HomeMy WebLinkAbout96-05358
SAlOIS,
SHUFF &
MASLAND
AT1'ORNEVS.ATIU.W
26 W. High Street
Carlisle, PA
RAY E. SHUMAN and
SHARON SHUMAN,
Plaint if f
v.
RENITA PAIGE JOHNSON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
No. 96-5358 CIVIL TERM
PRAECIPE TO ENTER JUDGMENT
TO THE PROTHONOTARY:
Please enter judgment in favor of Plaintiff pursuant to the
Award of Arbitrators in the amount of $18,921,29.
Date: (: _ 'i - '7 fi
\
Respectfully submitted,
SAIDIS,
MAS LAND
b~
Ray E. Shuman and Sharon Shuman,
Plaintiffs
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 5358
1996
CIVIL
v.
Renita Paige Johnson,
Defendant
v.
COuntry Corner Rental Center, Inc.,
Additional Defendant
RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially
in the following form:
PETITION FOR APPOINTMENT OF ARBITRATORS
TO THE HONORABLE, THE JUDGES OF SAID COURT:
Edward E. Guido. Esquire
, counsel for the plaintiff/defendant in
the above action (or actions), respectfully represents that:
1. The above-captioned action (or actions) is (are) at issue.
2. The claim of the plaintiff in the action is S
The counterclaim of the defendant in the action is N/A
The following attorneys ,are interested in the
wise disqualifi~d to sit as arbitrators:
case(s) as counselor are
Peter Foster. Esquire
other-
Anthony Adams, Esquire
WHEREFORE. your petitioner prays your Honorable Court to appoint three (3)
arbitrators to whom the case shall be submitted.
./
Edward"E. Gu1do, Esquire
foregoing
ORDER OF COURT
/4 fJiL.1 . L I ~ ,19 97. in consideration of ~he
petition, h'i..ollL'L ~ // v<... Esq., ,?JaNElle! .lnll. E/L
1/ / . /
7\~ 'Iii .1Jt!. fIIlmONd ,Esq., are appointed arbitrators in the
AND NOW,
Esq., and
above-captioned action (or actions) as prayed for.
'.
Fi~.':.(~v": :' .....u
" P. J.
" /k
t,f':( 16 en
.......,..
J
S'-j : l! :.:
\" '-,rr
-.~
'" '.
q . . 1
,
.,
~ " '" ,.J
~ r~ ')
f' .,
\l' '1l' ~ :.)
()
. "j In
~ I" Jt (.-
-.J l" .:::.. r:.) " .
- ~ ~
CS' -<<
~ r. '"
. ;.:":'.1
-: j
~b
,..','
J ''- ,.... . , ~"
:::::1;3.:; C;j';:;1
"
.1,'
: . t I ~.: !.:
I -:il:1
I;;'~;' ;.L.! :
"[-Ii-
, " \ \ 1 1.;1. ;'.. ~ I
,
:_IH:.E~i~; ,'_,I 11 'I t.
f;,",IJ it..
!~ ;
h,L~I', '-: :. H
l'
i~" iJ:'l p, ~_:':, .\!il'
t ,)
~ j r, ;.
I,h.;.:
'.
,"
:':j ~;
',lr'''':
d~' t, .. j
.- ;jot..
,ji
::..1_
~~!U
'?_~'~~L5Q-,)X/~!_..._" r n
,.
_' ,.i) n ~_ '/.
n,I.o.'/l
'J ,j ~,
::'1
! ,- UE
::1,1'.; .:] t
,:.~t_.:"
I. ('.~1.-;' I::. h .;:.'!-
w:. i.'r;
:;I_I;'I'-
~n,j
.-3 t
r.h.:;'
.::' ':i r;~.:-
l.
r' J !. ~- , c
~ .~' c. k r~. ;-.
_ I;
-"-:,'r-';:;i-"
;\. i f l'~ ~" ,~, :. ..
-~: r-::-l.l r':l'~
'-',
i,.:
, ;
I;"
;i"
: ~ : - ..
"','...
.1;
,.
','" , .. ;.1r.
.
, r: , .II t.!.-
, (~ .
,., (,_L'-J
.~-i <.. ".LL
..
~-)',~~J; .1vv...l.G.. i-.L ~
, . II':; ,;' ........,: t'f;.,
,.
!!.
"
..",; ,~
r>>i ,"
/..:;.//
. ' . ;;:.-',t...,.;"'."':"'~'
. "
..~.,/~
....,. ~..: ",.. ,"'..> '
.'/ ..~..v.'''-''--'
',I ~
. ,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY - PENNSYLVANIA
Ray E. Shuman and
Sharon Shuman,
Plaintiffs
NO: 96-5358
: CIVIL ACTION - LAW
vs.
: CIVIL TERM
Renita Paige Johnson,
Defendant
1.
ANSWER OF ADDITIONAL DEFENDANT
Admitted.
2.
Admitted.
3.
Admitted.
4.
Admitted.
5.
The Country Corner Rental Center, Inc., inspected the vehicle
of Defendant on September 29, 1995.
6.
Admitted.
7.
Admitted.
8.
Denied, after reasonable investigation Defendant is without
information sufficient to form a belief as to the truth of the
matter averred.
hereto and incorporated herein by reference as Exhibit "A". On
October 23, 1996 Mrs. Johnson filed an Answer which is attached
hereto and incorporated herein by reference as Exhibit "B".
5. In August of 1995 Additional Defendant inspected
Defendant's vehicle, including its brakes, and issued an inspection
sticker for said vehicle, a 1979 Chevrolet pick up truck.
6. The accident giving rise to the instant civil action
occurred on May 12, 1996 at approximately 9:00 PM on Ridge Road,
Hopewell Township, Cumberland County, pennsylvania.
7. At said time and place Defendant was operating her 1979
Chevrolet pick up truck along the said Ridge Road in a general
easterly direction.
8. At said time and place, the brakes on Defendant's vehicle
failed and then locked forcing Defendant's vehicle across the
westbound lane of Ridge Road and off the berm of the roadway into
Plaintiffs' yard.
9. At said time and place Defendant's vehicle collided with
a 1990 Grand Prix motor vehicle and a 1995 Ford pick up truck which
were parked in Plaintiffs' yard, causing property damage.
10. Said accident and damages were caused by the negligence
of Additional Defendant in not properly inspecting Defendant's
vehicle.
SAlOIS, GUIDO,
SHUFF &
MAS LAND
26 W. Hi!:" Sleecl
Carlislc,PA
RAY E. SHUMAN and
SHARON SHUMAN,
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 96-
CIVIL TERM
RENITA PAIGE JOHNSON,
Defendant
CIVIL ACTION - LAW
COMPLAINT
AND NOW, comes the Plaintiffs Ray E. Shuman and Sharon
Shuman, by and through their attorneys Saidis, Guido, Shuff &
Masland and aver as follows:
1. The Plaintiffs are Ray E. Shuman and Sharon Shuman,
adult individuals who currently reside at 993 Ridge Road,
Shippensburg, Cumberland County, Pennsylvania.
2. The Defendant is Renita Paige Johnson, an adult
individual who currently resides at 129 B002 Road, Shippensburg,
Cumberland County, Pennsylvania.
3. The events hereinafter complained of occurred on or
about May 12, 1996 at approximately 9:00 p.m. on Ridge Road,
Hopewell Township, Cumberland County, Pennsylvania.
4. At said time and place Defendant was operating a 1979
Chevrolet pick up truck along the said Ridge Road in a general
easterly direction.
5. At said time and place Plaintiffs were the owners of a
1995 Ford pick up truck and a 1990 Pontiac Grand Prix which were
lawfully parked.
6. At said time and place, Defendant. s vehicle crossed
through the westbound lane of said Ridge Road, ran off the berm
and struck Plaintiffs' vehicles.
EXHIBIT "A"
,
\.:
SAlOIS, GUIIlO,
snUFF &
MAS LAND
26 W. High Slrccl
Carlislc.J1A
7. Plaintiffs' damages as hereinafter set forth were the
direct and proximate result of the negligence of Defendant then
and there occurring.
8. Defendant was negligent generally and in the following
particulars:
a. Operating her vehicle in a reckless mqnner;
V b.
road;
Failing to drive on the right side of the
c. Failing to have her vehicle under proper
control;
L--- d. Failing to stop before colliding with
Plaintiffs' vehicles;
e. Fai ling to take action to avoid the collision
with Plaintiffs' vehicles;
f. Failing to comply with the provisions of the
Pennsylvania Motor Vehicle Code relating to the
operation of motor vehicles, specifically as it relates
to the aforesaid acts of negligence.
13. As a direct and proximate result of the negligence of
Defendant then and there occurring, the Plaintiffs sustained
damages of $18,921.29 as follows:
a. Property damage to the 1990 Grand Prix in the
amount of $2,263.57.
b. Property damage to the 1995 Ford pick up in
the amount of $15,813.34 ($24,677.34 less $8,864 net
salvage).
c. Vehicle rental in connection with 1990
Pontiac Grand Prix $419.38.
d. Vehicle rental in connection with 1995 Ford
pick up $425.00.
C:\wp\clients\johnson.ans
RAY E. SHUMAN and
SHARON SHUMAN,
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBEr-LAND COUNTY, PENNSYLVANIA
vs.
NO. 96-5358
CIVIL TERM
RENITA PAIGE JOHNSON,
Defendant
CIVIL ACTION - LAW
ANSWER TO COMPLAINT
AND NOW, comes the Defendant, Renita paige Johnson, by her
attorney, Peter B. Foster, Esquire, and answers the Complaint as
follows:
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted
5. Admitted.
6. Admitted.
7. Denied. It is
denied that Plaintiffs' claimed damages
were the direct and proximate result of the negligence of the
Defendant then and there occurring. Said averment states a
conclusion of law to which no responsive pleading is required.
8. Denied. It is denied that Defendant was negligent
EXlIIllIT "B"
generally. Said averment states a conclusion of law to which no
responsive pleading is required.
8(a). Denied. It is denied that Defendant operated her
vehicle in a reckless manner. Said averment states a conclusion
of law to which no responsive pleading is required.
8(b). Denied. It is denied that Defendant failed to drive
on the right side of the road. Defendant's brakes failed which
caused her vehicle to leave the highway due to the negligence of
Country Corner Rental center, Inc., in not properly inspecting her
vehicle.
8 (c) . Denied. It is denied that Defendant failed to have
her vehicle under proper control. Said averment states a
conclusion of law to which no responsive pleading is required.
8(d). Denied. It is denied that Defendant failed to stop
before colliding with Plaintiffs' vehicles. Defendant's brakes
failed which caused her vehicle to collide with Plaintiffs'
vehicles due to the negligence of Country Corner Rental center,
Inc., in not properly inspecting her vehicle.
8(e). Denied. It is denied that Defendant failed to take
action to avoid the coll 1sion with Plaintiffs' vehicles. Said
averment states a conclusion of law to which no responsive pleading
is required.
8(f).
Denied. It is denied that Defendant failed to
comply with the provisions of the pennsylvania Motor Vehicle Code
relating to the operation of motor vehicles, specificallY as it
relates to the aforesaid acts of negligence. Said averment states
a conclusion of law to which no responsive pleading is required.
13. Denied. It is denied that as a direct and proximate
resul t of the negligence of Defendant then and there occurring, the
Plaintiffs sustained damages of $18,921.29. Defendant has no
knowledge as to the truth or falsity of said averment and strict
proof thereof is demanded at trial. In addition, Defendant denies
having committed any negligent acts. said averment of negligence
constitutes a legal conclusion to which no responsive pleading is
required.
13(a). Denied. It is denied that Plaintiffs suffered
property damage to the 1990 Grand Prix in the amount of $2263.57.
Defendant has no knowledge as to the truth or falsity of said
averment and strict proof thereof is demanded at trial.
13(b). Denied. It is denied that Plaintiffs suffered
property damage to the 1995 Ford pick up in the amount of
$15,813.34 and strict proof thereof is demanded at trial.
13(c). Denied. It is denied that Plaintiffs suffered
damages in the nature of vehicle rental in connection with the 1990
Pontiac Grand Prix in the amount of $419.38. Defendant has no
knowledge as to the truth or falsity of said averment and strict
C:\wp\clients\johnson.ans
RAY E. SHUMAN and
SHARON SHUMAN,
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 96-5358
CIVIL TERM
RENITA PAIGE JOHNSON,
Defendant
CIVIL ACTION - LAW
ANSWER TO COMPLAINT
AND NOW, comes the Defendant, Renita paige Johnson, by her
attorney, Peter B. Foster, Esquire, and answers the Complaint as
follows:
1- Admitted.
2. Admitted.
3. Admitted.
4. Admitted
5. Admitted.
6. Admitted.
7. Denied. It is
denied that Plaintiffs' claimed damages
were the direct and proximate result of the negligence of the
Defendant then and there occurring. Said averment states a
conclusion of law to which no responsive pleading is required.
8. Denied. It is denied that Defendant was negligent
generally. Said averment states a conclusion of law to which no
responsive pleading is required.
8(a). Denied. It is denied that Defendant operated her
vehicle in a reckless manner. Said averment states a conclusion
of law to which no responsive pleading is required.
8(b). Denied. It is denied that Defendant failed to drive
on the right side of the road. Defendant's brakes failed which
caused her vehicle to leave the highway due to the negligence of
Country Corner Rental Center, Inc., in not properly inspecting her
vehicle.
8(c). Denied. It is denied that Defendant failed to have
her vehicle under proper control. Said averment states a
conclusion of law to which no responsive pleading is required.
8(d). Denied. It is denied that Defendant failed to stop
before colliding with Plaintiffs' vehicles. Defendant's brakes
failed which caused her vehicle to collide with Plaintiffs'
vehicles due to the negligence of Country Corner Rental Center,
Inc., in not properly inspecting her vehicle.
8(e). Denied. It is denied that Defendant failed to take
action to avoid the COllision with Plaintiffs' vehicles. Said
averment states a conclusion of law to which no responsive pleading
is required.
8(f) .
Denied. It is denied that Defendant failed to
comply with the provisions of the Pennsylvania Motor Vehicle Code
relating to the operation of motor vehicles, specifically as it
relates to the aforesaid acts of negligence. Said averment states
a conclusion of law to which no responsive pleading is required.
13. Denied. It is denied that as a direct and proximate
resul t of the negligence of Defendant then and there occurring, the
Plaintiffs sustained damages of $18,921.29. Defendant has no
knowledge as to the truth or falsity of said averment and strict
proof thereof is demanded at trial. In addition, Defendant denies
having committed any negligent acts. Said averment of negligence
constitutes a legal conclusion to which no responsive pleading is
required.
l3(a). Denied. It is denied that Plaintiffs suffered
property damage to the 1990 Grand Prix in the amount of $2263.57.
Defendant has no knowledge as to the truth or falsity of said
averment and strict proof thereof is demanded at trial.
13 (b) . Denied. It is denied that Plaintiffs suffered
property damage to the 1995 Ford pick up in the amount of
$15,813.34 and strict proof thereof is demanded at trial.
13(c). Denied. It is denied that Plaintiffs suffered
damages in the nature of vehicle rental in connection with the 1990
Pontiac Grand Prix in the amount of $419.38. Defendant has no
knowledge as to the truth or falsity of said averment and strict
\
>- C) ~::
c-~
r.:~ "oj :-1 ....
W';.:.: ',.,.".
) . .~
Sol " - :~.
ff'-
J.:. t.... ,j
9'
, . '" 1
or. ,-: .
U.!,. l- ; ;I;j
~r
l..... L '. -'1-
.. CJ
Ll.. , ~} \:.J
Cl (J.
,
r
Pa, Reporter, 449-700 A.2d 700 A.2d 1038, Duquesne Light Co, v, Woodland
Hills School Dist" (Pa.Cmwlth. 1997)
__________________________ Page 700 A.2d 1038 follows --------------------------
700 A,2d 1038
DUQUESNE LIGHT COMPANY
v,
WOODLAND HILLS SCHOOL DISTRICT
v.
MICHAEL BAKER, JR" INC., Coco Brothers Construction Company
and Carl G. Baker
V.
WAYNE CROUSE, INC,
Appeal of Carl G, BAKER, Appellant.
DUQUESNE LIGHT COMPANY
V.
WOODLAND HILLS SCHOOL DISTRICT
v.
MICHAEL BAKER, JR., INC., Coco Brothers Construction Company
and Carl G, Baker
V.
WAYNE CROUSE, INC.
Appeal of Michael BAKER, Jr., Inc" Appellant,
DUQUESNE LIGHT COMPANY
v,
MICHAEL BAKER, JR., INC., Coco Brothers Construction Company
and Carl G. Baker.
V.
WOODLAND HILLS SCHOOL DISTRICT
Appeal of Michael BAKER, Jr., Inc" Appellant.
DUQUESNE LIGHT COMPANY
V.
MICHAEL BAKER, JR" INC., Coco Brothers Construction Company
and Carl G. Baker,
V.
WOODLAND HILLS SCHOOL DISTRICT
Appeal of Carl G. BAKER, Appellant,
Commonwealth Court of Pennsylvania.
Argued June 5, 1997,
Decided Sept. 12, 1997,
After landslide on school district's property caused extensive damage to
school district's property and to electrical substation, litigation amongst
various parties, including engineer, architect, school district, and owner of
electrical substation was consolidated, and some settlements were reached prior
to trial, Following jury verdict in favor of substation owner and school
district and against engineer and architect, engineer and architect filed
petitions to open judgment entered by prothonotary denying all post-trial
motions, The Common Pleas Court, Allegheny County, Nos. GO 92-3455 and GO
91-18296, Johnson, J" denied petitions to open judgment, and 14 appeals
followed, The Commonwealth Court, Nos, 776'785 and 877'880 C.D. 1996, Kelley,
J., held that: (1) in an issue of first impression, rule providing that
prothonotary shall enter judgment if no post,trial motion is made or if court
does not dispose of post,trial motions within 120 days does not eliminate trial
judge's duty to file opinion; (2) issuing binding instruction to jury to find
Copyright (c) West Group 1997 No claim to original U,S, Govt. works
,
Pa, Reporter, 449,700 A,2d 700 A,2d lo3B, Duquesne Light Co, v, Woodland
Hills School Dist" (Pa,Cmwlth, 1997)
allowing Duquesne Light'S experts to testify as to information contained in
Hannigan's reports, We disagree,
[25] [26] pennsylvania courts recognize an exception to the hearsay
exclusionary rule for reports on which experts reasonably rely in reaching their
professional conclusions, Primavera v, Celotex Corporation, 415 Pa, Superior
Ct, 41, 50, 60B A,2d 515, 51B (1992), petition for allowance of appeal denied,
533 Pa, 641, 622 A,2d 1374 (1993), Experts are permitted to express opinions
based upon reports, not in evidence, provided that such reports are of a type
customarily relied upon by experts in the field in making professional
judgments, Id, at 50, 60B A,2d at 51B'19. However, an expert is not
permitted to "repeat another's opinion or data without bringing to bear on it
his own expertise and judgment," Id. at 52, 608 A,2d at 521,
[27] Hannigan's report pertaining to the soil condition is the type of
report upon which experts in the field would reasonably rely in making a
professional judgment. As such, the report may be utilized by experts in
rendering professional opinions, Accordingly, the trial court did not err in
allowing Duquesne Light's experts to rely and testify on this report.
6. SPOLIATION OF EVIDENCE
Michael Baker contends that the trial court erred in refusing to charge the
jury that the School District's disposal of the water line created an adverse
inference because it constituted "spoliation of evidence," We agree,
[28] The appellate role of this court is to determine whether the refusal of
requested jury instructions has caused prejudicial error. Musnuff V. City of
philadelphia, 163 Pa,Cmwlth, 120, 639 A,2d 1322 (1994). An error in refusing
requested jury instructions is harmless if not prejudicial, Id. 639 A.2d at
1323. However, where such a refusal is prejudicial, there is reversible error.
Id,
[29] [30] Under Pennsylvania law, a party cannot benefit from its own
withholding or spoliation of evidence, McHugh V. McHugh, 1B6 Pa, 197, 40 A,
410 (1898). Contrary to the position of the School District, the doctrine of
"spoliation of evidence" is not restricted to product liability cases. Id, At
least since the early 19th century, Pennsylvania courts have admitted evidence
tending to show that an opposing party destroyed evidence relevant to the
dispute being litigated in a variety of cases. Id,; See 2 Wigmore on Evidence
~ 291 (Chadbourn rev, 1979),
[31] The doctrine of spoliation attempts to compensate those whose legal
rights are impaired by the destruction of evidence by creating an adverse
inference against the party responsible for the destruction, The doctrine
permits a jury to infer that the "spoiled" evidence would have been unfavorable
to the position of the spoliator, McHugh, In McHugh, the Supreme Court
stated:
The spoliation of papers and the destruction or withholding of evidence
which a party ought to produce gives rise to a presumption unfavorable to
him, as his conduct may properly be attributed to his supposed knowledge that
the truth would operate against him, This principle has been applied in a
great variety of cases, and is now so well established that it is unnecessary
to do more than state it,
Copyright (c) West Group 1997 No claim to original U,S, Govt, works
Pa, Reporter, 449,700 A,2d 700 A,2d 1038, Duquesne Light Co, v, Woodland
Hills School Dist., (Pa,Cmwlth, 1997)
McHugh, 186 Pa, at 201, 40 A, at 411, So where evidence has been
destroyed, referral of the spoliation issue to a jury with accompanying
instructions is the proper and advisable course of action, McHugh; Wills v,
Hardcastle, 19 Pa, Superior Ct, 525 (1902) (both holding that an aggrieved
party was entitled to presumption in its favor if the jury found spoliation) .
[32J In the instant case, the School District began to investigate the cause
of the February 1990 landslide in April of 1990, R, 1027a. The School District
hired R, Gary Garvin, a geotechnical expert, to investigate and evaluate the
landslide, R, 1010a, In his report of July 16, 1990, Garvin advised the School
District that he could not determine "whether water leaking from the line
precipitated
___'______________________ Page 700 A.2d 1051 follows --------------------------
the landslide, or whether earth movements caused the failure of the water line"
as an evaluation of the water line design and installation was beyond the scope
of his expertise and services R, 1539a, Clearly, this statement as to the cause
of the landslide should have put the School District on notice that the water
line was relevant evidence,
Duquesne Light commenced its action against the school District in October
1991 for negligence in the creation and/or maintenance of the hillside and the
School District filed cross claim against Michael Baker and Carl Baker in
December 1992. with litigation pending, the School District, nevertheless,
disposed of the water line as part of its clean up of the landslide area, R,
1068a-71a, The School District never notified any parties to the suit of the
disposal. As a result, Michael Baker did not have an opportunity to inspect or
test the water line to determine the cause of the rupture.
The trial court's refusal to instruct the jury that it could draw an
inference that the water line would have been unfavorable to the position of the
School District was prejudicial to Michael Baker and thwarted the purpose of the
spoliation doctrine, The water line was material evidence to the defense.
Without access to the water line the defense was prevented from substantiating
its claims that a pipe defect in the water line or some cause unrelated to the
design caused the landslide,
The consequences suffered by Michael Baker as a result of the disposal of the
water line clearly required the trial court, in this instance, to instruct the
jury that an adverse inference may be implied against the School District if the
jury found spoliation, Accordingly, the trial court's refusal to instruct the
jury that it could infer that the "spoiled" evidence would have been unfavorable
to the position of the School District constituted an abuse of discretion and
prejudicial error,
7. NULLUM TEMPUS
Michael Baker argues that the trial court erred in denying his motion for
summary judgment and ruling, as a matter of law, that the statute of limitations
did not bar the School District's claims based on the doctrine of nullum tempus,
We disagree,
[33J Our scope of review of a trial court's order denying summary judgment
is limited to determining whether the trial court committed an error of law or
abused its discretion, DiMino v, Borough of Pottstown, 142 Pa.Cmwlth, 683, 598
Copyright (c) West Group 1997 No claim to original U,S, Govt, works
~TOt< .ET\JIN
SItING
Won L.IHNG____
00Tt. (,<!JPf.
UAll S>>Ol
~TOt. DvSl 'OOT
"STOt< \W
CAU'U
MOONTING
BOlT
sPtAI>1 $HI!lD
MOUI"ffiNG !Ot T
SW<iGEa
TEflON SEAL
MARIP"fC,
STURING ~NUCXlf
SnASH $HI(lD
FIGURE 5
_u
w..a lJHNC______
hS TON a ffiJtH
$lt1NC
COTta CAlJN.
UA.<[ SHOf
hS10N DuSI 1001
"STON SUJ.
CAlm a
MOUmlNG
80LT
!>'\ASH SHIEln
MOUf'mNG ~T
MAilr...c
SUNCfll
TEflON S[Al
STEERING ~NUO:l1
S1tAS>i SHl(LD
FIG URE 5
~
,
~
~
'I
.,
/ ~,
PHOTOGRAPHS
J,
. /'1
/,'
___.....J
)
./. '
/' /
/,i ~/-r
I // .
',,.'; ~ J H r ./;''!-~/'';--; /;:
'';;'_~ ','. '.;r- . -:"'~ Ai::;
~,
-. ,..,
- ,
<=
, : ~;.
/---
" :\.
).\ .
=)
~;~.
I
~cr{'p:!():,;
(:.....,(.~_ i/
Jl'.,l,Y ;i)S';:
[,,11
~
11\11
! . , ,~. .' ,
/. /'
.-., I "-/.-1"
~HUIUliHAr'H~
,
..--'
)
..
;^Kf':~.iJr ~,~~;?~~J!..'I,,~~__~~/ ~I.';>';~/(
.
"
.
.-",. ':' "
_~--:-!.....:=.' .1
I..~.::._.. 'l
. ."1.-: ".-J .' .~" ~' \
, ft'......
-
~~',-.,
~~~
.s:"~:!iI'
;\.
() i: '-) ',' ~ ; I .
I ~..I,,;~
..., ,-
. i' .:
'\
.. 4' '.J..
"-
--
.-.
--------::::
I
=>
e
I.. T-
. " r
, "II'JI', !ftf.'1
'];>{-
i"ll
'/{lJfi