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Home My WebLink About00-05937 >,',.- ,'--, -',0 d', . ,",:, ,^,-- ----'__~";~---:'~- ,,,,,':~,,, ,_~'",,,".ili,.';;',~__"-~ '";,:"_:,,:,.',:;,,:;,,,: "";',~,_ _\':jj ANDREW MCKENRICK and JUDY MCKENRICK, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 00 - S?J7 CNIL ACTION - LAW CUlL/~ OPAL AND JOHN MASON Defendants JURY TRIAL DEMANDED ORIGINAL 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 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 ,i u ~."o,..~"" ~"o' , ~ '-l' ,~> -""-'-"" , ~ ,'-', '0" '.',_ __'o,'..<::,_'';,>,,~_.c_ ' <,~" "" . '- -~"~~:' Il ANDREW MCKENRICK and JUDY MCKENRICK, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA i', I' E i: t , " ;~: : NO. I,:; i' CNIL ACTION - LAW i " , V. OPAL AND JOHN MASON Defendants f r: JURY TRIAL DEMANDED [-I I ii NOTICIA Le ban demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siquientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objectiones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. t~f If! lit ~1 I'} i~ ":. ~j ;;~' Cmnberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 , rei p Ii 11' f 4 , ~ , n: if r, u; fl:, [2 ~ :0 LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTA. SI NO TIENE ABODAGO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. , ~ "' I" it, " " , I .~ , t t f t I , , f u ~~",,'. - '-<- ' , -- ~ '.. ,-",,' "v ,,-,. ',=-- ..h,'o, ;'. ,,', ,- "~ ,,~' _' "d_ :""~' ANDREW MCKENRICK and JUDY MCKENRICK, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ; NO. tJo. 5'131 ~ '/ M-v V. CIVIL ACTION - LAW OPAL AND JOHN MASON Defendants JURY TRIAL DEMANDED COMPLAINT 1. Plaintiffs, Andrew and Judy McKenrick, are adult individuals, husband and wife, and currently reside at 63 West Pomfret Street, Carlisle, Cumberland County, Pennsylvania. 2. Defendants, John and Opal Mason, are adult individuals who reside at 63 West Pomfret Street, Carlisle, Cumberland County, Pennsylvania. 3. The facts and occurrences hereinafter related took place on or about August 31, 1999, at the Plaintiffs place of residence, 63 West Pomfret Street, Carlisle. 4. At that time and place, Plaintiffs resided at, and were legal tenants of said property, which is owned by Defendants John and Opal Mason. 5. At that time and place, Defendants were the owners of and the landlords to the residence at 63 West Pomfret Street, Carlisle, Cumberland County, Pennsylvania. 6. At that time and place, Plaintiffs' house contained a carpeted staircase consisting of eleven stairs, which was used to go between the upstairs bedrooms and the downstairs living room and kitchen. 7. At that time and place, the carpet on the staircase was loose and there was no handrail on either side of the staircase. 8. Prior to August 31, 1999, Defendants were made aware of the loose carpeting on the staircase numerous times. ,: II < . '~ - , . ~ . -'<' ","' --', ;", O"'''~''-'";''''MC _",,' , , ''',,, ,,;>,;,," ^,"'" , , ~, :2[;,,;> 9. At that time and place, Plaintiff Andrew McKenrick began to walk down the stairs, tripped on the loose carpeting and fell violently down seven steps, slannning into the wooden door at the base of the staircase. 10. The loose carpeting and missing handrail created a dangerous tripping hazard of which the Defendant was well aware prior to Plaintiffs' accident. The aforementioned dangerous condition existed for a sufficient amount of time before Plaintiffs accident, which should have given Defendants adequate time to correct the condition. 11. As a direct and proximate result of Defendants' negligence, Plaintiff suffered severe and painful injuries including, but not limited to, a cervical disc and a closed head injury. 12. Defendants had a legal duty as owners and landlords to provide a safe premises for Plaintiffs. 13. Defendants violated this duty to the Plaintiff, and were therefore negligent, III the following particulars: (a) failing to exercise the degree of care that a landowner owes to its tenants utilizing the premises for its intended purposes; (b) failing to properly maintain and operate the premises by allowing an unsafe hazard to exist; (c) failing to inspect its premises to determine whether there were any conditions or practices which could pose a hazard to tenants; (d) failing to remove the aforesaid tripping hazard even though they knew or should have known of its existence prior to Plaintiff s accident; " ti M ~. "" : ,,c, - '," ~'~.." __ '-5',,>, ,';:0",,' , -, ,,'~" '" , ,,,,',- '...." '--;.",., (e) failing to comply with the Borough of Carlisle Property Maintenance Code and BOCA Property Maintenance Code, which requires a handrail the entire length of the staircase, and all carpeting to be firmly secured. CLAIM I Andrew McKenrick v. John and Oval Mason 14. Paragraphs one through thirteen of this Complaint are incorporated herein by reference. 15. By reason of the aforesaid injuries sustained by Plaintiff, Andrew McKenrick, he incurred liability for medical treatment, medications, and similar miscellaneous expenses in an effort to restore himself to health, and a claim is made therefor. 16. As a result of the aforesaid injuries, Plaintiff, Andrew McKenrick, will incur future medical expenses, and a claim is made therefor. 17. As a result of the aforesaid injuries, Plaintiff, Andrew McKenrick, has undergone and in the future will undergo great physical and mental pain and suffering, great inconvenience in carrying out his daily activities, loss of life's pleasure and enjoyment, and a claim is made therefor. 18. As a result of the aforesaid injuries, Plaintiff, Andrew McKenrick, has been and in the future will be subject to great humiliation and embarrassment, and a claim is made therefor. 19. As a result of aforesaid injuries, Plaintiff, Andrew McKenrick, has lost wages and may suffer similar losses in the future, and may sustain a permanent loss of his earning power and capacity, and a claim is made therefor. II w <'","''''' ""~ ~~'~'" " "" "," ~ ,,-',:' ,." C.,<, _~_ ~" , . "",;':'':;;; 20. Plaintiff, Andrew McKenrick, continues to be plagued by persistent pain and limitation and, therefore, avers that his injuries will be of permanent nature, causing residual problems for the remainder of his lifetime, and a claim is made therefor. WHEREFORE, Plaintiff, Andrew McKenrick, demands judgment against Defendants John and Opal Mason in an amount in excess of twenty-five ($25,000) Thousand Dollars exclusive of interest and costs, and in excess of any jurisdictional amount requiring compulsory arbitration, along with any and all equitable relief deemed appropriate by this Honorable Court under the circumstances, and a trial by jury. CLAIM II Judv McKenrick v. John and Opal Mason 21. Paragraphs one through twenty of this Complaint are incorporated herein by reference. 22. By reason of the aforesaid injuries sustained by her husband, Plaintiff Judy McKenrick was required to incur liability for medical treatments, medications, and similar miscellaneous expenses in an effort to restore her husband to health, and may be required to incur similar expenses in the future and claim is made therefor. 23. By reason of the aforesaid injuries sustained by her husband, Plaintiff Judy McKenrick has been deprived of the assistance, companionship, consortium, and society of her husband and claim is made therefor. II '.''':, ""'""^" -e' ''''~"'' ~~.,' ;, .~ -"'_' 'h~" ,~,',__". ;;~i;__,:.:--: ~.",,,,,,,,,,f;" WHEREFORE, Plaintiff, Judy McKenrick, demands judgment against Defendants Jolm and Opal Mason in an amount in excess of Twenty-five Thousand ($25,000) Dollars, exclusive of interest and costs and in excess of jnrisdictional amount requiring compulsory arbitration, along with any and all equitable relief deemed appropriate by this Honorable Court under the circumstances, and a trial by jury. Respectfully submitted, ANGINO & ROVNER, P.C. D&c arf ififtW MichaelJ. LD. No. 58 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Attorney for Plaintiffs Ii tl .. ,:", ,,"' '","' .-' ;" -, ~"--- '- ,-,,-'----- ,'.' '_:":S.'~'. VERIFICATION I, JUDY McKENRICK, do hereby swear or affirm that the facts set forth in the foregoing COMPLAINT are true and correct to the best of my knowledge, information and belief I understand that this Verification is made subject to the provisions of 18 Pa.C.S.A. 94904, relating to unsworn falsification to authorities. ~~4.~ '\.~ Mc CK 769/JKW I li ~ -- ~-,- - ,'.'. ,- o~ 'c,' '~~ ^,kj. ~'~ ,:"'~,;.,;J ----":-,':;:,, , VERIFICATION I, ANDREW McKENRICK, do hereby swear or affirm that the facts set forth in the foregoing COMPLAINT are true and correct to the best of my knowledge, information and belief. I understand that this Verification is made subject to the provisions of 18 Pa.C.S.A. g4904, relating to unsworn falsification to authorities. $~ 769/JKW II " ti , ,-", "'~" i'1lJ" ":,;, m~~'~"" ':':,'" ~"';'~>lL 'LJ ;,:'"" ...... u ~ ;":"-~'-'" ., ~' ',,> ", ',,' ','<0,-" '~~- -" ,~ 0 , ?~ i ~ ..(q -OC,:" III f ~ ~ p i 2"; ;" h ~~" ; fi- (", ~ rJ . r::: g d .,~- -- t ~2 0- J I ~ C\ ~ ~ -;; -, & Fe tf' 1- C Sf; C.; :~ c_ ::i,,) '"".:: (;j S"? :.~ ';h ~ ~;:: ~i II.....!...... :~' ':;i' ,. ~i' r, ':1 llii ;::-1 t: [~ ~ ~.'. ~I t~ ;!! ~ ~ .:.' II....' g ;; ~ I! i ~ 'i 8 ~- ~ w -..."-'~ ~ ,~'- 0" ,_~ ., . ~ '" 00!ll!1l:' \ SHERIFF'S RETURN - REGULAR Af CASE NO: 2000-05937 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MCKENRICK ANDREW ET AL VS MASON OPAL ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MASON OPAL the DEFENDANT , at 0010:53 HOURS, on the 31st day of August , 2000 at 63 WEST POMFRET ST CARLISLE, PA 17013 by handing to OPAL MASON 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 Service Affidavit Surcharge 18.00 3.10 .00 10.00 .00 31.10 So Answers: ~f3r!' 1-~~< R. Thomas Kline 09/01/2000 ANGINO & ROVNER Sworn and Subscribed to before By: \Jo.um ~ . ~ Deputy Sheriff me this r!!:::. day of J;.,.G.uJ..~ >n) A.D. ()~ I j21J1dYl: {~9Pi rothonotary ~~~'." " -" ",'<"~ u"O- ~ . ~< -,~ ~ --.. ~ -~,~" ,-""-' I SHERIFF'S RETURN - REGULAR "" CASE NO: 2000-05937 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MCKENRICK ANDREW ET AL VS MASON OPAL ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MASON JOHN the DEFENDANT , at 0010:53 HOURS, on the 31st day of August , 2000 at 63 WEST POMFRET ST CARLISLE, PA 17013 by handing to OPAL MASON 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 Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So ;:~N"A'1:,?'~i R. Thomas Kline 09/01/2000 ANGINO & ROVNER Sworn and Subscribed to before By: \J~ g. ~ Deputy Sheriff ~ ~,~~D - Prothonotary Jefferson J. Shipman, Esquire 1. D. #51785 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P. O. Box 1268 HarrisDurg, PA 17108-1268 (717) 234-4161 Counsel for Defendants ANDREW MCKENRICK AND JUDY MCKENRICK, his wife, Plaintiffs v. OPAL AND JOHN MASON, Defendants A ... IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. CIVIL ACTION - LAW No. 00 - 5937 CIVIL TERM JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Jefferson J. Shipman, Esquire, of Goldberg, Katzman & Shipman, P.C., as counsel on behalf of Defendants Opal and John Mason. ~;;O~.:A~ I /I (~ GOLDBERG, KATZMAN & SHIPMAN, P.C. son J. Shipma , 1. #: 51785 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendants . """,;,,;,- , .',^, , ."",",:1 , '3 ""':"iJ ~ .. CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served on the following counsel of record, by depositing the same in the United States Mail, postage prepaid, in Harrisburg, Pennsylvania, on September 10, 2000: Michael J. Navitsky, Esq. Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 GOLDBERG, KATZMAN & SHIPMAN, P.C. ~~e I.D. #: 51785 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendants ":'ii ~ .H""'""",","r'c;"...".[.., ,. ...'.,..." ~,,' ,",' -- ":--,' '" ,', ~ "O"~>'" " "G', "">">',_l ,'<' "M'"'" ;=Plf-':; 7; (;-) ... ~-=--:: -::-' ,.c> >.2 ?: (/) 'F"'l --',:; ,," . "j '~.lJ <. .,~" " ." ~~.. ,'c'. ," f ~ I; ~ v . ~~ ~f ~i r' f ; ~ ~ : .~~,",- ~,,,,,,...,,,,,. - ,."" c:'_',' "-' -- -v'",;~, ,5', - ,,~ " '..'.-,'-. - ,,' , , , -- . -" -,--'~ ' . Jefferson J. Shipman, Esquire Attorney I. D. No. 51785 GOLDBERG, KATZMAN & SHIPM1!.N, P. c. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorneys for Defendants ANDREW MCKENRICK AND JUDY MCKENRICK, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. v. CIVIL ACTION - LAW OPAL AND JOHN MASON, Defendants No. 00 - 5937 CIVIL TERM JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Plaintiffs and their Attorney, Michael Navitskey, Esquire 4503 North Front Street Harrisburg, PA 17110 YOU ARE HEREBY notified to plead to the within New Matter of Defendants, Opal and John Mason, within twenty (20) days of service hereof. GOLDB RG, KATZMAN & SHIPMAN, P.C. . DATE: Cll '2. l \ ~ Je erson J. Shipm n, Esquire Attorney I.D. 51785 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendants -,~ " -", .,'d',,' 0',-"_-- c,;;.- . "'~~". ""'--',--- ,< . ',;; "'''j Jefferson J. Shipman, Esquire I.D. #51785 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Counsel for Defendants ANDREW MCKENRICK AND JUDY MCKENRICK, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. v. CIVIL ACTION - LAW OPAL AND JOHN MASON, Defendants No. 00 - 5937 CIVIL TERM JURY TRIAL DEMANDED DEFENDANTS' ANSWER WITH NEW MATTER TO PLAINTIFFS' COMPLAINT AND NOW, comes the Defendants, Opal and John Mason, by and through their counsel, Goldberg, Katzman & Shipman, P.C., and file the following Answer and New Matter in response to Plaintiffs' Complaint: 1. Admitted in part, denied in part. It is admitted only that the Plaintiffs reside at 63 West Pomfret Street, Carlisle, Cumberland County, Pennsylvania. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the remaining averments of Paragraph 1 and the same are, therefore, denied and strict proof demanded at the time of trial. J ---,'oC' _,_~""",.._ - 'c ' r'" " ;,.,',( "'=~-,-, ,~,,_ ~ , , '~'J; 2. Denied. 3. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 3 and the same are, therefore, denied and strict proof demanded at the time of trial. 4. Admitted. 5. Admitted. 6. Admitted. 7. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 7 and the same are, therefore, denied and strict proof demanded at the time of trial. 8. Denied. The averments contained in Paragraph 8 contain conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. 9. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the ,averments contained in Paragraph 9 and the same are, therefore, denied and strict proof demanded at the time of trial. 2 ",,,,'--.:','" :-',_,ih_, ,,", --;;'., :. ': ,1" ~ , '_'- ",/:'<,1 ';J 10. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 10 and the same are, therefore, denied and strict proof demanded at the time of trial. 11. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 11 and the same are, therefore, denied and strict proof demanded at the time of trial. 12. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 12 and the same are, therefore, denied and strict proof demanded at the time of trial. 13. Denied. The averments contained in Paragraph 13, Subparagraphs (a)-(e), contain conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. (a) Denied. It is specifically denied that the Defendants failed to exercise the degree of care that a 3 ~,. '^,'-. d" . '.,".", "" ':.F'n_"';,...:.. ;., "'''''",(,;"",,,i.~''';C' "~~'.<,,-~".:. .. -,,;'i,i:- '" ;'." .. """~Y landowner owes to its tenants utilizing the premises for its intended purposes; (b) Denied. It is specifically denied that the Defendants failed to properly maintain and operate the premises by allowing an unsafe hazard to exist; (c) Denied. It is specifically denied that the Defendants failed to inspect the premises to determine whether there were any conditions or practices which could pose a hazard to tenants; (d) Denied. It is specifically denied that the Defendants failed to remove a tripping hazard even though they knew or should have known of its existence prior to Plaintiff's accident; (e) Denied. It is specifically denied that the Defendants failed to comply with the Borough of Carlisle Property Maintenance Code and BOCA Property Maintenance Code, which allegedly requires a handrail the entire length of the staircase, and all carpeting to be firmly secured. 4 " ' r,' ',.~_ < ,).--~ ' ". '" "'y--,,~ - -- " ':, i'''--__. ,"~ CLAIM I ANDREW MCKENRICK v. JOHN AND OPAL MASON 14. The answering Defendants incorporate herein by reference their answers to Paragraphs 1 through 13 above as though fully set forth herein at length. 15. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 15 and the same are, therefore, denied and strict proof demanded at the time of trial. 16. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 16 and the same are, therefore, denied and strict proof demanded at the time of trial. 17. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 17 and the same are, therefore, denied and strict proof demanded at the time of trial. 18. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in 5 ,,"'- - -.""'"'" ,;~'--' -,' ',,,'-- '-'.'';;' , ;- " > "= Paragraph 18 and the same are, therefore, denied and strict proof demanded at the time of trial. 19. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 19 and the same are, therefore, denied and strict proof demanded at the time of trial. 20. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 20 and the same are, therefore, denied and strict proof demanded at the time of trial. WHEREFORE, the Defendants, Opal and John Mason, respectfully request that judgment be entered in their favor and that Plaintiffs' Complaint be dismissed with prejudice. CLAIM II JUDY MCKENRICK v. JOHN AND OPAL MASON 21. The answering Defendants incorporate herein by reference their answers to Paragraphs 1 through 20 above as though fully set forth herein at length. 22. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to 6 - , 0~_", ~' j,"c ~~ . form a belief as to the truth of the averments contained in Paragraph 22 and the same are, therefore, denied and strict proof demanded at the time of trial. 23. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 23 and the same are, therefore, denied and strict proof demanded at the time of trial. WHEREFORE, the Defendants, Opal and John Mason, respectfully request that judgment be entered in their favor and that Plaintiffs' Complaint be dismissed with prejudice. N~W MATTER By way of additional answer and reply, the Defendants interpose the following New Matter defenses: 24. That the Plaintiffs' claims are barred and/or limited by the Pennsylvania Comparative Negligence Act, 42 Pa. C.S.A. ~7102, et seq., and by the Doctrine of Comparative Negligence. 25. That the Plaintiff failed to exercise reasonable care for his own safety under the circumstances then and there existing. 7 ~ ,-,. .-"k u"._" "",:',' ,,'n'_ ""' , ;,~ ' ' " >' i"'~i 26. That the Plaintiff was comparatively negligent and failed to exercise reasonable care for his own safety in the follows: (a) Walking and stepping inattentively without first ascertaining whether it was safe to do so; (b) Knowingly and voluntarily encountering an obvious danger; (c) Failing to wear suitable shoes; (d) Failing to watch where he was walking and stepping; and (e) Walking and stepping in a hurried or otherwise inappropriate manner. 27. The Plaintiff's failure to exercise reasonable care for his own safety was a substantial factor in the happening of the accident. 28. If a dangerous condition existed at the time of the Plaintiff's accident, which is denied, then the Defendants aver that they did not have actual or constructive notice of the allegedly dangerous condition prior to the accident. 29. That the Plaintiff's injuries and damages, if any, were not caused by any act, omission or breaches of duty by answering Defendants. 8 - .~ ,.. ,~ ,-- , ",'^'C ~", -"',1'_ ""-,,.,- ~,>;" .''0-.'_''>, <~ ,;,;,~ " , '",-,.,' ~,' ,_ '0. "_"',;1L 30. That the Plaintiff knowingly and voluntarily assuming the risk of his injuries under the circumstances then and there existing by identifying a dangerous condition, appreciating its dangerous character and voluntarily proceeding to encounter the condition. 31. That if it should be found that there was any negligence on the part of the answering Defendants, which negligence is expressly denied, any such negligence was not a proximate cause of any damages to the Plaintiff. 32. That the Plaintiff's accident and any alleged injuries may have been caused by a 'trivial defect." WHEREFORE, the Defendants, Opal and John Mason, respectfully requests that judgment be entered in their favor and the Plaintiffs' Complaint be dismissed with prejudice. GOLDBERG, KATZMAN & SHIPMAN, P.C. Je ferson J. Shipman I.D. #: 51785 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendants Date: C\ \ ~\ \ '2 EMASON.ANS - 9 -"""--' _,'"__a ;,,', ~ ~, VERIFICATION I, OPAL MASON, hereby acknowledge that I am the Plaintiff in this action; 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. Section 4904, relating to unsworn falsification to authorities. fll!~/#o~ 0' Date: cy /9-0;) ~ ~ ,,~., ' , "..; ~, - - .-",--" ~_~o_;' _ ,'- "~ w --::-:';:T-:~,,:'~: ,,','- " ~ ".':;,1, ',~ '-->' ;';;,-.': VERIFICATION I, JOHN MASON, hereby acknowledge that I am the Plaintiff in this action; 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. Section 4904, relating to unsworn falsification to authorities. John Date:q-(q~ '9 M '-'",'. '-.- -- ' ,;,,', '-' '~.. ~.:'~;.,-;" \;" -"""1 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served on the following counsel of record, by depositing the same in the United States Mail, postage prepaid, in Harrisburg, Pennsylvania, on~. 2.1..,r'", 2000: Michael J. Navitsky, Esq. Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 GOLDBERG, KATZMAN & SHIPMAN, P.C. . Jef er on J. Shipman, I.D. #: 51785 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendants ,'';'~'~'-3'", ~..i) "" ";.",,,-"";- "."", -'.-' , -':'~~L'>1""'; ,- - "-,,' ", ,..~',j" ",,~~',' "-,,---"~>-' ". ....O^'..'_ ,- " , \1 ", ;! '~ i I I 0 (,-:':J n c c-~ ," - ~ v'> u..! -0 C:~] Pl n--; ~1:J IT1 l'T: -0 j-- Z :eL' Co,) ... ~ --... ~;0,~ <,c; 1'-0 (;;!-J ~ \......' "V ~..,-~ 'Ti r:> ~~j ~~ ...0:::" -;",--rn 5> c :,:::~ 2: ..- '1> :::;! <~ C- o< ,~ ',."n . ~":, ~~' -'"','-;"J,;."~"-,_ ,;' - " '.' ",,~',~,~~, "f"%:; ';.,'_'-- --- "!- >""'1 ->;;,"~'dJ ,. - , ANDREW MCKENRICK AND JUDY MCKENRICK, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. v. CIVIL ACTION - LAW OPAL AND JOHN MASON, Defendants No. 00 - 5937 CIVIL TERM JURY TRIAL DEMANDED STIPULATION OF COUNSEL IT IS HEREBY stipulated and agreed by and between Michael Navitsky, Esquire, counsel for Plaintiffs, and Jefferson J. Shipman, Esquire, counsel for Defendants, that Subparagraph (a) of Paragraph 13, only, is hereby stricken and deleted from the Complaint. ANGINO & ROVNER, P.C. By Micha: 1 Nav 4503 North ont Stree Harrisburg, PA 17110 Attorneys for Plaintiffs , GOLDBERG, KATZMAN & SHIPMAN, P.C. Je fe son J. Shipm n, Esquire 1. . #: 51785 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendants ~,:,k ~&~ fi, d-1JffD . . - . 'r'",' ,', '~J, ~ , 1-'- ;';',,,;Jc: & -' . CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served on the following counsel of record, by depositing the same in the United states Mail, postage prepaid, in Harrisburg, Pennsylvania, on ~,JJ:.. ~ " 2000: Michael J. Navitsky, Esq. Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 GOLDBERG, KATZMAN & SHIPMAN, P.C. Jef e son J. Shipma , Esquire I. . #: 51785 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendants .. ~",<,_ ,,~,',,-? "-'oo'."~ ," '- .,~, . , 0 Cl 0 ~ 0 ,.., .,,"- 'f.! -0 en f"1 -n mf'Ti -'0 r-- ~-q N 1:--q 2.:F'" il~, (I) ),'" N -=<:2.: c:: c~ -0 ~Cj -~. ~-O - PC: .. ~i ~ C"' "0- Xi (n '< ,,_, ~.-~J. . Ii ! 1 'I .1 i I I ! . . ~-~ .'1 ~, " --i>~'_ , ",4--" ',00' ,', ~" "_ ~ '," ,~. -""-'''/', ",' .', ,',,",,' ~'~:,l'_,~ ,-, ';;" ,;;,.-;3.." ANDREW MCKENRICK and JUDY MCKENRICK, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00 - 5937 Civil Term CNIL ACTION - LAW R\nrM ~ \ O h~'\l~\... ~~~ .;JtI ",. V. OPAL AND JOHN MASON Defendants JURY TRIAL DEMANDED PLAINTIFFS' RESPONSE TO DEFENDANTS' NEW MATTER 24. The allegations constitute conclusions of law to which no response is required. To the extent that any response is required, said allegations are denied. Plaintiff was not negligent. 25. The allegations constitute conclusions of law to which no response is required. To the extent that any response is required, said allegations are denied. Plaintiff was not negligent. 26. The allegations constitute conclusions of law to which no response is required. To the extent that any response is required, said allegations are denied. Plaintiff was not negligent. To the contrary, Plaintiff acted reasonably at all times with respect to the following: a. Walking and stepping attentively; b. Not knowingly or voluntarily encountering an obvious danger; c. Wearing suitable shoes, under the circumstances; d. Watching where he was walking and stepping; and e. Walking and stepping in a non-hurried or otherwise appropriate manner. " ~ . --'" "'~' , " ",,-',:. ," . ~,' ~,.,';-",",".,~,-. ," "'.",,- .;y,", ,'<".-',..-'\-':] 27. The allegations constitute conclusions of law to which no response is required. To the extent that any response is required, said allegations are denied. Plaintiff was not negligent in any fashion. 28. Denied. Defendants' allegations that they did not have actual or constructive notice of the dangerous condition of the stairwell within Plaintiffs' apartment; that is, that the carpeting was loose on the steps and that the stairwell lacked a handrail is false. To the contrary, Defendants were well aware of this condition prior to Plaintiffs' accident. 29. The allegations constitute conclusions of law to which no response is required. To the extent that any response is required, said allegations are denied. Plaintiffs injuries and damages were caused by Defendants' negligence. 30. The allegations constitute conclusions of law to which no response is required. To the extent that any response is required, said allegations are denied. Plaintiff was not negligent. Plaintiff did not knowingly and voluntarily assume the risk of any injury. Assumption of the risk, as a legal principal and defense, does not apply to this case as a matter of law. 31. The allegations constitute a conclusion of law to which no response is required. To the extent that any response is required, said allegations are denied. Defendants' negligence was the proximate cause of Plaintiffs' injuries and damages. 2 II ~ ,; '" '~, ..,"'~.','""',,,, <',no_ <'_' "'r'_ ~__c o~ 'l<-{,i:, ,'1';__";;-F~;,'-' r'X_ ~,"'" " -' '-, '~ ,~ -, .~ '., "";'~i absence of a handrail were not "trivial defects." Date: Ii II ,~ 32. Denied. The loose carpeting within the stairwell of Plaintiffs' apartment and the ttk J9( ()07!1J 3 Respectfully submitted, itsky, Esq LD. No.5 3 4503 N. Front Street Harrisburg, P A 1711 0 (717) 238-6791 Attorney for Plaintiffs ~1 ',. '", '. ~., " .,-,- ~c,,~,,'- T ',--) _,,' - :', '.',.' ~>:-,'il ::.,..;,-~,~! COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF CUMBERLAND I, MICHAEL J. NA VITSKY, being duly sworn according to law, depose and say that I am counsel for Plaintiffs, Andrew McKenrick and Judy McKenrick, and I am authorized to make this affidavit on behalf of said Plaintiffs, and that the facts set forth in the foregoing Response to New Matter are true and correct to the best of my knowledge, information and belief or, are true and correct based on the information obtained from Plaintiffs. Sworn to and subscribed before me this ;:l<fNay of So pkw. .ku.r ,2000. ~4uM1- otary Publ. Notarial Seal Kimberly J. Houser, Notary Public LowerAilen Twp., Cumberland County My Commission Expires Oct 2. 2000 Ii u '" CERTIFICATE OF SERVICE I, Jessie K. Walsh, an employee of the law firm of Angino & Rovner, P.c., do hereby certify that I am this day serving a true and correct copy of Plaintiffs' Response to New Matter of the Defendants, upon all counsel of record via postage prepaid first class United States mail addressed as follows: Jefferson J. Shipman, Esquire Goldberg, Katzman & Shipman, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 0~ 'K (j&L Jessie K. Walsh Dated: ~-f. de;, :;)(7)0 4 Ii II ., ,.._";:':;;,~, :1 --,-,~:c,;,.~" C,"- .;/- ';"~'';''iiliiif'~~~''~'; >, "-"-";,-';"- ~...:_:,."_~~..,o-- ,'" - -'- '.~"- ,,';''' -.-..'';j "+ ;,>.:, " ~: ~:! ~: ~1 ,;, 'll i\~ Ii Ii ijj , ;! (") C) 0 c: C:' -on ~s~ 0 -;JCD n 111rn ,-.\ o- z.::::;::; 1 -,-, ~~:l Z~~. ' - ~.., r,,:;. .'---' ~:~:~- ;~~:2=j ~C,i .'0 ~-~~ ~~~ 2'C :"",l( Z(~. .. ,'-' )> ~=:~ N Lj .. ..4 -/ :J1 "1;~ ~ '::0 ..... -< " , , i I, U ~ , I: ~ II i J I i , ~-" " ~ ,-, "'"" "."" ,'". ';0.' ,-,,"--c ~_:~., ,.- - ',.,-._ -A'~',<""___,,. _"""~.,,, _', c'_""';, --,~--.' .- ~-, "~_-:;;;;\l. ANDREW MCKENRICK and JUDY MCKENRICK, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00 - 5937 Civil Term v. OPAL AND JOHN MASON Defendants : CNIL ACTION - LAW : JURY TRIAL DEMANDED ORIGINAL PLAINTIFFS' REQUEST FOR ADMISSIONS DIRECTED TO DEFENDANTS AND NOW INTO COURT, through undersigned counsel, comes the Plaintiffs, Andrew McKenrick and Judy McKenrick, and request that the Defendants, Opal and John Mason, admit or deny the following facts: 1. The carpeting on the stairs in Plaintiffs' apartment was loose prior to Mr. McKenrick's August 31, 1999 accident. 2, The carpeting on the staircase in Plaintiffs' apartment was known to be loose by Defendants prior to Mr. McKenrick's August 31,1999 accident. 3. Plaintiffs told Defendants about the loose carpeting in Plaintiffs' apartment prior to Mr. McKenrick's August 31,1999 accident. 4. The stairwell inside Plaintiffs' apartment contained no handrail on either side of the staircase prior to August 31, 1999. 5. The Defendants knew that the stairwell in Plaintiffs' apartment contained no handrail on either side of the staircase prior to August 31, 1999. II il " :~',-"-~-.'-,,-.: ,~-,~, " .., .-" "' ~<.;,' - --,..- !;'".j,:': -' 6. The Defendants replaced the loose carpeting on the stairwell within Plaintiffs' apartment following Mr. McKenrick's August 31, 1999 accident. 7. The Defendants installed a handrail in the stairwell of Plaintiffs' apartment following Mr. McKenrick's August 31,1999 accident. 8. The Defendants were in violation of the Borough of Carlisle's Building Code, Chapter 183, pertaining to property maintenance, in that there was no handrail for the second floor apartment stairway (within Plaintiffs' apartment), and carpeting on the stairway was loose. 9. The Defendants' property, specifically, the stairwell within Plaintiffs' apartment, failed an inspection by the Borough of Carlisle Code Enforcement Officer, Michael H, Landis, following Plaintiffs' accident, in that the stairwell within Plaintiffs' apartment lacked a handrail and the carpeting on the stairway was loose. 10. The Defendants voluntary cooperation was requested by the Code Office of the Borough of Carlisle to replace the loose carpeting and to install a handrail in Plaintiffs' apartment based on an investigation performed by the aforesaid Code Enforcement Officer in response to Plaintiff s accident. 11. A photocopy of the September 7, 1999, correspondence from Michael H. Landis, Borough of Carlisle Code Enforcement Officer directed to Ms. Opal Mason (attached hereto), represents a true and accurate copy of the correspondence actually received by Defendants. 2 I " II , " ~"- ., ,"'ik:J-. -^',' ~_ ,,- -.", -';'_'-: , e, '~''''';'__ ,,"",,-<_,'--';,-, ---'.,- '" -..;~, -,,,. :_,-,-,-'"':,,,--';--" . '-"..;,;--,.- ,,-,.-, -- 12. Defendants voluntarily complied with the requests made by the Borough of Carlisle Code Enforcement Office as set forth in the September 7, 1999, correspondence from Michael H. Landis to Opal Mason. 13, Loose carpeting on the stairwell within Plaintiffs' apartment was not a trivial defect. 14. The absence of a handrail within the stairwell of Plaintiffs' apartment was not a trivial defect. Respectfully submitted, ANGlNO & ROVNER, P.C Date: l-q{ ()ffM Mich el 1. LD. No. 58 4503 N. Front Street Harrisburg,PA 17110 (717) 238-6791 Attorney for Plaintiffs 3 II .' .11 " _, M .' ,,_ ",. "'"-__ "'_~ _ _ , . . . _ __ _ _ --'---,'j;.. ,~" __,_ 0 _ , __->~i--" _~",_;i- .,; CERTIFICATE OF SERVICE I, Jessie K. Walsh, an employee of the law firm of Angino & Rovner, P,C., do hereby certify that I am this day serving a true and correct copy of Plaintiffs' Request for Admissions Directed to the Defendants, upon all counsel of record via postage prepaid first class United States mail addressed as follows: Jefferson J. Shipman, Esquire Goldberg, Katzman & Shipman, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 J~1{u>>L Jessie K. Walsh Dated: .5.p{ ,)7, ()J!lJ:) 4 ,I I, ~ "! -'-I ~*u "~ 0' " - _', - ..... "e,o <~- -~lc-lij~~' , ~ c ,~. ". ~" -- -~ . ~ - ---<i c',~' C,_W"~_"'_'" '-Y",- - I. I I ... I (") c: <' -om rnl1"' Z"'C' t5~; rjc) j?;", Z'" ...-:-c: Pc ~ c:::;- ,~.'. -' (=' r.') ~~.-\ - ~'q I; :1 ij i I' i, ~ \: I' i , i L.! "n r.....:;, ~ ~';:? -- .1 ._L_n ;:':2.~~ ~~ ?D -< "'-' \:? <:.11 ...J ~~ . ~. '--"C __,."' . - 'i'" "_"1'_,,,-__~_ -', -'."'-' '"" "-' <,~~~,'_'r.__'-'" C, :>, ,;' '-"",,'.t ,V,;;-, "-';";\},>,,:;'_"~". ",~,--,,-,;~~'__L,~-:_' LD. #51785 GOLDBERG, KATZMAN & SHIPMAN, P.C. 420 Market St~eet , ~~fO~rB8R !26@hlpman, Esqulre Harrisburg, PA 17108-1268 (717) 234-4161 counsel for Defendants ANDREW MCKENRICK AND JUDY MCKENRICK, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. v. CIVIL ACTION - LAW OPAL AND JOHN MASON, Defendants No. 00 - 5937 CIVIL TERM JURY TRIAL DEMANDED DEFENDANTS' ANSWERS TO PLAINTIFFS' REOUEST FOR ADMISSIONS AND NOW, come the Defendants, Opal and John Mason, by and through their counsel, Goldberg, Katzman & Shipman, P.C., and files the following Answer to Plaintiffs' Request for Admissions: 1. Denied. 2. Denied. 3. Denied. 4. Denied. 5. Denied. 6. Admitted only that carpeting was replaced following Mr. McKenrick's tenancy. Any remaining allegations are denied. 7. Admitted only that the hand rail was re-installed following Mr. McKenrick's tenancy. Any remaining statements are denied. ..,=,~., ,~, ~.<'~ <,_c._, ',,"_=" .'_ ,-,_. ""_',',<__." 8. Denied insofar as the statement is a conclusion of law. If a further response is required, it is admitted that Ms. Opal Mason received a letter dated September 7, 1999 from Michael Landis, Borough of Carlisle Code Enforcement Officer, pertaining to the hand rail and carpeting issues. 9. Denied insofar as the statement is a conclusion of law. If a further response is required, it is admitted that Ms. Opal Mason received a letter dated September 7, 1999 from Michael Landis, Borough of Carlisle Code Enforcement Officer, pertaining to the hand rail and carpeting issues. 10. Admitted only as to the hand rail. The remaining statements are denied. 11. Admitted that the correspondence was received. It is noted that the letter was not attached to the Request for Admissions. 12. Admitted. 13. Denied. 14. Denied. Respectfully submitted, G ERG, KATZMAN & SHIPMAN, P.C. son J. Shipman, Esquire 1. #: 51785 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendants ~ 0_' - - -~-- -- _.,_ .~~ ~ ~~_ - "~'l--'-' ,0",""--,_ ,'!'_'d.',h-ili:>"-...~--"--"~_~_ ,~-,> _~- 'I""~..,_' VERIFICATION I, John Mason, hereby acknowledge that I am the Defendant in this action; that I have read the foregoing Answers to Plaintiffs' Request for Admissions , 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. Section 4904, relating to unsworn falsification to authorities. John Date: {o- t~-<)o 53314.2 VERIFICATION I, Opal Mason, hereby acknowledge that I am the Defendant in this action; that I have read the foregoing Answers to Plaintiffs' Request for Admissions , 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. Section 4904, relating to unsworn falsification to authorities. Cf#~~/?7 Op son ~3~;:; fojn/pt ~^'~ ~~ - ,-.,', o' ~- ~_";,,.'_ - _~"'" ,,'-.<, _,.',,' ,,,';' /""",~.~,~",'___.,,,,,-_ -.,,,,"'-.' k. 1~~ ;-W,-..,~;,'Jo_",-" .;,,_, ,,,,ij CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served on the following counsel of record, by depositing the same in the United ail, postage prepaid, in Harrisburg, pennsylvania, on Michael J. Navitsky, Esq. Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 , 2000: & SHIPMAN, P.C. J ff son J. Shi man, Esquire I D. #: 51785 3 0 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendants .- *Aill. x, ,~_~=~~~:' ,- , ~, ""., " ". .,., '~ . "H'.' _,.,~~" 'I,,",,,,,' ,,' ". - '"' -" -- ~ . ".' ~- I := .''''') "} h,.) C,~, 0.; Z ...----.I :.;.) ____~ \..,.0 ~ . ~ - ...0..< ~ ,.,"".'. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM, -vs- CASE NO: 00-5937 OPAL AND JOHN MASON As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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: 02/26/2001 "- ) DEll-237497 SlSBO-LOl ,=- ~,' ~ ~,~ ~~ '-"'W COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM, -VS- CASE NO: 00-5937 OPAL AND JOHN MASON NOTICE OF INTENT, TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 CAlU.ISLE CONTAINER COMPANY THE CALIFORNIA CAFE CAlU.ISLE CAMP GROUND ALL AMERICAN FAMILY RESTAURANT EMPLOYMENT EMPLOYMENT EMPLOYMENT EMPLOYMENT TO: MICHAEL J. NAVITSKY, ESQUIRE KCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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 KeS or by contacting our local KCS office. DATE: 02/06/2001 KCS on behalf of JEIfIfISKSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT CC: JEFFERSON J. SHIPMAN, ESQUIRE - Any questions regarding this matter, contact THE KeS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-144506 51580-COl ~ -" " COMMONWEALTH OF PENNSYLVANIA - COUNTY OF CUMBERLA.'.'D ANDREW MCKENRICK & JUDY MCKENRICK VS File No. 00-5937 CIVIL OPAL & JOHN MASON SUBPOENA TO PRODUCE DOCUMTh-rS OR THINGS FOR DISCOVERY PURSUMIi-r TO RULE 4009.22 TO: f'TT$'1'nnTAN m' RRr.mm~ FOR' CARLISLE CONTAINER COMPANY (Name of Person or Entityt Within twe~. (20) days after service of this subpoena, you are ordered by the court to produce ~he following docu~ents or things: SEE ATTACHED at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Addl'es.) You may deih'ef 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 ad,'ance, the ",..onable cost of preparing the copies or producing the things sought. If you fail to ;>roduce 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: WFFRll.~ON.1. SHIPMAN. ESO. ADDRESS: PO BX 1268 HARRISBURG. PA 17108 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTOR."EY FOR: V......NTlAN.,. DATE: 0;:;)11 .J.UMd-- ().. Q{)() I BY THE COURT: Seal of the Court (Eff. 7! 97) ,ow _, ., '." . , .- .~'- . ~;"" ! EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE CONTAINER COMPANY 750 CLAREMONT ROAD CARLISLE, PA 17013 RE: 51580 ANDREW J. MCKENRICK Any and all employment records, files and memorandums, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee. Dates Requested: up to and including the present. Subject: ANDREW J. MCKENRICK 63 WEST POMFRET STREET, CARLISLE, PA Social Security #: 189-52-8666 Date of Birth: 12-23-1961 SUlO-289352 SlS80-LOl 'l' "Ji>,. , < , ~"'""~: CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM, -VS- CASE NO: 00-5937 OPAL AND JOHN MASON As a prerequisite to service of a subpeena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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: 02/26/2001 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-237498 51580-L02 ". '", "-': COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM. - VS- CASE NO: 00-5937 OPAL AND JOHN MASON NOTICE OF IN'l'EN'l' TO SERVE A SUBPOENA TO PRODUCE DOCUMEN'l'S AND THINGS FOR DISCOVERY PURS11AN'r TO RULE 4009.21 CARLISLE CORTAIIIER COMPANY TBB CALIPOlUllA CAFE CARLISLE CAMP GROmm ALL AHElUCAlI' FAMILY IlES'lAURART EMPLOYHEllT EMPLOYHEllT EMPLOYHEllT EMPLOYMENT TO: MICHAEL .1. HAVITSlCY, ESQUIIlE MCS on behalf of J1!;1'1'15K50B .1. SBIPMAB, ESQUIIlE 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: 02/06/2001 MCS on behalf of .ll5l"uK50B.1. SHIPHAII, ESQUIIlE Attorney for DEFEIlDAIIT CC : JEFPERSON .1. SHIPHAII. ESQUIRE - Any questions regarding this matter, contact TBB MCS GROW INC. 1601 MARlET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-144506 5:L5aO-CO~ ", l' .~ ~ ~ .~' '~ COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLA.'iD ANDREW MCKENRICK & JUDY MCKENRICK VS File :-':0.00-5937 CIVIL OPAL & JOHN MASON SUBPOENA TO PRODUCE DOCUMThiS OR THINGS FOR DISCOVERY PURSUA.1\;i TO RULE 4009...22 TO: rTT~'T'()nT AN ()]' RFr.ORDS FOR' THE CALIFORNIA CAFE I (Nam~ of Person or Entity) \-Vithin t"'t"e:'r.!" (10) days after ser.ke of this subpoena, you are ordered by th~ court to produce the following documents or things: SEE ATTACHED at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Addr"'l You may dein..er or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate 0: compliance. to the party making this request at the adclres listed ~bove. You have the right to seek, in adunce. the :..sonabIe cost of preparing the copies or producing the things sought. IE you fail to ;r.oduce the documents or things required by this subpoena.. witl'-.in twenty (20) days after its ser\'ice, the part)' senoing this subpoena may seek a cowt order compelling you to comply Mth r_ THIS SL"BPOENA WAS ISSUED AT THE REQUEST OF TIlE FOLLOWING PERSON: !\AME: TF.FFF.RSON.r. SHIPMAN. ESO. ADDRESS: PO BX 1268 HARRISBURG. PA 17108 TELEPHO!\E= 215-246-0900 SUPREME COURT ID #: ATTORSEY FOR: mn'''NnAN'I' BY TIlE COURT: DATE: rebJ~d. dbol Seal of the Court (:off 7/97) ~ '-'- """ ,," . - <'.' , EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: THE CALIFORNIA CAFE 38 WEST POMFRET STREET CARLISLE, PA 17013 RE: 51580 ANDREW J. MCKENRICK Any and all employment records, files and memorandums, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee. Dates Requested: up to and including the present. Subject: ANDREW J. MCKENRICK 63 WEST POMFRET STREET, CARLISLE, PA Social Security #: 189-52-8666 Date of Birth: 12-23-1961 SUIO-289354 5J...580-L02 ~' " 1'- , ~ ON",,, CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM, -VS- CASE NO: 00-5937 OPAL AND JOHN MASON . As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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: 02/26/2001 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-237499 SlSBO-L03 - -. '-I COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM, -VS- CASE NO: 00-5937 OPAL AND JOHN MASON NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUAN'J! TO RULE 41)09.21 . CARLISLE CONTAIlIER COMPANY THE CALIP01lllIA CAFE CARLISLE CAMP GB.OUHD ALL AMEB.ICAlf FAMILY RESTAURANT EMPLOYMENT EMPLOYMENT EMPLOYMENT EMPLOYMENT TO: MICHAEL J. NAVITSKY, ESQUIRE MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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 retuming sa. to KCS or by contacting our local MCS office. DATE: 02/06/2001 MCS on behalf of J~f'ISKSON J. SHIPMAN, ESQUIRE Attomey for DEPENDANT CC: JEFPERSOJl..1. SHIPMAN, ESQUIRE - Any questions regarding this matter, contact THE KCS GROUP IIIC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-144506 51580-Coi - " ,~ J.lliili. ~"~: COMMONWEALTH OF PENNSYLVANIA - COUNTY OF CUMBERLA.'.'D ANDREW MCKENRICK & JUDY MCKENRICK VS File No. 00-5937 CIVIL OPAL & JOHN MASON SUBPOENA TO PRODUCE DOCUMThlS OR THI~GS FOR DISCOVERY PURSUA.1\,;l TO RULE 4009.21 TO: (,TT~'T'nnT AN n'J:i' R'Rr.nRn~ FOR' CARLISLE CAMP GROUND (Sam~ of Person or Entity) \-\!ithin rwe:"r.)' (::!O) days after sen'ke of this subpoena. you are ordered by the court to produce the following documents or things: SEE ATTACHED al MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Address) You may deihoer 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 h,,'e the right to seek, in advance. the :easonable cost of preparing the copies or producing the things sought. If you fail to ;r.oduce the documents or things required by this subpoena. within twenty (20) days after its service. the party 5eI":ing this subpoena may seek a court order compelling you to comply with r.... THIS SL"BPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: SAME: nU'FRR ~ON .J. SHIPMAN. ESO. ADDRESS: PO BX 1268 HARRISBURG. PA 17108 TELEPHONE: 215-246-0900 SUPREME COlJRT 10 It: AITOR.'\EY FOR: BH'H'H'NnAN'T' BY THE COURT: DATE: r~~nU ;J., ::loo-L Seal of the Court (Eff, 7/97) 'I ." -, '<~ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE CAMP GROUND 1075 HARRISBURG PIKE CARLISLE, PA 17013 RE: 51580 ANDREW J. MCKENRICK Any and all employment records, files and memorandums, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee. Dates Requested: up to and including the present. SU~Kt:ANDREWJ.MCKENmCK 63 WEST POMFRET STREET, CARLISLE, PA Social Security #: 189-52-8666 Date of Birth: 12-23-1961 SUlO-289356 SlSBO-L03 t".. , ' ~- ,,-. ,-. ~..i;eJ CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM, -VS- CASE NO: 00-5937 OPAL AND JOHN MASON As a prerequisite to service of a subpeena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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: 02/26/2001 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-237500 5J..580-L04 ,- , . ~ ~ ,. , ", , ",,,"~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM, -VS- CASE NO: 00-5937 OPAL AND JOHN MASON NO'l'ICB OF b'J:ISN'l' TO SERVE A SUBPOENA, TO PRODUCE DOCUMBN'l'S AIm THINGS FOR DISCOVERY PURSUAR'r TO RULE 4009.21 . CAllLISLE CON'l'AIlIEll. COMPANY THE CALIFOllBIA CAFE CAllLISLE CAMP GROmm ALL AMElUCAR FAMILY RESTAUlWft EMPLOYIiIDT EMPLOYMERT EMPLOYMERT EMPLOYMERT TO: MICHAEL .1. HAVITSKY, ESQUIRE MCS on behalf of JEl'l'lSKSOM .1. SHIPMAN, ESQUIRE 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 retuming same to MCS or by contacting our local HCS office. DATE: 0210612001 HCS on behalf of JlS1'l'lSKSQH .1. SHIPMAN, ESQUIRE Attomey for DEFEHDAIlT CC: .1EFFERSOII.J. SHIPMAN, ESQUIRE - Any questions regarding this matter, contact THE MCS GROUP IlIC. 1601 MARKET STREET '800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-144506 S:Lsao-coi "' .-, ,-, J~~," '" COMMONWEALTH OF PENNSYLVANIA . COUNTY OF CUMBERL.-\..'\'D ANDREW MCKENRICK & JUDY MCKENRICK VS File No.00-5937 CIVIL OPAL & JOHN MASON SUBPOENA TO PRODUCE DOCUMThiS OR THINGS FOR DISCOVERY PURsUA."oi TO RULE 4009.22 TO: Cl1~'1'(\T\TUl (\11 Rl1rmm~ 1111R" AU. AMERICAN FAMILY RESTAURANT (N.me of Person or Entity) \o\~ithin rwt~. (10) days after service of this subpoena, you are ordered by th~ court to produce the following documents or things: SEE ATTACHED at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Adar.ss) You may deij,..,. or mail iegible copies of the documents or produce things re<!"ested by this subpoena. together with the certificate of compliance, to the party making this request at the ad~ listed above. You h,,'e the right to seek. in ad,'ance. the ",..onable cost of preparing the copies or producing the things sought. II you fail to ,-oduce the documents or things required by this subpoena. within twenty (20) da)'s after its service, the party senoing this st.:.bpoena may seek a court order compelling you to comply with r_ THIS SLllPOE.~A WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: SAME: 1EFFERSON J. SHIPMAN. ESO. ADDRESS: PO BX 1268 HARRISBURG. PA 17108 TELEPHOSE: 215-246-0900 SUPREME COURT 10 It: AITOR..'\Ff FOR.: T'llt'........T\ffiA1\TT BY THE COURT: Depury DATE: orJn~'(lJ.Ad- dl ()()f) { Seal of the Court (::if. 7/97) "r. ,; " . " - ,," " ,.."'~ EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ALL AMERICAN FAMILY RESTAURANT 1201 HARRISBURG PIKE CARLISLE, P A 17013 RE: 51580 ANDREW J. MCKENRICK Any and all employment records, files and memorandums, compensation, time and,attendance records, personnel records, payroll and salary reports and all medical records as an employee. Dates Requested: up to and including the present. Subject: ANDREW J. MCKENRICK 63 WEST POMFRET STREET, CARLISLE, PA Social Security #: 189-52-8666 Date of Birth: 12-23-1961 SUIO-289358 SlsaO-L04 ~'li<I~~~hlliili,\,"",b'lt,iiiM!!"..ili:ilI:i<l;;k~il!&~~-"':I'i""l;t';i.4"'''',,~;~);Io,,),J'''''"''-t'''i-'''~Yli~,*q,~Ji!l!illlll'lilfi;!1 r,-'r 'ilI~~~- ~, , ~-_. .- . ~ an.': " Ii".., ~:- If ~:< '~: i-;; ~~ .!i I:; I' i Ii. Ii ,:! I', ~: I Ii 0 -:-~.i ,-, '..' C- -n -::0"- -'-~ :~,. ~ " - ,) L: -, , r::: . ..:..-~- ,'--, 2: , . ):> .-." ~~~ ;t, '.,,", ~i.3 =< ( ,~ -~ "'-, -'","",,,,'-- I. ' :.,,;,.,,-~ ANDREW MCKENRICK and JUDY MCKENRICK, his wife, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA v, : NO, 00-5937 Civil Term OPAL AND JOHN MASON, Defendants : CIVIL ACTION. LAW : JURY TRIAL DEMANDED Praecipe to Withdraw Please withdraw the appearance of Michael J, Navitsky with the iaw firm of Angino & Rovner, P.C., 4503 North Front Street, Harrisburg, PA 17110 on behalf of the Plaintiffs, Mic J. I.D. No, 58 0 Angino & R ner, P,C. 4503 North Front Street Harrisburg, PA 17110 (717) 238-6791 Entry of Appearance Please enter Michael J, Navitsky with the law firm of Navitsky, Olson & Wisneski LLP, 2040 Linglestown Road, Suite 303, Harrisburg, PA 17110 on behalf of the Plaintiffs. Respectfully Submitted, Na itsky, Olson & Wisneski LP Dated: 3jJj M Micha I J, N I.D. No. 5880 2040 Linglestown Road, Suite 03 Harrisburg, PA 17110 (717) 541-9205 Counsel for Plaintiffs ,I il . '" ~'" -~. _.~ , ' -, ~ . CERTIFICATE OF SERVICE I, Jessie K. Walsh, legal secretary with the law firm of Navitsky, Olson & Wisneski LLP, do hereby certify that I am this day serving a true and correct copy of the Praecipe to Withdraw/Entry of Appearance upon all counsel of record via postage prepaid, first class United States mail addressed as follows: Jefferson J. Shipman, Esquire Goldberg, Katzman & Shipman, P,C, 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Counsel for Defendants Dated:3-d-O\ '--- ~-XW~ Jessie K, Walsh il U sw.'" _-i-"'~,f,,,~.";,.,.-<, mdif"'''''"''~' _co: bii:1i:l.i:lL:a~Lll,it!~,jj!imi:.~Il~;,1~ ;"j"'.Jcij-' .- ;gi- ' ;-::--' 'j .i r:-: ~~_ ~:::' ~~h~:' -" ~-2 -' ~,. '0 I> r, !, I , :"", (;0 ,:,;' ! . I i u: r I: )<i::' ~; f;: ,-~- 1'- f!! ~r !' ,,' f' ,';j F ~: i:' r ';1 ,1 I' ~'l " I j I , J ] , II ! ! I i\) :n 1'>-...) LC' ~:'J] -< ." ..,. ~ CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA 'PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM, -vs- CASE NO: 00-5937 OPAL AND JOHN MASON As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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: OS/24/2001 CS on behal~)f il ~ , ERSON ~ Attorney for DEFENDANT DEll-254939 515S0-L14 ; COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM, -VS- CASE NO: 00-5937 OPAL AND JOHN MASON NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ROSS'S STORES, INC. EMPLOYMENT TO: MICaAEL J. IIAVITSKY, ESQUIRE KeS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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 yourerpense by completing the attached counsel card and returning same to KeS or by contacting our local KeS office. DATE: 05/04/2001 KeS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFEIIlli\NT CC: JEFFERSON J. SHIPMAN, ESQUIRE - Any questions regarding this matter, contact THE KeS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-152104 51580-C01 ,"' ~ ~ .' ,. ~ - ~', ,r COMMONVVEAL TH OF PENN5Yt. VANIA :. COUNTI' OF CUMBERLA_'m ANDREW MCKENRICK & JUDY MCKENRICK VS File So. 00-<;'1,7 r.TVIL OPAL & JOHN MASSON SUBPOENA TO PRODUCE DOCUME\-rS OR THI~GS FOR DISCOVE!RY PURSUA.1\"T TO RULE 4009.21 TO: CUSTODIAN OF RECORDS FOR: ROSS'S STORES, INC. (S.l.me of Penon ot ::uirr) Within rwe~' (10) days Uter sOl'\'i.. of this subp"''''', you .... orderlO<! by the c:a..rt to prod.... the following do.umonts or 'hings;SEE ATTACHED 01 MCS GROUP INC., 1601 MARKET ST., #800, PHlLA.PA 19103 (Addteosl You may d.ih'" or maill.gibl. .opies of the doc:uments or produ.. thin9 reqaest.d by this s..bpoena, ,oge"o, w,th the ,ertifiute 0: ,ompli.an... to the porty mwng this r.qu.st at the address IistIO<! abov.. You h.a\'. th. right to so... ,n ad,"."... th. ,..sonoble .ost of pr.paring the .opies or produdng the things _ghl. If you fail to ;>:,aduc. the doc:um.nts or things r.quir.d by this subpoena. within tw.nty (:!O) da~'s uter ilS so'" "0, "0 ?0fT'" sorving this s"~po.n.a may s..k a COlltl order compeUing yo.. to .omply with i"_ THIS St'"BPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSO~: SAME: . JEFFERSON .J. SHIPMAN. ESOUIRE ADDRESS: PO BX 1268 HARRISBURG, PA 17108 TElEPHOSE: ?\ ~_?h.,,_nQnn SlJPREME COll1tT 10 I: ATIOR.-;n FOR: m:F1':NnAN'1' DATE: (Yl;::;y I .;try') J Seal of the Court . "~ r EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ROSS'S STORES,INC. 1707 SHEAR DR. CARLISLE, P A 17013 RE: 51580 ANDREWJ.MCKENIDCK Any and all employment records, files and memorandums, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee. Dates Requested: up to and including the present. Subject: ANDREW J. MCKENRICK 63 WEST POMFRET STREET, CARLISLE, PA Social Security #: 189-52-8666 Date of Birth: 12-23-1961 SUIO-304166 51580 -L14 - I - ", ,-., ~YiiiiI&~~~~iv'<'1';;':sfuFdi"__~Wil&/,r;,,,g~"']-"'ff' ., 0__' , ,_~_ _ ~"Iii'" ~ ,~""-- -l!i.~'.&ll If' f$~~-_ .-c ~-- ~t.' c 2'.: :::< " o c ~""" C':.. -..,," ~) u:; t,l c":' "'\) (-0 ..,,-~ " , -, i~~ :0 -< Ii " , ;J :f \i ~ ~' f ~: I I [ " , '-'-'~ , "".'_"~," Co" ',". """"'0<' ."._'_~,' ~._ ,'~" "", .. -,-' >~ ':""-_:'-~',<>-, ",- -." "e.,";:, . , Jefferson J, Shipman, Esquire I.V, #51785 GOLDBERG, KATZMAN & SHIPMAN, P.e. 320 Market Street P,O, Box 1268 Harrisburg. PA 17108-1268 (717) 234-4161 Attorneys for Defendants ANDREW MCKENRICK and JUDY MCKENRICK, his wife Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYL VANIA v, NO, 2336-3-99- 00-593+ "';v,\ CIVIL ACTION - LAW OPAL and JOHN MASON Defendants JURY TRIAL DEMANDED CERTIFICATE PREREOUISlTE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009,22, Defendant hereby certifies that: (I) A Notice Of Intent To Serve A Subpoena, with a copy of the subpoena attached thereto, was mailed, via Certified Mail, or delivered to each party at least twenty days prior to the date on which the subpoena was sought to be served; (2) A copy ofthe Notice OfIntent, including the proposed subpoena, are attached to this Certificate; (3) No objection to the subpoena has been received; and (4) The subpoena to be served is identical to the subpoena attached to the Notice Of Intent, -~, - '"' -__ -,,,-0\, ,-~ _"'",-'-[ "', ;-""--,__'_' <_ ,~ . ',-- , ,"-,,'-, , -..~:~' , CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all counsel of record by depositing the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, on the 1(.1" day of JU- {V J ,2001, addressed as follows: Michael 1. Navitsky, Esquire 2040 Linglestown Road, Suite 303 Hatrisburg, PA 17110 RG, KATZMAN & SHIPMAN, P.e. By Jefferson 1. Shipman, Esquire LD, #51785 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Counsel for Defendants \ -,,- ----"--,~"- , _, c <;;) GOLDBERG KATZMAN & SHIPMAN By Date: '7/1&/01 Jeffe on 1. Shipman, Esquire LD. No. 51785 320 Market Street P.O. Box 1268 Harrisburg, P A 171 08 Attorneys for Defendants ,-~ " i co, "~, - -. ~~ Jefferson J. Shipman, Esquire I.D. #51785 GOLDBERG, KATZMAN & SIllPMAN, P.e. 320 Market Street P.O. Box 1268 Harrisburg, P A 17108-1268 (117) 234-4161 Attorneys for Defendants ANDREW MCKENRICK and JUDY MCKENRICK. his wife Plaintiffs IN THE COURT OF COMMON PLEAS CillvlBERLAND COUNTY PENNSYLVANIA v. NO. 00-5937 OPAL and JOHN MASON Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 To: Plaintiffs and their Attorney, Michael 1. Navitsky, Esquire 2040 Linglestown Road, Suite 303 Harrisburg, P A 17110 PLEASE TAKE NOTICE that Defendants intend 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. - , By Date: to /,~frr 0 I _"~, M_ - ti>1 Jefferson 1. Shipman, Esquire. I.D. No. 51785 320 Market Street P.O. Box 1268 Harrisburg, P A 171 08 Attorney for Defendants ~'-' -~~.. " CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all counsel of record by depositing the same in the United States Mail, certified, --,-+~ postage prepaid, at Harrisburg, Pennsylvania, on the <I 6 day of J UV1 '< .2001, addressed as follows: Michael J. Navitsky, Esquire 2040 Linglestown Road, Suite 303 Harrisburg, P A 17110 By Jefferson 1. Shipman, Esquire I.D, #51785 320 Market Street P.O, Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Counsel for Defendants ~... - ~"- - , <nMJtlWElILTH OF PEl'lNSYLVANlA COONl'Y' OF CUMBERLAND Andrew McKenrick and Judy McKenrick Plaintiffs File No. 00-5937 Opal and John Mason Defendants SUBPOENA TO PRCOJeE DOCt.tENTS OR 1H I NGS FOR 0 I SCOVERY PURSUANT TO RULE 4009.22 TO: Orthopedic Associates (Nane of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by t.'1e COUI-t to produce the following docunents or things: Any and all medical records, correspondence reports and diagnostic tests, including physical therapy reports, x-ray reports relating to the care or treatment of Andrew J. McKenrick SS# 189~52-8666 D.O.B. 12/23/61 at 320 Market Street, , P.O. Box 1268, Harrisburg, PA 17108-1268 (Address) You may deliver or mail legible copies of the docunents or produce things requested by this subpoena, together with the certificate of carpliance, to the party making this request at the addr<>.ss listed above. You have the right to seel< in advance the reasonable cost of preparing the copies or producing the things sought. 1 f you fai I to produce the docunents or things required by this subpoen'9. within twenty (20) days after its service, the party serving this subpoena rray seek a court order "elling you to carply with it. IS SUBPOENA WAS ISSUED AT 1HE REQUEST OF 1HE FOLLOH1NG PERSON: : Jefferson J. Shipman, Esquire ESS:]20 Market Street, P.O. Box 1268 Harrisburg,_ PA 17108-1268 LEPHQNE: (717) 234-4161 REi"E COlm' 10 # 51785 TTORNEY FOR: Defendants ATE:_...J/I . )1' Seal of :J() ::J.(y)/ the eo&.-t Pro .dO/n f) tary/Cl ivi I Division [)~r- Deputy '---- (eff. 1/91) . , ..,,,,' c,__ -~" ..~ . - ~"""""-""t"""~'~~!!i'''''''lli"~~",,,1ia~,,,-jl[' ~ti~-'~ U ;," - ~ ,,'.... "",,-~~ "-..i.o n ",' ~ ,- 0 ,"'j ~, ''(J L__ j-,' ,- -;; .._,;~ -. - , C) '--.,; -' , , '-' ..-'""' C ~ '.-j J.:' C~ " J ~,-- ;0 ::! - ( "".' " - (,:1 II I , I: II. I 1"1 I: I r -. "Mi ANDREW MCKENRICK and JUDY MCKENRICK, his wife, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00 - 5937 Civil Term V. : CIVIL ACTION - LAW OPAL AND JOHN MASON Defendants : JURY TRIAL DEMANDED ORIGINAL PRAECIPE TO DISCONTINUE Please mark the above matter settled, ended, and discontinued. Respectfully submitted, NA VITSKY, OLSON D"", ~ 13\ cW J- avitsky, J.D. No. 803 2040 Linglestown Road, uite 303 Harrisburg, PA 17110 717/541-9205 Counsel for Plaintiffs ~ ~:....... " .;"0'",",-' , iIiiillf' ,,-[.~ '~ CERTIFICATE OF SERVICE I, Jessie K. Walsh, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of Plaintiffs' Praecipe to Discontinue upon all counsel of record via postage prepaid first class United States mail addressed as follows: Jefferson J. Shipman, Esquire Goldberg, Katzman & Shipman, P.C. 320 Market Street P.O. Box 1268 Harrisburg, P A 171 08-1268 ""-... 1~/1~01(cJ~ Jessie K. Walsh Date~-(~:J-- 11 Ii -'!'.:~!lil!li~~M~.~ - ~"'J, 0 '- -> '"'.~" ~=~;";,,,,,,,~,~tW.'1!'i1!~I\;j~~~~"- "';";'I/jjfii.i ",,~" ,~, - " "" L--- h- ~'.I1! ii. "I I'. Iii ;::1 ~:1 (') Cl q C h) .- ~ "f) f;-D .. J , III 1 , ::'J I ""!~ ;;; " , ~~-. ,"7'1 (~;5 C'"'; ;'.:) " :~:. () r:-:: C~" .:c- -C -H <; , ' :';~ ('~ :<.:':;: , J> ".,_: :') I " c::: '..J ;-:::: :,n ~~~ =< . ..J ..v -< 'I ;'1 fl II II 1.','.'1 ! II 1,:1 II II I :1 II 'i II II Ii il I] I".'i ,I II II II i;1 I I - ",-" i!TlwIitil - ~"l- CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM, -VS- CASE NO: 00-5937 OPAL AND JOHN MASON As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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: 05/15/2001 o behnf:!- Jl. ' ERSON~~UIRE Attorney for DEFENDANT DEll-252719 51580-LOS . " - .~, -, i_ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM, -VS- CASE NO: 00-5937 OPAL AND JOHN MASON NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUAN'l' TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: MICHAEL J. NAVITSKY, ESQUIRE KCS on belul1f of JEFFERSON J. SHIPMAN, ESQUIRE intends to serve a subpoena identical ~o the one that is attached to this notice. You have twenty (20) days from ~he 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: 04/25/2001 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT CC: JEFFERSON J. SHIPMAN, ESQUIRE - Any questions regarding this matter, contact THE KCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-151203 515BO-CO 1 ~- ~ 0-"' >>> LOCATION LIST <<< RECORDS REQUESTED MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL EMPLOYMENT EMPLOYMENT MEDICAL " ~ --I ~ ~ , ~'''~:''-'~iirl PAGE: 1 LOCATION NAME CARLISLE HOSPITAL CARLISLE HOSPITAL PAIN CLINIC MILTON HERSHEY MEDICAL CENTER DR. DAVID BAKER ALEXANDER SPRING REHAB, INC. HAROLD G. KRETZING, M.D. CALAHAN'S LAWN SERVICE HOFFMAN MILLS, INC. CHAHBERSBURG HOSPITAL DE02-151203 SlSaO-COl - ., .~~<l.' ~ It COMMONWEALTH OF PENNSYlVANIA , COUNTY OF CUMaERL"-'lD ANDREW MCKENRICK & JUDY MCKENRICK VS _ File So. 00-5937 CIVIL OPAL & JOHN MASON SUBPOENA TO PRODUCE DOC1JMEl."TS OR THINGS FOR DISCOVERY PURSUA.""TTO RtllE4009.22 TO: CUSTODIAN OF RECORDS FOR: CARLISLE HOSPITAL ['am. o( PftWft or End'!) Within rw''''Y (:!OJ d.ys oit.r service of this subpoe.... you on ordered by dle court to produce th. following docum.nts or thinss: ~FV. ATTArRlm ., MCS GROUP INC. 1601 MARKET STREET SUITE 800 PHILADELPHIA PA 19103, (,~-, You m.y d.iiv.. or moil I.gibl. copies of th. doculMtltl Of produc. t/Unp req..ested by this subpoena. together with the certificate at <ompli...... ro the pony aWc.ing this req_ Of rile .ddniU listH abov.. You MV' th. right to seek. in .d\,."c.. th. ,,"uon.bl. cost of prep.,;ng the copi" or P<Odud...t~..,. -IhL If you f>ilto ?:,oduc. the docum.nts or things '"<lUll'" .... rttis .ubpoena. witl-Jn tw.nty (:!O) c!.~.. oiter irs s,,,'ice. .n. pony s''''ing litis subpo.n. m.y seek. court order compellll"'" .. <OlIlply with it. THIS SLllPOENA WAS ISSUED ATTHI RtQ\.:Uf OfTH'E FOLLOWING PERSON: SAME: JEFFERSON J. SHIPMAN, ESQl:lll ADDRESS: P.O. BOX 1268 HARRISBURG PA 17 101 TELEPHOS!: (215) 246-0900 St,;PREME COlJllT ID I: ATTOR.'\EY FOIt: TIlE DEFENDANT DATE: 4n'\ ( ;;}< , :l t'Y} J nlj:~~: i!. td~ Prodlon2lirk. Civi . isi.. a fl-....p ?:1,n/J.N' / '- Seal of the Court 'O'f ~'n 1~~ ,,~ . LI ' , ~'" "~: EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE HOSPITAL & HEALTH SERVICES 246 PARKER STREET CARLISLE, PA 17013 RE: 51580 ANDREW J. MCKENRICK Any and all records, correspondence, files and memorandums, handwritten notes, relating to any examination, consultation care or treatment. Dates Requested: up to and including the present. Subject: ANDREW J. MCKENRICK 63 WEST POMFRET STREET, CARLISLE, PA Social Security #: 189-52-8666 Date of Birth: 12-23-1961 5U10-302344 515 a 0 - I.') ", ~~ ._~ ~~. .1 =~, CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM, -VS- CASE NO: 00-5937 OPAL AND JOHN MASON As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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: 05/15/2001 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-252720 SlS80-L06 .- . .' JJ-- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLANO IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM, -VS- CASE NO: 00-5937 OPAL AND JOHN MASON NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: MICHAEL J. HAVITSKY, ESQUIRE KeS on bebalf of JEFFERSON J. SHIPMAN, ESQUIRE 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 KeS or by contacting our local KeS office. DATE: 04/25/2001 KeS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT CC: JEFFERSON J. SHIPMAN, ESQUIRE - Any questions regarding this matter, contact THE KeS GROUP INC. 1601 HARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-151203 515BO-C01 >>> LOCATION LIST <<< RECORDS REQUESTED ~ ~ ., ~ '~'~"".; - PAGE: 1 LOCATION NAME MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL EMPLOYMENT EMPLOYMENT MEDICAL .' CARLISLE HOSPITAL CARLISLE HOSPITAL PAIN CLINIC MILTON IlERSIIEY MEDICAL CENTER DR. DAVID BAKER ALEXANDER SPllIBG REHAB, INC. HAROLD G. KRETZING, M.D. CALAHAN'S LAWN SERVICE HOFFMAN MILLS, INC. CHAMBERSBUllG HOSPITAL DE02-151203 51580-CO 1 - , ~--,-,-~i COMMO~WEAL TH OF PENNSYLVANIA , COUNTYOFCUMBERL~"D ANDREW MCKENRICK & JUDY MCKENRICK VS _ File ~o. 00-5937 CIVIL OPAL & JOHN MASON SUBPOENA TO PRODUCE DOClJMEl.{S OR THI~GS FOR DISCOVERY PURSUA."{ TO RULE 4009.l1 TO: CUSTODIAN OF RECORDS FOR: " CARLISLE HOSPITAL, PAIN CLINIC (!'~. of PtnoII or EDriC!) .....ilhinlW."'Y 1::0) days aher service of this subpoena. you are ordered by the court to produc"th. following docum.nt. or thinss: '~~~ A TT.Ar.Rrn al MCS GROUP INC. 1601 MARKET STllEET SUITE 800 PHILADELPHIA PA 19103, tAd_I You may d.in'" or mull.gible copies of the docu_ Of "..... thinp reqllest.d by thi. .ubpotn.. logtth.. with th. ctlTifiut. a: compli.nce. ro rh. pU1y making thi. 'eq_ at r" a4c1nu lUted above. You M\..th. right to 'tek. in adunce. the '....on.bl. co.t of pr.paring the copi" Of ,.....ucl"lt!l6thinp -shl. If you fail to ;:.oduc. the documents or things ,oqoUrM !tot thi, '..b,..... wit!'.iIt !Wenty 1201 c:.ys ait.r it< ,.'" te., ,h. patty ,.~'in5 tili. Ill~po.n. m.y ...k . cOW'! ord.r compell"'1 ~ to COlIlply with ~ THIS SLllPOENA WAS ISSUED AT THE REQt."ESTOfTHEFOLLOWING PERSON: S ....\tE: JEFFERSON J. SHIPMAN, ESQU 1 II ...DDRESS: P.O. BOX 1268 HARRISBURG PA 17\01 TELEPHOSE: (215) 246-0900 SliPREME COURT ID I: ...rrOR.\;E"!' fOR: THE DEFENDANT DATE: !J:pfl-' l :J 3, J. t"Y) / SuI of the Court ... ~-I "'""~ .- - ~ ~---, Irf: EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE HOSPITAL PAIN CLINIC C/O CARLISLE HOSPITAL 246 PARKER STREET CARLISLE, PA 17013 RE: 51580 ANDREWJ.MCKENmCK Any and all records, correspondence, files and memorandums, handwritten notes, relating to any examination, consultation care or treatment. Dates Requested: up to and including the present. Subject: ANDREW J. MCKENRICK 63 WEST POMFRET STREET, CARLISLE, PA Social Security #: 189-52-8666 Date of Birth: 12-23-1961 SU10-302346 51580 - I.') b - " -,,=,>,' "~ CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM, -VS- CASE NO: 00-5937 OPAL AND JOHN MASON As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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 rec~ived, 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: 05/15/2001 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-252721 51580-L07 COl-1M:ONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OP: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM. -VS- CASE NO: 00-5937 OPAL AND JOHN MASON NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUAlI'l' TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: MICHAEL J. NAVlTSKY. ESQUIRE MCS on behalf of JEFFERSON J. SHIPMAN. ESQUIRE 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: 04/2512001 MCS on behalf of JEFFERSON J. SHIPMAN. ESQUIRE Attorney for DEFENDANT CC: JEFFERSOIf J. SHIPMAN. ESQUIRE - Any question9 regarding this matter, contact THE KCS GROUP IIlC. 1601 MARlET STREET #800 PHILADELPHIA. PA 19103 (215) 246-0900 DE02-151203 SlSaO - co 1 - - . >>> LOCATION LIST <<< RECORDS REQUESTED ~" ~, ~"~~.' - -~ PAGE: 1 LOCATION NAME MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL EMPLOYMENT EMPLOYMENT MEDICAL .' CARLISLE HOSPITAL CARLISLE HOSPITAL PAIN CLINIC HILTON HERSHEY MEDICAL CENTER DR. DAVID IlAKEll ALEXANDER SPRING REHAB, INC. HAROLD G. KRETUNG, M.D. CALAMAN'S LAWN SERVICE HOFl'MAN HILLS, INC. CHAMBERS BURG HOSPITAL DE02-151203 5:1. 5 80 - C 01. - ~1~'< ~ ~ ,,__.J___ ~ ' " " i . -""=- COMMOr-.WEAL TH OF PENNSYLVANIA , COUNTYOFCUMBERL~'iD ANDREW MCKENRICK & JUDY MCKENRICK VS _ File So. 00-5937 CIVIL OPAL & JOHN MASON SUBPOENA TO PRODUCE DOCUMe.-rS OR THINGS FOR DISCOVERY PURSUA.I\'T TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER (S..m. of P.n.n or End".. Withill lWe~'I:01 da,is Uter service of this .ubpoeno. you"", o.dered by tile CQ1Irt to produce the following documents or things: ~"F"F ATTAr.Rlm .t MCS GROUP INC. 1601 MARKET STREET SUITE 800.. PHILADELPHIA PA 19103' t""_1 You may deiiTer 0. mail legible copies of the doculllentS or produce thinp req"...ed by this sub"""n.. togeth., with the '.rtifiClIt 0: compliance. to the pany ",wng this .eq_ at tM a4~ llsteclabave. You have the right to ...k, in ad,.."... the :tlSanable cost of preparing the copies or pra4uci...t~np _gilt. II you fail to ;r.oduce the documents or things .equi.... ... this subpoena. witJo.in ...enIY (:0) ca~'s aftor ill ,,,,'j,.. tn. pany .or,'ins th.is .uopaena may seek a caun order comp.IIl". v.. III comply with it.. THIS St"BPOENA WAS ISSUED AT THE REQl:UT OF TIfE FOLLOWING PERSON: :'\..'M~ JEFFERSON J. SHIPMAN, ESQt:lll ADDRESS: P.O. BOX 1268 HARRISBURG PA 1 J \ 0' TELEPHOS:: (21S) 246-0900 Sl,;PREME COUtrl'ID I: ATTOIL"EY FOR: THE DEFENDANT BY DATE: {J pn \ I ;;} ~ ~nn I , Seal of the Court ~.. ~':l ""-- . "'~.~ ~. , . .... '-' ~ .' EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MILTON HERSHEY MEDICAL CENTER 500 UNIVERSITY DRIVE PO BOX 850 HERSHEY, P A 17033 RE: 51580 ANDREW J. MCKENRICK Any and all records, correspondence, files and memorandums, handwritten notes, relating to any examination, consultation care or treatment. Dates Requested: up to and including the present. Subject: ANDREW J. MCKENRICK 63 WEST POMFRET STREET, CARLISLE, PA Social Security #: 189-52-8666 Date of Birth: 12-23-1961 SUlO-302348 51580-t.()7 - "-." '~ '~ ~ ' ~ "- f ~~ CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM. -VS- CASE NO: 00-5937 OPAL AND JOHN MASON As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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: 05/15/2001 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-252722 515B 0 - LOB ~",",' .~" ~, "~ , '" . COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM, -VS- CASE NO: 00-5937 OPAL AND JOHN MASON NOTICE OF IN'l'EN'l' TO SERVE A SUBPOENA TO PRODUCE DOCUMEN'l'S AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: MICHAEL J. NAVITSKY, ESQUIRE KCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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 KeS or by contacting our local KeS office. DATE: 04/25/2001 KeS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT CC: JEFFERSON J. SHIPMAN, ESQUIRE - Any questions regarding this matter, contact THE KeS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-151203 SlSBO - CO 1 L'"'""".~""~" >>> LOCATION LIST <<< RECORDS REQUESTED MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL EMPLOYMENT EMPLOYMENT MEDICAL .' -~,-' -..- "";, PAGE: 1 LOCATION NAME CARLISLE HqSPITAL CARLISLE HOSPITAL PAIN CLINIC MILTON HERSHEY MEDICAL CENTER DR. DAVID BAKER ALEXAIlDER SPRING REHAB, INC. HAROLD G. KRETZING, M.D. CALAMAN'S LAWN SERVICE HOFPMAII MILLS, INC. CHAMBERS BURG HOSPITAL DE02-151203 S:L 5 a 0 - C 0 ~ , " . ~ """. COMMO!'.WEAL TH OF PENNSYLVANIA . COUNTYOFCUMBERL~~O ANDREW MCKENRICK & JUDY MCKENRICK VS _ File So. 00-5937 CIVIL OPAL & JOHN MASON SUBPOENA TO PRODUCE DO~"'S OR THINGS FOR DISCOVERY PURSUA..""'TO RtJLE4009.2.2 TO: CUSTODIAN OF RECORDS FOR: DAVID C. BAKER, M.D. (S4II'Ie o( P.,... Of' bc:i",. Withi" rw.~. I:!O) days aIt.r service of this subpoena. you... ordered by the <aurt 10 produce Ih. following documenlS or thinSS: ~F.l<' A""Ar.~rn al MCS GROUP INC. 1601 MARKET STREET SUITE 800', PHILADELPHIA PA 19103' 1"4_1 You m.y de;;'.. or maillepble COlties of Ihe docu_ or prMlJO tl\inp req..esttd by this subpoena. together wilh the certificate 0: compli."ce. 10 Ihepll'lY makillg Ihi. roquea at IIle .dclnsa U.eclabove. You Mve Ihe right 10 seek. in od"'n... the ~"oll.ble cost of preparillg the copi" or "odlOCi", l"-'ctIinp _pt. If you (ail 10 ~odu.. Ihe documellls or thillgs required ... this sultpoeN. wit!".in twellty (:0) cays aIt.r it. sor\';ce. the party s,,,'ing this su~poe". may seek. court ord.r compell.." Vft to COlIIply with it. THIS St"BPOENA WAS ISSUED AT THE REQl;tST OF THE fOLLOWING PERSON: ~.,,\{E: JEFFERSON J. SHIPMAN. ESQUIU ....OORES!: P.o. BOX 1268 HARRISBURG FA 17\01 TELEPHOS:: (215) 246-0900 Sl,;PREME COUllT ID I: AITOR.\;EHOR: THE DEFENDANT DATE: {}J'12...\ ( ..:J, ;)..rv~J , ivi,ioll Seal of the Court :.:: ~ 'g~ '". " ~ .~-"~ EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. DAVID BAKER 19 BROOKWOOD AVENUE SUITE #104 CARLISLE, P A 17013 RE: 51580 ANDREWJ.MCKENIDCK Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requcsted: up to and including the present. Subject: ANDREW J. MCKENRICK 63 WEST POMFRET STREET, CARLISLE, PA Social Security #: 189-52-8666 Date of Birth: 12-23-1961 5U10-302350 51580 - [. () >i ~"" CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM, -vs- CASE NO: 00-5937 OPAL AND JOHN MASON As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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: 05/15/2001 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-252723 51580-L09 ,- ' ", ..i.~"~ , ~~. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM, -VS- CASE NO: 00-5937 OPAL AND JOHN MASON NOTICE OF INTEN'l' TO SERVE A SUBPOENA TO PRODUCE DOCUMEN'l'S AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: MICHAEL J. NAVITSKY, ESQUIRE KCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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 tbe undersigned an objection to the subpoena. If the twenty day notice period i. 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 KeS or by contacting our local KeS office. DATE: 04/25/2001 KeS on behalf of JEFFERSON J. SHIPMAJI, ISQUIU At torney for DEFEIIIlAIIT CC: JEFFERSON J. SHIPMAN, ESQUIRE - Any questions regarding this matter, contact THE KeS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA I q I 0 l (215) 246-0900 DE02-15l203 5:1.580 C'" I ............... 'jajio: >>> LOCATION LIST <<< PAGE: 1 RECORDS REQUESTED LOCATION HAME MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL EMPLOYMENT EMPLOYMENT MEDICAL CARLISLE HOSPITAL CARLISLE HOSPITAL PAIN CLINIC HILTON HERSHEY MEDICAL CENTER DR. DAVID BAKER ALEXANDER SPRING REHAB, INC. HAROLD G. KllETZING, H.D. CALAHAN'S LAWN SERVICE HOFFHAII HILLS, INC. CHAMBERSBURG HOSPITAL DE02-151203 5 ~ 5 B 0 - CO 1. ~ '" - .,c-. '" ~ -~ ~ - - ,r, COMMONWEALTH OF PENNsn VANIA , COUNTY OF CUMBERL~-':D ANDREW MCKENRICK & JUDY MCKENRICK VS _ ." File So. 0.0.-5937 CIVIL OPAL & JOHN MASON SUBPOENA TO PRODUCE DOC'UME'o.-rS OR THI~GS FOR DISCOVERY PURSUA.I\"TTO RULE 4009.22 TO: CUSTQDIAN OF RECQRDS FOR: ALEXANDER SPRING REHAB., INC. ('....e o( Penoa or Sat:iry) Within lW'~' (:01 days ailer s.rvice of this subpoeno. you In ord...c by 1M court to produce th. following documents or things: ~F.F. ATTAr.Rrn a' MCS GROUP INC. 160.1 MARKET STREET SUITE 80.0., PHILADELPHIA PA 1910.3 1....-1 You may deii\'1f or mail legible copies of the docu_ or prod.... thinp recr1lested by this subpoeno.logeth.t with Ihe certifi.... rr. compliance. to the porty making this '..._ It tM .d4Jws u.ted, above. You "",'e the right to s..k. in advance. the '1!uonabl. rost of preparing the ropies or produd... t~np _!hI. If you fail III ;rooduc. the documenll or lhings "quit... "" thi. subpoena. ~Jn twenty (:!Ill c!a~'s ailer its ser\'ire. the patty se,,'ing this s....poena may s"k a rourt order rompell.". ~.. Ie COlIlpll" witb it. THIS St."BPOENA WAS ISSUED AT TH~ llQl.'UT OF THE FOLLOWING PERSON: S...Mc ADDRESS: JEFFERSDN J. SHIPMAN. ESQU I U P.o.. BDX 1268 RARRISBUllG PA TELEPHOSE: (215) 246-0.90.0. Sl.:PREME COutrl' ID I: ArrOR.'\Ft. FOR: THE DEFENDANT l71Q4 DATE: {)rti...~( ~ 1- ;:It'''V'.l J I U""~~._ '- L2n~'L P~"'''''''~ Seal of the Court ::f 7.'97") ~~ ~ - n 1 ~, EXPIANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ALEXANDER SPRING REHAB, INC. 27 BROOKWOOD AVENUE CARLISLE, PA 17013 RE: 51580 ANDREW J. MCKENRICK Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: ANDREW J. MCKENRICK 63 WEST POMFRET STREET, CARLISLE, PA Social Security #: 189.52.8666 Date of Birth: 12.23.1961 SUlO-302352 51580 - I. () q '.',...~~ "- ~ ~. 0' ~ V, CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM, -VS- CASE NO: 00-5937 OPAL AND JOHN MASON As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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: 05/15/2001 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEl1-252724515BO-Ll0 =" ~ J-, ,--,,--,,' - ~-, ,~.' I ~- ,=~ ., ~~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM, -VS- CASE NO: 00-5937 OPAL AND JOHN MASON NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUAN'l' TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: MICHAEL J. SAVITSKY, ESQUIRE MCS on behalf of JEFFERSON J. SHIPHAIl, ESQUIU intends to serve a subpoena identical to the one that is attached to thi. 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 .ubpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returnina .... to HCS or by contacting our local MCS office. DATE: 04/25/2001 MCS on behalf of JEFFERSON J. SHIPHAIl, ESQUIRE Attorney for DEFEIlDAIIT CC: JEFFERSON J. SHIPHAIl, ESQUIRE - Any questions regarding this matter. .OOlact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-151203 SlSBO-CO 1 " , '"' -, ,~~~".~ ~l "~ '..lG >>> LOCATION LIST <<< PAGE, 1 RECORDS REQUESTED LOCATION NAME MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL EMPLOYMENT EMPLOYMENT MEDICAL CARLISLE HOSPITAL CARLISLE HOSPITAL PAIN CLINIC MILTON HERSHEY MEDICAL CENTER DR. DAVID BAKER ALEXANDER SPRING REHAB, INC. HAROLD G. KRETZIRG, M.D. CALAKAIf'S LAWN SERVICE HOFFKAR KILLS, INC. CHAKBERSBURG HOSPITAL DE02-151203 515 a () , ( : (I I - ,~ ~ .. , ~ . - ~', '- ~~"""', COMMONWEALTH OF PENNSYlVANIA . COUNTY OF CUMBERL~'\D ANDREW MCKENRICK & JUDY MCKENRICK VS _ ". File So. 00-5937 CIVIL OPAL & JOHN MASON SUBPOENA TO PRODUCE DOCUME.'.1S OR TIiI~GS FOR DISCOVERY PURSUA.I\"T TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: HAROLD G. KRETZING, M.D. (S.m_ of pfl'lOft Of' EftatyJ Within rw''''Y (201 day. oiI.r ..rvic. of this .ubpoe.... you IA ordtr" by the cowt to produce the following document. or things: ~FF ATTArltFn a' MCS GROUP INC. 1601 MARKET STREET SUITE 800. PHILADELPHIA PA 19103. 1"._' You may deih'" or mail I.gible copies of the documtfttl or pnICIuce thlnp requested by thi. .ubpoe.... togeth.r with the c.rtificate 0: compliance, to the pony aWdng thil r..._.. rhe Iddnou u._ above. You /Ianthe right to ...k. in ad" IIlC.. the ,.uombre COlt of preparing the copies or produci"lt~np -pit. If you fail to ?"oduc. rhe documents or things requir'" .... thi..ultpoefta. witt-.1ft twenty (:!OI c!a~'. oiler it. I'''' ice. the parry I''''ing tills lu~poena may seek a cowt order compell.." .... to COll'lply with it. THIS SLllPOENA WAS ISSUED AT THE REQl;tSTOFllfE FOLLOWING PERSON: SAME: JEFFERSON J. SHIPMAN, ESQl:llI ADDRESS: P.O. BOX 1268 HARRISBURG PA 17 lOS TEl.EPHOS!: (21S) 246-0900 SliPREME COU1lft'ID It ATTOR...;EY FOR: THE DEFENDANT . DATE: 4(.1' (_ ,,:)1 ;;)~I . ProtlunlatuylO.... Ci i.i.;aft ~~o_P7z2~~.r Seal of the Court :;; ~9:) ~. ,-- iJfO" ~ ~ -~'""""";"";;"'- EXPlANATION OF REQUIRED RECORDS . TO: CUSTODIAN OF RECORDS FOR: HAROLD G. KRETZING, M.D. BELVEDERE MEDICAL CENTER 850 WALNUT BOITOM RD CARLISLE, PA 17013 RE: 51580 ANDREW J. MCKENRICK Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: np to and including the present. Subject: ANDREW J. MCKENRICK 63 WEST POMFRET STREET, CARLISLE, PA Social Security #: 189-52-8666 Date of Birth: 12-23-1961 5UlO-302354 515 a 0 - I. 1 (I ,=- .. ~ , -~ -"ii!(~( CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM, -vs- CASE NO: 00-5937 OPAL AND JOHN MASON As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009,22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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: 05/15/2001 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-252725 515 a 0 - L 1. 1. .~ " , ., I.', ' ~ , - " - COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM, -VS- CASE NO: 00-5937 OPAL AND JOHN MASON NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: MICHAEL J. HAVITSKY, ESQUIRE MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days fram 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 KCS office. DATE: 04/25/2001 KCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT CC: JEFFERSON J. SHIPMAN, ESQUIRE - Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (2:).5) 246-0900 DE02-151203 SlSaO - CO 1 >>> LOCATION LIST <<< PAGE, 1 RECORDS REQUESTED LOCATION !fAME MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL EMPLOYMENT EMPLOYMENT MEDICAL .' CARLISLE HOSPITAL CARLISLE HOSPITAL PAIN CLINIC MILTON HERSHEY MEDICAL CENTER DR. DAVID BAKER ALEXANDER SPRING REHAB, INC. HAROLD G. KRETZING, H.D. CALAHAN'S LAWN SERVICE HOFFHAN MILLS, INC. CBAHBERSBURG HOSPITAL DE02-151203 Slsao -CO:l. ~~ ',- "~~" -0 ="'~ -; COMMOt'liVVEAL TH OF PENNSYLVANIA , COUNTY OF CUMBERL-\.."D ANDREW MCKENRICK & JUDY MCKENRICK VS File So. 00-5937 CIVIL OPAL & JOHN MASON SUBPOENA TO PRODUCE DOCUMThlS OR THI~GS FOR DISCOVERY PURSUA."l TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: CALAMAN'S LAWN SERVICE (!'.m. Q( Pnwft or Ezu:iry) Within rwe"'Y (;!O) d.ys Ute, service of this subpoen.. you ore ordered by the court to produce the following documents or things: S"R"R AT'TAr.HFn .t MCS GROUP INC. 1601 MARKET STREET SUITE 800 PHILADELPHIA PA 19103, 1"._' You m.y deih'" or mail legible copies of the documenn or prod""ethin9 requested by this subpoena. together with the certifiute 0: <ompHance. to the party mwng this request at t~ .cldross listed above. You ha,'e the right to seek. in .dunce. the ",..on.ble <ost of prepuing the copiet or p"ocIua"lthe things -!ht. If you fail to "oducethe documents or things requir'" bY thi, subpoena. witr.in twenty (;!O) cays after ilS se,,'ice. the party serving this s"bpoen. may snk a court order compdlu., Y'" to (Glllply with it. THIS St"BPOENA WAS ISSUED AT THE REQl:tST Of mE fOLLOWING PERSON: SAME: JEFFERSON J. SHIPMAN, ESQIJ Ill! ADDRESS: P.O. BOX 1268 HARRISBURG PA 17 10S TElEPHOSE: (215) 246-0900 SLJPREME COURT 10 I: ATIOR."E"t" FOR: THE DEFENDANT I DATE: P p~ ,( ...2.">'. ~t"')() I Seal of the Court :.;f 7/9:1 "._~ '--..- """ ~-- ~-!'~ EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CALAMAN'S LAWN SERVICE 456 MT. ROCK RD. NEWVILLE, PA 17241 RE: 51580 ANDREW J. MCKENRICK Any and all employment records, files and memorandums, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee. Dates Requested: up to and including the present. Subject: ANDREW J. MCKENRICK 63 WEST POMFRET STREET, CARLISLE, PA Social Security #: 189-52-8666 Date of Birth: 12-23-1961 SUlO-302356 51580-1.1 L CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM, -VS- CASE NO: 00-5937 OPAL AND JOHN MASON As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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: 05/15/2001 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-252726 51580-L12 , ~.,~" . . -- .""",_. ~."-" ~c ~'~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM, -VS- CASE NO: 00-5937 OPAL AND JOHN MASON NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] ,-.- TO: MICHAEL J. NAVITSKY, ESQUIRE KeS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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 KeS or by contacting our local KCS office. DATE: 04/25/2001 KeS on behalf of .JUl'lSKSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT CC: JEFFERSON J. SHIPMAN, ESQUIRE - Any questions regarding this matter, contact THE KeS Gll.OUP INC. 1601 KARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-151203 SlSaO - CO 1 >>> LOCATION LIST <<< PAGE: 1 RECORDS REQUESTED LOCATION NAME MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL EMPLOYMENT EMPLOYMENT MEDICAL CARLISLE HOSPITAL CARLISLE HOSPITAL PAIN CLINIC HILTON HERSHEY MEDICAL CENTER DR. DAVID IIADR ALEXANDER SPRING REHAB, INC. HAROLD G. KRETZING, M.D. CALAHAN'S LAWN SERVICE HOFPMAN MILLS, INC. CBAMBERSBURG HOSPITAL DE02-151203 51580 -co 1 - .~ i, " ..- .. ~'.> d_~ COMMO/'l4WEAL TH OF PENNSYLVANIA . COUNTYOFCUMBERL-\..'iO ANDREW MCKENRICK & JUDY MCKENRICK VS _ .- File :>;0. 00-5937 CIVIL OPAL & JOHN MASON SUBPOENA TO PRODUCE DOCUM~"'S OR THI:NGS FOR OISCOVERY PURsUA.~"T TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: HOFFMAN MILLS, INC. (!\,une af Pmoft or =:u::i~. Within lWe~- (:0) doy. Uter .ervi.e of thi. .ubp....... YO" ~ ordered by the <OUrt to prod....th. following do.um.nt. or things: ~1<''F. ATT'Ai~lnm II MCS GROUP INC. 1601 MARKET SUE!T SUITE 800 PHILADELPHIA PA 19103 IA.-., You moy d.in'" or maill'gible .opies of the dcxu_ or produce t/Unp "",,,osl.d by lhis ...bpoem. together with th. certificate o! ,ompli.n... to th. pAny lIl&king this rtq.... MIM .ddftu 1dted abov.. Yo.. haveth. right to ...k. in .d\'In". the ~uon.bl. .ost of preparing th. ,opin or produci"ll"-'ttlinp -shL [f you fail to ;r.od....the do<um.nts or things req..ir'" .... lhi....b~ witJo.in tw.nty (:!Ol day. Uter it. ",,'ice. the parry ""'ing thi. "'.po.n. m.y .eek..ourr order 'ompellift, y... to ....ply with it. THIS SCBPOENA WAS ISSUED AT THE REQl:Ur Of THE fOLLOWING PERSON: :-;AME: JEFFERSON J. SHIPMAN. ESQUlIl ...001l65: P.O. BOX 1268 HARRISBURG PA 171 oa TELEPHO:>;!: (215) 246-0900 SlJPREME COt.l1lT ID I: ...rrOR....E.t' FOR: THE DEFENDANT . iJion DATE: (Jp~\ l ..::U ;) rY\ I , Seal of the Court ::::; - 9'1 EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOFFMAN MILLS, INC. 35 SPRINGHOUSE RD. SHIPPENSBURG, PA 17257 RE: 51580 ANDREW J. MCKENRICK Any and all employment records, files and memorandums, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee. Dates Requested: up to and including the present. Subject: ANDREW J. MCKENRICK 63 WEST POMFRET STREET, CARLISLE, PA Social Security #: 189-52-8666 Date of Birth: 12-23-1961 SUlO-302358 51580 - I, I .' CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM, -VS- CASE NO: 00-5937 OPAL AND JOHN MASON As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.Z2 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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, (Z) 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: 05/15/Z001 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-252727 SlSaO-L13 """<-. o ,,' ..~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS ANDREW AND JUDY MCKENRICK TERM, -VS- CASE NO: 00-5937 OPAL AND JOHN MASON NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUAN'l' TO RULE 4009.21 Note: see enclosed list of locations ] TO: MICHAEL J. NAVITSKY, ESQUIRE HCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed'belov 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 retuming same to HCS or by contacting our local HCS office. DATE: 04/25/2001 KCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attomey for DEFENDANT CC: JEFFERSON J. SHIPMAN, ESQUIRE - Any questions regarding this matter, contact THE KCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-151203 s~sao-CO L , . ~ ". >>> LOCATION LIST <<< PAGE: 1 RECORDS REQUESTED LOCATION NAME MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL EMPLOYMENT EMPLOYMENT MEDICAL CARLISLE HQSPITAL CARLISLE HOSPITAL PAIN CLINIC MILTON HERSHEY MEDICAL CENTER DR. DAVID BAKER ALEXANDER SPRING REHAB, INC. HAROLD G. KRETZING, M.D. CALAMAH'S LAWN SERVICE HOFPMAH MILLS, INC. CHAHBERSBURG HOSPITAL DE02-151203 S:L 5 a 0 - C 0 ~ ,. - .~ ~~ - ',", -t!..u:.~h~, COMMOr--WEAL 1M OF PENNSYlVANIA . COUNT(OFCUMBERLA.'iD ANDREW MCKENRICK & JUDY MCKENRICK " VS _ File So. 00-5937 CIVIL OPAL & JOHN MASON SUBPOENA TO PRODUCE DOOJMEo..-rS OR THINGS FOR OISCOVERY PURSUA.,,-r TO RULE 4009..22 TO: CUSTODIAN OF RECORDS FOR: CHAMBERS BURG HOSPITAL (S 61!1. of Ptnoll or ::n:iryt \\'ithin rwe~' (:!OJ dlYs Uter service of this subpoena. you on ordered by the C'llUrt to produce the fallowing documents or things: ~"Fl<' A'M'A.c.l-t'Fn II MCS GROUP INC. 1601 MARKET STREET SUITE 800' PHILADELPHIA PA 19103' (A-I You mlY deu..er or mail legibl. copies of th. dacu",efttS or pracluc.thinp reqllest.d by this subpoena. tagelher with ,h. <frtifiul. ai rampUlnct. to th. party IIlwng this requftt...he Idclreu lilted abov.. You have the right 10 se.1<. in Idnnce.tht ,"uonlble cast of pr.paringth. capi" or produci"'l~ _ghL Ii ~'au fail to ;::-aduCt the docum.nts or things requirtfl "" INS ...b,..... witt'..in ...onry (20) cays ,Uter i,s se,,'ire. 'he patry ,,"'ing 'NS su:.paona "'"Y seek I court ard.r campeU.", rOll 10 co..ply with 1'_ THIS St"BPOENA WAS ISsum AT THE REQ":tSTOFTHEFOtLOWlNG PERSON: S "ME: JEFFERSON J. SHIPMAN. ESQ\Jt U ADDRESS: P.O. BOX 1268 HARRISBURG PA l7 108 TeLEPHOS:: (2IS) 246-0900 SliPREME COtjllT ID t: ...nOR....EY FOR: THE DEFENDANT DAre: IJF( .J.? ~Ot') \ I IYreE,2~..;_ ..a~ f) J:J ~~~ Seal of the Court -" ;,",'9~ - '" n EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CHAMBERSBURG HOSPITAL 112 NORTH SEVENTH ST. CHAMBERSBURG, PA 17201 RE: 51580 ANDREW J. MCKENRICK Any and all records, correspondence, files and memorandums, handwritten notes, relating to any examination, consultation care or treatment. Dates Requested: up to and including the present. Subject: ANDREW J. MCKENRICK 63 WEST POMFRET STREET, CARLISLE, PA Social Security #: 189-52-8666 Date of Birth: 12-23-1961 5U10-302360 51580-1.1 \ ~Jai1~(! '''-'<OJ ~~,.,,~~m,,-ef;,11t;lli'Ii.<",:S!,;;~~,i@;~~~llIil_~IliIMii<<lii'ffi "C._~1Iid3' I ~, > (") 0 q C <- c.: ! ---i [~ < ((; OJ :--1 ~ S ,- () <c_' ) < >- , il .. <~ ~"-- :'1 =< ::0 {~ -< >:i