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HomeMy WebLinkAbout14-6110 ti Supreme Co nnsylvania COU f,. Com moPleas For Prothonotary Use Only: C 1: 7 ojV$'I' t Docket No: Cu y rland ` County 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 El Complaint ❑ Writ of Summons ❑ Petition E C] Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiff's Name: Lead Defendant's Name: T Jami Felton Nicole Trimmer Dollar Amount Requested: ❑within arbitration limits I Are money damages requested? Yes El No O (check one) ❑x outside arbitration limits N Is this a Class Action Suit? ❑ Yes El No Is this an MDJAppeal? ❑ Yes F1 No A Name of Plaintiff /Appellant's Attorney: Ronald M. Graham, Esquire ❑ Check here if you have no attorney (are a Self- Represented [Pro Sel Litigant) TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑x Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections Nuisance Dept. of Transportation Premises Liability 8 Statutory Appeal: Other S ❑ Product Liability (does not include E mass tort) ❑ Employment Dispute: Slander/Libel/ Defamation Discrimination C ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board T ❑ Other: I ❑ Other: O MASS TORT Asbestos N ❑ Tobacco Toxic Tort - DES ❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste Other: ❑ Ejectment ❑ Common Law /Statutory Arbitration B ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment ❑ Ground Rent Mandamus ❑ Landlord /Tenant Dispute Non - Domestic Relations ❑ Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin Legal ❑ Quiet Title ❑ Other: ❑ Medical © Other: ❑ Other Professional: Updated 1/1/2011 GRAHAM & MAUER, P.C. Attorney for Plaintiff By: Ronald M. Graham, Es4 Y ID #64483 By: Whitney S. Graham, EsquYxe' ID # 312145 The Commons At Valley Forge Suite 7, P.O. Box 987 Valley Forge, PA 19482 (610)933 -3333 JAMI FELTON : IN THE CUMBERLAND COUNTY 205 East High Street, Apt. B : COURT OF COMMON PLEAS Carlisle, PA 17013 Plaintiff • V. : No.. NICOLE TRIMMER : CIVIL ACTION 126 Darr Avenue Carlisle, PA 17013 and KELLI MURPHY - GODFREY 242 Webster Street Carlisle, PA 17013 Defendants COMPLAINT 1. At all times pertinent hereto, Plaintiff Jami Felton was an adult individual residing at 205 East High Street, Apt. B, Carlisle, Pennsylvania. 2. On information and belief, at all times pertinent hereto, Nicole Trimmer was an adult individual residing at 126 Darr Avenue, Carlisle, Pennsylvania. 3. On information and belief, at all times pertinent hereto, Kelli Murphy - Godfrey was an adult individual residing at 242 Webster Street in Carlisle, Pennsylvania. GRAHAM 4. On or about March 14, 2014, at or about 1:20 p.m., Plaintiff Jami Felton, S & MAUER, P. C, I' L log; )< 3/93,5 hereinafter "Plaintiff Felton," was operating a Dodge Intrepid traveling southbound on South Hanover Street in the left traffic lane in the vicinity of Alliance Drive in Carlisle, Pennsylvania. 5. At said time and place, Defendant Nicole Trimmer, hereinafter "Defendant Trimmer," was operating a Hyundai Elantra and was attempting to make an unlawful left turn from Alliance Drive onto northbound South Hanover Street in Carlisle, Pennsylvania. 6. At said time and place, Defendant Kelli Murphy- Godfrey, hereinafter "Defendant Murphy- Godfrey," was stopped in the right hand traffic lane of South Hanover Street facing in a southernly direction. 7. At said time and place, Defendant Murphy- Godfrey motioned Defendant Trimmer to pass in front of Defendant Murphy - Godfrey's car and into the left traffic lane of southbound South Hanover Street directly into the path of Plaintiff Felton. 8. At said time and place, Defendant Trimmer drover her motor vehicle into the left traffic lane of South Hanover Street directly into the path of Plaintiff Felton's moving vehicle. 9. As a result of the sudden appearance of Defendant Trimmer's vehicle in Plaintiff Felton's path of travel, Plaintiff Felton was unable to avoid a collision with Defendant Trimmer's vehicle. 10. As a direct and proximate result of the aforementioned incident, Plaintiff Felton suffered severe and painful injuries including, comminuted fracture of the proximal diaphysis of the right femur resulting in right hip - intramedullary rodding, severe GRAHAM tissue swelling of the right knee, injuries to the cervical spine, pelvis, lumbar spine, and & MAUER, P.C. right hand, contusions and abrasions, as well as damage to her nerves and nervous systems,and muscle and other connective tissue, some or all of which are or may be permanent in nature. 11. As a direct and proximate result of the aforementioned incident and /or the resulting injuries and /or damages, Plaintiff Felton has been in the past and /or may be in the future unable to attend to her ususal habits, customs, vocation, advocation and /or enjoyment of life. 12. As a direct and proximate result of the aforementioned incident and the resulting injuries and /or damages, Plaintiff Felton has been compelled to and/or may be compelled to spend money for medical and surgical aid, medicines and similar medical and medically - related treatments, instrumentalities and modalities. 13. As a direct and proximate result of the aforementioned incident, Plaintiff Felton has suffered and /or may in the future suffer a loss of earnings and /or earning capacity. 14. As a direct and proximate result of the aforementioned incident and the resulting injuries and/or damages, the integrity, resilience, resistence to injury of Plaintiff Felton has been compromised so that Plaintiff Felton is more susceptible to injury and may have earlier onset of degenerative and other problems than Plaintiff Felton would have suffered had the above - mentioned injuries not occurred. 15. As a direct and proximate result of the aforementioned incident and the resulting injuries and /or damages, Plaintiff Felton has suffered and /or suffers and/or will suffer from physical and mental anguish, pain, inconvenience, humiliation and/or GRAHAM scarring. & MAUER, P.C. 16. Plaintiff Felton is entitled to recover damages under the full tort option provided by the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa. C.S.A. Sec. 1701 et seq. COUNT PLAINTIFF JAMI FELTON vs. DEFENDANT NICOLE TRIMMER 17. Paragraphs 1 through 16 are incorporated herein, as if set forth at length herein. 18. The above - mentioned collision was the direct and proximate result of the negligence and /or negligence per se of Defendant Trimmer and not due to any act or failure to act on the part of Plaintiff Jami Felton. 19. The negligence and /or negligence per se of Defendant Trimmer consisted of the following: a. Failing to properly operate and control her motor vehicle; b. Driving at an excessive rate of speed under the circumstances; C. Failing to have her motor vehicle under proper and adequate control at all times; d. Driving her motor vehicle in such a manner as to cause a collision with the motor vehicle driven by Plaintiff Felton; e. Failing to yield the right of way to Plaintiff Felton; f. Violating various statutes and rules of the road pertaining to operation of motor vehicles, including, without limitation, making an unlawful left turn and entering a traveled lane of traffic when it GRAHAM was unsafe to do so; & MAUER, P.C. g. Failing to exercise care and vigilance in the operation of her motor vehicle so as to avoid the collision with Plaintiff Felton; h. Failure to keep a proper look out; i. Failure to remain a safe and clear distance away from traffic having the right of way; j. Failure to stop in time to avoid a collision with Plaintiff Felton's vehicle; k. Failure to control her motor vehicle in a reasonable and prudent fashion; 1. Disregarding the rights, safety and position of motor vehicles lawfully on the public thorofare, including that of Plaintiff Felton; m. Driving into the path of moving traffic when it was unsafe to do so; and n. Negligence per se. WHEREFORE, Plaintiff Jami Felton hereby demands judgment in her favor and against Defendant Nicole Trimmer in an amount which exceeds the jurisdictional limit requiring arbitration referral by local rule and compensatory damages, plus interest, costs and such other remedies as this Court may deem just and proper. COUNT II PLAINTIFF JAMI FELTON vs. DEFENDANT KELLI MURPHY - GODFREY 20. Paragraphs 1 through 19 are incorporated herein, as if set forth at length herein. 21. The above - mentioned collision was the direct and proximate result of the negligence of Defendant Murphy- Godfrey and not due to any act or failure to act on the GRAHAM MAUER, P.C. part of Plaintiff Jami Felton. 22. Defendant Murphy- Godfrey was negligent and careless while operating a motor vehicle at said time and place for the following reasons which include: a. Failure to allow Defendant Nicole Trimmer to make her own observations concerning the advisability of driving into the path of Plaintiff Felton; b. Disregarding the rights, safety and position of vehicles on the highway including the vehicles operated by Defendant Trimmer and Plaintiff Felton; C. Failure to keep a proper lookout; d. Directing Defendant Trimmer that it was safe to proceed in spite of the danger that Defendant Murphy - Godfrey knew or should have known was then present; e. Failure to determine the proximity, direction and speed of the vehicle operated by Plaintiff Felton prior to directing Defendant Trimmer into the path of the vehicle operated by Plaintiff Felton; f. Negligently and carelessly directing Defendant Trimmer to enter the stream of traffic when Defendant Murphy - Godfrey knew or should have known that to do so was unsafe and likely to produce harm to those motorists lawfully proceeding on the highway including Plaintiff Felton; g. Failing to observe the approaching motor vehicle operated by Plaintiff Felton prior to waiving Defendant Trimmer into the path of said motor vehicle; GRAHAM h. Negligently aiding Defendant Trimmer in performing an unsafe & MAUER, P.C. and unlawful left turn into the path of the oncoming motor vehicle operated by Plaintiff Felton. WHEREFORE, Plaintiff Jami Felton hereby demands judgment in her favor and against Defendant Kelli Murphy- Godfrey in an amount which exceeds the jurisdictional limit requiring arbitration referral by local rule and compensatory damages, plus interest, costs and such other remedies as this Court may deem just and proper. GRAHA & MAUER, P.C. By: Ronal/m. Graham, Esquire Date: 13 y Attorney for Plaintiff GRAHAM MAUER, P.C. VERIFICATION I, Jami Felton, hereby state that I am the Plaintiff in this Action and verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that the statements therein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ?J J mi Felton GRAHAM & MAUER, P.C. Attorney for Plaintiff By: Ronald M. Graham, Esquire v " j ID #64483 t € J By: Whitney S. Graham, Esquire; ID #312145 t -_ The Commons At Valley Forge Suite 7, P.O. Box 987 Valley Forge, PA 19482 (610)933 -3333 JAMI FELTON : IN THE CUMBERLAND COUNTY 205 East High Street, Apt. B : COURT OF COMMON PLEAS Carlisle, PA 17013 Plaintiff V. :No.: / //U NICOLE TRIMMER : CIVIL ACTION 126 Darr Avenue Carlisle, PA 17013 and KELLI MURPHY - GODFREY 242 Webster Street Carlisle, PA 17013 Defendants ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of Ronald M. Graham, Esquire, and Whitney S. Graham, Esquire, as counsel for Plaintiff Jami Felton. GRAH &�MAUER,P.C. By: (� Rona . Graham, Esquire Date: /z / Attorney for Plaintiff GRAHAM S MAUER, P.C. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY i iL.t_u-O r IC Cl'. THE PRO T HONG fAi`, 2014OCT 2k PM 3:33 Imbr,1 OFFICE OFTI4-S!4-_RIFF CUMBERLAND COUNTY PENNSYLVANIA Jami L Felton vs. Nicole Trimmer (et al.) Case Number 2014-6110 SHERIFF'S RETURN OF SERVICE 10/17/2014 04:39 PM - Deputy William Cline, 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: Nicole Trimmer at 126 Darr Avenue, North Middleton, Carlisle, PA 1701 L' AM ' INE, DEPUTY 10/17/2014 05:55 PM - Deputy William Cline, being duly sworn according to law, served the requested Complaint & Notice by "personally" handing a true copy to a person representing themsel es to be the Defendant, to wit: Kelli Murphy -Godfrey at 242 Webster Street, Carlisle Street, Carlisle, P 7013. CLINE, DEPUTY SHERIFF COST: $57.56 SO ANSWERS, October 21, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuite Sheriff, •releosoft, Inc. STEPHEN L. BANKO, JR., ESQUIRE Pa. Supreme Court I. D. No. 41727 BRITTANY E. BAKSHI, ESQUIRE Pa. Supreme Court I.D. No. 311617 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17011 Telephone: (717) 760-7501 FAX: (717) 975-8124 E-mail: sbanko(a�marcolisedelstein.com C TtiEj FILED -OFFICE HONO TAR Y '011' CCT 27 PH 2: 19 CUMBERLAND COUNTY PENNSYLVANIA . Attorneys for Defendant, Nicole Trimmer IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY JAMI FELTON, Plaintiff v. NICOLE TRIMMER and KELLI MURPHY-GODFREY, Defendants DOCKET NO. 14-6110 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA: Kindly enter the appearance of the undersigned on behalf of Defendant, Nicole Trimmer, in the above -captioned matter. Date: / G - z ` - Bv. MARELSTEIN STE"H L. BA BRITTAr Y E. B Attorneys for De Nicole Trimmer KO, JR. SHI endant, CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing on all counsel of record by placing the same in the United d, States mail at Camp Hill, Pennsylvania, first-class postage prepaid, on the 41lay of &MOO , 2014, and addressed as follows: Ronald M. Graham, Esquire Whitney S. Graham, Esquire Graham & Mauer, P.C. The Commons At Valley Forge Suite 7 P.O. Box 987 Valley Forge, PA 19482 (Counsel for Plaintiff) Kelli Murphy -Godfrey 242 Webster Street Carlisle, PA 17013 (Defendant) MARGOLIS EDELSTEIN Angela 2 VI. Gayman, I Assistant STEPHEN L. BANKO, JR., ESQUIRE Pa. Supreme Court I. D. No. 41727 BRITTANY E. BAKSHI, ESQUIRE Pa. Supreme Court I.D. No. 311617 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17011 Telephone: (717) 760-7501 FAX: (717) 975-8124 E-mail: sbankoCc�margolisedelstein.com rl 3! Li k i y((. ��F;: TA 30 E, U - iil :ia.A?U COUNTY Y r' S ''I YLVIAtfl Attorneys for Defendant, Nicole Trimmer IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY JAMI FELTON, Plaintiff v. NICOLE TRIMMER and KELLI MURPHY-GODFREY, Defendants DOCKET NO. 14-6110 CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Jami Felton, Plaintiff do Ronald M. Graham, Esquire Whitney S. Graham, Esquire Graham & Mauer, P.C. The Commons At Valley Forge Suite 7 P.O. Box 987 Valley Forge, PA 19482 (Counsel for Plaintiff) You are hereby notified to file a written response to the enclosed New Matter within twenty (20) days from service hereof or a default judgment may be entered against you. Date: 10-3 4 - IV/ B DELSTEIN STEH. N L. =ANKO, JR. BRITTANY E. BAKSHI Attorneys for Defendant, Nicole Trimmer STEPHEN L. BANKO, JR., ESQUIRE Pa. Supreme Court I. D. No. 41727 BRITTANY E. BAKSHI, ESQUIRE Pa. Supreme Court I.D. No. 311617 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17011 Telephone: (717) 760-7501 FAX: (717) 975-8124 E-mail: sbanko(a.margolisedelstein.com Attorneys for Defendant, Nicole Trimmer IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY JAMI FELTON, v. Plaintiff NICOLE TRIMMER and KELLI MURPHY-GODFREY, Defendants DOCKET NO. 14-6110 CIVIL ACTION - LAW JURY TRIAL DEMANDED ANSWER AND NEW MATTER OF DEFENDANT, NICOLE TRIMMER, TO PLAINTIFF'S COMPLAINT 1. Denied. After reasonable investigation, Defendant, Nicole Trimmer ("Trimmer"), is without knowledge or information sufficient to form a belief as to the truth the averments contained in this paragraph and, therefore, they are denied. 2. Admitted in part and denied in part. Recently, Trimmer is married and her surname now is Drobenak. 3. Denied. After reasonable investigation, Trimmer is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph and, therefore, they are denied. 4. Admitted in part and denied in part. The accident occurred at approximately 3:20 to 3:25 p.m. 5. Denied. The allegations contained in this paragraph state a legal conclusion to which no response is necessary. 6. Admitted. 7. Admitted. 8. Denied as stated. It is admitted that Trimmer attempted to inch her vehicle across the west outside lane of South Hanover Street in an effort to make a left turn to head in a northerly direction on Hanover Street. Trimmer denies the implication of the allegations contained in this paragraph of Plaintiff's Complaint that she "drove directly into the path of Plaintiffs moving vehicle". 9. Denied. After reasonable investigation, as to the conduct of Plaintiff in operating her vehicle and whether she was able or unable to avoid a collision with Trimmer's vehicle, after reasonable investigation, Trimmer is without knowledge or information sufficient to form a belief as to the truth of said averment and, therefore, it is denied. 10. Denied. The allegations contained in this paragraph state a legal conclusion to which no response is necessary. By way of further answer, with regard to any allegation as to personal injury allegedly sustained by Plaintiff, after reasonable investigation, Trimmer is without knowledge or information sufficient to form a belief as to the truth of said averment and, therefore, it is denied. 11. Denied. The answer contained in paragraph 10 hereof is incorporated herein by reference as if set forth in its entirety. 12. Denied. The answer contained in paragraph 10 hereof is incorporated herein by reference as if set forth in its entirety. 13. Denied. The answer contained in paragraph 10 hereof is incorporated herein by reference as if set forth in its entirety. 14. Denied. The answer contained in paragraph 10 hereof is incorporated herein by reference as if set forth in its entirety. 15. Denied. The answer contained in paragraph 10 hereof is incorporated herein by reference as if set forth in its entirety. 16. Denied. The answer contained in paragraph 10 hereof is incorporated herein by reference as if set forth in its entirety. COUNT I PLAINTIFF V. TRIMMER 17. The answers contained in paragraphs 1 through 16 hereof are incorporated herein by reference as if set forth in their entirety. 18. Denied. The allegations contained in this paragraph state a legal conclusion to which no response is necessary. By way of further answer, the answer contained in paragraph 9 hereof are incorporated herein by reference as if set forth in its entirety. 19(a. -n.) Denied. The allegations contained in this paragraph state a legal conclusion to which no response is necessary. WHEREFORE, Defendant, Nicole Trimmer, demands judgment in her favor and against Plaintiff. COUNT II PLAINTIFF V. DEFENDANT KELLI MURPHY-GODFREY 20. The answers contained in paragraphs 1 through 19 hereof are incorporated herein by reference as if set forth in their entirety. 3 21-22 The allegations contained in these paragraphs are directed to a party other than Trimmer. Accordingly, and upon advice of counsel, no answer on the part of Trimmer is required. WHEREFORE, Defendant, Nicole Trimmer, demands judgment in her favor and against Plaintiff. NEW MATTER 23. The answers contained in paragraphs 1 through 22 hereof are incorporated herein by reference as if set forth in their entirety. 24. Plaintiffs entitlement to recovery, if any,is governed by and subject to her tort election under the Pennsylvania Motor Vehicle Financial Responsibility Law. WHEREFORE, Defendant, Nicole Trimmer, demands judgment in her favor and against Plaintiff. Date: I `'3t —\\"\ By: 4 MA' ��LI L EDELSTEIN 1. STEN L. BANKO, JR. A' � BRITTAY E. BAKSHI Attorneys for Defendant, Nicole Trimmer VERIFICATION I, Nicole Drobenak, formerly known as Nicole Trimmer, have read the foregoing Answer and New Matter to Plaintiff's Complaint. The factual statements contained therein are known by me and are true and correct to the best of my knowledge, information and belief. This statement and verification is made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsifications to authorities, which provides that, if I knowingly make false averments, I may be subject to criminal penalties. Date: CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing on all counsel of record by placing the same in the United States mail at Camp Hill, Pennsylvania, first-class postage prepaid, on the � " day of 000102." 2014, and addressed as follows: Ronald M. Graham, Esquire Whitney S. Graham, Esquire Graham & Mauer, P.C. The Commons At Valley Forge Suite 7 P.O. Box 987 Valley Forge, PA 19482 (Counsel for Plaintiff) Kelli Murphy -Godfrey 242 Webster Street Carlisle, PA 17013 (Defendant) MARGOLIS EDELSTEIN Angela Gayman, L gal Assistant !CF.. 0 I n 1 :01!0 2: 3 COLG‘JTv IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 14-6110 Civil NICOLE TRIMMER and KELLI MURPHY- : GODFREY, JURY TRIAL DEMANDED JAMI FELTON, V. Plaintiff Defendants PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of George H. Eager of Eager, Stengel, Quinn & Sofilka as attorney of record on behalf of Defendant Kelli Murphy -Godfrey in the above captioned action. DATE: • /L( BY: EAGER, STENGEL, QUINN & SOFILKA Ge . Eager, Esquire Att5rnek for Defendant Murphy -Godfrey I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 • CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Praecipe for Entry of Appearance upon the person set forth below and in the manner indicated: First class mail, postage pre -paid: Ronald M. Graham, Esquire Graham & Maurer, RC. The Commons at Valley Forge Suite 7, Box 987 Valley Forge, PA 19482 DATE: ((7 BY: EAGER, STENGEL, QUINN & SOFILKA GeorgieEager, Esquire Atto ey f r Defendant Murphy -Godfrey I.D. No. 2 740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 GRAHAM & MAUER, P.C. By: Ronald M. Graham, Esquire ID # 64483 By: Whitney S. Graham, Esquire ID # 312145 The Commons At Valley Forge Suite 7, P.O. Box 987 Valley Forge, PA 19482 (610)933-3333 Attorney for Plaintiff JAMI FELTON 205 East High Street, Apt. B Carlisle, PA 17013 Plaintiff : IN THE CUMBERLAND COUNTY : COURT OF COMMON PLEAS v. : No.: 14-6110 NICOLE TRIMMER : CIVIL ACTION 126 Darr Avenue Carlisle, PA 17013 and KELLI MURPHY-GODFREY 242 Webster Street Carlisle, PA 17013 Defendants PLAINTIFF'S RESPONSE TO NEW MATTER OF DEFENDANT NICOLE TRIMMER 23. The corresponding paragraph of Defendant Nicole Trimmer's New Matter does not warrant a response. 24. Denied. It is specifically denied that Plaintiffs entitlement to recovery is subject to her tort election under the Pennsylvania Motor Vehicle Financial Responsibility Law. To the contrary, Plaintiff Jami Felton's recovery is governed by Pa C.S.A. 75 §1701 et. seq. as stated in Plaintiff's Complaint, incorporated herein by reference, at paragraph 16. WHEREFORE, Plaintiff Jami Felton hereby demands judgment in her favor and against Defendant in such matter as set forth in Plaintiff's Complaint. By: Date: //.. 7 GRAHAM MAUER, P.C. Ronal s M. Graham, Esquire Attorney for Plaintiff • GRAHAM & MAUER, P.C. By: Ronald M. Graham, Esquire ID # 64483 By: Whitney S. Graham, Esquire ID # 312145 The Commons At Valley Forge Suite 7, P.O. Box 987 Valley Forge, PA 19482 (610)933-3333 Attorney for Plaintiff JAMI FELTON 205 East High Street, Apt. B Carlisle, PA 17013 Plaintiff b.1440 OM d :IN THE CUMBERLAND COUNTY : COURT OF COMMON PLEAS v. : No.: 14-6110 NICOLE TRIMMER : CIVIL ACTION 126 Darr Avenue Carlisle, PA 17013 and KELLI MURPHY-GODFREY 242 Webster Street Carlisle, PA 17013 Defendants CERTIFICATE OF SERVICE I, Ronald M. Graham, Esquire, attorney for Plaintiff, hereby certify that on this Aay of November, 2014, a true and correct copy of the foregoing Plaintiffs Response to New Matter of Nicole Trimmer was sent via regular US Mail, postage pre -paid to the following: Stephen L. Banko, JR. Esquire Brittany E. Bakshi, Esquire Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 Kelli Murphy -Godfrey 242 Webster Street Carlisle, PA 17013 By: GRAHAM & MAUER, P.C. Ronalfl'_VM. Graham, Esquire Attorney for Plaintiff i ?Oh NIP 24 Pi'1 1: 12 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JAMI FELTON, Plaintiff v. NO. 14-6110 Civil NICOLE TRIMMER and KELLI MURPHY- : GODFREY, JURY TRIAL DEMANDED Defendants ANSWER WITH NEW MATTER AND NEW MATTER PURSUANT TO PA.R.C.P. 1031.1 You are hereby notified to plead to the within New Matter within 20 days from the date of service hereto or a default judgment may be entered against you. AND NOW COMES DEFENDANT KELLI MURPHY-GODFREY, BY AND THROUGH HER ATTORNEY, GEORGE H. EAGER, AND FILES THE FOLLOWING ANSWER: 1-3. Admitted. 4-5. Denied in accordance with Pennsylvania Rule of Civil Procedure 1029(e). 6. Admit. 7-16. Denied in accordance with Pennsylvania Rule of Civil Procedure 1029(e). COUNT I PLAINTIFF JAMI FELTON v DEFENDANT NICOLE TRIMMER 17. Paragraphs 1 through 16 of Defendant Kelli Murphy-Godfrey's Answer are incorporated herein by reference as though fully set forth. 18-19. The allegations of paragraphs 18-19 are addressed to a defendant other than answering defendant and therefore, no responsive pleading is required. If it is deemed that a response is required, the allegations of paragraphs 18-19 are denied in accordance with Pennsylvania Rule of Civil Procedure 1029(e). WHEREFORE, Defendant Kelli Murphy -Godfrey demands that this honorable court enter an Order stating that Defendant Kelli Murphy -Godfrey is not liable to Plaintiff, is not jointly and severally liable to Plaintiff with the Defendant Nicole Trimmer and is not liable over to Defendant Nicole Trimmer by way of indemnity, contribution or otherwise and Defendant Kelli Murphy -Godfrey asks that judgment be entered in her favor and against Plaintiff on all claims set forth in Plaintiffs Complaint. COUNT II PLAINTIFF JAMI FELTON V DEFENDANT KELLI MURPHY-GODFREY 20. Paragraphs 1 through 19 of Defendant Kelli Murphy-Godfrey's Answer are incorporated herein by reference as though fully set forth. 21-22. The allegations of paragraphs 21-22 are denied in accordance with Pennsylvania Rule of Civil Procedure 1029(e). WHEREFORE, Defendant Kelli Murphy -Godfrey demands that this honorable court enter an Order stating that Defendant Kelli Murphy -Godfrey is not liable to Plaintiff, is not jointly and severally liable to Plaintiff with the Defendant Nicole Trimmer and is not liable over to Defendant Nicole Trimmer by way of indemnity, contribution or otherwise and Defendant Kelli Murphy -Godfrey asks that judgment be entered in her favor and against Plaintiff on all claims set forth in Plaintiffs Complaint. NEW MATTER 23. Paragraphs 1 through 22 inclusive above are incorporated herein by reference and made a part hereof. 24. Plaintiff's recovery is barred and/or limited pursuant to the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Act, 75 Pa.C.S.A. 1701, et. seq., and Answering Defendant Kelli Murphy -Godfrey hereby assert all of the rights and defenses available to her under the aforementioned act. 25. Plaintiff's claims are barred and/or limited pursuant to the applicable Statute of Limitations, the relevant portions of which are incorporated herein by reference. 26. Plaintiff's claims are barred and/or limited by the tort thresholds, applicable by election or law, of the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa.C.S.A. §1701, et. seq. 27. Plaintiff's claims are barred and/or limited by the preclusion of pleading, proving and/or recovering special damages as set forth in §1722 of the Pennsylvania Motor Vehicle Financial Responsibility Law, Pa.C.S.A. §1722. 28. Plaintiff's claims are barred by the affirmative defenses identified in Pennsylvania Rule of Civil Procedure 1030, including but not limited to (a) waiver; (b) estoppel; (c) statutes of limitation; (d) laches; (e) illegality; (f) release; (g) impossibility of performance; (h) fraud; (i) assumption of the risk; and (j) payment. WHEREFORE, DefendantKelli Murphy -Godfrey demands that this honorable court enter an Order stating that Defendant Kelli Murphy -Godfrey is not liable to Plaintiff, is not jointly and severally liable to Plaintiff with the Defendant Nicole Trimmer and is not liable over to Defendant Nicole Trimmer by way of indemnity, contribution or otherwise and Defendant Kelli Murphy -Godfrey asks that judgment be entered in her favor and against Plaintiff on all claims set forth in Plaintiffs Complaint. NEW MATTER PURSUANT TO PA.R.C.P. 1031.1 29. Answering Defendant hereby incorporates by reference paragraphs 1 through 28 of the foregoing Answer and New Matter as if same were set forth more fully at length. 30. Answering Defendant denies any and all liability to Plaintiff but avers that if Plaintiff is entitled to recovery based upon the allegations of the Complaint, or proof entered in support thereof, then any such right of recovery is due and based solely upon the acts or omissions of co-defendant, Nicole Trimmer, against whom Answering Defendant asserts a right of contribution and/or indemnity for any damages for which she may be determined to be liable to Plaintiff. WHEREFORE, Answering Defendant demands that this honorable court enter an Order stating that Answering Defendant is not liable to Plaintiff, is not jointly and severally liable to Plaintiff with the Co -Defendant Nicole Trimmer and is not liable over to Co -Defendant Nicole Trimmer by way of indemnity, contribution or otherwise and Answering Defendant asks that judgment be entered in her favor and against Plaintiff on all claims set forth in Plaintiffs Complaint. DATE: I1 WIN/ BY: EAGER, STENGEL, QUINN & SOFILKA George H. Eager, E .1:°re Attorney for Defen►tt Murphy -Godfrey I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 VERIFICATION I, Kelli Murphy -Godfrey, hereby verify that I am a Defendant in the foregoing action, and that the averments of the foregoing Answer with New Matter to the Complaint are true and correct to the best of my knowledge, information and belief. To the extent that any of the averments of the Answer with New Matter to the Complaint are based upon an understanding or application of law, I have relied upon counsel in making this Verification. I understand that I am subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities for any false statements made herein. Dated: 1,` / C/0 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Answer with New Matter and New Matter Pursuant to PA R.C.P. 1031.1 upon the person set forth below and in the manner indicated: First class mail, postage pre -paid: Ronald M. Graham, Esquire Graham & Maurer, P.C. The Commons at Valley Forge Suite 7, Box 987 Valley Forge, PA 19482 Attorney for Plaintiff DATE: � J )(I BY: Stephen L. Banko, Jr., Esquire Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 Attorney for Defendant Trimmer EAGER, STENGEL, QUINN & SOFILKA George H. Eager, E qui, Attorney for Defenda I.D. No. 27740 1347 Fruitville Pi Lancaster, PA 7601 (717) 290-7971 urphy-Godfrey Eli [' ( i FICE PROTHONOTAR`Y 2014 NOV 24 PM f: 12 CUMBERLAND COUNTY PENNSYLVANIA ORIGINAL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JAMI FELTON, Plaintiff v. NO. 14-6110 Civil NICOLE TRIMMER and KELLI MURPHY- : GODFREY, JURY TRIAL DEMANDED Defendants CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served an original of Interrogatories of Defendant Kelli Murphy -Godfrey Addressed to Plaintiff upon the person set forth below and in the manner indicated: First class mail, postage pre -paid: Ronald M. Graham, Esquire Graham & Maurer, P.C. The Commons at Valley Forge Suite 7, Box 987 Valley Forge, PA 19482 Attorney for Plaintiff DATE: fl BY: Stephen L. Banko, Jr., Esquire Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 Attorney for Defendant Trimmer EAGER, STENGEL, QUINN & SOFILKA George H. Eager, uire Attorney for Defen•ant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 t;;Y THE PROTHONOTARY 2OE4 NOV 24 PH 1:1 2 CU PENNSYLVAN A UNI Y LORGINALJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JAMI FELTON, Plaintiff v. NO. 14-6110 Civil NICOLE TRIMMER and KELLI MURPHY- : GODFREY, JURY TRIAL DEMANDED Defendants CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of Defendant's Request for Production and Copying of Documents - Set No. 1 Directed to Plaintiff upon the person set forth below and in the manner indicated: First class mail, postage pre -paid: Ronald M. Graham, Esquire Graham & Maurer, P.C. The Commons at Valley Forge Suite 7, Box 987 Valley Forge, PA 19482 Attorney for Plaintiff Stephen L. Banko, Jr., Esquire Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 Attorney for Defendant Trimmer EAGER, STENGEL, QUINN & SOFILKA George ager, Y-quir Attorney for Defe'dant Mrphy-Godfrey I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 STEPHEN L. BANKO, JR., ESQUIRE Pa. Supreme Court I. D. No. 41727 BRITTANY E. BAKSHI, ESQUIRE Pa. Supreme Court I.D. No. 311617 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17011 Telephone: (717) 760-7501 FAX: (717) 975-8124 E-mail: sbanko(a.margolisedelstein.com LED O'F100 THE P1O HO 0L•1 ' 2311��,(NOV 26 PM 12: 41 CUl IBE.RLAND COUNTY PENNSYLVANIA Attorneys for Defendant, Nicole Trimmer IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY JAMI FELTON, v. Plaintiff NICOLE TRIMMER and KELLI MURPHY-GODFREY, Defendants DOCKET NO. 14-6110 CIVIL ACTION - LAW JURY TRIAL DEMANDED REPLY OF DEFENDANT, NICOLE TRIMMER, TO CROSS CLAIM NEW MATTER OF DEFENDANT, KELLI MURPHY-GODFREY - PA. R.C.P. NO. 1031.1 29. Paragraphs 1-24 of the Answer and New Matter of Defendant, Nicole Trimmer ("Trimmer"), are incorporated herein by reference as if set forth in their entirety. 30. Denied. The allegations contained in this paragraph state a legal conclusion to which no response is necessary. WHEREFORE, Defendant, Nicole Trimmer, demands judgment in her favor and against Plaintiff and against Defendant, Kelli Murphy -Godfrey on said Defendant's New Matter pursuant to Pa. R.C.P. No. 1031.1. Date: 04,C By. MAR �� /IS . MELSTEIN ,r STE7 E ' L. B A NKO, JR. BRITTANY E. r:AKSHI Attorneys for Defendant, Nicole Trimmer CERTIFICATE OF SERVICE HEREBY CERTIFY that I served a true and correct copy of the foregoing on all counsel of record by placing the same in the United States mail at Camp Hill, tay Pennsylvania, first-class postage prepaid, on the.J of 0U 2014, and addressed as follows: Ronald M. Graham, Esquire Whitney S. Graham, Esquire Graham & Mauer, P.C. The Commons At Valley Forge Suite 7 P.O. Box 987 Valley Forge, PA 19482 (Counsel for Plaintiff) George H. Eager, Esquire Eager, Stengel, Quinn & Sofilka 1347 Fruitville Pike Lancaster, PA 17601 (Counsel for Defendant, Kelli Murphy -Godfrey) M ° RGOLIS EDELSTEIN Angela '.. Gayman, gal Assistant GRAHAM & MAUER, P.C. By: Ronald M. Graham, Esquire ID # 64483 By: Whitney S. Graham, Esquire ID # 312145 The Commons At Valley Forge Suite 7, P.O. Box 987 Valley Forge, PA 19482 (610)933-3333 JAMI FELTON 205 East High Street, Apt. B Carlisle, PA 17013 Plaintiff Attorney for Plaintiff. : IN THE CUMBERLAND COUNTY : COURT OF COMMON PLEAS v. : No.: 14-6110 NICOLE TRIMMER : CIVIL ACTION 126 Darr Avenue Carlisle, PA 17013 and KELLI MURPHY-GODFREY 242 Webster Street Carlisle, PA 17013 Defendants PLAINTIFF'S REPLY TO NEW MATTER OF DEFENDANT KELLI MURPHY- GODFREY 23. No reply required. 24. Denied. Answering Plaintiff is advised by counsel and, therefore, avers that the allegations contained in the corresponding paragraph of Defendant's New Matter are automatically deemed denied as conclusions of law to which no responsive pleading is required. Strict proof thereof is demanded at trial, if material. 25. Denied. Answering Plaintiff is advised by counsel and, therefore, avers that the allegations contained in the corresponding paragraph of Defendant's New Matter are automatically deemed denied as conclusions of law to which no responsive pleading is required. Strict proof thereof is demanded at trial, if material. To the extend however, a reply may be required, Plaintiff specifically denies that her Complaint was untimely filed. Ori the contrary, Plaintiff's Complaint was filed within the applicable statue of limitations. 26. Denied. Answering Plaintiff is advised by counsel and, therefore, avers that the allegations contained in the corresponding paragraph of Defendant's New Matter are automatically deemed denied as conclusions of law to which no responsive pleading is required. Strict proof thereof is demanded at trial, if material. 27. Denied. Answering Plaintiff is advised by counsel and, therefore, avers that the allegations contained in the corresponding paragraph of Defendant's New Matter are automatically deemed denied as conclusions of law to which no responsive pleading is required. Strict proof thereof is demanded at trial, if material. 28. Denied. Answering Plaintiff is advised by counsel and, therefore, avers that the allegations contained in the corresponding paragraph of Defendant's New Matter are automatically deemed denied as conclusions of law to which no responsive pleading is required. Strict proof thereof is demanded at trial, if material. To the extent however, a reply may be required, Plaintiff specifically denies that Plaintiff's claims are barred by the affirmative defenses of waiver, estoppel, statute of limitations, laches, illegality, release, impossibility of performance, fraud, assumption of the risk and payment. 29. No answer required. 30. Denied. Answering Plaintiff is advised by' counsel and, therefore, avers that the allegations contained in the corresponding paragraph of Defendant's New Matter are automatically deemed denied as conclusions of law to which no responsive pleading is required. Strict proof thereof is demanded at trial, if material. To the extent however, a reply may be required, Plaintiff specifically denies that Defendant Kelli Murphy -Godfrey is not liable to Plaintiff. By way of further answer Plaintiff specifically denies that Plaintiff s sole right of recovery is against Defendant Nicole Trimmer, but rather against Defendant Kelli Murphy- Godfrey as well. WHEREFORE, Plaintiff Jami Felton hereby demands judgment in her favor and against Defendant Kelli Murphy -Godfrey in an amount which exceeds the jurisdictional limit requiring arbitration referral by local rule and compensatory damages, plus interest, costs and such other remedies as this Court may deem just and proper. By: Date: )--•/ Respectfully submitted,• GRAHAM & MAUER, P.C. Ron la M. Graham GRAHAM & MAUER, P.C. By: Ronald M. Graham, Esquire ID # 64483 By: Whitney S. Graham, Esquire ID # 312145 The Commons At Valley Forge Suite 7, P.O. Box 987 Valley Forge, PA 19482 (610)933-3333 Attorney for Plaintiff JAMI FELTON 205 East High Street, Apt. B Carlisle, PA 17013 Plaintiff NICOLE TRIMMER 126 Darr Avenue Carlisle, PA 17013 and KELLI MURPHY-GODFREY 242 Webster Street Carlisle, PA 17013 Defendants : IN THE CUMBERLAND COUNTY COURT OF COMMON PLEAS : No.: 14-6110 : CIVIL ACTION • CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this Plaintiff's Reply to New Matter of Defendant Kelli Murphy -Godfrey was mailed first class, postage prepaid to the following Stephen L. Banko, Esquire Margolis Edelstein 3501 Trindle.Road Camp Hill, PA 17011 day of December 2014, a true and correct copy of i George Eager, Esquire Eager, Stengel, Quinn & Sofilka 1347 Fruitville Pike Lancaster, PA 17601-4001 By: GRAHAM & MAUER, P.C. Ron ld M. Graham, Esquire Attorney for Plaintiff IN TH.E MATTER OF: JAMI FELTON CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 14-6110 NICOLE TRIMMER, ET AL c-, y As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that n.� • (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/02/2015 •- lf of ST: HEN! . B' KO, JR., ESQ. Attorne for DEFENDANT KMUNSHOWER@MARGOLISEDELSTEIN.COM MCS # 61479-LO1 DE11 COMMONWEALTH OF PENNSYLVANIA IN THE MATTER OF: JAMI FELTON COUNTY OF CUMBERLAND -VS- NICOLE TRIMMER, ET AL COURT OF COMMON PLEAS TERM, CASE NO: 14-6110 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: RONALD M. GRAHAM, ESQ., PLAINTIFF COUNSEL GEORGE H. EAGER,ESQ. MCS on behalf of STEPHEN L. BANKO, JR., ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. DATE: 12/10/2014 CC: STEPHEN L. BANKO, JR., ESQ. - 21500.4-00078 RONALD M. GRAHAM, ESQ. GRAHAM & MAUER THE COMMONS @ VALLY FORGE STE.7 PO BOX 987-23 VALLEY FORGE, PA 19482 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 MCS # 61479-CO1 DE02 LOCATION NAME »> LOCATION LIST «< PAGE: RECORDS REQUESTED ORTHOPAEDIC INSTITUTE OF PA CARLISLE REGIONAL MEDICAL CTR CARLISLE REGIONAL MEDICAL CTR. CARLISLE .REGIONAL MEDICAL CTR. SADLER HEALTH CENTER CORP. HAMILTON HEALTH CENTER, INC. RANDSTAD STAFFING CEVA LOGISTICS MEDICAL, BILLING, AND RADIOLOGY RADIOLOGY MEDICAL RECORDS BILLING ONLY MEDICAL, BILLING, AND RADIOLOGY MEDICAL, BILLING, AND RADIOLOGY EMPLOYMENT EMPLOYMENT MCS # 61479-001 DE02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMI FELTON vs. NICOLE TRIMMER, ET AL. File No. 14-6110 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ORTHOPAEDIC INSTITUTE OF PA (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: * * * * SEE ATTACHED RIDER at The MCS Group. Inc.. 1601 ar>ket Street: Suite 00. Phil19103 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, inadvance, the reasonable cost of preparing -the copies or producingthe:things sought. If you fail to _produce: the 'documents or:things required by this. subpoena within twenty (20) days:.after its. service, the_.partyserving 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: STEPHEN L. BANKO, JR., ESQ. ADDRESS: 3510. TRINDLE_ROAD CAMP HILL, PA 17011 TELEPHONE: (215).246-0900 SUPREME COURT ID #: A 11 ORNEY FOR: Defendant Date:. Seal of the Court COURT: k, Civil Division Deputy 61479-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ORTHOPAEDIC INSTITUTE OF PA 3399 TRINDLE ROAD 2ND FLOOR CAMP HILL. PA 17011 RE: MCS # 61479-L01 JAM LYNN FELTON 205 E. HIGH STREET, APT. B CARLISLE, PA 17013 Social Security #: XXX -XX -6134 Date of Birth: 10-15-1967 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history.and physical reports. Supply all emergency room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs. EKGs. EMGs, MRIs and x-rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and.all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 61479-L01 SU10 IN THE MATTER OF: JAMI FELTON CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 14-6110 NICOLE TRIMMER, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/02/2015 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT KMUNSHOWER@MARGOLISEDELSTEIN.COM MCS # 61479-L02 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND • JAMI FELTON vs. NICOLE TRIMMER, ET AL File No. 14-6110 SUBPOENA TO PRODUCE DOCUMENTS OR THI-NGS FOR DISCOVERY PURSUANT TO RULE. 4009.22 TO: Custodian of Records for CARLISLE REGIONALDICAL CTR (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things. **** SEE ATTACHED RIDER **** at The .MCS Group. Inc.. 1601 Market.Strect.Suite 890. Philadelphia. PA 19103 You .may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with :the:certificate of compliance, to.the party making. this request at.the address. listed above. Youthave.the .ri.ght to seek, in advance, the reasonable cost of preparingthe.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: STEPHEN L. BANKO, JR.. ESQ. ADDRESS: 3510 TRINDLE ROAD CAMP HILL.. PA 1.7011 TELEPHONE: (215) 246=0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: kir/ Seal of the Court BY .1 .O ' T: ler , Civil Division Deputy 61479-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CTR 361 ALEXANDER SPRING RD RADIOLOGY DEPT. CARLISLE. PA 17013 RE: MCS # 61479-L02 JAMI LYNN FELTON 205 E. HIGH STREET, APT. B CARLISLE, PA 17013 'Social Security #: XXX -XX -6134 Date of Birth: 10-15-1967 Please provide any and all xray films, CT scans & MRI films and reports . This should contain all x-ray films__and reports in your possession, all archived films and reports, or films and reports in storage. Including any and all.such items as may be stored,in a computer database or otherwise in.electronic form. • Prior approval is required for fees in excess of $150.00 for hospitaps, $10.0.00 for all other providers. MCS # 61479-L02 SU10 IN THE MATTER OF: JAMI FELTON CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 14-6110 NICOLE TRIMMER, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/02/2015 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT KMUNSHOWER@MARGOLISEDELSTEIN.COM MCS # 61479-L03 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMI FELTON vs. NICOLE TRIMMER, ET AL File No. 14-6110 SUBPOENA TO PRODUCE.DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 400912 TO: Custodian of Records for CARLISLE REGIONAL MEDICAL CTR. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc.. 1601 Market Sfte_et. Smite 800.Philadelphia. PA 19103 You, may -deliver or -mail legible copies of the documents or produce things requested by.thi& subpoena, together withAhecertificate of compliance, to theparty .making:this: request atthenddres&listethabove. Youlavetheright to seek, in, advance, the reasonable cost of preparing the copies or producing the things sought. If you- fail to •produce the, documents or- thing&.required•by this subpoena within twenty (20):flay&afterits service, the party _serving this subpoenamay seek a_ coutt ordercompelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: STEPHEN L. BANKO, JR., ESQ. ADDRESS: 3510 TRINDLE ROAD CAMP,.HILL, PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: s Seal of the Court Deputy 61479-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CTR. 361_ ALEXANDER SPRING RD. MEDICAL RECORDS CARLISLE. PA 17015 RE: MCS # 61479-L03 JAMI LYNN FELTON 205 E. HIGH STREET, APT. B CARLISLE, PA 17013 Social Security #: XXX -XX -6134 Date of Birth: 10-15-1967 Please provide the entire hospital medical file, including but not limited to all inpatient and outpatient records, ER records, physical therapy records, intake or admission forms, correspondence to and from the consulting and treating physicians, and discharge forms. Include all files memoranda, handwritten notes, history and physical reports. Including any and all laboratory & office/admission charts. Supply all medication and prescription records, nurses' notes, doctor's comments, dietary and all patient consent or refusal of treatment, . This should contain all records in your possession, including all archived records, records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 61479-L03 SU10 IN THE MATTER OF: JA.MI FELTON CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 14-6110 NICOLE TRIMMER, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/02/2015 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT KMUNSHOWER@MARGOLISEDELSTEIN.COM MCS # 61479-L04 DEll COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMI FELTON File No. 14-6110 VS. NICOLE TRIMMER, ET AL SUBPOENA TO. PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT. TO. -RULE 4009.22 TO: Custodian of Records for CARLISLE REGIONAL .MEDICAL CTR, (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: * * * * SEE ATTACHED RIDER * * * * at The MCS Group. Inc.. 1601 Market Street. Suite 800Miiladelphia. PA 19103 You maydeliver 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. Ifyou <fail to produce the documents or things required by this subpoena within twenty (20).days after its service, the:1party serving.this subpoena may seek a courtt order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: STEPHEN L. BANKO, JR., ESQ. ADDRESS: 3510 TRINDLE ROAD CAMP HILL, PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court . BY URT: ry/Cler , Civil Division Deputy 61479-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CTR. 361 ALEXANDER SPRING RD. BILLING DEPT. CARLISLE. PA 17015 RE: MCS # 61479-L04 JAMI LYNN FELTON 205 E. HIGH STREET, APT. B CARLISLE, PA 17013 Social Security #: XXX -XX -6134 Date of Birth: 10-15-1967 Please provide any and all billing, insurance claims, and payments, outstanding and delinquent invoices. This should contain all records in your possession. all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 61479-L04 SU10 IN THE MATTER OF: JAMI FELTON CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 14-6110 NICOLE TRIMMER, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/02/2015 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT KMUNSHOWER@MARGOLISEDELSTEIN.COM MCS # 61479-L05 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMI FELTON vs. NICOLE TRIMMER, ET AL. File No. 14-6110 SUBPOENA TO PRODUCE. DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO -RULE 400:9.22 TO: Custodian of Records for SADLER HEALTH CENTER CORP. (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.Gr.oup..Inc., 1601 Market Street Suite 800. Philadelphia.. PA 19103 Youmay.deliver or mail legible copies of the documents or produce things requested by this subpoena, together with;the.:certificate.of.compliance, tothe making thisrequest..at the=address listetLabove. You .haverthe:right toseek, in advance, the reasonable cost of preparing..the..copies or producing: thethings sought. Ifyou'Sail:toproduce: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: STEPHEN L. BANKO. JR.. ESQ. ADDRESS: 3510 TRINDLE ROAD CAMP HILL. PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY 4 _ sU. T: Proms: no k, Civil Division Deputy 61479-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SADLER HEALTH CENTER CORP. 100 N. HANOVER ST. CARLISLE. PA 17013 RE: MCS # 61479-L05 JAMI LYNN FELTON 205 E. HIGH STREET, APT. B CARLISLE, PA 17013 Social Security #: XXX -XX -6134 Date of Birth: 10-15-1967 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history,and physical reports. Supply all emergency room records, physical therapy records. medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts, labs archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 61479-L05 SU10 IN THE MATTER OF: JAMI FELTON CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 14-6110 NICOLE TRIMMER, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/02/2015 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT KMUNSHOWER@MARGOLISEDELSTEIN.COM MCS # 61479-L06 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMI FELTON vs. NICOLE TRIMMER, ET AL File No. 14-6110 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HAMILTON HEALTH CENTER. INC. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested- by- this.subpoena,.:together with. thecertificate of compliance, to the. party making this request at..the_address:=listedabove_. You haveahe:°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: STEPHEN L. BANKO.. JR., ESQ. ADDRESS: 3510 TRINDLE ROAD CAMP HILL. PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY T Prothonotary/ ' erk, Civil Division Deputy 61479-06 EXPLANATION OF 'REQUIRED RECORDS T0: CUSTODIAN OF RECORDS FOR: HAMILTON HEALTH CENTER, INC. 1650 WALNUT ST. HARRISBURG. PA 17103 RE: MCS # 61479-L06 JAMI LYNN FELTON 205 E. HIGH STREET, APT. B CARLISLE, PA 17013 Social Security #: XXX -XX -6134 . Date of Birth: 10-15-1967 Please provide entire medical, billing and diagnostic file, including but not limited to any and all inpatient and outpatient records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history.and physical reports. Supply all emergency. room records, physical therapy records, medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs. EKGs, EMGs: MRIs and x-rays and all corresponding reports or inventories. This should contain all records in your possession all office and admission charts., labs archived records, or records in storage. Including any and all items as -may be stored in a computer database or otherwise in electronic form. ter: Prior approval is .required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 61479-L06 SU10 IN THE MATTER OF: jAMI FELTON CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 14-6110 NICOLE TRIMMER, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22. MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/02/2015 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT KMUNSHOWER@MARGOLISEDELSTEIN.COM MCS # 61479-L07 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMI FELTON vs. NICOLE TRIMMER, ET AL. File No. 14-6110 SUBPOENA TO. PRODUCE.. DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE.4009.22 TO: Custodian of Records for RANDSTAD STAFFING (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: * * * * SEE ATTACHED.. RIDER * * * * at The.MCS Group..Inc..1601_MarketStrceLS _80.0:, ._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°listaabove. Yonrhavethexight to seek, in advance, the reasonable cost of preparingthe: 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, theparty 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: STEPHEN L. BANKO, JR., ESQ. ADDRESS:. 3510 TRINDLE ROAD CAMP HILL._ PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court Prothonotary/Clerk, ivil Division Deputy 61479-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: RANDSIAD STAFFING 1 ALEXANDRA COURT CARLISLE. PA 17015 RE: MCS # 61479-L07 JAMI LYNN FELTON 205 E. HIGH STREET, APT. B CARLISLE, PA 17013 Social Security #: XXX -XX -6134 Date of Birth: 10-15-1967 Any and all employment records„ including applications, files, memoranda, compensation, disciplinary actions, time and attendance records. Please include personnel records, W2..forms, payroll and salary information. Supply all employee medical records including any,disability, workers compensation, or incident reports and claims. This should contain all records in your possession. all archived records, or records in storage. Including. any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 61479-L07 SU10 IN THE MATTER OF: JAMI FELTON CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 14-6110 NICOLE TRIMMER, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/02/2015 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT KMUNSHOWER@MARGOLISEDELSTEIN.COM MCS # 61479-L08 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND • JAMI FELTON vs. NICOLE TRIMMER, ET AL File No. 14-6110 SUBPOENA TO PROF UCE..D.00UMENTS ORTHINGS FOR DISCOVERY PURSUANT TO:RULE 4009.22 TO: Custodian of Records for CEVA LOGISTICS (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS. Group. Inc.. 1601 Market.Street._Suite> ia.: PA 19103 You. -may deliver or mail legible copies of the documents or produce things requestedbyahis subpoena, together with•the..certift.cate of compliance, to the party making:this.req:nest-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: STEPHEN L. BANKO,JR., ESQ. ADDRESS: 3510 TRINDLE ROAD CAMP HILL. PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY T / lerk, Ci 1 Division Deputy 61479-08'.. EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CEVA LOGISTICS 1501 DISTRIBUTION DRIVE CARLISLE. PA 17013 RE: MCS # 61479-L08 JAMI LYNN FELTON 205 E. HIGH STREET, APT. B CARLISLE, PA 17013 Social Security #: XXX -XX -6134 Date of Birth: 10-15-1967 Any and all employment records„ including applications, files, memoranda, compensation, disciplinary actions, time and attendance records. Please include personnel records, W2forms, payroll and salary information. Supply all employee medical records including any.disability, workers compensation, or incident reports and claims. This should contain all records in your possession. all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 61479-L08. SU10