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Home My WebLink About05-4575 CHRISTINE A. BLOSE, and JAMES S. BLOSE, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. : NO. 05 -Lj575 KENNETH A. HOSTETTER, Defendant : CNIL ACTION - LAW NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ON AGENCIES TIIAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 (717) 249-3166 Date: 'lfRjIJS k W. Allshouse, E quire ttorney ID # 78014 4833 Spring Road Shermans Dale, P A 17090 (717) 582-4006 Attorney for Plaintiffs CHRISTINE A. BLOSE, and JAMES S. BLOSE, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. (J:;. q ,'5'1:> Cl..;.J : NO. .- 1.u-- KENNETH A. HOSTETTER, Defendant : CNIL ACTION - LAW COMPLAINT AND NOW, comes the Plaintiffs, Christine A. Blose and James S. Blose, her husband, by and through their attorney, Mark W. Allshouse, Esquire, and aver as follows: 1. The Plaintiffs are Christine A. Blose and James S. Blose, husband and wife, adult individuals who reside at 164 Rye Lane, Shermans Dale, Perry County, Pennsylvania 17090. 2. The Defendant, Kenneth A. Hostetter, is an adult individual with the last known address of 441 Meadow Lane, Shermans Dale, Perry County, Pennsylvania 17090. 3. On or about April 28, 2004, Defendant Hostetter, was driving, and in possession and control, of a motor vehicle believed to be owned by him when it was involved in a chain reaction motor vehicle crash involving vehicles owned, occupied and driven by Brandon Shorter and Plaintiff, Christine A. Blose. 4. On or about the aforesaid date, Plaintiff, Christine A. Blose was stopped in traffic on eastbound SR944 when Defendant Hostetter, who was approaching and traveling eastbound on SR944 toward Plaintiff, was driving at a speed greater than reasonable and prudent and was unable to control his vehicle or to bring his vehicle to a stop and collided into the rear of a third party vehicle driven by Brandon Shorter of 8 Country Meadow, Shermans Dale, Perry County, Pennsylvania 17090. 2 5. Hostetter's vehicle impacted Shorter's vehicle with such force, that as a result of the irnpact and despite Shorter's evasive action to avoid Plaintiff's vehicle, Shorter was driven by Defendant Hostetter's vehicle forward and collided in a rear end impact into the vehicle driven by Plaintiff, Christine A. Blose. 6. Defendant Hostetter was charged with violating the Pennsylvania Vehicle Code for his reckless driving which resulted in the accident. 7. Plaintiffs were in no way and to no degree responsible for the collision herein at issue and are therefore in no way comparatively negligent. 8. As a result of the Defendant's negligence and recklessness which caused the chain reaction crash between the three vehicles, Plaintiff, Christine A. Blose sustained various injuries including, but not limited to, injuries to her head, neck, cervical spine, upper extremities, lumbar spine, as well as causing pre-existing, but otherwise asymptomatic conditions, to become problematic. 9. As a result of the aforesaid injuries, the Plaintiff was forced to seek and receive medical intervention including, but not limited to: a. Almost weekly manual spinal manipulation and mechanical traction for over twelve (12) months; b. Multiple diagnostic tests; c. Several weeks of physical therapy to alleviate her pam and regam strength; and d. Numerous visits to health care providers attempting to diagnose and treat Plaintiff's injuries. 3 10. As a further result of the Defendant's recklessness and negligence, the Plaintiff was caused to experience and suffer from: a. Pain in her neck, upper extremities, cervical and lumbar spine; b. Pain and stiffuess in the morning and again as the day progresses; c. Pain when bending and with prolonged sitting; d. Severe neck pain which was at times severe and debilitating; e. Severe dizziness and imbalance; f. Inability to engage in certain of her life's activities; g. Fear and anxiety arising from indications that her symptoms and problems could not be successfully treated; h. Fear and anxiety arising from indications that her problems would be permanent. 11. Plaintiff has been advised and therefore avers that her injuries are serious and symptomotology arising from these injuries and/or re-aggravated by the accident may be permanent and continued treatment throughout Plaintiff's lifetime may be necessary. 12. As a further result of Defendant's recklessness, Plaintiff Blose has sustained a severe shock to her nerves and nervous system which has caused her to undergo great mental anguish and physical pain from which she still suffers and will continue to suffer for an indefinite time in the future. 13. As a further result of Defendant's recklessness and injuries suffered by Plaintiff, Christine A. Blose, Plaintiffs have been compelled to expend various sums of money for medicine and medical attention. They have further been advised and therefore aver they will 4 continue to expend sums of money for medicine and medical attention for an unlimited time into the future. 14. As a result of the crash and injuries sustained by Plaintiff, Christine A. Blose, she was unable to follow her usual occupation and routine, suffering lost wages, and has been deprived of the ability to enjoy the simple pleasures of life and will be unable to do so for an indefinite time into the future. IS. Plaintiffs have satisfied all conditions precedent to filing and proceeding with this lawsuit. WHEREFORE, Plaintiff, Christine A. Blose, demands judgment against the Defendant in an amount in excess of the amount requiring compulsory arbitration. COUNT I CHRISTINE A. AND JAMES S. BLOSE V. KENNETH A. HOSTETTER 16. The averments contained in paragraphs 1 through 15 of this Complaint are hereby incorporated by reference as if set forth at length. 17. The aforesaid accident and injuries sustained by the Plaintiffs was a direct and proximate result of the recklessness and gross negligence of Defendant Hostetter. 18. The recklessness and gross negligence of Defendant Hostetter is both general and in the following particular respects: a. Driving and otherwise operating a vehicle under his control in a reckless, careless and negligent manner; b. Driving and otherwise operating a vehicle under his control at an excessive rate of speed; 5 c. Driving and otherwise operating a vehicle under his control such that it caused a chain reaction which force ultimately struck the vehicle occupied and being operated by Plaintiff, Christine A. Blose; d. Driving and otherwise operating a vehicle under his control in violation of the Pennsylvania Motor Vehicle Code; e. Driving and operating a vehicle under his control without due regard to the right, safety and position of Plaintiff's vehicle; f. Driving and otherwise operating a vehicle under his control without due regard for other traffic on the road; g. Failing to pay attention and to have his vehicle under control at all times; and h. Failed to stop his vehicle such that it caused a chain reaction rear end impact with a third party vehicle which ultimately impacted the vehicle of Plaintiff. 19. As a result of the recklessness herein set forth, and the negligence set forth in Count II hereof, the Plaintiffs sustained injuries as hereinbefore set forth. 20. It is believed and therefore averred that Plaintiff will in the future sustain loss of earnings and earning potential and will also, in the future, require continued medical care and treatment. 21. As a result of the negligence as set forth herein, Plaintiff has incurred substantial costs for co-pays, medical treatment, prescription drugs, fees for medical records, filing fees, lost wages and the like. WHEREFORE, the Plaintiff, Christine A. Blose, demands judgment against the Defendant in an amount in excess of that requiring compulsory arbitration. 6 COUNT II JAMES S. BLOSE. in his own ri2ht v. KENNETH A. HOSTETTER 22. The averments contained in paragraphs 1 through 21 of this Complaint are hereby incorporated by reference hereto as set forth at length herein. 23. At all times hereto, Plaintiff, James S. Blose was the husband and spouse of Plaintiff, Christine A. Blose. 24. As a result of the negligence of the Defendant, Plaintiff, James S. Blose was forced to attend to the injuries sustained by his wife, Christine A. Blose. 25. As a result of the negligence of the Defendant, Plaintiff, James S. Blose was denied the companionship, consortium, love, affection, tenderness of his wife and spouse, Christine A. Blose. WHEREFORE, Plaintiff, James S. Blose, demands judgment against the Defendant in an amount in excess of the amount requiring compulsory arbitration. Date: 9/1R/16 k W. Allshouse, E quire ttorney 1D # 78014 4833 Spring Road Shermans Dale, P A 17090 (717) 582-4006 Attorney for Plaintiffs 7 VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904, relating to unsworn falsification to authorities. (j~IKe .J Blow Christine A. Blose VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. ~u () 0.... ~~ . 0\ #~ CJ\ o i+J -~ (;; ~ 0() - lJ\ -tI :0 r- r- l/) ::r- o ~ (1l "', <::>;::-, 0 c:::.:., c.rl "T1 './J =rJ J- Q -0 m -" i= I '-" C""\ 0 0 'J '.:~ c? - -'.0 " ,"-n - ~) .. ~-,-! (Jl ~c. :Ja en --< F: \FILES\DA T AFlLEIProgressive7837\Current\ I 831pra l/tde Created 9/20104 0:06PM Revised: 9/22/05 240PM Thomas J, Williams, Esquire MARTS ON DEARDORFF WILLIAMS & OTTO I.D. 17512 Hillary A. Dean, Esquire I.D, 92878 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Defendant CHRISTINE A. BLOSE and JAMES S. BLOSE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. NO. 05-4575 CIVIL ACTION - LAW KENNETH A. HOSTETTER, Defendant JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTS ON DEARDORFF WILLIAMS & OTTO on behalf of Defendant Kenneth A. Hostetter in the above matter. MARTSON DEARDORFF WILLIAMS & OTTO By 'l~ f wJ1~ Thomas J. Williams, Esquire Hillary A. Dean, Esquire Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Defendant Dated: Septernber 22, 2005 CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, 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: Mark W. Allshouse, Esquire 4833 Spring Road Shermans Dale, P A 17090 MARTSON DEARDORFF WILLIAMS & OTTO ~~VJtl/(tMa/- G~ D, Eckenroad Ten East High Street Carlisle, P A 17013 (717) 243-3341 Dated: September 22, 2005 ,....> ~ <P if' ,...... "-' tj, ~ ..... ':J;.. " (:,\ -;:?""' ..-':-',"\r ,\'I,:,,\"", ....()\o ~c) t }J(") ">).'t,' _, ...-.;'1 :.'-.;-;:) (,<,Cf\ '/--' \ (~, -;":v:: .;;1 -? ...... ;') SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2005-04575 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BLOSE CHRISTINE A ET AL VS HOSTETTER KENNETH A R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: HOSTETTER KENNETH A but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of PERRY County, Pennsylvania, to serve the within COMPLAINT & NOTICE On September 14th , 2005 , this office was in receipt of the attached return from PERRY Sheriff's Costs: Docketing Out of County Surcharge Dep Perry County Postage 18.00 9.00 10.00 31.10 .74 68.84 09/14/2005 CHRISTIAN LAWYER So answers: -'7 ,:_'> ",,~;:'f~ -;~k:~~ R. Thomas Kline Sheriff of Cumberland County SOLUTIONS Sworn and subscribed to before me this ) G day of r::;--Ctlr~h. e,y 26U~ !JD.:-~_ 1 (~ry In The Court of Common Pleas of Cumberland County, Pennsylvania Christine A. Blose et al VS. Kenneth A. Hostetter No. 05-4575 civil Now, September 8, 2005 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Perry County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. .~~~~ Sheriff of Cum her land County, PA Affidavit of Service Now, September 12 2005 at 1: 35 o'c!ockP '-' M. served the within Notice & Complaint upon Kenneth A. Hostetter at 441 Meadow Lane (Carroll Township) Shermansdale, PA17090 by handing to Kenneth A. Hostetter, Defendant a True & Attested copy of the original Notice & Complaint and made lmown to Him the contents thereof. So answers, ~a~;mo< Deputy Sheri of Perr County, PA NOTARIAL sm 1IA1lGA1lEl F. FUCKINGER, NOTARY PUBUC BLOOMFIELO BORO,. PERRY COUNTY MY COMMISSION EXPIRES FES, 16 2008 COSTS SERVICE MILEAGE AFFIDAVIT $ Sworn and subscribed before me this /J-J.-hday of ~k-2oos- td-'1 $ F:IFlLESIDA T AF1LEIProgressive78371Curreml1831pralltde Created 9/20/04 0:06PM Revised: 10/11105 818AM Thomas J. WiJliams, Esquire MARTSON DEARDORFF WILLIAMS & OTTO I.D.17512 HiJlary A. Dean, Esquire I.D, 92878 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant CHRISTINE A. BLOSE and JAMES S, BLOSE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. NO. 05-4575 CNIL ACTION - LAW KENNETH A. HOSTETTER, Defendant JURY TRIAL DEMANDED DEFENDANT'S ANSWER TO PLAINTIFFS' COMPLAINT TO: CHRISTINE A, BLOSE and JAMES S, BLOUSE, Plaintiffs, and their attorney, MARK W, ALLSHOUSE, ESQUIRE YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED NEW MATTER WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST YOu. AND NOW, comes the Defendant, Kenneth A. Hostetter, by and through his attorneys, MARTS ON DEARDORFF WILLIAMS & OTTO, and hereby avers as foJlows: 1-25. Denied. The averments of Paragraphs 1-25 are denied generaJly in accordance with Pa.R.C,P. 1029(e). It is specifically denied that Defendant was recklessly operating his rnotor vehicle, whether speeding or in any other manner, and it is also specificaJly denied that any of Plaintiffs alleged injuries were caused by the collision in question. WHEREFORE, Defendant, Kenneth A. Hostetter, respectfuJly requests that this Court dismiss Plaintiffs' Complaint with prejudice and enter judgment in his favor and against Plaintiffs, NEW MATTER 26. The foregoing responses to the Cornplaint are incorporated herein by reference and realieged as a defense. 27, Plaintiffs claims are barred by the applicable Statute of Limitations. 28. Plaintiffs recovery is barred orreduced by the Pennsylvania Motor Vehicle financial Responsibility Law as amended. 29. Plaintiff or her representatives chose the limited tort option by signing a valid selection form. 30. Plaintiffs injuries do not involve death, serious irnpairment of bodily function or permanent disfigurement. WHEREfORE, Defendant demands judgment in his favor and dismissal of Plaintiffs' Complaint with prejudice. MARTS ON DEARDORFF WILLIAMS & OTTO Bylk-k .; 'l;vd~ Thomas J. Wilhams, Esquire Hillary A. Dean, Esquire Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Defendant Dated: October 10, 2005 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 rny 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 of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are rnade subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. 1(" ,u'tl {. Kenneth A. Hostetter / J-k It iLl ~ CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Answer to Plaintiffs' Complaint was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Mark W, Allshouse, Esquire 4833 Spring Road Shermans Dale, P A 17090 MARTSON DEARDORFF WILLIAMS & OTTO ~ldWfzul Ten East High Street Carlisle, P A 17013 (717) 243-3341 Dated: October 10, 2005 o C. T":- :;-, ..... c=> c::::::) CJ' o C) -j <:;{ ::;::! fii:TI r"~ ~~ ~ .-..:1 -< N """ I.!? -' CHRISTINE A. BLOSE, and JAMES S. BLOSE, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. : NO. 05-4575 KENNETH A. HOSTETTER, Defendant CIVIL ACTION - LAW PLAINTIFFS' REPLY TO DEFENDANT'S NEW MATTER AND NOW, come Plaintiffs, Christine A. Blose and James S. Blose, by and through their attorney, Mark W. Allshouse, Esquire and respectfully file the following Reply to Defendant's New Matter. 26, Denied. Paragraph 26 is a paragraph of incorporation to which no response is necessary. 27. Denied. The averment contained in paragraph 27 of Defendant's New Matter is a conclusion of law to which no response is necessary, Strict proof thereof is demanded, if relevant, at the time oftrial. 28. Denied. The averment contained in paragraph 28 of Defendant's New Matter is a conclusion of law to which no response is necessary. Strict proof thereof is demanded, if relevant, at the time of trial. 29. Denied. To the contrary, Plaintiff choose the full tort option on her auto insurance as is reflected on her auto insurance policy provided through discovery. 30. Denied, The averment contained in paragraph 30 of Defendant's New Matter is a conclusion of law to which no response is necessary, Strict proof thereof is demanded, if relevant, at the tirne oftrial. WHEREFORE, Plaintiffs respectfully request this Honorable Court to enter judgment in favor ofP1aintiffs and against Defendant. Respectfully submitted, -- Date: 10-18-05 cJ. M k W. Allshouse, A orney ID #78014 4833 Spring Road Shermans Dale, P A 17090 (717) 582-4006 Attorney for Plaintiffs CHRISTINE A. BLOSE, and JAMES S. BLOSE, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. : NO. 05-4575 KENNEIH A. HOSTETTER, Defendant : CIVIL ACTION - LAW VERIFICATION We, Christine A. Blose and James S. Blose, verify that the statements in the foregoing document are true and correct to the best of our knowledge, information and belief under penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: 10 -/8-05 (j~f(d 17Io~~ Christine A. Blose ' '/7 /7 .. //. ); ji/ Date: ID-/g-oS CHRISTINE A. BLOSE, and JAMES S. BLOSE, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. : NO. 05-4575 KENNETH A. HOSTETTER, Defendant : CIVIL ACTION - LAW CERTIFICATE OF SERVICE I, Mark W. Allshouse, Esquire, hereby certify that a copy of the foregoing has been duly served upon the following, by depositing a copy of the same in the United States Mail, first- class, postage prepaid, as follows: Thomas J. Williams, Esquire Hillary A. Dean, Esquire MARTSON, DEARDORFF, WILLIAMS & OTTO Ten East High Street Carlisle, PA 17013 Date: 10-/8-05 M k W. Allshouse, Esqu' e A orney ID #78014 4833 Spring Road Sherrnans Dale, P A 17090 (717) 582-4006 Attorney for Plaintiffs '" ;:-) '-'...) _,.1 ('J -n c-.... (: \...C) r.'" L'1 CHRISTINE A. BLOSE, and JAMES S. BLOSE, : IN THE COURT OF COMMON PLEAS :' CUMBERLAND COUNTY, PENNSYL VANIA Plaintiffs v. : NO. 05-4575 KENNETH A. HOSTETTER, and BRANDON R. SHORTER, Defendants : CIVIL ACTION - LAW NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You rnay 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 THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Date: /:1 -5-05 M k W. Allshouse ttorney ID # 78014 4833 Spring Road Shermans Dale, P A 17090 (717) 582-4006 Attorney for Plaintiffs CHRISTINE A. BLOSE, and JAMES S. BLOSE, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. : NO. 05-4575 KENNETH A. HOSTETTER, and BRANDON R. SHORTER, Defendants CIVIL ACTION - LAW AMENDED COMPLAINT AND NOW, comes the Plaintiffs, Christine A. Blose and James S. Blose, her husband, by and through their attorney, Mark W. Allshouse, Esquire, and aver as follows: I. The Plaintiffs are Christine A. Blose and James S. Blose, husband and wife, adult individuals who reside at 164 Rye Lane, Sherrnans Dale, Perry County, Pennsylvania 17090. 2. The Defendant, Kenneth A. Hostetter, is an adult individual with the last known address of 441 Meadow Lane, Sherrnans Dale, Perry County, Pennsylvania 17090 (hereinafter "Hostetter"), 3. The Defendant, Brandon R. Shorter, is an adult individual with the last known address of 8 Country Meadows, P.O. Box 393, Sherrnans Dale, Perry County, Pennsylvania 17090 (hereinafter "Shorter"). 4. On or about April 28, 2004, Defendant Hostetter, was driving, and in possession and control, of a motor vehicle believed to be owned, operated and controlled by hirn when it was involved in a rear-end motor vehicle crash when he lost control of his vehicle and/or failed to properly control his vehicle and caused a rear-end impact with the vehicle of Shorter which then was pushed into a rear-end impact with the vehicle of Plaintiff. 2 5, ln the alternative, on or about April 28, 2005, Defendant Shorter, was driving, and in possession and control, of a motor vehicle believed to be owned, operated and controlled by him when it was involved in a rear-end rnotor vehicle crash when he lost eontrol of his vehicle and/or failed to properly control his vehicle and caused a rear-end impact with the vehicle of Plaintiff. 6. On or about the aforesaid date, Plaintiff, Christine A. Blose was stopped in traffic on eastbound SR944 when D"fendant Hostetter, who was approaching and traveling eastbound on SR944 toward Plaintiff, was driving at a speed greater than reasonable and prudent and was unable to control his vehicle or to bring his vehicle to a stop and collided into the rear of a third party vehicle driven by Defendant, Brandon R. Shorter. 7. Hostetter's vehicle irnpacted Shorter's vehicle with such force, that as a result of the impact and despite Shorter's evasive action to avoid Plaintiffs vehicle, Shorter was driven by Defendant Hostetter's vehicle forward and collided in a rear end impact into the vehicle driven by Plaintiff, Christine A. Blose. 8. In the alternative, on or about the aforesaid date, Plaintiff, Christine A. Blose was stopped in traffic on eastbound State Route 944 when Defendant Shorter, who was approaching and traveling eastbound on State Route 944 towards Plaintiff was driving at a speed greater than reasonable and prudent and was unable to control his vehicle or bring his vehicle to a stop and collided into the rear of Plaintiffs vehicle. 9. Defendant Hostetter was charged with violating the Pennsylvania Vehicle Code for his reckless driving which resulted in the accident. 10. Plaintiffs were in no way and to no degree responsible for the collision herein at issue and are therefore in no way comparatively negligent. 3 11. As a result of the Defendants' negligence and recklessness which caused the chain reaction crash between the three vehicles, Plaintiff, Christine A. Blose sustained various injuries including, but not limited to, injuries to her head, neck, cervical spine, upper extremities, lumbar spine, as well as causing pre-existing, but otherwise asymptomatic conditions, to become problematic. 12. As a result of the aforesaid injuries, the Plaintiff was forced to seek and receive medical intervention including, but not limited to: a. Almost weekly manual spinal manipulation and mechanical traction for over twelve (12) months; b. Multiple diagnostic tests; c. Several weeks of physical therapy to alleviate her pam and regam strength; and d. Numerous visits to health care providers attempting to diagnose and treat Plaintiffs injuries. 13. As a further result of the Defendants' recklessness and negligence, the Plaintiff was caused to experience and suffer from: a. Pain in her neck, upper extrernities, cervical and lumbar spine; b. Pain and stiffness in the morning and again as the day progresses; c. Pain when bending and with prolonged sitting; d. Severe neck pain which was at times severe and debilitating; e. Severe rlizziness and imbalance; f. Inability to engage in certain of her life's activities; 4 '. g. Fear and anxiety arising from indications that her symptoms and problerns could not be successfully treated; h. Fear and anxiety arising frorn indications that her problems would be permanent. 14. Plaintiff has been advised and therefore avers that her injuries are serious and symptomotology arising from these injuries and/or re-aggravated by the accident may be permanent and continued treatment throughout Plaintiffs lifetime may be necessary. 15. As a further result of Defendants' recklessness, Plaintiff Blose has sustained a severe shock to her nerves and nervous system which has caused her to undergo great mental anguish and physical pain from which she still suffers and will continue to suffer for an indefinite time in the future. 16, As a further result of Defendants' recklessness and injuries suffered by Plaintiff, Christine A. Blose, Plaintiffs have been compelled to expend various sums of money for rnedicine and medical attention. They have further been advised and therefore aver they will continue to expend sums of money for medicine and medical attention for an unlimited time into the future. 17, As a result of the crash and injuries sustained by Plaintiff, Christine A. Blose, she was unable to follow her usual occupation and routine, suffering lost wages, and has been deprived of the ability to enjoy the simple pleasures of life and will be unable to do so for an indefinite time into the future. 18. Plaintiffs have satisfied all conditions precedent to filing and proceeding with this lawsuit. 5 COUNT I CHRISTINE A. AND JAMES S. BLOSE V. KENNETH A. HOSTETTER 19. The averments contained in paragraphs 1 through 18 of this Complaint are hereby incorporated by reference as if set forth at length. 20. The aforesaid accident and injuries sustained by the Plaintiffs was a direct and proximate result of the recklessness and gross negligence of Defendant Hostetter. 21. The recklessness and gross negligence of Defendant Hostetter is both general and in the following particular respects: a. Driving and otherwise operating a vehicle under his control in a reckless, careless and negligent manner; b. Driving and otherwise operating a vehicle under his control at an excessive rate of speed; c. Driving and otherwise operating a vehicle under his control such that it caused a chain reaction which force ultimately struck the vehicle occupied and being operated by Plaintiff, Christine A. Blose; d. Driving and otherwise operating a vehicle under his control in violation of the Pennsylvania Motor Vehicle Code; e. Driving and operating a vehicle under his control without due regard to the right, safety and position of Plaintiffs vehicle; f. Driving and otherwise operating a vehicle under his control without due regard for other traffic on the road; g. Failing to pay attention and to have his vehicle under control at all times; and 6 ". h. Failed to stop his vehicle such that it caused a chain reaction rear end impact with a third party vehicle which ultimately impacted the vehicle of Plaintiff. 22. As a result of the recklessness herein set forth, and the negligence set forth in Count II hereof, the Plaintiffs sustained injuries as hereinbefore set forth. 23. It is believed and therefore averred that Plaintiff will in the future sustain loss of earnings and earning potential and will also, in the future, require continued medical care and treatment. 24. As a result of the negligence as set forth herein, Plaintiff has incurred substantial costs for co-pays, medical treatment, prescription drugs, fees for medical records, filing fees, lost wages and the like. WHEREFORE, the Plaintiff, Christine A. Blose, demands judgment against the Defendant Hostetter in an amount in excess of that requiring compulsory arbitration. COUNT II JAMES S. BLOSE. in his own rieht v. KENNETH A. HOSTETTER 25. The averments contained in paragraphs 1 through 24 of this Complaint are hereby incorporated by reference hereto as set forth at length herein. 26. At all times hereto, Plaintiff, James S. Blose was the husband and spouse of Plaintiff, Christine A. Blose. 27. As a result of the negligence of the Defendant, Plaintiff, James S. Blose was forced to attend to the injuries sustained by his wife, Christine A. Blose. 28. As a result of the negligence of the Defendant, Plaintiff, James S. Blose was denied the companionship, consortium, love, affection, tenderness of his wife and spouse, Christine A. Blose. 7 '. WHEREFORE, Plaintiff, James S. Blose, demands judgment against the Defendant Hostetter in an amount in excess of the amount requiring compulsory arbitration. COUNT III CHRISTINE A. AND JAMES S. BLOSE V. BRANDON R. SHORTER 29. The averments contained in paragraphs 1 through 28 of this Complaint are hereby incorporated by reference as if set forth at length. 30. The aforesaid accident and injuries sustained by the Plaintiffs was a direct and proximate result of the recklessness and gross negligence of Defendant Shorter. 31. The recklessness and gross negligence of Defendant Shorter is both general and in the following particular respects: a. Driving and otherwise operating a vehicle under his control in a reckless, careless and negligent manner; b. Driving and otherwise operating a vehicle under his control at an excessive rate of speed; c. Driving and otherwise operating a vehicle under his control such that it caused a chain reaction which force ultimately struck the vehicle occupied and being operated by Plaintiff, Christine A. Blose; d. Driving and otherwise operating a vehicle under his control in violation of the Pennsylvania Motor Vehicle Code; e. Driving and operating a vehicle under his control without due regard to the right, safety and position of Plaintiff' s vehicle; f. Driving and otherwise operating a vehicle under his control without due regard for other traffic on the road; and 8 g. Failing to pay attention and to have his vehicle under control at all times. 32. As a result of the recklessness herein set forth, and the negligence set forth in Count IV hereof, the Plaintiffs sustained injuries as hereinbefore set forth. 33. It is believed and therefore averred that Plaintiff will in the future sustain loss of earnings and earning potentia' and will also, in the future, require continued medical care and treatment. 34. As a result of the negligence as set forth herein, Plaintiff has incurred substantial costs for co-pays, medical treatment, prescription drugs, fees for medical records. filing fees, lost wages and the like. WHEREFORE, the Plaintiff, Christine A. Blose, demands judgment against the Defendant Shorter in an amount in excess of that requiring compulsory arbitration. COUNT IV JAMES S. BLOSE. in his own rieht v. BRANDON R. SHORTER 35. The averments contained in paragraphs I through 34 of this Complaint are hereby incorporated by reference hereto as set forth at length herein. 36. At all times hereto, Plaintiff, James S. Blose was the husband and spouse of Plaintiff, Christine A. Blose. 37. As a result of the negligence of the Defendant, Plaintiff, James S. Blose was forced to attend to the injuries sustained by his wife, Christine A. Blose. 38. As a result of the negligence of the Defendant, Plaintiff, James S. Blose was denied the companionship, consortium, love, affection, tenderness of his wife and spouse, Christine A. Blose. 9 '. WHEREFORE, Plaintiff, James S. Blose, demands judgment against the Defendant Shorter in an amount in excess of the amount requiring compulsory arbitration. Date: /J-Y-tJ5 Mark W. Allshouse, Esquire Attorney ID # 78014 4833 Spring Road Shermans Dale, P A 17090 (717) 582-4006 Attorney for Plaintiffs lO '. VERIFICATION I verify that the statLments made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of l8 Pa. C.S. S 4904, relating to unsworn falsification to authorities. VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. /)h I/~ L )\,d ,,0 -Lc;;'~ Christine A. Blose ~- , L" u ,- ~,..;;. " ";\ \>, CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOEN~, PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTINE A. BLOSE AND JAMES S. BLOSE TERM, CUMBERLAND -VS- CASE NO: 05-4575 KENNETH A. HOSTETTER AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of THOMAS WILLIAMS, 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: 12/13/2005 M~y:BehaH of /. /1// _ ./, /., . ~(.//C/~'t/l /'YTHOMAS WILLIJlMS, ESQ. I Attorney for DEFENDANT DEll-5~19852 08582 -LO 1 (L' /' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTINE A. BLOSE AND JAMES S. BLOSE TERM, -VS- CASE NO: 05-4575 KENNETH A. HOSTETTER NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 'l009,21 [ Note: see enclosed list of locations] TO: MARK W. ALLSHOUSE, ESQ., PLAINTIFF COUNSEL MCS on behalf of THOMAS WILLIAMS, 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 reconi and serve upon the undersigned an objection to the subpoena. If the twenty iliiy notice period is waived or if no objection is made, then th~ 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: 11/23/2005 MCS on behalf of THOIIl[AS WILLIAMS, ESQ. Attorney for DEFENDANT CC: THOMAS WILLIAMS, ESQ. - 7837.183 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHHADELPHIA, PA 19103 (215) 246-0900 DE02-318395 08582 -co 1 LOCATION NAME BECKER CHIROPRACTIC DR. RICHARD BISBING COLLEEN FOOS, M.D. MICHAEL LUPINACCI, M.D. DR. PETER GIESSWEIN RAVI DUKKIPATI, MD. ADAM C, ABRAM, MD DR. ROBERT MICHELINI DR. SHAWNA BRENT >>> LOCATION LIST <<< PAGE: 1 RECORDS REQUESTED MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS DE02-318395 OBS82-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHRlSTINE A. BLOSE AND JAMES S. BLOSE FileNo. 05-4575 vs. KENNETH A. HOSTETTER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for BECKER CHIROPRACTIC (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 A TT ACHED RIDER .... at The MCS Group Ine 1601 Market Street Suite ROO Philadelphia PA ]9]03 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: ADDRESS: THOMAS WILLIAMS. ESO. 10 EAST HIGH STREET CARI.ISI.E PA 17013 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: AJ,.-)(") I P, d.-OQ.S B~E COURT: .v2~ Prothonotary/Clerk, Civil Div' . ~Jtt~ - Deputy Seal of the Court 08582-0] EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: BECKER CHIROPRACTIC 50l MARKET STREET LEMOYNE, PA l7043 RE: 8582 CHRISTINE A. BLOSE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication! prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: CHRISTINE A. BLOSE 164 RYE LANE, SHERMANS DALE, PA 17090 Social Security #: 169-64-1825 Date of Birth: 07.17.1968 SU1Cl-593026 0 B 5 B 2 - LO]. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENJl PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTINE A. BLOSE AND JAMES S. BLOSE TERM, CUMBERLAND -VS- CllSE NO: 05-4575 KENNETH A. HOSTETTER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of THOMAS WILLIAMS, 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, 12/13/2005 THOMAS WILLIAMS, ESQ. Attorney for DEFENDANT DEl1-5'19853 08582 - L 02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTINE A. BLOSE AND JAMES S. BLOSE TERM, -VS- CASE NO: 05-4575 KENNETH A. HOSTETTER 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: MARK W. ALLSHOUSE, ESQ., PLAINTIFF COUNSEL MCS on behalf of THOMAS WILLIAMS, 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 th~ 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: 11/23/2005 MCS on behalf of THOM~S WILLIAMS, ESQ. Attorney for DEFENDANT CC: THOMAS WILLIAMS, ESQ. - 7837,183 Any questions regarding this matter, contact THEMCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-318395 08582 - CO]. LOCATION NAME >>> LOCATION LIST <<< RECORDS REQUESTED PAGE: 1 BECKER CHIROPRACTIC DR. RICHARD BISBING COLLEEN FOOS, M.D. MICHAEL LUPINACCI, M.D, DR. PETER GIESSWEIN RAVI DUKKIPATI, MD. ADAM C. ABRAM, MD DR, ROBERT MICHELINI DR. SHAWNA BRENT MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS DE02-3U395 08582 -CO 1 COMMONWEAL THOF PENNSYLVANIA, COUN'1Y OF CUMBERLAND CHRISTINE A. BLOSE AND JAMES S. BLOSE FileNo. 0',-4575 vs. KENNETH A. HOSTETTER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. RICHARD BISBING (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 Ine 160] 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: ADDRESS: THOMAS WILLIAMS. ESO. 10 EAST HIGH STREET CARI.ISLE PA 17013 TELEPHONE: (2] 5\ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: ,/'LJeYl. If ~ClSS , BY THE COURT: (J ~;;d;w, Prothonotary/Clerk, CIvil ~Ch.L> _ Deputy Seal of the Court 08582-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. RICHARD BISBING 4570 VALLEY ROAD SHERMANS DALE, PA 17090 RE: 8582 CHRISTINE A. BLOSE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication! prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: CHRISTINE A. BLOSE 164 RYE LANE, SHERMANS DALE, PA 17090 Social Security #: 169-64-1825 Date of Birth: 07-17-1968 5U10-593028 0 B 5 B 2 - LO 2 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOEN~ PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTINE A. BLOSE AND JAMES S. BLOSE TERM, CUMBERLAND -VS- CASE NO: 05-4575 KENNETH A. HOSTETTER AS a prerequisite to service of a subpoena for documents imd things pursuant to Rule 4009.22 MCS on behalf of THOMAS WILLIAMS, 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: 12/13/2005 THOMAS WILLIAMS, ESQ. Attorney for DEFENDANT DEll-599854 08582 - L 03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTINE A. BLOSE AND JAMES S. BLOSE TERM, -VS- CASE NO: 05 -4 575 KENNETH A. HOSTETTER 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: MARK W. ALLSHOUSE, ESQ" PLAINTIFF COUNSEL MCS on behalf of THOMAS WILLIAMS, 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 th~ subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning saine to MCS or by contacting our local MCS office. DATE: 11/23/2005 MCS on behalf of THOM~S WILLIAMS, ESQ. Attorney for DEFENDANT CC: THOMAS WILLIAMS, ESQ. - 7837.183 Any questions regarding this matter, contact THEMCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-318395 08S82-COl >>> LOCATION LIST <<< LOCATION NAME RECORDS REQUESTED BECKER CHIROPRACTIC DR. RICHARD BISBING COLLEEN FOOS, M.D. MICHAEL LUPINACCI, M.D. DR. PETER GIESSWEIN RAVI DUKKIPATI, MD. ADAM C. ABRAM, MD DR. ROBERT MICHELINI DR. SHAWNA BRENT MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS PAGE: 1 DE02-311l395 08582 -CO 1 COMMONWEALTH OF PENNSYL VANIA, COUNTY OF CUMBERLAND CHRISTINE A. BLOSE AND JAMES S. BLOSE FileNo. 05-4575 vs. KENNETH A. HOSTETTER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for COLI.EENFOOS MD. (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 Tne 160l 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 Ilisted 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: ADDRESS: THOMAS WILLIAMS. ESO. 10 EAST HIGH STREET CARLISLE P A 170 I 3 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: A TTORNEY FOR: Defendant Date: ell )no . I P' ~~oS" , Be::~r: 'J Prothonotary/Clerk, CiVil Di '--- ~~~ -2.7f/?U4J Deputy Seal of the Court 08582-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: COLLEEN FOOS, M.D. 9 FLOWERS DRIVE MECHANICSBURG, PA RE: 8582 CHRISTINE A. BLOSE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records" correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication! prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any t:xamination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: CHRISTINE A. BLOSE 164 RYE LANE, SHERMANS DALE, PA 17090 Social Security #: 169-64-1825 Date of Birth: 07-17-1968 SU10-593030 0 B 5 B 2 - La 3 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENll PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTINE A. BLOSE AND JAMES S. BLOSE TERM, CUMBERLAND -VS- CIlSE NO: 05-4575 KENNETH A. HOSTETTER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of THOMAS WILLIAMS, 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, 12/13/2005 THOMAS WILLIIlMS, ESQ. Attorney for DEFENDANT DEll-5'19855 08582 - L 0 4 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTINE A. BLOSE AND JAMES S. BLOSE TERM, -VS- CASE NO: 05-4575 KENNETH A. HOSTETTER NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations 1 TO: MARK W. ALLSHOUSE, ESQ., PLAINTIFF COUNSEL MCS on behalf of THOMAS WILLIAMS, 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 th~ subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning saine to MCS or by contacting our local MCS office, DATE: 11/23/2005 MCS on behalf of THOM~S WILLIAMS, ESQ. Attorney for DEFENDANT cc: THOMAS WILLIAMS, ESQ. - 7837.183 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246 -0900 DE02-318395 08582 - CO 1 LOCATION NAME BECKER CHIROPRACTIC DR, RICHARD BISBING COLLEEN FOOS, M.D. MICHAEL LUPINACCI, M.D. DR. PETER GIESSWEIN RAVI DUKKIPATI, MD. ADAM C, ABRAM, MD DR, ROBERT MICHELINI DR, SHAWNA BRENT >>> LOCATION LIST <<< PAGE, 1 RECORDS REQUESTED MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS DE02-31B39508S82-COl COMMONWEALTH OF PENNSYLVANl;l~ COUNTY OF CUMBERLAND CHRISTINE A. BLOSE AND JAMES S. BLOSE FileNo. 05-4575 vs. KENNETH A. HOSTETTER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MICHAEL LUPINACCI. M.D. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the COUlrt to produce the following documents or things: .... SEE A TT ACHED RIDER .... at The MCS Graun Ine ]601 Market Street Suite ROO Philadelphia PA 19lO1 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: ADDRESS: THOMAS WILLIAMS. ESO. 10 EAST HIGH STREET CARLISLE PA ]7013 TELEPHONE: 1215\ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: ,.Itb) . lP ~()<:, S- , B{t=':: Prothonotary/Clerk, ~~th-C _ Deputy n Seal of the Court 08582-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MICHAEL LUPINACCI, M.D. 175 LANCASTER BLVD. P.O. BOX 2028 MECHANICSBURG, PA 17055 RE: 8582 CHRISTINE A. BLOSE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records., correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication! prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: CHRISTINE A. BLOSE 164 RYE LANE, SHERMANS DALE, PA 17090 Social Security #: 169-64-1825 Date of Birth: 07-17-1968 SUIO-593032 08S82-L04 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOE~~ PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTINE A. BLOSE AND JAMES S. BLOSE TERM, CUMBERLAND -VS- CASE NO: 05-4575 KENNETH A. HOSTETTER As a prerequisite to service of a subpoena for documents ,md things pursuant to Rule 4009.22 MCS on behalf of THOMAS WILLIAMS, 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: 12/13/2005 THOMAS WILLIAMS, ESQ. Attorney for DEFENDANT DEll-5'J9856 08582 - LOS COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTINE A. BLOSE AND JAMES S. BLOSE TERM, -VS- CASE NO: 05-4575 KENNETH A. HOSTETTER NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009,21 [ Note: see enclosed list of locations 1 TO: MARK W. ALLSHOUSE, ESQ., PLAINTIFF COUNSEL MCS on behalf of THOMAS WILLIAMS, 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 th!! subpoena may be served. Complete copies of any reproduced records may be or9-ered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office, DATE: 11/23/2005 MCS on behalf of THOK~S WILLIAMS, ESQ. Attorney for DEFENDANT CC: THOMAS WILLIAMS, ESQ. - 7837.183 Any questions regarding this matter, contact THE ]!o\CS GROUP INC, 1601 MARKET STREET #800 PHIL.IUlELPHIA, PA 19103 (215) 246-0900 DE02-318395 08S82-COl LOCATION NAME >>> LOCATION LIST <<< RECORDS REQUESTED PAGE: 1 BECKER CHIROPRACTIC DR. RICHARD BISBING COLLEEN FOOS, M.D. MICHAEL LUPINACCI, M.D. DR, PETER GIESSWEIN RAVI DUKKIPATI, MD. ADAM C. ABRAM, MD DR. ROBERT MICHELINI DR. SHAWNA BRENT MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS DE02-3183950BS82-COl COMMONWEALTH.oF PENNSYLVANIP~ COUNTY OF CUMBERLAND CHRISTINE A. BLOSE AND JAMES S. BLOSE FileNo. 0';-4575 vs. KENNETH A. HOSTETTER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR PETER GIESSWEIN (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 Grolij) Inc l60l Market Street Suite ROO Philadelnhia 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: ADDRESS: THOMAS WILLIAMS. ESO. 10 EAST HIGH STREET CARLISLE.PA 17013 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: ,/Z}~{) . J P J-C6S , BY THE COURT: (JA~.)7<. Prothonotary/Clerk, Civil C ~~_oJ~ Deputy . Seal of the Court 08582-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. PETER GIESSWEIN 5 BROOKWOOD AVE. SUITE 1 CARLISLE, PA 17013 RE: 8582 CHRISTINE A. BLOSE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication! prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any t,xamination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: CHRISTINE A. BLOSE 164 RYE LANE, SHERMANS DALE, PA 17090 Social Security #: 169-64-1825 Date of Birth: 07-17-1968 SUlO-593034 08582-L05 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOEN~ PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTINE A. BLOSE AND JAMES S. BLOSE TERM, CUMBERLAND -VS- CASE NO: 05-4575 KENNETH A. HOSTETTER AS a prerequisite tI;l service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of THOMAS WILLIAMS, 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: 12/13/2005 THOMAS WILLIAMS, ESQ. Attorney for DEFENDANT DEll-599857 08S82-L06 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTINE A. BLOSE AND JAMES S. BLOSE TERM, -VS - CASE NO: 05-4575 KENNETH A. HOSTETTER 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: MARK W, ALLSHOUSE, ESQ., PLAINTIFF COUNSEL MCS on behalf of THOMAS WILLIAMS, 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 da" notice period is waived or if no objection is made, then th!! subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning saine to MCS or by I~ontacting our local MCS office. DATE: 11/23/2005 MCS on behalf of THO~~S WILLIAMS, ESQ. Attorney for DEFENDANT CC: THOMAS WILLIAMS, ESQ, - 7837.183 Any questions regarding this matter, contact THE ]~CS GROUP INC, 1601 MARKET STREET #800 PHI~~ELPHIA, PA 19103 (215) 246-0900 DE02-31B395 08582 -CO 1 LOCATION NAME BECKER CHIROPRACTIC DR, RICHARD BISBING COLLEEN FOOS, M.D. MICHAEL LUPINACCI, M.D, DR. PETER GIESSWEIN RAVI DUKKIPATI, MD. ADAM C. ABRAM, MD DR. ROBERT MICHELINI DR. SHAWNA BRENT >>> LOCATION LIST <<< PAGE: 1 RECORDS REQUESTED MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS DE02-31!1395 0 8582 - C 01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHRISTINE A. BLOSE AND JAMES S. BLOSE FileNo. 05-4575 vs. KENNETH A. HOSTETTER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for RAVIDUKKlPATI MD (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 A TT ACHED RIDER .... at The MCS Gronn Tnc ] 601 Market Street Snite 800 Philadelnhia PA 19]03 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: ADDRESS: THOMAS WILLIAMS. ESO. 10 EAST HIGH STREET CARLISLE. PA 17013 TELEPHONE: (2] 5) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: AJOt) . /P .J /y:., S- / BY THE COURT: aA~-b Prothonotary/Clerk, Civil D 10 ~t'1-.--O _ Deputy c. Seal of the Court 08582-06 EXPLANA nON OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: RAVI DUKKIPATI, MD. 897 POPLAR CHURCH ROAD CAMP HILL, PA 17011 RE: 8582 CHRISTINE A. BLOSE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication! prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: CHRISTINE A. BLOSE 164 RYE LANE, SHERMANS DALE, PA 17090 Social Security #: 169-64-1825 Date of Birth: 07-17-1968 5U10-593036 OB5B2-LOG CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENII PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTINE A. BLOSE AND JAMES S. BLOSE TERM, CUMBERLAND -VS- CIlSE NO: 05-4575 KENNETH A. HOSTETTER AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of THOMAS WILLIAMS, 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: 12/13/2005 THOMAS WILLIIlMS, ESQ. Attorney for DEFENDANT DEll-5B858 08582 -LO 7 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COJRT OF COMMON PLEAS CHRISTINE A. BLOSE AND JAMES S. BLOSE TERM, -VS- CASE NO: 05-4575 KENNETH A. HOSTETTER NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations 1 TO: MARK W. ALLSHOUSE, ESQ., PLAINTIFF COUNSEL MCS on behalf of THOMAS WILLIAMS, 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 saine to MCS or by contacting our local MCS office. DATE: 11/23/2005 MCS on behalf of THOM~S WILLIAMS, ESQ, Attorney for DEFENDANT CC: THOMAS WILLIAMS, ESQ. - 7837.183 Any questions regarding this matter, contact THE MCS GROUP INC, 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-318395 0 B 5 B 2 - C 01 LOCATION NAME BECKER CHIROPRACTIC DR. RICHARD BISBING COLLEEN FOOS, M.D. MICHAEL LUPINACCI, M.D. DR. PETER GIESSWEIN RAVI DUKKIPATI, MD. ADAM C, ABRAM, MD DR. ROBERT MICHELINI DR. SHAWNA BRENT >>> LOCATION LIST <<< PAGE: 1 RECORDS REQUESTED MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS DE02-31:B395 085 B 2 - C 0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHRlSTINE A. BLOSE AND JAMES S. BLOSE FileNo. 05-4575 vs. KENNETH A. HOSTETTER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ADAM C ABRAM MD (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 A TT ACHED RlDER **** at The MCS Groun Inc ] 601 Market Street Suite 800 PhiJadelnhia 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: ADDRESS: THOMAS WILLIAMS. ESO. 10 EAST HIGH STREET CARI.ISLE PA ]7013 TELEPHONE: (2]5) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: ./1)O(J. /P .:l rYl-S I BY THE COURT: a ~/l-h-.-J Prothonotary/Clerk, Civil D' ~;.;h~ 0 j:J 7f~~lur-' eputy Seal of the Court 08582-07 EXPLANATION OF REQUIRED Rl~CORDS TO: CUSTODIAN OF RECORDS FOR: ADAM C. ABRAM, MD 220 WILSON ST. STE 200 CARLISLE, PA l7013 RE: 8582 CHRISTINE A. BLOSE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records" correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication! prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: CHRISTINE A. BLOSE 164 RYE LANE, SHERMANS DALE, PA 17090 Social Security #: 169-64-1825 Date of Birth: 07-17-1968 SU10-593038 OBSB2-L07 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTINE A. BLOSE AND JAMES S. BLOSE TERM, CUMBERLAND -VS- CASE NO: 05-4575 KENNETH A. HOSTETTER AS a prerequisite to service of a subpoena for documents ,nd things pursuant to Rule 4009.22 MCS on behalf of THOMAS WILLIAMS, ESQ. certifies that (1) A notice of intent to serve the subpoen~ 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: 12/13/2005 THOMAS WILLIl\MS, ESQ. Attorney for DEFENDANT DEll-5~19859 08582 - L 08 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTINE A. BLOSE AND JAMES S. BLOSE TERM, -VS- CASE NO: 05-4575 KENNETH A. HOSTETTER 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: MARK W. ALLSHOUSE, ESQ., PLAINTIFF COUNSEL MCS on behalf of THOMAS WILLIAMS, 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 th~ subpoena may bl~ served. Complete copies of any reproduced records may be or~ered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/23/2005 MCS on behalf of THOM~S WILLIAMS. ESQ, Attorney for DEFENDANT CC: THOMAS WILLIAMS, ESQ, - 7837.183 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-3l8395 08582 - CO 1 LOCATION NAME >>> LOCATION LIST <<< RECORDS REQUESTED PAGE: 1 BECKER CHIROPRACTIC DR. RICHARD BISBING COLLEEN FOOS, M.D. MICHAEL LUPINACCI, M.D. DR. PETER GIESSWEIN RAVI DUKKIPATI, MD. ADAM C. ABRAM, MD DR. ROBERT MICHELINI DR. SHAWNA BRENT MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS DE02-318395 08582-COl COMMONWEALTH OF PENNSYLVANIA COUN1Y OF CUMBERLAND CHRISTINE A. BLOSE AND JAMES S. BLOSE File No. ~;-4575 vs. KENNETH A. HOSTETTER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. ROBERT MICHELINI (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 A TT ACHED RIDER .... at The MCS Graun Ine l60l Market Street Suite ROO 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: ADDRESS: THOMAS WILLIAMS. ESO. ] 0 EAST HIGH STREET CARLISLE PA 170]3 TELEPHONE: (2] 5\ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: .A JOt) IP,~ , BYTHECOUR~: rJ~~. . Prothonotary/Clerk, Civil iV~ " ~Ch.O~- '---oeputy Seal of the Court 08582-08 EXPLANATION OF REQUIRED Rl8:CORDS TO: CUSTODIAN OF RECORDS FOR: DR. ROBERT MICHELINI 159 CENTER ROAD NEW BLOOMFIELD, PA 17068 RE: 8582 CHRISTINE A. BLOSE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medkation! prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present, Subject: CHRISTINE A. BLOSE 164 RYE LANE, SHERMANS DALE, PA 17090 Social Security #: 169-64-1825 Date of Birth: 07-17.1968 SU11J-593040 OB5B.2-LOB CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOEN1\ PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTINE A. BLOSE AND JAMES S. BLOSE TERM, CUMBERLAND -VS- C;,SE NO: 05-4575 KENNETH A. HOSTETTER As a prerequisite to service of a subpoena for documents a.nd things pursuant to Rule 4009.22 MCS on behalf of THOMAS WILLIAMS, ESQ. certif ies that (1) A notice of intent to servi 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: 12/13 / 2 0 05 THOMAS WILLIAMS, ESQ. Attorney for DEFENDANT DEll-599860 08582 - L 09 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTINE A. BLOSE AND JAMES S. BLOSE TERM, -VS- CASE NO: 05-4575 KENNETH A. HOSTETTER NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009,21 [ Note: see enclosed list of locations 1 TO: MARK W. ALLSHOUSE, ESQ" PLAINTIFF COUNSEL MCS on behalf of THOMAS WILLIAMS, 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 th~ subpoena may be served, Complete copies of any reproduced records may be or~red at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/23/2005 MCS on behalf of THOMAS WILLIAMS, ESQ. Attorney for DEFENDANT CC: THOMAS WILLIAMS, ESQ, - 7837.183 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246 -0900 DE02-318395 085 B 2 - C 01 LOCATION NAME >>> LOCATION LIST <<< RECORDS REQUESTED PAGE: 1 BECKER CHIROPRACTIC DR. RICHARD BISBING COLLEEN FOOS, M.D. MICHAEL LUPINACCI, M.D. DR, PETER GIESSWEIN RAVI DUKKIPATI, MD. ADAM C. ABRAM, MD DR. ROBERT MICHELINI DR. SHAWNA BRENT MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS DE02-3H139508S82-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHRISTINE A. BLOSE AND JAMES S. BLOSE File No. ___J15-4575 vs. KENNETH A. HOSTETTER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. SHA WNA BRENT (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 Oroun Ine ]601 Market Street Suite 800 PhiladeInhia PA 19]01 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. TIllS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: THOMAS WILLIAMS. ESO. 10 EAST HIGH STREET CARLISLE PA ]7013 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: . ,A )Of I If d./)&~ I BY THE COURT: ,/~ . Prot onotary/Clerk, C1Vl DIy, , ~()1nA~ ---Deputy Seal of the Court 08582-09 EXPLANATION OF REQUIRED RJECORDS TO: CUSTODIAN OF RECORDS FOR: DR. SHA WNA BRENT 20 ERFORD ROAD LEMOYNE, PA l7043 RE: 8582 CHRISTINE A. BLOSE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication! prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: CHRISTINE A. BLOSE 164 RYE LANE, SHERMANS DALE, PA 17090 Social Security #: 169-64-1825 Date of Birth: 07-17-1968 SU10-593042 OB5B2-L09 SHERIFF'S RETURN - OUT OF COUNTY ',. .,. CASE NO: 2005-04575 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BLOSE CHRISTINE A ET AL VS HOSTETTER KENNETH A R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: SHORTER BRANDON but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of PERRY County, Pennsylvania, to serve the within COMPLAINT & NOTICE On January 5th , 2006 , this office was in receipt of the attached return from PERRY Sheriff's Costs: Docketing Out of County Surcharge Dep Perry County Postage 18.00 9.00 10.00 27.76 1. 25 66.01 01/05/2006 CHRISTIAN LAWYER So answers.:.__~ ----'~--- -, z~:.-:><? ~,>~-- /~~::~_.-. R. Thomas Kline Sheriff of Cumberland County SOLUTIONS this , A- 10 -- subscribed to before -"I day Of"-.~ , AD~ foth ~ ary ~ me Sworn and ,:)Il-{J L . ., .. In The Court of Common Pleas of Cumberland County, Pennsylvania Christine A. Blose et al VS. Kenneth A. Hostetter et al SERVE: Brandon R. Shorter No. 05-4575 civil Now, Decenber 8, 200~ I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Perry County to execute this Writ, tbis deputation being made at the request and risk of the Plaintiff. .~~~~ Sheriff of Cumberland County, PA Affidavit of Service Now, ,20_, at 0' clock M, served the within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this _ day of ,20_ COSTS SERVICE MILEAGE AFFIDA VIT $ $ . . SHERIFF'S RETURN In the Court of Common Pleas Ofthe 41 st Judicial District of Pennsylvania- Perry County Branch No. 2005-4575 Cumberland County Christine A. Blose and J ames Blose VS Brandon R. Shorter 8 Country Meadows Shermansdale, P A 17090 Carl E. Nace, Sheriff, who being duly sworn according to law, says that he made a diligent search and inquiry for the within named Defendant(s) to wit, Brandon R. Shorter, but was unable to locate him/her in his bailiwick. He therefore returns the within Complaint for the above named Defendant(s) Brandon R. Shorter at 8 Country Meadows Shermansdale, PA 17090,NOT FOUND. NO SUCH ADDRESS IN SHERMANSDALE. PA. So Answers, Sworn and subscribed to before me thisd'i) day of &~nbe-(, 2005. d:vl 1 /; ( '.A:'vV . Carl E. Nace Sheriff of Perry County /~ NOTARIAL SL\l lIMGAREf f. FUCKlNGER. NOTAR'/ PUBUC 8lOO1lFIWl BORO.. KRR'I COUNTY II'f COMMISSION OO'IRlS Ff.B. 16 Wl8 \ CHRISTINE A. BLOSE, and JAMES S. BLOSE, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. : NO. 05-4575 KENNETH A. HOSTETTER, and BRANDON R. SHORTER, Defendants : CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please mark the above-caption matter as settled, discontinued and forever ended with prejudice as to all Defendants. Date: 1/L7/(J(, Attorney for Plaintiffs , CHRISTINE A. BLOSE, and JAMES S. BLOSE, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. : NO. 05-4575 KENNETH A. HOSTETTER, and BRANDON R. SHORTER, Defendants CIVIL ACTION - LAW CERTIFICATE OF SERVICE I hereby certifY that a copy of the foregoing docwnent has been duly served upon the following, by depositing a copy of the same in the United States Mail, first-class, postage prepaid, as follows: Thomas J. Williams, Esquire Hillary A. Dean, Esquire MARTS ON, DEARDORFF, WILLIAMS & OTTO Ten East High Street Carlisle, P A 17013 Progressive Insurance Attention: Veronica Shirk 4000 Crums Mill Road Suite 201 Harrisburg,PA l7112 k W. Allshouse, squire . LD. # 78014 4833 Spring Road Shermans Dale, P A 17090 (717) 582-4006 Date:t(Z.7(O" Attorney for Plaintiffs -0(' qJi ~~( f":- ,- :;>:.... ~.,.~ (,-' >('" o ,;;; .'- -::.~ '-, ...., = <=> a-> <.... ". Z (..) C> ~ -l :I::;n n1F- ""t?rtl -"0 ~~~~ -~)E~ ~~5n. ~~ C..o :< ".. ::l: N