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HomeMy WebLinkAbout99-05682 i I r r Y: ' i ?o r ray?g ? >LY r? ! y 4 Jy?' all, M 1 S ! JnV'' Y yyl?j?yjyIyyyy'?'? ? Y?Ft?3 v r +F M>? Xl y x i ? „F! "J 4iAAtt Tkj t NICHOLAS RHODES, PETITIONER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. MS. LAW, HEALTH CARE ADMINISTRATOR; JOHN PALAKOVICH; MR. KYLER, SUPERINTENDENT; SCHEIN EYE ASSOCIATES, RESPONDENTS 99-5680 CIVIL TERM 99-5681 CIVIL TERM X-5682 CIVIL TERM 99-5683 CIVIL TERM ORDER OF COURT AND NOW, this 2 _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 Cou, Edgar 6.18a-yTej, J. :saa RLFp-4D'FICE CF L:c ur,;"OVd1Y 99 SFP ?lo- AW 10: 34 cur,: r : ;, ccul ITY PE NSYL':",' IIA t 9R- s? s2. SEP 17 1999 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION NICHOLAS RHODES V MR. KYLER SUPERINTENDENT 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 se Dated 24s- 1999 q q - s(, S? a. C?...:2. T-V, ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION NICHOLAS RHODES V MR. KYLER SUPERINTENDENT 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 B. 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 Nicholas -Rhodes Pro se Dated 1, 1999 Y 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 Sohn 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 a , C M ? Q I W ?? r [if u. fC Li: J V: - 4_ I U n j cn c ? 0