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HomeMy WebLinkAbout13-4488 Supreme Court .of Pennsylvania Court Com " on Pleas �"� For Prothonotary Use Only: � ><vihCove� Sheet � CUM R0 %� 1i County Docket No: r �( itri ST,I The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by law or rules ofcourt. Commencement of Action: S 13 Complaint 9 Writ of Summons ❑ Petition ❑ Notice of Appeal ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: T Judi L. Ruby Shyamlata P. Patel I ❑ Check here if you are a Self - Represented (Pro Se) Litigant 0 Name of Plaintiff /Appellant Attorney: Leslie M. Fields, Esquire, Costopoulos, Foster & Fields, 831 Market Street, Lemoyne PA 17043 N Are money damages requested? : DYes 11 No Dollar Amount Requested: X within arbitration limits (Check one) outside arbitration limits A Is this a Class Action Suit? ❑ Yes [9 No Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Zoning Board S ❑ Product Liability (does not include ❑ Statutory Appeal: Other E mass tort) Employment Dispute: ❑ Slander/Libel/ Defamation Discrimination C ❑ Other: ❑Employment Dispute: Other , Judicial Appeals ❑ MDJ - Landlord /Tenant I ❑ Other: ❑ MDJ - Money Judgment O MASS TORT ❑ Other: ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration B ❑ Other: ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord /Tenant Dispute ❑ Non - Domestic Relations ❑ Mortgage Foreclosure Restraining Order PROFESSIONAL LIABLITY ❑ Partition ❑ Quo Warranto ❑ Dental ❑ Quiet Title ❑ Replevin ❑ Legal ❑ Medical ❑ Other: ❑ Other: ❑ Other Professional: Pa.R.C.P. 205.5 212010 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Judi L. Ruby 305 Walnut Street pp Carlisle, PA 17015 Case No. ��� y0 O Civil Term V. Civil Action Shyamlata P. Patel 47 Honeysuckle Avenue Mechanicsburg, PA 17050 =M C= Mme_. PRAECIPE FOR WRIT OF SUMMONS C/')r— w �` TO THE PROTHONOTARY /CLERK OF SAID COURT 'Co I> =© C: " C_' Issue summons in the above case. Cn Writ of Summons shall be issued and forwarded to Attorney /Sheriff. Date: C ;ig : natu of Attorney Print Name: Leslie M. Fields, Esquire Address: Costopoulos, Foster & Fields 831 Market Street Lemoyne, PA 17043 Telephone #: 717 - 761 -2121 Supreme Court ID Number: 29411 WRIT OF SUMMONS Q�a�3�ds To: �� ��� �a� YOU ARE NOTIFIED THAT THE ABOVE -NAMED PLAINTIFF(S) HAS /HAVE COMMENCED AN ACTION AGAINST YOU. Prothonotary/Clerk, Civil Division Date: Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY -., Ronny R Anderson + G--) � Sheriff ��. Jody S Smith , Chief Deputy Richard W Stewart "'t Solicitor QPP-CE CFT ESKRIFr - Judi Ruby Case Number vs. 2013-4488 Shyamalata P Patel SHERIFF'S RETURN OF SERVICE 08/05/2013 07:53 PM - Deputy Jeff Kolodzi, being duly sworn according to law, served the requested Writ of Summons by handing a true copy to a person representing themselves to be Parvin Patel, Husband,who accepted as"Adult Person in Charge"for Shyamalata P Patel at 47 Honeysuckle Avenue, Silver Spring, Mechanicsburg, PA 17050. JEF OL DZI, DEPUTY SHERIFF COST: $39.76 SO ANSWERS, August 06, 2013 RbNW R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoft,Inc. Johnson, Duffie, Stewart & Weidner BY: John A. Lucy, Esquire I.D. No. 203948 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jal@jdsw.com JUDI L. RUBY, • Plaintiff v. SHYAMLATA P. PATEL, Defendant PENNT !q Attorneys for Defendant, : IN THE COURT OF COMMON PLEAS OF • CUMBERLAND COUNTY, : PENNSYLVANIA CIVIL ACTION — LAW • NO. 13-4488 JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of Defendant, Shh amlata P. Patel, in the above -captioned matter. Date: May 2, 2014 620748 Respectfully submitted, JO r SON, DUFF ' EWART & WEIDNER ucy, Esquire Att •r ey I.D. No. 203948 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 jal@jdsw.com Counsel for Defendant, Shyamlata Patel CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Praecipe for Entry of Appearance has been duly served upon all counsel of record by depositing the same in the United States First Class Mail, postage prepaid, in Lemoyne, Pennsylvania, on May 2, 2014, as follows: Leslie M. Fields, Esquire Costopoulos, Foster & Fields 831 Market Street P.O. Box 222 Lemoyne, PA 17043-0222 Counsel for Plaintiff JOHNSO, , DUFFIE, STEWART & WEIDNER BY: 620748 • n . 6y, Esquire Johnson, Duffie, Stewart & Weidner BY: John A. Lucy, Esquire I.D. No. 203948 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jal@jdsw.com JUDI L. RUBY, Plaintiff v. Attorneys for Defendant, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA : CIVIL ACTION — LAW SHYAMLATA P. PATEL, Defendant : NO. 13-4488 JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Kindly issue a Rule on the Plaintiff, Judi L. Ruby, to file a Complaint within twenty (20) days of the date of service thereof, or suffer judgment of non pros. Date: May 2, 2014 620750 Respectfully submitte JOHNSON, DUFF , STEWART & WEIDNER BY: Jo,hr�A. Lucy, Esquire orney I.D. No. 203948 1 Market Street, P.O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 jal@jdsw.com Counsel for Defendant, Shyamlata Patel CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Praecipe for Rule to File Complaint has been duly served upon all counsel of record by depositing the same in the United States First Class Mail, postage prepaid, in Lemoyne, Pennsylvania, on May 2, 2014, as follows: Leslie M. Fields, Esquire Costopoulos, Foster & Fields 831 Market Street P.O. Box 222 Lemoyne, PA 17043-0222 Counsel for Plaintiff JOHNSO , DUFFIE, TEWART & WEIDNER y, Esquire 620750 Johnson, Duffie, Stewart & Weidner BY: John A. Lucy, Esquire I.D. No. 203948 301 Market Street P. 0. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jal@jdsw.com JUDI L. RUBY, Plaintiff v. Attorneys for Defendant, • IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — LAW SHYAMLATA P. PATEL, Defendant NO. 13-4488 JURY TRIAL DEMANDED RULE TO FILE COMPLAINT TO THE PLAINTIFF: You are hereby directed to file a Complaint in the above -captioned matter within 20 days or judgment non pros will be entered against you. DATE: 620750 PROTHONOTARY 1 Johnson, Duffie, Stewart & BY: John A. Lucy, Esquire I.D. No. 203948 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jal@jdsw.com Zi;"ILIf+i a" —Q PH 1: _+.: CUMBERLAND COUNT{, PENNSYLVANIA Weidner JUDI L. RUBY, Plaintiff v. SHYAMLATA P. PATEL, Defendant Attorneys for Defendant, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — LAW NO. 13-4488 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the Rule to File Complaint issued by the Court on May 5, 2014, has been duly served by depositing the same in the United States First Class Mail, postage prepaid, in Lemoyne, Pennsylvania, on May 7, 2014, as follows: 622350 Leslie M. Fields, Esquire Costopoulos, Foster & Fields 831 Market Street P.O. Box 222 Lemoyne, PA 17043-0222 Counsel for Plaintiff ------2 A true and correct copy of the transmittal letter is attach hereto as Exhibit "A". JOHNSON DUFF E STE & WEIDNER BY: John Lucy, Esquire Attorley I.D. No. 203948 301 arket Street, P.O. Box 109 Le oyne, PA 17043-0109 (7 7) 761-4540 jal@jdsw.com Counsel for Defendant, Shyamlata Patel JERRY R. DUFFLE RICHARD W STEWART EDMUND G. INNERS DAVID W. DELUCE JOHN A. STATLER JEFFREY B. RETTIG MARK C. DUFFLE JOHN R. NINOSKY MICHAEL J. CASSIDY MELISSA P. GREENY WADE D. MANLEY Leslie M. Fields, Esquire Costopoulos, Foster & Fields 831 Market Street P.O. Box 222 Lemoyne, PA 17043-0222 JOHN1SON� 1914-2014 May 7, 2014 Re: Judi L. Ruby v. Shyamlata P. Patel Cumberland County C.C.P.; No. 13-4488 Dear Ms. Fields: BARRIE B. GEHRLEIN ANTHONY T. LUCIDO CAROLYN B. MCCLAIN JOHN A. LUCY MATTHEW RIDLEY KAREN L. MASCIO OF COUNSEL HORACE A. JOHNSON C. ROY WEIDNER. JR. YA,t:r9'i 'S EYP. No. 15.1 Enclosed please find the Rule to File Complaint issued by the court on May 5, 2014. I look forward to receipt of the Complaint within twenty (20) days. JAUcsf 622356 22740-3197 Enclosure ry ti:- yours, JOHNSN, DU -FIE, STEWART & WEIDNER ohn'A. Lucy 301 MARKET STREET P.O. BOX I09 LEMOYNE, PENNSYLVANIA 170434109 WWW.JDSW.COM 717.761.4540 FAX: 717.761.3015 MAIL©JDSWCOM JOHNSON, DUFFIE, STEWART & WEIDNER, P.C. Johnson, Duffie, Stewart & Weidner BY: John A. Lucy, Esquire ID. No. 203948 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jal@jdsw.com JUDI L. RUBY, Plaintiff v. Attorneys for Defendant, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA : CIVIL ACTION — LAW SHYAMLATA P. PATEL, Defendant : NO. 13-4488 JURY TRIAL DEMANDED RULE TO FILE COMPLAINT TO THE PLAINTIFF: You are hereby directed to file a Complaint in the above -captioned matter within 20 days or judgment non pros will be entered against you. DATE:.411111UPPTI PROTHONO ARY - 177.1..TF7 C.:CPY F7',.'"i.r.,., PFC.07F1 In T.F,,,Lt;loily v,,flei•euf, I hE.re unto set 1 - ily hand. ME,' sea d of said Court at Ca6sle. Pa. 620750 . "-Hs _____5___ day of , 20 _Pi_ Prothonotan a_ cliaLsLo yJi 7:6T-1 11: CERTIFICATE NNCUMBERL��,P` ND RERc_,QUISITE TO SERVICE OF A SUBPOENA PESYL PURSUANT TO RULE 4009.22 IN THE MATTER OF: Court of Common Pleas - Cumberland County, PA JUDI RUBY vs. TERM: SITYAMLATA PATEL CASE No: 13-4488 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22. RecordTrak on behalf of JOHN LUCY Defendant certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) No objection to the subpoena has been received or it has been waived, and (3) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. Date : 05/30/2014 RecordTrak on behalf of /S/ JOHN LUCY Attorney for Defendant RT#: 266335 RECORDS PERTAIN TO: JUDI RUBY JUDI RUBY COURT: Court Of Common Pleas - Cumberland County, Pa vs.• TERM: SHYAMLATA PATEL NOTICE OF INTENT TO: LESLIE FIELDS, ESQUIRE COSTOPOULOS, FOSTER & FIELDS 831 MARKET ST LEMOYNE, PA 17043 (717) 761-2121 May 9, 2014 : DOCKET: 13-4488 TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS Please take notice that on behalf of JOHN LUCY, attorney for Defendant, RecordTrak intends to serve a subpoena identical to the one(s) attached to this notice. You have until May 29, 2014 to file of record and serve upon the undersigned an objection to the subpoena(s). If no objection is made, the subpoena(s) will be served. IF PLAINTIFF'S COUNSEL AGREES TO WAIVE THE 20 DAY NOTICE PERIOD, PLEASE INDICATE BELOW AND FAX SAME TO THE UNDERSIGNED AT YOUR EARLIEST OPPORTUNITY. IF YOU WISH TO PURCHASE COPIES OF THE RECORDS, PLEASE CONTACT RECORDTRAK FOR PRICING AND FAX THIS CORRESPONDENCE BY May 29, 2014 TO (610) 992-1405. All records will be provided (including no record statements) as produced by each record location. Daniel Wake 610.354.8348 RECORDTRAK 651 Allendale Road P. O. Box 61591 King of Prussia, PA 19406 LIST OF RECORD CUSTODIANS AND SUBPOENAS TAG 1 RECORD CUSTODIAN PINNACLE HEALTH FAMILY CARE SILVER SPRING MATERIALS BEING OBTAINED 1 . ALL MEDICAL RECORDS IN YOUR POSSESSION DATED 1/1/2006 TO PRESENT. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, RADIOLOGY REPORTS, PATHOLOGY REPORTS, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PATIENTS INFORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE SIGN THE ATTACHED CERTIFICATION AND RETURN WITH THE RECORDS.**************. 2 . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS DATED 1/1/2006 TO PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING.** JUDI RUBY vs. SHYAMLATA PATEL COURT: Court Of Common Pleas - Cumberland County, Pa TERM: DOCKET: 13-4488 2 PENN REHABILITATION 1 . ALL MEDICAL RECORDS IN YOUR POSSESSION DATED 1/1/2006 TO THE PRESENT . INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, RADIOLOGY REPORTS, PATHOLOGY REPORTS, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PATIENTS INFORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE SIGN THE ATTACHED CERI"I ICATION AND RETURN WITH THE RECORDS.************** 2 . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS DATED 1/1/2006 TO THE PRESENT . **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING.** ASSOCIATION, P.C. 3 CARLISLE REGIONAL 1 . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS DATED 1/1/2006 TO THE PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING.** **INCLUDING BUT NOT LIMITED TO RECORDS FROM KINETIC IMAGING. * * MEDICAL CENTER (RAD) 4 WEST SHORE EMS 1 . ANY AND ALL RECORDS REGARDING RESPONSE, TREATMENT AND TRANSPORT OF THE ABOVE NAMED INDIVIDUAL DATED FROM 10/6/11. 5 HOLY SPIRIT HOSPITAL 1 . ALL MEDICAL RECORDS IN YOUR POSSESSION DATED 1/1/2006 TO THE PRESENT. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, RADIOLOGY REPORTS, PATHOLOGY REPORTS, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PATIENTS INFORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE SIGN THE ATTACHED CERTIFICATION AND RETURN WITH THE RECORDS.************** (MED) 6 HOLY SPIRIT HOSPITAL 1 . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS DATED 1/1/2006 TO THE PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING. * * (RAD) 7 CARLISLE REGIONAL 1 . ALL MEDICAL RECORDS IN YOUR POSSESSION DATED 1/1/2006 TO THE PRESENT. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, RADIOLOGY REPORTS, PATHOLOGY REPORTS, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PATIENTS INFORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE SIGN THE ATTACHED CERTIFICATION AND RETURN WITH THE RECORDS.************** MEDICAL CENTER (MED) 9 PENN STATE MILTON S. 1 . ALL MEDICAL RECORDS IN YOUR POSSESSION DATED 1/1/2006 TO THE PRESENT. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, RADIOLOGY REPORTS, PATHOLOGY REPORTS, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PATIENTS INFORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE SIGN THE ATTACHED CERTIFICATION AND RETURN WITH THE RECORDS.************ HERSHEY MEDICAL CENTER (MED) 10 PENN STATE MILTON S. 1 . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS DATED 1/1/2006 TO THE PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING. * * HERSHEY MEDICAL CENTER (RAD) Page 2 JUDI RUBY COURT: Court Of Common Pleas - Cumberland County, Pa vs. SHYAMLATA PATEL TERM: DOCKET: 13-4488 11 WEISS PHYSICAL THERAPY 1 . ALL MEDICAL RECORDS IN YOUR POSSESSION DATED 1/1/2006 TO THE PRESENT. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, RADIOLOGY REPORTS, PATHOLOGY REPORTS, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PATIENTS INFORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE SIGN THE ATTACHED CER 1Ih ICATION AND RETURN WITH THE RECORDS.************** 2 . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS DATED 1/1/2006 TO THE PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING.** Yes, I would like a copy of all of the records listed above. Yes, I would like specific records I have indicated above. SIGNATURE: Date: FIRM: YES, I AGREE TO WAIVE THE 20 DAY NOTICE PERIOD FOR ALL SUBPOENAS ON THIS NOTICE Signature of Plaintiffs Counsel: Date: FIRM: EMAIL: Page 3 RT: 266335.1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JUDI RUBY `i. SITYAMLATA PATEL File No: 13-4488 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: PINNACLE HEALTH FAMILY CARE SILVER SPRING (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoena together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it, THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 220-1291 Supreme Court ID# Attorney for: Defendant DATE: s Seal of the Court BY THE COURT: RE: JUDI RUBY vs. SHYAMLATA PATEL CASE NO. 13-4488 RECORDTRAK FILE #: 266335; TAG 1 LOCATION: PINNACLE HEALTH FAMILY CARE SILVER SPRING RECORDS PERTAIN TO: JUDI RUBY SS #: , DOB: X . ALL MEDICAL RECORDS IN YOUR POSSESSION DATED X/X/XXXX TO PRESENT. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, RADIOLOGY REPORTS, PATHOLOGY REPORTS, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PATIENTS INFORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE SIGN THE ATTACHED CERTIFICATION AND RETURN WITH THE RECORDS.************** X . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS DATED X/X/XXXX TO PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING. * * RT: 266335.2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JUDI RUBY V. SITYAMLATA PATEL File No: 13-4488 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: PENN REHABILITATION ASSOCIATION, P.C. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoen; together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought, If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RecordTrak, JOHN LUCY Address: 651 Atndale Road King of Prussia PA 19406 Telephone: I00' 220-1291 Supreme Cour Attorney for: J4endant DATE: Seal of the Cou Itu I BY THE COURT: RE: JUDI RUBY vs. SHYAMLATA PATEL CASE NO. 13-4488 RECORDTRAK FILE #: 266335; TAG 2 LOCATION: PENN REHABILITATION ASSOCIATION, P.C. RECORDS PERTAIN TO: JUDI RUBY SS #: , DOB: X . ALL MEDICAL RECORDS IN YOUR POSSESSION DATED X/X/XXXX TO THE PRESENT . INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, RADIOLOGY REPORTS, PATHOLOGY REPORTS, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PATIENTS INFORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE SIGN THE ATTACHED CERTIFICATION AND RETURN WITH THE RECORDS.************** X . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS DATED X/X/XXXX TO THE PRESENT . **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING.** RE: JUDI RUBY vs. SHYAMLATA PATEL CASE NO. 13-4488 RECORDTRAK FILE #: 266335; TAG 3 LOCATION: CARLISLE REGIONAL MEDICAL CENTER (RAD) RECORDS PERTAIN TO: JUDI RUBY SS #: , DOB: X . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS DATED X/X/XXXX TO THE PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING.** **INCLUDING BUT NOT LIMITED TO RECORDS FROM KINETIC IMAGING. * * RT: 266335.4 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JUDI RUBY V. SHYAMLATA PATEL File No: 13-4488 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY_ PURSUANT TO RULE 4009.22 TO: WEST SHORE EMS (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoena together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought If you fail to produce the documents or things required by this subpoena within twenty (20) days ai'te its service, the party serving this subpoena may seek a court order compelling you to comply with ft. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (8001 220-129) Supreme Court ID# Attorney for: Defendant DATE: Seal of the Court BY THE COURT: RE: JUDI RUBY vs. SHYAMLATA PATEL CASE NO. 13-4488 RECORDTRAK FILE #: 266335; TAG 4 LOCATION: WEST SHORE EMS RECORDS PERTAIN TO: JUDI RUBY SS #: , DOB: X . ANY AND ALL RECORDS REGARDING RESPONSE, TREATMENT AND TRANSPORT OF THE ABOVE NAMED INDIVIDUAL DATED FROM XX/X/X1. RT: 266335.5 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JUDI RUBY V. SHYAMLATA PATEL File No: 13-4488 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSU}4NTJO RULE 4009.22 TO: HOLY SPIRIT HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoeni together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or produdug the things sought, If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (80Q1 220-1291. Supreme Court JD# Attorney for: Defendant DATE: Seal of the Court S)JIL BY THE COURT: RE: JUDI RUBY vs. SHYAMLATA PATEL CASE NO. 13-4488 RECORDTRAK FILE #: 266335; TAG 5 LOCATION: HOLY SPIRIT HOSPITAL (MED) RECORDS PERTAIN TO: JUDI RUBY SS #: , DOB: X . ALL MEDICAL RECORDS IN YOUR POSSESSION DATED X/X/XXXX TO THE PRESENT. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, RADIOLOGY REPORTS, PATHOLOGY REPORTS, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PA I LENTS INFORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE SIGN THE ATTACHED CERTIFICATION AND RETURN WITH THE RECORDS.************** RT: 266335.6 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JUDI RUBY V. SITYAMLATA PATEL File No: 13-4488 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: HOLY SPIRIT HOSPITAL Within twenty (20) days following documents or things: See attached rider. (Name of Person or Entity) er service of this subpoena, you are ordered by the Court to produce the at 631 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoena together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RccordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: , (8Q01220-1;91 Supreme Court ID# Attorney for: Defendant DATE: Seal of the Court BY THE COURT: RE: JUDI RUBY vs. SHYAMLATA PATEL CASE NO. 13-4488 RECORDTRAK FILE #: 266335; TAG 6 LOCATION: HOLY SPIRIT HOSPITAL (RAD) RECORDS PERTAIN TO: JUDI RUBY SS #: , DOB: X . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS DATED X/X/XXXX TO THE PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING.** RT: 266335.7 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JUDI RUBY v. SHYAMLATA PATEL File Na: 13-4488 SUBPOENA TQ PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CARLISLE REGIONAL MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You inay deliver or mail legible copies of the documents or produce things requested by this subpoena together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought. If you fail to produce the documents or things required by thisbpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (p001220-129 1 Supreme Court ID# Attorney for: Defendant DATE: Seal of the Court BY THE COURT: RE: JUDI RUBY vs. SHYAMLATA PATEL CASE NO. 13-4488 RECORDTRAK FILE #: 266335; TAG 7 LOCATION: CARLISLE REGIONAL MEDICAL CENTER (MED) RECORDS PERTAIN TO: JUDI RUBY SS #: , DOB: X . ALL MEDICAL RECORDS IN YOUR POSSESSION DATED X/X/XXXX TO THE PRESENT. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, RADIOLOGY REPORTS, PATHOLOGY REPORTS, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PATIENTS INFORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE SIGN THE ATTACHED CERTIFICATION AND RETURN WITH THE RECORDS.************** RT: 266335.9 7 /o COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JUDI RUBY V. SHYAMLATA PATEL File No: 13-4488 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: PENN STATE MILTON S. HERSHEY MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoena together with the certificate of compliance, to the party making this request at the address listed above, You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after Its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 220-1291 Supreme Court ID# Attorney for: Defendant DATE: Seal of the Court ‹)noli BY THE COURT: RE: JUDI RUBY vs. SHYAMLATA PATEL CASE NO. 13-4488 RECORDTRAK FILE #: 266335; TAG 9 LOCATION: PENN STATE MILTON S. HERSHEY MEDICAL CENTER (MED) RECORDS PERTAIN TO: JUDI RUBY SS #: , DOB: X . ALL MEDICAL RECORDS IN YOUR POSSESSION DATED X/X/XXXX TO THE PRESENT. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, RADIOLOGY REPORTS, PATHOLOGY REPORTS, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PATIENTS INFORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE SIGN THE ATTACHED CERTIFICATION AND RETURN WITH THE RECORDS.************ RT: 266335.10 q /o COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JUDI RUBY V. SHYAMLATA PATEL File No: 13-4488 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: PENN STATE MILTON S. HERSHEY MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoen: together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 220-1291 Supreme Court IDtt Attorney for: Defendant DATE: Seal of the Court ‹), Lo/p/ BY THE COURT: RE: JUDI RUBY vs. SHYAMLATA PATEL CASE NO. 13-4488 RECORDTRAK FILE #: 266335; TAG 10 LOCATION: PENN STATE MILTON S. HERSHEY MEDICAL CENTER (RAD) RECORDS PERTAIN TO: JUDI RUBY SS #: , DOB: X . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS DATED X/X/XXXX TO THE PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING. * * RT: 266335.11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JUDI RUBY V. SHYAMLATA PATEL File No:13-4488 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: WEISS PHYSICAL THERAPY (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoens together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought, If you fail to produce the documents or things required by this subpoena within twenty (20) days afte its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RccordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (8001 220-1291 Supreme Court ID# Attorney for: Defendant DATE: Seal of the Court BY THE COURT: RE: JUDI RUBY vs. SHYAMLATA PATEL CASE NO. 13-4488 RECORDTRAK FILE #: 266335; TAG 11 LOCATION: WEISS PHYSICAL THERAPY RECORDS PERTAIN TO: JUDI RUBY SS #: , DOB: X . ALL MEDICAL RECORDS IN YOUR POSSESSION DATED X/X/XXXX TO THE PRESENT. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, RADIOLOGY REPORTS, PATHOLOGY REPORTS, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PATIENTS INFORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE SIGN THE ATTACHED CER 11TH ICATION AND RETURN WITH THE RECORDS.************** X'. ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS DATED X/X/XXXX TO THE PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING.** 0 COSTOPOULOS, FOSTER & FIELDS By: Leslie M. Fields, Esquire I.D. No.: 29411 831 Market Street Lemoyne, PA 17043 Tel: 717.761.2121 Fax: 717.761.4031 Email:. LfieldsnCostopoulos.com JUDI L. RUBY, _ 1-ILED r JC I{E PR T f.HON T; iy JUN -4 PH 12: 54 CUMBERLAND COUNTY PENNSYLVANIA : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2013-4488 SHYAMLATA P. PATEL, : CIVIL ACTION - LAW Defendant NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff(s). You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE: LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 PHONE: (717) 249-3166 OR (800) 990-9108 JUDI L. RUBY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No.2013-4488 SHYAMLATA P. PATEL, : CIVIL ACTION - LAW Defendant PLAINTIFF'S COMPLAINT AND NOW comes the Plaintiff, Judi L. Ruby, by and through her attorney, Leslie M. Fields, Esquire, COSTOPOULOS, FOSTER & FIELDS, and respectfully represents as follows in support of this Complaint: The Parties 1. Plaintiff, Judi L. Ruby, is an adult individual residing at 305 Walnut Lane, Carlisle, Cumberland County, Pennsylvania 17015-7861. 2. Defendant, Shyamlata P. Patel, is an adult individual residing at 47 Honeysuckle Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050-3166. Background Allegations 3. The events giving rise to this cause of action occurred approximately at 11:12 p.m. on or about October 6, 2011 on East Main Street (State Route 641) near the intersection with South Chestnut Street in the Borough of Mechanicsburg, Cumberland County, Pennsylvania. 4. At the aforesaid time and place, Plaintiff, Judi L. Ruby, was a front -seat passenger in the vehicle operated by her son, Steven A. Ruby. 5. At the aforesaid time and place, Steven A. Ruby was operating a 2002 Pontiac Sunfire automobile and traveling eastbound on East Main Street when Defendant, Shyamlata P. Patel, who was operating a 2002 Toyota Sequoia SUV and traveling westbound on East Main Street, crossed over into Mr. Ruby's lane of traffic and struck the Plaintiff's vehicle head-on, thereby causing the serious injuries and damages set forth in detail below. 6. As a direct and proximate result of the negligence, carelessness and/or recklessness of the Defendant, Shyamlata P. Patel, the Plaintiff, Judi L. Ruby, has suffered serious injuries and damages which are set forth in detail below. 7. The negligence, carelessness and/or recklessness of the Defendant, Shyamlata P. Patel, was a substantial factor in causing the serious injuries and damages to the Plaintiff, Judi L. Ruby, which are set forth in detail below. NEGLIGENCE Plaintiff Judi L. Ruby v. Defendant Shyamlata P. Patel 8. The allegations set forth in paragraphs 1 through 7 above are incorporated by reference herein as if set forth in full. 9. At the aforesaid time and place, the collision and injuries resulting therefrom were caused by the negligent, careless and/or reckless acts of the Defendant, Shyamlata P. Patel, in that she: a) operated her motor vehicle in careless disregard for the safety of persons and property, particularly the Plaintiff, Judi L. Ruby, and the -2- vehicle and its operator, Steven A. Ruby, and another passenger; b) violated Section 3714(a) of the Pennsylvania Motor Vehicle Code, 75 Pa.C.S. § 3714(a), "Careless driving; General rule," and thus is negligent per se; c) caused the serious bodily injury of another person, specifically, Plaintiff, Judi L. Ruby, as a result of the violation of Section 3714(a) of the Pennsylvania Motor Vehicle Code; d) violated Section 3714[c] of the Pennsylvania Motor Vehicle Code, 75 Pa.C.S. § 3714[c], "Careless driving; Serious bodily injury," and thus is negligent per se; e) drove carelessly; f) engaged in distracted driving; g) failed to notice that the Plaintiff's vehicle was in the opposing lane of traffic; h) failed to maintain her vehicle under proper and lawful control; small I) failed to keep a proper lookout; j) failed to pay sufficient attention to the roadway and traffic; k) failed to see what she should have seen; 1) failed to notice the imminence of an accident and take the necessary steps to avoid it; and m) acted without due regard for the safety and rights of other -3- motorists and passengers, including the Plaintiff, Judi L. Ruby. 10. As a direct and proximate result of the negligent, careless and/or reckless acts of the Defendant, Shyamlata P. Patel, the Plaintiff, Judi L. Ruby, has suffered injuries which were and are severe, painful, serious and permanent. These injuries include but are not limited to: a) a serious lumbar strain and sprain; b) serious muscle spasms; c) pain radiating down the side of her left leg to the lower part of the leg; d) and a right knee contusion and pain. 11. As a further direct and proximate result of the negligent, careless and/or reckless acts of the Defendant, Shyamlata P. Patel, the Plaintiff, Judi L. Ruby, has been obligated to receive and undergo medical treatment and care and to assume medical expenses for the injuries she has suffered, and may be obligated to continue to receive and undergo such medical treatment and care and to assume medical expenses in the future. 12. As a further direct and proximate result of the negligent, careless and/or reckless acts of the Defendant, Shyamlata P. Patel, the Plaintiff, Judi L. Ruby, has sustained a loss of earnings and a loss of earnings capacity, and may continue to sustain such loss of earnings and loss of earnings capacity in the future. 13. As a further direct and proximate result of the negligent, careless and/or reckless acts of the Defendant, Shyamlata P. Patel, the Plaintiff, Judi L. Ruby, has -4- suffered medically determinable physical impairments which have prevented her from performing all of the normal acts and duties which constitute her usual and customary daily activities, and may continue to suffer such medically determinable physical impairments in the future. 14. As a further direct and proximate result of the negligent, careless and/or reckless acts of the Defendant, Shyamlata P. Patel, the Plaintiff, Judi L. Ruby, has experienced severe pain and suffering, mental anguish and humiliation, and may continue to experience such severe pain and suffering, mental anguish and humiliation in the future. 15. As a further direct and proximate result of the negligent, careless and/or reckless acts of the Defendant, Shyamlata P. Patel, the Plaintiff, Judi L. Ruby, has suffered a loss of life's pleasures, and may continue to suffer such a loss of life's pleasures in the future. 16. As a further direct and proximate result of the negligent, careless and/or reckless acts of the Defendant, Shyamlata P. Patel, the Plaintiff, Judi L. Ruby, has sustained certain incidental costs, and may continue to sustain such certain incidental costs in the future. -5- Conclusion WHEREFORE, Plaintiff, Judi L. Ruby, based on the foregoing averments, hereby demands judgment in her favor and against Defendant, Shyamlata P. Patel, in an amount within the compulsory arbitration limits together with costs and interest as provided by law. DATED: June 4, 2014 RESPECTFULLY SUBMITTED: Leslie M. Fields, Esquire I.D. No. 29411 Glc@ COSTOPOULOS, FOSTER & FIELDS 831 Market Street Lemoyne, Pennsylvania 17043 Phone: 717.761.2121 Fax: 717.761.4031 Email: Lfields@Costopoulos.com Web: www.Costopoulos.com ATTORNEY FOR PLAINTIFF -6- VERIFICATION I, Leslie M. Fields, Esquire, aver that I am the attorney for the answering Plaintiff in this case, and I aver that the averments contained in the foregoing pleadings are true and correct to the best of my knowledge, information and belief; and that the statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ie M. , ields, Esquire CERTIFICATE OF SERVICE I, Leslie M. Fields, Esquire, of Costopoulos, Foster & Fields, do hereby certify on this 4th day of June, 2014, a true and correct copy of the foregoing Plaintiffs Complaint was served upon all counsel of record by: Hand Delivery X First Class Mail, Postage Pre -Paid Certified Mail, Return Receipt Requested Fax Transmission Overnight Mail at the following address(es) and/or number(s): John A. Lucy, Esquire JOHNSON, DUFFIE, STEWART & WEIDNER, P.C. 301 Market Street P.O. Box 109 Lemoyne, PA 17043 Counsel for Defendant, Shyamlata P. Patel BY: COSTOPOULOS, FOSTER & FIELDS COSTOPOULOS, FOSTER & FIELDS By: Leslie M. Fields, Esquire I.D. No.: 29411 831 Market Street Lemoyne, PA 17043 Tel: 717.761.2121 Fax: 717.761.4031 Email: Lfields( Costopoulos.com JUDI L. RUBY, Plaintiff v. tvl'r ���Fq —b Pii I C UM�� r`c� ' �- PE�aI; S YL VCOUNT�, • : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No.2013-4488 SHYAMLATA P. PATEL, : CIVIL ACTION - LAW Defendant PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached verification of the Plaintiff, Judi L. Ruby, for that of counsel with respect to Plaintiff's Complaint. DATED: June 5, 2014 COSTOPOULOS, FOSTER & FIELDS eslie M. ields, Esquire I.D. No. 29411 COSTOPOULOS, FOSTER & FIELDS 831 Market Street Lemoyne, Pennsylvania 17043 Phone: 717.761.2121 Fax: 717.761.4031 Email: Lfields@Costopoulos.com Web: www.Costopoulos.com ATTORNEY FOR PLAINTIFF VERIFICATION I, Plaintiff, Judi L. Ruby, do hereby verify that the facts set forth in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that this statement is made subject to the penalties at 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. BY: DATED: June , 2014 -7- CERTIFICATE OF SERVICE I, Leslie M. Fields, Esquire, of Costopoulos, Foster & Fields, do hereby certify on this 5th day of June, 2014, a true and correct copy of the foregoing Praecipe to Substitute Verification was served upon all counsel of record by: Hand Delivery X First Class Mail, Postage Pre -Paid Certified Mail, Return Receipt Requested Fax Transmission Overnight Mail at the following address(es) and/or number(s): John A. Lucy, Esquire JOHNSON, DUFFIE, STEWART & WEIDNER, P.C. 301 Market Street P.O. Box 109 Lemoyne, PA 17043 Counsel for Defendant, Shyamlata P. Patel BY: COSTOPOULOS, FOSTER & FIELDS Leslie Fields Johnson, Duffle, Stewart &Weidner ', `u {,. 1;: u,y BY: John A. Lucy, Esquire I.D. No. 203948 '''''''L''"''5 r` C�,1';' I {, Attorneys for Defendant, 301 Market Street is ` Eta, Shyamlata P. Patel P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jal@jdsw.com JUDI L. RUBY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, : PENNSYLVANIA v. . : NO. 13-4488 SHYAMLATA P. PATEL, . Defendant : CIVIL ACTION — LAW : JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Plaintiff c/o Leslie M. Fields, Esquire Costopoulos, Foster& Fields 831 Market Street P.O. Box 222 Lemoyne, PA 17043-0222 AND NOW, this \"day of June, 2014, you are hereby notified to plead responsively within twenty (20) days of the date of - ice hereof, or judgment may be entered against you. Respe ully su•mitted, JOH SON, DU' FIE, STEW A = & WEIDNER BY: AA John - . J ucy, Esquire As .meI.D. No. 203948 01 M. , et Street, P.O. Box 109 Lemoy e, PA 17043-0109 (717) 761-4540 jal@jdsw.com Counsel for Defendant, Shyamlata P. Patel SEMP..116adigNMytn Johnson, Duffie, Stewart&Weidner BY: John A. Lucy, Esquire I.D. No. 203948 Attorneys for Defendant, 301 Market Street Shyamlata P. Patel P. 0. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jal@jdsw.corn JUDI L. RUBY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, : PENNSYLVANIA v. : NO. 13-4488 SHYAMLATA P. PATEL, Defendant : CIVIL ACTION — LAW : JURY TRIAL DEMANDED ANSWER AND NEW MATTER OF DEFENDANT, SHYAMLATA P. PATEL, TO PLAINTIFF'S COMPLAINT AND NOW, comes Defendant, Shyamlata P. Patel, by and through his counsel, John A. Lucy, Esquire and Johnson, Duffie, Stewart & Weidner, P.C., and files the following Answer and New Matter to Plaintiff's Complaint. The Parties 1. After reasonable investigation, Defendant is without knowledge or information to form a belief as to the truth or falsity of the averments contained in Paragraph 1 and the same is therefore denied and strict proof is demanded at the time of trial. 2. Admitted. Background Allegations 3. Admitted. 4. After reasonable investigation, Defendant is without knowledge or information to form a belief as to the truth or falsity of the averments contained in Paragraph 4 and the same is therefore denied and strict proof is demanded at the time of trial. 5. Admitted in part, and denied in part. It is admitted that the accident occurred on the time, date and place averred. As to the remainder of the allegations, after reasonable investigation, Defendant is without knowledge or information to form a belief as to the truth or falsity of the averments contained in Paragraph 5 and the same is therefore denied and strict proof is demanded at the time of trial. 6. Paragraph 6 sets forth a legal conclusion to which no response is required. To the extent a response is deemed necessary, said averments are denied and strict proof thereof is demanded at the time of trial. 7. Paragraph 7 sets forth a legal conclusion to which no response is required. To the extent a response is deemed necessary, said averments are denied and strict proof thereof is demanded at the time of trial. NEGLIGENCE Plaintiff, Judi L. Ruby v. Defendant, Shvamlata P. Patel 8. Defendant incorporates herein by reference his answers to Paragraphs 1 through 7 above as though fully set forth herein at length. 9. (a) — (m) Paragraph 9 and all of its subparts set forth a legal conclusion to which no response is required. To the extent a response is deemed necessary, said averments are denied and strict proof thereof is demanded at the time of trial. • •,•. • • ••- - 10. (a) — (d) Paragraph 10 and all of its subparts set forth a legal conclusion to which no response is required. To the extent a response is deemed necessary, said averments are denied and strict proof thereof is demanded at the time of trial. 11. Paragraph 11 sets forth a legal conclusion to which no response is required. To the extent a response is deemed necessary, said averments are denied and strict proof thereof is demanded at the time of trial. 12. Paragraph 12 sets forth a legal conclusion to which no response is required. To the extent a response is deemed necessary, said averments are denied and strict proof thereof is demanded at the time of trial. 13. Paragraph 13 sets forth a legal conclusion to which no response is required. To the extent a response is deemed necessary, said averments are denied and strict proof thereof is demanded at the time of trial. 14. Paragraph 14 sets forth a legal conclusion to which no response is required. To the extent a response is deemed necessary, said averments are denied and strict proof thereof is demanded at the time of trial. 15. Paragraph 15 sets forth a legal conclusion to which no response is required. To the extent a response is deemed necessary, said averments are denied and strict proof thereof is demanded at the time of trial. 16. Paragraph 16 sets forth a legal conclusion to which no response is required. To the extent a response is deemed necessary, said averments are denied and strict proof thereof is demanded at the time of trial. WHEREFORE, Defendant, Shyamlata P. Patel, respectfully requests that judgment be entered in his favor and that Plaintiffs Complaint be dismissed with prejudice. NEW MATTER 17. That Plaintiff's alleged cause of action may be barred in whole or in part by the Pennsylvania Motor Vehicle Financial Responsibility Law. 18. That Plaintiff's alleged cause of action may be barred by the Pennsylvania Motor Vehicle Financial Responsibility Law and the limited tort option. 19. That Plaintiff's alleged cause of action may be barred in whole or in part by the applicable statute of limitations. 20. That the Plaintiff's alleged cause of action may be barred in whole or in part by the Plaintiffs own comparative negligence and the Pennsylvania Comparative Negligence Act. 21. That if it should be found that there is any negligence on the part of Mr. Patel, which is denied, then in that event, any such negligence is not a factual cause of Plaintiff's harm. 22. That Plaintiff's alleged injuries may have been pre-existing. 23. That Plaintiffs may have failed to mitigate their alleged injuries. 24. That Plaintiff's alleged cause of action may have been caused in whole or in part by third parties or entities not presently involved in this action. 25. The accident may have been the result of a medical emergency. WHEREFORE, Defendant, Shyamlata P. Patel, respectfully requests that judgment be entered in his favor and that Plaintiff's Complaint be dismissed with prejudice. Respectfully sub •*.ed, JOHNSO.,, DUFF , STEWART & WEIDNER BY: ohn A ucy, Esquire Attornp ID. No. 203948 301 ryi rket Street, P.O. Box 109 Lemp, ne, PA 17043-0109 (717/ 761-4540 jal ejdsw.com Counsel for Defendant, Date: June , 2014 Shyamlata P. Patel 632736 VERIFICATION I, Shyamlata P. Patel, hereby acknowledge that I am the Defendant in this action; that I have read the foregoing Answer and New Matter to Plaintiffs Complaint; and that the facts stated therein are true and correct to the best of my knowledge, information and belief, understand that any false statements herein are made subject to penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. Shyamlata P. Patel Dated: , 2014 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Answer and New Matter to Plaintiff's Complaint has been duly served upon all counsel of record and unrepresented parties by depositing the same in the United States First Class Mail, postage prepaid, in Lemoyne, Pennsylvania, on June 1°\ , 2014, as follows: Leslie M. Fields, Esquire Costopoulos, Foster & Fields 831 Market Street P.O. Box 222 Lemoyne, PA 17043-0222 Counsel for Plaintiffs JOH ON, DUF' IE, STEWART & WEIDNER BY nA. 1 cy ..-1 I . _ COSTOPOULOS,FOSTER& FIELDS I '''!''' '23 r - Counsel for Plaintiff By: Leslie M. Fields, Esquire .!:BFRi / IiD.No.: 29411 /.., -Ai' imJo ENt,/,3 YI: U 831 Market Street VA 'u iliI ,A 1 Lemoyne,PA 17043 Tel: 717.761.2121 Fax: 717.761.4031 Email: Lfields(&,Costopoulos.com JUDI L. RUBY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 2013-4488 SHYAMLATA P. PATEL, : CIVIL ACTION - LAW Defendant REPLY TO NEW MATTER AND NOW come the Plaintiff, by and through her attorney, and replies as follows: 17. through 25. To the extent these allegations constitute conclusions of law, no response is required. Any factual allegations are Denied. WHEREFORE, Plaintiff respectfully requests that judgment be entered in her favor and against Defendant, Shyamlata P. Patel, in an amount within the compulsory arbitration limits. COSTOPOULOS, FOSTER& FIELDS ,••"" Leslie M. ,"elds, Esquire I.D. No. 29A 1 COSTOPOULOS, FOSTER& FIELDS 831 Market Street Lemoyne, Pennsylvania 17043 Phone: 717.761.2121 Fax: 717.761.4031 Email: Lfields@Costopoulos.com Web: www.Costopoulos.com ATTORNEY FOR PLAINTIFF DATED: June 20, 2014 CERTIFICATE OF SERVICE I, Leslie M. Fields, Esquire, of Costopoulos, Foster& Fields, do hereby certify on this 20th day of June, 2014, a true and correct copy of the foregoing Praecipe to Substitute Verification was served upon all counsel of record by: Hand Delivery X First Class Mail, Postage Pre-Paid Certified Mail, Return Receipt Requested Fax Transmission Overnight Mail at the following address(es) and/or number(s): John A. Lucy, Esquire JOHNSON, DUFFIE, STEWART& WEIDNER, P.C. 301 Market Street P.O. Box 109 Lemoyne, PA 17043 Counsel for Defendant, Shyamlata P. Patel BY: COSTOPOULOS, FOSTER& FIELDS ./ Leslie M. ields • O 4cP OTHONCOTA JUL 14 PM 2: U 1 CERTIFICATE CUMBERLAND COUITIRREQUISITE TO SERVICE OF A SUBPOENA PENNSYLVANIA PURSUANT TO RULE 4009.22 IN THE MATTER OF: Court of Common Pleas - Cumberland County, PA JUDI RUBY vs. TERM: SHYAMLATA PATEL CASE No: 13-4488 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22. RecordTrak on behalf of JOHN LUCY Defendant certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) No objection to the subpoena has been received or it has been waived, and (3) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. Date : 07/08/2014 RecordTrak on behalf of /S/ JOHN LUCY Attorney for Defendant RT#: 266335 RECORDS PERTAIN TO: JUDI RUBY JUDI RUBY COURT: Court Of Common Pleas - Cumberland County, Pa vs. TERM: SHYAMLATA PATEL NOTICE OF INTENT TO: LESLIE FIELDS, ESQUIRE COSTOPOULOS, FOSTER & FIELDS 831 MARKET ST LEMOYNE, PA 17043 (717) 761-2121 May 13, 2014 DOCKET: 13-4488 TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS Please take notice that on behalf of JOHN LUCY, attorney for Defendant, RecordTrak intends to serve a subpoena identical to the one(s) attached to this notice. You have until June 2, 2014 to file of record and serve upon the undersigned an objection to the subpoena(s). If no objection is made, the subpoena(s) will be served. IF COUNSEL AGREES TO WAIVE THE 20 DAY NOTICE PERIOD, PLEASE INDICATE BELOW AND FAX SAME TO THE UNDERSIGNED AT YOUR EARLIEST OPPORTUNITY. IF YOU WISH TO PURCHASE COPIES OF THE RECORDS, PLEASE CONTACT RECORDTRAK FOR PRICING AND FAX THIS CORRESPONDENCE BY June 2, 2014 TO (610) 992-1405. All records will be provided (including no record statements) as produced by each record location. Daniel Wake 610.354.8348 RECORDTRAK 651 Allendale Road P. O. Box 61591 King of Prussia, PA 19406 LIST OF RECORD CUSTODIANS AND SUBPOENAS TAG 12 RECORD CUSTODIAN JOYNER SPORTS MEDICINE INSTITUTE Yes, I would like a copy of all of the records listed above. Yes, I would like specific records I have indicated above. SIGNATURE: FIRM: Date: YES, I AGREE TO WAIVE THE 20 DAY NOTICE PERIOD FOR ALL SUBPOENAS ON THIS NOTICE Signature of Plaintiff's Counsel: Date: FIRM: EMAIL: RT: 266335.12 I� COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND 'LTD' RUBY V. SHYAMLATA PATEL File No: 13-4488 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: JOYNER SPORTS MEDICINE INSTITUTE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 220-1291 BY THE COURT: Supreme Court ID# Attorney for: Defendant. Prothonotary RE: JUDI RUBY vs. SHYAMLATA PATEL CASE NO. 13-4488 RECORDTRAK FILE #: 266335; TAG 12 LOCATION: JOYNER SPORTS MEDICINE INSTITUTE RECORDS PERTAIN TO: JUDI RUBY SS #: , DOB: X . ALL MEDICAL RECORDS IN YOUR POSSESSION. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, RADIOLOGY REPORTS, PATHOLOGY REPORTS, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PA I LENTS INFORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE SIGN THE ATTACHED CERTIFICATION AND RETURN WITH THE RECORDS.************** JUDI RUBY DOB: XX/XX/XX, SS# XXX-XX-XXXX, ALL RECORDS FROM X/X/XXXX TO PRESENT.X.. ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING.** JUDI RUBY DOB: XX/XX/XX, SS# XXX-XX-XXXX, ALL RECORDS FROM X/X/XXXX TO PRESENT. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MAI I ER OF: JUDI RUBY vs. SHYAMLATA PATEL = C=▪ 3• ▪ -11 zrhl rT1' ±-• r -- z ,.. --I -,▪ ,- -< X" r- < C3 > h Court of Common Pleas - Cumberland Capizt=PA ..-- = • • TERM: -.< c) CASE No: 13-4488 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22. RecordTrak on behalf of JOHN LUCY Defendant certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) No objection to the subpoena has been received or it has been waived, and (3) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. Date : 10/03/2014 RecordTrak on behalf of /S/ JOHN LUCY Attorney for Defendant RT#: 266335 RECORDS PERTAIN TO: JUDI RUBY JUDI RUBY COURT: Court Of Common Pleas - Cumberland County, Pa vs. TERM: SHYAMLATA PATEL NOTICE OF INTENT TO: LESLIE FIELDS, ESQUIRE COSTOPOULOS, FOSTER & FIELDS 831 MARKET ST LEMOYNE, PA 17043 (717) 761-2121 September 12, 2014 : DOCKET: 13-4488 TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS Please take notice that on behalf of JOHN LUCY, attorney for Defendant, RecordTrak intends to serve a subpoena identical to the one(s) attached to this notice. You have until October 2, 2014 to file of record and serve upon the undersigned an objection to the subpoena(s). If no objection is made, the subpoena(s) will be served. IF COUNSEL AGREES TO WAIVE THE 20 DAY NOTICE PERIOD, PLEASE INDICATE BELOW AND FAX SAME TO THE UNDERSIGNED AT YOUR EARLIEST OPPORTUNITY. IF YOU WISH TO PURCHASE COPIES OF THE RECORDS, PLEASE CONTACT RECORDTRAK FOR PRICING AND FAX THIS CORRESPONDENCE BY October 2, 2014 TO (610) 992-1405. All records will be provided (including no record statements) as produced by each record location. Daniel Wake 610.354.8348 RECORDTRAK 651 Allendale Road P. O. Box 61591 King of Prussia, PA 19406 LIST OF RECORD CUSTODIANS AND SUBPOENAS TAG 13 RECORD CUSTODIAN SILVER CREEK FAMILY HEALTH CENTER Yes, I would like a copy of all of the records listed above. Yes, I would like specific records I have indicated above. SIGNATURE: FIRM: Date: YES, I AGREE TO WAIVE THE 20 DAY NOTICE PERIOD FOR ALL SUBPOENAS ON THIS NOTICE Signature of Plaintiff's Counsel: Date: FIRM: EMAIL: RT: 266335.13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JUDI RUBY V. SHYAMLATA PATEL File No: 13-4488 SUpPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 400122 TO: SILVER CREEK FAMILY HEALTH CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoena together with the certificate of compliance, to the party making this request at the address listed above, You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought, If you fail to produce the documents or things required by this subpoena within twenty (20) days ate its service, the party serving this subpoena may seek a court order compelling you to comply with it, THIS SUBPOENA WAS ISSUED. AT THE REQUEST OF THE FOLLOWING PERSON: Name; RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: ( 8001220-1291 Supreme Court ID# Attorney for: Defendant DATE: Seal of the Court BY THE COURT: 15 J1 RE: JUDI RUBY vs. SHYAMLATA PATEL CASE NO. 13-4488 RECORDTRAK FILE #: 266335; TAG 13 LOCATION: SILVER CREEK FAMILY HEALTH CENTER RECORDS PERTAIN TO: JUDI RUBY SS #: , DOB: X . ALL MEDICAL RECORDS IN YOUR POSSESSION DATED X/X/XXXX TO PRESENT.. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, RADIOLOGY REPORTS, PATHOLOGY REPORTS, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PATIENTS INFORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE SIGN THE ATTACHED CERTIFICATION AND RETURN WITH THE RECORDS.**************