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HomeMy WebLinkAbout05-3491IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 0. Civil Action (X) Law ()Equity IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND 1402 KAREN L. Bradley y Drive H Drive 2 Grandview Court : Mechanicsburg, PA 17055 Carlisle, PA 17013 Plaintiff(s) & Address(es) Defendant(s) & Address(es) PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue a Writ of Summons in the above-captioned action. X A Writ of Summons shall be issued and forwarded to ( ) Attorney ( )Sheriff. Gerard C. Kramer, Esquire Schmidt, Ronca &a Kramer, P.C. 209 State Street Harrisburg, PA 17101 -'? (717) 232-6300 ignature of Attorney Date: ??5 I C?5 Supreme Court I.D. No. 44715 WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT: YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. Date: ) Check here if reverse is issued for additional information ? -6a ? ? ? a C- o ? a T r ? i is h? 7T? _. c? SHERIFF'S RETURN - REGULAR CASE NO: 2005-03491 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LOVARI IRMA J ET VS HALSEY KAREN L MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon HALSEY KAREN L DEFENDANT the , at 1405:00 HOURS, on the 13th day of July , 2005 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to KAREN L HALSEY BRADSHAW a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service .00 Postage .37 Surcharge 10.00 .00 28.37 Sworn and Subscribed to before me this jq day of A. D. 'P othonotary So Answers: R. Thomas Kline 07/14/2005 SCHMIDT RONCA KRAMER By: Deputy S eriff IRMA J. LOVARI and FRANK J. LOVARI, her husband, Plaintiffs V. KAREN L. HALSEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3491 CIVIL ACTION - LAW JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the undersigned on behalf of Defendant, Karen L. Halsey, in the above captioned case. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN BY: ,STEPHEN J. BARCAVAGE, ESQUIRE I.D. No. 78867 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3506 DATE: 1(m1 bg Attorneys for Defendant Karen L. Halsey CERTIFICATE OF SERVICE I, Susan M. Williams, an employee with the law firm of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this a q+) day of -Z' 2005,1 served a true and correct copy of the foregoing document via U.S. first-ca ass mail, postage pre- paid, as follows: Gerard C. Kramer, Esquire Schmidt, Ronca & Kramer, P.C. 209 State Street Harrisburg, PA 17101 'Q1 O . A , R O'i ul 4 oa?A? SUSAN M. WILLIAMS ?? iy i", _. --, "f ? ? . r? ..-1 ? ? 4; _ C+: ?? L ?-' : ?a IRMA J. LOVARI and FRANK J. LOVARI, her husband, Plaintiffs V. KAREN L. HALSEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3491 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE A COMPLAINT TO THE PROTHONOTARY: Kindly issue a Rule upon the Plaintiffs to file a Complaint within twenty (20) days hereof or suffer judgment non pros. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN BY STEPHEN J. BARCAVAGE, ESQUIRE I.D. No. 78867 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3506 DATE: ?'7I Ds- Attorneys for Defendant Karen L. Halsey CERTIFICATE OF SERVICE I, Susan M. Williams, an employee with the law firm of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this c?`}1h day of , 2005, I served a true and correct copy of the foregoing document via U.S. first-class mail, postage pre- paid, as follows: Gerard C. Kramer, Esquire Schmidt, Ronca & Kramer, P.C. 209 State Street Harrisburg, PA 17101 SUSAN M. WILLIAMS c^ rya _ , _ ?`) u? -iI ? ? ?_ J- ? -_ f- Gi -,l ', It (_ I1 ' => _71 N IRMA J. LOVARI and FRANK J. LOVARI, her husband, Plaintiffs V. KAREN L. HALSEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3491 CIVIL ACTION - LAW JURY TRIAL DEMANDED RULE AND NOW, this 3!K' y of 2005, upon consideration of the foregoing Praecipe, a Rule is hereby issued upon the Plaintiffs, Irma J. Lovari and Frank J. Lovari, to file a Complaint within twenty (20) days or suffer judgment of non pros. BY THE PROTHONOTARY: SEAL IRMA LOVARI and FRANK : IN THE COURT OF COMMON PLEAS LOVARI, Jr., her husband, : OF CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiffs V. CIVIL ACTION - LAW KAREN L. HALSEY NO. Defendants 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 ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IRMA LOVARI and FRANK LOVARI, Jr., her husband, Plaintiffs V. KAREN L. HALSEY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. Defendants : 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 accion dentro de los proximos veinte (20) dias despues de la notificacion 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 accion 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 reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IRMA LOVARI and FRANK IN THE COURT OF COMMON PLEAS LOVARI, Jr., her husband, OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. CIVIL ACTION - LAW KAREN L. HALSEY NO. Defendants JURY TRIAL DEMANDED COMPLAINT AND NOW, comes the Plaintiffs, Irma Lovari and Frank Lovari, by and through their attorneys, SCHMIDT, RONCA 8s KRAMER, P.C., and respectfully sets forth as follows: 1. Plaintiffs Irma Lovari and Frank Lovari are adult individuals currently residing at 2 Grandview Court, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant Karen Halsey is an adult individual currently residing at 1402 Bradley Drive, Carlisle, Cumberland County, Pennsylvania, 17013. 3. The facts and events hereinafter stated took place on or about August 22, 2003 at 3:19 p.m., on Rt. 15 (south) in Camp Hill, Cumberland County, Pennsylvania. 4. At the aforementioned time and place, Plaintiff Irma Lovari was driving south on Route 15 in Camp Hill. 5. At the aforementioned time and place, Defendant Karen L. Halsey was traveling behind Plaintiff Irma Lovari. 6. The rear-end collision occurred when Defendant Karen L. Halsey failed to observe Plaintiff Irma Lovari and collided with her vehicle. 7. The collision caused the injuries to the Plaintiffs as set forth below. COUNT I IRMA LOVARI v. KAREN L. HALSEY 8. Paragraphs 1 through 7 of the Plaintiff's complaint are incorporated herein by reference and made a part thereof as if set forth in full. 9. The accident was caused by the negligence and carelessness of Defendant Karen L. Halsey and was in no way caused or contributed to by Plaintiff Irma Lovari. 10. The negligence and carelessness of Defendant Karen L. Halsey consisted of the following: a. inattentiveness; b. failing to have her vehicle under proper and adequate control; C. negligently applying the brakes; d. failing to apply the brakes in time to avoid the collision; e. failing to observe the vehicle driven by Irma Lovari lawfully on the roadway; f. operating the vehicle at an excessive rate of speed under the circumstances; g. violating the assured clear distance rule; h. failing to operate the vehicle in accordance with existing traffic conditions and traffic controls; i. failing to keep a reasonable lookout for other vehicles lawfully on the roadway; j. operating her vehicle so as to create a dangerous situation for other vehicles on the roadway; and k. following too closely. 11. As a factual result of the accident, Plaintiff Irma Lovari suffered injuries which are severe and what are believed to be permanent, which include the following: a. lumbar strain; b. cervical strain; C. myofascial pain; d. exacerbation of headaches; and e. post traumatic stress directly related to the accident. 12. As a factual result of the accident, Plaintiff Irma Lovari, has incurred medical expenses to date and will continue to incur medical expenses into the future, and thus, a claim for these expenses is made. 13. As a factual result of the accident, Plaintiff Irma Lovari 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. 14. As a factual result of the accident, Plaintiff Irma Lovari has undergone in the past, and will continue to undergo in the future, great pain and suffering, and thus, a claim for these injuries is made. 15. As a factual result of the accident, Plaintiff Irma Lovari has been obliged to spend various sums of money and to incur various expenses for the injuries that she has suffered and may continue to incur the same in the future, and thus, a claim for these losses is made. 16. As a factual result of the accident, Plaintiff Irma Lovari suffered a loss of earnings and an impairment of her earning power and capacity in the future, and thus, a claim for these losses is made. 17. As a factual result of the accident, Plaintiff Irma Lovari suffered a permanent diminution of her ability to enjoy life and life's pleasures, and thus, a claim for these losses is made. WHEREFORE, Plaintiff Irma Lovari demands judgment on Defendant Karen L. Halsey in an amount in excess of an amount requiring compulsory arbitration. COUNT II FRANK LOVARI V. KAREN L. HALSEY LOSS OF CONSORTIUM 18. Paragraphs 1 through 17 of the Plaintiffs' Complaint are incorporated herein by reference and made a part thereof as if set forth in full. 19. Plaintiff Frank Lovari has suffered from the loss of services and companionship and consortium of his wife, Plaintiff Irma Lovari as a factual result of the negligence of Defendant Karen L. Halsey. WHEREFORE, Plaintiff Frank Lovari demands judgment on Defendant Karen L. Halsey in an amount in excess of an amount requiring compulsory arbitration. DATED: of Wo Respectfully submitted, SCHMIDT, RONCA & KRAMER, P.C. Gerard C. Kramer Attorney at Law I.D. no. 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs VERIFICATION BASED UPON PERSONAL KNOWLEDGE AND INFORMATION OBTAINED THROUGH COUNSEL I, IRMA LOVARI, verify that I am the Plaintiff in the foregoing action and that the attached Complaint is based upon information which has been gathered by my counsel in the preparation of this lawsuit. The language of the Complaint to the extent that it is based upon information that I have given to my counsel is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the Complaint are that of counsel, I relied upon counsel making this Verification. I understand that intentional false statements herein are subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsifications to authorities. Date: d ?J° lr/?x d? D ,?i IRMA LOVARI CERTIFICATE OF SERVICE AND NOW, this 16 day of , 2005, I, Gerard C. Kramer, Esq., hereby certify that I have this day served a true and correct copy of the Complaint by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Stephen J. Barcavage, Esquire Marshall, Dennehey, Warner, Coleman & Goggin 4200 Crums Mill Road, Ste. B Harrisburg, PA 17112 Respectfully submitted, SCHMIDT, RONCA & KRAMER, P.C. By:,9,cy4-d <. lCru, 1 c?c Gerard C. Kramer, Esquire I.D. No. 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs f7 N p ? -r? C cry T±: ?i n -- c... r ? as "' C) r {'": .. -5 . -t'. .. ?y"- ? ri .? L.. ? _? W IRMA J. LOVARI and FRANK J. LOVARI, her husband, Plaintiffs V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3491 CIVIL ACTION - LAW KAREN L. HALSEY, Defendant JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Irma J. Lovari and Frank J. Lovari, her husband, Plaintiffs c/o Gerard C. Kramer, Esquire Schmidt, Ronca & Kramer, P.C. 209 State Street Harrisburg, PA 17101 You are hereby notified to plead to the enclosed New Matter within twenty (20) days from service hereof or a default judgment may be filed against you. DATE: BlSl?O;' MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN J. BARCAVAGE, ESQUIRE I.D. No. 78867 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3506 BY: TEPHEN Attorneys for Defendant Karen L. Halsey IRMA J. LOVARI and FRANK J. LOVARI, her husband, Plaintiffs V. KAREN L. HALSEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3491 CIVIL ACTION - LAW JURY TRIAL DEMANDED ANSWER WITH NEW MATTER OF DEFENDANT, KAREN L. HALSEY, TO PLAINTIFFS' COMPLAINT NOW COMES Defendant, Karen L. Halsey, by and through her attorney, who files this response to Plaintiffs' Complaint and answers the Complaint as follows: Denied. Defendant lacks knowledge sufficient to form a belief as to the truth of the allegations contained in paragraph 1, and therefore, the same are denied with strict proof thereof required at trial. 2. Denied. Defendant lacks knowledge sufficient to form a belief as to the truth of the allegations contained in paragraph 2, and therefore, the same are denied with strict proof thereof required at trial. Denied. Defendant lacks knowledge sufficient to form a belief as to the truth of the allegations contained in paragraph 3, and therefore, the same are denied with strict proof thereof required at trial. 4. Denied. Defendant lacks knowledge sufficient to form a belief as to the truth of the allegations contained in paragraph 4, and therefore, the same are denied with strict proof thereof required at trial. 5. Denied. Defendant lacks knowledge sufficient to form a belief as to the truth of the allegations contained in paragraph 5, and therefore, the same are denied with strict proof thereof required at trial. 6. Denied. Paragraph 6 is denied in that the same contains conclusions of law to which no response is required; therefore, strict proof is required at trial. By way of further response, Defendant lacks knowledge sufficient to form a belief as to the truth of the allegations contained in paragraph 6, and therefore, the same are denied with strict proof thereof required at trial. Denied. Paragraph 7 is denied in that the same contains conclusions of law to which no response is required; therefore, strict proof is required at trial. By way of further response, Defendant lacks knowledge sufficient to form a belief as to the truth of the allegations contained in paragraph 7, and therefore, the same are denied with strict proof thereof required at trial. COUNT I IRMA LOVARI V. KAREN L. HALSEY NEGLIGENCE & Defendant hereby incorporates by reference her answers to Paragraphs 1-7 as if fully set forth herein. 9. Denied. Paragraph 9 is denied in that the same contains conclusions of law to which no response is required; therefore, strict proof is required at trial. By way of further response, Defendant lacks knowledge sufficient to form a belief as to the truth of the allegations 2 contained in paragraph 9 and therefore, the same are denied with strict proof thereof required at trial. 10.(a) - (k). Denied. Paragraph 10 (a) - (k) is denied in that the same contains conclusions of law to which no response is required; therefore, strict proof is required at trial. By way of further response, Defendant lacks knowledge sufficient to form a belief as to the truth of the allegations contained in paragraph 10 (a) - (k), and therefore, the same are denied with strict proof thereof required at trial. 11.(a) - (e). Denied. Paragraph 11 (a) - (e) is denied in that the same contains conclusions of law to which no response is required; therefore, strict proof is required at trial. By way of further response, Defendant lacks knowledge sufficient to form a belief as to the truth of the allegations contained in paragraph 11 (a) - (c), and therefore, the same are denied with strict proof thereof required at trial. 12. Denied. Paragraph 12 is denied in that the same contains conclusions of law to which no response is required; therefore, strict proof is required at trial. By way of further response, Defendant lacks knowledge sufficient to form a belief as to the truth of the allegations contained in paragraph 12 and therefore, the same are denied with strict proof thereof required at trial. 13. Denied. Paragraph 13 is denied in that the same contains conclusions of law to which no response is required; therefore, strict proof is required at trial. By way of further response, Defendant lacks knowledge sufficient to form a belief as to the truth of the allegations contained in paragraph 13 and therefore, the same are denied with strict proof thereof required at trial. 14. Denied. Paragraph 14 is denied in that the same contains conclusions of law to which no response is required; therefore, strict proof is required at trial. By way of further response, Defendant lacks knowledge sufficient to form a belief as to the truth of the allegations contained in paragraph 14 and therefore, the same are denied with strict proof thereof required at trial. 15. Denied. Paragraph 15 is denied in that the same contains conclusions of law to which no response is required; therefore, strict proof is required at trial. By way of further response, Defendant lacks knowledge sufficient to form a belief as to the truth of the allegations contained in paragraph 15 and therefore, the same are denied with strict proof thereof required at trial. 16. Denied. Paragraph 16 is denied in that the same contains conclusions of law to which no response is required; therefore, strict proof is required at trial. By way of further response, Defendant lacks knowledge sufficient to form a belief as to the truth of the allegations contained in paragraph 16 and therefore, the same are denied with strict proof thereof required at trial. 17. Denied. Paragraph 17 is denied in that the same contains conclusions of law to which no response is required; therefore, strict proof is required at trial. By way of further response, Defendant lacks knowledge sufficient to form a belief as to the truth of the allegations contained in paragraph 17 and therefore, the same are denied with strict proof thereof required at trial. 4 WHEREFORE, Defendant, Karen L. Halsey, respectfully requests judgment in her favor and against the Plaintiffs together with such other costs this Honorable Court deems appropriate. COUNT II FRANK LOVARI V. KAREN L. HALSEY LOSS OF CONSORTIUM 18. Defendant hereby incorporates by reference her answers to Paragraphs 1-17 as if fully set forth herein. 19. Denied. Paragraph 19 is denied in that the same contains conclusions of law to which no response is required; therefore, strict proof is required at trial. By way of further response, Defendant lacks knowledge sufficient to form a belief as to the truth of the allegations contained in paragraph 19, and therefore, the same are denied with strict proof thereof required at trial. WHEREFORE, Defendant, Karen L. Halsey, respectfully requests judgment in her favor and against the Plaintiffs together with such other costs this Honorable Court deems appropriate. NEW MATTER 20. Defendant hereby incorporates by reference her answers to Paragraphs 1-19 as if fully set forth herein. 21. Plaintiffs' claims are barred by the applicable statute of limitations. 22. Plaintiffs have failed to state a cause of action upon which relief can be granted. 23. Plaintiffs' claims are barred and/or limited by all applicable provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law. 24. No act or omission on the part of Defendant was a substantial or contributing factor in bringing about Plaintiffs' alleged injuries and/or damages, all such injuries and/or damages being expressly denied. 25. Any and all injuries and or damages as described in Plaintiffs' Complaint, the same being expressly denied, were caused in whole or in part by the acts or omissions on the part of Plaintiffs and/or others over whom Defendant had no control nor right of control. 26. Plaintiffs' claims are barred and/or limited by the doctrine of res judicata and/or collateral estoppel. 27. Plaintiffs' claims are derivative in nature and are barred as a matter of law. 28. Defendant breached no duty of care owed to Plaintiffs under the circumstances. 29. Plaintiffs' claims are barred and/or limited by the Pennsylvania Comparative Negligence Act. 30. Plaintiffs' claims are barred and/or limited by the; applicable provisions of the Pennsylvania Worker's Compensation Act. 31. At all times material hereto, Defendant acted in a safe, legal and non-negligent manner. 32. Plaintiffs' Complaint and/or claims may be barred by Plaintiffs' selection of limited tort on the applicable automobile insurance policy as set forth by 75 Pa.C.S.A. § 1705. WHEREFORE, Defendant, Karen L. Halsey, respectfully requests judgment in her favor and against the Plaintiffs together with such other costs this Honorable Court deems appropriate. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN BY: VAGE, ESQUIRE I.D. > Mill Road, Suite B PA 17112 (717) 651-3506 Attorneys for Defendant Karen L. Halsey DATE:? 1311 DJ? VERIFICATION The undersigned hereby verifies that the statements in the foregoing Answer with New Matter to Plaintiffs' Complaint are based upon information which has been furnished to counsel by me and information which has been gathered by counsel in the preparation of the defense of this lawsuit. The language of the Answer with New Matter to Plaintiffs' Complaint is that of counsel and not my own. I have read the Answer with New Matter to Plaintiffs' Complaint, and to the extent that it is based upon information which 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 Answer with New Matter to Plaintiffs' Complaint are that of counsel, I have relied upon my counsel in making this verification. The undersigned also understands that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. BY;; . tu7I KAREN L. HALSEY DATE: CERTIFICATE OF SERVICE I, Susan M. Williams, an employee with the law firm of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this a 164- day of 2005,1 served a true and correct copy of the foregoing document via U.S. first-class mail, postage pre- paid, as follows: Gerard C. Kramer, Esquire Schmidt, Ronca & Kramer, P.C. 209 State Street Harrisburg, PA 17101 SUSAN M. WILLIAMS f} ?? o ? - ? ? . ?'? _?1 ra --J _,? m? ' it; N ,._. ? ?._ , _? ...,. i .. - 'a _ °J v <: IRMA LOVARI and FRANK LOVARI, Jr., her husband, Plaintiffs V. : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA CIVIL ACTION - LAW KAREN L. HALSEY NO. ds- 34141 l?but(??JL? Defendants JURY TRIAL DEMANDED PLAINTIFF'S ANSWER TO NEW MATTER AND NOW, come the Plaintiffs, Irma Lovari and Frank Lovari, her husband, by and through their attorneys, SCHMIDT, RONCA &, KRAMER, P.C., and respectfully responds to Defendant's New Matter: 20. Paragraph 20 states no factual averments. 21. Paragraph 21 states a conclusion of law to which no responsive pleading is necessary. 22. Paragraph 22 states a conclusion of law to which no responsive pleading is necessary. 23. Paragraph 23 states a conclusion of law to which no responsive pleading is necessary. 24. Paragraph 24 states a conclusion of law to which no responsive pleading is necessary. 25. Paragraph 25 states a conclusion of law to which no responsive pleading is necessary. 26. Paragraph 26 states a conclusion of law to which no responsive pleading is necessary. 27. Paragraph 27 states a conclusion of law to which no responsive pleading is necessary. 28. Paragraph 28 states a conclusion of law to which no responsive pleading is necessary. 29. Paragraph 29 states a conclusion of law to which no responsive pleading is necessary. 30. Paragraph 30 states a conclusion of law to which no responsive pleading is necessary. 31. Paragraph 31 states a conclusion of law to which no responsive pleading is necessary. 32. Paragraph 32 states a conclusion of law to which no responsive pleading is necessary. WHEREFORE, the Plaintiffs request that the New Matter of the Defendants be dismissed and judgment be entered in favor of the Plaintiffs. Respectfully submitted, DATED: 016 S SCHMIDT, RONCA & KRAMER, P.C. ,Gerard C. Kramer Attorney at Law I.D. no. 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs ATTORNEY VERIFICATION I, Gerard C. Kramer, Esquire, verify that I am attorney of record for the Plaintiff. I verify that the facts contained in the foregoing document 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: d - C. Kramer, Esquire CERTIFICATE OF SERVICE AND NOW, this day of lh4J2 P , 2005, I, Gerard C. Kramer, Esq., hereby certify that I have this day served a true and correct copy of the Plaintiffs' Answer to New Matter by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Stephen J. Barcavage, Esquire Marshall, Dennehey, Warner, Coleman & Goggin 4200 Crums Mill Road, Ste. B Harrisburg, PA 17112 Respectfully submitted, SCHMIDT, RONCA & KRAMER, P.C. By: 9rard C. Kramer, Esquire I.D. No. 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs A IRMA J. LOVARI and FRANK J. LOVARI, her husband, Plaintiffs V. KAREN L. HALSEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3491 CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE OF SERVING DISCOVERY TO THE PROTHONOTARY: Please take notice that Defendant, Karen L. Halsey, served Interrogatories and Request for Production of Documents addressed to Plaintiffs pursuant to the Pennsylvania Rules of Civil Procedure, by mail, postage prepaid, on the 194h day of October, 2005. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN BY: STEPHEN J. BARCAVAGE, ESQUIRE I.D. No. 78867 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3506 Attorneys for Defendant Karen L. Halsey DATE: 1D6Rk1 All .. CERTIFICATE OF SERVICE I, Susan M. Williams, an employee with the law firm of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this (°+?) day of October, 2005, I served a true and correct copy of the Defendant's Notice of Serving Discovery via U.S. first-class mail, postage pre-paid, as follows: Gerard C. Kramer, Esquire Schmidt, Ronca & Kramer, P.C. 209 State Street Harrisburg, PA 17101 ??k , SUSAN M. WILLIAMS ?? .??? ?? 09195028 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND PLAINTIFF/S vs. KAREN L. HALSEY DEFENDANT/S COURT OF COMMON PLEAS NO. 05-3491 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 AS A PREREQUISITE TO SERVICE OF A SUBPOENA FOR DOCUMENTS AND THINGS PURSUANT TO RULE 4009.22, DEFENDANT CERTIFIES THAT (1) A NOTICE OF INTENT TO SERVE THE SUBPOENA WITH A COPY OF THE SUBPOENA ATTACHED THERETO WAS MAILED OR DELIVERED TO EACH PARTY AT LEAST TWENTY DAYS PRIOR TO THE DATE ON WHICH THE SUBPOENA IS SOUGHT TO BE SERVED, (2) 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 THAT WILL BE SERVED IS IDENTICAL TO THE SUBPOENA WHICH IS ATTACHED TO THE NOTICE OF INTENT TO SERVE THE SUBPOENA. DATE: 10/20/05 EPH N J. BARCAVAGE, ESQ. ATTORNEY FOR DEFENDANT 21237-00246 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND VS. KAREN L. HALSEY PLAINTIFF/S COURT OF COMMON PLEAS NO. 05-3491 DEFENDANT/S NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: GERALD C. KRAMER, ESQ. SCHMIDT, RONCA & KRAMER, P.C. 209 STATE ST. HARRISBURG PA 17101 ATTORNEY(S) FOR PLAINTIFF 09195028 12/26/05 DEFENDANT INTENDS TO SERVE A SUBPOENA IDENTICAL TO THE ONE THAT IS ATTACHED TO THIS NOTICE TO THE DEPONENT/S LISTED BELOW, REQUESTING RECORDS BE PRODUCED AT RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., PHILADELPHIA, PA 19103. YOU HAVE TWENTY (20) DAYS FROM THE DATE LISTED BELOW IN WHICH TO FILE OF RECORD AND SERVE UPON THE UNDERSIGNED AND RECORD COPY SERVICES (215-241-5858), AN OBJECTION TO THE SUBPOENA. IF NO OBJECTION IS MADE THE SUBPOENA/S MAY BE SERVED. HOLY SPIRIT HOSPITAL SHEPHERDSTOWN FAMILY PRACTICE CENTRAL PENNSYLVANIA REHABILITATION SERVICES, INC. PHYSICIANS OF REHABILITATION INDUSTRIAL & SPINE MEDICINE P.C. HEALTHSOUTH REHABILITATION CENTER HEALTHSOUTH REHABILITATION HOSPITAL MECHANICSBURG DR. HONG S. PARK, M.D. REHAB MEDICINE ASSOCIATES P.C. COUNTRY MARK NURSERY DATE: 9/21/05 STEPHEN J. BARCAVAGE, ESQ. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN 4200 CRUMS MILL RD. HARRISBURG PA 17112 ATTORNEY(S) FOR DEFENDANT AN 09195028 12/26/05 Ca%trNwEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND vs. KAREN L. HALSEY File No. Court of Common Pleas 05-3491 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISOOVERY PURSUANT TO RULE 4009.22 MEDICAL RECORDS DEPARTMENT HOLY SPIRIT HOSPITAL 503 N. 21ST ST. TO: CAMP HILL PA 17011-2288 (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., 5-300, PHILADELPHIA, PA. (Address) You may deliver or mail legible copies of the docunents or produce things requested by this subpoena, together with the certificate of coapliance, 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 canpelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: „A. .STEPHEN J. BARCAVAGE, ESQ. ADDRESS: TELEPHONE:FOR INFORMATION: (215) 241-5858 SUPREME COURT ID # ATTORNEY FORDEFENDANT DATE: Seal` of the Court ISSUED ON: 10/20/05 BY THE COURT: Prothohotary./C-1 k, Civi 1 Division Deputy (Eff. 7/97) NO. 05-3491 ADDENDUM TO SUBPOENA 09195028 12/26/05 IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND VS. KAREN L. HALSEY ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO REHAB/PHYSICAL THERAPY RECORDS, RECORDS REGARDING TREATMENT FOR DEPRESSION/ANXIETY/POST TRAUMATIC STRESS DISORDER, LAB REPORTS, REPORTS REGARDING X-RAYS, MRI'S, CT SCANS OR OTHER DIAGNOSTIC TESTING (NO ACTUAL FILMS NEEDED) TOGETHER WITH ALL REPORTS, NOTES, MEMOS, CORRESPONDENCE AND MEDICAL BILLS CONCERNING IRMA J. LOVARI (2 GRANDVIEW COURT, MECHANICSBURG, PA, DOB 02/02/53, SSN 078-46-9583) N 09195028 12/26/05 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBFRIAND IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND Vs KAREN L. HALSEY File No. Court of Common Pleas 05-3491 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF SHEPHERDSTOWN FAMILY PRACTICE 2140 FISHER RD. TO: MECHANICSBURG PA 17055 of Person or Enti Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunents or things: SEE ATTACHED ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of corpliance, 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 docunents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order cmpelling you to ornply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: STEPHEN J. BARCAVAGE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215T-2-0--n58 SUPREME COURT ID # ATTORNEY FOR:DEFENDANT DATE: U, Seal of the Court ISSUED ON: 10/20/05 BY THE COURT: /? - t;/ Prothonotary/cl"e'r•k, civI Division Deputy (Eff. 7/97) NO. 05-3491 ADDENDUM TO SUBPOENA 09195028 12/26/05 IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND VS. KAREN L. HALSEY ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO REHAB/PHYSICAL THERAPY RECORDS, RECORDS REGARDING TREATMENT FOR DEPRESSION/ANXIETY/POST TRAUMATIC STRESS DISORDER, LAB REPORTS, REPORTS REGARDING X-RAYS, MRI'S, CT SCANS OR OTHER DIAGNOSTIC TESTING (NO ACTUAL FILMS NEEDED) TOGETHER WITH ALL REPORTS, NOTES, MEMOS, CORRESPONDENCE AND MEDICAL BILLS CONCERNING IRMA J. LOVARI (2 GRANDVIEW COURT, MECHANICSBURG, PA, DOB 02/02/53, SSN 078-46-9583) N 09195028 12/26/05 commjNWEALTH OF PENNSYLVANIA ODUNPY OF CUMBERLAND IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND VS. KAREN L. HALSEY File No. Court of Common Pleas 05-3491 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF CENTRAL PENNSYLVANIA REHABILITATION SERVICES, INC. TO: 2120 FISHER RD. 5-101 MECHANICSBURG PA 17055 Name of Person or Ent Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., 5-300, PHILADELPHIA, PA. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of ccrrpliance, 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 compel l ir:g you to ccnply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: STEPHEN J. BARCAVAGE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID # ATTORNEY FOR DEFENDANT DATE: ?:' .1N - US Seal of the Court ISSUED ON: 10/20/05 BY THE COURT: Prothonotary/Cl k, Cy it Division Deputy (Eff. 1/97) NO. 05-3491 ADDENDUM TO SUBPOENA 09195028 12/26/05 IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND VS. KAREN L. HALSEY ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO REHAB/PHYSICAL THERAPY RECORDS, RECORDS REGARDING TREATMENT FOR DEPRESSION/ANXIETY/POST TRAUMATIC STRESS DISORDER, LAB REPORTS, REPORTS REGARDING X-RAYS, MRI'S, CT SCANS OR OTHER DIAGNOSTIC TESTING (NO ACTUAL FILMS NEEDED) TOGETHER WITH ALL REPORTS, NOTES, MEMOS, CORRESPONDENCE AND MEDICAL BILLS CONCERNING IRMA J. LOVARI (2 GRANDVIEW COURT, MECHANICSBURG, PA, DOB 02/02/53, SSN 078-46-9583) N 09195028 12/26/05 COMMONWEALTH OF PEW4SYLVANTA COUNTY OF CUMBERLAND IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND VS. KAREN L. HALSEY File No. Court of Common Pleas 05-3491 SUBPOENA TO PRODUCE DOCLIENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF PHYSICIANS OF REHABILITATION INDUSTRIAL & SPINE MEDICINE P.C. TO: 175 LANCASTER BLVD_ P.O. BOX 2028 Name of Person or Ent Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., 5-300, PHILADELPHIA, PA. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of cmpliance, 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 canpellir:g you to ocnply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME, STEPHEN J. BARCAVAGE, ESQ. ADDRESS: TELEPHONE:FOR INFORMATION: (215) 241-5858 SUPREME COURT ID # ATTORNEY FORpEFENDANT DATE: q o)-/- Z:6 S Seal of the Court ISSUED ON: 10/20/05 BY THE COURT: J rJ Prothonotary/C C' it Division Deputy (Eff. 7/97) N 09195028 12/26/05 COMMONWEALTH OF PENNSYLVANIA OOUITY OF CUMBERLAND IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND Vs KAREN L. HALSEY File No. Court of Common Pleas 05-3491 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISOOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF PHYSICIANS OF REHABILITATION INDUSTRIAL & SPINE MEDICINE P.C. TO: 175 LANCASTER BLVD. P.O. BOX 2028 of Person or Ent Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., 5-300, PHILADELPHIA, PA. (Address) 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 carpelling you to cmply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: STEPHEN J. BARCAVAGE, ESQ. ADDRESS: TELEPHONE:FOR INFORMATION: (215) 241-5858 SUPREME ODURT ID #_ ATTORNEY FORpEFENDANT DATE: Seal o5the z =ftl ISSUED ON: 10/20/05 BY THE COURT: J Prothonotaryy/„G rc, C? it Division Deputy (Eff. 7/97) N 112/26/08 C01%kCNWEALTH OF PEMRSYLVANTA COUNTY OF cumBERLAND IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND vs. KAREN L. HALSEY CUSTODIAN OF THE PHYSICIANS OF RE TO: 175 LANCASTER EL File No. Court of Common Pleas 05-3491 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 ORDS OF LITATION INDUSTRIAL & SPINE MEDICINE P.C. P.O. BOX 2028 'J (Name of Person or Entity Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunents or things: SEE ATTACHED ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of ocnpliance, 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 docunents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order carrpellir:g you to ccnply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME, STEPHEN J. BARCAVAGE, ESQ. ADDRESS: TELEPHONE:FOR INFORMATION: (215) 241-5858 SUPREME COURT ID #_ ATTORNEY FORpEFENDANT DATE: 5 -".--? Seal of the Court ISSUED ON: 10/20/05 BY THE COURT: 7 - Prothonotary/C' c, C' it Division Deputy (Eff. 7/97) NO. 05-3491 ADDENDUM TO SUBPOENA 09195028 12/26/05 IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND VS. KAREN L. HALSEY ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO REHAB/PHYSICAL THERAPY RECORDS, RECORDS REGARDING TREATMENT FOR DEPRESSION/ANXIETY/POST TRAUMATIC STRESS DISORDER, LAB REPORTS, REPORTS REGARDING X-RAYS, MRI'S, CT SCANS OR OTHER DIAGNOSTIC TESTING (NO ACTUAL FILMS NEEDED) TOGETHER WITH ALL REPORTS, NOTES, MEMOS, CORRESPONDENCE AND MEDICAL BILLS CONCERNING IRMA J. LOVARI (2 GRANDVIEW COURT, MECHANICSBURG, PA, DOB 02/02/53, SSN 078-46-9583) N 09195028 12/26/05 COMMDNWEALTH OF PENNSYLVANIA COONtY OF CUMEERIAND IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND Vs KAREN L. HALSEY File No. Court of Common Pleas 05-3491 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF HEALTHSOUTH REHABILITATION CENTER 920 CENTURY DR. TO: MECHANICSBURG PA 17055 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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., 5-300, PHILADELPHIA, PA. (Address) 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:STEPHEN J. BARCAVAGE, ESQ. ADDRESS: TELEPHONE:FOR INFORMATION: (215) 241-5858 SUPREME COURT ID # ATTORNEY FORDEFENDANT DATE : Seal of the Court ISSUED ON: 10/20/05 BY THE COURT: Prothonotary/Clerk, Civil Division Deputy (Eff. 7/97) NO. 05-3491 ADDENDUM TO SUBPOENA 09195028 12/26/05 IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND VS. KAREN L. HALSEY ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO REHAB/PHYSICAL THERAPY RECORDS, RECORDS REGARDING TREATMENT FOR DEPRESSION/ANXIETY/POST TRAUMATIC STRESS DISORDER, LAB REPORTS, REPORTS REGARDING X-RAYS, MRI'S, CT SCANS OR OTHER DIAGNOSTIC TESTING (NO ACTUAL FILMS NEEDED) TOGETHER WITH ALL REPORTS, NOTES, MEMOS, CORRESPONDENCE AND MEDICAL BILLS CONCERNING IRMA J. LOVARI (2 GRANDVIEW COURT, MECHANICSBURG, PA, DOB 02/02/53, SSN 078-46-9583) IN 09195028 12/26/05 COUNTY OF CUMBFRIAM IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND COMMONWEALTH OF PENNSYLVANIA Vs, KAREN L. HALSEY File No. Court of Common Pleas 05-3491 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 MEDICAL RECORDS DEPARTMENT HEALTHSOUTH REHABILITATION HOSPITAL MECHANICSBURG TO: 175 LANCASTER BLVD. MECHANICSBURG PA 17055 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following doc rents or things: SEE ATTACHED ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., 5-300, PHILADELPHIA, PA. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of curpliance, 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 documnts or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order ccrrpelling you to conply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: STEPHEN J. BARCAVAGE, ESQ. ADDRESS TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT BY THE OOURT: f DATE: Prothonotary/Gl,EOc -tivi/ Division Seal of th?v ISSUED ON: 10/20/05 Deputy (Eff. T/97) NO. 05-3491 ADDENDUM TO SUBPOENA 09195028 12/26/05 IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND VS. KAREN L. HALSEY ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO REHAB/PHYSICAL THERAPY RECORDS, RECORDS REGARDING TREATMENT FOR DEPRESSION/ANXIETY/POST TRAUMATIC STRESS DISORDER, LAB REPORTS, REPORTS REGARDING X-RAYS, MRI'S, CT SCANS OR OTHER DIAGNOSTIC TESTING (NO ACTUAL FILMS NEEDED) TOGETHER WITH ALL REPORTS, NOTES, MEMOS, CORRESPONDENCE AND MEDICAL BILLS CONCERNING IRMA J. LOVARI (2 GRANDVIEW COURT, MECHANICSBURG, PA, DOB 02/02/53, SSN 078-46-9583) A 09195028 12/26/05 COMMONWEALTH OF PENNSYLVANIA COIRTPY OF CUMBERIAND IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND Vs KAREN L. HALSEY File No. Court of Common Pleas 05-3491 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF DR. HONG S. PARK, M.D. REHAB MEDICINE ASSOCIATES P.C. TO: 5124 E. TRINDLE RD. MECHANICSBURG PA 17055 of Person or Ent Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., 5-300, PHILADELPHIA, PA. (Address) 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 docunents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order ccupelling you to crarply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: STEPHEN J. BARCAVAGE, ESQ. ADDRESS TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT BY THE COURT: DATE: Prothonotary- a Civ Division "/ ' f .r1--CIS Seal f the Court ISSUED ON: 10/20/05 Deputy (Eff. 7/97) NO. 05-3491 ADDENDUM TO SUBPOENA 09195028 12/26/05 IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND VS. KAREN L. HALSEY ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO REHAB/PHYSICAL THERAPY RECORDS, RECORDS REGARDING TREATMENT FOR DEPRESSION/ANXIETY/POST TRAUMATIC STRESS DISORDER, LAB REPORTS, REPORTS REGARDING X-RAYS, MRI'S, CT SCANS OR OTHER DIAGNOSTIC TESTING (NO ACTUAL FILMS NEEDED) TOGETHER WITH ALL REPORTS, NOTES, MEMOS, CORRESPONDENCE AND MEDICAL BILLS CONCERNING IRMA J. LOVARI (2 GRANDVIEW COURT, MECHANICSBURG, PA, DOB 02/02/53, SSN 078-46-9583) 09195028 12/26/05 CbM ONWEALTH OF PEtaLSYLVANIA OODNTY OF (IJKBERIAm IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND Vs KAREN L. HALSEY File No. Court of Common Pleas 05-3491 SUBPOENA TO PRODUCE DOCLMNTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: 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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., 5-300, PHILADELPHIA, PA. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of carpIiance, 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 crnpelling you to conply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME:STEPHEN J. BARCAVAGE, ESQ. ADDRESS: TELEPHONE:FOR INFORMATION: (215) 241-5858 SUPREME COURT ID k ATTORNEY FORDEFENDANT DATE: "/--" -0y- Seal of the Court ISSUED ON: 10/20/05 DEPARTMENT RK NURSERY 51 GETTYSBURG PIKE URG PA 17055 BY THE COURT: Protho tart' erg, Oivi Division Deputy (Eff. 7/97) NO. 05-3491 ADDENDUM TO SUBPOENA 09195028 12/26/05 IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND VS. KAREN L. HALSEY ANY AND ALL EMPLOYMENT INFORMATION, INCLUDING W-2S, 1099S, PAYROLL RECORDS, PERFORMANCE EVALUATIONS, SICKNESSES/ILLNESSES, DISCIPLINARY ACTIONS, MEMOS, CORRESPONDENCE, HANDWRITTEN NOTES AND ANY AND ALL MEDICAL REPORTS/OPINIONS CONCERNING IRMA J. LOVARI (2 GRANDVIEW COURT, MECHANICSBURG, PA, DOB 2/2/53, SSN 078-46-9583) CERTIFICATE OF SERVICE I, Susan M. Williams, an employee with the flaw firm of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this at-4 - day of November, 2005, I served a true and correct copy of the Certificate-Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22 via U.S. first-class mail, postage pre-paid, as follows: Gerard C. Kramer, Esquire Schmidt, Ronca & Kramer, P.C. 209 State Street Harrisburg, PA 17101 SUSAN M. WILLIAMS C: ''? ?? "? ?:'-??! ?? --? T-ry ' rl't ? I ?_: Il 1 ij ?F' - ? i?_1 4': -?ri ?i) ?11t ?.J .. r..? . . = [.i i } liJ 12145012 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND PLAINTIFF/S VS. KAREN L. HALSEY DEFENDANT/S COURT OF COMMON PLEAS NO. 05-3491 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 AS A PREREQUISITE TO SERVICE OF A SUBPOENA FOR DOCUMENTS AND THINGS PURSUANT TO RULE 4009.22, DEFENDANT CERTIFIES THAT (1) A NOTICE OF INTENT TO SERVE THE SUBPOENA WITH A COPY OF THE SUBPOENA ATTACHED THERETO WAS MAILED OR DELIVERED TO EACH PARTY AT LEAST TWENTY DAYS PRIOR TO THE DATE ON WHICH THE SUBPOENA IS SOUGHT TO BE SERVED, (2) 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 THAT WILL BE SERVED IS IDENTICAL TO THE SUBPOENA WHICH IS ATTACHED TO THE NOTICE OF INTENT TO SERVE THE SUBPOENA. DATE: 1/12/06 S PHEN J. BARCAVAGE, ESQ. ATTORNEY FOR DEFENDANT 21237-00246 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND VS. KAREN L. HALSEY PLAINTIFF/S COURT OF COMMON PLEAS NO. 05-3491 12145012 12/26/05 DEFENDANT/S NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: GERARD C. KRAMER, ESQ. SCHMIDT, RONCA & KRAMER, P.C. 209 STATE ST. HARRISBURG PA 17101 ATTORNEY(S) FOR PLAINTIFF DEFENDANT INTENDS TO SERVE A SUBPOENA IDENTICAL TO THE ONE T: NOTICE TO THE DEPONENT/S LISTED BELOW, REQUESTING RECORDS BE SERVICES, 1880 JOHN F. KENNEDY BLVD., PHILADELPHIA, PA 19103 DAYS FROM THE DATE LISTED BELOW IN WHICH TO FILE OF RECORD A AND RECORD COPY SERVICES (215-241-5858), AN OBJECTION TO THE IS MADE THE SUBPOENA/S MAY BE SERVED. PENNSYLVANIA OPEN MRI CHRISTOPHER ROYER, PSYD PHYSICIANS OF REHABILITATION DATE: 12/15/05 IAT IS ATTACHED TO THIS PRODUCED AT RECORD COPY YOU HAVE TWENTY (20) 9D SERVE UPON THE UNDERSIGNED SUBPOENA. IF NO OBJECTION STEPHEN J. :BARCAVAGE, ESQ. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN 4200 CRUMS MILL RD. HARRISBURG PA 17112 ATTORNEY(S) FOR DEFENDANT IN 12145012. 12/26/05 COMMONWEALTH OF PENNSYLVANIA COLDM OF CUMBERLAND IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND • Court of Common Pleas 05-3491 vs. File No. KAREN L. HALSEY SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF PENNSYLVANIA OPEN MRI 5400 CHAMBERS HILL RD. TO: HARRISBURG PA 17111 (Name of Person or Ent Within twenty (20) days after service of this subpoena, you are ordered by the avert to produce the following doaments or things: SEE ATTACHED ADDENDUM COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of cow liance, 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 docments or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order camel l ir:g you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAMEPTEPHEN J. BARCAVAGE, ESQ. ADDRESS: TELEPHONE TOR INFORMATION: (215) 241-5858 SUPREME COURT ID #_ ATTORNEY FOfjjEFENDANT DATE : % ^ - a - 4 Sealrof the'Court ISSUED ON: 1/12/06 BY THE COURT: a Prothonotary/01101i', Civil Division Deputy (Eff. 7/97) 12145012 12/26/05 COMMONWEALTH OF PENNSYLVANIA COUNPY OF CLI93ER AND IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND • Court of Common Pleas 05--3491 VS. File No. KAREN L. HALSEY SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF CHRISTOPHER ROYER, PSYD PHYSICIANS OF REHABILITATION TO: 4950 WILSON LANE MECHANICSBURG PA 17055 (Name of Person or Ent Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. (Address) 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 carpelling you to ca, ly with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: STEPHEN J. BARCAVAGE, ESQ. ADDRESS TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT DATE : / d - Seal of the'Cour ISSUED ON: 1/12/06 BY THE COURT: Protho otary/ Civil/ ivision Deputy (Eff. 7/97) NO. 05-3491 ADDENDUM TO SUBPOENA 12145012 12/26/05 IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND VS. KAREN L. HALSEY ANY AND ALL MEDICAL RECORDS, INCLUDING, BUT NOT LIMITED TO, RECORDS REGARDING TREATMENT FOR ANY AND ALL PSYCHOLOGICAL ISSUES, INCLUDING DEPRESSION/ANXIETY/ POST TRAUMATIC STRESS. DISORDER, ANY AND ALL LAB REPORTS, REPORTS REGARDING X-RAYS, MRI'S, CT SCANS OR OTHER DIAGNOSTIC TESTING PERFORMED (NO ACTUAL FILMS NEEDED), TOGETHER WITH ALL REPORTS, NOTES, MEMOS, CORRESPONDENCE AND MEDICAL BILLS CONCERNING IRMA J. LOVARI (2 GRANDVIEW CT., MECHANICSBURG, PA, DOB 02/02/53, SSN 078-46-9583) CERTIFICATE OF SERVICE I, Susan M. Williams, an employee with the law firm of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this a?dr01'day of January, 2006, I served a true and correct copy of the Certificate-Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22 via U.S. first-class mail, postage pre-paid, as follows: Gerard C. Kramer, Esquire Schmidt, Ronca & Kramer, P.C. 209 State Street Harrisburg, PA 17101 l?Vv K_ SUSAN M. WILLIAMS r` i ?-? ; .-{ - ? 1'l :'. .J ? 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IRMA J. LOVARI AND FRANK J. LOVARI, HER ) HUSBAND ) PLAINTIFF/S ) COURT OF COMMON PLEAS VS. KAREN L. HALSEY DEFENDANT/S NO. 05-3491 11216039 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 AS A PREREQUISITE TO SERVICE OF A SUBPOENA FOR DOCUMENTS AND THINGS PURSUANT TO RULE 4009.22, DEFENDANT CERTIFIES THAT (1) A NOTICE OF INTENT TO SERVE THE SUBPOENA WITH A COPY OF THE SUBPOENA ATTACHED THERETO WAS MAILED OR DELIVERED TO EACH PARTY AT LEAST TWENTY DAYS PRIOR TO THE DATE ON WHICH THE SUBPOENA IS SOUGHT TO BE SERVED, , (2) 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 THAT WILL BE SERVED IS IDENTICAL TO THE SUBPOENA WHICH IS ATTACHED TO THE NOTICE OF INTENT TO SERVE THE SUBPOENA. DATE: 12/21/06 STEPHEN J. BARCAVAGE, ESQ. ATTORNEY FOR DEFENDANT 21237-00246 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND VS. KAREN L. HALSEY PLAINTIFF/S COURT OF COMMON PLEAS NO. 05-3491 DEFENDANT/S NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: GERARD C. KRAMER, ESQ. SCHMIDT, KRAMER P.C. 209 STATE ST. HARRISBURG PA 17101 ATTORNEY(S) FOR PLAINTIFF 11216039 12/25/06 DEFENDANT INTENDS TO SERVE A SUBPOENA IDENTICAL TO THE ONE THAT IS ATTACHED TO THIS NOTICE TO THE DEPONENT/S LISTED BELOW, REQUESTING RECORDS BE PRODUCED AT RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., PHILADELPHIA, PA 19103. YOU HAVE,TWENTY (20) DAYS FROM THE DATE LISTED BELOW IN WHICH TO FILE OF RECORD AND SERVE UPON THE UNDERSIGNED AND RECORD COPY SERVICES (215-241-5858), AN OBJECTION TO THE SUBPOENA. IF NO OBJECTION IS MADE THE SUBPOENA/S MAY BE SERVED. HOLY SPIRIT HOSPITAL SHEPHERDSTOWN FAMILY PRACTICE DATE: 11/22/06 STEPHEN J. BARCAVAGE, ESQ. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN 4200 CRUMS MILL RD. HARRISBURG PA 17112 ATTORNEY(S) FOR DEFENDANT .&A 11216039 12/25/06 Cpp?F?LTH OF PEtdRMVANIA C OUNrY OF C( ID IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND Vs. KAREN L. HALSEY Court of Common Pleas 05-3491 Fi le No. SUBPOENA TO PRODUCE DOCLENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 MEDICAL RECORDS DEPARTMENT HOLY SPIRIT HOSPITAL 503 N. 21ST ST. TO: CAMP HILL PA 17011-2288 (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 ADDENDUM at RRCntm COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., 5-300, PHILADELPHIA, PA. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of ccrrpIiance, 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 ccrrj:?e l l i ng you to carry l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAPE. STEPHEN J. BARCAVAGE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT DATE : Seal of the Court ISSUED ON: 12/21/06 BY THE COURT: Lvazo P zenn? Prothonotary Clerk ivil Division Deputy (Eff. -1/97) NO. 05-3491 ADDENDUM TO SUBPOENA 11216039 1/09/07 IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND VS. KAREN L. HALSEY SEE ATTACHED ADDENDUM PERTAINING TO IRMA J. LOVARI (2 GRANDVIEW COURT, MECHANICSBURG, PA, DOB 02/02/53, SSN 078-46-9583). 16:05 From-MARSHALL DENNEHEY +7172321849 T-983 P.003/003 F-076 PAGE 2 OF 2 Instructions: Any and all medical records, including, but not limited to, hospital records, physical therapy records, rehab records, lab reports, x-ray films, MRls, CT scans, or other diagnostic testing performed, together with all diagnostic reports, medical reports, notes, memoranda, correspondence and medical bills concerning Irma J. Lovari; Date of Birth: 2/2/53; Social Security No. 078-46-9583 from September 2005 to the present. 11216039 12/25/06 (b1 1T.TH OF PENNSYLVANIA COUNTY OF CIRID IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND Court of Common Pleas 05-3491 Vs. File No. KAREN L. HALSEY SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISOOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF SHEPHERDSTOWN FAMILY PRACTICE 2140 FISHER RD. TO: MECHANICSBURG PA 17055 (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, FA. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of ccrpliance, 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 twer?ty (20) days after its service, the party serving this subpoena Tray seek a court order carpe l l i ng you to carp i y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: STEPHEN J. BARCAVAGE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT BY THE COURT: DATE: A _ C;? ?1 -Qi? Seal of the Court ISSUED ON: 12/21/06 Civil Division Deputy (Eff. 7/97) NO. 05-3491 ADDENDUM TO SUBPOENA 11216039 1/09/07 IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND VS. KAREN L. HALSEY SEE ATTACHED ADDENDUM PERTAINING TO IRMA J. LOVARI (2 GRANDVIEW COURT, MECHANICSBURG, PA, DOB 02/02/53, SSN 078-46-9583). 11-21-2006 16:05 From-MARSHALL DENNEHEY +T1T2321649 T-963 P-003/003 F-076 PAGE 2 OF 2 Instructions: Any and all medical records, including, but not limited to, hospital records, physical therapy records, rehab records, lab reports, x-ray films, MRis, CT scans, or other diagnostic testing performed, together with all diagnostic reports, medical reports, notes, memoranda, correspondence and medical bills concerning Irma J. Lovari; Date of Birth: 2/2/53; Social Security No. 078-46-9583 from September 2005 to the uresent. CERTIFICATE OF SERVICE I, Susan M. Williams, an employee with the law firm of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this CkTh day of December, 2006, I served a true and correct copy of the Certificate-Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22 via U.S. first-class mail, postage pre-paid, as follows: Gerard C. Kramer, Esquire Schmidt, Kramer, P.C. 209 State Street Harrisburg, PA 17101 SUSAN M. WILLIAMS N 'TJ ? - 'L7 ?'rf C-1 ?" t;. 1 Cr C7 ORIGINAL. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND VS. KAREN L. HALSEY PLAINTIFF/S DEFENDANT/S COURT OF COMMON PLEAS NO. 05-3491 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 08087038 AS A PREREQUISITE TO SERVICE OF A SUBPOENA FOR DOCUMENTS AND THINGS PURSUANT TO RULE 4009.22, DEFENDANT CERTIFIES THAT (1) A NOTICE OF INTENT TO SERVE THE SUBPOENA WITH A COPY OF THE SUBPOENA ATTACHED THERETO WAS MAILED OR DELIVERED TO EACH PARTY AT LEAST TWENTY DAYS PRIOR TO THE DATE ON WHICH THE SUBPOENA IS SOUGHT TO BE SERVED, (2) 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 THAT WILL BE SERVED IS IDENTICAL TO THE SUBPOENA WHICH IS ATTACHED TO THE NOTICE OF INTENT TO SERVE THE SUBPOENA. DATE: 9/07/07 -``"... . S P J. BARCAVAGE, ESQ. TTORNEY FOR DEFENDANT 21237-00246 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND VS. KAREN L. HALSEY PLAINTIFF/S COURT OF COMMON PLEAS NO. 05-3491 DEFENDANT/S NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: GERARD C. KRAMER, ESQ. SCHMIDT, KRAMER P.C. 209 STATE ST. HARRISBURG PA 17101 ATTORNEY(S) FOR PLAINTIFF 08087038 12/25/07 DEFENDANT INTENDS TO SERVE A SUBPOENA IDENTICAL TO THE ONE THAT IS ATTACHED TO THIS NOTICE TO THE DEPONENT/S LISTED BELOW, REQUESTING RECORDS BE PRODUCED AT RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., PHILADELPHIA, PA 19103. YOU HAVE TWENTY (20) DAYS FROM THE DATE LISTED BELOW IN WHICH TO FILE OF RECORD AND SERVE UPON THE UNDERSIG AND RECORD COPY SERVICES (215-241-5858), AN OBJECTION TO THE SUBPOENA. IF NO OBJECTION IS MADE THE SUBPOENA/S MAY BE SERVED. CONCENTRA MEDICAL CENTER ORTHOPEDIC INSTITUTE OF PENNSYLVANIA DATE: 8/09/07 STEPHEN J. BARCAVAGE, ESQ. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN 4200 CRUMS MILL RD. HARRISBURG PA 17112 ATTORNEY(S) FOR DEFENDANT NO 08087038 12/25/07 OF PENbbMVANIA CCUNI'Y amnam IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND Vs. File No. KAREN L. HALSEY Court of Common Pleas 05-3491 FOR DISOONERY PURSUANT TO U 4W9.22 CUSTODIAN OF THE RECORDS OF ORTHOPEDIC INSTITUTE OF PENNSYLVANIA 3399 TRINDLE RD. TO: CAMP HILL PA 17011 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the oourt to produce the following documents or things: SEE ATTACHED ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, A. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of coo I iance, 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 docunents 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 cmP1y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: STEPHEN J. BARCAVAGE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: 21 -5858 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT DATE : 4& '/'y. .2'no> 1 of the Court ISSUED ON: 9/07/07 BY THE OOURT: IV /f I Prothonatary/ erk, Civil Division Deputy (Eff. 7/97) NO. 05-3491 ADDENDUM TO SUBPOENA 08087038 12/25/07 IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND VS. KAREN L. HALSEY SEE ATTACHED ADDENDUM PERTAINING TO IRMA J. LOVARI (2 GRANDVIEW CT., MECHANICSBURG, PA, DOB 02/02/53, SSN 078-46-9583). AuQ-06-OT 15:41 From-MDWC&G T17-651-9630 T-315 P.003/003 F-603 PAGE 2 OF 2 instructions: Any and all medical records, including, but not limited to, physical therapy records, rehab records, lab reports, x-ray films, MRis, CT scans, or other diagnostic testing perlbrmed, together with all diagnostic reports, medical reports, notes, memoranda, correspondence and medical bills concerning Irma J. Lovarl; Date of Birth: 2/2153; Social Security No. 078-46.8583. 19 08087038 12/25/07 OF PENNSYENANIA OOH RM OF ( 'r tID IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND Vs. KAREN L. HALSEY TO: File No. Court of Common Pleas 05-3491 SUBPOENA 19 PRODUCE Q9911M OR THI FOR D I SONERY PURSUANT TO RULE 41109.22 OF THE RECORDS OF MEDICAL CENTER 4910 RITTER RD. BURG PA 17055 (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. (Address) You may deliver or mail legible copies of the docunents or produce things requested by this subpoena, together with the certificate of caTpliance, 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 tray seek a court order carpet l ing you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: STEPHEN J. BARCAVAGE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (2-15-)--2Z7--5858 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT DATE : l ..2w > Sell of the Court ISSUED ON; 9/07/07 BY THE COURT: Prothonotary lark, Civil Division Deputy (Eff. 1/97) NO. 05-3491 ADDENDUM TO SUBPOENA 08087038 12/25/07 IRMA J. LOVARI AND FRANK J. LOVARI, HER HUSBAND VS. KAREN L. HALSEY SEE ATTACHED ADDENDUM PERTAINING TO IRMA J. LOVARI (2 GRANDVIEW CT., MECHANICSBURG, PA, DOB 02/02/53, SSN 078-46-9583). Aug-09-OT 15:41 From-MMUG 711-651-9630 T-315 P-003/003 F-603 PAGE 2OF2 Instructions: Any and all medical records, Including, but not limited to, physical therapy records, rehab records, lab reports, x-ray films, We, CT scans, or other diagnostic testing performed, together with all diagnostic reports, medical reports, notes, memoranda, correspondence and medical bills concerning Irma J. Lovers; Date of Birth: 2/2153; Social Security No. 478-46-9583. CERTIFICATE OF SERVICE I, Susan M. Williams, an employee with the law firm of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this ?* day of September, 2007, I served a true and correct copy of the Certificate-Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22 via U.S. first-class mail, postage pre-paid, as follows: Gerard C. Kramer, Esquire Schmidt, Kramer, P.C. 209 State Street Harrisburg, PA 17101 SUSAN M. WELLIAMS n ? pZ? `i l cn i l Yi I ORIGINAL SCHMIDT, KRAMER, P.C. By: Gerard C. Kramer, Esquire 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs IRMA J. LOVARI and FRANK J. LOVARI, her husband, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-3491 V. KAREN L. HALSEY, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above-referenced matter as SETTLED, DISCONTINUED and ENDED with Prejudice. SCHMIDT, KRAMER, P.C. DATE: /Z? BY: erard C. Kramer, Esquire Attorney for Plaintiffs CERTIFICATE OF SERVICE I, Susan M. Williams, an employee with the law firm of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this day of August, 2008, I served a true and correct copy of the Praecipe to Settle, Discontinue and End via U.S. first-class mail, postage pre-paid, as follows: Gerard C. Kramer, Esquire Schmidt, Kramer, P.C. 209 State Street Harrisburg, PA 17101 SUSAN M. WILLIAMS h ra 7 ?-, - ! Mr, N s