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Home My WebLink About02-3648RACHELLE B. SYBRANDT a/k/a RACHELLE SYBRANDT, Plaintiff V. MYONG NYO KRZYKOWSKI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. Oa - ateL/ P (?'?". C?_FI CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY Please issue a Writ of Summons in the above-captioned matter and forward the Writ of Summons to the Sheriff for service on: Myong Nyo Krzykowski 511 North Market Street Duncannon, PA 17020 Date: a% 2.00 2- .144- Ronald D. Butler, Esquire Attorney for Plaintif I.D. #09826 500 N. Third St., P.O. Box 1004 Harrisburg, PA 17108-1004 (717) 236-1485 WRIT OF SUMMONS TO THE ABOVE-NAMED DEFENDANT: YOU ARE NOTIFIED THAT THE ABOVE-NAMED DEFENDANT HAS COMMENCED AN ACTION AGAINST YOU. Prothonotary Dated: Deputy V v -10 6s V' n FT'i W - r , r C? it A r` T7 rA SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2002-03648 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SYBRANDT RACHELLE B AKA RACHEL VS KRZYKOWSKI MYONG NYO R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: KRZYKOWSKI MYONG NYO but was unable to locate Her deputized the sheriff of PERRY in his bailiwick. He therefore serve the within WRIT OF SUMMONS County, Pennsylvania, to On August 14th 2002 this office was in receipt of the attached return from PERRY Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Perry Co 41.90 .00 78.90 08/14/2002 BUTLER LAW FIRM Sworn and subscribed to before me this o2 day of A.D. Prothonotary So answer - R. Thomas Kline Sheriff of Cumberland County Y In The Court of Common Pleas of Cumberland County, Pennsylvania Rachelle B. Sybrandt aka Rachelle Sybrandt VS. Myong Nyo Krzykowski SERVE: same NO. 02 3648 civil Now, August 6, 2002 I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of nerrv County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Now, August 12 within Writ of Summons Affidavit of Service 20 2 0, at 6:00 o'clock P M. served the upon Myong Nyo Krzykowski at 511 N. Market St. Duncannon, Pa. 17020 (Duncannon Borough) by handing toMyong Nyo Krzykowski a Tru & Attested. COPY of the original Writ of Summons and made known to Her the contents thereof. So answers, Sworn and subscribed before me this 13thday of August , 20 02 a? cL?f - NOTARIAL? kk MMiGARETF . FLICKINGER, NdfARYpUBLIC BLOOMEIELDBORO.,PERRY000NTV MY COMMISSION EXPIRES FEB. 16 2004 James T. Bennett Deputy Sheriff of Perry County, PA COSTS SERVICE $ MILEAGE AFFIDAVIT RACHELLE B. SYBRANDT a/k/a RACHELLE SYBRANDT, Plaintiff V. MYONG NYO KRYZKOWSKI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3648 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of undersigned counsel on behalf of Defendant Myong Krzykowski. Date: Z Respectfully submitted, NESTICO, DRUBY & HILDABRAND, LLP By: Richard B. Druby, Eire Attorney I.D. No. 61904 840 East Chocolate Avenue Hershey, Pennsylvania 17033 (717) 533-5406 (717) 533-5717 Attorney for Defendant Krzykowski CERTIFICATE OF SERVICE I, Richard B. Druby, of the law firm of Nestico, Druby & Hildabrand, LLP, hereby certify that on the day of December, 2002, a copy of the foregoing document was sent via First Class U.S. Mail, postage paid, to the following: Donald D. Butler, Esquire 500 North Third Street PO Box 1004 Harrisburg, PA 17108-1004 t S Y ? 4 d ..J r -a [ G? l RACHELLE D. SYBRANDT a/k/a RACHELLE SYBRANDT Plaintiff V. MYONG NYO KRZYKOWSKI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2002-03648 CIVIL ACTION - LAW NOTICE - COMPLAINT 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 THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Referral Service Court Administrator Fourth Floor, Courthouse Carlisle, PA 17013 (717) 240-6200 NOTICIA Le han demandado a usted an la corte. Si usted guiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado gue si usted no se defienda, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier gueja o alivio gue es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUNENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Referral Service Court Administrator Fourth Floor, Courthouse Carlisle, PA 17013 (717) 240-6200 RACHELLE D. SYBRANDT a/k/a RACHELLE SYBRANDT Plaintiff V. MYONG NYO KRZYKOWSKI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : No. 2002-03648 : CIVIL ACTION -LAW COMPLAINT Parties 1. The Plaintiff Rachelle D. Sybrandt is an adult individual who resides at 70 Station Road, Newville, Cumberland County, Pennsylvania. 2. The Defendant Myong Nyo Krzykowski is an adult individual who resides at 511 North Market Street, Duncannon, Perry County, Pennsylvania. Background 3. On Friday, August 11, 2000 at approximately 11:00 p.m., the Plaintiff Rachelle D. Sybrandt was a passenger in a 1996 Mercury she owned and which James Burgett was driving. On that same date the Defendant Myong Nyo Krzykowski was intoxicated and was operating a 1998 Chevrolet Blazer owned by Timothy Krzykowski. 4. James Burgett, with Rachelle Sybrandt as passenger, was traveling north on Front Street in Wormleysburg Borough, Cumberland County, Pennsylvania and had properly slowed and then stopped for another vehicle which had stopped in front of Plaintiff because pedestrians were crossing in front of that car. 5. The Defendant Myong Nyo Krzykowski was also traveling north on Front Street and was behind the Plaintiff Rachelle D. Sybrandt. 6. The Defendant Myong Nyo Krzykowski was driving at a reckless speed and approached the Plaintiff's car from behind in reckless manner. 7. Without warning the Defendant Myong Nyo Krzykowski caused the Chevrolet Blazer to plow into the rear of the Plaintiff's car, totally demolishing the car. 8. At the moment of impact the Plaintiff Rachelle D. Sybrandt was subjected to significant force which caused injury to her spine. 9. The force of the impact propelled Plaintiff's car forward into the car that had stopped in front of her. 10. At the time of the crash the Defendant Myong Nyo Krzykowski's blood alcohol was over the legal limit (i.e..10%). Negligence of Defendant Myong Nyo Krzykowski 11. Paragraphs 1-10 are incorporated herein by reference thereto. 12. The collision and all of hereinafter mentioned injuries and damages sustained by the Plaintiff Rachelle D. Sybrandt, are the direct result of the carelessness, reckless and negligence of the Defendant Myong Nyo Krzykowski as more particularly described as follows: (a) In failing to stop the vehicle she was operating before colliding with the vehicle in which Rachelle Sybrandt was a passenger; (b) In failing to keep alert and to maintain a proper lookout for the presence of other motor vehicles, more specifically, the vehicle in which Rachelle Sybrandt was a passenger; (c) In failing to keep adequate and proper control over his vehicle to avoid contact with the automobile in which Rachelle Sybrandt was a passenger; (d) In operating her vehicle in a reckless manner and with careless disregard for the rights or safety of others and in operating her vehicle in a manner endangering persons and property in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania, specifically 75 Pa. C.S.A. §3736; (e) In failing to properly and quickly apply her brakes to prevent his vehicle from colliding with the rear of the vehicle in which Rachelle Sybrandt was a passenger; (f) In operating a vehicle while under the influence of alcohol; (g) In operating her vehicle while intoxicated in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania, specifically 75 Pa.C.S.A §3731. 13. Shortly before the time of the crash the Defendant Myong Nyo Krzykowski drank alcohol. 14. The Defendant Myong Nyo Krzykowski knew or should have known that it was illegal to operate a motor vehicle after drinking alcohol to the point where she became intoxicated. 15. The Defendant Myong Nyo Krzykowsk:i became intoxicated from this drinking episode and was legally intoxicated at the time of the crash. 16. Even though the Defendant Myong Nyo Krzykowski knew or should have known she was intoxicated, she proceeded to operate the Blazer thus showing a reckless indifference for other persons, including Plaintiff Rachelle D. Sybrandt, who was lawfully on the roadway. 17. The Defendant Myong Nyo Krzykowski's action in driving while intoxicated constitutes outrageous and wanton conduct and as such gives rise to punitive damages to be assessed against the Defendant Myong Nyo Krzykowski. 18. The Defendant Myong Nyo Krzykowski. because of her intoxication was unable to properly control her vehicle or apply the brakes in anappropriate fashion. Injuries 19. The force and impact of the collision as caused by the negligence and outrageous conduct of the Defendant Myong Nyo Krzykowski caused serious injury to the Plaintiff Rachelle D. Sybrandt. 20. The Plaintiff Rachelle D. Sybrandt suffered the following injuries as a result of the negligence of the Defendant: (a) Herniated disc at C4-5; (b) Bulging disc at C5-6; (c) Persistent and continuous neck pain radiating into upper back, head and arms; (d) Permanent cervical ligament damage; (d) Numbness and tingling in both hands; (e) Severe migraine headaches; (f) Side-effects from medication; (g) Anxiety and depression. 21. By reason of the Plaintiff Rachelle D. Sybrandt's injuries set forth above she has received medical and chiropractic care, and may in the future: be required to receive said care to recover from the injuries she suffered in this crash. 22. As a result of the negligence and gross conduct of the Defendant Myong Nyo Krzykowski as described herein, the Plaintiff Rachelle D. Sybrandt has suffered and will continue to suffer mental and physical pain, great difficulty in carrying out and engaging in life's activities, a loss of life's pleasures and enjoyment, humiliation and embarrassment. 23. Plaintiff Rachelle D. Sybrandt has and will in the future sustain a loss of earnings and an impairment to her earning capacity. 24. Plaintiff Rachelle D. Sybrandt has been forced to expend sums of money for medical services, medication and therapy and related expenses in the past and may be required to continue to do so in the future. 25. All of Plaintiff Rachelle D. Sybrandt's injuries as herein described are continuing and will continue into the foreseeable future, as will the treatment costs thereof. 26. The negligence and outrageous conduct of the Defendant Myong Nyo Krzykowski has resulted in the general deterioration of Plaintiff'Rachelle D. Sybrandt's well-being. WHEREFORE, the Plaintiff Rachelle D. Sybrandt demands judgment against the Defendant Myong Nyo Krzykowski in an amount in excess of the compulsory arbitration limits of Cumberland County, together with interest, delay damages if applicable, punitive damages and costs of suit. Date: J QQ _4?/) a CLARAVAL & CLARAVAL By ®RT 4AIAVAL P.O. Box 11965 Harrisburg, PA 17108-1965 (717) 233-4.780 Supreme Court I.D. #19222 Attorneys for Plaintiff VERIFICATION I hereby certify that I am the Plaintiff in the foregoing action and that the facts set forth in the attached Complaint are based upon information that I have given to counsel and they are true and correct to the best of my knowledge, information, and belief. I understand that any false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. DATED: Rachelle 8. Sybrandt RACHELLE D. SYBRANDT a/k/a RACHELLE SYBRANDT Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : No. 2002-03648 MYONG NYO KRZYKOWSKI, CIVIL ACTION -LAW Defendant CERTIFICATE OF SERVICE I hereby certify that I have this day served a true and correct copy of the attached Complaint by first class mail, postage prepaid, addressed to the following person: Richard B. Druby, Esq. Nestico, Druby & Hildabrand 840 East Chocolate Avenue Hershey, PA 17033 CLARAVAL & CLARAVAL Date: I a7 10-.-2, By dfl ?,?, DENISE I. WILLIAMS, Secretary ? ?_. " 9r ?, ? - ?; '. .. \ ? _, ?, ? -?[ RACHELLE B. SYBRANDT a/k/a RACHELLE SYBRANDT, Plaintiff V. MYONG NYO KRYZKOWSKI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3648 CIVIL TERM CIVIL ACTION -LAW JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Rachelle B. Sybrandt c/o Robert F. Claraval, Esquire Claraval & Claraval P.O. Box 11965 Harrisburg, PA 17108-1965 You are hereby notified to plead to the enclosed Defendant's Answer With New Matter within twenty (20) days from service hereof or a default of judgment may be entered against you. NESTICO, DRU??& HILDABRAND, LLP IG Dated: p By: Richard B. Druby, Esq 'r /Attorney I.D. No. 61904 840 East Chocolate Avenue Hershey, Pennsylvania 17033 (717) 533-5406 (717) 533-5717 Attorney for Defendant RACHELLE B. SYBRANDT a/k/a RACHELLE SYBRANDT, Plaintiff V. MYONG NYO KRYZKOWSKI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3648 CIVIL TERM CIVIL ACTION -LAW JURY TRIAL DEMANDED DEFENDANT'S ANSWER WITH NEW MATTER 1. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments, and they are therefore denied. 2. Admitted. 3. Admitted in part and denied in part. It is admitted that on Friday, August 11, 2000 at approximately 11:00 p.m. Defendant was operating a 1998 Chevrolet Blazer owned by Timothy Kryzkowski. It is also admitted, upon information and belief that Plaintiff was a passenger in a 1996 Mercury owned by her and driven by James Burgett. However, the allegation that Defendant was operating her vehicle "while intoxicated" is denied as a legal conclusion. 4. After reasonable investigation, Defendant is without knowledge of information sufficient to form a belief as to the truth of the averments, and they are therefore denied. 14. Denied as stated. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments because the averments are vague and ambiguous, and they are therefore denied. 15. Denied as a conclusion of law. 16. Conclusion of law, to which no response is required. To the extent a response is required, it is denied that Defendant acted with reckless indifference and, further, the allegations of Paragraph 16 are denied pursuant to Pa. R.C.P. 1029 (e). IT Conclusion of law, to which no response is required. To the extent a response is required, it is denied that Defendant acted in an outrageous and wanton manner and, further, the allegations of Paragraph 17 are denied pursuant to Pa. R.C.P. 1029 (e). 18. Conclusion of law, to which no response is required. To the extent a response is required, the allegations of Paragraph 18 are denied pursuant to Pa. R.C.P. 1029 (e). 19. Conclusion of law, to which no response is required. To the extent a response is required, it is denied that Defendant acted in an outrageous manner and further, the allegations of Paragraph 19 are denied pursuant to Pa. R.C.P. 1029 (e). 20. Conclusion of law, to which no response is required. To the extent a response is required, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the allegations contained in subparagraph 20 (a) through 20 (g). As for the remaining allegations of Paragraph 20, they are denied pursuant to Pa. R.C.P. 1029 (e). 21. Conclusion of law, to which no response is required. To the extent a response is required, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments, and they are therefore denied. 22. Conclusion of law, to which no response is required. To the extent a response is required, with regard to the allegation that Plaintiff has suffered and will continue to suffer mental and physical pain, great difficulty in carrying out and engaging in life's activities, a loss of life' pleasures and enjoyment, humiliation and embarrassment, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments, and they are therefore denied. Further, it is denied that Defendant's conduct was "gross" and further, the remaining allegations of Paragraph 22 are denied pursuant to Pa. R.C.P. 1029 (e). 23. Conclusion of law, to which no response is required. To the extent a response is required, after reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments, and they are therefore denied. 24. Conclusion of law, to which no response is required. To the extent a response is required, after reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments, and they are therefore denied. 25. Conclusion of law, to which no response is required. To the extent a response is required, after reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments, and they are therefore denied. 26. Conclusion of law, to which no response is required. To the extent a response is required, as for the allegation that there has been a general deterioration of Plaintiff's well being, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments, and they are therefore denied. Further, it is denied that Defendant acted in an outrageous manner and, further, the allegations of Paragraph 26, they are denied pursuant to Pa. R.C.P. 1029 (e). WHEREFORE, Defendant demands that Plaintiff's Complaint be dismissed with prejudice and that judgment be entered in her favor and against the Plaintiff, plus costs of this action. NEW MATTER 27. Paragraphs 1-26 above are incorporated herein by reference. 28. Plaintiff s claims may be barred, in whole or in part, by the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law. 29. Plaintiff's claims may be barred, in whole or in part, by the selection of a limited tort option on applicable policies of insurance. 30. Plaintiff may have failed to mitigate her damages. 31. Defenses reserved pursuant to Pa.R.C.P. 1030(b) and all other defenses not required to be pleaded are hereby reserved. 32. Plaintiff's claims may be barred, in whole or in part, by any applicable statute of limitations. 33. If Plaintiff sustained damages as alleged, which is denied and of which strict proof is demanded, the same were caused by conditions for which Defendant is not responsible and/or the damages were not causally related to this accident. WHEREFORE, Defendant demands that Plaintiff s Complaint be dismissed with prejudice and that judgment be entered in her favor and against the Plaintiff, plus costs of this action. NESTICO, DRUBY & HILDABRAND. LLP By: Date: 4 6? Richard B. Druby, Esujrel Attorney I.D. No. 61904 840 East Chocolate Avenue Hershey, Pennsylvania 17033 (717) 533-5406 (717) 533-5717 Attorney for Defendant Krzykowski VERIFICATION I, Myong Nyo Kryzkowski, verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date: Myong Nyo ry ow ski CERTIFICATE OF SERVICE I, Richard B. Druby, of the law firm of Nestico, Druby & Hildabrand, LLP, hereby certify that on the 16th day of April, 2003, a copy of the foregoing document was sent via First Class U.S. Mail, postage paid, to the following: Robert F. Claraval, Esquire Claraval & Claraval P.O. Box 11965 Harrisbu fI-- - ) L.? r- RACHELLE D. SYBRANDT IN THE COURT OF COMMON PLEAS OF a/k/a RACHELLE SYBRANDT CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : V. No. 2002-03648 MYONG NYO KRZYKOWSKI, CIVIL ACTION -LAW Defendant PLAINTIFF'S REPLY TO DEFENDANT'S NEW MATTER 27. No answer is required. 28. Denied. Paragraph 28 is a conclusion of law to which no response is required. 29. Denied. It is denied that Plaintiff selected limited tort. 30. Denied. Paragraph 30 is a conclusion of law to which no response is required. 31. Denied. Paragraph 31 is a conclusion of law to which no response is required. 32. Denied. It is denied that the Plaintiff in any way violated any applicable statute of limitations. 33. Denied. The Defendant is solely responsible for the motor vehicle accident and the resulting injuries to the Plaintiff. Date: CLARAVAL & CLARAVAL By -"4 &'w ROBERT F. CLARAVAL P.O. Box 11965 Harrisburg, PA 17108-1965 (717) 233-4780 Supreme Court I.D. #19222 Attorneys for Plaintiff RACHELLE D. SYBRANDT a/k/a RACHELLE SYBRANDT Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : No. 2002-03648 MYONG NYO KRZYKOWSKI, CIVIL ACTION - LAW Defendant : CERTIFICATE OF SERVICE I hereby certify that I have this day served a true and correct copy of the attached Plaintiffs Reply to Defendant's New Matter by first class mail, postage prepaid, addressed to the following person: Richard B. Druby, Esq. Nestico, Druby & Hildabrand 840 East Chocolate Avenue Hershey, PA 17033 CLARAVAL & CLARAVAL Date: yT [0s BDENISE I. WILLIAMS, Secretary 0 C 4= w C) Rz ti 3'. 70 -' (,J E RACHELLE D. SYBRANDT a/k/a RACHELLE SYBRANDT Plaintiff V. MYONG NYO KRZYKOWSKI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : No. 2002-03648 CIVIL ACTION - LAW CERTIFICATE OF SERVICE I hereby certify that I have this day served Plaintiff's Request for Production of Documents addressed to Defendant Myong Nyo Krzykowski by first class mail, postage prepaid, addressed to the following person: Richard B. Druby, Esq. Nestico, Druby & Hildabrand 840 East Chocolate Avenue Hershey, PA 17033 CLARAVAL & CLARAVAL Date: r?' 10 3 BY DENISE I. JULIJAMS, Secretary n ? Mri c ? a , RACHELLE D. SYBRANDT aWa RACHELLE SYBRANDT Plaintiff V. MYONG NYO KRZYKOWSKI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2002-03648 CIVIL ACTION - LAW CERTIFICATE OF SERVICE I hereby certify that I have this day served Plaintiff's Response to Defendant's Interrogatories and Request for Production of Documents by first class mail, postage prepaid, addressed to the following persons: Richard B. Druby, Esq. Nestico, Druby & Hildabrand 840 East Chocolate Avenue Hershey, PA 17033 Date: CLARAVAL & CLARAVAL 7/3I 103 By lrt X WiluJIU DENISE I. WILLIAMS, Secretary For Robert F. Claraval RACHELLE B. SYBRANDT a/k/a RACHELLE SYBRANDT, Plaintiff V. MYONG NYO KRYZKOWSKI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3648 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of s subpoena for documents and things pursuant to Rule 4009.22, Defendant certifies that: (1) a notice of intent to serve subpoenas with a copy of the subpoenas attached thereto was mailed or delivered to each party at least twenty days prior to the date on 'which the subpoenas are sought to be served; (2) a copy of the notice of intent, including the proposed subpoenas, is attached to this certificate; (3) the twenty days notice has expired; and (4) the subpoenas which will be served are identical to the subpoenas which are attached to the notice of intent to serve the subpoenas. By: 7/! ?richard B. Druby, s ire Attorney I.D. No. 6 04 840 East Chocolate Avenue Hershey, PA 17033 (717) 533-5406 (717) 533-5717 Date: U Attorney for Defendants Kryzkowski COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RACHELLE B. SYBRANDT a/k/a RACI IELLE SYBRANDT, Plaintiff V. NO. 02-3648 CIVIL TERM MYONG NYO KRYZKOWSKI, : CIVIL ACTION -LAW Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS 012 THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Kelly Services, Inc. 211 W. Fort Street, Lobby 2 Detroit, MI 48266-4444 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things Any and all employment information from the beginning of employment to the present, including, but not limited to, employment applications, employee evaluations, report of work injuries, worker's compensation claims and any and all other information regarding the employment of Rochelle B. Sybrandt (DOD: 4/9/1970, SSN: 162-68-2593). at 840 East Chocolate Avenue, Hershey, PA 17033 You may deliver or mail legible copies of the documents or produce the 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. Ifyou 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 in advance the reasonable cost of preparing the copies or producing the things sought. Ifyou 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: Richard B. Drolly, Esquire Address: 840 East Chocolate Avenue Hershey, PA 17033 Telephone: (717) 533-5406 Supreme Court ID #61904 Attorney for: Defendant Date: tJ/ SealofCourt BY THE COURT: Prot ionotary/Clerk, Civil Division eputy (Eff. 7/97) COMMONWEALT14 OF PENNSYLVANIA COUNTY OF CUMBERLAND RACI IELLE B. SYBRANDT a/k/a RACHELLE SYBRANDT, Plaintiff V. NO. 02-3648 CIVIL TERM MYONG NYO KRYZKOWSKI, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS 012 THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: RMH Telemarketing 40 Morris Avenue, 2"'t FI Bryn Mawr, PA 19010 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things Any and all employment information from the beginning of employment to the present, including:, but not li employment applications, employee evaluations, report of work injuries, worker's compensation claims and any and m ited to, information regarding the employment of Rachelle D. Sybrandt (DOB: 4/9/1970, SSN: 162-68-2593). all other at 840 East Chocolate Avenue, Hershey, PA 17033 You may deliver or mail legible copies of the documents or produce the 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 in advance the reasonable cost of preparing the copies or producing the things sought. Ifyou 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: Telephone: Supreme Cot Attorney for: Richard B. Druby, Esquire 840 East Chocolate Avenue Hershey, PA 17033 (717) 533-5406 rt ID #61904 Defendant Z aGy Date: M e2 e- 4 /T" Seal of Court ' BY THE COURT: Prothonotary/ erknCivii yiivv?isio Deputy ° - (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RACHELLE B. SYBRANDT a/k/a RACHELLE SYBRANDT, Plaintiff V. NO. 02-3648 CIVIL TERM MYONG NYO KRYZKOWSKI, CIVIL ACTION-LAW Defendant : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: ABEL Personnel, Inc. 3356 Paxton Street Harrisburg, PA 17111 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things Any and all employment information from the beginning of employment to the present, including, but not limited to, employment applications, employee evaluations, report of work injuries, worker's compensation claims and any and all other information regarding the employment of Rachelle B. Sybrandt (DOB: 4/9/1970, SSN: 162-68-2593). at 840 East Chocolate Avenue, Hershey, PA 17033 You may deliver or mail legible copies of the documents or produce the 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 alter its service, the party serving this subpoena may 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: Richard B. Druby, Esquire Address: 840 East Chocolate Avenue Hershey, PA 17033 Telephone: (717) 533-5406 Supreme Court ID 461904 Attorney for: Defendant Date: Aa& Seal of Court BY THE COURT: Prothonotary/Clerk, Cnivil Division eputy (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RACHELLE B. SYBRANDT a/k/a RACHELLE SYBRANDT, Plaintiff V. NO. 02-3648 CIVIL TERM MYONG NYO KRYZKOWSKL CIVIL ACTION -LAW Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: PA State Employee's Credit Union 1 Credit Union Plance Harrisburg, PA 17110 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things Any and all employment information from the beginning of employment to the present, including, but not limited to, employment applications, employee evaluations, report of work injuries, worker's compensation claims and any and all other information regarding the employment of Rachelle B. Sybrandt (DOB: 4/9/1970, SSN: 162-68-2593). at 840 East Chocolate Avenue, Hershey, PA 17033 You may deliver or mail legible copies of the documents or produce the 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. Ifyou fail to produce the documents or things required by this subpoena within twenty (20) days a0er its service, the party serving this subpoena may 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: Richard B. Druby, Esquire Address: 840 East Chocolate Avenue Hershey, PA 17033 Telephone: (717) 533-5406 Supreme Court ID #61904 Attorney for: Defendant BY THE COURT: Prothonotary/Clerk, Civil Division Date: I j2 t! Al Seal of Court eputy 9t? (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RACHELLE B. SYBRANDT a/k/a RACHELLE SYBRANDT, Plaintiff V. NO. 02-3648 CIVIL TERM MYONG NYO KRYZKOWSKI, : CIVIL ACTION -LAW Defendant : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: TSR Wireless 2200 Fletcher Ave, Suite 4 Fort Lee, NJ 07024-5016 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all employment information from the beginning of employment to the present, including:, but not limited to, employment applications, employee evaluations, report of work injuries, worker's compensation claims and any and all other information regarding the employment of Rachelle B. Sybrandt (DOB: 4/9/1970, SSN: 162-68-2593). at 840 East Chocolate Avenue, Hershey, PA 17033 You may deliver or mail legible copies of the documents or produce the 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 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: Telephone: Supreme Cot Attorney for: Richard B. Druby, Esquire 840 East Chocolate Avenue Hershey, PA 17033 (717) 533-5406 rt ID #61904 Defendant BY THE COURT: Prothonotary/Clerk, Civil Divisio Date: Seal of Court / Deputy (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RACI IELLE B. SYBRANDT a/k/a RACHELLE SYBRANDT. Plaintiff V. NO. 02-3648 CIVIL TERM MYONG NYO KRYZKOWSKI, CIVIL ACTION-LAW Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: JFC Pro Temps, Inc. 1520 Market St. Camp Hill, PA 17011 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all employment information from the beginning of employment to the present, including:, but not limited to, employment applications, employee evaluations, report of work injuries, worker's compensation claims and any and all other information regarding the employment of Rachelle B. Sybrandt (DOB: 4/9/1970, SSN: 162-68-2593). at 840 East Chocolate Avenue, Hershey, PA 17033 You may deliver or mail legible copies of the documents or produce the 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 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: Richard B. Druby, Esquire Address: 840 East Chocolate Avenue Hershey, PA 17033 Telephone: (717) 533-5406 Supreme Court ID #61904 Attorney for: Defendant BY THE COURT: ?(,? "4, , ?Z? Prothonotary/Clerk, Civil Divfsiot Date: ` my Seal of Court Deputy (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RACI IELLE B. SYBRANDT a/k/a RACI IELLE SYBRANDT, plaintiff v. NO. 02-3648 CIVIL TERM MYONG NYO KRYZKOWSKI, : CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Electronic Data Systems - Camp Hill opt. 5400 Legacy Drive Plano, TX 75024 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things Any and all employment information from the beginning of employment to the present, including, but not limited to, employment applications, employee evaluations, report of work injuries, worker's compensation claims and any and all other information regarding the employment of Rachelle B. Sybrandt (DOD: 4/9/1970, SSN: 162-68-2593). at 840 East Chocolate Avenue, Hershey, PA 17033 You may deliver or mail legible copies of the documents or produce the 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 thines souuhr_ If you fail to produce the documents or things required by this subpoena within twenty (20) days afler its service, the party serving this subpoena may 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: Telephone: Supreme Cot Attorney for: Richard B. Druby, Esquire 840 East Chocolate Avenue Hershey, PA 17033 (717) 533-5406 rt ID #61904 Defendant Date: / '! `w" ?/ ry,<? Seal ofCourt??- (Eff. 7/97) BY THE COURT: CERTIFICATE OF SERVICE I, Christiana Appleby, of the law firm of Nestico, Druby & Hildabrand, LLP, hereby certify that on the 30th day of March, 2004, a copy of the foregoing document was sent via First Class U.S. Mail, postage paid, to the following: Robert F. Claraval, Esquire Claraval & Claraval 500 North Third Street, 2nd Floor Harrisburg, PA 17108-1965 Qj"h ap ( -- Christiana Appleby r.? O C o -n S_ ??',, . CJ JO _ - - b J -, It I I G Ln (li IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY SYBRANDT Vs. NO. 200203648 KRZYKOWSKI CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 RICHARD B DRUBY, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 04/26/04 RICHARD B DRUBY, ESQUIRE 840 E CHOCOLATE AVE HERSHEY, PA 17033 717-533-5406 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-31653 File #: R309774 By: Susan Tyre IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY SYBRANDT Vs. KRZYKOWSKI I No. 200203648 TO: ROBERT CLARAVAL, ESQ (PLAINTIFF) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) 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 no objection is made the subpoena may be served. Date: 04/05/04 RICHARD B DRUBY, ESQUIRE 840 E CHOCOLATE AVE HERSHEY, PA 17033 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGIAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3653 By: Susan Tyre Enc(s): Copy of subpoena(s) Counsel return card File #: R309774 COM+DNWEALTH OF PENNSYLVANIA COUNTY OF COMBERIAND SYBRANDT Vs. KRZYKOWSKI File No. 200203648 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO. KEYSTONE SPINE CTR, 3552 GETTYSBURG RD, CAMP HILL PA 17011-6801 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 091+;1+'XiTA-e?ffi -- at ....-- MEDICAL LEGAL REPRODUCTIONS ,(AiiNN Wre'ssl940DCSSTON ST., 77- You may deliver or mail legible copies of the docure;nts or produce things requested h this subpoena, together wit!i the certificate of ccnpIiance, to the party making thi: request at the address listed above. You have the right: to seek in advance the rea.onable 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 thin subpoena may seek a court orde ompelling you to ocmply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: RICHARD B DRUBY, ESQ ADDRESS: _ R4.0 --g runrnraTE AVE -PA L7033 TELEPHONE: _ SUPREME COURT ID # 215-335-3212 ATTORNEY FOR: DEFENDANT R309774-01 DATE: /2 e2/Jn Sbal of the Court BY THE COURT: Prothonotary 1 k, Civil Division _ ? t z Gr? ?aZ.L00i? 21?1a1's Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA SYBRANDT Vs. KRZYKOWSKI No. 200203648 CUSTODIAN OF RECORDS FOR: KEYSTONE SPINE CTR ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: RACHELLE B SYBRANDT ADDRESS: 70 STATION RD NEWVILLE PA DATE OF BIRTH: 04/09/70 SSAN: 162682593 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ l RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Aut orize signature or KEYSTONE SPINE CTR CUMBERLAND R309774-01 * * * SIGN AND RETURN THIS PAGE * * * COMMONWEALTH OF PENNSYLVANIA COUNTY OF CL]MB RIAND SYBRANDT Vs. KRZYKOWSKI File No. 200203648 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED SUBPOENA TO PRODUCE DOCLMNTS OR THINGS FOR DISCOVERY PURSUANT TO RULE' 4009.22 TO: CUMBERLAND VAL ORTHO, 120 N 7TH ST #101, CHAMBERSBURG PA 17201-1795 (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 KtTAC1WD--M)DENfDtJM at MEDICAL LEGAL REPRODUCTIONS ,(AtltlrC'e'ss)940 D:ESSTON ., FK----- You may deliver or mail legible copies of the documents or produce things requested t?> this subpoena, together with the certificate of ocmrpliance, to the party making thi: request at the address listed above. You have the right to seek in advance the rea.onable 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 thin subpoena may seek a court orde;• cxmpelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: RICHARD B DRUBY, ESQ ADDRESS:- 849 E CKOCOT-ATE AVE -PAY 7033 TELEPHONE: _ SUPREME COURT ID k215 - 3 3 5- 3 212 ATTORNEY FOR: DEFENDANT R309774-02 DATE: I,Z S dal of the Court BY TFE COURT: Prothon erkOq , Civil Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA SYBRANDT Vs. KRZYKOWSKI No. 200203648 CUSTODIAN OF RECORDS FOR: CUMBERLAND VAL ORTH(O ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: RACHELLE B SYBRANDT ADDRESS: 70 STATION RD NEWVILLE PA DATE OF BIRTH: 04/09/70 SSAN: 162682593 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU 017 YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or' CUMBERLAND VAL ORTHO CUMBERLAND R309774-02 *** SIGN AND RETURN THIS PAGE *** CU4CNWEALTH OF PENNSYLVANIA COUNPY OF CL]MBE 2IAND SYBRANDT Vs. KRZYKOWSKI File No. 200203648 . ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE' 4009.22 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 docunents qg inAssTT*eHB8--M)D&Q)L1A1 at DR JOSEPH DEMARIO, 310 N SALEM CHURCH RD, MECHANICSBURG PA 17050 MEDICAL LEGAL REPRODIICTIONS, 494V-mlbbTON . Ph es') You may deliver or mail legible copies of the documents or produce things requested h? this subpoena, together with the certificate of carpliance, to the party making thi- request at the address listed above. You have the right: to seek in advance the rea.onablE 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 thin, subpoena may seek a court orde crnpelling you to canply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAM: RICHARD B DRUBY, ESQ AIDRESS: Ban E cmncOIATE AVE HERSH 033 TELEPHONE: SUPREME OOURT ID # 215 - 3 3 5 1T- ATTORNEY FOR: DEFENDANT R309774-03 DATE: QAL-p /,2 -2vvY Sbal of the Oourt BY THE COURT: ota Civil Division ry/ k,C Deputy Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA SYBRANDT Vs. KRZYKOWSKI No. 200203648 CUSTODIAN OF RECORDS FOR: DR JOSEPH DEMARIO ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: RACHELLE B SYBRANDT ADDRESS: 70 STATION RD NEWVILLE PA DATE OF BIRTH: 04/09/70 SSAN: 162682593 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU 017 YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO.I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or DR JOSEPH DEMARIO CUMBERLAND R309774-03 * * * SIGN AND RETURN THIS PAGE * * * CaMHX WEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SYBRANDT Vs. KRZYKOWSKI File No. 200203648 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE' 4009.22 DR WILLIAM RANCK, 3544 N PROGRESS AVE #10:3, HARRISBURG PA 17110-9638 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 o§ingS;,TACHED )DENDUM at _ MEDICAL LEGAL REPRODUCTIONS, ANC, ¢9?T-U•. PA (Address) You may deliver or mail legible copies of the documents or produce things requested h? this subpoena, together with the certificate of compliance, to the party making thi= 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 orde compelling you to omply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: RICHARD B DRUBY, ESQ ADDRESS: _ 940 E CHOCOLATE AVE $A X9033 TELEPHONE: _ SUPREME COURT ID # 215-335-3212 ATTORNEY FOR: R309774-04 DEFENDANT DATE: PA,-J 1.2 '20VV S1 of the Court BY THE COURT: 01-- Prothonotary/C1 Civil Division Deputy (Eff. 1/97) ADDENDUM TO SUBPOENA SYBRANDT Vs. KRZYKOWSKI No. 200203648 CUSTODIAN OF RECORDS FOR: DR WILLIAM RANCK ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: RACHELLE B SYBRANDT ADDRESS: 70 STATION RD NEWVILLE PA DATE OF BIRTH: 04/09/70 SSAN: 162682593 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE. AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ) NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or DR WILLIAM RANCK CUMBERLAND R309774-04 *** SIGN AND RETURN THIS PAGE *** COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SYBRANDT Vs. File No. KRZYKOWSKI 200203648 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISODVERY PURSUANT TO RULE, 4009.22 DR HAROLD MCCOY, C/O SPINAL LOGIC, 11417 124TH AVE NE #102 TO: KIRKLAND WA 98033 (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 WTACHED ? D Ei? DUM at _ ?p MEDICAL LEGAL REPRODUCTIONS,(Address4 )94' D ., You may deliver or mail legible copies of the documents or produce things requested t? this subpoena, together with the certificate of compliance, to the party making thi_ 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 docunents or things required by this subpoena within twenty (20) days after its service, the party serving thin subpoena may seek a court orde•- crnpelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: RICHARD B DRUBY, ESQ ADDRESS: _ 840 F CHOCOLATE AVE 033 TELEPHONE: SUPREME COURT I D# 215-335-3212 ATTORNEY FOR DEFENDANT R309774-05 DATE: Pte.:D 1.2 .2"y meal of the Court BY TFIE COURT: a? D Prothonotary/ k, Civil Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA SYBRANDT Vs. KRZYKOWSKI No. 200203648 CUSTODIAN OF RECORDS FOR: DR HAROLD MCCOY ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: RACHELLE B SYBRANDT ADDRESS: 70 STATION RD NEWVILLE PA DATE OF BIRTH: 04/09/70 SSAN: 162682593 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Aut orize signature or DR HAROLD MCCOY CUMBERLAND R309774-05 * * * SIGN AND RETURN THIS PAGE * * * COM XMEALTH OF PENNSYLVANIA COUNPY OF CUMBERLAND SYBRANDT Vs. KRZYKOWSKI File No. 200203648 ORIGINAL X-RAYS REQUESTED ;MEDICAL BILLING REQUESTED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE: 4009.22 DR WILLIAM BEUTLER, C/O PA SPINE INST, 805 SIR THOMAS CT 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 fol lowing docunents og_things,;,??)DENDUM at MEDICAL LEGAL REPRODUCTIONS .(Atlaress)940 5ISSTON ., •. FA You may deliver or mail legible copies of the documents or produce things requested b this subpoena, together with the certificate of compliance, to the party making thi_ 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 docunents or things required by this subpoena within twenty (20) days after its service, the party serving thin subpoena may seek a court orde;- crnpelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REGIEST OF THE FOLLOWING PERSON: NX1E: RICHARD B DRUBY, ESQ ADDRESS: - 840 E CHOCOLATE AVE -PA-19033 mERSHEY, TELEPHONE: SUPREPE COURT ID # 215-335-3212 ATTORNEY FOR DEFENDANT R309774-06 DATE: ag j- 1.7 a&o SS 1 of the Court BY THE COURT: ev Protho?notaary/914 k, Civil Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA SYBRANDT Vs. KRZYKOWSKI No. 200203648 CUSTODIAN OF RECORDS FOR: DR WILLIAM BEUTLER ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: RACHELLE B SYBRANDT ADDRESS: 70 STATION RD NEWVILLE PA DATE OF BIRTH: 04/09/70 SSAN: 162682593 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature for DR WILLIAM BEUTLER CUMBERLAND R309774-06 * * * SIGN AND RETURN THIS PAGE * * * COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SYBRANDT Vs. File No. 200203648 KRZYKOWSKI MEDICAL BILLING REQUESTED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE: 4009.22 TO: HOLY SPIRIT HOSP, 503 N 21ST ST, CAMP HILL ATTN: MEDICAL RECORDS DEPT (Name of Person or Entity) PA 17011 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents %]tVngsfiTACTUED--?U3 at MEDICAL LEGAL REPRODUCTIONSTAcVrCe'ss44 )940 DISSTON ST., PHI ., You may deliver or mail legible copies of the documents or produce things requested 6? this subpoena, together with the certificate of caTpliance, to the party making thi_ request at the address listed above. You have the right to seek in advance the rea,onable 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 thin subpoena may seek a court orde ocmpelling you to camly with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: RICHARD B DRUBY, ESQ ADDRESS: _ 81 9 nHQZ0 ATE AVE JPA-Y7033 TELEPHONE: _ SUPREME COURT ID # 215-335-3212 ATTORNEY FOR: DEFENDANT R309774-07 DATE: I. Q. y 5 1 of the Court BY THE COURT : Z?2 .. Prothonotary/ a c, Civil Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA SYBRANDT Vs. No. 200203648 KRZYKOWSKI CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSP ANY AND ALL EMERGENCY ROOM RECORDS AND BILLS. PERTAINING TO: NAME: RACHELLE B SYBRANDT ADDRESS: 70 STATION RD NEWVILLE PA DATE OF BIRTH: 04/09/70 SSAN: 162682593 MEDICAL BILLING REQUESTED ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or HOLY SPIRIT HOSP CUMBERLAND R309774-07 * * * SIGN AND RETURN THIS PAGE * * * QMDNWFALTH OF PENNSYLVANIA COUNPY OF CUMBERLAND SYBRANDT Vs. KRZYKOWSKI File No. 200203648 ORIGINAL X-RAYS REQUESTED SUBPOENA TO PRODUCE DOCUIENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 HOLY SPIRIT HOSP-X, 503 N 21ST ST, CAMP HILL PA 17011 TO: ATTN• RA TQ OGY DEPT (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 ATTrA-CFIED-M) --- at MEDICAL LEGAL REPR0DUCTIONSQA3*V88st940 DISSTON ST., PHILA., You may deliver or mail legible copies of the documents or produce things requested ti this subpoena, together with the certificate of compliance, to the party making thi: request at the address listed above. You have the right; to seek in advance the rea^.onable 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 'thin subpoena may seek a court orde cxnpelling you to ccrmply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FCLLOWING PERSON: NAME: - RICHARD B DRUBY, ESQ ADDRESS. _ E AVE TELEPHONE: HER H ,-PA= 033 SUPREME COURT ID # 215-335-3212 ATTORNEY FOR: DEFENDANT R309774-08 DATE:-oyV the Court BY THE COURT: • h'.'? ?Prothorwotary/ k, Civil Division 0.1D., / 0 Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA SYBRANDT Vs. No. 200203648 KRZYKOWSKI CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSP-X ANY AND ALL EMERGENCY ROOM FILMS. PERTAINING TO: NAME: RACHELLE B SYBRANDT ADDRESS: 70 STATION RD NEWVILLE PA DATE OF BIRTH: 04/09/70 SSAN: 162682593 ORIGINAL X-RAYS REQUESTED ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN - COMPLETE AND RETURN [ 7 RECORDS ARE ATTACHED HERETO.I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or HOLY SPIRIT HOSP-X CUMBERLAND R309774-08 * * * SIGN AND RETURN THIS PAGE * * * COm DNWFALTH OF PENNSYLVANIA COUNPY OF CI K3ERLAND SYBRANDT Vs. KRZYKOWSKI File No. 200203648 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: DR MICHAEL LUPINACCI, 175 LANCASTER BLVD :BOX 2028, MECHANICSBURG PA 170 Name of Person or Ent Within twenty (20) days after service of this subpoena, you are ordered by the court tc produce the following documents or thing: --- SEE ATE M) DEDUM at MEDICAL LEGAL REPRODUCTIONS(A tsf940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested t this subpoena, together wit!) the certificate of compliance, to the party making thi- request at the address listed above. You have the right to seek in advance the rea.onable cost of preparing the copies or producing the things sought. If you fail to produce the docunents or things required by this subpoena within twenty (20) days after its service, the party serving thin subpoena may seek a court orde.- cxnipelling you to eanply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: RICHARD B DRUBY, ESQ ADDRESS: 840 F snnn E AVE TELEPHONE: H , --PA-7:7033 SUPREME COURT ID # 215-335-3212 ATTORNEY FOR: R309774-09 DEFENDANT DATE: (Lv d- is o2ovy Sda l of the Court BY THE COURT: lPJrothonnotalry/ w , Civil Division 7T' Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA SYBRANDT Vs. KRZYKOWSKI No. 200203648 CUSTODIAN OF RECORDS FOR: DR MICHAEL LUPINACCI ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: RACHELLE B SYBRANDT ADDRESS: 70 STATION RD NEWVILLE PA DATE OF BIRTH: 04/09/70 SSAN: 162682593 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature o:r DR MICHAEL LUPINACCI CUMBERLAND R309774-09 *** SIGN AND RETURN THIS PAGE *** a"UNWEALTH OF PENNSYLVAN][A COUNPY OF CLD03ERIAND SYBRANDT Vs. KRZYKOWSKI File No. 200203648 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED SUBPOENA TO PRODl1CE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents SLOthings: E ATE- MENDUM at DR JOHN PANTALONE, 267 W MAIN ST, HUMMELSTOWN PA 17036 MEDICAL LEGAL REPRODUCTIONSfAWO940 DISSTON ST., PHILA., You may deliver or mail legible copies of the documents or produce things requested t this subpoena, together wit!) the certificate of compliance, to the party making thi= 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 doaments or things required by this subpoena within twenty (20) days after its service, the party serving 'this subpoena may seek a court orde crnpelling you to ccnply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING (PERSON: NAME: RICHARD B DRUBY, ESQ ADDRESS: _ 849 GHOGG _TE AVE -PAZ7033 TELEPHONE: _ SUPREME ODURT ID # 215-335-3212 ATTORNEY FOR: DEFENDANT R309774-10 DATE: :l /a -u,, Y, S 1 of the Court BY THE COURT: Prothonotary ark, Civil Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA SYBRANDT Vs. No. 200203648 KRZYKOWSKI CUSTODIAN OF RECORDS FOR: DR JOHN PANTALONE ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: RACHELLE B SYBRANDT ADDRESS: 70 STATION RD NEWVILLE PA DATE OF BIRTH: 04/09/70 SSAN: 162682593 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or DR JOHN PANTALONE CUMBERLAND R309774-10 *** SIGN AND RETURN THIS PAGE *** CU44 NWFALTH OF P S]NSYLVAN fA COUNTY OF CUMB RLAM SYBRANDT Vs. File No. 200203648 KRZYKOWSKI ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 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 ors jngg ACHED AUDDENDUM at ANNETTE DURICA, MA, 79 CEDAR AVE, HERSHEY PA 17033 MEDICAL LEGAL REPRODUCTIONS(A e§st940 DISSTON ST., You may deliver or mail legible copies of the documents or produce things requested b? this subpoena, together with the certificate of campliance, to the party making thi= 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 thin subpoena may seek a court orde+- c=pelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: RICHARD B DRUBY, ESQ ADDRESS: 84n o GHGGGr.nmE AVE -PA 17033 TELEPHONE: _ SUPREME COURT ID k215 - 3 3 5- 3 212 ATTORNEY FOR: R309774-11 DEFENDANT DATE:-2& Y,- S 1 of the Court BY THE COURT: notary/018r , Civil D1V1Slpn 71? C ?? Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA SYBRANDT Vs. No. 200203648 KRZYKOWSKI CUSTODIAN OF RECORDS FOR: ANNETTE DURICA, MA ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: RACHELLE B SYBRANDT ADDRESS: 70 STATION RD NEWVILLE PA DATE OF BIRTH: 04/09/70 SSAN: 162682593 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO.I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or ANNETTE DURICA, MA CUMBERLAND R309774-11 * * * SIGN AND RETURN THIS PAGE * * * CD1 4191EALTH OF PIIaISYLVANfA COUNPY OF CUMBERLAND SYBRANDT Vs. File No. 200203648 KRZYKOWSKI MEDICAL BILLING REQUESTED SUBPOENA TO PRODUCE DOCUMENTS 'OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CARLISLE REG HOSP, 246 PARKER ST, CARLISLE PA 17013-3618 TO: ATTN: MEDICAL RECORDS DEPT (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court tc produce the following documents orSEh]nggTTACHED ADDENDUM at ==xx - --- MEDICAL LEGAL REPRODUCTIONS ,(AWCe'ssl940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested h this subpoena, together with the certificate of carpliance, to the party making thi: 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 souglht. If you fail to produce the docunents or things required by this subpoena within twenty (20) days after its service, the party serving thin subpoena may seek a court orde-- cxnpelling you to cmply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: RICHARD B DRUBY, ESQ ADDRESS: _ 84.0 c CHOCOLATE AVE HERSH=, FA I?033 TELEPHONE: SUPREME COURT ID # 215-335-3212 ATTORNEY FOR DEFENDANT R309774-12 DATE: „1 /a7 .2-0VY S (l of the Court BY THE COURT: cam.; „_? Prothonotary/C , Civil Division i Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA SYBRANDT Vs. No. 200203648 KRZYKOWSKI CUSTODIAN OF RECORDS FOR: CARLISLE REG HOSP Any and all hospital records, including microfilm, microfiche emergency room reports, x-ray reports, out-patient records physical therapy records, and any other information pertaining to: NAME: RACHELLE B SYBRANDT ADDRESS: 70 STATION RD NEWVILLE PA DATE OF BIRTH: 04/09/70 SSAN: 162682593 MEDICAL BILLING REQUESTED ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO.I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or CARLISLE REG HOSP CUMBERLAND R309774-12 *** SIGN AND RETURN THIS PAGE *** CaMMxA%EALTH OF PENNSYLVANIA COUtuy OF CUMBERLAND SYBRANDT Vs. File No. KRZYKOWSKI 200203648 ORIGINAL X-RAYS REQUESTED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RUI-E 4009.22 CARLISLE REG HOSP-X, 246 PARKER ST, CARLISLE PA 17013-3618 TO: ATTN: RADIOLOGY DEPT - (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 SEEngATTA-C? AD at MEDICAL LEGAL REPR0DUCTI0NS(AJN0 940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested h this subpoena, together with the certificate of caTpliance, to the party making thi_ request at the address listed above. You have the right to seek in advance the rea.onabie 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 orde ornipelling you to crnply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NX1E: RICHARD B DRUBY, ESQ ADDRESS: _ 848 H GlIGGGT A`T'E AVE -PA-I7033 TELEPHONE: _ SUPREME COURT ID #215 - 3 3 5- 3 212 ATTORNEY FOR DEFENDANT R309774-13 DATE: ()Ad j /a? J-6TY S 1 of the Court BY TFE 00URT': Prothcmota y/Clerk, ivil Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA SYBRANDT Vs. No. 200203648 KRZYKOWSKI CUSTODIAN OF RECORDS FOR: CARLISLE REG HOSP-X ANY AND ALL X-RAY FILMS. PERTAINING TO: NAME: RACHELLE B SYBRANDT ADDRESS: 70 STATION RD NEWVILLE PA DATE OF BIRTH: 04/09/70 SSAN: 162682593 ORIGINAL X-RAYS REQUESTED ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN - COMPLETE; AND RETURN [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. i hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or CARLISLE REG HOSP-X CUMBERLAND R309774-13 * * * SIGN AND RETURN THIS PAGE * * * n o C? i W n? O f_l `- J co w RACHITI i 13. SYBRANDT a/k/a RACI Il?LLE SYBRANDT Plaintiff MYONG NYO KRYZKOWSKI, Defendant IN TI IL COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3648 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE PREREOUISITF, TO SERVICE. OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoena for documents and things pursuant to Rule 4009.22, Defendant certifies that: (1) a notice of intent to serve subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served; (2) a copy of the notice of intent, including the proposed subpoena, is attached to this certificate; (3) the twenty days notice has expired; 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. By: Date: 840 Last Chocolate Avenue Hershey, PA 17033 (717) 533-5406 (717) 533-5717 Attorney for Defendants Kryzkowski Richard B. Druby, Es ire Attorney I.D. No. 6190 r RACHELLE B. SYBRANDT a/k/a RACHELLE SYBRANDT, Plaintiff V. MYONG NYO KRYZKOWSKI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3648 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendant 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 no objection is made, the subpoena may be served, Subpoena is for the following: Shippensburg University Date: Respectfully submitted, NESTICO, DRUBY & HII By: tchard B. Druby, Esqu're Attorney I.D. No. 6910/ 840 East Chocolate Avenue Hershey, PA 17033 (717) 533-5406 (717) 533-5717 Attorney for Defendants L.L.P. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RACHELLE B. SYBRANDT a/k/a RACHELLE SYBRANDT, Plaintiff V. : NO. 02.3648 CIVIL TERM MYONG NYO KRYZKOWSKI, CIVIL ACTION -LAW Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Shippensburg University C/o Alana G. Moriarty, Registrar 1871 Old Main Drive Shippensburg, PA 17257 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all student record Information from the beginning of enrollment to the present, including, but not limited to, applications, transfer records, degree requirements, courses, grades, transcripts Including any transfer credits, withdrawals and incompletes, detailed course schedule for each semester, acndemic advisors, disciplinary letters, degree anticipation date and any and all other Information regarding the education of Rachelie B. Sybrandt (DOB: 4/9/1970, SSN: 162.68.2593). at 840 East Chocolate Avenue, Hershey, PA 17033 You may deliver or mail legible copies of the documents or produce the 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 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: Richard B. Druby. Esquire Address: 840 East Chocolate Avenue Hershey, PA 17033 Telephone: (717) 533.5406 Supreme Court ID #61904 Attorney for: Defendant Date: Seal of Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy (Eff. 7/97) CERTIFICATE OF SERVICE I, Christiana E. Appleby, of the law firm of Nestico, Druby & Hildabrand, L.L.P., hereby certify that on the day of February, 2005, a copy of the foregoing document was sent via First Class U.S. Mail, postage paid, to the following: Robert F. Claraval, Esquire Claraval & Claraval PO Box 11965 Harrisburg, PA 17108-1965 IVu 1-1. Christiana E. Appleby CERTIFICATE OF SERVICE I, Christiana Appleby, of the law firm of Nestico, Druby & Ilildabrand, LIT, hereby certify that on the 15th day of March, 2005, a copy of the foregoing document was sent via First Class U.S. Mail, postage paid, to the following: Robert F. Claraval, Esquire Claraval & Claraval 500 North Third Street, 2"d Floor Harrisburg, PA 17108-1965 Christiana Appleby RACHELLE B. SYBRANDT a/k/a RACHELLESYBRANDT Plaintiff VS. MYONG NYO KRYZKOWSKI Defendant I : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO 2002-03648 CIVIL ACTION - LAW WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw the appearance of the undersigned as counsel for Defendant, Myong Nyo Kryzkowski, in the above-captioned case. By: RLAY & r66 nd B. Druby, Esquires 1904 840 East Chocolate Avenue Hershey, PA 17033 LLP ........................................................................................... ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the undersigned as counsel for Defendant, Myong Nyo Kryzkowski, in the above-captioned case. MARSHALL DENNEHEY WARNE OLE' & GOGGIN By: Ch p er M. Reeser, Esquire Attorney for Defendant I.D. 73632 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3509 ?? C:S i `? ...•.. - ?i ". _a ?h ?} ? .•... ? Marshall Dennehey Warner Coleman & Goggin By: Christopher M. Reeser, Esquire ID# 73632 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 717-651-3509 Our File No. 16235-00111 Attorney for Defendant RACHELLE B. SYBRANDT a/k/a RACHELLESYBRANDT Plaintiff VS. MYONG NYO KRYZKOWSKI Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO 2002-03648 CIVIL ACTION - LAW NOTICE TO PLEAD TO: Robert F. Claraval, Esquire Claraval and Claraval 500 North Third Street, 2nd Floor Harrisburg, PA 17101-1167 Attorney or Plaintiff You are hereby notified to plead to the enclosed Answer with New Matter within twenty (20) days from service hereof or a default judgment may be filed against you. Respectfully submitted, MARSHALL DENNEHEY WARNER MAN & GOGGIN Dated: November 28, 2006 By: Christopher M. Reeser, Esquire Attorney for Defendant I.D. 73632 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3509 Marshall Dennehey Warner Coleman & Goggin By: Christopher M. Reeser, Esquire ID# 73632 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 717-651-3509 Our File No. 16235-00111 Attorney for Defendant RACHELLE B. SYBRANDT a/k/a RACHELLESYBRANDT VS. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO 2002-03648 MYONG NYO KRYZKOWSKI Defendant . CIVIL ACTION - LAW DEFENDANT'S AMENDED ANSWER WITH NEW MATTER RE: PIGA OFFSET 34. Paragraphs 1-33 of Defendant's Answer with New Matter filed on or about April 17, 2003 is incorporated herein by reference as if set forth at length. 35. At all relevant times, Defendant Myong Nyo Kryzkowski was insured under a policy issued by Shelby Casualty Insurance Company. 36. Defendant Myong Nyo Kryzkowski has been provided a defense in this case under the same policy of insurance issued by Shelby Casualty. 37. On August 1, 2006, the District Court of Travis County, Texas entered an Order of Liquidation with a finding of insolvency against Shelby Casualty Insurance Company effective August 1, 2006, staying this action for 90 days. 38. A copy of the August 1, 2006 District Court of Travis County, Texas Order is attached hereto as Exhibit A. As a result of the August 1, 2006 Order of Liquidation, the provisions of 40 P.S. §991.1817(a) apply to Plaintiffs claims. 39. Plaintiff is required to exhaust all rights under any insurance policy, including but not limited to claims under accident and health insurance, uninsured motorist, underinsured motorist, worker's compensation, Blue Cross and Blue Shield, and all other coverages except for policies of an insolvent insurer. 40. Upon information and belief, certain of Plaintiffs bills for which recovery is sought in this action were paid or are payable under accident and health insurance, Blue Cross and Blue Shield, worker's compensation insurance, automobile insurance or other insurance. 41. Plaintiffs recovery under all other insurance reduces any amount payable by the Pennsylvania Property and Casualty Insurance Guaranty Association (PIGA) and, to the same extent, Plaintiffs claims against Defendant are also reduced. WHEREFORE, Defendant demands judgment in his favor. MARSHALL DENNEHEY WARNE MAN & GOGGIN By: Ch r' er M. Reeser, Esquire Attorney for Defendant Lang I.D. 73632 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 Dated: November 28, 2006 (717) 651-3509 EXHIBIT A Page 1 of II Cause No. D-1-GN-06-002366 THE TEXAS DEPARTMENT OF INSURANCE Plaintiff V. VESTA FIRE INSURANCE CORPORATION et al., Defendants § IN THE DISTRICT COURT OF § 4I § 2,e TRAVIS COUNTY, TEXAS-S § Q? § O ?v § 126th JUDICIAL DISTRICT; 91o w 0001 a b Q ¢ cr ORDER APPOINTING LIQUIDATOR AND PERMANENT INJUNCTION On this day, the Court heard the Application for Order of Liquidation filed by the Commissioner of Insurance for the State of Texas (the "Commissioner"), in his capacity as Rehabilitator of Defendants. The Application requests an order placing Defendants into liquidation pursuant to TEx. INS. CODE §2 1A.151 et seq, and appointing the Commissioner as Liquidator (the "Liquidator"). The Application also requests a Permanent Injunction pursuant to TLx. INS, CODE §21 A.008(a), enjoining Defendants and their agents from conducting Defendants' business, and enjoining other parties from taking any actions against Defendants or their property. The Rehabilitator appeared by and through his counsel of record, and requested that Vesta Fire Insurance Corporation, Shelby Casualty Insurance Company, The Shelby Insurance Company, Texas Select Lloyds Insurance Company and Select Insurance Services, Inc. be placed into liquidation, and that Vesta Insurance Corporation remain in rehabilitation. I. FINDINGS Having considered the Rehabilitator's Application, the evidence and arguments of counsel, the Court finds as follows: 1.1 The Court has jurisdiction over the parties and the subject matter of this action, http://www.ppciga.org/vestaorder.html 11/14/2006 Page 2 of II 1.2 Grounds exist to place Vesta Eire Insurance Corporation, Shelby Casualty Insurance Company, The Shelby Insurance Company, Texas Select Lloyds Insurance Company and Select Insurance Services, Inc, (collectively, the "Liquidated Defendants") into liquidation under TEx INS. CODE §21A.057. These grounds include, but are not limited to, the finding that the Liquidated Defendants are insolvent as defined in TEX. INS. CODE §21 A.004(a)(13). 13 Pursuant to TEX, INS. CODE §21A.151, the Commissioner shall be appointed as Liquidator of the Liquidate. Defendants. 1.4 Grounds exist to continue the rehabilitation of Vesta Insurance Corporation and the Commissioner's appointment as Rehabilitator of Vesta Insurance Corporation. 1.5 The Commissioner, as ltehabilitator or Liquidator, as applicable, is vested by operation of law with title to all of such Defendants' property as dofrned in TEX. INS. CODE §21A.004(a)(20). Such property shall include property of any kind or nature, whether real, personal, or mixed, including but not limited to money, funds, cash, stock, bonds, account deposits, statutory deposits, special deposits, contents of safe deposit boxes, funds held in share accounts or trust accounts, retainages and retainers, letters of credit, real estate, fixtures, furniture, equipment, books, records, documents and insurance policies, intellectual property, computer software and systems, information technology, internet domain names, patents and intangible assets, whether owned individually, jointly, or severally, wherever located, and all rights, claims or causes of action belonging to such Dctcndants, whether asserted or not, including but not limited t9 a"0unts mcivab1c, notes, premiums, subrogation, insurance and reinsurance proceeds, and all licenses held by such Defendants (collectively, "Defendants' Property"). The title to Defendants' fdl oat http;//www.ppciga.org/vestaorder,html 11/14/2006 Page 3 of II [a 009 Property shall extend to all items owned by Defendants, regardless of the name in which such items are held. 1.6 Defendants and their agents shall be required to cooperate with the Rehabilitator or Liquidator, as applicable, pursuant to Tux. INS. CODE §21A.010. 1.7 It is necessary for this Court to issue a permanent injunction pursuant to TEx. INS. CODE §21 A.008(a) to carry out the provisions of TEx. INTs. CODE ANN. Chapter 21 A, and prevent irreparable injury, loss and damage to the general public and Defendants' creditors. A necessity exists to enforce the provisions of TEX. INS. CODE Chapter 21A by enjoining Defendants and their agents from conducting Defendants' business, except as authorized by the Rehabilitator or Liquidator, as applicable; enjoining financial institutions or depositories from taking any actions in connection with Defendants' property, except as directed by the Rehabilitator or Liquidator, as applicable; and enjoining all claimants or creditors from asserting claims or causes of action against Defendants, except as permitted by TEX. INs. CODE. ANN. Chapter 21A. 1.8 Pursuant to TEX. INS. CODs: §21A.008(c), a stay remains in effect with respect to actions against Defendants or their property. In accordance with TEX. INS. CODE §21A.00$(o, such stay of actions against Defendants is in effect for the duration of this proceeding, and the stay of actions against Defendants' property is in effect for as long as the property belongs to the receivership estate. 1.9 Pursuant to TEX. INS. CODE §21A.008(d), a stay remains in effect with respect to actions against insureds covered under policies of insurance issued by Defendants. Such stay is in effect for 90 days after the date of the Agreed Order 4ppolnting Rehabilltator and Permanent hnjuncdon, or such further Nine as crdc=4 by this Court, http://www.ppciga.org/vestaorder.html 11/14/2006 Page 4 of II 0004 1.10 Dcfendants have been provided with proper notice of the Rehabilitators' application as provided in TEX. INS. CODE §21 A.007. H. APPOINTMENT OF LIQUIDATOR IT IS ORDERED that the Commissioner is appointed as Liquidator of the Liquidated .Defendants, and granted the following duties and powers: 2.1 The Liquidator is granted arid given all powers and authority under TEX. INS. CODE Chapter 21 A, and any and, all other powers and authority under applicable statutes and the common law of this State. 2.2 The Liquidator is authorized to conduct the Liquidated Defendants' busimss, administer the Liquidated Defendants' operations, and enter into any contracts necessary to perform the Liquidator's duties, at his discretion, pursuant to TEx INs. CODE §21A.154(a). 2.3 Pursuant to TEX. INS. CODE §21 A.151, title to all of the Liquidated Def'endants' Property, including but not limited to all the assets and rights described in this Order Appointing Liquidator and Permanent injunction, is vested in the Liquidator. The Liquidator is authorized to take oontrol and possession of the Liquidated Defendants' Property, wherever located, and remove all such property from such Defendants' prernim, 2,4 The Liquidator is vested wrath all of the Liquidated Defendants' rights as the customer of any bank, financial institution or other depository. The Liquidator is authorized to withdraw the Liquidated Defendants' Property from any such entity or any state or federal agency, or continue the operation of any accounts of Defendants, at his discretion. 2.5 Pursuant to TEx. INS. CODE §21A.154, the Liquidator has all the powers of the Liquidated Defendants' directors, officers, and managers, and the authority of such directors, officers, and managers is suspended, except as pennitted by the Liquidator. http://www.ppciga.org/vestaorder.html 11/14/2006 Page 5 of II Q005 The Liquidator is authorized to supervise, suspend, terminate, or dismiss any or all of the direCWTS, officers, managers, employees or agents of the Liquidated Defendants, or retain such persons at his discretion, and compensate them as he deems necessary from the Liquidated 1<lafendants' funds. 2.6 The Liquidator is authorized to retain any professional, administrative, and clerical services as he deems necessary pursuant to TEX. INS. CODE §2IA. 154. The Liquidator is further authorized to set the compensation of such persons, and pay for such services from the Liquidated Defendants'. funds pursuant to TEX. INS. CODE §21A.0I5(e), 2.7 The Liquidator is authorized to receive, aallec, control, open and review all mail addressed to or intended for the Liquidated Defendants, 2.8 The Liquidator is authorized to file, prosecute, defend, or settle any action as he deems necessary, including any action to enforce the provisions of this order. 2.9 The Liquidator is authorized to exclude any person from any property owned, ]cased or occupied by the Liquidated Defendants, at his discretion. 2,10 The Liquidator is authorized to assume or reject any contracts to which the Liquidated Defendants are a party at his discretion pursuant to TEX. INS. CODE §21A.01 3. 2.11 The Liquidator is authorized to pay benefits under workers compensation policies as provided in TEX, INS. CODE §21A.302. 2.12 The Liquidator is authorized to tape any action to effectuate any tr4naactions that have been initiated by the Rehabilitator to transfer policies of insurance under TFx. INS. CODE §21A.102, and may transfer such policies pursuant to TEX. INS. CODE §21 A.154(h). 2.1a Pursuant to TEX, iNB. CODE §21A.008(m), the Commissioner is not required to file a bond. http://www.ppciga,org/vestaorder.html 11/14/2006 Page 6 of II Q 006 2.14 in the event a successor is appointed to be the Commissioner, the successor shall become the Liquidator upon his appointment as Commissioner, and the former Commissioner shall be discharged as Liquidator as a matter of law. 2.15 The Liquidator has authorized James A. Guillot, Conservator for the Texas Department of Insurance, to tact on his behalf, A Special Deputy appointed under TEX. 1Ns. CODE §2IA.102(a) shall also have. all the rights and powers of the Liquidator, subject to any limitations imposed by the Liquidator. (.ll. PERMANENT INJUNCTION It is FURTHER ORDERED that the Clerk of this Court shall issue a Permanent 1r unction against the persons and entities named below, with the following force and effect: TO; Defendants and their agents inclWiilz but not limited to: Defendants and their current and former officers, trustees, directors and underwriters (including but not limited to David W. Laceficid, C. David Emery, Stephen F. Russell, Russell K, Crouch, Danny E. Laffey, Michael W, Peters, C. Ray Smith, III, Fred H. Wright, Robert J. McLaughlin„ Jr., John W. McCullough, George M. Orin, Ronald A. Deep, Martha Etta Joiner, Bobby L. Nolen, Norman W. Gayle, III, and Donald W, Thornton), owners (including but not limited to Vesta Insurance Group, Inc.), affiliates (including but not limited to J. Gordon Gaines, Inc.), managers, employees, agents, servants, representatives, attorneys, adjusters and other persons or entities acting on behalf of the Liquidated Defendants; Financial institutions, inclu ' z. but not limited to: any and all banks, savings and loan associations; trust companies, ertclit unions; welfare trusts; or any other financial or depository institutions in the possession of any of Defendants' Property, and AI other parties. including but not limited tQ: policyholders, creditors, claimants, reinsurers, intermediaries, attorneys and all other persons, associations, corporations, or any other legal entities: asserting claims or causes of action against Defendants, or in possession of any of Defendants' Property, and the United States postmaster. http://www.ppciga.org/vestaorder.html 11/14/2006 Page 7 of II Each of you are hereby RESTRAINED and ENJOINED from taking any and all of the following actions: Z007 3.1 Doing, operating, or conducting Defendants' business under any charter, certificate of authority, license, permit, power or privilege belonging to or issued to Defendants, or exercising any direction, control, or influence over Defendants' business, except through the authority of the Rehabilitator or Liquidator, as applicable, or his designees; 3.2 Transacting any business of Defendants in any manner except through the authority of the Rehabilitator or Liquidator, as applicable, or his'desigmees; 13 Using, releasing, transferring, selling, assigning, canceling, hypothecating, withdrawing, allowing to be withdrawn, offsetting, asserting ownership of, or removing from this Court's jurisdiction! & from Defendants' place of business, any of Defendants' Property or any other property purchased by Defendants, or any items into which such property has been transferred, deposited or placed, except through the authority of the Rehabilitator or Liquidator, as applicable, or his designees; 3.4 Wasting, disposing of, converting, dissipating, or concealing, in any manner, any of Defendants' Property; 3.5 Doing anything, directly or indirectly, to prevent the Rehabilitator or Liquidator, or.his designees, from gaining access to, acquiring, examining, or investigating any of Defendants' Property or any other property, books, documents, records, or other materials concerning Defendants' business, under whatever name they may be found; 3.6 Obstructing or interfering in any way with the conduct of this proceeding or any incidental investigation as prohibited by TFx. INS. CODE §21A.01 0(b); http://www.ppciga.org/vestaorder.html 11/14/2006 Page 8 of II 3.7 Intervening in this proceeding for the purpose of obtaining a payment from the receivership estate of the Defendants as prohibited by TEX. INS. CODE §21A.005(i); 3.8 ;flaking any claim, charge or offset, or commencing or prosecuting any action, appeal, or arbitration, including administrative proceedings, or obtaining any preference, judgment, attachment, garnishment, or other lien, or making any levy against Defendants, their property or any part thereof, or against the Rehabilitator or Liquidator, as applicable, except as permitted by TEX. Ins. Char; ANN. Chapter 21 A. EACH OF YOU ARE FURTHER ORDERED to make available and disclose to the RehaWitator or Liquidator, as applicable, or his designees, the nature, amount, and location of any and all of the items listed above, including but not limited to Defendants' Property, and immediately surrender all such property to the Rehabilitator or Liquidator, as applicable, or his designees. DEFENDANTS AND THEIR AGENTS ARE FURTHER ORDERED to cooperate with the RehaWitator or Liquidator, as applicable, or his designees, as required by TEX INS. CODE §21 A,010(a). IT 15 FURTHER ORDERED that the United. States Postmaster and any other delivery services shall deliver to the Rehabilitator or Liquidator, as applicable, or his designees, any items addressed to or intended for Defendants. IV. CONTINUATION OF COVERAGE 4.1 All reinsurance contracts by which the Liquidated Defendants have assumed the insurance obligations of another insurer arc canceled upon entry of this order pursuant to TEX. INS. CODE § 21A.252(a). Q006 http://www.ppciga.org/vestaorder.html 11/14/2006 Page 9 of II 4.2 Pursuant to TEX. 1NS. CODE § 2IA.]52(b), all policies, insurance contracts, surety bonds or surety undertakings of the Liquidated Defendants in effect at the time of issuance this order, other than life insurance, health insurance or annuities, continue in force only until the earlier of: (a) the date of the expiration of the policy; (b) the date the insured has replaced or terminated the policy, (c) August 24, 2006 at 12:01 a.m., the date and time of the Rehabititator's cancellation of policies issued by all of the Defendants under the authority granted in the Agreed Order Appointing Rehabilitator and Permanent Injunction pursuant to Tux. INS. CODE §21 A, I 02(b); or (d) the date that the Liquidator has transferred any policies pursuant to TEX. INS. CODE §21 A.154(h). In this event, such policies will continue in force with respect to the coverage provided by the insurer to which the policies are transferred. V, STAY OF PROCEEDINGS 5.1 An automatic stay remains in effect with respect to actions against Defendants or their property as provided by TEX. INS. COME §21 A.008(c). In accordance with TEX. INS. CODE §21 A.008(f), such stay of actions against Defendants is in effect for the duration of this proceeding, and the stay of actions against their property is in effect for as long as the property belongs to the receivership estate. 5.2 An automatic stay remains in effect with respect to actions against a person insured by Defendants as provided by TeX. INS. CODE §21A.008(d). Such stay is in effect for 90 16009 http://www.ppciga.org/vestaorder.html 11/14/2006 Page 10 of II zoso days after the entry of the Agreed Order Appointing Rehabilitator and Permanent Injunction, unless extended by this Court. 5.3 The stays in effect pursuant to TEX. INS. CODE §21A.008 shall he applicable to any actions described therein eommenced either before or after the entry of this order. VI. OTHER ORDERS 61 Vesta Insurance Corporation shall remain subject to the Agreed Order Appointing Rehabilitator and Permanent Injunction, and such ardor will continue in full force and effect with respect to Vesta Insurance Corporation. The Commissioner will continue to act as Rehabilitator of Vesta Insurance Corporation. 6.2 This Order Appointing Liquidator and Permanent Injunction shall issue and become etTective immediately, and shall continue in full force and effect until the entry of an order by this Court terminating this proceeding under TEX, INS. CODE §21 A.352. 6.3 Pursuant to TEX. INs. CODE 421A.055(b), this Order Appointing Liquidator and Permanent Injunction constitutes a final judgment, provided that this Court shall retain jurisdiction to issue further orders pursuant to Tax INS. CODE ANN. Chapter 2IA. 6.4 The terms of this Order Appointing Liquidator and Permanent Injunction shall not be construed to infringe upon the authority of any state insurance regulator in connection with any of Defendants' aftiliate$ th4t are domiciled in other states, 6.5 Pursuant to TFX. INS. CODE §21A.007(e), the Liquidator may provide notice of any application in the time periods prescribed in Rule 21(a) of the Texas Rules of Civil Procedure if he determines that an expedited hearing is necessary. In accordance with http-.//www.ppciga.org/vestaorder.html 11/14/2006 Page II of II ,rEX, INS, CODE §21A.007(d), the Liquidator alay provide notice of any application by first class mail, electronic mail, or facsimile transmission, at has discretion. 6.6 The State of Texas and the Attorney General of Texas shalt have a claim for reasonable attorneys' fees and court costs pursuant to TF-X CrV. PRAC. & RF,M. CoDL• ANN, §§ 64.051 and 66.003 and TGX. GOVT CODE § 402.006, and the amount and payment of such claim are subject to the provisions of TEX. INS. CODE ANN, Chapter 21 A. 6.7 Anyone over the age of 18 whom is not a party to nor interested in the outcome of this suit may serve all citations, writs and notices in this cause. SIGNED at Austin, Travis County, Texas, on this the I day of 2006, at ' . o'clock -e--m laoll f DISTRICT E PRESID \--1 ?5 SUBMITTED NO HEARING REQUIRED. RECOMMENDE4, SIGNED ON DAY 01?'ri`w 'QOM COLLINS, RECEIVE ISHIP SPECIAL MASTER http://www.ppciga.org/vestaorder.htmi 11/14/2006 ? , :. ? FE1 f..» r .w _ t ? ? -' "'C? Y i..l "-1 ?c N > :? ? ? .....a Marshall Dennehey Warner Coleman & Goggin By: Christopher M. Reeser, Esquire ID# 73632 4200 Crams Mill Road, Suite B Harrisburg, PA 17112 717-651-3509 Our File No. 16235-00111 Attorney for Defendant RACHELLE B. SYBRANDT a/k/a RACHELLESYBRANDT Plaintiff VS. MYONG NYO KRYZKOWSKI Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO 2002-03648 : CIVIL ACTION - LAW STIPULATION The parties do hereby stipulate and agree that Defendant's Answer with New Matter is hereby amended consistent with the document attached hereto. Plaintiff shall have 20 days to file a reply to Defendant's Amended New Matter. AL AND CLA2AVAL By: By: Q7-5b?ert F. C araval, Esquire Attorney for Plaintiff 500 North Third Street, 2nd Floor Harrisburg, PA 17101 MARSHALL DENNEHEY 1?9LEMAN & GOGGIN WARN 7 I 5_ Chris opher M. Reeser, Esquire Attorney for Defendant Lang I.D. 73632 4200 Crams Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3509 ? Q ?? ? ?? ,?-, c.= a.. ? t?_ ,?,. y ? ?..?; '???;.?' ??? ? ??? .,fN ? c? ? ? :.? -.? Marshall Dennehey Warner Coleman & Goggin By: Christopher M. Reeser, Esquire ID# 73632 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 717-651-3509 Our File No. 16235-00111 Attorney for Defendant RACHELLE B. SYBRANDT a/k/a RACHELLESYBRANDT VS. Plaintiff MYONG NYO KRYZKOWSKI Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO 2002-03648 : CIVIL ACTION - LAW CERTIFICATE OF SERVICE I, Christopher M. Reeser, Esquire, of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on November 28, 2006, I served a copy of Defendant's Amended Answer with New Matter re: PIGA Offset via First Class United States mail, postage prepaid as follows: Robert F. Claraval, Esquire Claraval and Claraval 500 North Third Street, 2nd Floor Harrisburg, PA 17101-1167 Attorney for Plaintiff Christopher M. Reeser r4l -j Robert F. Claraval, Esq. CLARAVAL & CLARAVAL 500 North Third Street, 2nd Floor Harrisburg, PA 17101 (717) 233-4780 Supreme Court I.D. 19222 Attorney for Plaintiff RACHELLE D. SYBRANDT a/k/a RACHELLE SYBRANDT Plaintiff V. MYONG NYO KRZYKOWSKI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : No. 2002-03648 CIVIL ACTION -LAW PLAINTIFF'S REPLY TO DEFENDANT'S AMENDED ANSWER WITH NEW MATTER RE: PIGA OFFSET 34. No answer is required. 35. Admitted. 36. Admitted. 37. Admitted. 38. Admitted. 39. Denied. Paragraph 39 is a conclusion of law to which no response is required. 40. It is admitted that certain of Plaintiff Rachelle Sybrandt's bills were paid by other sources. 41. Denied. Paragraph 41 is a conclusion of law to which no response is required. CLARAVAL & CLARAVAL Date: 0 ?o B ROBER .CLARAVAL 500 North Third Street, 2nd Floor Harrisburg, PA 17101 (717) 233-4780 Supreme Court I.D. # 19222 Attorneys for Plaintiff VERIFICATION I, Robert F. Claraval, being duly sworn according to law, depose and state that I am the attorney for the Plaintiff in this action and that the information contained in the foregoing document is true and correct to the best of my knowledge, information, and belief. I understand that any false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. 0 BERT F. CLARAVAL, ESQ. r RACHELLE D. SYBRANDT a/k/a RACHELLE SYBRANDT Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2002-03648 MYONG NYO KRZYKOWSKI, CIVIL ACTION -LAW Defendant CERTIFICATE OF SERVICE I hereby certify that I have this day served a true and correct copy of the attached Plaintiffs Reply to Defendant's Amended Answer with New Matter Re: PIGA Offset by first class mail, postage prepaid, addressed to the following person: Christopher M. Reeser, Esq. Marshall, Dennehey, Warner, Coleman & Goggin 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 CLARAVAL & CLARAVAL Date: I & k& By DENISE I. W LIAMS t1 ?' C.7 ?- ? -n _ -t^' , J ? 1' ,j`^.- _i? -- F7 _ -. l.t? --t v l.!-: ? RACHELLE D. SYBRANDT a/k/a RACHELLE SYBRANDT Plaintiff V. MYONG NYO KRZYKOWSKI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2002-03648 : CIVIL ACTION -LAW CERTIFICATE OF SERVICE I hereby certify that I have this day served the attached Answers to Interrogatories Directed to Plaintiff Rachelle D. Sybrandt by first class mail, postage prepaid, addressed to the following person: Christopher M. Reeser, Esq. Marshall, Dennehey, Warner, Coleman & Goggin 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 CLARAVAL & CLARAVAL Date: 1A laoko Ey ' DENISE I. WILLIAMS c.? ? -? i --s ?? ?,? } '1? ? f e' ?.?,I _i `.?. `,. ? i, r. "-? .? '7J k 0 IN THE MATTER OF: SYBRANDT KRZYLOWSKI CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA U_ A PURSUANT TO RULE 4009.22 COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 2002-03648 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CHRISTOPHER REESER, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 03/17/2008 on--b if of CHRISTOP R REESER, ESQ. Attorney for DEFENDANT R1.51 118-H DE11 68926-LO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: SYBRANDT -VS- KRZYLOWSKI COURT OF COMMON PLEAS TERM, CASE NO: 2002-03648 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 CAPITAL BLUE CROSS HEALTH ONE INSURANCE TO: ROBERT F. CLARAVAL, ESQ., PLAINTIFF COUNSEL MCS on behalf of CHRISTOPHER REESER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/25/2008 CC: CHRISTOPHER REESER, ESQ. - 16235-00111 Any questions regarding this matter, contact MCS on behalf of CHRISTOPHER REESER, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.49S 118-H DE02-0386869 68926-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SYBRANDT vs. KRZYLOWSKI File No. DA -31048 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CAPITAL BLUE CROSS HEALTH ONE (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 Trod 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: CHRISTOPHER REESER, ES ADDRESS: 4200 CRUMS MITT. ROAn TELEPHONE: (15) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY T URT HE : Proth notary/ i it vision MAR 1 7 2008 Date: aZ Deputy Seal of the Court 68926-01 4V 4 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CAPITAL BLUE CROSS HEALTH ONE P.O. BOX 890126 CAMP HILL. PA 17089 RE: 68926 RACHELLE DEIDRE SYBRANT Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. COPY OF BILL CONCERNING THE INSURANCE POLICY FILE REGARDING CONTRACT ID# H177680083 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 plaintiffs claim, payments including dates of payments, payee and reasons for payments, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: from: 08-11-2000 to 09-09-9999. Subject : RACHELLE DSIDRB SYBRANT 70 STATION RD, NEVPVILLE, PA 17241 Date of Birth: 04-09-1970 Date of Loss: 08/11/2000 R1.49S 118-H SU10-0722656 68926-LO1 ?^; n<? ? ? Ta ?' ?::? T -r _._ r .:-t: ; -? t ?- C` -- ?- _.> G??3 w rir 't C.? ..,,? CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SYBRANDT COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- KRZYLOWSKI CASE NO: 2002-03648 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CHRISTOPHER REESER, 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: 08/21/2009 MCS on behalf of /S/ lfhrijtopher /CeeJer, ?dc CHRISTOPHER REESER, ESQ. Attorney for DEFENDANT R1.86S 133-H DE11-0951805 68926-L02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: SYBRANDT -VS- KRZYLOWSKI COURT OF COMMON PLEAS TERM, CASE NO: 2002-03648 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 JOSEPH F.DEMARIO,D.O MEDICAL RECORDS TO: ROBERT F. CLARAVAL, ESQ., PLAINTIFF COUNSEL MCS on behalf of CHRISTOPHER REESER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/30/2009 MCS on behalf of CHRISTOPHER REESER, ESQ. Attorney for DEFENDANT CC: CHRISTOPHER REESER, ESQ ROBERT F. CLARAVAL, ESQ. CLARAVAL & CLARAVAL 500 N. 3RD. ST. 2ND FL. P.O. BOX 11965 HARRISBURG_ PA 171081965 16235-00111 THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.86S 133-H DE02-0543059 68926-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SYBRANDT VS. KRZYLOWSKI File No. 2002-03648 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JOSEPH F.DEMARIO.D.O. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: * * * * SEE ATTACHED RIDER * * * * at The MCS Group, Inc. 1601 Market Street, Suite 800, Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CHRISTOPHER REESER. ES ADDRESS: 4200 CRUMS MILL ROAD TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant AUG 212009 Date: JLJw Seal of the Court BY THE COURT: fij -- Prothonotary/Clerk, Civil DiV" Deputy 68926-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOSEPH F.DEMARIO,D.O. INTERNAL MEDICINE 6 MARKET PLAZA MECHANICSBURG, PA 17055 RE: 68926 RACHELLE DEIDRE SYBRANT Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO INPATIENT RECORDS, OUTPATIENT RECORDS, PT RECORDS, REHAB RECORDS, LAB REPORTS, XRAY FILMS, MRI'S,CT SCANS OR OTHER DIAGNOSTIC TESTING PERFORMED TOGETHER WITH ALL DIAGNOSTIC REPORTS, MEDICAL REPORTS, NOTES, MEMORANDA, CORRESPONDENCE AND MEDICAL BILLS Dates Requested: up to and including the present. Subject : RACHELLE DEIDRE SYBRANT 70 STATION RD, NEWVILLE, PA 17241 Date of Birth: 04-09-1970 R1.86S 133-H SU10-0796992 68926-LO2 toTARY OF THE r ' "t .,n 2 Gfl9 A?Jv 214 Fig 2*' 3 RACHELLE D. SYBRANDT IN THE COURT OF COMMON PLEAS OF a/k/a RACHELLE SYBRANDT :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v• No.2002-03648 MYONG NYO KRZYKOWSKI, :CIVIL ACTION -LAW Defendant . PRAECIPE ?~''~~ - ~~~~ {,r3 ~L _. ~~ _ ;~ i ~ `~., TO THE PROTHONOTARY: c ; =~= ~~ ~= .. :=s Please mark the above captioned action settled and discontinued. CLARAVAL & CLARAV. Date: ~ ~ ~ ~d By: ROBERT F.CLARAVAL' 500 North Third Street, 2nd Floor Harrisburg, PA 17101 X717)233-4?80 Supreme ;ourt LL'. #19222 Attorneys for Plaintiff Marshall Dennehey Warner Coleman & Goggin By: Christopher M. Reeser, Esquire ID# 73632 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 717-651-3509 Our File No. 16235-00111 Attorney for Defendant RACHELLE B. SYBRANDT aik/a RACHELLESYBRANDT vs. Plaintiff Iv1YONG NYO KRYZKOWSKI Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO 2002-03648 CIVIL ACTION -LAW CERTIFICATE OF SERVICE I, Christopher M. Reeser, Esquire, of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on February 23, 2010, I served a copy the Praecipe to discontinue via First Class United States mail, postage prepaid as follows: Robert F. Claraval, Esquire Claraval and Claraval 500 North Third Street, 2nd Floor Harrisburg, PA 17101-1167 Attorney for Plaintiff ~,. ~- Christopher M. 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