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IN RE: CALENE M. CLOUSE, IN THE COURT OF COMMON PLEAS
an alleged incapacitated person OF CUMBERLAND COUNTY,
: PENNSYLVANIA
ORPHANS' COURT DIVISION
On the Petition of No. 21-2015-0093
J. Edward Clouse
OBJECTION TO SUBPOENA PURSUANT TO RULE 4009.2
Calene M. Clouse objects to the proposed subpoena directed to Haven Behavioral
Hospital that is attached as Exhibit A to this objection for the following reason: The records
sought to be produced are, upon information and belief, records relating to treatment under
Pennsylvania's Mental Health Procedures Act, 50 P.S. §7101 et seq., and are confidential and
not subject to discovery pursuant to 50 P.S. §7111.
Respectfully submitted,
SAIDIS SULLIVAN & ROGERS
�PWd: fAy 11, 2015. BY:
Daniel L. Sullivan, Esquire
- Id. No. 34548
26 West High Street
r- F;. ,, Carlisle, PA 17013
W U Jcz) `—' ..J.. (717) 243-6222
Attorne s or Calene M. Clouse
LU
IVa
Neil W.Yahn,Esquire
Attorney I.D.No.82278
JSDC Law Offices
P.Q.Box 650
Hershey,PA 17033
Attorneys for Petitioner
IN RE: CALENE M. CLOUSE, ) IN THE COURT OF COMMON PLEAS
an alleged incapacitated person ) CUMBERLAND COUNTY,PENNSYLVANIA
ORPHANS`COURT DIVISION
On the Petition of )
J. Edward Clouse ) NO. 21-15-93
NOTICE OF INTENT TO SERVE A SUBPOENA
TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.22
Neil W. Yahn,Esquire 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 no objection is made the subpoena
may be served.
Respectfully submitted,
JSDC_LAW OFFICES
Date:-44-71 By:
Neil,°Warn Yahn,Esquire
Attorney I.D.No. 82278
O.Box+
ershey,PA 17033
(717) 533/-3280
ttorrrey for Petitioner
C
.-
LT'2
COMMONWEALTH OF PENNSYLVANrA
COUNTY OF CUMBERLAND
In Re:
CALENz M. CLOUSE,
an alleged incapacitated person F1kN0.2'1--15-
_93
on the Petition of
J. Edward Clouse
SUBPOENA TO PRODUCE DOCUMENTS OR TM NGS
FOR DISCOVERY PURSUANT TO RULE 409.22
TO:Haven Behavioral Hospital 145 1 N. 6th St. Reading, PA 19601
(Name of Pwwn orEntity}
Within twenty(20)days afttr service of this subpoena,you am ordered by the court to produce the
following documents or things:
See Attached Exhibit "A"
at the below referenced address
(Address}
You may deliver or mall legible copies of the documents or Produce things requested y ,
subpoena,together with the certificate of compliance,to the perty making this request at the addrms listed
above. You have the right to seek in advance the reasonable cost of preparing the copies Or producing the
things sought.
If you fall to produce the documents or 9&V required by this subpoena within twenty(20)days
after its service,the party saving this subpoena may seek a court order compelling you to comply with it
TIES SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: Neil Warner Yahn, Esquire
ADDRESS: P.O. Box 654
Hershey, PA 17013
TEL.&HOKE: 717-533-3280
SUPREME COURT ID# 82276
ATTORNEY FOR; J. Edward Clouse
BY THE COURM
Register of of the ombw
Court
Date:
Seal ofthe Court DW*
Y i
F
Q
F
�`
E
t
EXHIBIT"A"
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY
PURSUANT TO RULE 4009.22
TO: Haven Behavioral Hospital
145N6th St
Reading,PA 19601
Copies of any and all documents related to Calene M. Clouse,including but not limited
to,medical records,medical charts,prescriptions,prognoses,diagnoses,physician
referrals, specialist reports,nurses notes and capacity evaluations, for the time period
from January of 2013 though the date of this Subpoena.
i
��
i
Neil W.Yahn,Esquire
Attorney I.D.No.82278
JSDC Law Offices
P.Q.Box 650
Hershey,PA 17033
Attorneys for Petitioner
IN RE: CALENE M. CLOUSE, ) IN THE COURT OF COMMON PLEAS
an alleged incapacitated person ) CUMBERLAND COUNTY,PENNSYLVANIA
ORPHANS'COURT DIVISION
On the Petition of )
J. Edward Clouse } NO.21-15-93
CERTIFICATE OF SERVICE
AND NOW,thisZjday of April,2015,I,Neil W.Yahn,Esquire,do hereby certify that I
served a true and correct copy of the foregoing Notice of Intent to Serve a Subpoena upon the
following below-named individuals by depositing the same in the U.S. Mail,postage pre-paid at
Hershey,Dauphin County,Pennsylvania:
SERVED UPON:
Robert C. Saidis,Esquire
Saidis, Sullivan&Rogers
26 West High Street
Carlisle, PA 17013
Attorney for Calene Mouse
NEIL W�ER YAHN,ESQUIRE
Attorney I.D.#8+ 278
CERTIFICATE OF SERVICE
The undersigned hereby certifies that I have served the foregoing document upon counsel
of record this date by depositing a true and correct copy of the same in the United States mail,
first-class postage prepaid, addressed as follows:
Neil W. Yahn, Esq.
JSDC Law Office
P. O. Box 650
Hershey, PA 17033-0650
Attorney for J. Edward Clouse
SAIDIS, SULLIVAN & ROGERS
Dated: May 11, 2015 BY: �\
Daniel L. Sullivan, Esquire
Id. No. 34548
26 West High Street
Carlisle, PA 17013
(717) 243-6222
Attorneys for Calene M. Clouse