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Home My WebLink About01-2767 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DiViSiON HENRY LINE and : CONSTANCE BENTLEY LINE : CASE: 191 Ridge Drive : Carlisle, PA 17013 : Plaintiffs : CIVIL ACTION - LAW ,. V. : JURY TRIAL DEMANDED MICHAEL SCOTT : 326 Dorothy Drive : Pittsburgh, PA 15235 : Defendant. : PRAEC]PE FOR WRIT OF SUMMONS. TO THE PROTHONOTARY/CLERK OF SA~D COURT: Please issue a Writ of Summons against the Defendant, MICHAEL SCO~-I', in the above captioned case. Respectfully submitted, KAIN, BROWN,& ROBERTS LLP Joseph S. 8obei, Esq. pD 17715] Mat. ga. Tat'low, Esq. lID 23474] Attorney for Plaintiffs Attorney for Plaintiffs 212 North Third Street 119 East Market Street Suite 202, Cranberry Court York, Pennsylvania 17401 Harrisburg, PA 17101-1505 Tele: (717) 843-8968 fax: [717] 843-5664 DATED: May 3, 2001 SUMMONS IN CIVIL ACTION TO: MICHAEL SCO'I-r 326 DOROTHOY DRIVE PITTSBURGH, PA 15235 HANOVER, PA 17331 YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFFS HAS COMMENCED AN ACTION Pr~th'ono ry ".rk,~vil~i)~vision~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HENRY LINE and : CONSTANCE BENTLEY LINE : CASE: 0t - 2767 Civil 191 Ridge Drive : Carlisle, PA 17013 : Plaintiffs : CIVIL ACTION - LAW V, : : JURY TRIAL DEMANDED MICHAEL SCOTT : 326 Dorothy Drive : Pittsburgh, PA 15235 : Defendant. : PRAECIPE TO REINSTATE THE WRIT OF SUMMONS TO THE PROTHONOTARY/CLERK OF SAID COURT: Please reinstate the Writ of Summons against the Defendant, MICHAEl. SCOTT, in the above captioned case. Plaintiff's Address: Respectfully submitted, 191 Ridge Drive Carlisle, PA 17013 EM)i, BY:~ - Joseph B. Sobel, Esq. lID 17715] Mare g. Tarlow, Esq. lID 23474] Attorney for Plaintiffs Attorney for Plaintiffs 212 North Third Street 119 East Market Street Suite 202, Cranberry Court York, Pennsylvania 17401 Harrisburg, PA 17101-1505 Tele: (717) 843-8968 fax: [717] 843-5664 DATED: June 6, 2001 SUMMO.S ACT,O. YOU ARE NOTIFIED TH-"A'T'..~E ABOVE-~ HAS COMMENCED AN ACTION AGAINST YOU. ~ ....... Date: / MY: /,~ Deputy SHERIFF'S RETUP, N - OUT OF COUNTY CASE NO: 2001-02767 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LINE HENRY ET AL VS SCOT MICHAEL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFEND/kNT , to wit: SCOTT MICHAEL but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of ALLEGHENY County, Pennsylvania, to serve the within WRIT OF SUMMONS On May 25th , 2001 , this office was in receipt of the attached return from ALLEGHENY ~ Sheriff's Costs: So aDs'were;, .. ,, Docketing 18.00 .~_. ~ ~~ Out of County 9.00 ~_ Surcharge 10.00 ~_ R..Thomas Kline Dep. Allegheny Co 32.25 ..S~?~iff of Cumberland County 69.25 05/25/2001 ~IN, BROWN & ROBERTS Sworn and subscribed to before me this ~ day of ~ ~ A.D. ~ f Pro~honota~y ~ ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HENRY LINE end : (,~ CONSTANCE BENTLEY LINE : CASE: ~'~!- 191 Ridge Ddve : Carlisle, PA 17013 : Plaintiffs : CIVIL ACTION - LAW V. -' · . JURY TRIAL DEMANDED MICHAEL SCOTT : 326 Dorothy Ddve : Pittsburgh, PA 15235 : Defendant. : PRAEClPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY/CLERK OF SAID COURT: Please issue a Wdt of Summons against the Defendant, MICHAEL SCO']-I', in the above captioned case. Respectfully submitted, KAIN, BROWN & ROBERTS LLP BY: . '~'~-'~t~~' Joseph B. Sobei, Esq. lID 17715] Ma, rc'G. Tarlow, Esq. [ID 23474] Attomey for Plaintiffs Attomey for Plaintiffs 212 North Third Street 119 East Market Street Suite 202, Cranberry Court York, Pennsylvania 17401 Harrisburg, PA 17101-1505 Tele: (717) 843-8968 fax: [717] 843-5664 DATED: May 3, 2001 · **** TRUE (X)PY FROM RECORD SUMMONS iN CIVIL ACTION InT~I~~. I Imm .ntoaat myltm.l TO: MICHAEL SCOTT f~~~ 326 DOROTHOY DRIVE PITTSBURGH, PA 15235 . HAS YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFFS COMMENCED AN ACTION AGAINST YOU. Prothonotary/Clerk, Ciyil Division(~ Date: ~ ~:~/-) I BY: . ' .. . v Deput~J In The Court of Common. P/'eas of Cumberland County., Pennsylvania Henr~ Li.n~, et. h~~~ No. 01-2767 Now, 5 / 9 / o ~ ,20 O O, I, S~F OF C~E~ CO~TY, PA, do hereby d~u~ ~e She~ffof Allegheny Co~W to execute ~is W~, ~is dep~on being m~e at ~e request ~d risk of the Pla~ti~. Shrift of Cmb~lmd Count, PA Affidavit of Senqce Now, ,20. , at o'clock M. served the within ~pon by handing to a copy of the orig/nal and made known to the contents thereof. ~)~,~.-, -x U~-,~ '%"v~,a~ So answers, COSTS ~ Swora and subscribed before SERVICE ~,~,/~ ' '~; ..... "''~ mc r3.is day of k"~, t . ~0~ MILEAGE AFFIDA\rlT ?~ .OlD ] She{la R. O'B~ien, Notary Pub{{c { I pittst).foh AIIpqhsqy Count~ I HENRY LINE and CONSTANCE : IN THE COURT OF COMMON PLEAS OF BENTLEY LINE, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs : : vs. : 01-2767 CIVIL : CIVIL ACTION - LAW MICHAEL SCOTT, : Defendant : JURY TRIAL DEMANDED IN RE: MOTION FOR ALTERNATIVE SERVICE ORDER AND NOW, this z .O day of August. 2001, upon motion of the plaintiffs, it is hereby ordered that the plaintiffs may make service on the defendant, Michael Scott, by: a. Advertisement in a paper of general circulation in the city of the defendant's residence, AND; b. Mailing by both regular and certified mail - return receipt requested in care of Patricia Evans. 326 Dorothy Drive, Pittsburgh, PA 15235, AND; c. Mailing by certified mail - return receipt requested to the insurance carrier listed on the police report as insuring the defendant, at an office of said carrier within the Commonwealth of Pennsylvania. BY THE COURT, Marc G. Tarlow, Esquire For the Plaintiffs13 :rim IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HENRY LINE and CONSTANCE BENTLEY LINE 191 Ridge Drive : CASE: 01 - 2767 Civil Carlisle, PA 17013 : Plaintiffs : CIVIL ACTION - LAW . MICHAEL SCOTT : JURY TRIAL DEMANDED 326 Dorothy Ddve ' Pittsburgh, PA 15235 : Defendant· : MOTION FOR ALTERNATIVE SERVICE PURSUANT TO RULE 430 A Plaintiffs by the undersigned counsel hereby file this motion for Alternative service pursuant to Rule 430(a), the following of which is a statement: 1. Plaintiffs have filed a summons dated May 7, 2001, naming as Defendant, Michael Scott. 2. This action relates to a motor vehicle accident that took place on June 5, 1999. A description of that accident is contained in the police report, which is attached hereto and incorporated by reference herein. [Exhibit 1]. 3. A skip trace was performed to find the whereabouts of the Defendant. [Exhibit 2]. Based upon that skip trace and subsequent investigation, it is clear that the Defendant lives in Pittsburgh Pennsylvania. An address was found, and based upon that skip trace the summons was sent to Allegheny Country for service. However, the Sheriff was unable to effectuate service at the location obtained by Plaintiffs. [Exhibit 3]. 4. Thereafter, Four Star Investigations P.O. Box 17370, Pittsburgh, Pennsylvania, performed an even more detailed investigation, a copy of which is attached as Exhibit 4 and incorporated by reference herein. This included review of Defendant's property records, canvassing of neighbors at the last known address, and review of criminal and tax records. More than a mere paper search was made. 5. As can be demonstrated by that investigation, the Defendant has effectively concealed his whereabouts, and certainly can not be served by the busy shedff's office of Allegheny County which requires a specific time and place for service. 6. Based upon this record the Plaintiffs allege that they have made more than a good faith effort to locate the Defendant and attempted without success, to serve the Defendant through conventional means. See 2 Pa. Std. Practice §10.103. In light of the very mobile nature of the Defendant's existence it does not appear practicable to require that notice be handed directly to him by the Sheriff or otherwise. Accordingly, Plaintiffs request by this motion relief pursuant to Pa. R.Civ. Pre. No. 430(a). 7. Consistent with precedent and common sense under the circumstances the Plaintiffs contends that service of the summons (and along with a copy of the police report attached hereto as Exhibit 1) can be practically made in each of the following manners which should provide actual notice to the Defendant: a. Mailing by 'Certified Mail - Return Receipt Requested' through the U.S. Postal Service to the insurance carrier listed on the police report as insudng the Defendant at an office of Allstate Insurance Company within the Commonwealth of Pennsylvania. b. Mailing by 'Certified Mail - Return Receipt Requested' through the U.S. Postal Service to the Pennsylvania Department of Motor Vehicles. It has been verified as per the attached Exhibit 5 that the Defendant has a valid Pennsylvania ddver's license. It should be reasonably expected that the Defendant's insurance company and the Pennsylvania Department of Motor Vehicles that has licensed the Defendant to drive should know the Defendant's whereabouts. Such methods of service have been court approved in other cases. See 2 Pa. Std. Practice §10.105-6. 8. Because of the legal precedents upon which the Plaintiffs rely are contained in this motion, the Plaintiffs request that they be excused from the necessity of providing a supporting brief that would only be repetitive of what is contained herein. Wherefore, Plaintiffs respectfully request that this Court grant an order substantially in the form attached hereto permitting alternative service upon the Defendant. Plaintiff's Address: Respectfully submitted, 191 Ridge Drive Carlisle, PA 17013 KAiN~j~,~ L[P BY: L.. ~ /... / Joseph B. Sobei, Esq. lID 17715] ~,L~-5 g. Tariow, Esq. pi) 23474] Attorney for Plaintiffs Attorney for Plaintiffs 212 North Third Street 119 East Market Street Suite 202, Cranberry Court York, Pennsylvania 17401 Harrisburg, PA 17101-1505 Tale: (717) 843-8968 fax: [717] 843-5664 DATED: July 17, 2001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HENRY LINE and . CONSTANCE BENTLEY LINE : CASE: 0'1 - 2767 Civil 191 Ridge Drive : Carlisle, PA 17013 : Plaintiffs : CIVIL ACTION - LAW . V. .. MICHAEL SCOTT : JURY TRIAL DEMANDED : 326 Dorothy Drive : Pittsburgh, PA 15235 : Defendant. : .AFFIDAVIT OF MARC G. TARLOW~ ESO I, Marc G. Tarlow, Esquire, am an adult individual and hereby state as follows: 1. As co-counsel for the Plaintiffs Henry Line and Constance Line, I caused the summons in this matter to be filed. 2. Before filing that summons my office contracted a private investigator to perform a skip trace on the Defendant which gave an address for Defendant in Pittsburgh as listed in the caption of this action. 3. The summons was transmitted to Allegheny County for service. When the Sheriff of that County indicated that the Defendant was reported to not reside at that address, this office hired a private investigator in Pittsburgh to locate the Defendant. That investigation was thorough and demonstrates that the Defendant has no "fixed" address. 4. I believe that we have done all that is practicable to locate the Defendant, and that even were an investigator able to observe the Plaintiff at a fixed location, that because of the mobile nature of his life style that such a sighting would not be sufficient to arrange "conventional" service by the Sheriff. 5. I make these statements based upon the best of my knowledge information and belief. Date: ~.. L/./ /q; ..~, ~:, ~. / //~/,~ ~/,~ Marc .(~,,T~/, Es(~. COMMONWEALTH OF PENNSYLVANIA COUNTY OF YORK On this. /~'~J day of July, 2001, before me a Notary Public, in and for said County and Commonwealth, personally appeared Marc G. Tarlow, Esq., known to me or satisfactorily proven, to be the person whose name is subscribed to the within instrument and in due form of law acknowledge the within instrument to be his act and deed. IN WITNESS WHEREOF, I hereunto set my hand and official seal the date and year aforesaid. Notary Public ~ NOTARIAL -~EAL My Commission Expires: J BRENDAK.'I'OI~EFI, Nolmypub~c 1 I C~ ~f Yo~k, yak Coumy LU¥ ~lmlalton [~plres ~..,~. 4. 200~ Cart of service at last and best known address. ~,.'~b..uu ~EP ~752 FA~ 774 21Z3 ST&~E ~'~R~ ~ ~003 2845842 , EXHIBIT 1 00/14;3 ht~ qR.,m - ..... ~.. ~-- . , . ~ . 2845842 .L,~. ,::~. ~.JU ~,t,'JJ ,La;~)~, I-A.~ ??4 '-',L.L:~ 5T.~.'L'£ Y,,'T.K.Y J.~ ~I)U4 2845843 '~' ,,.,,,m'.,~ P.O. Box 60515 Harrisburg, PA 17106-0515 (717) 612-9600 (800) 443-0824 Fax (717) 612-9700 April 18, 2001 Ms. Andrea Blouse Kain, Brown & Roberts LLP Attorneys at Law 119 East Market St. York, PA 17401 Re: Henry & Constance Line Dear Andrea: In regards to your facsimile request dated April 17, 2001 with regards to a current address for Michael Scott, whose last known address is 17 Boyd Avenue, Jersey City, NJ, this report contains the results of Information Network Associates, Inc.'s ("INA") investigation to date. Utilizing the last known address above, INA's investigation has yielded the following address history for a Mr. Michael Scott, age approximately 45-50 and social security number 107-46-5760: Address Date Reported 1) 326 Dorothy Dr. 01/01 Pittsburgh, PA 15235 2) 17 Boyd Ave. 03/92 Jersey City, NJ 07304 3) 549 W. 26~n St. 08/91 New York, NY 10001 Andrea, please call me should you need to serve legal process on Mr. Scott in Pittsburgh, PA, and I'll be more than happy to refer you to a private investigative and legal process service firm in Pittsburgh, PA that is both one of INA's clients and is affordable and reliable. EXHIBIT 2 Ms. Andrea Blouse April 18, 2001 Page 2 Andrea, as we discussed on the telephone, INA's investigation to date has also yielded three (3) names that could possibly be the owner of the vehicle driven by Mr. Michael Scott. They are as follows: 1) Jocelyn Scott 17 Boyd Avenue Jersey City, NJ 07304 SSN: Unknown 2) Joscelyn F. Scott Address: Unknown SSN: 262-46-7027 DOB: January 1927 3) Joscelyn F. Scott SSN: 091-42-8963 Address: 243 Jewett Ave. 1st Floor Jersey City, NJ 07304 The information contained in this report is self-explanatory; however, if you have any questions, or if additional investigation is required, please advise. Thank you for using Information Network Associates, Inc. to fulfill your investigative re. quirements. Very truly yours, Information Network As?ciat~Inc.,~ D~R:wl Daniel P. ~(yan, CPA,, CFA ~n The Cou~:~ of Common Pte-~s o.f Cu,mbeH~nd Coun~¢, Pennsylvania Henry Line, et. al. Now, 5/9/ot ,20 O 0, L S~F OF CL~E~.~N~ COL~Z, pA, do hereby depuxize ~e Shedffof Allegheny Co~n~ to axezute ~is Wri% ~is d~outatJon being made at ~e request ~d dsk of the PlaLmi~% 5h~iffofC~b~ri~5 Count, PA A£fidavit of Se~4ce Now, ,20 , at o'¢Io¢k _ .~. s~rved the within Upon at hanamg to cop), or,he and made icuown to COSTS ' Sworn ~nd subscribed before SER%~CE ,_...%~% $ · · -- -.~ ' No~ Seal [ . I Sheila R O'B~n Nota Public EXHIBIT * * **FOUR STAR INV_ESTIGATIONS P.O. BOX 17370, Pittsburgh, PA 15235 412-798-9300 FAX 412-798-g302 July 2, 2001 Ms. Andrea Blouse Kain, Brown & Roberts LLP Attorneys at Law 119 East Market Street York, PA 17401 RE: Michael Scott LKA: 326 Dorothy Drive Pittsburgh, PA 15235 SU~4ARY OF INVESTIGATION Following your request, investigation was conducted to locate the subject, Michael Scott. Unfortunately, after following numerous leads, the most recent physical address we could find for the subject was the 326 Dorothy Drive address. We know, however, that it is a possible girlfriend of the subject's, Patricia Evans, who actually lives at Dorothy Drive. We feel certain that Michael Scott probably visits this location on a regular basis and that Ms. Evans will go visit Mr. Scott wherever he is physically located. We are equally certain, however, that Michael Scott does not, on a regular basis, live at 326 Dorothy Drive. INVESTIGATION (1) SOCIAL SECURITY I~ESEARCR Since we were provided with a Social Security Number for Michael Scott, we initiated our investigation by conducting EXHIBIT 4 Page 2 a research of that Social Security Number by way of computer. The only address they had for Mr. Scott, according to the search, was the 326 Dorothy Drive location. (2) LISTED RESIDENCE ADDRESS - 326 DOROTHY DRIVE, PITTS~ORGH, PA 15235 We then continued our investigation by physically going to the neighborhood at 326 Dorothy Drive. We found this to be a one story ranch style single family structure located in a racially mixed lower middle income residential area of Penn Hills. In attempting to canvass the neighborhood, we found no one knowledgeable of the subject, Michael Scott. Sources did state that a female resides at this location but her name was unknown. Sources added that an Annie Bradford is the actual owner of the property at 326 Dorothy Drive but does not live at this location and merely rents out the property. In addition to neighbors, we also tried to contact someone at the 326 Dorothy Drive location. On Tuesday, June 19th at 11:50 a.m., however, we found no one to be inside the house. There was an older Ford Explorer bearing PA registration #BXW-2373 parked in the driveway. We terminated our handling in this neighborhood. (3) ALLEGHENY COUNTY T AXASSES~Nmm~_T OFFICE Through the computer, we were able to punch in the property address at 326 Dorothy Drive, where we confirmed the fact that an Annie N. Bradford is the listed owner. A photostatic copy of that information is enclosed. (4) PENNSYLVANIA DEPARTMENT OFMOTORVEHIe?.m5 - PA We then conducted a motor vehicle check through Harrisburg, running the license plate number of the vehicle parked in the driveway at 326 Dorothy Drive. As a result, we found that license plate number, BXW-2373, is registered to Patricia A. Evans at 326 Dorothy Drive, Pittsburgh, PA 15235. Page 3 = 200 so E PITTSBURgH j_ PA 1520~H~ ~ER 412-361-6~ We then continued our investigation by locating and then interviewing Annie Bradford, the owner of the property at 326 Dorothy Drive in Penn Hills. In speaking to this woman by phone, we found her most cooperative. She confirmed that a Patricia Evans does live at her property on Dorothy Drive and has lived there for a few years. Source also seemed familiar with the fact that Patricia Evans did have a boyfriend, who was probably the Michael Scott who we were trying to locate. This source was convinced, however, that Michael Scott was not Currently living at the Dorothy Drive address. She stated that he was still around the area, however, and that Patricia Evans was still "seeing him". Source stated that she is certain Patricia Evans would not cooperate in providing us where Mr. Scott could be found. She could not give us a specific reason as to why Patricia Evans was hiding Michael Scott's location but thought that it was quite possible that he was in some type of trouble or owed money. Source thought Michael Scott was approximately the same age as Patricia Evans and was probably in his early to mid forties. Finally, Ms. Bradford stated she would attempt to speak with Patricia Evans and see if she could determine where Michael Scott was located. We did re-contact Ms. Bradford several days later, and she revealed that she did talk to Ms. Evans but that Ms. Evans would not provide her where Michael Scott could be located. Annie Bradford was convinced that Patricia Evans was still seeing Michael Scott and suggested that a surveillance be conducted at the Dorothy Drive location. We terminated our handling with Ms. Bradford. ~6) SOCI~ SEC~ZT~ ~ C~DiT ~aC~ ~R PA~ICIA We then continued our investigation by conducting a credit and Social Security check on Patricia Evans. As a result, we did find a listing for Patricia A. Evans with a Social Security Number of 186-54-0455 and a date of birth of 7/1/61. Although one service showed the current address for Patricia Evans as 326 Dorothy Drive, Pittsburgh, PA 15235, another service found a more recent address for this individual as 647 Irwin Street, Wall, PA 15148. It also is interesting to note that in addition to the name of Page 4 Patricia A. Evans, it also listed this individual with the name of Patricia A. Kimbrugh. We also learned through this check that the phone number listed for the Dorothy Drive residence is 412-823-8119. (7) CANVASS OF NEIGHBORHOOD AT 647 IRWIN STREETf W~?.T. (WZLMERDING) f PA 15148 Investigation continued by going to this address thinking of the possibility of Michael Scott living at that property owned by his girlfriend, Patricia Evans. Upon arrival at this location, we found it to be one of six row house units located in an older lower income area. Unfortunately, we found no one home at any of these units. We were eventually able to locate the owner of 647 Irwin Street, who happened to be Mary Cvejkus. Ms. Cvejkus actually lives at 14051 Ridge Road in North Huntingdon, PA and has a phone number of 412-751-6480. We were able to speak with Ms. Cvejkus, who we found to be cooperative. She stated that the lease at 647 Irwin Street is listed to Gloria and Michelle Evans. Gloria Evans is in her forties and the mother of Michelle, who is in her twenties. Source stated they are the only two names listed on the lease. She was not familiar with a Patricia Evans or with a Michael Scott. Source stated that the Evans' have been renting from her for approximately four months and that Gloria, the mother, works at a bar or lounge somewhere in the Turtle Creek, PA area, while the daughter, Michelle, works at a local hospital. Source stated she has had no problems with these individuals as tenants, and they do pay their rent in a timely fashion. She added, however, that she has heard from some neighbors that there are somewhat "unsavory" characters that are seen going in and out of that residence at various times during the course of the evening. This is the extent of the information we could obtain from this source, and we terminated our handling here. .(8) ALLEGHENY COUNTY CRIMINAL BECO~nS - PITTSBUR~Hr PA We then continued our investigation by researching Criminal Records in Allegheny County, which does encompass the Pittsburgh and surrounding areas. Page 5 Under the name of Michael Scott, we did find one record for an arrest found under Criminal Complaint ~200100373. The arrest date was 10/28/00 and it involved charges against Michael Scott of driving under the influence (DUI), possession, and careless driving. Michael Scott had a Social Security Number of 107-46-5760, date of birth of 2/9/57 and an address of 326 Dorothy Drive, Pittsburgh, PA 15235. It appeared these charges were dismissed, although, he did plead guilty to the DUI and was sentenced to two days to a maximum of 12 months in jail. He was also placed on probation. Please note we did subsequently speak to his assigned probation officer, Ms. Nicole Jubera. She was cooperative and stated that she has been assigned Michael Scott. She added, however, that she just received the case, and she is not scheduled to see Mr. Scott for the first time until July 17th. After that point, he will then be assigned specific alcohol related classes that we will have to attend. Source stated that the most current address she has for Mr. Scott is the 326 Dorothy Drive address in Penn Hills. She will not know whether that is a valid address until after she sees him on July 17th. We asked Ms. Jubera if we could contact her after July 17th to see if Mr. Scott provided her with a more recent address, and she indicated that would not be a problem. We found this source most cooperative. RECO~4ENDATIONS We are forwarding to you our handling to date concerning this matter. We strongly suggest that surveillance efforts be initiated at the Dorothy Dr~ve address to observe whether Michael Scott arrives at that location or whether his girlfriend, Patricia Evans, leaves to visit him at an unknown location. If after reviewing the report and the information contained therein you do feel additional handling is needed, please advise and we will handle as per your directive. Ross J. Gigli~'tti Enclosure Allegheny County Assessment Page I of I ALLEGHENY COUNTY CERTIFIED VALUES ~me Pa§e FOR 2001 ":: .~i~.?o .... 3:22 A['~l Last Upda.-.e was Saturday;. June '16. 200'I OWNER GENERAL INFORMATION Municipal Code: 934 PENN HILLS Block Lot: 0368-G-00268-0000-00 School District: Penn Hills Twp Previous Block Lot: 0368-G-00268-0000~00 Neighborhood Code: 93428 Owner Name: BRADFORD ANNIE M Property Location: 326 DOROTHY DR Tax Code: Taxable Sale Flag: Regular Owner code: Regular Sale Date: 12/4/1987 State Code: Residential Sale Price: $45,000 Use Code: Single Family Deed Book: 7692 Lot Front: 0 Deed Page: 186 Lot Area: 8,000 Abatement: No Homestead: No Farmstead: No County Value Full Value Total Land Value $15,600 Total Land Value $15, Total Building Value $38,100 Total Building Value $38, Total Market Value $53,700 Total Market Value $53, Property Description County Land: LAND - PRIMARY SITE (8000 SQFT). $15,600 Building: 1 STY RANCH HOUSE $38,100 W/PORCH FRAME - OPEN; PATIO CONCRETE; STOOP MASONRY AND FRAME SHED. Address Information Tax Bill Mailing: CITIMORTGAGE INC 0000 PO BOX 1800 FARMINGTON HIL, MI 48333-0000 Change Notice Mailing: 00326 DOROTHY DR PITI'SBURGH, PA 15235-0000 L_._e. gal Disclaimer http://~wvw2~c~unty~a~egheny~pa~us/Rea~Estate/General~asp?CurrB~L~t=~368G~268~'~ 6/19/2001 26'867 Imued Birth Date Exp~me i 08/16/l]0 02/~J/S7 02/10/04 ' 8~ Height · Eya~ M $' 10" BFIO Claas En~orlements C -- Com./Med. Re~t~lctlona ." · J "~:26 DOROTHY DRIVE " · PII'rSBURGH PA 15235 "" ·'t MICHAEL SCOTF ::. "" """"':~'. .... · '".' .'." i - ':.' "':' '~.'" - ' ' :"':" .i.'. '": '." "".' ""' "'.'"..,'. · '.:"' " .' "." '.. . .:- . . EXHIBIT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HENRY LINE and CONSTANCE BENTLEY LINE : Plaintiffs : CASE: 01-2767- Civil · CIVIL ACTION. LAW ¥. .. MICHAEL SCO'I'I' : JURY TRIAL DEMANDED Defendant. : You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twent 20 appearance Y ( ) days after thi · . personally or by attorney a ~;, ....... s Complaint and not;ce , nd -,,.t~ ,n writing with the ~.,,.,, ....... .ara o=,,=u, oy enterin a wri ..... x~u, oerenses or obiection- *--g.,-- . .tten set forth against you. You are warned that if you fail to do so the Case may proceed may be entered against you · ,= ~u me claims without you and a judgment by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. OUT WHERE YOU CAN GE ~="' ...... ELEPHONE T = ~" ...... NOT HAVE A T ,.,.~,~. m:Lp. H,. urr;~= ~iET FORTH BELOW TO FIND Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania Telephone Number: [717) 249-3166 AVIsO USTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea defenderse de las quejas expuestats en las paginas si. guiententse, debe tomar accion dentro de veinte (20) dias a partir de la fecha en que recibio la demanda y el.av~so Uated debe prese, n~.r comparecencia escrits en Persona Coa~ pot escnfo sus defensas o sus object,ones a las demandas en su contra, o pot abogado y Presentar en ia Se ha avisado que si usted no se defienda, la corte tomara medidas y puede entrar una orden contra usted sin Previo aviso o notificacion y por cualquier queja o alivio que es pedido en ia peticion de demanda. USTED PUEDE PERDER DINERo O PROPIEDADES O OTROS DERECHOs IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADo INMEDIATAMENTE. SI USTED NO TIENE O CONOCES UM ABOGADo, VAYA EN PERSONA O LLAME POR TELEFONo A LA OFICIANA CUYA DIRECCION SE ENCUENTRA ESCRITA ARA, JO PARA AVERJGUAR DONDE SE PUEDE CONSEQUIR ASISTENCIA LEGAL. Cumbertsnd County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania Telephone Number: [717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HENRY LINE and CONSTANCE BENTLEY LINE ' 191 Ridge Drive : Carlisle, PA 17013 .' CASE: 01 -2?6? Civil Plaintiffs : CIVIL ACTION. LAW MICHAEL SCOTT : JURY TRIAL DEMANDED 326 Dorothy Drive : Pittsburgh, PA 15235 : Defendant. ' COMPLAINT AND NOW, THIS 16t~ day of January 2002, come the plaintiffs, Henry Line and Constance Line by their undersigned counsels, with the following: 1. The Husband/Plaintiff is Henry Line, an adult individual who resides in Carlisle, Pennsylvania. 2. The Wife~Plaintiff is Constance Line who also resides in Carlisle, Pennsylvania, and who at all times relevant to the Complaint was the husband of plaintiff Henry Line. 3. Defendant in this action Michael Scott who resides at 326 Dorothy Drive, Pittsburgh, PA 15235. 4. On or about June 5, 1999, Husband/Plaintiff operating a vehicle a motor vehicle traveling on 1- 81 southbound in Cumberland County, Pennsylvania and stopped behind the line of traffic held up by construction. 5. Defendant Michael Scott was operating a motor vehicle traveling on 1-81 southbound. When Husband/Plaintiff stopped for construction traffic, the Defendant who was directly behind the Husband/Plaintiff failed to stop and struck Plaintiff/Husband,s vehicle in the rear causing PlaJntiff/Husband,s vehicle to impact the stopped vehicle in front of him. 6. Defendant failed to pay proper attention to the road and was traveling too fast for conditions. 7. The accident was caused by the negligence and recklessness of the defendant and was in no way caused by Husbend/Plaintif. 8. The wrongfu~ actions of the defendant were the preximate, legal, substantia~ and direct cause of the inJuries suffered by the plaintiff. COUNT I Constance Bentley Line V. Michael Scott 9, As a direct and proximate result of the wrengful actions of the defendant, the Wife/Plaintiff has sustained serious and permanent injudes as follows: (a) severe strain, sprain, and injury to her lumbar, sacral, thorecic and cervical spine, shoulders and associated soft tissues, arteries, veins and/or other blood vessels and nervous tissues; (b) damage to the muscles, blood vessels and other soft tissues of her body, including without limitation her back, neck, spine, arm(s), shoulder(s) and other parts of her body; (c) Possible damage to the nerves running from her cervical, thoracic, lumbar and sacral spine to her arm(s), leg(s), shoulder(s) and or possible damage to a cervical disk(s). W~fe/Plaintif as a result is limited Jn her functions and ability to lift, s/t, walk or even drive. (d) Lumbrosacral strain1 rediculitis and disc disease. The disc disease includes but is not limited to T-12, L-6, and L-4-5. (e) further injuries to her back, neck, head and other extremities; (f) such other injuries as may become known in the future; (g) all of the above are or may be Permanent; and (h) all of the above have required and/or in the future will or may require medical, surgical, treatment and/or other treatment and therapy. 10. A direct and preximate result of the wrongful actions of the defendant set forth above, the WEe/Plaintif has suffered and will continue to suffer great pain, suffering, fear, mental anguish, emotional distress, embarrassment and humiliation. Wife/Plaint/fi has sustained and will continue to sustain a permanent loss of the enjoyment of life and loss of life's pleasures. 11. As a direct and proximate result of the wrongful actions of the defendants set forth above, the Wife/Plaintiff has sustained and will continue to sustain a loss of earnings and earning power and earning capacity and profits from the family/husband's business due to her inability to work in that business for which claim is hereby made. 12. As a direct and proximate result of the wrongful actions of the defendants set forth above, the Wife/Plaint/fi has or may incur medical expenses and income losses which exceed those which are recoverable under 75 Pa.C.S. §1711, §1712 or other applicable law and for which claim is hereby made. WHEREFORE, Plaintiff/Wife demands judgment in her favor and against the defendant in excess of $30,000 plus costs of suit, plus pre and post judgment interest and such other and different relief as to which the plaintiff may be entitled. COUNT II Henry Line V. Michael Scott 13. The Preceding paragraphs are incorporated by reference. 14. As a result of the injuries sustained by the Wife/Plaintiff, the Husband/Plaint/fi, has been deprived of the assistance, companionship, consortium, work in his business for which replacement help was required, and society of his wife all of which have been or will be to his great damage and loss. 15. As a result of the collision, the automobile owned by the Husband/Plaintiff, sustained damage requiring repairs in the amount of $1263.50. (A copy of the repair estimate Js attached hereto and incorporated by reference herein.) That amount is hereby claimed in addition to the other damages sought in the complaint. WHEREFORE, Plaintiff/Husband demands judgment in his favor and against the Defendant in excess of $30,000 plus costs of suit, plus pre and post judgment interest and such other and different relief as to which the plaintiff may be entitled. Respectfully submitted, KAIN, B~OWN & ROBEItTS/~/ .. .... · ow, _g~.q. [ID 23474] s s ~ r-asr Market Street York, Pennsylvania 17401 Tele: (717) 843-8968 fax: [717] 843-5664 Joseph B. Sobel, Esq. Law Office of Joseph B. Sobel 212 North Third Street Suite 202 - Cranberry Court Harrisburg, PA 17101-1505 Attorneys for Plaintiffs I verify that the statements made in the fnregoing documents are true and correct to the best of my knowledge, information and belief'. I understand that the statements made herein are made subject to the penalties of 18 Pa.C.S. ~4.904 relating to unaworn falalflcafion to authorities. Hem,~ Li~e / V~RIFICATION I ved~y that the statements made In the foregoing documents are true and correct to the best of my knowledge, information and belief. I understand that the statements made herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to author/ties. o~s~ance Bentley Line ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HENRY LINE and CONSTANCE BENTLEY LINE : 191 Ridge Drive : CASE: 0t -2767 Civil Carlisle, PA 17013 : : v. Plaintiffs : CIVIL ACTION - LAW MICHAEL SCOTT : JURY TRIAL DEMANDED 326 Dorothy Drive : Pittsburgh, PA 15235 ' Defendant. : CERTIFICATE OF SERVICF AND NOW, this 16~ day of January 2002, I, MARC G. TARLOW, ESQUIRE, a member of the law firm of KAIN, BROWN & ROBERTS LLP, hereby certify that I have served a copy of the foregoing NOTICE and COMPLAINT by depositing same in the United States mail, postage prepaid at York, Pennsylvania, and by Certified Mail - Return Receipt Requested, addressed to as follows: Michael Scott 326 Dorothy drive Pittsburgh, pa 15235 Allstate Market Claim Office 6345 Flank Drive Suite 1000 Harrisburg, PA 17112. Respectfully submitted, KAIN, BROWN & ROBERTS LLP By: __ /~ MaJ~G. Tarlow, Esq. lID 23474] 119 East Market Street York, Pennsylvania 17401 Tele: (717) 843-8968 fax: [717] 843-5664 Joseph B. Sobel, Esq. Law Office of Joseph B. Sobel 212 North Third Street Suite 202 - Cranberry Court Harrisburg, PA 17101-1505 Attorneys for Plaintiffs HENRY LINE and : IN THE COURT OF COMMON PLEAS CONSTANCE BENTLEY LINE, : OF CUMBERLAND COUNTY, PENNSYLVANIA : Plaintiffs : CIVIL ACTION - LAW : No. 01-2767 V. · : MICHAEL SCOTT, : Defendant : JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please issue a Rule upon the Plaintiff to file a Complaint within twenty (20) days or suffer a judgment of non pros. Respectfully submitted, NEALON & GOVER, P.C. Christopher"J'. I~night, Esquire Attorney I.D. No. 80058 2411 North Front Street ///~ /o Harrisburg, PA 17110 Date: ~ "4_ (717) 232-9900 RULE TO THE PLAINTIFF: A Rule is hereby issued upon you to file a Complaint within twenty (20) days of service of this Rule or suffer a judgment of non pros. PFoth-o~otary_'~'P',4~- ~ CERTIFICATE OF SERVICF AND NOW, this /~' day of January, 2002, I hereby certify that have served the foregoing Praecipe for Rule to File a Complaint on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Mare G. Tadow, Esquire Kain, Brown & Roberts, LLP 119 East Market Street York, PA 17401 Joseph B. Sobel, Esquire 212 North Third St., Suite 202 Cranberry Court Harriburg, PA 17101-1505 Christopher,. Kr~ight, Esquire HENRY LINE AND : IN THE COURT OF COMMON PLEAS CONSTANCE BENTLEY LINE, : OF CUMBERLAND COUNTY, PENNSYLVANIA . Plaintiffs : CIVIL ACTION - LAW : NO. 01-2767 ¥. .' : JURY TRIAL DEMANDED MICHAEL SCOTT : ANSWER AND NOW, comes the Defendant, Michael Scott by through his attorneys, Nealon & Gover, P.C. and in response to Plaintiffs' Complaint, avers the following: 1. After reasonable investigation, Defendant is without knowledge and information sufficient to form a belief as to the truth of the averments contained in this paragraph. Strict proof of same is demanded at trial. 2. After reasonable investigation, Defendant is without knowledge and information sufficient to form a belief as to the truth of the averments contained in this paragraph. Strict proof of same is demanded at trial. 3. Admitted in part and denied in part. It is admitted that Defendant Michael Scott resides in Pittsburgh, PA. It is denied that he resides at the stated address. By way of further answer, Defendant Michael Scott's address is P.O. Box 27044, Pittsburgh, PA 15235. 4. Admitted in part and denied in part. It is admitted that on or about the stated date. Plaintiff Henry Line was operating a motor vehicle in the southbound lanes of 1-81, Cumberland County, Pennsylvania. It is further admitted that Plaintiff Henry Line's vehicle came to a stop. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to remaining averments contained in this paragraph. Strict proof of same is demanded at trial. 5. Admitted in part and denied in part. It is admitted that Defendant Michael Scott was operating a motor vehicle traveling southbound on 1-81. It is further admitted that Defendant Michael Scott's vehicle came in contact with the rear of the vehicle being operated by Plaintiff Henry Line. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the remaining averments contained in this paragraph. Strict proof of same is demanded at trial. 6. Denied as stated pursuant to Pa.R.C.P. 1029(e). 7. Admitted. 8. The averments contained in this paragraph state only conclusions of law to which no responsive is required. To the extent that they may be deemed factual and requiring of a response, they are denied pursuant to Pa.R.C.P. 1029(e). COUNT I CONSTANCE BENTLEY LINE V. MICHAEL SCOTT 9.-12. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph. Strict proof of same is demanded at trial. WHEREFORE, Defendant, Michael Scott, respectfully requests that this Honorable Court enter judgment in his favor and against Plaintiff, Constance Bentley Line. COUNT II HENRY LINE V. MICHAEL SCOTT 13. Paragraphs 1-12 above are incorporated herein by referenced as if fully set forth at length. 14.-15. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truths of the averments contained in this paragraph. Strict proof of same is demanded at trial. WHEREFORE, Defendant, Michael Scott, respectfully requests that this Honorable Court enter judgment in his favor and against Plaintiff, Henry Line. Respectfully submitted, NEALON & GOVER, P.C. Christopher J. Knight, Esquire Attorney i.D. No. 80058 2411 North Front Street ~ ~_~_._~ Harrisburg, PA 17110 Date: (717) 232-9900 VERIFICATION I, Michael Scott, verify that the statements made in the foregoing Answer are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Michael Scott CERTIFICATE OF SERVICE AND NOW, this 2nd day of April, 2002, I hereby certi~ that I have served the foregoing Answer on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Marc G. Tarlow, Esquire Kain, Brown & Roberts, LLP 119 East Market Street York, PA 17401 Joseph B. Sobel, Esquire 212 North Third St., Suite 202 Cranberry Court Harrisburg, PA 17101-1505 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HENRY LINE and CONSTANCE BENTLEY LINE ' 191 Ridge Drive : CASE: 01 - 2767 Civil Carlisle. PA 17013 : Plaintiffs : · CIVIL ACTION. LAW MICHAEL SCOTT : JURY TRIAL DEMANDED 326 Dorothy Drive : Pittsburgh, PA 15235 : Defendant· : PRAEClPE TO REINSTATE THE WRIT OF SUMMONS TO THE PROTHONOTARY/CLERK OF SAID COURT: Please reinstate the Writ of Summons against the Defendant. MICHAEL SCOTT, in the above captioned case. 191 Ridge Drive Respectfully submitted. Carlisle, PA 17013 KAIN, BROWN & R.~ LLP Joseph B. Slobel, Esq. lid 17715J Attorney for Plaintiffs , Esq. liD 23474] 212 North Third Street Attorney for Plaintiffs Suite 202, Cranberry Court 119 East Market Street Harrisburg, PA 17101-1505 York, Pennsylvania 17401 Tele: (717) 843-8968 fax: [717] 843-5664 DATED: June 6, 2001 .Y~O.U..A._R_E NOTIFIED~I~T THE ABOV MED PLAINTIFF HAS COMMENCED AN ACTION PLA,NT, HAS COMMENCED ^N HENRY LINE AND i IN THE COURT OF COMMON PLEAS CONSTANCE BENTLEY LINE, OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs : CIVIL ACTION - LAW ¥, : : MICHAEL SCOTT, : Defendant : JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARAN¢I TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Michael Scott, with regard to the above-captioned matter. Respectfully submitted, NEALON & GOVER, P.C. nstopl~r J. Knight, Esquire Attorney I.D. No. 80058 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 CERTIFICATE OF SERVICF AND NOW, this 5th day of October, 2001, I hereby certify that I have served the foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Mare G. Tarlow, Esquire Kain, Brown & Roberts, LLP 119 East Market Street York, PA 17401 hristoph~r J. Knight, Esquire IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HENRY LINE and : CONSTANCE BENTLEY LINE : CASE: 01 - 2767 Civil 191 Ridge Drive : Carlisle, PA 17013 : Plaintiffs : CIVIL ACTION - LAW ,, V, ; : JURY TRIAL DEMANDED MICHAEL SCOTT : 326 Dorothy Drive : Pittsburgh, PA 15235 : Defendant. : AFFIDAVIT OF COMPLIANCE OF SERVICE OF PROCE$; I, Marie-Andrea Blouse, Paralegal, am an adult individual and hereby state as follows: 1. That in compliance with Judge Kevin A. Hess Order of August 2, 2001, I performed the following to effectuate service of process: A. Mailed the Wdt of Summons in the above action by 'Certified Mail - Return Receipt Requested' to defendant Michael Scott, c/o Patdcia Evans at his last known address of 326 Dorothy Drive, Pittsburgh, PA 15232. That Return Receipt Number 7099-3400-0007-0729-6751 was signed by Patdcia Evans on September 17, 2001 and copy of which is attached hereto and incorporated by reference as Exhibit A. B. Mailed the Writ of Summons in the above action by 'Certified Mail - Return Receipt Requested' to defendant's insurance carrier 'AllState' at the address of Market Claim Office, 6345 Flank Drive, Suite 1000, Harrisburg, PA 17112. That Return Receipt Number 7099 3400 0007 0729 6768 was signed by H. Via on September 13, 2001 and copy of which is attached hereto and incorporated by reference as Exhibit B. C. That advertisement in a paper of general circulation was done in a local newspaper of Allegheny County by the Pittsburgh Post-Gazette on September 25, 2001. A copy of the Proof of Publication from the Pittsburgh Post-Gazette is attached hereto and incorporated by referenced as Exhibit C. D. That advertisement in a legal paper of Allegheny County was done by the Pittsburgh Legal Journal on September 13, 2001. A copy of the Proof of Publication of the Pittsburgh Legal Joumal is attached hereto and incorporated by referenced as Exhibit D. 2. I make these statements based upon the best of my knowledge information and belief. Date: October 17. 2001 .(_X..L.L.'.'L ' ~/_ L.' ...~--~L[ ,~' ¢.-' ~.._C.. '. Marie-Andraa Blouse, Paralegal COMMONWEALTH OF PENNSYLVANIA : COUNTY OF YORK : On this 17~ day of October, 2001, before me a Notary Public, in and for said County and Commonwealth, personally appeared lilarie.Andrea Blouse, known to me or satisfactorily proven, to be the person whose name is subscribed to the within instrument and in due form of law acknowledge the within instrument to be his act and deed. IN WITNESS WHEREOF, I hereunto se,.~my hand and official seal the date and year aforesaid. Notary Public r' NOTARIAL SEAL My Commission Expires: ~ BRENDA K. TO~PER, N¢~ Puflt~ I ..My Comm,'a~m Ex,es March 4, 2002 · Complete Iten'l. 1.2..nd 3. AJso complete item 4 if ReetHctsd Dellv~y I~ deeimd. · P~tnt your n~ne and acldm~, on the reverse ee that we can return the e~d to you. C. S,~sture , ~//,~ a Attach ~ia can:l to the back of ~e mallpieee, or on the front If apace permits. X r...~ I:] Agent 1. A~c~A~Vemeclto~ D. I~delv~yadcrn~mnt~xnlteml? I-lye~ I~ F~,m I P~stage & Fees Paid I USPS [ Permit No. G-lO · Sender: Please print your name, address, and ZIP+4 in this box · No. Term. 19 Proof of Publication of. Notice in Pittsburgh Post-Gazette Under Act No. 587. Approved May 16, 1929, P.L. 1784, as last amended by Act No. 409 of September-29. 1951 Co.mmonw. ealth of Pennsylvania, County of Allegheny, ss: A. Blanchard , being dui sworn, d~"poses ~oZ.Sa~y,s.?~a~_e_P~_~bu~h~ P~ost-G~ette, a new.s.p.a.par, ofgeneral circulation ublished in the ~ii of Pi~bur uv ~uu ,~ou~monwea~m aroresmo w · · .P ty gh, and Sun-Teleffra,h aud The Piusbur~ ~z~es~u~s~-co~i.n~l..-9~-3~ b.,y__~e., merg,ng.o.f the_Pi.'ttsbu.rgh Post-Gazette !n.l 9.69. a~t~. e l~.ttshur~h Post-Gazette was established in I~7 ,, ,~ .... :__ _~.~ ... eg. rapn. w~as establish.ed · · . . . b~ u,~.m~u~ Gl me r~ttsourgn uazette estao- ,sneo m l~o aha the Pittsburgh Post~ estabhshed m 1842, since which date the said Pittsburgh Post-Gazette has been regularly issued in said County and that a copy of said printed notice or ublicafi · e~.ctl~.y as the same was rinted and u I' ' P . on ~s attached hereto · . P p b ~shed m the regular i ' · sam lqttsburgh Post-Gazette a news,,~,~ of .... ~ ~: ................ ecl nons and ~$sues of the 25, of Septemhar, 2O01. Affiant further deposes that he/she is an agent for the PG Publishing Company, a co ration and ubl, of~c Pi.usbu. rgh Post-Oazcue; that, as such ~oem affiant io ,~,,, ...... u--' ....... .fpo_ . p 'sber unaer Gain; mat affiant is not int~-~,-~ ~n ~],~'~-.,-."--- - o ,,,,,y ~umor~cu ~o verity mc rotc o,ng statement ........ ~,, ,- -- ~, ~.c matter of the aforesaid notice or ' allnga-ons ,n the foregoing state m to rim~ -~-~-- --., -,- .......... publ,cauon; and that all __ - menta ........ , p,a~ auu ~.~uar-.dczer O! pumlcatloll are true. Sworn to an~.subscribed before me r~s day of: September 27, 2001. STATEMENT OF ADVERTISING COSTS KAIN, BROWN & ROBERTS Andrea Blouse 119 East Market St. York PA 17401 To PG Publishing Company Total $ 381.25 Publisher's Receipt for Advertising Costs PG PUBLISHING COMPANY, publisher of the Pittsburgh Post-Gazette. a newsp-per of ge~esai circulation, hereby acknowledges ~*ceipt of the aforsaid advertising and publication costs and certifies that the same have be~a f~ly paid. Office IN3 Publishing Company, a Corporation. Publisher of 34 Boulevard of the Allies PITTSBURGH, PA 15222 Pittsburgh Post-Gazette, a Newspai~er of General Circulation Phone 412-263-1338 By. I hereby cenify that the foregoing mener of said notice, is the original Proof of Publication and receipt for the Advertising costs in the subjec~ Atamz. y for ......... ~,-= ~,~u ~uN~rANCE BENTLEY LTNE V MTCHAEL SCOTT Ci[VT[. ACTZON 01-E7&7 Proof of Publication of Notice' in Pittsburgh Legal Journal UNDER ACT OF IVlAy 16. 1929, P.L. i784, AS LAST AMENDED BY ACT 520. OF JULY 5, 1947 State of Pennsylvania }ss: County of Allegheny, Jennifer A. Jones, a designated agent of the Publisher of the PI~]~BUR~H LEGAL JOUP, NAL, being duly sworn, deposes and says that the Pl~rsl{uaoH LZGAL JOURNAL is a legal newspaper which is published by The Allegheny County Bar Association at the offices at 400 Koppers Building, Pittsburgh, Allegheny County. Pennsylvania; and that the PI'PI'$BURGH LEGAL JOURNAL was established as a weekly newspaper on April 23, 1853, and as a daily legal newspaper on January 4. 1926. since which date said daily newspaper has been regularly issued in said County, and that a copy of the printed notice or publication which is attached hereto is exactly the same as it was printed and published in the regular editions and issues of the said daily legal newspaper on the following dates, viz: 13t, h DAY OF SEPTEMBER ~'001 Affiant further deposes that she is an agent duly authorized by the publisher of said PFI'I'SBURGH LEGAL JOUI~,{AL, to veri- fy the foregoing statement under oath and also declares that interested in the subject matter of the aforesaid no- tice or publicatior ~,d that ali a]l~g~tions Jn the foregoing state%aenntJ:s~(ot time p]aee and character of pubhcabon are true o~o~rn to and subscrJhe~ ;;;;re me this ' Notice · .;..'~....z3 ........... 13%h day o~. SEPTEMBER : Statement of Adver tis~l-~,~,:..,~ ~soc~,on et No~r " KAZN BROWN & ROBERT~ LLP 11~ EAST MARKET ST. TO PI'I'rSBUROH LEGAL JOURNAL For Publishing the notice or advertisement attached hereto on the above stated dates ................. Probating sam~ ........................................................................... you Total ! OO uo sar ~v~ ~wvss ce c~ueaor 140&2~-]'N¥# O1070?! E~,E. SO Publisher's Receipt for Advertising Costs The l%'rsauEG. L~GAL JouRNAL hereby acknowledges receipt of the aforesaid adverti m~¢?m~6z ~ and certifies that the same have been fully paid. · PI*I~SSU~G H LEGAL LTR~ Fluslness Omce--400 l(oppers Building Jo Pittsburgh, PA. 15219 B _ Established 1853--Phone 261-62~5 Y ........................................... 0.6.T........1..2.011l. ~ .... [ he.by ce~ify that the foregone, P~oor or Pub~icatio. a.d ~celp4~{~~{~ the IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HENRY LINE and : CONSTANCE BENTLEY LINE · CASE: 01-2767- Civil 191 Ridge Drive Carlisle, PA 17013 Plaintiffs : CIVIL ACTION - LAW .. ¥. .. : JURY TRIAL DEMANDED MICHAEL SCOTT : 326 Dorothy Drive .. Pittsburgh, PA 15235 : Defendant. : .CERTIFICATE OF SERVICF AND NOW, this 17~ of October 2001, I, Marc G. Tarlow, Esquire, a member of the law firm of Kain, Brown & Roberts, LLP hereby certify that I have served a copy of the foregoing AFFIDAVIT OF COMPLIANCE OF SERVICE OF PROCESS, by depositing same in the United States mail, postage prepaid at York, Pennsylvania, addressed to as follows: MICHAEL SCOTT 326 Dorothy Drive Pittsburgh, PA 15235 Respectfully submitted, KAIN, ?OWN & ROBEJL~st LLP Marconi Tarlo~, Ssq. pi) 23474] 119 I~ast Market Street ~ork, Pennsylvania 17401 Tele: (717) 843-8968 fax: [717] 843*5664 Joseph B. Slobel, Esq. lid 17715] 212 ~orth Third Street Suite 202, Cranber~ Co-rt Han'isb-rg, PA 17101-1505 Attorneys for Plaintiffs CERTIFICATI~ PRKRI~UZSITK TO SKRV'ZCK OF A SUBPOENA O c-, --~, C- s., -'1 PURSUANT TO ROLK 4009.22 -o[% ~-_ '-- ~ .:: ..;.' IN THE HATTER OF: COURT OF C~..N iL--J~As- CONSTANCE BENTLEYLINE TERH, ~ .-~ ,...~ -VS- CASE NO: 01-2767 SCOTT AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 HCS on behalf of C~ltlSTOPHER J. ~NICHT~ ESqU?e~ 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 t~enty days prlor to the date on ~lich the subpoena is sought to be (2) A copy of the not~ce of ~ntent, 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 not,ce of intent to serve the subpoena. DATE: 07/17/2002 ~~~ , Esqu~FE Attorney for DEFENDANT DEll-346246 98300--L01 COIqI~ONT~-:~T -TH OF PENNSYLV~NIA COUNTY OF CU-IqBERLA_qD TN 'ft~ HATTER OF: CO~B.T OF CG~10# PI,KAS CONSTANCK BHIFf-I, KYL INK TERM, -VS- ~-A-qK NO** 01-2767 SCOTT NOTICE OF INTENT TO SERVE A SUBPOEHA TO PRODUCE ~S · .E'fl.LHt~..~ FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed liet of locations ] TO: JOSKI'H B. SOBKL, ESq. H&RC C. T. Am-~V, ES(~UIRK MCS en behalf of f~J~TSTOFn]~a J. I~BLC, HT~, ESQUIRE :lo. tends to serve a 8ubpoella identical to the one ,h-t is attached to this notice. Yen have tonnt! (20) days from the date listed below /n which to file of record ~nd oe..v upon the undersigned an objection to the subpoena. If ~he twenty day notice period is waived or if no objection is made, then the subpoena may be served. ~mplete copies of say reproduced records may be o~dered at your expense by ccmplet~nS the attached cremes! card and £eture~nS sm~ to M~S or by centact~nS our local MCS office. DATE: 0612712002 I,ES on behalf of f~n~TSTOPmm j. RMi~HTt ESQUIRE Attorney for ~ ~: C~Tq~F--- J. ~0 E~ue- 01-427 Any questions resardln$ thio matter, contact TH~MCS GROUP ILK:. 1001 ~ S~uJ~T J8oo PHILAI~LPHT_A, PA 19103 (215) 240-0900 DE02-191461 983OO--CO2 >>> [,OCAT~Oll LTST RKCORDS REQUESTED LOCAT~Oli I~EDZCAL RECORDS RODIIKY HOUGH, ~iSORANCK STATE FAI~f AUTO INS. CO. 14KDICAL RKCORDS MATTIIKW #ICASTRO, PT I~DIGAJ. RECORDS DR. DAII'r~. J. MCCANli, D.C. I~DICAI. RECORDS BRIF. K D. KI, ASK~N, DO l~DI~d. RECORDS JOHN SPAYD I~DTCAL RECORDS TODD SAhus,-S, M.D. MKD~CA~ RECORDS WALIIUT BOTTOM RADTO~.OGY HKD'rCAL RKCOUnS ACTIVATOR I~DTCAL RKCORDS MAOIIKTTC ~MAO~iO CKIITKR i)K02-191461 08:300-(::02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CONSTANCE BENTLgYLINE : VS : : File N~ 01-2767 SCOTT : : SUBPOENA TO PRODUCE DOCUMENTS OR THING,~ FOR DISCOVERY PURSUANT TO RULE 4009 ~9 TO: CUSTODIAlq OF RECORDS FOR: RODNEY K. HOUGH, H.D. iN~,* of P~n or Entlly) Within twenty (20) days after service of thil luhpoeK1, you are ordered by the court to produce the following documents or thlflp: g~ at HCS GROUP INC., 1601 MARKET ST., #800, ~'ItLLA.,PA 19103 -- You may deliver or mil legible copies of ti,~deeumeflts or produce things requested by this subimena, together with the certificate of compliance, to the pafly makinS this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparin$ the copies or producinS the thinp sought. If you fail to produce the documents or thinp required by this subpoena, within twenty (20) days ag'ret its service, the jxmy servinS this subpoena may seek a court order compellins you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST O1: THE FOLLOWING PERSON: NAME: CBRISTOPEER E/qIGli'r. ESS. ADDRESS.- 2411 WORTli FROI~ ST. HARRTSBURG. PA 171].0 TELEPHONE: 215-246-0900 SUPREME COURT ID ~ ATTORNEY ~OR: DEFE'RDANT Seal of the Court ..~ (Eft. ?/~ ' EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: RODNEY HOUGH, M.D. 49 BROOKWOOD AVENUE CARLISLE, PA 17013 RE: 98300 CONSTANCE BENTLEYLINE Any and all records, correspondence, files and memorandums, handwritten notes, bi~ng and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the pruent. Subject: CONSTANCE BENTLEYLINE 191 RIDGE DR., CA~I.ISLE, PA 17017 Date of Birth: 12-17-1937 SU~0-$82628 98:300--LO:L CL~TI FICATE PE.KR.KQUISI'TK TO SERVICE OF A SUBPOENA PURSUANT TO RULE &009.22 IN THE MATTER OF: COURT OF COlOrON PLEAS CONSTANCE BENTLEYL 1'NE TERH, -VS- CASE HO: 01-2767 SCOTT As a prerequislte to service of a subpoena for documents and things pursuant to Rule 4009.22 HCS on behalf of CHRISTOPHER J. KNIGHT~ ESQUIRE 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 i8 sought to be served, (2) A copy of the notice of intent, includinS 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. HCS on behalf of DATE: 07~17/2002 CHRISTOPHER J. KNIGHT~ ESQUIRE Attorney for DEFENDANT DEll-3&6247 983 0 O--L02 ¢OI~II~Oh--wP_~A~.TH OF PENNSY'[.VANIA COT/NTY OF CTJYlBER/.AAqD TH THK MATTER OP.' COURT OF CGOOION PLEAS CO#STABCK BKIFfLKYLTBK TERM, -VS- CASK B0:01-2767 NOTICE OF Tnan~S e~K DTSC~vsAz ku~UmlJT TO m~'m.. 4009.21 [ loose: ,tee enclosed list of locatiouo ] MCS ou behalf of mmT=~uBBI J. nr~__~_t COz CIlIXSTOPB~I J. IO~IT, BSqUT_~. 01-42~ Any questions resardln8 thin rotter, c°ntact TOE ES ~ ~lC. 1601 MB~J~T STREET ~800 PH]].,AI)~L-UHTM, PA 19103 (215) Z/~6-0900 ~02-191461 98300--(::02 ~:*~ LOCATXOM LXST ~,~ PA~K.* l RECORDS REQUESTED LOC. A?XOli t~DXGAL RECORDS RODI~ HOUt~II. lq.D. XMS~,ANGK STARK FARM AUTO XMS. GO. I'~DXCAL R~RDS HATTHKM MXCASTRO, PT I~DXC*AL RKCORDS I~DXGAL RECORDS BRUCE D* ELASKT. M, DO I~DXCAL RKCORDS JOtul SP&YI) I~ICAL R~CORDS TODD SAM~S, H.D. )~DXGAL RECORDS MALMUT BOTTOM uAnXOLOGY I~DICAL RKGORDS AGTXYATOi I~'THODS, XMC. )~DXCAL RKCORDS MAGMETXC IH&GXII~ C~MTKR !~02-191461 98300--(::02 COMMONWEALTH OF P£NNSYLVANI.~ COUNTY OF CUMBERLAND CONSTANCE BENTLEYLINE : _. VS : : File No. 01-2767 SCOTT : : : SUBPOENA TO PRODUCE DOCUMENTS OR THING~ FOR DISCOVERY PURSUANT TO RULE 4009. TO: . CUSTODTAN OF RECOP, DS FOR: STATE FAFL.[ TNSImANCE (Name ~ tl~:tn~n., t~lv'ntY (20) d'Y' aft' sewic' °ir thb 'u bpaena..Sj~_ad~[ffdl~_~b~ the court to prod~c, the foil.n, dacuments. it HCS GROUP INC., 1601 NARIC. ET ST., ~L800, l'~t,{~,. ,PA 19103 -- IAddmq You may deliver or mail leBible copies of ~ ~ ~uce thln~ ~u~ by this subp~ t~her with the ce~ificite o( compliance, ~o the ~ ~nS t~; r~ ~ the Idd~ li~d I~e. You h, ~ ri~t m m~ in advice, the ~i~bie cest of p~nS Iht coati ~ ~l~ t~ ~ mu~t. If you ~ail to ~duce t~ d~um~ or thin~ ~ui~ ~ this ~ub~ within ~en~ (~) ~ ~er its N~Jce, the ~ se~EnS this ;ub~ my s~k i = ord~ ~m~i~nS ~ to rumply with it. THIS SUBPOENA WAS ISSUED AT THE REQL~ST OF THE FOLLOWING PERSON: NAME: CI~'I'STOPll~. EliXCHT. ESO. ADDRESS: 26,11 MOP, TH FROI~iT ST. HARRISBURG. PA 17110 TELEPHONE: 215-26,6-0900 SUPREME COURT ID ~ A'I'I'ORNEY FOR: DEFENDANT DATE: ~ ~ Se~l of the Cmut EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: STATE FARM AUTO INS. CO. 1690 KENNETH RD. P.O. BOX 14007 YORK, PA 17404 RE: 98300 CONSTANCE BENTLEYLINE Any and all claims files. Dates Requested: up to find including the pruent. Subject: CONSTANCE BENTLEYI.INE 191 RIDGE DR., CARLISLE, PA 17017 Date of Birth: 12-17-1937 Date of Loss: 06/0S/0099 SU10-382630 98'~- 0 O--L02 CERTIFICATE PF~REQU~SXTE TO SERVICK OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE HATTER OF: COURT OF CO~ON PLEAS CONSTANCE BENTLEYLINE TE?~I, -VS- CASE NO~ 01-2767 SCOTT As a prerequisite to service of a subpoena for documents and thinss pursuant to Rule 4009.22 HC$ on behalf of CHRISTOPHER J. KNXGHTt ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed o~ delivered to each party at least twenty days prior to the date on ~h~ch the subpoena ~s sought to be (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has bean received, and · (4) The subpoena which will be served ~s ~dentical to the subpoena which is attached to the notice of ~ntent to serve the subpoena. HCS on behalf of DATE: 071~712002 CHRISTOPHER J. KNIGHT, ESqUiRE Attorney for DEFENDANT DEl1-346248 98300--L03 CObD4Oh~dF~A~-TH OF PENNsI'LVA/qIA COUNTY OF CU~4~Ei~r~d~ND TN THK M~TTKR OF.' GO, BT OF GGI~Om PLKAS CONSTABGE BENTLEYLINK TSKd, -va- GASK BO.* 01-2767 BOTXCB OF XBTKBT ~O SERVE A SUB.aqUA TO pur~r~k~_B ~ · mAmaS L"~JK DX~H~uvnK! ~"ulwaupflIT TO um.m 4009.21 [ mote.* see enclosed list of locetio-s ] TO.* JOSEPH B. SOUtq., ESq. ~ C. TALLOW, M~S on behalf of CHIISTOIq~R J. 131T~HT~ KS~TT~ et lnteuda to oervu a eubpoem identical to ~h. cue that 1o attnchid to ~h~l not~ce. You have twuty (20) date from the date l~Jted below in which to file of ncord and serve U/Nm tim undersigned an objection to the mtbpomm. X£ the L~nt? day notice per~0d uived or Af no objection lo mmde, ~ the oubpomm my be served. Complete copie, of n7 reproduced recordo my be ordered at your expense by the attached counsel card and returpiR-_ sm to lES or by coutictJnS our local liDS office. DATE.* 06/27/2002 !~8 an belmlf of &t. toL'ney for ~ CC.* ~nsZSTOL"~II J. I]r~lT. ESqu.i.l~- 01-427 Any queotXon, regarding ~hi, mstter, coutact ~M~S ~ROUP lilt. 1601MaB~T ST~WT ~HXLM~IJ~ZAo PA 19103 (215) 2~6-0900 Dg02-191461 98300--CO2 >>> LOCAT'LOII LZST <<< RECORDS REq~KSTKD IOC&T/OH M I~DIGAL RKCORDS RDI~Y ROIl08, M.D. TNSURAHCE STATE FABll AUTO IHS. I~DIGAL RKCORDS N&TTH~ IFICASTRO, PT )~DICAL RKCORDS DR. DABIEL J. M~.,AJIII, D.C. I~DICAL RECORDS BBIF. K D. KLASK/ll, DO I~DICAL RKCORD6 ,IOHB SPAYD I~D*rCAL RKCORDS ~ SAMDKLS, N.D. )~D'rCAL RECORDS ACTIVATOR I~'rHODS. INC. !~02-1914,61 9 8 3 0 0 -- C 0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CONSTANCE BENTLEYLINE : : VS : : File No. 01-2767 GCOTT : ; _. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE ,1009. ?? TO:. CUSTODIAN OF RECORDG FOR: I. IATTH~ NICAGTRO, PT (Name o! P~,~ or ~#ty) 'Ill, tnb; ~venty (20) days a/tor es~ice of this subp4x~, you are ordered by the court to pcod~co the followlns documents at MOS GROUP INC., 1601 NARKI~-T ST., #800, PHILA.,PA 19103 (Adding) You may deliver or mail lestbte copies of th~ thK. umLmts OC produce thinss requested by this subpoena, tosether with the certificate of compliance, to the party makinG this request at the address listed above. You have the risht to ink, in advance, the reasonable cost of prepm'JnG the copies or producin~ the thinss sousht. If you fail to produce the documents or thinp required by this subpoena, within twenty (~0) days a~er its SorvJce, the pony servinG this subpoena may seek a court order comp~llinG you to comply with it. THIS SUBPOENA WAS lSSbl:u AT'~IE R£QU~ST OF'I~E FOLLOWING PERSON: NAME: CHRISTOPHER KNIGHT. ESO. ADDRESS: 2411 NORTR FRONT ST. HARRISBURG. PA 17110 TELEPHONE: 215-246-0900 SUPREMe: COURT ID ~. ATtORNeY FOR: DEFL~iDANT Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MA~I~HEW NICASTRO, PT 205 N. HANOVER STREET. CARLISLE, PA 17013 RE: 98300 CONSTANCE BENTLEYLINE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: CONSTANCE BENTLEYLINE 191 RIDGE DR., CARLISLE, PA 17017 Date of Birth: 12-17-19~t7 su~.0-382632 9 8 3 0 0 -- Y...O '~ CKRTI'PICATE PRKRK(~S?TK TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE HATTER OF: COURT OF C0~40N PLEAS CONSTANCE BENTLEYLINE TERN, -VS- CASE NO: 01-2767 SCOTT As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 HCS on behalf of CHRISTOPHER J. KNIGHT, EsquIRE 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 (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. 14CS on behalf of DATE= 07/17/2002 CHRISTOPHER J. KN~GHT~ ESQUIRE AttoL-ney for DEFENDANT DEll-346249 983OO--v-O4 COYlYlOI~-~.-.;~- -TH OF PENNSYLVANIA COTJNTY OF CTJI~fBER/_.AND MATTER 0P= COURT OF CGiSM)N PLK&S CO#STANGK BKNTLKYLTNK TKBM, -VS- CASH NO: 01-2767 NOTICE OF XNTBNT TO SBkVK A SUBPflmeA TO puo_n~u___u __n~wumu~s aun · ~'nun~ F~K DXSC3Jvssz I'U~UAIlT TO UlJTu_..-- 4009.21 [ Note: see enclosed Xlst of locations ] TOz JOSIlrg B. SOBBL, ESQ. HAIG C. TAILOV, eSqu~-e MCS on behalf of CHRISTOPHER J. KII~HTB EsquIRE ~ntend8 to serve · .ubpoe~ Ldent~cLl to the one that ~o atrJched to ~h~q notice. YOU have twenty (20) daye frem the date lJJted belOW In uhich to file of record and gem upon the undergl~ned an obJect~ou to the eubpoeua. Z£ the tweut]F day not~ce period ~o ea~ved or if no objection il made, then the subpoena my be served. C~mplete cop~es of any reproduced records may be ordered at your expense by cempletlnS the attached counsel card and returnin_e Il to MCS or by coutact~uS our loca! eCS office. MTN: 06~2712002 in! qulltXOUl relardV-2 ~hXI Bitter, contact THE H CS ~i00P IIC. 1601~B,~,.~T STREET rS00 PHILADILPHIA, PA ~0~03 (2~$) 246-0900 DKO2-191461 98'~00--C02 >>> LOCATION LIST <<~ PACK: 1 RKC:ORDS IW:qUKST~J LOC, ATTON I~DXCAL uECORDS RODNEY HOUGH, H.D. T#SURANGK STATK FARM AUTO IHS. CO. ~DXCAL RECORDS HATTHEV #IGASTRO, PT I~DXGAL RKCORDS DR. DA~ct. J. M~,GAIIH, D.C. I~DXCAL RECORDS BRUCE D. KLJ, SrTll, DO MKDIGAL RKC:ORDS JOHll SPAI'D I~DXCAL RKCORDS TODD SAJffJKLS, M.D. ~XGAL RKCORDS ACTIVATOR ~THODO, XII~. I~DXGAL RKCORDS H&GHETXC IM&GXIE~ CKBTKB. 1~02-191461 98300--C02 COMMONW'HALTH OF PENNSYLVANI.~ COUNTY OF CUMBERLAND CONSTANCE BENTLEYLINE : : VS : : File No. 01-2767 SCOTT : SUBPOENA TO PRODUCE DOCUMENTS OR THINC. C FOR DISCOVERY PURSUANT TO RULE 4009,?? TO: CUSTODTAN OF RECORDS FOR: DANTEL NCCAh'N, DC Within twenty (20) daYS a~ter K'rvico of thi~ eubpaena* you ire Mdered h,, th~ ...... :.__ ........ thin~: ~ - - - -, -,,-., ,~, F,wusmc~ Tn~ ~oilow~nm aorUmmlts a~ at MC-q GROUP [NC., 1601 t. Lq.K~,C't1 ST., #800, t'ttJ. L,A.,PA 19103 -- iAddr~ml You may deliver or mail lesible copifl c~ th~dm~ments or produce thinp reqUL~ted by this subpoena* tosether with the certificate of compliance, to the pat~y makinm this request at the addrL,~ listed above. You have the risht to sosk, in advance, the reasonable cost of preparln~ the copJ~ or producin~ tho Ihin~s sought. If you fail to produce the documents or thinSs required by this subpoena, within twenty (20) days after its service, the perry servinS this subpoena may ~eek a cotut order compellin8 you to comply with it. THIS SUBPOENA WAS ISSUL:D AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CHRiSTOPHeR l~XOilT. ESO. ADDRESS: 2411 NORTH FRONT ST. HAR~SBURG. PA 17110 TELEPHONE: 215-246-0900 SUPREME COURT ID it: ATTORNEY FOR: DEFENDANT BY2q~II/COIJRT: '~ ~. /'~ · _ S~al of the Cou~ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. DANIEL J. MCCANN, D.C. $ BROOKWOOD AVENUE SUITE-3 CARLISLE, PA 17013 RE: 98300 CONSTANCE BENTLEYLINE Any and all records, correspondence, files and memorandums, handwritten notes, billing and paymem records, relating to any examination, consultation, care or treatment. Dates Requested: up to and indudinI the pr~ent. Subject: CONSTANCE BENTLEYIANE 191 RIDGE DR., CARLISLE, PA 17017 Date of Birth: 12-17-1937 $u1.0-382654 9 8 ~, 0 O-- L,O ~- CERTXFXCATE PRKRKqu'r_SI'TE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COn.iON PLEAS CONSTANCE BENTLEYLINE TERH. -VS- CASE NO: 01-2767 SCOTT As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CIfRISTOPHEK J. KNIGHT, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was maZled or deXlvered 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, includin8 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 not~ce of intent to serve the subpoena. HCS on behalf of DATE: 07/17/2002 CHRISTOPHER J. KNIGHTr ESQUIRE Attorney for DEFENDANT DEll-3462§0 98300--L05 COI~fl~IONT~--'Ar TH OF PENNsYi. V~dq-rA COT_T~TY OF CTJ-Iv~BE1~j_.~ND -~u~ M&TTKR 0If: GOURT Oil COlil)B PLEAS COHSTAW:K BKIrYLKYLTNK TERM, -VS- CASK NO: 01-2767 SCOTT IIOTICB OF IIiTB]fP TO -_~ _m/R A SIJBI~uqf~, TO pu~_~ ~ Tn~nua ~m DI~3Jvm(x ~u~,-~&apf TO nmb 4009.21 [ gotez see enclosed list of locationo ] TOz JOSEPH B. SOBKL, gSq. MiRC C. TALLOW, KSqUIBK )ES on behalf of CHIISTOPHB~ J. I]F~HTt gS~nUu ~utendl to serve a oubpoona identical to the one that is attached to thio notice. You have LleUt! (20) dele fz~m the date listed below An uh~ch to file of recozd and serve upon the underuipd no objection to the subpomm. If the bmutT day notice period is n~ved or if no obJectien is made, then the eubpoem may be served. Complete copies of any reproduced recordo my be ordered at Tour ama by conplet~nS the attechad counoel card and returning sm to aCS or by centectln8 our local ~CS office. DATBf 06/27;2002 CHR~STOPHBR J. 1Or~RTt BSq~TU, Attorney for DKLf~ABT COz ~ilL~STOL~BR J. I]I~T, KSqUT]K- 01-427 An7 questions resardtn~ th~LimatteE° contact ~MG~ilM~ ~]IC. 1601M&EIRT STB~T ~800 ~~, PA 19103 (~S) 2~-0900 ~02-191461 98300--C02 ))) LOGATIOII LTST ~c~ RECORDS REqUESTer, LOCATION MEDICAL RECORDS ROI~IKY HOUGH, ll.D. XMSURAHCK STATE FAm~ AUTO IllS. CO. I~DXCAL RECORDS DR. DAlrrn- J. II:CAIBI, D.C. I~DXCAL RKCORDS BRUC~ D. KLASK/]I, DO I~DXCAL RKCORDS JOHIJ SPAYD I~DICAL R.t*CORDS TODD SAHIJELS, H. D · I~DTCAL RKCORDS WALIIUT BOTTGM UAn~OLOGY )~DTGAL RKCORDS ACTIVATOR I~THODS, B~02-191461 08'W00--C02 COMMON~q~ALTH OF P£NNSYLVANI.q. COUNTY OF CUMBERLAND CONSTANC~ BENTL~.YLINE : VS : : File No. 01-2767 SCOTT : SUBPOL~qA TO PRODUCE DOCUMENTS OR THING~ FOR DISCO¥-~Ry PURSUANT TO RULE 4009 ~: TO:. __CUSTODXAN OF RECORDS FOR: BRUCE D. KLASKIN, DO (Name of Pwmm of ~tnhl~ twenty (20) days a~tor Mrvice.~_~ this subpoena, you are ordered by the court to produce the followtnS doeuments of at X~CS GROUP THC., 160]. HAmUST ST., ~800, PHI'LA.,I'A 19103 -- You ..may de?er or_mail lesible cople~ ~ tkedaeuments or produce thinp requested by this subuflona, ~her with t certiricato or compliance, to the pa,~, mddn-, this r ....... '- ....... r .... o*' .J ........... u';. n ~m ar me aaarese ill~t~l above. You have the rifht to seek, in ..v~nce, me reaconaole cost of prepann$ the copies or pmducin~ tim thinp If you fail to produce the ducuments or thinp required by this subpnana, within twenty (20) days after its service, the IMrty servins this subpoena may seek a court order compellins you to comply with it. THIS SUBPOL:NA WAS ISSUI~L; AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CImTSTOPHER KNTGHT. SSO. ADDRESS: 2&Il NORTH FRONT ST. ~Ull~. PA 17~,J.0 TELEPHONF. 215-246-0900 SUPREMI~ COURT ID ~. ATrORNL~Y FOI~ DEFENDANT P~ihonoWffj,j~m~, Civil Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: BRUCE D. KLASKIN, DO 795 CHERRY TREE CT. STE 1 HANOVER, PA 17331 RE: 98300 CONSTANCE BENTLEYLINE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the pruent. SubJect: CONSTANCE BENTLEYLINE 191 RIDGE DR., CARLISLE, PA 17017 Date of Birth: 12-17-1937 SU10-382636 98300--'r-0..~, CKRTIFICATK PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4,009.22 IN THE HATTER OF: COU~T OF CO.ION PLEAS CONSTANCE BENTLEYLINE TERM, -VS- CASE NO: 01-2767 SCOTT As a prerequisite to service of a subpoena for documents and thlnss pursuant to Rule 4009.22 HCS on behalf of CHRISTOPHER J. KNIGHT, ESqUI~ 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 i8 sousht to be served, (2) A copy of the notice of intent, includin$ the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and The subpoena which will be served i8 identical to the subpoena which is attached to the notice of intent to serve the subpoena. HCS on behalf of DATE: 07/17/2002 CHRISTOPHER J. KNIGHT~ ESQUIRE Attorney for DEFENDANT DEll-346251 98300--L06 CO~OITwT~-TH OF PENNsI'LVANIA COUNTY OF CU-~aEI~L~I~D THE MATTER OF** GOURT OF ~ PLKAS GOIISTAIIGZ BKNTLKYLINK ~msPf, -VS- GASK NOz 01-2767 NOTICE GY IIITBIIT TO SBRVB A SUB~uq TO pu~ _n~L~__ ~ sun ~d~sa~ AK DI~vnA~ Fu~q]T TO un~.u_ 4009.2] [ II·ts, see e~clored IAst of Xecations ] TOt JOSEPH B. SOBBL, ESq. )ES on belmlf of CHRTSTOFB~I J. IIF~HTt ES(~Fr~ Lutends to servu · subpoena AdentAc·l ~o the one that ls attached to this notice. You havu L~auty (20) days fFem tho date listed below In ~d~lch to fA1· of record and serve upeu the undersipd m obJectiou to the subpoena. If tim twut! day notice prlod As oulved or if no objection is tomb, then the s~qmona my be served. Couplet· copies of any reproS--rd records my be ordered at yo~ ezpanoe by cmsplettn8 the attached counsel card nd returnlns sm to LES or by conUctln8 our local ES offAc·. DATKz 06127;2002 lES on belmlf of · --~rsTOPuul J. Ilr~ffT~ BSq~RE Attorney for ~ OCz CHRTSTOPH~I J. ~, ~- 01-427 Any questlous res~rdln8 ~h~gsmtter. contact THE LES ~ IBC. 1601M61]~T STI~T ~800 PH//~I~LPH~A, PA 19103 (215) 246-0900 !~02-191461 98300--(::02 RECORDS REQUESTED LOCATTON I~I)XCAL RKCORDS RODBi*Y HOUGH, M.D. INSURANCK STATE FABJf AUTO /liS. CO. I~DICAL R~CORDS DR. ~ J. HgCaJDI, D.C. ~DICAL RECORDS BRUCE D. I3,ASI/ll, DO HEDICAL RECORDS JOIDI SPAYD ~I)IGAL RKCORDS TOI~) SAkb~,S, M.D. J~D]'CAL RECORDS UM-uUT BOTTOM RADIOLOGY )~DTCAL RKCORDS ACTIVATOR I~THODS, I~DXCAL RECOUnS I~XC XI, M, GXII~ 1~02-191461 98300--C02 COMMONWEALTH OF P£NNSYLVANI.~ COUNTY OF CUMBERLAND CONSTANCE BENTLEYLINE : : V$ : : File No. 01-2767 SCOTT : : ., SUBPOENA TO PRODUCE DOCUM£NTS OR THING~ FOR DISCOVERY PURSUANT TO RUL£ 4009 TO: ._=__.CUSTODTAN OF RECORDS FOR: JOl~l SPAYD (Name ~ Pemm or Enffty) Within t~.nty (20) days ~ service of this subpom&, yin, arm ordered ' thin~: ~ ,-- by th eoun M Imxl,~ th following d.~,,~ or at MCS GRO~rP INC., 1601 I~.~XET 5~.--'~--~00. PItTLA.~ You rosy deliver or mail legible copI, of th~ M.ura~ or Inoduce thinp requHt~l by this subpoena, tog~l~r with the ce~ificste of compliance, to the parly m~kJng this requ~t at tho sdd~..~ listed shove. You hav~ th~ right to ~.~k, in edvsnce, the reasonable ¢o.t of prelm, ing th~ eople~ or producing th~ thinp mght. if you fail to produce the do~umenll or thi~ ~'quired by this subl~na, within Iwenty (20) day~ Mtor its Mrvi~, the serving this subpoena may ~'~k s cm~rl ord,r ~ompMli~l~ you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CHRISTOPHER 10~. KS~, ADDRESS: 2411 NORTH FRONT ST. HANR~SRDRG. p~, 17119 TELJ:PHON~ 215-2~6-0900 SUPRJ:ME COURT ID ~ A'I'rORNEY FOR~ DEFENDANT BY/TME COURT: Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOHN SPAYD 205 N. HANOVER STREET CARLISLE, PA 17013 RE: 98300 CONSTANCE BENTLEYLINE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. eet. CONSTANCE BENTLEYLINE 191 RIDGE DR., CARLISLE, PA 17017 Date of Birth: 12-17-1937 SU10-382638 ~8~00--~-,0(5 CERTIFICATK PRKRKQUISITK TO SKRVICK OF A SUBPOENA PURSUANT TO RULK 6,009.22 IN THE HATTER OF: COURT OF COItiON PLEAS CONSTANCE BENTLKYI, INK TERM. -VS- CASK NO= 01-2767 SCOTT As a prerequisite to service of a subpoena for documents and thinss pursuant to Rule 4009.22 HCS on behalf of CHRISTOPHER J. KNIGHT, ESQUIRE 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 h3tent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which rill be served ks identical to the subpoena vhich is attached to the notice of h3tent to serve the subpoena. MCS on behalf of DATE~ 07~17/2002 CHRISTOPHER J. KNIGHTr ESqUiRE Attorney for DEFENDANT DEll-3462§2 98300--Y-07 COIdI~fOI~-~-TH OF PENNSY1.V~-FA CO~JNTY OF C~JI~BEI~ ~-4~I~D XM TIIK IitTTKR OFz COURT Of GGIOIOII PLEAS COIISTAIICK BEBTIAll~ T~ilM, -VS- CASK IlOs 01-2767 HOTT~ OF TU~EIlT TO AEuVB A SUBI~u~. TO p _u~_,E~_.~m [-i-_'~ .... ~ · m~ ~R DI~vnz p~...~ ~ ~] 4009.21 [ ~te: oee ~1o8~ l~.t of l~at~o ] m ~lf of ~S~ J. ~t ~ h~ to 8e~ a o~ l~tlcal to ~ u ~t As aC~ to th~q ~e. Y~ ~ ~y (20) ~yo f~ ~ ~te lbt~ bl~ h ~ to file of ~o~ ~ n~ ~ e~bo of ny np~ ~o~s my b o~ a~ ~ ~e ~ att~ c~sel ca~ ~ ~t~Jn~ Se to ~ or ~ cmt~t{n~ ~ l~al office. ~z 06;27;2002 Any quemt~onm relardlnS thlm matter, caBtact ~ )ES ~ IBC. 1601 ~ STi~ ~800 PHXLAI~Ii. A, PA 19103 (210) 246-09OO 12g02-191461 98300--C02 nm02-191461 (~8':1. 00_C02 .COMMONWEALTH OF PENNSYLVANI.L COUNTY OF CUMBERLAND CONSTANCE BENTLEYL~NE : : VS : : lqle No. 01-2767 SCOTT : : : SUBPOENA TO PRODUCE DOCUMENTS OR THINe,' FOR DISCOVERY PURSUANT TO RULE 4009. TO:. CU_.____~STODIAN OF RECORDS FOE: TODD SAMUELS, M.D. at ~fCS GROUP INC., 1601 HARKET ST., ~800, PHTLA.,PA 19103 --- Yo.~...ma~ d~tver or. mi! le~ble ~opi~ o~ ~'m~,t~ ~ ~=e t~,~ ~'~um~ ~. t~.~- --'- cemncafe o~ compliance, to the na~v makin- tkl- .--.--. -~ .L-- --.,. ~; --? -- '; "-- ''"1n'~n~, sub~ner will1 the advance, the reasonable ¢~ o~r mnaelnw the co'a- -- --~ , ..... u have the rEsht to mk. in ~--,------u r.~- -- v,~,ucm~ ma tmnss soushL o -- r~,,~ m~y ~'~K i L~mT orglc Compmual you Io COntply w~th iL THIS SUBPOENA WAS ISSUI~u AT THE REQUEST OF THE FOLLOWING PEILSON: NAME: C~1'STOP~ KNIGRT. ADDKESS: 2&Il NORTH F~ONT ST. [IAR~URG. PA 17~0 T~L£PHONF.: 215-246-0900 SUPR£MI~ COURT ID A'rrORNEY FOR: DEFENDANT S~II o~ the Cou~t EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: TODD SAMUELS, M.D. 897 POPLAR CHURCH RD. CAMP HILL, PA 17011 RE: 98300 CONSTANCE BENTLEYLINE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examiuation, consultation, care or treatment. sDun_t~s' .,R~q,. ,uested: up to und including the present. bject . CONSTANCE BENTLEYLINE 191 RIDGE DR., CARLISLE, PA 17017 Dute of Birth: 12-1%1937 SU~0-382640 98500--L07 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOKliA t-uu-quANT TO RHLK 4009.22 IN THE HATTER OF: COURT OF CO~ION PLEAS CONSTANCE BENTLEYLINE TERH, -VS- CASH NO: 01-2767 SCOTT As · prerequisite to service of a subpoena for documents and thinss pursuant to Rule 4009.22 liCS on behalf of CHRISTOPHER J. ENIGHT, ESqUIU~ certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was amiled or delivered to each party at least treaty d~ys prior to the date on ~hich the subpoena is sousht to be served, (2) A copy of the notice of intent, includinS the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena ~htch rill be served is identical to the subpoena ~lch is attached to the notice of intent to serve the subpoena. HCS on behalf of DATE~ 07/17/2002 CHRISTOPHER J. KNIGHT~ ESQUIRE Attorney for DEFENDANT DE11-146253 98500--L08 CO~ON~-A~ -TH OF PE~-~SI'LVANIA COUNTY OF CU~UE~ND THK I~ATTKR OF: COUI[T Of CGO~OH PLKAS C0#STAIICK BKBTI~YLTNK TKHM, -VS- CASK IS)** 01-2767 SCOTT IJT-Slf~ ~O SERVE A SUBIUUi TO p_~_u~r~F_ u ~ Aun FOR DIS~3Jvn~z p-U-~mlpp TO_u'na- cl..fi.rig.21 TOz JOSI~ B. SOBKL, ESq. NAIC C. TAILOV. ZSqU~ acs au behalf of ~mL[STO~HBR J. I]F~err, Iaqfrz~j Intends to qcve a nbpoena identical to tim one ~ht is attached to ~h~s notice. You have twnty (Z0) days from ,-k. date lbted blow h uhich to f~la of record and serve uiHm undere~and an objection to the subpoena. Tf the toeuty day notice period uuived or if no obJec~ou h mede. tJmu the ,ublHmua may be -erred. Compbta copies of any reproduced records may be ordered at your azpen# by c"epletln8 the attached counael card and retuzn~-_ sm to MCS or by cmtact~ne~ our local aCS office. DATKz 06;27;2002 I~S au behalf of C~STO~R J. I]IRHTs ESCpJ]~B &ttornmy for ~ Ss ~S~ J. I~, ~- 01-427 Any qultiml relardl]q this matter, coutact ~I~S~0UP ]]lC. 1601)MIKIT STREET P800 PR1~AI)EL~HT~, P& 19103 (2X$) 246-0000 12g02-191461 98300--C02 R~GORDS REqUESTBI) ~'IISURANGE ROi~IEY HOU~H, X.D. ~I)XCAL RECORDS STATE FARM AUTO IIJS. GO. I~DXCAL R~ORDS DR. DAIF/~. J. JECA]~, D.C. BRUC~ D. ELASKII, DO MEDICAL RKCORDS JOHI~ ~DICAL RECORDS TODO SAIff~LS, M.D. )~DlCAL R~CORDS ACTIVATOR I~THODS, I]JC. DIOZ-Xg1461 gS:~ O0--CO:~ 4 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COHSTAI~CE BENTLEYLINE : VS : : Pile No. - 01-2767 SCOTt : SUBPOENA TO PRODUCE DOCUMENTS OR THIN~-% FOR DISCOVERY PURSUANT TO RULE TO: __CUSTODIAN OF RECORDS FOR: ~]ALNU'~ BOT~OH RADIOLOGY (N~ ~/~ ~ Within twenty (20) d~/l after ~e~ice of thi~ subp4mna, you ire ocdeced b~ the COUlt to produce the follow-inS daaunen~ af thin~l: ~ .cs ~ouP ~c.: ~ ~~103 ---------- - Yo.u...may de.liver o~. I~11 legible cop~el M ~det~lll~mts or produce thin~l I~que~ted by this subpoen~ to~ether with the cerTmcate O! compflance, to the p~.~y m~kin~ this request at the ad(bell listed ab(we. Vo · adv~nCeo th~ ~eaconable cost of pmF,mn~ the copiel or pl~(lu¢inj[ the [hin~l comlht, u here the right to seek, m if you f~/I to produce the documente or thin~s mquiced by this subp~elUl, within twemy (20! dayl ~t~ its service, the servin8 this subFoen4 may INk a cot~ (~Jet comFellln8 you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST Ol~ THE FOLLOWING PERSON: NAME: C]~ ~OPII~ g~TCll'g. ADDRI:SS: 2/)11 ~ORT. FgOlrr ST. I'IA~gRURG. PA 17110 TELl:PHONE: 21~-2D6-0900 SUPRFMZ COURT ID ~. ATTORNEY FOR: DEFENDANT · BY,~HE COURT: OAT~ ~ )1,,. ~. ~,, -, ~_. C ~.? ,-'~-_~ ~ Seal of the Corot EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: WALNUT BOTI~OM RADIOLOGY BELVEDERE MED. CTR. 850 WALNUT BOTTOM RD CARLISLE, PA 17013 RE: 98300 CONSTANCE BENTLEYLINE Any and all records, correspondence, f'de, s and momorandums, handwritten notes, billing and paymcm records, relating ~o any examination, consultation, care or treatment. SDutb~S Req_u~e~l___: u_p to and including the prueM. ect: c~$TANCE BENTLEYLINE 191 RIDGE DR., CARLISLE, PA 17017 I~k of Birth: 12-17-1937 SU10-$826~2 98300--L08 CKRTZFICATK PRKRKQUISZTK TO SKF, VICE OF A Su~PO~I~A PURSUABT TO RULE 4009.22 IN THE HATTER OF: COURT OF CO~ION PLEAS CONSTANCE BENTLEYLINE TERH, -VS- CASE NO: 01-2767 SCOTT As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 HCS on behalf of CHRISTOPHER J. KNIGHT~ HSqUIe~ 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 sousht to be served, (2) A copy of the notice of intent, including the proposed subpoena, attached to this certificate, (3) No objection to the subpoena has been received, and The subpoena ~htch rill be served is identical to the subpoena which Is attached to the notice of intent to serve the subpoena. ~fCS on behalf of DATE~ 07~17~2002 CHRISTOPHER J. KHIGHT~ ESqU?U~ Attorney for DEFENDANT DHl1-$46254 98~00--L09 COI~II~O~r-TH OF PEIqlqSI'LV~LIqIA COUNTY OF C~EI~v.d~ND Ill TBE M&TT~ OF~ GOI~T OF C~DN PLFA~ CONSTAB~ B~ITLEYL I1~ -VS- CASE I10:01-2767 '~" -~ ["Ti, IR DI~rvm(v ,t,,...~_._~UlT ~ u, nT.ie 4009.21 [ lore: see enCloled lilt of locations ] TO: ~ I. SOBBL. [Sq. M~C C. TALLOW. tSqu.l.d MB~ an bebal£ o£ C~HISTOP~H J. ZlT~ef ~ ~nte~dn to nez~e a hlontical to the one that 1~ attocbed to tht~ natlce. Tau hum tweet! (~0) dayn £rem tho date lbted belou In d~Lch to £11. of record and nerve upa the underslsond an objection to the nebpenea. If tho twut! day not~ce period 1o hived or if no obJectim it ramie, rimn the subpoena my be nerved. Gmplete copIn8 o£ any reproduced records may be ordered at ymi= ezpenge by cumplet~n~ the 8ttacbd counsel card ~nd retuntin8 om to )ES or by ceutactins our local ES office. DATK8 06;27;2002 NOS on bebel£ of Attorney for ~ cC: CHI~STOP~I j. IiI~HT. HqUII~- 01-427 Any qu~stions reprdinS ~k~g rotter, cmtact ~HI )ES ~ IBC. 1601 ~ STRUT PH]~. PA 19103 ¢215) 240-0900 Dg02-191461 98300--C02 )~.> L~CAT'rOll LTST ~< PAGE~ 1 RECORDS RKq~STKD I~D?GAL RKGORDS IOI~I~Y HO~J~H. M.D. 'rHsPuA~CK STATE FABH A.DTO IHS. GO. I~DIGAL R~GORDS DR. IMIII.EL J. HCCABll, D.C. )~DIGAL RKCORDS BRIF, E D. KI, ASr~'#, DO I~D't'CAL RKGOBDS JOHII SPAYD I~DTCAL RECORDS TOI~D SAMIIKLS, M.D. ~'02-1914&1 ~8'4.00_C02 .COMMONWEALTH OF PENNSYLVANIA .COUNTY OF CUMBI~nt.AND CONSTANCE BENTLEYLINE : : VS : : File No. 01-2767 SCOT~ : : : SUBPOENA TO PRODUCE DOCUMI~VTS OR THINGs: FOR DISCOVERY PURSUANT TO RULE 4009 TO:. ~ CUSTODTAN OF RECORDS FOR: ACTTVATOR EETHODS, TNC. at ECS GROUP INC., 1601 HARKET ST., ~800, PHILA.,PA~ IAdd~ui You may deliver or mail lestble copies of thedgeuments or produce thinks requortsd by this subpoena, tosether with the certificate of compliance, to the piny mikinStMs request at the addrfl, listed abov- favaflco, the reasonable cos(: of prelMrinS the copies or pcoducin~ the thinSs sou~" You have (fib rjr, hi: to seek, in If you Lrai] to produce the documents or tMnp required by this subpoena, wi(:Mn twenty (20) days ~f~er i~. Mr;ice, the servinf (:his subpoen~ may seek i court order compellinS you to Comply with ii:. THIS SUBPOENA WAS ISSUi~L~ AT THE REQUEST OF THE FOLLOWING PERSON: NAME: C~IT gTOpR~R KNIGHT. ADDRESS: 26,11 'NO~,Tll FRONT ST. l~l:$BffitG. PA 17110 TELEPHON~ 215-26,6-0900 SUPREME COURT ID ~ Seal of the Court EXPLANATION OF REQUIRED RECORDS TO.' CUSTODIAN OF RECORDS FOR: ACTIVATOR METHODS, INC. PO BOX 80317 PHOENIX, AR 85060 RE: 98300 CONSTANCE BENTLEYLINE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. ~t. CONSTANCE BENTLEYL1NE 191 RII]~E BR., CARLISLE, PA 17017 Date of girth: 12-17-1937 SU10-382644 98300--L09 CKRT?F'FCATK Plt]I:RK~UIS'rTK TO SERVICE OF A SUBPOEliA PURSUANT TO RULK 4009.22 IN THE HATTER OF: COURT OF CO,iON PLEAS CONSTANCE BENTLEYLINE TERH. -VS- CASE NO: 01-2767 SCOTT AS a prerequisite to service of a subpoena for documents and things pursuant to Rule &009.22 HCS on behalf of CHRISTOPHER J. KNIGHTr KSqUTUE 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 ~hich the subpoena is sought to be served. (2) A copy of the notice of intent, includlag the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, end (4) The subpoena uhich will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. llCS on behalf of DATEr. 07/17/2002 CHRISTOPitgit J. KNIGHT, Attorney for D~FENDANT DKll-346255 98300--LiO COI~II~ON-w-~-dLL-TH OF PEh-AV-qYI. VANI.~% CO~qTy OF CUI~BEP/.~e~qD THE M&TT~R OF~ COURT OF ~ PLFAS CO#STABCK BEHTLKYLINZ GASK IJO~ 01-2767 [ ~ote.* see enclosed list of locatioua ] TOI JOSIAH B. SOBBL, ESq. talc c. TALLOW, zs~r~ ~ em bo~if of ~TIT~~ _! ~FF~mm --- ' ~8ntical to ~S office. ~z 0612712002 H=S on beh&lf of Att~,~ for mmm61JT CC** C~STOL~BH J. IIXeHT, ISQu~. 01-427 Any questions resardln8 thio rotter, ceutact T~ NCS ~tOg[ lie. lSO1 MiR~IT STR~ ~SO0 PH~7.~I~JH~A, P& 19103 (2~$) 246-0900 !~02-191461 983 00--(:02 LOCATXOll LXST <<< RECORDS OESTED PAGes ,X I, OCATXOIJ M ~I)XGAL RECORDs ~ ZIISTJRAM~ RO/MIIY HOUGH, H.D. )~D?CAL RECORDS BRIF, E D. KI, AS~II, DO t~i)TCAL RKCORDS ,,TOHll SPA'fi) I~DTCAL R~CORDS TODD SANEI~S, X.D. tSDXGAL RECORDS MALIUT BOTTC0f BADXOLOGy ~DXGAL R~CORDS ACTXVAToit I~rHoD8. XlJC. ~02-XgXA6Z 98300--(::02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMB£RI. AN~ CONSTANCE BENTLEYLI~NE : : VS : SCOTT : File No. _ 01-2767 : ,* : FOR DISC VERy PU U T R ,1009,22 TO: CUSTODZAN OF R~CORD$ FOR: NAGNE?TC TNAG~NG CENTER iN*me of Perm ,~ ~#t~I Within Iw~nty (20) da-- ~ · - . ,hi.s. .... · ,--, -..~ es~. ~. ,.~.~,.~.... ~.~.~ ~ ~..... ~,.,.,h. foli~.s ,.,.... ., Yo.u...may deliver or.mail lestble copies of t~edmmm~ltS m' ~u~ t~n c~mf:cate of comphance, to the o~ ..~.- .~, ~ u~ ~ t~...,k if yOU fall to p~ t~ d~me~s ~ tM~ ~uJ~ tMs sub · THIS SUB~E~A WAS ISS~ AT ~E RE~ OF ~E ~LLOMNG ~RSON: .. NAM~ ~TS~p~ ~T~, ESOt ADDR~s:_ 2~11 ~ ~ ~UUTSRW~. PA 17110 T[L[PHON~ 21~-246~900 SU~[M~ ~T ID ~ A~RN~ FO~. D~ Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MAGNETIC IMAGING CENTER 4665 TRINDLE ROAD MECHANICSBURG, PA 17055 RE: 98300 CONSTANCE BENTLEYLINE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. 191 .RIDGE DR., CARLISLE, PA 17017 Da~e of Birth. 12-17-1937 SU10-382646 983OO--L3_O HENRY LINE AND : IN THE COURT OF COMMON PLEAS CONSTANCE BENTLEY LINE, : OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs : NO. 01-2767 . V, '. : CIVIL ACTION - LAW MICHAEL SCOTT, : Defendant : JURY TRIAL DEMANDED PRAEClPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Michael Scott, with regard to the above-captioned matter. Respectfully submitted, NEALON & GOVER, P.C. Michael S. Ferguson, Esquire Attorney I.D. No. 83882 2411 North Front St. I ( Harrisburg, PA 17110 Date: [~ {'{ 09 (717) 232-9900 CERTIFICATE OF SERVICE AND NOW, this ~(~' day of December 2003 I hereby certify that I have served the foregoing Praecipe to Enter Appearance on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Marc G. Tarlow, Esquire Kain, Brown & Roberts, LLP 119 East Market Street York, PA 17401 Joseph B. $obel, Esquire 212 North Third St., Suite 202 Cranberry Court Harrisburg, PA 17101-1505 M~ich~a~~squire HENRY LINE AND ! IN THE COURT OF COMMON PLEAS CONSTANCE BENTLEY LINE, · OF CUMBERLAND COUNTY, PENNSYLVANIA : Plaintiffs : NO. 01-2767 : v. : CIVIL ACTION - LAW : MICHAEL SCOTT : JURY TRIAL DEMANDED PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please mark the above-captioned matter settled, satisfied and the docket discontinued. Respectfully Submitted, SHUMAKER WILLIAMS, P.S. ' Marc (~.~a~w, Esquire Attorney I.D. No. ..~ 119 East Market Stree~ York, PA 17401 Date:/~. ~'..//.~,z/ (717) 848-5134