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Home My WebLink About05-3553O ANNE PICCIRILLI, wife, and WILLIAM PICCIRILLI, husband. Plaintiffs, v. DYAN FLYNN, a.k.a., DYAN REGAN, a.k.a., DIANE SHENK, a.k.a. DIANE FLYNN, and DIANE FLYNN, Defendants. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 13 5, 3 516 3 P Tom.. 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 the 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 ANNE PICCIRILLI, wife, and WILLIAM PICCIRILLI, husband. Plaintiffs, vi. DYAN FLYNN, a.k.a., DYAN REGAN, a.k.a., DIANE SHENK, a.k.a. DIANE FLYNN, and DIANE FLYNN, Defendants. IN THE COURT COMMON PLEAS OF CUMBERLAND OF COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. JURY TRIAL DEMANDED AVISO USTED HA SIDO DEMANDADO/A EN CORTE. defenderse de las demandas que se presentan paginas, debe tomar Si usted desea la notificaci6n de esta Demandatro de los mas adelante en las siguientes de un abogado una tom pr6ximradic veinte (20) dias despuds de y Aviso radicando personalmente o por medio escrita sus defensas de, y object nes ac las demandas present das a Corte suya. Se le advierte de Por escrito anterior silya. rmente, el to d que si usted falla de tomar acci6n como se describe dinero reel casO Puede proceder sin usted y un fallo Por itado de por e n de a en la demanda o cualquier otra recl cual andante ainaci6n o remedio mas itad aviso aor el dal. Puede ser dictado en contra su a importantes n icion Usted puede perder dinero o propiedad u ot?os de?echos 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 A CERCA DE COMO PROVEERLE INFORMACION 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 ANNE PICCIRILLI, wife and WILLIAM PICCIRILLI, husband. Plaintiffs, V. DYAN FLYNN, a.k a.k.a., DYAN REGAN, .a., D IANE SHENK, a.k.a. DIANE FLYNN, and DIANE FLYNN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. OS_ 3S?3 c Q Defendants. JURY TRIAL DEMANDED COMA AND NOW, the Plaintiffs, Anne Piccirilli and William , HMIDT, RONCA AND as through follows; their attorneys SC Piccirilli by and KRAMER, P.C. and hereby aver 1 • The Plaintiffs, Anne Piccirilli and William Piccirilli, individuals who at all times relev t hereto have lived are adult 213 Street, Camp Hill, releva are adult at 424 North Cumberland County, Pennsylvania 17011. 2• The Defendant D yan Flynn, a.k a DYan Regan aka Diane Shenk. a.k.a. Diane Flynn and Diane Flynn is an adult individual who at all times relevant hereto has lived at 5010 East Trindle Road, Mechanicsburg, Cumberland 3• The facts County Pennsylvania 17050. and occurrences hereinafter took place on or about August 5, 2003 on North Cumberland 21't st Street in East Pennsboro Township, land County Pennsylvania. 4• At the aforementioned time and place, the Plaintiff, Anne Piccirilli was operating a 1998 Mercedes. S. At the aforementioned time and place, the Defendant, Diane Flynn, was operating a motor vehicle that was traveling in the same direction, two cars behind the Plaintiffs vehicle. 6. At the aforementioned time and place, the Defendant, Diane Flynn, rear-ended the Plaintiffs vehicle when, in an attempt to pass a car making right-hand turn into the Holy Spirit Hospital entrance, she came into the left-hand turning lane where the Plaintiff was waiting to enter her home driveway and struck the Plaintiffs vehicle, causing her injuries set forth below. COUNT I ANNE PICCIRILLI V. DIANE FLYNN NEGLIGENCE 7. Paragraphs 1 through 6 of the Plaintiffs 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; b. failing to keep a reasonable look out for other operators lawfully on the roadway; c. failing to have her vehicle under proper and adequate control; d. failing to apply her brakes in time to avoid the collision with the Plaintiffs vehicle; e. negligently applying her brakes; f. failing to observe the Plaintiffs vehicle lawfully on the roadway; 2 g. failing to operate her vehicle in accordance with existing traffic conditions and traffic controls; h. operating her vehicle so as to create a dangerous situation for other vehicles on the roadway and; i. careless driving 10. As a direct and proximate result of the accident and the Defendant's carelessness, negligence and recklessness, the Plaintiff, Anne Piccirilli sustained injuries which are serious and may be permanent including, but not limited to: a. severe back pain; and b. leg pain 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 has 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 has suffered a permanent 3 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 earning poker and capacity, and thus, a claim for these losses is made. WHEREFORE, Plaintiff Anne Piccirilli demands judgment on the Defendant Diane Flynn in an amount in excess of Thirty-Five Thousand ($35,000.00) Dollars and in excess of an amount requiring compulsory arbitration. COUNT II WILLIAM PICCIRILLI V' DIANE FLYNN LOSS OF CONSORTIUM 16. Paragraphs 1 through 15 of the Plaintiffs' Complaint are incorporated herein by reference and made a part thereof as if set forth in full. IT As a direct and proximate result of the negligence and the injuries sustained in the motor vehicle accident by his wife, the Plaintiff, William Piccirilli, has suffered the loss of consortium, including the diminish of society and companionship of his wife. WHEREFORE, the Plaintiff, William Piccirilli, demands judgment on the Defendant, Diane Flynn in an amount in excess of Thirty-Five Thousand ($35,000.00) Dollars and in excess of an amount requiring compulsory arbitration. 4 Respectfully Submitted, Date: SCHMIDT, RONCA & KRAMER, P.C. By 2 / ,/ Scott B. Cooper, Esquire I.D. No. 70242 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs VERIFICATION BASED UPON PERSONAL KNOWLEDGE AND INFORMATION SUPPLIED BY COUNSEL We, Anne Piccirilli and William Piccirilli, hereby verify that we are the Plaintiffs in the foregoing action and that the attached Complaint is based upon the information that has been gathered by our counsel in preparation of this lawsuit. The language of the Complaint is that of counsel and is not ours. I have read the Complaint, and to the extent that it is based upon information that we have given to counsel, it is true and correct to the best of our knowledge, information, and belief. To the extent that the contents of the Complaint are that of counsel, we have relied upon counsel in making this Verification. We 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: i Anne Piccirilli Date: W (7 rrr? C -i ? ? G 7 ` CIO V _ C-j (^ V - G d Cl-)) SHERIFF'S RETURN - REGULAR CASE NO: 2005-03553 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PICCIRILLI WILLIAM ET AL VS FLYNN DYAN AKA DYAN REGAN AKA KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon FLYNN DYAN AKA DYAN REGAN AKA DIANNE SHENK AKA DIANE FLYNN the DEFENDANT , at 0013:20 HOURS, on the 19th day of July , 2005 at FACE FORWARD 1 LEMOYNE SQUARE HILL. PA 17011 by handing to CARTER ROTH (ADULT IN CHARGE) a true and attested copy of NOTICE together with COMPLAINT and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 12.80 Affidavit .00 Surcharge 10.00 .00 40.80 Sworn and Subscribed to before me this 2L? day of A. D. P othonotary So Answers: j;wd ? Z1 R. Thomas Kline 07/20/2005 SCHMIDT, RONCA, KRAMER By: D puty S ri ANNE PICCIRILLI, wife, and WILLIAM : IN THE COURT OF COMMON PLEAS PICCIRILLI, husband CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs VS. NO. 05-3553 Civil Term DYAN FLYNN, a.k.a., DYAN REGAN, a.k.a., DIANE SHENK, a.k.a. DIANE FLYNN, and DIANE FLYNN, Defendants JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Diane Flynn, with regard to the above-captioned matter. Respectfully submitted, NEALON GOVER & PERRY By: L44v- Cac?je- G. Shore, Esquire I.D. #: 85321 2411 North Front Street Harrisburg, PA 17110 717/232-9900 Date: I CERTIFICATE OF SERVICE AND NOW, this 17LI day of August, 2005, f 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 209 State Street Harrisburg, PA 17101 LZ L as& . Shore, Esquire r, ? n + '?;: G m ?_ N zrQ CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANNE PICCIRILLI, WIFE, AND WILLIAM PICCIRILLI, HUSBAND -VS- DYAN FLYNN, ET AL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 05-3553 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. DATE: 09/20/2005 /_MCS on behal of U /CASEY S RE, ESQ. Attorney for DEFENDANT DE11-585494 S 9 4 7 8- L O 1 C O M M O N W E A L T H OF P E NN S Y L VAN T A C O UN T Y OF C UMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS ANNE PICCIRILLI, WIFE, AND WILLIAM PICCIRILLI, HUSBAND -VS- DYAN FLYNN, ET AL NOTICE A TERM, CASE NO: 05-3553 TO PRODUCE DOCUMENTS AND [ 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 MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT CC: CASEY SHORE, ESQ. - 05-592 PATRICIA HOFFMAN - Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-311214 S 9 4 7 8- C O 2 ?>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED JOHNS HOPKINS HOSPITAL JOHNS HOPKINS HOSPITAL HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ASSOCIATED CARDIOLOGISTS JOHNS HOPKINS AT GREEN SPRING HEALTH SOUTH MECHANICSBURG FIRST CHOICE REHAB SPECIALISTS GEORGE HARHIGH, D.O. PA NEUROSCIENCE INSTITUTE, INC MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS DE02-311214 5 9 4 7 8- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANNE PICCIRILLI, WIFE, AND WILLIAM vs. DYAN FLYNN, ET AL File No. C MBER AND 05-3553 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JOHNS HOPKINS 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 MCC Croup Inc 1601 Market Street Suite 800 Philadel h' 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/C erk, Ci ' n Deputy Date: ?Y(1 ?? ??5 Seal of the Court 59478-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOHNS HOPKINS HOSPITAL 600 N. WOLFE STREET BALTIMORE, MD 21287 RE: 59478 ANNE PICCIRILLI 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 : ANNE PICCIRILLI 424 NO. 21ST STREET, CAMP HILL, PA 17011 Social Security 11: 035-28-4901 Date of Birth: 0412-1943 SU10-580914 5 94 7 8- 1, 0 1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANNE PICCIRILLI, WIFE, AND WILLIAM PICCIRILLI, HUSBAND -VS- DYAN FLYNN, ET AL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 05-3553 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 (lj 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 DE11-585495 S 9 4 7 8-10 2 C O M M O N W E A L 7H 01P P E N N S Y L -VAN 2 A COUNTY 01P C UMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS ANNE PICCIRILLI, WIFE, AND WILLIAM PICCIRILLI, HUSBAND -VS- DYAN FLYNN, ET AL NOTICE OF INTENT TERM, CASE NO: 05-3553 SUBPOENA TO PRODUCE PURSUANT TO RULE 4 [ 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. - 05-592 PATRICIA HOFFMAN - 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 DE02-311214 5 9 4 7 8- C O 2 >>> LOCATION LIST < PAGE: 1 LOCATION NAME RECORDS REQUESTED JOHNS HOPKINS HOSPITAL JOHNS HOPKINS HOSPITAL HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ASSOCIATED CARDIOLOGISTS JOHNS HOPKINS AT GREEN SPRING HEALTH SOUTH MECHANICSBURG FIRST CHOICE REHAB SPECIALISTS GEORGE HARHIGH, D.O. PA NEUROSCIENCE INSTITUTE, INC MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS E XRAYS MEDICAL RECORDS & XRAYS DE02-311214 5 9 4 7 8- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANNE PICCIRILLI, WIFE, AND WILLIAM File No. CUMBERLAND 05-3553 vs. DYAN FLYNN, ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JOHNS HOPKEVS 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. ESO. ADDRESS: 2411 N. FRONT ST. HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/C erk, Civj vt on Date: Deputy Seal of the Court 59478-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOHNS HOPKINS HOSPITAL 600 N. WOLFE STREET BALTIMORE, MD 21287 RE: 59478 ANNE PICCIRILLI 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 : ANNE PICCIRILLI 424 NO. 21ST STREET, CAMP HILL, PA 17011 Social Security #: 035-28-4901 Date of Birth: 04-12-1943 SU10-580916 59478-5.,02 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANNE PICCIRILLI, WIFE, AND WILLIAM PICCIRILLI, HUSBAND -vS- DYAN FLYNN, ET AL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE N0: 05-3553 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 DRII-585496 59478-L 03 C O M M O N W E A L T H OP P E N N S Y L VAN TA COUNTY OP C UMBER LAN D IN THE MATTER OF: ANNE PICCIRILLI, WIFE, AND WILLIAM PICCIRILLI, HUSBAND -VS- DYAN FLYNN, ET AL COURT OF COMMON PLEAS TERM, CASE NO: 05-3553 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOC3KENTS 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. - 05-592 PATRICIA HOFFMAN - 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 DE02-311214 59476-C!02 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED JOHNS HOPKINS HOSPITAL JOHNS HOPXINS HOSPITAL HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ASSOCIATED CARDIOLOGISTS JOHNS HOPKINS AT GREEN SPRING HEALTH SOUTH MECHANICSBURG FIRST CHOICE REHAB SPECIALISTS GEORGE HARHIGH, D.O. PA NEUROSCIENCE INSTITUTE, INC MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS 6 XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS 6 XRAYS DE02-311214 5 9 4 7 8- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANNE PICCIRILLI, WIFE, AND WILLIAM vs. DYAN FLYNN, ET AL File No. CUMBERLAND 05-3553 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HOLY SPIRIT 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: Prothonotary/Cler c, Civil tvtsi n Date: Ax.0, l? ?Kyns Deputy Seal of the Court 59478-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL 503 NORTH 21 ST STREET CAMP HILL, PA 17011 RE: 59478 ANNE PICCIRILLI 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 : ANNE PICCIRMLI 424 NO. 21ST STREET, CAMP HILL, PA 17011 Social Security N: 035-28-4901 Date of Birth: 04-12-1943 SU10-580918 59478-T,03 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANNE PICCIRILLI, WIFE, AND WILLIAM TERM, PICCIRILLI, HUSBAND CUMBERLAND -VS- CASE NO: 05-3553 DYAN FLYNN, ET AL 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 DE11-585497 S 94 7 8 - 1, 0 4 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 U M B E R L AN D IN THE MATTER OF: COURT OF COMMON PLEAS ANNE PICCIRILLI, WIFE, AND WILLIAM TERM, PICCIRILLI, HUSBAND -VS- CASE NO: 05-3553 DYAN FLYNN, ET AL 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. - 05-592 PATRICIA HOFFMAN - 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 DE02-311214 S 9 4 7 8- C O 2 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED JOHNS HOPKINS HOSPITAL JOHNS HOPXINS HOSPITAL HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ASSOCIATED CARDIOLOGISTS JOHNS HOPKINS AT GREEN SPRING HEALTH SOUTH MECHANICSBURG FIRST CHOICE REHAB SPECIALISTS GEORGE HARHIGH, D.O. PA NEUROSCIENCE INSTITUTE, INC MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS DE02-311214 5 9 4 7 8- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANNE PICCIRILLI, WIFE, AND WILLIAM File No. CUMBERLAND 05-3553 vs. DYAN FLYNN, ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HOLY SPIRIT 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 19101 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: l? Prothonotary/Clerk, Civil Nvisio Date: F, -Z 06? Deputy Seal of the Court 59478-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL 503 NORTH 21ST STREET CAMP HILL, PA 17011 RE: 59478 ANNE PICCIRILLI 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 : ANNE PICCIRILLI 424 NO. 21ST STREET, CAMP HILL, PA 17011 Social Security #: 035-28-4901 Date of Birth: 04-12-1943 SU10-580920 S9478-T-04 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANNE PICCIRILLI, WIFE, AND WILLIAM PICCIRILLI, HUSBAND -VS- DYAN FLYNN, ET AL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 05-3553 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 DE11-585498 59478-LOS C O M M O N W E A L T H OF' P E N N S Y L VAN TA COUNTY O EP C UMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS ANNE PICCIRILLI, WIFE, AND WILLIAM TERM, PICCIRILLI, HUSBAND -VS- CASE NO: 05-3553 DYAN FLYNN, ET AL 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. - 05-592 PATRICIA HOFFMAN - 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 DE02-311214 S 9 4 7 8- C O 2 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED JOHNS HOPKINS HOSPITAL MEDICAL RECORDS JOHNS HOPKINS HOSPITAL X-RAY ONLY HOLY SPIRIT HOSPITAL MEDICAL RECORDS HOLY SPIRIT HOSPITAL X-RAY ONLY ASSOCIATED CARDIOLOGISTS MEDICAL RECORDS JOHNS HOPKINS AT GREEN SPRING MEDICAL RECORDS HEALTH SOUTH MECHANICSBURG MEDICAL RECORDS FIRST CHOICE REHAB SPECIALISTS MEDICAL RECORDS GEORGE HARHIGH, D.O. MEDICAL RECORDS PA NEUROSCIENCE INSTITUTE, INC MEDICAL RECORDS & XRAYS 6 XRAYS & XRAYS & XRAYS & XRAYS & XRAYS DE02-311214 59478-C!02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANNE PICCIRILLI, WIFE, AND WILLIAM vs. DYAN FLYNN, ET AL File No. CUMBERLAND 05-3553 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ASSOCIATED CARDIOLOGISTS (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 Groun 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: 14 Prothonotary/C] k, Ci ivi-ion Date: /'P1 szoos Deputy Seal of the Court 59478-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ASSOCIATED CARDIOLOGISTS 2808 OLD POST ROAD HARRISBURG, PA 17110 RE: 59478 ANNE PICCIRILLI 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 : ANNE PICCIRILLI 424 NO. 21ST STREET, CAMP HILL, PA 17011 Social Security #: 035-28-4901 Date of Birth: 04-12-1943 SU10-580922 S 9 4 7 8- L 0 S CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANNE PICCIRILLI, WIFE, AND WILLIAM PICCIRILLI, HUSBAND -VS- DYAN FLYNN, ET AL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 05-3553 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 DE11-585499 59478-T-06 C O M M O N W E A L '1711 OP P E N N S Y L VAN T A COUNT Y OP C UMBER LAN D IN THE MATTER OF: ANNE PICCIRILLI, WIFE, AND WILLIAM PICCIRILLI, HUSBAND -VS- DYAN FLYNN, ET AL COURT OF COMMON PLEAS TERM, CASE NO: 05-3553 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. - 05-592 PATRICIA HOFFMAN - 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 DE02-311214 S 9 4 7 8- C O 2 >>> LOCATION LIST <<< PAGE: I LOCATION NAME RECORDS REQUESTED JOHNS HOPKINS HOSPITAL JOHNS HOPKINS HOSPITAL HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ASSOCIATED CARDIOLOGISTS JOHNS HOPKINS AT GREEN SPRING HEALTH SOUTH MECHANICSBURG FIRST CHOICE REHAB SPECIALISTS GEORGE HARHIGH, D.O. PA NEUROSCIENCE INSTITUTE, INC MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS 6 XRAYS MEDICAL RECORDS 6 XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS 6 XRAYS DE02-311214 59478-C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANNE PICCIRILLI, WIFE, AND WILLIAM vs. DYAN FLYNN, ET AL File No. CUMBERLAND 05-3553 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JOHNS HOPKINS AT GREEN SPRING (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/Clerk, Ci iv ion `J" t aO?s Date: Deputy Seal of the Court 59478-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR JOHNS HOPKINS AT GREEN SPRING STATION 10753 FALLS RD.,#360 LUTHERVILLE, MD 21093 RE: 59478 ANNE PICCIRILLI 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 : ANNE PICCEMLLI 424 NO. 21ST STREET, CAMP HILL, PA 17011 Social Security #: 035-28-4901 Date of Birth: 04-12-1943 SU'_0-580924 59478-L,06 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANNE PICCIRILLI, WIFE, AND WILLIAM PICCIRILLI, HUSBAND -VS- DYAN FLYNN, ET AL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 05-3553 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 DE11-585500 S9478-1,07 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 UMBER LAN D IN THE MATTER OF: ANNE PICCIRILLI, WIFE, AND WILLIAM PICCIRILLI, HUSBAND -VS- DYAN FLYNN, ET AL COURT OF COMMON PLEAS TERM, CASE NO: 05-3553 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. - 05-592 PATRICIA HOFFMAN - MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET (1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-311214 59478-C02 >>> LOCATION LIST <<< ON NAME JOHNS HOPKINS HOSPITAL JOHNS HOPKINS HOSPITAL HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ASSOCIATED CARDIOLOGISTS JOHNS HOPKINS AT GREEN SPRING HEALTH SOUTH MECHANICSBURG FIRST CHOICE REHAB SPECIALISTS GEORGE HARHIGH, D.O. PA NEUROSCIENCE INSTITUTE, INC RECORDS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS E XRAYS MEDICAL RECORDS 6 XRAYS PAGE: 1 DE02-311214 5 9 4 7 8- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANNE PICCIRILLI, WIFE, AND WILLIAM vs. DYAN FLYNN, ET AL File No. CUMBERLAND 05-3553 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HEALTH SOUTH MECHANICSBURG (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/ erk,`Civi t ision Date: Deputy Seal of the Court 59478-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HEALTH SOUTH MECHANICSBURG 175 LANCASTER BOULEVARD MECHANICSBURG, PA 17055 RE: 59478 ANNE PICCIRILLI 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 : ANNE PICCIRILLI 424 NO. 21ST STREET, CAMP HILL, PA 17011 Social Security 1!: 035-28-4901 Date of Birth: 04-12-1943 SU10-580926 5 9 4 7 8- 1, 0 7 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANNE PICCIRILLI, WIFE, AND WILLIAM PICCIRILLI, HUSBAND -VS- DYAN FLYNN, ET AL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 05-3553 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 DE11-585501 5 9 4 7 8- L O 8 C O M M O N W E A L T H OF' P E NN S Y L VAN 1A COUNTY OF' C U M B E R L AN D IN THE MATTER OF: COURT OF COMMON PLEAS ANNE PICCIRILLI, WIFE, AND WILLIAM PICCIRILLI, HUSBAND -VS- TERM, DYAN FLYNN, ET AL A CASE NO: 05-3553 )ENA TO PRODUCE DOCUMENTS FLE 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 MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT CC: CASEY SHORE, ESQ. - 05-592 PATRICIA HOFFMAN - Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-311214 5 9 4 7 8- C O 2 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED JOHNS HOPKINS HOSPITAL JOHNS HOPKINS HOSPITAL HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ASSOCIATED CARDIOLOGISTS JOHNS HOPKINS AT GREEN SPRING HEALTH SOUTH MECHANICSBURG FIRST CHOICE REHAB SPECIALISTS GEORGE HARHIGH, D.O. PA NEUROSCIENCE INSTITUTE, INC MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS 6 XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS DE02-311214 5 9 4 7 8- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANNE PICCIRILLI, WIFE, AND WILLIAM vs. DYAN FLYNN, ET AL File No. CUMBERLAND 05-3553 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for FIRST CHOICE REHAB SPECIALISTS (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/Clerk, Civil-D' ton Date: A nos Deputy Seal of the Court 59478-08 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR FIRST CHOICE REHAB SPECIALISTS 1790 OLD TRAIL ROAD SUITE F ETTERS, PA 17319 RE: 59478 ANNE PICCIRILLI 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 : ANNE PICCHRILLI 424 NO. 21ST STREET, CAMP HILL, PA 17011 Social Security #: 035-28-4901 Date of Birth: 04-12-1943 SU10-580928 59478-1,08 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANNE PICCIRILLI, WIFE, AND WILLIAM PICCIRILLI, HUSBAND -VS- DYAN FLYNN, ET AL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 05-3553 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 DE11-585502 S 9 4 7 8- L 0 9 C O M M O N W E A L T H O Y P E N N S Y L VAN T A COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS ANNE PICCIRILLI, WIFE, AND WILLIAM TERM, PICCIRILLI, HUSBAND -VS- CASE NO: 05-3553 DYAN FLYNN, ET AL NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS T 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. - 05-592 PATRICIA HOFFMAN - 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 DE02-311214 5 9 4 7 8- C O 2 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED JOHNS HOPKINS HOSPITAL JOHNS HOPKINS HOSPITAL HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ASSOCIATED CARDIOLOGISTS JOHNS HOPKINS AT GREEN SPRING HEALTH SOUTH MECHANICSBURG FIRST CHOICE REHAB SPECIALISTS GEORGE HARHIGH, D.O. PA NEUROSCIENCE INSTITUTE, INC MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS 6 XRAYS MEDICAL RECORDS 6 XRAYS DE02-311214 5 9 4 7 8- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANNE PICCIRILLI, WIFE, AND WILLIAM vs. DYAN FLYNN. ET AL File No. CUMBERLAND 05-3553 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for GEORGE HARHIGH. D.O. (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 Grouo. 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/Clerk, Civt Div ion ry Deputy Date: L p r , s Seal of the Court 59478-09 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: GEORGE HARHIGH, D.O. 25 SOUTH 35TH STREET CAMP HILL, PA 17011 RE: 59478 ANNE PICCIRILLI 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 : ANNE PICCIRILLI 424 NO. 21ST STREET, CAMP HILL, PA 17011 Social Security ll: 035-28-4901 Date of Birth: 04-12-1943 SU10-580930 59478-L 09 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANNE PICCIRILLI, WIFE, AND WILLIAM PICCIRILLI, HUSBAND -VS- DYAN FLYNN, ET AL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 05-3553 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 DE11-585503 S 9 4 7 8- L 1 0 C O M M O N W E A L T H OP P E N N S Y L VAN T A COUNTY OP C UMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS ANNE PICCIRILLI, WIFE, AND WILLIAM TERM, PICCIRILLI, HUSBAND -VS- CASE NO: 05-3553 DYAN FLYNN, ET AL NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOC NM NTS 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. - 05-592 PATRICIA HOFFMAN - 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 DE02-311214 5 9 4 7 8- C O 2 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED JOHNS HOPKINS HOSPITAL JOHNS HOPKINS HOSPITAL HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ASSOCIATED CARDIOLOGISTS JOHNS HOPKINS AT GREEN SPRING HEALTH SOUTH MECHANICSBURG FIRST CHOICE REHAB SPECIALISTS GEORGE HARHIGH, D.O. PA NEUROSCIENCE INSTITUTE, INC MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS 6 XRAYS DE02-311214 5 9 4 7 8- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANNE PICCIRILLI, WIFE, AND WILLIAM vs. DYAN FLYNN, ET AL File No. CUMBERLAND 05-3553 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PA NEUROSCIENCE INSTITUTE. INC (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** 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/CL rk, Civil Di i n Date: Deputy Seal of the Court 59478-10 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PA NEUROSCIENCE INSTITUTE, INC 4310 LONDONDERRY ROAD HARRISBURG, PA 17109 RE: 59478 ANNE PICCIRILLI 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 : ANNE PICCIRILLI 424 NO. 21ST STREET, CAMP HILL, PA 17011 Social Security #: 035-28-4901 Date of Birth: 04-12-1943 SU10-580932 5 9 4 7 8- L 1 0 ?) N p C_ cn ? j .-1 S? ? h) -a s?i ? • ? r? 'sr ANNE PICCIRILLI, wife, and WILLIAM : IN THE COURT OF COMMON PLEAS PICCIRILLI, husband CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs VS. NO. 05-3553 Civil Term DYAN FLYNN, a.k.a., DYAN REGAN, a.k.a., DIANE SHENK, a.k.a. DIANE FLYNN, and DIANE FLYNN, Defendants JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Anne and William Piccirilli and their attorney Scott B. Cooper, Esquire Schmidt Ronca & Kramer 209 State Street Harrisburg, PA 17101 YOU ARE HEREBY NOTIFIED to file a written response to the enclosed Answer with New Matter within twenty (20) days from service hereof or a judgment may be entered against you. Respectfully submitted, NEALON GOVER & PERRY By: , a. C G. Shore, Esquire Attorney I.D. No. 85321 2411 North Front St. Harrisburg, PA 17110 Date: q o (717) 232-9900 ANNE PICCIRILLI, wife, and WILLIAM : IN THE COURT OF COMMON PLEAS PICCIRILLI, husband CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs VS. NO. 05-3553 Civil Term DYAN FLYNN, a.k.a., DYAN REGAN, a.k.a., DIANE SHENK, a.k.a. DIANE FLYNN, and DIANE FLYNN, Defendants JURY TRIAL DEMANDED ANSWER TO COMPLAINT WITH NEW MATTER 1-5. Admitted based upon information and belief. 6. Neither admitted nor denied. Discovery is ongoing in this case and the Defendant is without sufficient information to form a belief as to the truth of this averment. To the extent that an answer is required, the averment is denied. COUNTI 7. No answer required. 8-15. Denied pursuant to Rule 1029(e) of the Pennsylvania Rules of Civil Procedure. WHEREFORE, the Defendant, Diane Flynn, respectfully requests that Count I of the Complaint be dismissed with costs to be paid by the Plaintiffs. COUNT II 16. No answer required. 17. Denied pursuant to Rule 1029(e) of the Pennsylvania Rules of Civil Procedure. WHEREFORE, the Defendant, Diane Flynn, respectfully requests that Count II of the Complaint be dismissed with costs to be paid by the Plaintiffs. NEW MATTER 18. Paragraphs 1-17 are incorporated herein as if reference were made thereto. 19. The Plaintiffs' claims may be barred in whole or in part by application of the Pennsylvania Motor Vehicle Financial Responsibility Act. WHEREFORE, the Defendant, Diane Flynn, respectfully requests that the Complaint against her be dismissed with costs to be paid by the Plaintiffs. Respectfully submitted, NEALON GOVER & PERRY By: C G. Shore, Esquire I.D. #: 85321 2411 North Front Street Harrisburg, PA 17110 717/232-9900 Date: 9 130 L VERIFICATION I, DIANE FLYNN, 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. §34904 relating to unsworn falsification to authorities. Date: `t'om' DIANE FLYNN CERTIFICATE OF SERVICE AND NOW, this 36a, day of, 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 209 State Street Harrisburg, PA 17101 L Case . Shore, Esquire ?? ? O CJ ? . ^ { ? ? _ { i ?- "l lll J r -•, ? ?? Lid ??^'? ' ?; i ? =? ?{it ?_ ? t . _. f.. r.7 .{ SHERIFF'S RETURN - REGULAR CASE NO: 2005-03553 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CIRILLI WILLIAM ET AL VS FLYNN DYAN AKA DYAN REGAN AKA DAVID MCKINNEY , Sheriff or Cumberland County,Pennsylvania, who being says, the within NOTICE FLYNN DYAN AKA DYAN REGAN AKA DIANNE SHENK DEFENDANT , at 0016:05 HOURS, on the Dep 3uly was AKA 5th -ity Sheriff of sworn according to law, served upon DIANE FLYNN the day of August , 2005 at 1 LEMOYNE SQUARE PLAZA CAMP HILL, PA 17011 by handing to DYAN REGAN (OWNER) a true and attested copy of NOTICE together with COMPLAINT and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 00 .00?c f .00 .00 R. Thomas Kline .00 .00 08/08/2005 SCHMIDT, RONCA & KRAMER Sworn and Subscribed to before me this day of Q O5 A.D. Prothonotary By: Deputy Sheriff ANNE PICCIRILLI, wife, and WILLIAM PICCIRILLI, husband. Plaintiffs, V. DYAN FLYNN, a.k.a., DYAN REGAN, a.k.a., DIANE SHENK, a.k.a. DIANE FLYNN, and DIANE FLYNN, Defendants. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 05-3553 JURY TRIAL DEMANDED PLAINTIFF'S REPLY TO DEFENDANT'S NEW MATTER 18. Paragraph 18 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. 19. Paragraph 19 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 19 and demands strict proof thereof from the Defendant prior to trial. WHEREFORE, the Plaintiffs respectfully requests that the Defendant's New Matter be dismissed with prejudice and that the relief requested in their Complaint be awarded. Respectfully Submitted, Date: ?'o?,e' )? 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 Plaintiffs ATTORNEY VERIFICATION I, Scott B. Cooper, Esquire, verify that I am attorney of record for the Plaintiffs. I verify that the facts contained in the foregoing Plaintiff's 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:?V 4,/ Scott B. Cooper CERTIFICATE OF SERVICE AND NOW, thiEj day of 2005, I hereby certify that I have, this day, caused a copy of the foregoing Plaintiffs 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: "A/ Scott B. Cooper, Esquire I.D.# 70242 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs ,?> ?: ? -, =, ? <;. r _ OR/ PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANNE PICCIRILLI, WIFE, AND WILLIAM PICCIRILLI, HUSBAND -vs- DYAN FLYNN, ET AL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 05-3553 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JENNI ALLEN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 08/26/2006 MCS on behalf of Ih?J?mrw AtLM, Eft JE I ALLEN, ESQ. Attorney for DEFENDANT R1.18 133-H DE11-0643647 59478-L11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANNE PICCIRILLI, WIFE, AND WILLIAM PICCIRILLI, HUSBAND -VS- DYAN FLYNN, ET AL COURT OF COMMON PLEAS TERM, CASE NO: 05-3553 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 GOOD SAMARITAN HOSPITAL MEDICAL RECORDS GOOD SAMARITAN HOSPITAL X-RAY ONLY TO: SCOTT B. COOPER, ESQ., PLAINTIFF COUNSEL MCS on behalf of JENNI ALLEN, 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: 08/08/2006 CC: JENNI ALLEN, ESQ. - 05-592 PATRICIA HOFFMAN - MCS on behalf of JENNI ALLEN, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.15S 133-H DE02-0339102 59478-C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANNE PICCIRILLI, WIFE, AND WILLIAM VS. DYAN FLYNN, ET AL File No. 05-3553 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for GOOD SAMARITAN 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 MCC Grottp 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: JENNI ALLEN. ESO. ADDRESS: 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: 151246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY T COURT: Pr onotw)y 0 c Civil ivision Date: A(AQ .7.?U 6 Deputy Seal of the Court 59478-11 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: GOOD SAMARITAN HOSPITAL 5601 LOCH RAVEN BLVD BALTIMORE, MD 21239 RE: 59478 ANNE PICCIRILLI Prior approval is required 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 : ANNE PICCIRILLI 424 NO. 21ST STREET, CAMP HILL, PA 17011 Social Security #: XXX-XX-4901 Date of Birth: 04-12-1943 R1.15S 133-H SU10-0636338 59478-L11 D / #,1 t PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANNE PICCIRILLI, WIFE, AND WILLIAM PICCIRILLI, HUSBAND -VS- DYAN FLYNN, ET AL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 05-3553 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JENNI ALLEN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 08/28/2006 MCS on behalf of 191 i mru. AR m, &f.. JENNI ALLEN, ESQ. Attorney for DEFENDANT R1.18 133-H DE11-0643648 59478-L12 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANNE PICCIRILLI, WIFE, AND WILLIAM PICCIRILLI, HUSBAND -VS- DYAN FLYNN, ET AL COURT OF COMMON PLEAS TERM, CASE NO: 05-3553 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 GOOD SAMARITAN HOSPITAL MEDICAL RECORDS GOOD SAMARITAN HOSPITAL X-RAY ONLY TO: SCOTT B. COOPER, ESQ., PLAINTIFF COUNSEL MCS on behalf of JENNI ALLEN, 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: 08/08/2006 CC: JENNI ALLEN, ESQ. - 05-592 PATRICIA HOFFMAN - MCS on behalf of JENNI ALLEN, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 133-H_ 1)902-0339102 59478-CO2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANNE PICCHULLI, WIFE, AND WILLIAM VS. DYAN FLYNN, ET AL File No. 05-3553 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for GOOD SAMARITAN 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: **** SE ATTACHED RIDER **** at The MCC Croyp Inc 1601 Market Street Suite R00 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: JENNI ALLEN. ESO. ADDRESS: 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (2151246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY T OURT: Pro ono/ , ivil D 'sion nL-? axo(. Deputy Date: ?•( Seal of the Court EXPLANATION OF REQUIRED RECORDS T0: CUSTODIAN OF RECORDS FOR GOOD SAMARITAN HOSPITAL RADIOLOGY DEPT. 5601 LOCH RAVEN BLVD BALTIMORE, MD 21239 RE: 59478 ANNE PICCIRILLI Prior approval is required 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 : ANNE PICCIRILLI 424 NO. 21ST STREET, CAMP HILL, PA 17011 Social Security #: XXX-XX-4901 Date of Birth: 04-12-1943 R1.15S 133-H SII10-0636340 59478-L12 c> . -?, ?` , ? `?' r??.i '?c: .,nrn ,?' ? (jl CY3 '?'" ;.. ?Ci '-s^ rJrn _? CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANNE PICCIRILLI, WIFE, AND WILLIAM -VS- DYAN FLYNN, ET AL ORIGIN-W COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 05-3553 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JENNI ALLEN, 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 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: 11/07/2006 7 M7S on behalf o, JE ALLEN, ESQ. Attorney for DEFENDANT R1.23 133-H DE12-0244263 59478-L13 7172325457 NOV-09-06 01:55PM FROM-SCHMIDT,RONCA & KRAMER PC 717 232 6467 T-947 P.001/001 F-360 1601 Market Street, Suite 800, pbBadtlphia Peansylvania 19103 (275) 246 - 0900 Fax Number (215) 246 - 0959 ! ! URGENT! ! t ! ! URGENT! ! ! ! ! URGENT! W! NOVEMBER 7, 2006 ANNE PICCHULLI ANNE PICCIRILLI, WIPE, AND WILLIAM Vs DYAN FLYNN, ET AL NEALON, DOVER, ET AL 3ENNI ALLEN, ESQ. - ( ) - We have been requested by the above--meationed counsel to Obtain Material On an expedited basis from the below listed custodiam. In order to comply with this request we must have your signature indicating that you waive the t e. my-day notice period provided in Ruby 4.009.21 a.?xi 4009.22. rlcasw fan this £oxvA to u3 immcdiatcly at 215) 216 0959 with your siswure so that we may comply with this request. Your cooperation would be greatly appreciated. Sincerely, CAROL IiAMILTON Custodians: HEALTHSOUTH-DLkGNOSTIC CTRS. - OTHER MRI Counsel: , SCOTT B. COOPER, ESQ. (7 232-6 7 X I agree to waive waiting period Date: Review Documents: Yes I do not agree to waive rule: Date: Copies: Yes No T agree to pay the invoice provided with the doeument? Billing Info: No Advise of Cast 12RW1-0002753 59478-C41 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANNE PICCIRILLI, WIFE, AND WILLIAM PICCIRILLI, HUSBAND -VS- DYAN FLYNN, ET AL COURT OF COMMON PLEAS TERM, CASE NO: 05-3553 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HEALTHSOUTH-DIAGNOSTIC CTRS. OTHER MRI TO: SCOTT B. COOPER, ESQ., PLAINTIFF COUNSEL MCS on behalf of JENNI ALLEN, 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: 11/07/2006 MCS on behalf of CC: JENNI ALLEN, ESQ. - 05-592 PATRICIA HOFFMAN - Any questions regarding this matter, contact JENNI ALLEN, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.23 133-H DE02 59478-C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANNE PICCIRILLI, WIFE, & WILLIAM PICCIRILLI, HUSBAND -VS- DYAN FLYNN, ET AL File No. 05-3553 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: HEALTHSOUTH-DIAGNOSTIC CTRS. (;tame of Person or Entity) Within twentv (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED at MCS GROUP INC. 1601 MARKET ST, STE 800, PHILA PA 19103 (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: JENNI ALLEN, ESQ. ADDRESS: 7411 NORTn FRMu gTRRF.'r HARRISBURG. PA 17110 TELEPHONE: (?15) 4 -0900 SUPREME COURT ID ;#: ATTORNEY FOR: DE1 ENDANT THE COURT: DATE- A l ambers 13, Cun Protnonota /Cleri:. C161 Division - Lbn- kJ Axd?- Deoun• Seal of the Court (E}f. 7/07) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HEALTHSOUTH-DIAGNOSTIC CTRS. 4349 CARLISLE PIKE CAMP HILL„ PA 17011 RE: 59478 ANNE PICCIRILLI Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. ANY AND ALL MRI FILMS FROM 5/3/03 AND 12/3/03 Dates Requested: up to and including the present. Subject : ANNE PICCIRILLI 424 NO. 21ST STREET, CAMP HILL, PA 17011 Social Security #: XXX-XX-4901 Date of Birth: 04-12-1943 R1.23 133-H SU10 59478-L13 '?'? Sri PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: (Check one) ( g ) for JURY trial at the next term of civil court. ( ) for trial without a jury. ----------------------------------------------- ----------------------------------- - -------------------- ------------------- --------- --------------------------- ------ CAPTION OF CASE (entire caption must be stated in full) Anne Piccirilli and William Piccirilli (Plaintiff) vs. Dyan Flynn a.k.a. Dyan Regan a.k.a. Diane Shenk a.k.a. Diane Flynn and Diane Flynn (Defendant) vs. (check one) ( j Assumpsit ( ) Trespass ( ) Trespass (Motor Vehicle) (x) Motes Vehicle--Acc1dent__ (other) The trial list will be called on March 4 , 200.8__ and Trials commence on March 31L 2008____._.. Pretrials will be held onMar_ch 12, 2008.__._.. (Briefs are due 5 days before pretrials.) (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214-1.) No.05-3553 Civil 19 - Indicate the attorney who will try case for the party who files this praecipe: ------ _____-_________ ______ Scott B Coop er -- ----_ Indicate trial counsel for other parties if known: _C-ase_y__-Sho-r-e?.._F-sdu re__and_ Zr-i-c__ Weiner, Esquire---- ----- - ---- - --- --- --- This case is ready for trial. Date: January 25,__2008 Signed: - -?./ - -- --- - Print Name: Attorney for: _ Pl.a.intiffs :? b ANNE PICCIRILLI, wife, #9 IN THE COURT OF COMMON PLEAS OF and WILLIAM PICCIRILLI, CUMBERLAND COUNTY, PENNSYLVANIA husband, Plaintiffs V. NO. 05-3553 CIVIL TERM DYAN FLYNN, a.k.a. DYAN REGAN, a.k.a. DIANE SHENK,: a.k.a. DIANE FLYNN, and DIANE FLYNN, Defendant JURY TRIAL DEMANDED IN RE: PRETRIAL CONFERENCE A pretrial conference was held Wednesday, March 12, 2008, before the Honorable Edward E. Guido, Judge. Present for the Plaintiffs was Scott B. Cooper, Esquire, and present for the Defendant was Casey G. Shore, Esquire. This is a motor vehicle accident in which liability is admitted. The only issue is the nature and extent of the damages caused by the accident. The parties anticipate this will take two days to try. Mr. Cooper has a pre-paid vacation scheduled for later in the week. Therefore, it is requested that this case be scheduled for Monday of trial week. There are no complicated legal issues. Settlement negotiations are ongo Court Edward E. Guido, J. Scott B. Cooper, Esquire For the Plaintiffs Casey G. Shore, Esquire For the Defendant TRUE COPY FROM RECOIL Amorry wh f,1 has otft sat my haj lie of said Court at N618 ,Pa. 44 'Prothonotary Court Administrator srs Vb ANNE PICCIRILLI, wife, : and WILLIAM PICCIRILLI,: Plaintiffs V. DYAN REGAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 05-3553 CIVIL TERM VERDICT [In this case, Defendant concedes that her negligence caused the accident that occurred on August 5, 2003, and that Plaintiff Anne Piccirilli suffered some harm as a result. Accordingly, the only questions that you have to decide are the following] Question 1: With respect to the harm to Plaintiff Anne Piccirilli that you find Defendant's negligence was a factual cause of, state the total amount of damages that you find she sustained in the following categories: 00 1. Non-economic losses: $; 2. Economic losses in the form of past medical expenses: $ Question 2: With respect to Plaintiff William Piccirilli, state the total amount of damages, if any, for loss of consortium that you find Defendant's negligence was a factual cause of: $500* (Date) ri s (Foreperson) y 0 7?p % i L7 4uuc aA4X • . 9 CASE NO.: COURTROOM NO.: ? Ann j Y,ec ; t`1 (C. l i.Q lit P; et _,,-+ `kS b 4Q n DOCKET NO.: ?S 3SS3 , d , DATE: 3! ? ?l p Juror # Name ...,...+35),"°.? P'IS Random No 4iG/.F..ds9Aa7Y.S?), ea4r vy ..T'.. . 3Fu... .1n .. en, iev^>:ves^.Ct . t; ? 132 CAMPBELL, LAURA j. -1985218725 A 49&;260844 - ? ' B&4N+p f 96 FAZAKERLEY, ROBERT D. -1954807380 102 CLARK, MATTHEW -1868168072 6 124 RYAN, THOMAS E. -1417108983 112 TRITT, BRUCE G. -1292272149 114 BRANDON, JAMES G. -1061403568 ( 138 SHEAFFER, DEBORAH -749698275 1 1 105 FREIDHOF, TINA L. -463247121 969958950 4 a 13 136 MELLOTT, ROGER R. -357618921 14 128 NGO, PHUONG -248296283 i (7 ( % -95 116 KREBS, JANE T. Z6743 - -76676354 P t y T 3 19 125 MCGINTY, JACOB A. -36138602 20 133 TWIGG, RYAN M 53886208 v ( 104 ALBRIGHT, HARRY F. 112287590 123 KOUVELIS, ARTHUR 391460648 24 93 ZEIGLER, JILLIAN M. 483018446 2 5 126 HOKE, STEPHANIE A. 694049631 26 130 CEKOVICH, GARY N. 757118722 2 7 119 FREILINO, JOHN E. 874568028 2"s 137 ANDERSON, MARK A 876690700 2() 120 GILES, TRICIA K 940498221 30 107 FIESELER, JONATHAN S. 1182804996 31 127 VRIENS, NATHAN 1215130036 3G 118 MATAFKA, JUDY 1384561319 33 140 WENGER, NEVIN JAY 1408168595 14 103 PFEIL, GERARD 1530042649 5 121 KRUEGER, TRUDY K. 1603489514 36 135 BABCOCK, PATRICIA L. 1672833838 Monday, March 31, 2008 Page 1 of 2 A&do t,ec ?o64 36 ?i juror # Name 139 NEWHOUSE, KENNETH 141 CONRAD, IRENE LARUE 108 GREBAS, JEFFREY Monday, March 31, 2008 Random No. 1899174426 1957737944 2031310005 Page 2 of 2