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HomeMy WebLinkAbout14-2571 Supreme Co .ennsylvania CQU f� CQI11 ' "',Pleas For Prothonotary Use Only: Docket No: 1 County ZO �. a. The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S 0 Complaint 0 Writ of Summons 0 Petition ® Transfer from Another Jurisdiction 0 Declaration of Taking E Lead Plaintiff's Name: Lead Defendant's Name: C Danielle M. George Erie Insurance T Dollar Amount Requested: ®within arbitration limits I Are money damages requested? 9 Yes 0 No (check one) ®x outside arbitration limits O N Is this a Class Action Suit? 0 Yes El No Is this an MDJAppeal? [3 Yes 9 No A Name of Plaintiff /Appellant's Attorney: Michael E. Kosik 0 Check here if you have no attorney (are a Self- Represented [Pro Se] Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS 0 Intentional 0 Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution 0 Debt Collection: Credit Card 0 Board of Assessment ®x Motor Vehicle Debt Collection: Other 0 Board of Elections 0 Nuisance Dept. of Transportation 0 Premises Liability Statutory Appeal: Other S 0 Product Liability (does not include E mass tort) [3 Employment Dispute: Discrimination 0 Slander/Libel/ Defamation ® Employment Dispute: Other 0 Zoning Board C 0 Other: ® Other: T I 0 Other: O MASS TORT 0 Asbestos N 0 Tobacco 0 Toxic Tort - DES 0 Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS 0 Toxic Waste 0 Ejectment 0 Common Law /Statutory Arbitration B 0 Other: 0 Eminent Domain /Condemnation 0 Declaratory Judgment Ground Rent ® Mandamus 0 Landlord /Tenant Dispute © Non- Domestic Relations 0 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure: Commercial 0 Quo Warranto Dental 0 Partition 0 Replevin 0 Legal 0 Quiet Title 0 Other: J Medical 0 Other: 0 Other Professional: Updated 11112011 2,; r , � P ^ COU � FP ! VA Pro;, SCHMIDT KRAMER Mike E. Kosik, Esquire Attorney 1D# : 36513 209 State Street Harrisburg, PA 17101. P(717) 232 -6300 F(717) 232 -6467 mkosik @schmidtkramer.com Attorneys for Plaintiff DANIELLE M. GEORGE IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNA. V. CIVIL ACTION - LA NO. U l ERIE INSURANCE, Defendant JURY TRIAL DEMANDED NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. � oL YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249 -3166 AVISO USTED HA SIDO DEMANDADO /A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despues de la notificaci6n de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar acci6n como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamaci6n o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mds aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249 -3166 SCHMIDT KRAMER Mike E. Kosik, Esquire Attorney ID# : 36513 209 State Street Harrisburg, PA 17.101 P(717) 232 -6300 F(717) 232 -6467 mkosik @schmidtkramer.com Attorneys for Plaintiff DANIELLE M. GEORGE IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNA. V. CIVIL ACTION - LAW NO. ERIE INSURANCE, Defendant JURY TRIAL DEMANDED COMPLAINT 1. Plaintiff Danielle M. George is an adult individual and citizen of the Commonwealth of Pennsylvania, who resides at 63 Vine Street, Newville, Cumberland County, Pennsylvania 17241. 2. Defendant Erie Insurance is an insurance carrier licensed to write insurance policies in the Commonwealth of Pennsylvania pursuant to the Pennsylvania Motor Vehicle Financial Responsibility Law (MVFRL), 75 Pa.C.S.A. §1701, et se q. (1984), and maintains an office at Rossmoyne Business Center, 4901 Louise Drive, P.O. Box 2013, Mechanicsburg, Pennsylvania, and regularly conducts business in Cumberland County, Pennsylvania. 3. On or about Friday, May 28, 2010, on State Highway 74 in South Middleton Township, Cumberland County, Pennsylvania, Plaintiff Danielle M. George was involved in a motor vehicle accident. 4. Prior to and including the date of the motor vehicle accident, Plaintiff Danielle M. George was insured under an automobile insurance policy covering the vehicle she was operating and issued by Defendant Erie Insurance at Policy Number Q O1 0408226. 5. The aforesaid Erie Insurance policy included underinsured motorist benefits for Plaintiff Danielle M. George in accordance with the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law, §1731 -1738. 6. At the time of the accidents, Plaintiff Danielle George purchased underinsured motorist benefits in the amount of $100,000.00 to protect her if she were injured as a result of an underinsured motorist. See Declaration page attached as Exhibit A. 7. At that time and place, the tortfeasor was not paying attention to traffic and, suddenly and without warning, violently slammed into the rear of the Plaintiff's stopped vehicle. 8. At the time of the aforesaid motor vehicle accident, the tortfeasor was underinsured. 9. As a result of the aforementioned accident, Plaintiff Danielle M. George sustained painful and severe injuries which include but are not limited to severe neck and low back pain, bilateral arm numbness, and right brachial plexopathy resulting in serious impairment of her bodily functions which has continued to the present time and is expected to be permanent. 1.0. As a result of the aforementioned injuries, Plaintiff Danielle M. George has been required to undergo extensive medical treatment in an effort to restore herself to health. 11. Plaintiff Danielle M. George continues to suffer from injuries resulting from this accident for which she has and will continue to need medical treatment in the future. 12. Plaintiff Danielle George's treating physician have confirmed that she is totally disabled as a result of injuries suffered in the motor vehicle accident for which she continues to receive treatment. 13. Plaintiff Danielle M. George has undergone and in the future will undergo great physical and mental suffering, great inconvenience in carrying out her daily activities, and loss of life's pleasures and enjoyment. 14. Defendant Erie Insurance has refused to tender the underinsured motorist limit in her case despite her extensive injuries and disability. 15. Plaintiff Danielle George has been unable to reach an amicable resolution of her underinsured motorist claim; and therefore in accordance with the Erie policy must bring suit to enforce her right to the benefits she purchased in her automobile insurance policy. WHEREFORE, Plaintiff Danielle M. George demands judgment against Defendant Erie Insurance underinsured motorist benefits, in the amount of $100,000, exclusive of interest and costs and in excess of jurisdictional amount requiring compulsory arbitration. SC ER PC Date: Michael E. Kosik I.D. No. 36513 209 State Street Harrisburg, PA 17110 (717) 232 -6300 Attorney for Plaintiff VERIFICATION BASED UPON PERSONAL KNOWLEDGE AND INFORMATION OBTAINED THROUGH COUNSEL I, Danielle George, verify that I am the Plaintiff in the foregoing action and that the attached Complaint is based upon information which has been gathered by my counsel in the preparation of this lawsuit. The language of the Complaint to the extent that it is based upon information that I have given to my counsel is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the Complaint are that of counsel, I relied upon counsel making this Verification. I understand that intentional false statements herein are subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsifications to authorities. Date: ri4E / PRO i;- 201 f4 Y PFj 1:144 JOHNSON, DUFFIE, STEWART & WEIDNEUMBFR� / N By: John A. Statler PENNNS }'LV A NI 0 j "� I.D. No. 43812 301 Market Street P. 0. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 jas@jdsw.com Attorneys for Defendant DANIELLE M. GEORGE, IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA vs. ERIE INSURANCE, Defendant : CIVIL ACTION — LAW : NO. 14-2571 Civil Term : JURY OF TWELVE PERSONS DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of John A. Statler, Esquire of Johnson, Duffie, Stewart & Weidner, P.C. as counsel for Defendant, Erie Insurance, in the above - captioned matter. Respectfully submitted, JOHNSON:I s STEWART & WEIDNER By: Date: May 1, 2014 621011 John A. Stat , Attorney I.D. No. 43 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant squire CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing Praecipe for Entry of Appearance upon all parties or counsel of record by depositing a copy of same in the United States Mail at Lemoyne, Pennsylvania, with first-class postage prepaid on the f54day of May, 2014 addressed to the following: Michael E. Kosik, Esquire Schmidt Kramer 209 State Street Harrisburg, PA 17101 JOHNSON, DUFFIE, STEWART & WEIDNER By: John A. Sta Attorney I.D. No. 43812 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFF!C_ OF THE ,SHERIFF t 1LED-QFFICE THE PRO f , ONO 2 It,1114¥-7 AMH: I I CI1�E�dtdSYL�,� ��'��� IIIA Danielle M George vs. Erie Insurance Case Number 2014-2571 SHERIFF'S RETURN OF SERVICE 04/30/2014 09:47 AM - Deputy Brian Grzyboski, being duly sworn according to law, served the requested Complaint & Notice by handing a true copy to a person representing themselves to be Gregg Knutson, Claims Supervisor , who accepted as "Adult Person in Charge" for Erie Insurance at 4901 Louise Drive, Lower Allen Township, Mechanicsburg, PA 17055. SHERIFF COST: $39.79 May 01, 2014 (G) County; uite Sheriff, Te eosoft, inc. BRIAN GRZY SO ANSWERS, RONi�R ANDERSON, SHERIFF JOHNSON, DUFFIE, STEWART & WEIDNER By: John A. Statler I.D. No. 43812 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 jas@jdsw.com Ii�� , L,/ CIJI\18 RCA COUNTY' PENNS tilfq Attorneys for Defendant DANIELLE M. GEORGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. ERIE INSURANCE, Defendant CIVIL ACTION — LAW NO. 14-2571 Civil Term JURY OF TWELVE PERSONS DEMANDED STIPULATION AND NOW, come the parties to the above case, by and through their respective counsel, who hereby agree and stipulate as follows: 1. The proper name of the Defendant in this case is Erie Insurance Exchange. 2. The caption of this case should be amended to reflect that Erie Insurance Exchange is the Defendant. 3. All references in the Complaint to Erie Insurance shall be deemed to apply to Erie Insurance Exchange. Stipulate and agreed to by: Schmidt K B Michael E. Kosik, Esquire Attorney I.D. No. 36513 209 State Street Harrisburg, PA 17101 Attorneys for Plaintiff. Danielle M. George Johnson, Duffie, Stewart & Weidner, P.C. By: John A. Statler, Esquire Attorney I.D. No. 43812 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Attorneys for Defendant Erie Insurance/Erie Insurance Exchange CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing Stipulation upon all parties or counsel of record by depositing a copy of same in the United States Mail at Lemoyne, Pennsylvania, with first-class postage prepaid on the 7 day of May, 2014 addressed to the following: Michael E. Kosik, Esquire Schmidt Kramer 209 State Street Harrisburg, PA 17101 JOHNS 'UFFIE, STEWART & WEIDNER By: John A. Statler Attorney IID. No. 43812 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant Erie Insurance/Erie Insurance Exchange w7 F OLE0-Ur F 0i. OF THE PR©TFiONO TA Y 2014 MAY i 3 Pi 35 CUMBERLAND COUNT`, PENNSYLVANIA DANIELLE M GEORGE, •IN THE COURT OF COMMON PLEAS OF Plaintiff •CUMBERLAND COUNTY, PENNSYLVANIA vs. ERIE INSURANCE, Defendant �a� AND NOW, this day of CIVIL ACTION — LAW NO. 14-2571 Civil Term JURY OF TWELVE PERSONS DEMANDED ORDER , 2014, upon stipulation of the parties, it is hereby ORDERED that the Defendant in this case is Erie Insurance Exchange, not Erie Insurance. It is further ORDERED that the caption of this case shall be amended to reflect that Erie Insurance Exchange is the Defendant in place of Erie Insurance. By the Court: Distribution: ichael E. Kosik, Esquire, Schmidt Kramer, 209 State Street, Harrisburg, PA 17101. �hn A. Statler, Esquire, Johnson, Duffie, Stewart & Weidner, P.C., 301 Market Street, Lemoyne, PA 17043 �bepi >z.s 1)2.4 s/ apy I(r �rr CUMBERLAND v PENNS YLVA NCow j �T JOHNSON, DUFFIE, STEWART & WEIDNER By: John A. Statler I.D. No. 43812 301 Market Street P. 0. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 jas@jdsw.com DANIELLE M. GEORGE, Plaintiff VS. ERIE INSURANCE EXCHANGE, Defendant Attorneys for Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION — LAW : NO. 14-2571 Civil Term : JURY OF TWELVE PERSONS DEMANDED NOTICE TO PLEAD TO: Danielle M. George, Plaintiff c/o Michael E. Kosik, Esquire Schmidt Kramer 209 State Street Harrisburg, PA 17101 YOU ARE REQUIRED to plead to the within Answer With New Matter within 20 days of service hereof or a default judgment may be entered against you. JOHNSON, DUFFIE, STEWART & WEIDNER Date: SI/ Li h By: John A. Statler, Esquire Attorney I.D. No. 43812 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant JOHNSON, DUFFIE, STEWART & WEIDNER By: John A. Statler I.D. No. 43812 301 Market Street P. 0. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 jas@jdsw.com DANIELLE M. GEORGE, Plaintiff vs. ERIE INSURANCE EXCHANGE, Defendant Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — LAW NO. 14-2571 Civil Term JURY OF TWELVE PERSONS DEMANDED ANSWER OF DEFENDANT ERIE INSURANCE EXCHANGE TO PLAINTIFF'S COMPLAINT INCLUDING NEW MATTER AND NOW, comes the Defendant, Erie Insurance Exchange, by its attorneys, Johnson, Duffie, Stewart & Weidner, P.C., who file the following Answer and New Matter in response to the Plaintiffs Complaint in this case: 1. Admitted on information and belief. 2. Defendant Erie Insurance Exchange is a reciprocal insurance exchange. It is admitted that Erie Insurance Exchange has an office located at 4901 Louise Drive, Mechanicsburg, Pennsylvania and further admitted that Erie Insurance Exchange regularly conducts business in Cumberland County, Pennsylvania. 3. Admitted. 4. Admitted. 5. It is admitted that the aforesaid Erie Insurance Exchange policy included underinsured motorist coverage. 6. It is admitted that the Erie Insurance policy covering Danielle George at the time of the subject accident included underinsured motorist coverage in the amount of $100,000. It is further admitted that Ms. George would only be entitled to underinsured motorist benefits if she were injured by an accident caused by an underinsured motorist. 7. Denied. After reasonable investigation, Defendant is without information sufficient to form a belief as to the truth or falsity of the specific averments in this paragraph and, therefore, denies the same. By way of further answer, Erie Insurance Exchange admits that the Plaintiffs vehicle was struck in the rear by another vehicle. 8. The averments in this paragraph constitute conclusions of law to which no response is required. In the event a response is deemed to be required, after reasonable investigation, Defendant Erie Insurance Exchange is without information sufficient to form a belief as to the truth or falsity of the averments that the tortfeasor who caused the subject accident was underinsured and, therefore denies the same and demands strict proof at time of trial if deemed material. 9. Denied. After reasonable investigation, Defendant Erie Insurance Exchange is without information sufficient to form a belief as to the truth or falsity of the averments in this paragraph and, therefore, denies the same and demands strict proof at time of trial if deemed material. 10. Denied. After reasonable investigation, Defendant Erie Insurance Exchange is without information sufficient to form a belief as to the truth or falsity of the averments in this paragraph and, therefore, denies the same and demands strict proof at time of trial if deemed material. 11. Denied. After reasonable investigation, Defendant Erie Insurance Exchange is without information sufficient to form a belief as to the truth or falsity of the averments in this paragraph and, therefore, denies the same and demands strict proof at time of trial if deemed material. 12. Denied. After reasonable investigation, Defendant Erie Insurance Exchange is without information sufficient to form a belief as to the truth or falsity of the averments in this paragraph and, therefore, denies the same and demands strict proof at time of trial if deemed material. 13. Denied. After reasonable investigation, Defendant Erie Insurance Exchange is without information sufficient to form a belief as to the truth or falsity of the averments in this paragraph and, therefore, denies the same and demands strict proof at time of trial if deemed material. 14. It is admitted that Defendant Erie Insurance Exchange has refused to tender the underinsured motorist limits of the subject policy based upon the available damages information. 15. It is admitted that the Plaintiff has been unable to reach an amicable resolution of her underinsured motorist claim. It is further admitted that in accordance with the Erie policy the Plaintiff has filed this lawsuit to determine the amount, if any, of underinsured motorist benefits to which she is entitled from the Defendant. WHEREFORE, Defendant Erie Insurance Exchange respectfully requests that the Plaintiffs Complaint be dismissed and that judgment be entered in favor of Defendant Erie Insurance Exchange and against the Plaintiff Danielle M. George in this case. NEW MATTER By way of additional answer and reply, Defendant Erie Insurance Exchange raises the following new matters: 16. Some or all of the Plaintiff's claims are barred in whole or in part and/or are limited by the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa.C.S.A. § 1701 et seq. and especially by § 1722 of that law. 17. To the extent that the Plaintiffs claims for damages have been paid or will be payable in the future by insurance, group contract or other arrangements for payment, then claims for those damages are barred by the defense of payment, by the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa.C.S.A. § 1722 and by the Patient Protection and Affordable Care Act, Public Law 111-148, a/k/a "ObamaCare". WHEREFORE, Defendant Erie Insurance Exchange respectfully requests that the Plaintiffs Complaint be dismissed and that judgment be entered in favor of Defendant Erie Insurance Exchange and against the Plaintiff Danielle M. George in this case. Respectfully submitted, JOHNSON7 STE ART & WEIDNER By: Date: May 1 '1 , 2014 622426 John A. Statler, Esq'u Attorney I.D. No. 43812 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant Erie Insurance Exchange VERIFICATION I, Douglas Kocher, hereby acknowledge that I ama representative of the Defendant in this action; that I have read the foregoing Answer of Defendant to Plaintiff's Complaint Including New Matter; and that the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. BY: ERIE INSURANCE EXCHANGE DOUGLA KOC R DATE: .51/1///V CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing Answer with New Matter to Plaintiff's Complaint upon all parties or counsel of record by depositing a copy of same in the United States Mail at Lemoyne, Pennsylvania, with first-class postage prepaid on the / 7 day of May, 2014 addressed to the following: Michael E. Kosik, Esquire Schmidt Kramer 209 State Street Harrisburg, PA 17101 JOHNSON, DUFFIE, STEWART & WEIDNER By: John A. Statler, Esquire I.D. No. 43812 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 jas@jdsw.com Attorney for Defendant Erie Insurance Exchange SCHMIDT KRAMER Mike E. Kosik, Esquire Attorney ID# : 36513 209 State Street Harrisburg, PA 171.01. P(717) 232-6300 F(717)232-6467 mkosik@schmidtkramer.com Attorneys for Plaintiff ND Co, Y(Vglfl��l'/ DANIELLE M. GEORGE : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNA. v. CIVIL ACTION - LAW NO. Ai,. 0151 ERIE INSURANCE EXCHANGE, Defendant JURY TRIAL DEMANDED PLAINTIFF'S REPLY TO DEFENDANT ERIE INSURANCE EXCHANGE'S NEW MATTER AND NOW comes Plaintiff Danielle M. George, by and through her attorneys, SCHMIDT KRAMER, and hereby replies to the New Matter of Defendant Erie Insurance Exchange as follows: 16. This averment is a conclusion of law to which no responsive pleading is required. To the extent a further response may be deemed proper it is specifically denied that the Pennsylvania Motor Vehicle Responsibility Law, 75 Pa.C.S.A § 1701 et seq. including Section 1722 of that Law bars in whole or in part or limits Plaintiff's claims against Defendant, Erie Insurance Exchange. 17. Denied. This averment is a conclusion of law which no responsive pleading is required. To the extent that a further response may be deemed proper it is specifically denied that the Patient Protection and Affordable Care Act, Public Law 111-148, in anyway effects the Defendant's obligation to pay future medical expenses. The Affordable Care Act, to the extent it is in anyway applicable to Plaintiff's claim, would be considered a collateral source for which the Defendant Erie Insurance Exchange is not entitled to claim any benefit. By way of further response Plaintiff, Danielle George does not seek to plead, prove or recover of any medical expenses which were paid by Erie that were part where part of the first party medical claim, therefore, the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa.C.S.A § 1722 is inapplicable with respect to this claim. WHEREFORE, Plaintiff respectfully requests this Honorable Court to dismiss Defendant's Answer and New Matter and enter judgment in her favor against the Defendant. Date: "7 2-o ZO ► 4 ER PC Michael E. Kosik I.D. No. 36513 209 State Street Harrisburg, PA 17110 (717) 232-6300 Attorney for Plaintiff SCHMIDT KRAMER Mike E. Kosik, Esquire Attorney ID# : 36513 209 State Street Harrisburg, PA 17101. P(717) 232-6300 F(717) 232-6467 mkosik@schmidtkramer.com Attorneys for Plaintiff DANIELLE M. GEORGE IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNA. v. CIVIL ACTION - LAW NO. ERIE INSURANCE EXCHANGE, Defendant JURY TRIAL DEMANDED AFFIDAVIT I, MICHAEL E. KOSIK, ESQUIRE, being duly sworn according to law, deposes and states that I am counsel for Plaintiffs, and I am authorized to make this Affidavit on behalf of said Plaintiffs, and the facts set forth in the foregoing Reply to New Matter, are true and correct to the best of my knowledge, information, and belief. Sworn to and subscribed before me this ash day of lY\ c& Michael E. Kosik , 2012. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Laura Trimble, Notary Publk WashingMy�COmmm Twp., Franklin County MEMBER, Iss o res Jan. 16, 2017 ASSOCIATION OF NOTARIES YG1AAA-e,f Notary Public My Commission Expires: Spnu6\ X011 CERTIFICATE OF SERVICE I, Laura Trimble, an employee of the law firm of Schmidt Kramer, P.C., do hereby certify that I am this day serving a true and correct copy of Plaintiffs Reply to Defendant's New Matter upon all counsel of record via United States first class mail, addressed as follows: John A. Statler, Esquire Johnson Duffle 301 Market Street PO Box 109 Lemoyne, PA 17043-0109 Counsel for Defendant Erie Insurance Exchange Date: I Li aura Trimble FILED-OFF-ICI:- THE --ICI:- CERTIFICATE 2Ci, JUN 30 41111: 06 PREREQUISITE TO SERVICE OF A SUB POENACUMEL r"; PENNS YLVACOUNTY PURSUANT TO RULE 4009.22 IN THE MATTER OF: Court of Common Pleas - Cumberland County, PA DANIELLE M. GEORGE vs. TERM: ERIE INSURANCE EXCHANGE CASE No: 14-2571 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22. RecordTrak on behalf of JOHN STATLER Defendant certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) No objection to the subpoena has been received or it has been waived, and (3) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. Date : 06/13/2014 RecordTrak on behalf of /S/ JOHN STATLER Attorney for Defendant RT#: 267737 RECORDS PERTAIN TO: DANIELLE M. GEORGE DANIELLE M. GEORGE : COURT: Court Of Common Pleas - Cumberland County, Pa vs. : TERM: ERIE INSURANCE EXCHANGE : DOCKET: 14-2571 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS TO: MICHAEL KOSIK SCHMIDT KRAMER, PC 209 STATE ST HARRISBURG, PA 17101 (717) 232-6467 June 5, 2014 Please take notice that on behalf of JOHN STATLER, attorney for Defendant, RecordTrak intends to serve a subpoena identical to the one(s) attached to this notice. You have until June 25, 2014 to file of record and serve upon the undersigned an objection to the subpoena(s). If no objection is made, the subpoena(s) will be served. IF PLAINTIFF'S COUNSEL AGREES TO WAIVE THE 20 DAY NOTICE PERIOD, PLEASE INDICATE BELOW AND FAX SAME TO THE UNDERSIGNED AT YOUR EARLIEST OPPORTUNITY. IF YOU WISH TO PURCHASE COPIES OF THE RECORDS, PLEASE CONTACT RECORDTRAK FOR PRICING AND FAX THIS CORRESPONDENCE BY June 25, 2014 TO (610) 992-1405. All records will be provided (including no record statements) as produced by each record location. Daniel Wake 610.354.8348 RECORDTRAK 651 Allendale Road P. O. Box 61591 King of Prussia, PA 19406 LIST OF RECORD CUSTODIANS AND SUBPOENAS TAG I RECORD CUSTODIAN SNYDER & DORER Yes, I would like a copy of all of the records listed above. Yes, I would like specific records I have indicated above. SIGNATURE: Date: FIRM: YES, I AGREE TO WAIVE THE 20 DAY NOTICE PERIOD FOR ALL SUBPOENAS ON THIS NOTICE Signature of Plaintiff's Counsel: Date: FIRM: EMAIL: RT: 267737.1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DANIELLE M. GEORGE V. ERIE INSURANCE EXCHANGE File No:14-2571 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: SNYDER & DORER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoena together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought. If you fall to produce the documents or things required by this subpoena within twenty (2(1) days afe• its service, the party serving this subpoena may seek a court order compelling you to comply with it, THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RecordTrak, JOHN STATLER Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 22 Supreme Court ID# Attorney for De%pdant' 1291 DATE: Seal of the Court BY THE COURT: RE: DANIELLE M. GEORGE vs. ERIE INSURANCE EXCHANGE CASE NO. 14-2571 RECORDTRAK FILE #: 267737; TAG 1 LOCATION: SNYDER & DORER RECORDS PERTAIN TO: DANIELLE M. GEORGE SS #: , DOB: X . COPIES OF ALL DEPOSITION TRANSCRIPTS, PLAINTIFF'S ANSWERS TO INTERROGATORIES, SURVEILLANCE REPORTS, SURVEILLANCE VIDEOS, AND COLOR AND/OR BLACK AND WHITE PHOTOGRAPHS OF THE VEHICLES INVOLVED IN THE ACCIDENT PERTAINING TO DANIELLE ZACH V. ZACHARY HAIR; D/L: XX/XX/XX; INSURED: OLIVIA HAIR; INSURED DRIVER: ZACHARY HAIR; POLICY NO. XX XX D XXX XXX; CLAIMANT: DANIELLE ZACH A/K/A DANIELLE GEORGE. FILED -OFFICE OF THE PROTHONOTARY 20141114 PH 1: 3 3' CUMBERLAND COUNTY PENNSYLVANIA PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 CERTIFICATE IN THE MATTER OF: Court of Common Pleas - Cumberland County, PA DANIELLE M. GEORGE vs. TERM: ERIE INSURANCE EXCHANGE CASE No: 14-2571 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22. RecordTrak on behalf of JOHN STATLER Defendant certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) No objection to the subpoena has been received or it has been waived, and (3) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. Date : 07/10/2014 RecordTrak on behalf of /S/ JOHN STATLER Attorney for Defendant RT#: 267737 RECORDS PERTAIN TO: DANIELLE M. GEORGE DANIELLE M. GEORGECOURT: Court Of Common Pleas -Cumberland County, Pa vs. TERM: ERIE INSURANCE EXCHANGE : DOCKET: 14-2571 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS TO: MICHAEL KOSIK SCHMIDT KRAMER, PC 209 STATE ST HARRISBURG, PA 17101 (717) 232-6467 June 24, 2014 Please take notice that on behalf of JOHN STATLER, attorney for Defendant, RecordTrak intends to serve a subpoena identical to the one(s) attached to this notice. You have until July 14, 2014 to file of record and serve upon the undersigned an objection to the subpoena(s). If no objection is made, the subpoena(s) will be served. IF COUNSEL AGREES TO WAIVE THE 20 DAY NOTICE PERIOD, PLEASE INDICATE BELOW AND FAX SAME TO THE UNDERSIGNED AT YOUR EARLIEST OPPORTUNITY. IF YOU WISH TO PURCHASE COPIES OF THE RECORDS, PLEASE CONTACT RECORDTRAK FOR PRICING AND FAX THIS CORRESPONDENCE BY July 14, 2014 TO (610) 992-1405. All records will be provided (including no record statements) as produced by each record location. Daniel Wake 610.354.8348 RECORDTRAK 651 Allendale Road P. O. Box 61591 King of Prussia, PA 19406 LIST OF RECORD CUSTODIANS AND SUBPOENAS TAG RECORD CUSTODIAN 2 CARLISLE REGIONAL MEDICAL CENTER (MED) 3 BIG SPRING PHYSICAL THERAPY & SPORTS MEDICINE 4 CHAMBERSBURG HOSPITAL (MED) 5 CHAMBERSBURG HOSPTTAL (RAD) 6 ORTHOPEDIC INSTITUTE OF PENNSYLVANIA 8 CARLISLE REGIONAL MEDICAL CENTER (RAD) 9 WALNUT BOTTOM RADIOLOGY 10 PENN STATE MILTON S. HERSHEY MEDICAL CENTER (MED) 11 PENN STATE MILTON S. HERSHEY MEDICAL CENTER (RAD) 12 CUMBERLAND VALLEY NEUROSURGICAL CONSULTANTS 13 SADLER HEALTH CENTER 14 GRAHAM MEDICAL CLINIC DANIELLE M. GEORGE : COURT: Court Of Common Pleas - Cumberland County, Pa vs. TERM: ERIE INSURANCE EXCHANGE DOCKET: 14-2571 Yes, I would like a copy of all of the records listed above. Yes, I would like specific records I have indicated above. SIGNATURE: Date: FIRM: YES, I AGREE TO WAIVE THE 20 DAY NOTICE PERIOD FOR ALL SUBPOENAS ON THIS NOTICE Signature of Plaintiff's Counsel: Date: FIRM: EMAIL: Page 2 RT: 267737.2 Z. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DANIELLE M. GEORGE V. ERIE INSURANCE EXCHANGE File No:14-2571 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY_ PURSUANT TO RULE 4009.22 TO: CARLISLE REGIONAL MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoeni together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought, If you fail to produce the documents or things required by this subpoena within twenty (20) days afte: its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON; Name: RecordTrak, JOHN STATLER Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (8001 220-1291 Supreme Court ID# Attorney for: Defendant DATE: Seal of the Court BY THE COURT: 0.6gt.;tL./ ZW-0/L Prothonotary RE: DANIELLE M. GEORGE vs. ERIE INSURANCE EXCHANGE CASE NO. 14-2571 RECORDTRAK FILE #: 267737; TAG 2 LOCATION: CARLISLE REGIONAL MEDICAL CENTER (MED) RECORDS PERTAIN TO: DANIELLE M. GEORGE SS #: , DOB: X.. ALL MEDICAL RECORDS DATED XX/XX/XXXX TO PRESENT ONLY -STRICTLY PERTAINING TO THE CARLISLE REGIONAL PAIN MANAGEMENT CENTER LOCATED AT X JENNIFER CT, CARLISLE, PA **AND** ALL OTHER CARLISLE REGIONAL MEDICAL CENTER MEDICAL RECORDS DATED X1/X/XX1X - X/1X/XX1X AND X/XX/XX I X - THE PRESENT INCLUDING INPATIENT, OUTPATIENT AND EMERGENCY ROOM TREATMENT, ALL CLINICAL CHARTS, REPORTS, INCLUDING RADIOLOGY REPORTS AND PATHOLOGY REPORTS, DOCUMENTS, CORRESPONDENCE, TEST RESULTS, STATEMENTS, QUESTIONNAIRES/HISTORIES, AND RECORDS RECEIVED FROM OTHER PHYSICIANS. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. RT: 267737.3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DANIELLE M. GEORGE V. ERIE INSURANCE EXCHANGE File No:14-2571 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY_ PURSUANT TO RULE 4009.22 TO: BIG SPRING PHYSICAL THERAPY & SPORTS MEDICINE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider, at 651 Allendale Road King of Prussia PA 19406 Yon may deliver or mail legible copies of the documents or produce things requested by this subpoeni together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or 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 A7 711E REQUEST OF THE FOLLOWING PERSON: Narne: RecordTrak, JOHN STATLER Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 220-1291 Supreme Court ID# Attorney for: Defendant DATE: Seal of the Court BY THE COURT: RE: DANIELLE M. GEORGE vs. ERIE INSURANCE EXCHANGE CASE NO. 14-2571 RECORDTRAK FILE #: 267737; TAG 3 LOCATION: BIG SPRING PHYSICAL THERAPY & SPORTS MEDICINE RECORDS PERTAIN TO: DANIELLE M. GEORGE SS #: , DOB: X . ALL MEDICAL RECORDS DATED XX/XX/XXXX TO PRESENT. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PATIENTS INFORMATION SHEET. RT: 267737.4 C1. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DANIELLE M. GEORGE V. ERIE INSURANCE EXCHANGE File No: 14-2571 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: 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 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoena together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought. i If you fail to produce the documents or•i tings required by this subpoena within twenty (20) days afte: its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RecordTrakz JOHN STATLER Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 220-1291 BY THE COURT: Supreme Court JD## Attorney for: Defendant DATE: Seal of the Court (2�3D�iy law2L1.110 Prothonotary RE: DANIELLE M. GEORGE vs. ERIE INSURANCE EXCHANGE CASE NO. 14-2571 RECORDTRAK FILE #: 267737; TAG 4 LOCATION: CHAMBERSBURG HOSPITAL (MED) RECORDS PERTAIN TO: DANIELLE M. GEORGE SS #: , DOB: X . MEDICAL RECORDS DATED XX/XX/XXXX TO PRESENT ONLY. INCLUDE INPATIENT, OUTPATIENT AND EMERGENCY ROOM TREATMENT, ALL CLINICAL CHARTS, REPORTS, DOCUMENTS, CORRESPONDENCE, TEST RESULTS, STATEMENTS, QUESTIONNAIRES/HISTORIES, AND RECORDS RECEIVED FROM OTHER PHYSICIANS. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. RT: 267737.5 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DANIELLE M. GEORGE V. ERIE INSURANCE EXCHANGE File No:14-2571 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: 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 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested. by this subpoena together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought If you fail to produce the documents or things required by this subpoena within twenty (20) days afte: its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RecordTrak, JOHN STATLER Address: 651 Allendale Road King of Prussia PA 19406 Telephone: f 800) 220-1291 BY THE COURT: Supreme Court ID# Attorney for: Defendant i:':i*.t:e:(:� �u�_ -� Prothonotary ' DATE: Seal of the Court 14) i) S RE: DANIELLE M. GEORGE vs. ERIE INSURANCE EXCHANGE CASE NO. 14-2571 RECORDTRAK FILE #: 267737; TAG 5 LOCATION: CHAMBERSBURG HOSPITAL (RAD) RECORDS PERTAIN TO: DANIELLE M. GEORGE SS #: , DOB: X . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS FROM XX/XX/XXXX TO PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING. * * RT: 267737.6 (0 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DANIELLE M. GEORGE V. ERIE INSURANCE EXCHANGE File No:14-2571 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: ORTHOPEDIC INSTITUTE OF PENNSYLVANIA (Name of Person or Endty) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoena together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RecordTrak, JOHN STATLER Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 220-1291 BY THE COURT: Supreme Court ID# Attorney for: Defendant DATE: Seal of the Court 1 . ateiL Prothonotary RE: DANIELLE M. GEORGE vs. ERIE INSURANCE EXCHANGE CASE NO. 14-2571 RECORDTRAK FILE #: 267737; TAG 6 LOCATION: ORTHOPEDIC INSTITUTE OF PENNSYLVANIA RECORDS PERTAIN TO: DANIELLE M. GEORGE SS #: , DOB: X . ALL MEDICAL RECORDS DATED XX/XX/XXXX AND ALSO XX/XX/XXXX TO PRESENT. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PATIENTS INFORMATION SHEET. X . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS FROM XX/XX/XXXX TO PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING.** RT: 267737.8 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DANIELLE M. GEORGE V. ERIE INSURANCE EXCHANGE File No:14-2571 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CARLISLE REGIONAL MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoeni together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought If you fail to produce the documents or things required by this subpoena within twenty (20) days afte its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RecordTrak, JOHN STATLER Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 220-1291 Supreme Court ID# Attorney for: Defendant DATE: BY THE COURT: Seal of the Court RE: DANIELLE M. GEORGE vs. ERIE INSURANCE EXCHANGE CASE NO. 14-2571 RECORDTRAK FILE #: 267737; TAG 8 LOCATION: CARLISLE REGIONAL MEDICAL CENTER (RAD) RECORDS PERTAIN TO: DANIELLE M. GEORGE SS #: , DOB: X . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS FOR DATES OF SERVICE XX/XX/XXXX TO PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING.** RT: 267737.9 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DANIELLE M. GEORGE V. ERIE INSURANCE EXCHANGE File No: 14-2571 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: WALNUT BOTTOM RADIOLOGY (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or procluce things requested by this subpoeni together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought, If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE ;FOLLOWING PERSON: Name: RecordTrak, JOHN STATLER Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 220-1291 Supreme Court ID# Attorney for: Defendant DATE: BY THE COURT: Prothonotary Seal of the Court RE: DANIELLE M. GEORGE vs. ERIE INSURANCE EXCHANGE CASE NO. 14-2571 RECORDTRAK FILE #: 267737; TAG 9 LOCATION: WALNUT BOTTOM RADIOLOGY RECORDS PERTAIN TO: DANIELLE M. GEORGE SS #: , DOB: X . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS FROM XX/XX/XXXX TO PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING.** RT: 267737.10 /0 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DANIELLE M. GEORGE V. ERIE INSURANCE EXCHANGE File No:14-2571 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.2 TO: PENN STATE MILTON S. HERSHEY MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoena together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or produdng the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days afte its service, the party serving this subpoena may seek a court order compelling you to comply with it, THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RecordTrak, JOHN STATLER Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 220-1291 Supreme Court ID# Attorney for; Defendant DATE: BY THE COURT: Prothonotary eal of the Court RE: DANIELLE M. GEORGE vs. ERIE INSURANCE EXCHANGE CASE NO. 14-2571 RECORDTRAK FILE #: 267737; TAG 10 LOCATION: PENN STATE MILTON S. HERSHEY MEDICAL CENTER (MED) RECORDS PERTAIN TO: DANIELLE M. GEORGE SS #: , DOB: X . MEDICAL RECORDS DATED XX/XX/XXXX TO PRESENT. INCLUDE INPA I LENT, OUTPAI'IhNT AND EMERGENCY ROOM TREATMENT, ALL CLINICAL CHARTS, REPORTS, CONSULTATIONS, DOCUMENTS, CORRESPONDENCE, TEST RESULTS, STATEMENTS, QUESTIONNAIRES/HISTORIES, NEUROLOGY AND NEUROSURGERY RECORDS, AND RECORDS RECEIVED FROM OTHER PHYSICIANS. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. RT: 267737.11 l0 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DANIELLE M. GEORGE v. ERIE INSURANCE EXCHANGE File No: 14-2571 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: PENN STATE MILTON S. HERSHEY MEDICAL CENTER e of Person or Endty) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoena together with the certificate of compliance, to the party malting this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought, If you fail to produce the documents or things required by this subpoena within twenty (20) days afte its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RecordTrak, JOHN STATLER Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (SOf) 220-1291 BY THE COURT: Supreme Court ID# Attorney for: Defendant DATE: Seal of the Court r t Prothonotary �a� f RE: DANIELLE M. GEORGE vs. ERIE INSURANCE EXCHANGE CASE NO. 14-2571 RECORDTRAK FILE #: 267737; TAG 11 LOCATION: PENN STATE MILTON S. HERSHEY MEDICAL CENTER (RAD) RECORDS PERTAIN TO: DANIELLE M. GEORGE SS #: , DOB: X . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS FROM XX/XX/XXXX TO PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING. * * RT: 267737.12 rte COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DANIELLE M. GEORGE V. ERIE INSURANCE EXCHANGE File No: 14-2571 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUMBERLAND VALLEY NEUROSURGICAL CONSULTANTS (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoena together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RecordTrak, JOHN STATLER Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 220-1291 BY THE COURT: Supreme Court ID# Attorney for: Defendant DATE: Seal of the Court /iitj L+'411 v h if Prothonotary RE: DANIELLE M. GEORGE vs. ERIE INSURANCE EXCHANGE CASE NO. 14-2571 RECORDTRAK FILE #: 267737; TAG 12 LOCATION: CUMBERLAND VALLEY NEUROSURGICAL CONSULTANTS RECORDS PERTAIN TO: DANIELLE M. GEORGE SS #: , DOB: X . ALL MEDICAL RECORDS DATED XX/XX/XXXX TO PRESENT ONLY. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PATIENTS INFORMATION SHEET. RT: 267737.13 13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DANIELLE M. GEORGE V. ERIE INSURANCE EXCHANGE File No: 14-2571 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: SADLER HEALTH CENTER. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoena together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RccordTrak, JOHN STATLER Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 229-1291 Supreme Court ID# Attorney for: Defendant DATE: BY THE COURT: Seal of the Court RE: DANIELLE M. GEORGE vs. ERIE INSURANCE EXCHANGE CASE NO. 14-2571 RECORDTRAK FILE #: 267737; TAG 13 LOCATION: SADLER HEALTH CENTER RECORDS PERTAIN TO: DANIELLE M. GEORGE SS #: , DOB: X . ALL MEDICAL RECORDS DATED XX/XX/XXXX TO PRESENT. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PAIILNTS INFORMATION SHEET. RT: 267737.14 If COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DANIELLE M. GEORGE V. ERIE INSURANCE EXCHANGE File No: 14-2571 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCQVERY PURSUANT TO RULE 4009.22 TO: GRAHAM MEDICAL CLINIC (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoena together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek to advance the reasonable cost of preparing copies or producing the things sought, If you fail to produce the documents or things required by this subpoena within twenty (20) days afte its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RecordTrak, JOHN STATLER Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 220-1291 BY THE COURT: Supreme Court Mg Attorney for: Defendant DATE: Seal of the Court (is 14 RE: DANIELLE M. GEORGE vs. ERIE INSURANCE EXCHANGE CASE NO. 14-2571 RECORDTRAK FILE #: 267737; TAG 14 LOCATION: GRAHAM MEDICAL CLINIC RECORDS PERTAIN TO: DANIELLE M. GEORGE SS #: , DOB: X . ALL MEDICAL RECORDS DATED XX/XX/XXXX TO XX/XX/XXXX AND XX/XX/XXXX TO PRESENT. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PAIIENTS INFORMATION SHEET. CERTIFICATE 2°1/ AUG IS + i. 03 CLIMBERLAND COU PREREQUISITE TO SERVICE OF A SUBPOI NhWS Y( VANIA-T Y PURSUANT TO RULE 4009.22 IN THE MATTER OF: Court of Common Pleas - Cumberland County, PA DANIELLE M. GEORGE vs. TERM: ERIE INSURANCE EXCHANGE CASE No: 14-2571 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22. RecordTrak on behalf of JOHN STATLER Defendant certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) No objection to the subpoena has been received or it has been waived, and (3) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. Date : 08/13/2014 RecordTrak on behalf of /S/ JOHN STATLER Attorney for Defendant RT#: 267737 RECORDS PERTAIN TO: DANIELLE M. GEORGE DANIELLE M. GEORGE : COURT: Court Of Common Pleas - Cumberland County, Pa vs. TERM: ERIE INSURANCE EXCHANGE : DOCKET: 14-2571 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS TO: MICHAEL KOSIK SCHMIDT KRAMER, PC 209 STATE ST HARRISBURG, PA 17101 (717) 232-6467 August 4, 2014 Please take notice that on behalf of JOHN STATLER, attorney for Defendant, RecordTrak intends to serve a subpoena identical to the one(s) attached to this notice. You have until August 25, 2014 to file of record and serve upon the undersigned an objection to the subpoena(s). If no objection is made, the subpoena(s) will be served. IF COUNSEL AGREES TO WAIVE THE 20 DAY NOTICE PERIOD, PLEASE INDICATE BELOW AND FAX SAME TO THE UNDERSIGNED AT YOUR EARLIEST OPPORTUNITY. IF YOU WISH TO PURCHASE COPIES OF THE RECORDS, PLEASE CONTACT RECORDTRAK FOR PRICING AND FAX THIS CORRESPONDENCE BY August 25, 2014 TO (610) 992-1405. All records will be provided (including no record statements) as produced by each record location. Daniel Wake 610.354.8348 RECORDTRAK 651 Allendale Road P. O. Box 61591 King of Prussia, PA 19406 LIST OF RECORD CUSTODIANS AND SUBPOENAS TAG RECORD CUSTODIAN 15 CARLISLE REGIONAL MEDICAL CENTER (MED) 16 CARLISLE DIGESTIVE DISEASE ASSOCIATES 17 CARLISLE UROLOGY 18 CARLISLE REGIONAL MEDICAL CENTER (RAD) Yes, I would like a copy of all of the records listed above. Yes, I would like specific records I have indicated above. SIGNATURE: FIRM: Date: YES, I AGREE TO WAIVE THE 20 DAY NOTICE PERIOD FOR ALL SUBPOENAS ON THIS NOTICE Signature of Plaintiff's Counsel: Date: FIRM: EMAIL: DANIELLE M. GEORGE COURT: Court Of Common Pleas - Cumberland County, Pa vs. TERM: ERIE INSURANCE EXCHANGE DOCKET: 14-2571 Page 2 RT: 267737.15 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DANIELLE M. GEORGE V. ERIE INSURANCE EXCHANGE File No: 14-2571 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CARLISLE REGIONAL MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoena together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought, If you fail to produce the documents or things required by this subpoena within twenty (20) days afte: its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RecordTrak, JOHN STATLER Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800122\Q� .. BY THE COURT: Supreme Court II1,V,_L Attorney for: Deter DATE: r' Seal of the Court Prothonotary 11.5- Prothonotary S RE: DANIELLE M. GEORGE vs. ERIE INSURANCE EXCHANGE CASE NO. 14-2571 RECORDTRAK FILE #: 267737; TAG 15 LOCATION: CARLISLE REGIONAL MEDICAL CENTER (MED) RECORDS PERTAIN TO: DANIELLE M. GEORGE SS #: , DOB: X . ALL MEDICAL RECORDS DATED XX/XX/XXXX TO XX/XX/XXXX ONLY. INCLUDE INPATIENT, OUTPATIENT AND EMERGENCY ROOM TREATMENT, ALL CLINICAL CHARTS, REPORTS, DOCUMENTS, CORRESPONDENCE, TEST RESULTS, STATEMENTS, QUESTIONNAJRES/HISTORIES, AND RECORDS RECEIVED FROM OTHER PHYSICIANS. RT: 267737.16 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DANIELLE M. GEORGE v. ERIE INSURANCE EXCHANGE i File No:14-2571 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CARLISLE DIGESTIVE DISEASE ASSOCIATES (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoena together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RecordTrak, JOHN STATLER Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 220-12,2.I • - Supreme Court ID# 'tie--- _ -- Attorney for: Defeutit— i. `^ ti-� ^-'- „- .;.ANS! DATE: ••✓ Seal of the Court '• • • ` `..1 • BY THE COURT: /'1. RE: DANIELLE M. GEORGE vs. ERIE INSURANCE EXCHANGE CASE NO. 14-2571 RECORDTRAK FILE #: 267737; TAG 16 LOCATION: CARLISLE DIGESTIVE DISEASE ASSOCIATES RECORDS PERTAIN TO: DANIELLE M. GEORGE SS #: , DOB: X . ALL MEDICAL RECORDS DATED XX/XX/XXXX TO PRESENT. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, RADIOLOGY FILMS/CD'S AND REPORTS, CORRESPONDENCE, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PAIThNTS INFORMATION SHEET. RT: 267737.17 17 - COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DANIELLE M. GEORGE V. ERIE INSURANCE EXCHANGE File No: 14-2571 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CARLISLE UROLOGY (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mall legible copies of the documents or produce things requested by this subpoena together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought, If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RecordTrak, JOHN STATLER Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 220-129) . . Supreme Court ID# .. rrr Attorney for: Defend r•� ^'.` [ DATE: '- �• • BY THE COURT: Prothonotary Seal of the Court RE: DANIELLE M. GEORGE vs. ERIE INSURANCE EXCHANGE CASE NO. 14-2571 RECORDTRAK FILE #: 267737; TAG 17 LOCATION: CARLISLE UROLOGY RECORDS PERTAIN TO: DANIELLE M. GEORGE SS #: , DOB: X . ALL MEDICAL RECORDS DATED XX/XX/XXXX TO PRESENT. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, RADIOLOGY FILMS/CD'S & REPORTS, CORRESPONDENCE, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PATIENTS INFORMATION SHEET. RT: 267737.18 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DANIELLE M. GEORGE V. ERIE INSURANCE EXCHANGE File No: 14-2571 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CARLISLE REGIONAL MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoen: together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought If you fail to produce the documents or things required by this subpoena within twenty (20) days afte: its service, the party serving this subpoena may seek a court order compelling you to comply with IL THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RecordTrak, JOHN STATLER Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) Supreme Court ID '\`'; �- Attorney for: ike4'aii - �;• \ ItT` DATE: BY THE COURT: 1.„.d." :Lae_ is • Seal of the Court RE: DANIELLE M. GEORGE vs. ERIE INSURANCE EXCHANGE CASE NO. 14-2571 RECOROTRAK FILE #: 267737; TAG 18 LOCATION: CARLISLE REGIONAL MEDICAL CENTER (RAD) RECORDS PERTAIN TO: DANIELLE M. GEORGE SS #: , DOB: 1. RADIOLOGY FILMS/CD'S AND REPORTS FROM XX/X1/XXXX TO 1X/XX/XXXX ONLY - **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING.**