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Home My WebLink About01-4538IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHRYN PERROTT DONAHEY, and her husband GLENN HOWARD DONAHEY as Administrators of the Estate of JOSEPH NICHOLAS DONAHEY and KATHRYN PERROTT DONAHEY and GLENN HOWARD DONAHEY, as Individuals, Plaintiffs JAMES DOWNEY LONG, M.D.; BARBARA BRANDT; SPIRIT PHYSICIAN SERVICES, INC. d/b/a CENTER FOR WOMEN'S HEALTH AND WELLNESS; and HOLY SPIRIT HOSPITAL, a nonprofit corporation Defendants NO--CIVIL ~. CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO ISSUE WRIT OF SUMMONS TO: PROTHONOTARY OF CUMBERLAND COUNTY Kindly issue the Writ of Summons against the following named defendants: James Downy Long, M.D.; Barbara Brandt; Spirit Physician Services, Inc. d/b/a Center for Women's Health and Wellness; and Holy Spirit Hospital. Iq. JURY TRIAL DEMANDED Respectfully submitted, ECKERT SEAMANS CHERIN & MELLOTT LLC 600 Grant Street, 44~ Floor Pittsburgh, PA 15219 (412) 566-6000 Attorneys for Plaintiffs Commonwealth of Pennsylvania County of Cumberland Kathryn Perrott Donahey, and her husband Glenn Howard Donahey as Administrators of the Estate of Joseph Nicholas Donahey and Kathryn Perrott Donahey and Glenn Howard Donahey, as individuals 86 Acker Rd. Newport, PA 17074 VSo James Downey Long, M.D.; Barbara Brandt; Spirit Physician Services, Inc. d/b/a Center For Women's Health and Wellness 423 N. 21st S~. Camp Hill, PA 17011 and Holy Spirit Hospital a nonprofit corporation 503 N. 21st St. Camp Hill, PA 17011-2788 Court o£ Common Pleas No ..... _oA = _4 A3_ 8_ _ _c_i_v_i_ _l ................. 19 .... In civil Action - Law To __J~_J~Qwll~y_LDJ~g._i~,:__t~ar]A~rD~_B_~andt; Spirit PhysicianServices, Inc. d/b/a Center for Women's Health and Wellness; and Holy Spirit Hospital, a nonprofit co or ti n . . You rl2re ~ere~ nolafted that ...... -K-a-t-h--r~n-~P--e-r-r-9-t-t-~D-~--n-a-h-e-~-~9n--d~-h-e--r~-h-u-s-b--aP~~5~-~P~7~-b-~[~t~rs of the Estate of Joseph Nicholas Donahey and Kathryn Perrotf Donahey and Glenn the Pl~'[~srdhg~r%9~frten~d {t]daie~l_s_ ....... _C_J-_v_!l___A_c_t__i_°_n__z__L_a_w_ .......................... against you which you are required to defend or a default judgment may be entered against you. (SEAL) Prothonota/~, By / -- /~/Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHRYN PERROTT DONAHEY, and her Husband GLENN HOWARD DONAHEY a Administrators of the Estate of JOSEPH NICHOLAS DONAHEY and KATHRYN PERROTT DONAHEY and GLENN HOWARD DONAHEY, as Individuals, Plaintiffs, JAMES DOWNEY LONG, M.D.; BARBARA BRANDT; SPIRIT PHYSICIAN SERVICES, 1NC. d/b/a CENTER FOR WOMEN'S HEALTH AND WELLNESS and HOLY SPIRIT HOSPITAL, a nonprofit: corporation, Defendants. Civil Action - Law No. 01-4538 Civil ACCEPTANCE OF SERVICE I accept service of the Writ of Summons on behalf of James Downey Long, M.D. and certify that I am authorized to do so. Date: '~/~;D/Z ! (Defendant or Authoriz~ Agent) METRE EVANS & WOODStDE 3401 NORTH FRONT STREE7 (Mmhng Addres~ 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHRYN PERROTT DONAHEY, and her Husband GLENN HOWARD DONAHEY a Administrators of the Estate of JOSEPH NICHOLAS DONAHEY and KATHRYN PERROTT DONAHEY and GLENN HOWARD DONAHEY, as Individuals, Plaintiffs, JAMES DOWNEY LONG, M.D.; BARBARA BRANDT; SPIRIT PHYSICIAN SERVICES, INC. d/b/a CENTER FOR WOMEN'S HEALTH AND WELLNESS and HOLY SPIRIT HOSPITAL, a nonprofit: corporation, Defendants. Civil Action - Law No. 01-4538 Civil ACCEPTANCE OF SERVICE I accept service of the Writ of Summons on behalf of Spirit Physician Services, Inc. clPo/a Center for Women's Health and Wellness and certify that I am authorized to do so. Date: ? J ~/C (Defendant o~ Au{horize~,YAgent) ME~rE EVANS & WOODSIDE Pn ~OX 5950 HARRISBURG, PA 1711n-nqsfl (Mailing Address) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHRYN PERROTT DONAHEY, and her Husband GLENN HOWARD DONAHEY a Administrators of the Estate of JOSEPH NICHOLAS DONAHEY and KATHRYN PERROTT DONAHEY and GLENN HOWARD DONAHEY, as Individuals, Plaintiffs, JAMES DOWNEY LONG, M.D.; BARBARA BRANDT; SPIRIT PHYSICIAN SERVICES, INC. d/b/a CENTER FOR WOMEN'S HEALTH AND WELLNESS and HOLY SPIRIT HOSPITAL, a nonprofit: corporation, Defendants. Civil Action - Law No. 01-4538 Civil ACCEPTANCE OF SERVICE I accept service of the Writ of Summons on behalf of Holy Spirit Hospital and certify that I am authorized to do so. (l~efendant o~'Autl~o~ized al{gent) MI:lit: EVANS & WOODSlDE 3401 NORTH FRONT STREET EG, BOX 5~$0 (Mailing Address) 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHRYN PERROTT DONAHEY, and her Husband GLENN HOWARD DONAHEY a Administrators of the Estate of JOSEPH NICHOLAS DONAHEY and KATHRYN PERROTT DONAHEY and GLENN HOWARD DONAHEY, as Individuals, Plaintiffs, JAMES DOWNEY LONG, M.D.; BARBARA BRANDT; SPIRIT PHYSICIAN SERVICES, 1NC. d/b/a CENTER FOR WOMEN'S HEALTH AND WELLNESS and HOLY SPIRIT HOSPITAL, a nonprofit: corporation, Defendants. Civil Action - Law No. 01-4538 Civil ACCEPTANCE OF SERVICE I accept service of the Writ of Summons on behalf of Barbara Brandt and certify that I am authorized to do so. Date: (Defen"fi"~ant or Authorized Agent) 7/0/ (Mailing Address) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHRYN PERROTT DONAHEY, and her husband GLENN HOWARD DONAHEY as Administrators of the Estate of JOSEPH NICHOLAS DONAHEY and KATHRYN PERROTT DONAHEY and GLENN HOWARD DONAHEY, as Individuals, Plaintiffs JAMES DOWNEY LONG, M.D.; BARBARA BRANDT; SPIRIT PHYSICIAN SERVICES, 1NC. d/b/a CENTER FOR WOMEN'S HEALTH AND WELLNESS; and HOLY SPIRIT HOSPITAL, a nonprofit corporation Defendants NO. 01-4538 CIVIL CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE JURY TRIAL DEMANDED Counsel of Record for these parties: ECKERT SEAMANS CHERIN & MELLOTT, LLC John E. Hall, Esquire PA I.D. No. 11095 U.S. Steel Tower 600 Grant Street, 44th Floor Pittsburgh, Pa 15219-2788 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHRYN PERROTT DONAHEY, and her husband GLENN HOWARD DONAHEY as Administrators of the Estate of JOSEPH NICHOLAS DONAHEY and KATHRYN PERROTT DONAHEY and GLENN HOWARD DONAHEY, as Individuals, Plaintiffs JAMES DOWNEY LONG, M.D.; BARBARA BRANDT; SPIRIT PHYSICIAN SERVICES, INC. d/b/a CENTER FOR WOMEN'S HEALTH AND WELLNESS; and HOLY SPIRIT HOSPITAL, a nonprofit corporation Defendants NO. 01-4538 CIVIL CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE TO THEPROTHONOTARY Please mark the docket settled and discontinued with prejudice as to defendants James Downey Long, M.D., Barbara Brandt, CNM, Holy Spirit Hospital, and Spirit Physicians, Inc. d/b/a Center for Women's Health and Wellness. Respectfully submitted John E. Hall, E~quire Z~/ I U - Eckert Seamans Cherin & Mellott LLC U.S. Steel Tower 600 Grant Street, 44th Floor Pittsburgh, PA 15219 412.566.1915 Attorneys for Plaintiffs CERTIFICATE OF SERVICE I hereby certify that I am this~6.~,., day of March 2004, serving a copy of the foregoing Praecipe to Discontinue upon the persons and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, First Class Mail postage prepaid, as follows: Craig A. Stone, Esquire Mette, Evans and Woodside 3401 North Front Street P.O. Box 5950 Harrisburg, PA 17110-0950 Sarah W. Arosell, Esquire Thomas Thomas & Haler 305 North Front Street, 6th Floor P.O. Box 999 Harrisburg, PA 17108