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Home My WebLink About11-77491- b. n i E OCT 13 Ali 9: 1 R. J. MARZELLA & ASSOCIATES, P.C. r" , e C k ? BY: Robin J. Marzella, Esquire rEN1`4SYL V,` tN11 Pennsylvania Supreme Court I.D. No. 66856 3513 North Front Street Harrisburg, PA 17110 Attorneys for Plaintiff, Telephone: (717) 234-7828 Helen Lefevre Facsimile: (717) 234-6883 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Helen Lefevre Plaintiff Docket No. //- -77y9 e1_111Z V. DaVita, Inc. d/b/a Renal Treatment Centers - Northeast, Inc. a/k/a DaVita - Berwyn, PA d/b/a Camp Hill Dialysis Center; DaVita Nephrology Medical Associates of Pennsylvania, P.C.; Mohamed Elnour, M.D.; Heather Blosser; Colleen Mirin; and Beverly Blatnik Defendants JURY TRIAL DEMANDED PRAECPIE TO ISSUE WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue Writ of Summons in the above-captioned action. 6 Writ of Summons shall be issued and forwarded to ( ) Attorney (X) Sheriff _Robin 1. Marzella. Esquire 3513 North Front Street Harrisburg, PA 17110 (717) 234-7828 Names/Address/Telephone No. of Attorney Signature o rney Supreme Court ID No. 856 Date: p 9A, oo)OV R# C*s463 R. J. MARZELLA & ASSOCIATES, P.C. BY: Robin J. Marzella, Esquire Pennsylvania Supreme Court I.D. No. 66856 3513 North Front Street Harrisburg, PA 17110 Attorneys for Plaintiff, Telephone: (717) 234-7828 Helen Lefevre Facsimile: (717) 234-6883 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Helen Lefevre Plaintiff V. DaVita, Inc. d/b/a Renal Treatment Centers - Northeast, Inc. a/Wa DaVita - Berwyn, PA d/b/a Camp Hill Dialysis Center; DaVita Nephrology Medical Associates of Pennsylvania, P.C.; Mohamed Elnour, M.D.; Heather Blosser; Colleen Mirin; and Beverly Blatnik Defendants Docket No. // / 7 f 1 &o.? JURY TRIAL DEMANDED WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANTS): ?QV?• MC. OW o(fhe ac+ (OC ai t - '?oc? n PA d /a ?d %/ Dr?9 ?Yais Al. r) n few 1/0-cgot/ r 19 YOU ARE NOTIFIED THATTHE ABOVE-NAMED PLAINTIFF(S) S HAS/1-IAVE COMMENC1'D ?J APN ACTION AGAINST YOU. ry Date: 10// ' /4 by Deputy 07. ( ) Check here if reverse is used for additional information R. J. MARZELLA & ASSOCIATES, P.C. BY: Robin J. Marzella, Esquire Pennsylvania Supreme Court I.D. No. 66856 3513 North Front Street Harrisburg, PA 17110 Attorneys for Plaintiff, Telephone: (717) 234-7828 Helen Lefevre Facsimile: (717) 234-6883 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Helen Lefevre Plaintiff Docket No. 777' 9 `'' L( L V. DaVita, Inc. d/b/a Renal Treatment Centers - Northeast, Inc. a/k/a DaVita - Berwyn, PA d/b/a Camp Hill Dialysis Center; DaVita Nephrology Medical Associates of Pennsylvania, P.C.; Mohamed Elnour, M.D.; Heather Blosser; Colleen Mirin; and Beverly Blatnik Defendants JURY TRIAL DEMANDED SHERIFF'S DIRECTIONS Please serve the Writ of Summons in the above-captioned action, issued 41 by the Prothonotary of Cumberland County upon the Defendant, DaVita, Inc. d/b/a Renal Treatment Centers - Northeast, Inc. a/Wa DaVita - Berwyn, PA d/b/a Camp Hill Dialysis Center, at the business address located at 425 N 21" Street, Plaza 21 Building, 1S` Floor, Camp Hill, Pennsylvania 17011, by personally handing a copy of the same to the manager, clerk, or other adult individual for the time being in charge of the business or activity of the business. 2. Please serve the Writ of Summons in the above-captioned action, issued by the Prothonotary of Cumberland County upon the Defendant, DaVita Nephrology Medical Associates of Pennsylvania, P.C., at the business address located at 60 Blacksmith Road, Newtown, Pennsylvania 18940, by personally handing a copy of the same to the manager, clerk, or other adult individual for the time being in charge of the business or activity of the business. 3. Please serve the Writ of Summons in the above-captioned action, issued by the Prothonotary of Cumberland County upon the Defendant, Mohamed Elnour, M.D., at the business address located at 425 N 21St Street, Plaza 21 Building, 1St Floor, Camp Hill, Pennsylvania 17011, by personally handing a copy of the same to the manager, clerk, or other adult individual for the time being in charge of the business or activity of the business. 4. Please serve the Writ of Summons in the above-captioned action, issued by the Prothonotary of Cumberland County upon the Defendant, Heather Blosser, at the business address located at 425 N 21St Street, Vt Floor, Plaza 21 Building, Camp Hill, Pennsylvania 17011, by personally handing a copy of the same to the manager, clerk, or other adult individual for the time being in charge of the business or activity of the business. Please serve the Writ of Summons in the above-captioned action, issued by the Prothonotary of Cumberland County upon the Defendant, Colleen Mirin, at the business address located at 425 N 21St Street, 1St Floor, Plaza 21 Building, Camp Hill, Pennsylvania 17011, by personally handing a copy of the same to the manager, clerk, or other adult individual for the time being in charge of the business or activity of the business. 6. Please serve the Writ of Summons in the above-captioned action, issued by the Prothonotary of Cumberland County upon the Defendant, Beverly Blatnik, at the business address located at 425 N 21St Street, Plaza 21 Building, 1St Floor, Camp Hill, Pennsylvania 17011, by personally handing a copy of the same to the manager, clerk, or other adult individual for the time being in charge of the business or activity of the business. Respectfully submitted, DATED: /V V,2 -l AMARZEL AsTES, P.C. B LLA., ESQUIRE ID No. 66856 L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Helen Lefevre, Plaintiff Docket No. 11-7749 Civil Term rnrn -C z tom' ' "3;1 c c z JURY TRIAL DEMANDED r 0 0 --s rn C:) -n C:) -n v ? N v. DaVita, Inc. d/b/a Renal Treatment Centers - Northeast, Inc. a/k/a DaVita - Berwyn, PA d/b/a Camp Hill Dialysis Center; DaVita Nephrology Medical Associates of Pennsylvania, P.C.; Mohamed Elnour, M.D.; Heather Blosser; Colleen Mirin; and Beverly Blatnik, Defendants ENTRY OF APPEARANCE Kindly enter the appearance of Karen E. Minehan, Esquire, as counsel for Defendants Renal Treatment Centers-Northeast, Inc. d/b/a Camp Hill Dialysis Center -v N w (incorrectly named as DaVita,Inc. d/b/a Renal Treatment Centers - Northeast, Inc. a/k/a DaVita - Berwyn, PA d/b/a Camp Hill Dialysis Center), DaVita Nephrology Medical Associates of Pennsylvania, P.C., Mohamed Elnour, M.D., Heather Blosser, Colleen Mirin, and Beverly Blatnik in the above-captioned matter. All papers should be served at 17 North Second Street, 16th Floor, f larrisburg, Pennsylvania 17101. Dated: November 9, 2011 STEVENS & LEE, P.C. By )&0 n Karen E. Min?ehn, Esquire Attorney I.D. No. 78050 17 North Second Street, 16th Floor Harrisburg, PA 17101 Phone: (717) 255-7376 Fax: (610) 371-7744 Email: kem@stevenslee.com SL1 1110582N 1 103320.00009 CERTIFICATE OF SERVICE I certify that on this date, I served a certified true and correct copy of the foregoing Entry of Appearance upon the following counsel of record, by depositing the same in the United States mail, postage prepaid, addressed as follows: Robin J. Marzella, Esquire 3513 North Front Street Harrisburg, PA 17110 Counsel for Plaintiff Date: November 9, 2011 SL1 1110582- 1103320.00009 ?;- E r.?0MONO TART IN THE COURT OF COMMON PLEAS ??? ? ??? ?? ?? ???? OF CUMBERLAND COUNTY, PENNSYLVANIA CUMBERLAND COUNTY Helen Lefevre, PENNSYLVANIA Plaintiff ; Docket No. 11-7749 Civil Term V. DaVita. Inc. d/b/a Renal "Treatment Centers - Northeast. Inc. a/k/a DaVita Berwyn, PA dlb/a Camp Hill Dialysis Center; DaVita Nephrology Medical Associates of Pennsylvania, P.C.; Mohamed Elnour, M.D., Heather Blosser; Colleen JURY TRIAL DEMANDED Mirin; and Beverly Blatnik, Defendants STIPULATION TO DISCONTINUE CLAIMS AGAINSTLESS THAN ALL DEFENDANTS AND TO AMEND CAPTION All named parties, individually or by and through their counsel, hereby stipulate and agree to the following: 1. The dialysis facility located at 425 North 21 "' Street, Camp Hill, PA where I leten Lefevre received dialysis care and treatment on October 15. 2009 is properly named as "Renal Treatment Centers-Northeast, Inc. d/b/a Camp Hill Dialysis Center.- 2. All parties agree and stipulate to amend the caption such that *'Renal Treatment Centers-Northeast, Inc. d/b/a Camp Hill Dialysis Center" is substituted for "Defendant DaVita, Inc. d/b/a Renal Treatment Centers Northeast. Inc. a/k/a DaVita - Berwyn, PA d/b/a Camp Hill Dialysis Center." 3. As more fully set forth in the Affidavit of Noninvolvement dated December 22, 201 1, Mohamed Elnour, M.D. did not provide any medical care or treatment to Plaintiff Helen Lefevre on October 15, 2009. 51, I I I I 1856N, 1103320.00009 4. All parties agree and stipulate to voluntarily discontinue all claims against Defendants DaVita Nephrology Medical Associates of Pennsylvania, P.C., Mohamed Elnour, M.D., Heather Blosser, Colleen Mirin, and Beverly Blatnik pursuant to Rule of Civil Procedure 229(b)(1). 5. All parties agree and stipulate that the discontinuance of all claims against Defendants 1-leather Blosser. Colleen Mirin, and Beverly Blatnik will not result in the discontinuance of any potential agency claims against Defendant Renal "Treatment Centers- Northeast, Inc. d/b/a Camp Hill Dialysis Center arising out of their alleged actions or omissions. 6. All parties stipulate that the caption should be amended as follows: Helen Lefevre, Plaintiff v. Renal Treatment Centers-Northeast, Inc. d/b/a Camp I fill Dialysis Center, Defendant 7. The Stipulation may be executed in counterparts and shall be considered effective when signed by all counsel even though signed on separate signature pages. 8. All counsel certify that they have authorization to execute the Stipulation on behalf of their respective clients and that they authorize the tiling of any non-original, facsimile or other copy of the present Stipulation. See Pa.Rule CIv.P. 205.3. 9. The parties, individually and/or by their respective counsel, have caused this Stipulation to be executed and intend to be legally bound thereby. Dated: DecemberP, 2011 STEVENS & LEE. P.C. By Karen E%inchan, Esquire Attorney LD. No. 78050 17 North Second Street, 16'h Floor Harrisburg, PA 17101 Phone: (717) 255-7384 2 SI 11 11 1856v 1 103320.00009 Fax: (610) 371-7744 Email: kem@stevenslee.com Dated: December 2011 By: R.J. MARZELLA & ASSOCIATES. P.C. Robin J. a, Esquire 3513 North Front Street Harrisburg, PA 17110 Counsel for Plaintiff SL I 1111856v t 103320,00009 CERTIFICATE OF SERVICE I certify that on this date. 1 served a certified true and correct copy of the foregoing Stipulation upon the following counsel of record, by depositing the same in the United States mail, postage prepaid, addressed as follows: Robin J. Marzella, Esquire 3 513 North Front Street Harrisburg, PA 17110 Counsel for Plaintiff Date: ? -)q aAD , ,')),I 1 11 1856e 1 103320.00009 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Helen Lefevre, Plaintiff V. DaVita, Inc. d/b/a Renal Treatment Centers - Northeast, Inc. a/k/a DaVita - Berwyn, PA d/b/a Camp Hill Dialysis Center; DaVita Nephrology Medical Associates of Pennsylvania, P.C.; Mohamed Elnour, M.D.; Heather Blosser; Colleen Mirin; and Beverly Blatnik, Docket No. 11-7749 Civil Term JURY TRIAL DEMANDED Defendants : AND NOW, this 3 " day of 6C46(A4* 2018 it is hereby ORDERED and DECREED that the caption is amended to read as follows: Helen Lefevre, Plaintiff V. Renal Treatment Centers-Northeast, Inc. d/b/a Camp Hill Dialysis Center, Defendant BY THE COURT: J. Rule 236 Notice: i? Karen E. Minehan, Esquire 17 North Second Street, 16th Floor Harrisburg, PA 17101 -? Phone: (717) 255-7376 Fax: 610 371-7744 rn3 rn cu L- rn-r- Email: kem@stevenslee.com Counsel for Defendants CD Robin J. Marzella Esquire , 3513 North Front Street ;; Harrisburg, PA 17110 s} Phone: (717) 234-7828 Fax: (717) 234-6883 Email: RMarzella@rjmarzella.com Counsel for Plaintiff SL I 1111856v 1 103320.00009 C v ,CS Ana. ??'d ' 1 jl/a I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Helen Lefevre, Plaintiff Docket No. 11-7749 Civil Term V. DaVita, Inc. d/b/a Renal Treatment Centers - Northeast, Inc. a/k/a DaVita - Berwyn, PA d/b/a Camp Hill Dialysis Center; DaVita Nephrology Medical Associates of Pennsylvania, P.C.; Mohamed Elnour, M.D.; Heather Blosser; Colleen JURY TRIAL DEMANDED Mirin; and Beverly Blatnik, Defendants SUGGESTION OF DEATH Kindly note that Plaintiff Helen Lefevre died on May 14, 2012. Dated: June 13, 2012 Respectfully submitted, STEVENS & LEE, P.C. ! p flalS7' 1 P.$ ?. 8Ei'% LAND C0UNT`' P'?N111S` LV! -!I"^, By (X ?, A t Karen E. Minehan, Esquire Attorney I.D. No. 78050 17 North Second Street, 16'' Floor Harrisburg, PA 17101 Phone: (717) 255-7376 Fax: (610) 371-7744 Email: kem@stevenslee.com SL I 1172670v l 103320.00009 CERTIFICATE OF SERVICE I, Karen E. Minehan, Esquire, certify that on this date, I served a certified true and correct copy of the foregoing Suggestion of Death upon the following counsel of record, by depositing the same in the United States mail, postage prepaid, addressed as follows: Robin J. Marzella, Esquire 3513 North Front Street Harrisburg, PA 17110 Counsel for Plaintiff Date: June 13, 2012 SL I 1172670v 1 103320.00009 POTHONOTA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2012 AUG 2 3 PH 2: 3 2 "UMBERLAND COUNTY Helen Lefevre, PENNSYLVANIA Plaintiff Docket No. 11-7749 Civil Term V. DaVita, Inc. d/b/a Renal Treatment Centers-' Northeast, Inc. a/k/a DaVita - Berwyn, PA d/b/a Camp Hill Dialysis Center; I@Vita Nephrology Medical Associates of Pennsylvania, P.C.; Mohamed Elnour, M.D.; Heather Blosser; Colleen JURY TRIAL DEMANDED Mirin; and Beverly Blatnik, Defendants PRAECIPE FOR RULE TO FILE COMPLAINT TO THE! PROTHONOTARY: Kindly enter a Rule upon the Plaintiff Helen Lefevre to file a Complaint in the present rihatter within twenty (20) days after service of said Rule or suffer a judgment of non pros. STEVENS & LEE, P.C. By rU,?,M Karen E. Minehan, squire Attorney I.D. No. 78050 17 North Second Street, 16th Floor Harrisburg, PA 17101 Phone: (717) 255-7384 Fax: (610) 371-7744 Email: kem@stevenslee.com Date: August 22, 2012 SL I 1187166v 1 103320.00009 CERTIFICATE OF SERVICE I, Karen E. Minehan, Esquire, certify that on this date, I served a certified true and correct copy of the foregoing documen upon the following counsel of record, by depositing the same in the United States mail, postage prepaid, addressed as follows: Robin J. Marzella, Esquire 3513 North Front Street Harrisburg, PA 17110 Counsel for Plaintiff Date: Alagust 22, 2012 SL I 1187166v l 103320.00009 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Helen Lefevre, Plaintiff Docket No. 11-7749 Civil Term V. DaVita, Ilnc. d/b/a Renal Treatment Centers - Northeast, Inc. a/k/a DaVita - Berwyn, PA d/b/a Camp Hill Dialysis Center; paVita Nephrology Medical Associates of Pennsylvania, P.C.; Mohamed Elnour, M.D.; Heather Blosser; Colleen JURY TRIAL DEMANDED Mirin; and Beverly Blatnik, Defendants RULE TO FILE COMPLAINT AND NOW, this o?Q day of August, 2012, a Rule has been entered upon Plaintiff Helen Lefevre to file a complaint within twenty (20) days after service of the Rule or suffer a judgment of non pros. -,h.- David D. Buell, Prothonotary SL I 1187166v 1 103320.00009