HomeMy WebLinkAbout03-1876IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
THE COMMONWEALTH OF PENNSYLVANIA
CORY A. CORMANY
V.
TINA D. ADAMS
CASE NO. 03-- f F (o
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
You have been sued in Court. If you wish to defend against the claim set
forth in the following pages, you must take action within twenty (20) days after
the Complaint and Notice are served by entering a written appearance personally
or by attorney and by filing in writing with the Court your defense or objection to
the claims set forth against you. You are warned that if you fail to do so the case
may proceed without you and 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 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
1 South Hanover Street
Carlisle, PA. 17013
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
THE COMMONWEALTH OF PENNSYLVANIA
CORY A. CORMANY
V.
TINA D. ADAMS
CASE NO.
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
AND NOW comes, Cory A. Cormany, Plaintiff, and sets forth causes of
action against the above named Defendant, wherefore the following is a statement:
1. Mr. Cory A. Cormany is an adult individual residing in
Cumberland County, Pennsylvania.
2. Ms. Tina D. Adams is an adult individual residing in Cumberland
County, Pennsylvania.
3. Plaintiff, Cory A. Cormany, is a high school graduate, a university
undergraduate, a taxpayer, a registered voter, a citizen, a confirmed methodist,
and a veteran of the United States of America.
4. Defendant is Tina D. Adams, a company supervisor employed by
McDonalds Co. of Carlisle, Pennsylvania; (McCopCo. Franchises).
5. The plaintiff is an equal opportunity applicant interested in
McDonalds Co. of Carlisle, Pennsylvania; (McCopCo. Franchises).
(1)
6. In or about the month of September of the year 1997, the plaintiff
did pursue an employment application at the McDonalds Co. of Carlisle, the High
Street location, authentic a documentation.
7. Pursuant the objects described in the aforementioned statements, the
plaintiff, Cory A. Cormany, did follow-up and pursue employment opportunity at
the McDonalds Co. of Carlisle, the Walnut Bottom Road location, throughout the
years 1998 and 1999; (The Golden M Corp.).
8. To or about the month of April of the year 2001, the plaintiff did
retain and service an employment application at the Ames Dept. Stores of Carlisle,
the Old M.J. Mall location, foregoing a timely full-time employment.
9. Preceding the issues described in the aforementioned statements, the
plaintiff, Cory A. Cormany, did achieve and retain employment opportunity at the
McDonalds Co. of Carlisle, non faulted an expiry period, obligatory a minor
child; (Alexandria Christine).
10. In or about the month of September of the year 2002, the plaintiff
did sustain an employment application at the McDonalds Co. of Carlisle,
argumentative several entailed locations, liberal a documentation.
11. Preceding the events described in the aforementioned statements, the
Plaintiff, Mr. Cory A. Cormany, did remand and follow-up employment
opportunity at the McDonalds Co. of Carlisle, the Walnut Bottom Road location,
supplemental all available locations; (The Golden M Corp.).
(2)
12. Pursuant the foregoing business the defendant, Tina D. Adams, did
divorce the plaintiff, Cory A. Cormany, allegorical an alcohol/driving issue;
nonreliable a vehicle and a decree, and did marry a convicted narcotics offender,
substantial an equal opportunity employer.
13. On or about October 4th of the year 2002, circumstantial an
employee (Thomas Minic), the defendant, Tina D. Adams, did directly
circumvent a decision; and, did deny the plaintiff, Cory A. Cormany, employment
opportunity pertinent The Golden M Corporation.
14. On or about November 4th of the year 2002, rhetorical a public
official (Fredric Colbertson), the defendant, Tina D. Adams, did once again deny
the plaintiff employment opportunity circumstantial the Health and Safety, Equal
Employment, and Human Relations Commissions of the Commonwealth of
Pennsylvania.
15. The Defendant, Ms. Tina Adams, did prejudicially discriminate with
neglect and malice, subordinately causing mental anguish, public humiliation,
emotional duress, and deprivation of equal right reliable the Plaintiff,
Mr. Cory Cormany.
16. The Defendant, Ms. Tina Adams, did deliberately cause Mr. Cory
Cormany lost wages and employment, benefits and expenses in the foregoing
amount, excessive a potential amount of Ten Thousand and 00 Dollars
(10,000.00), respectfully submitted exhibits A through F.
(3)
17. By reason of the aforementioned; Mr. Cory Cormany has suffered
discrimination, mental anguish, public humiliation, emotional duress,
constitutional deprivation, loss of wages and employment, benefits, and expenses
as a result of the defendant, Tina D. Adams.
WHEREAS, plaintiff, Cory A. Cormany, claims from the defendant, Tina
D. Adams, punitive and compensatory relief in an amount in excess of Ten
Thousand and 00 Dollars (10,000.00), plus costs of any proceeding.
(4)
I, Cory A. Cormany, Plaintiff in the above captioned action, hereby verify
and state that the facts set forth in the Complaint against Ms. Tina Adams are true
and correct to the best of my information, knowledge and belief. I understand that
false statements herein are made subject to the penalties of Pa. C.S.A. Section
4904, relating to unsworn verification to authorities.
Dated ) 3
Q By
Witn?r- '
Cory A. Cormany t
By -? _
Notary
IWIff"LIM
!lOM P. CUrriM NO MY PUNX
CWWN Mom^ cmmb~ Comity
Ib C=="= NVkM UftVh R 9004
(5)
AND NOW, this day of 2003, I, Cory A. Cormany
foregoing the aforesaid matter knowledgeable a legal pretext, and the
Commonwealth of Pennsylvania, hereby certify that I have served a copy of same
in person or by the United States Mail at Carlisle Pennsylvania, addressed as
follows:
Ms. Tina D. Adams
McDonalds Company
905 Walnut Bottom Rd.
Carlisle, PA 17013
Esquire Noted:
Cory A. Cormany
1883 Douglas Dr.
Carlisle, PA 17013
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(93
EMPLOYMENT TRAINING AND
EXPERIENCE SUMMARY
1. MCDONALDS OPENING PROCEDURES
A) Front Line C) Stocking/Truck
B) Grill Section D) Maintenance
2. MCDONALDS CLOSING PROCEDURES
A) Front Line C) Backroom/Parts
B) Grill Section D) Maintenance
3. MCDONALDS DAILY OPERATIONS
A) Front Line C)
B) Grill Secti Lobby/Drive Through
on
D)
Maintenance
4. MCDONALDS EQUIPMENT KNOWLEDGE
A) Front Line C) Fryers/Walk-ins
B) Grill Section D) Maintenance
5. MCDONALDS MANAGERIAL POLICIES
A) Front Line C) Opening/Closing
B) Grill Section D) Maintenance
6. MCDONALDS ADVERTISING POLICI ES
A) Front Line C)
B) G
ill Promo Sales/Menu
r
Section D) Maintenance
7. MCDONALDS RESOURCE POLICIES
A) Front Line C) References/McCopco
B) Grill Section D) Maintenance
8. SPECIAL DETAILS
A) As Assigned
(1)
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BALTIMORE CITY HEALTH DEPARTMENT
NOTIFICATION OF ?RTH REGISTRATION
7I2is certifies tha ere is on file in
the Bureau o f 1 Records of the
Baltimore fit th De artniet
a record of t= - O f ?g
NABS of cRILDCory A Isy
DAT! OF BtRTII Aug.? xx Mahe ru! K._ 66_17289
COMMMUONe1t OF KsALTH
AND AE018'rRAR OF v'rwL RacoRns
PLEASE BEE OTHER
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too"" Mrth Do xp,
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Clue End&
'Z 1 DOIJOLAS on
E M rota
.a 0 CORY AUSTER CORMANY
OF INOCULATIONS
L SECG?
TWO
til4 ?lYA 1.lD FO11
CORY
M01 CgFMAN
,cti
SETTLEMENT AGREEMENT
THIS AGREEMENT, made this day of 1989, by and
between CORY A. CORMANY, hereinafter called Husband, and TINA D. CORMANY
hereinafter called Wife;
WI T.NES SETH:
WHEREAS, Husband and Wife were lawfully married on 1?r,cember 1. 1^-l?
in Cumberland County, Pennsylvania; and
WHEREAS, differences have arisen between Husband and Wife in
consequence of which they have lived separate and apart from each other since
March 27, 1989 and have consented to a mutual consent divorce; and
WHEREAS. Husband and Wife desire to settle and determine their rights
and obligations.
NOW, THEREFORE, the parties, intending to he legally bound hereby,
agree as follows:
I. 5=aration. It shall be lawful for each party at all times hereafter to
live separate and apart from the other at such place as he or she may from time to time
choose or deem fit. The foregoing provision shall not be taken as admission on the part
of either party of the lawfulness or unlawfulness of the causes leading to them living
apart.
2. Division of Prop-•ty, The parties have divided between them to their
mutual satisfaction the household furniture, supplies and furnishings, and oilier articles
of household property which have heretofore been used by them in common, and neither
will make any claim to any such items which are now in possession or control of the
other, except as otherwise set forth herein.
The parties shall retain the respective automobiles in their possession and
assume any obligations associated therewith.
1
3. Debts. Except for the debts and obligations created hereunder, each
party agrees to pay and hereby agrees to hold the other harmless from any and all
personal debts and obligations incurred by hint or her subsequent to the date of
separation, which occurred in March 1989. If any claim, action or proceeding is herea;ter
brought seeking to hold the other party liable on account of such debts or obligations,
each party will at his or her sole expense defend the other party against any such elnrr•?,
action or proceedings, whether or not well-founded, and indemnify the other party
against any loss or liability resulting therefrom.
4. Eguitable Property. This Agreement constitutes a division of the parties'
marital property. The parties have determined that the division of this property conforms
with regard to the rights of each party. The division of existing marital property is not
intended by the parties to constitute in any way a sale or exchange of assets, and the
division is being effectuated without the introduction of outside funds or other property
not constituting the matrimonial estate.
Each party hereby acknowledges that this agreement adequately provides
for his or her needs and is in his or her best interest, and that the Agreement is not the
result of any fraud or undue influence exercised by either party upon the other or by any
other person or persons upon either party. Both parties hereby waive the following
procedural rights:
A. The right to obtain an inventory and appraisement of all marital and
separate property as defined by the Pennsylvania Divorce Code.
B. The right to obtain an income and expense statement of the other
party as provided by the Pennsylvania Divorce Code.
C. The right to have the court determine which property is marital and
which is non-marital, and equitably distribute between the parties that property which the
court determines to be marital.
2
C(6,3)
D. The right to have the court decide any other rights, remedies,
privileges, or obligations covered by this Agreement, including but not limited to possible
claims for divorce, spousal support, alimony, alimony pendente lite (temporary alimony),
and counsel fees, costs and expenses.
5. Custody and Support of Ale aildri Husband shall pay to Wife for the
support and maintenance of their minor child, Alexandria, born Decemb?r 16, 1988. ??Ie
amount established by agreement of the parties or as established by a court of compete,it
jurisdiction, said payments due hereunder to continue until said child reaches the age of
eighteen (18) or graduates from high school, whichever shall occur last, dies, marries or
otherwise becomes emancipated and so long as said child lives and resides with Wife.
Husband agrees that so long as he has an obligation to support Alexandria
that he will provide life insurance coverage in a sufficient amount, naming Alexandria as
a beneficiary thereon, to insure the payment due hereunder.
The Wife shall have primary physical custody of Alexandria. The Husband
shall have the right of visitation in Wife's home on Saturdays between the hours of 5:00
P.M. to 7: 00 p.m. and Sundays from l: 00 p.m. to 5:00 p.m. This arrangement shall continue
until such time as the Wife is satisfied that Husband's alcohol related problems are
controlled. So as not to endanger Alexandria and that he is capable of caring for her due
to her young age. When Husband has achieved the foregoing than the parties agree to
rrnegn•iate an expansion of the -father/ daughter contacts to include times of partial
physical custody.
6. Release of All Claims. Each party, except as otherwise provided for in
this Agreement, releases the other from all claims, liabilities, debts, obligations, actions
and causes of action of every kind that have been incurred, or may be incurred, relating
3
0
to or arising from the marriage between the parties. However, neither party is relieved or
discharged from any obligations under ibis Agreement or under any instrument or
document executed pursuant to this Agreement.
7. Breach. If either party breaches any provision of this Agreement, the
other party shall have the right, at his or her election, to sue for damages for such breach,
and seek, any other remedy allowed it law o- equity. T?:v. par%.; -?relching this ?0^1
shall be responsible for the payment o,' reasonable legal fees and costs incurred by tile.
other in enforcing his or her rights under this Agreement, or seeking such other remed,v
or relief as may be available to him or her, Waiver by one party of any breach of this
Agreement by the other party shall not be deemed a waiver of any subsequent, similar
breach or other breaches.
8. Full Disclosure. Husband and Wife each represent and warrant to the
other that he or she Us made a full and complete disclosure to the oth^r of all assets I)f
any nature whatsoever in which such party has an interest, of the source and amount of
the income of such party of every type whatsoever and all other facts relating to the
subject matter of this Agreement.
9. Divorce. This Agreement shall not be construed to affect or bar the right
of either Husband or Wife to a true and absolute divorce on legal and truthful grounds as
they ;.ow exis,` or may hereafter arise. It is understood, however, that Wife, as of the
sign;ng of Mi Agreement, his filed c-; act;on it divorce it th;r Cot<rt of Common Pleas
of Cumberland County in which she alleges that the marriage is irretrievably broken.
Both parties understand and agree that Wife shall pursue said divorce on the grounds that
the marriage is irretrievably broken, and that both parties will execute, deliver and file
the necessary affidavits and all other petitions or documents necessary to effectuate the
divorce pursuant to Section 201(c) of the Divorce Code. Husband agrees that the marriage
is irretrievably broken.
4
s
. _ . _- . lU. ?eDlefPr?fntion of Par i 1 bs r`ou W. Each party has had the opportunity
to have legal counsel to represent each of them in-the negotiation and preparation of this
Agreement qnd has either been so represented or has voluntarily chosen not to be
represented. Each party, has carefully read this Agreement and is completely aware, not
or!;y of its contents, but also of its legal effect.
-Add o a?_r l ' r t ?Pqj. Each of the parties shall on demand o.? withb?
reasonable period- thereafter, execute and deliver any and all other documents and do or
cause to- be done any other act or thing that may be necessary or desirable to effectuate
the provisions and purposes of this Agreement. If either party fails on demand to comply
with. the provision, that party shall pay to the other all attorneys' fees, costs and other
expenses reasonably incurred as a result of such failure.
12• Modification and Waiver. Modification or waiver of any provision of this
Agreement shall be effective only if made in writing and executed with the same
formality as this Agreement. i he failure of either party to insist upon strict performance
of any of the provisions of this Agreement shall not be construed as a waiver of any
subsequent default of the same or similar nature.
13. Descriptive Headings. The descriptive headings used herein are for
convenience only. They shall have no effect whatsoever in determining the rights or
obligations of th,r parties.
14. Successors and Assigns, This Agreement, except as otherwise expressly
provided herein, shall be binding upon and shall inure to the benefit of the respective
legatees, devisees, heirs, executors, administrators, assignees and successors in interest to
the parties.
15. Governing Law. This Agreement shall be governed by and shall be
construed in accordance with the laws of the Commonwealth of Pennsylvania.
5
0?
of art With the approval of arty court of compstent jurisdiction
ivoi':.: .r.ed*y,& >-wiy i'^ b-F Pe-ndi...Q u. ?' hl 'it ntr'V hrrr?t?'°a u'e
r
i,:s •s z tti: Agreet:amnt m-,Y be incorpo,?ated in any decree of •T1,solt<;r, divo;;.e Yhi,h
rno tE t:, sa ` Gy said court. it the eveni the court shall fa-7 or decline io inro: porut,
th, ovisions thereof in said de?reo, Then awl it that eve;Yt the parries.
fi' Y.• i' r. 6itlQtP,,:? /srJ:r i,' ?!? lfla car.,v 0., al: Of tlTe opgvisic.ns ehe.,cof.
It iT {: riser ^?-?;?' that r.,gardf?ss of ivhe:f rr said agree neat c,' any part
th,-r a:." is inro pctated in any such decree, the same shall not be merged in said decree,
but snici iv-esmen: and all the terms thereof shall continue, to be binding upon the parties
an. e"li2i:i!*+'. is • • S; person. a representaiives and assigns.
intending to be legally bound hereby, the parties
i.gei.- hrnds and seals the day and year first above written
W1,0-! S7
r?,_.-...._... _,.__.,.___._.._._.?._.,_..,. (SEAL)
Tina D. Cormany
X _ _ „? (SEAL)
Cory A. Cormany
6
iRTM 12-16-88 ?FILaE 1542150-88
FLED 12-21-88
CM DATE
a? CUMBEgLAND 0 02-09-89
tteo. OAT. 114111
SUBJECT FEMALE
ALEXANDRIA CHIISTINIE CORMANY
FATHERS 4AME AGE 22
Z-GRY AL I STER ;; IRMAVY
MOT;IERS MAIDEN NAME AGE 23
T14A U'IREEN LI ,HTNER ?Pft noinie?oeru =o 11 wNn Aet K alme Y . loom w?e aeeniti ibt»eipj. tt? if' , O•oNt?wt w M.awn.
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ALEXANDRIA CHRISTINE C-2RMANY
141 14 PdAFRET ST
CARLISLE PA
17013
?r
97L' 3-
TINA D CORMANY
VS
CORY A CORMANY
: IN THE COURT OF COMMON PLEAS
: CHESTER COUNTY, PENNSYLVANIA
: DOMESTIC RELATIONS
: NO. 0359N1991
SOC. SEC. 195-60-0447
CONF- 04/03/91 01:30 PM MIC
ID# 0090768
ORDER FOR EARNINGS REPORT AND SUBPOENA
TO:
MC DONALDS
905 WALNUT BOTTOM ROAD
CARLISLE pA 17013
02/15/91
RE: TINA D COR14ANY
BASED ON INFORMATION FURNISHED TO THE COURT THAT THE ABOVE MENTIONED
PERSON IS CURRENTLY EMPLOYED BY YOU, AND BECAUSE IT IS NECESSARY THAT
THE COURT BE ADVISED OF THE EMPLOYEE'S EARNINGS
ITEMIZATION OF HIS/HER OTHER BENEFITS TOGETHER WITH AN LIMITED TO
AUTOMOBILE ALLOWANCE, EXPENSE ACCOUNT,I RETIREMENTNBENEFITS, HEALTH AND
LIFE INSURANCE COVERAGES, IN ORDER TO ADJUDICATE A MATTER OF SUPPORT;
IT IS HEREBY ORDERED AND DECREED THAT YOU SUPPLY THE COURT WITH
THE INFORMATION REQUIRED BY THE ENCLOSED EARNINGS REPORT AND FILE IT
WITH THE COURT ON OR BEFORE
19 .
IF YOU FAIL TO SUPPLY THE INFORMATION REQUIRED BY THIS ORDER, A
SUBPOENA WILL BE ISSUED REQUIRING YOU TO ATTEND COURT AND BRING THE
MATERIAL WITH YOU.
BY THE COURT :
J.
DRS. 107
BROUJOS, GILROY 8 HOUSTON, P. C.
ATTORNEYS AT LAU,
JOHN H. BROL'10S
F4UBER 7' X. GILROY 4 NORTH HANOVER STREET
CHRISTOPHER C. HOUSTON CARLISLE, PENNSYLVANIA 17013
CERTIFIED, RESTRICTED MAIL
RETURN RECEIPT REQUESTED
March 28, 1994
Mr. Cory Alister Cormany
1883 Douglas Drive
Carlisle, PA 17013
Dear Mr. Cormany:
0
717-243-4574
NON-TOLL FOR HARRISBURG AREA:
717-766-1690
FAX;243-8227
Our office represents John D. Adams, Jr. who has filed a petition
to adopt your daughter, Alexandria Christine Corman
for service upon you is a copy of the petition for adoptionoal ng
with a copy of a March 23, 1994 Order issued by Judge Oler
whereby a hearing is scheduled for Monday, May 16, 1994 at 1:30
p.m. The hearing in question is to terminate your parental
rights of the minor child.
The necessity for a hearing can be eliminated if you would be
willing to sign a consent to the adoption. I have enclosed three
copies of a proposed consent which we request that you sign and
return to me in the enclosed envelope. This consent must be
signed by you personally and you must affix the date and place of
its execution. It must also be signed by at least two witnesses
you must also affix their addresses and signatures and their
relationship to you.
I will be happy to discuss this matter with you or your attorney
if you have any questions.
Sincerely yours,
Hubert X. Gilroy
sm
cc: Mr. & Mrs. John D. Adams, Jr.
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CORY A. CORMANY, CASE NO. 03-1876
Plaintiff
V. . CIVIL ACTION - LAW
TINA D. ADAMS, .
Defendant JURY TRIAL DEMANDED
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance for Tina D. Adams, Defendant, for the sole purpose of filing
Objections to jurisdiction and service of process upon Defendant.
DATE: , 2003
Respectfully submitted,
STOCK AND LEADER
T?iothy P. uth, Es 're/
Supreme Co 6024
Susquehanna Commerce Center East
221 West Philadelphia Street, Suite 600
York, PA 17404
(717) 846-9800
I:\USERS\KB\TPR\KENMAR\ENTRYAPP.PRA
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CORY A. CORMANY CASE NO. 03-1876
Plaintiff
V. CIVIL ACTION - LAW
TINA D. ADAMS JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
I, Timothy P. Ruth, Esquire, an attorney of the law firm of Stock and Leader,
Susquehanna Commerce Center East, 221 West Philadelphia Street, Suite 600, York,
Pennsylvania 17404, hereby certify that I have, on the date below written, served a true and
correct copy of the Praecipe for Entry of Appearance filed May 28, 2003, by first-class United
States mail, postage prepaid, addressed to the party of record as follows:
Cory A. Cormany
1883 Douglas Drive
Carlisle, PA 17013
Date: June 3, 2003
a,
Jt?(L)thy P. Ru , E e
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CORY A. CORMANY,
Plaintiff
V.
TINA D. ADAMS,
Defendant
CASE NO. 03-1876
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
MOTION FOR ADMISSION PRO HAC VICE
AND NOW COMES Timothy P. Ruth, Esquire, of the law firm of Stock and Leader,
and a member of the Pennsylvania Bar, pursuant to the Rules of Court, to move for the
admission pro hac vice of Yvette A. Heintzelman, Esquire and Alissa L. Gilfand, Esquire, to
represent Defendant Tina D. Adams in the above-captioned action.
Movant certifies that he finds the applicants to be reputable and competent attorneys,
and Movant is in a position to recommend the applicants' admission. The applications of
Yvette A. Heintzelman, Esquire and Alissa L. Gilfand, Esquire in support of this Motion are
attached hereto as Exhibits "A" and "B", respectively, and are incorporated herein by
reference.
Dated: June A-, 2003
Respectfully submitted,
STOCK AND LE.
Y ADE
C1-
othy P. R i
I.D. No. 26024
STOCK AND LEADER
Susquehanna Commerce Center East, Suite 600
221 West Philadelphia Street
York, PA 17404
(717) 846-9800
I:\USERS\KB\TPR\KENMAR\Pro Hac Vice Motion for Admission.doc
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CORY A. CORMANY, CASE NO. 03-1876
Plaintiff
TINA D. ADAMS,
v. CIVIL ACTION - LAW
Defendant JURY TRIAL DEMANDED
BY
AND NOW comes Yvette A. Heintzelman, Esquire and files her Application to appear as
counsel pro hac vice in the above-captioned litigation, and in support of her Application avers as
follows:
1. I hereby request permission, pursuant to the Pennsylvania Rules of Court and
Pennsylvania Bar Admission Rule 301(b), to appear as counsel pro hac vice for Defendant Tina
D. Adams, in the above-captioned action, which is pending before this Court.
2. My office address is: Seyfarth Shaw, 55 East Monroe Street, Suite 4200,
Chicago, IL 60603-5803.
3. I have been admitted to the Bars of the following Courts: United States Court of
Appeals for the Seventh Circuit, United States Court of Appeals for the Eighth Circuit, United
States Court of Appeals for the Ninth Circuit, United States District Court for the Eastern District
of Wisconsin, United States District Court for the Central District of Illinois, United States
District Court for the Northern District of Illinois, United States District Court for the Southern
District of Illinois, United States District Court for the Northern District of California, United
States Court of Appeals for the Eastern District of California, United States Court of Appeals for
1
CHI 10528500.2
the Southern District of California, the California Supreme Court I and the Illinois Supreme
Court.
4. I am a member in good standing of the Bars of all of the Courts listed in
Paragraph 3, above.
5. I am not currently suspended or disbarred in any Court.
6. The current attorney of record for Defendant is Timothy P. Ruth, Esquire, of the
York, Pennsylvania law firm of Stock and Leader, and he is an active member of the State Bar of
Pennsylvania. His address is Susquehanna Commerce Center East, 221 West Philadelphia
Street, Suite 600, York, Pennsylvania 17404, and his telephone number is (717) 846-9800.
7. I have reviewed the Pennsylvania Lawyer's Rules of Professional Conduct and
hereby agree that I shall be bound by them.
8. I and all attorneys associated with my firm who directly or indirectly provide
services to the party of cause at issue shall be bound by all the Rules of this Court.
9. I consent to the appointment of the Prothonotary of the Court of Common Pleas,
and the law firm of Stock and Leader, as agents upon whom service of process may be made for
all actions, including disciplinary actions, that may arise out of the practice of law under
Pennsylvania Bar Admission s Rules 301(b) and any activities related thereto.
10. I do not maintain an office in the Commonwealth of Pennsylvania.
WHEREFORE, Yvette A. Heintzelman, Esquire respectfully requests that this Honorable
Court grant this Application to appear as counsel pro hac vice in the above-captioned pending
litigation
Respectfully submitted,
Date: (0/6 103 .P.I A7??l?yvvG?
Evette Heintzelman, Esquire
::ODM ATC DOCS\CH 1 \10528500,2
I am currently on inactive status in the State of California.
CHI 10528500.2
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CORY A. CORMANY,
Plaintiff
V.
TINA D. ADAMS,
Defendant
CASE NO. 03-1876
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
AND NOW comes Alissa L. Gilfand, Esquire and files her Application to appear as
counsel pro hac vice in the above-captioned litigation, and in support of her Application avers as
follows:
1. I hereby request permission, pursuant to the Pennsylvania Rules of Court and
Pennsylvania Bar Admission Rule 301(b), to appear as counsel pro hac vice for Defendant Tina
D. Adams, in the above-captioned action, which is pending before this Court.
2. My office address is: Seyfarth Shaw, 55 East Monroe Street, Suite 4200,
Chicago, IL 60603-5803.
3. I have been admitted to the Bars of the following Courts: Supreme Court of
Illinois, United States District Court for the Northern District of Illinois, United States Court of
Appeals for the Seventh Circuit, and United States District Court for the Eastern District of
Michigan.
4. I am a member in good standing of the Bars of all of the Courts listed in
Paragraph 3, above.
5. I am not currently suspended or disbarred in any Court.
6. The current attorney of record for Defendant is Timothy P. Ruth, Esquire, of the
York, Pennsylvania law firm of Stock and Leader, and he is an active member of the State Bar of
2. CHI 10528496.1
Pennsylvania. His address is Susquehanna Commerce Center East, 221 West Philadelphia
Street, Suite 600, York, Pennsylvania 17404, and his telephone number is (717) 846-9800.
7. I have reviewed the Pennsylvania Lawyer's Rules of Professional Conduct and
hereby agree that I shall be bound by them.
8. I and all attorneys associated with my firm who directly or indirectly provide
services to the party of cause at issue shall be bound by all the Rules of this Court.
9. I consent to the appointment of the Prothonotary of the Court of Common Pleas,
and the law firm of Stock and Leader, as agents upon whom service of process may be made for
all actions, including disciplinary actions, that may arise out of the practice of law under
Pennsylvania Bar Admission s Rules 301(b) and any activities related thereto.
10. I do not maintain an office in the Commonwealth of Pennsylvania.
WHEREFORE, Alissa L. Gilfand, Esquire respectfully requests that this Honorable
Court grant this Application to appear as counsel pro hac vice in the above-captioned pending
litigation.
Respectfully submitted,
Date: ::ODMATCDOCS\CH I\10528496\1
2
CHI 10528496.1
?_? l
c. 1
'??,.,..
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, 1
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-< (J ?
JUN 1 3 2003 V
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CORY A. CORMANY, CASE NO. 03-1876
Plaintiff
V.
TINA D. ADAMS,
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
ORDER
AND NOW, this /(;'-day of ?, 2003, upon review and consideration
of the Applications To Appear As Counsel Pro Hac Vice In Pending Litigation filed by Yvette
A. Heintzelman, Esquire, and Alissa L. Gilfand, Esquire, and in consideration of the Motion
for Admission Pro Hac Vice filed by Timothy P. Ruth, Esquire, of the law firm of Stock and
Leader, in support of the Applications, it is hereby:
ORDERED that the Motion for Admission Pro Hac Vice filed with respect to the
Applications of Yvette A. Heintzelman Esquire, and Alissa L. Gilfand, Esquire, for an Order
granting them permission to appear as counsel pro hac vice pursuant to the Pennsylvania Rules
of Court is HEREBY GRANTED.
BY
JUDGE
I:\USERS\KB\TPR\KENMAR\Pro Hac Vice Order.doc
.? uNVn?,rsn.ra=0
-U :5
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
THE COMMONWEALTH OF PENNSYLVANIA
CORY A. CORMANY
PLAINTIFF,
V. )
TINA D. ADAMS
Defendant.
Case No. 03-1876
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance on behalf of the Plaintiffs, Tina D. Adams, in the above
matter.
STOCK AND LEADER
\h cy By--t ? ' nF
Dated Chnsrian F. Rhodes, Esquire
Attorney for Defendant
I.D. #89667
Susquehanna Commerce Center
East Building, 6th Floor
221 West Philadelphia Street
York, PA 17404
FXSERS\KBUPR\KENMAR\Praecipe Entry of Appearance.doc
M
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
THE COMMONWEALTH OF PENNSYLVANIA
CORY A. CORMANY
PLAINTIFF, )
V. )
TINA D. ADAMS
Defendant. )
Case No. 03-1876
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
I, Christian F. Rhodes, Esquire, an attorney of the law firm of Stock and Leader,
Susquehanna Commerce Center East, 221 West Philadelphia Street, Suite 600, York,
Pennsylvania 17404, hereby certify that I served the within Praecipe for Entry of Appearance
this day by first-class United States mail, postage prepaid, addressed to the party of record as
follows:
Cory A. Cormany
1883 Douglas Drive
Carlisle, PA 17013
Date: 3 ?°? oh
STOCK AND LEADER
By 4
Christian F. Rhodes., Esquire
Attorney for Defendant
Sup. Ct. I.D. #89667
221 West Philadelphia Street
Suite E600
York, PA 17404
Telephone: (717) 846-9800
FROM :LRW OFFICE OF JK JONES FRX NO..:717 240-0066 Mar. 16 2004 '11:32RM P2
PRAECIPE FOR LISTING CASE FOR ARGUMENT
(Must be typewritten and submitted in duplicate)
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please list the within matter for the next Argument Court.
CAPTION OF CASE
(entire caption must be stated in full)
CORY A. CORMANY
vs.
( Plaintiff )
TINA D. ADAMS
(Defendant)
JURY TRIAL DEMANDED
No. 03-187 Civil x ig 2004
1. State matter to be argued (i.e., plaintiff's motion for new trial, defendant's
demurrer to complaint, etc.):
Defendant's Preliminary Objections to Plaintiff's Complaint.
2. Identify counsel who will argue case:
(a) for Plaintiff: Pro Se
Address:
(b) for defendant: Christian F. Rhodes, Esquire
Address: Stock and Leader
221 West Philadelphia Street
Suite E600
York, PA 17404
3. I will notify all parties in writing within two days that this case has
been listed for argument.
4. Argument Court Date-, April 21, 2004
Dated:
ttorney for Defendant
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
THE COMMONWEALTH OF PENNSYLVANIA
CORY A. CORMANY
PLAINTIFF,
V.
TINA D. ADAMS
Defendant.
Case No. 03-1876
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
I, Christian F. Rhodes, Esquire, an attorney of the law firm of Stock and Leader,
Susquehanna Commerce Center East, 221 West Philadelphia Street, Suite 600, York,
Pennsylvania 17404, hereby certify that I served the within Praecipe for Listing Case for
Argument this day by first-class United States mail, postage prepaid, addressed to the party of
record as follows:
Date: -5 "aA °?-\
Cory A. Cormany
1883 Douglas Drive
Carlisle, PA 17013
STOCK AND LEADER
By- ( /
Christian F. Rhodes., Esquire
Attorney for Defendant
Sup. Ct. I.D. #89667
221 West Philadelphia Street
Suite E600
York, PA 17404
Telephone: (717) 846-9800
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
THE COMMONWEALTH OF PENNSYLVANIA
CORY A. CORMANY
Plaintiff, ) Case No. 03-1876
V. ) Civil Action - Law
TINA D. ADAMS Jury Trial Demanded
Defendant.
DEFENDANT'S PRELIMINARY OBJECTIONS TO PLAINTIFF'S COMPLAINT
Defendant Tina D. Adams, by her attorneys, files her preliminary objections to Plaintiff's
Complaint under Rule 1028(a)(4) of the Pennsylvania Rules of Civil Procedure. In support of
her Preliminary Objections, Defendant states as follows:
Plaintiff Cory A. Cormany, Defendant's ex-husband, filed a complaint against her
on April 23, 2002 alleging that he was discriminatorily denied employment at a McDonald's
restaurant which is owned by a company for which Defendant is the Director of Operations.
2. Plaintiff did not personally serve the complaint as required by Penn. R. Civ. P.
400, but rather served it by certified mail.
3. Plaintiff's claims against Defendant fall under the jurisdiction of either Title VII
of the Civil Rights Act of 1964, 42 U.S.C. § 2000e, et. seq. ("Title VII") or the Pennsylvania
Human Relations Act, as amended, 43 P.S. § 951, et seq. ("PHRA"). As such, Plaintiff was
required to file a charge of discrimination with either the Equal Employment Opportunity
Commission ("EEOC") or the Pennsylvania Human Relations Commission ("PHRC") within
180 days (or, in the case of the EEOC, within 300 days if proceedings were initially instituted
with a state or local agency). See 42 U.S.C. § 2000e-5(e)(1); 43 Pa. C.S. §§ 959(a), 962.Plaintiff
neither alleged he filed a charge of discrimination nor attached documentation demonstrating that
he had done so to his complaint. As such, his 1997 - 1999 and September, 2002 claims must be
dismissed under Penn. R. Civ. P. 1028(a)(4) because they are time-barred. See 42 U.S.C. §
2000e-5(c)(1); 43 Pa. C.S. §§ 959(a), 962. Significantly, 180 days had already passed as to these
claims by the time Plaintiff filed his complaint in April, 2003.
4. The remaining claims for alleged discriminatory conduct in October - November,
2002, must likewise be dismissed because while Plaintiff's complaint sat un-served, the statute
of limitations on those claims has expired. See 42 U.S.C. § 2000e-5(e)(1); 43 Pa. C.S. §§ 959(a),
962 and Lamp v. Heyman, 469 Pa. 465, 366 A.2d 882 (1976).
5. Alternatively, Plaintiff's complaint must be dismissed in its entirety because he
has failed to exhaust his administrative remedies under Title VII and the PHRA.
6. The arguments and authorities supporting Defendant's Preliminary Objections to
Plaintiff's Complaint are set forth in Defendant's Memorandum of Law in Support of her
Preliminary Objections, filed contemporaneously herewith.
2
WHEREFORE, for the reasons set forth herein and in Defendant's Memorandum of Law
in support of her Preliminary Objections, Defendant respectfully requests that Plaintiff's
complaint be dismissed with prejudice.
Respectfully submitted,
STOCK AND LEADER
y
T othy . R h squire
Supreme o ID 26024
By:
Christian F. Rhodes, Esq
Supreme Court ID #: 89667
Counsel for Defendant
Susquehanna Commerce Center East
221 W. Philadelphia St., Suite E600
York, PA 17404
Phone: (717) 846-9800
Fax: (717) 843-6134
March \ °\ 2004
1:\users\Wtpr\kenMUTO1s. DOC
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
THE COMMONWEALTH OF PENNSYLVANIA
CORY A. CORMANY
Plaintiff, ) Case No. 03-1876
V. ) Civil Action - Law
TINA D. ADAMS Jury Trial Demanded
Defendant.
CERTIFICATE OF SERVICE
I, Christian F. Rhodes, Esquire, an attorney of the law firm of Stock and Leader,
Susquehanna Commerce Center East, 221 West Philadelphia Street, Suite 600, York,
Pennsylvania 17404, hereby certify that I served the within Defendant's Preliminary
Objections to Plaintiff's Complaint this day by first-class United States mail, postage prepaid,
addressed to the party of record as follows:
Cory A. Cormany
1883 Douglas Drive
Carlisle, PA 17013
Date: 3 ?q O?
STOCK AND LEADER
Christian F. Rhodes., Esquire
Attorney for Defendant
Sup. Ct. I.D. #89667
221 West Philadelphia Street
Suite E600
York, PA 17404
Telephone: (717) 846-9800
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
THE COMMONWEALTH OF PENNSYLVANIA
CORY A. CORMANY
V.
KENNETH LEVINE
CASE NO. 03-1876
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
N T
You have been sued in Court. If you wish to defend against the claim set
forth in the following pages, you must take action within twenty (20) days after
the Complaint and Notice are served by entering a written appearance personally
or by attorney and by filing in writing with the Court your defense or objection to
the claims set forth against you. You are warned that if you fail to do so the case
may proceed without you and 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 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
1 South Hanover Street
Carlisle, PA. 17013
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
THE COMMONWEALTH OF PENNSYLVANIA
CORY A. CORMANY CASE NO. 03- l 876
V. CIVIL ACTION - LAW
KENNETH LEVINE JURY TRIAL DEMANDED
CONTP_L AINT_
AND NOW comes, Cory A. Cormany, Plaintiff, and sets forth causes of
action against the above named Defendant, wherefore the following is a statement:
1. Mr. Cory A, Connany is an adult individual residing in
Cumberland County, Pennsylvania.
1 Mr. Kenneth Levine is an adult individual residing in Cumberland
County, Permsylvania.
3. Plaintiff, Cory A. Connany, is a high school graduate, a university
undergraduate, a taxpayer, a registered voter, a citizen, a confirmed methodist,
and a veteran of the United States of America.
4. Defendant is Kenneth Levine, an owner operator employed by
McDonalds Co. of Carlisle, Pennsylvania; (McCopCo. Franchises).
5. The plaintiff is an equal opportunity applicant interested in
McDonalds Co. of Carlisle, Peruisylvania; (McCopCo. Franchises).
6. In or about the month of September of the year 1997, the plaintiff
did pursue an employment application at the McDonalds Co. of Carlisle, the High
Street location, authentic a documentation.
7. Preceding the events described in the aforementioned statements, the
plaintiff, Cory A. Cormany, did retain and remit employment opportunity at the
McDonalds Co. of Carlisle, non faulted an expiry period, throughout the years
1988 and 1989; (The Golden M Corp.).
8. On or about February 1st of the year 2002, the plaintiff did file a
criminal report pursuant Mr. John Adams, an ex-employee to The McDonalds Co.
of Carlisle, the husband of Ms. Tina Adams; (Kenmar Enterprises Inc.).
9. On or about February I Ith of the year 2002, the plaintiff did pursue
a criminal dismissal reliable Mr. John Adams, an instigator to The Commonwealth
of Pennsylvania, the friend of Mr. Wayne Ziegler; (Order Of The Court).
10. On or about June 7th of the year 2002, the plaintiff did file a civil
complaint pursuant Mr. Mathew Kennedy, an officer to The Carlisle Police
Department of Carlisle, the corroborator of Mr. Jeffrey Kurtz; (Borough Of
Carlisle Pennsylvania).
11. On or about December 3rd of the year 2002, the plaintiff did file a
criminal report pursuant Mr. Raymond Motter, an ex-employee to The McDonalds
Co. of Carlisle, the friend of Mr. John Adams; (Kenmar Enterprises Inc.).
12. On or about May 28th of the year 2003, the defendant did respond
(2)
a civil entry reliable Ms. Tina Adams, an operational director to The McDonalds
Co. of Carlisle, the wife of Mr. John Adams; (Kenmar Enterprises Inc.).
13. On or about June 16th of the year 2003, circumstantial a legal service
(Order of the Court), the defendant, Tina D. Adams, did directly circumvent a
decision; and, did deny the plaintiff, Cory A. Cormany, employment opportunity
pertinent a Pro Hac Vice.
14. On or about January 13th of the year 2004, rhetorical an attorney
(Hubert Gilroy), the defendant, Tina D. Adams, did once again deny the plaintiff
employment opportunity circumstantial the Health and Safety, Equal
Employment, and Human Relations Commissions of the Commonwealth of
Pennsylvania.
15. The Defendant, Mr. Kenneth Levine, did subordinately discriminate
with prejudice and malice, negligently causing mental anguish, public
humiliation, emotional duress, and deprivation of equal right reliable
the Plaintiff, Mr. Cory Cormany.
16. The Defendant, Mr. Kenneth Levine, did deliberately cause Mr.
Cory Cormany lost wages and employment, benefits and expenses in the foregoing
amount, excessive a potential amount of Ten Thousand and 00 Dollars
(10,000.00), respectfully submitted exhibits A through F.
17. By reason of the aforementioned; Mr. Cory Cormany has
suffered discrimination, mental anguish, public humiliation, emotional duress,
(3)
constitutional deprivation, loss of wages and employment, benefits, and expenses
as a result of the defendant, Kenneth Levine.
Vd EREAS, plaintiff, Cory A. Cormany, claims from the defendant,
Kenneth Levine, punitive and compensatory relief in an amount in excess of Ten
Thousand and 00 Dollars (10,000.00), plus costs of any proceeding.
(4)
VERIFICATION
1, Cory A. Connany, Plaintiff in the above captioned action, hereby verify
and state that the facts set forth in the Complaint against Mr. Kenneth Levine are
true and correct to the best of my infonnation, knowledge and belief i understand
that false statements herein are made subject to the penalties of Pa. C.S.A. Section
4904, relating to rmsworn verification to authorities.
Dated 3 ,
By
Cory A. Cormany
Witless
By _0 J 1 ?Ly.W
Notary
NOTARIAL SEAL
CLAUDIA A. BREWBAKER, NOTARY PiiBLIC
Carlisle Boro, Cumberland County
My Commission Expires April 4, 2005
(5)
EXHIBIT
A
(6)
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7
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
THE COMMONWEALTH OF PENNSYLVANIA
CORY A. CORMANY CASE NO. o3-4*
V. CIVIL ACTION - LAW
TINA D. ADAMS JURY TRIAL DEMANDED
You have been sued in Court. If you wish to defend against the claim set
forth in the following pages, you must take action within twenty (20) days after
the Complaint and Notice are served by entering a written appearance personally
or by attorney and by filing in writing with the Court your defense or objection to
the claims set forth against you. You are warned that if you fail to do so the case
may proceed without you and judgment may be entered against you by the Court
without finther notice for any money claimed in the Complaint or for any other
claim or relief requested by 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
1 South Hanover Street
Carlisle, PA. 17013
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EXHIBIT
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RE: District Attorney Defendant:
Cumberland County John Adams
Court House Square
Carlisle, PA 17013
I, Cory A. Cormany, being a citizen of the United States of America, do
hereby state and swear that at or about February 23, 1991, and through and about
a judgmental action, the above named defendant did commit the following crimes:
1) 903. Criminal Conspiracy - a person is guilty of conspiracy with another
person or persons to commit a crime if with intent of promoting or
facilitating its commission he: (1) agrees with such other person or persons
that they or one or more of them will engage in conduct which constitutes
such crime; or (2) agrees to aid such other person or persons in the planning
or commission of such crime or of an attempt or solicitation to commit such
crime.
2) 2705. Recklessly Endangering Another Person - a person commits a
misdemeanor of the second degree if he recklessly engages in conduct
which places or may place another person in danger of death or serious
bodily injury.
3) 2901. Kidnapping - a person is guilty of kidnapping if he unlawfully
removes another a substantial distance under the circumstances from the
place where he is found, or if he unlawfully confines another fora
substantial period in a place of isolation with any of the following
intentions: (1) To hold for ransom or reward, or as a shield or hostage. (2)
To facilitate commission of any felony or flight thereafter. (3) To inflict
bodily injury on or to terrorize the victim or another. (4) To interfere with
the performance by public officials of any governmental or political
function. (b) Grading - Kidnapping is a felony of the first degree. A
removal or confinement is unlawful within the meaning of this section if it
is accomplished by force, threat or deception, or, in the case of a person
who is under the age of 14 years or incompetent, if it is accomplished
without the consent of a person, guardian or other person responsible for
general supervision of his welfare.
4) 3105. Prompt Complaint - a prompt reporting of public authority is not
required in a prosecution under this chapter: Provided, however, that
nothing in this section shall be construed to prohibit a defendant from
V
introducing evidence of the alleged victim's failure to promptly report the
crime if such evidence would be admissible pursuant to the rules of
evidence.
5) 4305. Dealing in Infant Children - a person is guilty of a misdemeanor of
the first degree, if he deals in humanity, by trading, bartering, buying,
selling, or dealing in infant children.
6) 5101. Obstructing Administration of Law or Other Governmental Function
- a person commits a misdemeanor of the second degree if he intentionally
obstructs, impairs or perverts the administration of law or other
governmental function by force, violence, physical interference or obstacle,
breach of official duty, or any other unlawful act, except that this section
does not apply to flight by a person charged with crime, refusal to submit to
arrest, failure to perform a legal duty other than an official duty, or any
other means of avoiding compliance with law without affirmative
interference with governmental functions.
7) 5108. Compounding - a person commits a misdemeanor of the second
degree if he accepts or agrees to accept any pecuniary benefit in
consideration of refraining from reporting to law enforcement authorities
the commission or suspected commission of any offense or information
relating to an offense.
8) 5508. Disrupting Meetings or Processions - a person commits a
misdemeanor of the third degree if, with intent to prevent or disturb a
lawful meeting, procession or gathering, he disturbs or interrupts it.
903- 1972, Dec. 6, P.L. 1482, No. 334, 1, effective June 6 1973
2705-
1972, Dec. 6, P.L.
1482, No. 334, ,
1, effective June 6 .
1973
2901 -
1972, Dec. 6, P.L.
1482, No. 334, ,
1, effective June 6 .
1973
3105 -
1972, Dec. 6, P.L.
1482, No. 334, ,
1, effective June 6 .
1973
4305 -
1972, Dec. 6, P.L.
1482, No. 334, ,
1, effective June 6 .
1973
5101 -
1972, Dec. 6, P.L.
1482, No. 334, ,
1, effective June 6 .
1973
5108-
1972, Dec. 6, P.L.
1482, No. 334, ,
1, effective June 6 .
1973
5508-
1972, Dec. 6, P.L.
1482, No. 334, ,
1, effective June 6, .
1973.
I, Cory Cormany, hereby verify that the facts set forth in the above are true
and correct to the best of my knowledge or information and belief and that any
false statements herein are made subject to the penalties of Section 4904 of the
Crimes Code (18 Pa. C.S. 4904), relating to unworn falsification to authorities.
Dated By
Cory A. Corma-n??
INCIDENT REPORT
Criminal Conspiracy: In that John Adams did knowingly and intentionally
facilitate the commission of a crime promoting a solicitation capable a Defendant.
Recklessly Endangering Another Person: In that the Defendant did engage in
conduct which did place another person in danger of bodily injury. Kidnapping:
In that the Defendant did relocate and confine a minor child from the rightful
guardian substantial a distance and political a deception. Prompt Complaint: In
that the Defendant did subject indecent conduct questionable an authority, or
guardian, which did fail an official report. Dealing in Infant Children: In that the
Defendant did deal in a humanitarian trade by buying a custodial obligation
substantial an infant child. Obstructing Administration of Law or Other
Governmental Function: In that the Defendant did interfere and pervert a violence
breaching an official document affirmative an action, and liable a governmental
function. Compounding: In that the Defendant did accept pecuniary benefits
considerate an information, and reportorial the suspected commission of a crime.
Disrupting Meetings and Processions: In that the Defendant did intentionally
prevent and disturb conversations and meetings between two lawful guardians
interruptive a minor child.
I petition that a warrant of arrest or a summons be issued and that the
Defendant be required to answer the charges I have made. I verify that the facts
set forth in this complaint are true and correct to the best of my knowledge or
information and belief. This verification is made subject to the penalties of
Section 4904 of the Crimes Code (18 Pa. C.S. 4904), relating to unsworn
falsification to authorities.
Daed
Dated
C4- r 0.
Signature
Signature
I NManw S"
Nwen D. eneeo. NMr# Pwdk
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Mas Twp.. EpIrN,Mre 2a, CYV= Lntl Caun062
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AFFIDAVIT
On January 19, 1991, I, Cory A. Cormany, did proceed established
visitation regarding my said minor child at said residential environment, and was
denied according to the whereabouts of the said natural child. Proceeding such
noncommunicative relation. I did proceed established visitation for my said minor
child on February 2, 1991, and did again find the whereabouts hindered.
On February 9, 1991, I, Cory A. Cormany, did proceed established
visitation regarding my said minor child at said residential environment, and was
denied according to the residential vacancy once again. Proceeding such incident
Mr. John Adams did inform me by telephone that I was not permitted to contact
the said natural child or the opposing guardian.
On February 23, 1991, I, Cory A. Cormany, did proceed established
visitation regarding my said minor child at said residential environment, and was
denied according to the whereabouts of the said natural child. Proceeding such
incident Defendant John Adams did physically confront me purposeful the said
established time, and did envelope a dangerous altercation.
After or about the aforesaid date and time, mentioned in the aforesaid
paragraph, the Defendant John Adams did suppress evidential endulgences later
verificative my recognition, and knowledge; substantial the civil case number
1:CV-95-0844, and did interfere and deliberately cause and pervert a breach in an
official governmental function. The Defendant did prevent and disrupt affirmative
meetings and gatherings documented an obstacle, and necessary a maintenance;
Pursuant the Commonwealth of Pennsylvania,
In February of the year 1991 and through and about November of the year
1991, I, Cory A. Cormany, did visit with my said natural child in and about the
contact visitation area at the Cumberland County Prison, permissive and provided
the said natural child's mother and my parents. Proceeding such times and events,
irrelated the docketed visitation establishments; my said minor child would spend
the weekdays with me or my said parents, up and until approximately June of the
year 1992, During and through these foregoing time periods the said natural child
did complain of incidental situations and circumstances abnormal a consideration,
preponderate Mr. John Adams. I did submit correspondences, remissive actions
and incidents to the Children and Youth Services of Cumberland County, and
further did inform the county district attorney suspicious the Courts of
Cumberland County. Such issues did include indecent allegations and conduct
accusive both the Defendant John Adams and my parents; appeasable the said
natural child's legal guardians.
In the year 1993 and pursuant thereto and prior therein, I, Cory A.
Cormany, was delivered legal notices regarding my parental rights, and a petition
presentable the court of common pleas. I did respond to such formality and did
confront Mr. John Adams' Attorney; Mr. Gilroy, pursuant to and prior the case
number 64 in Orphans Court Division. Prescient thereto the monetary
ramifications certified to my attention through a mail correspondence; my said
minor child was to be relocated preparatory the Defendant John Adams. I did
infact submit a retaliatory crossclaim to the courts and did appraise criminal
propaganda, associated reliant the defendant's attorney and consensual the said
minor child's mother; forthright an argument and a conviction, and did attend the
official matter costly the order of the court pursuant further action.
In December of the year 1994 and through and about a problematic legal
judgment, I, Cory A. Cormany, did see and receive enfranchised reminiscences
meaningful the said minor child's whereabouts, and indigent an extenuating issue
endeavored an employment or affirmative educational dilemma. The Defendant
John Adams has continually attempted and solicited situations and circumstances
contemptual a deceptive relation mandatory a civil action. Mr. John Adams has
procrastinated important objects profligative myself in the years 1995, 1998, 1999
and 2001 beneficial a criminal outcome and suspicious an informative indecent
conduct.
1, Cory A. Cormany, on this J<,-L day of r??nc •?^ , of the year
2002, do hereby swear as a citizen and a voter of the CoQnonwealth of the
United States that the above facts are true and correct to the best of my knowledge
and belief.
Cory A. Gorman
Dated
Witness
I Nou w 9q1 j
NWnD. 6naad Nobly PlAlk I
1iM Cow W n Eypi21?10?02
Aw..", P MyNanfa Assoc alion of Notanas
EXHIBIT
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COMMONWEALTH OF PENNSYLVANIA
1
V.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: 01-2091 CRIMINAL
: CHARGE: APPEAL FROM SUMMARY
PUBLIC DRUNKENNESS
CORY CORMANY
: AFFIANT: PTL. MATTHEW KENNEDY
ORDER OF COURT
AND NOW, this _ day of , 2002, upon
consideration of the Commonwealth's Motion, the above-captioned
appeal is hereby deemed DISMISSED as moot.
By the Court,
J.
Jaime M. Reating
Chief Deputy District Attorney
Cory Cormany, Pro se
Cumberland County Prison
I
COMMONWEALTH OF PENNSYLVANIA
V.
CORY CORMANY
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: 01-2091 CRIMINAL
: CHARGE: APPEAL FROM SUMMARY
PUBLIC DRUNKENNESS
: AFFIANT: PTL. MATTHEW KENNEDY
COMMONWEALTH'S MOTION TO VACATE SUMMARY APPEAL AS MOOT
AND NOW, comes the Commonwealth of Pennsylvania who
respectfully requests an order of this Honorable Court vacating
the defendant's appeal as moot by averring the following:
1. On May 17, 2001, the defendant was charged under
citation P1896187-6 for a summary violation of Publam
Mr xi
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Drunkenness. A r_
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2. On October 11, 2001, the defendant filed a3or apl
z?
from summary conviction. At the date of that filinche
1
defendant had not yet been convicted of this summa --chaj_Zge
which was pending a hearing before District Justice Correal.
3. On December 7, 2001, the defendant was found not
guilty by District Justice Correal.
4. Despite the acquittal, this matter is still listed
under this docket number for an appeal from summary conviction.
WHEREFORE, the Commonwealth respectfully requests an Order
of this Honorable Court deeming the appeal from summary
conviction filed in the above-captioned case be dismissed as
moot.
Respectfully submitted,
7
ime M.
C
g
Chief Deputy District Attorney
THE COURT OF COMMON PLEAS CUMBERLAND COUNTY
THE COMMONWEALTH OF PENNSYLVANIA
CORY A. CORMANY CASE NO.
V. CIVIL ACTION - CRIMINAL L?W
r°
COMMONWEALTH JURY TRIAL
OTN:PA 0211500 DOCKET FILE: NT-0000620-: Q
TI
You have been sued in Court. If you wish to defend against the claim set
forth in the following pages, you must take action within twenty (20) days after
the Complaint and Notice are served by entering a written appearance personally
or by attorney and by filing in writing with the Court your defense or objection to
the claims set forth against you. You are warned that if you fail to do so the case
may proceed without you and 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 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
I South Hanover Street
Carlisle, PA. 17013
EXHIBIT
?9?
RE: District Attorney Defendant:
Cumberland County Raymond Motter
Court House Square
Carlisle, PA 17013
I, Cory A. Cormany, being a citizen of the United States of America, do
hereby state and swear that at or about April 21st, of the year 2002, and through
and about a judgmental action, the above named defendant did commit the
following crimes:
1) 901. Criminal Attempt - a person commits an attempt when, with intent to
commit a specific crime, he does any act which constitutes a substantial step
toward the commission of that crime.
2) 2709. Harassment - a person commits a summary offense when, with intent
to harass, annoy or alarm another person: (1) he strikes, shoves, kicks or
otherwise subjects him to physical contact, or attempts or threatens to do the
same; or (2) he follows a person in or about a public place or places; or (3)
he engages in a course of conduct or repeatedly commits acts which alarm
or seriously annoy such other person and which serve no legitimate purpose.
3) 3105. Prompt Complaint - a prompt reporting of public authority is not
required in a prosecution under this chapter: Provided, however, that
nothing in this section shall be construed to prohibit a defendant from
introducing evidence of the alleged victim's failure to promptly report the
crime if such evidence would be admissible pursuant the rules of evidence.
4) 4702. Threats and Other Improper Influences in Official or Political
Matters - a person commits an offense if he: (1) threatens unlawful harm to
any person with intent to influence his decision, opinion, recommendation,
vote or other exercise of discretion as a public servant, party official or
voter.
5) 4703. Retaliation for Past Official Action - a person commits a
misdemeanor of the second degree if he harms another by any unlawful act
in retaliation for anything lawfully done by the latter in the capacity of a
public servant.
6) 4953. Retaliation Against Witness or Victim - a person commits an offense
if he harms another by any unlawful act in retaliation for anything lawfully
done in the capacity of witness or victim.
7) 5107. Aiding Consummation of Crime - a person commits an offense if he
intentionally aids another to accomplish an unlawful object of a crime, as
by safeguarding the proceeds thereof or converting the proceeds into
negotiable funds.
8) 5503. Disorderly Conduct - a person is guilty of disorderly conduct if, with
intent to cause public inconvenience, annoyance or alarm, or recklessly
creating a risk thereof, he: (1) engages in fight or threatening, or in violent
or tumultuous behavior; (2) makes unreasonable noise; (3) uses obscene
language, or makes an obscene gesture, or (4) creates a hazard or physically
offensive condition by any act which serves no legitimate purpose of the
actor.
901 - 1972, Dec. 6, P.L. 1482, No. 334, 1, effective June 6, 1973.
2709- 1972, Dec. 6, P.L. 1482, No. 334, 1, effective June 6, 1973.
3105- 1972, Dec. 6, P.L. 1482, No. 334, 1, effective June 6, 1973.
4702- 1972, Dec. 6, P.L. 1482, No. 334, 1, effective June 6, 1973.
4703- 1972, Dec. 6, P.L. 1482, No. 334, 1, effective June 6, 1973.
4953 - 1972, Dec. 6, P.L. 1482, No. 334, 1, effective June 6, 1973.
5107- 1972, Dec. 6, P.L. 1482, No. 334, 1, effective June 6, 1973.
5503 - 1972, Dec. 6, P.L. 1482, No. 334, 1, effective June 6, 1973.
I, Cory Cormany, hereby verify that the facts set forth in the above are true
and correct to the best of my knowledge or information and belief and that any
false statements herein are made subject to the penalties of Section 4904 of the
Crimes Code (18 Pa. C.S. 4904), relating to unworn falsification to authorities.
Dated By
;9ry A. Co any
INCIDENT REPORT
Criminal Attempt: In that Raymond Motter did intentionally act toward the
commission of a crime constitutional a Defendant. Harassment: In that the
Defendant did strike and shove a person subjecting contact which did annoy and
seriously alarm people in a public place. Prompt Complaint: In that the Defendant
did construe evidence that allegedly prompted an individual to report a crime.
Threats and Other Improper Influences in Official or Political Matters: In that the
Defendant did influence the decisions and opinions of a voter substantial an
unlawful harm. Retaliation for Past Official Action: In that the Defendant did
unlawfully harm or did cause harm to an individual, circumstantial an official
action, in retaliation of a latter capacity. Retaliation Against Witness or Victim: In
that the Defendant did unlawfully act out against a witness in retaliation of an
official capacity causing or intending to cause harm. Aiding Consummation of
Crime: In that the Defendant did intentionally aid another to accomplish an
unlawful object and did safeguard the proceeds thereof, and did confess the
conversion of a fund. Disorderly Conduct: In that the Defendant did intentionally
engage in fight or threatening behavior violent an unreasonable act; that did
involve obscene gestures and language physically offensive a condition.
I petition that a warrant of arrest or a summons be issued and that the
Defendant be required to answer the charges I have made. I verify that the facts
set forth in this complaint are true and correct to the best of my knowledge or
information and belief. This verification is made subject to the penalties of
Section 4904 of the Crimes Code (18 Pa. C.S. 4904), relating to unsworn
falsification to authorities.
'a -Ddt a 12,
Dated
Signature
Signature
NOWM Sod
Helen D. Sneed. Nobly Pd*
M ftmTW,O nbmieWCwry
My Camr"W FxpY" J* 24.2006
hftmb r, ftv"Nwe Aao"m Of1*0
AFFIDAVIT
On April 21st, 2002, I, Cory A. Cormany, did converse with the identified
Defendant Raymond Molter at a female acquaintance of mine's home,
sequestering attention to statements he made pertinent an individual named Kevin
Shugharts. Mr. Shugharts evidently procrastinated statements to the Mr. Motter in
the Cumberland County Prison important incidents and events heard my said;
minor child (Alexandria Christine). Mr. Kevin Shugharts alleged to the Mr.
Raymond Motter, that; [he] had previously smoked (crack) cocaine with an
individual identified herein as John Adams (Cory's exwife's husband).
During the aforedescribed event stated, the identified individual Kevin
Shugharts; did litigate information to the Defendant Raymond Motter regarding
the said; minor child, saying; quote a heresay episode, "She's getting to be prime
meat", and that; [he], "wouldn't mind tapping [that], when she gets a little older."
I did subject and further did interrogate the defendant, questioning the truthfulness
of the applied insinuation. I did, on a prior occasion[s], remark and criticize the
Defendant Raymond Molter substantial a civil suit I filed against a Carlisle Police
Officer in 1994. 1 had informed Mr. Molter, that; I did infact complain of his
said, extra curricular activities (drug usages), and was consequently maced for it.
Such aforementioned information did become humorous to him, and did become
common knowledge between the defendant and myself; after a given time period.
I did conclude that Mr. Raymond Motter had talked indepth with the identified
individual Kevin Shugharts on several occasions within the county prison, and had
become additionally knowledgeable other illicit transactions, and an official
domestic incident as well. It was expressed to me that, "Your daughter must
becoming quite a looker Cory. Shugharts says John has big expectations for her."
The Defendant Raymond Motter did continue rhetoric, and did speak as though
Mr. Shugharts thought there was to be something impressionably wrong with the
defined John Adams, and, that; Mr. Shugharts seemed to have problems himself
with said; statutory issues. A Ms. Nicole Jastron did witness the conversation
abroad in and at `her place' of residence.
On June 7, 2002, I, Cory A. Cormany, did recognize a criminal complaint
to the Cumberland County District Attorney. Proceeding the aforementioned date
I did file a civil action in the Court of Common Pleas of Cumberland County
alleging private and public affairs impermeable the objects of illegal and legal
transactions, argumentative several Lawful Acts. I had been subjected a
controversial incident regarding the Carlisle Police Department on that same, said;
day, I did pursue the civil ramification allegary a summary matter. Coincidental
my involvement with the foregoing, I did witness the Defendant Raymond Motter
carrying on suspicious activity with an individual identified thereto as; Mr. John
Adams. I had been observing Mr. John Adams prior therein the year 1994
circumstantial a visitation/custody obligation documented problematic my said;
minor child. I had not ever met the defendant prior to or pursuant to, any interest,
included the said; visitation/custody matter, prescient [his] whereabouts officiallv
announced; that, particular year.
Prescient the aforedecsribed incident litigated, the identified individual
Nicole Jastron; did state deflamatory propaganda to me further her involvement
with the Defendant Raymond Motter. Ms. Jastron did say that, "Raymond and I
were talking about your daughter the other day." She said, that; she had brought
herself to the subject of my visitation/custody arrangements saying she thought my
situation [was], "messed up." Ms. Jastron did further the conversation by stating,
"Raymond says, well ...you know what they say, old enough' to bleed, old enough
to breed." It was my opinion that the aforesaid conversation was to be conclusive
`her opinion' regarding the issues and incidents described colorful the Defendant
Raymond Motter and Mr. Kevin Shugharts.
On September 15th, 2002, I, Cory A. Cormany did converse with the
individual Defendant Raymond Motter in the county prison that particular
morning relevant the said; minor child, and the object of complaint. I had
discussed this topic before with Mr. Motter in or about several other times, but did
not seem to communicate a common ground. The defendant did become very
upset over the arguments and issues at large, and did physically push and punch
me, and did warn at the aforestated date and time, that; [I], "better not" snitch to
anybody about what [he] had heard. The Defendant Raymond Motter did also tell
me that our conversation in and around the month of April 2002, "was not" any of
"their business", in obvious reference to the county administration and the local
police; simply conclusive a situation and a circumstance logical an altercation. A
C.O. Durnin, of the Cumberland County Prison, did witness and interrupt our
said; intermediary, and did inform "us", we needed to "cool it" or else we would
be; "locked up" pursuant a prison policy.
Pursuant the aforedescribed event stated, the identified individual Nicole
Jastron; did litigate information to me by telephone, acknowledging that the
Defendant Raymond Motter had been smoking (crack) cocaine in her bathroom
prior to his commitment to the county prison. She did continue to inform me that
I was to tell the defendant "that", he [was] not to be welcomed in her home any
longer, being said; that, the Mr. Motter and Ms. Jastron were allegedly (friends)
prior to the said; prison commitment. At or about the time that I relayed the
applied message to the defendant, he did become outraged and began yelling
obscenities stating, "I hope that John Adams rapes your daughter Cory", and, "I
don't care what Nicole says, she's nothing but a slut anyhow." The contents of the
events and issues remarked and criticized leads me to believe the commission of
crime has occurred; or is to occur, and that the defendant also is substantial (a)
proceeding, applicable the Court of Common Pleas. I did additionally, pursuant
the defendant's incarceration, helped the defendant with several legal problems. I
was to be incarcerated a reasonable probated violation outstanding a situation and
circumstance directly relevant Mr. Raymond Motter.
I, Cory A. Cormany, on this &c S day of Qr« \,r , of the year
2002, do hereby swear as a citizen and a voter of the Commonwealth of the
United States that the above facts are true and correct to the best of my knowledge
and belief.
Cory A. Cormany
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Dated
Witness
NoWW Seed
Helen D. Sneed Notary Pd*
Mddlesmc TM., CunberWW corx#y
My Ccrmission Fires July 24, 2006
Member, Pmwnylvaris Assadason Of NaWm
EXHIBIT
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CORY A. CORMANY,
Plaintiff
CASE NO. 03-1876
V.
CIVIL ACTION - LAW
TINA D. ADAMS,
Defendant
JURY TRIAL
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PRAECIPE FOR ENTRY OF APPEARANCE
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TO THE PROTHONOTARY:
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Kindly enter my appearance for Tina D. Adams, Defendant, for the sole purpose of filing
Objections to jurisdiction and service of process upon Defendant.
Respectfully submitted,
STOCK AND LEADER
DATE: 2003
/ Lothy uth Es ' e/
Supreme Co 6024
Susquehanna Commerce Center East
221 West Philadelphia Street, Suite 600
York, PA 17404
(717) 846-9800
I.IUSERSV,B\TPRIKENMAR?ENTRYAPP.PRA
JUN 1 3 2003
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CORY A. CORMANY, CASE NO. 03-1876
Plaintiff
V.
CIVIL ACTION - LAW
TINA D. ADAMS,
Defendant JURY TRIAL DEMANDED
ORDER
AND NOW, this I4 day of wll-? , 2003, upon review and consideration
of the Applications To Appear As Counsel Pro Hac Vice In Pending Litigation filed by Yvette
A. Heintzelman, Esquire, and Alissa L. Gilfand, Esquire, and in consideration of the Motion
for Admission Pro Hac Vice filed by Timothy P. Ruth, Esquire, of the law firm of Stock and
Leader, in support of the Applications, it is hereby:
ORDERED that the Motion for Admission Pro Hac Vice filed with respect to the
Applications of Yvette A. Heintzelman Esquire, and Alissa L. Gilfand, Esquire, for an Order
granting them permission to appear as counsel pro hac vice pursuant to the Pennsylvania Rules
of Court is HEREBY GRANTED.
BY rTHURT:
JUDGE
1AUSERS\KB\TPRUCENMAR\Pro Hac Vko order.doc
EXHIBIT
(1l)
JOIEV H. BROulos
HUBERT X. GILROY
BROUJOS & GILROY, P. c.
ATTORNEYS AT LAW
4 NORTH HANOVER STREET
CARLISLE, PENNSYLVANIA 17013
January 13, 2004
Cory A. Cormany
1883 Douglas Drive
Carlisle, PA 17013
Dear Mr. Cormany:
TELEP14ONE: (717) 243-4574
FACSIMILE: (717) 243-8227
jbroujos0broujosoroy.com
hgilroy®broujosgilroycom
NON-TOLL FOR HARRISBURG AREA
717-766-1690
Our office represents John and Tina Adams of 145 Kerrs Road, Carlisle, PA.
Please accept this letter as a notice to you that you are not to come on the property of Mr.
And Mrs. Adams at 145 Kerrs Road, Carlisle, PA. This notice is effective for any and all
matters and indicates that you may not come on the property of the Adams'. Any effort
by you to come on the property will result with the filing of a Trespass Action.
Additionally, you are hereby notified that you should not have any verbal or written
communication with Mr. Adams or with Mrs. Adams or with any of their children. Any
attempts by you to contact thew after this time will be deamed to be harassment and we
will turn the matter over to the appropriate criminal officials for prosecution.
Please note that this No Contact Provision also applies to any place of employment of Mr.
& Mrs. Adams.
The frivolous litigation you have filed coupled with the efforts you have made to contact
the Adams family is simply nothing more than harassment on your part and will no
longer be tolerated. We will pursue all remedies with criminal prosecution and any civil
remedies if necessary.
Please just stay away!
Sincerely yo rs
qe X. Gil y
y
jmw
cc: Mr. & Mrs. John Adams
Pennsylvania State Police Carlisle Barracks
Borough of Carlisle Police
CERTIFICATIQN_QF_ SERVICE
AND NOW, this -; day of 2004, 1, Cory A, Cormany
foregoing the aforesaid matter knowledgeable a legal pretext, and the
Commonwealth of Pennsylvania, hereby certify that I have served a copy of same
in person or by the United States Mail at Carlisle Pennsylvania, addressed as
follows:
Mr. Kenneth Levine
McDonalds Company
905 Walnut Bottom Rd.
Carlisle, PA 17013
Esquire Noted:
Cory A. Cormany
1883 Douglas Dr.
Carlisle, PA 17013
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CORY A. CORMANY, IN THE COURT OF COMMONPLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
TINA D. ADAMS,
Defendant NO. 03-1876 CIVIL TERM
IN RE: PRELIMINARY OBJECTIONS OF
DEFENDANT TO PLAINTIFF'S COMPLAINT
BEFORE HOFFER, P.J., and OLER, J.
ORDER OF COURT
AND NOW, this 19" day of May, 2004, upon consideration of Defendant's
preliminary objections to Plaintiff's complaint, and for the reasons stated in the
accompanying opinion, service upon Defendant is set aside, without prejudice to
Defendant's right to timely pursue other appropriate preliminary objections in the
event that Plaintiff causes Defendant to be subjected to personal jurisdiction of the
court.
BY THE
,Cory A. Cormany
1883 Douglas Drive
Carlisle, PA 17013
Plaintiff, pro se
v,Christian F. Rhodes, Esq.
Susquehanna Commerce
Center East
221 W. Philadelphia Street
Suite E600
York, PA 17404
Attorney for Defendant
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CORY A. CORMANY, IN THE COURT OF COMMONPLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
TINA D. ADAMS,
Defendant NO. 03-1876 CIVIL TERM
IN RE: PRELIMINARY OBJECTIONS OF
DEFENDANT TO PLAINTIFF'S COMPLAINT
BEFORE HOFFER, P.J., and OLER, J.
OPINION and ORDER OF COURT
OLER, J., May 19, 2004.
For disposition in this civil case in which a pro se Plaintiff has sued his
former wife' are preliminary objections filed by Defendant to Plaintiffs
complaint. The preliminary objections include an objection based upon improper
service.Z
Defendant's preliminary objections were argued before the above court en
banc on April 21, 2004.3 For the reasons stated in this opinion, Defendant's
preliminary objection based upon improper service of the complaint will be
sustained, and the service will be set aside.
STATEMENT OF FACTS
Plaintiff is identified in his complaint as "an adult individual residing in
Cumberland County, Pennsylvania."4 Defendant is similarly identified in the
complaint as "an adult individual residing in Cumberland County, Pennsylvania. ,5
1 See Plaintiffs Complaint, para. 12.
2 See Defendant's Preliminary Objections to Plaintiffs Complaint, para. 2; Pa. R.C.P. 1028(a)(1).
3 Plaintiff neither filed a brief nor appeared for the argument. "Plaintiffs Complaint, para. 1.
5 Plaintiffs Complaint, para. 2.
Plaintiff's complaint appears to be related to a failure of a McDonald's
restaurant franchisee (for which his former wife worked) to employ him.6
Representative of the largely unintelligible allegations in the complaint are these:
8. To or about the month of April of the year
2001, the plaintiff did retain and service an
employment application at the Ames Dept. Stores of
Carlisle, the Old M.J. Mall location, foregoing a timely
full-time employment.
9. Preceding the issues described in the
aforementioned statements, the plaintiff, Cory A.
Cormany, did achieve and retain employment
opportunity at the McDonalds Co. of Carlisle, non
faulted an expiry period, obligatory a minor child;
(Alexandria Christine).
10. In or about the month of September of the
year 2002, the plaintiff did sustain an. employment
application at the McDonalds Co. of Carlisle,
argumentative several entailed locations, liberal a
documentation.
12. Pursuant the foregoing business the
defendant, Tina D. Adams, did divorce the plaintiff,
Cory A. Cormany, allegorical an alcohol/driving issue;
nonreliable a vehicle and a decree, and did marry a
convicted narcotics offender, substantial an equal
opportunity employer.7
Defendant indicates that Plaintiffs complaint was served by certified mail.8
No sheriffs return appears in the record.
DISCUSSION
Under Pennsylvania Rule of Civil Procedure 400(a), as a general rule
"original process shall be served within the Commonwealth only by the sheriff."
As has been stated by the Pennsylvania Superior Court, "[r]egardless of whether
e See Plaintiff's Complaint, paras. 13-14
Plaintiff's Complaint, paras. 8-10, 12.
a Defendant's Preliminary Objections to Plaintiff's Complaint, para.. 2.
2
the action is commenced by writ of summons or where, as here, the action is
commenced by a complaint, service of process is essential to commencing the
action. Proper service is a prerequisite to a court acquiring personal jurisdiction
over a defendant." Ramsay v. Pierre, 822 A.2d 85, 89, (Pa. Super. 2003).
Where service is improper, it may be set aside. Collins v. Park, 423 Pa.
Super. 601, 621 A.2d 996 (1993). Accordingly, the following order will be
entered:
ORDER OF COURT
AND NOW, this 19`h day of May, 2004, upon consideration of Defendant's
preliminary objections to Plaintiff's complaint, and for the reasons stated in the
accompanying opinion, service upon Defendant is set aside, without prejudice to
Defendant's right to timely pursue other appropriate preliminary objections in the
event that Plaintiff causes Defendant to be subjected to personal jurisdiction of the
court.
BY THE COURT,
s/ J. Wesley Oler, Jr.
J. Wesley Oler, Jr., J.
Cory A. Cormany
1883 Douglas Drive
Carlisle, PA 17013
Plaintiff, pro se
Christian F. Rhodes, Esq.
Susquehanna Commerce
Center East
221 W. Philadelphia Street
Suite E600
York, PA 17404
Attorney for Defendant
3
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
THE COMMONWEALTH OF PENNSYLVANIA
CORY A. CORMANY
Plaintiff,
V.
TINA D. ADAMS
Case No. 03-1876
Civil Action - Law
Jury Trial Demanded
Defendant.
AFFIDAVIT OF TINA SAUTER
I, Tina Sauter, after being duly sworn on oath, declare as follows:
1. Since January 17, 1994, I have served as the Controller for Levine Enterprises,
Inc., which owns several McDonald's restaurant in Carlisle, PA. Levine Enterprises' office is
located at 123 S. Pitts Street, Carlisle, Pennsylvania.
2. As Controller, I receive all the mail that comes to Levine Enterprises.
3. On or about April 25, 2003, I received via certified mail a Complaint with the
case number 03-1876 and the caption, "Cory A. Cormany v. Tina D. Adams," from Cory A.
Cormany, which was apparently filed on April 23, 2003.
4. On or about March 25, 2004, I received a second Complaint with the case number
03-1876, but it had a different caption than the first complaint - "Cory A. Cormany v. Kenneth
Levine." Tiffany Rose, a Swing Manager, found the Complaint (with no postage) on the front
counter of one of Levine Enterprise's McDonald's restaurants, located at 608 East High Street
Road, Carlisle, Pennsylvania, and forwarded it to me at the office. I did not think that this
Complaint was related to Mr. Cormany's April, 2003 Complaint since it had a different caption
(the April, 2003 Complaint had the caption, "Cory A. Cormany v. Tina D. Adams). As such, I
forwarded it to Hubert Gilroy, an attorney handling several other lawsuits filed by Mr. Cormany
against Ms. Adams and her family members, including her children.
5. On or about September 28, 2004, I received a letter dated September 27, 2004
addressed to Mr. Kenneth Levine from Cory Cormany. Attached to the letter was an "Amended
Complaint," with the case number 03-1876 and the caption "Cory A. Cormany v. Tina D.
Adams," filed-stamped September 10, 2004 by the Prothonotary for the Court of Common Pleas
of Cumberland County.
6. Attached to the September 10, 2004 "Amended Complaint" were several exhibits.
7. Exhibit D contains documents purporting to be sworn statements and verifications
from the McDonald's employees referenced in Plaintiff's Amended Complaint. Each sworn
statement alleges that the witness observed conduct that violated "codes pursuant to Health and
Safety, Equal Employment and Human Relations Commissions of the Commonwealth of
Pennsylvania."
8. I believe that Mr. Cormany, or someone acting on his behalf, forged each of these
verifications. I base my belief on the following:
A) The first "Sworn Statement" and "Verification" contains the name of a
person - Walt Jawinski - who has not worked for Levine Enterprises since the early 1990's and
whose last name is spelled incorrectly. His last name is Karczewski.
B) The second "Sworn Statement" and "Verification" contains the name of a
person - Annett Jones- who has not worked for Levine Enterprises since 2002. In addition, the
witness's first name is spelled incorrectly - it should be spelled "Annette." Finally, this former
employee got divorced and went by her maiden name - Snyder - through most of her
employment with Levine Enterprises. "Jones" was her married name.
2
C) The third "Sworn Statement" and "Verification" contains the name of a
witness - Nina Davis - who has never worked for Levine Enterprises.
D) The fourth "Sworn Statement" and "Verification" contains the name of a
witness - Susan Starner - who has never worked for Levine Enterprises.
E) The fifth "Sworn Statement" and "Verification" contains the name of a
witness - Eugene Foley - who never worked for Levine Enterprises. Levine Enterprises did
employ a person named Mark E. Foley at one point, but not "Eugene Foley."
F) The sixth "Sworn Statement" and "Verification" contains the name of a
witness - Thomas Minic - whose worked for Levine Enterprises thought a prison work release
program for a short time and left the Company in 2002. Additionally, the witness's last name is
spelled incorrectly. His last name is spelled "Minnich."
Further Affiant sayeth not.
Tina Sauter
SUBSCRIBED and SWORN to before me
in County of Cumberland, State of Pennsylvania,
this 3Mday of November, 004.
C cq?
No ry Public
Notarial Seal
Bridget Ann Corcoran, Notary Public
Carlisle Boro, Cumberland County
My Commission Expires June 10, 2006
Member, Pennsylvania Association of Notaries
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
THE COMMONWEALTH OF PENNSYLVANIA
CORY A. CORMANY
Plaintiff,
V.
TINA D. ADAMS
Case No. 03-1876
Civil Action - Law
Jury Trial Demanded
Defendant.
DEFENDANT'S PRELIMINARY OBJECTIONS
TO PLAINTIFF'S MARCH 25, 2004 AND SEPTEMBER 10, 2004 COMPLAINTS
Defendant Tina D. Adams, by her attorneys, files her preliminary objections to Plaintiff's
March 25, 2004 and September 10, 2004 Complaints under Rule 1028(a)(4) and 1028(f) of the
Pennsylvania Rules of Civil Procedure. In support of her Preliminary Objections, Defendant
states as follows:
Plaintiff Cory A. Cormany, Defendant's ex-husbzaid, filed a complaint against her
(captioned "Cory A. Cormany v. Tina D. Adams") on or about A.,pril 23, 2003 alleging that he
was discriminatorily denied employment at a McDonald's restaurant which is owned by a
company for which Defendant is the Director of Operations.
2. Plaintiff did not personally serve the complaint as required by Penn. R. Civ. P.
400, but rather served it by certified mail.
3. On March 19, 2004, Defendant filed Preliminary Objections because the
Complaint was not served properly. In addition, Defendant argued that the Preliminary
Objections should be sustained because Plaintiff's claims were time-barred and because he failed
to exhaust his administrative remedies under either Title VII of the Civil Rights Act of 1964, 28
U.S.C. § 2000e, et. seq. or the Pennsylvania Human Relations Act, 43 P.S. § 951, et. seq.
CHI 10802312.1
4. On May 19, 2004, the Court sustained Defendant's Preliminary Objections as to
deficient service.
Meanwhile, on March 25, 2004, unbeknownst to Counsel for Defendant, Plaintiff
filed a second Complaint captioned "Cory A. Cormany v. Kenneth Levine," which contained
new allegations. Plaintiff served this Complaint on Defendant by sending it to Mr. Levine
regular mail. See Sauter Aff. 14.
6. Then, on September 10, 2004, Plaintiff filed an "Amended Complaint," with the
correct caption of "Cory A. Cormany v. Tina D. Adams." He served the "Amended Complaint"
on Ms. Adams by regular U.S. Mail on or about September 27, 2004. See Sauter Aff. ¶ 5.
7. Because Plaintiff's April 23, 2003 Complaint was not properly served, his service
of subsequent Complaints by U.S. Mail is insufficient under Perm. R. Civ. P. 400(a).
Additionally, Plaintiff's attempt to serve an entirely new complaint with a different caption, but
under the same case number (03-1876) is entirely improper. As a result, Defendant's
Preliminary Objections to Plaintiff's March 25, 2004 and September 10, 2004 Complaints for
deficient service should be sustained.
8. The arguments and authorities supporting Defendant's Preliminary Objections to
Plaintiff's March 25, 2004 and September 10, 2004 Complaints are set forth in Defendant's
Memorandum of Law in Support of her Preliminary Objections, filed contemporaneously
herewith.
WHEREFORE, for the reasons set forth herein and in ]Defendant's Memorandum of Law
in support of her Preliminary Objections, Defendant respectfully requests that Plaintiff's March
25, 2004 and September 10, 2004 Complaints be dismissed with prejudice.
2
CHI 10802312.1
Respectfully submitted,
Yvette Heintzelman
Alissa L. Gilfand
SEYFARTH SHAW LLP
55 East Monroe Street
Suite 4200
Chicago, IL 60603
(312) 346-8000
Timothy Ruth
STOCK AND LEADER
221 W. Philadelphia St.
Ste. E600
York, PA 17404
(717) 846-9800
Supreme Court ID #: 26024
Decemberly, 2004
TINA D. ADAMS
B ez?A'
ne of r Ayyyleys
CHI 10802312.1
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PRAECIPE FOR LISTING CASE FOR ARGUMENT
(Must be typewritten and submitted in duplicate)
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please list the within matter for the next Argument Court.
CAPTION OF CASE
(entire caption must be stated in full.)
CORY A. CORMANY
(Plaintiff)
VS.
TINA D. ADAMS
(Defendant)
No. 03 Civil 1876 19
1. State matter to be argued (i.e., plaintiff's motion for new trial, defendant's
demurrer to complaint, etc.):
Preliminary Objections to Complaint for failure to properly serve Complaint.
2. Identify counsel who will argue case:
(a) for plaintiff: Cory A. Cormany, Pro se
Address: 1883 Douglas Drive
Carlisle, PA 17013
(b) for defendant: Timothy P. Ruth, Esq. and/or Philip H. Spare, Esq.
Address: Stock and Leader, Susquehanna Commerce Center East
221 W. Philadelphia Street
York, PA 17404
3. I will notify all parties in writing within tw:) days that this case has
been listed for argument.
4. Argument Court Date: February 2, 2005
, P41a' D
A to., f - fe ant
Dated: Dec" dam',
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CORY A. CORMANY, CASE NO. 03-1876
Plaintiff
V. CIVIL ACTION - LAW
TINA D. ADAMS,
Defendant JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
I, Timothy P. Ruth, Esquire, an attorney of the law firm of Stock and Leader,
Susquehanna Commerce Center, 221 West Philadelphia Street, Suite E600, York,
Pennsylvania 17404, hereby certify that I have, on the date below written, served a true and
correct copy of DEFENDANT'S PRELIMINARY OBJECTIONS TO PLAINTIFF'S
MARCH 25, 2004 AND SEPTEMER 10, 2004 COMPLAINTS and the supporting
AFFIDAVIT OF TINA SAUTER in the above-captioned action, by regular first-class mail,
postage prepaid, addressed to the party of record as follows:
Cory A. Cormany
1883 Douglas Drive
Carlisle, PA 17013
DATE: December 20, 2004 G
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IAUSERSTKB\TPR\KENMAR\Cert of Service - PO's.doc
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
THE COMMONWEALTH OF PENNSYLVANIA
CORY A. CORMANY CASE NO. 03-1876
V.
TINA D. ADAMS
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NOTICE
You have been sued in Court. If you wish to respond to the objections set
forth in the following pages, you must take action within ten (10) days after this
Notice is served by entering a written appearance personally or by attorney and by
filing in writing with the Court your defense or objection. to the claims set forth
against you. You are warned that if you fail to do so the case may proceed without
you and 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 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
1 South Hanover Street
Carlisle, PA. 17013
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
THE COMMONWEALTH OF PENNSYLVANIA
CORY A. CORMANY CASE NO.. 03-1876
V. CIVIL ACTION - LAW
TINA D. ADAMS JURY TRIAL DEMANDED
AND NOW, this day of _, 2005; upon consideration
of Defendant Tina D. Adams' Preliminary Objections the Plaintiff moves to
Dismiss the Complaint in response thereto the Affidavit set forth Ms. Tina Sauter,
in consideration, it is hereby Ordered and Decreed that the said Preliminary
Objections are moot, and the Plaintiff may proceed Complaint.
J.
cc: Stock & Leader
Seyfarth Shaw LLP
Levine Enterprises Inc.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
THE COMMONWEALTH OF PENNSYLVANIA
CORY A. CORMANY
V
TINA D. ADAMS
CASE NO. 03-1876
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
PLAINTIFF'S PRELIMINARY OBJECTIONS TO DEFENDANT'S
DECEMBER 14, 20049S OBJECTIONS TO DEMURRER
Plaintiff; Cory A. Cormany, by pro-se litigation, files his preliminary
objections to Defendant's December 14, 2004 preliminary objections under Rule
1028(a)(4) and 1028(f) of the Pennsylvania Rules of Civil Procedure. In support
of his Preliminary Responses and Brief, Plaintiff states as follows:
1. Defendant; Tina D. Adams, plaintiff's ex-wife, filed a response
against her (captioned "Cory A. Cormany v. Tina D. ,Adams") on or about April
233, 2003 alleging that she was not discriminatorily denied employment at a
McDonalds restaurant which is owned by a company for which Defendant is the
Director of Operations.
(4)
2. Plaintiff did personally serve the complaint as required by Penn. R.
Civ. P. 401, but rather is serviced informally.
3. Affirmed, the preponderance of evidence is argumentative.
4. Affirmed, the preponderance of evidence is argumentative.
5. Affirmed, the preponderance of evidence is argumentative.
6. Denied, the preponderance of evidence is argumentative.
7. Denied, the preponderance of evidence is argumentative.
8. The arguments and authorities supporting Plaintiff s Order and Brief
to Plaintiff's March 255 2004, and September 10, 2004 Complaints are set forth in
Plaintiff's Memorandum of Law in Support of his Preliminary Objections, filed
contumely herewith.
WHEREFORE, for the reasons set forth therein and in Plaintiff's
Memorandum of Law in support of his Preliminary Objections, plaintiff
respectfully requests that Defendant's December 14, 2004 Preliminary Affidavit
be hereby dismissed without prejudice.
Respectfully Submitted,
A. Corn
(5)
'
'
_ - CD
tL
u? =-c
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
THE COMMONWEALTH OF PENNSYLVANIA
CORY A. CORMANY
V.
TINA D. ADAMS
CASE NO. 03-1876
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
CORY C.ORMANY'S RESPONSE. TO UNA SA R'S
AFFIDAVIT PURSUANT TO RULES OF CIVIL PROCEDURE
28 U S.C 1915o AND PROVISIONAL R C I'. 42 P.S.A. 1602
I, Cory Cormany, being duly sworn by affirmation, declare as follows:
1. Since December 14, 2004, I have been sewed by United States Mail
by the Stock And Leader Law Office, a true and coiTect copy of Tina Sauter's
Affidavit; whom is employed by Levine Enterprises located at 123 S. Pitt Street,
Carlisle, Pennsylvania.
2. As Plaintiff, I set forth a response as in accordance with Procedure.
3. On or about December 14, 2004, I received by regular postage an
Affidavit for the case number 03-1876; "Cory A. Cormany et. al. v. Tina D.
Adams et. al.", from the law office of Stock & Leader, which was apparently
(6)
filed on December 14th of the year 2004.
4. On or about March 19, 20041- I received an argumentative response
pursuant to R.C.P. 1028 (a)(4) for the case number 03-1876, but did not proceed
response for the purpose of demurrer. I did not believe that the complaint merited
further response in the nature of demurrer, and did proceed further Complaint.
As such I have filed complaint pursuant Mr. Gilroy regarding my natural
biological daughter and her mother; Ms. Tina Doreen Adams.
5. On or about December 13, 20045 I received a letter addressed to my
family counselor; Ms. Linda Klinger. Attached to the letter is a Fax with the
McDonalds Logo substantial Levine Enterprises Inc., for the Civil Case File 04-
1077 filed in the Court of Common Pleas of Cumberland County on March 12th
of the year 2004.
6. Attached herein this December 27, 2004, are several exhibits.
7. Exhibits A - F are letters, faxes, and civil and criminal objects
purporting truthful implication employable a future reference and Complaint.
Each sworn deference alleges a "series of events" that [I] did witness pursuant a
conduct and verification in violation to "codes substantial Health and Safety,
Equal Employment and Human Relations Commissions of the Commonwealth of
Pennsylvania."
8. As per iteration to the solvency of complaint and the American Bar
Association I did produce liability argumentative a timely manner.- I base my
following response:
(7)
A) Mr. Walt Jawinski may be spelled Mr. Walt
Karczewski, however the identity is argumentative
a said; proceeding. This individual can be
identified.
B) Ms. Annett Jones may be spelled Ms. Annette
Snyder, however the identity is argumentative a
said; proceeding. This individual can be
identified.
C) Ms. Nina Davis has been since married pursuant
her said; employment with McDonalds (Levine
Enterprises Inc.), however maintains termination
costly a pregnancy and child. This individual
can be identified.
D) Ms. Susan Starner has been since divorced
pursuant her said; employment with McDonalds
(Levine Enterprises Inc.), however maintains
termination costly an expression and policy. This
individual can be identified.
E) Ms. Eugene Foley has been :since deceased
pursuant her said; employment with McDonalds
(Levine Enterprises Inc.), however maintains
termination costly a social security and
grandsibling. This individual can be identified.
F) Mr. Thomas Minnich has been since incarcerated
pursuant his said; employment with McDonalds
(Levine Enterprises Inc.), however maintains
termination costly an institute and order of the
court. This individual can be identified.
Further Affiant sayeth so.
S,joY,? av-)a 4-a i??- ?
2-rjTk of" , Z-6 0q
NOTARIAL SEAL (g)
JODY S. SMITH, NOTARY PUBLIC
Carlisle Boro, Cumberland Count;,
My Commission Expires April 4, 2005,
ca co
EXHIBIT
A
(9)
FROM :LAW OFFICE OF JK JONES FAX NO. :717 240-0066 Mar. 16 2004 11:32AM P2
PRAECIPE FOR LISTING CASE FOR ARGUMENT
(Must be typewritten and submitted in duplicate)
TO 'SHE PROTHONOTARY OF CUMBERLAND COUNTY:
Please list the within matter fat the next Argument Court.
CAPTION OF CASE
(entire caption must be stated an full)
CORY A. CORMANY
VSO
TINA D. ADAMS
(Plaintiff) JURY TRIAL DEMAND
ID:?
(Defendant)
No. .03-187-6 Civil X 29 .2004
1.. State matter to be argued (i.e., plaintiff's =A:;-on for rw_w trial., defendant's
derwerex to c;anplaint, etc.
Defendant's Preliminary Objections to Plaintiff's Complaint.
2. . Identify aonsel who will argue case:
(a) fat Plaintiff: Pro Se
Address:
(b) f6r defendwti Christian F. Rhodes, Esquire
Address: Stock and Leader
221. West Philadelphia Street
Suite E600
York,.PA 17404
3. 1 will notify all parties in writing within two days that this case has
beer listed- far argument.
4. Argument Court Date: April 21;.2004
ldvft?
PRAECIPE FOR LISTING CASE FOR ARGUMENT Oopvp
(Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please list the within matter for the next Argument Court.
CAPTION OF CASE
(entire caption must be stated in full)
CORY A. CORMANY
(Plaintiff)
VS.
TINA D. ADAMS
(Defendant)
No. 03 Civil 1876 19
1. State matter to be argued (i.e., plaintiff's mention for new trial, defendant's
demurrer to complaint, etc.) :
Preliminary Objections to Complaint for failure to properly serve Complaint.
2. Identify counsel wbo will argue case:
(a) for plaintiff: Cory A. Cormany, Pro se
Address: 1883 Douglas Drive
• Carlisle, PA 17013
(b) for defendant: Timothy P. Ruth, Esq. and/or Philip H. Spakd, Esq.
Address: Stock and Leader, Susquehanna Commerce Center East
221 W. Philadelphia Street
York, PA 17404
3. I will notify all parties in writing within tw:) days that this case has
been listed for argument.
4. Argument Court Date: February 2, 2005
Dated: i er" &,z ate, a `?° AAte&GAreY f f e an t
ZW IJl E COURT Off' COMMON PLEAS OF
CU-tMTERLAMD COUM Y
TVE COMMOMWEA.CTV OF P-EWVSYlvAM9A
CORYA. CORMANY
V.
ALEXANDRIA C. CORMANY
CA
SENO
.
.
CIVIL ACTION - LA
_.: _ .ern
JURYTR.IAL DEM
TDED,,
_
You have been sued in Court. If you wish to defend against the claim set forth
in the following pages, you must take action within twenty (2o) days after the
Complaint and Notice are served by entering a written appearance personally or by
attorney and by filing in writing with the Court your defense or objection to the
claims set forth against you. You are warned that if you fail to do so the case may
proceed without you and judgment maybe entered against you bythe Court without
further notice for any money claimed in the Complaint or for any other claim or
relief requested by Plaintiff. You may lose money or property or other rights
importanttoyou.
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
Court Administrator
Cum6erfand County Bar Association
Irvin Row
Carlisle-, PA- 17013
EXHIBIT
(10)
HUMAN RELATIONS
RIVER FRONT OFFICE COMPLEX
HARRISBURG, PA 17104
ATTENTION INTAKE: REPORT
Through Act of 1955, P.L. 744, No. 222 As amended June 25, 1997 By Act 34 of 1997
43 P. S. to 959 - 963, I, Cory A. Cormany do hereby pledge and state the following:
A. Employment Agency - referred by memorandum or agency thereto the
Commonwealth of Pennsylvania.
B. Commission - is sworn to, and hereby credited to an extenuation of the state of
Pennsylvania for the purpose of taxation.
C. Political Subdivision - is an enfranchised unit confidential a certified
accountability named McDonalds (Levine Enterprises).
D. Discriminate - Ms. Tina Adams is the subject matter and did subordinately or
insubordinately cause an employable malpractice.
E. Persons - in that Mr. Walt Jawinski is an adult Caucasian male individual in
his late thirties.
F. Legislative Body - in that Mr. Walt Jawinski [was] employed by McDonalds of
Carlisle (Levine Enterprises) in or about the month of November 1990.
G. Employee - in that Mr. Walt Jawinski did terminate employment with McDonalds
pursuant a sexual relationship with Ms. Tina Adams.
H. Commercial Profit - in that Ms. Tina Adams did commit a lawful or unlawful
servitude for a commercialized benefactor pursuant an authority.
I, Cory A. Cormany, request and submit that an investigation be issued onto Ms. Tina
Adams, and that she be made to answer for prejudicial and discriminatory acts.
R-O1 -off
Date
Sign
(1-1)
HUMAN RELATIONS
RIVER FRONT OFFICE COMPLEX
HARRISBURG, PA 17104
ATTENTION INTAKE: REPORT
Through Act of 1955, P.L. 744, No. 222 As amended June 25, 1997 By Act 34 of 1997
43 P. S. to 959 - 963, I, Cory A. Cormany do hereby pledge and state the following:
A. Employment Agency - referred by memorandum or agency thereto the
Commonwealth of Pennsylvania.
B. Commission - is sworn to, and hereby credited to an extenuation of the state of
Pennsylvania for the purpose of taxation.
C. Political Subdivision - is an enfranchised unit confidential a certified
accountability named McDonalds (Levine Enterprises).
D. Discriminate - Ms. Tina Adams is the subject matter and did subordinately or
insubordinately cause an employable malpractice.
E. Persons - in that Ms. Annett Jones is an adult Caucasian female individual in
her late thirties.
F. Legislative Body - in that Ms. Annett Jones [was] employed by McDonalds of
Carlisle (Levine Enterprises) in or about the month of April 1995.
G. Employee - in that Ms. Annett Jones did terminate employment with McDonalds
pursuant a sexual relationship with Ms. Tina Adams.
H. Commercial Profit - in that Ms. Tina Adams did commit a lawful or unlawful
servitude for a commercialized benefactor pursuant an authority.
I, Cory A. Cormany, request and submit that an investigation be issued onto Ms. Tina
Adams, and that she be made to answer for prejudicial and discriminatory acts.
Date
Sign
(1-1)
HUMAN RELATIONS
RIVER FRONT OFFICE COMPLEX
HARRISBURG, PA 17104
ATTENTION INTAKE: REPORT
Through Act of 1955, P.L. 744, No. 222 As amended :tune 25, 1997 By Act 34 of 1997
43 P.S. to 959 - 963, I, Cory A. Cormany do hereby pledge and state the following:
A. Employment Agency - referred by memorandum or agency thereto the
Commonwealth of Pennsylvania.
B. Commission - is sworn to, and hereby credited to an extenuation of the state of
Pennsylvania for the purpose of taxation.
C. Political Subdivision - is an enfranchised unit confidential a certified
accountability named McDonalds (Levine Enterprises).
D. Discriminate - Ms. Tina Adams is the subject matter and did subordinately or
insubordinately cause an employable malpractice.
E. Persons - in that Ms. Nina Davis is an adult African American female individual in
her mid thirties.
F. Legislative. Body - in that Ms. Nina Davis [was] employed by McDonalds of
Carlisle (Levine Enterprises) in or about the month of June 1997.
G. Employee - in that Ms. Nina Davis did terminate employment with McDonalds
pursuant a six week pregnancy leave reliable Ms. Tina Adams.
H. Commercial Profit - in that Ms. Tina Adams did commit a lawful or unlawful
servitude for a commercialized benefactor pursuant an authority.
I, Cory A. Cormany, request and submit that an investigation be issued onto Ms. Tina
Adams, and that she be made to answer for prejudicial and discriminatory acts.
cl- - - oy
Date
C-2'r-2,
Sign -
(1-1)
HUMAN RELATIONS
RIVER FRONT OFFICE COMPLEX
HARRISBURG, PA 17104
ATTENTION INTAKE: REPORT
Through Act of 1955, P.L. 744, No. 222 As amended Tune 25, 1997 By Act 34 of 1997
43 P. S. to 959 - 963, 1, Cory A. Cormany do hereby pledge and state the following:
A. Employment Agency - referred by memorandum or agency thereto the
Commonwealth of Pennsylvania.
B. Commission - is sworn to, and hereby credited to an extenuation of the state of
Pennsylvania for the purpose of taxation.
C. Political Subdivision - is an enfranchised unit confidential a certified
accountability named McDonalds (Levine Enterprises).
D. Discriminate - Ms. Tina Adams is the subject matter and. did subordinately or
insubordinately cause an employable malpractice.
E. Persons - in that Ms. Susan Starner is an adult Caucasian female individual in
her mid forties.
F. Legislative Body - in that Ms. Susan Starner [was] employed by McDonalds of
Carlisle (Levine Enterprises) in or about the month of October 2000.
G. Employee - in that Ms. Susan Starner did terminate employment with McDonalds
pursuant being told, quote; "Get the F**k out of Here", by Ms. Tina Adams.
H. Commercial Profit - in that Ms. Tina Adams did commit a lawful or unlawful
servitude for a commercialized benefactor pursuant an authority.
I, Cory A. Cormany, request and submit that an investigation be issued onto Ms. Tina
Adams, and that she be made to answer for prejudicial and discriminatory acts.
-01-cry
Date
Sign (1-1)
HUMAN RELATIONS
RIVER FRONT OFFICE COMPLEX
HARRISBURG, PA 17104
ATTENTION INTAKE: REPORT
Through Act of 1955, P.L. 744, No. 222 As amended .Tune 25, 1997 By Act 34 of 1997
43 P. S. to 959 - 963, I, Cory A. Cormany do hereby pledge and state the following:
A. Employment Agency - referred by memorandum or agency thereto the
Commonwealth of Pennsylvania.
B. Commission - is sworn to, and hereby credited to an extenuation of the state of
Pennsylvania for the purpose of taxation.
C. Political Subdivision - is an enfranchised unit confidential a certified
accountability named McDonalds (Levine Enterprises).
D. Discriminate - Ms. Tina Adams is the subject matter and did subordinately or
insubordinately cause an employable malpractice.
E. Persons - in that Ms. Eugene Foley is an adult Caucasian female individual in
her mid sixties.
F. Legislative Body - in that Ms. Eugene Foley [was] employed by McDonalds of
Carlisle (Levine Enterprises) in or about the month of October 2002.
G. Employee - in that Ms. Eugene Foley did terminate employment with McDonalds
pursuant being told, that; she was = good enough to perform a "task" allegorical
Ms. Tina Adams.
H. Commercial Profit - in that Ms. Tina Adams did commit a lawful or unlawful
servitude for a commercialized benefactor pursuant an authority.
I, Cory A. Cormany, request and submit that an investigation be issued onto Ms. Tina
Adams, and that she be made to answer for prejudicial and discriminatory acts.
t -0-? "0Y
Date
Sign
(1-1)
HUMAN RELATIONS
RIVER FRONT OFFICE COMPLEX
HARRISBURG, PA 17104
ATTENTION INTAKE: REPORT
Through Act of 1955, P.L. 744, No. 222 As amended June 25, 1997 By Act 34 of 1997
43 P.S. to 959 - 963, I, Cory A. Cormany do hereby pledge and state the following:
A. Employment Agency - referred by memorandum or agency thereto the
Commonwealth of Pennsylvania.
B. Commission - is sworn to, and hereby credited to an extenuation of the state of
Pennsylvania for the purpose of taxation.
C. Political Subdivision - is an enfranchised unit confidential a certified
accountability named McDonalds (Levine Enterprises).
D. Discriminate - Ms. Tina Adams is the subject matter and did subordinately or
insubordinately cause an employable malpractice.
E. Persons - in that Mr. Thomas Minic is an adult Caucasian male individual in
his early thirties.
F. Legislative Body - in that Mr. Thomas Minic [was] employed by McDonalds of
Carlisle (Levine Enterprises) in or about the month of February 2003.
G. Employee - in that Mr. Thomas Minic did terminate employment with McDonalds
pursuant a timely civil filing, costly the order of the court, purposeful Ms. Tina
Adams.
H. Commercial Profit - in that Ms. Tina Adams did commit a lawful or unlawful
servitude for a commercialized benefactor pursuant an authority.
I, Cory A. Cormany, request and submit that an investigation be issued onto Ms. Tina
Adams, and that she be made to answer for prejudicial and discriminatory acts.
Date
Sign C::J?
(1-1)
EXHIBIT
C
(11)
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
THE COMMONWEALTH OF PENNSYLVANIA
CORY A. CORMANY CASE NO. Oy- Voss 12tv;P 7
V. CIVIL ACTION - LAIN
HUBERT X. GILROY : JUDGMENT DEMANDED
NOTICE
You have been sued In Court. If you wish to defend
against the claim set forth In the following pages, you must
take action within twenty (20) days after the Complaint and
Notice are served by entering a written .;.pearance
personally or by attorney and by filing in writing with the
Court your defense or objection to the claims set forth
against you.. You are warned that if you fail to do so the
case may proceed without you and judgment may be
entered against you by the Court without further notice for
any money claimed in the Complaint oir for any other claim
or relief requested by Plaintiff. You may lose money or
property or other rights important to you.
•. is ?.
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
1 South Hanover Street
Carlisle, PA. 17013 '11RUE COPY FROM RECORD
in 1'asti onY wn;Mf, i here unto sot mY hand
Co. at Ugsia. Pa.
4.1 C?
and t6ne Gal of sa% '
Thi day o .zZ2i?C
?? Protho
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
THE COMMONWEALTH OF PENNSYLVANIA
CORY A. CORMANY CASE 140. a y- yoss' `T..-
V. CIVIL ACTION - LAW
TINA D. ADAMS JURY TRIAL DEMANDED
NOTICE
You have been sued in Court. If you wish to defend
against the claim set forth in the following pages, you must
take action within twenty (20) days after the Complaint and
Notice are served by entering a written appearance
personally or by attorney and by filing in writing with the
Court your defense or objection to t;he' claims set forth
against you. You are warned that if you fail to do so the
case may proceed without you and 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 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 Rouse
1 South Hanover Street
Carlisle, PA. 170'13 TRUE COPY FROM PECOR'J
:ind the dal of s,-W C: ' d: G'wsia. P3.
s -7
day t
fins
19
pOmftn'OUry
RE: District Attorney Defendant:
Cumberland County Tina D. Adams
Court House Square Hubert X. Gilroy
Carlisle, PA 17013
I, Cory A. Cormany, being a citizen of the United States of America, do
hereby state and swear that at or about the month of June of the year 1992, and
through and about the month of March of the year 2004, the above named
defendant[s] did commit the following crimes:
1) 902. Criminal Solicitation - a person is guilty of solicitation to commit a
crime with intent of promoting or facilitating its commission he commands,
encourages or requests another person to engage in specific conduct which
would establish his complicity in its commission or attempted commission.
2) 2709. Harassment - a person commits a summary offense when, with intent
to harass, annoy or alarm another person: (1) he strikes, shoves, kicks or
otherwise subjects him to physical contact, or attempts or threatens to do the
same; or (2) he follows a person in or about a public place or places; or (3)
he engages in a course of conduct or repeatedly commits acts which serve
no legitimate purpose.
3) 2906. Criminal Coercion - a person is guilty of criminal coercion if, with
intent unlawfully to restrict freedom of action of another to the detriment of
the other, he threatens to: (1) commit any criminal offense; (2) accuse
anyone of a criminal offense; (3) expose any secret tending to subject any
person to hatred, contempt or ridicule; or (4) take or withhold action as an
official, or cause an official to take or withhold action.
4) 3105. Prompt Complaint - a prompt reporting of public authority is not
required in a prosecution under this chapter: Provided, however, that
nothing in this section shall be construed to prohibit a defendant from
introducing evidence of the alleged victim's failure to promptly report the
crime if such evidence would be admissible pursuant to the rules of
evidence.
5) 4305. Dealing in Infant Children - a person is guilty of a misdemeanor of
the first degree, if he deals in humanity, by trading, bartering, buying,
selling, or dealing in infant children.
6) 4952. Intimidation of Witness or Victims - a person commits an offense if,
with the intent to or with the knowledge that his conduct shall obstruct,
impede, impair, prevent or interfere with the administration of criminal
justice he intimidates or attempts to intimidate any witness or victim to: (1)
Refrain from informing or reporting to any law enforcement officer,
prosecuting official or judge concerning any information, document or
thing relating to the commission of a crime. (2) Give any false or
misleading information or testimony relating to the commission of any
crime to any law enforcement official, prosecuting attorney or judge. (3)
Withhold any testimony, information, document or thing relating to the
commission of a crime from any law enforcement official, prosecuting
attorney or judge. (4) Give any false or misleading information or
testimony relating to the commission of any crime to an attorney
representing a criminal defendant. (5) Elude, evade or ignore any request to
appear or legal process summoning him to appear to testify or supply
evidence. (6) Absent himself from any proceeding or investigation to which
he has been legally summoned.
7) 5101. Obstructing Administration of Law or Oler Governmental Function
- a person commits a misdemeanor of the second degree if he intentionally
obstructs, impairs or perverts the administration of law or other
governmental function by force, violence, physical interference or obstacle,
breach of official duty, or any other unlawful act, except that this section
does not apply to flight by a person charged with crime, refusal to submit to
arrest, failure to perform a legal duty other than an official duty, or any
other means of avoiding compliance with law without affirmative
interference with governmental functions.
8) 5108. Compounding - a person commits a misdemeanor of the second
degree if he accepts or agrees to accept any pecuniary benefit in
consideration of refraining from reporting to law enforcement authorities
the commission or suspected commission of any offense or information
relating to an offense.
9) 5508. Disrupting Meetings or Processions - a person commits a
misdemeanor of the third degree if, with intent to prevent or disturb a
lawful meeting, procession or gathering, he disturbs or interrupts it.
(2-1)
903 - 1972, Dec. 6, P.L.
2709 - 1972, Dec. 6, P.L.
2906 - 1972, Dec. 6, P.L.
3105 - 1972, Dec. 6, P.L.
4305 - 1972, Dec. 6, P.L.
4952 - 1972, Dec. 6, P.L.
5101 - 1972, Dec. 6, P.L.
5108 - 1972, Dec. 6, P.L.
5508 - 1972, Dec. 6, P.L.
1482, No. 334, 1, effective June 6, 1973.
1482, No. 334, 1, effective June 6, 1973.
1482, No. 334, 1, effective June 6, 1973.
1482, No. 334, 1, effective June 6, 1973.
1482, No. 334, 1, effective June 6, 1973.
1482, No. 334, 1, effective June 6, 1973.
1482, No. 334, 1, effective June 6, 1973.
1482, No. 334, 1, effective June 6, 1973.
1482, No. 334, 1, effective June 6, 1973.
I, Cory Cormany, hereby verify that the facts set forth in the above are true
and correct to the best of my knowledge or information and belief and that any
false statements herein are made subject to the penalties of Section 4904 of the
Crimes Code (18 Pa. C.S. 4904), relating to unsworn falsification to authorities.
Dated L f/11 31« rd By?,
Cory A. Cormany
(3-1)
INCIDENT REPORT
Criminal Solicitation: In that Tina Adams and Hubert Gilroy did knowingly and
intentionally promote and facilitate the commission of a crime requesting another
to attempt the complicity encouraged a Defendant. Criminal Coercion: In that the
Defendants did coerce the unlawful restricted freedom of action of another,
threatening to commit a criminal offense while exposing secrets subjugated a
hatred, and liable an official action. Harassment: In that the Defendants did annoy
and alarm a person repeatedly threatening physical contact in and about an official
intention which served no legitimate purpose. Prompt Complaint: In that the
Defendants did subject indecent conduct questionable an authority, or guardian,
which did fail an official report. Dealing in Infant Children: In that the
Defendants did deal in a humanitarian trade by buying a custodial obligation
substantial an infant child. Intimidation of Witness or Victims: In that the
Defendants did pronounce an official action and official document misleading
official action and the reporting to law enforcement officials the hindrance of a
minor child and the unlawful uses of illegal narcotics. Obstructing Administration
of Law or Other Governmental Function: In that the ]Defendants did interfere and
pervert a physical obstacle breaching an official document affirmative an action,
and liable a governmental function. Compounding: In that the Defendants did
accept pecuniary benefits considerate an information, and reportorial the suspected
commission of a crime. Disrupting Meetings and Processions: In that the
Defendants did intentionally prevent and disturb conversations and meetings
between two legally abounded individuals interruptive a custodial document.
I petition that a warrant of arrest or a summons be issued and that the
Defendant be required to answer the charges I have made. I verify that the facts
set forth in this complaint are true and correct to the best of my knowledge or
information and belief. This verification is made subject to the penalties of
Section 4904 of the Crimes Code (18 Pa. C.S. 4904), relating to unsworn
falsification to authorities.
/13
1 c?, `i
Dated
Signature
Dated
(1-2) NOTARIAL SEAL
JODY S. SMITH, NOTARY PUBLIC
Wdr \ oj-- Cck SU``bS( k +6 b&rp AQ, Carlisle Boro, Cumberland County
My Commission Expires April 4, 2005 ?
J6 A/
AFFIDAVIT
On June 21, 1992, I, Cory A. Cormany, did proceed established visitation
regarding my said minor child at said residential environment, and was denied
according to the whereabouts of the said natural chill. Proceeding incident, I did
proceed an argumentative situation and circumstance with the said minor child's
mother, the Defendant Tina Adams.
On November 7, 1992, I, Cory A. Cormany, did proceed established
visitation regarding my said minor child at said residential environment, and was
denied according to the whereabouts of the said natural child. Proceeding such
noncommunicative relations, I did proceed established visitation for my said
minor child on November 20, 1992, and did again find residential vacancy.
On April 1, 1994, I, Cory A. Cormany, did proceed established visitation
regarding my said minor child at said residential environment, and was denied
according to the whereabouts of the said natural child. Preceding such incident
Defendant Tina Adams did relocate the said residential environment restricting
criminal action, and did marry an adult male.
Before or about the aforesaid date and time, mentioned in the aforesaid
paragraph, the Defendant Tina Adams did suppress evidential indulgences later
verificative my recognition, and knowledge; substantial the civil case number
LCV-95-0844, and did interfere and deliberately cause, and pervert a breach in an
official governmental function. The Defendant did prevent and disrupt affirmative
meetings and gatherings documented an obstacle, and necessary a maintenance;
pursuant the Commonwealth of Pennsylvania.
In May of the year 1993 and through and about August of the year 1994, I,
Cory A. Cormany, did resume the disposition of the order of the court announcing
supervised visitation through the Children & Youth Service Centers. Proceeding
such times and events, irrelated the docketed visitation establishments; my said
minor child would receive enfranchised reminiscences, up and until approximately
December of the year 2003. During and through these foregoing time periods my
said relatives did exercise discretion in and about a consideration, obedient the
order of the court. I did submit correspondence, resourceful an official procedure;
developing consensual obligations preprietorial the Court of Cumberland County.
Such objects did indicate a consensual agreement[s] accusive the Defendant
Hubert Gilroy and a Mr. John Adams; who 'did infac:t threaten me by mail and
prescient thereto my person.
In the year 2004 and pursuant therein and prior thereto, I; Cory A.
Cormany, was informed by a relative of illegal oppositions. involved the
Defendant Tina Adams, pursuant my witnessing Mr. John Adams; Present
(1-3)
Husband, conspiring illicit applications outside or hereto my place of residence.
Ms. Tina Adams did indulge in the nonconsensual buying and selling of a minor
child with the Defendant Hubert Gilroy, whom both did accept monetary sums
and peculiar benefits. I did infact petition visitation to the said minor child's
mother interruptive an official informative service, foregoing an employable
outcome; cautious mental health issues. Such opportunity is prejudicially pursuant
the case number 64 in Orphans Court Division.
In March of the year 2004 and through and about a problematic legal
judgment, I, Cory A. Cormany, did pursue a sheriff service knowledgeable of the
present whereabouts, careful the said minor child's concerns, and indigent an
extenuating object endeavored an employment or affirmative legal imposition.
The Defendant Tina Adams has continually nonnegu fated and solicited situations
and circumstances contemptual a deceptive relation mandatory a civil action. Ms.
Tina Adams has procrastinated important issues obslructional myself in the years
1994, 1996, 1997 and 2002 beneficial a criminal outcome and suspicious an
informative indecent conduct.
I, Cory A. Cormany, on this ,3.1t, day of of the year
2004, do hereby swear as a citizen and a voter of the Commonwealth of the
United States that the above facts are true and correct to the best of my knowledge
and belief.
Cory A. Cormany
Dated
Sworn O-n? A?a_
t3z Io- Acj 6? 7--8y--r t Zoo (-! , 61)
S &?A V
NOTARIAL SEAL a
JODY S. SMITH. NOTARY PUBLIC
Ex es County
Carlisle Bor ioCum
es April 4. 2005 :
I My Comm{ss p
Witness
EXHIBIT
D
X12)
CORY A. CORMANY, IN THE COURT OF COMMONPLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
TINA D. ADAMS,
Defendant NO. 03-1876 CIVIL TERM
IN RE: PRELIMINARY OBJECTIONS OF
DEFENDANT TO PLAINTIFF'S COMPLAINT
BEFORE HOFFER, P.J., and C?LER, J.
ORDER OF COURT
AND NOW, this 19th day of May, 2004, upon consideration of Defendant's
preliminary objections to Plaintiffs complaint, and for the reasons stated in the
accompanying opinion, service upon Defendant is set aside, without prejudice to
Defendant's right to timely pursue other appropriate preliminary objections in the
event that Plaintiff causes Defendant to be subjected to personal jurisdiction of the
court.
BY THE COURT,
Wesley GG-r Jr., J.
C9Fy A. Cormany
83 Douglas Drive
Carlisle, PA 17013
Plaintiff, pro se
Christian F. Rhodes, Esq.
Susquehanna Commerce
Center East
221 W. Philadelphia Street
Suite E600
York, PA 17404
Attorney for Defendant
CORY A. CORMANY, : IN THE COURT OF COMMONPLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
TINA D. ADAMS,
Defendant NO. 03-1876 CIVIL TERM
IN RE: PRELIMINARY OBJECTIONS OF
DEFENDANT TO PLAINTIFF'S COMPLAINT
BEFORE HOFFER, P.J., and OLER, J.
OPINION and ORDER OF COURT
OLER, J., May 19, 2004.
For disposition in this civil case in which a pro se Plaintiff has sued his
former wife' are preliminary objections filed by Defendant to Plaintiff's
complaint. The preliminary objections include an objection based upon improper
service?
Defendant's preliminary objections were argued before the above court en
banc on April 21, 2004.3 For the reasons stated in this opinion, Defendant's
preliminary objection based upon improper service of the complaint will be
sustained, and the service will be set aside.
STATEMENT OF FACTS
Plaintiff is identified in his complaint as "an adult individual residing in
Cumberland County, Pennsylvania."4 Defendant is similarly identified in the
complaint as "an adult individual residing in Cumberland County, Pennsylvania.i5
1 See Plaintiff's Complaint, para. 12.
2 See Defendant's Preliminary Objections to Plaintiff's Complaint, para. 2; Pa. KC.P. 1028(a)(1).
3 Plaintiff neither filed a brief nor appeared for the argument.
a Plaintiff's Complaint, para. 1.
5 Plaintiff's Complaint, para. 2.
Plaintiff's complaint appears to be related to a failure of a McDonald's
restaurant franchisee (for which his former wife worked) to employ him.'
Representative of the largely unintelligible allegations in the complaint are these:
8. To or about the month of April of the year
2001, the plaintiff did retain and service an
employment application at the Ames Dept. Stores of
Carlisle, the Old M.J. Mall location, foregoing a timely
full-time employment.
9. Preceding the issues described in the
aforementioned statements, the plaintiff, Cory A.
Cormany, did achieve and retain employment
opportunity at the McDonalds Co. of Carlisle, non
faulted an expiry period, obligatory a minor child;
(Alexandria Christine).
10. In or about the month of September of the
year 2002, the plaintiff did sustain an employment
application at the McDonalds Co. of Carlisle,
argumentative several entailed locations, liberal a
documentation.
12. Pursuant the foregoing business the
defendant, Tina D. Adams, did divorce the plaintiff,
Cory A. Cormany, allegorical an alcohol/driving issue;
nonreliable a vehicle and a decree, and did marry a
convicted narcotics offender, substantial an equal
opportunity employer.
Defendant indicates that Plaintiff's complaint was served by certified mail.8
No sheriff's return appears in the record.
DISCUSSION
Under Pennsylvania Rule of Civil Procedure 400(a), as a general rule
"original process shall be served within the Commonwealth only by the sheriff."
As has been stated by the Pennsylvania Superior Court, "[rlegardless of whether
6 See Plaintiff's Complaint, paras. 13-14.
7 Plaintiffs Complaint, paras. 8-10, 12.
8 Defendant's Preliminary Objections to Plaintiff's Complaint, para. 2.
2
the action is commenced by writ of summons or where, as here, the action is
commenced by a complaint, service of process is essential to commencing the
action. Proper service is a prerequisite to a court acquiring personal jurisdiction
over a defendant." Ramsay v. Pierre, 822 A.2d 85, 89 (Pa. Super. 2003).
Where service is improper, it may be set aside. Collins v. Park, 423 Pa.
Super. 601, 621 A.2d 996 (1993). Accordingly, the following order will be
entered:
ORDER OF COURT
AND NOW, this 19a' day of May, 2004, upon consideration of Defendant's
preliminary objections to Plaintiffs complaint, and for the reasons stated in the
accompanying opinion, service upon Defendant is set aside, without prejudice to
Defendant's right to timely pursue other appropriate preliminary objections in the
event that Plaintiff causes Defendant to be subjected 1:0 personal jurisdiction of the
court.
BY THE COURT,
s/ J. Wesley Oler, Jr.
J. Wesley Oler, Jr., J.
Cory A. Cormany
1883 Douglas Drive
Carlisle, PA 17013
Plaintiff, pro se
Christian F. Rhodes, Esq.
Susquehanna Commerce
Center East
221 W. Philadelphia Street
Suite E600
York, PA 17404
Attorney for Defendant
3
EXHIBIT
E
(13)
r 1 S- r ?a rdL JE OER
ATTORNEYS AT LAW
STOCK AND LEADER LLP
D. REED ANDERSON
JOHN J. SHORB
WILUAM C GTERASCH, JR.
W. BRUCE WAE.LACE
MRHA+s W. KM
1R40rm P. RUTH
Wn1.uM I HAW
StEFHEx S. Russ u
THOMAS M SHORE
RONAED L HE WINER
JANE H. SanEssam
STEVEN M. HOVIS
JODY ANDERSON LMMnle
'AlSD AVMRTW IN MARYLAM
SUSQUEHANNA COMMERCE CENTER EAST
221 W. PHILADELPHIA STRERT-SUTM 600
YORK, PENNSYLVANIA 17404
PHONE (717) 846-9800
FAX (717) 843-6134
www.stockandleadercom
Direct Dial. (717) 849-4135
E-Mail Address: truth astockandleader.com
Cory A. Cormany
1883 Douglas Drive
Carlisle, PA 17013
March 19, 2004
STOac AND LEADER,
A PHOP?IpNAL CORPORATION
HENRY B. LEADER
J. Ross MCGDaw
RAYMOND L Hovs
BYRON H. LECATIS
MARIETTA H. BARD=
NELA. SIENRsE
MBT.nvOA B. KAUFMANN
DAVID A. JONES II
FRANK A. NARDO, JR.
EREN J. Mums
CRESTIAN R RHODES
MCCLEAN ST=
(1881-1962)
BASL A. SHORE
(1910-1988)
Re: Cory A. Cormany v. Tina D. Adams
Case No. 03-1876
In the Court of Common Pleas of Cumberland County, Pennsylvania
Dear Mr. Cormany:
Enclosed please find certified copies of the following documents which were filed today in
the above-referenced matter:
1. Defendant's Preliminary Objections to Plaintiff's Complaint;
2. Defendant's Memorandum of Law in Support of her Preliminary Objections;
3. Praecipe for entry of Appearance; and
4. Praecipe for Listing Case for Argument.
I. am hereby serving these upon you pursuant to the Pennsylvania Rules of Civil Procedure.
Very truly yours,
STOCK AND LEADER
Christian F. Rhodes
CFR/kb
Enclosures
cc: Alissa L. Gilfand, Esquire (w/enclosures)
IAUSERS\KB\TPR\KENMAR\Cormany Svc Itr.doc
BROCK.dLEADIR
ATTORNEYS AT LAW
91= AND LEADER UY
D. Rte ANDERSON
JOHN J. SHORE
WauAM C. G= ASCH, JR.
W. BRUCe WAUACE
N&MAEL W. KRac
TbAOM P. Rust
WwAM T. HAST
9r? S. RUSML
THOMAS M. SHM
RONALD L Hm mom
JANE 1•L SaWStUM
sum N. Hoes
JODY ANDm M L FOril "
NEE. A. SUNIZ e
`ALSO AaUrrTEV iNMARTLIND
SUSQUEHANNA COMMERCE CENTER EAST
221 W. PHRADVIXHA STREET-SUITE 600
YORY, PENNSYLVANIA 17404
PHONE (717) 846-9800
FAX (717) 843-6134
www.stockandleader.com
December 20, 2004
STOCic AND LEADmy
A PROF?oNM. CORPORA17oN
Harm B. LEADER
J. Roes McGwm
RAYMOND I- Hoes
BYRON H. LECATES
NARB3ITA H. BARBOUR
MELMA B. KMMMAM
DAVID A. JOM II
ERw J. MxM
RICHARD K. LAWS
NCCLEAN %=
(1881-1%2)
BASE. A. SHORE
(1910-1988)
Direct Dial: (717) 8494135
E-Mail Address: truthastockandleader.com
Cory A. Cormany
1883 Douglas Drive
Carlisle, PA 17013
Re: Cormany v. Tina D. Adams
No. 03-1876
In the Court of Common Pleas of Cumberland County, Pennsylvania
Dear Mr. Cormany:
Enclosed please find a certified, clocked-in copy of Defendant's Preliminary Objections
and the Affidavit of Tina Sauter filed on behalf of the Defendant on December 14, 2004, in the
above matter. I am hereby serving these upon you pursuant to the Pennsylvania Rules of Civil
Procedure and the Cumberland County Rules of Procedure.
I am also enclosing with this letter a copy of the Praecipe for Listing Case for Argument,
which I have filed with the Court by mail this date.
Very truly yours,
STOCK AND LEADER
( ;M' e..4
Timothy P.
TPR/kb
Enclosures
cc: Alissa L. Gilfand, Esquire (w/copies of encl.)
IAUSERS\KBITPRIKENMAR1Cormany Svc lu2.doc
BROUJOS & GILROY, P .c.
ATTORNEY'S AT LAW
JOHN H. BROUJOS 4 NORTH HANOVER STREET TELEPHONE: (717) 243-4574
HUBERr X. GnitoY CARr.is E, PENNSYLVANIA 1707.3 FAcsimrm (717) 243-8227
jbroujos®bmujosgdwy_com
hgi1roy0br°u4o9gi1roycom
NON-TOLL FOR HARRISBURG AREA
717-766-1690
December 13, 2004
Linda Klinger, Counselor
Stevens Human Services
33 State Avenue
Carlisle, PA 17013
Dear Miss Klinger:
Please be advised that our office represents Miss Tina Adams.
Enclosed is a letter Miss Adams received from her former husband, Cory A.
Cormany, directing Miss Adams to appear at your office on Friday, December 20te,
with regards to Alexandria Adams.
Please be advised that Miss Adams has no intention whatsoever of appearing in
your office with regards to any matters that Mr. Cormany initiates. Furthermore,
be advised that Mr. Cormany is not the father of Alexandria Adams. Mr.
Cormany's parental rights to Alexandria were terminated a number of years ago.
In summary he has no legal rights or obligations with respect to Alexandria.
Should you have any questions in this matter, please feel free to contact me.
I request that you do not contact Miss Adams either at her home or at her place of
employment.
Sincerely yours,
4G'
Hubert X. Gilroy
srb
cc: Tina Adams
Cory A. Cormany
DEG-13-2004 10:22 PM
Levine Enterprises, Inc.
etc an?a?
FAX
Date: o?-A
To:
P.01
123 South Pitt Street
Carlisle PA, 17013
Phone: 717-240•.0854
Fax: 717-249-2210
Fax Number: t?'4 3 - FSa a
Number Of .'Pages: "4 -- ` Q
w
Comments :
EXHIBIT
F
(14)
Cory A. Cormany
1883 Douglas Dr.
Carlisle, Pa. 17013
(717)3859196
December 21st, 2004
Ms. Alexandria Christine, Student
143 Kerrs Rd.
Carlisle, Pa. 17013
Dear Alexandria,
Kindly find enclosed a money order. 1 wanted to give you a Christmas
Present; however, unfortunately I must of missed you? Please be advised that I
have contacted the Cumberland County District Attorney's Office in regards to
The Stevens Human Service Facility. Also enclosed is a poem I wrote once,
"somebody" told me I should let you read- it? Please retain an interest in you
school studies, and hopefully I will be in touch soon again.
Very Truly Yours,
Cory A. Cormany
CAC
cc: Mr. Jeffrey Franks
Cory A. Cormany
1883 Douglas Dr.
Carlisle, Pa. 17013
(717)385-9196
December 21st, 2004
Ms. Linda Klinger, Counselor
33 State Avenue
Carlisle, Pa. 17013
Dear Linda,
Kindly find enclosed a copy of the current civil file Mr. Gilroy is handling
for Alexandria Christine, relevant her social security number and the Health and
Safety Commission of Pennsylvania. I shall copy the recommendation of Judge
Oler and the vital record consideration as previously discussed; which I shall
iterate, was never officially ,serviced unto me.
Very Truly Yours,
Cory A. Cormany
CAC
cc: Mr. Jeffrey Franks
(1)
Cory A. Cormany
1883 Douglas Dr.
Carlisle, Pa. 17013
(717)385-9196
December 21 st, 2004
Ms. Karen Lee, Counselor
Big Spring School District
45 Mt. Rock Road
Newville, Pa. 17241
Dear Ms. Lee,
Kindly find enclosed a copy of a letter I have writen to Detective Franks of
the Cumberland County District Attorney's Office, along with a copy. of the
oringinal divorce agreement. I may hope theorical ramifications maybe resolved
pursuant The Stevens Mental Health Facility.
Very Truly Yours,
Cory A. Cormany
CAC
cc: Mr. Jeffrey Franks
(1)
Cory A. Cormany
1883 Douglas Dr.
Carlisle, Pa. 17013
(717)385-9196
December 21 st, 2004
Mr. Skip Ebert, DistrictAttorney
Cumberland County Court Hoouse
1 South Hanover Street
Carlisle, Pa. 17013
Dear Mr. Ebert,
Kindly find enclosed a copy of the issues I sent to Detective Franks of the
Cumberland County District Attorney's Office. I appreciate any knowledgable
input you may have in light of civil or criminal objectivity. 1 simply would like to
visit with my child as per original agreement. I shall be in contact with Mr.
Michael Sherer and Ms. Frances DelDuca pursuant the upcoming year. I am sorry
to question consensual objects substantial the order of the court?
Very Truly Yours,
Cory A. Cormany
CAC
cc: Mr. Jeffrey Franks
(1)
Cory A. Cormany
1883 Douglas Dr.
Carlisle, Pa. 17013
(717)385-9196
December 21 st, 2004
Mr. Jeffrey Franks, Detective
Cumberland County Court Hoouse
1 South Hanover Street
Carlisle, Pa. 17013
Dear Mr. Franks,
Kindly find enclosed several letters I wrote relevant The Stevens Human
Services. I feel such hinderances to be directly pertinent Mr. Hubert Gilroy and
Ms. Tina Adams in light o- f Alexandria Christine Cormany's (Adams)
consideration? I have noted a letter to District Attorney Skip Ebert for the purpose
of a consensual investigation for relevant matters involved a rearranged visitation
as in compliance with decree and order of the court. '.Please feel free to contact me
at the above listed address and/or telephone number for the object of prosecution.
I am scheduled pursuant The Stevens Center for fat-nily and/or Drug & Alcohol
counseling on January 7th and January 10th of the year 2005.
Very Truly Yours,
Cory A. Cormany
CAC
cc: Mr. Skip Ebert
Ms. Linda Klinger
Ms. Karen Lee
Ms. Alexandria Christine
(1)
Cory A. Cormany
1883 Douglas Dr.
Carlisle, Pa. 17013
(717)385-9196
January 4th, 2004
Ms. Linda Klinger, Counselor
Stevens Human Services
33 State Ave.
Carlisle, Pa. 17013
Dear Ms. Klinger,
Kindly find enclosed a copy of the appointment notices I have sent
regarding Ms. Alexandria Christine (Cormany) and Ms. Tina Doreen Adams. I
thankyou for your attention.
Very Truly Yours,
Cory A. Cormany
CAC
cc: Ms. Tina Adams
Ms. Alexandria Christine
Ms. Karen Lee
Mr. Skip Ebert
(1)
Cory A. Cormany
1883 Douglas Dr.
Carlisle, Pa. 17013
(717)385-9196
January 4th, 2004
Ms. Karen Lee, Counselor
Big Spring School District
45 Mt. Rock Road
Newville, Pa. 17241
Dear Ms. Lee,
Kindly find enclosed a copy of the appointment notices I have sent
regarding Ms. Alexandria Christine (Cormany) and Ms. Tina Doreen Adams. I
thankyou for your attention.
Very Truly Yours,
Cory A. Cormany
CAC
cc: Ms. Tina Adams
Ms. Alexandria Christine
Ms. Linda Klinger
Mr. Skip Ebert
(1)
Cory A. Cormany
1883 Douglas Dr.
Carlisle, Pa. 17013
(717)385-9196
January 4th, 2004
Ms. Tina Adams, Mother
145 Kerrs Rd.
Carlisle, Pa. 17013
Dear Ms. Adams,
Please see it appropriate to reaquire appointment at The Stevens Human
Services of Carlisle, Pennsylvania; on or about January 10th, 2005 at or about
4:00 PM for the purpose of Alexandria Christine. I thankyou for your attention.
Very Truly Yours,
Cory A. Cormany
CAC
cc: Ms. Alexandria Christine
Ms. Linda Klinger
Ms. Karen Lee
Mr. Kenneth Levine
Mr. Skip Ebert
(1)
Cory A. Cormany
1883 Douglas Dr.
Carlisle, Pa. 17013
(717)385-9196
January 4th, 2004
Ms. Alexandria Christine, Daughter
145 Kerrs Rd.
• Carlisle, Pa. 17013
Dear Alexandria,
Please see it appropriate to attend appointment with your mother at The
Stevens Human Services of Carlisle, Pennsylvania; on or about January 10th,
2005 at or about 4:00 PM for the purpose of visitation. I thankyou for your
attention.
Very Truly Yours,
Cory A. Cormany
CAC
cc: Ms. Tina Adams
Ms. Linda Klinger
Ms. Karen Lee
Mr. Kenneth Levine
Mr. Skip Ebert
(1)
Cory A. Cormany
1883 Douglas Dr.
Carlisle, Pa. 17013
(717)385-9196
January 4th, 2004
Mr. Skip Ebert, District Attorney
Cumberland County Court House
1 South Hanover St.
Carlisle, Pa. 17013
Dear Mr. Ebert,
Kindly find enclosed a copy of the civil rarnification relevant Levine
Enterprises. I thankyou for your attention.
Very Truly Yours,
Cory A. Cormany
CAC
cc: Ms. Tina Adams
Ms. Alexandria Christine
Ms. Linda Klinger
Ms. Karen Lee
Mr. Kenneth Levine
(1)
EXHIBIT
Noteworthy Question
(1)
CERTIFICATION OF SERVICE
AND NOW, this day of
2005, I, Cory A. Cormany
foregoing the aforesaid matter knowledgeable a legal pretext, and the
Commonwealth of Pennsylvania, hereby certify that I have served a copy of same
in person or by the United States Mail at Carlisle Pennsylvania, addressed as
follows:
C/O Mr. Ken Levine
Ms. Tina D. Adams
McDonalds Company
123 South Pitt Street
Carlisle, PA 17013
Mr.Timothy Ruth
Stock & Leader
221 W. Philadelphia St.
Ste. E600
York, PA 17404
Ms. Yvette Hientzelman
Seyfarth Shaw LLP
55 East Monore Street
Chicago, IL 60603
Cory A. Cormany
1883 Douglas Dr.'
Carlisle, PA 17013
(15)
r- c-r
';'7 T77
l? J T rl
-c n?
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
THE COMMONWEALTH OF PENNSYLVANIA
CORY A. CORMANY CASE NO. 03-1876
V. CIVIL ACTION - LAW
TINA D. ADAMS JMY TRIAL DEMANDED
MOTION TO DISMISS
Respectfully Submitted;
4CA21i'ste?r?Cormany
(A)
FEB ®12005
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
THE COMMONWEALTH OF PENNSYLVANIA
CORY A. CORMANY
V.
TINA D. ADAMS
CASE NO. 03-1876
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
BRIEF IN SUPPORT OF MOTION FOR DISMISSAL
1. PROCEDURAL HISTORY/FACTUAL STATEMENT
On April 23rd of the year 2003, the plaintiff filed a Common Pleas
Complaint in Cumberland County. Pursuant such filing the defendant responded.
The plaintiff pursued another Common Pleas Complaint in Cumberland County
against another defendant named; Mr. Kenneth Levine. The said Defendant
Levine did not respond as in accordance to rule of procedure. On May 19th of the
year 2004; the Honorable Judge Oler dismissed the initial complaint[s] filed
against the defendants. The Plaintiff Cory A. Cormany than filed an Amended
Complaint against the Defendant Tina D. Adams on September 10th of the year
2004.
(1)
II. QUESTIONS PRESENTED FOR REVIEW
1. Whether there is sufficient evidence to sustain demurrer.
2. Whether there is sufficient evidence to sustain judgment.
3. Whether there are criminal objects supporting a judgment.
4. Whether there are criminal elements relevant a civil filing.
5. Whether there are prejudicial elements relevant a civil filing.
(2)
III. ARGUMENT
And Now, comes Cory Alister Cormany, Plaintiff; who respectfully
requests the Commonwealth of Pennsylvania to recognize dismissal as in
accordance with local, state and federal rule of civil procedure, and constitutional
a duplicative collateral estoppel. The primary [demurrer] is "argumentative" a
(sworn statement) and the subject of `service'.
The principal argument[s] is set forth in the defendant's and plaintiff's
Preliminary Objections set forth on January 4th, and iterated thereto January 13th,
2005. The defense argues Penn. R. Civ. P. 1028(a)(4), with prejudice; pursuant
the Commonwealth of Pennsylvania and `the Order of the Court'. The
complaintant argues Penn. R. Civ. P. 1602 and the object[s] of Joinder and future
Complaint. Claimants right of action for damages against city accrued when his
wife died as result of police officer's alleged negligence, and r t could not divert
claimant of his v s ed right by retroactively applying `ordinance' repealing waiver
of governmental immunity to pending action: 53 P.S. 5311. 101-5311. 803
(Repealed). City of Philadelphia v. Patton, 609 A.2d. 903. At same for the
purpose of reason: Although `taxing' ordinance must be strictly construed
language of local ordinances, like that of state statutes, should be given their plain
meaning. Lawrence G. Spielvo gel, Inc. v. Township of Cheltenham, 601 A.2d.
1310, 144 Pa. Comwlth. 510. Extenuating issues questionable the [object] of
(3)
complaint may pursue a financial servitude. Under Pennsylvania bonding law,
language in construction payment and executed by prime contractor in favor of
city, providing cause of action on the bond to every person who, whether as
subcontractor "or otherwise" furnished material or services on `project', would
be read expansively to confer standing to bring such action on subcontractor to
no
a subcontractor that is a subcontractor three levels removed from prime contract
"or otherwise" merely meant that materialman as well as subcontractor come with
in ambit of the bond. 8 P.S. 191 et. seq., 193(a)(2) 194(b). Nicholson Const. Co.
v. Standard Fire Ins. Co., 760 F.2d. 74,
The controversial objective [is] proclaimed in the Memorandum of Law set
forth by Ms. Tina Sauter. After being duly sworn the "defense's attorney[s]; as
professed to be ({one[s]})"; seem to recognize F.I.C.A., Federal Supplement, and
state and local taxable malfeasancies. The complaintant [does] `know' the.
following:
A) The first "Sworn Statement" and "Verification" contains the name of
a (person) - Walt Jawinski - who has not worked for Levine Enterprises since the
early 1990's and whose last name is spelled incorrectly. His last name is
Karczewski.
B) The second "Sworn Statement" and "Verification" contains the name
of a (person) - Annett Jones - who has not worked for Levine Enterprises since
2002. In addition, the witness's first name is spelled incorrectly - it should be
spelled "Annette." Finally; this former employee got divorced and went by her
(4)
maiden name - Snyder - through most of her employment with Levine
Enterprises. "Jones" was her married name.
C) The third "Sworn Statement" and "Verification" contains the name of
a wi es - Nina Davis - who has never worked for Levine Enterprises.
D) The fourth "Sworn Statement" and "Verification" contains the name
of a witness - Susan Starner - who never worked for Levine Enterprises.
E) The fifth "Sworn Statement" and "Verification" contains the name of
a witness - Eugene Foley - who never worked for Levine Enterprises. Levine
Enterprises did employ a person named Mark E. Foley at one point, but nQt
"Eugene Foley."
F) The sixth "Sworn Statement" and "Verification" contains the name of
a `wit s' - Thomas Minic - whose worked for Levine Enterprises through a
prison work release program for a short time and left the Company in 2002.
Additionally the witness's last name is spelled incorrectly. His last name is spelled
"Minnick."
Conclusive `elements {litigated a (joinder]', remain inapposite} complaints
pursuant; Cormany v. Cormany and Cormany v. Gilroy and Adams. City's
homeless service contracts constituted form of "professional services" exempt
from competitive bidding requirement under city charter. Lieberman Organization
v. City of Philadelphia, 595 A.2d. 638, 141 Pa. Comwlth. 9, appeal granted 582
A.2d. 326, 525 Pa. 660, affirmed 589 A.2d. 1111, 527 Pa. 206. Such
`Professional Services' fare] prepondatory The Stevens Mental Health Center, and
(5)
Biological Rightful Agreements clearified The United States Social Security
Office, and The Pennsylvania Birth Registration Service (Health and Safety
Commission). See Pennsylvania Academy of Chiropractic Physicians v.
Department of State, Bureau of Professional & Occupational Affair, 129. Pa.
Commu. Ct. 12, 564 A.2d. 551 (1989). Pursuant rule (1028)(a)(3) of the
Pennsylvania Rules of Civil Procedure: International Union of Operating
Engineers v. Linesville Construction Co., 457 Pa. 220, 322 A.2d. 353 (1974); a
demurrer will only be sustained where a complaint or pleading shows with
certainty that upon the facts averred the law will not permit the plaintiff to
recover. Rules of statutory constructions are applicable to both statutes and
ordinances. Ciavarella v. Zoning Bd. of Adjustment of Hazie Tp., 484 A.2d. 420,
86 Pa. Comwlth. 193. See attached exhibit and also particular; letters to Tina
Adams and Alexandria Cormany, as well as biological registration and consensual
obligation.
Respectfully Submitted;
C y Alister Corr ny
(6)
Office of the Prothonotary
Cumberland County
Carlisle, PA 17013
Curtis R. Long
Prothonotary
Cory A. Cormany '
1883 Douglas Drive
Carlisle, PA 17013
DATE: January 13, 2005,
TO: Mr. Cormany:
THIS IS TO NOTIFY YOU THAT CASE NUMBER 02-2770, Cory A. Cormany
VS. Abom & Kutulakis et al HAS BEEN LISTED FOR ARGUMENT ON February
2, 2005.
Cumberland County Argument Court Rules 210-1
through 210-14 shall be strictly enforced. If the issue
was listed for prior argument you must re-file your
brief as per Local Rule 210-11.
Curtis R. Lone
Prothonotary
EMPLOYMENT TRAINING AND
EXPERIENCE SUMMARY
1. MCDONALDS OPENING PROCEDURES
A) Front Line C) Stocking/Truck
B) Grill Section D) Maintenance
2. MCDONALDS CLOSING PROCEDURES
A) Front Line C) Backroom/Parts
B) Grill Section D) Maintenance
3. MCDONALDS DAILY OPERATIONS
A) Front Line C) Lobby/Drive Through
B) Grill Section D) Maintenance
4. MCDONALDS EQUIPMENT KNOWLEDGE
A) Front Line C) Fryers/Walk-ins
B) Grill Section D) Maintenance
5. MCDONALDS MANAGERIAL POLICIES
A) Front Line C) Opening/Closing
B) Grill Section D) Maintenance
6. MCDONALDS ADVERTISING POLICIES
A) Front Line C) Promo Sales/Menu
B) Grill Section D) Maintenance
7. MCDONALDS RESOURCE POLICIES
A) Front Line C) References/McCopco
B) Grill Section D) Customers
8. SPECIAL DETAILS
A) As Assigned
(1)
4-00 , 0p
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF HEALTH
BIOLOGICAL PARENT REGISTRATION IDENTIFICATION FORM
Each biological parent desiring to register must file a separate form with the Division of Vital Records, P.O. Box 1528, New
Castle, PA 16101
(Month. Day. Year)
4a. HOSPITAL. NAME (U r tzspital, give street b m) 4b. CITY, BORO. OR I4t,
CHILD'S TOWNSHIP OF BIRTH
PERSONAL
DATA 5. MOTHER'S MAIDEN NAME (First. Middle, Last)
6. IF KNOWN, LIST COURT, DOCKET NUMBER. COUNTY, STATE. AND DATE OF ADOPTION
Pursuant to Act 1984-195 [23 Pa. C.S. § 29051 and 28 Pa. Code § 1.49, a biological parent voluntarily completing and filing
this form with the Department of Health requests the Department to release the identifying information to the adoptee,
adoptive parents, or legal guardian upon request. Information on the Certificate of Live Birth will be released only if both
biological parents have completed and have on file a valid consent form.
If there is a change of address, a new form should be completed by the biological parent. At any time a biological parent(s)
may revoke the release of identifying information by contacting the Department of Health and completing and filing 'the
necessary forms.
AFFIDAVIT
OF
BIOLOGICAL
PARENT
Being duly sworn or by solemn affirmation, I state that I am the biological parent of the above child
and do hereby authorize the Department of Health to release the following information upon request
of the adoptee it eighteen (18) years of age or older, or if less than eighteen (18) years of age, to the
adoptive parent or legal guardian:
Signature of Biological Parent
Current Name of Biological Parent
(Please Print)
Complete Address
(Please Prii it)
Sworn (or afi!rrned) before me and subscribed in my presence th s day of
19._.._ by the person whose signature appears above and whose Identity is
SEAL
either personally known to me or satisfactorily proven to me
$iGNATJRE Cr p£FiCiAt ACM N Sl EP1NG OATH
Please use stamp or print name, municipality, county, and commission expiration date beiov,
r°OR DEPARTMENT OF HEALTH USE ONLY.
.
Cory A. Cormany
1883 Douglas Dr.
Carlisle, Pa. 17013
(717)385-9196
February 22nd, 2005
Ms. Alexandria Adams; Sibling
C/O Mr. Hubert Gilroy
4 North Hanover St.
Carlisle, Pa. 17013
Dear Alexandria;
Kindly find enclosed a copy of a Subpoena, along with a Civil Action for
the purpose of a characterized witness. Please additionally note a scheduled
appointment pursuant The Stevens Mental Health Center on or about February
28th of the year 2005; at or about 3:00 PM. This shall be my last appointment
and attempt to notify. I am sorry I have missed you.
Very Truly Yours,
Cory A. Cormany
P.S. Correction: Previous letter is noted as 2004 at or about January 4th; this is
2005 as corrected herein.
CAC
cc: Ms. Tina Adams
Mr. Hubert Gilroy
Mr. Skip Ebert
Mr. Anthony Adams
Mr. Dominick Nardone
(1)
Cory A. Cormany
1883 Douglas Dr.
Carlisle, Pa. 17013
(717)385-9196
February 22nd, 2005
Ms. Tina Adams; Ex-wife
C/O Mr. Hubert Gilroy
4 North Hanover St.
Carlisle, Pa. 17013
Dear Tina;
Kindly find enclosed a copy of a Subpoena, along with a Civil Action for
the purpose of a characterized witness. Please additionally note a scheduled
appointment pursuant The Stevens Mental Health Center on or about February
28th of the year 2005; at or about 3:00 PM. This shall be my last appointment
and attempt to notify. I thankyou for your attention.
Very Truly Yours,
Cory A. Cormany
P.S. Correction: Previous letter is noted as 2004 at or about January 4th; this is
2005 as corrected herein.
CAC
cc: Ms. Alexandria Adams
Mr. Hubert Gilroy
Mr. Skip Ebert
Mr. Anthony Adams
Mr. Dominick Nardone
(1)
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99`f TYYE COURT'OF COMMON P-r-EAS Of
C21MTERLAMD COrUM'Y
CORYA.CORMANY
V.
ALEXANDRIA C. CORMANY
CASE NO.
CINTL ACTION - LAW
JURYTRIAL DEMANDED
MOT7CE
You have been sued in Court. If you wish to defend against the claim set forth
in the following pages, you must take action within twenty (2o) days after the
Complaint and Notice are served by entering a written appearance personally or by
attorney and by filing.in writing with the Court your defense or objection to the
claims set forth against you. You are warned that if you fail to do so the case may
proceed without you and judgment maybe entered against you by the Court without
fin-ther notice for any money claimed in the Complaint or for any other claim or
relief requested by Plaintiff. You may lose money or property or other rights
importanttoyou.
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 CountyBar Association
Irvin Row
Carlisle, PA. i7or3
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
THE COMMONWEALTH OF PENNSYLVANIA
CORY A. CORMANY CASE NO. a 9- yos s" eu-J '7;1-
V. CIVIL ACTION - LAW
TINA D. ADAMS JURY TRIAL DEMANDED
NOTICE
You have been sued in Court. If you wish to defend
against the claim set forth in the following pages, you must
take action within twenty (20) days after the Complaint and
Notice are served by entering a written appearance
personally or by attorney and by filing in writing with the
Court your defense or objection to the claims set forth
against you. You are warned that if you fail to do so the
case may proceed without you and 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 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
1 South Hanover Street
Carlisle, PA. 17013 TRUE 007Y FI °IO!"i F1=1 `-F
in Ta±4, iir3rnI,y ?r ¢, i . tt. -:r.;' sei MV I
pp
ZZI
Prothonotary
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
THE COMMONWEALTH OF PENNSYLVANIA
CORY A. CORMANY CASE NO. oy--aO-5
V.
HUBERT X. GILROY
CIVIL ACTION - LAW
3UDGMENT DEMANDED
NOTICE
You have been sued in Court. If you wish to defend
against the claim set forth in the following pages, you must
take action within twenty (20) days after the Complaint and
Notice are served by entering a written pearance
personally or by attorney and by filing in writing with the
Court your defense or objection to the claims set forth
against you. You are warned that if you fail to do so the
case may proceed without you and 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 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
I South Hanover Street
Carlisle, PA. 17013 -TRUE COPY FROM RECORD
?n Testlrnony wile,eet, 1;were uriz set n, nand
and t tie seal of sa: Cv c st uruste..Y
Thi day o
"' pmthono
l*T
IN RE INT11E COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ADOPTION OF ORPHANS' COURT DIVISION
ALEXANDRIA CHRISTINE CORMANY NO. 64ADOP7ION 1993
C_ON?FNT TO Sjji<gSHAnOPTIOII;'
I, Tina Doreen Lightner (Adams), hereby certifies as follows:
1
1, Tina Doreen Lightner (Adams), currently reside at 145 Kerrs Road, NewviIle,
Cumberland County Pennsylvania.
2
My current age is 38,
3
My current marital status is that I am "tarried.
4
I am the mother of Alexandria Christine Cortnany.
5
The natural father of Alexandria Christine Cormany is Cory Alister Cormany.
6
I hereby voluntarily and unconditionally consent to the abolishment of the Adoption
of Alexandria Christine Cormany by John D. Adams Jr.
7
I understand that by signing this consent I indicate my intent to permanently take up
all rights of Alexandria Christine Connany.
8
I understand that Alexandria Christine Cormany will be eligible to visit with Cory
Mister Cormany.
9
I understand that I may not revoke this consent after a Court has entered a decree
confirming this consent or otherwise negotiated my parental rights to Alexandria
Christine Cormany, Even if a decree is entered terminating the right of John D. Adams
Jr. hereafter consenting the rights of Cory A. Cormany.
10
I have read and understand the above and I am signing it as a free and voluntary act.
Date
Tina Doreen Lightner (Adams)
Place of
signing :
We, the undersigned witnesses hereby certify that we are familiar with Tina Doreen
Lightner (Adams), and that we witness Tina Doreen Lightner (Adams) sign her
signature above at the place and date indicated.
WITNESS WITNESS
Signature Signature
Address
Address
Relationship Relationship
to Alexandria Christine Cormany to Alexandria Christine Cormany
iii 4 SI'OCK-LEADER
U„ ATTORNEYS AT LAW
ST AND Len LLP
D. REED ANDERSON
JOHN J. SHORE
WRLwm C. G?, JR.
W. BRUCE WALLACE
M&a L W. KE
TN= P Rv
Ww T. HAsr
STEerBN S. RUSSELL
THoMAs M. SHORR
RONALD L. HERSIEUER
JANE H. Sc ssuR
STEV@J M. Houk
JODY ANDERSON LEIGHrY"
PHE.tP H. STARE
NEE. A. SLENKER
'ALSOADMITTEDMMARYL NO
SUSQU1E NA COMMERCE CENTER EAST
221 W. PHILADELPHIA STREET-SURE 600
YORK, PENNSYLVANIA 17404
PHONE (717) 846-9800
FAx(717) 843.6134
www.stackandleader.com
January 13, 2005
Srou AND LEA m
A PEoEEaaNAL CD EADON
HENRY B. LEADER
). Ross McGnoas
RAYMOND L. HoV
BYRON H. LECAm
MARmTTA H. BARSOUR
DAV A. JoNRs B
ENN J. Mn RR
Run K. LAm
NATHAN C. PLATT
MCCLEAN sT
(1881-1962)
BASIL A. 5HORR
(1910-1988)
Direct Dial: (717) 849-4135
E-MailAddress: truth@stockandleader.com
Taryn N. Dixon
Cumberland County Court Administrator
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013-3387
Re: Cory A. Cormany v. Tina D. Adams
Case No. 03-1876
In the Court of Common Pleas of Cumberland County, Pennsylvania
Dear Ms. Dixon:
Enclosed please find two (2) copies of Defendant's Memorandum of Law in Support of
Preliminary Objections to Plaintiffs March 25, 2004 and September 10, 2004 Complaints in the
above matter. I am hereby filing them with your office in accordance with Rule 210-6 of the
Cumberland County Local Rules. This matter has been listed upon the February 2, 2005
Argument list.
Thank you very much for your attention to this matter. If you require anything further in
connection with the filing of this Memorandum, please contact me.
By copy of this letter, I am serving a copy of this Memorandum upon the Plaintiff. This
letter shall serve as certification of that service.
Very truly yours,
STOCK AND LEADER
rmothy
TPR/kb
Enclosures
cc: Cory A. Cormany (w/copy of encl.)
Alissa L. Gilfand, Esquire (w/copy of encl.)
1A7JSERS\KB\TPR\KENMAR\Cumb Co Ct Admin ItrAoc
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
THE COMMONWEALTH OF PENNSYLVANIA
CORY A. CORMANY
Plaintiff,
V.
TINA D. ADAMS
Defendant.
Case No. 03-1876
Civil Action - Law
Jury Trial Demanded
DEFENDANT'S MEMORANDUM OF LAW IN SUPPORT
OF HER PRELIMINARY OBJECTIONS TO PLAINTIFF'S
MARCH 25 2004 AND SEPTEMBER 10, 2004 COMPLAINTS
Defendant Tina D. Adams, by her attorneys, and pursuant to Penn. R. Civ. P. 1028(a)(4)
and 1028(f), hereby files this Memorandum of Law in Support of her Preliminary Objections to
Plaintiffs March 25, 2004 and September 10, 2004 Complaints.
BACKGROUND
Plaintiff Cory A. Cormany filed a complaint on or about April 23, 2003 claiming that he
was discriminatorily denied employment by his ex-wife, Defendant Tina D. Adams, Director of
Operations for Levine Enterprises, Inc., which owns a McDonald's restaurant in Carlisle, PA.
The Complaint was captioned, "Cory A. Cormany v. Tina D. Adams."
Plaintiff did not personally serve his complaint as required by Penn. R. Civ. P. 400, but
rather served it by certified mail on or about April 25, 2003. On March 19, 2004, Defendant
filed Preliminary Objections to Plaintiff s Complaint based on deficient service. In addition,
Defendant argued that Plaintiff's Complaint should be dismissed because his claims were time-
barred and he failed to exhaust his administrative remedies under either Title VII of the Civil
Rights Act of 1964, 28 U.S,C. § 2000e, et. seq. or the Pennsylvania Human Relations Act, 43
CHI 10802289.1
P. S. § 951, et. seq. On May 19, 2004, this Court sustained Defendant's Preliminary Objections
as to the deficient service of the complaint.
Meanwhile, on March 25, 2004, unbeknownst to Counsel for Defendant, Plaintiff filed a
second Complaint under the same case number as his original complaint (03-1876). However,
this Complaint contained new allegations and a new caption - "Cory A. Cormany v. Kenneth
Levine" (emphasis added). Plaintiff improperly served this Complaint by leaving it on the front
counter of one of Levine Enterprise's McDonald's restaurants, located at 608 East High Street
Road, Carlisle, Pennsylvania. The Store Manager who found it forwarded it to Controller Tina
Sauter at Levine Enterprises' main office. See Sauter Aff. ¶ 4 (attached hereto at Tab A).
Thinking this was an entirely new complaint because of the new caption, Ms. Sauter forwarded it
to Hubert Gilroy, an attorney handling several other lawsuits against Ms. Adams filed by
Plaintiff. Id. ¶ 4. Mr. Gilroy likewise believed it to be an entirely new complaint until Counsel
for Defendant contacted him in late September and informed him it was the same case number
with a different caption.
Counsel for Defendant was prompted to contact Mr. Gilroy, with whom she had
previously spoken about Plaintiff's other lawsuits against Ms. Adams, when she received notice
that Plaintiff filed an "Amended Complaint," with the caption, "Cory A. Corniany v. Tina D.
Adams," under Case No. 03-1876, on September 10, 2004. Plaintiff served the "Amended
Complaint" by regular U.S. Mail on Levine Enterprises on or about September 27, 2004. Sauter
Aff. ¶ 5. The Amended Complaint raises different claims than those raised in his April 23, 2003
Complaint.] Regardless, Plaintiff has again failed to serve his Amended Complaint in
1 Like his original Complaint, Plaintiff s Amended Complaint is largely unintelligible. It does,
however, make allegations that Defendant terminated several McDonald's employees. Attached
to Plaintiff's Amended Complaint under Exhibit D are documents purporting to be sworn
CHI 10802289.1
accordance with Penn. R. Civ. P. 400. As a result, Plaintiffs Amended Complaint should be
dismissed.
ARGUMENT
Preliminary objections admit as true all facts which are well pleaded as well as all
inferences which are reasonably deducible therefrom. See Pennsylvania Academy of
Chiropractic Physicians v. Department of State, Bureau of Professional & Occupational Affairs,
129 Pa. Commw. Ct. 12, 564 A.2d 551 (1989). Preliminary objections to a complaint should be
sustained where it appears with certainty that the law will not permit recovery. See Mucy Creek
Totivnship Citizens Committee v. Shipman, 132 Pa. Commw. Ct. 543, 573 A.2d 662 (1990).
Applying these standards to Plaintiffs complaint, it is clear that Defendant's preliminary
objections should be sustained.
L Plaintiff s Complaint was Improperly Served.
Pursuant to Penn. R. Civ. P. 400(a), "original process shall be served within the
Commonwealth only by the sheriff." Further, service shall be made "within thirty days after the
issuance of the writ or the filing of the complaint." Penn. R. Civ. P. 40 t (a). Plaintiff filed his
original Complaint on April 23, 2003 and sent it to Defendant by certified mail on or about April
25, 2003. On March 19, 2004, Defendant filed preliminary objections to Plaintiff s complaint
based, in part, on deficient service. On May 19, 2004, the Court sustained Defendant's
preliminary objections to Plaintiff s Complaint because it was not properly served. In the
meantime, in March, 2004, Plaintiff filed a second Complaint with a different caption and new
allegations, under Case No. 03-1876. Again, he failed to serve this Complaint in accordance
statements and verifications from the McDonald's employees referenced in Plaintiffs Amended
Complaint. Defendant believes each of the verifications to be inaccurate. As detailed in Tina
Sauter's Affidavit (¶¶ 6-8), several of the names of these "witnesses" are spelled incorrectly and
some of them have never been employed with Levine Enterprises.
CHI 10902289.1
with Penn. R. Civ. P. 400(a). Moreover, Plaintiff improperly changed the caption of the
complaint to sue "Kenneth Levine" instead of "Tina D. Adams" but kept the same case number.
Plaintiff did not take any further action with respect to his March 25 Complaint. Then,
on September 10, Plaintiff filed an "Amended Complaint," under Case No. 03-1876, with the
correct caption - "Cory A. Cormany v. Tina D. Adams - but with different allegations than those
made in his April, 2003 Complaint. Like his first and second Complaints, Plaintiff did not serve
his September 10 "Amended Complaint" in accordance with Penn. R. Civ. P. 400(a), but rather
served it by regular mail.
Under the Pennsylvania Rules of Civil Procedure, Plaintiff's service of both the March 25
and September 10 Complaints is deficient. Plaintiff failed to correct the deficient service of his
original Complaint (filed April 23, 2003), and his service of the two subsequent Complaints -
one of which inappropriately contained an entirely new caption -was therefore improper.
Independent of his original complaint, service by leaving a complaint on a counter of a
McDonald's restaurant and by U.S. Mail was also improper under Penn. R. Civ. P. 400(a). As a
result, his March 25 and September 10 Complaints, like his original Complaint, should be
dismissed and service should be set aside.
4
CHI 10802289.1
CONCLUSION
For all of the foregoing reasons, Defendant respectfully requests that the Court sustain its
preliminary objections to Plaintiffs March 25 and September 10 Complaints under Penn. R. Civ.
P. 1028(a)(4) and dismiss them with prejudice.
Respectfully submitted,
TINA D. ADAMS
By .-, -
One of H r Att ne
Yvette Heintzelman
Alissa L. Gilfand
SEYFARTH SHAW LLP
55 East Monroe Street
Suite 4200
Chicago, IL 60603
(312) 346-8000
Timothy Ruth
STOCK AND LEADER
221 W. Philadelphia St.
Ste. E600
York, PA 17404
(717) 846-9800
Supreme Court ID #: 26024
5
CHI 10802289.1
CORY A. CORMANY,
Plaintiff
V.
TINA D. ADAMS,
Defendant
IN THE COURT OF COMMONPLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 03-1876 CIVIL TERM
IN RE: PRELIMINARY OBJECTIONS OF
DEFENDANT TO PLAINTIFF'S COMPLAINT
BEFORE HOFFER, P.J., and OLER, J.
ORDER OF COURT
AND NOW, this 19ffi day of May, 2004, upon consideration of Defendant's
preliminary objections to Plaintiff's complaint, and for the reasons stated in the
accompanying opinion, service upon Defendant is set aside, without prejudice to
Defendant's right to timely pursue other appropriate preliminary objections in the
event that Plaintiff causes Defendant to be subjected to personal jurisdiction of the
court.
BY THE COURT,
esley aler, Jr., J.
Cory A. Cormany
1883 Douglas Drive
Carlisle, PA 17013
Plaintiff, pro se
Christian F. Rhodes, Esq.
Susquehanna Commerce
Center East
221 W. Philadelphia Street
Suite E600
York, PA 17404
Attorney for Defendant
CORY A. CORMANY, IN THE COURT OF COMMONPLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
TINA D. ADAMS,
Defendant NO. 03-1876 CIVIL TERM
IN RE: PRELIMINARY OBJECTIONS OF
DEFENDANT TO PLAINTIFF'S COMPLAINT
BEFORE HOFFER, P.J., and OLER, J.
OPINION and ORDER OF COURT
OLER, J., May 19, 2004.
For disposition in this civil case in which a pro se Plaintiff has sued his
former wife' are preliminary objections filed by Defendant to Plaintiffs
complaint. The preliminary objections include an objection based upon improper
2
service.
Defendant's preliminary objections were argued before the above court en
banc on April 21, 2004.3 For the reasons stated in this opinion, Defendant's
preliminary objection based upon improper service of the complaint will be
sustained, and the service will be set aside.
STATEMENT OF FACTS
Plaintiff is identified in his complaint as "an adult individual residing in
Cumberland County, Pennsylvania. ,4 Defendant is similarly identified in the
complaint as "an adult individual residing in Cumberland County, Pennsylvania."5
1 See Plaintiff s Complaint, para. 12.
2 See Defendant's Preliminary Objections to Plaintiff s Complaint, para. 2; Pa. R.C.P. 1028(a)(1).
3 Plaintiff neither filed a brief nor appeared for the argument.
4 Plaintiff s Complaint, para. 1.
' Plaintiff s Complaint, para. 2
Plaintiff's complaint appears to be related to a failure of a McDonald's
restaurant franchisee (for which his former wife worked) to employ him.6
Representative of the largely unintelligible allegations in the complaint are these:
8. To or about the month of April of the year
2001, the plaintiff did retain and service an
employment application at the Ames Dept. Stores of
Carlisle, the Old M.J. Mall location, foregoing a timely
full-time employment.
9. Preceding the issues described in the
aforementioned statements, the plaintiff, Cory A.
Cormany, did achieve and retain employment
opportunity at the McDonalds Co. of Carlisle, non
faulted an expiry period, obligatory a minor child;
(Alexandria Christine).
10. In or about the month of September of the
year 2002, the plaintiff did sustain an employment
application at the McDonalds Co. of Carlisle,
argumentative several entailed locations, liberal a
documentation.
12. Pursuant the foregoing business the
defendant, Tina D. Adams, did divorce the plaintiff,
Cory A. Cormany, allegorical an alcohol/driving issue;
nonreliable a vehicle and a decree, and did marry a
convicted narcotics offender, substantial an equal
opportunity employer.7
Defendant indicates that Plaintiff's complaint was served by certified mail.8
No sheriffs return appears in the record.
DISCUSSION
Under Pennsylvania Rule of Civil Procedure 400(a), as a general rule
"original process shall be served within the Commonwealth only by the sheriff."
As has been stated by the Pennsylvania Superior Court, "[r]egardless of whether
6 See Plaintiff's Complaint, paras. 13-14.
7 Plaintiff's Complaint, paras. 8-10, 12.
8 Defendant's Preliminary Objections to Plaintiffs Complaint, para. 2.
2
the action is commenced by writ of summons or where, as here, the action is
commenced by a complaint, service of process is essential to commencing the
action. Proper service is a prerequisite to a court acquiring personal jurisdiction
over a defendant." Ramsay v. Pierre, 822 A.2d 85, 89 (Pa. Super. 2003).
Where service is improper, it may be set aside. Collins v. Park, 423 Pa.
Super. 601, 621 A.2d 996 (1993). Accordingly, the following order will be
entered:
ORDER OF COURT
AND NOW, this 19`x' day of May, 2004, upon consideration of Defendant's
preliminary objections to Plaintiff's complaint, and for the reasons stated in the
accompanying opinion, service upon Defendant is set aside, without prejudice to
Defendant's right to timely pursue other appropriate preliminary objections in the
event that Plaintiff causes Defendant to be subjected to personal jurisdiction of the
court.
BY THE COURT,
s/ J. Wesley Oler, Jr.
J. Wesley Oler, Jr., J.
Cory A. Cormany
1883 Douglas Drive
Carlisle, PA 17013
Plaintiff, pro se
Christian F. Rhodes, Esq.
Susquehanna Commerce
Center East
221 W. Philadelphia Street
Suite E600
York, PA 17404
Attorney for Defendant
3
CERTIFICATION OF SERVICE
AND NOW, this Irt• day of 2005, I, Cory A. Cormany
foregoing the aforesaid matter knowledgeable a legal pretext, and the
Commonwealth of Pennsylvania, hereby certify that I have served a copy of same
in person or by the United States Mail at Carlisle Pennsylvania, addressed as
follows:
C/O Mr. Ken Levine
Ms. Tina D. Adams
McDonalds Company
123 South Pitt Street
Carlisle, PA 17013
Mr.Timothy Ruth
Stock & Leader
221 W. Philadelphia St.
Ste. E600
York, PA 17404
Ms. Yvette Hientzelman
Seyfarth Shaw LLP
55 East Monore Street
Chicago, IL 60603
Co A. Corm y
1883 Douglas Dr.
Carlisle, PA 17013
(8)
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1.14. D
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CORY A. CORMANY, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION-LAW
TINA D. ADAMS,
Defendant NO. 03-1876 CIVIL TERM
IN RE: DEFENDANT'S PRELIMINARY OBJECTIONS TO PLAINTIFF'S
MARCH 25, 2004, AND SEPTEMBER 10, 2004, COMPLAINTS
BEFORE OLER and GUIDO, JJ.
ORDER OF COURT
AND NOW, this 17'h day of February, 2005, upon consideration of Defendant's
Preliminary Objections to Plaintiffs March 25, 2004, and September 10, 2004,
Complaints, and of Defendant's "Motion To Dismiss," it is ordered and directed as
follows:
1. With respect to Defendant's preliminary objections, following
oral argument held on February 2, 2005, which Plaintiff did not attend, and
it appearing that Plaintiffs amended complaints were not filed in
compliance with Pennsylvania Rule of Civil Procedure 1033, Plaintiffs
amended complaints filed March 25, 2004, and September 10, 2004, are
dismissed; and
2. Plaintiffs "Motion To Dismiss," to the extent that it opposes
dismissal of the amended complaints, is denied.
BY THE COURT,
/Cory A. Cormany
1883 Douglas Drive
Carlisle, PA 17013
Plaintiff, Pro Se
()),-/9-64-5
VYvette Heintzelman
Alissa L. Gilfand, Esq.
Seyfarth Shaw LLP
55 East Monroe Street
Suite 4200
Chicago, IL 60603
Attorneys for Defendant
,1"i'mothy Ruth, Esq.
Stock and Leader
221 W. Philadelphia Street
Ste. E600
York, PA 17404
Attorney for Defendant
Curtis R. Long
Prothonotary
Office of the Protbonotarp
Cumberlanb Countp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
d3 - / 8716 CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573