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HomeMy WebLinkAbout02-3085 , AMY REBEKAH DERRICK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO,O:l_JoRS'CIVlLTERM v, GIANT FOOD STORES, INC" Defendant : CIVlLACTlON - LAW PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Kindly issue a writ of summons in the above-captioned action, AMY REBEKAH DERRICK, Plaintiff v, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO,o~ -~ CIVIL TERM GIANT FOOD STORES, INC" Defendant : CIVIL ACTION - LAW To: Giant Food Stores, Inc, 1149 Harrisburg Pike Carlisle, PA 17013 You", h,reby not;fi" that Amy Reb'kah D,,,,,. ,"" ~mm'n~' 'n ,ct;on against you. WRIT OF SUMMONS F:\FILES\DA TAFILE\Macdoc.cur\208-pra l/cny Created: 07/12/0211:40:51 AM Revised: 07/12102 11:59:34 AM 9500.208 AMY REBEKAH DERRICK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 02-3085 CIVIL ACTION-LAW GIANT FOOD STORES, INC., Defendant JURY TRIAL OF TWELVE DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTSON DEARDORFF WILLIAMS & OTTO on behalf of Defendant Giant Food Stores, Inc. in the above matter and issue a rule upon the Plaintiffs to file a Complaint within twenty (20) days from service thereof or suffer judgment of non pros. Defendant hereby demands a twelve juror jury trial in the above captioned action. MAR?/DEARDORFF WILLIAMS & OTTO By i!? George B. Fa ler, Jr., Esq LD. No. 49813 Ten East High Street Carlisle, P A 17013 (717) 243-3341 Dated: July 1B, 2002 Attorneys for Defendant Giant Food Stores, Inc, RULE AND NOW, this/nay of ~ ' 2002, a Rule is issued upon the Plaintiff to file a Complaint within twenty (20) days from service hereof. 15( ~.~~ Prothonotary ~<'~~k~rM CERTIFICATE OF SERVICE I, Christina N. Yost, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Amy Rebekah Derrick 387 North 19th Street Camp Hill, P A 17011 MARTSON DEARDORFF WILLIAMS & OTTO By ~"-~ II. '2!:.,r Christina N. Yost (j Ten East High Street Carlisle, P A 17013 (717) 243-3341 Dated: July 1 i 2002 0 l=' (-) ~ r....) .'h S- S:: ""'Dee; '-- rnrr ,- -"7 .....,..--, .A-- ~.,)...- ZC c:; (f) "c' -</ t;: CJ' -""(I -:::~l ;i> _.It',. ---~I ;sf':'; -. C) :...) en J>r- --' -.~ /- :.11 5.J :<! (J1 -< SHERIFF'S RETURN - REGULAR CASE NO: 2002-03085 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DERRICK AMY REBEKAH VS GIANT FOOD STORES INC BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon GIANT FOOD STORES INC the DEFENDANT , at 1325:00 HOURS, on the 9th day of July at 1149 HARRISBURG PIKE , 2002 CARLISLE, PA 17013 by handing to RUTH ANN FREDERICK RECEPTIONIST a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.45 .00 10.00 .00 31.45 ~~~~ R. Thomas Kline 07/10/2002 AMY DERRICK Sworn and Subscribed to before By: me this cJ...."...( day of ~'''~ ~A.D. ~,;:thonotary J~ } l ~ ~ R~ -. ~ 8 6 ?-J f' I ...J p::b Cv ~ ~ 9; is (") c :;::: ""1Jl";:J nlf1\ 2~ U),'.-,_. :::...(,,.t. r-:C-.' ~- ~~~>, J>c: "-;;Y :'''1 ~- o N L- c:: Z o -n N ~ -.TI :.';'~ ",'(.=!) ': c') ~jn-'. ~ :0 -< -G ~ ':i' ::Y (J"' , , AMY REBEKAH DERRICK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-3085 CIVIL TERM v. GIANT FOOD STORES, INC., Defendant : CIVIL ACTION - LAW NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717)-249-3166 AMY REBEKAH DERRICK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3085 CIVIL TERM v. GIANT FOOD STORES, INC., Defendant CIVIL ACTION - LAW COMPLAINT I. Plaintiff, Amy Rebekah Derrick, is an adult individual currently residing at 1200 Riverside Drive, No. 384, Burbank, Califomia 91506. 2. Defendant, Giant Food Stores, Inc., is a foreign corporation organized and existing under the laws of a state other than the Commonwealth of Pennsylvania, which conducts business within Pennsylvania and which has as its principal place of business 1149 Harrisburg Pike, Carlisle, Cumberland County, Pennsylvania 17013. 3. On or about July 6, 2000, defendant was the owner of the certain premises located at 700 Camp Hill Shopping Plaza, Camp Hill, Cumberland County, Pennsylvania. 4. At all relevant times hereto, defendant Giant Food Stores, Inc. was in exclusive custody, possession and control of said premises, and it was the duty of said defendant to keep and maintain these premises in a reasonably safe condition for those persons lawfully thereon. 5. On or about July 6, 2000, at approximately 9:00 a.m., plaintiff Amy Rebekah Derrick was an invitee at the aforesaid premises. 6. As plaintiff was walking along the front section of the store approaching a checkout line plaintiff's foot stepped in a foreign pink liquid substance which was on the floor surface and which caused the plaintiff to suddenly and without warning slip and fall toward the floor, suffering severe and serious injuries, which are herein after more fully set forth. 7. The aforesaid slip and fall suffered by the plaintiff was caused by the negligence, carelessness and/or recklessness of the defendant acting individually and/or by and through its agents (ostensible, apparent and/or actual), servants, workman and/or employees and consisting inter allia, of the following: a. Carelessly and negligently allowing and permitting the foreign substance to exist on the floor surface; b. Carelessly and negligently allowing and permitting the floor surface to exist in this dangerous condition; c. Negligently creating this dangerous condition on the floor surface; d. Failing to maintain the floor surface in a safe and proper condition; e. Failing to regularly inspect the floor condition so as to insure that it was in a proper and safe condition; f. Failing to warn and/or notify plaintiff of the existence of the pink foreign substance on the floor surface; g. Failing to remedy the dangerous condition caused by the substance on the floor surface; h. Failing to provide a safe floor surface for pedestrian travel inside the store. 8. As a result of the negligence, carelessness and/or recklessness of the defendant as aforesaid, the plaintiff, Amy Rebekah Derrick, was caused to suffer serious and permanent personal injuries, including but not limited to, severe thoracic spine sprain/strain, severe lumbar spine sprain/strain, lumbar disk desiccation and disk protrusion, severe back pain, decreased range of motion, and other injuries to her muscles, nerves and bones in her back. 9. As a result of the negligence, carelessness and/or recklessness of the defendant as aforesaid, the plaintiff has been caused to expend various sums of money for medical treatment and will be required to expend additional sums for medical treatment in the future for these injuries. 10. As a result of the negligence, carelessness and/or recklessness of the defendant as aforesaid, plaintiff has been caused to lose wages which she would have earned but for these injuries, and will continue to lose wages in the future. II. Plaintiff's quality of life has been negatively impacted as a result of the injuries suffered. WHEREFORE, plaintiff, Amy Rebekah Derrick, claims damages from the defendant Giant Food Stores, Inc. in an amount in excess of the mandatory arbitration limits, plus court costs and such other fees as the law may allow. Respectfully submitted, If)ff~ R. Mark Thomas, Esquire ID# 41301 101 S. Market Street Mechanicsburg, P A 17055 (717) 796-2100 . . VERIFICATION I, R. Mark Thomas, Esquire, attorney for the plaintiff Amy Rebekah Derrick, hereby state that the plaintiff Amy Rebekah Derrick is currently living in California and is not available to sign this verification in her own right. The averments contained within this Complaint have been reviewed and discussed with the plaintiff and based upon the information given to me by the plaintiff I hereby verify that I have sufficient information and belief to state that these averments are true and correct. This verification is being made with full knowledge that false statements contained herein can give rise to criminal charges under 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. Date: ~,.;(~ ;CV~ /J:rJ~ R. Mark Thornas, Esq. >- C) ~ cr; c "" I.-~ co ?<< C) UJ - ~~:;.. :-'2z ( J~,,,,. ~ '-.....J -d' cC':--:::' .......- .:) ::J 1..L_ ;,.1 ~e;;':~ (;.) (:0 a ;';6;) 6v~ C"; ..:):z: U,jL~;,_ !:~;d5 ='lU CJJ loLl: --, co a.. ;- ;;:( :::i: U- N a 0 0 F:\FILES\DA T AFILE\Macdoc.cur\208-ans.1/tdelcny Created: 07/12/0211:40:51 AM . Revised: 09/25/02 02:40:34 PM 9500.208 AMY REBEKAH DERRICK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 02-3085 CIVIL ACTION-LAW GIANT FOOD STORES, INC., Defendant JURY TRIAL OF TWELVE DEMANDED DEFENDANT'S ANSWER TO PLAINTIFF'S COMPLAINT 1. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth or falsity of the averments contained in this paragraph. 2. Denied as stated. To the contrary, Giant Food Stores, Inc. is a predecessor in interest to Giant Food Stores, LLC, a Delaware Limited Liability Company, with a principal place of business at 1149 Harrisburg Pike, Carlisle, Cumberland County, Pennsylvania. 3. Denied. To the contrary, see the averments stated in Paragraph 2. By way of further response, the premises at 1700 Camp HilI Shopping Plaza, Camp HilI, Cumberland County, Pennsylvania is owned by Camp HilI Shopping Plaza, 32nd Street and Trind1e Road, Camp HilI, Pennsylvania, 17011. 4. Denied. To the contrary, see the averments stated in Paragraphs 2 and 3. 5-11. Denied pursuant to Pa. RC.P. 1029 (e). WHEREFORE, Defendant demands judgement in its favor and disrnissal of Plaintiff's Complaint with prejudice. By Ge r, Jr., J.D. No. 49813 Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Defendant Dated: Septernber 25, 2002 I . VERIFICATION I, TIMOTHY REARDON, Vice President-Risk Management and Support Services of Giant Food Stores, LLC, acknowledge that I have the authority to execute this Verification on behalf of Giant Food Stores, LLC and certify that the foregoing Answer is based upon information which has been gathered by my counsel in the preparation of this lawsuit. The language of this Answer is that of counsel and not my own. I have read the document and to the extent that this Answer is based upon information which I have given to my counsel, it is true and correct and to the best of my knowledge, information and belief. To the extent that the content of this Answer is that of counsel, I have relied upon counsel in making this Verification. This statement and Verification are made subject to the penalties of 18Pa. C.S. ~ 4904 relating to unsworn falsification to authorities, which provides that if I knowingly make false averments, I rnay be subject to criminal penalties. Giant Food Stores, LLC ~ ~hYReardon ice President - Risk Mgt. & Support Services Dated: 'J /;"5 If) 2- F:\FILES\DA TAFILE\Macdoc.cur\208-ans.1 . - \ ~ECE'VEL SEP 1 7 2002 l\IIDwr ", CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Answer was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: R. Mark Thornas, Esquire 101 South Market Street Mechanicsburg, PA 17055 MARTSON DEARDORFF WILLIAMS & OTTO aD. Eckenroad East High Street Carlisle, PA 17013 (717) 243-3341 Dated: September 25, 2002 (J c: s: "Un:: qJL;-! ","--,,-) zC <n " ~6 <: ~o >8 ~ o 1'..:.'1 o -r; i~"n 0-' 'F: ~,_:~1~ " 'r"' '--:ttJ ;~~ "'~-rn g ~ -< :.J) rT1 ." N en ;Do ::x U'I ... CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS AMY REBEKAH DERRICK TERM, -VS- CASE NO: 02-3085 GIANT FOOD STORES, INC. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GEORGE FALLER, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: OS/20/2004 ~n behuta.U jJ , E GkLa~, ES~ CU. Atto y for DEFE~NT 7 DEll-493796 51732 -LO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS AMY REBEKAH DERRICK TERM, -VS- CASE NO: 02-3085 GIANT FOOD STORES, INC. NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: R. MARK THOMAS, ESQ., PLAINTIFF COUNSEL MCS on behalf of GEORGE FALLER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no Objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 04/30/2004 MCS on behalf of GEORGE FALLER, ESQ. Attorney for DEFENDANT CC: GEORGE FALLER, ESQ. - 9500-208 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-264468 51732 -CO 1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED BURBANK EMERGENCY MEDICAL WEST VALLEY ORTHO & SPORTS MED VARON CHIROPRACTIC CENTER UNIVERSITY IMAGING CENTER RADIO GRAPHICS MEDICAL TOLUCA LAKE HEALTH CENTER DR. MARY JO SZADA JAMES F. DALEY, JR., M.D. MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & lULLING MEDICAL RECORDS & lULLING DE02-264468 51732 - CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND AMY REBEKAH DERRICK FileNo. 02-3085 vs. GIANT FOOD STORES, INC. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for BURBANK EMERGENCY MEDICAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at TheMCSGroun Inc 1601 Market Street Suite 800 Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: GEORGE FALLER. ESO. 10 E. HIGH STREET CARLISLE. PAl 7013 TELEPHONE: (215) 246-0900 SUPREME COURT lD #: ATTORNEY FOR: Defendant BY THE COURT: A Prothonotary/Clerk, Civi Divisi L&l Deputy '--- Date: ilpa-d ;,)71 ,2('Jar Seal of the Court 51732-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: BURBANK EMERGENCY MEDICAL P.O. BOX 307 IDYLLWILD, CA 92549 RE: 51732 AMY REBEKAH DERRICK INCLUDE STATEMENT OF ACCOUNTS Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical and billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication! prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: AMY REBEKAH DERRICK 1200 RIVERSIDE DRIVE, BURBANK, CA 91506 Social Security #: 174-54-3435 Date of Birth: 09-03-1974 SU10-501666 51732 -LO 1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS AMY REBEKAH DERRICK TERM, -VS- CASE NO: 02-3085 GIANT FOOD STORES, INC. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GEORGE FALLER, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: OS/20/2004 GEORGE ~ALLER, ESQ. Attorney for DEFENDANT DEll-493797 51732 -LO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS AMY REBEKAH DERRICK TERM, -VS- CASE NO: 02-3085 GIANT FOOD STORES, INC. NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: R. MARK THOMAS, ESQ., PLAINTIFF COUNSEL MCS on behalf of GEORGE FALLER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 04/30/2004 MCS on behalf of GEORGE FALLER, ESQ. Attorney for DEFENDANT CC: GEORGE FALLER, ESQ. - 9500-208 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 I1E02-264468 51732 - C 01 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED BURBANK EMERGENCY MEDICAL WEST VALLEY ORTHO & SPORTS MED VARON CHIROPRACTIC CENTER UNIVERSITY IMAGING CENTER RADIO GRAPHICS MEDICAL TOLUCA LAKE HEALTH CENTER DR. MARY JO SZADA JAMES F. DALEY, JR., M.D. MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING llE02-26446851732-C01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND AMY REBEKAH DERRICK FileNo. 02-3085 vs. GIANT FOOD STORES, INC. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for WEST V ALLEY ORTHO & SPORTS MED (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group Inc 1601 Market Street Suite 800 Philadelnhia P A 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: GEORGE FALLER. ESO. 10 E HIGH STREET CARLISLE.PA 17013 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: --L Prothonotary/Clerk, Civil Divisio '-- 4A,o..,- --'~ .71fAu1. / Deputy Date: t:JpnlL .2/, )."OO'{ Seal of the Court 51732-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: WEST VALLEY ORTHO & SPORTS MED 1220 LA VENTE DRIVE SUITE 202 WESTLAKE VILLAGE, CA 91502 RE: 51732 AMY REBEKAH DERRICK INCLUDE STATEMENT OF ACCOUNTS Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical and billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication! prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: AMY REBEKAH DERRICK 1200 RIVERSIDE DRIVE, BURBANK, CA 91506 Social Security #: 174-54-3435 Date of Birth: 09-03-1974 SU10-501668 51732 -La 2 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS AMY REBEKAH DERRICK TERM, -VS- CASE NO: 02-3085 GIANT FOOD STORES, INC. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GEORGE FALLER, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the Eiubpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: OS/20/2004 GEORGE FALLER, ESQ. Attorney for DEFENDANT DEll-493798 51732 -La 3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS AMY REBEKAH DERRICK TERM, -VS- CAS E NO: 02 - 3 085 GIANT FOOD STORES, INC. NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: R. MARK THOMAS, ESQ., PLAINTIFF COUNSEL MCS on behalf of GEORGE FALLER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 04/30/2004 MCS on behalf of GEORGE FALLER, ESQ. Attorney for DEFENDANT CC: GEORGE FALLER, ESQ. - 9500-208 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 {215} 246-0900 DE02-264468 51732 - C 0 1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED BURBANK EMERGENCY MEDICAL WEST VALLEY ORTHO & SPORTS MED VARON CHIROPRACTIC CENTER UNIVERSITY IMAGING CENTER RADIO GRAPHICS MEDICAL TOLUCA LAKE HEALTH CENTER DR. MARY JO SZADA JAMES F. DALEY, JR., M.D. MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING IlE02-264468 51732-C01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND AMY REBEKAH DERRICK File No. 02-3085 vs. GIANT FOOD STORES, INC. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for VARON CHIROPRACTIC CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS GrO\~p IDe 1601 Market Street Suite 800 Philadelphia P A 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: GEORGE FALLER. ESO. 10 E HIGH STREET CARLISLE. PA ]7013 TELEPHONE: (215) 246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant BY THE COURT: A Prothonotary/Clerk, Civil '--- ~ lko.. ~ .Q 7fa4dIJ Deputy Date: t)ntti:L :l? :::/'/">/1' I I Seal of the Court 51732-03 EXPLANATION OF REQUIRED RJIi:CORDS TO: CUSTODIAN OF RECORDS FOR: VARON CHIROPRACTIC CENTER 360 EAST OLIVE AVENUE BURBANK, CA 91502 RE: 51732 AMY REBEKAH DERRICK INCLUDE STATEMENT OF ACCOUNT Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical and billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication! prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: AMY REBEKAH DERRICK 1200 RIVERSIDE DRIVE, BURBANK, CA 91506 Social Security #: 174-54-3435 Date of Birth: 09-03-1974 SU10-501670 51732-L03 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS AMY REBEKAH DERRICK TERM, -VS- CASE NO: 02-3085 GIANT FOOD STORES, INC. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GEORGE FALLER, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: OS/20/2004 GEORGE FALLER, ESQ. Attorney for DEFENDANT DEll-493799 51732 -LO 4 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS AMY REBEKAH DERRICK TERM, -VS- CASE NO: 02-3085 GIANT FOOD STORES, INC. NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: R. MARK THOMAS, ESQ., PLAINTIFF COUNSEL MCS on behalf of GEORGE FALLER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 04/30/2004 MCS on behalf of GEORGE FALLER, ESQ. Attorney for DEFENDANT CC: GEORGE FALLER, ESQ. - 9500-208 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-264468 51732 - C 01 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED BURBANK EMERGENCY MEDICAL WEST VALLEY ORTHO & SPORTS MED VARON CHIROPRACTIC CENTER UNIVERSITY IMAGING CENTER RADIO GRAPHICS MEDICAL TOLUCA LAKE HEALTH CENTER DR. MARY JO SZADA JAMES F. DALEY, JR., M.D. MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS .. BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS .. BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING DE02-264468 51732 - C 01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND AMY REBEKAH DERRICK FileNo. 02-3085 vs. GIANT FOOD STORES, INC. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for UNIVERSITY IMAGING CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS GroUD Ine 1601 Market Street Suite 800 Philadelnhia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: GEORGE FALLER. ESO. 10 E HIGH STREET CARLISLE. P A 17013 TELEPHONE: (215) 246-0900 SUPREME COURT lD #: ATTORNEY FOR: Defendant BY THE COURT: A Prothonotary/Clerk, Civil IVISIO '-- Aj~-J ~.7fCJV2<~ Deputy Date: /J.pll i. L .J.. 7, ::U~ Seal of the Court 51732-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: UNIVERSITY IMAGING CENTER 14915 BURBANK BOULEVARD SHERMAN OAKS, CA 91411 RE: 51732 AMY REBEKAH DERRICK INCLUDE STATEMENT OF ACCOUNT Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical and billing f11e including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, f11es, memoranda, handwritten notes, history and physical reports, medication! prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: AMY REBEKAH DERRICK 1200 RIVERSIDE DRIVE, BURBANK, CA 91506 Social Security #: 174-54-3435 Date of Birth: 09-03-1974 8U10-501672 51732-L04 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS AMY REBEKAH DERRICK TERM, -VS- CASE NO: 02-3085 GIANT FOOD STORES, INC. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GEORGE FALLER, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: OS/20/2004 GEORGE FALLER, ESQ. Attorney for DEFENDANT DEll-493800 51732-L05 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS AMY REBEKAH DERRICK TERM, -VS- CAS E NO: 02 - 3085 GIANT FOOD STORES, INC. NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: R. MARK THOMAS, ESQ., PLAINTIFF COUNSEL MCS on behalf of GEORGE FALLER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 04/30/2004 MCS on behalf of GEORGE FALLER, ESQ. Attorney for DEFENDANT CC: GEORGE FALLER, ESQ. - 9500-208 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-264468 51732 - C 01 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED BURBANK EMERGENCY MEDICAL WEST VALLEY ORTHO & SPORTS MED VARON CHIROPRACTIC CENTER UNIVERSITY IMAGING CENTER RADIO GRAPHICS MEDICAL TOLUCA LAKE HEALTH CENTER DR. MARY JO SZADA JAMES F. DALEY, JR., M.D. MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING DE02-264468 51732-C01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND AMY REBEKAH DERRICK FileNo. 02-3085 vs. GIANT FOOD STORES, INC. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for RADIO GRAPHICS MEDICAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS GrO\~p Ine 1601 Market Street Suite 800 Phi]ade]nhia PA ]9103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: GEORGE FALLER. ESO. 10 E. HIGH STREET CARLISLE. PA 17013 TELEPHONE: (215) 246-0900 SUPREME COURT lD #: ATTORNEY FOR: Defendant '--- Date: --1lpn.i.l ;),7\ :)r~'f Seal of the Court Deputy 51732-05 EXPLANATION OF REQUIRED RJ~CORDS TO: CUSTODIAN OF RECORDS FOR: RADIO GRAPHICS MEDICAL MEDICAL GROUP, INC. 949 SOUTH GODDRICH LOS ANGELES, CA 900224116 RE: 51732 AMY REBEKAH DERRICK INCLUDE STATEMENT OF ACCOUNT Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical and billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication! prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: AMY REBEKAH DERRICK 1200 RIVERSIDE DRIVE, BURBANK, CA 91506 Social Security #: 174-54-3435 Date of Birth: 09-03-1974 SUlO-501674 51732 -LO 5 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS AMY REBEKAH DERRICK TERM, -VS- CASE NO: 02-3085 GIANT FOOD STORES, INC. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GEORGE FALLER, ESQ. certifies that (11 A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: OS/20/2004 GEORGE FALLER, ESQ. Attorney for DEFENDANT DEll-493801 51732 -LO 6 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS AMY REBEKAH DERRICK TERM, -VS- CASE NO: 02-3085 GIANT FOOD STORES, INC. NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: R. MARK THOMAS, ESQ., PLAINTIFF COUNSEL MCS on behalf of GEORGE FALLER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 04/30/2004 MCS on behalf of GEORGE FALLER, ESQ. Attorney for DEFENDANT CC: GEORGE FALLER, ESQ. - 9500-208 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-264468 51732 - CO 1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED BURBANK EMERGENCY MEDICAL WEST VALLEY ORTHO & SPORTS MED VARON CHIROPRACTIC CENTER UNIVERSITY IMAGING CENTER RADIO GRAPHICS MEDICAL TOLUCA LAKE HEALTH CENTER DR. MARY JO SZADA JAMES F. DALEY, JR., M.D. MEDICAL RECORDS & EILLING MEDICAL RECORDS & EILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & HILLING MEDICAL RECORDS &0 BILLING IlE02-264468 51732 - C 01 COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND AMY REBEKAH DERRICK FileNo. 02-3085 vs. GIANT FOOD STORES, INC. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for TOLUCA LAKE HEALTH CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Groun Ine 1601 Market Street Suite 800 Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: GEORGE FALLER. ESO. 10 E HIGH STREET CARLISLE PA 17013 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: ~ Prothonotary/Clerk, Civil Divisi ~ Deputy '--- Date: tJpn:L L .), 7 { .:taJY Seal of the Court 51732-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: TOLUCA LAKE HEALTH CENTER 4323 RIVERSIDE DRIVE BURBANK, CA 91505 RE: 51732 AMY REBEKAH DERRICK INCLUDE STATEMENT OF ACCOUNT Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical and billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication! prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any eXamIDation, consultation, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: AMY REBEKAH DERRICK 1200 RIVERSIDE DRIVE, BURBANK, CA 91506 Social Security #: 174-54-3435 Date of Birth: 09-03-1974 S'iJ10-501676 51732-L06 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS AMY REBEKAH DERRICK TERM, -VS- CASE NO: 02-3085 GIANT FOOD STORES, INC. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GEORGE FALLER, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: OS/20/2004 GEORGE PALLER, ESQ. Attorney for DEFENDANT DEll-493802 51732 - L 07 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS AMY REBEKAH DERRICK TERM, -VS- CASE NO: 02-3085 GIANT FOOD STORES, INC. NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: R. MARK THOMAS, ESQ., PLAINTIFF COUNSEL MCS on behalf of GEORGE FALLER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 04/30/2004 MCS on behalf of GEORGE FALLER, ESQ. Attorney for DEFENDANT CC: GEORGE FALLER, ESQ. - 9500-208 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-264468 51732 - C 01 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED BURBANK EMERGENCY MEDICAL WEST VALLEY ORTHO & SPORTS MED VARON CHIROPRACTIC CENTER UNIVERSITY IMAGING CENTER RADIO GRAPHICS MEDICAL TOLUCA LAKE HEALTH CENTER DR. MARY JO SZADA JAMES F. DALEY, JR., M.D. MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING DE02-264468 51732 - C 01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND AMY REBEKAH DERRICK FileNo. 02-3085 vs. GIANT FOOD STORES, INC. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. MARY JO SZADA (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at TheMCSGrouo Ine ]60] Market Street Sllite800 Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: GEORGE FALLER. ESO. 10 E. HIGH STREET CARLISLE. PAl 70 13 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant '---- Date: rJtfi-l ( ,J? ( ') oay Seal of the Court 51732-07 EXPLANATION OF REQUIRED RJ[CORDS TO: CUSTODIAN OF RECORDS FOR: DR. MARY JO SZADA 381 S. FRONT STREET STEELTON, PA 17013 RE: 51732 AMY REBEKAH DERRICK INCLUDE STATEMENT OF ACCOUNT Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical and billing fIle including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports" medication! prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: AMY REBEKAH DERRICK 1200 RIVERSIDE DRIVE, BURBANK, CA 91506 Social Security #: 174-54-3435 Date of Birth: 09-03-1974 SU10-501678 51732 -LO 7 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS AMY REBEKAH DERRICK TERM, -VS- CASE NO: 02-3085 GIANT FOOD STORES, INC. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GEORGE FALLER, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on :oehalf of DATE: OS/20/2004 GEORGE FALLER, ESQ. Attorney for DEFENDANT DEll-493803 51732-LOa COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS AMY REBEKAH DERRICK TERM, -VS- CASE NO: 02-3085 GIANT FOOD STORES, INC. NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: R. MARK THOMAS, ESQ., PLAINTIFF COUNSEL MCS on behalf of GEORGE FALLER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 04/30/2004 MCS on behalf of GEORGE FALLER, ESQ. Attorney for DEFENDANT CC: GEORGE FALLER, ESQ. - 9500-208 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-264468 51732 - C 0 1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED BURBANK EMERGENCY MEDICAL WEST VALLEY ORTHO & SPORTS MED VARON CHIROPRACTIC CENTER UNIVERSITY IMAGING CENTER RADIO GRAPHICS MEDICAL TOLUCA LAKE HEALTH CENTER DR. MARY JO SZADA JAMES F. DALEY, JR., M.D. MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING IlE02-264468 51732 - C 01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND AMY REBEKAH DERRICK FileNo. 02-3085 vs. GIANT FOOD STORES, INC. SUBPOENA TO PRODUCE DOCUMENTS lOR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JAMES F DALEY JR MD. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group Ine 1601 Market Street Suite 800 Philadelnhia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: GEORGE FALLER. ESO. 10 E. HIGH STREET CARLISLE PA 17013 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: A Prothonotary/Clerk, C- L21~D P .c.m." ~_u Deputy ~~ ~ Date: tlpll..LL :1., ( )..1Ja'f Seal ofthe Court 51732-08 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JAMES F. DALEY, JR., M.D. 2025 TECHNOLOGY PARKWAY SUITE 108 MECHANICSBURG, PA 17055 RE: 51732 AMY REBEKAH DERRICK INCLUDE STATEMENT OF ACCOUNT Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical and billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, flles, memoranda, handwritten notes, history and physical reports, medication! prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: AMY REBEKAH DERRICK 1200 RIVERSIDE DRIVE, BURBANK, CA 91506 Social Security #: 174-54-3435 Date of Birth: 09-03-1974 SU10-501680 51732-LOB ("'I ~~ i:'" <:,:,:) .<c' o -n .-j -,- .'." -;~ r,) C) ~.' CERTIFICATE PREREQUISITE TO SERVICE OF A SlffiPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS AMY REBEKAH DERRICK TERM, -VS- CASE NO: 02-3085 GIANT FOOD STORES, IfoJC, AS a prerequisite to service of a subpoena for documents and things pursuant. to Rule 4009.22 MCS on behalf of GEORGE FALLER, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on whiCh the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena. is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: OS/20/2004 DEll-49380451734_L01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS AMY REBEKAH DERRICK TERM, -VS- CASE NO: 02-3085 GIANT FOOD STORES, rNC, NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 SCREEN ACTORS GUILD PENSION & INSURANCE TO: R. MARK THOMAS, ESQ., PLAINTIFF COUNSEL MCS on behalf of GEORGE FALLER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 04/30/2004 MCS on behalf of GEORGE FALLER, ESQ. Attorney for DEFENDANT CC: GEORGE FALLER, ESQ. - 9500 -208 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DECl2-26446951734_C01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLANI! AMY REBEKAH DERRICK FileNo. 02-3085 vs. GIANT FOOD STORES, r tJC , SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for SCREEN ACTORS GUILD PENSION & (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at TheMCSGroqp Tne ]601 Market Street Sllite800 Philadelnhia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing: the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: GEORGE FALLER. ESO. 10 E HIGH STREET CARLISLE P A ] 7013 TELEPHONE: 12]5) 246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant Date: ~l ;:;)/'.':> 6t'~r Seal of the Court BY?f ~)UR~: Prothonotary/Clerk, Civil Division '- ~2~.,P. Deputy 51734-01 EXPLANA TION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SCREEN ACTORS GUILD PENSION & HEALTH-P.O. BOX 7830 3501 W. OLIVE AVE. BURBANK, CA 915107830 RE: 51734 AMY REBEKAH DERRICK Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all insurance records and PIP files, including but not limited to medical reports and/or records, claims, any and all correspondence, documentation supporting plaintiff's claim, payments including dates of payments, payee and reasons for payments, including any and all !mch items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject: AMY REBEKAH DERRICK 1200 RIVERSIDE DR., BURBANK, CA 91506 Social Security #: 174-54-3435 Date of Birth: 09-03-1974 Date of Loss: 07/06/2000 SUlO -501682 51734 - L 0 1 ,,,: ~,~- f' . ~ C., -..1 -< ~.," "' c:::> ...- o "11 :o;:! fh;':J --:'d-', :oCJ So ?S,J3 ;:-:;ri--j -~-! ~~'!: .>..> 1"-.) \,' F":> .; J"": = W -<: v. IN Tim: COURT OF COMMON PLEAS OF CUMBERLAND COUNTY; PENNSYLVANIA NO. 02-3085 ClVlL AMY REBEKAH DERRICK, Plaintiff, GIANT FOOD STORES, INC. Defendant. RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the following form: PETITION FOR Al'POINTMENT OF ARJJIITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: George B. Faller, Jr. ,counsel for th~defendant in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of the plaintiff in the action is $ not in exces~~.$25 ,000 The counterclaim of the defendant in the action i. N I A The following attorneys are interestcd in the case(s) as counselor are otherwiso: disqualified to sit as IIrbitrators: R. Mark Thomas, Esquire, 101 South Market Street, Mechanicsburg'PA 17055 WHEREFORE. your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Re~~U~IY SUb~\')~./ ~ ~g~ ~Ui quire I.D. Nu er 49 13 ORDER OF COURT AND NOW, , 19_, iI. consideration ofthe Esq., , Esq., are appointed arbitrators in the above captioned action (or foregoing petition. Esq.. and actions) as prayed for. By the Court, P.l. \ ~ ~ ~ ~ >." '- ~ ~ ,] ~. '--'\l ~ .. ~ ~ % ~ \> ~, :.'. ~ ~ '. - - v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA NO. 02-3085 ClVlL AMY REBEKAH DERRICK, Plaintiff, GIANT FOOD STORES, INC. Defendant. RULE BU-l. The Petition for Appointment of Arbitrators shall be substantially in the following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO tHE HONORABLE. THE JUDGES OF SAID COURT: George B. Faller, Jr. , counsel for the1liUIWdefendant in the above action (or actions), respectfully represents that: 1. The above-caplioned action (or actions) is (are) at issue. 2. The claim of the plaintiff in the action is$ not in excess of .$25,000 Thc counterclaim of the defendant in the action is N / A The following attorneys are interestcd in the casc(s) as counselor are otherwise disqualified to sit as arbitrators: R. Mark Thomas, Esquire, 101 South Market Street, Mechanicsburg'PA 17055 WHEREFORE. your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Re~fUlIY SUb~~\ '1/..f)J - ) G~g~J4p".. t;U; quire I.D. Nuwoer 49 13 ORDER OF COURT Esq., D ~ d:?t:; / , Esq., are appointed arbitrators in the above captioned action (or Esq.. and (. actions) as PB ed for. P.l. ~ ~ ~ ..... ~ 1"".) '-... 'd ........ --t;, ~ ;"! .-.- : ~ Co,; ~ ,. <;:) ~ r: ~ ~ '0 t C;, -i' ~ (" ...] - ! :,' ," CS :D1 ,'S., 'tit> V. IN THE COURTOF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. NO. 02-3085 CIVIL AMY REBEKAH DERRICK GIANT FOOD STORES, INC. ORDER OF COURT AND NOW, April 13, 2005, because of counsel conflicts, the arbitration panel appointed on March 17, 2005, in the above matter is vacated; the new panel shall consist of James Jones, Esquire, Chairman; David Lopez, Esquire and Karen May, Esquire. By the Court, G~ ~ Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 ~orge B. Faller, Jr., Esquire 10 East High Street Carlisle, PA 17013 > .)dmes Jones, Esquire Chairman of the Arbitration Panel 7 Irvine Row Carlisle, PA 17013 Court Administrator ~c . I"~ f\.Li" liD :01 H'} jO ,;'"';f" II,j CI ,~1 Yif .."",'!q7 .! \;< .:!tJUl v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3085 CIVIL AMY REBEKAH DERRICK, Plaintiff, GIANT FOOD STORES, INC. Defendant. RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the fallowing form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THB HONORABLE, THE JUDGES OF SAID COURT: George B. Faller, Jr. . counsel for the19lllWllt19'defendant in the above action (or actions). respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. Theclaimoftheplaintiffintheactionis$not in excess of $25,000 The counterclaim of the defendant in the action is N / A The fOllowing attorneys are interested in the case(s) as counselor are otherwise disqualified to sit as arbitrators: R. Mark Thomas, Esquire, 101 South Market Street, Mechanicsburg'PA 17055 WHEREFORE. your petitioner prays your Honorable Coun to 'p!'Qinl three (3) arbitrators to whom the case shall be submitted. Re~fU]IY. ._.SUbl!~'\. '1/1/ G~fg~;t4 .. 't!(i'7qUire I.D. Num~er 49 13 ORDER OF COURT 1 . 19.;Zp~ .(;n con~id9ation of the ! J Esq.. O~ .x!td:~ /' , Esq., are appointed arbitrators in the above captioned action (or Esq.. and actions) as Pnl ed for. i P.l. "'" ~ "" '-- -..... -1::; <;:;-: ~ ...... c:--. ',' Cv ~ \ ~-5 l-;,/ I'" V >-- "\ ~ "t, "-... ~ - \J ~, ~ "'- ,-, ~ __ ,-_r ~ - MDW~6 fNFORMAT!ON. ADVICE' ADVOCACY ATTORNEYS & COUNSELLORS AT LAW TEJ.EPHONE FACSIMILE INTERNET (717) 243-3341 (717) 243-1850 www.mdwo.com WILLIAM F. MARTSON JOHN B. FOWLER III EDWARD L. SCHORPP DANIEL K. DEARDORFF THOMAS 1. WILLlAMS* lvo V. OTTO III GEORGE B. FALLER JR.* CARL C. RlSCH DAViD A. FnZslMONS DAVID R. GALLOWAY ANTHONY 1'. LUCIDO CHRISTOPHER E. RICE JENN1FER L. SPEARS HILLARY A. DEAN 10 EAST HIGH STREET CARLISLE, PENNSYLVANIA 17013 "'BOAIlD CERTIFIED CIVil TRIAL SPfClALlST April 12,2005 The Honorable George E. Hoffer Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 RE: Amy Rebekah Derrick v. Giant Food Stores, Inc. No. 02-3085-Cumberland County C.C.P. Our File Number: 9500.208 Dear Judge Hoffer: You recently appointed arbitrators in the above-referenced matter. Leslie Fields was the Chairperson of the Panel. Leslie called to advise me that all of the arbitrators essentially had conflicts of interest and, therefore, an entire new panel would need to be appointed. We all apologize for the inconvenience but these conflicts were obviously unforeseen. Very truly yours, GBF/mam Enclosure cc: R. Mark Thomas, Esquire Ms. Pam Graeff (D/L: 7/6/00; Store #110) (via e-mail) Ms. Denise DiSano (GL 0012926) (via e-mail) F\FILESIDA T AFILE\MAC9500lCutTenl\2U8gh 1 INFORMATION' ADVICE' ADVOCACY SM AMY: REBEKAH DERRICK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-3085 CIVIL TERM v. GIANT FOOD STORES, INC., Defendant CIVIL ACTION - LAW Petition to Vacate Court Appointed Arbitrators I. Plaintiff, Amy Rebekah Derrick, filed a complaint on August 30, 2002 against the above captioned defendant. 2. On September 26, 2002, the defendant filed an answer to plaintiffs complaint. 3. On February 11,2005, a Petition for Appointment of Arbitrators was tiled. 4. By order dated April 13,2005 an arbitration panel was appointed consisting of James Jones, Esquire, Chairman, David Lopes, Esquire and Karen May, Esquire. 5. Prior to the scheduling of an arbitration hearing the parties hereto were able to amicably settle this case. 6. A Preacipe to Settle and Discontinue this case was filed by the plaintiff, but rejected by the Prothonotary's Office until such time as the court order appointing the arbitration panel was vacated. 7. Counsel for the defendant, has been contacted regarding the filing ofthis Petition and has no objection to the granting of this Petition so that this matter may be closed. Wherefore, petitioner prays this honorable court will vacate the arbitration panel that was previously appointed on April 13, 2005. R~;~ R. Mark Thomas, Esquire Attorney for Plaintiff 101 South Market Street Mechanicsburg, P A 17055 (7]7) 796-2]00 ID#4]301 - AMY REBEKAH DERRICK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-3085 CIVIL TERM v. GIANT FOOD STORES, INC., Defendant : CIVIL ACTION - LAW Certificate of Service I, R. Mark Thomas, hereby certify that I have on this date served a copy of the forgoing Petition to Vacate Court Appointed Arbitrators to the following: George B. Fallei, Jr. 10 East High Street Carlisle, PA 17013 by first class mail, postage prepaid. l&rJ~ R. Mark Thomas, Esquire Attorney for Plaintiff 101 South Market Street Mechanicsburg, P A 17055 (717) 796-2100 ID# 41301 Dated: f'eb. ~~ ~~ ..---------- (_! f-..) C. "-:! r'.... en c:~\ ~ 0" .~ - RECEIVED MAR 0 ~ 1" t AMY REBEKAH DERRICK, Plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-3085 CIVIL TERM v. GIANT FOOD STORES, INC., Defendant CIVIL ACTION - LAW Order AND NOW, this Uday of March, 2006, upon consideration of the Petition to Vacate the Court Order which previously appointed an Arbitration Panel to hear this matter, and the Court being advised that the case was settled by agreement without arbitration, it is hereby ordered that the previous Court Order dated April 13, 2005 appointing an arbitration panel is hereby VACATED. by the court J L- '-------- J. ]-7-{)& ~ ~ Yf'; Co,.-, (,/, ,.___t) " 'j AMY REBEKAH DERRICK, Plaintiff v. GIANT FOOD STORES, INC., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3085 CIVIL TERM CIVIL ACTION - LAW PRAECIPE TO SETTLE AND DISCONTINUE TO THE PROTHONOTARY: Kindly mark the above-captioned case as settled and discontinued. Respectfully submitted, 7b?!~ R. Mark Thomas, Esquire Attorney for Plaintiff 101 South Market Street Mechanicsburg, P A 17055 (717) 796-2100 ID# 41301