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HomeMy WebLinkAbout05-6738SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff DARRAINE JONES, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA n I ?j- NO. Q -! ry3? atl L ( ' 1 CUMBERLAND-DAUPHIN-HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, and NORMA TOTTEN, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED 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 writincl 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 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 THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attornevs for Plaintiff DARRAINE JONES, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. CUMBERLAND-DAUPHIN-HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, and NORMA TOTTEN, Defendants NO. CIVIL ACTION - LAW JURY TRIAL DEMANDED LE HAN DEMANDADO A LISTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en ]as paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomaro medidas y puede entrar una orden contra Listed sin previo aviso o notoficacaion y por cualquier queja o alivio que es pedido en la peticion do demanda. usted puede perder dinero o sus propiededas o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff DARRAINE JONES, Plaintiff V. CUMBERLAND-DAUPHIN-HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, and NORMA TOTTEN, Defendants AND NOW comes the Plai IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. C?.S L 73 S- 6? ? ,. CIVIL ACTION - LAW JURY TRIAL DEMANDED JONES, by and through her attorneys, SHOLLENBERGER & JANUZZI, LLP, and respectfully represents the following: 1. The Plaintiff, DARRAINE JONES, is an adult individual who currently resides at 641 South 29th Street, Harrisburg, Pennsylvania '17111. 2. The Defendant, NORMA D. TOTTEN, ("Totten"), is an adult individual whose last known address is 220 West Water Street, Middletown, PA 17057. 3. The Defendant, CUMBERLAND-DAUPHIN-HARRISBURG TRANSIT AUTHORITY, is a Pennsylvania Corporation trading and doing business as CAPITAL AREA TRANSIT, ("CAT"), with its principal place of business located at 901 North Cameron Street, Harrisburg, Dauphin County, Pennsylvania 17105. 1 4. At all times relevant hereto, Defendant Totten was acting as the agent, servant and/or employee of Defendant CAT, and was operating the aforesaid 2002 Ford Bus within the course and scope of the agency and/or employment relationship with Defendant CAT. 5. The facts and circumstances hereinafter set forth took place on March 22, 2004, at or about 6:00 A.M., at the intersection of Market and Eighth Streets in Lemoyne, Cumberland County, Pennsylvania. 6. At the aforesaid time and place, Plaintiff, DARRAINE JONES, was the operator of a 1997 Honda Accord traveling on Market Street when Defendant Totten, while operating the aforesaid bus owned by Defendant CAT, pulled from a stop sign on Eighth Street, directly into the path of Plaintiff, striking her automobile on the rear passenger side and causing it to become airborne. 7. As a result of the aforesaid incident, Plaintiff, DARRAINE JONES, has suffered serious and permanent injuries, including but not limited to the following: (a) severe strain and sprain of the muscles, tendons, ligaments and other soft tissues at or about the cervical spine; (b) severe strain and sprain of the muscles, tendons, ligaments and other soft tissues at or about the thoracic spine; (c) severe strain and sprain of the muscles, tendons, ligaments and other soft tissues at or about the lumbar spine; (d) aggravation of pre-existing fibromyalgia; (e) severe shock to nerves and nervous system; (f) mental and physical anguish. 2 8. As a direct and proximate result of the aforesaid injuries, Plaintiff, DARRAINE JONES, has undergone and in the future will undergo great pain and suffering for which damages are claimed. 9. As a further result of the aforesaid injuries, Plaintiff, DARRAINE JONES, has suffered and may continue to suffer a loss of earnings for which damages are claimed. 10. As a further result of the aforesaid injuries, Plaintiff, DARRAINE JONES, has suffered and may continue to suffer a loss of earning capacity for which damages are claimed. 11. As a further result of the aforesaid injuries, Plaintiff, DARRAINE JONES, has sustained a permanent diminution in her ability to enjoy life and life's pleasures for which damages are claimed. 12. As a further result of this collision, Plaintiff, DARRAINE JONES, has and/or may incur reasonable and necessary medical and rehabilitative costs and expenses in excess of the amounts paid or payable pursuant to Subchapter B of the Pennsylvania Motor Vehicle Financial Responsibility Law, Workers' Compensation or any program, group contract, or other arrangement for payment of benefits as defined in 75 Pa. C.S.A. Section 1719. COUNTI DARRAINE JONES v. NORMA D. TOTTEN 13. Paragraphs 1 through 12 of Plaintiff's Complaint are incorporated herein by reference and made a part hereof as if set forth in full. 3 14. The aforesaid collision was a direct and proximate result of the negligence of Defendant, NORMA D. TOTTEN, in operating the 2002 Ford Bus in a careless, reckless and negligent manner as follows: (a) Failing to stop her vehicle at the point nearest the intersecting roadway where he/she had a clear view of approaching traffic on that intersecting roadway before entering it in violation of Section 3323 (b) of The PA Motor Vehicle Code; (b) Failing to yield the right-of-way to another vehicle in the intersection in violation of Section 3323 (b) of The PA Motor Vehicle Code; (c) In failing to observe Plaintiff's vehicle on the highway; (d) In failing to operate the vehicle in accordance with existing traffic conditions and traffic controls; (e) In failing to exercise the high degree of care required of a motorist entering an intersection; (f) In failing to properly observe traffic signals controlling Defendant's direction of travel; (g) In failing to keep a reasonable look-out for other vehicles lawfully on the road; (h) In attempting to enter an intersection when such movement could not be safely accomplished; (i) In failing to yield the right-of-way to traffic already upon the highway; Q) In failing to have the vehicle under proper and adequate control; (k) In otherwise operating said vehicle in careless, reckless and negligent manner and in a manner violating the Motor Vehicle Code of the Commonwealth of Pennsylvania 15. The aforesaid incident was caused solely and exclusively by the wrongful and liability producing conduct of the Defendant, NORMA D. TOTTEN, as set forth above and was due in no manner whatsoever to any act or failure to act on the part of the Plaintiff, DARRAINE JONES. WHEREFORE, Plaintiff, DARRAINE JONES, demands judgment against the Defendant, NORMA D. TOTTEN, for compensatory damages in an amount in excess of the amount requiring compulsory arbitration. COUNT II DARRAINE JONES v. CUMBERLAND-DAUPHIN-HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT 16. Paragraphs 1 through 10 of Plaintiff's Complaint are incorporated herein by reference and made a part hereof as if set forth in full. 17. The aforesaid collision was a direct and proximate result of the negligence of Defendant, CUMBERLAND-DAUPHIN-HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, acting through its agent, servant, and/or employee, Norma D. Totten, individually, in operating the 2002 Ford Bus in a careless, reckless and negligent manner as follows: (a) Failing to stop her vehicle at the point nearest the intersecting roadway where he/she had a clear view of approaching traffic on that intersecting roadway before entering it in violation of Section 3323 (b) of The PA Motor Vehicle Code; (b) Failing to yield the right-of-way to another vehicle in the intersection in violation of Section 3323 (b) of The PA Motor Vehicle Code; (c) In failing to observe Plaintiff's vehicle on the highway; (d) In failing to operate the vehicle in accordance with existing traffic conditions and traffic controls; (e) In failing to exercise the high degree of care required of a motorist entering an intersection; 5 (f) In failing to properly observe traffic signals controlling Defendant's direction of travel; (g) In failing to keep a reasonable look-out for other vehicles lawfully on the road; (h) In attempting to enter an intersection when such movement could not be safely accomplished; (i) In failing to yield the right-of-way to traffic already upon the highway; Q) In failing to have the vehicle under proper and adequate control; (k) In otherwise operating said vehicle in careless, reckless and negligent manner and in a manner violating the Motor Vehicle Code of the Commonwealth of Pennsylvania 18. The aforesaid incident was caused solely and exclusively by the wrongful and liability producing conduct of the Defendant, CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, acting through its agent, servant, and/or employee, Norma D. Totten, individually, as set forth above and was due in no manner whatsoever to any act or failure to act on the part of the Plaintiff, DARRAINE JONES. WHEREFORE, Plaintiff, DARRAINE JONES, demands judgment against the Defendant, CUMBERLAND-DAUPHIN-HARRISBURG TRANSIT AUTHORITY, t/d/b/a s CAPITAL AREA TRANSIT, acting through its agent, servant:, and/or employee, Norma D. Totten, individually, for compensatory damages in an amount in excess of the amount requiring compulsory arbitration. COUNT III DARRAINE JONES v. CUMBERLAND-DAUPHIN-HARRISBURG AREA TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT 19. Paragraphs 1 through 18 of Plaintiff's Complaint are incorporated herein by reference and made a part hereof as if set forth in full. 20. The aforesaid collision is the direct and proximate result of the Defendant, CUMBERLAND-DAUPHIN-HARRISBURG AREA TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, in allowing the Defendant, NORMA D. TOTTEN, to operate the 2002 Ford Bus by: (a) entrusting the motor vehicle to the Defendant, NORMA D. TOTTEN, when it knew or should have known that Defendant, NORMA D. TOTTEN, was incapable of operating the motor vehicle in a safe and lawful manner; (b) entrusting the motor vehicle to the Defendant, NORMA D. TOTTEN, when it knew or should have known that the Defendant, NORMA D. TOTTEN, was an incompetent and unsafe driver; (c) entrusting the motor vehicle to the Defendant, NORMA D. TOTTEN, when it knew or should have known that the Defendant, NORMA D. TOTTEN, would likely operate the vehicle in such a manner as to create an unreasonable risk of harm to other drivers on the roadway. WHEREFORE, Plaintiff, DARRAINE JONES, demands judgment against the Defendant, CUMBERLAND-DAUPHIN-HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, for compensatory damages in an amount in excess of the amount requiring compulsory arbitration. Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP By: arl J Januzzi, Esquire Attor ey I. D. No. 65575 2225 Millennium Way Enola, PA 17025 717-728-3200 Dated: December, 2005 VERIFICATION I, Darraine Jones , hereby acknowledge that I am a Plaintiff in this action and that I have read the Corrpl a i nt and that the facts stated herein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: 12/20/05 GAGLOBAMPDATAIDOMINITIAL CONSULT DOCS (SET-UPS)IVerifica6on.wpd 8111111111111 i 1u1111, 111 all 111111181111111 • I.I. lot 34W • Illllilllt, It 0111-1341 1101111-8111 • ill (1111134.3411 ?o G ? T w a 1\ ? fl lJ t ? ; n r,5 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff DARRAINE JONES, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. CUMBERLAND-DAUPHIN-HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, and NORMA TOTTEN, Defendants To the Prothonotary: NO. 05-6738 CIVIL ACTION - LAW JURY TRIAL DEMANDED Please reinstate the Complaint against the Defendant Norma Totten. Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP By: Januzzi, Esquire Dated: January 25, 2006 c> ?- ?: .? ,.r ??=' ?, ? ?? ? fib ?_ Y c??_. "l. , ?"?' " "`r ? _ 1 1 , ; ? x 7 . ] 5 ?: :G t ' J SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2005-06738 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JONES DARRAINE VS CUMB-DAUPHIN-HBG TRANSIT AUTHO 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: CUMBER-DAUPHIN-HBURG TRANSIT AUTH TDBA CAPITAL AREA TRANSIT but was unable to locate Them deputized the sheriff of DAUPHIN in his bailiwick. He therefore serve the within COMPLAINT & NOTICE County, Pennsylvania, to On January 18th , 2006 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: So answers: Docketing 18.00 Out of County 9.00 -? - ! Surcharge 10.00 R. Thomas Kline Dep Dauphin County 41.25 Sheriff of Cumberland County Postage 5.06 83.31 01/18/2006 SHOLLENBERGER & JANUZZI Sworn and subscribed to before me this a?`J? day oil A.D. P nota SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2005-06738 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JONES DARRAINE VS CUMB-DAUPHIN-HBG TRANSIT AUTHO 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: TOTTEN NORMA but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT & NOTICE On January 18th , 2006 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge .00 16.00 01/18/2006 SHOLLENBERGER & JANUZZI So answers: 6.00 .00??' 10.00 R. Thomas Kline .00 Sheriff of Cumberland County Sworn and subscribed to before me x, this )ki day o Proth ary In The Court of Common Pleas of Cumberland County, Penlasylva>nia Darraine Jones vs. Cumberland Dauphin Harrisburg Transit Authority t/d/b/a Capital Area Transit et al SERVE: same No. 05-6738 civil Now, December 28, 2005 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin deputation being made at the request and risk of the Plaintiff. County to execute this Writ, this Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to a and made known to So answers, the contents thereof. Sheriff of Sworn and subscribed before me this _ day of 20 copy of the original COSTS SERVICE _ MILEAGE _ AFFIDAVIT County, PA 20_, at o'clock M. served the m iftcQ of p ,,"i Pxrff Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania . JONES DARRAINE vs County of Dauphin CUMBERLAND DAUPHIN HARRISUBRG TRANSIT Sheriff's Return No. 2189-T - - -2005 OTHER COUNTY NO. 05-6738 CIVIL TERM AND NOW:December 30, 2005 at 11:20AM served the within NOTICE/COMPLAINT REQUEST FOR PROD/INTERR upon CUMBERLAND DAUPHIN HARRISUBRG TRANSIT by personally handing AUTHORITY T/D/B/A CAPITAL AREA TRANSIT to LESTER ALBRIGHT, MANAGER 1 true attested copy(ies) of the original NOTICE/COMPLAINT REQUEST FOR PROD/INTERR and making known to him/her the contents thereof at 901 NORTH CAMERON ST HARRISBURG, PA 17105-0000 Sworn and subscribed to before me this 10TH day of JANUARY, 2006 NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County My Commission Expires Sept. 1, 2006 So Answers, lel??°1c- Sheriff of Dauphin County, Pa. BY €l` y Deputy Sheriff Sheriff's Costs:$41.25 PD 12/29/2005 RCPT NO 213309 TQ In The Court of Common Pleas of Cumberland County, Penaisylvariia Darraine Jones VS. Cumberland Dauphin Harrisburg Transit Authority t/d/b/a Capital Area Transit et al No. 05-6738 civil SERVE: Norma Totten Now, December 28. 2005 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to a and made known to So answers, Sheriff of Sworn and subscribed before me this - day of 120 20 at o'clock M. served the copy of the original COSTS SERVICE MILEAGE AFFIDAVIT the contents thereof. County, PA mma, of t4le o 4pxtff Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania . JONES DARRAINE Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy vs County of Dauphin CUMBERLAND DAUPHIN HARRISUBRG TRANSIT Sheriff's Return No. 2189-T - - -2005 OTHER COUNTY NO. 05-6738 CIVIL TERM I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for TOTTEN NORMA the DEFENDANT named in the within NOTICE/COMPLAINT REQUEST FOR PROD/INTERR and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, January 5, 2006 AS PER JESSICA ZERBE, RESIDENT. DEFENDANT HAS NOT LIVED AT ADDRESS FOR TWO YEARS. Sworn and subscribed to before me this 10TH day of JANUARY, 2006 lam/ NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County My Commission Expires Sept I, 2006 So Answers, e;l*? Sheriff of Dauphin County, Pa. By Deputy Sheriff Sheriff's Costs:$41.25 PD 12/29/2005 RCPT NO 213309 SS c 1 SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2005-06738 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JONES DARRAINE VS CUMB-DAUPHIN-HBG TRANSIT AUTHO 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: TOTTEN NORMA but was unable to locate Her in his bailiwick He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT & NOTICE On February 8th , 2006 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: So answers Docketing 18.00 Out of County 9.00 Surcharge 10.00 R. Thomas Kline Dep Dauphin County 31.25 Sheriff of Cumber and County Postage 2.94 71.19 02/08/2006 SHOLLENBERGER & JANUZZI Sworn and subscribed to before me this 1_5 day of l ?? Z-trO4 D. Pro otar In The Court of Common Pleas of Cumberland County, Pennsylvania Darraine Jones vs. Cumberland Dauphin Harrisburg Transit Auwority et al 05-6738 civil SERVE: Norma Totten Now, January 30, 2006 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to a and made known to copy of the original So answers, the contents thereof. Sheriff of Sworn and subscribed before me this day of 20 20 , at o'clock M. served the COSTS SERVICE _ MILEAGE _ AFFIDAVIT County, PA (o f f ir,e of e c*hrriff Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin JONES DARRAINE TOTTEN NORMA Sheriff's Return vs No. 0177-T - - -2006 OTHER COUNTY NO. 05-6738 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy AND NOW:February 2, 2006 at 11:34AM served the within REINSTATED COMPLAINT,INTERR & REQUEST upon TOTTEN NORMA by personally handing to NORMA TOTTEN DEFT 1 true attested copy(ies) of the original REINSTATED COMPLAINT,INTERR & REQUEST and making known to him/her the contents thereof at 519 SOUTH FRONT ST STEELTON, PA 17113-0000 Sworn and subscribed to before me this 2ND day of FEBRUARY, 2006 So Answers, +y?? Sheriff of Dauphin County, Pa. NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County My Commission Expires Sept. 1, 2006 By \\c rJ1MxW Deputy Sheriff Sheriff's Costs:$31.25 PD 01/31/2006 RCPT NO 214325 JS RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No.: 67353 By: Jeffrey C. Mickletz Identification No.: 87531 25 North Front Street, First Floor Harrisburg, Pennsylvania 17101 (717) 234-7700 DARRAINE JONE Plaintiff, vs. CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, and NORMA TOTTEN Defendants. Attorneys for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a Capital Area Transit and Norma Totten COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO: 2005-6738 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter our appearance on behalf of defendants, Cumberland-Dauphin- Harrisburg Transit Authority, t/d/b/a Capital Area Transit, and Norma Totten in the above referenced matter. RA WLE . Stewart, Esquire C. Mickletz, Esquire ys for Defendants, Dater 2A 10(4 Harrisburg Transit Authority, t/d/b/a Capital Area Transit and Norma Totten 1308170 v.I CERTIFICATE OF SERVICE I hereby certify that on today's date, a true and correct copy of the foregoing Entry of Appearance was served by first-class mail, postage prepaid, upon all attorneys of record, addressed as follows: Karl A. Januzzi SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 RAWLE & HENDERSON LLP By: tewart, Esquire Mickletz, Esquire for Defendants, H* i*urg Transit Authority, t/d/b/a Capital Area Transit and Norma Totten Date: 51 24 I C) (0 1308170 v.1 o n. cn T y7 i rQ ? - W RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No.: 67353 By: Jeffrey C. Mickletz Identification No.: 87531 25 North Front Street, First Floor Harrisburg, Pennsylvania 17101 (717) 234-7700 DARRAINE JONES vs. Plaintiff, CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, and NORMA TOTTEN Defendants. Attorneys for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a Capital Area Transit and Norma Totten COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO: 2005-6738 PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached verification of Norma Totten for the verification of counsel to defendants' Answer with New Matter to the Plaintiffs' Complaint, which was previously filed with the Court. o....-? l 7 i D 6 RA WLE & H SON, LLP By: Gary N. Stewart, Esquire Jeffrey C. Mickletz, Esquire Attorneys for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a Capital Area Transit and Norma Totten 1324149 v.l 1 CERTIFICATE OF SERVICE I hereby certify that on today's date, a true and correct copy of the foregoing Praecipe to Substitute Verification was served via first class U.S. mail, postage pre-paid, upon the following: Karl A. Januzzi SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 RAWLE & SON LLP By. Gary N. Stewart, Esquire Jeffrey C. Mickletz, Esquire Attorneys for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a Capital Area Transit and Norma Totten Date: 1324149 v.I 07/03/20FI-5 14:30 7172326973 CAT SHARE,A RIDE PAGE 04 VERIFICATION Norma Totten, hereby states that she is a named defendant. She verifies that she has read the within Answer with New Matter to Plaintiff's Complaint and that it is true and correct to the best of her knowledge, information and belief. She understands that the statements set forth in said answer are made subject to the penalties of 18 Pa. Cons. Stat. Ann. §4904 relating to unsworn falsification to authorities. No a Totten Date:: 1311694 v,I r ? • RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No.: 67353 By: Jeffrey C. Mickletz Identification No.: 87531 25 North Front Street, First Floor Attorneys for Defendants, Harrisburg, Pennsylvania 17101 Cumberland-Dauphin-Harrisburg (717) 234-7700 Transit Authority, t/d/b/a Capital Area Transit and Norma Totten DARRAINE JONES COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY VS. NO: 2005-6738 CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, and NORMA TOTTEN Defendants. PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached verification of Perpetua Njuguna for the verification of counsel to defendants' Answer with New Matter to the Plaintiffs' Complaint, which was previously filed with the Court. Date: -)1 -21 C, RAWLE & HE SON, LLP By: ary N. Stewart, Esquire Jeffrey C. Mickletz, Esquire Attorneys for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a Capital Area Transit and Norma Totten 1324142 v.I „A CERTIFICATE OF SERVICE I hereby certify that on today's date, a true and correct copy of the foregoing Praecipe to Substitute Verification was served via first class U.S. mail, postage pre-paid, upon the following: Karl A. Januzzi SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 RAWLE & H SON LLP By: ary N. Stewart, Esquire Jeffrey C. Mickletz, Esquire Attorneys for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a Capital Area Transit and Norma Totten Date: ? ? v ? f 1324142 v.I 07/03/2006 14:30 7172326973 CAT SHARE A RIDE PAGE 03 VERIFICATION pF't _c16u1?i.4 ?, hereby states that he is an authorized representative for the defendant Cumberland-Dauphin-Harrisburg Transit Authority d/b/a Capital Area Transit. He verifies that he has read the within Answer with New Matter to Plaintiffs Complaint and that it. is true and correct to the best of his knowledge information and belief. He understands that the statements set forth its said Answers are made subject to the penalties of 18 Pa. Cons. Stat. Ann. § 4904, relating to unsworn falsification to authorities. By: Autho sentati.ve for Capital Area Transit Authority bated: drs p 131 J694 v.I _. .J „ ?y "l" ?? ?f 1 ,' i e -"? To Plaintiff: You are hereby notified to file a written response to the new matter and new matter within twenty (20) days from service hereof or a judgment may be entered against you. RAWLE & HENDERS 97-) By: Stewart, squire RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No.: 67353 By: Jeffrey C. Mickletz Identification No.: 87531 25 North Front Street, First Floor Harrisburg, Pennsylvania 17101 (717) 234-7700 DARRAINE JONES vs. Plaintiff, CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, and NORMA TOTTEN Defendants. Attorneys for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a Capital Area Transit and Norma Totten COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO: 2005-6738 DEFENDANTS CUMBERLAND-DAUPHIN-HARRISBURG TRANSIT AUTHORITY t/b/d/a CAPITAL AREA TRANSIT AND NORMA TOTTEN'S ANSWER WITH NEW MATTER TO PLAINTIFF'S COMPLAINT Defendants, Cumberland-Dauphin-Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten, hereby answer and assert new matter to plaintiff's complaint by and through their attorneys, Rawle & Henderson LLP, upon information and belief as follows. 1311694 v.I I . Admitted in part, denied in part. It is admitted only that Darraine Jones is an adult individual. Defendants have insufficient information or knowledge upon which to form a belief. 2. Admitted. 3. Admitted in part, denied in part. Defendant admits that it is a duly organized transit authority with a business address of 901 North Cameron Street, Harrisburg, Pennsylvania 17105 and is a governmental unit. The remaining averments of paragraph 3 of the complaint contain conclusions of law to which no responsive pleadings are required, and therefore, said averments are denied. 4. Admitted in part, denied in part. Admitted defendant Norma Totten was operating a 2002 Ford Bus. The remaining averments contained in paragraph 4 contain conclusions of law to which no responsive pleading is required and, to the extent that they are deemed otherwise, they are denied. 5. Admitted upon information and belief. 6. Denied. Defendants have insufficient knowledge upon which to form a belief. 7(a-f). Denied. Defendants have insufficient knowledge upon which to form a belief. 8. Denied. Defendants have insufficient knowledge upon which to form a belief. The averments contained in paragraph 8 contain conclusions of law to which no responsive pleading is required and, to the extent that they are deemed otherwise, they are denied. 9. Denied. Defendants have insufficient knowledge upon which to form a belief. 10. Denied. Defendants have insufficient knowledge upon which to form a belief. 11. Denied. Defendants have insufficient knowledge upon which to form a belief. 1311694 v.l 12. Denied. The averments contained in paragraph 12 contain conclusions of law to which no responsive pleading is required and, to the extent that they are deemed otherwise, they are denied. COUNTI DARRAINE JONES v. NORMA TOTTEN 13. Defendants Cumberland-Dauphin-Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten hereby incorporate paragraphs 1 through 12 of the answer as if they were set forth herein at length. 14(a-k). Denied. The averments contained in paragraph 14 contain conclusions of law to which no responsive pleading is required and, to the extent that they are deemed otherwise, they are denied. 15. Denied. The averments contained in paragraph 15 contain conclusions of law to which no responsive pleading is required and, to the extent that they are deemed otherwise, they are denied. WHEREFORE, defendants, Cumberland-Dauphin-Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten, respectfully request that this Honorable Court dismiss plaintiff's complaint with prejudice, deny the relief requested therein, grant judgment in favor of defendants Cumberland-Dauphin-Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten and against the plaintiff, and grant such other and further relief as this Honorable Court deems just and proper. 1311694 v.l COUNT II DARRAINE JONES v.-CUMBERLAND-DAUPHIN-HARRISBURG TRANSIT AUTHORITY t/b/d/a CAPITAL AREA TRANSIT 16. Defendants Cumberland-Dauphin-Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten hereby incorporate paragraphs 1 through 15 of the answer as if they were set forth herein at length. 17(a-k). Denied. The averments contained in paragraph 17 contain conclusions of law to which no responsive pleading is required and, to the extent that they are deemed otherwise, they are denied. 18. Denied. The averments contained in paragraph 18 contain conclusions of law to which no responsive pleading is required and, to the extent that they are deemed otherwise, they are denied. WHEREFORE, defendants, Cumberland-Dauphin-Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten, respectfully request that this Honorable Court dismiss plaintiff's complaint with prejudice, deny the relief requested therein, grant judgment in favor of defendants Cumberland-Dauphin-Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten and against the plaintiff, and grant such other and further relief as this Honorable Court deems just and proper. COUNT III DARRAINE JONES v. CUMBERLAND-DAUPHIN-HARRISBURG TRANSIT AUTHORITY t/b/d/a CAPITAL AREA TRANSIT 19. Defendants Cumberland-Dauphin-Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten hereby incorporate paragraphs 1 through 19 of the answer as if they were set forth herein at length. 1311694 v.l 20(a-c). Denied. The averments contained in paragraph 20 contain conclusions of law to which no responsive pleading is required and, to the extent that they are deemed otherwise, they are denied. WHEREFORE, defendants, Cumberland-Dauphin-Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten, respectfully request that this Honorable Court dismiss plaintiff's complaint with prejudice, deny the relief requested therein, grant judgment in favor of defendants Cumberland-Dauphin-Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten and against the plaintiff, and grant such other and further relief as this Honorable Court deems just and proper. NEW MATTER 21. Plaintiff fails to state a cause of action upon which relief can be granted. 22. Defendants are immune from liability pursuant to the Pennsylvania Sovereign Immunity Act. 23. Defendants' liability is limited, in whole or in part, pursuant to the Pennsylvania Sovereign Immunity Act. 24. Defendant claims all defenses available to it under the provisions of the Pennsylvania Sovereign Immunity Act. 25. Service of process was improper or insufficient. 26. No admissions or conduct on the part of the defendants contributed to plaintiff's alleged damages, if any. 27. Plaintiff failed to mitigate her alleged damages. 28. The damages complained of by plaintiff pre-existed or are unrelated to the accident which is the subject matter of this complaint. 1311694 v.I 29. Plaintiff's claims are barred by the doctrine of assumption of the risk. 30. The negligence of plaintiff either bar her recovery completely or reduces her claim under the doctrine of comparative negligence. 31. Plaintiff's alleged damages, if any were proximately caused, in whole or in part by the fault of third parties for whom defendant is not legally responsible. WHEREFORE, defendants, Cumberland-Dauphin-Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten, respectfully request that this Honorable Court dismiss plaintiff's complaint with prejudice, deny the relief requested therein, grant judgment in favor of defendants Cumberland-Dauphin-Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten and against the plaintiff, and grant such other and further relief as this Honorable Court deems just and proper. RAWLE & HEIR SAN LLP By: Date: /0 -/ ?/' "'/' ;! ary N. Stewart, Esquire Jeffrey C. Mickletz, Esquire Attorney for Defendants, Cumberland-Dauphin- Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten 1311694 v.I . 07/03/2006 14:30 717232697q CAT SHARE A RIDE VERIFICATION PAGE 03 P? utE AZ 1;ZwA hereby states that he is an authorized representative for the defendant Cumberland-Dauphin-Harrisburg Transit Authority d/b/a Capital Area Transit. He verifies that he has read the within Answer with New Matter to Plaintiff s Complaint and that it. is true and correct to the best of his knowledge information and belief. He understands that the statements set forth in said Answers are made subject to the penalties of 18 Pa. Cons. Stat, Ann. § 4944, relating to unswom falsification to authorities. By; Author presentative for Capital Area Transit Authority Dated; dts p 1311694 v. t 07/03/2006 14:30 7172326 CAT SHARE A RIDE PAGE 04 VERIFICATION Norma Totten, hereby states that she is a named defendant. She verifies that she has read the within Answer with New Matter to Plaintiff's Complaint an.d that it is true and correct to the best of her knowledge, information and belief. She understands that the statements set forth in said answer are made suhiect to the penalties of 18 Pa. Cons. Stat. Ann. §4904 relating to uztsworn falsification to authorities. No a Totten Date: b - 1 g `'O ^ 1111644 vj CERTIFICATE OF SERVICE I hereby certify that on today's date, a true and correct copy of the Answer with New Matter to Plaintiff's Complaint was served by first-class mail, postage prepaid, upon all attorneys of record, addressed as follows: Karl J. Januzzi, Esquire SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Attorney for plaintiff RAWLE & RSON LLP B Jeffrey C. Mickletz, Esquire Attorney for Defendants, Cumberland-Dauphin- Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten Date: Iro- l 1311694 v.I C`7 ? r7 . 77 117 . _ M ._ ? r y qt i y `J v SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff DARRAINE JONES, Plaintiff V. CUMBERLAND-DAUPHIN-HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, and NORMA TOTTEN, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-6738 CIVIL ACTION - LAW JURY TRIAL DEMANDED ANSWER TO NEW MATTER OF DEFENDANT AND NOW, comes the PLAINTIFF, DARRAINE JONES, by and through her attorneys, SHOLLENBERGER & JANUZZI, LLP, and respectfully answers the New Matter of Defendant as follows: 21-31. The allegations set forth in the paragraphs 21-31 of the Defendants' New Matter are conclusions of law which require no responsive pleading. By way of further answer, the allegations set forth in paragraphs 21-31 of the Defendants' New Matter are hereby denied. WHEREFORE, Plaintiff, DARRAINE JONES, respectfully requests Your Honorable Court strike Defendants' New Matter and enter judgment in her favor. Respectfully Submitted, SHOLLEI,BERGFVqR & JANUZZI, LLP Date: 10 (46(b By: Ka J. nuzzi Attorney for Plaintiff I.D. # 65575 SHOLLENBERGR 2225 Millennium W & JANUZZI, LLP Enola, Pennsylvania Way 1 Telephone Number: 7025 Fax Number: (717) 728-3200 for (77) 28-3400 Attorne s V Plaintiff DARRAINE JONES, Plaintiff V. CUMBERLAND-DAUPHIN-HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, and NORMA TOTTEN, Defendants I ?N THE COURT OF CUMBERLAND COUNOTY, PLEAS PENNSYLVANIA NO. 05-6738 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW this 24' day of October , 20061 hereb served Notice of Oral Deposition to the following by depositing a true and correct copy d same in the United States mail, Postage prepaid, addressed to: Jeffrey C. Mikletz, Esq. Rawle & Henderson, LLP 25 N. Front Street, 1 st Floor Harrisburg, PA 17101 Respectfully submitted, SHOLLEQ BERGER & JANUZZI, LLP By: nazzi, Esquire = CD r RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No.: 67353 By: Jeffrey C. Mickletz Identification No.: 87531 25 North Front Street, First Floor Harrisburg, Pennsylvania 17101 (717) 234-7700 Attorneys for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a Capital Area Transit and Norma Totten DARRAINE JONES Plaintiff, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs. CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, and NORMA TOTTEN Defendants NO: 2005-6738 CERTIFICATE PREREQUISITE TO SERVICE OF ADDITIONAL SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoena for documents and things pursuant to Rule 4009.22, Defendants, Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a/ Capital Area Transit and Norma Totten, certify that: 1. A Notice of Intent to Serve subpoenas with a copy of the subpoenas attached hereto 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 objections to the subpoenas have been received. 4. Counsel has waived the twenty (20 day waiting period thereby allowing the subpoenas to be served immediately. A copy of Counsel's waiver is attached. 1388208 v.1 4. The subpoenas which will be served are identical to the subpoenas which are attached to the Notice of Intent to Serve the Subpoena. RAWLE & HE ERSON LLP By/ Gary N. Stewart, Esquire Jeffrey C. Mickletz, Esquire Attorney for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten 1388208 v.I RAWLE &HEN DER SQN LLP wee Law C arc o? O 8 a e0, 4? 9. D 1783 DEBBIE L. STOLTZFUS 717-234-7700 dstoltzfus(c)yrawle.com The Nation's Oldest Law Office - Established in 1783 25 N. FRONT STREET FIRST FLOOR www.rawie.com HARRISBURG, PA 17101 TELEPHONE:(717) 234-7700 FACSIMILE:(717) 234-7710 November 6, 2006 Karl A. Januzzi SHOLLENBERGER & JANUZZI LLP 2225 Millennium Way Enola, PA 17025 Re: Darraine Jones v. Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a Capital Area Transit, and Norma Totten Cumberland County CCP No.: 05-6738 Our File No.: 250186 Dear Mr. Januzzi: Enclosed please find Defendant's Notice of Intent to Serve Subpoenas in the above captioned matter. Pursuant to Pennsylvania Rules of Civil Procedure, Rule 4009.2 1, you have twenty (20) days within which to file objections to these subpoenas. If no objections are received, the subpoenas will then be served. In the event you are agreeable to waiving the twenty (20) day waiting period, please sign the enclosed copy of this letter and return it to me in the envelope I have provided. Thank you for your cooperation and immediate attention to this matter. Very truly yours, RAWLE & HENDERSON LLP By ,? - 1 -6/ 4p?a? Debbie L. Stoltzfus DLS/ I hereby agree to waive the twenty (20) day waiting-period and are in agreement that the subpoenas may be served immediately. Dated: $ (9 1382011 v.1 PHILADELPHIA, PA PITTSBURGH, PA HARRISBURG, PA MEDIA, PA MARLTON, NJ NEW YORK, NY WILMINGTON, DE WHEELING, WV Nov 0 8 2006 RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No.: 67353 By: Jeffrey C. Mickletz Identification No.: 87531 25 North Front Street, First Floor Harrisburg, Pennsylvania 17101 (717) 234-7700 Attorneys for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a Capital Area Transit and Norma Totten DARRAINE JONES vs. CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, and NORMA TOTTEN Defendants NO: 2005-6738 NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendants, CUMBERLAND-DAUPHIN-HARRISBURG TRANSIT AUTHORITY, t/d/b/a/ CAPITAL AREA TRANSIT AND NORMA TOTTEN, intends to serve subpoenas identical to the ones that are 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 any objections you may have to the subpoenas. If no objections are made, the subpoenas may be served. RAWLE & HENDERSON LLP By: - dXV1 ary N. Stewart, Esquire Jeffrey C. Mickletz, Esquire Attorney for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY 1381951 v.1 COMMON WFALTI-l OF PI3NNSYl.VANIA COUNTY OF CUMBERLAND DARRATNE JONES VS. bile No. 2005-673 CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITYt/d/b/aCAPITAL AREA TRANSIT et al SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: HOLY SPIRIT HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON, 25 N. Front St., Harrisburg, PA 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Gary N. Stewart, Esquire ADDRESS: . F ron ree arris urg, TELEPHONE: 7 17-2 3 -7700 SUPRLME COURT ID 7 55 3 ATTORNEY FOR: Defendants Dater Q?Cm Scal of tile C'Nirt BY THE OURT: P •otilonotar vtl D' ision Deputy RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: Darraine Jones, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1363731 v.1 CERTIFICATE OF AUTHENTICITY FROM: HOLY SPIRIT HOSPITAL RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Title Print Name Date 1363731 v.l COMMONWEALTH Or 1'l?.NNSY1A/ANIA COUNTY O CUMBERLANi DARRAINE JONES VS. [pile No. 2005-673.8 _ CUMBERLAND-DAUPHIN- HARRISBURG ' TRANSI-T AUTHORITYt/d/b/aCAPITAL AREA TRANSIT et al SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO:DR. NITA RASTOGI (Name of Person or Entity) Within twenty (20) days after set-vice of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON, 25 N. Front St., Harrisburg, PA 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Gary N. Stewart, Esquire ADDRESS: 2? N. ron ree Harrisburg-,-PA TELEPHONE: 717-234-7700 SUPREME COURT ID 9 -67353 ATTORNEY FOR: Defendants Date:_x0d . Q Seal of the ,ourt BY THE?OURT: 'rotl o tally lull vision Deputy RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: Darraine Jones, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1363731 v.1 CERTIFICATE OF AUTHENTICITY FROM: DR. NITA RASTOGI RE: DARRAINE JONES DOB: 1/12160 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Print Name Title Date 13631,31 v.) COMMONWEAL;I'I I of llf"NNSYLVANIA COUNTY OF, CUN/ll3ERI,AND DARRAINE JONES VS. File No. _2000=6738 CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITYt/d/b%aCAPITAL AREA TRANSIT et al SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: PHYSIOTHERAPY ASSOCIATES (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON, 25 N. Front St., Harrisburg, PA 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Gary N. Stewart, Esquire ADDRESS: • ? ron ree Harrisburg, 1 TELEPHONE: 717-234-7700 SUPREME COURT ID # 7353 ATTORNEY FOR: Defendants Date:_ ou „ Scal of t_ he Court BY THE URT: rothonotary, Ci ivi on Deptity RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: Darraine Jones, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1363731 v.1 CERTIFICATE OF AUTHENTICITY FROM: PHYSIOTHERAPY ASSOCIATES RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Print Name Title Date 1363731 v.] COMMONV/1,,ALTH Oh PBNNSYLVANIA COUP! I'1' OF CUMBERLAND DARRAINE JONES VS , File No, 2005-67 3B CUMBERLAND--DAUPHIN- HARRISBURG 'TRANSI-T AUTHORITYt/d/b/aCAPITAL AREA TRANSIT et a1. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO; TRISTAN ASSOCIATES (Name of Person or Entity) Within twenty (20) clays after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON, 25 N. Front St., Harrisburg, PA 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party malting 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: Gary N. Stewart, Esquire ADDRESS: ron ree Harrisburg, PA 1710 TELEPHONE: 717-234-7700 SUPREME COURT ID # 67353 ATTORNEYFOR: Defendants Date:-4F .?--?° Seal of the Court 7 BY THE OURT: I /I I'ot'l751' ?Vil DI ISiOn Deptity RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: Darraine Jones, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1363731 v 1 CERTIFICATE OF AUTHENTICITY FROM: TRISTAN ASSOCIATES RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Title Print Name Date 1363731 v.1 COMMONWEAf,T1-I OF PF?NNSYI,VANIA COUN"IN 0l_, CUMI3GRLAND DARRAINE JONES VS. CUMBERLAND-DAUPHIN- Fife No. 2005--6 HARRISBURG TRANSIT AUTHORITYt/d/b%aCAPITAL AREA TRANSIT'et al SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: COMMUNITY IMAGING ASSOCIATES (Name of Person or Entity) Within twenty (20) clays after service of this subpoena, you are ordered by the court to produce the following docwnents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON, 25 N. Front St., Harrisburg, PA 17101 (Address) You may deliver or snail 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: Gary N. Stewart, Esquire ADDRESS: L15 N. ron ree arris urg, 1 TELEPHONE: 7 17-2 34-7700 SUPREME COURT ID It 67353 ATTORNEY FOR: Defendants Date:- AV? _?Q(, Seal of [fie Court BY THE 4CRT: Pc tlionotary ivisi n Deputy RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: Darraine Jones, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1363731 v.l CERTIFICATE OF AUTHENTICITY FROM: COMMUNITY IMAGING ASSOCIATES RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Print Name Title Date 1363731 v.1 CnMMONWL,,AI_TI-I OI' l'I?NNSYLVAN[A COUNTY OFCUM>3TRLAND DARRAINE JONES VS. CUMBERLAND-DAUPHIN- 1{ile No. 2005-67 38 HARRISBURG'. TRANSIT AUTHORITYt/d/b/aCAPITAL AREA TRANSIT'et al SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: STUART HARTMAN, 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 ADDENDUM atRAWLE & HENDERSON, 25 N. Front St., Harrisburg, PA 17101 (Address) You may deliver or trail 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: Gary N. Stewart, Esquire ADDRESS: 2? N. ron ree Harrisburg, PA 1'( 10 1 TELEPHONE: 717-2 34-7700 SUPREME COURT ID # 67353 ATTORNEYFOR: Defendants Date:_ ? - q Seal of the C 6111-t BY THE CART: Pro -tonotary, ivisio - Deputy RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: Darraine Jones, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1363731 v.1 CERTIFICATE OF AUTHENTICITY FROM: STUART HARTMAN, MD RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 am the Custodian of Records for the above-named deponent. hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Title Print Name Date 1363731 v.1 COMMON Wi-;A[ATI OF ['1=,'?NNSYLVANIA COUNTY 01 CUMR1=sR1_,AND DARRAINE JONES VS. CUMBERLAND-DAUPHIN- File No. 2005-67 3S HARRISBURG ' TRANSIT AUTHORITYt/d/b/aCAPITAL AREA TRANSIT'et al SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: STEVEN MORGANSTEIN, 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 ADDENDUM atRAWLE & HENDERSON, 25 N. Front St., Harrisburg, PA 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the riglit 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: Gary N. Stewart, Esquire ADDRESS: 2? N- ron ree Harrisburg, FA 1710 TELEPHONE: 717-234-7700 SUPREME COURT ID It 7353 ATTORNEYFOR: Defendants Date:??__g Seal of the C4?urt BY THE C RT: Pro lonotary, ivisr0t1 Deputy RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: Darraine Jones, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1363731 v.1 CERTIFICATE OF AUTHENTICITY FROM: STEVEN MORGANSTEIN, MD RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Print Name Title Date 1363731 v.1 COMMON WI OF PI?NNSYLVANIA COUNTY OF CUMBI,.i 1,AND DARRAINE JONES vs. CUMBERLAND-DAUPHIN- File No. 2005-6738 HARRISBURG 'TRANSIT AUTHORITYt/d/b/aCAPITAL AREA TRANSIT et- al SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: DR. J. MARK BATTIN, MD (Name of Person or Entity) Within twenty (20) clays after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON, 25 N. Front St., Harrisburg, PA 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Gary N. Stewart, Esquire ADDRESS: 2? A- ron Street Harrisburg, 1 TELEPHONE: 71-7-234-7700 SUPREME COURT ID # 67353 ATTORNEYFOR: Defendants Dater ?`Ulm Seal of the t'ourt BY THE C RT: Pr tltonotar v I Divi 'on Ueputy RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: Darraine Jones, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1363731 v.1 CERTIFICATE OF AUTHENTICITY FROM: DR. J.MARK BATTIN, MD RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Print Name Title Date 1363731 v.1 COMMNWEAL`I'lI 0FPl?NNSY1A/ANIA C :Oi 1NTY 01 CUMBERLAND DARRAINE JONES VS. File No. 2005-6738 CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITYt/d/b/aCAPITAL AREA TRANSIT'et al SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: HEALTHSOUTH/WORK PERFECT (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON, 25 N. Front St., Harrisburg, PA 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Gary N. Stewart, Esquire ADDRESS: ron Street Harris ur,, 1 TELEPHONE: 717-23 -7700 SUPREME COURT ID /1 7353 ATTORNEYFOR: Defendants ?_ Date: Seal of the Court BY THE QURT: P othonotar v ivis' n Depu(y RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: Darraine Jones, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1363731 vA CERTIFICATE OF AUTHENTICITY FROM: HEALTHSOUTHMORK PERFECT RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Print Name Title Date 1363731 v.1 COMM()N W EALTI 1 0 111=NNSYLVA1\1 IA C()I J NTY 0 CUMBERLAND DARRAINE JONES VS. CUMBERLAND-DAUPHIN- HARRISBURG TRANSI-T File No. 2005-6738 AUTHORITYt/d/b/aCAPITAL AREA TRANSIT'et al SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: BALINT BALOG, MD (Name of Person or Entity) Within twenty (20) clays after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON, 25 N. Front St., Harrisburg, PA 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Gary N. Stewart, Esquire ADDRESS: Front ree Harrisburg, PA - 1 TELEPHONE: 717-234-7700 SUPREME COURT ID # 7353 ATTORNEYFOR: Defendants Date:_aVW'_4ac'Np(c?. Seal of the Court BY TI-IE C RT: Pr thonotary, ivis' n - - Delw(y RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: Darraine Jones, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1363731 v.1 CERTIFICATE OF AUTHENTICITY FROM: BALINT BALOG, MD RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. i further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Print Name Title Date 1363731 v.1 COMMON WCALTII OFPENNSYLVANIA COUN'T'Y OF CUMBERLAND DARRAINE JONES VS. File No. 2005-673_U_ _ CUMBERLAND-DAUPHIN- HARRISBURG'TRANSIT AUTHORITYt/d/b/aCAPITAL AREA TRANSIT et al SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: ABINGTON ORTHOPEDIC SPECIALITY CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON, 25 N. Front St., Harrisburg, PA 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Gary N. Stewart, Esquire ADDRESS: Front ree Harrisburg, 1 TELEPHONE: 717-234-7700 SUPREME COURT ID # 67353 ATTORNEYFOR: Defendants Date:-,A)l -2o6(. Scat ofthe l oust BY THaEU RT: P othonotary o 4ivis' Deput y RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: Darraine Jones, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1363731 v.1 CERTIFICATE OF AUTHENTICITY FROM: ABINGTON ORTHOPAEDIC SPECIALITY CENTER RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Print Name Title Date 1363731 v.I C0ivlN/10NW[?AI.Tl-I01? PF-_,'NNSYLVANIA COUN'T'Y O1, CUMBERLAND DARRAINE JONES vs. File No. 2005-6735 CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITYt/d/b/aCAPITAL AREA TRANSIT 'et- al. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: DR. DUKKIPATI (Name of Person or Entity) Within twenty (20) clays after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON, 25 N. Front St., Harrisburg, PA 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Gary N. Stewart, Esquire ADDRESS: 25 ron Street arras urg, 1 TELEPHONE: 717-234-7700 SUPREME COURT ID fE 67353 ATTORNEYFOR: Defendants Date:_`????--_ ? b Seal of the Lout t BY THE C RT. Pr ionotary, ivis' n Deputy t • RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: Darraine Jones, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1363731 v_1 V CERTIFICATE OF AUTHENTICITY FROM: DR. DUKKIPATI RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Print Name Title Date 1363731 v.I COMMONM/FA1.7I'Il OF PENNSYLVANIA COUNTY OF ('UMI311RLAND DARRAINE JONES VS. bile No._ 2005-67 38 TO: CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITYt/d/b/aCAPITAL, AREA TRANSIT'et al SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 DR. PETER PAHAPILL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON, 25 N. Front St., Harrisburg, PA 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Gary N. Stewart, Esquire ADDRESS: ron ree aryls urg, 1 TELEPHONE: 717-234-7700 SUPREME COURT ID # 7353 ATTORNEY FOR: Defendants Dale:_??ry). _ Seal of the Cdurt BY THE C RT: Pr thonotalivi1 -- Deputy RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: Darraine Jones, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1363731 v.1 . % CERTIFICATE OF AUTHENTICITY FROM: DR. PETER PAHAPILL RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Title Print Name Date 1363731 v.1 r 4 M CERTIFICATE OF SERVICE I hereby certify that on today's date I served a true and correct copy of the foregoing Notice of Intent to Serve Subpoenas, by first-class mail, postage prepaid, upon all attorneys of record, addressed as follows: Karl J. Januzzi, Esquire SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Attorney for plaintiff RAWLE & HENDE SON LLP By: Gary N. Stewart, Esquire Attorney for Defendants, Gary N. Stewart, Esquire Jeffrey C. Mickletz, Esquire Attorney for Defendants, Cumberland-Dauphin- Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten Date: / 11610 6 1381951 v.l RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No.: 67353 By: Jeffrey C. Mickletz Identification No.: 87531 240 N. Third Street, Ninth Floor Harrisburg, Pennsylvania 17101 (717) 234-7700 Attorneys for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a Capital Area Transit and Norma Totten DARRAINE JONES Plaintiff, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs. CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, and NORMA TOTTEN Defendants NO: 2005-6738 CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoena for documents and things pursuant to Rule 4009.22, Defendants, Karen Love and Capital Area Transit (CAT), certify that: 1. A Notice of Intent to Serve subpoenas with a copy of the subpoenas attached hereto 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 objections to the subpoenas has been received. 2005058-1 DSTOLTZFUS RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No.: 67353 By: Jeffrey C. Mickletz Identification No.: 87531 25 North Front Street, First Floor Harrisburg, Pennsylvania 17101 (717) 234-7700 NO: 2005-6738 DARRAINE JONES VS. CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, and NORMA TOTTEN Defendants NOTICE OF INTENT TO SERVE ADDITIONAL SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendants, CUMBERLAND-DAUPHIN-HARRISBURG TRANSIT AUTHORITY, t/d/b/a/ CAPITAL AREA TRANSIT AND NORMA TOTTEN, intends to serve subpoenas identical to the ones that are 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 any objections you may have to the subpoenas. If no objections are made, the subpoenas may be served. RAWLE & By: COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY Attorneys for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a Capital Area Transit and Norma Totten ON LLP Gary N. Stewart, Esquire Jeffrey C. Mickletz, Esquire Attorney for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten 1406435 v.1 CERTIFICATE OF SERVICE I hereby certify that on today's date I served a true and correct copy of the foregoing Notice of Intent to Serve Subpoenas, by first-class mail, postage prepaid, upon all attorneys of record, addressed as follows: Karl J. Januzzi, Esquire SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Attorney for plaintiff RAWLE & 4ENDNRSONI, LLP By: Garysquire Attorney for Defendants, Gary N. Stewart, Esquire Jeffrey C. Mickletz, Esquire Attorney for Defendants, Cumberland-Dauphin- Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten Date: /1a '6 7 1406435 v.1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES VS. File No. 2005-6738 CUMBERLAND-DAUPHIN- HARRISBURG`TRANSI•T AUTHORITYt/d/b/aCAPI'TAL AREA TRANSIT et al SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: YORK HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON, 25 N. Front St., Harrisburg, PA 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Gary N. Stewart, Esquire ADDRESS: ron ree Harrisburg, 1 TELEPHONE: 717-23 -7700 SUPREME COURT ID # 7353 ATTORNEY FOR: Defendants Date: ...Ja,?-,s / Seal of the Cou •t BY THE COURT: Prothonotary, civil Division eputy RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: DARRAINE JONES, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1406442 v. I CERTIFICATE OF AUTHENTICITY FROM: YORK HOSPITAL RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Print Name Title Date 1406442 v. I CON/1N10NWFsALTI-I OF PI-;NNSYLVAN'[A COUNTY OF CUMBERLAND DARRAINE JONES VS. File No. 2005-6738 CUMBERLAND-DAUPHIN- HARRISBURG., TRANSIT AUTHORITYt/d/b/aCAPITAL AREA TRANSIT et al SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: COMMUNITY GENERAL OSTEOPATHIC HOSPITAL (Name of Person or Entity) Within twenty (20) clays after service of this subpoena, you are ordered by the court to Produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON, 25 N. Front St., Harrisburg, PA 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Gary N. Stewart, Esquire ADDRESS: ron ree Harr-is urg, 1 TELEPHONE: 717-23 -7700 SUPREME COURT ID tt 7353 ATTORNEY FOR: Defendants Date: ??s s cal ofthe court BY THE COURT: Prothonotary, Civil 41vi Deputy RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: DARRAINE JONES, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1406442 v.1 CERTIFICATE OF AUTHENTICITY FROM: COMMUNITY GENERAL OSTEOPATHIC HOSPITAL RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Print Name Title Date 1406442 v.I C(WMONWEALTH OF P1 NNSYL,VANIA COUNTY OF CUMBERLAND DARRAINE JONES vs. File No. 2005-67 38 CUMBERLAND-DAUPHIN- HARRISBURG'TRANSIT AUTHORITYt/d/b/aCAPITAL AREA TRANSIT et al SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: FIREMEN'S FUNDINSURANCE (Name of Person or Entity) Within twenty (20) clays after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON, 25 N. Front St., Harrisburg, PA 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Gary N. Stewart, Esquire ADDRESS: ron ree Harrisburg, PA TELEPHONE: 717-23 -7700 SUPREME COURT ID # 67353 ATTORNEYFOR: Defendants BY TUE COURT: Prothonotary, Civil Division Date: _j .-C?? Seal of the (?.ow t ity RIDER TO THE SUBPOENA ANY AND ALL records for any and all claims, PIP claims, property damage claims, including, but not limited to correspondence, memoranda, notes, electronic data including electronic data stored in a retrieval system, declaration sheet, applications for benefits, medical records, medical reports, medical bills, payments made in connection with claims, explanation of medical bill payments, payment records of medical expenses, payments records of work loss, investigation records, police reports, surveillance reports, photographs, videos, statements taken from any person, recorded statement summary notes, index searches, claim activity log notes, records stored at an off site facility, releases, settlement documents, and any other documentation regarding: Darraine Jones 641 S. 29`h Street Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 Claim #: 610-04-042542 1406457 v.I CERTIFICATE OF AUTHENTICITY FROM: FIREMEN'S FUND INSURANCE RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Print Name Title Date 1406442 v.I CERTIFICATE OF SERVICE I hereby certify that on today's date I served a true and correct copy of the foregoing Notice of Intent to Serve Subpoenas, by first-class mail, postage prepaid, upon all attorneys of record, addressed as follows: Karl J. Januzzi, Esquire SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Attorney for plaintiff RAWLE & HENDERSON LLP By: *Garry N. Stewart, Esquire Attorney for Defendants, Gary N. Stewart, Esquire Jeffrey C. Mickletz, Esquire Attorney for Defendants, Cumberland-Dauphin- Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten Date: 1/29/07 2005058-1 DSTOLTZFUS r-. C..? 'T. -T"i i,"l ? f c ,iJ C.-? ? ?t ? r r ? ? 1 .?' ;? 1 ?' , ?$T: ...-^ :.G .-G_ ?,^' RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No.: 67353 By: Michael T. Traxler Identification No.: 90961 Attorneys for Defendants, 240 N. Third Street, 9`' Floor Cumberland-Dauphin-Harrisburg Harrisburg, Pennsylvania 17101 Transit Authority, t/d/b/a Capital (717) 234-7700 Area Transit and Norma Totten DARRAINE JONE vs. CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, and NO: 2005-6738 NORMA TOTTEN Defendants. WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw the appearance of Jeffrey C. Mickletz, Esquire as co-counsel for the defendants, Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a Capital Area Transit, and Norma Totten in the above referenced matter. RAWLE & DER ON By: Esquire Cu berl -Dauphin Harrisburg Transit Au , t/d/b/a Capital Area Transit and Norma Totten ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter Michael T. Traxler, Esquire as co-counsel with Gary N. Stewart, Esquire on behalf of the defendants, Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a Capital Area Transit, and Norma Totten in the above referenced matter. RAWLE & HENDERSON LLP Date: -?l / / p6G7 COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY By: Gary N. Stewart, Esquire Michael T. Traxler, Esquire Attorneys for Defendants, Cumberland-Dauphin Harrisburg Transit Authority, t/d/b/a Capital Area Transit and Norma Totten 2022500-1 CERTIFICATE OF SERVICE I hereby certify that on today's date, a true and correct copy of the foregoing withdrawal/entry of appearance was served by first-class mail, postage prepaid, upon all attorneys of record, addressed as follows: Karl A. Januzzi SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 RAWLE & HENDERSON LLP By. i Michael T. Traxler Date: -?/ / 122 7 2022500-1 if1 } RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No.: 67353 By: Jeffrey C. Mickletz Identification No.: 87531 25 North Front Street, First Floor Harrisburg, Pennsylvania 17101 (717) 234-7700 DARRAINE JONES Plaintiff, vs. CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, and NORMA TOTTEN Defendants Attorneys for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a Capital Area Transit and Norma Totten COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO: 2005-6738 CERTIFICATE PREREQUISITE TO SERVICE OF ADDITIONAL SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoena for documents and things pursuant to Rule 4009.22, Defendants, Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a/ Capital Area Transit and Norma Totten, certify that: 1. A Notice of Intent to Serve subpoenas with a copy of the subpoenas attached hereto 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 objections to the subpoenas have been received. 4. Counsel has waived the twenty (20 day waiting period thereby allowing the subpoenas to be served immediately. A copy of Counsel's waiver is attached. 1388208 v.I RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No.: 67353 25 North Front Street, First Floor Harrisburg, Pennsylvania 17101 (717) 234-7700 Attorneys for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a Capital Area Transit and Norma Totten DARRAINE JONES Plaintiff, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs. CUMBERLAND-DAUPBIN- HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, and NORMA TOTTEN Defendants NO: 2005-6738 NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendants, CUMBERLAND-DAUPHIN-HARRISBURG TRANSIT AUTHORITY, t/d/b/a/ CAPITAL AREA TRANSIT AND NORMA TOTTEN, intends to serve subpoenas identical to the ones that are 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 any objections you may have to the subpoenas. If no objections are made, the subpoenas may be served. RAWLE & HE E ON LLP By: N. Stewart, Esquire Attorney for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten 1381951 v.1 RAWLE &LI_F,NDERSQN LLP .? o o; .o DEBBIE L. BTOLTZFUS PARALEGAL The Nation's Oldest Law Office - Estahlishedin 1783 717-234-7700 www.rawle.com dstoItzfti&@)rawle.com April 24, 2007 Karl A. Januzzi SHOLLENBERGER & JANUZZI LLP 2225 Millennium Way Enola, PA 17025 240 N. THIRD STREET NINTH FLOOR HARRISBURG, PA 17101 TELEPHONE:(717) 234-7700 FACSINLE:(717) 234-7710 Re: Darraine Jones v. Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a Capital Area Transit, and Norma Totten Cumberland County CCP No.: 05-6738 Our File No.: 250186 Dear Mr. Januzzi: Enclosed please find Defendant's Notice of Intent to Serve Subpoena in the above captioned matter. Pursuant to Pennsylvania Rules of Civil Procedure, Rule 4009.21, you have twenty (20) days within which to file objections to these subpoena. If no objections are received, the subpoena will then be served. In the event you are agreeable to waiving the twenty (20) day waiting period, please sign the enclosed copy of this letter and return it to me in the envelope 1 have provided. Thank you for your cooperation and immediate attention to this matter. Very truly yours, RAWLE & HENDERSON LLP By: Debbie L. Stoltzfus, Paralegal DLS/ I hereby agree to waive the twenty (20) day waiting period subpoenas may be served immediately. Dated: 2fQ 2063899-1 in agreement that the PHILADELPHIA, PA PITTSBURGH, PA HARRISBURG, PA MEDIA, PA MARLTON, NJ NEW YORK, NY WILMINGTON, DE WHEELING, WV COMMON V,V AL"i 110 1, PENNSYLVANIA C.;OIJNT'' OF CUMBEK i ,POND UARRAINE JONES VS. File No. 2005-6738 CUMBERLAND-DAUPHIN- ; HARRISBURG TRANSIT AUTHORITYt/d/b/aCAPITAL AREA TRANSIT et al SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO. LIBERTY MUTUAL, INSURANCE COMPANY (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON,24o -N. 3rd St. 9th Frkrrisburg, PA 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST Or'rHE FOLLOWING PERSON. NAME_ Gary N. Stewart, Esquire ADDRESS2R t . t'? 1710-1r arrls urg, ? ?rP,loNi J717-231-7700 SUPREME; COURT ID tl _T? 353 ATTORNEY FOR: Defendants Dale: x"j.._..J- Scal of the e ourt BY THE C RT: Pr thonotar Divi n Deputy ADDENDUM TO THE SUBPOENA ANY AND ALL records for any and all claims, PIP claims, property damage claims, including, but not limited to correspondence, memoranda, notes, electronic data including electronic data stored in a retrieval system, declaration sheet, applications for benefits, medical records, medical reports, medical bills, payments made in connection with claims, explanation of medical bill payments, payment records of medical expenses, payments records of work loss, investigation records, police reports, surveillance reports, photographs, videos, statements taken from any person, recorded statement summary notes, index searches, claim activity log notes, records stored at an off site facility, releases, settlement documents, and any other documentation regarding the following claims: #2952457; #4799581; #6948306; #7479152 and worker's comp claim #61004042542 Darraine Jones 641 S. 29" Street Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 2063900-1 FROM: LIBERTY MUTUAL INSURANCE RE: DARRAINE JONES DOB: SS#: I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Print Name Title Date 1249421 v.t CERTIFICATE OF SERVICE I hereby certify that on today's date I served a true and correct copy of the foregoing Notice of Intent to Serve Subpoenas, by first-class mail, postage prepaid, upon all attorneys of record, addressed as follows: Karl J. Januzzi, Esquire SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Attorney for plaintiff RAWLE & HENDERSON LLP By: Gary N. Stewart, Esquire Attorney for Defendants, Cumberland-Dauphin- Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten Date: y/aq l 0 `7 1381951 v.1 h-1 -J _..: T . -TI rj ,? RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No.: 67353 By: David Chludzinski Identification No.: 200702 240 North Street Street, Ninth Floor Harrisburg, Pennsylvania 17101 (717) 234-7700 DARRAINE JONES Plaintiff, vs. CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, and NORMA TOTTEN Defendants Attorneys for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a Capital Area Transit and Norma Totten COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO: 2005-6738 CERTIFICATE PREREQUISITE TO SERVICE OF ADDITIONAL SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoena for documents and things pursuant to Rule 4009.22, Defendants,Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a/ Capital Area Transit and Norma Totten, certify that: 1. A Notice of Intent to Serve subpoenas with a copy of the subpoenas attached hereto 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 objections to the subpoenas have been received. 3085032-1 I 1 4. The subpoenas which will be served are identical to the subpoenas which are attached to the Notice of Intent to Serve the Subpoena. RAWLE & HEND RSON LLP By: Gary N. Stewart, Esquire David Chludzinski, Esquire Attorney for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten Dated: July 9, 2009 3085032-1 RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No.: 67353 By: Jeffrey C. Mickletz Identification No.: 87531 25 North Front Street, First Floor Harrisburg, Pennsylvania 17101 (717) 234-7700 Attorneys for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a Capital Area Transit and Norma Totten DARRAINE JONES VS. CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, and NORMA TOTTEN Defendants NO: 2005-6738 NOTICE OF INTENT TO SERVE ADDITIONAL SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendants, CUMBERLAND-DAUPHIN-HARRISBURG TRANSIT AUTHORITY, t/d/b/a/ CAPITAL AREA TRANSIT AND NORMA TOTTEN, intends to serve subpoenas identical to the ones that are 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 any objections you may have to the subpoenas. If no objections are made, the subpoenas may be served. RAWLE & HENDERSON LLP By: COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY 4ry N. Stewart, Esquire effrey C. Mickletz, Esquire Attorney for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten 3048329-1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES VS. : File No. NO. 2005-6738 CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY: tfdlbA -DAPITAL AREA TRANSIT and'NORMA TOTTEN SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: HOLY SPIRIT HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON,2_40 N.3rd St.,9th Floor, Harrisburg,PA-'17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Gary N. Stewart, Esquire ADDRESS: 240 N Ord .St ._, 9th_ Floor Harrisburg, TELEPHONE: 717-234-7700 SUPREME COURT ID # 67353 ATTORNEY FOR: Defendants Date:_ (o Seal of the Court BY THE OUR onotary, ivi on Deputy --- T a RIDER TO SUBPOENA Any and all records and radiology films, FROM FEBRUARY 2007 UNTIL THE PRESENT, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: DARRAINE JONES, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1406442-1 CERTIFICATE OF AUTHENTICITY FROM: HOLY SPIRIT HOSPITAL RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Title Print Name Date 1406442-1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES VS. ; File No. NO. 2005-6738 CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY; tftl%b/a CAPITAL AREA TRANSIT ; and NORMA-TOTTEN SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: PHYSIOTHERAPY ASSOCIATES (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON,240 N.3rd St.,9th Floor., Harrisburg,PA.-`17101 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: Gary N. Stewart, Esquire ADDRESS: 240 N. 3rd?.. th Floor Harrisburg, Plul. TELEPHONE: 717-234-7700 SUPREME COURT ID # 7353 ATTORNEY FOR: Defendants Date: 19 0 Sea of the Court BY T COU T: rot onotary, Di Sion Deputy I t i RIDER TO SUBPOENA Any and all records and radiology films, FROM DECEMBER 2006 UNTIL THE PRESENT, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: DARRAINE JONES, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1406442-1 CERTIFICATE OF AUTHENTICITY FROM: PHYSIOTHERAPY ASSOCIATES RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Title Print Name Date 1406442-1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES VS. CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY: t?tIfbB'`OAPTTAL AREA TRANSIT and NORMA TOTTEN File No. NO. 2005-6738 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: TRISTAN ASSOCIATES (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON,2.40 N. 3rd St., 9th Floor, Harrisburg,PA 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Gary N. Stewart, Esquire ADDRESS: 24.0 N. 3rd- , 9th Floor Harris urg, Y T-t lu'I TELEPHONE: 7-17-234-7700 SUPREME COURT ID # 7353 ATTORNEYFOR: Defendants Date: 04,01 Sea of the court BY THE URT: P othonotary, C 'v ion Deputy RIDER TO SUBPOENA Any and all records and radiology films, FROM NOVEMBER 2007 UNTIL THE PRESENT, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: DARRAINE JONES, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1406442-1 CERTIFICATE OF AUTHENTICITY FROM: TRISTAN ASSOCIATES RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Title Print Name Date 1406442-1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES VS. FileNo. NO. 2005-6738 CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY O'lc Abl "CAPITAL AREA TRANSIT And NORMA TOTTEN SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: DR. STUART HARTMAN (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON,2;40 N.3rd St.,9th Floor, Harrisburg,PA.-'17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Garv N. Stewart, Esquire ADDRESS: 24D'- N.rd_-St., 9th Floor tarrisburg, FA I--(Iul TELEPHONE: 717-234-7700 SUPREME COURT ID # 7353 ATTORNEYFOR: Defendants Date:_ (p p Seal of t e Court BY THE OURT: othonotary, Deputy Is RIDER TO SUBPOENA Any and all records and radiology films, FROM DECEMBER 2006 UNTIL THE PRESENT, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: DARRAINE JONES, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1406442-1 CERTIFICATE OF AUTHENTICITY FROM: DR. STUART HARTMAN RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Print Name Title Date 1406442-1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES VS. CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY: t1d/b /a`CAP'ITAL AREA TRANSIT and NORMA TOTTEN File No. NO. 2005-6738 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: HEALTHSouth/ WORK PERFECT (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON,240 N.3rd St.,9th Floor, Harrisburg,PA- 17101 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: Gary N. Stewart, Esquire ADDRESS: 240. N. 3rA -0-_4- ._ , 9th Floor arr s urg,-'i ` 7TO TELEPHONE: 717-234-7700 SUPREME COURT ID !i 67353 ATTORNEY FOR: Defendants Date:_ & 1 q 0? Seal of th Court BY TH OU T: Prothonotary, Ci ' ivi on Deputy J RIDER TO SUBPOENA Any and all records and radiology films, FROM DECEMBER 2006 UNTIL THE PRESENT, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: DARRAINE JONES, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1406442-1 CERTIFICATE OF AUTHENTICITY FROM: HEALTHSOUTH/WORK PERFECT RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Print Name Title Date 1406442-1 A COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES VS. : File No. NO. 2005-6738 CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY t'1cilbf 'CAPITAL AREA TRANSIT and'NORMA TOTTEN SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: DR. BALINT BOLOG (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON,240 N.3rd St..,;9th Floor, Harrisburg,PA- 17101 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: Gar.V N. Stewart, Esquire ADDRESS:_ ? 24.D , N .3 d Zt _ _ 9th Floor arrisburg, 7A--xT-rU1 TELEPHONE: 717-23 -7 7 0 0 SUPREME COURT ID # 7353 ATTORNEY FOR: Defendants Sea o BY THE UR Date:_ / ?th Pr onotary, ivi on Deputy RIDER TO SUBPOENA Any and all records and radiology films from December 2006 until the present, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: DARRAINE JONES, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1406442-1 CERTIFICATE OF AUTHENTICITY FROM: BALINT BALOG, MD RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Title Print Name Date 1406442-1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES VS. . File No. NO. 2005-6738 CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY; tWb/ CAPITAL AREA TRANSIT And- NORMA TOTTEN SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: DR STEVEN MORG,ANSTEIN / PRISM (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON,240 N.3rd St..,9th Floor, Harrisburg,PA-`17101 !A AArnrel 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: Gary N. Stewart, Esquire ADDRESS: 240 N. 9rd Zt. , 9th_ Floor arr s urg, r TELEPHONE: 717-234-7700 SUPREME COURT ID # 7353 ATTORNEY FOR: Defendants Date: 6fiQ LID9 Seal of the Court BY THE OURT: P thonotary, Ci visi n Deputy RIDER TO SUBPOENA Any and all records and radiology films, FROM OCTOBER 2006 UNTIL THE PRESENT, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: DARRAINE JONES, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1406442-1 CERTIFICATE OF AUTHENTICITY FROM: DR. STEVEN MORGANSTEIN/PRISM RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Title Print Name Date 1406442-1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES VS. , File No. NO. 2005-6738 CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY: t >d/b A - CAPITAL AREA TRANSIT and'NORMA TOTTEN SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: DR. NITA RASTOGI (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON,240 N.3rd St.,9th Floor, Harrisburg,PA-_17101 A .1A-) 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: Gary N. Stewart, Esquire ADDRESS: 24() N, 3rd ._ .9thFloor Hai s urg, 1"r'Y'ITI TELEPHONE: 717-234-7700 SUPREME COURT ID # 67353 ATTORNEYFOR: Defendants Date: _419D? _ Seal of a Court BY T OURT: rot onotary, Div' ion Deputy RIDER TO SUBPOENA Any and all records and radiology films, FROM DECEMBER 2006 UNTIL THE PRESENT, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: DARRAINE JONES, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1406442-1 CERTIFICATE OF AUTHENTICITY FROM: DR. NITA RASTOGI RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-524550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Print Name Title Date 1406442-1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES VS. , File No. NO. 2005-6738 CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY: t1t3/b/a CAPITAL AREA. TRANSIT and NORMA TOTTEN SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: FIREMAN'S FUND INSURANCE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON,2_40 N. 3rd St.,9th Floor, Harrisburg,PA- 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Gary N. Stewart, Esquire ADDRESS: 24,0 A. A ._, 9th Floor Harrisburg, FA -1-Flul TELEPHONE: 717-234-7700 SUPREME COURT ID # 67353 ATTORNEY FOR: Defendants Date: 9 Seal th Court BY T CO RT: 4jiZ rothonotary , rv on Deputy RIDER TO SUBPOENA ANY AND ALL, records FROM JANUARYY 2007 UNTIL THE PRESENT, Medical Reports, Medical Bills, Doctor's office notes, reports of consultations, Reports of Independent Medical Evaluations, Reports of injury and/or illness, reports of investigations, photographs, statements, surveillance videos, transcripts of all worker'scompensation proceedings; all pleadings filed relating to any claims, wage and salary information, and any and all other documents contained in the worker's compensation file UNDER CLAIM #61004042542 FOR DATE OF LOSS: 8/16/04. DARRAINE JONES, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1406442-1 CERTIFICATE OF AUTHENTICITY FROM: FIREMAN'S FUND INSURANCE RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Print Name Title Date 140W2-1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES VS. . File No. NO. 2005-6738 CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY: t1d'./bf6? CAPITAL AREA TRANSIT and NORMA TOTTEN SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: COMMUNITY OSTEOPATIC GENERAL HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM at RAWLE & HENDERSON,240 N.3rd St. 9th Floor, Harrisburg,PA 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Gary N. Stewart, Esquire ADDRESS: 240 N. 3rc1 .. , 9th_ :Floor Harrisburg, FR Tj 1 TELEPHONE: 717-23 -7700 SUPREME COURT ID # 7 353 ATTORNEY FOR: De fendant s Date: he Log Seal f t e Court BY T OU T: Prothonotary, i sion Deputy RIDER TO SUBPOENA Any and all records and radiology films, FROM FEBRUARY 2007 UNTIL THE PRESENT, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: DARRAINE JONES, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1406442-1 CERTIFICATE OF AUTHENTICITY FROM: COMMUNITY OSTEOPATHIC GENERAL HOSPITAL RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Print Name Title Date 1406442-1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES VS. File No. NO. 2005-6738 CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY : t /ii/b /6 CAPITAL AREA TRANSIT and NORMA TOTTEN SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: LIBERTY MUTUAL INSURANCE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON,240 N.3rd St,.,9th Floor, Harrisburg,PA- 17101 f A AA-..% 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: Gary N. Stewart, Esquire ADDRESS: 240i s- burg A ..,9 -T-t I? Floor TELEPHONE: 717-234-7700 SUPREME COURT ID # 67353 ATTORNEY FOR: Defendants Date:_ Q Sea of ffie Court BY T COURT: rothonotary, ' Di tsion Deputy ADDENDUM TO THE SUBPOENA ANY AND ALL records for any and all claims, PIP claims, property damage claims, including, but not limited to correspondence, memoranda, notes, electronic data including electronic data stored in a retrieval system, declaration sheet, applications for benefits, medical records, medical reports, medical bills, payments made in connection with claims, explanation of medical bill payments, payment records of medical expenses, payments records of work loss, investigation records, police reports, surveillance reports, photographs, videos, statements taken from any person, recorded statement summary notes, index searches, claim activity log notes, records stored at an off site facility, releases, settlement documents, and any other documentation regarding the following claims: #2952457; #4799581; #6948306; #7479152; FROM JULY 2007 UNTIL THE PRESENT. Darraine Jones 641 S. 296` Street Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 2063900-1 CERTIFICATE OF AUTHENTICITY FROM: LIBERTY MUTUAL INSURANCE RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Print Name Title Date 1406442-1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES VS. : Fite No. NO. 2005-6738 CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY: t f ii/b /` CAPITAL AREA TRANSIT ' And NORMA TOTTEN SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: HERSHEY MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON,44 N. 3rd St..,9th Floor, Harrisburg,PA 17.101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the riglit 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: Gary N. Stewart, Esquire ADDRESS: _24-0 N_. d. A ..9th Floor arr s urg, TELEPHONE: 717-234-7700 SUPREME COURT ID # 67353 ATTORNEY FOR: Defendants Date:_ -01910 Seal of the Court BY T OU T; rothonotary, i sion T Deputy RIDER TO SUBPOENA Any and all records and radiology films, FROM NOVEMBER 2006 UNTIL THE PRESENT, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: DARRAINE JONES, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1406442-1 CERTIFICATE OF AUTHENTICITY FROM: HERSHEY MEDICAL CENTER RE: DARRAINE JONES DOB: 1112160 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Title Print Name Date 1406442-1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES VS. . File No. NO. 2005-6738 CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY: t fdfblt 'CAPITAL AREA TRANSIT and NORMA TOTTEN SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO:-DR. EMILY MATLIN (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON,240 N. 3rd St. ,9th Floor, Harrisburg,PA• 17101 (AA`Iroenl 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: Gary N. Stewart, Esquire ADDRESS: 24N. arc ._.9th Floor HaarrrisbUrg, Fri "'I")'Tul TELEPHONE: 717-234-7700 SUPREME COURT ID # 7353 ATTORNEYFOR:. Defendants Date: to R Seal of the Court BY 'l COURT: Prothonotary, i i sion Deputy RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, . consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: DARRAINE JONES, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SSM 100-52-4550 1406442-1 CERTIFICATE OF AUTHENTICITY FROM: DR. EMILY MATLIN RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Title Print Name Date 1406442-1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES VS. : File No. NO. 2005-6738 CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY: t:jdlb /a 'CAPITAL AREA TRANSIT ; and NORMA TOTTEN SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO:COLONIAL PARK FAMILY PRACTICE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM at RAWLE & HENDERSON,2.40 N-3rd St. 19th Floor, Harrisburg, PA-` 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Gary N. Stewart, Esquire ADDRESS: 240 N. Ord- ._ . 9th Floor arr sburg,'i'FA T-( lu l TELEPHONE: 717-234-7700 SUPREME COURT ID # 7353 ATTORNEY FOR: Defendants Date: 019 Seal f the Court BY T OU T: rothonotary, Sion Deputy RIDER TO SUBPOENA Any and all records and radiology films, FROM 2002 UNTIL THE PRESENT, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: DARRAINE JONES, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1406442-1 CERTIFICATE OF AUTHENTICITY FROM: COLONIAL PARK FAMILY PRACTICE RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Title Print Name Date 1406442-1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES VS. CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY: t f d ./b a ,CAPITAL AREA TRANSIT and NORMA-TOTTEN File No. N0. 2005-6738 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: PINNACLE HEALTH FAMILY CARE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON,240 N.3rd St.,.9th Floor, Harrisburg,PA- 17101 f D rlrlracel 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: Gary N. Stewart, Esquire ADDRESS: 240 N.3rd St._, th Floor harrisourg, FA T-1 1131 TELEPHONE: 717-234-7700 SUPREME COURT ID iE 67353 ATTORNEY FOR: Defendants Date: jp1/9 - Seal 'of the Court BY TH OU T: rothonotary, rv ion Deputy RIDER TO SUBPOENA Any and all records and radiology films, FROM DECEMBER 2006 UNTIL THE PRESENT, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: DARRAINE JONES, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1406442-1 CERTIFICATE OF AUTHENTICITY FROM: PINNACLE HEALTH FAMILY CARE RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. 1 hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Print Name Title Date 1406442-1 R COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES VS. File No. NO. 2005-6738 CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY tjdfb/s CAPITAL AREA TRANSIT And NORMA TOTTEN SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: OIP PHYSICAL THERAPY (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON,240 N.3rd St.,9th Floor, Harrisburg,PA-'17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Gary N. Stewart, Esquire ADDRESS: 240 N.3rd; ._.9th Floor Harrisburg, PH 7-rilTl TELEPHONE: 717-234-7700 SUPREME COURT ID # 67353 ATTORNEYFOR: Defendants Date: &/19 loq Sell of he Court BY TH OURT: if -0 othonotar?sion Deputy RIDER TO SUBPOENA Any and all records and radiology films, FROM NOVEMBER 2007 UNTIL THE PRESENT, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: DARRAINE JONES, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1406442-1 CERTIFICATE OF AUTHENTICITY FROM: OIP PHYSICAL THERAPY RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Title Print Name Date 1406442-1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES VS. CUMBERLAND DAUPHIN- HARRISBURG TRANSIT AUTHORITY: t'fttfbtCAPITAL AREA TRANSIT And NORMA TOTTEN File No. NO. 2005-6738 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: WILLIAM ROLLE, JR., MD/PRISM (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON,249 N. 3rd St,,9th Floor, Harrisburg,PA- 17101 (A Aj4rnoel 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: Gary N. Stewart, Esquire ADDRESS: 240 N. 3r? , , , 9th Floor arr sburg,-L-1 LU _L TELEPHONE: 717-234-7700 SUPREME COURT ID # 7353 ATTORNEY FOR: De Pendant s Date: 10114 /P,? Seal f t e Court BY T OU T: rothonota i ision Deputy RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: DARRAINE JONES, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1406442-1 CERTIFICATE OF AUTHENTICITY FROM: WILLIAM ROLLE, JR., MD/PRISM RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Print Name Title Date 1406442-1 b i , COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES VS. FifeNo. NO. 2005-6738 CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT,AUTHORITY: 1a'% 1 CAPITAL AREA TRANSIT and NORMA TOTTEN SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CAPITAL BLUE CROSS (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON,240 N.3rd St.,9th Floor, Harrisburg,PA 17101 tAaaress) 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: Gary N. Stewart, Esquire ADDRESS: 240 N. 3rc_St.,, 9th Floor Harr s urg, TELEPHONE: 717-234-7700 SUPREME COURT ID 7353 ATTORNEYFOR: Defendants Date:_ & /q IQ? Seal oft a Court BY T CO RT: rrothono "Sion Deputy .1 0 4 RIDER TO SUBPOENA ANY AND ALL, Applications for employment, wage and salary history, attendance records, job descriptions, reports of evaluations, W-2 forms, reports of injuries/illness, documents relating to workers compensation claims and/pr unemployment claims, reports of disciplinary actions, medical records, medical bills, and any and all other documents contained in the employment/personnel file relating to: DARRAINE JONES, 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1406442-1 1 CERTIFICATE OF AUTHENTICITY FROM: CAPITAL BLUE CROSS RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Title Print Name Date 1406442-1 i J s CERTIFICATE OF SERVICE I hereby certify that on today's date I served a true and correct copy of the foregoing Notice of Intent to Serve Additional Subpoenas, by first-class mail, postage prepaid, upon all attorneys of record, addressed as follows: Karl J. Januzzi, Esquire SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Attorney for plaintiff RAWLE & HENDERSON LLP By: Date: June 18, 2009 Gap( N. Stewart, Esquire ?ftorney for Defendants, Gary N. Stewart, Esquire Jeffrey C. Mickletz, Esquire Attorney for Defendants, Cumberland-Dauphin- Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten 3048329-1 it A 2 OO 33' J UL 10 F `1 3' C Q- RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No.: 67353 By: David Chludzinski Identification No.: 200702 240 North Street Street, Ninth Floor Harrisburg, Pennsylvania 17101 (717) 234-7700 DARRAINE JONES Plaintiff, VS. CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, and NORMA TOTTEN Defendants Attorneys for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a Capital Area Transit and Norma Totten COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO: 2005-6738 CERTIFICATE PREREQUISITE TO SERVICE OF ADDITIONAL SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoena for documents and things pursuant to Rule 4009.22, Defendants,Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a/ Capital Area Transit and Norma Totten, certify that: 1. A Notice of Intent to Serve subpoenas with a copy of the subpoenas attached hereto 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 objections to the subpoenas have been received. 3085032-1 4. The subpoenas which will be served are identical to the subpoenas which are attached to the Notice of Intent to Serve the Subpoena. RAWLE & HENDERSON LLP By: Gary N. Stewart, Esquire David Chludzinski, Esquire Attorney for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten Dated: August 18, 2009 3085032-1 RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No.: 67353 By: David Chludzinski Identification No.: 200702 25 North Front Street, First Floor Harrisburg, Pennsylvania 17101 (717) 234-7700 Attorneys for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a Capital Area Transit and Norma Totten DARRAINE JONES Plaintiff, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs. NO: 2005-6738 CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, and NORMA TOTTEN Defendants NOTICE OF INTENT TO SERVE ADDITIONAL SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendants, CUMBERLAND-DAUPHIN-HARRISBURG TRANSIT AUTHORITY, t/d/b/a/ CAPITAL AREA TRANSIT AND NORMA TOTTEN, intends to serve subpoenas identical to the ones that are 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 any objections you may have to the subpoenas. If no objections are made, the subpoenas may be served. RAWLE & By: ERSON LLP 'Gary N. Stewart, Esquire David Chludzinski, Esquire Attorney for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten 3048329-1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES VS : File No. 2005-6738 CAPITAL AREA TRANSIT, ET AL: SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: FAMILY & INTERNAL MEDICINE CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON,24.0 N. 3rd St.,9thFloor,Harrisburg, PA 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Gary N. Stewart, Esquire 946 - N _ 3rc? ?_, 9th F1 oor Harrisburg,_PA 17101 TELEPHONE: 71-7-234-7700 SUPREME COURT ID # 7353 ATTORNEY FOR: Defendants Date: a eal o the Court BY T COU T: Prothonot Zvi ion Deputy RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to: ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: Darraine Jones, 4125 Spring Valley Road, Harrisburg, PA 17109 and formerly of 641 S. 29"' Street, Harrisburg, PA 17111 DOB: 1/12/60 SSM 100-52-4550 1363731 v.1 CERTIFICATE OF AUTHENTICITY FROM: FAMILY & INTERNAL MEDICINE CENTER RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Title Print Name Date 1363731 v.1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES VS File No. 2005-6738 CAPITAL AREA TRANSIT, ET AL: SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: DR. JAGADEESH MOOLA (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON,240 N. 3rd St.,9thFloor,Harrisburg, PA 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Gary N. Stewart, Esquire ADDRESS 4n N_ 3rd St , 9 h "Floor Harrisburg,.PA 17101 TELEPHONE: 71-7-234-7700 SUPREME COURT ID # 7 3 5 3 ATTORNEY FOR: Defendants Date: 7 _ Salo the Court BY T COU T: AS-r-othon i ivi on Deputy RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to: ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: Darraine Jones, 4125 Spring Valley Road, Harrisburg, PA 17109 and formerly of 641 S. 29"' Street, Harrisburg, PA 17111 DOB: 1/12/60 SSM 100-52-4550 1363731 v.l CERTIFICATE OF AUTHENTICITY FROM: DR. JAGADEESH MOOLA RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 1 am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Title Print Name Date 1363731 v.1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES VS CAPITAL AREA TRANSIT, ET AL: File No. 2005-6738 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: POLYCLINIC HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON,240 N.3rd St.,9thFloor,Harrisburg, PA 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Gary N. Stewart, Esquire ADDRE 'Floor Harrisburg,.PA 17101 TELEPHONE: 717-23 -7700 SUPREME COURT ID # 67353 ATTORNEY FOR: De fendant s _ Date: a Bk9 Sea of the Court BY TH UR : o onotar , C' sio Deputy RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to: ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: Darraine Jones, 4125 Spring Valley Road, Harrisburg, PA 17109 and formerly of 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SSM 100-52-4550 1363731 v.1 CERTIFICATE OF AUTHENTICITY FROM: POLYCLINIC HOSPITAL RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Title Print Name Date 1363731 v.1 RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to: ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: Darraine Jones, 4125 Spring Valley Road, Harrisburg, PA 17109 and formerly of 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1363731 v.1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES VS File No. 2005-6738 CAPITAL AREA TRANSIT, ET AL: SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: DR. JOHN FRANKENY (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM atRAWLE & HENDERSON,240 N. 3rd St.,9thFloor,Harrisburg, PA 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Gary N. Stewart, Esquire ADDRES94n` N: -?T- t 9 h Floor Harrisburg PA 17101 TELEPHONE: 717-23 -7700 SUPREME COURT ID # 7353 ATTORNEY FOR: Defendants Date: 7 h e 0 _ Sea oft e Court BY TH OUR : onotary, Civ' visi Deputy CERTIFICATE OF AUTHENTICITY FROM: DR. JOHN FRANKENY RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Title Print Name Date 1363731 v.1 CERTIFICATE OF SERVICE I hereby certify that on today's date I served a true and correct copy of the foregoing Notice of Intent to Serve Additional Subpoenas, by first-class mail, postage prepaid, upon all attorneys of record, addressed as follows: Karl J. Januzzi, Esquire SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Attorney for plaintiff RAWLE & HENDERSON LLP r , By: f ary N. Stewart, Esquire Attorney for Defendants, Gary N. Stewart, Esquire David Chludzinski, Esquire Attorney for Defendants, Cumberland-Dauphin- Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten Date: June 18, 2009 3048329-1 FILED-O FiCE (T THE 2009 AGG' 19 PAM 2, IS 3 RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No. 67353 By: Brian A. McCall Identification No: 83030 Payne Shoemaker Building 240 North 3`d Street, 9th Floor Harrisburg, PA 17101 (717) 234-7700 (717) 234-7710 (fax) DARRAINE JONES, Plaintiff, L 10 m? n?izar? n r L 'N'D G' j. A Counsel for Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION - LAW vs. CUMBERLAND-DAUPHIN-H.4 TRANSIT AUTHORITY, t/d/b/a AREA TRANSIT, and NORMA Defendants NO. 2005-6738 AL N, JURY TRIAL DEMANDED AND NOW, comes the 11-fendants, by and through their counsel of record, Rawle & Henderson LLP, and hereby fil its Motion for Status Conference, respectfully averring as follows: 1. This case arises f om a motor vehicle accident which occurred on March 22, 2004, at approximately 6:00 a.m. ' Lemoyne, Cumberland County, Pennsylvania. 2. On that time and date, Norma Totten was operating a bus for Capital Area Transit (CAT) at the intersection of Market and 8th Streets in Lemoyne. 3. According to the police report, the plaintiff was traveling west on Market Street when Ms. Totten entered the inter ection from North 8th Street without waiting until the roadway was clear. 4304980-1 4. According to the; Capital Area Transit Authority Commercial Bus Accident Report, Ms. Totten stopped at st} p sign on 8t' Street. She glanced at her paperwork and then proceeded to turn on Market Street. An impact occurred between the front of the bus and the right rear side of a vehicle that w s traveling west on Market Street (Plaintiff's vehicle). 5. On or about December 27, 2005, Plaintiff filed a Complaint, sounding in negligence and asserting various personal injuries, including sprain/strains to her cervical thoracic and lumbar spine and aggravation of her pre-existing fibromyalgia. 6. Defendants filed their Answer on or about October 20, 2006. 8. Discovery in this after commenced many years ago. However, at this juncture, discovery has failed to steadily pr gress. 9. Counsel for Defendants has contacted counsel for the Plaintiff on several occasions to address the status o the case but no response has been received until just recently, as Plaintiff's counsel has provided some additional medical records. However, discovery remains incomplete in all other respects. 10. Noting the clear age of what has until recently become a static case, Defendants seek both progression and resoluti n of this matter. 11. Defendants believ that Court intervention will facilitate the resolution of this claim either via settlement or trial. 12. Accordingly, a status conference is necessary to set reasonable deadlines and parameters for discovery and trial, as well as to avoid unnecessary further delays. 13. As such, Moving efendants request that this matter be assigned to a Judge and a Status Conference hearing be sche uled. 4304980-1 WHEREFORE, the Moving Defendants respectfully requests that this Honorable Court grant the Motion for Status Conference. RAWLE &TIENDERSON LLP ZAY N. Stebirt, Esquire Identification No.: 67353 Brian A. McCall, Esquire PA Identification No.: 83030 Attorneys for Defendants. Payne Shoemaker Bldg., 91h Floor 240 North Third Street Harrisburg, PA 17101 gstewart@,rawle.com azeiter@rawle.com (717) 234-7700 - Telephone (717) 234-7710 - Facsimile Dated: ? - 9 , l f 4304980-1 SER I hereby certify document was served by first as follows: A on today's date, a true and correct copy of the foregoing mail, postage prepaid, upon all attorneys of record, addressed J. Januzzi, Esquire lenberger & Januzzi, LLP > Millennium Way a, PA 17025 rneys for Plaintiff RAWLE & HEN N LLP qA N. Ste art, Esquire d entification No.: 67353 Brian A. McCall, Esquire PA Identification No.: 83030 Attorneys for Defendants. Payne Shoemaker Bldg., 9`h Floor 240 North Third Street Harrisburg, PA 17101 gstewart(&rawle.com bmccalla,rawle.com (717) 234-7700 - Telephone (717) 234-7710 - Facsimile Dated: 3'9, 11 4304980-1 PROPOSED ORDER AND NOW, in consideration of Defendants Motion for a Status Conference, it is hereby E r+.? 5??? iCsl. rye( u :. ;iO HCNU TTAR 1 RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No. 67353 By: Brian A. McCall Identification No: 83030 Payne Shoemaker Building 240 North 3`d Street, 91h Floor Harrisburg, PA 17101 (717) 234-7700 (717) 234-7710 (fax) 3ERLAND COUNTY PoINSYLVANIA Counsel for Defendants DARRAINE JONES, COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, CIVIL ACTION - LAW Vs. NO. 2005-6738 CUMBERLAND-DAUPHIN-HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, and NORMA TOTTEN, JURY TRIAL DEMANDED Defendants. ORDERED that a status conference shall be held before the undersigned and U' CiB ?o% &,4, ffad A.07 z;t- eoul? -4. S ' &o-n A . Mc-NAI, KowI J. Januzzi,aq- PICO -3/'s/pt 3l ?*6 4304980-1 FICE L e F C l ONOTARY RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No.: 67353 By: Brian McCall Identification No.: 83030 240 North Street Street, Ninth Floor Harrisburg, Pennsylvania 17101 (717) 234-7700 DARRAINE JONES Plaintiff, VS. CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, and NORMA TOTTEN Defendants 12 A 10 1', r.A `-"L.At40 COUNTY E YLVA' 141A Attorneys for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a Capital Area Transit and Norma Totten COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO: 2005-6738 CERTIFICATE PREREQUISITE TO SERVICE OF ADDITIONAL SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoena for documents and things pursuant to Rule 4009.22, Defendants,Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a/ Capital Area Transit and Norma Totten, certify that: 1. A Notice of Intent to Serve subpoenas with a copy of the subpoenas attached hereto 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. No objections to the subpoenas have been received. 4461196-1 4. The subpoenas which will be served are identical to the subpoenas which are attached to the Notice of Intent to Serve the Subpoena. RAWLE & HENDERSON LLP By: 96ry N. Stewart, Esquire 43rian McCall, Esquire Attorney for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten Dated: April 11,2011 4461196-1 RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No.: 67353 By. Brian McCall Identification No.: 8303 1: 4> o c rte Harrisburg, Pennsylvania 17101 (717) 234-7700 DARRAINE JONES vs. Plaintiff, CUMBERLAND-DAUPHIN- HARRISBURG TRANSIT AUTHORITY, t/d/b/a CAPITAL AREA TRANSIT, and NORMA TOTTEN Defendants Attorneys for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority, t/d/b/a Capital Area Transit and Norma Totten COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO: 2005-6738 NOTICE OF INTENT TO SERVE ADDITIONAL SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendants, CUMBERLAND-DAUPHIN-HARRISBURG TRANSIT AUTHORITY, t/d/b/a/ CAPITAL AREA TRANSIT AND NORMA TOTTEN, intends to serve subpoenas identical to the ones that are 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 any objections you may have to the subpoenas. If no objections are made, the subpoenas may be served. r RAWLE & PENDERSON LLP By: ary N. Stewart, Esquire Brian McCall, Esquire Attorney for Defendants, Cumberland-Dauphin-Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten 4357229-1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES CUMBERLAND COUNTY COURT OF COMMON PLEAS V. CUMBERLAND-DAUPHIN : HARRISBURG TRANSIT AUTHORITY: t/d/b/a CAPITAL AREA TRANSIT : and NORMA TOTTEN NO.2005-6738 Subpoena to Produce Documents or Things for Discovery Pursuant to Rule 4009.22 To: Records Custodian, Natalie Dubchak MD (Name of Person or Entity) Within twenty (20) days after the service of this subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED ADDENDUM-at Rawle & Henderson LLP, 240 N. Third St.,9th Floor, Harrisburg PA 17101 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: Date: f SEAT:,; Name: Gary N. Stewart, Esquire Rawle & Henderson LLP 240 N.3rd St.,9th Floor Address: Harrisburg,PA 17101 Telephone: 717-234-7700 Supreme Court ID#: 67353 Attorney for: Defendants 4357242-1 BY THE COURT: RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to: ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: Darraine Jones, 4125 Spring Valley Road, Harrisburg, PA 17109 and formerly of 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1112/60 SS#: 100-52-4550 1381958-1 CERTIFICATE OF AUTHENTICITY FROM: DR. NATALIE DUBCHAK RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Print Name Title Date 1381958-1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES CUMBERLAND COUNTY COURT OF COMMON PLEAS V. CUMBERLAND-DAUPHIN : HARRISBURG TRANSIT AUTHORITY: t/ d/ b/ a CAPITAL AREA TRANSIT : and NORMA TOTTEN NO.2005-6738 Subpoena to Produce Documents or Things for Discovery Pursuant to Rule 4009.22 To: Records Custodian, Todd Fisher MD (Name of Person or Entity) Within twenty (20) days after the service of this subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED ADDENDUM-at Rawle 8v Henderson LLP, 240 N. Third St.,9th Floor, Harrisburg PA 17101 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: Date: -3-1-11 [SEAL] Name: Gary N. Stewart, Esquire Rawle & Henderson LLP 240 N.3rd St.,9th Floor Address: Harrisburg,PA 17101 Telephone: 717-234-7700 Supreme Court ID#: 67353 Attorney for: Defendants BY THE COURT: Prothonotary 4357242-1 RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to: ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: Darraine Jones, 4125 Spring Valley Road, Harrisburg, PA 17109 and formerly of 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1381958-1 CERTIFICATE OF AUTHENTICITY FROM: DR. TODD FISHER RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Title Print Name Date 1381958-1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES CUMBERLAND COUNTY COURT OF COMMON PLEAS V. CUMBERLAND-DAUPHIN : HARRISBURG TRANSIT AUTHORITY: t/ d/ b/ a CAPITAL AREA TRANSIT : and NORMA TOTTEN NO.2005-6738 Subpoena to Produce Documents or Things for Discovery Pursuant to Rule 4009.22 To: Records Custodian, Justin Fisher MD (Name of Person or Entity) Within twenty (20) days after the service of this subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED ADDENDUM-at Raw_ le & Henderson LLP, 240 N. Third St.,9th Floor, Harrisburg,PA 17101 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: Date: t - [SEAT:) Name: Gary N. Stewart, Esquire Rawle & Henderson LLP 240 N.3rd St.,9th Floor Address: Harrisburg,PA 17101 Telephone: 717-234-7700 Supreme Court ID#: 67353 Attorney for: Defendants BY THE COURT: Prothonotary 4357242-1 RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to: ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: Darraine Jones, 4125 Spring Valley Road, Harrisburg, PA 17109 and formerly of 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1381958-1 CERTIFICATE OF AUTHENTICITY FROM: DR. JUSTIN FISHER RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Title Print Name Date 1381958-1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES CUMBERLAND COUNTY COURT OF COMMON PLEAS V. CUMBERLAND-DAUPHIN : HARRISBURG TRANSIT AUTHORITY: t/ d/ b/ a CAPITAL AREA TRANSIT : and NORMA TOTTEN NO.2005-6738 Subpoena to Produce Documents or Things for Discovery Pursuant to Rule 4009.22 To: Records Custodian, Nita Rastogi MD (Name of Person or Entity) Within twenty (20) days after the service of this subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED ADDENDUM-at Rawle & Henderson LLP, 240 N. Third St.,9th Floor, Harrisburg,PA 17101 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 parry 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: Date: J-1 -1( (SEAL] Name: Gary N. Stewart, Esquire Rawle & Henderson LLP 240 N.3rd St.,9th Floor Address: Harrisburg,PA 17101 Telephone: 717-234-7700 Supreme Court ID#: 67353 Attorney for: Defendants BY THE COURT: Prothonotary (c - ; ( Ai 4357242-1 RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to: ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: Darraine Jones, 4125 Spring Valley Road, Harrisburg, PA 17109 and formerly of 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SSM 100-52-4550 1381958-1 CERTIFICATE OF AUTHENTICITY FROM: DR. NITA RASTOGI RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Title Print Name Date 1381958-1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES CUMBERLAND COUNTY COURT OF COMMON PLEAS V. CUMBERLAND-DAUPHIN HARRISBURG TRANSIT AUTHORITY: t/d/b/a CAPITAL AREA TRANSIT : and NORMA TOTTEN NO.2005-6738 Subpoena to Produce Documents or Things for Discovery Pursuant to Rule 4009.22 To: Records Custodian, Charles F. Yanofshy, MD (Name of Person or Entity) Within twenty (20) days after the service of this subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED ADDENDUM-at Rawle & Henderson LLP, 240 N. Third St.,9th Floor, Harrisburg PA 17101 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: Date: [SEAL] Name: Gary N. Stewart, Esquire Rawle & Henderson LLP 240 N.3rd St.,9th Floor Address: Harrisburg,PA 17101 Telephone: 717-234-7700 Supreme Court ID#: 67353 Attorney for: Defendants BY THE COURT: Prothonotary i 4357242-1 RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to: ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: Darraine Jones, 4125 Spring Valley Road, Harrisburg, PA 17109 and formerly of 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1381958-1 CERTIFICATE OF AUTHENTICITY FROM: DR. CHARLES S. YANOFSKY RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer. to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Title Print Name Date 1381958-1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES CUMBERLAND COUNTY COURT OF COMMON PLEAS V. CUMBERLAND-DAUPHIN HARRISBURG TRANSIT AUTHORITY: t/d/b/a CAPITAL AREA TRANSIT : and NORMA TOTTEN NO.2005-6738 Subpoena to Produce Documents or Things for Discovery Pursuant to Rule 4009.22 To: Records Custodian, Jajzdish Shah MD (Name of Person or Entity) Within twenty (20) days after the service of this subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED ADDENDUM-at Rawle & Henderson LLP, 240 N. Third St.,9th Floor, Harrisburg PA 17101 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: Date: _?-1 -11 [SEAL] Name: Gary N. Stewart, Esquire Rawle & Henderson LLP 240 N.3rd St.,9th Floor Address: Harrisburg,PA 17101 Telephone: 717-234-7700 Supreme Court ID#: 67353 Attorney for: Defendants 4357242-1 BY THE COURT: RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to: ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: Darraine Jones, 4125 Spring Valley Road, Harrisburg, PA 17109 and formerly of 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1381958-1 CERTIFICATE OF AUTHENTICITY FROM: DR. JAGDISH SHAH RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Title Print Name Date 1381958-1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES CUMBERLAND COUNTY COURT OF COMMON PLEAS V. CUMBERLAND-DAUPHIN HARRISBURG TRANSIT AUTHORITY: t/ d / b / a CAPITAL AREA TRANSIT : and NORMA TOTTEN NO.2005-6738 Subpoena to Produce Documents or Things for Discovery Pursuant to Rule 4009.22 To: Records Custodian, Sanjiv H Naidu MD (Name of Person or Entity) Within twenty (20) days after the service of this subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED ADDENDUM-at Rawle_ & Henderson LLP, 240 N. Third St.,9th Floor, Harrisburg PA 17101 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: Date: [SEAL] Name: Gary N. Stewart, Esquire Rawle & Henderson LLP 240 N.31-d St.,9th Floor Address: Harrisburg,PA 17101 Telephone : 717-234-7700 Supreme Court ID#: 67353 Attorney for: Defendants 4357242-1 BY THE COURT: RIDER TO SUBPOENA Any and all records and radiology films, including but not limited to: ambulance call reports, transport reports, doctor's notes, nurses' notes, consultation reports, notes of other office and medical personnel, history notes, hand-written notes, and typed notes, electronic data including electronic data stored in a retrieval system, office records, billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, radiology reports, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment rendered at any time to: Darraine Jones, 4125 Spring Valley Road, Harrisburg, PA 17109 and formerly of 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1381958-1 CERTIFICATE OF AUTHENTICITY FROM: DR. SANJIV H. NAIDU RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Title Print Name Date 1381958-1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DARRAINE JONES CUMBERLAND COUNTY COURT OF COMMON PLEAS V. CUMBERLAND-DAUPHIN : HARRISBURG TRANSIT AUTHORITY: t/ d/ b/ a CAPITAL AREA TRANSIT : and NORMA TOTTEN NO.2005-6738 Subpoena to Produce Documents or Things for Discovery Pursuant to Rule 4009.22 To: Records Custodian, The Friendship Center (Name of Person or Entity) Within twenty (20) days after the service of this subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED ADDENDUM-at Rawle & Henderson LLP, 240 N. Third St.,9th Floor, Harrisburg PA 17101 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: Date: 3'L-Ll [SEAL] Name: Gary N. Stewart, Esquire Rawle & Henderson LLP 240 N.3rd St.,9th Floor Address: Harrisburg,PA 17101 Telephone: 717-234-7700 Supreme Court ID#: 67353 Attorney for: Defendants 4357242-1 BY THE COURT: RIDER TO SUBPOENA Any and all records including but not limited to: Membership documents; attendance records; list of equipment used; exercise classes taken; billing statements, payment records, health insurance claim forms, correspondence, correspondence from attorney to Deponent, correspondence from Deponent to attorney, Patient questionnaire, Patient information sheet, memoranda, index cards, medical records, medical reports, prescription slips, and any other records, reports, records stored at an off-site facility, and any other documentation relating to any examination, consultation, care or treatment or membership status regarding: Darraine Jones, 4125 Spring Valley Road, Harrisburg, PA 17109 and formerly of 641 S. 29th Street, Harrisburg, PA 17111 DOB: 1/12/60 SS#: 100-52-4550 1381958-1 CERTIFICATE OF AUTHENTICITY FROM: THE FRIENDSHIP CENTER RE: DARRAINE JONES DOB: 1/12/60 SS#: 100-52-4550 I am the Custodian of Records for the above-named deponent. I hereby declare under the penalty of perjury under the laws of the United States of America that a thorough search of our files was made in answer to the Records Subpoena attached hereto, and that the documents provided herein represent a full and complete response to the documents requested in the aforesaid Subpoena. I further declare under the penalty of perjury under the laws of the United States of America that the attached documents are true and correct copies of the originals retained by our office. Signature Print Name Title Date 1381958-1 CERTIFICATE OF SERVICE I hereby certify that on today's date I served a true and correct copy of the foregoing Notice of Intent to Serve Additional Subpoenas, by first-class mail, postage prepaid, upon all attorneys of record, addressed as follows: Karl J. Januzzi, Esquire SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Attorney for plaintiff RAWLE & HENDERSON LLP By: Gary . Stewart, Esquire Attorney for Defendants, Gary N. Stewart, Esquire David Chludzinski, Esquire Attorney for Defendants, Cumberland-Dauphin- Harrisburg Transit Authority t/d/b/a Capital Area Transit and Norma Totten Date: /c 9/ / 4357229-1 Davi( ID. Buell- Prothonotary Office =�' f _r-fDU�7)fng' - �um6 errand County,�������an� ' -`'rk''~-'-n` --Q SoCicitor 73e CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH BY THE COURT, DAVID D. BUELL