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HomeMy WebLinkAbout04-4347William P. Douglas, Esq. Supreme Court I.D. #37926 Douglas Law Office 27 W. High St. Carlisle, PA 17013 Telephone (717) 243-1790 Joseph Zucatti In the Court of Common Pleas of Plaintiff Cumberland County, Pennsylvania vs No. 04- y(14y-7 Civil Term Shirley Mae Stambaugh 3419 Ritner Highway Newville, PA 17241 Civil action law Defendant Jury Trial Demanded Praecipe to Issue a Writ of Summons Dear Mr. Long: Please issue a writ of summons against the defendant, Shirley Mae Stambaugh William P. Dou s, Esq. Attorney fo aintiff date: August 27, 2004 ,c1 ? O ?? FV :tr •7 ?? ._ ?/ 'Y rTl :3 z'. Commonwealth of Pennsylvania County of Cumberland Joseph Zucatti In the Court of Common Pleas of Plaintiff Cumberland County, Pennsylvania vs No. 04- '-/341-7 Civil Term Shirley Mae Stambaugh 3419 Ritner Highway Newville, PA 17241 Civil action law Defendant Jury Trial Demanded Writ of Summons To: Shirley Mae Stambaugh 3419 Ritner Highway Newville, PA 17241 You are hereby notified that Joseph Zucatti has brought an action against you. date: August 27, 2004 William P. Douglas, Esq. Douglas Law Office 27 W. High St. Carlisle, PA 17013-0261 717-243-1790 Attorney for Plaintiff j ' Deputy Prothcgiotary 1111 G1 ( ? ? ss o 8 N SHERIFF'S RETURN - REGULAR CASE NO: 2004-04347 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ZUCATTI JOSEPH VS STAMBAUGH SHIRLEY MAE ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon STAMBAUGH SHIRLEY MAE the DEFENDANT , at 1006:00 HOURS, on the 8th day of September, 2004 at 3419 RITNER HIGHWAY NEWVILLE, PA 17241 SHIRLEY STAMBAUGH a true and attested copy of WRIT OF SUMMONS by handing to together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.14 Affidavit .00 Surcharge 10.00 .00 36.14 Sworn and Subscribed to before me this , day of ??ptin ?t?. oZUfl A. D. othonotary So Answers: ? -e? R. Thomas Kline 09/08/2004 DOUGLAS LAW OFFICE By. De uty Sherif CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ZUCATTI -VS- STAMBAUGH COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 04-4347 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/20/2005 MCS n 351behalf/o(f CAS X E, ESQ. ` Attorney for DEFENDANT DEII-585516 5 9 5 9 7- L 0 1 C O M M O N W E A L T H O EP P E N N S Y L VAN I -A COUNTY OP C UM B E R L AN D IN THE MATTER OF: COURT OF COMMON PLEAS ZUCATTI STAMBAUGH NOTICE OF I TERM, -VS- CASE NO: 04-4347 0•IT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND IMP nTCZMVTMV PTTRCTTANT TO RTTLE 4009.21 BELVEDERE MEDICAL CENTER MEDICAL RECORDS & XRAYS APPALACHIAN ORTHOPEDIC CENTER MEDICAL RECORDS & XRAYS CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS CARLISLE REGIONAL MEDICAL CNTR X-RAY ONLY TO: WILLIAM P. DOUGLAS, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 08/31/2005 CC: CASEY SHORE, ESQ. - 05-573 PATRICIA HOFFMAN - MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-311218 S 9 S 9 7- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ZUCATTI vs. STAMBAUGH File No. CUMBERLAND 04-4347 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for BELVEDERE MEDICALCENTER (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: ****SEE ATTACHED RIDER**** at The MCS Groun Inc 1601 Market Street Suite 800 Philadelphia FA 19103 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: CASEY SHORE. ESQ. ADDRESS: 2411 N. FRONT ST. HARRISBURG-PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: d ?(X Seal of the Court BY T F COURT: r Pro honota£y/CsI roil ivision Deputy 59597-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: BELVEDERE MEDICAL CENTER 850 WALNUT BOTTOM ROAD CARLISLE, PA 17013 RE: 59597 JOSEPH ZUCATTI Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medicationJprescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : JOSEPH ZUCATTI 1908 FRY LOOP AVE., CARLISLE, PA 17013 Social Security #: 175-48-3716 Date of Birth: 04-17-1962 SU10-580986 59597-L 03_ CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ZUCATTI STAMBAUGH COURT OF COMMON PLEAS TERM, CUMBERLAND -vs- CASE NO: 04-4347 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, ESQ. certifies that (1)' A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 09/20/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DE11-585517 5 9 5 9 7-T,0 2 C O M M O N W E A L T H OF' P E NN S Y L VANS A COUNTY OP C U M B E R L AN D IN THE MATTER OF: ZUCATTI -VS- STAMBAUGH TO SERVE A SUBPOENA R DISCOVERY PURSUAN COURT OF COMMON PLEAS TERM, CASE NO: 04-4347 BELVEDERE MEDICAL CENTER MEDICAL RECORDS 6 XRAYS APPALACHIAN ORTHOPEDIC CENTER MEDICAL RECORDS & XRAYS CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS CARLISLE REGIONAL MEDICAL CNTR X-RAY ONLY TO: WILLIAM P. DOUGLAS, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 08/31/2005 CC: CASEY SHORE, ESQ. - 05-573 PATRICIA HOFFMAN - Any questions regarding this matter, contact MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-311218 5 9 5 9 7- C 0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ZUCATTI vs. STAMBAUGH File No. CUMBE L AND 04-4347 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for APPALACHIAN ORTHOPEDIC CENTER (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: **** EE ATTACHED RIDER **** at The MCS G=12 Inc 1601 Market Street. Suite xnn Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with thecerfificate 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: CASEY SHORE, ESQ. ADDRESS: 2411 N FRONT ST HARRISBURG PA 17110 TELEPHONE: (215) 746-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: -?-a --? t ?DG2S Seal of the Court BY THE COURT: ] Prothonotary/ erk, Civil' v lion Deputy 59597-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: APPALACHIAN ORTHOPEDIC CENTER I DUNWOODY DRIVE CARLISLE, PA 17013 RE: 59597 JOSEPH ZUCATTI Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : JOSEPH ZUCATTI 1908 FRY LOOP AVE., CARLISLE, PA 17013 Social Security #: 175-48-3716 Date of Birth: 04-17-1962 SU10-580988 59597-L 02 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ZUCATTI STAMBAUGH COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 04-4347 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. WS on behalf of DATE: 09/20/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DEII-585518 5 9 5 9 7- 1,0 3 C O M M O N W E A L T H OF PENN S Y L VANS A COUNTY OF, C UM B E R L -AN ID IN THE MATTER OF: COURT OF COMMON PLEAS ZUCATTI -VS- STAMBAUGH OF INTENT TO SERVE A THINGS TERM, CASE NO: 04-4347 PRODUCE DOMIE TTS AND RULE 4009.21 BELVEDERE MEDICAL CENTER MEDICAL RECORDS 6 XRAYS APPALACHIAN ORTHOPEDIC CENTER MEDICAL RECORDS & XRAYS CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS CARLISLE REGIONAL MEDICAL CNTR X-RAY ONLY TO: WILLIAM P. DOUGLAS, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 08/31/2005 CC: CASEY SHORE, ESQ. - 05-573 PATRICIA HOFFMAN - Any questions regarding this matter, contact MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-311218 5 9 S 9 7- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ZUCATTI vs. STAMBAUGH File No. CUMBERLAND 04-4347 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARLISLE REGIONAL MEDICAL CNTR (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: **** E ATTACHED RIDER **** at The MCS Croup-Inc 1601 Market Street Suite 900 Philadelphia PA 19103 You may deliver of 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: CASEY SHORE. ESQ. ADDRESS: 7411 N FRONT ST HARRISBURG PA 17110 TELEPHONE: X2151246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Cl rk, Civil 1s on /In Date: Deputy I 1 Seal of the Court 59597-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CNTR 246 PARKER STREET CARLISLE, PA 17013 RE: 59597 JOSEPH ZUCATTI Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : JOSEPH ZUCATTI 1908 FRY LOOP AVE., CARLISLE, PA 17013 Social Security /f: 175-48-3716 Date of Birth: 04-17-1962 SU10-580990 5 9 5 9 7- L 0 3 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ZUCATTI STAMBAUGH COURT OF COMMON PLEAS TERM, CUMBERLAND -vs- CASE NO: 04-4347 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 09/20/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DEII-585519 S 9 5 9 7- L 04 COMMON W E A L T H 07 P E NN S Y L VAN TA COUNTY 01P C UMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS ZUCATTI -VS- STAM3AUGH NOTICE OF TO SERVE A TERM, CASE NO: 04-4347 DOCUMENTS AND TO RULE 4009.21 BELVEDERE MEDICAL CENTER MEDICAL RECORDS & XRAYS APPALACHIAN ORTHOPEDIC CENTER MEDICAL RECORDS & XRAYS CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS CARLISLE REGIONAL MEDICAL CNTR X-RAY ONLY TO: WILLIAM P. DOUGLAS, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 08/31/2005 CC: CASEY SHORE, ESQ. - 05-573 PATRICIA HOFFMAN - Any questions regarding this matter, contact MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-311218 5 9 5 9 7- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ZUCATTI vs. STAMBAUGH File No. CUMBERLAND 04-4347 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARLISLE REGIONAL MEDICAL CNTR (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: **** SEE ATTACHED RIDER **** at The MCS Croup, Inc 1601 Market Street Suite 800 Philadelphia PA 19103 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: CASEY SHORE. ESO. ADDRESS: 2411 N FRONT ST HA RIB 1R PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civ' iv lion Date: Deputy Seal of the Court 59597-04 EXPLANATION OF REQUIRED RECORDS TO. CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CNTR 246 PARKER STREET CARLISLE, PA 17013 RE: 59597 JOSEPH ZUCATTI Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : JOSEPH ZUCATTI 1908 FRY LOOP AVE., CARLISLE, PA 17013 Social Security #: 175-48-3716 Date of Birth: 04-17-1962 SU10-580992 S 9 5 9 7- L 0 4 ?? ? ?? ?:_ ? ' ?T -f7 ? m ? o? C,J? ? ? -r. _ '-??< - C??7? ': n' ? -? . < JOSEPH ZUCATTI, Plaintiff VS. SHIRLEY MAE STAMBAUGH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4347 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Shirley Mae Stambaugh, with regard to the above-captioned matter. Respectfully submitted, NEALON COVER & PERRY By: Ca ore, Esquire I.D. #: 85321 2411 North Front Street Harrisburg, PA 17110 717/232-9900 Date: C6 CERTIFICATE OF SERVICE AND NOW, this _ Ll1r, day of August, 2005, 1 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 mails, postage prepaid, addressed to: William P. Douglas, Esquire Douglas Law Office 27 W. High Street Carlisle, PA 17013 aslkN S lore, Esquire r c z- .4 l n El - _ -n L JOSEPH ZUCATTI, Plaintiff VS. SHIRLEY MAE STAMBAUGH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4347 CIVIL ACTION - LAW 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. Date: CCb TO THE PLAINTIFF: Respectfully submitted, NEALON GOVER & PERRY By Camay. Shore, Esquire I.D. #: 85321 2411 North Front Street Harrisburg, PA 17110 717/232-9900 RULE 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. DATED: P thon CERTIFICATE OF SERVICE AND NOW, this /0-1 day of August, 2005, 1 hereby certify that I have served the foregoing Praecipe for Rule to File Complaint on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: William P. Douglas, Esquire Douglas Law Office 27 West High Street P.O. Box 261 Carlisle, PA 17013 LAL Ca . Shore, Esquire C? 4r* Z m t7 YC %C v; ,a. 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 twenty (20) days after this complaint and notice are served by entering a written appearance personally or by attorney, and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you 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. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Legal Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 DOUGLAS LAW OFFICE Dated: q - N y - -5 William P. Douglas Attorney for Plaintiff COMPLAINT The plaintiff, Joseph Zucatti, is an adult individual residing at 1908 Fry Loop Avenue, Carlisle, Cumberland County, Pennsylvania. 2. The defendant, Shirley Mae Stambaugh, is an adult individual residing at 3419 Ritner Highway, Newville, Cumberland County, Pennsylvania. 3. On or about August 28, 2002, the plaintiff was traveling on Route 11, attempting to make a turn into the Food Lion parking lot. 4. At or about the same time and place, the defendant was operating her vehicle and failed to observe the plaintiff attempting to make his turn. 5. As a direct and proximate result of her negligence, the defendant collided with the plaintiff at a high rate of speed, causing injuries to the plaintiff's head and neck. The accident in question was caused solely by the negligence of the defendant. 6. The defendant was negligent in the following respects: (a) failure to drive within the assured clear distance ahead; (b) failure to maintain a proper lookout; (c) failure to operate the vehicle in a careful and prudent manner. 7. As a direct and proximate result of the accident, the plaintiff was injured. Those injuries include, but are not limited to, cervical strain/sprain, traumatic headache syndrome, and shock to his nerves and nervous system. 8. As a direct and proximate result of the accident, the plaintiff has incurred medical expenses in the past and may continue to do so into the future. As a direct and proximate result of the negligence of the defendant, the plaintiff has suffered and may continue to suffer in the future, pain, aggravation and inconvenience, loss of life's pleasures, loss of wages, and his economic horizons may be limited. WHEREFORE, it is prayed that judgment be entered in favor of the plaintiff, and against the defendant in an amount in excess of that requiring compulsory referral to arbitration. A jury trial is hereby demanded. DOUGLAS LAW OFFICE William P. Douglas,T-squire Attorney for aintiff 27 West Hig treet Carlisle, P 4 7013 717-243-1790 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VERIFICATION SS. I verify that the statements made in the foregoing document are true and correct, to the best of my knowledge, information, and belief. I understand that false statements herein made are subject to the provisions of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date William P. D Attorney for 5. cn Y v ?? W ?Y{ JOSEPH ZUCATTI, Plaintiff VS. SHIRLEY MAE STAMBAUGH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4347 CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Joseph Zucatti and his attorney William P. Douglas, Esquire Douglas Law Office 27 West High Street P.O. Box 261 Carlisle, PA 17013 YOU ARE HEREBY NOTIFIED to file a written response to the enclosed Answer with New Matter within twenty (20) days from service hereof or a judgment may be entered against you. Respectfully submitted, NEALON GOVER & PERRY By: t .?. as8y?. Shore, Esquire Attorney I.D. No. 85321 2411 North Front St. Harrisburg, PA 17110 Date: !G 1 C (717) 232-9900 JOSEPH ZUCATTI, Plaintiff VS. SHIRLEY MAE STAMBAUGH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4347 CIVIL ACTION - LAW JURY TRIAL DEMANDED DEFENDANT'S ANSWER TO COMPLAINT WITH NEW MATTER 1-3. Admitted based upon information and belief. 4-9. Denied pursuant to Rule 1029(e) of the Pennsylvania Rules of Civil Procedure. WHEREFORE, it is respectfully requested that the Complaint be dismissed with costs to be paid by the Plaintiff. NEW MATTER 10. Paragraphs 1-9 are incorporated herein as is reference were made thereto. 11. The Plaintiffs claim may be barred in whole or in part by application of the Pennsylvania Motor Vehicle Financial Responsibility Act. WHEREFORE, the Defendant respectfully requests that the Complaint be dismissed with costs to be paid by the Plaintiff. Date: C F Respectfully submitted, NEALON GOVER & PERRY By: Cas G. Shore, Esquire I. D. #: 85321 2411 North Front Street Harrisburg, PA 17110 717/232-9900 CERTIFICATE OF SERVICE AND NOW, this a?M' day of October, 2005, 1 hereby certify that I have served the foregoing Answer to Complaint with New Matter on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: William P. Douglas, Esquire Douglas Law Office 27 West High Street P.O. Box 261 Carlisle, PA 17013 ..: 4 1 Case . Shore, Esquire W r VERIFICATION I, SHIRLEY MAE STAMBAUGH, verify that the statements made in the foregoing ANSWERS TO THE COMPLAINT WITH NEW MATTER 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. Date: /? 0 ? Y`,: ?x ._ L C. -_. DOUGLAS LAW OFFICE 27 W. HIGH ST. WILLIAM P. DOUGLAS, ESQ. POB 261 Supreme Court I.D.# 37926 CARLISLE PA 17013 TELEPHONE 717-243-1790 Joseph Zucatti In the Court of Common Pleas of Plaintiff Cumberland County, Pennsylvania vs No. 04- 4347 Civil Term Shirley Mae Stambaugh Civil action law Defendant Jury Trial Demanded Reply to New Matter 10. Denied. The original allegation contained in the plaintiff's complaint are incorporated herein and reference is made thereto as if fully set forth at length. 11. Denied. Denied as a legal conclusion to which no response is necessary. r William P. Doug s, Esq. Attorney for aintiff AFFIDAVIT I hereby swear or affirm that the foregoing is true and correct to the best of my knowledge and/or information and belief. This is made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. i \, -L- . William P. Douglas, Esq. Date: November 4, 2005 C3 h> ? u fl?iV' ?? alb ? v?[!1 ?)? ? , _-? ice} \ ? _ ,I ; ?' ? N ` <i y- '•? ['? . p I CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ZUCATTI TERM, CUMBERLAND -vs- CASE NO: 04-4347 STAMBAUGH As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/23/2005 M S on b''ggh if o , CASW SHORE, ESQ' Att(6rney for DEFENDANT DE11-596004 S 9 S 9 7- L 05 C O M M O N W E A L T H OP P E N N S Y L VAN T.7%- COUNTY OP C UM B E R L -'%N ID IN THE MATTER OF: COURT OF COMMON PLEAS ZUCATTI -VS- STAMBAUGH OF INTENT TO TERM, CASE NO: 04-4347 TO "ZC9 SPRING ROAD FAMILY PRACTICE MEDICAL RECORDS & KRAYS TO: WILLIAM P. DOUGLAS, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ_ intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/03/2005 CC: CASEY SHORE, ESQ. - 05-573 PATRICIA HOFFMAN - 1554451912 Any questions regarding this matter, contact MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-316537 59S97-C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ZUCATTI vs. File No. 04-4347 STAMBAUGH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for SPRING ROAD FAMILY PRACTICE (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: **** SEE ATTACHED RIDER **** at The MCS Groun Inc 1601 Market Street, Suite 800 Philadelphia- PA 1910 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: CASEY SHORE. ESO ADDRESS: 2411 N FRONT ST. HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: / f Prothdnotary/Cleric; Civil Division I- NOV 2 3 2005 Date: LGT JY 0'w t' Deputy Seal of the Court 59597-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SPRING ROAD FAMILY PRACTICE 1921 SPRING ROAD CARLISLE, PA 17013 RE: 59597 JOSEPH ZUCATTI Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : JOSEPH ZUCATTI 1908 FRY LOOP AVE., CARLISLE, PA 17013 Social Security #: 175-48-3716 Date of Birth: 04-17-1962 SU10-589918 5 9 S 9 7-T-0 5 ,_?, ;_, -? ,_ ? , ,.; <- t,, `?- ,,.,. .._ .? . _ JOSEPH ZUCATTI, Plaintiff VS. SHIRLEY MAE STAMBAUGH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4347 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the undersigned's appearance on behalf of the Defendant, Shirley Mae Stambaugh, with regard to the above-captioned matter. Respectfully submitted, NEALON GOVER & PERRY By: t se G. ore, Esquire I.D. 321 2411 North Front Street Harrisburg, PA 17110 717/232-9900 Date: o(o t" no il77 n, j JOSEPH ZUCATTI, Plaintiff VS. SHIRLEY MAE STAMBAUGH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4347 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Shirley Mae Stambaugh, with regard to the above-captioned matter. Date: \o Respectfully submitted, NEALON GO\4ER & PERRY 2p l#: 843111 2 1 j North orth Front Street H rrisburg, PA 17110 717/232-99010 CERTIFICATE OF SERVICE AND NOW, this QI D+day of July, 2006, 1 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 mails, postage prepaid, addressed to: William P. Douglas, Esquire Douglas Law Office 27 W. High Street Carlisle, PA 17013 PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: ® for JURY trial at the next term of civil court. D for trial without a jury. ---- - ---- - ------------ - ----------- - --------------------------------------------------- CAPTION OF CASE (entire caption must be stated in full) (check one) JOSEPH ZUCATTI, ® Civil Action - Law ? Appeal from arbitration 13 (other) (Plaintiff) VS. The trial list will be called on 01,/ n Q n 7 and SHIRLEY STAMBAUGH, (Defendant) VS. Trials commence on _ 02/05/07 Pretrials will be held on 01/17/07 (Briefs are due S days before pretrials No. OW-4-147 Term Indicate the attorney who will try case for the party who files this praecipe: Jenni Henley Allen, Esquire Indicate trial counsel for other parties if known: w Itiam V. llou las Esquire - for Plan iff This case is ready for trial. Signed: Print Name: Qpnni Hpnley , A11pn Date:_ lo/11/06 Attorney for: Defendant f .- .!^ CERTIFICATE OF SERVICE AND NOW, this day of October, 2006, 1 hereby certify that I have served the foregoing Praecipe For Listing Case For Trial on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: William P. Douglas, Esquire Douglas Law Office 27 West High Street P.O. Box 261 Carlisle, PA 17013 Jejni Henley Allen, Esquire ..3 ? l_P pg-i ,;?t?r. -;? ;-`. ?, G? ?? _., %? ?:i=; «?? - ?,? ;-! .. ?.? JOSEPH ZUCATTI, Plaintiff VS. SHIRLEY MAE STAMBAUGH, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4347 : CIVIL ACTION - LAW : JURY TRIAL DEMANDED MOTION TO LIST FOR TRIAL TO THE HONORABLE JUDGE J. WESLEY OLER JR.: AND NOW, comes the Defendant, Shirley Mae Stambaugh, by and through her attorneys, Nealon Gover & Perry, and files the following Motion to List for Trial: 1. Nicole M. Werner, Esquire was in attendance for the call of the list this morning, however she was remiss in calling the above-referenced case to be listed for trial. 2. Ms. Werner attempted to notify Your Honor of the mistake, however, the case had already been stricken from the trial list. Accordingly, Your Honor requested that a Motion to List for Trial be filed. 3. Counsel for the Plaintiff, William P. Douglas, Esquire, was not present at the call of the list. 4. All relevant discovery and preliminary matters have been completed and the case is ready for trial. WHEREFORE, Defendant, Shirley Mae Stambaugh, respectfully requests that this Honorable Court grant the above Motion and list this case for the next trial term. Respectfully submitted, NEALON GOVER & PERRY IL, I By: Al' U- LjU--k Jenni Henley Allen, Esquire Attorney I.D. No. 84311 2411 North Front St. Harrisburg, PA 17110 Date: t` ' (717) 232-9900 41 *% CERTIFICATE OF SERVICE AND NOW, this day of January, 2007 I hereby certify that I have served the foregoing Motion to List Case for Trial on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: William P. Douglas, Esquire Douglas Law Office 27 West High Street P.O. Box 261 Carlisle, PA 17013 Jenni Henley Allen, Esquire.;: r'• { ?-: "?.> .? ?? r ?;. t,,..? `a JOSEPH ZUCATTI, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW SHIRLEY STAMBAUGH, Defendant 04-4347 CIVIL TERM IN RE: CASE STRICKEN FROM LIST ORDER OF COURT AND NOW, this 9th day of January, 2007, upon consideration of the call of the civil trial list, and the above-captioned case not having been called for trial, it is stricken from the trial list. I lliam P. Douglas, Esquire 57 W. Pomfret Street P.O. Box 261 Carlisle, PA 17013 For Plaintiff /enni Henley Allen, Esquire 2411 N. Front Street Harrisburg, PA 17111 For Defendant Court Administrato :mae 4 By the Court, Lu C? C^ - ?J c1s ? PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the following case: (Check One) (X) for JURY trial at the next term of civil court. ( ) for trial without a jury. (CAPTION OF CASE, entire caption must be state in full) (check one) (X) ( ) JOSEPH ZUCATTI, Vs. SHIRLEY MAE STAMBAUGH, Civil Action - Law Appeal from Arbitration (other) The trial list will be called on March 20. 2007 and Trials commence on April 16, 2007 Pretrials will be held on March 28. 2007 (Briefs are due 5 days pretrial.) (The party listing this case for trial shall provide forthwith a copy of the Praecipe to all counsel, pursuant to Local Rule 214.1.) No. 04-4347 Indicate the attorney who will try case for the party who files this Praecipe: Jenni Henley Allen, Esquire Indicate trial counsel for other parties if known: William P. Douglas, Esquire This case is ready for trial. Date: Plaintiff(s) Defendant(s) NEALON, ER & PERRY By: Imrey i Henley Allen, Esquire ney I.D. No. 84311 for Hubert and Alice Chin 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 C-? ? ?' n :.;. ' ?-°" -? t_.. T -r? ;?.- ? x? --- t ? , -;; ? ? ? .. .,.,..y _,, `? 1 ? ?? .? ....+ £ ??.r ., . „1-:' it ' - JOSEPH ZUCATTI, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 04-4347 SHIRLEY MAE STAMBAUGH, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED P R A E C I P E TO THE PROTHONOTARY: PLEASE WITHDRAW DEFENDANT'S PRAECIPE TO LIST THE ABOVE- CAPTIONED MATTER FOR TRIAL THE WEEK OF APRIL 16, 2007. Respectfully submitted, NEALON GOVER & PERRY By Date: ? i av C`1 Lehi IN41P?n, Esquire At'or ey I.D. NO. 84311 2 11 orth Front Street H ris urg, PA 17110 (71 232-9900 .. CERTIFICATE OF SERVICE AND NOW, this -v_ day of January, 2007, 1 hereby certify that I have served the foregoing PRAECIPE TO WITHDRAW REQUEST TO LIST FOR TRIAL on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: William P. Douglas, Esquire Douglas Law Office 27 West High Street P.O. Box 261 Carlisle, PA 17013 _., -'t 1 ^? - ? a?' W ? ?i I "?l - -r, - , _ , ::? '??ri ? .. -v„ - '?"? ? ' ?> JOSEPH ZUCATTI, vs. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Shirley Mae Stambaugh, Defendant NO. 4347 2004 CIVIL ACTION - LAW JURY TRIAL DEMANDED RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially in the Following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Matthew R. Gover. Esquire , counsel for the plaintiff/defendant in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of plaintiff in the action is $ 25, 000.00 The counterclaim of the defendant in the action is The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: William P. Douglas, Esquire, 27 West High St., Carlisle, PA 17013 WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. fubmitted, Ma.tthewIR. Gover, Esquire - No. 47593 ORDER OF COURT AND NOW, petition, Esq., and ,200 , in consideration of the foregoing Esq., and Esq., are appointed arbitrators in the above captioned action (or actions) as prayed for. By the Court, EDGAR B. BAYLEY -44 .? w a ?J JOSEPH ZUCATTI, V80 Plaintiff Shirley Mae Stambaugh, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 4347 2004 . CIVIL ACTION - LAW JURY TRIAL DEMANDED RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially in the Following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Matthew R. Gover, Esquire , counsel for the plaintiff/defendant in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of plaintiff in the action is S 25, 000.00 The counterclaim of the defendant in the action is The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: William P. Douqlas, Esquire, 27 West High St., Carlisle, PA 17013 WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. If e---z all MatthbwjR. Gover, Escy'uire - No. 47593 ORDER OF COURT A-1 Y-7 AND NOW, 200 in consideration of e f regoing petition, r Esq., and , Esq., and AP6 Esq., are appointed arbitrators in the above captioned a tion ( actions) as prayed for. By th Curt, DG B. YLE n•; j $..a rte: L J1 i- Ll- 0 Y _ T'r 1-,#') • F'? f V- r Ma OD(6 h r; C-71 "Y CID k 1 JOSEPH ZUCATTI, COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. SHIRLEY MAE STAMBAUGH, DEFENDANT 04-4347 CIVIL TERM ORDER OF COURT AND NOW, this I!f day of May, 2007, the appointment of Jacqueline M. Verney, Esquire, to the Board of Arbitrators in the above-captioned case, IS VACATED. Robert J. Dailey, Esquire, is appointed in her place. By the'?.'o-irt, /Harold S. Irwin, III, Esquire Chairman /Robert J. Dailey, Esquire Court Administrator :sal Edgar B. Bayley, J. Cope a,`d M 1 5,x.0 A i -`' t?? ;=', ?-'a ? . _ ._ ?°?; v? ?+ ? .....«r ...w L.a... rp"°LL ?n?y? JOSEPH ZUCATTI, COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. SHIRLEY MAE STAMBAUGH, DEFENDANT 04-4347 CIVIL TERM ORDER OF COURT AND NOW, this '9 day of June, 2007, the appointment of Robert J. Dailey, Esquire, to the Board of Arbitrators in the above-captioned case, IS VACATED. John W. Carter, Esquire, is appointed in his place. By the Co Edga o6rold S. Irwin, III, Esquire Chairman ? Ohn W. Carter, Esquire Court Administrator :sal Bayley, J. < F co ?- MLU ='`' S Cl- LL- Q ° C c -i Plaintiff / Defendant In The Court of Common Pleas of Cumberland County, Pennsylvania No. 04 - 4 Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office wi fidelity. i Signature i tore Signature k 'o S Name (Chairman) Law Firm 64 S S/- Address C4,0- l V& Pf 170/ 3 City, Zip Name Law Firm 3 /V7/r-r Address city, zip LIV-- a/71Pw- Name M d- J ? 4 Law Firm 36 ?• lVghovP? J/- Address ?:j ??- /7p /3 City, zip Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) 7VE04?LeA14,0??"" j . Arbitrator, dissents. (Insert name if applicable. Date of Hearing: 711 S-Ar7 Date of Award: -7//F k7 Notice of Entry of Award (Chairman) Now, the ?s± - day of , 20Q17 -, at 8: 50 , A .M., the above award was entered upon the docket and notice e1 o; given by mail'to the parties or their attorneys. Arbitrators' co:r_per_sation to be paid upon appeal: 350. DO By: Deputy e--i G ?SS lot a? a ?? p16 ?too?, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Vs File No. QLF Civil Term Def t . NOTICE OF APPEAL FROM AWARD OF BOARD OF ARBITRATORS TO THE PROTHONOTARY: Notice is given tha NA- appeals from the award of the board of arbitrators entered 's case on !0, 1 i 'K? A jury trial is demanded_.X_. (Check the line if a jury trial is demanded. Otherwise jury trial is waived.) I hereby certify that (1) the compensation of the arbitrators has been paid, or out the inapplicable clause.) or Attorney of Appellant Note: The demand for jury trial on appeal from compulsory arbitration is governed by Rule 10071(b). (b) No affidavit or verification is required. Adopted March 16, 1981, effective May 15, 1981. 7 f? W r PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: ® for JURY trial at the next term of civil court. ? for trial without a jury. ------------------------------------------------------------------------------------------------------------------ CAPTION OF CASE (entire caption must be stated in full) (check one) Civil Action - Law Appeal from arbitration JOSEPH ZUCATTI (Plaintiff) VS. SHIRLEY MAE STAMBAUGH (Defendant) VS. (other) The trial list will be called on_2 0 0 9 and Trials commence on June 29, 2009 Pretrials will be held on June 10, 2009 (Briefs are due 5 days before pretrials No. 04-4347 ,Civil Term Indicate the attorney who will try case for the party who files this praecipe: Casey G. Shore, Esquire Indicate trial counsel for other parties if known: William P. Douglas, Esquire This case is ready for trial. Date: )Z> Ca0ey G. Shore Attomeyfor: Shirley Mae Stambaugh F11.ED-OF rE OF THE PROTHONOTARY 2009 MAY { ! PM 2: 2 5 Jv wuNTY PENINSYLVMIA ?5-, 66 f d e C?" JOSEPH ZUCATTI, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW SHIRLEY MAE STAMBAUGH, Defendant 04-4347 CIVIL TERM IN RE: CASE STRICKEN FROM LIST ORDER OF COURT AND NOW, this 2nd day of June, 2009, upon consideration of the call of the civil trial list, and no counsel having called the above-captioned case for trial, it is stricken from the trial list. By the Court, ? William P. Douglas, Esquire 43 West South Street P.O. Box 261 Carlisle, PA 17013 For Plaintiff .., Ccasey G. Shore, Esquire 2411 North Front Street Harrisburg, PA 17110 For Defendant Court Administrator :mae (iGp r'es rn,at & 1L "Ikpt Lt - C_Jrt- I clt, ov- - LZ- y aooq JU.A.) - 3 AM io:3G? .. JOSEPH ZUCATTI, Plaintiff VS. SHIRLEY MAE STAMBAUGH, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4347 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the undersigned's appearance on behalf of the Defendant, Shirley Mae Stambaugh, with regard to the above-captioned matter. Respectfully submitted, Cas IGXhore, Esquire 1. D. #: 5321 orth Front Street Harrisburg, PA 17110 717/232-9900 Date: 11/(7 t CERTIFICATE OF VICE Q? AND NOW, this day of b0er,2009, I hereby certify that I have served the foregoing Praecipe for Withdrawal of Appearance on the following by depositing a true and correct copy of same in the United States mails, postage prepaid: addressed to: William P. Douglas, Esquire Douglas Law Office 27 W. High Street Carlisle, PA 17013 RLL)-?RCE OF THE pRCFI CINIOTRRY 2009 NOV 19 P 2: 4 3 cumib? : "JN'TY OWENS, BARCAVAGE AND MCINROY, LLC BY: Stephen J. Barcavage, Esquire Attorney I.D. No. 78867 2000 Linglestown Road, Suite 303 Harrisburg, PA 17110 (717) 909-2500 JOSEPH ZUCATTI Plaintiff vs. SHIRLEY MAE STAMBAUGH, CIVIL ACTION - LAW Defendant ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Stephen J. Barcavage, Esquire, Matthew L. Owens, Esquire and the law firm of Owens Barcavage and McInroy, LLC. as counsel of record for IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 04-4347 Shirley Mae Stambaugh in the above-captioned matter. DATE: I L AA OWENS BARCAVAGE AND MCINROY, LLC. BY: DATE: BY: St6phen J. Barcavage, Esqurie ID# 78867 2000 Lingle/Pl oad, Suite Harrisburg, 7110 (717) 909-2 Matthew%-'Uw-ens, Esquire ID# 76080 2000 Linglestown Road, Suite 303 Harrisburg, PA 17110 (717) 909-2500 CERTIFICATE OF SERVICE We, Stephen J. Barcavage, Esquire and Matthew L. Owens, Esquire, do hereby certify that on this day of November, 2009, we served a copy of the foregoing document via First Class United States mail, postage prepaid as follows: William P. Douglas, Esquire Douglas Law Office 27 W. High Street Carlisle, PA 17013 . Barcavage, Esquire Matthew L. Owens, Esquire FLED-Ot FiCE OF THE PIROTH OTA?Y 2009 NOV 19 P ( '1 2: 4 3 P NN3UAI,nA PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in triplicate) n TO THE PROTHONOTARY OF CUMBERLAND COUNTY o Please list the following case: M F ?X for JURY trial at the next term of civil court. - its ? for trial without a jury. J>t ? co --------------------------------------------------------------------------------------------------- - CAPTION OF CASE' " (entire caption must be stated in full) (check one) . ?X Civil Action - Law CD El Appeal from arbitration C' J S e lok Z (other) (Plaintiff) VS. The trial list will be called on 3/30/2010 and 4/26/2010 i r- le ?r' -e- 1 Trials commence on te S T?; b ^ v . ' r `9 4/07/2010 (Defendant) Pretrials will be held on vs. (Briefs are due S days before pretrials No. 04-4437 •5/3 V 7 Term Indicate the attorney who will try case for the party who files this praecipe: Stephen J. Barcavage, Esquire Indicate trial counsel for other parties if known: William P. Douglas, Esquire This case is ready for trial. Signed: ' S phen J. Barcavage Print'Name:_. Date: 03/03/2010 r Attorney for: Defendant, Shirley M. Stambaugh ?s•oc? ?rC. Allf V -K4 /39/ t-47-- c0ft l6 i 7-3 JOSEPH ZUCATTI, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. SHIRLEY MAE STAMBAUGH, DEFENDANT 04-4347 CIVIL TERM IN RE: PRETRIAL CONFERENCE A pretrial conference was held on Wednesday, April 7, 2010. Present on behalf of the defendant was Stephen J. Barcavage, Esquire. Plaintiff's counsel William P. Douglas, Esquire, was unable to attend. This is a simple automobile accident case which should take no more than one day to try. It is an appeal from an arbitration in which the arbitrators' award was $7,500. The defense has offered $2,670. No evidentiary issues are anticipated. Although Mr. Douglas was not in attendance, he has informed the court that he us ready to proceed. By the Court, William P. Douglas, Esquire bert H. Masland, J. For Plaintiff 0 -, Stephen J. Barcavage, Esquire " For Defendant - .; Court Administrator -? - _ sal -p } C=:k Lea 7a JUL-16-2010 11:43 JOSEPI-I ZUCATTI, IN THE COURT OF COMMON PLEAS laintiff CUMBI:~RLAND COUNTY, PA vs. N0.04-4347 SHIR.LEY MAE ST AUGH, CAVIL ACTION -LAW fend~nt PRAECIPE TO AISCONTiIN[JE A,CT~ON TO THE PROTHON TARY: Please mark the above matter settled, ended, discontinued and costs paid. DATE: A BY: 1 William P. Douglas, ID# `3 ~ oZ~ Douglas Law Office 27 W. High Street Carlisle, PA 17013 P.03 n a _. ~. ~.7 E"~ ~-- '~ ..E.y .. _ ., ;.~ ~: ; .,,__ -~= i. :. - - ~ i~: ~,: ,~ r: ri~ :~: • • .~-- - c..:: TOTAL P.03