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Home My WebLink About00-08527 .. 'L' I ' ~~ . 0" ,. . j n..:J.tJi~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRACY A. RAINELLI, Plaintiff vs. No. ~- J'5;;L'7~-r~ ELWOODC. STALEY, Defendant. CIVIL ACTION - LAW PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Please enter my appearance as attorney of record for the above-named Plaintiff, Tracy A. Rainelli. Please issue a summons in civil action in the above-captioned matter against the above-named Defendant, Elwood C. Staley, whose last known address was 107 Old York Road, New Cumberland, Cumberland County, Pennsylvania 17070. Service of all future pleadings may be had through Plaintiffs counsel at his address 0004 Union Street, Hollidaysburg, PA 16648. -".j ;f~ Richard A. Consiglio, Esq. Atty. for Plaintiff Pa. I.D. # 06669 304 Union Street Hollidaysburg, P A 16648 (814) 696-4347 Dated: I~ - fj--Od -'"," ,. ..~ ,," 1.:.",'",-.., JiIiL"~ ''''-~iIii ~f -< ~ '-.l J'~""""~~li!O~l1<iiI,"-~~I!li1;i;i ...i~ ~,..."" r ,lTnUIl_ __,..en ~,'_""'_..,.,W'~"f"H"__'_~" M __ ~"_,,,O_-'_"'-~~"', I, > ",;, ""..;",~". --~ Mfm_~"""_~~-r ~e .,; (') CI ()- C c:::> ""n s: cJ ~ "0\'0 ';""?1 ..;,~~ ~!T; :-) h .-C '7 zc;:;: - Cf) ~,-~ C:j "< ""- kG ~ (~:j~ ?2:0 Z.?n -0 ? 0 )>c 35 ~ "" .- -< "} t ~ 0 0 f c: '''fI s: .,-' ~, -Om "'-! Z ~ ~ Ze. (J),!.:; \2)) -<L !<o i ~ (') )>0 '2 c: z w =< f~ ~ ~ fi .. ..c. .. ~ ~ c5- 'e e v- ol t' r ~ ~" , . ..I " '" l ~"'" ' "" .' L---"-.' '4.'_'~ Commonwealth of PelU1sylvania County of Cumberland Tracy A. Rainelli Court of Common Pleas VB. No. _Q~L-:~~'!Ll___c,;j-'LLL'l:.exl])_________ 19____ Elwood C. Staley 107 Old York Road New Cumberland, Pa. 17070 In _~~}C!__~~_tj_QD__LliW______________________ To~_l~9_Q9__C_~_lit<>-lfL~______________________ You are hereby notified that ____~~~f~__~,__BliiD_~l_ljL____________________.________________________________________________ the Plaintiff ha S eommeneed an aetion in _____~~.yAL_1;,A~______________________________________ against you whieh you are required to defend or a default judgment may be entered against you. (SEAL) .cCllrJliEL_flL_~OJlg--------------------------- Prothonotary Da~e_~~~g5'_~__n____LQ.9_L____ XllL__ r'"'1. _ . - By __~~~~~~~q~~-:------------------. Deputy ~;;,i,i.<,,-,~,,:;,.,-.,I~,-,"-h~" 'iiill~m,,' 'l!lr-' .L'''~MJ'~G+,-''-@;~"t:~,';.-*.l'''I4)",;;~'';\;l'iiI~...i;j;rW_,iJ ,'ti" 'lhll!lllfili!8~wii~i':wlI' ~ .iili,jiil!l..~'" ~ , '~'1l'''dd!JL ,~,' "__~_,,,,",,,.~~-..k,j , , Z f-'t'l >-3 ~ , :I: w,; , roOf-' 'i I 00 0 a\-'. In '" ->'" III I I f-' f-' "'0 ,\-'. 0 0 , '" \-'. ::T k noo '<: , , P,C::1ll ,\-'. >::f-'p' , 0> ::l 'i If-' 3 P, :J:> , , 0-, '<: \-'. P, , r 0' n , '" rn 0 f:J:> ro '<: , I 0-, 0'::l:J:> In '1 0 ,; >, , " :c+ f-''i [J'J 0> S '" '1 [Jl ,\-'. III "" c+ \-'. w to c+ n '0 ::l III ~ :l j '" 'i 0 l::l i P,';f-' ro -> ro ::l , o ro f-' "tj ro rn 't""' Ill'<: f-' III rt \-'. :0> S' "tjp' \-'. to :'" 0> f-' , f-' \-'. , 0-, 0 , f-' I 0-, , ..., - '" , 0 l" , 00 t'l , -> I rn 1 0 I ,Q , , "L ~LL ,_.L:rLJJ~~ __ _ J5}! __ ., ,'~~,_ " , ,"..\,," , -- ~ ", ~, ~ ~" " ~ . --;_ill'..-I~~ SHERIFF'S RETURN - OUT OF COUNTY '. CASE NO: 2000-08527 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND RAINELLI TRACY A VS STALEY ELWOOD C R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: STALEY ELWOOD C but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania, to serve the within WRIT OF SUMMONS On January 16th , 2001 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing Out of County Surcharge DEP. YORK COUNTY 18.00 9.00 10.00 44.84 .00 81.84 01/16/2001 RICHARD A. Z~~ . - Thomas Kl ine ~... Sheriff of Cumberland County CONSIGLIO Sworn and subscribed to before me ''f~ rJ this "" day or.\..~.",,-,-, "7 dJrtJ I A.D. Q'f'L () )u,,pd. - ~ Prothonotary' _ l ""'.h..",,,;.",~""""<<@~'''''''','mlli_~" J -w=~___..w.;,-~",,",,:,,;, ,'._' -,,,j, ""-,~""'~"""",,,,,,,",,,,,,,",,,,"",,,,,,-~-,,,,,..,",,,...-",..,,..,, ""_,,,,"h,, J."""-,",^<4,_""""",..J.J"",,,',J-o" ,.",-""""""_;..~_"""<l",~\,,,.."'~;_~~ffiffi;I!'i!~_L___""""""'-",_:-ili.\i-.'!:' COUNTY OF YORK OFF1feE OF THE SHERIFF SERVICE CALL (717) 771-9601 28 EAST MARKET ST., YORK, PA 17401 SHERIFFSERy,ICE PROCESS RECEIPT, and Af'FtDAVIT OF RETURN ,. PLAINTlFF/SI Tracy Rainellj 3. DEFENDANT/SI Elwood Stale Writ of Summons { 5. NAME OF INDIVIDUAL COMPANY. CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, DR SOLD. Elwood C. Stalev 6. ADDRESS (STREET OR RFO WITH BOX NUMBER, APT. NO., CITY, BORO, TWP., STATE AND ZIP CODE '-0+- /6J.. 7. INDICATE SERVICE: 0 PERSONAL 0 PERSON IN CHARGE DEPUTIZECUm~Hi!l1I'/~ 0 1ST CLASS MAIL NOW 1 1 11 1 I nf\ , 20 _ I, SHERIFF OF ~~9ij2PA,do here v<u:\< . . COUNTYtoe~~k to law. I nls deputation being made at the request and risk of the plaintiff. '(';" "'" . . SHERI F OFV_~OUNTY 4. TYPE OF WRIT OR COMPLAINT SERVE .. AT o POSTED 0 OTHER tize the sheriff of Of according 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: Cumberland OUT OE:COUNTY CUMBERLAND ADVANCED FEE PAID BY SHERIFF . NOTE ONLY APPLlCAt3LE ON WRIT OF EXECUTION: N.S. WAIVER OF WATCHMAN. Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriff's sale thereof. 9. TYPE NAME AND ADDRESS of ATTORNEY I ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER 11. DATE FILED RICHARD A. CONSIGLIO, ESQ. 304 UNION ST. HOLIDAYSBURG, PA 16648 814-696-4347 12-11-00 12. SEND NOTICE OF SERVICE COPY NAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed). CUMBERLAND CO. SHERIFF .if 15. ExpirationlHearing Date 1~10"OO 16. HOW SERVED: PERSONAL RESIDENCE ( ) POSTED ( ) POEt ) OTHER ( SEE REMARKS 17.0 I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, etc. named above. (See remarks below.) 8. AME NO TITLE OF INDIVIDUAL SERVED I LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 19. Date of Service r~(/I f'" ~ I' 01 eck No. %! "'>, ~--,,--.,.-,,, 44. Signature of ..... /I _ Dep. Sheriff '}' V-- 45. Signa1ure o. rk A C TI N G County Sh OR ~mUAM M. 46. Signature of Foreign County Sheriff GNATURE 1-11-01 41. AFFIRMED and SUb$Cribe~;to b7~~~~me'~_~~.~;~,,;. 1 J. 42. day of 49. DATE 1. WHITE ~ Issuing AuthOrity 2. PINK- Attorney 4. BLUE - Sheriff's Office , f_ ,}:. ", -: :,2- );,:,,- .;j~i::,;;;,:i,t~?j~!:.~:-t:~ftf;;2?;;&;:;;':-:i{$'fMi!';!J-};~1Jl'fg&:\jtf,EE~gJ.~ '>-', '<' ~"f::,"-D]f;~f~~~1:gl!"~~~~1ff"J!~~iL~~I~Y;~~~1lill1t@^tJ\~~i'Jj~ ."1),;, ;'-1,.- :.:"':!;~'-/' ",'iJ..;" :,,"(";', "-,,,. ,,' '. '"' ~.' G.F-FI C '"~:" -,i~; VED ," E. OF Sf/"RI"-p YO '- , ,-. RK, PA ' '00 DEe lU 1 P{? 12 116 ~ - :-~";.-- ";~J "~',h " -'~)_'"_:;~ ',~- ;--^'''t ",-""~~~,,,;;:,,"t,,-'0;-:','!.'''- '1';'>.'C"J&""h''''l'!:MO:B/ -----.---'---.. "'---"-- ,-~---~,~.'-';..~- COUNTY OF YORK OFFtCE OF THE SHERIFF SEll:Ylt!Jt(Z;\;J;;L . (717) 771{96l\i 28 EAST MARKET ST., YORK, PA 17401 SHERIFF SERVICIE PROCESS RECEIPT, and AFF'Il)AVIT OF RETURN 1. PLAINTIFF/S/ .-.-..,.-.... - 3. DEFENDANT/S/ 4.'TYPE OF WRIT OR COMPLAINT SERVE .. AT { : \I~' ,~- . '\ ..'; "'" 5. NAME OF INDIVIDUAL COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHE'D,OR SOLD, 6. AODRESS (STREET OR RFO WITH BOX NUMBER, APT NO., Cln: BORO, TWP, STATE AND ZIP CODE r'l/:J p..'l'~ ~ " /....,C:J-..i. c, ''-::-""i ,!'n"" ;-:!\ . -,- n ...... ~r 7. INDICATE SERVICE: . o PERSONAL o PERSON IN CHARGE DEPUTIZE~',cc!61oj:EFfT.,""l\Itl o 1ST CLASS MAIL O~O$TEb:.,"n '.;iiiB~::;.". NOW, " /1.' I ~.I' . ' 20 ~ I. SHERIFF OF Y<>>~~COUNTY, PA, do hereby deputize;!li~~Ill ,;!i;fifiT'i\, ",. . '. . : ....... .... . . COUNTY to execute this Writ and make return tHereofal!;t~~'~/gi":;. to law. This deputatibn being made at th~ request and risk of the'plaintiff. . '.. ,j .'j . .j".. ,.... .'., 'T.,".,;,'...,. - , SHERIFF OF\VQflK'JZ:OUNTY 8, SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDlTlNG SERVICE: ", ,.~ "< . , I'TV 1;,1)" ". .-....' ~,' ',,0" , NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN'. Any deputy sheriff levying upon or attaching any property under Withiri-wli~:rl:l~~'~l,e:a~e;~'~~ without a wl;itchman, in custody, of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the'sfiEi:rjff"ta":any':pl~l.rlti~: herein for any loss, ,destruqtion, or removal of. any property before sheriff's sale thereof. " 9. TYPE' NAME AND ADDRESS of ATTORNEY 1.0RIGINATOR.and SIGNATURE 10. TELEPHONE NUMBER H.PA'i'E"pfffiE'P , l'""i ~\. ::~~:' J ~;.i , , UN-Ur~ ST. ~~ H[lL T. DI-\ Y '1::~ 12~'1.J 12. SEND NOTICE OF SERVICE COPY NAME AND ADDRESS BELOW: (This area must be completed if notice is to be'mailed). ,"_, -!cr;:L;)\~n 13. I acKnowledge receipt of the-writ or complaint as indicated above. 16. HOW SERVED: PERSONAL 1.><!. RESIDENCE ( ) POSTED ( ) POE ( ) SHERIFF'S OFFJ;(l' OTHER ( SEERFM!l~~S 17. Q I hereby certify and returl1 ~ NOTrobMfl'becai..lSe 1 am unable to locate the individual, company, etc. named above, (See remarks below.) 18. NAME AND TITLE OF INDIVIDUAL SERVED {-LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 1-9. Date of Servige ".~'- :,/ .- """,.r-;f <..' . oJ 21.ATT MPTS Da1e. . !/7'. 22. REMARKS 23. Adv(lnce Costs ,i'~l :k... ~ " 41. AFFIRMED and subscribed to before me,tnis " I.' 44. Signature of Dep. Sheriff 45. Signature of York . '\ County Sheriff 42. day of \' i' ,20;;~ _43. ~ P,ROTH@'1NOTARY '(~,-'" jir~! :"_'1."1 ~;': ~I'- 46. Sigriature of Foreign ,f County Sheriff 50. I ACKNOWLEDGE RECEIPT OFTHE SHERIFF'S. RETURN SIGNATURE OF AUTHORIZED ISSUING AUTHORITY AND TIT~E . 1. WHITE -Issuing Authority 2. PINK - Attorney 3. CANARY - Sheriff's Office 4. BLUE. Sheriff's Office 'r:'j\r . _ r:jlr~",y;rsl.!%'~;J;{;t~f,~)2!lN'f,f~?~~!l,m~~;-iWft'W:~i.l~~~J1:itBr.iliili'~~ , .'''-,.. .;;. ;'. - h' ,- -,", "" ,,_ -, - -$''';.,,-. ~ .,~)..";.:,-,,,'. _ -\""".E- i<?",td'1',';ii~1,;'-,~,~'_'"., ,'",;.0:"" ", t " < TRACY A. RAINELU, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-8527 ELWOOD C. STALEY, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please issue a Rule directing Plaintiff to file a Complaint against Defendant within twenty (20) days or non pros seq. reg. THOMAS, THOMAS & HAFER, LLP c-0)~ C. Kent Price, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7632 I.D. No. 06776 ATTORNEYS FOR DEFENDANT , ,. "",,-,,' TRACY A. RAINELLI, Plaintiff v. ELWOOD C. STALEY, Defendant 1-,-- "-,-",_,,"',,., ~--,-,,~ ,(" ~>;"..',"dk"''-'~:'''';''",}-~-;__, ",',' ,'"-,;,,:;~~ " , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-8527 CIVIL ACTION -LAW JURY TRIAL DEMANDED RULE TO FILE COMPLAINT TO: Tracy A. Rainelli c/o Richard A. Consiglio, Esquire 304 Union Street Holidaysburg, PA 16648 You are hereby directed to file a Complaint against Defendant within twenty (20) days or non pros seq. reg. DATED: :2/ J.~ / () ( ~4--J~ , 12.4 Prothonotary '.' " ," --~ -. -" - ,'- I." ~". ",.. -, "," ,,-^,,'-;. ;'" ,'-;,-, '-'-'.' '-'<~~-'''''r~ - TRACY A. RAINELLI, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. ELWOOD C. STALEY, NO. 00-8527 CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of THOMAS, THOMAS & HAFER, LLP as counsel on behalf of Defendant Elwood C. Staley in the above-captioned matter. All papers may be served upon the undersigned at P.O. Box 999, Harrisburg, PA 17108-0999. THOMAS, THOMAS & HAFER, LLP G-~IA~ C. Kent Price, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7632 I.D. No. 06776 ATTORNEYS FOR DEFENDANT - - _- - - "'_ _, ~ ," .,. _, __~ ,,--c___ <'-___,,' __ ,,' ~~",,'i' -- <-.-- ,,' "q'\:j I ., CERTIFICATE OF SERVICE rI<. AND NOW, this 23day of February, 2001, i, C. KENT PRICE, ESQUiRE, for the firm of THOMAS, THOMAS & HAFER, LLP, attorneys for Defendant, hereby certify that I have this day served the within Praecipe for Entry of Appearance by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Richard A. Consiglio, Esquire 304 Union Street Holidaysburg, PA 16648 THOMAS, THOMAS & HAFER, LLP C:.-/~ C. Kent Price, Esquire - ,."" -,- - '=',--- . .~, ~ -'" ,'-.',. <~'" ',' .. ',-, ,." .,,j;., ,,~ --^,j.',",,",.. '~" ~~ ,~,' ~" k, ,',,", . ',;,' -',,':'." -,-"""-,, 0:"~\-~~"'''';,;,,,,-,,,\,;d..'';;''';.; "-' -;,. -. "",~ -;:: -"t~; TRACY A. RAINELLI, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-8527 ELWOOD C. STALEY, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF PREREQUISITE TO SERVE SUBPOENAS PURSUANT TO RULE 4009.22 As a Prerequisite to service of Subpoenas for Documents and Things pursuant to Rule 4009.22, Defendant certifies that: 1. A copy of the Notice of Intent including the proposed Subpoenas attached to this Certificate. 2. Counsel was contacted via correspondence and has waived the 20 day requisite notice of intent to serve. 3. The Subpoenas which will be served are identical to the Subpoenas which are attached to the Notice of Intent THOMAS, THOMAS & HAFER, LLP C.-- C. Kent Price, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7632 I.D. No. 06776 ATTORNEYS FOR DEFENDANT _ _uJ,'-~ , '-'- ,'c.",L-'. ''',.." _"_~;J '''''''''"r-'-,:,,;:;C,-, ",_ TRACY A. RAINELLI, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-8527 " ELWOOD C. STALEY, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Counsel of Record Defendant intends to seNe Subpoenas identical to the ones attached to this Notice. You have twenty (20) days from the date listed below in which to file of record and seNe upon the undersigned an objection to the Subpoenas. If no objection is made, the Subpoenas may be seNed. THOMAS, THOMAS & HAFER, LLP r__~ ~ C. Kent Price, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7632 1.0. No. 06776 ATTORNEYS FOR DEFENDANT DATE: March 1, 2001 "," . . "';'--.'~"'?;-;:'~~"'J."~" """"',",,- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TRACY A. RAINELLI, IN THE COURT OF COMMON PLEAS Plaintiff NO. 00-8527 v. CIVIL ACTION -LAW , J ELWOOD C. STALEY , JURY TRIAL DEMANDED Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: HealthSouth Rehab Hospital of Mechanicsbuf'Q (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Copies of all medical records. includinG but not limited to out-patient. in-patient. office notes. records of other health care providers. and correspondence. pertaininG to Tracv A. Rainelli, date of birth: 12/20/43. for the period of time from December 15. 1998 to the present date. at 305 North Front Street. HarrisburG, P A 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name C. Kent Price. ESQuire Address: 305 North Front Street HarrisburG. PA 17101 Telephone: (717) 255-7632 Supreme Court 10 # 06776 Attorney For. Defendant ~~ Date: 79.... .,)~ dLJ6/ Seal of the Court Prothonotary/Clerk, Civil D' . ion . ~a-,.o ,8Cfi!~~r-- Deputy .-, ~- -. '''. - ~.J.~' "-~'~"""-' ");'~'"'~'-"-'~"'.' Q~".~jjj4'_-,",,~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TRACY A. RAINELLI , IN THE COURT OF COMMON PLEAS Plaintiff NO. 00-8527 v. CIVIL ACTION - LAW ,:,_f ELWOOD C. STALEY, JURY TRIAL DEMANDED Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Harrisburo Hosoital (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Cooies of all medical records. includino but not limited to out-oatient. in-patient. office notes. records of other health care oroviders. and correspondence. pertaininq to Tracv A. Rainelli, date of birth: 12/20/43. for the period oftime from December 15.1998 to the oresent date. at 305 North Front Street. Harrisburo. PA 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWlNG PERSON: Name C. Kent Price. Esouire Address: 305 North Front Street Harrisburo. PA 17101 Telephone: (717) 255-7632 Supreme Court 10 # 06776 Attorney For: Defendant Date: J;.~ ;:2 7 d-.OClI Seal of the Court . BY THE CO~RT~. /J (]>>17M .J~~ Prothonotary/Clerk, Civil ~n "- ~ p ~'\(, / Deputy ,- ~,,,- , .- ~, - -,.'-. - ""~ "i-'.- _ ",..,1..j,;j"""""',&""..i",'_,,, . ~i' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TRACY A. RAINELLI, IN THE COURT OF COMMON PLEAS Plaintiff NO. 00-8527 v. CIVIL ACTION - LAW ," ELWOOD C. STALEY, JURY TRIAL DEMANDED Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: OrthoDedic Institute of Central PA (Name of Person or Entiiy) Within tweniy (20) days aiter service of this subpoena, you are ordered by the court to produce the following documents or things: CODies of all medical records. includina but not limited to out-catient. in-catient. office notes. records of other health care croviders. and correscondence. certainino to Tracv A. Rainelli. date of birth: 12120/43. for the period of time from December 15. 1998 to the cresent date. at 305 North Front Street. Harrisburo. PA 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within tweniy (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 FOLLOW1NG PERSON: Name C. Kent Price. Esouire Address: 305 North Front Street Harrisburo. PA 17101 Telephone: (717) 255-7632 Supreme Court 10 ;; C6776 Attorney For: Defendant Date:~~ ;) 7 I ;; Cb I Seal of the Court ' Prothonotary/Clerk, ivil D' I n <.____ ,a~ (' /~?/f/l/7t'L r Deputy - . 'L_ , '< ~,',__ '_H ',;",-, >_, "" ~', CERTIFICATE OF SERVICE AND NOW, this 1ST day of March, 2001, I, C. KENT PRICE, ESQUIRE, for the firm of THOMAS, THOMAS & HAFER, LLP, attorneys for Defendant, hereby certify that I have this day served the within Notice of Intent to Serve Subpoenas to Produce Documents and Things for Discovery Pursuant to Rule 4009.21 by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Richard A. Consiglio, Esquire 304 Union Street Holidaysburg, PA 16648 THOMAS, THOMAS & HAFER, LLP c-d~ C. Kent Price, Esquire ~ -le..,: " I, I I 1;1 " :'1 "I i i1! i! I. " I:! I.' CERTIFICATE OF SERVICE AND NOW, this 5th day of March, 2001, I, C. KENT PRICE, ESQUIRE, for the firm of THOMAS, THOMAS & HAFER, LLP, attomeys for Defendant, hereby certify that I have this day served the within Certificate of Prerequisite to Serve Subpoenas Pursuant to Rule 4009.22 by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Richard A. Consiglio, Esquire 304 Union Street Holidaysburg; PA 16648 THOMAS, THOMAS & HAFER, LLP ~~~. C. Kent Price, Esquire .1 d >oj-' ~...\d.. :-_~--""-. _ '.' - "~j' IN TIIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA TRACY A. RAINELLI, Plaintiff vs. No. 00-8527 ELWOOD C. STALEY, Defendant CIVIL ACTION - LAW COMPLAINT Filed on behalf of: Plaintiff, Tracy A. Rainelli Counsel of record for this party: RICHARD A. CONSIGLIO, ESQUIRE Pa. I.D. # 06669 304 Union Street Hollidaysburg, P A 16648 (814) 696-4347 ., '-,.,-,"---,,:,---, "= IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRACY A. RAINELLI, Plaintiff ys. No. 00-8527 ELWOOD C. STALEY, Defendant CIVIL ACTION - LAW NOTICE TO DEFEND 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 the enclosed document 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 enclosed document 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, PA 17013 (717) 249-3166 800-990-9108 Richard A. Consiglio, Esq. Counsel for Plaintiff Pa. LD. # 06669 304 Union Street Hollidaysburg, PA 16648 (814) 696-4347 t ;. . ,..J. '; '-,"'- ""-";' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA TRACY A. RAINELLI, Plaintiff vs. No. 00-8527 ELWOOD C. STALEY, Defendant CIVIL ACTION - LAW COMPLAINT AND NOW, comeS the above-named Plaintiff, Tracy A. Rainelli, by and through her legal counsel, Richard A. Consiglio, Esquire, and files the following Complaint in civil action: 1. That the Plaintiff, Tracy A. Rainelli, is an adult individual who resides at 18 Furman Road, Dillsburg, Pennsylvania 17019. 2. That the Defendant, Elwood C. Staley, is an adult individual who resides at Box 1802, Harrisburg, Pennsylvania 17106. 3. That the incident described herein occurred at or about 6:40 p.m. on or about December 15, 1998 on Bridge Street in the municipality of New Cumberland, Cumberland County, Pennsylvania. 4. That on or about the above place described, the Plaintiff had parked her vehicle on the west side of Bridge Street in the area of the CVS Drug Store. Her vehicle was so parked, facing in a southerly direction. She had alighted from her vehicle on the driver's or traffic side of the same, and walked around her vehicle to the sidewalk on the passenger side of the same. She obtained some items from the passenger side of her vehicle and walked to the rear of her vehicle with the intention of crossing Bridge Street to the east side thereof. There were vehicles parked behind the Plaintiffs vehicle at that time and at that location. The Plaintiff stepped to the driver's side rear comer of her vehicle in anticipation of crossing the street. She was located approximately a foot or so beyond the rear of her vehicle on Bridge Street. She looked to her left in a northerly direction to determine what traffic, if any, was approaching her on her side ofthe street. Bridge Street is a two lane roadway with parking on either side of the street. After looking to her left to determine what traffic was approaching from the north, she looked to her right or to the south to see what, if any, traffic was approaching from that direction on the opposite side of the street. While looking to her left and right, the Plaintiff was standing still and waiting for traffic to clear. 5. That on the above described date, time and place, the above named Defendant, Elwood C. Staley, was operating his motor vehicle, a 1987 Pontiac 6000 automobile in a '~ 1'.': southerly direction on said Bridge Street. Said Defendant was operating his vehicle in a careless and negligent manner and caused his vehicle to come into violent contact with the body of the Plaintiff while she was standing, as above described, waiting for traffic to clear. Said violent contact occurred after the Plaintiff had looked to her left/north and was looking to her right and the south. 6. That the above-described automobile/pedestrian collision was a direct and proximate result of the negligence of the aforesaid Defendant in the following aspects: A. In failing to maintain control of his vehicle; and B. In failing to observe and avoid the Plaintiff at that time and place; and C. In failing to maintain a sharp look out of the road in front of him; and D. In continuing to operate his vehicle toward the Plaintiff when the Defendant saw, or in the exercise of reasonable care, should have seen, that further operation of his vehicle in that direction would result in the collision between his automobile and the Plaintiff/pedestrian; and E. In failing to brake his vehicle in sufficient time to avoid the aforesaid hitting/striking the Plaintiff; and F. In failing to exercise due and proper care for the safety and well being of pedestrians on the roadway, specifically the above-named Plaintiff. 1<" l '"' il"'-,-~-- -~' 7. As a direct and proximate result of the negligence of the aforesaid Defendant in striking the above-named Plaintiff/pedestrian with his automobile, the Plaintiff suffered serious painful and permanent injuries as more particularly herein set forth: A. Very serious injuries to her left leg in the nature of fracturing and shattering of the tibia and fibula, requiring significant surgery resulting in the insertion of rods, plates and screws into the bones of the leg; and B. A head injury; and C. Numerous contusions and multiple abrasions; and D. Severe shock to her nerves and nervous system. 8. As a result of the reckless, negligent and unlawful conduct of the Defendant, the Plaintiff has suffered physical pain and mental anguish for which she has continued to undergo medical treatment, including, but not limited to, surgical intervention, in an attempt to resolve the aforesaid injuries. 9. That as a result of the aforesaid injuries the Plaintiff has suffered significant loss of sick leave from work. ~ J~ ,~- _..__\_ . - '1;\' 10. That as a result of the aforesaid injuries the Plaintiff has been forced to expend large sums of money for medical treatment, medication and medical supplies in an effort to resolve her aforesaid injuries. 11. That the Plaintiff avers that the accident is solely the result of the negligence on the part of the Defendant; and not as a result, direct or indirect, of any negligence on her own part. WHEREFORE, the Plaintiff claims of the Defendant a sum in excess of the arbitration limits for the Court of Common Pleas of Cumberland County, Pennsylvania, plus the costs of this suit. Richard A. Consiglio, Esqu' Attorney for Plaintiff Pa. J.D. #06669 304 Union Street Hollidaysburg, P A 16648 (814) 696-4347 , . _ -"- " c -__ -, --~. '--",_,,;;_ < , }:,,: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA TRACY A. RAINELLI, Plaintiff vs. No. 00-8527 ELWOODC. STALEY, Defendant CIVIL ACTION - LAW CERTIFICATE OF MAILING .fi . NOW, this cfl.:J day of March, 2001, I, RICHARD A. CONSIGLIO, ESQUIRE, hereby certify that I have served a copy of Plaintiffs Cornplaint in the above-captioned matter, via certified U.S. Mail, postage prepaid and first class U.S. Mail, postage prepaid and addressed to: C. Kent Price, Esquire THOMAS, THOMAS & HAFER, LLP 305 North Front Street, Sixth Floor P.O. Box 999 Harrisburg, PA 17108 Richard A. Consiglio, Esq. Attorney for Plaintiff Pa LD. #06669 ri' '--.-' ,,'.0. " " '""" l' - -~ ~~'}.. '',i, VERIFICATION I, Richard A. Consiglio, Esquire, Attorney for Tracy A. Rainelli, Plaintiff, hereby verify that the staternents contained in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that any false statements made 'therein are subject to the criminal penalties contained in 18 Pa. C.S.A. ~ 4904, relating to unsworn falsification to authorities. , ~ Date: c'? 1;}.;2. -(]' ( ..;, -"'~"""'''''''Wt:T~OO>!";:~,~.j!lli!~~jjn",,,,";~,dJ'),, '~~'''''',~""~,,;.'''4<~,0i'"*U~i,~~~J;;i:n -,:" , """"'~~~.Hr. ..., y il:\'!!Ii']ul" ~ _~,_ ~_'W> ',-,~' ,"~ ,~,',,, ,; ~ ~-- "' "> ~ "-"""'" , ~ ~ " ,,~- >-' 0 0 ~~ C s: ::n: ",,' '"U r-,-' m rfi :';;:;0- Z '..,.-- ;.c;) -TJ :z F': ~.) , S?~t , 0' , r:: C} -, ~, Cj ..(-- '-' u ._;-; ~O w,,;;~ ::::;:--CJ (~) ,.J.-"'C ~ ;:511 , z ',\" ~ :< );.... fv ::0 -< , ~' ,-,<-.--- "'" TRACY A. RAINELLI, Plaintiff v. ELWOOD C. STALEY, Defendant TO: Tracy A. Rainelli clo Richard A. Consiglio, Esquire 304 Union Street Holidaysbutg, PA 16648 .-,,~,~ -~-"",,-..=I.-" '-."',,'"" ,"A~~ ..,"co;, . ',.",-.",'.'0 "~.-"" "''''-;;''''~ ". "'CO"""'-"'", '''.~'.J/-;~:! IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-8527 CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE YOU ARE HEREBY notified to plead to the enclosed New Matter within twenty (20) days of service hereof or a default judgment may be entered against you. DATED: J.f I C;;>;;2../ 0 I THOMAS, THOMAS & HAFER, LLP G-~~ C. Kent Price, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7632 ATTORNEYS FOR DEFENDANT . ~ .. ,," " TRACY A. RAINELLI, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-8527 CIVIL ACTION - LAW JURY TRIAL DEMANDED v. ELWOOD C. STALEY, Defendant ANSWER WITH NEW MATTER 1. Admitted. 2. Admitted in part, denied in part. It is denied that Defendant resides at Box 1802, Harrisburg, Pennsylvania. To the contrary, Defendant resides at 107 Old York Road, New Cumberland, Pennsylvania. The remaining allegations are admitted. 3. Admitted. 4. Denied in accordance with Pa.R.C.P. 1029(e). 5. Admitted in part, denied in part. It is admitted that the Defendant was operating a 1987 Pontiac 6000 in a southerly direction on Bridge Street in New Cumberland at or about 6:40 P.M. on December 15, 1998. It is further admitted that there was contact between the right side of Defendant's vehicle and the Plaintiff. It is specifically denied that the Defendant was operating his vehicle in a careless and negligent manner at the time. To the contrary, at all times relevant to the claim, the Defendant operated his vehicle in a safe, reasonable and prudent manner. The remaining allegations are denied in accordance with Pa.R.C.P. 1029(e). , ~~, c.' ,,, -",.~."'" O'~--'."""-',', 1, " . "It 6. Denied. It is specifically denied that the Defendant caused any contact involving his vehicle and the Plaintiff as a result of any negligent act or omission. To the contrary, at all times relevant to the claim, the Defendant operated his vehicle in a safe, reasonable and prudent manner. The remaining allegations, including those contained in subparagraphs A. through F., inclusive, are denied in accordance with Pa.R.C.P. 1029(e). 7. Denied. It is specifically denied that the Defendant caused any contact involving his vehicle and the Plaintiff as a result of any negligent act or omission. To the contrary, at all times relevant to the claim, the Defendant operated his vehicle in a safe, reasonable and prudent manner. The remaining allegations are denied in accordance with Pa.R.C.P. 1029(e). 8. Denied. It is specifically denied that the Defendant caused any contact involving his vehicle and the Plaintiff as a result of any negligent act or omission. To the contrary, at all times relevant to the claim, the Defendant operated his vehicle in a safe, reasonable and prudent manner. The remaining allegations are denied in accordance with Pa.R.C.P. 1029(e). 9. Denied. The allegations are denied on the basis that, after reasonable investigation, the Defendant iswithout information or knowledge sufficient to form a belief as to the truth thereof. 10. Denied. The allegations are denied on the basis that, after reasonable investigation, the Defendant is without information or knowledge sufficient to form a belief as to the truth thereof. "" ._, "'~.~ ~"'.'- ~">". " ,.~ ~",'~" ~,' -, , ~-~1 11. Denied. It is specifically denied that the Defendant caused or contributed to causing the accident by any negligent act or omission. To the contrary, at all times relevant to the claim, the Defendant operated his vehicle in a safe, reasonable and prudent manner. WHEREFORE, Defendant Elwood C. Staley demands judgment in his favor and against Plaintiff. NEW MATTER 12. The Plaintiffs claims may be barred or limited by provisions of the Motor Vehicle Financial Responsibility Law, 75 Pa.C.SA 31701 et seq. 13. The Plaintiffs claims may be barred or limited by her tort option election. 14. The Plaintiffs claims may be barred or limited by her own negligence, which was the sole and proximate cause of her injuries and damages. 15. At all times relevant hereto the Defendant operated his vehicle in a safe, reasonable and prudent manner. 16. The Defendant did not cause the accident by any negligent act or omission. 17. The Plaintiffs claims may be barred by the applicable statute of limitations. 18. Some or all of the Plaintiffs injuries may be due to or the result of pre- existing conditions. 19. The Plaintiff may have failed to mitigate her damages. , ,""". .~""...~.,,____._,.. "_ _. ",J"'-,"'\""" " .",~_""",___""~,,.,. n_...." "-<""-,"d~"''-N'O' ",--,,/..., __~ >.","j WHEREFORE, Defendant Elwood C. Staley demands judgment in his favor and against Plaintiff. THOMAS, THOMAS & HAFER, LLP ~0)~ C. Kent Price, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7632 1.0. No. 06776 ATTORNEYS FOR DEFENDANT :127063.1 ",. ,.. __.. _ ".,_'~+r'" "".,__,..",_ _ ',' ._,' ..,,~_\ VERIFICATION I verify that the facts set forth in the foregoing Answer with New Matter are true and correct to the best of my information, knowledge and belief. I understand that any false statements contained herein are made subject to the penalties of 18 Pa. C.SA ~4904, relating to unsworn falsification to authorities. -{~~ C, ~~/I Elwood C. Staley DATED: 3/3~~J ,-,"- . '- "~ " M~.'< ~"__.,, . ___""'___'_~"^'.~'"~:' ".",," ,,-_,=_,~'';''''''_; CERTIFICATE OF SERVICE ..#.. AND NOW, this Z day of April, 2001, I, C. KENT PRICE, ESQUIRE, for the firm of THOMAS, THOMAS & HAFER, LLP, attorneys for Defendant, hereby certify that I have this day served the within Answer with New Matter by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Richard A. Consiglio, Esquire 304 Union Street Holidaysburg, PA 16648 THOMAS, THOMAS & HAFER, LLP 0_~~ C. Kent Price, Esquire """ ---' '".," 0. ,,~ l , ~' - "" ., ,~ , , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA TRACY A. RAlNELLI, Plaintiff vs. No. 00-8527 ELWOOD C. STALEY, Defendant CIVIL ACTION - LAW PLAINTIFF'S ANSWER TO DEFENDANT'S NEW MATTER AND NOW comes the above-named Plaintiff, Tracy A. Rainelli, by and through her legal counsel, Richard A. Consiglio, Esquire, and files the following Answer to Defendant's New Matter in the above-captioned case: 1-11. Paragraphs No.1 through 11 of Plaintiff's Complaint are incorporated herein and made a part hereof as though fully written out. 12.-13. Denied in accordance with Pa. R.C.P. 1Q29(e). 14. It is denied that the Plaintiff's claims are barred or limited by her own negligence. On the contrary, Plaintiffs claims are the sole and proximate result of the negligence of the Defendant in this matter. It is further denied that at all times relevant hereto the Defendant .-.' ~~~ '. L > "" .d__ ~~ ,-" '"," l_"" . operated his vehicle in a safe, reasonable and prudent manner. On the contrary, at all times relevant hereto the Defendant operated his vehicle in a careless, reckless and negligent manner. 15. Denied for reasons set forth in Paragraph No. 14 above. 16. It is denied that the Defendant did not cause the accident by any negligent act or omission. On the contrary, it was the negligent acts and/or omissions of the Defendant that was the sole cause of the aforesaid accident. 17. It is denied that the Plaintiffs claims are barred by the applicable statute of limitations. On the contrary, Plaintiff initiated the aforesaid action within the two year period required by the statute of limitations. 18. It is denied that any of the Plaintiff's injuries are due to or are the result of any pre- existing condition. 19. It is denied that the Plaintifffailed to mitigate any of her damages. ;;..~.".,..~ - ~. , , I.- ",-, ,".c,' '" ~" ".--", c' """,-."...","-;-' ,,<, " ~-__.i.:._,-. i1S~ ",,'" . WHEREFORE, Plaintiff demands judgment in this rnatter in a sum in excess of the arbitration limits of the Court of Common Pleas of Cumberland County, Pennsylvania, plus the costs of this suit. Richard A. Consiglio, Es Attorney for Plaintiff Pa. ID #06669 304 Union Street Hollidaysburg, PA 16648 (814) 696-4347 ,'" ~ .~. ,,-"" ,r, "J "1-", , i' . -.l"ll!ii!',j,,,, ~ ~, VERIFICATION I, Richard A. Consiglio, Esquire, Attorney for Tracy A. Rainelli, Plaintiff, hereby verifY that the statements contained in the foregoing Plaintiff's Answer to Defendant's New Matter are true and correct to the best of my knowledge, information and belief. I understand that any false staternents made therein are subject to the criminal penalties contained in 18 Pa. C.S.A. ~ 4904, relating to unsworn falsification to authorities. Date: L(-oJ? - 01 , &,' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA TRACY A. RAINELLI, Plaintiff vs. No. 00-8527 ELWOOD C. STALEY, Defendant CIVIL ACTION - LAW CERTIFICATE OF MAILING -t. NOW, this ,.:27 day of April, 2001, I, RICHARD A. CONSIGLIO, ESQillRE, hereby certifY that I have served a copy of Plaintiff's Answer to Defendant's New Matter in the above-captioned matter, via certified U.S. Mail, postage prepaid and first class U.S. Mail, postage prepaid and addressed to: C. Kent Price, Esquire THOMAS, THOMAS & HAFER, LLP 305 North Front Street, Sixth Floor P.O. Box 999 Harrisburg, PA 17108 Richard A. Consiglio, Es . Attorney for Plaintiff Pa LD. #06669 ~IBi~i.:\.Jiiiill11~i*~"MOOfjit-:l~"~"''''~~~-iffi,jf-1''''jM:"''~4f,.M_,"',;j,<'4"g,',*M~"ili~RJIl:.11 Jlj-""~Wi&if,lilWJl~ ~-''1lO'-ir'~.i!lli'W'- --"".".."" L ~.. "" ". .~~ -'~ 1ilillIIiiiI~:i!l ,J... "U ltiJl '-I , , . () 0 ~...-, C -"'n 5- "'" :_~j- ;:gW ,J -:. IT1 :;;0 (ii;R Z_,-, ZC W ",-,fT! (j) ",:-.- 0 -,;-;C1 2"'. '~.. ') {jo., ;<0 -0 .~_"C :' ~ -;.j ~o ::l:: (5-~ :--0 ,~?"() ;J>c S~ ESm '~ .~ N 5J N -< . 1-". ,- _l ~ _ '. po r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA TRACY A. RAINELLI, Plaintiff vs. No. 00-8527 ELWOOD C. STALEY, Defendant CIVIL ACTION - LAW NOTICE OF SERVICE OF ANSWERS TO INTERROGATORIES .-, ." ~! Notice is hereby given that on the 9th day of April, 2002 the plaintiff served Answers to Interrogatories upon the defendant by mailing the same, via first class U.S. Mail, postage prepaid, addressed to the following: C. Kent Price, Esquire 305 North Front Street P.O. Box 999 Harrisburg, P A 17108 Richard A. Consiglio, Esquir Counsel for Plaintiff 304 Union Street Hollidaysburg, PA 16648 (814) 696-4347 Pa.ID#06669 : .. ... ,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRACY A. RAINELLI, Plaintiff vs. No. 00-8527 ELWOOD C. STALEY, Defendant CIVIL ACTION - LAW CERTIFICATE OF SERVICE , , j,C l '~.:' 1, Richard A. Consiglio, Esquire, counsel for the plaintiff, Tracy A. Rainelli, hereby certify that on the /7'7 day of April, 2002, a true and correct copy of the Notice of Service of Answer to Interrogatories was served upon counsel of record for the defendant by regular first class U.S. Mail, postage prepaid, as follows: C. Kent Price, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 Richard A. Consiglio, Esq . Counsel for Plaintiff 304 Union Street Hollidaysburg, PA 16648 (814) 696-4347 Pa.ID#06669 ,,:t,",';;;..',l~jj~ 'i ~1Iii~JIMilI'~~!"-l>>ii!RiMlm.r"i!i..~~";lWl~Ji;~"'>1:"c\;'>h!j,""',0.--;,l"',~"m;diUl6ill~~j~<u__\ ~'~IiloalIIll~Jt~._i\;l... ' 0."",,_,^,,_~ ,*,'~~,N~,," ,,"~n',. ". <... ,~,~. ,,'~' .,,<_',,"...A'~""~_ .'", .~-I ~, ~_.. ". ,~ ~_ ,,,.. 'r:~lV-"' , 0 CJ 0 C N '., S ):>0 'Dee -u ruFf 7.J -" L__.l' F Z C .....J nl co ID ':')0 -< (:~~ r::: c;- -"0 ~> Z D :;..2: ji: Ci r:? Ofn C Z c- ~ =< :TI f" -< ~ , .:: ... -, Jf ,J" ;:c " , .lj-",- PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONYrARY OF CUMBERLAND COUNTY Please list the following case: (Check one) x for JURY trial at the next term of civil court. for trial without a jury. ----------------------------------------- CAPTION OF CASE (entire caption must be stated in full) (check one) ( X ) Civil Action - Law Appeal from Arbitration TRACY A. RAINELLI (other) ( Plaintiff) vs. The trial list will be called on Feb. 11, 2003 and ELWOOD C. STALEY ( Defendant) Trials corrmence on March 10, 2003 Pretrials will be held on Februarv 19, 2( 03 (Briefs are due 5 days before pretrials.) vs. (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214.1.) No. 8527 Civil 1& 2000 Indicate the atto:rney who will try case for the party who files this praecipe: C. Kent Price Indicate trial counsel for other parties if known: Richard A. Consiglio This case is ready for trial. Signed: ~4&^)~ Date: 12.-)31)Q2. Print Name: r Kpnt Pr;~p Atto:rney for: Dpfpnnrmt ,.'.; .'i1ii-"" ,k-'-_~M~NIli~~~h}.j;~*\;.&i~,,,,",;mi,,:;j;;',,o\~.~}'>':J,,:<'iB:1>',tJ"rl"flj'_'"0 ,~ 'i:.i..>"" <1ll1&!il"llI ,~ , a 0 0 C "''' -'1 ;?' ,- vl"'fr :~ rnn"::'l ~ "Tl Z::C "i..... I~ zr- 1 q'...:_t ~~~ 1'-..1 - ~1 \.,.-' ,,:~ii~: !;2C --0 'J;>- .,.,s,.. ~tf:~ ~t:.:. .vC r;? l.,j" -~ z :::::> ", ~ :0 c..) -< ., ~. .' hi, .--~" - , .'" , .'''' .-,--, ..........~ MAR 2 4 Z003 ~ TRACY A. RAINELLI, Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNlY, PENNSYLVANIA vs. No. 00-8527 ELWOOD C. STALEY, Defendant CIVIL AmON - LAW PRAECIPE FOR SATISFACTION AND DISCONTINUANCE TO THE PROTHONOTARY: The above-captioned action having been satisfied and settled between the parties to their satisfaction, the Attorney for the Plaintiff requests that the record in the above- captioned action at law be marked settled, satisfied and discontinued with prejudice. Richard A. Consiglio, Esquire Attorney for Plaintiff Pa. !.D. #06669 304 Union Street Hollidaysburg, PA 16648 (814) 696-4347 Dated: March 17, 2003