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HomeMy WebLinkAbout10-3366SEREENA L. LECRONE, a Minor by her Parent and Guardian, MARY A. LECRONE, Plaintiffs v. WOLF BUS LINES, INC., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2010 - ~ 3 (o lc CIVIL TERM CIVIL ACTION -LAW PRAECIPE FOR ISSUANCE OF A WRIT OF SUMMONS TO CURTIS R. LONG, PROTHONOTARY: Please issue a Writ of Summons against the defendant, WOLF BUS LINES, INC., and enter my appearance on behalf of the plaintiffs, SEREENA L. LECRONE, a Minor by her Parent and Guardian, MARY A. LECRONE . Please direct the Sheriff to serve the defendant as follows: Wolf Bus Lines, Inc. 200 Old US Rt. 15 York Springs, PA 17372 May 19, 2010 To: WOLF BUS LINES, INC. t'1 C na v '~a ~ v t ~ ~ ~ Respectfully submitted, ? r ; : f ~'=. ~ ~~,~ ~r ~ ~ L IRWIN c IGHT, P.C Tr"-~- i=.~ _ `_-~`' --+ t. , , -.~ _ ~: ~ `~ ;'I i By: "'~ ~ Marcus . Mc g t squire b0 West omfret Street, Carlisle, PA 17013 f (717} 24 -2353 Supreme Court I.D. No: 25476 You are hereby notified that SEREENA L. LECRONE, a Minor by her Parent and Guardian, MARY A. LECRONE, plaintiff, has commenced an action against you which you are required to defend or a default judgment may be entered against you. PROTHONOTARY DEPUTY` ~ Date: / ~ , 2010 ~ 9a . oa ,,~ ~~ lr,~a- 7 ~--J 2~ aye 390 Stephen E. Geduldig, Esquire E-mail: sgeduldig@tthlaw.com Attorney I.D. No. 43530 (717) 237-7119 Stephanie L. Hersperger, Esquire E-mail: shersperger@tthlaw.com Attomey I.D. No. 78735 (71'7) 255-7239 THOMAS, THOMAS 8 HAFER, LLP 305 North Front Street Post Office Box 999 Harrisburg, Pennsylvania 17108-0999 F1LE, ~=~~ F ~}F THE ~'E~~'a'? NARY 1Q10 JUIy -8 AID 8~ 5 t ~~ ~~{r ' JL1N~Y PE~lPvSY(.Vr.NfA Attorneys for Defendant: FAX (717) 237-7105 WOLF'S BUS LINES, INC. SEREENA L. LECRONE, a Minor IN THE COURT OF COMMON PLEAS OF by her Parent and Guardian :CUMBERLAND COUNTY, PENNSYLVANIA MARY A. LECRONE, . Plaintiffs . CIVIL ACTION -- LAW ~• N0.2oio-3366 WOLF'S BUS LINES, INC. Defendant :JURY TRL~I. DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Stephen E. Geduldig, Esquire, Stephanie L. Hersperger, Esquire, and Thomas, Thomas & Hafer, LLP, as attorneys for Defendant, Wolfs Bus Lines, Inc., in the above-captioned matter, reserving our right to answer or otherwise plead to Plaintiffs' Complaint. Respectfully submitted, YC / ( C 6 8i8i33.i By: THOMAS, THOMAS &HAFER, LLP STEPHEN E. GEDULDIG, ESQUIRE Attorney I.D. No. 43530 STEPHANIE L. HERSPERGER, ESQUIRE Attorney I.D. No. 78735 Attorneys for Defendant, WOLF'S BUS LINES, INC. SEREENA L. LECRONE, a Minor by her Parent and Guardian MARY A. LECRONE, Plaintiffs v, WOLF'S BUS LINES, INC. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -- LAW N0.2o10-3366 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing ENTRY OF APPEARANCE was served by depositing the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, on the ~ day of June, 2oio, on all counsel of record as follows: Marcus A. McKnight, III, Esquire IRWIN & McKNIGHT 6o West Pomfret Street Carlisle, Pennsylvania i~oi3-3222 Attorneys for Plaintiffs THOMAS, THOMAS & HAFER, LLP r- Stephen E. Geduldig, Esquire 8i8i39.i .w} r ,` ~y ~~ ~ ~•J i~u 11 2010 JU~~ 24 PP1 3~ 03 FE. ~1v~Y~l~~.`JI~ SEREENA L. LECRONE, a Minor by her Parent and Guardian, MARY A. LECRONE, Plaintiffs v. WOLF BUS LINES, INC., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2010 - 3366 CIVIL TERM CIVIL ACTION -LAW PRAECIPE FOR REISSUANCE OF A WRIT OF SUMMONS TO DAVID D. BUELL, PROTHONOTARY: Please reissue the Writ of Summons for service of the following defendant at this address: Wolf Bus Lines, Inc. 200 Old US. Rt. 15 York Springs, PA 17372 By: Date: June 24, 2010 Respectfully submitted, IRWIN & McKNIGHT, P.C ~rcus A 1VrcKnight~ III, Esquire 60 West P mfret Street, arlisle, PA 17013 (717) 249- 353 Supreme Court I.D. No: 25476 ~ ~~s~i SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~o~3~tr nt ~u1~~r~.#~~~ ~. '-' ~r~~ ~~ i. . ~: j..o r . } -,7,:. pFFr~G£ nF'HE S~~RIFF f'1t }-t ~ r,r. ' a_.. j ,~ I ;~ 1 ~ 210 J ~~ ~ ~~~ 22 ~ Sereena L. Lecrone vs. Wolf Bus Lines, Inc. Case Number 2010-3366 HERIFF'S RETURN OF SERVICE 06/25/2010 Ronny R. Anderson, Sht and inquiry for the withir his bailiwick. He therefc Summons according to 07/02/2010 Adams County Return: Pennsylvania, do herby the within named defenc Co-Owner of Wolf Bus L same time handing to hi SHERIFF COST: $37.44 July 15, 2010 riff who being duly sworn according to law states that he made a diligent search named defendant, to wit: Wolf Bus Lines, Inc., but was unable to locate them in e deputized the Sheriff of Adams County, PA to serve the within Writ of end now July 2, 2010 at 1230 hours I, James W. Muller, Sheriff of Adams County, ;ertify and return that I served a true copy of the within Writ of Summons, upon ant, to wit: Wolf Bus Lines, Inc. by making known unto Tammy Wolf-Baker, fines, Inc. at 200 Old US Route 15, York Springs, PA 17372 its contents and at the it personally the said true and correct copy of the same. SO ANSWERS, RON R ANDERSON, SHERIFF (cj CountySuite Sheriff. Teleosoft, Inc. YORKTOWNE BUSINESS FORMS, INC. • PH. (717) 845-5955 • FAX (717) 848.8935 DATE RECEIVED DATE PROCESSED SHE IFF'S DEPARTMENT ADAMS COUNTY, PENNSYLVANIA COURTHOUSE, GETTYSBURG, PA 17325 SHERIFFS RVICE N18TRUCTIONB: See "INSTRUCTIONS FOR SERVICE OF PROCESS BY " PROCESS RECEIPT, and A FIDAVIT OF RETURN THE SHERIFF on the reverse a the last (No. 5) Dopy of this form. Please ~° a< print Isgibry, inaurir-g readabairy of as copies. Do rat detach any oopiss. ACSO fiJiV.M 1. PuINTIFF/S/ S~1A L. LECRON , a minor by her parent and 2. COURT NUMBER uardian MARY A. LF,CRONE 2010-3366 Civil Term 3. DEFENDANTS/ WbLF BUS LINES INC 4. TYPE OF WRIT OR COMPLAINT: . [~i.t of Stmnorls in Civil Actin ~R~ 5. NAME OF fNDIVIDUAL, COMPAN ,CORPORATION, ETC., TO SERVICE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED OR SOLD. Wolf Bus Lines, In . 6. ADDRESS (Street or RFD, Apart AT No., Cily, 8oro, Twp., State end ZIP CODE) .200 Old US Rovte 1 ,York Springs PA , 7. INDICATE UNUSUAL SERVICE: ^ PERSONAL PERSON IN CHARGE ^ DEPUTIZE ^ CERT. MAIL ^ REGISTERED MAIL ^ POSTED O OTHER Now, , I, SHERIFF OF ADAMS COUNTY, PA., do hereby deputize the Sheriff of County o execute this Writ and make return therof according to law. This deputation being made at the request and risk of the laintiff. 8. SPECIAL INSTRUCTIONS OR OTHER INFORMA SHERIFF OF ADAMS COUNTY ION THAT WILL ASSIST IN EXPEDITING SERVICE. NOTE ONLY APPLICABLE ON WRIT OF EXECUTIO : 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 i any plaintiff herein for any loss, destruction or remov found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to I of any such property before sheriff's sale thereof. 9. SKiNATURE of ATTORNEY a other ORKiiNATO requesting service on behaa of: 10. TELEPHONE NUMBER 1 t. DATE Marcus A. McKnight, III, C~. ~PIAINTIFF (717) 249-2353 O DEFENDANT PA E BELOW F R U E F SHERIFF ONLY -DON T WRITE BELOW THIS LINE 12. I acknowledge receipt of the writ SIGNATU or complaint es indicated above. of Authorized ACSO Deputy or Clerk and Title 13. Date Received 14. Expiration /~Gdate 6 29/2010 JULY 23 2010 15. I hereby CERTIFY and RETURN that I ^ have rsonally served, I~have served person in charge ^ have legal evidence of servic h i " " ^ have posted the above described property with , e as s own n Remarks (on reverse) he writ or complaint described on the individual, company, corporation, etc., at the address shown above or on the individual, company, ~rporation, etc., at the addr inserted below by handinglor Posting a TRUE and ATTESTED COPY therof. 18. ^ 1 hereby certify and return a NOT FOUND use I am. unable to locate the individual, company, corporaton, etc., named above. (See remarks bebw) 17. Name and title of krdividwl nerved Tamrrl Wolf-Baker Co-Owner' te, A person of suitable aW and dlacretlw, Read Order t ~rplal~ o a.f°^d°^t'sus~al p o 19. Address of where served (complete only N diHere Stets and ZIP CODE) t than shown above) (Street or RFD, Apartment No., City, Boro, Twp., 20. Date of Service 21. Time 7/2/10 12:30PM 22. ATTEMPTS Dab MINs Dap.int. Mlles Dep.lnt. Dab MINs Dep.Mt. Date MNp Dep.IM. Date Milp Dep.lnt. 23. Advance Costs 24. ~ ~ ~ ~ 25. 28. 27. Total Costs 28. Q~I~Ij~~li REFUND • $35.55 Pd. 7/14/10 $114.45 Ck. #23991 WER. 1 AFFIRMED and wbtaibed to before me this N/A ! r _ _ 1 .~ ` ` B1'~~4 aP• Sharilf) (pNeaa I~rMt a Typo) Date day °f Shane Shultz 7/2/2010 SipnMtee of Sttsrilf Date JAMES W. M[JL1~ER 7/2/2010 MY COMAl11SS10N EXPIRES SHERIFF oP ADAMS COUNTY I AGKNdNILEDGE RECEIPT OF THE SHERIFF•$ OF AUTIiORIZED ISSUING AllTFIORITY AND SIGNATURE 39. Date Received r_ _ - _ --- SHERIFF'S RETURN OF SERVICE ( ) (1) The within upon ,the within named defendarrf by mailing to by mail, return receipt requested, postage prepaid, on the a true and attested copy thereof at The return receipt signed by defendant on the is hereto attached and made a part of this return. ( ) (2) Outside the Commonwealth, pursuant-to Pa. R.C.P. 405 (c) (1) (Z), by mailing a true and attested copy thereof at in the following manner: ( ) (a) iso the defendant by ( )registered ( )certified mail, return receipt requested, postage prepaid, addressee only on the said receipt being returned NOT signed by defendant, but with a notation by the Postal Authorities that. Defendant refused to accept the same. The returned receipt and envelope is attached hereto and made a part of this return. And thereafter: ( ) (b) To the defendant by ordinary mail addressed to defendant at same address, with the return address of the Sheriff appearing thereon, on the I further certify that after fifteen (15) .days from the mailing date, I have not received said envelope back from the Postal Authorities. A certificate of mailing is hereto attached as a proof of mailing. (3) By publication in the Adams County Legal Journal, a weekly publication of general circulation in the County of Adams, Commonwealth of Pennsylvania, and the Gettysburg Times, a daily newspaper published in the County of Adams, Commonwealth of Pennsylvania and having general circulation in said County for successive weeks of The Affidavits from said Adams County Legal Journal and Gettysburg Times, are hereto attached and made part of this return. (d 1 By mailing to ( ) by mail, return receipt requested, postage prepaid, on the a true and attested copy thereof at The Authorities marked is hereto attached. (5) Other returned by the Postal Stephen E. Geduldig, Esquire E-mail: sgeduldig@tthlaw.com Attorney I.D. No. 43530 (717) 237-7119 Stephanie L. Hersperger, Esquire E-mail: shersperger@tthlaw.com Attorney I.D. No. 78735 (717) 255-7239 THOMAS, THOMAS & HAFER, LLP 305 North Front Street Post Office Box 999 Harrisburg, Pennsylvania 17108-0999 FAX (717) 237-7105 SEREENA L. LECRONE, a Minor by her Parent and Guardian MARY A. LECRONE, Plaintiffs V. WOLF'S BUS LINES, INC. Defendant FILED-OFFICE Or THE PROTHONOTARY Zn10 C? 15 P 158 rD =4,Dc hLAND COU? TY P Er1I1) YLVA'4IA Attorneys for Defendant: WOLF'S BUS LINES, INC. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -- LAW NO. 2010-3366 JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO ISSUANCE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that: 1. A Notice of Intent to Serve Subpoenas, with copies of the subpoenas attached thereto, was mailed or delivered to each party; 2. A copy of the Notice of Intent, including the proposed subpoenas, is attached to this Certificate; 3. Twenty (2o) days have elapsed and no objections have been filed; 4. The subpoenas which will be served are identical to the subpoenas which are attached to the Notice of Intent to Serve Subpoenas. TH , THOMAS & HAFER, LLP Date: Ols/) 0 S EN E. GEDULDIG, 0100 Attorney I. D. No. 43530 STEPHANIE L. HERSPERGER, ESQUIRE Attorney I.D. No. 78735 Attorneys for Defendants, WOLF BUS LINES, INC. Stephen E. Geduldig, Esquire E-mail: seduldig@tthlaw.com Attorney I.D. No. 43530 (717) 237-7119 Stephanie L. Hersperger, Esquire E-mail: shersperger@tthlaw.com Attorney I.D. No. 78735 (717) 255-7239 THOMAS, THOMAS & HAFER, LLP 305 North Front Street Post Office Box 999 Harrisburg, Pennsylvania 17108-0999 FAX (717) 237-7105 SEREENA L. LECRONE, a Minor by her Parent and Guardian MARY A. LECRONE, Plaintiffs V. VATOLF'S BUS LINES, INC. Defendant Attorneys for Defendant: WOLF'S BUS LINES, INC. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -- LAW NO. 2010-3366 JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 14004.21 TO: Counsel of Record Defendant intends to serve subpoenas, identical to the ones that are attached to this Notice. You have twenty (2o) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoenas. If no objection is made, the subpoenas will be served. TH , THOMAS & HAFER, LLP Date: `i I (t) ORTHEN E. GEDULDIG, QUI Attorney I.D. No. 43530 STEPHANIE L. HERSPERGER, ESQUIRE Attorney I.D. No. 78735 Attorneys for Defendants, WOLF BUS LINES, INC. SEREENA L, LECRONE, a Minor by her Parent and Guardian MARY A. LECRONE, Plaintiffs v. -07OLF'S BUS LINES, INC. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVILACTION -- LAW MEDICAL LIABILITY NO. 2010-3366 JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVER17 PURSUANT TO RULE 4009.22 TO: Currie & Hecht Oral & Maxillofacial Surgeons 25 Eastgate Drive Carlisle PA 17015 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of any and all dental records, including. but not limited to, reports. notes, studies bills. incoming and outgoing correspondence, films, labs, phone messages. summaries, etc for an}, inpatient outpatient ER clinic or office visits pertaining to Sereena Lecrone DOB: 05/15/1993 • from date of first visit to the present. at: Thomas. Thomas & Hafer LLP. 305 N. Front St.. P.O. Box 999.. Harrisburg.. PA 17108-0999. 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: Stephen E. Geduldig, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7119. ATTORNEY ID# 43530 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy SEREENA L. LECRONE, a Minor by her Parent and Guardian MARY A. LECRONE, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LIABILITY 17. NO. 2010-3366 WOLF'S BUS LINES, INC. Defendant -- LAVA7-MEDICAL : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Records Custodian K-Mart Pharmacy. l ] 80 Vdalnut Bottom Road. Carlisle, PA 17015 (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: A complete cop}, of your entire file on Sereena Lecrone; DOB: 05/15/1993. including. but not limited to Pharmacist's statements. Customer History Report. telephone messages. prescriptions, telephone scripts prescription log/historv. order forms. faxes. insurance log/history.. billing records or payment ledger (including any records stored electronically or written). from date of first prescription until present. at: Thomas Thomas & Hafer. LLP. 305 N. Front St., P.O. Box 999, Harrisburg. PA 17108-0999 (Address) 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: Stephen E. Geduldig, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7119 ATTORNEY ID# 43530 ATTORNEY FOR: Defendants BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy SEREENA L. LECRONE, a Minor by her Parent and Guardian MARY A. LECRONE, Plaintiffs It. WOLF BUS LINES INC. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Docket No.: 2010-3336 TURY TRIAL DEMANDED CNIL ACTION LAW - MEDICAL LIABILITY: SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Records Custodian. Physicians of Rehabilitation. Industrial & Spine Medicine. P.C., 4950 Wilson Lane. Mechanicsburg PA 17055 (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: Complete cries of any and all medical records. including. but not limited to, reports. notes. studies bills incoming and outgoing correspondence. films, labs, phone messages, surnrnaries, etc for any inpatient. outpatient. ER. clinic or office visits pertaining to Sereena Lecrone, DOB: 05/15/1993, from date of first visit to the present at: Thomas. Thomas & Hafer. LLP. 305 N. Front St... P.O. Box 999.. Harrisburg. PA 17108-0999 (Address) 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: Stephen E. Geduldig, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7119 ATTORNEY ID 4 43530 ATTORNEY FOR: Defendants BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy SEREENA L. LECRONE, a Minor by her Parent and Guardian MARY A. LECRONE, Plaintiffs Al. WOLF BUS LINES INC. Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Docket No.: 2010-3336 JURY TRIAL DEMANDED CIV1L ACTION LAW - MEDICAL LIABILITY: SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Records Custodian Carlisle Pediatric Associates. 804 Belvedere Street. Carlisle. PA 17013 (Name of Person or Entity) to produce Within twenty (20) days after service of this subpoena, you are ordered by the court the following documents or things: Complete copies of any and all medical records. including. but not limited to. reports. notes, studies. bills. incoming and outgoing correspondence, films. labs, phone messages, summaries, etc, for any inpatient. ou?2atient, ER. clinic or office visits pertaining to Sereena Lecrone, DOB: 05/15/1993, from date of first visit to the present at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Boa 999.. Harrisburg. PA 17108-0999 (Address) 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: Stephen E. Geduldig, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7119 ATTORNEY ID 4 43530 ATTORNEY FOR: Defendants BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy CERTIFICATE OF SERVICE AND NOW, this j `1 A day of , 2010, I, Susan S. Jones, a Paralegal in the law firm of Thomas, Thomas & Hafer, LLP, hereby certify, that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, first class, postage prepaid, to the follo Aring: Marcus A. McKnight, III, Esquire IRWIN & McKNIGHT 6o West Pomfret Street Carlisle, Pennsylvania 17013-3222 Susan S. Jones, Paralegal 880002.1 CERTIFICATE OF SERVICE AND NOW, this 15+? day of I, Susan S. Jones, a Paralegal in the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, first class, postage prepaid, to the following: Marcus A. McKnight, III, Esquire IRWIN & McKNIGHT 6o West Pomfret Street Carlisle, Pennsylvania 17013-3222 S-Y(4- Susan S. Jones, Pa alegal 888023.1 Stephen E. Geduldig, Esquire E-mail: sgeduldig@tthlaw.com Attorney I.D. No. 43530 (717) 237-7119 Stephanie L. Hersperger, Esquire E-mail: shersperger@tthlaw.com Attorney I.D. No. 78735 (717) 255-7239 THOMAS, THOMAS & HAFER, LLP 305 North Front Street Post Office Box 999 Harrisburg, Pennsylvania 17108-0999 FAX (717) 237-7105 -U4 r JCL: -PT ?1T ION A I _. ,3ERLAND COUNT'` Attorneys for Defendant: WOLF'S BUS LINES, INC. SEREENA L. LECRONE, a Minor by her Parent and Guardian MARY A. LECRONE, Plaintiffs V. WOLF'S BUS LINES, INC. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -- LAW : NO. 2010-3366 : JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO ISSUANCE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that: 1. A Notice of Intent to Serve Subpoenas, with copies of the subpoenas attached thereto, was mailed or delivered to each party; 2. A copy of the Notice of Intent, including the proposed subpoenas, is attached to this Certificate; 3. The 20 day period for filing and serving objections has been waived by all counsel, correspondence is attached, hereto; 4. The subpoenas which will be served are identical to the subpoenas which are attached to the Notice of Intent to Serve Subpoenas. THOMAS T & HAFER, LLP Date: 11/1vhl STEPHEN E. GEDULDIG, ESQUIRE Attorney I.D. No. 43530 STEPHANIE L. HERSPERGER, ESQUIRE Attorney I.D. No. 78735 Attorneys for Defendants, WOLF BUS LINES, INC. Stephen E. Geduldig, Esquire E-mail: sgeduldig@tthlaw.com Attorney I.D. No. 43530 (717) 237-7119 Stephanie L. Hersperger, Esquire E-mail: shersperger@tthlaw.com Attorney I.D. No. 78735 (717) 255-7239 THOMAS, THOMAS & HAFER, LLP 305 North Front Street Post Office Box 999 Harrisburg, Pennsylvania 17108-0999 FAX (717) 237-7105 SEREENA L. LECRONE, a Minor by her Parent and Guardian MARY A. LECRONE, Plaintiffs V. WOLF'S BUS LINES, INC. Defendant Attorneys for Defendant: WOLF'S BUS LINES, INC. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -- LAW NO. 2010-3366 : JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Counsel of Record Defendant intends to serve subpoenas, identical to the ones that are attached to this Notice. You have twenty (2o) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoenas. If no objection is made, the subpoenas will be served. THOMAS, ;THOMAS & kL4,FE LP Date: STEPHEN E. GEDULDIG, ESQUIRE Attorney I.D. No. 43530 STEPHANIE L. HERSPERGER, ESQUIRE Attorney I.D. No. 78735 Attorneys for Defendants, WOLF BUS LINES, INC. CAROL BOWER and RICHARD BOWER, her husband Plaintiffs V. WOLF'S BUS LINES INC. and PHILLIP WAGAMAN, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Carlisle Area School District, Student Records Dept., 623 W. Penn St. Carlisle, PA 17013 (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: Complete copies of the entire academic file, regarding Sereena Lecrone. DOB 05/15/1993, including, but not limited to, any and all, reports, correspondence, notes, memoranda, medical records, doctor 's excuses, standardized test results, absentee sheets, reviews, findings, iug_dance counselor documents and determinations, transcripts for all grades earned, etc., from date registered until present. at: Thomas, Thomas & Hafer, LLP, 305 N. Front St., P.O. Box 999, Harrisburg, PA 17108-0999 (Address) 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: Stephen E. Geduldig, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7119 ATTORNEY ID # 43530 ATTORNEY FOR: Defendants IN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA CIVIL ACTION - - LAW NO. to-s-648 : JURY TRIAL DEMANDED BY THE COURT: DATE: 1007319.1 Seal of the Court Prothonotary/Clerk, Civil Division Deputy SEREENA L. LECRONE, a Minor by her Parent and Guardian MARY A. LECRONE, Plaintiffs v. WOLF BUS LINES INC. Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Docket No.: 2010-3336 JURY TRIAL DEMANDED CIVIL ACTION LAW - MEDICAL LIABILITY: SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Records Custodian, WellMan Neurology, Todd Barron, M.D., 228 Saint Charles Wad Suite 200, York, PA 17402. (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: Complete copies of any and all medical records, including, but not limited to, reports, notes, studies, bills, incoming and outgoing correMondence, films, labs, phone messages, summaries, etc. for any inpatient, outpatient, ER, clinic or office visits pertaining to Sereena Lecrone, DOB: 05/15/1993, from date of first visit to the present. at: Thomas, Thomas & Hafer, LLP, 305 N. Front St., P.O. Box 999, Harrisburg, PA 17108-0999 (Address) 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: Stephen E. Geduldig, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7119 ATTORNEY ID # 43530 ATTORNEY FOR: Defendants BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy 1007330.1 CERTIFICATE OF SERVICE AND NOW, this ?g day of dC--hGtk/ , 2011, I, Susan S. Jones, a Paralegal in the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, first class, postage prepaid, to the following: Marcus A. McKnight, III, Esquire IRWIN & McKNIGHT 6o West Pomfret Street Carlisle, Pennsylvania 17013-3222 Susan S. Jones, 'Paralegal 1007340.1 THOMAS. THOMAS & HAFER LLP Marcus A. McKnight, III, Esquire October 28, 2011 Page 2 I, Marcus A. McKnight, III, Esquire, do hereby agree to waive the 20 Day Notice of Intent rule allowing counsel for Defendant, Wolf Bus Lines, Inc., to issue subpoenas as indicated on the Notice of Intent. DATE: CERTIFICATE OF SERVICE AND NOW, this day of Q dojNqv-? , 2011, I, Susan S. Jones, a Paralegal in the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, first class, postage prepaid, to the following: Marcus A. McKnight, III, Esquire IRWIN & McKNIGHT 6o West Pomfret Street Carlisle, Pennsylvania 17013-3222 'Sr' Susan S. Jones, Paralegal 888023.2 U A i TA i-" Thomas, Thomas & Hafer, LLP Stephen E. Gelduldig, Esquire Attorney I.D. 43530 305 North Front Street, 6th Floor P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7157 sgeduldig@tthlaw.com o It rti'triBr1 H Cl'` i't Attorneys for Defendant Wolf Bus Lines, Inc. SERENA L. LECRONE, a Minor, by her Parent and Guardian MARY A. LECRONE, Plaintiffs V. WOLF'S BUS LINES, INC., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010-3366 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO `SERVICE OF SUBPOENAS PURSUANT TO RULE 4409.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that: 1. A Notice of Intent to Serve Subpoenas with a copy of the subpoenas attached thereto was mailed or delivered to each party on or about May 24, 2012, to serve subpoenas upon Milton S. Hershey Medical Center, and Carlisle Pediatric Associates. 2. A true and correct file copy of the Notice of Intent, including a copy of the proposed subpoenas, is attached to this Certificate. 3. Twenty (20) days have elapsed and there have been no objections to the issuance of the subpoenas. 4. The subpoenas which will be served are identical to the subpoenas attached to the Notice of Intent to Serve Subpoenas. Respectfully submitted, THOMAS, THOMAS & HAFER, LLP By. STEPHEN E. GEDULDIG, ESQUIRE AnomeyI.D. No. 43530 Counsel for Defendant Date: June 20, 2012 Stephen E. Geduldig, Esquire E-mail: sgeduldig@tthlaw.com Attorney I.D. No. 43530 (717) 237-7119 Stephanie L. Hersperger, Esquire E-mail: shersperger@tthlaw.com Attorney I.D. No. 78735 (717) 255-7239 THOMAS, THOMAS & HAFER, LLP 305 North Front Street Post Office Box 999 Harrisburg, Pennsylvania 17108-0999 FAX (717) 237-7105 SEREENA L. LECRONE, a Minor by her Parent and Guardian MARY A. LECRONE, Plaintiffs Attorneys for Defendant: WOLF'S BUS LINES, INC. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -- LAW V. NO. 2010-3366 WOLF'S BUS LINES, INC. Defendant ;JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Counsel of Record Defendant intends to serve subpoenas, identical to the ones that are attached to this Notice. You have twenty (2o) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoenas. If no objection is made, the subpoenas will be served. Date: P7 a41 241 2 THO ,THOMAS &HAFER, LLP S EN E. GEDULDIG, E DIRE Attorney I.D. No. 43530 STEPHANIE L. HERSPERGER, ESQUIRE Attorney I.D. No. 78735 Attorneys for Defendants, WOLF BUS LINES, INC. SEREENA L. LECRONE, a Minor by her Parent and Guardian MARY A. LECRONE, Plaintiffs V. WOLF BUS LINES INC. Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Docket No.: 2010-3336 JURY TRIAL DEMANDED CIVIL ACTION LAW - MEDICAL LIABILITY: SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Milton S. Hershey Medical Center Health Information Services HU-24 P.O. Box 850, Hershey PA 17033-0850 (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: Complete copies of any and all medical records including but not limited to, reports, notes, studies bills incoming and outgoingcorrespondence, films labs phone messages, summaries, etc for any i patient outpatient ER clinic or office visits pertaining to Sereena Lecrone, DOB: 05/15/1993, from 06/01/11 to the present. at: Thomas Thomas & Hafer LLP 305 N Front St P.O. Box 999, Harrisburg PA 17108-0999 (Address) 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: Stephen E. Geduldig, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7119 ATTORNEY ID # 43530 ATTORNEY FOR: Defendants BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy 1093646.1 SEREENA L. LECRONE, a Minor by her Parent and Guardian MARY A. LECRONE, Plaintiffs v. WOLF BUS LINES INC. Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Docket No.: 2010-3336 JURY TRIAL DEMANDED CIVIL ACTION LAW - MEDICAL LIABILITY: SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Records Custodian Carlisle Pediatric Associates 804 Belvedere Street Carlisle PA 17013. (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: Complete copies of any and all medical records including but not limited to, rgports,_notes, studies bills incominiz and outgoing LcorreMondence films labs phone messages, summaries, etc for any inpatient outpatient ER clinic or office visits pertaining to Sereena Lecrone, DOB: 05/15/1993, from 09/30/10 to the present. at: Thomas Thomas & Hafer LLP 305 N Front St P.O. Box 999, Harrisburg, PA 17108-0999 (Address) 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: Stephen E. Geduldig, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7119 ATTORNEY ID # 43530 ATTORNEY FOR: Defendants BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy 1093636.1 CERTIFICATE OF SERVICE I, SUSAN S. JONES, PARALEGAL of the law firm of THOMAS, THOMAS, & HAFER, LLP do certify that I served the foregoing document on the following person(s), by depositing the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Markus A. McKnight, III, Esquire IRWIN & McKNIGHT 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 S,,, ?qrnaA? Susan S. Jones, Paralegal Daze: June 20, 2012 1107149.1 r'''' E: ~~.1 ,"t ~ ~~ 1,'1, ~ (~ ~ r t i %Jt1~Q~27 p~ ?: ~ ~ U ~E~NS YLy E;~Uf~~~ ~'y ~raiA SEREENA L. LECRONE, a Minor by her Parent and Guardian, MARY A. LECRONE, Plaintiffs v. WOLF BUS LINES, INC., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2010 - 3366 CIVIL TERM CIVIL ACTION -LAW PRAECIPE TO SETTLE AND DISCONTINUE TO THE PROTHONOTARY: Please mark the above-captioned case settled and discontinued. Respectfully submitted, IRWIN & N~NIGHT, P.C Marcus ,~(. M I, Esquire 60 West Pomfret et Carlisle, PA 17013 (717)249-2353 Supreme Court I.D. No: 25476 Date: November 27, 2012 SEREENA L. LECRONE, a Minor by her Parent and Guardian, MARY A. LECRONE, Plaintiffs v. WOLF BUS LINES, INC., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2010 - 3366 CIVIL TERM CIVIL ACTION -LAW CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached Praecipe to Settle and Discontinue was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: STEPHEN E. GEDULDIG, ESQUIRE THOMAS, THOMAS & HAFER, LLP P. O. BOX 999 HARRISBURG, PA 17108-0999 By: IRWIN & GHT, P.C. Esquire Date: November 27, 2012 60 West Pomfret Street Carlisle, PA 17013 (717) 249-2353 Supreme Court I.D. No. 25476