HomeMy WebLinkAbout99-04013
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
REBECCA P. DiDAY and CIVIL ACTION - LAW
ROBERT W. DiDAY, her husband, ?-
Plaintiffs No. 99 -?/(?/?
VS.
COMPLAINT IN A CIVIL ACTION
METRO HOTELS, INC., doing business as
RADISSON PENN HARRIS HOTEL, and
PENN HARRIS COMPANY,
Filed on behalf of REBECCA P. DiDAY and
Defendants ROBERT W. DiDAY, her husband, Plaintiffs
JURY TRIAL DEMANDED
Counsel of Record for this Party:
James R. Duffy, Esquire
Pa. I. D. # 10746
1800 Lawyers Building
428 Forbes Avenue
Pittsburgh, PA 15219
(412) 261-0134
(412) 281-3154 - Fax
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
REBECCA P. DiDAY and
ROBERT W. DiDAY, her husband,
Plaintiffs
VS.
METRO HOTELS, INC.,
d/b/a RADISSON PENN HARRIS
HOTEL, and PENN HARRIS
COMPANY,
Defendants
CIVIL ACTION - LAW
NO.
NOTICE TO DEFEND
TO: Metro Hotels, Inc., d/b/a Radisson Penn Harris Hotel, and
Penn Harris Company, Defendants
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, Pennsylvania 17013
(717) -249-3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
REBECCA P. DiDAY and
ROBERT W. DiDAY, her husband,
Plaintiffs
CIVIL ACTION - LAW
VS.
METRO HOTELS, INC., ]
d/b/a RADISSON PENN HARRIS ]
HOTEL, and PENN HARRIS ]
COMPANY, ]
Defendants ]
NO. F9- y01-3 C? T
Plaintiffs bring this complaint in civil action upon a cause as follows:
1. The plaintiffs are husband and wife and residents of Allegheny
County, residing at 221 Oakhaven Drive, Moon Township, Pennsylvania 15108.
2. The defendant, Metro Hotels, Inc., is a corporation duly created
and existing under and by virtue of the laws of the Commonwealth of Pennsylvania
and at all relevant times was the owner and operator of a hotel and convention center
operating under the name of the Penn Harris Company and the Radisson Penn Harris
Hotel and Convention Center, 1150 Camp Hill By-Pass, Camp Hill, Cumberland
County, Pennsylvania 17011.
3. On or about April 18, 1998 the wife plaintiff was a business visitor
and guest at the defendant Radisson Penn Harris Hotel and Convention Center
participating in the convention of the Alpha Delta Kappa International Honorary
Sorority where the wife plaintiff performed the officer duties of Sergeant-At-Arms for
the convention.
4. In order to facilitate the convention meeting of the honorary
- 1 -
sorority as aforesaid, the defendant, through its agents, servant and employees
erected, constructed, decorated and provided a platform stage to act as a dais for
those officers and speakers presiding and presenting at the luncheon for the
convention group.
5. At approximately 2:30 p.m., the wife plaintiff was seated on the
platform stage/dais in a position to permit her to perform her official duties as
Sergeant-At-Arms. In the course of those duties, the wife plaintiff was required to exit
the stage/dais. The wife plaintiff arose from her chair to proceed to the steps provided
for access to the stage/dais. In moving from her chair to the steps, the wife plaintiff's
foot caught in duct tape and velcro skirting which had been negligently installed on the
stage/dais by the agents, servants and employees of the defendant causing the wife
plaintiff to trip and fall on and down the steps of the platform.
6. As a result of the wife plaintiff's fall, caused by the negligence of
the defendant, acting through its agents, servants and employees, the wife plaintiff
suffered serious injuries, some of which are permanent in nature.
7. Plaintiffs aver the the aforesaid accident was caused solely and
proximately by the negligence of the defendant, acting through its agents, servants
and employees generally and as more specifically set forth as follows:
A. In failing to provide adequate facilities for the wife plaintiff and wife
plaintiff's convention group when they were fully informed of the size of the group and
the requirements for staging to facilitate the meeting;
B. In providing a stage/dais which was too small for the number of
guests intended to use the stage/dais.
C. In negligently dressing the stage/dais in velcro skirting in such a
way as to create a tripping hazard;
D. In negligently placing duct tape on the stage/dais in such a
-2-
manner as to create a tripping hazards;
E. In negligently dressing the stage/dais when they knew or should
have known that their actions created an unreasonable risk of personal injury to their
business visitors and guests;
F. In failing to warn wife plaintiff and others similarly situate;
G. In causing and allowing an inadequate stage/dais for the use of
the wife plaintiff's convention group;
H. In failing to take reasonable steps to make the stage/dais safe for
its intended use;
stage/dais;
1. In hiring incompetent help to supervise, build and dress the
J. In failing to correct a dangerous condition which they knew or
should have known would create an unreasonable risk of bodily injury to business
visitors and guests;
K. In otherwise failing to use due care and caution under the
circumstances.
8.
of the defendan
A.
fracture;
B.
C.
D.
E.
F.
As a result of the accident as aforesaid, caused by the negligence
t as aforesaid, the wife plaintiff suffered the following injuries:
an injury to the right foot, including but not limited to an avulsion
an injury to the right leg;
an injury to the right knee;
an injury to the back;
an injury to the nerves of the back and leg;
generalized bruises, contusions and abrasions of the right side of
-3-
her body including her shoulder, buttock and thigh;
G. shock to the nervous system with attendant nervous disorders.
9. As a result of the wife plaintiff's injuries as aforesaid, caused by
negligence of the defendant as aforesaid, the plaintiff's have suffered the following
damages:
A. Wife plaintiff has in the past and will in the future suffer great pain,
suffering and inconvenience;
B. Wife plaintiff has in the past and will in the future suffer the loss of
the enjoyment of everyday life;
C. The plaintiffs have in the past and will in the future be required to
expend large sums of money for hospitalization, medicine and medical attention in an
effort to restore the health of wife plaintiff.
D. The wife plaintiff has suffered the loss of earnings.
E. The wife plaintiff has suffered an impairment of earning capacity.
F. The husband plaintiff has in the past and will in the future suffer
the loss of services of his wife.
WHEREFORE, in consideration of the foregoing, the plaintiffs sue the
defendant to recover an amount in excess of Twenty-Five thousand ($25,000.00)
Dollars.
JURY TRIAL DEMANDED.
Respectfully submitted,
Jam s u squire
orney for Plai tiffs
-4-
The undersigned, REBECCA P. DiDAY and ROBERT W. DiDAY aver that
the facts contained in the foregoing CIVIL ACTION COMPLAINT are true and correct to
the best of their information, knowledge and belief and that this statement and
verification are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to
unsworn falsification to authorities which provides that if I make knowingly false
statements, I may be subject to criminal penalties.
i
REBECCA P. DiDAY
ROBERT W. DiDAY
Date: June 25, 1999
1.
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-04013 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DIDAY REBECCA P ET AL
VS.
METRO HOTELS INC ET AL
BRIAN BARRICK Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within NOTICE AND COMPLAINT IN
was served
upon METRO HOTELS INC DBA RADISSON PENN HARRIS AND PENN HARRIS CO the
defendant, at 15:30 HOURS, on the let day of July
1999 at 1150 CAMP HILL BY-PASS
CAMP HILL, PA 17011
,CUMBERLAND
County, Pennsylvania, by handing to THOMAS DICKERT (GENERAL
MANAGER)
a true and attested copy of the NOTICE AND COMPLAINT IN
together with CIVIL ACTION
and at the same time directing His attention to the contents thereof.
Sheriff's Costs. So answers:
Docketing 18.00
Service 9.30
r
Affidavit "f rp
Surcharge .00
8.00 R?S7-omas ine, nerirr
$33U-J ES R. DUFFY
002/1999
epu y
Sworn and subscribed to before me
this day of(-
19- 91 A. D.
?Q hL?cw
ro 0 o a??
POST & SCHELL, P.C.
BY: JOHN W.DORNBERGER
I.D. # 69293
240 GRANDVIEW AVENUE
CAMP HILL, PA 17011
(717) 731-1970
REBECCA P. DiDAY and
ROBERT W. DiDAY, her husband
Plaintiffs,
V.
METRO HOTELS, INC..
d/b/a RADISSON PENN HARRIS
HOTEL, and PENN HARRIS
COMPANY
Defendants.
TO THE PROTHONOTARY:
ATTORNEYS FOR DEFENDANT
METRO HOTELS, INC.
D/B/A RADISSON PENN HARRIS
HOTEL, AND PENN HARRIS
COMPANY
IN THE COURT OF COMMON
PLEAS
OF CUMBERLAND COUNTY -
PENNSYLVANIA
NO. 99-4013
CIVIL ACTION - LAW
Kindly enter my appearance for the Defendant, Metro Hotels, Inc., d/b/a Radisson Penn
Hams Hotel, and Penn Harris Company, in the above-captioned matter.
Respectfully submitted,
POST & SCHELL, P.C.
I, Kelley Spangler, an employee of the law offices of Post & Schell, P.C., do hereby certify that on the
date listed below, I did serve a true and correct copy of the foregoing document upon the following person(s)
at the following address(es) by sending same in the United States mail, first-class, postage prepaid:
James R. Duffy, Esquire
1800 Lawyers Building
428 Forbes Avenue
Pittsburgh, PA 15219
?I .1114 QP=C4L)
KELLEY S AN LER
DATE: 1 ;?99
Lo
111-1 -? - j Y
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
REBECCA P. DiDAY and CIVIL ACTION - LAW
ROBERT W. DiDAY, her husband,
Plaintiffs No. 99-4013
Vs.
NOTICE OF SERVICE OF PLAINTIFFS'
METRO HOTELS, INC., doing business as FIRST SET OF INTERROGATORIES
RADISSON PENN HARRIS HOTEL, and AND REQUEST FOR PRODUCTION OF
PENN HARRIS COMPANY, DOCUMENTS DIRECTED TO
DEFENDANTS
Defendants
Filed on behalf of REBECCA P. DiDAY and
ROBERT W. DiDAY, her husband, Plaintiffs
Counsel of Record for this Party:
James R. Duffy, Esquire
Pa. I.D. # 10746
1800 Lawyers Building
428 Forbes Avenue
Pittsburgh, PA 15219
(412) 261-0134
(412) 281-3154 - Fax
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
REBECCA P. DiDAY and ] CIVIL ACTION - LAW
ROBERT W. DIDAY, her husband, ]
Plaintiffs 1
vs. ] NO. 99-4013
METRO HOTELS, INC.,
d/b/a RADISSON PENN HARRIS
HOTEL, and PENN HARRIS
COMPANY,
Defendants
TO THE PROTHONOTARY:
Kindly take Notice that the original and two copies of Plaintiffs' First Set of
Interrogatories and Request for Production of Documents was served on Defendants'
counsel by First Class Mail, postage prepaid, on the ,,7-6 'bL day of _
1999 at the following address:
John W. Dornberger, Esquire
Post & Schell, P. C.
240 Grandview Avenue
Camp Hill, PA 17011
Respectfully submitted,
?r.
h'
i '7 JCL
S
7, rn =i
POST & SCHELL, P.C.
BY: JOHN W.DORNBERGER
I.D. #69293
240 GRANDVIEW AVENUE
CAMP HILL, PA 17011
(717) 731-1970
REBECCA P. DiDAY and
ROBERT W. DiDAY, her husband
Plaintiffs,
V.
METRO HOTELS, INC..
d/b/a RADISSON PENN HARRIS
HOTEL, and PENN HARRIS
COMPANY
Defendants.
ATTORNEYS FOR DEFENDANT
METRO HOTELS, INC.
D/B/A RADISSON PENN HARRIS
HOTEL, AND PENN HARRIS
COMPANY
IN THE COURT OF COMMON
PLEAS
OF CUMBERLAND COUNTY -
PENNSYLVANIA
NO. 99-4013
CIVIL ACTION - LAW
ANSWER AND NEW MATTER OF DEFENDANTS
METRO HOTELS, INC. AND
PENN HARRIS COMPANY TO Pi AINTIFFS' COMPI AINT
Defendants, Metro Hotels, Inc. and Penn Harris Company (incorrectly designated as "Metro
Hotels, Inc. d/b/a Radisson Penn Harris Hotel and Penn Hams Company" and [hereinafter
"Defendants"] files this Answer and New Matter to Plaintiffs' Complaint as follows:
1. Denied. After reasonable investigation, Defendants are without knowledge or
information sufficient to form a belief as to the truth of the allegations and, accordingly, all such
allegations are denied.
2. Admitted in part; denied in part. It is admitted that Metro Hotels, Inc. was the owner
of a hotel known as the Radisson Penn Harris Hotel and Convention Center at 1150 Camp Hill By-
Pass, Camp Hill, Cumberland County, Pennsylvania on April 18, 1998. It is admitted that Metro
Hotels, Inc. is a corporation organized and existing under the laws of the Commonwealth of
Pennsylvania. All remaining allegations are denied as conclusions of law.
3. Denied. After reasonable investigation, Defendants are without knowledge or
information sufficient to form a belief as to the truth of the allegations and, accordingly, all such
allegations are denied.
4. Denied. After reasonable investigation, Defendants are without knowledge or
information sufficient to form a belief as to the truth of the allegations and, accordingly, all such
allegations are denied.
5. Denied. It is denied that Defendants were negligent or that their actions or omissions
were the proximate cause of Plaintiffs' alleged damages. After reasonable investigation, Defendants
are without knowledge or information sufficient to form a belief as to the truth of the remaining
allegations and, accordingly, all such allegations are denied.
6. Denied. The corresponding allegations are denied because Plaintiffs fail to identify
"agents, servants and employees" with sufficient specificity. It is denied that Defendants were
negligent or that their actions or omissions were the proximate cause of Plaintiffs alleged damages.
After reasonable investigation, Defendants are without knowledge or information sufficient to form
a belief as to the truth of the remaining allegations and, accordingly, all such allegations are denied.
7. Denied. The corresponding allegations are denied because Plaintiffs fail to identify
"agents, servants and employees" or "tripping hazard" with sufficient specificity. To the extent any
further answer is required, Defendants deny that they were negligent, careless or reckless or that their
acts or omissions were the proximate cause of Plaintiffs' alleged damages. To the contrary,
Defendants acted reasonably under the circumstances. All remaining allegations are denied as
conclusions of law. After reasonable investigation, Defendants are without knowledge or
-2-
information sufficient to form a belief as to the truth of the remaining allegations and, accordingly,
all such allegations are denied. Defendants incorporate these averments into each and every
paragraph of this Answer as if set forth length therein.
8. Denied. Alter reasonable investigation, Defendants are without knowledge or
information sufficient to form a belief as to the truth of the allegations and, accordingly, all such
allegations are denied.
9. Denied. After reasonable investigation, Defendants are without knowledge or
information sufficient to form a belief as to the truth of the allegations and, accordingly, all such
allegations are denied.
WHEREFORE, Defendants respectfully request that this Honorable Court enter judgment
in favor of Defendants and against Plaintiffs.
10. Plaintiffs have failed to state a claim upon which relief can be granted.
11. Plaintiffs' claims are barred by the statute of limitations.
12. Recovery is barred because Plaintiffs assumed the risk of the occurrence of the
incident and the injuries or damages alleged.
13. The claims are barred in whole or in part by the contributory or comparative
negligence of Plaintiffs or that of their agents.
14. The alleged injuries and damages were the result of the actions and omissions of
Plaintiffs and/or persons other than Defendants.
15. Plaintiffs' claims are barred or limited by the doctrines of res judicata or collateral
estoppel.
-3-
16. Plaintiffs' claims are barred or limited based upon the applicable workers'
compensation law.
17. Plaintiffs have failed to mitigate her damages.
18. Plaintiffs' injuries and/or damages, if any, were caused by intervening wrongdoing
of others over which the Defendants had no control and for which this Defendants are not
responsible.
19. The damages alleged by Plaintiffs are not recoverable under the applicable law.
20. Defendants deny that they had any notice at all, either actual or constructive, of the
alleged defective condition described in Plaintiffs' Complaint.
WHEREFORE, Defendants respectfully requests that this Honorable Court enter judgment
in favor of Defendants and against Plaintiffs.
Respectfully submitted,
POST & SCHELL, P. C.
B
JOHN W. DO ESQ.
Date: October , 1999
-4-
do hereby swear and affirm that the facts and matters set forth in
the foregoing Answer and New Matter is true and correct to the best of my knowledge, information,
and belief. The undersigned understands that the statements made therein are made subject to the
penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities.
DATE: l-, 12 5
Y
Torn Dicker, General Mmmger
I, John W. Domberger, Esq., of the law offices of Post & Schell, P.C., do hereby certify that on the date
listed below, l did serve a true and correct copy of the foregoing document upon the following person(s) at the
following address(es) by sending same in the United States mail, first-class, postage prepaid:
James R. Duffy, Esquire
1800 Lawyers Building
428 Forbes Avenue
Pittsburgh, PA 15219
JO W. DORNB ESQ.
DATE: Octobera S . 1999
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
REBECCA P. DiDAY and
ROBERT W. DiDAY, her husband,
Plaintiffs
CIVIL ACTION - LAW
No. 99-4013
vs.
METRO HOTELS, INC., doing business as
RADISSON PENN HARRIS HOTEL, and
PENN HARRIS COMPANY,
Defendants
PLAINTIFFS' REPLY TO NEW MATTER
Filed on behalf of REBECCA P. DiDAY and
ROBERT W. DiDAY, her husband, Plaintiffs
Counsel of Record for this Party:
James R. Duffy, Esquire
Pa. I.D. # 10746
1800 Lawyers Building
428 Forbes Avenue
Pittsburgh, PA 152219
(412) 261-0134
(412) 281-3154 - Fax
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
REBECCA P. DiDAY and
ROBERT W. DiDAY, her husband,
Plaintiffs
Vs
METRO HOTELS, INC., ]
d/b/a RADISSON PENN HARRIS ]
HOTEL, and PENN HARRIS ]
COMPANY, ]
Defendants ]
CIVIL ACTION - LAW
NO. 1999-4013
AND NOW, come the Plaintiffs, by counsel, and reply to the New Matter of the
defendants as follows:
Paragraphs 10 and 11 of Defendants' Answer and New Matter state
conclusions of law to which no answer is required.
2. Paragraph 12 of Defendants' Answer and New Matter states a conclusion of
law to which no answer is required. To the extent that Paragraph 12 can be read to state assertions
of fact, those assertions are denied and it is affirmatively stated that the wife-plaintiff did not
assume the risk of the occurrence or of the negligence of the defendant through its agents, servants
and employees.
Paragraph 13 of Defendants' Answer and New Matter states a conclusion of
law to which no answer is required. To the extent that Paragraph 13 can be read to state assertions
of fact, those assertions are denied and it is affirmatively averred that the wife-plaintiff was not
contributorily or comparatively negligent and used due care at all times.
4. The averments of Paragraph 14 of Defendants' Answer and New Matter are
denied and the averments of Plaintiffs' Complaint related to the negligence of the defendant, acting
through its agents, servants and employees, is specifically restated as though set forth at length.
Paragraph 15 of Defendants' Answer and New Matter states a conclusion of
law to which no answer is required.
1-
6. Paragraph 16 of Defendants' Answer and New Matter is irrelevant in that no
workers' compensation law is applicable.
Paragraph 17 of Defendants' Answer and New Matter states a conclusion of
law to which no reply is necessary. To the extent that said Paragraph can be read to allege facts,
said allegations are denied and it is affirmatively averred that the wife-plaintiff has taken all
reasonable steps to attempt to cure her injuries and mitigate her damages.
8. Paragraph 18 of Defendants' Answer and New Matter states conclusions of
law to which no answer is required. To the extent that said Paragraph can be read to contain
factual averments, those factual averments are denied and Plaintiffs claim that the accident was
caused solely and proximately by the negligence of the defendant through their agents, servants
and employees acting in the course and scope of their employment is restated.
Paragraph 19 of Defendants' Answer and New Matter states a conclusion of
law to which no answer is required.
10. Paragraph 20 of Defendants' Answer and New Matter, to the extent that it
alleges a lack of notice of the defective conditions on the part of the defendant, is denied and it is
affirmatively averred that the defective conditions which were the proximate cause of the wife-
plaintiff's accident and injuries were created by the defendant through their agents, servants and
employees acting in the course and scope of their employment.
WHEREFORE, in consideration of the foregoing, plaintiffs demand judgment in
their behalf.
Respectfully
for
-2.
NO. 1999-4013
The undersigned, JAMES R. DUFFY, ESQUIRE, avers that the facts
contained in the foregoing REPLY TO NEW MATTER are true and correct to the best of
his information, knowledge and belief and that this statement and verification are
made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification
to authorities which provides that if I make knowingly false statements, I may be
subject to criminal penalties.
JAMES R. DU
November 9, 1999
Date:
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
REBECCA P. DIDAY and
ROBERT W. DIDAY, her husband,
Plaintiffs
CIVIL ACTION - LAW
VS.
METRO HOTELS, INC.,
d/b/a RADISSON PENN HARRIS
HOTEL, and PENN HARRIS
COMPANY,
Defendants
NO. 99-4013
CERTIFICATE OF SERVICE
I, James R. Duffy, Esquire, hereby certify that a true and correct copy of
the foregoing document was served upon counsel for the defendants by First Class
U. S. Mail, postage prepaid, on the 9 day of November , 1999 at the
following address:
John W. Dornberger, Esquire
Post & Schell, P.C.
240 Grandview Avenue
Camp Hill, PA 17011
James . D y, Esq.
Attorney for laintiffs
1800 Lawyers Building
428 Forbes Avenue
Pittsburgh, PA 15219
(412) 261-0134
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
REBECCA P. DiDAY and
ROBERT W. DiDAY, her husband,
Plaintiffs
CIVIL ACTION - LAW
No. 99-4013
vs.
METRO HOTELS, INC., doing business as
RADISSON PENN HARRIS HOTEL, and
PENN HARRIS COMPANY,
Defendants
CERTIFICATE OF SERVICE
Filed on behalf of REBECCA P. DiDAY and
ROBERT W. DiDAY, her husband, Plaintiffs
Counsel of Record for this Party:
James R. Duffy, Esquire
Pa. I. D. # 10746
1800 Lawyers Building
428 Forbes Avenue
Pittsburgh, PA 15219
(412) 261-0134
(412) 281-3154 - Fax
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
REBECCA P. DiDAY and ] CIVIL ACTION - LAW
ROBERT W. DiDAY, her husband, ]
Plaintiffs 1
vs. ] NO. 99-4013
METRO HOTELS, INC.,
d/b/a RADISSON PENN HARRIS
HOTEL, and PENN HARRIS
COMPANY,
Defendants
CERTIFICATE OF SERVICE
I, James R. Duffy, Esquire, hereby certify that the original of the
PLAINTIFFS' ANSWERS TO INTERROGATORIES and RESPONSE TO REQUEST
FOR PRODUCTION OF DOCUMENTS was served upon counsel for the defendants by
First Class U. S. Mail, postage prepaid, on the 9 day of NOVEMBER
1999 at the following address:
John W. Dornberger, Esquire
Post & Schell, P.C.
240 Grandview Avenue
Camp Hill, PA 17011
am R. Du sq.
omay for Plaintiffs
1800 Lawyers Building
428 Forbes Avenue
Pittsburgh, PA 15219
(412) 261-0134
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
REBECCA P. DiDAY and
ROBERT W. DiDAY, her husband,
Plaintiffs
CIVIL ACTION - LAW
No. 99.4013
VS.
METRO HOTELS, INC., doing business as
RADISSON PENN HARRIS HOTEL, and
PENN HARRIS COMPANY,
Defendants
CERTIFICATE OF SERVICE
Filed on behalf of REBECCA P. DiDAY and
ROBERT W. DiDAY, her husband, Plaintiffs
Counsel of Record for this Party:
James R. Duffy, Esquire
Pa. I.D. # 10746
1800 Lawyers Building
428 Forbes Avenue
Pittsburgh, PA 15219
(412) 261-0134
(412) 281-3154 - Fax
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
REBECCA P. DiDAY and
ROBERT W. DiDAY, her husband,
Plaintiffs
VS.
METRO HOTELS, INC.,
d/b/a RADISSON PENN HARRIS
HOTEL, and PENN HARRIS
COMPANY,
Defendants
CIVIL ACTION - LAW
NO. 99-4013
CERTIFICATE OF SERVICE
I, James R. Duffy, Esquire, hereby certify that the original of the
PLAINTIFFS' ANSWERS TO SUPPLEMENTAL INTERROGATORIES was served upon
counsel for the, defendants by First Class U. S. Mail, postage prepaid, on the
day of 2000 at the following address:
John W. Dornberger, Esquire
Post & Schell, P.C.
240 Grandview Avenue
Camp Hill, PA 17011
James uffy,
AGm-6y for Plaintiffs
1800 Lawyers Building
428 Forbes Avenue
Pittsburgh, PA 15219
(412) 261-0134
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
REBECCA P. DiDAY and
ROBERT W. DiDAY, her husband,
Plaintiffs
CIVIL ACTION - LAW
No. 99-4013
VS.
METRO HOTELS, INC., doing business as
RADISSON PENN HARRIS HOTEL, and
PENN HARRIS COMPANY,
Defendants
CERTIFICATE OF SERVICE
Filed on behalf of REBECCA P. DiDAY and
ROBERT W. DiDAY, her husband, Plaintiffs
Counsel of Record for this Party:
James R. Duffy, Esquire
Pa. I.D. # 10746
1800 Lawyers Building
428 Forbes Avenue
Pittsburgh, PA 15219
(412) 261-0134
(412) 281-3154 - Far.
1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
REBECCA P. DiDAY and ]
ROBERT W. DiDAY, her husband, ]
Plaintiffs ]
1
vs. ]
METRO HOTELS, INC., )
d/b/a RADISSON PENN HARRIS j
HOTEL, and PENN HARRIS ]
COMPANY, ]
Defendants ]
CIVIL ACTION - LAW
NO. 99-4013
CERTIFICATE OF SERVICE
I, James R. Duffy, Esquire, hereby certify that the original of the
PLAINTIFFS' ANSWERS TO SUPPLEMENTAL INTERROGATORIES (SET II) was
served upon counsel for the defendants by First Class U. S. Mail, postage prepaid, on
the 27th day of September 2000 at the following address:
John W. Dornberger, Esquire
Post & Schell, P.C.
240 Grandview Avenue
Camp Hill, PA 17011
mes R. Duf y,
for Plain iffs
1800 Lawyers Building
428 Forbes Avenue
Pittsburgh, PA 15219
(412) 261-0134
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
REBECCA P. DiDAY and CIVIL ACTION - LAW
ROBERT W. DiDAY, her husband,
Plaintiffs No. 99-4013
VS.
METRO HOTELS, INC., doing business as
RADISSON PENN HARRIS HOTEL, and
PENN HARRIS COMPANY,
Defendants
PRAECIPE TO SETTLE AND
DISCONTINUE
Filed on behalf of REBECCA P. DiDAY and
ROBERT W. DiDAY, her husband, Plaintiffs
Counsel of Record for this Party:
James R. Duffy, Esquire
Pa. I.D. # 10746
1800 Lawyers Building
428 Forbes Avenue
Pittsburgh, PA 15219
(412) 261-0134
(412) 281-3154 - Fax
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
REBECCA P. DIDAY and CIVIL ACTION - LAW
ROBERT W. DIDAY, her husband,
Plaintiffs
VS. No.99-4013
METRO HOTELS, INC., d/b/a
RADISSON PENN HARRIS HOTEL and
PENN HARRIS COMPANY
Defendants
PRAECIPE TO SETTLE AND DISCONTINUE
TO: PROTHONOTARY
SIR:
Kindly mark the docket in the captioned action settled and discontinued.
4m. Duffy,
Attorney for Plai tiffs
1800 Lawyers Building
428 Forbes Avenue
Pittsburgh, PA 15219
DATE: October 25, 2000
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