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HomeMy WebLinkAbout13-5763 Supreme Court Uf Pennsylvania Court of- Common Pleas For Prothonotary Use Only: C veil Uv r sh y et 1_ }, (, Docket No: CUMBERLAND r V County l n The informotion collected on this frirm is used solely fir court administration purposes. This farm does not suppl or replace the filing and service of pleadings or other papers os required by 1m4-' it rules of court. Commencement of Action: S [3 Complaint [x' Writ of Summons Q] Petition E [] Transfer from Another Jurisdiction (] Declaration of Taking C Lead Plaintiff's Name: Lead Defendant's Name: T Jennifer Ellis Susan J. Rosso, DPM I Are money damages requested? l Yes D No Dollar Amount Requested: Owithin arbitration limits U (check one) [Eoutside arbitration limits N Is this a Class Action Suit? 0 Yes 0 No Is this an MDJAppeal? [ Yes El No A Name of Plaintiff /Appellant's Attorney: Dennis M. Abrams, Esquire Check here if you have no attorney (are a Self - Represented 11 1 1 . 0 Set L,itiganf ) 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 0 Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution 0 Debt Collection: Credit Card 0 Board of Assessment J Motor Vehicle 0 Debt Collection: Other Board of Elections Nuisance Dept. of Transportation Premises Liability g Statutory Appeal: Other S Product Liability (does not include E mass tort) Employment Dispute: SlandertLibel/ Defamation Discrimination C 0 Other: Employment Dispute: Other Zoning Board T El Other: I Other: O MASS TORT 0 Asbestos N Tobacco Toxic Tort - DES 0 Toxic Tort -Implant REAL PROPERTY MISCELLANEOUS Toxic Waste 0 Other: [I Ejectment [] Common Law /Statutory Arbitration B Eminent Domain /Condemnation 0 Declaratory Judgment Ground Rent Q Mandamus 0 Landlord/Tenant Dispute © Non- Domestic Relations PROFESSIONAL LIABLITY Mortgage Foreclosure: Residential Restraining Order Mortgage Foreclosure: Commercial Quo Warranto [] Dental 0 Partition 0 Replevin Legal 0 Quiet Title 0 Other: x Medical [] Other: Other Professional: Updated 1/1/2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Plaintiff(s) & Address(es) Jennifer Ellis 347 New Market Court Wayne, PA 19087 ! 2 Case No. �� ✓ + ✓ Civil Term VS. Civil Action Defendant(s) & Address(es) Susan J. Rosso, DPM -, 3600 Trindle Road = M `=' Camp Hill, PA 17011 -E+ and C) ZLOTOFF, GILFERT & GOLD, PC C) .;: - T 3600 Trindle Road >< a °'? Camp Hill, PA 17011 =� PRAECIPE FOR WRIT OF SUMMONS __j TO THE PROTHONOTARY /CLERK OF SAID COURT: Issue summons in the above case Writ of Summons shall be issued and forwarded to Attorn eriff. Please Circle choice Date: October 3, 2013 Signature of Attorney Print Name: Dennis M. Abrams, Esquire Address: 555 City Line Avenue, Suite 500 Bala Cynwyd, PA 19004 Telephone #: 610- 667 -7511 Supreme Court ID Number: 40184 WRIT OF SUMMONS TO: Susan J. Rosso, DPM and Zlotoff, Gilfert & Gold, PC YOU ARE NOTIFIED THAT THE ABOVE -NAMED AINTIFF(S) HAS/HAVIP COMMEN ED AN ACTION AGAINST YOU. Prothonotary/Clerk, Civil Division Date: by Deputy n OAr j2 aQtok4 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff COM tier, Jody S Smith Chief Deputy " I Richard W Stewart - 3 11.•• 1 7 AN I : Solicitor OF cE OF S S EFIP UMBER A f-a>J ..',„.tl I PENNSYLVANIA Jennifer Ellis vs. Case Number Susan J Rosso(et al.) 2013-5763 SHERIFF'S RETURN OF SERVICE 10/15/2013 01:37 PM- Deputy William Cline, being duly sworn according to law, served the reque ted Writ of Summons by handing a true copy to a person representing themselves to be Mana•-r •• --- aF _ - • • . 8 ast Trindle Road, Suite •- awns ip, Mechanicsburg, PA 17050. a - WILLI M CLINE, DEPUTY 10/15/2013 01:37 PM - Deputy William Cline, being duly sworn according to law, served the requested Writ of Summons by handing a true co• • - •- •• -• -sentin• themselves to be Suzanne Rhodes, Office -• -• _ - ,_� . _ - - 108 East • .nu•u-r .��Vii,- M.i- c= ai a.l s`rk �,¢Zp',� a�.iLc�-1.LL..,u .� ..x,®;�.�., _ - ILLIAM CLINE, DEPUTY SHERIFF COST: $60.95 SO ANSWERS, October 16, 2013 RONR ANDERSON, SHERIFF (ui Cou-ty5ui:e,?hedf`,Teieoseti.. THE PROTHONOTAr' MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN 2fl13 NOV .1. PH ,2: $9 By: Frederic Roller/Mary Kate McGrath/Michelle I. Moses Identification Nos. 65513 /90690 /207723 CUMERLAN13 COUNTY 2000 Market Street Attorneys fiHAYLA Philadelphia, PA 19103 Susan J. Rosso, DPM and (215) 575-2770 /(215) 575-2863 /(215) 575-2758 Zlotoff, Gilfert& Gold, PC JENNIFER ELLIS • COURT OF COMMON PLEAS • CUMBERLAND COUNTY v. • SUSAN J. ROSSO, D.P.M. and • ZLOTOFF, GILFERT & GOLD, P.C. • NO. 13-5763 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter our appearances on behalf of defendants, Susan J. Rosso, D.P.M. and Zlotoff, Gilfert & Gold, P.C., with regard to the above-captioned matter. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN i By IOW. - FREDERIC ROLLER MARY KATE McGRATH MICHELLE I. MOSES Attorneys for Defendants, Susan J. Rosso, D.P.M. and Zlotoff, Gilfert & Gold, P.C. DATE: /0/50//2) g 'LEO-Of Fla: MARSHALL DENNEHEY WARNER ,f_ H • mu THO to i ' COLEMAN & GOGGIN 2813 NOV 4 PM 2: 10 By: Frederic Roller/ Mary Kate McGrath/Michelle I. Moses Identification Nos. 65513 / 90690 /207723 CUMIKAL AND COUNTY 2000 Market Street AttorneyslIEWNSIEVAiNits, Philadelphia, PA 19103 Susan J. Rosso, DPM and (215) 575-2770/(215) 575-2863 /(215) 575-2758 Zlotoff, Gilfert & Gold, PC JENNIFER ELLIS • COURT OF COMMON PLEAS • CUMBERLAND COUNTY v. • SUSAN J. ROSSO, D.P.M. and • ZLOTOFF, GILFERT & GOLD, P.C. • NO. 13-5763 PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Kindly issue Rule upon Plaintiff to file a Complaint within twenty (20) days or suffer Judgment of Non Pros MARSHALL, DENNEHEY, WARNER, COLEMA1 & GOGGIN By �� FREDERIC ROLLER MARY KATE McGRATH MICHELLE I. MOSES Attorneys for Defendants, Susan J. Rosso, D.P.M. and Zlotoff, Gilfert & Gold, P.C. RULE TO FILE COMPLAINT AND NOW, this � day of NDU6.If , 2013, a Rule is hereby granted upon Plaintiff to file a Complaint herein within twenty (20) days hereof or suffer the entry of a Judgment of Non Pros. - 1A .9_ Ill I■6_ 411.11 Prothonotary,to• VXD to • 1.L a CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA ORIGINAL PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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) wiij,ch is attached to the notice of intent to serve the subpoena. C ' cry m , n1_` 00 ET C 7 CO r- --t CD MCS o/ /half of <CD = ° ca +i DATE: 12/23/2013 _,i4 I 5 FRED R ROLLER, ESQ. --i crt oeN Attorney for DEFENDANT "‹ MCS # 97110-LO1 DEll COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DR. JOHN ROGERS MEDICAL, RADIOLOGY & PATHOLOGY DR. SCOTT MUELLER MEDICAL, RADIOLOGY & PATHOLOGY GIANT FOODS LLC LEGAL DEPT PRESCRIPTION/PHARMACEUTICAL RECORDS TO: DENNIS ABRAMS, ESQ. , PLAINTIFF COUNSEL MCS on behalf of FREDERIC ROLLER, 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: 11/29/2013 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT CC: FREDERIC ROLLER, ESQ. - 16246.00282 THE MCS GROUP INC. DENNIS ABRAMS, ESQ. 1601 MARKET STREET LOWENTHAL & ABRAMS #800 555 CITY LINE AVENUE PHILADELPHIA, PA 19103 SUITE 500 (215) 246-0900 BALA CYNWYD, PA 19004 MCS # 97110-001 DE02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND • JENNIFER ELLIS File No. 13-5763 vs. • • SUSAN ROSSO,D.P.M. • • SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for, DR.JOHN ROGERS (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 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: FREDERIC ROLLER.ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA, PA 19103 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: Pr thonotary/Clerk,Civil Division DEC 23 2013 einAcA- . Oral I. Deputy Date: eat of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. JOHN ROGERS 2025 TECHNOLOGY PARKWAY SUITE GO7 MECHANICSBURG, PA 17050 RE: MCS # 97110-L01 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX-XX-0447 Date of Birth: 06-16-1972 Please provide entire medical file, including but not limited to any and all inpatient and outpatient records. ER records, physical therapy records files, memoranda, handwritten notes, emails, phone messages, history, physical reports, and all prescriptions records. Radiology - Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. Pathology - Including all pathology materials, all blocks, slides, toxicological or pharmacological analyses and corresponding reports. This should contain all records in your possession, all office and admission charts, all archived records, or records in storage. Including any and all items as may be stored in a computer data base or otherwise electronic form. FILM INVENTORY Prior approval is required for fees in excess of$150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L01 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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. MCS on behalf of DATE: 12/23/2013 FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L02 DEll COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND • JENNIFER ELLIS • • File No. 13-5763 vs. SUSAN ROSSO,D.P.M. • SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR, SCOTT MUELLER (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 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: FREDERIC ROLLER.ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA,PA 19103 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: DEC 3 2013 Prothonotary/Clerk,Civil Division Date: I /as /3 Deputy Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. SCOTT MUELLER 2025 TECHNOLOGY PARKWAY SUITE 205 MECHANICSBURG, PA 17050 RE: MCS # 97110-L02 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX-XX-0447 Date of Birth: 06-16-1972 Please provide entire medical file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records files, memoranda, handwritten notes, emails, phone messages, history, physical reports, and all prescriptions records. Radiology - Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. Pathology - Including all pathology materials, all blocks, slides, toxicological or pharmacological analyses and corresponding reports. This should contain all records in your possession, all office and admission charts, all archived records, or records in storage. Including any and all items as may be stored in a computer data base or otherwise electronic form. FILM INVENTORY Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L02 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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. MCS on behalf of DATE: 12/23/2013 FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L03 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND, JENNIFER ELLIS • File No. 13-5763 vs. SUSAN ROSSO,D.P.M. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for. GIANT FOODS LLC LEGAL DEPT (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 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: FREDERIC ROLLER,ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA.PA 19103 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: / Prothonotary/Clerk,Civil Division CI 3 2013 Date: dS' Deputy Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: GIANT FOODS LLC LEGAL DEPT C/O BRIAN DUNWOODY 1385 HANCOCK STREET QUINCY, MA 02169 RE: MCS # 97110-L03 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX-XX-0447 Date of Birth: 06-16-1972 Please provide entire prescription and pharmaceutical file, including but not limited to all records, reports, correspondence, memoranda, complete prescription and medication history, along with payment and insurance records. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise electronic form. STORE LOCATION: 5301 SIMPSON FERRY ROAD, MECHANICSBURG, PA. STORE 6331 Prior approval is required for fees in excess of$150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L03 SU10 ti IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER ELLIS Plaintiff vs SUSAN J. ROSSO, DPM, ET AL Defendant . NO. 13 -5763 NOTICE TO DEFEND Ca Fri cp +iy � 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 AN 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. 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 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 REDUECED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1- 800 - 990 -9108 717 - 249 -3166 -;1 f LOWENTHAL & ABRAMS, PC By: Dennis M. Abrams, Esquire Identification No. 40181 555 City Line Avenue, Suite 500 Bala Cynwyd, PA 19001 (610) 667 -7511 JENNIFER ELLIS 347 New Market Court Chesterbrook, PA 19087 v. SUSAN J. ROSSO, DPM 5108 E Trindle Road Mechanicsburg, PA 17050 and ZLOTOFF, GILFERT & GOLD, PC 5108 E Trindle Road Mechanicsburg, PA 17050 Attorneys for Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : NO. 13 -5763 PLAINTIFF'S COMPLAINT The Defendant Susan J. Rosso is a podiatrist who practices in Cumberland County and at all times relevant was employed by the Defendant, Zlotoff, Gilfert & Gold, PC. Plaintiff is asserting professional medical liability claims against these Defendants. 1. Plaintiff Jennifer Ellis resides at the above address and at all times relevant herein received medical care and attention from the Defendants identified below. 2. The Defendant Susan J. Rosso, DPM (hereinafter referred to as "Rosso ") is an adult individual who at all times material and pertinent to this action was a podiatrist duly licensed to practice her profession in, by and pursuant to the laws of the Commonwealth of Pennsylvania; her regular office where she regularly conducted her business and engaged in the practice of her profession is at the above address; at all times and places material and pertinent to this action, Defendant Rosso held herself out to the public and to the Plaintiff as a competent and skilled podiatrist. 3. The Defendant Zlotoff, Gilfert & Gold, PC (hereinafter referred to as "Zlotoff, PC) is a Pennsylvania corporation operating a practice for podiatric medicine at the above address and is duly licensed by the laws of the Commonwealth of Pennsylvania to deliver podiatric services from its facilities and in such capacity delivered such services to the Plaintiff, Jennifer Ellis. 4. The Defendant Zlotoff, PC is a Pennsylvania corporation employing podiatrists and others within Cumberland County and in such capacity employed the Defendant Rosso (Plaintiff's attending podiatrist) as well as its office staff. 5. At all times and places relevant to this action, the Defendant Zlotoff, PC acted and /or failed to act by and through its agents, ostensible agents, servants, work persons and /or employees including the Defendant Rosso. 6. The Defendant Rosso at all times relevant hereto was an employee of the Defendant Zlotoff, PC and acted on behalf of said corporate Defendant as Plaintiff's treating podiatrist. 7. Plaintiff began a diet and an exercise program and enjoyed success losing approximately 40 pounds prior to March 4, 2011. 8. Contemporaneous with the exercise program, she developed an aching pain across the balls of both of her feet and because she had been a patient of the Defendant Zlotoff, PC previously, she scheduled an office appointment specifically to have an evaluation of the pain that she was experiencing in her left foot when spreading the 4th and 5th toes apart. 2 9. On or about March 4, 2011, Plaintiff was evaluated by Defendant Rosso in Defendant Zlotoff, PC's office; Rosso charted her chief complaint as diffuse aching pain across the balls of both feet; the pain was described in the records as shooting pain mostly in the morning. 10. On or about March 4, 2011, the Defendant Rosso performed a physical examination of the Plaintiff and upon palpation, according to the chart, the Plaintiff expressed pain surrounding the fifth metatarsophalangeal joint in the left foot; the chart also documents pain within the third inner space of the right foot. 11. As an incidental finding, the Defendant Rosso also noticed what she described as lesions on the plantar lateral aspect of the left mid foot. 12. On or about March 4, 2011, Defendant Rosso, after the physical examination, advised Plaintiff that she had warts on her left foot at mid foot and those warts had to be removed. 13. At that time and previously thereto, the area of Plaintiff's left mid foot was asymptomatic; Plaintiff was unaware she had warts and thought there was callous formation at that location. 14. On or about March 4, 2011, Plaintiff queried Defendant Rosso as to whether the medication she proposed to use to lift and remove the warts was safe for her; at which point Defendant Rosso assured Plaintiff the medication, called Blister Beetle, was safe and presented no risk to her. 15. On or about March 4, 2011, relying upon the assurances of the Defendant Rosso, Plaintiff submitted to the application of the medicine designed to cause a blister to form and effectively separate the warts from the underlying tissue enabling removal of the warts. 3 16. At no time did Defendant Rosso sculpt the insole of Plaintiff's left shoe or prescribe a diabetic shoe or make any provision to alleviate the pressure on the area where the medication was applied to remove the warts. 17. At least two more times Plaintiff returned for an application of the medication on the warts on her left mid foot; however by June 2011 Plaintiff noted there was a quarter sized darkened area where the medication had been applied and it appeared to her that the medication was not effective and was causing the condition to expand. 18. On or about June 21, 2011, Plaintiff again came to the Defendant Rosso for evaluation at which time it was confirmed that she now had a 1.5 cm diameter lesion that was not healing; at this point Rosso recommended surgery. 19. Approximately two days later, on or about June 23, 2011, Plaintiff returned to the Defendants because she could feel and see that her left foot was warm, red and swollen and she feared infection in the area where Rosso had been attempting to remove the warts. 20. On June 23, 2011, finding there was an infection, Rosso prescribed a ten day course of antibiotics; Plaintiff promptly filled the prescription and began taking the antibiotics on June 23, 2011. 21. On or about June 30, 2011, Plaintiff underwent laser surgery to remove the warts; Plaintiff had not even finished her course of antibiotics and, unbeknownst to her, still had an infected area on her left mid foot; however Rosso did not delay surgery but instead performed surgery on June 30, 2011. 22. The operative record for the Defendant indicates that she not only excised the warts but after excising she then applied a laser to the affected area. 4 23. On or after her laser surgery, the Defendant again failed to sculpt the insole of the left shoe or order a diabetic shoe or otherwise provide a means to alleviate the pressure on the area where the warts had been treated. 24. By July 27, 2011, either the initial infection never resolved or a new infection occurred and Defendant Rosso prescribed Keflex for the Plaintiff; a second prescription for Keflex was ordered on August 8, 2011 when the infection did not resolve. 25. On or about August 24, 2011, still complaining of significant pain in the left foot at the site of the excision of the warts; there was now significant scar tissue present, the wounds had not healed and Rosso prescribed physical therapy and additional medications in an attempt to treat the wound, heal the wound and reduce and /or eliminate Plaintiff's pain. 26. On or about September 6, 2011, Plaintiff returned to Defendants because she continued to be concerned about her left mid foot; a diagnosis of cellulitis plus significant scar tissue was made, Augmentin was prescribed to control inflammation and infection. 27. On or about October 13, 2011, Plaintiff returned to Rosso still with significant pain, scar tissue, failure to heal and informed Defendants that she was dissatisfied with the care and treatment she had received. 28. Prior to that last office visit of October 13, 2011, Plaintiff's physical therapist recommended she see a wound specialist and on October 11, 2011 Plaintiff was evaluated at Pinnacle Health Wound Center where, for the first time, she was prescribed a wound healing shoe to offload pressure on the affected area; other measures were also instituted to keep the bacterial count down, provide absorption to the drainage from the ongoing wound and attempt to heal the wound. 5 29. Throughout the first several months of being treated by Defendants, Plaintiff, a known diabetic, was on Methotrexate for her arthritis. 30. Plaintiff stopped her Methotrexate each time she began to use antibiotics. 31. After the wound care treatment finally succeeded at closing the wounds, a significant amount of scar tissue was left behind, such that, combined with the ongoing pain, Plaintiffs gait has been seriously affected to the extent that she will require a lifetime of orthotics as well as a knee brace, ankle and tendon surgery and possible knee surgery, as well as treatment to her right leg and other treatment as the sequelae of the Defendants' efforts to eradicate the warts, all of which will have a permanent impact on Plaintiffs left lower extremity, body and lifestyle. 32. Certificates of Merit regarding the conduct of Defendant Rosso and Defendant Zlotoff, PC are attached as Exhibit A and Exhibit B. COUNT I PLAINTIFF V DEFENDANT ROSSO 33. Plaintiff repeats and realleges the allegations contained in paragraphs 1 through 32 as though the same were set forth fully at length herein. 34. The Defendant Rosso owed a duty to Plaintiff to properly care for and treat her and timely adhere to the applicable standards of care but said Defendant breached that duty and was negligent and careless in her care and treatment of Plaintiff in that Defendant Rosso: a. b. chose to disturb asymptomatic warts when it was not appropriate to do so; failed to appreciate Plaintiffs existing morbidities which included being a diabetic, having rheumatoid arthritis, being on Methotrexate and being overweight; 6 c. failed to appreciate that the use of Canthacur was contraindicated on Plaintiff; d. failed to provide adequate space inside Plaintiff's shoe and /or footwear to enable the Canthacur to blister and function as it was designed without creating additional pressure on the wound inside her shoe; e. failed to relieve the pressure off of the area where Defendant Rosso was treating the warts; f. failed to order special shoe inserts or a special shoe to enable Plaintiff's wound to heal appropriately and adequately; g. failed to appreciate that Canthacur would be inappropriate medication for usage on the Plaintiff given her pre- existing conditions and her use of Methotrexate; h. assuring Plaintiff that Canthacur was safe for her when Defendant knew, or should have known, otherwise; i. after failing to eradicate the warts with Canthacur, deciding to use laser surgery to eradicate the warts; j. using laser surgery and excising the warts when Defendant knew, or should have known, that Plaintiff had not even completed her course of antibiotic therapy and the wound that would be operated on was or could still be infected; k. excising the warts and then using the laser when she knew, or should have known, her patient would not heal quickly; 1. failing to ensure that the area that would be subject to laser surgery was no longer infected; m. causing a prolongation and worsening of the infection in her left foot; n. failing to reduce Plaintiff's regimen while treating her warts; o. failing to appreciate the nature of Plaintiff's post -op condition; p. failing to appreciate that given Plaintiff's condition she was would develop significant scar tissue that could or would significantly affect her gait, mobility and left lower extremity generally; q. failing to timely refer Plaintiff to a wound care specialist; r. failing to recommend a rhuematological consult to determine whether Plaintiff should come off of the Methotrexate before any attempted removal of the warts; s. convincing Plaintiff to undergo laser surgery when the risks to Plaintiff outweighed the benefits thereof. 35. As a result of Defendant Rosso's negligence as identified above, Plaintiff has and will indefinitely into the future suffer injury including, but not limited to, injury to her left foot and ankle, Achilles tendon, left and right legs and back as well as causing significant scar tissue on the underside of Plaintiff's left foot in an area that is a significant pressure point, Plaintiff's gait has also been affected. 36. As a result of Defendant Rosso's negligence as identified above, Plaintiff has suffered and will continue to suffer significant physical and emotional pain and discomfort, she has suffered and will continue to suffer disfigurement, the loss of life's pleasures and the 8 enjoyment thereof and has and will continue to absorb and /or incur the costs and expense of continued medical care and treatment as a result of Defendants' negligence. 37. As a result of Defendant Rosso's negligence, Plaintiff may in the future suffer an impairment of her earning capacity. WHEREFORE, Plaintiff demands judgment against Defendant Rosso, jointly and severally, with the Defendant Zlotoff, PC for an amount in excess of Fifty Thousand Dollars ($50,000) plus costs and such further relief as the Court deems appropriate. COUNT II PLAINTIFF V DEFENDANT ZLOTOFF, PC 38. Plaintiff repeats and realleges the allegations contained in paragraphs 1 through 37 though the same were fully set forth herein at length. 39. The Defendant Zlotoff, PC, as employer of the Defendant Rosso, is vicariously liable for the negligence of its agent, employee and work person, the Defendant Rosso as described above. 40. As a result of the negligence of its employee and the vicarious liability therefore of Zlotoff, PC, Plaintiff has suffered the damages and injuries identified above. WHEREFORE, Plaintiff demands judgment against Defendant Zlotoff, PC, jointly and severally, with the Defendant Rosso for an amount in excess of Fifty Thousand Dollars ($50,000) plus costs and such further relief as the Court deems appropriate. BY: LOWENTHAL & ABRAMS, PC 9 S M. ABRAMS, ESQUIRE VERIFICATION I, JENNIFER ELLIS, hereby verify that I am a plaintiff in the within civil action, and that the facts set forth in the foregoing Complaint are true and accurate to the best of my knowledge, information and belief. I understand that this statement is made subject to the penalties of 18 P.C.S.A. §4904, relating to unsworn falsification to authorities. LOWENTHAL & ABRAMS, PC By: Dennis M. Abrams, Esquire Identification No. 40181 555 City Line Avenue, Suite 500 Bala Cynwyd, PA 19001 (610) 667-7511 JENNIFER ELLIS V. SUSAN J. ROSSO, DPM and SLOTOFF, GILFERT & GOLD, PC Attorneys for Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : NO. 13-5763 CERTIFICATE OF MERIT AS TO SUSAN J. ROSSO, DPM I, Dennis M. Abrams, certify that: o an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by this defendant in the treatment, practice or work that is the subject of the complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about the harm; OR o the claim that this defendant deviated from an acceptable professional standard is based solely on allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard and an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about the harm; Date: OR expert testimony of an appropriate licensed professional is unnecessary for prosecution of the claim against this defendant. NNIS M. ABRAMS, ESQUIRE Attorney for Plaintiff LOWENTHAL & ABRAMS, PC By: Dennis M. Abrams, Esquire Identification No. 40181 555 City Line Avenue, Suite 500 Bala Cynwyd, PA 19001 (610) 667-7511 Attorneys for Plaintiff JENNIFER ELLIS : COURT OF COMMON PLEAS : CUMBERLAND COUNTY V. : NO. 13-5763 SUSAN J. ROSSO, DPM and SLOTOFF, GILFERT & GOLD, PC CERTIFICATE OF MERIT AS TO SLOTOFF, GILFERT & GOLD, PC I, Dennis M. Abrams, certify that: o an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by this defendant in the treatment, practice or work that is the subject of the complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about the harm; OR the claim that this defendant deviated from an acceptable professional standard is based solely on allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard and an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about the harm; OR o expert testimony of an appropriate licensed professional is unnecessary for prosecution of the claim against this defendant. Date: Attorney for Plaintiff CERTIFICATION OF SERVICE I, Dennis M. Abrams, Esquire, of the law firm of Lowenthal & Abrams, P.C., hereby certify that on March 7, 2014, I served true and correct copies of the foregoing by United States first class mail, postage pre-paid, to the following: Frederic Roller, Esquire Marshall, Dennehey, Warner Coleman & Goggin 2000 Market Street Suite 2300 Philadelphia, PA 19103 LOWENTHAL ABRAMS, P.C. ABRAMS, ESQUIRE Counsel or plaintiff 10 ,V.In , 1 ?VII 1 N?R (,`,131rAF.‘E 10,41C\ MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Frederic Roller Mary Kate McGrath Michelle I. Moses Identification Nos.: 65513/90690/207723 2000 Market Street, 25th Floor Philadelphia, PA 19103 (215) 575-2260 NOTICE TO PLEAD TO PLAINTIFF YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED NEW MATTER WITHIN 20 DAYS FROM SERVICE HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST YOU. ATTORNEY/PARTY FILING Attorneys for Defendants: Susan J. Rosso, DPM and Zlotoff Gilfert & Gold, PC JENNIFER ELLIS V. SUSAN J. ROSSO, D.P.M. and ZLOTOFF, GILFERT & GOLD, P.C. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 13-5763 ANSWER WITH NEW MATTER TO COMPLAINT OF DEFENDANT, SUSAN J. ROSSO, D.P.M. AND NOW, comes Defendant, Susan J. Rosso, D.P.M. ("Defendant"), by and through her attorneys, Marshall Dennehey Warner Coleman & Goggin, to answer the Complaint of Plaintiff, Jennifer Ellis, and, in support thereof, avers as follows: 1, Admitted in part, denied in part. It is admitted that Jennifer Ellis is a Plaintiff in the within action. To the extent that the allegations of this paragraph are at odds with the available record, said allegations are denied. By way of further response, to the extent that the allegations of these paragraphs are conclusions of law, no responsive pleading is required of Answering Defendant. 2. Denied as stated. It is admitted that Dr. Rosso is a Podiatrist who is duly licensed to practice podiatric medicine in the Commonwealth of Pennsylvania. The care and treatment provided by Dr. Rosso to the Plaintiff was at all times medically appropriate and within the standard of care, and is reflected in the medica record, which is a document in writing which speaks for itself. To the extent that the allegations of paragraph 2 of the Complaint are conclusions of law, no responsive pleading is required. By way of further response, the allegations of this paragraph are denied pursuant to Pa. R.C.P. 1020. 3-5. Denied. To the extend that the allegations of paragraphs 3-5mre conclusions of law or are not directed to Answering Defendant, no responsive pleading is required. By way of further response, the allegations of this paragraph are denied pursuant to Pa. R,C.P. 1029. 6. Denied as stated. Answering Defendant denies all allegations of negligence, and maintains that for all times relevant to this litigation, the care and treatment which she provided to the Plaintiff was medically appropriate. To the extent that the allegations of this paragraph are at odds with the available record, said allegations are denied. It is unknown what is meant by "treating podiub\zt." By way of further response, to the extent that the allegations of these paragraphs are conclusions of law, no responsive pleading is required of Answering Defendant. 7-31. Denied as stated. To the extent that Answering Defendant is without sufficient information to affirm or deny the allegations of these paragraphs, said allegations are denied and strict proof thereof is demanded at trial. To the extent that the allegations of these paragraphs are at odds with the available record, said allegations are denied. Moreover, Answering Defendant denies all allegations of negligence, and maintains that for all times relevant to this litigation, the care and treatment which she provided to the Plaintiff was medically appropriate. To the extent that the allegations of these paragraphs are conclusions of law, no responsive pleading is required of Answering Defendant. By way of further response, the allegations of these paragraphs are denied pursuant to Pa. R.C.P. 1029. 32. Admitted in part, denied in part. It is admitted that Plaintiff attached certificates of merit as Exhibits "A" and "B" to the Complaint. All allegations of negligence are denied, and Answering Defendant maintains that the care and treatment which she provided to the Plaintiff was professionally appropriate. COUNT I PLAINTIFF v DEFENDANT ROSSO 33. Answering Defendant incorporates by reference her responses to paragraphs 1-32 of the Complaint as though fully set forth at length. 34-37. Denied. To the extent that the allegations of paragraphs 34-37 are conclusions of law, no responsive pleading is required. The care and treatment provided by Dr. Rosso to the Plaintiff was at all times medically appropriate and within the standard of care, and is reflected in the medical record, which is a document in writing which speaks for itself. To the extent that the allegations of these paragraphs differ from the medical record, said allegations are denied and strict proof of same is demanded at trial. By way of further response, the allegations of these paragraphs are denied pursuant to Pa. R.C.P. 1029. WHEREFORE, Answering Defendant respectfully demands judgment in her favor. COUNT II PLAINTIFF v. DEFENDANT ZLOTOFF, P.C. 38. Answering Defendant incorporates by reference her responses to paragraphs 1-37 of the Complaint as though fully set forth at length. 39-40. Denied. To the extent that the allegations of paragraphs 39-40 are conclusions of law or are not directed to Answering Defundmnt, no responsive pleading is required. The care and treatment provided by Dr. Rosso to the Plaintiff was at all times medically appropriate and within the standard of care, and is reflected in the medical record, which is a document in writing which speaks for itself. To the extent that the allegations of these paragraphs differ from the medical record, said Pd allegations are denied and strict proof of same is demanded at trial. By way of further response, the allegations of these paragraphs are denied pursuant to Pa. R.C.P. 1029. WHEREFORE, Answering Defendant respectfully demands judgment in her favor. NEW MATTER 41. Answering Defendant incorporates by reference her responses to paragraphs 1-40 of the Amended Complaint as though fully set forth at length. 42. he nature, origin, causation, amount and extent of injuries, damages and losses claimed are at issue and Answering Defendant demands proof of same of Plaintiff as required by law. 43. The injuries and/or damages as alleged in the Complaint of Plaintiff are not the result of negligent conduct on the part of the Answering Defendant. 44. The Complaint of Plaintiff is barred by the applicable Statute of Limitations. 45. Answering Defendant is not responsible for persons, events, circumstances or conditions reasonably beyond her control. 46. The Complaint of Plaintiff fails to state a cause of action upon which relief can be granted. 47. Plaintiff's Complaint sets forth claims against Answering Defendant, some or all of which may be barred by the conduct of the Plaintiff, and the relevant events therein. To this extent that Plaintiff's claims may be barred by the Doctrine of Comparative Negligence as enunciated under Pennsylvania law. 48. Plaintiff may have assumed the risk. 49. Any and all treatment and care provided by Answering Defendant was in accordance with the standard of care set forth in the medical community. 50. Plaintiff's claim is limited by the terms of any release which Plaintiff may have signed. vi 51. At all times material hereto, Answering Defendant provided proper and appropriate care and treatment to the Plaintiff. 52. Any injuries alleged and/or suffered by Plaintiff was the result of negligent and/or careless acts and/or omissions by persons and/or entities over whom Answering Defendant exercised no control. 53. The claims of Plaintiff may be barred by the Doctrine of Superseding and Intervening Cause. 54. Any award given to Plaintiff shall be offset by any public collateral source of compensation or benefits pursuant to Section 508 of the MCARE Act, which is incorporated by reference herein as though fully set forth at length. 55. No act or omission on the part of Answering Defendant could be considered the legal cause of any of the damages as set forth in the Complaint. WHEREFORE, Answering Defendant respectfully demands judgment in her favor, together with costs, interest and attorneys' fees. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN DATE: April 4, 2014 By F' DER ROLLER MARY E McGRATH MICHELLE I. MOSES Attorneys for Defendants, Susan J. Rosso, D.P.M. and Zlotoff, Gilfert & Gold, P.C. VERIFICATION Mary Kate McGrath verifies that she is an attorney of record for the Answering Defendant in this lawsuit, and that the answers are true and correct to the best of her knowledge, information and belief. This Verification is made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. DATE: April 4, 2014 Mary ate McGrath, Esq. CERTIFICATE OF SERVICE I, Mary Kate McGrath, Esquire, counsel for Susan J. Rosso, D.P.M., and Zlotoff, Gilfert & Gold, P.C., do hereby certify that on the 3th day of April, 2014, a true and correct copy of Answer with New Matter to Complaint of Defendant, Susan JRosso, D.P.M, in connection with the above-captioned matter, was served via regular U.S. mail upon the following individuals: Dennis M. Abrams, Esquire Lowenthal & Abrams, PC 555 City Line Avenue - Suite 500 Bala Cynwyd, PA 19004 Mary Ka McGrath, Esq. LOWENTHAL & ABRAMS, PC By: Dennis M. Abrams, Esquire Identification No. 40181 555 City Line Avenue, Suite 500 Bala Cynwyd, PA 19001 (610) 667-7511 JENNIFER ELLIS v. SUSAN J. ROSSO, DPM and ZLOTOFF, GILFERT & GOLD, PC APR -9 Arilt : b2 CUVIDERL AND COUNTY PENNSYLVANiA Attorneys for Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : NO. 13-5763 PLAINTIFF'S REPLY TO NEW MATTER OF DEFENDANT ZLOTOFF, GILFERT & GOLD, PC NOW COMES the Plaintiff, Jennifer Ellis, by and through counsel, Lowenthal & Abrams, PC, for and in response to the New Matter of the Defendant Zlotoff, Gilfert & Gold, PC and with respect to each corresponding paragraph thereof state: 41. Plaintiff incorporates by reference paragraphs 1 through 40 of her Amended Complaint as though set forth fully at length herein. 41-47. Denied. Plaintiffs are advised by counsel the corresponding averments constitute conclusions of law to which the Rules of Civil Procedure require no response. 48. Denied. Plaintiffs are advised by counsel the corresponding averments constitute conclusions of law to which the Rules of Civil Procedure require no response. By way of further reply, it is specifically denied that Plaintiff voluntarily assumed any risk of injury. 49-55. Denied. Plaintiffs are advised by counsel the corresponding averments constitute conclusions of law to which the Rules of Civil Procedure require no response. WHEREFORE Plaintiff respectfully requests the Answer and New Matter of Defendant Zlotoff, Gilfert & Gold, PC be struck and that she accorded the relief requested in her Complaint. LOWENTHAL & ABRAMS, PC 2 VERIFICATION I, JENNIFER ELLIS, hereby verify that I am a plaintiff in the within civil action, and that the facts set forth in the foregoing Reply to New Matter are true and accurate to the best of my knowledge, information and belief. I understand that this statement is made subject to the penalties of 18 P.C.S.A. §4904, relating to unsworn falsification to authorities. CERTIFICATION OF SERVICE 1, Dennis M. Abrams, Esquire, of the law firm of Lowenthal & Abrams, P.C., hereby certify that on April 7, 2014, 1 served true and correct copies of the foregoing by United States first class mail, postage pre-paid, to the following: Mary Kate McGrath, Esquire Marshall Dennehey Warner Coleman & Goggin 2000 Market Street Suite 2300 Philadelphia, PA 19103 BY: LOWENTHAL & ABRAMS, P.C. S M. ABRAMS, ESQ Counsel for plaintiff 3 LOWENTHAL & ABRAMS, PC By: Dennis M. Abrams, Esquire Identification No. 40181 555 City Line Avenue, Suite 500 Bala Cynwyd, PA 19001 (610) 667-7511 JENNIFER ELLIS v. SUSAN J. ROSSO, DPM and ZLOTOFF, GILFERT & GOLD, PC 9 11 5 a COUNT EBIIISYLVANIA, Attorneys for Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : NO. 13-5763 PLAINTIFF'S REPLY TO NEW MATTER OF DEFENDANT SUSAN J. ROSS, DPM NOW COMES the Plaintiff, Jennifer Ellis, by and through counsel, Lowenthal & Abrams, PC, for and in response to the New Matter of the Defendant Susan J. Rosso, DPM and with respect to each corresponding paragraph thereof state: 41. Plaintiff incorporates by reference paragraphs 1 through 40 of her Amended Complaint as though set forth fully at length herein. 41-47. Denied. Plaintiffs are advised by counsel the corresponding averments constitute conclusions of law to which the Rules of Civil Procedure require no response. 48. Denied. Plaintiffs are advised by counsel the corresponding averments constitute conclusions of law to which the Rules of Civil Procedure require no response. By way of further reply, it is specifically denied that Plaintiff voluntarily assumed any risk of injury. 49-55. Denied. Plaintiffs are advised by counsel the corresponding averments constitute conclusions of law to which the Rules of Civil Procedure require no response. WHEREFORE Plaintiff respectfully requests the Answer and New Matter of Defendant Susan J. Rosso, DPM be struck and that she accorded the relief requested in her Complaint. LOWENTHAL & ABRAMS, PC BY: DE fNIS M.(BRAMS, ESQUIRE 2 VERIFICATION I, JENNIFER ELLIS, hereby verify that I am a plaintiff in the within civil action, and that the facts set forth in the foregoing Reply to New Matter are true and accurate to the best of my knowledge, information and belief. I understand that this statement is made subject to the penalties of 18 P.C.S.A. §4904, relating to unsworn falsification to authorities. CERTIFICATION OF SERVICE I, Dennis M. Abrams, Esquire, of the law firm of Lowenthal & Abrams, P.C., hereby certify that on April 7, 2014, I served true and correct copies of the foregoing by United States first class mail, postage pre-paid, to the following: Mary Kate McGrath, Esquire Marshall Dennehey Warner Coleman & Goggin 2000 Market Street Suite 2300 Philadelphia, PA 19103 BY: LOWENTHAL & ABRAMS, P.C. DENNIS M. ABRAMS, ESQUIRE Counsel for plaintiff 3 CERTIFICATE PREREQUISITE TO SERVICE OF A'SUBPOENA PURSUANT TO RULE 4009.22 CRIGINAL IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM CUMBERLAND -VS- CASE NO: 13-- �-`S.'3 -6 N As a prerequisite to service of a subpoena for documents and things pu_�s_uant to Rule 4009.22 =; ' SUSAN ROSSO, D.P.M. MCS on behalf of FREDERIC ROLLER, 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: 04/11/2014 Attorney for DEFENDANT MCS # 97110 -L14 DE11 COMMONWEALTH OF PENNSYLVANIA IN THE MATTER OF: JENNIFER ELLIS COUNTY OF CUMBERLAND -VS- SUSAN ROSSO, D.P.M. COURT OF COMMON PLEAS TERM, CASE NO: 13 -5763 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DR. ASHLEY SUMMER MEDICAL, BILLING, AND X- RAY(S) JOHNS HOPKINS RHEUMATOLOGY CLI MEDICAL, BILLING, AND X- RAY(S) DR. BRIAN GOLDSTEIN MEDICAL, BILLING, AND X- RAY(S) TO: DENNIS ABRAMS, ESQ., PLAINTIFF COUNSEL MCS on behalf of FREDERIC ROLLER, 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: 03/20/2014 CC: FREDERIC ROLLER, ESQ. DENNIS ABRAMS, ESQ. LOWENTHAL & ABRAMS 555 CITY LINE AVENUE SUITE 500 BALA CYNWYD, PA 19004 - 16246.00282 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246 -0900 MCS # 97110 -001 DE02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13 -5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. ASHLEY SUMMER (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 * * ** 1 at The MCS Group, 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: FREDERIC ROLLER. ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA. PA 19103 TELEPHONE: (215) 246 -0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant rrpR .11- 201 Date: 3frihr Seal of the Court BY THE COURT: Prothonotary /Clerk, Civil Division EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. ASHLEY SUMMER 225 E. CITY AVENUE SUITE 109 BALA CYNWYD, PA 19004 RE: MCS # 97110 -L14 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06 -16 -1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x -rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110 -L14 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13 -5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 04/11/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110 -L15 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13 -5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JOHNS HOPK NS RHEUMATOLOGY CLINIC (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 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: FREDERIC ROLLER. ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA. PA 19103 TELEPHONE: (215) 246 -0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOHNS HOPKINS RHEUMATOLOGY CLINIC 5601 LOCH RAVEN BLVD. 507 RUSSEL MORGAN BALTIMORE, MD 21239 RE: MCS # 97110-L15 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX-XX-0447 Date of Birth: 06-16-1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests. including CAT scans, CT scans, EEGs. EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L15 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13 -5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 04/11/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110 -L16 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13 -5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. BRIAN GOLDSTEIN (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 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA, PA 19103 TELEPHONE: (215) 246 -0900 SUPREME COURT ID #: ATTORNEY FOR: Dgf ndant Date: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. BRIAN GOLDSTEIN 308 LEVERING MILL ROAD BALA CYNWYD, PA 19004 RE: MCS # 97110 -L16 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06 -16 -1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans. CT scans, EEGs, EKGs. EMGs. MRIs and x -rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110 -L16 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13 -5763 SUSAN ROSSO, D.P.M. c °)} As a prerequisite to service of a subpoena for documents and things- Ypsu4t to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, ESQ. certifies that t7) (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: 04/05/2014 MCS lf of DERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110 -L04 DE11 COMMONWEALTH OF PENNSYLVANIA IN THE MATTER OF: JENNIFER ELLIS COUNTY OF CUMBERLAND -VS- SUSAN ROSSO, D.P.M. COURT OF COMMON PLEAS TERM, CASE NO: 13 -5763 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: DENNIS ABRAMS, ESQ., PLAINTIFF COUNSEL MCS on behalf of FREDERIC ROLLER, 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: 03/14/2014 CC: FREDERIC ROLLER, ESQ. DENNIS ABRAMS, ESQ. LOWENTHAL & ABRAMS 555 CITY LINE AVENUE SUITE 500 BALA CYNWYD, PA 19004 - 16246.00282 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246 -0900 MCS # 97110 -001 DE02 »> LOCATION LIST «< PAGE: 1 LOCATION NAME RECORDS REQUESTED DR. LISA TKATCH MUELLER FAMILY PRACTICE DAVID S. TODOROFF, DPM DR. HOWARD ZLOTOFF, M.D. DR. ASMA KHAN DR. MAROMI NEI NANCY FAN, M.D. RONALD M. SCHLANSKY, MD. DR. CHRISTINE MACKLEY DR. ADIL M. WAHEED MEDICAL, BILLING, AND X- RAY(S) MEDICAL, BILLING, AND X- RAY(S) MEDICAL, BILLING, AND X- RAY(S) MEDICAL, BILLING, AND X- RAY(S) MEDICAL, BILLING, AND X- RAY(S) MEDICAL, BILLING, AND X- RAY(S) MEDICAL, BILLING, AND X- RAY(S) MEDICAL, BILLING, AND X- RAY(S) MEDICAL, BILLING, AND X- RAY(S) MEDICAL, BILLING, AND X- RAYS) MCS # 97110 -CO1 DE02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS File No. 13 -5763 vs. SUSAN ROSSO, D.P.M. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. LISA TKATCH (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 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA. PA 19103 TELEPHONE: (215) 246 -0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: APR 05 2074 *if Seal of the Court BY THE CO T: • 1 Prothonotary/Clerk, Civil Division _46P/1ft E_ Deputy EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. LISA TKATCH 205 S. FRONT STREET SUITE 6A PHILADELPHIA, PA 17104 RE: MCS # 97110 -L04 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06 -16 -1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x -rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110 -L04 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13 -5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 04/05/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110 -L05 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS - File No. 13 -5763 vs. SUSAN ROSSO, D.P.M. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MUELLER FAMILY PRACTICE (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 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA. PA 19103 TELEPHONE: (215) 246 -0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: rrpR 0 5 201k Seal of the Court rothonotary/Clerk, Civil Division Deputy EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MUELLER FAMILY PRACTICE 2025 TECHNOLOGY PARKWAY SUITE 207 MECHANICSBURG, PA 17050 RE: MCS # 97110 -L05 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06 -16 -1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication . and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x -rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110 -L05 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13 -5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 04/05/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110 -L06 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. - -File No. 13 -5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DAVID S. TODOROFF, DPM (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 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA, PA 19103 TELEPHONE: (215) 246 -0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: 'APR 05 2094 3PP Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DAVID S. TODOROFF, DPM 6100 OLD JONESTOWN ROAD SUITE B HARRISBURG, PA 17112 RE: MCS # 97110 -L06 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06 -16 -1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x -rays and all corresponding reports or. inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospital s, $100.00 for all other providers. MCS # 97110 -L06 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13 -5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 04/05/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110 -L07 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. - File No. 13-5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. HOWARD ZLOTOFF, M.D. (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 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: FREDERIC ROLLER, ESQ. ADDRESS: 000 MARKET STREET SUITE 2300 PHILADELPHIA, PA 19103 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY TIIE COURT: Prothonotary/Clerk, Civil Division Deputy 97110-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. HOWARD ZLOTOFF, M.D. 5108 E TRINDLE ROAD SUITE 100 MECHANICSBURG, PA 17050 RE: MCS # 97110-L07 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX-XX-0447 Date of Birth: 06-16-1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda. handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests. including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. • MCS # 97110-L07 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13 -5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 04/05/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110 -L08 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. - -File No. 13 -5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. ASMA KHAN (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 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: FREDERIC ROLLER. ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 TELEPHONE: (215) 246 -0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court rAPP 05 2014 BY THE COURT: Prothonotary/Clerk, Civil Division EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. ASMA KHAN 23 N. MAIN STREET BIGLERVILLE, PA 17307 RE:* MCS # 97110-L08 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX-XX-0447 Date of Birth: 06-16-1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L08 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 04/05/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L09 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. - -File No. 13 -5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. MAROMI NEI (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 * * ** U :11 '1 .1-.so. • .I.: 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA, PA 19103 TELEPHONE: (215) 246 -0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: BY THE COURT: Prothonotary/Clerk, Civil Division 24"-e4j2X- rApR Q 5 2014 l4 / Deputy Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. MAROMI NEI 909 WALNUT STREET 2ND FLOOR PHILADELPHIA, PA 19107 RE: MCS # 97110 -L09 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06 -16 -1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x -rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110 -L09 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13 -5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 04/05/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110 -L10 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.F.M. File No. 13 -5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for NANCY FAN, M.D. (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 ThQMC'_S Group, 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA, PA 19103 TELEPHONE: (215) 246 -0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court rAPR 0 5 2014 Prothonotary /Clerk, Civil Division EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: NANCY FAN, M.D. 213 GREENHILL AVE. #B WILMINGTON, DE 19805 RE: MCS # 97110 -L10 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06 -16 -1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x -rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110 -L10 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13 -5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 04/05/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110 -L11 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13 -5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for RONALD M. SCHLANSKY, MD. (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 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: FREDERIC ROLLER. ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA., PA 19103 TELEPHONE: (215) 246 -0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: •rApR 05 2014 Seal of the Court BY THE COURT: Prothonotary /Clerk, Civil Division Deputy EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: RONALD M. SCHLANSKY, MD. 220 WILSON STREET SUITE 104 CARLISLE, PA 17013 RE: MCS # 97110 -L11 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06 -16 -1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x -rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS #97110 -L11 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13 -5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 04/05/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110 -L12 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13 -5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. CHRISTINE MACKLEY (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 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: FREDERIC ROLLER, ESO. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA. PA 19103 TELEPHONE: (215) 246 -0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: BY THE COURT: Prothonotary /Clerk, Civil Division rAPR 05 2014 L2-i A ? ':?7 `� /� /4-( Deputy Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. CHRISTINE MACKLEY 530 WALTON AVENUE HUMMELSTOWN, PA 17036 RE: MCS # 97110 -L12 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06 -16 -1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x -rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110 -L12 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13 -5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 04/05/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110 -L13 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS File No. 13 -5763 vs. SUSAN ROSSO, D.P.M. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. ADIL M. WAHEED (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 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA, PA 19103 TELEPHONE: (215) 246 -0900 SUPREME COURT ID #: ATTORNEY FOR: DPfenc➢ant Date: BY THE COURT: Prothonotary/Clerk, Civil Division Seal of the Court 97110 -13 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. ADIL M. WAHEED 503 N. 21ST STREET CAMP HILL, PA 17011 RE: MCS # 97110 -L13 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06 -16 -1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x -rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110 -L13 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13 -5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things gAiivaii-t rl to Rule 4009.22 2 - CD ", ry MCS on behalf of FREDERIC ROLLER, 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: 04/21/2014 MCS o ?' -lf of FR (ERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110 -L17 DE11 COMMONWEALTH OF PENNSYLVANIA IN THE MATTER OF: JENNIFER ELLIS COUNTY OF CUMBERLAND -VS- SUSAN ROSSO, D.P.M. COURT OF COMMON PLEAS TERM, CASE NO: 13 -5763 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: DENNIS ABRAMS, ESQ., PLAINTIFF COUNSEL MCS on behalf of FREDERIC ROLLER, 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: 03/28/2014 CC: FREDERIC ROLLER, ESQ. DENNIS ABRAMS, ESQ. LOWENTHAL & ABRAMS 555 CITY LINE AVENUE SUITE 500 BALA CYNWYD, PA 19004 - 16246.00282 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246 -0900 MCS # 97110 -001 DE02 »> LOCATION LIST «< PAGE: 1 LOCATION NAME RECORDS REQUESTED MCCANN CHIROPRACTIC CENTER PREMIERE PSYCHIATRY ASSOCIATES DR. MICHAEL BAER, M.D. KEVIN CLAWSON, M.D. DR. BENYAM TEGENE, M.D. DR. SHARON CLINE, M.D. SHASHANK C. SRIVASTAVA, DPM DR. CHARLES S. YANOFSKY, M.D. PAUL H. MCCABE, M.D. ZLOTOFF, GILFERT, GOLD & ASSOC MEDICAL, BILLING, AND X- RAY(S) MEDICAL, BILLING, AND X- RAY(S) MEDICAL, BILLING, AND X- RAY(S) MEDICAL, BILLING, AND X- RAY(S) MEDICAL, BILLING, AND X- RAYS) MEDICAL, BILLING, AND X- RAY(S) MEDICAL, BILLING, AND X- RAY(S) MEDICAL, BILLING, AND X- RAY(S) MEDICAL, BILLING, AND X- RAY(S) MEDICAL, BILLING, AND X- RAYS) MCS # 97110 -001 DE02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13 -5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MCCANN CHIROPRACTIC 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 Group. 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA, PA 19103 TELEPHONE: (215) 246 -0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MCCANN CHIROPRACTIC CENTER 241 YORK ROAD CARLISLE, PA 17013 RE: MCS # 97110 -L17 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06 -16 -1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x -rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110 -L17 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13 -5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 04/21/2014 MCS of F =� RIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110 -L18 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13 -5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PREMIERE PSYCHIATRY ASSOCIATES (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 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: FREDERIC ROLLER. ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA, PA 19103 TELEPHONE: (215) 246 -0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: 3ks�y 1 2014 Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PREMIERE PSYCHIATRY ASSOCIATES 3461 MARKET ST. SUITE 102 CAMP HILL, PA 17011 RE: MCS # 97110 -L18 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06 -16 -1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x -rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110 -L18 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13 -5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 04/21/2014 FRE ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110 -L19 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13 -5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. MICHAEL BAER, M.D. (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 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA. PA 19103 TELEPHONE: (215) 246 -0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Sks� /PR z � 2014 Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. MICHAEL BAER, M.D. 211 BROAD ST. MARYSVILLE, PA 17053 RE: MCS # 97110 -L19 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06 -16 -1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x -rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110 -L19 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13 -5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 04/21/2014 FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110 -L20 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13 -5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for KEVIN CLAWSON. M.D. (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 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 P I LADELPHIA. PA 19103 TELEPHONE: (215) 246 -0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: APR 21'2014 Seal of the Court BY THE COURT: Pr; honotary/Cl 1 Division De uty EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: KEVIN CLAWSON, M.D. 220 WILSON STREET #104 CARLISLE, PA 17103 RE: MCS # 97110 -L20 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06 -16 -1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x -rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110 -L20 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 04/21/2014 ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L21 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13 -5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. BENYAM TEG NE. M.D. (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 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA. PA 19103 TELEPHONE: (215) 246 -0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: NAPR 2 120W Seal of the Court BY THE COURT: De ! uty EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. BENYAM TEGENE, M.D. 3461 MARKET ST. # 102 CAMP HILL, PA 17011 RE: MCS # 97110-L21 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX-XX-0447 Date of Birth: 06-16-1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans. EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $15O.00 for hospitals, $100.00 for all other providers. MCS # 97110-L21 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 04/21/2014 R R ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L22 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13 -5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. SHARON CLINE. M.D. (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 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA, PA 19103 TELEPHONE: (215) 246 -0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: 05)Villt 2 a zma Seal of the Court BY THE COURT: Rx\■. &kELL P� thonotary/C1: rk =vil Division A.* D; •uty EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. SHARON CLINE, M.D. 100 COMMUNITY DR. SUITE 102 TOBYHANNA, PA 18466 RE: MCS # 97110-L22 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX-XX-0447 Date of Birth: 06-16-1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L22 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 04/21/2014 FRED C ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L23 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13 -5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for SHASHANK C. SRIVASTAVA, DPM (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 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA, PA 19103 TELEPHONE: (215) 246 -0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY THE COURT: ck\az x. Pr;, honotary/Cle k, Ci it Division De uty EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SHASHANK C. SRIVASTAVA, DPM 2401 RESERARCH BLVD. SUITE 350 ROCKVILLE, MD 20850 RE: MCS # 97110 -L23 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06 -16 -1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x -rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110 -L23 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13 -5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 04/21/2014 FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110 -L24 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13 -5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR, CHARLES S. YANOFSKY, M.D, (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 Ma ket 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: FREDERIC ROLLER. ESQ. ADDRESS: 2090 MARKET STREET SUITE 2300 PHILADELPHIA, PA 19103 TELEPHONE: (215) 246 -0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: 3 /asky APR 2 Seal of the Court BY THE COURT: EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. CHARLES S. YANOFSKY, M.D. 2025 TECHNOLOGY PARKWAY SUITE 201 MECHANICSBURG, PA 17050 RE: MCS # 97110 -L24 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06 -16 -1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x -rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110 -L24 SU1O CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 04/21/2014 MCS o FREDEIt OLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L25 DEll COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13 -5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PAUL H. MCCABE, M.D. (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 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE2300 PHILADELPHIA, PA 19103 TELEPHONE: (215) 246 -0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: shcig APR 2 Y 2014 Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PAUL H. MCCABE, M.D. 2025 TECHNOLOGY PARKWAY SUITE 201 MECHANICSBURG, PA 17050 RE: MCS # 97110-L25 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX-XX-0447 Date of Birth: 06-16-1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records. correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L25 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 04/21/2014 MCS on ¼1 FR ERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L26 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.F.M. File No. 13 -5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ZLOTOFF, GILFERT. GOLD & ASSOCIATES (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 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA. PA 19103 TELEPHONE: (215) 246 -0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: ,,25,/tOPR 014 Seal of the Court Y THE COURT: • Prs� onotary/Cler Civil D EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ZLOTOFF, GILFERT, GOLD & ASSOCIATES 5108 EAST TRINDLE ROAD SUITE 100 MECHANICSBURG, PA 17050 RE: MCS # 97110-L26 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX-XX-0447 Date of Birth: 06-16-1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs. MRIs and x-rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L26 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things rsuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 05/06/2014 FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L27 DE11 COMMONWEALTH OF PENNSYLVANIA IN THE MATTER OF: JENNIFER ELLIS COUNTY OF CUMBERLAND -VS- SUSAN ROSSO, D.P.M. COURT OF COMMON PLEAS TERM, CASE NO: 13-5763 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 MARIANTHI KIRKIDOU, M.D. SABIHA KHAN, M.D. JUWARIA WAHEED, M.D. MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS & XRAYS MEDICAL, BILLING, AND X-RAY(S) TO: DENNIS ABRAMS, ESQ., PLAINTIFF COUNSEL MCS on behalf of FREDERIC ROLLER, 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: 04/14/2014 CC: FREDERIC ROLLER, ESQ. DENNIS ABRAMS, ESQ. LOWENTHAL & ABRAMS 555 CITY LINE AVENUE SUITE 500 BALA CYNWYD, PA 19004 - 16246.00282 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 MCS # 97110-001 DE02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13-5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MARIANTHI KIRKIDOU, M.D. (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 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA. PA 19103 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: LI 1019 MAY 062014 Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division 97110-27 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MARIANTHI KIRKIDOU, M.D. 833 CHESTNUT ST. SUITE 640 PHILADELPHIA, PA 19107 RE: MCS # 97110-L27 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06-16-1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records. correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L27 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 05/06/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L28 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13-5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for SABIHA KHAN. M.D. (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 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: FREDERIC ROLLER. ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA PA 19103 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: 'MAY 0 6 2014 Lii91/ Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division 97110-28 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SABIHA KHAN, M.D. 7315 WISCONSIN AVENUE JOHNS HOPKINS COMM. BETHESDA, MD 20814 RE: MCS # 97110-L28 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06-16-1972 Please provide entire medical and diagnostic film file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records, correspondence to and from the consulting and treating physicians. Include all files, memoranda, handwritten records and notes, emails, phone messages, history and physical reports. Supply all medication and prescription records. Provide all diagnostic films and tests, including CAT scans, CT scans, EEG's EKG'S, EMG'S, MRI'S, and x-ray and all corresponding reports or inventories. This should contain all records in your possession, all office and admission charts, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L28 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 05/06/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L29 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13-5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JUWARIA WAHEED. M.D. (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 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA, PA 19103 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: 1' Irk/ MAY 0 6 2014 Seal of the Court Prothonotary/Clerk, Civil Division 97110-29 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JUWARIA WAHEED, M.D. 5601 LOCH RAVEN BLVD GOOD SAMARITAN #507 BALTIMORE, MD 21239 RE: MCS # 97110-L29 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06-16-1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILMS PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L29 SU10 • 4 • MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Frederic Roller Mary Kate McGrath Michelle 1. Moses Identification Nos.: 65513/90690/207723 2000 Market Street, 2591 Floor Philadelphia, PA 19103 (215) 575-2260 '2 '111tp143,11?,1 • CNitip coo, LVAIll A Attorneys for Defendants: Susan J. Rosso, DPM and Zlotoff Gilfert & Gold, PC JENNIFER ELLIS V. SUSAN J. ROSSO, D.P.M. and ZLOTOFF, GILFERT & GOLD, P.C. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 13-5763 PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the Verification of Susan Rosso, D.P.M., attached as Exhibit "A", to the Answer and New Matter to Plaintiffs Complaint, which was previously filed in reference to the above -captioned matter. DATE: May 28, 2014 MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN By FREDER ROLLER MARY TE McGRATH MICHELLE I. MOSES Attorneys for Defendants, Susan J. Rosso, D.P.M. and Zlotoff, Gilfert & Gold, P.C. MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Frederic Roller Mary Kate McGrath Michelle I. Moses Identification Nos.: 65513/90690/207723 2000 Market Street, 25th Floor Philadelphia, PA 19103 (215) 575-2260 Attorneys for Defendants: Susan J. Rosso, DPM and Zlotoff Gilfert & Gold, PC JENNIFER ELLIS v. SUSAN J. ROSSO, D.P.M. and ZLOTOFF, GILFERT & GOLD, P.C. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 13-5763 CERTIFICATE OF SERVICE I, Mary Kate McGrath, Esquire, counsel for Susan J. Rosso, D.P.M., and Zlotoff, Gilfert & Gold, P.C., do hereby certify that on this date, a true and correct copy of Praecipe to Substitute Verification to Answer with New Matter of Defendant, Susan J.Rosso, D.P.M., in connection with the above -captioned matter, was served via regular U.S. mail upon the following individuals: DATE: May 28, 2014 Dennis M. Abrams, Esquire Lowenthal & Abrams, PC 555 City Line Avenue - Suite 500 Bala Cynwyd, PA 19004 MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN By 1v�/ FREDERI ROLLER MARY K E McGRATH MICHELLE I. MOSES Attorneys for Defendants, Susan J. Rosso, D.P.M. and Zlotoff, Gilfert & Gold, P.C. VERIFICATION Susan J. Rosso, D.P.M. verifies that she is a Defendant in this lawsuit, that she has reviewed the foregoing Answer with New Matter to Plaintiffs Complaint , and that the answers are based on information furnished to counsel and/or information which has been gathered by counsel in the course of this lawsuit. The language is that of counsel and not of signer. Signer verifies that she has read the answers and that they are true and correct to the best of her knowledge, information and belief. To the extent that the contents are that of counsel, signer has relied upon counsel in taking this Verification. This Verification is made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Susan J. Rosso, D.P.M. DATE: (4,1k4-0.1 16246.00282 0.7 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 ORIGINAL IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, ESQ. certifies that rrZ f -T1 r— < .1> m CD C--) 171 \ (1) A notice of intent to serve the subpoena with a copy of the-ASubpoerie0 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: 08/26/2014 MCS o' f of FR PERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L30 DE11 COMMONWEALTH OF PENNSYLVANIA IN THE MATTER OF: JENNIFER ELLIS COUNTY OF CUMBERLAND -VS- SUSAN ROSSO, D.P.M. COURT OF COMMON PLEAS TERM, CASE NO: 13-5763 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 SHARON CLINE, M.D. MEDICAL, BILLING, AND RADIOLOGY DR. BEVERLEY UNIACKE MEDICAL, BILLING, AND RADIOLOGY TO: DENNIS ABRAMS, ESQ., PLAINTIFF COUNSEL MCS on behalf of FREDERIC ROLLER, 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. DATE: 08/04/2014 CC: FREDERIC ROLLER, ESQ. - 16246.00282 DENNIS ABRAMS, ESQ. LOWENTHAL & ABRAMS 555 CITY LINE AVENUE SUITE 500 BALA CYNWYD, PA 19004 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 MCS # 97110-001 DE02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13-5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for SHARON CLINE. M.D. (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 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA, PA 19103 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division 97110-30 - EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SHARON CLINE, M.D. 2501 N THIRD STREET HARRISBURG, PA 17110 RE: MCS # 97110-L30 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06-16-1972 Please Provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating.physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs. EMGs, MRIs and x-rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILM PRIOR TO SENDING ANY STUDIES. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L30 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 08/26/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L31 DEll COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13-5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE4009.22 TO: Custodian of Records for DR. BEVERLEY UNIACKE (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 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA, PA 19103 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date,_ ?o ji Seal of the Court BY THE COURT: Prothonotary/Clerk, C ivil Division (1'7 1 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. BEVERLEY UNIACKE 1 TRINITY DRIVE SUITE 120 DISSBURG, PA 17019 RE: MCS # 97110-L31 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06-16-1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILM PRIOR TO SENDING ANY STUDIES. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L31 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 ORIGINAL IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pisuaiti to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, ESQ. certifies that �- rr j~' - --- C7 , -.7^t CD ---4 (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: 09/03/2014 MCS o •f'half of FRO RIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L32 DE11 COMMONWEALTH OF PENNSYLVANIA IN THE MATTER OF: JENNIFER ELLIS COUNTY OF CUMBERLAND -VS- SUSAN ROSSO, D.P.M. COURT OF COMMON PLEAS TERM, CASE NO: 13-5763 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations TO: DENNIS ABRAMS, ESQ., PLAINTIFF COUNSEL MCS on behalf of FREDERIC ROLLER, 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. DATE: 08/12/2014 CC: FREDERIC ROLLER, ESQ. - 16246.00282 DENNIS ABRAMS, ESQ. LOWENTHAL & ABRAMS 555 CITY LINE AVENUE SUITE 500 BALA CYNWYD, PA 19004 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 MCS # 97110-001 DE02 »> LOCATION LIST «< PAGE: LOCATION NAME RECORDS REQUESTED DR. CHRISTINE MACKLEY MEDICAL RECORDS, BILLING & PATHOLOGY ROTHMAN INSTITUTE MEDICAL RECORDS ROTHMAN INSTITUTE BILLING ONLY ROTHMAN INSTITUTE RADIOLOGY ROTHMAN INSTITUTE PATHOLOGY JOHNS HOPKINS HOSPITAL MEDICAL RECORDS JOHNS HOPKINS HOSPITAL BILLING ONLY JOHNS HOPKINS UNIV. HOSPITAL RADIOLOGY JOHNS HOPKINS UNIVERSITY PATHOLOGY MCS # 97110-001 DE02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13-5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. CHRISTINE MACKLEY (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 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA. PA 19103 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court honotary/Clerk, Civil Division 97110-32 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. CHRISTINE MACKLEY 530 WALTON AVENUE HUMMELSTOWN, PA 17036 RE: MCS # 97110-L32, JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06-16-1972 Please provide entire medical file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records files, memoranda, handwritten notes, emails, phone messages, history, physical reports. and all prescriptions records. Billing - Please provide any and all billing, insurance claims, and payments, outstanding and delinquent invoices. Pathology - Including all pathology materials, all blocks, slides, toxicological or pharmacological analyses and corresponding reports. This should contain all records in your possession, all office and admission charts. all archived records, or records in storage. Including any and all items as may be stored in a computer data base or otherwise electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L32 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 09/03/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L33 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13-5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ROTHMAN 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 The MCS Group. 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA. PA 19103 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: /) / (4S E Seal of the Court 201 BY THE COURT: o Prothonotary/Clerk, Civil Division 97110-33 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ROTHMAN INSTITUTE LEGAL DEPT. 925 CHESTNUT STREET PHILADELPHIA, PA 19107 RE: MCS # 97110-L33 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06-16-1972 Please provide entire medical file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records files, memoranda, handwritten notes, emails, phone messages, history, physical reports, Laboratory & office/admission charts, and all prescriptions records. This should contain all records in your possession, all office and admission charts, all archived records, or, records in storage. Including any and all items as:may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L33 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 09/03/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L34 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13-5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ROTHMAN 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 The MCS Group. 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: FREDERIC ROLLER. ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA. PA 19103 IELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: SEP BY THE COURT: rothonotary/Clerk, Civil Division 3 2014 Deputy Seal of the Court 97110-34 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ROTHMAN INSTITUTE BILLING DEPT. 14TH FL 925 CHESTNUT STREET PHILADELPHIA, PA 19107 RE: MCS # 97110-L34 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06-16-1972 Please provide any and all billing, insurance claims, and payments, outstanding and delinquent invoices. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L34 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 09/03/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L35 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13-5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ROTHMAN 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 The MCS Group, 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: FREDERIC ROLLER. ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPH • , PA 19103 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: BY THE COURT: Seal of the Court Prothonota Deputy Clerk, Civil Division 97110-35 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ROTHMAN INSTITUTE RADIOLOGY DEPT. 925 CHESTNUT STREET PHILADELPHIA, PA 19107 RE: MCS # 97110-L35 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06-16-1972 Please provide any and all x-ray films, CT scans & MRI films and reports possession. all archived films and reports, or films and reports in storage. Including any and all such items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILM PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L35 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 09/03/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L36 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13-5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ROTH1vLAN 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 The MCS Group. 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA. PA 19103 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court Pro hono C erk, Civil Division 97110-'16 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ROTHMAN INSTITUTE PATHOLOGY DEPT. 925 CHESTNUT STREET PHILADELPHIA, PA 19107 RE: MCS # 97110-L36 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06-16-1972 Please provide any and all pathology reports and records. This should contain all pathology records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation. diagnosis care or treatment. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L36 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 09/03/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L37 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13-5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JOHN HOPKINS 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 The MCS Group. Inc . 1601 MarketStreet. Suite800. 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: FREDERIC ROLLER. ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA. PA 19103 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: s/) N SEP 0 3 2014 Seal of the Court hono ry/C erk, Civil Division 97110-37 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOHNS HOPKINS HOSPITAL MEDICAL RECORDS 1800 ORLEANS STREET BALTIMORE, MD 21287 RE: MCS # 97110-L37 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06-16-1972 Please provide the entire hospital medical file, including but not limited to all inpatient and outpatient, records, ER records, physical therapy records. intake or admission forms, correspondence to and from the consulting and treating physicians, and discharge forms. Include all files, memoranda, handwritten notes, history and physical reports. Including any and all laboratory & office/admission charts. Supply all medication and prescription records, nursesnotes, doctor's comments, dietary and all patient consent or refusal of treatment, . This should contain all records in your possession, including all archived records, records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L37 SU10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13-5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JOHN HOPKINS 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 The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 191113 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA. PA 19103 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: r/7//// SEP 03 2014 Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division 97110-38 EXPLANATION OF REQUIRED RECORDS T0: CUSTODIAN OF RECORDS FOR: JOHNS HOPKINS HOSPITAL BILLING DEPT. 1800 ORLEANS STREET BALTIMORE. MD 21287 RE: MCS # 97110-L38 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06-16-1972 Please provide any and all billing, insurance claims, and payments, outstanding and delinquent invoices. This should contain all records in your possession. all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L38 SU1O CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 09/03/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L39 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13-5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JOHN HOPKINS 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 The MCS Group. 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA. PA 19103 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court Prothonotary/Clerk, Civil Division Deputy 97110-39 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOHNS HOPKINS UNIV. HOSPITAL RADIOLOGY DEPT. 1800 ORLEANS STREET BALTIMORE, MD 21287 RE: MCS # 97110-L39 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06-16-1972 Please provide any and all x-ray films, CT scans & MRI films and reports possession, all archived films and reports, or films and reports in storage. Including any and all such items as may be stored in a computer database or otherwise in electronic form. PLEASE PROVIDE LIST OF FILM PRIOR TO SENDING ANY STUDIES Prior approval is required for fees in excess of $150.00 for hospitals,$100.00 for all other providers. MCS # 97110-L39 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 09/03/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L40 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13-5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JOHN HOPKINS 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 The MCS Group. 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: FREDERIC ROLLER. ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA. PA 19103 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: c/7 /y SEP 03204 Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy 97110-40 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOHNS HOPKINS UNIVERSITY 1800 ORLEANS STREET PATHOLOGY DEPT. BALTIMORE. MD 21287 RE: MCS # 97110-L40 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06-16-1972 Please provide any and all pathology reports and records. This should contain all pathology records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis care or treatment. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MP MCS # 97110-L40 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 P' L IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things prsu,ant,�; to Rule 4009.22 P1 ? •-- 0 r v up ` iv _� z- certifies that ✓ r r (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, MCS on behalf of FREDERIC ROLLER, ESQ. r 1 rr t; (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: 09/19/2014 MCS on i.L3 alf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L41 DEll COMMONWEALTH OF PENNSYLVANIA IN THE MATTER OF: JENNIFER ELLIS COUNTY OF CUMBERLAND -VS- SUSAN ROSSO, D.P.M. COURT OF COMMON PLEAS TERM, CASE NO: 13-5763 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: DENNIS ABRAMS, ESQ., PLAINTIFF COUNSEL MCS on behalf of FREDERIC ROLLER, 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. DATE: 08/28/2014 CC: FREDERIC ROLLER, ESQ. - 16246.00282 DENNIS ABRAMS, ESQ. LOWENTHAL & ABRAMS 555 CITY LINE AVENUE SUITE 500 BALA CYNWYD, PA 19004 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 MCS # 97110-001 DE02 LOCATION NAME »> LOCATION LIST «< PAGE: 1 RECORDS REQUESTED THE FRANKLIN COUNTY BAR ASSOCI LOWENTHAL & ABRAMS HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL DR. ERIC BINDER HIGHMARK, INC. GIANT INC EMPLOYMENT EMPLOYMENT MEDICAL RECORDS BILLING ONLY RADIOLOGY MEDICAL, BILLING, AND RADIOLOGY HEALTH INSURANCE PRESCRIPTION/PHARMACEUTICAL RECORDS MCS # 97110-CO1 DE02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13-5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for THE FRANKLIN COUNTY BAR ASSOCIATION (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 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA. PA 19103 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: SEP I Seal of the Court BYT Prothono . ry Clerk, Civ Division Deputy 97110-41 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: THE FRANKLIN COUNTY BAR ASSOCIATION 100 LINCOLN WAY EAST SUITE E CHAMBERSBURG, PA 17201 RE: MCS # 97110-L41 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06-16-1972 Any and all employment records„ including applications, files, memoranda, compensation, disciplinary actions, time and attendance records. Please include personnel records, W2 forms, payroll and salary information. Supply all employee medical records including any disability, workers compensation, or incident reports and claims. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L41 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 09/19/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L42 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13-5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for LOWENTHAL & ABRAMS (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 890. 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA, PA 19103 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: 8 021 -/IV la 1 Seal of the Court BY THE C • URT: _.1 Pro tary/C erk, Civil Division Deputy 97110-42 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: LOWENTHAL & ABRAMS 555 CITY INE AVE SUITE 500 BALA CYNWYD, PA 19004 RE: MCS # 97110-L42 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: 197-68-0447 Date of Birth: 06-16-1972 Any and all employment records„ including applications, files, memoranda, compensation, disciplinary actions, time and attendance records. Please include personnel records, W2 forms, payroll and salary information. Supply all employee medical records including any disability, workers compensation, or incident reports and claims. This should contain all records in your possession, all archived records, or records in storage. Including any and all Items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L42 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 09/19/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L43 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13-5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for 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 The MCS Group. 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA. PA 19103 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Prothonotary/Clerk, Civ Division SEP It 9 20 4 Deputy Date: Seal of the Court 97110-43 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL MEDICAL RECORDS 503 N. 21ST STREET CAMP HILL, PA 17011 RE: MCS # 97110-L43 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: 197-68-0447 Date of Birth: 06-16-1972 Please provide the entire hospital medical file, including but not limited to all inpatient and outpatient records, ER records, physical therapy records, intake or admission forms, correspondence to and from the consulting and treating physicians, and discharge forms. Include all files, memoranda, handwritten notes, history and physical reports. Including any and all laboratory & office/admission charts. Supply all medication and prescription records, nurses' notes, doctor's comments, dietary and all patient consent or refusal of treatment, . This should contain all records in your possession, including all archived records, records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L43 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 09/19/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L44 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13-5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for 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 The MCS Group. 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA. PA 19103 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: S e Court Prothonotary/Cler , Civil Di ision Deputy 97110-44 EXPLANATION OF REQUIRED RECORDS T0: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL BILLING DEPT. 503 N. 21ST STREET CAMP HILL, PA 17011 RE: MCS # 97110-L44 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: 197-68-0447 Date of Birth: 06-16-1972 Please provide any and all billing, insurance claims, and payments, outstanding and delinquent invoices. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L44 SU1O CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 09/19/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L45 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13-5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for 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 * * * * :1, '._ ,*- •i-, • 1 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA, PA 19103 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: SEP 1 614I y Seal of the Court to BY T 1 T: Prothono . ry rk, Civi Division Deputy 97110-45 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL RADIOLOGY DEPT. 503 N. 21ST STREET CAMP HILL, PA 17011 RE: MCS # 97110-L45 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: 197-68-0447 Date of Birth: 06-16-1972 Please provide any and all x-ray films, CT scans & MRI films and reports possession, all archived films and reports, or films and reports in storage. Including any and all such items as may be stored in a computer database or otherwise in electronic form. FILM INVENTORY Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L45 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 09/19/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L46 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No, 13-5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. ERIC BINDER (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 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: FREDERIC ROLLER, ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA. PA 19103 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant SER I 9 n Date: Seal of the Court BY do aordwor Prothon eflir/Clerk, Ci 1 Division Deputy 97110-46 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. ERIC BINDER SUSQUEHANNA INTERNAL MED. 890 POPLAR CHURCH RD CAMP HILL, PA 17011 RE: MCS # 97110-L46 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06-16-1972 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans. EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. FILM INVENTORY Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L46 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 09/19/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L47 DEll COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13-5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HIGEMARL.IN( 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 The MCS Group. Inc. 1601 Market Street. quite 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: FREDERIC ROLLER_ ESQ. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA. PA 19103 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court SEP 1 S 2014 BY T Prothono erk, Civil Deputy 97110-47 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HIGHMARK, INC. P.O. BOX 890035 CUSTOMER SERVICE CAMP HILL, PA 170890035 RE: MCS # 97110-L47 JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: 197-68-0447 Date of Birth: 06-16-1972 Please provide any and all records, pertaining to the member. Include all claims, claim notices, appeals, payments and reimbursements. Supply any and all medical records, reports, prescription and pharmacy records. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as maybe stored in a computer database_or otherwise in electronic form. POLICY NO.: ZAR104323734001, GROUP NO.: 02502188 Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L47 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER ELLIS TERM, CUMBERLAND -VS- CASE NO: 13-5763 SUSAN ROSSO, D.P.M. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of FREDERIC ROLLER, 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: 09/19/2014 MCS on behalf of FREDERIC ROLLER, ESQ. Attorney for DEFENDANT MCS # 97110-L48 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER ELLIS vs. SUSAN ROSSO, D.P.M. File No. 13-5763 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for GIANT INC (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 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 TRE REQUEST OF THE FOLLOWING PERSON: NAME: FREDERIC ROLLER, ESO. ADDRESS: 2000 MARKET STREET SUITE 2300 PHILADELPHIA, PA 19103 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY T d Prothono /Clerk, • ivil Division Deputy 97110-48 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: GIANT INC 255 CUMBERLAND PARKWAY MECHANICSBURG, PA 17055 RE: MCS # 97110-L48. JENNIFER ELLIS 412 STONEHEDGE LANE MECHANICSBURG, PA 17055 Social Security #: XXX -XX -0447 Date of Birth: 06-16-1972 Please provide entire prescription and pharmaceutical file, including but not limited to all records, reports, correspondence, memoranda, complete prescription and medication history, along with payment and insurance records. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 97110-L48 $U10 MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Frederic Roller / Mary Kate McGrath / Michelle Identification Nos. 65513 / 90690 / 207723 2000 Market Street Philadelphia, PA 19103 (215) 575-2770 / (215) 575-2863 / (215) 575-2758 JENNIFER ELLIS v. SUSAN J. ROSSO, D.P.M. and ZLOTOFF, GILFERT & GOLD, P.C. I. Moses UL.U-uFHli�h TIE PR0TH0 I0 iV ; frDEC 18 HI! 00 CUMBERLAND COUNTY Y Attorneys for: liplottalftVANLA Susan J. Rosso, DPM and Zlotoff, Gilfert & Gold, PC COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 13-5763 DEMAND FOR JURY TRIAL TO THE PROTHONOTARY: A jury trial consisting of 12 jurors is hereby demanded by Defendants, Susan J. Rosso, D.P.M. and Zlotoff, Gilfert & Gold, P.C., in the above -entitled matter. MARSHALL, DENNEHEY, WARNER, COLE ► 4 AN & GOGGIN FREDERIC ROLLER MARY KATE McGRATH MICHELLE I. MOSES Attorneys for Defendants, Susan J. Rosso, D.P.M. and Zlotoff, Gilfert & Gold, P.C. DATE: December 16, 2014