Loading...
HomeMy WebLinkAbout02-2847cop,/ POST & SCHELL, P.C. BY: JOHN W. DORNBERGER, ESQUIRE I.D. #:69293 240 GRANDVIEW AVENUE CAMP HILL, PA 17011 (717) 731-1970 ATTORNEYS FOR DEFENDANTS DAVD M. EICHELBERGER AND SUSAN S. EICHELBERGER STEPHANIE PRESBERY-HUNT, Plaintiff, DAVID M. EICHELBERGER and SUSAN S. EICHELBERGER, H/W, Defendants. COURT OF COMMON PLEAS DAUPHIN COUNTY NO: NO. 4958-S-2001 ORDER AND NOW, this day of ,2002, upon consideration of the Stipulated Motion of Plaimiff Stephanie Presbery-Hunt and Defendants David M. Eichelberger and Susan S. Eichelberger, it is hereby ORDERED and DECREED that the Stipulated Motion is GRANTED and the above-captioned action is transferred to the Court of Common Pleas for Cumberland County, with costs and fees to be paid by i)laintiffs. BY THE COURT: _ J. POST & SCHELL, P.C. BY: JOHN W. DORNBERGER, ESQUIRE I.D. # 69293 240 GtL~NDVIEW AVENUE CAMP HILL, PA 17011 ~ (717) 731-1970 ATTORNEYS FOR DEFENDANTS DAVID M. EICHELBERGER AND SUSAN S. EICHELBERGER STEPHANIE PRESBERY-HUNT Vo Plaintiff, DAVID M. EICHELBERGER and SUSAN S. EICHELBERGER h/w Defendants. IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY NO. 4958-S-2001 STIPULATED MOTION BETWEEN PLAINTIFFS AND DEFENDANT~O TRANSFER VENUE FROM DAUPHIN COUNTY TO CUMBERLAN~-~ COUNTY PURSUANT TO PA.R.C.P. 1006(e) Plaintiff Stephanie Presbery-Hunt ("Plaintiff") and Defendants David M. Eichelberger and Susan S. Eichelberger ("Defendants" or "Eichelbergers"), by and through their undersigned counsel, hereby jointly submit the following Stipulated Motion to Transfer Venue from Dauphin County to Cumberland County pursuant to Pa.R.C.P. 1006(e). It is requested that this Honorable Court role on this Stipulated Motion prior to, or in place of, a decision on Defendants' previously filed Preliminary Objections based on venue. 1. Plaintiffcommenced this lawsuit against the above-captioned Defendants by the filing of a Complaint in this Court on or about October 23, 2001. 2. The Complaint was served on Defendants at their residence located at 455 Lake Meade Drive, East Berlin, Adams County, Pennsylvania, on December 10, 2001; Plaintiffs Complaint incorrectly located Defendants' residence in York County. 3. In her Complaint, Plaintiff alleges she sustained injuries and damages in a slip and fall which occurred on or around December 18, 1999. 4. Plaintiffs alleged acciden~t occurred in a building she was living in as a tenant which is, and was, owned by Defendants and is located at 152 North Pitt Street, Carlisle, Cumberland County, Pennsylvania ("the property"). 5. - Defendants often conduct business related to the property as Eichelberger Enterprises. However, this is a sole proprietorship operated by the Eichelbergers; Eichelberger Enterprises is not a legal entity and has never been registered as a fictitious name with any state agency. 6. The deed to the property is in the names of David M. Eichelberger and Susan S. Eichelberger; there is no reference to Eichelberger Enterprises in the deed to the property. 7. The proper~y where Plaintiff allegedly sustained her injuries is located in Cumberland County, Pennsylvania. 8. At all times relevant to this lawsuit, Defendants maintained their residence in Adams County, where they were served with the Complaint. 9. Defendants have no connection to Dauphin County: they do not own property in Dauphin County, have never maintained a residence in Dauphin County arid have never worked in Dauphin County. 10. The only connection this action has to Dauphin County is that the Plaintiff resides therein, which is irrelevant under the venue provisions of the Pennsylvania Rules of Civil Procedure. 11. Pursuant to Pennsylvania Rule of Civil Procedure 1006(e), improper venue shall be raised by preliminary objection and if sustained, and there is a county of proper venue, "the action shall not be dismissed but shall be transferred to the appropriate court of that county," with costs and fees to be paid by plaintiff. 12. On or about December 28~ 2001, Defendants filed Preliminary Objections with this Honorable Court based on improper venue which sought to have the action transferred to Cumberland County. 13. - Plaintiff has agreed not to oppoge Defendants' Preliminary Objection and, accordingly, both parties seek to have this action transferred, at Plaintiffs expense, to Cumberland County where venue is proper. 14. Should this Honorable Court grant the Stipulated Motion of Plaintiff and Defendants, Defendants will withdraw their preyiously filed Preliminary Objections as they will be rendered moot; if the Stipulated Motion is denied, it is requested that this Honorable Court render a decision on Defendants' previously filed Preliminary Objections based on venue which are unopposed by Plaintiff. WHEREFORE, Plaintiff Stephanie Presbery-Hunt and Defendants David M. Eichelberger and Susan S. Eichelberger respectfully request that this Honorable Court enter an Order in the proposed form and order that this cause of action be transferred to Cumberland County, with costs and fees to be paid by Plaintiff, pursuant to Rule 1006(e). JO~IN W. DORNBERGER, ESQ. Aftomey for Defendants David M. Eichelberger and Susan S. Eichelberger DATE: Respectfully submitted, GRAHM & MAUER, P.C. (~I¢ J. 1VIS, JEll./, ESQUIRE Attorney fd4 Plaintiff Stephanie Presbery-Hunt DATE: -3- CERTIFICATE OF SERVICE I, John W. Domberger, an attorney with the law offices of Post & Schell, P.C., do hereby certify that on the date listed below, I di/t serve a true and correct copy of the foregoing document upon the following person(s) at the following address(es) by sending same in the United States mail, first-class, postage prepaid: Date: Lisa J. Mauer, Esquire Grahm & Mauer, P.C. The Commons at Valley Forge Suite 22, Post Office Box 987 Valley Forge, PA 19482 Attorney for Plaintiff POS' Jo ~erger, Esquire POST & SCHELL, P.C. BY: JOHN W. DORNBERGER, ESQUIRE I.D. #:69293 240 GRANDVIEW AVENUE CAMP HILL, PA 17011 (717) 731-1970 STEPHANIE PRESBERY-HUNT, Plaintiff, DAVID M. EICHELBERGER and SUSAN S. EICHELBERGER, H/W, Defendants. ATTORNEYS FOR DEFENDANTS DAVID M. EICHELBERGER AND SUSAN S. EICHELBERGER COURT OF COMMON PLEAS DAUPHIN COUNTY NO: NO. 4958-S-2001 ORDER AND NOW, this day of ,2002, upon consideration of the Stipulated Motion of Plaintiff Stephanie Presbery-Hunt and Defendants David M. Eichelberger and Susan S. Eichelberger, it is hereby ORDERED and DECREED that the Stipulated Motion is GRANTED and the above-captioned action is transferred to the Court of Common Pleas for Cumberland Cotmty, with costs and fees to be paid by i>laintiffs. BY THE COURT: POST & SCHELL, P.C. BY: JOHN W. DORNBERGER, ESQUIRE I.D. # 69293 240 GRANDVIEW AVENUE CAMP HILL, PA 17011 (717) 731-1970 ATTORNEYS FOR DEFENDANTS DAVID M. EICHELBERGER AND SUSAN S. EICHELBERGER STEPHANIE PRESBERY-HUNT Plaintiff, DAVID M. EICHELBERGER and SUSAN S. EICHELBERGER h/w Defendants. IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY NO. 4958-S-2001 STIPULATED MOTION BETWEEN PLAINTIFFS AND DEFENDAiNTS TRANSFER VENUE FROM DAUPHIN COUNTY TO CUMBERLAND COUNTY PURSUANT TO PA.R.C.P. 1006(e~ Plaintiff Stephanie Presbery-Hunt ("Plaintiff') and Defendants David M. Eichelberger and Susan S. Eichelberger ("Defendants" or "Eichelbergers"), by and through their undersigned counsel, hereby jointly submit the following Stipulated Motion to Transfer Venue from Dauphin County to Cumberland County pursuant to Pa.R.C.P. 1006(e). It is requested that this Honorable Court rule on this Stipulated Motion prior to, or in place of, a decision on Defendants' previously filed Preliminary Objections based on venue. 1. Plaintiff commenced this lawsuit against the above-captioned Defendants by the filing of a Complaint in this Court on or about October 23, 2001. The Complaint was served on Defendants at their residence located at 455 Lake Meade Drive, East Berlin, Adams County, Pennsylvania, on December 10, 2001; Plaintiffs Complaint incorrectly located Defendants' residence in York County. 3. In her Complaint, Plaintiff alleges she sustained injuries and damages in a slip and fall which occurred on or around December 18, 1999. 4. Plaintiffs alleged accident occurred in a building she was living in as a tenant which is, and was, owned by Defendants and is located at 152 North Pitt Street, Carlisle, Cumberland County, Pennsylvania ("the property"). 5. - Defendants often conduct business related to the property as Eichelberger Enterprises. However, this is a sole proprietorship operated by the Eichelbergers; Eichelberger Enterprises is not a legal entity and has never been registered as a fictitious name with any state agency. 6. The deed to the property is in the names of David M. Eichelberger and Susan S. Eichelberger; there is no reference to Eichelberger Enterprises in the deed to the property. 7. The property where Plaintiff allegedly sustained her injuries is located in Cumberland Connty, Pennsylvania. 8. At all times relevant to this lawsuit, Defendants maintained their residence in Adams County, where they were served with the Complaint. 9. Defendants have no connection to Dauphin County: they do not own property in Dauphin County, have never maintained a residence in Dauphin County and have never worked in Dauphin County. 10. The only connection this action has to Dauphin County is that the Plaintiff resides therein, which is irrelevant under the venue provisions of the Pennsylvania Rules of Civil Procedure. 11. Pursuant to Pennsylvania Rule of Civil Procedure 1006(e), improper venue shall be raised by preliminary objection and if sustained, and there is a county of proper venue, "the action -2- shall not be dismissed but shall be transferred to the appropriate court of that county," with costs and fees to be paid by plaintiff. 12. On or about December 28~ 2001, Defendants filed Preliminary Objections with this Honorable Court based on improper venue which sought to have the action transferred to Cumberland County. 13. ' Plaintiff has agreednot to oppose Defendants' Preliminary Objection and, accordingly, both parties seek to have this action transferred, at Plaintiffs expense, to Cumberland County where venue is proper. 14. Should this Honorable Court grant the Stipulated Motion of Plaintiff and Defendants, Defendants will withdraw their pre~,iously filed Preliminary Objections as they will be rendered moot; if the Stipulated Motion is denied, it is requested that this Honorable Court render a decision on Defendants' previously filed Preliminary Objections based on venue which are unopposed by Plaintiff. WHEREFORE, Plaintiff Stephanie Presbery-Hunt and Defendants David M. Eichelberger and Susan S. Eichelberger respectfully request that this Honorable Court enter an Order in the proposed form and order that this cause of action be transferred to Cumberland County, with costs and fees to be paid by Plaintiff, pursuant to Rule 1006(e). O~tN W. DORNBERGER, ESQ. Aftomey for Defendants David M. Eichelberger and Susan S. Eichelberger DATE: Respectfully submitted, GRAHM & MAUER, P.C. By: (~I~I~ J. M,~JJE~, ESQUIRE Attorney fd~ Plaintiff Stephanie Presbery-Hunt DATE: ~_.._ ~-- O 2 -3- CERTIFICATE OF SERVICE I, John W. Domberger, an attorney with the law offices of Post & Schell, P.C., do hereby certify that on the date listed below, I di~t serve a tree and correct copy of the foregoing document upon the following person(s) at the following address(es) by sending same in the United States mail, first-class, postage prepaid: Lisa J. Mauer, Esquire Grahm & Mauer, P.C. The Commons at Valley Forge Suite 22, Post Office Box 987 Valley Forge, PA 19482 Attorney for Plaintiff Date: Jo~erger, Esquire GRAHAM & M_AUER, P.C. BY: Lisa J. Mauer, Esquire Attorney I.D. No.: 65426 The Commons at Valley Forge Suite 22, P.O. Box 987 Valley Forge, Pennsylvania 19482 (610) 933-3333 STEPHANIE PRESBERY-HUNT 202 Reily Street Harrisburg, PA 17102 VS. DAVID M. EICHELBERGER and SUSAN S. EICHELBERGER h/w t/a EICHELBERGER ENTERPRISES 455 Lake Meade Drive East Berlin, PA 17316 Attorney for Plaintiff NOTICE TO DEFEND IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY E .Cx3 ! You have been sued in Court. If you wish to defend against the claims .s~fortlffn th~ m ~ following pages, you must take action within twenty (20) days after this Complaint an~notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Dauphin County Courthouse Front and Market streets Harrisburg, PA 17101 717/255-2692 GRAHAM & MAUER, P.C. BY: Lisa J. Mauer, Esquire Attorney I.D. No.: 65426 The Commons at Valley Forge Suite 22, P.O. Box 987 Valley Forge, Pennsylvania 19482 (610) 933-3333 STEPHANIE PRESBERY-HUNT 202 Reily Street Harrisburg, PA 17102 VS. DAVID M. EICHELBERGER and SUSAN S. EICHELBERGER h/w t/a EICHELBERGER ENTERPRISES : 455 Lake Meade Drive : East Berlin, PA 17316 : Attorney for Plaintiff : IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY No.: COMPLAINT 1. Plaintiff Stephanie Presbery-Hunt is an adult individual who resides at ~ Reil~ Street in Harrisburg, Dauphin County, Pennsylvania 17102. 2. Defendants David M. Eichelberger and Susan S. Eichelberger, husband and wife, ifa Eichelberger Enterprises, (hereinafter "Defendant Eichelberger") are adult individuals who reside at 455 Lake Meade Drive in East Berlin, York County, Pennsylvania 17316. 3. At all times pertinent hereto, Defendant Eichelberger owned, leased, possessed maintained and/or otherwise controlled the premises known as 152 North Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 4. At all times pertinent hereto, Plaintiffwas a business invitee on the premises of Defendant Eiehelberger. 5. On or about December 18, 1999, Plaintiff Stephanie Presbery-Hunt slipped and/or tripped and fell on the staircase providing access to Ms. Hunt's apartment at 152 North Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 6. At said time and place, Plaintiff reached for a hand rail to arrest her fall and said hand rail detached from the wall causing Plaintiffto continue her fail onto the steps. 7. At all times pertinent hereto, Defendant Eichelberger had a duty to maintain the said premises in a safe condition. 8. As a direct and proximate result of Defendants' carelessness and negligence, as described more fully herein, Plaintiff Stephanie Presbery-Hunt suffered injuries, including, but not necessarily limited to: fracture of the distal fibula with lateral displacement of the talus, severe shock to Plaintiff Stephanie Prespery-Hunt's nerves and nervous system, mental anguish, depression, embarrassment, humiliation, permanent scarring and interference with Plaintiff Stephanie Presbery-Hunt's activities of daily life. Some or ail of these injuries are or may be permanent and have caused Plaintiff Stephanie Presbery-Hunt great pain and suffering in the past and may continue to do so for an indefinite time into the future. 9. As a direct and proximate result of Defendants' carelessness and negligence, as described more fully herein, Plaintiff Stephanie Presbery-Hunt has been in the past, and may continue to be in the future, unable to attend to her ususal habits, customs, vocation and enjoyment of life. 10. As direct and proximate result of Defendants' carelessness and negligence, as described more fully herein, Plaintiff Stephanie Presbery-Hunt has been in the past, and may continue to in the future, required to undergo medical and surglcai procedures. 11. As a direct and proximate of Defendants' carelessness and negligence, as described more fully herein, Plaintiff Stephanie Presbery-Hunt has been in the past and/or may in the future be required to spend great sums of money for medical and surgical procedures, as a result of her injuries. 12. As a direct and proximate result of Defendants' carelessness and negligence, as described more fully herein, Plaintiff Stephunie Presbery-Hunt has been in the past and may be in the future, unable to engage in her usual occupation and, therefore, has in the past and may in the future continue to suffer a loss of income and/or loss of earning capacity. 13. As a direct and proximate result of Defendants' carelessness and negligence, as described more fully herein, Plaintiff Stephanie Presbery-Hunt has in the past, and may continue in the future, to suffer embarrassment and humiliation, as a result of the permanent scarring resulting from her injuries. 14. The aforesaid injuries were the direct and proximate result of Defendants' carelessness and negligence, which consisted of, inter alia, the following acts and/or omissions: a) defendants maintained and/or constructed or caused to be maintained and/ or constructed a staircase with stairs of varied heights and/or widths; b) defendants maintained or allowed to be maintained worn and slippery carpeting on the stairs; c) defendants maintained and/or constructed or caused to be maintained and/ or constructed a staircase with a handrail that was not properly secured to the walt; d) defendants maintained and/or created or allowed to be maintained and/or created a staircase that was poorly lit; e) failing to inspect and maintain the staircase in a safe condition; f) failing to provide a residence which is free from latent defects, including the non-uniformity of step heights and/or widths, worn, slippery carpeting covering those steps and an inadequate hand mil; g) failing to make the area of the premises containing said dangerous condition reasonably safe for tenants, including Plaintiff; h) failing to provide a safe and habitable residence for Plaintiff; i) concealing a defective and dangerous handrail; and j) failing to warn Plaintiff of the dangerous condition of the premises which Defendant Eichelberger knew or should have known existed at the time Defendant rented said premises to Plaintiff. WHEREFORE, Plaintiff Stephanie Presbe~-Hunt respectfully requests that judgment be entered in her favor and against the Defendants in an amount in excess of the arbitration limit, plus interest and costs. Date: October 19, 2001 By: Respectfully submitted, GRAHAM & MAUER, P.C. (..-L'is~ J. 1V~(~er/ Attorney f~ Plaintiff VERIFICATION I, Stephanie Presbery-Hunt, hereby state that I am the Plaintiff in this Action and veri~ that the statements made in the foregoing doctunent are true and correct to the best of my knowledge, information and belief. I understand that the statements therein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. DATE: POST & SCHELL, P.C. BY: JOHN W. DORNBERGER, ESQUIRE I.D. # 69293 240 GRANDVIEW AVENUE CAMP HILL, PA 17011 (717) 731-1970 ATTORNEYS FOR DEFENDANTS DAVID M. EICHELBERGER AND SUSAN S. EICHELBERGER STEPHANIE PRESBERY-HUNT Plaintiff, DAVID M. EICHELBERGER and SUSAN S. EICHELBERGER h/w Defendants. IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY NO. 4958-S-2001 PRELIMINARY OBJECTIONS OF DEFENDANTS DAVID M. EICHELBERGER AND SUSAN S. EICHELBERGER Defendants David M. Eichelberger and Susan S. Eichelberger ("Defendants" or "Eichelbergers"), by and through their undersigned counsel, hereby submit the following Preliminary Objections in accordance with Pennsylvania Rule of Civil Procedure 1006(e) and local role 211. 1. Plaintiff commenced this lawsuit against the above-captioned Defendants by the filing ora Complaint in this Court on or about October 23, 2001. 2. Plaintiff's Complaint incorrectly locates Defendants' residence in York County; Defendants actually reside at 455 Lake Meade Drive, East Berlin, Adams County, Pennsylvania. 3. In her Complaint, Plaintiff alleges that she sustained injuries and damages in a slip and fall which occurred on or around December 18, 1999 in a building she was living in as a tenant which is, and was, owned by Defendants and is located at 152 North Pitt Street, Carlisle, Cumberland County, Pennsylvania ("the property"). 4. The deed to the property is in the names of owners David M. Eichelberger and Susan S. Eichelberger. 5. The Pennsylvania Rules of Civil Procedure require that an objection for improper venue must be made by preliminary objection or it is waived. Pa.R.C.P. 1006(e) and 1028(a)(1). 6. In the instant matter, venue is improper in Dauphin County because Defendants have no connection to this County and the requirements ofPa. R.C.P. 1006(a) are not met. 7. David M. Eichelberger and Susan S. Eichelberger are husband and wife who have jointly owned the Cumberland County property where Plaintiff allegedly fell since 1992. 8. All the events giving rise to this lawsuit occurred in Cumberland County, where venue is proper. 9. At all times relevant to this lawsuit, Defendants maintained their residence in Adams County, where they were served with Plaintiffs Complaint and where venue is also proper. 10. Defendants have no connection to Dauphin County. 11. Defendants do not own property in Dauphin County, have never maintained a residence in Dauphin County and have never worked in Dauphin County. 12. Plaintiff has not alleged contacts with Dauphin County sufficient to satisfy the venue requirements of the Pennsylvania Rules of Civil Procedure. 13. The only connection Dauphin County has to this action is that Plaintiff currently resides therein, which is irrelevant under the venue provisions of the Pennsylvania Rules of Civil Procedure. 14. Venue should be transferred to Cumberland County where the events giving rise to the suit transpired. -2- WHEREFORE, Defendants David M. Eichelberger and Susan S. Eichelberger respectfully request that this Honorable Court sustain its Preliminary Objections to venue, and order that this cause of action be transferred to Cumberland County, with costs and fees to be paid by Plaintiff pursuant to Rule 1006(e). DATE: Respectfully submitted, POST & ;~ By: JOl~ W.?ORNBEI~GER, ESQ. Atto~ey for Defendants David M. Eichelberger and Susan S. Eichelberger -3- I, John W. Dornberger, Attorney for David M. Eichelberger and Susan S. Eichelberger, do hereby swear and affirm that the facts and matters set forth in the foregoing document are true and correct to the best of my knowledge, information, and belief. The undersigned understands that the statements made therein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. DATE: John W. Esquire CERTIFICATE OF SERVICE I, John W. Dornberger, an attorney with the law offices of Post & Schell, P.C., do hereby certify that on the date listed below, I did serve a true and correct copy of the foregoing document upon the following person(s) at the following address(es) by sending same in the Un/ted States mail, first-class, postage prepaid: Lisa J. Mauer, Esquire Grahm & Mauer, P.C. The Commons at Valley Forge Suite 22, Post Office Box 987 Valley Forge, PA 19482 Attorney for Plaintiff Date: POST John' D~berger, Esquire GRAHAM & MAUER, P.C. BY: Lisa J. Mauer, Esquire Attorney I.D. No.: 65426 The Commons at Valley Forge Suite 22, P.O. Box 987 Valley Forge, Pennsylvania 19482 (610) 933-3333 STEPHANIE PRESBERY-HLrNT 202 R¢ily Street Harrisburg, PA 17102 VS. DAVID M. EICHELBERGER and SUSAN S. EICHELBERGER h/w t/a EICHELBERGER ENTERPRISES 455 Lake Meade Drive East Berlin, PA 17316 Attorney for Plaintiff DAUPHIN COUNTY NO.: 4958 S 2001 IN THE COURT OF COMMON PLEAS PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the complaint, a copy of which is attached hereto. GRAHAM & MAUER, P.C. Date: November 19, 2001 By: ' Attorney fOi- Plaintiff .J STEPHANIE PRESBERY-HUNT, Plaintiff DAVID M. EICHELBERGER and SUSAN S. EICHELBERGER, h/w, Defendants AND NOW, this : IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNSYLVANIA : : NO. 4958 S 2001' ORDER March, 2002, upon consideration of the attached stipulation, it is hereby ORDERED that the Prothonotary of Dauphin County is directed to transfer this case to the Court of Common Pleas of Cumberland County. All costs and fees associated with the transfer are to be paid by plaintiff. Distribution: Lisa J. Mauer, Esquire, The Commons at Valley Forge, Suite 22, P.O. Box 987, Valley Forge, PA 19482 John W. Domberger, Esquire, 240 Grandview Avenue, Camp Hill, PA 17011 Stephen Farina, Dauphin County Prothonotary Curt Long, Cumberland County Prothonotary, One Courthouse Square, Carlisle, PA 17013-3387 / COURT DAUPHIN OF COMMON PLEAS COUNTY CIVIL ACTION SUITS 2001 Entry By Summons ( ) Writ of Execution Issued: Appearance For: Plaintiff' Complaint Petition Appeal Custody Assumpsit Divorce Mortgage Foreclosure Change of Name Ejectment Quiet Title Defendant: Appt. of Viewers Replevin ( ) Declaration of Taking ( ) Forma Paupcris ( ) Mental Health ( t Protective Order ( ) Districl Juslice ( ) Date: (~/5/2002 Time: 02:30 PM Page 1 of 2 Filed: Subtype: Comment: Dauphin County Complete Case History 4958-CV-2001 -CV Stephanie Preabery Hunt vs. David M Eichelberger, etal. 10/22/2001 Civil Physical File: Y Appealed: N User: ADEETER Judge History Date 11/29/2001 Plaintiff Name: Address: Judge Reason for Removal No Judge, Current Presbery Hunt, Stephanie Phone: Employer: Party Type: Comment: Defendant Name: Address: Home: Eichelberger, David M Work: Phone: Home: Employer: Party Type: Comment: Attorneys Mauer, Lisa J Dornberger, John W Defendant Name: Eichelberger, Susan S Address: Work: (Primary attorney) Phone: Employer: Party Type: Comment: Register of Actions 10/22/2001 11/23/2001 1~/10/2001 12/17/2001 Home: Work: New Civil Case Filed This Date. Complaint reinstated, see praecipe filed See Docket Book for prior entries. Served Complaint upon Defendant(s) David M Eichelberger and Susan S Eichelberger. So Answers, J.R. Lotwick, Sheriff. Paid $66.00. Post & Schell by: John W. Dornberger, Esq. enters appearance on behalf of defendants. SSN: DOB: Sex: Send notices: Y SSN: DOB: Sex: Send notices: Y Send Notices Send Notices SSN: DOB: Sex: Send notices: Y No Judge, No Judge, No Judge, No Judge, No Judge, Date: 6Y5/2002 Time: 02:30 PM Page 2 of 2 Register of Actions 12/28/2001 2/28/2002 3/4/2002 3/7/2002 Dauphin County Complete Case History 4958-CV-2001 -CV Stephanie Presbery Hunt vs. David M Eichelberger, etal. Preliminary Objections of defendants David M. Eichelberger and Susan S. Eichelberger, filed Stipulated motion between plaintiffs and defendants to transfer venue from Dauphin County to Cumberland County pursuant to PA. R.C.P. 1006(e), filed Upon consideration of the attached Stipulation, it is hereby ORDERED that the Prothonotary of Dauphin County is directed to transfer this case to the Court of Common Pleas of Cumberland County. All costs and fees associated with the transfer are to be paid by the Plaintiff. See ORDER filed. Copies Distributed 3-4-02. The above action is transfer to the Court of Common Pleas of Cumberland County I hereby certify that the foregoin/g.is a true and corj'ect copy of the original filed. / . f! P~ o ItS No Judge, No Judge, Lewis, Richard A. No Judge, User: ADEETER Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania County of Dauphin : : Sheriff's Return No.4958-S - -2001 AND NOW:December 10, 2001 COMPLAINT EICHELBERGER DAVID M T/A EICHELBERGER ENTERPRISES (ADAMS CO) to SUSAN EICHELBERGER, PERSON IN CHARGE of the original COMPLAINT to him/her the contents thereof at at 6:13PMserved the within upon by personally handing 1 true attested copy(ies) and making known 455 LAKE MEADE DRIVE EAST BERLIN, PA 17316-0000 So Answers, Sheriff of Dauphin County, Pa. Plaintiff: HUNT PRESBERY STEPHANIE Sheriff's Costs:S66.00 PD 10/23/2001 RCPT NO 155667 DATE RECEIVEO DATE PROCESSED SHERIFF'S DEPARTMENT ADAMS COUNTY, PENNSYLVANIA COURTHOUSE, GETTYSBURG, PA 17525 INSTRUCTIONS: See "INSTRUCTIONS FOR SERVICE OF PROCESS BY SHERIFF SERVICE THE SHERIFF" on the rever~e of the last (No. 5) copy of this form. P1e~ae PROCESS RECEIPT, and AFFIDAVIT OF RETURN typo or p~et ~.;ib~,, i.~u.ng re.pab,ity of., cop~es. DO nut detaab any copk~. AC~D ENV.# 1. PLAINTIFF/S/ J 2. COURT NUMBER STEPHANIE PRESBERY-HUNT I 4958-S-2001 3. DEFENDANT/S/ DAVID M. EICHE~.BERGER and SUSAN S. EICBET.BERGER, b/w [4. ~YPE OF WmT O~ COMPLAINT: t/a EICHELgERGER ENTERPRISES ~einstated Complaint Si~RVE 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC., TO SERVICE OR DESCRIPnON OF PROPERTY TO BE LEVIED, AI-rACHED OR SOLD, David M. Eicbelberger & Susan S. Eicbelberger t/a Eicbelberger Enterprises 6. ADDRESS (Street or RFD, Apartment NO., City, Boro, Twp., State and ZIP CODE) &T 455 Lake Meade DriVe, East Berlin, PA 17316 INDICATE UNUSUAL SERVICE: [] PERSONAL [] PERSON IN CHARGE [] DEPUTIZE [] CERT. MAIL [] REGISTERED MAIL ~ POSTED [] OTHER Now, , I, SHERIFF OF ADAMS COUNTY, PA., do hereby deputize the Sheriff of County to execute this Writ and make return therof according to law. This deputation being made at the request and risk of the plaintiff. C: :%7.;;':' OF ADAMS COUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE. NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN--Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, affer notifying person of levy or affachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before sheriff's sale thereof. 9. SIGNATURE of AT[OHr~EY or other ORIGINATOR requesting service on behalf of: 10. TELEPHONE NUMBER 11. DATE Lisa J. Mauer, Esq. ~FLA~N~FF [] DEFENDANT (610) 933-3333 SPACE BELOW FOR USE OF SHERIFF ONLY -- DO NOT WRITE BELOW THIS LINE 12.~rl ackno,.~:-d~comptaint asreceiptindlCated°f theabove,Writ J SIGNATURE of Authorized ACED Deputy or Clerk and Title I 13. Date Received 14. Expiration / Hearing date 15. I heraby CERTIFY and RETURN that J [~have personally served, [] have served person in charge, [] have legal evidence of service as shown in "Remarks" (on reverse) [] have posted the above described property with the writ or complaint described on the individual, company, corporation, etc., at the address shown above or on the individual, company, corporation, etc,, at the address Inserted below by handing/or Posting a TRUE and ATTESTED COPY therof. 16. [] I hereby certify and return a NOT FOUND because I am unable to locate the Individual, company, corporation, etc., nan~cl above. (See remarks below) 17. Name and title of individual served Susan S. Eichelberger secved personally and I la. ^ p~o. o~ suitable ~ and dl~rm~n Read Order accepted se~ice for ~d M. Eichel~rger p~,.~ D 19. Addr~ ~ ~e ~ (~pl~e on~ if different than shown ~ove) (Street or RFD, Apa~ment No., C~, ~ro, Twp., State and ZIP COD~ 20. Date of ~wice 21. Time ~. A, ,cm.,= ~ Mil. ~p.lnt. O.~ MI~ ~,.Int. Dm MI~ hp.~m. Dm Mit.. ~ 12/10/2001 6:13PM ~. ~an~ ~ 24 25 ~ ,Int. Date MII~ ~p.lnt. SO ANSER. Jar~s W. Muller AFFIRMED and subscribed to before me this day of MY COMMISSION EXPIRE8 ~HERIFF OF ADAMS COUNTY I ACKNOV. n Em~__= ,t=C~-il'i OF THE C'.'.:..... = RETURN ~IGNATURE JDate 12/10/2001 Date 12/10/2001 39. Dote Received PROTHONOTARY SHERIFF'S RETURN OF SERVICE (~) The within upon defendant by mailing to by prepaid, , the within named mail, return receipt requested, postage on the a true and attested copy thereof at The return receipt signed by defendant on the made a part of this return. (2) Outside the Commonwealth, pursuant to Pa. R.C.P. 405 (c) (1) and attested copy thereof at is hereto attached and (2), by mailing a true in the following manner: ( ) (a) to the defendant by ( ) registered ( ) certified mail, return receipt requested, postage prepaid, addressee only on the said receipt being returned NOT signed by defendant, but with a notation by the Postal Authorities that Defendant refused to accept the same. The returned receipt and envelope is attached hereto and made a part of this return. And thereafter: ( ) (b) To the defendant by ordinary mail addressed to defendant at same address, with the return address of the Sheriff appearing thereon, on the I further certify that after fifteen (15) days from the mailing date, I have not received' said envelope back from the Postal Authorities. A certificate of mailing is hereto attached as a proof of mailing. ( 3 ) By publication in the Adams County Legal Journal, a weekly publication of general circulation in the County of Adams, Commonwealth of Pennsylvania, and the Gettysburg Times, a daily newspaper published in the County of Adams, Commonwealth of Pennsylvania and having general circulation in said County for successive weeks of The Affidavits from said Adams County Legal Journal and Gettysburg Times, are hereto attached and made part of this return. ) ( 4 ) By mailing to by a true and attested copy thereof at mail, return receipt requested, postage prepaid, on the The is hereto attached. ) ( 5 ) Other returned by the Postal Mary Jane Snyder Real Estate Deput~ William T. Tully Solicitor J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief DepuO~ Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 J.R. Lotwick Sheriff Plaintiff STEPHANIE PRESBURY-HUNT VS Defendant DAVID ~( EICHELBERGER T/A EICHELBERGER ENTERPRISES No. 49.58 S 2001 And Now; December 3, 2001 I, hereby Deputize the Sheriff of ADAMS County, Pennsylvania, to serve the within REINSTATED COMPLAINT upon DA VID M. EICHELBERGER T/A E1CHELBERGER ENTERPRISES at 455 LAKE MEADE DRIVE EASTBERLIN, PA 17316 According to Law. So Answers Copies: 1 Advanced Costs: $150. O0 J.R. Lotwick, Sheriff of Dauphin County, Pa. (KINDLY RETURN THIS DEPUTIZA TION WITH YOUR RETURN OF SER VICE) RETURN ~,J. Nno3 03Al303~ Mary Jane Snyder Real Estate DepuO, William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 (717) 255-2660 J.R. Lotwick Sheriff SHERIFF'S RETURN No: 4958 S 2001 Page: J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy And Now: OCTOBER 30, 2001 SheriffofYORK COUNTY, PA made diligent search and inquiry for within named defendant, DAVID M. EICHELBERGER T/A EICHELBERGER ENTERPRISES and returns Not Found. So Answers, Sheriff of the County of Dauphin Plaintiff: STEPHANIE PRESBERY-HUNT Sheriff's Cost: NOTE: ADDRESS GIVEN 455 LAKE MEADE DR, EAST BERLIN, PA. 17316 IS LOCATED IN ADAMS COUNTY. COUNTY Of YORK OFFICE QF THE SHERIFF (1 of 2) 28 EAST MARKET ST., YORK, PA 17401 SHERIFF SERVICE PROCESS RECEIPT and AFFIDAVIT OF RETURN SERVICE CALL (717) 771-9601 1. PLAINTIFF/S/ Stephanie Presbery-Hunt 3 DEFENDANT/S/ David M. Eichelbe SERVE /' 5 NAME OF INDIVIDUAL, COMPANY ~"~ !.- David M. Eic. h~lher~r ~/~ F~h~lh~r~r Hn~iSOS ~ ~ 6 ADDRESS (STREET OR RFO WITH'"BOX NUMBER, APT. NO., CITY, BOR~, TWP., STATE ANb ~IP CODE) AT ~-455 Lake Meade Dr. Ea.~t Berlin. Pa. 1731& 7. INDICATE SERVICE: Q PERSONAL ~1 PERSON'IN CHARGE X]~ DEPUTIZi= (~ CERT. MAIL Q 1 ST CLASS MAIL 4. TYPE OF WRIT OR COMPLAINT ATTACHED, OR SOLD POSTED Q OTHER NOW ,20 I, SHERIFF OF YORK COUNTY, PA, do hereby deputize the sheriff of COUNTY to execute this Writ and make return thereof according to law. This deputization being made at the request and risk of the plaintiff. SHERIFF OF YORK COUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: OUT O~ COUNTY DAUPH IN ADVANCE FEE PAID BY ATTY Ni3TE: ONLY APPLICABLE ON WRIT OF EXECUTION; N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy er the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriffs sala thereof. 9. TYPE NAME and ADDRESS of ATTORNEY I ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER 11. DATE FILED LISA J. MAUER,ESQ.. THE COF~v~NS AT VALT,~ FORGE (610) 933-3333 STE. 22, PO BOX 987, VAT,L~Y FORGE, PA 19482 10/22/01 12. SEND NOTICE OF SERVICE COPY TO NAME AN D ADDRESS BELOVth (This area must be completed if notice is to be mailad). DAUPHIN COUNTY SHERIFF 13. I acknowledge receipt of the writ 14. DATE RECEIVED 15. Expiration/Hearing Date or complaint as indicated above. Jo T.UDWIG 3.0/24/03. 11/23./03. 16-jHOWSERVED: PERSONAL( ) RESIDENCE( ) POSTED( ) POE( ) SHERIFF'SOFFICS( ) OTHER( ) SEE REMARKS BELOW t7. ~J~ I hereby certify and return a NOT FOUND because I am unabla to locate the individual, company, eh:. named above. (See remarks below.) 18. NAME AN D TITLE OF INDIVIDUAL SERVED / LIST ADDRESS H ERE IF NOT SHOWN ABOVE (Relationship to Defendant) 19. Date of Service 20. Time of Service 211ATTEMPTS22 REMARKS Date Time Miles Int. IDafo Time Miles Int. IDate Time Miles Int. I Date Time Miles Int. I Date Time Miles Int. I Date Time Miles Int. · 9 ty . dvance COS s 36. Service Costs 37. NolaP/Ceil 38. Mileage/Postage/Not Found 41. AFFIRMED and subscribed to before me this ;"~ ~ 42. dayof r}£Tr'IRFR 2o_Q143 _~?~.~,/~.. z& 44. Signature of Notarial ~11 1 46. Signature of York James V. Vangreen, Notary Public ! County Sheriff City of York, YorkCoumty, PA, I WILLIAM M. HOSE My Commission Expires Mai'. 21, 2OO5~ 48 Signature of Foreign County Sheriff _ _ . 10-30-01 50 ~ ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE OF AUTHORIZED ISSUING AUTHORITY AN D 3 ITLE 51. DATE RECEIVED 1. WHITE - Issuing Authority 2 PINK - Attorney 3. CANARY - Sheriffs Office 4. BLUE - Sheriffis Office Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 J.R. Lotwick Sheriff Plaintiff STEPHAN1E PRESBERY-HUNT VS Defendant DAVID 11~ E1CHELBERGER T/A EICHELBERGER ENTERPRISES No. 4958 $ 2001 And Now; October 23, 2001 I, hereby Deputize the Sheriffof YORK County, Pennsylvania, to serve the within COMPIMINT upon DAVID M. E1CHELBERGER T/A E1CHELBERGER ENTERPRISES 455 LAKE MEADE DR EASTBERLIN, PA 17316 J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy According to Law. So Answers Copies: 1 Advanced Costs: $ 75. O0 J.R. Lotwick, Sheriff of Dauphin County, Pa. (KINDL Y RETURN THIS DEPUTIZATION }YITH YOUR RETURN OF SER VICE) RETURN Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Shedff J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania County of Dauphin Sheriff's Return No.4958-S - - -2001 AND NOW:December 10, 2001 at 6:13PMserved the within COMPLAINT EICHELBERGER SUSAN S T/A EICHELBERGER ENTERPRISES (ADAMS CO) to HER upon by personally handing 1 true attested copy(ies) of the original COMPLAINT and making known to him/her the contents thereof at 455 LAKE MEADE DR EAST BERLIN, PA 17316-0000 So Answers, Sheriff of Dauphin County, Pa. Plaintiff: HUNT PRESBERY STEPHANIE Sheriff's Costs:S66.00 PD 10/23/2001 RCPT NO 155667 DATE RECEIVED DATE PROCESSED SHERIFF'S 'DEPARTMENT ADAMS COUNTY, PENNSYLVANIA COURTHOUSE, GETTYSBURG, PA 17325 INSTRUCTIONS: See "INSTRUCTIONS FOR SERVICE OF PROCESS BY SHERIFF SERVICE THE SHERIFF" on the reverse of the last (No. 5) ~opy of this form. Please PROCESS RECEIPT, and AFFIDAVIT OF RETURN typa or pri~ legibly, insuri.g readability of all copies. Do not detach any copies. ACSD ENV.# 1. PLAINTIFF/S/ 2. COUR,T, NUMBER 3~Ef'~iE PR~bERY-HU[~t ~. ~ ~ 49.58-S,2001 s. DEFENDANT/S/ DAVID H. EICHE%J~ERGER and SUS;W. 5. EIC~{GER, b/w [4. TY,E OF WmT .OR COMPLAINT: t/a EiC~!ELBERGER E~I'ERPRISES ~einstated Complaint SERVE s. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC., TO'SERVICE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED OR SOLD. Davia ~r~. ~.tcbal~aroo~ & Susaa $. £ic~eJ. be~_"g~r L/a Eicbe:Lbe~&er E,~Le'cprises 6. ADDRESS (Street or RFD, Apartment No., City, Boro, Twp., State and ZIP CODE) aT 455 L~ke He,de D~if~[~st ~e~lin, P~ 17316 7. INDICATE UNUSUAL SERVICE: [] PERSONAL [] PERSON IN CHARGE [] DEPUTIZE [] CERT. MAIL [] REGISTERED MAIL [] POSTED [] OTHER Now, , I, SHERIFF OF ADAMS COUNTY, PA., do hereby deputize the Sheriff of County to execute this Writ and make return therof according to law. This deputation being made at the request and risk of the plaintiff. SHERIFF OF ADAMS COUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE. NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN--Any deputy shedff levying ~pon or attaching ~ny property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before sheriff's sale thereof. 9. SIGNATURE of ATTORNEY or other ORIGINATOR requesting service on behalf of: 10. TELEPHONE NUMBER 11. DATE ~is~ Jo ?~l]ei-~ F~.~(]. [] DEFENDANT (,0107 ~J.~-.)J3.) SPACE BEL(~W FOR USE OF SHERIFF ONLY -- DO NOT WRITE BELOW THIS LINE 15. I hereby CERTIFY and RETURN that I [:~ave personally served, [] have served person in charge, [] have legal evidence of service as shown in "Remarks" (on reverse) [] have posted the above described property with the writ or complaint described on the individual, company, corporation, etc., at the address shown above or on the individual, company~ corporation, etc., at the address inserted below by handing/or Posting a TRUE and ATTESTED COPY therof. 16. [] I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, corporation, etc., named above. (See remarks below) 17. Name and title of individual sewed ~L1S~}~] ~. ~.C~i~e~'~E,~.' D,~:CVed pe['SOB~ 11y a ~ th~ msMIng tn the ~fenda.t's usual acta?ted secv[c~ for DaVid H. [:ic~e]['x~-~~ .... ~,.o ~ata and ZIP CODE) 28. ~ REFUND AFFIRMED ar.:t sub~crlpad to before me this day of ~-,~;~u.u~.~ y/Oepcty~ PUblic MY COMMISSION EXPIRES I ACKNowLEDGE RECEIPT OF THE SHERIFF'8 RETURN SIGNATURE OF AUTHORIZED I~UING AUTHORITY AND TITLE. SO ANSWER. Date Date SHERIFF'S RETURN OF SERVICE ) ( 1 ) The within upon defendant by mailing to by_ prepaid, a true and attested copy thereof at the within named mai[. return receipt requested, postage on the ) (2) The return receipt signed by defendant on the made a part of this return. Outside the Commonwealth, pursuant to Pa. R.C.P. 405 (c) and attested copy thereof at is hereto attached and (1) (2), by mailing a true in the following manner: ( ) (a) to the defendant by ( ) registered ( ) certified mail, return receipt requested, postage prepaid, addressee only on the said receipt being returned NOT signed by defendant, but with a notation by the Postal Authorities that Defendant refused to accept the same. The returned receipt and envelope is attached hereto and made a part of this return. And thereafter: ( ) (b) To the defendant by ordinary mail addressed to defendant at same address, with the return address of the Sheriff appearing thereon, on the I further certify that after fifteen (15) days from the mailing date, I have not received' (3) said envelope back from the Postal Authorities. A certificate of mailing is hereto attached as a proof of mailing. By publication in the Adams County Legal Journal, a weekly publication of general circulation in the County of Adams, Commonwealth of Pennsylvania, and the Gettysburg Times, a daily newspaper published in the County of Adams, Commonwealth of Pennsylvania and having general circulation in said County for successive weeks of The Affidavits from said Adams County Legal Journal and Gettysburg Times, are hereto attached and made part of this return. By mailing to by mail, return receipt requested, postage prepaid, on the (4) a true and attested copy thereof at The returned by the Postal ' AdthOtitleS marked is hereto attached. ( 5 ) Other Mary Jane Snyder Real Estate DepuO~ William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 J.R. Lotwick Sheriff J. Daniel Basile Chlef Depu~ Michael W. Rinehart Assistant Chief Depu~ Plaintiff STEPHANIE PRESBURY-HUNT vs Defendant SUSAN S. E1CHELBERGER T/A EICHELBERGER ENTERPRISES No. 4958 S 2001 And Now; December 3, 2001 I, hereby Deputize the Sheriff of ADAMS County, Pennsylvania, to serve the within REINSTATED COMPLAINT upon SUSAN S. EICHELBERGER T/A EICHELBERGER ENTERPRISES 455 LAKE MEADE DRIVE EASTBERLIN, PA 17316 According to Law. So Answers Copies: 1 Advanced Costs: J.R. Lotwick, Sheriff of Dauphin County, Pa. (KINDL Y RETURN THIS DEPUTIZA TION WITH YOUR RETURN OF SER VICE) RETURN AINflO3 $1dVO¥ OCJ :11 'V q- 3'JI) IOOZ ' Q3AI303B Mary Jane Snyder Real Estate DepuO~ William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 (717) 255-2660 J.1L Lotwick Sheriff SHERIFF'S RETURN No: 4958 S 2001 Page: J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chlef Deputy And Now: OCTOBER 30, 2001 Sheriff of YORK COUNTY, PA made diligent search and inquiry for within named defendant, SUSAN S. EICHELBERGER T/A EICHELBERGER ENTERPRISES and returns Not Found. So AnsweFs, J.R. Lotwick Sheriff of the County of Dauphin Plaintiff.' STEPHANIE PRESBERY-HUNT SheriW s Cost: NOTE: ADDRESS GIVEN 455 LAKE MEADE DR, EAST BERLIN, PA. 17316 IS LOCATED IN ADAMS COUNTY. Mary Jane Snyder Real Estate DepuO~ William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 J.R. Lotwick Sheriff Plaintiff STEPHAN1E PRESBERY-HUNT V$ Defendant SUSAN E1CHELBERGER T/A EICHELBERGER ENTERPRISES No. 4958 S 2001 And Now; October 23, 2001 I, hereby Deputize the Sheriffof YORK County, Pennsylvania, to serve the within COMPLAINT upon SUSAN EICHELBERGER T/A E1CHELBERGER ENTERPRISES at 455 LAKE MEADE DR EAST BERLIN, PA 17316 J. Daniel Basile Chief DepuO~ Michael W. Rinehart Assistant Chief Depu~ According to Law. So Answers Copies: 1 Advanced Costs: J.R. Lotwick, Sheriff of Dauphin County, Pa. (KINDLY RETURN THIS DEPUTIZA TION WITtt YOUR RETURN OF SER VICE) RETURN Sheriff HUNT PRESBERY STEPHANIE ENTERPRISES (~) 455 LAKE MEADE DRIVE EAST BERLIN, PA 17316 (01 COPY) ZICELERGERSUS~ S T/A EICZELBERGER ENTERPRISES i~k~U~ O) 455 ~E ME~E DR EAST BERLIN, PA 17316 (01 COPY) ~ NO. 4958-S - -2001 COMPLAINT Directions to Sheriff of Dauphin County, PA MAUER LISA {610) 933-3333 THE COLONS AT V~LEY FORGE SUITE 22, P.O.BOX 987 V~LEY FORGE, PA 19482 GRAHAM & MAUER, P.C. ATTORNEYS-AT-LAW THE COI~MONS AT VALLEY FORGE SUITE 22, P.O. BOX 987 VXLLEY FORG~, PA 19482 (610) 9333333 1-800-218-0808 FAX (610) 983-0570 1136 S~MMERWOOD DmVl~ HAR~SBURG, PA 17111 (717) 240-0900 (717) 652-1200 November 5, 2001 Sheriff's Department ' Dauphin County Courthouse Front & Market Streets Harrisburg, PA 17101 Stephanie Presbery Hunt vs. David and Susan Eichelberger CCP # 4958 S 2001 Dear Sir or Madam: Enclosed please find a check in the amount of$150.00 payable to Adams County Sheriff for service in the above captioned case. Ple~sg fp ,r~,vard the appropriate documents to Adams County. Thank you for your cooperation in this matter. Sincerely, Enclsoure ZO:~ N~ L- AON I0 301J JO S,JJl~'J2ll g AiNNO3 NtH~JN V ~I POST & SCHELL, P.C. BY: JOHN W. DORNBERGER, ESQUIRE I.D. # 69293 240 GRANDVIEW AVENUE CAMP HILL, PA 17011 (717) 731-1970 ATTORNEYS FOR DEFENDANTS DAVID M. EICHELBERGER AND SUSAN S. EICHELBERGER STEPHANIE PRESBERY-HUNT Plaintiff, DAVID M. EICHELBERGER and SUSAN S. EICHELBERGER h/w Defendants. 1N THE COURT OF COMMON PLEAS DAUPHIN COUNTY NO. 4958-S-2001 TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Defendants, David M. Eichelberger and Susan S. Eichelberger. POST & SCHELL, P.C. JOI-[ Attor~ W. DORNBERGER ey I.D. No. 69293 240 ~ randview Avenue Camp Hill, PA 17011 (717) 731-1970 Attorneys for David M. Eichelberger and Susan S. Eichelberger CERTIFICATE OF SERVICE I, John W. Domberger, an attorney with the law offices of Post & Schell, P.C., do hereby certify that on the date listed below, I did serve a tree and correct copy of the foregoing document upon the following person(s) at the following address(es) by sending same in the United States mail, first-class, postage prepaid: Lisa J. Mauer, Esquire Grahm & Mauer, P.C. The Commons at Valley Forge Suite 22, Post Office Box 987 Valley Forge, PA 19482 Attorney for Plaintiff Date: POST & SCHELL, P.C. Jo~ire GRAHAM & MAUER, P.C. BY: Lisa J. Mauer, Esquire Attorney I.D. No.: 65426 The Commons at Valley Forge Suite 22, P.O. Box 987 Valley Forge, Pennsylvania 19482 (610) 933-3333 STEPHANIE PRESBERY-HUNT : : vs. : NO.: 2002-02847 DAVID M. EICHELBERGER and : SUSAN S. EICHELBERGER tgw : t/a EICHELBERGER ENTERPRISES : Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PLAINTIFF'S REPLY TO DEFENDANTS' NEW MATTER 15. Denied. Answering Plaintiff is advised by counsel and, therefore, avers that the allegations contained in the corresponding paragraph of the Defendant's New Matter are automatically deemed denied as conclusions of law to which no responsive pleading is required. Strict proof thereof is demanded at trial, if material. By way of further reply, PlaintiWs Complaint clearly states a claim upon which relief can be granted. 16. Denied. Answering Plaintiff is advised by counsel and, therefore, avers that the allegations contained in the corresponding paragraph of the Defendant's New Matter are automatically deemed denied as conclusions of law to which no responsive pleading is required. Strict proof thereof is demanded at trial, if material. By way of further reply, Plaintiff's Complaint was timely filed and Plaintiff's claims are not barred by the statute of limitations. 17. Denied. Answering Plaintiff is advised by counsel and, therefore, avers that the allegations contained in the corresponding paragraph of the Defendant's New Matter are automatically deemed denied as conclusions of law to which no responsive pleading is required. Strict proof thereof is demanded at trial, if material. By of further reply, Defendants are owners of the premises and, therefore, did have actual or constructive notice of the defective condition on the premises. 18. Denied. Answering Plaintiff is advised by counsel and, therefore, avers that the allegations contained in the corresponding paragraph of the Defendant's New Matter are automatically deemed denied as conclusions of law to which no responsive pleading is required. Strict proof thereof is demanded at trial, if material. By way of further reply, Defendants are liable for Plaintiff's injuries and/or damages resulting from the defective condition on the premises, since Defendants were responsible for the maintenance of the premises. 19. Denied. Answering Plaintiff is advised by counsel and, therefore, avers that the allegations contained in the corresponding paragraph of the Defendam's New Matter are automatically deemed denied as conclusions of law to which no responsive pleading is required. Strict proof thereof is demanded at trial, if material. By way of further reply, Plaintiff was in no way contributorily and/or comparatively negligent. 20. Denied. Answering Plaintiff is advised by counsel and, therefore, avers that the allegations contained in the corresponding paragraph of the Defendant's New Matter are automatically deemed denied as conclusions of law to which no responsive pleading is required. Strict proof thereof is demanded at trial, if material. By way of further reply, Plaintiff in no way assumed the risk of the occurrence of the incident and the injuries and damages sustained. 21. Denied. Answering Plaintiff is advised by counsel and, therefore, avers that the allegations contained in the corresponding paragraph of the Defendant's New Matter are automatically deemed denied as conclusions of law to which no responsive pleading is required. Strict proof thereof is demanded at trial, if material. By way of further reply, Plaintiff's injuries and damages were the direct result of Defendants' negligence. 22. Denied. Answering Plaintiff is advised by counsel and, therefore, avers that the allegations contained in the corresponding paragraph of the Defe~ttant's New Matter are automatically deemed denied as conclusions of law to which no responsive pleading is required. Strict proof thereof is demanded at trial, if mterial. By way of further reply, Plaintiff is in no way responsible for spoliation of evidence. To the contrary, to the extent Plaintiff's claims may be barred in whole or in part by the doctrine of spoliation of evidence, said spoliation is solely attributable to Defendants' conduct. 23. Denied. Answering Plaintiff is advised by conn~l and, therefore, avers that the allegations contained in the corresponding paragraph of the Defendant's New Matter are automatically deemed denied as conclusions of law to which no responsive pleading is required. Strict proof thereof is demanded at trial, if material. By way of further reply, Plaintiff in no way failed to mitigate her damages. To the contrary, Plalntiffhas made every effort to mitigate her damages resulting from this accident. 24. Denied. Answering Plaintiff is advised by counsel and, therefore, avers that the allegations contained in the corresponding paragraph of the Defendant's New Matter are automatically deemed denied as conclusions of law to which no responsive pleading is required. Strict proof thereof is demanded at trial, if material. By way of further reply, Plaintiff's injuries and damages were caused solely by the negligence of Defendants and not by the intervening wrongdoing of others over which Defendants had no control. 25. Denied. Answering Plaintiff is advised by counsel and, therefore, avers that the allegations contained in the corresponding paragraph of the Defendant's New Matter are automatically deemed denied as conclusions of law to which no responsive pleading is required. Strict proof thereof is demanded at trial, if material. By way of further reply, Plaintiff's Complaint was timely filed and Plaintiff' s claims are not barred by the doctrine of res judicata and/or collateral estoppel. 26. Denied. Answering Plaintiff is advised by counsel and, therefore, avers that the allegations contained in the corresponding paragraph of the Defendant's New Matter are automatically deemed denied as conclusions of law to which no responsive pleading is required. Strict proof thereof is demanded at trial, if material. By way of further reply, Plaintiff specifically denies that her claims are barred by the lease between Plaintiff and Defendants and that her remedies are limited exclusively by the lease. 27. Denied. Answering Plaintiff is advised by counsel and, therefore, avers that the allegations contained in the corresponding paragraph of the Defendant's New Matter are automatically deemed denied as conclusions of law to which no responsive pleading is required. Strict proof thereof is demanded at trial, if material. By way of further reply, Plaintiff has not failed to join all persons or parties necessary for a just adfltdication of the controversy. 28. Denied. It is specifically denied that the perils or dangers of which Plaintiffcomplalns were open and obviously known to Plaintiff. To the contrary, said perils or dangers represented latent defects of which Defendants had aclu_a! or constructive notice. 29. Denied. Answering Plaintiff is advised by counsel and, therefore, avers that the allegations contained in the corresponding paragraph of the Defer~dant's New Matter are automatically deemed denied as conclusions of law to which no responsive pleading is required. Strict proof thereof is demanded at trial, if material. By way of further reply, PlaintiWs claim is not barred or limited by the affirmative defense of consent. To the contrary, Plaintiff in no way consented to the defective condition of the premises located at 152 North Pitt Street, Carlisle, Cumberland County, Pennsylvania. 30. Denied. It is specifically denied that Plaintiff failed to provide Defendants with adequate and proper notice of any defects. To the contrary, Defer~,d~nts, as owners of the Premises located at 152 North Pitt Street, Carlisle, Pennsylvania, had actual or constructive notice of the defective condition on the premises and a duty to warn Plaintiff of the defective condition or make said condition safe. 31. Denied. The defective conditions described in Plaintiff's Complaint were in no way caused by the Plaintiff. To the contrmy, said defective conditions on the premises were caused solely by the negligence of Defendants. 32. Denied. It is specifically denied that Plaintiff's injuries and damages were not proximately caused by Defendants. To the contrary, Plaintiff's injuries and damages were caused solely by the negligence of Defendants. 33. Denied. Answering Plaintiff is advised by counsel and, therefore, avers that the allegations contained in the corresponding paragraph of the Defendant's New Matter are automatically deemed denied as conclusions of law to which no responsive pleading is required. Strict proof thereof is demanded at trial, if material. By way of further reply, Defendants, as owners of the premises located at 152 North Pitt Street, Carlisle, Pennsylvania, had a duty to make safe or warn Plaintiff of the defective conditions which existed on the property at the time of Plaintiff's fall. Defendants, as owners of the premises, had a duty to inspect the premises and, therefore, had actual or constructive notice of the defective condition of the premises. 34. Denied. The damages alleged by Plaintiff are clearly recoverable under the applicable law. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter judgment in her favor and against Defendants. Date: Respectfully submitted, o GRAHAM & MAUER, P.C. By:( ~i/sa 'J'J Maue(' ~ ~'~Att~'~ey for ~laintiff VERIFICATION I, Stephanie Muir, hereby state that I am the Plaintiff in this Action and verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that the sta~ments therein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. DATE: September 26, 2002 GRAHAM & MAUER, P.C. BY: Lisa J. Mauer, Esquire Attorney I.D. No.: 65426 The Commons at Valley Forge Suite 22, P.O. Box 987 Valley Forge, Pennsylvania 19482 (610) 933-3333 STEPHANIE PRESBERY-HUNT VS. DAVID M. EICHELBERGER and SUSAN S. EICHELBERGER h/w t/a EICHELBERGER ENTERPRISES Attorney for Plaint~f IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 2002-02847 CERTIFICATE OF SERVICE I, Lisa $. Mauer, Esquire, attorney for Plaimiff, do hereby certify that on this 27~ day of September, 2002, plaintiff's Reply to Defendant's New Matter was sent by First Class, US Mail to the following: Jack Canavan, Esquire Post & Schell 240 G-randview Avenue Camp Hill, PA 17011 Fax No. 717-731-1985 GRAHAM & MAUER, P.C. ( fl~isa/J. MaWr, l~sqfi~re ~'~ Affomey ~Of Plaintiff POST & SCHELL, P.C. BY: JOHN W. DORNBERGER I.D. #: 69293 BY: JOHN R. CANAVAN I.D. #: 84728 240 GRANDVIEW AVENUE CAMP HILL, PA 17011 (717) 731-1970 STEPHANIE PRESBERY-HUNT Plaintiff, Vo DAVID M. EICHELBERGER and SUSAN S. EICHELBERGER h/w Defendants. ATTORNEYS FOR DEFENDANTS DAVID M. EICHELBERGER AND SUSAN S. EICHELBERGER, H/W COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2002-02847 CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Plaintiff.' You are hereby notified to plead to the enclosed Answer and New Matter of Defendants David M. Eichelberger and Susan S. Eichelberger within twenty (20) days hereof or a default judgment may be entered against you. POST & SCH By: JOHN ~[."C~IqAVA!~ DATE: m service , ESQ. Attom ts for Defendants David M. Eichell erger and Susan S. Eichelberger POST & SCHELL, P.C. BY: JOHN W. DORNBERGER I.D. #: 69293 BY: JOHN R. CANAVAN I.D. #: 84728 240 GRANDVIEW AVENUE CAMP HILL, PA 17011 (717) 731-1970 STEPHANIE PRESBERY-HUNT Plaintiff, Vo DAVD M. EICHELBERGER and SUSAN S. EICHELBERGER h/w Defendants. ATTORNEYS FOR DEFENDANTS DAVID M. EICHELBERGER AND SUSAN S. EICHELBERGER, H/W COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2002-02847 CIVIL ACTION - LAW JURY TRIAL DEMANDED ANSWER AND NEW MATTER OF DAVID M. EICHELBERGER, SUSAN S. EICHELBERGER AND EICHELBERGER ENTERPRISES TO PLAINTIFF'S COMPLAINT Defendants David M. Eichelberger, Susan S. Eichelberger and Eichelberger Enterprises ("Defendants"), by and through their attorneys, Post & Schcll, P.C., hereby file this Answer and New Matter to Plaintiff's Complaint as follows: 1. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of the allegations and, accordingly, all such allegations are denied. 2. Admitted in part; denied in part. It is denied that 455 Lake Mead Drive is located in York County, Pennsylvania. It is admitted that David M. Eichelberger and Susan S. Eichelberger, husband and wife, reside at 455 Lake Mead Drive, East Berlin, Adams County, Pennsylvania. 3. Admitted in part; denied in part. The corresponding allegations are denied to the extent that the Complaint fails to identify "at all times pertinent hereto" with sufficient specificity. It is admitted that Defendants owned and maintained the property at 152 North Pitt Street, Carlisle, Cumberland County, Pennsylvania on December 18, 1999. All remaining allegations are denied as conclusions of law. 4. Denied. The corresponding allegations are conclusions of law to which no responses is required. To the extent a response is required, the allegations are denied pursuant to Rule 1029(e) of the Pennsylvania Rules of Civil Procedure. 5. Denied. The corresponding allegations are denied pursuant to Rule 1029(e) of the Pennsylvania Rules of Civil Procedure. To the extent any further response is required, after reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of the allegations and, accordingly, all such allegations are denied. 6. Denied. The corresponding allegations are denied pursuant to Rule 1029(e) of the Pennsylvania Rules of Civil Procedure. To the extent any further response is required, after reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of the allegations and, accordingly, all such allegations are denied. 7. Denied. The corresponding allegations are conclusions of law to which no response is required. To the extent any further response is required, it is denied that Defendants had actual or constructive knowledge of any allegedly defective condition or that there was, in fact, a defective condition which was the proximate cause of Plaintiff's alleged injuries. 8. Denied. The corresponding allegations are denied pursuant to Rule 1029(e) of the Pennsylvania Rules of Civil Procedure. To the extent any further response is required, after reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of the allegations and, accordingly, all such allegations are denied. Any remaining allegations are denied as conclusions of law. 9. Denied. The corresponding allegations are denied pursuant to Rule 1029(e) of the Pennsylvania Rules of Civil Procedure. To the extent any further response is required, after reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the troth of the allegations and, accordingly, all such allegations are denied. 10. Denied. The corresponding allegations are denied pursuant to Rule 1029(e) of the Pennsylvania Rules of Civil Procedure. To the extent any further response is required, after reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of the allegations and, accordingly, all such allegations are denied. 11. Denied. The corresponding allegations are denied pursuant to Rule 1029(e) of the Pennsylvania Rules of Civil Procedure. To the extent any further response is required, after reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of the allegations and, accordingly, all such allegations are denied. 12. Denied. The corresponding allegations are denied pursuant to Rule 1029(e) of the Pennsylvania Rules of Civil Procedure. To the extent any further response is required, after reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the troth of the allegations and, accordingly, all such allegations are denied. 13. Denied. The corresponding allegations are denied pursuant to Rule 1029(e) of the Pennsylvania Rules of Civil Procedure. To the extent any further response is required, after reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of the allegations and, accordingly, all such allegations are denied. 14. Denied. The corresponding allegations are denied pursuant to Rule 1029(e) of the Pennsylvania Rules of Civil Procedure. To the extent any further response is required, the allegations are denied as conclusions of law. WHEREFORE, Defendants David M. and Susan S. Eichelberger respectfully request that this Honorable Court enter judgment in their favor and against Plaintiff. NEW MATTER 15. Plaintiff may have failed to state a claim upon which relief can be granted. 16. Plaintiff's claims may be barred by the statute of limitations. 17. Defendants are not liable for any of Plaintiff's alleged injuries and/or damages because they did not have actual or constructive notice of any allegedly defective condition on the premises. 18. Defendants are not liable for any of Plaintiff's alleged injuries and/or damages because the existence of any allegedly defective condition, the same being denied, was caused by Plaintiff's negligent maintenance of the premises. 19. Plaintiff's claims may be barred in whole or in part by her contributory and/or comparative negligence or that of her agents. 20. Plaintiff's claims may be barred because Plaintiff assumed the risk of the occurrence of the incident and the injuries or damages claimed. 21. The alleged injuries and damages were the result of the actions and omissions of Plaintiff and/or persons other than Defendant. 22. ofevidence. 23. Plaintiff's claims may be barred in whole or in part by the doctrine of spoliation Plaintiffmay have failed to mitigate her damages. 24. Plaintiff's injuries and/or damages, if any, were caused by intervening wrongdoing of others over which the Defendant had no control and for which this Defendant is not responsible. Plaintiff's claims may be barred by the doctrine of res judicata and/or collateral 25. estoppel. 26. Defendants assert all of the defenses, limitations and provisions of any and all agreements entered into by Defendants and Plaintiff regarding the lease by Plaintiff of the property at 152 North Pitt Street, Carlisle, Cumberland County, Pennsylvania and Defendant avers that the remedies of Plaintiff as against Defendant are limited exclusively thereto and therefore the present action may be barred. 27. Plaintiff may have failed to join all persons or parties necessary for a just adjudication of the controversy. 28. The perils or dangers of which Plaintiff complains, to the extent any existed, the same being denied, were open and obviously known to Plaintiff, who nevertheless conducted herself in such a manner as to expose herself to said perils and/or dangers. Plaintiff s claims may be barred or limited by the affirmative defense of consent. Plaintiff failed to provide Defendants with adequate and proper notice of any 29. 30. alleged defect. 31. The conditions described in Plaintiff's Complaint, which allegedly caused her injuries, may have been caused by Plaintiff. 32. The damages alleged to have been sustained by Plaintiff were not proximately caused by Defndants. 33. Defendants may not have had actual and/or constructive possession of the area of the property in which Plaintiff allege the accident occurred and, therefore, Defendants had not duty to correct or warn Plaintiff of the conditions which Plaintiff alleges existed on the property. 34. The damages alleged by Plaintiff are not recoverable under the applicable law. WHEREFORE, Defendants David M. and Susan S. Eichelberger respectfully request that this Honorable Court enter judgment in their favor and against Plaintiff. DATE: PoSTRespectfully& S~HE~h i' i,~submitte~ By~ J(~q R. CANAVAN, ESQ. At~6mey for Defendants VERIFICATION I, David M. Eichelberger, do hereby swear and affirm that the facts and matters set forth in the Objections and Answers to Plaintiff's Interrogatories are tree and correct to the best of my knowledge, information, and belief. The undersigned understands that the statements made therein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. DATE: David ~Eichelberge~r VERIFICATION I, Susan S. Eichelberger, do hereby swear and affirm that the facts and matters set forth in the Objections and Answers to Plaintiff's Interrogatories are true and correct to the best of my knowledge, information, and belief. The undersigned understands that the statements made therein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. DATE: CERTIFICATE OF SERVICE I, John R. Canavan, Esquire, do hereby certify that on the date listed below, I did serve a tree and correct copy of the foregoing document upon the following person(s) at the following address(es) by sending same in the United States mail, first-class, postage prepaid: Lisa J. Mauer, Esquire Grahm & Mauer, P.C. The Commons at Valley Forge Suite 22, Post Office Box 987 Valley Forge, PA 19482 Attorney for Plaintiff DATE: POST & SCH~, P.~ By: f~//b/~/~ ..... J~q k. C~VAN, ES~. \05_A~LIABXJPM\CORR\127321 ~RYM\16205~50000 STEPHANIE PRESBERY-HUNT, Plaintiff DAVID M. EICHELBERGER, and SUSAN S. EICHELBERGER h/w t/a EICHELBERGER ENTERPRISES, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 200:2-02847 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the undersigned on behalf of Defendants, David M. Eichelberger and Susan S. Eichelberger, h/w t/a Eichelberger Enterprises, in the above- referenced matter. Respectfully submitted, MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN DATED: BY: J0~P'I~ F. MUR]t~Y,E~sq~ire 4~00 Crums Mill Road Suite B Harrisburg, PA 17112 I.D. No. 78119 (717) 651-3508 CERTIFICATE PREREQUISITE TO SERVICE OF A S~POENA PURSU~ TO RULE 4009.22 IN THE MATTER OF: PRESBERY-HUNT COURT OF COMMON PLEAS TERM, EICHELBERGER -VS- CASE NO: 2002-2847 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOSEPH F. MURPHY, 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: 07/29/2003 JOSEPH F. MURPHY, ESQ~ Attorney for DEFENDANT DEll-434190 9 5 1 7 7 --LO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PRESBERY-HUNT EICHELBERGER -VS - COURT 0F C0~40N PLEAS TERM, CASE NO: 2002-2847 NOTICE OF IN~r~faTT TO SERVE A SUBPOENA TO PRODUCE DOCUMF~-rS A~,, · r~w~S FOR DISCOVERy PurSUANT TO RULE 4009.21 WILLIS WILLARD, M.D. PMA GROUP ALLSTATE INSURANCE COMPANY PHIC0 SERVICE COMPANY MEDICAL RECORDS INSURANCE INSUP~%NCE INSURANCE TO: LISA J. MAUER, ESQ. MCS on behalf of JOSEPH F. MURPHY, 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: 07/09/2003 CC: JOSEPH F. MURPHY, ESQ. - 16205-PENDING MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEPENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1~01 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-234611 95177--CO1 COMMON-WEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PRRSBERY-HuNT VS Et t;m.:LBERG'ER File No. 2002-: - '~' "~q7 TO: SUBPOENA TO PRODUCE DOCUMENTS OR THING£ FOR DISCOVERY PURSUANT TO RULE 4009.?? CUS1DDIAIt OF RECORDS FOR; IflLLIS IfIl.l.ai~n, ~ (Name of Person or Entity.) Within twen .ty (20) days after service of this subpoena, you are ordered bv the court to produce the following documents or things: ~ . at lqCS G'ROUP INC., 1601 NAllr~£ ST., t~800, PH~.a.pA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: JOSEPH NIJRPRY, ESQ. ADDRESS: 4200 CRIMS HILL RD., HARRISBURG, PA 17112 TELEPHONE: 215-246-0900 SUPREME COURT ID #: A'I-FORNEY FOR: DEFENDANT DATE: ! Seal or' the Court ¥7-FECOU, , Pramonota~y/Cler[, Civil ' on (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: WILLIS WILLARD, M.D. 49 BROOKWOOD AVENUE CARLISLE, PA 17013 RE: 95177 STEPHANIE PRESBERY-HUNT Entire med, ical fde, including, but not limited to any and all records, corresponaence 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 resent. Subject: STEPHANIE PRESBERY_HUN~,p Social Security #: 176-54-2327 SU10-453052 9 5 1 7 7 --LO 1 CERTIFICATE PREREOUISITE TO SERVICE OF A SUBPOENA PURSU~ TO RULE 400).22 IN THE MATTER OF: PRESBERY-HUNT COURT OF COMMON PLEAS TERM, EICHELBERGER -rs - CASE NO: 2002-2847 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOSEPH F. MURPHY, ESQ. certifies that (l) 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: 07/29/2003 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT DEll-434191 9 5 1 7 7 --LO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PRESBERY-HUNT EICHELBERGER -VS- COURT OF COMMON PLEAS TERM, CASE NO: 2002-2847 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS THINGS FOR DIS~y PURSITAITT TO RDLI~ 4009.21 WILLIS WILLARD, M.D. PEA GROUP ALLSTATE INSURANCE CONPANY PHIC0 SERVICE COMPANY MEDICAL RECORDS INSURANCE INSUP~/~CE INSUP. ANCE TO: LISA J. MAUER, ESQ. MCS on behalf of JOSEPH F. MURPHY, 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: 07/09/2003 CC: JOSEPH F. t~IRPBY, ESQ. - 16205-PENDING MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEPENDANT Any questions regard/nE this matter, THE MCS GROUP INC. 1601 MARKET STREET #00O PHILADELPHIA, PA 19103 (215) 246-0900 DE02-234611 95 177--CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PRESBERY-HUNT VS EIUH ~:I.BLtRGER File No. 2002 TO: SUBPOENA TO PRODUCE DOCUMENTS OR THING£ FOR DISCOVERY PURSUANT TO RULE 4009,?'~ COSTODIAN OF RECOKI)S FOR; PMA GROIYP (Name of Person or Emity. ~ Within enty (~0) days after service of this subpoena, you are ordered bv the court to produce the following documents or things: ~AC~D ' at MCS GROUP INC., 1601MAm~T ST., {800, PHIY~-PA 19103 (Address} You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this r~quest 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 fai to produce the documents or things required by this subpoena, within twenty (20) davs after ts service,.the party serving this subpoena may seek a court order compelling you to comply with t ' THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: JOSEPH I~IRPHY, ESQ. ADDRES& 4200 CRI]MS MXLL RD., HARRXSBORG, PA 17112 TELEPH©N'E: 215-246-0900 SL'PREME COURT ID #: ATTORNEY FOR: DEF]ENDANT DATE: Seal of the Court (Eif. 7/07) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PMA GROUP P.O. BOX 25250 LEHIGH VALLEY, PA 18002 RE: 95177 STEPHANIE PRESBERY-HUNT CLAIM NO.: 5000W099320000000; FILE NO: 4U000664133 Any and all insurance records and PIP files, including but not limited to ~nocedical rep?rts and/or records, claims, any and all correspondence, umentanon supporting plaintiff's claim, payments including dates of payments, payee and reasons for payments, including any and all such items stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject: STEPHANIE PRESBERY-HUNT Social Security #: 176-54-2327 Date of Loss: 12/18/1999 SU10-453054 95 1 7 7--L02 CERTIFICATE PREREOUISITE TO SERVICE OF A SUBPOENA PURSU2~,~}T TO RULE 400).22 IN THE MATTER OF: PRESBERY-HUNT COURT OF COMMON PLEAS TERM, EICHELBERGER -VS - CASE NO: 2002-2847 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOSEPH F. MURPHY, 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: 07/29/2003 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT DEll-434192 9 5 1 7 7 --LO 3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PRESEERY-HUNT EICHELBEEGER -VS- COURT OF COMMON PLEAS TERM, CASE NO: 2002-2847 NOTICE OF II~i'~TT TO SERVE A SUBPOENA TO PRODUCE DOCD-~Uf~TS 'r~/m4GS FOR DISCOVERy PUI~SUANT TO RULE 4009.21 WILLIS WILLAHD, M.D. PMA GROUP ALLSTATE INSURANCE COMPANY PHIC0 SERVICE COMPANY MEDICAL RECORDS INSURANCE INSURANCE INSUP, ANCE TO: LISA J. MAUER, ESQ. MCS on behalf of JOSEPH F. MURPHY, 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: 07/09/2003 CC: JOSEPH F. MURPHY, ESQ. - 16205-PENDING MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDAFr Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET ~800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-234611 95177--CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PRESBER¥-I~JNT VS EIGUgLBERGER File No. 2002. TO: SUBPOENA TO PRODUCE DOCUIVlENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.29 CUSTODIAN OF RECORDS FOR; ALLSTATE INSURANCE C~4~/iY (Name of Person or EntiW. ) Within twenty. (20) days after service of this subpoena, you are ordered bv the court to produce the following documents or things: SEE AT~I~ql~ ' at MCS GROUP INC., 1601HARKE~ ST., #800, PEILA. PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twen .fy (20) davs 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: JOSI~I/ HURPI~, ESQ. ADDRESS: 4200 CRUHS HILL RI)., BARILISBURG, PA 17112 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: D g i~I~AI~ Seal of the Cour: EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ALLSTATE INSURANCE COMPANY 6345 FLANK DRIVE SUITE 1000 HARRISBURG, PA 17112 RE: 95177 STEPHANIE PRESBERY-HUNT CLAIM NO.: 155396191101 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 stored in a computer database or otherwise in electronic form, pertaining to: ~ua,tes Re. quested: up to and including the present. bjeet. STEPHANIE PRESBERY-HUNT Social Security #: 176-54-2327 Date of Loss: 12/18/1999 SU10-453056 9 5 1 7 7 --LO 3 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: PRESBERY-HUNT COURT OF COMMON PLEAS TERM, EICHELBERGER -VS- CASE NO: 2002-2847 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOSEPH F. MURPHY, 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: '07/29/2003 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT DEll-434193 9 5 1 7 7--LO 4 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: PRESBERY-HUNT EICHELBERGER -VS- COURT OF C0~i0N PLEAS TERM, CASE NO: 2002-2847 NOTICE OF Ii~T~NT TO S~R%q~ A SIIBPO]~NA TO PRODUCE D~S A~rl~ T~--~ WO~ DISC~Y Pu.~UANT TO RUX~ 4009.21 WILLIS WILLARD, M.D. PMA GROUP ALLSTATE INSUP. ANCE COMPANY PHICO SERVICE COMPANY MEDICAL RECORDS INSURANCE INSURANCE INSURANCE TO: LISA J. MAUER, ESQ. MCS on behalf of JOSEPH F. MURPHY, 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: 07/09/2003 CC: JOSEPH F. KIRPHY, ESQ. - 16205-PENDING MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-234611 95 1 77--CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PRE SBER¥-ItUW[ VS EI~;IiI~I~BERGER File No. 2002-- TO: SUBPOENA TO PRODUCE DOCUMENTS OR THING~ FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAIq OF RECORDS FOR; PltICO SERVICE CO (Name of Pe~on or Entity, J Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the fo ow ng documents or things: SEE at HCS gROUP INC., 1601 HARKE~ ST., #800, PItII~.PA 19103 (Address/ You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this r~kiuest 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. It' 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: JOSEPH HU'Ri~, ESQ. ADDRE$5: 4200 CRUMS I'ffIZ RD., lt.~ISBl~tG, PA 17112 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT Seal of the Cour: (Eli. 7 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PHICO SERVICE COMPANY P.O. BOX 2029 MECHANICSBURG, PA 17055 RE: 95177 STEPHANIE PRESBERY-HUNT CLAIM NO.: 021176542327B Any and all insurance records and PIP fries, 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 stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject :STEPHANIE PRESBERY-HUNT Social Security #: 176-54-2327 Date of Loss: 12/18/1999 SU10-453058 9 5 1 7 7 --LO 4 CERTIFICATE PP, EKEOUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22: IN THE MATTER OF: STEPHANIE PRESBERY-HUNT COURT OF COMMON PLEAS TERM, EICHELBERGER ~VS- CASE NO: 2002-02847 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOSEPH F. MURPHY, ESq. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/27/2003 DEll-453310 95177--LO 5 C OlVll~iO bIl~ -:AL T H OF PENNSYLVANIA COUNTY OF C UlVlB E }tLAND IN THE MATTER OF: STEPHANIE PRESBERY-HUNT -VS- EICHELBERGER COURT OF COMMON PLEAS TERM, CASE NO: 2002-02847 NOTICE OF INT~.~ TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS~OR DISCOVERY PURSUANT TO RULE 4009.21 HEALTHSOUTH REHAB HARTMANREHABILITA~ION ASSOC. POLYCLINIC MEDICAL!CENTER ADULT ~ALTH CLINId LOYSVILLE COMPLEX MEDICAL RECORDS MEDICAL EECORDS MEDICAL RECORDS MEDICAL RECORDS 19~PLOYMENT TO: LISA J. MAUER,{ESQ. MCS on behalf of JqSEPH F. MURPHY, ESq. intends to serve a subpoena identical to the one that is attached to this notice!. You have twenty (20) days from the date ilisted 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 reprqduced records may be ordered at your expense by completing the attached couns~l card and returning same to MCS or by contacting our local MCS office. DATE: 10107/2003 CC: JOSEPH F. MURPHY, ESQ. - 16218-00105 MCS on behalf of JOSEPH F. MURPHY, ESq. Attorney for DEFENDANT Any questions regal ding this matter, contact THE MOS GROU~ INC. 1601 MARKET STREET ;800 PHILADELPHIA, PA 19103 (215) 246-0900 I)E02-244028 95177--C01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STEPHANIE PRESBERY-HUNT VS. EICHELBERGER File No. 2002-02847 SUBI~OENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Record~ for HEALTHSOUTH 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 RIDER **** at The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadeh~hia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, togeth~ with the certificate of compliance, to the party making this request at the address listed above. You have the rigl to seek, in advance, the reasohable cost of preparing the copies or producing the things sought. If you fail to produce the doquments or th/rigs required by this subpoena within twenty (20) days after its servic 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: JOSEPH F. ADDRESS: 4200 CRUM SUITE B HARRISBU TELEPHONE: (215) 246-0~ SUPREME COURT ID #: ATTORNEY FOR: Defe ~URPHY, ESQ. MILL ROAD kG. PA 17110 90 dant Date: Seal of the ; >urt BY TH[', COURT: _~ Prothonotary/Clerk, Civil Div~[~n Deputy 95177-05 EXPLANATION OF REQUIRED iRECORDS TO: CUSTODIAN OF RECORDS FOR: HEALTHSOUTH REHAB MECHANICSBURG REHAB CTR. 4700 UNION DEPOSIT HARRISBURG, PA 17111 RE: 95177 , STEPHANIE PRESBERY-HUNT Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other pro~'iders. Entire medical file, inclgding but not limited to any and all records, correspondence to and f~om the consulting and treating physicians, files, memoranda, handwritte, 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 p~rtaining to: Dates Requested: up t~ and including the present. Subject: STEPHANIEJ PRESBERY-HUNT Social Security #: 176-$4-2327 Date of Birth: 07-27-1958 SU10-467696 95177--L05 CERTIFICATE PREREQUISITE TO SERVICE OF A St~POENA PURSUANT TO RULE 4009.2Z IN THE MATTER OF: STEPHANIE PRESBERY-HUNT COURT OF COMMON PLEAS TERM, EICHELBERGER 4VS- CASE NO: 2002-02847 As a prerequisite go service of a subpoena for docttments and things pursuant to Rule 4009.22 eCS!on behalf of JOSEPH F. MURPHY, ESq. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached ~hereto 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 ~o this certificate, (3) No object~on to the subpoena has been rece:Lved, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/27/2003 eCS on behalf of JOSEPH F. MURPHY, ESq. Attorney for DEFENDANT DEll-453311 95177--LO 5 C 0 lv]1401,,V~q~ AL T H OF PENNSYLVANIA COUNTY OF CU14B E[RLAND IN THE MATTER OF: STEPHANIE PRESBERY-HUNT -VS- EICHELBERGER COURT OF COMMON PLEAS TERM, CASE NO: 2002-02847 HEALTHSOUTH P. EHAB HARTMANREHABILITA' POLYCLINIC MEDICAL ADULT HEALTH CLINI~ LOYSVILLE COMPLEX NOTICE OF IN~ENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THING~ FOR DISCOVERY PURSUANT TO RULE 4009.21 MEDICAL RECORDS ~ION ASSOC. MEDICAL RECORDS CENTER MEDICAL RECORDS MEDICAL RECORDS EMPLOYMENT TO: LISA J. MAUER, ESQ. MCS on behalf of J,)SEPH F. MURPHY, ESq. intsnds to serve a subpoena identical to the o~e that is attached to this notice. You have twenty (20) days from the dateilisted below in which to file of record and serve upon the undersigned an objgction to the subpoena. If the twmnty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any repr6duced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/07/2003 CC: JOSEPH F. MURPHY, ESQ. - 16218-00105 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT Any questions rega :ding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 18oo PHILADELPHIA, PA 19103 (2i5) 246-0900 DE02-244028 95177--CCi COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STEPHANIE PRESBERY-HUNT VS. EICHELBERGER File No. 2002-02847 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Record~ for HARTMAN REHABILITATION ASSOC. (Name of Person or Entity) Within twenty (20) days afie~ service of this subpoena, you are ordered by the court to produce the following documents or things: ***~* SEE ATTACHED RIDER **** at The MCS Grout>. Inc..il601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by tk~s subpoena, togeth with the certificatc of compliance, to the party making this request at the address listed above. You have the ri to seek, in advanct,' -the reast~nable cost of preparing the copies or producing the things sought. If you fail to produce the do4uments or things required by this subpoena within twenty (20) days after its serv: 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: JOSEPH F. MURPHY, ESQ. ADDRESS: 4200 CRUMS MILL ROAD SUITE B i I-IPdCRISBU[RG. PA 17110 TELEPHONE: (215~ 246-0~00 sUP ME COtmT #: i ATTORNEY FOR: Defendant Date: Seal of the BY TH]?, COURT: Prothonotary/Clerk, Cix~il Di~i~~''~ Deputy (~ - 95177-16 EXPLANATION OF REQUIRED iRECORDS TO: CUSTODIAN OF RECORDS FOR: HARTMAN REHABILITATION ASSOC. 2645 N. 3RD STREET SUITE 490 HARRISBURG, PA 17110 RE: 95177 STEPHANIE PRESBERY-HUNT INCLUDE RECORDS FROM STUART A. HARTMAN, D.O. Please call for prior appl-oval for fees in excess of $100.00 for hospitals, $50.00 for all other prox}iders. Entire medical file, inchiding but not limited to any and all recmds, correspondence to and f~om the consulting and treating physicians, files, memoranda, handwritteO notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otl~erwise in electronic form, relating to anty examination, diagnosis or treatment p~rtaining to: Dates Requested: up tO and including the present. Subject: STEPHANIE PRESBERY-HUNT Social Security #: 176-54-2327 Date of Birth: 07-27-1958 SU10-467698 9 5 1 7 7 -- L 0 6 CERTIFICATE PKEKEQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO ~ULE 4009.22: IN THE MATTER OF: STEPHANIE PRESBERY-HUNT COURT OF COMMON PLEAS TERM, EICHELBERGER CASE NO: 2002-02847 As a prerequisite ~o service of a subpoena for documents and things pursuant to Rule 4009.22 eCS ion behalf of JOSEPH F. MURPHY, ESq. certifies that (1) A notice ~f intent to serve the subpoena with a copy of the subpoena attached ~hereto 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 ~o this certificate, (3) No object~on to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/27/2003 eCS on behalf of JOSEPH F. MURPHY, ESq. Attorney for DEFENDANT DEll-453312 95177--L0 7 C O lvflv~ O 5F~rE AL T H OF PENNSYLVANIA COUNTY OF C UlV~B E ~RLAND IN THE MATTER OF: STEPHANIE PRESBERY-HUNT -VS- EICHELBERGER COURT OF COMMON PLEAS TERM, CASE NO: 2002-02847 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THING~ FOR DISCOVERY PURSUANT TO RULE 4009.21 NRALTHSOUTH REHAB i MEDICAL RECORDS REHABILITATION ASSOC. MEDICAL RECORDS HARTMAN POLYCLINIC MEDICAL{CENTER MEDICAL RECORDS ADULT HEALTH CLINI~ MEDICAL RECORDS LOYSVILLE COMPLEX EMPLOYMENT TO: LISA J. MAUER, iESQ. MCS on behalf of J~)SEPH F. MURPHY, ESq. intends to serve a subpoena identical to the ~ days from the date undersigned an obi waived or if no ob copies of any repr the attached couns MGS office. he that is attached to this notics. You have twenty (20) listed below ia which to file of record and serve upon the ~ction to the subpoena. If the twenty day notice period is iection is made, then the subpoens may be served. Complete ~duced records may be ordered at your expense by completing 31 card and returning same to MCS or by contacting our local DATE: 10/0712003 CC: JOSEPH F. MURPHY, ESQ. - 16218-00105 MCS on behalf of JOSEPH F. MURPHY, ESq. Attorney for DEFENDANT Any questions rega :ding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET ~800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-244028 95177--CC 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STEPHANIE PRESBERY-HUNT VS, EICHELBERGER File No. 2002-02847 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FgR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Record! for pOLYCLINIC MEDICAL CENTER (Name o£ Person or Entity) Within twenty (20) days afte~ service of this subpoena, you are ordered by the court to produce the following documents or things: ***? SEE ATTACHED RIDER **** at The MCS Grouts. Inc..!1601 Market Street. Suite 800. Phdadelohm. P 19103 You may deliver or mail leg/Ne copies of the documents or produce things requested by this subpoena, togeth with the certificate of compliance, to the party making this request at the address listed above. You have the ri to seek, in advance, the reasdnable 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 at~er its serv the party serving this subpoOaa may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: JOSEPH F. VIURPHY, ESQ. ADDRESS: 4200 CRLri~ iS MILL ROAD SUITE B . HARRISBURG. PA 17110 TELEPHONE: (215} 246-0000 SUPREME coURT ID #: i ATTORNEY FOR: Defendant Date: Seal of the ~ourt Prothonotary/Clerk, Civil Div~n Deputy 95177-17 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: POLYCLINIC MEDICAL CENTER 2601 NORTH 3RD STREET HARRISBURG, PA 17110 RE: 95177 STEPHANIE PRESBER¥-HUNT Entire hospital medical t correspondence to and f, memoranda, handwritte~ prescription records, nm and all patient consent o medication, lab and diag as may be stored in a co: relating to any examinat admission, discharge, or Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other prox4iders. lc, including but not limited to any and all records, om the consulting and/or treating physician, files, notes~ history and physical reports, medication/ se's notes, doctor's comments, dietary restrictions, refusal of treatment, procedures, test, and/or aostic test results, including any and all such items nputer database or otherwise in electronic form, on, consultation, diagnosis, care, treatment, emergency care pertaining to: Dates Requested: up t6 and including the present. Subject: STEPHANIE PRESBERY-ItUNT Social Security/it: 176-54-2327 Date of Birth: 07-27-1958 SU10-467700 95177--L0,7 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: STEPHANIE PRESBERY-MUNT COURT OF COMMON PLEAS TERM, EICHELBERGER CASE NO: 2002-02847 As a prerequisite rio service of a subpoena for documents and things pursuant to Rule 4009.22 MCS ion behalf of JOSEPH F. MURPHY, ESq. certifies that (1) A notice ~f intent to serve the subpoena wlth a copy of the subpoena attached ~hereto was mailed or delivered to each party at least twenty dans prior to the date on which the subpoena is sought to be served, (2) A copy of Ithe notice of intent, including the proposed subpoena, is attached <o this certificate, (3) No object~on to the subpoena has been receJ.ved, and (4) The subpoena which will be served is identical to the subpoena which is attachMd to the notice of intent to serve the subpoena. DATE: 10/27/2003 MCS on behalf of JOSEPH F. MURPHY, ESq. Attorney for DEFENDANT DEll-453313 95177--L0 B C O ~ll~O N-W-EAL T H OF PENN;SYLVANIA COUNTY OF CUFIB E :RLAND IN THE MATTER OF: STEPHANIE PRESBERY-HUNT -VS- EICHELBERGER COURT OF COMMON PLEAS TERM, CASE NO: 2002-02847 NOTICE OF INT~ THINGS HEALTHSOUTH REHAB HARTMANREHABILITA! POLYCLINIC MEDICAL ADULT HEALTH CLINI( LOYSVILLE COMPLEX ~ TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND FOR DISCOVERY PURSUANT TO RULE 4009.21 'ION ASSOC. CENTER MEDICAL ~ECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS E~dPLOYMENT TO: LISA J. MAUER,JESQ. MCS on behalf of JqSEPH F. MURPHy, ESq. intends to serve a subpoena identical to the oge that is attached to this notice. You have twenty (20) days from the dateJlisted below in which to file of record and serve upon the undersigned an objgction to the subpoena. If the twenty day notice period is waived or if no obi copies of any repr~ the attached couns~ MCa office. DATE: 1010712003 ection is made, then the subpoena may be served. Complete ,duced records may be ordered at your expense by completing card and returning same to MCS or by contacting our local MCS on behalf of JOSEPH F. MUPdPHY, ESq. Attorney for DEFENDANT CC: JOSEPH F. MUP~, ESQ. - 16218-00105 Any questions regal · ding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET ~800 PHILADELPHIA, PA 19103 (215) 246-0900 :DE02-244028 95177--CG1 COMMONWEALTH OF PENNSYLVANIA COLrNTY OF CUMBERLAND STEPHANIE PRESBERY-HUNT VS. EICHELBERGER File No. 2002-02847 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Record~ for ADULT HEALTH CLINIC (Name of Person or Entity) Within twemy (20) days aft~ service of this subpoena, you are ordered by the court to produce the following documents or things: ***4 SE]~ ATTACHED RIDER **** at The MCS Grout>. Inc.. ~601 Market Street. Suite 800. Philadclohia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, togetb with the certificate of compli~mce, to the party making this request at the address listed above. You have the rig] to seek, in advance, the reasohable cost of preparing the copies or produci:ag the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its servic the party serving this subpoeCa may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: JOSEPH F. I~IURPHY, ESQ. ADDRESS: 4200 CRUMS MILL ROAD SUITE B HARRISBURG. PA 17110 TELEPHONE: (215) 246-0~00 SUPREME COURT ID #: I ATTORNEY FOR: Defe~Oonl; Date: Seal of the Cburt Prothonotary/Clerk, Civil l~ivi¢~ot~ l~eputy 95177-~8 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ADULT HEALTH CLINIC 177 NORTH HANOVER STREET CARLISE, PA 17013 RE: 95177 STEPHANIE PRESBEI~y-HUNT Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other proxfiders. Entire medical file, inch ding but not limited to any and all records, coirespondence to and fl om the consulting and treating physiciarts, files, memoranda, handwritte~ notes, history and physical reports, medication/ prescription recoMs, inc udin. g a.ny and all such items as may be stored in a computer database or ot]terw~se ~n electronic form, relating to any examination, diagnosis or treatment p~,:rtaining to: Dates Requested: up t, ~ and including the present. Subject: STEPHANIE PRESBERY-HUNT Social Security #: 176-54-2327 Date of Birth: 07-27-1958 SU10~467702 95177--L08 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: STEPHANIE PRESBERY-HUNT COURT OF COMMON PLEAS TERM, EICHELBERGER -US- CASE NO: 2002-02847 As a prerequisite tO service of a subpoena for documents and things pursuant to Rule 4009.22 MCS On behalf of JOSEPH F. MURPHY, ESq. certifies that (1) A notice o~ intent to serve the subpoena with a copy of the subpoena attached t~ereto was mailed or delivered to each party at least twenty day~ prior to the date on which the subpoena is sought to be served, (2) A copy of ~he notice of intent, including the proposed subpoena, is attached t~ this certificate, (3) No objectign to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attache¢ to the notice of £ntent to serve the subpoena. DATE: 10/27/2003 MCS on behalf of JOSEPH Y. MURPHY, ESQ. Attorney for DEFENDANT DEll-453314 95177--L0~ C O lvllvIO N-~q~AL T H OF PENNSYLVANIA COUNTY OF CI31VlB E ]ILAND IN THE MATTER OF: STEPHANIE PRESBERY-~HUNT -VS- EICHELBERGER COURT OF COMMON PLEAS TERM, CASE NO: 2002-02847 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS~OR DISCOVERY PURSUAN~ TO RULE 4009.21 HEALTHSOUTH REHAB / MEDICAL RECORDS HARTMAN REBABILITAT~ON ASSOC. MEDICAL RECORDS POLYCLINIC MEDICAL ~ENTER MEDICAL RECORDS ADULT HEALTH CLINIC:! MEDICAL RECORDS LOYSVILLE COMPLEX ! EMPLOYMENT TO: LISA J. MAUER, MCS on behalf of JO identical to the on days from the date undersigned an obje waived or if no obi copies of any repro the attached counse MCS office. DATE: 10]07/2003 Esq. ~EPH F. MURPHY, ESq. intends to serve a subpoena that is attached to this notice. You have twenty (20) listed below in which to file of record and serve upon the ztion to the subpoena. If the twenty day notice period is ~ction is made, then the subpoena may be served. Complete iuced records may be ordered at your expense by completing card and returning same to MCS or by contacting our local CC: JOSEPH F. MURP~, ESQ. - 16218-00105 Any questions regarding this matter, contact MCS on behalf of JOSEPH F. MURPHY, ESq. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-244028 95177--C0~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TO: STEPHANIE PRESBERY-HUNT VS. EICHELBERGER Within twenty (20) days af~ex documents or things: **** at The MCS Grout). Inc.. You may a. liver or mail legi with the ce~ fificate of compli~ to seek, in a:lvance, the reaso: If you fail to produce the doc the party serving this subpoer THIS SUBPOENA WAS ISS File No. 2002-02847 i SUBI~OENA TO PRODUCE DOCUMENTS OR THINGS FQR DISCOVERY PURSUANT TO RULE 4009.22 Custodian of Record~ for LOYSVILLE COMPLEX (Name of Person or Entity) service of this subpoena, you are ordered by the court to produce the following SEE ATTACHED RIDER **** 601 Market Street. Suite 800. Philadelphia. PA 19103 ~le copies of the documents or produce things requested by this subpoena, togethe ~ce, to the party making this request at the address listed above. You have the figt ruble cost of preparing the copies or producing the thing l sought. ~ments or things required by this subpoena within twenty (20) days after its servic~ a may seek a court order compelling you to comply with it. UED AT THE REQUEST OF THE FOLLO'WiNG PERSON: NAME: JOSEPH F. I~ ADDRESS: 4200 CRUM SUITE B HARRISBUI TELEPHONE: (215'~ 246-09. SUPREME COURT ID #: ATTORNEY FOR: Defe Date: [URPHY, ESO. MILL ROAD :G. PA 17110 )0 ,dant BY THE COURT: Pro~notary/-C~erk, Civil Di¢Ts't~ Deputy Seal of the C,3urt 95177-0t EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: LOYSVILLE COMPLEX R.R.#2, BOX #365-B HUMAN RESOURCES OFF. LOYSVILLE, PA 1704' RE: 95177 STEPHANIE PRESBEI~ (-HUNT Please call for prior appr $50.00 for all other prov: Any and all employment time and attendance reco~ all medical records as an stored in a computer data Dates Requested: up to Subject: STEPHANIE i ~val for fees in excess of $100.00 for hospitals, ders. :ecords, applications, files, memoranda, compensation, ds, personnel records, payroll and salary reports and :mployee, including any and all such items as may be rase or otherwise in electronic form, pertaining to: and including the present. 'RESBERY-HUNT Social S~urity #: 176-54-2327 Date of Birth: 07-27-195~ SU10-467704 9 517 7 --LO § CERTIFICATE PREREQUISITE TO SERVICE OF A SImPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COi~40N PLEAS STEPHANIE PRESBERY-HUNT TERM, -VS- CASE NO: 2002-02847 DAVID AND SUSAN EICHELBERGER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOSEPH F. MURPHY, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/03/2003 v//~z~ /~, DEll-454656 32OO5--LO1 COMMONWEALTH OF P ENN-C: YLVAN I A COUNTY OF CUMB E I~LAND IN TEE MATTER OF: STEPHANIE PRESBERY-HUNT -VS- DAVID AND SUSAN EIC~ELBERGEE COURT OF COMMON PLEAS TERM, CASE NO: 2002-02847 NOTICE OF IN'r~T TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND · r~/NGS FOR DISCO~KY PURSUANT TO RULE 4009.21 HEALTHSOUTH REHAB HARTMAN REHABILITATION ASSOC. POLYCLINIC MEDICAL CENTER ADULT HEALTH CLINIC LOYSVILLE COMPLEX MEDICAL RECOP~DS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS EMPLOYMENT TO: LISA J. MAUER, ESQ. MCS on behalf of JOSEPH F. MURPHY, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reprodUced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/13/2003 CC: JOSEPH F. MURPHY, ESQ. - 16218-00105 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-244826 3 2 O O 5 --CO I COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STEPHANIE PRESBERY-HUNT VS. DAVID AND SUSAN EICHLBERGER File No. 2002-02847 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HEALTHSOUTH 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 ATFACHED RIDER **** at The MO*q Group. Inc._ t601 Market Street. Suite 800. Philadelphia. PA ]:9103 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 fight to seek, in advance, the reasonable cost of preparing the copies or producirtg 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: JOSEPH F. MURPHY, ESQ, ADDRESS: 4200 CRUMS MILL ROAD SUITE B HARRISBURG. PA 17110 TELEPHONE: (215'} 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY THE COURT.;, /~ Prothonotary/(~le~k-, Civil~-~visi~n J Deputy 32005-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HEALTHSOUTH REHAB MECHANICSBURG REHAB CTR. 4700 UNION DEPOSIT HARRISBURG, PA 17111 RE: 32005 STEPHANIE PRESBERY-HUNT Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 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, ties, memoranda, handwritten notes, history and physical repons, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to ~aay examination, diagnosis or treatment pertaining to: Dates Requested: up t° and including the present. Subject: STEPHANIE PRESBERY-HUNT Social Security #: 176454-2327 Date of Birth: 07-27-1958 SU10-468692 3 2 0 0 5 --LO 1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RIFLE 4009.22 IN THE MATTER OF: STEPHANIE PRESBERY-HUNT COURT OF COMMON PLEAS TERM, -VS- DAVID AND SUSAN EICHELBERGER CASE NO: 2002-02847 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOSEPH F. MURPHY, 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 sou§bt to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/03/2003 MCS on behalf of JOSEPH F. MURPHY, ESq. Attorney for DEFENDANT DEll-454657 32005--L02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STEPHANIE PRESBERY-HUNT DAVID AND SUSAN EICHELBERGER COURT OF COMMON PLEAS TERM, CASE NO: 2002-02847 NOTICE OF IN'£~ TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS THINGS FOR DISCOVERY PD~.SU~NT TO RULE 4009.21 HEALTHSOUTH REHAB HARTMAN REHABILITATION ASSOC. POLYCLINIC MEDICAL CENTER ADULT HEALTH CLINIC LOYSVILLE COMPLEX MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS EMPLOYMENT TO: LISA J. MAUER, ESQ. ' MCS on behalf of JOSEPH F. MURPHY, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of :record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS ,or by contacting our local MCS office. DATE: 10/13/2003 CC: JOSEPH F. MURPHY, ESQ. - 16218-00105 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-244826 32005 --CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STEPHANIE PRESBERY-HUNT VS. DAVID AND SUSAN EICHLBERGER File No. 2002-02847 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARTMAN REHABILITATION 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 ATFACHED RIDER **** at The MC~$ Group. Inc.. 1601 Market Street. ,quite R00. 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 reasofiable 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: JOSEPH F. MURPHY. ESO. ADDRESS: 4200 CRUMS MILL ROAD SUITE B HARRISBUI~G. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Seal of the CoUrt BY THE COURT: /~ /] Prothonolary/Cle~, Civil~~'~ Deputy 32005-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARTMAN REHABILITATION ASSOC. 2645 N. 3RD STREET SUITE 490 HARRISBURG, PA 17110 RE: 32005 STEPHANIE PRESBERY-HUNT INCLUDING RECORDS FROM STUART A. HARTMAN, D.C. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other pr6viders. 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, histow 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: STEPHANIE PRESBERY-HUNT Social Security #: 176454-2327 Date of Birth: 07-27-1958 SU10-468694 3 2 0 0 5 --LO 2 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.2~~. IN THE MATTER OF: COURT OF C0MAMON PLEAS STEPHANIE PRESBERY-HUNT TERM, -VS- CASE NO: 2002-02847 DAVID AND SUSAN EICHELBERGER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOSEPH F. MURPHY, 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 attache~ to the notice of intent to serve the subpoena. MCS on behalf of DATE: 11/03/2003 JOSEPH F. MURPHY, ESq. Attorney for DEFENDANT DEll-454658 32005--L03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STEPHANIE PRESBERY-EUNT -VS- DAVID AND SUSAN'EICEELBEEGER COURT OF COMMON PLEAS TERM, CASE N0: 2002-02847 NOTICE OF INTE~L__TO SERV~ A SUBPOENA TO PRODUCE DOC'0Iw~qTS AND THINGS,~DISCO~IIK~ PURSUANT TO ROLE 4009.21 HEALTHSOUTH REHAB HARTMAN REHABILITATION ASSOC. POLYCLINIC MEDICAL CENTER ADULT HEALTH CLINIC LOYSVILLE COMPLEX MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS EMPLOYMENT TO: LISA J. MAUER, ESQ. MCS on behalf of JOSEPH F. MURPHY, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/13/2003 CC: JOSEPH F. MURPHY, ESQ. - 16218-00105 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-244826 3 200 5--CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STEPHANIE PRESBERY-HUNT VS. DAVID AND SUSAN EICHLBERGER File No. 2002-02847 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 400922 TO: Custodian of Records for POLYCLINIC MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by ~he court to produce the following documents or things: **** SEE AT]?ACHED 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 compliahce, 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: JOSEPH F. MURPHY. ESO. ADDRESS: 4200 CRIIMS! MILL P, OAD SUITE B HARRISBURg. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defen~aqt BY THE ,COURT: Prot honotary/Cle~, Civi~-D~ Date: Seal of the CoUrt Deputy 32005-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: POLYCLINIC MEDICAL CENTER 2601 NORTH 3RD STREET HARRISBURG, PA 17110 RE: 32005 STEPHANIE PRESBERY-HUNT Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 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, h/story 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: STEPHANIE PRESBERY-HUNT Social Security #: 176~54-2327 Date of Birth: 07-27-1958 SU10-468696 3 2 0 0 5 --LO 3 CERTIFICATE PKEREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COF~fON PLEAS STEPHANIE PRESBERY-HUNT TERM, -VS- CASE NO: 2002-02847 DAVID AND SUSAN EICHELBERGER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOSEPH F. MURPHY, 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. MCS on behalf of DATE: 11/03/2003 JOSEPH F. MURPHY, ESq. Attorney for DEFENDANT DEll-454659 32005--L04 COMMONWEALTH OF PENN-C| YLVAN IA COUNTY OF CUMBERLAND IN THE MATTER OF: STEPHANIE PRESBERY-HUNT -rS- DAVID AND SUSAN EICHELBERGER COURT OF COMMON PLEAS TERM, CASE NO: 2002-02847 NOTICE OF I~T~T TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINC. S ~FOR DISCOVERY PURSI]~'T TO RD~ 4009.21 HEALTHSOUTH REHAB HARTMAN REHABILITATION ASSOC. POLYCLINIC MEDICAL CENTER ADULT HEALTH CLINIC LOYSVILLE COMPLEX MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS EMPLOYMENT TO: LISA J. MAUER, ESQ. MCS on behalf of JOSEPH F. MURPHY, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/13/2003 CC: JOSEPH F. MURPHY, ESQ. - 16218-00105 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-244826 3 200 5--CO i COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STEPHANIE PRESBERY-HUNT VS. DAVID AND SUSAN EICHLBERGER File No. _ 2002-02847 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ADULT HEALTH CLINIC (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by lhe court to produce the following documents or things: **** SEE ATFACHED 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 ISSI~ED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: JOSEPH F. MURPHY, ESQ. ADDRESS: 4200 CRIIMS!MILL ROAD SUITE B HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: Al'TOP, NEY FOR: Defendant BY THE COURT.'~/,L2/~ Z Prot honotary/Cle~, ~ivi]- Di~ ' ~ Date: ~7~ Seal of the Court Deputy 32005-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ADULT HEALTH CLINIC 177 NORTH HANOVER STREET CARLISE, PA 17013 RE: 32005 STEPHANIE PRESBERY-HUNT Please call for prior approval for fees in excess of $100.00 for ihospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and t~rom the consulting and treating physicians, files, memoranda, handwritten notes, history and physical repons, 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 lo and including the present. Subject: STEPHANIE PRESBERY-HUNT Social Securi? #: 176-54-2327 Date of Birth. 07-27-1958 SU10-468698 3 2 0 0 5 --LO 4 CERTIFICATE PKEKEQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22: IN THE MATTER OF: STEPHANIE PRESBERY-HUNT COURT OF COMMON PLEAS TERM, -VS- DAVID AND SUSAN EICHELBERGEE CASE NO: 2002-02847 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOSEPH F. MURPHY, ESq. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered tc, each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/03/2003 MCS on behalf of JOSEPH F. MURPHY, ESq. Attorney for DEFENDANT DEll-454660 32005--L05 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STEPHANIE PRESBERY-HUNT -VS- DAVID AND SUSAN EICHELBERGER COURT OF COMMON PLEAS TERM, CASE N0:2002-02847 NOTICE OF I~'r~NT TO SERVE A SUBPOEN~ TO PRODUCE ~S AND THINGS FO]{ DISCO~K~ PURSUANT TO RULE 4009.21 HEALTHSOUTH REHAB HARTMAN REHABILITATION ASSOC. POLYCLINIC MEDICAL ~ENTER ADULT HEALTH CLINIC LOYSVILLE COMPLEX MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS EMPLOYMENT TO: LISA J. MAUER, ~SQ. MCS on behalf of JOSEPH F. MURPHY, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/13/2003 CC: JOSEPH ?. MURPHY, ESQ. - 16218-00105 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-244826 32OO5--CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STEPHANIE PRESBERY-HUNT VS. DAVID AND SUSAN EICHLBERGER File No.. 2002-02847 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for LOYSVI1,1 ~E COMPLEX (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: **** ~EE ATI'ACHED 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: JOSEPH F. MURPHY. ESO. ADDRESS: 4200 CRUMS MILL ROAD SUITE B HARRISBURJG. PA 17110 TELEPHONE: (215~} 246-0900 SUPREME COURT ID #: ATTORNEY FOR: DefenUant Seal of the Court BY THE COURT/~ ~ ~ ~Ih .~~ Prothonotary/Clc/rk, ~2~vi7 Div}s'i'~'fl~ ' J Deputy 32005-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: LOYSVILLE COMPLEX R.R.#2, BOX #365-B HUMAN RESOURCES OFF. LOYSVILLE, PA 17047 RE: 32005 STEPHANIE PRESBERY-HUNT Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all employment records, applications, files, memoranda, compensation, time and attendance reaords, 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 Go and including the present. Subject: STEPHANIE PRESBERY-HUNT Social Securi!.y #: 176~54-2327 Date of Birth. 07-27-1958 SU10-468700 3 2 0 0 5 --LO 5 CRRTI?ICI?~ PURSUAN~ ~0 RULR 4003.22 IN THE MATTER OF: STEPHANIE PRESBERY-HUNT COURT OF COMMON PLEAS TERM, -VS- DAVID AND SUSAN EICHELBERGER CASE NO: 2002-02847 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOSEPH F. MURPHY, ESQ. certifies that (i) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) NO objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/06/2003 ~Watorhey for DEFEN~ ~/ DEll-455599 3 2 9 92 --LO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STEPHANIE PRESBERY-HUNT -VS- DAVID AND SUSAN EICHELBERGER COURT OF COMMON PLEAS TERM, CASE NO: 2002-02847 NOTICE OF INT~a~T TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AN~ FOR DISCOVERY PURSUANT TO RULE 4009.21 RODNEY K. HOUGH, M.D. MEDICAL RECORDS TO: LISA J. MAUER, ESQ. MCS on behalf of JOSEPH F. MURPHY, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/17/200] CC: JOSEPH F. MURPHY, ESQ. - 16218-00105 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-245114 32 9 92 --CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STEPHANIE PRESBERY-HUNT VS. DAVID AND SUSAN EICHELBERGER File No. 2002-02847 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009-2~, TO: Custodian of Records for RODNEY K. HOUGH. 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 MGq Group_ Inc.. 1601 Market StreeL 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 fight 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: JOSEPH F. MURPHY. ESO. ADDRESS: 4200 CRIIMS MILL ROAD SUITE B HARRISBIJRG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Date: Seal of the Court Prothonotary/Clerk, Civil Divisk~,/ 32992-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: RODNEY K. HOUGH, M.D. P.O. BOX 100, REAR SUITE 101 NOBLE BLVD. CARLISLE, PA 17013 RE: 32992 STEPHANIE PRESBERY-HUNT Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 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, histo~ 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 iand including the present. Subject :~TEPHANIE PRESBERY-HUNT Social Security #: 176-54-2327 Date of Birth: 07-274958 SU10-469504 3 2 9 92 --LO 1 GRAHAM & MAUER, P.C. By: Ronald M. Graham, Esquire Attorney ID # 64483 The Commons at Valley Forge Suite 22, P.O. Box 987 Valley Forge, Pennsylvania 19482 (610~ 933-3333 STEPHANIE PRESBERY-HUNT Plaintiff VS. DAVID M. EICHELBERGER and SUSAN S. EICHELBERGER h/w t/a EICHELBERGER ENTERPRISES Defendants Attorney for Plaimiff IN THE COURT OF COlvlIvlON PLEAS CUMBERLAND COUNTY NO.: 2002-02847 PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of Ronald M. Graham, Esquire, as attorney for the Plaintiff Stephanie Presbury-Hunt. Respect ful'b~ Submitted, By: ~ GRAHAb~UER, P.e. GRAHAM & MAUER, p.C. By: Ronald M. Graham, Esqu/re Attorney ID # 64483 The Commons at Valley Forge Suite 22, P.O. Box 987 Valley Forge, Pennsylvania 19482 £61~ 933-3333 STEPHAN]E PRESBERY-HUNT : 1N THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY VS. NO.: 2002-02847 DAVID M. EICHELBERGER and SUSAN S. EICHELBERGER h/w t/a EICHELBERGER ENTERPRISES Defendants Attorney for Plaintiff CERTIFICATE OF SERVICE I, Ronald M. Graham, Esquire, attorney for Plaintiff, do hereby certify that on this ~ day of January, 2004 Entry of Ao~earanc~ was sero by First Class, US Mail to the following: Joseph Murphy, Esquire Marshall, Dennehey, Warner, Coleman & Goggin 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 GRAHAM & MAUER, p.c. By: Ronak Attorn, ?laintiff CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: STEPBANIE PRESBERY-HUNT C0URT OF COMMON PLEAS TERM, -VS- DAVID AND SUSAN EICHELEERGER CASE NO: 2002-02847 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOSEPH F. MURPHY, 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: 02/11/2004 ~Attorney for DEFENDANT DEll-472866 3 2 9 92 --LO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STEPHANIE PRESBERY-HUNT -VS- DAVID AND SUSAN EICHELBERGER COURT OF COMMON PLEAS TERM, CASE NO: 2002-02847 NOTICE OF I~x~a~T TO SERVE A SUBPOENA TO PRODUCE DOcuMENTS · m'~ilN6}S FOR DISCOVERY PURSUANT TO RIILR 4009.2] NANCY M. COHEN, ESQ. OTHER TO: LISA J. NAUER, ESQ. MCS on behalf of JOSEPH F. MURPHY, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/22/2004 CC: JOSEPH F. MURPHY, ESQ. - 16218-00105 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE NCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-253575 32 992 --CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STEPHANIE PRESBERY-HUNT VS. DAVID AND SUSAN EICHELBERGER File No. 2oo2-o2847 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for NANCY M. COHEN. ESQ, (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Groun. Inc.. 1601 Market Street. Suite 800. Philadelnhia. 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 thLngs 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: JOSEPH F. MURPHY. ESQ. ADDRESS: 4200 CRUMS MILL ROAD SUITE B HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: F£8 1 200t / Seal of the Court BY T~IE COURT: ./') othonotary/Clerk, Civil Division Deputy EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: NANCY M. COHEN, ESQ. 121 S. BROAD STREET SUITE 800 PHILADELPHIA, PA 19107 RE: 32992 STEPHANIE PRESBERY-HUNT ALL PLEADINGS, DISCOVERY RESPONSES, AND TESTIMONY OF PLANTIFF RELATIVE TO HER CLAIM ARISING OUT OF THE 11/14/2000 AUTO ACCIDENT. Subject: STEPHANIE PRESBERY-HUNT Social Security #: 176-54-2327 Date of Birth: 07-27-1958 SU10-484604 3 2 9 92 --LO 2 CERTIFICATE PREREQUISITR TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: STEPHANIE PRESBERY-HUNT COURT OF COMMON PLEAS TERM, -VS- DAVID AND SUSAN EICHELBERGER CASE NO: 2002-02847 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOSEPH F. MURPHY, 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: 03/09/2004 MC~B~ on be~lf ~f __ ~ tor ey for DEfErrAl+ / j3/ DEll-477894 3 2 9 92 --LO 3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STEPHANIE PRESBERY-HUNT -VS- DAVID AND SUSAN EICHELBERGER COURT OF COMMON PLEAS TERM, CASE NO: 2002-02847 NOTICE OF INTm~T TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS A~,~ '£nlNGS FOR DISCOVERy PURSUANT TO RULE 4009.21 CARLISLE HOUSING OPPORTUNITIES KEYSTONE RESIDENCE KEYSTONE SERVICES SYSTEM. INC. OTHER EMPLOYMENT EMPLOYMENT TO: RONALD M. GRAHAM, ESQUIRE MCS on behalf of JOSEPH F. MURPHY, 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: 02/18/2004 CC: JOSEPH F. MURPHY, ESQ. - 16218-00105 McS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1G01 MARKET STREET #000 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-256199 32 992--CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STEPHANIE PRESBERY-HUNT VS. DAVID AND SUSAN EICHELBERGER : File No. 2002-02847 .SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009 ~'~ TO: Custodian of Records for CARLISLE HOI ISING OPPORTUNITIKR (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 1910,3 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 fight 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: JOSEPH F. MURPHY. ESQ. ADDRESS: 4200 CRIJMS Mil J. ROAD SUITE. B HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant MAR 09 2004 Date: Ili Seal of the Court BY THE CO. URT: ~ Prothonotary/Clerk, Civil I)~n Deputy 32992-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE HOUSING OPPORTUNITIES 60 WEST PENN STREET CARLISLE, PA 17013 RE: 32992 STEPHANIE PRESBERY-HUNT (MUIR) Subject: STEPHANIE PRESBERY-HUNT (MUIR) DSocial .~.urity #: 176-54-2327 ate of Birth: 07-27-1958 SU10-488646 3 2 9 9 2 --LO 3 CERTIFICATE PREREQUISITE TO SERVICE 0F A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER 0F: STEPHANIE PRESBERY-HUNT COURT OF COMMON PLEAS TERM, -VS- DAVID AND SUSAN EICHELBERGER CASE NO: 2002-02847 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOSEPE F. MURPHY, 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: 03/09/2004 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT DEll-477895 3 2 9 92 --LO4 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN TEE MATTER OF: STEPHANIE PRESBERY-HUNT -VS- DAVID AND SUSAN EICHELBERGER COURT OF COMMON PLEAS TERM, CASE NO: 2002-02847 NOTICE OF IB'£~'T TO SERVI~ A Su~POI~IA TO PRODUCE DOuuMI~qTS AND THINGkq FOR DISCO~Y PUI~I~%NT TO R~,R 4009.21 CARLISLE HOUSING OPPORTUNITIES KEYSTONE RESIDENCE KEYSTONE SERVICES SYSTEN. INC. OTHER EMPLOYMENT EMPLOYMENT TO: RONALD N. GRAHAM, ESQUIRE MCS on behalf of JOSEPH F. MURPHY, 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: 02/18/2004 CC: JOSEPH F. MURPHY, ESQ. - 16218-00105 MOS on behalf of JOSEPH F. MURPHY; ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (2t5) 246-0900 DE02-256199 32 992--CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STEPHANIE PRESBERY-HUNT VS. DAVID AND SUSAN EICHELBERGER File No. 2002-02847 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.:Z~ TO: Custodian of Records for KEYSTONE RESIDENCE (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 MGq 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: JOSEPH F. MURPHY. ESO. ADDRESS: 4200 CRUMS MIIJ, ROAD SUITE B HARRISBURG_ PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant MAR 0 9 2004 Date: ~ Il. ~r~,5I Seal of the Court BY ~HE COtU. RT: /h Prothonotary/~"~rk, Civil Divi~'''~ Deputy-- ' C 32992-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: KEYSTONE RESIDENCE 940 E. PARK DRIVE SUITE 100 HARRISBURG, PA 17111 RE: 32992 STEPHANIE PRESBERY-HUNT (MUIR) Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all employment records, applications, fries, memoranda, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: sD~a~j.es Re.q~uested: up to and including the present. ect .STEPHANIE PRESBERY-HUNT (MUIR) Social Security #: 176-54-2327 Date of Birth: 07-27-1958 SUi0-488648 32 992--L04 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: STEPHANIE PRESBERY-HUNT COURT OF COMMON PLEAS TERM, -VS- DAVID AND SUSAN EICHELBERGER CASE NO: 2002-02847 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOSEPH F. MURPHY, ESQ. certifies that (1) A notice of intent to serve the subpoena wish 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. D~T~ 03/09/2004 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT DEll-477896 3 2 9 92 --LO 5 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STEPEANIE PRESBERY-RUNT -VS- DAVID AND SUSAN EICHELBERGER COURT 0F COMMON PLEAS TERM, CASE NO: 2002-02847 NOTICE OF I~'£~u~T TO SEI~VIE A SUBPOENA TO PRODUCE DOcu~FTS AND THIN6~ FOR DISCOVERY PUP~uAITT TO RULE 4009.21 CARLISLE HOUSING OPPORTUNITIES KEYSTONE RESIDENCE KEYSTONE SERVICES SYSTEM. INC. OTEER EMPLOYMENT EMPLOYMENT TO: RONALD N. GRAHAM, ESQUIRE NCS on behalf of JOSEPH F. MURPHY, 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: 02/18/2004 CC: JOSEPH P. MURPHY, ESQ. - 16218-00105 MOS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDAET Any questions reparding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET ~800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-256i99 32 992--CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STEPHANIE PRESBERY-HUNT VS. DAVID AND SUSAN EICHELBERGER File No. 2002-o2847 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009,22 TO: Custodian of Records for KEYSTONE SERVICES SYSTEM. INC. (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~g Group_ Inc.. 1601 Market Street. Suite 800_ Philadelphia. PA 191Q~ 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: JOSEPH F. MURPHY: ESO. ADDRESS: 4200 CRUMS MIl J. ROAD SUITE B HARRISBURG_ PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATFORNEY FOR: Defendant MAR 0 9 2O04 Seal of the Court BY/~E COURT: Prothonotary/Clerk, Civil Di'~ Deputy Date: 32992-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: KEYSTONE SERVICES SYSTEM. INC. 310 NORTH 2ND STREET HARRISBURG, PA 17101 RE: 32992 STEPHANIE PRESBERY-HUNT (MUIR) Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all employmem records, applications, fries, memoranda, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject :STEPHANIE PRESBERY-HUNT (MUIR) Social Security #: 176-54-2327 Date of Birth: 0%27-1958 SU10-488650 3 2 9 9 2 --LO 5 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.2:! IN THE MATTER OF: STEPHANIE PRESBERY-HUNT COURT OF COMMON PLEAS TERM, -VS- DAVID & SUSAN EICHELBERGER CASE NO: 2002-02847 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOSEPH F. MURPHY, 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: 04/05/2004 /~0SEP~ F. MURPHY, /~SQ~/ / ~/Atto~ney for DEFE~fDA~/ /' DEll-483444 3 2 9 9 2 --LO 6 COMMONWEALTH OF PENN'SYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STEPHANIE PRESBERY-HUNT -VS- DAVID & SUSAN EICHELBERGER COURT OF COMMON PLEAS TERM, CASE NO: 2002-02847 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSI3ANT TO RULE 4009.21 LEHOY KEARNEY, JR. D.0. ELWYN, INC. NEW DIRECTIONS SCHOOL SOUTHEAST SECURE TREATMENT BENSALEM YOUTH DEVELOPMENT CTR STEINBERG & GIRSH MEDICAL RECORDS EMPLOYMENT EMPLOYMENT EMPLOYMENT EMPLOYMENT OTHER TO: RONALD M. GRAHAM, ESQUIRE, PLAINTIFF COUNSEL MCS On behalf of JOSEPH F. MURPHY, 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: 03/15/2004 CC: JOSEPH F. MURPHY, ESQ. - 16218-00105 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-259199 3 2 9 92 --CO 1 COMMONWEALTH OF PFNNSYLVAN1A COUNTY OF CUMBERLAND STEPHANIE PRESBERY-HUNT VS. DAVID AND SUSAN EICHELBERGER File No. 2002-02847 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for LEROY KEARNEY. JR. D,O. (Name of Person or Entity) Within twenty (20) days aRer 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 th/ngs requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the fight 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: JOSEPH F. MURPHY, ESQ. ADDRESS: 4200 CRUMS MILL ROAD SUITE B HARRISBURG. PA 17110 TELEPHONE: (215'} 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Seal of the Court BY/THE COURT: D~y EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: LEROY KEARNEY, JR. D.O. 5944 WALNUT STREET PHILADELPHIA, PA 19139 RE: 32992 STEPHANIE PRESBERY-HUNT (MUIR) Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 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/ prescriptio.n re. cords, including any and all such items as may be stored in a computer datat)ase or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: ~ua, tes Requested: up to and including the present. bject: STEPHANIE PRESBERY-HUNT (MUIR) Social Security #: 176-54-2327 Date of Birth: 07-27-1958 SU10-493290 3 2 9 92--L0 6 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: STEPHANIE PRESBERY-HUNT COURT OF COMMON PLEAS TERM, -VS- DAVID & SUSAN EICHELBERGER CASE NO: 2002-02847 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOSEPH F. MURPHY, ESQ. certifies that (i) 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: 04/05/2004 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT DEll-483445 32 9 92--LO 7 COMMONWEALTH OF PENS[SYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STEPHANIE PRESBERY-HUNT -VS- DAVID & SUSAN EICHELBERGER COURT OF COMMON PLEAS TERM, CASE NO: 2002-02847 NOTICE OF Ii~TIf~-T ~O SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND ~i-NGS POll DISCOVERY PUltSUA/F~ TO RULE 4009.21 LEROY KEARNEY, JR. D.0. ELWYN, INC. NEW DIRECTIONS SCHOOL SOUTHEAST SECURE TREATMENT BENSALEM YOUTH DEVELOPMENT CTR STEINBERG & GIRSH MEDICAL RECORDS EMPLOYMENT EMPLOYMENT EMPLOYMENT EMPLOYMENT OTHER TO: RONALD M. GRAHAM, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of JOSEPH F. MURPHY, 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: 03/15/2004 CC: JOSEPH F. MURPHY, ESQ. - 16218-00105 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET ~800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-259199 32 9 92--CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STEPHANIE PRESBERY-HUNT VS. DAVID AND SUSAN EICHELBERGER File No. 2002-02847 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ELWYN. INC. (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 Grouts. 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 FOLLOWTNG PERSON: NAME: JOSEPH F. MURPHY, ESQ. ADDRESS: 4200 CRUMS MILL ROAD SUITE B HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: to, 0 o0.f Seal of the Court Pro~on~)Cl~rerk /~x c?Q~ -. 'ry ~rk,~2i~l Divisi~ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ELWYN, INC. 4040 MARKET STREET PHILADELPHIA, PA 19104 RE: 32992 STEPHANIE PRESBERY-HUNT (MUIR) Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 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 :STEPHANIE PRESBERY-HUNT (MUIR) Social Se.c. urity #: 176-54-2327 Date of B~rth: 07-27-1958 8U10-493292 3 2 9 9 2 --LO 7 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: STEPHANIE PRESBERY-HUNT COURT OF COMMON PLEAS TERM, -VS- DAVID & SUSAN EICHELBERGER CASE NO: 2002-02847 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOSEPH F. MURPHY, ESQ. certifies that (~) 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: 04/05/2004 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT DEll-483446 3 2 9 9 2 --LO 8 COMMONWEALTH OF PENSrSYLVANIA COUNTY OF CUMBS:RLAND IN THE MATTER OF: STEPHANIE PRESBERY-HUNT -VS- DAVID & SUSAN EICHELBERGER COURT OF COMMON PLEAS TERM, CASE NO: 2002-02847 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 LEROY KEARNEY, JR. D.0. ELWYN, INC. NEW DIRECTIONS SCHOOL SOUTHEAST SECURE TREATMENT BENSALEM YOUTH DEVELOPMENT CTR STEINBERG & GIRSH MEDICAL RECORDS EMPLOYMENT EMPLOYMENT EMPLOYMENT EMPLOYMENT OTHER T0: RONALD M. GRAHAM, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of JOSEPH F. MURPHY, ESQ. intends to serve a subpoena identical to the one that is attached to this notine. 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: 03/15/2004 CC: JOSEPH F. MURPHY, ESQ. - 16218-00105 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-259199 3 2 9 92 --CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STEPHAN1E PRESBERY-HUNT VS. DAVID AND SUSAN EICHELBERGER File No. 2002-02847 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.2?, TO: Custodian of Records for NEW DIRECTIONS SCHOOL (Name of Person or Entity) Within twenty (20) days atter service of this subpoena, you are ordered by 1he court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc.. 1601 Market StreeL 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 enmply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: JOSEPH F. MURPHY, ESQ. ADDRESS: 4200 CRUMS MILL ROAD SUITE B HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Seal of the Court BY THE COURT: ,~ .o Pr~o~onotary/Clerk{, C~il Divi~ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: NEW DIRECTIONS SCHOOL 919 S. 49TH STREET PHILADELPHIA, PA 19148 RE: 32992 STEPHANIE PRESBERY-HUNT (MUIR) Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 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: ~)ua~tes Requested: up to and including the present. bject: STEPHANIE PRESBERY-HUNT (MUIR) Social Security #: 176-54-2327 Date of Birth: 07-27-1958 SU10-493294 32992 --LO 8 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: STEPHANIE PRESBERY-HUNT COURT OF COMMON PLEAS TERM, -VS- DAVID & SUSAN EICHELBERGER CASE NO: 2002-02847 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOSEPH F. MURPHY, 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, includin9 the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been receJ, ved, 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: 04/05/2004 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT DEll-483447 3 2 9 9 2 --LO 9 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STEPHANIE PRESBERY-HUNT -VS- DAVID & SUSAN EICHELBERGER COURT OF COMMON PLEAS TERM, CASE NO: 2002-02847 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 LEROY KEARNEY, JR. D.O. ELWYN, INC. NEW DIRECTIONS SCHOOL SOUTHEAST SECURE TREATMENT BENSALEM YOUTH DEVELOPMENT CTR STEINBERG & GIRSH MEDICAL RECORDS EMPLOYMENT EMPLOYMENT EMPLOYMENT EMPLOYMENT OTHER TO: RONALD M. GRAHAM, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of JOSEPH F. MURPHY, 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: 03/15/2004 CC: JOSEPH F. MURPHY, ESQ. - 16218-00105 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-259199 32 9 92--CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STEPHANIE PRESBERY-HUNT VS. DAVID AND SUSAN EICHELBERGER File No. 2002-02847 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for SOUTHEAST SECURE TREATMENT (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 Grouv. Inc._ 1601 Market Street. Suite 800. Philadelnhia. 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: JOSEPH F. MURPHY, ESQ. ADDRESS: 4200 CRUMS MILL ROAD SUITE B HARRISBURG. PA 17110 TELEPHONE: (215'} 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: ~ {0~ O(OO¢ Seal of the Court Pro~onotm-y/Clerk{ Cixil Divi~, EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SOUTHEAST SECURE TREATMENT 1824 W. STRASBURG ROAD WEST CHESTER, PA 19380 RE: 32992 STEPHANIE PRESBERY-HUNT (MUIR) Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all employment records, applications, files, memoranda, compensation, time and attendance records, personnel records, payroll and sala~ 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 :STEPHANIE PRESBERY-HUNT(MUIR) Social Security #: 176-54-2327 Date of Birth: 07-27-1958 SU10-693296 3 2 992--L0 9 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: STEPHANIE PRESBERY-HUNT COURT OF COMMON PLEAS TERM, -VS- DAVID & SUSAN EICRELBERGER CASE NO: 2002-02847 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOSEPH F. MURPHY, 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: 04/05/2004 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT DEll-483448 3 2 9 92 --L10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STEPHANIE PRESBERY-HUNT -VS- DAVID & SUSAN EICHELBERGER COURT OF COMMON PLEAS TERM, CASE NO: 2002-02847 NOTICE OF INT~z4T TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCO%~KY PURSUANT TO RULE 4009.21 LEROY KEARNEY, JR. D.0. ELWYN, INC. NEW DIRECTIONS SCHOOL SOUTHEAST SECURE TREATMENT BENSALEM YOUTH DEVELOPMENT CTR STEINBERG & GIRSH MEDICAL RECORDS EMPLOYMENT EMPLOYMENT EMPLOYMENT EMPLOYMENT OTHER TO: RONALD M. GRAHAM, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of JOSEPH F. MURPHY, 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: 03/15/2004 CC: JOSEPH F. MURPHY, ESQ. - 16218-00105 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-259199 3 2 9 92 --CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STEPHAN1E PRESBERY-HUNT VS. DAVID AND SUSAN EICHELBERGER File No.. 2002-021347 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for BENSALEM YOUTH DEVELOPMENT 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 Sn'eet. Suite 800. Philadeh~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: JOSEPH F. MURPHY. ESO. ADDRESS: 4200 CRUMS MILL ROAD SUITE 13 HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Seal of the Court Pr<~thonotary/Clqrk,t Civil Divig/~n R9OOg-lfl EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: BENSALEM YOUTH DEVELOPMENT CTR 3701 OLD TREVOSE ROAD BENSALEM, PA 19020 RE: 32992 STEPHANIE PRESBERY-HUNT (MUIR) Please call for prior approval for fees in excess of $100.00 for ]hospitals, $50.00 for all other providers. Any and all employment records, applications, files, memoranda, compensation, time and attendance records, personnel records, payroll and salm'y 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: STEPHANIE PRESBERY-HUNT (MUIR) Social Security #: 176-54-2327 Date of Birth: 07-27-1958 SU10-493298 32 992--L10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: STEPHANIE PRESBERY-HUNT COURT OF COMMON PLEAS TERM, -VS- DAVID & SUSAN EICHELBERGER CASE NO: 2002-02847 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOSEPH F. MURPHY, ESQ. certifies that 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: 04/05/2004 MCS on. behalf of JOSEP~[ F. MURPHY, ESQ. Attorney for DEFENDANT DEll-483449 3 2 9 92 --Lll COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STEPHANIE PRESBERY-HUNT -VS- DAVID & SUSAN EICHELBERGER COURT OF COMMON PLEAS TERM, CASE NO: 2002-02847 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOcuMENTS AND · ~4TNGS FOR DISCOI~K¥ PURSUANT TO RULE 4009.21 LEROY KEARNEY, JR. D.0. ELWYN, INC. NEW DIRECTIONS SCHOOL SOUTHEAST SECURE TREATMENT BENSALEM YOUTH DEVELOPMENT CTR STEINBERG & GIRSH MEDICAL RECORDS EMPLOYMENT EMPLOYMENT EMPLOYMENT EMPLOYMENT OTHER TO: RONALD M. GRAHAM, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of JOSEPH F. MURPHY, 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: 03/15/2004 CC: JOSEPH F. MURPHY, ESQ. - 16218-00105 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-259199 32 9 92--CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STEPHANIE PRESBERY-HUNT VS. DAVID AND SUSAN EICHELBERGER File No. _ 2002-02847 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for STEINBERG & GIRSH (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 Thc MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelnhia. 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: JOSEPH F. MURPHY, ESQ. ADDRESS: 4200 CRLrMS MILL ROAD SUITE B HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY THE COLTRT: /'~ ,o Pro. thonotary/Clerk~t CiVil Divisi~l ATFACHMENT TO SUBPOENA Directed to: Law Firm of Steinberg & Girsh 1 Liberty Place, Suite 2880 1650 Market Street Philadelphia, PA 19103-7301 You are requested to provide copies of all pleadings, discovery served upon Plaintiff and answers thereto, and any and all deposition transcripts, as well as correspondence/invoices from any and all court reporters who recorded testimony involved in Plaintiff Stephanie Presbery-Hunt (Muir)'s civil action. EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: STEINBERG & GIRSH 1650 MARKET STREET SUITE 2880 PHILADELPHIA, PA 19103 RE: 32992 STEPHANIE PRESBERY-HUNT (MUIR) *****SEE ATTACHED***** Subject: STEPHANIE PRESBERY-HUNT (MUIR) Social Security #: 176-54-2327 Date of Birth: 07-27-1958 SU10-493300 3 2 9 9 2 --L1 1 STEPHANIE PRESBERY-HUNT, Plaintiff Vo DAVID M. EICHELBERGER, and SUSAN S. EICHELBERGER h/w t/a EICHELBERGER ENTERPRISES, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 2002-02847 PRAECIPE FOR DISCONTINUANCE TO: Prothonotary Please mark the above referenced matter settled, ended and discontinued with prejudice. DATE: 7 ~.'~__ ~)C~ BY: Rona~4~l~:~, Esquire GRAltI~ & MAUER, P.C. The Commons at Valley Forge Suite 22, P.O. Box 987 Valley Forge, PA 19482 Attorney for Plaintioff MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN BY: Michael D. Pipa, Esquire Identification No. 53624 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3500 STEPHANIE PRESBERY-HUNT, Plaintiff DAVID M. EICHELBERGER, and SUSAN S. EICHELBERGER h/w t/a EICHELBERGER ENTERPRISES, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 2002-02847 CERTIFICATION OF SERVICE I hereby certify that I have served upon all parties listed below a tree and correct copy of Praecipe for Discominuance in the above-captioned matter this date by regular mail. Ronald M. Graham, Esquire GRAHAM & MAUER, P.C. The Commons at Valley Forge Suite 22, P.O. Box 987 Valley Forge, PA 19482 MARSHALL, DENNEHE¥, WARNER COLEMAN AND GOGGIN MICHAEL D. PIP~,, Attorneys for Defendan,t 105_A~LIAB~I4EP~SLPGl1654041TNMl162181O0105