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Home My WebLink About11-8314 FOULKROD ELLIS Professional Corporation 4000 Market Street Camp Hill, Pennsylvania 17011 Telephone: (717) 909-7006 Fax: (717) 909-6955 FILED-OFFICE ,? . 1NE PROTHONOTARY 2011 DEC 21 PM 121-11 COUIey for Defendants, CUMBERLAND rt E. Wolf, M.D. and FENNsyVAN1kosmetic Surgery by Wolf, P.C. TRESSA JANIATI, V. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA ROBERT WOLF, M.D., COSMETIC SURGERY BY WOLF, P.C. t/d/b/a WATERSEDGE COMPREHENSIVE COSMETIC SURGERY, Defendants NO. 11-8314 CIVIL ACTION MEDICAL PROFESSIONAL LIABILITY ACTION JURY TRIAL DEMANDED 1. Failing to remove the Intranasal Doyle Splints for approximately twenty-two (22) months following Tressa Janiati's septoplasty surgery fell below the applicable reasonable standard of care. ADMITTED DENIED OBJECTION. Defendants object to the Request for Admission as the Request seeks an admission of a legal conclusion. The Request does not comply with Pa. R.C.P. 4014, which allows requests for admission only of the truth of matters "that relate to statements or opinions of fact or the application of law to fact." Respectfully submitted, FOULKROD ELLIS PROFESSIONAL CORPORATION Date: 0 ( By: 0'f I fA, Leig A.J. Ellis, Esquire Attorney I.D. No. 53229 leigh(&foulkrod.com Cindy N. Ellis, Esquire Attorney I.D. No. 83823 cindY foulkrod.com I HEREBY CERTIFY that a true and correct copy of the foregoing was served upon counsel of record this C;)-_J day of 2011, by depositing said copy in the United States Mail at Camp Hill, Pennsylvania, postage prepaid, first class delivery, and addressed as follows: Robin J. Marzella, Esquire R.J. Marzella & Associates, P.C. 3513 North Front Street Harrisburg, PA 17110-1438 Attorneys for Plaintiff FOULKROD ELLIS Professional Corporation J N Crystal 1 Nemetz, Secretary I' ILED-OFFICE FOULKROD ELLq THE PROTHONOTARY Professional Corporj DEC 27 Ph 206 4000 Market Street UU ii tt Camp Hill, Pennsylvania 7 Faxephon (71( ( 1909-66955 PENNS LVAK ATY TRESSA JANIATI, Plaintiff V. ROBERT WOLF, M.D., COSMETIC SURGERY BY WOLF, P.C. t/d/b/a WATERSEDGE COMPREHENSIVE Attorney for Defendants, Robert E. Wolf, M.D. and Cosmetic Surgery by Wolf, P.C. COSMETIC SURGERY, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 11-8314 CIVIL ACTION MEDICAL PROFESSIONAL LIABILITY ACTION JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO: PROTHONOTARY Kindly enter our appearance on behalf of Defendants, Robert E. Wolf, M.D. and Cosmetic Surgery by Wolf, P.C., with regard to the above-captioned action. Respectfully submitted, FOULKROD ELLIS PROFESSIONAL CORPORATION Date: 2 By: _jd Leigh A.J. s, Esquire Attorney I. . o. 53229 leighawfoul od.com Cindy N. Ellis, Esquire Attorney I.D. No. 83823 cindygfoulkrod.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served upon counsel of record this a3?1j day of J .c.??, 2011, by depositing said copy in the United States Mail at Camp Hill, Pennsylvania, postage prepaid, first class delivery, and addressed as follows: Robin J. Marzella, Esquire R.J. Marzella & Associates, P.C. 3513 North Front Street Harrisburg, PA 1711)-1438 Attorneys for Plaintiff FOULKROD ELLIS Professional Corporation Crystal . Nemetz, Secretary rI 'FILED-OFFICE OF THE PROTHONOTARY 2011 DEC 30 ISM I I ,-51 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 Telephone: (717) 234-7828 Facsimile: (717) 234-6883 CUMBERLAND COUNTY PENNSYLVANIA Attorneys for Plaintiff, Tressa Janiati IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Tressa Janiati Plaintiff Docket No. 11-8314 Civil Term Robert Wolf, M.D.; Cosmetic Surgery by Wolf, PC t/d/b/a WatersEDGE Comprehensive Cosmetic Surgery Defendants Civil action (x)Law ( )Equity V. Jury Trial Demanded REQUEST FOR ADMISSION DIRECTED TO ROBERT WOLF, M.D. SET TWO Plaintiff, Tress Janiati, serves upon Defendant, Robert Wolf, M.D., the following requests for admission within the scope of Pa.R.C.P. 4003.1 through 4003.5 and Pa.R.C.P. 4014(a). Defendant is directed to respond in accordance with the Rules of Civil Procedure. 1 r 1. Defendant Wolf failed to remove the Intranasal Doyle Splints for approximately twenty-two (22) months following Tressa Janiati's septoplasy surgery. ADMITTED DENIED 2. Defendant Wolf, as the attending physician, was solely responsible for ensuring the removal of the Intranasal Doyle Splints following Tressa Janiati's septoplasy surgery. ADMITTED DENIED 3. Defendant Wolf s failure to remove the Intranasal Doyle Splints for approximately twenty-two (22) months following Tressa Janiati's septoplasy surgery fell below the applicable standard of care in the Cumberland County medical community. ADMITTED DENIED Dated: Robit'j.'Srrzella, Esquire Attorney Identification No. 66856 2 CERTIFICATE OF SERVICE I, ,jacqulyn R. Harris, hereby certify that a true and correct copy of the foregoing Request for Admission Directed to Robert Wolf, M.D., Set Two, was served upon counsel of record this 28th day of December, 2011, by depositing said copy in the United States Mail at Harrisburg, Pennsylvania, postage prepaid, first class delivery, and addressed as follows: Leigh A j. Ellis, Esquire Foulkrod Ellis, P.C. 4000 Market Street Camp Hill, PA 17011 R. J. MARZELLA & ASSOCIATES, P.C. BY: A-A"I JA ULYN H I , LAW CLERK FOULKROD ELLIS Professional Corporation 4000 Market Street Camp Hill, Pennsylvania 17011 Telephone: (717) 909-7006 Fax: (717) 909-6955 LI 4 41I,? - Phi 12' Cl' Attorney for Defendants, ° Robert E. Wolf, M.D. and i, a ',?a Cosmetic Surgery by Wolf, P.C.' ? ? I-V0 TRESSA JANIATI, : Plaintiff V. : ROBERT WOLF, M.D., COSMETIC SURGERY BY WOLF, P.C. t/d/b/a WATERSEDGE COMPREHENSIVE COSMETIC SURGERY, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 11-8314 CIVIL ACTION MEDICAL PROFESSIONAL LIABILITY ACTION JURY TRIAL DEMANDED - OBJECTIONS AND ANSWERS OF DEFENDANTS, 1 ER.T E. WOLF, Mb: A COSM1E?"IC SURO1?RV by W?'?, Px., TO'PLAlC1 MIF" `REQU"T FORA 1, 3M' Sl(l?`I''2 1. Defendant Wolf failed to remove the Intranasal Doyle Splints for approximately twenty-two (22) months following Tressa Janiati's septoplasty surgery. ADMITTED DENIED Admitted. 2. Defendant Wolf, as the attending physician, was solely responsible for ensuring the removal of the Intranal Doyle Splints following Tressa Janiati's septoplasty surger. ADMITTED DENIED OBJECTION. Defendants object to the Request for Admission as the Request seeks an admission of a legal conclusion. The Request does not comply with Pa. R.C.P. 4014, which allows requests for admission only of the truth of matters "that relate to statements or opinions of fact or the application of law to fact." 3. Defendant Wolf s failure to remove the Intranasal Doyle Splints for approximately twenty-two (22) months following Tressa Janiati's septoplasty surgery fell below the applicable standard of care in the Cumberland County medical community. ADMITTED DENIED OBJECTION. Defendants object to the Request for Admission as the Request seeks an admission of a legal conclusion. The Request does not comply with Pa. R.C.P. 4014, which allows requests for admission only of the truth of matters "that relate to statements or opinions of fact or the application of law to fact." Respectfully submitted, FOULKROD ELLIS PROFESSIONAL CORPORATION Date: By: T Leigh A.J. Ellis, Esquire Attorney I.D. No. 53229 leighAfoulkrod.com Cindy N. Ellis, Esquire Attorney I.D. No. 83823 cindy(a- foulkrod. com CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served upon counsel of record this day of 2012, by depositing said copy in the United States Mail at Camp Hill, Pennsylv,nia, postage prepaid, first class delivery, and addressed as follows: Robin J. Marzella, Esquire R.J. Marzella & Associates, P.C. 3513 North Front Street Harrisburg, PA 17110-1438 Attorneys for Plaintiff FOULKROD ELLIS Professional Corporation &Ih-? ) JI-S,?, Cryst 1 L. Nemetz, Secre y R.J. MARZELLA & ASSOCIATES, P.C. BY: Robin J. Marzella, Esquire n ` Pennsylvania Supreme Court I.D. No. 66856' 3513 North Front Street i ?} E_RLAil"") COUN i `'` Harrisburg, PA. 17110 ;' L H` N S Y &`i, A t,l I A Email: rarzella@rjmarzella.com Attorneys for Plaintiffs Telephone: (717) 234-7828 Tressa Janati FacsiWile: (717) 234-6883 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Tressa Janiati Plaintiff Docket No. 11-8314 Civil Term Civil action (x)Law ( )Equity V. Robert Wolf, M.D.; Cosmetic Surgery by Wolf, PC t/d/b/a WatersEDGE Comprehensive Cosmetic Surgery Defendants Jury Trial Demanded PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY, CUMBERLAND COUNTY: Please mark the above-referenced action settled and discontinued as to all Defendants. Date: Respectfully submitted, R.J. a & Associates, P.C. Robin J. Mar a, Esquire Attorney I cation No. 66856 1 CERTIFICATE OF SERVICE I, Jacqulyn R. Harris, hereby certify that a true and correct copy of the foregoing Praecipe to Discontinue was served upon counsel of record this 30th day of May, 2012, by depositing said copy in the United States Mail at Harrisburg, Pennsylvania, postage prepaid, first class delivery, and addressed as follows: Leigh A j. Ellis, Esquire Foulkrod Ellis, P.C. 4000 Market Street Camp Hill, PA 17011 R. J. MARZELLA & ASSOCIATES, P.C. BY: 4eq?' , LAW CLERK