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HomeMy WebLinkAbout02-4526 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA SHARON VANHOVE, and : DARRELL VANHOVE, : Plaintiffs : WALTER POLLACK, : : Defendant : Civil Number JURY TRIAL DEMANDED NOTICE TO DEFEND TO: Walter Pollack YOU HAVE BEEN SUED 1N 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 axe 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 F1ND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 1-800-990-9108 Document #: 242105. l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA SHARON VANHOVE, and DARRELL VANHOVE, VS. Plaintiffs WALTER POLLACK, Defendant Civil Number JURY TRIAL DEMANDED NOTICE TO DEFEND TO: Walter Pollack LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere 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 que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso a notificacion y por cualquier queja o alivio que 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 IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL D1NERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE 9PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 1-800-990-9108 Document #: 242105. l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA SHARON VANHOVE, and DARRELLVANHOVE, VS. Plaintiffs WALTER POLLACK, Defendant Civil Number JURY TRIAL DEMANDED COMPLAINT 1. Plaintiffs Sharon and Darrell VanHove are adult individuals residing at 75 Hill Lane, Newville, Cumberland County, Pennsylvania. 2. Defendant Walter Pollack is an adult individual residing at 246 Hunters Road, Newville, Cumberland County, Pennsylvania. On June 19, 2001, Plaintiff Sharon VanHove was the driver of a 1998 Pontiac Gran Prix. 4. On the aforesaid date, Sharon VanHove's vehicle was traveling south on North High Street, Newville, Pennsylvania, and Defendant Walter Pollack was operating a 1993 Dodge Caravan stopped facing north on North High Street, Newville, Pennsylvania. 5. As Plaintiff approached the area where Defendant was located, the Defendant suddenly and without warning made a left-hand turn in front of and directly into the path of the Plaintiff, causing the two vehicles to collide. 6. As a result of the aforesaid accident and collision, Plaintiff sustained various personal injuries, all or some of which may be permanent or chronic in nature, including lumbar Document #. 242103.1 12. a part hereofi 13. pain, neck pain, arm pain, braising to the upper arm and elbow, acate cervical and lumbar strain, aggravation of prior asymptomatic back condition, internal disc disruption of the lumbar spine, disc herniation, and nerve injuries. 7. As a result of the aforesaid accident and injuries, Plaintiff has incurred various medical expenses for physicians, hospitals, medical supplies, medications, therapy, and other medical treatment, and she will in the future continue to incur such medical expenses. 8. As a result of the aforesaid accident and injuries, Plaintiff has sustained a loss of income and may in the future continue to suffer a loss of income and a permanent impairment of her future earning capacity. 9. As a result of the aforesaid accident and injuries, Plaintiff has undergone emotional and mental distress and anguish, embarrassment and humiliation, and will in the future continue to undergo such mental distress and anguish, embarrassment and humiliation. 10. As a result of the aforesaid accident and injuries, Plaintiff has undergone much pain, suffering, inconvenience, loss of the enjoyment of life, and the loss of life's pleasures, and will in the futura continue to suffer such losses. 11. because of the aforesaid accident and injuries, Plaintiff has sustained, or may in the future sustain, permanent scarring and disfigurement. COUNT I Sharon VanItove v. Walter Pollack Preceding Paragraphs 1 through I 1 are incorporated herein by reference and made The aforesaid accident and injuries suffered by Plaintiffwere the direct and proximate result of the negligence and carelessness of Defendant, as follows: (a) He failed to operate his vehicle at a safe and appropriate speed; Document #: 242103. l (b) (c) (d) He failed to keep a proper lookout for other vehicles on the highway; He failed to yield the right-of-way to Plaintiff; He made a left-hand turn in front of Plaintiff when it was not safe to do so and when he was not able to proceed safely in front of Plaintiff; (e) He failed to keep his vehicle under control; (f) He failed to steer or stop his vehicle so as to avoid a collision with Plaintiff's vehicle; and (g) He failed to observe Plaintiff's vehicle. 14. Defendant is liable to Plaintiff for all of those damages sustained by Plaintiff, as set forth in the preceding paragraphs. WHEREFORE, Plaintiff demands judgment against Defendant in an amount exceeding that requiring submission to compulsory arbitration, plus costs. COUNT II LOSS OF CONSORTIUM Plaintiff Darrell VanHove v. Walter Pollack 15. Paragraphs 1 through 14 hereof are incorporated herein by reference as if fully set 16. During all relevant times, Plaintiffs Sharon VanHove and Darrell VanHove were husband and wife, and solely as a result of the aforesaid negligence of Defendant, and Plaintiff Sharon VanHove's injuries therefrom, the Plaintiff Darrell VanHove has been deprived of the assistance, companionship, consortium, services and society of his wife all to his great loss and detriment which may continue indefinitely. Document#.'242103.1 WHEREFORE, Plaintiff demands judgment against Defendant in an amount exceeding that requiring submission to compulsory arbitration, plus costs. Dated: METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Edward E. Knauss, IV, Esquire Attorney I.D. No. 19919 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 Attorneys for Plaintiffs Document #: 242103.1 VERIFICATION We, Sharon VanHove and Darrell VanHove, do hereby verify that the facts set forth in the foregoing Complaint are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities. Date: Sharon VanHove Date:~__ Document#.'2421031 SHERIFF'S RETURN - REGULAR CASE NO: 2002-04526 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND VANHOVE SHARON ET AL VS POLLACK WALTER CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon POLLACK WALTER the DEFENDANT at 1333:00 HOURS, at 246 HUNTERS ROAD NEWVILLE, PA 17241 WALTER POLLACK on the 1st day of October , 2002 by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.28 Affidavit .00 Surcharge 10.00 .00 36 .28 Sworn and Subscribed to before me this ['~ day of O~ ~ ~2~ A.D. gr~othonotary So Answers: R. Thomas Kline 10/02/2002 METZGER WICKERSHAM .... Deputy ~f~i f f SHARON VANHOVE and DARRELL VANHOVE, Plaintiffs V. WALTER POLLACK, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 4526 - 2002 : CIVIL ACTION - LAW '. : JURY TRIAL DEMANDED TO: Sharon VanHove and Darrell VanHove, Plaintiffs c/o Edward E. Knauss, IV, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 N. Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED NEW MATTER WITHIN TWENTY (20) DAYS OF SERVICE HEREOF OR A JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. Respectfully submitted, By: oMAS, THOM~LP , Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7629 Attorney for Defendant Dated: October 17, 2002 SHARON VANHOVE and DARRELL VANHOVE, Plaintiffs V. WALTER POLLACK, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 4526 - 2002 : CIVIL ACTION - LAW '. : : JURY TRIAL DEMANDED Defendant, Walter Pollack, by and through his attorneys, Thomas, Thomas & Hafer, LLP, and Douglas B. Marcello, Esquire, hereby files the following Answer with New Matter to Plaintiffs' Complaint: 1. Denied. Answering Defendant is without information or belief as to the truth of the averments of paragraph 1 and hence it is denied and proof is demanded at time of trial. 2. Denied as stated. 3. Denied. Answering Defendant is without information or belief as to the truth of the averments of paragraph 3 and hence it is denied and proof is demanded at time of trial. 4. Admitted. 5. Denied as stated pursuant to Pa.R.C.P. Rule 1029(e). 6. Denied. Answering Defendant is without information or belief as to the truth of the averments of paragraph 6 and hence it is denied and proof is demanded at time of trial. 7. Denied. Answering Defendant is without information or belief as to the truth of the averments of paragraph 7 and hence it is denied and proof is demanded at time of trial. 8. Denied. Answering Defendant is without information or belief as to the truth of the averments of paragraph 8 and hence it is denied and proof is demanded at time of trial. 9. Denied. Answering Defendant is without information or belief as to the truth of the averments of paragraph 9 and hence it is denied and proof is demanded at time of trial. 10. Denied. Answering Defendant is without information or belief as to the truth of the averments of paragraph 10 and hence it is denied and proof is demanded at time of trial. 11. Denied. Answering Defendant is without information or belief as to the truth of the averments of paragraph 11 and hence it is denied and proof is demanded at time of trial. COUNT I Sharon VanHove v. Walter Pollack 12. The averments of paragraphs 1 through 11 are incorporated herein and made a part hereof as if set forth in full. 13. Denied. The averments of paragraph 13 and any and all subparts are denied pursuant to Pa.R.C.P. Rule 1029(e). 14. Denied. The averments of paragraph 14 state a conclusion of law to which no responsive pleading is required. In the alternative, the averments are denied and proof is demanded at time of trial. WHEREFORE, Defendant requests this Honorable Court to dismiss Plaintiffs' Complaint. COUNT II LOSS OF CONSORTIUM Darrell VanHove v. Walter Pollack 15. The averments of paragraphs 1 through 14 are incorporated herein and made a part hereof as set forth in full. 16. Denied. Answering Defendant is without information or belief as to the truth of the averments of paragraph 16 and hence it is denied and proof is demanded at time of trial. In the alternative, the averments ,of paragraph 16 are denied pursuant to Pa.R.C.P. Rule 1029(e). Any and all allegations or claims of negligence by Defendants are specifically denied. WHEREFORE, Defendant requests this Honorable Court to dismiss Plaintiffs' Complaint. NEW MATTER Some or all of Plaintiffs' claims may be barred or reduced by Plaintiffs' election 17. of the limited tort option. 18. Some or all of Plaintiffs' claims may be barred or reduced by Plaintiffs' comparative and/or contributory negligence. 19. Some or all of Plaintiffs' claims may be barred or reduced by the Pennsylvania Motor Vehicle Financial Responsibility Act. 20. limitations. WHEREFORE, Complaint. Date: October 17, 2002 :185687.1 Some or all of Plaintiffs claims may be barred by the applicable statute of Defendant requests this Honorable Court to dismiss Plaintiffs' Respectfully submitted, THOMAS, THOMAS & HAFER, LLP Dougla~cello, Esquire 305 N6rth Front Street Post Office Box 999 Harrisburg, PA 17108-0999 (717) 255-7238 Attorney for Defendant VERIFICATION I hereby verify that the averments made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to unswom falsification to authorities. Dated: : 168837. By: Walter Polll(ck. e.eK I certify that the foregoing document in within action was served upon the following by enclosing the same in an envelope addressed as follows, postage prepaid and de,Pthositing the same in the United States Mail, First Class Mail, at Harrisburg, Pennsylvania on the 17 day of October, 2002: Edward E. Knauss, IV, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 N. Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (Attorney for Plaintif~ :185564.1 THOMAS, THOMAS & HAFER, LLP D ouglas.~::l~vlarce~, Esquire IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA SHARON VANHOVE, and DARRELL VANHOVE, Plaintiffs VS. WALTER POLLACK, Defendant Civil Number 02-4526 JURY TRIAL DEMANDED REPLY OF PLAINTIFFS TO NEW MATTER 17- 20. These paragraphs are all denied. In further answer thereto, Plaintiff carried the full tort option at the time of the accident. WHEREFORE, Plaintiffs demand that the New Matter be dismissed and the judgment be entered in their favor with costs. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Edward E. Knauss, IV I. D. No. 19199 3211 North Front Street P. O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiffs Dated: VERIFICATION I, Edward E. Knauss, IV, Esquire, do hereby verify that the facts set forth in the foregoing Reply of Plaintiffs to New Matter are tree and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities. Date: /~/-/~ Y_2 7__ ward E. Knauss, IV CERTIFICATE OF SERVICE I, the undersigned, do hereby certify that on the date set forth below, I did serve a tree and correct copy of the foregoing document upon the following person(s) at the following address(es) indicated below by sending same in the United States mail, postage prepaid, as follows: Doug Marcello, Esquire Thomas, Thomas & Hafer 305 N. Front Street Harrisburg, PA 17101 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Edward E. Knauss, IV Dated: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA SHARON VANHOVE, and DARRELL VANHOVE, VS. Plaintiffs WALTERPOLLACK, Defendant Civil Number 02-4526 JURY T~AL DEMANDED PRAECIPE FOR SUBSTITUTION OF VERIFICATION TO: The Prothonotary Please substitute the attached Verification for the Verification of Counsel in the Reply of Plaintiffs to New Matter. Date: Respectfully submitted, METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By: l~dward E. Knauss, IV, Esquire Attomey I.D. No. 19199 3211 N. Front Street Harrisburg, PA 17110-0300 (717)238-8187 Document #: 241496.1 VERIFICATION I, Sharon Van Hove, do hereby verify that the facts set forth in the foregoing Reply of Plaintiffs to New Matter are tree and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities. Date: ~Far'oh~gan H6ve~ -- .~. - CERTIFICATE OF SERVICE AND NOW, on this 23rd day of October, 2002, I, Edward E. Knauss, IV, Esquire, of Metzger, Wickersham, Knauss & Erb, P.C., attorneys for Plaintiffs, hereby certify that I served this Praecipe for Substitution of Verification by depositing the same in the United States mail, postage prepaid, in Harrisburg, Pennsylvania, addressed to: Doug Marcello, Esquire Thomas, Thomas & Hafer 305 N. Front Street Harrisburg, PA 17101 Edward E. Knauss, IV Document #: 244392.1 SHARON VANHOVE and DARRELL VANHOVE. Plaintiffs V. WALTER POLLACK, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 4526 - 2002 : CIVIL ACTION - LAW : : : JURY TRIAL DEMANDED As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that: A Notice of Intent to Serve Subpoenas with a copy of the subpoenas attached thereto was mailed or delivered to Plaintiff's counsel at least twenty days prior to the day on which the subpoenas were sought to be served; A copy of the Notice of Intent, including the proposed subpoenas, are attached to this Certificate; Plaintiff's counsel has waived the 20 days and a copy of that correspondence is attached hereto; The subpoenas which will be served are identical to the subpoenas which are attached to the Notice of Intent to Serve Subpoena. Date: November 12, 2002 :190043.1 THOMAS, THOMAS & HAFER, LLP Dodgt~ B.~[~--C-¢I~, Esquire 305 North Front Street - 6th FI. Harrisburg, PA 17108 (717) 255-7238 Attorney.fbr Defendant SHARON VANHOVE and DARRELL VANHOVE, Plaintiffs V. WALTER POLLACK, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; : NO. 4526 - 2002 : CIVIL ACTION - LAW : . : JURY TRIAL DEMANDED TO: Counsel and Parties of Record Defendant, Walter Pollack, intends to serve subpoenas identical to the ones 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 subpoenas. If no objection is made, the subpoenas may be served. Date: November 5, 2002 :189193.1 THOMAS, THOMAS & HAFER, LLP By: glas~.J~xrcello.~quire 305 Nort~ont Street P. O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7238 Attorneys for Defendant SHARON VANHOVE and DARRELL VANHOVE, Plaintiffs V. WALTER POLLACK, Defendant TO: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 4526 - 2002 : CIVIL ACTION - LAW : : : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.~ Health South of Meehaniesburg, P.O. Box 2016, Meehaniesburg, PA 17055 (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: Complete copies of any and all medical records, medical reports, medical bills, diagnosti, studies, notes, correspondence, MR[ films, CAT scans, and/or x-ray films in yotu possession regarding Sharon L. VanRove, SSN: 199-58-10681 D/O/B: 9/6/6?. at: Thomas, Thomas & Haler, LLP~ 305 N. Front St., P.O. Box 999, ]~arrisbure. PA 17108-0999 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the paxty 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: Douglas B. Marcello, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7238 SUPREME COURT ID#: 36510 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonota~/Clerk, Civil Division :189157.1 Deputy SHARON VANHOVE arid DARRELL VANHOVE, Plaintiffs V. WALTER POLLACK, Defendmat IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 4526 - 2002 CIVIL ACTION - LAW JURY TRIAL DEMANDED TO: SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.2? State Farm Insurance 1690 Kenneth Road P O Box 14007 Yor PA 17404 (Nallle ° ' 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: Corn lete co ies of an and all records with re ard to Claim No.: 38-J722-475. D/L: 6/19/01 re ardin Sharon L. Vanltove SSN: 199-58-1068. D/O/B: 9/6/62 Thomas Thomas & Itafer LLP 305 N. Front St. P.O. Box 999 llarrisbur PA 17108-0a~;9 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Douglas B. Marcello, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717)' 255-7238 SUPREME COURT ID#: 36510 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division :189157.2 Deputy SHARON VANHOVE and DARRELL VANHOVE, Pla/ntiffs V. WALTER POLLACK, Defendant TO: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 4526 - 2002 : CIVIL ACTION - LAW : : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR TIlinGS _FOR DISCOVERY PURSUANT TO RULE 4009.22 shi Hose Co. Ambulance MS 15 East Bi S tin Avenue Newville PA (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: Corn lete co ies of an and all records with re ard to Sharon L. Vanltove SSN: 199-58- 1068- D/O/B: 9/6/62- Date of Accident:6/19/01. Incident Location: 68 North Hi h Street Carlisle_!~_~PA at: ~er LLP 305 N. Front St. P.O. Box . ltarrisbur pA 1710~ · · 999 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena~ together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIs SUBPOENA WAS ISSUED AT ~ REQUEST OF THE FOLLOWING PERSON: NAME: Douglas B. Marcello, Esquire ' ;)~_RESS: P.O. Box 999, Harrisburg, PA 17108-0999 EPHONE: (717) 255-7238 SUPREME COURT ID#: 36510 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division 89157.3 Deputy SHARON VANHOVE and DARRELL VANI-IOVE, Plaintiffs V. WALTER POLLACK, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 4526 - 2002 : CIVIL ACTION - LAW . : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS F_OR DISCOVERY PURSUANT TO RULE 4009.22 TO: .Carlisle Regional Medical Center, 246 Parker 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 the following documents or things: Complete copies of any and aH medical records, medical reports, medical bills, diagnosti,. .studies, notes, correspondence, MRI films, CAT scans, and/or x-ray films in you. possession regarding Sharon L. VanHove, SSN: 199-58-1068~ D/O/B: 9/6/62 at: Thomas, Thomas & Haler, LLP, 305 N. Front St., P.O. Box 999, Rarrisbur~. PA 17108-099!~ (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Douglas B. Marcello, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7238 SUPREME COURT ID#: 36510 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division :189157.4 Deputy SHARON VANHOVE and DARRELL VANHOVE, Plaintiffs V. WALTER POLLACK, Defendant TO: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 4526 - 2002 : CIVIL ACTION - LAW : : : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.27 William A. Rolle, Jr., M.D., PRISM, 175 Lancaster Boulevard, Mechanicsburg, PA 17055 (Name of Person or Entity) Within twenty (20) days after service of tiffs subpoena, you are ordered by the court tO produce the following documents or things: .Complete copies of any and all medical records, medical reports, medical bills, dia_onosti, studies, notes corres ondence MRI films CAT scans and/or x-ra f'rims in our possession regarding Sharon L. VanHove, SSN: 199-58-10681 D/O/B: 9/6/62 at: Thomas. Thomas & l-Iafer, LI.P, 305 N. Front St., P.O. Box 999, Harrisburg. PA 17108-099~ (Ad&ess) 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: Douglas B. Marcello, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7238 SUPREME COURT ID#: 36510 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division :189157.6 Deputy SHARON VANHOVE and DARRELL VANHOVE, Plaintiffs V. WALTER POLLACK, Defendant TO: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 4526 - 2002 : CIVIL ACTION - LAW : : : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.27. Michael R. Gawlas, D.O., Good Hope Family Practice, 1830 Good Hope Road, Enola_,_PA 17025 (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: .Complete copies of any and all medical records, medical reports, medical bills, di8_onosfir studies, notes, correspondence, Mill films, CAT seans~ and/or x-ray films iii yom possession regarding Sharon L. VanHove, SSN: 199-58-1068; D/O/B: 9/6/62 at: Thomas, Thomas & Hafer, LLP, 305 N. Front St., P.O. Box 999, Harrisburg. PA 17108-099,J iAddress) 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, withi~ 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: Douglas B. Marcello, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7238 SUPREME COURT ID#: 36510 ATTORNEY FOR: Defenaant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division :189157.7 Deputy SHARON VANHOVE mhd DARRELL VANHOVE, Plaintiffs V. WALTER POLLACK, Defendant TO: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 4526 - 2002 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.2?, Libe Mutual Insurance Corn an 5021 Louise Drive Mechanicsbur PA 17055 (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: Corn lete co ies of an and all em lo ment records medical records and an and all other documents writin and information re ardin Poli No.: 5BA03816502- Sharon L. VanHove SSN'. 199-58-1068. D/O/B: 9/6/62 at: (Address) You may deliver or mail legible copies of the documems 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: Douglas B. Marcello, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 25 5-7238 SUPREME COURT ID#: 36510 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division :189157.8 Deputy SHARON VANHOVE and DARRELL VANHOVE, Plah~tiffs V. WALTER POLLACK, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . : NO. 4526 - 2002 : CIVIL ACTION - LAW : : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.2~. TO: Lumbermen's Mutual Casualty (Kemper Group) 5001 Louise Drive., Mechanicsburg, PA 17055 (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: Complete copies of any and all records and any and all other documents~ writings and information regarding an accident that occurred on or about 2/29/961 Policy No.: B01179004260q Sharon L. Vanglove, SSN: 199-58-10681 D/O/B: 9/6/62 at: Thomas, Thomas & Hafer, LLP, 305 N. Front St., P.O. Box 999, Harrisburg, PA 17108-0999 (Address) You may deliver or mail legible copies of the documents or produce things requested by tiffs 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: Douglas B. Marcello, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7238 SUPREME COURT ID#: 36510 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division :189157.9 Deputy I certify that the foregoing documem in within action was served upon the following by enclosing the same in an envelope addressed as follows, postage prepaid and depositing the same in the United States Mail, First Class Mail, at Harrisburg, Pennsylvania on the 5th day of November, 2002: Edward E. Knauss, IV, Esquire Metzger, Wiekersham, Knauss & Erb, P.C. 3211 N. Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (Attorney for Plaintify) :185564.1 By: THO ;.~.~ THOMAS & HAFER, LLP o6/glas B. Marcello, 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 Stefanie ~L Brown (717) 255- 7234 smb~,~,,tthlaw, corn November 5, 2002 Edward E. Knauss, IV, Esquire Metzger, Wickersham, Knauss & 'Em} P.C. 3211 N. Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 Re.' Sharon VanHove and Darrell l~anHove v. Walter Pollack Cumberland County C.C.P. No.: 2002-4526 Our File No.: 310-21351 Dear Ed: Enclosed please fred a Notice of Intent to Serve Subpoenas pursuant to Pa.R.C.P. 4009.21 and copy of said subpoenas regarding the above-referenced matter. If you are agreeable to waiving the 20 day objection period, please sign and reau-n the enclosed duplicate copy of this letter. Please indicate if you request copies of records produced as a result of the subpoenas. Thank you for your anticipated courtesy and cooperation. Best regards, Paralegal to Douglas B. Marcello smb:189193.1 THOMAS, THOMAS & HAFER, LLP Enclosur¢.~. Edward E. ~au~g, I~, Esquir~--~ I certify that the foregoing document in within action was served upon the following by enclosing the same in an envelope addressed as follows, postage prepaid and depositing the same in the United States Mail, First Class Mail, at Harrisburg, Pennsylvania on the 12th day of November, 2002: Edward E. Knauss, IV, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 N. Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (Attorney for Plaintifj~ :185564.1 THOMAS, THOMAS & HAFER, LLP ByS~ _ _ SHARON VANHOVE and DARRELL VANHOVE, Plaintiffs V. WALTER POLLACK, Defendant : IN FHE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA '. : NO. 4526 - 2002 : CIVIL ACTION - LAW : : JURY TRIAL DEMANDED As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that: A Notice of Intent to Serve Subpoenas with a copy of the subpoenas attached thereto was mailed or delivered to Plaintiffs counsel at least twenty days prior to the day on which the subpoenas were sought to be served; A copy of the Notice of Intent, including the proposed subpoenas, are attached to this Certificate; ~ Plaintiff's counsel has waived the 20 days and a copy of that correspondence is attached hereto; The subpoenas which will be served are identical to the subpoenas which are attached to the Notice of Intent to Serve Subpoena. Date: November 26, 2002 :190043.2 By: THOMA~S,, THOMAS & HAFER, LLP 12]6~glas B. Marcello, Esquire 3t05 North Front Street - 6th FI. Harrisburg, PA 17108 (717) 255-7238 Attorney for Defendant SHARON VANHOVE and DARRELL VANHOVE, Plaintiffs V. WALTER POLLACK, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 4526 - 2002 : CIVIL ACTION[- LAW : JURY TRIAL DEMANDED TO: Counsel and Parties of Record Defendant, Walter Pollack, intends to serve a subpoena identical to the one attached to this notice. You have twenty (20) days from the date listed below Ln 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: November 12, 2002 :180193.2 By: D~as B. Marcello, Esquire Harrisburg, PA 17108-0999 (717) 255-7238 Attorneys for DeJkndant SHARON VANHOVE and DARRELL VANHOVE, Plaintiffs V. WALTER POLLACK, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 4526 - 2002 : CIVIL ACTION[ - LAW : . : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Mark R. Grubb, M.D., Orthopedic Institute of PA, 875 Poplar Church Road, Camp ltill, PA 17011 (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: Complete copies of any and all medical records, medical reports, medical bills, diagnostic studies, notes, correspondence, MRI idms, CAT scans, and/or x-ray films in your t}ossession re~ardin~ Sharon L. VanHove, SSN: 199-58-1068; D/O/B: 9/6/62 at: Thomas, Thomas & Hafer, LLP, 305 N. Front St., P.O. Box 999, Harrisburg, PA 17108-0999 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek. a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Douglas B. Marcello, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7238 SUPREME COURT ID#: 36510 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy :189157.10 I certify that the foregoing document in within action was served upon the following by enclosing the same in an envelope addressed as follows, postage prepaid and depositing the same in the United States Mail, First Class Mail, at Harrisburg, Pennsylvania on the 12th day of November, 2002: Edward E. Knauss, IV, Esquire Metzger, Wiekersham, Knauss & Erb, P.C. 3211 N. Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (Attorney for P laintifO :185564.1 By: THOMAS, THOMAS & HAFER, LLP · Marcello, Esquire THOMAS, THOMAS & HAFER t. LP ATr©RIqEYS ,~T LAW 305 North Front Sb'eet, P.O. Box 999, Harrisburg, PA i7108 Phone: (717) ~37-7100 Fax: (717) 237-7105 November 12, 2002 SteJ~tnie M. Brown (717) 255- 7234 smb(~tthlcrw, corn Edward E. Knauss, IV, Esquire Melzger, Wickersham, Knauss & Erb, P.C. 3211 N. Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 Re.' Sharon VanHove and Darrell VanHove v. Walter Pollack Cumberland County C.C.P. No.: 2002-4526 Our File No.: 310-21351 Dem' Ed: Enclosed please find a Notice of Intent to Serve Subpoenas pm'swam to Pa.R.C.P. 4009.21 and copy of said subpoenas regarding the above-ret~renced matter. If you are agreeable to x~aiving the 20 day objection period, please sign mad return the enclosed duplicate copy of this letter. Please indicate if'you requesl copies of records produced as a result of the subpoenas. Thank you for your anticipated courtesy and cooperation. smb: 189193.2 Enclosure /Edward E. Knauss, IV. Esquire Best regards, ~ _/~ / t~aralel~al. Jto glas B. Marcello THOMAS, THOMAS & HAFER, LLP I certify that the foregoing document in within action was served upon the following by enclosing the same in an envelope addressed as follows, postage prepaid and depositing the same in the United States Mail, First Class Mail, at Harrisburg, Pennsylvania on the 26th day of November, 2002: Edward E. Knauss, IV, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 N. Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (Attorney for Plaintiff) :185564.1 By: THOM~THOMAS & HAFER, LLP Douglas B. Marcello, Esquire SHARON VANHOVE and DARRELL VANHOVE, Plaintiffs V. WALTER POLLACK, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 4526 - 2002 : CIVIL ACTION - LAW .' : : JURY TRIAL DEMANDED As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that: A Notice of Intent to Serve Subpoenas with a copy of the subpoenas attached thereto was mailed or delivered to Plaintiff's counsel at least twenty days prior to the day on which the subpoenas were sought to be served; A copy of the Notice of Intent, including the proposed subpoenas, are attached to this Certificate; o Plaintiff's counsel has waived the 20 days and a copy of that correspondence is attached hereto; Plaintiff's counsel has also verbally waived the 20 days with regard to the subpoena for Harrisburg Hospital on January 21, 2003. The subpoenas which will be served are identical to the subpoenas which are attached to the Notice of Intent to Serve Subpoena. Date: January 21, 2003 :190043.3 THOMAS, THOMAS & HAFER, LLP DoUgl~ B/q~arcello, Esquire 305 Nortlrr~ront Street - 6th Fl. Harrisburg, PA 17108 (717) 255-7238 Attorney for Defendant SHARON VANHOVE and DARRELL VANHOVE, Plaintiffs V. WALTER POLLACK, Defendant TO: Counsel and Parties of Record : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 4526 - 2002 : CIVIL ACTION - LAW .- : JLTRy TRIAL DEMANDED Defendant, Walter Pollock, intends to serve a subpoena identical to the one 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: January 3, 2003 :189193.3 THOMAS, THOMAS & HAFER, LLP Dougl~a,./,B~ MaS:'cello; Esqhir~ 305 North Front Street P. O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7238 ,4ttorneys for Defendant SHARON VANHOVE and DARRELL VANHOVE, Plaintiffs V. WALTER POLLACK, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 4526 - 2002 : CIVIL ACTION - LAW : JURY TRIAL DEMANDED TO: SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 Keystone Spine Center~ Inc., 1521 Cedar Cliff Drive, Camp RilL PA 17011 (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: Complete copies of any and all medical records, medical reports~ medical bill.~ diagnosfi,- studies~ notes~ correspondence, MRI filrna~ CAT scans~ and/or x-ray filrnn in you, possession regarding Sharon L. VanHove~ SSN: 199-58-1068; D/O/B: 9/6/62 at: Thomas, Thomas & Hafer~ LLP~ 305 N. Front St.~ P.O. Box 999, Harrisburg~ PA 17108-0999 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the eopie~or producing the thing~ 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. TI-IlS SUBPOENA WAS ISSUED AT ?I--IE REQUEST OF THE FOLLOWING PERSON: NAME: Douglas B. Marcello, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7238 SUPREME COURT ID#: 36510 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division :189157.11 Deputy SHARON VANHOVE and DARRELL VAN-HOVE, Plaintiffs V. WALTER POLLACK, Defendant : 12N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 4526 - 2002 : CIVIL ACTION - LAW : : ·: JURY TRIAL DEMANDED TO: SUBPOENA TO PRODUCE DOCUMENTS OR TILINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 Harrisburg Hospital-Pinnacle Health, South Front Street, HarrisburR, PA 17101 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of any and aH medical records, medical reports, medical bills, diao_nostir ,studies, notes, correspondence, ER records, Mill filma~ CAT scans, and/or x-ray filmn ~, your oossession re~ardine Sharon L. VanRove, SSN: 199'58-1068~ D/O/B: 9/6/62 at: .Thomas, Thoma~ & Hafer, LLP, 305 N. Front St., P.O. Box 999, Harrisburg~ PA 17108 0999 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above: YOU have the right to ~eek in advance, the reasonable CoSt 0f 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: Douglas B. Marcello, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7238 SUPREME COURT ID#: 36510 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division :189157.12 Deputy I certify that the foregoing document in within action was served upon the following by enclosing the same in an envelope addressed as follows, postage prepaid and d,el~ositing the same ;;United States Mail, First Class Mail, at Harrisburg, Pennsylvania on the 3 day of January, Edward E. Knauss, IV, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 N. Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (Attorney for Plaintif~ :185564.1 By: !HO S, THOMAS & HAFER, LLP ~buglas B. Marcello, Esquire January 1 O, 2003 STEFAN!E M. BRO$,rN THOMAS, THOMAS & HAFER, LLP 305 North Front Street P.O. Box 999 Harrisburg, Pa 17108 SINCE 1888 3211 North Front Street EO. Box 5300 Harrisburg, PA 17110-0300 717-238-8187 Fax: 717-234-9478 Other Offic~ Colonial Park Mechanicsburg 717-652-7020 717-691-5577 Millersburg shippensburg 717-692-5810 717-530-7515 RE: VANHOVE vs. Pollack Dear Ms. Brown: We are in receipt of your correspondence dated January 3, 2003, along with a Notice of Intent to Serve Subpoenas to Keystone Spine Center. Please be advised that we have no objection to this subpoena. Kindly supply our office with copies of all records received pursuant to the subpoena. If, rou should have any comments or questions, please feel free to contact me at the above nur [Der. Vel truly yours, Paralegal AMF/hs Document #: 248401. ] James ECad Edward E. Knauss, IV* Jered L. Hock Steven E Miner Clark DeVere Francis J. Lafferty, IV David H. Martineau Andrew W. Norfleet Melissa L. Van Eck Andrew C. Spears Young-Sub Koo * Board Certified in civil trial law and advocacy by the National Board I certify that the foregoing document in within action was served upon the following by enclosing the same in an envelope addressed as follows, postage prepaid and depositing the same in the United States Mail, First Class Mail, at Harrisburg, Pennsylvania on the 21st day of January, 2003: Edward E. Knauss, IV, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 N. Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (Attorney for Plaintiff) :185564.1 By: TH~.~S, THOMAS & HAFER, LLP ouglas B. Marcello, Esquire SHARON VANHOVE and DARRELL VANHOVE, Plaintiffs Vo WALTER POLLACK, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 4526 - 2002 : CIVIL ACTION - LAW : JURY TRIAL DEMANDED As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that: A Notice of Intent to Serve Subpoenas with a copy of the subpoenas attached thereto was mailed or delivered to Plaintiff's counsel at least twenty days prior to the day on which the subpoenas were sought to be served; A copy of the Notice of Intent, including the proposed subpoenas, are attached to this Certificate; Plaintiff's counsel has waived the 20 days and a copy of that correspondence is attached hereto. The subpoenas which will be served are identical to the subpoenas which are attached to the Notice of Intent to Serve Subpoena. Date: March 10, 2003 :190043.4 By: THOMAS, THOMAS & HAFER, LLP Dou~ ,t~B. )~ar~ellg(~Esqui.'re ~' th 305 North'~'~ont Sfreet - 6 Fl. Harrisburg, PA 17108 (717) 255-7238 Attorney for Defendant SHARON VANt-IOVE and DARRELL VANHOVE, Plaintiffs V. WALTER POLLACK, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 4526 - 2002 : CIVIL ACTION - LAW : JURY TRIAL DEMANDED NOTICE OF ~TENT TO SERVE SUBPOENAS TO i, DISCO~RYP~UANTTO RULE4009~21 TO: Counsel and Parties of Record Defendant, Walter Pollock, intends to serve subpoenas identical to the ones 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 subpoenas. If no objection is made, the subpoenas may be served. Date: February 26, 2003 :189193.4 By: THOMAS, THOMAS & HAFER, LLP Dou, gl'~. ~ello, Esquire 30ff"North Front Street P. O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7238 Attorneys for Defendant SHARON VANI-IOVE and DARRELL VANHOVE, Plaintiffs WALTER POLLACK, Defendmat : IN THE COURT OF COM2MON PLEAS : CUM]3ERLANTD COUNTY, PENNSYLVANIA : : NO. 4526 - 2002 : ClX/IL ACTION - LAW : JURY TRIAL DEM_ANDED TO: 'SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOXrERY PURSU.~J~T TO RULE 4009.22 Tristan Associates, 4518 Union Deposit Road. Harrisburg. PA 17111 (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: Complete copies of any and ali medical records~ medical reports, medical bills, diagnostic studies, notes, .correspondence, MRI films, CAT scans, and/or x-ray films in x,our possession regarding Sharon L. VanHove, SSN: 199-58-1068: D/O/B: 9/6/62 at: Thomas. Thomas & Haler, LLP~ 305 N. Front St., P.O. Box 999, Harrisburg. PA 17108-0999 (Address) You may deliver or mail le~ble copies of the docmr~ents 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 sert, ice, the pm-ty 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: Douglas B. Marcello, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONTE: (? 17) 25 5-7238 SUPREME COURT IDif: 36510 ATTORNEY FOR: Defendant BY THE COURT: DATE: SeaI of the Com-t Prothonota~,/Clerk, Civil Division :189157.13 Deputy SI-Li_RON VANHOVE and DARP,_ELL VANHOVE, Plaintiffs WALTER POLLACK, Defendmxt IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 4526 - 2002 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Orthopedic Institute of Pennsylvania, 875 Poplar Church Road, Camp Hill, PA 17011 (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: Complete copies of any and all IV[RI film~ CAT scans~ and/or x-ray films in your possession regardinff Sharon L. VanI4ove~ SSN: 199-58-1068; D/O/B: 9/6/62 at: Thomas~ Thomas & Haler, LLP~ 305 N. Front St., P.O. Box 999. ltarrisburg, PA 17108-0999 (Address) You may deliver or mail legible copies of the documents or produce ttfings 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 tl~ngs sought. If you fail to produce the docUments or things required by this subpoena, within m~enty (20) days after its service; the party sen, ing this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQLTEST OF THE FOLLO\~q-NG PERSON: NAME; Douglas B. Mm-cello, Esquire ADDRESS: P.O.'-Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (~17) 25 5-7238. SUPREME COURT lZ)#: 36510 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division -:189157.14 Deputy SHARON VANHO\qE and DAR_R_ELL VANHOVE, Plaintiffs V. WALTER POLLACK, Defendant :/N THE COLTRT OF COlkG4ON PLEAS : CUM~BERLAND COUNTY, PENNSS~LVANIA : : NO. 4526 - 2002 : CIVIL ACTION -. LAW : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Physicians Imaging Centers. 4349 Carlisle Pike, Camp Hill, PA 17011 (Name of Person or Entity) Within m, enty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of any and all medical records, medical reports~ medical bills, diagnostic studies, notes~ correspondence MRI films, CAT scans, and/or x-ray filrn.~ in your possession re~arding Sharon L. VanHove, SSN: 199-58-1068] D/O/B: 9/6/62 at: Thomas, Thomas & l:Iafer~ LLP, 305 N. Front St., P.O. Box 999, Harrisburg, PA 17108-0999 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producCg 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 BrAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Douglas:B. Marcello, Esquire ADDRESS: P.O. Box 999, Han-isburg, PA 17108-0999 TELEPHONE: (717) 255-7238 SUPREME COURT ID#: 36510 ATTORNEY FOR: Defendant BY THE COURT: DATE.: Seal of the Court Prothonotary/Clerk, Civil Division :189157.15 Deputy SHARON VANi-IOVE and DARRELL VANI-tOVE, Plaintiffs WALTER POLLACK, Defendm~t IN THE COURT OF COM2vlON PLEAS CUM. BERLAND COUNTY, PENNSYLVANIA NO. 4526 - 2002 CI¥IL ACTION - LAW JURY TRIAL DEMANDED ' SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Holy Spirit Hospital, ATTN: Records Custodian, 503 North 21st Street, Camp Hill, PA 17011 (Name of Person or Entity) Within twenty (20) days after service of th_is subpoena, you are ordered by the court to produce the follOWing documents or things: Complete copies of any and all MRI films~ CAT scans, and/or x-ray films in your possession regarding Sharon L. VanHove, SSN: 199-58-1068; D/O/B: 9/6/62 at: Thomas, Thomas & Hafer. LLP, 305 N. Front St., P.O. Box 999, Harrisburg, PA 17108-0999 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the ti-tings sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its serxdce, the party sezadng this subpoena may seek a court order compelling you to comply Mth it. THIS SUBPOENA WAS ISSUED AT TI-~ REQUEST OF THE FOLLOV¢ING PERSON: NAME: DouglasB. Marcello, Esquire ADDRESS: P.O. 'Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 25 5-7238 SUPREME COURT ID#: 36510 ATTORNEY FOR: Defendant BY THE. COURT: DATE: Seal of the Com-t Prothonotm3,/Clerk, Civil Division :189157.16 Deputy SHARON VANI-IOVE and DARRELL VANHOVE, Plaintiffs WALTER POLLACK, Defendant · IN THE COURT OF COS~MON PLEAS · CUM]3ERLAND COUNTTy, PENNSYLVANIA · NO. 4526 - 2002 · CIVIL ACTION - LAW · JURY TRIAL DEMANDED :'SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: MaenetiC lmagin~ Center, 4665 Trindle Road, Mechanicsbur~, PA 17055 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the foll(~wing documents or things: Complete copies of any and all MRI films, CAT scan~ and/or x-ray ~ms in your. possession regarding Sharon L. VanFIove, SSN: 199-58-1068; D/O/B: 9/6/62 at: Thomas. Thomas & l:lafer, I,IJP~ 305 N. Front St, P.O. Box 999, Harrisburg, PA 17108-0999 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above· You have the fight to seek in advance, the reasonable cost of preparing the copies or producing the things sought. ILl you fail to produce the documents or things required by this subpoena, w4thin Bxrenty (20) days after its service, .the party ser~4ng this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE. REQUEST OF TILE FOLLOWING PERSON: NAM2E: Douglas B. Marcello, Esquire ADDRESS: P.O?'Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (~ 17) 255-7238 SUPREME COL~T ID#: 36510 ATTORNEY FOR: Defe~dant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Ci~41 Division :189157.17 Deputy I certify that the foregoing document in within action was served upon the following by enclosing the same in an envelope addressed as follows, postage prepaid and depositing the same in the United States Mail, First Class Mail, at Harrisburg, Pennsylvania on the 25th day of February, 2003: . Edward E. Knau§s, IV, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 N. Front Street P.O. Box 5300 Harrisburg, PA !7110-0300 (Attorney for Pl,.?.intif)9 :185564.1 By: TitOMAS~.T/~OMAS & ItAFER, LLP Doaglas B. Marcello, Esquire THOMAS, THOMAS & HAFER LLP ATTORNEYS AT [,AW 305 North Front Street, P.O. Box 999, Harrisburg, PA 17108 Phone: (717) 237-7100 Fax: (717) 237-7105 February 26, 2003 Edward E. Knauss, IV, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 N. Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 Re.' Sharon VanHove and Darrell VanHove v. Walter Pollack Cumberland County C.C.P. No.: 2002-4526 ~Our File No.: 310-21351 Dear Ed: www.tthlaw.com Stefanie M. Brown (717) 255-7234 smb~tthlaw, com Enclosed please find a Notice of Intent to Serve Subpoenas pursuant to Pa.R.C.P. 4009.21 and copy of said subpoenas regarding the above-referenced matter. If you are agreeable to waiving the 20 day objection period, please sign and return the enclosed duplicate copy of this letter. Please indicate if you request copies of records produced as a result of the subpoenas. Thank you for your anticipated courtesy and cooperation. smb:189193.4 Enclosure... Edward E. Knauss, IV, Esquire I certify that the foregoing document in within action was served upon the following by enclosing the same in an envelope addressed as follows, postage prepaid and depositing the same in the United States Mail, First Class Mail, at Harrisburg, Pennsylvania on the l0th day of March, 2003: Edward E. Knauss, IV, Esquire Metzger, Wiekersham, Knanss & Erb, P.C. 3211 N. Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (Attorney for Plaintiff) THOMAS, THOMAS & HAFER, LLP Douglaa~. M~rcello, Esquire :185564.1 SHARON VANHOVE and DARRELL VANHOVE, Plaintiffs WALTER POLLACK, Defendant : 1N THE COURT ,OF COMMON PLEAS : CUMBERLAND COUNTY. PENNSYLVANIA : : NO. 4526 - 2002 : CIVIL ACTION - LAW : JURY TRIAL DEMANDED TO THE PROTHONOTARY: Date: 258860.1 Please mark the above matter settled, discontinued and ended. By: Metzgp~'Wicker~sJ~am, Knauss & Erb, P.C. Edward E. Knauss, IV, Esqu' 3211 N. Front Street P.O. Box 5300 Hamsburg, PA 17110-0300