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Home My WebLink About94-02521 j / / / , ~ ~ - '- .~ u o l{) (() REBECCA L. BENSON . Claimant . v. . LEE G. DANTE, M.D. . and . LEE G. DAN'l'E, M.D., P.A. . Health Care . Providers . . . . . . . IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA q '-I - .:l S".11 ~.:r.R/LI?yV NI9(, NO. . . . . . . ORDER II AND NOW, the \ I r day of M,,-VJ Petition of Lee G. Dante, M.D., it is hereby .' , 1994, upon the ORDERED that the Prothonotary shall issue a Subpoena Duces Tecum directing the Custodian of Records for Pennsylvania Blue Shield to appear for a deposition on the lOth day of June, 1994 at 10:00 a.m. at the offices of Pennsylvania Blue Shield, 1800 Center Street, Camp Hill, Pennsylvania 17089-0089, and to bring with him/her for inspection and photocopying any and all records, relating to medical services, whether or not reimbursed, as well as correspondence to or from that office regarding payments made or refused on her behalf and any and all other information rendered for the physical, mental or emotional condition pertaining tOl Rebecca Lois Benson 929 Candlelight Drive Bel Air, MD 21041 Date of Birth: February 21, 1952 Social Security No. 222-36-8623 Any person authorized to administer oath and record and transcribe deposition testimony under the laws of the - '" REBECCA L. BENSON . claimant . v. . LEE G. DANTE, M.D. . and . LEE G. DANTE, M.D., P.A. . Health Care . Providers . . . . . * . IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA <1'1-- .:z S" ~ I 6.,,;.J. ;:r....I\I\......J MISe. tlB. . . . . . . PETITION FOR ISSUANCE OF SUBPOENA DUCES TECUM RELATING TO A FOREIGN ACTION The Defendant, Lee G. Dante, H.D., by his attorney, Amy B. Heinrich, Esq., Goodell, DeVries, Leech & Gray, respectfully applies to the Court for a Subpoena Duces Tecum pursuant to 42 Pat C. S. S 5326, for the following reasons: 1. Lee G. Dante, M.D. is the Defendant in a Health Claims Arbitration action known as Rebecca L. Benson v. Lee G. Dante. M.D.. et a1., HCA 93-l23, before the Health Claims Arbitration Office, State of Maryland. 2. Attached hereto is a commission issued by the Director of the Health Claims Arbitration Office, State of Maryland, regarding the taking of depositions by Lee G. Dante, M.D. 3. The requested Subpoena Duces Tecum is to direct the Custodian of Records for Pennsylyania Blue Shield, 1800 Center Street, Camp Hill, Pennsylvania 17089-0089, to appear for a deposition before a notary public on the lOth day of June, 1993 at 10:00 a.m. at the offices of Pennsylvania Blue Shield, lBOO Center Street, Camp Hill, Pennsylvania 17089-0089. The - ". custodian is directed to bring for inspection and photocopying any and all records, relating to medical services, whether or not reimbursed, as well as correspondence to or from that office regarding payments made or refused on her behalf and any and all other information rendered for the physical, mental or emotional condition pertaining to: Rebecca Lois Benson 929 Candlelight Drive Bel Air, MD 21041 Date of Birth: February 21, 1952 Social Security No.: 222-36-8623 4. Proper notice of said deposition has or will be provided to all parties hereto in accordance with the practice and procedures of this commonwealth and the Health Claims Arbitration Office, State of Maryland. 5. Pursuant to the Uniform Deposition Act, a portion of which is codified in 42 Pat S. C. S 5326, this Honorable Court may order a person domiciled in this State to give his deposition for use in a matter pending in a tribunal outside this Commonwealth. 6. Further, 42 Pat S. C. S 5326 provides that the Court may enter such an order upon application of any interested party. WHEREFORE, Petitioner, Lee G. Dante, M.D., respectfully requests this Court to grant this Petition and issue the Order attached hereto directing the Prothonotary to issue the requested Subpoenas Duces Tecum. - 2 - .. " REBECCA L. BENSON . Claimant . v. . LEE G. DANTE, M.D. . and . LEE G. DANTE, M.D. , P.A. . Health Care . Providers . . . . . . . BEFORE THE HEALTH CLAIMS ARBITRATION OFFICE q't -.;lS:11 ~L::r~ HCA No. 93-123 . . . . . . , i , , I II , ,1 NOTICE TO TAKE DEPOSITION DUCES TECUM Notice is hereby giyen pursuant to the Rules of Prooeduru that the oral deposition for the purpose of discovery will be taken of the custodian of Records for Pennsylvania Blue Shield, 1800 Center street, Camp Hill, Pennsylvania 17089-0089. This deposition, scheduled for the purpose of obtaining records only, is to be held at 10100 .... on Kon4.y, Jun. 13, 1"., at the offices of Pennsylvania Blue Shield, 1800 Center street, Camp Hill, Pennsylvania 17089-0089. The custodian is directed to bring with him/her at the time of the deposition, any and all records, relating to medical services, whether or not reimbursed, as well as correspondence to or from your office regarding payments made or refused on her behalf and any and all other information rendered for the physical, mental or emotional condition pertaining to: Rebecca Lois Benson 929 Candlelight Drive Bel Air, MD 21041 Date of Birth: February 21, 1952 Social Security No. 222-36-8623 II I I I I ~@ii:UW~n BEFORE THE , APR J 4 199, HEALTH CLAIMS HEALTH CLAIM~ABITRA'f/ON OFFICE REBECCA L. BENSON . Claimant . v. . LEE G. DANTE, M.D. . and . LEE G. DANTE, M.D. . Health Care . Providers . . . . . . . i , I II II I I I I I I I I ! ARBITRATION OFFICE q..,.-~S;,),l C\.:"~.:r...."""", HCA No. 93-123 . . . . . . COMMISSION TO TAKE DEPOSITION DUCES TECUM TO ANY JUDGE, MAGISTRATE, OR OTHER JUDICIAL OFFICER OR NOTARY PUBLIC OF THE STATE OF PENNSYLVANIA I, as Director of the Health Claims Arbitration Office, state of Maryland, having jurisdiction over the case captioned above, do by this document, authorize you to cause to come before you, to be examined in a case pending before the Health Claims Arbitration Office, state of Maryland, all and every such person and at such time and place as shall be named to you for that purpose, by Amy B. Heinrich, Esq., Goodell, DeVries, Leech & Gray, Commerce Place, One South Street, suite 2000, Baltimore, Maryland 21202, as attorneys or agents for the Defendant, Lee G. Dante, M.D., and exhort and command you to issue a subpoena duces tecum commanding every such person to appear before you and upon his/her oath or solemn affirmation to testify to the whole truth touching his/her knowledge 9.f ,,"qI1Y~MUg._~!l.!.~ting to the said matter and controversy betwe~~" the saides'.~ ~. _ -e-:::3<_ 'wliIIw1'll !:l,A THb L 1'lIIIl_ Wl'l'RA~'IOU Dl'jrfCE DIlle . '~'\i,:'::"j'i BI:; IIn h ^ U .l.l0I4"/t.r.. Harry~ Chase ;"'Di~:~~~r;"~'I:"ij ''''i~';:~~ ~7~JI '1' U ""TI con filII.,