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HomeMy WebLinkAbout14-2818 8 n Supreme Co» {o : ?ennsylvania Cout' . -mom O x Pleas For Prothonotary Use Only: C Yil 'OYeI'tsll Docket No: E o, y c .�er a�tr d �- County The information collected on this form is used solely for court administration purposes. This farm does not supplement or replace the filing and service ofpleadings or other papers as required by lav or rules of court. Commencement of Action: S 1 Complaint 0 Writ of Summons Petition Transfer from Another Jurisdiction Q Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: Sara Jane Crognale Stephen G. Matusheski Dollar Amount Requested: Owithin arbitration limits I Are money damages requested? El Yes 0 No (check one) Qoutside arbitration limits O N Is this a Class Action Suit? ri-11 Yes l0 No Is this an MDJAppeal? 0 Yes El No A Name of Plaintiff/Appellant's Attorney: Charles E. Schmidt,Jr., Schmidt Kramer PC Check here if you have no attorney(area Self-Represented jPro Sel 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 E3 Intentional ( Buyer Plaintiff Administrative Agencies rq Malicious Prosecution ll Debt Collection:Credit Card [3 Board of Assessment x Motor Vehicle F-7 Debt Collection:Other Q Board of Elections Nuisance I_° Dept.of Transportation Premises Liability Statutory Appeal:Other S Product Liability (does not include mass tart) (] Employment Dispute: Discrimination Slander/Libel/Defamation COther: ( Employment Dispute:Other Zoning Board ,r ll Other: [3 Other: O MASS TORT 0 Asbestos N [3 Tobacco l Toxic Tort-DES Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS 0 Toxic Waste El Ejectment El Common Law/Statutory Arbitration B Other: Eminent Domain/Condemnation 0 Declaratory Judgment Q Ground Rent 171 Mandamus J Landlord/Tenant Dispute Non-Domestic Relations M Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY -i Mortgage Foreclosure:Commercial rl Quo Warranto Q Dental El Partition Replevin Q Legal l] Quiet Title 0 Other: Medical Other: Other Professional: Updated 1/1/2011 SCHMIDT KRAMER PC r, '` fH BY: Charles E. Schmidt, Jr., ESQUIREi/ I.D. #19198 '��: 209 State Street Pr- (717) Harrisburg, PA 17101 r- t (717) 232-6300 AAYA4yA for Plaintiff(s) cschmidt(&schmidtkramer com SARA JANE CROGNALE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff `V. No. d v STEPHEN G. MATUSHESKI CIVIL ACTION - LAW 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. 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 S Carlisle, PA 17013 (717) 249-3166 a , 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 despu6s 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 mas 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 C . SCHMIDT KRAMER PC BY: Charles E. Schmidt, Jr., ESQUIRE I.D. #19198 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorneys for Plaintiff(s) cschmidt(a),schmidtkramer com SARA JANE CROGNALE : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. No. STEPHEN G. MATUSHESKI CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED COMPLAINT AND NOW, comes Plaintiff, Sara Jane Crognale, by and through her attorneys, Schmidt Kramer PC, hereby aver the following: 1. Plaintiff, Sara Jane Crognale, is an adult individual residing in Enola, Cumberland County, Pennsylvania. 2. Defendant, Stephen G. Matusheski, is an adult individual residing at 1903 Beckley Drive, New Cumberland, Cumberland County, Pennsylvania 17070. 3. On July 16, 2012, Defendant rear-ended Plaintiff while she was stopped at the red light at the intersection of Lowther Street and Third Street in Lemoyne, Cumberland County, Pennsylvania. 4. As a result of the impact, Plaintiff suffered significant injuries to her neck and upper spine. 5. As a result of the accident, Plaintiff had to undergo a cervical fusion of four vertebrae and required significant rehabilitation following her major neck surgery. 6. As a direct result of the accident, Plaintiff incurred the following damages: a. Medical bills in excess to her PIP coverage; 1 b. Past and future pain and suffering; C. Permanent disability and loss of the rotation and function of her cervical spine; d. Scaring; e. Loss of life's pleasures; f. All legal damages permitted by the Pennsylvania Motor Vehicle Financial Responsibility Act and the Common Law applicable to a motor vehicle accident in the Commonwealth of Pennsylvania. 7. The Defendant is liable to Plaintiff for the injuries which resulted from the accident of July 16, 2012 which were legally caused by Defendant's negligence as follows: a. Running into the rear of a stopped vehicle; b. Failing to observe the road before him; C. Driving too fast for conditions; d. Failing to maintain lookout for other vehicles on the highway; e. Failing to stop his vehicle within the assured clear distance ahead; f. Not paying attention to where he was going; A g. Failing to take any evasive action to avoid hitting a plainly observed vehicle ahead of him; h. Following too closely; i. Violating provisions of the Pennsylvania Vehicle Code including Section 3714; j. Failing to operate his vehicle in a reasonable fashion under the circumstances present at the time of the accident. WHEREFORE, Plaintiffs demand judgment against the Defendants in excess of the compulsory arbitration limits of Cumberland County. Respectfully submitted, SC I T KRAMER PC ��� By.. Charles E. Schmidt, Jr., Esquire Attorney I.D. #19198 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorneys for Plaintiff i VERIFICATION BASED UPON PERSONAL KNOWLEDGE AND INFORMATION OBTAINED THROUGH COUNSEL I, Sara Jane Crognale, 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: Sara Jane ognale PENNS Y�°'� CC�J ✓ti fd1A JOHNSON, DUFFIE, STEWART & WEIDNER By: Wade D. Manley, Esquire I.D. No. 87244 301 Market Street P. 0. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 wdm@jdsw.com Attorneys for Defendant SARA JANE CROGNALE, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 14-2818 Civil v. CIVIL ACTION — LAW STEPHEN G. MATUSHESKI, JURY TRIAL DEMANDED Defendant PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of the undersigned on behalf of the Defendant in the above -captioned matter. Date: May 20 , 2014 624894 Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER itliTaxt(41 Wade D. Manley, Esquire Attorney I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant By: CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Praecipe for Entry of Appearance has been duly served upon the following counsel of record, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on May ZD , 2014: Charles E. Schmidt, Jr., Esquire Schmidt Kramer PC 209 State Street Harrisburg, PA 17101 JOHNSON, DUFFIE, STEWART & WEIDNER By: wig Wade D. Manley, squire Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY PRO . H 4 MAY 28 PM 2: 57 CUMBERLAND COUNT': PENNSYLVANIA Sarah J. Crognale vs. Stephen Matusheski Case Number 2014 -2818 SHERIFF'S RETURN OF SERVICE 05/13/2014 05:59 PM - Deputy Ronald Hoover, being duly sworn according to law, served the requested Complaint & Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Stephen Matusheski at 1903 Beckley Drive, New Cumberland Borough, New Cumberland, PA 17070. RONALD HOOVER, DEPUTY SHERIFF COST: $47.21 SO ANSWERS, May 14, 2014 ROOR ANDERSON, SHERIFF • {HMO i r-t T: ?r3 ', J€IN 23 PM 12: 3 CUMBERLAND COUNTY PENNSYLVANIA JOHNSON,DUFFIE,STEWART&WEIDNER Attorneys for Defendant By: Wade D. Manley, Esquire I.D. No. 87244 301 Market Street P. 0. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 wdm@jdsw.com SARA JANE CROGNALE, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : NO. 14-2818 Civil • v. : CIVIL ACTION — LAW STEPHEN G. MATUSHESKI, • : JURY TRIAL DEMANDED Defendant • NOTICE TO PLEAD To: SARA JANE CROGNALE, Plaintiff do Charles E. Schmidt, Jr., Esquire Schmidt Kramer PC 209 State Street Harrisburg, PA 17101 You are hereby notified to file a written response to the enclosed Answer with New Matter within twenty (20) days from service hereof or a judgment may be entered against you. JOHNSON, DUFFIE, STEWART &WEIDNER By: NalG Wade D. Manley, Ekquire Attorney I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 DATE: June ' , 2014 Attorneys for Defendant, Stephen G. Matusheski JOHNSON,DUFFIE,STEWART&WEIDNER Attorneys for Defendant, By: Wade D. Manley, Esquire Jamie Forrey I.D. No. 87244 301 Market Street P. 0. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 wdm@jdsw.com SARA JANE CROGNALE, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : NO. 14-2818 Civil • v. : CIVIL ACTION — LAW STEPHEN G. MATUSHESKI, • : JURY TRIAL DEMANDED Defendant • DEFENDANT'S ANSWER WITH NEW MATTER TO PLAINTIFF'S COMPLAINT AND NOW, comes the Defendant, Stephen G. Matusheski, by and through his attorneys, Johnson, Duffie, Stewart & Weidner, P.C., and files the following Answer with New matter to the Plaintiff's Complaint, and in support thereof avers as follows: 1. DENIED. After reasonable investigation, the Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in this paragraph. 2. ADMITTED. 3. ADMITTED IN PART; DENIED IN PART. It is admitted that on the date set forth an accident occurred near the intersection identified. The remainder of the averments are denied and strict proof thereof is demanded. 2 .i' 4. DENIED. The averments contained in this paragraph are conclusions of law to which no response is required. If it is deemed that a response is required, the averments contained in this paragraph are specifically denied and strict proof thereof is demanded. 5. DENIED. The averments contained in this paragraph are conclusions of law to which no response is required. If it is deemed that a response is required, the averments contained in this paragraph are specifically denied and strict proof thereof is demanded. 6. DENIED. The averments contained in this paragraph are conclusions of law to which no response is required. If it is deemed that a response is required, the averments contained in this paragraph are specifically denied and strict proof thereof is demanded. By way of further answer, the parties have entered into a stipulation striking the allegations contained in paragraph 6(f). 7. DENIED. The averments contained in this paragraph are conclusions of law to which no response is required. If it is deemed that a response is required, the averments contained in this paragraph are specifically denied and strict proof thereof is demanded. By way of further answer, the parties have entered into a stipulation striking the allegations contained in paragraph 7(i) and (j). WHEREFORE, the Defendant, Stephen G. Matusheski, respectfully requests that judgment be entered in his favor and that Plaintiff's Complaint be dismissed with prejudice. 3 • NEW MATTER By way of additional answer and reply, the Defendant, Stephen G. Matusheski, raises the following New Matter: 8. Some or all of Plaintiff's claims are barred by the applicable statute of limitations. 9. Some or all of 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. 10. Discovery may reveal that the Plaintiff may have failed to mitigate her damages. 11. Discovery may reveal that some or all of the Plaintiff's alleged injuries, conditions or damages preexisted the date of the alleged accident and were not caused or aggravated by this accident. 12. Discovery may reveal that some or all of the Plaintiff's alleged injuries, conditions or damages were caused by the events that occurred subsequent to the accident. 13. To the extent that Plaintiff has been or will be paid some or all of her damages, then the claims for those damages are barred both by §1722 of the Pennsylvania Motor Vehicle Financial Responsibility Law and by the defense of payment generally. 14. The Plaintiff has failed to state a causes of action upon which any relief of any kind can be granted. 15. The Plaintiff's alleged causes of action are barred in whole or in part by the doctrines of comparative negligence and/or contributory negligence, as may be applied to the facts disclosed in discovery. 16. The mechanism of the Plaintiff's alleged injuries were under the care, custody and control of persons or entities other than the answering Defendant. 4 17. The mechanism of the Plaintiff's alleged injuries were under the care, custody and control of persons or entities other than the answering Defendant, such as persons including, but not limited to, the Plaintiff. 18. The alleged damages claimed by the Plaintiff were created and/or caused by individuals under circumstances over whom answering Defendant had no control or right to control. 19. Sudden and unexpected conditions at the time of the accident may have created an emergency for drivers on the roadway, including answering Defendant. WHEREFORE, the Defendant, Stephen G. Matusheski, respectfully demands judgment in his favor and requests that Plaintiff's Complaint be dismissed with prejudice and that judgment be entered in Defendant's favor. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER By: W GM C Wade D. Manley, squire Attorney I.D. No. 244 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Date: June , 2014 Attorneys for Defendant, Stephen G. Matusheski 5 VERIFICATION I, STEPHEN G. MATUSHESKI, hereby acknowledge that I am a Defendant in this action; that I have read the foregoing Defendant's Answer with New Matter to Plaintiff's Complaint; 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. STEPHEN G. MATUSHESKI DATE: 6/X//� CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing document has been duly served upon the following counsel of record, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on June , 2014: Charles E. Schmidt, Jr., Esquire Schmidt Kramer PC 209 State Street Harrisburg, PA 17101 JOHNSON, DUFFIE, STEWART & WEIDNER /0)/V4A4 By: Wade D..Manley, squire SCHMIDT KRAMER PC BY: Charles E. Schmidt,Jr.,ESQUIRE I.D. #1919$ 209 State Street Harrisburg,PA 17101 (717)232-6300 !3'ktt'h� eys for Plaintiff() cschmid schmidtkramer.com t'liii A,,' J - bb; �{ SARA JANE CROGNALE : IN THE COUk t` #/t6MMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. No. 14-2818 Civil STEPHEN G. MATUSHESKI CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED PLAINTIFF'S ANSWER TO DEFENDANT'S NEW MATTER 8 - 19. The allegations herein attempt to raise affirmative defense by stating conclusions of law, rather than the material facts upon which the defenses are based. In so doing, they violate the Pa. rules of pleading an affirmative defense, and are insufficient as a matter of law to raise the asserted defenses. As conclusions of law they require no response. To the extent these allegation raise a factual contention, they are denied pursuant to Pa.R.C.P 1029(e). WHEREFORE, Plaintiffs demand judgment against the Defendants in excess of the compulsory arbitration limits of Cumberland County. Respectfully submitted, SCHMIDT KRAMER PC By: TerZS. an, Esquire Attorne D. #36807 209 S e Street Harri burg, PA 17101 (717) 232-6300 Attorneys for Plaintiff CERTIFICATE OF SERVICE rA AND NOW, this'5 day of 2014, I, Terry S. Hyman, Esquire, counsel for the Plaintiff, hereby certify that I have, this day, served a copy of Plaintiff's Answer to Defendant's New Matter by serving a copy of the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Wade D. Manley, Esquire Johnson Duffle P.O. Box 109 301 Market Street Lemoyne, PA 17043-0109 Respectfully submitted, SCHMIDT KRAMER PC By: Te S ym I.D.# 6807 20 S treet Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiff ff CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 PROTH 2i0i5JAN -2 AM11:3 ? CUMBERLAND COUNTY Y PENNSYLVANIA IN THE MATTER OF: Court of Common Pleas - Cumberland County, PA SARA JANE CROGNALE vs. TERM: STEPHEN G. MATUSHESKI CASE No: 14-2818 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22. RecordTrak on behalf of WADE MANLEY 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 : 12/30/2014 RecordTrak on behalf of /S/ WADE MANLEY Attorney for Defendant RT#: 273220 RECORDS PERTAIN TO: SARA J. CROGNALE SARA JANE CROGNALE COURT: Court Of Common Pleas - Cumberland County, Pa vs. TERM: STEPHEN G. MATUSHESKI : DOCKET: 14-2818 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS TO: CHARLES SCHMIDT SCHMIDT KRAMER, PC 209 STATE ST HARRISBURG, PA 17101 (717) 232-6467 December 9, 2014 Please take notice that on behalf of WADE MANLEY, attorney for Defendant, RecordTrak intends to serve a subpoena identical to the one(s) attached to this notice. You have until December 29, 2014 to file of record and serve upon the undersigned an objection to the subpoena(s). If no objection is made, the subpoena(s) will be served. IF 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 December 29, 2014 TO (610) 992-1405. All records will be provided (including no record statements) as produced by each record location. Daniel Wake 610.354.8348 RECORDTRAK 651 Allendale Road P. O. Box 61591 King of Prussia, PA 19406 LIST OF RECORD CUSTODIANS AND SUBPOENAS TAG RECORD CUSTODIAN 8 PENN STATE MILTON S. HERSHEY MEDICAL CENTER (MED) 9 AT&T Yes, I would like a copy of all of the records listed above. Yes, I would like specific records I have indicated above. SIGNATURE: Date: FIRM: YES, I AGREE TO WAIVE THE 20 DAY NOTICE PERIOD FOR ALL SUBPOENAS ON THIS NOTICE Signature of Plaintiffs Counsel: Date: FIRM: EMAIL: RT: 273220.8 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SARA JANE CROGNALE V. STEPHEN G. MATUSHESKI File No:14-2818 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: PENN STATE MILTON S. HERSHEY MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoena together with the certificate of compliance, to the party making this request at the address Listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RecordTrak, WADE MANLEY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 220-1291 Supreme Court ID# Attorney for: Defendant DATE: Seal of the Court Pi BY THE COURT: RE: SARA JANE CROGNALE vs. STEPHEN G. MATUSHESKI CASE NO. 14-2818 RECORDTRAK FILE #: 273220; TAG 8 LOCATION: PENN STATE MILTON S. HERSHEY MEDICAL CENTER (MED) RECORDS PERTAIN TO: SARA J. CROGNALE SS #: , DOB: X . COPIES OF ANY AND ALL MEDICAL RECORDS (FOR XX/XX/XX TO THE PRESENT), INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, OFFICE NOTES, PHYSICAL THERAPY RECORDS, CORRESPONDENCE, X-RAY REPORTS , MRI REPORTS, CT REPORTS , HOSPITAL RECORDS, ANY AND ALL RECORDS FROM CLINICS OR DEPARTMENTS OR OTHER OFFICE LOCATIONS OF THE REQUESTED PROVIDER PERTAINING TO ANY EVALUATION, CARE OR TREATMENT RENDERED TO: SARA JANE CROGNALE. RT: 273220.9 t COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SARA JANE CROONALE V. STEPHEN G. MATUSHESKI File No:14-2818 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: AT&T (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoen: together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought, If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: RecordTrak, WADE MANLEY Address: 651. Allendale Road King of Prussia PA 19406 Telephone: (800)220-1291 Supreme Court 1D# Attorney for: Defendant DATE: Seal of the Court P// s/41 BY THE COURT: RE: SARA JANE CROGNALE vs. STEPHEN G. MATUSHESKI CASE NO. 14-2818 RECORDTRAK FILE #: 273220; TAG 9 LOCATION: AT&T RECORDS PERTAIN TO: SARA J. CROGNALE SS #: , DOB: X . PLEASE PROVIDE CERIIUIED COPIES OF ALL RECORDS PERTAINING TO CELLULAR PHONE NUMBER (XXX) XXX-XXXX FOR THE TIME PERIOD OF JULY XX, XXXX, XX:XX AM EST TO JULY XX, XXXX, XX:XX AM EST, TO INCLUDE: (A)NAMES AND ADDRESSES OF SUBSCRIBERS (B)ANY AND ALL INCOMING PHONE CALLS, WITH TIME OF CALLS AND DURATION (C)ANY AND ALL OUTGOING PHONE CALLS, WITH TIME OF CALLS AND DURATION (D)RECORDS OF ANY AND ALL INCOMING TEXT MESSAGES (NO CONTENT) INCLUDING TIME OF TEXT MESSAGE (E)RECORDS OF ANY AND ALL OUTGOING TEXT MESSAGES (NO CONTENT) INCLUDING TIME OF TEXT MESSAGE (F)RECORD OF ANY ACCESS TO INTERNET INCLUDING TIME AND DURATION.