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HomeMy WebLinkAbout03-3085 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VAN I A No. (1L~ - ,3()RS ~;oLl'!-~ C i v i I Act i on - (X) Law ( ) Equ j ty CARL GROVE and MARGARET (PEGGY) GROVE, 5751 Union Deposit Road Harrisburg, PA 17111 TLC INVESTMENT, INC. t/d/b/a GOLDEN CORRAL 2125 South Queen Street York, PA 17403 GOLDEN CORRAL CORPORATION PO BOX 29502 versus Raleigh, NC 27626-0502 Plaintiff(s) & Address(es) Defendant(s) & Address(es) PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue writ of summons in the above-captioned action. X Writ of Summons shal I be issued and forwarded to ( )Attorney (X)Sheriff Richard H. Wix, Esq. Wix, Wenger & Weidner 4705 DUke Street Harrisbura. PA 17109-3099 (717) 652-8455 Names/Address/ Telephon No. of Attorney ~ l~ Jl W;,- Signature of Attorney Supreme Court ID No. 07274 Date: 6/27/03 WRIT OF SUK'40NS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. ~ ,(1d<r' J 12. 'CP Date:....)..t...0p .-V:>,.:l~ ~ d,n~ t? g .~v<.~ . , 'eL. Deputy ) Check here if reverse is issued for additional information PROTHON. - 55 1l (.:) ~ 'l 0 -- - C!t w 8 0 € 4) ~ (") a 0 6" c: (...,;; CI) ~ -n ~ -or)) ,- mn '- '-T. 2-' Z zr-' ," ::'......) .'r-;....i "t- (j'J" .,.,::..~ ~ ,,'- a -......-,: ::,' (-'-) <c. ',~ " E:(' -' :':.1 ~r: ,.--', '.' r,,) ii, :r:~~ :.n J< -l -C -.j ';'J -< SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2003-03085 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GROVE CARL ET AL VS TLC INVESTMENT INC TDBA GOLDEN 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: TLC INVESTMENT INC TDBA GOLDEN CORRAL but was unable to locate Them in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania, to serve the within WRIT OF SUMMONS On July 29th , 2003 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep York County 23.60 .00 60.60 07/29/2003 WIX WENGER WEIDNER So R. Thomas Kl'ine Sheriff of Cumber Sworn and subscribed to before me this t.. e;, day of ~("J-' ..Lov.,3 A.D. n . _ Q /rLjp,.. tJ.4:C ~ prothonota/y' COUNTY OF YORK OFFICE OF THE SHERIFF SER VICE CALL (717) 771-9601 28 EAST MARKET ST., YORK. PA 17401 SHERIFF SERVICE PROCESS RECEIPT and AFFIDAVIT OF RETURN INSTRUCTIONS PLEASE TYPE ONLY UNE 1 THRU 12 DO NOT DETACH ANY COPIES 1. PLAINTIFFfS/ Carl Grove and Margaret (Peggy) Grove 3.DEFENDANT!S! TLC Investment, Inc. and Golden Corral Corporation SERVE { 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION. ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD. ~ TLC Investment, Inc. ..".. 6. ADDRESS (STREET OR RFO WITH BOX NUMBER, APT NO.. CITY, BORa, 1WP., STATE AND ZIP CODE) AT 2125 South Queen Street, York, PA 17403 7. INDICATE SERVICE: ::J PERSONAL U PERSON IN CHARGE XXXOEPUTIZE ("J~~ 0 1ST CLASS MAIL \J POSTED NOW July 1,2003 ,20_I,SHERIFFOt- I:COUNT~~,~erebydeputiz Vork COUNTY to execute th~~ t to law. This deputization being made at the request and risk of the plaintiff. -r' SHERIFF OF COUNTY Cumberland 2. COURT NUMBER 03-3085 civil 4. TYPE OF WRIT OR COMPLAINT Writ of Summons U OTHER 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: OUT OF COUNTY CUMBERLAND ADVANCED FEE PAID BY ATTY NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriff's sale thereof. 9. TYPI;:N~MEamt.ADDRESSofATTORNEYfORIGINATORandSIGNATURE .f"i.J. ....1. A _ I tl' '\ ~ ~o. TELEPHONE NUMBER 111. DATE FILED R1Chard H, W1X, Esq. \~~ ~ 4705 Duke Street, HarriSburg, PA 17109 17-652-8455 6-30-03 12. .,SE;:ND)\IOTICE;.OF_SERVICl;COPYT.Q NAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed). R1Chard H. W1X, ~sq, CUMBERLAND CO SHERIFF 4705 Duke Street, Harrisburg, PA 17109-3099 SPACE BELOW FOR USE OF THE SHERIFF - DO NOT WRITE BELOW THIS LINE 13. I acknowledge receipt of the writ 114. DATE RECEIVED 115. Expiration/Hearing Date or complaint a, Indicated above. R. AHRENS 7-3-03 7-30-03 16. HOW SERVED: PERSONAL ( RESIDENCE ( ) POSTED ( ) POE>'l SHERIFPS OFFICE ( ) OTHER ( 17 ~ r hereby certify and return a NOT FOUND because I am unable to locate the indiVidual, company, etc name above (See remarks below) 18 ')t~mf)tyY\SErVf:L1~~H:~~on'h'PtoDefendant) 21 ATTEMPTS I Date I T,me li'b' I'ntl~t~ TIme I Mle, 1'01 I Date I TIme I M"e, lint I Date 1 TIme j M'le'l'nt 22. REMARKS: O\q,V\~ M.. 'fC--vvT\ - .8oej:.~~, SEE REMARKS BELOW 11g il"7j:; 120 ;~:53;; I Date I TIm~ Mle, lint I Date I TIme I M,'e, lint 0f\lJJ C 3> 3 ) 23. Advance Costs 124. Service Costs /25. N/F 126. Mileage 127. postagel28. SubTotal 129. Pound 130. Notary 131. 7S.00 18.00 3.60 21.6, 7.00 34. Foreign County Costs '35. Advance Costs /36. Service Costs 137. Notary Cert. 38. Mileage/Posted/Not Found 41. AFFIRMED and subscribed to before me this 24th 42. day of July, 20....Q;;l43. f!?l/PV surchg.132. Tot. Costsj33, CosIsDueofiii!! I~heck No. 7,.60 $S1.40 V~~ 139, Total Costs 140. Costs Due or Refund t)~ t ~SOAN~WERS . Signature of Dep.Sheriff . . Signature of York ~ ~ . ~ NOT"RIAL ilEAL County She"" V' ~~ rrJ. ELlsg~JQ$fW~~?:j~~t~~~I'UbIlC WILLI M. HSOE, SHERIFF . 'J.~ml"IQ~ .pl 20, 6 48. Signature of Foreign jf ." . \.~ I} County Sheriff 50. I OWL GE REC T OF THE SHE IF ETW(N SIGNATURE 151. DATE RECEIVED o AUTHORIZED ISSUING AUTHORITY AND I lE 45_,ofJE7/6 j 47. 6ATE 7/24/03 49. DATE 1. WHITE -Issuing Authority 2. PINK - Attomey 3. CANARY - Sherifrs Office 4. BLUE ~ Sheriffs Office . "",""",,"; _:?_\t.,"~::;-~: .~ "";''';.':h',' ';.l'.:,?,~i\Iot~~~~ )flliil"~l'I"."U>:~=:'~~" '-:;;;'~;'''~,y",....~_._+..,',," '" '-.-. COUNTY OF YORK , OFFICE OF THE SHERIFF SERVICE CALL (717) 771-9601 28 EAST MARKET ST., YORK. PA 17401 SHERIFF SERVICE PROCESS RECEIPT and AFFIDAVIT OF RETURN INSTRUCTIONS PLEASE TYPE ONLY LINE 1 THRU 12 DO NOT DETACH ANY COPIES , t I ~ \ i ! I f' [; ~ II II Ii , , ~ i 1. PLAINTIFFISI Carl GrOVt= and .t--'larqaxe-c (Peggy) (~YUVC 3. DEFENDANT/51 'rLC I;~v(-?:stme,nt: I Inc.' ~ and Golden Corral COJ~'por2.l.tion SERVE { 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD . 6. ADDR~;~%TR~~VO:~F~1:~~1 ~~ N~I~~~,.APT NO., CITY, BORO, TWP., STATE AND ZIP CODE) AT 212::', SOlJth Queerl ~~i:-rel},tf 01J';'/ :)i\ J..}~103 7 INDICATE SERVICE: LJ PERSONAL~I PERSON IN CHARGE X'}.u DEPUTIZE ~ :;J~R;I= j\;lAl~>: Q 1 ST CLASS MAIL (] POSTED 0 OTHER NOW J Lii' " ,'GO:., ,20 _ I, SHERIFF OF~OUNTY, PA, do hereby deputize Ih sheriff of , Ynrl< , , COUNTY to execute thiS~r' ~~ return the ~ng to law, ThiS deputlzatlon being made at the request and nsk of the plaintiff. .....~""',...""""AoC,"" -' SHERIFF OF~ OUNlY r:uJ"b~~TJ.and 2 COURT NUMBER 03-JOB5 civil 4 lYPE OF WRIT OR COMPLAINT ~i]rit. of S-:"lmm().i,~:, 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE "I' NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff 10 any plaintiff herein for any loss, destruction, or removal of any property before sheriffs sale thereof 9. lYF,~ NAM~ ~!l~AD8RES~ oi~~-r:ORN~~/ ORIGINATOR and SIGNATURE .~: .) .; _ f.- 1, ! 1 ' h_.ch0.,'-- c. n. 1,\ J........, E~)q. r ':""I"i t.,,").!\;' ..... ....~--";"I'; 4705 Duke Street, Harrisburg, PA 17109 12. ~~~!~\.N?1T~~,~ OF?ERV,IS~ ~?PY Tq ,!:lAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed);_" ~_.#&1~_,~ 11. kl,L~1 E~q. _ 4705 Duke Street, Harrisburqf PA 17109-3099 SPACE BELOW FOR USE OF THE SHERIFF -'- DO NOT WRITE: BELOW.THlS' LINE 13. I acknowledge receipt of the writ \14: '~AT:.RE~EIVED 115. ExpirationlHearing Date or complaint as indicated above. _ i -, _ --. ) 16 HOW SERVED: PERSONAL ( RESIDENCE ( POSTED ( ) POEj41 SHERIFF'S OFFICE ( ) OTHER ( ) 17. Q I herePY certify and return a NOT FOUND because I am unable 10 locate the individual, company, etc. name above_ (See remarks below.) 18)("~ A~b, T,'T4EOF'ND'V'~UAL S:RV,\D / LIST ~ORESS H~T'F~~': SHt~~ AB!~~ (R,'ailo05hIP 10 Defendanl) 21 ATTEMPTS I Dale l"me I t;s 1'01 I'Dale l"me I Miles I'nl I Dale l"me I Miles I'nl I Dale l"me I Miles I'nl 22. REMARKS, I). ,.VI UC co d\ _ D, i, , '. h. 1')'\'~ -, "Ot:'\'');-,....ev(;'' 1'0 TELEPHONE NUMBER r 17-6~)2~R((455 1" DATE FILED f e_." SEE REMARKS BELOW 11,9~ ~te~ ~rvice 120, Tim"e,_~f,:~rvIC, e , ./;' J 'i~ ~ J,:,", .' ''''',,-0,,... " ; " ' '. ~ or; '_'I I Oale I 11me'l Miles I'"t I Dale I 11'me I ;"n.s 1'"1 I \, .;;ji)iiv'0 '; j " t,: C,,- ,-, '}",.: 23. Advance Costs \24 Service Costs \25, N/F 126, Mileage r'7. postage\28. Sub Total 129. Pound \30.. Notary 131. surchg'132. Tot. COSIS\33. Costs Duec{~ (Check No. , ~g.OO .l.hn ~'1.6n 2.00 .'] 6\' $51 ~;;".~ V&j{,.;,;;' 34. Foreign County Costs ;.'I~~:,'~vanceCostst36. Service Costs 137. NotaryCert. /38. Mileage/PostedlNotFound 139, TttalCosts 140. Costs Due or Refund 41. AFFIRMED and sUQ)ci"ibedtc; beto,r,e ,.me this ?: 4 tn .' "" ~.J /1;. ':1A so A~WERS J 1 - ._~,"".-:"- "44. Signature of t',. 1/ 45. DATE ';.-. 42 day of ,ui ,2~..+:J43pROTHfNOTARY _~~~:~:'~;~;:fYOr;'-)Non L '!~."__",,,"_-4'. ./...J. . .~_~ 4;;6A~1/~.} ~--, _q'_"-'~- County Sheriff ~' ,/ '~~.~, #"'/ /1/t'1oIII:-----. 'J ,'/ILJ.IA/.lI'l. HSOE, SHERIF'F' '/ 04/(;, LJ,;~u{V(-J,~ RE~JT OF ~.?j~Ml j~~~l,. S'GNAT:E g~~~f:u~~~:;ore;gn 151. D"TE RECE':D OATE . OTAUTHORIZED ISSUING AUTHORllY ANfftftLE , r r , 't.' ~' 1. WHITE -Issuing Authority 2. PINK - Attorney 3, CANARY - Sheriff's Office :4. BLUE - Sheriffs Office ~ COUNTY OF YORK (" ,>, . '."., OFFICE OF THE SHERIFF SERVICE CALL (717) 771-9601 28 EAST MARKET ST.. YORK, PA 17401 SHERIFF SERVICE PROCESS RECEIPT and AFFIDAVIT OF RETURN INSTRUCTIONS PLEASE TYPE ONLY LINE 1 THRU 12 DO NOT DETACH ANY COPIES 1. PLAINTIFF/S/ Carl Grove and Margaret (Peggy) Grove 2. COURT NUMBER 03-3085 civil 4. TYPE OF WRIT OR COMPLAINT 3. DEFENDANT/51 TLC Invest..ment i Inc!lo and Golden Corral Coroorution SERVE { 5. NAME ~~ ~DIVIDUAL. COMPANY, CORPORATION, Ere. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATIACHED, OR SOLD, ........ TLC Investment" Inc. .".. 6. ADDRESS (STREET OR RFO WITH BOX NUMBER, APT. NO., CITY, BORD, TWP., STATE AND ZIP CODE) AT 2125 South Queen Str~€t, York, PA 17403 7. INDICATE SERVICE: o PERSONAL !.:.:I PERSQN IN CHARGE X?lXOEPl,lTIZE C'1....~.~, u 1STCl1SS MAIL [JPQSTED !:.lOTHER .NOW July 1, 2003 ,20 _I, SHERIFF OF I: CC>UNTY,.E..p.A A"W. h. e.rebYd..epy~~. sheriff of . York . . COUNTY to execute t~~~Cl.~:r%\.!:lrnj1PeT'~~~ding to law. This deputlzatlon being made at the request and risk of the plaintiff. .,. 't' . SHERIFF OF~ COUNTY Cumberland Writ of Smmnons 8. SPECIAL iNSTRUCTIONS OR OTHER INFORMATION THAT WilL ASSIST IN EXPEDITING SERVICE: , ,. ~ -,J' , ,. 'J .., -.; ,,~ J. ~. NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriff's sale thereof 9 TYP~ NAME anqADORESS of.ATTORNEY / ORIGINATOR and SIGNATURE LI", '. .,....l..n ,,,,,\... \-\ LJ;.<' ~10. TELEPHONE NUMBER R~chard H, W~x, Esq. \~, ~~ 4705 Duke Street, Harrisburg, PA 17109 17-652-8455 12. ~rgft~Ti?d.OF tf~RV~15?:Y T~ ~q: AND ADDRESS BELOW: (This area must be completed if notice is to be mailed)() ;: j' i '. 'i . k: Lt. 1 1 n. . , 4705 Duke Street, Harrisburq, PA 17109-3099 SPACE BELOW FOR USE OF THE SHERIFF ~ DO NOT WRITE BELOW THIS' LINE 13, I acknowledge receipt of the writ ., ," \ ~' I ,14:.." ._DA..T....~ R.~.. .~EIVED 115. .-./E~i:~.t.~."", _IH,..~.a.~,..ng Date or complaint as indicated above, ic.. i, I...." -, ~, .' . __ ~ . '. .16. HOW SERVED: PERSONAL ( ) RESIDENCE ( ):OSTED ( ) POEj't SHERIFF'S OFFICE (- ) OTHER ( ) SEE REMARKS BELOW 17. U r herebY certify and return a NOT FOUND because I am unable to locate the individual, company, etc. name at>ove. (See remarks below.) 18"~ NJMr~NQ ~,'TlE.pF INDIV'q.~.A~\ SERV~_.D I LIST ADDRESS HERf 'F, N?~ s~o~,~ ~B?~,~ ("efationship to Defendant) 119. ~ale of ~Nice 120. 1ime~f ~eNice )(." ,.,\... '\.'".) 7["7173 lo,.,!','! 21. ATTEMf'TS I Date l"me I /~s ( Int~' Date l"me / Mles lint I Date l"me I Miles lint I Date l"me I Miles lint I Date l"me I Miles /'nt I Date l"me I ~s r Int 22. REMARKS, 0 . ^' .(.. v'''' -.B f..' L . -\'I"'e., PI 00 1?'-f4i<'r' 1" ~D~T: F,'~E~ ~JFF' \ \ , \, . . I \ fhvf'!) ,\. ~ "'" .-,if.; r /, 23. ~:an~e c;oSIs 124. .S.' eNice cos..lsl. 25. N/F 126. Mileage iT postagel28. Sub Tolal 129. Pound 130. Notary 131. Surchg,!32, Tot Costs I 33. C<"\sD",~ ICheck ~o.. i , _ ," ,e.QO'i. ,. 60 /1.>;~ 7 (If) 23 60 ~"l 1" V0l'R;7x 34. Foreign County COS::"~~:'J~f~..~~:~~~~;~l~~' Service Costs '37. Notary Cert.,38. Mileage/Posted/Not Found , 39. Total Costs /40":" -r;osts l)ue or Refund 41.AFFIRMEDandsu~ch~d1i;~efor.e..me~'t~~':'.'\::'j2'4th S' - f\'" J' , JfJ SO"WERS 42. day of Ju1 i .. ,2~...)l343': .e,-'r .1 ~%~~~~ v"""":.. \ 1 tJAA.~' 't 45.~/fJ1Io] v. PI10TIi I NOTARY .~. Signature of York r //.J'} _ A ~ .. 47. b~TE -_....-- County Sheriff ' ..... - .- "'~~ -I"'[?'r ~ . c' .i WILLr~ 14. HSOE, SHERIFF 7/24/03 U l~{k~E RE';J~::~~1t~:lj.111N SIGNAT~/~~~~u~~~~:orelg~ 151. DATE RECEI::D DATE cifAUTHORIZED ISSUING AUTHORITY AN~ - 1. WHITE -Issuing Authority 2. PINK - Attorney 3. CANARY - Sheriff's Office "4. BLUE - Sheriff's Office BARRY A. KRONTHAL, ESQUIRE Pa. Supreme Court I.D. No. 55672 MARGOLIS EDELSTEIN P. O. Box 932 Harrisburg, P A 171 08-0932 Telephone: (717) 975-8114 Facsimile: (717) 975-8124 E-Mail: bkronthal@margolisedelstein.com Attorneys for Defendant, TLC Investment File# 38500.4-00064 CARL GROVE AND MARGARET (PEGGY) GROVE Plaintiffs COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA vs. NO. 03-3085 CNIL ACTION LAW TLC INVESTMENT, INC. T/D/B/A GOLDEN CORRAL, AND GOLDEN CORRAL CORPORATION JURY TRIAL DEMANDED Defendants PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly enter my appearance on behalf of Defendant, TLC Investment, Inc., tldlb/a Golden Corral, in the above-captioned matter. I am authorized to accept service on behalf of said Defendant. DATE (zo /6'{ By: Ba 1\. Kronthal, Esquire Attorney No. 55672 3510 Trindle Road Camp Hill, PA 17011 717-975-8114 Attorney for Defendant. TLC CERTIFICATE OF SERVICE I, the undersigned, do hereby certify that I have this ;)jL day 0~l(liU3j2Q04, served a true and correct copy of the Praecipe to Enter Appearance upon the person(s) and in the manner indicated below: Service bv First Class Mail. Postafle Prepaid. Addressed as Follows: Richard H. Wix, Esquire 4705 Duke Street Harrisburg, PA 17109-3099 Golden Corral Corporation P.O. Box 29502 Raleigh, NC 27626-0502 MARGOLIS EDELSTEIN By: /\ Ii /J /1 ( ~_ ...~ /t,--- Carol Moose D:\l Selective Insurance\38500A-00064\Pleads\Entry of Appearance.1-9-04.wpd -~ ..... () '" 0 = c- c.::,;' -n .- ~:~ (- -I --'-' c. -J: l'~'-I )::::;.. "T1 ~ rn f= -n ill ,,~ ~.)O ~.~~ ~1,:1 , V r,":? -'n -:.. () . rT'! (...) I '::'::':j c:J ~j en BARRY A. KRONTHAL, ESQUIRE Pa. Supreme Court I.D. No. 55672 MARGOLIS EDELSTEIN P. O. Box 932 Harrisburg, PA 17108-0932 Telephone: (717) 975-8114 Facsimile: (717) 975-8124 E-Mail: bkronthal@margolisedelstein.com Attorneys for Defendant, TLC Investmeot File# 38500.4-00064 CARL GROVE AND MARGARET (PEGGY) GROVE Plaintiffs COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA vs. NO. 03-3085 CNlL ACTION LAW TLC INVESTMENT, INC. T/D/B/A GOLDEN CORRAL, AND GOLDEN CORRAL CORPORATION JURY TRIAL DEMANDED Defendants PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please issue a Rule upon Plaintiff to file a Complaint within twenty (20) days from service hereof or suffer judgment non pros. DATE ~/~ olD 'I .KRONTHAL Attorney J.D. #55672 P.O. Box 932 Harrisburg, P A 17108-0932 (717) 975-8114 Attorney for Defendant TO THE PLAINTIFF: You are hereby ordered and directed to file your Complaint against Defendants in the above-captioned matter within twenty (20) days of service ofthis Rule against you or suffer judgment !lQIl1llQS. DATE: J:'cl J.L/, ).C>()t.j CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy ofthe foregoing Praecipe for Rule to File Complaint on all counsel of record by placing the same in the United States mail at Camp Hill, Pennsylvania, first-class postage prepaid, on the ~3 day of k1Jru~, 2004, and addressed as follows: Richard H. Wix, Esquire 4705 Duke Street Harrisburg, P A 17109-3099 Golden Corral Corporation P.O. Box 29502 Raleigh, NC 27626-0502 MARGOLIS EDELSTEIN By: (}JU) ~ Carol Moose o ~~~: \,. ( ~,~-. .c::. :;.! .- '" C.:,-;;l C.-:;l ~- -,., l~l.i co ~~~ C) -11 :-:;-1 :~~ -". ry r- Ui , " 0.3 -.)CJp.s (!;DLL~&J..n, CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy ofthe foregoing Praecipe for Rule to File Complaint on all counsel of record by placing the same in the United States mail at Camp Hill, Pennsylvania, first-class postage prepaid, on the --.!:.~ day of ~ 2004, and addressed as follows: Richard H. Wix, Esquire 4705 Duke Street Harrisburg, P A 171 09-3099 Golden Corral Corporation P.O. Box 29502 Raleigh, NC 27626-0502 MARGOLIS EDELSTEIN By: ~e..oc f'rL- Carol Moose BARRY A. KRONTHAL, ESQUIRE Pa. Supreme Court I.D. No. 55672 MARGOLIS EDELSTEIN P. O. Box 932 Harrisburg, PA 17108-0932 Telephone: (717) 975-8114 Facsimile: (717) 975-8124 E-Mail: bkronthal@margolisedelstein.com Attorneys for Defendant, TLC Investment File# 38500.4-00064 CARL GROVE AND MARGARET (PEGGY) GROVE Plaintiffs COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA vs. NO. 03-3085 CNIL ACTION LAW TLC INVESTMENT, INC. T/D/B/A GOLDEN CORRAL, AND GOLDEN CORRAL CORPORATION JURY TRIAL DEMANDED Defendants PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly file the attached Certificate of Service of the Rule to File Complaint of Defendant, TLC Investment, Inc. t/dlb/a Golden Corral. MARGOLI DELSTEIN DATE ;;./ :2<t! D 1 R ONTHAL Attorn J.D. #55672 P.O. Box 932 Harrisburg, PA 17108-0932 (717) 975-8114 Attorney for Defendant TO THE PLAINTIFF: You are hereby ordered and directed to file your Complaint against Defendants in the above-captioned matter within twenty (20) days of service of this Rule against you or suffer judgment non~. DATE: Prothonotary, Cumberland County . "---"",---<,' BARRY A. KRONTHAL, ESQUIRE Pa. Supreme Court I.D. No. 55672 MARGOLIS EDELSTEIN P. O. Box 932 Harrisburg, P A 171 08-0932 Telephone: (717) 975-8114 Facsimile: (717) 975-8124 E.Mail: bkronthal@margolisedelstein.com Attorneys for Defendant, TLC Investment File# 38500.4-00064 CARL GROVE AND MARGARET (PEGGY) GROVE Plaintiffs vs. TLC INVESTMENT, INC. T/D/B/A GOLDEN CORRAL, AND GOLDEN CORRAL CORPORATION Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA NO. 03-3085 CNlL ACTION LAW JURY TRIAL DEMANDED PRAECIPE FOR RUI,E TO FILE COMPLAINT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: o ~:; ;'Cj '. Co' ~~~; ~ --. "" c::;) c=., .-:- ...., fTl CD ,,~ oJ 1') .J:"" C.il () -n ::,--J ~,'-, '1 rnr:-.:c -l1r'" :l:JO OJ.. :.:;j ~j:~ ~~ f~~; :,.! ~.l . ~... :::} Please issue a Rule upon Plaintiff to file a Complaint within twenty (20) days from service hereof or suffer judgment non pros. DA TE ~/ ~ OlD 'I .KRONTHAL Attorney J.D. #55672 P.O. Box 932 Harrisburg, P A 17108-0932 (717) 975-8114 Attorney for Defendant TO THE PLAINTIFF: You are hereby ordered and directed to file your Complaint against Defendants in the above-captioned matter within twenty (20) days of service of this Rule against you or suffer judgment IlQIl~. DATE: )-'&1:,;).,-/ ;WOlf '. TRUE COpy FROM RECOR~rothonotary, Cumberland Co In Testimony whereof, I here unto set my hand and the seal 01 S<iid t Caflisle, Pa. ay 01 g .,.. -.J 5.:' r1"1 p~\ -c? """'; ~~"" zc.: ((J~:__ ~,u :!.;:C") ~C) )>~ ::-4 -< 'vv' r-> = = ...,.. :x :>> ;;0 I W -0 :::J: ~ z:- o -n :r:n m,... -om 86 ~...,..~ :I:;:!J 00 :;;m L.I ---I ~ '< ~1 CARL GROVE AND MARGARGET (PEGGY) GROVE, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3085 v. CIVIL ACTION - l_AW TLC INVESTMENT, INC. Ud/b/a GOLDEN CORRAL, and JURY TRIAL DEMANDED GOLDEN CORRAL CORPORATION, : Defendant NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND CO. BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demand as que se presentan mas adelante en las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despues de la notificaci6n de esta Demanda y Aviso radicando personalmente 0 por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito SllS defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se Ie advierte de que si usted falla de tomar acci6n como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demand a 0 cualquier otra reclamaci6n 0 remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero 0 propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME 0 VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER IINFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CUALlFICAN. CUMBERLAND CO. BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 CARL GROVE AND MARGARGET (PEGGY) GROVE, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3085 v. CIVIL ACTION - LAW TLC INVESTMENT, INC. tJd/b/a GOLDEN CORRAL, and JURY TRIAL DEMANDED GOLDEN CORRAL CORPORATION, : Defendant COMPLAINT AND NOW come the Plaintiffs, by their attorneys, Wix, Wenger & Weidner and set forth the following Complaint. 1. The Plaintiffs are adult individuals, husband and wife, residing at 5751 Union Deposit Road, Harrisburg, Pennsylvania 17111, 2, Defendant TLC Investment, Inc. is a corporation having its principal offices located at 2125 South Queen Street, York, Pennsylvania 1"7403. 3. Golden Corral Corporation is a corporation having its principal offices located at P,O. Box 29502, Raleigh, North Carolina 27626. 4. The facts and occurrences hereafter related took place on or about July 13, 2001 at approximately 9:00 p.m. at the Golden Con"al restaurant on the Carlisle Pike, Cumberland County, Pennsylvania, 5. Defendant Golden Corral Corporation was the franchisor of the restaurant located on the Carlisle Pike, known as the Golden Corral restaurant, and had the legal right to control the premises and its franchisee in the manner in which the restaurant was operated. 6. Defendant TLC Investment, Inc. is the franchisee and operator of the Golden Corral restaurant located on the Carlisle Pike, and at all times material hereto, Defendant was in ownership, possession and/or control of the premises and was responsible for maintaining the safe condition of the property known as the Golden Corral restaurant. 7. On July 13, 2001, Plaintiffs had eaten dinner at the above restaurant and were business invitees of the Defendants. 8. After Plaintiffs had finished their dinner, Plaintiff Peggy Grove went to the ladies' room prior to leaving the restaurant. 9. While Peggy Grove was in the ladies' room, the agents, servants and employees of Defendants began mopping the floors of the restaurant and as Peggy Grove was walking from the ladies' room toward the exit door, she slipped on a wet, slippery floor and fell sustaining the injuries hereinafter set forth. 10. At all times material hereto, Defendants, who had exclusive of said premises, allowed or caused the floors of the restaurant to be wet and slippery, constituting a dangerous condition. 11. At all times material hereto, there were no warning signs posted on the premises or other precautions taken or available so as to prevent the Plaintiff from falling. 12. The aforesaid accident and injuries resulting therefrom were due to the negligence of the Defendants in that they: 2 , ' a) caused the floor to be wet and slippery and thereby posing a dangerous condition and an unreasonable risk of injury to the Plaintiff and other persons lawfully upon the premises; b) in causing or permitting the floors to be wet while patrons were still in the restaurant when Defendants knew or should have known of the likelihood of the condition .of the wet floors to be a slipping hazard to persons using the premises; and c) in failing to make a reasonable inspection of said premises which would have revealed the existence of the dangerous condition posed by the wet floor and thereby allowing the same to be and remain a dangerous condition when the Defendants knew or should have known of it; d) in failing to insure that the area open to the plJblic at said premises was maintained in a safe condition to prevent injury to the Plaintiff and other persons lawfully upon the premises; e) in failing to place any signs or warnings to the public of the dangerous condition; f) failing to have adequate safeguards to prevent persons from slipping on the premises; and g) in maintaining the dangerous condition and failing to make the premises safe for business invitees such as the Plainti"ff. 13. Solely as a result of the Defendants' negligence, Plaintiff Peggy Grove sustained serious injuries including, but not limited to, a fracture through the surgical 3 neck of the humerus, an avulsion fracture from the upper alveolar ridge, damage to her teeth, as well as numerous cuts and abrasions, and injuries to her nerves and nervous systems. 14. As a direct and proximate result of the ne!Jligence of the Defendants, Plaintiff Peggy Grove has undergone great physical pain, discomfort and mental anguish and she will continue to endure the same for an indefinite period of time in the future to her great detriment and loss, physically, emotionally and financially. 15. As a direct and proximate result of the ne9ligence of the Defendants, Peggy Grove has been and will in the future be hindered from attending to her daily duties to her great detriment, loss, humiliation and embarrassment. 16. As a direct and proximate result of the negligence of the Defendants, Peggy Grove has and will in the future suffer a loss of life's pleasures. COUNT I MARGARET (PEGGY) GROVE v. TLC INVESTMENT. INC. tJd/b/a GOLDEN CORRAL 17. Plaintiffs incorporate herein by reference the allegations of paragraphs 1 through 16 of this Complaint. 18. Defendant TLC Investment, Inc. was negli~lent in causing the Plaintiffs injuries in that its agents, servants and employees were ne91igent as follows: a) caused the floor to be wet and slippery and thereby posing a dangerous condition and an unreasonable risk of injury to the Plaintiff and other persons lawfully upon the premises; 4 b) in causing or permitting the floors to be wet while patrons were still in the restaurant when Defendants knew or should have known of the likelihood of the condition of the wet floors to be a slipping hazard to persons using the premises; and c) in failing to make a reasonable inspection of said premises which would have revealed the existence of the dangerous condition posed by the wet floor and thereby allowing the same to be and remain a dangerous condition when the Defendants knew or should have known of it; d) in failing to insure that the area open to the public at said premises was maintained in a safe condition to prevent injury to the Plaintiff and other persons lawfully upon the premises; e) in failing to place any signs or warnings to the public of the dangerous condition; f) failing to have adequate safeguards to prevent persons from slipping on the premises; and g) in maintaining the dangerous condition and failing to make the premises safe for business invitees such as the Plaintiff. WHEREFORE, Plaintiff demands judgment against the Defendant in excess of $35,000.00. 5 i '. . " COUNT 1\ CARL GROVE v. TLC INVESTMENT. INC. tJd/b/a GOLDEN CORRAL LOSS OF CONSORTION 19. Plaintiffs incorporate herein by reference the allegations of paragraphs 1 through 18 of this Complaint. 20. As a result of Defendant's negligence and careless that have caused personal injuries to his wife, Plaintiff Carl Grove has lost and will continue to lose the companionship, comfort, society, services and other forms of consortion of his wife. WHEREFORE, Plaintiff demands judgment against the Defendant in excess of $35,000.00. COUNT III MARGARET (PEGGY) GROVE v. GOLDEN CORRAL CORPORATION 21. Plaintiff incorporates herein by reference the allegations of paragraphs 1 through 20 of this Complaint. 22. Defendant Gold Corral Corporation as franchisor had the right to control the actions of Defendant TLC Investment, Inc. and the manner in which the premises was operated as a restaurant and failed to exercise its right to control the operation of the premises in a safe manner, as ism ore particularly set forth in t he a lIegations of paragraph 18. WHEREFORE, Plaintiff demands judgment against the Defendant in excess of $35,000.00. 6 . " . " COUNT IV CARL GROVE v. GOLDEN CORRAL CORPORATION LOSS OF CONSORTION 23. Plaintiffs incorporate herein by reference the allegations of paragraphs 1 through 22 of this Complaint. 24. As a result of Defendant's negligence and careless that have caused personal injuries to his wife, Plaintiff Carl Grove has lost and will continue to lose the companionship, comfort, society, services and other forms of consortion of his wife. WHEREFORE, Plaintiff demands judgment against the Defendant in excess of $35,000.00. Respectfully submitted, WIX, WENGER I~ WEIDNER Dated: 7/? /0 y ~f7" } By ~~{ ii-;J ,/ Richard H. Wix: Esq., 10# 07274 Attorneys for Plaintiff 4705 Duke Street Harrisburg, PA 17109-3099 (717) 652-845~j 7 "', . . ., VERIFICATION I, Carl Grove, have read the foregoing Complaint which has been drafted by my counsel. The factual statements and/or denials contained therein are true and correct to the best of my knowledge, information and belief. I am authorized to make this verification. This verification is made only as to the factual averments contained therein and not to legal conclusions and averments authorized by counsel in his capacity as attorney for the party or parties hereto. This verification is made subject to the penalties of 18 PA. C.S. Section 4904, relating to unsworn falsification to authorities which provides that, if I knowingly made false averments, I may be subject to criminal penalties. Date: 1 h lo~ ~ ~ / .~ /~~A -. Carl Grove , '. '~I JI' 0, . CERTIFICATE OF SERVICE AND NOW, this 8th day of July, 2004, I, Gaye Crist, an employee of the firm of Wix, Wenger & Weidner, attorneys for Plaintiffs, hereby certify that I served the within Complaint this date by depositing a copy of same in the United States mail, postage prepaid, in Harrisburg, Pennsylvania, addressed as follows: Barry A. Kronthal, Esq. Margolis Edelstein P.O. Box 932 Harrisburg, PA 17108-0932 WIX, WENGER & WEIDNER __A~ ,~~) Gaye Crrs . . . C) '" 0 ~~ r-' ("':"4 -, ~ .-< -. '-- :T:--n ,- c:: nl.= f--~ -o;"n I ")6 \D Sc .....,~ '"1 t . -;:J ,-0_" , :::(. C,] c""j --. rn .. , r.., ~::l 0.- -.: c:") :q -< N ""' CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF, COURT OF COMMON PLEAS CARL GROVE AND MARGARET GROVE TERM, -VS- CASE NO: 03-3085 TLC INVESTMENT, INC. T/D/B/A GOLDEN CORRAL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. 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 ~ -P(B~Rq,TZt;, ESQ. 1&0 Attorney for DEFENDANT DATE: 03/07/2005 DEll-547487 SJ..l36-LOJ.. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CARL GROVE AND MARGARET GROVE TERM, -VS- CASE NO: 03-3085 TLC INVESTMENT, INC. T/D/B/A GOLDEN CORRAL NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ORTHOPEDIC INSTITUTE OF PA. FOREST HILLS DENTAL ASSOC. HEALTH SOUTH SPORTS MEDICINE WALTER B. WATKIN, JR., M.D. MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY{S) MEDICAL, BILLING, AND X-RAY(S) TO: RICHARD WIX , ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that is attacbed to this notice. You have twenty (20) days from tbe 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 expense by completing the attacbed counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/14/2005 MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT CC: BARRY A. KRONTHAL, ESQ. - 38500.4-00064 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-292399 81136-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARL GROVE AND MARGARET GROVE FileNo. 03-3085 vs. TLC INVESTMENT, INC. T/D/B/A GOLDEN SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HOI Y SPIRIT HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: .... SEE A TT ACHED RIDER .... at The MCS Grol<P Inc ]60] Market Street Suite 800 Philadelphia PA ]9]03 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: BARRY A. KRONTHAL ESO. 3510 TRINDLE ROAD CAMP HILL. PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: ~ (}U/L---ho ) ~ ~ Prothonotary/Clerk, Civil Di~ Date: h'b MAR 0 7 ZGDS t. ~ODS Seal of the Court 81136-01 EXPLANA nON OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL 503 NORTH 21ST STREET CAMP HILL, PA 17011 RE: 81136 MARGARET GROVE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. RECORDS FROM 111/2001 TO PRESENT Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treattnent, procedures, tests, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treattnent, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject: MARGARET GROVE 5751 UNION DEPOSIT ROAD, HARRISBURG, PA 17111 Social Security #: 201-18-1992 Date of Birth: 06-30-1925 SUlO-548258 8ll36-LOl CERTIFICATE PREREQUISITE TO SERVICE OF A SOB POENA PURSUANT TO RULE 4009.22 IN THE MATTER OF, COURT OF COMMON PLEAS CARL GROVE AND MARGARET GROVE TERM, -VS- CASE NO: 03-3085 TLC INVESTMENT, INC. T/D/B/A GOLDEN CORRAL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. 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, 03/07/2005 BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT DEll-S47488 8ll36-L02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CARL GROVE AND MARGARET GROVE TERM, -VS- CASE NO: 03-3085 TLC INVESTMENT, INC. T/D/B/A GOLDEN CORRAL NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ORTHOPEDIC INSTITUTE OF PA. FOREST HILLS DENTAL ASSOC. HEALTH SOUTH SPORTS MEDICINE WALTER B. WATKIN, JR., M.D. MEDICAL RECORDS ~ HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) TO: RICHARD WIX , ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. 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 whicb to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to NCS or by contacting our local MCS office. DATE: 02/14/2005 Nes on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT CC: BARRY A. KRONTHAL, ESQ. - 38500.4-00064 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 OE02-292399 B]']' 3 6 - CO]. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARL GROVE AND MARGARET GROVE FileNo. 03-3085 vs. TLC INVESTMENT, INC. TID/B/A GOLDEN SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009,22 TO: Custodian "fRecords for HOLY SPIRIT HOSPITAL (Name "fPerson or Entity) Within twenty (20) days after service "fthis subpoena, you are ordered by the court to produce the following documents or things: .... SEE A TT ACHED RIDER .... at The MCS Group Inc 160] Market Street Suite 800 Phi]adelpbia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: BARRY A. KRONTHAL. ESO. 3510 TRINDLE ROAD CAMPHII.L PA ]7011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: f;;L, MAR 0 7 2005 PI d,C6S' BY THE COURT: ~. Prothonotary/Clerk. Civi 4,,- b -e 7?;~ Deputy '---- Seal of the Court 8] ]36-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL 503 NORTH 21ST STREET CAMP HILL, PA 17011 RE: 81136 MARGARET GROVE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. DA TES FROM 1/1/01 TO PRESENT Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject: MARGARET GROVE 5751 UNION DEPOSIT ROAD, HARRISBURG, PA 17111 Social Security #: 201-18-1992 Date of Birth: 06-30-1925 SUID-54826D 81136-L02 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CARL GROVE AND MARGARET GROVE TERM, -VS - CASE NO: 03-3085 TLC INVESTMENT, INC. T/D/B/A GOLDEN CORRAL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. 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: 03/07/2005 BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT DEll-547489 8ll36-L03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CARL GROVE AND MARGARET GROVE TERM, -VS- CASE NO: 03-3085 TLC INVESTMENT, INC. T/D/B/A GOLDEN CORRAL NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ORTHOPEDIC INSTITUTE OF PA. FOREST HILLS DENTAL ASSOC. HEALTH SOUTH SPORTS MEDICINE WALTER B. WATKIN, JR., M.D. MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, AND X-RAY(SI MEDICAL, BILLING, AND X-RAY(SI MEDICAL, BILLING, AND X-RAY(SI MEDICAL, BILLING, AND X-RAY(S) TO: RICHARD WIX , ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. intends to serve a subpoena identical to tbe one that is attached to this notice. You have twenty (20) days from tbe date listed below in which to file of record and serve upon tbe undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attacbed counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/14/2005 MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT CC: BARRY A. KRONTHAL, ESQ. - 38500.4-00064 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET .800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-29239981136-C01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARL GROVE AND MARGARET GROVE FileNo. 03-3085 vs. TLC INVESTMENT, INC. TID/B/A GOLDEN SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ORTHOPEDIC INSTITUTE OF P A. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE A TT ACHED RIDER **** at The MCS Group Inc ]60] Market Street Suite 800 Phi]adelnhia PA 19101 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: BARRY A. KRONTHAL. ESO. 3510 TRINDLE ROAD CAMP HILL PA 170] I TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: ~~~R 072005 ~ ,2(..::0.. \' Seal of the Court 81136-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ORTHOPEDIC INSTITUTE OF PA. 875 POPLAR CHURCH ROAD CAMP HILL, PA 17011 RE: 81136 MARGARET GROVE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. DATES FROM 11112001 TO PRESENT Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: MARGARET GROVE 5751 UNION DEPOSIT ROAD, HARRISBURG, PA 17111 Social Security #: 201-18-1992 Date of Birth: 06-30-1925 8U10-548262 Bl136-L03 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CARL GROVE AND MARGARET GROVE TERM, -VS- CASE NO: 03-3085 TLC INVESTMENT, INC. T/D/B/A GOLDEN CORRAL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that II) 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: 03/07/2005 BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT DEll-547490 81136-L04 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CARL GROVE AND MARGARET GROVE TERM, -VS- CASE NO: 03-3085 TLC INVESTMENT, INC. T/D/B/A GOLDEN CORRAL NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ORTHOPEDIC INSTITUTE OF PA. FOREST HILLS DENTAL ASSOC. HEALTHSOUTH SPORTS MEDICINE WALTER B. WATKIN, JR., M.D. MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(Sl TO: RICHARD WIX , ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. 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 tbe subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/14/2005 MCS on bebalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT CC: BARRY A. KRONTHAL, ESQ. - 38500.4-00064 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-292399 a~~36-CO~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARL GROVE AND MARGARET GROVE File No. 03-3085 vs. TLC INVESTMENT, INC. T/D/B/A GOLDEN SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for FOREST HILLS DENTAL ASSOC. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: .... SEE A TT ACHED RIDER .... at The MCS Groll!) Inc 1601 Market Street Sllile ROO Philadel!)bia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: BARRY A. KRONTHAL. ESO. 3';] 0 TRINDLE ROAD CAMP HII.L PA 170] I TELEPHONE: (2] 5) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: ~ MAR \l 7 ZGOS ~S P. ;)..()6S . Deputy Seal of the Court 81136-04 EXPLANA nON OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: FOREST HILLS DENTAL ASSOC. 2247 FOREST HILLS DRIVE HARRISBURG, PA 17112 RE: 81136 MARGARET GROVE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. DATES RECORDS FROM 11112001 TO PRESENT Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: MARGARET GROVE 5751 UNION DEPOSIT ROAD, HARRISBURG, PA 17111 Social Security #: 201-18-1992 Date of Birth: 06-30-1925 8UlO-548264 8 ~ ~ 36 -LO 4 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CARL GROVE AND MARGARET GROVE TERM, -VS- CASE NO: 03-3085 TLC INVESTMENT, INC. T/D/B/A GOLDEN CORRAL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. 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: 03/07/2005 BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT DEll-547491 8~~36-L05 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CARL GROVE AND MARGARET GROVE TERM, -VS- CASE NO: 03-3085 TLC INVESTMENT, INC. T/D/B/A GOLDEN CORRAL NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ORTHOPEDIC INSTITUTE OF PA. FOREST HILLS DENTAL ASSOC. HEALTH SOUTH SPORTS MEDICINE WALTER B. WATKIN, JR., M.D. MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) TO: RICHARD WIX , ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. 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 expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/14/2005 MCS on bebalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT CC: BARRY A. KRONTHAL, ESQ. - 38500.4-00064 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-292399 B 11 3 6 - C 01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARL GROVE AND MARGARET GROVE FileNo. 03-3085 vs. TLC INVESTMENT, INC. TlDfB/A GOLDEN SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HEALTHSOUTH SPORTS MEDICINE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: .... SEE A TT ACHED RIDER .... at The MCS Group Ino ]60] Market Street Suite 800 Phi]adelobia PA ]9]03 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: BARRY A. KRONTHAL. ESO. 3510 TRINDI,E ROAD CAMP HILI. PA 17011 TELEPHONE: (2] 5) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: MA.R (; 7 ;-liD] ~vL, cf'L ~ Prothonotary/Clerk, Civil ~n_ q 9 71;~~ Deputy <.. Seal of the Court 81136-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HEALTHSOUTH SPORTS MEDICINE 450 POWERS A VENUE SUITE 102 HARRISBURG, PA 17109 RE: 81136 MARGARET GROVE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. MEDICAL RECORDS FROM 11112001 TO PRESENT Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: MARGARET GROVE 5751 UNION DEPOSIT ROAD, HARRISBURG, PA 17111 Social Security #: 201-18-1992 Date of Birth: 06-30-1925 8U10-548266 Sll36 -LO 5 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CARL GROVE AND MARGARET GROVE TERM, -VS- CASE NO: 03-3085 TLC INVESTMENT, INC. T/D/B/A GOLDEN CORRAL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. ce rt if i est ha t (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: 03/07/2005 BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT DEl1-547492 B 1. 1. 36 - L 06 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CARL GROVE AND MARGARET GROVE TERM, -VS- CASE NO: 03-3085 TLC INVESTMENT, INC. T/D/B/A GOLDEN CORRAL NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ORTHOPEDIC INSTITUTE OF PA. FOREST HILLS DENTAL ASSOC. HEALTH SOUTH SPORTS MEDICINE WALTER B. WATKIN, JR., M.D. MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(SJ TO: RICHARD WIX , ESQ.. PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from tbe date listed below in wbich to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made. then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/14/2005 MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT CC: BARRY A. KRONTHAL, ESQ. - 38500.4-00064 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-292399 B 11 3 6 - C 01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARL GROVE AND MARGARET GROVE FileNo. 03-3085 vs. TLC INVESTMENT, INC. T/DIBIA GOLDEN SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for WALTER B. WATKIN JR.. M.D (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: .... SEE A TT ACHED RIDER .... at The MCS Group Inc 1601 Market Street Suite ROO Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: BARRY A. KRONTHAL. ESO. 35] 0 TRINDLR ROAD CAMP HILL PA ] 701] TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: ~~tR (\ 7 2QO: " p. ~/'::>'<:>\ . Seal of the Court 81136-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: WALTER B. WATKIN, JR., M.D. 845 SIR THOMAS COURT SUITE 3 HARRISBURG, PA 17109 RE: 81136 MARGARET GROVE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x -ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: MARGARET GROVE 5751 UNION DEPOSIT ROAD, HARRISBURG, PA 17111 Social Security #: 201-18-1992 Date of Birth: 06-30-1925 SU10-5482G8 Bll36-L06 ------------- ,1'\ ~-,j - CARL GROVE and MARGARET (PEGGY) GROVE, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3085 CIVIL ACTION - LAW TLC INVESTMENT. INC. tJd/b/a GOLDEN CORRAL, and JURY TRIAL DEMANDED GOLDEN CORRAL CORPORATION, : Defendants To: Prothonotary PRAECIPE Please mark the above-referenced action as settled and discontinued with prejudice. Dated: 7/12/06 Respectfully submitted, WIX, WENGER & WEIDNER By r&~ L ~. (,.J,( Richard H. Wix, Esq., 10# 07274 Attorneys for Plaintiffs 4705 Duke Street Harrisburg, PA 17109-3099 (717) 652-8455 1'.' G\ ....._~".. C-'