HomeMy WebLinkAbout99-00820
Plainti IT and its insurancc carricr havc had no opportunity to allow invcstigativc cxpcrts to cxaminc
the fire sccnc on their bchal f.
7. Upon information and belief, defendant Wcst Shorc, plans to dcmolish thc fire sccnc
tomorrow moming, February II, 1999,
8. Plaintiff has requested, to no avail, that Defendant refrain from demolishing the fire
scene until after Plaintiffs own investigative experts have had a full opportunity to review the scene
so that Plaintiff will be able to defend himself from any allegations made against him.
9. If the fire scene is demolished tomolTow, Plaintiff will be immediately and
irreparably harnled, in that only Defendant West Shore, who plans to bring legal action against
Plaintiff for allegedly causing the fire, will have had an opportunity to examine all of the evidence
at the fire scene.
10. No government entity or individual has ordered for public safety reasons, or
otherwise, that the building be demolished.
,.
WHEREFORE, Plaintiff respectfully requests that this Court grant the following relief:
(i) Prohibit Defendants from demolishing the fire scene for three days until February 13,
1999 (in accord with the proposed temporary restraining order attached hereto); and
(ii) That Plaintiff receive such other and further relief as the Court deems reasonable,
necessary and just.
POST & SCHELL, P,C.
February 11, 1999
By /!.//7/<7/W=
KEN LEVINE #60984 . .
215-587-1035
JAMES MALLOY #69043