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Home My WebLink About06-2166 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 2006 - W4-e- e(Z PAUL E. STONE, as Co-Administrator of the Estate of KENNETH E. WALLACE, Deceased 703 Bloserville Road Newville, PA 17241 CIVIL ACTION - LAW BARBARA J. MYERS, as Co-Administrator of the Estate of KENNETH E. WALLACE, Deceased 1756 Sherman Valley Road Elliottsburg, PA 17024 Plaintiffs & Addresses versus LISA J. CASE, as Administratrix of the Estate of JOYCE G. CASE, Deceased 126 Cross Timber Way Frederick, MD 21702 JURY TRIAL DEMANDED Defendant & Address PRAECIPE FOR A WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue a Writ of Summons in the above-captioned action. X Writ of Summons shall be issued and forwarded to David Wisneski, Esquire Navitsky, Olson & Wisneski LLP 2040 Linglestown Road Suite 303 Harrisburg, PA 17110 (717) 541-9205 Name/Address/Telephone No. of Attorney (X ) Attorney and ( ) Sheriff ( ) Defendant I ?. nature Attorney iof ig I.D. No. 58796 Dated: April 18, 2006 f 1 tA ll r. F IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PAUL E. STONE, as Co-Administrator of the Estate as KENNETH E. WALLACE, Deceased 703 Bloserville Road Newville, PA 17241 CIVIL ACTION - LAW LISA J. CASE, as Administratrix of the Estate of JOYCE G. CASE, Deceased 126 Cross Timber Way Frederick, MD 21702 BARBARA J. MYERS, as Co-Administrator of the Estate of KENNETH E. WALLACE, Deceased 1756 Sherman Valley Road Elliottsburg, PA 17024 Plaintiffs & Addresses versus WRIT OF SUMMONS JURY TRIAL DEMANDED Defendant & Address TO THE ABOVE NAMED DEFENDANT: YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFFS HAVE COMMENCED AN ACTION AGAINST YOU. Proth notary Dated: CZ&z11 /?. ACC( Deputy PAUL E. STONE and BARBARA J. MYERS, as Co-Administrators of the Estate of KENNETH E. WALLACE, Deceased, Plaintiffs V. LISA J. CASE, as Administratrix of the Estate of JOYCE G. CASE, Deceased, Defendant NO. 2006-2166 CIVIL ACTION - LAW JURY TRIAL DEMANDED AFFIDAVIT OF SERVICE This is to certify that on the 14th day of April, 2006 a true and correct copy of the Writ of Summons was mailed to Defendant Lisa J. Case as Administratrix of the Estate of Joyce G. Case, via certified mail, return receipt requested, at 126 Cross Timber Way, Frederick, MD 21702. A copy of the certified mail receipt No. 7005 2570 0000 3671 6526 is attached hereto. Lois E. Stauffer RETURN OF SERVICE This is to certify that on the 27th day of April, 2006, the Writ of Summons was served upon Defendant Lisa J. Case as Administratrix of the Estate of Joyce G. Case, via certified mail, return receipt requested at the above-noted address. A copy of the signed return receipt No. 7005 2570 0000 3671 6526 is attached hereto. Lois E. Stauffer to and subscribed before me this l u day of Lj-1 .2006.1 Public t.;UMMUNWEALTH OF PENNSYLVANIA Notarial Seal Michaeline J. Hine, Notary Public Susquehanna Twp., Dauphin County My Commission Expires Sept. 28, 2008 Member, Pennsylvania Association Of Notaries MY COMMISSION EXPIRES: IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA CERTIFIED MAIL,:, RECEIF (Domestic Mail Only, No Insurance Coverai r-q I I 2 M Postage $ W. 39 7> ? C3 C3 CerBfied Fee $2.40 ?• 0106 D C3 Retum R Fee (Endorsement pe egi?uired) $1.85 1 Postmark O p -A R 19 2006 I estricted Delivery Fee fl, I) r - (Endorsement Required) Ln rU Total Postage & Fees $ $4.64 0114/19/2006 Ln 0 Sent To MS Lisa Case, U P5 SL - - ... _ - ° •T = - -- ° • fti . .. -•-- ...__. T- Wrest, Apt Nof n or PO Box No. ??(? 11155 I1M?OPv ?f.l?(,?i4 ¦ Complete items 1, 2, and 3. Also complete x A Sig atu item 4 If Restricted Delivery is desired. ? Agent ¦ Print your name and address on the reverse ? Addressee so that we can return the card to you. B. Received b ( Name) C. Date of Delivery ¦ Attach this card to the back of the maiipieoe, or on the front if space permits. { y ?? D. Is delivery address different from item 1? ? Yes 1. Article Addressed to: If YES, enter delivery address bekwv: ? No GMs . 1?sci? 5: Cct>,5?2. lalo Cross 3. Type ified Mail ? E nsw Mail O Registered JB?etum Receipt for Merchandise ? Insured mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Number 7005 2570 0000 3671 6526 (Transfer from service label) PS Form 3811, February 2004 Domestic Return Receipt 102595424A-1540 CERTIFICATE OF SERVICE I, Lois E. Stauffer, an employee of the law firm of Navitsky, Olson & Wisneski LLP hereby certify that a true and correct copy of the foregoing Affidavit of Service/Return of Service was served upon the following person by first-class United States mail, postage prepaid on May 10, 2006 as follows: Ms. Lisa J. Case 126 Cross Timber Way Frederick, MD 21702 Administratrix of the Estate of Joyce G. Case Lois E. Stauffer C.`3 r-a p -C) M. 1 _ . fTl Joseph G. Muzic, Jr., Esquire NIKOLAUS & HOHENADEL, L.L.P. 212 North Queen Street Lancaster, PA 17603 (717) 299-3726 (717) 299-1811 - FAX Attorney I.D. No: 55919 jmuzic@n-hlaw.com Attorney for Defendant PAUL E. STONE and BARBARA J. MYERS, as Co-Administrators of the Estate of KENNETH E. WALLACE, Deceased Plaintiffs VS. LISA J. CASE, as Administratrix of the Estate of JOYCE G. CASE, Deceased Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVIL ACTION - LAW NO. 2006-2166 JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Defendant Lisa J. Case, as Administratrix of the Estate of Joyce G. Case, Deceased, in reference to the above matter. NIKOLAUS & /Muzic, Jr., Esquire for Defendant DATE: S-d J - 0 6 w No. 2006-2166 CERTIFICATE OF SERVICE I hereby certify that the foregoing Entry of Appearance was sent by first-class mail, postage prepaid on the date set forth to the following: David Wisneski, Esquire Navitsky, Olson & Wisneski, LLP 2040 Linglestown Road, Suite 303 Harrisburg, PA 17110 NIKOLAUS & HOHENADEL, LLP G. )ffuzic, Jr., Esquire y r Defendant Date: 5 'o2a-0 6 2 F !J N C? 'Y1 --i n r `,S PAUL E. STONE and BARBARA J. MYERS, as Co-Administrators of the Estate of KENNETH E. WALLACE, Deceased, IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA NO. 2006-2166 Plaintiffs V. CIVIL ACTION - LAW LISA J. CASE, as Administratrix of the Estate of JOYCE G. CASE, Deceased, Defendant JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 To: Counsel and Parties of Record Paul E. Stone and Barbara J. Myers, as Co-Administrators of the Estate of Kenneth E. Wallace, Deceased, Plaintiffs intend to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. Respectfully submitted, NAVITSKY, O ON & W SNESKI LLP David S. Wisneski, Esquire I.D. No. 58796 2040 Linglestown Road, Suite 303 Harrisburg, PA 17110 717/541-9205 Counsel for Plaintiffs Date: July 24, 2006 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAUL E. STONE and BARBARA J. MYERS, as Co-Administrators of the Estate of KENNETH E. WALLACE, Deceased, Plaintiffs V. LISA J. CASE, as Administratrix of the Estate of JOYCE G. CASE, Deceased, Defendant NO. 2006-2166 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Commissioner of State Police 1800 Elmerton Avenue Harrisburg, PA 17110 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all photographs or video taken of incident number HOl- 1499162 that occurred on July 28 2005 in the Camp Hill Boro Cumberland County. The nhotow2hs are filed under ID Number 2005-0448. at Navitskv Olson & Wisneski LLP 2040 Linglestown Road Suite 303, Harrisburg. PA 17110. (Address) You may deliver or mail legible copies of the documents or produce things requested this subpoena, together with the certificate of compliance, to the party making the request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you failed to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING: NAME: David S. Wisneski, Esquire ADDRESS: 2040 Linglestown Road, Suite 303, Harrisburg, PA 17110 TELEPHONE: (717) 541-9205 SUPREME COURT ID # 58796 ATTORNEY FOR: Plaintiffs BY THE COURT: Prothonotary/Clerk, Civil Division Seal of the Court Deputy CUMBERLAND COUNTY, ss: served On the day of 1-11, (name of person served) with the foregoing subpoena by: (Describe method of Service) I verify that the statements in the Return of Service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unworn falsification to authorities. Date: (Signature) CERTIFICATE OF SERVICE I, Lois E. Stauffer, an employee of the law firm of Navitsky, Olson & Wisneski LLP hereby certify that a true and correct copy of the foregoing Notice of Intent to Serve a Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21 was served upon the following person by first-class United States mail, postage prepaid on July 24, 2006 as follows: Joseph G. Muzic, Jr., Esquire Nikolaus & Hohendal, LLP 212 North Queen Street Lancsater, PA 17803 Counsel for Defendant Bi d L4 Lois E. Stauffer ?? r> .a ,-.:, ?,, ' ?? _ . -_ PAUL E. STONE and BARBARA J. MYERS, as Co-Administrators of the Estate of KENNETH E. WALLACE, Deceased, Plaintiffs V. LISA J. CASE, as Administratrix of the Estate of JOYCE G. CASE, Deceased, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA NO. 2006-2166 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.21 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Paul E. Stone and Barbara J. Myers, as Co-Administrators of the Estate of Kenneth E. Wallace, Deceased, Plaintiffs, certify that: (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served; (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate; (3) No objection to the subpoena has been received; and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. Respectfully submitted, NAVITSKY, O ON & WISNE9U LLP David S. isneski, Esquire I.D. No. 58796 2040 Linglestown Road, Suite 303 Harrisburg, PA 17110 717/541-9205 Counsel for Plaintiffs Date: August 29, 2006 PAUL E. STONE and BARBARA J. MYERS, as Co-Administrators of the Estate of KENNETH E. WALLACE, Deceased, IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA NO. 2006-2166 Plaintiffs V. LISA J. CASE, as Administratox of the Estate of JOYCE G. CASE, Deceased, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED )ENA TO PRODUCE DOCUMENTS -: To: Counsel and Parties of Record Paul E. Stone and Barbara J. Myers, as Co-Administrators of the Estate of Kenneth E. Wallace, Deceased, Plaintiffs intend to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. Respectfully submitted, NAVITSKY, %$ON & David S. Wisneski, Esquire I.D. No. 58796 2040 Linglestown Road, Suite 303 Harrisburg, PA 17110 7171541-9205 Counsel for Plaintiffs LLP Date: July 24, 2006 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAUL E. STONE and BARBARA J. MYERS, as Co-Administrators of the Estate of KENNETH E. WALLACE, Deceased, Plaintiffs V. LISA J. CASE, as Administratrix of the Estate of JOYCE G. CASE, Deceased, Defendant NO. 2006-2166 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Commissioner of State Police 1800 Elmerton Avenue Harrisburg, PA 17110 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all photographs or video taken of incident number 1-101- 1499162 that occurred on July 28 2005 in the Camp Hill Boro Cumberland County. The photographs are filed under ID Number 2005-0448. at Navitsky Olson & Wisneski LLP 2040 Linglestown Road Suite 303, Harrisburg, PA 17110 (Address) You may deliver or mail legible copies of the documents or produce things requested this subpoena, together with the certificate of compliance, to the party making the request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you failed to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING: NAME: David S. Wisneski, Esuuire ADDRESS: 2040 Linglestown Road, Suite 303, Harrisburg, PA 17110 TELEPHONE: (717) 541-9205 SUPREME COURT ID# 58796 ATTORNEY FOR: Plaintiffs BY THE COURT: Prothonotary/Clerk, Civil Division Seal of the Court Deputy CERTIFICATE OF SERVICE I, Lois E. Stauffer, an employee of the law firm ofNavitsky, Olson & Wisneski LLP hereby certify that a true and correct copy of the foregoing Notice of Intent to Serve a Subpoena to Produce Documents and Tbings for Discovery Pursuant to Rule 4009.21 was served upon the following person by first-class United States mail, postage prepaid on July 24, 2006 as follows: Joseph G. Muzic, Jr., Esquire Nikolaus & Hohendal, LLP 212 North Queen Street Lancsater, PA 17803 Counsel for Defendant LA A Lois E. Stauffer CERTIFICATE OF SERVICE I, Lois E. Stauffer, an employee of the law firm of Navitsky, Olson & Wisneski LLP hereby certify that a true and correct copy of the foregoing Certificate Prerequisite to Service of a Subpoena Pursuant to Rule 4009.21 was served upon the following person by first-class United States mail, postage prepaid on August 29, 2006 as follows: Joseph G. Muzic, Jr., Esquire Nikolaus & Hohendal, LLP 212 North (queen Street Lancsater, PA 17803 Counsel for Defendant rlll6c_. F. :N . Lois E. Stauffer V \j Tf Qy . J _ PAUL E. STONE and BARBARA J. MYERS, as Co-Administrators of the Estate of KENNETH E. WALLACE, Deceased, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA NO. 2006-2166 V. CIVIL ACTION - LAW LISA J. CASE, as Administratrix of the Estate of JOYCE G. CASE, Deceased, Defendant JURY TRIAL DEMANDED PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please mark the above-captioned action settled, ended and discontinued. Respectfully submitted, NAVITSKY, OL?ON & WIS David S. WisAeski, Esquire I.D. No. 58796 2040 Linglestown Road, Suite 303 Harrisburg, PA 17110 717/541-9205 Counsel for Plaintiff KI Date: August 14, 2007 CERTIFICATE OF SERVICE I, Lois E. Stauffer, an employee of the law firm of Navitsky, Olson & Wisneski LLP hereby certify that a true and correct copy of the foregoing Praecipe to Discontinue was served upon the following persons by first-class United States mail, postage prepaid on August 14, 2007 as follows: Joseph G. Muzic, Jr., Esquire Nikolaus & Hohendal, LLP 212 North Queen Street Lancsater, PA 17803 Counsel for Defendant George B. Faller, Jr., Esquire Martson, Deardorff, Williams & Otto 10 East High Street Carlisle, PA 17013 Douglas C. Yohe, Esquire Latsha, Davis, Yohe & McKenna, P.C. 1700 Bent Creek Blvd., Ste. 140 Mechanicsburg PA 17050 Mr. Rick Bruno Corporate Claims Management P.O. Box 2308 Ivyland, PA 18974 - A(R,&, F_ A"44 Lois E. Stauffer r=- crx _5 rrr