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Home My WebLink About02-1167 Orphans Court~-" z .~ LISA HATHCOX, INDIVIDUALLY AND AS PARENT AND NATURAL GUARDIAN OF CHRISTOPHER HATHCOX AND ELLA JEAN NICHOLS, Plaintiffs v. ARGENBRIGHT SECURITY, INC. AND ARGENBRIGHT HOLDINGS LIMITED AND US AIRWAYS AND AMERICAN AIRLINES Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION -LAW - - o~.- tlt,1 NO. 011. Oa - 11 b'} q ORDER APPR VING SETTLEMENT AND ORDER FOR DISTRIBUTION AND NOW,~[I ~ Q~pon consideration of Petition for Leave to Settle or Compromise a Minor's Action, in the above captioned matter, it is hereby ORDERED and DECREED that petitioner is authorized to enter into a settlement with Defendants, Argenbright Security, Inc., Argenbright Holdings Limited and American Airlines on behalf of Christopher Hathcox, a minor, in the sum of Five Hundred Dollars and 00/100 ($500.00). The funds shall be held in a restricted account not to be withdrawn before the minor attains majority or upon prior leave of the court. J. ,~~,~,~ j ~ ~ ' l l rV -~ .i r t I~ r ~ ~ ~' r,,a ~ . '1 ISA HATHCOX, INDIVIDUALLY AND AS PARENT AND NATURAL GUARDIAN OF CHRISTOPHER HATHCOX AND ELLA JEAN NICHOLS, Plaintiffs v. ARGENBRIGHT SECURITY, INC. AND ARGENBRIGHT HOLDINGS LIMITED AND US AIRWAYS AND AMERICAN AIRLINES Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA NO. PETITION FOR LEAVE TO SETTLE OR COMPROMISE MINOR'S ACTION To the Honorable, the Judges of the Said Court: This Petition of Christopher Hathcox, a minor, by his Guardian, Lisa Hathcox and by his attorneys, Paul F. D'Emilio, Esquire and Stephanie E. Chertok, Esquire respectfully requests: 1. Petitioner is Christopher Hathcox, a minor, by his mother and natural guardian, Lisa Hathcox, and his attorneys, Paul F. D'Emilio, Esquire and Stephanie E. Chertok, Esquire. 2. The minor was born on June 11, 1992, and his social security number is 3. The minor resides with Lisa Hathcox at the following address: 1208 Redwood Hill Circle, Carlisle, PA 17013. 4. No guardian has been appointed for the minor. 5. The minor's mother is Lisa Hathcox who resides at the following address: 1208 Redwood Circle, Carlisle, PA 17013. 6. The minor's father is James Hathcox. Mother has legal and physical custody of 1 JAMES HATHCOX, IN THE COURT OF COMMON PLgAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA . CIVIL ACTION - LAW v. NO. 94-2971 CIVIL TERM LISA J. HATHCOX, Defendant CIVIL ACTION - CUSTODY CDURT ORDER ~ _L~{ day of ~'~`~~ , . 1996, upon AND NOW, this _~ --- consideration of the attached Custody on ciliation Report, it is ordered and directed as follows: - I. The Mother, Lisa J. Hathcox, shall have 1ega1 and physical custody of Christopher Joshua Hathcox, born June I1, 1992. 2. The Father, James Hathcox, shall enjoy !temporary physical custody of the minor child at such times as agreed upon by the parties. Additionally, Father shall have reasonable telephone access to the minor child. 3. In the event• the Father is dissatisfied with the time of physical custody provided to him by the Mother, or in any other way dissatisfied with this order, the Father may oeri.tior_ the Covrt to have the case again scheduled for a c. _~~" G'J~'I18r°rC° ;~T;Li. %aie 6.uS~v~~ vit .~~_.r,. ~ . 4. Mother's counsel is directed to serve a copy of-this order and t 7e 3ttaC hed CuSty^dy Ccnc:.liation .t2eri.7rt an the Father by regular mail and certified mail. ~!! ~ " ~. ~~'° ~~~Ny~~~='~~~s~" i °~~. ~' #> ~::' ~:,~~~~'}~ k..` BY T.~IE COURT, ~~ € ~~~~~y ~i~~]~rJrii~lB ~ ~ ~~.~uf E~ Se0~2~ w~~ ~i j 9~:19:~i rh;~ !~ day ~~~~; ~~ ~~ ~~~ / -^ -Z~ ~' _ ` ~ Qrh~~rt~~t~ta~~ cc: Carol J. Lindsay, Esquire •~ r~ ~`~~ti~ 5~'~3 ~ ~'~ - -u d ~ ~, ~X~ ~~J I `r ~~ A,~ DEC 16 2002 3:37PM HP LRSERJET 3200 p.l DEC 16.2002 3:37PM HP LASERJET 3200 p•2 Paul F. DrEmilla, Esquire Attorney ID41 16654 Stephanie E, Chertok, Esquire Attorney ID~i 52651 905 W. Sproul Road, Suite I07 Springfield, PA 19064 JI~HY FF.~Pq~ ATTORNEY FOR Plaintiff Plain~i~ls) Lisa Ffathcox, Individually and as ?argot and Natural Guardian of Christopher Hathcox, a minor and Ella Jean Nichols .- ~~,-~- "" vs' ~~~~~ ~~~~~ Defendvrtts(s) Argenbr~ht Secnrit,;, Inc. and Argenbright Holding Limited and US Airways and Amef i.cazt Airlines ;~ ~"' t;. You have peen sued in coup. !f you wish to defend against the claims set faith in the following pages. you must cake action within twenty (20} days after this complaint and notice are served. by entering a written appta rante pers4ttally nr hyattQ-rtsy;and filing in +uriring with the couR your defenses or objections to the elaitns set forth against you. You dR warned tfiat if you fail to do so the case may proceed without you and a judgment maybe entered against you by the ct•.urt ,rithuut furthe- notice for any rneney etatmett in the complaint or for any other claim or relief requested by the ptaintifC. You may lase money or property or other rights important to you. YUU SHOULD TAKE T1iiS p,4P1rR 70 YOUR LAWYER AT ONCE. iF YOU DO NOT NAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OF4'1CE SET FORTH BtiLt7w TO FlN D bUT WHER F You CAN GET l.£GnL HELP. Lnwyar Refcrcnre 5rnrit-t One Reading Center Philadelphia, f ~~~~.~ I~~nia 19107 Teicpha„~ X2151 238=6333 TTY 1215) 451W6197 L-_xN16iT ,,~., .A`dISG'' Lc hen demandndo a acted en la core. Si acted yuiere derenaene ae csta~ demandas expuestas en lac paginassiguientes. ttstcd tiene vein+c i20) dial do plero al partir de la feeha de Ia dertanda y la notificacion. Hace falta ascntar unacVmparrnn:rrcnta urn prrtnna Deno unabs?gadoy rntrsttura ;3 cortc en forrtta escrita susdeftnsas o sus objeeianes a lac demandasen contra de su persona. Sea avisado yue si acted no se defiende, la eorte Comoro medidas y puede continuer la dcmanda en Contra says sin previo aviso o notification. Adcrnas. la corn ISUttIt deeidir a fnvor del demandante y reyuurc yue u,+rii cumpla cart togas lus prnvisinnes de ciao dcmandn, llatsti rnccle ircrd?:r dinero o sus propiedades o otros dercchos importantes pars acted. LLEVE ESTA DEMANDA A UN ABOOADOINMt'f31 A'T'AM £N~TE. S{ VOTIENE ABOGAUOOSI NOTIENE EL DINF.ROSUFICIENTE UE PACAR TAL SERVICIO, VA,YA E1V FERRONA O 1.1.AME Pf.1R TLt.t.PONO A L.4 OFICIN.+t CUYA DIRECCtON SE CNCtIF1TRA ESCRIT.A .aBAJO PARA AYERIGUAR DONDE tiF I'L'EC)E f_'f1ti~Ff'~1!IR ASISTENCIA i,1:CAL. M.CORNAOUA PA4.PROTHY AUG 2 8 2001 A~F~ COfIRT OF COhf.4f0,'~' PLEAS Philadelphia D1~1S10n~ TER~4f. ~, y f`1 t`7'r GO~~ ,ti'o. ,{~ cry 0.1~~~~1? Jury Trial Demanded 5ervicio de Refercncia Legal (J~p Rrading Centro FiLtdelfia. PA 19107 Telelona. (715) ~38-6333 TTY (215) ~+ 51-619`7 DEC 16 2002 3:37PM HP Lf~SERJET 3200 PAUL F. D'EMILIO, ESQUIRE PA Supreme Court ID: 16b54 905 W. Sproul Rd., Suite 107 Springfield, PA 19064 610-338-0338 STEPHANIFs E. CHERTOK, ESQUIRE PA Supreme Court ID: 52651 6~. West Louther Street Carlisle, PA 17013 717-249-1177 L23A HATHCOX, INDIVIDUALLY AND - AS PARENT AND NATURAL C~tTARDIAN OF CHRISTOPHER HATHCO% AND LI~LA JEAN NICHOLS, 1208 Redwood Hills Circle Carlisle, PA 17013 Plaintiffs v. ARGENBRIGHT SECURITY, INC. Scott Plaza 2, Suite 310 Essington, PA 19113 AND p,RGBNBRICHT HQLDINCS LIMITED Fulton County Atlanta, GA AND ' US AIRWAYS 2345 Crystal Drive Ar~.~.ngtcn, VA 2227 f AND -- AMERICAN AIRLINES P.O. Box 619612MD2400 Da=~.as; ~'t. Woxth, TX 75261-9612 a. ~rdan c s COb~LAINT IN THE COQRT OF COD+II+SON PLEAS OF PHILADELPHIA Caj~y, pENTQSYLYANIA CIVIL ACTION - LAMP TERM, 2001 NO. Plaintiffs, by their attorneys, Paul F. D`Emilio, F~r~t~ire, and Stephanie E. Chertok, Esquire, bring this claim upon a cause whereot the following is a statement: Parties 1. Plaintiff, Lisa Hathcox, Individually and as parent and p.:3 __ _ DEC 16 2002 3:38PM HP LASERJET 3200 i natural guardian of Christopher Hathcox is an individual residing i at 1205 Redwood Hills Circle, Carlisle, PA 17013. I .I 2. Plaintiff, Ella Jean Nichols is an individual residing at 1208 Redwood Hills Circle, Carlisle, PA 27013. ~ Lisa Hathcox and Ella Jean Nichols are sometimes referred to ~' 'as the "adult Plaintiffs". ' 3. Defendant, Argenbright Security, Inc. is a corporation ' organized ar_d existing under the laws of Georgia and authorized to do business within the Commonwealth of Pennsylvania with its principal place of business at Scott Plaza 2, Suite 310, Essington, PA 19113. 4. Defendant, Argenbright Holdings Limited is a corporation that owns all of the outstanding capital stock of Argenbright Security, Irc . , and has its Principal place of business in~ Fulton County, Atlanta Georgia. 5. Argenbright Holdings Limited provides pre-departure screening at various airports though-cut the United States including the Philadelphia Airport through its wholly-owned subsidiary tirger~r=ynt Securi~~y, inc. i 6. At the Philadelphia Airport, various airlines, including US Airways and American Airlines, have contracted with Argenbright Holdings Limited, and/or its subsidiary Argenbright Security, Inc. j (collectively hereafter "Argenbright") to conduct pre-departure screening and to provide other security services. 7. At all times material hereto, Argenbright was providing p.4 DEC 16 2002 3:39PM HP LRSERJET 3200 p•5 security services for and as the agent of American Airlines, including during the events set forth below. 8. At all times hereinafter mentioned the security checkpoint was being manned at the time by employees of Argenbright Security. 9. Upcn information and belief, Argenbright Security had been hired by Americar. Airlines to provide security for its terminal and I, gate areas at the Philadelprlia Airport. ~ 10. Defendant, American Airlines is a corporation organized and i existina under the laws of Texas and authorized to do business :in the Commonwealth of Pennsylvania with offices at P.Q. Box 619612 MD 2400 Dallas/Ft. Wort:'i, TX 75261-9612. 11. Defendant US Airways is a corporation organized and existing __ under the laws of Virginia and au~horized to do business in the Commonwealth of Pennsylvania with offices at 2345 Crystal Drive, Arlington, VA 22227. 12. All times hereinafter the Defendant, Argenbright Security, Inc. operated and maintained. control security at the US Airways and American Airlines Security checkpoint, terminal "A" of the Ph~iadelon-~a 1nLerna~~o._a. ?:~rpcr:.. 13. At all times hereinafter mentioned the Defendants acted through their workman, agents, serrants and employees, then and there engaged in the business of the Defendants and acting within the scope of their employment. Factual Alleaatioas II 14. At all times hereinafter mentioned Defendants were in DEC 16 2002 3:41PM HP LRSERJET 3200 P.v controlled and operated the maintained, Y ort. possession of, anal at the Philadelphia International AZ_p term- left the International 1999 ., Plaintiffs October 10~ at 15. On or about terminal ate check point at the international international g scanner ernational Airport and entered the security Philadelphia Int check point. Iwo (2? backpacks and a 16. Plaintiff, Lisa Hathcox rem°ved them together with a video camera on the and Placed h the metal ~~ fan.lypack" be checked. Plaintiffs' then went trroug halt to Ptal detectors they came out of she m.. detectcrs. After Plaintiffs' ,roved toward their out on the backpacks ar~d fanny?ack and teen _ Nic.~ols 'was e went to retrieve a wheel chair since Mrs. gate. Th y US Air promised t:'~at a wheelchair handicapped and needed a cane. there was none. 'e at the gate upon their arrival but ~vould fl walkway, plaintiffs were Thereafter, about half way down the ~P k oint, entering r ~ a ~ the c__..c: P the recurytY ga~~ accused of skiPPing'~ ~- security agent that 'nto a sterile area. Plaintiffs advised the s had been i check and their bag trey had gone through the security ,_ vnt~y_ay e security agent ,,gas satisf;ed and Plaircl=-s checked. Th Dint, plaintiffs were lane. At that p to their p airways staff. a shuttle bus the police and pulled off the shuttle bus by Subsequently, Plaintiffs Plaintiffs and their bags were searched. ed back to the shuttle bus to go an the plane. were then releas lane boarded, Plaintiffs were again forced to dep 17, Once they had ~ of the FAA in '+ by the FAA. plaintiffs answered al- for "question g -DEC 16 2002 3:43PM HP LASER.7ET 3000 p. i ~- ~ - - - .. -~ questions and then were sent to the Airport Police Department. 'I Plaintiff's were promised that there their grandmother who was :`i waiting in Harrisburg would be notifed of the delay but she was not. Eventually, Plaintiffs were released and sent home on a _I mini-bus or van from Philadelphia to Harrisburg Airport and which j was their ultimate destination and had to take a taxi to Carlisle since their ride left. 18. Adult Plaintiffs were charged with violation of Federal Aviation Regu'ation 107.2a which states that it is an offense for any person to attempt to enter a sterile area without submitting to the screening of his or her person or proper~y. The sterile area is that part of an airport between the security check po~:nt and thP- _ passenger boarding gate door. Plaintiff could be found liable and subject to a civil penalty. ].9. The FAA ultimately found that the adult Plaintiffs were not guilty of any violation. No explanation was given for the repeated searches, the detention at ,a security office far more than two {2} ', hours and the unfounded charges. The FAA has refused to produce t:_e' _ ._n"TPSf `G~~'r2 ~~.1°v ~:=G' ?1C'~V C.'-u~ms ~~' - .., ,.; _:~e _es were de~t~c~Y~u. 20. Plaintiffs continually requested that the video surveillance camera be reviewed which would confirm their position but Defendar_ts failed, refused and neglected to do so. '~, 2Z. On April 17, 2000, a Criminal Information was filed by the United States Attorney against Argenbright Security, Inc., ~~ Argenbright Holding, Limited and a series of individuals (the "Criminal Fraud Action"). 22. The Information in the Criminal Fraud Action charges, among _. _ _ ___ DEC 16 2002 3:46PM HP LRSERJET 3200 - _._ P.8 other things, that Argenbright intentionally failed to properly train and failed to, conduct proper background checks of the employees conducting security at the?Phil;:adelphia Airport. 23. The Information in the Criminal Fraud Action further charges that Argenbright and others conspired to and did falsify records and test results and made false statements concerning the security at the Philadelphia Airport to both the FAA and United States A~torney`s Office. 24. The actions and omissions of the Defendants were so outrageous, wilful, wan~on ar~d in reckless disregard of she health and weal being of the Plaintiffs as to entitle the Plaintiffs t.o punitive damages. As a direct and proximate result of Defendants negligence and willful and wanton ccnduct Plaintiff have suffered the injuries set forth above. "~ 25. The actions, omissions and conduct of the Defendants and their ager_ts, t~orkmen, servants and employees were grossly negligent, wanton, reckless, outrageous and in total disregard for the rights of the Plaintiffs so that as a result Plaintiff is entitled to reascnabie attorney .fees. 26. As a direct and proximate result of the misconduct herein described, Plaintiffs experience and continue to experience physical and mer_tal pain and anguish, humiliation, embarrassment, sickness, disability, emotional distress, physical pain and suffering, loss and/or reduction of enjoyment of life, shock to their nerves and nervous systems which will continue in the future, DEC 16 2002 3:49PM HP LRSERJET 3200 p.9 incurred expenses including legal fees and economical loss in connection with their defense of the charges that were lodged against them, wrongful detention,loss, of reputation in the community and other damages, losses and injuries. WHEREFORE, Plaintiffs demand judgment against all of the Defendants in an amount in excess of the jurisdictional amount, tcgether with costs, delay damages, interest, and any other relief this Court deems appropriate. COUNT Z Plaintiffs v. All Defendant _ Assault and Battery 27. Plaintiffs incorporate by reference all of the allegations contained in paragraphs 1 through 26, inclusive, as full as thcugh t:~e same were herein set forth at length. 28. By reason of the aforesaid Defendants acts uer~e done with the intent to put the Plaintiffs in reasonable and immediate apprehension of harmful and offer.~sive contact and did in fact cause: such apprehensior_ to Plaintiffs. 29. Defendants did touch Plaintiffs without their express consent. WHEREFORE, Plaintiffs demar.;;. ;udament against the Defendants, Argenbright Security, Inc., in an amount in excess of the jurisdictional amount, together with costs, delay damages, interest, and any-other relief this Court deems appropriate. COUNT I2 Plaintiffs v. All Defendants False Imprisonment/False Arrest 3C. Plaintiffs incorporate by reference all of the allegations DEC 16 2002 3:52PM HP LRSERJET 3200 contained in paragraphs 1 through 29, inclusive, as fully as though the same were herein set forth at length. 31. Defendants' unlawful seizure, false: arrest, confinement and imprisonment of Plaintiffs was against their will and said conduct was without probable cause and without the privilege to do so. WHEREFORE, Plaintiffs demand judgment against the Defendants ir.: an amcunt in excess of the jurisdictional amount, together with costs, delay damages, interest, and any other relief this Cour~ deems appropriate. COUNT I I I Plaintiffs v. All Defendants Intentional Misconduct and Conspiracy p.10 32. Plaintiffs incorporate by reference alp of the allegations- -- curtained in paragraphs I through 31, inclusive, as full as though t:`~e same were herein set forth at length. 33. Argenbright had a duty to properly train, supervise and control their employees. 34. Argenbright, its management and employees, among other things: a. failed to conduct employment checks on persons employed ~t ~: ` ?'_:~ladel hia miry cry., b. falsely certified to the FAP. that the employment checks had been done; c. failed to properly conduct testing of screeners; d. failed to properly train their employees; e. failed to properly test their employees; f. failed to properly supervise their employees; and DEC 16 2002 3:54PM HP LRSERJET 3200 p.ll . - ~ .. - g. manned checkpoints with untrained employees. 35. Argenbright did not properly train, supervise, control or adequately screen the background of its employees. 36. Argenbright's failure to properly train, supervise, control or adequately screen the background of its employees was intent~.onal, ~Nillful and outrageous and done with knowledge of the danger it posed to individuals using the Philadelphia Airport. 37. Argenbright's failure tc properly train and supervise was - intentional, willful and outrageous. 38. The failure of Argenbright to properly supervise, train and control employees at the Phi=adelphia Airport, was a part of and in furtherance of a conspiracy involving defendants Argenbriaht- '- Security, Inc., Argenbright Holding Limited and others. 39. The nature and extent of the conspiracy referred to above is set for~h in the Criminal Information filed in the Criminal Fraud Acton, which is incorporated hereir_ by reference as if set forth fully and at length. ~~ 40. The false report would not have occurred had Argentbright's e*n;lo~,Tees :oeen crc.erly trained and/cr superrised. 41. The false report would not have occurred but for the intentional, willful, and outrageous conduct of Argenbright. 42. The failure to properly train, supervise and control their employees was outrageous, intentional, willful, and done wits knowledge of the danger it posed to individuals using the Philadelphia International Airport like the Hathcox family. DEC 16 202 3:57P11 HP LFiSERJET 32UU 43. As the direct and proximate result of Argenbright's outrageous, intentional and willful misconduct as set forth above, Plaintiffs' were falsely arrested] and. sustained severe and permanent injury and other damages. WHEREFORE, Plaintiffs demand judgment against the Defendants in an amount in excess of the jurisdictional amount, together with costs, delay damages, interest, and any other relief phis Court deems appropriate. _ COIINT IV Plaiatiffs v. Argenbright Security, Inc. and ', Argenbright Holdings Limited Negligence 44. Plaintiffs incorporate by reference all of the allegations contained in paragraphs 1 through 43, inclusive, as full as though_ ,.~ the same were herein set forth at length. 45. Argenbright had a duty to exercise rea~oriable care in selecting, supervisir_~g, training and controlling its employees. 46. Argenbright failed to exercise ~easorable care il, selecting, supervising, training, and controlling its employees. 47. ?~rgenbright's failure to properly select, supertrise, train and,~cr control its employees ~Nas neal~.gent, reckless and grossly negligent. ~I a8. Argenbright breached its duties of selecting, supervising, ~! training and controlling its employees and other employees were not properly selected, supervised, trained and/or controlled. 49. The failures of Argenbright to properly select supervise, train and control its employees was the direct and proximate cause ~,I p.lz ~~ DEC 16 2002 4:OOPM HP LRSERJET 3200 p.13 of the false imprisonment of the Plaintiffs and of the damages Plaintiffs have sustained. WHEREFORE, Plaintiffs demand judgment against the Defendants in an amount in excess of the jurisdictional amount, together with costs, delay damages, interest, and any other relief this Court deems appropriate. COUNT IV Flaintif£s v. American Airlines aad US Airways Negligence _ 50. Plaintiffs incorporate by reference all of the allegations contained in paragraphs 1 through 49, inclusive, as full as though the same were herein set forth at length. 51. American Airlines and US Airways have the primary duty for t e - security of its gate and operations area. 52. American and US Airways were negligent in that they failed to have any supervisory persons present at the security checkpoint at terminal "A". 53. American and USAir were•~urther negligent in that they failed to monitor the actions and activities of Argenbright, its agent. 54. riad American a:~d USAirr properly m~or~itcred or s~.~perfised the actions and activities of Argenbright they would have discovered Argenbright's ongoing criminal, fraudulent, reckless and negligent ccnduct well before it was discovered by the FAA or the United States Attorney. '~ 55. As the direct and proximate result of American's and L'SAir's ~~ failure to supervise and monitor the activities of Argenbright, :i I Argenbri,ght was able to engage in a course of conduct which was criminalJ, fraudulent, reckless and negligent, which conduct j ~ present d an extreme danger to the kra~relling public and to the ~ persons using the Philadelphia Airport. 56. Ask~the direct and proximate result of the negligence of I' America~l and USAir as set forth above, the Plaintiffs were falsely ~i ~, ~~ arrested and sustained severe and permanent injury and their family sustained other damages. I 6' WH~R}3FORE, Plaintiffs demand judgment against the 7efendants in an amount in excess of the jurisdictional amount, together with costs, delay damages, interest, and any other relief this Court deems appropriate. DATE: ° ~ . PA ~ F . D EMTEIO~, ESQ . , STEPHANIE E. CHERTOK, ESQ., ATTGRNEY FOR PLAINTIFFS UtC: 16 ~00~ 4: ^4YM RP CHStKJt I ~~ITO V E R I_F I C A-Z~ S,a N ~ : r~ Lisa Hathcox, Individually and as parent and natural guardian of Christopher Hathcox and Ella Jean Nichols, Plaintiffs in the above captioned matter verifies that the facts contained in the foregoing Complaint are true and correct . I undet-el.aiYd that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATE : ~1 ~~ f a~~ t li 5~, N [~.t~_ Lisa Hathcox, Individually and as parent and natural guardian of Christopher Hathcox DATE : ~f d~ 1 ~~~ 1 ,,,V Lzi Ella J n Niehcls