HomeMy WebLinkAbout02-2596
ROBBIN R. MASTEN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
2002- d59~ CIVaTERM
JEFFREY L. BIXLER,
Defendant
:
CIVa ACTION - LAW
PRAECIPE FOR ISSUANCE OF A WRIT OF SUMMONS
TO CURTIS R. LONG, PROTHONOTARY:
Please issue a Writ of Summons against the defendant, JEFFREY L. BIXLER, and enter my appearance
on behalf of the plaintiff, Robbin R. Masten, Please direct the Sheriff to serve the defendant as follows:
Jeffrey L. Bixler
44 Sandy Bottom Road
Carlisle, P A 17013
Respectfully submitted,
By:
May 27, 2002
To: JEFFREY L. BIXLER
You are hereby notified that Robbin R. Masten, plaintiff, has commenced an action against you which
you are required to defend or a default judgment may be entered against you.
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PROTH OTARY
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Date: ~ .;18" , 2002
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SHERIFF'S RETURN - REGULAR
CASE NO: 2002-02596 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MASTEN ROBBIN R
VS
BIXLER JEFFREY L
DAVID MCKINNEY
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within WRIT OF SUMMONS
was served upon
BIXLER JEFFREY L
the
DEFENDANT
, at 1909:00 HOURS, on the 30th day of May
, 2002
at 44 SANDY BOTTOM ROAD
CARLISLE, PA 17013
by handing to
JEFFREY BIXLER
a true and attested copy of WRIT OF SUMMONS
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
4.14
.00
10.00
.00
32.14
So Answers:
r~r/t(:~~
R. Thomas Kline
Sworn and Subscribed to before
05/31/2002
IRWIN MCKNIGHT HUGHES
By: IJ,/)~~~ .
Deputy Sheriff~
.......
me this )b ~ day of
rj,u,. ;2.(1-0..2- A.D.
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thonotary I
..
THOMAS, THOMAS & HAFER, LLP
John Flounlacker, Esquire
305 N. Front Street
P,O, Box 999
Harrisburg, PA 17108-0999
(717)237-7134
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance for Defendant, Jeffrey L. Bixler in the above-
captioned case.
THOMAS, THOMAS & HAFER, LLP
ohn F ounlacker, Esquire
I.D. Number: 73112
305 North Front Street
P.O. Box 999
Harrisburg, PA 17101
(717)237-7134
Counsel for Defendant
Dated: ~!o 2.
.'
CERTIFICATE OF SERVICE
Hafer, LLP, hereby state that a true and correct copy of the foregoing Entry of
I. Jeannie L. Kawalec, an employee for the law firm Thomas, Thomas &
Appearance was served upon all counsel of record by first class United States mail,
postage prepaid, addressed as follows, on the date set forth below:
Bv First Class U.S. Mail:
Marcus A. McKnight, III, Esquire
60 West Pomfest Street
Carlisle, PA 17013
THOMAS, THOMAS & HAFER, LLP
Dated: 7/.L/OL-
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eannie L. Kawalec
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THOMAS, THOMAS & HAFER, LLP
John Flounlacker, Esquire
305 N. Front Street
P.O. Box 999
Harrisburg, PA 17108-0999
(717)237-7134
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
PRAECIPE TO FILE A COMPLAINT
TO THE PROTHONOTARY:
Please enter a RULE upon Plaintiff to file a Complaint within twenty (20) days
hereof or suffer the entry of a Judgment of Non Pros.
RULE TO FILE A COMPLAINT
AND NOW, this 3(L.&-Lday of July ,2002, a RULE is hereby granted upon
Plaintiffs to file a Complaint herein within twenty (20) days after service hereof or suffer
the entry of a Judgment of Non Pros.
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PROTHONOTARY ~
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THOMAS, THOMAS & HAFER, LLP
John Flounlacker, Esquire
305 N, Front Street
P,O, Box 999
Harrisburg, PA 17108-0999
(717)237-7134
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No.: 2002- 2596
ROBBIN R. MASTEN,
Plaintiff
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
I. Jeannie L. Kawalec, an employee for the law firm Thomas, Thomas &
Hafer, LLP, hereby state that a true and correct copy of the Rule to File Complaint dated
July 3, 2002 was served upon all counsel of record by first class United States mail,
postage prepaid, addressed as follows, on the date set forth below:
Bv First Class U.S. Mail:
Marcus A. McKnight, III, Esquire
60 West Pomfest Street
Carlisle, PA 17013
THOMAS, THOMAS & HAFER, LLP
Dated: 7 / '7/0 L
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ROBBIN R. MASTEN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
2002-2596 CML TERM
JEFFREY L. BIXLER,
Defendant
JURY TRIAL DEMANDED
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this complaint, order 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 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 ALA WYER, 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
(717) 249-3166
1-800-990-9108
1
Americans with Disabilities
Act of 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our
office. All arrangements must be made at least 72 hours prior to any hearing or business before the
court. You must attend the scheduled conference or hearing.
2
ROBBIN R. MASTEN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
2002-2596 CIVIL TERM
JEFFREY L. BIXLER,
Defendant
JURY TRIAL DEMANDED
COMPLAINT
AND NOW, this 14th day of August 2002 come the PlaintitT, Robbin R. Masten, by and
through her attorneys, Irwin, McKnight & Hughes, and makes the following Complaint against
the Defendant, Jeffrey L. Bixler:
1.
The Plaintiff is Robbin R. Masten, an adult individual residing at 15 McCoy Lane,
Carlisle, Pennsylvania 17013.
2.
The Defendant is Jeffrey L. Bixler, an adult individual residing at 44 Sandy Bottom Road,
Carlisle, Pennsylvania 17013.
3.
On May 29, 2000, PlaintitT, Robbin R. Masten, resided at 10 Sandy Bottom Road,
Carlisle, Pennsylvania 170 13, at the time of the accident. The Plaintiff took her new puppy on
a leash to introduce the new puppy to her neighbors, Jeffrey L. Bixler and his children.
Unfortunately, they were not home at the time, and the Plaintiff proceed to walk home
past the Defendant's dog which was tied next to the sidewalk.
3
4.
In order to exit the Defendant's property, the Plaintiff and her puppy had to pass the
Defendant's dog which was tied up near the garage. A cat belonging to Defendant, Jeffi:ey L.
Bixler, appeared nearby and proceeded to jump on the Defendant's dog and then upon the
Plaintiff's dog attacking each dog by biting, scratching and clawing. Neither dog provoked the
cat to attack or caused the cat any distress or alann.
5.
The cat then proceeded to attack Plaintiff by jumping on Plaintiff's right leg and began to
hang on her leg with its claws and teeth, biting, clawing and scratching until the Plaintiff was
able to dislodge the cat by knocking it off of her leg.
6.
Immediately following the attack, the Plaintiff's husband rushed her to the emergency
room at Carlisle Regional Medical Center where the physicians cleaned the wounds and
discussed further treatment with the Plaintiff.
7.
Due to the unprovoked nature of the cat attack, the physicians advised the Plaintiff that it
was in her best interest to proceed with a series of five (5) anti-rabies injections in the event the
cat had been infected with rabies (Hydrophobia). The Plaintiff underwent the series of injections
at the physician's recommendation.
8.
On May 31, 2000, the Plaintiff returned to the emergency room at the Carlisle Regional
Medical Center with a secondary infection to the wounds she received from the cat attack.
4
9.
As a result of the attack by Defendant's cat, the Plaintiff, Robbin R. Masten, has
sustained damages consisting of intensive treatment for the prevention of rabies as well as
severe secondary infection. She has also incurred medical expenses as a result of the
Defendant's cat attacking her.
10.
The Plaintiff sustained injuries causing significant pain and suffering and seeks damages
for pain and suffering as well as damages for any permanent injuries.
11.
The Defendant, Jeffrey L. Bixler, was negligent in that he failed to do the
following:
a. To control the cat he maintained on his premises.
b. To warn visitors that a cat on the premises may attack.
c. To provide a safe entrance to his home.
d. To maintain a cat on his premises which he knew to be dangerous.
e. To adequately control the cat which was unleashed at the time of the attack.
12.
The negligence of the Defendant, Jeffrey L. Bixler, is the proximate cause of the injuries
sustained by the Plaintiff, Robbin R. Masten.
5
WHEREFORE, the Plaintiff, Robbin R. Masten, requests compensation and damages
from the Defendant, Jeffrey L. Bixler, in the amount in excess of Twenty-Five Thousand and
no/100 ($25,000.00) Dollars with interest as permitted by law and the costs of this litigation.
Respectfully submitted,
By:
Date: August 14,2002
6
VERIFICATION
The foregoing Complaint is based upon information which has been gathered by
counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unsworn falsification to authorities.
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ROB IN R. STE
Date: AUGUST 14, 2002
ROBBIN R. MASTEN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
2002-2596 CIVIL TERM
JEFFREY L. BIXLER,
Defendant
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached Complaint was
served upon the following by depositing a true and correct copy of the same in the United States
mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and
addressed as follows:
John F1ounlacker, Esq.
Thomas, Thomas & Hafer, LLP
305 North Front Street
P. O. Box 999
Harrisburg, PA 17108
IRWIN, McKNIGHT & HUGHES
By:
Date: August Is, 2002
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THOMAS, THOMAS & HAFER, LLP
John Flounlacker, Esquire
305 N. Front Street
P.O. Box 999
Harrisburg, PA 17108-0999
(717)237-7134
ROBBIN R. MASTEN,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
: JURY TRIAL DEMANDED
NOTICE TO PLEAD
TO ALL PARTIES:
YOU ARE HEREBY REQUIRED to respond to the within New Matter within twenty
(20) days of the date of service hereof or a default judgment may be entered against you.
Respectfully submitted,
THOMAS, THOMAS & HAFER, LLP
~-
Date: ~/to I 02-
By:
Jo Flounlacker, Esquire
Attor ey I.D. # 73112
P.O. Box 999
305 N. Front Street
Harrisburg, PA 17108-0999
THOMAS, THOMAS & HAFER, LLP
John Flounlacker, Esquire
305 N. Front Street
P.O. Box 999
Harrisburg, PA 17108-0999
(717)237-7134
ROBBIN R. MASTEN,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
DEFENDANT, JEFFREY L. BIXLER'S,
ANSWER AND NEW MATTER TO PLAINTIFF'S COMPLAINT
AND NOW ONTO COURT, through undersigned counsel, comes the
Defendant, Jeffrey L. Bixler, who, in Answer to the Complaint of the Plaintiff, respectfully
represents that::
1. It is admitted the Plaintiff is who she says she is.
2. Admitted.
3. The averments in this paragraph are denied generally in accordance with
Pa.R.C.P. 1029(e).
4. The averments in this paragraph are denied generally in accordance with
Pa.R.C.P. 1029(e).
5. The averments in this paragraph are denied generally in accordance with
Pa.R.C.P. 1029(e).
6. The averments in this paragraph are denied generally in accordance with
PaRC.P. 1029(e).
7. The averments in this paragraph are denied generally in accordance with
Pa.R.C.P. 1029(e). By way of further answer the allegations in this paragraph are denied
as after reasonable investigation, answering Defendant lacks information or knowledge
sufficient to form a basis to the belief as to the truth of the averments contained in this
paragraph and same are therefore denied, strict proof being demanded at trial, if relevant.
8. The averments in this paragraph are denied generally in accordance with
Pa.R.C.P. 1029(e). By way of further answer the allegations in this paragraph are denied
as after reasonable investigation, answering Defendant lacks information or knowledge
sufficient to form a basis to the belief as to the truth of the averments contained in this
paragraph and same are therefore denied, strict proof being demanded at trial, if relevant.
9. The averments in this paragraph are denied generally in accordance with
Pa.R.C.P. 1029(e). By way offurther answer the allegations in this paragraph are denied
as after reasonable investigation, answering Defendant lacks information or knowledge
sufficient to form a basis to the belief as to the truth of the averments contained in this
paragraph and same are therefore denied, strict proof being demanded at trial, if relevant.
10. The averments in this paragraph are denied generally in accordance with
Pa.R.C.P. 1029(e). By way of further answer the allegations in this paragraph are denied
as after reasonable investigation, answering Defendant lacks information or knowledge
sufficient to form a basis to the belief as to the truth of the averments contained in this
paragraph and same are therefore denied, strict proof being demanded at trial, if relevant.
11. The Answering Defendant submits that all of the allegations contained
within this paragraph of the Plaintiff's Complaint amount to legal conclusions which
require no Answer. By way of further explanation:
(a) It is specifically denied that Defendant was negligent in failing to
control the cat he maintained on his premises.
(b) It is specifically denied that Defendant was negligent in failing to
warn visitors that a cat on the premises may attack.
(c) It is specifically denied that Defendant was negligent in failing to
provide a safe entrance to his home.
(d) It is specifically denied that Defendant was negligent in maintaining
a cat on his premises which he knew to be dangerous.
(e) It is specifically denied that Defendant was negligent in failing to
adequately control the cat which was unleashed at the time of the attack.
12. Denied.
13. The Answering Defendant submits that all of the allegations contained
within this paragraph of the Plaintiffs Complaint amount to legal conclusions which
require no Answer. By way of further explanations the allegations in this paragraph are
denied.
NEW MA ITER
14. The Plaintiff has failed to state a claim upon which relief may be granted.
15. None of the conduct on the part of the Answering Defendant amount to a
breach of any duty that the Defendant owed to this Plaintiff.
16. At the time of this incident the Plaintiff may have been trespassing.
17. Some and/or all of the Plaintiffs claims may be reduced and/or barred
based on the Plaintiffs negligence.
18. The Plaintiff failed to maintain reasonable control of her animal at all times
relevant to this incident.
19. None of the conduct on the part of the Answering Defendant amounted to
a substantial cause for the Plaintiff's damages.
20. The Plaintiff has suffered no wage loss as a consequence of this incident.
21. The Plaintiff has discontinued any form of medical care and/or treatment in
connection with any injuries that she allegedly received in this incident.
Respectfully submitted,
THOMAS, THOMAS & HAFER, LLP
Date: q/ D/6 l--
By:
John lounla ker, Esquire
Atto ey I.D. # 73112
P.O. Box 999
305 N. Front Street
Harrisburg, PA 17108-0999
(717)237-7134
VERIFICATION
I, Defendant, Jeffrey L. Bixler, hereby state that the statements made in the
foregoing Answer with New Matter to Plaintiffs Complaint are true and correct to the best
of my knowledge, information and belief. The undersigned understands that the
statements therein are made subject to the penalties of 18 Pa.C.SA ~904 relating to
unsworn falsification to authorities.
J!l~xl4L/
. .
CERTIFICATE OF SERVICE
I. Jeannie L. Kawalec, an employee for the law firm Thomas, Thomas &
Hafer, LLP, hereby state that a true and correct copy of the foregoing Answer with New
Matter was served upon all counsel of record by first class United States mail, postage
prepaid, addressed as follows, on the date set forth below:
Bv First Class U.S. Mail:
Marcus A. McKnight, III, Esquire
60 West Pomfest Street
Carlisle, PA 17013
THOMAS, THOMAS & HAFER, LLP
Dated: //;6/0 L
_~'J~
annie L. Kawalec
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Thomas, Thomas & Hafer, LLP
305 N. Front Street
P.O. Box 999
Harrisburg, PA 17108-0999
(717)237-7125
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
As a prerequisite to service of subpoenas for documents and things pursuant to Rule
4009.22, Defendant certifies that:
1. A Notice of Intent to Serve Subpoena with a copy of the subpoena attached
thereto was mailed or delivered to each party;
2.
Certificate;
A copy of the Notice of Intent, including the proposed subpoena, is attached to this
3.
More than twenty (20) days have elapsed and no objections have been filed; and
4. The subpoena which will be served is identical to the subpoena which is attached
to the Notice of Intent to Serve Subpoena.
THOMAS, THOMAS & HAFER, LLP
Date: December'--~, 2002
By:
~~
JOHr( FLOUNLACKER, ESQUIRE
Attorney for Defendant
216114-1
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THOMAS, THOMAS & HAFER, LLP
John Flounlacker, Esquire
305 N. Front Street
P.O. Box 999
Harrisburg, PA 17108-0999
{717}237-7134
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No.: 2002- 2596
ROBBIN R. MASTEN,
Plaintiff
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
TO: Counsel of Record
Defendant 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 no objection is made,
the subpoena will be served.
THOMAS, THOMAS & HAFER, LLP
Date: November J~2002
By:
JOH~N~
Attorney for Defendant
212134-1
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Carlisle Regional 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:
A complete copy of all records pertaining to ROBBIN R. MASTEN. including but not
limited to: notes of visits. reports. consultations. records of other health care providers.
reports of diagnostic studies and bills.
at: Thomas. Thomas & Hafer. LLP. 305 N. Front Street. Harrisburg. PA 17101
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with
the certificate of compliance, to the party making this request at the address listed above. You have the right to seek
in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the
party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: John Flounlacker, Esquire
ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717) 237-7125
SUPREME COURT 10#: 73112
A TIORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk, Civil Division
Deputy
212192-1
CERTIFICATE OF SERVICE
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AND NOW, thisok-~ day of November, 2002, I, DEENA D. BOLZE, a Paralegal in
the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that I sent a true and correct
copy of the foregoing document by placing a copy of the same in the United States Mail,
first class, postage prepaid, to the following:
Marcus A. McKnight, III, Esquire
60 West Pomfret Street
Carlisle, PA 17013
/1
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Deena D. Bolze, Paralegal
212134-1
John Flounlacker, Esquire
Thomas, Thomas & Hafer, LLP
305 N. Front Street
P.O. Box 999
Harrisburg, PA 17108-0999
(717)237-7125
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
AND NOW, this ~O1! day of December 2002, I, DEENA D. BOLZE, a Paralegal
in the law firm of Thomas, Thomas & Hafer LLP, hereby certify that I sent a true and
correct copy of the foregoing document by placing a copy of the same in the United States
Mail, first class, postage prepaid, to the following:
Marcus A. McKnight, III, Esquire
60 West Pomfret Street
Carlisle, PA 17013
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Deena D. BOIze, Paralegal! -
216114-1
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John Flounlacker, Esquire
Thomas, Thomas & Hafer, LLP
305 N. Front Street
P,O. Box 999
Harrisburg, PA 17108-0999
(717)237-7125
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No,: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
CERTIFICATE
PREREQUISITE TO SERVICE OF SUBPOENAS
PURSUANT TO RULE 4009.22
As a prerequisite to service of subpoenas for documents and things pursuant to Rule
4009,22, Defendant certifies that:
1. A Notice of Intent to Serve Subpoenas with copies of the subpoenas attached
thereto was mailed or delivered to each party;
2. A copy of the Notice of Intent, including the proposed subpoenas, is attached to
this Certificate;
3. More than twenty (20) days has elapsed and no objections have been filed; and
4. The subpoenas which will be served are identical to the subpoenas which are
attached to the Notice of Intent to Serve Subpoenas.
THOMAS, THOMAS & HAFER, LLP
Date: July 21, 2003
By:
JOH~~
Attorney for Defendant
216114.2
THOMAS, THOMAS & HAFER, LLP
305 North Front Street
P.O. Box 999
Harrisburg, PA 17108
John Flounlacker, Esquire
Attorney 1.D. 73112
(717)237-7134
Attorneys for Defendant
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NOTICE OF INTENT TO SERVE SUBPOENAS
TO PRODUCE DOCUMENTS AND THINGS FOR
DISCOVERY PURSUANT TO RULE 4009.21
TO: Counsel of Record
Defendant intends to serve subpoenas identical to the ones that are attached to
this Notice. You have twenty (20) days from the d ate listed below in which to file of
record and serve upon the undersigned an objection to the subpoenas. If no objection is
made, the subpoenas will be served.
THOMAS, THOMAS & HAFER, LLP
Date: June 25, 2003
By:
9tk~
JOHN FLOUNLACKER
Attorney for Defendant
212134.2
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Familv Medical Center of Cumberland Vallev, 5 Willow Mil Park Road,
Mechanicsbura. PA 17050
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things;
A complete copv of all records pertainina to ROBBIN R. MASTEN (DOB: 8/16/66: SSN:
521-21-6675) includinq. but not limited to: patient histories. correspondence. memos.
proaress notes. reports. consultations. records of other health care providers, reports of
diaanostic studies and medical bills
at: Thomas, Thomas & Hafer. LLP. 305 N. Front Street. Harrisbura. PA 17101
(Address)
You may deliver or mail legible copies of thl!' documents or produce things requested by this subpoena, together with
the certificate of compliance, to the party making this request at the address iisted 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: John Flounlacker, Esquire
ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717) 237-7125
SUPREME COURT ID#: 73112
ATTORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk. Civil Division
Deputy
212192.3
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009,22
TO: Rov E. Kerry, MoO.. 17 6th Avenue, Greenville. PA 16125
Within twenty (20) days after service of this subpoena. you are ordered by the court to produce the following
documents or things:
A complete COpy of all records pertainina to ROBBIN R. MASTEN (DOB: 8/16/66: SSN:
521-21-6675) includina, but not limited to: patient histories. correspondence. memos,
proaress notes. reports, consultations, records of other health care providers, reports of
diaanostic studies and medical bills
at: Thomas, Thomas & Hafer. LLP. 305 N. Front Street Harrisbura, PA 17101
(Address)
You may deliver or maii 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: John Flounlacker, Esquire
ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717) 237-7125
SUPREME COURT 10#: 73112
ATTORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk, Civil Division
Deputy
212192-4
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLANO
ROBBIN R. MASTEN,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Dr. Stephen Davis. 1863 Center Street. Camp Hill. PA 17011
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things:
A complete copv of all records pertainino to ROBBIN R. MASTEN (DOB: 8/16/66: SSN:
521-21-6675) includinq, but not limited to: patient histories. correspondence, memos.
prooress notes, reports, consultations, records of other health care providers, reports of
diaqnostic studies and medical bills
at: Thomas, Thomas & Hafer. LLP, 305 N. Front Street. Harrisburo, PA 17101
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with
the certificate of compliance, to the party making this request at the address listed above, You have the i'ight 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 compeliing you to comply with It.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: John Flounlacker, Esquire
ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717) 237-7125
SUPREME COURT ID#: 73112
ATTORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk, Civil Division
Deputy
212192.5
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Dr. Richard M. Seldow. D.C.. 431 Bridqe Street New Cumberland. PA 17070
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things:
A complete copv of all records pertaininq to ROBBIN R. MASTEN (DOB: 8/16/66: SSN:
521-21-6675) includinq, but not limited to: patient histories. correspondence. memos.
proqress notes, reports. consultations, records of other health care providers, reports of
diaqnostic studies and medical bills
at: Thomas, Thomas & Hafer, LLP. 305 N. Front Street Harrisburq. PA 17101
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this subpoena. together with
the certificate of compliance. to the party making this request at the address listed above. You have the right to seek
in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena. within twenty (20) days after its service. the
party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: John Flounlacker, Esquire
ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717) 237-7125
SUPREME COURT 10#: 73112
ATTORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk, Civil Division
Deputy
212192.6
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Dr. Jimenez, 4401 Farqreen Road. Harrisburq, PA 17110
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the foliowing
documents or things:
A complete copv of all records pertaininq to ROBBIN R. MASTEN (DOB: 8/16/66: SSN:
521-21-6675) includinq. but not limited to: patient histories, correspondence. memos,
proqress notes. reports, consultations, records of other health care providers, reports of
diaqnostic studies and medical bills
at: Thomas, Thomas & Hafer, LLP. 305 N. Front Street Harrisburq, PA 17101
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with
-the certificate of compliance, to the party making this request at the address listed above. You have the right 10 seek
in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fall 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: John Flounlacker, Esquire
ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717) 237-7125
SUPREME COURT lD#: 73112
ATTORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk, Civil Division
Deputy
212192.7
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Polvclinic Hospital. 2601 North 3rd Street Harrisburq. PA 17110
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things:
A complete copv of all records pertaininq to ROBBIN R. MASTEN (DOB: 8/16/66; SSN:
521-21-6675) includinq, but not limited to: patient histories, operative reports.
correspondence. memos, proqress notes, reports. consultations, records of other health
care providers, reports of diaqnostic studies and medical bills
at: Thomas. Thomas & Hafer. LLP. 305 N. Front Street. Harrisburq, PA 17101
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with
the certificate of compliance, to the party making thrs 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: John Flounlacker, Esquire
ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717) 237-7125
SUPREME COURT 10#: 73112
ATTORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk, Civil Division
Deputy
212192-8
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBBIN R. MASTEN,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - lAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Orthopedic Institute of Pennsvlvania, 875 Poplar Church Road, Camp Hill. PA
17011
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the foliowing
documents or things:
A complete COpy of all records pertainina to ROBBIN R. MASTEN (DOB: 8/16/66: SSN:
521-21-6675) includina. but not limited to: patient histories, operative reports,
correspondence, memos. proaress notes. reports, consultations, records of other health
care providers. reports of diaanostic studies and medical bills
at: Thomas, Thomas & Hafer. lLP. 305 N. Front Street. Harrisbura, PA 17101
(Address) _ .
You may deliver or mail legible copies of the documents or produce things requested by tliis subpoena, together with
the certificate of compliance, to the perty 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: John Flounlacker, Esquire
ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717) 237-7125
SUPREME COURT 10#: 73112
ATTORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk, Civil Division
Deputy
212192-9
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBBIN R. MASTEN,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: CIGNA. PO Box 15552. Wilminaton. DE 19850
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things:
A complete copv of all claim records pertainina to ROBBIN R. MASTEN (DOB: 8/16/66:
SSN: 521-21-6675: Insured: United Technoloaies: Employee: Thomas Masten:
Employee SSN: 316-66-5095) includina, but not limited to: correspondence, memos,
medical records, notes. reports, consultations, claim forms, statements of injury,
diaanosis, proanosis and medical bills
at: Thomas. Thomas & Hafer, LLP, 305 N. Front Street Harrisbura, PA 17101
(Address) ..
You may deliver or mail legible Copies of the documents or produce things requested by this subpoena, together with
the certificate of compliance, to the party making this request at the address listed above. You have the right to seek
in advance. the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the
party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: John Flounlacker, Esquire
ADDRESS: P,O. Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717) 237-7125
SUPREME COURT ID#: 73112
ATTORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk, Civil DiYision
Deputy
212192-10
CERTIFICATE OF SERVICE
AND NOW, this 25th day of June, 2003, I, DEENA B. MORRISON, a Paralegal in
the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that I sent a true and correct
copy of the foregoing document by placing a copy of the same in the United States Mail,
first class, postage prepaid, to the following:
Marcus A. McKnight, III, Esquire
60 West Pomfret Street
Carlisle, PA 17013
t ~,." l1flt~v
Deena B. Morrison,'Pa legal
212134-2
John Flounlacker, Esquire
Thomas, Thomas & Hafer, LLP
305 N. Front Street
P.O, Box 999
Harrisburg. PA 17108-0999
(717)237-7125
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No.: 2002- 2596
ROBBIN R. MASTEN,
Plaintiff
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
AND NOW, this 21st day of July 2003, I, DEENA B. MORRISON, a Paralegal in the law firm
of Thomas, Thomas & Hafer LLP, hereby certify that I sent a true and correct copy of the foregoing
document by placing a copy of the same in the United States Mail, first class, postage prepaid, to the
following:
Marcus A. McKnight, III, Esquire
60 West Pomfret Street
Carlisle, PA 17013
216114,2
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THOMAS, THOMAS & HAFER, LLP
305 North Front Street
P.O. Box 999
Hanisburg, PA 17108
John Flounlacker, Esquire
Attorney 1.D. 73112
(717)237-7134
Attorneys for Defendant
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
CERTIFICATE
PREREQUISITE TO SERVICE OF SUBPOENAS
PURSUANT TO RULE 4009.22
As a prerequisite to service of subpoenas for documents and things pursuant to Rule
4009.22, Defendant certifies that:
1, A Notice of Intent to Serve Subpoenas with copies of the subpoenas attached
thereto was mailed or delivered to each party;
2. A copy of the Notice of Intent, including the proposed subpoenas, is attached to
this Certificate;
3. More than twenty (20) days has elapsed and no objections have been filed; and
4. The subpoenas which will be served are identical to the subpoenas which are
attached to the Notice of Intent to Serve Subpoenas.
THOMAS, THOMAS & HAFER, LLP
Date: March 22, 2004
By:
~~
JOHN FLOUNLACKER, ESQUIRE
Attorney for Defendant
216114-3
THOMAS, THOMAS & HAFER, LLP
305 North Front Street
P.O. Box 999
Harrisburg, PA 17108
John Flounlacker, Esquire
Attorney LD. 73112
(717)237-7134
Attorneys for Defendant
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NOTICE OF INTENT TO SERVE. SUBPOENAS
TO PRODUCE DOCUMENTS AND THINGS FOR
DISCOVERY PURSUANT TO RULE 4009.21
TO: Counsel of Record
Defendant intends to serve subpoenas identical to the ones that are attached to
this Notice. You have twenty (20) days from the date listed below in which to file of
record and serve upon the undersigned an objection to the subpoenas. If no objection is
made, the subpoenas will be served.
THOMAS, THOMAS & HAFER, LLP
Date: February 27,2004
By:
JO~~
Attorney for Defendant
212134-3
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Carlisle Reqional 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:
A complete copv of all records pertaininq to ROBBIN R. MASTEN. (DOB: 8/16/66;
SSN: 521.21.6675) includinq. but not limited to: admissions records, operative reports,
patient histories, correspondence, memos. proqress notes, evaluations. reports,
consultations, records of other health care providers and reports of diaqnostic studies
from December 2002 to the Dresent
at: Thomas, Thomas & Hafer, LLP, 305 N. Front Street. Harrisburq. PA 17101
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with
the certificate of compliance, to the party making this request at the address listed above. You have the right to seek
in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fali 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: John Flounlacker, Esquire
ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717) 237-7134
SUPREME COURT 10#: 73112
ATTORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk, Civil Division
Deputy
212192-25
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Sportino Hill Medical Center, 35 S. Sportino Hill Road. Mechanicsburo, PA 17055
(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:
A complete COpy of all records pertainino to ROBBIN R. MASTEN. (OOB: 8/16/66;
SSN: 521-21-6675) includino, but not limited to: patient histories, correspondence,
memos, prooress notes. evaluations, therapy records. reports, consultations. records of
other health care providers and reports of diaonostic studies from 1990 to the present
at: Thomas, Thomas & Hafer, LLP, 305 N. Front Street, Harrisburo, PA 17101
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with
the certificate of compliance, to the party making this request at the address listed above. You have the right to seek
in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the
party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: John Flounlacker, Esquire
ADDRESS: P.O, Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717) 237-7134
SUPREME COURT ID#: 73112
ATTORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk, Civil Division
Deputy
212192-26
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 4002- 2596
CIVIL IACTION - LAW
JEFFREY L. BIXLER
Defendant
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Huona Kina LAC, 196 Thomas Johnson Drive. #125, Frederick, MD 21702
Within twenty (20) deys after service of this subpoena, you are ordered by the court to produce the following
documents or things:
A complete COpy of all records pertainina to ROBBIN R. MASTEN (DOB: 8/16/66: SSN:
521-21-6675) includina. but not limited to: patient histories, correspondence. memos.
proaress notes. notes of office visits, evaluations, reports. consultations. records of
other health care providers, reports of diaanostic studies and medical bills from 1990 to
the present
at: Thomas. Thomas & Hafer. LLP, 305 N. Front Stree!. Harrisbura. PA 17101
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with
the certificate of compliance, to the party making this request at the address listed above. You have the right to seek
in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the
party serving this subpoena may seek a court order compelling you to compiy with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: John Flounlacker, Esquire
ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717) 237-7134
SUPREME COURT ID#: 73112
ATTORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk, Civil Division
Deputy
212192-11
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBBIN R. MASTEN.
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Hetrick Center. 500 N. Union Street. Middletown, PA 17057
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things:
A complete copv of all records pertainino to ROBBIN R. MASTEN (DOB: 8/16/66: SSN:
521-21-6675) includino, but not limited to: patient histories, correspondence, memos.
prooress notes, notes of office visits, evaluations, reports. consultations. records of
other health care providers and reports of diaonostic studies from 1990 to the present
at: Thomas. Thomas & Hafer, LLP, 305 N. Front Street Harrisburo, PA 17101
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with
the certificate of compliance. to the party making this request at the address listed above, You have the right to seek
in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the
party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: John Flounlacker, Esquire
ADDRESS: P.O. Box 999, Harrisbur9. PA 17108-0999
TELEPHONE: (717) 237-7134
SUPREME COURT 10#: 73112
ATTORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk, Civil Division
Deputy
212192-'2
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Belvedere Medical Corporation. Department of Familv Practice. 850 Walnut Bottom
Road. Carlisle. PA 17013
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things:
A complete copv of all records pertainina to ROBBIN R. MASTEN (DOB: 8/16/66: SSN:
521-21-6675) includina, but not limited to: patient histories, correspondence, memos.
proaress notes, notes of office visits. evaluations. reports. consultations, records of
other health care providers and reports of diaanostic studies from 1990 to the present
at: Thomas, Thomas & Hafer, LLP, 305 N. Front Street Harrisbura, PA 17101
(Address)
You may deliver or mail iegible 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: John Flounlacker, Esquire
ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717) 237-7134
SUPREME COURT ID#: 73112
ATTORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk, Civil Division
Deputy
212192-13
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Holv Spirit Hospital, 503 N. 21st Street. Camp Hill. PA 17011-2204
Within twenty (20) days after service of this subpoena. you are ordered by the court to produce the following
documents or things:
A complete copv of all records pertaininq to ROBBIN R. MASTEN (DOB: 8/16/66: SSN:
521-21-6675) includinq. but not limited to: admissions records. operative reports.
patient histories, correspondence, memos. proqress notes, evaluations, reports,
consultations. records of other health care providers and reports of diaqnostic studies
from 1990 to the present
at: Thomas, Thomas & Hafer. LLP, 305 N. Front Street. Harrisburq. PA 17101
(Address)
You may deiiver 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 iisted 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: John Flounlacker, Esquire
ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717) 237-7134
SUPREME COURT ID#: 73112
ATTORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk, Civil Division
Deputy
212192-14
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Adams Chiropractic, PC, 246 South Lehiqh Avenue. Frackville. PA 17931
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things:
A complete copv of all records pertaininq to ROBBIN R. MASTEN (DOB: 8/16/66: SSN:
521-21-6675) includinq. but not limited to: patient histories, correspondence. memos,
proqress notes, evaluations, reports, consultations. notes of office visits, therapv
records, records of other health care providers and reports of diaqnostic studies from
1990 to the present
at: Thomas. Thomas & Hafer, LLP, 305 N. Front Street. Harrisburq. PA 17101
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with
the certificate of compliance, to the party making this request at the address listed above, You have the right to seek
in advance, the reasonable cost of preparing the copies or producing the things sought.
if you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the
party serving this subpoena may seek a court order compeiling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: John Flounlacker, Esquire
ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717) 237-7134
SUPREME COURT ID#: 73112
ATTORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk, Civil Division
Deputy
212192-15
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Geisinqer Clinic, 100 North Academv Avenue, Danville. PA 17822
Within twenty (20) days aller service of this subpoena, you are ordered by the court to produce the following
documents or things:
A complete copv of all records pertaininq to ROBBIN R. MASTEN (DOB: 8/16/66: SSN:
521-21-6675) includinq, but not limited to: hospital admissions. patient histories.
correspondence. memos, proqress notes. evaluations. reports, consultations, notes of
office visits. therapy records. records of other health care providers and reports of
diaqnostic studies from 1990 to the present
at: Thomas, Thomas & Hafer. LLP, 305 N. Front Street, Harrisburq, PA 17101
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with
the certificate of compliance. to the party making this request at the address listed above. You have the right to seek
in advance. the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena. within twenty (20) days aller 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: John Flounlacker, Esquire
ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717) 237-7134
SUPREME COURT ID#: 73112
ATTORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk, Civil Division
Deputy
212192-16
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Harrisburq Hospital. 111 S. Front Street, Harrisburq, PA 17101
Within twenty (20) days after service of this subpoena. you are ordered by the court to produce the following
documents or things:
A complete COpy of all records pertaininq to ROBBIN R. MASTEN (DOB: 8/16/66: SSN:
521-21-6675) includinq, but not limited to: hospital admissions. operative reports,
patient histories, correspondence. memos. proqress notes, evaluations. reports,
consultations. notes of office Yisits, therapy records, records of other health care
providers and reports of diaqnostic studies from 1990 to the present
at: Thomas, Thomas & Hafer. LLP. 305 N. Front Street. Harrisburq. PA 17101
(Address)
You may deliver or mall 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: John Flounlacker, Esquire
ADDRESS: P.O. Box 999, Harrisburg. PA 17108-0999
TELEPHONE: (717) 237-7134
SUPREME COURT ID#: 73112
ATTORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk, Civil Division
Deputy
212192-17
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Kevstone Rehabilitation, 665 Philadelphia St Indiana. PA 15701
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things:
A complete copv of all records pertainino to ROBBIN R. MASTEN (DOB: 8/16/66: SSN:
521-21-6675) includino, but not limited to: patient histories. correspondence. memos.
prooress notes. evaluations, reports. consultations. notes of office visits. therapv
records, records of other health care providers and reports of diaonostic studies from
1990 to the present
at: Thomas, Thomas & Hafer. LLP. 305 N. Front Street Harrisburo, PA 17101
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with
the certificate of compliance, to the party making this request at the address listed above, You have the right to seek
in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena. within twenty (20) days after its service, the
party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: John Flounlacker, Esquire
ADDRESS: P,O. Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717) 237-7134
SUPREME COURT ID#: 73112
ATTORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk, Civil Division
Deputy
212192.18
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBBIN R. MASTEN,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Laurel Hiqhlands Health Center, 911 Liqonier Street #1. Latrobe. PA 15650
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things:
A complete copv of all records pertaininq to ROBBIN R. MASTEN (OOB: 8/16/66: SSN:
521-21-6675) inciudinq, but not limited to: patient histories, correspondence. memos,
proqress notes, evaluations. reports. consultations, notes of office visits, therapv
records, records of other health care providers and reports of diaqnostic studies from
1990 to the present
at: Thomas, Thomas & Hafer, LLP, 305 N. Front Street Harrisburo, PA 17101
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with
the certificate of compliance, to the party making this request at the address listed above, You have the right to seek
in advance, the reasonable cost of preparing the copies or producing the things sought.
if you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the
party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: John Flounlacker, Esquire
ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717) 237-7134
SUPREME COURT 10#: 73112
ATTORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk, Civil Division
Deputy
212192-19
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Kilmore Eve Associates. 890 Century Drive, Mechanicsbura, PA 17055-4375
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things:
A complete copv of all records pertainina to ROBBIN R. MASTEN (DOB: 8/16/66; SSN:
521-21-6675) includina, but not limited to: patient histories, correspondence, memos.
proaress notes. notes of office visits. reports and records of other health care providers
from 1990 to the present
at: Thomas, Thomas & Hafer. LLP. 305 N. Front Street. Harrisbura, PA 17101
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with
the certificate of compliance. to the party making this request at the address listed above. You have the right to seek
in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena. within twenty (20) days after its service. the
party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: John Flounlacker, Esquire
ADDRESS: P.O, Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717) 237-7134
SUPREME COURT ID#: 73112
ATTORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk, Civil Division
Deputy
212192-21
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: John M. Sullivan, M.D. & Assoc" 1001 S. Market Street. Suite B, Mechanicsburq.
PA 17055
Within twenty (20) days after service of this subpoena. you are ordered by the court to produce the following
documents or things:
A complete COpy of all records pertaininq to ROBBIN R. MASTEN (OOB: 8/16/66: SSN:
521-21-6675) includinq, but not limited to: patient histories. correspondence. memos,
proqress notes. evaluations, reports, consultations, notes of office visits, therapy
records. records of other health care providers and reports of diaqnostic studies from
1990 to the present
at: Thomas. Thomas & Hafer, LLP, 305 N. Front Street. Harrisburq. PA 17101
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with
the certificate of compliance, to the party making this request at the address listed above. You have the rtght 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: John Flounlacker, Esquire
ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717) 237-7134
SUPREME COURT ID#: 73112
ATTORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk, Civil Division
Deputy
212192-22
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Robert Skotnicki, DO, 856 Century Drive, Mechanicsburq, PA 17055
Within twenty (20) days after selVice of this subpoena. you are ordered by the court to produce the following
documents or things:
A complete copv of all records pertaininq to ROBBIN R. MASTEN (DOB: 8/16/66: SSN:
521-21-6675) includinq. but not limited to: patient histories, correspondence, memos.
proqress notes, evaluations, reports. consultations. notes of office visits, therapv
records. records of other health care providers and reports of diaqnostic studies from
1990 to the present
at: Thomas. Thomas & Hafer. LLP, 305 N. Front Street. Harrisburq. PA 17101
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with
the certificate of compliance, to the party making this request at the address listed above. You have the right to seek
in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its selVice, the
party selVing this subpoena may seek a court order compeliing you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: John Flounlacker, Esquire
ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717) 237-7134
SUPREME COURT 10#: 73112
ATTORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk, Civil Division
Deputy
212192-23
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: PCHC, 1012 West Main Street Stroudsburo, PA 18360
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things:
A complete copv of all records pertainino to ROBBIN R. MASTEN (DOB: 8/16/66: SSN:
521-21-6675) includino. but not limited to: patient histories, correspondence, memos.
prooress notes, notes of office visits, evaluations, reports, consultations. records of
other health care providers and reports of diaonostic studies from 1990 to the present
at: Thomas, Thomas & Hafer, LLP. 305 N. Front Street Harrisburo. PA 17101
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with
the certificate of compliance, to the party making this request at the address listed above. You have the right to seek
in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the
party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: John Flounlacker, Esquire
ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717) 237-7134
SUPREME COURT ID#: 73112
ATTORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk, Civil Division
Deputy
212192-24
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBBIN R. MASTEN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: David Toomev. 0.0.. 2416 Lititz Pike, Lancaster. PA 17601
(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:
A complete copv of all records pertaininq to ROBBIN R. MASTEN. (OOB: 8/16/66;
SSN: 521.21.6675) includinq, but not limited to: patient histories, correspondence.
memos. proqress notes, evaluations, therapy records. reports. consultations. records of
other health care providers and reports of diaqnostic studies from 1990 to the present
at: Thomas, Thomas & Hafer. LLP. 305 N. Front Street Harrisburq. PA 17101
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with
the certificate of compliance, to the party making this request at the address listed above. You have the right to seek
in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service. the
party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: John Flounlacker, Esquire
ADDRESS: P,O. Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717) 237-7134
SUPREME COURT 10#: 73112
ATTORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk, Civil Division
Deputy
212192-27
.
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBBIN R. MASTEN,
. Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Skvline Oncoloav
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things:
A complete copv of all records pertainina to ROBBIN R. MASTEN (DOB: 8/16/66; SSN:
521-21-6675) inciudina, but not limited to: patient histories. correspondence, memos.
proaress notes, evaluations, reports, consultations, notes of office visits, therapy
records, records of other health care providers and reports of diaanostic studies from
1990 to the present
at: Thomas, Thomas & Hafer, LLP, 305 N. Front Street. Harrisbura. PA 17101
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this subpoena. together with
the certificate of compliance, to the party making this request at the address listed above, You have the right to seek
in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the
party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: John Flounlacker, Esquire
ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717) 237-7134
SUPREME COURT ID#: 73112
ATTORNEY FOR: Defendant
BY THE COURT:
DATE:
Seal of the Court
Prothonotary/Clerk. Civil Division
Deputy
212192-20
.
CERTIFICATE OF SERVICE
AND NOW, this 27th day of February, 2004, I, DEENA B. MORRISON, a Paralegal
in the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that I sent a true and
correct copy of the foregoing document by placing a copy of the same in the United
States Mail, first class, postage prepaid, to the following:
Marcus A. McKnight, III, Esquire
60 West Pomfret Street
Carlisle, PA 17013
?
212134-3
,
THOMAS, THOMAS & HAFER, LLP
305 North Front Street
P.O. Box 999
Harrisburg, PA 17108
John Flounlacker, Esquire
Attorney!.D, 73112
(717)237-7134
Attorneys for Defendant
ROBBIN R. MASTEN,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No.: 2002- 2596
JEFFREY L. BIXLER
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
AND NOW, this 22,d day of March 2004, I, DEENA B. MORRISON, a Paralegal in the law
firm of Thomas, Thomas & Hafer LLP, hereby certify that I sent a true and correct copy of the
foregoing document by placing a copy of the same in the United States Mail, first class, postage
prepaid, to the following:
Marcus A. McKnight, III, Esquire
60 West Pomfret Street
Carlisle, PA 17013
"
(
,
i
,"-...
216114-3
ROBBIN R. MASTEN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
2002-2596 CIVIL TERM
JEFFREY L. BIXLER,
Defendant
JURY TlUAL DEMANDED
PRAECIPE TO SETTLE AND DISCONTINUE
To Curtis R. Long, Prothonotary:
Please mark the above-captioned case settled and discontinued and issue a Settlement
Certificate to Marcus A. McKnight, ill, Esquire, at 60 West Pomfret Street, Carlisle,
Pennsylvania 17013.
Respectfully submitted,
By:
Date: July 12, 2005
ROBBIN R. MASTEN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
2002-2596 CIVIL TERM
JEFFREY L. BIXLER,
Defendant
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
I, Marcus A, McKnight, ill, Esquire, hereby certify that a copy of attached Praecipe to
Settle and Discontinue was served upon the following by depositing a true and correct copy of
the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the
date referenced below and addressed as follows:
John F1ounlacker, Esq.
Thomas, Thomas & Hafer
305 North Front Street,
P. O. Box 999
Harrisburg, P A 17108
By:
Date: July 12, 2005
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