HomeMy WebLinkAbout12-5189,r
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William P. Douglas, Esq.
Supreme Court I.D. #37926
Douglas Law Office
43 West, South Street
Gettysburg, PA 17325
Telephone (717) 337-3111_
"h 12 A U G 20 P`112• ` I
"E'I N S Y LVA111A
Thomas Wisotzkey and Diane
Wisotzkey h / w
Plaintiffs
vs
Hanover Hospital, Inc. and Lisa J.
McIntyre
Defendant
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No. 12 - _,5'1 9-q Civil Term
Civil action law
Jury Trial Demanded
Praecipe to Issue a Writ of Summons
Dear Mr. Buell:
Please issue a writ of summons against the defendants,
Hanover Hospital, Inc. and Lisa J. Mclntryre
William P. Douglas, q.
Attorney for Plaintis
Date; August 20, 2012
,F163. 7S ` ,?4. y
Commonwealth of Pennsylvania
County of Cumberland
Tho as Wisotzkey and Diane In the Court of Common Pleas of
Wisotzkey h/w Cumberland County, Pennsylvania
Plaintiff
vs
Hanover Hospital, Inc. and
Lisa l? McIntyre
300 I ighland Avenue
Hanover, Pennsylvania
No. 12 - ,-(" Civil Term
Civil action law
Jury Trial Demanded
Defendant
Writ of Summons
Hanover Hospital, Inc. Lisa McIntyre
300 Highland Avenue c/o Hanover Hospital, Inc.
Hanover, Pennsylvania 17331 300 Highland Avenue
Hanover, PA 17331
You are hereby notified that Thomas Wisotzkey and
Diane Wisotzkey have brought an action against you.
Date: August 20, 2012
William P. Douglas, Esq.
Dougglas Law Office
43 V. South St.
Carlisle, PA 17013
717-243-1790
Attorney for Plaintiff
P t???'
1360696
DICICIE, MCCAMEY & CHILCOTE, P.C.
BY: Francis E. Marshall, Jr., Esquire
ATTORNEY I.D. N0.27594
BY: Aaron S. Jayman, Esquire
ATTORNEY LD. N0.85651
Plaza 21, Suite 302
425 North 21st Street
Camp Hill, PA 17011
717-731-4800 (Tele)
888-811-7144 fFaxl
THOMAS WISOTZKEY AND DIANE
WISOTZKEY, husband and wife,
Plaintiffs
v.
HANOVER HOSPITAL, INC. AND LISA
J. MCINTYRE,
Defendants
ATTORNEY FOR: Dl
HANOVER HOSPITAL, INC. AND LISA M.
IN THE COURT OF COMMON p~.E ~
OF CUMBERLAND COUNTY;b N
PENNSYLVANIA ~
i~~-~~89
NO.-~ `-tea: ,,,~y, ca
O
~~ 'U
MEDICAL MALPRACTICE A OPi~
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--a w
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JURY TRIAL DEMANDED
ENTRY OF AFPE~I~,ANGE
1'O 1'HE PROTHONOTARY:
Please enter the appearance of Francis E. Marshall, Jr., Esquire and Aaron S. Ja
Esquire, as counsel for Defendants, Hanover Hospital, Inc. and Lisa M. McIntyre, in the a
captioned matter.
Date: August 28, 2012
Respectfully submitted,
DICKIE CAMEY & CHILCO'~E, P.C.
~~.
By: --
Francis E. Marshall, Jr., Esquire
Supreme Court I. D. #27594
425 N. 21st Street, Suite 302
Camp Hill, PA 17011-3700
(717) 731-4800
Attorney for Defendants, Hanover Hos,~ital, Inc.
and Lisa M. McIntyre
~~,
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CERTIFICATE OF SERVICE
AND NOW, August 28, 2012, I, Francis E. Marshall, Jr., Esquire, hereby certify
did serve a true and correct copy of the foregoing upon all counsel of record by depositing,
causing to be deposited, same in the U.S. mail, postage prepaid, at Camp Hill, Pennsy
addressed as follows:
By First-Class Mail:
William P. Douglas, Esquire
DOUGLAS LAW FIRM
43 West South Street
Carlisle, PA 17013
(Counsel for Plaintiffs)
G%`r`~_
Francis E. Marshall, Jr., Esquire
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
2312 SEP I I Pty 12= 31
Richard W Stewart
Solicitor
CIMSERLANG COUNTY
Thomas Wisotzkey (et al.) Case Number
vs.
Lisa Mcintyre (et al.) 2012-5189
SHERIFF'S RETURN OF SERVICE
08/21/2012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search
and inquiry for the within named defendant, to wit: Lisa Mcintyre c/o Hanover Hospital, but was unable to
locate her in his bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania to serve the
within Writ of Summons according to law.
08/21/2012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search
and inquiry for the within named defendant, to wit: Hanover Hospital, but was unable to locate them in his
bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania to serve the within Writ of
Summons according to law.
08/30/2012 03:50 PM - York County Return: And now August 30, 2012 at 1550 hours I, Jack Lotwick, Sheriff of York
County, Pennsylvania, do hereby certify and return that I served a true copy of the within Writ of
Summons, upon the within named defendant, to wit: Hanover Hospital by making known unto Diane
Albin, Administrative Assistant for Hanover Hospital at 300 Highland Avenue, Hanover, Pennsylvania
17331 its contents and at the same time handing to her personally the said true and correct copy of the
same.
08/30/2012 03:50 PM - York County Return: And now August 30, 2012 at 1550 hours I, Jack Lotwick, Sheriff of York
County, Pennsylvania, do hereby certify and return that I served a true copy of the within Writ of
Summons, upon the within named defendant, to wit: Lisa McIntyre c/o Hanover Hospital by making
known unto Diane Albin, Administrative Assistant for Hanover Hospital at 300 Highland Avenue, Hanover,
Pennsylvania 17331 its contents and at the same time handing to her personally the said true and correct
copy of the same.
SHERIFF COST: $53.45
September 11, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
SHERIFF'S OFFICE OF YORK COUNTY
Richard P Keuerleber PETER J. MANGAN, ESQ.
Sheriff Solicitor
Reuben B Zeager Richard E Rice, II
Chief Deputy, Operations Chief Deputy, Administration
THOMAS WISOTZKEY (et al.) Case Number
vs.
HANOVER HOSPITAL, INC. (et al.) 12-5189 CIVIL
SHERIFF'S RETURN OF SERVICE
08/30/2012 03:50 PM - DEPUTY MICHAEL S. ECKARD, BEING DULY SWORN ACCORDING TO LAW, SERVED
THE REQUESTED WRIT OF SUMMONS (WOSM) BY HANDING A TRUE COPY TO A PERSON
REPRESENTING THEMSELVES TO BE DIANNE ALBIN, ADMINISTRATIVE ASSISTANT, WHO
ACCEPTED AS "ADULT PERSON IN CHARGE" FOR HANOVER HOSPITAL, INC. AT 300 HIGHLAND
AVE, HANOVER, PA 17331.
WCAAE CKAR , DEPUTY
08/30/2012 03:50 PM - DEPUTY MICHAEL S. ECKARD, BEING DULY SWORN ACCORDING TO LAW, SERVED
THE REQUESTED WRIT OF SUMMONS (WOSM) BY HANDING ATRUE COPY TO A PERSON
REPRESENTING THEMSELVES TO BE DIANNE ALBIN, ADMINISTRATIVE ASSISTANT, WHO
ACCEPTED AS "ADULT PERSON IN CHARGE" FOR LISA MCINTYRE AT 300 HIGHLAND AVENUE,
C/O HANOVER HOSPITAL, HANOVER, PA 17331.
SHERIFF COST: $54.31
September 06, 2012
CIO if
AAcCKA ,
EPUTY
SO A RS,
RICHARD P KEUERL BER, SHE FF
S..?ONWEALTti OF PENNSYLVANIA
Notarial Seal
Sheila E. Cook, Notary Public
III
>oringe ;6,j? TWp., York County I
,,,y ,,;omffj$Sion Expir" Feb. 1, 2013
fN rnL rr, Pennsylvania Asaociaton of Notaries
NOTARY _
Affirmed and subscribed to before me this
6TH day of SEPTEMBER 2012
CauntyS.,it? >henf' TeieesoF...
Commonwealth of Pennsylvania
County of Cumberland
Thomas Wisotzkey and Diane In the Court of Common Pleas of
Wisotzkey h/w Cumberland County, Pennsylvania
Plaintiff
vs
Hanover Hospital, Inc. and
Lisa J. McIntyre
300 Highland Avenue
Hanover, Pennsylvania
Defendant
No. 12 - ?-/ ? q Civil Term
Civil action law
Jury Trial Demanded
Writ of Summons
Hanover Hospital, Inc. Lisa McIntyre
300 Highland Avenue c/o Hanover Hospital, Inc.
Hanover, Pennsylvania 17331 300 Highland Avenue
Hanover, PA 17331
You are hereby notified that Thomas Wisotzkey and
Diane Wisotzkey have brought an action against you.
J)Cia, a 2. &-.e //
Date: August 20, 2012
William P. Douglas, Esq.
Douglas Law Office
43 W. South St.
Carlisle, PA 17013
717-243-1790
Attorney for Plaintiff
0? "-01 , .,a rnotary
TRUE COPY FROM RECORD
In Testimony whereof, I here unto set my hand
and then said Cyfurt at C?rtisla,P??
This daY O
T f?C? r)'
notary
t- +
THOMAS WISOTZKEY AND DIANE IN THE COURT OF COMMON PLEAS OF
WISOTZKEY,husband and wife, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs, NO. 12-5189
V. MEDICAL MALPRACTICE ACTION
HANOVER HOSPITAL, INC.AND LISA J.
MCINTYRE,
JURY TRIAL DEMANDED
Defendants.
ORDER
AND NOW,this -� day of.A V'i'-/ 2013, upon consideration of
the Defendants' Preliminary Objections to Plaintiffs' Complaint it is hereby ORDERED as
follows:
1. The above captioned matter shall be transferred to the Court of Common Pleas
of York County, Pennsylvania with all costs and fees for transferring and removal
of the record to be paid by the Plaintiffs.
ce.
BY THE COURT:
Distribution: r
Ce -� -�
William P. Douglas, Esquire — ��� / // rnm
Aaron S.Jayman, Esquire - COPNnc� �elivPriCc� �
_ � .