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Home My WebLink About01-03973IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 3 9 f3 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 CIVIL ACTION -LAW JURY TRIAL DEMANDED KENNETH CONIVER, M.D. 207 House Avenue Camp Hill, PA 17011 JAMES KEARNEY, M.D. 207 House Avenue Camp Hill, PA 17011 JAMES RICH, M.D. 207 House Avenue Camp Hill, PA 17011 JOSEPH TORCHIA, M.D. 207 House Avenue Camp Hill, PA 17011 CONKER, RICH ASSOCIATES 207 House Avenue Camp Hill, PA 17011 HERITAGE MEDICAL GROUP, LLP t/d/b/a CONKER, RICH ASSOCIATES 1007 Mumma Drive Wormleysburg, PA 17043 CONNER, RICH, KEARNEY, TORCHIA ASSOCIATES 207 House Avenue 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 OAttorney Dated: June 26, 2001 David Wisneski, Esquire Navitsky, Olson & Wisneski LLP 2040 Linglestown Road, Suite 303 Harrisburg, PA 17110 717/541-9205 Counsel for Plaintiffs I.D. No. 58796 ~_ :~ i -~; - c`~ ;~3 ~£- *.~ :\, .'> _ r r; ,. .. _ _.. ., _ ~~~ r a~sa A~ -, ~, i~i;e-~s 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 NO. 01 -3g ~3 CIVIL ACTION -LAW JURY TRIAL DEMANDED KENNETH CONKER, M.D. 207 House Avenue Camp Hill, PA 17011 JAMES KEARNEY, M.D. 207 House Avenue Camp Hill, PA 17011 JAMES RICH, M.D. 207 House Avenue Camp Hill, PA 17011 JOSEPH TORCHIA, M.D. 207 House Avenue Camp Hill, PA 17011 CONKER, RICH ASSOCIATES 207 House Avenue Camp Hill, PA 17011 HERITAGE MEDICAL GROUP, LLP t/d/b/a CONKER, RICH ASSOCIATES 1007 Mumma Drive Wormleysburg, PA 17043 a Y Plaintiffs & Address Versus Defendants & Addresses WRIT OF SUMMONS TO THE ABOVE-NAMED DEFENDANTS: YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAIN'T'IFF HAS COMMENCED AN ACTION AGAINST YOU. /s/ ~.~,vrfsD ~ia~ma Prothonotary Dated: ~~^~- ~, awl CONNER, RICH, KEARNEY, TORCHIA ASSOCIATES 207 House Avenue Camp Hill, PA 17011 by i~°~-cC~ ~_,1~~~,~%~ i~~ epu ~. , _ ~_ ~{- ~ ~~ ~ ^ `lye ~ "~ i ' V` +~ ~ _ w ~~ ~ C r ~~ ~ D ~ ~~ ~ } v. ~~ ~&~r':~"~~~u~uc a--re=;=,~~. ~ ,s~.~i~4a+~eiE'%~n,:3`a~<a'hat±~tiE~T~~ rc~,ti~lelwR ~a~:°~lr-fir.-,:. ~s;;.: CASE NO: 2001-03973 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TOWSEY DONALD ET AL VS CONNER KENNETH 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 CONNER KENNETH MD the DEFENDANT at 0915:00 HOURS, on the 10th day of July 2001 at 207 HOUSE AVENUE CAMP HILL, PA 17011 by handing to LENORA SANDRIDGE ACCOUNTS MANAGER 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 .23„r,~ day of 1 oZtrv A.D. Q .~ othonotary ' So Answers: R. Thomas Kline 07/11/2001 NAVITSKY OLSON WISNESKI By. ~~~~y~/~ ' Deputy here SHERIFF'S RETURN - REGULAR CASE NO: 2001-03973 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TOWSEY DONALD ET AL VS CONNER KENNETH 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 KEARNEY JAMES MD was served upon DEFENDANT the at 0915:00 HOURS, on the 10th day of July 2001 at 207 HOUSE AVENUE CAMP HILL, PA 17011 by handing to LENORA SANDRIDGE ACCOUNTS MANAGER 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 So Answers: Service .00 ,GS*~~-*~°^~ '°~ Affidavit .00 Surcharge 10.00 R. Thomas Kline nn 16.00 07/11/2001 NAVITSKY OLSON & WISNESKI Sworn and Subscribed to before By: me this d~ day of Deputy S eriff ~t547 ~ -y A . D . P o onotary .,~,~~~. CASE NO: 2001-03973 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TOWSEY DONALD ET AL VS CONNER KENNETH 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 RICH JAMES MD was served upon DEFENDANT the at 0915:00 HOURS, on the 10th day of July 2001 at 207 HOUSE AVENUE CAMP HILL, PA 17011 by handing to LENORA SANDRIDGE ACCOUNTS MANAGER 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 this d3.tio1 day of oZe / A.D. r thonotary ' So Answers: ~, y~-s~.C ~i~ R. Thomas Kline%% 07/11/2001 NAVITSKY OLSON & WISNESKI ~D~ eriff SHERIFF'S RETURN - REGULAR CASE NO: 2001-03973 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TOWSEY DONALD ET AL VS CONNER KENNETH MD ET CPL MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS TORCHIA JOSEPH MD was served upon DEFENDANT the at 0915:00 HOURS, on the 10th day of July 2001 at 207 HOUE AVENUE CAMP HILL, PA 17011 by handing to LENORA SANDRIDGE ACCOUNTS MANAGER 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 t/~h~i s ~ 3,rcC day o f ~fif.i'~ o2Cr~/ A.D. ~1/~~ ~ t ro-thonotar~ So Answers: R. Thomas Kline 07/11/2001 NAVITSKY OLSON & WISNESKI By. Deputy Sh iff SHERIFF'S RETURN - REGULAR CASE NO: 2001-03973 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TOWSEY DONALD ET AL VS CONNER KENNETH 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 CONNER RICH ASSOCIATES the DEFENDANT at 0915:00 HOURS, on the 10th day of July 2001 at 207 HOUSE AVENUE CAMP HILL. PA 17011 LENORA SANDRIDGE a true and attested copy of WRIT OF SUMMONS by handing to ACCOUNTS MANAGER 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 t//h~~is .13,~..~ day of ~h../,_ o2ov/ A.D. i i r thonotary '07"~ So Answers: ~~~ R. Thomas Kline By: _ Deput S eriff 07/11/2001 NAVITSKY OLSON & WISNESKT SHERIFF'S RETURN - REGULAR CASE NO: 2001-03973 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TOWSEY DONALD ET AL VS CONNER KENNETH 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 HERITAGE MEDICAL GROUP LLP was served upon the DEFENDANT at 0921:00 HOURS, on the 10th day of July 2001 at 1007 MUMMA DRIVE WORMLEYSBURG, PA 17043 JOHN K REIGHTOR, CEO by handing to a true and attested copy of WRIT OF SUMMONS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service 9.75 Affidavit .00 Surcharge 10.00 .00 25.75 Sworn and Subscribed to before me this o23,cd day of A.D. othonotary So Answers: ~~'~ R. Thomas Kline 07/11/2001 NAVITSKY OLSON & WISNESKI By. Deputy eriff SHERIFF'S RETURN - REGULAR CASE NO: 2001-03973 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TOWSEY DONALD ET AL VS CONNER KENNETH 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 CONNER RICH KEARNEY TORCHIA ASSOCIATES the DEFENDANT at 0915:00 HOURS, on the 10th day of July 2001 at 207 HOUSE AVE CAMP HILL, PA 17011 by handing to LENORA SANDRIDGE ACCOUNTS MANAGER 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 this .23,,,/ day of ~t,.~+~a~o ~ A . D . ~~ ~iLiOOo -7~7 Pr t onotary So Answers: ~~s~ R. Thomas Kline 07/11/2001 NAVITSKY OLSON & WISNESKI By: Deputy Sheriff DONALD TOWSEY, As Administrator of the Estate of Mark Towsey, Deceased, and Donald Towsey, Individually and in his own right, Plaintiff v. NO. 01-3973 IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA CIVIL ACTION -LAW KENNETH CONNER, M.D., JAMES KEARNEY, M.D., JAMES RICH, M.D., JOSEPH TORCHIA, M.D., CONNER, RICH ASSOCIATES, HERITAGE MEDICAL GROUP, LLP t/d/b/a CONNER, RICH ASSOCIATES and CONNER, RICH, KEARNEY, TORCHIA ASSOCIATES, Defendants JURY TRIAL DEMANDED PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please discontinue the above-captioned action as to all Defendants. Respectfully submitted, NAVITSKY, OLSON & WISNESKI LLP David S. Wisneski, Esquire I.D. No. 58796 2040 Linglestown Road, Suite 303 Harrisburg, PA 17110 717/541-9205 Counsel for Plaintiff Date: September 10, 2001 ,. - , - t CERTIFICATE OF SERVICE I, Lois E. Stauffer, an employee of the law fum of Navitsky, Olson & Wisneski LLP hereby certify that a true and correct copy of the foregoing PRAECIPE TO DISCONTINUE was served upon the followingpersons by first-class United States mail, postage prepaid on September 10, 2001 as follows: Kenneth Connor, M.D. 207 House Avenue Camp Hill, PA 17011 James Kearney, M.D. 207 House Avenue Camp Hill, PA 17011 James Rich, M.D. 207 House Avenue Camp Hill, PA 17011 Joseph Torchia, M.D. 207 House Avenue Camp Hill, PA 17011 Conner, Rich Associates 207 House Avenue Camp Hill, PA 17011 Heritage Medical Group, LLP t/d/b/a Conner, Rich Associates 1007 Mumma Drive Wormleysburg, PA 17043 Conner, Rich, Kearney, Torchia Associates 207 House Avenue Camp Hill, PA 17011 Lois E. Stauffer I 'S c7 c.. - -,. -' v c ;n -n -_ ,, - ,, ~.. ~ - ~r.4 w_ ~ ' . ~' __ 'C~ , 9~; 7 .~ ~ .vi •~ ~