Loading...
HomeMy WebLinkAbout01-03993KEVIN KENDIG and NANCY KENDIG, Plaintiffs v. CHRISTY SCHALE and EDMUND SCHALE, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. d/- 3993 ~;,~( ~~,.. CIVIL ACTION -LAW JURY TRIAL DEMANDED PRAECIPE FOR WRITS OF SUMMONS TO THE PROTHONOTARY: Kindly issue Writs of Summons against Defendants Christy Schale and Edmund Schale. The Writs of Summons should be delivered to the Sheriff for service upon Defendants Christy Schale and Edmund Schale. Respectfully submitted by, METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By ~ C~~O Melissa L. Stickel, Esquire Attorney ID No. 85869 3211 N. Front Street P.O. Box 5300 Harrisburg, PA 17110 (717)238-8187 Attorneys for Plaintiffs Date: (p/~~/Q~ Document #: 209598.1 KEVIN KENDIG and NANCY KENDIG, Plaintiffs v. CHRISTY SCHALE and EDMUND SCHALE, Defendants TO: Christy Schale 262 Walnut Street Shippensburg, PA 17257 -and- Edmund Schale 262 Walnut Street Shippensburg, PA 17257 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. C~/- 3 95'3 C'un=P "7~~ CIVIL ACTION -LAW JURY TRIAL DEMANDED WRITS OF SUMMONS You are hereby notified that Plaintiffs have commenced an action against you. Prothonotary Dated: ,,~ 2 '~ ~i / Document #.~ 209597.7 i) ~- -- , r T(` ` rnr - j ~ ~. r - !' (_ ,:., ~, "` C.`. .. :~ t ~; =' _~ ~' W ~' ~ ~ "' U~ c a' ~~ .- KEVIN KENDIG and : IN THE COURT OF COMMON PLEAS NANCY KENDIG, :CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFFS v. NO.OI-3993 CIVIL TERM CIVIL ACTION - AT LAW CHRISTY SCHALE and EDMUND SCHALE, DEFENDANTS :JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please issue a Rule upon the Plaintiff to file a Complaint within twenty (20) days or suffer a judgment. of non pros. Date: 07/17/01 TO THE PLAINTIFF: Respectfully submitted, NEALON & GOVER, P.C. By: Chnstop J. Knight, Esquire Atty. I. 80058 2411 North Front Street Harrisburg, PA 17110 (717)232-9900 RULE A Rule is hereby issued upon you to file a Complaint within twenty (20) days of service of this Rule or suffer a judgment of non pros. DATED: ~ ~•n~- a r .V . KEVIN KENDIG and NANCY KENDIG, v. PLAINTIFFS CHRISTY SCHALE and EDMUND SCHALE, DEFENDANTS TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.O1-3993 CIVIL TERM CIVIL ACTION - AT LAW JilRY TRIAL DEMANDED PRAECIPE Please enter the undersigned's appearance on behalf of the Defendants, Christy Schale and Edmund Schale, with regard to the above-captioned matter. Respectfully submitted, NEALON & GOVER, P.C. Christo er .Knight, Esquire Atty. LD. #80058 2411 North Front Street Harrisburg, PA 17110 Date: 07/17/01 (717) 232-9900 CERTIFICATE OF SERVICE AND NOW, this 17th day of July, 2001, I hereby certify that I have served the foregoing Praecipe on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Melissa L. Stickel, Esquire METZGER, WICKERSHAM, KNAUSS & ERB, P.C. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110 SHERIFF'S RETURN - REGULAR .. CASE NO: 2001-03993 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND KENDIG KEVIN ET AL VS SCHALE CHRISTY ET AL DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon SCHALE CHRISTY the DEFENDANT at 1638:00 HOURS, on the 6th day of July 2001 at 262 WALNUT ST SHIPPENSBURG, PA 17257 EDMUND SCHALE 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 18.00 Service 13.65 Affidavit .00 Surcharge 10.00 .00 41.65 Sworn and Subscribed to before me this 23,u~ day of ~, ~Zvu/ A.D. /~fit.~. Ci /DtcYL~i,~10 Ferro honotary T J So Answers: ~~~ R. Thomas Kline 07/09/2001 METZGER WICKERSHAM By. L Dep y h riff .`. CASE NO: 2001-03993 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND KENDIG KEVIN ET AL VS SCHALE CHRISTY ET AL DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon SCHALE EDMUND the DEFENDANT at 1638:00 HOURS, on the 6th day of July 2001 at 262 WALNUT ST SHIPPENSBURG. PA 17257 EDMUND SCHALE a true and attested copy of WRIT OF SUMMONS by handing to together with and at the same time directing His 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 ~3,L,~ day of app A.D. ~. AO ~~ P o~Yiotary '~ So Answers: ~~~~~ R. Thomas Kline 07/09/2001 METZGER WICKERSHAM By: ~~~~~ ,,.,,rte Dei ty Sheriff KEVIN KENDIG and NANCY KENDIG, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3993 CIVIL TERM v. CHRISTY SCHALE and EDMUND SCHALE, Defendants CIVIL ACTION -LAW JURY TRIAL DEMANDED NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written 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, PA 17013 (800) 990-9108 METZGER, WICKERSHAM, KNAUgS/S & ERB, P.C. Melissa L. Van Eck, Esquire Attorney I.D. 85869 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiff Document #: 215565.7 KEVIN KENDIG and IN THE COURT OF COMMON PLEAS OF NANCY KENDIG, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs NO. 01-3993 CIVIL. TERM vi. CIVIL ACTION -LAW CHRISTY SCHALE and EDMUND SCHALE, Defendants JURY TRIAL DEMANDED CmMPLAINT 1. Plaintiffs Kevin and Nancy Kendig, husband and wife, are adult individuals residing at 74 Kline Road, Shippensburg, Cumberland County, Pennsylvania 17257. 2. Defendant Edmund Schale, is an adult individual residing at 262 Walnut Street Shippensburg, Cumberland County, Pennsylvania 17257. 3. Defendant Christy Schale, is an adult individual residing at 262 Walnut Street, Shippensburg, Cumberland County, Pennsylvania 17257. 4. On June 27, 1999, Plaintiff Kevin Kendig was the operator of a 1987 Chevrolet truck with Pennsylvania Registration Plate No. ZN67229 which was pulling a John Deere hay bailer. 5. On the aforesaid date at approximately 2:05 p.m., Defendant Christy Schale was driving a 1985 Chevrolet Caprice with Pennsylvania Registration Plate No. BAW 1156. 6. On the aforesaid date and time, Plaintiff Kevin Kendig's vehicle was traveling North on Route 11 in Shippensburg, Cumberland County, Pennsylvania. 7. On the aforesaid time and date Defendant crossed the double yellow line striking the Plaintiff s vehicle. Document #: 215565.! ..,.mn.. .. _. 8. The collision occurred solely as the result of the negligence, carelessness and recklessness of the Defendant and was due in no matter to any act, failure to react, on the part of the Plaintiff. 9. Defendant owed a duty to the other lawful users of the roadway in the Commonwealth of Pennsylvania to operate her vehicle in such a way as not to cause harm or damage to said other persons and to the Plaintiffs in particular. 10. The negligence, carelessness and recklessness of the Defendant constitute the following: (a) Failing to operate her vehicle on the right side of the roadway in violation of 42 Pa.C.S.A. § 3301; (b) Operating her vehicle in careless disregard for the safety of persons and/or property in violation of 75 Pa.C.S.A. § 3714; (c) Failing to keep her vehicle under proper and adequate control so as to not expose other users to an unreasonable risk of harm; (d) Operating her vehicle too fast for the conditions existing at the aforesaid time and place in violation of 75 Pa.C.S.A. § 3361; (e) Failing to keep alert and maintain proper lookout for the presence of the motor vehicles on the streets and highways; (f) Exceeding the applicable maximum speed limit in violation of 75 Pa.C.S.A. § 3362; and (g) Otherwise operating her vehicle in an unsafe manner. Document #: 215565.! 11. As a direct and proximate result of the collision and negligent, careless and recklessness of Defendants, Plaintiff suffered personal injuries and damages as more fully set forth herein. COUNT I Plaintiff Kevin Kendig v. Defendant Christy Schale 12. Paragraphs 1 through 11 are incorporated herein by reference as if set forth more fully set forth. 13. As a direct and proximate result of the collision and the negligence, carelessness and recklessness of Defendants, Plaintiff Kevin Kendig sustained and in the future may sustain, serious and debilitating injuries, some of which are or may be permanent, an aggravation and/or exacerbation, and which include but are not limited to the following: (a) Trauma and injury to his right shoulder; (b) Trauma and injury to his neck; (c) Trauma and injury to his right arm; (d) Psychological trauma; and (e) Other painful and debilitating injuries. 14. As a direct and proximate result of the aforesaid collision, negligence, carelessness and recklessness of Defendants, Plaintiff Kevin Kendig was forced to incur medical bills and expenses for the injuries he has suffered and will continue to incur medical expenses in the future. Document #: 215565.1 15. As a direct and proximate result of the aforesaid collision, negligence, carelessness and recklessness of Defendants, Plaintiff Kevin Kendig has suffered and will suffer a sever loss of earnings, permanent disability, impairment and/or loss of earning capacity, loss of incentive bonuses, loss of stock options, loss of fringe benefits, loss of household services and similar economic losses. 16. As a direct and proximate result of the aforesaid collision, negligence, carelessness and recklessness of Defendants, Plaintiff Kevin Kendig, has undergone and, in the future, will undergo great physical pain, mental pain, discomfort, inconvenience, distress, embarrassment, humiliation, loss of life's pleasures, all to his great detriment and loss. WHEREFORE, Plaintiff Kevin Kendig demands judgment in his favor and against the Defendants for the aforesaid damages which exceeds the limits for compulsory arbitration in Cumberland County, Pennsylvania, and demands costs, interest and/or damages for delay against Defendants as allowed by law. COUNT II Plaintiff Nancv Kendig v. Defendant Christy Schale 17. Paragraphs 1 through 16 are incorporated herein by reference as if set forth more fully set forth. 18. During all relevant times Plaintiffs Kevin and Nancy Kendig, were husband and wife and solely as a result of the collision, the aforesaid negligence, carelessness and recklessness of Defendant and as a result of the injuries to Plaintiff Kevin Kendig, the Plaintiff Nancy Kendig has been deprived of the assistance, companionship, consortium and society of Document #: 215565.1 • gym- _ .. _ .. - ,_ __ ~ - her husband and has lost his services to her all to her great loss and detriment which may continue indefmitely. WHEREFORE, Plaintiff Nancy Kendig demands judgment in her favor and against the Defendants for the aforesaid damages, which exceed the limits for compulsory arbitration in Cumberland County, Pennsylvania and demand costs, interest and/or damages for delays against Defendants as allowed by law. COi1NT III Plaintiffs. Kevin Kendig and Nancy Kendie v. Defendant Edmund Schale 19. Paragraphs 1 through 18 hereof are incorporated herein by reference as if fully set forth. 20. At the aforesaid time and place, Defendant, Edmund Schale, had entrusted and permitted Defendant, Christy Schale, to operate his motor vehicle when he knew or should have known that Defendant, Christy Schale, was incompetent to operate said motor vehicle. 21. The accident was caused directly, proximately, and/or substantially by the negligence, carelessness, and recklessness of Defendant, Edmund Schale, in the following particulars: (a) permitting Defendant, Christy Schale, to operate his vehicle when he had actual and/or constructive knowledge that Defendant, Christy Schale, was not a safe and competent driver; Document #: 215565.1 _.,,. (b) allowing Defendant, Christy Schale, to operate his motor vehicle in a busy and congested area when he knew or should have known that Defendant, Christy Schale, was not competent; (c) failing to properly supervise Defendant, Christy Schale, when she was operating his motor vehicle; (d) failing to properly investigate Defendant, Christy Schale's, ability to drive his vehicle; and (e) failing to take precautions to prevent Defendant, Christy Schale, from operating his motor vehicle. 22. The negligent acts of Defendant, Christy Schale, are imputable to Defendant, Edmund Schale, for his negligent entrustment of the motor vehicle to Defendant, Christy Schale. 23. As a direct and proximate result of the aforesaid negligence, recklessness, and carelessness, Defendant, Edmund Schale, is liable for the above mentioned damages and claim is made therefor. WHEREFORE, Plaintiffs Kevin Kendig and Nancy Kendig demand judgment in their favor and against the Defendants for the aforesaid damages which exceeds the limits for Document #: 2!5565.1 compulsory arbitration in Cumberland County, Pennsylvania, and demands costs, interest and/ar damages for delay against Defendants as allowed by law. METZGER, WICKERSHAM, KNAUSS & ERB By: ~ ~.fJ~~ ~le~~~~-~, k1'l ~ ~~`• ~I~~I°~ Melissa L. VanEck;'Esquire Attorney I.D. No. 85869 3211 North Front Street . P.O. Box 5300 Harrisburg, PA 17110-0300 (717)238-8187 Attorneys for Plaintiffs Document #: 275565.7 I, Kevin Kendig, verify the statements made in the foregoing Complaint are true and correct- I understand false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. evin Kendig Date: ~ ~ Document #: 215565.1 VERIFICATION I, Nancy Kendig, verify the statements made in the foregoing Complaint are true and correct. I understand false statements herein aze made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: ) 0 Document #: 215565.1 Nancy Kendig KEVIN KENDIG and IN THE COURT OF COMMON PLEAS OF NANCY KENDIG, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs NO. 01-3993 CIVIL TERM v. CIVIL ACTION -LAW CHRISTY SCHALE and EDMUND SCHALE, Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this L~ day of September, 2001, Melissa L. Van Eck, Esquire, of Metzger, Wickersham, Knauss & Erb, P.C., attorneys for Plaintiff, hereby certify that I served a copy of the within Complaint this day by depositing the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Christy Schale Edmund Schale c/o Christopher J. Knight, Esquire Nealon & Gover 2411 North Front Street Harrisburg, PA 17110 ~~m ~'~ Melissa L. Van Eck Document #: 275565.1 ~-) t'~~ C= '_ -t „~ , ~ -r __ ' _ _ --i __ r_ ~C-; .~.._ -'C. .. _~ ~ 'S`- . ~; .r ~I ~m _'. RAhv,~*v~.•, r--=.~ ••~e ~:~•u; -..s~~~~fscAV S+,pspESkF~Prk *H "'Ur!e~~ Y =asna,~;~~q.T '~ KEVIN KENDIG and NANCY KENDIG, PLAINTIFFS v. CHRISTY SCHALE and EDMUND SCHALE, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3993 CIVIL TERM CIVIL ACTION - AT LAW JURY TRIAL DEMANDED ANSWER AND NOW, comes the Defendants, Christy Schale and Edmund Schale, by and through their attorneys, Nealon & Gover, P.C., and in response to Plaintiffs' Complaint, aver the following: 1. Admitted, upon information and belief. 2.-3. Admitted. 4. Admitted, upon information and belief. 5.-6. Admitted. 7. Admitted in part and denied in part. It is admitted that at the foresaid time and date Defendant Christy Schale's vehicle came in contact with the Plaintiffs vehicle. The remaining averments contained in this paragraph are denied as stated pursuant to Pa.R.C.P. 1029(e). 8.-9. The averments contained in these paragraphs state only conclusions of law to which no response is required. To the extent that the averments are deemed factual and requiring of a response, they are denied pursuant to Pa.R.C.P. 1029(e). 10. Denied as stated pursuant to 1029(e). 11. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph. Strict proof of same is demanded at trial. COUNTI Plaintiff Kevin Kendig v. Defendant Christy Schale 12. Paragraphs 1 through 11 above are incorporated herein by reference as if fully set forth at length. 13.-16. After reasonable investigation, Defendant Christy Schale is without knowledge or information sufficient to form a belief as to the truth of the averments contained in these paragraphs. Strict proof of same is demanded at trial. WHEREFORE, Defendant Christy Schale respecffully requests that this Honorable Court enter judgment in her favor and against Plaintiff, Kevin Kendig. COUNT II Plaintiff Nancy Kendig v. Defendant Christy Schale 17. Paragraphs 1 through 16 above are incorporated herein by reference as if fully set forth at length. 18. After reasonable investigation, Defendant Christy Schale is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph. Strict proof of same is demanded at trial. WHEREFORE, Defendant Christy Schale respectfully requests that this Honorable Court enter judgment in her favor and against Plaintiff, Nancy Kendig. COUNT III Plaintiffs. Kevin Kendig and Nancy Kendig v. Defendant Edmund Schale 19. Paragraphs 1 through 18 above are incorporated herein by reference as if fully set forth at length. 20.-21. Denied pursuant to Pa.R.C.P. 1029(e). 22.-23. The averments contained in these paragraphs state only conclusions of law to which no response is required. To the extent that they may be deemed factual and requiring of a response, they are denied pursuant to Pa.R.C.P. 1029(e). WHEREFORE, Defendant Edmund Schale respectfully requests that this Honorable Court enter judgment in his favor and against Plaintiffs. Respectfully submitted, NEALON & GOVER, P.C. By: Christopher '. fight, Esquire Attorney I.D. No. 80058 2411 North Front Street ~ ~ Harrisburg, PA 17110 Date: '~ (717) 232-9900 VERIFICATION I, Edmund Schale, verify that the statements made in the foregoing Answer are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: l -Z4 -aool ~~~M.(,c~n.~~l c~~~~ Edmund Schale VERIFICATION I, Christy Schale, verify that the statements made in the foregoing Answer are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: 9/~/ ~~ .az:d Christy S ale CERTIFICi4TE OF SERVICE AND NOW, this 4th day of October, 2001, 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 mail, postage prepaid, addressed to: Melissa L. Van Eck, Esquire Metzger Wickersham 3211 North Front Street Harrisburg, PA 17110-0300 Christop r J. Knight, Esquire CERTIFICATB - ~ PREREQUISITE TO SERVICH dF A SIIBPOENA PURSUANT TO RIILE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KEVIN KENDIG TERM, -VS- CASE N0: 01-3993 SCHALE 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: 02/13/2002 CS oq beha~ H r ~-~~~RE r~~~r HRISTOPHE J. RNIG T, ESQUI Attorney for DEFENDANT DE11-310024 8 3 0 3 9- L 0 1 C OMD~iO NWEAL TH O F PENN S YLVAN=A = COUNTY OF CLT1GiBERLAND IN THE MATTEA OF: COURT OF COt~Il~fON PLEAS KEVIN RENDIG TERM, -VS- CASE N0: 01-3993 SCHALE [ Note: see enclosed list of locations. T0: M6[.ISSA L. VAN ECH, BSQ. MCS on behalf of CHAISTOPHEE J. &NIGHT, BSQDIRE intends to serve a subpoena.- identical to the one that is attached to this notice. icon have tmeatg (20) days frog the date listed below in which to file of record-and serve upon they 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 ezpense by cc®pleting the attached counsel card and retnraing same to MCS or by contacting our local MCS office. DATB: 01/24/2002 MCS on behalf of oQ CC: CBRISTOPBBB J. KNIGHT, BSQIIIRB- 01-301 Any questions regarding. this matter, contact CHAISTOPHSB J. KNIGHT, ESQDIBH Attorney for DEFBNDANT THB MCS GAODP INC. 1601 MABHHT STBBBS #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-176375 8 3 0 3 9- C 0 1 »> LOCATION LIST «< PAGE: 1 RECORDS REQDESTBD LOCATION NAME 2~DICAL !IIO)ICAL l03DICAL TQ+DICAL MEDICAL MEDICAL l~DICAL MEDICAL MBDICAL CLI TBANSPOHT LLP = 3 PENHSYLVANLA COOHSffi.IHG SVS. VALLEY 2~DICAL CENTER CARLISLE HOSPITAL CHAMBHHSBDHG HOSPITAL APPALACHIAN ORTHOPEDIC CENTER DAVID BAHTZHL, K.D. CHAMBSRSBDHG HOSPITAL SHIPPENBDHG HEALTH SSHVICBS ' DE02-176375 8 3 0 3 9- C 0 1 CsJ .1`AOTV'WEALTH OF PENti'SYLVANIA COUNTY OF CUMBERL4.\'D KEVIN KENDIG - VS SCHALE ~ File \o. 01-3993 SUBPOENA TO PROD[JCE DOCU1dE\ i 5 OR THINGS FOR DISCOVERY PURSU,3\T TO RULE 4009?' T!~; CUSTODIAN OF RECORDS FOR:CLI TRANSPORT LLP (tiamr of Peaen ar ~rq 'n'i:5ia nYe.-r (.7) days afar. sercica of this subpoena, you ue ordertd br elte rntss to produca toe foiicwing ~ocunenn or ;hinzx CF.T? ATTAf HRT1 at MCS GROUP INC., 1601 MARKET ST., 11800, PHILA.,PA 19103 IAdde~ael Yov e:av dein•es m mail iegible copies of the docutnenn or produes ti3nr~s raebested by this subpoena, together with the certificate of rompiiance, ro the parry making this request a the add.~st listed. alsavc You bare the rig:t: to seek, in adranca. the aasonabie cost of preparing the copin ar produdng the L''sing7 mousht. If you .cai1 to -oduce the doraments ar things required by this subpoena, will'Srs twenty ('~) days aver its sen•ice. the patty sen•ins ::.is subpoena may seek a court order eampoling you to coatplr with G T-r.IS SL3'rOE':VA WAS ISSUED AT T'.zE REQLL;T OFTr:E FsOLLOWING PERSO\: NAME: CHRISTOPHER J. KNIGHT. ES ADDt?<;= 2411 NORTH FRONT ST. HARRISBURG, PA 17110 TcZE.a:iON~ 215-246-n9nn S~PC_1{= CL?L~ ID 1: ATTDR\~ FOIh DEFENDANT DAi_~ ~ 1 ,t ~~~{~-e ~dba Seal of the Cato: EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CLI TRANSPORT LLP PENN PROFESSIONAL CENTER 3370 LYNNWOOD DRIVE ALTOONA, PA 16602 RE: 83039 KEVIN KENDIG 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 :KEVIN KENDIG 74 KLINE ROAD, SHIPPENSBURG, PA 17257 Social Security l~: 211-54-8834 Date of Birth: 02-07-1962 SU10-351808 8 3 0 3 9- L 0 1 CERTIFICATE - a ` PREREQUISITE TO SERVICE OF A SUBPOENA PIIRSIIANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KEVIN RENDIG TERM, -VS- CASE N0: 01-3993 SCHALE 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: 02/13/2002 CHRISTOPHER J. KNIGHT, ESQUIRE Attorney for DEFENDANT DE11-310025 8 3 0 3 9- L 0 2 COMNIONWEALTE3 OF PENNSYLVANSA = COUNTY OF CLiIZI73ERLAND IN THE MATTER OF: COURT OF COMMON PLEAS KEVIN RENDIG TERM, -VS- CASE N0: 01-3993 SCHALE { Note: see enclosed list of locations ] T0: MBLI$SA L. VAN BCg, BSQ. MCS oa behalf of CHBISTOPBBB J. ENYGH?, ESQUIBB intends to serve a snbpoeaa. _ 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 that ~underaigued an objection to the subpoena. If the twentg day notice period is ; waived or if ao objection is made, then the subpoena may be served. Complete-. copies of any reproduced records may be ordered at your ezpease by completing the. attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/24/2002 , CC: CHRISTOPHBH J. KNIGHT, BSQIIIBE= 01-301 Any questions regarding this matter, contact P~CS oa behalf of CHRISTOPHHB J. KNIGHT, ESQIIIRB Attorney for DBPBNDANT THE MCS GR011P INC. 1601 MABKBT STREET 4800 PHILADBLPHIA, PA 19103 (215) 246-0900 DE02-176575 8 3 0 3 9- C 0 1 »> LOCATION LIST «< PAGE. 1 RECORDS REQIIBSTSD LOCATION NAlHi MEDICAL MEDICAL lDiDICAL !lBDICAL MBDICAL MBDICAL MEDICAL MEDICAL MEDICAL CLI TRANSPORT LLP ~' PENNSYLVANIA CODNSELING S4S. VALLEY MBDICAL CENTER CABLISLH HOSYZTAL CHAMBSBSBDRG HOSPITAL ApPpr.sepTex.ORTHOPEDIC CffiiTBR DAVID HART2EL, K.D. CHAMBEBSBDRG HOSPITAi. SHIPPHNBDBC HHALTH SERVICBS DE02-176375 8 3 0 3 9- C 0 1 COMMONWEALTH OF PEN.\'SYLVANIA COUNTY OF CUMBERL4.\'D KEVIN KENDIG VS SCHALE <ile \o. 01-3993 SUBPOENA TO PRODUCE DOCL~IE\TS OR T'r:I\GS FOR DISCOVERY PURSU?~\T TO RULE 4009?' T7; CUSTODIAN OF RECORDS FOR: PENNSYLVANIA COUSELING SERVICES 11ame of Prnan er err) `n'i:iin twe.-r (~) days ai:er se~icr of this subpoena. you are ordesrd by efts Hurt to ptoduex toe rciiawing dac~ateras or ;hingx RF.F. ATTAt'HF.D at MCS GROUP INC., 1601 MARKET ST., 41800, PHILA.,PA 19103 L~ddrsssl You tray deiive: or mail legible copies of, the docamenb or produca ciitsa ttgsested by this subpaeea, together with''the cenificue of compliance, to the part' malting this request ae the add.-zss fixed above. You have the efzht to seaic. in adrance, t.`.e :asanabie cost of preparing the copid or produrng the Hsi:e~ stxt;ftt. If rou .'ail tC -aduce the documents or things required by this subpoena. wiLr-eu ewe:try (mil days ai:er its ser: ice. the part' sen•ing ::.is s.bpoetu may stele a court order eampoling you ro comply aviLai is THIS 5t3POEVA WAS I55UED ATT.-iE REQV'~=T OFT'rIE FDLLOWIriG PE1250N: NAME: CHRISTOPHER J. KNIGHT, ES ADDR_S. 2411 NORTH FRONT ST. . HARRISBURG, PA 17110 f'cLE?NONE; ~~ s-~aF-Dann S ~P3~t= CDL~i ID s: AT'i0R\eYFt71~ DEFENDANT Seal of the Dour. (.:f: i/97 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PENNSYLVANIA COUNSELING SVS. 700 CHERRY ST. CARLISLE„ PA 17013 RE: 83039 KEVIN KENDIG 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 :KEVIN KENDIG 74 KLINE ROAD, SHIPPENSBURG, PA 17257 Social Security /{: 211-54-8834 Date of Birth: 02-07-1962 SU10-351810 8 3 0 3 9- L 0 2 CERTIFICATE - PREREQIIISITE TO SERVICE aF A SUBPOENA PURSIIANT TO RIILE 4009.22 IN THE MATTER OF: KEVIN KENDIG -VS- 5CHALE COURT OF COMMON PLEAS TERM, CASE N0: 01-3993 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 o~ 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: 02/13/2002 CHRISTOPHER J. KNIGHT, ESQUIRE Attorney for DEFENDANT DE11-310026 8 3 0 3 9- L 0 3 COML~IONWEALTIi OF PENNSYLVANIA -- COUNTY ~OF CUMBERLAND ZN TFfE MATTER OF: COURT OF COMMON PLEAS KEVIN RENDIG TERM, -VS- CASE N0: 01-3993 SCHALE AND [ Note: see enclosed list of locations ) T0: MELISSA L. VAN ECS, BSQ. MCS on behalf of CHRISTOPHBH J. KNIGHT, ESQDIBE intends to serve a sabpoena_ _ identical to the one-that is attached to this notice. You have twenty (20} days from the date listed below is which to file of record and serve upon the° undersigned as objection to the subpoena. If. the twenty day notice period is ~raived or if po objection is sleds, then the subpoena may be served. Complete: copies of say reproduced records may be ordered at your~ezpense by completing the attached counsel card and returning same to MCS or by contacting onr local MCS office. DATE: 01/24/2002° CC: GHRISTOPHEE J. KNIGHT, ESQDIBE- 01-301 Any questions regarding this natter, contact MCS on behalf of CHRISTOPHSH J. KNIGHT, BSQUIBE Attorney for DBFSNDANT THE MCS GBODP INC. 1601 MABBKT STBBKT #800 PHILADELPHI$, PA 19103 (215) 246-0900 DE02-176375 8 3 0 3 9- C 0 1 »> LOCATION LIST «< PAGE: 1. BECOSpS EEQDSSTSD LOCATION NAME MBDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MBDICAL lHiDICAL MBDICAL CLI TEANSPOET LLP ,' PENNSYLVANIA CODNSBLING SVS. VALLEY MBDICAL CSNTSE CABLISLB HOSPITAL CHAMBEESBi7RG HOSPITAL APPALACHIAN OETHOPEDIC CSNTSB DAVID BA$TZBL, K.D. CHAl~EBSBIISG HOSPITAL SHIPPENBDEG HHALiH SSSVICBS DS02-176375 8 3 0 3 9- C 0 1 ~~ COIVtiVEALTH OF PENNSYLVANIA COUNTY OF CUMBERL4\'D KEVIN KENDIG = -•- VS SCBALE File \o. 01-3993 TQ; CUSTODIAN OF RECORDS FOR: VALLEY MEDICAL GROUP (Yamr ai ?man or~R) H'i:hin rwe-• (') days ai:r servicr of this subpoena. you are ardrrd by t.~e c~ar.:o producx rye ioilcwirtg docaments ar ;pings: SF.F. ATTACHED at MCS GROUP INC., 1601 MARKET ST., 1F800, PAILA.,PA 19103 • (Addrrrrt Yau may dei'n•e• or mail legible copies of the doeumenb or produea tisirtp esgnested by this subpoena. together with the certifian oc compliane:. to the parry malting this request at the address liseed abov<. You bare the right ro seric in adraner, the:rasanabfe cost of preparing the copies or producing the risings scersht li you. Fail m -educe the docamenb to things required by this subpoena. wiLLaz twenty (2.1') days alter its sen•icr. the parry ser+•ing :tSs subpoena may seek a emut order compelling you to comply wiLcs ie THIS St3P0ENA WAS ISSUED AT TiiE REQ(JE= i OF Tr:E FflLLOWIriG PEILO\: NRME: CHRISTOPHER J. KNIGHT, ES ADO: 2411 NORTH FRONT ST. HARRISBURG, PA 17110 T2LE?'r.ON; Zt a- 4t;-noon S ~PR~{z CirLlri TD ~: A1i0R\~K?1~ DEFENDANT DATE: ~. ~.`3,t v.ata /~. o2G~~ BY ins OL'A . p.gtyenatity~"~ty~jl ~ivuion 7! 4fY 5<ai O{the Cotsr. (.:f: i/97 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: VALLEY MEDICAL CENTER 411 SOUTH FAYETTE STREET SHIPPEN5BURG, PA 17257 RE: 83039 KEVIN KENDIG 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 :KEVIN KENDIG 74 KLINE ROAD, SHIPPENSBURG, PA 17257 Social Security #: 21~-54-8834 Date of Birth: 02-07-1962 SU10-351512 8 3 0 3 9- L 0 3 a PRERBQUISITB TO SERVICB OF A SIIBPOENA PURSIIANT TO RULB 4009.22 IN THE MATTER OF: KEVIN RENDIG SCHALE COURT OF COMMON PLEAS TERM, -VS- CASE N0: 01-3993 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 subapoena 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: 02/13/2002 CHRISTOPHER J. KNIGHT, ESQUIRE Attorney for DEFENDANT DE11-310027 8 3 0 3 9- L 0 4 COD~IONWEALTI3 OF PENNSYLVAN=A - COUNTY OF CL;NiBERLAND IN THE MATTER OF: COURT OF COMMON~PLEAS KEVIN KENDIG TERM, -VS- CASE N0: 01-3993 SCHALE [ Note: see enclosed list of locations j T0: MEf.ZSSA L. VAN HCg, ESQ. !!CS on behalf of CBBISTOPHEB J. ENIGHT, BSQIIIBS intends to serve a subpoena. identical to the one that is attached to this notice. You have twenty"(20) days from the date listed belor in which to file of record and serve upon then undersigned an objection to the subpoena. If the twenty day notice period is'- waiped or if no objection is made, then the subpoena may be served. Complete. copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or 'by contacting onr local MCS office. DATE: 01/24/2002 MCS oa behalf of CHEISTOPHBB J. EHIGHT, ESQIIIRH Attorney for DEFBHDAHT CC: CHBZSTOPHE$ J. SNIGHT, ESQDIBE- 01-301 Any questions regarding this matter, contact THB MCS G80DP INC. 1601 MAERET STREET ~aoD PHILADBLPHIA, PA 19103 (215) 246-0900 DE02-176375 8 3 0 3 9- C 0 1 »> LOCATION LIST «< PAGE: 1 RECORDS BHQDESTBD LOCATION NAM6 MEDICAL CLI TRANSPOET LLP _ MEDICAL - ' PENNSYLVANIA CODNSffi.ING SOS. _ MEDICAL - ,, e VALLBY I~HSDICAL CBNTBR l~DICAL CABLISLE HOSPITAL MEDICAL CHAMBERSBIIRG HOSPITAL MEDICAL APPALACHIAN O$THOPSDIC CHN?S& l~DICAL DAVID HASTZffi.. K.D. L~DICAL CHAMBERSBDBG HOSPITAL MEDICAL SHIPPSNBiIRG HEALTH SERVICES . DE02-176375 8 3 0 3 9- C 0 1 COMI4SOIv'WEALTH OF PE:~*SYLVANIA • COUNTY OF CUMBERL.4.\'D KEVIN KENDIG -- VS SCHALE FIe No. 01-3993 ~!~; CUSTODIAN OF RECORDS FOR: CARLISLE HOSPITAL ~tiamr of Per,an ar Win) t~'i:hin rwe.-r (I]) days aitr. senics of this suboaana. you ue ardrrd br L4e tour. to produces toe ioiiawirtg dor~atents or t^.ingx SF.F. ATTA('AF.n u MCS GROUP INC., 1601 MARKET ST., X1800, PHILA.,PA 19103 twadrrsst Yau may deiis•a or mail legible copies of the dacumenn or ptoduea ehing~ rtenested by this subpoena, togetaer with the certificate of eomp[ianet, to the part' making this request at the adders listed above. You bare the right to seek in ad+•ancr. t.`r reasonable teat of preparing the espies err producing the wings stanght: If rau ,'ail tc -oduce the documents or things required by this subpoena, wiL'-ots rwe:try (2.1') days arer its se:+•ice, the pu-y sen•ing ::,is subpoena may seek a court order eompeiling you to camaly with THIS SL3POTTIA WA5 I5_='JED AT T:-IE REQUEST OF T'r?E FDLLOWI?VG PEIi50~: NRMF: CHRISTOPHER J. KNIGHT~ESO. _ ADDR_~ 2411 NORTH FRONT ST. HARRISBURG, PA 17110 TILE?I?dNl= ~t a_~ab-oann S~PS~t=COLr2~, ID h ~TTOR1eYFD1C DEFENDANT BY( ~ on~~~ ~ c~.,~ DA i L• `aw Y ~ .~-.i' n s I ~ t ,~ Y~~ ~ P~tAottaary/Caic G~.t iaion \ /lni. o 3ca1 of the Cossr. <~ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE HOSPITAL 246 PARKER STREET CARLISLE, PA 17013 RE: 83039 KEVIN KENDIG Any and all records, correspondence, files and memorandums, handwritten notes, relating to any examination, consultation care or treatment. Dates Requested: up to and including the present. Subject :KEVIN KENDIG 74 KLINE ROAD, SHIPPENSBURG, PA 17257 Social Security #: 211-54-8834 Date of Birth: 02-07-1962 SU10-351814 8 3 0 3 9- L 0 4 CERTIFICATH - .PREREQUISITE TO SERVICE ~F A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: KEVIN RENDIG SCHALE COURT OF COMMON PLEAS TERM, -VS- CASE N0: 01-3993 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: 02/13(2002 CHRISTOPHER J. KNIGHT, ESQUIRE Attorney for DEFENDANT DE11-310028 8 3 0 3 9- L O S COMD~lONWEALTE3 OF PENNSYLVAN=A -- COUNTY OF CLTNiBERLAND IN THE MATTER OFr COURT OF COMMON PLEAS KEVIN RENDIG TERM, -VS- CASE N0: 01-3993 SCHALE [ Note: see enclosed list of locations ] T0: !ffi.ISSA L. VAN HCH:, HSQ. ?ICS on behalf of CHRISTOPHBB J. HN]CGHT, ESQDIRH intends to serve a subpoena.. identical to the one that is attached to this notice. Yon have twenty (20) days from the date listed below in which to file of record and serve upon the= undersigned an abjection 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 ezpense by casipleting the attached counsel card and returning same to IBS or by contacting our local MCS office. DAVE: 01/24/2002 , AlCS on behalf of CHRISTOPHER J. HNIGHT, ESQUIRH Attorney for Dffi+ENOANT a CC: CHRISTOPHBR J. HNIGHF, BSQIIIBB- 01-301 Any questions regarding this matter, contact THH NCS GROUP INC. 1601 MABEBT STRHBT fS00 PHILADHLPHIA, PA 19103 (215) 246-0900 DH02-176375 8 3 0 3 9- C 0 1 »> LOCATION LIST «< PAGE: 1 RECORDS REQIIESTED LOCATION NAME MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MBDICAL MEDICAL CLI TRANSPORT LLP PENNSYLVANIA CODNSffi.ING $VS. VALLEY MEDICAL CENTER CARLISLE HOSPITAL CHAMBHRSBDRG HOSPITAL APPALACHIAN OBTHOPEDIC QENTBR DAVID HARTZSL, M.D. CHAMBERSBDRG HOSPITAL SHIPPENBIIRG HEALTH SSEVICES DE02-176375 8 3 0 3 9- C 0 1 C7M1~iONWEALTH OF PEN\'SYLVANIA COUNTY OF CUMBERL~..irD KEVIN KENDIG VS SCHALE ~ File \o. 01-3993 SUBPOENA TO PRODUCE DOCLT~IE'.1T~ OR T~-iL\GS FOR DISCOVERY PURSUIT TO RULE 4009?' T!~; CUSTODIAN OF RECORDS FOR: CHAMBERSBURG PAIN SERVICES 1\ame of Pusan or ~n7 Ki:hin rwe~• (') days arr. sersica of thin subooesta, you ue orderrd by the t~tta ttt produce the foltawing docustmts ar :hingx - SEF. ATTACRED ' at MCS GROUP INC., 1601. MARKET ST., IF800> PHILA.,PA 19103 (Address) You may denser or mail legible copies of the dacumenn or produce tiittsi etenested by thii subpoena. togr.=er with the cenifiate of compliant:, to the. paay malting this request at the add.-~ lietad above. You tiara the tight to seek. in adsance, tht +asonable cost of preparing tote copies or producing the slangs swght. if sou hit to -oduce the documents or ehinga required by this subpoena, wiL~ei7 (weary ('~') dars alter in setsice, the pat-.y sensing ;rSs subpttena may setic a court order mmoeiling you to comaly with ie THIS SL3POEVA W AS ISStJEED AT TFiE REQUE_`T OF T'rIE FOLLOWING PERSO\: NRIrfE: CHRISTOPHER J. RNIGHT. ES .ADORES:: 2411 NORTH FRONT ST. HARRISBURG, PA 17110 TcLE.Q:jQIY~ Z15-~46-09(1(1 S :'?^t_1i: CDtrATID ~: ATr0R1EYfOR• DEFENDANT DAiLS sy~ ~ /(at t e Seal of the Coto: (.rf: i/97 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CHAMBERSBURG HOSPITAL PAIN SERVICES 112 N. TTH ST. CHAMBERSBURG, PA 17201 RE: 83039 KEVIN KENDIG Any and all records, correspondence, files and memorandums, handwritten notes, relating to any examination, consultation care or treatment. Dates Requested: up to and including the present. Subject :KEVIN KENDIG 74 KLINE ROAD, SHIPPENSBURG, PA 17257 Social Security #: 211-54-8834 Date of Birth: 02-07-1962 SU10-351816 8 3 0 3 9- L O S _- _ PREBEQIIISITE TO SERVICE OF A SIIBPOENA Pi1RSIIANT TO RULE 4009.22 IN THE MATTER OF: KEVIN KENDIG -VS- SCHALE COURT OF COMMON PLEAS TERM, CASE N0: 01-3993 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: 02/13/2002 CHRISTOPHER J. KNIGHT, ESQUIRE Attorney for DEFENDANT DEIl-310029 8 3 0 3 9- L 0 6 COMD'iONGTEALTE3 OF PENNSYLVANIA -- ~ COUNTY OF CL1fkIBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS KEVIN KENDIG -VS- SCHALE A [ Note: see enclosed list of locations J TERM, CASE N0: 01-3993 TO: MELISSA L. VAN BC$, BSQ. TB;S on behalf of CHRISTOPHBH J. KNIGHT, ESQDIBB intends to sezve a subpoena.. identical to the one that is attached to this notice. Yon have twenty (20) - days frog the date listed belor in which to file of record and serve upon thee. undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena mag be served. Complete-- copies of any Teproduced records may be ordered at your ezpense b7 completing, the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/24/2002 CC: CHRISTOPHER J. KNIGHT, ESQDIBH- 01-301 Any questions regarding this matter, contact MCS oa behalf of CHRISTOPHER J. KNIGHT„ ESQDIBB Attorney for DEFENDANT THB MCS GROUP INC. 1601 MABEBT STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-176375 8 3 0 3 9- C 0 1 »> LOCATION LIST «< PAGE: 1 RECORDS REQDESTED LOCATION NAlIS MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL CLI TEANSPORT LLP § PENNSYLVANIA CODNSHLING SOS. VALLEY MEDICAL CENTER CABLISLH HOSPITAL CHAMBHRSBDRG HOSPITAL APPALACHIAN OHTHOPBDIC CENTEE DAVID HA&TZBL. M.D. CHANBHHSBIIRG HOSPITAL SHIPPBNBIIRG HHALTH SHHVICHS DH02-176375 8 3 0 3 9- C 0 1 COMNcONWEALTH OF PE~rSYLVANIA COUNTY OF CUMBERL4.\'D KEVIN KENDIG --- VS SCHALE FIe \o. 01-3993 SUBPOENA TO PRODUCE DOCIJ~IE:\TS OR T'r.I\GS FOR DISCOVERY PURSUA:\T TO RULE 40a9?' TQ; CUSTODIAN OF RECORDS FOR: APPALACHIAN ORTHOPEDIC CENTER Itiame ei Perean ar'sdtst - t+'i:4in ¢++e.-r (~) days at•.r. services of this sabportna. you are ardrrd by 6he eaua to prndura the faiiawing documents ar thina~x SF.F. ATTA(:HF.D at MCS GROUP INC., 1601 MARKET ST., 1IS00, PHILA.,PA 19103 IAddree+) You may deiirer or mail legible copies of the docatnenn ar product ehirta eegaested by this subpoena. roger=er with the ceniFinteaf compliant:, to the pure making t.4is request at the add.+ls listed abovt_ You beset the ri¢itt to se•.k. in adxance, the seasonable cost of preparing thecopin or produr'ng the L'tin} seusht. If rau ,'aiI to :soduce the doramenls ar things reouired by this subpceny wir.'-as twenty ('a) days arer its sar: ice. the part' sen•ing ::.s tebooena may seek a court order eompoling you to comply tviLS THIS SL3POE~1A W!S ISztJEL1 ATT:-iE REQL~=T OFTFiEFOLLOWING PERSON: NRME: CHRISTOPHER J. KNIGHT, ESO. ADDR~~S: 2411 NORTH FRONT ST. HARRISBURG, PA 17110 TaLE?:?ONE ~t s_~4~_nonn 5~?Q~4E DDL~? ID t. ~TiOR\iYFOEL• DEFENDANT DAT_ ~ ,t i 15 ~/ / _ ~d~i ~ Seal of the Cosa: EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAIV'OF RECORDS FOR: APPALACHIAN ORTHOPEDIC CENTER 1 DUNWOODY DR. CARLISLE, PA 17013 RE: 83039 KEVIN KENDIG 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 :KEVIN KENDIG 74 KLINE ROAD, SHIPPENSBURG, PA 17257 Social Security /h. 211-54-8834 Date of Birth: 02-07-1962 SU10-351818 8 3 0 3 9- L 0 6 CERTIFICATE PRSBEQUISITE TO SERVICE OF A SIIBPOHNA PURSIIANT TO RULE 4009.22 IN THE MATTER OF: CODRT OF COMMON PLEAS KEVIN KENDIG TERM, -VS- CASE N0: 01-3993 SCHALE 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, C3) 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: 02/13/2002 CHRISTOPHER J. KNIGHT, ESQUIRE Attorney for DEFENDANT DE11-310030 8 3 0 3 9- L 0 7 C OMNIONWEAL T H O F PE NN S YLVAN =A - COUNTY OF CLxNiBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS KEVIN KENDIG TERM, -VS- CASE N0: 01-3993 SCHALE [ Note: see enclosed list of locations ] T0: MBI.ISSA L. VAN HCg, ESQ. MCS on behalf of CHRISTOPHER J. KNIGHT, ESQDIRE intends to serve a subpoena-.- identical to the one that is attached to this notice. Yon have twenty (20) days fry the date listed below in which to file of record and serve upon the: undersigned an objection to the subpoena. If the twenty dap notice period is - waived or if ao objection is made, then the subpoena may be served. Cc®plete copies of any reproduced records may be ordered at your ezpense by completing the attached counsel car~and returning same io MCS or by contacting our local MCS office. DATE: 01/24/2002 CC: CHRISTOPHER J. KNIGHT, ESQDIBE- 01-301 Any questions regarding this matter, contact MCS oa behalf of CHRISTOPHSB J. KNIGHT, ESQIIIRE Attorney for DEFENDANT THE MCS GBOIIP INC. 1601 MABKHT STBEET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-176375 8 3 0 3 9- C 0 1 »> LOCATION LIST «< PAGH: RECORDS REQDHSTED LOCATION NAMB MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MBDICAL MBDICAL MEDICAL CLI TRANSPORT LLP PENNSYLVANIA CODNSSLING SVS. VALLHY MEDICAL CENTER CARLISLB HOSPITAL CHAMBBRSBDRG HOSPITAL APPALACHIAN ORTHOPHDIC CHNTHR DAVID HARTZHL, M.D. CBAMBHRSBDRG HOSPITAL SHIPPHNBDRG BBALTB SERVICHS DH02-176375 8 3 0 3 9- C O 1. COMMOiv'WEALT'H OF PENNSYLVANIA COUNTY OF CUMBERL~..\'D KEVIN KENDIG VS SCHALE File \o. 01-3993 1Q; CUSTODIAN OF RECORDS FOR: DR. HARTZELL (tiamr ai Pmen rr a~tT) '~'i:hia ewea~ ('} days ai:r. service of this subpoena. you ara ordered by L+f~ ewzx to prndvca the ioiiowing toc~taenn or things SEE ATTACHED at MCS GROUP INC., 1601 MARKET ST., IFS00, PHILA.,PA 19103 (Addrar) You may deiire• ar mail fegib[e topics of the dttessmenta ar produca t.~.is:tQ rt+eaested by this subpoena, roger:^.er with the certificate of mmplianee. to the parry trtaking this Bequest at the addrstss fixed above. Yoss hava ehe right to seek in adrancr, the :easonabie cost of preparing ehe copies ar producing the ~its~ sosssht. If tau ,'ail tC :coduce the dtxuments or things required by this subpoena, wiL'-.3st twenty ('~) dars ai:er its san•ice. the pu-y sen•ing ;:.is s::paesta may seek a court order compelling you to eompIy wiLa3 G TfiL SL'3POE~fA W.AS ISSUErJ AT T:?E REQU~"T OFT'eiE FDLLOWI*iG PERSON: NAME: CHRISTOPHER J. KNIGHT. ES ADDASS: 2411 NORTH FRONT ST. HARRISBURG, PA 17110 T_LE.R??LNE ~t5-~4t,-Dann S~PFi=1t'c`COL°3~i ID ~: ATTOR\cYFOR DEFENDANT DAi ° ~ .+ Y. ti ~ ~(T~nd~. Seal of the Catut EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DAVID HARTZEL, M.D. 850 WALNUT BOTTOM ROAD CARLISLE, PA 170133698 RE: 83039 KEVIN I{ENDIG 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 :KEVIN KENDIG 74 KLINE ROAD, SffiPPENSBURG, PA 17257 Social Security #: 211-54-8834 Date of Birth: 02-07-1962 SU10-351820 8 3 0 3 9- L 0 7 CERTIFICATB - ~ - PREREQBISITE TO SERVICE OF A SBBPOENA PIIRSIIANT TO RULE 4009.22 IN THE HATTER OF: KEVIN RENDIG SCHALE COURT OF COMMON PLEAS TERM, -VS- CASE N0: 01-3993 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 copq 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: 02/13/2002 CHRISTOPHER J. KNIGHT, ESQUIRE Attorney for DEFENDANT DE11-310031 8 3 0 3 9- L 0 8 C OM1~2O NWEAL TH O F PENNSYLVANIA = COUNTY ~OF CLICIKBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS KEVIN KENDIG TERM, -VS- CASE N0: 01-3993 SCHALE [ Note: see enclosed list of locations ] 20: MBLISSA L. VAH ECB, ESQ. MCS on behalf of CHBISTOPHB6 J. KN'%GHT, ESQIIIRE intends to serve a subpoena-_ identical to the one that is attached to this notice. You have twenty (20) days fry the date listed below is 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 ezpense by completing the attached counsel card and returning same to MCS or by contacting onr local MCS office. DATE: 01/24-/2002 CC: CHRISTOPHBH J. KNIGHT, ESQDIBH- 01-301 Any questions regarding this matter, contact MCS oa behalf of CHRISTOPHBR J. KNIGHT, ESQDIRE Attorney for DEFENDANT THE MCS GROIIP INC. 1601 MABKBT STREBi $800 PH]ZADBLPHIA, PA 19103 (215) 246-0900 DE02-176375 8 3 0 3 9- C 0 1 »> LOCATION LIST «< PAGE: 1 RECORDS REQDESTED LOCATION NAME l1LDICAL l~DICAL I~DICAL MBDICAL MEDICAL MEDICAL t~DICAL M®ICAL MEDICAL 0 0 a CLI TRANSPORT LLP PENNSYLVANIA COIINSELItIG SVS. VALLEY MEDICAL CENTER CABLISLS HOSPITAL CHAMB$RSBIJRG HOSPITAL APPALACHIAN ORTHOPEDIC CENTBB DAVID HAR?ZEL, M.D. CBAMBERSBDRG HOSPITAL SHIPPBNBDRG HEALTH SERVICES DE02-176375 8 3 0 3 9- C O 1. COMMO[yVV'EALTH OF PENtirSYLVANIA ' COUNTY OF CUMBERL.~\'D KEVIN KENDIG _ VS SCHALE File ~o. 01-3993 TO; CUSTODIAN OF RECORDS FOR: CHAMBERSBURG HOSPITAL (tiame ni Pmnn ar _.8t~) N'i:h7.: cove.-• (:.^) days aver sen•ics of this subpoena. yov ue orderrd'>,•r t.~e cevr. to prodvcs toe fciiewinz eeriments ar ;hints: RF.F. ATTACHED at MCS GROUP INC., 1601 MARKET ST., 1)800, PHILA.,PA 19103 (~ddrea~l Yov may deih•r. or nail legible espies of the docimenn ar produce e.'~.irt3! senesced by this.svbgoerta.:oge:=er with the certifinte o? compliant:, to the parry malting this request at the add.~s Hated above. Yov have the tight to seaic. in adsancs. che:tuonabie cost of preparinS the copies or producing the tiZ•.nlo soasht. if .•av .'ail to -oduce the daramenta or things required by this subp~oet'u, wiL~a-t twenty ('_I') days niter its se^: ice, the part' sen•ing is tcbeoena may seek a court order compelling you to comalr with i= THIS SL3PflEV?~ W ~ ISSUED AT THE REQLTE~ i OFTr?E F•DLLOWII~IG PERSO\: NRME: CHRISTOPHER J: KNIGHT ..ES ADOR=~~ 2411 NORTH FRONT ST. HARRISBURG, PA 17110 T'cLE.aMQNE Z) s-~4(,-Dann SLPFi~t=CDL~TID D: ~TOR~"e~'FDR DEFENDANT ' BY s CO 'R?: DA =' ~~QO v~ P~tteneur)t/Cers G - span YrY Sell Of the COBS: (.ff. i/97 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CHAMBERSBURG HOSPITAL 112 NORTH SEVENTH ST. CHAMBERSBURG, PA 17201 RE: 83039 KEVIN KENDIG Any and all records, correspondence, files and memorandums, handwritten notes, relating to any exarmnation, consultation care or treatment. Dates Requested: up to and including the present. Subject :KEVIN KENAIG 74 KLINE ROAD, SffiPPENSBURG, PA 17257 Social Security #: 211-54-8834 Date of Birth: 02-07-1962 SU10-351822 8 3 0 3 9- L 0 8 CERTIFICATE - PREREQUISITE TO SERVICE OF A SUBPOENA PIIRSIIANT TO RI1LE 4009.22 IN THE MATTER OF: KEVIN KENDIG -VS- SCHALE COURT OF COMMON PLEAS TERM, CASE N0: 01-3993 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: 02/13/2002 CHRISTOPHER J. KNIGHT, ESQUIRE Attorney for DEFENDANT DE11-310032 8 3 0 3 9- L 0 9 COIrII~~iONWEALTEi OF PENNSYLVAN=A - ~ - C OUN TY O F CL7MB ERLAND IN THE MATTER OF: COURT OF COMMON PLEAS KEVIN KENDIG -VS- SCHALE NOTICE OF INTHNT TO TERM, CASE N0: 01-3993 TO PRODOCB [ Note: see enclosed list of locations ] AND T0: MELISSA L. VAN ECR, ESQ. TICS on behalf of CHRISTOPHEg J. ENfGHT, ESQDIRE 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 is 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 HCS or by contacting our local MCS office. DATE: 01/24/2002 MCS on behalf of CHRISTOPHSE J. KNIGHT, ESQDIRE Attorney for DEFENDANT CC: CHRISTOPHSB J. KNIGHT, ESQDIRE- 01-301 Any questions regarding this matter, contact TH8 MCS GRODP INC. 1601 HAWKER STREHT #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-176375 8 3 0 3 9- C 0 1 »> LOCATION LIST «< PAGE: 1 RECORDS REQOESTED LOCATION NAME MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MBDICAL MEDICAL MEDICAL CLI TBANSPORT LLP PENNSYLVANIA COIINSELING SOS. VALLEY MEDICAL CENTER CARLISLE HOSPITAL CHBI~ERSBDRG HOSPITAL APPALACHIAIi ORTHOPEDIC CHNTHR DAVID HARTZEL, M.D. CHAMBERSBDRG HOSPITAL SHIPPENBi7RG HEALTH SERVICES DS02-176375 8 3 0 3 9- C 0 1 COMMONWEALTH OF PEVN*SYLVANIA ' ~ COUNTY OF CUMBERL~\D KEVIN KENDIG VS SCHALE • File \o. 01-3993 TQ; CUSTODIAN OF RECORDS FOR: SHIPPENSBURG HEALTH SERVICES I:~amr or Person or ~~dn) H'i:hin twe-cr 1.7) days aftC. service of this subpoena, you ue ordered by the court to oroducs the following doatments or ;hinge: _ FF.F. ATTAC.HF.D at MGS GROUP INC., 1601 MARKET ST., 11800, PHILA.,PA 19103 I~~ddtns) Yau may denser or mail legibie copies of the documents ar produce thfngs requested by this subpoena. together with the certificate of cnmpiianrt, ro the party making this request at the addss~se fixed shave. You base she right to sric in adsancs, the suanabie cost of preparing the copies or producing the things sought. If you fail ro -oduee the documents or things required by this subpoena, wilt-a twenty (~I d»•s after ice san•ice, the parry sensing:tie s~bpaena may seek a roust order compelling you to comply wins G THIS St3POE~1A WAS ISSUED ATT'riE REQUEST OFT'riE FOLLOWING PERSOti: NAME CHRISTOPHER J. KNIGHT. ESO. .4DDRE5 2411 NORTH FRONT ST. HARRISBURG, PA 17110 T-cLlEaiiON€ ~) 5-~4~-noun Si:PR~ir COL'RTID *: ATTOR.\EY FOR' DEFENDANT DAie .~/`~7a tl1~.i ~~T alY~~. r Seal of the Caur: (iE:f. i/9~ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SHIPPENBURG HEALTH SERVICES 46 WALNUT BOTTOM ROAD SHIPPENSBURG, PA 17257 RE: 83039 KEVIN KENDIG Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: upp to and including the present. Subject :KEVIN KENDIG 74 KLINE ROAD, SHH'PENSBURG, PA 17257 Social Security;Y: 211-54-8834 Date of Birth: 02-07-1962 SU10-351824 8 3 0 3 9- L 0 9 r ~ c:,~ ' E- r: - -,-r ter' ` . ~ CO .-_. ~~'... -, _i_ ~, P." -~ (J: m f - ~Ea`rE4`, ~ a _~, a ti^,a~~>zw ~,2.r~ fTK+T~,:.?6dif1%SS~~H~pA~'?P~®~' KEVIN KENDIG and NANCY KENDIG, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3993 CIVIL TERM v. CHRISTY SCHALE and EDMUND SCHALE, Defendants CIVIL ACTION -LAW JURY TRIAL DEMANDED PRAECIPE TO WITFIDRAW APPEARANCE Kindly withdraw the appeazance of Melissa L. Van Eck, Esquire, on behalf of Plaintiffs, Nancy Kendig and Kevin Kendig. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. ©~~~ By~~~~iD_-~ Melissa L. Van Eck, Esquire Attorney I.D. No. 85869 P.O. Box 5300 Dated: 3211 North Front Street Harrisburg, PA 17110-0300 (717)238-8187 PRAECIPE TO ENTER APPEARANCE Kindly enter the appearance of Andrew Norfleet, Esquire, on behalf of Plaintiffs, Kevin Kendig and Nancy Kendig. Dated: Z- ~'~ 82 METZGER, WICKERSHAM, KNAUSS & ERB, P.C Document #: 247789.1 Harrisburg, PA 17110 (717)238-8187 ~ c ~- ~._ --+ ~,~,. ,~ ~~~ _ ,. < -~ ~~ _ t,. ~ , ~ •' , ~ ~ ~.; ` i ~C ,J ~ ~~ I: TI '< s KEVIN KENDIG and NANCY KENDIG, PLAINTIFFS v. CHRISTY SCHALE and EDMUND SCHALE, DEFENDANTS TO THE PROTHONOTARY: 4 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3993 CIVIL TERM CIVIL ACTION - AT LAW JURY TRIAL DEMANDED PRAECIPE Please enter the undersigned's appearance on behalf of the Defendants, Christy Schale and Edmund Schale, with regard to the above-captioned matter. Respectfully submitted, Date: 62 ~Lt ~OS NEALON & GOVER, P.C. By: ~~~4~ Michael S. Ferguso ,Esquire Attorney I.D. No. 83882 2411 North Front St. Harrisburg, PA 17110 (717)232-9900 CERTIFICATE OF SERVICE AND NOW, this I f 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: Andrew Norfleet, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 N. Front St. Harrisburg, PA 17110 V ~'lG~~ Michael S. Ferguson, Esquire c o w 7l cc r i` 7 _ 1' T n 7 R7~ ._ ~ m s c r; 5 i ~~ ~., S < - ~ ~ ~ ~ ~~~ Ir. l'.: 1 - .. KEVIN KENDIG and NANCY KENDIG, PLAINTIFFS v. CHRISTY SCHALE and EDMUND SCHALE, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3993 CIVIL TERM CIVIL ACTION - AT LAW JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendants, Christy and Edmund Schale, with regard to the above-captioned matter. Respectfully submitted, NEALON, GOVER & PERRY By: G.~ G. Shore, Esquire I.D. #: 85321 2411 North Front Street Harrisburg, PA 17110 717/232-9900 Date: oL O~ CERTIFIC~4TE OF SERVICE AND NOW, this Its' day of February, 2005, 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 mails, postage prepaid, addressed to: Andrew Norfleet, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 N. Front St. Harrisburg, PA 17110 Cas .Shore, Esquire .~ -i i ".; I~li_'c ^~i_ ..~ ~ ~.~ C.J - C:.l ... 4,;:1 ... KEVIN KENDIG and NANCY KENDIG, PLAINTIFFS v. CHRISTY SCHALE and EDMUND SCHALE, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.01-3993 CIVIL TERM CIVIL ACTION - AT LAW JURY TRIAL DEMANDED PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the undersigned's appearance on behalf of the Defendants, Christy and Edmund Schale, with regard to the above-captioned matter. Respectfully submitted, Date: 1 ~ NEALON, GOVER & PERRY BY~ , C ~uLdl ~ ~~ Michael S. Fergu n, Esqui I.D. #: 83882 2411 North Front Street Harrisburg, PA 17110 717/232-9900 CERTIFIC~4TE OF SERVICE AND NOW, this 11~ day of February, 2005, I hereby certify that I have served the foregoing WITHDRAWAL OF APPEARANCE on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Andrew Norfleet, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 N. Front St. Harrisburg, PA 17110 ~~,~~~t~,4ubNL (_!0~ (.ICJ Michael S. Fe guson, Esq ire _> _ ` ~, .. _~ .T. -_ ~.~ S ~ _, , .- ,,, . , -~- ~.t ~ , ' ' c~~ _ r i c.~~ `i 4r:3 ` ,, METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By: Andrew W. Norfleet, Esquire Attorney I.D. No. 83894 P.O. Box 5300 Harrisburg, PA 17110-0300 (717)238-8187 Attorney for Plaintiff KEVIN KENDIG and NANCY KENDIG, Plaintiffs v. CHRISTY SCHALE and EDMUND SCHALE, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3993 CIVIL TERM CIVIL ACTION -LAW NRY TRIAL DEMANDED PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly mark the entire above-captioned case se ~ continued and ended. By: C!, Andrew W. orfleet, Es Attorney I.D. No. 83894 3211 N. Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 Attorney for Plaintiff (717) 238-8187 Date: August 31, 2005 335210-/ ~' - x CERTIFICATE OF SERVICE I, Tammy M. Nissley, of the law firm of Metzger, Wickersham, Knauss & Erb, P.C., hereby certify that I served a true and correct copy of Plaintiffs' Praecipe to Settle, Discontinue and End with reference to the foregoing action by first class mail, postage prepaid, this 31St day of August, 2005 on the following: Casey G. Shore, Esq. Nealon, Gover & Perry PC 2411 North Front Street Harrisburg, PA 17110 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Tammy M. Niss y 335110-/ r-, ~ ,~ 4 O t RTi~-' ' ! ~/..~ ti ~'}.1~ =i-' .. ~ _ _~e ~_.~ ~;, tS + ~lT. -~ ~t Q~ :3 _~