HomeMy WebLinkAbout08-3229IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
Dawn R. Miller
100 Spangler Rd.
Lewisberry, PA 17339
Plaintiff
CIVIL ACTION-MEDICAL
PROFESSIONAL LIABILITY
ACTION
vS - 3.2? 0;. LV.
Frederick R. Mane, M.D.
168 N. 11th Street
Sunbury, PA 17801
And
Holy Spirit Hospital Behavioral Health
503 N. 21st Street
Camp Hill, Pa. 17011
Defendants
PRAECIPE TO ISSUE WRIT OF fflaIN9N5
TO THE PROTHONOTARY:
Kindly issue a Writ of Summons in the above-referenced matter, and forward the Writ to
the Sheriff for service upon the Defendants.
Respectfully submitted,
12
Dawn R. Miller
100 Spangler Rd.
Lewisberry, Pa. 17339
(717) 308-2899
9 : C71 -C
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Commonwealth of Pennsylvania
County of Cumberland
WRIT OF SUMMONS
DAWN R. MILLER
100 SPANGLER RD.
LEWISBERRY, PA 17339
Plaintiff
Vs.
FREDERICK R. MADE, M.D.
168 N. 11TH STREET
SUNBURY, PA 17801
AND
HOLY SPIRIT HOSPITAL
BEHAVIORAL HEALTH
503 N. 21sT STREET
CAMP HILL, PA 17011
Defendant
Court of Common Pleas
No 08-3229 CIVIL TERM
In CivilAction-Law
To FREDERICK R. MADE, M.D. AND HOLY SPIRIT HOSPITAL
BEHAVIORAL HEALTH,
You are hereby notified that DAWN R. MILLER the Plaintiff(s) 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) Cu s R. Lon o tary
Date MAY 22, 2008 By
Deputy
Attorney:
Name: DAWN R. MILLER
Address: 100 SPANGLER RD.
LEWISBERRY, PA 17339
Attorney for: Pro Se
Telephone: 717-308-2899
Supreme Court ID No.
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-03229 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MILLER DAWN R
VS
MAUE FREDERICK R MD ET AL
RONALD E HOOVER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within WRIT OF SUMMONS was served upon
TWATT'Ll V'0V VDTr1V D Mn the
DEFENDANT , at 0013:36 HOURS, on the 9th day of June 2008
at HOLY SPRIT HOSPITAL 503 N 21ST ST
CAMP HILL, PA 17013 by handing to
KAY TIPTON LEGAL COORDINATOR-RISK MGMT
a true and attested copy of WRIT OF SUMMONS
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 15.00
Affidavit .00
Surcharge 10.00
Postage .42
4J17)0V C - 43.42
Sworn and Subscibed to
before me this
of
So Answers:
R. Thomas Kline(
06/10/2008
DAWN MILLER
By: day Deputy Sheriff
A. D.
SHERIFF'S.RETURN - REGULAR
CASE NO: 2008-03229 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MILLER DAWN R
VS
MAUE FREDERICK R MD ET AL
RONALD E HOOVER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within WRIT OF SUMMONS was served upon
HOLY SPIRIT HOSPITAL BEHAVOIRAL HEALTH the
DEFENDANT , at 0013:36 HOURS, on the 9th day of June , 2008
at 210 SENATE AVENUE
CAMP HILL, PA 17011
3RD FLOOR
by handing to
KAY TIPTON LEGAL COORDINATOR-RISK MGMT
a true and attested copy of WRIT OF SUMMONS
together with
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
41)110y( 16..0000
Sworn and Subscibed to
before me this day
of ,
So Answers:
R. Thomas Kline
06/10/2008
DAWN R. MILLER
By : ??a???e??i??/
Deputy Sheriff
A. D.
326971
DICKIE, MCCAMEY & CHILCOTE, P.C.
BY Thomas M. Chairs, Esquire
ATTORNEY I.D. NO. 78565
BY Aaron S. Jayman, Esquire
ATTORNEY I.D. NO. 85651
1200 Camp Hill Bypass, Suite 205
Camp Hill, PA 17011
(717)731-4800 (Tele)
ATTORNEY FOR DEFENDANTS
FREDERICK R. MADE, M.D. AND HOLY SPIRIT
HOSPITAL BEHAVIORAL HEALTH
DAWN R. MILLER, PRO SE ,
Plaintiff
V.
FREDERICK R. MADE, M.D. AND HOLY
SPIRIT HOSPITAL BEHAVIORAL
HEALTH,
Defendants
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 08-3229
MEDICAL MALPRACTICE ACTION
JURY TRIAL DEMANDED
ENTRY OF APPEARANCE`
TO THE PROTHONOTARY:
Please enter the appearance of Thomas M. Chairs, Esquire and Aaron S. Jayman, Esquire, as
counsel for Defendants, Frederick R. Maue, M.D. and Holy Spirit Hospital Behavioral Health, in
the above-captioned matter.
Respectfully submitted,
DICKIE, MCCAMEY H COTE, P.C.
Date: July 1, 2008 By:
Th as M. Chairs, Esquire
Supreme Court I.D. No. 78565
1200 Camp Hill Bypass
Suite 205
Camp Hill, PA 17011-3700
(717) 731-4800
Attorney for Defendants, Frederick R. Maue, M.D. and
Holy Spirit Hospital Behavioral Health
CERTIFICATE OF SERVICE
AND NOW, July 1, 2008, I, Thomas M. Chairs, Esquire, hereby certify that I did serve a
true and correct copy of the foregoing ENTRY OF APPEARANCE upon all counsel of record
by depositing, or causing to be deposited, same in the U.S. mail, postage prepaid, at Camp Hill,
Pennsylvania, addressed as follows:
By First-Class Mail
Dawn R. Miller, Pro Se
100 Spangler Road
Lewisberry, PA 17339
(Plaintiff)
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DICKIE, MCCAMEY & CHILCOTE, P.C.
BY: Thomas M. Chairs, Esquire
ATTORNEY I.D. NO. 78565
1200 Camp Hill Bypass, Suite 205
Camp Hill, PA 17011
(717)7314800 (Tele)
(717)731-4803 (Fax)
DAWN R. MILLER, PRO SE,
Plaintiff
V.
FREDERICK R. MADE, M.D. AND HOLY
SPIRIT HOSPITAL BEHAVIORAL
HEALTH,
Defendants
ATTORNEY FOR DEFENDANTS
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 08-3229
c c
MEDICAL MALPRACTICE A ° OPZ
t
JURY TRIAL DEMANDED
PRAECIPE FOR RULE TO FILE COMPLAINT ^.
v
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nF
TO THE PROTHONOTARY:
Kindly issue a rule upon Plaintiff to file a Complaint in the above-captioned case within
twenty (20) days after service of the Rule or suffer a judgment of non pros.
Respectfully submitted,
DICKIE, MCCAMMEY & CHILCOTE, P.C.
Date: April 19, 2010 By._
4Thos. 4Chairs, Esquire
Supreme Court I.D. #78565
1200 Camp Hill Bypass, Suite 205
Camp Hill, PA 17011-3700
(717) 731-4800
Attorney for Defendants
CERTIFICATE OF SERVICE
AND NOW, April 19, 2010, I, Thomas M. Chairs, Esquire, hereby certify that I did serve
a true and correct copy of the foregoing PRAECIPE FOR RULE TO FILE COMPLAINT
upon all counsel of record by depositing, or causing to be deposited, same in the U.S. mail,
postage prepaid, at Camp Hill, Pennsylvania, addressed as follows:
By First-Class Mail:
Dawn R. Miller, Pro Se
100 Spangler Road
Lewisberry, PA 17339
7
Thomas airs, Esquire
DAWN R. MILLER, PRO SE,
Plaintiff
V.
FREDERICK R. MADE, M.D. AND HOLY
SPIRIT HOSPITAL BEHAVIORAL.
HEALTH,
Defendants
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
,
PENNSYLVANIA
C) N
o
NO. 08-3229 M
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MEDICAL MALPRACTICE ?9FION! ,
n.'
JURY TRIAL DEMANDED
RULE TO FILE COMPLAINT
AND NOW, this o21"' day of Apr('( , 2010, a Rule is hereby issued upon
Plaintiffs to file a Complaint in the above-captioned case within twenty (20) days after service of
the Rule or suffer a judgment of non pros.
Deputy
620335
CERTIFICATE OF SERVICE
#- 51;0? enll I
AND NOW, April 23, 2010, I, Thomas M. Chairs, Esquire, hereby certify that I did serve
a true and correct copy of the foregoing RULE TO FILE COMPLAINT upon all counsel of
record by depositing, or causing to be deposited, same in the U.S. mail, postage prepaid - return
receipt requested, at Camp Hill, Pennsylvania, addressed as follows:
By First-Class Mail:
Dawn R. Miller, Pro Se
100 Spangler Road
Lewisberry, PA 17339
(Pro Se)
(Return Receipt Requested)
Chairs,
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652722
DICKIE, MCCAMEY & CHILCOTE, P.C.
BY: Thomas M. Chairs, Esquire
ATTORNEY I.D. NO. 78565
BY: Aaron S. Jayman, Esquire
ATTORNEY I.D. NO. 85651
1200 Camp Hill Bypass, Suite 205
Camp Hill, PA 17011
(717)7314800 (Tele)
DAWN R. MILLER, PRO SE,
Plaintiff
V.
FREDERICK R. MADE, M.D. AND HOLY
SPIRIT HOSPITAL BEHAVIORAL
HEALTH,
Defendants
ATTORNEY FOR DEFENDANTS
Cz
IN THE COURT OF COMMO AX
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 08-3229
'
?a
MEDICAL MALPRACTICE ACTION
JURY TRIAL DEMANDED
DEFENDANTS' MOTION FOR SERVICE
PURSUANT TO SPECIAL ORDER OF COURT
AND NOW, come Defendants, Frederick R. Maue, M.D. and Holy Spirit Hospital
Behavioral Health, by and through their counsel, Dickie, McCamey & Chilcote, P.C., and move
this Honorable Court for an Order directing service of the Rule to File Complaint by publication
in accordance with Pennsylvania Rule of Civil Procedure 430(b)(1), and in support thereof aver
the following:
1. Pro Se Plaintiff, Dawn R. Miller, initiated this medical professional liability
action with the filing of a Writ of Summons on May 22, 2008. See Exhibit "A."
2. Counsel for the Defendants entered their appearance on July 2, 2008.
3. Plaintiff failed to take any actions to prosecute this matter and as a result the
4
Defendants filed a Praecipe for Rule to File a Complaint on April 21, 2010. See Exhibit "B."
4. On April 21, 2010, the Prothonotary issued a Rule upon Plaintiff to file a
Complaint within twenty (20) days after service of the Rule or suffer a judgment of non pros.
See Exhibit "C."
5. Defendants served Plaintiff with a time-stamped original of the Prothonotary's
Rule to File a Complaint by certified mail, return-receipt requested on April 23, 2010. See
Exhibit "D."
6. The post office attempted to serve the materials on multiple occasions but all
attempts were unsuccessful and the materials were returned as unclaimed to Defendants' office
on May 18, 2010. See Exhibit "E."
7. Defendants employed a Pennsylvania process server to serve the Rule to File
Complaint on Plaintiff on June 9, 2010. The process server was unable to serve and/or locate
Plaintiff at her last unknown address. See Affidavit attached hereto as Exhibit "F."
8. Although Defendants have made a reasonable good faith effort to locate
Plaintiffs whereabouts, as stated above, Defendants have been unable to complete service of the
Rule to File Complaint on Plaintiff.
9. Pennsylvania Rule of Civil Procedure 430(a) specifically provides:
If service cannot be made under the applicable rule [defendant] may move
the court for a special order directing the method of service. The motion
shall be accompanied by an affidavit stating the nature and extent of the
investigation which has been made to determine the whereabouts of the
[plaintiff) and the reasons why service cannot be made.
10. Pa.R.C.P 403(b)(1) provides for service by publication as follows:
The service of process by publication has been authorized by Rule of Civil
Procedure or Order of Court, the publication shall be by advertising a
notice of action once in the legal publication, if any, designated by the
court for publication of legal notices and in one newspaper of general
circulation within the county.
2
11. In conformity with Pa.R.C.P. 430(a), the Defendants set forth, as verified, in the
within Motion, that they have made a reasonable good faith effort to locate the whereabouts of
Plaintiff. The Defendants efforts included inquiries to the post office and a Pennsylvania process
server. However, Defendants have been unable to effectuate service of the Rule to File
Complaint on the Plaintiff.
12. In order to complete service of the Rule to File Complaint on the Plaintiff,
Defendants, so as to move this action forward to ultimate disposition, respectfully request that
this Honorable Court, pursuant to Pa.R.C.P. 430 et seq., grant a special Order directing service of
the Rule to File Complaint by publication on Plaintiff.
13. Pursuant to Local Rule 208.3(a)(9), Defendants were unable to locate Plaintiff to
secure concurrence in this Motion.
WHEREFORE, Defendants request that this Court permit service by publication pursuant
to Rule 430 of the Pennsylvania Rules of Civil Procedure.
Respectfully submitted,
DICKIE, MCCAMEY & CHILCOTE, P.C.
Date: June 18, 2010 By:
11 Ja an, Esquire
Su Court I. D. #85651
1200 Camp Hill Bypass, Suite 205
Camp Hill, PA 17011-3700
(717) 731-4800
Attorney for Defendants, Frederick R. Maue, M.D.
and Holy Spirit Hospital Behavioral Health
3
652799
VERIFICATION
I, Aaron S. Jayman, Esquire, hereby state that I am an attorney for Defendants, Frederick
R. Maue, M.D. and Holy Spirit Hospital Behavioral Health, in this action and verify that the
statements made in the foregoing Defendants' Motion for Service Pursuant to Special Order of
Court are true and correct to the best of my knowledge, information and belief.
The undersigned understands that the statements herein are made subject to the penalties
of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities.
Respectfully submitted,
DICKIE, MCCAMEY & CHILCOTE, P.C.
Date: June 18, 2010 By:
Aar H y an , Esquire
Sup C urt I. D. #85651
120 C Hill Bypass, Suite 205
Camp Hill, PA 17011-3700
(717) 731-4800
Attorney for Defendants
i ?
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
100 Spangler Rd
Le?isberry, PA 17339 :
plaintiff
V.
Frederid[ R. Main M.D.
1"N. 11th Street :
Sunbury, PA 17001
And
Holy Spirit Hospital Behavioral Health
503 N. 21st Street :
Carp Han, Pa. 17011 :
Defendants
TO THE PROTHONOTARY:
CIVIL ACTION MEDICAL
PROFESSIONAL LIABILITY
ACTION
09- 3.22?
Kindly issue a Writ of Sualmons in the above-referenced matter, and forward the Writ to
the Sheriff for service upon the Defendants.
Respectfully submitted,
Dawn I Mill
100 Spangler Rd.
Lewisberry, Pa. 17339
(717) 309-2899
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Commonwealth of Pennsylvania
County of Cumberland
WRIT OF SUMMONS
DAWN R. MILLER
100 SPANGLER RD.
LEWISBERRY, PA 17339
Plaintiff
Vs.
FREDERICK R. MAUE, M.D.
168 N. 11TH STREET
SUNBURY, PA 17801
AND
HOLY SPIRIT HOSPITAL
BEHAVIORAL HEALTH
503 N. 21sT STREET
CAMP HILL, PA 17011
Defendant
Court of Common Pleas
No 08-3229 CIVIL TERM
In CivilAction-Law
To FREDERICK R. MAUE, M.D. AND HOLY SPIRIT HOSPITAL
BEHAVIORAL HEALTH,
You are hereby notified that DAWN R. MILLER the Plaintiff(s) 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) C s R. 5?4wo tary
Date MAY 22, 2008 By
Deputy
Attorney:
Name: DAWN R. MILLER
Address: 100 SPANGLER RD.
LEWISBERRY, PA 17339
Attorney for: Pro Se
Telephone: 717-308-2899
Supreme Court ID No.
• SHERIFF'S RETURN - REGULAR
CASE NO: 2008-03229 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MILLER DAWN R
VS
MAUE FREDERICK R MD ET AL
RONALD E HOOVER
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within WRIT OF SUMMONS
was served upon
MAUE FREDERICK R MD the
DEFENDANT , at 0013:36 HOURS, on the 9th day of June , 2008
at HOLY SPRIT HOSPITAL
503 N 21ST ST
CAMP HILL, PA 17013 by handing to
KAY TIPTON LEGAL COORDINATOR-RISK MGMT
a true and attested copy of WRIT OF SUMMONS
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 15.00
Affidavit .00
Surcharge 10.00
Postage
I-J]"Al 4- 42
v/ 43.42
So Answers:
R. Thomas Kline(
06/10/2008
DAWN MILLER
Sworn and Subscibed to By: C?erw
before me this day Deputy /Sheriff
of , A.D.
DICKIE, MCCAMEY & CHILCOTE, P.C.
BY: Thomas M. Chairs, Esquire
ATTORNEY I.D. NO. 78565
1200 Camp Hilt Bypass, Suite 205
Camp Hill, PA 17011
(717)7314800 (Tele)
(717)7314803 (Fax)
DAWN R. MILLER, PRO SE,
Plaintiff
V.
FREDERICK R. MADE, M.D. AND HOLY
SPIRIT HOSPITAL BEHAVIORAL
HEALTH,
Defendants
ATTORNEY FOR DEFENDANTS
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 08-3229
MEDICAL MALPRACTICE 4011'
'a.
15
rA
JURY TRIAL DEMANDED
PRAECIPE FOR RULE TO FILE COMPLAINT
TO THE PROTHONOTARY:
a
n,.
V
Kindly issue a rule upon Plaintiff to file a Complaint in the above-captioned case within
twenty (20) days after service of the Rule or suffer a judgment of non pros.
Respectfully submitted,
DICKIE, MCCA_MEY & CHILCOTE, P.C.
Date: April 19, 2010 By:
Th M. Chairs, Esquire
Supreme Court I.D. #78565
1200 Camp Hill Bypass, Suite 205
Camp Hill, PA 17011-3700
(717) 731-4800
Attorney for Defendants
CERTIFICATE OF SERVICE
AND NOW, April 19, 2010, I, Thomas M. Chairs, Esquire, hereby certify that I did serve
a true and correct copy of the foregoing PRAECIPE FOR RULE TO FILE COMPLAINT
upon all counsel of record by depositing, or causing to be deposited, same in the U.S. mail,
postage prepaid, at Camp Hill, Pennsylvania, addressed as follows:
By First-Ctsss Mail:
Dawn R. Miller, Pro Se
100 Spangler Road
Lewisberry, PA 17339
Thomas airs, Esquire
DAWN R. MILLER, PRO SE,
Plaintiff
V.
FREDERICK R. MADE, M.D. AND HOLY
SPIRIT HOSPITAL BEHAVIORAL
HEALTH,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
,
PENNSYLVANIA
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NO. 08-3229 s °
MEDICAL MALPRACTICE 'IOW
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Defendants ' j JURY TRIAL DEMANDED
RULE TO FILE COMPLAINT
AND NOW, this c2e* day of Apr('( , 2010, a Rule is hereby issued upon
Plaintiffs to file a Complaint in the above-captioned case within twenty (20) days after service of
the Rule or suffer a judgment of non pros.
By:
_ Deputy
620335
CERTIFICATE OF SERVICE
eW7
AND NOW, April 23, 2010, I, Thomas M. Chairs, Esquire, hereby certify that I did serve
a true and correct copy of the foregoing RULE TO FILE COMPLAINT upon all counsel of
record by depositing, or causing to be deposited, same in the U.S. mail, postage prepaid - return
receipt requested, at Camp Hill, Pennsylvania, addressed as follows:
By First-Class Mall:
Dawn R. Miller, Pro Se
100 Spangler Road
Lewisberry, PA 17339
(Pro Se)
(Return Receipt Requested)
Chairs,
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Dikllku`?e
Thomas M. Chairs Direct Dial: 717-731-4800
Attomey-at Direct Fax: 717-731-4803
Admitted in P PAA, , MD tchairs@dmclaw.com
April 23, 2010
RETURN RECEIPT REQUESTED
Dawn R. Miller, Pro Se
I:./ Spangler Road
Lewisberry, PA 17339
RE: Dawn R. Miller v. Maue and Holy Spirit Hospital Behavioral Health
Docket No.: 08-3229
Our File No.: PC-178 (0029096.0311304)
Dear Ms. Miller:
I enclose herewith the time-stamped original of the Prothonotary's Rule to File
Complaint dated April 21, 2010, with regard to the above-referenced matter.
very truly yours,
DICKIE, MCCAM)EN-& CHILCOTE, P.C.
TMC/nlb
Enclosure
(7006 2150 0003 8541 3908)
ul(XiE. *(AMFY x (H11 WE, P.C. 1 AITORNEY) ei 14W
MAIrr• 711.731.4800 FAX: 117 i31.4803
1100 GIMP HItE BYPASS. iUITE 205 ; CAMP HILL PA 1701 i-3700 1 V7WWAM(tAW (op,
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DAWN R. MILLER, PRO SE,
Plaintiff
V.
FREDERICK R. MAUE, M.D. AND HOLY
SPIRIT HOSPITAL BEHAVIORAL
HEALTH,
Defendants
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
,
PENNSYLVANIA
_N
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NO. 08-3229
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MEDICAL MALPRACTICE A I01T!
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M
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JURY TRIAL DEMANDED
RULE TO FILE COMPLAINT
AND NOW, this ald day of April , 2010, a Rule is hereby issued upon
Plaintiffs to file a Complaint in the above-captioned case within twenty (20) days after service of
the Rule or suffer a judgment of non pros.
c
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Prothonotary
By:
Deputy
TRUE COPY FROM RECORD
In Tiodmany wh wsO, l here unto set my hand
and the seal of said Cpurt at Carlisle, Pa.
?TMs_aL._day at Anrif , 2010
Y . Pr°tl'°"ofry
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620335
CERTIFICATE OF SERVICE
AND NOW, April 23, 2010, I, Thomas M. Chairs, Esquire, hereby certify that I did serve
a true and correct copy of the foregoing RULE TO FILE COMPLAINT upon all counsel of
record by depositing, or causing to be deposited, same in the U.S. mail, postage prepaid - return
receipt requested, at Camp Hill, Pennsylvania, addressed as follows:
By First-Class Mail:
Dawn R. Miller, Pro Se
100 Spangler Road
Lewisberry, PA 17339
(Pro Se)
(Return Receipt Requested)
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Thom Chairs,-Esquire
n 18 10 09:30a
Prool' of Serx ice Rule
Capitol Copy service
717-233-2925
p.1
11JUKIL, MUCAMEY & CHILCOTE, P.C. ATTORNEY FOR DEFENDANTS
By "Thomas M. Chairs, Esquire FREDERICK R. MAUE, M.D. AND HOLY SPIRIT
ATTORNEY I.D. NO. 78565 HOSPITAL BEHAVIORAL HEALTH
BY Aaron S. Jayman, Esquire
ATTORNEY I.D. NO. 85651
1200 Camp Hill Bypass, Suite 205
Camp Hill, PA 17011
(717)731-4800 (Tele)
(717)731-48 3 (Fax)
DAWN R. MILLER, PRO SE , IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY,
PENNSYLVANIA
V.
FREDERICK R. MADE, M.D. AND HOLY
SPIRIT HOSPITAL BEHAVIORAL
HEALTH,
Defendants
NO. 08-3229
MEDICAL MALPRACTICE ACTION
JURY TRIAL DEMANDED
PROOF OF SERVICE
On June 9, 2010, at approximately I 1:15a.m., 1 the undersigned, being over the age of 18,
attempted to serve the Prothonotary of Cumberland County's Rule to Complaint dated April 21,
2010, by personal service to Dawn R. Miller, Pro Se of 4 Sportsman Road, Enola, PA 17025. 1
certify that the foregoing statements made by me are true. I am aware that if any of the
foregoing statements are willfully false, 1 am subject to punishment.
Dated: iI 0
Address for Service:
( ) is in the Military
( X) is not in the Military
Received Time Jun.18. 9:03AM
Stephen hover
Dawn R. Miller
4 Sportsman Road
Enola, PA 17025
CERTIFICATE OF SERVICE
AND NOW, June 18, 2010, I, Aaron S. Jayman, Esquire, hereby certify that I did serve a
true and correct copy of the foregoing DEFENDANT'S MOTION FOR SERVICE
PURSUANT TO SPECIAL ORDER OF COURT upon all counsel of record by depositing, or
causing to be deposited, same in the U.S. mail, postage prepaid, at Camp Hill, Pennsylvania,
addressed as follows:
By First-Class and Certified Mail Mail:
Dawn R. Miller, Pro Se
4 Sportsman Road
Enola, PA 17025
18 10 09:30a
Proof of ScrviceRulc
Capitol Copti Service 717-233-2925
DICKIE, MCCAMEY & CHILCOTE, P.C.
BY Thomas M. Chairs, Esquire
ATTORNEY I.D. NO. 78565
BY Aaron S. Jayman, Esquire
ATTORNEY I.D. NO. 85651
1200 Camp Hill Bypass, Suite 205
Camp Hill, PA 17011
(717)731-4800 (Tele)
(717)731-4803 (Fax)
DAWN R. MILLER, PRO SE,
Plaintiff
V.
FREDERICK R. MAUE, M.D. AND HOLY
SPIRIT HOSPITAL BEHAVIORAL
HEALTH,
Defendants
p.1
ATTORNEY FOR DEFENDANTS
FREDERICK R. MAUE, M.D. AND HOLY SPIRIT
HOSPITAL BEHAVIORAL HEALTH
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 08-3229
MEDICAL MALPRACTICE ACTION
JURY TRIAL DEMANDED
PROOF OF SERVICE
On June 9, 2010, at approximately 11:I5a.m., I the undersigned, being over the age of l8,
attempted to serve the Prothonotary of Cumberland County's Rule to Complaint dated April 21,
2010, by personal service to Dawn R. ]Miller, Pro Se of 4 Sportsman Road, Enola, PA 17025. I
certify that the foregoing statements made by me are true. I am aware that if any of the
foregoing statements are willfully false, I am subject to punishment.
I f ! 1
Dated: I ?I
Stephen hover
Address for Service: Dawn R. Miller
( ) is in the Military 4 Sportsman Road
( X) is not in the Military Enola, PA 17025
i
Received Time Jun.18. 9:0?tiM
CERTIFICATE OF SERVICE
AND NOW, June 18, 2010, I, Aaron S. Jayman, Esquire, hereby certify that I did serve a
true and correct copy of the foregoing DEFENDANT'S MOTION FOR SERVICE
PURSUANT TO SPECIAL ORDER OF COURT upon all counsel of record by depositing, or
causing to be deposited, same in the U.S. mail, postage prepaid, at Camp Hill, Pennsylvania,
addressed as follows:
By First-Class and Certified Mail Mail:
Dawn R. Miller, Pro Se
4 Sportsman Road
Enola, PA 17025
3
JUN 2 2 2010
DAWN R. MILLER, PRO SE,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 08-3229
MEDICAL MALPRACTICE ACTION
FREDERICK R. MAUE, M.D. AND HOLY
SPIRIT HOSPITAL BEHAVIORAL
HEALTH,
Defendants
JURY TRIAL DEMANDED
t
652747
ORDER
AND NOW this day of- , 2010, upon
consideration of Defendd?an?ts' M?tigP for ServiPursuant S ecie of Court, it is ereby
6N1 aD. I T 3 cy ?o. ?
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- 110
DICKIE, MCCAMEY & CHILCOTE, P.C. ATTORNEY FOR DEFENDANTS
BY: Thomas M. Chairs, Esquire FREDERICK R. MADE, M.D. AND HOLY
ATTORNEY I.D. NO. 78565 SPIRIT HOSPITAL BEHAVIORAL HEALTH
Aaron S. Jayman, Esquire
ATTORNEY I.D. NO. 85651
1200 Camp Hill Bypass, Suite 205
Camp Hill, PA 17011
(717)7314800 (Tele)
(717)731-4803 (Fax)
DAWN R. MILLER, PRO SE,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 08-3229
FREDERICK R. MAUE, M.D. AND HOLY
SPIRIT HOSPITAL BEHAVIORAL
HEALTH,
Defendants
MEDICAL MALPRACTICE ACTION
JURY TRIAL DEMANDED
TEN-DAY NOTICE
To: Dawn R. Miller, Pro Se Trim
,--
4 Sportsman Road
Enola, PA 17025
C", r1o
Date of Notice: June 28, 2010 cr
(a) IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO FILE A COMPLAINT
IN THE ABOVE MATTER. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE
DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT
A HEARING AND YOU MAY LOSE YOUR PROPERTY OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING
OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
Office of Prothonotary Cumberland County Lawyer Referral Service
Cumberland County Courthouse Cumberland County Bar Association
One Courthouse Square 32 S. Bedford Street
Carlisle, PA 17013-3387 Carlisle, PA 17013
(717) 240-6195 (717) 249-3166 (800) 990-9108
Respectfully submitted,
DICKIE, MCCAMEY & CHILCOTE, P.C.
Date: June 28, 2010 By:
no a airs, Esquire
Su eVJagan ID. #785 65
Aaro , Esquire
Supreme Court I.D. #85651
1200 Camp Hill Bypass, Suite 205
Camp Hill, PA 17011-3700
(717) 731-4800
Attorney for Defendants
2
V_
CERTIFICATE OF SERVICE
AND NOW, June 28, 2010, I, Aaron S. Jayman, Esquire, hereby certify that I did serve a
true and correct copy of the foregoing TEN-DAY NOTICE upon all counsel of record by
depositing, or causing to be deposited, same in the U.S. mail, postage prepaid and certified mail
at Camp Hill, Pennsylvania, addressed as follows:
By First-Class Mail:
Dawn R. Miller, Pro Se
4 Sportsman Road
Enola, PA 17025
(Plaintiff - Pro Se)
Acvf'-??
Aaron (._J , Esquire
,.
DICKIE, MCCAMEY & HILCOTE, P.C. ATTORNEY FOR DEFENDANTS
BY: Thomas M. Chairs, squire FREDERICK R. MAUE, M.D. AND HOLY
ATTORNEY I.D. N0.78 65 SPIRIT HOSPITAL BEHAVIORAL HEALTH
1200 Camp Hill Bypass, S ite 205
Camp Hill, PA 17011
(717)731-4800 (Tele)
(717 731-4803 Fax)
DAWN R. MILLER, P O SE , IN THE COURT OF COMMON PLEAS
PI intiff OF CUMBERLAND COUNTY,
PENNSYLVANIA
v. N0. 08-3229 ~. ~ `-r;
-- t .- _~
MEDICAL MALPRACTICE TIO~ ' ~-_--
. , ~ --,
FREDERICK R. MAU , M.D. AND HOLY ~ : `- -, -
~.,
SPIRIT HOSPITAL B HAVIORAL ~_~A ~; -~ - = ~ ~;
HEALTH, ~~~ `~ ~~•' _~=`
D fendants JURY TRIAL DEMANDED =~ '~
PRAECIPE FOR ENTRY OF NON PROS
Kindly enter j
Defendants, Frederick
undersigned, hereby
of Judgment Non Pros
Praecipe.
of non pros against Plaintiff, Dawn R. Miller, and in favor
Maue, M.D. and Holy Spirit Hospital Behavioral Health. I, the
fY that the attached Notice of Intention to File a Praecipe for the
served on Plaintiff more than ten (10) days prior to the filing of
Respectfully submitted,
D1CK1E, MCCAMEY
Date: July 13, 2010
G~r~ ~a~'
ays~li~i
IL~OfiU `~a'~
~~~y~~ ,~~y ~h~~rl
E, P.C:~
Th airs, Esquire
Supreme Court LD. No. 78565
1200 Camp Hill Bypass, Suite 205
Camp Hill, PA 1701 l -3700
(717) 731-4800
Attorney for Defendants, Frederick R. Maue,
and Holy Spirit Hospital Behavioral Health
D.
,..-
CERTIFICATE OF SERVICE
AND NOW, July 13, 2010, I, Thomas M. Chairs, Esquire, hereby certify that I did serve
a true and correct copy df the foregoing PRAECIPE FOR ENTRY OF NON PROS upon all
counsel of record by depositing, or causing to be deposited, same in the U.S. mail, postage
prepaid, at Camp Hill, Pennsylvania, addressed as follows:
By First-Class Mail:
Dawn R. Miller, Pro Se
4 Sportsman Road
Enola, PA 17025
Get ~ -~.~
Thomas M. Chairs, Esquire
DAWN R. MILLER, P O SE, IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
Pl intiff PENNSYLVANIA
v. NO. 08-3229
FREDERICK R. MAU , M.D. AND HOLY MEDICAL MALPRACTICE ACTION
SPIRIT HOSPITAL B HAVIORAL
HEALTH,
JURY TRIAL DEMANDED
NOTICE OF ENTRY OF NON PROS
TO: Dawn R. Miller, Pro Se
4 Sportsman Ro d
Enola, PA 1702
Date of Notice: July 13, ~ZO10
Please be advised that a Judgment of Non Pros has been entered against you and in favor
of Defendants, Frederick~R. Maue, M.D. and Holy Spirit Hospital Behavioral Health in the
above-captioned action.
Date: ~ ~ ~ . ~_~~
~(l~ll f~ t1v~
umberland County Prothonotary
2