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HomeMy WebLinkAbout02-3995THIS IS A MAJOR JURY MATTER An assessment of damages is required LAW OFFICES OF STEVEN D. JANEL BY: Steven D. Janel, Esquire Identification No: 73016 1200 Walnut Street Fifth Floor Philadelphia, PA 19107 (215) 772-9080 APRIL CRONE 1131 Old Willow Mill Road Mechanicsburg, PA 17055 V. LAURA LINDSAY 103 Bungalow Road Enola, PA 17025 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKETNO.: 0,2. 39q5' ?(~XP CIVIL ACTION - LAW NOTICE You have been sued in court, if you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the 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 Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 THIS IS A MAJOR JURY MATTER An assessment of damages is required LAW OFFICES OF STEVEN D. JANEL BY: Steven D. Janel, Esquire Identification No: 73016 1200 Walnut Street Fifth Floor Philadelphia, PA 19107 (215) 772-9080 APRIL CRONE 1131 Old Willow Mill Road Mechanicsburg, PA 17055 V. LAURA LINDSAY 103 Bungalow Road Enola, PA 17025 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKETNO.: o,,~. ~qt~' CWIL ACTION - LAW CIVIL ACTION COMPLAINT Plaintiff April Crone, by counsel Steven D. Janel, Esquire, hereby demands damages from the Defendant herein, and in support thereof avers: 1. Plaintiff April Crone is an individual and resides at the above-captioned address. 2. Defendant Laura Lindsay is an individual and resides at the above-captioned address. 3. At all times relevant herein, the Defendant owned, operated, maintained and controlled a 1998 Ford Taurus motor vehicle bearing Pennsylvania license plate number BAG-9822, which was being driven by the Defendant. 4. On August 24, 2000, the Plaintiffwas a passenger in a motor vehicle traveling on the northbound entrance ramp to I-81 in Silver Spring Township, Pennsylvania, when the stopped motor vehicle in which she traveling was violently struck in the rear by the motor vehicle operated by the Defendant. 5. This collision was the direct and proximate result of the joint or several and direct or vicarious negligence of the Defendant. 6. As a direct and proximate result of the joint or several and direct or vicarious negligence and recklessness of the Defendant, the Plaintiffhas sustained injuries and damages which may include: (a) Serious and permanent personal injuries, including, but not limited to, those to her cervical, thoracic and lumbar areas; (b) Past medical expenses incurred for the diagnosis, treatment and cure of the said personal injuries, as well as other out-of-pocket expenses and economic loss; (c) Future medical expenses incurred for the diagnosis, treatment and cure of the said personal injuries, as well as other out-of-pocket expenses and economic loss; (d) Past pain; (e) Future pain; (f) Past suffering; (g) Future suffering; (h) Embarrassment and humiliation; (i) Past loss of enjoyment of life; (j) Future loss of enjoyment of life. WHEREFORE, Plaintiff April Crone hereby demands compensatory damages fxom the Defendant herein, jointly, severally and/or vicariously, plus interest thereon and costs. LAW OFFICES OF STF~EN D. JANEL BY: SAteven~D J~el'~Esquirettorney [pr Plaintiff ' VERIFICATION I, April Crone, am the Plaintiff in the instant matter, and I verify that the statements made in the Civil Action Complaint 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. April Crone SHERIFF'S RETURN - CASE NO: 2002-03995 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CRONE APRIL VS LINDSAY LAURA REGULAR BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LINDSAY LAURA the DEFENDANT , at 2111:00 HOURS, at 103 BUNGALOW ROAD ENOLA, PA 17025 LAURA LINDSAY a true and attested copy of on the 9th day of September, 2002 by handing to COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff,s Costs: Docketing 18.00 Service 10.35 Affidavit .00 Surcharge 10.00 .00 38.35 Sworn and Subscribed to before me this /5 ~ day of ~ J(*~ A.D. P~o~honot ary So Answers: R. Thomas Kline 09/10/2002 STEVEN JANEL By: Deput~ Sheriff THOMAS, THOMAS & HAFER, LLP C. Kent Price, Esquire I.D. No. 06776 305 North Front Street P. O. Box 999 Harrisburg, PA 17108 (717) 255-7632 APRIL CRONE, LAURA L NDSAY, Plaintiff Defendant Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3995 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of THOMAS, THOMAS & HAFER, LLP as counsel on behalf of Defendant Laura Lindsay in the above-captioned matter. All papers may be served upon the undersigned at P.O. Box 999, Harrisburg, PA 17108-0999. THOMAS, THOMAS & HAFER, LLP C. Kent Price, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7632 I.D. No. 06776 CERTIFICATE OF SERVICE AND NOW, this '~(~)-r~'ay of September, 2002, I, C. KENT PRICE, ESQUIRE, for the firm of THOMAS, THOMAS & HAFER, LLP, attorneys for Defendant, hereby certify that I have this day served the within Praecipe for Entry of Appearance by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Steven D. Janel, Esquire Law Offices of Steven D. Janel 1200 Walnut Street Fifth Floor Philadelphia, PA 19107 C. Kent Price, Esquire THOMAS, THOMAS & HAFER, LLP C. Kent Price, Esquire I.D. No. 06776 305 North Front Street P. O. Box 999 Harrisburg, PA 17108 (717) 255-7632 Attorney for Defendant APRIL CRONE, LAURA LINDSAY, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA iNO. 02-3995 CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO: April Crone c/o Steven D. Janel, Esquire Law Offices of Steven D. Janel 1200 Walnut Street Fifth Floor Philadelphia, PA 19107 YOU ARE HEREBY notified to plead to the enclosed New Matter within twenty (20) days of service hereof or a default judgment may be entered against you. DATED: THOMAS, THOMAS & HAFER, LLP C. Kent Price'., Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7632 ATTORNEYS FOR DEFENDANT THOMAS, THOMAS & HAFER, LLP C. Kent Price, Esquire I.D. No. 06776 305 North Front Street P. O. Box 999 Harrisburg, PA 17108 (717) 255-7632 Attorney for Defendant APRIL CRONE, LAURA LINDSAY, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3995 CIVIL ACTION - LAW JURY TRIAL DEMANDED 2. 3. 4. DEFENDANT'S ANSWER WITH NEW MATTER Admitted. Admitted. Admitted. Admitted in part, denied in part. The allegation that the vehicle in which Plaintiff was riding as a passenger 'mas struck "violently" is a conclusion of law and/or fact to which no answer is required. To the extent that an answer may be required, the allegation is denied pursuant to Pa.R.C.P. 1029(e). The remaining allegations are admitted. Denied. The allegations are conclusions of law and/or fact to which no answer is required. To the extent that an answer may be required, the allegations are denied pursuant to Pa.R.C.P. 1029(e). Denied. The allegation that the Defendant caused injuries and damages to the Plaintiff as the result of negligent and reckless acts or omissions is a conclusion of law and/or fact to which no answer is required. To the extent that an answer may be required, the allegation is denied pursuant to Pa.R.C.P. 1029(e). The remaining allegations regarding the injuries and damages sustained by the Plaintiff are denied on the basis that, after reasonable investigation, the Defendant is without information or knowledge sufficient to form a belief as to the truth thereof. WHEREFORE, Defendant Laura Lindsay demands judgment in her favor and against Plaintiff April Crone. NEW MATTER o The Plaintiff's claims may be barred or limited by application of provisions of the Motor Vehicle Financial Responsibility Law, including but not limited to 75 Pa.C.S.A. 1722 The Plaintiff's claims may be barred by the applicable tort option election. The Plaintiff's injuries may not qualify as "serious" which would, therefore, bar her claims for non-economic losses. 10. Some or all of Plaintiff's alleged injuries may be due to pre-existing conditions. 11. Plaintiff may have failed to mitigate her damages. WHEREFORE, Defendant Laura Lindsay demands judgment in her favor and against Plaintiff April Crone. THOMAS, THOMAS & HAFER, LLP C. Kent Price, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7632 :184354.1 VERIFICATION I verify that the facts set forth in the foregoing Answer with New Matter are true and correct to the best of my information, knowledge and belief. I understand that any false statements contained herein are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. ~a/~ ra Lindsay CERTIFICATE OF SERVICE AND NOW, this .~-k~ day of November, 2002, I, C. KENT PRICE, ESQUIRE, for the firm of THOMAS, THOMAS & HAFER, LLP, attorneys for Defendant, hereby certify that I have this day served the within Answer with New Matter by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Steven D. Janel, Esquire Law Offices of Steven D. Janel 1200 Walnut Street Fifth Floor Philadelphia, PA 19107 THOMAS, THOMAS & HAFER, LLP C. Kent Price, Esquire APRIL CRONE, Vo LAURA LINDSAY, Plaintiff Defendant IN THE COURT OF COMMO? CUMBERLAND COUB PENNSYLVANIA NO. 02-3995 CIVIL ACTION - LA JURY TRI~L DEMAN] DEFENDANT'S MOTION TO COMPEL DISCOVERY RES FROM PLAINTIFF 1. The instant cause of action stems from alleged injuries sustai~ Crone as a result of a motor vehicle accident that occurred on August 24, 200i 2. On or about September 30, 2002, Defendant served Plaintiff and Request for Production of Documents, true and correct cepies of which as Exhibit "A." 3. Having received no response to the aforesaid discovery reque! directed a letter to Plaintiff's counsel dated January 2, 2003, inquiring discovery responses, a true and correct copy of such correspondence bein Exhibit "B". 4. The undersigned directed another letter to Plaintiff's attorne, 2003, enclosing additional copies of Defendant's Interrogatorie, s and Reques Documents and requesting that Plaintiff respond to the outstanding discovery correct copy of such correspondence being attached hereto as Exhibit "C". 5. Having received no response to the discovery requests, the m another letter to Plaintiff's counsel dated February 28, 2003, requestin: 'PLEAS OF 'TY, ~r )ED 'ONSES ~d by Plaintiff April ). Mth Interrogatories are attached hereto ;ts, the undersigned ts to the status of attached hereto as dated January 15, for Production of :quests, a true and .dersigned directed that Defendant's discovery requests be answered within 21 days of the date of fine letter, a tm, such correspondence being attached hereto as Exhibit "D". 6. Despite the passage of more than six (6) months since the with the aforesaid discovery request, Plaintiff has failed to answer or object sought a protective order limiting or otherwise qualifying her obligation to has she sought or obtained an extension of time within which to respond. 7. Defendant is prejudiced in her ability to prepare a defense to Plaintiff due to the continuing refusal and/or failure of Plaintiff April C aforesaid discovery requests previously served upon her, which refusal i without legal basis. WHEREFORE, Defendant Laura Lindsay respectfully request that tl~ direct Plaintiff April Crone to file full, complete, specific and detaile, objection, to all outstanding Interrogatories and Request for Production ol twenty (20) days or suffer appropriate sanctions. THOMAS, THOMAS & HAFE C. Kent Price, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7632 I.D. No. 06776 ATTORNEYS FOR DEFENDA LINDSAY 231391 and correct copy of ?laintiff was served thereto, nor has she :espond thereto, nor the claims made by tone to answer the unreasonable and s Honorable Court answers, without Documents within [, LLP qT LAURA THOMAS, THOMAS & HAFER, LLP C. Kent Pdce, Esquire I.D. No. 06776 305 North Front Street P. O. Box 999 Harrisburg, PA 17108 (717) 255-7632 Attorney for APRIL CRONE, LAUP, A LINDSAY, Plaintiff Defendant IN THE COURT OF COMMO OF CUMBERLAND COUN PENNSYLVANIA NO. 02-3995 CIVIL ACTION - LAY JURY TRIAL DEMAND INTERROGATORIES DIRECTED TO PLAINTIFF TO: April Crone cio Steven D. Janel, Esquire Law Offices of Steven D. Janel 1200 Walnut Street Fifth Floor Philadelphia, PA 19107 PLEASE TAKE NOTICE that you are hereby required, pursuan Rules of Civil Procedure, Rule 4005 and 4006, as amended, to file the upon the undersigned a copy of your Answers and Objections, if any, in oath to the following Interrogatories within thirty (30) days after Interrogatories. The Answers shall be inserted in the space provii insufficient space to answer an Interrogatory, the remainder of the Answ( supplemental sheet. These shall be deemed to be continuing Interrogatories. If be1 your Answers and the time of trial of this case, you, or anyone acting on )efendant N PLEAS I'Y, ED to Pennsylvania ~dginal and serve writing and under service of the Jed. If there is shall follow on a feen the time of four behalf, learn of any further Information not contained in your Answers, you shall pre information to the undersigned by Supplemental Answers. THOMAS, THOMAS & HAFEF C. Kent Price, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 1'7108-0999 (717) 255-7632 mptly furnish said ~, LLP ATTORNEYS FOR DEFEND,~ NT INTERROGATORIES 1. State your full name, current residence address, date marital status. ANSWER: 2. State the name and business address of your current em your employment began. If you are presently retired, state the date yc and address of your employer at the time of your retirement, and a bri~ nature of your occupation at that time. ANSWER: 3. State your present job title and set forth requirements/responsibilities of your current position, and the length of ! that capacity. ANSWER: birth, and current Ioyer and the date retired, the name ~ description of the in detail the our employment in 4. For the five (5) years immediately preceding the date o' which this claim arose, state: (a) the name and address of each of your employers or employed, each of your business addresses and the na while self-employed; (b) the dates of commencement and termination of each employment or self-employment; (c) a detailed description of the services of work performed employment or self-employment; (d) the name of your immediate superior to whom you were r of the places of employment listed above; and (e) the reason for the termination of each employment or self- ANSWER: the incident out of if you were self ne of the business af your periods of for each source of .~sponsible at each employment. state: 5. If you were employed at the time of the incident referred (a) (b) (c) (d) the name and business address of your employer; the position you held and the nature of the work you perf( the date your employment began; and the average weekly earnings/wages you received fc immediately preceding the incident. ANSWER: :o in the Complaint, rmed; and r the six months 6. If you have lost any time from your business or occupati~ the incident referred to in the Complaint, state: (a) the number of days lost and the dates thereof; and (b) the amount of any earnings/wages lost, together with an such amount was calculated. ANSWER: ~n since the date of explanation of how (a) (b) (c) If you are making a claim for lost income or loss of eamin the basis for such claim; the amount of such claim; and an explanation of how this amount was calculated. ANSWER: o (a) (b) If you are making a claim for past or future medical expen the amount of such claim; and itemize each health care provider who thereof and the charges made therefor. ANSWER: has rendered s~ capacity, state: ~s, state: .~rvices, the dates 9. List all other financial losses for which you claim sp, provide an itemization of the amount of each, setting forth the manner itemization was calculated. ANSWER: 10. List all social, recreational, family or other activities and hc participated or engaged in the five (5) years immediately before the ini this claim arises. ANSWER: ;cial damages and )y which each such ,bbies in which you ;ident out of which 11. If, as a result of the incident referred to in the Compla prevented from or limited in engaging in your normal business, social or other activities, state: (a) itemize each of the activities so affected; and (b) describe the manner in which the incident ;~ffected you~ each such activity. ANSWER: nt, you are or were recreational, family ability to engage in 12. State the name and address of every doc[or, chiropral care provider from whom you have received treatment or by who~ examined since August 24, 2000 to the present time and list all dates treatment or were examined by each doctor, chiropractor or health can ANSWER: 13. State the name and address of every hospital or medical have been admitted as an in-patient since August 24, 2000 to the pres~ on which you were admitted to each hospital or medical facility. ANSWER: 14. State the name and address of every hospital or medical received out-patient, emergency or clinic treatment since August 24, 2~ and list all dates when you received such treatment at each hospital or ANSWER: tor or other health you have been ~vhen you received :~rovider. ~cility to which you ~t and list all dates fi~cility at which you )00 to the present ~edical facility. 15. Describe each injury that you contend you sustained incident referred to in the Complaint. ANSWER: as a result of the 16. If you are claiming a physical and/or mental disability a,, the incident referred to in the Complaint, state: (a) the specific nature and degree of such disability; (b) whether it is total or partial; and (c) whether it is permanent or temporary. ANSWER: a consequence of 17. If you had suffered any injuries or diseases to those ar~ you claim to have been injured or affected by the incident referred to any time before that incident, state: (a) the date and place where each such injury c,ccurred; (b) provide a detailed description of the specific injury or inju~ (c) if any such injury required surgery, state thE; nature of th nature of the surgery performed, the name of the surge~ the hospital involved. ANSWER: as of the body that in the Complaint at :es sustained; and surgery, state the and the name of 18. If you had suffered any injuries or diseases to those are you claim to have been injured or affected by the incident referred to any time after that incident, state: (a) the date and place where each such injury occurred; (b) provide a detailed description of the specific injury or injur (c) if any such injury required surgery, state the natu performed, the name of the surgeon and the name of the ANSWER: as of the body that n the Complaint at es sustained; and e of the surgery lospital involved. 19. State all illnesses, sicknesses, diseases, disabilities or ot conditions from which you have suffered before the incident referred t~ including a detailed description of the symptoms whiclh you exper condition. ANSWER: 20. State all illnesses, sicknesses, diseases, disabilities or ott conditions from which you have suffered after the incident referred to including a detailed description of the symptoms which you expe~ condition. ANSWER: ~er physical/mental in the Complaint, ~nced from each er physical/mental in the Complaint, enced from each 21. If you have a family physician or other medical practitio~ consult for any general physical or mental complaint, give his/her nam~ upon which you last consulted him/her, and the reason for such consult ANSWER: ~er with whom you address, the date tion. 22. Identify each person from whom you, your attorney or an behalf has obtained a statement concerning any matter relating to this the date on which any such statement was obtained. ANSWER: 23. State the full name and last known address of every per~ your attorney or anyone acting on your behalf who was a witness to t~ claims to have any knowledge regarding the facts and circumstancei incident set forth in the Complaint and its occurrence. ANSWER: one acting on your action and provide ;on known to you, ~e incident or who surrounding the 24. State the name and address of each person whom you non-expert witness at the tdal of this case. ANSWER: 25. List and describe all exhibits which you intend to use at th~ ANSWER: intend to call as a trial of this case. 26. Identify each person whom you expect to (;all as an ex and state the ~ on which each such expert is expected to t, ANSWER: )eft witness at trial ~stify. 27. With regard to each expert identified above, state the folk the facts and opinions to which the expert is ,expected to a summary of the grounds for each opinion to which the to testify. NOTE: As your answer, you may attach hereto each expert. ANSWER: 28. Identify each separate item of information supplied to ea~ above for his/her review, use or consideration as a basis for formulating including all objects and documents examined. ANSWER: ~ving: ;stify; and expert is expected a report signed by h expert identified his/her opinion(s), 29. With regard to each expert whom you expect to call at t~ supply a current copy of his/her curriculum vitae. ANSWER trial of this case, 30. Are you now receiving, or have you ever received, any Social Secudty benefits for disability, or any Workers' Compensation agency, company, person, corporation or government? If so, state: (a) the nature of any such payments; (b) the date you received such payment; (c) from what injuries or disability you received such payme injury occurred or disability arose; (d) by whom you were paid; (e) whether you now have any present disabiliity as a res~ and/or disability; (f) if so, the nature and extent of such disability; (g) whether you had any disability or injury at the time of which this claim arises; and (h) if so, the nature and extent of such disability or injury. ANSWER: disability pension, benefits from any nt, and how such It of such injuries incident out of 31. Have you made any claim for any benefits under any me or policy of insurance relating to injuries from the accident out of which so, state: (a) the name of the insurance company or organization to wi made; (b) the date of the claim or application; (c) the claim number and policy number under which the clail (d) whether or not such claim was paid and if so, the n~ received. ANSWER: Jical pay coverage ~is claim arose? If ~m said claim was was made; and ture and amount 32. Have you ever made any claim for any benefits under a or against any person, firm or corporation for personal injuries or physi you have not heretofore listed in your answers to these Interrogatories? (a) the injury or condition for which such claim was made; (b) the name and address of the person, firm or' corporation whom such claim was made; (c) the date the claim was made; and (d) the nature and amount of any payment received therefore ANSWER: ~y insurance policy :al condition which If so, state: o whom or against 33. Had you been involved in any motor vehicle .accidents, as of a vehicle or a passenger, within the ten (10) years immediately pre the incident out of which this claim arises. If so, state: (a) the date and location of each such accident; (b) the facts and circumstances of each such accident; and (c) a description of every injury you sustained, if any. ANSWER: either the operator ceding the date of 34. Have you been treated or examined by a chiropractor v preceding the date of the incident out of which this claim arises. If so, pi (a) the name and address of each such chiropractor; (b) the dates of treatment by each such chiropractor; and (c) a brief description of the physical complaints or sympt¢ received treatment from each such chiropractor. ANSWER: ithin the ten years ease state: ~ms for which you 35. If you, your attomey or anyone acting on your behalf investigation of the subject incident, please provide the name, addr~ number of all (a) persons contacted during the course of such inves witnesses identified as a result of the investigation. ANSWER: has conducted an ss, and telephone '.igation and (b) all 36. If you are a named insured on a policy of insurance covet registered motor vehicle which was wdtten or renewed after July 1,199t you chose the "limited tort" option or "full tort" option as described in Motor Vehicle Financial Responsibility Act, as amended July 1, 19~ contained in 75 Pa.C.S.A. Section 1705. ANSWER: nga Pennsylvania :), indicate whether the Pennsylvania )0 or Act VI, and 37. If you are not a named insured on a policy of ins~ Pennsylvania registered motor vehicle which was written or renewed indicate whether the named insured(s) in the household in which yo~ "limited tort" or "full tort" option as described in the Pennsylvania Mote Responsibility Act, as amended July 1, 1990 and contained in 75 Pa.C.I ANSWER: ~rance covering a after July 1, 1990, reside chose the Vehicle Financial .A. Section 1705. 38. State whether you have made a claim or s,ubmitted an party benefits under any motor vehicle insurance policy as a result of to in the Complaint. If so, state the following: (a) the name and address of the insured under the policy; (b) the name and address of the insurance carrier issuing the (c) the policy number. ANSWER: ~pplication for first- ~e incident referred policy; and 39. For all medical care providers from whom you received tr that you attribute to the accident, identify each medical care provider than the full amount invoiced for his/hedits services as payment in full. ANSWER: .~atment for injuries that accepted less 40. For all medical care providers identified in your answ6 interrogatory, state the following: (a) the name of the medical care provider; (b) the total amount invoiced for medical sel¥ices from provider; and (c) the amount ~ as payment in full fOr medical medical care provider. ANSWER: to the foregoing ~at medical care ervices from that 41. Identify and attach to your answers all documents answers to the foregoing interrogatories. ANSWER: ~at relate to your 42. Identify the source and state the amount and date of am payments of any kind that you have received or have been~ paid on youl losses you sustained or expenses you incurred as a result of the including but not limited to all first party insurance benefits, worke medical expense coverage and compensation for disability, di~ disfigurement, death, income or hospital indemnity and lost income or ea ANSWER: and all benefits or behalf because of subject accident, rs' compensation, ~memberment or rnings. 43. Set forth in detail, including the dates, nature and amc damages which have not been paid and are not payable under the co the Motor Vehicle Financial Responsibility Law, or workers' com~ program, group contract or other arrangement for payment of benefits you calculated such amounts and determined that they were not paid or ANSWER: ant of any special verage set forth in ~ensation, or any and explain how ~ayable. 44. Identify all insurance policies, benefit plans, and program employment policies or agreements, or other arrangements for pa expenses, income loss, dismemberment or disfigurement, death or per which you are an insured, covered person, or eligible to receive paymen ANSWER: ~, group contracts, fment of medical ional injury, under Is or benefits. CERTIFICATE OF SERVICE_ AND NOW, this ~(~-~ay of September, 2002, I, C. KENT PR the firm of THOMAS, THOMAS & HAFER, LLP, attorneys for Defen( that I have this day served the within Interrogatories Directed to Plain! copy of the same in the United States Mail, postage prepa~id, at Harrisbi addressed to: Steven D. Janel, Esquire Law Offices of Steven D. Janel 1200 Walnut Street Fifth Floor Philadelphia, PA 19107 .~E, ESQUIRE, for ant, hereby certify iff by depositing a Jrg, Pennsylvania, THOMAS,. THOMAS & ~HAFER, LLP C. Kent Price, Esquire THOMAS, THOMAS & HAFER, LLP C. Kent Price, Esquire I.D. No. 06776 305 North Front Street P. O. Box 999 Harrisburg, PA 17108 (717) 255-7632 Attorney f~ APRIL CRONE, Vo LAURA LINDSAY, Plaintiff Defendant IN THE COURT OF COMMt OF CUMBERLAND COU PENNSYLVANIA NO. 02-3995 CIVIL ACTION - L/ JURY TRIAL DEMANi REQUEST FOR PRODUCTION OF DOCUMENTS DIRECTED TO PLAINTIFE TO: Apdl Crone c/o Steven D. Janel, Esquire Law Offices of Steven D. Janel 1200 Walnut Street Fifth Floor Philadelphia, PA 19107 PLEASE TAKE NOTICE that pursuant to Rule 4009 of the Penn Civil Procedure, you are hereby requested to produce for inspection an~ offices of THOMAS, THOMAS & HAFER, 305 North Front Street, P.O. Harrisburg, Pennsylvania, 17108, the following requested documents a your possession, custody, or control. Production is to be made within th service of the Request. The following definition is applicable to and incorporated by refert Request for Production of Documents: r Defendant )N PLEAS ~ITY, W )ED ;ylvania Rules of I/or copying at the )ox 999, ,d items within irty (30) days of ;nce into each A. The term "document", as used, means the odginal and a written, typed or other graphic matter of any kind, no matter by whom pr sent or received or neither, including but not limited to: 1. Contracts, agreements, letters and other forms of corresp communications; 2. Memoranda, reports, financial statements and transcripts; 3. Minutes, records or transcripts of meetings and conferenC persons in attendance; 4. Reports and summaries of interviews; and 5. Records, memoranda, notes and notations of all telephon CLAIMS OF PRIVILEGE If any document sought by the Request is withheld 'From producti privilege, work product or any other reason, Plaintiff shall identify such his/her response to this Request by stating the date, author, and each r~ documents and shall indicate the precise reason why its production is bi REQUEST FOR PRODUCTION OF DOCUMENTS 1. All statements, summaries of statements, transcripts of re or interviews relating to, referring to or in any way describing the allegat set forth in the Complaint. 2. All documents prepared by Plaintiff, her agents or emploY acting on her behalf, during an investigation of the allegations and even the Complaint, or prepared in anticipation of litigation or trial of this matti mental impressions, conclusions or opinions of counsel. copies of any ~ared whether 3ndence or es, and lists of conversations. ~n based on document in .~cipient of the ._,ing withheld. corded statements ons and events as ~es or anyone is as set forth in 9r, excluding the 4. 5. 6. All photographs, films or videotapes taken in regard to this All statements of each eyewitness to the incident. All statements of each person who will be called as a witn~ All medical articles reviewed and consulted irt anticipation which will be used for purposes of cross-examination at trial. All documents or other demonstrative evidence which will used at trial. 8. 9. All documents regarding insurance benefits [)aid due to th The policy declaration sheet for each applicable automobi! providing first party benefits which reflects the limits of coverage and the elected. 10. Reports of all experts who will be called by Plaintiff to testi 11. A current curriculum vitae for each expert expected to be to testify at tdai. 12. All investigations, reports, test results, drawings, sketche.' records of this incident and the events surrounding this incident. 13. All medical bills concerning the injudes suffered by Plaintit 14. All bills, invoices, statements, etc. for non-medical and oti expenses incurred by Plaintiff. 15. All medical records pertaining to Plaintiff for treatment rec 24, 2000 to the present time, concerning the injuries allegedly suffered forth in the Complaint. incident. ~ss at trial. 3f litigation or trial, ~e introduced or s incident. e insurance policy tort option r¥ at trial. ;ailed by Plaintiff summaries or ~er incidental eived from August )y Plaintiff as set 16. All Federal and State Income Tax Retums, including W-2 Plaintiff for each year from 1997 to the present. This request is intended to cover all documents in the possessior control of Plaintiff, her agents, employees, and attomeys, and is deemt thus requiring her to modif7 and/or supplement her response to Defend she obtains further or additional documents up to the time of trial. THOMAS, THOMAS & HAFE C. Kent Price, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7632 ATTORNEYS FOR DEFEND/ forms filed by custody and to be continuing, :nt's Request as ~,, LLP ,NT CERTIFICATE OF SERVICE AND NOW, this ~ (~)'~day of September, 2002, I, C. KENT PRI~ the firm of THOMAS, THOMAS & HAFER, LLP, attorneys for Defend~ that I have this day served the within Request for Production of Docu Plaintiff by depositing a copy of the same in the United States Mail, pc Harrisburg, Pennsylvania, addressed to: Steven D. Janel, Esquire Law Offices of Steven D. Janel 1200 Walnut Street Fifth Floor Philadelphia, PA 19107 ;E, ESQUIRE, for ~nt, hereby certify nents Directed to ,stage prepaid, at THOMAS, THO~AFER, LLP C. Kent Price, Esquire THOMAS, THOMAS & HAFER LLP ATTORNEYS AT LAW 305 North Front Street, P.O. Box 999, Harrisburg, PA 17108 Phone: (717) 237-7100 Fax: (717) 237-7105 January 2, 2003 Steven D. Janel, Esquire Law Offices of Steven D. Janel 1200 Walnut Street Fifth Floor Philadelphia, PA 19107 RE: Crone v. Lindsay Dear Mr. Janel: www. tthlaw.com C. Kent Price (717) 255- 7632 ckp@tthlaw, com THOMAS, THOMAS & HAFER, I C. Kent Price CKP/ves:189388.2 Lehigh Valley Office: 3400 Bath Pike, Suite 201, Bethlehem, PA 18017 * Phone: (610) 868-165 ,LP 5 * Fax: (610) 868-1702 Sincerely yours, I wrote to you back on November 6, 2002 regarding this matter. In that ,~tter I proposed that you send me a settlement package with all related medical and other pertinent rei:ords bearing on the damage aspects of the claim, as well as a reasonable settlement de~nand based up on those materials. It was my hope that we might be able to circumvent the usual discowery routine ami determine whether the matter was capable of being settled sooner rather than later and. without an ur. necessary expenditure of time. To date I have received no response. There is discovery outstanding to each of us. Mine was served on you on or about September 30, 2002 and yours was served on me on or about October 23, 2002. I have aske] my paralegal to begin the process of preparing responses to yours, although that would seem to b~ a waste of time presently. ' ' / 1 Let me again reiterate my request that you provide me with a reasonable qettlement demand together with all supporting documentation. Otherwise, please respond to my o~standing discovery so we can proceed to schedule depositions. THOMAS, THOMAS & HAFER LLP ATTORNEYS AT LAW 305 North Front Street, P.O. Box 999, Harrisburg, PA 17108 Phone: (717) 237-7100 Fax: (717) 237-7105 January 15, 2003 Steven D. Janel, Esquire Law Offices of Steven D. Janel 1200 Walnut Street, Fifth Floor Philadelphia, PA 19107 RE: Crone v. Lindsay Dear Mr. Janel: Enclosed are Defendant's Answers to Plaintiffs Interrogatories (Set 1) a~ Responses to Plaintiff's Request to Produce to Defendant (Set 1). Please respond discovery so we can proceed to schedule depositions. Thank you for your attenti{ Sincerely yours, THOMAS, THOMAS; & HAFER, I CKP/kar: 189388.3 C. Kent Price Lehigh Valley Office: 3400 Bath Pike, Suite 201, Bethlehem, PA 18017 * Phone: (610) 868-1671, www.tthlaw.com C. Kent Price (717) 255- 7632 ckp~tthlaw, com d Defendant's to my outstanding n to this matter. LP Fax: (610) 868-1702 HOMAS, THOMAS & HAFER LLP ATTORNEYS AT LAW 305 North Front Street, P.O. Box 999, Harrisburg, PA 17108 Phone: (717) 237-7100 Fax: (717) 237-7105 February 28, 2003 Steven D. Janel, Esquire Law Offices of Steven D. Janel 1200 Walnut Street Fifth Floor Philadelphia, PA 19107 RE: Crone v. Lindsey Dear Mr. Janel: I am writing to follow up on my letters to you of November 6, 2002 and J well as a subsequent telephone call, regarding this matter. I have irfformally requ those letters, and I have also served.you with formal discovery in the nature of In about September 30, 2002, all for the sole purpose' of obtaining the necessary mai your client's claim for settlement purposes. So far I have received nothing in resl; I am starting to come under some pressure to get this case moving. Conse choice but to insist that you respond to my Interrogatories within 2'.1 days of the I failing which I will have to file a motion to compel. In the meantime, I have enclosed an Authorization to be signed by your el: me to obtain a copy of her first-party claim file from Presque Isle Insurance. Pie.' sign the Authorization and return it to me in the enclosed self-addressed envelope with a complete copy of all documents that I eventually receive in response to the Thank you. Sincerely yours, THOMAS, THOMAS & HAFER, L: crP/ves:189388.8 C. Kent Price Lehigh Valley Office: 3400 Bath Pike, Suite 201, Bethlehem, PA 18017 * Phone: (610) 868-167~; www.tthlaw.com C. Kent Price (717) 255- 7632 ckp~tthlaw, corn muary 2, 2003, as .-sted information in errogatories on or .-rials to evaluate onse. :luently, I have no late of this letter, ent that will allow se have Ms. Crone I will provide you Authorization. ~P · Fax: (610) 868-1702 CERTIFICATE OF SERVICE AND NOW, this 8TM day of April, 2003, I, C. KENT PRICE, ESQUI THOMAS, THOMAS & HAFER, LLP, attorneys for Defendm~t, hereby cert day served the within Motion to Compel Discovery Responses 'by depositing in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addre~ Steven D. Janel, Esquire Law Offices of Steven D. Janel 1200 Walnut Street Fifth Floor Philadelphia, PA 19107 THOMAS, THOMAS & HAFEl C. Kent Price, Esquire ~E, for the firm of [fy that I have this copy of the same ;ed to: LLP APRIL CRONE, Vo LAURA LINDSAY, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3995 CIVIL ACTION - LAW JURY TRIAL DEMANDED ORDER OF COURT AND NOW, this ! ! '~ day of 42~ 7 ,2003, upon consideration of the Motion of Defendant Laura Lindsay to Compel Discovery Responses from Plaintiff, a Rule is hereby issued upon Plaintiff to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT THOMAS, THOMAS & HAFER, LLP 305 North Front Street P.O. Box 999 Hanisburg, PA 17108 APRIL CRONE, Plaintiff V LAURA LINDSAY, Defendant C. Kent Price, Esquire A~tomey I.D. 06776 717-255-7632 Attorney for Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3995 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that: 1. Plaintiff does not object to the subpoena and waives the Notice of Intent to Service a Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21; 2. A copy of a letter dated June 16, 2003, and executed by Plaintiff's counsel, Steven D. Janel, Esquire, indicating no objections and waiver of the notice of intent is attached to this Certificate; 3. A copy of the proposed subpoena is attached to this certificate; and 4. The subpoena which will be served is identical to the subpoena which is attached to this certificate. Date: THOMAS, THOMAS & HAl*ER, LLP C. Kent Price, Esquire I.D. Number: 06776 Attorney for Defendant Post Office Box 999 Harrisburg, PA 17108 (717) 255-7632 244306.1 THOMAS, THOMAS & HAFER LLP ATTORNEYS AT LAW 305 North Front Street, P.O. Box 999, Harrisburg, PA 17/08 Phone: (717) 237-7/00 Fax: (717) 237-7/05 Jur~ z / Z~J www.tthlaw.com Rick L. Stains, Jr., Paralegal (717) 441- 7056 rstains~tthlaw, com Steven D. Janel, Esquire Law Offices of Steven D. Janel 1200 Walnm Stieet, Fifth Floor Philadelphia, PA 19107 June 16, 2003 April Crone v. Laura Lindsay Docket No.: 02-3995 Our File No.: 347.21265 Dear Attorney Janel: Enclosed please find a Notice of Intent to Serve Subpoenas pursuant to Rule 4009.21. If you have no objection to the subpoenaing of these records and are willing to waive the 20-day notice period, please sign where indicated and return a copy of this letter to me at your earliest convenience. Thank you for your attention to this matter. Sincerely, Enclosures I. ~ b. 'J'~'~ , Esquire, counsel for Plaintiff, have no objection to the serving of the subpoenas identified in the attached Notice of Intent and hereby waive the~.~20-day notice period. Counsel for Defendant shall provide me with copies of all re, cords when they n pursuant to these subpoe~n;s. . n they.~ 242020.1 Lehigh Valley Office: 3400 Bath Pike, Suite 302, Bethlehem, PA 18017 · Phone: (610) 868-1675 * Fax: (610) 868-1702 Steven D. Janel. F~qmre Member PA &: NJ Bars LAW OFFICES OF STEVEN D. JANEL 1200'WALNUT STREET FIFTH FLOOR PHILADELPHIA, PA 19107 (215) 772-9080 F~,x (215) 546-5355 E-M~: smvenjanellaw~ rcn.com JU~ 2 ? Circle West Office Park. Suite ~12 I Penningron-Washi~gton Crossing Road ?ermington, NJ 08543 609) 730-8150 June 24, 2003 C. Kent Price, Esquire Thomas, Thomas & Hafer, L.L.P. 305 N. Front Street, 6th Floor P.O. Box 999 Harrisburg, PA 17108 RE: April Crone v. Laura Lindsay, Cumberland County C.C.P., Civil Action Law, Docket No. 02-3995 Dear Mr. Price: Enclosed please find Plaintiffs waiver of the 20 day notice period for the service of subpoenas. Kindly forward tree and correct copies of all documents received pursuant to the subpoenas to this office upon your receipt thereof. Thank you for your continuing professional courtesy. Please contact me with any questions. SDJ/wns Enclosures Stev~D. Jane%,,. THOMAS, THOMAS & HAFER, LLP C. Kent Pdce, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7632 APRIL CRONE, Plaintiff LAURA LINDSAY, Defendant Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3995 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGR FOR DISCOVERY PURSUANT TO RULE 4009.27 Custodian of Records, William Gagliardi, D.C., 2007 Chestnut Street, P.O. Box 15896, Philadelphia, PA 19103 (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: Any and all correspondence, hospitalization and medical records regarding treatment rendered on behalf of APRIL CRONE. SSN: 172-70-8473, D/O/B: 08/06/82, including, but not limited to patient histories, charts, progress notes, consultation reports, medication charts, statements of injury, diagnosis, prognosis, x-rays or other diagnostics, diagnostic test results and reports. at THOMAS, THOMAS & HAFER, LLP, 305 N. Front Street, POB 999, Harrisburg, PA 17108 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 dght 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 paKy serving this subpoena may seek a coud order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: C. Kent Price, Esquire ADDRESS 305 N. Front Street, P. O. Box 999 Harrisburq, PA 17108 TELEPHONE: (717) 255-7632 SUPREME COURT ID No: 06776 A'I=FORNEY FOR: Defendant DATE: J(Z.,,~3E., ./~:~,~ ~..(:3~33 Seal of the Court Deputy 242010.1 THOMAS, THOMAS & HAFER, LLP C. Kent Price, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7632 APRIL CRONE, Plaintiff LAURA LINDSAY, Defendant Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3995 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.?? Custodian of Records, Casses Chiropractic, 313 S. Hanover Street, Carlisle, PA 17013 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce lhe following documents or things: Any and all correspondence, hospitalization and medical records regarding treatment rendered on behalf of APRIL CRONE. SSN: 172-70-8473, D/O/B: 08/06/82, including, but not limited to patient histories, charts, progress notes, consultation reports, medication charts, statements of injury, diagnosis, prognosis, x-rays or other diagnostics, diagnostic test results and reports. at THOMAS, THOMAS & HAFER, LLP, 305 N. Front Street, POB 999, Harrisburg, PA 17108 You may deliver or mail legib~ copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this mqueat at the address listed above. You have the dght to seek, in advance, the reasonable cost of prepadng the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) day~; after its service, the pad7 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: C. Kent Pric~ ADDRESS 305 N. Front Street, P. O. Box 999 Harrisburq, PA 17108 TELEPHONE: {717) 255-7632 SUPREME COURT ID NO: 06776 A~'ORNEY FOR: Defendant DATE: '..~I,.,~.,~E,. I~:~ Seal of the Cobrt Deputy 242010.2 THOMAS1 THOMAS & HAFER, LLP C. Kent Price, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7632 APRIL CRONE, Plaintiff LAURA LINDSAY, Defendant Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3995 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THING,~ FOR DISCOVERY PURSUANT TO RULE 4009 27 Custodian of Records, Spinal Imaging, Inc., 5 Norfolk Avenue, S. Easton, MA 02375 (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: Any and all correspondence, hospitalization and medical records regarding treatment rendered on behalf of APRIL CRONE. SSN: 172-70-8473, D/O/B: 08/06/82, including, but not limited to patient histories, charts, progress notes, consultation reports, medication charts, statements of injury, diagnosis, prognosis, x-rays or other diagnostics, diagnostic test results and reports. at THOMAS, THOMAS & HAFER, LLP, 305 N. Front Street, POB 999, Harrisburg, PA 17108 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 prepadeg 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: C. Kent~ ADDRESS 305 N. Front Street, P. O. Box 999 Harrisburg, PA 17108 TELEPHONE: (717) 255-7632 SUPREME COURT ID NO: 06776 ATTORNEY FOR: Defendant DATE: Jl,.&,..~..,, 1.O, Seal of the Court ry ad(,Civil Division (~ Deputy 242010.3 THOMAS, THOMAS & HAFER, LLP C. Kent Pdce, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7632 APRIL CRONE, Plaintiff LAURA LINDSAY, Defendant Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3995 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGR FOR DISCOVERY PURSUANT TO RULE 4009.27 Custodian of Records, Imaging and Interventional Assoc., P.O. Box 1928, Voorhees, NJ 08043-9028 (Name of Person or Entity) Whthin twenty (20) days after service of this subpoena, you am ordered by the court to produce the following documents or things: Any and all correspondence, hospitalization and medical records regarding treatment rendered on behalf of APRIL CRONE. SSN: 172-70-8473, D/O/B: 08/06/82, including, but not limited to patient histories, charts, progress notes, consultation reports, medication charts, statements of injury, diagnosis, prognosis, x-rays or other diagnostics, diagnostic test results and reports. at THOMAS, THOMAS & HAFER, LLP, 305 N. Front Street, POB 999, Harrisburg, PA 17108 You may deliver or mail legible copies of the documents or produce th[r~js requested by this subpoena, together with the cer~cefa of compliance, to the pa~y making this request at the address listed above. You have the dght 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) day.,~ 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: C. Kent Pri~ ADDRESS 305 N. Front Street, P. O. Box 999 Harrisbur.q, PA 17108 TELEPHONE: (717) 255-7632 SUPREME COURT ID NO: 06776 ATTORNEY FOR: Defendant DATE: J~.~ ~.. IP~ Seal of the Court Prothonotary/Clerk, Civi~ Deputy 242010.4 THOMAS, THOMAS & HAFER, LLP C. Kent Pdce, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7632 APRIL CRONE, Plaintiff LAURA LINDSAY, Defendant Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3995 CIVIL ACTION - L.AW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THING,~ FOR DISCOVERY PURSUANT TO RULE 4009 22 Custodian of Records, Wellness Center at Rittenhouse Chirepractic, LI..C, 2007 Chestnut Street, Phila., PA 19103 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the cour~ to produce the followfng documents or things: Any and all correspondence, hospitalization and medical records regarding treatment rendered on behalf of APRIL CRONE. SSN: 172-70-8473, D/O/B: 08/06/82, including, but riot limited to patient histories, charts, progress notes, consultation reports, medication charts, statements of injury, diagnosis, prognosis, x-rays or other diagnostics, diagnostic test results and reports. at THOMAS, THOMAS & HAFER, LLP, 305 N. Front Street, PCB 99.q, Harrisburg, PA 17108 You may deliver or mail legible copies of the documents or produce things request, ed by this subpoena, together with the cediflcete 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 cemply with it. THIS SUBPOENA WAS ISSUED AT ']'HE REQUEST OF THE FOLLOWING PERSON: NAME: C. Kent Pri~ ADDRESS 305 N. Front Street, P. O. Box 999 Harrisbur.q, PA 17108 TELEPHONE: {717) 255-7632 SUPREME COURT ID No: 06776 ATTORNEY FOR: Defendant DA'rE: ¢._ Seal of the Court ry C erk, Civil Div s on~ Deputy 242010.5 THOMAS, THOMAS & HAFER, LLP C. Kent Pdoe, Esquire 305 NoAh Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7632 APRIL CRONE, Plaintiff LAURA LINDSAY, Defendant Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3995 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THING,~ FOR DISCOVERY PURSUANT TO RULE 4009 22 Custodian of Records, Julian Hirsch, D.C., 103 S. US Hwy 1-Ste B4, Jupiter, FL 33477 (Name of Pemon or Entity) Within twenty (20) days after service of ~his subpoena, you are ordered by fl.,e court to produce the following documents or things: Any and all correspondence, hospitalization and medical records regarding treatment rendered on behalf of APRIL CRONE. SSN: 172-70-8473, D/O/B: 08/06/82, including, but not limited to patient histories, charts, progress notes, consultation reports, medication charts, statements of injury, diagnosis, prognosis, x-rays or other diagnostics, diagnostic test results and reports. at THOMAS, THOMAS & HAFER, LLP, 305 N. Front Street, POB 99,~, Harrisburg, PA 17108 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the fight to seek. in advance, the reasonable cost of preparing the copies or producing the things sought, If you fail to produce the documents or things required by this subpoena, within twenty (20) days afar its seMco, 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: C. Kent Pr~ ADDRESS 305 N. Front Street, P. O. Box 999 Harrisburq, PA 17108 TELEPHONE: {717} 255-7632 SUPREME COURT ID No: 06776 A~TORNEY FOR: Defendant DATE: Sear of the Court Deputy 242010.6 THOMAS, THOMAS & HAFER, LLP C. Kent Price, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7632 APRIL CRONE, Plaintiff LAURA LINDSAY, Defendant Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3995 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGR FOR DISCOVERY PURSUANT TO RULE 4009, 72 Custodian of Records, SpineCenter of PA, 1911 Arch Street, P.O. Box 820681, Philadelphia, PA 19182 (Name of Pemon or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the cour[ to produce the following documents or things: Any and all correspondence, hospitalization and medical records regarding treatment rendered on behalf of APRIL CRONE. SSN: 172-70~8473, D/O/B: 08/06/82, including, but not limited to patient histories, charts, progress notes, consultation reports, medication charts, statements of injury, diagnosis, prognosis, x-rays or other diagnostics, diagnostic test results and reports. at THOMAS, THOMAS & HAFER, LLP, 305 N. Front Street, POB 999, Harrisburg, PA 17108 You may deriver or mail legible copies of the documents or produce things requested by this subpoena, together with the cert~cate of compliance, to the party making this request at the address listed above, You have the ri iht 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) da~; 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: C. Kent P~ ADDRESS 305 N. Front Street, P. O. Box 999 Harrisbur,q, PA 17108 TELEPHONE: (717) 255-7632 SUPREME COURT ID NO: 06776. ATTORNEY FOR: Defendant DATE: Seal of ~he Court Prothonotary/Clerk, Civil Division Deputy 242010.7 THOMAS, THOMAS & HAFER, LLP C. Kent Pdce, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7632 APRIL CRONE, Plaintiff LAURA LINDSAY, Defendant Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 02-3995 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 Custodian of Records, Analgesic Healthcare, P.O. Box 271570, Tampa, FL 33688 (Name of Pemon or Entity) 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 correspondence, hospitalization and medical records regarding treatment rendered on behalf of APRIL CRONE. SSN: 172-70-8473, D/O/B: 08/06/82, including, but not limited to patient histories, charts, progress notes, consultation reports, medication charts, statements of injury, diagnosis, prognosis, x-rays or other diagnostics, diagnostic test results and reports. at THOMAS, THOMAS & HAFER, LLP, 305 N. Front Street, POB 999, Harrisburg, PA 17108 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) day~ 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: C. Kent Price, Esquire ADDRESS 305 N. Front Street, P. O. Box 999 Harrisbur.q, PA 17108 TELEPHONE: (717) 255-7632 SUPREME COURT ID No: 06776 A'CFORNEY FOR: Defendant DATE: JLZ.O~. ~ J;;~ ~ Seal of the Court Deputy 242010.8 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA APRIL CRONE, v. NO. 02-3995 LAURA LINDSAY, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: Steven D. J 1 Pennington Pennington, Please mark the docket in the above-captioned matter as settl d d discontinued with prejudice. Date: \!~/05 ';J , U,' '. C_i