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Home My WebLink About00-00534 ~ , '. I ~ . I) 1; . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF CORRECTIONS, STATE CORRECTIONAL INSTITUTION AT CAMP HILL, n c,..: s: '"1J,"-' ~t (/'."!"- ~2~~ d>. ,-) L_('-- >--) c Z .'111 - EquitY< C::> t;::; (-' ~') c..... .:,:~,'" "'".. ''':-'~E ~>),F;) , -:'~ ~~? ~5~~ j;! XJ -< ."') (""" :t:m. Plaintiff #2600-53'-1 No, <:' ',. '-, ';;-' v, --:.n (h JERRY SHIELDS, Defendant NOTICE TO DEFEND 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 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 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 WHERE YOU CAN GET LEGAL HELP. Central Pennsylvania Legal Services 213-A North Front Street Harrisburg, PA 17105 (717) 232-0581 ""-'.' NOIlCA Le han demandado a usted en la corte. Si usted qui ere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plaza al partir de la fecha de la demanda y la notificacion, Usted debe presentar una apariencia escrita 0 en persona 0 par 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 previa aviso 0 notificacion y par cualquier queja 0 alivio que es pedido en Ia petie ion de demanda, Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted, LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEMENTE, SINO IlENE ABOGADO 0 SINO IlENE ELDINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRIT A ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Central Pennsylvania Legal Services 213-A North Front Street Harrisburg, PA 17105 (717) 232-0581 " 1-. ,-""-'- " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF CORRECTIONS, STATE CORRECTIONAL INSTITUTION AT CAMP HILL, Plaintiff v. 02 0V1./ -.53'1 No, Ci'. il Aetion - Equity JERRY SHIELDS, Defendant COMPLAINT AND NOW, this 26th day of January, 2000, comes the Plaintiff, Commonwealth of Pennsylvania, Department of Corrections, State Correctional Institution at Camp Hill and avers the following in support of this Complaint: I. This action is brought in the Court's original jurisdiction. 2. Plaintiff is the Commonwealth of Pennsylvania, Department of Corrections, State Correctional Institution at Camp Hill. 3, Plaintiff is an executive agency of the Commonwealth of Pennsylvania responsible for administrating the state correctional system including the State Correctional Institution at Camp HilL 4. Defendant Jerry Shields is an inmate presently incarcerated at the State Correctional Institution at Camp HilL 5, Since January 19,2000, save for about three meals, Mr. Shields has refused and continues to refuse food. 1 ~ 1-.,,,- 6. Since January 19, 2000, Mr. Shields has missed approximately twenty-two (22) meals, including dinner on January 27, 1999, and breakfast on January 28, 2000. 7. Mr. Shields has a history of refusing food, having done so in December, 1999 at State Correctional Institution at Coal Township, 8. The above-mentioned behavior places this inmate at a great risk for his health; specifically, infections and heart, liver, and kidney problems in the next 24 to 48 hours. 9, Based upon a combination of weight loss symptoms and physical exam, it is the opinion of Dr. Young that Mr. Shields is in imminent danger of the loss of life or other immediate and severe irreparable harm unless examination, diagnostic testing including invasive diagnostic testing and medical treatment including nutrition and hydration are administered immediately, (See Affidavit of Dr. Young attached hereto as Exhibit A and made a part hereof), 10, It is impossible to predict the exact point at which Mr. Shields's condition may result in immediate, severe and in"eparable hann; therefore, immediate intervention is necessary. 11, Permitting Mr. Shields to engage in a suicidal. act by refusing nutrition will cause a significant disruption to the orderly administration ofthe State Correctional Institution at Camp HilL The effects of his death would demoralize the staff and instill the belief in the inmate population that the prison administration caused and permitted Mr. Shields's death. This will lead to animosity toward the staff and undermine confidence in prison authority, 2 j~ ,.- ~ ,L___ < "''--'''': WHEREFORE, based on the foregoing, the Commonwealth of Pennsylvania, Department of Corrections, State Correctional Institution at Camp Hill, request this Court to enter an Order: A. Authorizing the Plaintiff or Plaintiffs designee to involuntarily examine, perfonTI such diagnostic tests including invasive diagnostic tests and administer such medical , treatment including nutrition and hydration, as may be necessary, in Plaintiffs opinion, to preserve the safety, health and life ofMr. Shields, B. Providing such other relief as this Court deems proper. Respectfully submitted, ~~4: -Steven Brian Loux . Assistant Counsel Attorney I.D. No. 76459 P A Department of Corrections 55 Utley Drive Camp Hill, P A 17011 (717) 731-0444 DATE:January 28, 2000 3 -~ - , . ~.- -- . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF CORRECTIONS, STATE CORRECTIONAL INSTITUTION AT CAMP HILL, Plaintiff v, No, Civil Action - Equity JERRY SHIELDS, Defendant PROOF OF SERVICE I hereby certify that a true and correct copy of the Complaint was served on the person and in the manner indicated below: Personal service by hand-delivery Jerry Shields, CU-OOB SCI-Camp Hill 2500 Lisburn Road Camp Hill, PA 17001-8837 Respectfully submitted, teven Brian Loux Assistant Counsel Attorney I.D, No. 76459 P A Department of Corrections 55 Utley Drive Camp Hill, PA 17011 (717) 731-0444 DATE: January 28, 2000 ~ . ,. ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYL VANIA COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF CORRECTIONS, STATE CORRECTIONAL INSTITUTION AT CAMP HILL, Plaintiff v, No. Civil Action - Equity JERRY SHIELDS, Defendant VERIFICATION I, Teresa Law, am the duly appointed Corrections Health Care Administrator of the State Correctional Institution at Camp Hill and am authorized to make this verification, I have reviewed the attached Complaint with respect to the involuntary treatment of Jerry Shields, I hereby verify that the allegations contained in the attached Complaint are true and correct to the best of my knowledge, information and belief. I make this verification subject to the penalties under 18 Pa,C.S. !l4904 relating to unsworn falsification to authorities, r Tere Law Corrections Health Car Administrator State Correctional Institution at Camp Hill DATE:January 28, 2000 _, l. - -'. L...h. ~ . ~ ~ UNSWORN AFFlDA VIT I, Doctor William Young, state the following: 1. I am a medical doctor licensed to practice medicine in the Commonwealth of Pennsylvania. I am a staffphysician at the State Correctional Institution at Camp Hill. I am familiar with Jerry Shields, who is a 30 year old inmate at the State Correctional Institution at Camp Hill. 2. Since January 19, 2000, save for perhaps three (3) meals, Mr. Shields has refused and continues to refuse food, 3. Since January 19,2000, Mr. Shields has missed approximately twenty-two (22) meals. 4, Mr. Shields has a history of fasting, having done so in December, 1999 at the State Correctional Institution at Coal Township. 5. The abovecmentioned behavior places this inmate at a great risk for his health; specifically, infections and heart, liver and kidney problems in the next 24 to 48 hours, 6. Based upon a combination of weight loss symptoms and physical exam, it is my opinion that Mr. Shields is in imminent danger of the loss oflife or other irreparable hann unless diagnostic testing including invasive diagnostic testing, and medical treatment including nutrition and hydration are administered immediately. Mr. Shields may die or suffer other immediate and severe irreparable hann if sllch testing and treatment are not administered to him as soon as possible, I understand that this statement is made subject to the penalties of 18 Pa,C,S. 94904, relating to unsworn falsification to authorities. Date: Lrlr.JJyJ& JCO(l J ~, , i , .1' i; COMMONWEALTH OF PENNSYL VANIA, DEPARTMENT OF CORRECTIONS, STATE CORRECTIONAL INSTITUTION AT CAMP HILL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - EQUITY JERRY SHIELDS, Defendant NO. 2000-534 EQUITY ORDER OF COURT AND NOW, this 28th day of January, 2000, a hearing is scheduled on the continuance of the preliminary injunction for Wednesday, the 2nd day of February, 2000, at 3:00 p.m., in Courtroom No.1, Cumberland County Courthouse, Carlisle, Peunsylvania. BY THE COURT, Steven Brian Loux, Esq. Assistant Counsel P A Department of Corrections ~ I-,;z, Ii, 6V 55 Utley Drive Camp Hill, PA 170ll Attorney for Plaintiff Jerry Shields, CU-0013 SCI-Camp Hill 2500 Lisburn Road Camp Hill, P A l700 l-453l ~<~; J.O./Y> ~ UjI '''1' ,-;;;.-~ ."'''~~lIJi:~~___- IT ~ .~ ~''''''"''''\Il_l'fiillI~'''f"''"rt .. " ,~_.o .. ~~ _~_c. (') c: S: :tIfL ~n; <::tJ (%, s,- j:$ ..:;' ~<"o < C), ~o ~ <: ~ IliiiliioI ~. -- c:, o (~ ..-r: ,iff .-0 ---.-": ''\j OJ ! ;-7,~-;) " ,,"l'--:i C) - 2~~~ _b! .:;;;) -" """ ::e: -. -. .. I:- e.'", m _'lliI- - ..... o ~ ." t, JAN 2 8 zaau I/J 0, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF CORRECTIONS, STATE CORRECTIONAL INSTITUTION AT CAMP HILL, Plaintiff c?OOQ- 531 No, Ci '1 AetiBJiI - Equity v. JERRY SHIELDS, Defendant ~ ORDER AND NOW, thi~ day of ~, 2000, upon Plaintiffs Application for Ex Parte for Preliminary Injunction and based upon the affidavit of the attesting physician, it appears that immediate relief is necessary in order to preserve the life of the Defendant pending the adjudication ofthis matter. Therefore, it is hereby ordered that: 1. Pending the adjudication of this matter Plaintiff or Plaintiffs designee may involuntarily examine and perform diagnostic tests including invasive diagnostic tests on Jerry Shields, and may involuntarily administer medical treatment including nutrition and hydration to Jerry Shields as may, in the opinion of medical staff, be necessary to preserve his health and life. 2. A hearing before this Court on this matter shall be scheduled in accordance with Pa, RC.P, 1531 as will be specified by further order. BY THE COURT , ~~~I!iIrnilU",".."-,*!</ihl~~~.-J;Wl<J"""),,,~,,_;>;~~' -~., . t }f {~ .~~ \~ ! ~':!:lill.'~.- , ~ , _lilid . , , .. .OJ ^' ~ "~~'t"' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYL VANIA, DEPARTMENT OF CORRECTIONS, STATE CORRECTIONAL INSTITUTION AT CAMP HILL, Plaintiff Civil Action - Equity v. No. JERRY SHIELDS, Defendant APPLICATION FOR EX PARTE PRELIMINARY INJUNCTION Pursuant to Pa, Rc'P, 1531, the Commonwealth of Pennsylvania, Department of Corrections, State Correctional Institution at Camp Hill, petitions this Honorable Court to issue an order ex parte granting the concurrently filed Motion for a Preliminary Injnnction pending a hearing because ofthe following: 1. Plaintiff's Complaint and Motion for Preliminary Injnnction in this matter are incorporated by reference as if fully set forth herein. 2. Defendant will suffer irreparable hann, possibly resulting in death, if the relief sought is not immediately granted, 3. Immediate relief, as requested, is necessary to sustain the life and health of the Defendant pending the adjudication of this matter. "l_""'''''''~ ~ ~~ ~ '0 ~ - , ,L -.~_: " . , , WHEREFORE, Plaintiff requests this Court to ex parte order a preliminary injunction permitting Plaintiff or Plaintiff's designee to involuntary examine and perform diagnostic tests including invasive diagnostic tests on Defendant, and to involuntarily provide to Defendant medical treatment including nutrition and hydration as, in Plaintiff's opinion, are necessary to sustain Defendant's life pending the adjudication ofthis matter. Respectfully submitted, k-~~ Steven Brian Loux Assistant Counsel Attorney LD. No. 76459 P A Department of Corrections 55 Utley Drive CampHill,PA 17011 (717)731 -0444 DATE: January 28,2000 ,~~.." - '- ....... ~ -~. '''-~"'~, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYL VANIA, DEPARTMENT OF CORRECTIONS, STATE CORRECTIONAL INSTITUTION AT CAMP HILL, Plaintiff v, No. Civil Action - Equity JERRY SHIELDS, Defendant PROOF OF SERVICE I hereby certii)' that a true and correct copy of the Application for Ex Parte Preliminary Injunction was served on the person and in the manner indicated below: Personal service by hand-delivery Jerry Shields, CU-0013 SCI-Camp Hill 2500 Lisburn Road CampHill,PA 17001-4531 Respectfully submitted, ~~~ Steven Brian Loux Assistant Counsel Attorney I.D, No, 76459 P A Department of Corrections 55 Utley Drive CampHill,PA 17011 (717)731-0444 DATE: January 28,2000 - ,,' '--- ~~ , ~~- . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF CORRECTIONS, STATE CORRECTIONAL INSTITUTION AT CAMP HILL, Plaintiff v. No, Civil Action - Equity JERRY SHIELDS, Defendant MOTION FOR PRELIMINARY INJUNCTION I. Plaintiff's Complaint in this matter is incorporated by reference as if fully set forth herein, 2, Defendant will suffer immediate, severe and irreparable harm possibly resulting in death if ongoing involuntary examination, diagnostic testing including invasive diagnostic testing and medical treatment including nutrition and hydration are not permitted. 3. Based upon the facts set forth in the Complaint and in Plaintiff's concurrently filed Application for ex parte Preliminary Injunction, Plaintiffhas a clear right to perform ongoing involuntary examinations and diagnostic tests including invasive diagnostic tests, and to administer ongoing involuntarily medical treatment including nutrition and hydration. Commonwealth of Pennsylvania, Department of Public Welfare, Farview State Hospital v. Joseph Kallinger, 134 Pa. Cmwlth, 415, 580 A.2d 887 (1990). ilIIiIil j , '-"".<"" ~~ ~~~ . . WHEREFORE, Plaintiff requests this Court to enter a preliminary injunction permitting Plaintiff or Plaintiff's designee to involuntary examine and perform diagnostic tests including invasive diagnostic tests on Defendant, and to involuntarily provide to Defendant medical treatment including nutrition and hydration as, in Plaintiffs opinion, are necessary to preserve the health, safety and life of Defendant. Respectfully submitted, ~1~4 Sieven Brian Loux Assistant Counsel Attorney I.D. No. 76459 PA Department of Corrections 55 Utley Drive Camp Hill, P A 17011 (7 1 7)73 1 -0444 DATE: January 28, 2000 2 "" - , ~"" ~-" .' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF CORRECTIONS, STATE CORRECTIONAL INSTITUTION AT CAMP HILL, Plaintiff Civil Action - Equity v, No. JERRY SHIELDS, Defendant PROOF OF SERVICE I hereby certify that a true and correct copy of the Motion for Preliminary Injunction was served on the person and in the manner indicated below: Personal service by hand-delivery Jerry Shields, CU-0013 SCI-Camp Hill 2500 Lisburn Road Camp Hill, PA 17001-8837 Respectfully submitted, JJ:~~t!:-Jf Assistant Counsel Attomey J.D. No. 76459 P A Department of Corrections 55 Utley Drive Camp Hill, PA 17011 (717) 731-0444 DATE: January 28,2000 ~""-'" ~"'- !Jli!;l;I~lMldiOi,!ioru<~<<lil>i1'lliIoJ1IM~<lili!fI"""-ti"d,;n,~~<~~m;''''''-''';:i~!V&r~_' ,~--"~.."~ ~ ~ Il - II ~ ""~~_---M .--"'.......... o ~ -ocr] rnn', :;z:.:JJ ~?i;~ <;:G i>,-., z>-,', PC Z :2 -C;.l ~- ~:J> ,.- ~'"'~~ IIIiIIIIIIIili 1') CD \':-~I,:D 5\~) :;OJ:, 6('~ Z-rn g 'JO ::< P'" ..."" ~., 9 c.n (J"l COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF CORRECTIONS, STATE CORRECTIONAL INSTITUTION AT CAMP HILL, Plaintiff v. JERRY SHIELDS, Defendant - , -"... '-"".~-,"- > --'-.'''. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - EQUITY NO. 2000-534 EQUITY ORDER OF COURT AND NOW, this 151 day of February, 2000, upon consideration of the attched letter from Steven B. Loux, attorney for Plaintiff, the hearing previously scheduled for February 2, 2000, is cancelled. Steven Brian Loux, Esq. Assistant Counsel P A Department of Corrections 55 Utley Drive Camp Hill, PA 17011 Attorney for Plaintiff Jerry Shields, CU-0013 SCI-Camp Hill 2500 Lisburn Road Camp Hill, PA l700l-4531 Defendant BY THE COURT, \f"I\"l .'!hiif!\ )~NN;i I J~J NI~:rr, ,~l', :,......,',-,< .:,JO . , "J.../ ! /JII:-i i:.LJ";!Mn>"'\ ...., " '>..".;':':;;' ~J IV 'r, ~' r (' J.:t :v :':iJ Z- 8J.j DO J".Li\ji("':\:,'~" ,. ", _ . ~... .........' ".: 'r"J -,- I J -' '0' ::?c':71 .'::':::,.:",,_",:-;,l_L ,jl ';'.I~~l,~"""-~J:-j 1..::1 ,,-- . -'- Office of the Public Defender - ft/..fltl C~cV .:z(~/bO fU.' :rc 0. - ,., --, ",-..,..', ., 02/01/00 14:51 FAX 7310492 CHIEF COUNSEL/UTLEY ,,""--.- -C< " ." ,_ 141002 .... PENNSYLVANIA DEPARTMENT OF CORRECTIONS OFFICE OF CHIEF COUNSEL 55 UTLEY DRIVE CAMP HILL, PENNSYLVANIA 17011 (717) 731-0444 February 1, 2000 BY FACSIMILE AND FIRST CLASS MAIL Honorable J. Wesley Oler, Jr. Court of Common Pleas of Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Dear Judge Oler: Enclosed please find a copy of the Praecipe to Withdraw Motion for Preliminary Injunction that will be sent today by overnight mail to the Prothonotary. As the Defendant is currently voluntarily eating, we no longer need a preliminary injunction. If you have any questions, I can be reached at (717) 731-0444 Sincerely, ~p~ Steven B. Loux Assistant Counsel cc: File -~ . ~~ UIJ' " I ,_ ~,-, '"'- -' \ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYL V AN1A DEPARTMENT OF CORRECTIONS, STATE CORRECTIONAL INSTITUTION AT CAMP HILL, Plaintiff v, No. 2000-534 Equity JERRY SHIELDS, Defendant PRAECIPE TO WITHDRAW MOTION FOR PRELIMINARY INJUNCTION TO THE HONORABLE COURT, COURT ADMINISTRATOR, AND PROTHONOTARY OF SAID COURT: Plaintiff in the above referenced matter hereby withdraws its Motion for Preliminary Injunction filed with this Court on January 28, 2000, Respectfully submitted, ~~4 Assistant Counsel Attorney J.D. No, 76459 P A Department of Corrections 55 Utley Drive Camp Hill, P A 17011 (717) 731-0444 DATE:February 1, 2000 ~1llllilll!i~;Iii__lilll!~Il!Id~!)@li,~t",""'-'i,,-~~gl-id;lL ~ "~ ~"-~ = . -~ ~ ,~ - .~ ".. <~ ~ - ""--", 'l:".-, , .. 0 Q 8 c 0 $:: ..." .~ vC[: r'l rnr"" c:J , -:.'J z:f z L I 1---r1 ~:~' (.~.) :0; C) ,-, -_~~I u '<~ :~ " ~ ..~ ::.J z('} C) ~<....) I.D rn :;r,;",c -::'..J 5 N ~ :0 -< U1 -< "' ~ ~~ ~ . 40,_ , .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF CORRECTIONS, STATE CORRECTIONAL INSTITUTION AT CAMP HILL, Plaintiff v, No. 2000-534 Equity JERRY SHIELDS, Defendant PROOF OF SERVICE I hereby certify that a true and correct copy of Plaintiffs Praecipe to Withdraw Motion for Preliminary Injunction was served on the person and in the manner indicated below: Personal service by hand-delivery Jerry Shields, CU-0013 SCI-Camp Hill 2500 Lisburn Road Camp Hill, P A 17001-4531 Respectfully submitted, ~~~ Steven Brian Loux Assistant Counsel Attorney LD. No. 76459 P A Department of Corrections 55 Utley Drive Camp Hill, PA 17011 (717) 731-044~ DATE: February 1, 2000 j ~~_IIH!lii!i~b4iilBilMi~~I1i%'i:l\Wl!;}'lb,!~~:;Mi\.'!W.lli$"llllijEi'- ~~~ '-","""". '" ~,I- "~ .",i - ~. '"'1ldIII" ~ -~ (") co () C C) -;, s: ..." .-1 -oce1 rr> ;.T; rrlrTI CO Z::i) I ,T! ~~d~ "", C:.! G) !~;:t~) r:;:!""" <.::~"' ~: " -n J.~C~' G (") ~6 \.C ;-n rc ~ "7' ~""0 :::i :JJ -< (...'1 -< =- itilil .,.1 '0,',., I' .' .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY JERRY SHIELDS, Petitioner, v. 00-534 CIVIL TERM COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF: CORRECTIONS Respondent. PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly; .enter' my .appearance. on behalf of the Department 'of Corrections in the above action. The Counsel on record, Steven B. Loux is no longer employed with the Department of Corrections. I also request that the above action be discontinued. ~<&)M.. ~ Randall N. Sears Deputy Chief Counsel Attorney Id. No: 3930l P A Department of Corrections 55 Utley Drive Camp Hill, PA l70ll 717) 731-0444 , -,' Dated: September 5, 2003 ..-- - -- .' .. , jJ JlI$lt!i;l: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY JERRY SHIELDS, Petitioner, v. 00-534 CIVIL TERM COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF: CORRECTIONS Respondent. PROOF OF SERVICE I, the undersigned, hereby certify that a copy of the Praecipe for Entry of Appearance in this matter was served upon the person(s) in the manner indicated below. Dated: September 5, 2003 Service by first-class mail addressed as follows: Jerry Shields, CU-OOB SCI -Pittsburgh P. O. Box 99901 Pittsburgh, PA l5233 ~1~Ai--~,~ Deborah J. Bry Clerk Typist II P A Department of Corrections 55 Utley Drive Camp Hill, PA 17011 (7l7) 731-0444 ....I;;...~ ~""-~~_lWc.,,,,,,,",,"'-~,^ uft! - nll11U1dll;';i~Ii'&!\,~..&Ill~"'" ;',"' '~'- ~ .. .< ~ -~......, . ~!ij'n1~"lilI/jJ/"'iIlt "~ ..... -lit, ,i .. 0 C1 .;:;?, C GO " Z :"n -oGJ ,'''1 men '0 h,:J::' I ;\':""i Zr" '"~,, ~~j:. OJ Cl r;::: c.' -0 ::~ ~Q -"" ~sF~~' 5~ 'i? i.: :z _0 ~ (,) '<