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Home My WebLink About03-2131 N THE COURTO~TY'~~SYLVANIA CUMBERLAND - ~a c C~~~~~`T~~-t NO. last, SUZANNE H. GRAHAM, 5223 Eton Place Mechanicsburg, PA 17055 CIVIL ACTION -LAW ALICE CHIN • 5230 Eton Place • Mechanicsburg, PA 17055 : JLgy TRIAL DEMANDED . HUBERT CHIN 5230 Eton Place PA 17055 • Mechanicsburg, versus Defendants & Addresses Plaintiff & Address pItAECIPE FOR A WET OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: e issue a writ of summons in the above-captioned action. Pleas Writ of Summons shall be issued and fo~,arded to ~~ _ X--- ~ ,~~ u~re Michael J• l lsont & Wisneski LLP Navitsky, 0 Road DNS' 2040 Lir,glestown Suite 303 PA 17110 Harrisburg, (717) 541-9205 honeNo• of Attorney Name/Ad~esslTelep Sim a ure of ~ttQrney I.D. No• 588 2003 Dated: Apri128, ( )Attorney and (X) Sheriff ( )Defendant ~~. ~~..~. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.~=~,3 ~ C~viC`~~ CIVIL ACTION -LAW SUZANNE H. GRAHAM, HUBERT CHIN 5223 Eton Place 5230 Eton Place Mechanicsburg, PA 17055 Mechanicsburg, PA 17055 ALICE CHIN 5230 Eton Place Mechanicsburg, PA 17055 JURY TRIAL DEMANDED versus Plaintiff & Address Defendants & Addresses WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT: YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. Prothonotary Dated: ~./ S. (~~ Deputy IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. D3 - .? 13 ( ~t v t 1~~-'~-l CIVIL ACTION -LAW SUZANNE H. GRAHAM, HUBERT CHIN 5223 Eton Place 5230 Eton Place Mechanicsburg, PA 17055 Mechanicsburg, PA 17055 ALICE CHIN 5230 Eton Place Mechanicsburg, PA 17055 JURY TRIAL DEMANDED versus Plaintiff & Address Defendants & Addresses PRAECIPE FOR A WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue a writ of summons in the above-captioned action. X Writ of Summons shall be issued and forwarded to ( )Attorney and (X) Sheriff ~ . ' ( )Defendant Michael J. Navitsky, Esquire Navitsky, Olson & Wisneski LLP 2040 Linglestown Road Suite 303 Harrisburg, PA 17110 (717) 541-9205 Name/Address/Telephone No. of Attorney d Signature of ~ttc~rney I.D. No. 588 Dated: Apri128, 2003 w a n ~ F w d w T~ SHERIFF'S RETURN - REGULAR CASE NO: 2003-02131 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GRAHAM SUZANNE H VS CHIN HUBERT ET AL CPL. MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon CHIN ALICE the DEFENDANT at 2007:00 HOURS, on the 6th day of May 2003 at 5230 ETON PLACE MECHANICSBURG, PA 17055 TT TrL~ ('~UTTT by handing to a true and attested copy of WRIT OF SUMMONS REQUEST FOR PRODUCTION OF DOCUMENTS 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 /~f ~ day of ~~~ ~3 A.D. ~ n rothonotary ~ So Answers: ,.~")d~r/ ~ ~P 4~ i r R. Thomas Kline 05/07/2003 NAVITSKY OLS SNESKI By. Deputy eriff ~.. ... SHERIFF'S RETURN - REGULAR CASE NO: 2003-02131 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GRAHAM SUZANNE H VS CHIN HUBERT ET AL CPL. MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon (''L7TTT T-TTTRF'R'T the DEFENDANT at 2007:00 HOURS, on the 6th day of May 2003 at 5230 ETON PLACE MECHANICSBURG, PA 17055 by handing to ALICE CHIN, WIFE a true and attested copy of WRIT OF SUMMONS REQUEST FOR PRODUCTION OF DOCUMENTS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 7.59 .00 10.00 So Answers: R. Thomas Kline 05/07/20 NAVITSKY Sworn and Subscribed to before By: me this ~ ~/ ~` day of c~- ~~-3 A . D . .~ rothonotary SUZANNE H. GRAHAM, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-2131 HUBERT CHIN and CIVIL ACTION -LAW ALICE CHIN, Defendants JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendants, Hubert Chin and Alice Chin, with regard to the above-captioned matter. Respectfully submitted, NEALON Sz GOVER, P.C. Date: ~ Z3 ~ By; ~ ~. Brian R. Sinn ,Esquire Attorney I.D. No. 84188 2411 North Front St. Harrisburg, PA 17110 (717) 232-9900 SUZANNE H. GRAHAM, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA ~• NO. 03-2131 HUBERT CHIN and CIVIL ACTION -LAW ALICE CHIN, , Defendants JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please issue a Rule upon the Plaintiff to file a Complaint within twenty (20) days or suffer a judgment of non pros. Respectfully submitted, NEALON & GOVER, P.C. Date: ~ z3~~~ ~~~ By: Brian R. Sinne ,Esquire Attorney I.D. No. 84188 2411 North Front St. Harrisburg, PA 17110 (717) 232-9900 RULE TO THE PLAINTIFF: A Rule is hereby issued upon you to file a Complaint within twenty (20) days of service of this Rule or suffer a judgment of non pros. DATED: ~~ d~OC,~ `~c,e2.~c.~c~! Prothonotary /~ CERTIFICATE OF SERVICE 'GfX AND NOW, this ~ day of May, 2003, I hereby certify that I have served the foregoing Praecipe for Rule to File Complaint on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Michael J. Navitsky, Esquire Navitsky, Olson & Wisneski, LLP 2040 Linglestown Rd., Suite 303 Harrisburg, PA 17110 Eileen S. Smith, Secretary ~ ~ o r~ ~~ --~C ~ "E'3C-"~ Z - ' ~•,,~ _~~, s31 G!y ~? : ~~ W ': ~~. c ~ -~ rn . ~ r-- --a ~' ~ cr- SUZANNE H. GRAHAM, IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA Plaintiff NO.03-21_S1 -Civil Term v. CNIL AC"LION -LAW HUBERT CHIN and ALICE CHIN, his ~R~Ci~NQL wife, Defendants JURY TRIAL DEMANDED NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appeazance 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 maybe 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 Baz Association 2 Liberty Avenue Cazlisle, PA 17013 (717)249-3166 SUZANNE H. GRAHAM, IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA Plaintiff NO.03-2131 -Civil Term v. CNIL ACTION -LAW HUBERT CHIN and ALICE CHIN, his wife, Defendants JURY TRLAL DEMANDED NOTICIA Le han 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 notification. Usted debe presentaz una apariencia escrita o en persona o por abogado y archivaz en la Corte en forma escrita sus defenses o sus objections a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la Corte tomaza medidas y puede entraz una Orden contra usted sin previo aviso o notification y por cualquier queja o alivio que es pedido en la petition de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes paza usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTA. SI NO TIENE ABODAGO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIQ VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Baz Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 SUZANNE H. GRAHAM, IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA Plaintiff NO. 03-2131 -Civil Terrn v. HUBERT CHIN and ALICE CHIN, his wife, CIVIL AC"PION -LAW Defendants JURY TRIAL DEMANDED COMPLAINT 1. Plaintiff, Suzanne H. Graham, is a person of the full age of majority and resident of Cumberland County, Pennsylvania. 2. Defendants, Hubert and Alice Chin, are persons of the full age of majority who were at all material times herein married to one another and residents of Cumberland County, Pennsylvania. 3. At all material times herein Defendants owned and maintained a home and property located at 5230 Eton Place, Mechanicsburg, Lower Allen Township, Cumberland County, Pennsylvania. 4. Defendants' property includes a front yard and sidewalk, with a sweet gum tree between the sidewalk and curb to the street. 5. At all material times herein Defendants had an affirmative legal duty based on common law and Lower Allen Township Ordinance to inspect, maintain and repair the sidewalk on their property, as well as the sweet gum tree that grew between the sidewalk and curb. 6. Defendants failed in their affirmative legal duty to inspect, maintain, and repair their sidewalk and sweet gum tree in that, over the years, the roots of the tree buckled the sidewalk, breaking the concrete and raising it in a disjointed fashion by approximately five degrees, and the fruit of the tree (gumballs) caused much debris on the sidewalk that created a perennial slipping hazard that Mrs. Chin referred to as "my living nightmare." 7. On the evening of October 29, 2001, while waking her dog, Plaintiff passed in front of Defendants' home on Defendants' sidewalk, traversing the raised and broken sidewalk and fell on gumballs from Defendants' tree that littered Defendants' sidewalk. 8. The accident caused Plaintiff to suffer a fractured right (dominant) shoulder that has required extensive medical care, including surgery to replace the shoulder with a prosthesis and intense, prolonged physical therapy and rehabilitation. 9. Plaintiff believes and therefore avers that Defendants are answerable for her accident and injuries based on their breach of the affirmative legal duty owed to Plaintiff to inspect, maintain, and repair their sidewalk and sweet ball tree in order to keep the sidewalk in a reasonably safe condition. 10. Defendants' owed Plaintiff a duty of reasonable care as Plaintiff was lawfully walking on the Defendants' sidewalk at the time of the accident. 11. Defendants breach of their duty of reasonable care owed to Plaintiff constitutes negligence and Plaintiff claims that Defendants were negligent in the following particulars: a. failing to inspect the sidewalk and sweet gum tree; b. failing to maintain the sidewalk and sweet gum tree; c. failing to repair the sidewalk and sweet gum tree; d. failing to warn Plaintiff of the dangers created by the condition of the sidewalk and debris caused by broken concrete and the tree; e. failing to sweep their sidewalk clear of debris; f. failing to prune or trim their sweet gum tree; g. failing to cut down and remove the sweet ball tree; h. waiting until after Plaintiff s accident to make repairs to their property given the fact that Defendants were aware for years of the dangers caused by their sidewalk and tree and yet took no feasible corrective action; i. waiting until after Plaintiff's accident to cut the sweet ball tree; and j. waiting until after Plaintiff's accident to clear the debris from their sidewalk. 12. Defendants' negligence also violated Lower Allen Township Ordinance 202.2 that provides, in pertinent part, that "no person shall permit any trees...to otherwise obstruct, impede or interfere with traffic on or using such streets or sidewalks." 13. As Plaintiff was an intended beneficiary of the aforesaid law and was lawfully traversing Defendants' sidewalk at the time of the accident and suffered severe injuries as a direct result, that were meant to be prevented by the law, Defendants' aforesaid negligence constitutes negligence per se and Defendants are therefore liable unto Plaintiff as a matter of law for all injuries and damages suffered as a result of the violation. 14. As a direct and proximate result of Defendants' negligence and negligence per se as stated above, Plaintiff suffered, continues to suffer, and will suffer in the future the following elements of damage cognizable by law, all of'which claim is made therefore: a. past, present and future pain and suffering; b. past, present and future medical and related expenses; c. scarring and disfigurement; d. past, present and future loss of earnings and eanung capacity; e. past, present and future loss of enjoyment of life; f. permanent disability, limitation, and restriction; and g. all damages cognizable by law. WHEREFORE, Plaintiff prays for judgment against Defendants in an amount in excess of twenty-five thousand ($25,000.00) dollars, exclusive of interests and costs and for trial by jury, and all general and equitable relief and for trial by jury. Date: r // ~W~ Respectfully submitted, NAVITSKY, OLSON & Michael J. v tsky, Esc I.D. No. 588 3 2040 Linglestown Road, Harrisburg, PA 17110 717/541-9205 Counsel far Plaintiff LLP VERIFICATION I, SUZANNE H. GRAHAM, 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. §4904, relating to unsworn falsification to authorities. WITNESS Suzanne H. Graham CERTIFICATE OF SERVICE I, Jessie K. Walsh, an employee of the law firm of Navitsky, Olson & Wisneski LLP, do hereby certify that I am this f day of July, 2003 serving a true and correct copy of the Complaint upon all counsel of record via postage prepaid first class United States mail addressed as follows: Brian R. Sinnett, Esquire Nealon & Gover, P.C. 2411 North Front Street Harrisburg, PA 17110 Counsel for Plaintiff ~Q Jessie K. Walsh C? ,~ (:: -' °, i ' r.. (> ._ :') --y ~_`._, __ :~j ~ r SUZANNE H. GRAHAM, Plaintiff v. HUBERT CHIN and ALICE CHIN, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.03-2131 CIVIL ACTION -LAW JURY TRIAL DEMANDED DEFENDANT'S ANSWER TO PLAINTIFF'S COMPLAINT AND NOW, come the Defendants, Hubert and Alice Chin, by and through their attorneys, Nealon & Gover, P.C., and files the following Answer to Plaintiff's Complaint. 1. Admitted, based upon information and belief. 2. Admitted. 3. Admitted. 4. Admitted. 5. This paragraph avers a conclusion of law to which no response is required. However, to the extent that this Honorable Court deems a response appropriate, it is denied pursuant to Pa.R.C.P. 1029(e). 6. Denied pursuant to Pa.R.C.P. 1029(e). 7. Denied pursuant to Pa.R.C.P. 1029(e). 8. At the present time, Answering Defendants are without information sufficient to form a belief as to the truth of the matter asserted and strict proof of same is demanded at trial. g. This paragraph avers a conclusion of law to which no response is required. However, to the extent that this Honorable Court deems a response appropriate same is denied pursuant to Pa.R.C.P. 1029(e). 10. This paragraph avers a conclusion of law to which no response is required. However, to the extent that this Honorable Court deems a response appropriate same is denied pursuant to Pa.R.C.P. 1029(e). 11. This paragraph and its subparts aver a conclusion of law to which no response is required. However, to the extent that this Honorable Court deems a response appropriate same is denied pursuant to Pa.R.C.P. 1029(e). 12. This paragraph avers a conclusion of law to which no response is required. However, to the extent that this Honorable Court deems a response appropriate same is denied pursuant to Pa.R.C.P. 1029(e). 13. This paragraph avers a conclusion of law to which no response is required. However, to the extent that this Honorable Court deems a response appropriate same is denied pursuant to Pa.R.C.P. 1029(e). 14. This paragraph and its subparts are den ied pursuant to Pa.R.C.P. 1029(e). WHEREFORE, Defendants, Hubert and Alice (:.hin respectfully request that judgment be entered in their favor together with the cost of this action. Respectfully submitted, NEALON & GOVER, P.C. Brian R. Si/~ nnett Esquire Attorney I.D. No. 84188 2411 North Front St. Harrisburg, PA 17110 Date: 7/Z3/~ ~ (717) 232-9900 VERIFICATION We, Hubert and Alice Chin, verify that the statements made in the foregoing Answer with New Matter are true and correct. We understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. r Date: ~~ 03 ~` Hubert Chin Date: 7 ~~ 6 oU i `--~.Gt~' Alice Chin CERTIFICATE OF SERVICE AND NOW, this ~`7 day of July, 2003, I hereby certify that I have served the foregoing Answer to Plaintiff's Complaint on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Michael J. Navitsky, Esquire Navitsky, Olson & Wisneski, LLP 2040 Linglestown Rd., Suite 303 Harrisburg, PA 17110 ~~~~~ Eileen S. Smith, Secretary r`~ - (: ( 'l :.; -r~ ~; ';:. _ ~ 1 ,.~ ~•. c >_'~ .. ~, . .l (~l '\ SUZANNE H. GRAHAM, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-2131 HUBERT CHIN and CIVIL ACTION -LAW ALICE CHIN, Defendants JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendants, Hubert Chin and Alice Chin, with regard to the above-captioned matter. Respectfully submitted, NEALON & GOVER, P.C. By. ~~~ Michael S. Ferguson, Esquire Attorney I.D. No. 83882 2411 North Front St. Harrisburg, PA 17110 Date: ~ ~- tl ~ 03 (717) 232-9900 CERTIFICATE OF SERVICE AND NOW, this ~~ day of December, 2003, I hereby certify that I have served the foregoing Praecipe to Enter Appearance on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Michael J. Navitsky, Esquire Navitsky, Olson & Wisneski, LLP 2040 Linglestown Rd., Suite 303 Harrisburg, PA 17110 ~~~~ Michael S. Ferguson, Esquire [`l nJ <:J ~- C:i ~ ~ c..> l C.; i ~-I ` - 1- -. C_j f'17 _, ~. r- _ _ 'n rT c ~l l-.J " ~ r G; t`ci CERTIFICATE PREREQUISITE TO SERVICE OF A SUHF'OENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SUZANNE H. GRAHAM -VS- HUBERT CHIN COURT OF COMMON PLEAS TERM, CASE N0: 03-2131 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON 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: 03/17/2004 CS on be 1 f I HAEL I' SO ESQ. Attorney for DE NDAN DE11-480114 4 1 6 4 7- L 0 1 C O M M O N W E A L T H O F P E NN S~Y L VAN S A C O UN T Y O F C UM B E R:LAN D IN THE MATTER OF: COURT OF COMMON PLEAS SUZANNE H. GRAHAM -VS- HUBERT CHIN TERM, CASE N0: 03-2131 NOTICE OF INPSNT TO SERVE A SUBPOENA TO PRODIICE DOCUMENTS AND THINGS FOR DISCOVERY PIIRSUANT TO RULE 4009.21 HOLY SPIRIT HOSPITAL MHDICAL RECORDS ORTHOPHDIC INSTITDTE OP PA. MEDICAL RECORDS JOYNER SPORTS MEDICINE MEDICAL RECORDS HEALTHSODTH RHHAB MHDICAL RECORDS SHEPHERDSTOWN FAMILY PRACTICH MEDICAL RECORDS T0: MICHAEL J. NAVITSRY, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGIISON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office- DATE: 02/26/2004 CC: MICHAEL FERGUSON, ESQ. - 03-293 PATRICIA HOFFMAN - 5131637570H19 Any questions regarding this matter, contact MCS on behalf of -MICHAEL FHAGUSON, ESQ. Attorney for DEFENDANT THE MCS GROIIP INC. 1601 MARRET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-257423 4 1 6 4 7- C 0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUZANNE H. GRAHAM vs. HUBERT CHIN File No. 03-2131 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for SHEPHERDSTOWN FAMILY PR4CTICE (Name of Pelson or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEEATTACHED RIDER **** at The M('S ('.rrntp, Ind, 1601 Market Street, S n~ 'ty r_R00, Philade hia. PA 1'9103 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 fight 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 afer 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: MICHAEL FERGUSON. ESO. ADDRESS: 2411 N. FRONT ST. HARRISBURG PA 17110 TELEPHONE: L215) 246-0900 SUPREME COURT ID J1: ATTORNEY FOR: Defendant M/aR 1 7 2004 Date: .~~ - ~U ~~ Seal of the urt B HE CO~~U~R/"T: P [honot•3ry/Cle ivil Divisi 'n >z- ~ Depu y 41647-OS EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL 503 NORTH 21ST STREET CAMP HILL, PA 17011 RE: 41647 SUZANNE H. GRAHAM Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and alll records, correspondence to and from the consulting and/or treating physicizm, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all Stich items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, caze, treatme~at, admission, discharge, or emergency caze pertaining to: Dates Requested: up to and including the present. Subject :SUZANNE H. GRAHAM 5223 ETON PLACE, MECHANICSBURG, PA 17055 Social Security 1f: 19428-9338 Date of Birth: 11-16-1936 SU10-490378 4 1 6 4 7- L 0 1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUB]?OENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SUZANNE H. GRAHAM -VS- HUBERT CHIN COURT OF COMMON PLEAS TERM, CASE N0: 03-2131 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/17/2004 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DE11 -480115 4 1 6 4 7- L 02 C O M M O N W E A L T H O F P E NN S~Y L VAN I A COUNT Y O F C UM B E R:LAN D IN THE MATTER OF: COURT OF COMMON PLEAS SUZANNE H. GRAHAM -VS- HUBERT CHIN NOTICE OF INTEN'P A HOLY SPIRIT HOSPITAL MEDICAL RECORDS ORTHOPEDIC INSTITDTE OF PA. MEDICAL RECORDS JOYNER SPORTS MEDICINE MEDICAL RECORDS HEALTHSOUTH REHAB MEDICAL RECORDS SHEPHERDSTOAN FAMILY PRACTICE MEDICAL RECORDS TERM, CASE N0: 03-2131 21 T0: MICHAEL J. NAVITSRY, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICNAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/26/2004 CC: MICHAEL PERGIISON, ESQ. - 03-293 PATRICIA HOFFMAN - 5131637570B19 Any questions regarding this matter, contact MCS on behalf of MICHAEL FERGIISON, ESQ. Attorney for DEFENDANT TH8 MCS GROIIP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE~02-257423 4 1 6 4 7- C 0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUZANNE H. GRAHAM vs. HUBERT CHIN File No. 03-2131 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HOL y SPIRT HOSPITAT. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: * * * * SEE ATTACHED RIDER * * a[ The MCS Grrn~, inc., 1601 Market Street, Suite R00_ Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to [he 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 afer 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: MICHAEL FERGUSON. ESO. ADDRESS: 2411 N. FRONT ST. HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant MAR 1 7 2004 Date: ~ N~}~f,1. O Q. ~ ~CS Seal oft Court BY~THE COURT:. P thonotary/Cle k, ivil Div s n Dep ty ~~ , 41647-O1 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ORTHOPEDIC INSTITUTE OF PA. 875 POPLAR CHURCH ROAD CAMP HILL, PA 17011 RE: 41647 SUZANNE H. GRAHAM Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians., files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject :SUZANNE H. GRAHAM 5223 ETON PLACE, MECHANICSBURG, PA 1705!i Social Security #: 19428-9338 Date of Birth: 11-16-1936 SU10-490380 4 1 6 4 7- L 0 2 CERTIFICATE PRERSQIIISITE TO SBRVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SUZANNE H. GRAHAM -VS- COURT OF COMMON PLEAS TERM, CASE N0: 03-2131 HUBERT CHIN As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/17/2004 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DE11-480116 4 1 6 4 7- L 0 3 C O M M O N W E A L T H O F P E NN S'Y L VAN 2 A COUNT Y O F C UMBER :LAN D IN THE MATTER OF: COURT OF COMMON PLEAS SUZANNE H. GRAHAM TERM, -VS- CASE N0: 03-2131 HUBERT CHIN NOTICE OF ]10TEN'P TO SERVE A SIIBPOENA TO PRODUCE DOCDNffidTS ] THINGS FOR DISCOVERY PURSIIAN'P TO RULE 4009.21 HOLY SPIRIT HOSPITAL MEDICAL RECORDS ORTHOPEDIC INSTITUTE OF PA. MEDICAL RECORDS JOYNBR SPORTS MEDICINE MEDICAL RECORDS HEALTHSODTH REHAB MEDICAL RECORDS SHEPHERDSTOWN FAMILY PRACTICE MEDICAL RECORDS T0: MICNAEL J. NAVITSRY, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/26/2004 CC: MICHAEL FERGIISON, ESQ. - 03-293 PATRICIA HOFFMAN - 5131637570B19 Any questions regarding this matter, contact MCS on behalf of _ MICHAEL PERGUSON, ESQ. Attorney for DEFENDANT THE MCS GROIIP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-257423 4 1 6 4 7- C 0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUZANNE H. GRAHAM vs. HUBERT CHIN File No. 03-2131 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ORTHOPEDIC INSTITUTE OF PA.. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documen[sorthings: ****SEEATTACHEDRIDER**** at The MCS Gro~~n. Inc.. 1 fi01 Market Street. Suite R00_ Philade hia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing; the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days afer 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 FOLLOV~JING PERSON: NAME: MICHAEL FERGUSON. ESQ. ADDRESS: 2411 N. FRONT ST. HARRISBURG, PA 17110 TELEPHONE: (2151246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant MAR 1 7 2004 Date: ' ~,~ 6 "`C). °~~ Seal of the Court BY THE COURT: ~ o,~. Prothonotary/CI k Civil Divisi~ Depu y , 41647-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOYNER SPORTS MEDICINE BLUE MOUNTAIN CENTER 4800 LINGLESTOWN RD HARRISBURG, PA 17043 RE: 41647 SUZANNE H. GRAHAM Please call for prior approval for fees in excess of $100.00 for hos)~itals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject :SUZANNE H. GRAHAM 5223 ETON PLACE, MECHANICSBURG, PA 17055 Social Security ~: 19428-9338 Date of Birth: i1-16-1936 SU10-490382 4 1 6 4 7- L 0 3 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RIILE 4009.22 IN THE MATTER OF: SUZANNE H. GRAHAM -VS- HUBERT CHIN COURT OF COMMON PLEAS TERM, CASE N0: 03-2131 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, E;iQ. 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 identic~sl to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/17/2004 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DE11-480117 4 1 6 4 7- L 0 4 C O M M O N W E A L T H O F P E NN S 'iC L VAN 2 A COUNTY OF CUMBER7LAND IN THE MATTER OF: COURT OF COMMON PLEAS SUZANNE H. GRAHAM -VS- HUBERT CHIN NOTICE OF II~TSNT TO HOLY SPIRIT HOSPITAL MEDICAL RECORDS ORTHOPEDIC INSTITUTE OF PA. MEDICAL RECORDS JOYNER SPORTS MEDICINE MEDICAL RECORDS HEALTHSODTH REHAH MEDICAL RECORDS SHEPHERDSTOWN PAMILY PRACTICE MEDICAL RECORDS TERM, CASE N0: 03-2131 T0: MICHAEL J. NAVITSRY, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGIISON, ESQ. intends t0 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 imay 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: 02/26/2004 CC: MICHAEL FERGUSON, ESQ. - 03-293 PATAICIA AOPPMAN - 5131637570B19 Any questions regarding this matter, contact MCS on behalf of MICRAEL PERGUSON, ESQ. Attorney for DEFENDANT TflE MCS GRODP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DH;02-257423 4 1 6 4 7- C 0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUZANNE H. GRAHAM vs. HUBERT CHIN File No. _ 03-2131 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 40(19.22 TO: Custodian of Records for IOYNFR SPORTS MEDICINE. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The M('S Croglt, inc 1607 Market Street Suite R00. Philadelnhia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the adldress listed above. You have the right to seek, in advance, the reasonable wst 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 afer 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: MICHAEL FERGUSON ESO. ADDRESS: 2411 N. FRONT ST. ARRI~TS~BiIR(i, PA 17110 TELEPHONE: (2~~46-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant MAR 1 7 2004 a~0• ~VU Date: Seal of the Court B E COURT: Prothonotary/C er Civil Divi>;i n Dep ty ' ~ 41647-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR HEALTHSOUTH REHAB 175 LANCASTER BLVD P.O. BOX 2016 MECHANICSBURG, PA 17055 RE: 41647 SUZANNE H. GRAHAM Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treatmg physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be shored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject :SUZANNE H. GRAHAM 5223 ETON PLACE, MECHANICSBURG, PA 1705'.1 Social Security #: 194-28-9338 Date of Birth: 11-16-1936 SU10-490384 4 1 6 4 7- L 0 4 CERTIFICATE PREREQUISITE TO SERVICE OP A SUBPOENA PIIRSIIANT TO RIILE 4009.22 IN THE MATTER OF: SUZANNE H. GRAHAM -VS- HUBERT CHIN COURT OF COMMON PLEAS TERM, CASE N0: 03-2131 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, E;{Q. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to e°ach 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: 03/17/2004 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DE11-480118 4 1 6 4 7- L O S C O M M O N W E A L T H O F P E NN S `.C L VAN 2 A COUNT Y O F C U M B E R LAN D IN THE MATTER OF: COURT OF COMMON PLEAS SUZANNE H. GRAHAM -VS- HUBERT CHIN NOTICE OF INTSN'P A HOLY SPIRIT HOSPITAL MHDICAL RECORDS ORTHOPHDIC INSTITDTE OP PA. MEDICAL RECORDS JOYNBR SPORTS MEDICINH MEDICAL RECORDS HEALTHSOUTH RHHAB MEDICAL RHCORDS SHBPHHRDSTONN PAMILY PRACTICH MEDICAL RECORDS TERM, CASE N0: 03-2131 T0: MICHAEL J. NAVITSRY, ESQ., PLAINTIFP COIINSEL MCS on behalf of MICHAEL FERGIISON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena imay 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: 02/26/2004 CC: MICHABL FSRGDSON, ESQ. - 03-293 PATRICIA HOFPMAN - 5131637570B19 Any questions regarding this matter, contact MCS on behalf of MICHAEL FERGIISON, ESQ. Attorney fOI DEFENDANT THH MCS GRODP INC. 1601 MARRBT STREBT #800 PHILADELPHIA, PA 19103 (215) 246-0900 D1302-257423 4 1 6 4 7- C 0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUZANNE H. GRAHAM vs. HUBERT CHIN File No. _ 03-2131 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 400922 TO: Custodian of Records for HFAT THSOUTH REHAR (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** a[ The MCC Crny~ Inc 1601 Marke[ Street Cnite ft00 Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the acldress 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 pally serving this subpoena may seek a court order compelling you to amply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL FERGUSON. ESO. ADDRESS: ~A1 t N_ FRnNT ST. HARRICRiiRG PA 17110 TELEPHONE: ~~l 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant MAR 1 7 2004 Date: ~ ~~ Seal of [he Court B THE CO~U~ R^T: ~C, A' w~ Prothonotary/Cler , ivil Divisian~ L-U,.~- C~,L Depu y 41647-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SHEPHERDSTOWN FAMILY PRACTICE 2140 FISHER ROAD MECHANICSBURG, PA 17055 RE: 41647 SUZANNE H. GRAHAM Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : SiIZANNE H. GRAHAM 5223 ETON PLACE, MECHANICSBURG, PA 1705:1 Social Security N: 194-28-9338 Date of Birth: 11-16-1936 Sif10-490386 41647-LOS PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please. list the following case: (Check One) (X) for JURY trial at the next term of civil court. ( ) for trial without a jury. (CAPTION OF CASE, entire caption must be state in full) (check one) (X) Civil Action -Law ( ) Appeal from Arbitration ( ) (other) SUZANNE H. GRAHAM, Plaintiff(s) Vs. HUBERT CHIN and ALICE CHIN, Defendant(s) The trial list will be called on May 22, 2007 and Trials commence on June 18, 2007 Pretrials will be held on May 30, 2007 (Briefs are due 5 days pretrial.) (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. 03-2131 Indicate the attorney who will try case for the party who files this Praecipe: Jenni Henley Allen, Esquire Indicate trial counsel for other parties if known: Michael J. Navitsky, Esquire This case is ready for trial. Date: NEALON,dG~~R & PERRY By: r)1i Henley Allen, Esquire tt rney I.D. No. 84311 rney for Hubert and Alice Chin 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 r-~ a n 4 ~_ ~ . ~ t..r, ~. p-~ ,.+ ~~ -'f' yu '. ` _ r ~ ~'1 'l ~ E~ {'~ '~" "~~ ,~ a ..C ~ ~ SUZANNE H. GRAHAM, Plaintiff v. HUBERT CHIN and ALICE CHIN, his wife, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA N0.03-2131- Civil Term CIVIL ACTION -LAW JURY TRIAL DEMANDED PRAECIPE TO DISCONTINUE Please mark the above-matter ended and discontinued. Respectfully Submitted, Suzanne (Grab ) Gons 28 Cardamon Drive Mechanicsburg, PA 17050 Date: ~d ~ ~~ ~~~ Respectfully submitted, NAVITSKY, OLSON & WI NEST ~` J ,r /~~' U Michael J. Navitslc~yy,~squire I.D. No. 58803 2040 Linglestown Road, Suite 303 Harrisburg, PA 17110 717/541-9205 Counsel for Plaintiff Date: CERTIFICATE OF SERVICE I, Jessie K. Walsh, an employee of the law firm of Navitsky, Olson & Wisneski LLP, do hereby certify that I am this 19th day of February, 2007 serving a true and correct copy of Pracipe to Discontinue upon all counsel of record via postage prepaid first class United States mail addressed as follows: Jenni Henley Allen, Esquire Nealon & Gover, P.C. 2411 North Front Street Harrisburg, PA 17110 Counsel for Plaintiffs -'~ ~.. ~~ Jessie K. Walsh n ~ o c- ~ „ ~ Y- ~ ~ ~~~ ,~, ~ _~, ~~~ Q ~`' ~ c' ~~ = { ~ e~~ , ~; ~ SUZANNE H. GRAHAM, PLAINTIFF V. HUBERT CHfN AND ALICE CHIN, DEFENDANTS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-2131 CIVIL TERM ORDER OF COURT AND NOW, this ~ day of May, 2007, this case having been discontinued by plaintiff pursuant to Pa. Rule of Civil Procedure 229, IT IS STRICKEN from the June Term trial list. icha I J. Navistky, Esquire For laintiff enni Henley Allen, Esquir For Defendants Court Administrator .~ :sal Edgar B. Bayley, :~ ~~~• ~,~in _ '~'a"'efr'~',~ i ~ I ~~ 0 ! ~~~~ LQQZ ~ "i:? ~-~1:~~11~