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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. in -3003 ON;, MM
CIVIL ACTION - MEDICAL PROFESSIONAL LIABILITY ACTION
VALERIE BRADLEY, Individually and Holy Spirit Hospital
as Co-Administrator of the Estate of c/o their counsel, Thomas M. Chairs, Esq.
CHASE JONES, Deceased Dickie McCamey
821 Pheasant Drive North 1200 Camp Hill Bypass, Suite 205
Carlisle, PA 17013 Camp Hill, PA 17011-3700
AARON JONES, Individually and
as Co-Administrator of the Estate of
CHASE JONES, Deceased
11 Garden Drive
Carlisle, PA 17013
Plaintiffs Defendant
versus
PRAECIPE FOR WRIT OF SUMMONS
TO THE PROTHONOTARY OF SAID COURT:
Please issue a writ of summons in the above-captioned action.
X Writ of Summons shall be issued and forwarded to
Michael J. Navitsky, Esquire
Navitsky, Olson & Wisneski LLP
2040 Linglestown Road, Suite 303
Harrisburg, PA 17110
(717) 541-9205
Dated:
Signature
I.D. No. 5
WRIT OF SUMMONS
TO THE ABOVE NAMED DEFENDANT:
n a
( ) Attorney and
(X) Sheriff
( ) Defendant
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YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED
AN ACTION AGAINST i'OU.
'4L, ?euJl
othonotary
Dated: 5 /D by
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson ,
Sheriff ~~~ ` {
Jody S Smith ~~` ~'~o
Chief Deputy -,. ~,~~~ ~~~~ ~ ~ ~~ $: ~~
Edward L Schorpp
Solicitor ~? ~ ~`~' rf
Valerie Bradley I
vs.
Holy Sprit Hospital
Case Number
2010-3003
SHERIFF'S RETURN OF SERVICE
05/11/2010 Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on May 11, 2010 at 1409
hours, he served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Holy
Spirit Hospital, by making known unto Thomas M. Chairs, Counsel for Holy Spirit Hospital at 1200 Camp
Hill Bypass Suite 205, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same
time handing to him personally the said true and correct copy of the same..
SHERIFF COST: $41.94 SO ANSWERS,
~~ ~°~~
May 12, 2010 RON R ANDERSON, SHERIFF
8y ~~ (~_""'~7
DENNI Fi?Y, DEPj Y/S IFF
tq Coui;?ySulte :yhenft, TelaosoYt. In,.
-~'iv ~r h- ... ~r
VALERIE BRADLEY and AARON
JONES, Individually and VALERIE
BRADLEY and AARON JONES, as
Co-Administrators of the Estate of
CHASE JONES, Deceased
Plaintiffs
v.
HOLY SPIRIT HOSPITAL,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYLVANIA
NO.
CIVIL ACTION -MEDICAL
PROFESSIONAL LIABILITY ACTION
JURY TRIAL DEMANDED
ACCEPTANCE OF SERVICE
I, Thomas M. Chairs, Esquire, accept service of the Writ of Summons on behalf of
Defendant Holy Spirit Hospital and certify that I am authorized to do so.
t ~
~~~ f
Date: ~ ` ~ 4 ~'
.,~ , '",~
~- ~` ~ >~ r
Thorfias M. Chairs, Esquire
Dickie McCamey
1200 Camp Hill Bypass, Suite 205
Camp Hill, PA 17011-3700
i
DICKIE, MCCAMEY & CHILCOTE, P.C.
BY: Thomas M. Chairs, Esquire
ATTORNEY I.D. NO. 78565
Plaza 21, Suite 302
425 North 21st Street
Camp Hill, PA 17011
717-731-4800 (Tele)
888-811-7144 (Fax)
VALERIE BRADLEY AND AARON
JONES, INDIVIDUALLY AND VALERIE
BRADLEY AND AARON JONES, AS CO-
ADMINISTRATORS OF THE ESTATE
OF CHASE JONES, DECEASED,
Plaintiffs,
V.
COLLEEN FOOS, M.D., CUMBERLAND
VALLEY OBSTETRICS AND
GYNECOLOGY, P.C. AND HOLY SPIRIT
HOSPITAL,
Defendants
ATTORNEY FOR DEFENDANT
HOLY SPIRIT HOSPITAL
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 09-5971 & 2010-3003
CIVIL ACTION - MEDICAL
JURY TRIAL DEMANDED
PRAECIPE FOR CHANGE OF ADDRESS FOR SERVICE UPON DEFENDANT
HOLY SPIRIT HOSPITAL
TO THE PROTHONOTARY:
Please direct all future Notices and correspondence to the following address and the
undersigned counsel.
Dickie, McCamey & Chilcote, P.C.
Plaza 21, Suite 302
425 N. 21St Street -? -
Camp Hill, PA 17011 -= --t
_
-Q ,?
Respectfully submitted,
DICKIE, MCCAMEY & CHILCOTE, P.C.
e n
Date: February 9, 2011 By:'
Thoma's' M. Chairs, Esquire
Supreme Court I.D. #78565
Aaron S. Jayman, Esquire
Supreme Court I. D. #85651
425 N. 21St Street, Suite 302
Camp Hill, PA 17011-3700
(717) 731-4800
(888) 811-7144
Attorney for Defendant, Holy Spirit Hospital
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CERTIFICATE OF SERVICE
AND NOW, February 9, 2011, I, Thomas M. Chairs, Esquire, hereby certify that I did
serve a true and correct copy of the foregoing 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:
Michael J. Navitsky, Esquire
NAVITSKY, OLSON & WISNESKI, LLP
2040 Linglestown Road, Suite 303
Harrisburg, PA 17110
(Counsel for Plaintiffs)
Sarah W. Arosell, Esquire
THOMAS, THOMAS & HAFER, LLP
P.O. Box 999
Harrisburg, PA 17108
(Counsel for Defendants, Colleen Foos, M.D. and Cumberland Valley Obstetrics and
Gynecology, P.C.)
Thoms?as'tvl: Chairs, Esquire