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HomeMy WebLinkAbout96-03636 \. ~ ~ ~ \. " "'- ~ ~ ~ "".... '-,," -, "< , \ I / i<"i ii'!"" ,..tl ' ,;,.11' " ~ ~ , , i " - j ... I I .~ i .. '-.l I , ~ ., ~ I ,I . ./ ..3 / ~ ALISON KOTZMOYER, Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERI,AND COUNTY, PENNSYLVANIA NO. () rr :; (, 1c-. ( I { I ( \ (' CIVIL ACTION - LAW ASSAULT AND BATTERY v. JOHN HOCKER, NOTICE TO DEFENDANT NAMED HEREIN: You have been sued in Court. It you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing wIth the Court your defenses or objections to the claims set forth against you, You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff, You may lose money or property or other rights important to you. YOU SHOULD 'rAKE 'rHIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FOR'l'H BELOW TO FIND OUT WIIEHE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOH Cumberland County Court House, 4th Flr, 1 Courthouse Square Carlisle, Pennsylvania 17013-3387 (717) 240-6200 Le han demand ado a usted enla corte. si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partie de la fecha de la demanda y la notificacion. Usted de be presentar una apariencia escrita 0 en persona 0 pOI." abogado y archival." en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y pOI." cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. ALISON KOTZMOYER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 'II., .-:1.. ,:t, (I, . I I., . JOHN HOCKER, Defendant CIVIL ACTION - LAW ASSAUL'l' AND 13AT'l'ER'l COMPLAINT AND NOW comes the Plaintiff, Alison Kotzmoyer, by and through her attorneys, Friedman and Friedman, P.c., and brings this cause of action against the Defendant and avers as followsr 1. The Plaintiff, Alison Kot?moyer, is an adult individual residing at 93 Pleasant View Terrace, New Cumberland, 'lork county, Pennsylvania 17070, 2. The Defendant, John Hocker, is an adult individual residing at 1710 Charles st., New cumberland, Cumberland county, Pennsylvania 17070. 3. On or about the evening of January 28, 1995, the Plaintiff was a passenger in a vehicle being driven by her sister in a lawful and careful manner in a northerly direction on Bridge Street in New Cumberland, 4. After the Plaintiff's sister made a left turn at the traffic signal onto Lowther Road in Lemoyne, the Defendant negligently, recklessly, and carelessly operated a 1992 Toyota Camry so as to pull in front of the vehicle in which the Plaintiff was a passenger so as to interfere with the Plaintiff's vehicle's right of way, and which resulted in the driver of the vehicle in which tha Plaintiff was a passenger sounding her horn and slamming on her brakes, 5, After the above-referenced incident, the Plaintiff's sister, the driver of the vehicle in which the Plaintiff was a passenger, continued towards her destin~tion of the Capital city Mall, her vehicle now being behind the Defendant/s vehicle. 6. While traveling in a westerly direction on Old Gettysburg Road in Camp Hill, and approaching the traffic signal at the intersection of Old Gettysburg Road and Hartzdale Drive, the Plaintiff/s sister pulled into the left lane in order to prepare to make a left turn onto Hartzdale Drive, and the Defendant remained in the right lane as if traveling straight ahead. 7. Upon stopping his vehicle due to a red light, the Defendant exited his vehicle and unsuccessfully attempted to open the Plaintiff/s passenger side door, COUNT I 8. The averments contained in paragraphs 1 through 7 above are incorporated herein as though more fully set forth at length. 9. At the above-referenced date and place, the Defendant assaulted the Plaintiff with his fist, and did punch through the passenger window beside Which the Plaintiff sat/ and did shatter the window, causing glass to be strewn onto the Plaintiff, and causing the Plaintiff to be jerked about the interior of the vehiole with great foroe and violence and to be covered with glass particles. 10. As a result of the Defendant's assault and battery, the Plaintiff suffered the following injuries I a, A severe exacerbation of a pre-existing cervical sprain/strain; b. An exacerbation of a pre-existing lumbar strain; c. Pain in her chest; d. Pain in her neck; e. Pain in her low back; f. Spasm in the Bcalene muscles bilaterally; g. Decreased cervical range of motion; h. Decreased grip strength; i. Pain in the upper trapezius muscles, the lateral cervical muscles, the mid-cervical spinous processes, and the T-8 spinous process; j. Palpable muscle spasms in various muscles in her neck and upper back; k. Facial abrasions; 1. Pain and discomfort in her eyes and face; m. Permanent facial scarring; and n. Emotional and psychological pain and suffering. JUl. -013-[ '.1?6 1;2 :OJ? --- , DEPT, ltlBOI<'.1I HJLJc 110, ','1','78~52.?';:" P.03 llJ w:Jr"'-'" - '0 ALISON KOTZMOYER, Plaintiff Defendant IN 'rHE COUR'l' OF COMMON PLEAS CUMBEHLANO COUWl'Y, PENNSYLVANI'" NO, ql", -,-30 H" (}~U.l~l1L CIVIL ACTION - LAW ASSAULT AND BATTERY v, JOHN HOCKER, NOTICE TO DEF'ENDAN'l' NAMED HEREIN: . ", Vou havo been suod in Court, If you wish to defend against the claims set forth in tho fallowing pages, you must take action within twenty (20) days after this Complaint and Notice ara sarved, by entering a written appearance p~rsonally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. Vou are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim Qr relief requested by the Plaintiff, You may lose money or property or other rights importallt to you. YOU SHOULD TAKE 'rillS PAPER TO YOUR LAWYER AT ONCE. If YOU DO NOT HAVE 1\ LAWYER OR clINNOT lIF'FORD ONE, GO TO OR TELEPHONE TilE OFPICE SET FORTH BELOW TO FIND OUT WHERf: YOU CAN GET LEGAL HELP, COURT ADMINISTRATOR Cumberland County Court House, 4th FIr. 1 Courthouse Square Carlisla, Pennsylvania 17013-3387 (717) 240-6200 La han demandado a usted enla corte. Si usted quiare doEendersQ de estas demandas expueatas en las paginas siguiantes, usted tiene viente (20) dins de plaza a1 partie de la facha de 1a demanda y la notiEicacion. Usted debe presentar una apariencia escrita 0 en persona 0 par abogado y nrchivar en la corte en torma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no Sa defiende, la corte tomara medidas y puede entrar una orden contra usted sin previa aviao 0 notificacion y par cua1quier queja 0 alivio que es pedido en 1a petician de demanda, Usted puede perder dinero 0 SUB propiedadoD 0 otros derechos importantes para usted. " 1 lJEPT, Lf-lBor<& I fll)US TR',' 71 '17835225 P, 05 10 ALISON KOTZMOYER, Plaintiff I IN TilE COURT 01" COMMON PLEAS I CUMDERLAND COUNTY, PENNSYLVANIA t t NO. t t CtVIL ACTION - LAW t ASSAULT AND BATTERY v, JOliN HOCKER, Dehndllnt tlOHl'LAIN'[ AND NOW como a th$ Plaintiff, Alison Kot7.moyer, by and through her attornoys, Friodman Rnd Friodman, P,c., and bringB this cause of /lction against the Defendant and aVers as tollowSI 1. l'he Plaintiff, Alison Kot?moyer, is an adult individual residing at 93 Pleasant View Terrace, New Cumberland, York County, Pennaylvania 17070, 2. The Defendant, John Hocker, is an adult individual residing at 1710 Charles st" New Cumberland, Cumberland County, PennsYlvania 17070, 3. On or about the evening of January 28, 1995, the Plaintiff was a passenger in a vehiCle being driven by her sister in a laWful and careful manner in a northerly direction on Bridge street in New Cumberland, 4. After the Plaintiff's sister made a left turn at the traffic signal onto Lowther Rood in Lemoyno, the Defendant negligently, recklessly, and carelessly operated a 1992 Toyota Camry so as to pull in front of the vehicle in which the Plaintiff was a passengor so as to interfere with the Plaintiff'S vehicle's right of way, and Which ~nsulted in the drivor of th~ """ ...... vehicle in which the plaintiff Was n passonger Bounding h,r horn and sla~ing on her brakes, 5. After the above-referenced incident, the Plaintiff's sister, the driver of the vehicle in which the Plaintiff was a passenger, continued towards her destinstion of the capital city Mall, her vehiclo now being behind the Defendant's vehicle, 6. While traveling in a westerly direction on Old Gettysburg Road in camp Hill, and approaching the traffic signal at the intersection of Old Gettysburg Road and Hartzdale Drive, the Plaintiff's sister pulled into the left lane in order to prepare to make a left turn onto Ifartzdnle Drive, and the Defendant remained in the right lane as if traVeling straight ahaad. 9. At the above-referenced date and place. the Defendant assaulted the Plaintiff with his fist, and did punch through the passenger window beside Which the Plaintiff sat, and did shatter the window, causing glass to be ntrewn onto the Plaintiff, and causing the Plaintiff to be jarked about tho >.,. .,' .. ., interior of the vehicle with great torco and violonce and to covered with glass partlclee, 10, As a reault of the Defendant's assault and battery, the Plaintiff suttered the following injuries: a. A aevere exacerbation ot a pro-existing cervi~al sprain/strain; b. An exacerbation of a pro-oxistinq lumbar strain; c. Pain in her choat; d. Pain in her neck; .. Pain in her low back; f. Spasm in tho scaleno muscles bilaterally; g. Decreased cervical range ot motion; h, Decreased grip strength; , i. Pain in the upper trapeziue muscles, tho lateral cervical muscles, the mid-cervical spinous proceases, and the T-8 spinous procees; j. Palpable muscle spasms in various musclee in her neck and upper back; " It, Facial abrasions; 1, Pain and discomfort il1 her eyea and tace; m, Perlnanent facial scarring; and n. Emotional and psychological pain and suffering. JlJL-OB-1996 12'10 '] OEPT, UIIJOR~ I NIJUS fRo ','1'r;r:n~,2.2~ P,OO'10 ~."" , ','1',' ..l 11. As a further roault of the Defendant's Qsu6ult And battery, the Plaintiff BUffered greAt pain, nnd boliav4s and therefore overs that sho will continue to auffer recun'ing pain, and wall hindered and prevented from performing and trilnsilctinq her usual attairs and business, 12. As a fUt'ther result of the Defendant's assault and battery, the Plaintiff was forced to obtain modical treAtment tram VArious providers, and did incur the following medical expenses endeavoring to cure herself of her injuriest a. Richard M, Seldow, D,C. b. Plastic Surgery Center., L.td. c. Premier Eye Care Group, rnc, $2,54J,OO 125,00 50,00 mIEREFORE, tho Plaintiff, Alison Kotzmoyer, demands judgment against tha Defendant, John Hocker, in an amount in excess of $25,000,00, and, therefore, not bound fot' compulsory arbitration. COUNT II 13. The averments contained in paragraphs 1 through 12 above are incorporated heroin as though more fully set forth at length. 14, On the date of the assault and battery, the Plaintiff was n seventeen (17) yeat' old minor child. 15, The malicious, reckless, and willful conduct on the port of the Defendant was without p~ovocntion from the Plaintiff/victim, .'1" .t' I' . , " ; " , II , JUL-08-19~6 12110 1 DEPT, U1EOf;&lfjIJusm't' ','I';",'03'5_;:::',"~ 1',\)') IU " . ~ \~, 'J: 1.1. . WHEREFORE, the Pia intitf, Alison KotzmoYllr, dUlIltHln nil award for aotual and punitive damagee as allowed by law in ~n amount in eXoess of $25,000.00, Rnd, thorefore, not bound for compulsory arbitration. Reapectfully sUbmitted, DatQI~~li70 17100 JFK/bptPleading$\AKotzmoyer.cmp " P. llJ/lll ;X,..!~... VERI P'ICI\'I'rON I, Alison Kotzmoyat, herQby acknOWledge that r ~m the Plaintiff in the foregoing action; that I have read the foragoinq complaint, and th~ facts stated therein arc true and correct to the best of my knowledgo, information and belie!. I understand that any talso statements herein are made sUbjeot to penalties of 18 Pa, C,S, Section 4904, relating to unSWorn falsification to authorities. Datedl~ d5l,ft?, ~Yb~1 Al SOI\ Ko oyer ; ,I" i i I 1\ I I I ALISON KOTZHOYER, Plaintiff Defendant I IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA I I NO, 96-3636 Civil I I CIVIL ACTION - LAW I ASSAULT AND BATTERY v. JOHN HOCKER, AMENDED COMPL~INT AND NOW comes the Plaintiff, Alison Kotzmoyer, by and through her attorneys, Friedman and Friedman, P.C., and brings this cause of action against the Defendant and avers as follows: 1. The Plaintiff, Alison Kotzmoyer, is an adult individual residing at 93 Pleasant View Terrace, New Cumberland, York County, Pennsylvania 17070. 2. The Defendant, John Hocker, is an adult individual residing at 1710 Charles st., New Cumberland, Cumberland County, Pennsylvania 17070, 3. On or about the evening of January 28, 1995, the Plaintiff was a passenger in a vehicle being driven by her sister in a lawful and careful manner in a northerly direction on Bridge Street in New Cumberland. 4. After the Plaintiff's sister made a left turn at the traffic signal onto Lowther Road in Lemoyne, the Defendant negligently, recklessly, and carelessly operated a 1992 Toyota Camry so as to pull in front of the vehicle in which the Plaintiff was a passenger so as to interfere with the Plaintiff's vehicle's right of way, and which resulted in the driver of the vehicle in whioh the Plaintiff was a passenger sounding her horn and slamming on her brakes, 5. After the above-referenced incident, the Plaintiff's sister, the driver of the vehicle in wllich the Plaintiff was a passellger, continued towards her destination of the Capital city Mall, her vehicle now being behind the Defendant's vehicle, 6, While traveling in a Westerly direction on Old Gettysburg Road in Camp Hill, and approaching the traffic signal at the intersection of Old Gettysburg Road and Hartzdale Drive, the Plaintiff's sister pulled into the left lane in order to prepare to make a left turn onto Hartzdale Drive, and the Defendant remained in the right lane as if traveling straight ahead. 7. Upon stopping his vehicle due to a red light, the Defendant exited his vehicle and Unsuccessfully attempted to open the Plaintiff's passenger side door. COUNT I B. The averments contained in paragraphs 1 through 7 above are incorporated herein as though more fully set forth at length. 9. At the above-referenced date and place, the Defendant assaulted the Plaintiff with his fist, and did punch through the passenger window beside which the Plaintiff sat, and did shatter the window, causing glass to be strewn onto the Plaintiff, and causing the Plaintiff to be jerked about the r , . " I ~ . I; interior at the vehicle with great force and violence and to be oovered with qlass particles. 10, As a result of the Defendant's assault and battery, the Plaintiff suffered tho fallowing injuriesl a. A severe exacerbation of a pre-existing cervical sprain/strain, b. An exacerbation of a pre-existing lumbar strain, Pain in her chest, Pain in her neck, Pain in her low back, c. d. e. t. Spasm in the scalene muscles bilaterally; g. Decreased cervical range of motion; h. Decreased grip strength, i. Pain in the upper trapezius muscles, the lateral cervical muscles, the mid-cervical spinous processes, and the T-8 spinous process, j. Palpable muscle spasms in various muscles in her neck and upper back, k. Facial abrasions, 1. Pain and discomfort in her eyes and face; m. Permanent facial scarring; and n. Emotional and psychological pain and SUffering. 11. As a further result of the Oefendant's assault and battery, the Plaintiff suffered great pain, and believes and therefore avers that she will continue to suffer recurring pain, and was hi.ndered and prevented from performi.ng and transacting her usual affairs and business. 12. As a further result of the Defendant's assault and battery, the Plaintiff was forced to obtain medical treatment from various providers, and did incur the following medical expenses endeavoring to cure herself of her injuries: a. Richard M. Seldow, D.C, b. Plastic surgery center, Ltd. c. Premier Eye Care Group, Inc, $2,543.00 125.00 50.00 WHEREFORE, the Plaintiff, Alison Kotzmoyer, demands jUdgment against the Defendant, John Hocker, in an amount in excess of $25,000.00/ and, therefore, not bound for compulsory arbitration. COUNT II 13. The averments contained in paragraphs 1 through 12 above are incorporated herein as though more fully set forth at length. 14. On the date of the assault and battery, the Plaintiff was a seventeen (17) year old minor child. 15. The assault and battery undertaken by the Defendant, as averred in paragraphs 7 and 9 herein, was outrageous/ willful and malicious, and without legal justification or excuse, , I too I'" , , ,. ',' j',1 " . ...... ~ ~2t. ~~ U 8 6~ ...... ... ~ E ...... ~ . '''; ~ a.,; ~ s ""p., . ... "" ~ . '- 12 .: .: ~ jVl ~~ u~ "."'~ .'c;! ~ ~~~Vl,"~ - 'r .J p::.... ,8 .... ~8" I:'-il'l- .. o ~ ~ ~ a .......-,: a I<.~~g ~ ~uu~'" ~ Q . <ij~i.~o~ 'r=; p:: r=; F; ,.;< 0 ~ ~ ~ p 0 ~p,; 0 tj::::;<j6;.,: < 0 e ., , ~ ;:2,0-<,1- ;0. i;;j III ~ 1B~a;...l!5 ~ :t, ~ iil F", t:""'--r. Vl <:i III J ;?""9.;:::~ ...... I<. ......d"u , :?, ~ ......l...iO.......'.Clli.."..'... OIt...-o. O~.'-"''M)''".&I.'" ALISON KOTZMOYER, Plaintiff v. IN TilE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO, 96-3636 civil JOHN HOCKER, Defendant CIVIL ACTION - LAW ASSAULT AND BATTERY ~NDED COMPLAINT AND NOW comes tho Plaintiff, Alison Kotzmoyer, by and through her attorneys, Friedman and Friedman, P.C., and brings this cause of action against the Defendant and avers as follows: 1, The Plaintiff, Alison Kotzmoyer, is an adult individual residing at 93 Pleasant View Terrace, New Cumberland, York county, Pennsylvania 17070. 2. The Defendant, John Hocker, is an adult individual residing at 1710 Charles St., New Cumberland, Cumberland County, Pennsylvania 17070. 3. On or about the evening of January 28, 1995, the Plaintiff was a passenger in a vehicle being driven by her sister in a lawful and car.eful manner in a northerly direction on Bridge street in New Cumberland. 4. After the Plaintiff's sister made a left turn at the traffic signal onto Lowther Road in Lemoyne, the Defendant negligently, recklessly, and carelessly operated a 1992 Toyota Camry so as to pull in front of the vehicle in which the Plaintiff was a passenger so as to interfere with the Plaintiff's vehicle's right of way, and which resulted in the driver of the vehicle in which the Plaintiff was a passenger sounding her horn and slamming on her brakes. 5. After the above-referenced incident, the Plaintiff's sister, the driver of the vehicle in which the Plaintiff was a passenger, continued towards her destination of the Capital City Mall, her vehicle now being behind the Defendant's vehicle. 6. While traveling in a westerly direction on Old Gettysburg Road in Camp Hill, and approaching the traffic signal at the intersection of Old Gettysburg Road and Hartzdale Drive, the Plaintiff's sister pulled into the left lane in order to prepare to make a left turn onto Hartzdale Drive, and the Defendant remained in the right lane as if traveling straight ahead. 7. Upon stopping his vehicle due to a red light, the Defendant exited his vehicle and unsuccessfully attempted to open the Plaintiff's passenger side door, COUNT I 8. The averments contained in paragraphs 1 through 7 above are incorporated herein as though more fully set forth at length. 9. At the above-referenced date and place, the Defendant assaulted the Plaintiff with his fist, and did punch through the passenger window beside which the Plaintiff sat, and did shatter the window, causing glass to be strewn onto the Plaintiff, and causing the Plaintiff to be jerked about the ~ interior ot the vehicle with greet foroe and violenc~ and to be aov.red with glass partiales. 10. As a result of the Defendant's assault and battery, the Plaintift BUffered the following injuries I a, A severe exacerbation of a pre-existing cervical sprain/strain; b. An exacerbation of a pre-existing lumbar strain; o. Pain in her chest; d. Pain in her necki e. Pain in her low backi t. Spasm in the scalene muscles bilaterally; g. Decreased cervical range of motion; h. Decreased grip strength; i. Pain in the upper trapezius muscles, the lateral cervical muscles, the mid-cervical spinous processes, and the T-8 spinous process; j. Palpable muscle spasms in various musoles in her neck and upper back; k. Facial abrasions; 1, Pain and discomfort in her eyes and facei m. Permanent facial scarringi and n. Emotional and psychological pain and SUffering. 11. As a further result of the Defendant's assault and battery, the Plaintiff suffered great pain, and believes and therefore avers that she will continue to suffer. recurring pain, and was hindered and prevented from performing and transacting her usual affairs and business, 12. As a further result of the Defendant's assault and battery, the Plaintiff was forced to obtain medical treatment from various providers, and did incur the following medical expenses endeavoring to cure herself of her injuries: a. Richard M. Seld~w, D,C. b. Plastic Surgery Center, Ltd, c. Premier Eye Care Group, Inc. $2,543,00 125,00 50.00 WHEREFORE, the Plaintiff, Alison Kotzmoyer, demands jUdgment against the Defendant, John Hocker, in an amount in excess of $25,000.00, and, therefore, not bound for compulsory arbitration. COUNT II 13. The averments contained in paragraphs 1 through 12 above are incorporated herein as though more fully set forth at length. 14. On the date of the asnault and battery, the Plaintiff was a seventeen (17) year old minor child. 15. The assault and battery undertaken by the Defendant, as averred in paragraphs 7 and 9 herein, was outrageous, willful and malicious, and without legal justification or excusp.. ALISOl~ KOTZMOYER I IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA I v. I No. 96-3636 Civil I I CIVIL ACTION - LAW JOHN HOCKER I ASSAULT ORDER AND NOW, this day of , 199, upon consideration of Defendant's Preliminary Objections to Plaintiff's Complaint, IT IS HEREBY ORDERED AND DECREED that Count II of the Plaintiff's Complaint be dismissed, BY THE COURT: J. v. IN 'I'm: COUH'I' OF COMMON PLEAS CUMI3WLANll COUNTY, Pl::NNSYLVl\tllA NO. 96-~636 civil ALISON KOTZMOYEH, PlaintH( Defendant CIVIL ACTION - LAW ASSAULT ANn BATTERY JOliN HOCKER, NOTIC~; TO DEFENDANT NAMED HEREIN: You have been sued in Court, If you wish to defend against the cl~ims set forth in the following pages, you must take action within twenty (20) days after this Amended complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court withQut further notice for any money claimed in the Amended Complaint or for any other claim or relief requested by the Plaintiff, You may lose money or property or other rights important to you, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COUR'l' ADMINISTRA'l'OR Cumberland County Court House, 4th FIr. 1 Courthouse Square Carlisle, Pennsylvania 17013-3387 (717) 240-6200 Le han demandado a usted enla corte. si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partie de la fccha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona, Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notiticacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos import antes para usted. ALISON KO'l'ZMOYEH, PlaintifC Defendant IN 'l'IIE COUH'l' OF COMMON PLEAS CUMI3EJU.ANO COUN'l'Y, PENNSYLVANIA NO. 96-3636 civil CIVIL ACTION - LAW ASSAULT AND BATTEHY v. JOHN HOCKER, AMENDER-COMPLAINT AND NOW comes the Plaintiff, Alison Kotzmoyer, by and through he~ attorneys, Friedman and Friedman, P.C., and brings this cause of action against the Defendant and avers as follows: 1. The Plaintiff, Alison Kotzmoyer, is an adult individual residing at 93 Pleasant View Terrace, New Cumberland, York County, Pennsylvania 17070. 2. The Defendant, John Hocker, is an adult individual residing at 1710 Charles st" New Cumbe~land, Cumberland County, Pennsylvania 17070. 3. On or about the evening of January 28, 1995, the Plaintiff was a passenger in a vehicle being driven by her sister in a lawful and careful manner in a northerly direction on Bridge street in New Cumberland. 4, After the Plaintiff's sister made a left turn at the traffic signal onto Lowther Road in Lemoyne, the Defendant negligently, recklessly, and carelessly operated a 1992 Toyota Camry so as to pull in front of the vehicle in which the Plaintiff was a passenger so as to interfere with the Plaintiff's vehicle's right of way, and which resulted in the driver of the vehicle in which the Plnintiff war,) .1 pnllIJCtI(jc'r 13011nding hor horn and slamming on her brakes, 6. After the above-referenced incident, the Plaintiff's sister, the driver of the vehicle in which the Plaintiff was a passenger, continued towards her destination of the Capital City Mall, her vehicle now being behind the Defendant's vehicle, 6. While traveling in a westerly direction on old Gettysburg Road in Camp Hill, and approaching the traffic signal at the intersection of Old Gettysburg Road and Hartzdale Drive, the Plaintiff's sister pulled into the left lane in order to prepare to make ft left turn onto Hartzdale Drive, and the Defendant remained in the right lane as if traveling straight ahead. 7. Upon stopping his vehicle due to a red light, t.he Defendant exited his vehicle and unsuccessfully attempted to open the Plaintiff's passenger side door, COUNT I 8. The averments contained in paragraphs 1 through 7 above are incorporated herein as though more fully set forth at length. 9. At the above-referenced date and place, the Defendant assaulted the Plaintiff with his fist, and did punch through the passenger window beside which the Plaintiff sat, and did shatter the window, causing glass to be strewn onto the Plaintiff, and causing the Plaintiff to be jerked about the ALISON KOTZMo\' lH, I'laintirr v. III '!'IIE COURT OF COMMON PLEAS CUMUEMLAND COUNTY, PENNSYLVANIA No. 96-3636 Civil JOliN HOCKER, Defendant CIVIL ACTION - LAW ASSAULT AND BATTER\' Non CE TO DEFENDANT NAMED HEREINt You have been sued in Court. If you wish to defend against the claims Bet forth in the following pages, you must take action within twenty (20) days after this Amended Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Amended Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR Cumberland County Court House, 4th FIr. 1 Courthouse Square Carlisle, Pennsylvania 17013-3387 (717) 240-6200 Le han demandndo a usted enla corte. si usted quiere defenderse de estas demnndas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partie de la fecha de 1a demanda y 1a notificacion. Usted de be presentar una apariencia escrita 0 en persona 0 por abogado y archivar en 1a corte en forma escrita sus defensas 0 sUs objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notif\cacion y por cualquier queja 0 a1ivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 SUs propiedades 0 otros derechos importantes para usted. ALISON l<OTZMOYEM, Plaintiff v. IN 'rilE couln or COMMON I'LEJ\S CUMI3EHL1\NP COUNTY, PENNSYLVMllA NO. 96-3636 civil JOHN HOCl<ER, Defendant CIVI L Ac'rIoN - LAW ASSAULT AND BATTERY ~11IT AND NOW comes the Plaintiff, Alison l<otzmoyer, by and through her attorneys, Friedman and Fr.iedman, P.c., and brings this cause of action against the Defendant and avers as follows: 1. The Plaintiff, Alison l<otzmoyer, is an adult individual residing at 93 Pleasant View Terrace, New Cumberland, York County, Pennsylvania 17070. 2. The Defendant, John Hocker, is an adult individual residing at 1710 Charles st., New Cumberland, Cumberland county, Pennsylvania 17070. 3. On or about the evening of January 28, 1995, the Plaintiff was a passenger in a vehicle being driven by her sister in a lawful and careful manner in a northerly direction on Bridge street in New Cumberland. 4. After the Plaintiff's sister made a left turn at the traffic signal onto Lowther Road in Lemoyne, the Defendant negligently, recklessly, and carelessly operated a 1992 Toyota Camry so as to pull in front of the vehicle in which the Plaintiff was a passenger so as to interfere with the Plaintiff's vehicle's right of way, and which resulted in the driver of the vehicle in which the PIli inti ff \IiHl .} pllGsenger sounding her horn and slamming on her brakes. 5. After the above-referenced incident, the plnintiff's sister, the driver ot tho vehicle in which the Plaintiff was a passenger, continued towlIrds her destination of the Capital city Mall, her vehicle now being behind the Defendant's vehicle. 6. While traveling in a westerly direction on Old Gettysburg Road in Camp Hill, and approaching the traffic signal at the intersection of Old Gettysburg Road and Hartzdale Drive, the Plaintiff's sister pulled into the left lane in order to prepare to make a left turn onto Hartzda1e Drive, and the Defendant remained in the right lane as if traveling straight ahead. 7. Upon stopping his vehicle due to a red light, the Defendant exited his vehicle and unsuccessfully attempted to open the Plaintiff'S passenger side door. COUNT I 8. The averments contained in paragraphs 1 through 7 above are incorporated herein as though more fully set forth at length. 9. At the above-referenced date and place, the Defendant assaulted the Plaintiff with his fist, and did punch through the passenger window beside which the Plaintiff sat, and did shatter tile window, causing glass to be strewn onto the Plaintiff, and causing the Plaintiff to be jerked about the - interior of tho vehicle with grellt force and violence ond to bo covered with glass particles. 10. As a result of the Defendant's assault and battery, the Plaintiff suffered the following injuriesl a. A severe exacerbation of a pre-existing cervical sprain/strain; b. An exacerbation of a pre-existing lumbar strain; Pain in her chest; Pain in her neck; Pain in her ~ow back; c. d. e. f. Spasm in the scalene muscles bilaterally; g. Decreased cervical range of motion; h. Decreased grip strength; i. Pain in the upper trapezius muscles, the lateral cervical muscles, the mid-cervical spinous processes, and the T-8 spinous process; j. Palpable muscle spasm~ in various muscles in her neck and upper back; k. Facial abrasions; 1. Pain and discomfort in her eyes and face; m. Permanent facial scarring; and n. Emotional and psychological pain and SUffering. 16. The Defendant'& Actions, as AVerr~d in paragraphs 7 and 9 herein, were undertaken solely with the intent to harm the Plaintiff. 17. The malicious, outrageous, and willful conduct on the part of the Defendant, as averred in paragraphs 7 and 9 herein, was without provocation from the Plaintiff/victim. WHEREFORE, the Plaintiff, Alison Kotzmoyer, demands an award for actual and punitive damages as allowed by law in an amount in excess of $25,000.00, and, therefore, not bound for compulsory arbitration. Dat~l~ ~)\,q~ Respectfully submitted, FRIEDMAN, P.C. / F. l< ng, N. Second Stre Pe house Suite P. O. Box 984 Harrisburg, PA 17108 (717) 236-8000 JFK/bpIPleadings\AKotzmoyer.cmp :' PHAEC I I'J:!J'O}1 1!.IF~l!,!<_; _<:~!;_!~_IOH.~.I!GI!!:l}'!i'!' _._._~---- - (Huut be typ.!Wriltl!ll mKl t1ubnJ.ttoo in duplicate) TO TilE I'ROTHONO'I'AllY Of' CUMU~~llLANll COUNTY c rlem,c UlIt tile witlllIl 11~lt:ler for the next Aruuoont Court. --------------------------------------------------------------------------------------- CAPTION OF CASE (entire caption must be stated in full) VB. I. , " '. "1-, -. U! " ~> I , "J " {i) : I (Plaintiff) 1::' .11.) ',; \~l I'l,.' - .",') )'..: .-. -r" .l .. " .~ ".') ~q "I -, ALISON Karm:JYIJR. JaIN 1I0a<ER, ( Defend.llnt ) No. 3636 Civil 19 96 1. State matter to be argued (Le., plaintiff's motion for new trial, defend.llnt's denurrer to CaTqllaint, etc.): Preliminary Cbjcctions of lbfcnu3Ilt to Plaintiff's AntlnJcu Conlllnint. 2. Identify counsel who will argue case: (a) for plaintiff: ,John F, King, Esquire Address: 600 N. Seconu St., 5th HI',. Harrisburg, PA 17101 (b) for defendant: Address : Hobert B, ~lacIntyrc, Esquire 5201 Jonest<Mn Ild., P. O. Box 6656, Harrisburg, PA 17112 3. I....ill notify all parties in writing within h<<> days that this case has been listed for argtJrellt. 4 . ArgLment Court Oilte: October 2, 199<> Dated: Augw; t "J ". 1~% b: ,-I) .~ c:: '.. ..1~ ',' \... ., l...- n .:.r '/.:.1.- I'" )', ~..- ," %;' "': . ,,_1. .. .1 "'J (' t,") ,'(.1 Et I ! 0) 1\" .,..1.1" ~' ,',(,) (l..' ,I':;;' \" +,', " lI, <II ". ~) 0 l)' (,) C6) Ii. THOMAS K~INE Sn.,11I \" of <lIUl1tb '\,\\\ ''fo el:/", ~~ ,~: "0 " ~~,~~~. ~--:.~~~~\o;-.- _;~~~~. '. -' " ... 'II \ -I ~.~~ .'j. ,~.',..';;,.t.\~=.,.;:. ":"<.'\:" . r. t ...._,.....,-~ ',{ 'f'~ ',' .'- . ~ .- . . .~" -,' . l' I, ,j .., ~ ..'l'"~~~-~,.: -;;.' "-\ ., 1/_"';::' ~_;-__~'",,~.;~........r,- '-:i;' ~~.-~;~~. ;~1~ ~:.~' PONNY It ANOERSON Chili Clpuly HOFACE A JOHNSCN e~IICllcr OFFICE OF THE SHERIFF AUDREY a AOAME Pili all. II OIPuty Court Houee Carlisle, Pennsylvania 17013 TO: lion. William 1I0Sp. RE: York County Sheriff's Dept. 26 Eaat Market St. York, PA 17401 .John Bocker VS 8li?abeth Kot?moyer No. 96-3636 Civil Term Writ of Summons Against Addtl Deft Dear Sir: EnclosedplellSefindv.Titof Writ of SummoMs Against AddU Deft to be served upon 811?abeth Kot?moyer at 93 Pleas an t View Terrace, New Cumberland, PA 17070 in your County. Kindly made service thereof and send us your bill of costs and [ will mail a check for same, or enclosed is advc.nce costs which you request. Very truly yours. ..;r?'C'.",( ~ ,.~ ....:~'.' ,. ,< I /~~ 'j '. . .,'......4:~"'...e .t . R. THO~IAS KU:-':E. Sheriff Cumberland County. PennsylvaniCl Enclosures: -. . Ef r " (JI .~ I ;:::;. ., N 0.:.-, """" :.:~' . <.t '" , ,", H~I.I,H~, ..~ llll"" II''' , EXhibit A Ii',; "j "I,,,,,,! <t> ",,;'; ! i'>.~ ~":,,,tf. ;:t '~, ) ~' , . .. ", " " " ~~ V t Ii I' I ,~ I /1; r .-..,. ALISON l<OTZMOYER, Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERDAND COUNTY, PENNSYLVANIA NO. 96-3636 civil CIVIL ACTION - LAW ASSAULT AND BATTERY v. JOliN HOCl<ER, NOTICE; TO DEFENDANT NAMED HEREIN: You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Amended Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do 60, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Amended Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER A'l' ONCE. IF YOU DO NOT HAVE A I,AWYER OR CANNO'f AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FOR'l'1I BELOW 'fO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR Cumberland County Court House, 4th FIr. 1 Courthouse Square Carlisle, Pennsylvania 17013-3387 (717) 240-6200 Le han demandado a usted enla corte. si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partie de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, 1a corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en 1a peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. ~C\. ~\ .,", ALISON KOTZMOYER, Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-3636 civil CIVIL ACTION - LAW ASSAULT AND BATTERY v. JOHN HOCKER, AMENDED COMPLAINT AND NOW comes the Plaintiff, Alison Kotzmoyer, by and through her attorneys, Friedman and Friedman, P.C., and brings this cause of action against the Defendant and avers as follows: 1. The Plaintiff, Alison Kotzmoyer, is an adult individual residing at 93 Pleasant View Terrace, New Cumberland, York County, Pennsylvania 17070. 2. The Defendant, John Hocker, is an adult individual residing at 1710 Charles st., Now Cumberland, Cumberland county, Pennsylvania 17070. 3. On or about the evening of January 28, 1995, the Plaintiff was a passenger in a vehicle being driven by her sister in a lawful and careful manner in a northerly direction on Bridge Street in New Cumberland. 4. After the Plaintiff's sister made a left turn at the traffic signal onto Lowther Road in Lemoyne, the Defendant negligently, reckless1y, and carelessly operated a 1992 Toyota camry so as to pull in front of the vehicle in which the Plaintiff was a passenger so as to interfere with the Plaintiff's vehicle's right of way, and which resulted in the driver of the vehio1e in which the Plaintiff was a passenger sounding her horn and slamming on her brakes. 5. After the above-referenced incident, the Plaintiff's sister, the driver of the vehicle in which the Plaintiff was a passenger, continued towards her destination of the capital city Mall, her vehicle now being behind the Defendant's vehio1e. 6. While traveling in a westerly direction on old Gettysburg Road in Camp Hill, and approaching the traffic signal at the intersection of Old Gettysburg Road and Hartzdale Drive, the Plaintiff's sister pulled into the left lane in order to prepare to make a left turn onto Hartzda1e Drive, and the Defendant remained in the right lane as if traveling straight ahead. 7. Upon stopping his vehicle due to a red light, the Defendant exited his vehicle and unsuccessfully attempted to open the Plaintiff's passenger side door. COUNT I 8. The averments contained in paragraphs 1 through 7 above are incorporated herein as though more fully set forth at length. 9. At the above-referenced date and place, the Defendant assaulted the Plaintiff with his fist, and did punch through the passenger window beside which the Plaintiff sat, and did shatter the window, causing glass to be strewn onto the Plaintiff, and causing the Plaintiff to be jerked about the 1t. As a further result of the Defendant's assault and battery, the Plaintiff suffered great pain, and believes and therefore avers that she will continue to suffer recurring pain, and was hindered and prevented from performing and transacting her usual affairs and business. 12. As a further result of the Defendant's assault and battery, the Plaintiff was forced to obtain merlica1 treatment from various providers, and did incur the following medical expenses endeavoring to cure herself of her injuries: a. Richard M. Se1dow, D.C. b. Plastic Surgery Center, Ltd. c. Premier Eye Care Group, Inc. $2,543.00 125.00 50.00 WHEREFORE, the Plaintiff, Alison Rotzmoyer, demands judgment against the Defendant, John Hocker, in an amount in excess of $25,000.00, and, therefore, not bound for compulsory arbitration. COUNT II 13. The averments contained in paragraphs 1 through 12 above are inccrporated herein as though more fully set forth at length. 14. On the date of the assault and battery, the Plaintiff was a seventeen (17) year old minor child. 15. The assault and battery undertaken by the Defendant, as averred in paragraphs 7 and 9 herein, was outrageous, willful and malicious, and without legal justification or excuse. _.A 1 """-'1'"'1''' 1olI1"I"',' I"" '.11"0111 tV I exhibit B ."'., (rh' ,! I P 'I .. -.....-........ 96.099 I,AW OFFICES OF DONAI,D R. DORER 3907 IIllrtzdule Ilrlve, Suite 706 Cllmp 1111I, IJA 17011 Telephone Number: (717) 731.0988 Attorneys for Defendunt, John lIocker ALISON KOl'ZMOYlm, PLAIN11FF IN TilE COURT OF COMMON PLEAS CUMllERLANJ> COUNTY, PENNSYLVANIA vs. No. 96-3636 CIVIL JOlIN HOCKER, DEFENJ>ANT CIVIL AcrION. LAW JURY TRIAL DEMANDED VERIFICATION I, John Hocker , verify Ihat the statements made in the foregoing Answer of Defendant, fu1mJJ:ocker, to Plaintiffs Complaint which are within the personal knowledge of the undersigned, are lJ1Je and correct, and as to the facts based on the infonnation of others, the IIl1dersigned, after diligent inquiry, believe them to be true. And further, this Veritication is signed on the recommendation of my allomeys, who advise me lhatthe allegations and language in this document arc required legally to raise issues for resolution at trial, by the Court, or by continuing investigation and preparation for trial. I understood that some of these allegations may prove inappropriate after investigation and trin.1 preparation arc complete and I leave the detennination of these malleI'S to my allomeys on their advice. I understand that all statements herein are made subject to the penalties of 18 Pa.C.S.A. ~4904, relating to IInswom falsifications to authorities. Dated: Jolt7At I I ~d/_ IOIln Hocker 96-099 LAW OFFICES OF nONALD R. DORER 3907 lIartzdale Drive, Suite 706 Camp Hili, IJA 17011 Telephone Number: (717) 731-0988 Attorlley~ for J>efelldullt, John Hocker ALISON K01'lMOVER, 1'J.AINml' IN TilE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. .JOliN HOCKER. J)EfENIlANT No. 96-3636 CIVIL VS. EUZABETlI KOTZI\IOYER, ADIlITIONAL DEFENIlANT CIVIL ACTION . LAW .JURV TRIAL DEMANDED VERIFICATION DONALD R. DORER, ESQUIRE, hereby Slales lhal he is altorney for the Defendant in this actioll, and is authorized to verify thaI lhe stalemeJlls made in the foregoing pleading are true and COITeClto the besl of his knowledge, infonllluion and belief. The undersigned understands that the statemenls therein are made subjcctto the penalties of 18 Pa.C.S.A. g4904 relating to unsworn falsification to authorities. L~/) ..~.. DO ALD R. DORER, ESQUIRE Altomey for Defendant, John Hocker Dated: October 18. 1996 ~~ "~I -t'1 ( ti - 1'1 ~ , 1 (~ " I' ,; ~ I ". , ) f' - '1 -.: III -.: ('J ~I" = lie ~I'l~ ~gH> f.., :t~~~ I EO. ii'i ~ ,;;; O U I:! ~ ,_.... -.:.. ......- .. ""' " = .... .... ... w-=-- 'I ~,...CI; ,........ - ~, ~ - - .,. ..... .. ..( _ . _ II< ~.. U ~ ~ CI: 1'11< Nu,: %.11'I~ rJlAl~Cll)E.EQR..US'JJN!!,.CL\~E.l"Q.I!~~ (Musl he IYlll'wrllll'n nnd suhmllll'd III dUJlllclIll'.) TO nm PROnWNOTARY OF CUMBERLAND COUNTY: Plcasc IIsl thc following CIISC (chccK onc): - ( x) for JURY trlnllll thc ncxt tcnn of civil court. ( ) for IrllIl without a .Jury. q V) () ( -J " . If) I ;lIr I: \I \1 'I ,'. Ilrt " ".: '-' ',I II I . .~. ) ....; "',1 " 'I , ( ", J "', ,!ll ~ ~. " ~ ! ,. ,-,:, j CAPTION OF CASE: (Entire Cuplion Must Bc SUllcd In Full) (Check One) ( AssulllJlslI ( ) TresJluss Alison KotzllIoyer. ( x) Trespllss (Motor Vehicle) ( ) (Pllllnllft) IOt/u:r) VS, John Hocker, '111< Irinl II" will he </llled un OCluher 14. 1997 Trin'" l'()I11I11~n(~ on NuvelliliITJn. 1991 (Defendlllll) Pre-trilllN will he held on (ll-roher 22. 191)7 IIlritf. Ir\! due .~ .1.),. heloln: Ilr~ Iri.I..) (Ill..: plll1)' IiMitllZ lhi. UbC tilr Irilll hlulll'rtl\Ihlc l.n1hwilh II l'lljl)' nf rhe: I'rHc..;ipc III .J1l'tlllllM'I, IllJUlJ',ll 1.1 1.1\,'.1 ~HII! 21".1,) No. 96-~ Civil_ 19 96 Indicate the allomey who willlry case for Ihe party who files this pracclpc: Donald R. Dorcr. Esquirc. Allomey for o.:fendanl. Rubinate...Jnc.gbs & Saba, 214 Sellilk.AYJ:1lli~fu!i!L503. Camp Hill. Penll!ij:'lvania~ 17011: (17) 731-0988. _ Indicatc trial counsel for other panics if known: John F. King. E~!lillre. Allo.n.lcy for Plaintiff. Fricdman & Erlcdman. P.C.. 600 Nonh Second Street. Penthou,lc Suite. P.O. Box 9H4. Harrili!llirJ:....EldIlli)'lYJlDia. 1710L 1717) 236.8000. _ Additional Counsel: -RQben B. MacIntyre. Esquire, Macllllyre & MacIntyre. 5201 Joncstown Road. Harrisburg. FrnruiylY.'I!lia 17112: (717) 6~:2185. ~ / This casc is ready for trial. I / ;' / \ Signedf / ' ',. Print ~alTle:-1;!Q!IJl.!\L.lL.Dorer. Esquire AlIomcy for: Defcllil.il111- Date: September 17. 1997