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Home My WebLink About05-0192 ANNETTE D. COMP, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. 2005- /9 J.... CIVIL TERM FELIPE RODRIGUEZ, Defendant CIVL ACTION - LAW PRAECIPE FOR ISSUANCE OF A WRIT OF SUMMONS TO CURTIS R. LONG, PROTHONOTARY: Please issue a Writ of Summons against the defendant, FELIPE RODRIGUEZ, and enter my appearance on behalf of the plaintiff, ANNETTE D. COMPo Please direct the Sheriff to serve the defendant as follows: FELIPE RODRIGUEZ 104 LOUISA LANE MECHANICSBURG, P A 17055 Respectfully submitted, By: J.D. No: 25476 Date: January 10, 2005 To: FELIPE RODRIGUEZ You are hereby notified that Annette D. Comp, plaintiff, has co. m=nced an ~71'. t you which you are requUed to defend 0' a default judgment may be entered fft you. ~_ JA/lL:R~~ON08'v B~ a~. op_Ln1~ ni:~~y Date:J:J0 LD , 2005 'i~ <0 lrt ~ co ~ ~ {Q. o ~ -u F ~ -----z ~ ! ~t~ ,....or.., .....- \. rn t~!; ~ : z 11 ~.] (""' ~7:L C ';~~j~ - ~ ..' ~: C:~":':;:)l"'~'~~~ .~-'-t ' '= j~ :::-.. r:-? ~;:~ , <...~) ~....:'... --~ c~. SHERIFF'S RETURN - OUT OF COUNTY .' ~ t CASE NO: 2005-00192 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COMP ANNETTE D VS RODRIGUEZ FELIPE R, Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: RODRIGUEZ FELIPE but was unable to locate Him in his bailiwick, He therefore deputized the sheriff of LEBANON County, Pennsylvania, to serve the within WRIT OF SUMMONS On February 3rd, 2005 , this office was in receipt of the attached return from LEBANON Sheriff's Costs: Docketing Out of County Surcharge Mileage Dep Lebanon County So ans r~ ' --~-----: -_/ we _,~'..;-.'> ~.;::: ___-'~ ~.." .... "-. -,,"<,~ -p"''' R~~~~~==- --- Sheriff of Cumberland County 18.00 9.00 10.00 8,88 30,53 76,41 02/03/2005 MARCUS MCKNIGHT Sworn and subscribed to before me A this i!~ day of J.tL; .:2iJ-O{ A,D. (N,J)~ $- prothonotar'fr .' Ih The Court of Common Pleas of Cumberland County, Pennsylvania Annette D. Canp VS, Felipe Rodriguez 05-192 civil No. Now, January 19. 2005 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of County to execute this Writ, this Lebanon deputation being made at the request and risk of the Plaintiff. ~.,..., ...J.7 ^ .' ^", ~;.' _.'" +"" ~~~71. ~ ,,~~..-~l'...:t ./f'" ,:..."'~-:,,-I> ~ ".r' ~,.,." """,,,," . . Sheriff of Cumberland County, PA Affidavit of SeI~Tice Now, ,20_, at o'clock M, served the within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sheriff of County, P A Sworn and subscribed before me this _ day of ,20_ COSTS SERVICE MILEAGE AFFIDA VIT $ $ . . WRIT OF SUMMONS Annette D. Comp Marcus A. McKnight, III, Esquire Irwin & McKnight 60 W. Pomfret Street Carlisle, P A 17013 (717) 249-2353 VS. Felipe Rodriguez Return to Cumberland County No. 2005-192 Docket Page 21701 STATE OF PENNSYLVANIA COUNTY OF LEBANON } } SS: David A. Heath, Deputy Sheriff, being duly sworn according to law, deposes and says that he served the within WRIT OF SUMMONS upon FELIPE RODRIGUEZ, the within named DEFENDANT, by handing a true and attested copy thereof, personally to Luz Of ray, she being his Sister and Person in Charge at the time of service on January 25,2005 at 9:30 A,M" at 533 Maple Street, Lehanon (City), Lebanon County, Pennsylvania, and hy making known to her the contents of the same. Sworn to and subscrihed hefore me SO ANSWERS, _f)~C{ )I~ DEPU]:: SHERIF~ L J '. @ ~VM~ SHE F @ this 28th day of January 2005 h Q~ tary Puhlic -r t\,:'l..~L SU),L K"IB,,?L Y ,,\ B::C'\:~ :,,',"1 P'J~li, Ci~)' ~: L_-::}2,'H:i. L ej2.:H:1 ;'2~ti;!~j. Pa. M} l.prT\m:smn up/res 0?t-efT',~~\ 17. 2006 SHERIFF'S COSTS IN ABOVE PROCEEDINGS Advanced Costs paid on 0I/24/05 Check No, 48584 Amount Costs Incurred: Amount Refund: Check No, 16695 Amount $100.00 $ 30.53 $ 69,47 All Sheriff's Costs shall be due and payable when services are performed, and it shall be lawful for him to demand and receive from the party instituting the proceedings, or any party liable for the costs thereof, all unpaid sheriff's fees on the same before he shall be obligated hy law to make return thereof. See, 2, Act of June 20,1911, P,L. 1072 ANNETTE D. COMP, Plaintiff VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-192 CIVIL TERM FELIPE RODRIGUEZ, Defendant CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, FELIPE RODRIGUEZ, with regard to the above-captioned matter. Respectfully submitted, NEALON GOVER & PERRY Date: (('73{oC By:Mu 6 {)f:;112f c{ Michael S. Ferguson, Esquire 1.0. No, 83882 2411 North Front Street Harrisburg, PA 17110 7171232-9900 . CERTIFICATE OF SERVICE 71<:1 AND NOW, this l> day of May, 2005, I hereby certify that I have served the foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Marcus A. McKnight, III, Esquire IRWIN & McKNIGHT 60 West Pomfret Street Carlisle, PA 17013 lqvlWaur Michael S. Ferguson, Esquire :-' ---I' , , , I ~., t VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-192 CIVIL TERM ANNETTE D. COMP, Plaintiff FELIPE RODRIGUEZ, Defendant CIVIL ACTION - LAW PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please issue a Rule upon the Plaintiff to file a Complaint within twenty (20) days or suffer a judgment of non pros. Respectfully submitted, NEALON GOVER & PERRY Date: ~ ~) CS By: 1ULl~Q~Wr Michael S. Ferguson, Esquire /.D. No. 83882 2411 North Front Street Harrisburg, PA 17110 717/232 -9900 RULE TO THE PLAINTIFF: A Rule is hereby issued upon you to file a Complaint within twenty (20) days of service of this Rule or suffer a judgment of non pros. DATED: fYl ';:J.'f ...:{ <'", ~ t'Y.>S . CERTIFICATE OF SERVICE AND NOW, this L 51~ day of May, 2005, I hereby certify that I have served the foregoing PRAECIPE FOR RULE TO FILE COMPLAINT on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Marcus A. McKnight, III, Esquire IRWIN & McKNIGHT 60 West Pomfret Street Carlisle, PA 17013 1." ,(Vi r~ luitcUt:>1~~ . Michael S. erguson, EsqUire , -1 ~. >) t.:' .-,") " w ,~ - "...' - CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009,22 ORIGINAL IN THE MATTER OF: COURT OF COMMON PLEAS COMP TERM, CUMBERLAND -VS- CASE NO: 2005-192 RODRIGUEZ AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. 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) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served ~s identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01(11(2006 /('~J#I ~~ /:CMi~1iRGU~Q. Attorney for DEF DANT /7 DEll-603952 13885-LOl COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND COMPo FileNo. 2005-192 Ys. RODRlGUEZ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for 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 RlDER .... at The MCS Group Inc 1601 Market Street Suite 800 Philadelnhia PA 19101 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 have the right to seek, in advance, the reasonable cost of preparing the 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 serv'ce, 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: ADDRESS: MICHAEL FERGUSON. ESO. 241] N FRONT ST HARRISBlJRG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT lD #: ATTORNEY FOR: Defendant JAN 1 1 2006 Date: O~r /4, ;)IYlS Deputy Seal of the Court 13885-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: 13885 ANNEITE D COMP Prior approval is required for fees in excess of $IOQ,QO for hospitals, $50,00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50,00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication! prescription records, nurse's notes, doctor's comments, dietary restrictions, and alll?atient consent or refusal of treatment, procedures, test, and/or medicanon, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, reIa~ to any examination, consultation, diagnosis, care, treatment, admi!:Slon, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject: ANNETI'E D COMP 930 FORRESl' COURT, CARLISLE, PA 17011 Social Security #: 197-66-1288 DareorBUrth:~I~I979 SUlO-597076 13885 -LO 1 CERTIFICATE PREREQUISITE TO SERVICB OF A SUBPOBNA PURSUANT TO RULE 4009,22 ORIGINAL IN THE MATTER OF: COURT OF COMMON PLEAS COMP TERM, CUMBERLAND -VS- CASE NO: 2005-192 RODRIGUEZ As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. 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) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/11/2006 lf~ AEL FERGUSON SQ. Attorney for D ENDANT fD /7 DEl1-603953 13885 - L 02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CENTER IMf 1907 GREENTREE ROAD CHERRY HILL, NJ 08003 RE: 13885 ANNEITE D COMP Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequed~=rts, includ~ any and all such items as may be stored in a computer ase or OtheIWISe in electronic form, relating to any examination, consultation, diagnosis, care or treatment pert"ining to: Dates Requested: up to and including the present. Subject: ANNETTE D COMP 930 FORREST COURT, CARLISLE, PA 17011 Social Security #: 197-66-1288 Date of Birth: 08-13-1979 8U10-597078 13BBS-L02 CERTIFICATE PURSUANT TO RULE 4009.22 ORIGINAL PREREQUISITE TO SERVICE OF A SUBPOENA IN THE MATTER OF: COURT OF COMMON PLEAS COMP TERM, CUMBERLAND -VS- CASE NO: 2005-192 RODRIGUEZ As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. 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) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. /-7 DATE: 01/11/2006 ~ DEll-603954 1388S-L03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS COMP TERM, -VS- CASE NO: 2005-192 RODRIGUEZ NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCB DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HERSHEY MEDICAL CENTER CENTER IMT ALEXANDER SPRING REHAB DR, WILLIAM KAUFFMAN HERSHEY MEDICAL CENTER MEDICAL RECORDS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL R$CPRDS & XRAYS X-RAY ONLY TO: MARCUS MCKNIGHT, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ, intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served, Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office, DATE: 12/22/2005 MCS on behalf of MICHAEL FERGUSON, ESQ, Attorney for DEFENDANT CC: MICHAEL FERGUSON, ESQ, - 05-375 Any questions regarding this matter, contact THE MCS GROUP INC, 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246 -0900 DE02-320390 13885-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COMPo FileNo, 2005-192 vs. RODRIGUEZ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ALEXANDER SPRING REHAB (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 The MCS Group Inc 1601 Market Street Suite 800 Philadelphia PA 191m 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 have the right to seek, in advance, the reasonable cost of preparing the copies or producing the tlllngs 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: ADDRESS: MICHAEL FERGUSON, ESO. 2411 N FRONT ST HARRISBURG, PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: =t JAN 1 I 2006 Fe, /4 MCJS I Deputy Seal of the Court 13885-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ALEXANDER SPRING REHAB 1 TYLER COURT SUITE-200 CARLISLE, PA 17013 RE: 13885 ANNETTE D COMP Prior approval is required for fees in excess of $100.00 for hospitals, $50,00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, inclu~ any and all such items as may be stored in a computer database or otheTWlse in electronic form, relating to any eJramination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: ANNETI'E D COMP 930 FORREST COURT, CARLISLE, PA 17011 Social Security #: 197-66-1288 Date of Birth: 08-13-1979 8U10-597080 13BBS-L03 -I CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 O/1/G/NAL IN THE MATTER OF: COURT OF COMMON PLEAS COMP TERM, CUMBERLAND -VS- CASE NO: 2005-192 RODRIGUEZ As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. 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) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena, DATE: 01/11/2006 12>>Jl.b2!:~ /! /J/~~~7 Attorney for D NDANT DEll-603955 13885-L04 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS COMP TERM, -VS- CASE NO: 2005-192 RODRIGUEZ NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HERSHEY MEDICAL CENTER CENTER IMT ALEXANDER SPRING REHAB DR. WILLIAM KAUFFMAN HERSHEY MEDICAL CENTER MEDICAL RECORDS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL R$CPRDS & XRAYS X-RAY ONLY TO: MARCUS MCKNIGHT, ESQ" PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ, intends to serve a subpoena identical to the one that is attached to this notice, You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena, If the twenty day notice period is waived or if no objection is made, then the subpoena may be served, Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office, DATE: 12{22{2005 MCS on behalf of MICHAEL FERGUSON, ESQ, Attorney for DEFENDANT CC: MICHAEL FERGUSON, ESQ, - 05-375 Any questions regarding this matter, contact THE MCS GROUP INC, 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-320390 13885 -CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COMP: FileNo, 2005-192 vs, RODRIGUEZ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. WILLIAM KAUFFMAN (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 The MCS Gro4j) Inc ]60] Market Street Suite 800 Philade]phia PA 19]03 You may ueliver 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 have the right to seek, in advance, the reasonable cost of preparing the 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: ADDRESS: MICHAEL FERGUSON, ESO, 2411 N FRONT ST. HARRISRURG,PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant , n'il b' lSlOn Date: :J) JAN 1 1 2006 €c 11.../. ~MS , Deputy Seal of the Court 13 885-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR, WILLIAM KAUFFMAN SPRING ROAD FAMILY PRAC 1921 SPRING ROAD CARLISLE, PA RE: 13885 ANNEITE D COMP Prior approval is required for fees in excess of $100.00 for hospitals, $50,00 for all other providers, Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, inclu~ any and all such items as may be stored in a computer database or otheIWISe in electronic form, relating to any examinarion, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: ANNETIE D COMP 930 FORREST COURT, CARLISLE, PA 17011 Social Security #: 197-66-1288 Date of Birth: 08-13-1979 SUIO-59708213BB5-L04 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009,22 ORIGINAL IN THE MATTER OF: COURT OF COMMON PLEAS COMP TERM, CUMBERLAND -VS- CASE NO: 2005-192 RODRIGUEZ AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009,22 MCS on behalf of MICHAEL FERGUSON, ESQ. 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) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01(11(2006 Ay~~_a~ ~. . ~~~/7 Attorney for ~FENDANT / DE11-603956 13885-L05 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS COMP TERM, -VS- CASE NO: 2005-192 RODRIGUEZ NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCB DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HERSHEY MEDICAL CENTER CENTER IMT ALEXANDER SPRING REHAB DR, WILLIAM KAUFFMAN HERSHEY MEDICAL CENTER MEDICAL RECORDS MEDICAL RECORDS ~ XRAYS MEDICAL RECORDS ~ XRAYS MEDICAL R$CPRDS ~ XRAYS X-RAY ONLY TO: MARCUS MCKNIGHT, ESQ" PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice, You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena, If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office, DATE: 12/22/2005 MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT CC: MICHAEL FERGUSON, ESQ, - 05-375 Any questions regarding this matter, contact THE MCS GROUP INC, 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-320390 13885-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COMPo FileNo, 2005-192 vs, RODRIGUEZ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for 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 The MCS GroUD Inc 1601 Market Street Suite 800 Philadelphia PA 19103 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 have the right to seek, in advance, the reasonable cost of preparing the 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: ADDRESS: MICHAEL FERGUSON, ESO. 2411 N FRONT ST HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: --=u JAN 1 1 2006 ~r 14, ;l6t0S Deputy Seal of the Court 13885-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: 13885 ANNEITE D COMP Prior approval is required for fees in excess of $100.00 for hospitals, $50,00 for all other providers, Please call for prior approval for fees in excess of $100,00 for hospitals, $50.00 for all other providers, Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject: ANNETIE D COMP 930 FORREST COURT, CARLISLE, PA 17011 Social Security #: 197-66-1288 DareorBUrth:~I~un9 SUIO-597084 13885-L05 Ci t-~ , ) "r1 ..:- " L_ ..,".-- GO () :-<. VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-192 CIVIL TERM ANNETTE D. COMP, Plaintiff FELIPE RODRIGUEZ, Defendant CIVIL ACTION - LAW NOTICE TO PLEAD TO: Annette D. Comp C/o Marcus A. McKnight, III, Esquire IRWIN & McKNIGHT 60 West Pomfret Street Carlisle, PA 17013 YOU ARE HEREBY NOTIFIED that the Answer to Complaint set forth herein contains averments against you to which you are required to respond within twenty (20) days after service thereof. Failure by you to do so may constitute an admission. Respectfully submitted, NEALON GOVER & PERRY Date: 1-/1--1 10f.., By-MU'C~CE Michael S. Fergus n, Esquire 1.0, #: 83882 2411 North Front Street Harrisburg, PA 17110 717/232 -9900 ANNETTE D. COMP, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS, NO. 2005-192 CIVIL TERM FELIPE RODRIGUEZ, Defendant CIVIL ACTION - LAW ANSWER TO COMPLAINT WITH NEW MATTER 1, Admitted on information and belief. 2. Admitted. 3. Admitted, 4. Admitted. 5. Denied. It is denied that the Defendant in this matter caused any injuries to the Plaintiff. The matter is specifically denied pursuant to Pa. RC.P. 1029(e). 6. Denied pursuant to Pa. RC,P. 1029(e). 7. Admitted. 8 -12. Denied pursuant to Pa. RCP. 1029(e). 13. Denied pursuant to Pa, RC.P. 1029(e). WHEREFORE, Defendant Felipe Rodriguez, requests judgment in his favor and against the Plaintiff together with any costs associated therewith. NEW MATTER 14. Paragraphs 1 through 13 are incorporated herein by reference thereto. 15. Plaintiff's claims may be barred in whole or in part by application of the Pennsylvania Motor Vehicle Financial Responsibility Act, 75 Pa. C.SA 91701 et. Seq. WHEREFORE, Defendant Felipe Rodriguez, requests judgment in his favor and against the Plaintiff together with any costs associated therewith. Respectfully submitted, NEALON GOVER & PERRY By /)1~ () c,()5lev'c. -- Michael S. Ferguson, Esquire Attorney 1.0. No. 83882 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 Date:~ VERIFICATION I, Michael S. Ferguson, Esquire, make this Verification on behalf of the Defendant, Felipe Rodriguez, a knowledgeable representative of which is currently unavailable to sign this Verification. I represent that the facts set forth in the foregoing Answer to Complaint With New Matter are true and correct to the best of my knowledge, information, and belief. I understand that this Verification is made subject to the penalties of 18 Pa.C.SA 94904 relating to unsworn falsification to authorities. ,.-').-,. /M (t(pi)j.I?O~1 Michael S. Ferguson, Esquire CERTIFICATE OF SERVICE r- AND NOW, this ? Z day of l:e0rud, 2006, I hereby certify that I have served the foregoing ANSWER TO COMPLAINT WITH NEW MATTER on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Marcus A. McKnight, III, Esquire IRWIN & McKNIGHT 60 West Pomfret Street Carlisle, PA 17013 ~1~{rL~~/ Michael S. Ferguson, Esquire , " .-. . ANNETTE D. COMP, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. 2005- 192 CIVIL TERM FELIPE RODRIGUEZ, Defendant CIVL ACTION - LAW PRAECIPE TO SETTLE AND DISCONTINUE To Curtis R. Long, Prothonotary: Please mark the above-captioned case settled and discontinued and issue a Settlement Certificate to Marcus A. McKnight, Ill, Esquire, at 60 West Pomfret Street, Carlisle, Pennsylvania 17013. Respectfully submitted, IRWIN & McKNIGHT Date: May 19,2006 .. ANNETTE D. COMP, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 2005- 192 CIVIL TERM FELIPE RODRIGUEZ, Defendant CIVL ACTION - LAW CERTIFICATE OF SERVICE I, Marcus A. McKnight, ill, Esquire, hereby certify that a copy of attached Praecipe to Settle and Discontinue was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: Michael S. Ferguson, Esq. 2411 North Front Street Harrisburg, PA 17110 IRWIN & McKNIGHT By: Date: May 19, 2006 () r....:> 0 c::::> ~;; c,:) -1'1 <::n ~ :P- "Tl __L':lt. :::,. -." rT1;= -o'fTi \.0 ::-nS? ~i? ('i:~ \J ;'~2f~ ~ ~ ;..;"rn .......' -~ (J1 ~ 0 -<