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Home My WebLink About11-9401Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS Court of Common Pleas Robert M. Shank, Individually and as Administrator of the Estate of Cynthia Ann Shank, Deceased Plaintiff Vs. No. 2011-9401 Manor Care of Carlisle PA, LLC d/b/a Manor Care Health Services, Carlisle 940 Walnut Bottom Rood Carlisle, PA 17013 And HCR Manor Care Inc. Manorcare, Inc.; HCR Healthcare, LLC; HCR II Healthcare, LLC; HC III Healthcare, LLC; 333 North Summit Street Toledo, OH 43604 And HCR IV Healthcare, L1LC 333 North Summit Street Toledo, OH 43604 In CivilAction-Law To: Manor Care of Carlisle PA, LLC d/b/a Manor Care Health Services, Carlisle; HCR Manor Care Inc.; Manoicare, Inc.; HCR Healthcare, LLC; HCR II Healthcare, LLC; HCR III Healthcare, LLC; HCR IV Healthcare, LLC You are hereby notified that the Plaintiff, Robert M. Shank, Individually and as Administrator of the Estate of Cynthia Ann Shank, Deceased, has commenced an action in Civil Action-Law ag'4inst you which you are required to defend or a default judgment may be entered against YOU. (SEAL) Da ' d uell, Prothonotary Date 12-27-i 1 By Deputy Attorney: Chad P. Shannon, Esquire Address: ROBERT PEIRCE & ASSOCIATES, P.C., 2500 Gulf Tower, 707 Grant St., Pittsburgh, PA 15219 Attorney for: Plaintiff Telephone: 412-281-729 Supreme Court ID No. 1212 r1 FILED-OFFICE TJJE PROTHONOTARY N I I DEC 21 AM 10" 54 CUMBERLAND WWTY PENNSY001A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Civil Division i ROBERT M. SHANK, I dividually and as ADMINISTRATOR OF HE ESTATE OF CYNTHIA ANN SHANK, DECEASED Plaintiff, No. - clot 0('vtc Code: PRAECIPE FOR WRIT OF SUMMONS VS. Filed on behalf of: Plaintiff, Robert M. MANOR CARE OF CARLISLE PA, LLC d/b/a Shank, Individually and as Administrator MANOR CARE HEALTH SERVICES, of the Estate of Cynthia M. Shank, CARLISLE; j Deceased HCR MANOR CARE, INC.; MANORCARE, INC.; HCR HEALTHCARE, LL(; HCR II HEALTHCARE, I? LC; HCR III HEALTHCARE, LLC; HCR IV HEALTHCARE, ?LLC; Defendants Counsel of Record for this Party: ROBERT F. DALEY, ESQUIRE Pa. I.D. No.: 81992 CHAD P. SHANNON, ESQUIRE Pa. I.D. No.: 91212 MAX PETRUNYA, ESQUIRE Pa. I.D. No.: 309122 ROBERT PEIRCE & ASSOCIATES, P.C. Firm I.D. 839 2500 Gulf Tower, 707 Grant Street Pittsburgh, PA 15219 (412) 281-7229 ?gga.ao QM e k'# V11 p1* 408g2t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Civil Division ROBERT M. SHANK, I dividually and as ADMINISTRATOR OF HE ESTATE OF CYNTHIA ANN SHANK, ECEASED Plaintiff, vs. MANOR CARE OF CARL SLE PA, LLC d/b/a MANOR CARE HEA TH SERVICES, CARLISLE; HCR MANOR CARE, INC4; MANORCARE, INC.; i HCR HEALTHCARE, LL(; i HCR 11 HEALTHCARE, LLC; HCR III HEALTHCARE, I LC; HCR IV HEALTHCARE, Defendants To: The Prothonotary No. 1 -I Please issue a Writ f Summons in the above-captioned matter. i Respectfully submitted, ROBERT PEIRCE & ASSOCIATES, P.C. r, By: CHA P. SHANNON, ESQUIRE Counsel for Plaintiff 12/27/2011 11:52AM FAX 4122814229 RCHFT °EIRCE ? ASSOC. ? 1 \ T 7'l;Tl., r1 CUUItT I F (() COMMON PLEAS OF f C i]MBl•.Ri.ANU C,UIJNTY, PENNS'YL'VANIA Civil Division 1A0005/000b ROBERT M. SHANK, I dividually and as ADMINISTRATOR OF 'TIE ESTATE OP No. CYNTIIIA ANN SHANK, bECRASED Code: Plaintiff; PRAECIPE FOR WRIT OF SUMMONS vs. I MANOR APA, LLC d/b/a MANOR CARE HEALTH SERVICES, CARLISLE; 940 Walnu Ilottom Road Carlisle, PA 17013 HCR MAl OR CARE, iNO,; 333 North ?unnrnit Street Toledo, OF[ 43604 MANORCARE, INC.; 333 North ununit Street Toledo, 01 43604 HCR HEALTHCARE, L4C; 333 North ,summit Street `I'otedo, 01-1 143604 14CR 11 HUALTHCAR , PLC; 333 North 'iummit Street Toledo, OI 43604 Filed on behalf of: Plaintiff, Robert M. Shank, Individually and as Administrator of the Estate of Cynthia . M. Shank, Deceased Counsel of Record for this Partv: ROBERT 1`. DALLY, ESQ JIltl Pa. I.D. No.: 81992 CHAD P. SHANNON, ESQUIRI? Pa. T.D. No.: 91212 MAX PETRUNYA, ESQUIRE Pa. I.D. No.: 309122 ROBER"1' PE1RCE &c ASSOCIATES, P.C. Firm I.D. 839 2500 Gull"lower, 707 Grant Street Pittsburgh, PA 15219 (412) 281-7229 12/27/2011 11:52AM FAX 4122014229 ^^BEP' °E?RCE ° ASSOC. ?. HCR 11111 RALTHCARL, L LC; 333 North Summit Street Toledo, U ? 43604 HCR IV HEALTHCARE, II LC; 333 North Summit Street Toledo, 01,143604 IM000610006 Defendants. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson Sheriff 'I?;(l?C 'HE Jody S Smith Chief Deputy 2012 JAN 20 AM 8: 2 Richard W Stewart Solicitor CUMBERLAND CO'UN ' PENNSYLVANIA Robert M. Shank Case Number vs. 2011-9401 Manor Care of Carlisle PA LLC SHERIFF'S RETURN OF SERVICE 01/13/2012 01:00 PM - William Cline, Corporal, who being duly sworn according to law, states that on January 12, 2012 at 1300 hours, he served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Manor Care of Carlisle, PA, LLC d/b/a Manor Care Health Services, Carlisle, by making known unto Dan Fessler, Administrator for ManorCare Health Services at 940 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to him personally the said true and correct copy of the same. r ILLIAM CLINE, DEPUTY SHERIFF COST: $34.00 January 17, 2012 SO ANSWERS, R-01 \10'e' ANDERSON, SHERIFF Court?,Suite Shenl Te?.eesoft. I ?c. BURNS WHITE LLC BY: William J. Mundy Identification No. 57679 By: John M. Skrocki Identification No. 49071 100 Four Falls, Suite 515 1001 Conshohocken State Road West Conshohocken, PA 19428 (484) 567-5700 Robert M. Shank, Individually and as Administrator of the Estate of Cynthia Ann Shank, Deceased Plaintiff VS. Manor Care of Carlisle PA, LLC d/b/a Manor Care Health Services, Carlisle, HCR Manor Care Inc, Manorcare, Inc., HCR Healthcare, LLC HCR II Healthcare, LLC, HCR II Healthcare, LLC, HCR III Healthcare, LLC and HCR IV Healthcare, LLC Defendants. Attorneys for Defendants, Manor Care of Carlisle PA, LLC d/b/a Manor Care Health Services, Carlisle, HCR Manor Care Inc., Manorcare, Inc., HCR Healthcare, LLC, HCR II Healthcare, LLC, HCR III Healthcare, LLC and HCR IV Healthcare, LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY C 11- 9401 ? -- zrn NO-49 (zryr??-- co :: ? ? u ; ° C-) C:) JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter our appearance as attorneys for defendants Manor Care of Carlisle PA, LLC d/b/a Manor Care Health Services, Carlisle, HCR Manor Care Inc., Manorcare, Inc., HCR Healthcare. LLC, HCR II Healthcare, LLC, HCR III Healthcare, LLC and HCR IV Healthcare, LLC, in the above matter. BURNS WHITE LLC WILLI J. M Y JOHN V. SKROCKI Attorneys for Defendants, Attorneys for Defendants, Manor Care of Carlisle PA, LLC d/b/a Manor Care Health Services, Carlisle, HCR Manor Care Inc., Manorcare, Inc., HCR Healthcare, LLC, HCR II Healthcare, LLC, Dated: a .? HCR III Healthcare, LL C and HCR IV Healthcare, LLC CERTIFICATE OF SERVICE I, John M. Skrocki, Esquire, hereby certify that on this date, a true and correct copy of the foregoing Entry of Appearance was delivered by United States First-Class Mail, postage prepaid, as follows: Chad P. Shannon, Esquire Robert Pierce & Associates, P.C. 2500 Gulf Tower, 707 Grant Street Pittsburg PA 15219 Plaintiff's counsel Dated: / 1 r 2 i F ILEo'-O F ICE OF i"HE PROTHONOTAfj•;, 2013 SEP 26 PPS 1: 29 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Civil Division ROBERT M. SHANK, Individually and as ADMINISTRATOR OF THE ESTATE OF No. 2011 - 9401 CYNTHIA ANN SHANK, DECEASED Code: Plaintiff, PRAECIPE TO SETTLE AND vs. DISCONTINUE MANOR CARE OF CARLISLE PA, LLC d/b/a Filed on behalf of: Plaintiff, Robert M. MANOR CARE HEALTH SERVICES, Shank, Individually and as Administrator CARLISLE; HCR MANOR CARE, INC.; of the Estate of Cynthia M. Shank, MANORCARE, INC.; HCR HEALTHCARE, Deceased LLC; HCR II HEALTHCARE, LLC; HCR III HEALTHCARE, LLC; HCR IV HEALTHCARE, LLC; Counsel of Record for this Party: Defendants. ROBERT F. DALEY, ESQUIRE Pa. I.D. No.: 81992 CHAD P. SHANNON, ESQUIRE Pa. I.D. No.: 91212 MAX PETRUNYA, ESQUIRE Pa. I.D. No.: 309122 ROBERT PEIRCE & ASSOCIATES, P.C. Firm I.D. 839 2500 Gulf Tower, 707 Grant Street Pittsburgh, PA 15219 (412) 281-7229 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Civil Division ROBERT M. SHANK, Individually and as ADMINISTRATOR OF THE ESTATE OF CYNTHIA ANN SHANK, DECEASED Plaintiff, No. 2011 - 9401 vs. MANOR CARE OF CARLISLE PA, LLC d/b/a MANOR CARE HEALTH SERVICES, CARLISLE, et al., Defendants. PRAECIPE TO SETTLE AND DISCONTINUE TO: THE PROTHONOTARY: Please settle and discontinue the above-captioned case and mark it off the docket, or satisfy Verdict, Award or Judgment. ATTORNEY FOR PLAINTIFF ( X) Attorney for Plaintiff ( ) Attorney for Defendant ( ) Attorney for Crossclaim ( ) Sheriff Due ( ) Secretary of Commonwealth ( ) Sheriff Mileage ( X) Prothonotary S&D with Issue Costs ( ) County Verdict ( ) Orders ( ) Awards from Arbitration ( ) Certificate ( ) Equity ( ) Case & Counterclaim or Crossclaim ( ) Plaintiff s Bill ( ) Witness Bill ( ) Judgment on Verdict ( ) M.L. ( ) D.S.B. ( ) Execution-Sat. or S&D ( ) Garnishes Fee DATE: PRO. COSTS: rd Sworn to and subscribed before me this c 3 day of , 2013. COwONNfEALTH OF PEI NMVAMA NOTARIAL SEAL NOTARY VBLIC ASHLEIGH 0 DUDLEY 6 No"pum CITY OF pITT9VjW,ALLEGHEW COMITY of Conn MWR Expim Fib 18,2014 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Civil Division ROBERT M. SHANK, Individually and as ADMINISTRATOR OF THE ESTATE OF CYNTHIA ANN SHANK, DECEASED Plaintiff, No. 2011 - 9401 vs. MANOR CARE OF CARLISLE PA, LLC d/b/a MANOR CARE HEALTH SERVICES, CARLISLE, et al., Defendants. CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Praecipe to Settle and Discontinue was served by first class United States mail, postage prepaid, upon counsel for the Defendants, addressed as follows: John M. Skrocki, Esquire Burns White Suite 515 100 Four Falls 1001 West Conshohocken State Road West Conshohocken, PA 19428 Respectfully submitted, ROBERT PEIRCE &ASSOCIATES, P.C. By: 0 CHA . SHANNON, ESQUIRE Counsel for Plaintiff