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HomeMy WebLinkAbout06-6611ANGINO & ROVNER, P.C. Michael E. Kosik, Esquire Attorney ID# : 36513 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: mkosik@angino-rovner.com SHEILA DUNN IN THE COURT OF COMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNA. V. CIVIL ACTION -LAW n :NO. ? -"/I l.. l u I ERNEST WEIRICK 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 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 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 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 32 South Bedford Street Carlisle, PA Telephone number- 717- 249-3166 337659 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas sugnuientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEPFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEQUIR ASISTENCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA Telephone number- 717- 249-3166 337659 SHEILA DUNN Plaintiff V. ERNEST WERUCK Defendant IN THE COURT OF COMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVIL ACTION - LAW T?+-- NO. 01, : JURY TRIAL DEMANDED COMPLAINT 1. Plaintiff Sheila Dunn is an adult individual and citizen of the Commonwealth of Pennsylvania, who resides at 1715 Penn Street, Harrisburg, Dauphin County, Pennsylvania. 2. Defendant Ernest Weirick is an adult individual and citizen of the Commonwealth of Pennsylvania, who resides at 210 Willow Mill Park Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. The facts and occurrences hereinafter related took place on Tuesday, July 12, 2005 at approximately 10:50 a.m., on Interstate 81 southbound in Southhampton Township, Cumberland County, approximately one mile before the Shippensburg exit. 4. Interstate 81 in the area of the accident is a four-lane, limited access interstate highway which has two northbound and two southbound lanes and a grass median with a posted speed limit of 65 miles per hour. 5. At that time, Plaintiff Sheila Dunn was operating a 1999 Suzuki Grand Vitara traveling in the right southbound lane of Interstate 81. 6. At that time and place, Defendant Ernest Weirick was operating a 1983 Buick Centry which he had stopped off the right (west) berm of Interstate 81. 337659 7. At that time and place, Defendant Ernest Weirick attempted to cross both southbound lanes of Interstate 81 from the berm in an attempt to head northbound via an emergency vehicle cross-over. 8. At that time and place, as Defendant Ernest Weirick entered the southbound lane, Plaintiff Sheila Dunn moved to the left in an attempt to avoid the Defendant's vehicle. 9. At that time and place, Defendant Ernest Weirick struck the passenger's side rear of Plaintiff Sheila Dunn's car causing it to lose control. 10. At that time and place, Plaintiff Sheila Dunn's vehicle slid in a south west direction across both southbound lanes, rolling over before coming to rest facing north east off the west berm of Interstate 81. 11. The foregoing accident and all of the injuries and damages set forth hereinafter sustained by Plaintiff Sheila Dunn are the direct and proximate result of the negligent, careless, and reckless manner in which Defendant Ernest Weirick operated his vehicle as follows: (a) attempting to cross the highway to cross the median to travel in the opposite direction in violation of the Pennsylvania Motor Vehicle Code, including §75 Pa.C.S.A. §3311 (b) failure to keep alert and maintain a proper watch for the presence of other motor vehicles on the highway; (c) failing to yield the right-of-way before entering or crossing the roadway in violation of 75 Pa.C.S.A. §3322; (d) failure to signal his intention to enter the travel lane from the berm and waiting until the movement could be made safely; (e) attempting to turn around to travel in the opposite direction when such traffic maneuver was prohibitive and unsafe and in violation of 75 Pa.C.S.A. §3332; (f) failure to drive his vehicle with due regard for the highway and traffic conditions which were existing and of which he was or should have been aware; 337659 (g) failure to have proper and adequate control over his vehicle; and (h) driving his vehicle upon the highway in a manner endangering persons and property and in a reckless manner with careless disregard to the rights and safety of others and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 12. Plaintiff Sheila Dunn sustained painful and severe injuries which include but are not limited to a laceration to the top of her head, concussion, left shoulder pain, right pelvic pain, left shin pain, right knee pain, left chest pain, low back pain from herniated disc and aggravation of a previously healed lower back injury as well as general trauma and aggravation to her nervous system. 13. By reason of the aforesaid injuries sustained by Plaintiff Sheila Dunn, she was forced to incur liability for medical treatment, medications and similar miscellaneous expenses in an effort to restore herself to health, and claim is made therefor. 14. Because of the nature of her injuries, Plaintiff Sheila Dunn has been advised and, therefore, avers that she may be forced to incur similar expenses in the future, and claim is made therefor. 15. As a result of the aforementioned injuries, Plaintiff Sheila Dunn has undergone and in the future will undergo great physical and mental suffering, great inconvenience in carrying out her daily activities, loss of life's pleasures and enjoyment, and claim is made therefor. 16. As a result of the aforementioned injuries, Plaintiff Sheila Dunn has sustained work loss, loss of opportunity and a permanent diminution of his earning power and capacity, 337659 and claim is made therefor. WHEREFORE, Plaintiff Sheila Dunn demands judgment against Defendant Ernest Weirick in an amount in excess of Thirty-Five Thousand ($35,000.00) Dollars, Exclusive of interest and costs, and in excess of any jurisdictional amount requiring compulsory arbitration- Michael E. Kosik I.D. No. 36513 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Attorney for Plaintiff 337659 VERIFICATION I, SHEILA DUNN, do swear and affirm that the facts set forth in the foregoing COMPLAINT are true and correct to the best of my knowledge, information and belief. I understand that this verification is made subject to the penalties of the Rules of Civil Procedure relating to unworn falsification to authorities. Dated: 1 oC? ` SHEILA DUNN N ? 4 ~s W C;l C 7_ ;;7 BARRY A KRONTHAL, ESQUIRE Pa. Supreme Court I.D. No. 55672 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17110 Attorney for: Telephone: [717] 760-7503 DEFENDANT, Fax: [717] 975-8124 ERNEST WEIRICK E-mail:bkronthal@margolisedelstein.com SHEILA DUNN IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ERNEST WEIRICK NO. 06-6611 Defendant JURY TRIAL DEMANDED PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly enter my appearance on behalf of Defendant, Ernest Weirick, in the above- captioned matter. MARGOLIS DATE: 12- 121? BY: . nt al, Esquire Attorney o. 672 3510 Trindle Road Camp Hill, PA 17011 (717) 760-7503 CERTIFICATE OF SERVICE I, the undersigned, do hereby certify that I have this 4 day of 06 served a true and correct copy of the Praecipe to Enter Appearance upon the person(s) via first class postage prepaid regular mail to: Michael E. Kosik, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 y? Carol Moose 2 ?. c .:? ?, ??' <_"?? r_., '? r,.- ?' C - T, 'w1 ? ;'ter i _,) ' F?fl ?? "'? --'.7 SHERIFF'S RETURN - REGULAR CASE NO: 2006-06611 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DUNN SHEILA VS WEIRICK ERNEST JASON VIORAL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon T.TT. TnTrTI '00NTUC'' the DEFENDANT , at 1715:00 HOURS, on the 17th day of November 2006 at 210 WILLOW MILL PARK ROAD MECHANICSBURG, PA ERNEST WEIRICK by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 7.92 Postage .39 - .? Surcharge 10.00 R. Thomas Kline .00- 36.31 ? 11/20/2006 ANGINO & ROVNER ?,2 /0 7?LCm Sworn and Subscibed to By: before me this day ep ty Sheriff of A.D. BARRY A KRONTHAL, ESQUIRE Pa. Supreme Court I.D. No. 55672 GOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17110 Telephone: [717] 760-7503 Fax: [717] 975-8124 E-mail:bkronthal@margolisedelstein.com SHEILA DUNN Plaintiff V. ERNEST WEIRICK Defendant Attorney for: DEFENDANT, ERNEST WEIRICK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-6611 JURY TRIAL DEMANDED TO: Sheila Dunn c/o Michael E. Kosik, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 NOTICE TO PLEAD YOU ARE HEREBY NOTIFIED to plead to the enclosed ANSWER AND NEW MATTER OF DEFENDANT, ERNEST WEIRICK, within twenty (20) days from service hereof, or a default judgment may be entered against you. Respectfully submitted, Date: 3 0-9 6 7 3510 Trindle Road Camp Hill, PA 17011. 717-975-8114 Attorney for Defendant BARRY A KRONTHAL, ESQUIRE Pa. Supreme Court I.D. No. 55672 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17110 Telephone: [717] 760-7503 Fax: [717] 975-8124 E-mail:bkronthal@margolisedelstein.com SHEILA DUNN Plaintiff V. ERNEST WEIRICK Defendant Attorney for: DEFENDANT, ERNEST WEIRICK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-6611 JURY TRIAL DEMANDED ANSWER AND NEW MATTER OF DEFENDANT ERNE ;T WEIRICK TO THE COMPLAINT OF PLAINTIFF SHEILA DUNN AND NOW, comes Defendant, Ernest Weirick ("Defendant"), by and through his counsel, Margolis Edelstein, and hereby files this Answer with New Matter to the Complaint of Plaintiff, Sheila Dunn ("Plaintiff'), averring the following in support thereof: ANSWER 1. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of this paragraph and they are, therefore, denied. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted upon information and belief. 6. Admitted. 7. Denied. The averments of this paragraph are generally denied, pursuant to Pa. R.C.P. No. 1029(e). 8. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of this paragraph and they are, therefore, denied. By way of further answer, Defendant's vehicle was not moving at the time of the subject collision. 9. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments regarding what caused Plaintiff to lose control, and the averments relating thereto are, therefore, denied. The remaining averments of this paragraph are generally denied, pursuant to Pa. R.C.P. No. 1029(e). 10. Admitted. 11. Denied. The averments of this paragraph state a conclusion of law to which no response is required and they are, therefore, denied. By way of further answer, the averments of this paragraph are generally denied, pursuant to Pa. R.C.P. No. 1029(e). Further, pursuant to a stipulation entered into among the parties, Paragraph 11(h) has been stricken in its entirety. A copy of the Stipulation is attached hereto, made a part hereof and marked as Exhibit "A." 12. Denied. The averments of this paragraph state a conclusion of law to which no response is required and they are, therefore, denied. By way of further answer, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of this paragraph and they are, therefore, denied. 13. Denied. The averments of this paragraph state a conclusion of law to which no response is required and they are, therefore, denied. By way of further answer, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of this paragraph and they are, therefore, denied. 14. Denied. The averments of this paragraph state a conclusion of law to which no response is required and they are, therefore, denied. By way of further answer, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of this paragraph and they are, therefore, denied. 15. Denied. The averments of this paragraph state a conclusion of law to which no response is required and they are, therefore, denied. By way of further answer, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of this paragraph and they are, therefore, denied. 16. Denied. The averments of this paragraph state a conclusion of law to which no response is required and they are, therefore, denied. By way of further answer, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of this paragraph and they are, therefore, denied. WHEREFORE, Defendant, Ernest Weirick, respectfully requests that judgment be entered in his favor and against Plaintiff, Sheila Dunn, with costs assessed to Plaintiff. NEW MATTER 17. The answers contained in paragraphs 1 through 16 inclusive hereof, are incorporated by reference herein as if set forth in their entirety. 18. Plaintiff's claims, if any, are barred by the applicable statute of limitations. 19. The subject collision and Plaintiffs alleged damages and/or injuries, if any, were solely, directly and proximately caused by Plaintiffs own negligent, reckless, and/or careless conduct. 20. Plaintiff s claims, if any, are barred by the doctrines of contributory and comparative negligence and assumption of the risk. 21. Plaintiff has failed to state a claim upon which relief can be granted. 22. Plaintiff s claims, if any, are barred by her failure to mitigate her damages. 23. At all times relevant hereto, Defendant was responding appropriately under the circumstances then existing to a sudden emergency. 24. Plaintiff is precluded from pleading, introducing into evidence, or recovering any and all monies payable as "required benefits" pursuant to the Pennsylvania Motor Vehicle Financial Responsibility Law, Act of February 12, 1984, 75 Pa. Cons. Stat. § 1701 et seq. 25. Plaintiff s claims, if any, are governed by her tort selection. 26. Plaintiff's alleged damages, if any, were caused by the negligent, reckless, careless, and willful conduct of others over whom Defendant had no control, and for whom he is not legally or otherwise responsible. WHEREFORE, Defendant, Ernest Weirick, respectfully requests that judgment be entered in his favor and against Plaintiff, Sheila Dunn, with costs assessed to Plaintiff.. DATE: a 1 a 3 0 --7 MARGOLIS EDWSTE1N Barry A. al, Esquire Attorney N . 5672 3510 Trindle oad Camp Hill, PA 17011 717-975-8114 Z?)Al-bf---? /+ BARRY A KRONTHAL, ESQUIRE Pa. Supreme Court I.D. No. 55672 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17110 Telephone: [717] 760-7503 Fax: [717] 975-8124 E-mail:bkronthal@margolisedelstein.com SHEILA DUNN Plaintiff v. ERNEST WEIRICK Defendant Attorney for: DEFENDANT, ERNEST WEIRICK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-6611 JURY TRIAL DEMANDED STIPULATION Plaintiff, Sheila Dunn, by and through her counsel, Michael Kosik, Esquire, and Defendant, Ernest Weirick, by and through his counsel, Barry A. Kronthal, Esquire, hereby agree and stipulate that Paragraph 11(h) shall be stricken, in its entirety, from Plaintiff s Complaint. This Stipulation is effective upon the approval of the Court of Common Pleas of Cumberland County, Pennsylvania. DATE: 3 `7 ID #55674 3510 Trindle Road Camp Hill, PA 17011 717-975-8114 ANGINO DATE: Michael Kosik, Esquire ID# 36513 4503 N. Front Street Harrisburg, PA 17110 717-238-6791 VERIFICATION I, Ernest Weirick, state that I have read the foregoing Answer with New Matter, and that the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa.C.S.A. § 4904, relating to unsworn falsification to authorities. Date: Ernest Weirick Dunn v. Weuick CERTIFICATE OF SERVICE I, the undersigned, do hereby certify that I have this day of , 2007, served a true and correct copy of the foregoing Answer with New Matter upon the person(s) and in the manner indicated below: Service by First Class Mail Postage Prepaid. Addressed as Follows Michael E. Kosik, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 MARGOLIS EDELSTEIN By-Oi--O a I-K-, Carol Moose MAmdir\1 Kemper\34025.4-00016 Dunn v. Weirick\P1ead\Answer.2-7-07.wpd -J - .. l rn ^_' BARRY A KRONTHAL, ESQUIRE Pa. Supreme Court I.D. No. 55672 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17110 Telephone: [7171760-7503 Fax: [717] 975-8124 E-mail:bk.ronthal@margolisedelstein.com Attorney for: DEFENDANT, ERNEST WEIRICK SHEILA DUNK Plaintiff V. ERNEST WEIRICK Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-6611 JURY TRIAL DEMANDED STIPULATION Plaintiff, Sheila Dunn, by and through her counsel, Michael Kosik, Esquire, and Defendant, Ernest Weirick, by and through his counsel, Barry A. Kronthal, Esquire, hereby agree and stipulate that Paragraph I I (h) shall be stricken, in its entirety, from Plaintiff's Complaint. This Stipulation is effective upon the approval of the Court of Common Pleas of Cumberland Countv, Pennsylvania. DATE: .3 It A07 ILI 3510 4'rindle Road Camp Hill, PA 17011 717-975-8114 DATE: ANGINO AN-D ROVNER Michael Kosik, Esquire ID# 36513 4503 N. Front Street Harrisburg, PA 17110 717-238-6791 ANGINO & ROVNER, P.C. Michael E. Kosik, Esquire Attorney ID# : 36513 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: mkosik@angino-rovner.com SHEILA DUNN Plaintiff V. ERNEST WEIRICK Defendant : IN THE COURT OF COMON PLEAS OF : CUMBERLAND COUNTY, PENNA. CIVIL ACTION -LAW NO. 06-6611 JURY TRIAL DEMANDED PLAINTIFF'S REPLY TO DEFENDANT NEW MATTER AND NOW comes the Plaintiff Sheila Dunn, by and through her attorneys, Angino & Rovner, P.C., and hereby replies to the New Matter of Defendant as follows: 17. Pennsylvania Rule of Civil Procedure 1030 provides that a party may set forth as New Matter any material facts which are not merely denials of the averments of the preceding pleading. A review of the Defendant's Answer to Plaintiffs Complaint only contains admissions or general denials to the corresponding paragraphs of Plaintiff s Complaint with the exception of paragraph 8. Therefore, Defendant's incorporation of its Answer to Plaintiffs Complaint as New Matter was improper. By way of further response to paragraph 8 of Defendant's New Matter, it is specifically denied that Defendant Ernest Weirick's vehicle was not moving 337659 immediately prior to and at the time of the accident. To the contrary, Plaintiff Sheila Dunn maintains that Defendant moved from the shoulder of the highway in an effort to cross both southbound lanes of Interstate 81 in an effort to get into the emergency vehicle crossover in the center median. Plaintiff Sheila Dunn attempted to move left to avoid impact with the Defendant's vehicle and in the process of doing so was struck in the rear by the Defendant's vehicle which caused her to lose control of her vehicle ultimately causing it to roll over before coming to rest off the highway. 18. Denied. This averment is a conclusion of law to which no responsive pleading is required. To the extent that a response may be deemed proper, it is specifically denied that Plaintiffs claims are barred by the applicable statute of limitations. Plaintiff maintains that the statute of limitations applicable to her claim is the two-year statute of limitations contained in 42 Pa. C.S.A. §5524. As stated in Plaintiffs Complaint, the cause of action giving rise to her claim occurred on July 12, 2005. Since Plaintiff s Complaint was filed and served on the Defendant well before the two-year anniversary of this accident, it is specifically denied that Plaintiffs claim is barred by the applicable statue of limitations. 19. Denied. This averment is a conclusion of law to which no responsive pleading is required. To the extent that a response may be deemed proper, it is specifically denied that the accident resulting in Plaintiffs injuries and damages was a result of any negligence on the part of the Plaintiff Sheila Dunn. It is specifically denied that Plaintiff Sheila Dunn was in any way negligent upon the cause of action stated in her Complaint and, therefore, it is denied that she was negligent, reckless, or careless in the operation of her motor vehicle accident. To the contrary, it is averred that the accident occurred as a result of the Defendant's attempting to utilize the emergency vehicle cross-over in the median and moving from a position on the shoulder of the highway across 351488 2 the two southbound lanes of Interstate 81 directly into the path of the Plaintiff who was properly proceeding on the highway within the posted speed limit as set forth in more detail in Plaintiffs Complaint. 20. Denied. This averment is a conclusion of law to which no responsive pleading is required. By way of further response it is specifically denied that Plaintiff s claim is barred by the Doctrine of Contributory or Comparative Negligence and assumption of the risk. As previously stated, it is specifically denied that Plaintiff was negligent in any manner upon the cause of action and, therefore, it is denied that she was either contributorily or comparatively negligent. By way of further response, it is specifically denied that the defense of assumption of the risk is applicable to a motor vehicle accident in Pennsylvania. 21. Denied. This averment is a conclusion of law to which no responsive pleading is required. To the extent that a response may be deemed proper, it is specifically denied that Plaintiffs Complaint fails to state a claim upon which relief can be granted. To the contrary, it is averred that Plaintiffs Complaint sufficiently and specifically sets forth a claim against the Defendant for motor vehicle negligence and upon which relief can be granted. 22. Denied. This averment is a conclusion of law to which no responsive pleading is required. To the extent that a response may be deemed proper, it is specifically denied that Plaintiffs claim maybe barred by her alleged failure to mitigate damages. To the contrary, it is averred that at all times Plaintiff Sheila Dunn followed the directions of her treating physicians and has attempted in every respect to minimize the effect that the injury has had upon her. 23. Denied. This averment is a conclusion of law to which no responsive pleading is required. To the extent that a response may be deemed proper, it is specifically denied that the Doctrine of Sudden Emergency is in any way applicable to the Defendant's conduct. Plaintiff 351488 3 Sheila Dunn was approaching from the rear when the Defendant entered the highway from the shoulder of the roadway. Defendant Ernest Weirick had an obligation and duty to remain stopped on the shoulder while traffic approached in the traffic lanes. It was the Defendant's failure to follow the requirements of the various provisions of the Pennsylvania Motor Vehicle Code and his negligence in re-entering the travel lanes and attempting to make an improper turn on a limited access highway which resulted in the accident and Plaintiff Sheila Dunn's resulting injuries. It is specifically denied that the defense of Sudden Emergency is available to the Defendant, however, this defense certainly would be applicable to the circumstances presented to the Plaintiff Sheila Dunn. 24. Denied. This averment is a conclusion of law to which no responsive pleading is required. To the extent that a response may be deemed proper, it is specifically denied that the Pennsylvania Motor Vehicle Financial Responsibility Law in any way limits or restricts Plaintiffs claim for injuries and damages set forth in her Complaint. Plaintiff Sheila Dunn seeks to recover medical bills and work loss for which she is entitled to recover and which are not controlled by the Pennsylvania Motor Vehicle Financial Responsibility Law. 25. Denied. This averment is a conclusion of law to which no responsive pleading is required. To the extent that a response may be deemed proper, it is specifically denied that Plaintiff Sheila Dunn was required to make a tort selection. Plaintiff Sheila Dunn was covered by a commercial automobile policy at the time of the accident and, therefore, was not required to make a tort selection under 75 Pa. C.S.A. § 1705. 26. Denied. This averment is a mixed conclusion of fact and law to which no responsive pleading is required. To the extent that a response may be deemed proper, it is specifically denied that Plaintiffs injuries or damages were caused by the negligence, recklessness, 351488 4 carelessness or other conduct of unidentified third parties over whom the Defendant claims no control. To the contrary, it is averred that at all times Plaintiff's injuries and damages were caused directly and proximally by the conduct of the Defendant who was negligent in the operation of his motor vehicle in failing to yield the right-of-way to the Plaintiff who was properly proceeding on a limited access Interstate highway and re-entering the highway and attempting to make an illegal turning maneuver across the southbound lanes of Interstate 81 as set forth more fully in Plaintiff's Complaint. Plaintiff's injuries and damages were not the result of conduct of any other person or unidentified party and was solely the result of the Defendant's negligence as set forth in Plaintiffs Complaint. WHEREFORE, Plaintiff respectfully requests that this Honorable Court dismiss Defendant's New Matter enter judgment in favor of Plaintiff and against Defendant. 351488 5 I.D. No. 36513 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiff VERIFICATION I, SHEILA DUNN, do hereby swear and affirm that the facts set forth in the foregoing Reply to New Matter is true and correct to the best of our knowledge, information and belief. I understand that this verification is made subject to the penalties of the Rules of Civil Procedure relating to unsworn falsification to authorities. SHEILA DUNN Dated: CERTIFICATE OF SERVICE I, Michelle M. Milojevich, an employee of the law fmn of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of PLAINTIFF'S REPLY TO DEFENDANT'S NEW MATTER upon all counsel of record via postage prepaid first class United States mail addressed as follows: Barry A. Kronthal, Esquire Margolis Edelstein P.O. Box 932 Harrisburg, PA 17108-0932 Michelle M. Milojevich Dated: 4/4/07 351488 6 v 1 . F r-j 4Ln -° tv ,y BARRY A KRONTRAL, ESQUIRE Pa. Supreme Court I.D. No. 55672 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17110 Attorney for: Telephone: [717] 760-7503 DEFENDANT, Fax: [717] 975-8124 ERNEST WEIRICK E-mail:blcronthal@margolisedelstei.n.com SHEILA DUNN IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ERNEST WEIRICK NO. 06-6611 Defendant JURY TRIAL DEMANDED AMENDMENT TO STIPULATION The following Paragraph should be added to the Stipulation of Counsel filed on or about March 23, 2007: No Judges have ruled upon any other issue in this matter, and all counsel concur with the Stipulation as filed. MARGOLIS DATE: Barry nt 1, Esquire ID #55672 3510 Trindle Road Camp Hill, PA 17011 717-975-8114 CERTIFICATE OF SERVICE I, the undersigned, do hereby certify that I have this 24 day of Apo I , 2007, served a true and correct copy of the following upon the person(s) and in the manner indicated below: Service by First Class Mail, Postage Prepaid, Addressed as Follows: Michael Kosik, Esquire 4503 N. Front Street Harrisburg, PA 17110 MARGOLIS EDELSTEIN By. .. Carol Moose MAmdir\1 Kemper\34025.4-00016 Dunn v. Weirick\Plead\Amendment to Stipulation.4-16-07.wpd C'i ? p ? ? ? ;. r ? _? -, -? t? ?? , ? - ?3 -11 ?3 i `???`f ?;:. r_. „? _3 <,? ? ?? G y 3, • t MARS92Wr SHEILA DUNN IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ERNEST WEIRICK NO. 06-6611 Defendant JURY TRIAL DEMANDED ORDER AND NOW, on this 0day of May , 2007, upon consideration of the Stipulation, IT IS HEREBY ORDERED AND DECREED that Paragraph 11(h) shall be stricken, in its entirety, from Plaintiff's Complaint ?k --? JUDGE .46 ANGINO & ROVNER, P.C. Michael E. Kosik, Esquire Attorney ID# : 36513 4503 North Front Street Harrisburg, PA 17110-1708 (717)238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: mkosik@angino-rovner.com ORIGINAL SHEILA DUNN Plaintiff V. ERNEST WEIRICK Defendant IN THE COURT OF COMON PLEAS OF CUMBERLAND COUNTY, PENNA. : CIVIL ACTION -LAW : NO. 06-6611 : JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Plaintiff 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 337659 undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. DATED: 5/30/07 Michael E. Ko; I.D. No. 36513 Esquire 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiff 356363 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN Plaintiffs : versus ERNEST WEIRICK : No. 06-6611 Defendant/s : SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Bureau of Driver Licensing Driver Record Services PO Box 68695 Harrisburg, PA 17106-8695 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: driving record for Ernest Weirick, driver's number 219 128 97 at Angino & Rovner, 4503 N. Front St., Hbg., PA 17110. 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 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: Address: Telephone: Supreme Court ID #: Attorney for: Michael E. Kosik, Esquire 4503 North Front Street Harrisburg, PA 17110 (717) 238-6791 36513 Plaintiff BY THE COURT: Date: Seal of the Court Prothonotary/Clerk, Civil Division Deputy CERTIFICATE OF SERVICE I, Michelle M. Milojevich, an employee of the law fun of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of NOTICE OF INTENT TO SERVE SUBPOENA upon all counsel of record via postage prepaid fast class United States mail addressed as follows: Barry A. Kronthal, Esquire Margolis Edelstein P.O. Box 932 Harrisburg, PA 17108-0932 Michelle M. Milojevich Dated: 5/30/07 356363 r.41 J 44 ANGINO & ROVNER, P.C. Michael E. Kosik, Esquire Attorney ID# : 36513 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: mkosik@angino-rovner.com ORIGINAL SHEILA DUNN Plaintiff V. ERNEST WEIRICK Defendant IN THE COURT OF COMON PLEAS OF CUMBERLAND COUNTY, PENNA. : CIVIL ACTION -LAW : NO. 06-6611 : JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Plaintiff 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 337659 undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. ANGINO & ROVNER, P.C. XrK4sik, quire I.D. No. 36513 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiff DATED: 5/30/07 356363 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN Plaintiws : versus : No. 06-6611 ERNEST WEIRICK Defendant/s : SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Boshinski Eye Clinic 6520 Carlisle Pike Mechanicsburg, PA 17050 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: copies of all office notes for Ernest Weirick, 210 Willow Mill Park Road, Mechanicsburg, PA 17050; SSN #: 178-16-6616 at Angino & Rovner, 4503 N. Front St., Hbg., PA 17110. 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 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: Address: Telephone: Supreme Court ID #: Attorney for: Michael E. Kosik, Esquire 4503 North Front Street Harrisburg, PA 17110 (717) 238-6791 36513 Plaintiff BY THE COURT: Date: Seal of the Court Prothonotary/Clerk, Civil Division Deputy CERTIFICATE OF SERVICE I, Michelle M. Milojevich, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of NOTICE OF INTENT TO SERVE SUBPOENA upon all counsel of record via postage prepaid first class United States mail addressed as follows: Barry A. Kronthal, Esquire Margolis Edelstein P.O. Box 932 Harrisburg, PA 17108-0932 M chelle M. MiIojevich Dated: 5/30/07 356363 3 Q ? IT IN THE MATTER OF: SHEILA DUNN ERNEST WEIRICK CERTIFICATE ORIGINAL PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 06-6611 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 06/20/2007 CS on behalf of lS KRONTHAL,? Attor y for DEFENDAN R1.35 133-H DE11-0694727 88112-LO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CASE NO: 06-6611 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ( Note: see enclosed list of locations ) TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 05/31/2007 CC: BARRY A. KRONTHAL, ESQ. - 34025.4-00016 Any questions regarding this matter, contact MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 21.355 133-H DE02-0364998 88112-CO1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED CARLISLE REGIONAL MEDICAL CNTR GREEN HILL FAMILY HEALTH CTR HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ALEXANDER SPRING REHAB HORIZON EYE CARE GROUP GREATER BALTIMORE NEURO. ASSOC CENTRAL PENN MEDICAL GROUP QUANTUM IMAGING & THERA. ASSOC HEALTHSOUTH MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS 1.35S 133-H DE02-0364998 88112-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN File No. 06-6611 VS. ERNEST WEIRICK SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARLISLE REGIONAL MEDICAL CNTR (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER**** at The MCS Gr=, Inc.- 1601 Market Street. Suite 800- P iladelp1lia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL. ESQ. ADDRESS: 3510 TRINDLE ROAD -CAMP HILL. PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Pr thono Ci Division JUN 2 0 ,20D? - Deputy Date: Seal of the Court 88112-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CNTR 361 ALEXANDER SPRING RD MEDICAL RECORDS CARLISLE, PA 17015 RE: 88112 SHEILA DUNN Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : SHEILA DUNN 1715 PENN STREET, HARRISBURG, PA 17102 Social Security #: XXX-XX-0250 Date of Birth: 02-06-1945 t1.35S 133-H SU10-0688706 88112-LO1 IN THE MATTER OF: SHEILA DUNN ERNEST WEIRICK CERTIFICATE ORIGINAL PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 06-6611 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 06/20/2007 S on b a Of of ??// R O , Sr t. Attorn for DEFENDANT :1.35 133-H DE11-0694728 88112-L02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF : SHEILA DUNN -VS- ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CASE NO: 06-6611 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY.A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that.is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 05/31/2007 CC: BARRY A. KRONTHAL, ESQ. - 34025.4-00016 Any questions regarding this matter, contact MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 1.35S 133-H DE02-0364998 88112-CO1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED CARLISLE REGIONAL MEDICAL CNTR GREEN HILL FAMILY HEALTH CTR HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ALEXANDER SPRING REHAB HORIZON EYE CARE GROUP GREATER BALTIMORE NEURO. ASSOC CENTRAL PENN MEDICAL GROUP QUAN'T'UM IMAGING & THERA. ASSOC HEALTHSOUTH MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS t1.35S 133-H DE02-0364998 88112-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN VS. ERNEST WEIRICK File No. 06-6611 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for GREEN HILL. FAMILY HEALTH CTR (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group Inc.- 1601 Market s=cL Suite 800, Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL. ESQ. ADDRESS: 3510 TRZMI,F ROAD CAMP HILL. PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY COURT: .19 0-1L Pr ono Ci . Division JUN 2 0 2007 Deputy Date: L 2667 Seal of the Court 88112-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: GREEN HILL FAMILY HEALTH CTR 503 BRIDGE STREET NEW CUMBERLAND, PA 17070 RE: 88112 SHEILA DUNN Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : SHEILA DUNN 1715 PENN STREET, HARRISBURG, PA 17102 Social Security #: XXX-XX-0250 Date of Birth: 02-06-1945 1.35S 133-H SU10-0688708 88112-L02 IN THE MATTER OF: SHEILA DUNN ERNEST WEIRICK CERTIFICATE ORIGINAL PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 06-6611 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 06/20/2007 CS on behalf of 1?( eg 00 . R W NTH AL, E (? Attorn for DEFENDANT 21.35 133-H DE11-0694729 88112 -LO3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF : SHEILA DUNN -VS- ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CASE NO: 06-6611 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY.A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 05/31/2007 CC: BARRY A. KRONTHAL, ESQ. - 34025.4-00016 Any questions regarding this matter, contact MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 1.35S 133-H DE02-0364998 88112 - CO 1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED CARLISLE REGIONAL MEDICAL CNTR GREEN HILL FAMILY HEALTH CTR HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ALEXANDER SPRING REHAB HORIZON EYE CARE GROUP GREATER BALTIMORE NEURO. ASSOC CENTRAL PENN MEDICAL GROUP QUANTUM IMAGING & THERA. ASSOC HEALTHSOUTH MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS 1.35S 133-H DE02-0364998 88112-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN VS. ERNEST WEIRICK File No. 06-6611 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HOLY SPIRIT HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS CaM. Inc.- 1601 Market Street, Suite 800, P iladejphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL. ESO. ADDRESS: 3510 TRINDLE ROAD CAMP HILL PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUN 2 0 2007 Date: ?L f ?lYS7 Seal of the Court BY COURT: APro onotary/Cl ivil ivision Deputy 88112-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL MEDICAL RECORDS 503 N. 21ST STREET CAMP HILL, PA 17011 RE: 88112 SHEILA DUNN Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : SHEILA DUNN 1715 PENN STREET, HARRISBURG, PA 17102 Social Security #: 199-34-0250 Date of Birth: 02-06-1945 11.35S 133-H SU10-0688710 88112-LO3 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK ORIGINAL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-6611 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 06/20/2007 S on b half of C ESQ Attorny for DEFENDANT :1.35 133-H DE11-0694730 88112-L04 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CASE NO: 06-6611 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ( Note: see enclosed list of locations ] TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of.record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 05/31/2007 CC: BARRY A. KRONTHAL, ESQ. - 34025.4-00016 Any questions regarding this matter, contact MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 1.35S 133-H D902-0364998 88112-CO1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED CARLISLE REGIONAL MEDICAL CNTR GREEN HILL FAMILY HEALTH CTR HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ALEXANDER SPRING REHAB HORIZON EYE CARE GROUP GREATER BALTIMORE NEURO. ASSOC CENTRAL PENN MEDICAL GROUP QUANTUM IMAGING & THERA. ASSOC HEALTHSOUTH MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS .35S 133-H DE02-0364998 88112-COI COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN VS. ERNEST WEIRICK File No. 06-6611 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for _ HOLY SPIRIT HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS rojW Inc. 1601 M &t Street, Suite 800, Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the parry 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: BARRY A KRONTHAi ESQ ADDRESS: 3510 TRINDLE ROAD CAMP HILL- PA 17011 TELEPHONE: (15) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE URT: Pro notary?.ler i '1 D Won Date: JUN,2 0'2007 Deputy ?y C f ZT Seal of the Court 88112-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL RADIOLOGY DEPT. 503 N. 21ST STREET CAMP HILL, PA 17011 RE: 88112 SHEILA DUNN Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : SHEILA DUNN 1715 PENN STREET, HARRISBURG, PA 17102 Social Security #: 199-34-0250 Date of Birth: 02-06-1945 .35S 133-H SU10-0688712 88112-LO4 IN THE MATTER OF: SHEILA DUNN ERNEST WEIRICK CERTIFICATE 0;VriNAL PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 06-6611 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 06/20/2007 CS on behalf of KRONT?c? . Hifor DEFENDANT R1.35 133-H DE11-0694731 88112 -LO5 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CASE NO: 06-6611 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ( Note: see enclosed list of locations ) TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. intends to serve a subpoena identical to-the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 05/31/2007 CC: BARRY A. KRONTHAL, ESQ. - 34025.4-00016 Any questions regarding this matter, contact MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 21.35S 133-H DE02-0364998 88112-COl >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED CARLISLE REGIONAL MEDICAL CNTR GREEN HILL FAMILY HEALTH CTR HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ALEXANDER SPRING REHAB HORIZON EYE CARE GROUP GREATER BALTIMORE NEURO. ASSOC CENTRAL PENN MEDICAL GROUP QUANTUM IMAGING & THERA. ASSOC HEALTHSOUTH MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORD R1.35S 133-H DE02-0364998 88112-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN VS. ERNEST WEIRICK File No. 06-6611 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ALEXANDER SPRING REHAB (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED EMM **** at The MCS Groilp, Inc 1601 Market Street. Suite 800 Philaddpj ; PA 19103 - You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL. ESQ. ADDRESS: 3510 TRINDLE ROAD CAMP HILL. PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE URT: Proth otary/Cl i '1 'si4 JUN 2 0 2007 Deputy Date: 4iG Seal of the Court 88112-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ALEXANDER SPRING REHAB 1 TYLER COURT SUITE-200 CARLISLE. PA 17013 RE: 88112 SHEILA DUNN Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : SHEILA DUNN 1715 PENN STREET, HARRISBURG, PA 17102 Social Security #: XXX-XX-0250 Date of Birth: 02-06-1945 R1.35S 133-H SU10-0688714 88112-LO5 IN THE MATTER OF: SHEILA DUNN ERNEST WEIRICK CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 06-6611 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 06/20/2007 n qh l f o ti OQ kB Attorney for DEFENDANT R1.35 133-H DE11-0694732 88112-L06 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK [ Note: see enclosed list of locations ] COURT OF COMMON PLEAS TERM, CASE NO: 06-6611 TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 05/31/2007 CC: BARRY A. KRONTHAL, ESQ. - 34025.4-00016 Any questions regarding this matter, contact MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.35S 133-H D802-0364998 88112-COl >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED CARLISLE REGIONAL MEDICAL CNTR GREEN HILL FAMILY HEALTH CTR HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ALEXANDER SPRING REHAB HORIZON EYE CARE GROUP GREATER BALTIMORE NEURO. ASSOC CENTRAL PENN MEDICAL GROUP QUANTUM IMAGING & THERA. ASSOC HEALTHSOUTH MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS R1.35S 133-H DE02-0364998 88112-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN File No. 06-6611 VS. ERNEST WEIRICK SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HORIZON EYE CARE GROUP (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RTDER..**** at The MCS GE=- Inc 1601 Market Street Suite 800, PhiladdpW PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL. ESO. ADDRESS: 3510 TRINDLE ROAD CAMP HILL PA 17011 TELEPHONE:. 5) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUN 2 0 2001 Date: d vim? Seal of the Court BY THE COURT: Prot notary/Cl ivil ivision Deputy 88112-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HORIZON EYE CARE GROUP 207 MEDICAL ARTS BLDG. 220 WILSON STREET CARLISLE, PA 17013 RE: 88112 SHEILA DUNN Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : SHEILA DUNN 1715 PENN STREET, HARRISBURG, PA 17102 Social Security #: XXX-XX-0250 Date of Birth: 02-06-1945 R1.35S 133-H SU10-0688716 88112-LO6 IN THE MATTER OF: SHEILA DUNN ERNEST WEIRICK CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA ORGINN PURSUANT TO RULE 4009.22 COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 06-6611 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 06/20/2007 c? CS on beh;}Jlf off l R (l•I?KRM (??7??AL, E?Q. Attor ey for DEFENDANT 11.35 133-H DE11-0694733 88112 -LO7 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: SHEILA DUNN -vS- ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CASE NO: 06-6611 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ) TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena maybe 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: 05/31/2007 CC: BARRY A. KRONTHAL, ESQ. - 34025.4-00016 Any questions regarding this matter, contact MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 L.35S 133-H DB02-0364998 88112-COl >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED CARLISLE REGIONAL MEDICAL CNTR GREEN HILL FAMILY HEALTH CTR HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ALEXANDER SPRING REHAB HORIZON EYE CARE GROUP GREATER BALTIMORE NEURO. ASSOC CENTRAL PENN MEDICAL GROUP QUANTUM IMAGING & THERA. ASSOC HEALTHSOUTH MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS' .1.35S 133-H DE02-0364998 88112-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN File No. 06-6611 VS. ERNEST WEIRICK SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for GREATER BALTIMORE NEURO ASSOC (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group Inc 1601 Market Street Suite 800, Philadelphia- PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL. ESQ. ADDRESS: 3510 TRINDLE ROAD CAMP HILL, PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUN 2 0 2007 Date: albi o? _t 02 Seal of the Court BY THE COURT: Pro 'notary/ i ' ivision Deputy 88112-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: GREATER BALTIMORE NEURO. ASSOC 6569 N. CHARLES STREET SUITE 403 BALTIMORE. MD 21204 RE: 88112 SHEILA DUNN Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : SHEILA DUNN 1715 PENN STREET, HARRISBURG, PA 17102 Social Security #: XXX-XX-0250 Date of Birth: 02-06-1945 R1.35S 133-H SU10-0688718 88112-LO7 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SHEILA DUNN TERM, CUMBERLAND -VS- CASE NO: 06-6611 ERNEST WEIRICK As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 06/20/2007 %AEii f td ?b . Attorney for DEFENDANT 1.35 133-H DE11-0694734 88112-LO8 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CASE NO: 06-6611 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ( Note: see enclosed list of locations ] TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 05/31/2007 CC: BARRY A. KRONTHAL, ESQ. - 34025.4-00016 Any questions regarding this matter, contact MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 ,1.35S 133-H D1902-0364998 88112-COl >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED CARLISLE REGIONAL MEDICAL CNTR GREEN HILL FAMILY HEALTH CTR HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ALEXANDER SPRING REHAB HORIZON EYE CARE GROUP GREATER BALTIMORE NEURO. ASSOC CENTRAL.PENN MEDICAL GROUP QUANTUM IMAGING & THERA. ASSOC HEALTHSOUTH MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS t1.35S 133-H DE02-0364998 88112-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN File No. 06-6611 VS. ERNEST WEIRICK SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CENTRAL PENN MEDICAL GROUP (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Cg=, Inc- 1601 Market Street Suitc 900, Philadelpl"- PA 19103 - - You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL. ESO. ADDRESS: 3510 TRIND .E RO CAMP HILL,, PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID M ATTORNEY FOR: Defendant JUN 2 0 2007 Date: Xz y c2 Vf, c266 7 Seal of the Court BY THE URT: Proth otary/Clerk, D' 'sion Deputy 88112-08 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CENTRAL PENN MEDICAL GROUP 1097 COMMERCIAL AVE P 0 BOX 468 EAST PETERSBURG, PA 17601 RE: 88112 SHEILA DUNN Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : SHEILA DUNN 1715 PENN STREET, HARRISBURG, PA 17102 Social Security #: XXX-XX-0250 Date of Birth: 02-06-1945 R1.35S 133-H SU10-0688720 88112 -LO8 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK ORIGINAL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-6611 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 06/20/2007 CS on ?ihlqlf of c W-rm- KRO . Attor y for DEFENDANT R1.35 133-H DE11-0694735 88112-L09 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: SHEILA DUNN -vS- ERNEST WEIRICK [ Note: see enclosed list of locations ] COURT OF COMMON PLEAS TERM, CASE NO: 06-6611 TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY.A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 05/31/2007 CC: BARRY A. KRONTHAL, ESQ. - 34025.4-00016 Any questions regarding this matter, contact MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 16.01 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.35S 133-H DB02-0364998 88112-CO1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED CARLISLE REGIONAL MEDICAL CNTR GREEN HILL FAMILY HEALTH CTR HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ALEXANDER SPRING REHAB HORIZON EYE CARE GROUP GREATER BALTIMORE NEURO. ASSOC CENTRAL PENN MEDICAL GROUP QUANTUM IMAGING & THERA. ASSOC HEALTHSOUTH MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS R1.35S 133-H DE02-0364998 88112-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN VS. ERNEST WEIRICK File No. 06-6611 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for QUANTUM IMAGING & THERA. ASSOC (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER**** at The MCS Cm w- Inc.- 1601 Market Street, Suite 800, Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL. ESO. ADDRESS: 3510 TRINDLE ROAD _CAMP HILL- PA 17011 TELEPHONE: 12151246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE C URT: Protho otary/Cler i ion JUN $ 0 2007 Deputy Date: Seal of the Court 88112-09 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: QUANTUM IMAGING & THERA. ASSOC 405 ST. JOHN CHURCH RD. CAMP HILL, PA 17011 RE: 88112 SHEILA DUNN Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : SHEILA DUNN 1715 PENN STREET, HARRISBURG, PA 17102 Social Security #: XXX-XX-0250 Date of Birth: 02-06-1945 R1.35S 133-H SU10-0688722 88112-L09 OHIGIP?A[ CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-6611 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 06/20/2007 CS on b half of R NTHAL ES Si Attorne for DEFENDANT R1.35 133-H DE11-0694736 88112-LlO COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CASE NO: 06-6611 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 05/31/2007 CC: BARRY A. KRONTHAL, ESQ. - 34025.4-00016 Any questions regarding this matter, contact MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.35S 133-H DE02-0364998 88112-C01 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED CARLISLE REGIONAL MEDICAL CNTR GREEN HILL FAMILY HEALTH CTR HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ALEXANDER SPRING REHAB HORIZON EYE CARE GROUP GREATER BALTIMORE NEURO. ASSOC CENTRAL PENN MEDICAL GROUP QUANTUM IMAGING & THERA. ASSOC HFALTHSOUTH MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDIS R1.35S 133-H DE02-0364998 88112-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN VS. ERNEST WEIRICK File No. 06-6611 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HEAL THSOLTT H (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS C*r W Inc 1601 Market Street_ Suite 800, Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL. ESQ. ADDRESS: 3510 TRINDLE ROAD CAMP HILL, PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE URT: Proth otary/ Ci ' ivision JUN 2 0 2007 f Date: r c ? Deputy ?Lcd? `T-?- Seal of the Court 88112-10 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HEALTHSOUTH 840 NORTH FRONT STREET WORMLEYSBURG, PA 17043 RE: 88112 SHEILA DUNN Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : SHEILA DUNN 1715 PENN STREET, HARRISBURG, PA 17102 Social Security #: XXX-XX-0250 Date of Birth: 02-06-1945 R1.35S 133-H SU10-0688724 88112-L10 C7 e D S b T } cx? ANGINO & ROVNER, P.C. Michael E. Kosik, Esquire Attorney ID# : 36513 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: mkosik@angino-rovner.com ORIGINAL C.l N SHEILA DUNN Plaintiff V. ERNEST WEIRICK Defendant : IN THE COURT OF COMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVIL ACTION -LAW NO. 06-6611 JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.21 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Plaintiff certifies that: (1) a notice of intent to serve a subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party, and plaintiff received a letter from defense counsel waiving the 20 days, letter attached; (2) a copy of the notice of intent, including the proposed subpoena is attached to this certificate, (3) defendant waived the 20 days as evidenced by a copy of his letter attached hereto. 337659 (4) the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve a subpoena. Dated: 6/21/07 Michael E. Kosik, Esquire Attorney for Plaintiff 356363 C a _ • ?y sv 'Vi ANGINO & ROVNER, P.C. tr; < Michael E. Kosik, Esquire Attorney H)#: 36513 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: mkosik@angino-rovner.com SHEILA DUNN : IN THE COURT OF COMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNA. V. : CIVIL ACTION -LAW : NO. 06-6611 ERNEST WEIRICK Defendant JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Plaintiff 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 337659 undersigned an objection to the subpoena If no objection is made, the subpoena may be served. DATED: 5/30/07 ANGINO & ROVNER, P.C. Wt-K&ik, qu ire I.D. No. 36513 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiff 356363 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN versus ERNEST WEIRICK Plaintiffs . : No. 06-6611 Defendant/s : SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Boshinski Eye Clinic 6520 Carlisle Pike Mechanicsburg, PA 17050 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: copies of all office notes for Ernest Weirick, 210 Willow Mill Park Road, Mechanicsburg, PA 17050; SSN #: 178-16-6616 at Angino & Rovner, 4503 N. Front St., Hbg., PA 17110. 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 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: Address Telephone: Supreme Court ID #: Attorney for: Michael E. Kosik, Esquire 4503 North Front Street Harrisburg, PA 17110 (717) 238-6791 36513 Plaintiff BY THE COURT: Date: Seal of the Court Prothonotary/Clerk, Civil Division Deputy CERTIFICATE OF SERVICE I, Michelle M. Milojevich, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of NOTICE OF INTENT TO SERVE SUBPOENA upon all counsel of record via postage prepaid first class United States mail addressed as follows: Barry A. Kronthal, Esquire Margolis Edelstein P.O. Box 932 Harrisburg, PA 17108-0932 Michelle M. Milojevich Dated: 5/30/07 356363 3 CERTIFICATE OF SERVICE I, Michelle M. Milojevich, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of CERTIFICATE PRE- REQUISITE TO SERVICE OF SUBPOENA upon all counsel of record via postage prepaid first class United States mail addressed as follows: Barry A. Kronthal, Esquire Margolis Edelstein P.O. Box 932 Harrisburg, PA 17108-0932 Michelle M. Milojevich Dated: 6/21/07 356363 4 9 :23 cn m ? v? ORIGINAL ANGINO & ROVNER, P.C. Michael E. Kosik, Esquire Attorney ID# : 36513 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: mkosik@angino-rovner.com SHEILA DUNN : IN THE COURT OF COMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNA. V. CIVIL ACTION -LAW NO. 06-6611 ERNEST WEIRICK Defendant JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.21 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Plaintiff certifies that: (1) a notice of intent to serve a subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party, and plaintiff received a letter from defense counsel waiving the 20 days, letter attached; (2) a copy of the notice of intent, including the proposed subpoena is attached to this certificate, (3) defendant waived the 20 days as evidenced by a copy of his letter attached hereto. 337659 (4) the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve a subpoena. Dated: 6/21/07 Wichael E. Kosik, Esquire Attorney for Plaintiff 356363 2 t J _ V } `= ` m 0 ANGINO & ROVNER, P.C. -- Michael E. Kosik, Esquire Attorney ID# : 36513 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: mkosik@angino-rovner.com SHEILA DUNN : IN THE COURT OF COMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNA. V. CIVIL ACTION -LAW NO. 06-6611 ERNEST WEIRICK Defendant JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Plaintiff 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 337659 undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. ANGINO A ROWER, P.C. Michael E. Kosik, Esquire I.D. No. 36513 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiff DATED: 5130/07 356363 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN PlaintiWs : versus : No. 06-6611 ERNEST WEIRICK Defendantls : SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Bureau of Driver Licensing Driver Record Services PO Box 68695 Harrisburg, PA 17106-8695 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: driving record for Ernest Weirick, driver's number 219 128 97 at Angino & Rovner, 4503 N. Front St., Hbg., PA 17110. 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 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: Address: Telephone: Supreme Court ID #: Attorney for: Michael E. Kosik, Esquire 4503 North Front Street Harrisburg, PA 17110 (717) 238-6791 36513 Plaintiff BY THE COURT: Date: Seal of the Court Prothonotary/Clerk, Civil Division Deputy CERTIFICATE OF SERVICE I, Michelle M. IvIilojevich, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of NOTICE OF INTENT TO SERVE SUBPOENA upon all counsel of record via postage prepaid first class United States mail addressed as follows: Barry A. Kronthal, Esquire Margolis Edelstein P.O. Box 932 Harrisburg, PA 17108-0932 Michelle M. Milojevich Dated: 5/30/07 356363 3 CERTIFICATE OF SERVICE I, Michelle M. Milojevich, an employee of the law fun of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of CERTIFICATE PRE- REQUISITE TO SERVICE OF SUBPOENA upon all counsel of record via postage prepaid first class United States mail addressed as follows: Barry A. Kronthal, Esquire Margolis Edelstein P.O. Box 932 Harrisburg, PA 17108-0932 Michelle M. Milojevich Dated: 6/21/07 356363 4 CJ f-3 c U D rt" r i i ? ft'? ? a '1 f i CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 ORIGINAL IN THE MATTER OF: COURT OF COMMON PLEAS SHEILA DUNN TERM, CUMBERLAND -VS- CASE NO: 06-6611 ERNEST WEIRICK As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ES certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 07/30/2007 I C 4 Attor ey for DEFENDANT R1.35 133-H DE11-0701464 88112-Lll COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CASE NO: 06-6611 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 MENSANA CLINIC MEDICAL RECORDS ADVANCED RADIOLOGY X-RAY ONLY REGINALD J. DAVIS, M.. MEDICAL RECORDS MAGNETIC IMAGING CENTER X-RAY ONLY CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS ROBERT PEROUTKA, M.D. MEDICAL RECORDS TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/10/2007 CC: BARRY A. KRONTHAL, ESQ. - 34025.4-00016 Any questions regarding this matter, contact MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.35S 133-H DE02-0367963 88112-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN VS. ERNEST WEIRICK File No. 06-6611 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MENSANA CLINIC (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MC Troup. Inc.. 1601 Market Street Suite 800, Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL. ESO. ADDRESS: 3510 TRINDLE ROAD CAMP HILL PA 17011 TELEPHONE: (15) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUL 3 0 2007 Date: 9?. a a, "o1-00 7 Seal of the Court BY THE COURT: /S/ e 4'zi; X X?!7v Prothonotary/Clerk, Civil Divisi Deputy 88112-11 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MENSANA CLINIC 1718 GREENSPRING VALLEY STEVENSON, MD 21153 RE: 88112 SHEILA DUNN Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : SHEILA DUNN 1715 PENN STREET, HARRISBURG, PA 17102 Social Security #: XXX-XX-0250 Date of Birth: 02-06-1945 R1.35S 133-H SU10-0694198 88112-Lll CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SHEILA DUNN -vS- ERNEST WEIRICK ORIGINWL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-6611 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 07/30/2007 W CS on ? f o B O QL Attorn for DEFENDANT R1.35 133-H DE11-0701465 88112-L12 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CASE NO: 06-6611 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 MENSANA CLINIC ADVANCED RADIOLOGY REGINALD J. DAVIS, M.. MAGNETIC IMAGING CENTER CARLISLE REGIONAL MEDICAL ROBERT PEROUTKA, M.D. MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS MEDICAL RECORDS TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/10/2007 CC: BARRY A. KRONTHAL, ESQ. - 34025.4-00016 Any questions regarding this matter, contact MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.35S 133-H DE02-0367963 88112-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN vs. ERNEST WEIRICK File No. 06-6611 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO Custodian of Records for ADVANCED RADIOLOGY (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Grog, Inc.. 1601 Market Street. Suite 800, Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL. ESO. ADDRESS: 351012MLE ROAD CAMP HILL, PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: JUL 3 0 2007 Date:- °202 j o2U4 7 Seal of the Court , 4Z 644?? 14e Prothonotary/Clerk, Civil Division(/ a'u - Deputy 88112-12 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ADVANCED RADIOLOGY 6701 NORTH CHARLES STREET BALTIMORE. MD 21204 RE: 88112 SHEILA DUNN Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : SHEILA DUNN 1715 PENN STREET, HARRISBURG, PA 17102 Social Security #: XXX-XX-0250 Date of Birth: 02-06-1945 R1.35S 133-H SU10-0694200 88112-L12 ORIGINAL CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-6611 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 07/30/2007 of TT11 DWL&0N Attor y for DEFENDANT R1.35 133-H DE11-0701466 88112-L13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CASE NO: 06-6611 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 MENSANA CLINIC MEDICAL RECORDS ADVANCED RADIOLOGY X-RAY ONLY REGINALD J. DAVIS, M.. MEDICAL RECORDS MAGNETIC IMAGING CENTER X-RAY ONLY CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS ROBERT PEROUTKA, M.D. MEDICAL RECORDS TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/10/2007 CC: BARRY A. KRONTHAL, ESQ. - 34025.4-00016 Any questions regarding this matter, contact MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.35S 133-H DE02-0367963 88112-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN vs. ERNEST WEIRICK File No. 06-6611 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for REGINAT D I. DAMS, M.. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED E MM * * * * at The MCS Cff Inc., 1601 Market Street Suite 800_ Pliladelp ia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL. ESQ. ADDRESS: 3510 TRINDLE ROAD CAMP HILL_ PA 17011 TELEPHONE: 15) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUL' 3 0 2007 Date: ca 40 7 Seal of the Court BY THE COURT: Prothbnotary/Clerk, Civil Di2V _ 0?a? Deputy 88112-13 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: REGINALD J. DAVIS, M.. 6569 N. CHARLES STREET SUITE 411 BALTIMORE, MD 21204 RE: 88112 SHEILA DUNN Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : SHEILA DUNN 1715 PENN STREET, HARRISBURG, PA 17102 Social Security #: XXX-XX-0250 Date of Birth: 02-06-1945 R1.35S 133-H SU10-0694202 88112-L13 IN THE MATTER OF: SHEILA DUNN ERNEST WEIRICK CERTIFICATE ORIGAOL PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 COURT OF COMMON PLEAS TERM, CUMBERLAND -vs- CASE NO: 06-6611 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 07/30/2007 CS on ? 1 f o Attorn y for DEFENDANT R1.35 133-H DE11-0701467 88112-L14 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CASE NO: 06-6611 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 MENSANA CLINIC MEDICAL RECORDS ADVANCED RADIOLOGY X-RAY ONLY REGINALD J. DAVIS, M.. MEDICAL RECORDS MAGNETIC IMAGING CENTER X-RAY ONLY CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS ROBERT PEROUTKA, M.D. MEDICAL RECORDS TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/10/2007 CC: BARRY A. KRONTHAL, ESQ. - 34025.4-00016 Any questions regarding this matter, contact MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.35S 133-11 DE02-0367963 88112-COI COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN VS. ERNEST WEIRICK, File No. 06-6611 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MAGNETIC IMAGING CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER**** at The MCS Ca=. Inc., 1601 Market Street. Suite 800. Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS. SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL. ES ADDRESS: 3510 TRINDLE ROAD TELEPHONE: (15) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Divis? JUL - 3 0 2007 Deputy o2oD C'1- ? Date: Seal of the Court 88112-14 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MAGNETIC IMAGING CENTER 4665 TRINDLE ROAD MECHANICSBURG, PA 17050 RE: 88112 SHEILA DUNN Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : SHEILA DUNN 1715 PENN STREET, HARRISBURG, PA 17102 Social Security #: XXX-XX-0250 Date of Birth: 02-06-1945 R1.35S 133-H SU10-0694204 88112-L14 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK ORIGINAL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-6611 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 07/30/2007 S on f of LL , ONT ' Attorn y for DEFENDANT R1.35 133-H DE11-0701468 88112-LlS COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CASE NO: 06-6611 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 MENSANA CLINIC MEDICAL RECORDS ADVANCED RADIOLOGY X-RAY ONLY REGINALD J. DAVIS, M.. MEDICAL RECORDS MAGNETIC IMAGING CENTER X-RAY ONLY CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS ROBERT PEROUTKA, M.D. MEDICAL RECORDS TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/10/2007 CC: BARRY A. KRONTHAL, ESQ. - 34025.4-00016 Any questions regarding this matter, contact MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.35S 133-H DE02-0367963 88112-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN VS. ERNEST WEIRICK File No. 06-6611 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARLISLE REGIONAL MEDICAL CNTR (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER**** at The MCS Gmo. Inc.- 1601 Market Street. Suite 800 Philadelphia- PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL. ESQ. ADDRESS: 3510 LE ROAD CAMP HILL PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUL 3 0 2007 Date: 7 Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Divin Deputy 88112-15 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CNTR 361 ALEXANDER SPRING RD MEDICAL RECORDS CARLISLE, PA 17015 RE: 88112 SHEILA DUNN Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : SHEILA DUNN 1715 PENN STREET, HARRISBURG, PA 17102 Social Security #: XXX-XX-0250 Date of Birth: 02-06-1945 R1.35S 133-H SU10-0694206 88112-L15 v;2/GINAL CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-6611 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 07/30/2007 Won f o IS' O S + l Attorn y for DEFENDANT R1.35 133-H DE11-0701469 88112-L16 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CASE NO: 06-6611 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 MENSANA CLINIC MEDICAL RECORDS ADVANCED RADIOLOGY X-RAY ONLY REGINALD J. DAVIS, M.. MEDICAL RECORDS MAGNETIC IMAGING CENTER X-RAY ONLY CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS ROBERT PEROUTKA, M.D. MEDICAL RECORDS TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/10/2007 CC: BARRY A. KRONTHAL, ESQ. - 34025.4-00016 Any questions regarding this matter, contact MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.35S 133-H DE02-0367963 88112-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN vs. ERNEST WEIRICK File No. 06-6611 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ROBERT PEROUTKA. M.D. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER**** at The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena., together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL. ESQ. ADDRESS: 35101EMLE ROAD CAMP HELL. PA 17011 TELEPHONE: (15) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUL 3 0 2007 Date: o. Seal of the Court BY THE ??COURT: f? Prothonotary/Clerk, Civil Division! Ya? Deputy 88112-16 EXPLANATION OF REQUIRED RECORDS LR1.35S 133-H TO: CUSTODIAN OF RECORDS FOR: ROBERT PEROUTKA, M.D. 1300 YORK ROAD LUTHERVILLE TIMONIUM, MD 21093 RE: 88112 SHEILA DUNN Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : SHEILA DUNN 1715 PENN STREET, HARRISBURG, PA 17102 Social Security #: XXX-XX-0250 Date of Birth: 02-06-1945 SU10-0694208 88112-L16 - TI r7l te r ? td:D CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK 0 ! ' 1 COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-6611 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ES certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 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: 07/19/2007 C Yn A behalf R o .S? KRON ESQ. 4 / Attorne for DEFENDANT R1.39 133-H DE12-0248378 88112-L17 Q J UL. Co. GCIC1! G•G7r1'It??Hl7all'IV be MQVIlLm rizkbprH. 1601 Market Street, Suite 800, Philadelphia Pennsylvania 19103 (215) N6 - 0900 Fax Number (215) 246 - 0959 URGENT!.... URGENT! ! ! ! !' i JULY 1?9, 2007 SHEILA DUNK SHEILA DUNN Vs ERNEST WBIRICK MARGOLIS EDELSTEIN BARRY A. KRONTHAL, ESQ. - (717) 975-8124 - INSURANCE ff been requested by the above-mentioned counsel to obtain material on an basis from the below listed custodians. In order to comply with this request we your signature indicating that you waive the twenty-day notice period provided 009.21 and 4009.22_ PIease fax this form to us immediately at (215) 246-0959 si giature so that we may comply with this request, Your to peration would be greatly appreciated. Sincerely, CAROL HAMILTON Ins: ESSIVE INSURANCE ' t F I IYV. (1z) r. 1 URGENT! ! ! ! ! r'l kEL E. KOSIK, ESQ. (717) 238-5610 to waive 'W-' ' period 1(1' ,aS Date: p&f Yes o I a ay the invoice provided with the documents Docameihies o Advise of Cost t agree to waive rule: Date: Info: RRwl-ooos9as 88112-C01 COMMONWEALTH OF PENNSYLVANIA, COUNTY OF CUMBERLAND IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CASE NO: 06-6611 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 PROGRESSIVE INSURANCE INSURANCE TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/19/2007 MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT CC: BARRY A. KRONTHAL, ESQ. - 34025.4-00016 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.35 133-H DE02-0368739 88112-COl COMMONWEALTH OF PENNSYLVANIA, COUNTY OF CUMBERLAND IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CASE NO: 06-6611 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 PROGRESSIVE INSURANCE INSURANCE TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/19/2007 MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT CC: BARRY A. KRONTHAL, ESQ. - 34025.4-00016 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #600 PHILADELPHIA, PA 19103 (215) 246-0900 R1.35 133-H DE02-0368739 88112-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN File No. 06-6611 - vs. ERNEST WEIRICK SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PROGRESSIVE INSURANCE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group Inc 1601 market Street Suite 800 Philadelp.hia,PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A KRONTHAL. ESO. ADDRESS: 3 51 n TR il\mT .E R OAD CAMP HILL .. PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant AJG 10 2007 Date: 7 D? Seal of the Court 88112-17 BY THE COURT: EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PROGRESSIVE INSURANCE 1216 MAIN STREET PITTSTON, PA 18640 RE: 88112 SHEILA DUNN Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all insurance records and PIP files, including but not limited to medical reports and/or records, claims, any and all correspondence, documentation supporting plaintiff's claim, payments including dates of payments, payee and reasons for payments, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : SHEILA DUNN 1715 PENN STREET, HARRISBURG, PA 17102 Social Security #: XXX-XX-0250 Date of Birth: 02-06-1945 Date of Loss: 07/12/2005 R1.35 133-H SU10-0695588 88112-L17 c`? ?' C? C- ','. ,. [ ,Y ?.... __. ? Y ;? C '+ r. '=: ^-?J ??11 h y F ? ? '- ..'` f".3 G?` C,*T •'4. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 ORIGINAL IN THE MATTER OF: COURT OF COMMON PLEAS SHEILA DUNN TERM, CUMBERLAND -VS- CASE NO: 06-6611 ERNEST WEIRICK As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/10/2007 on behalf of BARRY A KRONTHAL, ESQ. Attorney for DEFENDAkT R1.41 133-H DE11-0709824 88112-L18 COMMONWEALTH OF PENNSYLVANIA • COUNTY OF CUMBERLAND IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CASE NO: 06-6611 NOTICE OF INTEN'D' TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 SEIDE M. MEMORIAL HOSPITAL MEDICAL RECORDS JOHN VICKORY, M.D. MEDICAL RECORDS B. KENNETH NELSON, M.D. MEDICAL GREATER BALTIMORE MEDICAL CTR MEDICAL RECORDS DR. STEVEN REMILLARD MEDICAL RECORDS TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice. period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 08/21/2007 CC: BARRY A. KRONTHAL, ESQ. - 34025.4-00016 Any questions regarding this matter, contact MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.41S 133-H DE02-0372014 88112-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN VS. ERNEST WEIRICK File No. 06-6611 SUBPOENA TO PRODUCE DOCUMENTS 9 THINGS Fog DISCOVERY PURSUANT TO RULE .22 TO: Custodian of Records for SEMIR M_ MEMORIAL HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Q=- Inc_, 1601 Market Street Suite 800. Pl ilsdelnhia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST. OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL. ESQ. ADDRESS: 3510 TRINDLE ROAD CAMP HILL„ PA 17011 TELEPHONE: (2,15) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: SEP 10 2007 Date: 10'07 Seal of the Court 'k/ 6"? C. - P thonotary/Clerk, Civil D 'sion Deputy 88112-18 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SEIDE M. MEMORIAL HOSPITAL MEDICAL RECORDS DEPT 120 SOUTH FILBERT ST MECHANICBURG. PA 17055 RE: 88112 SHEILA DUNN Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : SHEILA DUNK 1715 PENN STREET, HARRISBURG, PA 17102 Social Security #: XXX-XX-0250 Date of Birth: 02-06-1945 R1.41S 133-H SU10-0701270 88112-L18 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK ORIGMViiv COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-6611 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/10/2007 / M on beTONTHAL, f 4Alv'l L/JC BARRY ESQ. Attorney for DEFENDANT R1.41 133-H DE11-0709825 8811_2-L19 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: SHEILA DUNN -vS- ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CASE NO: 06-6611 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 SEIDE M. MEMORIAL HOSPITAL MEDICAL RECORDS JOHN VICKORY, M.D. MEDICAL RECORDS B. KENNETH NELSON, M.D. MEDICAL GREATER BALTIMORE MEDICAL CTR MEDICAL RECORDS DR. STEVEN REMILLARD MEDICAL RECORDS TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 08/21/2007 CC: BARRY A. KRONTHAL, ESQ. - 34025.4-00016 Any questions regarding this matter, contact MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.41S 133-H DE02-0372014 88112-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN VS. ERNEST WEIRICK File No. 06-6611 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JOHN VICKORY. M.D. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHE RIDER **** at The MCS Groin, nc„ 1601 Market Street cite 800. P iladeWilia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTH,AL. ESQ. ADDRESS: 3510 JUMLE ROAD CAMP HILL- PA 17011 TELEPHONE:. (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant SEP 10 2007 Date: %1/010-7 Seal of the Court BY THE COURT: r thonotary/Clerk, Civil Di Sion ?'&' - P. rtL N.. Deputy 88112-19 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOHN VICKORY, M.D. 417 VILLAGE DRIVE CARLISLE, PA 17015 RE: 88112 SHEILA DUNN Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : SHEILA DUNN 1715 PENN STREET, HARRISBURG, PR 17102 Social Security #: XXX-XX-0250 Date of Birth: 02-06-1945 R1.41S 133-H SU10-0701272 88112-L19 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-6611 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/10/2007 /J1 M on behalf o744-?t-tw/ 4N BARRY . THAL, ESQ. Attorney for DEFENDANT -?' R1.41 133-H DE11-0709626 8813_2-L20 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: SHEILA DUNN COURT OF COMMON PLEAS TERM, -VS- CASE NO: 06-6611 ERNEST WEIRICK NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 SEIDE M. MEMORIAL HOSPITAL MEDICAL RECORDS JOHN VICKORY, M.D. MEDICAL RECORDS B. KENNETH NELSON, M.D. MEDICAL GREATER BALTIMORE MEDICAL CTR MEDICAL RECORDS DR. STEVEN REMILLARD MEDICAL RECORDS TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 08/21/2007 CC: BARRY A. KRONTHAL, ESQ. - 34025.4-00016 Any questions regarding this matter, contact MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.41S 133-H DE02-0372014 88112-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN VS. ERNEST WEIRICK File No. 06-6611 TO: Custodian of Records for B KENNETH NELSON, M.D. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS C*_=. Inc-- 1601 Market Street. Suite 800. Philadelphia- PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL. ESO. ADDRESS: 3510 TRINDLE ROAD CAI" HILL, PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: 'Prbthonotary/Clerk, Civil vision SEP 10 2007 ??? ?,- Date: 8 olpa Deputy Seal of the Court 88112-20 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: B. KENNETH NELSON, M.D. 809 N. BETHLEHEM PIKE SPRINGHOUSE, PA 19477 RE: 88112 SHEILA DUNN Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. ANY AND ALL PSYCHIATRIC RECORDS Dates Requested: up to and including the present. Subject : SHEILA DUNN 1715 PENN STREET, HARRISBURG, PA 17102 Social Security #: XXX-XX-0250 Date of Birth: 02-06-1945 R1.41S 133-H SU10-0701274 88112-L20 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 001 GINAL IN THE MATTER OF: COURT OF COMMON PLEAS SHEILA DUNN TERM, CUMBERLAND -VS- CASE NO: 06-6611 ERNEST WEIRICK As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/10/2007 on behalf of /BARRY KRO?/NTdHAL, ESQ. Attorney for DEFENDANT R1.41 133-H DE11-0709827 88112-L,21 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CASE NO: 06-6611 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 SEIDE M. MEMORIAL HOSPITAL MEDICAL RECORDS JOHN VICKORY, M.D. MEDICAL RECORDS B. KENNETH NELSON, M.D. MEDICAL GREATER BALTIMORE MEDICAL CTR MEDICAL RECORDS DR. STEVEN REMILLARD MEDICAL RECORDS TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 08/21/2007 CC: BARRY A. KRONTHAL, ESQ. - 34025.4-00016 Any questions regarding this matter, contact MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.41S 133-H DE02-0372014 88112-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN VS. ERNEST WEIRICK File No. 06-6611 TO: Custodian of Records for EATER BALTIMORE MEDICAL GTR (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHE RIDER **** at The MCS Cn=- Inc- , 1601 Market Street Suite 800. Philadej hLia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAI.. ESO. ADDRESS: 3510 TRINDLE ROAD CAMP HILL. PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID M ATTORNEY FOR: Defendant SEP 10 2001 Date: g'10 ?A'1 Seal of the Court BY THE COURT: thonotary/Clerk, Civil ivision Deputy 0 '01 88112-21 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: GREATER BALTIMORE MEDICAL CTR MEDICAL RECORDS 6701 N. CHARLES ST. BALTIMORE, MD 21204 RE: 88112 SHEILA DUNN Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : SHEILA DUNN 1715 PENN STREET, HARRISBURG, PA 17102 Social Security #: XXX-XX-0250 Date of Birth: 02-06-1945 R1.41S 133-H SU10-0701276 88112-L21 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SHEILA DUNN ERNEST WEIRICK ORIGINAL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-6611 -vs- As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/10/2007 on be al o%/?? BARRY . KRONTHAL, ESQ. Attorney for DEFENDANT R1.41 133-H DE11-0709828 88112-L22 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CASE NO: 06-6611 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 SEIDE M. MEMORIAL HOSPITAL MEDICAL RECORDS JOHN VICKORY, M.D. MEDICAL RECORDS B. KENNETH NELSON, M.D. MEDICAL GREATER BALTIMORE MEDICAL CTR MEDICAL RECORDS DR. STEVEN REMILLARD I MEDICAL RECORDS TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 08/21/2007 CC: BARRY A. KRONTHAL, ESQ. - 34025.4-00016 Any questions regarding this matter, contact MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.41S 133-H D202-0372014 88112-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN VS. TO: ERNEST WEIRICK File No. 06-6611 Custodian of Records for DR STEVEN MILLARD (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: **** SEF_ ATTACHED RIDER **** at The MCS Cron; , Inc- 1601 Market Street Suite 800, Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL. ESO. ADDRESS: 3510 TRINDLE ROAD CAMP HH L_ PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant W10MY Date: 8 10.1 07 Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil ivision &,,,. r__ &.1h 44, Deputy 88112-22 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. STEVEN REMILLARD CENTER FOR WELLNESS 4079 DERRY STREET HARRISBURG, PA 17111 RE: 88112 SHEILA DUNN Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : SHEILA DUNN 1715 PENN STREET, HARRISBURG, PA 17102 Social Security #: XXX-XX-0250 Date of Birth: 02-06-1945 R1.41S 133-H SU10-0701278 88112-L22 -ri err? cn r-rt ? cn .? to c_?s CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SHEILA DUNN -VS- ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-6611 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/24/2008 S on behal f RY KRONTHAL, ESQ. / Attor y for DEFENDANT R1.51 120-N DE11-0732580 8 8 11.2 - L.2 3 COMLVIOZ?I -4§,L'rM OF PENNSYLVAN I A C OUNT Y O F C UMB E R L AND IN THE MATTER OF: COURT OF COMMON PLEAS SHEILA DUNN -VS- ERNEST WEIRICK TERM, CASE NO: 06-6611 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 INWHA CHO, M.D. MEDICAL RECORDS QUICK COURIER EMPLOYMENT TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS c,r by contacting our local MCS office. DATE: 01/04/2008 CC: BARRY A. KRONTHAL, ESQ. - 34025.4-00016 Any questions regarding this matter, contact MCS on behalf of BARRY A. KRONTHAL, ESQ. _ Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.49S 120-N DE02-0383465 8 8 1 1 2- C 0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN File No. 06-6611 VS. ERNEST WEIRICK SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for INWHA CHO M .D (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACH M RMM **** at The MCS Group, Inc., 1601 Market Street Suite 800 Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL. ESO. ADDRESS: 3510 TRINDLE ROAD CAMP HILL. PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JAN 2 4 2008 Date: J`a,,??-)'n6g Seal of the Court 88112-23 EXPLANATION TO: CUSTODIAN OF RECORDS FOR: INWHA CHO, M. D. 195 STOCK STREET SUITE 303 HANOVER, PA 17331 RE: 88112 SHEILA DUNN OF REQUIRED RECORDS Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical file, including but not limited to any and. all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : SHEILA DUNN 1715 PENN STREET, HARRISBURG, PA 17102 Social Security #: XXX-XX-0250 Date of Birth: 02-06-1945 R1.49S 120-N SU10-0717586 8 8 112 -L2 3 16 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SHEILA DUNN ERNEST WEIRICK COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 06-6611 -VS- As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf, of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve'the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. S on behal of DATE: 01/24/2008 BARRY C KRONTHAL, ESQ. Atto? ey for DEFENDANT R1.51 120-N DE11-0732581 8 8 1 1 2- L 2 4 CON4N41VVCr$ALT1-1 CDF PENN'SYLVAN I A COUNTY OF' CLTNSBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SHEILA DUNN -VS- ERNEST WEIRICK TERM, CASE NO: 06-6611 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 INWHA CHO, M.D. MEDICAL RECORDS QUICK COURIER EMPLOYMENT TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. _ intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached_::ounsel card and returning same to MCS or by contacting our local MCS office. DATE: 01!04/2008 CC: BARRY A. KRONTHAL, ESQ. 34025.4-00016 Any questions regarding this matter, contact MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.49S 120-N DE02-0383465 8 8 1 1 2- C 0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEILA DUNN vs. ERNEST WEIRICK File No. 06-6611 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for QUICK COURIER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER**** at The MCS Group. Inc.. 1601 Market Street. Suite 800, Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL. ESO. ADDRESS: 3510 TRINDLE ROAD CAMP HILL. PA 17011 TELEPHONE: 215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JAN 2 4 2008 Date: p? T Seal of the Court 88112-24 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: QUICK COURIER 5185 CAMPUS DRIVE PLYMOUTH MEETING, PA 19462 RE: 88112 SHEILA DUNN Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all employment records, applications, files, 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 be stored in a computer database or otherwise in electronic form,. pertaining to: Dates Requested: up to and including the present. Subject : SHEILA DUNN 1715 PENN STREET, HARRISBURG, PA 17102 Social Security #. XXX-XX-0250 Date of Birth: 02-06-1945 R1.49S 120-N SII10-0717588 8 8 112 - L2 4 L?? r..> ?.-? _ } '_'? C._ _ r ? ?7 <...... f ("`? 1? ? - °^+n 07 ?_..1 T, ti .?.?1 ?, •y? ANGINO & ROVNER, P.C. Michael E. Kosik, Esquire Attorney ID# : 36513 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: mkosik@angino-rovner.com SHEILA DUNN Plaintiff V. : IN THE COURT OF COMON PLEAS OF : CUMBERLAND COUNTY, PENNA. CIVIL ACTION -LAW NO. 06-6611 ERNEST WEIRICK Defendant TO THE PROTHONOTARY: JURY TRIAL DEMANDED PRAECIPE Please mark the above-captioned action as settled, satisfied, and discontinued. DATED: 8/15/08 cc: Barry A. Kronthal, Esquire Michael h. Kos1K, tsqulre I.D. No. 36513 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiff 337659 c? `? X4-3 ` ? fj'? ?. Cf1 .?(?,', "? :: .: ^? ? . > =-, '? i-", i ? ??. ?• ?`_ ? :. ;?