Loading...
HomeMy WebLinkAbout06-4716IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ot. - N7l 4 1. toil t f/L'?'? ®??@G? CIVIL ACTION - MEDICAL PROFESSIONAL LIABILITY ACTION PATRICIA A. DISNEY JASON J. LITTON, M.D. 509 Huntington Avenue 3399 Trindle Road Enola, PA 17025 Camp Hill, PA 17011 ORTHOPEDIC INSTITUTE OF PENNA. 3399 Trindle Road Camp Hill, PA 17011 Plaintiff Defendants versus PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue a writ of summons in the above-captioned action. X Writ of Summons shall be issued and forwarded to Michael J. Navitsky, Esquire Navitsky, Olson & Wisneski LLP 2040 Linglestown Road, Suite 303' Harrisburg, PA 17110 (717) 541-9205 (X) Sheriff Dated: Q-(q-06 ON, t4. W 35 c-n W rr . PATRICIA A. DISNEY, V. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNA. JASON J. LITTON, M.D., and ORTHOPEDIC INSTITUTE OF PENNSYLVANIA, Defendants No. 6to ?lU????r?'1 CIVIL ACTION - MEDICAL PROFESSIONAL LIABILITY ACTION JURY TRIAL DEMANDED ORIGIKA6 L WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT: YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. P'7 6X67 ?L - Pro onotary Dated: (c by Deputy THOMAS, THOMAS & HAFEP, LLP 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 Evan Black, Esquire Attorney I.D. 17884 (717) 441-7051 Hugh P. O'Neill, III, Esquire Attorney I.D. 69986 Attorneys for Defendants Jason J. Litton, M.D. and Orthopedic Institute of Pennsylvania PATRICIA A. DISNEY, Plaintiff vs. JASON J. LITTON, M.D. and ORTHOPEDIC INSTITUTE OF PENNSYLVANIA, Defendants To the Prothonotary: IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA CASE NO.: 06-4716 CIVIL TERM JURY TRIAL DEMANDED Kindly enter the appearance of the undersigned on behalf of the Defendants, Jason J. Litton, M.D. and Orthopedic Institute of Pennsylvania, relative to the above- captioned action. Respectfully submitted, Date: g -1`l O` Thomas, Thom 4, Hafer, LLP By: ?- - Evan Black, Esquire Atto 0 884 Hu III, Esquire Attorney I.D. No. 69986 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 Attorneys for Defendants CERTIFICATE OF SERVICE I, Joan L. Wolfe, employee of the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that a true and correct copy of the foregoing document was sent to the following counsel of record by placing a copy of same by First Class in the United States mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Michael Navitsky, Esquire Navitsky, Olson & Wisneski, LLP 2040 Linglestown Road Suite 303 Harrisburg, PA 17110 THOMAS, THOMAS & HAFER, LLP Date: ?- 3d -.fib Joan L. Wolfe h1 n r ,,, ?, mr >., u.. F f? '.^n ?+ ?"? C..; _ S" C_ .. Vi=a N -{ G-, O -n m? ?' T -, C?` _? -.. (,) ?"J \,?n ?` THOMAS, THOMAS & HAFER, LLP 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 Evan Black, Esquire Attorney I.D. 17884 (717) 441-7051 Hugh P. O'Neill, III, Esquire Attorney I.D. 69986 Attorneys for Defendants Jason J. Litton, M.D. and Orthopedic Institute of Pennsylvania PATRICIA A. DISNEY, Plaintiff VS. JASON J. LITTON, M.D. and ORTHOPEDIC INSTITUTE OF PENNSYLVANIA, Defendants IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA CASE NO.: 06-4716 CIVIL TERM JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY OF SAID COURT: Please issue a Rule on Plaintiffs to file a Complaint in the above case within twenty (20) days after service of the Rule or suffer a judgment of non pros. Respectfully submitted, Thom Th as Hafer, LLP r Date:, 31=? By: ?=> Evan Black,.,s? Attorney I.D. No. 17884 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 Attorneys for Defendants PATRICIA A. DISNEY, Plaintiff VS. JASON J. LITTON, M.D. and ORTHOPEDIC INSTITUTE OF PENNSYLVANIA, Defendants IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA CASE NO.: 06-4716 CIVIL TERM JURY TRIAL DEMANDED RULE TO FILE COMPLAINT TO: Patricia Disney c/o Michael Navitsky, Esquire Navitsky, Olson & Wisneski, LLP 2040 Linglestown Road Suite 303 Harrisburg, PA 17110 You are hereby directed to file a Complaint against Defendant within twenty (20) days or non pros seq. reg. Prothonotary DATED: SIP, F+ !r 4. CERTIFICATE OF SERVICE I, Joan L. Wolfe, employee of the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that a true and correct copy of the foregoing document was sent to the following counsel of record by placing a copy of same by First Class in the United States mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Michael Navitsky, Esquire Navitsky, Olson & Wisneski, LLP 2040 Linglestown Road Suite 303 Harrisburg, PA 17110 Date: l ? / , N- THOMAS, THOMAS & HAFER, LLP f Joan L. Wolfe ,, ?_.a ` ? __, c..'? ? , 7 s ?, , .. ? -- `tt i ?. ..,;, t S CASE NO: 2006-04716 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF' CUMBERLAND DISNEY PATRICIA A VS LITTON JASON J MD ET AL RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon LITTON JASON J MD the DEFENDANT at 1050:00 HOURS, on the 23rd day of August , 2006 at 3399 TRINDLE ROAD CAMP HILL, PA 17011 BONNIE SHEARER, ADMIN ASST by handing to ADULT IN CHARGE a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff ' 13 Costs: So Answers: Docketing 18.00 Service 13.20 Postage .39 Surcharge 10.00 R. Thomas Kline .00 41.59;/ 08/24/2006 NAVITSKY OLSON Wq- NESKI Sworn and Subscibed to By: before me this day Deputy Sheriff of A.D. ' CASE NO: 2006-04716 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF' CUMBERLAND DISNEY PATRICIA A VS LITTON JASON J MD ET AL RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon ORTHOPEDIC INSTITUTE OF PENNA DEFENDANT the , at 1050:00 HOURS, on the 23rd day of August , 2006 at 3399 TRINDLE ROAD CAMP HILL, PA 17011 by handing to BONNIE SHEARER, ADMIN ASST. ADULT IN CHARGE a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 6.00 Service .00 f' Affidavit .00 ?'., p ?. Surcharge 10.00 R. Thomas Kline ^n 16.001/ 08/24/2006 a??y'pL NAVITSKY OLSON W NE KI Sworn and Subscibed to By: before me this day Deputy Sheriff of A. D. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA 0 11/-% f" ftAj 8171 Z U COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-4716 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/09/2006 MCS on behalf of P/ ZLAC Attorney for DEFENDANT R1.20 133-H DE11-0650462 34430-LO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ROBERT P. LONERGAN, M.D. MEDICAL, BILLING, AND X-RAY(S) THE ARL INGTON GROUP MEDICAL, BILLING, AND X-RAY(S) HERSHEY MEDICAL CENTER MEDICAL RECORDS HERSHEY MEDICAL CENTER BILLING ONLY HERSHEY MEDICAL CENTER X-RAY ONLY HERSHEY MEDICAL CENTER MEDICAL, BILLING, AND X-RAY(S) TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 09/19/2006 CC: EVAN BLACK, ESQ. 819-61175 Any questions regarding this matter, contact R1.16S 133-H MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-0342136 34430-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY VS. JASON J. LITTON, M.D. AND ORTHOPEDIC File No. 06-4716 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ROBERT P LONERGAN, M.D. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER**** at The MCS Groun Inc., 1601 Market Street Suite 800 Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK, ES ADDRESS: 305 N. FRONT STF HARRISBURG. PA 17108 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: 6o BY T COURT: f? Proth otary/Clerk, vil DiIs ion Deputy Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ROBERT P. LONERGAN, M.D. 207 HOUSE AVENUE SUITE 105 CAMP HILL, PA 17011 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING ALL XRAYS OF THE KNEES Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: XXX-XX-5265 Date of Birth: 06-03-1941 R1.16S 133-H SU10-0643772 34430-LO1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA Rte: tr ? ? +kf . of t ?.... k 4 ?> s _.u COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-4716 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ES certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/09/2006 MCS on behalf of EVAN BLACK,?Q.? Attorney for DEFENDANT I R1.20 133-H DE11-0650463 34430-L02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ROBERT P. LONERGAN, M.D. MEDICAL, BILLING, AND X-RAY(S) THE ARL INGTON GROUP MEDICAL, BILLING, AND X-RAY(S) HERSHEY MEDICAL CENTER MEDICAL RECORDS HERSHEY MEDICAL CENTER BILLING ONLY HERSHEY MEDICAL CENTER X-RAY ON LY HERSHEY MEDICAL CENTER MEDICAL, BILLING, AND X-RAY(S) TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 09/19/2006 CC: EVAN BLACK, ESQ. - 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY VS. JASON J. LITTON, M.D. AND ORTHOPEDIC File No. 06-4716 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for THE ARLINGTON GROUP (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc.. 1601 Market Street, Suite 800 Philadelphia- PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ESQ. ADDRESS: 305 N. FRONT ST F .T P.O. BOX 999 HARRISBURG. PA 17108 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: { dG.? BY TH COURT: ?z Prot notary/ erk, ivil ivision Deputy Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: THE ARLINGTON GROUP P.O. BOX 6507 HARRISBURG, PA 17112 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDE COPY OF ALL XRAYS OF THE KNEES Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: XXX-XX-5265 Date of Birth: 06-03-1941 R1.16S 133-H SU10-0643774 34430-LO2 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA A f r* J(/AJj? kk pt ?? f,?g ? COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-4716 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ES certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/09/2006 MCS on behalf of Attorney for DEFENDANT R1.20 133-H DE11-0650464 34430-L03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ROBERT P. LONERGAN, M.D. MEDICAL, BILLING, AND X-RAY(S) THE ARLINGTON GROUP MEDICAL, BILLING, AND X-RAY(S) HERSHEY MEDICAL CENTER MEDICAL RECORDS HERSHEY MEDICAL CENTER BILLING ONLY HERSHEY MEDICAL CENTER X-RAY ON LY HERSHEY MEDICAL CENTER MEDICAL, BILLING, AND X-RAY(S) TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 09/19/2006 CC: EVAN BLACK, ESQ. 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY vs. JASON J. LITTON, M.D. AND ORTHOPEDIC File No. 06-4716 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for 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 RIDER **** at The MCS Group, Inc., 1601 Market Street, Suite 800. Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK, ES ADDRESS: 305 N_ FRONT STF TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Q6 [.? BY THE OURT: Protho otary/C vil D' ision Deputy Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR HERSHEY MEDICAL CENTER MEDICAL RECORDS 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: 188-32-5265 Date of Birth: 06-03-1941 R1.16S 133-H SU10-0643776 34430-LO3 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA Plt? l /° l r p: e PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PATRICIA A. DISNEY TERM, CUMBERLAND -VS- CASE NO: 06-4716 JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/09/2006 MCS on behalf of I §K BLACK, S o Attorney for DEFENDANT R1.20 133-H DE11-0650465 34430-L04 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ROBERT P. LONERGAN, M.D. MEDICAL, BILLING, AND X-RAY(S) THE ARLINGTON GROUP MEDICAL, BILLING, AND X-RAY(S) HERSHEY MEDICAL CENTER MEDICAL RECORDS HERSHEY MEDICAL CENTER BILLING ONLY HERSHEY MEDICAL CENTER X-RAY ONLY HERSHEY MEDICAL CENTER MEDICAL, BILLING, AND X-RAY(S) TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 09/19/2006 CC: EVAN BLACK, ESQ. 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 9103 (215) 246-0900 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY VS. JASON J. LITTON, M.D. AND ORTHOPEDIC File No. 06-4716 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for 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 RIDER **** at The MCS Groin. Inc.. 1601 Market Street, Suite 800. Philadelphia- PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ES ADDRESS: 305 N. FRONT STF TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: A:',V4. BY THE COURT: Prothonotary/C , ivil ivision Deputy Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER BILLING DEPT. 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all billing, insurance claims, payments, outstanding and/or delinquent invoices, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: XXX-XX-5265 Date of Birth: 06-03-1941 R1.16S 133-H SU10-0643778 34430-L04 CERTIFICATE IN THE MATTER OF: PATRICIA A. DISNEY PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 01 'if ?--l t tf t: COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 06-4716 JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/09/2006 MCS on behalf of ?G?-BLAC Q. . -? Attorney for DEFENDANT R1.20 133-H DE11-0650466 34430-L05 a COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ROBERT P. LONERGAN, M.D. MEDICAL, BILLING, AND X-RAY(S) THE ARLINGTON GROUP MEDICAL, BILLING, AND X-RAY(S) HERSHEY MEDICAL CENTER MEDICAL RECORDS HERSHEY MEDICAL CENTER BILLING ONLY HERSHEY MEDICAL CENTER X-RAY ON LY HERSHEY MEDICAL CENTER MEDICAL, BILLING, AND X-RAY(S) TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 09/19/2006 CC: EVAN BLACK, ESQ. 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY VS. JASON J. LITTON, M.D. AND ORTHOPEDIC File No. 06-4716 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for 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 RIDER **** at The MCS Groun, Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ESO. ADDRESS: 305 N. FRONT STREET P.O. BOX 999 HARRISBURG. PA 17108 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE C URT: _ja Prothonotary/Clerk, Div' on Deputy -gg ---'J q a" Date: Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER RADIOLOGY DEPT. 500 UNIVERSITY DRIVE HERSHEY, PA 19182 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING RADIOLOGY RECORDS/INVENTORY OF ALL KNEE X-RAYS Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: 188-32-5265 Date of Birth: 06-03-1941 I R1.16S 133-H SU10-0643780 34430-L05 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA k ? ? 1' k `is ?w1 COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-4716 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/09/2006 MCSon behalf of E/???AN B?I,ACK, AES Attorney for DEFENDANT R1.20 133-H DE11-0650467 34430-L06 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ROBERT P. LONERGAN, M.D. MEDICAL, BILLING, AND X-RAY(S) THE ARL INGTON GROUP MEDICAL, BILLING, AND X-RAY(S) HERSHEY MEDICAL CENTER MEDICAL RECORDS HERSHEY MEDICAL CENTER BILLING ONLY HERSHEY MEDICAL CENTER X-RAY ONLY HERSHEY MEDICAL CENTER MEDICAL, BILLING, AND X-RAY(S) TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 09/19/2006 CC: EVAN BLACK, ESQ. 819-61175 MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY VS. JASON J. LITTON, M.D. AND ORTHOPEDIC File No. 06-4716 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for 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 RIDER**** at The MCS Grown Inc 1601 Market Street Suite 800 Phiiladelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK ES ADDRESS: 305 N. FRONT STF TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY T O T: Proth otaryl r Ci Division Date: Seal of the Court Deputy EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR HERSHEY MEDICAL CENTER DEPT. OF ORTHO. & REHAB. 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING RADIOLOGY RECORDS/INVENTORY OF ALL KNEE X-RAYS Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: XXX-XX-5265 Date of Birth: 06-03-1941 R1.16S 133-H SU10-0643782 34430-L06 C`J f?3 -? t ? .? . ---d . ? ._..... ?_,... ? ' ?,' _.,.?. i Y- , i .... . 1 ..-.» : ? _ .....5 ._ ? THOMAS, THOMAS & HAFER, LLP 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 Evan Black, Esquire Attorney I.D. 17884 (717) 441-7051 Hugh P. O'Neill, III, Esquire Attorney I.D. 69986 Attorneys for Defendants Jason J. Litton, M.D. and Orthopedic Institute of Pennsylvania PATRICIA A. DISNEY, Plaintiff IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA V. JASON J. LITTON, M.D. and ORTHOPEDIC INSTITUTE OF PENNSYLVANIA, CASE NO.: 064716 CIVIL TERM JURY TRIAL DEMANDED Defendants NOTICE TO PLEAD TO: Plaintiff c/o Michael J. Navitsky, Esquire Navitsky, Olson & Wisneski, LLP 2040 Linglestown Road, Suite 303 Harrisburg, PA 17110 You are hereby notified that you are required to respond to the enclosed New Matter within thirty (30) days of service or judgment may be entered against you. Date: U Thomas, Thomas & Hafer, L - By an &e< Esquire Attorney I.D. No. 17884 Hugh P. O'Neill, III, Esquire Attorney I.D. No. 69986 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 Attorneys for Defendants THOMAS, THOMAS & HAFER, LLP 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 Evan Black, Esquire Attorney I.D. 17884 (717) 441-7051 Hugh P. O'Neill, III, Esquire Attorney I.D. 69986 Attorneys for Defendants Jason J. Litton, M.D. and Orthopedic Institute of Pennsylvania PATRICIA A. DISNEY, Plaintiff V. JASON J. LITTON, M.D. and ORTHOPEDIC INSTITUTE OF PENNSYLVANIA, Defendants IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA CASE NO.: 06-4716 CIVIL TERM JURY TRIAL DEMANDED DEFENDANTS' ANSWER AND NEW MATTER TO PLAINTIFF'S COMPLAINT AND NOW, come Defendants, Jason J. Litton, M.D., and Orthopedic Institute of Pennsylvania, by and through their attorneys, Thomas, Thomas, and Hafer, LLP, and hereby files this Answer and New Matter to Plaintiffs Complaint as follows: 1. Denied. After reasonable investigation, Answering Defendants are without sufficient knowledge or information to form an opinion or belief as to the truth or falsity of the allegations contained therein. All allegations are placed at issue and strict proof thereof is demanded at the time of trial. 2. Admitted. 3. Denied as stated. To the contrary, Dr. Litton is board certified in the field of orthopedic surgery. 4. Admitted. 5. Denied as stated. To the contrary, Defendant Orthopedic Institute of Pennsylvania is a Pennsylvania professional corporation with offices in Camp Hill, Cumberland County, Pennsylvania. 6. Admitted in part; denied in part. It is only admitted that Defendant Dr. Litton was a shareholder of Defendant Orthopedic Institute of Pennsylvania. All other allegations are specifically denied. Moreover, all other allegations are denied as conclusions of law and pursuant to Pa.R.C.P. 1029(e). All allegations are placed at issue and strict proof thereof is demanded at time of trial. 7. Admitted in part; denied in part. It is only admitted that Ms. Disney was a patient of Dr. Litton and that Dr. Litton performed surgery on Ms. Disney on September 13, 2004. By way of further answer, all other allegations are denied pursuant to Pa.R.C.P. 1029(e). All allegations are placed at issue and strict proof thereof is demanded at time of trial. 8. Denied. It is specifically denied that Dr. Litton used a tibial compartment that was too big and that there was a 4-5 mm. overhang and that it was cemented in place with an 2 uneven base. To the contrary, Dr. Litton acted within the requisite standard of care at all times relevant. By way of further answer, all allegations are generally denied pursuant to Pa.R.C.P. 1029(e). All allegations are placed at issue and strict proof thereof is demanded at time of trial. 9. Denied. The allegations contained in this paragraph are denied pursuant to Pa.R.C.P. 1029(e). All allegations are placed at issue and strict proof thereof is demanded at the time of trial. 10. Denied. Rather, the medical records speak for themselves. By way of further answer, all allegations are denied as legal conclusions and are further generally denied pursuant to Pa.R.C.P. 1029(e). All allegations are placed at issue and strict proof thereof is demanded at time of trial. 11. Denied. The allegations contained in this paragraph are denied pursuant to Pa.R.C.P. 1029(e). All allegations are placed at issue and strict proof thereof is demanded at the time of trial. 12. Admitted in part; denied in part. It is only admitted that Plaintiff's counsel produced an expert report to defense counsel. By way of further answer, all other allegations are denied pursuant to Pa.R.C.P. 1029(e). All allegations are placed at issue and strict proof thereof is demanded at the time of trial. COUNT I Patricia A. Disney v. Jason J. Litton, M.D. 13. Answering Defendant incorporates his responses to Paragraphs 1-12 of this Complaint as if set forth herein at length. 3 14.-26. Denied. All allegations of negligence, as described in the corresponding paragraphs of Plaintiff's Complaint, as well as allegations of causation are specifically denied as if all times relevant Dr. Litton acted within the requisite standard of care. All allegations are denied as conclusion of law and pursuant to Pa.R.C.P. 1029(e). All allegations are placed at issue and strict proof thereof is demanded at the time of trial. WHEREFORE, Answering Defendant demand judgments in his favor and against Plaintiff including costs. COUNT II Patricia A. Disney v. Orthopedic Institute of Pennsylvania 27. Answering Defendant incorporates its responses to Paragraphs 1-26 of Plaintiff's Complaint as if set forth herein at length. 28.-31. Denied. All allegations of negligence on the part of Defendant Litton as well as those of causation are specifically denied as Defendant Litton acted within the requisite standard of care at all times relevant. By way of further answer, it is only admitted that at all times relevant, Defendant Litton was a shareholder of Defendant Orthopedic Institute of Pennsylvania. By way of further answer, all other allegations are specifically denied, denied as conclusions of law, and/or generally denied pursuant to Pa.R.C.P. 1029(e). All allegations are placed at issue and strict proof thereof is demanded at the time of trial. WHEREFORE, Answering Defendant demands judgment in its favor and against all the parties together with costs. 4 NEW MATTER 32, Defendants incorporate Paragraphs 1-31 of this Answer as if set forth below. 33. Plaintiff's Complaint fails to state a claim upon which relief can be granted. 34. Plaintiff's claims are barred by the applicable statute of limitations 42 Pa. C.S.A. §5524. 35. Defendants at all times material hereto, acted in a careful, reasonable, and prudent manner consistent with the required standard of care. 36. Insofar as Defendants or any person for whom he is or may be vicariously liable, elected a treatment modality which is recognized as proper, but may differ from another appropriate treatment modality, then Answering Defendants raise the "two schools of thought" defense. 37. Plaintiff assumed the risk of medical treatment rendered. 38. Plaintiff's claims are barred, limited or reduced by the Pennsylvania Comparative Act, 42 Pa. C.S.A. §7102. 39. If Plaintiff's suffered injuries as alleged, such allegations being specifically denied, Plaintiff's injuries were caused by persons, entities, occurrences, instrumentalities or events unrelated to and not under the control of Defendants. 40. In the event that it is determined that Defendants were negligent with regard to any of the allegations contained in and with respect to the Plaintiff's Complaint, said allegations being specifically denied, discovery may establish that said negligence was superseded by the intervening negligent acts of other persons, parties and/or organizations other than Defendants 5 and over whom Defendants had no control, right of control, or responsibility and, therefore, Defendants are not liable. 41. The injuries and/or damages alleged to have been sustained by the Plaintiff were not proximately caused by Defendants. 42. Any acts or omissions of Defendants alleged to constitute negligence were not the substantial causes or factors of the subject incident and/or did not result in any injuries alleged by Plaintiff. 43. Plaintiff's injuries and losses, if any, were not caused by the conduct or negligence of Defendants, but rather were caused by pre-existing medical conditions and causes beyond the control of Defendants, and therefore Plaintiff may not recover against Defendants. 44. Plaintiff's claims, the existence of which are specifically denied by Defendants, may be reduced and/or limited by any collateral source of compensation and/or benefit in accordance with the Pennsylvania Supreme Court decision in Moorhead v. Crozier-Chester Medical Center. 45. Defendants are entitled to and assert all defenses on limitations and damages which are available to it under the Health Care Services Malpractice Act, 40 Pa. C.S.A. §1301.1.01. et seq. 46. Defendants raise all affirmative defenses of the Medical Care Availability and Reduction of Error (M'Care) Act a/k/a Act 13 of 2002 as a limitibar to Plaintiffs' claims. 47. Pa.R.C.P. 238 for delay damages is inapplicable under the facts of the present case and is unconstitutional and in violation of the Constitution of the United States and the Constitution of the Commonwealth of Pennsylvania. 6 48. For purposes of preserving the same, and subject to discovery, all or some of Plaintiff's claims may be barred pursuant to the affirmative defenses of release, offset, or accord and satisfaction. 49. Defendants incorporate the Stipulation of counsel in lieu of Preliminary Objections relating to Paragraphs 12 and 19 of Plaintiff's Complaint. WHEREFORE, Defendants demand judgment in their favor and against Plaintiff, together with costs. THOMAS, THOMAS & HAFER, LLP By: Evan Back, squi Attorney I.D. No. 17884 Hugh P. O'Neill, III, Esquire Attorney I.D. No. 69986 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 237-7100 Attorneys for Defendants Dated: (,,,/ 10/06 7 VERIFICATION I, Jason J. Litton, on my own behalf, and on behalf of Orthopedic Institute of Pennsylvania, hereby state and aver that I have read the foregoing Answer and New Matter to Plaintiff's Complaint which was drafted by my counsel. The factual statements contained therein are true and correct to the best of my knowledge, information and belief, although the language is that of my counsel, and, to the extent that the content of the foregoing document is that of counsel, I have relied upon counsel in making this Verification. This statement is made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false statements, I may be subject to criminal penalties. Date: % (`''' Jason n, 456646.1 CERTIFICATE OF SERVICE I, Betty K. Sheaffer, employee of the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that a true and correct copy of the foregoing document was sent to the following counsel of record by placing a copy of same by First Class in the United States mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Michael J. Navitsky, Esquire Navitsky, Olson & Wisneski, LLP 2040 Linglestown Road, Suite 303 Harrisburg, PA 17110 Attorney for Plaintiff Thomas, Thomas & Hafer, LLP r? Date: /I G A cxl ` Betty K. eaffer 456625.1 SON Lt; a 7 A fi r: ?Y} ? Elm 04 i - ^? W PATRICIA A. DISNEY, V. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNA No. 06-4716 Civil Term JASON J. LITTON, M.D., and CIVIL ACTION - MEDICAL ORTHOPEDIC INSTITUTE OF PROFESSIONAL LIABILITY ACTION PENNSYLVANIA, Defendants JURY TRIAL DEMANDED PLAINTIFF'S RESPONSE TO DEFENDANTS' NEW MATTER 32. Paragraph 32 of Defendants' New Matter requires no response. To the extent that any response is required, said allegations are denied and Plaintiff reiterates each paragraph and Count of her Complaint as if set forth herein. 33. The allegations constitute a conclusion of law to which no response is required. To the extent that any response is required, said allegation is denied. Plaintiff s Complaint states a claim upon which relief can be granted. 34. The allegations constitute a conclusion of law to which no response is required. To the extent that any response is required, said allegation is denied. Plaintiff s claims were timely filed and are therefore not barred by any statute of limitation. 35. Denied. Defendants were negligent and their negligence caused Plaintiff s harm as set forth in her Complaint. 36. The allegations constitute a conclusion of law to which no response is required. To the extent that any response is required, said allegations are denied. The "two schools of thought" defense does not apply to this case. 37. The allegations constitute a conclusion of law to which no response is required. To the extent that any response is required, said allegations are denied. Plaintiff did not assume the risk of the medical treatment rendered. 38. The allegations constitute a conclusion of law to which no response is required. To the extent that any response is required, said allegations are denied. Plaintiff's claims are not barred or limited or reduced by any comparative negligence. To the contrary, comparative negligence does not apply to this case. Plaintiff was not comparatively negligent. 39. The allegations constitute a conclusion of law to which no response is required. To the extent that any response is required, said allegations are denied. Defendants were negligent and their negligence caused Plaintiff's harm as set forth in her Complaint. 40. The allegations constitute a conclusion of law to which no response is required. To the extent that any response is required, said allegations are denied. Defendants were negligent and their negligence caused Plaintiff's harm as set forth in her Complaint. Defendants' negligence was not superceded by the intervening negligence of any other person. Rather, Defendants' negligence caused Plaintiff's harm as set forth in her Complaint. 41. The allegations constitute a conclusion of law to which no response is required. To the extent that any response is required, said allegations are denied. Defendants' negligence caused Plaintiff's harm as set forth in her Complaint. 42. The allegations constitute conclusions of law to which no response is required. To the extent that any response is required, said allegations are denied. Defendants' negligence caused Plaintiff's harm. 43. Denied. Defendants were negligent and their negligence caused Plaintiff's harm as set forth in her Complaint. Plaintiff's injuries were not caused in any fashion by any pre- existing medical condition. Rather, Defendants created the harmful medical condition by their negligence. 44. The allegations constitute conclusions of law to which no response is required. To the extent that any response is required, Plaintiff's claims will be governed by Pennsylvania law applicable to her case. 45. The allegations constitute conclusions of law to which no response is required. To the extent that any response is required, said allegations are denied. 46. The allegations constitute conclusions of law to which no response is required. To the extent that any response is required, said allegations are denied. Affirmative defenses not raised are waived. 47. The allegations constitute conclusions of law to which no response is required. To the extent that any response is required, said allegations are denied. Delay damages are applicable and appropriate under Pennsylvania Rules of Civil Procedure 238. 48. The allegations constitute a conclusion of law to which no response is required. To the extent that any response is required, said allegations are denied. Plaintiff's claims are not barred in any fashion by any affirmative defense or release or offset or accord and satisfaction. 49. Admitted and so stipulated. Respectfully submitted, NAVITSKY, OLSON & A -. A . Date: Michael J. J#itsky, Esquij I.D. No. 58W3 2040 Linglestown Road, Suite 303 Harrisburg, PA 17110 717/541-9205 Counsel for Plaintiff LLP COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS I, MICHAEL J. NAVITSKY, being duly sworn according to law, depose and say that I am counsel for Plaintiff, Patricia A. Disney, and I am authorized to make this affidavit on behalf of said Plaintiff, and verify that the facts set forth in the foregoing Answer to New Matter are true and correct to the best of my knowledge, information and belief, or are true and correct based on the information obtained from Plaintiff. Sworn and subscribed before me this day of Lc?Dlae ? , 2006. &Ik" "- &L4L Notary Public COMMUN*r-%;.Ia ur ?tNNSYL ANIA Notarial Seal Lois E. Stauffer, Notary Public C t of Harrisburg, Dauphin County 'y Commission Expires Mar. 28,2009 CERTIFICATE OF SERVICE I, Jessie K. Walsh, an employee of the law firm of Navitsky, Olson & Wisneski LLP, do hereby certify that I am this 26th day of October, 2006 serving a true and correct copy of Plaintiffs Response to Defendants' New Matter upon all counsel of record via postage prepaid first class United States mail addressed as follows: Evan Black, Esquire Thomas, Thomas & Hafer, LLP P.O. Box 999 305 North Front Street Harrisburg, PA 17101 I J Jessie K. Walsh C_ S ?=t y. ORIG a L PATRICIA A. DISNEY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA V. JASON J. LITTON, M.D., and ORTHOPEDIC INSTITUTE OF PENNSYLVANIA, NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 No. 06-4716 Civil Term CIVIL ACTION - MEDICAL : PROFESSIONAL LIABILITY ACTION Defendants JURY TRIAL DEMANDED PATRICIA A. DISNEY, V. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNA. JASON J. LITTON, M.D., and ORTHOPEDIC INSTITUTE OF PENNSYLVANIA, Defendants No. 06-4716 Civil Term CIVIL ACTION - MEDICAL PROFESSIONAL LIABILITY ACTION JURY TRIAL DEMANDED AVISO LISTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar acci6n dentro de veinte (20) dias a partir de la fecha en que recibi6 la demanda y el aviso. Usted debe presentar comparecencia escrita en persona o por abogado y presentar en la Corte por escrito sus defensas o sus objeciones a las demandas en su contra. Se le avisa que si no se defiende, el caso puede proceder sin usted y la Corte puede decidir en su contra sin mas aviso o notificaci6n por cualquier dinero reclamado en la demanda o por cualquier otra queja o compensaci6n reclamados por el Demandante. USTED PUEDE PERDER DINERO, O PROPIEDADES U OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE O NO CONOCE UN ABOGADO, VAYA O LLAME A LA OFICINA EN LA DIRECCION ESCRITA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 2 PATRICIA A. DISNEY, V. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA No. 06-4716 Civil Term CIVIL ACTION - MEDICAL PROFESSIONAL LIABILITY ACTION JASON J. LITTON, M.D., and ORTHOPEDIC INSTITUTE OF PENNSYLVANIA, Defendants JURY TRIAL DEMANDED COMPLAINT 1. Plaintiff, Patricia A. Disney, is an adult individual who resides in Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant, Jason J. Litton, M.D., is currently and was at all times relevant to this Complaint a physician licensed to practice medicine in the Commonwealth of Pennsylvania. 3. At all times relevant to this Complaint, Defendant Dr. Litton held himself out to the public as a specialist in orthopedic surgery. 4. Defendant Dr. Litton maintains a professional office in Camp Hill, Cumberland County, Pennsylvania. 5. Defendant, Orthopedic Institute of Pennsylvania, is a Pennsylvania corporation, professional corporation, partnership, association or business entity that maintains offices and facilities in Camp Hill, Cumberland County, Pennsylvania. 6. At all times relevant to this Complaint, Defendant Dr. Litton was a servant, agent, apparent agent, employee, partner, and/or stockholder of Defendant Orthopedic Institute of Pennsylvania and was acting in such capacity. 3 7. Plaintiff Ms. Disney was a patient of Defendant Dr. Litton for many years who, at the age of 65, underwent a total left knee replacement by Defendant Dr. Litton on September 13, 2004. 8. Unfortunately, Defendant Dr. Litton used a tibial component that was too big and there was 4-5 mm overhang and further cemented it in place with an uneven base. 9. Plaintiff Ms. Disney consequently experienced extreme pain and limited motion following this surgery and was seen by three different specialists in the area, all of whom agreed that the prosthesis was too big and misplaced and needed to be removed. 10. Plaintiff Ms. Disney therefore underwent a second surgery to completely remove the left knee prosthesis installed by Defendant Dr. Litton and replaced it with a prosthesis that was half the size on July 22, 2005. 11. In addition to requiring the second surgery to correct Dr. Litton's work, Ms. Disney has incurred related medical bills, past, present and future pain and suffering that she would otherwise not have experienced, additional surgical scarring and related pain and limitation relative to the second surgery, a loss of enjoyment of life and life's pleasures and therefore seeks all compensable damages cognizable under Pennsylvania law. 12. Plaintiff Ms. Disney has had the medical records and evidence evaluated by an expert in the field of orthopedic surgery who has authored and signed a medical expert report dated July 19, 2006, which has already been produced to defense counsel. The orthopedic surgeon who independently reviewed this material concluded that, "Dr. Litton deviated from standard of care by putting in a prosthesis that was several sizes too big and this created ligamentus and patellar tendon problems in Ms. Disney and requiring her to have a revision procedure." 4 COUNTI Patricia A. Disney v. Jason J. Litton, M.D. 13. Paragraphs one through twelve of this Complaint are incorporated herein by reference as if set forth at length. 14. Plaintiff's injuries as alleged herein are a direct and proximate result of the negligence of Defendant Dr. Litton as set forth herein. 15. As a direct and proximate result of Defendant Dr. Litton's negligence, he is liable to Plaintiff Ms. Disney for the injuries alleged herein. 16. Defendant Dr. Litton was negligent, and deviated from the appropriate standard of medical care by installing a prosthesis that was several sizes too big and this created ligamentus and patellar tendon problems in Plaintiff Ms. Disney that required her to have a revision procedure. 17. Defendant Dr. Litton failed to properly install the proper sized prosthesis during the September 13, 2004 surgery. 18. Defendant Dr. Litton failed to properly install the instrumentation in Plaintiff's knee during the September 13, 2004 surgery. 19. Based on information and belief and information presently available through Defendant Orthopedic Institute of Pennsylvania, Defendant Dr. Litton failed to take intraoperative x-rays during the September 13, 2004 surgery to confirm the proper size and placement of the prosthesis. If Defendant Orthopedic Institute of Pennsylvania is correct, then Defendant Dr. Litton was negligent in failing to do so as Plaintiff's medical expert opined that "a too large prosthesis which would have been noted at the time of surgery and 5 particularly seen on x-ray, that this deviation caused Ms. Disney to have the continued problems with her knee that required revision surgery." Therefore, failure to obtain intraoperative films constituted negligence and a deviation from the standard of care that directly and proximately caused Plaintiff's harm as alleged herein. 20. Defendant Dr. Litton failed, during the course of the September 13, 2004 surgery to make sure that the prosthesis placed in Plaintiffs knee was properly installed and adequately aligned. 21. If Defendant Dr. Litton utilized intraoperative imagining to insure the proper position of the prosthesis during the September 13, 2004 surgery, then he improperly read and/or interpreted any such intraoperative imaging and this constituted negligence and a deviation from the standard of medical care that caused all of Plaintiff's harm as alleged herein. 22. As a direct and proximate result of Defendant Dr. Litton's negligence as set forth above, Plaintiff Ms. Disney experienced a failed total left knee replacement, required additional surgery, suffers from excruciating and intractable knee pain and is faced with the prospect of having ongoing pain, limitation and disability created by Defendant's negligence and living with such pain and disability and limitation for the remainder of her life, and claim is made therefor. 23. As a direct result of the aforesaid negligence and consequent injuries, Plaintiff has incurred and will in the future incur medical and rehabilitative expenses that she otherwise would not have incurred and claim is made therefore. 24. As a direct result of the aforesaid negligence and consequent injuries, Plaintiff has undergone and will in the future undergo great physical and mental pain and suffering, 6 great inconvenience in carrying out her daily activities and a loss of life's pleasures and enjoyment and claim is made therefor. 25. As a direct result of the aforesaid negligence and injuries, Plaintiff has sustained scarring and disfigurement due to the subsequent surgery necessitated by Defendant's negligence and claim is made therefor. 26. As a direct result of the aforesaid negligence and injuries, Plaintiff has been and in the future will be subject to humiliation and embarrassment and claim is made therefor. WHEREFORE, Plaintiff, Patricia A. Disney, demands judgment against Defendant, Jason J. Litton, M.D., for compensatory damages in an amount in excess of Twenty-five Thousand ($25,000) Dollars, exclusive of interests and costs and in excess of any jurisdictional amount requiring compulsory arbitration. COUNT II Patricia A. Disney v. Orthopedic Institute of Pennsylvania 27. Paragraphs one through twelve of this Complaint and Count I are incorporated herein by reference as if set forth at length. 28. At all times relevant to this Complaint, Defendant Dr. Litton was a servant, agent, apparent agent, employee, stockholder, and/or partner of Defendant Orthopedic Institute of Pennsylvania and was acting in such capacity. 29. Plaintiff Ms. Disney's injuries as alleged herein were the direct and proximate result of the negligence of Defendant Orthopedic Institute of Pennsylvania's servant, agent, apparent agent, employee, stock holder and/or partner, Defendant Dr. Litton, as set forth in Count I of this Complaint. 7 30. As a direct result of the negligence of its servant, agent, apparent agent, employee, stock holder, and/or partner, Defendant Dr. Litton, as set forth in Count I of this Complaint, Defendant Orthopedic Institute of Pennsylvania is liable to Plaintiff for the injuries alleged herein. 31. Defendant Orthopedic Institute of Pennsylvania is vicariously liable for the negligence of its servant, agent, apparent agent, employee, stock holder, and/or partner, Defendant Dr. Litton, as alleged in Count I of this Complaint. WHEREFORE, Plaintiff, Patricia A. Disney, demands judgment against Defendant, Orthopedic Institute of Pennsylvania ,for compensatory damages in an amount in excess of Twenty-five Thousand ($25,000) Dollars exclusive of interests and costs and in excess of any jurisdictional amount requiring compulsory arbitration. Respectfully submitted, NAVITSKY, OLSON & WISNESKI LLP YV - -V Michael avitsky, ire I.D. No. 5803 2040 Linglestown Road, Suite 303 Harrisburg, PA 17110 717/541-9205 Counsel for Plaintiff Date: 8 VERIFICATION I, Patricia A. Disney, verify that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief. I understand that this Verification is made subject to the provisions of 18 Pa. C.S.A. §4904, relating to Patricia A. Disney unsworn falsification to authorities. CERTIFICATE OF SERVICE I, Jessie K. Walsh, an employee of the law firm of Navitsky, Olson & Wisneski LLP, do hereby certify that I am this 25th day of September, 2006 serving a true and correct copy of Plaintiffs Complaint upon all counsel of record via postage prepaid first class United States mail addressed as follows: Evan Black, Esquire Thomas, Thomas & Hafer, LLP P.O. Box 999 305 North Front Street Harrisburg, PA 17101 Jessie K. Walsh 9 C="r rim r N ??3 ~-i CD __j yG 7 PATRICIA A. DISNEY, V. Plaintiff JASON J. LITTON, M.D., and ORTHOPEDIC INSTITUTE OF PENNSYLVANIA, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA ORI C ' No. 06-4716 Civil Term CIVIL ACTION - MEDICAL PROFESSIONAL LIABILITY ACTION JURY TRIAL DEMANDED CERTIFICATE OF MERIT AS TO DEFENDANT JASON J. LITTON, M.D. I, Michael J. Navitsky, Esquire, certify that: L>cf! an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by this defendant in the treatment, practice or work that is the subject of the complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about the harm; OR ? the claim that this defendant deviated from an acceptable professional standard is based solely on allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard and an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about the harm; OR ? expert testimony of an appropriate licensed professional is unnecessary for prosecution of the claim against this defendant. Date: q ,j 61 bb Respectfully submitted, NAVITSKY, OLSON &ISNESKI LLP O_r Micliael J. a itsky, Es or I. D. No. S 3 2040 Linglestown Road, Suite 303 Harrisburg, PA 17110 717/541-9205 Counsel for Plaintiff CERTIFICATE OF SERVICE I, Jessie K. Walsh, an employee of the law firm of Navitsky, Olson & Wisneski LLP, do hereby certify that I am this 25th day of September, 2006 serving a true and correct copy of Plaintiffs Certificates of Merit upon all counsel of record via postage prepaid first class United States mail addressed as follows: Evan Black, Esquire Thomas, Thomas & Hafer, LLP P.O. Box 999 305 North Front Street Harrisburg, PA 17101 Jessie K. Walsh C -'j . X11 07, r-.3 . I C) C PATRICIA A. DISNEY, V. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, P : L ? No. 06-4716 Civil Term JASON J. LITTON, M.D., and CIVIL ACTION - MEDICAL ORTHOPEDIC INSTITUTE OF PROFESSIONAL LIABILITY ACTION PENNSYLVANIA, Defendants JURY TRIAL DEMANDED CERTIFICATE OF MERIT AS TO DEFENDANT ORTHOPEDIC INSTITUTE OF PENNSYLVANIA I, Michael J. Navitsky, Esquire, certify that: ? an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by this defendant in the treatment, practice or work that is the subject of the complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about the harm; OR the claim that this defendant deviated from an acceptable professional standard is based solely on allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard and an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about the harm; OR ? expert testimony of an appropriate licensed professional is unnecessary for prosecution of the claim against this defendant. Date: ?? 0 b Respectfully submitted, NAVITSKY, OLSON & WISNESKI LLP avitsky, uire Michael J ? ? 47 I.D. No. 03 2040 Linglestown Road, Suite 303 Harrisburg, PA 17110 717/541-9205 Counsel for Plaintiff N -?v I r T THOMAS, THOMAS & HAFER, LLP 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 Evan Black, Esquire Attorney I.D. 17884 (717) 441-7051 Hugh P. O'Neill, III, Esquire Attorney I.D. 69986 PATRICIA A. DISNEY, Plaintiff VS. JASON J. LITTON, M.D. and ORTHOPEDIC INSTITUTE OF PENNSYLVANIA, Defendants Attorneys for Defendants Jason J. Litton, M.D. and Orthopedic Institute of Pennsylvania IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA CASE NO.: 064716 CIVIL TERM JURY TRIAL DEMANDED STIPULATION OF COUNSEL IN LIEU OF PRELIMINARY OBJECTIONS The undersigned counsel hereby stipulate and agree that Plaintiffs Complaint shall be amended as follows in lieu of Defendants' filing Preliminary Objections: Paragraph 12 of Plaintiffs Complaint shall be amended to read as follows: "Plaintiff Ms. Disney has had the medical records and evidence evaluated by an expert in the field of orthopedic surgery who has authored and signed a medical expert report dated July 19, 2006, which has already been produced to defense counsel. Paragraph 19 of Plaintiffs Complaint shall be amended to read as follows: "Based on information and belief, and information presently available through Defendant Orthopedic Institute of Pennsylvania, Defendant Dr. Litton failed to take intraoperative x-rays during the September 13, 20041 torffirm the proper size and placement of the prosthesis. If Defendant Orthopedic Institute of Pennsylvania is correct, then Defendant Dr. Litton was negligent in failing to do so as Plaintiffs medical expert opined in his medical expert report dated July 19, 2006. Therefore, a failure to obtain intraoperative films constituted negligence and a deviation from the standard of care that directly and proximately caused Plaintiffs harm as alleged herein. Defendants shall file an Answer and New Matter to Plaintiffs Complaint. Respectfully submitted, NAVITSKY, OLSON & )IUISNE%I, LLP Michael J. Na , Et,uire Attorney 1. D. o.5 803 2040 Linglest n oad, Suite Harrisburg, PA 17110 (717) 541-9205 Counsel for Plaintiff THOMAS, THOMAS AND HAFER Evan Black- ,Esquire v Attorney i.D. No. 17884 Hugh P. O'Neill, III, Esquire Attorney I.D. No. 69986 305 North Front Street P.O. Box 69986 Harrisburg, PA 17108-0999 Counsel for Jason J. Litton, M.D., and Orthopedic Institute of Pennsylvania Dated: l 0/x7/,6 456599.1 1, 77 i n{' tP IN THE MATTER OF: PATRICIA A. DISNEY CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 06-4716 JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/23/2007 on b of E BLA Q. / !? Attorney for DEFENDAN R1.23 133-H DE11-0667304 34430-L07 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE .A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/03/2007 CC: EVAN BLACK, ESQ. - 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.16S 133-H DE02-0350944 34430-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY vs. JASON J. LITTON, M.D. AND ORTHOPEDIC File No. 06-4716 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ROBERT P LONERGAN M.D. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group Inc 1601 Market Street, Suite 800 Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK, ESO. ADDRESS: 305 N. FRONT STREET P.O. BOX 999 HARRISBURG. PA 17108 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant ,.SAN 2 3 2007 Date: 1?C . ?74 ,60& Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Divi (__?X 2• ( ?? Deputy 34430-07 • EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ROBERT P. LONERGAN, M.D. C/O DR JASON LITTON 3399 TRINDLE RD CAMP HILL, PA 17011 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING X-RAYS OF THE KNEES Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: XXX-XX-5265 Date of Birth: 06-03-1941 R1.16S 133-H SU10-0662648 34430-LO7 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA 4 0i 10 COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-4716 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/23/2007 (?S f EVAN BLACK, ` Attorney for DEFENDAN74 R1.23 133-H DE11-0667305 34430-L08 i 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ( Note: see enclosed list of locations TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/03/2007 CC: EVAN BLACK, ESQ. - 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 IR1.16S 133-H DE02-0350944 34430-COl >>> LOCATION LIST <<< LOCATION NAME RECORDS REQUESTED PAGE: 1 ROBERT P. LONERGAN, M.D. ARLINGTON GROUP HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER MSHMC ORTHOPAEDICS SHIRLEY A. ALBANO-ALUQUIN,MD HOLY REDEEMER HOSPITAL HOLY REDEEMER HOSPITAL HOLY REDEEMER HOSPITAL COMFORT CARE OF HOLY SPIRIT HARRISBURG HOSPITAL HARRISBURG HOSPITAL HARRISBURG HOSPITAL SUSQUEHANNA INTERNAL MED. ASSO JAGADEESH K. MOOLA, M.D. FREDERICKSON OUTPATIENT MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS BILLING ONLY X-RAY ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS & BILLING OTHER MEDICAL HOSPITAL OTHER BILLING X-RAY ONLY OTHER MEDICAL OTHER MEDICAL HOSPITAL OTHER BILLING X-RAY ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) OTHER MEDICAL AND X-RAY lz1.16S 133-H DE02-0350944 34430-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY VS. JASON J. LITTON, M.D. AND ORTHOPEDIC File No. 06-4716 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for THE ARLINGTON GROUP (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group Inc 1601 Market Street Suite 800 Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ES ADDRESS: 305 N. FRONT STf HARRISBURG. PA 17108 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Ci JAN 2 3 2007 22 26U? Deputy Date: L r Seal of the Court R1.16S 133-H EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ARLINGTON GROUP 805 SIR THOMAS COURT HARRISBURG, PA 17109 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING X-RAYS OF THE KNEES Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: XXX-XX-5265 Date of Birth: 06-03-1941 SU10-0662650 34430-LO8 CERTIFICATE COURT OF COMMON PLEAS PURSUANT TO RULE 4009.22 IN THE MATTER OF: PATRICIA A. DISNEY PREREQUISITE TO SERVICE OF A SUBPOENA TERM, CUMBERLAND -VS- CASE NO: 06-4716 JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/23/2007 CS be f Attorney for DEFEND R1.23 133-H DE11-0667306 34430-L09 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/03/2007 CC: EVAN BLACK, ESQ. - 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 JR1.16S 133-H DE02-0350944 34430-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY vs. JASON J. LITTON, M.D. AND ORTHOPEDIC File No. 06-4716 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for 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 RIDER **** at The MCS Groun Inc 1601 Market Street Suite 800, Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ESO. ADDRESS: 305 N. FRONT STREET P.O. BOX 999 HARRISBURG. PA 17108 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JAN 2 3 2007 Date: EC. .2 2, 2664, Seal of the Court 34430-09 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER MEDICAL RECORDS 500 UNIVERSITY DRIVE HERSHEY. PA 17033 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: 188-32-5265 Date of Birth: 06-03-1941 R1.16S 133-H SU10-0662652 34430-LO9 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-4716 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQj certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/23/2007 C MC?S n be of ' EV11A , ESQ . 44 Attorney for DEFENDANT R1.23 133-H DE11-0667307 34430-L10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations l TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/03/2007 CC: EVAN BLACK, ESQ. 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 IR1.16S 133-H DE02-0350944 34430-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY VS. JASON J. LITTON, M.D. AND ORTHOPEDIC File No. 06-4716 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for 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 RIDER **** at The MCS Group, Inc„ 1601 Market Street, Suite 800. PMladelphia_ PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ESO. ADDRESS: 305 N. FRONT STREET P.O. BOX 999 HARRISBURG. PA 17108 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant --??CJAN 2 3 2007 Date: _ i2'7 2ooL Seal of the Court BY T E COURT: Prothonotary/Clerk, Civi D' on Deputy 34430-10 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER BILLING DEPT. 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all billing, insurance claims, payments, outstanding and/or delinquent invoices, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: XXX-XX-5265 Date of Birth: 06-03-1941 R1.16S 133-H SU10-0662654 34430-L10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PATRICIA A. DISNEY TERM, CUMBERLAND -VS- CASE NO: 06-4716 JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/23/2007 beh of c , Q .-- Attorney for DEFENDANT J R1.23 133-H DE11-0667308 34430-Lll COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/03/2007 CC: EVAN BLACK, ESQ. 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 IR1.16S 133-H DE02-0350944 34430-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY vs. JASON J. LITTON, M.D. AND ORTHOPEDIC File No. 06-4716 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for 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 RIDER **** at The MCS Group. Inc, 1601 Market Street, Suite 800. Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ESO. ADDRESS: 305 N. FRONT STREE _HARRISBURG, PA 17108 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JAN 2 3 2007 Date: I)Ec- .?, -QaU to Seal of the Court Deputy BY T COURT: Prothonotary/Clerk, Civil Divi ' 34430-11 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER RADIOLOGY DEPT. 500 UNIVERSITY DRIVE HERSHEY, PA 19182 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING X-RAYS OF THE KNEES Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social security #: 188-32-5265 Date of Birth: 06-03-1941 R1.16S 133-H SU10-0662656 34430-Lll CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-4716 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/23/2007 M n be of CEV BLA , ESQ. Attorney for DEFEND T R1.23 133-H DE11-0667309 34430-L12 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/03/2007 CC: EVAN BLACK, ESQ. - 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 IR1.16S 133-H DE02-0350944 34430-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY vs. JASON J. LITTON, M.D. AND ORTHOPEDIC File No. 06-4716 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MSHMC ORTHOPAEDICS (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Gros, Inc.- 1601 Market Street. Suite 800 Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ESO. ADDRESS: 305 N. FRONT STREE HARRISBURG. PA 17108 TELEPHONE: (15) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, JAN 2 3 2007 Deputy Date: lorr `? .16/An Seal of the Court 34430-12 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MSHMC ORTHOPAEDICS HERSHEY MEDICAL CENTER 500 UNIVERSITY DR HERSHEY, PA 17033 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING KNEE X-RAYS Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: XXX-XX-5265 Date of Birth: 06-03-1941 R1.16S 133-H SU10-0662658 34430-L12 CERTIFICATE IN THE MATTER OF: PATRICIA A. DISNEY PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 06-4716 JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/23/2007 M ron be of S C EV B , ESQ. Attorney for DEFENDANT R1.23 133-H DE11-0667310 34430-L13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ( Note: see enclosed list of locations TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/03/2007 CC: EVAN BLACK, ESQ. - 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 JR1.16S 133-H DE02-0350944 34430-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY vs. JASON J. LITTON, M.D. AND ORTHOPEDIC File No. 06-4716 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for SHIRLEY A AL BANO-ALUOUIN MD (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group Inc.- 1601 Market Strreet Suite 800, Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ESQ. ADDRESS: 305 N. FRONT STREET P.O. BOX 999 HARRISBURG, PA 17108 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JAN 2 3 2007 Date: ? C- ';Z g Seal of the Court 34430-13 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SHIRLEY A. ALBANO-ALUQUIN,MD MSHMC RHEUMATOLOGY 500 UNIVERSITY DR HERSHEY, PA 17033 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical and billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: XXX-XX-5265 Date of Birth: 06-03-1941 R1.16S 133-H SU10-0662660 34430-L13 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-4716 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ES certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/23/2007 MC n beh of L?A&C' , ES . ` JOB 4 Attorney for DEFEND R1.23 133-H DE11-0667311 34430-L14 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/03/2007 CC: EVAN BLACK, ESQ. 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 IR1.16S 133-H DE02-0350944 34430-CO1 LOCATION NAME >>> LOCATION LIST <<< RECORDS PAGE: 1 ROBERT P. LONERGAN, M.D. MEDICAL, BILLING, AND X-RAY(S) ARLINGTON GROUP MEDICAL, BILLING, AND X-RAY(S) HERSHEY MEDICAL CENTER MEDICAL RECORDS HERSHEY MEDICAL CENTER BILLING ONLY HERSHEY MEDICAL CENTER X-RAY ONLY MSHMC ORTHOPAEDICS MEDICAL, BILLING, AND X-RAY(S) SHIRLEY A. ALBANO-ALUQUIN,MD MEDICAL RECORDS & BILLING HOLY REDEEMER HOSPITAL OTHER MEDICAL HOSPITAL HOLY REDEEMER HOSPITAL OTHER BILLING HOLY REDEEMER HOSPITAL X-RAY ONLY COMFORT CARE OF HOLY SPIRIT OTHER MEDICAL HARRISBURG HOSPITAL OTHER MEDICAL HOSPITAL HARRISBURG HOSPITAL OTHER BILLING HARRISBURG HOSPITAL X-RAY ONLY SUSQ13EHANNA INTERNAL MED. ASSO MEDICAL, BILLING, AND X-RAY(S) JAGADEESH K. MOOLA, M.D. MEDICAL, BILLING, AND X-RAY(S) FREDERICKSON OUTPATIENT OTHER MEDICAL AND X-RAY 16S 133-H DE02-0350944 34430-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY File No. 06-4716 vs. JASON J. LITTON, M.D. AND ORTHOPEDIC SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HOLY REDEEMER HOSPITAL, (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group Inc 1601 Market Street Suite 800, Philadebjhia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ESO. ADDRESS: 305 N. FRONT STREET P.O. BOX 999 HARRISBURG. PA 17108 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Di JAN 2 3 2007 Deputy Date: ,! L ? 2oLk' Seal of the Court 34430-14 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY REDEEMER HOSPITAL MEDICAL RECORDS 1648 HUNTINGDON PIKE MEADOWBROOK, PA 19046 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. ANY AND ALL RECORDS FROM 09/01/04 TO PRESENT Dates Requested: from: 09-01-2004 to the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: 188-32-5265 Date of Birth: 06-03-1941 'R1.16S 133-H SU10-0662662 34430-L14 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA 9e PURSUANT TO RULE 4009.22 IN THE MATTER OF: PATRICIA A. DISNEY COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA CASE NO: 06-4716 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/23/2007 EVAN BLA , ESQ. Attorney for DEFEND T R1.23 133-H DE11-0667312 34430-L15 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ) TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/03/2007 CC: EVAN BLACK, ESQ. - 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 IR1.16S 133-H DE02-0350944 34430-COl >>> LOCATION LIST <<< LOCATION NAME RECORDS REQUESTED PAGE: 1 ROBERT P. LONERGAN, M.D. MEDICAL, BILLING, AND X-RAY(S) ARLINGTON GROUP MEDICAL, BILLING, AND X-RAY(S) HERSHEY MEDICAL CENTER MEDICAL RECORDS HERSHEY MEDICAL CENTER BILLING ONLY HERSHEY MEDICAL CENTER X-RAY ONLY MSHMC ORTHOPAEDICS MEDICAL, BILLING, AND X-RAY(S) SHIRLEY A. ALBANO-ALUQUIN,MD MEDICAL RECORDS & BILLING HOLY REDEEMER HOSPITAL OTHER MEDICAL HOSPITAL HOLY REDEEMER HOSPITAL OTHER BILLING HOLY REDEEMER HOSPITAL X-RAY ONLY COMFORT CARE OF HOLY SPIRIT OTHER MEDICAL HARRISBURG HOSPITAL OTHER MEDICAL HOSPITAL HARRISBURG HOSPITAL OTHER BILLING HARRISBURG HOSPITAL X-RAY ONLY SUSQUEHANNA INTERNAL MED. ASSO MEDICAL, BILLING, AND X-RAY(S) JAGADEESH K. MOOLA, M.D. MEDICAL, BILLING, AND X-RAY(S) FREDERICKSON OUTPATIENT OTHER MEDICAL AND X-RAY .16S 133-H DE02-0350944 34430-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY VS. JASON J. LITTON, M.D. AND ORTHOPEDIC File No. 06-4716 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HOLY REDEEMER HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS GrojW, Inc.- 1601 Market Street Suite 800 Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ES ADDRESS: 305 N. FRONT STF TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JAN 2 3 2007 Date: >c r ? Cie Seal of the Court BY HE COURT: Prothonotary/Clerk, Civil Div' eputy 34430-15 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY REDEEMER HOSPITAL BILLING DEPT. 1648 HUNTINGDON PIKE MEADOWBROOK, PA 19046 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. DATES FROM 9/1/04 TO PRESENT Dates Requested: from: 09-01-2004 to the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: XXX-XX-5265 Date of Birth: 06-03-1941 R1.16S 133-H SU10-0662664 34430-L15 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA do? COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-4716 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/23/2007 SC?2n be o ? EVAN K, ESQ. Attorney for DEFEND T R1.23 133-H DE11-0667313 34430-LlG COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/03/2007 CC: EVAN BLACK, ESQ. 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 IR1.16S 133-H DE02-0350944 34430-COl >>> LOCATION LIST <<< LOCATION NAME RECORDS REQUESTED PAGE: 1 ROBERT P. LONERGAN, M.D. MEDICAL, BILLING, AND X-RAY(S) ARLINGTON GROUP MEDICAL, BILLING, AND X-RAY(S) HERSHEY MEDICAL CENTER MEDICAL RECORDS HERSHEY MEDICAL CENTER BILLING ONLY HERSHEY MEDICAL CENTER X-RAY ONLY MSHMC ORTHOPAEDICS MEDICAL, BILLING, AND X-RAY(S) SHIRLEY A. ALBANO-ALUQUIN,MD MEDICAL RECORDS & BILLING HOLY REDEEMER HOSPITAL OTHER MEDICAL HOSPITAL HOLY REDEEMER HOSPITAL OTHER BILLING HOLY REDEEMER HOSPITAL X-RAY ONLY COMFORT CARE OF HOLY SPIRIT OTHER MEDICAL HARRISBURG HOSPITAL OTHER MEDICAL HOSPITAL HARRISBURG HOSPITAL OTHER BILLING HARRISBURG HOSPITAL X-RAY ONLY SUSQUEHANNA INTERNAL MED. ASSO MEDICAL, BILLING, AND X-RAY(S) JAGADEESH K. MOOLA, M.D. MEDICAL, BILLING, AND X-RAY(S) FREDERICKSON OUTPATIENT OTHER MEDICAL AND X-RAY 16S 133-H DE02-0350944 34430-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY vs. JASON J. LITTON, M.D. AND ORTHOPEDIC File No. 06-4716 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HOLY REDEEMER HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group Inc., 1601 Market Street Suite 800, Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ESO. ADDRESS: 305 N. FRONT STREET P.O. BOX 999 HARRISBURG, PA 17108 TELEPHONE: (215) 246-0900 SUPREME COURT ID 4: ATTORNEY FOR: Defendant JAN 2 3 2007 Date: a"T? 00 L Seal of the Court BY COURT: Prothonotary/Clerk, Civi Di A.n Deputy 34430-16 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY REDEEMER HOSPITAL RADIOLOGY DEPARTMENT 1648 HUNTINGDON PIKE MEADOWBROOK, PA 19046 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING DIAGNOSTIC FILMS DATES FRON 9/1/04 TO PRESENT Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: from: 09-01-2004 to the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social security #: 188-32-5265 Date of Birth: 06-03-1941 R1.16S 133-H SU10-0662666 34430-L16 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA `'r3 COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-4716 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/23/2007 (S o k? f ? EVA? B K, ESQ. Attorney for DEFEN ANT 'R1.23 133-H DE11-0667314 34430-L17 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/03/2007 CC: EVAN BLACK, ESQ. - 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 IR1.16S 133-H DE02-0350944 34430-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY vs. File No. 06-4716 JASON J. LITTON, M.D. AND ORTHOPEDIC SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for COMFORT CARE OF HOLY SPIRIT (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 ER **** at The MCS Groun Inc 1601 Market Street. Suite 800 Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ES ADDRESS: 305 N. FRONT STF HARRISBURG, PA 17108 TELEPHONE: (215246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JAN 2 3 2007 Date: r _ aT?Ljb6 Seal of the Court 34430-17 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: COMFORT CARE OF HOLY SPIRIT VNA OF MECHANICSBURG PO BOX 309 CAMP HILL. PA 17011 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. ANY AND ALL RECORDS FROM 01/01/2003 TO PRESENT Dates Requested: from: 01-01-2003 to the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: XXX-XX-5265 Date of Birth: 06-03-1941 R1.16S 133-H SU10-0662668 34430-L17 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA s` I A ? COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-4716 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ES certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/23/2007 f n o EVAN ZE 61 Attorney for DEFEN T R1.23 133-H DE11-0667315 34430-L18 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/03/2007 CC: EVAN BLACK, ESQ. - 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 'R1.16S 133-H DE02-0350944 34430-CO1 >>> LOCATION LIST <<< LOCATION NAME RECORDS REQUESTED ROBERT P. LONERGAN, M.D. MEDICAL, BILLING, AND X-RAY(S) ARLINGTON GROUP MEDICAL, BILLING, AND X-RAY(S) HERSHEY MEDICAL CENTER MEDICAL RECORDS HERSHEY MEDICAL CENTER BILLING ONLY HERSHEY MEDICAL CENTER X-RAY ONLY MSHMC ORTHOPAEDICS MEDICAL, BILLING, AND X-RAY(S) SHIRLEY A. ALBANO-ALUQUIN,MD MEDICAL RECORDS & BILLING HOLY REDEEMER HOSPITAL OTHER MEDICAL HOSPITAL HOLY REDEEMER HOSPITAL OTHER BILLING HOLY REDEEMER HOSPITAL X-RAY ONLY COMFORT CARE OF HOLY SPIRIT OTHER MEDICAL HARRISBURG HOSPITAL OTHER MEDICAL HOSPITAL HARRISBURG HOSPITAL OTHER BILLING HARRISBURG HOSPITAL X-RAY ONLY SUSQUEHANNA INTERNAL MED. ASSO MEDICAL, BILLING, AND X-RAY(S) JAGADEESH K. MOOLA, M.D. MEDICAL, BILLING, AND X-RAY(S) FREDERICKSON OUTPATIENT OTHER MEDICAL AND X-RAY PAGE: 1 16S 133-H DE02-0350944 34430-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY VS. JASON J. LITTON, M.D. AND ORTHOPEDIC File No. 06-4716 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court. to, pmducz-the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Gm=- Inc 1601 Market Street, Suite 800 Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK, ESQ. ADDRESS: 305 N. FRONT STREET P.O. BOX 999 HARRISBURG. PA 17108 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant ,SAN 2 3 2007 Date: T ° Seal of the Court BY THE COURT: Prothonotary/Clerk, 34430-18 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL MEDICAL RECORDS 111 S. FRONT STREET HARRISBURG, PA 17101 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. MECIAL RECORDS DATES FROM 1/1/04 TO PRESENT Dates Requested: from: 01-01-2004 to the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: 188-32-5265 Date of Birth: 06-03-1941 R1.16S 133-H SU10-0662670 34430-L18 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA ( 1000% 9l COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-4716 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/23/2007 n b of C EV BLA E?¢:-' Attorney for DEFEND R1.23 133-H DE11-0667316 34430-L19 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/03/2007 CC: EVAN BLACK, ESQ. - 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 'R1.16S 133-H DE02-0350944 34430-CO1 LOCATION NAME ROBERT P. LONERGAN, M.D. ARLINGTON GROUP HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER MSHMC ORTHOPAEDICS SHIRLEY A. ALBANO-ALUQUIN,MD HOLY REDEEMER HOSPITAL HOLY REDEEMER HOSPITAL HOLY REDEEMER HOSPITAL COMFORT CARE OF HOLY SPIRIT HARRISBURG HOSPITAL HARRISBURG HOSPITAL HARRISBURG HOSPITAL SUSQUEHANNA INTERNAL MED. ASSO JAGADEESH K. MOOLA, M.D. FREDERICKSON OUTPATIENT >>> LOCATION LIST <<< RECORDS MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS BILLING ONLY X-RAY ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS & BILLING OTHER MEDICAL HOSPITAL OTHER BILLING X-RAY ONLY OTHER MEDICAL OTHER MEDICAL HOSPITAL OTHER BILLING X-RAY ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) OTHER MEDICAL AND X-RAY PAGE: 1 IR1.16S 133-H DE02-0350944 34430-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY vs. JASON J. LITTON, M.D. AND ORTHOPEDIC File No. 06-4716 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the-following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc., 1601 Market Street Suite 800 Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ESO. ADDRESS: 305 N. FRONT STREET P.O. BOX 999 HARRISBURG. PA 17108 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Civil JAN 2 3 200 Deputy Date: c- Y Seal of the Court 34430-19 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL BILLING RECORDS 111 S. FRONT STREET HARRISBURG, PA 17101 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. BILLING RECORDS FROM 1/1/04 TO PRESENT Dates Requested: from: 01-01-2004 to the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: 188-32-5265 Date of Birth: 06-03-1941 R1.16S 133-H SU10-0662672 34430-L19 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-4716 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ES certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/23/2007 5 oiPK, f o/f VAN ESQ. Attorney for DEFEN ANT R1.23 133-H DE11-0667317 34430-L20 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/03/2007 CC: EVAN BLACK, ESQ. - 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 16S 133-H DE02-0350944 34430-CO1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED ROBERT P. LONERGAN, M.D. MEDICAL, BILLING, AND X-RAY(S) ARLINGTON GROUP MEDICAL, BILLING, AND X-RAY(S) HERSHEY MEDICAL CENTER MEDICAL RECORDS HERSHEY MEDICAL CENTER BILLING ONLY HERSHEY MEDICAL CENTER X-RAY ONLY MSHMC ORTHOPAEDICS MEDICAL, BILLING, AND X-RAY(S) SHIRLEY A. ALBANO-ALUQUIN,MD MEDICAL RECORDS & BILLING HOLY REDEEMER HOSPITAL OTHER MEDICAL HOSPITAL HOLY REDEEMER HOSPITAL OTHER BILLING HOLY REDEEMER HOSPITAL X-RAY ONLY COMFORT CARE OF HOLY SPIRIT OTHER MEDICAL HARRISBURG HOSPITAL OTHER MEDICAL HOSPITAL HARRISBURG HOSPITAL OTHER BILLING HARRISBURG HOSPITAL X-RAY ONLY SUSQUEHANNA INTERNAL MED. ASSO MEDICAL, BILLING, AND X-RAY(S) JAGADEESH K. MOOLA, M.D. MEDICAL, BILLING, AND X-RAY(S) FREDERICKSON OUTPATIENT OTHER MEDICAL AND X-RAY 16S 133-H DE02-0350944 34430-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY vs. JASON J. LITTON, M.D. AND ORTHOPEDIC File No. 06-4716 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce.the.following.. _ documents or things: **** SEE ATTACHED RIDER **** at The MCS Group, Inc 1601 Market Street Suite 800 Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ES ADDRESS: 305 N. FRONT STI HARRISBURG. PA 17108 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY E COURT: Prothonotary/Clerk, Civi D' ' ton Deputy 34430-20 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL RADIOLOGY DEPT. 111 S. FRONT STREET HARRISBURG, PA 17105 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING DIAGNOSTIC FILMS FROM 1/1/2004 TO PRESENT Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: from: 01-01-2004 to the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: 188-32-5265 Date of Birth: 06-03-1941 R1.16S 133-H SU10-0662674 34430-L20 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY VS. JASON J. LITTON, M.D. AND ORTHOPEDIC File No. 06-4716 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for SUSQUEHANNA INTERNAL MED ASSO (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the. court to produce the following. documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc 1601 Market Street Suite 800 Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ES ADDRESS: 305 N. FRONT -M TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JAN 2 s 2007 Date: 1) 1P r ZZ (-v Seal of the Court BY T COURT: Prothonotary/Clerk, Civil Div' ' n Deputy 34430-21 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SUSQUEHANNA INTERNAL MED. ASSO 890 POPLAR CHURCH ROAD CAMP HILL, PA 17011 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING DIAGNOSTIC FILMS Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: XXX-XX-5265 Date of Birth: 06-03-1941 R1.16S 133-H SU10-0662676 34430-L21 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-4716 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/23/2007 M n b V ?of EV L , Attorney for DEFENDANT R1.23 133-H DE11-0667319 34430-L22 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/03/2007 CC: EVAN BLACK, ESQ. - 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 ,R1.16S 133-H DE02-0350944 34430-COl >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED ROBERT P. LONERGAN, M.D. MEDICAL, BILLING, AND X-RAY(S) ARLINGTON GROUP MEDICAL, BILLING, AND X-RAY(S) HERSHEY MEDICAL CENTER MEDICAL RECORDS HERSHEY MEDICAL CENTER BILLING ONLY HERSHEY MEDICAL CENTER X-RAY ONLY MSHMC ORTHOPAEDICS MEDICAL, BILLING, AND X-RAY(S) SHIRLEY A. ALBANO-ALUQUIN,MD MEDICAL RECORDS & BILLING HOLY REDEEMER HOSPITAL OTHER MEDICAL HOSPITAL HOLY REDEEMER HOSPITAL OTHER BILLING HOLY REDEEMER HOSPITAL X-RAY ONLY COMFORT CARE OF HOLY SPIRIT OTHER MEDICAL HARRISBURG HOSPITAL OTHER MEDICAL HOSPITAL HARRISBURG HOSPITAL OTHER BILLING HARRISBURG HOSPITAL X-RAY ONLY SUSQUEHANNA INTERNAL MED. ASSO MEDICAL, BILLING, AND X-RAY(S) JAGADEESH K. MOOLA, M.D. MEDICAL, BILLING, AND X-RAY(S) FREDERICKSON OUTPATIENT OTHER MEDICAL AND X-RAY :1.16S 133-H DE02-0350944 34430-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY vs. JASON J. LITTON, M.D. AND ORTHOPEDIC File No. 06-4716 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JAGADEESH K MOOLA M.D. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group Inc 1601 Market Street Suite 800, Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ESO. ADDRESS: 305 N. FRONT STREET P.O. BOX 999 HARRISBURG. PA 17108 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JAN 2 3 2007 Date: -,0? _ 2zz6e Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil iv' ' Deputy 34430-22 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JAGADEESH K. MOOLA, M.D. 890 POPLAR CHURCH ROAD STE. 409 CAMP HILL, PA 17011 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING DIAGNOSTIC FILMS Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social security #: XXX-XX-5265 Date of Birth: 06-03-1941 R1.16S 133-H SU10-0662678 34430-L22 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-4716 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/23/2007 IMCS-nn C b oAN 13 SQ. Attorney for DEFENDP?T R1.23 133-H DEll-0667320 34430-L23 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA COURT OF COMMON PLEAS TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20). days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/03/2007 CC: EVAN BLACK, ESQ. - 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 'R1.16S 133-H DE02-0350944 34430-COl >>> LOCATION LIST <<< LOCATION NAME ROBERT P. LONERGAN, M.D. ARLINGTON GROUP HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER MSHMC ORTHOPAEDICS SHIRLEY A. ALBANO-ALUQUIN,MD HOLY REDEEMER HOSPITAL HOLY REDEEMER HOSPITAL HOLY REDEEMER HOSPITAL COMFORT CARE OF HOLY SPIRIT HARRISBURG HOSPITAL HARRISBURG HOSPITAL HARRISBURG HOSPITAL SUSQUEHANNA INTERNAL MED. ASSO JAGADEESH K. MOOLA, M.D. FREDERICKSON OUTPATIENT RECORDS REQUESTED MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS BILLING ONLY X-RAY ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS & BILLING OTHER MEDICAL HOSPITAL OTHER BILLING X-RAY ONLY OTHER MEDICAL OTHER MEDICAL HOSPITAL OTHER BILLING X-RAY ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) OTHER MEDICAL AND X-RAY PAGE: 1 R133-H DE02-0350944 34430-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY vs. File No. 06-4716 JASON J. LITTON, M.D. AND ORTHOPEDIC SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for FREDERICKSON OUTPATIENT (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: --****SEE ATTACHED RIDER**** at The MCS ('Troup. Inc.. 1601 Market Street, Suite 80 Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ES ADDRESS: 305 N. FRONT STF TELEPHONE: _ 15) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JAN 2 3 2007 Date: 1 ? 2 1 1661.6 Seal of the Court BY T COURT: Prothonotary/Clerk, Ci4Di* De puty 34430-23 N EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: FREDERICKSON OUTPATIENT 2015 TECHNOLOGY PARKWAY MECHANICSBURG, PA 17050 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING DIAGNOSTIC FILMS FROM 01/01/2004 TO PRESENT Dates Requested: from: 01-01-2004 to the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: XXX-XX-5265 Date of Birth: 06-03-1941 R1.16S 133-H SU10-0662680 34430-L23 r.-r1 C7 ^C CERTIFICATE ORIGIA* PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PATRICIA A. DISNEY TERM, CUMBERLAND -VS- CASE NO: 06-4716 JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/12/2007 S on be f o VAN BLACK, ESQ. Attorney for DEFENDANT R1.42 105-N DE11 3 4 4 3 0- L 2 4 j"ONM bri I'll A r AS\1 ?C! O,Z :'I old 61 AON LODZ XO'd1C11?# Gw 3HI JO C OMNI(O NWE A L T H O F P E N N S Y L VAN I A COUNT Y O F C UMB E R L AND IN THE MATTER OF: COURT OF COMMON PLEAS PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/22/2007 CC: EVAN BLACK, ESQ. 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 1.41S 105-N DE02-0377035 3 4 4 3 0- C 0 1 >>> LOCATION LIST <<< PAGE LOCATION NAME RECORDS REQUESTED THE HETRICK CENTER WILLIAM PARRISH,MD CARDIN i& PHYSICAL THERAPY PA NEUROLOGICAL ASSOCIATES HEALTHSOUTH MEDICARE/HGSA AARP INTERGROUP CENTRAL PENN PHYSICAL THERPAY PA OPEN MRI FIRST CHOICE REHABILITATION MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, INSURANCE INSURANCE INSURANCE MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) 1.41S 105-N DE02-0377035 3 4 4 3 0- C 0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY VS. File No. 064716 JASON J. LITTON, M.D. AND ORTHOPEDIC SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for THE HETRT K ENTER (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 ATTAC D RIDER **** at The M CS .roan. Inc 1601 Market Street Suite 800, P ilad Whia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ES ADDRESS: 305 N_ FRONT cTt~ TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: s rothonotary/Clerk, C',61 Division N V .1 2 2007 Deputy Date: / p Seal of the Court 34430-24 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: THE HETRICK CENTER 6481 CARLISLE PIKE MECHANICSBURG, PA 17055 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. FILM INVENTORY Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: XXX-XX-5265 Date of Birth: 06-03-1941 L.41S 105-N SU10-0708872 34430-1.24 CERTIFICATE ORIGIAW PREREQUISITE TO SERVICE OF A SUBPOENA ?? PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PATRICIA A. DISNEY TERM, CUMBERLAND -VS- CASE NO: 06-4716 JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/12/2007 ` M S on beh of . EVAN BLACK, ESQ. Attorney for DEFENDANT 1.42 105-N DE11 34430-T-,25 COMMONWEALTH OF PENNSYLVAN I A COUNT Y O IF C UMB E R L AND IN THE MATTER OF: COURT OF COMMON PLEAS PATRICIA A. DISNEY TERM, -VS- CASE NO: 06-4716 JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ, intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/22/2007 CC: EVAN BLACK, ESQ. 819-61175 Any questions regarding this matter, contact .41S 105-N MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-0377035 3 4 4 3 0- C 0 1 >>> LOCATION LIST <<< PAGE LOCATION NAME RECORDS REQUESTED THE HETRICK CENTER WILLIAM PARRISH,MD CARDIN & PHYSICAL THERAPY PA NEUROLOGICAL ASSOCIATES HEALTHSOUTH MEDICAREIHGSA AARP INTERGROUP CENTRAL PENN PHYSICAL THERAPY PA OPEN MRI FIRST CHOICE REHABILITATION 41S 105-N MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, INSURANCE INSURANCE INSURANCE MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) DE02-0377035 3 4 4 3 0- C 0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY File No. 06-4716 VS. JASON J. LITTON, M.D. AND ORTHOPEDIC SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for WILLIAM P RRI H MD (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things:_ ****SEE ATTACHED RIDER**** at _ The MC4 Q=. Inc 1601 Market tree Suite 800, Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ES ADDRESS: 305 N. FRONT STT TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: " Prbthonotary/Clerk, Ci Division NOV 12 2007 p' Deputy Date: 10 ?llo?D'? Seal of the Court 34430-25 EXPLANATION OF TO: CUSTODIAN OF RECORDS FOR: WILLIAM PARRISH,MD 2150 NOLL DRIVE STE 200 LANCASTER, PA 17603 RE: 34430 PATRICIA A DISNEY REQUIRED RECORDS Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. FILM INVENTORY Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: XXX-XX-5265 Date of Birth: 06-03-1941 41S 105-N SU10-0708874 34430-1.25 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 ORIGINAL IN THE MATTER OF: COURT OF COMMON PLEAS PATRICIA A. DISNEY TERM, CUMBERLAND -VS- CASE NO: 06-4716 JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena ha.s been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/12/2007 ?n Wf E VAN BLACK, ESQ Attorney for DEFENDANT L.42 105-N DEll 3 4 4 3 0- L 2 6 C OMIVIONWE A L T H O F P E N N S Y L VAN I A COUNT Y O F C UMB E R L AND IN THE MATTER OF: COURT OF COMMON PLEAS PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations J TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/22/2007 MCS on behalf of CC: EVAN BLACK, ESQ. 819-61175 Any questions regarding this matter, contact 41S 105-N _EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-0377035 3 4 4 3 0- C 0 1 >>> LOCATION LIST <<< PAGE LOCATION NAME RECORDS REQUESTED THE HETRICK CENTER WILLIAM PARRISH,MD CARDIN & PHYSICAL THERAPY PA NEUROLOGICAL ASSOCIATES HEALTHSOUTH MEDICARE/HGSA AARP INTERGROUP CENTRAL PENN PHYSICAL THERPAY PA OPEN MRI FIRST CHOICE REHABILITATION 41S 105-N MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, INSURANCE INSURANCE INSURANCE MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) DE02-0377035 3 4 4 3 0- C O 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY File No. 06-4716 vs. JASON J. LITTON, M.D. AND ORTHOPEDIC SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records forR1?IN & PHYSI T. APY (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:- **** S_F.F ATTA D IDER **** at _ The MCS Gro1M Inc 1601 Market Street Suite 800- p ilad biaPA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ES ADDRESS: 305 N_ FRONT RTI; TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: s r thonota IClerk, Civi ivision NOV 122007 Date: _10 /Ilolb% Deputy Seal of the Court 34430-26 EXPLANATION OF TO: CUSTODIAN OF RECORDS FOR: CARDIN & PHYSICAL THERAPY 290 E. POMFRET ST. CARLISLE, PA 17013 RE: 34430 PATRICIA A DISNEY REQUIRED RECORDS Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. FILM INVENTORY Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: XXX-XX-5265 Date of Birth: 06-03-1941 .41S 105-N SU10-0708876 3 4 4 3 0- L 2 6 CERTIFICATE ORIGIM PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PATRICIA A. DISNEY TERM, CUMBERLAND -VS- CASE NO: 06-4716 JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/12/2007 CS on be 1 of ? EVAN BLACK, ESQ. Attorney for DEFENDANT 1.42 105-N DE11 3 4 4 3 0- L 2 7 COMLVIONWEALTH coip ii jai,. COUNT Y O F C UMB E R L AND IN THE MATTER OF: COURT OF COMMON PLEAS PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA [ Note: see enclosed list of locations ] TERM, CASE NO: 06-4716 TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ, intends to serve a subpoena identical to the one that is attached to- this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/22/2007 MCS on behalf of CC: EVAN BLACK, ESQ. 819-61175 Any questions regarding this matter, contact .41S 105-N EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-037.7035 3 4 4 3 0- C O 1 >>> LOCATION LIST <<< PAGE LOCATION NAME RECORDS REQUESTED THE HETRICK CENTER WILLIAM PARRISH.MD CARDIN & PHYSICAL THERAPY PA NEUROLOGICAL ASSOCIATES HEALTHSOUTH MEDICARE/HGSA AARP INTERGROUP CENTRAL PENN PHYSICAL THERPAY PA OPEN MRI FIRST CHOICE REHABILITATION .415 105-N MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, INSURANCE INSURANCE INSURANCE MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) DE02-0377035 3 4 4 3 0- C --O 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY File No. 06-4716 VS. JASON J. LITTON, M.D. AND ORTHOPEDIC SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PA NFi TR O I i A A (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at FMCS Groun Inc 1601 Market Street pit 800. P ilad pbia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ES ADDRESS: 305 N_ FROWT qTT, TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant NOV 12 2007 Date: I D 1!o , Seal of the Court BY THE COURT: &hnotary/Clerk Civil ivision ??jn L A!:!txp?' Deputy 34430-27 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PA NEUROLOGICAL ASSOCIATES 108 LOWTHER STREET HARRISVIEW PROF. CTR LEMOYNE, PA 17043 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. FILM INVENTORY Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: XXX-XX-5265 Date of Birth: 06-03-1941 L.41S 105-N SU10-0708878 34430-T-.27 CERTIFICATE ORIGIN& PREREQUISITE TO SERVICE OF A SUBPOENA 4W- PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PATRICIA A. DISNEY TERM, CUMBERLAND -VS- CASE NO: 06-4716 JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/12/2007 CS on be f of EVAN BLA K, ESQ.` Attorney for DEFENDANt- 42 105-N DE11 3 4 4 3 0- L 2 8 COMMONWEA L T 1A C )IF P E N N S Y L V AN I A COUNT Y O F C UMB E R L AND IN THE MATTER OF: COURT OF COMMON PLEAS PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/22/2007 CC: EVAN BLACK, ESQ. 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET 1/800 PHILADELPHIA, PA 19103 (215) 246-0900 41S 105-N DE02-0377035 3 4 4 3 0- 4--0 1 >>> LOCATION LIST <<< PAGE LOCATION NAME RECORDS REQUESTED THE HETRICK CENTER MEDICAL, BILLING, AND X-RAY(S) WILLIAM PARRISH,MD MEDICAL, BILLING, AND X-RAY(S) CARDIN & PHYSICAL THERAPY MEDICAL, BILLING, AND X-RAY(S) PA NEUROLOGICAL ASSOCIATES MEDICAL, BILLING, AND X-RAY(S) HEALTHSOUTH MEDICAL, BILLING, AND X-RAY(S) MEDICARE/HGSA INSURANCE AARP INSURANCE INTERGROUP INSURANCE CENTRAL PENN PHYSICAL THERPAY MEDICAL, BILLING, AND X-RAY(S) PA OPEN MRI MEDICAL, BILLING, AND X-RAY(S) FIRST CHOICE REHABILITATION MEDICAL, BILLING, AND X-RAY(S) .41S 105-N DE 02-0 377035 34430-C701 COMMONWEALTH.OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY VS. File No. 064716 JASON J. LITTON, M.D. AND ORTHOPEDIC SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HEALTHSOUTH (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 ATTA HED EDER **** at The MCS Grog Inc.. 1601 Market Street. Suite 800, Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ES ADDRESS: 305 N. FRONT SIT TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Vr6thonotary/Clerk, Ci 1 Division 112007 NOV Deputy Date: /D /it. Seal of the Court 34430-28 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HEALTHSOUTH 840 NORTH FRONT STREET WORMLEYSBURG, PA 17043 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. FILM INVENTORY Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: XXX-XX-5265 Date of Birth: 06-03-1941 41S 105-N SU10-0708880 3 4 4 3 0- L 2 8 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA ORIGIN& ---- - PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PATRICIA A. DISNEY TERM, CUMBERLAND -VS- CASE NO: 06-4716 JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/12/2007 S on beh Of EVAN BLACK, ESQ. Attorney for DEFENDANT' L.42 105-N DEll 3 4 4 3 0- L 2 9 C OMMONWE A L T H O F P'E N N S Y L VAN I A COUNT-k' 001F C TJMB E R L AND IN THE MATTER OF: COURT OF COMMON PLEAS PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR.DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to- this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/22/2007 CC: EVAN BLACK, ESQ. 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 .41S 105-N DE02-03717035 3 4 4 3 0- 4--0 1 >>> LOCATION LIST <<< PAGE LOCATION NAME RECORDS REQUESTED THE HETRICK CENTER WILLIAM PARRISH,MD CARDIN & PHYSICAL THERAPY PA NEUROLOGICAL ASSOCIATES HEALTHSOUTH MEDICARE/HGSA AARP INTERGROUP CENTRAL PENN PHYSICAL THERAAY PA OPEN MRI FIRST CHOICE REHABILITATION MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, INSURANCE INSURANCE INSURANCE MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) .41S 105-N DE02-0377035 3 4 4 3 0- C O 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY VS. JASON J. LMON, M.D. AND ORTHOPEDIC File No. 06-4716 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MEDICARF/HGSA (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER**** at The MCS Groun, Inc.. 1601 Market Street Suite 800, Philadelphia- PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ES ADDRESS: 305 N. FRONT STF TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant NOV 12 2007 Date: o pr/ Seal of the Court BY THE COURT: P f.11 s thonotary/Clerk, Ci Division Deputy (T U 34430-29 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MEDICARE/HGSA LEGAL SERVICES P. O. BOX 890700 CAMP HILL, PA 170890700 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all insurance records and PIP files, including but not limited to medical reports and/or records, claims, any and all correspondence, documentation supporting plaintiff's claim, payments including dates of payments, payee and reasons for payments, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: from: 01-01-2004 to the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: XXX-XX-5265 Date of Birth: 06-03-1941 _.41S 105-N SU10-0708882 34430-T-,29 CERTIFICATE ORIGINA .PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PATRICIA A. DISNEY TERM, CUMBERLAND -VS- CASE NO: 06-4716 JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/12/2007 f /imcs on b ?fo EVAN BLACK, ESQ. Attorney for DEFENDANT 1.42 105-N DE11 34430-1-m30 COMMONWEAIL- T14 OIP PE114 114 SYLVAN I A C O UN T Y O F C UMB E 13-1 IL -A, 1*4 E> IN THE MATTER OF: COURT OF COMMON PLEAS PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR.DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ, intends to serve a subpoena identical to the one that is attached to- this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/22/2007 CC: EVAN BLACK, ESQ. 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET 1/800 PHILADELPHIA, PA 19103 (215) 246-0900 .41S 105-N DE02-0377035 3 4 4 3 0- C 0 1 >>> LOCATION LIST <<< PAGE LOCATION NAME RECORDS REQUESTED THE HETRICK CENTER MEDICAL, BILLING, AND X-RAY(S) WILLIAM PARRISH,MD MEDICAL. BILLING. AND X-RAY(S) CARDIN & PHYSICAL THERAPY MEDICAL, BILLING, AND X-RAY(S) PA NEUROLOGICAL ASSOCIATES MEDICAL, BILLING, AND X-RAY(S) HEALTHSOUTH MEDICAL, BILLING, AND X-RAY(S) MEDICARE/HGSA INSURANCE AARP INSURANCE INTERGROUP INSURANCE CENTRAL PENN PHYSICAL THERPAY MEDICAL, BILLING, AND X-RAY(S) PA OPEN MRI MEDICAL, BILLING, AND X-RAY(S) FIRST CHOICE REHABILITATION MEDICAL, BILLING, AND X-RAY(S) .41S 105-N DE02-0377035 3 4 4 3 0- C O 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY File No. 064716 VS. JASON J. LITTON, M.D. AND ORTHOPEDIC SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for .CARP (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER**** at The MCS Troup. Inc.. 1601 Market tree Suite 800, P iladeWa PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ES ADDRESS: 305 N. FRONT STF TELEPHONE: , (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Pi6thonotary/Clerk, Civi ivision NOV 12 2007 // Date: JD 1(0/ 01 Deputy Seal of the Court 34430-30 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: AARP UNITED HEALTHCARE OPTIONS P.O. BOX 740819 ATLANTA, GA 30374 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. ID x{04695002212 Any and all insurance records and PIP files, including but not limited to medical reports and/or records, claims, any and all correspondence, documentation supporting plaintiff's claim, payments including dates of payments, payee and reasons for payments, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: from: 01-01-2004 to the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: XXX-XX-5265 Date of Birth. 06-03-1941 41S 105-N SU10-0708884 3 4 4 3 0- L 3 O CERTIFICATE ORIGIN4 PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PATRICIA A. DISNEY TERM, CUMBERLAND -VS- CASE NO: 06-4716 JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/12/2007 CS on beha f of s EVAN BLACK, ESQ. t Attorney for DEFENDANT/ .42 105-N DEll 3 4 4 3 0- L 3 1 COMIUIONWEALTH OF F'ENNSYLVAN I A COUNT Y O F C UMB E R L AND IN THE MATTER OF: COURT OF COMMON PLEAS PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR.DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to- this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10122/2007 CC: EVAN BLACK, ESQ. 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET //800 PHILADELPHIA, PA 19103 (215) 246-0900 .41S 105-N DE02-037.7035 34430-4--01 >>> LOCATION LIST <<< PAGE LOCATION NAME RECORDS REQUESTED THE HETRICK CENTER MEDICAL, BILLING, AND X-RAY(S) WILLIAM PARRISH,MD MEDICAL, BILLING, AND X-RAY(S) CARDIN & PHYSICAL THERAPY MEDICAL, BILLING, AND X-RAY(S) PA NEUROLOGICAL ASSOCIATES MEDICAL, BILLING, AND X-RAY(S) HEALTHSOUTH MEDICAL, BILLING, AND X-RAY(S) MEDICARE/HGSA INSURANCE AARP INSURANCE INTERGROUP INSURANCE CENTRAL PENN PHYSICAL THERPAY MEDICAL, BILLING, AND X-RAY(S) PA OPEN MRI MEDICAL, BILLING, AND X-RAY(S) FIRST CHOICE REHABILITATION MEDICAL, BILLING, AND X-RAY(S) .41S 105-N DE02-0377035 3 4 4 3 0- C O 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY File No. 06-4716 VS. JASON J. LITTON, M.D. AND ORTHOPEDIC SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for INTERGROUP (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 orthings: **** SEE ATTACHED RIDER**** at _ The MCS Group. Inc.. 1601 Market Street. Suite 800, P iladelRhia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: _EVAN BLACK. ES ADDRESS: 305 N. FRONT STF TELEPHONE: _ (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant NOV 12 2007 Date: Seal of the Court BY THE COURT: ." Pr6thonotary/Clerk, Civ ivision Deputy 34430-31 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: INTERGROUP PO BOX 7260 FT. LAUDERDALE, FL 33338 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. PLAN CODE 187 POLICY # 188325265 GROUP# MBA015 Any and all insurance records and PIP files, including but not limited to medical reports and/or records, claims, any and all correspondence, documentation supporting plaintiff's claim, payments including dates of payments, payee and reasons for payments, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: from: 01-01-2004 to the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: XXX XX-5265 Date of Birth: 06-03-1941 41S 105-N SU10-0708886 34430-1-33- CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 ORIGINAL IN THE MATTER OF: COURT OF COMMON PLEAS PATRICIA A. DISNEY TERM, CUMBERLAND -VS- CASE NO: 06-4716 JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days.prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/12/2007 / S on b=af E VAN BLACK, ESQ.' Attorney for DEFENDAN .42 105-N DE11 34430-1132 COMMOI%WEAI-TH OF PENNSYLVAN I A COUNT Y O F C UMB E R 1LAND IN THE MATTER OF: COURT OF COMMON PLEAS PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR.DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/22/2007 CC: EVAN BLACK, ESQ. 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 41S 105-N DE02-0377035 3 4 4 3 0- C O 1 »> LOCATION LIST <<< PAGE LOCATION NAME RECORDS REQUESTED THE HETRICK CENTER WILLIAM PARRISH,MD CARDIN & PHYSICAL THERAPY PA NEUROLOGICAL ASSOCIATES HEALTHSOUTH MEDICARE/HGSA AARP INTERGROUP CENTRAL PENN PHYSICAL THERPAY PA OPEN MRI FIRST CHOICE REHABILITATION 41S 105-N MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, INSURANCE INSURANCE INSURANCE MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) DE02-0377035 3 4 4 3 0- 4 CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY File No. 064716 vs. JASON J. LITTON, M.D. AND ORTHOPEDIC SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for _ CEN'TRAI, PENN PHYSICAT. TH . PAY (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: _ **** SEE ATTACHED RIDER **** at The MCS Group. Inc- 1601 Market Street, Suite 800, Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ES ADDRESS: 305 N. FRONT RIT TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT:: K . " r 4th tuy/C 1 e r k , Civil vision Deputy Date: /o?llo D?pIOV 12 2007 Seal of the Court 34430-32 EXPLANATION OF TO: CUSTODIAN OF RECORDS FOR: CENTRAL PENN PHYSICAL THERAPY 875 POPLAR CHURCH RD STE 100 CAMP HILL, PA 17011 RE: 34430 PATRICIA A DISNEY REQUIRED RECORDS Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records; correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: XXX-XX-5265 Date of Birth: 06-03-1941 R1.41S 120-N SU10-0709104 :3'1L--9L:30-3L9:3.2 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 ORIGINAL IN THE MATTER OF: COURT OF COMMON PLEAS PATRICIA A. DISNEY TERM, CUMBERLAND -VS- CASE NO: 06-4716 JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/12/2007 CS on beh of EVAN BLAC , ESQ. , Attorney for DEFENDANT .42 105-N DE11 34430-T-,33 COIvR4v10NWEALT14 OF PENNSYLVAN I A COUNT Y O F C LJMB E R L AND IN THE MATTER OF: COURT OF COMMON PLEAS PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR.DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations J TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to- this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/22/2007 CC: EVAN BLACK, ESQ. 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 41S 105-N DE02-037.7035 3 4 4 3 0- f --O I >>> LOCATION LIST <<< PAGE LOCATION NAME RECORDS REQUESTED THE HETRICK CENTER WILLIAM PARRISH,MD CARDIN & PHYSICAL THERAPY PA NEUROLOGICAL ASSOCIATES HEALTHSOUTH MEDICARE/HGSA AARP INTERGROUP CENTRAL PENN PHYSICAL THERPAY PA OPEN MRI FIRST CHOICE REHABILITATION MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, INSURANCE INSURANCE INSURANCE MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) 41S 105-N DE02-0377035 34430-C701 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY VS. JASON J. LITTON, M.D. AND ORTHOPEDIC File No. 064716 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PA OPEN MRI (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER**** at The MCS Groun. Inc., 1601 Market Stre Suite 800, Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. E ADDRESS: 305 N. FRONT ST TELEPHONE: (15) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant ID ?tp 0,1 Nov 12 2007 Date: Seal of the Court BY THE COURT: " ro onotary/Clerk, Civil Di sion Deputy 34430-33 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PA OPEN MRI 5400 CHAMBERS HILL ROAD HARRISBURG, PA 17111 RE: 34430 PATRICIA A DISNEY Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. FILM INVENTORY Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: XXX-XX-5265 Date of Birth: 06-03-1941 .41S 105-N SU10-0708890 3 4 4 3 0- L 3 3 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: PATRICIA A. DISNEY ORIGIW COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA CASE NO: 06-4716 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/12/2007 CS on beh 1 of l 140r? " EVAN BLACK, ESQ. 1 Attorney for DEFENDAN 1.42 105-N DE11 3 4 4 3 0- L 3 4 COIVJQVIO1qW1EA1LT14 OF PENNSYLVAN I A COUNT Y O F C UMB E R L AND IN THE MATTER OF: COURT OF COMMON PLEAS PATRICIA A. DISNEY -VS- JASON J. LITTON, M.D. AND ORTHOPEDIC INSTITUTE OF PENNSYLVANIA TERM, CASE NO: 06-4716 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations I TO: MICHAEL J. NAVITSKY, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/22/2007 CC: EVAN BLACK, ESQ. 819-61175 Any questions regarding this matter, contact MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 41S 105-N DE02-0377035 3 4 4 3 0- C 0 1 >>> LOCATION LIST <<< PAGE LOCATION NAME RECORDS REQUESTED THE HETRICK CENTER WILLIAM PARRISH.MD CARDIN & PHYSICAL THERAPY PA NEUROLOGICAL ASSOCIATES HEALTHSOUTH MEDICARE/HGSA AARP INTERGROUP CENTRAL PENN PHYSICAL THERPAY PA OPEN MRI FIRST CHOICE REHABILITATION MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, INSURANCE INSURANCE INSURANCE MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) .41S 105-N DE02-0377035 3 4 4 3 0- C O 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATRICIA A. DISNEY VS. JASON J. LITTON, M.D. AND ORTHOPEDIC File No. 06-4716 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for FIRST CHOICE REHABILITATION (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:_ **** . ATTA D RIDER **** at The M == Inc-- 1601 Market Stree Suite 800. P ilad (phis PA 1 103 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: EVAN BLACK. ES ADDRESS: 305 N_ FRONT CTF TELEPHONE: _(215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant NOV 12 2007 Date: ID /(o%ry Seal of the Court BY THE COURT: C k?. Ima thonotary/Clerk, Civil ivision Deputy 34430-34 EXPLANATION TO: CUSTODIAN OF RECORDS FOR: FIRST CHOICE REHABILITATION 550 N. 12TH STREET LEMOYNE, PA 17043 RE: 34430 PATRICIA A DISNEY OF REQUIRED RECORDS Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : PATRICIA A DISNEY 509 HUNTINGTON AVENUE, ENOLA, PA 17025 Social Security #: XXX-XX-5265 Date of Birth: 06-03-1941 41S 105-N SU10-0708892 3 4 4 3 0- L 3 4 C3 ?' O { - r- -n i3 ? C1 i - ?* t.? r j w w THOMAS, THOMAS & HAFER, LLP 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 Evan Black, Esquire Attorney I.D. 17884 (717) 441-7051 Hugh P. O'Neill, III, Esquire Attorney I.D. 69986 Attorneys for Defendants Jason J. Litton, M.D. and Orthopedic Institute of Pennsylvania PATRICIA A. DISNEY, Plaintiff V. JASON J. LITTON, M.D. and ORTHOPEDIC INSTITUTE OF PENNSYLVANIA, Defendants IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA CASE NO.: 06-4716 CIVIL TERM JURY TRIAL DEMANDED SUGGESTION OF DEATH TO THE PROTHONOTARY: AND NOW, it is suggested that the Defendant Jason J. Litton, M.D., died on September 5, 2008. Kindly enter of record the Suggestion of Death oh behalf of his Estate. THOMAS, T OMAS & HAFER, LLP By: Ev lac , Esquire Attorney I.D. No. 17884 Hugh P. O'Neill, III, Esquire Attorney I.D. No. 69986 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 237-7100 Attorneys for Defendants Dated: 2 CERTIFICATE OF SERVICE I, Joan L. Wolfe, employee of the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that a true and correct copy of the foregoing document was sent to the following counsel of record by placing a copy of same by First Class in the United States mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Michael J. Navitsky, Esquire Navitsky, Olson & Wisneski, LLP 2040 Linglestown Road, Suite 303 Harrisburg, PA 17110 Attorney for Plaintiff Thomas, Thomas & Hafer, LLP fzo?, Date: P J Wolfe 624899.1 C ? ?° c7 F'; r1?;• VJ ?CJ PATRICIA A. DISNEY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNA V. No. 06-4716 Civil Term JASON J. LITTON, M.D., and CIVIL ACTION - MEDICAL ORTHOPEDIC INSTITUTE OF PROFESSIONAL LIABILITY ACTION PENNSYLVANIA, Defendants JURY TRIAL DEMANDED PLAINTIFFS' MOTION REQUESTING THE COURT TO SCHEDULE A CASE MANAGEMENT CONFERENCE AND TO ISSUE A SCHEDULING ORDER PURSUANT TO PA. R.C.P. 1042.41 AND NOW, comes the Plaintiff, Patricia A. Disney, by and through their attorneys, Navitsky, Olson & Wisneski LLP and hereby move Your Honorable Court to schedule a Case Management Conference and to issue a Scheduling Order in the above-captioned case for the following reasons: 1. This is a medical negligence action that was commenced via the filing of a Writ of Summons on or about August 17, 2006. 2. Plaintiff's Complaint was filed on or about September 26, 2006. 3. Defendant's Answer to Plaintiffs' Complaint was filed on or about October 16, 2006. 4. Discovery in this case has been ongoing. 5. Pursuant to Pa. R.C.P. 1042.41, Plaintiff respectfully requests that the Court schedule a Case Management Conference in order to set a timetable for the completion of discovery and the production of expert reports. 6. Plaintiff believes that it would also be beneficial, given counsels' trial calendars and the necessity of scheduling expert witnesses, to discuss possible trial dates during the course of such a conference. WHEREFORE, Plaintiff respectfully requests Your Honorable Court to schedule a Case Management Conference in the above-captioned case, and, following such Conference, to issue a Scheduling Order. Respectfully submitted, NAVITSKY, OLSON & WISNESKI LLP Michael J N itsky, Es i e I.D. No. 3 2040 Linglestown Roa , uite 303 Harrisburg, PA 17110 717/541-9205 Counsel for Plaintiff Date: 019 d1 Q'? CERTIFICATE OF SERVICE I, Jessie K. Walsh, an employee of the law firm of Navitsky, Olson & Wisneski LLP, do hereby certify that I am this c c) day of October, 2008 serving a true and correct copy of Plaintiffs Motion Requesting The Court to Schedule a Case Management Conference and to Issue a Scheduling Order pursuant to Pa.R.C.P. 1042.41 upon all counsel of record via postage prepaid first class United States mail addressed as follows: Evan Black, Esquire Thomas, Thomas & Hafer, LLP P.O. Box 999 305 North Front Street Harrisburg, PA 17101 Jessie K. Walsh f."'? !i? _._ C? _ ---? ?^a3 f..:.,e ± i 7 fi ? ... ? t. ? •. _.rt v E??? PATRICIA A. DISNEY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA V. JASON J. LITTON, M.D., and ORTHOPEDIC INSTITUTE OF PENNSYLVANIA, Defendants No. 06-4716 Civil Term CIVIL ACTION - MEDICAL PROFESSIONAL LIABILITY ACTION JURY TRIAL DEMANDED PLAINTIFFS' AMENDED MOTION REQUESTING THE COURT TO SCHEDULE A CASE MANAGEMENT CONFERENCE AND TO ISSUE A SCHEDULING ORDER PURSUANT TO PA. R.C.P. 1042.41 AND NOW, comes the Plaintiff, Patricia A. Disney, by and through their attorneys, Navitsky, Olson & Wisneski LLP and hereby move Your Honorable Court to schedule a Case Management Conference and to issue a Scheduling Order in the above-captioned case for the following reasons: 1. This is a medical negligence action that was commenced via the filing of a Writ of Summons on or about August 17, 2006. 2. Plaintiff's Complaint was filed on or about September 26, 2006. 3. Defendant's Answer to Plaintiffs' Complaint was filed on or about October 16, 2006. 4. Discovery in this case has been ongoing. 5. Pursuant to Pa. R.C.P. 1042.41, Plaintiff respectfully requests that the Court schedule a Case Management Conference in order to set a timetable for the completion of discovery and the production of expert reports. 6. Plaintiff believes that it would also be beneficial, given counsels' trial calendars and the necessity of scheduling expert witnesses, to discuss possible trial dates during the course of such a conference. 7. No previous rulings have been made by a judge in this case. 8. Defense counsel in this matter has been contacted by telephone and concurs with the request for a Case Management Conference WHEREFORE, Plaintiff respectfully requests Your Honorable Court to schedule a Case Management Conference in the above-captioned case, and, following such Conference, to issue a Scheduling Order. Respectfully submitted, NAVITSKY, OLSON & WISNESKI LLP 0AA . B A A ' ('. V utd,{{iW%q__11I `VW)I/ Michael J. N ,#itsky, EsISui I.D. No. 58803 2040 Linglestown Road, 303 Harrisburg, PA 17110 717/541-9205 Counsel for Plaintiff Date: l Q??2? 0 CERTIFICATE OF SERVICE I, Jessie K. Walsh, an employee of the law firm of Navitsky, Olson & Wisneski LLP, do m hereby certify that I am this dq'day of October, 2008 serving a true and correct copy of Plaintiffs Amended Motion Requesting The Court to Schedule a Case Management Conference and to Issue a Scheduling Order pursuant to Pa.R.C.P. 1042.41 upon all counsel of record via postage prepaid first class United States mail addressed as follows: Evan Black, Esquire Thomas, Thomas & Hafer, LLP P.O. Box 999 305 North Front Street Harrisburg, PA 17101 Jessie K. Walsh C) 'l . t,? PATRICIA A. DISNEY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNA V. No. 06-4716 Civil Term JASON J. LITTON, M.D., and CIVIL ACTION - MEDICAL ORTHOPEDIC INSTITUTE OF PROFESSIONAL LIABILITY ACTION PENNSYLVANIA, Defendants JURY TRIAL DEMANDED PLAINTIFFS' AMENDED MOTION REQUESTING THE COURT TO SCHEDULE A CASE MANAGEMENT CONFERENCE AND TO ISSUE A SCHEDULING ORDER PURSUANT TO PA. R.C.P. 1042.41 AND NOW, comes the Plaintiff, Patricia A. Disney, by and through their attorneys, Navitsky, Olson & Wisneski LLP and hereby move Your Honorable Court to schedule a Case Management Conference and to issue a Scheduling Order in the above-captioned case for the following reasons: 1. This is a medical negligence action that was commenced via the filing of a Writ of Summons on or about August 17, 2006. 2. Plaintiff's Complaint was filed on or about September 26, 2006. 3. Defendant's Answer to Plaintiffs' Complaint was filed on or about October 16, 2006. 4. Discovery in this case has been ongoing. 5. Pursuant to Pa. R.C.P. 1042.41, Plaintiff respectfully requests that the Court schedule a Case Management Conference in order to set a timetable for the completion of discovery and the production of expert reports. 6. Plaintiff believes that it would also be beneficial, given counsels' trial calendars and the necessity of scheduling expert witnesses, to discuss possible trial dates during the course of such a conference. 7. No previous rulings have been made by a judge in this case. 8. Defense counsel in this matter has been contacted by telephone and concurs with the request for a Case Management Conference WHEREFORE, Plaintiff respectfully requests Your Honorable Court to schedule a Case Management Conference in the above-captioned case, and, following such Conference, to issue a Scheduling Order. Respectfully submitted, NAVITSKY, OLSON & WISNESKI LLP ?- J?nf Y. ? Micha J. Navitsky, Esquire I.D. No. 58803 2040 Linglestown Road, Suite 303 Harrisburg, PA 17110 717/541-9205 Counsel for Plaintiff Date: October 31, 2008 ?, :?-,? K?? - t-? ? ? ?? ? ?t ?„ °-{ C: M?? ( t ( ;' "Y"" ?°'.. OCT 2 4 2008 PATRICIA A. DISNEY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA No. 06-4716 Civil Term CIVIL ACTION - MEDICAL PROFESSIONAL LIABILITY ACTION JURY TRIAL DEMANDED V. JASON J. LITTON, M.D., and ORTHOPEDIC INSTITUTE OF PENNSYLVANIA, Defendants ORDER AND NOW, upon consideration of Plaintiff's Motion Requesting The Court to Schedule a Case Management Conference and to Issue a Scheduling Order pursuant to Pa.R.C.P. 1042.41, it is hereby Ordered that a Case Management Conference will be held in this matter on the day of 200/8, at;:,0 o'clock a Jpm. The Conference will take place before The Honorable Q 4,0 in r2t"-? L? and counsel for all parties l? shall attend. BY THE COURT: fib( 9C :6 WV 9- AON SOQZ AW101"vUtt : t 06d aiii 'D 3:01':11 lfd THOMAS, THOMAS & HAFER, LLP 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 Evan Black, Esquire Attorney I.D. 17884 (717) 441-7051 Hugh P. O'Neill, III, Esquire Attorney I.D. 69986 PATRICIA A. DISNEY, Plaintiff Attorneys for Defendants Jason J. Litton, M.D. and Orthopedic Institute of Pennsylvania IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA V. CASE NO.: 06-4716 CIVIL TERM JASON J. LITTON, M.D. and JURY TRIAL DEMANDED ORTHOPEDIC INSTITUTE OF PENNSYLVANIA, Defendants PRAECIPE FOR SUBSTITUTION TO THE PROTHONOTARY: Kindly substitute as of record Linda T. Litton, by Letters of Administration, as representative of the Estate of Jason J. Litton, M.D., Deceased. Attached hereto is a copy of the Short Certificate granting Letters of Administration to Linda T. Litton. Respectfully submitted, THOMAS, THOMAS & HAFEg, LLP By: Attorney I.D. No. 17884 CERTIFICATE OF SERVICE I, Joan L. Wolfe, employee of the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that a true and correct copy of the foregoing document was sent to the following counsel of record by placing a copy of same by First Class in the United States mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Michael J. Navitsky, Esquire Navitsky, Olson & Wisneski, LLP 2040 Linglestown Road, Suite 303 Harrisburg, PA 17110 Attorney for Plaintiff Stanley A. Smith, Esquire Rhoads & Sinon LLP One South Market Square, 12th Floor P.O. Box 1146 Harrisburg, PA 17108-1146 Thomas, Thomas & Hafer, LLP Date: J L. Wolfe 648831.I COMMONWEALTH OF PENNSYLVANIA - SHORT CERTIFICATE COUNTY OF YORK I, BRADLEY C. JACOBS Register for the Probate of Wills and Granting Letters of Administration &c. in and for YORK County, do hereby certify that on the 22nd day of September, Two Thousand and Eight, Letters TESTAMENTARY in common form were granted by the Register of said County, on the estate of JASON J LITTON , late of MONAGHAN TOWNSHIP (First, Middle, Last) in said county, deceased, to LINDA T LITTON (First, Middle, Las[) and that same has not since been revoked. IN TESTIMONY WHEREOF, I have here unto set my hand and affixed the seal of said office at YORK, PENNSYLVANIA, this 22nd day of September Two Thousand and Eight. File No. 67 08 - 01374 Date of Death 910512008 S.S. # 114-28-4480 Register O ills BRADLEY C. JACOBS Register of Wills & Clerk of Orphans' Court My Commission Expires First Monday, January 2012 NOT VALID WITHOUT ORIGINAL SIGNATURE AND IMPRESSED SEAL ca Cam' ` y 2 W? PATRICIA A. DISNEY, Plaintiff V. JASON J. LITTON, M.D., and ORTHOPEDIC INSTITUTE OF PENNSYLVANIA, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA No. 06-4716 Civil Term CIVIL ACTION - MEDICAL PROFESSIONAL LIABILITY ACTION JURY TRIAL DEMANDED PRAECIPE TO DISCONTINUE Please mark the above matter settled, ended, and discontinued. Date: 1-a o , Uoi Respectfully submitted, NAVITSKY, OLSON & WISNESKI LLP 1Michael "avitsky, lire I.D. No. 58803 2040 Linglestown Road, Suite 303 Harrisburg, PA 17110 717/541-9205 Counsel for Plaintiff CERTIFICATE OF SERVICE I, Jessie K. Walsh, an employee of the law firm of Navitsky, Olson & Wisneski LLP, do hereby certify that I am this p?11 day of - , 2002- serving a true and correct copy of the Praecipe to Discontinue upon all counsel of record via postage prepaid first class United States mail addressed as follows: Evan Black, Esquire Thomas, Thomas & Hafer, LLP P.O. Box 999 305 North Front Street Harrisburg, PA 17101 Jessie K. Walsh C`? ?- c°? , ..,? _,.,? ' ?. ,?- ?- w --r- L{{ ,, S.. ?! i ?. s ??? -' 1+ -1 ^ + J ?,4 ? «. ti y ry ..?