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HomeMy WebLinkAbout96-01730 ,II 0,,1 " " ~ . , ' ~\ I 'f ' I I I ~ I , I J !~ " \" ,~ , I ....... I i . ~ 103. Any actions of Defendants were privileged. 104. Any actions of Defendants were justified. 105. Any actions of Defendants were consented to by Plaintiff. 106. At all times, Defendents acted upon the reasonabla and good faith belief that their actions wero lawful and that they wars doing right. 107. Defendants ers entitled to various immunities end limitations on damages under the laws of this Commonwealth and cleim is made therefor. WHEREFORE. Defendants demand that Plaintiff's complaint against them be dismissed, A true and correct copy of Defendants' Answer with New MaUer is attached hereto, incorporated herein by reference and marked as Exhibit" A". 5. The Answer with Now Mattllr was endorsed with a Notice to Plead and was originally sent via U.S. Mall. first class, postage prepaid to the Plaintiff in core of the Cumberland County Prison, P.O. Box 820. Carlisle, Pennsylvania 17013, however the some was returned and was resent to the Plaintiff again via U.S. Mail, first class, postage prepaid in care of the Cumberland County Prison at 1101 Claremont Road, Carlisle. Pannsylvania 17013, This mailing was not raturned to Defendants' counsel. 6. Plaintiff has failed to file a responsive pleading to Defendants' New Matter, and more than twenty (20) days have passed from the date of service of the Answer and New Matter upon the Plaintiff. A true and correct copy of the docket entries on this case is attached hereto, incorporated herein by reference and marked as Exhibit "B". 7. As a result of the Plaintiff's failure to admit or deny the averments set forth in the Defendants' New Matter. by law, the averments contained in Defendants' New MattElr are deemed admiued pursuant to Pa,R.C.P, 1029Ib), 8. As a rosult of the deemed admittol of the averments contained in Defendants' New Matter, there are no genuine issues 01 material fact to be decided, and the Plaintiff has no cause of action against the Defendants. Johnson, Dume, Stewart" Weidner By: C. Roy Weidner, Ir. 1.0. No. 19'30 301 Market Street P. O. Box 109 Lemoyne, PeMsylvania 17043-0109 (717) 761-4'40 FilE COpy Attorneys for Defendants CORY A. CORMANY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-1730 CIVIL TERM v, CIVIL ACTION - LAW FRANK TEANEY, CURTIS COLBERTSON, TRAVIS SHENK, JACK WALLACE, MICHAEL ILE, JURY TRIAL DEMANDED NOTICE TO PLEAD r', , -, C' 0;.', -" . .. , ~! .. ., , .. '.1 , . r'..) ... ~..' c;, ~ oJ f~ : . -." - ~ - . - - . .. ~. C;".' .. I . I .o( .- ....11 :-:~ Defendants TO: Cory A. Cormany % Cumberland County Prison P. O. Box 820 Carlisle, PA 17013 AND NOW. this 26'" day of April, 1996, you are hereby notified to plead responsively within twenty (20) days of the date of service hereof, or Judgment may bs entered against you. ~:HN;~:;');:;:NER lI(I::V~~ 1.0, No. 19530 301 Market Street Post Office Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Defendants I'YS510 H96.-01730 Cumberland County Civil Case CORMANY CORY A (VS) TEANEY Prothonotary's Office Page Inquiry FRANK ET AL 1 Reference No..: Filed. ......,: 4/01/19~~ Ca~e Type."..: COMPLAINT Time..!.....,: / 18: Judgmeht. . , , . . : .00 Execut on Date 0 08/ 0 Judge Assigned: SHEELY HAROLD E PJ Sat/Dis/Gntd, , a/a / 0 JurR Trial..., Hii er ,!ourt 1 H er Court 2 ....................................................... ........................ General Index Attorney Info CORMANY CORY A PLAINTIFF TEANEY FRANK DEFENDANT WEIDNER C ROY JR COLBERTSON CURTIS DEFENDANT WEIDNER C ROY JR SHENK TRAVIS DEFENDANT WEIDNER C ROY JR WALLACE JACK DEFENDANT WEIDNER C ROY JR ILE MICHAEL DEFENDANT WEIDNER C ROY JR ......**..................................................................**.... * Date Entries * ................................................................................ 84/81/96 4/ 1/96 04/10/96 COMPI,AINT - CIVIL ACTION PETITION - PROCEED IN FORMA PAUPERIS GRANTED HAROLD E SHEELY P SUDGE SHERIFF'S RETURN FILED Liti;ant.: TEANEY FRANK SERV 0 4/9/96 Date RETURNED 4/19/96 Costs,...: SO,OO Pd By: 00/00/0000 04/10/96 SHERIFF'S R~TURN FILED Liti~ant.: COLBERTSON CURTIS SERV 0 4/8/96 Date RETD 4/19/96 Costs....: SO,OO Pd By: 00/00/0000 04/10/96 SHERIFF'S R~TURN FILED Liti~ant.: SHENK TRAVIS SERV 0 4/8/96 Date RETD 4/19/96 Costs...,: SO.OO Pd By: 00/00/0000 04/10/96 SHERIFF'S R~TURN FILED Litigant.: WALLACE JACK SERVED 4/8/96 Date/RETD 4/19/96 Costs, ...: SO,OO Pd By: 00/00/0000 04/10/96 SHERIFF'S R~TURN FILED Liti~ant.: ILE MICHAEL SERV 0 4/8/96 Date RETD 4/19/96 Costs.".: $0.00 Pd By: 00/00/0000 84/26/96 PRAECIPE TO ENTER APPEARANCE FOR DEFENDANTS BY C ROY WEIDNER JR ESQ 4/26/96 ANSWER TO PLAINTIFF'S COMPLAINT ................**......*.............................................**........ * End of Case Information * ....................................................**.........**.....**........ THE APPLICATION IS HEREBY TRUE COpy rROM RECOilO In T estimoi1'1 'IInereof, I h~rn unto ~l my hall" ~;;\J t"e f.('.ll L.! 30Ild r;(lurt ;l~ Car;i~Ii:, I>"J. i'h~Lli.o:i!.~'!.IY. (ll~~_, 19.~:t4 \ ~ _ \L .~ !..lJ~li.dlO. Ill,' - Prothonotary COUNT THREE Ca", A. CtJ"".nv v. F,.nk rHn.V 25. Admitted In "-rt. D""led In P,rt, Peregrephs 1 through 24 hereof ere Incorporeted by reference herein. 26-29. D.nled. 30. WHEREFORE. Defendent demends thet Plaintiff's complaint against him be dismissed. COUNT FOUR Corv A. Corm.nll II. Curtis Co/b.rtson 31. Admitted In ".rt. Dlllled In P,rt. Paragraphs 1 through 30 hereof ere incorporeted by reference hersln. 32.35. D""ac/. 36. WHEREFORE, Defendent demands that Plaintiff's complelnt egalnst him be dismissed. COUNT FIVE Corv A. Corm.nll II. Curtis Co/b.rtson 37. Admitted In ".rt. D.nled In Plrt. Paregrephs 1 through 36 hereof ere Incorporeted by reference herein. 38.41. D.nled. 42. WHEREFORE, Defendent demends thet Plelntlff's complelnt egeinst him be dismissed. - -_. COUNT FIFTEEN Co", A. CtJ"".nll II. Mich.., n. 97, Admltttd In ",,,. Denltd In ",,,. Paragraphs 1 through 98 hareof ere Incorporated by raferenca herein. 98-101. Denltd. 102. WHEREFORE, Dsfandant demand, that Plaintiff', complaint against him ba dismissed. NEW MA TTER 103. Any actions of Dafendants were prlvilegsd. 104. Any actions of Defendants were justified. 105. Any actions of Defendants were consented to by Plaintiff. 106. At all times, DlIfendants acted upon the reasonable and good faith belief that their actions were lawful and that they were doing right. 107. Defendants are sntitled to vsrlous Immunities and IImitetlons on damages under the laws of this Commonwealth snd claim is mede therefor. WHEREFORE, Defsndants demand that Plaintiff's complaint against them be dismissed. JOHNSON, DUFFIE, STEWART & WEIDNER ~~ By: .. . . Roy Weldn r, Jr 1.0. No. 19530 301 Msrket Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 Attorneys for Defendants :&2& 73 (e) Any other sourl'esl (NO) I have rel'elved an amount upon Investment status and withdraw from brokeralle firm, and have expended the ex('esslve rate as In said form for the purpose of student loan and unsel'ured venture. I did receive employment walles In the form of taxed Income In the months of January and I:ebruary of the year 1')')5, These monies have also been distributed In order to se('ure l'redlt and apply the purpose of the application al'knowledlled for Investment status to debtor. I have also rel'c\ved Ten Dollars (10.00) weekly over the past twelve (Il) months (Ilifts). ,i. Do you own any ('ash, or do you have money In checklnll or savlnll al'l'ounts. (Y!:S) I have approximately Twenty and 00 Dollars In my chel'klnll/savlnll acwunt. 4. Do you own or have any Interest In any real estate, stol'ks, bonds, notes, automobiles or other valuable property (excludlnll ordinary household furnlshinlls and c10thlnllfl (YI,S) I have Interest in real estate for the purpose of unsecured loan and the applkation of debtor. I have a motorcycle which has been mnflscated by the Carlisle Police Department. I will value this initial property at approximately Hfty Two Thousand anJ 00 Dollars. I l'an spel'ulate household furnlshlnlls and c10thlnll at present. 5. Ust the persons who arc dependent upon you for support, state your relationship to those persons and Indkate how mUl'h you contribute toward their support. I have an unsecured loan which Is with my father and the payments arc In eXl'CSS of approximately One Hundred and 00 Dollars monthly (100.00). I have a student loan that my father has assisted me with. I havc a daughter, whkh Is of relevant important'e to prol'eedlnll the instant of financial obligation and l'ustody/ visitation rlllht. I declare under penalty of perjury that the forelloinllls true and l'orre('t. l'xel'utcdon__# L{ '1 C ~OLY(~ . Cory A. corman? .~ . ' d The plaintiff will note that the applkatlon does proreed the Issue of l"rime and Is for the applied Issue of immunity and the Commonwealth of Pennsylvania, It docs prm'eed the issue of order and the obJert of willful misl"lmdul"t. Whercf'ore the Plaintiff Cory Corman)' docs submit that the Honorahle Courts of Cumberland County Ilrant the petitioner's request so that he may proreed as due l"ourse. The applkation docs al"knowledlle forma paupcrls prm'cedlnll and thc Tltlc 18 Pennsylvania Consolidated Statutes Annotated. The application is hereby denied. The application Is hereby Ilranted. -JJ it',1 t-' ~ I'I.AJNTlH CORY A, CORMANY IN TIII:COlIIU OI'COMMON PI.I:ASOI' CUMIIERIAND COUNTY, PI:NNSYI.V ANIA v, CASliNO. (j(... /1 Jo (!wd' ,i...-. DlH:NDANT I'RANK TEANEY Cll RTIS COI.IIERTSON TRAVIS SIIENK JACK WAl.lACI: MICIIAI:I. II.E CIVil. ACTION - CRIMINAL lAW JURY TRIAL COMPlAINT AND NOW, comes Cory A. Cormany, Plaillliff, and sets forth causes of action against the above Defendants, whereof the followinll is a statement: 1. Plaintiff is Cory Cormany, an adult individual residinll in Cumberland County, I'c.nnsylvania. I.. Defendants Frank Teaney, Curtis Colbertson, Jack Wallace, Michael lie, and Travis Shenk arc adult individuals who arc employed at Cumberland County Prison. 3. Plaintiff Cory Cormany is a high ,,'hool graduate in allending South Middleton School District. lie is also academically achieved through lIarrisburg Area Community College, University of Nebraska, and Pennsylvania State University. The Plaintiff is a taxpayer and registered voter in the County of Cumberland and a citizen of the United St.lIes of America. 4. On or about January 13rd, of the year I ()'lh, at or about approximately 3:()() PM, the Plaillliff was secured in his assigned cell located in Cumberland County Prison. The assigned cell heing, Housing Unit 11 numbered four (4). 5. On 01' about the aforesaid approximate time the Plaintiff was writing a leller \0 the lIonorable Judlle Sheely' of the Courts lIf the Common Pleas In order to Inquire about his relea~e from Cumberland County Prison and to al'knowledlle al'tion. b. On or about .i: 10 I'M, January l.ird, of the year I <)<)b, the Defendants I'rank Teaney, Curtis Culbertson, Jack Wallace, Mil'hael lie, and Travis Shenk did enter the holdlnll l'ell of the Plaintiff Cory Cormany, and did assault, harm, shock, beat, threaten, and bond aile him at the Cumberland County Prison. Then did tie him to a board for approximately twelve (12) hours where they did kkk, step, shock and punch him. 7. Previous to the aforesaid date and time the Plaintiff Cory Cormany had been denied food and beveralle for an Indefinite determined time, alonll with other privilelles. 8. Pursuant to the allelled the Plaintiff did altend a hearlnll in the Court of Common Pleas, Cumberland County, and was llranted mediral altentlon at the Cumberland County Prison on or about January 24th, of the year 1 ')<)b. 'l. The Plaintiff was transported on 01' about '):()O M,I, January l4th, of the year 1 'l'lb, by the Cumberland County Sheriff's Department. The 1I0norable Judlle Georlle lIoffer did preside the aforesaid hearlnR. 10. The Plaintiff Cory Cormany has suffered pain for injuries to his lells, arms, head, and lleneral bodily areas from the anions taken by the Defendants I'rank Teaney, Curtis Culbertson, Jack Wallace, Mil'haellle, and Travis Shenk. 11. The Plaintiff has suffered public humiliation, mental anllulsh, emotional distress, and solitary confinement concerninll Incarceration. lie has suffered a loss of television, telephone, usual m(~als, open yard, llymnasium and recreational time, bathinll leisure, visitation, library, medlral altentlon, and work release privllelle. 12. The Plaintiff was Incarcerated in Cumberland County Prison in lieu of Twenty Bve Thousand Dollars in ball (l5,OOO.OO), COllN'IONI: COI~Y A. CORMANY V. I'RANK HANEY PENNSYLVANIA CIUMLS COD!: SOI.lCITATION, CIUMINAI. CONSPIIlACY, AND CONTLI\Wr - <JO I. ')o:l, ')O,~. ')04, AND <)05 13. The averments set forth In Parallraphs one throullh twelve (I-Il) of the Complaint arc Incorporated by reference as If set forth at lenllth. 14. The crimes of Solicitation, Conspiracy, and Contempt arc serious as havlnll happened in Cumberland County Prison. The Inddents arc listed In the statements one throullh twelve (I - I l) and arc respertfuHy submitted within, pursuant to exhibits: A-Z. 15. The Defendant !'rank Teaney did conspire and solidt causinll contempt and Injury to the Plaintiff Cormany. Ill. The Defendant I;rank Teaney did conspire and solidt to the crimes of Assault, Harm, Recklessly Lndanllerinll Another Person, Terroristic Threats, and Offidal Oppression. It has caused the Plaintiff Corman)' pain and sufferinll for injury, mental anlluish, public humiliation, emotional distress, and inc;\rceration with loss of prlvile~e. 17. By reason of the afon:said matters the Plaintiff COl")' Cormany has suffered Injury, pain, mental anllulsh. public humiliation, emotional distress, and incarceration with loss of privilclle. 18. WIIl:RHOIU', the Plaintiff Cory Cormany claims from the Defendant, (;rank Teaney, In an amount excess of Twenty Hve Thousand and 00 Dollars (l5,OOO.OO) plus cost of suit. COUNI'IWO COIW ^. C()RM^NY V. m^NK TI:J\NEY PENNSYLV^NI^ CIUMi:S COD\: ^SSMIU' Do:l, DHlNlTlONS "II^RM" 4501, IU,CKLESSLY END^N<;!,RlNc; ^NOTIIEH pmSON D05, TERROIUSTIC TI IHI:J\TS DOh, ^ND OIHCI^L OPPIU,SSION 5.iOl 1 <). The averments set forth in Paragraphs one through twelve (\ -1:l) of the Complaint are Incorporated hy reference as If set forth at length. lO. The crimes of ^ssault, lIarm, Recklessly \:ndanKerlng ^nother Person, Tcrrorlstic Threats, and Official Opprcssion are serious as having happcned In the Cumherland County Prison and to the said Plaintiff. ll. On or ahout January Brd, of the year I ()<)h, the Plaintiff Cormany was in his assigned ccll writing a lctter to the Courts of the Cumherland COUl1ly pursuant to ^rticle I of the U.S. Constitution when thc Dclendant Tcaney did enter the assigned cell and did commit the arts of crime hcrein. It is explained in the statements one throuKh twclve (1-1 L) and set forth at IcnKth pursuant to exhihits:^-Z. n. The Plail1liff Cory Cormany did suffer injury to his head, leK, arms, and Kcneral hodily area~i from the Dclendant's artions, and did suffer pain for injury, mcntal anKuish, puhllc humiliation, emotional distress, and incarceration with loss of privileKc. B. By reason of the aforesaid, the Plaintiff Cory Cormany has suffered pain, injury, mcntal anKulsh, puhlic humiliation, cmotional distress, and incarccration with loss of privileKe. L4. WIIHUHlRE, the Plaimiff Cory Cormany claims from thc Defendant, I'rank Tcaney, in an amount e.xccss of Twenty l'ivc Thousand and 00 Dollars (L5,OOO.OO) plus cost of suit. c()l/NTTlIlu:t: CORY ^. CORM^NY V. m^NK TlANI:), CIVIL M:TION - LAW Wll.IHIl. MISCONDUCT ^ND TIIIUATS ^ND OTIII]{ IMl'lHlI'l'R INIH/loNCI: IN OI'l'ICI^L ^ND POI.ITIC^l.l\I^'ITIR'i 470l l5. The averments set forth in I'arallraphs one throul!h twelve (1-12) of the ComplaInt arc incorporated hy reference as if set forth at lenllth. lb. The crime of Threats amI Other Improper Inlluence in Onklal and Political Mailers is serious as havinll happened in Cumherland Coullly Prison and to the said Plaintiff. 27. On or ahout January 23rd. of the year 1 ')')(,. the Plaintiff was in housinll unit B, cell 114. writinll a leller to the Courts of the Cumherland Coullly pursuant to ^rtirles I. IV, V. VIII, and XIV of the U.S. Constitution when the Defendant Teaney did enter the assillned cell and did assault, shock, harm, heat, threaten, and honda!!,! him. Then did tic him to a hoard for approximately twelve ( 1 l) hours where he did kick, step, and punch him. 21\. The Plaintiff Cory Cormany did suffer injury \0 his head, lells. arms, and Ileneral hodily areas from the Defendant's actions and did suffer pain for injury. mental anlluish, puhlic humiliation, emotional distress, and incarceration with loss of privilelle. l'). By reason of the aforesaid mailers the I'laillliff Cory Cormany has suffered injury, pain, mental anlluish, puhlic humiliation, emotional distress, and incarceration with los.s of privilclle, 30, WHERHOIU:, the Plaintiff Cory Cormany r1aims from the Defendalll, Frank Teaney, in an amount ex,'ess of Twenty Hve Thousand and O() Dollars (25,OOO.()()) plus cost of suit. COlINTIOllR CORY A, CORMANY V. ClI KI'lS COl.BElnSON PENNSYl.VANIA CfUMES COni: SOl.lCITATION, ClUMINA!. CONSPIJ{ACY, AND CONTI:t\lI'f - 'I()I, 'IOZ, 'I():!, '104, AND'J05 .il. The averments set forth in Paral4raphs one throul4h twelve (l-ll) of the Complaint are incorporated hy reference as If set forth at lenl4th. .il. The nlmes of Solicitation, Conspiracy, and Contempt are serious as havinK happencd in Cumhcrland County Prison. Thl' Inridents are Iistcd In thc stawmcnts one thr<lUKh twclvc (1-1 L) and are rcspcctfully suhmillcd within, pursuant to exhihits: A-Z. .B. The Defendant Curtis Colhertson did conspire and solicit causinK l"(mtcmpt and injury to the Plaintiff Cormany. .i4. The Defendant Curtis Colhertson did conspire and solicit to thc crimes of Assault, lIarm, Recklessly EndanKerinl4 Another Person, Tcrroristic Threats, and Official Oppression. It has causcd the Plaintiff Cormany pain and sulTerinK for injury, mental anKuish, puhllc humiliation, emotional distress, and incarceration with loss of privi1cKe. 35. By reason of the aforcsaid malleI's the Plaintiff Cory Cormany has suffered injury, pain, mental anKulsh, puhlic humiliation, emotional distress, and incarccration with loss of privileKe. 36. WIIEIUTOIU:, the Plaintiff Cory Cormany claims from the Defendant, Curtis Colbertson, in an amount excess of Twenty Hve Thousand and 00 Dollars (25,000.00) plus cost of suit. COllNT riVE CORY A. CORMANY V. CURTIS COI.llI:lnSoN PENNSYLVANIA CIUMl:S COD!: ASSAlH:r DOL, DHINITlONS "IIARI\I" 4501. RECKl.IiSSLY ENDANC;mIN(j ANOTlIEH Pl:RSON 2105, TERIWIUSTIC TIIIUATS D( lh, AND OHIClAL OPPI~E"SION 530 I 37. The averments set forth in ParaKraphs one throuKh twelve (1-12) of the Complaint are incorporated hy reference as if set forth at lenKth. .ill. The crimes of Assaull, Harm, Recklessly EndanKerin~ Another Person, Terroristic Threats, and Oflkial Oppression are serious as havin~ happened in the Cumherland County Prison and to the said Plaintiff. 3'). On or ahout January 23rd, of the year 1 'l'll>, the Plaintiff Cormany was in his assi~ned cell writinK a letter to the Courts of the Cumherland County pursuant to Article I of the U.S. Constitution when the ()efendalll Colhertson did elller the assiKned ,'ell and did commit the acts of crimc herein. II is explained in the statements one throuKh twelve (1-12) and set forth at len~th pursuant to exhihits: A- Z. ..10. The Plaintiff Cory Cormany did suffer injury to his head, IcK, arms, and ~eneral hodily areas from the Defendant's actions, and did suffer pain for injury, mental an~uish, puhlic humiliation, emotional distress, and incarceration with loss of privile~e. 41. My reason of the aforesaid, the Plaintiff Cory Cormany has suffered pain, Injury, mental an~uish, puhlic humiliation, emotional distrcss, and incarceration with loss of privilcKe. 42. WIIEHHORI:, the Plaintiff Cory Cormany claims from the Defendant, Curtis Colhertson, in an amount e"l'ess of Twenty Bve Thousand and 00 Dollars (25,000.00) plus cost of suit. COUNTSIX CORY ^' COHM^NY V. CURns COI.BLlnSON CIVil. ^CIION - lAW WIl.lHII. MISCONDUCT ^ND TIIIUATS ^ND OTHER IMI'HOI'I:R INIUII'NCI: IN OI;HCI^1. ^ND POLl nC^L MAITIR-; 4702 4.i, The avcrmellls set forth In I'arallraphs one throullh twelve t I-Il.) of the Complaint are Inrorporated hy referenre as if set forth at lenllth. .Jot The crime of Threats and Other Improper Inlluenre In Ollkial and Politkal Matters is serious as havinll happened In Cumherland County Prison and to the said Plaintiff. 45. On or ahout January l..{rd, of the year I <)')h, the Plaintiff was in housinll unit B, rell 114, writinll a letter to the Courts of the Cumherland County pursuant to ^rticles I, IV, V, VIII, and XIV of thr: u.s. Constitution when the Defendant Colhertson did enter the asslllned rell and did assault, shork, harm, heal, threaten, and hondalle him. Then did tic him to a hoard for approximately twelve (Il.) hours where he did kkk, step, and punrh him. .J(,. The Plaintiff Cory Cormany did suffer injury to his head, lells, arms, and Ileneral hodily areas from the Defendal1l's actions and did sutler pain for Injury, mental anllulsh, puhllr humiliation, emotional distress, and Inrarreration with loss of privilelle. 47. By reason of the aforesaid mailers the Plaintiff Cory Cormany has suffered Injury, pain, mental anllulsh, puhllr humiliation, emotional distress, and Inrarrcratlon with loss of privilellc. 48. WIIEHI'I'OIU:, the Plaintiff Cory Cormany claims from the Defendant, Curtis Colbcrtson, In an amount exress of Twenty Five Thousand and 00 Dollars (l.5,OOO.OO) plus rost of sull. COllNTSI:VIN CORY ^. CORM^NY V:m^VlS SIII:NK I'I:NNSYLV^NI^ CIUMLS com SOl.lCITArION, CIUMINJ\L CONSPIH^CY, ^ND CON'lu,wr. '101, 'IOL, 'IO.~, '104, ^ND<)05 4<). The averments set forth in Parallnlphs one throullh twelve (1-l:l) of the Complaint are incorporated hy reference .IS if set forth at lenllth. 50. The crimes of Solicitation, Conspiracy, and Contempt are serious as havlnK happened in Cumherland County Prison. The incidents are listed in the statements one throullh twelve (1.11.) and are respectfully suhmitted within, pursuant to exhihits: ^.Z. 51. The Defendant Travis Shenk did conspire and solicit causinll ('()ntempt and injury to the Plaintiff Cormany. 51.. The Defendant Travis Shenk did conspire and solicit to the crimes of ^ssault, Harm, Recklessly l:ndanllerinK ^nother Person, Terroristic Threats, and Official Oppression. It has caused the Plaintiff Cormany pain and sufferinll for injury, mental anllulsh, puhlic humiliation, emotional distress, and Incarceration with loss of privile!(e. 53. By reason of the aforesaid matters the Plaintiff Cory Cormany has suffered injury, pain, mental an!(uish, puhlic humiliation. emotional distress, and incarceration with loss of privilclle. 54. WIIl:RHOIU:, the Plaintiff Cory Cormany claims from the Defendant, Travis Shenk, in an '''nount excess of Twenty Hve Thousand and 00 Dollars (l5,OOO.OO) plus cost of suit. COllNTUcalT CORY A. COI~MANY V. T1V\VIS SIIENK PEN NSYl.VANIA CIUMES COI1l, ASSAUI:r DOl, DlHNITlONS "HARM" "SOl, RECKI.I:SSl.Y ENDAN(iE!UN(j ANOTllm PI:R'iON DOS, THUUlRISTIC TIIIU:A'IS DOh, AND OHICIAI. OPPIUiSSION S.{O I SS. The averments set forth In Parallraphs one throuKh twelve (I-Il) of the Complaint an- Inwrporated by reference a~ If set forth at lenKth. Sf>. The crimes of Assault, Harm, Recklessly Endanllerinll Another Person, Terrorlstk Threats, and Offidal Oppression are serious as havinK happened In the Cumberland County Prison and to the said Plaintiff. 57. On or about January nrd, of the year I ')<)f>, the Plahlllff Cormany was In his assiKned cell wrltlnK a letter to the Courts of the Cumberland County pursuant to Article I of the U.S. Constitution when the Defendant Shenk did enter the asslKned cell and did commit the arts of rrlme herein. It Is explained in the statements one throuKh twelve (1-12) and set forth at lenKth pursuant to exhibits: A-Z. 58. The Plaintiff Cory Cormany did suffer injury to his head, lell, arms, and Kencral bodily areas from the Dcfendant's actions, and did suITer pain for injury, mental anKuish, public humiliation, emotional distress, and incarceration with loss of prlvileKe. 5<). By reason of the aforesaid, the Plaintiff Cory Cormany has suffered pain, Injury, mental anKuish, public humiliation, emotional distrl~ss, and Incan-eration with loss of prlvileKc. f>O. WIn:RHORE, the Plaintiff Cory Cormany claims from the Defendant, Travis Shenk, in an amount excess of Twenty Hve Thousand and 00 Dollars (lS,OOO.OO) plus cost of suit. COUNTNINI, CORY ^. COI{M^NY V. TI{^VIS Sm:NK CIVIL ^CnON - lAW WII.lHII. MISCONDUCT ^ND T1I1UATS ^ND OTIII:R IMI'I{OPI:I{ INIUII:NCI: IN OHICIM, ^ND I'OUTIC^1. M^'rrmS 470l ()\. The averments set forth in l'araRraphs one throullh twelve (I-Il) of the Complaint are Inrorporated by reference as If set forth at lenRth. Cil. The rrlme of Thrcats and Other Improper Inl1uenre in Oflklal and I'olitlral Mailers Is serious as havlnll happcned In Cumberland County Prison and 10 Ihc said Plaintiff. Clio On or about January Lird, of Ihe year I l)<)() , thc Plalnllff was In houslnll unil H, cell //4, wrilinll a leller \0 Ihe Courls of thc Cumbcrland County pursuanl \0 ^rtldcs I, IV, V, VIII, and XIV of thc U.S. Constitullon whcn Ihe Defcndanl Shcnk did enlcr the assillncd cell and did assault, shork, harm, beat, threatcn, and hondallc him. Thcn did tie him to a board for approximately twclve (Il) hours wherc he did kiCk, stcp, and punch him. 64. The Plalmlff Cory Cormany did suffer Injury to his head, lells, urms, and Ilcneral bodily arc:\s from the Dcfendant's actions and did suffer pain for Injury, mental anllulsh, public humlliallon, emolional distress, and Incan-eratlon wilh loss of privilelle. 6S. By reason of the aforesaid matters the Plaintiff Cory Cormany has suffered Injury, pain, mental anllulsh, public humillalion, emotional distress, and Inrarrerutlon wilh loss of privllellc. 66. WIIEI{IHlRI;, the Plaintiff Cory Cormany r1alms from the Defendant, Travis Shenk, in an amount ex('css of Twenty Five Thousand and 00 Dollan US,OOO.OO) plus rost of suit. COllNTIlN COI{Y A. COI{MANY V. JACK WALlACE PENNSYl.VANIA C1UMES COm: SOl.lCITATION, CIUJ\IINAl. CONSPIHACY, AND CONTINI'r - <)01, ')OL, ')OJ, ')04, AN D ')05 b7. The .\Verments set fOrlh in Panlllraphs one throullh lwelve (I-IL) of the Complaint arc inrorponlted hy reference as if set fOrlh at lenllth. h8, The rrimes of Solicitation, Conspiracy, and Contempt are serious as havinll happened in Cumherland County Prison. The incidents are listed in the statemel1ls one throullh twelve (I-IL) and arc respectfully suhmitted within, pursuant to eshihits: A-Z. h9. The Defendant Jack Wallace did conspire and solkit causinll contempt and Injury to the I'laillllff Cormany. 70. The Defendant Jack Wallace did mnspire and solicit to the crimes of Assault, lIarm, Recklessly Endanllerinll Another I'erson, Terroristk Threats, and Official Oppression. it has \'aused the Plaintiff Cormany pain and sufferhlll for injury, mental anlluish, puhli<' humiliation, emotiolMI distress, and incarceration with loss of privilelle. 71. By reason of the aforesaid mailers the Plaintiff Cory Cormany has suff\:red injury, pain, mental anlluish, puhlir humiliation, emotional distress, and inrarreration with loss of privilcllc, 1'1.. WIII:HIHmE, the I'laintiff Cory Cormany claims from the Defendant, lark Wallare, in an amount excess of Twenty !'Ive Thousand and 00 Dollars (L5,OO().()O) plus cost of suit. -: COUNT IUMN CORY A. CORMANY V. JACK WAl.IACI: PENNSYLVANIA CIUI\IES COD!: ASSAUlT nOl, DHINITIONS " II A I{I\I " 45ll!, I{ECKl.I~<;SLY I'NDAN<II:RINl; ^NOTlII'I{ pmSON n05, TERRORISTIC TIIRE~TS nOh, ANI)(>IHCI^LOPI)IU~<;SION 5301 73. Thc "vcrmcnts sct forth In P"r"l!r"phs onc thrrlul!h twclvc (I. 11) of thc Compl"lnt arc Inl'Orporatcd by rcfcrcm'c as If sct forth at Icnl!th. 74. Thc ,'rlmcs of ^ss"ult, lIarm, Rccklcssly I:nd"nl!crinl! ^nothcr Pcrson, Tcrroristic Thrcats, and Offici,,1 Opprcsslon arc scrious "s havinK happcncd in thc Cumbcrland County Prison and to thc said Plaintiff. 75. On or about '"nuary Brd, of thc ycar I ()<)(l, thc PI"lntiff Corm"ny w"s in his assiKncd cell writlnl! " Icttcr to thc Courts of thc Cumbcrl"nd County pursu"nt to ^rticlc I of thc U.S. Constitution whcn thc Defcndant Wall"ce did cntcr thc "ssiKncd ccll and did commit thc acts of crlmc hcrcin, It Is cxpl"incd in thc statements one throul!h twclve (1-11) ,,"d sct forth at lenKth pursuant to cxhibits: ^-Z. 7b. Thc PI"intlff Cory Cormany did suffcr Injury to his hcad, ICK, arms, and KCllcral bodily "rcas from thc Defcndant's actions, and did suffcr pain for injury, mental anl!uish, public humili"tlon, cmotlonal distrcss, "lid Im'"rccratlon with loss of privilcKc. 77. liy rc"son of thc "forcsaid, thc Plaintiff Cory Cormany has suffcrcd pain, injury, mental "nl!uish, public humiliation, cmotional distress, and incarccration with loss of privilcllc. 78. WIIJ:lUHlRI:, thc PI"intlff Cory Corm"ny dalms from thc Defcndant, lark Wall"cc, in an "mount I:Xl'CSS of Twenty Bvc Thousand and 00 DolI"rs (15,OOO.OIl) plus ('ost of suit. .1 COllNTIWllVI: CORY ^, CORM^NY V. J^CK W^l.lACI: CIVIl. ^C'1'I0N - lAW WlI,l.l'lIl. MISCONDUCT ^NDTIIRb\TS ^ND OTIII:t{ IMPI{OPI:I{ INFLlII:NCI: IN OHICI^1. ^ND POl.lTlC^1. MA'ITI:R.'i 470l 7<), The averments set forth In Paragraphs one through twelve (1-1 l) of the Complaint are Incorporated by reference as If set forth at length. 80. The ulme of Threats and Other Improper Influence In Offklal and Polltkal Matters is serious as having happened in Cumberland County Prison and to the said Plaintiff. 8 \. On or about January 23rd, of the year 1<)<)(" thc Plaintiff was In housing unit B, cell ",4, writing a letter to the Courts of the Cumberland County pursuant \0 Mtkles I, IV, V, VllI, and XIV of the U.S. Constitution when the Defendant Wallace did enter the assigned cell and did assault, shod" harm, beat, threaten, and bondilgc him. Then did tic him to a board for approxlmatcly twelve (12) hours where he did kkk, step, and punch him. 8:.!. The Plaintiff Cory Cormany did suffer Injury to his head, legs, arms, and general bodily areas from the Defendant's actions and did suffcr pain for injury, mental anguish, public humiliation, emotional distrcss, and in('an'cration with loss of privilege. 83. By reason of the aforesaid matters the Plaintiff Cory Cormany has suffercd Injury, pain, mental anguish, public humiliation, emotional dlstrcss, and inrarceration with loss of privilege. 84. WIII:RHORI:, thc Plaintiff Cory Cormany daims from the Defendant, .lark Wallace, in an amount ex('ess of Twenty Bve Thousand and 00 Dollars US,OOO.OO) plus ('ost of suit. c(llINT'r1IIRrI:lN COI~Y ^' CORMANY V. MICIIAt:l. II.L PLNNSYI.VANIA CIUMLS COlli: SOLICITATION, CIUMINAL CC lNSPIHM;Y, AND CONTI:J\II'I- 'lO I, 'JOL, 'lO.i, IJO~, AND'J05 85. The avermenls sel forlh In Paral(raphs one Ihroul(h Iwelve (1-12) of Ihe Complalnl are irworporaled hy reference as if sel forlh al lenKlh. 116. The crimes of Sollc\lallon, Conspiracy, and Conlempl are serious as havinK happened In Cumherland Counly Prison. The incldenls are IIsled In Ihe slalemenls one Ih.'OUKh Iwel\e (I-I L) and are respectfully suhmllled within, pursuanl 10 exhlhits: A-I.. 1\7. The Defend.lIll Mkhacl lie diu conspire anu solicit causlnK contempt anu Injury 10 Ihe Plaintiff Cormany. llll. The Defenuanl Michael lie diu conspire and solicit 10 the crimes of Assaull, lIarm, I{ecklessly I:nuanKerinl( Anolher Person, Terrorlstir Thn!als, anu Official Oppression. It has caused the Plaintiff Cormany pain and suffering for injury, mental anguish, puhlk humiliation, emotional distress, anu incarceration with loss of prlvi1cKe. IN. By reason of Ihe aforesaid mailers Ihe Plaintiff Cory Cormany has suffered Injury, pain, menial anKuish, puhlic humilialion, emotional uislress, and Incarceration with loss of privl1cKe. 'JO. WIILRHORI:, the PlalntilT Cory Cormany claims from the Defendant, Mirhael lie, In an amounl excess of Twenty Bve Thousand and 00 Dollars l25,OOO.OO) plus COSI of suit. . . COIINTlC)lII\IHN CORY ^. CORM^NY V. t\IICII^I:I. II.L PLNNSYI.V^NI^ C1Ut\ILS CO()l: ^SS^UI:II.7Ol., lllJlNllloNS "IIMM" 4501, RECKIH;SI.Y ENllt.N(iLlUN(; ^NOTIII:R PLHSON DOS, Tl:IUWIUSTIC TIIIU:t\TS DOh, ^NI) ()H:ICI^1. (>I'PI(b'iSI()N S.iO I I)). The averments set forth In Parallraphs one throullh twelve (1-12) of the Complaint arc Inrorporated by rekrenre as if sel forth at lenllth. I)L The rrlmcs of ^ssault, Harm, Rerklessly I:ndanllcrlnll ^nother Person, Terrorlstil' Threats. and Offil'lal Opprcssion arc scrious as havillll happcncd in thc Cumberland Count)' Prison amtto thc said Plainllff. 'H. On or about January 2.ird, of the year 1')%, thc I'laillliff Cormany was in his asslllncd rcll writirlR a leiteI' to the Courts of the Cumberland County pursuanl to ^rtidc I of the U.S. Constitution when thc Dcfcndalll lie did enter the asslglled rell and did ('ommlt thc a('ts of rrime herein. It is cxplained in the statemcnts onc throullh twelve (1-12) and sct forth at length pursuant \0 cxhibits: ^-Z. ,)-t. The Plaillllff Cory Cormany did suiTer injury to his head, IeR, arms, and Ileneral bodily areas from the Defendalll's anions, and did suffer pain for injury, mental anguish, puhlir humiliation, emotional distrcss, and ilH'arrcration with loss of privilef~l:. 95. By reasnn of thc aforesaid, the Plaintiff Cory Cormany has suffcrcd pain, injury, mental anRuish. publir humiliation, cmotional distress, and inrarreration with loss of privilellc. l)(,. WHLI(I:H>I(I:. the Plaintiff Cory Cormany claims from the Defendant, Mil'hacllle. in .10 amount cxrcss of Twenty l'ive Thousand and 00 Dollars (2S,OOO.OO) plus rost of suit. , . C()lINTI'IFIl,EN CORY ^, CORI\I^NY V, I\IICII^,]. 11.1' CIVIL ^CnON - lAW WII.lHII. MISCONDlICT ^Nll TIIIUATS ^ND OTIIl:R IMPIWPI:R INIUIINCE IN ol'l'ICI^1. ^ND POI.ITICM M^rn:ll'; ~702 <J7. Thc avcrments sct forth in Paral(raphs one throul(h twelvc (1-12) of the Complaint arc In('()rporated hy referencc as if set forth at Icnl(th. 9/1. Thc crime of Thn:ats and Othcr Impropcr Intlucnce In Official and Political Mallcrs Is serious as havinl( happened 'in Cumhcrland County Prison and to the said Plaintiff. <)<). On or ahout January 23rd, of the year I <)')(" the Plaintiff was in housinl( unit B, ccll II~, writinl( a letter to the Courts of the Cumherland County pursuant to ^rticles I, IV, V, VIII, and XIV of the lI.S. Constitution whcn the Defendant lie did entcr the assil(ncd cell and did assault, shock, harm, heat, threatcn, and hondal(e him. Then did tic him to a board for approximately twelve ( 12) hours where he did kick, stcp, and punch him. \00. The Plaintiff Cory Cormany did suffer injury to his head, ICl(s, arms, and l(cncral hodily areas from thc Defendant's anions and did suffer pain for injury, mcntal anl(uish, public humiliation, cmotional distress, and incarceration with loss of privilel(c. JO 1. By reason of thc aforcsaid mailers thc Plaintiff Cory Cormany has suffcred injury, pain, mcntal anl(uish, puhlic humiliation, cmotional distress, and incarceration with loss of privilel(e. JOL WIIERHOHL, the Plaintiff Cory Cormany daims from the Defendant, Michacl IIc, in an amount cxcess of Twcnty Hvc Thousand and 00 Dollars US,OO().OO) plus cost of suit. DIICIP'LINANY'NOCIEDUN( I JrilllU.TI: COIllWlY. Cn'J~.~~ _... .h. 1:;11.... It:! L.fI i\PP r: ),~. DA 11 TH,U _.O'O"INIII 0(1.,1)0- IJ5 0' O,HN&[IL_: ~),J ,HI, 'LACI O'O"l:frollll: Unit H 1.l5 nghtlil~\ CHANG~_._.__-,--~_. .~..__*. WITH",," InllWtp. PARKERL_~-,~I(,-(~:::}~L WIICONDUCT IIX'LAIN WHO" WHAt ~~. w~. I:'O~..:. MLl:!.!!!~.!L_ _._.______._'____.._____ On the abovp. di\t(! Lj t i.l(.)prll,~ ilnnt\! 1 y L I.; 00 I.I)Ull, l11m;j t~1 COl\!olANY appn).\dlt.~~.!!!l.......:.;_~..'iJ...~.:.~..~._~ and r~pnrted to m.- th~' t h~ \oJ;!:'. ...u_~,~r~. b~/ lllllldf:IJ AJ.~DEKSON, CO~1AN'i . __~____..' d18Dlavcd~~0lQl!L,jl.1 l\l~; u;l('.I\. r.l W.I'~ Gouii l'~~n~:~t.b.Nl>EI<SO~_~*.~~.:.~..~:L~..__.._.__.._ CORNANY'fJ cf~ll H..ll L.1 ...JI,k hi.1n fl)r .\ "5ko.1I" bdlll.1it. COtU!ANY \rr,'t)u1.d n'H v,iv.. l'i~\lI':P:~;l)}: ,\, . tlnd a brief t r~u..l'n~rlt___~tJJ.:L4_1.~sI....._.:~hiJ:;_,_;!LK~!:.m!~_L..~:';i.c:ul,1 t~g__J.~~_}!hJ::l..~_i.L~J...ti~Y_'::!:.!_'_:._l ~J.~~.~.__~.__._ ..,_ outbidf,l of c,"ll li..ll ~h~\::._'"lJlt/wt:__ycl"~.!L':d\lin~.d bt:t1,Jl~Hn both L\~~~,~!). AN})EH~(_~.~;__.y,~..~___...._~_.~_._~ lQnvl,!i.! to unit A-3. prc...th~:lr~Jl~nfLll'.~m-~nt._:~otJ.l .:.1[t~r thin incj(teTlt. CORMANY, ~~:.__~~~_._____u_ tJ::..lmln-.::d bv Nurr:.! S1lli:.. nnd l.r.!~~.!..tl,.ld _X~l.~~_tJ\rIr:>?_ilL._blte wIJundn. ~G..~~~AN.l,~:.~._.5J.~:.f\ ;'1 \,,,,'d t..r_'______.____.. ~:~;~::.:.4 ~aP::-:~;: l in~~~~~~;~~~;:,~.~,:.~J 1;=---- :~~~:~~=~-~:,X:.-~u ..... ... ~~ -i. .~ C.O. BARROWS. ll. h1 L.~~~\;IT;Kfi""" I. AS AN INMATE OF THE CUMBERLAND COUNTY PRISON. UNDERSTAND THAT I AM ~K; T.O 7f' DIIC:I~LINARY HEARl NO. I FURTHER UNDERSTAND THAT IF I PLEAD OUILTY I ALSO WAIVE MY RIGWr TO THAT HEA"'NO. INMATE ~LEA TO CHAIllGr. IN"'ATE "QNATURl[ lXI DATIO, NOTICI f'~/() . '15 OAT[ 0' HIANINQ P'N-<?S Tlt.4E 0' _ HIA"INO . __.~___ DATE ___.__.__.~.. '.'''_'__._h'_ _____.~_ $IGNATUnIO, -/'..;1-//.6/ /'/ CHAI" PERSON l)O ,1-( /~4.r A/ DISCIPLINARY ACTION IUMt.4A"Y 0' _ ..ill'Y;;;: I kill /1/ A /'1$ e ,",d. 1'1 ~A/l" [) I/~ IV <? r LV' / J hi ~ A r>,- /1/ /~ T#/..: 7::/# r~ ~~J 1)_.L0.L~ 1/ ~ r.: tllt,l+1 /lll/ V 6vll-T:.Y .:;:/ /; ----~--- ~ / . OII'OIITION ,CJ ~ L 6(~/r -~J.J rio/I'I/Irl.- C{//-":JU./1....::Li~0{) /v~ TI;r rl/~"/./'" 1/ H/. J 6".-#/'1'1: ('.:I 1#1-; I::.{!/J,IIJ ;:dU#I) .Li.:../.!.L.._",.,~.J.L_ t'JI-- /;'loU//',u(., A~ ("/.LL~L_.:.-:./~/) /A/ (,It/#ITI:.--t:.;J) . .._____~_..._n_____ _n___n._. ....---------.------cr.o / --'...dJI t1 /.. C.PLr.rLl.CI VI f, T. ".d 1< 6'(/ t-!!!L.I.TART 0.. _ /-. ./ - '1 .11' - '/. c ~_.~_!__,_ Rrt.[ASI__:..:L._""" c YOU HAVE THE RIGHT TO APPEAL THIS OECISION TO II! WAR EN WITHiN TEN 1101 DAYS. ,/ v ~h' ~ /' 10'.0 , J ".-" .' ..........:..,,,( //-..~./ "'1t.4lrN -. J_v- /( J. I 80ARO ) "'EMlnR _ _ _._.::!"~(C. 10ANO MDIUa "IVIIWID IV WAltDI:N (>\ u ,e::; ..../., , . .:- /l ~?f-t~____ j / I - . ) .___..._.___ OAT I ~UMBERLAND \';OUNTY t"RISON DISCIPLINARY PROCEDURf; IWlI6I~ CORMANY. C... B-04 DAn 08-30-9.5 TI'" ---- ---.------..--- cm -T:Ir!D'ipi~~8H.J'-AlAhJR6a' G-1lLOCIt DA'lROOH/&-BLOCIt .'__ CHA.DU-34. g...nJ!lTNG._Dl...l.OCl_Ul' 8:20PM "LACI o. n...lu.I.1r WITHI.... JroKSK'$. MULHOI.LAHD AlID ~L!YO'.S KEKT,BW,,~,D~.~n._B.!~!.__ ""CDHDUCT 'OX'LAlN WHO. WHAT WHI.I. WH'N "OW. AHa WHYI WHILB IN UNIT "C" AlID ASSISTING TOE NURSES INMATE COIIKAII! UJUSED SBVBIlAL IWlBDIGS -ni>>t C/O BYRIa WHO WIll TUB STAn' STATION nnlBTOn TilE---- l'IIOHB. I ASD:D HIK 1'WICE AlID A THIRD T1lIE DB SAID "roC!( YOIr'. I DIE!I l'U:;I:IW~lm(;IUVr.Il ::: ::"':11,0 HIK to LOCK UP.AND DB IlUUSED. IlIHATB ~1lIWIY B~ ~I ::ULI\"1.'OW~ .t.1>PgnAM1Rn .... t'll A 'l'IIIlEATEIfDIC HAHIfIlIl BY TIIEll C/O'S . BELL. , D HAD"ARllIVElIIlJ ESCORT IHllATB COIUWIIY JW:J: TO HIS CELL. WHILE GOIllG BAa to unIT B ur; (COllRANl} IlI!Uftll VIIXI lYlMR.t.nVB AND FOIlCB WAS REQUlIiK.i>-TO PLACB IllKi.TE coiliWiY-nJ HIS CELJ;;--l!ND--OYSTATEMIlfr.--- ----------.--.-----.--.--- ~:~~.O.T 08-30-9.5 =~O,~A.~~=~~~~,:~:~.. t!oo k~!Il :~~~;~~-=~'O:IXI--;~:;~-~__~ I, AS AN INMATE OF THE CUMBERLANO COUNTY PRISON. UNDERSTAND THAT I AM ENTITLED TO A DISCIPLINARY HEARING. I FURTHER UNDERSTANO THAT IF I PLEAD GUILTY I ALSO WAIVE MY RIGHT TO THAT HEARING. //7 ,..,... . .....t // p.P INMATI~L.lEA I.J,,". 1;. 5 INMATE TOCHANOI I -'If{/: /'" J /; J) CI IIClvJa,oNATuJt. ~" 9-)-'15 ... l' ,ylr~/ '''/(F/:(/:I:" Tv ,,-,",',' '/-'/1' .., .~ , '1"'&.-' OAT[ L6_;...:.:'_~__ .. ~._._!.!!_..:.~:,-.~::.. DATr Q' NOTrer ,y,,', DArro. 1_ 7 - 6,' HrA"'NO 'v TIME Oil _ HrA"INO 7'2,:} /)1'/ SIGNA rUNE 01' ft.' ;/~ '", CHAI" PERSON IXI ///.~.. ////...... DISCIPLINARY ACTION .UMMA"Y 0' 1I"1I0~.lrOI""a. ZAIMHrl; CtN<I>t rlt'lY /{1'/'dJ/;/J T,;J /t'77/_A/1/ /r/.N/"/"~ ._--_._~--- U//aL-TI11..' /;VfU/:I"V,;",. rpt:.J'/.",l/rl:t..- ,/. 1- -- IA. I '-'l-.JNI.> IA;,/., /JrLL ~"'l<rTJ"II/t/v ~U/; /17 /, :<r /. .!y /(/ -rtf'"". l,s/:,"r.;/(, ;'.t',~_.--(.(('/,:7 J.J r}ll' ,o/</ /; , L /" ,p (/,10/ ,-.:: OI~"O.tTJON //;/;'" I?OIlI< IJ /~J,./"ILJ Zv~l~ /;.. C:'o 1~/"ld.N/ (;~Ufl,ry C/l1 /11.. L ,/ c.."'AI("-It'( 1,1,1 I Z f' /It./o_ J,,{'I ~'3o ILfiy'r ',,(:ie-It "v,,,, -}/V H..,I (,~<t!JII;;I!. r~rAL &/: 7'tJ LLd~ _ ""Nil tp~f 01'. - "-~:;;;"-7--- .1 ~N 5: .~ D<AIMr..1\i.'>I._~ Dr. f,;tVrIC.)I't -rl t~ (,u.// II, ~L___ $TART '/-/-/.:: "nEASI_I;';'~ ~ /. ) YOU HAVE THE RIGHT TO APPEAL THIS DECISION T.9'1'IiE WA"~N WITHIN l'EN 110/ DAYS :::~.:"'ON '~#;2a' -' 0'tZ:., - :~~:~.~/ fd;';'1 (""';'If .___ "'l.blI.n-L-; ~~_~ .0"""0 . -______ hUMBER .IVIIWID ~/ 11 /-:- -L . IV WANOIEN ..'/ Y r::.":.-(,/,, ___. - OATI (',.. ') ~UMBERLAND COUNTY PRISON '-8 DISCIPLINARY'RQCEDURI INW.&TII: CORMAN! CORY A, CILL. B-4 DAn '1 9< 0' O"IN51 ~-:'" :"' ~. 0' ';:~:NS[ J I 1.OP~." 'LACI 011' l."lnN&1I: UNIT-B cMA.n.-1..42.INDlIil:'E!u:tH OR UELlIll::l\;Ul:: A(;'I'WN 01\ AI"fI':l~ TO EXPOSE ANOTHER PERSOJL TO J!'Q!>JJ. Yi'li!1 Jll~.. .QR QTiiliR JJAliARlJOUliHA'IJ::IUAL W,TN..... C/O DERR C/\tDI)RI~lL_._.NU~':;1;; tlULIlUlJ..AtllL. .... ""CONOUCTIIX",AIN~~WM"" w~ ~..5t"!.A'!Ut!!!L_ ON THt: ABOVE DATt: AND TIm; I On'ICl::R IiICKilKIl F, WAS INVOLVED IN RESTRAINING INMATE COR)>lANY C,A, 'ro THE nOOR AND HANDciit'VINGtrm;.AJ.'i'EiCfilC.-- BECAME DISORDERLY TOWARDS OFFICt:~S ~~ !/NIT-II, ONCE INMATf. COIlMANY C.A, WilS-lTi\NDcUHI'.Vr;lffisr.--- M1ILH01,LAND CAME IN AND CHECKED INMATE CO[lMANY FOR ANY Ill'JuRIES. NURSE MULHDr.l;J\/''O.i\SKF.D "n'YI'F.'-..- COULD TURN INMATE CORMANY C,A, ON HIS RACDo CHECK IIISVIliL STGmr;--ONC~-LNfIATF..-(~ORHANn;w.r--' ON HIS BACK I TOLD HtH. TO CALM. um,:J'I.~. AT TIrS POINT tmlAn CORMANY Sl'1TsrnU'l'UWCOlITA1'lnrr.-rrr.om, AT MY FACE HITTING ME IN NY MOUTiL AT- fH(~;-. POiNT-r-W.(S.IIF.t:tPJ1:jj BY ANOTlif:I\OFF' l!;":~. :l(J [ C(1Ur.Tl.. WASH MY MOUTH OUT AND FOll.OW iN-S'r[fUT1oNAIPOl.IC2YABOU1'-li1:(j(jJrPA.tlloCf~NS~ --.-----.. ~-----..__..____ ,m.' --------... -. .-...... . .... ..----.--.1Ti1Z;-------..... .._u ...-.. ... DATI 9 d a ~ IIGNA-TUItIOl' . r /~ . ' 1I0NA'rURJ: 01' ~../ ~ - . 0'""'0.' '/- 1'-, .I'O.'''OO'''CI.....,)(. '6 ~. MlnLIAOI.1X1 ~/~.~::.._ I I. AS AN INMATE 0, THE CUMSERlAND COUNTY PRISON. UNDERSTAND THAT I AM ENTiTlED {({'A OISCIPllNARY HEARING. I FURTHER UNDERSTAND THAT IF I PLEAD GUilTY I ALSO WAIVE MY RIGHT TO THAT HEARING. 04TIO, NOT'CI INMAn'l.l" iJ (" INMATE: TO CHAIIOl 1\/" /,;." 1':1,) ~l"Lt.!~V:',c2._. SIGNATURE _(.~L__.___~._.. '1.u. y.::,' DATIO,. 'I' .. .. TIMI: 0' HEARINQ . L l - 9' S _ HIIA.ttf'llQ CATE .?2t:1 If" UIONATUltE 0' ?~ CHAIR "I"ION 1)(1 ~" c" ;P~-id UMMAltV 0' .0CUn,.0. rd", <lTI.. et>""""'d'.Y. (" /<IO-I--C/"I.-~ r." 9"'" r", -r"NI: ,)". ";'; lA,h,-~vf J;; Th"/ ~/f<' ,.1 t I/YhllY r ,.I "'1./ r ~;I/Il I-'~ ...., /,1/ . ;'/.1"" ( ~) U//o. /:_,.',._(.. f)'1! SI.lir I~' i;"", CA:-~:LisJ.;; DISCIPLINARY ACTION //I"~.N,d / /(/t":... /1 t? ~~(::-'=-_....____ C t~~.Jo.' ..-,,/, /v Y - '":.,;';" t" .(, c ,.... , " T }. j /J ~ IC _;:: .) - .. rfi r- . " :/ /' / ,,' /0/ /" I I (' I ,. ------ .- .I ~ -: (") D ~ ': : / orA.T a. - .L z. '/.( .ILIA" / . /,;. '??' :?U HAVE THE RIGHT TO A~PEAl THIS DECISION TO THE WARDEN WITHIN TEN "01 DAYS. 11.'".'0' ~,~..-- C' ~/:/d 'OA"O CI f\/) ') .~) ~ ..,,'. . -- MI:M.I:Ilt _ 7') 1-6-;', ~, /~J:l a A, '_ "'0 ,"", ' I '_.___ lallL- . Lll 11/. .;;. 'OA"O '"W"o --..p /'--->;'T'~-- .. . h --_.. """... --...--____.____._._______ ____ NA"D.N '-~ ,,~ L~. 7 , -~--___ DATE ........-.---- ~--_.- .------.,---..- ..-- --- "---'--.-"'--..--. .... .-------- . CUMBERLAND COUNTY PRISON OISCIPLINARV PAOCI:OURE INMATE ACTION COpy INII"',.. rnRMANV r r.nRY.....A...____...._._.__._~.__ CELL B-04 e.n 11/")/95 TIM. 6'55 PH 0... 0"'1""11 _~___._ 0' O'HNIL_-' "ACI R H o,o,uN..UNIT C UAY 00 .---.--..--- CHA"Q~ 1,)4 REFUSING TO LOCK UP .. -"-"-"-' .------ .---- _._~._------_.._---- -....-----..----..- WI1"UII CPL, CULBERTSON/C/O KE.N_!_ ~1.9 _\'.~~LACF~_.______.._ ..IICO.OUC1 'IX"AI' WNO. WNAT WNU' WNIN. NOW. 'Ne WNY' ON THE ABOVE DATE ANl!.~:....!N!IATE C(:Il}\ANV \:A~_ ~::_.. TURNING rRON THE LAWLiiiwv WITHINMATE MITCHELL WHEN I NOTICED [NHAn: COllHXNY C^1lR.yrnc- F; _ LAW BOOK WITH-HIN. I INFORMED INMATE COKl'lANY THAT HI'; WA~ NUl <;UJNI. l<J rAKr.-TllA-r-(I,Alt41~ . TO HIS CELL AND I WOULD RETURN IT ~'OR HIM. AT THIS TIME INMATE CORMANY RI,CANF. ARGUMENTATIVE AT nns POINT I ORDERED INMATE CORMANY TO LOCK-UP HE REFUSED HE BY TELLING MF. [ DON,'T UNDERSTAND WHAT YOUR SAYING. [THEN TOLD C/O FINKENBINDER TO GET SOME OTl!fJ!. OFFICERS !lOWN .. HER!, C/O'S KENT, WALLACE AND CPL. _CULBERTSON RESPONDED. CPL. CUl.BERTSON TIIEN ORDERED INMATE CORMANY TO LOCK-UP AGAIN CORMANY REPl.IED BY SAYING "I DON'T UNDERSTAND" CPr. CUI.BERTSON ORIlERED US OUT OF THE UNIT, SGT. TEANF,:.'T.HEN ..TO~P_U,L!O PREPARE FOR A FORC~Q... CELL1iQy'I'., _ _ u _____ END O~' REPORT ________ OATI I I 110NATUltI0l' ,,,(. /'") \'/ \."J I. .'GNATVRI: 0... ..A.uL-~ 0' 01'0" 1/ < ~ 4~' O"OOYING O""cu ,., " ) \.. , ,. ~ IN"HI.eu,XI ~_ ~, I, AB AN INMATE 0, THE CUMBERLAND COUNTY PRISON, UNDERSTAND "HAT I AM ENTITLED TO .. DI.C:I'LINA"Y HIA"ING. I 'URTHI" UNDERSTAND THAT" I ..LIAD GUILTY 1 ALSO WAIVE MY RIGHT TO THAT HIA"'NG. INMAn 'LIA TO CHAltOI INMATE SIGNATUltl IXI DATE 0' NOTICE //..)-;/ ~;- DATIO' N..OINO-L'I. /'7 9, .--- DATI!: '.'_.'__._n.__ .----.---.-.-.--- TIMIO, HIlA"INO ,;t<l 7. ~-... / IIGNATU.. O. ~. ~ CHAllt "I".ON Ix,./r ./: ~ ,.. :--- .UMMAlty 0' It""oel'l'!'IINoa DISCIPLINARY ACTION ~fltl/~..~::hd7 M~~;:;:,:" ;r;; N/h:.vu .r~/f ~ . (.rh;~',,,/~~/.,__ /,:p M( Lf,'/,A'i;' /.I6~ )", '----- -- :)IIPoa.TlnN /.. -:J,; /' _.:d.~ //.0/7 /://1,:... &-..' h/l/~""",. 15/ ~ rt"'</I ------_._-~----- ad.;-,; /.r"J//'''J'''.d' '-la//u .~'V, ('/~..., /'~ ~'~"'~"''''''J'? //:<Jfda.'J';' /; .~/".,; , LL""YLL:L.... ~__'~/V...J /11/~(~"'1'1r/ f .,In" &,' .Liu.Lat:L-JIU.LL:L r;., /i/',!"'__~.,..~.,_.y...J ./),.._....Ud____ "A.. ,. /).i/~~/,/iI.-__~ .;('1/.(/ - '34;'~ .".... 'I !l1h6 ~O~AV~ RIGHT TO A....EAL THIS D::~:':N TO,~~Et~AR(~N WIT~rN TEN 1101 DAVS .~;7:"O~ J .r:( ,/_ .=: ;;;;;: ~~_' ,\~ iJ~1 (L__~_ ~Y~~::~N r: /1 /' / ~'~'''1 c.. ,/.. ,- .~ "_ r -.....__._._-~.._-- ----------- . --.-..-...------ Cc>-") A. Cr-MO~:) 7/<:;) ---~""V} (2.. Cc/,'~k I {c6. \ IOI~ ~ort>-llr- :J,-cC~Q rSW0 CufV\ ~<!..r JO'AJ COI..I\"I\;,\1' CUlf 1=Icu~ / ~u+~ ~O~- ~ c;rJ~(c- (~ (/0/3 I Oeor jc.i;t S.~ej0 I )~ rr ""'0 !wf r !...tt, c+ 1:-''1'''~x;, I t-e-t v~("\J. :h k f c,V 71 - o~ '-t 1 0.j, C'I ,j~{ ~ OJ;.,d-, ;C lY)Vj.r-f r(lc.~(rrj-' -Jl~ i.).)u<....r o~ fn':]fl.f"~ cA:..c-J- ;:c ,F(.j A(?/,{. ; '" Cv"" bJr-jev. ~"f lr 6+';;0 '\. ~ ''>d v, of >/J '~L X(1 ~ l2 i 'r"' d ~ ot-e 01 ~r-I ~/'0 I ~"cJ'V-o q dOl JL.. ll",,:,~,^rf-, 01: N..f ~~.e., ~ c.o~ctcl"\+ ~Ci~~^~ I Arec.~, c,-",J c~ ~ 6."'/ +-..) a.~ J(.c..o M '^) M.-O-J + ~~"'""'"<- 0.-. [ ;r:; 0 """'-- cD CD IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA CORY A. CORMANY, CIVIL ACTION NO. 1ICV-"-0844 Plaintiff (Chief Judge Rambo) v. (Magistrate Judge Blewitt) KAREN FINKENBINDER, et a1., FILED SCRt\NTON Defendants UEC 051995 ORDER THE B~CKGROUND or THIS ORDER IS AS FOLLOWS I On May 30, 1995, the Plaintiff, Cory ~E.R -:~@7;LERK A. Cormany, filed this civil rights action pursuant to 42 U.S.C. S 1983. (000. 1). Currently pending before the court are the Defendants' motion for a more definite statement (000. 8) and A motior to dismiss the complaint filed on behalf of Defendant Rudolf. (000. ') . Additionally, the Plaintiff has several motions pending before the court. Among these motions are a motion to strike impertinent material from the Defendants' motion for a more definite statement (000. 17); a motion to dismiss Defendant RUdoli (000. 14); several motions for joinder of additional defendants (0008. 18, 31, 34, 36, and 38); and several motions for summary judgment (Doos. 2', 33, 3' and 41). These motions are ripe for disposition, Upon review of the record, and for purposes of utility, the court shall grant the Defendants' motion for a more definite statement (Doc. 8), as well as the Plaintiff's motions for joinder AO /1A (n~y !'l/H)) AO I2A Irt1lvll/l1.?1 - (Dooe. 18, 31, 34, 3' and 38). In addition, the Plaintiff will be ordered to file a more simple, concise, and direct amended complaint, which shall include any and all Defendants whom the Plaintiff wishes join. Based on the Plaintiff's concurrence (Doce. 14, al and 22) in the motion to dismiss the complaint filed on behalf of Defendant Rudolf (Doc. 'I, the motion will be granted. Based upon the court's order of July 21, 1995 (Doc. 13) denying the Plaintiff's prior motion to strike (000. 121, the Plaintiff's current motion to strike (Doc. 171 is denied as moot. Finally, the Plaintiff's pending motions for summary judgment (DOC8. a" 33, 3' and 41) will be denied as moot in light of the court's order to file an amended complaint. tit... AND NOW, this~__ day of Oeoember, 1"', I~ I8 HEREBY ORDERED THATI 1, The Defendants' motion for a more definite statement (000. 8) is GRANTED. 2. The Plaintiff's motions for joinder of additional defendants (0008. 18, 31, 34, 3', and 38) are GRANTED. 3. The Plaintiff is ordered to file an amended complaint by January 1, 1"'. 4. The amended complaint shall properly allege a claim under 42 U.S.c. S 1983. 5. The amended complaint shall be filed to the same docket number as the instant action and shall be entitled "Amended Complaint", 2 II :1 I @ 1l '" - :> 'j; -.I Eo!! c"" M OJ C OJ .. '"' .0 ;J Cl ..... o'~ I" ~ C _ '"' ...J '" " ;( .c :> :!t _ OJ " ~ c c OJ ~ OJ i 0 r~ ... :l: EQ.- ,. [~] ,. I- " ~. ~ ~ . :;.!! ~ ~~~ ~ oQ.;J "'" >- -" g c I- ... OJ "' - >-"'" .c Z I- iil"'>-< ~ 8~~ ~ OJ >- ~ ;0 '" < u'- - ." OJ >-:l! Q. c " .. ell: ,_ ~ "'0 '" . E 0 ..O!! .- ::l ~ .... .S: Co - 0 >-;J " . >- ",.._ 0 "0 : ... c _ il.l '" :J 0 - c: Q. o OJ ~ :!t < "0 :J il.l Co :l: c:"'O..c '" CIt ~ ... ......c: vi ~ c: c ",..:.c Q. il.l ~ .- '" c: ;J E _.c .. oJ! >- C V'I.s;:, il.l ~ il.l'- .... eo.E-::; j '':; '" ~~ 0 1. ilJ .... Q. .... E :> . "'" ~o~:::u ~.c"'U '" _ E ~ OJ c f . t1).. State University. fl. On December 5th, of the year 1993, Plaintiff Cory Cormany was assaulted and unlawfully detained by Defendant Karen Hnkenbinder for Public Drunkenness. 7. On May 4th, of the year 1 ')'J4, Plaintiff Cory Corm.!ny was adjudicated of the allcllation of Public Drunkenness, set forth by the Defendant Karen Finkenbinder, no determination of lluilt. 1\. Prior thereto, the allellation of Public Drunklmncss, prior to the date of December 5th of the year 19'H, the Plaintiff Cory Cormany was again allellated for Public Drunkenness. The allcgation was set forth by Officer Mace of the Carllslc Polke Department, the Plaintiff was detl~rmined to be guilty. C). On ^prll 5th of the year 1994 the PlaintiIT Cory Cormany filed civil suit allainst the Defendant Karen Finkenbinder in the Court of Common Pleas, Cumberland County. 10. Prior to the civil suit and prior to the allellation of Public Drunkenness set forth allainst and by the Defendant Karen Finkenbinder, the Plaintiff Cory Cormany was allcllatcd for various criminal chaq~es concerninll a domestk dispute, on or about the month of July of the year 1992, by the Defendant Karen Hnkenbinder. 11. The Plaintiff was adjudicated, with no determination of llullt concerning the allegations set forth by the Defendant Karen Finkenbinder in or about the month of September of the year 1992. The Plaintiff's bail was set at One Hundred Thousand and 00 Dollars (lOO,nOn.oOl, however the Defendant was found guilty of a summary offensl:. 12. On May 2nd of the year 1994 the Defendant Ronald Egolf filed a criminal allegation against the Plaintiff Cory Cormany. The Defendant Karen Finkenbinder did conspire with the Defendant Ronald EllOlf in the allegation, no determination of llull!. 13. On November 4th of the year 1 'J94 the Defendant K. D. McCoy filed a criminal allegation against the Plaintiff Cory Cormany. The complaint was in the P nature of simple assault, no determination of guilt. 14, On February l'lth of the ye<lr 1'l')5 the Defend<lnt I.arry Kell flied an <lllellatlon allainst the Plaintiff Cory Corman)'. The complaint was allain In the n'!IUre of simple assault anJ again there was no determination of guilt. IS. In the <lforelllelllioned complaint filed by the Ilefendant Honald Lllolf it is said that the Plaimiff Cory Cormany said he recc\vc:d tr<!atmenl. This is said by the Def<!ndant Karen Hnkenbinder, however there arc no Court Hecords. 1 (,. In the aforementioned complaint filed by th<! Defendant 1.arry Kell it is stated that the Def<!ndalll is said to have known the Plaintiff Cory Cormany can be combative. The Plaintiff Cory Cormany did not ever meet the Defendant 1.arry Kell ulllllthe date of February 1 'lth of the year I <)<)5. The said term combative Is said to be C(lImructed by the allegation set forth by th<! Def<!ndant K. D. McCoy and the incident described in the civil suit allell<!d allainst th<! lkfendant Kar<!n FinK<!nbim!er. Neither of th<! two complaillls could prov<! to b<! factual at th<! tinl<! of th<! arr<!st. mad<! by th<! Def<!lllJant Larry Kell. 17. There arc complaints listed in lh<! Court of Common I'Ic<ls Cumberland County Pennsylvania. Th<! complaints Include the llef<!nJants Kar<!n Finkenbinder and I.arry Kell. they Include their abusive and lawful anions as Police Offkers for the Borough of Carlisle. II!. Th<! Plaintiff Cory Cormany has suffered public humiliation caused by the Jcfamation of his character as a result of the Defendants' harassing and conspir<ltorial <lnlons. I'). The Plaintiff Cory Cormany has suffered mental anlluish, emotional distress, and imprisonment as a n:suit of the Defendants' harassing and conspiratorial actions. 20. The Plaillliff h<ls suffered physkal injury, pain, antI .suffering as a re,mlt of th<! Defendants' harassing and conspiratorial actions. 21. The Plaintiff Cory Cormany has suffered lost wages, benefits, and excessive legal f<!es in excessive approximate amount of Tell Thousand and 00 Dollars ( 10,000.(0) in adJition to lost college tuition fees, as a result of the Defendants' harassing and COt/NT FIITEEN CORY CORMANY V. GEORGE I'INKENBINDER PENNSYl.VANIA CRIMES CODE SOl.lCIHTION, CRIMINAl. CONSPIRACY AND CONTl~Wr - 901,902,903,904, AND'JOS 127. The averments set forth In Parallraphs one throullh twenty-two (1-22) of the Complaint are inmrporated by reference a,~ if set forth at lenllth. 128. The rrimes of Solldtation, Conspiracy, and Contempt are serious as having happened in the County of Cumberland. The incidents are relevant to statements one through seventeen (1-17) of the complaint and respectfully submitted exhibits: A-Z. 129. The Defendant George Finkenbinder did conspire, solicit, cause contempt, assault, oppress, endanller and harm the Plaintiff Cory Cormany after he did file a complaint in the Middle Oistrkt Court pertaining to Karen I'lnkenbinder, et oIl. 130. The Defendant George Finkenbinder did deliberately swear at the plaintiff and cut his phone conversation short with his father while they were discussinll the reasons pertaininll to why he had not yet been released from prison. 131. The Defendant Georlle I'inkenbinder has submitted a Disciplinary Procedure Report and has induded statements that are relevant to the clements of the complaint. 132. The Defendant I'lnkenbinder has not stated why the plaintiff could not finish his phone conversation while in quote Unit "C" nor has admitted reasoning as to why the plaintiff became quote "combative" whllc he was returning to Unit B. lie did in fact physically hanll up and take the telephone away from the plaintiff, then did commil the arts mentioned afore. lie did say to the plaintiff quote, "You're never 1I'~llinll out of jail". I.B. The Defendant Finkenbinder did conspire, solicil, <,<,use contempt, officially oppress, assault. endanllcr and harm thc Plalntifr Cory Cormany. It is relevant to Count hlUrteen (14) and the complaint in its entirety. It has caused the COUNTSIXTHN CORY CORMANY V. DAWN KEl.l. PENNSYl.VANIA CRIMES CODE SOLICITATION, CRIMINAL CONSPIHACY AND CONTEMI'l'-901, 902, C)03, 904,^ND905 136. The averments set forth In Paragraphs one through twenty-two (I-22) of the Complaint are incorporated by reference as if set forth at length. 137. The crimc,~ of Solicitation, Conspiracy, and Contempt arc serious as having happencd in thc County of Cumbcrland. Thc incidents are relevant to statements one through seventeen (1-17) of the complaint and respcctfully submittcd exhibits: ^-Z. Ll8. The Defcndant Dawn Kcll did conspire, solidt, cause contempt, milliriously acted, and did threatcn and improperly Influcnce the plaintiff during a visitation with his parents. 139. The Defcndant Dawn Kell did tell the plaintiff's father that he could not visit with thc plaintiff five (5) minutcs after his arrival, while he had forty minutes visiting time remaininll. This is in further respects to the plaintiff's relea,~e and the Defendant l.arry Kell. 140. The Defcndant Dawn Kell did acknowledlle supervision of visitation throullh the tclephone windows and did malidously cut the visit short when the prison stipulates one hour on Saturday and one hour on Sunday, unless given two separatc visits per day, This Is relevant to the plaintiff's financial status, shelter upon rclease, and his opinion in official and political matters. It is relevant to the complaint in its el\lirety. 141. The Defendant Kell did not state why the visit was shortened to five minutes, nor implied reasoning for her actions. Thus violatinll constitutional provision and amendment. 142. The Defendant Kell did conspire, solidt, cause wntempt, maliciously act, and did threaten and improperly influence the Plaintiff Cory Cormany. It Is relevant COUNTBGII'IHN CORY CORMANY V. sccnT MORRISON PENNSYI.VANIA CRIMES COD!: SOLICITATION, CRIMINAl. CONSI'IHACY AND CONTEMl'f-90I, 902, 903, 904,AND905 153. The averments set forth In Paragraphs one through twenty-two (1-22) of the Complaint are incorporated by reference as If set forth at Icngth. , 154. The crimes of Solicitation, Conspiracy, and Contempt are serious as having happened in the County of Cumberland. The incidents arc rclevant to statements one through seventeen (1-17) of the complaint and respectfully submitted exhibits: A-Z. 155. The Defendant Morrison did conspire, solicit, cause contempt, assault, oppress, cndanger and harm the Plaintiff Cory Cormany after he did file a complaint in the Middle District Court pertaining to Karen Finkcnbinder, ct al. 156. The Dcfendant Morrison did entcr thc holding cell of the Plaintiff Cormany with an electric shock shield and did press the plaintiff down into his bcd with the clectrlcal shield whilc it was on. This was after the plaintiff rcfuscd to allow the defendant to tear up and tear through his legal papers. The plaintiff did throw water on thc defendant for attempting the afore. 157. The Defendant Morrison has committed actions that are relevant to the romp.lllnt, and has not providcd the plaintiff with order as to rcason for his allegcd acts. 158. The Defendant Morrison did conspire, solicit, causc contcmpt, offiCially oppress, assault, endangcr and harm the Plaintiff Cory Cormany. It is relevant to Count nfteen and the complaint in its entirety. It has caused the Plaintiff emotional distress, public humiliation, mental anguish, imprisonment, pain and suffering for injuries inflicted, potential lost wages, lost benfllS, and loss of property. 15C). By reason of the aforesaid matters the Plaintiff has suffered emotional distress, public humiliation, mental anguish, imprisonment, pain and suffering for COlJN'I'NINI:I'HN CORYCORMANYV:roDDDERR I'ENNSYI.VANIA CJ{IME'i COD!: SOLICITATION, CRIMINAl. CONSPIRACY AND CONTEMI'I'- <JOI, <J02,')03, ')04, AND<JOS If)!. Thc averments set forth in I'aragraphs one through twenty-two (I-22) of thc Complaint arc Incorporated by reference as if sct forth .It length. 162. Thc rrlmes of Solicitation, Conspiracy, and Contempt are serious as having happencd in thc County of Cumberland. Thc incidents are rclevant to statemcnts one through scvcnteen (1-17) of thc complaint and respectfully submitted exhibits: ^-Z. I (d. Thc Dcfendant Derr did conspirc, solicit, cause contempt, assault, oppress, cndanger and harm the Plaintiff Cory Cormany after he did filc a complaint in the Middle District Court pertaining to Karen nnkcnbinder, et al. 164. The Defendant Derr did enter the holding cell of the Plaintiff Cormany with the Defendnat Morrison and did strike the plaintiff several times In the face while he was being forced to his matrcss with an electric shock shield that was being administcred by the Defendant Morrison. This was aftcr thc plaintiff refused to allow the defendant to tear up and tear through his legal papers. The plaintiff did throw water on the defendant for attcmptlng the afore. 16S. The Defendant Derr did repeatedly use a ta7cr device while the plaintiff was being handcuffed and shackled by other associates of the aforc defendant. 166. The Dcfendant Morrison has committed actions that are relevant to thc complaint, and has not provided the plaintiff with ordcr as to rcason for his alleged acts. 167. Thc Defendant Todd Derr did conspire, solicit, cause contempt, officially opprcss, assault, endanger and harm the I'laintiff Cory Cormany. It is relevant to Count nftcen and the wmplaint in its entiret)'. It has causcd the Plaintiff emotional distress, public humiliation, mental anguish, Imprisonment, pain and suffering for COUNTlWENW CORY CORMANY V. CIlARUS CUI.HERTSON, TRAVIS SHENK. TREVOR KENT, JERRY MAl.I~~KI PENNSYLVANIA CRIMES CODE SOI.lCITATION, CRIMINAl. CONSPIRACY AND CONTF.MPr - 901, 902, 903,904, AND 905 170. Thc averments set forth in Paragraphs one through twcnty-two (1-22) of thc eomplaint are incorporated by refcrence as if set forth at length. 171. The crimes of Solicitation, Conspiracy, and Contempt are serious as having happened in the County of Cumberland. The incidents are relevant to statements one through scventeen (1-17) of the complaint and respectfully submitted exhibits: A-Z. 172. The Defcndants Culbertson, Shenk, Kent and Maleski did conspire, solicit, causc contempt, assault, oppl'ess, endanger and harm the Plaintiff Cory Cormany after he did file a complaint in the Middle District Court pertaining to Karen Finkenbinder, et al. 173. The Defendants Culbertson, Shenk, Kent and Maleski did enter the holding cell of the Plaintiff Cormany and did handcuff and shackle the plaintiff while the Defendants Morrison and Derr were administering shocking devices on the plaintiff. The shocking dcvlces did cause the plaintiff to wet his pants and the palintiff did spit on the defendants and their associates for administering the afore. 174. The Defendants Culbertson, Shenk, kent and Maleski did force the plaintiff to the ground and did remove the plaintiff's legal papers, cosmetics, and personal clothing, then did lcave the plaintiff handcuffed and shackled In the holding cell. 175. The Plaintiff Cormany was in the holding cell when the prison nurse came to his cell door and asked him if he wanted to bc checked for injuries. The Defendants Culbertson, Shenk. Kent and Maleski did reopen the plaintiff's cell door and did come in and throw the plaintiff to the ground causing his head to hit the floor and repeatedly twisted his arm while the nursc was supposed to chcck him for injurics. 176. The Defendants Culbertson, Shenk, Kent and Maleski did choke the plaintiff into unconr1ousness and thcn put him on a board so that hc l'Ould not move his arms and legs. They did lock him in the holdinll ccll and leave him therc for approximatdy twelve (12) hours. Thcy did deny him proper medical attention, however was provided ice whilc he was fastencd to a board. 177. Thc defendants did have an associalC videotape the incidents, howver it is unable to dctermine what has become of the tape. 178. The Defendants Culbertson, Shcnk, Kcnt and J\laleskl did conspire, solicit, cause contcmpt, officially oppress, assault, endang(~r and harm the Plaintiff Cory Cormany. It is rclevant to Count l'ifteen and the l'Omplaint in its entirety. It has caused the Phlintiff emotional distress, public humiliation, mental anguish, imprisonment, pain and suffering for injuries inflicted, potential lost wages, lost benfits, and loss of property. 179. By reason of the aforesaid matters the Plaintiff has suffered emotional distress, public humiliation, mental anguish, imprisonmcnt, pain and suffering for injuries inflicted, lost wages, lost benefits, and loss of propcrty. 180. WI\l:RHOIU:, the Plaintiff Cory Cormany claims from the Defendants Travis Shenk, Trevor Kent, Charles Culbertson and Jerry J\laleski each, in an amount excess of Twenty-Hve Thousand and 00 Dollars (25,000.00) plus cost of suit. Respectfully submittcd, Cory A. Corman} INTERNATIONAL PRISON MINISTR y ~ 0 BOH3 O~ll~5, TX 7&2ll March 24, 1995 Mr Cory A Cormany Cumberland Co Prison 1101 Claremont Rd Car1i"le, PA 17013 Dear Mr Cormany, I have received you~ let~er. Please wLite anyt~me. Here are some scripture verses which will be especially helpful to one with rour .pecial problem 1 Pe.lm 3416, P..lm 341 18, Psalm 40117, Isa ah 41110, Isaiah 40131, Phi11ipians 3113-14, Proverbs 3114-5, Proverbs 20:1, Proverbs 23129-32, Isaiah 5111, Habakkuk 2115, Ephesians 5118. Read these, meditate upon them, and let them speak to your heart. If you want to quit drinking accept Christ as your Saviour and let Him fill you with His Holy Spirit so you will have power to live for God. Even when you have done these things, don't be discouraged should you fall. The devil will not let you go without a struggle and will con- tinue to tempt you to do his bidding. When you realize what you have done, do as King David of the Old Testament did. Ask God to forgive you and restore you to the joy of your salvation. For John 119 says, "If we confess our sins, He is faithful and just to forgive our sins and cleanse us from all unrighteousness." You will grow stronger in the Lord with each new victory He gives. When you are a child of God, you are right and clean before God's eyes because of Jesus Christ and His sacrifice and His blood which cleanses. I John 1:9 God has forgiven, you must forgive yourself. You csn becausti of Jesus. Pray asking God to heal your memories. Every time you feel guilty or , unforgiving towards yourself--give thanks unto God that Jesus paid for all your sins past and present. When God forgives He forgets, and puts behind Him your sin--casts it into the deepest sea--puts it as far from Him as east is from west. Go to God's Word, the Bible...the Gospels Matthew, Mark, Luke, and John, and mark the word "forgiveness" and the word "believe". See what God says. Forgiveness is the key to relationships. Jesus taught His disclples to pray. "Forgive us our debts as we forgive our debtors." Matthew 6:12 Then Matthew 5:44 tells us to "Love your enemies, bless them that curse you, do good to them that hate you and pray for them that despitefully use you and perse- cute you." When we forgive by choice (our will) no matter what our emotions say, there can be no root of bitterness grow in our heart and God can work with us and with the person or persons hurting u.. It never fails, the Lord will bring your emotions into line with Hi. will and shed love abroad in your heart for that person. Also the Lord is free to do His good pleasure in the life of the other person as well. Choosing to forgive frees us of thinking bad thoughts about a person and speaking hurtful words against that person. We can go on with Ollr walk with Jesus trusting Him to take care of the whole situation. Joy can fill our hearts and spillover to bless others. See th~ story of Joseph in the Old Testament. Forgiving is for the good of our own souls in the midst of injustice and persecution as well as it causes a release of the person to the Lord in the spiritual. Forgiving also keeps the root of bitterness and hatn;d hom yruwil'l<J 111 our hearts. ,lesus l:hrist is the perfect example of forgiving. Many laws both Hebrew and Roman were broken at His trials. He had no lawyer at all. Yet for an eternal purpose and for the love He had for you and me, Hs submitted to the laws being used to kill Him. Jesus prayed "Father, forgive them for they know not what they do." Prayer is a weapon of the higher law of God that is mighty to move man, laws, mountains. Freedom is in Jesus Christ and only Jesus can give you freedom from prison whether He uses the law or man or both. May you ask for and receive God's wisdom and direction for your everyday life and future goals. Following Jesus is great because He has only good thoughts towards usl Our literature is sent free of charge to prisoners and we are happy to do BO. We are aending some helpful material to you which I hope you will enjoy. Please allow two to four weeks for delivery. You are remembered in our prayers. My wife, Leola and our staff send greetings to you, We pray God's grace and loving care be with you. Sincerely, ct~'" f:<cJ Chaplain Ray /.Vo\c.(' C(lt'~ 01, E'tj'" (o,~ 3, 5c"-., Tr~ --~ @ CUMBERLAND COUNTY REI IN THE OFFICE OF THE DISTRICT ATTORNEY DEFENDANTS: I=tO^\A TeM~ Cvr\." G,\\"~f\ TruvI) ~,,~"" ' ~,,~ Wc..\\o.C( r<\ Ie...\.-. ...t...\ 1.\<. I Cory A. Cormany bein<J a citizen ot thll United States of America and a register.ed voter in the County of Cumberland and a resident of Carlisle, do hereby statel I accuse the above name defendants, who are employed in Cumberland County w~th violatin~ the Crimes Code of the Commonwealth of Pennsylvania at 1101 Clare- mont Re:. Carlisle, Pa. 17013 on or aboutl.)ol', J.3r's, \"\"\c. -3:001"/"1 Participants were: f. ~n::.r!.< 1" ~Cl\t"1 d.. C<.r"'~'., C~~"Thof\ 3. r~\~ S~\.( 'f ' ~c::ct<.. Cu....\ \ 0.&:( S, (f\,' "-\H\ l1\~ The acts committed by the accused werel A. 2701 Simplc Assault (3) attempts by physical menace to put another in fear of imment scrious bodily injury. B. 2702 Aggravated Assault (1) attempts to cause serious bodily injury to another, or causes such injury intentionally, knowingly or recklessly under circumstances manifesting extreme indifference to the valuc of hu~an life; (4) attempts to cause or intentionally or knowingly cause" bodily injury to another with a deadly weapon. -"-'- -.-.. ---...-....---...... .................... C. 2705 Recklessly Endangering Another Personl A person commits a misdemeanor of the second degree if he recklessly engages in conduct which places or may place another in danger or death or serious bodily injury. D. 2706 Terroistic Threats: A person commits an~ is guilty of a mis- demeanor of the first degree if he threatens to commit any crime of violence with intent to terroize another or to cause evacuation of a bUilding, place of assembly, or facility of public transportation, or otherwise to cause serious public inconvienience, or reckless disre- gard of the risk of causing such terror or inconvienience. E. 4501 Definitions "Harm," loss, disadvantage or injury or anything so regarded by the person affected, including loss, disadvanta~e or inj ury to any other person or entity in wel fare he/ she intrested. F. 5301 Official Oppression: A person acting or purporting to act in official capacity or taking advantage of such actual or purported capacity commits a misdemeanor of the second degree if, knowing that his conduct is illegal he: (1) subjects ahother to arrest, detention, search, seizure, mistreatment, dispossession, assessment, lien or other infringement of personal or property rights, or. (2) denies or impedes another in the exercise or enjoyment of any right, privilege, power, or immunity. G. 4702 Threats and Other Impropcr Influence on Official and Political Matters: A person commits an offense if he (1) threatens unlawful harm to any person with intent to influence his decision, opinion, recommendation, vot~ or other exercise of discretion as publi' ser- vant, party official, or voter. X3126 Inelecent Assault: ^ person who htJri inelecent oontact with another not his/her spouse, or causes such other to have indccent contact with him is CJ\lilty of indecent assault, a misdemeanor of thE: secon.\degree if~ (1) He does so without the consent of the other person. (2) He knows that thc other person suffers from mental disease or defect which ren- . --._.-.._._.-.~-._.. ... ,- dere him or her incapable of appraising the nature of his/her conduct. (3) He knows that the other person is unaware that a indecent contact Is being committed. (4) He halO substantially impaired the other person's power to appraise or control his or her conduct, by administring or employing without the knowl,dge of thu other drugs, intoxicants or other means for the purpose of preventing resistance or; (5) The other person is in custody of law or detained in hospital or other institution and the actor has supervisory or disciplinary authority over him. 2701': 1972 , Dec. 6, P.r.. 1482, No. 334, $ 1, effective June 6, 1973. 2702: 1972 , Dec. 6 , P . r.. 1482, No. 334, $ 1, effec t i ve June, 6, 1973. 2705: 1972 , Dec. 6, P.L. 1482, No. 334, $ 1, effective June 6, 1973. 2706: 1972, Dec. 6 , P.L. 1482, No. 334, $ 1, effective June 6, 1973. 4501: 1972 , Dec. 6, P.r.. 1482, No. 334, $ 1, effective June 6, 1973. 5301: 1972, Dec. 6 , P.L. 1482, No. 334, $ 1, effective June 6 , 1973. 4702: 1972, Dec. 6, P.r.. 1482, No. 334, $ 1, ef fective June 6, 1973. ~ 1972, Dec. 5, P.L. 1482, No. 334, $ 1, ef fective June 6, 1973. I verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information and belief. This verification is made subject to the penalties of section 4904 of the Crimes Code (18 Pa. c.S. 4904) relating to unsworn falsification to authorities. LIST OF EVENTS AND NOW comes cory Cormany, Plaintiff, pr6 se, and sets forth causes of action against the above Defendants, whereof th~ following is a statement: 1. Plaintiff is Cory Cormany, an adult individual residing in Cumberland County, Pennsylvania. 2. Dflfendants'Frank Teaney, curtis Cobertson, Travis Shenk, Michael Ile, and Ja~k "allace are adult individuals who are employed in cumberland County, Pcnnsylvania. 3. On or about January 23rd, of the year 1996, at approximately 3:00 P.M., the Defendants herein did enter the Housing Unit B of the Cumberland County Prison. They are identified as wearing masks and helmets and carring sticks, shields, and electric shocking devices. 4. On or about the aforesaid date and time the Defendants herein did blurt words at the Plaintiff Cormany, however cannot cle:o.'r1y be identified because of the masks they were wearing. 5. On or about 3:10 P.M. the Defendants herein did open the cell number four door of the housing unit B and did enter. The Plaintiff was assigned to cell. number four in lieu of Twenty Five Thousand Doll.ars (25,000.00) in bail previous to the afore. 6. The Defendants did perpetrate with masks, sticks, shields and did attack the Plaintiff without sa~d reason or cause. Then did ~unch shock, pinch, kick and bondage him. The Plaintiff was denied many privileges previous to the afore. 7. The Defendants did take the Plaintiff out of the assigned cell and did tie him to a board where they did kick, punch, pinch and shock him. 8. The Defcndant Teaney did deliberatcly and intentionally bondage and kick thc Plaintiff pursuant to the aforE. 9. Thc Defcndant colbcrtson did deliberately and intentionall.y punch, pinch and did jam his thumbs into the cyes of the Plaintiff cormany whi 1e he was tied to the board and pursuant to the afore choked punched and shocked him. 10. The Defendant Wallace did deliberately and intentionally bondage and punch the Plaintiff and did repeatedly shock and pinch him while he was tied to the board and pursuant to thc afore. 11. Tho Defendant Shenk did deliberately and intentionally bondage, kick, punch, pinch and choke the Plaintiff causing convul- sions and temporary unconciousness while he was tied to a board and pursuant to thc afore. 12. The Defcndant lIe did deliberatcly and intentionally bondage, pinch and punch the Plaintiff and did tie him to a board pursuant to the afore. 13. The Defendants did leave the Plaintiff on the board for approximately twelve (12) hours or until such time tho following shift did return him to the dssigned cell number four. 14. The Plaintiff did file a complaint on certain employees in the Cumberland County Prison previous to the incident described. Certain Defendants herein are alleged to have committed a~ts against thE: Plaintiff Cormany prior to the alleged. 15. The Plaintiff has suffered pain, injury, mental anguish, emotional distress and loss of privileges with incd,rceration because of thl! actions taken by the Defendants Teaney, Colbertson, Shenk, lIe, and Wallace. I verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information and belief. This verification is made subject to the penalties of section 4904 of the Crimes CodE! (laPa. C.S. 4904) relating to unsworn falsification to authorities. ./ ~ ( CA 'C_r~.'"7J complaintant (~ Witness II / ~ ~(-Y- I C/~-t.A./1 A-../M., NotAn:\I ~"'tll Hemcrtl\. MOtor, N(lI,liYI4J~iC M1l.1dl~,^ Twp. r:umtlor1.Jr"KJ COUI,ty "',..,. Cumr~,I((l L:fprp'.j ~-kl'1 ::'0, 1 ~}7 ll)rfbuf', F'lfl1rl5y~jriiit~ 'iO~~Sd PRAECIPE FOR LISTING CASE FOR ARGUMENT (Muat be typewritten and submitted hi duplicate) TO THE PROTHONOTARY OF CUtdBERLAND COUNTY: Please Ilst the within matter for the next: o Pre-Trial Araument Court ex Arsument Court ................................................................................................. CAPTION OF CASE (entll'e caption must be stated in full) (plaintiff) (j V'l n r: tT\ ." \'l; "" ;1 qJL:r ';:~ , j I~-'] ;f;, , "~ v \D >1 , ~J( !~ .~ .,., ?~t. ~,1. ....' ~ :...> l-j " ,I r:- .. ." '-'.J -, (1\ ", r:.. ~"'-I CORY A. CORMANY vs. FRANK TEANEY, CURTIS COLBERTSON, TRAVIS SHENK, JACK WALLACE, and MICHAEL ILE, (Defendants) No. 96-1730 Civil Term I. State matter to be araued (i.e., Plaintiffs motion for new trial, Defendant's demurrer to complaint, etc.): Defendants' Motion for Summary Judgment 2. Identify counsel who will argue ca.,e: a) For Plaintiff: Address: Cory A. Cormany, Pro Se Cumberland County Prison, 1101 Claremont Road, Carlisle, PA 17013 b) For Defendants: Address: Joseph L. Hitchinas - Johnson, Duffie, Stewart &. Weidner 301 Market Street, P.O. Box 109, Lemoyne, PA 17043-0109 3. I will notify all parties in writing within two days that this case has been listed for araument. 4. Araument COlllt Date: Call of Araument List Date: O~tl)ber 2, 1996 September 2, 1996 Dated: Auaust6, 1996 I 'Ii III I I "~I j' '/ I ,,' -~ I i":'l' "1 ! 11\' i " ,I I I' " , n , , ", II', I I, I /1 'II. " I, iI , , " , " , , " I I, !I !i ,/1 I. I " /, , 1\ " -,I,' I. j I, , , ,i i11,li III' :..1,1,'1 ',I t. I, ,I , , " i'il. ,I /1.... ~J {)l, C'A~t... (/nut1,.., I "'~fii' li\ , ! .t, I' ,i' ; I " I', " " ", 'f I 'ii' !:!' ,I r~ ~e~.pi;. ,~~t o Ii (';)<1.-.r'~'~-- In the present case, the Defendants' New MaUl" contains tho following factual allegations: 103. Any actions of Dafendants were ,,,'vileged. 104. Any actions of Defendants were iOlslified. 105. Any actions of Defendants ware (;IIIIsented to by Plaintiff. 106. At all times, Dafandants acted upon the ressonable and good flllth belief thet their actions were lawful and that they were doing right. 107. Defendants ara entitled to various immunities and limitations on damages under the laws of this Commonwealth and claim is made therefor, WHEREFORE, Defendants demand that Plaintiff's Complaint against them be dismissad. (Sea Defendants' Answer with New Matter). The Answer which contained the above New Malter was sent to the Plaintiff at the Cumberland County Prison on April 29, 1996. The Answer with New Matter contained a Notice to Plead adviSing the Plaintiff that he must respond within twenty (20) days or judgment may be entered against him. As the docket entry in this case attached to Defendants' Motion as Exhibit "B" Indicates, the Plaintiff has never filed a responsive pleading, either admitting or denying the factual allegations containad in the Defendants' New Matter. Moreover, Pleintiff has neither requested a continuance to file en Answar from the Defendants, nor has he petitioned the Court for such an extension. As a result, pursuant to Pe.R.C.P. 1029, the factual allegati(lns contained in the New Malter are deemed admitted against the Plaintiff. It has been stated that "legal liability in tort is predicated upon acts which cannot be justified In law, or which are done without just or lawful excuse or justifiable cause or occasion." Summary of Pe. Jurisprudence, To;ts . 5: 1. Moreover, "a person cannot maintain an action for a wrong occasioned by an act to which he or she consented." Summary of Pa, Jurisprudence, Torts' 5: 1.74 Am Jur 2d, Torts , 49. By admitting the allegations in the New Matter, i.e. that the actions of the Defendants were privileged, justified, consented to by the Plaintiff, done in the reasonable and good faith belief thet the actions were lawful, and that the Defendants are entitled to various immunities and limitations on dlmlg.., thl Pllintiff no longer h.. I vilble cluse of Ictlon Igllnst the Defendents, snd liS such, thl Complelnt Igelnsl the Defendenls muSI be dismissed, Courts of this Commonweelth heve held thet summery judgment Is approprllte where e plrty do.. not respond within the twenty (201 dlY time period to 'actuel ellegetlons contelned in New Mettsr. 5.. I.g., Edmond v. SouthellStern Pennsvlvanla TransDo'l~tion. Authoritv, ___ Pa. Commw. ,6151 A.2d 6415 (1994); Gotwalt v. DellinQer, 395 F'a. Super, 439,577 A.2d 623 (1990). Moreover, the Edmond Court went so fer es to declere that even if a party files a Reply to New Metter beyond the twenty /201 day period, the reply has no legel effect because the pleadings era closed and summery judgment Is w'lffanted. See Edmond. 651 A.2d at 647. In the present case, by operation of law, the Plaintiff has admitted that among other things. the actions of the Defendants were privileged. justified and consented to by Plaintiff. (See Defendants' Answer with New Metter" 103-1051. As e result. tho Plaintiff cannot maintain an action against the Defendants for personal injuries based on ections which were privileged. justified and to which he himself consented. By failing to respond to the New Matter and having these factual allegations in the New Metter deemed admitted egainst him. Plaintiff hes no cause of action against the Defendents end the Compliant must be dismissed. . charts, statements, or other written material which relates to either the liability of the Defendants, or the alleged Injuries suffered by the Plaintiff. In accordance with Pa.R.C.P. No. 4002.1 this request has not been filed with the Court. Your responses should be In accordance with Pa.R.C.P. 4014, and are to be supplemented in accordance with Pa.R.C.P. No. 4007.4. ~ B. ADMISSIONS REOUESTED Please admit or deny each of the following factual statements, with a detailed explanation for each deniel: 1. On or about January 23, 1996, Cory A. Cormany was a prisoner incarcereted in Cumberland County Prison in lieu of $26,000.00 bail. 2. Prior to January 23, 1996, while incarcarated In Cumberland County Prison, Cory A. Cormany faced disciplinary action for various offenses occurring on August 6, 1996, August 30, 1996, September 21, 1996, and November 23, 1995. 3. ) As a result of the incident occurring on January 23, 1996, Cory A. Cormany received disciplinary.ection on the charge of "indiffarent or deliberate ection or attempt to expose another person to bodily fluids or othar hazardous material." 4. On January 23, 1996, Cory A. Cormany spit on Defendant Travis Shenk hitting him in the shouldm end right sid a of his neck and shirt, and then reached 8 cup into the toilet In his cell and threw what appeared to be urine and water on Defendant Travis Shank. 6. Cory A. Cormany refused to attend tha disciplinary haaring held on February 6, 1996 with regard to the charge arising out of tha incidant of January 23, 1996. 6. Cory A. Cormany's actions of January 23, 1996 including spitting and throwing urine on Defendant Travis Shenk constituted risk of physical harm to Defendant Shenk. 7. Cory A. Cormany's pctlons on January 23, 1996 consisting 01 spitting and throwing urine on Defendant Trevls Shenk were In violation 01 the rules 01 the Cumberland County Prison and subjected Cory A. Cormany to disciplinary action. 8. At no time material to this case, did Delendant Frenk Teaney assault, harm, shock. baat, threaten and/or bondage Cory A. Cormany to a board lor twelva (121 hours and kick, stap, shock or punch him. , 9. At no time material to this case, did Delendant Curtis Colbertson assault, harm, shock, beat. threaten end/or bondage Cory A. Cormany to a board lor twelve (12) hours and kick, step, shock or punch him. 10. At no time material to this case, did Delendant Travis Shenk essault, harm, shock, beat, threaten and/or bondage Cory A. Cormany to a board for twelve (12) hours and kick, step, shock or punch him. 11. At no time material to this case, did Delendant Jack Wallace assault, harm, shock, beat, threaten and/or bondage Cory A. Cormany to a board lor twelve (12) hours and kick, step, shock or punch him. 'I 12. At no time material to this case, did Delendant Michael lie assault, harm, shock, beat, threaten and/or bondage Cory A. Cormany to a board lor twelve (12) tJours end kick, step, shock or punch him. 13. The actions of Defendants Frank Teaney, Curtis Colbertson, Travis Shenk, Jack Wallace, and Michael lie were appropriate under the circumstances existing on January 23, 1996 based on the behavior 01 Cory A. Cormany, which included spitting on the Delendants and throwing urine on them. 14. At no time material to this case, did Cory A. Cormany suffer physical Injuries as a result 01 the alleged Incident occurring in the Cumberland County Prison on January 23, 1996. PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted In duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Pleue list the within matter for the next: o Pre-Trial Argument Coun 11 Arllument Coun ................................................................................................. CAPTION OF CASE \entire caption must be stated in full) '. -I 1 " CORY A, CORMANY, '.11 '1 ) ,(l) " ., , I I'il I .' (Plaintiff) v~. , " " (:~ C') FRANK TEANEY, CURTIS COLBERTSON, TRAVIS SHENK, JACK WALLACE and MICHAEL ILE, (Defendants) No. 96-1730 Civil Term I. State matter to be argued (I,e., Plaintiffs motion for new trial, Defendant's demurrer to complaint, etc,): Defendants' Motion for Summary Judgment 2. Identify counsel who will argue case: a) For Plaintiff: Address: Cory A. Cormany, Pro Se 1883 Douglas Drive, Carlisle. P A 17013 b) Joseph L. Hitcbings, Esquire 301 Market St" P.O. Box 109, Lemoyne, PA 17043-0109 For Defendants: Address: 3. I will notify all panics in writing within two days that this case has been listed for argument. 4. Argument Coun Date: April 16, 1997 Call of ArgumentUst Date: Dated: March II, 1997