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Home My WebLink About02-4612SHOLLENBERGER & JANUZZI, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 Attorneys for Plaintiff BRUCE A. DOOLITTLE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. THOMAS SANGREY and AIMEE SANGREY, husband and wife, and T. ANTHONY SANGREY, Defendants NO. p2 - '94,1*t- l l.-? CIVIL ACTION - LAW JURY TRIAL DEMANDED 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 this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that, if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money 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. DAUPHIN COUNTY LAWYER REFERRAL SERVICE 213 North Front Street Harrisburg, PA 17101 (717) 232-7536 SHOLLENBERGER & JANUZZI, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 Attorneys for Plaintiff BRUCE A. DOOLITTLE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. THOMAS SANGREY and AIMEE SANGREY, husband and wife, and T ANTHONY SANGREY, Defendants NO. CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICIA LE HAN DEMANDADO A LISTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (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 ]as demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomaro medidas y puede entrar una orden contra usted sin previo aviso o notoficacaion y por cualquier queja o alivio que es pedido en la peticion do demanda. usted puede perder dinero o sus propiededas o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAIL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. DAUPHIN COUNTY LAWYER REFERRAL SERVICE 213 North Front Street Harrisburg, PA 17101 (717) 232-7536 SHOLLENBERGER & JANUZZI, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 Attorneys for Plaintiff BRUCE A. DOOLITTLE, Plaintiff V. THOMAS SANGREY and AIMEE SANGREY, husband and wife, and T ANTHONY SANGREY, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. - CIVIL ACTION - LAW JURY TRIAL DEMANDED COMPLAINT AND NOW comes the Plaintiff, BRUCE A DOOLITTLE, by and through his attorney, SHOLLENBERGER & JANUZZI, LLP, and respectfully represents the following: 1. The Plaintiff, BRUCE A. DOOLITTLE, is an adult individual who currently resides at 136 Bosler Avenue, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendants, THOMAS and AIMEE SANGREY, are a husband and wife whose last known address is 107 Ellsmere Lane, Mechanicsburg, Cumberland County, Pennsylvania. 3. The Defendant, T. ANTHONY SANGREY, is an adult individual whose last know address is 19 E. Main Street, Mechanicsburg, Cumberland County, Pennsylvania. 4. The facts and circumstances hereinafter set forth took place on June 27, 2001 at or about 5:30-6:30 p m. at 19 E. Main St., Apt. 6, Mechanicsburg, Cumberland County, Pennsylvania. 5. At all times relevant hereto, the Plaintiff resided in Apartment 6 in the above referenced apartment building owned by the Defendants, THOMAS SANGREY and AIMEE SANGREY. SHOLLENBERGER&JANUM, LLP 1820 UNGLESTOW ROAD • P.O. BOX 60545 • HARRISBURG, PA 17106-0545 (717) 234-37M • FAX (717) 234-8212 6. At the aforesaid time and place, Plaintiff, BRUCE A DOOLITTLE was filling a birdfeeder on the fire escape, when the railing collapsed and he fell 20 feet and landed on top of an air conditioning unit. 7. At all times relevant hereto, the Defendants, THOMAS SANGREY, AIMEE SANGREY and T. ANTHONY SANGREY, retained control of the common areas of said apartment building, including the fire escape. 8. The aforesaid incident and resulting injury to the Plaintiff, BRUCE A DOOLITTLE, was caused as a direct and proximate result of the negligence, carelessness and recklessness of the Defendants, THOMAS SANGREY, AIMEE SANGREY and T. ANTHONY SANGREY, which consisted of: Allowing the railing on the said fire escape to fall into disrepair; C. Failing to exercise reasonable care to discover the obvious dangerous condition referenced above and the unreasonable risk involved; d. Failure to warn its lessees of the obvious dangerous condition of the above referenced fire escape; e. Failure to exercise the duty of reasonable care required of lessors to their lessees to protect lessees from known and obvious dangerous conditions existing on that part of the premises controlled by the lessor; and Failing to repair a railing which was in obvious need of repair. 9. The aforesaid incident was caused solely and exclusively by the wrongful and liability producing conduct of the Defendants, THOMAS SANGREY, AIMEE SANGREY and T. ANTHONY SANGREY as set forth above and was due in no manner whatsoever to any act or failure to act on the part of the Plaintiff, BRUCE A DOOLITTLE. 10. As a result of the above described fall, Plaintiff, BRUCE A DOOLITTLE, sustained serious and permanent injuries, including but not limited to: a. Cerebral contusions with right frontoparietal contusion and small hemotoma; SHOLLENBERGER & JANUZZI, UP 1820 UNG=OW ROAD • P.O. BOX 60545 • HARRISBURG, PA 171060545 (717) 234-37W • FAX (717) 2348212 b. Left temporal contusion; C. Cerebral concussion; d. Multiple contusions of the hand with pain and loss of range of motion of multiple joints; e. Bruise/fracture of ribs number three and number ten; F. Closed head injury with resultant permanent disability; f. Severe shock to the nerves and nervous system; g. Extreme mental and physical anguish. 11. As a further result of the wrongful and liability producing conduct of the Defendant herein, Plaintiff, BRUCE A DOOLITTLE has been obliged to expend various and diverse sums of money for medicine and medical care and treatment in and about an effort to cure himself of the ills and injuries he has suffered and will be obliged to do so in the future to his great detriment and loss. 12. As a further result of the wrongful and liability producing conduct of the Defendants herein, Plaintiff, BRUCE A DOOLITTLE has suffered a loss of his earnings and earning capacity, and has and may continue to suffer such loss and depreciation for an indefinite time into the future. 13. As a further result of the wrongful and liability producing conduct of the Defendants herein, Plaintiff, BRUCE A DOOLITTLE has undergone great physical pain and anguish, as well as embarrassment and humiliation and will continue to endure the same for an indefinite time into the future to his great detriment and loss. 14. As a further result of the wrongful and liability producing conduct of the Defendants herein, Plaintiff, BRUCE A DOOLITTLE has been extremely 3 SHOLUF4BERGER & JANOZZI, LLP 1820 UNGUSTOW ROAD • P.O. BOX 0545 • HAMSBURG, PA 17106-0545 (717) 2343700 0 FAX Q17) 234-8212 inconvenienced and unable to attend to his life's daily activities as well as having been deprived of life's pleasures and will continue to suffer same for an indefinite time into the future to his great detriment and loss. 17. As a further result of the wrongful and liability producing conduct of the Defendants herein, Plaintiff, BRUCE A DOOLITTLE has suffered other expenses and losses. WHEREFORE, Plaintiff, BRUCE A. DOOLITTLE demands judgment against the Defendants, THOMAS SANGREY and AIMEE SANGREY for compensatory damages in an amount in excess of the amount requiring compulsory arbitration. Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP By: L4d Karl J. an zi , Esq. Attorney I.D. No. 65575 Dated: 2002 4 SHOLLENBERGER & JANUZZI, LLP 1820 UNGLESTOW ROAD • P.O. BOX 60545 • HARRISBURG, PA 171064545 (717) 23F3700 0 FAX (717) 234-8212 VERIFICATION I, Bruce A. Doolittle , hereby acknowledge that I am a Plaintiff in this action and that I have read the Carl a i nt and that the facts stated herein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date:. 023 ?U?? 1630 LINGLESTONN ROAD 0 P:0E 60% 60519NiZZI Up (Z" DJ NAA.2ISBIIRG. PA 17106-0545 3700 * PAt ;]3]I 2J4 8.212 •n , .1 7 „ x OL-) STEPHEN L. BANKO, JR., ESQUIRE Pa. Supreme Court I. D. No. 41727 MARGOLIS EDELSTEIN P.O. Box 932 Harrisburg, PA 17108-0932 3510 Trindle Road Camp Hill, PA 17011 Telephone: (717) 975-8114 FAX: (717) 975-8124 Attorney for Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRUCE A. DOOLITTLE, Plaintiff NO. 02-4612 CIVIL TERM V. THOMAS SANGREY and AIMEE SANGREY, husband and wife,: and T. ANTHONY SANGREY, Defendants TO THE PROTHONOTARY: CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO ENTER APPEARANCE Kindly enter my appearance on behalf of Defendants, Thomas Sangrey and Aimee Sangrey, husband and wife, and T. Anthony Sangrey, in the above-captioned matter. IS EDELSTEIN Date: October 2002 By: St L. Banko, Jr. Atto ney D. No. 41727 P. O. Box 932 Harrisburg, PA 17108-0932 3510 Trindle Road Camp Hill, PA 17011 (717) 975-8114 (717) 975-8124 FAX Counsel for Defendants CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing on all counsel of record by placing the same in the United States mail at Camp Hill, Pennsylvania, first-class postage prepaid, on the _1_1 day of Lce , 2002, and addressed as follows: Karl J. Januzzi, Esquire Shollenberger & Januzzi, LLP 1820 Linglestown Road P. 0. Box 60545 Harrisburg, PA 17106-0545 (Attorney for Plaintiff) Secretary n CJ _TJ ^ t_ ri f_l ' l -? ..... _ mi , n i ri 1 ry w SHERIFF'S RETURN - REGULAR CASE NO: 2002-04612 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DOOLITTLE BRUCE A VS SANGREY THOMAS ET AL RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SANGREY THOMAS the DEFENDANT , at 1218:00 HOURS, on the 30th day of September, 2002 at 107 ELLSMERE LANE MECHANICSBURG, PA 17055 by handing to AIMEE SANGREY, WIFE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs Docketing 18.00 Service 6.90 Affidavit .00 Surcharge 10.00 .00 34.90 Sworn and Subscribed to before me this b'" day of Cl Gu. tro L A. D. . n "4- Prothonotary ' I - So Answers: R. Thomas Kline 10/02/2002 SHOLLENBERGER JANUZZI By: Deputy Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2002-04612 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DOOLITTLE BRUCE A VS SANGREY THOMAS ET AL RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon AIMEE the DEFENDANT , at 1218:00 HOURS, on the 30th day of September, 2002 at 107 ELLSMERE LANE MECHANICSBURG, PA 17055 by handing to AIMEE SANGREY a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 nn 1 V . VU Sworn and Subscribed to before me this 1 41 day of ?c'?d? row A.D. othonotary So Answers: R. Thomas Kline 10/02/2002 SHOLLENBERGER JANUZZI By: `-Ueput ? Sheriff?' SHERIFF'S RETURN - REGULAR CASE NO: 2002-04612 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DOOLITTLE BRUCE A VS SANGREY THOMAS ET AL VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SANGREY T ANTHONY the DEFENDANT , at 1750:00 HOURS, on the 1st day of October 2002 at 19 E MAIN STREET APT 4 MECHANICSBURG, PA 17055 by handing to T ANTHONY SANGREY 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 6.00 Service 6.90 Affidavit .00 Surcharge 10.00 .00 22.90 Sworn and Subscribed to before me this ?- day of QrZjt__ .2#,).L A.D. C a ?. Q., 1 'Prothonotary, So Answers: R. Thomas Kline 10/02/2002 SHOLLENBERGER JANUZZI By: Yez,- ?Deputy Sheriff STEPHEN L. BANKO, JR., ESQUIRE Pa. Supreme Court I. D. No. 41727 MARGOLIS EDELSTEIN P.O. Box 932 Harrisburg, PA 17108-0932 3510 Trindle Road Camp Hill, PA 17011 Telephone: (717) 975-8114 FAX: (717) 975-8124 Attorney for Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRUCE A. DOOLITTLE, V. Plaintiff THOMAS SANGREY and AIMEE SANGREY, husband and wife,: and T. ANTHONY SANGREY, Defendants NO. 02-4612 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Bruce A. Doolittle, Plaintiff C/o Karl J. Januzzi, Esquire Shollenberger & Januzzi, LLP 1820 Linglestown Road P. 0. Box 60545 Harrisburg, PA 17106-0545 Attorney for Plaintiff You are hereby notified to file a written response to the enclosed New Matter within twenty (20) days from service hereof or a default judgment may be entered against you. S EDELSTEIN Date: October l , 2002 By: Ste e L. Banko, Jr. Attorney I.D. No. 41727 P. 0. Box 932 Harrisburg, PA 17108-0932 3510 Trindle Road Camp Hill, PA 17011 (717) 975-8114 Counsel for Defendants STEPHEN L. BANKO, JR., ESQUIRE Pa. Supreme Court I. D. No. 41727 MARGOLIS EDELSTEIN P.O. Box 932 Harrisburg, PA 17108-0932 3510 Trindle Road Camp Hill, PA 17011 Telephone: (717) 975-8114 FAX: (717) 975-8124 Attorney for Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRUCE A. DOOLITTLE, Plaintiff NO. 02-4612 CIVIL TERM V. THOMAS SANGREY and AIMEE SANGREY, husband and wife,: and T. ANTHONY SANGREY, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED ANSWER AND NEW MATTER OF DEFENDANTS TO_ PLAINTIFF'S COMPLAINT 1. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph and, therefore, they are denied. 2. Admitted. 3. Admitted. 4. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph and, therefore, they are denied. 5. Admitted. 6. Admitted in part and denied in part. While it is admitted that Plaintiff alleges that he fell from a landing outside a second story apartment, as to whether he, in fact, fell from the place he alleges, what caused the fall, if any, whether the railing collapsed in such an incident and the distance that he fell, after reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of the averments and, therefore, they are denied. 7. Denied. The allegations contained in this paragraph state a legal conclusion to which no response is necessary. 8. a.-f. Denied. The allegations contained in this paragraph state a legal conclusion to which no response is necessary. 9. Denied. The allegations contained in this paragraph state a legal conclusion to which no response is necessary. 10. a.-g. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph and, therefore, they are denied. 11. Denied. The answer contained in paragraphs 9 and 10 hereof are incorporated herein by reference as if set forth in their entirety. 12. Denied. The answer contained in paragraphs 9 and 10 hereof are incorporated herein by reference as if set forth in their entirety. 2 13. Denied. The answer contained in paragraphs 9 and 10 hereof are incorporated herein by reference as if set forth in their entirety. 14. Denied. The answer contained in paragraphs 9 and 10 hereof are incorporated herein by reference as if set forth in their entirety. 15-16. The copy of Plaintiff's Complaint which was served upon Defendants did not contain paragraphs numbered 15 or 16. 17. Upon an agreement of counsel, this paragraph of Plaintiff's Complaint has been withdrawn and no answer on the part of Defendants is required. WHEREFORE, Defendants, Thomas Sangrey and Aimee Sangrey, husband and wife, and T. Anthony Sangrey, demand judgment in their favor and against Plaintiff. NEW MATTER 18. The answers contained in paragraphs 1 through 17 hereof are incorporated herein by reference as if set forth in their entirety. 19. To the extent that Plaintiff was injured, he assumed the risk of his own injury as set forth in paragraph 8 of his Complaint. Plaintiff alleges that there was a "obvious dangerous condition" which caused his fall. Without admitting the truth or falsity of that allegation, however, if the condition was, in 3 fact, "obvious and dangerous," Plaintiff assumed the risk of his own injury by engaging in the conduct set forth in paragraph 6 of his Complaint. 20. As set forth in paragraph 19 hereof, Plaintiff was contributorily negligent and such negligence outweighs any wrongful conduct on the part of the Defendants, any negligence on the part of Defendants being expressly denied. WHEREFORE, Defendants, Thomas Sangrey and Aimee Sangrey, husband and wife, and T. Anthony Sangrey, demand judgment in their favor and against Plaintiff. MARGOLIS EDELSTEIN Date: October , 2002 By: u, JStP n L. Banko, Jr. ey I.D. No. 41727 Box 932 Harrisburg, PA 17108-0932 3510 Trindle Road Camp Hill, PA 17011 (717) 975-8114 (717) 975-8124 FAX Counsel for Defendants 4 VERIFICATION We, THOMAS SANGREY and AIMEE SANGREY, state that we have read the foregoing document; and that the facts stated therein are true and correct to the best of our knowledge, information and belief. We understand that any false statements herein are made subject to penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: Date: THOMAS SAIMEE SANGREY Answer and New Matter/28150.4-00012 VERIFICATION I, T. ANTHONY SANGREY, state that I have read the foregoing document; and that the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: ?- -? Answer and New Matter/28150.4-00012 ERTIFICATE OF I hereby certify that the fore I served a t going on all counsel rue and correct co United of record b PY of postage Prepaid es mail at Camp Hill, Pennsylvania pcing the same in the , on the first-class addressed ? day of as follows; 2002 ' and Karl J. Januzzi, Esquire Shollenberger & Januzzi, 1820 Linglestown Road LLP P. 0. BOX Harrisburg, PA g, PA 17106-0545 (Attorney for Plaintiff) Secretary r, : _? n r' ,1? .'' ._; , -` ' - ? .? ? ?:: ?? ?:- .,, - . _.; .. . _- ; ., :_? "_, : :? ? ;? SHOLLENBERGER & JANUZZI, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 Attorneys for Plaintiff BRUCE A. DOOLITTLE Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA THOMAS SANGREY and AIMEE SANGREY, husband and wife, and T ANTHONY SANGREY, Defendants NO. 4612-CV-2002-CV CIVIL ACTION - LAW JURY TRIAL DEMANDED AND NOW comes the Plaintiff, BRUCE A. DOOLITTLE, by and through HIS attorneys, SHOLLENBERGER & JANUZZI, LLP, and respectfully answers the Defendant's New Matter as follows: 19-20. The allegations set forth in Paragraphs 19-20 of the Defendant's New Matter are conclusions of law which require no responsive pleading. By way of further answer, all allegations set forth in the above referenced paragraphs are hereby denied. WHEREFORE, Plaintiff, BRUCE A. DOOLITTLE, respectfully request your Honorable Court strike Defendant's New Matter, and enter judgment in Plaintiffs favor. Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP By: J. anuzzi, Esq. n y I.D. #65575 Date: ,oII??o-s. SHOLLENBERGER & JANUZZI, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 Attorneys for Plaintiff BRUCE A. DOOLITTLE Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. THOMAS SANGREY and AIMEE SANGREY, husband and wife, and T. ANTHONY SANGREY, Defendants NO. 4612-CV-2002-CV CIVIL ACTION - LAW JURY TRIAL DEMANDED Certificate of Service AND NOW this 17th day of October, 2002 1 hereby certify that I have served the following Answer to Defendant's New Matter on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Stephen L. Banko, Jr., Esq. MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17011 Respectfully submitted, SHOLLEIXBERGER & JANUZZI, LLP By: J. inuzzi, Esq. I.D. #65575 Dated: AL Li-, 2002 n C) (-; D =c SHOLLENBERGER & JANUZZI, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 Attornevs for Plaintiff BRUCE A. DOOLITTLE, Plaintiff V. THOMAS SANGREY and AIMEE SANGREY, husband and wife, and T ANTHONY SANGREY, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 4612-CV-2002-CV CIVIL ACTION - LAW JURY TRIAL DEMANDED STIPULATION AND NOW, this / 3/17 day of December, 2002, the parties, by their counsels, do stipulate and agree as follows: 1. Plaintiff, Bruce A. Doolittle, amends his Complaint as follows: The Plaintiff, BRUCE A. DOOLITTLE, is an adult individual who currently resides at 136 Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania. 2. It shall not be necessary for the Plaintiffs to file an Amended Complaint. 3. It shall not be necessary for Defendant to answer said additional averment and said averment is deemed to be denied. 4. The averment contained in this Stipulation shall constitute the averment that would have been filed as part of an Amended Complaint. 5. This Stipulation shall be filed as of record. SHOLLENBERGER & JANUZZI, LLP WA,,, sr I Karl J anuzzi, Esquire Attorney ID. #65575 Date: C'!o6 oy OLIS EDELSTEIN Steven L. BanlO Jr., Esquire Attorney ID. #(r}e I 1 ^77.`7 Date: 1-) 131 b2' SHOLLENBERGER & JANUZZI, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 Attorneys for Plaintiff BRUCE A. DOOLITTLE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. THOMAS SANGREY and AIMEE SANGREY, husband and wife, and T ANTHONY SANGREY, Defendants NO. 4612-CV-2002-CV CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW this 17th day of December, 2002 1 hereby certify that I have served the Stipulation to the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Stephen L. Bank, Jr., Esq. Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP By: K Januzzi, Esq. Atto ey I.D. #65575 Dated: December 17, 2002 C> c3 r3 ? r f ' ?-7 G: GD SHOLLENBERGER & JANUZZI, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 Attorneys for Plaintiff BRUCE A. DOOLITTLE, Plaintiff V. THOMAS SANGREY and AIMEE SANGREY, husband and wife, and T. ANTHONY SANGREY, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 4612-CV-2002-CV CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW this 7" day of January, 2003 1 hereby certify that I have served Plaintiff's Answers to Defendants' First Request for Production of Documents and Plaintiff's Answers to Interrogatories of the Defendants to the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Stephen L. Banko, Jr., Esq. Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP By: Karl J. J nuzzi, Esq. Attorney I.D. #65575 Dated: January 7, 2003 n _.Y r .. - C Co ? 2 { Z :: Keystone Metal Building Services, Inc., : Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4912 V. FTF Construction, Inc., Defendant CIVIL ACTION - LAW PRAECIPE TO MARK PRAECIPE FOR WRIT OF EXECUTION WITHDRAWN TO THE PROTHONOTARY: Please mark the Praecipe for Writ of Execution filed with your office on February 13, 2003 withdrawn. Writ of Execution documents were sent to the Lancaster County Sheriffs Office on March 4, 2003, and are being returned to Plaintiffs counsel due to an error. Said Writ of Execution documents were never filed or acted upon by the Lancaster County Sheriff. Date: ?' ? 03 SAIDIS, SHUFF, FLOWER & LINDSAY By: Jacl n 41Ct.I.D. Esquire Sup e # 90166 26 West High Street Carlisle, PA 17013 (717).243-6222 Attorney for Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street Carlisle, PA Keystone Metal Building IN THE COURT OF COMMON PLEAS Services, Inc., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 02-4912 V. FTF Construction, Inc., CIVIL ACTION - LAW Defendant CERTIFICATE OF SERVICE On this day of March, 2003, 1 hereby certify that I served a true and correct copy of the foregoing Praecipe to Mark Praecipe for Writ of Execution Withdrawn, upon all parties of record via United States mail, postage prepaid, addressed as follows: Jere L. Thome, Vice President 2271 Ridge Road Elizabethtown, PA 17022 r DATED: '_ 5' O J iclyn . Smith SAIDIS SNUFF, FLOWER & LINDSAY AMMYS•AM AW 26 W. High Street Carlisle, PA n Cnp Ott,,.` N = t:' ?` o .f;? SHOLLENBERGER & JANUZZI, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 Attorneys for Plaintiff BRUCE DOOLITTLE, Plaintiffs V. THOMAS SANGREY and AIMEE SANGREY, husband and wife, and T ANTHONY SANGREY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 4612-CV-2002-CV CIVIL ACTION - LAW JURY TRIAL DEMANDED Certificate of Service AND NOW this 27th day of March, 2003 1 hereby certify that I have served the Plaintiffs Interrogatories Propounded to Defendant (T. Anthony Sangrey) - Set One, and Plaintiffs Request for Production of Documents on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Stephen L. Banko, Jr., Esq. Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 Respectfully submitted, SHOLLENBERGER„& JANUZZI, LLP By: Karl k- J , uzN, Esq. Attorney I.D. #65575 Dated: March 27, 2003 (" t r =- f Il SHOLLENBERGER & JANUZZI, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 Attorneys for Plaintiff BRUCE DOOLITTLE, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. THOMAS SANGREY and AIMEE SANGREY, husband and wife, and T. ANTHONY SANGREY, Defendant NO. 4612-CV-2002-CV CIVIL ACTION - LAW JURY TRIAL DEMANDED Certificate of Service AND NOW this 27th day of March, 2003 1 hereby certify that I have served the Plaintiff's Interrogatories Propounded to Defendant (Thomas and Aimee Sangrey) - Set One, and Plaintiffs Request for Production of Documents on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Stephen L. Banko, Jr., Esq. Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 Respectfully submitted, SHOLLE ERGER & JANUZZI, LLP By: K if. Januzzi, Esq. Attorney I.D. #65575 Dated: March 27, 2003 fTi { In. 7 l ;' = -i t13 "C SHOLLENBERGER & JANUZZI, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 BRUCE A. DOOLITTLE Plaintiff V. THOMAS SANGREY and AIMEE SANGREY, husband and wife, and T. ANTHONY SANGREY, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 4612-CV-2002-CV CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO TAKE DEPOSITION TO: Stephen L. Banko, Jr., Esq Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 PLEASE TAKE NOTICE that pursuant to Pennsylvania Rules of Civil Procedure No. 4007, counsel for the Plaintiff, Bruce A. Doolittle will take the deposition of T. Anthony Sangrey for the purpose of discovery and for use as evidence in the above action or for both purposes before a Notary Public of the Commonwealth of Pennsylvania at the offices of Shollenberger & Januzzi, LLP, 1820 Linglestown Road, Harrisburg, PA 17110 at 12:00 p.m. on Thursday, July 10, 2003, or before some other officer authorized to take depositions on all matters, not privileged, which are relevant and material to the issues and the subject matter involved in the pending action and that the said T. Anthony Sangrey is required to appear at the aforesaid time at the above address and submit to such examination before said Notary Public. Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP Attornevs for Plaintiff By: JlJanuzzi, Esq. •nev I. D. No. 65575 Date: May 16, 2003 i' ?? 1 SHOLLENBERGER & JANUZZI, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 Attorneys for Plaintiffs BRUCE A. DOOLITTLE Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. THOMAS SANGREY and AIMEE SANGREY, husband and wife, and T ANTHONY SANGREY, Defendants NO. 4612-CV-2002-CV CIVIL ACTION - LAW JURY TRIAL DEMANDED Certificate of Service AND NOW this 16th of May, 2003, 1 hereby certify that I have served the following NOTICE TO TAKE ORAL DEPOSITION on the following by forwarding a true and correct copy of same in the United States mail, postage prepaid, addressed to: Stephen L. Banko, Jr., Esq Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP By: _ 4 arl J. Januzzi, Esq. Attorney I.D. #65575 Dated: May 16, 2003 n c.,a " r k SHOLLENBERGER & JANUZZI, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 BRUCE A. DOOLITTLE Plaintiff V. THOMAS SANGREY and AIMEE SANGREY, husband and wife, and T ANTHONY SANGREY, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 4612-CV-2002-CV CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO TAKE DEPOSITION TO: Stephen L. Banko, Jr., Esq Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 PLEASE TAKE NOTICE that pursuant to Pennsylvania Rules of Civil Procedure No. 4007, counsel for the Plaintiff, Bruce A. Doolittle will take the deposition of Thomas Sangrey for the purpose of discovery and for use as evidence in the above action or for both purposes before a Notary Public of the Commonwealth of Pennsylvania at the offices of Shollenberger & Januzzi, LLP, 1820 Linglestown Road, Harrisburg, PA 17110 at 11:00 a.m. on Thursday, July 10, 2003, or before some other officer authorized to take depositions on all matters, not privileged, which are relevant and material to the issues and the subject matter involved in the pending action and that the said Thomas Sangrey is required to appear at the aforesaid time at the above address and submit to such examination before said Notary Public. Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP Attorneys for Plaintiff By: J fanuzzi, Esq. 'n y I. D. No. 65575 Date: May 16, 2003 SHOLLENBERGER & JANUZZI, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 Attorneys for Plaintiffs BRUCE A. DOOLITTLE Plaintiff V. THOMAS SANGREY and AIMEE SANGREY, husband and wife, and T. ANTHONY SANGREY, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 4612-CV-2002-CV CIVIL ACTION - LAW JURY TRIAL DEMANDED Certificate of Service AND NOW this 16th of May, 2003, 1 hereby certify that I have served the following NOTICE TO TAKE ORAL DEPOSITION on the following by forwarding a true and correct copy of same in the United States mail, postage prepaid, addressed to: Stephen L. Banko, Jr., Esq Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP By: kljk- f<arl'J. Januzzi, Esq. Attorney I.D. #65575 Dated: May 16, 2003 C -0:[-' ?r Iii C CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS BRUCE A. DOOLITTLE TERM, -VS- CASE NO: 02-4612 THOMAS SANGREY AND AIMEE SANGREY, ET AL. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 08/13/2003 AS on b elf f "?\QY} ^? I. BJR. , S Attorney for DEFENDANT DE11-438325 0 S 2? 1- L 0 1 COMMONWEAL T H OF P E NN S Y L VAN 2 A COUNT-Sr OF CUMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS BRUCE A. DOOLITTLE -VS- THOMAS SANGREY AND AIMEE SANGREY, ET AL. OF A TO LEBANON VALLEY FAMILY MEDICAL MEDICAL RECORDS FAMILY MEDICAL CTR./CAMP HILL MEDICAL RECORDS DR. OSTDAHL MEDICAL RECORDS ORTHO. INSTITUTE OF PA MEDICAL RECORDS POLYCLINIC HOSPITAL MEDICAL RECORDS CHRISTOPHER ROYER, M.D. MEDICAL RECORDS TERM, CASE NO: 02-4612 TO: KARL J. JANUZZI, ESQ. MCS on behalf of STEPHEN L. BANKO JR., ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/24/2003 MCS on behalf of STEPHEN L. BANKO JR., ESQ. Attorney for DEFENDANT CC: STEPHEN L. BANKO JR., ESQ. - 28150.4-00012 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA,19103 (215) 246-0900 DE02-236487 052:S 1- C O 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BRUCE DOOLITTLE VS THOMAS SANGREY 6 AIDE SANGREY, ET AL File No. 02-4612 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: LEBANON VALLEY FAMILY MEDICINE (Name of Person or Entity) Within twenty (20) days after service of this things: at MCS GROUP INC., 1601 MARKET ST., 1800, PHILA.,PA 19103 (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: STEPHEN BANKO ESO ADDRESS: 3510 TRINDLE RD. ou are ordered by the court to produce the following documents or ATTACHED CAMP HILL PA 17011 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT BYT ('OU T: DATE: JJ Prothonotary/Clerk, ivi D' DePt Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: LEBANON VALLEY FAMILY MEDICAL 1400 S. FORGE RD. SUITE-1 PALMYRA, PA 17078 RE: 5231 BRUCE ALLEN DOOLITTLE Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : BRUCE ALLEN DOOLITTLE 136 BOSLER AVE., LEMOYNE, PA 17043 Social Security #: 521-68-2578 Date of Birth: 05-19-1947 SU10-455896 0 5 2 3 1- L 0 3. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS BRUCE A. DOOLITTLE TERM, -VS - CASE NO: 02-4612 THOMAS SANGREY AND AIMEE SANGREY, ET AL. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 08/13/2003 STEPHEN L. BANKO JR., ESQ. Attorney for DEFENDANT DE11-438326 O S 2 3 1- L 02 C O M M O N W E AL T H OF P E NN S Y L VAN 2 A COUNTY OF CUMBER LAN D IN THE MATTER OF: BRUCE A. DOOLITTLE -VS- THOMAS SANGREY AND AIMEE SANGREY, ET AL. A LEBANON VALLEY FAMILY MEDICAL MEDICAL RECORDS FAMILY MEDICAL CTR./CAMP HILL MEDICAL RECORDS DR. OSTDAHL MEDICAL RECORDS ORTHO. INSTITUTE OF PA MEDICAL RECORDS POLYCLINIC HOSPITAL MEDICAL RECORDS CHRISTOPHER ROYER, M.D. MEDICAL RECORDS COURT OF COMMON PLEAS TERM, CASE NO: 02-4612 TO: KARL J. JANUZZI, ESQ. MCS on behalf of STEPHEN L. BANKO JR., ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of ;record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/24/2003 CC: STEPHEN L. BANKO JR., ESQ. - 28150.4-00012 Any questions regarding this matter, contact MCS on behalf of STEPHEN L. BANKO JR., ESQ. Attorney for DEFENDANT THE MCS GROUP INC. ,1601 MARKET STREIET #800 PHILADELPHIA, PA 19103 (215) 246-0900 IDE02-236467 0 5 2 3 1- C O 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BRUCE DOOLITTLE VS File No. 02-4612 THOMAS SANGREY 6 AIMEE SANGREY, ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: FAMILY MEDICINE C UER OF CAMP HILL (Name of Person or Entity) Within twenty (20) days after service of this by the court to produce the following documents or ''-5.. at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (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: STEPHEN BANKO, JR., E ADDRESS: 3510 TRINDLE RD. CAMP HILL PA 17011 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT DATE: ^? n/ Prothonotary/Cl?errkc iiision Deput Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: FAMILY MEDICAL CTR./CAMP HILL 4076 MARKET STREET CAMP HILL, PA 17011 RE: 5231 BRUCE ALLEN DOOLITTLE Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject :BRUCE ALLEN DOOLITTLE 136 BOSLER AVE., LEMOYNE, PA 17043 Social Security #: 521-68-2578 Date of Birth: 05-19-1947 SU10-455898 0 5 2 3 1- L 02 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS BRUCE A. DOOLITTLE TERM, -VS- CASE NO: 02-4612 THOMAS SANGREY AND AIMEE SANGREY, ET AL. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO JR.., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 08%13/2003 STEPHEN L. BANKO JR., ESQ. Attorney for DEFENDANT DE11-438327 05233--L 03 C O M M O N W E AL T H OF P E NN S Y L VAN 2 A COUNTY OF CUMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS BRUCE A. DOOLITTLE -vs- THOMAS SANGREY AND AIMEE SANGREY, ET AL. LEBANON VALLEY FAMILY MEDICAL MEDICAL RECORDS FAMILY MEDICAL CTR./CAMP HILL MEDICAL RECORDS DR. OSTDAHL MEDICAL RECORDS ORTHO. INSTITUTE OF PA MEDICAL RECORDS POLYCLINIC HOSPITAL MEDICAL RECORDS CHRISTOPHER ROYER, M.D. MEDICAL RECORDS TERM, CASE NO: 02-4612 TO: KARL J. JANUZZI, ESQ. MCS on behalf of STEPHEN L. BANRO JR., ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/24/2OD3 CC: STEPHEN L. BANKO JR., ESQ. - 28150.4-00012 Any questions regarding this matter, contact MCS on behalf of STEPHEN L. BANKO JR., ESQ. Attorney for DEF ANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA,' 19103 (215) 246-0900 1OH02-236487 0 5 2 1- C O 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BRUCE DOOLITTLE VS File No. THOMAS SANGREY ?ti AIMLE SANGREY, ET AL 02-4612 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: ROGER OSTDAHL, M.D. (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 SEE ATTACHED things: at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 1 (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: STEPHEN BANKO, JR. ADDRESS: 3510 TRINDLE RD. CAMP HILL PA 17011 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT B HE COU DATE: Prothonotary/Clerk cil Division D urv Seal of the Court (Ef f. 7 / 97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. OSTDAHL 920 CENTURY DRIVE MECHANICSBURG, PA 17011 RE: 5231 BRUCE ALLEN DOOLITTLE Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : BRUCE ALLEN DOOLITTLE 136 BOSLER AVE., LEMOYNE, PA 17043 Social Security #: 521-68-2578 Date of Birth: 05-19-1947 SU10-455900 0 523 1- L 03 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS BRUCE A. DOOLITTLE TERM, -VS- CASE NO: 02-4612 THOMAS SANGREY AND AIMEE SANGREY, ET AL. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 08/13/2003 STEPHEN L. BANKO JR., ESQ. Attorney for DEFENDANT DE11-438328 0523a--T,04 C O M M O NW E A L T H OP COUNTY o pi IN THE MATTER OF: BRUCE A. DOOLITTLE -VS THOMAS SANGREY AND AIMEE SANGREY, ET AL. TO LEBANON VALLEY FAMILY MEDICAL MEDICAL RECORDS FAMILY MEDICAL CTR./CAMP HILL MEDICAL RECORDS DR. OSTDAHL MEDICAL RECORDS ORTHO. INSTITUTE OF PA MEDICAL RECORDS POLYCLINIC HOSPITAL MEDICAL RECORDS CHRISTOPHER ROYER, M.D. MEDICAL RECORDS COURT OF COMMON PLEAS TERM, CASE NO: 02-4612 TO: KARL J. JANUZZI, ESQ. MCS on behalf of STEPHEN L. BANKO JR., ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/24/2003 CC: STEPHEN L. BANKO JR., ESQ. - 28150.4-00012 Any questions regarding this matter, contact P E NN S Y L VAN S.A C U M B E R. LAN D MCS on behalf of STEPHEN L. AN0 Attorney fo , ESQ. EFHE V THE MCS GROUP INC,. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-236487 0 5 2 3 1- C O 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BRUCE DOOLITTLE VS File No. THOMAS SANGREY & AIME SANGREY, ET AL 02-4612 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: ORTHOPEDIC INSTITUTE. OF 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: SEE ATTACHED at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (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: STEPHEN BANRO, JR. ADDRESS: 3510 TRINDLE RD. CAMP HILL PA 17011 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT BY E C?URF? C JJ y Prothonotary/Clerk, Ddtsion DATE: ? f2 - e } •? /011J De[ute Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ORTHO. INSTITUTE OF PA 875 POPLAR CHURCH ROAD CAMP HILL, PA 17011 RE: 5231 BRUCE ALLEN DOOLITTLE Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : BRUCE ALLEN DOOLITTLE 136 BOSLER AVE., LEMOYNE, PA 17043 Social Security #: 521-68-2578 Date of Birth: 05-19-1947 3U10-455902 0 5 2 3 1- L 04 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS BRUCE A. DOOLITTLE TERM, -VS- CASE NO: 02-4612 THOMAS SANGREY AND AIMEE SANGREY, ET AL. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 08/13/2003 STEPHEN L. BANKO JR., ESQ. Attorney for DEFENDANT DEll-438329 0 5 2 3 1- L O S COMMONWEALTH OF PE1'ZNS'YLVAN211- COUNTY OF CUMBER LAND IN THE MATTER OF: COURT OF COMMON PLEAS BRUCE A. DOOLITTLE -VS- THOMAS SANGREY AND AIMEE SANGREY, ET At. LEBANON VALLEY FAMILY MEDICAL MEDICAL RECORDS FAMILY MEDICAL CTR./CAMP HILL MEDICAL RECORDS DR. OSTDAHL MEDICAL RECORDS ORTHO. INSTITUTE OF PA MEDICAL RECORDS POLYCLINIC HOSPITAL MEDICAL RECORDS CHRISTOPHER ROYER, M.D. MEDICAL RECORDS TERM, CASE NO: 02-4612 TO: KARL J. JANUZZI, ESQ. MCS on behalf of STEPHEN L. BANKO JR., ESQ. intends to serve a subpoena identical to the one that is attached to this notice.. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/24/2003 CC: STEPHEN L. BANKO JR., ESQ. - 28150.4-00012 Any questions regarding this matter, contact MCS on behalf of STEPHEN L. BANRO JR., ESQ. Attorney for DEF NDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-236487 0 5 2 3 1- C O 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BRUCE DOOLITTLE VS File No. THOMAS SANGREY 6 AIMEE SANGREY, ET AL 02-4612 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: POLYCLINIC HOSPITAL (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 SEE ATTACHED things: at MCS GROUP INC., 1601 MARKET ST., 1500, PHILA.,PA 1 (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: STEPHEN BANKO, JR., E ADDRESS: 3510 TRINDLE RD. CAMP HILL PA 17011 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT DATE: ?[ C Lam/ ?7 Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: POLYCLINIC HOSPITAL PINNACLE HEALTH SYSTEM 2601 N. 3RD STREET HARRISBURG, PA 17105 RE: 5231 BRUCE ALLEN DOOLITTLE Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, tests, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : BRUCE ALLEN DOOLITTLE 136 BOSLER AVE., LEMOYNE, PA 17043 Social Security #: 521-68-2578 Date of Birth: 05-19-1947 SU10-455904 0 5 2 3 1- L 0 S CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: BRUCE A. DOOLITTLE _VS_ THOMAS SANGREY AND AIMEE SANGREY, ET AL. COURT OF COMMON PLEAS TERM, CASE NO: 02-4612 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 08/13/2003 STEPHEN L. BANKO JR., ESQ. Attorney for DEFENDANT DEll-438330 0 52 3 1- L O 6 C O M M O N W E AL T H OP COUNTY or IN THE MATTER OF: BRUCE A. DOOLITTLE -VS- THOMAS SANGREY AND AIMEE SANGREY, ET AL. LEBANON VALLEY FAMILY MEDICAL MEDICAL RECORDS FAMILY MEDICAL CTR./CAMP HILL MEDICAL RECORDS DR. OSTDAHL MEDICAL RECORDS ORTHO. INSTITUTE OF PA MEDICAL RECORDS POLYCLINIC HOSPITAL MEDICAL RECORDS CHRISTOPHER ROYER, M.D. MEDICAL RECORDS COURT OF COMMON PLEAS TERM, CASE NO: 02-4612 TO: KARL J. JANUZZI, ESQ. MCS on behalf of STEPHEN L. BANKO JR., ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/24/2003 CC: STEPHEN L. BANKO JR., ESQ. - 28150.4-00012 Any questions regarding this matter, contact PENNSYT,VANSA CUM 8 E R LAN D MCS on behalf of STEPHEN L. BANRO JR., ESQ. Attorney for DEFE ANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-236487 0 5 2 ?31- C O 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BRUCE DOOLITTLE VS File No. 02-4612 THOMAS SANGREY 5 AIMEE SANGREY, ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: CBRISTOPHER ROYER (Name of Person or Entity) Within twenty (20) days after service of this subpo by the court to produce the following documents or rmngs: at MCS GROUP INC., 1601 MARKET ST., #800, PBILA.,PA 19103 (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: STEPHEN BANKO JR ESO ADDRESS: 3510 TRINDLE RD. CAMP HILL PA 17011 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT DATE: I7 D.n/A BY T [E COURT* Prothonotary/Clerk, '[)beis?°^ Depute Seal of the Court (Ef f. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CHRISTOPHER ROYER, M.D. PRISM-NEURO PSYCH.DEPT. 4950 WILSON LANE MECHANICSBURG, PA 17055 RE: 5231 BRUCE ALLEN DOOLITTLE Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : BRUCE ALLEN DOOLITTLE 136 BOSLER AVE., LEMOYNE, PA 17043 Social Security #: 521-68-2578 Date of Birth: 05-19-1947 SU10-455906 0 5 2 3 1- L 0 6 c? r_. '? '; T rn?` 5 L?i'.. ? ?,_ ?.?'.. ??.. G.,: ?`fi ?`L_ .. j ?? [:"" -< CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS BRUCE A. DOOLITTLE TERM, _VS_ THOMAS SANGREY AND AIMEE SANGREY, ET AL CASE NO: 02-4612 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS kl h / 7 DATE: 11/04/2003 E NKO J' , A Attor for DEFE A DE11-455154 05237.-L01 COMMONWEALTH OF P E NN S Y L VAN 2 A COUNTY OF CUMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS BRUCE A. DOOLITTLE -VS- THOMAS SANGREY AND:AIMEE SANGREY, ET AL NOTICE OF ]NPEIT TO SERVE A SUBPOENA T THINGS FOR DISCOVERY PURSUANT THERAPIES UNLIMITED MEDICAL RECORDS TO: KARL J. JANUZZA, ESQ. TERM, CASE NO: 02-4612 MCS on behalf of S EPHEN L: BANKO JR., ESQ. intends to serve a subpoena identical to the o e that is attached to this notice. You have twenty (20) days from the date.listed below in which to file of record and serve upon the undersigned an objdction to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reprdduced records may be ordered at your expense by completing the attached counsk card and returning same to MCS or by contacting our local MCS office. DATE: 10/15/2003 MCS on behalf of PEEN L. BANKO JR., orney for DEFENDANT CC: STEPHEN L. BANKO JR., ESQ. - 28150.4-00012 Any questions regariding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-244834 05233--CO: COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BRUCE A. DOOLITTLE File No. 02-4612 VS. THOMAS SANGREY AND AIMEE SANGREY, ET AL TO: Custodian of Within twenty (20) days after documents or things: **** at of this subpoena, you are ordered by the court to produce the following You may deliver or mail legible copies of the documents or produce things requested by this subpoena, tog with the certificate of compliance, to the party making this request at the address listed above. You have the 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 the party serving this subpoenla may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: STEPHEN L BANKO JR. ADDRESS: 3510 TRiND .F. RD. TELEPHONE: (215) 246-09W SUPREME COURT ID #: ATTORNEY FOR: Defe dant m:'i Q Ik 2$03 Date: Q _ T Seal of the Court BY THE COURT: LZZ? ?? Prothonotary/Clerk, Civil Divis' 05231-0? (Name of Person or Entity) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BRUCE A. DOOLITTLE vs. File No. 02-4612 THOMAS SANGREY AND AIMEE SANGREY, ET AL TO: Custodian of (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things:_ **** SEE ATTA H D RIDR **** at You may deliver or mail legible copies of the documents or produce things requested by this subpoena, tog with the certificate of compliapce, to the party making this request at the address listed above. You have the 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 sej 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: TEP W L {O J ADDRESS: 3510 TRTNDt RD 7011 TELEPHONE: (y)?) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Qefenaant Q 4 200 Date: CC+ 9? Seal of the Court BY Deputy COURT: Civil 05231-07 1 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: THERAPIES UNLIMITED 2151 LINGLESTOWN ROAD SUITE 140 HARRISBURG, PA 17110 RE: 5231 BRUCE ALLEN DOOLITTLE Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, incl ding any and all such items as may be stored in a computer database or o rwtse in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up t and including the present. Subject : BRUCE ALL N DOOLITTLE 136 BOSLER AVE., LEMOYNE, PA 17043 Social Security #: 521-6 -2578 Date of Birth: 05-19-19 7 SU10-468994 0 S 2 3 1- L O -? ^ l'J T T ? _ L n, J cal` ? G4 „! > D J f71 `J NO 7 C,) SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attornevs for Plaintiff BRUCE A. DOOLITTLE, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 4612-CV-2002-CV THOMAS SANGREY and AIMEE SANGREY, husband and wife, and T. CIVIL ACTION - LAW ANTHONY SANGREY, JURY TRIAL DEMANDED Defendants 'PRAECI PE FOR CHANGE OF ADDRESS OF COUNSEL FOR PLAINTIFF TO THE PROTHONOTARY: Please be advised that the address of the undersigned counsel has changed to the following: Karl J. Januzzi, Esq. Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 (717) 728-3200 FAX: (717) 728-3400 Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP By: arl J. Janu i, Esq. I.D. # 65575 Date: November 24, 2004 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff BRUCE A. DOOLITTLE, Plaintiff V. THOMAS SANGREY and AIMEE SANGREY, husband and wife, and T ANTHONY SANGREY, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 4612-CV-2002-CV CIVIL ACTION - LAND JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW this 24 day of November, 2004 1 hereby certify that I have served the Praecipe for Change of Address of Counsel for Plaintiff to the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Stephen L. Banko, Jr., Esq. Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP ( By: Karl J. Januzzi, sq. Attorney I.D. #65575 Dated: November 24, 2004 t7 r rTl T 4 ?. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS BRUCE A. DOOLITTLE TERM, -VS- CASE NO: 02-4612 THOMAS SANGREY AND AIMEE SANGREY, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 07/05/2005 MCS n be alf of ? V o 7 ? P L. ANKO ? U Attorney for DEFENDANT DE11-569890 0 5 2 3 1- 1,0 8 C O M M O NW E A 11`1711 OP P E NN S Y'L VAN 2 A COUNTY OP CUMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS BRUCE A. DOOLITTLE -VS- THOMAS SANGREY AND AIMEE SANGREY, ET AL NOTICE OF INTENT TO SERVE A SUBPOENA 7 THINGS FOR DISCOVERY PURSUANT PINNACLE HLTH/HARRISBURG HOSP. MEDICAL RECORDS PINNACLE HLTH/HARRISBURG HOSP. X-RAY ONLY TERM, CASE NO: 02-4612 TO: KARL JANUZZI, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN L. BANKO JR., ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made,-then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 06/13/2005 CC: STEPHEN L. BANRO JR., ESQ. - 28150.4-00012 Any questions regarding this matter, contact MCS on behalf of STEPHEN L. BANRO JR., ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-303272 0 5 2 3 1- C O 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BRUCE A. DOOLITTLE vs. File No. 02-4612 THOMAS SANGREY AND AIMEE SANGREY, ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PINNACLE HLTH/HARRISBURG HOSp (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER**** at The M CS Group- Inc.. 1601 Market Street, Suit 800 Philadelphia PA 1911)3 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: STEPHEN L. BANKO JR.. ESO. ADDRESS: 3510 TRINDLF RD, CAMP HILL _ PA 17011 TELEPHONE: (15) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUL 0 5 2005 Date: J[ t?-.f tee 2669 Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil ivisi c Ad, o _Y 77 ?ClI?C3c?? eputy 05231-08 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PINNACLE HLTH/HARRISBURG HOSP. 111 SOUTH FRONT STREET HARRISBURG, PA 17101 RE: 5231 BRUCE ALLEN DOOLITTLE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. RECORDS FOR 6/27/01 ADMISSION ONLY ADMISSION ACCOUNT N 210356951 Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. - Entire hospital medical file, including but not limited to any and all :records, correspondence to and from the consulting and/or treating physician„ files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : BRUCE ALLEN DOOLITTLE 136 BOSLER AVE., LEMOYNE, PA 17043 Social Security N: 521-68-2578 Date of Birth: 05-19-1947 SU10-568710 0 5 2 3 1- L O 8 I CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS BRUCE A. DOOLITTLE TERM, -VS- THOMAS SANGREY AND AIMEE SANGREY, ET AL CASE NO: 02-4612 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/05/2005 STEPHEN L. BANKO JR., ESQ. Attorney for DEFENDANT DE11-569891 05231-11,09 C O M M O N W E A L 117H OP P E NN S Y L VAN 2 A COUNTY O EP CUMBER LAN D IN THE MATTER OF: BRUCE A. DOOLITTLE -VS- THOMAS SANGREY AND AIMEE SANGREY, ET AL A SUBPOENA PINNACLE HLTH/HARRISBURG HOSP. MEDICAL RECORDS PINNACLE HLTH/HARRISBURG HOSP. X-RAY ONLY COURT OF COMMON PLEAS TERM, CASE NO: 02-4612 TO: KARL JANUZZI, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN L. BANKO JR., ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made,-then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 06/13/2005 CC: STEPHEN L. BANRO JR., ESQ. - 28150.4-00012 Any questions regarding this matter, contact MCS on behalf of STEPHEN L. BANKO JR., ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-303272 0 52 3 1-C0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BRUCE A. DOOLITTLE VS. File No. _ 02-4612 THOMAS SANGREY AND AIMEE SANGREY, ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PINNACLE HLTH/HARRISBURG HOSE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER**** at The M ro ro n 1601 Market Street. Suite 800 Philad lnhia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: STEPHEN L. BANKO JR.. ESQ. ADDRESS: 3510 TRINDLF RD. CAMP HILL. PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary'Clerk, JUL 0 S 2005 Date: J t wF- L ja.s, Deputy Seal of the Court 05231-09 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PINNACLE HLTH/HARRISBURG HOSP. I l l SOUTH FRONT STREET HARRISBURG, PA 17101 RE: 5231 BRUCE ALLEN DOOLITTLE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING DIAGNOSTICS FILMS. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : BRUCE ALLEN DOOLITTLE 136 BOSLER AVE., LEMOYNE, PA 17043 Social Security #: 521-68-2578 Date of Birth: 05-19-1947 SU10-568712 0 5 2 3 1- 1, 0 9 a r 2- K u 71 xa r PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: (Check one) ( XX) for JURY trial at the next term of civil court. for trial without a jury. CAPTION OF CASE (entire caption must be stated in full) (check one) BRUCE A. DOOLITTLE (X ) Civil Action - Law ( ) Appeal from Arbitration (other) (Plaintiff) VS. THOMAS SANGREY and AIMEE SANGREY, husband and wife, and T. ANTHONY SANGREY (Defendant) VS. The trial list will be called on 2/14/06 and Trials commence on 3/13/06 Pretrials will be held on 2/22/06 (Briefs are due 5 days before pretrials.) (The party listing this case for trial shall) provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214.1.) No. 02-4612 Civil x1CRxxxxxxxxxx Indicate the attorney who will try case for the party who files this praecipe: Stephen L. Banko, Jr., Esquire Margolis Edelstein, 3510 Trindle Rd., Camp Hill, PA 17011 (717)760-7501 Indicate trial counsel for other parties if known: Karl J. Januzzi, Esquire, Shollenbereer & Januzzi. 2225 Millennium Wav. Enola. PA 17025 This case is ready for trial. Signed: V ., Print Name: STEPHEN L. BANKO, JR., ESQUIRE Date: December ?3b , 2005 Attorney for: DEFENDANTS CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the foregoing on all counsel of record by placing the same in the United States mail at Clamp Hill, Pennsylvania, first-class postage prepaid, on the ?, day of 2005, and addressed as follows: Karl J. Januzzi, Esquire Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 (Counsel for Plaintiff) Barbara J. Smith N (? C? -, Y' '1l _ 1 -i T: a ?__ . __,,?`_ . "_ :ti" ?? ti ? SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff BRUCE A. DOOLITTLE, Claimant V. THOMAS SANGREY and AIMEE SANGREY, husband and wife, and T ANTHONY SANGREY, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 4612-CV-2002-CV CIVIL ACTION - LAW JURY TRIAL DEMANDED As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Plaintiff, certifies that: 1. a notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party, 2. the twenty day notice period was waived by opposing counsel (letter stating same is attached hereto, 3. a copy of the notice of intent, including the proposed subpoena, is attached to this certificate, 4. no objection to the subpoena has been received, and 5. the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. Respectfully submitted: SHOLLENBERGER & JANUZZI, LLP Attorne for laintiff By: Karl J. nuzzi, Esq. Attorney I. D. No. 65575 Attorney for Plaintiff Date: February 17, 2006 IS •2705 16:23 FR0M:SH0LLENE3ERGER87RNU2Z 728 3400 TC:0-758124 P.2'4 SHOLLENBERGER 61. JANUZZI, LLP 2225 MILLENNIUM WAY ENOLA, PA. 17025 www.sholljanlaw.wm (717) 728-3200 FAX (717) 728,3400 Ple a mply to Etola Office TIMOTHY A. SHOLLENBERGER KARL J. JANUZZI ADAM T WOLFE Writers Direct E-mail - kiina shollianlaw.com HARRISBURG OFFICE 4811 JONESTOWN RD SUITE 221 HARRISBURG, PA 17109 (Do noc send mail to this addm,) (717) 671.6400 FAX (717) 6714900 February 15, 2006 VIA FACSIMILE Stephen L Bank Margolis Edelste 3510 Trindle Roi Camp Hill, PA 1 RE: Dear Steve: Jr., Esquire 1 Enclosed ybu will find a Notice of Intent in regard to a subpoena I intend to serve in the above case. The proposed subpoena is also enclosed. Please indicate whether you would be willing to waive the 20 day notice period. If you would be willing to waive the twenty days, please sign below and fax this letter back to me as soon as possible. Thank you your attention to this matter. Very tru yours, K*IJanuzzi KJJ:hr Enclosures I, Stephen 4. Banko, Jr., Esq., hereby waive the twenty days for service of a subpoena in thelabove captioned case. f, Stephen L. Banko, Jr„ Esq. SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attornevs for Plaintiff BRUCE A. DOOLITTLE, Claimant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. THOMAS SANGREY and AIMEE SANGREY, husband and wife, and T ANTHONY SANGREY, Defendants NO. 4612-CV-2002-CV CIVIL ACTION - LAW JURY TRIAL DEMANDED To: Defendants, Thomas Sangrey, Aimee Sangrey, and T. Anthony Sangrey c/o Stephen L. Banko, Esquire Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 Plaintiff Bruce Doolittle intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Respectfully submitted: SHOLLENBERGER & JANUZZI, LLP Attorneys fRr Plaintiff By: J/?anuzzi, Esq. 10y I. D. No. 65575 -nev for Plaintiff Date: February 15 , 2006 COMMONWEALTH OF PENNSYLVANLA COUNTY OF CUMBERLAND Bruce A. Doolittle, Plaintiff File No.4612-CV-2002-3V V. Thomas Sangrey and Aimee Sangrey, husband and wife, and T. Anthony Sangrey, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Mechanicsburg Police Department (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: The citation issued by the fire marshal] to the above landlords in conjunction wtih an incident that occurred on June 27, 2001 following address: 19 E Main Street Apt 6 Merhanirahurg at 2225 MiIIennium Wa)z FnnlaT Pa t?025 (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 ADDRESS: 7991 nel i I---:.._: IV-, TELEPHONE. (717) 728-3200 SUPREME COURT rD # 65575 ATTORNEY FOR: P I a i nt i f f i Date:_ Seal of the Court BY THE COURT: Pr thonotary, Civil ivisiod Dep*, SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff BRUCE A. DOOLITTLE, Claimant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. THOMAS SANGREY and AIMEE SANGREY, husband and wife, and T. ANTHONY SANGREY, Defendants NO. 4612-CV-2002-CV CIVIL ACTION - LAW JURY TRIAL DEMANDED AND NOW this 17th day of February, 2006, 1 hereby certify that I have served the Certificate Prerequisite on the following by forwarding a true and correct copy of same in the United States mail, postage prepaid, addressed to: Stephen L. Banko, Esquire Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 By: Karl 4JJuzzzzi, Esquire .. ,; BRUCE A. DOOLITTLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW . NO. 4612-2002 CIVIL TERM THOMAS SANGREY and AIMEE : SANGREY, husband and wife: and T. ANTHONY SANGREY, . Defendants JURY TRIAL DEMANDED IN RE: PRETRIAL CONFERENCE A pretrial conference was held in the above-captioned case in the chambers of Judge Oler on Wednesday, February 22, 2006. Present on behalf of the Plaintiff was Karl J. Januzzi, Esquire. Present on behalf of the Defendants was Stephen L. Banko, Jr., Esquire. This is a negligence action for personal injuries based upon premises liability arising out of a fall from a second floor landing area of a fire escape of a building owned or managed by Defendants and partially leased to Plaintiff's daughter. Defenses include lack of negligence, contributory negligence, and assumption of the risk. This will be a jury trial in which, pursuant to an agreement of counsel, each side will have 4 peremptory challenges, for a total of 8 The estimated duration of trial is 2 days. Counsel are requested to furnish to the Court at least 5 days prior to the commencement of the trial term at which this case is tried briefs with their respective positions as to the status of the Plaintiff on the premises. In the event that counsel are able to stipulate as to the Plaintiff's status (business invitee, licensee or trespasser), it will not be necessary for briefs to be submitted on the issue. To the extent that any depositions are to be shown or read to the jury, and contain objections requiring rulings by the trial court, counsel are directed to furnish a copy of the transcript in question to the Court at least 5 days prior to the commencement of the trial term, with the areas of objection being highlighted, and with briefs indicating their positions on the objections. With respect to settlement negotiations, a more than nominal offer has been made by Defendants, but it is substantially lower than the present demand of Plaintiff. It does appear to the Court that there is a reasonable chance of settlement in this case. By the Court, Karl J. Januzzi, Esquire Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 For Plaintiff Stephen L. Banko, Esquire Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 For Defendants Court Administrator mae _, ?r _;, -; - ??,.-- C` _, Curtis R. Long Prothonotary (Office of tFje Protbonotarp CumbErrarlb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor CVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573