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Home My WebLink About01-05533IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FRANCES GRIMES Plaintiff v. HARRIS SAVINGS BANK, Defendant . No. ®~ -,5.533 C~-~ CIVIL ACTION -LAW JURY TRIAL DEMANDED YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth against you 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 Gaims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a default 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 THIS OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral Service Two Liberty Street Carlisle, Pennsylvania 17013 (717) 249 - 3166 1-800-990-9108 aw oFF~~ES or Are E. Axemxxs, P. Q iwo wes. mnrvxzr s.sccr s. orrice eox asz Yoaa. Pa.uxefln~.wu ~~aoa IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FRANCES GRIMES NO. Plaintiff v. CIVIL ACTION -LAW HARRIS SAVINGS BANK, Defendant :JURY TRIAL LISTED I•IA SIDO DEMANDADO EN LA CORTE. Si usted desea defenderse de las quejas expuestas en las p~ginas siguientes, debe tomar action dentro de veinte (20) dies a partir de la fecha en que recibio la demanda y el aviso. Usted debe presenter comparecencia escrita en persona o por abogado y presenter en la Corte por escrito sus defenses o sus objeciones a las demandas en su contra. Se le avisa que si no se defiende, el caso puede proceder sin usted y la Corte puede decidir en su contra sin mas aviso o notification por cualquier dinero reelamado en la demands o por tualquier otra queja o compensation retlamados por el Demendante. LISTED PUEDE PERDER DlNERO, O PROPRIEDADES U OTROS OERECHOS IMPORTANTES PARA LISTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI LISTED NO TIENE O NO CONOCE UN ABOGADO, VAYA O LLAME A LA OFICINA EN LA DIRECCION ESCRITA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCtA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral Service Two Liberty Street Carlisle, Pennsylvania 17013 (717) 249 - 3166 1 X00-990-9108 aw oFFI~E= of rAns E. Axexxxa, P. Q MARKET STFEET ST OFFICE BOX ss2 Yoae, Paivrvaxcvenu Taos IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FRANCES GRIMES Plaintiff v. HARRIS SAVINGS BANI(, Defendant CIVIL ACTION -LAW JURY TRIAL DEMANDED COMPLAINT 1. The Plaintiff, Frances Grimes, is an adult individual residing at 105 Spring Garden Estates, Carlisle, Pennsylvania 17013. 2. The Defendant, Harris Savings Bank, is a Pennsylvania corporation with an address for service of 2nd and Pine Streets, Harrisburg, Pennsylvania 17101. 3. At all times relevant hereto, the Defendant owned and operated a retail banking branch at 921 Calvary Road, Carlisle, Pennsylvania 17013. 4. On January 31, 2000, Plaintiff was doing business as a business invitee at the aforementioned bank. 5. On January 31, 2000, at approximately 1:30 p.m., the Plaintiff was ww OFFICES OF IALE r'.. AW6TINH, P. C.. TWO WEST MPRHE! STREET POET OFFlCE BO%BSs Yosv, Pzmeanveme vaos onl aas-osoe exiting the bank to return to her car in the parking lot when she slipped and fell on ice, which had accumulated on the sidewalk in hills and ridges so as to unreasonably obstruct travel. 6. As a result of her fall, the Plaintiff sustained serious and permanent injuries. 7. At all times relevant hereto, the Defendant acted through its employees, representatives, and/or servants, and is vicariously liable for the negligence of those individuals or entities. 8. This accident occurred solely as a result of the negligence of the employees, representatives, agents, and/or servants of the Defendant and was due in no manner to any act, or failure to act, on the part of the Plaintiff. 9. The negligence of the employees, representatives, agents, and/or servants of the Defendant consisted of the following: a) Failing to recognize the special element of harm and danger of ice on the sidewalk; b) Permitting or allowing the ice to accumulate on the sidewalk in front of the bank in hills and ridges which unreasonably obstructed travel when the Defendant knew that its patrons and invitees such as the Piaintiff would have to traverse the area; e) Failing to utilize that degree of care required for business invitees such as the Plaintiff by not maintaining the premises in a safe and usable condition; d) Failing to inspect the premises to discover the unsafe and hazardous condition of ice on the sidewalk; e) Failing to warn or protect the Plaintiff from the unsafe and hazardous condition of ice on the sidewalk when the Defendant knew or should known that the Plaintiff would be unable to protect her; EElccs OF IALE F..VAN6TINE, P. C. wE51 MnanEi sireEEi POS> OFFICE aox a52 Yom, Paareen¢~x+w vaoa 2 f) Failing to correct the hazardous and dangerous icy condition that the Defendant knew or should have known existed on the premises: g) Creating or allowing a hazardous condition to exist which the Defendant knew or should have known involved an unreasonable risk of danger to persons such as the Plaintiff who. would not know or have reason to know of the unreasonable risk of harm; h) Failing to carry on the Defendant's activities with reasonable care for the safety of the public; i) Failing to remove the ice from the sidewalk; and j) Failing to mask the icy condition by salt, cinder, or otherwise covering the area to make it safe for use. 10. As a result of the aforesaid negligence, the Plaintiff suffered serious and permanent injuries including but not limited to intertrochanteric fracture of the left hip, contusions, and a severe shock to her nerves and nervous system. 11. As a result of the negligence of the Defendant, the Plaintiff was forced to incur medical bills and expenses for the injuries she has suffered, and she will continue to incur medical expenses in the future. 12. As a result of the negligence of the Defendant, the Plaintiff has undergone, and in the future may undergo, great mental and physical pain and suffering, mental anguish and humiliation, loss of life's pleasures, and a severe limitation in her pursuit of daily activities, all to her great loss and detriment. W oFF EE= of IAie E. Axsxxxz, P. G iW0 WEST MPRHET STFEET POST OFFICE BOX cs2 Yose. Pzxs Taos 3 WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter judgment against the Defendant in an amount in excess of the mandatory arbitration limits. RESPECTFULLY SUBMITTED: LAW OFFICES OF DALE E. ANSTtNE, P.C. Attorx(ey I.D. #38894 Two West Market Street P.O. Box 952 York, PA 17405 (717) 846 -0606 E= of TALE E.vAN9TINE~ P. ri. POST OFFICE BOX 952ET Yoaa, ParxerLV.wu naos vnt eaaasaa 4 I HEREBY VERIFY that the information set forth in the foregoing Complaint 4axe E.rAxemxxxa, P. G Posr orrics~eox aszsr Yosa, Pew. envevls ~1a06 is true and correct to the best of my knowledge, information and belief. I understand that any false statements contained herein are subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: .S~ ~o Frances Grimes 0 ~ ~ ~, ~ ~ ~ ,~ ~ ~ ~ _- U Lj 1 [ ,~ f _ ~~'~ _ ~~i ~. ~.1 ... __~11 ~. G. ^ i ~t i~ v~ Ca) -~ POST & SCHELL, P.C. BY: AMY L. CORYER I.D. # 82718 240 GRANDVIEW AVENUE CAMP HILL, PA 17011 (717) 731-1970 ATTORNEYS FOR DEFENDANT HARRIS SAVINGS BANK FRANCES GRIMES IN THE COURT OF COMMON PLEAS Plaintiff, OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-5533 HARRIS SAVINGS BANK CIVIL ACTION -LAW Defendant. NRY TRIAL DEMANDED TO THE PROTHONOTARY: ENTRY OF APPEARANCE Kindly enter my appearance on behalf of Defendant, Harris Savings Bank, in connection with the above-captioned matter. Respectfully submitted, POST & SCHELL, P.C. DATE: I O l i K~ o f ~~v'~ Gm/a9 AMY L. ORYE ESQUIRE Attorney for Defendant Harris Savings Bank ., CERTIFICATE OF SERVICE I, Kelley Spangler, an employee with the law firm of Post & Schell, P.C., do hereby certify that on the date set forth below, I did serve a true and correct copy of the foregoing document upon the following persons at the following addresses indicated below by sending same in the United States mail, first-class, postage prepaid: Gregory E. Martin, Esquire DALE E..Si~ISTINE, P.C. Two West Market Street P.O. Box 852 York, PA17405 Date: ~ ~ Kel ey Sp r IviaPWJY "`' ~ f9IkL1~6$k'"" Ef'AwiHFYH'C~l&"~M4'k _ _ _ _ _ •~~aya~w.i~ - _ .. _.J.~ ~ C -L; C~ tf) ~?'t U 1 -:,._ - '~ ~ -'G~ - ~ : 4 - i ., , . ~ y- ~ C CS3 SHERIFF'S RETURN - OUT OF COUNTY SASE NO: 2001-05533 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GRIMES FRANCES VS HARRIS SAVINGS BANK R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: HARRIS SAVINGS BANK but was unable to locate Them in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT & NOT ICE On October 9th 2001 this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: So answer - Docketing 18.00 Out of County 9.00 /~ Surcharge 10.00 R. Thomas Kli e Dep Dauphin Co 25.50 Sheriff of Cumber land County .00 62.50 10/09/2001 DALE ANSTINE Sworn and subscribed to before me this /G t" day of ~~„_ 7go~ A.D. Qom, ~ (~_ h~,nn „ p.~ Prothonotary i •. ,,, (1~~.~.t~c~ ~~ ~C~e o~5~eriff Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717)255-2660 fax: (717)255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania Couuty of Dauphin Sheriff's Return No. 2799-T - - -2001 OTHER COUNTY NO. 01-5533 NOTICE & COMPLAINT HARRIS SAVINGS BANK GRIMES FRANCES vs • HARRIS SAVINGS BANK J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy at 1:56PM served the within upon by personally handing to STEPHANIE JACOBS, ASSISTANT MANAGER 1 true attested copy(ies) of the original NOTICE & COMPLAINT and making known to him/her the contents thereof at 2ND & PINE STREETS HBG, PA 17101-0000 DEFENDANT IS NOW WAYPOINT BANK LOCATED AT 235 NORTH SECOND ST., HBG. THE FORMER HARRIS SAVINGS BANK. Sworn and subscribed to before me this 2ND day of OCTOBER, 2001 t, - ~.. ~f~~ PROTHONOTARY AND NOW: October 1, 2001 So Answers, l~~°7~L Sheriff of Dauphin County, Pa. y "~~'" Depu Sher' f Sheriff's Costs: $25.5 PD 10/02/2001 RCPT NO 154845 HAYES l.Ip, O1 5533 civil Now, September 26, 2001 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of ~u~'u' County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~`.~ Sheriff of Cumberland County, PA ~lfffidavat ®f Sea°vace Naw, within upon at by handing to a 20 , at o'clock M. served the and made known to copy of the original the contents thereof. So answers, Sheriff of Sworn and subscribed before ane this day of , 20_ COSTS SERVICE _ MILEAGE _ AFFIDAVIT County, PA POST & $CHELL, P.C. BY: AMY L. CORYER' I.D. # 82718 240 GRANDVIEW AVENUE CAMP HILL, PA 17011 (717)731-1970 ATTORNEYS FOR DEFENDANT WAYPOINT BANK, formerly HARRIS SAVINGS BANK FRANCES GRIMES IN THE COURT OF COMMON PLEAS Plaintiff, OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-5533 HARRIS SAVINGS BANK CIVIL ACTION -LAW Defendant. JURY TRIAL DEMANDED TO: Gregory E. Martin, Esquire DALE E. ANSTINE, P.C. Two West Market Street P.O. Box 852 York, PA 17405 NOTICE TO PLEAD You are hereby notified to file a written response to the enclosed Answer with New Matter within twenty (20) days from service hereof or a judgment maybe entered against you. Date: Iq AMY L. CORYERI, ESQ. Counsel for Defendant Waypoint Bank, formerly Hams Savings Bank POST & SCHELL, P.C. BY: AMY L. CORYER I.D. # 82718 240 GRANDVIEW AVENUE CAMP HILL, PA 17011 (717) 731-1970 ATTORNEYS FOR DEFENDANT WAYPOINT BANK, formerly HARRIS SAVINGS BANK FRANCES GRIMES IN THE COURT OF COMMON PLEAS Plaintiff, OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-5533 HARRIS SAVINGS BANK CIVIL ACTION -LAW Defendant. JURY TRIAL DEMANDED ANSWER OF DEFENDANT WAYPOINT BANK, FORMERLY HARRIS SAVINGS BANK. TO PLAINTIFF'S COMPLAINT WITH NEW MATTER AND NOW, comes Defendant, Waypoint Bank, formerly Hams Savings Bank, by and through its attorney, Post & Schell, P.C., and for its Answer to Plaintiff's Complaint, states as follows: 1. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations and, accordingly, all such allegations are denied. 2. Denied. Harris Savings Bank no longer exists. Its' successor is Waypoint Bank with offices located at 235 N. Second Street, Harrisburg, PA 17101. 3. Denied as stated. Hams Savings Bank is no longer in existence. Furthermore, the corresponding allegation is denied because Plaintiff fails to identify "at all times relevant hereto" with sufficient specificity 4. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations and, accordingly, all such allegations are denied. 5. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations and, accordingly, all such allegations are denied. Furthermore, this allegation contains conclusions of law to which no response is required. 6. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations and, accordingly, all such allegations are denied. Furthermore, the corresponding allegation is denied as a conclusion of law to which no response is required. All allegations of causation and consequential injury are specifically denied as improper legal conclusions and strict proof thereof is demanded at trial. 7. Denied. The corresponding allegation is denied as a conclusion of law to which no response is required. 8. Denied. The corresponding allegation is denied as a conclusion of law to which no response is required. All allegations of causation and consequential injury are specifically denied as improper legal conclusions and strict proof thereof is demanded at trial. It is specifically denied that Defendant was negligent. To the contrary, Defendant at no time was negligent and at all times acted completely in accordance with accepted standards of caze consistent with standards of the commurrity. 9. Denied. The corresponding allegations aze denied as conclusions of law to which no response is required. It is specifically denied that Defendant was negligent. To the contrary, Defendant at no time was negligent and at all times acted completely in accordance with accepted standards of care consistent with standards of the community. 10. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations and, accordingly, all such allegations are denied. Furthermore, the corresponding allegation is denied as a conclusion of law to which no response is required. All allegations of causation and consequential injury are specifically denied as improper legal conclusions and strict proof thereof is demanded at trial. 11. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations and, accordingly, all such allegations are denied. Furthermore, the corresponding allegation is denied as a conclusion of law to which no response is required. All allegations of causation and consequential injury are specifically denied as improper legal conclusions and strict proof thereof is demanded at trial. 12. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations and, accordingly, all such allegations are denied. Furthermore, the corresponding allegation is denied as a conclusion of law to which no response is required. All allegations of causation and consequential injury are specifically denied as improper legal conclusions and strict proof thereof is demanded at trial. WHEREFORE, Defendant, Waypoint Bank, formerly Hams Savings Bank, respectfully requests that this Honorable Court grant judgment in its favor and against the Plaintiff on the Complaint, together with costs and expenses. NEW MATTER The Defendant hereby raises the following New Matter: one through twelve of the foregoing Answer as if fully set forth herein. 14. The Plaintiff may have failed to state a cause of action upon which relief can be granted. 15. The statute of limitations may have expired prior to the initiation of this lawsuit. 16. Defendant was not negligent. 17. The Defendant's agents, servants and/or employees were not negligent. 18. Any acts or omissions of the Defendant and/or the Defendant's agents, servants and/or employees alleged to constitute negligence were not substantial causes or factors of the subject incident and/or did not result in the injuries and/or losses alleged by the Plaintiffs. 19. The incident and/or damages described in Plaintiffs Complaint may have been caused or contributed to by the Plaintiff. 20. Plaintiffls negligence exceeds that of Defendant, if such is proven. 21. The negligent acts or omissions of other individuals and/or entities may have constituted intervening, superseding causes of the damages and/or injuries alleged to have been sustained by the Plaintiff. 22 The Plaintiff may have assumed the risk. 23. The Plaintiff may have been contributorily negligent. 24. The incident, injuries and/or damages alleged to have been sustained by the Plaintiff were not proximately caused by Defendant. 25. Plaintiff may not have properly mitigated her damages. 26. The peril or danger of which Plaintiff complains, to the extent it existed, which Defendant denies, was open and obviously known to Plaintiff, Frances Grimes, who nevertheless conducted herself in such a manner as to expose herself to said peril or danger. 27. Plaintiff failed to properly observe as she was proceeding. 28. Plaintiff may have failed to keep a proper lookout as she was proceeding. 29. Plaintiff had a choice of two distinct paths, one of which was perfectly safe and another which was obviously subject to dangers and risks. Plaintiff, voluntarily and knowingly choosing the dangerous path, is contributorily negligent as a matter of law. WHEREFORE, Defendant, Waypoint Bank, formerly Hams Savings Bank, respectfully requests that this Honorable Court grant judgment in its favor and against the Plaintiff on the Complaint, together with costs and expenses. Respectfully submitted, POST & SCHELL, P.C. Date: AMY L. CORYER;~ESQUIIZE Counsel for Defendant Waypoint Bank, formerly Hams Savings Bank .. ~; VERIFICATION I, Richard C. Ruben, Executive Vice President of Waypoint Bank, do hereby swear and affirm that the facts and matters set forth in the Answer and New Matter Pursuant are true and correct to the best of my knowledge, information and belief. The undersigned understands that the statements made therein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. DATE: ~~ d 6 Richard C. Ruben I, Candice M. Baker, an employee with the law firm of Post & Schell, P.C., do hereby certify that on the date set forth below, I did serve a true and correct copy of the foregoing document upon the following persons at the following addresses indicated below by sending same in the United States mail, first-class, postage prepaid: Gregory E. Martin, Esquire DALE E. ANSTINE, P.C. Two West Market Street P.O. Box 852 York, PA17405 Date: /~ / //!• _ Candice M. Baker r ~-: _ --, ~., „y,; ; ; _~_- cF:' " ~ ~. -; ~.. r: ; - ,, ~=~: ' C: .. , =t '~ :.? r., .~ B~ '~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FRANCES GRIMES Plaintiff v. HARRIS SAVINGS BANK Defendant NO: 01-5533 Civil Action -Law JURY TRIAL DEMANDED PLAINTIFFS' REPLY TO NEW MATTER OF DEFENDANT 13. Paragraph 13 is an incorporation paragraph to which no responsive pleading is required. To the extent that such a responsive pleading is required, it is denied and strict proof thereof is demanded at trial. 14. - 29. Denied. Paragraphs 14 through 29 state a conclusion of law to which no responsive pleading is required. To the extent that such a responsive pleading is required, it is denied and strict proof thereof is demanded at trial. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter judgment against the Defendants in an amount in excess of the mandatory arbitration limits. RESPECTFULLY SUBMITTED: LAW OFFICES OF DALE E. ANSTINE, P.C. .1L8 B. ANBT]NN. P. C. Yaea. Pervxsvtv~xu z~>o05 Gregefy E. Martin, Esquire Attorney I.D. #38894 Two West Market Street P.O. Box 952 York, PA 17405 (717) 846 - 0606 • , I HEREBY VERIFY that the information set forth in the foregoing Reply to New Matter is true and correct to the best of my knowledge, information and belief. I understand that any false statements contained herein are subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: ~iLay,~-,c~e~~~ Frances Grimes uw ovviccs ov IACS E. AxexxxE, P. G nrekrr s.Aeer vosr ovrice aox ssz Yom, Pxmaenveeru ~~aoa I~ 'a CERTIFICATE OF SERVICE AND NOW, this 14th day of November, 2001, I, Gregory E. Martin, Esquire, a member of the Law Offices of Dale E. Anstine P.C., hereby certify that I have, this date, served a copy of the within and foregoing document by first class United States Mail, postage, pre-paid, addressed to the party or attorney of record as follows: Amy L. Coryer, Esquire Post & Schell, P.C. 240 Grandview Avenue Camp Hill, PA 17011 Respectfully submitted, LAW OFFICES OF DALE E. ANSTINE, P.C. BY: Gregory E. Martin, Esquire I.D. NO: 38894 Two West Market Street P.O. Box 952 York PA 17405 (717)846-0606 •aa E. Axsm~xa. P. C. -. ~~ ~ ~ ~ c. .... -, ~. :~ ~; n 21' _ . {.. _,.~ r~ t - Wi =- ~ _ _ ~ l.i ..~ . ~ `` ~~~ ..a _ '^'~L ) C ~ J C,? ~~~ ~ ., ~ ~} ~ -G t31 q A POST &SCHELL, P.C. BY: AMY L. CORYER I.D. # 82718 240 GRANDVIEW AVENUE CAMP HILL, PA 17011 (717) 731-1970 ATTORNEYS FOR DEFENDANT WAYPOINT BANK, formerly HARRIS SAVINGS BANK FRANCES GRIMES IN THE COURT OF COMMON PLEAS Plaintiff, OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-5533 HARRIS SAVINGS BANK CIVIL ACTION -LAW Defendant. NRY TRIAL DEMANDED PRAECIPE FOR WRIT TO JOIN ADDITIONAL DEFENDANT TO THE PROTHONOTARY: Kindly issue a Writ to G. Edward Knisely as an additional defendant in the above-captioned matter. Respectfully submitted, POSTn& SCHELnL, P. C. Date: I ~~~pj- BY~n,u ~ ('~, AM L. C ER, ESQ. Attorney for Defendant Waypoint Bank, formerly Hams Savings Bank Y CF,~TIFICATF OF CEI2VICF. I, Candice M. Baker, an employee with the law firm of Post & Schell, P.C, do hereby certify that on the date set forth below, I did serve a true and correct copy of the foregoing document upon the following persons at the following addresses indicated below by sending same in the United States mail, first-class, postage prepaid: Gregory E. Martin, Esquire DALE E. ANSTINE, P.C. Two West Market Street P.O. Box 852 York, PA17405 Date:~~~ Candice M. Bak ,v ~ : ; -YgknNM_ ~ -;. u~: ~..__.2 Amt 7 itiKi`~9llli I~1 ~'~ .., _ ^7 'f~ _ _ !_..; ~ <.: , _ ~~~ t. .,, ~ - __ ~~^ _.~ C.; ~~' v ~.. W U _~ ~-. y -G t~3 -~ -p~.1y.5~ .Jl ~ ~ ~ r i POST & SCHELL, P.C. BY: AMY L. CORYER I.D. # 82718 240 GRANDVIEW AVENUE CAMP HILL, PA 17011 (717) 731-1970 ATTORNEYS FOR DEFENDANT WAYPOINT BANK, formerly HARRIS SAVINGS BANK FRANCES GRIMES IN THE COURT OF COMMON PLEAS Plaintiff, OF CUMBERLAND COUNTY, PENNSYLVANLA v. NO. 01-5533 HARRIS SAVINGS BANK CIVIL ACTION -LAW Defendant. JURY TRIAL DEMANDED WRIT OF SUMMONS TO JOIN ADDITIONAL DEFENDANT TO: G. Edward Knisely 801 Lindsey Road Carlisle, PA 17013 You are hereby notified that Defendant, Waypoint Bank, formerly Harris Savings Bank, has commenced an action against you. Date: Prothonotary Cumberland County, ss The Commonwealth of Pennsylvania to G. Edward Knisely (Name of Addirtional Defendant) You are notified that Harris savings sank (Name (s) of Defendant (s) ) has (have) joined you as an additional defendant in this action, which you are re- quired to defend. Date De~emhPr 5, ~nf11 Curtis R. Long Rrat4xottcrtary ~~, ///IOC, n , ~. /I~rY. ~'~ - - (~~) G. Edward Knisely 801 Lindsey Road Carlisle, PA 17013 a a H~nNro~ C ~ ~ ~ ~ rNF ~wxH m C y,y ~~Nan~~,o 0 H °'orom Nm Z y ~E N~ ~ c ~ r -y :~ ~ ~ o '~7 C='7 trJ z d~ yz ~w 0 r N r N R+ N ~ °a o P. r w Y a ~I o•~ ,~ ~, .. s ~' S 0 Iw ~n n r_~ 8a i SHERIFF'S RETURN - REGULAR CASE NO: 2001-05533 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GRIMES FRANCES VS HARRIS 5AVINGS BANK JASON MORAL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT TO ADD'L DEFEN. was served upon KNISELY G EDWARD the ADD'L DEFENDANT, at 1546:00 HOURS, on the 10th day of December 2001 at 801 LINDSEY ROAD CARLISLE, PA 17013 by handing to G EDWARD KNISELY a true and attested copy of WRIT TO ADD'L DEFEN. together with and at the same time directing His attention to the contents thereof Sheriff's Costs: Docketing 18.00 Service 3.25 Affidavit .00 Surcharge 10.00 .00 31.25 Sworn and Subscribed to before me this J2 `=- day of ~P~ o2tsv 7 A . D . ~,... Q . r1~. ,~OoT ~-Prothonotary ~ So Answers: .~~~ R. Thomas Kline 12/11/2001 POST & SCHELL By: tc~.~ D puty Sheriff ~,..~. ~~: CERTIFICATE PREREQIIISZTE TO SERVICE OF A SIIBPOENA PURSIIANT TO RULE 4009.22 IN THE MATTER OF: FRANCES GRIMES -VS- HARRIS SAVINGS BANK COURT OF COMMON PLEAS TERM, CASE N0: 01-5533 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of AMY L. CORYER, 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: 03/19/2002 S on be}~a f of L OCR ~ ~ IIIR~E Attorn y for DE NDANT DE11-323458 8 6 5 1 1- L 0 1 C OMNIO NWEAL T H O F P E NN S YLVAN 2A COUNT Y O F CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS FRANCES GRIMES -VS- HARRIS SAVINGS BANK T'O SSRVE A BELVEDERE MEDICAL CENTER MEDIGAL RECORDS DR. LARRY THOMPSON MEDICAL RECORDS DANIEL P. HELY, H.D. MEDICAL RECORDS ANDY SLIEGAR EMPLOYMENT T0: GREGORY MARTIN ESQ. TERM, CASE N0: 01-5533 MCS on behalf of AHY L. CORYER, ESQBIRH intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records mar be ordered at your ezpense by completing the attached counsel card aad returning same to MCS or by contacting our local MCS office. DATE: 02J26/2002 CC: AMY L. COYER, ESQDIRE - 626-86380 JANEAN NILSON - 9380009309001 Any questions regarding this matter, contact MCS on behalf of AMY L. CORYER, ESQIIIRE Attorney for DEFENDANT THE MCS GROIIP INC. 1601 MARKET STREET /800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-179547 8 6 5 1 1- C 0 2 COMMONWEALTH OF PEN\tSYLVpNIA COUNTY OF CUMBERL~\*D PRANCES GRIMES VS • Fi1eNo. nt-55'1't HARRIS SAVINGS BANK SUBPOENA TO PRODUCE DOCUME\TS OR THIV GS FOR DISCOVERY PURSUAAZ' TO RULE 4009 TO: CUSTODIAN OF RECORDS FOR: BELVIDRE MEDICAL CENTER (Name of Person ae eager) Within n.e-ry• f7D) days aher service of this suSEE A'1"1'ACHED rdered by ttse court to produce the following documents or things: ll MCS (;RnTiP TNf._. 7Finl MARKET RT_ !lROn PHTT.A_.PA 1910't (Addnssj You msy deiia•er or mail legible copin of the doeumenn or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the add~t listed above. You haa•e ehe right to seek in advance, t:te -essanabfe cost of prepuing the eopin m producing t9te tttings stught. If you fail ro -oduce the dxumenp or things required by this subpoena, wit3sin twenty (~) days aher its sen•iee, the party sen•ing tiffs subpoena may seek a court order compelling you to comply with r THIS SLBPOE*IA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: 1.A.'v(E: AMY L. CORYER. ES ADDRESS: 240 CRANDVIEW AVE. CAMP HILL, PA 17011 TELEPHO\=• 215-246-0900 SZ;PRE~iE C0~'RT ID +-: ATTOR\EY FOR; DEFENDANT DATE: ~ ~ < • n ~ ~ ~ 9t ~rT- Seal of the Cottrt (E.'f. i/9~ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: BELVEDERE MEDICAL CENTER 850 WALNUT BOTTOM ROAD CARLISLE, PA 17013 RE: 86511 FRANCES GRIMES INCLUDING ANY AND ALL RECORDS FROM: DR. HOLLEN, DR. POTTER AND DR. JOSEPH CAMPBELL 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 :FRANCES GRIMES 105 SPRING GARDEN ESTATES, CARLISLE, PA 17013 Social Security ~#: 185-26-1268 Date of Birth: 10-22-1935 SU10-358328 8 6 5 1 1- L 0 1 CERTIFICATE PREREQIIISITE TO SERIIYCE OF A SUBPOENA PURSIIANT TO RULE 4009.22 IN THE MATTER OF: FRANCES GRIMES -VS- HARRIS SAVINGS BANK COURT OF COMMON PLEAS TERM, CASE N0: 01-5533 As a prerequisite to service of a subpoe^.a for documents and things pursuant to Rule 4009.22 MCS on behalf of AMY L. CORYER, 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: 03/19/2002 AMY L. CORYER, ESQUIRE Attorney for DEFENDANT DEll-317306 5 6 5 1 1- L 0 2 COA4A4ONWEALTH OF PENNSYLVANIA COUNT Y O F C UMB E RLAND IN THE MATTER OF: COURT OF COMMON PLEAS FRANCES GRIMES -VS- HARRIS SAVINGS BANK OF BELtYEDERE MEDICAL CENTER DR. LARRY TAOMPSON DANZEL P. RELY, K.D. ANDY SWEGAR T0: GREGORY MARTIN ESQ. TO MBDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS EMPLOYMENT TERM, CASE N0: 01-5533 MCS on behalf of AMY L. CORYER, ESQIIIRE 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 pour expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/26/2002 MCS on behalf of CC: AMY L. CORYER, ESQDIRE - 626-86380 JANEAN WILSON - 9380009309001 Any questions regarding this matter, contact AMY L. CORYER, ESQDIRE Attorney for DEFENDANT THE MCS GROIIP INC. 1601 MARRBT STREET /800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-179547 8 6 5 1 1- C 0 2 COMMONWEALTH OF PEV\rSYLVANIA COUNTY OF CUMBERL.A_VD FRANCES GRIMES VS • File \o. 01 -s577 HARRIS SAVINGS BANK T0: CUSTODIAN OF RECORDS FOR: DR. L~,RRY THOMPSON (Kane of Pmon or:a+arr) Within rwer• (:D) days after service of this suSEE ATTACHED rdered by the court ro produce the fallowing documents or things: at MCC gROTTP TNC.. 16(11 MARKRT RT_.4R(10 PHTT.A..PA 19107 IAddresq You mn• deih~er or mail legible copies of the doeume,tra or produce ehirtgs tergaested by this subpoena. together with the certificate of compliance, ro the patty making this request at the address Iis;tad above. You has•e the right to seek in ads•ance. the seasonable cost of preparing the copies ar producing the thing fought. It ~•ou Eail ro roduce the documents or things required by this subpoena, within twenty (~) davs after its sen•ice, the party sen•ing this subpoena may seek a court order compelling you ro comply with is THIS SLBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: ~,4,etE; AMY L. CORYER .4DDRE55c 240 GRANDVIEW AVE. CAMP HILL, PA 17011 TELEPHOX=• 215-246-0900 SLPKEAtE COtr7t? ID !: ATTORNEY FOR DEFENDANT DATE: Seal of the Court (.ff. i/91 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. LARRY THOMPSON 1 TYLER COURT CARLISLE, PA 17013 RE: 86511 FRANCES GRIMES 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 :FRANCES GRIMES 105 SPRING GARDEN ESTATES, CARLISLE, PA 17013 Social Security #: 185-26-1268 Date of Birth: 10-22-1935 SU10-357984 8 6 5 1 1- L 0 2 CERTIFICATE PREREQIIISITE TO SERVICE OF A SUBPOENA PIIRSIIANT TO RIILE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS FRANCES GRIMES TERM, -VS- CASE N0: 01-5533 HARRIS SAVINGS BANK As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of AMY L. CORYER, 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: 03/19/2002 AMY L. CORYER, ESQUIRE Attorney for DEFENDANT DE11-317307 8 6 5 1 1- L 0 3 C ONIl~20 NWEAL T H O F P E NN S YLVAN IA COUNTY OF CT7MBERLADTD IN THE MATTER OF: COURT OF COMMON PLEAS FRANCES GRIMES -VS- HARRIS SAVINGS BANK TO BELVEDERE MEDICAL CENTER DR. LARRY TAOMPSON DANIEL P. RELY, K.D. ANDY SWEGAR T0: GREGORY MARTIN ESQ. MBDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS EMPLOYMENT TERM, CASE N0: 01-5533 MCS on behalf of AMY L. CORYER, ESQIIIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your ezpense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. .DATE: 02~26~2002 CC: AMY L. CORYER, ESQIIIRE - 626-86380 JANEAN WILSON - 9380009309001 Any questions regarding this matter, contact MCS on behalf of AMY L. CORYER, ESQIIIRE Attorney for DEFENDANT THE MCS GROIIP INC. 1601 MAR&ET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-179547 8 6 5 1 1- C 0 2 COMMONWEALTH OF PEA*SYLVANIA COUNTY OF CUMBERL.A.\'D FRANCES GRIMES VS • File \a. m-ss99 HARRIS SAVINGS BANK , SUBPOENA TO PRODUCE DOCUME\TS OR THINGS FOR DISCOVERY PURSUA.\T TO RULE 4009 ~~ ~7; CUSTODIAN OF RECORDS FOR: DR. D°NIEL RELY I'~ame of Person or ssttin) N'i;hin ewe--r (:D) days aher service of this suSEE ATTACHED rdered by ttte court to produce the following documents or things: at MCS (:Rn1iP TNC.. 16n1 MARKET ST_ _IkR00. PHTT.A .PA 19109 (Address) You may deiit•e: or mail legible copies of the documa:tts ar pmduee things eequened by this subpoena, together with the certificate of compliance, to the psaev, staking this request at the address listed above. Yau have the right to seek in advance, t:te reasonable Lost of preparing the copies or producing the thing sought. If you Eail ro -oduce the documents or things required by this subpoena, wit!-.in ewenry (~) days after its sen•ice, the party sen•ing tiffs subpoena may sack a court order compelling you ro comply with is THIS SLBPOE*1A WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: \A.4tE: AMY_ L. CORYER .4DDRE54: 240 GRANDVIEW AVE. CAMP HILL, PA 17011 TELEPHO~=• 215-246-0900 SI+PREAIE COIiRT ID *: ATTOR.~EY EOI~; DEFENDANT DATE ~ ~15~.~ ~g ott ~U~e Seal of the Court (=ff. i/91 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DANIEL P. HELY, M.D. 1 DUNWOODY DRIVE CARLISLE, PA 17013 RE: 36511 FRANCES GRIMES 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 :FRANCES GRIMES 105 SPRING GARDEN ESTATES, CARLISLE, PA 17013 Social Security #: 185-26-1268 Date off Birth: 10-22-1935 SU10-357986 8 6 5 2 1- L 0 3 CERTIFICATE PREREQUISITE TO SERVICE OF A SIIBPOENA PIIRSIIANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS FRANCES GRIMES TERM, -VS- CASE N0: 01-5533 HARRIS SAVINGS BANK As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of AMY L. CORYER, 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 abjection 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: 03(19/2002 AMY L. CORYER, ESQUIRE Attorney for DEFENDANT DE11-317308 8 6 5 1 1- L 0 4 CONIPQONWEALTH OF PENNSYLVANIA COUNTY O F CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS FRANCES GRIMES -VS- HARR25 SAVINGS BANK OF BELVEDERE MEDICAL CENTER DR. LARRY THOMPSON DANIEL P. HELY, M.D. ANDY SWEGAR T0: GREGORY MARTIN FSQ. TO FbDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS EMPLOYMENT TERM, CASE N0: 01-5533 MCS on behalf of AMY L. CORYER, 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 in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your ezpense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/26/2002 MCS on behalf of CC: AMY L. CORYER, ESQIIIRE - 626-86380 SANEAN GILSON - 9380009309001 Any questions regarding this matter, contact AMY L. CORYER, ESQIIIRE Attorney for DEFENDANT THE MCS GROIIP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-179547 8 6 5 1 1- C 0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERL.~\'D FRANCES GRIMES VS • Fill VO. O1 -5544 HARRIS SAVINGS BANK SUBPOENA TO PRODUCE DOCUME\Z'S OR THLVGS FOR DISCOVERY PURSUA_\T TO RULE 4009.E TQ; CUSTODIAN OF RECORDS FOR: ANDY SWrGAR (Name of Penoe or Farah) N'i:hin rwe-~• (.O) days aher sen•ice of this suSEE ATTACHED rdered ~ ~! court to produce the following documents or things: at MfS GR(1TiP TNC_ _ 7 F,M MARKRT RT. .lkRM. PHT7 A PA 1 9104 (Address) Yau tnsy det7r•er or mail legible copies of the docume: is or produce ehisegs eegne:sted by this subpoena, eogether with the certificate o: compliance, ro the party making this request ar the addtlsa Iixed above. You haa•e the right ro seek in adt anee, the tasonable Lost of preparing the copies or producing the ettitsgs sought. If you fail ro roduce the documenb or things required by this subpoena, within twenty ('~) days after its sen•ice. the pam+ sen•ing ttis subpoena may seek a court order compelling you to costply with r_ THIS SLBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: \.4ME: AMY L. CORYER. E ADDRESS: 240 GRANDVIEW AVE. CAMP HILL, PA 17011 TELl:PEIOX=• 215-246-0900 SCPRE~iE COUAT ID tt: ATTOR\EY fOR DEFENDANT DAME: ,~~ l9t aoo~., Seal of the Cotart (=ff.i/9i~ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ANDY SWEGAR COLLEGE & LOUTHER STREETS CARLISLE, PA 17013 RE: 86511 FRANCES GRIMES INCLUDING .IOB APPLICATION, AND REVIEWS, ETC. Any and all employment records, files and memorandums, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee. Dates Requested: up to and including the present. Subject :FRANCES GRIMES 105 SPRING GARDEN ESTATES, CARLISLE, PA 17013 Social Security #: 185-26-1268 Date of Birth: 10-22-1935 SU10-357988 8 6 5 1 1- L 0 4 ~, `- ~ - =; ~T ~ ~ ~ - _ - -- ,.~ _ , :_ - :' --, - t_, ~., - , ~, t , a <~ -~ PRAECIPE FOR LISTING CASE POR TRIAL (Must be typewritten and suYxnitted in duplicate) TO THE PROTHON:YPAAY OF CLY~IDERLAND COUNTY Please list the following case: (Check one) ( ~O for JURY trial at the next term of civil court. ( ) for trial without e jury. CAPTION OF CASE (entire caption must tie stated in full) (chec;c one) Frances Grimes (X) Civil Action - Law v. Harris Savings Bank v. G. Edwax~.Knisely ( ) Appeal from Arbitration ( ) (other) T1'le trial list w111 'oe called on and October ~, 2002 Trials commence on November 2002 Pretrial5 will be held OYprtnhar '~@~ 700 (arie£s are due 5 days before pretrials.) (The party listing this case for trial shall provide forthwith a Copy of the praecipe to all Counsel, pursuant to local Rule 214.1.) No. 01 Civil 5533 19 Indicate the attorney who will try cnee for the party who files this praecipe: Gregory E Martin, Esa P O Box 952 York PA 1 405 Indicate trial counsel for other parties if known: John R_ Canavan_ Esquire 240 Cr-.,A~;A~ n r v+ii nn i~n77 Thie case is ready for trial. Signed: Print GreQOry E qr. Iaatee July 2002 Attorney for: Plaintiff ' c, , ~ ~,. ~~ ~~ 4 l j. ~.) rI ~ v~ 1 ,~ U ' .1. _.. (/- i - ~ ~ l ' v~~. :-~1 1 ~`-. ny ~ ~J ~ 4' J . ~ a EeY . 4. Frances Grimes : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA V Harris Savings Bank V G. Edwazd Knisely NO. 01-5533 CIVIL TERM ORDER OF COURT AND NOW, October 8, 2002, by agreement of counsel, the above captioned case is hereby settled from the November 4, 2002 trial term. By the Court, Ge •ge y o r Gregory E. Martin, Esquire For the Plaintiff John R. Canavan, Esquire For the Defendant G. Edward Knisely Defendant Court Administrator ~~ /b. a9-dz' ld _ "F°`" 'drad~m~&rc-,W'..'o-~ra~~.e~:"tiTws~e(~ks,ns::v~6 itw.ra. :.te;.eaullS~ar ma.~re~'i 3~t~~ir. ai6amxx. .._. t r ~'l'/I;;/i7, "-! it ~; -:7,ri,l -, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Frances Grimes No: 01-5533 v Harris Savings Bank CIVIL ACTION -LAW v. G. Edward Knisely PRAECIPE TO REMOVE To the Prothonotary: (X) Please mark the above captioned action SETTLED AND SATISFIED OR OPlease mark the above captioned judgment or lien settled and satisfied. E. Martin, Esquire rney for the Plaintiff No: 38894 CC: Jack Canavan, Esquire PLEASE ISSUE A CERTIFICATE OF SETTLEMENT AND SATISFACTION TO ATTORNEY MARTIN. ALB E. ANNTINH. P. C. ..o.=x...uo smee. Yo[[oP[xxsxxv[xu'1'/OOE I c; €= ~, -. Fil.", • T t "_l" ~~- .' (- ~~ .~ V f,3 -~ ~~