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Home My WebLink About01-5373IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 0/o ~'3 '(3 ~,;,O Civil Action- ( ) Law ( ) Equity Plaintiff(s) & Defendant)s) & Address(es) Address(es) PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue writ of summons in the above-captioned action. ~// Writ of Summons shall be issued and forwarded to ( ) Attorney (~'~her~ff Name/Address / Telephone No. of Attorney Supreme Court ID No. WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMIvlENCED AN ACTION AGAINST YOU. ~ //~ ,,x~.~,.,_ .-~.~.' Date: ( ) Check here ifreveme is issued for additional information. Prothonotary ~ , t by ~.~ ~ ~.~.~.~ Deputy THOMAS, THOMAS & HAFER, LLP By: Jeffrey B. Rettig, Esquire Identification No. 19616 305 North Front Street P.O. Box 999 Han~sburg, PA 17108-0999 (717) 255-7639 Attorney for Defendant LORI COGLEY DOYLE, Plaintiff V. ANDREW CHARLES STRONG, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 01-5373 CIVIL ACTION - LAW ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of Jeffrey B. Rettig, Esquire, and Thomas, Thomas & Hafer, LLP on behalf of Defendant Andrew Charles Strong in the above-captioned matter. Respectfully submitted, THOMAS, THOMAS & HAFER, LLP JeTB. 'g, --squire d CERTIFICATE OF SERVICE I do hereby cert~ that I sent a true and correct copy of the foregoing document to all counsel of record by placing a copy of the same in the United States first-class mail, postage prepaid, addressed as follows: Lori Cogley Doyle 4516 Crooked Hill Road Harrisburg, PA 17110 By: THOMAS, THOMAS & HAFER, LLP l~.Ul~ettig, Esquire(~ THOMAS, THOMAS & HAFER, LLP By: Jeffrey B. Rettig, Esquire Identification No. 19616 305 North Front Street P. 0. Box 999 Harrisbun2, PA 17108-0999 (717) 255-7639 Attorney for Defendant LORI COGLEY DOYLE, Plaintiff V. ANDREW CHARLES STRONG, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 01-5373 CIVIL ACTION - LAW PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Kindly issue a Rule on Plaintiff to file a Complaint in the above case within twenty (20) days of service of said Rule, or suffer a judgment of non pros pursuant to Pa.R.C.P. 1037(a). DATE: lO/Iq/or THOMAS, THOMAS & HAFER, LLP NOW, Prothonotary RULE TO FILE COMPLAINT ,2001, RULE ISSUED AS ABOVE. Deputy CERTIFICATE OF SERVICE I do hereby certify that I sent a true and correct copy of the foregoing document to all counsel of record by placing a copy of the same in the United States first-class mail, postage prepaid, addressed as follows: Lori Cogley Doyle 4516 Crooked Hill Road Harrisburg, PA 17110 Date: By: THOMAS, THOMAS & HAFER, LLP THOMAS, THOMAS & HAFER, LLP By: Jeffrey B. Rettig, Esquire Identification No. 19616 305 North Front Street P. Oo Box 999 Harrisburg, PA 17108-0999 (717) 255-7639 Attorney for Defendant LORI COGLEY DOYLE, : : Plaintiff : : V, : : ANDREW CHARLES STRONG, : : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 01-5373 CIVIL ACTION - LAW NOTICE OF INTENTION TO FILE PRAECIPE FOR ENTRY OF JUDGMENT OF NON PROS AND NOW, comes Andrew Charles Strong, by and through his attorneys, Thomas, Thomas & Hafer, LLP, to notify Plaintiff of his intention to file a Praecipe for Entry of Judgment of Non Pros in ten (10) days and state as follows: 1. This case was initiated by filing a Writ of Summons by Plaintiff on or about September 14, 2001. 2. A Rule to File a Complaint was obtained and served upon Plaintiff on October 26, 2001. 3. Plaintiff has not yet filed a Complaint and more than twenty days has elapsed since the service of the Rule to File a Complaint. 4. This Notice of Intention to File a Praecipe for Entry of Judgment of Non Pros is being served on Plaintiff as indicated on the Certificate of Service and permits Plaintiff ten days in which to cure her failure to file a Complaint. If a Complaint is not filed within the next ten days, a Praecipe for Entry of Judgment of Non Pros will be filed with the court and the case will be dismissed. THOMAS, THOMAS & HAFER, LLP By: ~~rey ~.~uire Date: /(/,2_/0 ! CERTIFICATE OF SERVICF I do hereby certify that I sent a true and correct copy of the foregoing document to all counsel of record by placing a copy of the same in the United States first-class mail, postage prepaid, addressed as follows: Lori Cogley Doyle 4516 Crooked Hill Road Harrisburg, PA 17110 Date: By: THOMAS, THOMAS & HAFER, LLP THOMAS, THOMAS & HAFER, LLP By: Jeffrey B. Ret#g, Esquire Identification No. 19616 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7639 Attorney for Defendant LORI COGLEY DOYLE, : : Plaintiff : : V. : .. ANDREW CHARLES STRONG, : : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 01-5373 CIVIL ACTION - LAW AND NOW, comes the Defendant, by his attorneys, Thomas, Thomas & Hafer, LLP, and files this Praecipe for Entry of Judgment of Non Pros, pursuant to Pa. R.C.P. 1037(a) based on the following considerations: 1. This case was initiated by the filing of a Writ of Summons by Plaintiff on or about September 14, 2001. 2. On October 23, 2001, the Court issued a Rule to File Complaint upon Plaintiff. 3. On October 26, 2001, counsel for Defendant served the executed Rule to File Complaint on Plaintiff which allowed Plaintiff twenty (20) days within which to file a Complaint. A copy of the correspondence transmitting the Rule is attached hereto and marked as Exhibit "A". 4. On November 21,2001, counsel for Defendant served Plaintiff with the Pa. R.C.P. 237.1 (a)(2) Notice Of Intent to Take a Non Pros. A copy of said "Notice" is attached hereto and marked as Exhibit "B". 5. To date, no Complaint has been filed by the Plaintiff in this action, which is in violation of Pa. R.C.P. 1037(a). WHEREFORE, Defendant respectfully requests your Honorable Court to enter a Judgment of Non Pros against Plaintiff, and discontinue this action without costs or judgment to Defendant for Plaintiff's failure to file a Complaint in this action pursuant to the Pennsylvania Rules of Civil Procedure. THOMAS, THOMAS & HAFER, LLP J~!~ I~. Rettig, Esquir~X' Exhibit A JOSEPH P. HAFER JAMES K. THOMAS, 1[ ROBERTSON B. TAYLOR JEFFREY B. RETTIG PETER J. CURRY R. BURKE McLEMORE. JR. EDWARD H. JORDAN, JR. C. KENT PRICE RANDALL G. GALE DAVID L SCHWALM PETER J. SPEAKER DOUGLAS B, MARCELLO PAUL J. DELLASEGA SARAH W. AROSELL EUGENE N. McHUGH OF COUNSEL JAMES K. THOMAS THOMAS, THOMAS & HAFER, LLP ATTORNEYS AT LAW 305 NORTH FRONT STREET SIXTH FLOOR RO. BOX 999 HARRISBURG, PA 17108 (717) 237-7100 FAX (717) 237-7105 WRITER'S DIRECT DiAL NUMBER (717) 255-7639 JBR@tthlaw.com October 26, 2001 STEPHEN E. GEDULDIG KAREN S. COATES TODD B. NARVOL JAMES J. DODD-O DANIEL L. GRILL JOHN J. McNALLY, Ill KEVIN C. McNAMARA BROOKS R. FOLAND JONATHAN C. DEISHER JOHN FLOUNLACKER JOHN T. HUSKIN, JR. MICHELE J. THORP CLAUDIO J. DIPAOLO STEPHANIE L. HERSPERGER HUGH P. O'NEILL, 111 W. DARREN POWELL DRUMMOND B. TAYLOR VIA CERTIFIED MAIL Lori Cogley Doyle 4516 Crooked Hill Road Harrisburg, PA 17110 RE: Doyle v. Strong Dear Ms. Doyle: Enclosed is a Rule to File a Complaint in this matter. Please respond accordingly. Thank you. Yours very truly, THOMAS, THOMAS & HAFER, LLP JBR/ees Enclosure By: Jeffrey B. Rettig LEHIGH VALLEY OFFICE: 3400 BATH PIKE, SUITE 201, BETHLEHEM, PA 1801? (610) 868-1675 FAX (610) 868-1702 · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: 2. Articie Number [] Agent [] Addressee ~d Mail [] Express Mail [] Return Receipt for Merchandise [] Insured Mail [] C.O.D. Restricted Delivery? (Extra Fee) [] Yes m=,S Form/3811, Mar. ch 2~.01 Domestic Return Receipt THOMAS, THOMAS & HAPER, LLP By: Jeffrey B. Rettig, Esquire Identification No. 19616 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7639 Attorney for Defendant LORI COGLEY DOYLE, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 01-5373 ANDREW CHARLES STRONG, Defendant CIVIL ACTION - LAW PRAEClPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Kindly issue a Rule on Plaintiff to file a Complaint in the above case within twenty (20) days of service of said Rule, or suffer a judgment of non pros pursuant to Pa.R.C.P. 1037(a). DATE: lC/! 9/0¢ THOMAS, THOMAS & HAFER, LLP Jeffr,~ E~. Rettig, Esqui[/'} CoL/fisel for Defendant'" RULE TO FILE COMPLAINT TRUE COPY FROM RECORD in Testimony whereof, I here unto set my hand and the_s~lpf said Court at Carlisle, Pa. P~thon0tary ' ! ~ ,2001, RULE ISSUED AS ABOVE. Prothonotary (. -Deputy Exhibit B THOMAS, THOMAS & HAFER, LLP By: Jeffrey B. Rettig, Esquire Identification No. 19616 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7639 Attorney for Defendant LORI COGLEY DOYLE, Plaintiff V. ANDREW CHARLES STRONG, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 01-5373 CIVIL ACTION - LAW NOTICE OF INTENTION TO FILE PRAECIPE FOR ENTRY OF JUDGMENT OF NON PROS AND NOW, comes Andrew Charles Strong, by and through his attomeys, Thomas, Thomas & Hafer, LLP, to notify Plaintiff of his intention to file a Preecipe for Entry of Judgment of Non Pros in ten (10) days and state as follows: 1. This case was initiated by filing a Writ of Summons by Plaintiff on or about September 14, 2001. 2. A Rule to File a Complaint was obtained and served upon Plaintiff on October 26, 2001. 3. Plaintiff has not yet filed a Complaint and more than twenty days has elapsed since the service of the Rule to File a Complaint. 4. This Notice of Intention to File a Praecipe for Entry of Judgment of Non Pros is being served on Plaintiff as indicated on the Certificate of Service and permits Plaintiff ten days in which to cure her failure to file a Complaint. If a Complaint is not filed within the next ten days, a Prae¢ipe for Entry of Judgment of Non Pros will be filed with the court and the case will be dismissed. THOMAS, THOMAS & HAFER, LLP /¢Yeffrey B. Rettig,~..~quire Date: /[/2-/0 t CERTIFICATE OF SERVICE I do hereby certify that I sent a true and correct copy of the foregoing document to all counsel of record by placing a copy of the same in the United States first-class mail, postage prepaid, addressed as follows: Lori Cogley Doyle 4516 Crooked Hill Road Harrisburg, PA 17110 Date: By: THOMAS, THOMAS & HAFER, LLP J~-~y B, Rettig, Es~ro CERTIFICATE OF SERVICE I do hereby certify that I sent a true and correct copy of the foregoing document to all counsel of record by placing a copy of the same in the United States first-class mail, postage prepaid, addressed as follows: Lori Cogley Doyle 4516 Crooked Hill Road Harrisburg, PA 17110 THOMAS, THOMAS & HAFER, LLP THOMAS, THOMAS & HAFER, LLP By: Jeffrey B. Ret#g, Esquire Identification No. 19616 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7639 Attorney for Defendant LORI COGLEY DOYLE, Plaintiff V. ANDREW CHARLES STRONG, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 01-5373 CIVIL ACTION -LAW NOTICE OF ENTRY OF JUDGMENT OF NON PRO,~ TO: Lori Cogley Doyle 4516 Crooked Hill Road Harrisburg, PA 17110 Jeffrey B. Rettig, Esquire P.O. Box 999 Harrisburg, PA 17108-0999 Please be advised that a judgment of non pros has been entered against Plaintiff and in favor of the Defendant Andrew Charles Strong in the above matter. Prothonotary "' ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COGLEY DOYLE Vs. STRONG NO. 015373 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 JEFFREY B RETTIG, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 12/13/01 JEFFREY B RETTIG, ESQUIRE ATTN: CAROL LANDIS 305 N FRONT ST 6TH F HARRISBURG, PA 17108 717-255-7237 ATTORNEY FOR DEFENDANT SHOULD BE ~DDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3581 INC. By: Mercedes Feeney File #: M281290 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COGLEY DOYLE Vs. STRONG No. 015373 TO: LORI COGLEY DOYLE NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 11/20/01 JEFFREY B RETTIG, ESQUIRE ATTN: CAROL LANDIS 305 N FRONT ST 6TM F HARRISBURG, PA 17108 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3581 INC. By: Mercedes Feeney Enc(s): Copy of Counsel File ~: M281290 subpoena(s) return card ~TH OF LORI COGLEY DOYLE VS. ANDREW CHARLES STRONG File No. 2001 5373 SUBPOENA TO PRCOUCE DOOJMENTS OR THINGS FOR D I SO)VERY PURSUANT TO RULE 4009.22 TO: DR MATTHEW BOLAND (Na~e of Person o~ Entity) within twenty (20) days afte~ service of this subpoena, you a~e o~de~ed by the court to prc~uce the following d~t~ or things: **SEE ATTACHED ~nn~r~r~** at M~DTC~L LR~AT, ~RODUCTIONS INC_494Q DISSTON ST PHILA PA 19135 (Address) ~. You n~y deliver or mail legib]e copies of the documents or.produce things r~ques[ed b~ this subpoena, togethe~ with the certificate Of .~,~liance, to the~party:mak~n9 thiz request at the address listed above. You have the right to seek in advance the rea~onabl~ cost of prepa~in9 th6 copies or producin9 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 orde~- o.~,oelling you to cu,~ly with it. THIS SUBPOENA WAS ISSUED AT THE RE(i~JEST OF THE FOLLCWING PERSON: TELEPHONE: SUPRI~E CCURT I D .~ ATTORNEY FOR: 305 N FRONT ST BOX .......... ... 17108 (215) 335-3212 DEFEND~NT DATE.: ~2[13/01 · ~l of the ~x~rt BY THE COURT: Prothonotary/O]el~k, Civil DiVisio~. ~ / O~puty (Elf. 7/97) ADDENDUM TO SUBPOENA COGLEY DOYLE Vs. STRONG No. 015373 CUSTODIAN OF RECORDS FOR: DR NIATTHEWBOLAND **SEE ATTACHED ADDENDUM** PERTAINING TO: NAME: LORI COGLEY DOYLE ADDRESS: DATE OF BIRTH: 05/26/58 SSAN: 195503814 MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN [ ] RECORDSAREATTACHED HERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NODOCUMENTSAVA1LABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERLAND M281290-01 Authorized signature for DR MATTHEW BOLAND *** SIGN AND RETURN THIS PAGE *** MEDICAL LEGAL REPRODUCTIONS, INC. Main Office 4940 Disston Street Philadelphia, Pa. 19135 Phone: (215) 335-3212 Fax: (215) 338-:~980 E-mail Address: legal@medleg, com Jefferson Bldg., Suite 926 1015 Chestnut Street Philadelphia, Pa. 19107 COMPLETE COPES OF ANY AND ALL RECORDS IN MEDICAL FILE, INCLUDING BUT NOT LIMITED TO, ANY AND ALL RECORDS, CORRESPONDENCE, FILES AND MEMORANDUMS, PROGRESS NOTES, CLINIC NOTES, INPATIENT AND/OR OUTPATIENT RECORDS, RADIOLOGICAL REPORTS, HAAIDWRITTEN NOTES, BILLING AND PAYMENT RECORDS RELATING TO P. NY EXAMINATION, INPATIENT AND/OR OUTPATIENT CONSULTATION, CARE OR TREATEMENT, ETC. CRAIG A. KUHN, Plaintiff C.A.R.S. PROTECTION PLUS, INC., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01--5¢-J'~9 CIVIL TERM ol - CIVIL ACTION LAW REPLY TO NEW MATTER 17. Denied. Plaintiff sets forth a legal claim upon which relief can be granted. 18. Denied. Improper previous repairs were not made to the vehicle, and if they were, those repairs did not void the warranty. 19. Denied. Plaintiff's claim is covered under the terms and conditions of the warranty contract. Denied. The claims complained of by Plaintiff are covered by the terms of 20. the warranty. 21. limitations. Denied. Plaintiffs action was filed within the applicable statute of Respectfully submitted, O'BRIEN, BARIC & SCHERER Michael A. Scherer, Esquire I.D. # 61974 17 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 mas.dlrlgenllt/kuhnlnewmatter, rep VERIFICATION The statements in the foregoing Reply To New Matter are based upon information which has been assembled by my attorney in this litigation. The language of the statements is not my own. I have read the statements; and to the extent that they are based upon information which I have given to my counsel, they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsifications to authorities. CERTIFICATE OF SERVICE I hereby certify that on December 1'7 , 2001, I, Jennifer S. Lindsay, secretary to Michael A. Scherer, Esquire, did serve a copy of the Reply To New Matter, by first class U.S. mail, postage prepaid, to the party listed below, as follows: David A. Regoli, Esquire 2300 Freeport Road, Suite 10 New Kensington, Pennsylvania 15068 IN THF COURT OF COMMON PLEAS OF CUMBERLAND COUNTY DOYLE Vs. STRONG NO. 015373 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 JEFFREY B RETTIG, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3.No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 12/20/01 JEFFREY B RETTIG, ESQUIRE 305 N FRONT ST 6TH FL PO BOX 999 HARRISBURG, PA 17108 717-237-7101 ATTORNEY FOR DEFENDANT ZNQUZRZES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3581 INC. By: Mar~edes Feeney File #: M281536 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY DOYLE STRONG Vs. No. 015373 TO: LORI COGLEY DOYLE NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 11/29/01 JEFFREY B RETTIG, ESQUIRE 305 N FRONT ST 6TH FL PO BOX 999 HARRISBURG, PA 17108 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO= MEDICAL LEGAL REPRODUCTIONS, 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3581 INC. By: Mercedes Feeney Eric (s): File #: Copy of subpoena(s) Counsel return card M281536 C~N~TH OF pI~VAN~ DOYLE : : Vs. : File No. STRONG . 015373 TO: MEDICAL BILLING REQUESTED SUBPOENA TO PRCOUC~ DOCU~NTS O~ TH I N~ FO~ DISOOVERY PURSUANT TO RULE 4009.22 TRAVELERS PROP & CAS CO, PO BOX 13485, RED/DING PA 19612-3485 (Name of Person or Entity) Within twenty (20) days afte~ service of this sub~oena, you. ere ordered by the court to prc~Juce the following doctme~ts or things: SEE ATTACHED ADD ND NI MEDICAL LE6;AL REPRODUCTIONS~A~.t~s%940 DISSTON ST., PHILA., PA You' 'imay deliver or mail legible copies of the documents o~ produce things requested bt -this subpoena, 'together with the certificate .iof cu,:~liance, to the party making this request at the address listed 'above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving 'this subpoena may seek a Court order' o.~,~elling yo~ to co,~ly with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: JEFFREY B RETTIG, ESQ ADO~ESS: 305 .... ,"',,,'~m om 6TH FL TELEPHONE: SUPREME COURT ID .~t ATTORNEY FOR: F~RISBURG, FA 17108 215-335-3212 DEFENDANT M281536-01 12 'O/Ol DATE: : :Seal of the Court BY THE COURT: P~othonota~¥~Cl~rk, Civil Division ! I Deputy (Elf. ~/97) ADDENDUM TO SUBPOENA DOYLE Vs. STRONG NO. 015373 CUSTODIAN OF RECORDS FOR: TRAVELERS PROP & CAS CO **SEE ATTACHED ADDENDUM** PERTAINING TO: NAME: ADDRESS: DATE OF BIRTH: SSAN: LORI COGLEY DOYLE 05/26/58 195503814 MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN [ ] [ ] P~CORDSAREAFFACHED HERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. NODOCUMENFSAV/JLABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERLAND M281536-01 Authorized signature for TRAVELERS PROP & CAS CO *** SIGN AND RETURN THIS PAGE *** MEDICAL LEGAL REPRODUCTIONS, INC Main Office 4940 Disston Street Philadelphia, Pa. 19135 Phone: (215) 335-3212 Fax: (215) 338-2980 E-mail Address: legal@medleg, com Jefferson Bldg., Suite 926 1015 Chestnut Street Philadelphia, Pa. 19107 LORI COGLEY DOYLE'S FIRST PARTY FILE INCLUDING BUT NOT LIMITED TO ANY AND ALL POLICIES, REFLECTING THE TORT SELECTION, ALL RECORDS, MEDICAL RECORDS AND REPORTS, CORRESPONDENCE, BILLING AND PAYPIENT RECORDS, INVESTIGATION REPORTS, STATEMENTS, PHOTOGRAPHS, SURVIELLANCE FOOTAGE, RESULTS OF ANY PEER REVIEW ORGANIZATION, RESULTS OF ANY INDEPENDENT MEDICAL EXAMINATION, FILE I-LANDER LOG NOTES, RESULTS OF ANY INDEX CHECKS, ETC. CLAIM/FILE #278 PP S3B 8769M. CO~N~TH OF pI~NtSYLVi~N-iA DOYLE : Vs. : Fi ]e No. : STRONG . 015373 SUBPOENA TO PROOUCE DOCUME~S OR THII, X~ .F..OR DISCOVERY PURSUANT TO RULE 4009.22 TO: TRA~q~LERS PROP & CAS CO, PO BOX 13485, REDJDING PA 19612-3485 AmmB3. r~ga'~R~W'RTTTNG DEPT (Na~le of Person o~ Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the fol ]owir~3 doccrnent.~ or th i ngs: SEE MEDICAL LEGAL REPRODUCTiONS(A~s~940 DISSTON ST., PHILA., PA You may deliver or mai] legible copies of the doccrnents or produce things requested b% this subPOena, together with the certificate df cc~,'~liance, to the pa~ty making thiz request at the address listed air,ye. You have the right to seek in advance the reasonabl~ cost of preparing the cc~ies or producing the things sought. If you fail t~ produce the docents or things required by this subpoena within twenty (20) days after its service, the party serving 'this subl~ena may seek a court orde~- O:x,~Jeiling you to cor,'~ty with it. TH I S SUBPOENA WAS ISSUED AT THE RE(;~JEST O~ THE FOLLGWI NG PERSON: NAME: .TRWWRRY B ~ETTIG, ESQ $~ 6TH FL TELEPHONE SUPREME COroT ATTORNEY FOR H3~P~RISBURG, PA 17108 215-335-3212 DEFEND~NT M281536-02 · 2/1 0101 DATE: '~eal of the Court BY THE COURT: Prothonotary/~:j~k, Oivil Division / / ~ty (Eff. 7/97) DOYLE Vs. STRONG ADDEND UM TO SUBPOENA No. 015373 CUSTODIAN OF RECORDS FOR: TRAVELERS PROP & CAS CO LORI COGLEY'S UNDERWRITING FILE. CLAIM/FILE #278 PPS 3B8769M PERTAINING TO: NAME: LORI COGLEY DOYLE ADDRESS: DATE OF BIRTH: 05/26/58 SSAN: 195503814 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN [ ] [ ] RECORDSAREATTACHED HERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. NO DOCUMENTS AVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERLAND M281536-02 Authorized signature for TRAVELERS PROP & CAS CO *** SIGN AND RETURN THIS PAGE *** C) ~ Cb