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Home My WebLink About13-7458 Supreme Co nnsylvania Court f Cai fuo leas For Prothonotary UseOn&: a AA Q t Docket No: * �. County 13 - '7y. The information collected on this forth is used solely for court administration purposes. This form does not supplement. or replace the fr.l ing and service of pleadings or other papers as required by 1mr• or rules of court. Commencement of Action: S Complaint ,Writ of Summons IM Petition Transfer from Another Jurisdiction E] Declaration of Taking E Lead Plaintiff's Name: Lead Defendant' s Name: 7QYWtS �VQ'7 C > T 70 �oucje_r 5eQck S`Peciaw!) ( - �er1 al La Dollar Amount Requested: 17 within arbitration limits I Are money damages requested? es ®1�'0 (check one) t%utside arbitration limits Q N Is this a Class Action Suit? U7 Yes ,No Is this an MDJAppeal? (] Yes WNo A Name of Plaintiff/Appellant's Attorney: h a_ r I Q S s q LA.1►' 2 Check here if you have no attorney (are a Self - Represented 1Pro Se] Litigant) Nature of the Case Place an'. V' to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that `you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS n Intentional Buyer Plaintiff Administrative Agencies Malicious Prosecution Fj Debt Collection: Credit Card U Board of Assessment Motor Vehicle Debt Collection: Other Board of Elections n Nuisance n Dept. of Transportation 0 Premises Liability ® Statutory Appeal: Other S Product Liability (does not include mass tort) Employment Dispute: F i Discrimination Slander/Libel/ Defamation Employment Dispute: Other n Zoning Board C ; Other: ® Other: T I Other: 0 MASS TORT 0 Asbestos N r) Tobacco Toxic Tort - DES Toxic Tort - Innplant REAL PROPERTY MISCELLANEOUS ® Toxic Waste Ejectment Common Law /Statutory Arbitration B , Other: Eminent Domain/Condemnation n Declaratory Judgment M Ground Rent n Mandamus [I Landlord/Tenant Dispute E] Non - Domestic Relations Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY Mortgage Foreclosure: Commercial Q Quo Warranto Dental n Partition n Replevin Legal rj Quiet Title 0 Other: .91 Medical r Other: ® Other Professional: Updated 11112011 R. J. MARZELLA & ASSOCIATES, P.C. Attorney for BY: Charles W. Marsar, Jr., Esquire Jeff Bouder, Individually, Pennsylvania Supreme Court I.D. No. 86072 and as Administrator of the 35 North Front Street Estate of Gail Louise Bouder Harrisburg, PA 17110 Telephone: (717) 234 -7828 Facsimile: (717 6883 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Jeff Bouder, Individually, DOCKET NO. 3 - - W5 l � and as the Administrator of the Estate of Gail Louise Bouder PROFESSIONAL MEDICAL NEGLIGENCE Plaintiff, V. Select Specialty Hospital- Central Pennsylvania, L.P. Corporate Trust Center -�;- 1209 Orange St.' -' Wilmington, DE 198o1 C/-) r Select Medical Corporation - �.' - Corporate Trust Center 1209 Orange St. Wilmington, DE 198o1 y- Select Medical Corporation T /D /B /A Select Specialty Hospital- Central Pennsylvania, L.P. Corporation Trust Center 1209 Orange St. Wilmington, DE 198o1 Defendants JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue Writ of Summons in the above - captioned action. 1 Writ of Summons shall be issued and forwarded to (X) Attorney () Sheriff Charles W. Marsar. Jr.. Esquire 1.E.�e (. �/ •�- � 35j-3 North Front Street _ Signature of Attor ey Harrisburg. PA 17110_ (7 - 34x _ Supreme Court ID No. 860 Names /Address/Telephone No. Date: / •2/'11 yil of Attorney WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANTS: YOU ARE NOTIFIED THAT THE ABOVE -NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. Prothono ary Date: C'L • �l b Deputy ( ),Check here if reverse is used for additional information. CERTIFICATE OF SERVICE I, Enjoli Neely, hereby certify that a true and correct copy of the foregoing document was served upon counsel of record this Vth day of Decemb 2013, by depositing.said copy in the United States Mail at Harrisburg, Pennsylvania, postage prepaid, first class delivery, and addressed as follows: Select Specialty Hospital - Central Pennsylvania, L.P. Corporate Trust Center 1209 Orange St. Wilmington, DE 198oi Select Medical Corporation Corporate Trust Center 1209 Orange St. Wilmington, DE 198oi Select Medical Corporation T /D /B /A Select Specialty Hospital - Central Pennsylvania, L.P. Corporation Trust Center Corporate Trust Center 1209 Orange St. Wilmington, DE 198ol R. J. MARZELLA & ASSOCIATES, P.C. BY: �' g"� ENJOLI NEELY, PARALEGAL C> R. J. MARZELLA & ASSOCIATES, P.C. Attorney for BY: Charles W. Marsar, Jr.,Esquire Jeff Bonder, Individually, Pennsylvania Supreme Court I.D. No. 86072 and as Administrator of the 3513 North Front Street Estate of Gail Louise Bouder Harrisburg, PA 17110 Telephone: (717) 234-7828 Facsimile: (717) 234-6883 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Jeff Bonder, Individually, DOCKET NO. � .'3 -�" y rg and as the Administrator of the Estate of Gail Louise Bouder PROFESSIONAL MEDICAL NEGLIGENCE Plaintiff, V. Select Specialty Hospital- Central Pennsylvania, L.P. Corporate Trust Center 1209 Orange St. Wilmington, DE 19801 ' Select Medical Corporation .y ; Corporate Trust Center ; 1209 Orange St. r-: = _ Wilmington, DE 19801 Select Medical Corporation T/D/B/A Select Specialty Hospital- Central Pennsylvania, L.P. Corporation Trust Center 1209 Orange St. Wilmington, DE 19801 Defendants JURY TRIAL DEMANDED //. 7S�"-I- ,�► 306�y.� PRAECIPE TO REISSUE WRIT OF SUMMONS TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please re-issue Writ of Summons in the above-captioned action. 2 Writ of Summons shall be issued and forwarde A n (X) Sheriff Charles W. Marsar, Esquire 3513 North Front Street Signature of to ey Harrisburg, PA 17110 Supre a Court I o. 86072 (717) 234-7828 Date: �{ CERTIFICATE OF SERVICE I, Enjoli Neely, hereby certify that a true and correct copy of the foregoing document was served upon counsel of record this 14th day of January, 2014, by depositing said copy in the United States Mail at Harrisburg, Pennsylvania, postage prepaid, first class delivery, and addressed as follows: Select Specialty Hospital—Central Pennsylvania, L.P. Corporate Trust Center 1209 Orange St. Wilmington, DE 19801 Select Medical Corporation Corporate Trust Center 1209 Orange St. Wilmington, DE 19801 Select Medical Corporation T/DB/A Select Specialty Hospital—Central Pennsylvania, L.P. Corporation Trust Center Corporate Trust Center 1209 Orange St. Wilmington, DE 19801 R.J.MARZELLA&ASSOCIATES,P.C. BY: ENJOLI NEEL ,PARALEGAL SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ,err Jody S Smith -01q FE8 Chief Deputy ' I I (. Richard W Stewart k.v, 40%, Solicitor PENNS LVAN Jeff Bouder vs. Case Number Select Specialty Hospital - Central Pennsylvania, L.P. (et al.) 2013-7458 SHERIFF'S RETURN OF SERVICE 01/10/2014 Ronny R Anderson, Sheriff, who being duly sworn according to law, states that he served the within Writ of Summons upon the within named defendant, Select Medical Corporation, in the following manner: On January 10, 2014 the Sheriff mailed by certified mail, return receipt requested a true and correct copy of the within Writ of Summons to the defendant's last known address of 1209 Orange Street, Wilmington, DE 19801. The certified mail return receipt card was received by the Cumberland County Sheriff's Office signed by Melanie M. Grath on January 14, 2014. 01/10/2014 Ronny R Anderson, Sheriff, who being duly sworn according to law, states that he served the within Writ of Summons upon the within named defendant, Select Specialty Hospital - Central Pennsylvania, L.P., in the following manner: On January 10, 2014 the Sheriff mailed by certified mail, return receipt requested a true and correct copy of the within Writ of Summons to the defendant's last known address of 1209 Orange Street, Wilmington, DE 19801. The certified mail return receipt card was received by the Cumberland County Sheriff's Office signed by Melaine M. Grath on January 14, 2014. 01/10/2014 Ronny R Anderson, Sheriff, who being duly sworn according to law, states that he served the within Writ of Summons upon the within named defendant, Select Medical Corporation t/d/b/a Select Specialty Hospital Central, in the following manner: On January 10, 2014 the Sheriff mailed by certified mail, return receipt requested a true and correct copy of the within Writ of Summons to the defendant's last known address of 1209 Orange Street, Wilmington, DE 19801. The certified mail return receipt card was received by the Cumberland County Sheriff's Office signed by Melanie M. Grath adult in chage for Select Medical Corporation t/d/b/a Select Specialty Hospital Central on January 21, 2014. SHERIFF COST: $78.33 SO ANSWERS, January 31, 2014 RONNS' R ANDERSON, SHERIFF SENDER: COMPLETE THIS SECTION COMPLETE THIS SECTION ON DELIVERY • Complete Items 1,2,and 3.Also complete 1111.1111511111W item 4 if Restricted Delivery is desired. X ❑Agent ▪ Print your name and address on the reverse 0 Addressee so that we can return the card to you. rriv ' • Attach this card to the back of the mailpiece, , r or on the front if space permits. 1. Article Addressed to: D. Is delivery address different from item 1? ❑Yes If YES,enter delivery address below: ❑No Select Medical Corporation SAN 14 2014 -f1rl 1209 Orange Street -74 3 Wilmington, DE 19801 3. Service type ❑Certified Mail ❑Express Mail ❑Registered ❑Return Receipt for Merchandise ❑Insured Mall ❑C.O.D. 4. Restricted Delivery?(Extra Fee) ❑Yes 2. (Transfer from 7007 0710 0003 2210 3849 (Transfer from servJce label) PS Form 3811,February 2004 Domestic Return Receipt 102595-02-tit-1540 SENDER: COMPLETE THIS SECTION COMPLETE THIS SECTION ON DELIVERY • Complete items 1,2,and 3.Also complete item 4 if Restricted Delivery is desired. X F "� • Print your name and address on the reverse ❑ s" so that we can return the card to you 04 • Attach this card to the back of the mailpiece, or on the front if space permits. D. Is delivery address different from item 1? ❑Yes 1. Article Addressed to: it YES,enter delivery address below: ❑No Select Specialty Hospital -Central Pennsylvania, L.P. 1209 Orange Street 0�3 ,�; `JC� Wilmington, DE 19801 7 Certified Mail ❑Express Mall ❑Registered ❑Return Receipt for Merchandise ❑Insured Mail ❑C.O.D. 4. Restricted Delivery?(Extra Fee) ❑Yes 2. Article Number 7007 0 710 0003 2 210 3832 (Transfer from service label) PS Form 3811,February 2004 Domestic Return Receipt 102595-02-M-1540 SENDER: COMPLETE THIS SECTION COMPLETE THIS SECTION ON DELIVERY • Complete Items 1,2,and 3.Also complete " item 4 if Restricted Delivery is desired. • Print your name and address on the reverse x )1I? d,t : [ ,h v Agent ❑Addressee so that we can return the card to you. • Attach this card to the back of the mailpiece, ) 'Date d Mikity or on the front if space permits. D. Is delivery address different from Item 1? ❑Yes 1. Article Addressed to: If YES,enter delivery address below: ❑No Select Medical Corporation t/d/b/a Select Specialty Hospital Central 1209 Orange Street Wilmington, DE 19801 Certified Mail ❑Express Mail Registered ❑Return Receipt for Merchandise JAN 2 1 71114 ❑insured Mail ❑C.O.D. 4. Restricted Delivery?(Extra Fee) ❑yes 2. Article Number (Transfer from service label) 7007 0710 0003 2210 3856 /1/-7'7 PS Form 3811,February 2004 Domestic Retum Receipt G/3_7 y 5g 102595-02-M-1540 FOULKROD ELLIS Professional Corporation 4000 Market Street Camp Hill, Pennsylvania 17,Q 1 Telephone: (717) 909- 700167uUMBERLAND COUNTY Fax: (717) 909 -6955 PENNSYLVANIA THE PROTHON,i17,,T2( 2014 HAR '3 PH 2: 20 Attorney for Defendants: Select Specialty Hospital- Central Pennsylvania, L.P., Select Medical Corporation, and Select Medical Corporation t/d/b /a Select Specialty Hospital — Central Pennsylvania, L.P. JEFF BOUDER, Individually and as the Administrator of the Estate of GAIL LOUISE BOUDER, Plaintiff v. SELECT SPECIALTY HOSPITAL - CENTRAL PENNSYLVANIA, L.P.; SELECT MEDICAL CORPORATION; AND SELECT MEDICAL CORPORATION t /d/b /a SELECT SPECIALTY HOSPITAL - CENTRAL PENNSYLVANIA, L.P., Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 13 -7458 PROFESSIONAL MEDICAL NEGLIGENCE JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter our appearance on behalf of Defendants, Select Specialty Hospital - Central Pennsylvania, L.P., Select Medical Corporation, and Select Medical Corporation t /d/b /a Select Specialty Hospital — Central Pennsylvania, L.P. in the above - captioned action. Respectfully submitted, FOULKROD ELLIS PROFESSIONAL CORPORATION Date: ib O /// By: )(11,L Leigh'A.J. Ellis, Esquire Attorney I.D. No. 53229 leigh@foulkrod.com Cindy N. Ellis, Esquire Attorney I.D. No. 83823 cindy gfoulkrod.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that true and correct copies of the foregoing were served upon all counsel of record this 28th day of February, 2014, by depositing said copy in the United States Mail at Camp Hill, Pennsylvania, postage prepaid, first class delivery, and addressed as follows: Charles W. Marsar, Jr., Esquire R.J. Marzella & Associates, P.C. 3513 North Front Street Harrisburg, PA 17110 (Counsel to Plaintiff By: FOULKROD ELLIS PROFESSIONAL CORPORATION tacy L. Breon, Paralegal FOULKROD ELLIS Professional Corporation 4000 Market Street Camp Hill, Pennsylvania 17011 Telephone: (717) 909-7006 Fax: (717) 909-6955 F!I ED-OF FICE 1_4' THE PROTHONOTA1'l 2011, MAR —3 PM 2: 2 Attorney for Defendants: Select Specialty Hospital-Central Pennsylvania, L.P., CUMBERLAND COUNTY Select Medical Corporation, and PENNSYLVANIA Select Medical Corporation t/d/b/a Select Specialty Hospital — Central Pennsylvania, L.P. JEFF BOUDER, Individually and as the Administrator of the Estate of GAIL LOUISE BOUDER, Plaintiff , v. SELECT SPECIALTY HOSPITAL- CENTRAL PENNSYLVANIA, L.P.; SELECT MEDICAL CORPORATION; AND SELECT MEDICAL CORPORATION t/d/b/a SELECT SPECIALTY HOSPITAL-CENTRAL PENNSYLVANIA, L.P., Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 13-7458 PROFESSIONAL MEDICAL NEGLIGENCE JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO: PROTHONOTARY Please issue a Rule upon Plaintiff to file a Complaint within twenty (20) days from service hereof or suffer judgment non pros. Respectfully submitted, Date: 0V), FOULKROD ELLIS PROFESSIONAL CORPORATION By: Leigh A.J. Ellis, Esquire Attorney I.D. No. 53229 1 ei gh@foul krod .com Cindy N. Ellis, Esquire Attorney I.D. No. 83823 cindy@foulkrod.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that true and correct copies of the foregoing were served upon all counsel of record this 28th day of February, 2014, by depositing said copy in the United States Mail at Camp Hill, Pennsylvania, postage prepaid, first class delivery, and addressed as follows: Charles W. Marsar, Jr., Esquire R.J. Marzella & Associates, P.C. 3513 North Front Street Harrisburg, PA 17110 (Counsel to Plaintiffi By: FOULKROD ELLIS PROFESSIONAL CORPORATION Stacy L. Breon, Paralegal JEFF BOUDER, Individually and as the Administrator of the Estate of GAIL LOUISE BOUDER, Plaintiff v. SELECT SPECIALTY HOSPITAL - CENTRAL PENNSYLVANIA, L.P.; SELECT MEDICAL CORPORATION; AND SELECT MEDICAL CORPORATION t/d/b /a SELECT SPECIALTY HOSPITAL - CENTRAL PENNSYLVANIA, L.P., Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 13 -7458 PROFESSIONAL MEDICAL NEGLIGENCE JURY TRIAL DEMANDED RULE TO THE PLAINTIFF: You are hereby ordered and directed to file your Complaint against Defendant in the above - captioned matter within twenty (20) days of service of this Rule against you or suffer judgment non pros. \\ Date:3 3 .24� JJaW C1 �� - �LE l Prothonotar y • A R. J. MARZELLA & ASSOCIATES, P.C. BY: Charles W. Marsar, Jr., Esquire Pennsylvania Supreme Court I.D. No. 86072 3513 North Front Street Harrisburg, PA 17110 Telephone: (717) 234-7828 Facsimile(73-4-68 Attorney for Jeff Bouder, Individually, and as Administrator of the Estate of Gail Louise Bouder IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Jeff Bouder, Individually, and as the Administrator of the Estate of Gail Louise Bouder Plaintiff, v. Select Specialty Hospital- Central Pennsylvania, L.P. Corporate Trust Center 1209 Orange St. Wilmington, DE 19801 Select Medical Corporation Corporate Trust Center 1209 Orange St. Wilmington, DE 19801 Select Medical Corporation T/D/B/A Select Specialty Hospital- Central : Pennsylvania, L.P. Corporation Trust Center 1209 Orange St. Wilmington, DE 19801 Defendants DOCKET NO.13-7458 PROFESSIONAL MEDICAL NEGLIGENCE JURY TRIAL DEMANDED G) CJA N PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY, CUMBERLAND COUNTY: Attorne PI the above -referenced action settled and discontinued. Charles W. Ma A •enti orney_ Esquire o. 86072 Date: g(Ltby CERTIFICATE OF SERVICE I, Mary Greenwood -Drumheller, hereby certify that a true and correct copy of the foregoing document was served upon counsel of record this 20th day of August, 2014, by depositing said copy in the United States Mail at Harrisburg, Pennsylvania, postage prepaid, first class delivery, and addressed as follows: Foulkrod Ellis Professional Corporation 4000 Market Street Camp Hill, Pennsylvania 17011 R. J. MARZELLA & ASSOCIATES, P.C. MAR REE OD-DRUMHELLER, LAW CLERK