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Home My WebLink About01-04538« ~r 4 d ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHRYN PERROTT DONAHEY, and her husband GLENN HOWARD DONAHEY as Administrators of the Estate of JOSEPH NICHOLAS DONAHEY and KATHRYN PERROTT DONAHEY and GLENN HOWARD DONAHEY, as Individuals, 8(o R-c-tie v' 1~ 9 ~~'Ir~}~~- ; ~{a l ~-b:]-`--I Plainriffs v. JAMES DOWNEY LONG, M.D.; BARBARA BRANDY; SPIRIT PHYSICIAN SERVICES, INC. d/b/a CENTER FOR WOMEN'S HEALTH AND WELLNESS; and HOLY SPIRIT HOSPITAL, a nonprofit corporation Defendants NOCIVIL ~ al- ys~~ CIVIL ACTION -LAW JURY TRIAL DEMANDED PRAECIPE TO ISSUE WRIT OF SUMMONS TO: PROTHONOTARY OF CUMBERLAND COUNTY Kindly issue the Writ of Summons against the following named defendants: James Downy Long, M.D.; Barbara Brandt; Spirit Physician Services, Inc. d/b/a Center for Women's Health and Wellness; and Holy Spirit Hospital. ~ . .~ o~.s p6v~n-,e~y ~c~cj, M. ~ . ~~-rl~rz~ ~r~.ndi- S~ir~~ ~Yu.~sic~a~s, tnc. ~~bla Cen+e~ ~,~ women~s l-~at~, ~tn~e(~n~ (-123 N . 2f S'' sfi, t-f o l ~ S~ I r~ 1- ~; ~ f Sb3 til• 21~r ~-{- ;. JURY TRIAL DEMANDED Date: 0~7 ~"~J Respectfully submitted, ECKERT SEAMANS CHERIN & MELLOTT LLC ~~~~ Jo .Hall, Esquire (Pa. I.D. 11095) 600 Grant Street, 44~' Floor Pittsburgh, PA 15219 (412) 566-6000 Attorneys for Plaintiffs Commonwealth of Pennsylvania County of Cumberland Kathryn Perrott Donahey, and her husband Glenn Howard Donahey as Administrators of the Estate of Joseph Nicholas Donahey and Kathryn Perrott Donahey and Glenn Howard Donahey, as individuals 86 Acker Rd. Newport, PA 17074 vs. James Downey Long, M.D.; Barbara Brandt; Spirit Physician Services, Inc. d1bJa Center Court of Com[non Pleas For Women's Health and Wellness 423 N. 21st S't. No. ____ 01-4538 Civil ________________ 19 Camp Hill, PA 17011 and In Civil Action - Law Holy Spirit Hospital a nonprofit corporation 503 N. 21st 5t. Camp Hill, PA 17011-2788 To __,7s~merxl?4witeg_IS1i14._M,.Q.J_~arbai'd.BSandt; Spirit Physician Services, Inc. d/b/a Center ~Or Women's Health and Wellness; and Holy Spirit Hospital, a nonprofit Yo°orpor~eregy notified that _Kathrxn_Perrott Donahey__ and her husband Glenn Howard Donahey as Administrators of the EstahtQe.,of JosepA'h Nri7cholas Donahey and Kathryn Perrott Donahey and Glenn the Plam°~f~sd h~OVe~rn~iien~~d ld~ 3C~.tonuit51s______Civi l_Action _ Law - - ------------------------------- against you which you are required to defend or a default judgment may be entered against you. (SEAL) !S/ ;~ Prothonota Date G~-- c~77 ~~, ,yam P tY c ~~~ --- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHRYN PERROTT DONAHEY, and her Husband GLENN HOWARD DONAHEY a Administrators of the Estate of JOSEPH NICHOLAS DONAHEY and KATHRYN PERROTT DONAHEY and GLENN HOWARD DONAHEY, as Individuals, Civil Action -Law Plaintiffs, No. 01-4538 Civil v. JAMES DOWNEY LONG, M.D.; BARBARA BRANDY; SPIRIT PHYSICIAN SERVICES, INC. d/b/a CENTER FOR WOMEN'S HEALTH AND WELLNESS and HOLY SPIRIT HOSPITAL, a nonprofit corporation, Defendants. ACCEPTANCE OF SERVICE I accept service of the Writ of Summons on behalf of James Downey Long, M.D. and certify that I am authorized to do so. Date: y' 7'J ZJ ~~~ w (Defendant or Authori Agent) METTE EYANS & WOODSIDE 3401 NO H FR (Mailing Ad ess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHRYN PERROTT DONAHEY, and her Civil Action -Law Husband GLENN HOWARD DONAHEY a Administrators of the Estate of JOSEPH NICHOLAS DONAHEY and KATHRYN PERROTT DONAHEY and GLENN HOWARD DONAHEY, as Individuals, Plaintiffs, No. 01-4538 Civil v. JAMES DOWNEY LONG, M.D.; BARBARA BRANDY; SPIRIT PHYSICIAN SERVICES, INC. d/b/a CENTER FOR WOMEN'S HEALTH AND WELLNESS and HOLY SPIRIT HOSPITAL, a nonprofit corporation, Defendants. ACCEPTANCE OF SERVICE I accept service of the Writ of Summons on behalf of Spirit Physician Services, Inc. d/b/a Center for Women's Health and Wellness and certify that I am authorized to do so. Date: ~ ~~ d/ ~ ~ ~~ (Defendant or Authorize Agent) METTE EVANS & WOODSIDE vn BOX-5959 HARRISBURG PA 17iin-no5n (Mailing Address) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHRYN PERROTT DONAHEY, and her Husband GLENN HOWARD DONAHEY a Administrators of the Estate of JOSEPH NICHOLAS DONAHEY and KATHRYN PERROTT DONAHEY and GLENN HOWARD DONAHEY, as Individuals, Civil Action -Law Plaintiffs, No. 01-4538 Civil v. JAMES DOWNEY LONG, M.D.; BARBARA BRANDY; SPIRIT PHYSICIAN SERVICES, INC. d/b/a CENTER FOR WOMEN'S HEALTH AND WELLNESS and HOLY SPIRIT HOSPITAL, a nonprofit corporation, Defendants. ACCEPTANCE OF SERVICE I accept service of the Writ of Summons on behalf of Holy Spirit Hospital and certify that I am authorized to do so. Date: ~ ~~ ~ 1 (Defendant or Authorized gent) METfE EVANS & WOODSIDE t FRO T STR ET HARRtS®4~RG Ph 17110 A95A (Mailing Address) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHRYN PERROTT DONAHEY, and her Husband GLENN HOWARD DONAHEY a Administrators of the Estate of JOSEPH NICHOLAS DONAHEY and KATHRYN PERROTT DONAHEY and GLENN HOWARD DONAHEY, as Individuals, Civil Action -Law Plaintiffs, No. 01-4538 Civil v. JAMES DOWNEY LONG, M.D.; BARBARA BRANDY; SPIRIT PHYSICIAN SERVICES, INC. d/b/a CENTER FOR WOMEN'S HEALTH AND WELLNESS and HOLY 5PIRIT HOSPITAL, a nonprofit corporation, Defendants. ACCEPTANCE OF SERVICE I accept service of the Writ of Summons on behalf of Barbara Brandt and certify that I am authorized to do so. Date: d 2 ~ o~ (Defen ant or Authorize ~ent) ~ 5 0~2'~ 7/0 (Mailing Address) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHRYN PERROTT DONAHEY, and her husband GLENN HOWARD DONAHEY as Administrators of the Estate of JOSEPH NICHOLAS DONAHEY and KATHRYN PERROTT DONAHEY and GLENN HOWARD DONAHEY, as Individuals, Plaintiffs v. 3AMES DOWNEY LONG, M.D.; BARBARA BRANDY; SPIRIT PHYSICIAN SERVICES, INC. d/b/a CENTER FOR WOMEN'S HEALTH AND WELLNESS; and HOLY SPIRIT HOSPITAL, a nonprofit corporation Defendants NO.OI-4538 CIVIL CIVIL ACTION -LAW PRAECIPE TO DISCONTINUE JURY TRIAL DEMANDED Counsel of Record for these parties: ECKERT 5EAMANS CHERIN & MELLOTT,LLC John E. Hall, Esquire PA I.D. No. 11095 U.S. Steel Tower 600 Grant Street, 44s' Floor Pittsburgh, Pa 15219-2788 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHRYN PERROTT DONAHEY, and her NO. 01-4538 CIVIL husband GLENN HOWARD DONAHEY as Administrators of the Estate of JOSEPH NICHOLAS DONAHEY and CIVIL ACTION -LAW KATHRYN PERROTT DONAHEY and GLENN HOWARD DONAHEY, as Individuals, Plaintiffs v. JAME5 DOWNEY LONG, M.D.; BARBARA BRANDY; SPIRIT PHYSICIAN SERVICES, INC. d/b/a CENTER FOR WOMEN'S HEALTH AND WELLNESS; and HOLY SPIRIT HOSPITAL, a nonprofit corporation Defendants PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY Please mazk the docket settled and discontinued with prejudice as to defendants James Downey Long, M.D., Barbara Brandt, CNM, Holy Spirit Hospital, and Spirit Physicians, Inc. d/b/a Center for Women's Health and Wellness. Respectfully submitted 1 John E. Hall, Esquire Eckert Seamans Cherin & ellott LLC U.S. Steel Tower 600 Grant Street, 44a' Floor Pittsburgh, PA 15219 412.566.1915 Attorneys for Plaintiffs CERTIFICATE OF SERVICE I hereby certify that I am this day of March 2004, serving a copy of the foregoing Praecipe to Discontinue 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, First Class Mail postage prepaid, as follows: Craig A. Stone, Esquire Mette, Evans and Woodside 3401 North Front Street P.O. Box 5950 Harrisburg, PA 17110-0950 Sarah W. Arosell, Esquire Thomas Thomas & Hafer 305 North Front Street, 6~h Floor P.O. Box 999 Harrisburg, PA 17108 Jo .Hall