HomeMy WebLinkAbout05-07-04 JOSEPH D. BRENNER, SR., JOSEPH · IN THE COURT OF COMMON PLEAS OF
D. BRENNER, JR., and MARGARET B. ' CUMBERLAND COUNTY, PENNSYLVANIA
BUSHEY · ORPHANS' COURT DIVISION
Petitioners ·
· NO. 21-04-087
Vo '
MANUFACTURERS AND TRADERS ·
TRUST COMPANY, a New York ·
corporation, DAVID C. GORITY, an ·
individual, and CURT R. STAUFFER, · :"
an individual, r. ~. .
Respondents ·
CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22.
As a prerequisite to service of a subpoena for documents and things pursuant to Rule
4009.22, the undersigned certifies that
(1) a notice of intent to serve the subpoena with a copy of the subpoena attached
thereto was mailed or delivered to each party at least twenty days prior to the date on which the
subpoena is sought to be served,
(2) a copy of the notice of intent, including the proposed subpoena, is attached to this
certificate,
(3) no objection to the subpoena has been received, and
(4) the subpoena which will be served is identical to the subpoena which is attached
to the notice of intent to serve the subpoena.
Date: May 7, 2004 ~
Keith O. Brenneman, Esquire
Attorney ID #47077
44 W. Main Street
L^~v oF~.cEs Mechanicsburg, PA 17055
SNELBAKER,
BrENNEMAN (717) 697-8528
~, s~^~ Attorneys for Petitioners
IN RE: ESTATE OF :
JOSEPH D. BRENNER, SR., JOSEPH D. : IN' THE COURT OF COMMON PLEAS
BRENNER, JR., and MARGARET B. BUSHEY, : OF CUMBERLAND COUNTY,
: PENNSYLVANIA
Petitioners, :
: ORPHANS' COURT DIVISION
V.
: No. 21-2004-087
MANUFACTURERS AND TRADERS TRUST :
COMPANY, a New York corporation, DAVID C. :
GORITY, an individual, and CURT R. :
STAUFFER, an individual, :
:
Respondents. :
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE
DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
Petitioners intend 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 or record and serve
upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may
be served.
DATED this /~ day of April, 2004.
TONKON TORP
W' am F. Martson, Jr., OSB No. 72163
Robyn E. Ridler, OSB No. 00016
Attorneys for Petitioners
IN RE: ESTATE OF :
JOSEPH D. BRENNER, SR., JOSEPH D. : IN THE COURT OF COMMON PLEAS
BRENNER, JR., and MARGARET B. BUSHEY, : OF CUMBERLAND COUNTY,
: PENNSYLVANIA
Petitioners, :
: ORPHANS' COURT DIVISION
V.
: No. 21-2004-087
MANUFACTURERS AND TRADERS TRUST :
COMPANY, a New York corporation, DAVID C. :
GORITY, an individual, and CURT R. :
STAUFFER, an individual, :
:
Respondents. :
SUBPOENA TO PRODUCE DOCUI¥IENTS OR THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.22
TO: Sprint
Sprint Subpoena Compliance Dept.
Mail Stop KSOPHM0216-2B776
6480 Sprint Parkway
Overland Park, KS 66251
Fax number (913) 315-0736
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following documents or things:
Records of all incoming and outgoing telephone calls from June 1, 2002, to June
30, 2002, between the offices of Manufacturers and Traders Trust Company, 1415
Ritner Highway, Carlisle, Pennsylvania (including but not limited to the telephone
numbers 717-240-4505 and 717-240-4565) and any of the following telephone
numbers: 717-243-3850 (the home of Joseph D. Brenner, Sr.), 717-245-7114 (the
office of Joseph D. Brenner, Jr.), or 71%243-8381 (the home of Richard D. and
Margaret B. Bushey).
at the offices ofTonkon Torp LLP, 1600 Pioneer Tower, 888 S.W. Fifth Ave., Portland, OR
97204.
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
copics or producing the things sought.
If you fail to produce the documents or things required by this subpoena witkin twenty
(20) days aftcr 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:
William F. Martson, Jr.
OSB No. 72163
Tonkon Torp LLP
1600 Pioneer Tower
888 S.W. Fifth Ave.
Portland, OR 97204
503-802-2005
Attorney for Petitioners Joseph D. Brenner, Sr., Joseph D. Brenner, Jr., and
Margaret B. Bushey
BY THE COURT: ,
DATE: By
2
CERTIFICATE OF SERVICE
I hereby certify that I served the foregoing NOTICE OF INTENT TO SERVE A
SUBPOENAS PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO
RULE 4009.21 on:
Mark D. Bradshaw
Stevens & Lee
P. O. Box 11670
Harrisburg, PA 17108-1670
Of Attorneys for Respondents
['~ by mailing a copy thereof in a sealed, first-class postage prepaid envelope,
addressed to each attorney's last-known address and depositing in the U.S. mail at Portland,
Oregon on the date set forth below;
[] by causing a copy thereof to be hand-delivered to said attorneys at each
attorney's last-known office address on the date set forth below;
[] by sending a copy thereof via overnight courier in a sealed, prepaid envelope,
addressed to each attorney's last-known address on the date set forth below; or
[] by faxing a copy thereof to each attorney at each attorney's last-known
facsimile number on the date set forth below.
DATED this. /Z//~day of April, 2004.
TONKON TORP Lt~P
By. ~ c~...~. .'C-~ ~.~/~__~
William F. ~artson, Jr., OSB No. 72163
Robyn E. Ridler, OSB No. 00016
Attorneys for Petitioners
031590\0000 \566363 V)01
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