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11 1
NICHOLAS RHODES,
PETITIONER
V.
MS. LAW, HEALTH CARE
ADMINISTRATOR;
JOHN PALAKOVICH;
MR. KYLER, SUPERINTENDENT;
SCHEIN EYE ASSOCIATES,
RESPONDENTS
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-5680 CIVIL TERM
09-5681 CIVIL TERM
99-5682 CIVIL TERM
99-5683 CIVIL TERM
ORDER OF COURT
AND NOW, this ZIA_day of September, 1999, the four related
separately captioned actions are consolidated under 99-5680 Civil. Petitioner may
proceed in forma pauperis without paying the filing fees and the Sheriff of Cumberland
County is directed to serve respondents with the consolidated complaint.
By the Cop/
Edgar 8.18ayTej, J.
:saa
FILEC-0`FiCF
OA.Ry
99 SrP 21, All 10: gy
CUb1ZL:;L",j r?)UN7Y
PENINS LVANA
9 9- sb sl C,,,x -7,,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CIVIL DIVISION
NICHOLAS RHODES
V
John Palakovich
COMPLAINT
NOTICE OF SUIT
MALPRACTICE - MEDICAL
NOW COMES, Nicholas Rhodes, in the above captioned action to place
this individual on notice of suit and avers the following:
1. Plaintiff is Nicholas Rhodes an inmate which was housed at
SCI-Camp Hill
2. Plaintiff was under the direct care of the above named
defendant
3. Plaintiff comes to this court to place said individual on
notice of suit for malpractice
4. Plaintiff while under the care of Superintendent Kyler
underwent surgery which caused the loss of his eye
5. Plaintiff seeks damages against all persons involved in his
care for the loss of his eye and the pain and suffering he was
forced to endure during this period.
6. Plaintiff is placing all parities on notice due to the fact
that he is incarcerated and may not be able to pursue this in the
courts until he is released because he is indigent at this time
7. Plaintiff also seeks to have the parties responsible arrange to
have his eye cosmetically corrected
8. Plaintiff will seek the assistance of an attorney and will
pursue this issue as soon as possible but this notice is being put
in place in order to insure that his rights are protected by the
Court
8. Plaintiff would consider an out of court settlement in this
action before suit is entered and anyone interested in pursuing an
out of court settlement should contact plaintiff at RD 1 Box 67
Waynesburg Pa 15370
li l . 1\ t& "a
Nicholas Rhodes
Pro se
Dated ? 1999
SEP 17 1999
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CIVIL DIVISION
NICHOLAS RHODES
V
JOHN PALAROVICH
PETITION TO PROCEED IN FORMA PAUPERIS
NOW COMES, NIcholas Rhodes, Pro se in the above captioned action
and avers the following:
1. Petitioner is Nicholas Rhodes an adult individual currently
incarcerated at SCI-Waynesburg.
2. Petitioner comes to this Court to file Notice of Suit in a
civil matter dealing with the loss of his eye during his
incarceration
3. Petitioner is without the funds needed to pay costs and fees in
this case.
4. Petitioner has an average of $20.00 per month in his prison
account.
5. Petitioner does not own a car, home, banking account, savings
account, property or anything of real value at this time.
6. Petitioner has no family or friend that can pay the fees or
costs in this action.
WHEREFORE this petitioner prays that this Court grants this
petition and permits him to proceed in this action without paying
fees or costs.
Nicholas Rhodes
Pro as
Dated: 12
I-qq 1999
.1 o
PROOF OF SERVICE
I Nicholas Rhodes do hereby swear that I did serve a true
and correct copy of the attached Notice of Suit to the
persons listed below individually and in the manner
indicated below
U.S. First Class Mail
John Palakovich
SCI-Camp Hill
Ms. Law Health Care Administrator
SCI-Camp Hill
Schein Eye Associates
Harrisburg Pa.
Mr. Kyler Superintendent
SCI-Camp Hill
Nicholas Rhodes
Pro se
Dated 1999
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