HomeMy WebLinkAbout01-5923PENNSYLVANIA:
DANIEL S. APPLEBY,
Plaintiff,
VS.
ROSS STORES, INC.,
Defendants.
1N THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
AT LAW NO. ~!
PETITION FOR ISSUANCE OF SUBPOENA
DUCES TECUM PURSUANT TO 42 Pa. C.S. § 5326
COMES NOW, the Petitioner, Leslie A. Trotter, an attomey licensed to practice law in
the Commonwealth of Virginia, and asks this Court to issue the subpoenas duces tecum attached
hereto pursuant to 42 Pa. C.S. § 5326. The subpoenas duces tecum relate to a matter pending in
the Loudoun County Circuit Court in the Commonwealth of Virginia styled, Daniel S. Appleb¥
v. Ross Stores, Inc., At Law No. 24349. Petitioner respectfully requests that the practice and
procedure regarding the subpoenas be wholly the practice and procedure of the Commonwealth
of Virginia as more specifically set forth in the attached subpoenas duces tecum.
Virginia State Bar No.: 27700
Leslie A. Trotter
Virginia State Bar No.: 45040
REES, BROOME & DIAZ, P.C.
8133 Leesburg Pike, Ninth Floor
Vienna, Virginia 22182
(703) 790-1911
Fax No. (703) 848-2530
Counsel for Ross Stores, Inc.
ROSS STORES, INC.
By Counsel
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing Petition for Issuance of Subpoena Duces
Tecum was mailed, postage prepaid to:
this
Christopher M. Dove, Esquire
Daniel J. Travostino, P.C.
107 North King Street
Leesburg, Virginia 20176-2820
Counsel for Daniel S. Appleby
dayof 0~]~r4r ~2001. Les~l~e~/~ ~
A. Trotter
PENNSYLVANIA:
DANIEL S. APPLEBY,
Plaintiff,
VS.
ROSS STORES, INC.,
Defendants.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
AT LAW NO.
CERTIFICATE PREREQUISITE 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, Ross Stores, Inc., certifies that:
1. Notices of Intent to Serve the Subpoenas with copies of the subpoenas attached
hereto were mailed or delivered to each party at least twenty (20) days prior to the date in which
the Subpoenas were sought to be served;
2. A copy of each Notice of Intent, including the proposed subpoenas, are attached
to this Certificate;
3. No objection to the Subpoenas have been received; and
4. The Subpoenas which will be served are identical tO the Subpoenas which are
attached to the Notices of Intent to Serve the Subpoenas, except for the addition of the date upon
which the documents and tangible things must be made available.
Date
Virginia State Bar No.: 45040
REES, BROOME & DIAZ, P.C.
8133 Leesburg Pike, Ninth Floor
Vienna, Virginia 22182
(703) 790-1911
Fax No. (703) 848-2530
Counsel for Ross Stores, Inc.
OCT ' 2DOl
PENNSYLVANIA:
THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
DANIEL S. APPLEBY,
Plaintiff,
VS.
ROSS STORES, INC.,
Defendant.
ORDER
THIS MATTER COMES before the Court upon Defendant's Petition for Issuance of
Subpoenas Duces Tecum; and
IT APPEARING TO THE COURT that the subpoenas Duces Tecum relate to a matter
pending in the Loudoun County Circuit Court in the Commonwealth of Virginia Styled, Daniel
S. Appleby v. Ross Stores, Inc., At Law No. 24349;
IT IS THEREFORE,
ADJUDGED, ORDERED AND DECREED that the subpoenas Duces Tecum directed to,
Apple-A-Day and Healthsouth Medical Clinic be issued pursuant to 42 Pa. C.S. § 5326.
ATLAWNO. 0'--..~c~5 ~
Entered this /~ r day of October, 2001.
rR=. E CoP FR,gJ . RE,oORD
Chis day ~[ ". ,
Pmth~o~rf
SHERIFF'S
CASE NO: 2001-05923 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
APPLEBY DANIEL S
VS
ROSS STORES INC
DOUGLAS DONSEN ,
RETURN - REGULAR
Cumberland County, Pennsylvania,
says, the within SUBPOENA
HEALTHSOUTH MEDICAL CLINIC
Sheriff or Deputy Sheriff of
who being duly sworn according to law,
was served upon
~ the
WITNESS , at 1045:00 HOURS,
at 1124 HARRISBURG PIKE
CARLISLE, PA 17013
HEATHER MILLIKEN, MEDICAL ASST
on the 31st day of October , 2001
by handing to
a true and attested copy of SUBPOENA
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 3.25
Affidavit .00
Surcharge 10.00
.00
31.25
Sworn and Subscribed to before
me this g~ day of
~ ~! A.D.
~ ' Prothonotary
So Answers:
R. Thomas Kline
i1/01/200i
REES BROOME & DIAZ
By: ~~/~z~.---~-
D~puty Sheriff
SHERIFF'S RETURN -
CRSE NO: 2001-05923 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
APPLEBY DANIEL S
VS
ROSS STORES INC
REGULAR
DOUGLAS DONSEN , Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within SUBPOENA was served upon
APPLE A DAY the
WITNESS , at 1045:00 HOURS,
at 1124 HARRISBURG PIKE
CARLISLE, PA 17013
HEATHER MILLIKEN, MEDICAL ASST
a true and attested copy of SUBPOENA
on the 31st day of October , 2001
by handing to
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
16.00
Sworn and Subscribed to before
me this ~ day of
~ ~%~/ A.D.
Pr6t honor ary
So Answers:
R. Thomas Kline
ii/Oi/200i
REES BROOME
By:
& DIAZ
D$~uty Sheri