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Home My WebLink About99-00962 IN 'y1'.fl"" (3~c.-"c..f D;: (!'0I/1116'<-~ P#)/5 6/ ('WI.!r-> 0::: it""",/ CoV-/"') a. C/tJ; / /Ie 16/~ -IACU /0 UJs 2 e //12.N; P IfJ/AJ+"pf' , -II q c; -1& L ~A-t'~~ Vs . D I f)'Y1 i? fretD S /(J4luIG i .4;OP/ S il/\.d. k f-I fc.(J C. I AruJl-' i,) Tlv~ /lIVe! S I '{J fl12f1 111111 Jlf.. ~ --JDk Dc~ D--""nf'. ' I -JaiL-,^- \::";>e,e ~rel\-d €.Jt--t2. ,z; 0.35 /7"1/lRfi./ S I- (l11/1/1,// d // ~ /70// p~ 11-r:..~ 0t;;~ leje,! CJ! SUJtfl#cJ~5 /;:> /k /~61;fo/d4/- y P/eftsc? ISSu-e. it WR,:~ bPSUj/Ylff1-0)'1-S A94/~5f ---;t r/bouC' /VI'1/1<-.ed VP/'C>I<-C~IV* 1Ye,;J-" cI ;:;/1 5"", hit< ,Ik j ck~ Y&f ~Vo's ?'G'J,.?-v-; C; 10 S rI1.LJert\~.s- s C:) r. ( _ 0 <;> '-is f'\ec.~",\ ~CSbwf'" r'c, 17 () s S '1I,)l <;'/ u ~ .,- t!l >- tr; (''0 ?~ <l. 1-' (Ii ..J ..'Z. Cl i,.i LU-:. 0-:'.. " - u:i. '-. , ..;;. u... :::J ~!)i~ "....1 .'->- ,. l.._: 0:) .C- 0'..'. 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No. 42136 THOMAS, THOMAS & HAFER, LLP Posl Office Box 999 Harrisburg, Pennsylvania 17108 (717) 237-7100 E-Mail: seaalltthlaw.com Attorneys for Defendants: DIMETRIOS KARAGIANNIS, KARAGIANNIS, INC. and SIERRA MADRE LOUIS ZELAZNY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA v. NO. 99-962 CIVIL DIMETRIOS KARAGIANNIS, KARAGIANNIS, INC., SIERRA MADRE, JOHN DOE JOHN DOE, and Defendants PRAECIPE AND RULE TO FILE A COMPLAINT TO THE PROTHONOTARY OF SAID COURT: Please issue a Rule on Plaintiff to file a Complaint in the above case within twenty (20) days after service of the Rule or suffer a judgment of non pros. /-/'1/ ~ 1 THOMAS, THOMAS & HAFER, LLP ~M~ By: :52704.1 TODD B. NARVOL, ESQUIRE Attorney 1.0, No. 42136 STEPHEN E. GEDULDIG, ESQUIRE Attorney 1.0. No. 43530 Attorneys for Defendants, Oimetrios Karagiannis, Karagiannis, Inc. and Sierra Madre RULE NOW, >lILI-A.{k--; ~ , 1999, RULE IS ISSUED AS ABOVE. ~/ [to.'J , . .~:) . ':) ~ ~ (~:,fj 'J J , :' of :', ',) , , , ol - on UJ 1/'1 E 'M 0 ~ e:: r- V e:: .8 " ~ Eo< <0 <0 aI. 'M () ...:i ~~~ ..-l Ole:: ~ ~ 'M <0>-< E > >, H C . ~ i~ 'M e:: <0 . V 'tl ~ e:: g ~ () N ~ UJ ~ e:: 0 < <0 'M'tl <0 'M N ..-l UJ e:: <0 .j.J f ~~ \0' V o e::::E v,v en u ~'a~' enl N UJ 'M <0 00 <l: 1 I > ~'M <0 Q Q en' UJ .j.J tn ~ ..-l I/'Ijr- ",I 'M V <0 ~ e:: e:: 'M ]~ E , ;J E~V..c::.c:: > d 0 'M <O'M 0 0 'M :z; ...:i Q~Ul"""" () - . . . LOUIS ZELAZNY, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 99-962 Plaintiff v. DIMETRIOS KARAGIANNIS, KARAGIANNIS, INC., SIERRA MADRE,: JOHN DOE and JOHN DOE, Defendants : JURY TRIAL DEMANDED NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 6. Defendant John Doe II is an unknown adult individual who, upon information and belief, was employed by Defendants Karagiannis, Inc. and/or Sierra Madre, Inc. on the date of the incident set forth below. 7. Defendant Dimetrios Karagiannis is, upon information and belief, the Secretary and Treasurer of Karagiannis, Inc. and the President of Sierra Madre, Inc. 8. Sierra Madre is a bar/restaurant which operates at 4035 Market Street, Camp Hill, PA 9. On the evening of February 18, 1997, Zelazny was a patron of Sierra Madre/Karagiannis, Inc., arriving at approximately 10:00 p.m. 10. Upon his arrival, both Dimetrios Karagiannis and John Doe I (Brett Farence) were present on the premises, and located at the end of the bar. 11. Zelazny began a tab at the bar, and ordered both food and drinks. 12. At approximately 12:30 p.m., Zelazny moved to another area along the bar. Upon his return, he found that a drink he had just purchased, and had not begun to drink, had been removed from the bar and thrown away. 13. Zelazny asked for the bartender, John Doe II, to replace his drink. 14. At this time, both John Doe II and Dimetrios Karagiannis became verbally abusive to Zelazny, stating to him that he must pay his tab and leave the premises. 15. Zelazny advised John Doe" and Karagiannis that he would pay his tab, excluding the last drink, which was not provided to him. 2 16. Karagiannis stated that he was going to call the police, to which Zelazny consented. 17. Zelazny remained standing at the end of the bar, waiting for the police, on the assumption that Karagiannis had actually contacted the police. 18. Without warning or provocation, Karagiannis attacked Zelazny, forcing him to the ground, and then began to punch Zelazny in the face. 19. While he was defenseless to the attack of Karagiannis, John Doe I and John Doe II grabbed Zelazny's arms, allowing Karagiannis to continue to strike the helpless Zelazny. 20. Another patron, William T. Moreo, attempted to intervene, but was pushed out of the way by John Doe II. 21. Eventually, Karagiannis, John Doe I and John Doe II ceased beating Zelazny, and allowed him to get to his feet. 22. Zelazny questioned Karagiannis why he would attack him. 23. At this point, again without any warning or provocation, Karagiannis, John Doe I and John Doe II forced Zelazny to the ground and continued their brutal attack. 24. At no time did Zelazny physically or verbally threaten Karagiannis, John Doe I, John Doe II, or any other patron or employee present at the scene. 25. When the attack finally ended, Zelazny was able to get off the ground and called the police. 3 26. Upon seeing that Zelazny had contacted the police, Karagiannis told Zelazny not to worry about the tab any more, but rather he should just leave the premises. 27. All Defendants' actions, as set forth herein, were outrageous, wanton, reckless and done with complete indifference to the rights of Zelazny. 28. Due to Defendants' actions, Zelazny suffered numerous injuries, continues to suffer from such injuries, and has incurred medical costs and lost wages. COUNT I Zelazny v. Karagiannis, John Doe I and John Doe II Assault 29. Paragraphs 1 through 29 are incorporated fully herein by reference. 30. Defendants' actions were intended to cause harmful and offensive contact with Zelazny, and placed Zelazny in apprehension of immediate harmful and offensive contact. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter judgment for Plaintiff and against Defendants, plus award costs and punitive damages. 4 VERIFICATION I, Louis Zelazny, have read the foregoing Complaint, and hereby certify that the facts set forth therein ~re true and correct to the best of my knowledge, information and belief. This statement is made subject to the penalties of 18 Pa. Const. Stat. Ann. ~ 4904 relating to unsworn falsification to authorities. By:JtM~ is Z ny, DATED: 4 ~ 12-- 91 ~ (]' ~ h- ",' .- j.:: /. t.:':J :-,:-) :<(, lJ.\ ~~ C) 2: C.) C,:' .- , .J :.:~~ p: : ~ . t'.'.- .~ ~.:J (~j r;.7;- , ,. ). ~-: en . ~~ ~~~ ~.~- I J I:. 2": A'__ .\1 LJJ -.' :~-:~ L'.- ,_:: -'J :J_ Li' ::~) () c.1" U 0'1-_',"