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Home My WebLink About05-2941SCHMIDT, RONCA & KRAMER, P.C. BY: Scott B. Cooper, ESQUIRE I.D. #70242 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorneys for Plaintiffs scooven@srklaw.com Ashley Dickinson, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs CIVIL ACTION - LAW V. Curtis Ulrich, No. OS- a 9 4 / l: t ( A 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 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 Asociation 32 S. Bedford Street Carlisle, PA 17013 SCHMIDT, RONCA & KRAMER, p•C. BY: Scott B. Cooper, ESQUIRE I.D. #70242 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorneys for Plaintiffs Ashley Dickinson, _ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, Plaintiffs PENNSYLVANIA CIVIL ACTION - LAW V. Curtis Ulrich, : No. Defendant JURY TRIAL DEMANDED AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despues de la notificaci6n de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar acci6n como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamaci6n o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin 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, LLA ME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE ME 0 PROVE INFORMACION A CERCA DE COMO CONSEGUIR UN ABO GADO. 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 32 S. Bedford Street Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ASHLEY DICKINSON, IN THE COURT OF COMMON Plaintiffs : PLEAS : CUMBERLAND COUNTY, V. : PENNSYLVANIA CURTIS ULRICH, Defendant COMPLAINT CIVIL ACTION - LAW NO. US"- a91/I 0?;C AND NOW COMES, the Plaintiff, Ashley Dickinson, by and through her attorneys SCHMIDT, RONCA AND KRAMER, P.C. and hereby avers as follow: 1. The Plaintiff, Ashley Dickinson, is an adult individual who at all times relevant hereto has lived at 647 West Chestnut Street, Lancaster, Lancaster County, Pennsylvania 17603. 2. The Defendant, Curtis Ulrich, is an adult individual who at all times relevant hereto has lived at 107-A East Main Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The facts and occurrences hereinafter took place on or about June 17, 2003 on Lampeter Road in Lampeter Township, -1- Lancaster County Pennsylvania. 4. At the aforementioned time and place, the Plaintiff, Ashley Dickinson was a passenger in a vehicle being driven by her sister, Farran Dickinson. 5. At the aforementioned time and place, the Defendant, Curtis Ulrich, was traveling in the same direction, behind the Dickinson vehicle. 6. At the aforementioned time and place, the Defendant, Curtis Ulrich, rear-ended the Dickinson vehicle when causing the injuries to Ashley set forth below. COUNT I ASHLEY DICKIN ON V. CURTIS ULRICH NEGLIGENCE 7. Paragraphs 1 through 6 of the Plaintiff's Complaint are incorporated by reference and made a part thereof as if set forth in full. 8. The accident was caused by the negligence, carelessness and recklessness of the Defendant, and was in no way caused or contributed to by the Plaintiff. 9. The carelessness, negligence and recklessness of the Defendant consisted of the following: a. inattentiveness; -2- b. failing to keep a reasonable look out for other vehicles lawfully on the roadway; C. failing to have his vehicle under proper and adequate control; d. failing to apply his brakes in time to avoid the collision with the Dickinson vehicle; e. negligently applying his brakes; f. failing to observe the Dickinson vehicle la roadway; wfully on the g. failing to operate his vehicle in accordance with existing traffic conditions and traffic controls; h. Operating his vehicle so as to create a dangerous situation for other vehicles on the roadway; L operating his vehicle so that he could not stop within the assured clear distance ahead and; j. careless driving. 10. As a direct and proximate result of the accident and the Defendant's carelessness, negligence and recklessness, the Plaintiff, Ashley Dickinson sustained injuries which are serious and may be permanent including, but not limited to: a. lumbar strain; b. thoracic pain; and c. head pain. -3- 11. As a direct and proximate result of the injuries sustained in the motor vehicle accident, the Plaintiff has been advised and, therefore avers, that the aforementioned injuries may be permanent in nature and effect and, thus, a claim for these injuries is made. 12. As a direct and proximate result of the accident, the Plaintiff, and others on her behalf, have incurred medical expenses for the injuries she has sustained, and may continue to incur medical expenses into the future, and thus, a claim for these expenses is made. 13. As a direct and proximate result of the injuries sustained in the motor vehicle accident, the Plaintiff has undergone in the past, and may continue to undergo in the future, great pain and suffering, and thus, a claim for these losses is made. 14. As a direct and proximate result of the injuries sustained in the motor vehicle accident, the Plaintiff may have suffered a permanent diminution of her ability to enjoy life and life's pleasures, and thus, a claim for these losses is made. 15. As a direct and proximate result of the injuries sustained in the motor vehicle accident, the Plaintiff has suffered a real loss of wages, and may have suffered an impairment of her future -4- earning power and capacity, and thus, a claim for these losses is made. WHEREFORE, Plaintiff Ashley Dickinson demands judgment on the Defendant Curtis Ulrich in an amount in excess of Thirty-Five Thousand ($35,000.00) Dollars and in excess of an amount requiring compulsory arbitration. Respectfully Submitted, SCHMIDT, RONCA & KRAMER, P.C. By Scott B. Cooper, Esquire I.D. No. 70242 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiff -5- VERIFICATION BASED UPON PERSONAL KNOWLEDGE AND INFORMATION SUPPLIED BY COUNSEL I, Ashley Dickinson, hereby verify that I am the Plaintiffs in the foregoing action and that the attached Complaint is based upon the information that has been gathered by my counsel in preparation of this lawsuit. The language of the Complaint is that of counsel and is not mine. I have read the Complaint, and to the extent that it is based upon information that I have given to counsel, it 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 have relied upon counsel in making this Verification. I understand that intentional false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsifications made to authorities. Date:_ C.Q- 6 -6S Ashley Di k' son ? I ? 'O 7 ra N SCHMIDT, RONCA & KRAMER, P.C. BY: Scott B. Cooper, ESQUIRE I.D. #70242 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorneys for Plaintiffs scooperasrklaw.com Ashley Dickinson, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. : CIVIL ACTION - LAW Curtis Ulrich, : No. 05-2941 Civil Term Defendant : JURY TRIAL DEMANDED PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY OF SAID COURT: Please reinstate Plaintiff's Complaint in the above-captioned action which was filed in your office on June 9, 2005. Respectfully submitted, SCHMIDT, RONCA & KRAMER, P.C. By: Scott B. ooper, Esquire I.D. No. 70242 Date: 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiff SCHMIDT, RONCA & KRAMER, P.C. BY: Scott B. Cooper, ESQUIRE I.D. #70242 209 State Street `-' Cz' LO Harrisburg, PA 17101 (717) 232-6300 = ?? Attorneys for Plaintiffs c scooper0srklaw.com Ashley Dickinson, IN THE COURT OF COMMON PLEAS 0 JIfl : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs CIVIL ACTION - LAW V. Curtis Ulrich, No. DS- ;t951/ ?tvc ???2i r? 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 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 AiSociation 32 S. Bedford Street Carlisle, PA 17013 SCHMIDT, RONCA & KRAMER, P.C. BY: Scott B. Cooper, ESQUIRE I.D. #70242 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorneys for Plaintiffs - scoopeit@srklaw.com Ashley Dickinson, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs CIVIL ACTION - LAW V. Curtis Ulrich, No. Defendant JURY TRIAL DEMANDED AVISO USTED HA SIDO DEMANDADO/A EN CORfE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despues de la notificaci6n de esta Demanda y Aviso radicando personalmente o por medio de un abogado una co:mparecencia 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 0 VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUUEDE 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 32 S. Bedford Street Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DICKINSON, IN THE COURT OF COMN Plaintiffs PLEAS CUMBERLAND COUNTY, V. PENNSYLVANIA CURTIS ULRICH, Defendant I : CIVIL ACTION - LAW NO. COMPLAINT AND NOW COMES, the Plaintiff, Ashley Dickinson, by and through her attorneys SCHMIDT, RONCA AND KRAMER, P.C. and hereby avers as follow: 1. The Plaintiff, Ashley Dickinson, is an adult individual who at all times relevant hereto has lived at 647 West Chestnut Street, Lancaster, Lancaster County, Pennsylvania 17603. 2. The Defendant, Curtis Ulrich, is an adult individual who at all times relevant hereto has lived at 107-A East Main Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The facts and occurrences hereinafter took place on or about June 17, 2003 on Lampeter Road in Lampeter Township, -1- Lancaster County Pennsylvania. 4. At the aforementioned time and place, the Plaintiff, Ashley Dickinson was a passenger in a vehicle being driven by her sister, Farran Dickinson. 5. At the aforementioned time and place, the Defendant, Curtis Ulrich, was traveling in the same direction, behind the Dickinson vehicle. 6. At the aforementioned time and place, the Defendant, Curtis Ulrich, rear-ended the Dickinson vehicle when causing the injuries to Ashley set forth below. COUNTI ASHLEY DICKINSON V. CURTIS ULRICH NEGLIGENCE 7. Paragraphs 1 through 6 of the Plaintiff Complaint are incorporated by reference and made a part thereof as if set forth in full. 8. The accident was caused by the negligence, carelessness and recklessness of the Defendant, and was in no way caused or contributed to by the Plaintiff. 9. The carelessness, negligence and recklessness of the Defendant consisted of the following: a. inattentiveness; -2- b. failing to keep a reasonable look out for other vehicles lawfully on the roadway; c. failing to have his vehicle under proper and adequate control; d. failing to apply his brakes in time to avoid the collision with the Dickinson vehicle; e. negligently applying his brakes; f. failing to observe the Dickinson vehicle lawfully on the roadway; g. failing to operate his vehicle in accordance with existing traffic conditions and traffic controls; h. operating his vehicle so as to create a dangerous situation for other vehicles on the roadway; i. operating his vehicle so that he could not stop within the assured clear distance ahead and; j. careless driving. 10. As a direct and proximate result of the accident and the Defendant's carelessness, negligence and recklessness, the Plaintiff, Ashley Dickinson sustained injuries which are serious and may be permanent including, but not limited to: a. lumbar strain; b. thoracic pain; and c. head pain. -3- 11. As a direct and proximate result of the injuries sustained in the motor vehicle accident, the Plaintiff has been advised and, therefore avers, that the aforementioned injuries may be permanent in nature and effect and, thus, a claim for these injuries is made. 12. As a direct and proximate result of the accident, the Plaintiff, and others on her behalf, have incurred medical expenses for the injuries she has sustained, and may continue to incur medical expenses into the future, and thus, a claim for these expenses is made. 13. As a direct and proximate result of the injuries sustained in the motor vehicle accident, the Plaintiff has undergone in the past, and may continue to undergo in the future, great pain and suffering, and thus, a claim for these losses is made. 14. As a direct and proximate result of the injuries sustained in the motor vehicle accident, the Plaintiff may have suffered a permanent diminution of her ability to enjoy life and life's pleasures, and thus, a claim for these losses is made. 15. As a direct and proximate result of the injuries sustained in the motor vehicle accident, the Plaintiff has suffered a real loss of wages, and may have suffered an impairment of her future -4- earning power and capacity, and thus, a claim for these losses is made. WHEREFORE, Plaintiff Ashley Dickinson demands judgment on the Defendant Curtis Ulrich in an amount in excess of Thirty-Five Thousand ($35,000.00) Dollars and in excess of an amount requiring compulsory arbitration. Respectfully Submitted, SCHMIDT, R.ONCA & KRAMER, P.C. By iz?/ Scott B. Cooper, Esquire I.D. No. 70242 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiff -5- VERIFICATION BASED UPON PERSONAL KNOWLEDGE AND INFORMATION SUPPLIED BY COUNSEL I, Ashley Dickinson, hereby verify that I am the Plaintiffs in the foregoing action and that the attached Complaint is based upon the information that has been gathered by my counsel in preparation of this lawsuit. The language of the Complaint is that of counsel and is not mine. I have read the Complaint, and to the extent that it is based upon information that I have given to counsel, it 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 have relied upon counsel in making this Verification. I understand that intentional false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsifications made to authorities. Date: \ n Ashley Di kinson r> ? p _ - ?-, cn -n ?-- .. L. sn rte-' -? ?-? .? ;?? :?: > c'; :_ ? >' ? -?, '-' cn '" as ASHLEY DICKINSON, Plaintiff V. CURTIS ULRICH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 05-2941 CIVIL TERM JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Curtis Ulrich, with regard to the above-captioned matter. Respectfully submitted, NEALON GOVER & PERRY By: 1.6.,c_ Ctrs G. hove, Esquire I.D. #: 85321 2411 North Front Street Harrisburg, PA 17110 717/232-9900 Date: dabczb CERTIFICATE OF SERVICE AND NOW, this )7'z' day of August, 2005, 1 hereby certify that I have served the foregoing Praecipe for Entry of Appearance on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Scott B. Cooper, Esquire Schmidt, Ronca & Kramer, P.C. 209 State Street Harrisburg, PA 17101 LzAL Cas . Shore, Esquire c'), c7 fell ,Z i? G : S 7 ^ O t 4 ? W tJ CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: DICKINSON -VS- ULRICH TERM, CUMBERLAND CASE NO: 05-2941 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, ES 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: 09/20/2005 COURT OF COMMON PLEAS /hCS n behalf o? CAS S E, ESQ. l Attorney for DEFENDANT DE11-595504 5 9 4 8 4- 1, 0 1 C O M M O N W E A L 'EH 01P P E N N S Y L VANS A COUNTY OP CUMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS DICKINSON -VS- ULRICH INTENT TO SERVE A FOR TERM, CASE NO: 05-2941 [ Note: see enclosed list of locations ) TO: SCOTT B. COOPER, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 08/31/2005 CC: CASEY SHORE, ESQ. - 05-613 MICHAEL SMOLUR - Any questions regarding this matter, contact MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-311215 5 9 4 8 4- C O 2 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED LANCASTER REGIONAL MED. CENTER LANCASTER REGIONAL MED. CENTER NOVACARE DR. DAVID LING LANCASTER EMERGENCY MED. SVCS. LANCASTER RADIOLOGY ASSOCIATES LANCASTER GENERAL HOSPITAL LANCASTER GENERAL HOSPITAL MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS 6 XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY DE02-311215 5 9 4 8 4- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DICKINSON vs. ULRICH File No. CUMBERLAND 05-2941 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for LANCASTER REGIONAL MED CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group Lac 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 the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CASEY SHORE. ESQ. ADDRESS: 2411 N FRONT ST HARRISBURG-PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: N/' Q l p -) C&S" Seal of the Court BY THE COURT- Prothonotary/, 1erkk, Ci tv Sion Deputy 59484-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: LANCASTER REGIONAL MED. CENTER 250 COLLEGE AVENUE LANCASTER, PA 17603 RE: 59484 ASHLEY DICKINSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : ASHLEY DICKINSON 340 WALTER AVE., LANCASTER, PA 17602 Social Security It: 185-66-1473 Date of Birth: 03-09-1986 SU10-580934 S 9 4 8 4- L O 1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: DICKINSON ULRICH COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 05-2941 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 09/20/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DE11-585505 59484-L 02 C O M M O N W E A L T H OP P E N N S Y L VAN T A COUNTY 0177 C UMBER LAN D IN THE MATTER OF: DICKINSON -VS- ULRICH COURT OF COMMON PLEAS TERM, CASE NO: 05-2941 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMffiNTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: SCOTT B. COOPER, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 08/31/2005 CC: CASEY SHORE, ESQ. - 05-613 MICHAEL SMOLUK - Any questions regarding this matter, contact MCS on behalf of CASEY SHORE, ESQ_ Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-311215 5 9 4 8 4- C O 2 ON NAME LANCASTER REGIONAL MED. CENTER LANCASTER REGIONAL MED. CENTER NOVACARE DR. DAVID LING LANCASTER EMERGENCY MED. SVCS. LANCASTER RADIOLOGY ASSOCIATES LANCASTER GENERAL HOSPITAL LANCASTER GENERAL HOSPITAL >> LOCATION LIST <<< RECORDS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY PAGE: I DE02-311215 5 9 4 8 4- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DICKINSON File No. CUMBERLAND 05-2941 vs. ULRICH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for LANCASTER REGIONAL MED CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The M Group Inc 1601 Market Street, it 800 Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CASEY SHORE. ESQ. ADDRESS: 2411 N. FRONT T HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/ erk, Ci iv Sion Deputy Date: Seal of the Court 59484-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: LANCASTER REGIONAL MED. CENTER 250 COLLEGE AVENUE LANCASTER, PA 17603 RE: 59484 ASHLEY DICKINSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : ASHLEY DICKINSON 340 WALTER AVE., LANCASTER, PA 17602 Social Security !/: 185-66-1473 Date of Birth: 03-09-1986 SU10-580936 59464-1,02 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS DICKINSON TERM, CUMBERLAND -VS- CASE NO: 05-2941 ULRICH As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, E certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 09/20/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DEII-585506 5 9 4 8 4- L 0 3 C O M M O N W E A L T H OF' P E N N S Y L VAN T A COUNTY OP C UM B E R L AN D IN THE MATTER OF: COURT OF COMMON PLEAS DICKINSON -VS- ULRICH NOTICE OF INTENT TERM, CASE NO: 05-2941 SUBPOENA TO PRODUCE D( PURSUANT [ Note: see enclosed list of locations ] TO: SCOTT B. COOPER, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 08/31/2005 CC: CASEY SHORE, ESQ. - 05-613 MICHAEL SMOLUK - Any questions regarding this matter, contact MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-311215 5 9 4 8 4- C 0 2 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED LANCASTER REGIONAL MED. CENTER LANCASTER REGIONAL MED. CENTER NOVACARE DR. DAVID LING LANCASTER EMERGENCY MED. SVCS. LANCASTER RADIOLOGY ASSOCIATES LANCASTER GENERAL HOSPITAL LANCASTER GENERAL HOSPITAL MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY DE02-311215 5 9 4 8 4- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DICKINSON vs. ULRICH File No. CUMBERLAND 05-2941 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for NOVACARF (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 M Group- Inc- 1601 Market Street, Snrtr 800 Philad ]nhia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena,-together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CASEY SHORE. ESO. ADDRESS: 2411 N FRONT T HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/C rk, Ci t Divis n Date: Deputy ((Q ? ? ?(?? Seal of the Court 59484-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: NOVACARE 327 N. DUKE STREEET LANCASTER, PA 17602 RE: 59484 ASHLEY DICKINSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : ASHLEY DICKINSON 340 WALTER AVE., LANCASTER, PA 17602 Social Security #: 185-66-1473 Date of Birth: 03-09-1986 SU10-580538 59484-1,03 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: DICKINSON ULRICH COURT OF COMMON PLEAS TERM, CUMBERLAND -v5- CASE NO: 05-2941 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 09/20/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DE11-58550 59484-L 04 C O M M O N W E A L T H OF, P E N N S Y L VAN TA COUNTY OP C UM B E R L AND IN THE MATTER OF: COURT OF COMMON PLEAS DICKINSON -VS- ULRICH NOTICE OF INTE TERM, CASE NO: 05-2941 3 A SUBPOENA TO PRODUCE DOCI PURSUANT [ Note: see enclosed list of locations ] TO: SCOTT B. COOPER, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 08/31/2005 CC: CASEY SHORE, ESQ. - 05-613 MICHAEL SMOLUK - Any questions regarding this matter, contact MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-311215 5 9 4 8 4- C O 2 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED LANCASTER REGIONAL MED. CENTER LANCASTER REGIONAL MED. CENTER NOVACARE DR. DAVID LING LANCASTER EMERGENCY MED. SVCS. LANCASTER RADIOLOGY ASSOCIATES LANCASTER GENERAL HOSPITAL LANCASTER GENERAL HOSPITAL MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY DE02-311215 5 94 84 -C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DICKINSON vs. ULRICH File No. CUMBERLAND 05-2941 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. DAVID LING (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 800 Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CASEY SHORE. ESQ. ADDRESS: 2411 N. FRONT ST. HARRISBURG: PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/C1 rk, Civi t ion Date: Deputy Seal of the Court 59484-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. DAVID LING 322 N. ARCH STREET LANCASTER, PA 17604 RE: 59484 ASHLEY DICKINSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : ASHLEY DICKINSON 340 WALTER AVE., LANCASTER, PA 17602 Social Security N: 185-66-1473 Date of Birth: 03-09-1986 SU10-580940 S 9 4 8 4- L 04 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: DICKINSON ULRICH COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 05-2941 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 09/20/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DE11-585508 5 9 4 8 4- L 0 S C O M M O N W E A L T H OF' P E N N S Y L VANS A COUNTY OF' C UMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS DICKINSON -VS- ULRICH TERM, CASE NO: 05-2941 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 1 TO: SCOTT B. COOPER, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 08/31/2005 CC: CASEY SHORE, ESQ. - 05-613 MICHAEL SMOLUK - Any questions regarding this matter, contact MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-311215 5 9 4 8 4- C O 2 >>> LOCATION LIST << PAGE: 1 LOCATION NAME RECORDS REQUESTED LANCASTER REGIONAL MED. CENTER LANCASTER REGIONAL MED. CENTER NOVACARE DR. DAVID LING LANCASTER EMERGENCY MED. SVCS. LANCASTER RADIOLOGY ASSOCIATES LANCASTER GENERAL HOSPITAL LANCASTER GENERAL HOSPITAL MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY DE02-311215 5 9 4 8 4- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DICKINSON File No. CUMBERLAND 05-2941 vs. ULRICH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for LANCASTER EMERGENCY MED. SVCS. (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 800 Philadelphia- PA 1910 You may deliver or mail legible copies of the documents or produce things requested by this subpoena; together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CASEY SHORE. ES ADDRESS: 2411 N. FRONT ST_ TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Cl k, Civ to Date: (? 1'P Deputy ? Seal of the Court 59484-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: LANCASTER EMERGENCY MED. SVCS. 100 E. CHARLOTTE ST. MILLERSVILLE, PA 17751 RE: 59484 ASHLEY DICKINSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medic ation/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : ASHLEY DICKINSON 340 WALTER AVE., LANCASTER, PA 17602 Social Security #: 185-66-1473 Date of Birth: 03-09-1986 SU10-580942 5 94 8 4- L O 5 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: DICKINSON ULRICH COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 05-2941 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 09/20/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DE11-585509 5 9 4 8 4- L 0 6 C O M M O N W E A L T H O F P E N N S Y L VANS A COUNT Y OF, C UM B E R L AN D IN THE MATTER OF: COURT OF COMMON PLEAS DICKINSON TERM, -VS- CASE NO: 05-2941 ULRICH 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: SCOTT H. COOPER, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served- Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 08/31/2005 CC: CASEY SHORE, ESQ. - 05-613 MICHAEL SMOLUK - MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-311215 5 9 4 8 4- C 0 2 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED LANCASTER REGIONAL MED. CENTER LANCASTER REGIONAL MED. CENTER NOVACARE DR. DAVID LING LANCASTER EMERGENCY MED. SVCS. LANCASTER RADIOLOGY ASSOCIATES LANCASTER GENERAL HOSPITAL LANCASTER GENERAL HOSPITAL MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS 6 XRAYS MEDICAL RECORDS 6 XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY DE02-311215 5 9 4 8 4- C 0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DICKINSON vs. ULRICH File No. CUMBERLAND 05-2941 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for LANCASTER RADIOLOGY ASSOCIATES (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at 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 the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CASEY SHORE. ESO. ADDRESS: 2411 N. FRONT ST. HARRISBURG-PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Cl rk, Civil son l , Date: , Deputy Sea] of the Court 59484-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR LANCASTER RADIOLOGY ASSOCIATES 2260 ERIN COURT STE C PO BOX 3216 LANCASTER, PA 176013 RE: 59484 ASHLEY DICKINSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to' any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : ASHLEY DICKINSON 340 WALTER AVE., LANCASTER, PA 17602 Social Security N: 185-66-1473 Date of Birth: 03-09-1986 SU10-580944 59484-L,06 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS DICKINSON TERM, CUMBERLAND -vs- CASE NO: 05-2941 ULRICH As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, E certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 09/20/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DE11-585510 5 94 84 -L Q 7 C O M M O N W E A L T H OF P E N N S Y L,VAN T -A, COUNTY OF' C UMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS DICKINSON -VS- ULRICH TERM, CASE NO: 05-2941 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUKffiTPS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ) TO: SCOTT B. COOPER, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 08/31/2005 CC: CASEY SHORE, ESQ. - 05-613 MICHAEL SMOLUR - MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-311215 5 9 4 8 4- C 0 2 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED LANCASTER REGIONAL MED. CENTER LANCASTER REGIONAL MED. CENTER NOVACARE DR. DAVID LING LANCASTER EMERGENCY MED. SVCS. LANCASTER RADIOLOGY ASSOCIATES LANCASTER GENERAL HOSPITAL LANCASTER GENERAL HOSPITAL MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY DE02-311215 5 94 84 -C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DICKINSON vs. ULRICH File No. CUMBERLAND 05-2941 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for LANCASTER GENERAL HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things:- **** SEE ATTACHED RIDER **** at The MCS 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 the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CASEY SHORE. ESQ. ADDRESS: 2411 N. FRONT ST HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: O Prothonotary/CI rk, Cid tvis on Date: IP 'lc.( &?^ - Deputy Seal of the Court 59484-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR LANCASTER GENERAL HOSPITAL 555 N. DUKE STREET P.O. BOX 3555 LANCASTER, PA 17604 RE: 59484 ASHLEY DICKINSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : ASHLEY DICKINSON 340 WALTER AVE., LANCASTER, PA 17602 Social Security /1: 185-66-1473 Date of Birth: 03-09-1986 SU10-580946 59484-L,07 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: DICKINSON ULRICH COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 05-2941 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 09/20/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DE11-585511 59484-11,08 C O M M O N W E A L T H OF, P E N N S Y L VAN T A COUNT Y OP C UM B E R L AN D IN THE MATTER OF: COURT OF COMMON PLEAS DICKINSON -VS- ULRICH TERM, CASE NO: 05-2941 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: SCOTT B. COOPER, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 08/31/2005 CC: CASEY SHORE, ESQ. - 05-613 MICHAEL SMOLUK - MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-311215 5 9 4 8 4- C 0 2 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED LANCASTER REGIONAL MED. CENTER LANCASTER REGIONAL MED. CENTER NOVACARE DR. DAVID LING LANCASTER EMERGENCY MED. SVCS. LANCASTER RADIOLOGY ASSOCIATES LANCASTER GENERAL HOSPITAL LANCASTER GENERAL HOSPITAL MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS 6 XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY DE02-311215 S 94 84 -C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY- OF CUMBERLAND DICKINSON vs. ULRICH File No. CUMBERLAND 05-2941 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for LANCASTER GENERAL HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS GrojW. Inc.- 1601 Market Street. Suite 500. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena; together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CASEY SHORE. ESQ. ADDRESS: 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Cl rk, Civil on Date: Deputy Seal of the Court 59484-08 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: LANCASTER GENERAL HOSPITAL 555 N. DUKE STREET P.O. BOX 3555 LANCASTER, PA 17604 RE: 59484 ASHLEY DICKINSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : ASHLEY DICKINSON 340 WALTER AVE., LANCASTER, PA 17602 Social Security #: 185-66-1473 Date of Birth: 03-09-1986 SU10-580948 5 9 4 8 4- L 0 8 r? Q ('? = -C1 _ + ?? { ? ? ` rr^r?? ? ? ? C7 ; ; it j .? tom ? :'< t? ? ASHLEY DICKINSON, Plaintiff V. CURTIS ULRICH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 05-2941 CIVIL TERM JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Ashley Dickinson and her attorney Scott B. Cooper, Esquire Schmidt, Ronca & Kramer, P.C. 209 State Street Harrisburg, PA 17101 YOU ARE HEREBY NOTIFIED to file a response to the enclosed New Matter within twenty (20) days of service hereof. Failure by you to do so may constitute an admission. By Respectfully submitted, NEALON GOVER & PERRY Ca esp. Shore, Esquire Attorney I.D. No. 85321 2411 North Front St. Harrisburg, PA 17110 Date: ?.5 (717) 232-9900 ASHLEY DICKINSON, Plaintiff V. CURTIS ULRICH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 05-2941 CIVIL TERM JURY TRIAL DEMANDED ANSWER TO COMPLAINT WITH NEW MATTER 1-4. Admitted based upon information and belief. 5-6. Neither admitted nor denied. Discovery is ongoing in this matter and the Defendant is presently without sufficient information to form a belief as to the truth of these averments. To the extent an answer is required, the averments are denied. COUNTI 7. No answer required. 8-15. Denied pursuant to Rule 1029(e) of the Pennsylvania Rules of Civil Procedure. WHEREFORE, the Defendant, Curtis Ulrich, respectfully requests that the Complaint against him be dismissed with costs to be paid by the Plaintiff. NEW MATTER 16. Paragraphs 1-15 are incorporated herein as if reference were made thereto. 17. The Plaintiff's claims may be barred in whole or in part by application of the Pennsylvania Motor Vehicle Financial Responsibility Act. WHEREFORE, the Defendant respectfully requests that the Complaint be dismissed with costs to be paid by the Plaintiff. Respectfully submitted, NEALON GOVER & PERRY By: sae C 1?? C;se ?G. hore, Esquire I, D. x'85321 2411 North Front Street Harrisburg, PA 17110 717/232-9900 Date: 'f a2 ccas VERIFICATION I, CURTIS ULRICH, verify that the statements made in the foregoing ANSWER TO COMPLAINT WITH NEW MATTER are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: Zo-? ( Z/j CURTIS ULRICH CERTIFICATE OF SERVICE AND NOW, this 271:jt day of September, 2005, 1 hereby certify that I have served the foregoing Praecipe for Entry of Appearance on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Scott B. Cooper, Esquire Schmidt, Ronca & Kramer, P.C. 209 State Street Harrisburg, PA 17101 Case Shore, Esquire .4 T G.h, t SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2005-02941 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DICKINSON ASHLEY VS ULRICH CURTIS R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: ULRICH CURTIS but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of LANCASTER serve the within COMPLAINT & NOTICE County, Pennsylvania, to On August 12th , 2005 , this office was in receipt of the attached return from LANCASTER Sheriff's Costs: So answer;;, Docketing 18.00 Out of County 9.00 Surcharge 10.00 R. Thomas Kline Lancaster County 47.03 Sheriff of Cumberland County .00 84.03 08/12/2005 SCHMIDT RONCA KRAMER Sworn and subscribed to before me this oo?R? day of 44,4(a? ?p A.D. Pr nota 113040 fit ? ' SHERIFF'S OFFICE 3 H 50 NORTH DUKE STREET, P.O. BOX 83480, LANCASTER, PENNSYLVANIA 17608-3480 a (717) 299-8200 ^ SHERIFF SERVICE 0, ; E OR PRINT L& l i PROCESS RECEIPT, and AFFIDAVIT OF RETURN DO NQT` CH ANY C a 1 PLAINTfFF/S/ - 2 COURT NUMBER Ashley Dickinson 05-2941 civil m 3. DEFENDANT/S/ 4 TYPE OF WRIT OR COMPLAINT Curtis Ulrich Notice and Ccmplaint SERVE 5 NAME OF INDIVIDUAL, COMPANY. CORPORATION, ETC. TO BE SERVED 0 Curtis Ulrich fi ADDRESS (Street or RFD, Apartment No. City, Boo, Twp_ State and ZIP Code) AT 291 W Fulton Street New Holland PA 17557 7. INDICATE UNUSUAL SERVICE: El DEPUTIZE ? OTHER Now, Jul 7 20 05 I, SHERIFF OF-t COUNTY, PA., do hereby deputize the Sheriff of ancas er County to execute this Writ a urn thereof g to law. This deputation being made at the request and risk of the plaintiff. -S Ear T FIES -J co r- S. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: Curnberland Please mail return of service to Cumberland County Sheriff. Thank you. NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave Same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss. destruction or removal of any such property before sheriffs sale thereof S. SIGNATURE of ATTORNEY or other ORIGINATOR 10. TELEPHONE NUMBER 11. DATE SCOTT B.000PER ESO. 717-232-6300 7/14/05 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed) SCHMIDT RONCA, & KRAMER 209 STATE ST. HARRISBURG, PA. 17101 13 1 acknowledge receipt of the writ t NAME of Authorized LCSO Deputy or Clerk 14. Date Received IS . Expiration/Hearing date or complain) asindicated above ( JACKIE MICCICHE 717-299-8200 7/25/05 8/15/05 16. 1 hereby CERTIFY and RETURN that I aye personally served. ? have legal evidence of service as shown in "Remarks', ? have executed as shown in "Remarks", the writ or complaint des d on the individual, company, corporation ,etc_ at the address shown above or on the individual company cor- poration. elc.. at the address inserted below by handing a TRUE and ATTESTED COPY thereof. 17. ? 1 hereby certify and return a NOT FOUND because I am unable to locate the intlivitlual, company, corporation, etc.. named above. (See remarks below) 18 Name and title of individual served (if not shown above) (Relationship to r efendanp 19 ?No Service S. Remarks Beim (No. 30) 20 Address of where served (complete only if different the win above) teI*r RFD, Apartment No .City.Boro.Twp State and Zip Code) ryrl o 1 - v 30 LCn-- lr-c?,C 0 - (-I 0(-?- 21 Date of Service y l...a 22 Time `,,• 5 Zi -ED ST 23. ATTEMPTS pjt Miles Dep Int. Date Miles pop. Int. DNe Miles Dep. Int. Dote Miles Dep. Int. Date Miles Dep. Int. 24. Advance Costs 25. Service Costs 26. Notary Cad 27 Mileage/Postage/N. F. 28 Total Costs 29 COST DUE OR REFUND IuG?- 30. REMARKS:- S.T.A. 31. AFFIRMED and subscribed to before 34. day of IN THE COURT OF COMD Plaintiffs CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW CURTIS ULRICH, Defendant I : l NO. 05-2941 JURY TRIAL PLEAS PLAINTIFF'S REPLY TO DEFENDANT'S NEW MATTER 16. Paragraph 16 is not directed towards answering Plaintiff and, thus, no response is required. By way of further answer, if a responsive pleading is deemed required, the Plaintiff incorporates the allegations and facts and circumstances of her Complaint as set forth in full. 17. Paragraph 17 is a conclusion of law to which no response is deemed required. By way of further answer, if a responsive pleading is deemed required, the Plaintiff denies the allegations in paragraph 17 and demands strict proof thereof from the Defendant prior to trial. WHEREFORE, the Plaintiff respectfully requests that the Defendant's New Matter be dismissed with prejudice and that the relief requested in her Complaint be awarded. Date: ? 0/-, Respectfully Submitted, J SCHMIDT, RONCA & KRAMER, P.C. By: Scott B. Cooper, Esquire I.D. No. 70242 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiff ATTORNEY VERIFICATION I, Scott B. Cooper, Esquire, verify that I am attorney of record for the Plaintiff. I verify that the facts contained in the foregoing Plaintiffs Reply to Defendant's New Matter are true and correct to the best of my knowledge, information and belief. I understand that intentional false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsifications to authorities. Date: ",O //L) Scott B. Cooper CERTIFICATE OF SERVICE 41 AND NOW, this J day of COL) 2005, I hereby certify that I have, this day, caused a copy of the foregoing Plaintiff's Reply to Defendant's New Matter to be served by deposit in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: First Class Mail: Casey Shore, Esquire Nealon Gover & Perry 2411 North Front Street Harrisburg, Pa 17110 Schmidt, Ronca, & Kramer, P.C. By: Scott B. Cooper, Esquire I.D.# 70242 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiff T? (? ?, 1'.N ? ? _ ???4 ?„-. ti?? ?7 - 1 ?? ` ti ?\ Curtis R. Long Prothonotary office of the Protbonotarp uCumberralab Couutp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor - CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2 BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573