HomeMy WebLinkAbout01-03972
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
DONALD TOWSEY, as Administrator
of the Estate of Mark Towsey, Deceased,
and bonald Towsey, Individually and
in his own right
2130 Canterbury Drive
Mechanicsburg, PA 17055
NO. d ~ / ~ ! ^Ic~ ~~ U1°
CIVIL ACTION -LAW
JURY TRIAL DEMANDED
HOWARD RUDNICK, M.D.
North 215` Street
Camp Hill, PA 17011
HOLY SPIRIT HOSPITAL
North 21St Street
Camp Hill, PA 17011
HOLY SPIl2IT HOSPITAL OF THE
SISTERS OF CHRISTIAN CHARITY
t/d/b/a HOLY SPIRIT HOSPITAL
North 21S` Street
Camp Hill, PA 17011
Plaintiffs & Address Versus Defendants & Addresses
PRAECIPE FOR WRIT OF SUMMONS
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please issue a Writ of Summons in the above-captioned action.
X Writ of Summons shall be issued and forward to: (X) Sheriff ()Attorney
Dated: June 26, 2001
David Wisneski, Esquire
Nauitsky, Olson & Wisneski LLP
2040 Linglestown Road, Suite 303
Harrisburg, PA 17110
717/541-9205
Counsel for Plaintiffs
I.D. No. 58746
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11
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
DONALD TOWSEY, as Administrator
of the Estate of Mark Towsey, Deceased,
and Donald Towsey, Individually and
in his own right
2130 Canterbury Drive
Mechanicsburg, PA 17055
Plaintiffs & Address Versus
Defendants & Addresses
WRIT OF SUMMONS
TO THE ABOVE-NAMED DEFENDANTS:
YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED
AN ACTION AGAINST YOU.
CIVIL ACTION -LAW
NRY TRIAL DEMANDED
HOWARD RUDNICK, M.D.
North 21st Street
Camp Hill, PA 17011
HOLY SPIRIT HOSPITAL
North 21st Street
Camp Hill, PA 17011
HOLY SPIl2IT HOSPITAL OF THE
SISTERS OF CHRISTIAN CHARITY
t/d/b/a HOLY SPIRIT HOSPITAL
North 21St Street
Camp Hill, PA 17011
Prothonotary
Dated• ~~` by
De~pputy
~,F i"~~Yirnosiy wnoroot, f hmre unte set my hang
grid th0 ssal.Of ~it1 Court at Carllsie. Ra.
Phis fh G8y (~~1e- -,o~2~C~1~}~-,
prothonotary ~
SHERIFF'S RETURN - REGULAR
CASE N0: 2001-03972 P
COMMONWEALTH OF PENNSYLVANIA:
COUN'T'Y OF CUMBERLAND
TOWSEY DONALD
VS
RUDNICK HOWARD MD ET AL
CPL MICHAEL BARRICK
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within WRIT OF SUMMONS was served upon
RUDN7CK HOWARD MD the
DEFENDANT at 0905:00 HOURS, on the 10th day of July 2001
at 503 NORTH 21ST STREET
CAMP HILL, PA 17011 by handing to
JENNIFER BINNER, ADMINISTRATION
a true and attested copy of WRIT OF SUMMONS together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 9.75
Affidavit .00
Surcharge 10.00
.00
37.75
Sworn and Subscribed to before
me/this~ day of
A.D.
J`
r thonotary
So Answers:
~~
R. Thomas Kline
07/11/2001
NAVITSKY OLSO~N ~W/~IS,N~ESKI
Deputy Sheriff
~'~"~~
SHERIFF'S RETURN - REGULAR
CASE NO: 2001-03972 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
TOWSEY DONALD
VS
RUDNICK HOWARD MD ET AL
CPL MICHAEL BARRICK Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within WRIT OF SUMMONS
HOLY SPIRIT HOSPITAL
was served upon
the
DEFENDANT at 0905:00 HOURS, on the 10th day of July 2001
at 503 NORTH 21ST STREET
CAMP HILL. PA 17011
by handing to
JENNIFER BINNER ADMINISTRATION
a true and attested copy of WRIT OF SUMMONS together with
and at the same time directing Her attention to the contents thereof.
Sheriffs Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
16.00
Sworn and Subscribed to before
me this ~,3,eaL day of
A.D.
r thonotary
So Answers:
~~~`~~
R. Thomas Kline
07/11/2001
NAVITSKY OLSON WISNESKI
~' Deputy heriff
CASE NO: 2001-03972 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
TOWSEY DONALD
VS
RUDNICK HOWARD MD ET AL
CPL MICHAEL BARRICK Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within WRIT OF SUMMONS was served upon
HOLY SPIRIT HOSPITAL OF THE SISTERS OF CHRISTIAN CHARITY the
DEFENDANT at 0905:00 HOURS, on the 10th day of July 2001
at 503 NORTH 21ST STREET
CAMP HILL, PA 17011
JENNIFER BINNER
by handing to
ADMINISTRATION
a true and attested copy of WRIT OF SUMMONS
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
16.00
Sworn and Subscribed to before
me th/is~ a23,wL day of
~~ ~ ~Zbij/ A.D.
P~rc t o~notary
So Answers:
.a~?~G,,~~/
R. Thomas Kline
07/11/2001
NAVITSKY OLSON WISNESKI
By:
Depu y riff
,.tea .
DONALD TOWSEY, as Administrator : IN THE COURT OF COMMON PLEAS OF
of the ESTATE OF MARK TOWSEY, :CUMBERLAND COUNTY, PENNSYLVANIA
Deceased, and Donald Towsey,
Individually and in his own right,
Plaintiff
v.
NO.O1-3972
HOWARD RUDNICK, M.D.,
HOLY SPIRIT HOSPITAL, and
HOLY SPIRIT HOSPITAL OF
THE SISTERS OF CHRISTIAN
CHARITY t/d/b/a HOLY SPIRIT
HOSPITAL,
Defendants :CIVIL ACTION -LAW
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
PLEASE enter our appearance on behalf of defendants, Howard Rudnick,
M.D., Holy Spirit Hospital and Holy Spirit Hospital of the Sisters of Christian Charity
t/d/b/a Holy Spirit Hospital.
METTE, EVANS & WOODSIDE
sy: ~ /Yw
teven D, Snyder, E uire
Sup. Ct. I.D. #34344
3401 North Front Street
P. O. Box 5950
Harrisburg, PA 17110-0950
(717)232-5000
Attorneys for Defendants
Date: July 30, 2001
CERTIFICATE OF SERVICE
I certify that I am this day serving a copy of the foregoing document upon the
person and in the manner indicated below, which service satisfies the requirements of
the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United
States Mail, Harrisburg, Pennsylvania, with first-class postage, prepaid, as follows:
David S. Wisneski, Esquire
Angino & Rovner, P.C.
4503 North Front Street
Harrisburg, PA 17110
METTE, EVANS & WOODSIDE
By:
Steven D. Snyder, Esq re
Sup. Ct. I. D. #34344
3401 North Front Street
P. O. Box 5950
Harrisburg, PA 17110-0950
(717)232-5000
Attorneys for Defendants,
DATE: July 30, 2001
:267532 l
,.,.~
DONALD TOWSEY, as Administrator : IN THE COURT OF COMMON PLEAS OF
of the ESTATE OF MARK TOWSEY, :CUMBERLAND COUNTY, PENNSYLVANIA
Deceased, and Donald Towsey,
Individually and in his own right,
Plaintiff
v.
NO.O1-3972
HOWARD RUDNICK, M.D.,
HOLY SPIRIT HOSPITAL, and
HOLY SPIRIT HOSPITAL OF
THE SISTERS OF CHRISTIAN
CHARITY t/d/b/a HOLY. SPIRIT
HOSPITAL,
Defendants :CIVIL ACTION -LAW
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 judgment of non pros.
METTE, EVANS & WOODSIDE
By:
Steven D. Snyder, Esqui
Sup. Ct. I. D. #34344
3401 North Front Street
P. O. Box 5950
Harrisburg, PA 17110-0950
(717)232-5000
Attorneys for Defendants
DATED: July 30, 2001
DONALD TOWSEY, as Administrator
of the ESTATE OF MARK TOWSEY,
Deceased, and Donald Towsey,
Individually and in his own right,
Plaintiff
v.
HOWARD RUDNICK, M.D.,
HOLY SPIRIT HOSPITAL, and
HOLY SPIRIT HOSPITAL OF
THE SISTERS OF CHRISTIAN
CHARITY t/d/b/a HOLY SPIRIT
HOSPITAL,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.O1-3972
CIVIL ACTION -LAW
RULE TO FILE A COMPLAINT
TO: Donald Towsey, as Administrator of the Estate of Mark
Towsey, Deceased, and Donald Towsey, Individually and in his own right
c/o David S. Wisneski, Esquire
Angino & Rovner, P.C.
4503 North Front Street
Harrisburg, PA 17110
You are hereby directed to file a complaint in the above entitled matter within
twenty (20) days of service hereof or judgment of non pros will be entered against
you.
Prothonotary
Acc.s~ /~ ~~ 1
~~.
s"-.• r ~.~er~• .a~n~c~ve4W.., . use "sw!*~s+~;A'P2Pawn5+~.i'~tia~Iti6~`
MICHAEL M. HADOWSKI, ESQUIRE
Pa. Supreme Court I.D. No. 32646
MARGOLIS EDELSTEIN
3510 Trindle Road
Camp Hill, Pennsylvania 17011
Telephone: [7177 975-8114 Attorney for Defendants:
Fax: [717] 975-6124 HOWARD RUDNICK, M.D.,
E-Mail: mbadowski®margolisedelstein.com HOLY SPIRIT HOSPITAL, AND
HOLY SPIRIT HOSPITAL OF THE SISTERS
OF CHRISTIAN CHARITY T/D/B/A
HOLY SPIRIT HOSPITAL
DONALD TOWSEY, AS ADMINISTRATOR
OF THE ESTATE OF MARK.TOWSEY,
DECEASED, AND DONALD TOWSEY,
INDIVIDUALLY AND IN HIS OWN
RIGHT,
PLAINTIFF,
VS.
HOWARD RUDNICK, M.D.,
HOLY SPIRIT HOSPITAL, AND
HOLY SPIRIT HOSPITAL OF THE
SISTERS OF CHRISTIAN CHARITY
T/D/B/A HOLY SPIRIT HOSPITAL,
DEFENDANTS.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
DOCKET NO. 01-3972
JURY TRIAL DEMANDED
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA:
Kindly enter my appearance on behalf of DEFENDANTS,
HOWARD RUDNICK, M.D., HOLY SPIRIT HOSPITAL, AND HOLY SPIRIT
HOSPITAL OF THE SISTERS OF CHRISTIAN CHARITY T/D/B/A HOLY SPIRIT
HOSPITAL, in the above-captioned matter.
Date : ~/~~~
MARGO ED STEI J /
By: lr -~!~
ICHAE M.:BADOWSKI
Attorney for Defendants
„ ,.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I served a true and correct copy
of the foregoing on all counsel of record by placing the same in
the United States mail at Camp Hill, Pennsylvania, first-class
postage prepaid, on the r ~ day of 2001, and
addressed as followsc
Michael J. Navitsky, Esquire
NAVITSKY, OLSON & WISNESKI LLP
2040 Linglestown Road, Suite 303
Harrisburg, PA 17110
(Counsel for Plaintiff)
MARGOLIS EDELSTEIN
S e ary
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4
DONALD TOWSEY, as Administrator : IN THE COURT OF COMMON PLEAS OF
of the ESTATE OF MARK TOWSEY, :CUMBERLAND COUNTY, PENNSYLVANIA
Deceased, and Donald Towsey,
Individually and in his own right,
Plaintiff
v.
NO.O1-3972
HOWARD RUDNICK, M.D.,
HOLY SPIRIT HOSPITAL, and
HOLY SPIRIT HOSPITAL OF
THE SISTERS OF CHRISTIAN
CHARITY t/d/b/a HOLY SPIRIT
HOSPITAL,
Defendants :CIVIL ACTION -LAW
WITHDRAWAL OF APPEARANCE
TO THE PROTHONOTARY:
PLEASE withdraw our appearance on behalf of defendants, Howard Rudnick,
M.D., Holy Spirit Hospital and Holy Spirit Hospital of the Sisters of Christian Charity
t/d/b/a Holy Spirit Hospital, in the above captioned action.
METTE, EVANS & WOODSIDE
By: J
Steven D. Snyder, quire
Sup. Ct. I.D. #34344
3401 North Front Street
P. O. Box 5950
Harrisburg, PA 17110-0950
(717)232-5000
Date: August 8, 2001
CERTIFICATE OF SERVICE
I certify that I am this day serving a copy of the foregoing document upon the
persons and in the manner indicated below, which service satisfies the requirements of
the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United
States Mail, Harrisburg, Pennsylvania, with first-class postage, prepaid, as follows:
David S. Wisneslu, Esquire
Angino & Rovner, P.C.
4503 North Front Street
Harrisburg, PA 17110
Michael M. Badowslu, Esquire
Margolis Edelstein
P. O. Box 932
Harrisburg, PA 17108-0932
METTE, EVANS & WOODSIDE
By:
Steven D. Snyder, Es wire
Sup. Ct. I. D. #34344
3401 North Front Street
P. O. Box 5950
Harrisburg, PA 17110-0950
(717)232-5000
DATE: August S, 2001
:267532 1
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DONALD TOWSEY, AS ADMINISTRATOR
OF THE ESTATE OF MARK TOWSEY,
DECEASED, AND DONALD TOWSEY,
INDIVIDUALLY AND IN HIS OWN
RIGHT,
PLAINTIFF,
VS.
HOWARD RUDNICK, M.D.,
HOLY SPIRIT HOSPITAL, AND
HOLY SPIRIT HOSPITAL OF THE
SISTERS OF CHRISTIAN CHARITY
T/D/B/A HOLY SPIRIT HOSPITAL,
DEFENDANTS.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
." DOCKET NO. 01-3972
JURY TRIAL DEMANDED
PRAECIPE TO MARK CASE SETTLED,
DISCONTINUED AND ENDED
TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA:
Kindly mark the above-captioned matter, settled,
discontinued and ended with prejudice.
NAVITSKY, OLSON & WISNESKI, LLP
Date: ~S-3a-b J By,
David S. Wi neski, Esquir
2040 Linglestown Road, Suite 303
Harrisburg, PA 17110
Attorneys for Plaintiff
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