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Home My WebLink About03-6123PLAINTIFF CORY A. CORMANY DEFENDANT HAROLD SHEELY, THE : ADMINISTRATION AND STAFF OF THE : CUMBERLAND COUNTY BAR ASSOCIATION, LYLE : HERR, SAMUEL COOVER AND DIRK BERRY OF THE : CUMBERLAND COUNTY COURT HOUSE : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CASE NO. 0,.,q-(oil3 O)~ 1) GRIEVANCE ACTION JURY TRIAL/JUDGMENT NOTICE You have been sued in Court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after the Complaint and Notice are served by entering a written appearance personally or by attorney and by filing in writing with the Court your defense or objection to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and 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 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. Court Administrator Cumberland County Court House 1 South Hanover Street Carlisle, PA. 17013 PLAINTIFF CORY A. CORMANY DEFENDANT HAROLD SHEELY, THE ADMINISTRATION AND STAFF OF THE : CUMBERLAND COUNTY BAR ASSOCIATION, LYLE : HERR, SAMUEL COOVER AND DIRK BERRY OF THE : CUMBERLAND COUNTY COURT HOUSE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CASE NO. ,5~,-3 ' 6 / 1. 3 GRIEVANCE ACTION JURY TRIAL/JUDGMENT GRIEVANCE COMPLAINT AND NOW comes, Cory Cormany; Plaintiff, and sets forth causes of action against the above Defendants, whereof the following is set forth at length: 1. Plaintiff is Cory Cormany, an adult individual residing in Carlisle, Cumberland County, Pennsylvania. 2. Defendant Harold Sheely and associates are adult individuals employed with the Cumberland County Bar Association, Cumberland County, Pennsylvania. individuals County, Pennsylvania. Defendants Lyle Herr, Samuel Coover and Dirk Berry are adult employed by the Cumberland County Court House, Cumberland (1) 4. Plaintiff Cory Cormany is a high school graduate, academically achieved through a university or universities, a taxpayer, a registered voter and a citizen of the United States of America. 5. In and about the year 1985 and through and about the application herein, Plaintiff Cory Cormany was subjugated criminal and civil allegation unconstitutional a due process; hereto the Commonwealth of Pennsylvania. 6. The criminal terms 85-0722, 86-0358, 89-2068, 91-0505, 92-1252, 93-1078, 93~1079, 94-0973, 94-0974, 94-1222, 95-0027 and 95-0376 in the Common Pleas Court of Cumberland County is in accordance with the solicit ramifications litigated in the civil case 1:CV-95-0844 filed in the United States District Court for Pennsylvania. 7. The criminal terms 94-1222, 95-0375 and 95-0376 in the Common Pleas Court of Cumberland County is in accordance with the procedural obligations stated in the civil cases 95-5222, 96-1730 and 96-1969 filed in the Cumberland County Common Pleas Court for Pennsylvania. 8. The criminal terms 96-1584, 97-0174, 97-1443, 97-1444, 97-1445, 97-1446, 97-1447, 97o1448, 97-1504 and 97-1701 in the Common Pleas Court of Cumberland County is in accordance with the solicit ramifications litigated in the civil case I:CV-01-1803 filed in the United States District Court for Pennsylvania. 9. The criminal terms 97-1504, 01-0092 through 01-0097 in the Common Pleas Court of Cumberland County is in accordance with the procedural obligations stated in the civil cases 96-4435, 01-1727 and 01-6467 filed in the (2) Cumberland County Common Pleas Court for Pennsylvania. 10. On December 19th, of the year 1990, Defendant Lyle Herr complained of an argumentative conversation, allegory the Plaintiff Cory Corrnany, and did later contradict such stipulated implication, as in accordance with a Ms. Tina Adams and the Common Pleas Court of Cumberland County. 11. In or about the month of February 1996, Plaintiff Cory Cormany was directed and ordered a psychiatric review, as in accordance with the Defendant Harold Sheely, which did consequently breach an agreement in the Common Pleas Court of Cumberland County. 12. On October 2nd, of the year 2001, Defendant Samuel Coover compiled a reactionary assault team, explicit the Plaintiff Cory Cormany, and did later excuse such stipulated implication, as in accordance with a Mr. David MacMain and the Common Pleas Court of Cumberland County. 13. In and about the month of January 2002, Plaintiff Cory Cormany was directed and ordered a subpoena appearance, as in accordance with the Defendant Dirk Berry, which did deface a criminal element in the Common Pleas Court of Cumberland County. 14. The case numbers 94-1679, 95-0310 and 01-6467 in the Common Pleas Court of Cumberland County do collaborate a Mr. Raymond Motter, a Mr. John Adams, and a Mr. Carl Heyward; allegary illicit narcotic activity witnessed by the Plaintiff Cory Cormany in the Commonwealth of Pennsylvania. 15. The Commonwealth of Pennsylvania has convicted Mr. Carl (3) Dis~ict Coua of the accordance with the Pennsylvania. Heyward, Mr. John Adams and Mr. Raymond Motter of crimes identified and associated with illegal narcotic actions, as in accordance with the Controlled Substance Act set forth by the United States of America. 16. The Plaintiff Cory Cormany has acknowledged Criminal, Civil and Actual issues of malice identified and associated with unconstitutional public actions, as in accordance with the Post Conviction Act set forth by the United States of America. 17. The case numbers 1:CV-95-0844 and 1:CV-01-1803 in the Middle United States were adjudicated and dismissed, as in rules of court set forth by the Commonwealth of 18. On June 7th, of the year 2002, the Plaintiff Cory Cormany required an expensive civil complaint responsible the Commonwealth of Pennsylvania, and sufficient a procedure as in accordance with P.S.A. 42 R.C.P. 205.2, 227.4, 239 and P.S.A. 42 J.J.P. 5304, 5306 and 5307. 19. On March 15th, of the year 2002, the Plaintiff Cory Cormany filed several reports liable the Attorney General's Office and argumentative a state procedure, as in accordance with P.S.A. 42 R.C.P. 132, 133, 134 and P.S.A. 42 J.J.P. 1513, 1514 and 1515. 20. The Commonwealth of Pennsylvania did precede criminal allegations slanderous a confliction of interest, and noncertified an official service, for the case number 01-209 l; naming the Plaintiff Cory Cormany a defendant substantial (4) a County Detective William Diehl. 21. The Commonwealth of Pennsylvania did proceed criminal commitments malicious a prosecutorial conduct and noncertified an official appearance; usable the Defendants Lyle Herr, Samuel Coover and Dirk Berry as in disaccordance with P.S.A. 42 R.C.P. 58, 71, 84, 85, 113, 122, 124 and 134. 22. The Commonwealth of Pennsylvania did precede criminal propaganda solicit a careful liability, and certified an official accusation, for the case number 01-0494; naming the Plaintiff Cory Cormany a defendant substantial a County Attorney Edmund Zigmund. 23. The Commonwealth of Pennsylvania did proceed criminal hearings conspiratorial an act of justice and certified an official position; usable the Defendants Harold Sheely and associates as in disaccordance with P.S.A. 42 R.C.P. 58, 65, 66, 101, 102, 110, 123 and 130. 24. The intentional and criminal ramifications demonitized in the case numbers 85-0722, 86-0358, 89-2068, 91-0505, 92-1252, 93-1078, 93-1079, 94- 0973, 94-0974, 0174, 97-1443, 94-1222, 95-0027, 95-0374, 95-0375, 95-0376, 96-1584, 97- 97-1444, 97-1445, 97-1446, 97-1447, 97-1448, 97-1504, 97- 1701, 01-0092, 01-0093, 01-0094, 01-0095, 01-0096 and 01-0097, decidable the Common Pleas Court of the Cumberland County, are in disaccordance with the Commonwealth and United States Constitutions. 25. The compensatory and punitive ramifications remedialized in the case numbers 95-5222, 96-1969, 01-6467 and 03-1778, convincible the Common Pleas (5) Court of the Cumberland County, are in disaccordance with the Commonwealth and United States Constitutions. 26. The Plaintiff Cory Cormany has suffered public humiliation as caused by the defmnation of his character, pain and physical injury as a result of the Defendants' malicious m~d prejudicial actions. 27. The Plaintiff Cory Cormany has suffered mental anguish, emotional distress, imprisonment, loss of employment and inherent right as a result of the Defendants' malicious and prejudicial actions. 28. The Plaintiff Cory Cormany has suffered lost wages, benefits, fees and property in the mount in excess of Two Htmdred and Fifty Thousand and 00 Dollars (250,000.00) as result of the Defendants' malicious and prejudicial actions. (6) COUNT ONE CORY A. CORMANY V. HAROLD SHEELY AND ASSOCIATES GRIEVANCE ACTION WILLFUL MISCONDUCT 29. The averments set forth in Paragraphs one through twenty eight (1-28) of the Grievance Complaint are incorporated by reference as if set forth as a statement. 30. The prejudicial and malicious matters and actions are serious as having happened in the Cumberland County, Pennsylvania, respectfully submissive the order of the court and exhibits A through I. 31. Preceding the situations and circumstances defined in the aforementioned statements, the Plaintiff Cory Cormany was not ever empowered a lawful servitude for the purpose of a pursuit in happiness, nor was he ever petitioned with a serviceable indictment for the purpose of an immunological warrant. 32. The Defendant Harold Sheely did implement policy and directive within or throughout the incidents and issues in question, and does have supervisory power unconstitutional an effective legislative, judiciary or executive procedure. 33. The Plaintiff Cory Cormany did suffer pain for injuries felt and (7) sustained, mental anguish, public humiliation, emotional distress, loss of inherent right, loss of employment and property, confinement and incarceration. 34. By reason of the aforesaid matter, Plaintiff Cory Cormany has suffered pain, injury, mental anguish, public humiliation, emotional distress, loss of inherent right, loss of employment and property, confinement and incarceration. WHEREFORE, the Plaintiff Cory Cormany, claims from the Defendant in an amount in excess of Two Hundred and Fifty Thousand and 00 Dollars (250,000.00) plus cost of suit. (8) COUNT TWO CORY A. CORMANY V. LYLE HERR GRIEVANCE ACTION WILLFUL MISCONDUCT 35. The averments set forth in Paragraphs one through twenty eight (1-28) of the Grievance Complaint are incorporated by reference as if set forth as a statement. 36. The prejudicial and malicious matters and actions are serious as having happened in the Cumberland County, Pennsylvania, respectfully submissive the order of the court and exhibits A through I. 37. Preceding the situations and circumstances defined in the aforementioned statements, the Plaintiff Cory Cormany was not ever depositioned for the purpose of probable cause, nor was he ever serviced with an arbitrary reason of indifference for the purpose of an immunological affirmation. 38. The Defendant Lyle Herr did implement policy and directive within or throughout the incidents and issues in question, and does have supervisory power unconstitutional an effective legislative, judiciary or executive procedure. 39. The Plaintiff Cory Cormany did suffer pain for injuries felt and sustained, mental anguish, public humiliation, emotional distress, loss of inherent right, loss of employment and property, confinement and incarceration. (9) 40. By reason of the aforesaid matter, Plaintiff Cory Cormany has suffered pain, injury, mental anguish, public humiliation, emotional distress, loss of inherent right, loss of employment and property, confinement and incarceration. WHEREFORE, the Plaintiff Cory Cormany, claims from the Defendant in an amount in excess of Two Hundred and Fifty Thousand and 00 Dollars (250,000.00) plus cost of suit. (10) COUNT THREE_ CORY A. CORMANY V. SAMUEL COOVER GRIEVANCE ACTION WILLFUL MISCONDUCT 41. The averments set forth in Paragraphs one through twenty eight (1-28) of the Grievance Complaint are incorporated by reference as if set forth as a statement. 42. The prejudicial and malicious matters and actions are serious as having happened in the Cumberland County, Pennsylvania, respectfully submissive the order of the court and exhibits A through I. 43. Preceding the situations and circumstances defined in the aforementioned statements, the Plaintiff Cory Cormany was not ever depositioned for the purpose of probable cause, nor was he ever serviced with an arbitrary reason of indifference for the purpose of an immunological affirmation. 44. The Defendant Samuel Coover did implement policy and directive within or throughout the incidents and issues in question, and does have supervisory power unconstitutional an effective legislative, judiciary or executive procedure. 45. The Plaintiff Cory Cormany did suffer pain for injuries felt and sustained, mental anguish, public humiliation, emotional distress, loss of inherent right, loss of employment and property, confinement and incarceration. 46. By reason of the aforesaid matter, Plaintiff Cory Cormany has suffered pain, injury, mental anguish, public humiliation, emotional distress, loss of inherent right, loss of employment and property, confinement and incarceration. WHEREFORE, the Plaintiff Cory Cormany, claims from the Defendant in an amount in excess of Two Hundred and Fifty Thousand and 00 Dollars (250,000.00) plus cost of suit. (12) COUNT FOUR CORY A. CORMANY V. DIRK BERRY GRIEVANCE ACTION WILLFUL MISCONDUCT 47. The averments set forth in Paragraphs one through twenty eight (1-28) of the Grievance Complaint are incorporated by reference as if set forth as a statement. 48. The prejudicial and malicious matters and actions are serious as having happened in the Cumberland County, Pennsylvania, respectfully submissive the order of the court and exhibits A through I. 49. Preceding the situations and circumstances defined in the aforementioned statements, the Plaintiff Cory Cormany was not ever summoned with prima-facie cause for the purpose of indictment, nor was he ever dispositioned for the purpose of an immunological service. 50. The Defendant Dirk Berry did implement policy and directive within or throughout the incidents and issues in question, and does have supervisory power unconstitutional an effective legislative, judiciary or executive procedure. 51. The Plaintiff Cory Cormany did suffer pain for injuries felt and sustained, mental anguish, public humiliation, emotional distress, loss of inherent right, loss of employment and property, confinement and incarceration. 03) 52. By reason of the aforesaid matter, Plaintiff Cory Cormany has suffered pain, injury, mental anguish, public humiliation, emotional distress, loss of inherent right, loss of employment and property, confinement and incarceration. WHEREFORE, the Plaintiff Cory Cormany, claims from the Defendant in an amount in excess of Two Hundred and Fifty Thousand and 00 Dollars (250,000.00) plus cost of suit. (14) VERIFICATION I, Cory A. Cormany, Plaintiff in the above captioned action, hereby verify and state that the facts set forth in the Grievance Complaint against Harold Sheely, the Administration and Staff of the Cumberland County Bar Association, Lyle Herr, Samuel Coover and Dirk Berry are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn verification to authorities. Dated Cory A. Cormany (15) CERTIFLCATION OF SERVICE AND NOW, this~i~!- day of /k~u¢ ,.x~6, 200~, I Cory A. Company foregoing the aforesaid matter on behalf of my Attorney, hereby certify that I have served the foregoing document upon the following by depositing a copy of same in the United States Mail, at Carlisle Pennsylvania, addressed as follows: Cmnberland County Bar Association Harold Sheely and Associates 1 South Hanover Street Carlisle, PA 17013 Cumberland County Court House Lyle Herr Samuel Coover Dirk Berry 1 South Hanover Street Carlisle, PA 17013 Cory A. Cormany 1883 Douglas Dr. Carlisle, Pa. 17013 ~ BALTIMORE CITY HEALTH DEPARTMENT NOTIFICATION OF B~RTH REGISTRA~ON ~is ce~ifies thai~ here ~s ~ on file in o~ Or ~la~t~ug,~ Ignix} Mate ~.~.. ~-17269 no21 091 78~ BLU CORY ALISTER CORMANY,,~ 1883 DOUGLAS DRIVE 1/,, ~ t CARLISLE PA 1701.3 ~ .,~ ·. . ..... CUMBERLAND COUNTY, PENNSYLVANIA ADULT PROBATION AND PAROLE DEPARTMENT 1 COURTHOUSE SQUARE CARLISLE, PA 17013 Cory Cormany Imnate Cumberland County Prison Dear Cory, I am in receipt of your request and I believe ][ found the petition that you were interested in. It was filed on 12-!9-90. Again, I must remind you that all official records are kept in the Cumberland County Clerk of Courts Office. S~incer ely.,.-~ Lyle Herr Supervisor Telephone Toll Free Adult Probation Costs/~nes Shipponsburg (717) 240-6255 (717) 240-6275 (717) 532-7286 FAX# 240-64~0 Telephone Toll Free DUi Programs West Shore (717) 240-6280 (717) 607-0371 IN RE: ADOPTION OF ALEXANDRIA CHRISTINE CORMANY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION NO. 64 ADOPTIONS 1993 IN RE: REQUEST FOR INVOLUNTARY TERMINATION OF PARENTAL RIGHTS BEFORE OLER, J. DECREE NISI AND NOW, this {~ day of August, 1994, upon careful consideration of the request for involuntary termination of parental rights and Cory Cormany's response to the request, and following a hearing thereon: The Court, being satisfied as to the truth of the facts set forth in the request, and that the request should be granted, so finds, and further finds that Cory Cormany has forfeited his parental rights to Alexandria Christine Cormany, and it is adjudicated, adjudged, and decreed that all parental rights of Cory Cormany with respect to Alexandria Christine Cormany are terminated forever. This Decree shall become a Final Decree unless a post-trial motion is filed within ten days pursuant to Pennsylvania Rule of Civil Procedure 227.1. Petitioner's counsel is establishment of a time If no such post-trial motion is filed, directed to contact the Court for the for the adoption proceeding. BY THE COURT, J esley OlerO ., J. ~ubert X. Gilroy, Esq. 4 N. ~anover Street Carlisle, PA 17013 Attorney for Petitioner tory Cormany ~1883 Douglas Drive Carlisle, PA 17013 Natural Father Pro Se IN RE: : : ADOPTION OF : ALEXANDRIA CHRISTINE CORMANy : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION NO. 64 ADOPTIONS 1993 IN RE: REQUEST FOR INVOLUNTARY TERMINATION OF PARENTAL RIOHTS BEFORE OLER, J. OPINION and DECREE NISI For disposition at this time is a request for involuntary termination of parental rights.~ The request seeks the involuntary termination of the parental rights of Cory Cormany (Natural Father) with respect to his minor child Alexandria Christine Cormany (Minor Child). A hearing on the matter was held on Monday, May 16, 1994. Based upon the evidence presented at the hearing, the request for involuntary termination of parental rights will be granted. FINDINGS OF FACT 1. On September 7, 1993, a Petition for Adoption of the Minor Child was filed. 2. The Petition for Adoption contained a request for involuntary termination of parental rights, seeking to terminate the Natural Father's parental rights with respect to the Minor Child, preparatory to an adoption of the Minor Child by John D. Adams, Jr. 3. John D. Adams, Jr., the step-father of Minor Child, resides at 384 Crossroad School Road, Newville, Cumberland County, ~ See Act of October 15, 1980, P.L. 934, ~1, 23 Pa. C.S.A. ~2512. No. 64 Adoptions 1993 Pennsylvania. 4. Cory Cormany, the natural father of Minor Child, resides at 1883 Douglas Drive, Carlisle, Cumberland County, Pennsylvania. 5. The natural mother is Tina D. Adams (Natural Mother); she resides with John D. Adams, Jr. and the Minor Child at 384 Crossroad School Road, Newville, Cumberland County, Pennsylvania. 6. The Natural Mother and the Natural Father were married on January 1, 1988; they separated in March of 1989, and were divorced on December 6, 1989. 7. One child was born of the marriage of Tina D. Adams and Cory Cormany: Alexandria Christine Cormany (d.o.b. December 16, 1988). 8. The Minor Child has always resided with her Natural Mother. 9. John D. Adams, Jr., and the Natural Mother were married on November 15, 1992. John D. Adams, Jr. has been residing with the Natural Mother and the Minor Child since January of 1991. 10. The grounds alleged in the request for involuntary termination of parental rights are that the Natural Father has by conduct continuing for a period of at least six months either evidenced a settled purpose of relinquishing parental claim to the Minor Child or has refused or failed to perform parental duties.~ ~ Petition for Adoption, paragraph 12; Act of October 15, 1980, P.L. 934, ~1, as amended 23 Pa. C.S.A. ~2511(a)(1) (1994 Supp.). 2 No. 64 Adoptions 1993 was parents of the Natural Father. 12. Since June of 1992, and immediately preceding the filing of Father did not contact the Natural visitation rights with respect to his Minor Child. 11. The last time that the Natural Father saw his Minor Child in June of 1992 when the Minor Child was visiting with the throughout the six months the petition, the Natural Mother to seek custody or 13. Since June of 1992, and throughout the six months immediately preceding the filing of the petition, the 'Natural Father did not attempt to contact his Minor Child either by telephone or through letters. 14. Since June of 1992, and throughout the six months immediately preceding the filing of the petition, the Natural Father did not send his Minor Child a birthday gift or a Christmas card. 15. Since June of 1992, and throughout the six months immediately preceding the filing of the petition, the Natural Father did not provide any financial support for his Minor Child. 16. The Natural father has been incarcerated on occasion. 17. In a letter sent in August of 1992 (Petitioner's Exhibit No. 2), the Natural Father wrote to the Natural Mother as follows: "Take Alexandria, move somewhere that I nor my family can ever find you, and never contact me nor them again .... As Alexandria grows, it is up to you to teach her, love her and protect her. I will not No. 64 Adoptions 1993 and cannot." 18. In a letter sent in December of 1992 (Petitioner's Exhibit No. 4), the Natural Father wrote to the Natural Mother as follows: "I cannot handle any type of visitation." 19. The Court finds that the Natural Father has by his conduct for a period well in excess of six months immediately preceding the filing of the petition abandoned his Minor Child by evidencing a settled purpose of relinquishing parental claim to her and has refused or failed to perform his parental duties during such period. 20. Since commencement of residence with the Natural Mother, John D. Adams, Jr., has treated the Minor Child as his own, and the Minor Child has come to regard John D. Adams, Jr., as her father. 21. The Minor Child refers to John D. Adams, Jr., as Daddy and to the Natural Father as Uncle Cory. 22. John D. Adams, Jr., is currently unemployed. 23. John D. Adams, Jr., has been diagnosed as having Multiple Sclerosis. 24. The medical condition of John D. Adams, Jr., does not adversely affect his ability to be a father; John D. Adams, Jr., without assistance, cares .for the Minor Child every day while the Natural Mother is at work. 25. John D. Adams, Jr., participates in extra-curricular activities with the Minor Child; he coaches the Minor Child's T- No. 64 Adoptions 1993 ball team. 26. John D. Adams, Jr., financially supports the Minor Child by means of his Social Security benefits. 27. The termination of the parental rights of Cory Cormany, with a view toward adoption by John D. Adams, Jr., will serve the needs and welfare of the Minor Child. 28. The foregoing Findings of Fact are made on the basis of clear and convincing evidence. a STATEMENT OF LAW Under Section 2511(a)(1) of the Adoption Act, "[t]he rights of parent in regard to a child may be terminated after a petition filed on [the ground that t]he parent by conduct continuing for a period of at least six months immediately preceding the filing of the petition either has evidenced a settled purpose of relinquishing parental claim to a child or has refused or failed to perform parental duties."3 The Act further provides as follows: The court in terminating the rights of a parent shall give primary consideration to the needs and welfare of the child. The rights of a parent shall not be terminated solely on the basis of environmental factors such as inadequate housing, furnishings, income, clothing and medical care if found to be beyond the control of the parent. With respect to any petition filed pursuant to subsection (a) (1)..., the court shall not consider any efforts by the parent to remedy the conditions ~ Act of October 15, 1980, P.L. 934, ~1, as amended, 23 Pa. C.S.A. ~2511(a)(1) (1994 Supp.). 5 No. 64 Adoptions 1993 described therein which are first initiated subsequent to the giving of notice of filing of the petition? "The evidentiary standard for terminating parental rights was formulated by the United States Supreme Court which established that parental rights may not be terminated in the absence of clear and convincing evidence." In re Adoption of Hamilton, 379 Pa. Super. 274, 278, 549 A.2d 1291, 1293 (1988), citing Santosky v. Kramer, 455 U.S. 745, 102 S. Ct. 1388, 71 L. Ed. 2d 599 (1982). "This principle requires evidence which is 'so clear, direct, weighty, and convincing as to enable the [factfinder] clear conviction without hesitancy of the truth of facts in issue.'"s to come to a the precise The process by which an issue of involuntary termination has traditionally been analyzed has been described as follows: [O]nce the court has determined that the requirements for involuntary termination of parental rights pursuant to 23 Pa. C.S.A. S2511(a) have been met, the court must further inquire whether termination will clearly serve the "needs and welfare" of the child. In answering that question, "it is the child's welfare that is paramount." In re E.S.M., 424 Pa. Super. 296, 304, 622 A.2d 388, 392-93 (1993), 4 Act of October 15, 1980, P.L. 934, §1, as amended, 23 Pa. C.S.A. ~2511(b) (1994 Supp.). s In re Adoption of Hamilton, 379 Pa. Super. 274, 278, 549 A.2d 1291, 1293 (1988), quoting In re Shires, 363 Pa. Super. 225, 227-28, 525 A.2d 801, 802 (1987). 6 No. 64 Adoptions 1993 quoting In re Adoption of Hamilton, 379 Pa. Super. 274, 280-81, 549 A.2d 1291, 1294 (1987). APPLICATION OF LAW TO FACTS In the present case, the Court has found that the statutory requirements for termination under Section 2511(a)(1) of the Adoption Act have been satisfied by clear and convincing evidence, in that the Natural Father has abandoned his Minor Child and has refused or failed to perform his parental duties for the requisite period. In addition, the Court has found that the best interests of the Minor Child will be facilitated by the termination of parental rights here sought and the prospective adoption by John D. For these reasons, the following Decree Nisi will be Adams, Jr. entered:~ DECREE NISI AND NOW', this t~t~ day of August, 1994, upon careful consideration of the request for involuntary termination of parental rights and Cory Cormany's response to the request, and following a hearing thereon: The Court, being satisfied as to the truth of the facts set forth in the request, and that the request should be granted, so finds, and further finds that Cory Cormany has forfeited his parental rights to Alexandria Christine Cormany, and it is 1141 ~ See In re Adoption of C.R.V., (1991.). 7 408 Pa. Super. 386, 596 A.2d No. 64 Adoptions 1993 adjudicated, adjudged, and decreed that all parental rights of Cory Cormany with respect to Alexandria Christine Cormany are terminated forever. This Decree shall become a motion is filed within ten days Civil Procedure 227.1. If no Final Decree unless a post-trial pursuant to Pennsylvania Rule of such post-trial motion is filed, Petitioner's counsel is directed to contact the Court for the establishment of a time for the adoption proceeding. BY THE COURT, s/ J. Wesley Oler, Jr. J. Wesley Oler, Jr., J. Hubert X. Gilroy, Esq. 4 N. Hanover Street Carlisle, PA 17013 Attorney for Petitioner Cory Cormany 1883 Douglas Drive Carlisle, PA 17013 Natural Father Pro Se STATEMENT The below signed solemnly swear that on or about October 2nd, of the year 2001, Mr. Samuel Coover of the Cumberland County Prison did instruct and inform a violent involuntary ramification submissive an aggressive incident, constitutional a sadistic right, in the Cumberland County Prison. Print Print Print Print Sign sign Sign Sign Witness 'Cory .4. Cormany Dated . . Dated MONTGOMERY, McCRACKEN, WALKER & R/lOADS, LLP BY: DAVID J. MACMAIN IDENTIFICATION NO. 59320 123 S. BROAD STREET PHILADELPHIA, PA 19109 (215) 772-1500 ATTORNEY FOR DEFENDANT MATTHEW KENNEDY CORY A. CORMANY, Plaintiff, V. : : EARL REITZ JR., STEVE CALAMAN, : FRANK TEANEY, CARL HEYWARD : OF THE CUMBERLAND COUNTY : PRISON, MATHEW KENNEDY OF : THE CARLISLE POLICE DEPARTMENT,: WILLIAM DIEHL OF THE CUMBERLAND COUNTY D.A. AND PAULA CORREAL, Defendants. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL ACTION -Law NO. 01-6467 CIVIL TERM ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance in the matter captioned above on behalf of Defendant Matthew Kennedy. MONTGOMERY, McCRACKEN, WALKER & RHOADS, LLP I.D. No. 593~ 123 S. Broad'Street Philadelphia, PA 19109 (215) 772-1500 COMMONWEALTH CORY ALLISTER CORMANY OTN: E679706-6 E965660-3 E726607-0 E004022-4 IN THE COURT OF COM}(0N PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94-1222 CRIMINAL TERM CHARGE: (B) FALSE SWEARING AFFIANT: DET. RONALD EGOLF 95-0027 CRIMINAL TERM CHARGE: (A) PUBLIC DRUNI<ENNESS AFFIANT: SGT. RICHARD SMIT~ 95-0375 CRIMINAL TERM CHARGE: (F) UNAUTHORIZED USE OF AUTOMOBILE AFFIA/~T: DET. JOH~'S~-~CE~!TO 95-03?6 CRIMINAL TERM CHARGEs (A) SIMPLE ASSAULT AFFIANT: PTL. LARRY KELL IN RE: SENTENCING ORDER OF COURT AND NOW, this 6th day of June, 1995, the Defendant% Cory Allister Cormany, now appears for sentence on the above charges represented by H. Anthony Ada/ns, Esquire, Assistant Public Defender. Pleas were previously entered to the above charqes. The Defendant now appears for sentence accordingly. To 94-1222, Count B, False Swearing, a second degree misdemeanor, sentence of the Court is the Defendant pay the costs of prosecution and undergo imprisornnent in the Cum~berland County Prison for not less than 1 month nor more than 23 months. Sentence to date from today. To 95-0027, Count A, Public DrunkenneSs, a stunmary offense, sentence of the Court is the Defendant pay costs of prosecution and a fine of $25.00. To 95-0375, sentence of the Cour~ is the Defendant pay the costs of prosecution and undergo imprisonment in the Cumberland County Prison for not less than I month nor more than 23 months. Sentence to run from today and run concurrent with the sentence imposed to the above charge of False Swearing. To 95-0376, Count A, Simple Assault, sentence of the Court is the Defendant pay the costs of prosecution and undergo imprisonment in the Cumberland County Prison for not !ez~ than 3 months nor more ::ham 23 ~o~ths. Sentence to date from today. The Defendant to be given credit for 27 days previously served. Also to 95-0027, Count A, by agreement of'the District Attorney, the 1981 ~onda motorcyole that was seized by the police in connection with that incident shall be returned to tSe Defendant.' By the Court, Sr. Assistant District Attorney H. Anthony Adams, Esquire Assistant Public Defender Probation mal COMMONWEALTH V. CORY ALLISTER CORMANY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94-1222 CRIMINAL TERM CHARGE: (B) FALSE SWEARING 95-0027 CRIMINAL TERM CHARGE: (A) PUBLIC DRUNKENNESS 95-0375 CRIMINAL TERM CHARGE: (F) UNAUTHORIZED USE OF AUTOMOBILE 95-0376 CRIMINAL TERM CHARGE: (A) SIMPLE ASSAULT ORDER OF COURT AND NOW, this 12th day of FEBRUARY, 1996, the Court notes that the defendant has served many months over his minimum sentence. The Court will consider parole for the defendant if he agrees to an evaluation to be conducted by Rocco Manfredi, M.D. If the defendant will comply with any treatment recommendations required by Dr. Manfredi and agrees before me in Court to all treatment recommendations, I will place him on parole for the balance of the above sentences. Thomas Placey, Esq. District Attorney's Office Michael Scherer, Esq. For the Defendant By the Court, Harold E. Sheely, Michael Piper Probation COMMONWEALTH OF PENNSYLVANIA VS CORY A. CORMANY (Name of Defendant} IN THE CRIMINAL COURTS O~ THE COUNTY OF Cri~ninal Action No. ~ of 1~94 1995 0376 1995 ORDER 19__ AND NOW this 14th day of FEBRUARY , 19 96 Upon consideration of the foregoing motion: 1. [] The motion is returned to defendant for amendment as follows, such amendment to be made on or before · ]9 2. [] A rtHe is granted upon the Commonwealth of Pennsylvania to show cause why a hearing should not be granted. The rule is returnable on or before 19 3. ~] The request to proceed as a poor person, without the payment of costs, is [] granted 4. ~/Upon finding that defendant is unable to obtain a lawyer MI-CHAEL SCHERER ed to represent him. 5. '~The Clerk of this Court is ordered and directed to do the following forthwith: (a) To serve a copy of this motion and this order upon the District Attorney of (b) To send a copy of this motion and this order to MICHAEL $CHERER (c) To send a copy of this order to the defendant. [] denied. Esq., is appoir, tq CUHBE RLAND County. Esq., the lawyer for the defendant. The Defendan&-ti~ .-gJ~y:a'n, q20;>da~ to file an amended petit_iDb ~ aver any additional grounds for rel'~of after consultatJ~on w:Lth ¢o_~ns~.. There- after, the D~$tr.l,¢~ Attorney.%s, ~xven 20 days mmre to fxl~--Dn answer. If issues of '~&~t'~e :raised, ~he District Attorney sh~'~l~equest a hearing; ~f nQt, '~e' ~,S.~d~i.rected, ~o forthwith list the",~a~.~ for tIGINAL 7 CUMBERLAND COUNTY PRISON REQUEST FORM unto fi'- ..< SECURITY STAFF TREATMENT STAFF [] WARDEN ~ DEPUTY WARDEN-TREATMENT DEPUTY WARDEN-SECURITY [-I WORK RELEASE MANAGERS DEPUTY WARDEN-OPERATIONS [] MEDICAL DEPARTMENT TRAINING SPECIALIST EARNED T13/iE CASE MANAGER [] ACCOUNTS OFFICER [] DRUG/ALCOHOL CASE MANAGER [] RECORDS DEP3_RTMENT ~ MAJNTENANCE DEP)d~TMENT [] CORRECTIONAL COUNSELOR ~ PSYCHOLOGIST Shiftleader: [] CHAPLAIN [] INSTITUTIONAL PAROLE OFFICER BE SPECIFIC IN EXPLAINING REOUEST ANSWERED BY: GEN-5 DATE: ~/'7/~- % James K. Jones, Esquire Dirk E. Berry, Esquire THE LAW OFFICE OF JAMES K. JONES, ESQUIRE ATTORNEY AND COUNSELOR IN THE GENERAL PRACTICE OF THE LAW 7 IRVINE ROW CARLISLE, PA 17013-30'19 Telephone (717) 240-0296 Fax (7'~ 7) 240-0066 Emai{: JKJONESY @ aol.com December 19, 2001 Cory A. Cormany Cumberland County Prison 1101 Clammont Road Carlisle, PA 17013 RE: Docket file CR-574-01 Dear Mr. Cormany: The case number that you have requested is 01-0494; resisting arrest or other law enfomement. This is the case that was bound over at the preliminary hearing which you refused to be present for. Regarding the other matters, please be advised that I will not take any of your civil malpractice cases. If you have any questions or concerns, please do not hesitate to contact me. Sincerely yours, Law Office of James K. Jones, Esquire Esquire DB/sed James K. Jones, Esquire Dirk E. Berry, Esquire THE LAW OFFICE OF JAMES K. JONES, ESQUIRE ATTORNEY AND COUNSELOR IN THE GENERAL PRACTICE OF THE LAW 7 IRVINE ROW CARLISLE. PA 17013-3019 Telephone (717) 240-0296 Fax (717) 240-0066 Email: JKJONESY ~ aol.com January 10, 2002 Cory A. Cormany Cumberi~td Coanly Pri5o~ 1101 Claremom Road Carlisle, PA 17013 RE: Response to letter of January 8, 2002 Dear Mr. Cormany:. I have reviewed your letter dated January 8, 2002. Your letter does not make sense, nor does it appear to bear on any issue relevant to docket number 01-0494. Please allow me to reiterate my position regarding your case. I have been appointed to represent you regarding docket number 01-0494. 1 have previously represented you at docket number 01-0432, wherein yqu were found not guilty at summary trial. However, the only matter that I currently represent you on is docket number 01-0494, resisting arrest or other law enforcement. Formal arraignment on that charge is scheduled for January 25, 2002. I do not represent you, nor will I represent you, on any private or civil matter. Nor will I comment on, or participate in, any petitions relating to any other matter outside of criminal docket number 01-0494. If you have any questions or concerns, please do not hesitate to contact me. Sincerely yours, Law Office of James K. Jones, Esquire Dir'~-g?qg~, Esquire DB/sed THE COURT OF COMMON PLEAS CUMBERLAND COUNTY THE COMMONWEALTH OF PENNSYLVANIA CORY A. CORMANY : CASE NO. r;,V. VVO COMMONWEALTH : OTN:PA 0211500 : CIVIL ACTION ~ CRIMINAL L~X~V ~ JURY TRIAL DOCKET FILE: NOTICE You have been sued in Court. If you w'ish to defend against the claim set forth in the tbllowing pages, you must take action within twenty (20) days after the Complaint and Notice are served by entering a written appearance personally or by attorney and by filing in writing with the Court your defense or objection to the claims set tbrth against you. You are warned that if you fail to do so the case may proceed without you and 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 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 AFFORE ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO ;'IND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Court House I South Hanover Street Carlisle, PA. 17013 Attorney General U. S. District Court 228 Walnut Street Harrisburg, PA 17101 Defendant: Lyle Herr Samuel Coover Dirk Berry I, Cory A. Cormany, being a citizen of the United States of America, do hereby state and swear that at or about April 16th, of the year 1986, and through and about a judgmental action, the above named defendant did commit the following crimes: 1) 901. Criminal Attempt - a person commits an attempt when, with intent to commit a specific crime, he does any act which constitutes a substantial step toward the commission of that crime. 2) 2701. Simple Assault - a person is guilty of assault if he: (1) attempts to cause or intentionally, knowingly or recklessly causes bodily injury to another; (2) negligently causes bodily injury to another with a deadly weapon; or (3) attempts by physical menace to put another in fear of imminent serious bodily injury. 3) 2705. Recklessly Endangering Another Person - a person commits a misdemeanor of the second degree if he recklessly engages in conduct which places or may place another person in danger of death or serious bodily injury. 4) 2706. Terroristic Threats - a person is guilty of a misdemeanor of the first degree if he threatens to commit any crime of violence with intent to terrorize another or cause evacuation of a building, place of assembly, or facility of public transportation, or otherwise to cause serious public inconvenience or in reckless disregard of the risk of causing such terror or inconvenience. 5) 2709. Harassment ~ a person commits a summary offense when, with intent to harass, annoy or alarm another person: (1)he strikes, shoves, kicks or otherwise subjects him to physical contact, or attempts or threatens to do the same, or (2) he follows a person in or about a public place or places; or (3) he engages in a course of conduct or repeatedly commits acts which alarm or seriously annoy such other person and which serve no legitimate purpose, 6) 7) 8) 9) lO) 12) 2902. Unlawful Restraint - a person commits a misdemeanor of the first degree if he knowingly: (1) restrains another unlawfully in circumstances exposing him to risk of serious bodily injury; or (2) holds another in a condition of involuntary servitude. 2903. False Imprisonment - a person commits a misdemeanor of the first degree if he knowingly restrains another unlawfully so as to interfere substantially with his liberty. 2906. Criminal Coercion - a person is guilty of Criminal Coercion if with intent to unlawfully restrict fi:eedom of action of another to the detriment of the other, he threatens to: (1) commit any criminal offense; (2) accuse anyone of a criminal offense; (3) expose any secret tending to subject any person to hatred, contempt or ridicule; or (4) take or withhold action as an official; or cause an official to take or withhold action. 3105. Prompt Complaint - a prompt reporting of public authority is not required in a prosecution under this chapter: Provided, however, that nothing in this section shall be construed to prohibit a defendant from introducing evidence of the alleged victim's failure to promptly report the crime if such evidence would be admissible pursuant to the rules of evidence. 3107. Resistance Not Required - the alleged victim need not resist the actor in prosecution under this chapter: Provided, however, that nothing in this section shall be construed to prohibit a defendant from introducing evidence that the alleged victim consented to the conduct in question. 3126. Indecent Assault - a person who has indecent contact with another not his spouse, or causes such other to have indecent contact with him is guilty of indecent assault a misdemeanor of the second degree if: (1) he does so without the consent of the other person; (2) he knows that the other person suffers from a mental disease or defect which renders him or her incapable of appraising the nature of his or her conduct; (3) he knows that the other person is unaware that an indecent contact is being committed; or (5) the other person is in custody of law or detained in a hospital or other institution and the actor has supervisory or disciplinary authority over him. 4111. Fraud in Insolvency - a person commits a misdemeanor of the second degree if, knowing that proceedings have been or are about to be instituted 13) 14) 15) 16) 17) for the appointment of a receiver or other person entitled to administer property for the benefit of creditors, or that any other composition or liquidation for the benefit of creditors has been or is about to be made he: (1) destroys, removes, conceals, encumbers, transfers, or otherwise deals with any property with intent to defeat or obstruct the claim of any creditor, or otherwise to obstruct the operation of any law relating to administration of property for the benefit of creditors; (2) knowingly falsifies any writing or record relating to the property; or (3) knowingly misrepresents or refuses to disclose to a receiver or other person entitled to administer property for the benefit of creditors, the existence, amount or location which the actor could be legally required to furnish in relation to such administration. 4114. Securing Execution of Documents by Deception - a person commits a misdemeanor of the second degree if by deception he causes another to execute any instrument affecting or purporting to affect or likely to affect the pecuniary interest of any person. 4305. Dealing in Infant Children - a person is guilty of a misdemeanor of the first degree, if he deals in humanity, by trading, bartering, buying, selling, or dealing in infant children. 4501. Definitions "Harm" - loss, disadvantage or injury, or anything so regarded by the person affected, including loss, disadvantage or injury to any person or entity in whose welfare he is interested. 4702. Threats and Other Improper Influences in Official or Political Matters - a person commits an offense if he: (1) threatens unlawful harm to any person with intent to influence his decision, opinion, recommendation, vote or other exercise of discretion as a public servant, party official or voter. 5107. Aiding Consummation of a Crime - a person commits an offense if he intentionally aids another to accomplish an unlawful object of a crime, as by safeguarding the proceeds thereof or converting the proceeds into negotiable funds. 5108. Compounding - a person commits a misdemeanor of the second degree if he accepts or agrees to accept any pecuniary benefit in consideration of refraining from reporting to law enforcement authorities the commission or suspected commission of any offense or information relating to an offense. 19) 5301. Official Oppression - a person acting or purporting to act in an official capacity or taking advantage of such actual or purporting capacity commits a misdemeanor of the second degree if knowing that his conduct is illegal, he (1) subjects another to arrest, detention, search, seizure, mistreatment, dispossession, assessment, lien or other infringement of personal or property rights; or (2) denies or impedes another in the exercise of enjoyment of any right, privilege, power or immunity. 2o) 5302. Speculating or Wagering on Official Action or Information - a public servant commits a misdemeanor of the second degree if in contemplation of official action by himself or by a governmental unit with which he is associated, or in reliance on information to which he has access in his official capacity and which has not been made public he: (1) acquires a pecuniary interest in any property, transaction or enterprise which may be affected by such information or official action; (3) aids another to do any of the foregoing. 901 - 1972, Dec. 2701 - 1972, Dec. 2705 - 1972, Dec. 2706 - 1972, Dec. 2709 - 1972, Dec. 2902 - 1972, Dec. 2903 - 1972, Dec. 2906 - 1972, Dec. 3105 - 1972, Dec. 3107 - 1972, Dec. 3126 - 1972, Dec. 4111 - 1972, Dec. 4114 - 1972, Dec. 4305 - 1972, Dec. 4501 - 1972, Dec. 4702 - 1972, Dec. 5107 - 1972, Dec. 5108 - 1972, Dec. 5301 - 1972, Dec. 5302 - 1972, Dec. 6, P.L. 1482 6, P.L. 1482. 6, P.L. 1482. 6, P.L. 1482. 6, P.L. 1482. 6, P.L. 1482 6, P.L. 1482 6, P.L. 1482. No. 6, P.L. 1482 No. 6, P.L. 1482 No. 6, P.L. 1482. No. 6, P.L. 1482 No. 6, P.L. 1482 No. 6, P.L. 1482 No. 6, P.L. 1482, No. 6, P.L. 1482, No. 6, P.L. 1482, No. 6, P.L. 1482, No. 6, P.L. 1482, No. 6, P.L. 1482, No. No. No. No. No. No. No. No. 334, 1, effective June 6, 334, 1, effective June 6, 334, 1, effective June 6, 334, 1, effective June 6, 334, 1, effective June 6, 334, 1, effective June 6, 334, 1, effective June 6, 334, 1, effective June 6, 334 1, effective June 6, 334 334 334 334 334 334 334 334 334 334 334 1, effective June 6, 1, effective June 6, 1, effective June 6, 1, effective June 6, 1, effective June 6, 1, effective June 6, 1, effective June 6, 1, effective June 6, 1, effective June 6, 1, effective June 6, 1, effective June 6, 1973. 1973. 1973. 1973. 1973. 1973. 1973. 1973. 1973. 1973. 1973. 1973. 1973. 1973. 1973. 1973. 1973. 1973. 1973. 1973. I, Cory Cormany, hereby verify that the facts set forth in the above are true and correct to the best of my knowledge or information and belief and that any false statements herein are made subject to the penalties of Section 4904 of the Crimes Code (18 Pa. C.S. 4904), relating to unswom falsification to authorities. Dated INCIDENT REPORT Criminal Attempt: In that Lyle Herr, Samuel Coover and Dirk Berry did intentionally attempt to commit a crime substantial a Defendant or constitutional the Defendants, Simple Assault: In that the Defendants did knowingly and recklessly cause a person bodily harm by a physical menace which did cause an individual imminent fear, also useful a weapon: Recklessly Endangering Another Person: In that the Defendants did cause another person to be put in danger of death and serious bodily injury directional an engagement. Terroristic Threats: In that the Defendants did cause serious inconvenience reckless a violent intent substantial a public place. Harassment: In that the Defendants did repeatedly annoy and alarm an individual subjecting physical contact which did serve no legitimate purpose. Unlawful Restraint: In that the Defendants did support and expose another person to an involuntary servitude conditional a risk of bodily injury. False Imprisonment: In that the Defendants did knowipgly interfere with the liberty of an individual substantial a policy. Criminal Coercion: In that the Defendants did unlawfully cause the restriction of a freedom contemptual the commission of a crime and accussive an official action and hatred. Prompt Complaint: In that the Defendants did construe the prosecution of an indecent evidence within a timely requirement. Resistance Not Required: In that the Defendants did introduce evidence consensual a questionable conduct and reliable a victim. Indecent Assault: In that the Defendants did appraise a course of conduct capable an indecent contact, that did cause a nonconsensual supervisory disciplinary authority to impair another person substantial the prevention of a resistance and a custody. Fraud in Insolvency: In that the Defendants did institute the misrepresentation and appointment of a required fund otherwise beneficial a creditor, and did obstruct a relative information entitled an administrative composition factual a rental property, and liable an existing location encumbersome a claim and submissive a legality. Securing Execution of Documents by Deception: In that the Defendants did affect or purport the pecuniary interest of a person likely a deceptive instrument. Dealing in Infant Children: In that the Defendants did barter in a humanity that did affect a buying and selling of a custody arrangement concerning an infant child. Definitions "Harm": In that the Defendants did take advantage of a person whose welfare they were interested. Threats and Other Improper Influences in Official or Political Matters: In that the Defendants did influence a person intentional a recommendation and unlawful a discretionary vote. Aiding Consummation of Crime: In that the Defendants did intentionally aid one another to accomplish an unlawful objective negotiable a public fund. Compounding: In that the Defendants did accept pecuniary benefits in consideration of refraining to report or represent the suspected commission of a relative offense. Official Oppression: In that the Defendants did purport an official capacity subjective an illegal conduct that did deny and impede another in the exercise of a right and enjoyment; powerful a detention, search, seizure, mistreatment, dispossession and assessment. Speculating or Wagering on Official Action or Information: In that the Defendants are public servants and did contemplate a governmental action reliant an information, and did acquire pecuniary interests in property and transactions intentional the case term 1:CV-95-0844 and the docket files NT-187-00, NT-188-00, NT-189-00, NT-190-00, NT-205-00, NT-748-00, NT-770-00 and NT-839~00 proceeding CR- 574-01 and the case numbers 97-0174 and 01-2091. I petition that a warrant of arrest or a summons be issued and that the Defendant be required to answer the charges I have made. I verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information and belief. This verification is made subject to the penalties of Section 4904 of the Crimes Code (18 Pa. C.S. 4904), relating to unsworn falsification to authorities. Signature Dated Si~{ature Notadal Seal Helen O Sneed, Notary Public Midd;esex Twp., Cumberland County My Commission Expires June 24, 2002 Member, Pennsylvania Association of Notaces AFFIDAVIT On April 16, 1986, I, Cory A. Cormany, did recognize a criminal complaint, problematic an episode and an incident, to Mr. Lyle Herr regarding an alleged altercation said to have occurred in the Borough of Carlisle. Pursuant thereto my acknowledgment, and relevant therein my recognition, the Defendant Lyle Herr did petition the courts of the common pleas, despite my assertive well being, non. justifiable the commission of a crime. The Defendant did state that I had violated a local law, contrary to my due process rights, and did circumvent a detention powerful a constitutional dilemma and the outcome of a trial. Proceeding and prescient the aforementioned circumstance; I was probated and accused a resolution consensual a timely engagement, and was subjected a series of tests that could in no way be responsive a positive outcome. The Defendant Lyle Herr did lie on Sbveral occasions, and did also appraise me applicative an assessment causing me fear, harm and endangerment relative a weapon, and a confinement. On March 28, 1989, I, Cory A. Cormany, did once again recognize a criminal complaint, debatable a traffic offense, to Mr. Lyle Herr regarding an alleged driving under the influence of alcohol said to have occurred in Upper Allen Township. Again pursuant thereto my acknowledgment, and relevant therein my recognition, the Defendant Lyle Herr did petition the courts of the common pleas, despite my assertive well being, brutal the commission of a crime. The Defendant did state that I had violated a local law, contrary to my due process rights, and did endorse a mistreatment suppressive a constitutional dilemma and the outcome of a trial. Preceding and pursuant the aforementioned situation; I was probated and annoyed an accomplishment, nonconsensual a child custody arrangement, and was subjected a pecuniary action reliant an information, and a series of transactions proprietary a right, and contemptual an official hatred. The Defendant Lyle Herr did alarm me and did interfere a risk of bodily injury conditional an involuntary servitude substantial a liberty, and a timely reconciliation. On October 1, 1989, I, Cory A. Cormany, did remand a domestic incident significant my ex-wife, to Ms. Tina Cormany argumentative an alleged trespass said to have occurred in the North Middleton Township. Prior therein my petition, and prescient thereto my advisory, the Defendant Lyle Herr did conversate with Ms. Tina Cormany informing her that she should leave me because I drank and drove an automobile. The Defendant did litigate a stipulated response unlawful a restricted time span, and did seriously inconvenience both my ex-wife and myself sufficient a document, and deceptive an official action. The Defendant Lyle Herr did detain and influence both Ms. Tina Cormany and myself intentional a recommendation and political an opinionated vote, costly a careful situation and circumstance. Mr. Lyle Herr is alleged to be a Probation Officer or Supervisor in the Cthmberland County. On February 23, 1991, I, Cory A. Cormany, did presume a visitation agreement, consensual my ex-wife, to Mr. John Adams questionable an alleged altercation said to have occurred in the Borough of Carlisle. Prior therein my consent, and pursuant thereto my employment, the Defendant Lyle Herr did obstruct an evidence deceptive Ms. Tina Cormany and informative a statement submissive an official action, and speculatory a negotiable fund. The Defendant did again litigate a stipulated response unlawful a restricted time span, and did seriously risk bodily injury prescient a privilege and a fight credited a property. The Defendant Lyle Herr did acquire a pecuniary interest in both my ex-wife and myself powerful the reported commission of a crime and considerate the buying and selling of a humanity. Mr. John Adams is alleged to be a Convicted Drug Dealer or User in the Cumberland County. On February 19, 1995, I, Cory A. Cormany, did submit a criminal complaint, compliant a hospitalization and an affair, to Mr. Samuel Coover allegary a said commitment to the Cumberland County Prison. Prescient thereto my intentions, and relevant therein my imprisonment, the Defendant Samuel Coover did supervise an authority reckless a conduct that did cause bodily injury and indecent resistance punctilious a prompt response. The Defendant did provide weapons and instruments that did cause and do inflict serious bodily harm factual a freedom, and unlawful a liberty, proceeding the outcome of a trial constitutional an involuntary servitude. Proceeding and prescient the aforementioned circumstance; I was probated and pursued a resolution nonconsensual an adoption term case number 64; that was subjected a negative outcome responsible an official action. The Defendant Samuel Coover did direct and implement detention and assessment exposing and threatening physical conduct which did serve no legitimate purpose evenditiary a video tape, and influential an illicit threatening propaganda. On June 21, 1997, I, Cory A. Cormany, did once again remand a criminal complaint, sadistic a treatment, to Mr. Samuel Coover important a said commitment to the Cumberland County Prison. Prior thereto my an'est, and pursuant therein my recognition, the Defendant Samuel Coover did once again exercise an authority influential a conduct that did cause bodily harm and indecent resistance truthful a prompt consideration. The Defendant did again unlawfully supervise an outcome that did expose and subject me to serious bodily injury, factual a freedom and suspicious a liberty, proceeding the issues of a trial constitutional an involuntary servitude. Preceding and pursuant the aforementioned situation; I was brutalized and impeded an accomplishment relative the commission of a crime. The Defendant Samuel Coover did procrastinate and wager a series of incidents which did dispose and infringe a prejudicial action malicious a local law. Mr. Samuel Coover is alleged to be a Training Specialist or Supervisor in the Cumberland County. On July 24, 2001, I, Cory A. Cormany, did order a summary hearing, significant an appeal, to Mr. Darrell Dethlefs capable an alleged action said to have occurred in the Borough of Carlisle. Prior therein my commitment, and pursuant thereto my detention, the Defendant Samuel Coover did collaborate and conspire with a C. O. Frank Teaney, and did harass me threatening the evacuation and unlawful transportation of my person consistent a physical contact on October 2, 2001, in Cumberland County Prison. I was restrained and subjected servitude and assaulted prescient and pursuant to September 12, 2001, and again seriously annoyed and alarmed. The Defendant did concur an official ramification costly a civil action preparatory the common pleas court; criminal case term number 01- 0494, which did terrorize me affectionate a loss and a disadvantage. Pursuant such contemplation I was searched and denied my property rights relevant an information and several pecuniary transactions, safeguarding a Ms. Marcia Kuhn and the said; Mr. Darrell Dethlefs, whom did officially misrepresent me considerate a Mr. Dirk Berry. Mr. Darrell Dethlefs is alleged to be a Public Defender or Attorney in the Cumberland County. Ms. Marcia Kuhn is alleged to be an Accounts Officer or Accountant in the Cumberland County. On December 7, 2001, I, Cory A. Cormany, did once again order a summary hearing, objectional an appeal, to Mr. Dirk Berry reportorial an alleged incident said to have occurred in Middlesex Township. Pursuant thereto my acknowledgment, and relevant therein my commitment, the Defendant Dirk Berry did inform me that criminal elements concerning the offenses defined did not matter and were irrelevant to the disposition of a hearing petitioned by a Ms. Paula Correal. The Defendant did state that the aforesaid matter would be bound over to a higher court and did litigate a common pleas court case term number 01- 0432. Proceeding and prescient the aforementioned documentation; I was not notified of a future release date from prison, nor petitioned aware of such said factual case term numbers, nor serviced and summoned knowledgeable a scheduled Formal Arraignment or said Charge. I had pursued a "Legal Service", relevant a child custody matter, allegory hereto and prior the aforementioned. The Defendant Dirk Berry did inform me pursuant January 25, 2002, that I was serviced circumstantial a case term number 01-2536 and charged with resisting arrest in light of a previous numeric deception, or mistake, and a said; summary acquittal. During or about the aforesaid ramification the Honorable Judge Guido of the Cumberland County Courts allegedly posted a'bail imposition, and did schedule a pre-trial and trial for matters documented in the Common Pleas Court of Pennsylvania. Mr. Dirk Berry is alleged to be a Public Defender or Attorney in the Cumberland County. Ms. Paula Correal is alleged to be a District Justice or Magistrate in the Cumberland County. I, Cory A. Cormany, on this c~¢¢v- day of ¢'-6(qc~=~. , of the year 2002, do hereby swear as a citizen and a voter of the Commonwealth of the United States that the above facts are true and correct to the best of my knowledge and belief. ~CoryA. Corm~ny ~-~) '~ Dated Witness Attorney General U. S. District Court 228 Walnut Street Harrisburg, PA 17101 Defendant: Maswadeh Arafat Alonzo Thorton Joe Anilus Keith Walker Jimmy Hernandez I, Cory A. Cormany, being a citizen of the United States of America, do hereby state and swear that at or about September 15th, of the year 2001, and through and about a judgmental action, the above named defendant[s] did commit the following crimes: 1) 903. Criminal Conspiracy - a person is guilty of conspiracy with another person or persons to commit a crime if with the intent of promoting or facilitating its commission he: (1) agrees with such other person or persons that they or one or more of them will engage in conduct which constitutes such crime; or (2) agrees to aid such other person or 'persons in the planning or commission of such crime or of an attempt or solicitation to commit such crime. 2) 4703. Retaliation for Past Official Action - a person commits a misdemeanor of the second degree if he harms another by any unlawful act in retaliation for anything lawfully done by the latter in the capacity of a public servant. 3) 5101. Obstructing Administration of Law or Other Governmental Function - a person commits a misdemeanor of the second degree if he intentionally obstructs, impairs or perverts the administration of law or other governmental function by force, violence, physical interference or obstacle, breach of official duty, or any other unlawful act, except that this section does not apply to flight by a person charged with crime, refusal to submit to arrest, failure to perform a legal duty other than an official duty, or any other means of avoiding compliance with law without affirmative interference with governmental functions. 4) 5107. Aiding Consummation of Crime - a person commits an offense if he intentionally aids another to accomplish an unlawful object of a crime, as by safeguarding the proceeds thereof or converting the proceeds into negotiable funds. 5) 6) 7) 8) 5108. Compounding - a person commits a misdemeanor of the second degree if he accepts or agrees to accept any pecuniary benefit in consideration of refraining from reporting to law enforcement authorities the commission or suspected commission of any offense or information relating to an offense. 5503. Disorderly Conduct - a person is guilty of disorderly conduct if, with intent to cause public inconvenience, annoyance or alarm, or recklessly creating a risk thereof, he: (1) engages in fight or threatening, or in violent or tumultuous behavior; (2) makes unreasonable noise; (3) uses obscene language, or makes an obscene gesture, or (4) creates a hazardous or physically offensive condition by any act which serves no legitimate purpose of the actor. 5508. Disrupting Meetings and Processions - a person commits a misdemeanor of the third degree if, with intent to prevent or disturb a lawful meeting, procession or gathering, he disturbs or interrupts it. 6504. Public Nuisances - whoever erects, sets tip, establishes, maintains, keeps or continues, or causes to be erected, set up, established, maintained, kept or continued, any public or common nuisance is guilty of a misdemeanor of the second degree, where the nuisance is in existence at the time of the conviction and sentence, the court, in its discretion, may direct either the defendant or the sheriff of the county at the expense of the defendant to abate the same. 903 - 1972, Dec. 6, P.L. 1482 4703 - 1972, Dec. 6, P.L. 1482 5101 - 1972, 5107- 1972, 5108- 1972, 5503 - 1972, 5508- 1972, 6504 - 1972, Dec. 6, P.L. 1482 Dec. 6, P.L. 1482 Dec. 6, P.L. 1482 Dec. 6, P.L. 1482 Dec. 6, P.L. 1482 Dec. 6, P.L. 1482 No. 334, No. 334 No. 334 No. 334 No. 334 No. 334 No. 334 No. 334 1, effective June 6, 1973. 1, effective June 6, 1973. 1, effective June 6, 1973. 1, effective June 6, 1973. 1, effective June 6, 1973. 1, effective June 6, 1973. 1, effective June 6, 1973. 1, effective June 6, 1973. I, Cory Cormany, hereby verify that the facts set forth in the above are true and correct to the best of my knowledge or information and belief and that any false statements herein are made subject to the penalties of Section 4904 of the Crimes Code (18 Pa. C.S. 4904), relating to unsworn falsification to authorities. INCIDENT REPORT Criminal Conspiracy: In that Maswadeh Ararat, Alonzo Thorton, Joe Anilus, Keith Walker and Jimmy Hemandez did solicit the planning and commission of crimes promoting or facilitating a Defendant or Defendants. Retaliation for Past Official Action: In that the Defendants did unlawfully agree a latter complicity of harm sought retaliatory a public servant. Obstruction Administration of Law or Other Governmental Function: In that the Defendants did obstruct and pervert a judicial inference aff~rmative a governmental function. Aiding Consummation of Crime: In that the Defendants did accomplish an unlawful object safeguarding a negotiable sum legitimate an information. Compounding: In that the Defendants did consider a pecuniary benefit suspicious an authority. Disorderly Conduct: In that the Defendants did annoy and alarm an individual or individuals causative a gesture and an offensive condition. Disrupting Meetings and Processions: In that the Defendants did intentionally interrupt and disturb a lawful procession reliable an individual. Public Nuisances: In that the Defendants did erect, set up and establish a nuisance abatable a discretionary maintenanc6 and intentional the case term 1:CV-02-0046 and the docket files NT-187-00, NT-188-00, NT-189-00, NT-190-00, NT~205-00, NT-748-00, NT-770-00 and NT-839-00 proceeding CR- 574-01 and the case numbers 01-0432 and 01~0494. I petition that a warrant of arrest or a summons be issued and that the Defendant be required to answer the charges I have made. I verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information and belief. This verification is made subject to the penalties of Section 4904 of the Crimes Code (18 Pa. C.S. 4904), relating to unsworn falsification to authorities. Datbd Signature Dated Signature ~ ,*~,~,? C~,ommlsslor~ Expires June 24, 2002 AFFIDAVIT On September 15, 2001, I, Cory A. Cormany, did witness Mr. Maswadeh Arafat solicit information in a unit staff station located in the Cumberland County Prison. The Defendant Maswadeh Ararat did make and respond to questions and statements regarding the catastrophe announced in New York, pertinent the destruction of the World Trade Center. The Defendant did reply to propaganda remarkable his incarceration saying, "I'm an American too...I needed money, I needed money." Mr. Maswadeh Arafat did also state, "I am a Muslim...we are peaceful people and only kill when we need to." A C. O. Albright of the Cumberland County Prison was present during such interrogatories extrinsic other inmates and another staffing associate, and I did inform the Defendant that he did not have to make or corroborate such issues. I did tell Mr. Maswadeh Ararat that he did have a right to silence. The Defendant Maswadeh Arafat did say, "I know, I know...they told me my rights...I am not ashamed. You see it was an accident, I only needed the insurance." Mr. Maswadeh Arafat was alleged to be in prison for burning down his place of business and for trafficking narcotics. On November 4, 2001, I, Cory A. Cormany, did witness Mr. Maswadeh Arafat proceed numerous questions and comments in the Law Library at the Cumberland County Prison. The Defendant Maswadeh Ararat did implicate a Mr. Alonzo Thorton, a Mr. Joe Anilus, and a Mr. Keith Walker; seemingly relevant a package and a conversation he was to have. I did surmise that the Defendants Alonzo Thorton, Joe Anilus and Keith Walker all participated in the burning of a business located in the Historic District of Carlisle, Pennsylvania, from Mr. Maswadeh Arafat's statements. I did acknowledge the Defendant say, "I know they hired this Walker guy, but I was out of the country and didn't own the business..." Mr. Maswadeh Ararat did later contradict and say, "I don't know, I sold the business and got the money I needed when it burned down." Proceeding the events described in the foregoing paragraph, Mr. Maswadeh Arafat did aggress a series of comments to me on several occasions. I did witness the Defendant Maswadeh Ararat in a verbal and physical conflict in the gymnasium of the Cumberland County Prison. The Defendant was loudly procrastinating to another individual exclaiming, "don't tell people about my money...they don't need to know...I need my bail." I did overhear the Defendant continue exacerbation with a Mr. Carl Heyward also saying, "I'11 get it, I'll get it...after he has his visit." It was my assumption that there was a pecuniary barter taking place and I did not chose to continue to listen to such ongoing rhetoric. On another occasion; the Defendant Maswadeh Arafat did speak to me asking, "What should I do about the Federal Government and Fraud?" I did not answer his question and did shrug my shoulders and walked off in the opposite direction of the said; institutional gymnasium, in the Cumberland County Prison. On December 31, 2001, I, Cory A. Cormany, did witness a Mr. Jimmy Hernandez, alias Juan Sanchez, solicit information in the Law Library in the Cumberland County Prison. The Defendant Jimmy Hernandez did remark and collaborate numerous exasperations regarding his criminal problems. The Defendant did continue on about a Mr. Cruz; who allegedly informed police officers about illegal narcotic activity having occurred in Lebanon, Pennsylvania, relevant himself. Mr. Jimmy Hernandez did present me with several indictment orders troubling me as to my opinion extendible a futile and threatening obligation. The Defendant Jimmy Hernandez did reply when I asked him about his criminal dilemmas and said, "I guess I see what you're saying, but I can't say exactly...I deal a lot of drugs you know...I just deal a lot of drugs." I did inform the Defendant that he did not have to tell me of his problems and did also make this point valid upon a preceding consulted occasion, likely a said criminal conviction. The.Defendant Jimmy Hernandez did tell me quote, "don't worry about it...I got ya." Prescient the issues defined in the foregoing paragraph, Mr. Jimmy Hernandez did conspire with the Mr, Maswadeh Ararat; again in the Law Library at the Cumberland County Prison. I did witness the Defendant Jimmy Hemandez give the Defendant Maswadeh Ararat something in a plain white envelope, and then did literally refer, "you got me on Thursday right?" The opposing Defendant did gratify the aforementioned Defendant seemingly to acknowledge an erectable beneficial transaction. Mr. Maswadeh Arafat did continue and ramble on about other matters proceeded the aforementioned destruction in New York City. The Defendant Maswadeh Arafat did impose the thought that he knew people who could do, or were capable of a harm. He did say, "I know people who hate the United States Government do 'ya know what I am talking about?" The Defendant did seem to become very emotional at that point and said something about the war in Afghanistan, and did state that he wanted to kill Americans, especially; "Guards and Cops." Mr. Maswadeh Arafat did additionally procrastinate that he had done, "Business" with Mr. Jimmy Hemandez before. The Defendant Maswadeh Ararat did state. "you know I'm good for it, we seen keys together, ya know blood." The Defendant kept annoying me pursuant my legal endeavors and the common pleas criminal case term number 01-2091 and 01-2536, going on about the typewriter and why Americans and the United States should be destroyed, and that Islam should have quote, "All the money and power in the world." I, Cory A. Cormany, on this ~ ~ ~4~, day of ;:~.~...~. , of the year 2002, do hereby swear as a citizen and a voter of the Commonwealth of the United States that the above facts are true and correct to the best of my knowledge and belief. Cory A. Dated Holeo O. ShOed, Notary Public Middlesex Twp., Cumberland Count,/ My Commissio'r~ Expires June 24 2002 RE: District Attorney Cumberland County Court House Square Carlisle,. Pa. 17013 Defendant: Harold Sheely, The Administration and Staff of the Cumberland County Court House I, Cory A. Cormany, being a citizen of the United States of America, do hereby state and swear that in and about the actions and incidents stated herein, and through and about a judgment stated hereto, the above named defendant did commit the following crimes. 1) 902. Criminal Solicitation - a person is guilty of solicitation to commit a crime with the intent of promoting or facilitating its commission he commands, encourages or requests another person to engage in specific conduct which would constitute such crime or an attempt to commit such crime or which would establish his complicity in its commission or attempted commission. 2) 2504. Involuntary Manslaughter - (a) General rule - a person is guilty of involuntary manslaughter when as a direct result of the doing of a lawful act in a reckless or grossly negligent manner, he causes the death of another person. (b) Grading - Involuntary manslaughter is a misdemeanor of the first degree, where the victim is under 12 years of age and is in the care custody or control of the person who caused the death involuntary manslaughter is a felony of the second degree. 3) 2705. Recklessly Endangering Another Person - a person commits misdemeanor of the second degree if he recklessly engages in conduct which places or may place another person in danger of death or serious bodily injury. a 4) 2709. Harassment - a person commits a summary offense when, with intent to harass, annoy or alarm another person: (1) he strikes, shoves, kicks or otherwise subjects him to physical contact, or attempts or threatens to do the same; or (2) he follows a person in or about a public place or places; or (3) he engages in a course of conduct or repeatedly commits acts which alarm or seriously annoy such other person and which serve no legitimate purpose. 5) 2902. Unlawful Restraint - a person commits a misdemeanor of the first degree if he knowingly: (1) restrains another unlawfully in circumstances exposing him to risk of serious bodily injury; or (2) holds another in a condition of involuntary servitude. 6) 2903. False Imprisonment - a person commits a misdemeanor of the second degree if he knowingly restrains another unlawfully so as to interfere substantially with his liberty. 7) 2906. Criminal Coercion a person is guilty of criminal coercion if; with intent unlawfully to restrict freedom of action of another to the detriment of the other, he threatens to: (1) commit any criminal offense; (2) accuse anyone of a criminal offense; (3) expose any secret tending to subject any person to hatred, contempt 8) 9) t0 11 12) or ridicule; or (4) take or withhold action as an official, or cause an official to take or withhold action. 3503. Criminal Trespass - a person commits an offense if, knowing that he is not licensed or privileged to do so, he (i) enters, gains entry by subterfuge or surreptitiously remains in any building or occupied structure or seperately secured or occupied portion thereof; or (ii) breaks into any building or occupied structure or seperately secured or occupied portion thereof. (2) An offense under paragraph (1)(i) is a felony of the third degree, and an offense under paragraph (1)(ii) is a felony of the second degree. (3) As used in this subsection: "Breaks into." To gain entry by force, breaking, intimidation, unauthorized opening of locks, or through an opening not designed for human access. 3923. Theft by Extortion a person is guilty of theft if he intentionally obtains or withholds property of another by threatening to: (1) commit another criminal offense; (2) accuse anyone of a criminal offense; (3) expose any secret tending to subject any person to hatred, contempt or ridicule; (4) take or withhold action as an official, or cause an official to take or withhold action; (5) bring about or continue a strike or boycott or other collective unofficial action, if the property is not demanded or received for the benefit of the group in whose interest the actor purports to act; (6) testify or provide information or withhold testimony or information with respect to the legal claim or defense of another; or (7) inflict any other harm which would not benefit 'the actor. 5301. Official Oppression - a person acting or purporting to act in a official capacity or taking advantage of such actual or purporting capacity commits a misdemeanor of the second degree if knowing that his conduct is illegal, he (1) subjects another to arrest, detention, search, seizure, mistreatment, dispossession assessment, lien or other infringement of personal or property rights, or (2) denies or impedes another in the exercise or enjoyment of any right, privilege, power or immunity. 5302. Speculating or Wagering on Official Action or Information a public servant commits a misdemeanor of the second degree if in contemplation of official action by himself or by a governmental unit with which he is associated, or in reliance on information to which he has access in his official capacity and which has not been made public he: (1) acquires a pecuniary interest in any property, transaction or enterprise which may be affected by such information or official action; (2) speculates or wagers on the basis of such information or official action; or (3) aids another to do any of the foregoing. 5726. Action for Removal from Office or Employment - any aggrieved person shall have the right to bring an action in Commonwealth Court against any investigative or law enforcement officer, public official or public employee seeking the officer's, official or employee's removal from office or employment on the grounds that the officer, official or employee has intentionally violated the provisions of this chapter. If the court such officer, official or employee has in fact intentionally violated the provisions of this chapter, the court shall order the dismissal or or employee. 902 - 1972, Dec. 2504 - 1972, Dec. 2705 - 1972, Dec 2709 - 1972, Dec 2902 - 1972, Dec 2903 - 1972 Dec 2906 - 1972 Dec 3503 - 1972 Dec 3923 - 1972 Dec 5301 - 1972 Dec 5302 - 1972 Dec 5726 - 1978 Oct shall conclude that removal from office of said officer, official No. 334, 1, No 334, 1, No 334, 1, No 334 1, No 334 1, No 334. 1, No 334. 1, No 334. 1, No 334 No 334 1, No 334 No. 164 2, 6, P.L. 1482 6, P.L. 1482 6, P.L. 1482 6, P.L. 1482 6, P.L. 1482 6, P.L. 1482 6, P.L. 1482 6, P.L. 1482 6, P.L. 1482 6, P.L. 1482 6, P.L. 1482 4, P.L. 831 effective June 6, effective effective effective effective 1973. June 6 June 6 June 6 June 6 effective June 6 effective June 6 effective June 6 effective June 6 effective June 6 effective June 6 effective in 60 days. I, Cory A. Cormany, do hereby verify that the facts set forth in the above are true and correct to the best of my knowledge or information and belief, and that any false statements herein are made subject to the penalties of Section 4904 of the Crimes Code (18 Pa. C.S. 4904), relating to unsworn falsification to authorities. 1973. 1973, 1973. 1973. 1973. 1973. 1973. 1973. 1973. 1973. Dated Cory A. Cormany SWORN STATEMENT 1. On or about October 15, the Plaintiff, Cory Cormany, commit a crime. 1985, and relevant herein and hereto, was mislead to believe he did legally 2. At or about the aforesai'd date and time, the Plaintiff Cory Cormany was allocated and accused of actions and unreliable incidents unconstitutional a due process. 3. Pursuant the aforementioned described event, the Defendant A1 Masland, a member of the county administration, did knowingly and willfully procrastinate a~criminal_off~nse. 4. Prior the foregoing statement, the Defendant Taylor Andrews, member of the county administration, did knowingly and willfully permit the Plaintiff to admit a criminal liability. a 5. On or about April 15, 1986, and relevant herein and hereto, Plaintiff, Cory Cormany, was mislead to believe he did legally commit a crime. the 6. At or about the aforesaid date and time, Cormany was allo~-ated and accused of actions unconstitutional a due process. the Plaintiff Cory and unreliable incidents 7. Proceeding the aforementioned described.event, the Defendant Lyle Herr, a county staffing member~ did coax and convince the Plaintiff to pronounce a guilty ramification in exchange for a restricted liberty or freedom. 8. Prior the foregoing statement, the Defendant Donald Doter, a member of the county administration, did knowingly'and willfully permit the Plaintiff to admit a criminal liability. 9. On or about June 19, 1987~ and relevant herein and hereto, Plaintiff, Cory Cormany, was mislead to believe he did legally commit a crime. the 10. Cormany was all~ated and accused unconstitutional a due process. At or about the aforesaid date and time, the Plaintiff Cory of actions and unreliable incidents 11. Proceeding the aforementioned described event, the Defendant Lyle Herr, a county staffing member, did say and expose the Plaintiff to chemical testing nonpresentable an authen{ilc.'f6rce or determination. 12 Prior the foregoing statement, the Defendant Donald Doter, a member of the county administration, did knowingly and willfully represent the Plaintiff submissive a criminal liability. 13 On or about June 7, 1988, and relevant herein Plaintiff, Cory Cormany, was mislead to believe he commit a crime. and hereto, did legally the 14 At or about the aforesaid date and time, the Plaintiff Cormany was all~¢ated and accused Of actions and unreliable unconstitutional a due process. Cory incidents 15 Proceeding the aforementioned described event, the Defendant Lyle Herr, a county staffing member, did lie and proclaim the Plaintiff to be responsible an auto accident in which he was not Or did not. 16 Prior the foregoing statement, the Defendant Donald Doter, a member of the county administration, did knowingly and willfully represent the Plaintiff submissive a criminal liability. 17 On or about March 28, 1989, and Plaintiff, Cory Cormany, was mislead commit a crime. relevant herein and hereto, to believe he did legally the 18 At or about the aforesaid date and time, Cormany was allocated and accused of actions unconstitutional a due process. the Plaintiff Cory and unreliable incidents 19. Proceeding the aforementioned described event, the Defendant Lyle Herr, a county staffing member, did affirm and renounce the Plaintiff to be guilty of a criminal offense prejudicial an outcome or violation. 20. Pursuant the foregoing statement, the Defendant Ronald Toro, member of the county administration, did knowingly and willfully permit the Plaintiff to admit a criminal liability. 21. On or about October 1, 1989, and relevant herein and hereto, Plaintiff, Cory Cormany, was mislead to believe he did legally commit a crime. the 22. At or about the aforesaid date and time, the Plaintiff Cory Cormany was allocated and accused of actions and unreliable incidents unconstitutional a due process. 23. Proceeding the aforementioned described event, ~h~ Defendant Lyle Herr, a county staffing member, did manipulate and intimidate the Plaintiff and his spouse questionable a peaceful procedural dilemma or reconciliation. 24. Pursuant the foregoing statement, the Defendant Richard Snelbaker, a member of the county administration, did knowingly ~nd willfully represent the Plaintiff ineffective a criminal liability. 25. On or about February 24, 1991, and relevant herein and hereto, the Plaintiff, Cory Cormany, was mislead to believe he did legally commit a crime. 26. At or about the aforesaid date and time, the Plaintiff Cory Cormany was allo~ated and accused of actions and unreliable incidents unconstitutional a due process. 27. Proceeding the aforementioned described event, the Defendant Lyle Herr, a county staffing member, did victimize and slander the Plaintiff and his former spouse prescient a negligible malicious procrastination or divorce. 28. Pursuant the foregoing statement, the Defendant Ellen Berry, member of the county administration, did knowingly and willfully p~rmit the Plaintiff to admit a criminal liability. 29. Plaintiff, Cory Cormany, commit a crime. On or about June 21, 1992, and relevant herein and hereto, was mislead to believe he did legally the 30. At or about the aforesaid date and time, the Plaintiff Cory Cormany was. all~ated and accused of actions and unreliable incidents unconstitutional a due process. 31. Proceeding the aforementioned described event, the Defendant Mike Piper, a county staffing member, did petition and in£orm the Plaintiff of a stipulated breach in contract excusable a timely violation or penalty. 32. Pursuant the foregoing statement, the Defendant Taylor Andrews, a member of the county administration, did knowingly and willfully represent the Plaintiff effective a criminal liability. 33. On or about August 24, 1993, and relevant herein and hereto, the Plaintiff, Cory Cormany, was mislead to believe he did legally commit a crime. 34. Prior the aforesaid date and time, the Plaintiff Cory Cormany was allocated and accused of Colorful and pretensive incidents unconstitutional a due process. 35. On or about August Plaintiff, Cory Cormany, commit a crime. 2, 1994, and relevant herein and hereto,, the was mislead to believe he did legally 36. Prior the aforesaid date and time, the Plaintiff Cory Cormany was allocated and accused of colorful and pretensive incidents unconstitutional a due process. 37. On or about November 15, 1994, and relevant herein and hereto, the Plaintiff, Cory Cormany, was mislead to believe he did legally commit a crime. 38. At or about the aforesaid date and time, the Plaintiff Cory Cormany was allocated and accused of actions and unreliable incidents unconstitutional a due process. 39. On or about the Plaintiff, commit a crime. February 19, 1995, and relevant herein and hereto, Cory Cormany, was mislead to believe he did legally 40. At or about the aforesaid date and time, Cormany was allocated and accused of actions unconstitutional a due process. the Plaintiff Cory and unreliable incidents 41. Proceeding the aforementioned described event, the Defendant Johnathan Birheck, a member of the county administration, did knowingly and willfully procrastinate a criminal offense. 42. Pursuant the foregoing statement, the Defendant Anthony Adams, a member of the county administration, did knowingly and willfully represent the Plaintiff ineffective a criminal liability. 43. Prior the aforementioned described event, the Defendant Nichole Horrick, a county staffing member, did petition and inform the Plaintiff to be guilty Of a criminal offense prejudicial an outcome or violation. 44. On or about May 29, 1996, and relevant herein and hereto, Plaintiff, Cory Cormany, was maliciously summoned liable a believable legal offense. the 45. At or about the aforesaid date and time, Cormany was allocated and accused of colorful unconstitutional a due process. the Plaintiff Cory and pretensive incidents 46. Proceeding the aforementioned described event, the Defendant Jamie Keating, a member of the county administration, did knowingly and willfully procrastinate a summary offense. 47. Prior the foregoing statement, the Defendant Jeffrey Franks, county staffing member, did knowingly and willfully exploit the Plaintiff costly a criminal propaganda. a 48. the Plaintiff, On or about September 6, 1996, and relevant herein and hereto, Cory Cormany, was mislead to believe he did legally commit a crime. 49. At or about the aforesaid date and time, the Plaintiff Cormany was allocated and accused of actions and unreliable unconstitutional a due process. Cory incidents 50. Proceeding the aforementioned described event, the Defendant William Gaibaig, a member of the county administration, did knowingly and willfully procrastinate a criminal offense. 51. Prior the foregoing statement, the Defendant Timothy Clawges, member of the county administration, did knowingly and willfully permit the Plaintiff to admit a criminal liability. a 52. On or about June 21, 1997, and relevant herein and hereto, Plaintiff, Cory Cormany, was mislead to believe he did legally commit a crime. the 53. At or about the aforesaid date and time, Cormany was all~'ated and accused of actions unconstitutional a due process. the Plaintiff Cory and unreliable incidents 54. Proceeding the aforementioned described event, the Defendant William Gabaig, a member of the county administration, did knowingly and willfully procrastinate a criminal offense. 55. Pursuant the foregoing statement, the Defendant Timothy Clawges, a member of the county administration, did knowingly and willfully represent the Plaintiff ineffective a criminal defense. 56. On or about October 30, Plaintiff, Cory Cormany, was commit a crime. 1997, and relevant herein and hereto, mislead to believe he did legally the 57. At or about the aforesaid date and time, the Plaintiff Cory Cormany was allocated and accused of colorful and pretensive incidents unconstitutional a due process. 58. Prior the foregoing statement, the Defendant Ellen Berry, a member of the county administration, did knowingly and willfully represent the Plaintiff submissive a criminal liability. 59. Proceeding the aforementioned described event, the Defendant Jamie Keating, a member of the county administration, did knowingly and willfully litigate a criminal offense. 60. On or about December 2, 1997, and relevant herein and hereto, Plaintiff, Cory Cormany, was mislead to believe he did legally commit a crime. the 61. Prior the aforesaid date and time, the Plaintiff Cory Cormany was allocated and accused of colorful and pretensive £ncidents unconstitutional a due process. 62. On or about May 3, 2000, and relevant herein and hereto, the Plaintiff, Cory Cormany, was mislead to believe he did legally commit a crime. 63. At or about the aforesaid date and time, the Plaintiff Cory Cormany was allocated and accused of colorful and pretensive incidents unconstitutiohal a due process. 64. Proceeding the aforementioned described event, the Defendant Darrell Dethlefs, a member of the county administration, did knowingly and willfully deny the Plaintiff the right to a criminal defense. 65. On or about August Plaintiff, Cory Cormany, commit a crime. 6, 2001, and relevant herein and hereto, was mislead to believe he did legally the 66. Pursuant the aforesaid date and time, the Plaintiff Cory Cormany was charged and committed to prison unreliable a colorful action and constitutional a pretensive procession. 67. the Plaintiff, On or about October 2 2001, and r ant herein and hereto, Cory Cormany, was maliciously summoned liable a believable legal offense. 68. At or about the aforesaid date and time, the Plaintiff Cory Cormany was all~ated and accused of actions and unreliable incidents unconstitutional a due process. 69. Proceeding the aforementioned described event, the Defendant Edmund Zigmund, a member of the county administration, did knowingly and willfully procrastinate a misdemeanor offense. 70. Prior the foregoing statement, the Defendant William Diehl, county staffing member, did knowingly and willfully exploit the Plaintiff costly a criminal propaganda. a 71. Prescient the aforementioned described event, the Defendant Dirk Berry, a member of the county administration, did knowingly and willfully represent the Plaintiff submissive a criminal dilemma. 72. Pursuant the foregoing incidents stated, the Defendant Harold Sheely, a former elected county official, did corroborate and over see issues amd objects, and did exercise discretion admissive the county court house and the Court of Common Pleas of Cumberland County Case Nos. 01-0432 and 01-2536. 73. The Defendants did cause a reasonable suspicion of doubt deliberate a requisite criminal intention, and political the solicit allegations enstated during and throughout the eventful occasions defined, wherein the Plaintiff Cory Cormany feels victimized as an individual residence of the Commonwealth of Pennsylvania. 74. treatment, faults and additional Joe Anilus, The Plaintiff has suffered and sustained, abusive and wrongful stressful and constant condemnation punishible other prejudices involving also the uses of firearms, wherefore filings include a Defendant Jimmy Hernandez, Kieth Walker, Alonzo Thorton and a Mr. Ararat of the Cumberland County. I, Cory A. Cormany, do hereby verify that the facts set forth in the above are true and correct to the best of my knowledge or information and belief, and that any false statements herein are made subject to the penalties of Section 4904 of the Crimes Code (18 Pa. C.S. 4904), relating to unsworn falsification to authorities. ~itness Cory A. Cormany THE COMMONWEALTH OF PENNSYLVANIA CORY A .CORMANY V. COMMONWEALTH OTN:H 424983-6 CASE NO. 01o0494 CRIMINAL LAW - CIVIL ACTION JURY TRIAL DOCKET FILE: CR-0000574~01 NOTICE You have been sued in Court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after the Complaint and Notice are served by entering a written appearance personally or by attorney and by filing in writing with the Court your defense or objection to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and 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 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. Court Administrator Cumberland County Court House 1 South Hanover Street Carlisle, PA. 17013 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY THE COMMONWEALTH OF PENNSYLVANIA CORY A .CORMANY V. COMMONWEALTH OTN:H 424983-6 CASE NO. 01-0494 CRIMINAL LAW - CIVIL ACTION JURY TRIAL DOCKET FILE: CR-0000574-01 PETITION AND NOW comes, Cory Cormany, by the Attorney Dirk E. Berry, and sets forth causes of action against the Commonwealth of Pennsylvania, wherefore the following is a statement: 1. Cory Cormany is an adult individual residing in the Commonwealth of Pennsylvania. 2. Marie Hall is an adult individual empowered by the Commonwealth of Pennsylvania. 3. Chris Durnin is an adult individual empowered by the Commonwealth of Pennsylvania. 4. Karen Edwards is an adult individual empowered by the Commonwealth of Pennsylvania. 5. Curtis Colbertson is an adult individual empowered by the Commonwealth of Pennsylvania. 6. Shannon Dunlap is an adult individual empowered by the Commonwealth of Pennsylvania. 7. Frank Teaney is an adult individual empowered by the Commonwealth of Pennsylvania. 8. Jane Scott is an adult individual empowered by the Commonwealth of Pennsylvania. 9. Michael Carey is an adult individual empowered by the Commonwealth of Pennsylvania. 10. Helen Sneed is an adult individual empowered by the Commonwealth of Pennsylvania. 11. Earl Reitz, Jr. is an adult individual empowered by the Commonwealth of Pennsylvania. 12. Karen Finkenbinder is an adult individual empowered by the Commonwealth of Pennsylvania. 13. Shane Cohick is Commonwealth of Pennsylvania. 14. Joseph Hogarth is Commonwealth of Pennsylvania. 15. Jeffrey Kurtz is Commonwealth of Pennsylvania. 16. William Miller is Commonwealth of Pennsylvania. 17. Mathew Kennedy Commonwealth of Pennsylvania. 18. Michael Guido is an adult individual empowered by the an adult individual empowered by the an adult individual empowered by the an adult individual empowered by the is an adult individual empowered by the an adult individual empowered by the Commonwealth of Pennsylvania. 19. Stephen Margeson Commonwealth of Pennsylvania. 20. Jeffrey Franks is Commonwealth of Pennsylvania. 21. William Diehl is Commonwealth of Pennsylvania. is an adult individual empowered by the an adult individual empowered by the an adult individual empowered by the 22. Pennsylvania. 23. Edmund Zigmtmd Commonwealth of Pennsylvania. 24. Patrick Lauer is Commonwealth of Pennsylvania. Lyle Herr is an adult individual empowered by the Commonwealth of is an adult individual empowered by the an adult individual empowered by the 25. Cory Cormany is a high school graduate, a university undergraduate, a taxpayer, a registered voter, and a citizen of the United States of America. 26. On May 29th, 1996, Det. Jeffrey Franks did petition a summary complaint in the Commonwealth of Pennsylvania allegary Mr. Cory Cormany and determinative the Honorable District Magistrate Paula Correal. 27. On January 2nd, 1998, Mr. Cory Cormany did forfeit an employment application contractual Morris-Knudson, mandatory I.B.M. and the Commonwealth of Pennsylvania Department of Corrections. 28. On December 29th, 1999, the Commonwealth of Pennsylvania Department of Corrections did omit Mr. Cory Cormany pursuant Ptl. Karen 36. On September 21st, 2001, Mr. Cory Cormany did file a civil complaint in the United States District Court of Pennsylvania against Warden Earl Reitz, Jr., et al. 37. On October 2nd, 2001, Det. William Diehl did petition a criminal complaint in the Commonwealth of Pennsylvania allegary Mr. Cory Cormany and determinative the Honorable District Magistrate Paula Correal. 38. On October 12th, 2001, Mr. Cory Cormany did appeal a summary obligation in the Court of Common Pleas of Cumberland County judicious the Honorable District Magistrate Paula Correal. 39. On November 26th,. 2001, Mr. Cory Cormany did file a civil complaint in the Court of Common Pleas of Cumberland County against Warden Earl Reitz, Jr., et al. 40. On November 26th, 2001, the Honorable United States Judge Silvia Rambo did dismiss Warden Earl Reitz, Jr. consensual a malicious action enstated by Mr. Cory Cormany. 41. On December 7th, 2001, the Honorable District Magistrate Paula Correal did subpoena Mr. Cory Cormany intentional various criminative offenses entelechied by the Clerk of Court Denis Lebo. 42. On December 10th, 2001, Mr. Lyle Herr did remand a prior record account noteworthy the Commonwealth of Pennsylvania requested by Mr. Cory Cormany. 43. On December 24th, 2001, D.W. Helen Sneed did notarize an evidential service receipt responsive the Commonwealth of Pennsylvania Finkenbinder, Pti. Shane Cohick, and Pti. Joseph Hogarth. 29. On March 22nd, 2001, the Honorable District Magistrate Paula Correal did sentence Mr. Cory Cormany concurrent numerous summary issues cited by Ptl. Jeffery Kurtz, Ptl. William Miller, and Sgt. Michael Guido. 30. On March 23rd, 2001, Mr. Cory Cormany did file a civil complaint in the Court of Common Pleas of Cumberland County against the Honorable District Magistrate Paula Correal, et al. 31. On July 24th, 2001, the Honorable Commonwealth Judge Kevin Hess did confirm the Honorable District Magistrate Paula Correal directional numerous summary issues ordered by Mr. Cory Cormany. 32. On August 6th, 2001, the Cumberland County Prison did commit Mr. Cory Cormany admissible a definite time period implemented by C.O. Marie Hall and Cpl. Shannon Dunlap. 33. On August 14th, 2001, the Honorable Commonwealth Judge Kevin Hess did dismiss the Honorable District Magistrate Paula Correal consensual a prejudicial action enstated by Mr. Cory Cormany. 34. On August 21st, 2001, Mr. Cory Cormany did motion a sentence modification in the Court of Common Pleas of Cumberland County instructional the Clerk of Court Denis Lebo. 35. On September 12th, 2001, Pti. Mathew Kennedy did engage an incidental arbitration reportorial D.W. Michael Carey, D.W. Jane Scott, Sgt. Frank Teaney, Cpl. Curtis Colbertson, C.O. Chris Durnin, C.O. Marie .Hall, and Ms. Karen Edwards. deprivation of constitutional Mr. Cory Cormany. 47. The Commonwealth right, confinement and incarceration prejudicial of Pennsylvania did additionally cause Mr. Cory Cormany lost wages and employment, benefits, expenses and property in the foregoing amount duplicative an excessive potential amount of Two Hundred and Fifty Thousand and 00 Dollars (250,000.00), respectfully submitted exhibits A through P. 46. By reason of the aforementioned; Mr. Cory Cormany has suffered pain, mental anguish, public humiliation, emotional distress, constitutional deprivation, confinement, incarceration, loss of wages and employment, benefits, expenses and property as a result of the Commonwealth of Pennsylvania. WHEREAS, Cory Cormany, claims from the Commonwealth of Pennsylvania relief in an amount in excess of Two Hundred and Fifty Thousand and 00 Dollars (250,000.00) plus release from prison. petitioned by Attorney Edmund Zigmund. 44. On December 24th, 2001, Mr. Cory Cormany did approve a criminal complaint to the District Attorney of Cumberland County against Chief Stephen Margeson, et al. 45. On January 3rd, 2002, Mr. Cory Cormany did authorize a legal action to the Attorney Patrick Lauer preparatory the Court of Common Pleas of Cumberland County, Pennsylvania. 46. The Commonwealth of Pennsylvania did maliciously invoke pain and suffering, mental anguish, public humiliation, emotional distress, THE CORY A .CORMANY V. COMMONWEALTH OTN:H 424983-6 COURT OF COMMON PLEAS CUMBERLAND COUNTY THE COMMONWEALTH OF PENNSYLVANIA CASE NO. 01-0494 CRIIvtlNAL LAW - CIVIL ACTION JURY TRIAL DOCKET FILE: CR-0000574-01 NOTICE You have been sued in Court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after the Complaint and Notice are served by entering a written appearance personally or by attorney and by filing in writing with the Court your defense or objection to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and 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 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. Court Administrator Cumberland County Court House 1 South Hanover Street Carlisle, PA. 17013 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY TIq~ COMMONWEALTH OF PENNSYLVANIA CORY A .CORMANY CASE NO. 01-0494 V. CRIMINAL LAW - CIVIL ACTION COMMONWEALTH JURY TRIAL OTN:H 424983-6 DOCKET FILE: CR-0000574-01 COMPLAINT I, Cory A. Cormany, declare that I am the petitioner in the above titled proceeding; that in support of my request to proceed without being required to prepay fees, costs or give security thereof, I state that because of my poverty, I am unable to pay the cost of said proceedings or give security thereof; that I believe I am entitled to relief. The nature of my action, defense, or other proceedings or the issues t intend to present on appeal briefly stated as follows: In further support of the application, I answer the following questions: Are you presently employed? (No) Have you received within the past twelve months any money from any of the followin9 sources? (a) Business, profession or other form of self-employment? (No) (b) Rent payments, interest or dividends? (No) (c) Pension, annuities or life insurance payments? (No) (d) Gifts or inheritances? (No) -l- (e) Any other sources? (No) Do you have any cash, or do you have money in checking/savings accounts? (Yes) I have approximately twenty five and O0 dollars available in my checking/savings account. Do you own or have any interest in any real estate, stocks, bonds, notes, automobiles or other valuable property (excluding ordinary household furnishings and clothing)? (No) Not at present. List the persons who are dependent upon you for support, state your relationship to those persons and indicate how much you contribute toward their support. I have an unsecured loan with American General Finance Company for amounts required. I have a biological daughter, however, is relevant to proceeding concerning financial obligation. VERIFICATION I, Cory A. Cormany, Petitioner in the above captioned action, hereby Verify and state that the facts set forth in the Complaint against the Commonwealth of Pennsylvania are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn verification to authorities. Dated I/_x/~¥ By Cory A. Cormany -2- CERTIFICATION OF SERVICE AND NOW, this 3rd day of January 2002, I Cory A. Cormany foregoing the aforesaid matter on behalf of the Commonwealth of Pennsylvania hereby certify that I have served a copy of same in the United States Mail at Carlisle Pennsylvania, addressed as follows: Clerk of Courts Cumberland County Court House 1 South Hanover Street Carlisle, PA 17013 Cory A. Cormany 1101 Claremont Road Carlisle, PA 17013 DEVLIN & DEVINE William J. Devlin, Jr., Esquire Atty. I.D. # 42717 Suite 200, 100 West Elm Street Conshohocken, PA 19428 (610) 397-4614 CORYA. CORMANY Attorney for Defendants, Lyle Herr, Samuel Coover and Dirk Berry COURT OF COMMON PLEAS HAROLD SHEELY, THE ADMINISTRATION AND STAFF OF THE CUMBERLAND COUNTY BAR ASSOCIATION, LYLE HERR, SAMUEL COOVER AND DIRK BERRY: OF THE CUMBERLAND COUNTY COURTHOUSE CUMBERLAND COUNTY NO. 03-6123 CIVIL ENTRY OF APPEARANCF TO THE PROTHONOTARY: KindlyentermyappearanceonbehalfofDe~ndants, LyleHerr, SamueiCoover and DirkBerry, intheabove-captioned maker. DEVLIN & DEVINE William.//Devlin, Jr., E~uire PRAECIPE FOR LISTING CASE FOR ARG~EN{ {It~t be typ~r~tten and sut~/tted in du[~IJcate) TO THE PROTHONOTARY OF CUNHERLAND COUNTY: Please I i_~t the ~r/O~n matter fo~ the ~ Argm~nt Court. CAPTION OF CASE (ent/~ cap~ioo ntmt be stated in CORY A. CORMANY H~RIOLD SHEELY, THE ADMINISTRATION AND STAFF OF THE CUMBERLAND COUNTY BAR ASSOCIATION, LYLE HERR, SAMUEL COOVER AND DIRK BERRY OF THE CUMBERLAND COUNTY COURHOUSE No. 6123 2003 1. State matt~_r to be ~ (i.e., PAaint~ff's motio~ for new ~, ~f~t's PRELIMIN~y OBJECTIONS OF LYLE HERR, S~EL COOVER AND DIRK BERRY TO PLAINTIFF'S 'CO~LAINT {a) f~ ~t~f: Plaintiff is Pro Se, Cory A. Cormany ~: 1883 Douglas Drive, Carlisle, PA 17013 (b) fo~ defendant: William J. Devlin, Jr., Esquire ~: Devlin & Devine, 100 W. Elm St., Ste. 200 Conshohocken, PA 19428 3. ! ~il I ~otif~ a]t Part~es in writing within t~o days that ~ c~ has been 1.tst~_ fo~ ar~jm~mt. January 9, 2004 fo~'Lyle HeR, Samu , and Dir~ Berry ,~ 6 2004 DEVLIN & DEVINE William J. Devlin, Jr., Esquire Atty. I.D. # 42717 Suite 200, 100 West Elm Street Conshohocken, PA 19428 (610) 397-4614 Attorney for Defendants, Lyle Herr, Samuel Coover and Dirk Berry CORYA. CORMANY HAROLD SHEELY, THE ADMINISTRATION ANDSTAFFOF THE CUMBERLAND COUNTY BAR ASSOCIATION, LYLEHERR, SAMUELCOOVERAND DIRKBERRY: OFTHECUMBERLAND COUNTY COURTHOUSE COURT OFCOMMON PLEAS CUMBERLAND COUNTY NO. 03-6123 CIVIL PRELIMINARY OBJECTIONS OF DEFENDANTS, LYLE HERR, SAMUEL COOVER AND DIRK BERRY~ TO PLAINTIFF'S COMPLAINT Defendants, Lyle Herr, Samuel Coover and Dirk Berry, by and through their attorney, William J. Devlin, Jr., hereby file Preliminary Objections to Plaintiff's Complaint and in support thereof aver as follows: 1. Plaintiff Cory Cormany has filed a fifty-two (52) paragraph complaint against various Defendants. 2. Plaintiff's Complaint fails to state any causes of action against Defendants, Lyle Herr, Samuel Coover and Dirk Berry ("Cumberland County Defendants") in a concise and summary form as required by the Pennsylvania Rules of Civil Procedure. See PA.R.Civ. P. 1019 (a). 3. Plaintiff's Complaint contains paragraph after paragraph of nonsensical sentences some of which contain English words and some which contain words that appear to be wholly made up by Plaintiff. 4. Defendants, Lyle Herr, Samuel Coover and Dirk Berry names are contained in only three paragraphs of plaintiff's Complaint (10, 12, 13 respectively). 5. For instance, in Paragraph 10 Plaintiff states: On December 19th, of the year 1990, Defendant Lyle Herr complained of an argumentative conversation, allegory the Plaintiff Cory Cormany, and did later contradict such stipulated implication, as in accordance with a Ms. Tina Adams and the Common Pleas Court of Cumberland County. 6. In Paragraph 12 Plaintiff alleges: On October 2nd, of the year 2001, Defendant Samuel Coover compiled a reactionary assault team, explicit the Plaintiff Cory Cormany, and did later excuse such stipulated implication, as in accordance with a Mr. David MacMain and the Common Pleas Court of Cumberland County. 7. In Paragraph 13 Plaintiff alleges: In and about the month of January 2002, Plaintiff Cory Cormany was directed and ordered a subpoena appearance, as in accordance with the Defendant Dirk Berry, which did deface a criminal element in the common Pleas Court of Cumberland County. 8. There are no plain and concise statements of what The Cumberland County Defendants did that would warrant a cause of action being asserted against them. 9. In Counts Two, Three and Four, Plaintiff alleges that Lyle Herr, Samuel Coover and Dirk Berry were "willful misconduct". 10. Plaintiff alleges in paragraphs 37 and 43 that: Preceding the situation and circumstances defined in the aforementioned statements, the plaintiff Cory Cormany was not ever depositioned for the purpose of probable cause, nor was he ever treated with an arbitrary reason of indifference for the purpose of an immunological affirmation. 11. Plaintiff alleges in paragraph 49 that: Preceding the situation and circumstances defined in the aforementioned statements, the plaintiff Cory Cormany was not ever summoned with prima-facie cause for the purpose of indictment, nor was he ever dispositioned for the purpose of an immunological service. 12. Nonsensical words placed on paper next to the names of Cumberland County Defendants does not state a cause of action, and the Court should dismiss PlaintifFs Complaint. 13. A demur will only be sustained where a Complaint or Pleading shows with certainty that upon the facts averred, the law will not permit the Plaintiff to recover. International Union of Operating Engineers v. Linesville Construction Co., 457 Pa. 220, 322 A.2d 353 (1974). 14. The court should grant the Cumberland County Defendants and demur to Plaintiff's Complaint based on Plaintiff's failure to plead in plain, clear and concise language a cause of action. 15. Plaintiff has not served the Complaint on the Cumberland County Defendants by proper service. The Complaint should be dismissed. WHEREFORE, Defendants, Lyle Herr, Samuel Coover and Dirk Berry, respectfully request this Court to grant their Preliminary Objections and to dismiss Plaintiff's Complaint in addition to such other relief as the Court deems appropriate. Respectfully Submitted, · 'a~'i]J. D~vlin, Jr., IE~q~ire Attorney for Defendant§, Lyle Herr, Samuel Coover and Dirk Berry DEVLIN & DEVINE William J. Devlin, Jr., Esquire Atty. I.D. #42717 Suite 200, 100 West Elm street Conshohocken, PA 19428 (610) 397-4614 Attorney for Defendants, Lyle Herr, Samuel Coover and Dirk Berry CORYA. CORMANY HAROLD SHEELY, THE ADMINISTRATION AND STAFF OF THE CUMBERLAND COUNTY BAR ASSOCIATION, LYLE HERR, SAMUEL COOVER AND DIRK BERRY: OF THE CUMBERLAND COUNTY COURTHOUSE COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 03-6123 CIVIL PRELIMINARY OBJECTIONS OF DEFENDANTS, LYLE HERR, SAMUEL COOVER AND DIRK BERRY~ TO PLAINTIFF'S COMPLAINT Defendants, Lyle Herr, Samuel Coover and Dirk Berry, by and through their attorney, William J. Devlin, Jr., hereby file Preliminary Objections to Plaintiff's Complaint and in support thereof aver as follows: 1. Plaintiff Cory Cormany has filed a fifty-two (52) paragraph complaint against various Defendants. 2. Plaintiffs Complaint fails to state any causes of action against Defendants, Lyle Herr, Samuel Coover and Dirk Berry ("Cumberland County Defendants") in a concise and summary form as required by the Pennsylvania Rules of Civil Procedure. See PA.R.Civ. P. 1019 (a). 3. Plaintiff's Complaint contains paragraph after paragraph of nonsensical sentences some of which contain English words and some which contain words that appear to be wholly made up by Plaintiff. 4. Defendants, Lyle Herr, Samuel Coover and Dirk Berry names are contained in only three paragraphs of plaintiff's Complaint (10, 12, 13 respectively). 5. For instance, in Paragraph 10 Plaintiff states: On December 19th, of the year 1990, Defendant Lyle Herr complained of an argumentative conversation, allegory the Plaintiff Cory Cormany, and did later contradict such stipulated implication, as in accordance with a Ms. Tina Adams and the Common Pleas Court of Cumberland County. 6. In Paragraph 12 Plaintiff alleges: On October 2nd, of the year 2001, Defendant Samuel Coover compiled a reactionary assault team, explicit the Plaintiff Cory Cormany, and did later excuse such stipulated implication, as in accordance with a Mr. David MacMain and the Common Pleas Court of Cumberland County. 7. In Paragraph 13 Plaintiff alleges: In and about the month of January 2002, Plaintiff Cory Cormany was directed and ordered a subpoena appearance, as in accordance with the Defendant Dirk Berry, which did deface a criminal element in the common Pleas Court of Cumberland County. 8. There are no plain and concise statements of what The Cumberland County Defendants did that would warrant a cause of action being asserted against them. 9. In Counts Two, Three and Four, Plaintiff alleges that Lyle Herr, Samuel Coover and Dirk Berry were "willful misconduct". 10. Plaintiff alleges in paragraphs 37 and 43 that: Preceding the situation and circumstances defined in the aforementioned statements, the plaintiff Cory Cormany was not ever depositioned for the purpose of probable cause, nor was he ever treated with an arbitrary reason of indifference for the purpose of an immunological affirmation. 11. Plaintiff alleges in paragraph 49 that: Preceding the situation and circumstances defined in the aforementioned statements, the plaintiff Cory Cormany was not ever summoned with prima-facie cause for the purpose of indictment, nor was he ever dispositioned for the purpose of an immunological service. 12. Nonsensical words placed on paper next to the names of Cumberland County Defendants does not state a cause of action, and the Court should dismiss Plaintiff's Complaint. 13. A demur will only be sustained where a Complaint or Pleading shows with certainty that upon the facts averred, the law will not permit the Plaintiff to recover. International Union of Operatin.q Enqineers v. Linesville Construction Co., 457 Pa. 220, 322 A.2d 353 (1974). 14. The court should grant the Cumberland County Defendants and demur to Plaintiff's Complaint based on Plaintiff's failure to plead in plain, clear and concise language a cause of action. 15. Plaintiff has not served the Complaint on the Cumberland County Defendants by proper service. The Complaint should be dismissed. WHEREFORE, Defendants, Lyle Herr, Samuel Coover and Dirk Berry, respectfully request this Court to grant their Preliminary Objections and to dismiss Plaintiff's Complaint in addition to such other relief as the Court deems appropriate. Respectfully Submitted, By: William J. Devil, Jr., Esquire- -/./v/ - Attorney for Defendants, Lyle Herr, Samuel Coover and Dirk Berry Stephen E. Geduldig, Esquire Attorney LD. No. 43530 Shawn E. Smith, Esquire Attorney I.D. No. 86121 THOMAS, THOMAS & HAFER, LLP Post Office Box 999 Harrisburg, Pennsylvania 17108-0999 (717) 237-7100 FAX (717) 237-7105 E-Mail: sc!ed uldia (~tthlaw.com Attorneys for Defendant: THE ADMINISTRATION AND STAFF OF THE CUMBERLAND COUNTY BAR ASSOCIATION CORY A. CORMANY, Plaintiff HAROLD SHEELY; THE ADMINISTRATION AND STAFF OF THE CUMBERLAND COUNTY BAR ASSOCIATION; LYLE HERR; SAMUEL COOVER and DIRK BERRY OF THE CUMBERLAND COUNTY COURTHOUSE, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-6123 CIVIL JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Stephen E. Geduldig, Esquire, Shawn E. Smith, Esquire, and Thomas, Thomas & Hafer, LLP, as attorneys for Defendant, The Administration and Staff of the Cumberland County Bar Association, in the above-captioned matter, reserving our right to answer or otherwise plead to Plaintiff's Complaint. 276198.1 By: Respectfully submitted, THO~S, THO~S & ~FER,, STEPHEN $. GEDULD~fT~,E~-~Q~RE Attorney I.D. No. 43530 S~WN E. SMITH, ESQUIRE Attorney I.D. No. 86121 Attorneys for Defendant, THE ~MINIST~TION A/gD STAFF C~BERLAND COUNTY BAR ASSOCIATION CERTIFICATE OF SERVICE I hereby certify that a tree and correct copy of the foregoing document was served by depositing the same in the United States Mail, served upon all parties of record by first class United States mail, postage prepaid, addressed as follows, on the date set forth below: Cory A. Cormany 1883 Douglas Drive Carlisle, PA 17013 Plaintiff, Pro Se William J. Devlin, Jr., Esquire DEVLIN & DEVINE Suite 200 100 West Elm Street Conshohocken, Pennsylvania 19428 Attorneys for Defendants, Lyle Herr, Samuel Coover and Dirk Berry The Honorable Harold F. Sheely Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 276199.2 THOMAS, THOMAS & HAFE___R, !,~lC'''~'. CORY A. CORMANY, Plaintiff HAROLD SHEELY; THE ADMINISTRATION AND STAFF OF THE CUMBERLAND COUNTY BAR ASSOCIATION; LYLE HERR; SAMUEL COOVER and DIRK BERRY OF THE CUMBERLAND COUNTY COURTHOUSE, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03-6123 CIVIL : JURY TRIAL DEMANDED ORDER AND NOW, this day of ,2004, upon consideration of the Preliminary Objections in the Nature of Demurrer by the Defendant The Administration and Staff of the Cumberland County Bar Association and the briefs of the parties with regard thereto, it is hereby ORDERED and DIRECTED as follows: 1. This Plaintiff has failed to effectuate service on the Defendants, any attempt at service is set aside and this court lacks personal jurisdiction over Defendant The Administration and Staff of the Cumberland County Bar Association; and 2. As the Complaint fails to set forth a viable cause of action against Defendant, The Administration and Staff of the Cumberland County Bar Association, preliminary Objections in the nature of a demurrer are sustained and any allegations against The Administration and Staff of the Cumberland County Bar Association Cumberland County are hereby dismissed. BY THE COURT: 276246.1 j. Stephen E. Geduldig, Esquire Attorney I.D. No. 43530 Shawn E. Smith, Esquire Attorney I.D. No. 86121 THOMAS, THOMAS & HAFER, LLP 305 North Front Street Post Office Box 999 Harrisburg, Pennsylvania 17108-0999 (717) 237-7100 FAX (717) 237-7105 Attorneys for Defendant: The Administration and Staffof the Cumberland County Bar Association CORY A. CORMANY, Plaintiff HAROLD SHEELY; THE ADMINISTRATION AND STAFF OF THE CUMBERLAND COUNTY BAR ASSOCIATION; LYLE HERR; SAMUEL COOVER and DIRK BERRY OF THE CUMBERLAND COUNTY COURTHOUSE, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-6123 CIVIL JURY TRIAL DEMANDED DEFENDANT~ ADMINISTRATION AND STAFF OF THE CUMBERLAND COUNTY BAR ASSOCIATION'S~ PRELIMINARY OBJECTIONS TO PLAINTIFF'S COMPLAINT AND NOW, comes Defendant, The Administration and Staff of the Cumberland County Bar Association, by and through its attorneys, Thomas, Thomas & Hafer, LLP, and files these Preliminary Objections to Plaintiff's Complaint and in support thereof, avers as follows: I. FACTS AND PROCEDURAL HISTORY 1. Plaintiff began this action by filing a Complaint in the Court of Common Pleas of Cumberland County on November 21, 2003. A copy of Plaintiff's Complaint is attached hereto as Exhibit A. 2. Moving Defendant was never served with the Complaint. 3. First, service was attempted via first class mail to an incorrect address, thus a copy was never even received. 4. Second, and regardless, service was not proper under the Pennsylvania Rules of Civil Procedure. 5. The first notice Moving Defendants had of being a possible party in this matter was from Attorney William Devlin, counsel for Defendants Herr, Coover and Berry, who copied the Moving Defendants at the correct address when he filed his Preliminary Objections. 6. In addition to the lack of service and therefore lack of personal jurisdiction, after reviewing the Complaint the Bar Association has no idea what Plaintiff is claiming. 7. Additionally, there is no cause of action set forth against the Bar Association. II. THERE WAS NO SERVICE AND THEREFORE~ NO PERSONAL JURISDICTION 8. Paragraphs 1 through 7 are incorporated herein as if set forth in full. The Cumberland County Bar Association was never served was PlaintifFs Complaint. 10. The Plaintiff, according to his certificate of service, attempted to mail the Complaint to an incorrect address. Exhibit A. 11. It is only because of Attorney William Devlin sending a copy to the correct address with his Preliminary Objections, that the Moving Defendants were even aware of having been named as a possible Defendant in a lawsuit. In fact, a review of the docket reveals that there is no certificate of service filed by 12. Plaintiff. 13. Further, even if Plaintiff had mailed the Complaint to the Bar Association's correct address, service would still be defective. 14. Pennsylvania Rule of Civil Procedure 400 requires that original process may only be served within the Commonwealth by the Sheriff, except for several specific types of cases. Pa.R.C.P. 400. 15. None of those exceptions apply to this case. 16. The requirements of the procedure that govern the validity of service of process must be strictly followed. Burger v. Borough of Ingram, 697 A.2d 1037 (Pa. Cmwlth. 1997). 17. The return itself is required to demonstrate that service was made in conformity with the rules. Id. WHEREFORE, Defendant Cumberland County Bar Association respectfully submits that service was inadequate and should therefore be set aside, as this Honorable Court does not have personal jurisdiction over the Moving Defendants. III. DEMURRER IS PROPER AS NO CAUSE OF ACTION IS PLED 18. Paragraphs 1 through 17 are incorporated herein as if set forth in full. 19. In addition to lack of, and improper, service, Plaintiff's Complaint fails to set forth any cause of action against the Cumberland County Bar Association and as such, Moving Defendants should be removed from the case. 20. Pennsylvania Rule of Civil Procedure 1028 prescribes preliminary objections as the appropriate method by which to challenge the legal sufficiency of the allegations a petitioner raises as a basis for relief. Pa.R.C.P. 1029(a)(4); In re Adoption of S.P.T., 783 A.2d 779, 782 (Pa. Super. 2001). 21. Where a defendant files preliminary objections to a plaintiff's complaint in the nature of a demurrer, the court's review is limited to the content of the complaint. In re Adoption of S.P.T., 783 A.2d at 782. 22. Thus, the court may determine only whether, on the basis of the allegations the plaintiff pled, he or she possesses a cause of action recognized at law. Id. A review of the Complaint reveals that there is no cause of action alleged by the 23. Plaintiff. 24. Even taken as true, to the extent that one can make sense of the allegations, nothing in the Complaint can be interpreted to establish a cause of action generally. 25. Moreover, there is no cause of action set forth in the Complaint against the Cumberland County Bar Association. 26. The only paragraph that even mentions the Bar Association is Paragraph 2 which alleges that Senior Judge Sheely is somehow an employee of the Cumberland County Bar Association. 27. Nothing in the Complaint states why the Moving Defendants are in the caption of this case. 28. As such, nothing in the Complaint can be read as establishing a cause of action against the Moving Defendants and a demurrer as to the Cumberland County Bar Association is appropriate. WHEREFORE, Defendants Cumberland County Bar Association respectfully submit that Plaintiff's Complaint fails to set forth any viable cause of action against Moving Defendants and as such, a demurrer is proper. IV. THE COMPLAINT SHOULD BE STRICKEN FOR FAILURE TO PLEAD IN A CLEAR AND CONCISE MANNER 29. Paragraphs 1 through 28 are incorporated herein as if set forth in full. 30. Finally, Moving Defendants submit that as Plaintiff has completely failed to plead his Complaint in a plain and concise manner under the Rules, it should be stricken. 31. Super. 1996). 32. Pennsylvania is a fact pleading state. Miketic v. Baron, 675 A.2d 324, 330 (Pa. Pennsylvania Rule of Civil Procedure 1019(a) requires that "[t]he material facts on which a cause of action or defense is based shall be stated in a concise and summary form." Pa.R.C.P. 1019(a). 33. The purpose of Rule 1019(a) is to require the pleader to disclose material facts sufficient to enable the adverse party to prepare his case and to convince the court that the averments are not merely subterfuge. Smith v. Wagner, 588 A.2d 1308, 1310 (Pa. Super. 1991). 34. The complaint must define the issues, and thus every act or performance essential to that end must be set forth. Miketic v. Barom 675 A.2d 324, 330 (Pa. Super. 1996). 35. Rule 1019(a) means the complaint must not only apprise the defendant of an asserted claim, but it must also synopsize the facts essential to support the claim. Id. 36. The complaint should be specifically specific so as to inform the defendant of the nature of the improprieties with which he is charged. Local No. 163, International Union of United Brewery v. Watkins, 207 A.2d 776, 779 (Pa. 1965). 37. General conclusions of law violate the requirements of Rule 1019(a). Pennsylvania PUC v. Zanella Transit, Inc., 417 A.2d 860 (Pa. Cmwlth. 1980). 38. If a complaint fails to meet these requirements, the court may sustain a preliminary objection for lack of specificity. Pa.R.C.P. 1028(a)(3). Moving Defendants barely understand what Plaintiff is saying, no less what he is 39. alleging. 40. Nothing in the Complaint mentions any wrongdoing by the Bar Association, a social and professional group of attorneys in the County. 41. Yet, it is named as a Defendant for no reason which is apparent in the Complaint. 42. This is a clear violation of Rule 1019 and thus, should the Court choose not to grant the Moving Defendant's demurrer, the Complaint should be stricken for failure to plead in a remotely plain and concise manner. WHEREFORE, Defendant Cumberland County Bar Association respectfully submits that Plaintiff's Complaint fails to meet any of the pleading requirements established by the Rules of Civil Procedure and as such, should be stricken. 276235.1 By: Respectfully submitted, THOMAS, THOMAS & HAFER, LLP ~t %-q,~m~. GeduldigX;W~iu~ Attorney I.D. No. 43530 Shawn E. Smith, Esquire Attorney I.D. No. 86121 Attorneys for Defendant, The Administration and Staff Cumberland County Bar Association , CL~4I~E:~,..~.ND COJNT¥ HR PLAINTIFF' CORY A, COI~MANY DEFENDANT HAROLD SHEELY, TI-lB: ADMINISTRATION AND STAFF OP TIlE; IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CASS XO. CUMBERLAND COUN1W GRIEVANCE ACTION ~ ;,;, HP. RR, SAM'LTEL C.~0OVER ,:~e.: 7?? ;.~ You have be~n sued in Court. If you wish to defend against the claim set forth in the foil. owing pages, you must take acQon within twenty (20) clays afmr thc C°~fam~T~d-N6~'~ are servcd~by entering a written appearance personally or by attorney and by filing in writing with ~e Court your defense or objection to thc claims :et forth against you, You are warned that ifyou fail to do so the case may proceed without yo~ and judgment may be enter~i agair~t you by the Court without further notice for an)' money claimext in the Complaint or for any other claim or r;lief requ~$1zd by Plaintiff. You may lose money or property or other rights imporunt to you. YOU SHOULD TAKE T'FES PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAvE A LAWYER OR CANNOT A1;FO~ ONE, GO TO OR TELEPHONE ~ OFFICE SET FORTH BELOW TO FIND OUT WI. IERE YOU CAN GET LEOAL I-[ELP. Court Admiu{sirator Cumberland County Court I'-Iou~e 1 South I--I~nover Strut CarI~sIe, PA. 17013 ~ ~ , ~ Jan ~ ~u~ '~'>~l'10 5289'~°P, a, 23 ,lan 29, 2004~' 3:i2FM PEEP. L~,:,~ In,,, Xb.,, Pa, 17011 . PLAInTiFF CORY A. COR/WASrY DEFENDANT EAR, OLD SI~ELY, ADMINISTRATION AND STAFF OF TI{E : CUMBERLAND COUNTY BAR ASSOCIATION, LYLE : HERR, SAMUEL COOVER AND DIRK BF.3~Y OF THE : CUMBERLAND CO~'Y COU~.T HOUSE : IN TH~ COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENN~YI,VANIA CAS~ NO. GI;JEVANCE ACT/ON ~RY Ti~JAL/3UDGNfENT OI~EVANC£ CO~tA~T Defendants Lyle Herr, Samuel''''~ ''' t'~3.~ Coovet and Dirk Ben7 ate ~ul! individual~ employed by the CUmberland County Court Hou.~e, Cumberland County, Pennsylvania. '.i,~n. ?. 200~~l 3: Pleas 4. Plaintiff' Cor~ Corm~-~ is a. high school ~r~lu,,~e, -c~lcmicall~' ~Nev~d ~u~ a ~ive~i~ or ~ivc~i~s, ~ ~ayer~ a re~ster~ your ~d a ci~zen o~ ~e United States ~. In ~d about '~,~ y~ 19g~ ~d ~ou~ ~d ~ut ~e applica~on h~e~, Pl~ntiff Co~ C~y w~ 'subju~md ~imi~ ~d ci~l ~cons~mgon~ a duc process; h~eto ~e Commbnwe~h of P~ylv~ia. 6. ~e c~mi~l to~s 85-0722, 86-0358, 89-2068, 91-0~0J, 92-1252, 93-1078, 93-1079, 94-0973, 9~974, 94-1222, 95-0027 ~d 9~-0376 in ~he Common Pl~a Cou~ of C~land Co~ is in accor~ce wi~ ~e solicit r~lfications litigated in ~e civil case 1:CV-9~-0844 filed in ~e U~md States Dia~ct COurt for. Pe~sylvania. 7. ~e criminal t~s 94-1~ 95-0J75 and 95-0376 in ~e Common Co~ of C~l~d Co~ is in accord~ wi~ ~e proced~l obIigatlons ~ted in ~he civil c~es 95-5222, 96-1730 ~d 96-1969 fil~ ~ ~e C~l~d Co~ Common Pleas Co~ f~ P~ylv~ia. 8. ~c c~l m~s 96-1584, 97-0174, 97-1443, 97-I~4, 97-1445, 97-1~6, 97-1447, 97-1448, 97-~04 ~d 97-1701 in ~c Common Pleas Co~ of C~b~land Co~ is ia sc~r~ce wi~ the solicit ~fi~tiom li6gamd in ~e civil c~e I:CV-01-1801 filed ~ ~e United $~gs Dis~c: Co~ ~r Pe~ylv~i~ 9, The criminal te~s 97-1504, 01-0~2 ~ou~. 01-0097 ~ ~e C~mon Ple~ Co~ of Cum~rl~d Co~W is in acco~ce ~ ~e obllga~o~ aamd in ~e civil cases 96-443~, 01-1727 ~d 0~-6467 filed in ~e Cumberland County Common Pleas Court for Pennsylvania. ~ On December 19th, of the yc~' 1990, Defendant Lyle Herr comported of' an ar&umentat/ve conversation, ~llegory the Plaintiff Cory Corman7, and did later contradict such. aipulated implication, as in accorcknce with a Ms. Tina Adams and the Conunon Ple~ Court of Cumberland County. 1 I. I.n or about the month of February 1995, Plsdntiff Cory Corman), direcmd and ordered a psychiatric review, as in accordance with the Defendant Harold Sheely, which did consequently breach an agrccrn~rit in the Common Pleas Court of' Cumberland CounW. 12. On October. 2nd, o£ the year 2001, Defendant Samuel Coover compiled a reactionary assault team, explicit the Plaintiff Cory Co,many, and did later excuse such stipulated implication, as in accordance with a Mr. David MacMain and the Common Pie= Court of Cumberland C0unty. ! 3. In and about the mcn~ cf,ranuary 2002, Plaintiff Cory Corm~ny was direc~ and ordered a subpoena appe,~ranca, as in accordance with the Defendant Dirk Berry, whi.ch did deface a criminal element in the Common Ple~s Court of Cumbcrl~,nd County. 14. The case numbers 94-1679, 95-0310 anc~ 01-4467 in the Catv. moa Pleas Court of Cumberland County do collaborate · Mr. P, symond Motter, a Mr. .l'ohn Adams, and a Mr. Ce, r] Heyward; alleiaz7 illicit n~rcot/c act/vary witaessed by 6~e Plaintiff Cory CormanT in the Co~.nmonwcalth o£ Penmy]vani~. 15, The Commonwealth o£.Penn~ylvania ha~ co~victad .Mr. Carl '.l,~s. £?, £005~£ 3:L3FM FEE~LESS Ir~s, Hba, Pa, 170!1 ~an ~ ~uu~ ~l'Io, 5289'u~P. ?, 23 Heyw~rd, Mr, .rohn Ado.ms and Mr. Raymond Motter of crimes identified arid associated with illegal narcotic actions, as in a~¢ordance wilh the Corllrolled Submnce Act set forth by the United States of America. 16. The Plaintiff Cory Coii. any has acknowl,'dged Criminal. Civil and Acres[ issues of malice identified and e.~so¢iated with unconsfitutioml public actions, as in acc. oral,ce with the Post Conviction Act set forth by the Statues of America. 17. The case numhel's 1:CV-95-0844 and 1:CV-01-1803 in. the Middle District Court of the United States were adjudicated and dismissed, accordance with the niles of court set forth by the Commonwealth of PermsylvanJs. ! $. On lunc 7th, of the year 2002, the Pl~intlff Cory Cormany required an expensive civil c~mplaim responsible th~ Commonwealth of Penneylvanla, and sufficient s procedure as in accordance with P.$A. 42 R.C,P. 205.2, 227.4, 239 ~.nd P.S.A. 42 J.~I.P. $30d, 5306 ar~i ~07, 19. On March lSth, of thc year 2002, the Pla;ntiff Cory Cormany several repons liible the. Attorney General's Office and argumentative. procedure, ss in. accordance with P.S.A. 42 R.C,P. 132, 133, 134 and P.$.A. 42 J.I.P, 1513, 1514 and 151.5. 20. The Commonwealth of Penmylvsnta did precede criminal allegations slanderous a c, onflic~ion of interest, and ~.oncertif]¢d an official service, for the cas~ number 01-2091; naming the PLtimiffCory Corrnany a defendant substantial .lan ?. £Q,04~L q' 13FI,~ FEERL=,.,: In,. Hh.;, Pa. 170t~ a County Detective WilJiam Diehl, 21.) The Commonwealth of Permsylvania did proceed crLminal commitments mslieiou~ a pro~ecutorial conduct and noneertifiad aa official appezrance; usable the Defendznt~ Lyle .FIett,, Samuel Coove~ ~saccortt~mee vaith P.S,A. 42 R.C,P, 58, 71, 84, 85, 113. 122, 124 aad i34. 22, The Commonwealth of' Pennsylvania did precede criminal proi~a~nda solicit a c.a~d'ul liability, and c~ni.fied an o£fldal accusaSon, for the case number 01-0494; namin$ the ?lai~tiff Cory Cormany a defendant substantial a Cour~ A~tome¥ Edmund,Zigmund. 2~, The Comm~nwealt~ of Pe~ylva~ia corispira~orial an' ac£ of justice and certified an official position; u.~ble the Det'~ndants H~rold Sheely and ~so¢iates as in disaocord~ce with P.$.A. 42 R.C.P. $S, 65, 66, I01, 102, 110, 123 and 130. 24. The intentional snd crimt~d'ramiflcatlon~ demonit/zed in the case numbers 15-0722, 86-0~8, 89-20~8, 91-050~, ~2-12~2, 9~-1078, 9~-1079, 94- 0973, 94-097,i, 94-1221, 9~-0027, ~$-0374, 9B-037~, 95-0376, 96-1584, 97- 0124, ~7-14d3, 97-1444, 97-1445, 97-1446, 97-1447, 97-1448, 97-1504, 9'/- ]701, 01-0092, 01-009B, 01-0094, 01-0095, 01-0096 and 01-0097, clecidsbla th~ Common Pleas Cour~ of the Cuml:ed~nd Couut~, Commonwealth and Uni~l Slates Constitutions. 25. The compensatory and punitive ramificatio~l remedial~ in the numbers 95-5222. 96-1969, 01-646'/and 03-1771/, convincible the Common Pleas Hha, Pa. i?Oli ~an ~r ~ =o'~'No. 5289~° P. 9~20 Court of the Cumberland COUnty, are i~ di.~aecordaace wifla the Comrnoaw~alfla a~d United S~.~es Constitutions. 2~.6./ The PI~n~ Co~ Comfy h~ suff~ed pubic M~iliati~ as caus~ by ~e dd~fion of his oh~lct~, p~ and physic] ~ja~ ~ a r~lt of fl~a .~fga~t:' m~iciou$ ~d ~reju~ci~ a~ions. 27. The Plain6ff Co~ Co~<ly h~ S~ged m~tfl a~s~ ~mofi~al · s~s$, im~so~eng loss of cm~o~ngm ~d i~m~t fight ~ a resuR of ~ Def~ts' m~icio~s aud prej~icial actions. 28, ~ Plaintiff' Co~ C~y ~$ s~r~ lost wagos, b<ofiu, fg~ ~d prop~ M ~e ~ount m ezcgas of Two H<&~ ~d Fi~ ~o~d ~d 00 ~llea (250,000,00) as r~a~t of ~e D~' ~tcious ~d ~r~ju~ci~ CORY A. CORMANY V. IIAR,0LD SHEELY AND ASSOCIATES GRII~VANCE ACTION WILLFUL MISCONDUCT (l-2g) of ~e Grievance Compl~m ~e inco~ora~ed by refe~ ~ if set forth ~ a ~tement. 30. The prejudicial and rnslicious m~'t~-s and actions a~ serious as submissiv~ ~e or~ of ~e co~ ~d ~bi~ A ~ou~ I. 31. P~cedi~ the sit~tlons ~d circ~s~l~ defined in aforementioned st~ment~, ~e Plaingff Co~ Co~y was not ever ~w~d a law~l ~vi~dc ~or ~e p~se of a pursuit in haziness, nor was M petifi~ ~ a se~ic~ble indic~enl for ~e p~ose of ~ 32. ~e: ~feng~t H~old Sheely ~d impl~ent policy ~d d~liva within or ~Shou~ ~ inci~n~ ~d iau~ in qu,s~on, ~nd ~s prooedure. 33. The Plaintiff Cory Connally did sla"fer pain for injuries fel~ anti (7) sustained, mental ansuish, public' l~umilio*ion, emotional d~e~ss, ~4. By re.on of ~e efore~d me.r. Plaintiff s~ered ~, i~j~, mental ~gui~, ~bljc h~ili~io~ em~io~l ~s, loss of inherent rith~ loss of ~plo~ent ~d '~op~, contingent ~d inc~e~tion. ~FO~, ~e Plaintiff Co~ Co,a~y, claims ~ ~ount in excess of T~ Hundred m~d Fi~ ~ou~d snd ~ Doll~s (2~0,0~.~) pl~ cos~ of suit. CORY A. COKMAN'Y V. LYLE I-IEKK GKIEVANCE ACTION WILLFUL MISCONDUCT 35. The ~v~rnems ~et forth in para~aphs One tbtoush twenly ei~h~ (1-28) of the G~evan¢= ComplaLut are i~¢orporated by r~f~ence ~s if se! forth as a statement. 36. having happened in the Cumberl~d County, pennsylvania, respectfuJly submissive the order et' the court and exhibit~ A through Y. Precedin~ the situations and circumstances defined in the aforen~en~io,ed s~tements, the Plaintiff' Cory Corrn~ny w~ not ever ~lepo~itioned for t~e purpose of p~ob~ble cause, nor was he ever service~i wi~ re.on of indifference for ~e purpose of aa immunological af!-wm,at~on. ~38.) Thc Do£~cl~mt Dylc Hm'c dlcl iruplemcnt policy ~4 cli~[v~ withiu or thr~ugh~ut the inciden~ sud issues in clue~i°n, and does have supervisory power unconstltuticnal an effective legislative, judiciary or executive procedure. s9. The Plsin~iff Cory Corm~,y. did suffer p~in for injuries felt and sustained, m~nt~l ~gulsh, public humiliation, emotion.1 distress, loss of inherem right, loss o£ employme~ .nd property, confinement md i~c~rcer~tion. 61/~j$/:260~' 85:1'~ 71'72a97977 40. By reason of the aforesaid matter, Plaintiff Cory Cormany has -suffered pain, injury, menial imguisb, public hamiliatlon, emotional distress, of inherent right, loss ~f employment and property, 'confinement incarceration. WHEREFORE, the Plaintiff Cory Cormany, elalm$ fi-om the l~fenclant in an amount in excess of Two Hundred and Fi/by Thoasmd and 00 Dollars (2~0.000,~) plus cost of suit. CORY A. COR~ANY v. ~AlvtUEL C00VER GI~IEVANCE ACTION WILLFUl- MISCONDUCT 41. The averments set forth in Paragrapl~ one throui~ twet~ty eight (1-25) of the (3rievance Complaint are incorporated by reference as if set forth as a 9tat~ment. 42. The prejudicial and maliciou~ matters and actions are seriou9 as having hal:gened in the Cumberland County, pennsylvania, respectfully s~bm~e the order of the court and exJfiblts A through L Preceding the situations nad circumstances defined in the aforementioned statements, the Plaintiff Coq, Cormany wee not ever ~positioned for the pm-pose of probable cause, nor was he ever serviced with an arbltrar~ rea$o~/oilinditTcrence for thc purpos~ of.n imm~nol~sical affiTedon- ix~// The l~fen&nt Samuel Coov~r did implement pohcy arid dir~c~ve wi~hln or throughout the in;Meats a~ttt issues in question, and does have supervisory power unconstitutional an effective legislative, judiciary or executive l~ocedure. 45.' The Plaintiff Cory C0rmany did suffer pain for injuries felt and sustained, ment:~l ansui~h, public hurniJiation, emotional distress, loss of inherent Bl/BG/20~' o5:~3 7t72~S7~77 !ns Htr, Pa 170!1 o~,, =, .~ right, loss of employment and property, confinement ~md incazcerstion. 46. By ~n of ~h~ afore,~d ma~, Plaimiff Cou Com~ ~s ~uff~ed p~, init, mental ~uish, pubUc hmUiation, cmot[o~l di,~ss, loss of i~er~t ri~h~ Io~ of emplo~cm ~d prop~, co~nement ~d inc~on. ~FO~, the ?l~nfiff Co~ Co~y, cl~s ~ ~e ~fen~t ~. ~ ~o~t in excess of Two H~ed ~d Fi~ Tho~d a~ ~ DolOrs (250.000.00) plm cost of suit, ~1/1~$/28~4 I)~:I ~ CORY A. COP, M. ANY v. UIRK BERRY ORIEVANCE ACTION WILLFUL MISCONDUCT a7, The avemae~ts s~t forth in Para~rapl~ one throuSh tweo,ty (1-28) of ~e ~ev~ce Compare ~e ~e~o~ted by refer~ce a S~t~cnL 48. ~e pr~judici~ ~d maticio~ ma~ ~d ~dom havi~g h~p~e~ in ~e C~rl~ Co~, P~nsylv~ia, res~c~lly sub~isslvs ~e order o~e co~ ~d e~bi~ A ~ou~ I. ~e st~tio~ ~d circ~st~ces defined Prece~in~ ~fore~ent~oned ~mt~men~, ~e Pl.~ff Co~ C~y wa~ n~ ever ~m~ed wi~ pr~-f, cie c.~ for ~e p~e o~ ind~c~en~ nor w.~ be ever ~p~ed for ~e p~ose of m i~ogicsl ~ ~ou¢out ~ incf~u~ aod ~ues m ques~on, ~d does h~ve powe~ ~conetkudo~ ~ effe~ive I, egisl~dve, judici~ or executive ~O~d~c. ~1. The Pl~n~ff C~ Co.my ~d ~fe~ pzin for ~es felt s~t~ined, m~l ~n~sh, p~lic h~ili~, emotion.l di~es~, lo~ ~ 1o~ of emplo~t ~d ~ope~, confinement ~d incam~on. CU~:~L~ND C~I_INTY ~ ~2. By reason of the aforesaid raitter, Plaintiff Cory Cormany has suffered pain, injury, mental a~gulsh, p,blic humiliation, emotlonsl digress, loss of inherent ritht, loss of employment md property, confmcment a~d incarceration. WHBRI/FOP-,.E, th~ Plaintiff Cory Carmany, c],,ims fi.om the Defendant ]n an amount in excess of Two Ht~clred and Fifty Thousand and O0 Dollars (250,000,00) plus cost of suit. ~' ?4,0E 3: 15PI,i PEERLE,$,S In:;, 81/8~/2884 85:13 O..l~,,tSE~Ln,wID C~I..~TY ~R A. Dockets: Registration and Ace:l~mic mck~owl~nmntm B. Records: Coun~ Decis/on~ ~d ~s of Refe~ D. Record: Ord~s of Co~ ~d ~ucst Fora ~ck~: ~Ucrs reg~ding co~sel md c~m~nd proccd~e F. Records: Civil case file G. Dockets: Crimil~al Reports H. Reports: Criminal Complaints I[. pegtion: Crib,hal Manet 717240?$77 C~i~D COJNTY ~ (ZT:.RTIFICATION OF ~ AND NOW, ~hi~.~_ day of ~ 2002, I Co~ A. Cormany foregoint~ the aforesaid matt~ on b~lf of my A~omey, h~e~ c~i~ ~at I have s~ ~e fore~oin& d~t up~ ~e followin~ by d~osifin8 a ca~ of same in ~c Uni~d S~s Mail, at C~]i~te P~n~ylv~ ad.~esscd ~ follows: Curnb~rl~d County B~r Association Harold Sheely and Associ~t. cs I Souih Hanover Su'eet Carl|51c, PA 17013 Cumberl~nd County Cour~ House L¥1e Herr $~.m~l Coover Dirk Bet./ 1 South Hnnover Street Carlis]e, PA 17013 .Cory i. Corm~ny lSS:~ Dou~l~ Dr. C~rlislc, Pa, 17013 ~ 2O04aoE 3'15PI'~I PEERLE,% 'ns. O.i~IBER~'qD cDJqtv kl~ I, Cory A. Comae.ny, Plaint;ff in the above captioned action, hereby verify ;nd state that the facts act forth in the Grievance Complaint agatnst Harold ~thedy, the A~'nLuistzatlon and Staff of th.e CurnlperlaJad County Bm As,ociation, L)de Hen', SamUel Coover an~t Dirk Berry arc true ~.d correct to the b~ of my information, knowledge, and belief. I underst-nd that false sta~menta herein are made subject to *.he penalties of 18 Pa. C.S.A. Section 4904 relating to m~swom vcrificntion to authorities. Coif A. Con:nan7 (I~) CERTIFICATE OF SERVICE I hereby certify that a tree and correct copy of the foregoing document was served by depositing the same in the United States Mail, served upon all parties of record by first class United States mail, postage prepaid, addressed as follows, on the date set forth below: Cory A. Cormany 1883 Douglas Drive Carlisle, PA 17013 Plaintiff, Pro Se William J. Devlin, Jr., Esquire DEVLIN & DEVINE Suite 200 100 West Elm Street Conshohocken, Pennsylvania 19428 Attorneys for Defendants, Lyle Herr, Samuel Coover and Dirk Berry The Honorable Harold F. Sheely Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 276199.2 Sh~ith, Esquire PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter for the next Argument Court. CAPTION OF CASE: (entire caption must be stated in full) CORYA. CORMANY, (Plaintiff) VS. HAROLD SHEELY, THE ADMINISTRATION AND STAFF OF THE CUMBERLAND COUNTY BAR ASSOCIATION LYLE HERR, SAMUEL COOVER AND DIRK BERRY OF OF THE CUMBERLAND COUNTY COURTHOUSE,, (Defendants) t.t~3 No. ~"~"~ ,,.~ Civil 2003 State matter to be argued (i.e., plaintiff's motion for new trial, defendant's demurrer to complaint, etc.): Preliminary Objection of Defendant The Administration and Staff of the Cumberland County Bar Association 2. Identify counsel who will argue case: (a) for plaintiff: address: Pro Se, Cory A. Cormany 1883 Douglas Drive, Carlisle, PA 17013 (b) for defendants: Shawn E. Smith, Esquire address: P.O. Box 999, Harrisburg, PA 17108 Dated: 4. January 29, 2004 I will notify all parties in writing within two days that this case has been listed for argument. Argument Court Date: .~' Attorney for Defendant The Adm~n'~0n and Staff of the Cumberland County Bar Association CORY A. CORMANY, Plaintiff HAROLD SHEELY; THE ADMINISTRATION AND STAFF OF THE CUMBERLAND COUNTY BAR ASSOCIATION; LYLE HERR; SAMUEL COOVER and DIRK BERRY OF THE CUMBERLAND COUNTY COURTHOUSE, Defendants : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-6123 CIVIL TERM IN RE: PRELIMINARY OBJECTIONS OF DEFENDANT ADMINISTRATION AND STAFF OF CUMBERLAND COUNTY BAR ASSOCIATION TO PLAINTIFF'S COMPLAINT BEFORE HOFFER, P.J., and OLER, J. ORDER OF COURT AND NOW, this 1st day of April, 2004, upon consideration of the preliminary objections of Defendant Administration and Staff of the Cumberland County Bar Association, and for the reasons stated in the accompanying opinion, the preliminary objections are sustained and Plaintiff's complaint is dismissed as Administration and Staff of the Cumberland County Bar to Defendant Association. BY THE COURT, ~.. X~Tesley Oleff~, J. Cory A. Cormany 1883 Douglas Drive Carlisle, PA 17013 Plaintiff, pro Se Stephen E. Geduldig, Esq. Shawn E. Smith, Esq. Thomas, Thomas & Hafer, LLP 305 North Front Street P.O. Box 999 ,,~,]0~4 Harrisburg, PA 17108-0999 Attomeys for Defendant Administration and Staff of the Cumberland County Bar Association Willimn J. Devlin, Jr., Esq. Devlin & Devine Suite 200 100 West Elm Street Conshohoeken, PA 19428 Attomey for Defendants Herr, Coover and Berry CORY A. CORMANY, : Plaintiff V. HAROLD SHEELY; THE ADMINISTRATION AND STAFF OF THE CUMBERLAND COUNTY BAR ASSOCIATION; LYLE HERR; SAMUEL COOVER and DIRK BERRY OF THE CUMBERLAND COUNTY COURTHOUSE, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-6123 CIVIL TERM IN RE: PRELIMINARY OBJECTIONS OF DEFENDANT ADMINISTRATION AND STAFF OF CUMBERLAND COUNTY BAR ASSOCIATION TO PLAINTIFF'S COMPLAINT BEFORE HOFFER, P.J., and OLER, J. OPINION and ORDER OF COURT OLER, J., April I, 2004. For disposition in this civil case in which a pro se Plaintiff has sued various individuals and "the Administration and Staff of the Cumberland County Bar Association," preliminary objections to Plaintiff's complaint have been filed on behalf of the Administration and Staff of the Cumberland County Bar Association (hereinafter Defendant).1 The preliminary objections being pursued by Defendant are in the nature of a demurrer and in the form of a motion to strike for failure to t Defendant, Administration and Staff of the Cumberland County Bar Association's, Preliminary Objections to Plaintiff's Complaint, filed Jan. 29, 2004 (hereinafter Defendant's preliminary objections). plead facts in a concise and summary form in conformity with Pennsylvania Rule of Civil Procedure 1019(a).2 The bases of the preliminary objections are that only one paragraph in the complaint mentions Defendant,3 that "[n]othing in the Complaint states why [Defendant] is in the caption of the case,''4 that "[n]othing in the complaint mentions any wrongdoing by Defendant,''s and that the complaint is basically incomprehensible.6 Defendant's preliminary objections were argued on March 24, 2004.7 For the reasons stated in this opinion, Defendant's preliminary objections will be sustained and Plaintiff's complaint against Defendant will be dismissed. STATEMENT OF FACTS Plaintiff's complaint in the above-captioned matter was filed on November 21, 2003. Paragraph 1 of the complaint identifies the Plaintiff as "an adult individual residing in Carlisle, Cumberland County, Pennsylvania? Paragraph 2 states that "Defendant Harold Sheely and associates are adult individuals employed with the Cumberland County Bar Association, Cumberland County, Pennsylvania.''9 Paragraph 3 states that Defendants Lyle Herr, Samuel Coover and Dirk Berry are adult individuals employed by the Cumberland County Court House, Cumberland County, Pennsylvania. J0 Typical of the 51 paragraphs which follow are these: 2 At oral argument, Defendant's counsel waived a preliminary objection based upon improper service of the complaint. 3 Defendant's preliminary objections, para. 26. 4 Defendant's preliminary objections, para. 27, 40. s Defendant's preliminary objections, para. 40. 6 Defendant's preliminary objections, para. 39. 7 Plaintiff neither submitted a brief nor appeared for argument. a Plaintiff's complaint, para. 1. 9 Plaintiff's complaint, para. 2. l0 Plaintiff's complaint, para. 3. 2 5. In and about the year 1985 and through and about the application herein, Plaintiff Cory Cormany was subjugated criminal and civil allegation unconstitutional a due process; hereto the Commonwealth of Pennsylvania. 6. The criminal terms 85-0722, 86-0358, 89- 2068, 91-0505, 92-1252, 93-1078, 93-1079, 94-0973, 94-0974, 94-1222, 95-0027 and 95-0376 in the Common Pleas Court of Cumberland County is in accordance with the solicit ramifications litigated in the civil casel:CV-95-0844 filed in the United States District Court for Pennsylvania. 7. The criminal terms 94-1222, 95-0375 and 95- 0376 in the Common Pleas Court of Cumberland County is in accordance with the procedural obligations stated in the civil cases 95-5222, 96-1730 and 96-1969 filed in the Cumberland County Common Pleas Court for Pennsylvania. 8. The criminal terms 96-1584, 97-0174, 97- 1443, 97-1444, 97-1445, 97-1446, 97-1447, 97-1448, 97-1504 and 97-1701 in the Common Pleas Court of Cumberland County is in accordance with the solicit ramifications litigated in the civil case 1:CV-01-1803 filed in the United States District Court for Pennsylvania. 9. The criminal terms 97-1504, 01-0092 through 01-0097 in the Common Pleas Court of Cumberland County is in .accordance with the procedural obligations stated in the civil cases 96- 4435, 01-1727 and 01-6467 filed in the Cumberland County Common Pleas Court for Pennsylvania. 11. In or about the month of February 1996, Plaintiff Cory Cormany was directed and ordered a psychiatric review, as in accordance with the Defendant Harold Sheely, which did consequently breach an agreement in the Common Pleas Court of Cumberland County. 16. The Plaintiff Cory Cormany has acknowledged Criminal, Civil and Actual issues of malice identified and associated with unconstitutional public actions, as in accordance with the Post Conviction Act set forth by the United States of America. 17. The case numbers of 1:CV-95-0844 and 1:CV-01-1803 in the Middle District Court of the United States were adjudicated and dismissed, as in accordance with the rules of court set forth by the Commonwealth of Pennsylvania. 20. The Commonwealth of Pennsylvania did precede criminal allegations slanderous a confliction of interest, and noncertified an official service, for the case number 01-2091; naming the Plaintiff Cory Cormany a defendant substantial a County Detective William Diehl. 23. The Commonwealth of Pennsylvania did proceed criminal hearings conspiratorial an act of justice and certified an official position; usable the Defendants Harold Sheely and associates as in disaccordance with P.S.A. 42 R.C.P. 58, 65, 66, 101, 102, 110, 123, and 130. 24. The intentional and criminal ramifications demonetized in the case numbers 85-0722, 86-0358, 89-2068, 91-0505, 92-1252, 93-1078, 93-1079, 94- 0973, 94-0974, 94-1222, 95-0027, 95-0374, 95-0375, 95-0376, 96-1584, 97-0174, 97-1443, 97-1444, 97- 1445, 97-1446, 97-1447, 97-1448, 97-1504, 97-1701, 01-0092, 01-0093, 01-0094, 01-0095, 01-0096 and 01- 0097, decidable the Common Pleas Court of the Cumberland County, are in disaccordance with the Commonwealth and United States Constitutions. 25. The compensatory and punitive ramifications remedialized in the case numbers 95- 4 5222, 96-1969, 01-6467, and 03-1778, convincible the Common Pleas Court of the Cumberland County, are in disaccordance with the Commonwealth and United States Constitutions. 28. The Plaintiff Cory Cormany has suffered lost wages, benefits, fees and property in the amount in excess of Two Hundred Fifty Thousand and 00 Dollars (250,000.00) as result of the Defendants' malicious and prejudicial actions. 30. The prejudicial and malicious matters and actions are serious as having happened in the Cumberland County, Pennsylvania, respectfully submissive the order of the court and exhibits A through I. 31. Preceding the situations and circumstances defined in the aforementioned statements, the Plaintiff Cory Cormany was not ever empowered a lawful servitude for the purpose of a pursuit in happiness, nor was he ever petitioned with a serviceable indictment for the purpose of an immunological warrant. 43. Preceding the situations and circumstances defined in the aforementioned statements, the Plaintiff Cory Cormany was not ever depositioned for the purpose of probable cause, nor was he ever serviced with an arbitrary reason of indifference for the purpose of an immunological affirmation. Il DISCUSSION As a general proposition, Pennsylvania courts are not required to entertain submissions which are incoherent, incomprehensible or unintelligible. See, e.g., Commonwealth v. Albert, 522 Pa. 331, 561 A.2d 736 (1989); Commonwealth ex tel. Swarm v. Shovling, 423 Pa. 26, 233 A.2d 1 (1966). Thus, it has been said that "[p]reliminary objections are certainly appropriate where a pleading Plaintiff's complaint, at 1-11. 5 is ,.. incoherent .... "Jackson v. Richards 5 & lOInc., 289 Pa. Super. 445, 451, 433 A.2d 888, 891 (1981). More specifically, under Pennsylvania Rule of Civil Procedure 1019(a), "[t]he material facts on which a cause of action or defense is based shall be stated in a concise and summary form." Implicit within this rule is a requirement that the pleading be intelligible. See Allensworth v. First Galesburg Nat? Bank & Trust Co., 18 Ill. App. 2d 608, 152 N.E.2d 890 (1958). Where a portion ora pleading fails to conform to the rule, it is susceptible to a preliminary objection. See Pa. R.C.P. 1028(a)(2) (failure of pleading to conform to law or rule of court). Upon consideration of such an objection, the court may properly strike the affected pleading. See, e.g., Commonwealth, Pennsylvania Public Utility Commission v. Zanella Transit, Inc., 53 Pa. Commw. 359, 417 A.2d 860 (1980). Under Pennsylvania Rule of Civil Procedure 1028(a)(2), a pleading which is legally insufficient to set forth a cause of action is also susceptible to a preliminary objection. Implicit within this rule as well is a requirement that the pleading be intelligible. See Allensworth v. First Galesburg Nat'l Bank & Trust Co., 18 Ili. App. 2d 608, 152 N.E.2d 890 (1958). Upon consideration of such an objection, the court may properly sustain a demurrer and dismiss the pleading. Id. In this regard, it is well settled that "[p]leadings will be construed against a pleader on the theory that he or she has stated his or her case as best he or she can." 2 Goodrich Amram 2d 1019:7, at 249 (2001). In the present case, a careful reading of Plaintiff's complaint indicates that Plaintiff's claim is not stated in a concise and summary form in the sense of being intelligible, Furthermore, as Defendant notes, the Cumberland County Bar Association is mentioned in only one paragraph of Plaintiff's complaint (paragraph 2). Even if it is assumed, as alleged by Plaintiff, that former President Judge Sheely of this court is, or was, somehow an "employee" of the Bar Association, a fair reading of the complaint does not set forth any cognizable 6 cause of action against its administration and staff. For these reasons, and based upon the foregoing principles of law, the following order will be entered: ORDER OF COURT AND NOW, this 1st day of April, 2004, upon consideration of the preliminary objections of Defendant Administration and Staff of the Cumberland County Bar Association, and for the reasons stated in the accompanying opinion, the preliminary objections are sustained and Plaintiff's complaint is dismissed as to Defendant Administration and Staff of the Cumberland County Bar Association. BY THE COURT, /s/5. Wesley Oler, Jr. J. Wesley Oler, Jr., J. Cory A. Cormany 1883 Douglas Drive Carlisle, PA 17013 Plaintiff, pro Se Stephen E. Geduldig, Esq. Shawn E. Smith, Esq. Thomas, Thomas & Hafer, LLP 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 Attorneys for Defendant Administration and Staff of the Cumberland County Bar Association William J. Devlin, Jr., Esq. Devlin & Devine Suite 200 100 West Elm Street Conshohocken, PA 19428 Attorney for Defendants Herr, Coover and Berry 7 Stephen E. Geduldig, Esquire Attorney I.D. No. 43530 Shawn E. Smith, Esquire Attomey I.D. No. 86121 THOMAS, THOMAS & HAFER, LLP 305 North Front Street Pest Office Box 999 Harrisburg, Pennsylvania 17108-0999 (717) 237-7100 FAX (717) 237-7105 E-Maih saeduldia @tthlaw.com Attorneys for Defendant: THE ADMINISTRATION AND STAFF OF THE CUMBERLAND COUNTY BAR ASSOCIATION CORY A. CORMANY, Plaintiff HAROLD SHEELY; THE ADMINISTRATION AND STAFF OF THE CUMBERLAND COUNTY BAR ASSOCIATION; LYLE HERR; SAMUEL COOVER and DIRK BERRY OF THE CUMBERLAND COUNTY COURTHOUSE, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03'6123 CrVIL JURY TRIAL DEMANDED I, Shawn E. Smith, Esq., state the following facts with regard to service of matters in the above case upon the Plaintiff, Mr. Cormany, are true and correct: I am an attorney in good standing in the Commonwealth of Pennsylvania, an officer of this Honorable Court, and an associate of the firm of "Phomas, 'l~homas & Hafer, LLP, in Harrisburg, Pennsylvania. I, along with Stephen E. Geduldig, Esq., am counsel for Defendant, the Administration and Staff of the Cumberland County Bar Association in the above case. On or about January 29, 2004, Defendant Cumberland County Bar Association filed Preliminary Objections and Briefs in support thereof to Plaintiffs Complaint in this case. As indicated by the Certificate of Service attached thereto, and the filing letter sent to the Prothonotary's office dated January 29, 2004, copies of the Preliminary Objections and Briefs in support thereof were sent to "Cory A. Cormany, 1883 Douglas Drive, Carlisle, Pennsylvania 17013." A true and correct copy of the letter sent to the Prothonotary's office and sent to Plaintiff, along with the Preliminary Objections and the Briefs in support thereof dated January 24, 2004, is attached hereto as Exhibit A. This address is not only the address of record for the Plaintiff in this case, and a copy of his driver's license was attached to his Complaint which verifies this address as being that of the Plaintiff. Pursuant to Local Rules, on March 11, 2004, an additional copy of the Brief in Support of Defendant Cumberland County Bar Association's Preliminary Objections were sent to both the Court Administrator, as well as to the Plaintiff in this case. A true and correct copy of the letter sent to the Court Administrator and sent to Plaintiff, along with the Preliminary Objections and the Briefs in support thereof dated March 11, 2004, is attached hereto as Exhibit B. As indicated by the letter dated March 11, 2004, not only was an additional copy of the Brief sent to Mr. Cormany, but the specific date of the argument scheduling this case, March 24, 2004, was also noted specifically in the letter after defense counsel received that argument date from the Court Administrator. Thus, counsel for Defendant Cumberland County Bar Association hereby verifies that copies of the Preliminary Objections, the Briefs in support thereof, and the date for argument of these matters were all sent to the Plaintiff in this case at his address of record. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsifications to authorities. By ~h'~awn E. Sm~E~ Sworn and subscribed before me, this ~__~__ day of ~/~C~: .2004. Notary Public 285624.1 2 Exhibit A THOMAS, THOMAS & HAFER LLP ATTORNEYS AT LAI~r 305 North Front Street, P.O. Box 999, Harrisburg, PA 17108 Phone: (717) 237-7100 Fax: (717) 237-7105 www.tthlaw.com ShawnE. Smith (71~ 237-7100 ssmith@tth~w, com January 29, 2004 Prothonotary Cumberland County Core,house One Courthouse Square Carlisle, PA 17013 Re-' .Cormany v. Sheel¥~ et al Cumberland County No. 03-6123 Dear Prothonotary: Please file the enclosed Entry of Appearance, Praecipe for Listing Case for Argument, Prelim/nary Objections and Brief in Support thereto with regard to the above-referenced matter. All counsel of record have been served with a copy of the same. Please time-stamp and return the extra copy in the envelope provided. Thank you for your cooperation regarding this matter. Should you have any questions, please do not hesitate to contact this office. Yours truly, THOMAS, THOMAS & HAFER, LLP Shawn E. Smith SES/jlk:276289.1 Enclosure cc. Cory A. Cormany (w/enclos.) William J. Devlin., Jr., Esquire (w/enclos.) The Honorable Harold F. Sheely (w/enclos.) Lehigh Valley Office: 3400 Bath Pike, Suite 302, Bethlehem, PA 18017 * Phone: (610) 868-1675 * Fax: (610) 868-1702 Exhibit B THOMAS, THOMAS & HAFER LLP ATTORNEYS AT LAW 305 North Front Street, P.O. Box 999, Harrisburg, PA 17108 Phone: (717) 237-7100 Fax: (717) 237-7105 Shawn E. Smith (717) 237-7100 ssmith@tthlaw, com March 11, 2004 Taryn N. Dixon Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Re: Corman¥ v. Sheel¥~ et al Cumberland County No. 03-6123 Dear Ms. Dixon: Enclosed please find the Brief in Support of Preliminary Objections of the Administration and Staff of the Cumberland County Bar Association which is scheduled to be argued on March 24, 2004. All parties of record have been served with a copy of the same. Please time-stamp and return the extra copy in the envelope provided. Thank you for your cooperation regarding this matter. Should you have any questions, please do not hesitate to contact this office. Yours truly, THOMAS, THOMAS & HAFER, LLP Shawn E. Smith SES/jlk:276289.2 Enclosure cc. Cory A. Cormany (w/enclos.) William J. Devlin., Jr., Esquire (w/enclos.) The Honorable Harold F. Sheely (w/enclos.) Lehigh Valley Office: 3400 Bath Pike, Suite 302, Bethlehem, PA 18017 * Phone: (610) 868-1675 * Fax: (610) 868-1702 CERTIFICATE OF SERVICE I, Becky Rusbatch, an employee of the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that a true and correct copy of the foregoing document was served by depositing the same in the United States Mail, served upon all parties of record by first class United States mail, postage prepaid, addressed as follows, on 'the date set forth below: Cory A. Cormany 1883 Douglas Drive Carlisle, PA 17013 Plaintiff, Pro Se William J. Devlin, Jr., Esquire DEVLIN & DEVINE Suite 200 100 West Elm Street Conshohocken, PA 19428 Attorneys for Defendants, Lyle Herr, Samuel Coover and Dirk Berry The Honorable J. Wesley Oler, Jr. Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 The Honorable George E. Hoffer, P.J. Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Date: 3/31/04 THOMAS, THOMAS & HAFER, LLP Becky Ru~b~tath, :[~gal Secretary 276199.2 CORY A. CORMANY, Plaintiff HAROLD SHEELY; : THE ADMiNISTRATION: AND STAFF OF THE : CUMBERLAND : COUNTY BAR : ASSOCIATION; LYLE : HERR; SAMUEL COOVER AND DIRK : BERRY OF THE : CUMBERLAND COUNTY COURTHOUSE, Defendants 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-6123 CIVIL TERM IN RE: PRELIMINARY OBJECTIONS OF DEFENDANTS HERR, COOVER AND BERRY TO PLAINTIFF'S COMPLAINT BEFORE HOFFER, P.J., and OLER, J. ORDER OF COURT AND NOW, this 19th day of May, 2004, upon consideration of the preliminary objections to Plaintiff's complaint filed on behalf of Defendants Herr, Coover and Berry, and for the reasons stated in the accompanying opinion, it is ordered and directed as follows: 1. The preliminary objections filed on January 20, 2004, are stricken as duplicative of tlhose filed on January 15, 2004; and 2. The preliminary objections filed on January 15, 2004, are sustained to the extent that they seek dismissal of Plaintiff's complaint, and Plaintiff's complaint is dismissed as to Defendants ]Herr, Coover and Berry. /tSory A. Cormany 1883 Douglas Drive Carlisle, PA 17013 Plaintiff, pro Se o8~'ephen E. Geduldig, Esq. Shawn E. Smith, Esq. Thomas, Thomas & Hafer, LLP 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 Attorneys for Defendant Administration and Staff of the Cumberland County Bar Association vWilliam J. Devlin, Jr., Esq. Devlin & Devine Suite 200 100 West Elm Street Conshohocken, PA 19428 Attorney for Defendants Herr, Coover and Berry BY THE COURT lJWesley ~ Jr., J.//', 05 - O-O CORY A. CORMANY, Plaintiff HAROLD SHEELY; THE ADMINISTRATION AND STAFF OF THE CUMBERLAND COUNTY BAR ASSOCIATION; LYLE HERR; SAMUEL COOVER AND DIRK BERRY OF THE CUMBERLAND COUNTY COURTHOUSE, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-6123 CIVIL TERM IN RE: PRELIMINARY OBJECTIONS OF DEFENDANTS HERR, COOVER AND BERRY TO PLAINTIFF'S COMPLAINT BEFORE HOFFER, P.J., and OLER, J. OPINION and ORDER OF COURT OLER, J., May 19, 2004. For disposition in this civil case in which a pro se Plaintiff has sued various parties, preliminary objections to Plaintiff's complaint have been filed on behalf of Defendants Lyle Herr, Samuel Coover and Dirk Berry.1 The preliminary objections being pursued by Defendant are in the nature of a demurrer2 and a motion to strike for failure to plead facts in a concise and summary form in conformity with Pennsylvania Rule of Civil Procedure 1019(a),3 inter alia.4 ~ Preliminary Objections of Defendants, Lyle Herr, Samuel Coover and Dirk Berry, to Plaintiff's complaint, filed January 15, 2004 (hereinalter preliminary objections of Defendants Herr, Coover and Berry). 2 Preliminary objections of Defendants Herr, Coover and Berry, pasta. 14. 3 Preliminary objections of Defendants Herr, Coover and Berry, para. 2. 4 Preliminary objections of Defendants Herr, Coover and Berry, para. 15. In the preliminary objections, the moving parties note that their names appear rarely in the complaint,s and contend further that Plaintiff's Complaint contains paragraph after paragraph of nonsensical sentences[,] some of which contain English words and some [of] which contain words that appear to be wholly made up by Plaintiff.6 The preliminary objections of Defendants Herr, Coover and Berry were argued before the above court en banc on February 4, 2004.7 For the reasons stated in this opinion, the preliminary objections will be sustained and Plaintiff's complaint against Defendants Herr, Coover and Berry 'will be dismissed. STATEMENT OF FACTS Plaintiff's complaint, which was filed on November 21, 2003, contains 52 paragraphs and 83 pages. Paragraph 1 of the complaint identifies the Plaintiff as "an adult individual residing in Carlisle, Cumberland County, Pennsylvania.''8 Paragraph 3 states that "Defendants Lyle Herr, Samuel Coover and Dirk Berry are adult individuals employed by the Cumberland County Court House, Cumberland County, Pennsylvania.''9 Typical of the other 50 paragraphs of the complaint are these: 5. In and about the year 1985 and through and about the application herein, Plaintiff Cory Cormany was subjugated criminal and civil1 allegation unconstitutional a due process; hereto the Commonwealth of Pennsylvania. 6. The criminal terms 85-0722, 86-0358, 89- 2068, 91-0505, 92-1252, 93-1078, 93-1079, 94-0973, 94-0974, 94-1222, 95-0027 and 95-0376 in the Common Pleas Court of Cumberland .County is in accordance with the solicit ramifications litigated in Preliminary objections of Defendants Herr, Coover and Berry, para. 4. Preliminary objections of Defendants Herr, Coover and Berry, para. 3. Plaintiff neither submitted a brief nor appeared for argument. Plaintiff's complaint, para. 1. Plaintiff's complaint, para. 3. 2 the civil case 1 :CV-95-0844 filed in the: United States District Court for Pennsylvania. 7. The criminal terms 94-1222, 95;-0375 and 95- 0376 in the Common Pleas Court of Cumberland County is in accordance with tl~te procedural obligations stated in the civil cases 95-:5222, 96-1730 and 96-1969 filed in the Cumberland County Common Pleas Court for Pennsylvania. 8. The criminal terms 96-1584, 97-0174, 97- 1443, 97-1444, 97-1445, 97-1446, 97-1447, 97-1448, 97-1504 and 97-1701 in the Common ]?leas Court of Cumberland County is in accordance with the solicit ramifications litigated in the civil case 1:CV-01-1803 filed in the United States District Court for Pennsylvania. 9. The criminal terms 97-1504, 01-0092 through 01-0097 in the Common Pleas Court of Cumberland County is in accordance with the procedural obligations stated in the civil cases 96- 4435, 01-1727 and 01-6467 filed in the Cumberland County Common Pleas Court for Pennsylvania. 10. On December 19th, of the year 1990, Defendant Lyle Herr complained of an argumentative conversation, allegory the Plaintiff Cory Cormany, and did later contradict such stipulated implication, as in accordance with a Ms. Tina Adams and the Common Pleas Court of Cumberland County. 12. On October 2nd, of the year 2001, Defendant Samuel Coover compiled a reactionary assault team, explicit the Plaintiff Cory Cormany, and did later excuse such stipulated implication, as in accordance with a Mr. David MaclVlain and the Common Pleas Court of Cumberland County. 13. In and about the month of January 2002, Plaintiff Cory Cormany was directed and ordered a subpoena appearance, as in accordance with the Defendant Dirk Berry, which did deface a criminal element in the Common Pleas Court of Cumberland County. 3 16. The Plaintiff Cory Cormany has acknowledged Criminal, Civil and Actual issues of malice identified and associated with unconstitutional public actions, as in accordance xvith the Post Conviction Act set forth by the United States of America. 17. The case numbers of 1:CV-95-0844 and 1:CV-01-1803 in the Middle District Court of the United States were adjudicated and dismissed, as in accordance with the rules of court set forth by the Commonwealth of Pennsylvania. 20. The Commonwealth of Pennsylvania did precede criminal allegations slanderous a confliction of interest, and noncertified an official service, for the case number 01-2091; naming the Plaintiff Cory Cormany a defendant substantial a County Detective William Diehl. 23. The Commonwealth of Pennsylvania did proceed criminal hearings conspiratorial an act of justice and certified an official position; usable the Defendants Harold Sheely and associates as in disaccordance with P.S.A. 42 R.C.P. 58, 65, 66, 101, 102, 110, 123, and 130. 24. The intentional and criminal ramifications demonetized in the case numbers 85-0722, 86-0358, 89-2068, 91-0505, 92-1252, 93-1078, 93-1079, 94- 0973, 94-0974, 94-1222, 95-0027, 95-0374, 95-0375, 95-0376, 96-1584, 97-0174, 97-1443, 97-1444, 97- 1445, 97-1446, 97-1447, 97-1448, 97-1:504, 97-1701, 01-0092, 01-0093, 01-0094, 01-0095, 01.-0096 and 01- 0097, decidable the Common Pleas ,Court of the Cumberland County, are in disaccordance with the Commonwealth and United States Constitutions. 25. The compensatory and punitive ramifications remedialized in the case numbers 95- 5222, 96-1969, 01-6467, and 03-1778, convincible the Common Pleas Court of the Cumberland County, are 4 in disaccordance with the Commonwealth and United States Constitutions. 28. The Plaintiff Cory Cormany has suffered lost wages, benefits, fees and property in the amount in excess of Two Hundred Fifty Thousand and 00 Dollars (250,000.00) as result of the Defendants' malicious and prejudicial actions. 30. The prejudicial and malicious matters and actions are serious as having happened in the Cumberland County, Pennsylvania, respectfully submissive the order of the court and exhibits A through I. 31. Preceding the situations and circumstances defined in the aforementioned statements, the Plaintiff Cory Cormany was not ever empowered a lawful servitude for the purpose of a pursuit in happiness, nor was he ever petitioned with a serviceable indictment for the purpose of an immunological warrant. 37. Preceding the situations and circumstances defined in the aforementioned statements, the Plaintiff Cory Cormany was not ever depositioned for the purpose of probable cause, nor was he ever serviced with an arbitrary reason of indifference for the purpose of an immunological affirmation. 38. The Defendant Lyle Herr did implement policy and directive within or throughout the incidents and issues in question, and does have supervisory power unconstitutional an effectiwe legislative, judiciary or executive procedure. 44. The Defendant Samuel Coover did implement policy and directive within or throughout the incidents and issues in question, and does have supervisory power unconstitutional an effective legislative, judiciary or executive procedure. 50. The Defendant Dirk Berry did implement policy and directive within or throughout the incidents and issues in question, and does have supervisory power unconstitutional an effective legislative, judiciary or executive procedure,jo The preliminary objections of Defendants Herr, Coover and Berry, as heretofore described, were filed on January 15, 2004. An identical set of preliminary objections was filed by the same Defendants on January 20, 2004. This latter set of preliminary objections will be stricken as duplicative. DISCUSSION As a general proposition, Pennsylvania courts are not required to entertain submissions which are incoherent, incomprehensible or unintelligible. See, e.g., Commonwealth v. Albert, 522 Pa. 331, 561 A.2d 736 (1989); Commonwealth ex tel. Swann v. Shovling, 423 Pa. 26, 233 A.2d 1 (1966). Thus, it has been said that "[p]reliminary objections are certainly appropriate where a pleading is... incoherent .... "Jackson v. Richards 5 & 10 Inc., 289 Pa. Super. 445, 451, 433 A.2d 888, 891 (1981). More specifically, under Pennsylvania Rule of Civil Procedure 1019(a), "[t]he material facts on which a cause of action or defense is based shall be stated in a concise and summary form." Implicit within this :rule is a requirement that the pleading be intelligible. See Allensworth v. First Galesburg Nat'l Bank & Trust Co., 18 I11. App. 2d 608, 152 N.E.2d 890 (1958). Where a portion of a pleading fails to conform to the rule, it is susceptible to a preliminary objection. See Pa. R.C.P. 1028(a)(2) (failure of pleading to conform to law or rule of court). Upon consideration of such an objection, the court may properly strike the affected pleading. See, e.g., Commonwealth, Pennsylvania Public Utility Commission v. Zanella Transit, Inc., 53 Pa. Commw. 359, 417 A.2d 860 (1980). ~o Plaintiffs complaint, at 1-13. 6 Under Pennsylvania Rule of Civil Procedure 1028(a)(2), a pleading which is legally insufficient to set forth a cause of action is also susceptible to a preliminary objection. Implicit within this rule as well is a requirement that the pleading be intelligible. See Allensworth v. First Galesburg Nat'l Bank & Trust Co., 18 Ill. App. 2d 608, 152 N.E.2d 890 (1958). Upon consideration of such an objection, the court may properly sustain a demurrer and dismiss the pleading. Id. In this regard, it is well settled that "[p]leadings will be construed against a pleader on the theory that he or she has stated his or her case as best he or she can." 2 Goodrich Amram 2d 1019:7, at 249 (2001). In the present case, a careful reading of Plaintiff's complaint indicates that Plaintiff's claims against Defendants Herr, Coover and Berry are not stated in a concise and summary form in the sense of being intelligible, nor can the complaint be understood as setting forth any legally cognizable cause of action against any of these defendants. Based upon the foregoing principles of law, the following order will therefore be entered: ORDER OF COURT AND NOW, this 19th day of May, 2004, upon consideration of the preliminary objections to Plaintiff's complaint filed on behalf of Defendants Herr, Coover and Berry, and for the reasons stated in the accompanying opinion, it is ordered and directed as follows: 1. The preliminary objections fi]led on January 20, 2004, are stricken as duplicative of those filed on January 15, 2004; and 2. The preliminary objections fi]led on January 15, 2004, are sustained to the extent that they seek dismissal of Plaintiff's complaint, and Plaintiff's complaint is dismissed as to Defendants Herr, Coover and Berry. 7 BY THE COURT, Cory A. Cormany 1883 Douglas Drive Carlisle, PA 17013 Plaintiff, pro Se Stephen E. Geduldig, Esq. Shawn E. Smith, Esq. Thomas, Thomas & Hafer, LLP 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 Attorneys for Defendant Administration and Staff of the Cumberland County Bar Association William J. Devlin, Jr., Esq. Devlin & Devine Suite 200 100 West Elm Street Conshohocken, PA 19428 Attorney for Defendants Herr, Coover and Berry s/ J. Wesley Oler, Jr. J. Wesley Oler, Jr., J. 8