Docket Number: 2643 PRESBYTERIAN MEDICAL CENTER OF WASHINGTON, PENNSYLVANIA, INC.

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Docket Number: 2643 PRESBYTERIAN MEDICAL CENTER OF WASHINGTON, PENNSYLVANIA, INC. Samuel B. Fineman, Esquire Randy J. Riley, Esquire *Daniel K. Natirboff, Esquire Michael A. Hynum, Esquire VS. COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF PUBLIC WELFARE John A. Kane, Chief Counsel Kathleen Grogan, Assistant Counsel Jason W. Manne, Assistant Counsel

February 5, 1998 Claim and filing fee filed by attorney for Plaintiff. Amount of Claim: $300.00+. February 10, 1998 Copy of Claim forwarded to attorney for Defendant and Chief Deputy Attorney General. ANSWER DUE FROM DEFENDANT MARCH 10, 1998. February 17, 1998 Acceptance of Service of Claim received from Chief Deputy Attorney General. Receipt of same acknowledged by Chief Deputy Attorney General February 11, 1998. February 26, 1998 Letter received from attorney for Defendant requsting a 30-day extension of time until March 30, 1998, in which to file Defendant=s Response to Plaintiff=s Claim. February 27, 1998 Letter forwarded to Defendant granting Defendant a 30-day extension of time until March 30, 1998, in which to file Defendant=s Response to Plaintiff=s Claim. Response due March 30, 1998. March 31, 1998 Letter received from attorney for Defendant requesting a 30-day extension of time in which to file Defendant=s Response to Plaintiff=s Claim. April 2, 1998 Letter forwarded to Defendant granting Defendant=s request for a 30-day extension of time in which to file Defendant=s Response to Plaintiff=s Claim. Response due May 4, 1998. May 11, 1998 Letter filed by attorney for Defendant requesting until June 15, 1998, in which to file their response to Plaintiff=s Claim. Copy forwarded to attorney for Plaintiff by attorney for Defendant. May 13, 1998 Letter forwarded to Defendant granting Defendant until June 15, 2

1998 in which to file their response to Plaintiff=s Claim. Copy forwarded to attorney for Plaintiff and attorney for Defendant. June 22, 1998 Answer and New Matter filed by attorney for Defendant. Copy forwarded to attorney for Plaintiff by attorney for Defendant. July 1, 1998 Letter forwarded to attorney for Plaintiff requesting response to Defendant=s New Matter. Response due August 1, 1998. July 31, 1998 Plaintiff=s Answer to New Matter filed by attorney for Plaintiff. Copy forwarded to attorney for Defendant by attorney for Plaintiff. August 6, 1998 Letter forwarded to parties directing parties to commence with discovery. November 16, 1999 from parties December 16, 1999. November 19, 1999 Status letter received from attorney for Plaintiff advising that the parties are conducting settlement negotiations. November 19, 1999 Certificate of Service of Plaintiff=s Request for Production of Documents and First Request for Answers to Interrogatories filed by attorney for Plaintiff. November 29, 1999 Amended Answer, New Matter and Counterclaim filed by attorney for Defendant. Copy forwarded to attorney for Plaintiff by attorney for Defendant. Response due from Plaintiff 1/3/00. December 31, 1999 Letter received from attorney for Plaintiff requesting an 3

extension of time until February 4, 2000 in which to respond to Defendant=s New Matter and Counterclaim. January 5, 2000 Letter forwarded to attorney for Plaintiff granting Plaintiff=s request for an extension of time until February 4, 2000 in which to respond to Defendant=s Amended New Matter and Counterclaim. RESPONSE DUE FEBRUARY 4, 2000. February 7, 2000 Plaintiff=s Reply to Defendant=s Amended New Matter and Counterclaim filed by attorney for Plaintiff. Copy forwarded to attorney for Defendant by attorney for Plaintiff. February 10, 2000 Letter forwarded to parties directing parties to commence with discovery. February 14, 2000 Counter-Reply to New Matter to Counterclaim filed by attorney for Defendant. Copy forwarded to attorney for Plaintiff by attorney for Defendant. September 12, 2000 from parties October 12, 2000. *October 2, 2000 Withdrawal of Appearance of Randy J.Riley, Esquire and Entry of Appearance of Daniel K. Natirboff, Esquire filed by attorney for Plaintiff. October 2, 2000 Motion to Compel Discovery filed by attorney for Plaintiff. Copy forwarded to attorney for Defendant by attorney for Plaintiff. Response due from Defendant November 6, 2000. March 19, 2001 4

from parties April 19, 2001. April 17, 2001 Status letter received from attorney for Plaintiff advising that the Claimant is currently preparing a settlement offer for submission to Defendant. May 23, 2001 from parties June 25, 2001. June 25, 2001 Letter received from attorney for Plaintiff advising that the parties are in the process of conducting settlement negotiations. November 19, 2001 The Board rendered an Opinion and made the following Order: AAND NOW, this 19th day of November, 2001, it is hereby ORDERED and DECREED that the Defendant, Commonwealth of Pennsylvania, Department of Public Welfare, shall answer the discovery requests of Claimant, Presbyterian Medical Center of Washington, Pennsylvania, Inc., within thirty (30) days of the exit date of this Order or suffer sanctions.@ Copy forwarded to attorney for Plaintiff and attorney for Defendant. November 29, 2001 Acceptance of Service of Opinion and Order dated November 19, 2001 received from attorney for Plaintiff. Receipt of same acknowledged by attorney for Plaintiff November 27, 2001. February 7, 2002 from parties March 7, 2002. March 8, 2002 Status letter received from attorney for Plaintiff advising that the parties are in discovery. September 11, 2002 5

from parties October 11, 2002. October 15, 2002 Letter received from attorney for Plaintiff advising that the parties are in discovery and upon completion of discovery, Plaintiff will pursue settlement. November 22, 2005 Board rendered an Opinion and Order. Order as follows: AND NOW, this 22 nd day of November, 2005, it is ORDERED and DECREED that pursuant to 42 Pa. C.S.A. 5103(a) and Pa. R.C.P. 213(f), this matter and the record thereof is TRANSFERRED to the Department of Public Welfare, Bureau of Hearings and Appeals. Copy forwarded to Plaintiff and Defendant. 6