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HomeMy WebLinkAbout02-2169ELAINE NACE, Plaintiff Ve DANIEL R. MILLER and RUTH MILLER (nee RUTH REINARD), Husband and wife, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO./~lt.'~ CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717)-249-3166 ELAINE NACE, Plaintiff DANIEL R. MILLER and RUTH MILLER (nee RUTH REINARD), Husband and wife, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.O~-~I/~ CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED COMPLAINT COUNT I ELAINE NACE, by and through her attorney, R. Mark Thomas, Esquire, hereby files a Complaint against the defendants, DANIEL R. MILLER and RUTH MILLER (nee RUTH REINARD), as follows: 1. Plaintiff Elaine Nace is an adult individual who currently resides at 344 North Second Street, Wormleysburg, Cumberland County, Pennsylvania 17043. 2. Defendants Daniel R. Miller and Ruth Miller (nee Ruth Reinard) are husband and wife and reside at Rte. 1, Box 109, Port Treverton, Pennsylvania 17864. 3. The car accident which gives rise to this cause of action occurred on May 3, 2000, which was before Defendants Daniel R. Miller and Ruth Miller were married. 4. On or about May 3, 2000, at approximately 8:00 a.m., plaintiff Elaine Nace was driving a 1995 Saturn Northbound on 38th Street in the area of 3800 Trindle Road, Camp Hill, Pennsylvania when she stopped to make a left hand turn into the strip mall at that location. 5. Plaintiff had activated her left turn signal prior to coming to a stop and was waiting for oncoming traffic to clear prior to turning left. 6. Suddenly and without warning to plaintiff Elaine Nace, defendant Ruth Miller (nee Reinard), who was driving a truck owned by defendant Daniel R. Miller, collided with the rear end of plaintiffs 1995 Saturn. 7. Defendant Ruth Miller (nee Reinard) carelessly, recklessly and negligently drove Mr. Miller's vehicle into the rear end of plaintiffs car causing plaintiff to sustained severe and serious injuries as described more fully hereinafter. 8. The carelessness, recklessness and negligence of the defendant Ruth Miller (nee Reinard) consisted of the following: (a) Failing to have her vehicle under proper and adequate control at the time of the collision; (b) Operating her vehicle in a careless and reckless manner without due regard for the rights and safety of those lawfully upon the roadway, one of whom was plaintiff Elaine Nace at the point aforesaid; (c) Failing to see that plaintiff had stopped her car and activated her left turn signal for the purpose of turning left; (d) Failing to stop her vehicle prior to colliding with the rear end of plaintiffs car; (e) Following too closely so as to prevent her from being able to stop her car prior to colliding with the rear end of plaintiffs car; and (f) Failing to avoid colliding with plaintiffs car when there was sufficient time to either stop or avoid colliding with the rear end of plaintiffs car. 9. By reason of the aforesaid carelessness, recklessness and negligence of defendant Ruth Miller (nee Reinard) as herein before alleged, the plaintiff Elaine Nace, suffered severe and permanent injuries to her neck, shoulders and back which consisted of severe and permanent injuries to the bones, muscles, tendons, ligaments, nerves and tissues of her neck, shoulders and back including, but not limited to, acute cervical strain and sprain, lumbar strain and sprain as well as other injuries in the area of her neck, shoulders and back which have yet to be diagnosed. 10. Plaintiff has in the past and will in the future undergo severe pain and suffering which has resulted in and will in the future result in her inability to attend to her usual duties and occupation, all to her great financial detriment and loss. 11. In addition to the aforesaid physical injuries, plaintiff Elaine Nace, as a direct result of defendant's carelessness, recklessness and negligence as been caused to suffer loss in the form of anxiety, humiliation, frustration, loss of the feeling of well being, limitation of activities, and the loss of enjoyment of life. 12. As a further result of the accident herein, plaintiff Elaine Nace has been and will be obliged to receive and undergo medical care,to expend various sums of money and to incur various expenses for injuries which she has suffered, and she will be obliged to continue to expend such sums or incur such expenditures for an indefinite period of time in the future. 13. As a further result of the accident herein, plaintiff Elaine Nace has and will suffer a loss of her earnings and/or an impairment of her earning capacity and this loss will continue for an indefinite period of time in the future. WHEREFORE, plaintiff demands judgment against the defendant in excess of Twenty thousand ($20,000.00) dollars, plus interest and costs as the law may allow. 14. Paragraphs i through 13 are incorporated herein as if set forth at length. 15. Defendant Daniel R. Miller was the owner of the car being driven by defendant Ruth Miller (nee Ruth Reinard) at the time of this accident. 16. It is believed and therefore averred that Ruth Miller (nee Ruth Reinard) was driving the vehicle with the permission of defendant Daniel R. Miller and/or in the alternative Ruth Miller (nee Ruth Reinard) was operating his vehicle for his benefit and was thereby acting as his agent at the time of this accident. WHEREFORE, plaintiff prays that judgment will be entered in her favor and against defendant Daniel R. Miller for the injuries caused in this accident in an amount in excess of Twenty thousand ($20,000.00) dollars, plus interest and costs as the law may allow. R. Mark Thomas Attorney for Plaintiff 101 S. Market Street Mechanicsburg, PA 17055 (717) 796-2100 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities. Date_ ..-C'---2.-0 ~ '_ SHERIFF'S RETURN - CASE NO: 2002-02169 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NACE ELAINE VS MILLER DANIEL R ET AL Thomas Kline OUT OF COUNTY duly sworn according to law, and inquiry for the within named DEFENDANT MILLER RUTH NEE RUTH REINARD but was unable to locate Her deputized the sheriff of SNYDER serve the within COMPLAINT , Sheriff or Deputy Sheriff who being says, that he made a diligent search and , to wit: He therefore Pennsylvania, in his bailiwick. County, & NOTICE to On May 14th , 2002 , this office was in receipt of the attached return from SNYDER Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 05/14/2002 R MARK THOMAS g. Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this 3,~ day of~l .... ! ~2~ p~ A.D. / ! ProthonOtaryt , SHERIFF'S RETURN - OUT OF COUNTY ~ASE NO: 2002-02169 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NACE ELAINE VS MILLER DANIEL R ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: MILLER DANIEL R but was unable to locate Him in his bailiwick. deputized the sheriff of SNYDER County, serve the within COMPLAINT & NOTICE He therefore Pennsylvania, to On May 14th , 2002 , this office was in receipt of the attached return from SNYDER Sheriff's Costs: Docketing Out of County Surcharge Dep Snyder Co 1@.00 9.00 10.00 25.00 .00 62.00 05/14/2002 R MARK THOMAS So answers~ / R/. Thomas Kline y Sheriff of Cumberlan~d County Sworn and subscribed to before me ,~ day of/~ this A.D. P~othonota~y' gAVED # 02-2169 MISC. DKT. BK. # 31 PAGE # 044 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ELAINE NACE ¥S DANIEL R. MILLER and RUTH MILLER (nee RUTH REINARD) h/w NO: 02-2169 NOTICE AND COMPLAINT AFFIDAVIT OF SERVICE AND NOW, May 10, 2002 1 Catherine Zellers, Deputy Sheriff for Joseph S. Reigle, Jr., Sheriff of Snyder County, Pennsylvania, being duly sworn according to law deposes and says that on May 9, 2002, at 10:40 A.M. served a copy &the above described Notice and Complaint, upon Daniel R. Miller and Ruth Miller (nee Ruth Reinard), named defendant, by personally handing to Ruth Miller, herself and as adult person in charge of the defendants residence at the time of service for Daniel R. Miller, her husband at RR#1, Box 109, Chapman Road, Port Trevorton, Snyder County, Pennsylvania, a hue and correct copy of the above described Notice and Complaint and made know to ~9~th Miller the contents of the same. SO ANSWERS BY JOSEPH REIGLE, JR., SHERIFF : SNYDER COUNTY, PENNSYLVANIA DEPc O~ 'dC ~ ARA~ THZ~oLtpEZy~V-ANiA COLFNTY OF SNYDER SS: SWORN TO AND SUBSC ~RI~ED BEFORE ME THIS ~d~2~_DAY~)F '7.//z2~. ,2002 DEPUTATION BY: SHERIFF OF CUIV~ERI.AND COUNTY PA. PAID TO COUNTY CHECK # SNYDER COUNTY SHERIFF'S FEES: Docketing, Service, Etc. Mileage Notmy $ lg. O0 9.00 3.00 REIMBURSED TO PETTY CASH CHECK # TOTAL: $ 25.00 DEPOSIT :$75.00 Receipt #9215 Refund :$50.00 Check# Return this form to Olnberland County Sheriff's office. In' The Court of Common Pleas of Cumberland County, Pennsylvania Elaine Nace Daniel R. M~er et al SERVE: Daniel R. Miller No. 02 2169 civil NOW, May 6, 2002 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Snyder Coun%~; to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, ,20 , at o'clock __ M. served the upon at by handing to a and made known to >- c~ Sworn and subscribed before me this day of ,20__ copy of the original So answers, Sheriffof COSTS SERVICE MILEAGE AFFIDAVIT the contents thereof. County, PA Return this form to Cuuberland County Sheriff's office. In The CoUrt of Common Pleas of Cumberland County, Pennsylvania Elaine Nace Daniel R. M~ler et al SERVE: Ruth Miller (nee Ruth Reina~o' 02 2169 civil Now, ~ay 6, 2002 ., I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Snyder County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, ,20 , at o'clock __ M. served the within upon by handing to a =and made known to Sworn and subscribed before me this day of. copy of the original ,2O So answers, the contents thereof. Sheriff of COSTS SERVICE MILEAGE AFFIDAVIT County, PA ELAINE NACE, Plaintiff, DANIEL R. MILLER and RUTH MILLER (nee RUTH RIENARD), husband and wife, Defendants. IN THE COURT 0F COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO.: 02-2169 CIVIL ACTION - ~AW ! JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behal of the Daniel R. and Ruth Miller, with regard to the above-captioned ma1 er. Date: Defendants, Respectfully submitted, NEALON & GOVER, By: ~ .... Andrew C. Lehm; I.D. #: 81937 2411 North Front Harrisburg, PA 1; 717/232-9900 n, Esquire ~treet '110 CERTIFICATE OF SERVICE AND NOW, this / '~,/~day of June, 2002, I hereby certify that I have served the / foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following by depositing a / true and correct copy of same in the United States mail, postage ~repaid, addressed to: R. Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 ELAINE NACE, Plaintiff, DANIEL R. MILLER and RUTH MILLER (nee RUTH REINARD), husband and wife, Defendants. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO.: 02-2169 CIVIL ACTION - LAW JURY TRIAL DEMANDED ANSWER TO COMPLAINT COUNT I 1. Admitted upon information and belief. 2.-3. Admitted. 4.-7. Denied as stated, however, it is admitted that on May3, 2000, at approximately 8:00 a.m., in the area of the 3800 block of Trindle Road in Camp Hill, 'Pennsylvania, the front of Defendants' vehicle came into contact with the rear of Plaintiff's vehicle. The remaining averments contained in these paragraphs are denied pursuant to Pa.R.C.P. 1029(e). 8. Denied pursuant to Pa.R.C.P. 1029(e). 9.-13. Denied as Defendant is without sufficient information to form a belief as to the truth of the matter asserted, and proof is demanded at trial. Any remaining averments contained in these paragraphs are denied pursuant to Pa.R.C.P. 1029(e). WHEREFORE, Defendant Ruth Miller respectfully requests judgment in her favor plus costs. COUNT II 14. Paragraphs 1 through 13 are incorporated herein as if set forth at length by reference thereto. 15. Admitted. 16. Denied as stated, however, it is admitted that the vehicle driven by Defendant Ruth Miller was driven with permission of Defendant Daniel R. Miller; however it is denied that Defendant Ruth Miller was acting as an agent of Daniel Miller at the time of said accident. WHEREFORE, Defendant Daniel Miller respectfully requests judgment in his favor plus costs. Respectfully submitted, NEALON & GOVER, P.C. C. Lehman, £squire I.D. #: 81937 2411 North Front Street Harrisburg, PA 17110 717/232-9900 VERIFICATION We, DANIEL R. MILLER and RUTH MILLER (nee RUTH REINARD), verify that the statements made in the foregoing ANSWER TO COMPLAINT are true and correct. We understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: DANIEL R. MILLER RUTH MILLER, (nee ~ REINA~D) CERTIFICATE OF SERVICE AND NOW, this '/'(~ day of July, 2002, I hereby certify that I have served the foregoing ANSWER TO COMPLAINT on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: R. Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 Andrew C. Lehman, Esquire 9J!nb$::] 'UBLUqa"] '0 ,~a~puv 990ZI- V8 'fiJnqso!ueqoalAI ],eeJ]S ],eHJelAI q],nos ~0 b eJ!nbsE] 'SeLUOql NJelA] 'M :o~ pesseJppe 'p!edeJd el~e],sod 'l!eLU se~e]s pe~!UFI eq~ ul eLues ~o/~do3 :~38JJo3 pue @nJ~ e 6u!~!sodep Xq 6u!AOllOJ aql uo 1NIVqclI/X]O0 01 ~FIAASNV eq), p@AJes e^eq I ~eq], ,~jildeo XqeJeq I '~00~ 'XInF ,to Xep ,0~ siq] 'MON QNV :101^ 135 -I0 3/V01-11/ 133 CERTIPICATR PRRRRQUISITE TO S~RVICE OP A SUBPORNA PURSUANT TO RUL~ 4009.22 IN THE MATTER 0IF: ELAINE NAC~ COURT OF COMMON PLEAS TERM, -VS- CASE N0: 02-2169 DANIEL R. ~ND RUTH MILLER AS a prereguisite to service of a subpoena for documents and thin§s pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) Ainotice of intent to serve the subpoena with a copy of the subpoena a~tached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be s~rved, (2) A]copy of the notice of intent, includin9 the proposed subpoena, is a~tached to this certificate, (3) Nd objection to the subpoena has been received, and (4) T~ subpoena which will be served is identical to the subpoena which isl attached to the notice of intent to serve the subpoena. DATE: 01/27 2003 Attorney for DEFENDANT DEll-388686 1 824 7--LO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER 0iF: ELAINE NACE -VS- DANIEL R. AND RUTH MILLER COURT 0F COMMON PLEAS TERM, CASE NO: 02-2169 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUP~NTS AND FOR DISCO~faY Pu~tS~ ~C) Rur,R 4009.21 [ Note: see enclosed list of locations ] TO: R. MARK TH0~AS, ESQ. MCS on behalf of ANDREW C. LEH~%N, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from ~he 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: 01/04/2003 CC: ANDREW C. LEHMAN, ESQ. - 02-252 %CS on behalf of ANDREW C. LEHMAN, ESQ.. Attorney for DEFENDANT Any questiohs regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #000 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-211649 18247--C01 >>> LOCATION LIST <<< PAGE: 1 LOCATION RECORDS REQUESTED EXPERIENCE NORMS CO~40N SENSE ADOPTION SERVICES FRANCIS X. BRESCIA, JR., D.0. HOLY SPIRIT HOSPITAL DR. EDWARD SCH~PPELL, D.C. JOHN N. PIKULI~ U.O. UR.STUART HART~AN EDWARD S. VlOLAGO, M.D. RNPLOYNENT RNPLOYMRNT MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS DE02-211649 1824 7--C01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERL_AND ELAINE NACE VS DANIEL R. & RUTH MILLER File No. 02-2169 TO:. CUSTqDIAN SUBPOENA TO PRODUCE DOCU~S OR THINGC FOR DISCOVERY PURSUANT TO RULE 40097~ OF RECORDS FOR: EXPERIENCE WORKS Within twenty (20) days after se"vice of this subpoena, you are ordered by the court to produce the foilowtn~ documents or thin~: at MCS GRQUP INC., 1601 MAREKT ST., #800, PHILA.,PA 19t03 (A~--~) You may deliver Or mail legible copies of the documents oe produce thfflSIi requested by this subpoena, to~ether with the certificate of complia~e, to the party makin$ this request at the address :hd~,e advance, the reasonable cost of preparin~ the co es ~r .......... You have the ri~tt to seek, in If you fail to prodUCe the documents or thinss required by this subpoena, within twen~ (20) days a~ter its service, the party servin$ this subpoena may seek · coufl order compelHn[ you to comply with IL THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ANDP~ C.T~Em4AN, ESq. ADDRES~ 2~11 NORTH FRONT ST. H~RRISBURG' PA 17110 .-'. TELEPHON~ i 215-246-0900 SUPREME COURT ID ~. A'I~ORNEY FO~ DEFENDANT Seal of the Court (~f. 7/97] EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: EXPERIENCE WORKS 817 MARKET STREET MECHANICSBURG, PA 17055 RE: 18247 ELAINE L. NACE Any and all emPloyment records, applications, fries, memoranda, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee, including any and all such items as may tboe: stored in aicomputer database or otherwise in electronic form, pertaining u.tes Req_u_e~ted: up to and including the present. bject: ELAINE L. NACE 3,~4~4.~.,Nb.S~sCOND STREET, WORMLEYSBURG, Pa 17043 Social Security #: 202-36-6026 SU10-418260 1 824 7--LO 1 CERTIFICATE PREREOUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER 0~: ELAINE NACE COURT OF COMMON PLEAS TERM, -VS- DANIEL R. AND RUTH MILLER CASE NO: 02-2169 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 40~9.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A ~notice of intent to serve the subpoena with a copy of the subpoena atitached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be seirved, (2) A !copy of the notice of intent, including the proposed subpoena, is atltached to this certificate, (3) Noi objection to the subpoena has been received, and (4) ThE subpoena which will be served is identical to the subpoena which isiattached to the notice of intent to serve the subpoena. DATE: 01/27i2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-388687 1 824 7--LO 2 COMMONWEALTH OF PE]~NSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER 0F: ELAINE N~CE DANIEL R.i AND RUTH MILLER COURT OF C0~9~0N PLEAS TERM, CASE NO: 02-2169 NOTIC~ OF ~ TO SERVE A SUBPO~m~A TO P~DUC~ ~S AND 'lmJ~S F~k DISC~mtY Pu~tt~r~- ¶N) RUT.W 4009.21 TO: R. ~ ~CS on be] identical days from undersigm waived or copies of [ Note: see enclosed list of locations ] U~ THOMAS, ESQ. lalf of ANDREW C. LEHPAN, ESQ. intends to serve a subpoena to the one that is attached to this notice. You have twenty (20) the date listed below in which to file of record and serve upon the id an objection to the subpoena. If the twenty day notice period is if no objection is made, then the sub~na may be served. Complete any reproduced records may be ordered at your expense by completing the attacl,ed counsel card and returnin~ same to )~S or by contacting our local ~CS office. DATE: 01/06/2003 CC: ANDR~N C. LEHNAN, ESQ. - 02-252 ~CS on behalf of aEw c. smo , Attorney for DRFRNDANT Any questions regardin~ this matter, contact THE NCS GROUP INC. 1601 NARKRT STRRRT ~800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-211649 · 8 2 4 7 --CO 1 LOCATION LIST ¢¢< PAGE: 1 LOCATION NA~ RECORDS REQU}ISTED EXPERIENCE NO~KS COMMON SENSE 2~)OPTION SERVICES FRANCIS X. BRESCIA, JR., D.O. HOLY SPIRIT H~SPITA5 DR. EDWARD SC]~APPRLL, D.C. JOHN N. PIK~]L~N D.O. DR.STUART HAR~AN ED#2~ S. VIO~AG0, N.D. EMPLOYMENT EMPLOYMENT M~DICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS DE02-211649 i 8 2 4 7 --CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBFRLAND ELAINE N~CE VS DANIEL R.i& RUTH MILLER File No. 02-2169 TO:. SUBPOI~A TO PRODUC S OR THINGS FOR DISCOVF. RY PURSUANT ~ ~OF RECORDS FOR: COMMOM SENSE ADOPTION SERVICES 1601 MAREKT ST. , #800, PHILA. ,PA 19103 THIS sUBI~A WAS ISSULrD AT TI~ RI~Q~ OF TE~ FOLLOWING P~tSON: NAM& AND ADDR~.S~. TL:LEPHON~ SUPRI~ COl ATTORNL~' FC ~ C.t.~-3~tAN~ ESq. Z411 NORTIt FRONT ST. tAIIXSBUR(~'. PA 17110 21~-246-0900 DAI'~ Seal of the Court (~. 7197) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: COMMON S~NSE ADOPTION SERVICES 3820 MARKET STREET CAMP HILLi PA 17011 RE: 18247 ELAINE L. NACE Any and all e~ployment records, applications, files, memo~r~lda, compensation, time and attenp, ance records, personnel records, payroll and salary reports and all medica~ records as an employee, including any and all such items as may tbS: stored in a computer database or otherwise in electronic from, pertaining Dates Requested: up to and including the present. SubjeCt: ELAINE L. NACE 344 IN. SECOND STREET, WORMI.EYSBURG., PA 17043 Social Securi y #: 202-36-6026 SU10-418262 1 824 7--LO 2 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBP0gNA PURSUANT TO RULE 4D~,.22 IN THE MATTER OF: ELAINE NACE COURT OF COMMON PLEAS TERM, -rs - CASE NO: 02-2169 DANIEL R. %ND RUTH MILLER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A{notice of intent to serve the subpoena with a copy of the subpoena a~tached thereto was mailed or delivered to each party at least t~enty days prior to the date on which the subpoena is sought to be s~rved, (2) A Icopy of the notice of intent, including the proposed subpoena, is at!tached to this certificate, (3) Noi objection to the subpoena has been received, and (4) Th~ subpoena which will be served is identical to the subpoena which isi attached to the notice of intent to serve the subpoena. DATE: 01/27~2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDAN~ DEll-388688 1824 7--LO 3 COMMONWEALTH OF PE]~NSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ELAINE N~CE DANIEL R.i AND RUTH MILLER COURT OF COMMON PLEAS TERM, CASE NO: 02-2169 NOTIC~ OF INT~qT TO S~RV~ A SUBPO~ TO P~OnUf~ ~S AND ~ 'r~.L~K?~ F,O~ DISC~ Pu~tm~f~ ¶~O R_~'.~ 4009.21 [ Note: see enclosed list of locations ] TO: R. NA MCS on be identical days from undersigm IK THOMAS, ESQ. lalf of ANDREW C. LEHNAN, ESQ. :intends to serve a subpoena to the one that is attached to this notice. You have twenty (20) the date listed below in which to file of record and serve upon the id 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 attac]ted counsel card and returning same to I~CS or by contacting our local NCS offict DATE: 01/~6/2003 CC: ANDREW C. LEHNAN, ESQ. - 02-252 NCS on behalf of NDRSS C. LSm S, eS . Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STHEET J800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-211649 i 8 2 4 7 --CO I LOCATION LIST ¢¢< PAGE: i LOCATION RECORDS RHQUBSTED EXPERIENCE NO~KS COlOrON SENSE ~DORTION SERVICES FRANCIS X. BRESCIA, JR., D.O. HOLY SPIRIT HQSPITAL DR. EDWARD SC~PPELL, D.C. JOHN N. PIKUL~N D.O. DE.STUART HAR~MAN EDNARD S. VIO~GO, M.D. ENPLOYMENT ENPLOYM~NT M~DICAL RECORDS MEDICAL RECORDS W[~DICAL RECORDS MEDICAL R~CORDS ~DIC~ RECORDS ~DIC~ RECORDS DE02-211649 I 8 2 4 7 --CO 1 COMMOlVWEALTH OF PENNSYLVANIA C_OUN'i~ OF CUMBFRLAND ELAINE NA DANIEL R. CE : VS : & RUTH MILLER : File N~ FOR DISCOVERY PURSUANT TO RULE TO:. ~F RECORDS FOR: FRANCIS X.BRESCIA, JR. 02-2169 at ~. , 1601 HARLOT ST. , #800, PHILA. ,PA 19103 (i You._may de!iv* or nwil le~iMe milles of the doL*unmn~ ~ produce fldn~ --~d '-- ~ -- ¢ .ertlflcate.of p, ilm,~e, to the perry this uest ,,-~_ ay' f,, ..t:~e~.. tos~her with the THIS SUBPOENA WAS ISsuED AT TH~ R~QUT:ST OF TI~ FOLLOWING PERSON: NAM~ A~ ADORES& TELEPHON~ SUPRI~M~ CO~ ATrORNEY i~ PEW ¢.~.mO.N, ESQ. 2411 NORTH FRONT ST. ~R~ASBURG'. PA 17110 21~-246-0900 )P~ DEFENDAh~ the Com~ (Elf. EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: FRANCIS X. IBRESCIA, JR. D.O. ROUTE 22-322 ' P. O. BOX 247 DAUPHIN, EA 17018 RE: 18247 ~ ELAINE L. ACE Entire medical frie, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, fries, memoranda, h}andwritten notes, history and physical reports, r. nedication/ prescription .r~ords, including any and all such items as may be stored in a c, gmpute, r da.tap .ase or.otherwise in electronic form, relating to any examination, olagnos~s or trgatment pertaining to: Dates R.e~ues~ed: up to and including the present. Subject. ELAINE L. NACE 344 N. SECOND STREET, WORMLEYSBURG, PA 17043 Social Security #: 202-36-6026 SU10-418264 1 824 7--L03 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009..22 IN THE MATTER 0F: COURT OF COMMON PLEAS ELAINE NAC* TERM, -VS - DANIEL R. AND RUTH MILLER CASE NO: 02-2169 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 40D9.22 MCS on behalf of ANDREW C. LEHMAN', ESQ. certifies that (1)-Ainotice of intent to serve the subpoena with a copy of the subpoena a~tached 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 icopy of the notice of intent, including the proposed subpoena, is atltached to this certificate, {]) NO objection to the subpoena has been received, and (4) Th~. subpoena which will be served is identical to the subpoena which isl attached to the notice of intent to serve the subpoena. DATE: 01/27!2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-388689 1824 7--LO4 COMMONWEALTH OF PEI~NSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER iOF: ELAINE N!CE -VS - DANIEL R. AND RUTH MILLER COURT OF COMMON PLEAS TERM, CASE N0: 02-2169 TO: R. ~U MCS on bel [ Note: see enclosed list of locations ] THOMAS, ESQ. tall of ANDREW C. LEHMAN, ESQ. intenda 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 thetwenty day notice period is waived orlif no objection is made, then the subp¢~na may be served. Complete copies of lany reproduced records may be ordered at your expense by completing the attached counsel card and returning same to ~S or by contacting our local NCS office. DATE: 01/~6/2003 CC: ANDREWi C. LBB~AN, NS0. - 02-252 ~CS on behalf of ANDREW C. LEHMAN, ~SQ. Attorney for DBFBNDANT Any questigns regarding this uatter, contact THE ~CS GROUP iNC. 1601 ~R~ET STREET ~800 PHILADBLPHIA, PA 19103 (215) 246-0900 DE02-211649 i 8 2 4 7 --CO I LOCATION LIST <¢,: PAGE: 1 LOCATION RECORDS REQUESTED EXPERIENCE WORKS CO~N SENSE ~ION SERVICES F~CIS X. BRESCIA, JR., D.O. HOLY SPIRIT H~SPIT~ DR. EDWARD SC~PP~LL, D.C. JOHN N. PIKUL~N D.O. DR.STUART H~ EDWARD S. VIO~GO, M.D. ENPLO~ ENPLO~ ~DIC~ RECORDS NEDIC~ RECORDS ~DIC~ RECORDS ~DICAL RECORDS ~DIC~ RECORDS ~DICAL RECORDS DE02-211649 i 8 2 4 7 --CO 1 COMMONWEALTH OF PENNSYLVANI: COUNTY OF CUMBERLAND ELAINE NACE VS DANIEL Ro & RUTH MILLER File No. 02-2169 TO:. SUBPOENA TO PRODU S OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 F RECORDS FOR: HOLY SPIRIT HOSPITAL thJn~: ------ · t MCS Gl 20) (hys after ~evi. M thb .-bl~.~ y~ mM *~ by the cout to produte the followin~ dommems ~ .OUP IN~., 1601 I~,REKT ST., 1800, PHILA.. ,PA 19103 (Addmm) You au), delive, m nmii klJble cop4es M the documents oe produm thfnp ~uemed '--- thl. -- certificate M coE ~pliince, to the JMfl? Inlkinf thil m~m It the ~Ld~ ,,~.~."?_._ _ ~ . ~u .opoe~, toslth~ with the advance, the rea mn~b - ---~ ___ ~ ,muu aa(we. YOU nave tim d to · i iec°et°fPreperin~thec°pies°fPr°duclnjtMthb~muEhL 8hr mk, m If you fail to pre s~vin$ thio sub duce the documen~ or thinp required by this luba(mni, wJthbl twenty ,~m mena may seek a court ruder comlml!i__m~ you io eof~%vith iL --'.y ENAWASlSSUEDATTHERI~QUESTOFT[~FOLLOWiNGPERSON: 24~! NORTlt FRONT ST. [IAIKISBURG~ PA 17110 :-, 21~-246-0900 I~ DEFENDANT Seal o[ the Court BY TH]/COURT: THIS SUBP~ NAM~ ANn ADDRESS~ TELEPHONU SUPREME COl ATrORNEY FC (F~. 7/~/) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRI~F HOSPITAL 503 N. 21 ST 'STREET CAMP HILLi PA 17011 RE: 18247 ELAINE L. NACE Entire hospit~ medical file, including but not limited to any and all records, correspondenCe to and from the consulting and/or treating physician, files, memoranda, liandwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and. all patien~ consent or refusal of treatment, procedures, tests, and/or meaication, lab and diagnostic test results, including ap.y and all such items as.m?y be sto~ed in a computer database or otherwise m 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: ELAINE L. NACE 3,~4~.~.,N~.S~,COND STREET, WORMLEYSBURG, PA 17043 Social Securi!y #: 202-36-6026 SU10-418574 1824 7--L04 CERTIFICATE PREREOUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OiF: ELAINE NAC~ COURT OF COMMON PLEAS TERM, -VS- DANIEL R. ~ND RUTH MILLER CASE N0: 02-2169 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A!notice of intent to serve the subpoena wit'h a copy of the subpoena a~tached thereto was mailed or delivered to each party at least t~enty days prior to the date on which the subpoena is sought to be served, (2) Aicopy of the notice of intent, includingl the proposed subpoena, is a~tached 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: 01/2Vi/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-388690 1 8 24 7--LO 5 COMMONWEALTH OF PE~NNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ELAINE N~CE -rS o DANIEL Ri AND RUTH MILLER COURT OF COMMON PLEAS TERM, CASE NO: 02-2169 NOTZ~ OF ~ TO S]~RVB A SUBPOBIO~ T~) PRODU(~ ~S · ruJ_B~S ~O~ DISCO~t~-~f Putt~tt~rr TO RUTJZ 4009.21 [ Note: see enclosed list of locations ] TO: R. ~ THO~%S, ES0. ~CS on b~alf of ANDREW C. LER~%N, ESQ. intends to serve a subpoena idsnticali 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 undsrsign~d 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 co~leting the attaC~ed counsel card and returning same to ]~CS or by contacting our local ~CS offic,~. DATE: 01/06/2003 cc: ~Daaw ¢. ~.Bmm%~, Es0. - 02-252 NCS on behalf of ANDREW C. LEHMAN, ES9. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARF~T STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-211649 1 8 ~ 4 7 --CO 1 LOCATION LIST ¢<,¢ PAGE: 1 LOCATION N~e~qE RECORDS REQUI~STED EXPERIENCE WORKS COMMON SENSE ~DOPTION SERVICES FRANCIS X. BRESCIA, JR., D.O. HOLY SPIRIT HOSPITAL DR. EDNARD SCHAPPELL, D.C. JOHN N. PIKUL~N D.O. DR.STUART HAR~MAN EDNARD S. VIOLAGO, M.D. ENPLOYNENT ENPLOYNENT NItDICAL RECOI~DS NEDICAL RECORDS MEDICAL RECORDS MEDICAL RECOILS MEDICAL RECOILS MEDICAL RECOILS DE02-211649 I 8 2 4 7 --CO 1 COMMONWEALTH OF PENNSYLVANIA COUN'I~ OF CUMBFRLAND ELAINE N~CE VS D~IEL R. & RUTtt HILLER File No. 02-2169 a~ ~C., 1601 MAREKT ST., ~800, PHILA.,PA 19103 tn~ this mbpoeM m~' eeek a mun mM~ co~pefli~y~ to comply with It, twenty (20) d~y~ ~'~e~ iU Mrvice, the party THIS SUBP01~qA WAS ISSUSD AT THS REQUEST OF 3'lis FOLLOWING PERSON: NAME: ADDRE~.q~ TELEPHONE: SUPR~M~ C~ ATTORNIY R C · T-~l~n~l.-,~xlq ~ ESq. NORTH FRONT ST. RAItI~BOR(;'. PA 17110 21~-246-0900 DATE: BY TI{S COURT:/Q L. D /~ the Cou~ (F~. 7/97) EXPLANATION. OF REQUIRED RECORDS ~TO: CUSTODIAN OF RECORDS FOR: DR. EDWARD SCHAPPELL, D.C. 3301 SCHOOLHOUSE LANE HARRISBURG, PA 17109 RE: 18247 ELAINE L. I~ACE Entire medica correspondent memoranda, t prescription r{ computer data L frie, including but not limited to any and all records, e to and from the consulting and treating physk:ians, fries, andwritten notes, history and physical reports, medication/ :cords, including any and all such items as may be stored in a Base or otherwise in electronic form, relating to any examination, diagnosis or t[eatment pertaining to: Dates Requested: up to and including the present. Subject: ELAINE L. NACE ,..3~.,N~.S~sCOND STREET, WORMLEYSBURG, Pa 17043 Social Security #. 202-36-6026 SU10-418268 1 8 24 7 --LO 5 CRRT~ICAT~ PREREOUISITE TO S~RVICE OF A SUBPOEN~ PURSUANT TO RUL~ 4009.22 IN THE MATTER 0!F: ELAINE NACiE DANIEL R. hND RUTH MILLER COURT OF COMMON PLEAS TERM, CASE NO: 02-2169 AS a prereguisite to service of a subpoena for documents and things pursuant to Rule 40 9.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena a~tached thereto was mailed or delivered to each party at least twenty days prior to the date on which tile subpoena is sought to be served, (2) Aicopy of the notice of intent, includinf~ the proposed subpoena, is a~tached to this certificate, (3) N~ objection to the subpoena has been received, and (4) T~e~ subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/2~ '2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-388691 1824 7--T.O 6 COMMONWEALTH OF PE]~NSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER 0F: ELAINE N~CE -VS- DANIEL R AND RUTH MILLER COURT OF COMMON PLEAS TERM, CASE NO: 02-2169 NOTIC~ OF ]3qTI~T TO SRRVI{ A SUBPORNA ~) PRODUCR IX)CUNI~qTS FOR DISCOVm(Y ~'U~U~UA~T TO RU~.R 4009.21 [ Note: see enclosed list of locations ] TO: R. ~%RK THONAS, RSQ. #CS on behalf of ANORRN C. LgHNAN, gSQ. 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 WCS or by contacting our local NCS office. .AT : 01/06/2003 CC: - 02-252 NCS on behalf of a~OagW c. L~aWAW, gS9. Attorney for DRFRNDA~T Any questions regarding this matter, contact TRR MCS GROUP INC. 1601 NAR~RT STRRRT 1800 PHILADRLPHIA, PA 19103 (215) 246-0900 DR02-211649 1 8 2 4 7 --CO 1 LOCATION hIST ¢~.: PAGE: 1 LOCATION NAME RECORDS REQUESTED EXPERIENCE WORKS COMMON SENSE ~DOPTION SERVICES FRANCIS X. BRESCIA, JR., D.O. HOLY SPIRIT HOSPITAL DR. EDWARD SC~APPgLL, D.C. JOHN N. PIKUL~N D.O. DR.STUART HARTMAN EDWARD S. VIO~AGO, M.D. ENPLOYMENT EMPLOYMENT MEDICAL RECO~S MEDICAL RECO~S MEDICAL RECO~S MEDICAL RECO~S MEDICAL RECORDS MEDICAL RECORDS DE02-211649 1 8 2 4 7 --CO i COMMONWEALTH OF PENNSYLVANL~ COUNTY OF CUMBERLAND ELAINE N~CE VS DANIEL R. & RUTH MILLER File N~ 02-2169 r~A ut~UV~:Ry PURSUANT TO RULE T(~, ~F RECORDS FOR: JOHN N.PIKULIN (Nmm ~ hmm ~ ~ 1601 ItAR.~T ST., #800, PHILA.,PA 19103 (Addmm) THIS SUBPOENA WAS ISSUED AT THE REQUEST OF TltE FOLLOWING PERSON: NAME: A~R~ C.LEm~.H, Esq. ADDRE.q,~ 2411 NORTH FRONT ST. HAB~SBI~G' PA 17110 :'. TELEPHON~ 21.}-246-0900 SUPREME CO~JWr ID ~ ------- ATrORNL~' FOR: DEFElq'DANT DAT~: 31. aOOil Seal of the Court BY TH~ COURT/'[ .~. D /~ Deputy/ ' EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOHN N. PII~ULIN D.O. 221 BRIDGEISTREET NEW CUMBERLAND, PA 17070 RE: 18247 ELAINE L. NACE Entire medica correspondenc memoranda, ~ prescription re computer dat~ diagnosis or t~ file, including but not limited to any and all records, e to and from the consulting and treating physicians, files, andwritten notes, history and physical reports, medication/ cords, including any and all such items as may be stored in a ~ase or otherwise in electronic form, relating to any examination, eatment pertaining to: Dates Requested: up to and including the present. Subject: ELAINE L. NACE 3.~44.iI..Nb.S~sCOND STREET, WORMLEYSBURG, PA 17043 Social Securily #. 202-36-6026 SU10-418270 1 8 2 4 7--LO 6 CERTIFICATE PRRREOUISITE TO SERVIC~ OF A SUBPOENA PURSUANT TO RUL~ 400~.22 IN THE MATTER 0~: ELAINE NACk COURT OF COMMON PLEAS TERM, i -VS- CASE NO: 02-2169 DANIEL R. ~ND RUTH MILLER AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 40~9.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1).A notice of intent to serve the subpoena with a copy of the subpoena al:~tached thereto was mailed or delivered to each party at least t~enty days prior to the date on which the subpoena is sought to be sE!rved, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) N0 objection to the subpoena has been received, and DATE: 01/21/2003 (4) TBe subpoena which will be served is identical to the subpoena which it attached to the notice of intent to serve the subpoena. MCS on behalf of ANDREW C. LERMAN,' ESQ. Attorney for DEFENDANT DEll-388692 1824 V--LO 7 COMMONWEALTH OF PEI~NSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER 0F: COURT OF COMMON PLEAS ELAINE NiCE TERM, -VS- CASE NO: 02-2169 DANIEL R.! AND RUTH MILLER NOTIC~ OF ~ TO SBRV~ A SUBPORNA_ TO PRODUC~ ~S AND i -rilings ~Ok DISC.3~¥m(¥ ~U~taq~F ¶N) RUr.m 4009.21 [ Note: see enclosed list of locations ] TO: R. ~K THOMAS, ESQ. MCS on behalf of ANDREW C. LEHMAN, ES9. intends to serve a subpoena identicallto the one that is attached to this nol:ice. You have twenty (20) days fromlthe 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 orl. if no objection is made, then the sub~)ena may be served. Complete copies of Jany reproduced records may be ordered at your expense by completing the attacked counsel card and returnin9 same to I~CS or by contactin9 our local ~CS office. DATE: 01/~6/2003 CC: ANDREM C. LBHMAN, ESQ. - 02-252 MCS on behalf of a~DRSW c. Lsmm%N, SSQ. Attorney for DBFBNDANT ~ny questions regaxdtng this matter, contact THE MCS GROUP INC. 1601 PJ~RK~T STREET J800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-211G49 1 8 2 4 7 --CO 1 LOCATION LIST <~,: PAGE: 1 LOCATION N~ RECORDS REQI~ISTED EXPERIENCE NO~KS COMMON SENSE ~DOPTION SERVICES FRANCIS X. BRiSCIA, JR., D.O. HOLY SPIRIT H~SPITAL DR. EDWARD SCS~.PPBLL, D.C. JOHN N. PIKUL~N D.O. DE.STUART HAR~.AN EDNARD S. VIO~AGO, N.D. ENPLOYNENT ENPLOYN~NT MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS DE02-211649 I 8 2 4 7 --CO 1 COMMONWEALTH OF PENNSYI. VANL~ COUN~-Y OF CUMBFR__I. AND E~I~ NA DANIEL R. VS & RUTH MILLER File No. 02-2169 FOR DISCOVERY PURSUANT TO RULE TO:. ~F RECORDS FOR: STUART A. HARTMAN at ~., 1601 MAREKT ST., ~800, PHILA.,PA 19103 THIS SUBPOI~IA WAS ~ AT ~ I~QIJ~ST OF TI.I~ 13OLLOWING PlfltSON: NAM~ Ah'] ADDRES~ TELEPHON& SUPREM! CO AITORNL~ !~ ,RE~ C.LS:I~AN~ ESq. 2411 NORTH FRONT ST. HAIIXSBURG' PA 17110 21~-246-0900 )[f~ DEFENDANT 31: Seal of the Court (~.~. 7/90 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. STUART IHARTMAN 2645 N.THIRD STREET SUITE 490 HARRISBUR~.~, PA 17110 RE: 18247 ELAINE L. NACE Entire medical correspondenc memoranda, h prescription re computer data] diagnosis or tr file, including but not limited to any and all records, .~ to and from the consulting and treating physicians, fries, andwritten notes, history and physical reports, medication/ cords, including any and all such items as may be stored in a ~ase or otherwise in electronic form, relating to any examination, ~atment pertaining to: Dates Requested: up to and including the present. Subject: ELAINE L. NACE 3,~4~.2..Nb.S~sCOND STREET, WORMLEYSBURG, Pa 17043 Social Securi~ #: 202-36-6026 ' SU10-418272 · 824 7--LO 7 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER 0~ ELAINE NAC5 -VS- COURT OF COMMON PLEAS TERM, CASE NO: 02-2169 DANIEL R. ~ND RUTH MILLER AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4099.22 i MCS on behalf of ANDREW C. LEHMAN', ESQ. ~ certifies that (1) A!notice of intent to serve the subpoena with a copy of the subpoena a~tached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be se (2) A at (3) No rved, copy of the notice of intent, including the proposed subpoena, is tached to this certificate, objection to the subpoena has been received, and (4) T~e subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/27/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-388693 1 824 7--LO 8 COMMONWEALTH OF PES[NSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER 0F: ELAINE NA!E DANIEL R.}AND RUTH MILLER COURT OF COMMON PLEAS TERM, CASE NO: 02-2169 NOTICE TO: R. ~A~ ~CS on bet identical days from undersigne waived or copies of the attach MCS office DATE: 01/0 CC: ANDRKd OF ~ TO SERVE A SUBPOI~qA TO PRODUCE DO~S AN~ FOR DISO3~tY ~tm/~ TO R~I~ 4009.21 [ Note: see enclosed list of locations ] K THOMAS, 8SO. all of ~qDREM C. LEHMAN, ESQ. intends to serve a subpoena to the one that is attached to this notice. You have twenty (20) the date listedbelo~ in which to file of record and serve upon the d an objection to the subpoena. If the twenty day notice period is if no objection is made, then the subpoena may be served. Complete any reproduced records may be ordered at your expense by completin9 ed counsel card and returnin9 same to ~CS or by contactin9 our local /2oo C. LEHIOHI, - 02-252 MCS on behalf of ANDREM C. LBH~N, ESQ. Attorney for DRFRNDANT ~ny questipns regar~kLng this ~atter, contact THR MCS GROUP INC. 1601 MAPART STRRRT J800 PHILADRLPHIA, PA 19103 (215) 246-0900 DR02-211649 · 8 2 4 7 --CO · LOCATION LIST ¢¢¢ PAGE: 1 LOCATION NANR RECORDS REQUESTED EXPERIENCB NOI~KS CO~9~ON SENSBE~PTION SERVICES FRANCIS X. SCI&, JR., D.O. HOLY SPIRIT H~SPITAL DR. EDN~ SC~P~, D. C. JOHN N. PIK~N D.O. DR. STUART ~~ EDN~ S. VI0~GO, N.D. EMPLOYMENT EMPLOYMENT M~DICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RHCORDS DE02-211649 1 8 2 4 7 --CO i COMMONWF~LTH OF P~qNSYLVANL* COUNTY OF CUMBERLAN~ ELAINE NA¢ DANIEL R. TO:. cusu Within twemy thinp: ~ ~ MCS Gt You my derive advance, the rea :E VS & RUTH MILLER File No. 02-2169 'ODIAN SUBPOENA TO PRODUC~ DOCU] ~V~_ S OR THINGf FOR DISCO¥~.~gY PU]~_~U~'TO RULE OF RECORDS FOR: EDUARDO VIOLAGO 20) d~s &q~r Mrvi~ o~ this mblMetW, you ire ordered by the cout to produce the followtn~ ~ ~ .OUP INC., 1601MAR~T ST., #800, PBiLA..,PA 19103 (i ~pum~. m me iMny ~ thi. req,N.e m the ~ddmm 11.~1 above. Yo~ have &- -'-~'-:?'----Y ';' ..... iomlble coat of pmparins th~ ~ m, pmducJns th~ tld~.~l mu~hL me rt~M to Me~, m servin~ thb sub twenty (20) chys ~ its service, the Pm7 THIS SUBI~ENA WAS ISSUSD AT TH~ R~QU~ST OF TH~ FOLLOWING Pl~lSON: Seal of the Court BY TH~ COURT:/~ ..L. ,//) ,~ / (F~. EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: EDWARD S. ~rIOLAGO, M.D. POLYCLINI(~ MEDICAL CTR. 2601 N. 3RD ,STREET HARRISBURg, PA 17110 RE: 18247 N~CE ELAINE L. Entire medical correspondenc, memoranda, h file, including but not limited to any .and all records, ,' to and from the consulting and treating physicians, fries, mdwritten notes, history and physical reports, medicatiord prescription re.'ords, including any and all such items as may be stored in a computer datal~ase or otherwise in electronic form, relating to any examination, diagnosis or tr, mtment pertaining to: Dates Requesl ed: up to and including the present. Subject: EL,a INE L. NACE 344 N. SECOND STREET, WORM1.EYSBURG, PA 17043 Social Securit ~' #: 202-36-6026 SU10-418274 1 824 7--LO 8 ELAINE NACE, Plaintiff, DANIEL R. MILLER and RUTH MILLER (nee RUTH REINARD), husband and wife, Defendants. IN THE COURT OF COMMON PLEAS CUMBERI.AND COUNTY, PENNA. NO.: 02-;).169 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO MARK SETTLED AND DISCONTINUE TO THE PROTHONOTARY: Please mark the above-captioned matter settled, satisfied and the docket discontinued. Date: Respectfully submitted, By: R. Mark Thomas, Esquire Attorney I.D. # 101 South Market Street Mechanicsburg, PA 17055 (717) 697-4650