Loading...
HomeMy WebLinkAbout04-48421N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant CIVIL ACTION - LAW EX PARTE ORDER ALLOWING DEPOSITIONS IN PENNSYLVANIA RELATING TO AN ACTION PENDING IN ANOTHER STATE AND NOW, this dayofSeptember, 2004, Plaintiff having filed an Ex Parte Petition regarding an action pending in the Circuit Court of Oregon for the County of Clackamas requesting an Order compelling the attendance of Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Karen Ferree, Terry Ferree, Kathy Ferree and Wendy Harris for deposition and/or production of documents, and this Court having duly considered Plaintiff's Petition, and being fully advised in the premises; IT IS HEREBY ORDERED that the Ex Parte Petition For An Order To Take Depositions In Pennsylvania Relating To An Action Pending in Another State is hereby granted, and that Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Karen Ferree, Terry Ferree, Kathy Ferree and Wendy Harris shall appear for deposition in accordance with the Oregon Court Rules, and shall produce any documents requested, on Monday, October 4, 2004, at 9:00 a.m. at the Holiday Inn West, 5401 Carlisle Pike, Mechanicsburg, Pennsylwmia. IT IS FURTHER ORDERED that a copy of this Order, the Petition, the Deposition Notice, and the statutory witness fee shall be served upon the deponents, in accordance with Pennsylvania Court Rules. By the Court 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff CIVIL ACTION - LAW 2. During the discovery process, the Plaintiff has learned that Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Karen Ferree, Terry Ferree, Kathy Ferree and Wendy Harris possess information regarding the claims at issue in the Oregon action which is either relevant or will lead to the discovery of relevant information. The information sought by Plaintiff is vital to the complete disposition of the Plaintiff's interests in the Oregon action in which a trial is scheduled on November 4, 2004. 3. Pursuant to Pennsylvania statute, 42 Pa.C.S. §5326, and Pa. R.C.P. 4007.1 regarding STEPHANIE LYNN CORNWALL, Defendant EX PARTE PETITION FOR AN ORDER TO TAKE DEPOSITIONS IN PENNSYLVANIA RELATING TO AN ACTION PENDING IN ANOTHER STATE Plaintiff, George Mackie Cornwall, III, by and through his attorneys, Hanft & Knight, P.C., and Steven Allen Smith, P.C., in accordance with Pa. R.C.P. 4007.1 (f) and 42 Pa. C.S. §5326 hereby petitions your Honorable Court to enter an Order compelling t!q~e attendance of Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Karen Ferree, Terry Farree, Kathy Ferree and Wendy Harris for deposition, and in support thereof asserts the following: 1. George Mackie Cornwall, III, is Plaintiff in a divorce and custody action pending in the Circuit Court of Oregon for the County of Clackamas, Family Law Department, No. DK03- 03721. A copy of the Commission from the Circuit Court of Oregon is attached hereto as Exhibit the conduct and use of depositions, Plaintiff seeks to take the deposition of the persons named above. 4. 42 Pa. C.S.A. §5326(a) provides in pertinent part: A court of record in this Commonwealth may order a person who is domiciled or found within this Commonwealth to give his testimony or statement or to produce documents or other things for use in a matter pending in a tribunal outside this Commonwealth. The order may be made upon the application of any interested person.., for taking the testimony or statement or producing the documents or other things. To the extent the order does not prescribe otherwise, the practice and procedure shall be in accordance with the court of this Commonwealth issuing the order... 5. Amie E. Rupp is a resident of the Commonwealth of Pennsylvania and resides at RR2, Box 184 A8, Thompsontown, Pennsylvania 17094. 6. Michael Rupp is a resident of the Commonwealth of Pennsylvania and resides at RR2, Box 184 A8, Thompsontown, Pennsylvania 17094. 7. Roberta Rupp is aresident ofthe Commonwealth of Peunsylvania and resides at RR2' Box 184 A8, Thompsontown, Pennsylvania 17094. 8. Joyce H. Ferree is a resident of the Commonwealth of pennsylvania and resides at 212 Chestnut Street, Mount Holly Springs, Peimsylvania 17065-.1210. 9. Keith Ferree is a resident of the Commonwealth of Pennsylvania and resides at 526 Eutaw Avenue, New Cumberland, pennsylvania 17070-1850. 10. Karen Ferree is a resident of the Commonwealth of Pennsylvania and resides at 526 Eutaw Avenue, New Cumberland, Pennsylvania 17070-1850. 11. Terry Ferree is a resident of the Commonwealth o f Pennsylvania and resides at 6151 Manor Hill Circle, Harrisburg, pennsylvania 17111-3845. 12. Kathy Ferree is a resident of the Commonwealth of Pennsylvania and resides at 6151 Manor Hill Circle, Harrisburg, Pennsylvania 17111-3845. 13. Wendy Harris is a resident of the Commonwealt!q~ of Pennsylvania and resides at Chambersburg, Pennsylvania. 14. The Plaintiffs request the appearance ofAmie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Karen Ferree, Terry Ferree, Kathy Ferree and Wendy Harris for deposition on Tuesday, October 4, 2004 at 9:00 a.m. at the Holiday Inn West, 5401 Carlisle Pike, Mechanicsburg, Pennsylvania, or at such other date, time, and place as the parties may agree. The Notices of Deposition are attached hereto as Exhibit B. 15. The Plaintiff requires the deposition of Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Karen Ferree, Terry Ferree, Kathy Ferree and Wendy Harris and the production of the documents requested in the Notice of Deposition to fully prepare for the trial of their cause in the Oregon action. WHEREFORE, Plaintiff respectfully requests your Honorable Court to enter an order compelling the appearance for deposition of Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Karen Ferree, Terry Ferree, Kathy Ferree ~md Wendy Harris at the date, time and location as set forth above. Steven Allen Smith, Esquire 5745 NE Glisan Street Portland, Oregon 97213 (503) 228-7256 Attorney for Plaintiff HANFT & KNIGHT, P.C. Sean M. Shultz, Esquire ~ Attorney I.D. No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013 (717) 249-:5373 Attorney for Plaintiff 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff No. CIVIL ACTION - LAW STEPHANIE LYNN CORNWALL, Defendant CERTIFICATE OF SERVICI~ AND NOW, this ~'~ 'q~ day of September, 2004, I, Sean M. Shultz, Esquire, hereby certify that I have served a copy of the Petition for an Order to Take Depositions by mailing the same by United States mail, postage prepaid, to: Lanai J. Blake, Jr., Esquire 3700 Barbur Building 3718 SW Condor Street, #110 Portland, Oregon 97239 HANFT & KNIGHT, P.C. Sean M. Shultz, Esquire ~ Attorney I.D. No. 90946 19 Brookwood Awsnue, Suite 106 Carlisle, Pennsylwmia 17013 (717) 249-5373 Attorney for Plaintiff Exhibit "A" 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF CLACKAMAS Family Law Department In the Matter of the Marriage of GEORGE MACKIE CORNWALL IlL Petitioner, and STEPHANIE LYNN CORNWALL, Respondent. No. DR 03-03721 COMMISSION TO TAKE DEPOSITION AND/OR REQUEST TO ISSUE SUBPOENAS IN A FOREIGN JURISDICTION TO: Person a~tthorized to administer oath within the jurisdiction of the State of Pennsylvania for the Court of Common Please of Cumberland County, Pennsylvania. FROM: Presiding Court, 5th Judicial District. IT IS HEREBY COMMISSIONED, pursuant to Rule 38 of the Oregon Rules of Civil 19 Procedure {codifying the Unifon-n Foreign Deposition Act), by an order signed by Judge 20~on August ~ _F--D, 2004, at Oregon City, Oregon, that by the representation 21 of the Oregon attorney for the Petitioner, persons residing within the jurisdiction of your PAGE 1 - COMMISSION TO TAKE DEPOSITION AND/OR REQUEST TO ISSUE SUBPOENAS IN A FOREIGN JURISDICTION STEVEN ALLEN SMITH, P.C. 5745 NE GLISAN STREET PORTLAND, OREGON 97213 (503) 228-7256 , _~. 8,1.~.kc court are to be deposed by telephone, to perpetuate testimony, pursuant to the roles and statutes of the State of Oregon at a time to be set by the attorney conducting the deposition. 3 It is the understanding of the Oregon attorney that a formal associiation of counsel within your jurisdiction may be necessary. IT IS FURTHER COMMISSIONED, pursuant to Rule 55 of the ORCP, that bas~dl 6 upon the representation of the above-mentioned Oregon attorney and by an order dated as 7 above, that records pertaining to the above-captioned lawsuit exist within your jurisdiction 8 9 lO 11 12 13 14 15 and that subpoenas be issued from your court for the acquisition of such records. The COMMISSION is dated this ;,)Q.") day of August, 2004. SUBM?/D BY: Attorney for Petitioner (Dep~)~Court Administrator Ex Officio Clerk of the Court 16 Z:~D~\Corg4022~Pleading\DepoCommission .wPd 17 18 19 2O 21 PAGE 2 - COMMISSION TO TAKE DEPOSITION AND/OR REQUEST TO ISSUE SUBPOENAS IN A FOREIGN JURISDICTION STEVEN ALLEN SMITH, P.C. 5745 NE GLISAN STREET PORTLAND, OREGON 97213 (503) 228-7256 Exhibit "B" IN THE COURT OF COMMON PLEAS OF CUMBERLAND cOUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff No. CIVIL ACTION - LAW STEPHANIE LYNN CORNWALL, Defendant NOTICE TO TAKE DEPOSITION TO: AMIE E. RUPP RR 2, Box 184A8 Thompsontown, Pennsylvania 17094 WHEREAS, Steven Allen Smith, Esquire has received a commission, issuing out of the Circuit Court of Oregon for the County of Clackamas, for the examination of witnesses, Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Fe'rree, Karen Ferree, Terry Ferree, Kathy Ferree and Wendy Harris, in the above pending action pursuant to the Oregon Rules of Civil Procedure. I hereby give you notice that Steven Allen Smith, Esquire, will execute the commission, on behalf of George M. Cornwall, III, on Monday, October 4, 20.04, beginning at 9:00 a.m. at the Holiday Inn West located at 5401 Carlisle Pike, Mechanicsburg, Pennsylvania.. Date: September 24, 2004 HANFT & KNIGHT, P.C. ScJafi'M. Shultz, Esquire Attorney I.D. No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013 -9142 (717) 249-5373 Attorney for Plaintiff 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant No. CIVIL ACTION - LAW NOTICE TO TAKE DEPOSITION TO: MICHAEL RUPP RR 2, Box 184A8 Thompsontown, Pennsylvania 17094 WHEREAS, Steven Allen Smith, Esquire has received a commission, issuing out of the Circuit Court of Oregon for the County of Clackamas, for the examination of witnesses, Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith FmTee, Karen, Ferree, Terry Ferree, Kathy Ferree and Wendy Harris, in the above pending action pursuant to the Oregon Rules of Civil Procedure. I hereby give you notice that Steven Allen Smith, Esquire:, will execute the commission, on behalf of George M. Cornwall, III, on Monday, October 4, 2004, beginning at 9:00 a.m. at the Holiday Inn West located at 5401 Carlisle Pike, Mechanicsburg,, Pennsylvania.. Date: September 24, 2004 HANFT & KNIGHT, P.C. Se~i~l~l. Shultz, Esq ' Attorney I.D. No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 Attorney for Plaintiff 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant No. CIVIL ACTION - LAW NOTICE TO TAKE DEPOSITION TO: ROBERTA RUPP RR 2, Box 184 A8 Thompsontown, Pennsylvania 17094 WHEREAS, Steven Allen Smith, Esquire has received a commission, issuing out of the Circuit Court of Oregon for the County of Clackamas, for the ex amination of witnesses, Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Karen Ferree, Terry Ferree, Kathy Ferree and Wendy Harris, in the above pending action pursuant to the Oregon Rules of Civil Procedure. I hereby give you notice that Steven Allen Smith, Esquire, will execute the commission, on behalf of George M. Cornwall, 1II, on Monday, October 4, 2004, beginning at 9:00 a.m. at the Holiday Inn West located at 5401 Carlisle Pike, Mechanicsburg, Pennsylvania.. Date: September 24, 2004 HANFT & KNIGHT, P.C. BYse~ S~h~ul~~ Attorney I.D. No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, pennsylvania 17013-9142 (717) 249-5373 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND cOUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff No. CIVIL ACTION - LAW STEPHANIE LYNN CORNWALL, Defendant NOTICE TO TAKE DEPOSITION TO: JOYCE H. FERREE 212 Chestnut Street Mount Holly Springs, Pennsylvania 17065-1210 WHEREAS, Steven Allen Smith, Esquire has received a commission, issuing out of the Circuit Court of Oregon for the County of Clackamas, for the examination of witnesses, Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Karen Ferree, Terry Ferree, Kathy Ferree and Wendy Harris, in the above pending action pursuant to the Oregon Rules of Civil Procedure. I hereby give you notice that Steven Allen Smith, Esquire:, will execute the commission, on behalf of George M. Cornwall, III, on Monday, October 4, 20134, beginning at 9:00 a.m. at the Holiday Inn West located at 5401 Carlisle Pike, Mechanicsburg:, Pennsylvania.. Date: September 24, 2004 HANFT & KNIGHT, P.C. Sean M. Shultz, Esquire Attorney I.D. No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, pennsylvania 17013-9142 (717) 24.9-5373 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND cOUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant No. CIVIL ACTION - LAW NOTICE TO TAKE DEPOSITIO.~N TO: KEITH FERREE 526 Eutaw Avenue New Cumberland, Pennsylvania 17070-1850 WHEREAS, Steven Allen Smith, Esquire has received a commission, issuing out of the Circuit Court of Oregon for the County of Clackamas, for the examination of witnesses, Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Karen Ferree, Terry Ferree, Kathy Ferree and Wendy Harris, in the above pending action pursuant to the Oregon Rules of Civil Procedure. I hereby give you notice that Steven Allen Smith, Esquire:, will execute the commission, on behalf of George M. Cornwall, m, on Monday, October 4, 2004, beginning at 9:00 a.m. at the Holiday Inn West located at 5401 Carlisle Pike, Mechanicsburg, pennsylvania.. Date: September 24, 2004 HANFT & KNIGHT, P.C. Sean M. Shultz, Esquir Attorney I.D. No. 90946 19 Broo]~vood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 24.9-5373 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND cOUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHAN1E LYNN CORNWALL, Defendant TO: No. CIVIL ACTION - LAW NOTICE TO TAKE DEPOSITION KAREN FERREE 526 Eutaw Avenue New Cumberland, Pennsylvania 17070-1850 WHEREAS, Steven Allen Smith, Esquire has received a commission, issuing out of the Circuit Court of Oregon for the County of Clackamas, for the examination of witnesses, Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Terry Ferree, Karen Ferree, Kathy Ferree and Wendy Harris, in the above pending action pursuant to the Oregon Rules of Civil Procedure. I hereby give you notice that Steven Allen Smith, Esquire:, will execute the commission, on behalf of George M. Cornwall, HI, on Monday, October 4, 2004, beginning at 9:00 a.m. at the Holiday Inn West located at 5401 Carlisle Pike, Mechanicsburg:, Pennsylvania.. Date: September 24, 2004 HANFT &~._KNIGHT, P.C. ,- Attorney I.D. No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, pennsylvania 17013-9142 (717) 24.9-5373 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND cOUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant No. CIVIL ACTION - LAW NOTICE TO TAKE DEPOSITION TO: TERRY FERREE 6151 Manor Hill Circle Harrisburg, Pennsylvania 170111-3845 WHEREAS, Steven Allen Smith, Esquire has received a commission, issuing out of the Circuit Court of Oregon for the County of Clackamas, for the examination of witnesses, Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Terry Ferree, Karen Ferree, Kathy Ferree and Wendy Harris, in the above pending action pursuant to the Oregon Rules of Civil Procedure. I hereby give you notice that Steven Allen Smith, Esquire:, will execute the commission, on behalf of George M. Cornwall, HI, on Monday, October 4, 2004, beginning at 9:00 a.m. at the Holiday Inn West located at 5401 Carlisle Pike, Mechanicsburg, Pennsylvania.. Date: September 24, 2004 HANFT & KNIGHT, P.C. Sean M. Shultz, Esqmre Attorney I.D. No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, pennsylvania 17013-9142 (717) 24.9-5373 Attorney for Plaintiff 1N THE COURT OF COMMON PLEAS OF CUMBERLAND cOUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant No. CIVIL ACTION - LAW NOTICE TO TAKE DEPOSITION TO: KATHY FERREE 6151 Manor Hill Circle Harrisburg, Pennsylvania 17111-3845 WHEREAS, Steven Allen Smith, Esquire has received a commission, issuing out of the Circuit Court of Oregon for the County of Clackamas, for the examination of witnesses, Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Karen Ferree, Terry Ferree, Kathy Ferree and Wendy Harris, in the above pending action pursuant to the Oregon Rules of Civil Procedure. I hereby give you notice that Steven Allen Smith, Esquire, will execute the commission, on behalf of George M. Cornwall, III, on Monday, October 4, 2004, beginning at 9:00 a.m. at the Holiday Inn West located at 5401 Carlisle Pike, Mechanicsburg, Pennsylvania.. Date: September 24, 2004 Attorney I.D. No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND cOUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant No. CIVIL ACTION - LAW NOTICE TO TAKE DEPOSITION TO: WENDY HARRIS Chambersburg, Permsylvania WHEREAS, Steven Allen Smith, Esquire has received a commission, issuing out of the Circuit Court of Oregon for the County of Clackamas, for the examination of witnesses, Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Karen Ferree, Terry Ferree, Kathy Ferree and Wendy Harris, in the above pending action pursuant to the Oregon Rules of Civil Procedure. I hereby give you notice that Steven Allen Smith, Esquire, will execute the commission, on behalf of George M. Cornwall, III, on Monday, October 4, 2004, beginning at 9:00 a.m. at the Holiday Inn West located at 5401 Carlisle Pike, Mechanicsburg, Pennsylvania.. Date: September 24, 2004 HANFT & KNIGHT, P.C. Attorney I.D. No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, pennsylvania 17013-9142 (717) 249-5373 Attorney for Plaintiff 1N THE COURT OF COMMON PI,EAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGEM. CORNWALL, III, No. Oye_ t/,o5.2,/ ~ Plaintiff v. CIVIL ACTION - LAW STEPHANIE LYNN CORNWALL, : Defendant E_~X PA_RTE P_ETITIO_N FOR AN ORDER TO TAIC~E DEPOSITIONS IN PENNSYLVANIA RI~LATING TO AN ACTION PENDI[NG IN A~/OT-HE~ S~-ATE Plaintiff, George Mackie Cornwall, III, by and through his attorneys, Hanft & Knight, p.C., and Steven Allen Smith, P.C., in accordance with Pa. R.C.P. 4007.1 (f) and 42 Pa. C.S. §5326 hereby petitions your Honorable Court to enter an Order compelling the attendance of Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Karen Ferree, Terry Farree, Kathy Ferree and Wendy Harris for deposition, and in support thereof as, serts the following: 1. George Mackie Cornwall, III, is Plaintiffin a divorce and custody action pending in the Circuit Court of Oregon for the County of Clackamas, Family Law Department, No. DK03- 03721. A copy of the Commission from the Circuit Court of Oregon is attached hereto as Exhibit 2. During the discovery process, the Plaintiff has leto-ned that Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Karen Ferree, 'Ferry Ferree, Kathy Ferree and Wendy Harris possess information regarding the claims at issue in th,,' Oregon action which is either relevant or will lead to the discovery of relevant information. The information sought by Plaintiff is vital to the complete disposition of the Plaintiff's interests in the Oregon action in which a trial is scheduled on November 4, 2004. Pursuant to Pennsylvania statute, 42 Pa.C.S. §5326, and Pa. R.C.P. 4007.1 regarding the conduct and use of depositions, Plaintiff seeks to take the deposition of the persons named above. 4. 42 Pa. C.S.A. §5326(a) provides in pertinent part: A court of record in this Commonwealth may order a person who is domiciled or found within this Commonwealth to give his testimony or statement or to produce documents or other things for use in a matter pending in a tribunal outside this Commonwealth. The order may be made upon the application of any interested person.., for taking the testimony or statement or producing the documents or other things. To the extent the order does not prescribe otherwise, the practice and procedure shall be in accordance with the court of this Commonwealth issuing the order... 5. Amie E. Rupp is a resident of the Commonwealth of Pennsylvania and resides at RR2, Box 184 A8, Thompsontown, Pennsylvania 17094. 6. Michael Rupp is a resident of the Commonwealth of Pennsylvania and resides at RR2, Box 184 AS, Thompsontown, Pennsylvania 17094. 7. Roberta Rupp is a resident of the Commonwealth of Pennsylvania and resides at RR2, Box 184 AS, Thompsontown, Pennsylvania 17094. 8. Joyce H. Ferree is a resident of the Commonwealth of Pennsylvania and resides at 212 Chestnut Street, Mount Holly Springs, Pennsylvania 17065-1210. 9. Keith Ferree is a resident of the Commonwealth ofl:'ennsylvania and resides at 526 Eutaw Avenue, New Cumberland, Pennsylvania 17070-1850. 10. Karen Ferree is a resident of the Commonwealth of Pennsylvania and resides at 526 Eutaw Avenue, New Cumberland, Pennsylvania 17070-1850. 11. Terry Ferree is a resident of the Commonwealth of Pennsylvania and ms/des at 6151 Manor Hill Circle, Harrisburg, Pennsylvania 17111-3845. 12. Kathy Ferree is a resident of the Commonwealth of Pennsylvania and resides at 6151 Manor Hill Circle, Harrisburg, Pennsylvania 17111-3845. 13. Wendy Harris is a resident of the Commonwealth of Pennsylvania and resides at Chambersburg, Pennsylvania. 14. The Plaintiffs request the appearance ofAmie E. lq',upp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Karen Ferree, Terry Ferree, Kathy Ferree and Wendy HaITis for deposition on Tuesday, October 4, 2004 at 9:00 a.m. at the Holi[day Inn West, 5401 Carlisle Pike, Mechanicsburg, Pennsylvania, or at such other date, time, and place as the parties may agree. The Notices of Deposition are attached hereto as Exhibit B. 15. The Plaintiff requires the deposition of Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Karen Ferree, Terry Ferree, Kathy Ferree and Wendy Harris and the production of the documents requested in the Notice of Deposition to fully prepare for the trial of their cause in the Oregon action. WHEREFORE, Plaintiff respectfully requests your Honorable Court to enter an order compelling the appearance for deposition ofAmie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Fetree, Karen Ferree, Terry Ferree, Kathy Ferree and Wendy Harris at the date, time and location as set forth above. Steven Allen Smith, Esquire 5745 NE Glisan Street Portland, Oregon 97213 (503) 228-7256 Attorney for Plaintiff HANET & K2'~IGHT, p.c. Sean M. Shult~Es~ Attorney I.D. No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013 (717) 249-5373 Attorney for Plaintiff 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant No. CIVIL ACTION - LAW .CERTI]7ICATE OF SERVICE_ AND NOW, this_~ q44~_ day of September, 2004, I, Sean M. Shultz, Esquire, hereby certify that I have served a copy of the Petition for an Order to Take Depositions by mailing the same by United States mail, postage prepaid, to: Larry J. Blake, Jr., Esquire 3700 Barbur Building 3718 SW Condor Street, #110 Portland, Oregon 97239 HANFT & KNIGHT, P.C. Attorney I.D. No. 90946 19 Brookwood Avenne, Suite 106 Carlisle, Pennsylvania 17013 (717) 249-5373 Attorney for Plaintiff Exhibit "A" 2 5 6 7 8 IN THE CIRCUIT COURT OF THE STATE (DF OREGON FOR THE COUNTY OF CLACKA.M~S Family Law Department 9 In the Matter of the Marriage of 10 GEORGE MACKIE CORNWALL IIL 11 Petitioner, 12 and 13 STEPHANIE LYNN CORNWALL, 14 Respondent. No. DR 03-03721 COMMISSION TO TAKE DEPOSITION AND/OR REQUEST TO ISSUE SUBPOENAS IN A FOREIGN JURISDICTION 15 16 TO: Person at~thorized to administer oath within the jurisdiction of the State of Pennsylvania for the Court of Common Please of Cumberland County, Pennsylvania. 17 FROM: Presiding Court, 5th Judicial District. 18 IT IS HEREBY COMMISSIONED, pursuant to Rule 38 of the Oregon Rules of Civil 19 Procedure (codifying the Uniform Foreign Deposition Act), by an order signed by Judge 20 '~L~on August --~:5~-, 2004, at Oregon City, Oregon, that by the representation 21 of the Oregon attorney for the Petitioner, persons residing within the jurisdiction of your PAGE 1 - COMMISSION TO TAKE DEPOSITION AND/OR REQUEST TO ISSUE SUBPOENAS IN A FOREIGN JURISDICTION STEVEN ALLEN SMITH, P.C. 5745 NE GLISAN STREET PORTLAND, OREGON 97213 (503) 228-7256 I court are to be deposed by telephone, to perpetuate testimony, pursuant to the rules and 2 · statutes of the State of Oregon at a time to be set by the attorney conducting the deposition. 3 It is the understanding of the Oregon attorney that a formal association of counsel within 4 your jurisdiction may be necessaW. IT IS FURTHER COMMISSIONED, pursuant to Rule ,5,5 of the ORCP, that based: upon the representation of the above-mentioned Oregon attorney and by an order dated as above, that records pertaining to the above-captioned lawsuit exist within your jurisdiction and that subpoenas be issued from your court for the acquisition of such records. The COMMISSION is dated this ,~ ~) day of August, 2004. 10 11 12 13 14 15 SUBMIT~ffD BY: :Steuen Allen Smith, OSB 74307 Attorney for Petitioner iDe(~p~trt~FC~ urt Administrator Ex Officio Clerk of the Court 16 Z:\DW~\Cor g40gl~Pleading~DepoCom mi.~ion .wpd 17 18 19 2O 21 PAGE 2 - COMMISSION TO TAKE DEPOSITION AND/OR REQUEST TO ISSUE SUBPOENAS IN A FOREIGN JURISDICTION STEVFN ALLEN SMITH, P.C. 5745 NE GLISAN STREET PORTLAND, OREGON 97213 (503) 228-7256 Exhibit "B" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff No. CIVIL ACTION - LAW STEPHANIE LYNN CORNWALL, Defendant NOTICE TO TAKE DEPOSITION TO: AMIE E. RUPP RR 2, Box 184 A8 Thompsontown, Pennsylvania 17094 WHEREAS, Steven Allen Smith, Esquire has receiw,~d a commission, issuing out of the Circuit Court of Oregon for the County of Clackamas, for the examination of witnesses, Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Karen Ferree, Terry Ferree, Kathy Ferree and Wendy Harris, in the above pending action pursuant to the Oregon Rules of Civil Procedure. I hereby give you notice that Steven Allen Smith, Esqu:[re, will execute the commission, on behalf of George M. Cornwall, 1II, on Monday, October 4, 2004, beginning at 9:00 a.m. at the Holiday Inn West located at 5401 Carlisle Pike, Mechanicsburg, Pennsylvania.. Date: September 24, 2004 HANFT & KNIGHT, P.C. By S Mi. Shultz, Esquire Attorney I.D. No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013 -9142 (717) 2,49-5373 Attorney for Plaintiff IN THE COURT OF COMMON ['LEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant No. CIVIL ACTION - LAW NOTICE TO TAKE DEPOSITION TO: MICHAEL RUPP RR 2, Box 184 A8 Thompsontown, Pennsylvania 17094 WHEREAS, Steven Allen Smith, Esquire has received a commission, issuing out of the Circuit Court of Oregon for the County of Clackamas, for the examination of witnesses, Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith ]?erree, Karen, Ferree, Terry Ferree, Kathy Ferree and Wendy Harris, in the above pending action pursuant to the Oregon Rules of Civil Procedure. I hereby give you notice that Steven Allen Smith, Esquire, will execute the commission, on behalf of George M. Cornwall, Ili, on Monday, October 4, 2;004, beginning at 9:00 a.m. at the Holiday Inn West located at 5401 Carlisle Pike, Mechanicsbm-g, Pennsylvania.. Date: September 24, 2004 HANFr & KNIGHT, P.C. BYse~FS/I. Shultz, Esquire Attorney I.D. No. 90946 19 Brookwood Avenue, Suite 106 Carlisle,, Pennsylvania 17013-9142 (717) 249-5373 Attorney for Plaintiff 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant No. CIVIL ACTION - LAW NOTICE TO TAKE DEPOSITION TO: ROBERTA RUPP RR 2, Box 184A8 Thompsontown, Pennsylvania 17094 WHEREAS, Steven Allen Smith, Esquire has receiw,'d a commission, issuing out of the Circuit Court of Oregon for the County of Clackamas, for the examination of witnesses, Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Karen Ferree, Terry Ferree, Kathy Ferree and Wendy Harris, in the above pending action pursuant to the Oregon Rules of Civil Procedure. I hereby give you notice that Steven Allen Smith, Esquire, will execute the commission, on behalf of George M. Cornwall, III, on Monday, October 4, 2004, beginning at 9:00 a.m. at the Holiday Inn West located at 5401 Carlisle Pike, Mechanicsbm.g, Pennsylvania.. Date: September 24, 2004 HANFT & KNIGHT, P.C. By Sean Mi. Shultz, EsquirT'- Attorne. y I.D. No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 2.49-5373 Attorney for Plaintiff 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant No. CIVIL ACTION - LAW NOTICE TO TAKE DEPOSITION TO: JOYCE H. FERREE 212 Chestnut Street Mount Holly Springs, Pennsylvania 17065-1210 WHEREAS, Steven Allen Smith, Esquire has receiw,~d a commission, issuing out of the Circuit Court of Oregon for the County of Clackamas, for the'. examination of witnesses, Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Karen Ferree, Terry Ferree, Kathy Ferree and Wendy Harris, in the above pending action pursuant to the Oregon Rules of Civil Procedure. I hereby give you notice that Steven Allen Smith, Esquire, will execute the commission, on behalf of George M. Cornwall, III, on Monday, October 4, 2004, beginning at 9:00 a.m. at the Holiday Inn West located at 5401 Carlisle Pike, Mechanicsburg, Pennsylvania.. Date: September 24, 2004 HANFr & KNIGHT, P.C. Sean M. Shultz, Esquire Attorne. y I.D. No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 2,49-5373 Attorney for Plaintiff 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANLA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant No. CIVIL ACTION - LAW NOTICE TO TAKE DEPOSITION TO: KEITH FERREE 526 Eutaw Avenue New Cumberland, Pennsylvania 17070-1850 WHEREAS, Steven Allen Smith, Esquire has receiw~d a commission, issuing out of the Circuit Court of Oregon for the County of Clackamas, for the, examination of witnesses, Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Karen Ferree, Terry Ferree, Kathy Ferree and Wendy Harris, in the above pending action pursuant to the Oregon Rules of Civil Procedure. I hereby give you notice that Steven Allen Smith, Esquire, will execute the commission, on behalf of George M. Cornwall, III, on Monday, October 4, 2004, beginning at 9:00 a.m. at the Holiday Inn West located at 5401 Carlisle Pike, Mechanicsburg, Pennsylvania.. Date: September 24, 2004 HANFT & KNIGHT, P.C. Bys ean . Shultz, esquire Attorney I.D. No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 2.49-5373 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant No. CIVIL ACTION - LAW NOTICE TO TAKE DEPOSITION TO: KAREN FERREE 526 Eutaw Avenue New Cumberland, Pennsylvania 17070-1850 WHEREAS, Steven Allen Smith, Esquire has received a commission, issuing out of the Circuit Court of Oregon for the County of Clackamas, for the examination of witnesses, Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Terry Ferree, Karen Ferree, Kathy Ferree and Wendy Harris, in the above pending action pursuant to the Oregon Rules of Civil Procedure. I hereby give you notice that Steven Allen Smith, Esquire, will execute the commission, on behalf of George M. Cornwall, 1II, on Monday, October 4, 2004, beginning at 9:00 a.m. at the Holiday Inn West located at 5401 Carlisle Pike, Mechanicsburg, Pennsylvania.. Date: September 24, 2004 HANFT & KNIGHT, P.C. By Sean M. Shultz, EsqUire Attorney I.D. No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant No. CIVIL ACTION - LAW NOTICE TO TAKE DEPOSITION TO: TERRY FERREE 6151 Manor Hill Circle Harrisburg, Pennsylvania 170111-3845 WHEREAS, Steven Allen Smith, Esquire has receiw:d a commission, issuing out of the Circuit Court of Oregon for the County of Clackamas, for the examination of witnesses, Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Terry Ferree, Karen Ferree, Kathy Ferree and Wendy Harris, in the above pending action pursuant to the Oregon Rules of Civil Procedure. I hereby give you notice that Steven Allen Smith, Esquire, will execute the commission, on behalf of George M. Cornwall, III, on Monday, October 4, 2004, beginning at 9:00 a.m. at the Holiday Inn West located at 5401 Carlisle Pike, Mechanicsburg, Pennsylvania.. Date: September 24, 2004 HANFT & KNIGHT, P.C. By Sean M. Shultz, Esqu'~rre Attorney I.D. No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013 -9142 (717) 249~5373 Attorney for Plaintiff 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant No. : CIVIL ACTION - LAW NOTICE TO TAKE DEPOSITION TO: KATHY FERREE 6151 Manor Hill Circle Harrisburg, Pennsylvania 17111-3845 WHEREAS, Steven Allen Smith, Esquire has received a commission, issuing out of the Cimuit Court of Oregon for the County of Clackamas, for the. examination of witnesses, Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Karen Ferree, Terry Ferree, Kathy Ferree and Wendy Harris, in the above pending action pursuant to the Oregon Rules of Civil Procedure. I hereby give you notice that Steven Allen Smith, Esquire, will execute the commission, on behalf of George M. Cornwall, Ili, on Monday, October 4, ,~004, beginning at 9:00 a.m. at the Holiday Inn West located at 5401 Carlisle Pike, Mechanicsburg, Pennsylvania.. Date: September 24, 2004 HANFr & KNIGHT, P.C. Attorney I.D. No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 2.49-5373 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant No. CIVIL ACTION - LAW NOTICE TO TAKE DEPOSITION TO: WENDY HARRIS Chambersburg, Pennsylvania WHEREAS, Steven Allen Smith, Esquire has received a commission, issuing out of the Circuit Court of Oregon for the County of Clackamas, for the examination of witnesses, Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Fen'ee, Keith Ferree, Karen Ferree, Terry Ferree, Kathy Ferree and Wendy Harris, in the above pending action pursuant to the Oregon Rules of Civil Procedure. I hereby give you notice that Steven Allen Smith, Esquire, will execute the commission, on behalf of George M. Cornwall, III, on Monday, October 4, 2004, beginning at 9:00 a.m. at the Holiday Inn West located at 5401 Carlisle Pike, Mechanicsburg, Pennsylvania.. Date: September 24, 2004 HANFT & KNIGHT, P.C. By_ Sean M. Shultz, Esquir~ Attorney I.D. No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 Attorney for Plaintiff 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHAN1E LYNN CORNWALL, Defendant CIVIL ACTION - LAW EX PARTE ORDER ALLOWING DEPOSITIONS IN PENNSYLVANIA RELATING TO AN ACTION PENDING IN ANOTItER STATE AND NOW, this ~ dayofSeptember, 2004, Plaintiff having filed an Ex Parte Petition regarding an action pending in the Circuit Court of Oregon for the County of Clackamas requesting an Order compelling the attendance of Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Karen Ferree, Terry Ferree, Kathy Ferree and Wendy Harris for deposition and/or production o fdocuments, and this Court having duly considered P 1 aintiff' s Petition, and being fully advised in the premises; IT IS HEREBY ORDERED that the Ex Parte Petition For An Order To Take Depositions In Pennsylvania Relating To An Action Pending in Another State is hereby granted, and that Amie E. Rupp, Michael Rupp, Roberta Rupp, Joyce H. Ferree, Keith Ferree, Karen Ferree, Terry Ferree, Kathy Ferree and Wendy Harris shall appear for deposition in accordance with the Oregon Court Rules, and shall produce any documents requested, on Monday, October 4, 2004, at 9:00 a.m. at the Holiday Inn West, 5401 Carlisle Pike, Mechanicsburg, Pennsylvania. IT IS FURTHER ORDERED that a copy of this Order, the Petition, the Deposition Notice, and the statutory witness fee shall be served upon the deponents, in accordance with Pennsylvania Court Rules. B 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant No. 04-04842 CIVIL ACTION - LAW EX PARTE PETITION FOR AN ORDER TO TAKE DEPOSITIONS IN PENNSYLVANIA RELATING TO AN ACTION PENDING IN ANOTHER STATE AFFIDAVIT ~';'~r~c~ /-,/~,~v'~/~>n,,~o , being duly sworn according to law deposes and say that he/she served the Order allowing the deposition of Gen2d Trump, the Petition, the Deposition Notice and the statutorywitness fee on f---~C'fe r~/,/ -T',~ ,~ -~ ff at _ /c~t/g ~50edo,,z I~a, C,~¢,~/5t?__~ at ~2.;~ o o'clock, f3_.m, on _~~ "~I~ ,the .jc~ __dayof_ ('~C ,2004. Sworn and subscrib~:d before me this _/q~l, dayof ~r)~_J/~J{L~ ,2004 --' Notarial Seal Dolly M, Hous~, Notary Public South Middleton Twp., Cumberiand Counh/ My Comrr~ssion Expires Sept _94, 200~ IN THE COURT OF COMMON' PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff No. 04-04842 CIVIL ACTION - LAW STEPHANIE LYNN CORNWALL, : Defendant : E~X PARTE PETITION FOR AN ORDER TO TAKE DEPOSITION,',; IN PENNSYLVANIA RELATING TO .AN ACTION PENDING IN ANOTHER STATE .AFFIDAVIT - 4~e~t~CD ?a!/r---~a//t/[z?rr, ~q~'2 , being duly sworn according to law deposes ~d say that he/she se~ed the Order allowing the deposition of Jen Burly, the Petition, the Deposition Notice ~d the statuto~ witness fee on ~x~ at -7~c~ 3oi C~' ~aC,~t'5~t /~O o'clock, _~ .m. on -~ .... , the ~ ~ ~ _, 2004. Sworn and subscribed before me this ~J ~']]~ day of~, 2004 Notary-~ublic0 (' Notai~J Sea Dolly M. Housel, Nola~ Public Sot~ Middloton Twp., Curnbedand County MY Commission F~ms Sept. 24, 2006 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant No. 04-04842 CIVIL ACTION - LAW _EX PARTE PETITION FOR AN ORDER TO TAKE DEPOSITIONS I_N PENNSYLVANIA RELATING TO AN ACTION PENDING IN ANOTHER STATE _AFFIDAVIT ~~'t~/Td--~ -"Z4/~t'//c/~-,o~,a,o _, being duly sworn according to law deposes and say that he/she se~ed the Order allowing the stin Michael Rupp, the Petition, the Deposition Notice ~d the stamtoWwimess fee on ~ ~/~. ~/r~ ~E ~ at ~2~C~L ~5d~ ~, ~d~m ~ at ~_~J ~ D o'clock, ~ .m. on _, the ff,Z _ day of ~ ~ ,2004. Sworn and subscribed before me this ~ day of_ ,2004 Notary P ub-li-c 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant No. 04-04842 CIVIL ACTION - LAW EX PARTE PETITION FOR AN ORDER TO TAKE DEPOSITIONS I.~N PENNSYLVANIA RELA3[/iNG TO _AN ACTION PENDING IN ANOTHER STATE _AFFIDAVIT_ Deposition Notice and the statutory witness fee on ~_~AZ/~ z~ at ~'.2:~(o C-,qeC,j~E' F~, ~,4~2~,or.e.~ ~t ~', .~ D o'clock, 7Z) .m. · ¢'~'/~4/'n/(-''rv,40 _, being duly sworn according to law deposes and say the on _, the __ /~,q/ _ dayof~d.-~z, ,2004. Sworn and subscribod before me this day of 2004 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant No. 04--04842 CIVIL ACTION - LAW EX PARTE PETITION FOR AN ORDER TO TAKE DEPOSITIONS IN PENNSYLVANIA RELATING TO AN ACTION PENDING IN ANOTHER STATE AFFIDAVIT , being duly sworn according to law deposes and say that he/she served the Order allowing the deposition of Officer Troy Wiser, the Petition, the Deposition Notice and the statutory witness fee on , the / q at '7'; 0 0 o'clock, rD .m. on _dayof (~9 ~t _, 2004. Sworn and subscribed, before me this · ]~-~ day of~, 2004 NotarTymubli~ ' _ _ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant No. 04-04842 CIVIL ACTION - LAW EX PARTE PETITION FOR AN ORDER TO TAKE DEPOSITIONg IN PENNSYLVANIA RELATING TO AN ACTION PENDING IN ANOTHER sTATE AFFIDAVIT c~LD . ~ ~ , being duly sworn according to law deposes and say that he/she se~ed the Order allowing the deposition ofTm~y Co~ez, the Petition, the Deposition Notice ~d the sta~to~wimess fee on ~ m V ~o ~ ~ z _,the ,/$-- _dayof o'clock, ,,-4 .m. on dT&~z-' ,2004. Sworn and subscribe~ before me this /t~ ~Z~ day of []ff, J~ ~_..I,~"' 2004 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant No. 04.-04842 CIVIL ACTION - LAW _EX PARTE PETITION FOR AN ORDER TO TAKE DEPOSITIONS IN PENNSYLVANIA RELATING TO -AN ACTION PENDING IN ANOTHER STATE .AFFIDAVIT _ (~,~60 /~,~6/ta~O , being duly sworn according to law deposes and say that he/she served the Order allow~p~osition of Terry Ferree, the Petition, the Deposition Notice and the statutory witness fee On ~7'~F, ~ F'~ a ~ ~ at f~/~/ rr/,~o,~ ~4~,c~ F~. ~¢; ~.~_ at _ / ~; ~o o'clock, /9 .m. on _,the ~/(,, _ dayof_ O c~ ,2004. Sworn and subscrib~l before me this ~_~] ~h_ day of~, 2004 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant No. 04-04842 CIVIL ACTION - LAW EX PARTE PETITION FOR AN ORDER T(.) TAKE DEPOSITIONS .IN PENNSYLVANIA RELATING TO _AN ACTION PENDING IN ANOTHER STATE AFFIDAVIT ~.7~r'~ 7L~.~/,~z.rl~ , being duly sworn according to law deposes and say that he/she served the Order allowing the deposition of Keith Ferree, the Petition, the Deposition Notice and the statutory witness fee on at ~2~ C~ ~. ~ &mfl~_ ~:3q _ o'clock, ~ .m. on ,the_ ]~ _dayof ~ _, 2004. Sworn and subscrib~l before me this ~_ ~--~ day of~, 2004 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant No. 04-04842 CIVIL ACTION - LAW EX PARTE PETITION FOR AN ORDER TO TAKE DEPOSITIONS IN PENNSYLVANIA RELATING TO AN ACTION PENDING IN ANOTHER STATE AFFIDAVIT ~T-,,? AO) //--//~M to E ~rtt~ , being duly s;vom according to law deposes and say that he/she served the Order allowing the deposition of Michael Rupp, the Petition, the Deposition Notice and the statutorywitness fee on tvx t ¢ M ~ gL ,~:~. ~, ~,/9 at f2-o-~ 2. ~o~. /:r~ .~1-2 .~'/d/~$,J~.-'/~-r~at }~tjlO o'clock, F .m. on ,the ! ? dayof ~ ,2004. Sworn and subscrib~l before me this / ?'~- day of ~J~~, 2004 ~otafial Dolly M. Hot.~ol, No~ Public South Middl~:m Twp., Cumberland ~ My Commission Excres Sept 24, 2006 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant No. 04-04842 CIVIL ACTION - LAW EX PARTE PETITION FOR AN ORDER TO TAKE DEPOSITIONS IN PENNSYLVANIA RELATING TO AN ACTION PENDING IN ANOTHER STATE AFFIDAVIT ~,~.q,~ c ~ ]~/c~,,.L~ r2aa ~,-) , being duly sworn according to law deposes and say OrS ~ ~' ~ that he/she se~ed the er allowing the deposition of~ie ~Ruf~ the Petition, the Deposition Notice~dthestatuto~witnessfeeon ~c ~ ~ ¢,~ ~c~ec z. ~ at ~2 ~o~ ~ZVA~,.~M~.go~.at ~q:lo o'clock, ~ .m. on ,the 17 _dayof Oc,~. ,2004. Sw.o,m and subscribe~be£ore me this /?~t.,~ dayof~, 2004 Notar,) Pubqic~ - Notarial Seal Dolly M. Housel, Notary Public South Middleton Twp., Cumbedand County My Commis~on Expires Sep, 24, 200(5