HomeMy WebLinkAbout97-01359
....
~
", ~
}~
~-
.,
"
tI
"..
~
'" ~
J~
~
.',;,
.'1
.
',oj
,
j .
C
. .
:E 0'
fI Ul
>. '0 . W t"l
Cl C 0 I"'!
Ul III ."j . c
'0 U .S >. r-
I"'! C I"'!Ul III Cl I"'!
."j ."j III Cl ~ ~ I"'!Cl I
> ..:l ololU I ~~ ell ii
."j ~ ...t...c III u."j ..,
CJ >. ~~ ::l I ::ll:l<Ill;..,.., l~
Cl t:l ~ III ~"'N
ell ~ o Cl >. ..,1 '<
Ill, U :cenoo , 'I"'! . ell ell
t"l ::l Ct') rn .~ CI"'!Clt"l..,
I"'! olol Cl..c:: III U, OI"'!*,N
1 en I"'!olol >. , ..c:::cUl
r- Ull"'! C , C. .rot .-
ell C ."j III 0 , Clr-I"'!Cr-
Cl I"'!Cl ..c:: I Ult"lk I"'!
I
I"'! k:C olol I ON III ,r-
~ Cl III C I t')I"'!CJH-
I
:c CJ Ill; I
j,
i
I
I
i
I
I
I
i
>- -, :-
q; -
I~'.; C\.
'..
~J~" N .-,....,..
.: :~)
ff!i' - ;:;;.
!-i:: -,.
c.. '.-
gf. ... ;:j
-"J" " -
.'t:/J
L1.J ~; - .;:}i~
_I
O:t': C':::
i=-~ c..
-..; ':.!Q..
lr. .... ::3
0 O'l U
>.: 0' r=
;::: ...:z .~
,_. if; :'J..-,:
L1JQ o~,
<","-'. ~: u~"
.-(, ' ...,!.
ft:;: 0.. ~.)2
6t"; t'J .~. If)
\, ('J -',-,.
U.~L" .--- /.
l'~ -/
U:l.:' W .~.ltU
(:. - ~10-
.... ~.
'0. r- :::>
u U' (,)
~ lO ~
Q , ,
"" ~ gi
~~
f1l2= :t:
Q., :.....
C)-'
~& ,... 7~
- ~:fl
,if FE: .'rr~
!H~
lJ... ~ .
~ ~
~H~l
; .. a ~Ii
11 g I~
-'I
- I- -.--'lo
.
4, At all times material to plaintilrs caU5e of action, defendant Carlisle Hospital
and Health Services (hereinafter called "Carlisle Hospital") was the owner, operator and
possessor, maintainer and in control of a hospital open to the patients for medical care for
pay.
50 At all times material to plaintilrs cause of action, defendant Anthony],
Guarracio, MoD. (hereinafter called "Guarracio"), was the agent, servant, workman and/or
employee of Carlisle Hospital, acting at all times in the course and scope of his
employment with and on behalf of said Carlisle Hospital.
6. All of the acts alleged to have been done or not to have been done by defendant
Guarracio were done or not done by said defendant, his agents, servants, workmen and/or
employees, acting in the course and scope of their employment with and on behalf of said
defendant.
7. All of the acts alleged to have been done or not to have been done by defendant
Carlisle Hospital were done or not done by said defendant, its agents, servants, workmen
and/or employees, acting in the course and scope of their employment with and on behalf
of said defendant.
S, On Thursday, March 23, 1995 plaintiff fell down a set of steps injuring her left
ankle and lego
9. Citizen's Ambulance, Inc. responded to an emergency call for a possible leg
fracture, discovered plaintiff complaining of pain in her left ankle. Plaintiff's ankle and
lower leg was immobilized with a splint, she was placed on a stretcher and transported to
the emergency room of the Carlisle Hospital.
10, Plaintiff was placed in Room No. One and the responding paramedic of
Citizen's Ambulance, Inc. gave Carlisle Hospital's emergency room personnel a report of
the incident which noted possible leg fracture.
11, Plaintiff was seen by Defendant Guarracio sometime after being delivered to
the hospital at which time he touched the toes on her left foot and despite the pain she felt
and despite her assertions that she believed she had suffered a broken ankle and/or leg, the
said defendant did not physically examine her ankle or leg.
120 Despite her assertions that she believed she had suffered a broken ankle or leg,
Defendant Guarracio did not order that x-rays be taken of plaintitrs lower left leg and her
left ankleo
13, Plaintiff was seen by agents, employees, and servants of Carlisle Hospital
including nurses, assistants and/or technicians after being delivered to the hospital and
despite the pain she felt and despite her assertions that she believed she had suffered a
broken ankle and/or leg, no agent, employee or servant of said defendant physically
examined her ankle or leg.
14, Despite her assertions that she believed she had suffered a broken ankle or leg,
no agent, employee and/or technician of Carlisle Hospital including doctors, nurses,
assistants and technicians ordered that x-rays be taken of plaintitrs lower left leg and her
left ankle.
150 Plaintiff was diagnosed by Guarracio and agents of Carlisle Hospital, to have
suffered a sprained ankle,
16, Plaintiff requested that her leg and ankle be x-rayed as she believed that her leg
and/or ankle had been brokeno
17, Guarracio and agents of Carlisle Hospital refused to x-ray plaintiffs lower left
leg and ankle and prescribed treatment as follows: that an ace bandage be wrapped around
plaintitrs left ankle, that she be given crutches and bear no weight on her left ankle, that
she take Advil for pain (2-3 tablets 4 times a day with food), that she place ice on her
ankle for four hours a day, and that ifher ankle still bothered her on the following Monday
(four days later) that she call her family doctor.
18, Plaintiff was discharged from Carlisle Hospital within approximately three
hours of her being delivered to its emergency room without having an x-ray of her lower
left leg or ankle, She informed Carlisle Hospital's agents, employees and servants and
Guarracio that she would have to drive herself home and was instructed that she was
physically capable of doing so.
19, During the remainder of that day and the days to follow, plcintiff experienced
great pain in her lower left leg and ankle and she could barely drive to her home after her
visit to the hospital's emergency room. move from her car to her house or even from the
couch in her living room to the bathroom without great paino
200 On the day of her release from Carlisle Hospital and the care ofGuarracio and
the days to follow. the pain in Plaintiffs lower left leg and ankle became increasingly
unbearable. her foot began to discolor and on Monday when she called her family doctor
to find he was on away. she returned to the Carlisle Hospital and its emergency room.
21. From the time that she was transported to Carlisle Hospital and its emergency
room on Thursday March 23. 1995 at 12:17 p.m. until she returned to Carlisle Hospital
and its emergency room on March 27, 1997 at 4:34 p.m" plaintiff did not re-injure her leg
by placing weight on it. striking it, falling, stumbling, standing, jumping or the like, or in
any manner whatsoever and had followed the directions of Guarracio and Carlisle Hospital
as per the prescribed treatment she should follow.
22. Upon her readmittance to the Carlisle hospital an x-ray was taken and it was
detennined that she was suffering from a comminuted fracture of the left distal tibia.
diaphysis and proximal fibular neck, that said injuries had occurred on Thursday March
23, 1995 as a result of a fall plaintiff had suffered prior to her being delivered to the
Carlisle Hospital on said date and an orthopedic surgeon was contacted.
23, Plaintiffs lower left leg and ankle was thereafter immobilized in a short leg
cast. advised continued elevation and ice and scheduled for intramedullary nailing of the
fracture on the following Wednesday morning. Plaintiff was given a prescription for
percocel.
24. Guarracio. Carlisle Hospital. their agents, servants and employees were
negligent in failing to properly diagnose on March 23. 1995, the multiple fractures
suffered by plaintiff in her fall and for failing to order x-rays for diagnostic purposes.
25. Guarracio was negligent in failing to review the report of the emergency
medical technicians from the ambulance company which noted possible broken leg and
failing to examine plaintiff's lower left leg and ankle and failing to order an x-ray after
repeatedly being told by plaintiff that she believed her leg and/or ankle to be broken.
26, Carlisle Hospital, their agents. servants and employees were negligent in failing
to fonnulate, instruct its personnel as to proper emergency room procedures for the
handling of possible fractures to insure that persons diagnosed by emergency ambulance
crews as having possibly suffered broken bones have x-rays perfonned for diagnostic
purposes.
27, Carlisle Hospital, their agents, servants and employees were negligent in failing
to fonnulate, instruct its personnel as to proper emergency room procedures for the
handling of possible fractures to insure that persons complaining that he or she believed
that he or she had possibly suffered broken bones have x-rays perfonned for diagnostic
purposes.
28, Carlisle Hospital, their agents, servants and employees were negligent in failing
to employ competent and capable doctors, nurses, assistants and other employees.
29, The negligence, carelessness and malpractice of the Defendants also consisted
of the following:
a, Failing to properly diagnosis her multiple fractures.
b, Failing to recognize the complaints of the plaintiff as to her condition,
c. Failing to recognize that Plaintiff was in acute distress,
d. Failing and omitting to take proper precautions and to use proper
remedies to avoid or to minimize the injuries sustained by Plaintiff which resulted in her
damages as set forth hereinafter.
e. Failing and neglecting to order tests sufficient to reveal the cause of
Plaintiff's symptoms and the true nature of her condition.
f. Failing to order the proper medications which plaintill's condition
required.
g. Failing to adequately conduct examinations on Plaintill's lower, left leg,
or in perfonning the examination so carelessly as not to have discovered that Plaintiff was
in serious danger after her fall.
h. The situation that occurred in respect to plaintiff would occur only in
the presence of negligence and would not have occurred in the absence of negligence.
30, In addition to the allegations of negligence set forth above, Defendant Carlisle
Hospital is further responsible to Plaintiff for her injuries and damages as a direct and
proximate result of its negligence, carelessness and malpractice as follows:
a. Failing to enact or promulgate or if enacted or promulgated, failing to
enforce sufficient and adequate rules and regulations regarding to the treatment of patients
in the condition of Plaintiff.
bo Failing to provide adequate supervision of its doctors, nurses, staff and
other agents, servants and employees to ensure that proper hospital practices and
procedures were followed.
c, Failing and neglected to employ and hire doctors, nurses, staff and other
agents, servants and employees with adequate experience, training, qualifications and skills
to promptly and properly treat persons exhibiting symptoms and complaints as were
exhibited by Plaintiff.
d. Pennitting Plaintiff to be treated and cared for, when Defendant knew or
in exercise of reasonable care and diligence should have known, that treatment and care
was being rendered by persons not properly qualified, trained, skilled or experienced to
render such medical care.
e, Extending staff privileges to doctors who are not sufficiently qualified by
experience, training, research and educational background to adequately and properly
diagnose, treat and attend to Plaintiff with the condition then effecting her.
f. Failing to have reasonable, diligent and properly trained personnel on
duty to care for PlaintilT.
g. Failing to properly supervise doctors, nurses, staff and other agents,
servants and employees in the diagnosis and treatment of Plain tilT.
310 As a result of the negligence, carelessness and malpractice of the defendants, as
more fully set fbrth herein, plaintiff sustained serious, painful and pennanent personal
injuries, more particularly hereinafter set forth.
32, As a result of the accident caused by Defendants, negligent act or acts, Plaintiff
has been unable to work in any capacity and has been detennined to be disabled by the
social security administration,
33. As a result of the accident caused by Defendants, negligent act or acts, Plaintiff
has been disfigured and must use a cane to help her walk. She also has a pronounced limp
while walking.
34, As a result of the accident caused by Defendants, negligent act or acts, and the
multiple injuries sustained therefrom, Plaintiff will have to in the future as she has had to in
the past since the accident endure intensifYing pain in her leg and the mental stress
associated with such pain.
35. As a result ofthe accident caused by Defendants, negligent act or acts, and the
multiple injuries sustained therefrom. Plaintiff has been unable to perfonn many of the
minor tasks she had been able to perfonn prior to the accident including, but not limited
to, standing for periods of time, kneeling, dancing, walking and has thus suffered greatly.
36. Plaintiff has incurred medical bills not in excess of twenty-five thousand dollars
($25,000.00).
370 Plaintiff will incur future medical bills in excess of twenty-five thousand dollars
($25,000,00),
38, Plaintiff has suffered lost wages in excess of twenty-five thousand dollars
($25,000.00).
VERIFICATION
I, Helen Stuckey Lindsey, the Plaintiff in this action, verilY that I have read the
foregoing Complaint and to the best of my individual knowledge, infonnation and belief
the statements made therein are true and correct.
I understand that the statement made herein are subject to the provisions and penalties of
18 Pa, C,S, Section 4904 relating to unsworn falsifications to authorities.
Date: ~ - 9- 9/'
,
-?/cry
I
.,
i
>- o. .
Cf: ,..,: r::
is -'-i
1J1!-:; "':
h~r: n::
11.0
C;l~- ,
T t.' ~n {,-\
c:,:
LUl. ,
u.: 12 : c~ " . ,
.' ~..~. r:~LL
l'~.
u. (/' ::3
(') u' U
6. Denied. To the extent that Paragraph 6 contains allegations of agency, those
allegations are denied since after reasonable investigation, Answering Defendants are without
knowledge or information sufficient to form a belief as to the truth or falsity of the averments
contained therein. The remainder of the averments contained in Paragraph 6 are denied
generally in accordance with Pa.R.C,P. 1029(e).
7. Denied. To the extent that Paragraph 7 contains allegations of agency, those
allegations are specifically and unequivocally denied since after reasonable investigation,
Answering Defendants are without knowledge or information sufficient to form a belief as to the
truth or falsity of the averments contained therein. The remainder of the allegations contained
in Paragraph 7 are denied generally in accordance with the Pa.R,C.P. 1029(e).
8-12. Denied. The averments contained in Paragraphs 8 through 12 are denied
generally in accordance with Pa.R.C.P. 1029(e).
13. Denied. To the extent that Paragraph 13 contains allegations of agency, those
allegations are specifically and unequivocally denied since after reasonable investigation.
Answering Defendants are without knowledge or information sufficient to form a belief as to the
truth or falsity of the averments contained therein. The remainder of the allegations contained
in Paragraph 13 are denied generally in accord with Pa.R.C,P. 1029(e),
14. Denied. To the extent that Paragraph 14 contains allegations of agency. those
allegations are specifically and unequivocally denied since after reasonable investigation.
Answering Defendants are without knowledge or information sufficient to form a belief as to the
truth or falsity of the averments contained therein. The remainder of the allegations contained
in Paragraph 14 are denied generally in accord with Pa.R.C.P, 1029(e).
15. Denied. To the extent that Paragraph 15 contains al1egations of agency. those
allegations are specifically and unequivocally denied since after reasonable investigation.
Answering Defendants are without knowledge or information sufficient to form a belief as to the
truth or falsity of the averments contained therein. The remainder of the allegations contained
in Paragraph 15 are denied generally in accord with Pa.R.C.P. 1029(e).
16, Denied. The averments contained in Paragraph 16 are denied generally in
accord with Pa.R.C.P. 1029(e).
17. Denied. To the extent that Paragraph 17 contains allegations of agency. those
allegations are specifically and unequivocally denied since after reasonable investigation.
Answering Defendants are without knowledge or information sufficient to form a belief as to the
truth or falsity of the averments contained therein. The remainder of the allegations contained
in Paragraph 17 are denied general1y in accord with Pa.R.C.P. 1029(e).
18. Denied. To the extent that Paragraph 18 contains allegations of agency. those
al1egations are specifically and unequivocal1y denied since after reasonable investigation.
Answering Defendants are without knowledge or information sufficient to form a belief as to the
truth or falsity of the averments contained therein. The remainder of the allegations contained
in Paragraph 18 are denied general1y in accord with Pa.R,C.P. 1029(e).
19,23. Denied. The averments contained in Paragraph 19 through 23 are denied
general1y in accord with Pa,R.C.P. 1029(e).
24. Denied. To the extent that Paragraph 24 contains allegations of agency. those
allegations are specifically and unequivocally denied since after reasonable investigation.
Answering Defendants are without knowledge or information sufficient to form a belief as to the
truth or falsity of those averments. The remainder of the allegations contained in Paragraph 24
constitute conclusions of law as opposed to statements of fact and no response is required. In
the alternative, to the extent that the remainder of the allegations of Paragraph 24 are deemed
to contain facts to which a response is deemed required, the averments of this paragraph are
denied in accord with Pa.R.C.P. l029(e).
25. Denied. The averments contained in Paragraph 25 of the Plaintiffs Complaint set
forth conclusions of law as opposed to statements of fact and no response is required. In the
alternative, to the extent that the allegations of Paragraph 25 are deemed to contain facts to
which a response is deemed required, the averments of this paragraph are denied in accord with
Pa.R.C.P. l029(e).
26. Denied. To the extent that Paragraph 26 contains allegations of agency. those
allegations are specifically and unequivocally denied since after reasonable investigation,
Answering Defendants are without knowledge or information sufficient to form a belief as to the
truth or falsity of those averments. The remainder of the allegations contained in Paragraph 26
set forth conclusions of law as opposed to statements of fact and no response is required. In the
alternative to the extent that the remainder of the allegations of Paragraph 26 are deemed to
contain facts to which a response is deemed required, the remainder of the averments of this
pamgraph are denied in accord with Pa,R,C.P. l029(e).
27. Denied. To the extent that Pamgraph 27 contains allegations of agency, those
allegations are specifically and unequivocally denied since after reasonable investigation.
Answering Defendants are without knowledge or information sufficient to form a belief as to the
truth or falsity of those averments. The remainder of the allegations contained in Paragraph 27
set forth conclusions of law as opposed to statements of fact and no response is required. In the
alternative to the extent that the remainder of the allegations of Paragraph 27 are deemed to
contain facts to which a response is deemed required, the remainder of the averments of this
paragraph are denied in accord with Pa.R.C.P. 1029(e).
28. Denied. To the extent that Paragraph 28 contains allegations of agency. those
allegations are specifically and unequivocally denied since after reasonable investigation,
Answering Defendants are without knowledge or information sufficient to form a belief as to the
truth or falsity of those averments. The remainder of the allegations contained in Paragraph 28
set forth conclusions of law as opposed to statements of fact and no response is required. In the
alternative to the extent that the remainder of the allegations of Paragraph 28 are deemed to
contain facts to which a response is deemed required, the remainder of the averments of this
paragraph are denied in accord with Pa.R.C.P. 1029(e).
29. Denied. The averments contained in Paragraph 29 ofthe Plaintifrs Complaint set
forth conclusions of law as opposed to statements of fact and no response is required. In the
alternative, to the extent that the allegations of Paragraph 29 are deemed to contain facts to
which a response is deemed required, the averments of this paragraph are denied in accord with
Pa.R.C.P. 1029(e).
30, Denied. To the extent that Paragraph 30 contains allegations of agency. those
allegations are specifically and unequivocally denied since after reasonable investigation,
Answering Defendants are without knowledge or information sufficient to form a belief as to the
truth or falsity of those averments. The remainder of the allegations contained in Paragraph 30
set forth conclusions of law as opposed to statements of fact and no response is required. In the
alternative to the extent that the remainder of the allegations of Paragraph 30 are deemed to
contain facts to which a response is deemed required, the averments of this paragraph are
denied in accord with Pa,R.C.P. 1029(e).
31-35. Denied. The allegations contained in Paragraphs 31 through 35 set forth
conclusions of law as opposed to statements of fact and no response is required. In the
alternative to the extent that the allegations of Paragraphs 31 through 35 are deemed to contain
facts to which a response is deemed required, the averments of these paragraphs are denied in
accord with Pa.R.C.p. 1029(e).
36-43. Denied. The averments contained in Paragraphs 36 through 43 are denied
generally in accord with Pa.R.C.p. 1029(e).
Wherefore, Answering Defendants deny that the Plaintiff is entitled to the relief
claimed or any relief whatsoever and demand that judgment be entered in their favor and
against the Plaintiff and that they awarded appropriate costs and fees.
NEW MA'ITEa
44. Plaintiff has failed to state a claim upon which relief can be granted.
45. To the extent that the Plaintiff has stated a claim for damages arising out of
injuries to her person, those claims are barred by the doctrine of the election of remedies as
Plaintiff has been paid $60,000.00 by Donald R. Barrick, Individually and Trading as Barrick's
Flea Market Barn, Paul E, Weibley, Barbara J. Weibleyand Erie Insurance Group for all damages
and injuries set forth in the Plaintiffs Complaint.
46. Plaintiffs claims are barred by her execution of a Release executed on or about
October 28, 1997, for and in consideration of the receipt of $60,000,00 paid to the Plaintiff by
Donald R. Barrick, Individually and Trading as Barrick's Flea Market Barn, Paul E. Weibley,
Barbara J. Weibley and Erie Insurance Group,
47. Plaintiffs claims are barred by the applicable statute of limitations.
48. It is believed and therefore averred, that discovery will show that the Plaintiff
was negligent and that her negligence exceeded the negligence, if any, of the Answering
Defendants, thereby barring recovery by operation of the Pennsylvania Comparative Negligence
Act.
49. It is believed and therefore averred, that discovery will show that the Plaintiff
voluntarily assumed a known risk thereby barring recovery by the operation of the doctrine of
assumption of the risk.
50. Plaintiffs injuries, if any, were sustained as a result of natural or unknown causes
and not as a result of any action or inaction on behalf of Answering Defendants.
51. At all times material hereto, Answering Defendants acted in accord with the
applicable standard of care.
52. No conduct on the part of the Answering Defendants was a substantial factor in
causing or contributing to any harm which the Plaintiff may have suffered.
53. If the Plaintiff suffered any damage, the damage was caused by the conduct of
others over whom the Answering Defendants had no control or right to control,
54. In so far as Answering Defendants or any agent, seIVant or employee of
Answering Defendants or any person over whom Answering Defendants may be vicariously
liable elected a treatment modality which is recognized as proper but may differ from another
appropriate treatment modality, and Answering Defendants raise the "two schools of thought"
defense.
55. In so far as Answering Defendants or any agent, seIVant or employee of Answering
Defendants or any person for whom Answering Defendants may be vicariously liable was required to
render a diagnosis in this case, Answering Defendants or said agent, servant or employee of the
Answering Defendants took all reasonable and necessal}' steps to make a proper and appropriate
diagnosis and to the extent it may be detennined that that diagnosis was in error, Answering
Defendants assert that the error in diagnosis was a reasonable and legally justifiable error.
56. Answering Defendants and all agents, servants and employees of Answering
Defendants and all persons over whom Answering Defendants may be vicariously liable acted
reasonably, prudently and properly at all times material hereto.
57. If Plaintiff suffered any damages, Plaintiff has been fully and completely compensated
for those damages and any judgment or verdict rendered in this case should be set, off in the amount
of $60,000.00 which the Plaintiff received in exchange for her execution of a Release on or about
October 28,1997.
58. Plaintiff by and through her counsel agreed to the settlement of a disputed claim with
the Answering Defendants and the Plaintiff is in breach of that agreement to settle by proceeding
with this civil action.
Wherefore, Answering Defendants deny that Plaintiff is entitled to the relief claimed or any
relief whatsoever and demand that judgment be entered in their favor and against the Plaintiff and
that they be awarded appropriate costs and fees.
~ Q ~
C\I
..
~2 .:t 8~
!~~ x:
Q." ~
[=5 0'\ ~fi!
FE '''(I)
I ..)z
ti:!P 2: tJi~
::J
1= -, a
t5 (l:)
0'\
3H~1
~ I ~ ~I!:
~ eat>
.~ . . ..
.. .. -
_... ..... ,P-
.;
~
.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
HELEN STUCKEY LINDSEY
Lot 207, Creekview Fanus
Shcrmansdale, PA 17090
Plaintiff
v.
NO.97-1359 CIVIL TERM
CIVIL ACTION - LAW
CARLISLE HOSPITAL AND
HEALTH SERVICES and
ANTHONY J. GUARRACINO, M.D. :
246 Parker Strcct
Carlisle, PA 17013
Defendants: JURY TRIAL DEMANDED
REPLY TO NEW MATTER
AND NOW this qa day of Junc, 1998 comes Plaintiff, by and through her
counsel, Joseph D. Buckley, Esquire and Replys to Defendants' New Mattcr as follows:
44 - 580 Dcnied, The allcgations containcd in Paragraphs 44 - 58 sct forth
conclusions of law as opposcd to statements of fact and no response is requircd. In the
altemativc to the extent that thc allegations of Paragraphs 44 - 58 are decmcd to contain
facts to which a responsc is deemed required, the avenucnts of the paragraphs arc dcnied
in accord with Pa.R.C,P. 1024(c).
WHEREFORE, Plaintiff rcquests this Honorablc Court entcr a judgmcnt in hcr
favor as sct forth in hcr original Complaint.
Respectfully submitted
.'
....- r-. . ,-
(~- ..
i:. ~
I.!! ~.- ''" '. "
, ,
p: .
t~.
t~) ':: , ..
"; ~ j"'" J
C. , ..::;.
1..
...1, , ~ 1 !J
(j:' . , , , , (L
-, ; '.
I , m ::,
() u' U
:- ~. f;
CT: -
;S "';.:
/-, :;l...~
u , , ~,-);;
( ,-
\".;- , --)4:."
(.<- :'~=.:i
C-r); - C'\J ,..-:>=
c, . (I)
L'j I ' .~
, ,.,-::::.-;;
II ~ I ::~~! ,. ,'ifij
" -' 2]C!..
-J
U. '..
C7\ ::J
f... , e'-. (,)
-- - '-
j-'~ L~-;
~'~.~ .. I ,,:-:
II I '.: - ,
.
~_.!; ~
\,- c
C_ " ~-_l
.:~ \
rIll. N ..
:} ~-)..
r;-- I
I I ,':I
0.." :;;~ 1 .-
,. . ....-.:
I m :)
-- U\ U
.
22
HELEN STUCKEY LINDSEY
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V
CARLISLE HOSPITAL AND HEALTH
SERVICES AND ANTHONY J. GUARRACINO,
M.D.
: NO. 97-1359 CIVIL TERM
ORDER OF COURT
AND NOW, August 17, 1999, by agreement of counsel, the above captioned case
is hereby continued from the September 13, 1999 trial tenn, Counsel is directed to relist the case
when ready.
By the Court,
Joseph D. Buckley, Esquire
For the Plaintiff
Kendra D, McGuire, Esquire
For the Defendant
Court Administrator
?i\tC\\qq Cq)(U P1a.'Llcc(
>- co ~
!? c
I-" c;; ;)~
L!s9. ' ,-):-:....
~o :r:: u.....
<1.:
tf-j:L Q.. l~~
i'ir' ,-.,;;-
1 _, (") '~~(..n
OU, ...-,.
I ~......-
UJU. 'riiD
--:-~tl' U
U:T LLl '00..
F c::l ."";
U. m ':3
0 c.n u