HomeMy WebLinkAbout01-3501
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
JEANNE M. WEBER
Plain tiff
NO.: Ot - .3S'6(
Cu~l 'i~
CIVIL ACTION - LAW
v.
MATTHEW JOHN THOMAS
Defendant
JURY TRIAL DEMANDED
NOTTCR
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth
against you 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 default 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 OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THIS OFFICE SET FORTH BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
(7171 846-0606
CUMBERLAND COUNTY BAR ASSOCIATION
Lawyer Referral Service
Two Liberty Street
Carlisle, Pennsylvania 17013
(717) 249 - 3166
1-800-990-9108
LAW OFFICES OF
AI..E E. ANSTINE" P. C.
TWO WEST MARKET STREET
POST OFFICE BOX 952
YORK, PJ;:N"XSYLVANIA. 17....05
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
JEANNE M. WEBER
Plaintiff
NO.:
CIVIL ACTION - LAW
vi.
MATTHEW JOHN THOMAS
Defendant
JURY TRIAL DEMANDED
A VTSO
USTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea defenderse de las
quejas expuestas en las paginas siguientes, debe tomar acci6n dentro de veinte (20) dias a partir de
la fecha en que recibi6 la demanda y e1 aviso. Usted debe presentar comparecencia escrita en
persona 0 par abogado y presentar en la Corte por escrito sus defensas 0 sus objeciones alas
demandas en su contra.
Se Ie avisa que si no se defiende, el caso puede proceder sin usted y la Corte puede decidir
en su contra sin mas aviso 0 notificaci6n por cualquier dinero rec1amado en la demanda 0 par
cualquier otra queja 0 compensaci6n rec1amados por el Demandante. USTED PUEDE PERDER
DINERO, 0 PROPRIEDADES U OTROS DERECHOS IMPORTANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE.
SI USTED NO TIENE 0 NO CONOCE UN ABOGADO, V AYA 0 LLAME A LA
OFICINA EN LA DIRECCION ESCRITA ABAJO PARA A VERIGUAR DONDE
PUEDE OBTENER ASISTENCIA LEGAL.
TWO WEST MARKET STREET
POST OFFICE BOX 952
YORK, PR'NNSYLVANlA 17405
CUMBERLAND COUNTY BAR ASSOCIATION
Lawyer Referral Service
Two Liberty Street
Carlisle, Pennsylvania 17013
(717) 249 - 3166
1-800-990-9108
LAW OFFICES OF
)ALE E. ASSTINE, P. C.
LAW OFFICES OF
)ALE E. ANSTINE, P. c..
TWO WEST MARKET STREE:T
POST OFFICE BOX 952
YORK, Pfl~NSYLVANTA 17405
(717) 846-0606
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
JEANNE M. WEBER
Plaintiff
NO.: 0 J~ 3 50) ~ ~ u...--
CIVIL ACTION - LAW
v.
MATTHEW JOHN THOMAS
Defendant
JURY TRIAL DEMANDED
COMPLAINT
1. The Plaintiff is an adult individual residing at 150 Pine Tree Road, Orrtanna, P A
17353.
2. The Defendant is a minor individual having a date of birth of March 15, 1984 who
resides at 13 Westwind Drive, Lemoyne, P A 17043.
3, On October 20,2000, the Plaintiff was a passenger in a Ford Ambulance bearing PA
registration plate 14308-MG which was operated by Charles Sherman and owned by Lower
Allen Township.
4. On October 20, 2000, the Defendant was the operator a 1999 Volkswagen Passat bearing
P A registration plate BWW -6897 which was owned by and used with the permission of Charles
E. Thomas and Joyce D. Thomas.
5. On October 20,2000 at approximately 5:00 p.m., the Plaintiff was a passenger in the
aforesaid ambulance in the course of her duties as an EMS personnel, and the ambulance was
proceeding on an emergency call with all of its emergency equipment and lights activated.
6. At that same time and place, the ambulance was being operated eastbound on State Route
2018, Carlisle Road approaching its intersection with State Route 2033, Creek Road, and was
intending to proceed straight through the intersection.
7. At that same time and place, the operator of the ambulance approached the intersection
with his emergency lights and equipment activated, stopped the ambulance to ensure he could
safely proceed to the intersection, and began to proceed slowly through the intersection.
8. At that same time and place, the Defendant was operating his vehicle northbound on
Creek Road at an excessive rate of speed when he failed to stop or take other evasive action and
collided with the ambulance in the intersection resulting in injuries and damages to the Plaintiff.
9. This accident occurred as a result of the negligence of the Defendant and was due
in no manner to any act, or failure to act, on the part of the Plaintiff.
10. This matter is alleged to exceed the applicable limits of arbitration, and a jury trial
is hereby demanded.
11. The negligence of Defendant Thomas consisted of the following:
a) Failing to properly operate and control his motor vehicle;
b) Failing to keep alert and maintain a proper lookout for the presence
of other motor vehicles on the streets and highways;
c) Operating his vehicle in careless disregard for the safety of others and
the Plaintiff in particular, in violation of75 Pa.C.S. 93714;
LAW OFFICES OF
:JALE E. ANSTINE, P. C"
TWO WEST MARKET STREET
POST OFFICE BOX 952
YORK, PENNSYLVANIA 17405
d)
Operating his vehicle too fast for the conditions then and there
existing, in violation of75 Pa.C.S. 93361;
(717) 846-0606
e) Failing to yield the right-of-way to the ambulance in violation of75
Pa.C.S. 93325(a); and
2
LAW OFFICES OF
[)ALE E. A~8TJNE,P. c.
TWO WEST MARKET STREET
POST OFFICE BOX 952
YORK, PENNSYLVANIA 17405
f) Failing to observe the presence ofthe ambulance within a sufficient
period of time to stop his vehicle before entering the intersection
when the Defendant knew or should have known of the presence of
the ambulance.
12. As a result of the negligence of the Defendant, the Plaintiff suffered
serious and permanent injuries including lumbar sprain/strain, sacroiliac strain, hip pain,
pelvic pain, left knee pain and severe shock to her nerves and nervous system.
13. As a result of the negligence of the Defendant, the Plaintiff was forced to
incur medical bills and expenses for the injuries she has suffered, the cost or reasonable value of
which is, or may be, in excess of the sum recoverable under the Pennsylvania Motor Vehicle
Financial Responsibility Law, and she will continue to incur medical expenses in the future.
14. As a result of the negligence ofthe Defendant, the Plaintiffhas suffered, or may suffer, a
severe loss of her earnings and impairment of her earning capacity. This loss of income and
impairment of earning capacity has exceeded, or may exceed, the sum recoverable under the
Pennsylvania Motor Vehicle Financial Responsibility Law, and the loss of income and impairment
of earning capacity will, or may, continue in the future.
15. As a result of the negligence of the Defendant, the Plaintiff has undergone, and in
the future may undergo, great mental and physical pain and suffering, mental anguish and
humiliation, loss of life's pleasures, and a severe limitation in her pursuit of daily
activities, all to her great loss and detriment.
3
> .
:lAI~": E. AN~TINE, P. c.
TWO WEST MARKET STREET
POST OFFICE BOX 952
YORK, PENNSYI.VANIA 17-1-05
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter
judgment against the Defendant in an amount in excess of the mandatory arbitration limits.
RESPECTFULLY SUBMITTED:
LAW OFFICES OF DALE E. ANSTINE, P.C.
Leah~e)tO
Attorney LD. #29176
Two West Market Street
P.O. Box 952
Yark, Pennsylvania 17405
(717) 846 - 0606
4
. '
LAW OFFICES OF
)AI..F; E. ANSTINE, Ill. C.
TWO WEST MARKET STREET
POST OFFICE BOX 952
YORK, PF,NNSYLVANTA 17405
VERIFICATION
I HEREBY VERIFY that the information set forth in the foregoing Complaint is true and
correct to the best of my knowledge, information and belief. I understand that any false
statements contained herein are subject to the penalties of 18 Pa.C.S. 94904, relating to unsworn
falsification to authorities.
Date: W 'I It} /
,
~?~aJ~
F:\FI LES\DA T AFILE\Travdoc,cur\723-pra.l/mah
Created: O"tf!2/01 lO:49:~3 AM
Revised 07/12/0] ]057.37 AM
30907C3
JEANNE M. WEBER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
NO, 01-3501
MATTHEW JOHN THOMAS,
Defendant
JURY TRIAL OF TWELVE DEMANDED
PRAECIPE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Enter the appearance of MARTSON DEARDORFF WILLIAMS & OTTO on behalf of
Defendant, Matthew John Thomas, in the above matter. Defendant hereby demands a twelve juror
jury trial in the above captioned action.
MARTSON DEARDORFF WILLIAMS & OTTO
fi89if!
By
George B. Faller, Jr., Esqu'
I.D, No. 49813
Ten East High Street
Carlisle, P A 17013
(717) 243-3341
Attorneys for Defendant
Matthew John Thomas
Dated: July 12,2001
CERTIFICATE OF SERVICE
I, Melinda A. Hall, an authorized agent for Martson Deardorff Williams & Otto, hereby
certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post
Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows:
Leah B. Graff, Esquire
LAW OFFICES OF DALE E, ANSTINE, p,c.
Two West Market Street
P.O, Box 952
York, PA 17405
MARTSON DEARDORFF WILLIAMS & OTTO
By f~rv( dl~llPl 0. Q _ dHC
Melinda \A. Hall
Ten East High Street
Carlisle, P A 17013
(717) 243-3341
Dated: July 12,2001
~
?-i
~-
---.
N
\-')J
'-
'"'-J
.~
,}
. ....~'
SHERIFF'S RETURN - REGULAR
CASE NO: 2001-03501 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WEBER JEANNE M
VS
THOMAS MATTHEW JOHN
SHAWN HARRISON
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
THOMAS MATTHEW JOHN
the
DEFENDANT
, at 1815:00 HOURS, on the 28th day of June
2001
at 13 WESTWIND DR
LEMOYNE, PA 17043
by handing to
JOYCE THOMAS, MOTHER
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
9.92
.00
10.00
.00
37.92
r~-~?~
R. Thomas Kline
06/29/2001
DALE E ANSTINE
"""
Sworn and Subscribed to before By:
me this lYE::-'
day of
q~ c2tJ-ol A.D.
I Cl6'~[) ~ ~
Pr thonotary
JEANNE M. WEBER
v.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND CO., PENNA.
CIVIL ACTION - LAW
NO. 01-3501
JURY TRIAL DEMANDED
MATTHEW JOHN THOMAS
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that Plaintiffs Interrogatories, Set #1 and Set #2, along with
Plaintiffs Request for Production of Documents were sent to counsel for Defendant by First Class
United States Mail on the below date to the following address:
George B. Faller, Jr., Esquire
Martson, Deardorff, Williams & Otto
Ten East High Street
Carlisle, P A 17013
Date:
ID 3-01
~~u
Leah . Graff, EsqUIre f
Attorney J.D. No. 29176
Attorney for Plaintiff
~ALE E. ANSTINE. P. C.
YORK, J'E!<I"NSYLV"N1A 1740~
-
P,;O a"0;-0606
c
()
(\
l'
\h
N
. ,
~
S1
~. c.'
:">
:s
~
r
.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
WEBER
Vs.
THOMAS
NO. 013501
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena(s) for documents and things
pursuant to Rule 4009.22 GEORGE FALLER, ESQUIRE certifies that:
1. A Notice of Intent to Serve the Subpoena(s) with a copy of
the subpoena(s) attached thereto was mailed or delivered to
each party at least twenty days prior to the date on which
the subpoena(s) is sought to be served,
2. A copy of the Notice of Intent, including the proposed
subpoena(s) is attached to this certificate,
3. No objection to the subpoena(s) has been received, and
4. The subpoena(s) which will be served is identical to
the subpoena(s) which is attached to the Notice of Intent
to Serve the Subpoena(s).
Date: 12/06/01
GEORGE FALLER, ESQUIRE
MARTSON DEARDORFF WILLIAMS
TEN EAST HIGH STREET
CARLISLE, PA 17013
717-243-3341
ATTORNEY FOR DEFENDANT
INQUIRIES SHOULD BE ADDRESSED TO:
MEDICAL LEGAL REPRODUCTIONS, INC.
4940 DISSTON STREET
PHILADELPHIA PA 19135
(215)
File #: M281051
By: Christine Janiszewski
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
WEBER
Vs.
THOMAS
No. 013501
TO: LEAH GRAFF
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE
DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
DEFENDANT intends to serve a subpoena(s) identical to
the one(s) attached to this notice. You have twenty (20) days
from the date listed below in which to file of record and serve upon
the undersigned an objection to the subpoena. If no objection is
made the subpoena may be served.
Date: 11/13/01
GEORGE FALLER, ESQUIRE
MARTSON DEARDORFF WILLIAMS
TEN EAST HIGH STREET
CARLISLE, PA 17013
ATTORNEY FOR DEFENDANT
INQUIRIES SHOULD BE ADDRESSED TO:
MEDICAL LEGAL REPRODUCTIONS, INC.
4940 DISSTON STREET
PHILADELPHIA, PA 19135
(215) 335-3336
By: Christine Janiszewski
Enc(s): Copy of subppena!~)',
Counsel return card
File #: M2810S1
COfoM)NWFALTH OF pmNSYLVANIA
<XXJNI'Y OF QJMBERIAND
WEBER
Vs.
Fi le No.
013501
THOMAS
SUBPOENA TO PR<XlUCE DCCU1ENTS OR ni I NGS
FOR 0 I SCOVERY PURSUANT TO RUlE 4009. 22
HOLY SPIRIT HOSP, 503 N 21ST ST, CAMP HILL PA 17011-2288
TO: ATTN: MEDICAL RECORDS DEPT
(Name of Person or Ent i ty)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docunent!'> os~n1ttT ACHED ADDENDUM
at
MEDICAL LEGAL REPRODUCTIONS,( INC, 4940 DISSTON ST., PHILA., PA
Address)
You may deliver or mail legible copies of the documents or produce things requested h,
this subpoena, together with the certificate of carpliance, to the party making thi~
request at the address listed above. You have the right to seek in advance the reasonablE
cost of pre9aring the copies or producing the things sought.
I f you fai 1 to produce the docunents or things required by this subpoena within t....,enty
(20) days after its serv~ce, the party serving thh subpoena may seek a court orde,-
carpel 1 ;09 you to carply with it.
ni I S SUBPOENA WAS I SSUED AT THE RECUEST OF n;E FOlLCW 1 NG PERSON:
~: GEORGE FALLER, ESQ
ADDRESS: MARTSON DEARDORFF WILLIAMS
CARLISLE, P^ 17013
TELF.:PH:)NE:
SUPREl"E roj~H I D #
ATTORNEY FOR:
215-335-3212
49813
DEFENDANT
/1:1 /5101
BY THE ~T:
~otLf~~: ~;~ii .~;visi~
(l, ' <.
'Y'1t1.L- (1- ~
Deputy
M281051-01
DATE:
Seal of the Court
(Eff. 1/97)
ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR : HOLY SPIRIT HOSP
Any and all hospital records, including microfilm, microfiche
emergency room reports, x-ray reports, out-patient records physical
therapy records, and any other information pertaining to:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED.
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
PATIENT BILLING
X-RAYS
RECORDS / XRAYS have been destroyed
Date
Authorized signature for
HOLY SPIRIT HOSP
CUMBERLAND
M281051-01
*** SIGN AND RETURN THIS PAGE ***
C()MM)NWEAL'l'H OF PENNSYLVANIA
axJNl'Y OF C1JMBERIAND
WEBER
Vs.
Fi le No.
013501
THOMAS
SUBPOENA TO PRCOlX::E cx:::GU1ENTS OR TH I NGS
FOR 0 I S(X)VERY PURSUANT TO RULE 4009. 22
ORTHO INST OF PENNA, 875 POPLAR CHURCH RD, CAMP HILL PA 17011
TO:
(Ncrne of Person or Ent ity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docunent~ os~n~TACHED ADDENDUM
at
MEDICAL LEGAL REPRODUCTIONS,( INC, 4940 DISSTON ST., PHILA., PA
Address)
You may deliver or mail legible copies of the documents or produce things requested ~)
this subpoena, together with the certificate of carp1iance, to the party making thi~
request at the address listed above. You have the right to seek in advance the reasonablE
cost of pre9aring the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within tw.enty
(20) days after its servke, the party serving thh subpoena may seek a court orde.-
carpe 11 ;ng you to carp 1y with it.
TH I S SUBPOENA WAS I SSUEO AT THE REQUEST OF THE Fcx..LCW I NG PERSON:
NAf'E: GEORGE FALLER, ESQ
ADDRESS: MARTSON DEARDORFF WILLIAMS
CARLIGLE, PA 17013
TELEPHONE:
SUPR8"E COJRT 10 #
ATTORNEY FOR:
215 -33 5 - 3212
49813
DEFENDANT
j J 1/5/ en
BY THE COJRT:
~~~{'~yrciU: .~;~; i.D;~;~i~
~Q.~
M281051-02
DATE:
Seal of the Court
Deputy
(Eff. 7/97)
ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: ORTHO INST OF PENNA
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough searc~1
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
PATIENT BILLING
X-RAYS
RECORDS / XRAYS have been destroyed
Authorized signature for
ORTHO INST OF PENNA
Date
CUMBERLAND
M281051-02
*** SIGN AND RETURN THIS PAGE ***
COfoM)NWEALTH OF PlllNSYLVANIA
CXXJNl'Y OF a.JMBERIAND
WEBER
VS.
Fi 1e No.
013501
THOMAS
SUBPOENA TO PROCllX::E DCCU1ENTS OR nt I NGS
FOR D I S(X)VERY PURSUANT TO RULE 4009.22
FAMILY MED CTR, 4076 MARKET ST, CAMP HILL PA 17070
TO:
(Nane of Person or Ent ity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docunent~ OSEJ.tinA~TACHED ADDENDUM
at
MEDICAL LEGAL REPRODUCTIONS'CINC, ~940 DISSTON ST., PHILA., PA
Address)
You may deliver or mail legible copies of the documents or produce things requeste~ ~)
this subpoena, together with the certificate of carpliance, to the party making thi:::
request at the address listed above. You have the right to seek in advance the reasonablE
cost of preqaring the copies or producing the things sought.
I f you fai 1 to produce the docunents or things required by this subpoena within t.,...enty
(20) days after its serv~ce, the party serving thh ~;ubpoena may seek a court orde.-
(xxrpe 11 ing you to ccrrp ly with it.
TI-i I S SU6POENA WAS
NAt'E :
ADDRESS:
I SSUED AT THE REOOEST OF THE FOLLOH I NG PERSON:
GEORGE FALLER, ESQ
MARTSON DEARDORFF WILLIAMS
CARLISLE, p~ 17013
TELEPH:JNE :
SUPREl"'E CCUH I D #
ATTORNEY FOR:
215-335-)212
49813
DEFENDANT
Sea 1 of the Court
BY THE COJRT:
~~~L4:z}dfir;': ~iv;l
C)'-7'~ ~ ~~lb-:
M281051-03
l/ Ii .s-/oi...n..
Division
DATE:
Deputy
(Eff. 7/97)
ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: FAMILY MED CTR
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough sea:Lch
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
PATIENT BILLING
RECORDS / XRAYS have been destroyed
X-RAYS
Date
Authorized signature for
FAMILY MED CTR
CUMBERLAND
M281051-03
*** SIGN AND RETURN THIS PAGE ***
C()fwM)NWEALTH OF PEmSYI.,VANIA
COUNrY OF aJMBERIAND
WEBER
Vs.
Fi le No.
013501
THOMAS
SUBPOENA TO PRODl.JCE c:x:x:u-ENTS OR TH I ~
FOR 0 I SCOVERY PURSUANT TO RULE 4009. 22
LOWER SWATARA EMERG MED, 659 SPRING GARDEN DR, MIDDLETOWN PA 17057
TO: ATTN: PERSONNEL DEPARTMENT
(Ncme of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docunent~ osEtinA~TACHED ADDENDUM
at
MEDICAL LEGAL REPRODUCTIONS,( INC, 4940 DISSTON ST., PHILA., PA
Address)
You may del iver or mai 1 legible copies of the docunents or produce things. requested t'::
th i s subpoena, together wi th the cert i f icate of carp 1 i ance, to the party mak i ng th i ~
request at the address listed above. You have the right to seek in advance the reasonable
cost of preqaring the copies or producing the things sought.
If you fail to produce the docunents or things required by this subpoena within tw.enty
(20) days after its serv~ce, the party serving thh ~jubpoena may seek a court orde;'
oompelling you to comply with it.
TH I S SUBPOENA WAS
NAf'E:
ADDRESS:
I SSUED AT THE REQUEST OF THE FOLLCW I NG PERSON:
GEORGE FALLER, ESQ
MARTSON DEARDORFF WILLIAMS
CARLI OLE , rA 17013
215-335-3212
TELEPH:)NE:
SUPREfoE COJRT 10 #
ATTORNEY FOR:
49813
DEFENDANT
J I /1::{/01
BY THE COJRT:
Cu,:;.~~r!i,t!l;;,.i.{.;C~i~il. 0 i~ i ;ion
~C2~
M281051-04
DATE:
Seal of the Court
Deputy
(Eff. 7/97)
ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: LOWER SWATARA EMERG MED
ANY EMPLOYMENT APPLICATIONS, EARNINGS, LEDGER SHEETS, TIME CARDS
REVIEWS, ATTENDANCE SHEETS, ANY AND ALL MEDICAL RECORDS AND REPORTS
AND PRE-EMPLOYMENT PHYSICALS, WORKMEN'S COMPENSATION CLAIMS MADE, ANY
W-2 WITHHOLDING TAX FORMS, AND ANY OTHER INFORMATION PERTAINING TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
PATIENT BILLING
RECORDS / XRAYS have been destroyed
X-RAYS
Date
Authorized signature for
LOWER SWATARA EMERG MED
CUMBERLAND
M281051-04
*** SIGN AND RETURN THIS PAGE ***
C()t.M)NWEM..TH OF PENNSYLVANIA
CCXJNI'Y OF aJMBERIAND
WEBER
VS.
Fi 1e No.
013501
THOMAS
SUBPOENA TO PR~ co::t.t-ENTS OR TH I NGS
FOR DISCOVERY PURSUANT TO RUlE 4009. 22
WEST SHORE ALS SERVICES, 503 N 21ST ST, CAMP HILL PA 17011-2044
TO: ATTN: PERSONNEL DEPARTMENT
(Ncrne of Person or Ent ity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docunents OSEi:in.x.~TACHED ADDENDUM
at
MEDICAL LEGAL REPRODUCTIONS'(I!cFr~s~940 DISSTON ST., PHILA., PA
You may deliver or mail legible copies of the documents or produce things requested h,
th i s subpoena, together with the cert i f i cate of carp li ance, to the party mak i ng th i ~
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 tw.enty
(20) days after its serv~ce, the party serving thi:; ~;ubpoena may seek a court orde;-
a::rrpell;ng you to carply with it.
n; I S SUBPOENA WAS I SSUED AT THE REQUEST OF THE F<X.LON I NG PERSON:
~: GEORGE FALLER, ESQ
~ESS: MARTSON DEARDORFF WILLIAMS
TELEPH:>NE:
SUPRB-E roJRT I D #
ATTORNEY FOR:
CARLISLE, FA 1ry013
215-335-3212
49813
DEFENDANT
. ..
II 1/{'101
BY lHE CCURT:
(1" .-1. P~ot~~6 J;:k. .~i;il~i~i~ ion
QY1 a ~1~
M281051-05
DATE:
Seal of the Court
Deputy
(Eff. 7/97)
ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: WEST SHORE ALS SERVICES
ANY EMPLOYMENT APPLICATIONS, EARNINGS, LEDGER SHEETS, TIME CARDS
REVIEWS, ATTENDANCE SHEETS, ANY AND ALL MEDICAL RECORDS AND REPORTS
AND PRE-EMPLOYMENT PHYSICALS, WORKMEN'S COMPENSATION CLAIMS MADE, ANY
W-2 WITHHOLDING TAX FORMS, AND ANY OTHER INFORMATION PERTAINING TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
PATIENT BILLING
X-RAYS
RECORDS / XRAYS have been destroyed
Date
Authorized signature for
WEST SHORE ALS SERVICES
CUMBERLAND
M281051-05
*** SIGN AND RETURN THIS PAGE ***
~TH OF PENNSYLVANIA
axJNrY OF aJMBERIAND
WEBER
Vs.
Fi 1e No.
013501
THOMAS
SUBPOENA TO PROOLX::E !XX:U1ENTS OR THI NGS
FOR D I SCOYERY PURSUANT TO RULE 4009. 22
LOWER ALLEN TWP, 1993 HUMMELL AVE, CAMP HILL PA 17011
TO: ATTN: PERSONNEL DEPARTMENT
(Na-ne of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docunent~ <sEtinl~TACHED ADDENDU1\t1
at
MEDICAL LEGAL REPRODUCTIONS,(I~C, ~940 DISSTON ST., PHILA., PA
Address)
You may deliver or mail legible copies of the documents or produce things requested t)
this subpoena, together with the certificate of carp1iance, to the party making thi::
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 tw.enty
(20) days after its serv~ce, the party serving thh ~;ubpoena may seek a court orde,-
carpe 11 ing you to carp 1y with it.
TH I S SUBPOENA WAS I SSUED AT THE REOJEST OF TIiE FOLLCW I NG PERSON:
~: GEORGE FALLER, ESQ
ADDRESS: MARTSON DEARDORFF WILLIAMS
CARLISLE, r~ 11013
TELEPHJNE:
SUPREl-E (X)IJH I D #
ATTORNEY FOR:
215 - 3'"3 5 - 3 212
49813
DEFENDANT
"Ii /;"5'/01
BY THE COJRT:
. -- .. ... -~ot!'f1/Ct.;k.
C)1j/R_12 ~
M281051-06
Civil Division
DATE:
Seal of the Court
Deputy
(Eff. 7/97)
ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: LOWER ALLEN TWP
ANY EMPLOYMENT APPLICATIONS, EARNINGS, LEDGER SHEETS, TIME CARDS
REVIEWS, ATTENDANCE SHEETS, ANY AND ALL MEDICAL RECORDS AND REPORTS
AND PRE-EMPLOYMENT PHYSICALS, WORKMEN'S COMPENSATION CLAIMS MADE, ANY
W-2 WITHHOLDING TAX FORMS, AND ANY OTHER INFORMATION PERTAINING TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
PATIENT BILLING
X-RAYS
RECORDS / XRAYS have been destroyed
Date
Authorized signature for
LOWER ALLEN TWP
CUMBERLAND
M281051-06
*** SIGN AND RETURN THIS PAGE ***
.
(X)MM)NWEM.TH OF PENNSYLVANIA
CXXJNl'Y OF CUMBERIAND
WEBER
Vs.
File No.
013501
THOMAS
SUBPOENA TO PROOJCE DCO...t1ENTS OR TH I NGS
FOR DISCOVERY PURSUANT TO RUlE 4009. 22
,
PINNACLE HEALTH HOSP, 111 S FRONT ST, HARRISBURG PA 17101
TO: ATTN: PERSONNEL DEPARTMENT
(Nane of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docunents osEtinl~TACHED ADDENDUM
at
MEDICAL LEGAL REPRODUCTIONS'(1~es:r40 DISSTON ST., PHILA., PA
You may deliver or mail legible copies of the documents or produce things requested h}
this subpoena, together with the certificate of carpliance, to the party making thi~
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 t~enty
(20) days after its serv~ce, the party serving thh ~;ubpoena may seek a court orde,-
carpe 11 ing YOll to carp ly with it.
TH I S SUBPOENA WAS I SSUED AT THE REOJEST OF THE FOLLCW I NG PERSON:
~: GEORGE FALLER, ESQ
~ESS: MARTSON DEARDORFF WILLIAMS
TELEPH:>NE:
SUPRB-E CCUH ID #
ATTORNEY FOR:
CARLISLE, r~ 11013
215-3"35-3212
49813
DEFENDANT
/ / / 15~ /01
BY THE c:a.JRT:
.. (',,"~~~L!';t/oI;'~,
GI,. 0. Yvtul:J-J
M281051-07
Civil Division
DATE:
Seal of the Court
Deputy
(Eff. 7/97)
ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: PINNACLE HEALTH HOSP
ANY EMPLOYMENT APPLICATIONS, EARNINGS, LEDGER SHEETS, TIME CARDS
REVIEWS, ATTENDANCE SHEETS, ANY AND ALL MEDICAL RECORDS AND REPORTS
AND PRE-EMPLOYMENT PHYSICALS, WORKMEN'S COMPENSATION CLAIMS MADE, ANY
W-2 WITHHOLDING TAX FORMS, AND ANY OTHER INFORMATION PERTAINING TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
PATIENT BILLING
RECORDS / XRAYS have been destroyed
X-RAYS
Date
Authorized signature for
PINNACLE HEALTH HOSP
CUMBERLAND
M281051-07
*** SIGN AND RETURN THIS PAGE ***
COfwM:>NWEALTH OF PENNSYLVANIA
COONrY OF aJMBERIAND
WEBER
VS.
Fi 1e No.
013501
THOMAS
SUBPOENA TO PRoou:::E [XX).J1ENTS OR TI11 NGS
FOR 0 I S(X)VERY PURSUANT TO RUlE 4009. 22
CHAMBERSBURG HOSP, 112 N 7TH ST, CHAMBERS BURG PA 17201-6005
TO: ATTN: PERSONNEL DEPARTMENT
(Nane of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docunent~ ~Etin~~TACHED ADDENDmI
at
MEDICAL LEGAL REPRODUCTIONS'CINC, ~940 DISSTON ST., PHILA., PA
Address)
You may deliver or mail legible copies of the documents or produce things requested h)
this subpoena, together with the certificate of carp1iance, to the party making thi~
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 tw.enty
(20) days after its serv~ce, the party serving thh ~jubpoena may seek a court orde.-
compelling you to comply with it.
m I S SUBPOENA WAS , SSUED AT THE RECUEST OF 1}{E FOLLCW I NG PERSON:
NAME: GEORGE FALLER, ESQ
ADDRESS: MARTSON DEARDORFF WILLIAMS
CARLIGLE, FA 11013
TELEPH:)NE:
SUPREr'E OOJRT 10 #
ATTORNEY FOR:
215-335-3212
49813
DEFENDANT
[2 81 0 51 - 08
8Y THE CCURT:
11116-/01
~,. .12 ~ ~.
Prothonot itlerk,
9~ (2 ~
DATE:
Civil Division
Seal of the Court
Deputy
(Eff. 7/97)
ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: CHAMBERS BURG HOSP
ANY EMPLOYMENT APPLICATIONS, EARNINGS, LEDGER SHEETS, TIME CARDS
REVIEWS, ATTENDANCE SHEETS, ANY AND ALL MEDICAL RECORDS AND REPORTS
AND PRE-EMPLOYMENT PHYSICALS, WORKMEN'S COMPENSATION CLAIMS MADE, ANY
W-2 WITHHOLDING TAX FORMS, AND ANY OTHER INFORMATION PERTAINING TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
PATIENT BILLING
RECORDS / XRAYS have been destroyed
X-RAYS
Authorized signature for
CHAMBERS BURG HOSP
Date
CUMBERLAND
M281051-08
*** SIGN AND RETURN THIS PAGE ***
C()l.M)NWEM..TH OF PENNSYLVANIA
axJNI'Y OF CUMBERLAND
WEBER
Vs.
Fi le No.
013501
THOMAS
SUBPOENA TO PRCOl..a: D<X::lJ1ENTS OR TH I NGS
FOR 0 I SCOVERY PURSUANT TO RULE 4009. 22
EAST PENNSBORO AMBULANCE, 750 S HUMER ST, ENOLA PA 17025
TO: ATTN: PERSONNEL DEPARTMENT
(Ncrne of PersOf'l or Ent ity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docunent!'; OSEitn1tTTACHED ADDENDU~I
at
MEDICAL LEGAL REPRODUCTIONS,( INC, 4940 DISSTON ST., PHILA., PA
Address)
You may deliver or mail legible copies of the documents or produce things requested h,
this subpoena, together with the certificate of carpliance, to the party making thi::
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 t~enty
(20) days after its serv~ce, the party serving thh ~;ubpoena may seek a court orde.'
o::rrpe l1;ng you to carp ly with it.
TH I S SUBPOENA WAS I SSUED AT THE REQUEST OF THE FOLLON I NG PERSON:
NAME: GEORGE FALLER, ESQ
ADDRESS: MARTSON DEARDORFF WILLIAMS
CARLICLE, rA 17013
TELF:PH:lNE :
SUPREr-E <::cuRT I 0 #
ATTORNEY FOR:
215-335-3212
49813
DEFENDANT
II / J~/Ol
BY THE CCXJRT:
"Ca.~12 ~ r."
Prothonotaryl er, Civi 1
~_ Q_ ~1d
~281051-09
DivisiOf'l
DATE:
Seal of the Court
Deputy
(Eff. 7/97)
ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: EAST PENNSBORO AMBULANCE
ANY EMPLOYMENT APPLICATIONS, EARNINGS, LEDGER SHEETS, TIME CARDS
REVIEWS, ATTENDANCE SHEETS, ANY AND ALL MEDICAL RECORDS AND REPORTS
AND PRE-EMPLOYMENT PHYSICALS, WORKMEN'S COMPENSATION CLAIMS MADE, ANY
W-2 WITHHOLDING TAX FORMS, AND ANY OTHER INFORMATION PERTAINING TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
PATIENT BILLING
RECORDS / XRAYS have been destroyed
X-RAYS
Date
Authorized signature for
EAST PENNSBORO AMBULANCE
CUMBERLAND
M281051-09
*** SIGN AND RETURN THIS PAGE ***
C()l.M)NWEM.TH OF PENNSYLVANIA
a:xJNl'Y OF a.JMBERL.l\ND
WEBER
Vs.
Fi le No.
013501
THOMAS
SUBPOENA TO PRCOl..a: DCX:U1ENTS OR TH I NGS
FOR 0 I SCOVERY PURSUANT TO RULE 4009. 22
FAYETTEVILLE VOL FIRE, 101 W MAIN ST, FAYETTEVILLE PA 17222
TO: ATTN: PERSONNEL DEPARTMENT
(Ncrne of PersOf'l or Ent ity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docunent!'; os~in2tTTACHED ADDENDlJl\tI
at
MEDICAL LEGAL REPRODUCTIONS'(ARf,gessj940 DISSTON ST., PHILA., PA
You may deliver or mail legible copies of the documents or produce things requested h,
th i s subpoena I together wi th the cert i f icate of carp 1 i ance, to the party mak i ng th i::
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 t~enty
(20) days after its serv~ce, the party serving thh subpoena may seek a court orde;'
o::rrpe 11 ; ng you to carp 1 y with it.
TH I S SUBPOENA WAS I SSUED AT THE REQUEST OF THE FOLLON I NG PERSON:
NAME: GEORGE FALLER, ESQ
ADDRESS: MARTSON DEARDORFF WILLIAMS
CARLISLE, PA 17013
TELF:PH:lNE:
SUPREr-E <::cuRT I 0 #
ATTORNEY FOR:
215-335-3212
49813
DEFENDANT
II / l~io'l
BY THE CCXJRT:
e,;~~~{'~~l'~;v; 1
~t2~
112 81 0 51 - 10
DATE:
DivisiOf'l
Seal of the Court
Deputy
(Eff. 7/97)
ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: FAYETTEVILLE VOL FIRE
ANY EMPLOYMENT APPLICATIONS, EARNINGS, LEDGER SHEETS, TIME CARDS
REVIEWS, ATTENDANCE SHEETS, ANY AND ALL MEDICAL RECORDS AND REPORTS
AND PRE-EMPLOYMENT PHYSICALS, WORKMEN'S COMPENSATION CLAIMS MADE, ANY
W-2 WITHHOLDING TAX FORMS, AND ANY OTHER INFORMATION PERTAINING TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
PATIENT BILLING
RECORDS / XRAYS have been destroyed
X-RAYS
Date
Authorized signature for
FAYETTEVILLE VOL FIRE
CUMBERLAND
M281051-10
*** SIGN AND RETURN THIS PAGE ***
COfvM)NWEALTH OF PENNSYLVANIA
COUNl'Y OF aJMBERLAND
WEBER
Vs.
File No.
013501
THOMAS
SUBPOENA TO PRODUCE IXX:U1ENTS OR TH I NGS
FOR 0 I SCOVERY PURSUANT TO RULE 4009. 22
CARLISLE HOSP ADV LIFE SP, 246 PARKER ST, CARLISLE PA 17013
TO: ATTN: PERSONNEL DEPARTMENT
(Ncrne of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docunent!'; os~inA~TACHED ADDENDUJ\t1
at
MEDICAL LEGAL REPRODUCTIONS'(A~~es:r40 DISSTON ST., PHILA., PA
You may deliver or mail legible copies of the documents or produce things requested h)
this subpoena, together with the certificate of carpliance, to the party making thi::
request at the address listed above. You have the right to seek in advance the reasonablf
cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within t~enty
(20) days after its serv~ce, the party serving thh ~;ubpoena may seek a court orde;'
o::rrpe 11 ing you to carp ly with it.
TH I S SUBPOENA WAS I SSUED AT THE REQUEST OF lHE FOLLON I NG PERSON:
~: GEORGE FALLER, ESQ
ADDRESS: MARTSON DEARDORFF WILLIAMS
TELF:Pf-OIlE :
SUPREr-E <::cuRT I 0 #
ATTORNEY FOR:
CARLISLE, FA 17013
215-335-3212
49813
DEFENDANT
J I /IS'/oi
BY THE CCXJRT:
~ur~~oL~fd1';:k.
281051-11
Civil Division
DATE:
Sea 1 of the Court
Deputy
(Eff. 1/97)
ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: CARLISLE HOSP ADV LIFE SP
ANY EMPLOYMENT APPLICATIONS, EARNINGS, LEDGER SHEETS, TIME CARDS
REVIEWS, ATTENDANCE SHEETS, ANY AND ALL MEDICAL RECORDS AND REPORTS
AND PRE-EMPLOYMENT PHYSICALS, WORKMEN'S COMPENSATION CLAIMS MADE, ANY
W-2 WITHHOLDING TAX FORMS, AND ANY OTHER INFORMATION PERTAINING TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
PATIENT BILLING
RECORDS / XRAYS have been destroyed
X-RAYS
Date
Authorized signature for
CARLISLE HOSP ADV LIFE SP
CUMBERLAND
M281051-11
*** SIGN AND RETURN THIS PAGE ***
"
.
C()l.M)NWEl\LTH OF PENNSYLVANIA
OOUNI'Y OF a.JMBERI..,AND
WEBER
Vs.
File No.
013501
THOMAS
SUBPOENA TO PRCOl..a: rxx::::Lt1ENTS OR TH I NGS
FOR 0 I SCOVERY PURSUANT TO RULE 4009. 22
STATE FARM INS CO, ONE STATE FARM DR, CONCORDVILLE PA 19339
TO: ATTN: JOHN ZAMPELLI JR
(Ncrne of PersOf'l or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following doa..rnent!'; ~E:ftinA~TACHED ADDENDUM
at
MEDICAL LEGAL REPRODUCTIONS'(A~~ess1940 DISSTON ST., PHILA., PA
You may deliver or mail legible copies of the documents or produce things requested h,
this subpoena, together with the certificate of carpliance, to the party making thi::
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 t~enty
(20) days after its serv~ce, the party serving thh ~;ubpoena may seek a court orde;'
carpe lling you to carp ly with it.
TH I S SUBPOENA WAS I SSUED AT THE REQUEST OF THE FOLLON 1 NG PERSON:
NAME: GEORGE FALLER, ESQ
ADDRESS: MARTSON DEARDORFF WILLIAMS
CARLICLE, rA 17013
TELF:PH:lNE :
SUPREr-E <X:.'(JRT I 0 #
ATTORNEY FOR:
215-335-3212
49813
DEFENDANT
if /15/01
BY THE CCXJRT:
~~~L~J/C'l;k, civi 1 DivisiOf'l
~~ ()~
'1281051-12
DATE:
Seal of the Court
Deputy
(Eff. 1/97)
'(
.
ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: STATE FARM INS CO
PIP FILE; POL #706 1991 FIO 38 A
PERTAINING TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
PATIENT BILLING
RECORDS / XRAYS have been destroyed
X-RAYS
Date
Authorized signature for
STATE FARM INS CO
CUMBERLAND
M281051-12
*** SIGN AND RETURN THIS PAGE ***
~
.
~TH OF PENNSYLVANIA
COONrY OF QJMBERI.AND
WEBER
VS.
Fi le No.
013501
THOMAS
SUBPOENA TO PR()()l..CE DCCU1ENTS OR TH I NGS
FOR 0 I SCOVERY PURSUANT TO RULE 4009.22
HARLEYSVILLE INS CO, PO BOX 1016, MOORESTOWN NJ 08057
TO:
(Ncrne of PersOf'l or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docunent!'; ~EtinX~TACHED ADDENDUM
at
MEDICAL LEGAL REPRODUCTIONS'(1!~es:r40 DISSTON ST., PHILA., PA
You may deliver or mail legible copies of the documents or produce things requested h)
this subpoena, together with the certificate of carpliance, to the party making thi::
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.
I f you fai 1 to produce the docunents or things required by this subpoena within t~enty
(20) days after its serv~ce, the party serving thh ~;ubpoena may seek a court orde.'
o::rrpe 11 ing you to carp ly with it.
TH I S SUBPOENA WAS
N#'E :
ADDRESS:
I SSUED AT THE REQUEST Of THE FOLLOH I 00 PERSON:
GEORGE FALLER, ESQ
MARTSON DEARDORFF WILLIAMS
CARLICLE, rA 1~013
215-3~5-3212
49'813
TELF:PtmE:
~R8-E ~T 10 #
ATTORNEY FOR:
DEFENDANT
1(lt j}Ol
BY THE COURT:
12.. f,.~tLft;~k:Ci~i'l
C)jrU--- 0 7M... ~ ~;-- J
Division
M281051-13
DATE:
Seal of the Court
Deputy
(Eff. 7/97)
.. I
,
.
ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: HARLEYSVILLE INS CO
ANY AND ALL WORKERS COMPENSATION RECORDS.
INSURED: LOWER ALLEN TOWNSHIP
PERTAINING TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
PATIENT BILLING
RECORDS / XRAYS have been destroyed
X-RAYS
Authorized signature for
HARLEYSVILLE INS CO
Date
CUMBERLAND
M281051-13
*** SIGN AND RETURN THIS PAGE ***
o
~
r\
-.l
f\!
N
():)
~
~
...,
~-1
'<)
( ..,.-)
F:\FlLES\DA T AFILE\Travdoc.arc\ Travdoc.OI \ 723-ans I/drg
Created: 08/2010 1 01:53 39 PM
Revise~. 01/02/0211'1318 AM
3090.723
JEANNE M. WEBER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LA W
NO. 01-3501
MATTHEW JOHN THOMAS,
Defendant
JURY TRIAL OF TWELVE DEMANDED
ANSWER
TO: JEANNE M. WEBER, PLAINTIFF, and her attorney LEAH B. GRAFF, ESQUIRE
1. After reasonable investigation, the answering Defendant is without knowledge or
information sufficient to form a belief as to the truth or falsity of the averment contained in this
paragraph.
2. Admitted.
3. After reasonable investigation, the answering Defendant is without knowledge or
information sufficient to form a belief as to the truth or falsity of the averment contained in this
paragraph regarding the ownership of the ambulance. All other averments contained in this
paragraph are admitted.
4. Admitted.
5. After reasonable investigation, the answering Defendant is without knowledge or
information sufficient to form a belief as to the truth or falsity of the averments contained in this
paragraph.
6. After reasonable investigation, the answering Defendant is without knowledge or
information sufficient to form a belief as to the truth or falsity of the averment contained in this
paragraph regarding the intention ofthe ambulance operator. All other averments contained in this
paragraph are admitted.
7. After reasonable investigation, the answering Defendant is without knowledge or
information sufficient to form a belief as to the truth or falsity of the averment contained in this
paragraph. As a result, Defendant denies all averments contained in this paragraph.
8.-15. Denied.
I
WHEREFORE, Defendant demands judgment in his favor and dismissal of Plaintiffs'
Complaint with prejudice.
MARTS ON EARDORFF WILLIAMS & OTTO
By
George B. Faller, JI.
Attorney I.D. 49813
Ten East High Street
Carlisle, P A 17013-3093
(717) 243-3341
Attorneys for Defendant
Date: January 2,2001
2
VERIFICATION
The foregoing Answer is based upon information which has been gathered by my counsel in
the preparation of the lawsuit. The language of the document is that of counsel and not my own. I
have read the document and to the extent that it is based upon information which I have given to my
counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that
the content ofthe document is that of counsel, I have relied upon counsel in making this verification.
This statement and verification are made subject to the penalties of 18 Pa. C. s. 9 4904 relating
to unsworn falsification to authorities, which provides that ifI knowingly make false averments, I may
be subject to criminal penalties.
~.
/
Matthew "~~T~omas
CERTIFICATE OF SERVICE
I, David R. Galloway, an authorized agent for MARTSON DEARDORFF WILLIAMS &
OTTO, hereby certify that a copy of the foregoing Answer was served this date by depositing same
in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows:
Leah B. Graff, Esquire
LAW OFFICES OF DALE E. ANSTINE, P.C.
Two West Market Street
P.O. Box 952
York, PA 17405
Dated: January 2,2002
"""1:"]
n~.
d';
f'__
c.,'.'
-,'
~:~:
~;~'. .-
L:'~'~
~.. (':
C:j
~
-<
c---) ;
,--
.....
(....) -<
JEANNE M. WEBER
v.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND CO., PENNA.
CIVIL ACTION - LA W
NO. 01-3501
JURY TRIAL DEMANDED
MATTHEW JOHN THOMAS
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the Notice of Deposition was sent by
First Class United States Mail to counsel for Defendant on the below date at the following address:
George B. Faller, Jr., Esquire
Martson, Deardorff, Williams & Otto
Ten East High Street
Carlisle, PA 17013
Date: t...1- ,~<1 -Q'd-
L~~s4~~
Attorney J.D. No. 29176
Attorney for Plaintiff
)ALE E. AYHTIYE. P. C.
YORK, !'ENNSYLVANIA 17405
/'
:"J
( ",
-~
JEANNE M. WEBER
V.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND CO., PENNA.
CIVIL ACTION - LAW
NO. 01-3501
JURY TRIAL DEMANDED
MATTHEW JOHN THOMAS
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the Amended Notice of Deposition
was sent by First Class United States Mail to counsel for Defendant on the below date at the
following address:
George B. Faller, Jr., Esquire
Martson, Deardorff, Williams & Otto
Ten East High Street
Carlisle, P A 17013
Date: /.; ---I :1-{) d-
~~ .4/{/
Leah B. Graff, Esquire
Attorney LD. No. 29176
Attorney for Plaintiff
.ALE E. ANSTINE. P. C.
TWO WEST .....RKET STREET
I'05T O~F'CE BO>< 952
YOElX, PENNSYLVANIA 1740~
q
c
-oft
g~~~^:
_-:,r r
/.-=-
(j) ,
_?
r;,:.
...;--
-~~'2
~
c:-:
r<
c_
.---
-rJ
,,)
.::.~
..........~.
c-;'""")
:<
'Ji
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
WEBER
Vs.
THOMAS
NO. 013501
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena(s) for documents and things
pursuant to Rule 4009.22 GEORGE B FALLER, ESQUIRE certifies that:
1. A Notice of Intent to Serve the Subpoena(s) with a copy of
the subpoena(s) attached thereto was mailed or delivered to
each party at least twenty days prior to the date on which
the subpoena(s) is sought to be served,
2. A copy of the Notice of Intent, including the proposed
subpoena(s) is attached to this certificate,
3. No objection to the subpoena(s) has been received, and
4. The subpoena(s) which will be served is identical to
the subpoena(s) which is attached to the Notice of Intent
to Serve the Subpoena(s) .
Date: 07/09/02
:/ ...
~. // //
L ..... ~
._.~
GEORGE B FALLER, ESQUIRE
MARTSON DEARDORFF WILLIAMS
TEN EAST HIGH STREET
CARLISLE, PA 17013-3093
717-243-3341
ATTORNEY FOR DEFENDANT
INQUIRIES SHOULD BE ADDRESSED TO:
MEDICAL LEGAL REPRODUCTIONS, INC.
4940 DISSTON STREET
PHILADELPHIA PA 19135
(215)
File #: M288040
By: Christine Janiszewski
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
WEBER
Vs.
THOMAS
No. 013501
TO: LEAH GRAFF
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE
DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
DEFENDANT intends to serve a subpoena(s) identical to
the one(s) attached to this notice. You have twenty (20) days
from the date listed below in which to file of record and serve upon
the undersigned an objection to the subpoena. If no objection is
made the subpoena may be served.
Date: 06/14/02
GEORGE B FALLER, ESQUIRE
MARTSON DEARDORFF WILLIAMS
TEN EAST HIGH STREET
CARLISLE, PA 17013-3093
ATTORNEY FOR DEFENDANT
INQUIRIES SHOULD BE ADDRESSED TO:
MEDICAL LEGAL REPRODUCTIONS, INC.
4940 DISSTON STREET
PHILADELPHIA, PA 19135
(215) 335-3336
By: Christine Janiszewski
Enc(s): Copy of subpoena(s)
Counsel return card
File #: M288040
COM-UNWEALTH OF PmNSYLVANIA
axJNI'Y OF aJMBERIAND
WEBER
Vs.
Fi le No.
013501
THOMAS
SUBPOENA TO PR~ r:xx::t..M:NTS OR TH I NGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
SHAFFER ORECCHIA ASSOCS, 650 N 12TH ST, LEMOYNE PA 17043
TO:
(Name of Person or Ent ity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docunenti:; c:sEEinAT'FACIIED ADDENDU1\i
at
MEu~CAL L~GAL ~~~~UUUC~~U~~, ~NC, 4940 DISSTON ST., PHILA., PA
(Address)
You may del iver or mai 1 legible copies of the docunents or produce things requested t-:)
this subpoena, together with the certificate of carpliance, to the party making thi::
request at the address listed above. You have the right to seek in advance the reasonabl(
cost of preparing the copies or producing the things sought.
I f you fai 1 to produce the docunents or things required by this subpoena within twenty
(20) days after its servke, the party serving thi:; ~;ubpoena may seek a court crde.-
carpe 11 i ng you to carp 1 y wi th it.
TH I S SUBPOENA WAS
N.A1'E :
ADDRESS:
I SSUED AT THE REQJEST OF THE FOLLON I NG PERSON:
GEORGE B FALLER, ESQ
MARTSON DEARDORFF WILLIAMS
CART,TST.F., PA 17013-3093
TELF:PH:>NE:
SU'R8'E ~T 10 #
A1TORNEY FOR:
21S 3-3S 3212
49813
DEFENDANT
DATE: ,-)l.L.A.) ~ ;:) L c:lDo Ql..
Sea 1 of the ~rt
M288040-01
c/ ._-------
Prothonotary Clerk ivi 1 Divis ion
<~ ho~ "- ,27?;y; /U"f . r;:.p<Jty -<~
(Eft. 1/97)
ADDENDUM TO SUBPOENA
WEBER
VB.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: SHAFFER ORECCHIA ASSOCS
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWlJ CT MECI-IANICSBURG PA
DATE OF' BIR'fH: 12/13/50
SSAN: 190427580
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
PATIENT BILLING
X-RAYS
RECORDS / XRAYS have been destroyed
Authorized signature for
SHAFFER ORECCHIA ASSOCS
Date
CUMBERLAND
M288040-01
*** SIGN AND RETURN THIS PAGE ***
CDrM>NWEALTH OF PENNSYLVANIA
COONrY OF aJMBffiIAND
WEBER
Vs.
Fi le No.
013501
THOMAS
SUBPOENA TO PRCCO::E cx:x:::t..tENTS OR THI NGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
COWLEY ASSOCS, 425 N 21ST ST, PLZ 21 STE 2-1
CAMP HILL PA 17011
TO:
(N<nle of PersOf'l or Entity)
within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docunenti:; ~in.A..!ifTACIIED ADDENDUl\1
at
M~U~CAL L~GAL KBPRODUCTIONS, IN~, 494u U~SSTON ST., PH~LA., PA
(Address)
You may del iver or mai 1 legible copies of the docunents or produce things requested ~;)
this subpoena, together with the certificate of CO'T'Pl iance, to the party making th T::
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.
I f you fai 1 to produce the docunents or things required by this subpoena within twenty
(20) days after its servke, the party serving thi!; subpoena may seek a court o.-de,-
carpe 11 i ng you to carp 1 y w; th ; t .
TH I S SUBPOENA WAS
NAME :
ADDRESS:
I SSUEO AT THE RE~ST Of ll-E FOLLON I NG PERSON:
GEORGE B FALLER, ESQ
MARTSON DEARDORFF WILLIAMS
TELF:PH:lNE:
SUPREr-E caJRT 10 #
ATTORNEY FOR:
c;ART. T SLR..- PA 17013 - 3 093
21:::; 3-3-:::; 3212
49813
DEFENDANT
M288040-02
BY
DATE' -.J 4A ) e .;2 tJ ..;) ()6 ~~
Seal of the rt
Prothonotary/Clerk, Civ. lvisioo
~(Yr-f2~e7fQ7.17A''JL, )'
DepUty
(Eff. 7/97)
ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: COWLEY ASSOCS
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWl, CT MECHANICSBURG PA
DA'1'E OF BIRTH: 12/13/50
SSAN: 190427580
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
PATIENT BILLING
RECORDS / XRAYS have been destroyed
X-RAYS
Date
Authorized signature for
COWLEY ASSOCS
CUMBERLAND
M288040-02
* * * SIGN AND RETURN THIS PAGE * * *
a:)foM)N'WEl\IIrn OF P:rnNSYLVANIA
CXXJNI'Y OF a.JMBEm.AND
WEBER
Vs.
Fi le No.
013501
THOMAS
$UBPOENA TO PR<X:ll..CE lXX::lJ-ENTS OR TH' NGS
FOR DISCOVERY PURSUANT TO RUlE 4009.22
GETTYSBURG HOSP, 147 GETTYS ST BOX 3786, GETTYSBURG PA 17325-0786
ATTN: MEDICAL RECORDS DEPT
(Ncrne of Person or Entity)
TO:
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docunent;:; ~i~"TAClIED ADDENDUM
at
MEDICAL L.t!;l:ZAL K.t!;1"KODUCTIONS, INC, 4940 JJ.l:S:S'!'U.N :ST., 1"H.lLA., 1"a--------
(Address)
You may del iver or mai 1 legible copies of the docunents or produce things request.ed t-:)
th i s subpoena, together wi th the cert i f icate of carp 1 i ance, to the party mak i ng th i ::
request at the address 1 isted above. You have the right to seek in advance the reasor-lab IE
cost of preparing the copies or producing the things sought.
I f you fai 1 to produce the docunents or things required by this subpoena within b.Jenty
(20) days after its serv~ce, the party serving thi!1 ~;ubpoena may seek a court o.-de,-
cx:rrpe 11 ing you to carp 1y with it.
TH I S SUBPOENA WAS I SSUED AT THE REQUEST OF THE FOLLON I NG PERSON:
GEORGE B FALLER, ESQ
N.AJ-E :
ADDRESS:
MARTSON DEARDORFF WILLIAMS
C'ART,TST,'R. PA 17013 -3 093
TELF:PH:)NE :
SUPR8'E CCUH 10#
ATTORNEY FOR:
215 33~ 3212
49813
DEFENDANT
DATE: I.. ) LlA.:)p _ ;;;.. f- ~Ct> -~
Sea 1 of the Cou,.Jt -
M288040-03
BY
(Eff. 1/97)
ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: GETTYSBURG HOSP
Any and all hospital records, including microfilm, microfiche
emergency room reports, x-ray reports, out-patient records physical
therapy records, and any other information pertaining to:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHP~ICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED.
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things abc)ve mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
PATIENT BILLING
X-RAYS
RECORDS / XRAYS have been destroyed
Date
Authorized signature for
GETTYSBURG HOSP
CUMBERLAND
M288040-03
*** SIGN AND RETURN THIS PAGE ***
C(Mo{)NWEM,TH OF PENNSYLVANIA
a:xJNrY OF CUMBERLAND
WEBER
Vs.
File No.
013501
THOMAS
MEDICAL BILLING REQUESTED
SUBPOENA TO PRco...a: D<X::lJ1ENTS OR TH I NGS
FOR 0 I SCOVERY PURSUANT TO RUlE 4009. 22
CAPITAL BLUE CROSS, 2500 ELMERTON AVE, HARRISBURG PA 17177
ATTN: LEGAL DEPT
TO:
(Ncrne of PersOf'l or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docunent!'; CS:eEinRTTACIIED ADDENDU~I
at
~.t;lnCAL Lt;GAL .Kt;.I:'.KODOC'l'rONS, J..NC, 4~4u lJJ.SSTU.N S'l'., PHILA., pa-------
(Address)
You may del iver or mai 1 legible copies of the documents or produce things requested t,)
this subpoena, together with the certificate of COl"Pliance, to the party making thi::
request at the address listed above. You have the right to seek in advance the reasonabl~
cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within t~enty
(20) days after its serv~ce, the party serving thh ~;ubpoena may seek a court onie;-
o::rrpe 11 ing you to carp ly with it.
TH I S SUBPOENA WAS
NAl'E :
ADDRESS:
I SSUEO AT THE REQJEST OF THE FOLLON' NG PERSON:
GEORGE B FALLER, ESQ
MARTSON DEARDORFF WILLIAMS
r.ART,ISLE PA 17013-3093
TELF.PHJNE:
SUPR8'E COJRT 10 #
ATTORNEY FOR:
2Ei 33::; 3212
49813
DEFENDANT
M288040-04
BY
DATE: ...... )/~ P ::LC- ( dC)(j~_
Seal of the Court
~
(Eff. '1/97)
. .
ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR : CAPITAL BLUE CROSS
ANY AND ALL MEDICAL BILLS, LIENS AND WORKERS COMPENSATION
INFORMATION. POL #1904275; CONTRACT #020967020
PERTAINING TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
MEDICAL BILLING REQUESTED
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - .- -
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
PATIENT BILLING
X-RAYS
RECORDS / XRAYS have been destroyed
Date
Authorized signature for
CAPITAL BLUE CROSS
CUMBERLAND
M288040-04
* * * SIGN AND RETURN THIS PAGE * * *
o
('oJ
~
~
N
'-'1
c:
"
f_..~ I...
/'.- 1..--
~
. .
IV
CO
;"I
~
.
....~'.:.:..
--1
-<.
I;)
...<,
JEANNE M. WEBER
v.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND CO., PENNA.
CIVIL ACTION - LAW
NO. 01-3501
JURY TRIAL DEMANDED
MATTHEW JOHN THOMAS
PRAECIPE TO REMOVE
To The Prothonotary:
(X) Please mark the above captioned action settled and satisfied.
PLEASE ISSUE A CERTIFICATE OF DISCONTINUANCE.
LAW OFFICES OF DALE E. ANSTINE, P.e.
Respectfully Submitted:
~6~
Leah B. Graff, Esquire
Attorney ill No. 29176
Two West Market Street
P.O. Box 952
York, PA 17405
(71 7) 846 - 0606
Attorney for the Plaintiff
" -;;2/- a.;2
DATE
)ALE E. ANSTINE. P. c.
YORK, PENSSYLVANIA 17405
(') 0 Co"
,,-'"
C f";' ,.on
....,- z:.
~.
-UCn ':? 'D
C)~~. ,.e'-"::
zf~ N ~, 'i"'\
~.,.....,
03'~ u1 t_' '-'"'
20
r:: ,--' -0 ;" 1\
~'-" ,;~~~
~Q :>
'57E ~5.n
-=4
~ ? 1--
(X) ~