Document npZGRBvmpJ7mjZ9q1avxz5db8
Te: Mr. W. Bronner
Internal
"
Memorandum Date: January 3, 1986
Unit: 0* G. C. - New York
From:
E./J. Eichen
Unit: NL CHEMICALS - Hightstown
Subject: Vr . Mc CULLOUGH v s . ALBERICO
r ec eiv ed : JAN fi 1986
h. BRONNEB
Attached please find correspondence recently received on the above-captioned case. Please advise us as to how we should proceed.
Thank you for your assistance.
-/k Attach.
:. J. Eichen
NL 000039593
N 26092
. - V'T-"V.r;."."j': ;
Medical Copy Services
1315 Walnut Srr*rf. Suit* 1016 Ptuladalohta. Prnsvlvama 19107 (2151 5<W>0334 October 21, 1985
YQ .
National Lead Industries/ Associated Lead Inc 2545 Aramingo Ave Phila.,PA
RE : MCS180978, Robert McCullough
Dear Records Custodian:
Patricia Young, PMSLIC
certain records from you.
has asked that we obtain copies of
The records of which you are custodian have been requested by counsel torDefendant . . in the above lawsuit which is pending in the Court of Common Pleas of Philadelphia County. This request is being made pursuant to court regulation #390 which provides for the informal production of records where there is no abjection by counsel and is an effort to save time and expense.
Although the attached records reproduction subpoena is not a formal subpoena, if far same reason you choose not to produce the records in the manner indicated on the attached records reproduction subpoena, a formal subpoena may be subsequently served requiring your personal appearance at an attorney's office to produce the records and authenticate them.
We look forward to obtaining the records in the manner indicated in the attached records reproduction subpoena.
Enclosure
NL 000039594
Pennsylvania New York Delaware Virginia Maryland Washington. D.C. Connecticut New Jersey
N 26092.01
RECORDS REPRODUCTION SUBPOENA
Robert McCullough
vs
Alberico, MD
COURT OF COMMON PLEAS
PHILADELPH lA COUNTY , PA
August
TERM. 19 85
NO .
3253
TO: CUSTODIAN OF RECORDS FOR
National Lead Ind/Assoc Lead, Inc
1. You are requested to produce
Any and all records, correspondence, files and memorandums, handwritten notes, billing
and payment records, relating to any examination, consultation, care or treatment of
Robert McCullough, Plaintiff,- Address: 6534 N. 18th St, Phila.,PA; as a patient up to,and
including the present.
'
2. YOU SHOULD PROOUCE THESE RECORDS ON OR BEFORE n-15-85
BY :
(xxxx ) mailing the original records to Medical Copy Services where the originals will be copied and returned to you;
( } producing the original records at your office for reproduction at Medical Copy Services after which the originals will be returned to you;
( ) bringing the original records to Medical Copy Services where they will be copied at that location and returned
to you. DO NOT MAIL THE ORIGINAL RECORDS;
( ) producing the original records at your office where the originals will be copied. DO NOT MAIL THE ORIGINAL RECORDS.
Dste' October 21, 1985
MEDICAL COPY SERVICES 1315 Walnut Street. Suite 1016 Philadelphia. PA 19107 (215
By:
NL 000039595
N 26092.02
CERTIFICATION OF RECORD CUSTODIAN
I am the authorized Custodian of Records for
National Lead Ind/Assoc Lead Inc
and I have the authority to certify the attached records of
Robert McCullough
Being duly sworn according to law, I hereby certify, depose and say that:
These records were reproduced in my presence or at my direction, these records were prepared in the ordinary course of business by authorized personnel on or about the time of the event or act, and a careful search for the records has been made by me or under my direction and produced in accordance with the attached subpoena duces tecum. Therefore these records constitute all the records of said individual described above.
I certify and declare that the above described facts are true and correct to the best of my
personal Knowledge.
f
Comments: ____________________________ '
___ !_____ __ _______ __ ________
Date:
Signature:
NL 000039596
N 26092.03