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HomeMy WebLinkAbout06-7178 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. [!!)(e ? L" CIVIL ACTION - LAW THERESE ROGERS 869-D Rhuehaus Lane Hummelstown, PA 17036 EYAL DIOR 1091 Trefalgar Street Teaneck, NJ 07666 VERSAMED MEDICAL SYSTEMS, INC. individually and t/d/b/a VERSAMED, INC. 365 West Passaic Street Rochelle Park, NJ 07662 2 Blue Hill Plaza Box 1512 Pearl River, New York 10965 Plaintiff(s)& Address(es) Defendant(s) Address(es) JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Kindly issue a Writ of Summons against Defendants Eyal Dior and VersaMed Medical Systems, Inc. individually and t/d/b/a Versamed, Inc. The Writ of Summons should be served upon the Defendants as indicated in the Sheriff's directions. Date: December 14, 2006 METZ;rancis R S SS & ERB, P.C. By J. Laffe , IV, E uire I.D. No. 84009 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiff 364563-1 a ?' c -? C7_v tL? ov-) t ti. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. N. -711P l : t u h ?/L? CIVIL ACTION - LAW JURY TRIAL DEMANDED WRIT OF SUMMONS METZGER, WICKERSHAM, P.C. By: Francis J. Lafferty, IV, Esquire Attorney I.D. No. 84009 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Therese Rogers THERESE ROGERS, Plaintiff vs. EYAL DIOR and VERSAMED MEDICAL SYSTEMS, INC., individually and t/d/b/a VERSAMED, INC. Defendants TO: Eyal Dior 1091 Trefalgar Street Teaneck, NJ 07666 You are hereby notified that Plaintiff Therese Rogers has commenced an action against you. Dated:G 364563-1 METZGER, WICKERSHAM, P.C. By: Francis J. Lafferty, IV, Esquire Attorney I.D. No. 84009 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 THERESE ROGERS, Plaintiff Attorneys for Plaintiff Therese Rogers IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. ?CS !I LlJ C`u6L CIVIL ACTION - LAW EYAL DIOR and VERSAMED MEDICAL SYSTEMS, INC., individually and t/d/b/a VERSAMED, INC. Defendants JURY TRIAL DEMANDED WRIT OF SUMMONS TO: VersaMed Medical Systems, Inc., individually and t/d/b/a VersaMed, Inc. 365 West Passaic Street Rochelle Park, NJ 07662 2 Blue Hill Plaza Box 1512 Pearl River, NY 10965 You are hereby notified that Plaintiff Therese Rogers has commenced an action against you. Dated: a/-'1,471& ?'P- ? Prothonotary 364563-/ METZGER, WICKERSHAM, P.C. By: Francis J. Lafferty, IV, Esquire Attorney I.D. No. 84009 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Therese Rogers THERESE ROGERS, vs. EYAL DIOR and VERSAMED : MEDICAL SYSTEMS, INC., individually and t/d/b/a VERSAMED, INC. Defendants NO. Cam- -7r7P CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO REISSUE WRIT OF SUMMONS TO THE PROTHONOTARY: Please reissue the Writ of Summons that was issued in the above-captioned action on December 19, 2006. METZGER, WIC RS , KNAUSS &ERB, P.C. By Date: January 16, 2007 IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA I.D. No. 84009 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiff 364563-2 ? a a? ? c? -n -c? is t ``` ?^ ?? c" .?7 ?=?? ` ?= :'ate (i??#?? ? ??? ?qqs a x- J ?'t Y?l _. tea"' ?'. .r^ 'i .?` ? ?``?1C. s THERESE ROGERS, Plaintiff VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-7178-Civil Term EYAL DIOR and VERSAMED MEDICAL SYSTEMS, INC., Individually And t/d/b/a VERSAMED, INC., CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendants, EYAL DIOR and VERSAMED MEDICAL SYSEMS, INC., with regard to the above-captioned matter. Respectfully submitted, Date: NEALON GLOVER & PERRY By: Jn i enley Allen, Esquire I. D. N . 84311 2411 orth Front Street Har ' urg, PA 17110 717/232-9900 CERTIFICATE OF SERVICE .?A AND NOW, this day of January, 2007, 1 hereby certify that I have served the foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Francis J. Lafferty, IV, Esquire METZGER, WICKERSHAM, P.C. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 Henley Allen, Esquire r-? qj) r . .. rTA ? ... THERESE ROGERS, Plaintiff VS. EYAL DIOR and VERSAMED MEDICAL SYSTEMS, INC., Individually And t/d/b/a VERSAMED, INC., Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-7178-Civil Term CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please issue a Rule upon the Plaintiff to file a Complaint within twenty (20) days or suffer a judgment of non pros. Respectfully submitted, Date: \0 NEALON GOVER & PERRY By: - J. X1 J i Henley Allen, ire I. o. 84311 2 11 North Front Street Ha ' burg, PA 17110 717/232-9900 RULE TO THE PLAINTIFF: A Rule is hereby issued upon you to file a Complaint within twenty (20) days of service of this Rule or suffer a judgment of non pros. DATED: k 66 Ila A , I Pr honotar I ? CERTIFICATE OF SERVICE AND NOW, this ? day of January, 2007, 1 hereby certify that I have served the foregoing PRAECIPE FOR RULE TO FILE COMPLAINT on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Francis J. Lafferty, IV, Esquire METZGER, WICKERSHAM, P.C. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 Tt METZGER, WICKERSHAM, P.C. By: Francis J. Lafferty, IV, Esquire Attorney I.D. No. 84009 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 THERESE ROGERS, Plaintiff VS. EYAL DIOR and VERSAMED MEDICAL SYSTEMS, INC., individually and t/d/b/a VERSAMED, INC. Defendants TO: Defendants Attorneys for Plaintiff Therese Rogers IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-7178 CIVIL ACTION - LAW JURY TRIAL DEMANDED YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within Twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiffs. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (800) 990-9108 338820-1 AVISO USTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion dentro de veinte (20) dias a partir de la fecha en que recibio la demanda y el aviso. Usted debe presentar comparecencia esrita en persona o po abogado y presentar en la Corte por escrito sus defensas o sus objeciones a las demandas en su contra. Se le avisa que si no se defiende, el caso puede proceder sin usted y la Corte puede decidir en su contra sin mas aviso o notificacion por cualquier dinero reclamado en la demanda o por cualquier dinero reclamado en la demanda o po cualquier otra queja o compensacion reclamados por el Demandante. USTED PUEDE PERDER DINERO, O PROPIEDADES U OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI USTED NO TIENE O NO CONOCE UN ABODAGO, VAYA O LLAME A LA OFICINA EN LA DIRECCION ESCRITA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Lawyer Referral Service Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (800) 990-9108 338820-1 METZGER, WICKERSHAM, P.C. By: Francis J. Lafferty, IV, Esquire Attorney I.D. No. 84009 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 THERESE ROGERS, vs. Plaintiff EYAL DIOR and VERSAMED MEDICAL SYSTEMS, INC., individually and t/d/b/a VERSAMED, INC. Defendants Attorneys for Plaintiff Therese Rogers IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-7178 CIVIL ACTION - LAW JURY TRIAL DEMANDED COMPLAINT AND NOW, comes the Plaintiff, Therese Rogers, by and through her attorneys, Metzger, Wickersham, Knauss & Erb, and respectfully represents the following: FACTS APPLICABLE TO ALL COUNTS 1. Plaintiff Therese Rogers is an adult individual who resides at 869-D Rhuehaus Lane, Hummelstown, Dauphin County, Pennsylvania. 2. Defendant Eyal Dior is an adult individual whose last known address is 1091 Trefalgar Street, Teaneck, New Jersey. 3. Defendant Versamed Medical Systems, Inc. is a Delaware corporation with a principal place of business at 2 Blue Hill Plaza, Box 1512, Pearl River, New York, 10965 and also trades and does business as Versamed, Inc. 338820-1 4. The facts and circumstances hereinafter set forth occurred on January 5, 2005 at or about 12:30 P.M. at the intersection of Central Boulevard and Trindle Road, Hampden Township, Cumberland County, Pennsylvania. 5. At the aforesaid time and place, Plaintiff Therese Rodgers was operating a 2000 Saturn bearing Pennsylvania Registration Plate No. EKF5130. 6. At the aforesaid time and place, Defendants, either individually and/or jointly and severally, owned, maintained, controlled and/or leased a 2003 Ford Winstar bearing New Jersey Plate No. PDL78H. 7. At the aforesaid time and place, Plaintiff Therese Rogers was operating the 2000 Saturn and was stopped at a stop sign on Central Boulevard and Trindle Road, Hampden Township, Cumberland County, Pennsylvania. 8. At the aforesaid time and place, Defendant Eyal Dior was operating the 2003 Ford Winstar with the permission of Defendant Versamed Medical Systems, Inc., t/d/b/a Versamed, Inc. and within the scope of his employment with Defendant Versamed Medical Systems, Inc., t/d/b/a Versamed, Inc. 9. At the aforesaid time and place, the vehicle operated by Defendant Eyal Dior was also traveling on Central Boulevard approaching the intersection of Trindle Road, Hampden Township, Cumberland County, directly behind the vehicle operated by Plaintiff. 10. At the aforesaid time and date, Defendant Eyal Dior failed to stop and struck the rear of Plaintiff's vehicle. 338820-1 COUNTI PLAINTIFF THERESE ROGERS V. DEFENDANT EYAL DIOR 11. Paragraphs 1 through 10 of Plaintiffs' Complaint are incorporated herein by reference as if fully set forth. 12. Defendant owed a duty to Plaintiff Therese Rogers and other lawful users of the roadways in the Commonwealth of Pennsylvania to operate the vehicle he was driving in such a way as not to cause harm or damage to said other persons and to the Plaintiff in particular. 13. The aforesaid collision was the direct and proximate result of the negligence of the Defendant Eyal Dior, either individually and/or jointly and severally, in operating the 2003 Ford Winstar in a careless, reckless and negligent manner as follows: (a) Failing to observe Plaintiff's vehicle on the roadway; (b) Following too closely to Plaintiff's vehicle in violation of 75 Pa.C.S.A. §3310 and applicable law; (c) Failing to slow or stop the vehicle he was operating so as to avoid a rear-end collision; (d) Failing to maintain and stop the vehicle he was operating within the assured clear distance ahead in violation of 75 Pa.C.S.A. §3361 and applicable law; (e) Failing to apply the brakes to the vehicle he was operating or take other evasive action to avoid the collision with the rear of Plaintiffs' vehicle; (f) Failing to maintain adequate control of the vehicle he was operating in order to avoid a collision; (g) Failing to give warning to Plaintiff Therese Rogers of his impending collision with Plaintiff's vehicle; 338810-I (h) Operating his vehicle in careless disregard for the safety of persons and/or property in violation of 75 Pa.C.S.A. §3714 and applicable law; (i) Failing to keep his vehicle under proper and adequate control so as not to expose other users to an unreasonable risk of harm; (j) Operating his vehicle too fast for the conditions existing at the aforesaid time and place in violation of 75 Pa.C.S.A. §3361 and applicable law; (k) Failing to keep alert and maintain a proper lookout for the presence of other motor vehicles on the streets and highways; (1) Exceeding the applicable maximum speed limit in violation of 75 Pa.C.S.A. §3362 and applicable law; (m) Operating his vehicle in reckless disregard in violation of 75 Pa. C.S.A. §3736 and applicable law; (n) In failing to yield the right-of-way to traffic already upon the highway; (o) In operating the vehicle so as to create a dangerous situation for other vehicles on the roadway; (p) Otherwise operating his vehicle at an unsafe speed; (q) Not keeping his eyes on the roadway; (r) Not keeping alert; and (s) Colliding into Plaintiff's vehicle. 14. As a direct and proximate result of the collision and the negligent, careless and reckless conduct of Defendant Dior, either individually and/or jointly and severally, Plaintiff, Therese Rogers, sustained and in the future may sustain, serious and debilitating injuries, some of which are or may be permanent, an aggravation and/or exacerbation of pre-existing conditions, and which include, but are not limited to, the following: 338820-1 (a) Severe strain and sprain of the muscles, tendons, ligaments and other soft tissues at or about the cervical spine; (b) Severe strain and sprain of the muscles, tendons, ligaments and other soft tissues at or about the thoracic spine; (c) Severe strain and sprain of the muscles, tendons, ligaments and other soft tissues at or about the lumbar spine; (d) Cervicalgia; and (e) Bulging discs. 15. As a direct and proximate result of the aforesaid collision, negligence, carelessness and recklessness of Defendant Dior, either individually and/or jointly and severally, Plaintiff, Therese Rogers, has undergone and in the future will undergo physical pain, mental anguish, discomfort, inconvenience, distress, embarrassment and humiliation, past, present and future loss of her ability to enjoy the pleasures of life and limitations in her pursuit of daily activities all to her great loss and detriment. 16. As a direct and proximate result of the aforesaid collision, negligence, carelessness and recklessness of Defendant Dior, either individually and/or jointly and severally, Plaintiff, Therese Rogers, has and/or may in the future incur expenses for medical treatment and rehabilitation for which damages are claimed. 17. As a direct and proximate result of the aforesaid collision, negligence, carelessness and recklessness of Defendant Dior, either individually and/or jointly and severally, Plaintiff, Therese Rogers, has suffered and will continue to suffer a loss of earnings for which damages are claimed. 18. Asa direct and proximate result of the aforesaid collision, negligence, 338820-1 carelessness and recklessness of Defendant Dior, either individually and/or jointly and severally, Plaintiff, Therese Rogers, has and/or may in the future incur a loss of earning capacity, loss of household services and other economic damages for which damages are claimed. 19. As a direct and proximate result of the aforesaid collision and the negligence, carelessness and recklessness of Defendant Dior, either individually and/or jointly and severally, Plaintiff Therese Rogers sustained incidental costs and losses to include, but not limited to, past and future medication costs and medical appliances. WHEREFORE, Plaintiff Therese Rogers demands judgment in her favor and against the Defendant Eyal Dior, either individually and/or jointly and severally, for the aforesaid damages in an amount in excess of the limits of compulsory arbitration in Cumberland County, Pennsylvania plus interest and/or damages for delay and costs for prosecution. COUNT II PLAINTIFF THERESE ROGERS V. DEFENDANT VERSAMED MEDICAL SYSTEMS, INC., INDIVIDUALLY AND T/DB/A VERSAMED, INC. 20. Paragraphs 1 through 19 hereof are incorporated herein by reference as if fully set forth. 21. At all times relevant hereto, Defendant Eyal Dior was an employee, servant, workman and/or agent of Defendant Versamed Medical Systems, Inc., t/d/b/a Versamed, Inc., and was acting within the scope of his employment with Defendant Versamed Medical Systems, Inc., t/d/b/a Versamed, Inc., and Defendant Versamed Medical Systems, Inc., t/d/b/a Versamed, Inc., either individually and/or jointly and severally is vicariously liable for his acts, 338820-1 commissions or omissions as though it performed the acts, commission or omissions itself and is subject to the doctrine of respondeat superior. 22. In addition to being vicariously liable for the acts of its employee, servant, workman and/or agent, Defendant Versamed Medical Systems, Inc., t/d/b/a Versamed, Inc. was also negligent, careless and reckless as follows: a. Failing to properly train its employees, servants, workmen and/or agents in the operation of its vehicles; b. Failing to provide its employees, servants, workmen and/or agents with proper directions before allowing them to operate its vehicles; c. Failing to ensure that its employees, servants, workmen and/or agents are familiar with the roadways and route of travel before allowing them to operate its vehicles; d. Failing to properly supervise or control its employees, servants, workmen and/or agents while they are operating its vehicles; e. Hiring and/or retaining employees, servants, workmen and/or agents who may be unfit or incompetent to operate its vehicles; f. Failing to have in place proper procedures, rules, regulations, protocols or safety measures to ensure that other motorists are not endangered by the operation of its vehicles by its employees, servants, workmen and/or agents; g. Sending out its employee, servant, workman and/or agent for an errand or job without proper instructions, directions and guidance; and h. Failing to take proper precautions to protect Plaintiff and other lawful users of the roadway from the negligent, careless and reckless actions of its employees, servants, workmen and/or agents. 23. As a result of the aforesaid negligence, carelessness, and/or recklessness of Defendant Versamed Medical Systems, Inc. and Versamed, Inc., either individually and/or jointly and severally, Plaintiff sustained the aforesaid damages. 338820-1 WHEREFORE, Plaintiff Therese Rogers demands judgment in her favor and against the Defendant Versamed Medical Systems, Inc., t/d/b/a Versamed, Inc., either individually and/or jointly and severally, for the aforesaid damages in an amount in excess of the limits of compulsory arbitration in Cumberland County, Pennsylvania plus interest and/or damages for delay and costs for prosecution. Respectfully submitted, METZGER, WIC AM,1 By: Dated: ?? d 7 F cis J. Laf y;IV, rqu Attorney I. No. 84009 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiff S & ERB, P.C. 338820-1 VERIFICATION The undersigned hereby certifies that he is the attorney for the Plaintiff, and that the facts in the foregoing Complaint are true and correct to the best of his knowledge, information, and belief, and that said matters relating to the Plaintiff, are as known to the undersigned as to the client, Plaintiff, said knowledge being based upon information contained in the attorney's file in this matter, and further states that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities. Dated: 338820-1 CERTIFICATE OF SERVICE I, Sandra K. Spade, an employee of Metzger, Wickersham, Knauss and Erb, P.C., do hereby certify that on the date set forth below, I did serve a true and correct copy of the foregoing document upon the following person(s) at the following address(es) indicated below by sending same in the United States mail, postage prepaid, as follows: Jenni Henley Allen, Esquire NEALON GOVER & PERRY 2411 North Front Street Harrisburg, PA 17110 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By A:) Sandra K. S e Dated: 338820-/ N C) c. -n -- :. -r, r cm -n ? r -V r- -T j =1C C cl C,7 "i METZGER, WICKERSHAM, P.C. By: Francis J. Lafferty, IV, Esquire Attorney I.D. No. 84009 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Therese Rogers THERESE ROGERS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 06-7178 CIVIL ACTION - LAW EYAL DIOR and VERSAMED MEDICAL SYSTEMS, INC., individually and t/d/b/a VERSAMED, INC. Defendants JURY TRIAL DEMANDED PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Please substitute the attached Verification for the Verification of counsel that was attached to Plaintiff's Complaint filed in the above-captioned action on February 20, 2007. Dated: 3( /ft//a 7 METZGER, WL.ICSRSHAN1,,KNAUSS & ERB, P.C. By: Froicis J. Lafferty, IV, Esquire Attorney I.D. No. 84009 P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff 373670-1 VERIFICATION I, Therese Rogers, hereby certify that the following is correct: The facts set forth in-the foregoing Complaint are based upon information which I have furnished to counsel, as well as upon information which has been gathered by counsel and/or others acting on my behalf in this matter. The language of the Complaint is that of counsel and not my own. I have read the Complaint, and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the content of the Complaint is that of counsel, I have relied upon such counsel in making this Verification. I hereby acknowledge that the facts set forth in the aforesaid Complaint are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities. Dated: 1J - 12 o7 plxl Therese Rogers 338820-1 CERTIFICATE OF SERVICE I, Francis J. Lafferty, IV, Esquire, an attorney with the law firm of Metzger, Wickersham, Knauss and Erb, P.C., do hereby certify that on the date set forth below, I did serve a true and correct copy of the foregoing document upon the following person(s) at the following address(es) indicated below by sending same in the United States mail, postage prepaid, as follows: Jenni Henley Allen, Esquire NEALON GOVER & PERRY 2411 North Front Street Harrisburg, PA 17110 Attorneys for Defendants METZGER, WKNAUSS & ERB, P.C. By rancis J. Lafferty, IV Dated: 51f?l 7 373670-1 C3 -? p g rt!r; ?' al ?r N S rJJ rn G?7 TJ METZGER, WICKERSHAM, P.C. By: Francis J. Lafferty, IV, Esquire Attorney I.D. No. 84009 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Therese Rogers THERESE ROGERS, Plaintiff VS. EYAL DIOR and VERSAMED MEDICAL SYSTEMS, INC., individually and t/d/b/a VERSAMED, INC. Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-7178 CIVIL ACTION - LAW JURY TRIAL DEMANDED ACCEPTANCE OF SERVICE I accept service of the Complaint on behalf of Defendant Eyal Dior, and certify that I am authorized to do so. & PERRY By: ____L' Date:/ '2007 J i Henley Allen, Esquire 4 North Front Street Harrisburg, PA 17110 (717) 232-9900 373677-I CHI, Z -at 17 SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE NO: 2006-07178 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROGERS THERESE VS. DIOR EYAL ET AL R. Thomas Kline , Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT DIOR EYAL by United States Certified Mail postage prepaid, on the 20th day of December ,2006 at 0000:00 HOURS, at 1091 TREFALGAR STREET TEANECK, NJ 07666 a true and attested copy of the attached WRIT OF SUMMONS Together with The returned receipt card was signed by ENVELOPE WAS RETURNED 00/00/0000 . Additional Comments: on Sheriff's Costs: Docketing 18.00 Service 4.64 Affidavit .00 Surcharge 10.00 .00 So answers: lR. Thomas Kl' e Sheriff of Cumberland County 111aJo 7 ()p, ? 32.64 Paid by HENNESSY & WALKER Sworn and Subscribed to before me this day of , on 01/10/2007 A. D. t SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE NO: 2006-07178 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROGERS THERESE VS. DIOR EYAL ET AL R. Thomas Kline , Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT VERSAMED MEDICAL SYSTEMS INC by United States Certified Mail postage prepaid, on the 20th day of December 2006 at 0000:00 HOURS, at 365 WEST PASSAIC STREET ROCHELLE PARK, NJ 07662 a true and attested copy of the attached WRIT OF SUMMONS Together with The returned receipt card was signed by ENVELOPE WAS RETURNED on 00/00/0000 . Additional Comments: Sheriff's Costs: So an ors - Docketing 6.00 -- Service 4.64 R. Thomas Kline Affidavit .00 Sheriff of Cumberland County Surcharge 10.00 .00 20.64 V I1;,410 7 Paid by METZGER WICKERSHAM on 01/10/2007 Sworn and Subscribed to before me this day of A.D. t SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE NO: 2006-07178 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROGERS THERESE VS. DIOR EYAL ET AL R. Thomas Kline , Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT VERSAMED MEDICAL SYSTEMS INC T/D/B/A VERSAMED INC by United States Certified Mail postage prepaid, on the 20th day of December 2006 at 0000:00 HOURS, at 365 WEST PASSAIC STREET ROCHELLE PARK, NJ 07662 and attested copy of the attached WRIT OF SUMMONS with a true Together receipt card was signed by ENVELOPE WAS RETURNED 00/00/0000 . Additional Comments: Sheriff's Costs: Docketing 6.00 Service 4.64 Affidavit .00 Surcharge 10.00 00 1lz 4'1®? 20.64 So an rs : - ??- R. Thomas Kline Sheriff of Cumberland County Paid by METZGER WICKERSHAM Sworn and Subscribed to before me this day of , The returned on on 01/10/2007 . A. D. SHERIFF'S RETURN - U.S. CERTIFIED MAIL ? rCASE NO: 2006-07178 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROGERS THERESE VS. DIOR EYAL ET AL R. Thomas Kline , Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT VERSAMED MEDICAL SYSTEMS INC _, by United States Certified Mail postage prepaid, on the 20th day of December ,2006 at 0000:00 HOURS, at 2 BLUE HILL PLAZA BOX 1512 PEARL RIVER, NY 10965 and attested copy of the attached WRIT OF SUMMONS with receipt card was signed by P POPE 12/27/2006 . Additional Comments: a true Together The returned on Sheriff's Costs: So ans Docketing 6.00 Service 4.64 R. Thomas Kline Affidavit .00 Sheriff of Cumberland County Surcharge 10.00 .00 20.64 Paid by METZGER WICKERSHAM on 01/10/2007 Sworn and Subscribed to before me this day of A.D. SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE NO: 2006-07178 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROGERS THERESE VS. DIOR EYAL ET AL R. Thomas Kline , Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT VERSAMED MEDICAL SYSTEMS INC T/D/B/A VERSAMED INC by United States Certified Mail postage prepaid, on the 20th day of December ,2006 at 0000:00 HOURS, at 2 BLUE HILL PLAZA BOX 1512 PEARL RIVER, NY 10965 and attested copy of the attached WRIT OF SUMMONS with a true . Together _ I The returned receipt card was signed by P POPE on 12/27/2006 . Additional Comments: Sheriff's Costs: So ans ?,r Docketing 6.00 Service 4.64 R. 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Z n .? d ?C] 'th LO ..f3 op 67 ro ? N a N Y ?' co r-zl p r 41 SO Q Ln Lt. C3 cV??'?4 N $ ? "y .D r r ? ? ??0.4 rG ?j u w? ? aQ fir- G c?i> ao?'•sAO u fo ' N M ? ? o NC ? ??m°rowO o W ~ cn (DD C m ., p N ?v x CA m m it a2C:03 (D =4 (D a 00 to f i N o y $ g a;+ 03 03 H n CL iv ?i m map. ° re fu C3 ~ N H N mw0Cm • w C3 o ?D `? w o Ma y p N Cl. ?a? 300 0 m ' ? ua a m m o -0 C3 O? ? Sa 0 P X' ? ? ? p 00 ? 3 3 o f"'' o ? cV (? n t . m 1CL W U W O 0- U) W 4 F W H Z • O N_ L_ ?t a IV 'zy c co vi N Q? co N ca G O T C Q t?7f c4 0.N i 'O 2 d Q a. Q c!? u.. u. W UJ D LLA Q r C7C W O t!? C.7 cc, ? W 4 •9 Cl) N b CC1 O h N r C , O D p '0 n 0 o 3 i >C p rt ITJ 6, H --- cn ci 0n-?3 m ?p,?Ag o?co WA ? Ln N (p h, a (D=rCD Xm 0 0S m s C3 D(a . C) EL 5? W -n (D =;; CD m Ln Fj ?p V? o y &Z' w p1 o m m 53 aON -RT.W N ru (p N Q+F? a m w N 0 w CDQI to F Nz 0 C O H to 3 y r o as vi D C] C] rn n m ?' ....? aN SO?0O C) ni O O wO m F: 3 o H . m m ? m L 0 m m (D a -' E 0 r0 C] c ? ? A to ? W x w ? ?) < a zz?:- co m m O ?00 ?a ? 0 v CL C p a o `L W V N N f N CL. N 'u. CL a p.r. t.9% C' U W U? m it t: • N a N c co N N Q? i .d T3 co aS c co G 0 7+ .Q N co N a. a? c Cf) • i Q 4L LJ.. d w us 0 2 Q us C:) in co G;l d W Q ?z v ? r:? THERESE ROGERS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 06-7178-Civil Term EYAL DIOR and VERSAMED MEDICAL SYSTEMS, INC., Individually And t/d/b/a VERSAMED, INC., CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Therese Rogers C/o Francis J. Lafferty, IV, Esquire METZGER, WICKERSHAM, P.C. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 YOU ARE HEREBY NOTIFIED that the Answer to Complaint set forth herein contains averments against you to which you are required to respond within twenty (20) days after service thereof. Failure by you to do so may constitute an admission. Respectfully submitted, Date: .5" oj0 b1 NEALO&GO R& PERRY By: Matthew R. Gover, Esquire I.D. No. 47593 2411 North Front Street Harrisburg, PA 17110 717/232-9900 THERESE ROGERS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 06-7178-Civil Term EYAL DIOR and VERSAMED MEDICAL SYSTEMS, INC., Individually And t/d/b/a VERSAMED, INC., CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED ANSWER TO COMPLAINT WITH NEW MATTER 1. Admitted based upon information and belief. 2. Admitted based upon information and belief. 3. Admitted based upon information and belief. 4. Admitted based upon information and belief. 5. Admitted based upon information and belief. 6. Admitted based upon information and belief. 7. Denied pursuant to Pa. R.C.P. 1029(e). 8. Admitted based upon information and belief. 9. Admitted based upon information and belief. 10. Denied pursuant to Pa. R.C.P. 1029(e). COUNTI PLAINTIFF THERESE ROGERS V. DEFENDANT EYAL DIOR 11. No responsive pleading required. 12. Denied pursuant to Pa. R.C.P. 1029(e). 13. Denied pursuant to Pa. R.C.P. 1029(e). 14. Denied pursuant to Pa. R.C.P. 1029(e). 15. Denied pursuant to Pa. R.C.P. 1029(e). 16. Denied pursuant to Pa. R.C.P. 1029(e). 17. Denied pursuant to Pa. R.C.P. 1029(e). 18. Denied pursuant to Pa. R.C.P. 1029(e). 19. Denied pursuant to Pa. R.C.P. 1029(e). WHEREFORE, the Defendant respectfully requests this Honorable Court to dismiss the Plaintiff's Complaint with costs to be paid by the Plaintiff. COUNT II PLAINTIFF THERESE ROGERS V. DEFENDANT VERSAMED MEDICAL SYSTEMS, INC., INDIVIDUALLY AND T/D/B/A VERSAMED, INC 20. No responsive pleading required. 21. Admitted. 22. Denied pursuant to Pa. R.C.P. 1029(e). 23. Denied pursuant to Pa. R.C.P. 1029(e). WHEREFORE, the Defendant respectfully requests this Honorable Court to Dismiss the Plaintiff's Complaint with costs to be paid by the Plaintiff. NEW MATTER 24. Paragraphs 1 through 23 are incorporated herein by reference thereto. 25. The Plaintiff's claims may be barred in whole or in part by application of the Pennsylvania Motor Vehicle Financial Responsibility Act. Respectfully submitted, NEALOWWVER & PERRY BJ Date: 6-172,/0 -7 Matthew R. Gover, Esquire Attorney I.D. No. 47593 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 VERIFICATION I, EYAL DIOR, verify that the statements made in the foregoing ANSWER TO COMPLAINT WITH NEW MATTER are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. cry../2.,.. Date: May 17 2007 EYAL DIOR VERIFICATION I, JERRY KORTEN, of Versamed Medical Systems, Inc., t/d/b/a Versamed, Inc., verify that the statements made in the foregoing ANSWER TO COMPLAINT WITH NEW MATTER are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: JERRY KORTEN for VERSAMED MEDICAL SYSTEMS, INC. T/D/B/A VERSAMED, INC. CERTIFICATE OF SERVICE AND NOW, this day of d , 2007, 1 hereby certify that I have served the foregoing ANSWER TO COMPLAINT WITH NEW MATTER on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Francis J. Lafferty, IV, Esquire METZGER, WICKERSHAM, P.C. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 r ew over, Esquire <-_' ;?? "? -?? ;--? } , EV _r., _. .?_: ?. , - _ -? -- rte: -? METZGER, WICKERSHAM, P.C. By: Francis J. Lafferty, IV, Esquire Attorney I.D. No. 84009 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 THERESE ROGERS, vs. Plaintiff EYAL DIOR and VERSAMED MEDICAL SYSTEMS, INC., individually and t/d/b/a VERSAMED, INC. Defendants Attorneys for Plaintiff Therese Rogers IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-7178 CIVIL ACTION - LAW JURY TRIAL DEMANDED PLAINTIFF'S REPLY TO DEFENDANTS' NEW MATTER 24. Paragraph 24 of Defendants' New Matter is an incorporation paragraph and no response is necessary. 25. Conclusions of law, no reply required. If a reply is required, the averments are specifically denied and denied pursuant to Pa.R.C.P. No. 1029(e). By way of further reply, Plaintiff's Complaint speaks for itself and is incorporated herein by reference. Furthermore, Defendant has failed to specifically identify the sections of the Pennsylvania Motor Vehicle Financial Responsibility Law she is referring to and therefore Plaintiff cannot properly respond. Moreover, Plaintiff's claims are not precluded, barred or limited in any manner pursuant to Pennsylvania Motor Vehicle Financial Responsibility Law. 378381-1 Dated: METZGER, WICI AM, KNAUSS & ERB, P.C. By: Francis J. Laffe , IV, E uire Attorney I.D. No. 84009 P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff 378381-1 VERIFICATION The undersigned hereby certifies that he is the attorney for the Plaintiff, Therese Rogers, and that the facts in the foregoing Plaintiff's Reply to New Matter of Defendants, are true and correct to the best of his knowledge, information and belief, and that said matters relating to the Plaintiff's Reply to New Matter of Defendants are as known to the undersigned as to the client, Plaintiff, Therese Rogers, said knowledge being based upon information contained in the attorney's files in this matter, and further states that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities. 111;7d F ancis I Laf , IV Dated: 47 378381-1 CERTIFICATE OF SERVICE I, Francis J. Lafferty, IV, Esquire, an attorney with the law firm of Metzger, Wickersham, Knauss and Erb, P.C., do hereby certify that on the date set forth below, I did serve a true and correct copy of the foregoing document upon the following person(s) at the following address(es) indicated below by sending same in the United States mail, postage prepaid, as follows: Matthew R. Gover, Esquire NEALON GOVER & PERRY 2411 North Front Street Harrisburg, PA 17110 Attorneys for Defendants Dated: 1??11,51-01-7 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By rancis J. Laf erty, IV 378381-1 C? ? C) C= ?' -n °? -T; ,- '; c? ,-? ?- .? ??.. -?. , - .S? ' r'' ?» ,r•?!? ??'? __.{ __- ? :'17 ?• ti -? V ORIGINAL THERESE ROGERS, Plaintiff VS. EYAL DIOR and VERSAMED MEDICAL SYSTEMS, INC., Individually And t/d/b/a VERSAMED, INC., Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-7178-Civil Term CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Please withdraw NEALON GOVER & PERRY'S appearance on behalf of the Defendants, EYAL DIOR and VERSAMED MEDICAL SYSEMS, INC., with regard to the above-captioned matter. Respectfully submitted, b Date: to NEALON GOVER & PERRY By: ----- Matthew R. Gover, Esquire I.D. No. 47593 For: NEALON GOVER & PERRY 2411 North Front Street Harrisburg, PA 17110 717/232-9900 CERTIFICATE OF SERVICE AND NOW, this day of October, 2007, 1 hereby certify that I have served the foregoing PRAECIPE FOR WITHDRAWAL OF APPEARANCE on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Francis J. Lafferty, IV, Esquire METZGER, WICKERSHAM, P.C. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 C"7 llir55? Ma a R. G er, squire N C?--. --? .--? ?° Ga `.1:. -; ! ?' ? ? ---', _ t r?? , q•..3 ' ; ,.D .?- ?? `...? .:. C,? 4 ORIGINAL THERESE ROGERS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW EYAL DIOR and VERSAMED : MEDICAL SYSTEMS, INC., NO. 06-7178 Civil Term Individually and t/d/b/a VERSAMED, : INC., Defendants : JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the undersigned on behalf of Defendants, Eyal Dior and VersaMed Medical Systems, Inc., Individually and t/d/b/a VersaMed, Inc., in the above- captioned case. 16)?-6161MARSHALL, DENNEHEY, WARNER, DATE: COLEMAN & GOGGIN BY: DONALD L. CARMELITE, ESQUIRE I.D. No. 84730 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3504 Attorney for Defendants CERTIFICATE OF SERVICE I, Susan M. Williams, an employee with the law firm of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this &Vo l day of October, 2007, I served a true and correct copy of the Entry of Appearance, via U.S. first-class mail, postage pre-paid, as follows: Francis J. Lafferty, IV, Esquire METZGER, WICKERSHAM, P.C. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 SUSAN M. WILLIAMS c ; i ' N `_ ORIGINAL THERESE ROGERS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW EYAL DIOR and VERSAMED MEDICAL SYSTEMS, INC., NO. 06-7178 Civil Term Individually and t/d/b/a VERSAMED, INC., Defendants JURY TRIAL DEMANDED NOTICE OF SERVING DISCOVERY TO THE PROTHONOTARY: Please take notice that Defendants, Eyal Dior and VersaMed Medical Systems, Inc., Individually and t/d/b/a VersaMed, Inc., served Interrogatories and Request for Production of Documents addressed to Plaintiff, Therese Rogers, pursuant to the Pennsylvania Rules of Civil Procedure, by mail, postage prepaid, on the B?tay of November, 2007. MARSHALL, COLEMAN & DATE: lt"? BY: , WARNER, ,PKALD L. CARMELITE, ESQUIRE D I.D. No. 84730 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3504 Attorney for Defendants A CERTIFICATE OF SERVICE I, Susan M. Williams, an employee with the law firm of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this 0+?N day of November, 2007, I served a true and correct copy of the Notice of Serving Discovery, via U.S. first-class mail, postage pre- paid, as follows: Francis J. Lafferty, IV, Esquire METZGER, WICKERSHAM, P.C. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 SUSAN M. WILLIAMS ,?.. C") ? ?? ?.. --; ,?, ,-i ?-= ? _' ?;? cs? ?,?a:: ?. _ ?t ?t ?..7 Q -r? ?? *? ?? ;- J r? ?. s _,-? ?_„ i.? ?? '"? ORIGINAL COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND THERESE ROGERS VS. PLAINTIFF/S EYAL DIOR & VERSAMED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A VERSAMED, INC. DEFENDANT/S COURT OF COMMON PLEAS NO. 06-7178 CIVIL CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 01158032 AS A PREREQUISITE TO SERVICE OF A SUBPOENA FOR DOCUMENTS AND THINGS PURSUANT TO RULE 4009.22, DEFENDANT 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 THAT WILL BE SERVED IS IDENTICAL TO THE SUBPOENA WHICH IS ATTACHED TO THE NOTICE OF INTENT TO SERVE THE SUBPOENA. DATE: 2/15/08 97 D LD L. CARMELITE, ESQ. ATTORNEY FOR DEFENDANT 012,26.01286 1874663774 J42 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND THERESE ROGERS VS. PLAINTIFF/S COURT OF COMMON PLEAS EYAL DIOR & VERSAMED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A VERSAMED, INC. DEFENDANT/S NO. 06-7178 CIVIL NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: FRANCIS J. LAFFERTY, IV, ESQ. METZGER, WICKERSHAM, KNAUSS & ERB 3211 N. FRONT ST. P.O. BOX 5300 HARRISBURG PA 17110 ATTORNEY(S) FOR PLAINTIFF 01158032 12/25/08 DEFENDANT INTENDS TO SERVE A SUBPOENA IDENTICAL TO THE ONE THAT IS ATTACHED TO THIS NOTICE TO THE DEPONENT/S LISTED BELOW, REQUESTING RECORDS BE PRODUCED AT RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., PHILADELPHIA, PA 19103. YOU HAVE TWENTY (20) DAYS FROM THE DATE LISTED BELOW IN WHICH TO FILE OF RECORD AND SERVE UPON THE UNDERSIGNED AND RECORD COPY SERVICES (215-241-5858), AN OBJECTION TO THE SUBPOENA. IF NO OBJECTION IS MADE THE SUBPOENA/S MAY BE SERVED. HOLY SPIRIT HOSPITAL FAMILY MEDICINE CENTER PROGRESSIVE INSURANCE COMPANY DATE: 1/16/08 DONALD L. CARMELITE, ESQ. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN 4200 CRUMS MILL RD. HARRISBURG PA 17112 ATTORNEY(S) FOR DEFENDANT THERESE ROGERS VS. AAA 01158032 12/25/08 COMMONWEALTH OF PENNSYLVANIA cowry OF C UKBERIAM Court of Common Pleas 06-7178 CIVIL Fi le No. EYAL DIOR & VERSAMED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A VERSAMED, INC. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISOO'VERY PURSUANT TO RULE 4009.22 MEDICAL RECORDS DEPARTMENT HOLY SPIRIT HOSPITAL 503 N. 21ST ST. TO: CAMP HILL PA 17011-2288 (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of om pliance, 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 docxanents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order corn, e l ling you to comp l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DONALD L. CARMELITE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME OOURT ID # ATTORNEY FOR: DEFENDANT DATE: ??? / g- ? W&- a 1 of t6b Court ISSUED ON: FEB 15M BY THE COURT: '? j , is U! 0??1 Pro tary/Clerk, Civil Div 'on Deputy (Eff. 7/97) NO. 06-7178 CIVIL ADDENDUM TO SUBPOENA 01158032 12/25/08 THERESE ROGERS VS. EYAL DIOR & VERSAMED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A VERSAMED, INC. SEE ATTACHED ADDENDUM PERTAINING TO THERESE A. ROGERS (869-D RHUE HAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). Jan-15-06 10:26 From-MDWC&G 717-651-9630 T-430 P-003/003 F-679 PAGE 2 OF 2 Instructions for MEDICAL records: Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x- ray films, MRls, CT scans, or other diagnostic testing performed, together with all diagnostic reports, medical reports, notes, memoranda, correspondence and medical bills concerning Therese A. Rogers; Date of Birth: 10/11164; Social Security No. 164-68-9422. N 01158032 12/25/08 COMMONWEALTH OF PENNSYLVANIA COUN'T'Y OF aUbSEFIANID THERESE ROGERS Vs.. EYAL DIOR & VERSAMED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A VERSAMED, INC. File No. Court of Common Pleas 06-7178 CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR TH I NOS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF FAMILY MEDICINE CENTER 6085 LINGLESTOWN RD. TO: HARRISBURG PA 17112 (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. (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 b this subpoena (20) days after its service the part servi this sub within twenty party n9 subpoena may seek k a court order carpe l l i ng you to comp l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DONALD L. CARMELITE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT DATE: S 1 of th urt ISSUED ON: FEB 15 M BY THE OOURT: Prothonotary/Clerk, Civil Di Vision Deput (Eff. 7/97) NO. 06-7178 CIVIL ADDENDUM TO SUBPOENA 01158032 12/25/08 THERESE ROGERS VS. EYAL DIOR & VERSAMED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A VERSAMED, INC. SEE ATTACHED ADDENDUM PERTAINING TO THERESE A. ROGERS (869-D RHUE HAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). Jan-1 5-% 10:26 From-MUG 717-651-9630 T-430 P-003/003 F-679 PAGE 2 OF 2 Instructions for MEDICAL records: Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x- ray films, MRIs, CT scans, or other diagnostic testing performed, together with all diagnostic reports, medical reports, notes, memoranda, correspondence and medical bills concerning Therese A. Rogers; Date of Birth: 10111164; Social Security No. 154-68-9422. IN 01158032 12/25/08 Op OF pYLVANIA oDuNry OF CUMBERLAND THERESE ROGERS Fi le No. Court of Common Pleas 06-7178 CIVIL Vs. EYAL DIOR & VERSAMED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A VERSAMED, INC. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 PROGRESSIVE INSURANCE COMPANY 300 OXFORD DR. S-400 TO: MONROEVILLE PA 15146 (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. (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 tray seek a court order ccmpel l ing you to ccnp1y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DONALD L. CARMELITE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT DATE : ` / a 00 Se of the C&rt 2 ISSUED ON: FEB 15 BY THE 00URT: /s/ Q. 9 Prothonotary/Clerk, Civil ivision o«_ Deputy (Eff. 1/97) NO. 06-7178 CIVIL ADDENDUM TO SUBPOENA 01158032 12/25/08 THERESE ROGERS VS. EYAL DIOR & VERSAMED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A VERSAMED, INC. SEE ATTACHED ADDENDUM PERTAINING TO THERESE A. ROGERS (869-D RHUE HAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). Jan-15-08 10:27 From-MMUG TIT-651-9630 T-431 P-003/003 F-680 PAGE 2 OF 2 Instructions for INSURANCE records: Any and all records In your possession, custody or control, Including, but not limited to, documents regarding tort option selection, insurance policies, investigative materials, photographs, medical records, reports and/or opinions, medical invoices and/or bills, together with amounts paid by Progressive Insurance Company on behalf of Therese A. Rogers for any and all medical expenses and/or property damage incurred as a result of any and all automobile accidents, including, but not limited to, an accident that occurred on 1/5/05; Policy No. 60488967-4; Claim No. 055146119. CERTIFICATE OF SERVICE I, Susan M. Williams, an employee with the law firm of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this a`",\ day of February, 2007, I served a true and correct copy of the Certificate-Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22, via U.S. first-class mail, postage pre-paid, as follows: Francis J. Lafferty, IV, Esquire METZGER, WICKERSHAM, P.C. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 am?_ k SUSAN M. WILLIAMS r? N G'1 r 02118019 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND THERESE ROGERS VS. PLAINTIFF/S EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A/ VERSAMED, INC. DEFENDANT/S COURT OF COMMON PLEAS NO. 06-7178 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 AS A PREREQUISITE TO SERVICE OF A SUBPOENA FOR DOCUMENTS AND THINGS PURSUANT TO RULE 4009.22, DEFENDANT 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 THAT WILL BE SERVED IS IDENTICAL TO THE SUBPOENA WHICH IS ATTACHED TO THE NOTICE OF INTENT TO SERVE THE SUBPOENA. DATE: 3/14/08 01226-01286 1874663774 J42 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND THERESE ROGERS VS. PLAINTIFF/S COURT OF COMMON PLEAS EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A/ VERSAMED, INC. DEFENDANT/S NO. 06-7178 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: FRANCIS J. LAFFERTY, IV, ESQ. METZGER, WICKERSHAM, KNAUSS & ERB 3211 N. FRONT ST. P.O. BOX 5300 HARRISBURG PA 17110 ATTORNEY(S) FOR PLAINTIFF 02118019 12/25/08 DEFENDANT INTENDS TO SERVE A SUBPOENA IDENTICAL TO THE ONE THAT IS ATTACHED TO THIS NOTICE TO THE DEPONENT/S LISTED BELOW, REQUESTING RECORDS BE PRODUCED AT RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., PHILADELPHIA, PA 19103. YOU HAVE TWENTY (20) DAYS FROM THE DATE LISTED BELOW IN WHICH TO FILE OF RECORD AND SERVE UPON THE UNDERSIGNED AND RECORD COPY SERVICES (215-241-5858), AN OBJECTION TO THE SUBPOENA. IF NO OBJECTION IS MADE THE SUBPOENA/S MAY BE SERVED. HEALTHSOUTH REHABILITATION AT HERSHEY REGIONAL ORTHOPEDIC ASSOCIATES P.C. ARLINGTON ORTHOPEDIC CLINIC DR. SAMUEL F. GETTY, D.C. HARRISBURG HOSPITAL DATE: 2/13/08 DONALD L. CARMELITE, ESQ. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN 4200 CRUMS MILL RD. HARRISBURG PA 17112 ATTORNEY(S) FOR DEFENDANT N 02118019 12/25/08 apVAMMMMITH OF p'YLVANIA COUNTY OF -CLIGEPIM THERESE ROGERS Vs. INDIAV. & VERSAMED SYSTEMS, INC., IDIOR File No. Court of Common Pleas 06-7178 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISOONERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF HEALTHSOUTH REHABILITATION AT HERSHEY 555 E. CHOCOLATE AVE. TO: HERSHEY PA 17033 (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 ADDENDUM at RRrnRn COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of am pliance, 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 docurents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order ccrrrpe l l i r:g you to ca, l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DONALD L. CARMELITE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID # ATTORNEY FOR:DEFENDANT DATE: 19 '2 0-07 Seal of ` the `Uourt ISSUED ON: W 1 4 20M BY THE OOURT: /it 'e eLa Prothonotary/C 1 erk , Ci v i 1 Division Deputy (Eff. 7/97) NO. 06-7178 ADDENDUM TO SUBPOENA 02118019 12/25/08 THERESE ROGERS VS. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A/ VERSAMED, INC. SEE ATTACHED ADDENDUM PERTAINING TO THERESE A. ROGERS (823B RHUEHAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). Feb-11-08 11:01 From-MMUG 717-651-9630 T-647 P.03MC03 F-240 PAGE 2 OF 2 Instructions for MEDICAL records: Any and all medical records, Including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x- ray films, MRIs, CT scans, or other diagnostic testing performed, together with all diagnostic reports, medical reports, notes, memoranda, correspondence and medical bills concerning Therese A. Rogers; Date of Birth: 10/11164; Social Security No. 154-6M422. N 0211801 MMMONWEAI,TH OF PFNIl+IMVANIA Cowry OF (QA `ID THERESE ROGERS ' Vs. File No. EYAL INC., DINDIVV. VERSAMED MEDICAL Court of Common Pleas 06-7178 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF REGIONAL ORTHOPEDIC ASSOCIATES P.C. 410 - 412 CUMBERLAND ST. TO: LEBANON PA 17042 (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., 5-300, PHILADELPHIA, PA. (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 ctmpe l l i r:g you to carp l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAPE: DONALD L. CARMELITE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215 241-5858 SUPREME COURT ID # ATTORNEY FOR pEFENDANT DATE : Lj .'? I q, '2 ev r Seal of the Court ISSUED ON: LIAR 14 20 BY THE COURT: SProthonotary/Clerk Civil Division ?'11- OA Deputy (Eff. 7/97) NO. 06-7178 ADDENDUM TO SUBPOENA 02118019 12/25/08 THERESE ROGERS VS. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A/ VERSAMED, INC. SEE ATTACHED ADDENDUM PERTAINING TO THERESE A. ROGERS (823B RHUEHAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). Feb-11-08 11:01 From-MDWC&G 717-651-9630 T-64T P.003/103 F-140 PAGE 2 OF 2 instructions for MEDICAL records: Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x- ray films, MRIs, CT scans, or other diagnostic testing performed, together with all diagnostic reports, medical reports, notes, memoranda, correspondence and medical bills concerning Therese A. Rogers; Date of Birth: 10111164; Social Security No. 154-68-9422. N 0118019 112/25/08 COM*41NWFAETH OF pIIrN:SYLVANIA COUNTY OF MEERIAW THERESE ROGERS ' • Court of Common Pleas 06-7178 File No. Vs. EYAL D INDIAV. & VT/D/BA/ MEVERSAMED, INC. . INC., SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF ARLINGTON ORTHOPEDIC CLINIC 805 SIR THOMAS COURT TO: HARRISBURG PA 17109-5004 (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., 5-300, PHILADELPHIA, PA. (Address) You may deliver or mail legible copies of the docunents or produce things requested by this subpoena, together with the certificate of cmPliance, 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 carpe l l irg you to omp l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAIL: DONALD L. CARMELITE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215 - 858 SUPREME OOURT ID # ATTORNEY FOR: DEFENDANT DATE : Tt Seal of the Court ISSUED ON: MAR 14 2008 BY THE COURT: s ?e L?:, Prothonotary/Clerk, Civil Division Deputy (Eff. 7/97) NO. 06-7178 ADDENDUM TO SUBPOENA 02118019 12/25/08 THERESE ROGERS VS. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A/ VERSAMED, INC. SEE ATTACHED ADDENDUM PERTAINING TO THERESE A. ROGERS (823B RHUEHAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). Feb-11-08 11:01 FrwMDWC&G .--9AW 717-651-8630 T-647 P.003/003 F-240 PAGE 2OF2 Instructions for MEDICAL records: Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x- ray films, MRls, CT scans, or other diagnostic testing performed, together with all diagnostic reports, medical reports, notes, memoranda, correspondence and medical bills concerning Therese A. Rogers; Date of Birth: 10/11/64; Social Security No. 154-68-9422. N 112/25/08 app OF PENNSYLVANIA 0OUNPY OF THERESE ROGERS Court of Common Pleas 06-7178 File No. VS. INC., LDINDIVV. & AND VERSAMED MEDICAL SYSTEMS, SUBPOENA TO PRODUCE DOCUMENTS OR TH 1 NGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF DR. SAMUEL F. GETTY, D.C. 4901 DERRY ST. TO: HARRISBURG PA 17111 (Nwm 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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of cia, liance, 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 subpoen3 within twenty (20) days after its service, the party serving this subpoena may seek a court order compe l l i rag you to crop l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DONALD L. CARMELITE, ESQ. ADDRESS: TELEPHONE. FOR INFORMATION: (215) - 858 SUPREME OGURT ID # ATTORNEY FOR: DEFENDANT DATE : Lj"? /C7 a2 6y t Seal of the 'Court ISSUED ON: IIAR 1 4.2W8 BY THE COURT: s k LM4 Prothonotary/Clerk Civil Division Deputy (Eff. 7/97) J0. 06-7178 ADDENDUM TO SUBPOENA 02118019 12/25/08 THERESE ROGERS VS. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A/ VERSAMED, INC. SEE ATTACHED ADDENDUM PERTAINING TO THERESE A. ROGERS (823B RHUEHAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). Feb-11-08 11:01 From-MMUG TIT-651-8630 T-647 P.003/003 F-240 PAGE 2 OF 2 OW instructlons for MEDICAL records: Any and all medical records, Including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x- ray films, MRIs, CT scans, or other diagnostic testing performed, together with all diagnostic reports, medical reports, notes, memoranda, correspondence and medical bills concerning Therese A. Rogers; Date of Birth: 10111164; Social Security No. 154-68-9422. BXN 02118019 12/25/08 COMMONWEALTH OF PENNSYLVANIA COLWN OF THERESE ROGERS Vs. File No. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A/ VERSAMED, INC. Court of Common Pleas 06-7178 SUBPOENA TO PRODUCE DOCUMENTS OR THINeS FOR DISONERY PURSUANT TO RULE 4009.22 MEDICAL RECORDS DEPARTMENT HARRISBURG HOSPITAL 111 S. FRONT ST. TO: HARRISBURG PA 17101 (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, A. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of eanpliance, 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 compel 1 ir:g you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DONALD L. CARMELITE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215 -5858 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT DATE: / g o 67J I Seal of the ourt ISSUED ON: W 14M BY THE COURT: s Prothonotary/C1 Civil Division Deputy (Eff. 7/97) NO. 06-7178 ADDENDUM TO SUBPOENA 02118019 12/25/08 THERESE ROGERS VS. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A/ VERSAMED, INC. SEE ATTACHED ADDENDUM PERTAINING TO THERESE A. ROGERS (823B RHUEHAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). Feb-11-08 11:01 From-M UG TIT-651-9630 T-647 P.003/003 F-240 PAGE 2 OF 2 Ins,..Ions for MEDICAL records; Any and all medical records, Including, but not limited to, Inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x- ray films, MRis, CT scans, or other diagnostic testing performed, together with all diagnostic reports, medical reports, notes, memoranda, correspondence and medical bills concerning Therese A. Rogers; Date of Birth: 10111/64; Social Security No. 154-68-9422. CERTIFICATE OF SERVICE I, Susan M. Williams, an employee with the law firm of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this day of March, 2008, I served a true and correct copy of the Certificate-Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22, via U.S. first-class mail, postage pre-paid, as follows: Francis J. Lafferty, IV, Esquire METZGER, WICKERSHAM, P.C. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 ?? , ?? )11' Q, kA A? SUSAN M. WILLIAMS c.? hJ ?i:f ? C. { ORIGINAL. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND THERESE ROGERS VS. PLAINTIFF/S EYAL DIOR AND VERSAMED MEDICAL SYSTEM, INC., INDIV. & T/D/B/A VERSA MED, INC. DEFENDANT/S COURT OF COMMON PLEAS NO. 06-7178 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 03118014 AS A PREREQUISITE TO SERVICE OF A SUBPOENA FOR DOCUMENTS AND THINGS PURSUANT TO RULE 4009.22, DEFENDANT 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 THAT WILL BE SERVED IS IDENTICAL TO THE SUBPOENA WHICH IS ATTACHED TO THE NOTICE OF INTENT TO SERVE THE SUBPOENA. DATE: 4/11/08 `?o DONALD L. CARMELITE, ESQ. ATTORNEY FOR DEFENDANT 01226-01286 174663774 J42 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND THERESE ROGERS 03118014 12/25/08 PLAINTIFF/S ) COURT OF COMMON PLEAS VS. ) EYAL DIOR AND VERSAMED MEDICAL SYSTEM, ) NO. 06-7178 INC., INDIV. & T/D/B/A VERSA MED, INC. ) DEFENDANT/S ) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: FRANCIS J. LAFFERTY, IV, ESQ. METZGER, WICKERSHAM, KNAUSS & ERE 3211 N. FRONT ST. P.O. BOX 5300 HARRISBURG PA 17110 ATTORNEY(S) FOR PLAINTIFF DEFENDANT INTENDS TO SERVE A SUBPOENA IDENTICAL TO THE ONE THAT IS ATTACHED TO THIS NOTICE TO THE DEPONENT/S LISTED BELOW, REQUESTING RECORDS BE PRODUCED AT RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., PHILADELPHIA, PA 19103. YOU HAVE TWENTY (20) DAYS FROM THE DATE LISTED BELOW IN WHICH TO FILE OF RECORD AND SERVE UPON THE UNDERSIGNED AND RECORD COPY SERVICES (215-241-5858), AN OBJECTION TO THE SUBPOENA. IF NO OBJECTION IS MADE THE SUBPOENA/S MAY BE SERVED. PROGRESSIVE NORTHERN INSURANCE I DATE: 3/12/08 DONALD L. CARMELITE, ESQ. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN 4200 CRUMS MILL RD. HARRISBURG PA 17112 ATTORNEY(S) FOR DEFENDANT -- 1 N 03118014 12/25/08 COtfUNWERINS OF PErNMVANTA 00MM OF CUMBERLAND THERESE ROGERS Vs. EYAL DIOR AND VERSAMED MEDICAL SYSTEM, INC., INDIV. & T/D/B/A VERSA MED, INC. Court of Common Pleas 06-7178 File No. SUBPOENA TO PRODUCE DOCLIENTS OR THINGS FOR DISOOVERY PURSUANT TO RULE 4009.22 PROGRESSIVE NORTHERN INSURANCE 300 OXFORD DR. S-400 TO: MONROEVILLE PA 15146 (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of ccrrpliance, 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 (20) days after its service, the party compelling you to car ply with it. things required by this subpoena within twenty serving this subpoena may seek a court order THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DONALD L. CARMELITE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 24T---5858 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT DATE: _ MA4,,_, j-7 .2oDY Seal of they Court ISSUED ON: I ! BY THE 77 T: othono 1 k, Civil Division Deputy (Eff. 7/97) } NO. 06-7178 ADDENDUM TO SUBPOENA 03118014 12/25/08 THERESE ROGERS VS. EYAL DIOR AND VERSAMED MEDICAL SYSTEM, INC., INDIV. & T/D/B/A VERSA MED, INC. SEE ATTACHED ADDENDUM PERTAINING TO THERESE A. ROGERS (869-D RHUE HAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). Instructions for INSURANCE records: Any and all records In your possession, custody or control; Including, but not limited to, documents regarding tort option selection, insurance policies, investigative materials, photographs, medical records, reports and/or opinions, medical invoices and/or bills, together with amounts paid by Progressive insurance Company on behalf of Therese A. Rogers for any and all medical expenses and/or property damage incurred as a result of any and all automobile accidents, including, but not limited to, an accident that occurred on 115/05; Policy No. 60488967-4; Claim No. 055146119. CERTIFICATE OF SERVICE I, Susan M. Williams, an employee with the law firm of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this _ day of April, 2008, I served a true and correct copy of the Certificate-Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22, via U.S. first-class mail, postage pre-paid, as follows: Francis J. Lafferty, IV, Esquire METZGER, WICKERSHAM, P.C. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 SUSAN M. WILLIAMS c'7 a -ri -n (T, ORIGINAL COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND THERESE ROGERS PLAINTIFF/S COURT OF COMMON PLEAS VS. EYAL DIOR & VERSAMED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A VERSAMED, INC. NO. 06-7178 DEFENDANT/S CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 06108006 AS A PREREQUISITE TO SERVICE OF A SUBPOENA FOR DOCUMENTS AND THINGS PURSUANT TO RULE 4009.22, DEFENDANT 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 THAT WILL BE SERVED IS IDENTICAL TO THE SUBPOENA WHICH IS ATTACHED TO THE NOTICE OF INTENT TO SERVE THE SUBPOENA. DATE: 7/08/08 -4 L DON D L. CARMELITE, ESQ. ATTORNEY FOR DEFENDANT 01226-01286 1874663774 J42 THERESE ROGERS COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PLAINTIFF/S VS. EYAL DIOR & VERSAMED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A VERSAMED, INC. DEFENDANT/S COURT OF COMMON PLEAS NO. 06-7178 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: FRANCIS J. LAFFERTY, IV, ESQ. METZGER, WICKERSHAM, KNAUSS & ERB 3211 N. FRONT ST. P.O. BOX 5300 HARRISBURG PA 17110 ATTORNEY(S) FOR PLAINTIFF 06108006 12/25/08 DEFENDANT INTENDS TO SERVE A SUBPOENA IDENTICAL TO THE ONE THAT IS ATTACHED TO THIS NOTICE TO THE DEPONENT/S LISTED BELOW, REQUESTING RECORDS BE PRODUCED AT RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., PHILADELPHIA, PA 19103. YOU HAVE TWENTY (20) DAYS FROM THE DATE LISTED BELOW IN WHICH TO FILE OF RECORD AND SERVE UPON THE UNDERSIGNED AND RECORD COPY SERVICES (215-241-5858), AN OBJECTION TO THE SUBPOENA. IF NO OBJECTION IS MADE THE SUBPOENA/S MAY BE SERVED. SUSQUEHANNA VALLEY SURGICAL CENTER DR. WILLIAM A. ROLLE, JR., M.D. PRISM DATE: 6/11/08 DONALD L. CARMELITE, ESQ. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN 4200 CRUMS MILL RD. HARRISBURG PA 17112 ATTORNEY(S) FOR DEFENDANT COMMONWEAM OF PENNSYLVANIA COURrY OF CUMBERLAND THERESE ROGERS 06108006 12/25/08 Court of Common Pleas 06-7178 Vs. File No. EYAL DIOR & VERSAMED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A VERSAMED, INC. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISa VERY PURSUANT To RULE 4009.22 CUSTODIAN OF THE RECORDS OF SUSQUEHANNA VALLEY SURGICAL CENTER 4310 LONDONDERRY RD. TO: HARRISBURG PA 17109 (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, -PA. (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 corrpe l l i r:g you to comp l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DONALD L. CARMELITE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 74 =-58 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT DATE : lJ? - / _ 0 0"09 Seal of the Oourt ISSUED ON:- O 8 US BY THE COURT: Pr honotari k. C' it Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA 06108006 NO. 06-7178 12/25/08 THERESE ROGERS VS. EYAL DIOR & VERSAMED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A VERSAMED, INC. SEE ATTACHED ADDENDUM PERTAINING TO THERESE A. ROGERS (823B RHUEHAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). Jun-10-08 08:23 From-MDWC&G Instructions for MEDICAL records: 717-651-9630 Any and all medical records, including, but not limite outpatient records, physical therapy records, rehab r ray films, MRIs, CT scans, or other diagnostic testing with all diagnostic reports, medical reports, notes, m correspondence and medical bills concerning Theres Birth: 10111164; Social Security No. 154-68-9422. T-559 P-003/003 F-74T PAGE 2 OF 2 to, inpatient records, ;orris, lab reports, x- ierFormed, together A. Rogers; Date of 06108006 12/25/08 COMtUNWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND THERESE ROGERS File No. Court of Common Pleas 06-7178 Vs. EYAL DIOR & VERSAMED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A VERSAMED, INC. SUBPOENA TO PRODUCE DOW ENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF DR. WILLIAM A. ROLLE, JR., M.D. PRISM TO: 4310 LONDONDERRY RD. S-106 BLOOM BUILDING (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, P . (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 ccmrie l ling you to carp l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DONALD L. CARMELITE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: 21 271--5858 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT DATE: /3, 07 0V Seal of the Court ISSUED ON:, O 8 M BY THE COURTAtary/ Prot iv 1 Division Deputy (Eff. 1/97) NO. 06-7178 ADDENDUM TO SUBPOENA 06108006 12/25/08 THERESE ROGERS VS. EYAL DIOR & VERSAMED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A VERSAMED, INC. SEE ATTACHED ADDENDUM PERTAINING TO THERESE A. ROGERS (823B RHUEHAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). 0 Jun-10-08 08:2.' From-MMUG Instructions for MEDICAL records: TIT-651-9630 Any and all medical records, including, but not limite outpatient records, physical therapy records, rehab r, ray films, MRls, CT scans, or other diagnostic testing with all diagnostic reports, medical reports, notes, mi correspondence and medical bills concerning Theres Birth: 10111164; Social Security No. 154-68-9422. L. ?Y T-559 P-003/003 F-747 PAGE 2 OF 2 Ito, inpatient records, ords, lab reports, x- erformed, together oranda, A. Rogers; Date of CERTIFICATE OF SERVICE I, Susan M. Williams, an employee with the law firm of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this ID4\ day of July, 2008, I served a true and correct copy of the Certificate-Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22, via U.S. first-class mail, postage pre-paid, as follows: Francis J. Lafferty, IV, Esquire METZGER, WICKERSHAM, P.C. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 SUSAN M. WILLIAMS 771- { 09038050 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND THERESE ROGERS PLAINTIFF/S VS. EYAL DIOR & VERSA MED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A VERSA MED, INC, DEFENDANT/S ORIGINAL COURT OF COMMON PLEAS NO. 06-7178 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 AS A PREREQUISITE TO SERVICE OF A SUBPOENA FOR DOCUMENTS AND THINGS PURSUANT TO RULE 4009.22, DEFENDANT 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 THAT WILL BE SERVED IS IDENTICAL TO THE SUBPOENA WHICH IS ATTACHED TO THE NOTICE OF INTENT TO SERVE THE SUBPOENA. DATE: 10/06/08 01226-01286 1874663774 J42 THERESE ROGERS VS. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PLAINTIFF/S COURT OF COMMON PLEAS EYAL DIOR & VERSA MED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A VERSA MED, INC. DEFENDANT/S NO. 06-7178 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: FRANCIS J. LAFFERTY, IV, ESQ. METZGER WICKERSHAM, P.C. 3211 N. FRONT ST. P.O. BOX 5300 HARRISBURG PA 17110 ATTORNEY(S) FOR PLAINTIFF 09038050 12/25/08 DEFENDANT INTENDS TO SERVE A SUBPOENA IDENTICAL TO THE ONE THAT IS ATTACHED TO THIS NOTICE TO THE DEPONENT/S LISTED BELOW, REQUESTING RECORDS BE PRODUCED AT RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., PHILADELPHIA, PA 19103. YOU HAVE TWENTY (20) DAYS FROM THE DATE LISTED BELOW IN WHICH TO FILE OF RECORD AND SERVE UPON THE UNDERSIGNED AND RECORD COPY SERVICES (215-241-5858), AN OBJECTION TO THE SUBPOENA. IF NO OBJECTION IS MADE THE SUBPOENA/S MAY BE SERVED. HARRISBURG AREA COMMUNITY COLLEGE SHAR HARBOVSKY, CRNP DATE: 9/05/08 DONALD L. CARMELITE, ESQ. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN 4200 CRUMS MILL RD. HARRISBURG PA 17112 ATTORNEY(S) FOR DEFENDANT 1V 09038050 12/25/08 OpmmrwwvALTfi OF pFZa1S'SfZAANIA COUNTY OF CUMBERLANID THERESE ROGERS Court of Common Pleas 06-7178 VS. File No. MEVERSADICALMEDSYSTEMS INC, SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISOOVERY PURSUANT TO RULE 4009.22 HARRISBURG AREA COMMUNITY COLLEGE ONE HAAC DR. 'dip: HARRISBURG PA 17110 (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of ocrpliance, 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 subpoera may seek a court order ccrrpe l l i ng you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DONALD L. CARMELITE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: - 58 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT DATE: Lmt?_ /U 100 ? Seal of the Court ISSUED ON: = 06M BY THE COURT: P thonotar ivil Division Deputy (Eff. 7/97) NO. 06-7178 ADDENDUM TO SUBPOENA 09038050 12/25/08 THERESE ROGERS VS. EYAL DIOR & VERSA MED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A VERSA MED, INC. SEE ATTACHED ADDENDUM PERTAINING TO THERESE ANN ROGERS (823B RHUEHAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). Any and all records, including, but not limited to, applica ons, transcripts, documents, incoming nursing student health examinatio forms or any other written or electronically stored material pertaining t Therese Ann Rogers; Date of Birth: 10111164; Social Security No. 154. 8-9422. COUNTY OF COMBERIAND OF PENNSYLVANIA THERESE ROGERS Vs. _ File No. N 09038050 12/25/08 Court of Common Pleas 06-7178 EYAL DIOR & VERSA MED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A VERSA MED, INC. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 SHAR HARBOVSKY, CRNP 6085 LINGLESTOWN RD. TO: HARRISBURG PA 17112 (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., 5-300, PHILADELPHIA, PA. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of ccapIiance, 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 ccrgbe l l i ng you to carp l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DONALD L. CARMELITE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 2 - 858 SUPREME OOURT ID # ATTORNEY FOR: DEFENDANT DATE : In .2i Seal of the Cart ISSUED ON: Off 0 6 20 BY THE COURT: Pro tar ivil Division Deputy (Eff. 1/97) NO. 06-7178 ADDENDUM TO SUBPOENA 09038050 12/25/08 THERESE ROGERS VS. EYAL DIOR & VERSA MED MEDICAL SYSTEMS, INC., INDIV. & T/D/B/A VERSA MED, INC. SEE ATTACHED ADDENDUM PERTAINING TO THERESE ANN ROGERS (823B RHUEHAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). Instructions for records from Shar Harbovsky. CRNP: Any and all medical records, including, but not limited' Community College incoming student nursing health e pertaining to Therese Ann Rogers; Date of Birth: 10111 No. 154-66-9422. a Harrisburg Area nination form, ; Social Security CERTIFICATE OF SERVICE I, Susan M. Williams, an employee with the law firm of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this day of October, 2008, I served a true and correct copy of the Certificate-Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22, via U.S. first-class mail, postage pre-paid, as follows: Francis J. Lafferty, IV, Esquire METZGER, WICKERSHAM, P.C. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 WJOA"%?' SUSAN M. WI LIAMS CD + f ...? X33gyp' sy c.. L ? _•C 09308033 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND THERESE ROGERS VS. PLAINTIFF/S EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., INDIV. AND T/D/B/A VERSAMED, INC. DEFENDANT/S COURT OF COMMON PLEAS NO. 06-7178 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 AS A PREREQUISITE TO SERVICE OF A SUBPOENA FOR DOCUMENTS AND THINGS PURSUANT TO RULE 4009.22, DEFENDANT 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 THAT WILL BE SERVED IS IDENTICAL TO THE SUBPOENA WHICH IS ATTACHED TO THE NOTICE OF INTENT TO SERVE THE SUBPOENA. DATE: 10/29/08 DODML f L. CARMELITE, ESP. ATTORNEY FOR DEFENDANT O.226-01286 1874663774 J42 THERESE ROGERS COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PLAINTIFF/S VS. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., INDIV. AND T/D/B/A VERSAMED, INC. DEFENDANT/S COURT OF COMMON PLEAS NO. 06-7178 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: FRANCIS J. LAFFERTY, IV, ESQ. METZGER WICKERSHAM, P.C. 3211 N. FRONT ST. P.O. BOX 5300 HARRISBURG PA 17110 ATTORNEY(S) FOR PLAINTIFF 09308033 12/25/08 DEFENDANT INTENDS TO SERVE A SUBPOENA IDENTICAL TO THE ONE THAT IS ATTACHED TO THIS NOTICE TO THE DEPONENT/S LISTED BELOW, REQUESTING RECORDS BE PRODUCED AT RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., PHILADELPHIA, PA 19103. YOU HAVE TWENTY (20) DAYS FROM THE DATE LISTED BELOW IN WHICH TO FILE OF RECORD AND SERVE UPON THE UNDERSIGNED AND RECORD COPY SERVICES (215-241-5858), AN OBJECTION TO THE SUBPOENA. IF NO OBJECTION IS MADE THE SUBPOENA/S MAY BE SERVED. MILTON S. HERSHEY MEDICAL CENTER VIRTUA WEST JERSEY HOSPITAL/MARLTON DIVISION VIRTUA MEMORIAL HOSPITAL LOURDES MEDICAL CENTER OF BURLINGTON COUNTY DATE: 10/01/08 DONALD L. CARMELITE, ESQ. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN 4200 CRUMS MILL RD. HARRISBURG PA 17112 ATTORNEY(S) FOR DEFENDANT SBX 02/225/08 rnmw* mmT.TH OF PII$B1MVANIA aDUNPY OF CiIGERIAM THERESE ROGERS File No. Court of Common Pleas 06-7178 Vs. . INC.,DINDIAV. ANDRT/D B/AEVERSAMED, INC. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISODVERY PURSUANT TO RULE 4009.22 MEDICAL RECORDS DEPARTMENT MILTON S. HERSHEY MEDICAL CENTER 500 UNIVERSITY DR. TO: P.O. BOX 850 HERSHEY PA 17033 (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., 5-300, PHILADELPHIA, PA. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of oanpliance, 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 carpelling you to carp1y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DONALD L. CARMELITE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215 - 858 SUPREME COURT ID # ATTORNEY FOR:DEFENDANT DATE • C, c t.-14' J, 9 &V1? Searl?r of the t ISSUED ON: a.J?,rt a 9 BY THE COURT: ;Ijlf. I - fmlt*?L Pro tary/C , i I Division Deputy (Eff. 7/97) NO. 06-7178 ADDENDUM TO SUBPOENA 09308033 12/25/08 THERESE ROGERS VS. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., INDIV. AND T/D/B/A VERSAMED, INC. SEE ATTACHED ADDENDUM PERTAINING TO THERSE ANN ROGERS (823B RHUEHAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). Sep-40-06 15:16 From-MDWC&G 717-651-9630 T-436 P-003/003 F-445 PAGE 2OF2 Instructions for MEDICAL records: Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x- ray films, MRls, CT scans, or other diagnostic testing performed, together with all diagnostic reports, medical reports, notes, memoranda, correspondence and medical bills concerning Therese A. Rogers; Date of Birth: 10111/64; Social Security No. 164-68-9422. XN 02/225/08 . WMT.XH OF PIIa17'YI+VANIA QOUl1PY OF aRE RLAM THERESE ROGERS ' Vs. File No. INC.,D V.INDIV.DANDRT/D B/AEVERSAMED, INC. Court of Common Pleas 06-7178 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 MEDICAL RECORDS DEPARTMENT VIRTUA WEST JERSEY HOSPITAL/MARLTON DIVISION TO: 90 BRICK RD. MARLTON NJ 08053 (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, . (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of caTpliance, 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 ccrroe l l i ng you to ca p l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DONALD L. CARMELITE, ESQ. ADDRESS: TELEPHONE' FOR INFORMATION: - 58 SUPREME OOURT ID # ATTORNEY FOR: DEFENDANT DATE' 6361zt ? 3 a &rO g Seal of the Court ISSUED ON: = 2 9 BY THE COURT : Pro tary/Cler ? Division Deputy (Eff. 1/97) NO. 06-7178 ADDENDUM TO SUBPOENA 09308033 12/25/08 THERESE ROGERS VS. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., INDIV. AND T/D/B/A VERSAMED, INC. SEE ATTACHED ADDENDUM PERTAINING TO THERSE ANN ROGERS (823B RHUEHAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). Sea-30-08 15:16 From-MDWC4G 717-651-9630 T-438 P-003/003 F-445 PAGE 2OF2 instructions for MEDICAL records: Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x- ray films, MRis, CT scans, or other diagnostic testing performed, together with all diagnostic reports, medical reports, notes, memoranda, correspondence and medical bills concerning Therese A. Rogers; Date of Birth: 10111164; Social Security No. 154-68-9422. SBXN 09308033 12/25/08 rr&Mr*A4MT.TH OF PERNSYLVANIA COUNPY OF CLDG ERIAND THERESE ROGERS Vs. File No. INCC..,DINDIAV. ANDRT/D B/AEVERSAMED, EMSC, Court of Common Pleas 06-7178 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 MEDICAL RECORDS DEPARTMENT VIRTUA MEMORIAL HOSPITAL 175 MADISON AVE. TO: MT. HOLLY NJ 08060-2038 (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, . (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of catpliance, 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 carpel ling you to carp1y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DONALD L. CARMELITE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: 241-5858 SUPREME OOURT ID # ATTORNEY FOR: DEFENDANT DATE : l ?? t&L' 3 2 c o t Seal of the Court ISSUED ON: T, r 2, 9 BY THE COURT: Pro y/C1 Ci it Division Deputy (Eff. 1/97) NO. 06-7178 ADDENDUM TO SUBPOENA 09308033 12/25/08 THERESE ROGERS VS. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., INDIV. AND T/D/B/A VERSAMED, INC. SEE ATTACHED ADDENDUM PERTAINING TO THERSE ANN ROGERS (823B RHUEHAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). Sep-30-08 15:16 From-MDWC&G 717-651-9630 T-438 P-003/003 F-445 PAGE 2OF2 Instructions for MEDICAL records: Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x- ray films, MRls, CT scans, or other diagnostic testing performed, together with all diagnostic reports, medical reports, notes, memoranda, correspondence and medical bills concerning Therese A. Rogers; Date of Birth: 10/11/64; Social Security No. 164-68-9422. BXN 09308033 12/25/08 NTH OF PFIalSYLVANIA CO1;Jtz1'Y OF CL14BERIAM THERESE ROGERS Vs. File No. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., INDIV. AND T/D/B/A VERSAMED, INC. Court of Common Pleas 06-7178 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 MEDICAL RECORDS DEPARTMENT LOURDES MEDICAL CENTER OF BURLINGTON COUNTY TO: 218A SUNSET RD. WILLINGBORO NJ 08046-1110 (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, . (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of carpliance, 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 subpoen3 within twenty (20) days after its service, the party serving this subpoena may seek a court order carI el i ing you to conply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NN1E: DONALD L. CARMELITE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: 2 241-5858 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT DATE : (P e--u 3 '9 (`U V Seal of the Court ISSUED ON: OCT 2 9 BY THE COURT: Prot tary , Civ 1 Division Deputy (Eff. 7/97) NO. 06-7178 ADDENDUM TO SUBPOENA 09308033 12/25/08 THERESE ROGERS VS. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., INDIV. AND T/D/B/A VERSAMED, INC. SEE ATTACHED ADDENDUM PERTAINING TO THERSE ANN ROGERS (823B RHUEHAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). Sep-30-08 15:16 From-MDWC&G 717-651-9630 T-438 P-003/003 F-445 PAGE 2 OF 2 Instructions for MEDICAL. records: Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x- ray films, MRis, CT scans, or other diagnostic testing performed, together with all diagnostic reports, medical reports, notes, memoranda, correspondence and medical bills concerning Therese A. Rogers; Date of Birth: 10/11164; Social Security No. 164-68-9422. CERTIFICATE OF SERVICE I, Susan M. Williams, an employee with the law firm of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this ?t h day of November, 2008, I served a true and correct copy of the Certificate-Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22, via U.S. first-class mail, postage pre-paid, as follows: Francis J. Lafferty, IV, Esquire METZGER, WICKERSHAM, P.C. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 L SUSAN M. WILLIAMS ? ??_ ?: ?+ 'r: THERESE ROGERS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. EYAL DIOR and VERSAMED : CIVIL ACTION - LAW MEDICAL SYSTEMS, INC., NO. 06-7178 Civil Term Individually and t/d/b/a VERSAMED, INC., Defendants JURY TRIAL DEMANDED DEFENDANTS EYAL DIOR AND VERSAMED MEDICAL SYSTEMS. INC.'S MOTION FOR A STATUS CONFERENCE AND NOW come the Defendants by and through their attorneys, Marshall, Dennehey, Warner, Coleman & Goggin and hereby respectfully request this Honorable Court schedule a Status Conference in order to establish pretrial deadlines and a trial date and in support thereof avers as follows: 1. This matter was initiated by Writ of Summons on or about December 19, 2006. 2. Thereafter, on or about February 16, 2007, Plaintiff filed a Complaint. 3. This matter arises from a motor vehicle accident that occurred on January 5, 2005 at the intersection of Central Boulevard and Trindle Road in Hampton Township, Cumberland County, Pennsylvania. 4. Plaintiffs claims sound in negligence. 5. The parties have engaged in written discovery and the party depositions have been concluded. 6. At the conclusion of the depositions in October 2008, Plaintiff indicated that she would be making a settlement demand and/or advising what additional activity she intended to pursue prior to resolving this matter through trial. 7. After repeated attempts to secure a demand from Plaintiffs counsel and/or be advised what additional activity she intends to pursue, Plaintiffs counsel has not responded to the same. 8. Accordingly, the undersigned counsel wishes to secure pretrial deadlines including close of discovery, experts, dispositive motions and listing the case for trial for a trial term after a date certain. 9. The undersigned counsel sought the concurrence of Plaintiffs counsel but no response was received. See correspondence of June 3, 2009 from Don Carmelite to Francis Lafferty, Esquire attached hereto as Exhibit A. 10. No judge has had any prior involvement in this matter. WHEREFORE, Defendants Eyal Dior and Versamed Medical System, Inc. respectfully requests this Honorable Court grant this motion and order a Status Conference between the parties for the purposes of discussing settlement and establishing pretrial deadlines. Respectfully submitted, DATE: I0 % MARSHALL, DENNEHEY, WARNER, CML+'IAI & GOGGIN DOt1D L. CARMELITE, ESQUIRE I.D. No. 84730 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3504 Attorney for Defendant CERTIFICATE OF SERVICE I, Sarah A. Doerfler, an employee with the law firm of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this 11'*day of July, 2009, I served a true and correct copy of the foregoing document via U.S. first-class mail, postage pre-paid, as follows: Francis J. Lafferty, IV, Esquire METZGER, WICKERSHAM, P.C. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 Sarah A. Doerfler 05/499366.v1 ?xG?jb 1-f- A A REGIONAL DEFENSE LITIGATION LAW FIRM MARSHALL DENNEHEY WARNER COLEMAN GOGGIN P-NNSYLVANtA Bethlehem Doylestown DSLAWARB Wilmington A P R o F F 5 S l o N A L C o R P o R A T 1 o N www.marshaUctennchey.com .com Har sburg oHro Akron 200 Crums Mill Road, Suite B - Harrisbu g, PA 17112 b King of Prussia Phdad,IPhia Pittsburgh Scranton Williamsport PLOUDA Pt. Lauderdale Jacksonville Orlando (717) 651-3500 • Fax (717) 651-9630 NawJssser Cherry Hill Roseland Tampa NawYatx New York Direct Dial: 717-651-3504 Email: dicarmelite@mdwcg.com June 3, 2009 Via Facsimile Francis J. Lafferty, IV, Esquire METZGER, WICKERSHAM, P.C. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 RE: Therese Rovers v. Eval Dior and VersaMed Medical Systems, Inc., Individually and t/d/b/a VersaMed. Inc. CCP (Cumberland County) No. 06-7178 Civil Term Our File No.: 01226-01286.A42 Dear Frank: Enclosed please find a Motion for Status Conference with the court. Please advise if you concur with the motion by the close of business Friday, June 5, 2009. Very Carmelite DLC/sad Enclosure 05/499367. v l Confirmation Report- Memory Send Page : 001 Date t Time: Jun-04-09 11:26 Line 1 : 717-651-9630 Line 2 Machine ID MDWC&G Job number 122 Date 1 24 To x7172349478 Number of pages 007 Start time Jun-04 11:24 End time Jun-04 11:26 Pages sent 007 Status OK _. ---- - ,._---_.__ Job number 122 *** SEND SUCCESSFUL 4200 Cruma Mill Road, Bnitc 13. Ilaarii-loU ar8, PA 17112 FACSIMIi.<E TRANSMISSION SI3S'1MT TOe COMPANY: 1TL8'P80NE FAX IVLIMSER(8): Fraracis J. Lairerty. N, M3RTZ(3331;t-. WICKERSHAM. (717) 238-8187 717-234-9478 8sgtaira P. C. oomaisavic,v: Donald I-. Cnr*xIwHtC rTi W=l9R1 717-651-3504 OXM FILE #: 0 1 22601 2 86 DATE: 06/04/09 ORIGiINATOR: SAD cover NAME: Pogdrs v. Dior and VimmuMad. Inc. CLwIM #[ NUMBER OF PACWLSs 7 CbscluctinS cover pnSs) IF CUPY IS XX-X- rCPXBLE QR XJVC"JWAOX "7W PLBiISE C,A r r- (7Z 7f 6SZ-4S00 IA ".""X d TBLY F4ma jwjIT.R.ON.SIIArZS.SlON AUIL Fw.X NUMBER. ISt f717) 601-0630 ?+rwCONFIDENTIALITY NOTICE+?w+ The doeuments sooompanyina his tolvar,M "snsmission oonrahh lnfb[metlon firm the lilw Bent or Maaehdl. 931=1%ohey. Wilmer. Coalman AL Cosain whisk I. eanMenl{a/ anr//or Np/1y p,IWIOSod. Tuir infbrrrhatlan Is Intended only [br Who we of the indeh.igtla[ or emisy MmW on this trtetamle,Ion show. ,f YOO Ore stet the Intended reelplent, you Ore hereby not117a4 uurt you should rennin Ovm readlns the ocnvum rl or the ttenstolaelon. that arw til"hwurs, aopyina. dixtribugon or the wKMSs erany notion In roltaaaee an Nov ovnaenis of thla tol esopied IMbrrniltlon is strictly prohibi[a4, and [hilt the deeutnents should be rowrned to this [roan Immedi-.W. in tilt rexurd. ir3,- haw -.1-d this -1-py In error, please notify vs by telephone irnmodistely so mac we misty umtnp ibr the return of v to W, I MARSHALL, DENNEHEY WARNER, CoiEMAIV GOGGIN A P R O Y' E S S I O N A L C O R P O R A ' 1 ' I O N www.nwrshaDdennahey.com 4200 Crums Mill Road, Suite B, Harrisburg, PA 17112 FACSIMILE TRANSMISSION SHEET TO: COMPANY: TELEPHONE FAX NUMBER(S): Francis J. Lafferty, IV, METZGER, WICKERSHAM, (717) 238-8187 717-234-9478 Esquire P.C. ATTORNEY: Donald L. Carmelite NUMBER: 717-651-3504 OUR FILE #: 0122601286 DATE: 06/04/09 ORIGINATOR: SAD CASE NAME. Rogers v. Dior and VersaMed, Inc. CLAIM #: NUMBER OF PAGES: 7 (including cover page) IF COPY IS ILLEGIBLE OR INCOMPLETE PLEASE CALL (717) 651-3500 IMMEDIA TEL Y FOR RETRANSMISSION OUR FAX NUMBER IS: (717) 651-9630 (This space to be used for short or supplemental messages) ***CONFIDENTIALITY NOTICE*** The documents accompanying this telecopy transmission contain information from the law firm of Marshall, Dennehey, Warner, Coleman & Goggin which is confidential and/or legally privileged. This information is intended only for the use of the individual or entity named on this transmission sheet, If you are not the intended recipient, you are hereby notified that you should refrain from reading the contents of the transmission, that any disclosure, copying, distribution or the taking of any action in reliance on the contents of this telecopied infonnation is strictly prohibited, and that the documents should be returned to this Firm immediately. In this regard, if you have received this telecopy in error, please notify us by telephone immediately so that we may arrange for the return of the original documents to its. FILED-- %-i"; *E Z 9 ? ' 28 Sri ;2: ? -1 JUL ? 9 2009(4 THERESE ROGERS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW EYAL DIOR and VERSAMED MEDICAL SYSTEMS, INC., NO. 06-7178 Civil Term Individually and t/d/b/a VERSAMED, INC., Defendants JURY TRIAL DEMANDED ORDER AND NOW this - day of , 2009, upon consideration of Defendants' Motion for a Status Conference it is hereby ORDERED and DECREED that a Status Conference is scheduled for CL , 2009 before the Honorable, imC-mnrtfoom/Chambers No: 04 I 13 0 A. m` Distribution List: Francis J. Lafferty, IV, Esquire METZGER, WICKERSHAM, P.C. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 Attorney for Plaintiff Donald L. Carmelite, Esquire Marshall, Dennehey, Warner, Coleman & Goggin 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 Attorney for Defendants 05/499368.v 1 e0 picS ?12a1 LLL g/3 ?rrl r? F Tf " , ?. iAPY > ?C,99 ml `.i J ,-3 A" 11 rt. •2 c THERESE ROGERS, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., Individually and t/d/b/a/ VERSAMED, INC., DEFENDANTS NO. 06-7178 CIVIL ORDER OF COURT AND NOW, this 2nd day of September, 2009, upon consideration of the Status Conference held this date, IT IS HEREBY ORDERED AND DIRECTED that: 1. This matter is set down for the April 26, 2010 civil trial term. Counsel are considered attached for this trial term; 2. Fact discovery shall close on Friday, October 30, 2009; 3. Plaintiff's expert report(s) is due Wednesday, December 30, 2009; 4. Defendant's expert report(s) is due Monday, February 1, 2010; and 5. Any rebuttal report by Plaintiff is due Monday, February 15, 2010. By the Court, Francis J. Lafferty, IV, Esquire Attorney for Plaintiff 3211 North Front Street P. O. Box 5300 Harrisburg, PA 17110-0300 ,ADonald L. Carmelite, Esquire Attorney for Defendant 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 bas M. L. Ebert, Jr., J. COPI'Esmat 6L 4?a?? N - ci 14vq W OF THE `rl` " 2009 SEP -3 AM H• 1 E} CUM16 - I Y t THERESE ROGERS ORIGINAL COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PLAINTIFF/S VS. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., ET AL DEFENDANT/S COURT OF COMMON PLEAS NO. 06-7178 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 11119048 AS A PREREQUISITE TO SERVICE OF A SUBPOENA FOR DOCUMENTS AND THINGS PURSUANT TO RULE 4009.22, DEFENDANT 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 THAT WILL BE SERVED IS IDENTICAL TO THE SUBPOENA WHICH IS ATTACHED TO THE NOTICE OF INTENT TO SERVE THE SUBPOENA. DATE: 12/11/09 DONALD L.?ARMELITE, ESQ. ATTORNEY R DEFENDANT 01226-01286 1874663774 J42 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND THERESE ROGERS VS. PLAINTIFF/S COURT OF COMMON PLEAS EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., ET AL DEFENDANT/S NO. 06-7178 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: FRANCIS J. LAFFERTY, IV, ESQ. METZGER WICKERSHAM, P.C. 3211 N. FRONT ST. P.O. BOX 5300 HARRISBURG PA 17110 ATTORNEY(S) FOR PLAINTIFF 11119048 12/25/09 DEFENDANT INTENDS TO SERVE A SUBPOENA IDENTICAL TO THE ONE THAT IS ATTACHED TO THIS NOTICE TO THE DEPONENT/S LISTED BELOW, REQUESTING RECORDS BE PRODUCED AT RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., PHILADELPHIA, PA 19103. YOU HAVE TWENTY (20) DAYS FROM THE DATE LISTED BELOW IN WHICH TO FILE OF RECORD AND SERVE UPON THE UNDERSIGNED AND RECORD COPY SERVICES (215-241-5858), AN OBJECTION TO THE SUBPOENA. IF NO OBJECTION IS MADE THE SUBPOENA/S MAY BE SERVED. HOLY SPIRIT HOSPITAL FAMILY CARE OF LOWER PAXTON HEALTHSOUTH REHABILITATION AT HERSHEY REGIONAL ORTHOPEDIC ASSOCIATES, PC ARLINGTON ORTHOPEDIC CLINIC DR. SAMUEL F. GETTY, D.C. DR. WILLIAM A. ROLLE, JR., M.D. PRISM SUSQUEHANNA VALLEY SURGERY CENTER MILTON S. HERSHEY MEDICAL CENTER DATE: 11/13/09 DONALD L. CARMELITE, ESQ. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN 4200 CRUMS MILL RD. HARRISBURG PA 17112 ATTORNEY(S) FOR DEFENDANT XN 11119048 12/25/09 001*DNWF_ILTH OF pSYLVANTA COUNTY OF CLIGERUM THERESE ROGERS File No. VS. - EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., ET AL Court of Common Pleas 06-7178 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DIS00YERY PURSUANT TO RULE 4009.22 MEDICAL RECORDS DEPARTMENT HOLY TO: _rAmP HILLIPA 017011-22883 N. 21ST ST. (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 ADDENDUM at RrnRll oPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of ccrmliance, 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 tray seek a court order ocmpelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAPE: DONALD L. CARMELITE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPRE)+E COURT I D # ATTORNEY FOR: DEFENDANT DATE • 7L"t4j,., , It, , 2-tM 9 Seal of the Court ISSUED ON: 12/11/09 BY THE COURT: Prothonotary/C1 k, Civil Division Deputy (Eff. 7/97) NO. 06-7178 ADDENDUM TO SUBPOENA 11119048 12/25/09 THERESE ROGERS VS. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., ET AL SEE ATTACHED ADDENDUM PERTAINING TO THERESE ANN ROGERS (823B RHUEHAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). Instructions for medical records from Holy Spirit Hospital: Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x-ray films, MRls, CT scans, or other Diagnostic testing performed, together with all diagnostic reports, medical reports, notes, memoranda, correspondence and medical bills concerning Therese A. Rogers from January 2005 to the present; Date of Birth: 10/11/64; Social Security No. 154-68-9422. N 11119048 12/25/09 OF PENNSYLVANIA COUNTY OF C(]KBEFLADID THERESE ROGERS Vs.. File No. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., ET AL Court of Common Pleas 06-7178 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURWANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF FAMILY CARE OF LOWER PAXTON 2310 PATTON RD. TO: HARRISBURG PA 17112 (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of ca, liance, 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 camellirg you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DONALD L. CARMELITE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215 -5858 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT DATE : 74t,.?+a w /G CrU ¢ Seal of the Court ISSUED ON: 12/11/09 BY THE COURT: Prothonotary/Clark, Civil Division L 0, 1 Deputy (Eff. 7/97) NO. 06-7178 ADDENDUM TO SUBPOENA 11119048 12/25/09 THERESE ROGERS VS. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., ET AL SEE ATTACHED ADDENDUM PERTAINING TO THERESE ANN ROGERS (823B RHUEHAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). Instructions for medical records from Family Medicine Center: Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x-ray films, MRls, CT scans, or other diagnostic testing performed, together with all diagnostic reports, medical reports, notes, memoranda, correspondence and medical bills concerning Therese A. Rogers from December 2007 to the present; Date of Birth: 10/11/64; Social Security No. 154-68-9422. N 11119048 12/25/09 OF PENNSYLVANIA OOUNPY OF (RIGID THERESE ROGERS VS., File No. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., ET AL Court of Common Pleas 06-7178 SUBPOENA TO PRODUCE ooCI?ENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF HEALTHSOUTH REHABILITATION AT HERSHEY 555 E. CHOCOLATE AVE. TO: HERSHEY PA 17033 (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 ADDENDUM at -RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., 5-300, PHILADELPHIA, PA. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of ca, liance, 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 comp 1y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DONALD L. CARMELITE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT DATE : A-c d-..' , it, ztm 9 Seal of the Court ISSUED ON: 12/11/09 BY THE COURT: Prothon/o''t77 aryl/C l erk , Ci v i l D i v i s i on Deputy (Eff. 7/97) NO. 06-7178 ADDENDUM TO SUBPOENA 11119048 12/25/09 THERESE ROGERS VS. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., ET AL SEE ATTACHED ADDENDUM PERTAINING TO THERESE ANN ROGERS (823B RHUEHAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). Instructions for medical, records from HealthSouth Rehab - Hershey: : r':I . Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x-ray films,. MRIs, CT scans, or other,diagnostic testing performed, together with all diagnostic reports, medical report-4i notes,. memoranda, correspondence and medical Nils concerning Therese-A. Rogers from May 2005 to the present; Date of Birth: 10/11/64; Social Security No. 154-68-9422. N 11119048 12/25/09 COM,LTH OF pIIa1SYLVANIA couN 'Y OF CUMBERLAND THERESE ROGERS Vs. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., ET AL Court of Common Pleas 06-7178 File No. SUBPOENA TO PRODUCE D=J E.NTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF REGIONAL ORTHOPEDIC ASSOCIATES, PC P.O. BOX 629 TO: LEBANON PA 17042 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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of caspliance, 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 ccnpel ling you to cmp1y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DONALD L. CARMELITE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215 241-5858 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT DATE : 74V4114, 11. a trl? Seal of the Court 12/11/09 BY THE COURT : I/S.1 W Lma Prothonotary/C1 k, Civil Division L14A- Day (Eff. 1/97) ti NO. 06-7178 ADDENDUM TO SUBPOENA 11119048 12/25/09 THERESE ROGERS VS. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., ET AL SEE ATTACHED ADDENDUM PERTAINING TO THERESE ANN ROGERS (823B RHUEHAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). Instructions for medical records.from Regional Orthopedic Associates: Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x-ray films, MRls, CT scans, or otherAiagnostic.testing performed, together with all diagnostic reports, medical reports, notes, memoranda, correspondence and medical bills concerning Theresef A. Rogers from October 2005 to the present: Date of Birth: 10/1 UK Social Security No. 154-68-9422. i :41.3 . N 11119048 12/25/09 rr#&t1 WFWfflH OF PENNSYLVANIA OOEMY OF C( ID THERESE ROGERS Vs. File No. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., ET AL Court of Common Pleas 06-7178 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF ARLINGTON ORTHOPEDIC CLINIC 805 SIR THOMAS COURT TO: HARRISBURG PA 17109-5004 (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, . (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 ocmpe l l irg you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DONALD L. CARMELITE, ESQ. ADDRESS: TELEPHONE' FOR INFORMATION: (21 241-5858 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT DATE : owu Seal of the t ISSUED ON: 12/11/09 BY THE COURT: /s 1 Cry /?_ &.-& Prothonotary/01", Civil Division L12 Deputy (Eff. 7/97) NO. 06-7178 ADDENDUM TO SUBPOENA 11119048 12/25/09 THERESE ROGERS VS. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., ET AL SEE ATTACHED ADDENDUM PERTAINING TO THERESE ANN ROGERS (823B RHUEHAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). Instructions for medical records from Arlington Orthopedics: Any and all medical records, Incfubing, -but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x-ray films, MRIs, CT scans, or other diagnostic testing performed, together with all diagnostic reports, medical reports, notes, memoranda, correspondence and medical bills concerning Ther6s -X Rogers from June 2007 to the present; Date of Birth: 10/11/64; Social Security No. 154-68-9422. N 11119048 12/25/09 COMMONWE&I,T'H OF PIIa]S'YLVANIA COUNTY OF CUMBERIANID THERESE ROGERS Court of Common Pleas 06-7178 File No. VS. . EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, ' INC., ET AL ' SUBPOENA TO PRODUCE DOCLMITS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF DR. SAMUEL F. GETTY, D.C. 542 A BRIDGE ST. TO: NEW CUMBERLAND PA 17070 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you ore ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM at RRC:ORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. (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 ooampe l l irg you to camp l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DONALD L. CARMELITE, ESQ. ADDRESS: TELEPHONE' FOR INFORMATION: (215) 241-5858 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT DATE : 7b>OC4 /L, 20D 9 Seal of the Court ISSUED ON: 12/11109 BY THE COURT: Prothonotary/C1 k, Civil Division Deputy (Eff. 1/97) NO. 06-7178 ADDENDUM TO SUBPOENA 11119048 12/25/09 THERESE ROGERS VS. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., ET AL SEE ATTACHED ADDENDUM PERTAINING TO THERESE ANN ROGERS (823B RHUEHAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). Instructions for medical records from Samuel F. G®tty, D.C.: Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x-ray films, MRls, CT scans, or other diagnostic testing performed, together with all diagnostic reports, medical reports, notes, memoranda, correspondence and medical bills concerning Therese A. Rogers from July 2006 to the present; Date of Birth: 10/11/64; Social Security No. 154-68-9422. N 11119048 12/25/09 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBE1tiANID THERESE ROGERS Vs. File No. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., ET AL , Court of Common Pleas 06-7178 SUBPOENA To PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF DR. WILLIAM A. ROLLE, JR., M.D. PRISM TO: 4310 LONDONDERRY RD. S-106 BLOOM BUILDING HARR %MWM or verson or Entity Within twenty (20) days after service of this subpoena, you are ordered b SEE ATTACHED ADDENDUM Y the court to produce the following documents or things: at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. (Address) You may deliver or mail legible copies of the documents or produce thi this subpoena, together with the certificate of n3s requested by cal liance, 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 thins required (20) days after its service the g equired by this subpoena within twenty caripelling you to party serving this subpoena may seek a court order comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DONALD L. CARMELITE, ESQ. ADDRESS: TELEPHONE, FOR INFORMATION: (215)-2-4T-5858 SUPREME 000RT ID # ATTORNEY FOR: DEFENDANT DATE : 7?,orxrn /. - Seal of the ? Q t ISSUED ON: 12/11/09 BY THE COURT: s Prothonotary/C1 Civil Division U ? - Deputy (Eff. 7/97) NO. 06-7178 ADDENDUM TO SUBPOENA 11119048 12/25/09 THERESE ROGERS VS. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., ET AL SEE ATTACHED ADDENDUM PERTAINING TO THERESE ANN ROGERS (823B RHUEHAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). Instructions for medical records,from William A. Rolle, Jr.. M.DJPRISM: Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical theraipy records, rehab records, lab reports, x-ray films, MRls, CT scans, or oth,er,,;.¢iggnostic testing performed, together with all diagnostic reports, medical reports, notes, memoranda, correspondence and medical bills concerning Theres4:.A. Rogers from January 2006 to the present; Date of Birth: 10/11/64; Social Security No. 154-68-9422. J . N 11119048 12/25/09 COMMONWEALTH OF PFNVSYLVANIA ClOUNrY OF C UMBERLA ID THERESE ROGERS Vs. File No. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., ET AL Court of Common Pleas 06-7178 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF SUSQUEHANNA VALLEY SURGERY CENTER 4310 LONDONDERRY RD. TO: HARRISBURG PA 17109 (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, . (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of oat liance, 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 compel ling you to c ia, ly with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DONALD L. CARMELITE, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME OOURT ID # ATTORNEY FOR: DEFENDANT BATE: Atn'eti,?,c,ci 11. Seal of the C,burt ISSUED ON: 12/11/09 BY THE COURT: Prothonotary/Cl k, Civil Division c. Deputy (Eff. 7/97) NO. 06-7178 ADDENDUM TO SUBPOENA 11119048 12/25/09 THERESE ROGERS VS. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., ET AL SEE ATTACHED ADDENDUM PERTAINING TO THERESE ANN ROGERS (823B RHUEHAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). I r Instructions for medical records from Susquehanna Valley Surgery Center: Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical ttter9pPrecords, rehab records, lab reports, x-ray films, MRIs, CT scans, or other diagnostic testing performed, together with all diagnostic reports, medical reports; notes, memoranda, correspondence and medical bills concerning Therese A. Rogers from January 2006 to the present; Date of Birth: 10/11164; Social Security No. 154-68-9422. 7? SBXN 11119048 12/25/09 'THERESE ROGERS Vs. rr&&rwWFALTH OF PI NRMVANIA CO[3Nry OF C I93 BLAND EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., ET AL Court of Common Pleas 06-7178 File No. SUBPOENA TO PRODUCE DOCUMENTS OR TH I NOS FOR DISCOVERY PURSUANT TO RULE 4009.22 MEDICAL RECORDS DEPARTMENT PILTO MILTON S. 8 HERSHEY EDP AL CENTER 500 UNIVERSITY DR. TO: (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, . (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of ompliance, 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 pr"ce 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 carpel l ir:g you to camp ly with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME DONALD L. CARMELITE, ESQ. ADDRESS: FOR INFORMATION: - 858 TELEPHONE: SUPREME COURT I D # ATTORNEY FOR: DEFENDANT DATE: It. x700 Seal of the (Urt T ISSUED ON: 12/11/09 BY THE COURT: s ' Prothonotary/C1 , Civil Division Deputy (Eff. 7/97) NO. 06-7178 ADDENDUM TO SUBPOENA 11119048 12/25/09 THERESE ROGERS VS. EYAL DIOR AND VERSAMED MEDICAL SYSTEMS, INC., ET AL SEE ATTACHED ADDENDUM PERTAINING TO THERESE ANN ROGERS (823B RHUEHAUS LANE, HUMMELSTOWN, PA, DOB 10/11/64, SSN 154-68-9422). i Instructions for medical records from Penn State Hershey Medical Center: Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x-ray films, MRIs, CT scans, or other diagnostic testing performed, together with all diagnostic reports, medical repor4s; notes, memoranda, correspondence and medical bills concerning Therest A. Rogers from September 2008 to the present; Date of Birth: 10/11164; Social Security-No. 154-68-9422. ,.7 . CERTIFICATE OF SERVICE I, Susan M. Williams, an employee with the law firm of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this °t'?N day of December, 2009, I served a true and correct copy of the Certificate-Prerequisite to Service of Subpoenas Pursuant to Rule 4009.22, via U.S. first-class mail, postage pre-paid, as follows: Francis J. Lafferty, IV, Esquire METZGER, WICKERSHAM, P.C. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 Y _ , a4-4 _4 D SUSAN M. WILLIAMS F EU LJLr4^t-_ -,. ? , ???.1 L?o CA ORIGINAL THERESE ROGERS, V. EYAL DIOR and VER! MEDICAL SYSTEMS, Individually and t/d/b/a INC., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ° D NO. 06-7178 Civil Term ? rv AMED, w ?a Defendants JURY TRIAL DEMANDED = y n rn 4 TO THE PROTHONOTAR : Please remove the AN been settled by the parties. case from the April 2010 Trial Term as this case has Respectfully submitted, WARNER, COLF.POIAN & DATE: 31 ITI (0 BY: 1?99ALIY-t -?MELITE, ESQUIRE I.D. No. 84730 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3504 Attorney for Defendants CERTIFICATE OF SERVICE I, Susan M. W an employee with the law firm of Marshall, Dennehey, Warner, Coleman& Goggin, do hereby certify that on this 114'1 day of March, 2010, I served a true and correct copy of the class mail, postage pre-paid, Francis J. Lafferty, IV, Esqu METZGER, WICKERSHAT 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 to Remove Case from April 2010 Trial Term, via U.S. first- follows: P.C. SUSAN M. WILLIAMS M % METZGER, WICKERSHAM, P.C. By: Francis J. Lafferty, IV, Esquire Attorney I.D. No. 84009 3211 North Front Street P.O. Box 5300 Harrisburg, PA 171 10-0300 (717) 238-8187 RED- fRCE OF THE PROCTHON`OTARY 2010 MAIR 24 PH 1: 30 Attorneys for P1wf_ '.: Therese Rogers THERESE ROGERS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 06-7178 CIVIL ACTION - LAW EYAL DIOR and VERSAMED MEDICAL SYSTEMS, INC., individually and t/d/b/a JURY TRIAL DEMANDED VERSAMED, INC. Defendants PRAECIPE TO SETTLE DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above captioned matter settled, discontinued and ended. & ERB, P.C. By: Dated 11 Fidncis J. Lafferif, AV, Esquire Attorney I.D. No. 84009 P.O. Box 5300 3211 North Front Street Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiff 440034-1 J, y CERTIFICATE OF SERVICE I, Francis J. Lafferty, IV, of the law firm of Metzger, Wickersham, Knauss & Erb, P.C., hereby certify that I served a true and exact copy of the foregoing document with reference to the foregoing action by first class mail, postage prepaid, this 23?d day of March, 2010, on the following: Donald L. Carmelite MARSHALL, DENNEHEY, COLEMAN & GOGGIN 4200 Crums Mill Rd., Ste. B Harrisburg, Pa 17112 WARNER 440034-1