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Home My WebLink About03-4232RUSSELL ERIC READY and WALTER R. READY, individually and as Executors of the Estate of Russell Ready, Deceased and BEATRICE R. READY, Plaintiffs THE NIGHTINGALE NURSING HOME, 1NC,, doing business as MANORCARE HEALTH SERVICES - CAMP HILL, MANOR CARE, INC. AND MANOR CARE OF AMERICA, INC., Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003- ~/o~3~ ~ CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR WRITS OF SUMMONS TO THE PROTHONOTARY: Please issue Writs of Summons directed to Defendants The Nightingale Nursing Home, Inc., doing business as ManorCare Health Services - Camp Hill, Manor Care, Inc. and Manor Care of America, Inc., at 1700 Market Street, Camp Hill, Pennsylvania. SNELBAKER, BRENNEMAN & SPARE, P. C. LAW OFFICES SNELBAkER, BRENNeMAN & SPARE Date: August 27, 2003 Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiffs Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS Russell Eric Ready and Walter R. Ready, individually and as Executors of the Estate of Russell Ready, Deceased and Beatrice R. Ready Plaintiff Vs. The Nightingale Nursing Home, Inc. doing business as ManorCare Health Services-Camp Hill, Manor Care, Inc. and Manor Care of America Inc. 1700 Market Street Camp Hill, PA Defendant Court of Common Pleas No. 03-4232 Civil Term In CivilAction-Law To The Nightingale Nursing Home, Inc., doing business as ManorCare Health Services - Camp Hill, Manor Care, Inc. and Manor Care of America, Inc. You are hereby notified that Russell Eric Ready and Walter R. Ready, individually and as Executors of the Estate of Russell Ready, Deceased and Beatrice R. Ready the Plaintiff has / have commenced an action in Civil Action-Law against you which you are required to defend or a default judgment may be entered against you. (SEAL) Date August 27, 2003 CURTIS R. LONG Prothonotary By Deputy Attorney: Name: Keith O. Brenneman, Esq. Address: Snelbaker, Brenneman & Spare, P.C. 44 W. Main Street M~.hc~r~, PA 17055 Phone: (717) 697-8528 Attorneys for Plaintiffs McKISSOCK & HOFFMAN, P.C. By: William J. Mundy, Esquire I.D.#: 57679 By: Edwin A.D. Schwartz, Esquire I.D. #: 75902 2040 LINGLESTOWN ROAD SUITE 302 HARRISBURG, PA 17110 (717) 540-3400 RUSSELL ERIC READY and WALTER R. READY, individually and as Executors of the ESTATE OF RUSSELL READY, DECEASED and BEATRICE R. READY Plaintiffs THE NIGHTINGALE NURSING HOME, INC., d/b/a MANORCARE HEALTH SERVICES- CAMP HILL, MANOR CARE, INC. AND MANOR CARE OF AMERICA, INC. Defendants ATTORNEYS FOR DEFENDANT, THE NIGHTINGALE NURSING HOME, INC., d/b/a MANORCAR£-'- HEALTH SERVICES - CAMP HILL, MANOI;', CARE, INC. AND MANOR CARE OF AMERICA, INC. IN THE COUP, T OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-4232 CIVIL ACTION - LAW JURY TRIALDEMANDED ENTRY OF APPEARANCE Kindly enter our appearance on behalf of Defendant, The Nightingale Nursing Home, Inc., d/b/a ManorCare Health Services - Camp Hill, Manor Care, Inc. and Manor Care of America, Inc., in the above-captioned. Respectfully submitted, McKissock & Hoffman, P.C. William J. Mundy,-E'-sg~ah~e I.D. No.: 57679 Edwin A.D. Schwartz, Esquire I.D. No.: 75902 2040 Linglestown Road Suite 302 Harrisburg, PA 17'110 (717) 540-3400 Dated: ,,~,,,~,.s"/,/~'~ Attorneys for Defendant CERTIFICATE OF SERVICE', I hereby certify that I am this day serving a copy of the foregoing Entry of Appearance upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, first-class postage prepaid; addressed as follows: Keith O. Brenneman, Esquire Snelbaker, Brenneman & Spare, P.C. 44 W. Market Street Mechanicsburg, PA 17055 (Counsel for Plaintiffs) By: McKissock & Hoff[p~n, P.C. William J. Mundy, Esqu~r'e '~ I.D. No.: 57679 Edwin A.D. Schwartz, Esquire I.D. No.: 75902 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 (717) 540-3400 Dated:~__ Attorneys for Defe~ndant McKISSOCK & HOFFMAN, P.C. By: William J. Mundy, Esquire I.D.#: 57679 By: Edwin A.D. Schwartz, Esquire I.D. #: 75902 2040 LINGLESTOWN ROAD SUITE 302 HARRISBURG, PA 17110 (717) 540-3400 ATTORNEYS FOR DEFENDANT, THE NIGHTINGALE NURSING HOME, INC., d/b/a MANORCARE HEALTH SERVICES - CAMP HILL, MANOR CARE, INC. AND MANOR CARE OF AMERICA, INC. RUSSELL ERIC READY and WALTER R. READY, individually and as Executors of the ESTATE OF RUSSELL READY, DECEASED and BEATRICE R. READY Plaintiffs THE NIGHTINGALE NURSING HOME, INC., d/b/a MANORCARE HEALTH SERVICES - CAMP HILL, MANOR CARE, INC. AND MANOR CARE OF AMERICA, INC. Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-4232 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE A COMPLAINT Please issue a Rule directed to Plaintiff to file a Complaint in the above-captioned matter within twenty (20) days of service or suffer judgment No__n Pros. Respectfully s..J,tl)mitted, Edwin A.F). Sch~r~, Esquire RULE AND NOW, this /~.,'/"/'", day of _~'~ ~ , 2003, upon consideration of Defendants' I Praecipe For Rule To File A Complaint, a Rule is hereby granted upon Plaintiff to file a Complaint within twenty (20) days of service, or suffer judgment Non Pros. Rule issued this ~[p'"l/'h:lay of_~L_, 2003. Curtis Long, Pr0thonotary(~r' ~ CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Praecipe for Rule to File A Complaint~Rule upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, first-class postage prepaid, addressed as follows: Keith O. Brenneman, Esquire Snelbaker, Brenneman & Spare, IP.C. 44 W. Main Street Mechanicsburg, PA 17055 ( Counsel for Plaintiffs) McKissock & Hoffman, P.C. William J. IVlun~, E,s~L~-e~ Identification No.: 57679 Edwin A.D. Schwartz, Esquire Identification No.: 75902 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 (717) 540-3400 Attorneys for Defendant SHERIFFIS RETURN - REGULAR CASE NO: 2003-04232 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND READY RUSSELL ERIC ET AL VS NIGHTINGALE NURSING HOME INC CPL. MICHAEL BARRICK Cumberland County, Pennsylvania, says, the within WRIT OF SUMMONS was served upon NIGHTINGALE NURSING HOME INC DBA MANORCARE HEALTH SERVICES the Sheriff or Deputy Sheriff of who being duly sworn according to law, on the 4th day of September, 2003 together with DEFENDANT at 1242:00 HOURS, at 1700 MARKET STREET CAMP HILL, PA 17011 by handing to DONNA RIESEN, BUSINESS MANAGER, ADULT IN CHARGE a true and attested copy of WRIT OF SUMMONS and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.35 Affidavit .00 Surcharge 10.00 .00 38.35 Sworn and Subscribed to before me this /7~ day of / 'Prothonotary So Answers: R. Thomas Kline 09/05/2003 SNELBAKER BRENNEM~ SPARE ~ Deputy"Sheriff SHERIFF'S CASE NO: 2003-04232 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND READY RUSSELL ERIC ET AL VS NIGHTINGALE NURSING HOME INC RETURN - REGULAR CPL. MICHAEL BARRICK , Cumberland County, Pennsylvania, Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 4th day of September, 2003 by handing to MANAGER, ADULT IN CHARGE copy of WRIT OF SUMMONS together with says, the within WRIT OF SUMMONS MANOR CARE INC DEFENDANT , at 1242:00 HOURS, at 1700 MARKET STREET CAMP HILL, PA 17011 DONNA RIESEN, BUSINESS a true and attested and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6 Service Affidavit Surcharge 10 16 O0 O0 O0 O0 O0 O0 Sworn and Subscribed to before me this /7 ~ day of A.D. t Prothonotary ' So Answers: R. Thomas Kline 09/05/2003 SNELBAKER BRENNEMAN SPARE By: ~ ~Deputy Shc~rl-Tf SHERIFF'S RETURN - REGULAR CASE NO: 2003-04232 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND READY RUSSELL ERIC ET AL VS NIGHTINGALE NURSING HOME INC CPL. MICHAEL BARRICK , Cumberland County, Pennsylvania, Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 4th day of September, 2003 by handing to MANAGER, ADULT IN CHARGE true and attested copy of WRIT OF SUMMONS together with says, the within WRIT OF SUMMONS MA-NOR CARE OF ~4ERICA INC DEFENDANT , at 1242:00 HOURS, at 1700 MARKET STREET CAMP HILL, PA 17011 DONNA RIESEN, BUSINESS a and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this /7 ~ day of A.D. So Answers: R. Thomas Kline 09/05/2003 SNELBAKER BRENNEM3~N SPARE LAW OFFICES SNELBakEr. BRENNEMAN & SPARE RUSSELL ERIC READY and WALTER R. READY, individually and as Executors of the Estate of russell Ready, Deceased and BEATRICE R. READY, Plaintiffs THE NIGHTINGALE NURSING HOME, INC., doing business as MANORCARE HEALTH SERVICES - CAMP HILL, MANOR CARE, INC. AND MANOR CARE OF AMERICA, INC., Defendants IN THE COURT OF COMMON PLEAS OFI CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002; - 4232 Civil CIVIL ACTION - LAW JURY TFdAL DEMANDED PRAECIPE TO THE PROTHONOTARY: Please mark the above-captioned action discontinued and ended on your docket and indices. SNELBAKER, BRENNEMAN & SPARE, P. C. Date: October 23, 2003 Keith O. Brem~eman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiffs & SPARE CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have, on the below dat{ :aused a tree and correct copy of the foregoing Praecipe to be served upon the persons and ir nanner indicated below: FIRST CLASS MAIL, POSTAGE pREPAID, .ADDRESSED AS FOLLOWS: Edwin A. D. Schwartz, Esquire McKissock & Hoffman, P. C. 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 SNELBAKER, BRENNEMAN & SPARE, P.C. Date: October 23, 2003 By: Keith O. Brermeman, Esquire 44 W. Main Street P. O. Box318 Mechanicsburg, ]?A 17055 (717) 697-8528 Attorneys for Pl~fintiffs the