HomeMy WebLinkAbout99-03330i
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DIANE M. NIGHBERT, : IN THE COURT OF COMMON PLEAS
Plaintiff : OF CUMBERLAND COUNTY
V.
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
NANCY BERGERT, individually and as a
member and managing partner of
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
WILLIAM T. WRIGHT, II, individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
HASBROUK S. WRIGHT, JR., individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
JOHN DOE, property owner of 1521 Cedar
Cliff Drive, Camp Hill, PA; and
KEYSTONE SPINE CENTER, INC.,
Defendants
NO. J?-2330 LC(i"?7
CIVIL ACTION - LAW
PRAECIPE FOR A WRIT OF SUMMONS
To The Prothonotary:
Please issue a Writ of Summons in the above captioned matter to each of the following:
Cliffdale Associates; a Pennsylvania Partnership, 1010 Brentwater Road, Camp Hill, PA
17011;
Nancy Bergert, individually and as a member and managing partner of Clif(ddale Associates, a
Pennsylvania partnership, 1010 Brentwater Road, Camp Hill, PA 17011;
William T. Wright II, individually and as a member of Cliffdale Associates, a Pennsylvania
partnership, 1010 Brentwater Road, Camp Hill, PA 17011;
Hasbrouk S. Wright, Jr., individually and as a member of Cliffdale Associates, Inc., a
Pennsylvania partnership, 1010 Brentwater Road, Camp Hill, PA 17011;
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John Doe, Property Owner, 1521. Cedar Cliff Drive, Camp Hill, PA 17011; and
Keystone Spine Center, Inc., a Pennsylvania corporation,
1521 Cedar Cliff Drivo, Camp Hill, PA 17011
BY: Andrea C Jacobs , Esq.
JACOBSEN & I S
52 East High Street
Carlisle, PA 17013
Telephone: (717) 249-0427
Fax: (717) 249-8427
Attorney No. 20052
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Commonwealth of Pennsylvania
County of Cumberland
Diane M. Nighbert
VS.
Cliffdale Associates, a Pennsylvania
Partnership; and
Nancy Bergert, William T. Wright, II,
Hasbrouk S. Wright, Jr.
Individually and as members of
Cliffdale Associates, a
Pennsylvania Partnership; and
Court of Common Pleas
John Doe; and No. __99-3330 Ci-v_il___________________
l9
Keystone Spine Center, Inc.
In __ Ciy_il Action ---Law
To _jUiffdale lAssaaiates,.-a.J?ennsylvania Partnership et. al,(see attached)
You are hereby notified that
-- - Diane M_- Nighbert ----- --------------------------- - ---------------
the Plaintiff has commenced an action in ------------ Ci`cil.Action-__J,aw-______-
against you which you are required to defend or a default judgment may be entered against you.
(SEAL)
Curtis R. Lon
--- - ----- 9 ---------------------------
Prothonotary
Date -- 214UP-Ra------------------ 1992- By ---J?A - --?`-`X??-
---------
Deputy
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Please issue a Writ of Summons in the above captioned matter to each of the following:
Cliffdalo Associates; a Pennsylvania Partnership, 1010 Brentwater Road, Camp Hill, PA
17011;
Nancy llorgort individually slid as a member and "tans in
Pennsylvania partnership, 1010 Brentwater Road, Camp HIP p A 17011CIilfdale Associates, a
William T. Wright If. individually and as n ntnntbor of Cliffdale Associatos, a Pennsylvan ia
partnership. 1010 13re rentwaler Road, Camp Hill, PA 17011;
Hasbrouk S. Wright, Jr., individually and as a member of Cliffdale Associates, Inc.,
"oil naaylvailia partnership, 1010 Brentwater Road, Camp Hill, PA 17011; a
John Doe, Property Owner, 1521 Cedar Cliff Drive, Camp Hill, PA 17011; and
Keystone Spine Center, Inc., a Pennsylvania corporation,
1521 Cedar Cliff Drive, Camp Hill, PA 17011
I`
ALL ^,
i
j BY: Andrea C Jacobs I, Esq.
+ JACOBSEN & M?yl ,S
52 East High Street
Carlisle, PA 17013
Telephone: (717) 240.0427
Fax: (717) 249-8427
Attorney No. 20952
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DIANE M. NIGHBERT,
Plaintiff
V8.
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
NANCY BERGERT, WILLIAM T.
WRIGHT, II, HASBROUK S. WRIGHT,
JR., Individually and as members
of Cliffdale Associates, a
Pennsylvania Partnership; and
JOHN DOE; and KEYSTONE SPINE
CENTER, INC.
Defendants
No. 99-13.0-Civil
qq-33 0
JURY TRIAL DEMANDED
Type of Pleading:
PRAECIPE FOR ENTRY
OF APPEARANCE
Filed on Behalf of:
DEFENDANT, KEYSTONE
SPINE CENTER, INC.
Counsel of Record
for this Party:
MARY LOU MAIERHOFER, ESQ
MEYER, DARRAGH, BUCKLER,
BEBENEK & ECK, PLLC
120 Lakemont Park Blvd.
Altoona, PA 16602
(814) 941-4600
I.D. #62175
MLM/vtd/MUBENE-99801
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
DIANE M. NIGHBERT,
Plaintiff
VS.
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
NANCY BERGERT, WILLIAM T.
WRIGHT, II, HASBROUK S. WRIGHT,
JR., Individually and as members
of Cliffdale Associates, a
Pennsylvania Partnership; and
JOHN DOE; and KEYSTONE SPINE
CENTER, INC.
Defendants
No. 49-3-3_ Civil
C)Q-333p
JURY TRIAL DEMANDED
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter the appearance of MARY LOU MAIERHOFER, ESQUIRE,
of MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC, as Counsel of
Record on behalf of Defendant, Keystone Spine Center, Inc., in the
above-captioned matter.
MEYER, DARRAGH, BUCKLER,
BY:
& ECK, PLLC
,'nW4 WV ;Y.Y\Vi u?\, uV?V YI\u
65 for Defendant,
Keystone Spine Center, Inc.
120 Lakemont Park Boulevard
Altoona, PA 16602
(814) 941-4600
I.B. #62175
DATE: June 22. 1999
MLM/Vtd/MUEENE-99801
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DIANE M. NIGHBERT,
Plaintiff
VS.
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
NANCY BERGERT, WILLIAM T.
WRIGHT, II, HASBROUK S. WRIGHT,
JR., Individually and as members
of Cliffdale Associates, a
Pennsylvania Partnership; and
JOHN DOE; and KEYSTONE SPINE
CENTER, INC.
Defendants
No. .99 Bae Civil
99 -333 d
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
I, Mary Lou Maierhofer, Esquire, of the law firm of MEYER,
DARRAGH, BUCKLER, BEBENEK & ECK, PLLC, hereby certify that a true
and correct copy of the Praecipe for Entry of Appearance was served
this 22nd day of June, 1999, by mailing same First Class United
States mail, postage prepaid, addressed as follows:
Andrea C. Jacobsen, Esquire Cliffdale Associates
JACOBSEN & MILKES 1010 Brentwater Road
52 E. High Street Camp Hill, PA 17011
Carlisle, PA 17013
Nancy Bergert
Cliffdale Associates
1010 Brentwater Road
Camp Hill, PA 17011
Hasbrouk S. Wright, Jr.
Cliffdale Associates
1010 Brentwater Road
Camp Hill, PA 17011
MEYER,
BY:
William T. Wright, II
Cliffdale Associates
1010 Brentwater Road
Camp Hill, PA 17011
John Doe, Property Owner
1521 Cedar Cliff Drive
Camp Hill, PA 17011
,/5uc7LER, BEBENEK & ECK, PLLC
! \
Counsel for Def ndant,
Keystone Spine Center, Inc.
120 Lakemont Park Boulevard
Altoona, PA 16602
(814) 941-4600
I.D. )#62175
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DIANE M. NIGHBERT,
Plaintiff
Vs.
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
NANCY BERGERT, WILLIAM T.
WRIGHT, II, HASBROUK S. WRIGHT,
JR., Individually and as members
of Cliffdale Associates, a
Pennsylvania Partnership; and
JOHN DOE; and KEYSTONE SPINE
CENTER, INC.
Defendants
No. 99-930 Civil
. ?/?-333p
JURY TRIAL DEMANDED
Type of Pleading:
PRAECIPE FOR RULE
TO FILE COMPLAINT
Filed on Behalf of:
DEFENDANT, KEYSTONE
SPINE CENTER, INC.
Counsel of Record
for this Party:
MARY LOU MAIERHOFER, ESQ.
MEYER, DARRAGH, BUCKLER,
BEBENEK & ECK, PLLC
120 Lakemont Park, Blvd.
Altoona, PA 16602
(814) 941-4600
I.D. 462175
MWVtd/MUBENE•99801
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DIANE M. NIGHBERT,
Plaintiff
VS. No. 99-330 Civil
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and JURY TRIAL DEMANDED
NANCY BERGERT, WILLIAM T.
WRIGHT, II, HASBROUK S. WRIGHT,
JR., Individually and as members
of Cliffdale Associates, a
Pennsylvania Partnership; and
JOHN DOE; and KEYSTONE SPINE
CENTER, INC.
Defendants
PRAECIPE FOR RULE TO FILE COMPLAINT
TO THE PROTHONOTARY:
Please enter a Rule upon the Plaintiff, Diane M. Nighbert, to
file a Complaint in the above-captioned matter within twenty (20)
days of the date of service of said Rule.
MEYER,
BEBENEK & ECK, PLLC
BY: /"7?? ?Lffhl
MARY LOW4AAliERHOFER, ESQUIRE
Counsel ifor Defendant,
Keystone Spine Center, Inc.
120 Lakemont Park Boulevard
Altoona, PA 16602
(814) 941-4600
I.D. #62175
DATE: June 22. 1999
nuv v c c i rua eN a- e? e o i
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DIANE M. NIGHBERT,
Plaintiff
Vs.
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
NANCY BERGERT, WILLIAM T.
WRIGHT, II, HASBROUK S. WRIGHT,
JR., Individually and as members
of Cliffdale Associates, a
Pennsylvania Partnership; and
JOHN DOE; and KEYSTONE SPINE
CENTER, INC.
Defendants
R U L E
No. 99-330 Civil
JURY TRIAL DEMANDED
AND NOW, this day of ) ttt' 1999,
upon consideration of the foregoing Praec pe and on Motion of Mary
Lou Maierhofer, Esquire, Counsel for Defendant, Keystone Spine
Center, Inc., a Rule is granted on the Plaintiff to file her
Complaint Sec. Leg within twenty (20) days of service of said Rule,
or Judgment of Non Pros may be entered.
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MU4/vId/MUBENE-99801
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DIANE M. NIGHBERT,
Plaintiff ??d0
vs. No. 99-330 Civil
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and JURY TRIAL DEMANDED
NANCY BERGERT, WILLIAM T.
WRIGHT, II, HASBROUK S. WRIGHT,
JR., Individually and as members
of Cliffdale Associates, a
Pennsylvania Partnership; and
JOHN DOE; and KEYSTONE SPINE
CENTER, INC.
Defendants
CERTIFICATE OF SERVICE OF RULE TO FILE COMPLAINT
You are hereby notified that on the 28th day of June, 1999,
Defendant, Keystone Spine Center, Inc., by its Counsel, MEYER,
DARRAGH, BUCKLER, BEBENEK & ECK, PLLC, served a Rule upon
Plaintiff, Diane M. Nighbert, by mailing the original of same
first-class mail, poFtage prepaid, addressed to Plaintiff's
Counsel, as follows:
Andrea C. Jacobsen, Esquire
JACOBSEN & MILKES
52 E. High Street
Carlisle, PA 171013
MEYER, DARRAGH,,, BU LER, BEBENEK & ECK, PLLC
r
BY:
Counsel j-dr+ Defendant,
Kays{one Spine Center, Inc.
120 Lakemont Park Boulevard
Altoona, PA 16602
(814) 941-4600
I.D. #62175
- i,
MM/vta/M1I MM.99801
/17
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DIANE M. NIGHBERT,
Plaintiff
VS.
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
NANCY BERGERT, WILLIAM T.
WRIGHT, II, HASBROUK S. WRIGHT,
JR., Individually and as members
of Cliffdale Associates, a
Pennsylvania Partnership; and
JOHN DOE; and KEYSTONE SPINE
CENTER, INC.
Defendants
No. 99-330 Civil
JURY TRIAL DEMANDED
R U L E
AND NOW, this O Kn day of (A-vj? 1999,
upon consideration of the foregoing Praec p and on Motion of Mary
Lou Maierhofer, Esquire, Counsel for Defendant, Keystone Spine
Center, Inc., a Rule is granted on the Plaintiff to file her
Complaint Sec. Leg within twenty (20) days of service of said Rule,
or Judgment of Non Pros may be entered.
InTFROM R
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-03330 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NIGHBERT DIANE M
vs.
CLIFFDALE ASSOC INC ET AL
TIMOTHY REITZ , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within WRIT OF SUMMONS was served
upon CLIFFDALE ASSOCIATES the
defendant, at 1757:00 HOURS, on the 8th day of June
1999 at 1010 BRENTWATER ROAD
CAMP HILL, PA 17011 CUMBERLAND
County, Pennsylvania, by handing to BRYAN BERGERT,GENERAL
MAINTANCE
a true and attested copy of the WRIT OF SUMMONS
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00 So answers:
18.0 r
.000
8.00 K. MOMS Kline, bnerl
-JACOBSEN & MILKES
06/16/1999
by
Sworn and subscribed to before me
this lL t-2? day of
1 11 p y e
19 .Y A.D.
std`
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-03330 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NIGHBERT DIANE M
vs.
CLIFFDALE ASSOC INC ET AL
TIMOTHY REITZ , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within WRIT OF SUMMONS _ was served
upon BERGERT NANCY the
defendant, at 1757:00 HOURS, on the 8th day of June
1999 at 1010 BRENTWATER ROAD
CAMP HILL, PA 17011 CUMBERLAND
County, Pennsylvania, by handing to BRYAN BERGERT,GENERAL
MAINTANCE
a true and attested copy of the WRIT OF SUMMONS
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing 6.00
Service .00 2
Affidavit .00
Surcharge 8.00 _om ine, SrieLM
--
S14QU-JACOBSEN & MILKES
06/16/1999
by
.
P y e i
Sworn and subscribed to before me
this /G ?` day of (I
19 A. D. -F'P?Erro`n`5? a may`
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-03330 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NIGHBERT DIANE M
vs.
CLIFFDALE ASSOC INC ET AL
TIMOTHY REITZ Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within WRIT OF SUMMONS
was served
upon WRIGHT WILLIXI T II the
defendant, at 1757:00 HOURS, on the 8th day of June
1999 at 1010 BRENTWATER ROAD
CAMP HILL, PA 17011 CUMBERLAND
County, Pennsylvania, by handing to BRYAN BERGERT,GENERAL
MAINTANCE
a true and attested copy of the WRIT OF SUMMONS
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So answi??`^" -
Docketing 6.00
Service 00 2
Affidavit .
Surcharge 8.00
omas i
$14?0-JAGOBSEN & MILKES
06/16/1999
by e
Sworn and subscribed before me
this 1& 5- day of
19199 A.D.
?r nono,
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-03330 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NIGHBERT DIANE M
VS.
CLIFFDALE ASSOC INC ET AL
TIMOTHY REITZ Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within WRIT OF SUMMONS was served
upon WRIGHT HASBROUK S JR the
defendant, at 1757:00 HOURS, on the 8th day of June
1999 at 1010 BRENTWATER ROAD
CAMP HILL, PA 17011 ,CUMBERLAND
County, Pennsylvania, by handing to BRYAN BERGERT,GENERAL
MAINTANCE
a true and attested copy of the WRIT OF SUMMONS
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing 6.00
Service .00?? 2
Affidavit 00
Surcharge 8.00 oma ine, e,
-JACOBS1999 MILKES
by
y i
Sworn and subscribed to before me
this 141?" day of
19%2 A. D.
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-03330 P
COUNTYW FL CUMBERLANDTH OF
NIGHBERT DIANE M
VS.
CLIFFDALE ASSOC INC ET AL
BRIAN BARRICK , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
was served
to law, says, the within WRIT OF SUMMONS
the
upon DOE JOHN
defendant, at 1852:00 HOURS, on the 11th day of June
1999 at 1010 BRENTWATER ROAD
CAMP HILL, PA 17011 CUMBERLAND
County, Pennsylvania, by handing to NANCY BERGERT,OWNER
a true and attested copy of the WRIT OF SUMMONS
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 8.00 A--T m in , eri
$T4-.Oa-JACOBSEN & MILKES
06/16/1999
by
e? y Zeri
sworn and subscribed to before me
this A m day of 9L-
19 99 A. D.
?„
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-03330 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NIGHBERT DIANE M
VS.
CLIFFDALE ASSOC INC 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 KEYSTONE SPINE CENTER INC the
defendant, at 1311:00 HOURS, on the 7th day of June
1999 at 1521 CEDAR CLIFF DRIVE
CAMP HILL, PA 17011 CUMBERLAND
County, Pennsylvania, by handing to RUSSELL POOL,PRESIDENT
a true and attested copy of the WRIT OF SUMMONS
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00 So answers:
.00
.00
8.00 mas 1 1 2 -
$4.UU "JACOBSE999 MILKES
by
Sworn and subscribed to before me
this /L V- day of
19 A.D.
?? a h<d
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DIANE M. NIGHBERT,
Plaintiff
V.
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
NANCY BERGERT, individually and as a
member and managing partner of
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
WILLIAM T. WRIGHT, II, individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
HASBROUI{ S. WRIGHT, JR., individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
KEYSTONE SPINE CENTER, INC.,
Defendants
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
NO. 99.3330
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
COMPLAINT
AND NOW comes Diane M. Nighbert, by her counsel, Andrea C. Jacobsen,
Esquire, JACOBSEN & MILKES, and states as follows:
1. Plaintiff is Diane M. Nighbert, an adult citizen of Cumberland County,
Pennsylvania, who resides at 2426 Clover Drive, Mechanicsburg, Cumberland
County, PA 17055.
2. Defendant Cliffdale Associates is a Pennsylvania Partnership with offices at
1010 Brentwater Road, Camp Hill, Cumberland County, PA 17011.
3. Defendants Cliffdale Associates, Nancy Bergert, William T. Wright, II, and
Hasbrouk S. Wright, Jr., were at all times herein mentioned, and still are, the
owners in fee simple of certain real property located at 1521 Cedar Cliff Drive,
Camp Hill, Cumberland County, PA 17011, and the operators of an office building
at that site.
i
4. The building at 1521 Cedar Cliff Drive is a public office building open to
public and in particular to persons having business with the occupants and tenants
of the building.
5. Defendant Keystone Spine Center, Inc. was at all times herein mentioned a
tenant and occupant of the said office building at 1521 Cedar Cliff Drive, Camp
Hill, Cumberland County, PA 17011, at which site they operated a physical therapy
office or clinic which provided services to the public.
6. The office of Keystone Spine Center, Inc., is located on the lower level of the
said office building. In order to enter the offices of Keystone Spine Center, Inc., it is
necessary to cross the front entrance area of the building and proceed down a flight
of steps to the lower level.
7. Doors to the outside of the said office building enter into the front entrance
area of the building. Across the front entrance area of the building are two flights
of stairs of approximately five steps each, one leading down to the lower level, and
one leading up to the upper level.
8. During inclement wet weather, such as rain, water regularly entered the
building and accumulated on the floor in the front entranceway.
9. On June 3, 1997, and prior thereto, there was no rug, mat or other covering
on the floor surface of the front entrance area of the said office building to absorb
any of the water on the floor.
10. The water and dampness on the uncovered floor surface reduced the traction
of the floor surface and left it very slick, and dangerous to anyone entering the office
building and crossing the surface of the front entrance area.
11. On a recurring basis, during inclement weather, the accumulated water and
dampness was tracked by parties entering the building through the doors and
traversing the distance to the flights of stairs on the other side of the entrance area
and on to the steps of the stairs leaving them wet or damp and in a slippery and
dangerous condition.
12. On June 3, 1997, the floor surface of the steps appeared to be grooved hard
rubber. There were no mats or treads, sandpaper or coarse surface or other
covering of the surface of the steps to absorb the wetness or dampness that was
tracked to the stairs by parties entering the building from the outside, or to increase
traction or reduce the slickness and the slippery and dangerous condition of the
floor surface and the steps of the flights of stairs in the building.
13. As a result of the wet and damp surface, and the slick nature of the floor
covering, the stairs represented a danger to the public entering the front entrance
area and proceeding up or down the flights of stairs.
14. On June 3, 1997, and prior thereto, the defendants allowed the said
defective and dangerous condition of the entrance area and stairs to be and remain
in this dangerous condition, when they knew, or had reason to know of the unsafe
nature of the entrance area and stairs and the danger to visitors entering the office
building.
15. On June 3, 1997, plaintiff Diane Nighbert entered the office building at or
about midday for the purpose of visiting the offices and clinic of Keystone Spine
Center, Inc., located in the building. She came to meet her mother, a patient of
Keystone Spine Center, Inc., and provide her with transportation home.
16. On June 3, 1997, the weather was wet and the floor of the entranceway was
wet and damp when plaintiff entered the building.
17. Plaintiff had never entered the building previously and was not familiar
with the exact location of the office of Keystone Spine Center, Inc., in the building.
She proceeded across the entranceway and began to climb the flight of stairs to the
second floor. After she had climbed a few steps, she noticed that there were no
lights on upstairs, and she realized that Keystone Spine Center, Inc., was probably
located on the lower level. She turned around and proceeded down the stairs with
the intention of descending the flight to the lower level.
18. As she proceeded down the stairs, plaintiff observed a handwritten sign
attached to the overhang wall facing the downward flight. The sign, hand written
in crayon or marker, read, "Slippery When Wet."
19. Plaintiff did not know of any other path to the lower level or any other
means of accessing the office of Keystone Spine Center, Inc., except by the stairs,
She had no choice but to proceed down the stairs in order to reach her destination.
20. Plaintiff heeded the sign and proceeded very slowly and with particular care
down the stairs and held tightly on to the railing, which was attached to the wall on
the right side of the stairway as she faced it from the entranceway.
j
21. Despite her care, plaintiff felt her foot slide on the slick and slippery surface
j of the first or second step and she lost her balance and slipped and fell. to the bottom
of the flight of stairs.
22. At the time that she fell, plaintiff was holding tightly on to the railing and
her hand got caught in the rail as she slid down the stairs. As the force of the fall.
pulled her downward, plaintiff felt her right fingers strike something hard.
23. The sound of plaintiffs fall was heard by her mother inside the offices of
Keystone Spine Center, Inc., which was located at the foot of the stairway, and also
by others in the office, including the receptionist.
b
24. Plaintiffs mother and the receptionist ran out of the office to investigate.
They found plaintiff sitting on the bottom step, shaken, complaining of her fall, and
her discomfort.
25. The receptionist told plaintiff and her mother that she knew that the floor
was very slippery, that plaintiff was not the first person to fall.
26. Plaintiffs mother and the receptionist helped plaintiff up from the floor.
Her mother assisted plaintiff up the stairs and out of the building to her car.
27. Plaintiff suffered multiple contusions in her fall. Plaintiff had a sore
backside; her head, neck and hand hurt, and she had pain in the right buttocks and
across her lower back.
28. Plaintiff and her mother proceeded to plaintiffs home. Plaintiff had a red
and bruised lower back, bruised right elbow, and pain in her head, neck, hand, arm,
hip and right buttocks.
29. Plaintiffs infant son, who was then six months of age, and weighed
approximately 20 lbs., was at her home with a babysitter. Plaintiff was unable to
pick up the child and care for him due to her pain. She has continued to have
difficulties with his care due to her injuries.
30. Plaintiff was scheduled to work the evening of her fall at her job as a retail
cashier at TJ Maxx, but was unable to go to work due to her injuries. Plaintiff took
some over the counter pain medicine and lay down but did not obtain relief.
31. That evening, plaintiff went to her family doctor, Dr. David Wenner, at
Shepherdstown Family Practice, for treatment for her injuries suffered in the fall.
She reported right arm and back pain; multiple contusions were noted. Her
physician prescribed medication for her pain and inflammation, recommended rest
and advised her not to work the next day. He directed plaintiff to return if the
discomfort persisted.
32. During the next few days, plaintiff continued to suffer from her injuries.
She experienced vertigo and neck pain. She again sought medical treatment and
was advised to wait and see if her problems resolved.
33. Over the next month, plaintiff continued to experience pain, especially back
and neck pain, and dizziness. She returned to her family physician in July 1997,
complaining of her continued pain and other symptoms, including ongoing back and
neck pain.
34. Due to her injuries and her pain, plaintiff was unable to perform the duties
of her employment. As a consequence, she was forced to miss work on numerous
occasions.
35. Despite treatment with medication and rest, plaintiff continued to suffer
ongoing discomfort and pain. She was referred in late July 1997, by her family
physician for physical therapy treatments at Keystone Spine Center, Inc.
36. After her course of physical therapy, plaintiff continued to do recommended
exercises, but still suffered from pain and discomfort, especially in her lower back,
neck and arm.
37. In November 1997, plaintiff reported her continued back pain to her family
physician and was referred for x-rays of her spine.
38. In December 1997, plaintiff was referred for an orthopedic evaluation of her
chronic back pain.
39. In early 1998, plaintiff continued to seek medical attention for her injuries.
In May 1998, she was again referred for evaluation of her chronic neck and back
pain and for difficulties with her right hand.
40. In November 1998, plaintiff was referred by her family doctor for a second
course of physical therapy for plaintiff at Central Penn Rehab Services in
Mechanicsburg, PA. That treatment was received from November 2 to November
30, 1999.
41. Plaintiff still suffers from her injuries. She continues to take pain
medication for her lower back and neck discomfort.
42. As a result of injuries suffered in her fall, she is unable to stand in one
position for extended periods of time without great discomfort, suffers chronic pain
in her back, neck, and right arm. She is limited in her lifting, and experiences other
symptoms, including dizziness and numbness.
43. At the time of her injury, plaintiff was employed at TJ Maxx and at Giant
Food Stores as a cashier. At the job at Giant, she was required to stand in one
position for extended periods of time. As a result of her injuries, plaintiff found that
she could not perform the requirements of her job at Giant without great
discomfort. As a result, she was forced to resign from that position, to her economic
detriment.
44. As a direct result of her ongoing discomfort from her fall, plaintiff missed in
excess of 50 hours of work at both of her jobs.
45. Plaintiff is limited in her ability to comfortably stand in one place, to sit for
extended periods of time, and to lift, as a result of injuries suffered in her fall. She
continues to experience difficulty with her right arm.
46. Plaintiff has incurred, and continues to incur, medical expenses as a result
of her injuries, including the cost of co-payments to her family doctor, whose costs
are primarily covered by an HMO. Plaintiff has incurred the costs of physical
therapy treatment at Central Penn Rehab Services, in the amount of $848.06.
47. Additional specific costs of treatment have been covered by insurance in the
amount of $387.00.
48. Plaintiff was required to obtain a brace for her arm as a result of her
injuries.
49. As a result of lost wages from missed work, and the need to change her
employment, and the physical limitations she now suffers, plaintiff has suffered and
continues to suffer economic harm and loss of earnings.
50. As a result of her injuries, plaintiff has suffered discomfort and
inconvenience with regard to her care of her young son, as she is hampered in her
ability to lift him without pain.
51. As a result of her injuries, plaintiff has suffered and continues to suffer
great pain and suffering and ongoing damage to her back, neck and right arm.
52. Defendant Keystone Spine Center, Inc., knew that the slick and slippery
condition of the steps leading to their office represented a danger to their visitors.
53. Defendants Cliffdale Associates, Nancy Bergert, William T. Wright, and
Hasbrouk S. Wright, Jr.., knew or should have known that the common areas of the
building were dangerous to visitors to their building at 1521 Cedar Cliff Drive when
the weather was damp, and that such danger was present on a recurrent basis.
54. Plaintiffs injuries were the direct result of defendants' failure to take steps
to make the building safe and to correct the dangerous condition of the stairs
leading to the lower level of the building caused by the slick surface of the floor and
steps, and the absence of any adequate means of control of the water entering the
building during inclement weather.
WHEREFORE, Plaintiff has been injured by defendants and asks this Court to
award her damages in excess of Twenty Five Thousand Dollars ($25,000.00) and to
grant such further relief as this court may deem proper and just.
Respectfully submitted,
DATE:
BY: A dre C. Jacobsen, Esq.
JACO SE & MILKES
52 East High Street
Carlisle, PA 17013
Telephone: (717) 249-6427
Fax: (717) 249-8427
Attorney No. 20952
I hereby verify that the statements made in the foregoing
are true and correct. I further understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to
authorities.
DATE: / /? I f 1 13 ?) 1J
DIANE M. NIGHBERT
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DIANE M. NIGHBERT,
Plaintiff
VS.
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
NANCY BERGERT, individually and
as a member and managing partner
of CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
WILLIAM T. WRIGHT, II,
individually and as a member of
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
HASBROUK S. WRIGHT, JR.,
individually and as a member of
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
KEYSTONE SPINE CENTER, INC.
Defendants
No. 99-3330 Civil
JURY TRIAL DEMANDED
Type of Pleading:
PRELIMINARY OBJECTIONS
Filed on Behalf of:
DEFENDANT, KEYSTONE
SPINE CENTER, INC.
Counsel of Record
for this Party:
MARY LOU MAIERHOFER, ESQ.
MEYER, DARRAGH, BUCKLER,
BEBENEK & ECK, PLLC
120 Lakemont Park Blvd.
Altoona, PA 16602
(814) 941-4600
I.D. #62175
MLM/vfd/MUBENE-99801 -
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DIANE M. NIGHBERT,
Plaintiff
VS.
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
NANCY BERGERT, individually and
as a member and managing partner
of CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
WILLIAM T. WRIGHT, II,
individually and as a member of
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
HASBROUK S. WRIGHT, JR.,
individually and as a member of
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
KEYSTONE SPINE CENTER, INC.
Defendants
No. 99-3330 Civil
JURY TRIAL DEMANDED
PRELIMINARY OBJECTIONS
NOW COMES the Defendant, Keystone Spine Center, Inc., by and
through its counsel, MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC,
and files the following Preliminary Objections of which the
following is a statement:
2. Plaintiff commenced this lawsuit by filing a Writ of
Summons on or about June 2, 1999, and thereafter filed a Complaint
on August 4, 1999.
2. Plaintiff alleges injuries as a result of falling down
steps at 1521 Cedar Cliff Drive, Camp Hill, Cumberland County,
Pennsylvania, on June 3, 1997.
3. Plaintiff alleges personal injuries as a result of the
incident.
ISSUE I - DEMURRER
(Violation of Pa.R.C.P. 1020)
4. The allegations set forth above are incorporated herein
by reference thereto as if the same were set forth at length.
5. Plaintiff's Complaint is extremely confusing as Plaintiff
has grouped all five Defendants together.
6. From a review of the Complaint, it appears as a result of
the allegations set forth in paragraph 54, Plaintiff just
generalizes allegations against all of the Defendants.
7. Paragraph 54 of Plaintiff's Complaint states the
following:
Plaintiff's injuries were the direct result of
the defendants' failure to take steps to make
the building safe and correct the dangerous
condition of the steps leading to the lower
level of the building caused by the slick
surface of the floor and steps, and the
absence of any adequate means of control of
the water entering the building during
inclement weather.
B. Plaintiff's Complaint is in violation of Pa.R.C.P. §
1020(a) which requires that each cause of action against each
Defendant be separated and any special damages related thereto must
be set forth in a separate count containing a separate demand for
relief.
9. The logic and basis for this requirement is to not only
2
set forth allegations individually so that each' Defendant has
notice to what is being alleged against him/her, but to also
separate the allegations so the Complaint is not confusing when
Defendants respond to same.
10. Plaintiff has grouped all of the Defendants together,
thus, violating the Pennsylvania Rules of Civil Procedure.
11. This grouping together by Plaintiff of the allegations
against all of the Defendants has created a very confusing
Complaint, thereby, not permitting the allegations to be separated
against each of the Defendants for the specific Defendant to
respond.
WHEREFORE, Defendant, Keystone Spine Center, Inc., prays that
Plaintiff's Complaint be dismissed with prejudice or Plaintiff be
required to file an Amended Complaint separating all allegations
against each of the Defendants in a concise and clear manner.
ISSUE II - DEMURRER
(Failure to State a Cause of Action)
12. The allegations set forth above are incorporated herein
by reference thereto as if the same were set forth at length.
13. Plaintiff sets forth in her Complaint the following:
5. Defendant Keystone Spine Center, Inc. was
at all times herein mentioned a tenant and
occupant of the said office building at 1521
Cedar Cliff Drive, Camp Hill, Cumberland
County, PA 17011, at which site they operated
a physical therapy office or clinic which
provided services to the public.
52. Defendant Keystone Spine Center, Inc.,
knew that the slick and slippery condition of
3
the steps leading to their office represented
a danger to their visitors.
54. Plaintiff's injuries were the direct
result of the defendants' failure to take
steps to make the building safe and correct
the dangerous condition of the steps leading
to the lower level of the building caused by
the slick surface of the floor and steps, and
the absence of any adequate means of control
of the water entering the building during
inclement weather.
14. Plaintiff has failed to set forth a cause of action
against this Defendant.
WHEREFORE, Defendant, Keystone Spine Center, Inc., prays that
Plaintiff's Complaint be dismissed w' h prejudice.
MEYER, D RAGH, B C ER, BEBENEK & ECK, PLLC
1
BY: 1V
MARY li IERHOFER, ESQUIRE
Counsel for'Defendant,
Keystone Spine Center, Inc.
120 Lakemont Park Boulevard
Altoona, PA 16602
(814) 941-4600 f :.
I.D. #62175
1
I!
4
CERTIFICATE OF SERVICE
I, Mary Lou Maierhofer, Esquire, of the law firm of MEYER,
DARRAGH, BUCKLER, BEBENEK & ECK, PLLC, hereby certify that a true
and correct copy of the foregoing Preliminary objections was served
this 17th day of August, 1999, by mailing same First Class United
States mail, postage prepaid, addressed as follows:
Andrea C. Jacobsen, Esquire
JACOBSEN & MILKES
52 E. High Street
Carlisle, PA 17013
Cliffdale Associates
1010 Brentwater Road
Camp Hill, PA 17011
Nancy Bergert
Cliffdale Associates
1010 Brentwater Road
Camp Hill, PA 17011
William T. Wright, II
Cliffdale Associates
1010 Brentwater Road
Camp Hill, PA 17011
Hasbrouk S. Wright, Jr.
Cliffdale Associates
1010 Brentwater Road
Camp Hill, PA 17011
MEYER,
,/SUCKLER, BEBENEK & ECK, PLLC
BY:
Counsel' Defendant,
Keys ne Spine Center, Inc.
120 Lakemont Park Boulevard
Altoona, PA 16602
(814) 941-4600
I.D. #62175
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LEAS OF IN THE COURT OF COMMON CIVIL ACT ON BE LLAAWND COUNTY, PENNSYLVANIA
DIANE M. NIGHBEPlaintiff
VS.
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
NANCY BERGERT, individually and
as a member and managing partner
of CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
WILLIAM T. WRIGHT, II,
individually and as a member of
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
HASBROUK S. WRIGHT, JR.,
individually and as a member of
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
KEYSTONE SPINE CENTER, INC.
Defendants
No. 99-3330 Civil
JURY TRIAL DEMANDED
Type of Pleading:
;,.pRAECIPE!FOR LISTING,
C:OR,"ARGUMENT
Filed on Behalf of:
DEFENDANT, KEYSTONE
SPINE CENTER, INC.
Counsel of Record
for this Party:
MARY LOU MAIERHOFER, ESQ
MEYER, DARRAGH, BUCKLER,
BEBENEK & ECK, PLLC
120 Lakemont Park Blvd.
Altoona, PA 16602
(814) 941-4600
I.D. #62175
PRAECIPE FOR LISTING CASE FOR ARGUMENT
(Must be typewritten and submitted in duplicate)
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please list the within matter for the next Argument Court.
-----------------------------------------------------------------
CAPTION OF CASE
(entire caption must be stated in full)
DIANE M. NIGHBERT,
Plaintiff
VS.
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
NANCY BERGERT, individually and
as a member and managing partner
of CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
WILLIAM T. WRIGHT, II,
individually and as a member of No. 3330 Civil 1999
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
HASBROUK S. WRIGHT, JR.,
individually and as a member of
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
KEYSTONE SPINE CENTER, INC.
Defendants
1. State matter to argued (i.e., plaintiff's motion for new
trial, defendant's demurrer to complaint, etc.):
Defendant, Keystone Spine Center, Inc.'s Preliminary
objections
2. Identify counsel who will argue case:
3
(a) for plaintiff: Andrea C. Jacobsen, Esquire
Address: JACOBSEN & MILKES
52 E. High Street
Carlisle, PA 17013
(b) for defendant: Mary Lou Maierhofer, Esquire
Address: MEYER, DARRAGH, BUCKLER, BEBENEK
& ECK, PLLC
120 Lakemont Park Boulevard
Altoona, PA 16602
(Counsel for Defendant, Keystone Spine Center, Inc.)
I will notify all parties in writing within two days that this
case has been listed for argument. /
4. Argument Court Date:
Dated: F; l'1-ly
October 13
Sp
Center, Inc.
CERTIFICATE OF SERVICE
I, Mary Lou Maierhofer, Esquire, of the law firm of MEYER,
DARRAGH, BUCKLER, BEBENEK & ECK, PLLC, hereby certify that a true
and correct copy of the foregoing Praecipe for Listing Case for
Argument was served this 17th day of August, 1999, by mailing same
First Class United States mail, postage prepaid, addressed as
follows:
Andrea C. Jacobsen, Esquire
JACOBSEN & MILKES
52 E. High Street
Carlisle, PA 17013
Cliffdale Associates
1010 Brentwater Road
Camp Hill, PA 17011
Nancy Bergert
Cliffdale Associates
1010 Brentwater Road
Camp Hill, PA 17011
William T. Wright, II
Cliffdale Associates
1010 Brentwater Road
Camp Hill, PA 17011
Hasbrouk S. Wright, Jr.
Cliffdale Associates
1010 Brentwater Road
Camp Hill, PA 17011
MEYER,
, BUCKLER, BEBENEK & ECK, PLLC
(Z li;' jai
, dl j
BY:
RY?LQ IERHOFER, ESQUIRE
Coun/ for Defendant,
Ke stone Spine Center, Inc.
120 Lakemont Park Boulevard
Altoona, PA 16602
(814) 941-4600
I.B. #62175
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DIANE M. NIGHBERT,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
V.
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
NANCY BERGERT, individually and as a
member and managing partner of
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
NO. 99-3330
WILLIAM T. WRIGHT, II, individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
HASBROUK S. WRIGHT, JR., individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
KEYSTONE SPINE CENTER, INC.,
Defendants
: CIVIL ACTION -LAW
PFRTIFI `{ ATF, OF CFFVICE
I, Angela S. Garland, hereby certify that a true and correct copy of a Complaint in the above
captioned matter, was duly served upon Hasbrouk S. Wright, Jr., defendant, by depositing it in the U.S.
Mail, postage paid, on August 4, 1999, addressed as follows:
Hasbrouk S. Wright, Jr.
1010 Brentwater Road
Camp Hill, PA 17011
hereby verify that the statements made in the foregoing are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to
unsworn falsification to authorities.
Dated:
AN F:1 S. GARLAND
r ? ?7
L-
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DIANE M. NIGHBERT,
Plaintiff
V.
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
NANCY BERGERT, individually and as a
member and managing partner of
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
WILLIAM T. WRIGHT, II, individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
HASBROUI{ S. WRIGHT, JR., individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
KEYSTONE SPINE CENTER, INC.,
Defendants
IN THE. COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
NO. 99-3330
CIVIL ACTION - LAW
I, Angela S. Garland, hereby certify that a true and correct copy of a Complaint in the above
captioned matter, was duly served upon William T. Wright, II, defendant, by depositing it in the U.S.
Mail, postage paid, on August 4, 1999, addressed as follows:
William T. Wright, 11
1010 Brentwater Road
Camp Hill, PA 17011
hereby verify that the statements made in the foregoing are true and correct. I understand
that false statements herein are made subject to the penalties of IS Pa.C.S. Section 4904, relating to
unsworn falsification to authorities.
Dated: 60
'GEI.A S. GAIII.?IND
r.
i
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DIANE M. NIGHBERT,
Plaintiff
V.
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
NANCY BERGERT, individually and as a
member and managing partner of
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
WILLIAM T. WRIGHT, II, individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
HASBROUK S. WRIGHT, JR., individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
KEYSTONE SPINE CENTER, INC.,
Defendants
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
NO. 99-3330
CIVIL ACTION - LAW
I, Angela S. Garland, hereby certify that a true and correct copy of a Complaint in the above
captioned matter, was duly served upon Nancy Bergert, defendant, by depositing it in the U.S. Mail,
postage paid, on August, 1999, addressed as follows:
Nancy Bergert
1010 Brentwater Road
Camp Hill, PA 11011
hereby verify that the statements made in the foregoing are true and correct. 1 understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to
unsworn falsification to authorities.
Unted:
7
7
NGIs"lJ1 S. GAIII.?iND
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C.'
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DIANE M. NIGHBERT,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
V.
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
NANCY BERGERT, individually and as a
member and managing partner of
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
NO. 99-3330
WILLIAM T. WRIGHT, 11, individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
HASBROUK S. WRIGHT, JR., individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
KEYSTONE SPINE CENTER, INC.,
Defendants
CIVIL ACTION - LAW
CERTIFICATE nR SERUCE
I, Angela S. Garland, hereby certify that a true and correct copy of a Complaint in the above
captioned matter, was duly served upon Cliffdale Associates, a Pennsylvania Partnership, plaintiff, by
depositing it in the U.S. Mail, postage paid, on August 9, 1999, addressed as follows:
Cliffdale Associates
1010 Brentwater Road
Camp Hill, PA 17011
hereby verify that the statements made in the foregoing are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 990.1, relating to
unworn falsification to authorities.
Dated: 6/?y L
NGEI.?1 S. 3AR[.AA'D
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DIANE M. NIGHBERT,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
V.
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
NANCY BERGERT, individually and as a
member and managing partner of
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
NO. 99-3330
WILLIAM T. WRIGHT, II, individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
HASBROUK S. WRIGHT, JR., individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
KEYSTONE SPINE CENTER, INC.,
Defendants
CIVIL ACTION - LAW
I, Angela S. Garland, hereby certify that a true and correct copy of a Complaint in the above
captioned matter, was duly served upon Mary Lou Maierhofer, counsel for defendant, Keystone Spine
Center, by depositing it in the U.S. Mail, postage paid, on August, 1999, addressed as follows:
Mary Lou Maierhofer, Esq.
Meyer, Darragh, Buckler, Bebenek S Eck
129 Lakemont Park Boulevard
Altoona, PA 16602
hereby verify that the statements made in the foregoing are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to
unsworn falsification to authorities.
Dated:
62ELA S. GARLAND
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MIMIOdlMUBENE•98801
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DIANE M. NIGHBERT,
VS.
Plaintiff
No. 99-3330 Civil
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
NANCY BERGERT, individually and
as a member and managing partner
of CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
WILLIAM T. WRIGHT, II,
individually and as a member of
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
HASBROUK S. WRIGHT, JR.,
individually and as a member of
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
KEYSTONE SPINE CENTER, INC.
Defendants
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
1, Mary Lou Maierhofer, Esquire, of the law firm of MEYER, DARRAGH, BUCKLER,
BEBENEK & ECK, PLLC, hereby certify that Defendant, Keystone Spine Center, Inc.'s
First Request for Production of Documents and First Set of Interrogatories Directed to
Plaintiff were served this 161h day of November, 1999, by mailing same First Class United
States mail, postage prepaid, addressed as follows:
Andrea C. Jacobsen, Esquire
JACOBSEN & MILKES
52 E. High Street
Carlisle, PA 17013
Nancy Bergert
Cliffdale Associates
1010 Brentwater Road
Camp Hill, PA 17011
Cliffdale Associates
1010 Brentwater Road
Camp Hill, PA 17011
William T. Wright, II
Cliffdale Associates
1010 Brentwater Road
Camp Hill, PA 17011
Hasbrouk S. Wright, Jr.
Cliffdale Associates
1010 Brentwater Road
Camp Hill, PA 17011
MEYER, DARRAPH, BUCKLER, BEBENEK & ECK, PLLC
BY:
Counsel of endant, Keystone Spine Center, Inc.
120 Lak mont Park Boulevard
Altoona, PA 16602
(814) 941-4600
I.D.#62175
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PRAECIPE FOR LISTING CASE FOR ARGUMENT
(Must be typewritten and submitted in duplicate)
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please list the within matter for the next Argument Court.
CAPTION OF CASE
(entire caption must be stated in full)
DIANE M. NIGHBERT,
Plaintiff
VS.
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
NANCY BERGERT, individually and
as s member and managing partner
of CLIFFDALE ASSOCIATES, a
- Pennsylvania Partnership; and
WLLIAM T. WRIGHT. 11,
individually and as a member of No. 3330 Civil 1999
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
HASBROUK S. WRIGHT, JR.,
Individually and as a member of
CLIFFDALE ASSOCIATES, e
Pennsylvania Partnership; and
KEYSTONE SPINE CENTER, INC.
Defendants
State matter to argued (i.e., plaintiffs motion for new trial, defendant's demurrer
to complaint, etc.):
Defendant, Keystone Spine Center, Inc.'s Preliminary Objections
2. Identify counsel who will argue case:
(a) for plaintiff: Andrea C. Jacobsen, Esquire
Address: JACOBSEN & MILKES
52 E. High Street
Carlisle, PA 17013
(b) for defendant: Mary Lou Maierhofer, Esquire
Address: MEYER, DARRAGH, BUCKLER, BEBENEK &
ECK, PLLC
120 Lakemont Park Boulevard
Altoona, PA 16602
(Counsel for Defendant, Keystone Spine Center, Inc.)
3. 1 will notify all parties in writing within two days that this case has been listed for
argument.
4. Argument Court Date: December 8. 1999
Dated: 11-19-92
Attorney for Defendant, Keystone
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PRAECIPE FOR LISTING CASE FOR ARGUMENT
(Must be typewritten and submitted in duplicate)
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please list the within matter for the next Argument Court.
CAPTION OF CASE
(entire caption must be stated in full)
DIANE M. NIGHSERT,
Plaintiff
VS.
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
NANCY BERGERT, Individually and
as a member and managing partner
of CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
WILLIAM T. WRIGHT, 11,
individually and as a member of No. 3330 Civil 1999
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
HASBROUK S. WRIGHT, JR.,
Individually and as a member of
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
KEYSTONE SPINE CENTER, INC.
Defendants
1. State matter to argued (i.e., plaintiffs motion for new trial, defendant's demurrer
to complaint, etc.):
Defendant, Keystone Spine Center, Inc.'s Preliminary Objections
2. Identify counsel who will argue case:
(a) for plaintiff: Andrea C. Jacobsen, Esquire
Address: JACOBSEN & MILKES
52 E. High Street
Carlisle, PA 17013
(b) for defendant: Mary Lou Maierhofer, Esquire
Address: MEYER, DARRAGH, BUCKLER, BEBENEK &
ECK, PLLC
120 Lakemont Park Boulevard
Altoona, PA 16602
(Counsel for Defendant, Keystone Spine Center, Inc.)
3. 1 will notify all parties in writing within two days that this case has been listed for
argument.
4. Argument Court Date: December 8. 1999
Dated: 11-19-99 -
Attorney for Defendant, Keystone
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DIANE M. NIGHBERT,
Plaintiff
VS.
No. 99-3330 Civil
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
NANCY BERGERT, individually and
as a member and managing partner
of CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
WILLIAM T. WRIGHT, 11,
individually and as a member of
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
HASBROUK S. WRIGHT, JR.,
individually and as a member of
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
KEYSTONE SPINE CENTER, INC.
Defendants
JURY TRIAL DEMANDED
Type of Pleading: .
PRAECIPE TO WITHDRAW
PRAECIPE FOR ARGUMENT
ON PRELIMINARY
OBJECTIONS
Filed on Behalf of:
DEFENDANT, KEYSTONE
SPINE CENTER, INC.
Counsel of Record
for this Party:
MARY LOU MAIERHOFER,
ESQ.
MEYER, DARRAGH, BUCKLER,
BEBENEK & ECK, PLLC
120 Lakernont Park Blvd.
Altoona, PA 16602
(814) 9414600
I.D. #62175
MLMIvWIMUBENE•99801
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DIANE M. NIGHBERT,
Plaintiff
VS.
No. 99-3330 Civil
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
NANCY BERGERT, WILLIAM T.
WRIGHT, II, HASBROUK S. WRIGHT,
JR., Individually and as members
of Cliffdale Associates, a
Pennsylvania Partnership; and
JOHN DOE; and KEYSTONE SPINE
CENTER, INC.
Defendants
JURY TRIAL DEMANDED
PRAECIPE TO WITHDRAW
PRAECIPE FOR ARGUMENT
TO THE PROTHONOTARY:
Kindly withdraw the Praecipe for Argument on Defendant, Keystone Spine
Center, Inc.'s Preliminary Objections in the above-captioned matter.
MEYER, DAtIAGH, BUCKLER, BEBENEK & ECK, PLLC
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BY: r r , r i,
MARY LOU M IIEE I' 'E, E;
Counsel for Defen an , eystc
120 Lakemont Park Boulevard
Altoona, PA 16602
(814) 941-4600
Date: 12-2-99 I.D. #62175
cc: Andrea C. Jacobsen, Esq.
JIRE
Spine Center, Inc.
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PRAECIPE FOR LISTING CASE FOR ARGUMENT
(Must be typewritten and submitted in duplicate)
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please list the within matter for the next Argument Court.
CAPTION OF CASE
(entire caption must be stated in full)
DIANE M NIGHBERT,
Plaintiff
VS.
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
NANCY BERGERT, Individually and
as a member and managing partner
of CLIFFDALE ASSOCIATES, a
Pennsylvania Partnemnip; and
WILLIAM T. WRIGHT. 11,
individually and as a member of
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
HASBROUK S. WRIGHT, JR.,
individually and as a member of
CLIFFDALE ASSOCIATES, a
Pennsylvania Partnership; and
KEYSTONE SPINE CENTER, INC.
Defendants
No. 3330 Civil 1999
1. State matter to argued (i.e., plaintiffs motion for new trial, defendant's demurrer
to complaint, etc.):
Defendant, Keystone Spine Center, Inc.'s Preliminary Objections
2. Identify counsel who will argue case:
(a) for plaintiff: Andrea C. Jacobsen, Esquire
Address: JACOBSEN & MILKES
52 E. High Street
Carlisle, PA 17013
(b) for defendant: Mary Lou Maierhofer, Esquire
Address: MEYER, DARRAGH, BUCKLER, BEBENEK &
ECK, PLLC
120 Lakemont Park Boulevard
Altoona, PA 16602
(Counsel for Defendant, Keystone Spine Center, Inc.)
3. 1 will notify all parties in writing within two days that this case has been listed for
argument.
4. Argument Court Date: March 1. 2000 4
Dated: 1-31-00 Attbt?ney4or Defendant, Keystone
CERTIFICATE OF SERVICE
I, Mary Lou Maierhofer, Esquire, of the law firm of MEYER, DARRAGH,
BUCKLER, BEBENEK & ECK, PLLC, hereby certify that a true and correct copy of the
foregoing Praecipe for Listing Case for Argument on Defendant, Keystone Spine
Center, Inc.'s Preliminary Objections was served this 31e1 day of January, 2000, by
mailing same First Class United States mail, postage prepaid, addressed as follows:
Andrea C. Jacobsen, Esquire
JACOBSEN & MILKES
52 E. High Street
Carlisle, PA 17013
Cliffdale Associates
1010 Brentwater Road
Camp Hill, PA 17011
Nancy Bergert
Cliffdale Associates
1010 Brentwater Road
Camp Hill, PA 17011
William T. Wright, II
Cliffdale Associates
1010 Brentwater Road
Camp Hill, PA 17011
Hasbrouk S. Wright, Jr.
Ciiffdaie Associates
1010 Brentwater Road
Camp Hill, PA 17011
MEYER
BUCKLER, BEBENEK & ECK, PLLC
BY:
IVIMMY LyU A1tKHUVhR, LbQU
Counsel for Defendant,
Keystone Spine Center, Inc.
120 Lakemont Park Boulevard
Altoona, PA 16602
(814) 941-4600
I.D. #62175
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lj ?DIANE M. NIGHBERT, : IN THE COURT OF COMMON PLEAS
Plaintiff : OF CUMBERLAND COUNTY
V.
CLIFPDALE ASSOCIATE'S, it Pennsylvania
Partnership; and
NANCY BFJIGT_RT, individually and as it
member and managing partner of
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
NO. 99.3330
WILLIAM T. WRIGHT, II, individually and
as a member of CLIFPDALE ASSOCIATES,
a Pennsylvania Partnership; and
HASBROUK S. WRIGHT, JR., individually and :
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
KEYSTONE SPINE CENTER, INC.,
Defendants
CML ACTION - LAW
PRAECIPE
TO THE PROTHONOTARY:
Please mark the above case as settled in full, and discontinue any further
action as to any claims or potential claims of the plaintiff or defendants, related
to this action, with prejudice, on behalf of all parties.
FOR THE PLAINTIFF:
Date: 3-115-00 Respectfully submitted,
BY: Andre cobsen
JACOBSEN S MILKES
52 E. High Street
Carlisle, PA 17013
(717) 249-6427
(717) 249.8427 - Fax
Attorney No. 20952
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DIANE M. NIGHBERT,
Plaintiff
V.
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
NANCY BERGERT, individually and as a
member and managing partner of
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
WILLIAM T. WRIGHT, II, individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
HASBROUIi S. WRIGHT, JR., individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
KEYSTONE SPINE CENTER, INC.,
Defendants
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
: NO. 99.3330
: CIVIL ACTION - LAW
CERTIFICATE OR CFRVTVTI'
I, Shelley Eichelberger, hereby certify that a true and correct copy of a Praecipe in the above
captioned matter, was duly served upon Mary Lou Maierhofer, counsel for defendant, Keystone Spine
Center, by depositing it in the U.S. Mail, postage paid, on March 17, 2000, addressed as follows:
Mary Lou Maierhofer, Esq.
129 Lakemont Park Boulevard
Altoona, PA 16602
I hereby verify that the statements made in the foregoing are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa,C.S. Section 4904, relating to
unsworn falsification to authorities.
Dated: -3117/00 V , ??
Shelle ichelberger
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DIANE M. NIGHBERT.
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
V.
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
NANCY BERGERT, individually and as a
member and managing partner of
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
NO. 99-3330
WILLIAM T. WRIGHT, II, individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
HASBROUK S. WRIGHT, JR., individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
KEYSTONE SPINE CENTER, INC.,
Defendants
CIVIL ACTION - LAW
CEIRTIFICATE. Or SERVICE
I, Shelley Eichelberger, hereby certify that a true and correct copy of a Praecipe in the above
captioned matter, was duly served upon Nancy Bergert, by depositing it in the U.S. Mail, postage paid,
on March 17, 2000, addressed as follows:
Nancy Bergert
1010 Brentwater Road
Camp Hill, PA 17011
I hereby verify that the statements made in the foregoing are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4901, relating to
unsworn falsification to authorities.
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Dated: 3)1-7)0-0
Shell?cl!-I: i chel be rge r
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DIANE M. NIGHBERT,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
V.
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
NANCY BERGERT, individually and as a
member and managing partner of
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
NO. 99-3330
WILLIAM T. WRIGHT, II, individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
HASBROUK S. WRIGHT, JR., individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
KEYSTONE SPINE CENTER, INC.,
Defendants
CIVIL ACTION - LAW
r.RRTTFTCATr, nF CFRVIrE
I, Shelley Eichelberger, hereby certify that a true and correct copy of a Praecipe in the above
captioned matter, was duly served upon Hasbrouk S. Wright, Jr., by depositing it in the U.S. Mail,
postage paid, on March 17, 2000, addressed as follows:
Hasbrouk S. Wright, Jr.
1010 Brentwater Road
Camp Hill, PA 17011
I hereby verify that the statements made in the foregoing are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to
unsworn falsification to authorities.
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Dated:31/7/DD /j 4'? (I y
Shelley Ptichelberger
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DIANE M. NIGHBERT,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
V.
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
NANCY BERGERT, individually and as a
member and managing partner of
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
NO. 99-3330
WILLIAM T. WRIGHT, 11, individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
HASBROUK S. WRIGHT, JR., individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
KEYSTONE SPINE CENTER, INC.,
Defendants
CIVIL ACTION - LAW
CERTIFICATE -op qp.RvT(-.r.
I, Shelley Eichelberger, hereby certify that a true and correct copy of a Praecipe in the above
captioned matter, was duly served upon William T. Wright, II, by depositing it in the U.S. Mail, postage
paid, on March 17, x^.000, addressed as follows:
William T. Wright, II
1010 Brentwater Road
Camp Hill, PA 17011
I hereby verify that the statements made in the foregoing are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to
unsworn falsification to authorities,
Doted: -Vt 710a
Shea Eichelberger J
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DIANE M. NIGHBERT,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
V.
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
NANCY BERGERT, individually and as a
member and managing partner of
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
NO. 99.3330
WILLIAM T. WRIGHT, II, individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
IIASBROUK S. WRIGHT, JR., individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
KEYSTONE SPINE CENTER, INC.,
Defendants
CIVIL ACTION - LAW
CERTIFICATE OE SERVICE
I, Shelley Eichelberger, hereby certify that a true and correct copy of a Praecipe in the above
captioned matter, was duly served upon Cliffdale Associates, by depositing it in the U.S. Mail, postage
paid, on March 17, 2000, addressed as follows:
Cliffdale Associates
1010 Brentwater Road
Camp Hill, PA 17011
I hereby verify that the statements made in the foregoing are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to
unworn falsification to authorities.
QI 1
Dated: 3117/DD
Shelley 'ichelberger
I
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DIANE M. NIGHBERT,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
V.
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
NANCY BERGERT, individually and as a
member and managing partner of
CLIFFDALE ASSOCIATES, a Pennsylvania
Partnership; and
NO. 90.3330
WILLIAM T. WRIGHT, 11, individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
HASBROUIC S. WRIGHT, JR., individually and
as a member of CLIFFDALE ASSOCIATES,
a Pennsylvania Partnership; and
KEYSTONE SPINE CENTER, INC.,
Defendants
CIVIL ACTION - LAW
CERTIFICATE VICE
I, Shelley Eichelberger, hereby certify that a true and correct copy of a Praecipe in the above
captioned matter, was duly served upon Keystone Spine Center, INC., by depositing it in the U.S. Mail,
postage paid, on March 17, 2000, addressed as follows:
Keystone Spine Center, INC.
1621 Cedar Cliff Road
Camp Hill, PA 17011 -
1 hereby verify that the statements made in the foregoing are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to
unsworn falsification to authorities. _C (^
Datcd:3//7/DD
Shelleywichelberger
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