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HomeMy WebLinkAbout05-0949 . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RICKY J. SOUDERS, CIVIL DIVISION Plaintiff NO: O~ ~ 9l/9 ~~d YfI2.r\. vs. STEPHEN B. THOMAS, PRAECIPE FOR WRIT OF SUMMONS IN CIVIL ACTION Defendant Filed on Behalf of Plaintiffs: Counsel of Record for this Party: MICHAEL E. METRO, ESQUIRE Pa.J.D. No. 62185 VILLANOV ALA W OFFICES, P.C 16 Chatham Square Pittsburgh, PA 15219 A JURY TRIAL IS DEMANDED. (412) 471-1933 (412) 471.2733 Facsimile . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RICKY J. SOUDERS, CIVIL DIVISION Plaintiff NO: Of; -ql/? CI'U~tT~ vs. STEPHEN B. THOMAS, Defendant PRAECIPE FOR WRIT OF SUMMONS IN CIVIL ACTION TO THE PROTHONOTARY: Kindly file a Writ of Summons in Civil Action in regards to the above- captioned case. Respectfully submitted, 4rrr Michael E. Metro, Esquire Attorney for Plaintiff .. ' . ". " . pP \i.~ t".J - - btl .0 .c. -() -'Cl. lI\ lI\ l.1 Q -0 r- t- r '-- .~r\ 'c:) - .' i, g ,,__C r<' VILLANOVA LAW OFFICES, P.c. 16 Chatham Square Pittsburgh, P A 15219 James Villanova'" Michael E. Metro* (*Licensed in Pennsylvania and West Virginia) (412) 471.1933 Fax No. (412) 471.2733 February 15, 2005 Prothonotary, Cumberland County Cumberland County Court House Carlisle, PA 17103-3387 Re: Ricky Souders v. Stephen B. Thomas Date of Accident: May 1, 2003 .To Whom It May Concern: Enclosed for filing, please fmd an original and two copies of our Praecipe for Writ of Swnmons with reference to the above-captioned case. Would you please be so kind as to time-stamp one copy and return it to the undersigned in the enclosed, self-addressed, stamped envelope that we have provided for your convenience. Our check is enclosed in the amount of$55.50 for the filing fee. Would you then please be so kind as to forward the Praecipe to the Sheriff's Office of Cumberland County for service. We enclose a check in the amount of $100.00 made payable to Cumberland County Sheriff's Office as well as a check in the amount of $100.00 made payable to Fulton County Sheriff's Office for service upon Stephen B. Thomas at: Stephen B. Thomas 131 Forbes Trial Road McConnellsburg, P A 17233 Thank you very much. If you have any questions or concerns, please do not hesitate to contact me. Sincerely, 44 Michael E. Metro MEMlajm Enclosures Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS RICKY J. SOUDERS Plaintiff Court of Common Pleas Vs. No. 05-949 CIVIL TERM In CivilAction-Law STEPHEN B. THOMAS 131 FORBES TRIAL ROAD McCONNELLSBURG, PA 17233 Defendant To STEPHEN B. THOMAS You are hereby notified that RICKY J. SOUDERS, the Plaintiff has I have commenced an action in Civil Action-Law against you which you are required to defend or a default judgment may be entered against you. (SEAL) CURTIS R. LONG Prothonotary Date FEBRUARY 23, 2005 Attorney: Name: MICHAEL E. METRO, ESQUIRE Address: VILLANOV A LAW OFFICES, P.c. 16 CHATHAM SQUARE PITTSBURGH, PA 15219 Attorney for: Plaintiff Telephone: 412-471-1933 Supreme Court ID No. 62185 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RICKY 1. SOUDERS, CIVIL DIVISION Plaintiff No. 05-949 Civil Term vs. STEPHEN B. THOMAS, COMPLAINT IN CIVIL ACTION Defendant Filed on behalf of the Plaintiff: RICKY J. SOUDERS, Counsel of Record for this Party: Michael E. Metro, Esquire PALD.#62I85 VILLANOVA LAW OFFICES, P .C. I6 Chatham Square Pittsburgh, PA 15219 (412) 471-1933 A JURY TRIAL IS DEMANDED IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA RICKY J. SOUDERS, CIVIL DIVISION Plaintiff No. 05-949 Civil Term vs. STEPHEN B. THOMAS, Defendant NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you, You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any 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 OR KNOW A LAWYER, THEN YOU SHOULD GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 32 South Bedford StI'ect Carlisle, P A 1701 TELEPHONE NUMBER: 1-800-990-91 08 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RICKY J. SOUDERS, CIVIL DIVISION Plaintiff No. 05-949 Civil Term vs. STEPHEN B. THOMAS, Defendant COMPLAINT IN CIVIL ACTION AND NOW, comes the Plaintiff, Ricky J. Souders, by and through his attorneys, Villanova Law Offices, P.C., and Michael E. Metro, Esquire, as his attorney and does hereby file the within Complaint in Civil Action and avers, therefore, as follows: 1. Plaintiff, Ricky J. Souders, is an adult individual and currently resides in McConnellsburg, Fulton County, Pennsylvania. 2. Defendant, Stephen B. Thomas, is an adult individual currently residing in McConnellsburg, Fulton County, Pennsylvania. 3. On or about May I, 2003, at approximately3:00 p.m., Plaintiff, Ricky J. Souders, was a front seat passenger in a motor vehicle operated by Defendant, Stephen B. Thomas, traveling westbound on the Pennsylvania Turnpike near Newville, Cumberland County, Pennsylvania, when, due to the negligence, carelessness and recklessness of the Defendant, Stephen B. Thomas said vehicle was caused to leave the roadway striking the north berm guardrail with the right front portion of Defendant's vehicle and also striking the concrete median barrier with the front of Defendant's motor vehicle, causing Plaintiff, Ricky J. Souders to sustain numerous injuries and damages. 4. The serious injuries sustained by Plaintiff, Ricky J. Souders, were directly and proximately caused by the negligence, carelessness and recklessness of the Defendant, Stephen B. Thomas, in general and in the following particulars: a. In failing to keep a proper lookout; b. In failing to keep his vehicle under proper control; c. In operating his motor vehicle in an inattentive manner; d. In failing to stop his motor vehicle, check its speed, or change its course when the Defendant Operator knew, or in the exercise of ordinary and reasonable care, should and ought to have known that continuing to operate said motor vehicle in the same direction would cause said motor vehicle to leave the aforesaid roadway; e. In failing to properly maintain the vehicle he drove; f. In going faster than the legal speed limit and conditions allowed; g. In failing to avoid the accident by changing the direction of his vehicle; and h. In failing to avoid the accident by applying his brakes. 5. Solely as a result ofthe negligence, carelessness and recklessness of the Defendant, Stephen B. Thomas, the Plaintift~ Ricky 1. Souders, sustained the following injuries, all of which are or may be of a permanent nature: a. Severe sprains and strains of and injury and damages to the bones, joints, muscles, ligaments, tendons, discs, nerves and tissues of the areas ofthe bilateral shoulders, neck, mid back, upper extremities and head; b. Rotator cuff tear of the left shoulder requiring surgical intervention; c. Rotator cufftear of the right shoulder; d. Abrasions and contusions about the head, including a corneal abrasion of the left eye with blurred vision; e. Aggravation of pre-existing bilateral shoulder abnormalities, requiring surgical intervention. f. Severe shock and injury and damage to the nerves and nervous system; g. Nervousness, emotional tension and anxiety; and h. Personality change and depression. 6. The serious and permanent injuries mentioned in Paragraph Five (5) herein represent a situation which removes this case from consideration as one which would be disallowed because of any law of the Commonwealth of Pennsylvania regarding a limited tort option. 7. Plaintiff sustained the following damages as a result of these injuries: a. He has endured and will continue to endure great pain, suffering, inconvenience, embarrassment, mental anguish, and emotional and psychological trauma; b. He has been and will be required to expend large sums of money for medical treatment and care, hospitalization, medical supplies, surgical appliances, rehabilitation and therapeutic treatment, medicines, and other attendant services; c. He has sustained and will continue to sustain lost earnings, and his earning capacity has been reduced and may be permanently impaired; d. He has sustained property damage; e. His general health, strength, and vitality have been impaired; and f. He has and will in the future be unable to enjoy various pleasures of life that he previously enjoyed. WHEREFORE, the Plaintiff, Ricky J. Souders, seeks ajudgment against the Defendant, Stephen B. Thomas, for an amount in excess of Twenty Five Thousand ($25,000.00) Dollars with interest and costs provided by law. A JURY TRIAL IS DEMANDED. Respectfully Submitted, .4 k~!_/'- Michael E. Metro, Esquire Attorney for Plaintiff VERIFICATION I, Ricky J. Souders, having personal knowledge of the factual statements made in this, COMPLAINT IN CIVIL ACTION, verifY that these statements are true to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. 0." 3j 10 1) Ricky J. Soud rs CERTIFICATE OF SERVICE I, Michael E. Metro, hereby certify that the within document, COMPLAINT IN CIVL ACTION, was served upon the following by U. S. postal service, postage prepaid, . f~ this ~day of March, 2005. Stephen B. Thomas 131 Forbes Trail Road McConnellsburg, P A 17233 VILLANO V A LAW OFFICES, P.C. By: (. Michael E. Metro <, SHERIFF'S RETURN - OUT OF COUNTY , . CASE NO: 2005-00949 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SOUDERS RICKY J VS THOMAS STEPHEN B R. Thomas Kline , Sheriff or Deputy Sheriff wh being duly sworn according to law, says, that he made a diligent sea ch and and inquiry for the within named DEFENDANT , to wit: THOMAS STEPHEN B but was unable to locate Him in his bailiwick. He therefo e deputized the sheriff of FULTON County, Pennsylvan a, to serve the within WRIT OF SUMMONS On March 14th , 2005 , this office was in receipt of he attached return from FULTON Sheriff's Costs: Docketing Out of County Surcharge Dep Fulton County Postage 18.00 9.00 10.00 38.48 .74 76.22 03/14/2005 MICHAEL METRO So answe~ ./ . c''''< , .. ';;-',::-::,.../ -";.:::;.~~.:~.-,. ~_.~~--::-. ~/~'" .' "'= / -- -- --,., _:"::-_. .---....-....' -~ :::.---'- " ~.. R. Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before this /Ld.l day of J4-r ,,'1,. l 3~ ~Di~"'~?\J ~iOffi no'ary.. . me . . In The Court of Common Pleas of Cumberland County, Pen sylvania Ricky J. Souders VS. Stephen B. Thomas No. 05-949 civi Now, March 2, 2005 , I, SHERIFF OF CUMBERLAND COUN Y, PA, do hereby deputize the Sheriff of Fulton County to execute thi Writ, this deputation being made at the request and risk of the Plaintiff. Gk;~::/,J /~ .-;.' .., ~.... ~ ~~~.",~'" ~ ~",.~d<'A'.,..,"~~ f Sheriff of Cumberland County, A Affidavit of Service Now, n1() rc j, ,20 c!.>-' at / / '(IC) o'clock /A, M. s rved the within 5", upon 8~ as C ,., <' tis 6;,,,- A at 7.:7 '33 by handing to a copy of the original and made known to the contents the eof. So answers, . ;:. 7 C,pf11 Co nly. PA Sworn and subscribed before me this qth day of .t1d1dl ,2005 Jll/-<Ya,[WJ),7. ~f1L Jkpk~ p{).~ COSTS SERVICE / Z d(/ $ MILEAGE C;. ';IX? AFFIDAVIT ,..;,17 i (N) #::> :S",cL.e"J< 10, <1rJ J;:;;, ;] $ . , . . Casey G. Shore, Esquire NEALON, GOVER & PERRY 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 cshore@nealon-gover.com VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-949-CV RICKY J. SOUDERS, Plaintiff STEPHEN B. THOMAS, Defendant CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Stephen B. Thomas, with regard to the above-captioned matter. Respectfully submitted, NEALON, GOVER & PERRY By: !~~ s y G. Shore, Esquire I.D. #: 85321 2411 North Front Street Harrisburg, PA 17110 717/232-9900 Date: ..1'7 )05 -=q I . .~ CERTIFICATE OF SERVICE AND NOW, this 'l-d: day of April, 2005, I hereby certify that I have served the foregoing Praecipe for Entry of Appearance on the following by depositing a true and correct copy of same in the United States mails, postage prepaid. addressed to: Michael Metro, Esquire Villanova Law Offices, P.C. 16 Chatham Square Pittsburgh, PA 15219 ~~E""irn ~ C? ....' c::--' ,:,~, L...... C) .".1 "-' ",' ;;'1 - 0.' -11 "'.."' \.: CJ -" , RICKY J. SOUDERS, Plaintiff VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-949-CV STEPHEN B. THOMAS, Defendant CIVIL ACTION - LAW NOTICE TO PLEAD TO: Ricky J. Souders and his attorney Michael Metro, Esquire Villanova Law Offices, P.C. 16 Chatham Square Pittsburgh, PA 15219 YOU ARE HEREBY NOTIFIED to file a response to the enclosed New Matter within twenty (20) days of service hereof. Failure by you to do so may constitute an admission. Respectfully submitted, NEALOt-l GOVER & PERRY By: t~ c~. Shore, Esquire Attorney I.D. No. 85321 2411 North Front St. Harrisburg, PA 17110 (717) 232-9900 Date: ~ RICKY J. SOUDERS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO.05-949-CV STEPHEN B. THOMAS. Defendant CIVIL ACTION - LAW ANSWER TO PLAINTIFF'S COMPLAINT WITH NEW MATTER 1. Admitted based upon information and belief. 2. Admitted. 3. Admitted in part. denied in part. It is admitted that on or about May 1, 2003 the Plaintiff was a front seat passenger in a motor vehicle being driven by Stephen B. Thomas, traveling westbound on the Pennsylvania Turnpike near Newville, Cumberland County, Pennsylvania. It is further admitted that the motor vehicle operated by Stephen B. Thomas left the roadway and struck the north berm guiderail and subsequently struck the concrete median barrier. All other averments within this paragraph are denied pursuant to Rule 1029(e) of the Pennsylvania Rules of Civil Procedure. 4. Denied pursuant to 1 029(e) of the Pennsylvania Rules of Civil Procedure, 5. Denied pursuant to 1 029(e) of the Pennsylvania Rules of Civil Procedure, 6. This averment contains a legal conclusion to which no response is required. 7. The Defendant is without sufficient information to answer the averments contained within this paragraph at this time. To the extent an answer is required, the averments are denied pursuant to Rule 1 029( e) of the Pennsylvania Rules of Civil Procedure. WHEREFORE, the Defendant respectfully requests that the Complaint filed against him be dismissed, with costs to be paid by the Plaintiff. NEW MATTER 8. Paragraphs 1 - 7 are incorporated herein. 9. The Plaintiff's claims may be barred in whole or in part by application of the Pennsylvania Motor Vehicle Financial Responsibility Act. WHEREFORE, the Defendant respectfully requests that the Complaint against him be dismissed, and the costs of this action be assessed against the Plaintiff. Respectfully submitted, NEALON GOVER & PERRY By: ~~ Cas . Shore, Esquire I.D. #: 85321 2411 North Front Street Harrisburg, PA 17110 717/232-9900 Date: 4-t, b~ I ( VERIFICATION I, Stephen B. Thomas, verify that the statements made in the foregoing Answer with New Matter are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.SA ~4904 relating to unsworn falsification to authorities. Date: If - /'1-0 CERTIFICATE OF SERVICE AND NOW. this ,J,J,i1a..day of April, 2005. I hereby certify that I have served the foregoing Answer With New Matter on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Michael Metro. Esquire Villanova Law Offices, P.C. 16 Chatham Square Pittsburgh, PA 15219 . Shore, Esquire -~\:1: cl-"f',' ....... ,,, ~'.} !,-~ ~. ":'1'- .( Yr' ~ ? .-." ""~ c? c.l1 :P" -t) ?:J '" c' -0 -,.- -- ~ :'C.,-. M1p-, -\'I" l~ :;:j~) C?:(i ~~\J-~ ~~ -::J ."'. c.,.} ,.., c:> . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RICKY J. SOUDERS, CIVIL DIVISION Plaintiff No. 05-949 Civil Term vs. STEPHEN B. THOMAS, REPLY TO NEW MATTER Defendant Filed on behalf of the Plaintiff: RICKY J, SOUDERS, Counsel of Record for this Party: Michael E. Metro, Esquire PA J.D. # 62185 VILLANOVA LAW OFFICES, P.c. 16 Chatham Square Pittsburgh, PA 15219 (412) 471-1933 A JURY TRIAL IS DEMANDED IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RICKY J. SOUDERS, CIVIL DIVISION Plaintiff No. 05-949 Civil Term vs. STEPHEN B. THOMAS, Defendant REPLY TO NEW MATTER AND NOW, comes the Plaintiff, Ricky J. Souders, by and through his attorneys, Villanova Law Offices, P.C., and Michael E. Metro, Esquire, as his attorney and does hereby file the within Reply to New Matter and 'avers, therefore, as follows: 1. Paragraphs I through 9 of Defendant's New Matter contain legal conclusions to which no response is necessary. Respectfully Submitted, #~ Michael E. Metro, Esquire Attorney for Plaintiff . . VERIFICATION I RICKY J. SOUDERS,'having personal knowledge of the factual statements made in this, REPLY TO NEW MATTER ,verify that these statements are true to the best of my information, knowledge and belief. I Understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. ~~~~~~ ic y J. 1tfers . , Date: S~!o. 5 I CERTIFICATE OF SERVICE I, Michael E. Metro, hereby certify that the within document, Reply to New Matter, was served upon the following by U. S. postal service, postage prepaid, this ~ ~day of M7 ,2005. Casey G. Shore, Esquire 2411 North Frollt Streel Harrisburg, PA 17110 VILLANOVA LAW OFFICES, P.e. By: ~ _______ Michael E. Metro (~, l-':'l ':.";',)- ':3; (") ~-,,\ ~ r:-? cP ,-...) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA RICKY J. SOUDERS, Plaintiff, CIVIL DIVISION vs. No. 05-949 Civil Term STEPHEN B. THOMAS, NOTICE OF SERVICE (Discovery Requests) Defendant. Filed on behalf of the Plaintiff: RICKY J. SOUDERS, Counsel of Record for this Party: Michael E. Metro, Esquire PA LD. # 62185 VILLANOVA LAW OFFICES, P.C. 16 Chatham Square Pittsburgh, PA 15219 (412) 471-1933 A JURY TRIAL IS DEMANDED IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA RICKY 1. SOUDERS, CIVIL DIVISION Plaintiff, No. 05-949 Civil Term vs. STEPHEN B. THOMAS, Defendant. NOTICE OF SERVICE (Discovery Requests) We hereby certify that an original and one (I) copy of Plaintiffs First Set of Interrogatories and First Request for Production of Documents Directed to Defendant, were mailed by U.S.' First Class Mail, postage prepaid to the following individual this II ~ day of f+.-<; lid- . ,2005. Casey G. Shore, Esquire 2411 North Front Street Harrisburg, PA 17110 Respectfully Submitted, Villanova Law Offices, P.C., ~4. Michael E. Metro, Esquire Attorney for Plaintiff CERTIFICATE OF SERVICE I, Michael E. Metro, hereby certify that the within document, Notice of Service (Discovery Requests), was served upon the following by U. S. postal service, postage prepaid, this 'I ~ day of ~~ J ,2005. Casey G. Shore, Esquire 2411 North Front Street Harrisburg, PA 17110 VILLANOV A LAW OFFICES, P.C. BY:~ Michael E. Metro -cr.t1 n~;;L:. ~;'-, . u! ~, ~~12:. ;.-" C:' -,',/ :'::-=\ -< o ~~; ,..., ~ ~ GJ - ~ ~-n {"l~f"'- -am9 :::1) 00 CO\ -r. ""!: -\\ Oc; Zrn 9, ~ (J"\ ;po :::r.: - - cJ'\ 0:> CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -VS- CASE NO: 05-949-CV THOMAS AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, 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: 08/22/2005 behalf of c; _. RE~'L for DEFENDANT DEl1-580162 33 922 - L 01 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HARRY JOHNSTON, D.O. ROBERT P. DURNING, M.D. DR. ROBERT N. RICHARDS, M.D. APRIL ARMSTRONG, M.D. PETER JABLIN, M.D. JOEY L. LANE, O.D. CHRISTINA FEATERS, M.D, DR. JAMES HAMMOND CHAMBERSBURG HOSPITAL CHAMBERS BURG HOSPITAL FULTON COUNTY MEDICAL CENTER CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER MEDICAL RECORDS ,. XRAYS MEDICAL RECORDS ,. XRAYS MEDICAL RECORDS ,. XRAYS MEDICAL RECORDS ,. XRAYS MEDICAL RECORDS ,. XRAYS MEDICAL RECORDS ,. XRAYS MEDICAL RECORDS ,. XRAYS MEDICAL RECORDS ,. XRAYS X-RAY ONLY MEDICAL RECORDS MEDICAL RECORDS ,. XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY DE02-308458 33922 -CO 2 COMMONWEALTB OF PENNSYLVANIA COUNTY OF CUMBERLAND SOUDERS FileNo. 05-949-CV vs. THOMAS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RUL,E 4009.22 TO: Custodian of Records for HARRY JOHNSTON D.O (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 RIDFR **** at The MCS GrollP 'ne 1601 Market Street Suite 800 Philadelnhia FA 19t03 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 adlicr:ess listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: CASEY SHORE. ESO, 2411 N FRONT ST. HARRISBURG PA 17110 TELEPHOt{E: (215)246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: L Date: 'lib- _ J (, J ,-,,;n c2f'>C. 5' - I I Seal of the Court "- L:{4 OJ Deputy 33922-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRY JOHNSTON" D.O. 425 EAST PINE STRIIT MCCONNELLSBURG, PA 17233 HE: 33922 RICKY SOUDERS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all o1her providers. Entire medical, billing, and diagnostic file, including but oot limited to any and all records, correspondence to and from 1he consufting andlor treating physicians, files, memoranda, handwritten notes, history and physical reports, medicationlp~tion records, medical billing and payment records, x-ray films and tests wi subsequent reports, including any and all such items as may be stored in a computer database or o1herwise in electronic foIm, relating to any eJ<"",inllrinn, consultation, d;llgllOSis, care or treatment pertalning to: Dates Requested: up to and including the present. Subject: RICKY SOUDERS P.O. BOX 65, MCCONELLSBURG, PA 17233 Social Security #: 189-46-5380 Date of Birth: 01-07-1956 SUlO-576840 33922 -LO 1 CERTIFICATE PREREQUISITE TO SRRVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -VS- CASE NO: OS-949-CV THOMAS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, 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: 08/22/2005 CASEY SHORE, ESQ. Attorney :Eor DEFENDANT DE11-580163 33922 - L 02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM. -VS- CASE NO: 05-949-CV THOMAS NOTICE OF INTEN'f TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY l?URSUANT TO ROLE 4009.21 [ Note: see enclosed list of locations J TO: MICHAEL METRO, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ. intemls 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 objectiqn is made, then the subpoena may be served. Complete copies of any reproduce,! 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: 08/02/2005 MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT CC: CASEY SHORE, ESQ. PATRICIA HOFFMAN - 05-205 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DEO:Z-308458 33922-C02 >>> LOCATION LIST <<< PAGB: 1 WCATION NAME RBCORDS RBQUESTBD HARRY JOHNSTON, D.O. ROBBRT P. DURNING, M.D. DR. ROBERT N. RICHARDS, M.D. APRIL ARMSTRONG, M.D. PETER JABLIB, M.D. JOBY L. LANE, O.D. CHRISTINA FBATBRS, M.D. DR. JAMES IlAMMOND CHAMBBRSBURG HOSPITAL CHAMBBRSBURG HOSPITAL FULTON COUNTY MEDICAL CBNTBR CARLISLB RBGIONAL MEDICAL CNTR CARLISLB RBGIONAL MEDICAL CNTR HBRSHEY MEDICAL CBNTER HBRSHEY MEDICAL CBNTER MEDICAL RBCORDS lie XRAYS MEDICAL RBCORDS lie XRAYS MEDICAL RECORDS lie X-RAYS MEDICAL RBCORDS lie XRAYS MEDICAL RBCORDS lie XRAYS MEDICAL RBCORDS lie XRAYS MBDICAL RBCORDS lie XRAYS MEDICAL RBCORDS lie XRAYS X-RAY ONLY MEDICAL RECORDS MEDICAL RBCORDS lie ,XRAYS MEDICAL RBCORDS X-RAY ONLY MEDICAL RBCORDS X-RAY ONLY DB02:-308458 33922 -C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SOUDERS FileNo. 05.949-CV vs. THOMAS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ROBERT P DURNING MD. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by tlle court to produce the following documents or things: **** SEE ATTACHED RIDER **** at TheMC!,;GrollP lnc 1601 MarkelSlTeel !';uile800 Philadelohia 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 fall to produce the documents or things required by this subpoena willhin twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: CASEY SHORE. ESO. 2411 N. FRONT ST. HARRlSBlJRG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant Dale: AU6lz 21m .... LL, ::)7, ~06S I Seal of the Court Prothonotary/Clerk, Civil Diy,' n ~rboJ2-- Deputy '-- 33922-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ROBERT P. DURNING, M.D. 401 WOOD ST.ffHE ARNOTT BLDG. SUITE: 401 PIITSBURGH, PA 15222 RE: 33922 RICKY SOUDERS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and di:igJ1omc file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physic:al reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such i.tems as may be stored in a computer database or otherwise in electronic fOInl, relating to any examination. consultation, di'lglV'Sis, care or tw>f1T1M1t pertaining to: Dates Requested: up to and iucludiug the present. Subject: RICKY SOUDERS P.O. BOX 65, MCCONELLSBURG, PA 17233 Social Security #: 1119-46-5380 Date of Birth: 01-07-l956 SUlO-576842 33922 -LO 2 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -VS- CASE NO: 05-949-CV THOMI\.S I\.s a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CI\.SEY SHORE, 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: 08/22/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DEll-58016433922-L03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -VS- CASE NO: 05-949-CV THOMAS 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: MICHAEL METRO, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, 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 objectiqn is made, then the subpoena ,~ay be served. Complete copies of any reproduceq records may be ordered at your expense by completing the attached counsel card and returning same to MCS OJe by contacting our local MCS office; DATE: 08/02/2005 MCS on bebalf of CASEY SHORE, ESQ. Attorney for DEFENDANT CC: CASEY SHORE, ESQ. PATRICIA HOFFMAN - 05-205 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET '800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-308458 33922 -CO 2 >>> LOCATION LIST <<< PAGB: 1 LOCATION NAMB RBCORDS REQUESTBD HARRY JOHNSTON, D.O. ROBBRT P. DURNING, M.D. DR. ROBBRT N. RICHARDS, M.D. APRIL ARMSTRONG, M.D. PBTBR JABLIN, M.D. JOEY L. LANll, O.D. CHRISTINA FRATBRS, M.D. DR. JAMBS HAMMOND CHAMBBRSBUEG HOSPITAL CHAMBBRSBURG HOSPITAL FULTON COUNTY MEDICAL CBNTBR CARLISLB RBGIONAL MEDICAL CNTR CARLISLB RBGIONAL MEDICAL CNTR HBRSHBY MEDICAL CBNTER HBRSHEY MEDICAL CBNTBR MEDICAL RBCORDS & XRAYS MEDICAL RBCORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RBCORDS & XRAYS MEDICAL RBCORDS & XRAYS MEDICAL RBCORDS & XRAYS MEDICAL RECORDS & KRAYS MEDICAL RBCORDS & KRAYS X-RAY ONLY MEDICAL RBCORDS MEDICAL RBCORDS & .KRAYS MEDICAL RBCORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY DBO:!-308458 339:2:2 - CO:2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SOUDERS FileNo. 05-949-CV vs. THOMAS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RUl,E 4009.22 TO: Custodian of Records for DR. ROBERT N RICHARDS 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 A TT ACHED RIDER **** at The MCS Grolln Inc ]60] Market Street Suite 800 Philadelphia PA ]9]01 You may deliver or mail legible copies of the documents or produce things requested by thig subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: CASEY SHORE. ESO. 24II N FRONT ST HARRISBURG. PA 17110 TELEPHONE: (215) 246.0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant BY THE COURT: --&1 Prothonotary/Clerk, Civi Di n Date: '- 1 j" I .iz1llll :27/,.,/0&)" Seal of the Court 33922.03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. ROBERT N. RICHARDS, M.D. 1035 WAYNE AVENUE ORTIlOPEDIC ASSOC. CHAMBERSBURG, PA 17201 RE: 33922 RICKY SOUDERS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. EUtire medical, billing, and diagnostic file, including but oot limik:d to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda. handwritten notes, history and physical reports, medicationlprescription records, medical billing and payment reconls, x-ray fiJms and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic fOlm, relating to any eJ[aminlltioo, consultation, llillgJ1O'ris, care or tn"-"fnv"nt pertaining to: Dates Requested: up to and including the present. Subject: RICKY SOUDERS P.O. BOX 65, MCCONELLSBURG, PA 17233 Soclal Security #: 189-46-5380 Date of Birth: 01-07-1956 SUlO-516844 339:2:2 - L 03 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -VS- CASE NO: 05-949-CV THOMAS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, ESQ. certifies that II) 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: OS/22/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DEll-5S0165 33922-L04 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -vs- CASE NO: 05-949-CV THOMAS NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOClJMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: MICHAEL METRO, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, 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 objectiqn 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: 08/02/2005 MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT CC: CASEY SHORE, ESQ. PATRICIA HOFFMAN - 05-205 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-308458 33 9:2 :2 - C 0 :2 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HARRY JOHNSTON, D.O. ROBERT P. DURNING, M.D. DR. ROBERT N. RICHARDS, M.D. APRIL ARMSTRONG, M.D. PETER JABLIN, M.D. JOEY L. LANE, O.D. CHRISTINA PRATERS, M.D. DR. JAMES HAMMOND CHAMBgRSBURG HOSPITAL CHAMBERSBURG HOSPITAL FULTON COUNTY MEDICAL CENTER CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS X-RAY OIlLY MEDICAL RECORDS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY OIlLY MEDICAL RECORDS X-RAY ONLY DE02-308458 33922-C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SOUDERS FileNo. 05.949-CV vs. THOMAS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for APRIl. ARMSTRONG 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 A IT ACHED RIDER **** at The MCS GrOll)) Inc 1601 Market Street Suite 800 Philadelnhia PA 191m You may deliver or mail legible copies of the documents'or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above, You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the 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. TIllS SUBPOENA WAS ISSUED AT TIlE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: CASEY SHORE. ESO. 2411 N FRONTST HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant AU6:Zz 2lIli Date: ,.j U 1y .:J? l .J"n^-S Seal of the Court '-----r5et~c,~ _2 '7fr/Jl?~ eputy 33922-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: APRIL ARMSTRONG, M.D. 500 UNIVERSITY DRIVE P.O. BOX 850 HERSHEY, PA 170330850 RE:33922 RICKY SOUDERS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Fntire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, inc~ any and all such items as may be stored in a computer database or otheIWJSe in electronic form, relating to any eJ<aminarion, consultation, <li'lgJ'OSis, care or treatment pertaining to: Dates R.equested: up to and including the present. Subject: lUCKY SOUDERS P.O. BOX 65, MCCONELLSBURG, PA 17233 Social Security #: 189-46-5380 Date of Birth: 01-07-19S6 8U10-576846 33922 -LO 4 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -VS- CASE NO: 05-949-CV THOMAS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, 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 identicall to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 08/22/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DEll-580166 33 922 - LOS COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -VS- CASE NO: 05-949-CV THOMAS NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCOMENTS AND THINGS FOR DISCOVERY PDRSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: MICHAEL METRO. ESQ.. PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, 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 objectiQn is made, then the subpoena Inay be served. Complete copies of any reproduce4 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: 08/02/2005 MCS on behalf of CASEY SHORE. ESQ. Attorney for DEFENDANT CC: CASEY SHORE. ESQ. PATRICIA HOFFMAN - 05-205 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 8800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-308458 33922-C02 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HARRY JOHNSTON, D.O. ROBERT P. DURNING, M.D. DR. ROBERT N. RICHARDS, M.D. APRIL ARMSTRONG, M.D. PETER JABLIN, M.D. JOEY L. LANE. O.D. CHRISTINA FRATERS, M.D. DR. JAMES HAMMOND CHAMEERSBURG HOSPITAL CHAMEERSBURG HOSPITAL FULTON COUNTY MEDICAL CENTER CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS X-RAY ONLY MEDICAL RECORDS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY DE02-308458 33922 - CO 2 COMMONWEAL Ti-I OF PENNSYLVANIA COUNTY OF CUMBERLAND SOUDERS FileNo. 05-949-CV vs. THOMAS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PETER JABLIN. 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 GmQp Ine 160] Market Street Suite 800 Fhiladelnhia FA ]9103 You may deliver or mail legible copies of the documerrts or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: CASEY SHORE. ESO. 2411 N FRONT ST. HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant Date: uL All&iz 2lIli ---J i ;2.'7, ~D&S BY THE COURT: kb- Prothonotary/Clerk, Civil D. '--- ~a,-e. _2 7ft'/( o/~ Deputy Seal of the Court 33922-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PETER JABUN, M.D. 601 NORLAND AVENUE CHAMBERSBURG, PA 17201 RE: 33922 RICKY SOUDERS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, bi)1ing, and diagnostic file, including but not limiu:d to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment recollls, x-ray films and tests witli subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any eX3Tllinlltion, consultation, lI;llgnnsis, care or trelllttll'!nt perttining to: Dates Requested: up to and including the present. Subject: RICKY SOUDERS P.O. BOX 65, MCCONELLSBURG, PA 17233 Social Security #: 189-46-5380 Date oCBirth: 01-07-1956 SUlO-576848 33922 -LO 5 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT" OF COMMON PLEAS SOUDERS TERM, -VS- CASE NO: o5-949-CV THOMAS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, 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: 08/22/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DEl1-580167 33922 - L 06 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -VS- CASE NO: 05-949-CV THOMAS NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCOMENTS AND THINGS FOR DISCOVERY PDRSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: MICHAEL METRO, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, 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 objectiQn is made, then the subpoena nay be served. Complete copies of any reproduce4 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: 08/02/2005 MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT CC: CASEY SHORE, ESQ. PATRICIA HOFFMAN - 05-205 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 8800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-308458 33922 -C02 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HARRY JOHNSTON, D.O. ROBERT P. DURNING, M.D. DR. ROBERT N. RICHARDS, M.D. APRIL ARMSTRONG, M.D. PETER JABLIN, M.D. JOEY L. LANE, O.D. CHRISTINA FRATERS, M.D. DR. JAMES HAMMOND CHAMEERSBURG HOSPITAL CHAMEERSBURG HOSPITAL FULTON COUNTY MEDICAL CENTER CARLISLE REGIONAL MRDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS X-RAY ONLY MEDICAL RECORDS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY DE02-30845833922-C02 COMMONWEAL ill OF PENNSYLVANIA COUNTY OF CUMBERLAND SOUDERS FileNo. 05-949-CV vs. THOMAS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JOEY L LANE. O.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 ('.,-oun Inc 160] Market Street Suite 800 Phi]adelphia PA ]9103 You may deliver or maiJlegible copies of the documents or produce things requested'by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: CASEY SHORE. ESO. 2411 N. FRONT ST HARRISBURG. PA 171 ]0 TELEPHONE: (2]5)246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant Date: t.-J AlISt'Z 2lIli o y .;L7,~N'iC; BY THE COURT: ~ Prothonotary/Clerk, Civil Diy.. '--- 4~<HZ. P7IU-rU Deputy Sea] of the Court 33922-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOEY L. LANE, O.D. SHULTZ & LANE OPTOMETRIST 182 BUCHANAN TRAIL MCCONELLSBURG, PA 17233 RE:33922 RICKY SOUDERS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnosIic file, including but not limited to any and all records, conespondence to and from the consulting and/or treating physicians, files, memoranda, handwritten DOtes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any eJ<amination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: RICKY SOUDERS P.O. BOX 65, MCCONELLSBURG, PA 17233 Social Security #: 189-46-5380 Date of Birth: 01-07-l956 SUlO-576850 33922 -LO 6 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -vs- CASE NO: 05-949-CV THOMAS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, ESQ. certifies that (1) A notice of in'tent 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: 08/22/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DEll-580168 33922-L07 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -vs- CASE NO: 05-949-CV THOMAS NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCOMENTS AND THINGS FOR DISCOVERY PDRSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: MICHAEL METRO, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, BSQ. 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 objectiQn is made, then the subpoena may be served. Complete copies of any reproduce4 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: 08/02/2005 MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT CC: CASEY SHORE, ESQ. PATRICIA HOFFMAN - 05-205 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET '800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-308458 33922 -C02 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HARRY JOHNSTON, D.O. ROBERT P. DURNING, M.D. DR. ROBERT N. RICHARDS, M.D. APRIL ARMSTRONG, M. D. PETER JABLIN, M.D. JOEY L. LANE, O.D. CHRISTINA FRATERS, M.D. DR. JAMES HAMMOND CHAMEERSBURG HOSPITAL CHAMEERSBURG HOSPITAL FULTON COUNTY MEDICAL CENTER CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS X-RAY ONLY MEDICAL RECORDS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY DE02-308458 33922 - CO 2 COMMONWEAL TIt OF PENNSYLVANIA COUNTY OF CUMBERLAND SOUDERS FileNo. 05-949-CY vs. THOMAS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CHRISTINA PRATERS. 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 Gmun Ine ]601 Market Street. Suite 800 Philadelnhia PA 19103 You may deliver or maillegibie copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: CASEY SHORE. ESO. 2411 N FRONT ST HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURJ': PrO~~~/CI Date: A111l:fZ2llli pu~ &s:. o'la/S- Seal of the Court Deputy 33922-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CHRISTINA FEATERS, M.D. 354 MILL STREET HAGERSTOWN, MD 21740 HE: 33922 RICKY SOUDERS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and ~ file, including but not limik:d to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, dillgJlOSis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: RICKY SOUDERS P.O. BOX 65, MCCONELLSBURG, PA 17233 Social Security #: 189-46-5380 Date of Birth: 01-07-1956 SU10-576852 33922 -LO 7 CERTIFICATE PREREQUISITE TO SERVICE OF A SUB]~OENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -VS- CASE NO: 05-949-CV THOMAS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the sub'poena 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: 08/22/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DEll-580169 33 922 - L 0 8 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -vs- CASE NO: 05-949-CV THOMAS NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCOMENTS AND THINGS FOR DISCOVERY PDRSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: MICHAEL METRO, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ. inteuds 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 r-ecord and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objectiQn is made, then the subpoena Inay be served. Complete copies of any reprodnce4 records may be ordered at yaur expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 08/02/2005 MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT CC: CASEY SHORE, ESQ. PATRICIA HOFFMAN - 05-205 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET '800 PHILADELPHIA, PA 19103 (215) 246-0900 DEII2-30845833922-C02 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HARRY JOHNSTON, D.O. ROBERT P. DURNING, M.D. DR. ROBERT N. RICHARDS, M.D_ APRIL ARMSTRONG, M.D. PETER JABLIN, M.D. JOEY L. LANE, O.D. CHRISTINA FRATERS, M.D. DR. JAMES HAMMOND CHAMEERSBURG HOSPITAL CHAMEERSBURG HOSPITAL FULTON COUNTY MEDICAL CENTER CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS X-RAY ONLY MEDICAL RECORDS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY DECI2-308458 33922-C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SOUDERS FileNo. 05-949-CY vs. THOMAS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR JAMES HAMMOND (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 GroQp Ine ]601 Market Street Suite 800 Philadelnhia PA 19]01 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 ri~t 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 widlin twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: CASEY SHORE. ESO. 241] N. FRONT ST HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: .'Zt 2D H d~:d4::<5- Seal of the Court Deputy 33922-08 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. JAMES HAMMOND HERSHEY MED. CTR. 500 UNIVERSITY DR. HERSHEY, PA 17033 RE: 33922 RICKY SOUDERS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic fI]e, includmg but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, fIles, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic fonn, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: RICKY SOUDERS P.O. BOX 65, MCCONELLSBURG, PA 17233 Social Security #: 189-46-5380 Date of Birth: 01-07-1956 SUIo-57648233922-L08 CERTIFICATE PREREQUISITE TO SERVICB OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -VS- CASE NO: 05-949-CV THOMAS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, 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: 08/22/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DEll-58017o 33922-L09 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -vs- CASE NO: 05-949-CV THOMAS NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCOMENTS AND THINGS FOR DISCOVERY PDRSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: MICHAEL METRO, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, 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 r,ecord and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objectiQn is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at yaur expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 08/02/2005 MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT CC: CASEY SHORE, ESQ. PATRICIA HOFFMAN - 05-205 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 8800 PHILADELPHIA, PA 19103 (215) 246-0900 DE1l2-308458 33922-C02 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HARRY JOHNSTON, D.O. ROBERT P. DURNING, M.D. DR. ROBERT N. RICHARDS, M.D. APRIL ARMSTRONG, M.D. PETER JABLIN, M.D. JOEY L. LANE, O.D. CHRISTINA FRATERS, M.D. DR. JAMES HAMMOND CHAMEERSBURG HOSPITAL CHAMEERSBURG HOSPITAL FULTON COUNTY MEDICAL CENTER CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER MEDICAL RECORDS & .KRAYS MEDICAL RECORDS & .KRAYS MEDICAL RECORDS & .KRAYS MEDICAL RECORDS & :KRAYS MEDICAL RECORDS & .KRAYS MEDICAL RECORDS & .KRAYS MEDICAL RECORDS & :KRAYS MEDICAL RECORDS & :KRAYS X-RAY ONLY MEDICAL RECORDS MEDICAL RECORDS & :KRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY DE02-308458 33922 - CO 2 COMMONWEAL ill OF PENNSYLVANIA COUNTY OF CUMBERLAND SOUDERS FileNo. 05-949-CY vs. THOMAS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CHAMBERSBURG 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 GTOllp Ine 1601 Market Street Suite 800 Philadelphia P A 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right ' to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: CASEY SHORE. ESO. 241 I N FRONT ST HARRISBURG. PA 17110 TELEPHONE: (2] 5) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant I otaIy/Clerk, C vil D. sion Date: (}dj AIlS 212l1li 078': r:J~..j Deputy Seal of the Court 33922-09 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CHAMBERSBURG HOSPITAL 112 NORTH SEVENTH ST. CHAMBERSBURG, PA ]7201 RE: 33922 RICKY SOUDERS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. ' Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. . Any and all x-ray films and rePorts, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject: RICKY SOUDERS P.O. BOX 65, MCCONELLSBURG, PA 17233 Social Security #: 189-46-5380 Date of Birth: 01-07-1956 SUIo-576484 33922-L09 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -VS- CASE NO: o5-949-CV THOMAS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, 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: 08/22/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DEl1-580171 33922-L10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -vs- CASE NO: o5-949-CV THOMAS NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCOMENTS AND THINGS FOR DISCOVERY PDRSUANT TO ROLE 4009.21 [ Note: see enclosed list of locations] TO: MICHAEL METRO, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, 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 r,ecord and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objectiQn is made, then the subpoena Inay be served. Complete copies of any reproduced records may be ordered at yaar expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 08/02/2005 MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT CC: CASEY SHORE, ESQ. PATRICIA HOFFMAN - 05-205 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET '800 PHILADELPHIA, PA 19103 (215) 246-0900 DE1l2-308458 33922-C02 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HARRY JOHNSTON, D.O. ROBERT P. DURNING, M.D. DR. ROBERT N_ RICHARDS, M.D. APRIL ARMSTRONG, M.D. PETER JABLIN, M.D. JOEY L. LANE, O.D. CHRISTINA FEATERS, M.D_ DR. JAMES HAMMOND CHAMEERSBURG HOSPITAL CHAMEERSBURG HOSPITAL FULTON COUNTY MEDICAL CENTER CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER MRDICAL RECORDS & .KRAYS MEDICAL RECORDS & .KRAYS MEDICAL RECORDS & KRAYS MEDICAL RECORDS & .KRAYS MEDICAL RECORDS &KRAYS MEDICAL RECORDS & KRAYS MEDICAL RECORDS & .KRAYS MEDICAL RECORDS & .KRAYS X-RAY ONLY MEDICAL RECORDS MEDICAL RECORDS & .KRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY DE02-308458 33922 -CO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SOUDERS FileNo. 05-949-CY vs. THOMAS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CHAMBERSRURG 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 TheMCSGTOQp Ine 1601 Market Street Suite 800 Philadelphia PA 19]03 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: Y QU have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: CASEY SHORE. ESO. 2411 N FRONT ST HARRISBURG PA ]7110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: _.72211& Hdr.~ Deputy Seal of the Court 33922-10 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CHAMBERSBURG HOSPITAL ] 12 NORTH SEVENTH ST. CHAMBERSBURG, PA 17201 RE: 33922 RICKY SOUDERS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $]OO.()() for hospitals, $50.00 for all other providers. Entire ho~ital medical fIle, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicia:ll, fIles, memoranda, handwritten notes, history and physical reports, medi(:ation/ prescription records, nurse's notes, doctor's connnents, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in e]ectronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject: RICKY SOUDERS P.O. BOX 65, MCCONELLSBURG, PA 17233 Social Security #: 18946-5380 Date of Birth: 01-07-1956 SUIo-576486 33922-L10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBI~ENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -VS- CASE NO: 05-949-CV THOMAS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, 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: 08/22/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DEl1-58ol72 33922-Lll COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -VS- CASE NO: 05-949-CV THOMAS NOTICE OF INTBNT TO SERVE A SUBPOENA TO PRODUCE DOCOMENTS AND THINGS FOR DISCOVERY PDRSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: MICHABL METRO, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, 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 objectiQn is made, then the subpoena lDay 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 o:r by contacting our local MCS office. DATE: 08/02/2005 MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT CC: CASEY SHORE, ESQ. PATRICIA HOFFMAN - 05-205 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 8800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-30845833922-C02 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HARRY JOHNSTON, D.O. ROBERT P. DURNING, M.D. DR. ROBERT N. RICHARDS, M.D. APRIL ARMSTRONG, M.D. PETER JABLIN, M.D. JOEY L. LANE, O.D. CHRISTINA FRATERS, M.D. DR. JAMES HAMMOND CHAMEERSBURG HOSPITAL CHAMEERSBURG HOSPITAL FULTON COUNTY MEDICAL CENTER CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER MEDICAL RECORDS & :lRAYS MEDICAL RECORDS & :lRAYS MEDICAL RECORDS & :lRAYS MEDICAL RECORDS & :lRAYS MEDICAL RECORDS & :lRAYS MEDICAL RECORDS & :lRAYS MEDICAL RECORDS & :lRAYS MEDICAL RECORDS & :lRAYS X-RAY ONLY MEDICAL RECORDS MEDICAL RECORDS & :lRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY DE02-308458 33922 -C02 COMMONWEAL TIl: OF PENNSYLVANIA COUNTY OF CUMBERLAND SOUDERS FileNo. 05-949-CY vs. THOMAS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for FULTON COUNTY MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Groun Ine 160] Market Street Suite 800 Philadelphia PA 19103 You may deliver or mail legible copies of the documents or prgduce 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 wilhin twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: CASEY SHORE. ESO. 2411 N FRONT ST HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY TH(5pURT: ~ry/CI ilDiv. ton Date: AUG2 z 2lIli v'l dJ.P,~ Seal of the Court Deputy 33922-11 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: FULTON COUNTY MEDICAL CENTER 216 S. 1ST STREET MCCONNELLSBURG, PA 17233 RE: 33922 RICKY SOUDERS Prior approval is required for fees in excess of $]00.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic fI]e, including but not limited to any and al] records, correspondence to and from the consulting andl/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray fIlms and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic fOlID, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to aud including the present. Subject: RICKY SOUDERS P.O. BOX 65, MCCONELLSBURG, PA 17233 Social Security #: 189-46-5380 Date of Birth: 01-07-1956 SUIo-57648833922-Lll CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -VS- CASE NO: 05-949-CV THOMAS AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was maiied 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: 08/22/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DEll-580173 33922 -L12 COMMONWEALTH OF PENNS.YLVANIA COUNTY OF CUMBERLAND IN THE MATTER.OF: COURT OF COMMON PLEAS SOUDERS TERM, -vs- CASE NO: o5-949-CV THOMAS NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCOMENTS AND THINGS FOR DISCOVERY PDRSUANT TO RU[,B 4009.21 [ Note: see enclosed list of locations] TO: MICHAEL METRO, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ. intenc~ 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 rE,cord and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objectiQn 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: 08/02/2005 MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT CC: CASEY SHORE, ESQ. PATRICIA HOFFMAN - 05-205 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 8800 PHILADELPHIA, PA 19103 (215) 246-0900 DEO:Z-308458 33922-C02 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HARRY JOHNSTON, D.O. ROBERT P. DURNING, M.D. DR. ROBERT N. RICHARDS, M.D. APRIL ARMSTRONG, M.D. PETER JABLIN, M.D. JOEY L. LANE, O.D. CHRISTINA FRATERS, M.D. DR. JAMES HAMMOND CHAMEERSBURG HOSPITAL CHAMEERSBURG HOSPITAL FULTON COUNTY MEDICAL CENTER CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR HERSHEY MEDICAL CENTBR HERSHEY MEDICAL CENTER MEDICAL RECORDS & ]{RAYS MEDICAL RECORDS & ]{RAYS MEDICAL RECORDS & ]{RAYS MEDICAL RECORDS & ]{RAYS MEDICAL RECORDS & ]{RAYS MEDICAL RECORDS & ]{RAYS MEDICAL RECORDS & ltRAYS MEDICAL RECORDS & J[RAYS X-RAY ONLY MEDICAL RECORDS MEDICAL RECORDS & ltRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY DE02-308458 33922 -CO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SOUDERS FileNo. 05-949-CY vs. THOMAS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARLISLE REGIONAL MEDICAL CNTR (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 GroQp Iue 1601 Market Street Suite 800 Philadelphia PA 19'103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: CASEY SHORE. ESO. 2411 N FRONT ST. HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: ProthOne~/Cler Date: Al/61Z 2lIi y_# o/? ~ Deputy Seal of the Court 33922-12 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CNTR 246 PARKER STREET CARLISLE, PA 17013 RE: 33922 RICKY SOUDERS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire :hospital medical fIle, including but not ]imited to any and alii records, correspondence to and from the consulting and/or treating physician, fI]es, memoranda, handwritten notes, history and physical reports, medication! prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including tbe present. Subject: RICKY SOUDERS P.O. BOX 65, MCCONELLSBURG, PA 17233 Social Security #: 189-46-5380 Date of Birtb: 01-07-1956 SUIO-57649o 33922-L12 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -VS- CASE NO: o5-949-CV THOMAS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, 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: 08/22/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DEll-580174 33922 -L13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -vs- CASE NO: 05-949-CV THOMAS NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCOMENTS AND THINGS FOR DISCOVERY PDRSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: MICHAEL METRO, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, 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 objectiQn 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: 08/02/2005 MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT CC: CASEY SHORE, ESQ. PATRICIA HOFFMAN - 05-205 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-308458 33922 -CO 2 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HARRY JOHNSTON, D.O. ROBERT P. DURNING, M.D. DR. ROBERT N. RICHARDS, M.D. APRIL ARMSTRONG, M.D. PETER JABLIN, M.D. JOEY L. LANE, O.D. CHRISTINA PRATERS, M.D. DR. JAMES HAMMOND CHAMEERSBURG HOSPITAL CHAMEERSBURG HOSPITAL FULTON COUNTY MEDICAL CENTER CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS X-RAY ONLY MEDICAL RECORDS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY DE02-308458 33922-C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SOUDERS FileNo. 05-949-CY vs. THOMAS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARLISLE REGIONAL MEDICAL CNTR (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 TheMCSGrouj) 1ne ]60] Market Street Suite 800 Philadelphia PA 19103 'You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this reqUest at the address listed above. You have the'right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: CASEY SHORE. ESO. 24] 1 N FRONT ST HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: ~;ZZ2llli a~f .,;>~ ~ .P Seal of the Court , Prothonot Deputy 33922-13 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CNTR 246 PARKER STREET CARLISLE, PA ]7013 RE: 33922 RICKY SOUDERS Prior approval is required for fees in excess of $]00.00 for hospitals, $50.00 for al] other providers. Please call for prior approval for fees in excess of $]00.00 for hospitals, $50.00 for all other providers. Any and all x-ray films and reports, inc]uding any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject: RICKY SOUDERS P.O. BOX 65, MCCONELLSBURG, PA 17233 Social Security #: 189-46-5380 Date of Birth: 01-07-1956 SUIO-576492 33922-L13 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -VS- CASE NO: 05-949-CV THOMAS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, 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: 08/22/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DEl1-580175 33922-L14 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -VS- CASE NO: 05-949-CV THOMAS NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCOMENTS AND THINGS FOR DISCOVERY PDRSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: MICHAEL METRO, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, 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 objectiQn 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: 08/02/2005 MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT CC: CASEY SHORE, ESQ. PATRICIA HOFFMAN - 05-205 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET '800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-308458 33922-C02 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HARRY JOHNSTON, D.O. ROBERT P. DURNING, M.D. DR. ROBERT N. RICHARDS, M.D. APRIL ARMSTRONG, M.D. PETER JABLIN, M.D. JOEY L. LANE, O.D. CHRISTINA PRATERS, M.D. DR. JAMES HAMMOND CHAMBERSBURG HOSPITAL CHAMEERSBURG HOSPITAL FULTON COUNTY MEDICAL CENTER CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS " XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS X-RAY ONLY MEDICAL RECORDS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X -RAY ONLY MEDICAL RECORDS X-RAY ONLY DE02-308458 33922-C02 COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND SOUDERS FileNo. 05-949.CY Ys. THOMAS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HERSHEY MEDICAl. CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE A TT ACHED RIDER **** at The MCS Groun Ine ]601 Market Street Suite 800 Philadelphia PA 19103 You may deliver or mail legible copies of the documents or ,Produce things requested by this subpoena; together with the certificate of compliance, to the party making this'request at the address listed above. You have the right. to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: CASEY SHORE. ESO. 2411 N FRONT ST. HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BYTH~T: Prothon tary/CI " I Date: AlI6iUI~ a"1"J.F. ~S- ,;/ Seal of the Court Deputy 33922-14 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: 33922 RICKY SOUDERS Prior approval is required for fees in excess of $ I 00.00 for hospitals, $50.00 for aI] other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for aI] other providers. Entire hospital medical fI]e, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication! prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and aI] such items as may be stored in a computer database or otherwise in e]ectronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject: RICKY SOUDERS P.O. BOX 65, MCCONELLSBURG, PA 17233 Social Security #: 189-46-5380 Date of Birth: 01-07-1956 SUIO-57649433922-L14 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -VS- CASE NO: o5-949-CV THOMAS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, 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: 08/22/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DEl1-58017633922-L15 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SOUDERS TERM, -VS- CASE NO: 05-949-CV THOMAS NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE J>OC(JMENTS AND THINGS FOR DISCOVERY PVRSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: MICHAEL METRO, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE. 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 objectiqn 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: OS/02/2005 MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT CC: CASEY SHORE, ESQ. PATRICIA HOFFMAN - 05-205 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET .SOO PHILADELPHIA, PA 19103 (215) 246-0900 DE02-30S45S 33922-C02 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HARRY JOHNSTON. D.O. ROBERT P. DURNING, M.D. DR. ROBERT N. RICHARDS, M.D. APRIL ARMSTRONG, M.D. PETER JAELIN, M.D. JOEY L. LANE. O.D. CHRISTINA PRATERS, M.D. DR. JAMES HAMMOND CHAMEERSBURG HOSPITAL CHAMBERSBURG HOSPITAL FULTON COUNTY MEDICAL CENTER CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS X-RAY ONLY MEDICAL RECORDS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY DE02-308458 33922 -C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SOUDERS FileNo. 05-949-CV vs. TIlOMAS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HERSHEY MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group Ine 1601 Market Street Suite ROO Phi]adelphia PA ]9103 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 atthe address lisied 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. TIllS SUBPOENA WAS ISSUED AT TIlE REQUEST OF TIlE FOLLOWING PERSON: NAME: ADDRESS: CASEY SHORE. ESO. 2411 N FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant Date: P1- All6ZZ ZlIli c2F- ~ Seal of the Court Deputy 33922-15 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: 33922 RICKY SOUDERS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. P]ease cal] for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all x-ray fI]ms and reports, including any and all such items as may be stored in a computer database or otherwise in e]ectronic form, pertaining to: Dates Requested: up to and including tbe present. Subject: RICKY SOUDERS P.O. BOX 65, MCCONELLSBURG, PA 17233 Social Security #: 189-46-5380 Date of Birtb: 01-07-1956 8U10-576496 33922-L1S (") ~- ;:~;. '" "'" "'" "" ".. c: <:') !:i? 5!-c. fn~ -0 rr: ,~r:JC i~~ ~'5 F?, j;} ::0 -< 1'-' '-0 t'" - :i: "'9 -, ~ <:::> N - .. .... Jenni Henley Allen, Esquire NEALON, GOVER & PERRY 2411 North Front Street Harrisburg, PA 17110 (717) 232.9900 iallen@ngplawfinn.com VS_ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.05.949.CV RICKY J. SOUDERS, Plaintiff STEPHEN B. THOMAS, Defendant CIVIL ACTION - LAW NOTICE OF DEATH The death of Stephen B. Thomas, a party to the above-action, during dependency of this action is noted upon the record_ Respectfully submitted, NEALON GOVER & PERRY By: , .... CERTIFICATE OF SERVICE AND NOW, this ~ay of August, 2006, I hereby certify that I have served the foregoing NOTICE OF DEATH on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Mark S. Silver, Esquire JOSEPH A. KLEIN, P.C. 500 North Third Street, ih Floor Harrisburg, PA 17101 r " (') ...., ~ = ~ = ..... ;:ljm ". ~:o rn c:::: Z:1:' en d 25:, I (f) _._ -.J ~<; <C; " )>' .-, Zc; :J: '0 :i>f;; ':! ~ Q ~ VI .- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RICKY J. SOUDERS, CIVIL DIVISION P]aintiff, NO: 05.949.CV CODE: vs. STEPHEN B. THOMAS, PRAECIPE TO SETTLE AND DISCONTINUE Defendant Filed on Behalf of Plaintiff: Counsel of Record for this Party: Michae] E. Metro Pa. J.D. No. 62185 VILLANOV A LAW OFFICES, P.C ] 6 Chatham Square Pittsburgh, PA 152]9 A JURY TRIAL IS DEMANDED. (412) 471-1933 - ~..,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RICKY J. SOUDERS, CIVIL DIVISION P]aintiff, vs. No. 05-949-CV STEPHEN B. THOMAS Defendant PRAECIPE TO SETTLE AND DISCONTINUE TO THE PROTHONOTARY: Kindly Settle and Discontinue the above-captioned civil matter. Respectful]y submitted, 4/~ Michae] E. Metro Attorney for Plaintiff g ~ ""tJrf.: 92~\;.- ~{~c r;' \"- :.~'- r-> ;g cS"' ~ ,,-, N N -- " . Q, ~~ :g~ C),() -:1~:+r\ ()o ~r-n ':::--I ~ -0 :% c..) .' - N