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Home My WebLink About01-2767 FX ~ .,. , ' " ,,= _ .', ".. '_0 ",- ;~ ;;.\1";", 'i'''", ,', -"-." , '~ ";,,'4.."_ " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HENRY LINE and CONSTANCE BENTLEY LINE 191 Ridge Drive Carlisle, PA 17013 CASE: 01 - 2767 Civil Plaintiffs CIVIL ACTION - LAW v. JURY TRIAL DEMANDED MICHAEL SCOTT 326 Dorothy Drive Pittsburgh, PA 15235 Defendant. ORDER And Now this _ day of July 2001 upon motion of the Plaintiffs it is hereby ORDERED that the Plaintiffs may make service upon the Defendant Michael Scott by: a. Mailing by 'Certified Mail - Return Receipt Requested' to the insurance carrier listed on the police report as insuring the Defendant at an office of Allstate Insurance Company within the Commonwealth of Pennsylvania; AND b. Mailing by 'Certified Mail - Return Receipt Requested' to the Pennsylvania Oepartment of Motor Vehicles. BY THE COURT J. [" . ~h '," - " ,~"", " .~'" .. ' ." .0'. "'" ',~ , ;z:,;'i .. ,> IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HENRY LINE and CONSTANCE BENTLEY LINE 191 Ridge Drive Carlisle, PA 17013 CASE: OJ - ,;)7& 7 (~ Plaintiffs CIVIL ACTION - LAW v. JURY TRIAL DEMANDED MICHAEL SCOTT 326 Dorothy Drive Pittsburgh, PA 15235 Defendant. PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY/CLERK OF SAID COURT: Please issue a Writ of Summons against the Defendant, MICHAEL SCOTT, in the above captioned case. Respectfully submitted, Joseph B. Sobel, Esq. lID 17715] Attorney for Plaintiffs 212 North Third Street Suite 202, Cranberry Court Harrisburg, PA 17101-1505 ByKAIN,;;;;P:SLLP M3rc'G. Tarlow, Esq. lID 23474] Attorney for Plaintiffs 119 East Market Street York, Pennsylvania 17401 Tele: (717) 843-8968 fax: [717] 843-5664 DATED: May 3,2001 ***** SUMMONS IN CIVIL ACTION TO: MICHAEL SCOTT 326 DOROTHOY DRIVE PITTSBURGH, PA 15235 HANOVER, PA 17331 YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFFS HAS COMMENCED AN ACTION AGAINST YOU. 0. ,_ .( j) " --,U'l-Lw / ^-~ Protho otary/Clerk, 9vil fivision _ BY: ", / /J/..l . Depu Date: '-n~ 7. ;(O-VI ~~~~<!j,",-'1;i1;'E',ti~~fu!cl~jllil>'&l\Milil\Htilll0*"t,;@J;;,!!~;'I;M\1'i&kI!1'cl.~~~~!iIlltI:ilil!li.~ ~ ...... -- -- ~ \00> ',D \~ ,~ " -- <:3 ~. '" -- -'\ ~ '-.-" '^' -'-j:r~~1. 1~ ~j G..' I -e,-." c::- ~ "" ~' ~ ~ l"'- e.... ~ -, = ~ m: z: l/l: -I: ,.. :.J .~ rrlt,'1 o~ - ~~ <i !'I -'I 1.,,','1 1':, ~I r- . i I' !, cg 0 <::> b c: -n s: 3 --, -00:1 )~ -,,- rnrr' -< ~'I1~~ z::X? I -'ottl :zc;:: .-J :')'"r''' ~~~7 ~~)i r::B -0 0,- - ~~~~ PO 2:Cl r:- om p- c: ---I ~ 0 ~ (.0 C< _, J Ie ~ ", ~' ,,, 0"',,,,;, '-,;, ", ':' '~' , - "'Ii;;; , . , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HENRY LINE and CONSTANCE BENTLEY LINE 191 Ridge Drive Carlisle, PA 17013 CASE: 01 . 2767 Civil Plaintiffs CIVIL ACTION - LAW v. JURY TRIAL DEMANDED MICHAEL SCOTT 326 Dorothy Drive Pittsburgh, PA 15235 Defendant. PRAECIPE TO REINSTATE THE WRIT OF SUMMONS TO THE PROTHONOTARY/CLERK OF SAID COURT: Please reinstate the Writ of Summons against the Defendant, MICHAEL SCOTT, in the above captioned case. Plaintiff's Address: 191 Ridge Drive Carlisle, PA 17013 Respectfully submitted, Josepb B. Sobel. Esq. lID 17715] Attorney for Plaintiffs 212 North Third Street Suite 202, Cranberry Court Harrisburg, PA 17101-1505 BY: Marc G. Tarlow, Esq. lID 23474J Attorney for Plaintiffs 119 East Market Street York, Pennsylvania 17401 Tele: (717) 843-8968 fax: [717] 843-5664 DATED: June 6,2001 ***** SUMMONS IN CIVIL ACTION MICHAEL SCOTT DOROTHY DRIVE GH, PA 15235 YOU ARE NOTIFIED TH AGAINST YOU. Date: NTIFF HAS COMMENCED AN ACTION BY: Deputy' ~mJii~OO~oli'>t:ljfj!:~~';'itM!.lh!!!~~~ff;j't!'b~~-&:.ili-'t~j"";,ii&l;;,;,ii,.-"",irN.;4i>~~<llti!:& ^ ~ 0"", ~ ~ ,',~~,O,N~'," " ..,",,",,'" _,_""- "~', ..',",''''' .~"",,..' " '~,~ "...~IIt'ii"~'"'..~.JJ.Jj .' ", ,~, ,'_ "",- ,W, , ,,"- -~ I.: . 1 i I I " , , Ii h !; () 0 0 C "Tl <'" L -oa~ c::: mr'il z "T1 ZT r z~' .~-:P~ (j) ~, -<~,: w -- -' "-- r:c' ~~~~ :< -0 :2?;l) :--.L~ :;;:0 r;~ 6~~ c Z --1 =<! ;'0 )> ::0 -< , ~,,, -, - ,=,,~" _' I. --=- ~~~"'"""". ' .",; , ~'"""'" ~ ,,,', j' - - ~;'~\ .. . SHERIFF'S RETURN - OUT OF COUNTY , "" .. CASE NO: 2001-02767 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND . LINE HENRY ET AL VS SCOT MICHAEL 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: SCOTT MICHAEL but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of ALLEGHENY County, Pennsylvania, to serve the within WRIT OF SUMMONS On May 25th , 2001 , this office was in receipt of the attached return from ALLEGHENY Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep. Allegheny Co 32.25 .00 69.25 OS/25/2001 KAIN, BROWN & ROBERTS ?!J omas Kline iff of Cumberland County Sworn and subscribed to before me this .li '!f:' day of C}...~ :ktJ1 A.D. ~~t~t~ . ~, ~ ~,-. H~ L', ' ;, Cj-" ~", ,.,~:, ',_.', ,. '(~g ... ~ .J>- . . ""l~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HENRY LINE and CONSTANCE BENTLEY LINE 191 Ridge Drive Carlisle, PA 17013 CASE: Ot- cR,'7&7 (!.{~ Plaintiffs CIVIL ACTION. LAW v. JURY TRIAL DEMANDED MICHAEL SCOTT 326 Dorothy Drive Pittsburgh, PA 15235 Defendant. PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY/CLERK OF SAID COURT: Please issue a Writ of Summons against the Defendant, MICHAEL SCOTT, in the above captioned case. Respectfully submitted, Joseph R.Sobel, Esq. [lD 17715) Attorney for Plaintiffs 212 North Third Street Suite 202, Cranberry Court Harrisburg, PA 17101-1505 ByMIN' B"l;:g;:;s LLP M.!U'c'G. Tarlow, Esq. [lD 23474) Attorney for Plaintiffs 119 East Market Street York, Pennsylvania 17401 Tele: (717) 843-8968 fax: [717] 843-5664 DATED: May 3,2001 ***** TRUE COPY FROM RECORD In TwtIlnonywher8Of. I b8I8 unto_ my hand and the staI or said CGU at Cartl~, PI.. fhl 1M d I .' a-D 1Jf fV SUMMONS IN CIVIL ACTION TO: MICHAEL SCOTT 326 DOROTHOY DRIVE PITTSBURGH, PA 15235 bl'rIlLE:F\, P'.. .. H1 YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFFS HAS COMMENCED A AGAINST YOU. c Date: '~ 7. dOv/ / fY'- Prothonotary/Clerk, Civil Division . BY (pLd~"'Jt7- , / " Dep ,~ ,,' --,' ," " , ~iMl1H~~I~,,,",,.,,,.;,jPlt~molKi~~\il~I,.,:{JO,;101~~g~&l~IW$~~~- [l:tu~ ~' ~ .......' 1.:~, (~~,- "....- - -.<.~ ~, '"~ ,~ ''jr''.k =-~~ ~mm -'. . _ '_...._,0., ~^_~~ ,,' = ~,O, ,~~ ,~ ...... ~~ if ,. 'f t~ .. ii;' i" r Ii I' I. 11 'I I' I! Ii I, l~ !~ ![ 'I ~ , , i ~ ~ S~ <:;: -- 83 3:c ;;!; :,.-. 0" ,~ ,- ._~;;:.; :t';,., ~Q -. "1 (f) .. N --I -< , '" r:- -- g ,..-j <: (i;, 6l ,:.;. I -0 >!j r;-. = -~ Z ::.:I:' ~ ,:;11 J> = ..., ~W'I ~ j~ 1_,~,'j L~;:J @1i.;) \. ."", . .-_."""""'~, ~-~ '" ,~~ ~ ""~~ilw""~~ ^^~".~"....~ t;.W'L:<>15 In The Court of Commotl'Pltas of Cumberland County, Pennsylvania Henry..:... LjI}~, et~s~l. \ '25 C, ^< Michael Scott ',./\1.0 ~ ~~~(U\lf.. No. 01-2767 Civil Now, 5/9/01 , 20 Q ~ , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Allegheny County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. . .' ~~~~t Sheriff of Cumberland County, PA Affidavit of Service Now , o'clock , 20_, at M. served the within upon at by handing to a copy of the original and made Imown to '5- \ 1..-0\ OO:f.s,-,"" ~'j.c \~ ~~ p...".. ?...,.....,~- ~~ L ',0"" t'---- the contents thereof. So answers, -- ~I'<:-' C~ .,.... Sberiffofr!A )f~ty'PA ~~i~CE" ?J-j.,.~<, ..f.'....... .J MILEAGE" AFFIDAVIT ~ ,aD Sworn and subscribed before me this _ day of /II/!' j :r I 200L- Nptarial Seal . Sheila R. O'Brien. Notary Public Plttsbur\lh II,lIeqheny County Mv Com'Tfh':';101l Ex 'e~" ,lune 19. 2004 Mooiher. l';;e'r;r~ar:j"" ~....00c\... iOOQ1 NotafieS $ 23S,d--<) ~ ;L, . . ~' - d ;:'-::"'_""~,~,,.,~ ~"'<'-~'o<",".',,,,,~,- , "". -'1 ""'~"1~~~ ... s HENRY LINE and CONSTANCE BENTLEY LINE, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 01-2767 CIVIL CIVIL ACTION - LAW MICHAEL SCOTT, Defendant JURY TRIAL DEMANDED IN RE: MOTION FOR ALTERNATIVE SERVICE ORDER AND NOW, this 2. -.; day of August, 2001, upon motion of the plaintiffs, it is hereby ordered that the plaintiffs may make service on the defendant, Michael Scott, by: a. Advertisement in a paper of general circulation in the city of the defendant's residence, AND; b. Mailing by both regular and certified mail - return receipt requested in care of Patricia Evans, 326 Dorothy Drive, Pittsburgh, PA 15235, AND; c. Mailing by certified mail - return receipt requested to the insurance carrier listed on the police report as insuring the defendant, at an office of said carrier within the Commonwealth of Pennsylvania. :rIm BY THE COURT, ~{,o\ V'\~ Marc G. Tarlow, Esquire F or the Plaintiffs ;~~l_~~Ml~'lliJiW'il'!i!il!iH...~~~J-ai&!.ili!'."_~'Il;i;ili;'~~!i!lll~~i:;" ~~~ ""''''. .~ ~< \v\Lf VINVAlASNN3d JJ.NflOCJ m~~n:jj8\111na "11'" "d 7.- "1'1'" 'n 1 ~c., f-; '_. .; 11 I '-I AtJ\:I10!K)HlC 38;j:l(}-(T:r:l~ ,}(1 -'''-' ,~, .- ~"~'.:iJlij..Jii -- f~.lli.ijiLl;i;HlIJil1:11 -,.~~_", ,'~' U~ " ... 1",'. "H " Ii{ In l' '!J I; ,i] R. fti !l ~ Ii !~ ~! ;l 1 i , , , I ~ . -- " ~ " ' --,- ~,~" ~ -~ ~,' .'.'IliI~' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HENRY LINE and CONSTANCE BENTLEY LINE 191 Ridge Drive Carlisle, PA 17013 CASE: 01 - 2767 Civil Plaintiffs CIVIL ACTION - LAW v. JURY TRIAL DEMANDED MICHAEL SCOTT 326 Dorothy Drive Pittsburgh, PA 15235 Defendant. MOTION FOR ALTERNATIVE SERVICE PURSUANT TO RULE 430lAl Plaintiffs by the undersigned counsel hereby file this motion for Alternative service pursuant to Rule 430(a), the following of which is a statement: 1. Plaintiffs have filed a summons dated May 7, 2001, naming as Defendant, Michael Scott. 2. This action relates to a motor vehicle accident that took place on June 5, 1999. A description of that accident is contained in the police report, which is attached hereto and incorporated by reference herein. [Exhibit 1]. 3. A skip trace was performed to find the whereabouts of the Defendant. [Exhibit 2]. Based upon that skip trace and subsequent investigation, it is clear that the Defendant lives in Pittsburgh Pennsylvania. An address was found, and based upon that skip trace the summons was sent to Allegheny Country for service. However, the Sheriff was unable to effectuate service at the location obtained by Plaintiffs. [Exhibit 3]. 4. Thereafter, Four Star Investigations P.O. Box 17370, Pittsburgh, Pennsylvania, performed an even more detailed investigation, a copy of which is attached as Exhibit 4 and incorporated by reference herein. This included review of Defendant's property records, canvassing of neighbors at the last known address, and review of criminal and tax records. More than a mere paper search was made. c ~ "' """ I'':;, . .~"., ~ --,' ~"=""'. "- "; , ~' do ~ 5. As can be demonstrated by that investigation, the Defendant has effectively concealed his whereabouts, and certainly can not be served by the busy sheriff's office of Allegheny County which requires a specific time and place for service. 6. Based upon this record the Plaintiffs allege that they have made more than a good faith effort to locate the Defendant and attempted without success, to serve the Defendant through conventional means. See 2 Pa. Std. Practice ~10.103. In light of the very mobile nature of the Defendant's existence it does not appear practicable to require that notice be handed directly to him by the Sheriff or otherwise. Accordingly, Plaintiffs request by this motion relief pursuant to Pa. R.eiv. Pro. No. 430(a). 7. Consistent with precedent and common sense under the circumstances the Plaintiffs contends that service of the summons (and along with a copy of the police report attached hereto as Exhibit 1) can be practically made in each of the following manners which should provide actual notice to the Defendant: a. Mailing by 'Certified Mail - Return Receipt Requested' through the U.S. Postal Service to the insurance carrier listed on the police report as insuring the Defendant at an office of Allstate Insurance Company within the Commonwealth of Pennsylvania. b. Mailing by 'Certified Mail - Return Receipt Requested' through the U.S. Postal Service to the Pennsylvania Department of Motor Vehicles. It has been verified as per the attached Exhibit 5 that the Defendant has a valid Pennsylvania driver's license. It should be reasonably expected that the Defendant's insurance company and the Pennsylvania Department of Motor Vehicles that has licensed the Defendant to drive should know the Defendant's whereabouts. Such methods of service have been court approved in , other cases. See 2 Pa. Std. Practice ~1 0.1 05-6. 8. Because of the legal precedents upon which the Plaintiffs rely are contained in this motion, the Plaintiffs request that they be excused from the necessity of providing a supporting brief that would only be repetitive of what is contained herein. J"'" .o,~~ ,,'.": - ~, . '.' "";"J ,'",. - '''''W-, Wherefore, Plaintiffs respectfully request that this Court grant an order substantially in the form attached hereto permitting alternative service upon the Defendant. Plaintiff's Address: 191 Ridge Drive Carlisle, PA 17013 Respectfully submitted, Joseph B. Sobel, Esq. lID 17715) Attorney for Plaintiffs 212 North Third Street Suite 202, Cranberry Court Harrisburg, PA 17101-1505 DATED: July 17, 2001! BY: Marc G. Tarlow, Esq. lID 23474) Attorney for Plaintiffs 11 9 East Market Street York, Pennsylvania 17401 T ele: (717) 843-8968 fax: [717] 843-5664 " , ,'~ , ,-:, -" -~ 4" 'i' ; ; ,,< ..' - '" . 0' ~. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HENRY LINE and CONSTANCE BENTLEY LINE 191 Ridge Drive Carlisle, PA 17013 CASE: 01 - 2767 Civil Plaintiffs CIVIL ACTION - LAW v. JURY TRIAL DEMANDED MICHAEL SCOTT 326 Dorothy Drive Pittsburgh, PA 15235 Defendant. AFFIDAVIT OF MARC G. TARLOW. ESQ. I, Marc G. Tarlow, Esquire, am an adult individual and hereby state as follows: 1. As co-counsel for the Plaintiffs Henry Line and Constance Line, I caused the summons in this mattjlr to be filed. 2. Before' filing that summons my office contracted a private investigator to perform a skip trace on the Defendant which gave an address for Defendant in Pittsburgh as listed in the caption ofthis action. 3. The summons was transmitted to Allegheny County for service. When the Sheriff of that County indicated that the Defendant was reported to not reside at that address, this office hired a private investigator in Pittsburgh to locate the Defendant. That investigation was thorough and demonstrates that the Defendant has no "fixed" address. 4. I believe that we have done all that is practicable to locate the Defendant, and that even were an investigator able to observe the Plaintiff at a fixed location, that because of the mobile nature of his life style that such a sighting would not be sufficient to arrange "conventional" service. by the Sheriff. - ,'- -, I' ~_ .,', I" ~J _ :",_1' -,' '~'~j~~c 5. I make these statements based upon the best of my knowledge information and belief. Date: JUl.-4 (0( . :J.. 00 J , . Marc . COMMONWEALTH OF PENNSYLVANIA COUNTY OF YORK On this /11'11 day of July, 2001, before me a Notary Public, in and for said County and Commonwealth, personally appeared Marc G. Tarlow, Esq., known to me or satisfactorily proven, to be the person whose name is subscribed to the within instrument and in due form of law acknowledge the within instrument to be his act and deed. IN WITNESS WHEREOF, I hereunto set my hand and official seal the date and year aforesaid. ~A.. x:: 7fSEAL) Notary Public NOTARIAL SEAL BRENDA K. TOPPER. Notary Public Cily 01 York, York Counly Mv Commission Exnlres March 4, 2002 My Commission Expires: Cert of service at last and best known address. lU.'~5/,)u Ift:;U ".",. =~iJ~ 1.1~~'i"~~:,~~t_,~".I_:, ,'_, . ':~ ~ ~. . ~~.~j"ill~I!l!~_;nltl!:u"~,,,,,,t:;;,,,, Nf\ @ 00114j,-.::'U CO_NlWALlH OF PflNHISYl.VANIA POLleE ACCIDENT REPORT ~r_' ( -._.....1,:] HARR1~auRG ..1JlW 1 ~ . RUeSt TO 0\$a,A'I SHUtS ~~~;~;,,~..J~_:51tM '" ~=t':-fg2 'I070~(,p_q ...___.__. -. 8?u. 'Sl~"~ t.L..--rE-.--....- .-..- I ~., -o.P,t.tl'Ot. _C""'T~~,,. ~____ '~_"1J_.. ~.m-&1<g"t -_._~:tp]..;2p.-.- L,; -, .~ --- "--- -- ~ ~.~ " ......- l'ilrAlVVf'4 , ""~ T", 2.IZI t .~.:: . .....; :;l", .*!;....;:~f.;~ ';'.~:t:. N. COIMn' "t"'lJ~li?1 A...)D .____ 2.1 . Haiia'.... """" ..5~lS".6.sP;2 '~~ '2.11. PRINCIPAl. RO WAYINFORMATION ii""Aou'n:lC),OJt ._-~ ;]."., ," .lYP'l a __l"", 50 _, I~Z. INTERSEcnNG ROAD: 2I.~HO"~ "'... nlllUT ~ ,9. 2'f~--.~' ~,;9;.r;.flk:.l~1-'L h--tiJ.r.... '?&'C... ..., _.._ ...~___t:.:~y . """r_ ,,~~!___1..!~"-_._... .--L' Of"":' 3 IF NOT A TlNTERSECTION: I: "'KUa> 0 f'.......", I 1"'~~~Ti-;;- ~_.;;;:~~.= t-tP~ . ,'9.aD'YtHIClt,ofA\lEroBE i'T,\If1fc.t..E~ r-J' ),.~C1~~S Ewj3l~"""AfU . I M&cJYf.D F~T11ESCfJE.7 o. NONl l,.MJ I . 2. J:~, ,~am: FT. : r,:'" 'r" ,..\INl1 ~ ~ ! ;.' =...... ~'-"'J' >),. "",t .... -...to 0 _no Xl \ ., ..bl f'ol..J "\ ~ NiX. I 3.$lvtt'E UNfT1: Z (1-'~. "" OJ tii.1TFPFIC pucpAl" ~ . I ~.... '''''" 'J ~ CBJ B '" """""""- C' [" '..,..,...,.,r rl ('" . I"""", - , ";'TE~.S ~.J N .. ~ v. ... I -.l... I.. ',:.i.~~:~~t.~f,,:~-.;:~'~,......,uearr:.1~~~':C~.>'~.~.;,.:.,'." .::. ~~.;i.: ';:::~...~~~~~~J~;~~:~~~~,~;r' .' 'f:r~~i~~f\. rt'~~,oal"':"\ AE"'I~@, I~. ":}""::,~,YCl '~11! 3O-plATmTOO _. -.... - - .--L-.:.~~... ~~~~~__rN 1"''''~_'1lB1.':1{.~L........_ ~~:...."'" ?5S'l~~<;lQ~\"1, .. l.,~~.-5~.~~__._.___..__ __ :~~,\\,,~_-_-_-__-,,-..._, .. ~~ ~ t.._. . """"-3& 2\ - .. - - . '---, 1 "'i~ ---ft)~-M---:"~:-U q'~~:'~~13--- '~- .s " o::.::t;'-----~-'- ..:WHf . I~"- ~~C>f f"'-"""'T . ~.-/... 4~'~ MJ~_...- L-""""""' 1 Y la.O _0 110O\'..' .''''''J~,.Jb "'1.1S! 's; y t.:J NO _0 -.14Mn c.J ;iPEf-iii'u 0 4I..}vr~ ... - .u~~ - .~cw. .- 1~ I - n""I 0-, ... U6IlGt .., ~ ... .... ~ 0<<' '.... ~ 0 "- ame... ..,......""""CT \2 .;;\'!iCU1 -.... "'". Vfi-,,;:: "',........-~_llCf '..) . POWl" -.TAt.,..............,,, "'_ -:rrAtuO 0 Q ~~., I ";'""" ----. '~:""'ION ._\ ':;)1_ . _ r\l "" "'.~ CULl '1',$T~~ 5i.:DANfP - -1". _R S \'\\.. ~~S&.._M' n~__' ...= o.3:L..j.:~+ \ ~~___ ..L ..~ ~~'tL.______ ...~ U,'-..II( ~U&. ~ ~ ~~t>.t.....,\. . .-........ ~~<..""...~ ....~ tC ...~ C'_..Jh l.~14 ""ax l._.... .. .C~ ....... 01' "'.< \--..... """" ...- . ," ...,.,. ....,~...... ,'" CCUiI.~. . ~ ,,!}t, l:QtJII. vEK 'm MM.R ,YO" ClAIS TON tl..A$G I'i . CNREA .1. ~...~ .-.- ".c.NtIUE.R __ Illi>oIi5lI it-:c:mr.81Alt ..--....-----.- n.r.rrv.ITATE .~ .~ ... .....u=ii~' ---- I~ : ~!JCj. . T"l'PE :..J~I.1. .. "" 1: -- . llI'.......T ". ."" _ ...-" yON 0 ....0 AIU> ....-.. _ ~1"'" --' - -- ._ -'U_ 2845842 ~. . , 71. TO.. 0 \.OOlQJ ......,.,.. ......-rc . EXHIBIT 1 .....:- "1_.1 ~~i"<',"<, ;'';'''. ~_ ~~~l' 1 ~j.' .:.;) tjV.~_~!:,~''\.~ il~.~~__ ,_.~.. Iir" _111I10'" ""~ oJ, .;'.......iJ~"'~, I ~'_, _" ~.~_~~~I " ___li. ';",;;i.c ,'. ." ~'i!ii,j;,j'l;bwm, j.1).'..Vfl)v \l.C.~" J.";:)'iLrrl.A 11,. ,6:J.J..) ,',ii!"" ~- - '.~ '" ., ~ '., ..r.:~.;;:~ J - t_: ~ '::,~Wili~, ,""",,.;,,-,,,,,~J.' ,~~ . ""~"l~"'II; "'"j,~;';ii;"",., M ~"Willt;Ii1Jijill-i.-,': lU/.:,t)iUU ~tt..'lJ l.J;,')':} l<'A.\. c , 't , , "" ..' ~~ '"" , .' .. '=';"--'- '-""\ ~": D~8 INFORMATION NETWORK ASSOCIATES >Nt P.O. Box 60515 Harrisburg, PA 17106-0515 (717) 612-9600 (800) 443-0824 Fax (717) 612-9700 April 18, 2001 Ms. Andrea Blouse Kain, Brown & Roberts LLP Attorneys at Law 119 East Market St. York, PA 17401 Re: Henry & Constance Line I Dear Andrea: In regards to your facsimile request d$.ted Ap;d,l 17, 2001 with regards to a current address for Micha~l Scott, whose last known address is 17 Boyd Avenue, Jersey City, NJ, this report contains the results of Information Network Associates 1 Inc.' s ("INA") investigation to date. Utilizing the last known address above, INA's investigation has yielded the following address history for a Mr. Michael Scott, age approximately 45-50 and social security number 107-46-5760: Address Date Reported 1) 326 Dorothy Dr. 01/01 Pittsburgh, PA 15235 2) 17 Boyd Ave. 03/92 Jersey City, NJ 07304 3) 549 W. 26th St. 08/91 New York, NY 10001 Andrea, please call me should you need to serve legal process on Mr. Scott in Pittsburgh, PA, and I'll be more than happy to refer you to a pri vate investigative and legal process service firm in Pittsburgh, PA that is both one of INA's clients and is affordable and reliable. EXHIBIT 2 Ms. Andrea Blouse April 18, 2001 Page 2 l.od -" '. '" .1 ..,:,f ,~~, Andrea, as we discussed on the telephone, INA's investigation to date has also yielded three (3) names that could possibly be the owner of the vehicle driven by Mr. Michael Scott. They are as follows: The information however, if you have is required, please Network Associates, re.quirements. DPR:wl 1) Jocelyn Scott 17 Boyd Avenue Jersey City, NJ 07304 SSN: Unknown 2) Joscelyn F. Scott Address: Unknown SSN: 262-46-7027 DOB: January 1927 3) Joscelyn F. Scott SSN: 091-42-8963 Address: 243 Jewett Ave. 1 st Floor Jersey City, NJ 07304 contained in this report is self-explanatory; any questions, or if additional investigation advise. Thank you for using Information Inc. to fulfill your investigative Very truly yours, Information By: Daniel 'A.' ~.u"";'--";;"";--'m-:Y; .,~ ~ - ,". - -.~ -~; ~ ",- ~ ,-- - -~ . ~:;t '\ In The Com:t of Common Pleas o.f Cllmbe:dand CountY, Pennsylvania Henry Li.ne, et~s~l. <2( C, ^< Michael Scott~\\V ~~\"" \)(J(Ur\\-tl.l\-D Q.\ \lL No. 0 1 - 2 7 6 7 C i v il \--8\t 9A- \ '5h~ ~~, -'- Now, ~!9!Ol , 20 ill () , I, SHERIFF OF CUlvIBERL.A...1\i"I) C01Jl'-..TTY, PA, do hereby deputize the Sheriff of Allegheny County to execute this Writ, this deputation being made at the request and risk of the Plaintii'i'. . ~(2/ ~ ~-" '1: ~~:llo~;~ f~'" SheriffofCurnberiand Coumy, PA Affidavit of Service Now, 70 . ,__ _,aL o'clock M. served the within upon at by handing to a copy OIthe original and made lmown to S-II..-o\ Do~s~,"""" U\....,.e= '\\~~ . 'f tl1e -contents u"1.ereo . So answers, f><o->1~.c;. t?--=- ?"""~,~- ~""-'-".S L'..:o6 ~__ TIle u~s day of i~~',:." " /' -.!i2i)' '...~....- u~c~~ Shdnot ,/~...j, 1(' ,".' f,-1l...coun:ty, PA "9~".1 U fJ'''ef.2-F .:/... :':~..~A~.., ! .F{..~V;(:...,.:t)r~" , ,,,'t. i' _~"., ~ - 1 .;;.I rOS~l'Q , '-' U ''')._. r SERVICE::>",:).,,'J.,\ MILE.t.,GE .-'\FFIDA \flY ~ ,C'O , Swam and subsc~ibed berore $ ~~..L~ $ 3),~~ ~ Notarial Seal Sheila R. O'Srien, Notary Public I Pitlsbl.lfl~h. A,lIi?'1he!'i\Y County I Mv (.Vf'fl''1''!~ . ~ron b 'f:!~~ Jun~ 19. 2004 \ ~('mDr;.. ,':':er;i:;:'SYI\lili:;"". ..,SC)C[;' :on 01 Notanes EXHIBIT 3 .,-- e" '~_ '.' ". ~ ~, ',h ' " '~., '. ' _"'J.~"~:, * * * *FOUR STAR INVESTIGATI,ONS P.O. BOX 17370, Pittsburgh, PA 15235 412-798-9300 FAX 412-798-9302 July 2, 2001 Ms. Andrea Blouse Kain, Brown & Roberts LLP Attorneys at Law 119 East Market Street York, PA 17401 RE: LKA: Michael Scott 326 Dorothy Drive Pittsburgh, PA 15235 SUMMARY OF INVESTIGATION Following your request, investigation was conducted to locate the subject, Michael Scott. Unfortunately, after following numerous leads, the most recent physical address we could find for the subject was the 326 Dorothy Drive address. We know, however, that it is a possible girlfriend of the subject's, Patricia Evans, who actually lives at Dorothy Drive. We feel certain that Michael Scott probably visits this location on a regular basis and that Ms. Evans will go visit Mr. Scott wherever he is physically located. We are equally certain, however, that Michael Scott does not, on a regular basis, live at 326 Dorothy Drive. INVESTIGATION (1) SOCIAL SECURITY RESEARCH Since we were provided with a Social Security Number for Michael Scott, we initiated our investigation by conducting EXHIBIT 4 "' ., ~ ,'.:,t ,- !1,_ - ~'"'~iWi>!,~,,- Page 2 a research of that Social Security Number by way of computer. The only address they had for Mr. Scott, according to the search, was the 326 Dorothy Drive location. (2) LISTED RESIDENCE ADDRESS - 326 DOROTHY DRIVE, PITTSBURGH, PA 15235 We then continued our investigation by physically going to the neighborhood at 326 Dorothy Drive. We found this to be a one story ranch style single family structure located in a racially mixed lower middle income residential area of Penn Hills. In attempting to canvass the neighborhood, we found no one knowledgeable of the subject, Michael Scott. Sources did state that a female resides at this location but her name was unknown. Sources added that an Annie Bradford is the actual owner of the property at 326 Dorothy Drive but does not live at this location and merely rents out the property. In addition to neighbors, we also tried to contact someone at the 326 Dorothy Drive location. On Tuesday, June 19th at 11:50 a.m., however, we found no one to be inside the house. There was an older Ford Explorer bearing PA registration #BXW-2373 parked in the driveway. We terminated our handling in this neighborhood. (3) ALLEGHENY COUNTY TAX ASSESSMENT OFFICE Through the computer, we were able to punch in the property address at 326 Dorothy Drive, where we confirmed the fact that an Annie N. Bradford is the listed owner. A photostatic copy of that information is enclosed. (4) PENNSYLVANIA DEPARTMENT OF MOTOR VEHICLES - HARRISBURG, PA We then conducted a motor vehicle check through Harrisburg, running the license plate number of the vehicle parked in the driveway at 326 Dorothy Drive. As a result, we found that license plate number, BXW-2373, is registered to Patricia A. Evans at 326 Dorothy Drive, Pittsburgh, PA 15235. "" , < , '..:i\C' ,~~~-'-"-" ~- , ",,' -,~- ^, ,- - , ~,. '- L i~ Page 3 (5) CONTACT WITH ANNIE BRADFORD - 200 SOUTH PACIFIC STREET, PITTSBURGH, PA 15206, PHONE NUMBER 412-361-6626 We then continued our investigation by locating and then interviewing Annie Bradford, the owner of the property at 326 Dorothy Drive in Penn Hills. In speaking to this woman by phone, we found her most cooperative. She confirmed that a Patricia Evans does live at her property on Dorothy Drive and has lived there for a few years. Source also seemed familiar with the fact that Patricia Evans did have a boyfriend, who was probably the Michael Scott who we were trying to locate. This source was convinced, however, that Michael Scott was not currently living at the Dorothy Drive address. She stated that he was still around the area, however, and that Patricia Evans was still "seeing him". Source stated that she is certain Patricia Evans would not cooperate in providing us where Mr. Scott could be found. She could not give us a specific reason as to why Patricia Evans was hiding Michael Scott's location but thought that it was quite possible that he was in some type of trouble or owed money. Source thought Michael Scott was approximately the same age as patricia Evans and was probably in his early to mid forties. Finally, Ms. Bradford stated she would attempt to speak with Patricia Evans and see if she could determine where Michael Scott was located. We did re-contact Ms. Bradford several days later, and she revealed that she did talk to Ms. Evans but that Ms. Evans would not provide her where Michael Scott could be located. Annie Bradford was convinced that Patricia Evans was still seeing Michael Scott and suggested that a surveillance be conducted at the Dorothy Drive location. We terminated our handling with Ms. Bradford. (6) SOCIAL SECURITY AND CREDIT RETRACE FOR PATRICIA EVANS We then continued our investigation by conducting a credit and Social Security check on Patricia Evans. As a result, we did find a listing for Patricia A. Evans with a Social Security Number of 186-54-0455 and a date of birth of 7/1/61. Although one service showed the current address for Patricia Evans as 326 Dorothy Drive, Pittsburgh, PA 15235, another service found a more recent address for this individual as 647 Irwin Street, Wall, PA 15148. It also is interesting to note that in addition to the name of " "'~"-," -~.,',~",,-~. """,;,.;.,~,~,..' ,- '~iA"i, Page 4 Patricia A. Evans, it also listed this individual with the name of Patricia A. Kimbrugh. We also learned through this check that the phone number listed for the Dorothy Drive ~esidence is 412-823-8119. (7) CANVASS OF NEIGHBORHOOD AT 647 IRWIN STREET, WALL (WILMERDING), PA 15148 Investigation continued by going to this address thinking of the possibility of Michael Scott living at that property owned by his girlfriend, Patricia Evans. Upon arrival at this location, we found it to be one of six row house units located in an older lower income area. Unfortunately, we found no one home at any of these units. We were eventually able to locate the owner of 647 Irwin Street, who happened to be Mary Cvejkus. Ms. Cvejkus actually lives at 14051 Ridge Road in North Huntingdon, PA and has a phone number of 412-751-6480. We were able to speak with Ms. Cvejkus, who we found to be cooperative. She stated that the lease at 647 Irwin Street is listed to Gloria and Michelle Evans. Gloria Evans is in her forties and the mother of Michelle, who is in her twenties. Source stated they are the only two names listed on the lease. She was not familiar with a Patricia Evans or with a Michael Scott. Source stated that the Evans' have been renting from her for approximately four months and that Gloria, the mother, works at a bar or lounge somewhere in the Turtle Creek, PA area, while the daughter, Michelle, works at a local hospital. Source stated she has had no problems with these individuals as tenants, and they do pay their rent in a timely fashion. She added, however, that she has heard from some neighbors that there are somewhat "unsavory" characters that are seen going in and out of that residence at various times during the course of the evening. This is the extent of the information we could obtain from this source, and we terminated our handling here. (8) ALLEGHENY COUNTY CRIMINAL RECORDS - PITTSBURGH, PA We then continued our investigation by researching Criminal Records in Allegheny County, which does encompass the pittsburgh and surrounding areas. I e ~" - .,-' ."'" -",,,-'-." ".'- ~ 0 :.dJ '~ . , . ' Page 5 Under the name of Michael Scott, we did find one record for an arrest found under Criminal Complaint #200100373. The arrest date was 10/28/00 and it involved charges against Michael Scott of driving under the influence (DUI), possession, and careless driving. Michael Scott had a Social Security Number of 107-46-5760, date of birth of 2/9/57 and an address of 326 Dorothy Drive, Pittsburgh, PA 15235. It appeared these charges were dismissed, although, he did plead guilty to the DUl and was sentenced to two days to a maximum of 12 months in jail. He was also placed on probation. Please note we did subsequently speak to his assigned probation officer, Ms. Nicole Jubera. She was cooperative and stated that she has been assigned Michael Scott. She added, however, that she just received the case, and she is not scheduled to see Mr. Scott for the first time until July 17th. After that point, he will then be assigned specific alcohol related classes that we will have to attend. Source stated that the most current address she has for Mr. Scott is the 326 Dorothy Drive address in Penn Hills. She will not know whether that is a valid address until after she sees him on July 17th. We asked Ms. Jubera if we could contact her after July 17th to see if Mr. Scott provided her with a more recent address, and she indicated that would not be a problem. We found this source most cooperative. RECOMMENDATIONS We are forwarding to you our handling to date concerning this matter. We strongly suggest that surveillance efforts be initiated at the Dorothy Drive address to observe whether Michael Scott arrives at that location or whether his girlfriend, Patricia Evans, leaves to visit him at an unknown location. If after reviewing the report and the information contained therein you do feel additional handling is needed, please advise and we will handle as per your directive. ..-----, . .,.Z/ (/ )C'----v--. X. '.11,' ,J; n iL<- (.~-' # ,..1 I ) -- -..... 71 -,c,.(.~ Ross J. Gigli'o'tti v Enclosure , , . Allegheny County Assessment Page I of 1 ~ ~le~,p-~n~ Home Page ALLEGHENY COUNTY CERTIFIED VALUES FOR 2001 . .', > ~., 1!Jki1)' ,",..:,,", .'3,'."~:~;. ::ii~:'~:~:: ------.--.......-..............-.....-..................................... OWNER GENERAL INFORMATION Municipal Code: 934 PENN HILLS Block Lot: Previous Block L.ot: 0368-G-00268.0000.00 School Distl'ict 03G8.<3..00268-0000-00 Neinhborhood Code Penn Hills Twp 93428 Owner Name: Property Location: BRADFORD ANNIE M 326 DOROTHY OR Tax Code: Owner code: State Code: Use Code: Lot F mnt: Lot Area: Homestead: Farmstead: Taxable Hegular Residential Single Family o 8.000 No No Sale Flag: Sale Date: Sale Price: Deed Book: Deed Page: Abatement: Regular 12/4/1987 $45.000 7692 '18G No County Value Total Land Value Total Building Value Total Market Value $'15,600 $38,100 $53,700 Full Value Total Land Value Total Building Value Total Mal'ke! Value $15, $38, $53, Property Description Land: LAND - PRIM,ARY SITE (8000 SOFT). Building: '1 STY RANCH HOUSE WI POP.CH FRAME - OPEN; PATIO CONCRETE; STOOP MASONRY AND FRI~,ME SHED, County $15.600 $~)8, 100 Address Information Tax Bill Mailing: CITIMOfHGf-\GE INC 0000 PO BOX '1800 FARMINC:iTON HIL., MI 4833:3-0000 Change Notice Mailing: 00326 DOFWTHY DR PITTSBUF:GH, P/\15235-0000 L.egal.Disclaimer hltp://\l'\vw2.cOlltlty ,al !cglwny, pa,lls/Real Estate!GeneraLasp'?CllrrBloLol~cCJ36SG()026S0[)O'.. 6/191200 [ , , 1S.-S~.ll;,"!'1:j EHtin Date E.:q::Htf.'s . 081'16100 02l0n/57 02/10/04 ' Sex Height f::v-e,'!::, M 5' 10" af-{O Cla$,s End.ol'sem.:mts. C CnmJMer.:l, Bestrlcticns '/1 326 DOROH,!V 1.1RlVE prrrSBllRGH PA 1 f,Z:'iS MICHAEL SCOTT -1~ <;.._;$6 1111I11111111111111111. .. EXHIBIT 5 '" ,. ~. ,q< ,~ ~,.>__,,",~",_ ~"',,,-,,,,,"~,,'__ 0,,"," '~-- .' . , , . COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN CERTIFICATE OF SERVICE I certify that on the 25th day of July, 2001, a true and correct copy of the foregoing Motion for Alternative Service Pursuant to Rule 430(a), was served upon Defendant, Michael Scott, by mailing same to him by certified mail, return receipt requested, at his last and best known address, as follows: MICHAEL SCOTT 326 DOROTHY DRIVE PITTSBURGH PA 15235 e (D. Joseph obel, At rney for Plainti fs, Henry Line and Constance Bentley Line 1.D. #17715 P.O. Box 828 Harrisburg, PA 17108-0828 (717) 234-2200 ~~f:ffit-i.~ii~~1ll!llili'o;M~~.:i' "'~llifi_l~" " . . ',1 I '" . . , J iJ I ':I I ~ c. ~ '1 ! ! I I " ,C. f,o~. h","7,.;"t, ~,--.y-' ~ r..... ~ ':J '-> . c_ i" Q " , - w -- y . . ..... ~ :'0 3 "".",'.." - - ,,'~,~ .- ,=~ ~<" ,,~ "-~ P. . > . "~'~,~'.~.-," ,<' . ~~,-, -,...~ .~ . . . ~~~ j," ',1 :.. -il!lil!~~~ .' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION' HENRY LINE and CONSTANCE BENTLEY LINE Plaintiffs CASE: 01-2767- Civil CIVIL ACTION - LAW v. JURY TRIAL DEMANDED MICHAEL SCOTT Defendant. NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania Telephone Number: [717] 249-3166 AVISO USTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea defenderse de ias quejas expuestats en las paginas siguiententes, debe tomar accion dentro de veinte (20) dias a partir de la fecha en que recibio la demanda y el aviso. Usted debe presentar comparecencia escrita en persona 0 por abogado y presentar en la Corte por escrito sus defensas 0 sus objectiones alas demand as en su contra. Se ha avisado que si usted no se defienda, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. USTED PUEDE PERDER DINERO 0 PROPIEDADES 0 OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE E'STA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE 0 CONOCES UM ABOGADO VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICIANA CUYA DIRECCION SE ENCUENTRA E'SCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEQUIR ASISTENCIA LEGAL Cumbe~and County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania Telephone Number: [717] 249-3166 ~~ "~' ~ ~~.. -~~ }':, : ~'- "~""'~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HENRY LINE and CONSTANCE BENTLEY LINE 191 Ridge Drive Carlisle, PA 17013 CASE: 01 - 2767 Civil Plaintiffs CIVIL ACTION - LAW v. JURY TRIAL DEMANDED MICHAEL SCOTT 326 Dorothy Drive Pittsburgh, PA 15235 Defendant. COMPLAINT AND NOW, THIS 16th day of January 2002, come the plaintiffs, Henry Line and Constance Line by their undersigned counsels, with the following: 1. The Husband/Plaintiff is Henry Line, an adult individual who resides in Carlisle, Pennsylvania. 2. The Wife/Plaintiff is Constance Line who also resides in Carlisle, Pennsylvania, and who at all times relevant to the Complaint was the husband of plaintiff Henry Line. 3. Defendant in this action Michael Scott who resides at 326 Dorothy Drive, Pittsburgh, PA 15235. 4. On or about June 5, 1999, Husband/Plaintiff operating a vehicle a motor vehicle traveling on 1- 81 southbound in Cumberland County, Pennsylvania and stopped behind the line of traffic held up by construction. 5. Defendant Michael Scott was operating a motor vehicle traveling on 1-81 southbound. When Husband/Plaintiff stopped for construction traffic, the Defendant who was directly behind the Husband/Plaintiff failed to stop and struck Plaintiff/Husband's vehicle in the rear causing Plaintiff/Husband's vehicle to impact the stopped vehicle in front of him. 6. Defendant failed to pay proper attention to the road and was traveling too fast for conditions. .--- "'~ ,. , " ':"'''''_'c -",-' 'U"]['8c 7. The accident was caused by the negligence and recklessness of the defendant and was in no way caused by Husband/Plaintiff. 8. The wrongful actions of the defendant were the proximate, legal, substantial and direct cause of the injuries suffered by the plaintiff. COUNT I Constance Bentley Line v. Michael Scott 9. As a direct and proximate result of the wrongful actions of the defendant, the Wife/Plaintiff has sustained serious and permanent injuries as follows: (a) severe strain, sprain, and injury to her lumbar, sacral, thoracic and cervical spine, shoulders and associated soft tissues, arteries, veins and/or other blood vessels and nervous tissues; (b) damage to the muscles, blood vessels and other soft tissues of her body, including without limitation her back, neck, spine, arm(s), shoulder(s) and other parts of her body; (c) Possible damage to the nerves running from her cervical, thoracic, lumbar and sacral spine to her arm(s), leg(s), shoulder(s) and or possible damage to a cervical disk(s). Wife/Plaintiff as a result is limited in her functions and ability to lift, sit, walk or even drive. (d) Lumbrosacral strain, radiculitis and disc disease. The disc disease includes but is not limited to T-12, L-6, and L-4-5. (e) further injuries to her back, neck, head and other extremities; (f) such other injuries as may become known in the future; (g) all of the above are or may be permanent; and (h) all of the above have required and/or in the future will or may require medical, surgical, treatment and/or other treatment and therapy. 10. A direct and proximate result of the wrongful actions of the defendant set forth above, the Wife/Plaintiff has suffered and will continue to suffer great pain, suffering, fear, mental anguish, "~ ,~" , 1",,--- ~ ~ ~ J__ _ .' ""'"""'".,,,,,~ , , . ~ , ~'=~;j emotional distress, embarrassment and humiliation. Wife/Plaintiff has sustained and will continue to sustain a permanent loss of the enjoyment of life and loss of life's pleasures. 11. As a direct and proximate result of the wrongful actions of the defendants set forth above, the Wife/Plaintiff has sustained and will continue to sustain a loss of earnings and earning power and earning capacity and profits from the family/husband's business due to her inability to work in that business for which claim is hereby made. 12. As a direct and proximate result of the wrongful actions of the defendants set forth above, the Wife/Plaintiff has or may incur medical expenses and income losses which exceed those which are recoverable under 75 Pa.C.S. ~1711, ~1712 or other applicable law and for which claim is hereby made. WHEREFORE, PlaintifflWife demands judgment in her favor and against the defendant in excess of $30,000 plus costs of suit, plus pre and post judgment interest and such other and different relief as to which the plaintiff may be entitled. COUNT II Henry Line v. Michael Scott 13. The preceding paragraphs are incorporated by reference. 14. As a result of the injuries sustained by the Wife/Plaintiff, the Husband/Plaintiff, has been deprived of the assistance, companionship, consortium, work in his business for which replacement help was required. and society of his wife all of which have been or will be to his great damage and loss. 15. As a result of the collision, the automobile owned by the Husband/Plaintiff, sustained damage requiring repairs in the amount of $1263.50. (A copy of the repair estimate is attached hereto and incorporated by reference herein.) That amount is hereby claimed in addition to the other damages sought in the complaint. - '~ - ~ .' "'- -",",,' '-" '1,;"..",~.'~II!t'k WHEREFORE, Plaintiff/Husband demands judgment in his favor and against the Defendant in excess of $30,000 plus costs of suit, plus pre and post judgment interest and such other and different relief as to which the plaintiff may be entitled. Respectfully submitted, KAIN, BROWN & ROBERTS L / By: arc G. Tarlow, q. [ID 23474] 119 East Market Street York, Pennsylvania 17401 Tele: (717) 843-8968 fax: [717] 843-5664 Joseph B. Sobel, Esq. Law Office of Joseph B. Sobel 212 North Third Street Suite 202 - Cranberry Court Harrisburg, PA 17101-1505 Attorneys for Plaintiffs ,_ ~". '.,_ 1 ~ ~' -","''-=",'' . -,,,,, ',,", ,. '.""",, "'" ,,' 'w; _ ,0. '--'';'"'' " \" _ -.; . ,_ " ";;--",,: VERIFICATION I verify that the statements made in the foregoing documents are true and correct to the best of my knowledge, information and belief. I understand that the statements made herein are made subject to the penalties of 18 Pa.C.S. ~904 relating to unsworn falsification to authorities. ~~ Hen Line VERlFICATION I verify that the statements made in the foregoing documents are true and correct to the best of my knowledge, information and belief. I understand that the statements made herein are made subject to the penalties of 18 Pa. C.S, \14904 relating to unsworn falsification to authorities. /~ - ~""';"" ,- ' ~,~ , ," ~ , -'- ,-, .L,'~"~i.";'" ...;,"~ '~~M~J;<j;j;LM,> IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HENRY LINE and CONSTANCE BENTLEY LINE 191 Ridge Drive Carlisle, PA 17013 CASE: 01 - 2767 Civil Plaintiffs CIVIL ACTION - LAW v. JURY TRIAL DEMANDED MICHAEL SCOTT 326 Dorothy Drive Pittsburgh, PA 15235 Defendant. CERTIFICATE OF SERVICE AND NOW, this 16th day of January 2002, I, MARC G. TARLOW, ESQUIRE, a member of the law firm of KAIN, BROWN & ROBERTS LLP, hereby certify that I have served a copy of the foregoing NOTICE and COMPLAINT by depositing same in the United States mail, postage prepaid at York, Pennsylvania, and by Certified Mail - Return Receipt Requested, addressed to as follows: Michael Scott 326 Dorothy drive Pittsburgh, pa 15235 Allstate Market Claim Office 6345 Flank Drive Suite 1000 Harrisburg, PA 17112. Respectfully submitted, KAIN, BROWN & ROBERTS LLP By: Mar. G. Tarlow, Esq. [ID 23474] 119 East Market Street York, Pennsylvania 17401 Tele: (717) 843-8968 fax: [717] 843-5664 Joseph B. Sobel, Esq. Law Office of Joseph B. Sobel 212 North Third Street Suite 202 - Cranberry Court Harrisburg, PA 17101-1505 Attorneys for Plaintiffs ~~_~~"tl,t\~'-'k,,",~~,";j;;i~","'Hj\fu~~mi-,"'<':,,<i-;;;->M."'~<:"~;T~c';'lli,~'"",~~-,,~,;&iI;~~!'lilDitili"-"" I( cJ K-fJ ",,_, w' _ ~'.__,,_ ,,~~ &m,~.'~ > -'. .,=~~, .",. ,',-~..' -,"" ,~ < . ,...,"_.....~"' "'.......W6l@~' --. '1liiI\!Ir"" "I:.'j ! I i I I II II II !I I' 11 I I I I I I I 0 0 .j C r",,] TC -' ~, rr: ~ ~ :;.:-.'" 'Tl -;:~~, Z .- :1~,: u' .-.J -< ,-,- r::: ,- , >: --0 -', , '-Tl Z :..... (-') )> c:: "') ~~ , \ I c: ~ ~,,- ~c --j co -< (..) -< .= ~ - "~,, ""'''~-".. -' .~",,, ~<"~,I<',i:-" ',,,-- .,'..,c' '~, ~'" _A"'."'''' ;'-,<"__~.-i-""";;""__I _', ,.,.. _ '" '.M~"_ ;:,:.,',C,kJ;,;",_. ~',. . \~" . ,.. . HENRY LINE and CONSTANCE BENTLEY LINE, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 01-2767 v. MICHAEL SCOTT, Defendant 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. By: ~i~ Christopher1. night, Esquire Attorney 1.0. No. 80058 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 Date: r/6/tJL I I 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. Date: ~bL v. ;'11.'1 q ~ 00"-.. Cw *a) i/ x?? Prothonotary ~ ^ ,.., ^ .--<' ,~'~"n "~'~,' .~ '.;..,r;. - ',' ,;,' "',' '" "",., "::'i "' '-"-.ii~. - , 'v':".'" - '''v~" ' ~ 'v,,'. -~" . ," , CERTIFICATE OF SERVICE AND NOW, this / ~ f'1 day of January, 2002, I hereby certify that I have served the foregoing Praecipe for Rule to File a Complaint on the following by depositing a true and correct copy of sarne in the United States mail, postage prepaid, addressed to: Marc G. Tarlow, Esquire Kain, Brown & Roberts, LLP 119 East Market Street York, PA 17401 Joseph B. Sobel, Esquire 212 North Third St., Suite 202 Cranberry Court Harriburg, PA 17101-1505 ~ ."H"" "''"'~1...<~."... ~ibili:oI_ 41. 'w '^' ~-'", ~,~ "",'. ';'W'-, . '] j';';' ",ii;i,~,,, It<~ ''',0 . " ." ~::J'-".'i' ^' .j,,"o " ~, o G; (Jl~i ' !:.lir< !P~ :2;C_' (?C~, --r-' ::;;:: 5';! '-- , :~- ;"' ~"""'j I~ ~~j ~ = -- ~."'k' -' "_'L"_,>;';",-~_,' "." "~"".""'''",'''-''';;;-.D"",''''''''',,",'"'ddt~ '~;.:"..i'",',";"""-","'~,'"',,,,M'~~; ";i-',,> :,,,,,.:,,;,-j:~,! HENRY LINE AND CONSTANCE BENTLEY LINE, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01.2767 v. JURY TRIAL DEMANDED MICHAEL SCOTT ANSWER AND NOW, cornes the Defendant, Michael Scott by through his attorneys, Nealon & Gover, P,C. and in response to Plaintiffs' Complaint, avers the following: 1, After reasonable investigation, Defendant is without knowledge and inforrnation sufficient to forrn a belief as to the truth of the averrnents contained in this paragraph. Strict proof of sarne is demanded at trial. 2, After reasonable investigation, Defendant is without knowledge and inforrnation sufficient to forrn a belief as to the truth of the averments contained in this paragraph. Strict proof of sarne is demanded at trial. 3. Admitted in part and denied in part. It is adrnitted that Defendant Michael Scott resides in Pittsburgh, PA. It is denied that he resides at the stated address. By way of further answer, Defendant Michael Scott's address is P.O. Box 27044, Pittsburgh, PA 15235. 4. Adrnitted in part and denied in part. It is adrnitted that on or about the stated date, Plaintiff Henry Line was operating a rnotor vehicle in the southbound lanes of 1-81, Curnberland County, Pennsylvania. It is further admitted that Plaintiff Henry "< - . ~-,"- -~ --~ ;," -, ";y',," ~",,,..< ",d-~" ," "~'--'-"'" ;-';';;;,,"~r,"""""""'__'" I,,~'~-'".~"'k;'''''~''' =--~''''''''",~'n-, , '." ,~.( ,~',.;i'~ Line's vehicle carne to a stop. After reasonable investigation, Defendant is without knowledge or inforrnation sufficient to form a belief as to rernaining averments contained in this paragraph. Strict proof of same is dernanded at trial. 5. Adrnitted in part and denied in part. It is adrnitted that Defendant Michael Scott was operating a motor vehicle traveling southbound on 1-81, It is further admitted that Defendant Michael Scott's vehicle carne in contact with the rear of the vehicle being operated by Plaintiff Henry Line. After reasonable investigation, Defendant is without knowledge or inforrnation sufficient to forrn a belief as to the truth of the rernaining averrnents contained in this paragraph. Strict proof of same is demanded at trial. 6. Denied as stated pursuant to Pa.R.C.P. 1029(e). 7. Admitted. 8, The averments contained in this paragraph state only conclusions of law to which no responsive is required. To the extent that they may be deerned factual and requiring of a response, they are denied pursuant to PaR,C.P. 1029(e). COUNT I CONSTANCE BENTLEY LINE V. MICHAEL SCOTT 9.-12. After reasonable investigation, Defendant is without knowledge or inforrnation sufficient to forrn a belief as to the truth of the averrnents contained in this paragraph. Strict proof of same is dernanded at trial. ~" ,~,",,-' "~'~o" '" ,',,~',._' ,~'," ""''''" '.""",,""" '';.,=-,'4''''~'''''"",,'''''L k"" ""'"'~"";;''''~ij';~' WHEREFORE, Defendant, Michael Scott, respectfully requests that this Honorable Court enter judgrnent in his favor and against Plaintiff, Constance Bentley Line. COUNT II HENRY LINE V. MICHAEL SCOTT 13. Paragraphs 1-12 above are incorporated herein by referenced as if fully set forth at length. 14.-15. After reasonable investigation, Defendant is without knowledge or inforrnation sufficient to forrn a belief as to the truths of the averrnents contained in this paragraph. Strict proof of sarne is demanded at trial. WHEREFORE, Defendant, Michael Scott, respectfully requests that this Honorable Court enter judgrnent in his favor and against Plaintiff, Henry Line. Respectfully subrnitted, NEALON & GOVER, P.C. By: ~~ Christopher J. Knight, Esquire Attorney I.D. No. 80058 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 Date: t-lz!~'Z- '"' ,u,~",- ""'.","'C,,', .",.",,,,- >>"";""""'~"""""""'""'~"-"'",,;">., "'-c:, "'J;,; VERIFICATION I, Michael Scott, verify that the statements rnade in the foregoing Answer are true and correct. I understand that false statements herein are rnade subject to the penalties of 18 Pa.C.SA S4904 relating to unsworn falsification to authorities. Date: 0"5/'2.1..10~, -&~ ~_____w Michael Scott . =-,' ~,' ^~. - >'~ - ;".,- '" "',' ,- -="- '-"'""" ,'<~ '" ,", ',"" '.- ,',~"-' '. '~"~'-;;.&; ll,,;''';ii),E'''.'''''-"'''''''''''''~~'k 'i-'" ,c~' __," ;,;",i .,:\,,}l,~ CERTIFICATE OF SERVICE AND NOW, this 2nd day of April, 2002, I hereby certify that I have served the foregoing Answer on the following by depositing a true and correct copy of same in the United States rnail, postage prepaid, addressed to: Marc G. Tarlow, Esquire Kain, Brown & Roberts, LLP 119 East Market Street York, PA 17401 Joseph B. Sobel, Esquire 212 North Third St., Suite 202 Cranberry Court Harrisburg, PA 17101-1505 _iMl;!.l- "Iii"'""''' ~ Xj:; ~- ~ ,",'." ' '_0.'" "" \L..;...,,;( ~"o ':~'Uir-~~~~';'" " ...;;-_or~ ..'~-""' . ,~ - C'~~o ~_ I 0 0 0 C N " <?' "'" .--1 .~ "T! ~r :0 -rJl.::U mf"1 ;IV , 11r_ 7~-r1 --.,rn Z!'~::; I ;~j9 V?J:.: w -<..c:< ~~p ~CJ ..0 '--,--.-- II eo ::" ~2B '<::.0 ";:-rn r;: 0 )>c: ~ z: f"" $ =2 (~ -< -. --- " ~ .__ o. --",{,:,,'<. '. ",,','1, -~" k:~'" _.0;'./_ ':~"-"'>"__",~, "O,,,,,~,~,; .. . . , ". .... f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HENRY LINE and CONSTANCE BENTLEY LINE 191 Ridge Drive Carlisle, PA 17013 CASE: 01 - 2767 Civil Plaintiffs CIVIL ACTION - LAW v. JURY TRIAL DEMANDED MICHAEL SCOTT 326 Dorothy Drive Pittsburgh, PA 15235 Defendant. PRAECIPE TO REINSTATE THE WRIT OF SUMMONS TO THE PROTHONOTARY/CLERK OF SAID COURT: Please reinstate the Writ of Summons against the Defendant, MICHAEL SCOTT, in the above captioned case. Plaintiffs Address: 191 Ridge Drive Carlisle, PA 17013 Respectfully submitted, Joseph B. Sobel, Esq. lID 17715) Attorney for Plaintiffs 212 North Third Street Suite 202, Cranberry Court Harrisburg, PA 17101-1505 c G. Tarlow, Esq. lID 23474) Attorney for Plaintiffs 119 East Market Street York, Pennsylvania 17401 Tele: (717) 843-8968 fax: [717] 843-5664 DATED: June 6,2001 Date: ***** SUMMONS IN CIVIL ACTION MICHAEL SCOTT 26 DOROTHY DRIVE PI URGH, PA 15235 YOU ARE NOTIFIED AGAINST YOU. MED PLAINTIFF HAS COMMENCED AN ACTION BY: Deputy .illt- ',' ''''''';':;;'.'''' "''-'~IBilIi.''-. ~iJ!."lli~~!:i~~*i;ili_~ll<l',;jll<li>~IiIlII!-u.'- ~ .... ~ "~~ "", ~~ " '-'w~ nO. ",' ~, . ... , t 0 0 () C ~1I :s: (/) :::3 "OJ f"\"1 rnrn --0 ',ip Z-r'. ~" -::;rn zr' roz '~~6 -<.::-~ r:: ,....-.-, ;<'-' ::s -,- --t, ~O -~ g~~ 5>~ ~~ ~. z ~ :<! IV J ~' ~~ ,~ '""" .~,~" ':>/"""~"";'-""""\-",-"H,:' -, ,-,," .1 ."u,"',:', ;i,,'l~",,: ',-;,';'1;:0;;':__" Ji"J""~;"~""d"'_ _.-,,-,;, ',,:~-:~'.':~.J~<iV'i;"'.&~:'';~;'''' <:Co';, ,.4";" '~':'h~ L , HENRY LINE AND CONSTANCE BENTLEY LINE, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 01- ~'1-l.ol v. MICHAEL SCOTT, Defendant JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Michael Scott, with regard to the above-captioned matter. Respectfully submitted, NEALON & GOVER, P.C. BY~~ Christop r J. Knight, Esquire Attorney I.D. No. 80058 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 ".. .J, .:,,". ~,'_ ," - ", lei ,. "''''''--~' )" '~~,i'l",,;~,~ ;o,',:;';.,,)ti, '>''''"""__j.-;,,,,. <~\,~"';,:,. .0:',~ ~,~~",,'~\~f;J CERTIFICATE OF SERVICE AND NOW, this 5th day of October, 2001, I hereby certify that I have served the foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Marc G. Tarlow, Esquire Kain, Brown & Roberts, LLP 119 East Market Street York, PA 17401 (I~~~ Christop er J. Knight, Esquire ,.~I@Il~*"'-''';;'~~- 8t ;;; , " ,- """~'~llifd~"~1'JW~iWtWwii~_j ~ .0 ~ ' t' ~ " ,.' ~ ~,'"' ili~" 0' -;'" '.'__"j'o ~ ~- tS1 , c;: I',. ;:_',r ~'::;(:--':: .-'-"";0' (- --"_7 =< C~:' '-::::.; ;:-'-; ., ~~ I o , C- ,"" LO :''1 C~I ~"''', ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HENRY LINE and CONSTANCE BENTLEY LINE 191 Ridge Drive Carlisle, PA 17013 CASE: 01 - 2767 Civil Plaintiffs CIVIL ACTION. LAW v. JURY TRIAL DEMANDED MICHAEL SCOTT 326 Dorothy Drive Pittsburgh, PA 15235 Defendant. AFFIDAVIT OF COMPLIANCE OF SERVICE OF PROCESS I, Marie-Andrea Blouse, Paralegal, am an adult individual and hereby state as follows: 1. That in compliance with Judge Kevin A. Hess Order of August 2, 2001, I performed the following to effectuate service of process: A. Mailed the Writ of Summons in the above action by 'Certified Mail - Return Receipt Requested' to defendant Michael Scott, c/o Patricia Evans at his last known address of 326 Dorothy Drive, Pittsburgh, PA 15232. That Return Receipt Number 7099-3400-0007-0729-6751 was signed by Patricia Evans on September 17, 2001 and copy of which is attached hereto and incorporated by reference as Exhibit A. B. Mailed the Writ of Summons in the above action by 'Certified Mail - Return Receipt Requested' to defendant's insurance carrier 'AllState' at the address of Market Claim Office, 6345 Flank Drive, Suite 1000, Harrisburg, PA 17112. That Return Receipt Number 70993400000707296768 was signed by H. Via on September 13, 2001 and copy of which is attached hereto and incorporated by reference as Exhibit B. 0__ ~ri<"",". ~,AtObl j,. ",- " . ,~ '. ~' "J-~.- .', ",.'" '" 'C~ C. That advertisement in a paper of general circulation was done in a local newspaper of Allegheny County by the Pittsburgh Post-Gazette on September 25, 2001. A copy of the Proof of Publication from the Pittsburgh Post-Gazette is attached hereto and incorporated by referenced as Exhibit C. D. That advertisement in a legal paper of Allegheny County was done by the Pittsburgh Legal Journal on September 13, 2001. A copy of the Proof of Publication of the Pittsburgh Legal Journal is attached hereto and incorporated by referenced as Exhibit D. 2. I make these statements based upon the best of my knowledge information and belief. Date: October 17, 2001 KQul ,(L,k~CL Marie-Andrea Blouse, Paralegal COMMONWEALTH OF PENNSYLVANIA COUNTY OF YORK On this 1 yth day of October, 2001, before me a Notary Public, in and for said County and Commonwealth, personally appeared Marie-Andrea Blouse, known to me or satisfactorily proven, to be the person whose name is subscribed to the within instrument and in due form of law acknowledge the within instrument to be his act and deed. IN WITNESS WHEREOF, I hereunto se my hand and official seal the date and year aforesaid. Notary Public (SEAL) My Commission Expires: NOTARIAL SEAL BRENDA K. TOPPER, Notary Public City 01 York, York County '. Commission Ex ires March 4, 2002 SENDER: COMPLETE THIS SECTION . Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. ' 1. Article Addressed to: 7~\2..-\c...\f\ u~\.3CL~'.:'::, c.J~ \-I.--,c-~ ~~ 3~6 O~\t;-\--"';:\. ~\, 7\ \\" \:)\),~I.r\ I~ \"5a35 x o Agent ddressee DYes o No D. Is delivery address different from item 1? If YES, enter delivery address below: 3. Service Type l::H5ertified Mall D--Registered o Insured Mail o Express Mail D Return Receipt for Merchandise .0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number fR9PY from service label) r\ + COl '-'\ '3 '\ on tT)j -r (';:; ;::;A PS Form 3811, July 1999 Domestic Return Receipt UNITED STATES POSTAL SERIft \) KG p ,-?0 ..../ ~:~ P\~ ...... " (n+'S \ 10259S-QO.M-0952 -;'.... ,. 'vI . Sender: Please print ;o:oLlr.nam":' address, and ZIP+4 in this box. ...~. - ::...~! I"j..-- p~stage &Fe~e Paid .'''' 'USPS --- .~: ' . Permit No. G-10 w M~e..( G-\{:\S2-~ . fL'A-\0\~cC1~~~ \\C\ cc., \;\S.~ ~_IJ\2-=~2:.( g c}C)r ~(YA R '--lD ( EXHIBIT A AlL.STATE& INTERNATIONAL SENDER: COMPLETE THIS SECTION . Complete Items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: W,L~$\p;.\5"'. . ~\\'.u.~' C\CU('{'. ~c...C (6':>LQ 0\0...\'\.'<. Dr.,s..,.-\:-e. \00 W("'l>Io\:)~\ \?P\ \~\ \d 2. Article '1c PS Form UNITED STATES POSTAL SERVICE ~ SlgnaturecJJ J 14 o Agent o Addressee [j -Yes DNa D. Is delivery address different from item 1? If YES. ent~ deli",:~1Y address below: 3. Service 'TYpe O"Certified Mail 0 Express Mail QA("eglsterecl 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D, 4. Restricted Delivery? (Extra Fee) 0 Yes i5-00.M.0952 First-Class Mail Postage & Fees Paid USPS Permit No. G-10 . Sender: Please print your name, address, and ZIP+4 in this box. , M AQ...C G- \ ..p.. iC...-Lo I....-C> ~'A\Y\~foc...::>}.::> ~ Q.c\o~\:::3 \ \c:'\ 'Lf','C,\ )\'fKL'C~"\ 'S\-, ~D~ 'C:?~ \.0t~C) \ EXHIBIT :::IS ALl_STATEIS INTERNATIONAL --- ~. ~k '-'-" ~ "., < " .,-".~; . >, . .,"'.' "'- , '"'-'':'.-'"'='''''-' " '-Id'. No. Tenn. 19 Proof of Publication of. Notice in Pittsburgh Post-Gazette Under Act No. 587. Approved May 16, 1929. P,L. 1784. as last amended by Act No. 409 of September 29. 195) Commonwealth of Pennsylvania, County of Allegheny, ss: A. Blanchard . being duly sworn, deposes and says that the Pittsburgh Post-Gazette, a newspaper of general circulation published in the City of Pittsburgh, County and Commonwealth aforesaid, was established in 1993 by the merging of the Pittsburgh Post-Gazette and Sun-Telegraph and The Pittsburgh Press and the Pittsburgh Post-Gazette and Sun-Telegraph was established in 1960 and the Pittsburgh Post-Gazette was established in 1927 by the merging of the Pittsburgh Gazette estab- lished in 1786 and the Pittsburgh Post. established in 1842, since which date the said Pittsburgh Post-Gazette has been regularly issued in said County and that a copy of said printed notice or publication is attached hereto exactly as the same was printed and published in the r~ar editions and issues of the said Pittsburgh Post-Gazette a newspaper of general circu ation on the follOWIng dates, viz: 25, of September, 2001. Affiant further deposes that he/she is an agent for the PG Publishing Company, a corporation and publisher of the Pittsburgh Post-Gazette; that, as such agent, affiant is duly authorized .to verify the foregoing statement under oath; that affiant is not interested in the subject matter of the aforesaid notice or publication: and that all allegations in the foregoing statement as to time, place and character of publicatio are true. COPY OF NOTICE OR PUBLICATION IN THE,eOURTOF COMMON PLEAS OF CUMBERLAND ".~ COUNTY, --PENNSYLVANIA . ,CIVIL DIVISION ,:J:t-roI"Y Line and. Con- stance BentleY Une. PH::llntlffs v. Michael Scott, 'Defendant. -QASE:-Ol-2767 CIVIL CIVil ACTION - LAW Jury Tr.ial Demanded ' . NOTICE -..ii}; ~~~~~;I 6~rv~ . Pittsburgh, .'PA' 15235 ~'--YOIJ, are 'notified, that m:n~,:rJ~~ff~'i~?'~~a~fi~~ - against 'YOU ',:entered 'as Case.-G,1-2767 -CiVil in ,the Court Of, Common ,Pleas . of Cumbl!r.Iand',-:County. I ~~:_~~~~~aMW~~~na~,~ ,I ".-If youiWlsh 'Jo':defend. \ YOU musf filoter. a ~rltten apPe,aran"c;:e "personally or by-,attorney:and fllfng III w.rltlng,wlth,the c.ourt .j your defenses' or, objec- t tions' to ,the claims 'set forth 'agalnst..,you.",:;You are warnecLthat..I,f, YOU fall to 'de) : ,SO ,',the-case maY ,proceed' without ~a"v g~~~~~;~dg~rn~l -~""~3fri~!~r~n:r ',~~: quested bi:the"Plalntiff. ! You may Jose money or croperty, or other rights m~Ga'i\l8J~~',:TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF .Y;O~y~~"~.r ~t~~o~ ~FORD ONE, GO TO OR TELEPHONE THE ~ OF,F ICE SET FORTH ,BELOW,TO FIND OUT :WHERE'YOU 'CAN GET "EGALHELP.' .. , :uCumberland ,County. .>', '~::2B~rJ'r'~~~~~Se '.Corllsle, 'Pennsylvania Total ...______.._____ Te\~::"(71.7) 249-3166 ---- - '-PUblisher's Receipt for Advertising Costs PG PUBLISHING COMPANY, publisher of the Pillsburgh Post-Gazette. a newspaper of general circulation, ~ereby acknowledges receipt of the aforsaid advertising and publication costs and certifies that the same have been fully p31d. P Puti ishin Comp Sworn to and. subscribed before me this day of: September 27~ 2001. 1&J,Z!da::M- '~'-""">""""" . , ,-" '~.~-"........_..... ~,....--; :~ --,' . ::. :;-- , ::'.,'.; ;~,: L_'~__,~~ :~_:' '~"~_~~I"'~:.:~';".: \';;.'. 'C;.' ~'.~"~~ ,\,'. -' ~~.._~""""--_.._~ "'" ;;;... ""C"" .',- - -^"' . ::, ~2" ,::1 :~r;:~\'-,..:.:; STATEMENT OF ADVERTISING KAIN, BROWN & ROBERTS Andrea Blouse 119 East Market St. York PA 17401 To PG Publishing Company COSTS --- $ 381.25 Office 34 Boulevard of the Allies PITTSBURGH, PA 15222 Phone 412-263-1338 By I hereby certify that the foregoing is the original Proof of Publication and receipt for the mailer of said notice. PG Publishing Company, a Corporation. Publisher of Pittsburgh Post-Gazelle, a Newspaper of General Circulation Advertising costs in the subject EXHIBIT L Attorney for All.STATEQ!lINTERNATIONAl - .'.- ~ ~. IN RE, HENIW LINE AND CONSTANCE: BE:NTLEY LINE V MICHAEL SCOTT CTVIL ACTION 01-2767 i:J;: ,'~ .;, -' '~:;h ~roof of Publication of Notice in Pittsburgh Legal Journal UNDERACT OF MAY 16, 1929, P.L.1784, AS LAST AMENDED BY ACT 520, OF JULY 5,1947 State of Pennsylvania } County of Allegheny, ss: Jennifer A. Jones, a designated agent of the Publisher of the PITrSBURGH LEGAL JOURNAL, being duly sworn, deposes and says that the PITrSBURGH LEGAL JOURNAL is a legal newspaper which is published by The Allegheny County Bar Association at the offices at 400 Koppers Building, Pittsburgh, Allegheny County, Pennsylvania; and that the PITrSBURGH LEGAL JOURNAL was established as a weekly newspaper on April 23, 1853, and as a daily legal newspaper on January 4, 1926, since which date said daily newspaper has been regularly issued in said County, and that a copy of the printed notice or publication which is attached hereto is exactly the same as it was printed and published in the regular editions and issues of the said daily legal newspaper on the following dates, viz: 13th DAY OF SEPTEMBER 2001 Affiant further deposes that she is an agent duly authorized by the publisher of said PITrSBURGH LEGAL JOURNAL, to veri- fy the foregoing statement under oath and also declares that affiant is not interested in the subject matter of the aforesaid no- tice or publication, d that all all tions in the foregoing statement as fo time, place and character of publication are true. v. MICHAEL SCOTI', Defendant. NOTICE To: Michael Scott 328 Dorothy Drive Pittsburgh. PA 1523$ You are notified that the plaintiffs have commenced a civil action against you en- tered as Case 01-2767 Civil in the Court of Common Pleas oCCumberland County, Pennsylvania, which you are required to defend. If you wish to defend, you must enter a written appearance personally or by attor- ney and filing in writing with the ~urt your defenses or objections to the cla1Dl8 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 en- tered against you without fu~.notice for the reliefrequested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE TIllS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOTHAVEALAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LE- GAL HELP. Cumberland County Bar Association 14062- INV# 0107071 Publisher's Receipt for Advertising Costs C'~l~;~~':~~::'ia The f'ITrSBURGH LEGAL JOURNAL hereby acknowledges receipt of the aforesaid adverti. Thla (717) "9-3166. lTh 256 and certifies that the same have been fully paid. f. & 0 u ~. . PI-rrSBURGH LEGAL Jou Business Office-400 Koppers Building f Pittsburgh, PA. 15219 By OCl.-:7..l.20nL...................... Established 185S-Phone 261.6255 ........................................... . . om to and subscribed before me this . ..:~.~:t:~':::~a~..........~.e.~)::::.:~:~~:~. Notarial Seal Ma!:llaret Ann Lewis, Notary Public Pillsburgh, Allegheny County My Commission Expires Nov. 16. 2004 Statement of Adverti~8lmiYlvama ASSOCIation of Notaries KAIN BROWN & ROBERTS LLP 119 EAST MARKET ST, YORK PA 17401 To f'ITISBURGH LEGAL JOURNAL For Publishing the notice or advertisement attached hereto on the above stated dates................. 241 .80 Probating same..................... 1. .00 Total 242.80 Copy of Notice or Publication Notice IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CMLDMSION HENRY LINE and : CASE: CONSTANCE BENTLEY: 01-2767 Civil LINE, : CIVILACTION Plaintiffs : LAW : JURY TRIAL : DEMANDED I hereby certify that the forego' ,~ ;0 the orilrinal Pro~Jf of Publication and ReceiptR~~@URNAib. the subject matter of said notice. EXHIBIT ::I) Attorney/or........ ............ ..... ........ .... .............. .................. .... All-Sl'ArEI!lINTERNAn~NAl A'~ ,',>-- ,- , '""'oJ ~,,,,,'~ - ,"," -;; ," "". ,'",{., ,~,", W~,',; ;i, ", ,.-~; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HENRY LINE and CONSTANCE BENTLEY LINE 191 Ridge Drive Carlisle, PA 17013 CASE: 01-2767- Civil Plaintiffs CIVIL ACTION - LAW v. JURY TRIAL DEMANDED MICHAEL SCOTT 326 Dorothy Drive Pittsburgh, PA 15235 Defendant. CERTIFICATE OF SERVICE AND NOW, this 17th of October 2001, I, Marc G. Tarlow, Esquire, a member of the law firm of Kain, Brown & Roberts, LLP hereby certify that I have served a copy of the foregoing AFFIDAVIT OF COMPLIANCE OF SERVICE OF PROCESS, by depositing same in the United States mail, postage prepaid at York, Pennsylvania, addressed to as follows: MICHAEL SCOTT 326 Dorothy Drive Pittsburgh, PA 15235 Respectfully submitted, KAIN, BROWN & ROBE Ii / I BY: / Marc . Tarlo ,Esq.[ID 23474) 1119 East Market Street ~ork, Pennsylvania 17401 Tele: (717) 843-8968 fax: [717] 843-5664 Joseph B. Sobel, Esq. [lD 17715] 212 North Third Street Suite 202, Cranberry Court Harrisburg, PA 17101-1505 Attorneys for Plaintiffs ;~~I~~~~~g~li;;),i,&i.11it1~MM~~1it!W ~(~. rlllll!: " .. "e. ^ ~. _, ~ .. ,'">j."..,,__,< ,~,,"?f~,",,;fl' ,''''',;Z~,~,,~, "" ",<c '_"",',,," <'<,,,,,." ~,,',"C>~~ ~"; _ ,--q" ~, "~"""'. ~"~.rr"""'~ .~" ' .~" .. ~-- .ilii:r'~" IT. ;'i' f ~ 0 {'.::J ~2 !;; ~.'- :::::> "1JeD .:-:> :-;1 q}r.---: -; " '"'-:J.J ~i: <:0 ~C ""tJ ;~~~ :P~, ~. :So ~ )>C :.., 6m z '" :;! ~ 5:; (..,) -< , .'~ - . I JjI .~ ~" '.- ~" ~",-,,<,', '_',O:,-..,r'< .~. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA <;7): r-) r,) ,::;, PURSUANT TO RULE 4009,22 () c:: s: "'1J\J:J COq] .c......,-cl ZC'" ~)~;:: ~C C~C,N ~r: ~ ,.- ,-- f':':: -::J "T', .n CONSTANCE BENTLEYLINE TERM, . > --- Pffus {~,) c"'-') = ,~3 IT~ .. ---l IN THE MATTER OF: COURT OF :::> en ;">' ':'0. -<c -vs- CASE NO: 01-2767 SCOTT As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CHRISTOPHER J, KNIGHT, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 07{17{2002 yp.y,~ ~a.l(#'v~ . L.~~T, ESQUIRE Attorney for DEFENDANT DEll-346246 98300-L01 ,'~ , , '~. '_-'d' "'0 -!ill~ ,;: COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE HATTER OF: COURT OF COMKON PLEAS CONSTANCE BENTLEYLINE TEllM, -VS- CASE NO: 01-2767 SCOTT NOTICE OF IN'l'ENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: JOSEPH B. SOBEL, ESQ. HARC C, TARLOW, ESQUIRE KeS on behalf of CHRISTOPHER J, KNIGHT, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice, You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to KeS or by contacting our local KeS office, DATE: 06/27/2002 KeS on behalf of CHRISTOPHER J. KNIGHT, ESQUIRE Attorney for DEllENDAN'l' CC: CHRISTOPHER J. KNIGHT, ESQUIRE- 01-427 Any questions regarding this matter, contact THE KeS GROUP INC, 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (2lS) 246-0900 DE02-191461 98300-C02 . . . . >>> LOCATION LIST <<< RECORDS REQUESTED . . l'IIIDlCAL RECORDS INSURANCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS , " " - -'-~Oi'_";";" PAGE: 1 LOCATION NAME RODIlKY HOUGH, M,D. STATE FARM AUTO INS, CO. MATTHEW NICASTRO, PT DR. DANIEL J. MCCANN, D,C, BRUCE D. KLASKlH, DO JOHN SPAYD TODD SAMUELS, M.D. WALNUT BOTTOM RADIOLOGY ACTIVATOR METHODS, INC, MAGNETIC IMAGING CENTER DE02-1.91.461. 9 a 3 0 0 - C 0 2. - "J " ... ,- , -' '" "',~, ~",,,,,-, ,,' ...."~, ""'-~''-'''''''''-''"'":~( . , . ~ " \ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CONSTANCE BENTLEYLINE VS FileNo. 01-2767 SCOTT SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: RODNEY K. HOUGH, M.D. (NUle of Penon or Entity) Within twenty (20) days after service of this subpoena. you are ordered by the court to produce the following documents or things: ~FF A'I"I'Ar.HFn MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Ad_) at You may deliver or mail legible copies of tke-1Iveu1ftents 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 haY<! 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: CHRISTOPHER KNIGHT. ESO. ADDRESS: 2411 NORTH FRONT ST. HARRISBURG. PA 17110 TELEPHONE: 215-246-0900 SUPREME COURT 10 It: ATTORNEY FOR: . DEFENDANT BY. DATE: ._)II.)~ ~4, ~rY.~. Seal of the Court .:.-,"-";"'~ (Efi. 7 WI) - = ~ '- ~'- ., ,'- ,;~ , " . ~" ,~ . "''ii! EXPIANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: RODNEY HOUGH, M.D. 49 BROOKWOOD AVENUE CARLISLE, P A 17013 RE: 98300 CONSTANCE BENTLEYLINE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: CONSTANCE BENTLEYLINE 191 RIDGE DR., CARLISLE, PA 17017 Date of Birth: 12-17-1937 5U10-382628 98300-LOl ~> 0"," " ,;" _J'~ I~"- ,;.""'~o~: CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009,22 IN THE MATTER OF: COURT OF COMMON PLEAS CONSTANCE BENTLEYLINE TERM, -V5- CASE NO: 01-2767 SCOTT As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CHRISTOPHER J; KNIGHT, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served. (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena, MCS on behalf of DATE, 07{17{2002 CHRISTOPHER J. KNIGHT, ESQUIRE Attorney for DEFENDANT DEll-346247 9S300-L02 - ~--"- , '-~ '.L., ~. > ,-~ ,- ~ A. ~ ~~}", COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE HATTER OP: COURT OP COMMON PLEAS CONSTANCE BEIlTLEYLIIIE TERM, -VS- CASE NO: 01-2767 SCOTT NOTICE OP III'RlI'l' TO SERVE A SUBPOENA TO PRODUCE I)()C1JJIBtftS MID '!'Bums FOR DISCOVERY PURSUJUr.r TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: JOSBPII B. SOBEL, ESQ. HAllC C. tAllLOV, ESQUIU MCS on behalf of CBKISTOPIIEIl J. DIGBT. ESQUIU intends to sene a subpoena identical to the one that is attached to this notIce. Yog have twenty (20) days frea the date listed below in which to file of record aml serve upon the undersigned an objection to the subpoena. If the twenty .day notice period is vaived or if DO objection is ..de, then the subpoena MY be served. ec.plete copies of any reproduced records _y be orclered at your ezpense by c.,leting the attached counsel card and returning s_ to MCS or by contacting our local MCS office, DATE: 06/27/2002 MCS on behalf of CBKISTOPIIEIl J. DIGBT. ESQUIU Attorney for D~ CC: CBKISTOPIIEIl J. DIGBT. BSQUIU- 01-427 Any questions regarding this utter, contact THE MCS GIlOUP IJIC. 1601 IWIDT STIID'1' #800 PBILADBLPBIA, PA 19103 (215) 246-0900 DE02-191461 98300-C02 ,~ - >>> LOCATION LIST <<< RECORDS REQUESTED . . MEDICAL RECORDS IIIS1JRAIICE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS , ~ ,.' ,,~"'~" ~ J ''!iiiiii:iuli!'i\D!\l-;i PAGE. 1 LOCATION lIAME RODNEY BOUGH, M,D, STAn: FARM AUTO IllS. CO. KATTIIBW IIICASTRO, PT DR. IlAIIIBL J. MCCAIDI, D.C. BRUCE D. KLASKIII, DO JOBll SPAYD TODD SAMUELS, M,D. VALHlJ'l' BOTTOM RADIOLOGY ACTIVATOR METHODS, IIIC, KAGIlBTIC IMAGIIfG \;UIUA DB02-191461 98300-C02 - -,- " ,'~ -" " ~ ~ ~" - ^ . " - ~ 1i . . COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND , CONSTANCE BENTLEYLINE VS FileNo. 01-2767 SCOTT SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: STATE FARM INSURANCE (Nome of P...on or Entity) Within twenty (20) days alter service of this subpoena, you are ordered by the .our! to produ<o the following do<uments or things: ~.... A.'l''l'jl.C~H'F.n MCS GROUP INC.. 1601 MARKET ST.. 1/800. PHILA. .PA 19103 (Addteul at '(ou may deliver or maUlegible .opies of ~1Ieculftftlts or produ.e things requested by this subpoena. together with the .ertifitate of .omplian.e.to the party making this request at the address listed above. '(ou have the right to seek. in advan.e, the reasonable .ost of preparing the copies or produdng the things sought. If you fail to prod...e the do<uments or things required by this subpoena, within twenty (20) days after its seNi.e, 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: CHRISTOPHER KNIGHT. ESO. ADDRESS: 2411 NORTH FRONT ST. HARRISBURG. PA 17110 TELEPHONE: 215-246-0900 SUPREME COURT 10 ~ ATTORNEY FOR: DEFENDANT DATE: --.J11~,)t:: ;:JL/ :::;)rY~;;}' - ,- - B~~~T~~ ~ ProthonolllryfCI Civil n '-- - /21o~t7 P. ~/J-'Y'~f o. Seal of the Court IFf. 7/ Q7\ , ~ ~"=-,' ..' '" ~" ,~~- >",'-- ~,' .t> " ' - '.' ~">'''';i.,j EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: STATE FARM AUTO INS. CO. 1690 KENNETH RD. P.O. BOX 14007 YORK, PA 17404 RE: 98300 CONSTANCE BENTLEYLINE Any and all claims files. Dates Requested: up to and including the present. Subject: CONSTANCE BENTI..EYLINE 191 RIDGE DR., CARLISLE, PA 17017 Date of Birth: 12-17-1937 Date of Loss: 06/05/0099 SU10-38Z630 98300 -L02 .- . j,'....' ~" .. ~, 1) ,- -Q;i . . CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009,22 IN THE MATTER OF: COURT OF COMMON PLEAS CONSTANCE BENTLEYLINE TERM, -VS- CASE NO: 01-2767 SCOTT As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CHRISTOPHER J. KNIGHT, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07{17/2002 CHRISTOPHER J. KNIGHT, ESQUIRE Attorney for DEFENDANT DEll-346248 9S300-L03 ~!. ~ ~' , '. .,., , '"'''' '0 ", lliJ 11irJi;i~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN TIlE KATTER OF: COURT OF COMMON PLEAS CONSTANCE BEHTLEYLIHE TEIlM, -VS- CASE NO: 01-2767 SCOT'!' NO'l'ICE OF Ilft'Ell'l' '1'0 SERVE A SUBPODA '1'0 PRODUCE DOCl)JIEN'.rS AliD THINGS FOR' DISCOVERY PURSlJAR'l '1'0 RULE 4009.21 [ Hote: see enclosed list of locations ) TO: .JOSEPH B. SOBEL, ESQ. KAIlC c. TARLOW, ESQUlU MCS on behalf of CBlUS'fOPBER .J. lDIIGIft', ESQUlU intends to serve a subpoena identical to the one that is attached to this Dotice. Y_ have tweDty (20) days frOlll the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the tweDty. .day Dotice period is waived or if no objection is _de, then the subpoena _y be served. ea.plete copies of any reproduced records _y be ordered at your ezpeIlse by caapleting the attached counsel card and retuming s_ to MCS or by contacting our local MCS office. nATE: 06/27/2002 MCS on behalf of CBlUS'fOPBER .J. IDIIGIft'. ESQUllIE Attorney for DEPBlIIlAft CC: CBI.lS'fOPBER J. IDIIGIIT, ESQUllIE- 01-427 /my questions regarding this _tter. contact TIlE MCS GIlOUP DIC. 1601 lWlD'l' STIlEET '800 PBlLADELPB1A. PA 19103 (21.5) 246-0900 DE02-191461 98300-C02 .. ~ "". , -, .' >>> LOCATIOM LIST <<< RECORDS REQUESTED . 'MEDICAL RECORDS IMSUllAMCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS ., ~.~~ PAGE: LOCATIOM 1fAME RODllEY BOUGH, H,D, STATE FARM AUTO IllS. CO. HAT'tIIEW HlCASTRO, PT DR, DANIEL J, HCCAIIIr, D. C, BRUCE D. KLASlUM, DO JOB SPAYD TODD SAHlIELS, H,D. WALIltI'f BOTTOK RADIOLOGY ACTIVATOR METHODS, DlC, HAGME'l'IC IHAGUJG CEIITER ~.-,=" " '~'iWJ~l\;g,! 1. " DB02-1.91461 98300-C02 . . . " \ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CONSTANCE BENTLEYLINE VS FileNo. 01-2767 SCOTT SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009,22 TO: CUSTODIAN OF RECORDS FOR: RODNEY K. HOUGH, M,D, (N.amr of Penon or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documettts or things: !:: F"'R A '1''' A c;FrRn at MCS GROUP INC" 16Dl MARKET ST" #800, PHlLA"PA 19103 (Ad.u...) You may deliver or mail legible copies of tftttUecu~ts or produce things requested by this subpoena, together with the certifica.te of compliance, to the party making this request at the address listed above. You hav-e 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: CHRISTOPHER KNIGHT. ESO, ADDRESS: 2411 NORTH FRONT ST, HARRISBURG. PA 17110 TELEPHONE: 215-246-0900 SUPREME COURT IV If: ATTORNEY FOR: DEFENDANT BY DATE: . )/' D~ ,,;)4. ~rr\~. Seal of the Court ".-= .~;~ . ..-.~ (Eff. 7/971 . "~.'"~ . , ",. ,_ ,L' " '. ~ _', '-1_.," , "" . "--";~,\ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MAITHEW NICASTRO, PT 205 N. HANOVER STREET. CARLISLE, PA 17013 RE: 98300 CONSTANCE BENTLEYLINE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: CONSTANCE BENTLEYLINE 191 RIDGE DR., CARLISLE, PA 17017 Date of Birth: 12-17-1937 5U10-382632 9S300-L03 I:~ ~~ " ,1 ~~r ."~ ," '__~;'H 'I ,;~},: . . CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN tHE MATTER OF: COURT OF COMMON PLEAS CONSTANCE BENTLEYLINE TERM, -VS- CASE NO: 01-2767 SCOTT As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CHRISTOPHER J. KNIGHT, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/l7{2002 CHRISTOPHER J. KNIGHT, ESQUIRE Attorney for DEFENDANT DEll-346249 98300-L04 , ~' ~ ,~- ,," ,- ~ , . 411 . . COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE HATTER OF. COURT OF COMMON PLEAS CONSTANCE BENTLEYLINE TEBK, -VS- CASE NO. 01-2767 SCOTT NOTICE OF 1R'rEN'l' TO SERVE A SUBPOERA TO PRODUCE DOCUlIER'1'S AND THINGS FOR DISCOVERY PURSUA1ft' TO RULE 4009. 21 ( Note. see enclosed list of locations ] TO. .JOSEPH B. SOBEL, ESQ, HAIlC C. tARLOW, ESQUIRE MeS on behalf of CHRISTOPHER .J. DIGBT, BSQUID intllllds to serve a subpoena identical to the one that is attached to this DOtice. You have twenty (20) days frea the date listed below in which to file of record lIIId serve I1JIOIl the UDdersigned 1III objection to the subpoena. If the twenty day notice period is waived or if no objection is I118.de, then the subpoena may be served. C~lete copies of lIIIY reproduced records _y be ordered at your expense by c...,letinr. the attachedcoUDsel card and returninr. s_ to MeS or by contacting our local MeS office. DATE. 06/27/2002 MeS ou behalf of CDISTOPBD. .J. D1GBT, BSQUIRE Attorney for DBFEIIDART CC. CDISTOPHER.J. D1GBT, BSQUIRB- 01-427 Any questions regarding this I118.tter, contact '!lIB MeS GllOlJP D1C. 1601 HAllDT STREET #SOO PllIIADBLPHIA, PA 19103 (215) 246-0900 DB02-191461 98300-C02 J:aljU7'-~ RECORDS REQUESTED . . MEDICAL RECORDS INSUlWlCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS - ~ , >>> LOCATION LIST <<< . Iill. ',,'" ~ .",--~,",,' ~ . ~ ~='~~ ~?, PAGE: 1 LOCATION IlAHE RODNEY HOUGH, H,D. STATE FAllM AUTO IRS, CO. MAT'l'BEW NICASTRO, PT DR. DANIEL J. HCCANlf, D.C. BRUCE D, KLASnN, DO JOHN SPAYD TODD SAHIlELS, H,D. WALNUT BOTTOK RADIOLOGY ACTIVATOR METHODS, IRC, MAGNETIC IMAGING CENTER DE02.-191461 98300-C02. . . COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CONSTANCE BENTLEYLINE vs File No. 01-2767 SCOTT SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: STATE FARM INSURANCE (Name ot Penon or Entity) Within twenty (20) days after service of this subpoena, you .... ord.red by th. court to produc.th. following docum.nts or things: ~R~ ATTAr.1=llm at MCS GROUP INC, , 1601 MARKET ST" #800, PHlLA.,PA 19103 (Address) You may deliver or mail legible copies of tft1!'deeuments 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 rail to produc.the documents or things required by this subpoena. within twenty (20) days after its servic., the party serving this subpoena: may seek a court order compeJJing you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CHRISTOPHER KNIGHT. ESO, ADDRESS: 2411 NORTH FRONT ST. HARRISBURG. PA 17110 TELEPHONE: 215-246-0900 SUPREME COURT 10 It: A TIORNEY FOR: DEFENDANT ;:;}.Lf, ;::;:),-y,;;J.. - DATE: .......J'lJ"IP PMthotlobry/Cl_ Civil. n '-- . ~f7--r'" p ~/JA''Y'' f Seal of the Court {T:ff 7/Q7'\ . '.' .' '" "~-' . , ~ " 1.:-" ,:.;."-~'.' ~--.d-_."'.'~~_hi EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. DANIEL J. MCCANN, D.C. S BROOKWOOD AVENUE SUITE-3 CARLISLE, PA 17013 RE: 98300 CONSTANCE BENTLEYLINE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: CONSTANCE BENTLEYLlNE 191 RIDGE DR., CARLISLE, PA 17017 Date of Birth: 12-17-1937 SUlO-382634 98300-L04 - '."\ - ... ~ .L J~" ; ~.'O ~i!ii~} CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009,22 IN THE MATTER OF: COURT OF COMMON PLEAS CONSTANCE BENTLEYLINE TERM, -VS- CASE NO: 01-2767 SCOTT As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CHRISTOPHER J. KNIGHT, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/17/2002 CHRISTOPHER J. KNIGHT, ESQUIRE Attorney for DEFENDANT DEll-346250 9S300-LOS -,"" ',.J ~~ b ~ . ~- ~ <"~ ~< ...."" . ~>w ')'. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OP: COURT OP COMMON PLEAS CONSTANCE BEHTLEYLlHE TE1lK, -VS- CASE NO: 01-2767 SCOTT NanCE OF IN'.rEN'.r '1'0 SERVE A SUBPOENA 'l'O PRODUCE IlOCtJICBlft'S AND THINGS FOR DISCOVERY PURSUAN'l' '1'0 RULE 4009.21 [ Note: see enclosed list of locations ] TO: JOSIPB B. SOBEL, ESQ, MAKe C. '1'A1lLOW, ISQUlIlB !CS on behalf of CIIKlS1'OPBEll J. IDIIGIIT, ESQUlIlB intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days fr_ the date lillted bel_ in which to file of record ad 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. ec.plete copies of any reproduced records may be ordered at your ezpeI1se by caapleting the attached counsel card and returning s_ to !CS or by contacting our local !CS office. DATE: 06/27/2002 !CS on behalf of CIIKlSTOPBD. J. DIGIIT, ESQUIIlB Attorney for Dn'BRDA1I't CC: CIIKlSTOPBD. J. IDIIGIIT, ESQUlIlB- 01-427 Any questions regarding this matter, contact TBE !CS GROUP DIC. 1601 MAIllET STIlBE'1' #800 PJnLADELPBIA, PA 19103 (21S) 246-0900 DI02-19H61 98300-C02 < .~ >>> LOCATIOH LIST <<< RECORDS REQUESTED . . MEDICAL RECORDS IHSURAHCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS ,.', -" ",' ,,' ~ '~h lW'-- --.. '~\" "-~w , -,,,"= PAGE: 1 LOCATIOH !lAME RODKEY BOUGH, K,D. STATE FARK AUTO IHS, CO, MATTBEll' NICASTRO, PT DR, DANIEL J. KCCAlOI, D. C. BRUCE D. KLASKlN, 00 JOBII SPAYD TODD SAMUELS, H.D, WALIIOT BOTTOM RADIOLOGY ACTIVATOR METHODS, IHC. MAGllETlC DfAGIHG CEIITD. " DE02-191461 98300-C02 . COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND o CONSTANCE BENTLEYLINE vs FileNo. 01-2767 SCOTT SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009,22 TO: CUSTODIAN OF RECORDS FOR: MATTHEW NICASTRO, PT (N.am" of Penon 01' Entity) 'Within twenty (20) da.ys after service of this subpcxN,. you are ordered by the court to produce the following documents 01' things: ~FF. ATTAr.HFn - at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Ad.u.s.) You may deliver or mail legible copi.es of the-1iecuments 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: CHRISTOPHER KNIGHT. ESO. ADDRESS: 2411 NORTH FRONT ST. HARRISBURG. PA 17110 TELEPHONE: 215-246-0900 SUPREME COURT ID "- ATTORNEY FOR: DEFENDANT BY DATE: '- ), J L )s:' .:)c.; ;:;;)~~ ( ....... Seal of the Court _ __'n'rr;'JJ_7j07'\ 1,- . _ L__~ .'" """'. ._',',,~ ~ -iL,,,-' '" -~-- ,C '0"', , ir.~ EXPIANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: BRUCE D. KLASKIN, DO 795 CHERRY TREE CT. STE 1 HANOVER, PA 17331 RE: 98300 CONSTANCE BENTLEYLlNE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: CONSTANCE BENTLEYLINE 191 RIDGE DR., CARLISLE, PA 17017 Date of Birth: 12-17-1937 8U10-382636 98300-L05 ~ . . . ,,' ~ - ~, ---" '-~ '.', ~, ""'''', "[ -',,", ~~""\t CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009,22 IN THE MATTER OF: COURT OF COMMON PLEAS CONSTANCE BENTLEYLINE TERM, -VS- CASE NO: 01-2767 SCOTT As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CHRISTOPHER J. KNIGHT, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/17{2002 CHRISTOPHER J. KNIGHT, ESQUIRE Attorney for DEFENDANT DEll-346251 9S300-L06 I. ~_~ ~, ~. ,;"J'_"--"" l.".ili~~; COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE HATTER OF: COURT OF COIH>N PLEAS CONSTANCE BENTLEYLIME TEllM, -VS- CASE NO: 01-2767 SCOTT NOTICE OF IR'rBII'r 'l'O SERVE A SUBPOENA TO PRODUCE DOCtJMENTS AND TBIBGS POR DISCOVERY PURSUAII'.r 'l'O RULE 4009.21 [ Note: see enclosed list of locations ) TO: .JOSBPB B. SOBEL, ESQ. HABC C. TARLOW, ESQUIU K:S on behalf of CIIlUSTOPBEll J. DIGB'f, ESQUIU intends to serve a subpoena identical to the one that is attached to this DOtice. Yon have t1IllIlty (20) days frea the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena, If the t1IllIlty .day DOtice period is _ived or if DO objection is IDade, then the subpoena IDaY be served. CclIIplete copies of any reproduced records IDaY be ordered at your ezpense by cmlpleting the attached counsel card and returning s_ to tl:S or by contacting onr local tl:S office. DATE: 06/27/2002 MCS on behalf of CIIlUSTOPBEll .J. DIGB'f, ESQUIU Attomey for DEPE1mA1rr cc: CIIlUSTOPBEll .J. DIGIJ'f, ESQUIU- 01-427 Any questions regarding this IDatter, contact TBIl MCS GROUP IlIC. 1601 HAUEr STREIT laoo PBTT An1n.PJIIA, PA 19103 (215) 246-0900 DE02-191461 98300-C02 ., ~ ,," ~ " >>> LOCATION LIST <<< RECORDS REQUESTED MEDICAL RECORDS INSURANCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL BCORDS MEDICAL BCORDS '"" , .' -. PAGE: LOCATION IWfE RODNEY HOUGH. M,O, STATE FARM AUTO INS. CO. MATTHEW NICASTRO. PT OR. DANIEL J. HCCANIf. D.C, BRUCE O. ltLASnN. DO JOHN SPAYD TODD SAMUELS. M,O, WALN1JT BOT'l'OM RADIOLOGY ACTIVATOR METHODS. INC. MAGNETIC IMAGING CEIlTER . v~" . "' 1 DE02-191461 98300-C02 '1~ "' ~" " " Iii,; --,.~; . . ': COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND CONSTANCE BENTLEYLINE VS File No. 01-2767 SCOTT SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.~ TO: CUSTODIAN OF RECORDS FOR: JOHN SPAYD (Name of P....... or Enrityl Within twenty (20) days alter service of this subpoe~ you are ordered by the court to produce the following docu_ or things: ~1:'R' A'1'TAr.1=I'F.n - MCS GROUP INC., 1601 MARKET ST., *800, PHlLA.,PA 19103 (Addresl) .t You m.y deliver or m.illegible copies of t+le-.....lIIetlls or produce things requested by this subpoena. together with the certific.te of compliance, to the party making this request at the .ddr.... 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: CHRISTOPHER KNIGHT. ESO. ADDRESS: 2411 NORTH FRONT ST. HARRISBURG. PA 17110 TELEPHONE: 215-246-0900 SUPREME COURT ID I: A lTORNEY FOR: DEFENDANT DATE:.... hi. ~f. ;:)4 ~A6:J ( --- BY~;;~T~ ~ _~ ~ ~~~tJ_ /)~~ Oepu ---- Seal of the Court {t:t~ 7/Q'7\ J._ ,'~ ." -'-~ " " . ' ~,o ";'~ ., "'"' ~ ,~',. i.,"~' - ___' '-.d;'\,; EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOHN SPAYD 205 N. HANOVER STREET CARLISLE, P A 17013 RE: 98300 CONSTANCE BENTLEYLINE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: CONSTANCE BENTLEYLINE 191 RIDGE DR., CARLISLE, PA 17017 Date of Birth: 12-17-1937 SU10-382638 98300-L06 "h~~ J' - '" n." . , _1! l~ ~[llilil'" i'~~i CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUAlIT TO RULE 4009,22 IN THE MATTER OF: COURT OF COMMON PLEAS CONSTANCE BENTLEYLINE TERM, -VS- CASE NO: 01-2767 SCOTT As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CHRISTOPHER J. KNIGHT, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served. (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena, MCS on behalf of PATE: 07/17/2002 CHRISTOPHER J. KNIGHT, ESQUIRE Attorney for DEFENDANT DEll-346252 98300-L07 I"' ,," .~' , .' ~, .~~ ',,, ,.'~ - -0 ':"~ ~'- a :e COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND 1M TIlE MATTEll OPt COUllT OF COlH)B PLEAS COMSTAIlCE BEHTLEYLlllE TEIlM, -vs- CASE MO: 01-2767 SCOTT RO'lICE OP III'lENT TO SERVE A SUBPOEIIA TO PRODUCE lXK;,"l'JISII'J.'S AIID THINGS PaR DISCOVERY PURSUAliT TO RULE 4009.21 [ Rote. see enclosed list of locations ] TO: .JOSBPII B. SOBEL, ESQ. JfAJI.C C. TAIlLOW, ESQUIBE MCS on behalf of CBRISTOPIIBIl .J. DIGBT, ESQUIU intl!llds to sene a subpoeDa identical to the one that is attac:hed to this _tice. Yon ha_ t\IIenty (20) days fr_ the date listed below in which to file of record and sene upcm the unclersiped an objection to the subpoeDa. If the t\IIent'J .day _tice period is waived or if DO objection is _de, then the subpoeDa _'1 be served. ea.plete copies of any reproduced records _'1 be ordered at your expeIIse by c.-pleting the attached counsel card and retumiD& Sag! to MCS or by contacting our local MCS office. DATE. 06/27/2002 MCS on behalf of CBRISTOPIIBIl .J. DIj;8T, ESQUlBE Attorney for DEnIIWI'! cc: CBIlISTOPIIBIl.J. DIGBT, ESQUIU- 01-427 Any questions regarding this _tter, contact TIIB MCS GROUP IIIC. 1601 IWlD'l . STRBB1 #aoo pIIn.Amrr.PBIA, PA 19103 (21S) 246-0900 DE02-l91461 98300-C02 , . >>> LOCA'flOIl LIST <<< RECORDS REQUESTED KEDICAL RECORDS IlISURAHCE KEDICAL RECORDS KEDICAL RECORDS KEDICAL RECORDS KEDlCAL RECORDS KEDlCAL RECORDS KEDlCAL RECORDS KEDlCAL RECORDS KEDlCAL RECORDS ~,-- ,-- -, ..- PAGE: LOCA'flOIl lWIE RODDY BOUGH, M,D. STAn: FAJlM AUTO IllS. CO, MAT'1'IIEV lflCASTRO, PT DR. DAlflEL J. MCCAlftI, D. C. BRUCE D. KLASKlM, DO JOBlf SPAYD TODD SAHllELS, M.D. WALlftJT BOTTOM RADIOLOGY ACTIVATOR METHODS, lRC. MAGIlB'flC lHAGlIIG CEIl'I'EIl ~~ , ' - _ijEM:'; 1 , DE02-191461 98300-C02 . COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND o CONSTANCE BENTLEYLINE vs File No. 01-2767 SCOTT SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: DANIEL MCCANN, DC (N.ame of Penon or Entity) Within twenty (20) days after service of Utis subpoen... you ue ordered by the court to produce the following documents or things: !=:'RF A'T''l'Ar.HRn at MCS GROUP INC., 1601 MARKET ST., #800, PRILA.,PA 19103 (Addross) You may deliver or mailtegible copies o! ~<ie<u""",.. 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 SOUght4 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 compeHing you to comply with it. THIS SUBPOEN A WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CHRISTOPHER KNIGHT. ESO. ADDRESS: 2411 NORTH FRONT ST. HARRISBURG. PA 17110 TELEPHONE: 215-246-0900 SUPREME COURT 10 " ATTORNEY FOR: DEFENDANT BY Prothonotary/Clerk: Q DATE: ...... ;,-' .~- ;:)4 , ::J ry.;:J... ..... Sea! of the Court {,:'ft '1/Q7'\ ."" . ""'-''''", ~ ~ ^ '/'~" "-', '; , ",.:, ',,,- "'";"'i'; EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: TODD SAMUELS, M.D. 897 POPlAR CHURCH RD. CAMP HILL, P A 17011 RE: 98300 CONSTANCE BENTLEYLINE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: CONSTANCE BENTLEYUNE 191 RIDGE DR., CARLISLE, PA 17017 Date of Birth: 12-17-1937 SUIO-382640 98300-L07 ~" "'" - '" ~.i-";" ,.:<,,'.__ ""'~7, CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CONSTANCE BENTLEYLINE TERM, -VS- CASE NO: 01-2767 SCOTT As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 KCS on behalf of CHRISTOPHER J. KNIGHT, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. KCS on behalf of DATE: 07/17{2002 CHRISTOPHER J. KNIGHT, ESQUIRE Attorney for DEFENDANT DEll-346253 98300-L08 . - '~- ~ , <~ . - Jl!i:'" CO~ONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE KATTER OF: COUll.T OF COIH)M PLEAS COMSTAllCE BE1fTLEYLllIE TERM. -vs- CASE NO: 01-2767 SCOTT lIO'1'ICE OF Ilt'.rBlft TO SERVB A SUBPOElIA TO PRODUCE DOCUJIER',rS AIm 'l'BIRGS FOR DISCOVERY PURSUAII'.r TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: .10SBPB B. SOBEL. ESQ. KABC C. TAllLOV. ESQUIRE J<<:S on behalf of CBRISTOPIIER .1. DIGB1'. ESQtJDB intends to serve a subpoena iclentical to the one that is attached to this IIDtice. You have twenty (20) days frea the date listed bel_ in which to file of record 8Dd serve upon the undersiped IUl objection to the subpoena. If the twenty day notice period is waived or if no objection is ..de. then the subpoeaa ..y be served. ea.plete copies of lUly reproduced records ..y be ordered at your ezpense by cmlpleting the attached counsel card IUld retunaing s_ to IES or by contacting our local J<<:S office. ~TB: 06/27/2002 IES on behalf of CBRISTOPIIER .1. DIG81. ESQUIU Attorney for DBRIIIlAB'f ee: CBRISTOPIIER .1. DIGB1'. ESQUIU- 01-427 Any questions reprding this ..tter. contact THE IES GROUP INC. 1601 KAJID'l SftU'f #800 PBTI.Amn."IIIA. PA 19103 (215) 246-0900 DE02-191461 98300-C02 , ~.... . >>> LOCATIOR LIST <<< RECORDS REQlIESTED MEDICAL RECORDS INSUIWICE MEDICAL RECORDS MEDICAL RECOllDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECOllDS MEDICAL RECORDS ,^ , ;'"- - PAGE: LOCATION IWIE RODIlEY BOUGH, M.D. STAn FAlIM Atml IllS. CO, MATTHEW NlCAS'l'RO, PT DR. DAIIIEL J. MCCAlQI, D.C. BRUCE D. 1lLASXl1f, DO JOHN SPAYD TODD SAHlJELS, M.D. WA1JIlI'f BOT'fOM RADIOLOGY ACTIVATOR HETBODS, llIC. MAGlUTIC IMAGIIIG CERTER - :1;; 1 :..,'. -,:;.; :~ J DE02-191461 98300-C02 ,.." " <'.~, "q If';'" . . , '. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CONSTANCE BENTLEYLINE VS FileNo. 01-2767 SCOTT SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: WALNUT BOTTOM RADIOLOGY (Nam. of Ponon or Entity, Within twenty (20) days after service of this .ubpoe.... you are ordered by the court to produce the following dOCUlMnts Of things: ~F.F ATTAr.'RFn. - at MCS GROUP INC., 1601 MARKET ST., #800, PHlLA.,PA 19103 (Ackboso) You may deliver or mail legible copies of lhe-llllCulI....ts or produce things requested by this subpoena, together with the certificate of compliance, to the party malcing thi. 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: CHRISTOPHER KNIGHT. ESO. ADDRESS: 2411 NORTH FRONT ST. lUllltTSBURG. PA 17110 TELEPHONE: 215-246-0900 SUPREME COURT to fh ATrORNEY FOR: DEFENDANT B E COURT: DATE: ~ ), L .-I ')c? :::Jl.( ~ r...,~ , --- Prothonotaty/Clork. CIvIl Seal of the Court rFff 7/<,7\ ~ """--I " . ,~ " ,.c...." ,,,~, ,," _n. ;,;- --~ <' EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: WALNUT BOTIOM RADIOLOGY BELVEDERE MED. erR. 850 WALNUT BOTIOM RD CARLISLE, P A 17013 RE:98300 CONSTANCEBENTLEYUNE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: CONSTANCE BENTLEYLINE 191 RIDGE DR., CARLISLE, PA 17017 Date or Birth: 12.17.1937 5U10-382642 98300-L08 " " , "-' " " -;. ~. "~""",,,,;;sc(ifc CERTIFICATE PREREqUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009,22 IN THE MATTER OF: COURT OF COMMON PLEAS CONSTANCE BENTLEYLINE TERM, -VS- CASE NO: 01-2767 SCOTT As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 KCS on behalf of CHRISTOPHER J. KNIGHT, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served. (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. KCS on behalf of DATE: 07{17/2002 CHRISTOPHER J. KNIGHT, ESQUIRE Attorney for DEFENDANT DEll-346254 9S300-L09 " ~".' , ~ ,- ~~"'-'"''-llfi':JI~ @;:! COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND III THE HATTEll 01": COUllT OF COIIfOlt PLEAS COIISTAlfCE BEllTLEYLINE TERM, -VS- CASE ltO: 01-2767 SCOTT RO'l'ICE OP IN'l'BR'l' TO SERVE A SUBPOBlIA TO PRODUCB IlOCUlmR'rS AIm TBIHGS FOR DISCOVERY PURS1JAJI"l' TO RULE 4009.21 [ Rote: see enclosed list of locations ] TO: .lOOPS B. SOBm., ESQ. HARe C. TAJILOV, ESQUlIIB HCS on behalf of CHRISTOPHER J. DllGIIT, ESQUIBE intends to serve a subpoena identical to the one that is attached to this notice. Y_ have twenty (20) days f~ the date lillted bel_ in which to file of record III1d serve upaa the. UDders1ped 11I1 objection to the subpoena. If the twenty .day notice period is _ived or if no objection is _de, then the subpoena _y be served. ec.plete copies of lUly reproduced records _y be orelered at your ezpeIlse by caspleting the attached counsel card and returnin& s_ to HCS or by contacting our local HCS office. DAD: 0612112002 HCS on behalf of CHRISTOPHER J. DllGIIT, BSQUIIIB Attorney for uU~ cc: CHRISTOPHER J. DllGIIT, BSQUIIIB- 01-421 Any questions regarding this _tter, contact 'lIIB HCS GROUP D1C. 1601 IIAIlDY STIID'l #800 P1JTt ..mn PIllA, PA 19103 (215) 246-0900 DB02-191461 98:300-C02 - - - ~"',. >>> LOCAUOB LIST <<< RECORDS REQUESTED MEDICAL RECORDS IHSURARCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS .=-"<. " ~ '"'- '.......~ ~ - PAGE: LOCAUOII IIAME RODIIEY BOUGH, M,D, STAn PAllM AUTO IllS, CO, KAT'1'IIEW IIICASTRO, PT DR. DAIIIEL J, MCCAIIII, D. C. BRUCE D. ILASnll, DO JOB SPAYD TODD SAMUELS, M.D. VALHU'! BOT'lOH RADIOLOGY ACTIVATOR METHODS, IIIC. KAGllEUC IMAGIIIG CEIITER. 1 >~ .~ ";<,j' . .. DB02-191461 98300-C02 . COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CONSTANCE BENTLEYLINE VS FileNo. 01-2767 SCOTT SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: ACTIVATOR METHODS, INC. (Name of P~non or Entity) Within twenty (20) day. after ...rvice of thi. subpoena. you are ordered by the court to produce the foHowing documents or things: ~F.F AT"Ar.R'Rn at MCS GROUP INC., 1601 MARKET ST., 11800, PHILA. ,PA 19103 (Address} '(ou may deliver or maillegibte copies of the"~!ft'ents or produce things requested by this subpoena.. together with the certificate of compliance, to the party making this request at the addres~ 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 .ubpoena. within twenty (20) days after it. service, the party serving this subpoena may seek a court order compe:l1ing you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CHRISTOPHER KNIGllT. ESQ. ADDRESS: 2411 "NORTH FRONT ST. HARRISBURG. PA 17110 TELEPHONE: 215-246-0900 SUPREME COURT ID It, A TIORNEY FOR: DEFENDANT DATE:,- )/ ~ L"y;;' ,.:::)4 .;trv.~ ~ " BY~~') ~ .~ ProlhonobryfClerl<. Qvil ............ - .an/}" <:> P - ~.(7./y vi Oepu . Seal of the Court f'f:U ~ ,_qn EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ACTIVATOR METHODS, INC. PO BOX 80317 PHOENIX, AR 85060 RE: 98300 CONSTANCEBENTLEYUNE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: CONSTANCE BENTLEYLINE . 191 RIDGE DR., CARLISLE, PA 17017 Date of Birth: 12.17.1937 SU10-382644 9S300-L09 -'.-: ~"".- " . Yf:t< CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CONSTANCE BENTLEYLINE TERM, -vs- CASE NO: 01-2767 SCOTT As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CHRISTOPHER J. KNIGHT, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/17/2002 CHRISTOPHER J. KNIGHT, ESQUIRE Attorney for DEFENDANT DEll-.346255 98300-L10 . . ,'........'- ,-.-, , . ~'~, ,- - ..~ "~-'";-.'~O~~"'''-Itii: 1.:&- "'1 COM:M:ONWEALTH OF PENNSYLVANIA. COUNTY OF CUMBERLAND IN THE MATTER OF, COURT OF COIH)H PLEAS CONSTANCE BElf'l'LEYLIIlE TE!lM, -vs- CASE RO. 01-2161 SCOTT IIO'.l'ICB OF IIft'Bft '1'0 SERVE A SUBPOBRA '1'0 PRODUCE DOCUlIBR'.rS ARD TBIBGS FOR DISCOVERY PURSUAlft '1'0 RULB 4009.21 [ Rote. see enclosed list of locations ] TO. .10SEPH B. SOBEL, ESQ. MAIlC C. TAlLOW, ESQUlU illS on behalf of CHRIStoPHER .1. D1IGHT, ESQUlIB intl!llCls to serve a 1I1IbpoeQa"', . ., identical to the one that is attached to this Datice. You have ~tY(2. .0-) .....f...::.' days fr_ the date listed below in which to file of record and serve IJllOIl ", undersigned an objection to the subpoena. If the ~t:r .day Datice periOd 1.', _bed or if no objection is made, then the subpoena _y be served. ec.plete copies of any reproduced records may be ordered at your .~.e by. CC8pletiag the attached counsel card and retuming same to illS or by contactiag our local illS office. DATE. 06/21/2002 illS on behalf of CHRIStoPHER .1. BIGHT, ESQUllIE Attomey for uki~uAII'f ce. CHRIStoPHER .1. BIGHT, BSQUlU- 01-427 Any questions regarding this matter, contact TIlE illS GIOUP DC. 1601 lfAUB'f S'l'IBft #800 PIllLADBLPBlA, PA 19103 (215) 246-0900 DE02-191461 9S300-C02 ',j " , >>> LOCATION LISt <<< _ d' .".. ~ r ~~ PAGE. RECORDS REQUESTED MEDICAL RECORDS IRSURAlfCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS LOCATIOR !lAME RODDY BOUGH, M.D. STAtE FARM AUTO IRS. CO. MATtHEW NICASTRO, PT DR. DARIEL J. HCCANR. D.C. BRUCE D. KLASKlN, DO JOHN SPAYD TODD SAMUELS, M.D. 'iW.NU'l BOTTOM 1IADIOLOGY ACTIVAtoR ME'l'BODS, IRe. MAGNETIC DfAGIRG CENTER -"~~j,; 1 ~~~ ~ j '. DB02-191461 98300-C02 - '" ~-, " <<-; . - , ", , \ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CONSTANCE BENTLEYLINE vs File No. 01-2767 SCOTT SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RUI,E 4009.~ TO: CUSTODIAN OF RECORDS FOR: MAGNETIC IMAGING CENTER (Name of Person or Entity) Within twenty (20) clays alter ...rvice of this subpoena, you _ ordered by the court to produce the following documents or things: ~1i"V A.T"A.r.~rn - at MCS GROUP INC" 1601 MARKET ST., H800, PHILA.,PA 19103 (Addnul You may deliver or mail legible copies of ~1hI<u-..ts 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 s...k, in advance. the reasonable cost of preparing the copies or producing the things sought. If you faU 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 com~1Jing you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME; CHRISTOPRF.1l KNIGHT. ESO. ADDRESS: 2411 NORTH FRONT S1. HARRISBURG. PA 17110 TELEPHONE: 215-246-0900 SUPREME COURT 10 ,I, ATTORNEY FOR: DEFENDANT DATE: -1u.....)<>:' ~qt .:;lrv,~..... Seal of the Court IlJf 7/97) , , EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MAGNETIC IMAGING CENTER 4665 TRINDLE ROAD MECHANICSBURG, PA 17055 RE: 98300 CONSTANCE BENTLEYLINE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: CONSTANCE BENTLEYLINE 191 RIDGE DR., CARLISLE, PA 17017 Date of Birth: 12-17-1937 ,,- - .-~ ,,,,-',~,,;~'"" - '_L"'~~"W~-~".-i SU10-382646 983 00 - L:L 0 " , .'~ r.'_ _ ~,~,~" ",_ ,~.." ,~~'"_ . __'=_=~"" _~ - ~ ,~--~-__.,_ "' ._'_,,,__''''' ,"'''_''_'~ . HENRY LINE AND CONSTANCE BENTLEY LINE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs NO. 01-2767 v. CIVIL ACTION - LAW MICHAEL SCOTT, Defendant JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Michael Scott, with regard to the above-captioned matter. Respectfully submitted, NEALON & GOVER, P.C. By: 1U(i~(~~ Michael S. Ferguson, Esquire Attorney 1.0. No. 83882 2411 North Front St. Harrisburg, PA 17110 (717) 232-9900 Date: 11::J(( (03 -,~~.- >_c'~'"~'_ _ .--~-~_ -o.--.~__~A.~_""'_"",V__<~_.__ ,',~ _, '~jj: , 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: Marc G. Tarlow, Esquire Kain, Brown & Roberts, LLP 119 East Market Street York, PA 17401 Joseph B. Sobel, Esquire 212 North Third St., Suite 202 Cranberry Court Harrisburg, PA 17101-1505 ~~~q";re ~ .'......:;. ~_",' ~,_'.<,~." _ .W J'Iil.' ,"~ , . ~~~ -"--~ ,,~. ." ill -.-",..,- _ , .'';:-'J';''~~~''~'" .' ~, ~~--""' ,~ .. (") c ~ :.~.: f~~5 . I I'''' :~.!,J (~,i;~ ,~ " ~-~ =::: ....., (;.~ => <....> o Pl n o Tj ~ nl:IJ ,..... -om :"'JO 0' --;0 :r: :ri O-D zCl cSm ,--> ~ ~l U1 ~ ~,) (..) c.J " ~- _,J"',._ -"'- .C_,,,,_ ....-.,--'",,'" ~"_C':_ "o'_'~o~_,,~_,_"_I,.;.-_--.-_,,~__ -- ";.~-',~ - '-;~';;;_d,o'_~"J.; ',,',_. "'e. __,"", .'L-~__.'_ __~_,_ ""J/-. ~ ~-~~'-- HENRY LINE AND CONSTANCE BENTLEY LINE, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-2767 v. CIVIL ACTION - LAW MICHAEL SCOTT JURY TRIAL DEMANDED PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please mark the above-captioned matter settled, satisfied and the docket discontinued. Respectfully Submitted, SHUMAKER WILLIAMS, P.C. " Date: (J.G-il-f)'! By: ~/ ( . arc ow, Esquire Attorney 1.0. No. i$'I7l( 119 East Market Stree York, PA 17401 (717) 848-5134 liii? 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