HomeMy WebLinkAbout13-0380DOUGLAS WOTRING,
Plaintiff
V
MARGARET STUSKI
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DOCKET NO.: 13-380
CIVIL ACTION - LAW
NOTICE OF HEARING FOR SEIZURE OF PROPERTY
To: MARGARET STUSKI, Esq.:
You are hereby notified that:
(1) Plaintiff has commenced an action of replevin and has filed a motion for seizure
of the property described in the Complaint. A copy of the Complaint and Motion are
attached to this notice;
(2) There will be a hearing on this Motion at - : 30 o'clock P M on the
floor, Cumberland
134"day of Moiff'A , 29k0; Courtroom # on the
County Courthouse, Carlisle, Pennsylvania.
(3) You may appear in person or by a lawyer at the time and place set forth or file
written objections setting forth your reasons why the property should not be seized;
(4) Your failure to appear at the hearing may result in the seizure of the property
claimed by the plaintiff before a final decision in this case.
i
Date: O
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DOUGLAS WOTRING, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2013-0380 CIVIL TERM
MARGARET STUSKI,
Defendant CIVIL ACTION - LAW
ORDER OF COURT
AND NOW, this 26th day of April, 2013 , following a hearing
on Plaintiff ' s Writ of Seizure, pursuant to Pa.R. C. P. 1075 . 1, we
find that the Plaintiff has failed to demonstrate the probable
validity of his claim, and, therefore, no Writ shall issue and the
Motion is DENIED.
By the Court,
Albert H. Masland, J.
Ancent M. Monfredo, Esquire
For the Plainitff
Mrgaret M. Stuski, Esquire
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DOUGLAS WOTRING, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA
V. : DOCKET NO.: 13-380
MARGARET STUSKI CIVIL ACTION—LAW
Defendant
PLAINTIFF'S ANSWER TO DEFENDANT'S PRELIMINARY OBJECTIONS
AND NOW, comes Plaintiff,Douglas Wotring,by and through his counsel,
Vincent M. Monfredo,Esq., and submits the following answers:
1. Admitted. =
2. Admitted. ,--
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3. Denied. Strict proof of the same is requested at trial. Plaintiff denies eN-&
threatening to kill himself. Plaintiff states that he initially moved in,because hd
needed a place to live and because Defendant needed assistance caring for her
dogs (not Oreo and Casey).
4. Admitted in part. Denied in part. It is admitted that he lived there open ended. It
is denied that he lived there on and off. Plaintiff lived there full time from 2001
until March 2012.
5. Denied. By way of further answer, after reasonable investigation the Plaintiff is
without knowledge or information sufficient to form a belief as to the truth of this
paragraph. By way of further answer,Plaintiff denies and requests strict proof of
the same at trial.
6. Denied. Strict proof of the same is demanded at trial. By way of further answer,
if Defendant is referring to the dog known as "Oreo"then Plaintiff claims that he
is the one who found Oreo on Petfinder while looking for a dog for himself.
7. Admitted.
8. Admitted.
9. Denied. Strict proof of the same is demanded at trial. By way of further answer,
Plaintiff and Defendant had a conversation about Plaintiff keeping the dog as a
gift even after Defendant paid for Oreo.
10. Denied. Strict proof of the same is demanded at trial. By way of further answer,
Plaintiff found the dog"Casey" and showed the Defendant the information
regarding him.
11. Admitted.
12. Denied. Strict proof of the same is demanded at trial. By way of further answer,
after reasonable investigation the Plaintiff is without knowledge or information
sufficient to form a belief as to the truth of this paragraph.
13. Admitted.
14. Admitted. By way of further answer, Plaintiff was concerned with Defendant's
ability to raise another dog and did not believe she should commit to one. To be
more specific,Plaintiff was worried because at this point he had become the one
caring for Oreo full time and she was only home two days a week while working
in or near Philadelphia.
15. Admitted.
16. Denied. Strict proof of the same is demanded at trial. By way of further answer,
the original contracts have to be produced and Plaintiff is therefore without the
knowledge to admit or deny this paragraph. By way of further answer,this
paragraph calls for a conclusion of law and is therefore denied.
17. Denied. Calls for a conclusion of law is therefore denied. By way of further
answer, strict proof of the same is demanded at trial.
18. Denied. Defendant's only involvement with OES rescue from 2001 to 2012 was
when she helped two dogs be transported to a foster home.
19. Denied. Plaintiff contends that the dogs were given to him by Defendant as gifts.
20. Admitted. By way of further answer,Plaintiff moved out after purchasing his
own home after the Defendant almost lost her home due to court action.
21. Denied. Plaintiff maintained ownership the entire time of the relationship and
showed this by caring for the dogs, purchasing their expenses, and paying for the
visits to the groomer and doctor. By way of further answer, strict proof of the
same is demanded at trial.
22. Denied. Calls for a conclusion of law. By way of further answer strict proof of
the same is demanded at trial.
23. Denied. Strict proof of the same is demanded at trial. By way of further answer,
Plaintiff never attempted to "ruin her life"but merely has only acted to get his
dogs back.
24. Denied. Calls for a conclusion of law. Strict proof of the same is demanded at
trial. By way of further answer, when Plaintiff moved out,the dogs resided with
him for a time and then a 50150 agreement was reached. At no point was Plaintiff
stalking or harassing Defendant.
25. Denied. Plaintiff admits to using such a website but not to harass or threaten
Defendant. Plaintiff admits to using the website on another person.
26. Denied. After reasonable investigation the Plaintiff is without knowledge or
information sufficient to form a belief as to the truth of this paragraph. By way of
further answer,Defendant has no reason to fear Plaintiff and her"fear" is merely
a way to disparage Plaintiff s character, a lie, or possible a figment of her
imagination or a misreading of the situation. Plaintiff and Defendant originally
had a 50/50 agreement where the two parties would regularly have to meet and
discuss the dogs.
27. Denied. Plaintiff is willing to work out a visitation or custody agreement with the
dogs and poses no threat to Defendant. Plaintiff already did this with Defendant
and she did not keep the deal. By way of further answer, strict proof of the same
is demanded at trial.
28. Denied in part. Admitted in part. Plaintiff admits to making valid complaints that
he believes are founded and denies to making numerous unfounded complaints.
By way of further answer, strict proof of the same is demanded at trial.
29. Admitted in part. Denied in part. Plaintiff admits to contacting people regarding
this case for support, witness testimony and evidence. Plaintiff denies that he
keeps telling them he will ruin her life. Strict proof of the same is demanded at
trial.
30. Denied in part. Strict proof of the same is demanded at trial. By way of further
answer this paragraph calls for a conclusion of law. Plaintiff admits he did
contact the Human Society but not that it was for harassing purposes.
31. Denied. Strict proof of the same is demanded at trial. Plaintiff admits he pursued
the complaint but not that it was unfounded.
32. Denied. Strict proof of the same is demanded at trial. Plaintiff contends he was
not asked to move his items before he moved out. Plaintiff still remained in
possession of the keys and was allowed in the house and had further access to his
items.
33. Denied. Strict proof of the same is demanded at trial. Plaintiff kept his items at
the Defendant's property with her permission upon moving out. He continued to
come over to the Defendant's house to pick up the dogs per their 50/50 agreement
and he still had keys and a garage door opener.
34. Admitted.
34. Denied. Calls for a conclusion of law. By way of further answer, Plaintiff denies
abandoning his property and was not allowed on the property following July 14,
and prior to July 14 the Defendant allowed Plaintiff to keep his property there.
35. Admitted.
36. Denied. Calls for a conclusion of law.
37. Denied. Plaintiff did attempt to get his items back from Defendant. Strict proof
of the same is demanded at trial.
38. Admitted.
39. Denied. Plaintiff was fired after Defendant caused problems between her Mother
and her Stepfather. Stepfather stated that Plaintiff could continue to work as there
were several ongoing projects. Defendants Stepfather then offered continued
employment for strictly property maintenance going forward. Plaintiff Resigned
following Defendant becoming involved in Building maintenance side of the
business,to avoid any potential conflicts.
40. Denied. Strict proof of the same is demanded at trial. Plaintiff never took
advantage of Defendant's stepfather and believes Defendant is again using lies to
disparage his character.
41. Denied. This paragraph is too vague to respond to without a date or time period.
By way of further answer strict proof of the same is demanded at trial. By way of
further answer,the paragraph calls for a conclusion of law.
42. Denied. This paragraph is too vague to respond to without a date or time period.
By way of further answer strict proof of the same is demanded at trial.
43. Admitted.
44. Admitted. By way of further answer,Plaintiff had access to Defendant's PSECU
account to pay for household items and personal bills while the Defendant was
working in Philadelphia. This happened after shut off notices and nonpayment
notices were being sent for several months.
45. Admitted. By way of further answer,Plaintiff would reimburse himself for large
bills that he loaned to the Defendant to pay for such things as heating oil, garage
door replacement,boiler replacement, water heater replacement, window
replacement, etc...
46. Denied. Undersigned counsel has attempted numerous conversations with
Defendant which have resulted in unprofessional conduct toward him. Defendant
refuses to listen to anything anyone has to say and does not care to hear
undersigned counsel's position. Defendant seems unable to grasp that Plaintiff
claims these dogs were gifted to him.
47. Admitted.
48. Admitted.
49, Denied. Strict proof of the same is demanded at trial. By way of further answer,
Plaintiff denies any harassing conduct. By way of further answer, the paragraph
calls for a conclusion of law.
50. Admitted.
51. Admitted. Plaintiff learned of this after the fact.
52. Denied. Calls for a conclusion of law. Strict proof of the same is demanded at
trial.
53. Admitted.
PRELIMINARY OBJECTION—LACK OF CAPACITY.TO SUE
54. No response required.
55. Admitted.
56. Denied. By way of further answer, after reasonable investigation the Plaintiff is
without knowledge or information sufficient to form a belief. By way of further
answer,Plaintiff denies and requests strict proof of the same at trial. By way of
further answer, calls for a conclusion of law and is therefore denied.
57. Denied. By way of further answer, after reasonable investigation the Plaintiff is
without knowledge or information sufficient to form a belief. By way of further
answer, Plaintiff denies and requests strict proof of the same at trial. By way of
further answer, calls for a conclusion of law and is therefore denied.
PRELIMINARY OBJECTION—LEGAL INSUFFICIENCY OF PLEADING
58. No response required.
59. Admitted.
' 1
60. Denied. Conclusion.of law required.
61. Denied. Conclusion of law required.
62. Denied. Conclusion of law required.
63. Denied. Conclusion of law required.
64. Denied. Conclusion of law required.
65..Denied. Conclusion of law required.
66. Denied. Conclusion of law required.
67. Denied in part. Admitted in part. It is admitted that Defendant is listed on the
licenses. It is denied that she is the clear owner of the dog based on Plaintiff's
raising and care of the dogs. By way of further answer, strict proof of the same is
demanded at trial.
68. Denied. Conclusion of law.
WHEREFORE,Plaintiff respectfully requests that this Honorable Court overrule
Defendant's Preliminary Objections.
Respectfully Submitted,
Date:
Vincent M. Monfredo,Esquire
5000 Ritter Rd.
Suite 202
Mechanicsburg, PA 17055
717.585.2064
Supreme Court ID#206671
Attorney for Plaintiff
DOUGLAS WOTRING, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA
V. DOCKET NO.: 13-3 80
MARGARET STUSKI CIVIL ACTION—LAW
Defendant
CERTIFICATE OF SERVICE
I, Vincent M. Monfredo,Esquire, do hereby certify that I served a copy of the
Answers to Preliminary Objections upon the following by depositing same in the United
States mail, postage prepaid, , at Carlisle,Pennsylvania, addressed as follows:
Margaret M. Stuski, Esq.
908 W. Walnut St.
Wormleysburg,PA 17043
Respectfully Submitted,
Date:
Vincent M. Monfredo, Esquire
5000 Ritter Rd.
Suite 202
Mechanicsburg,PA 17055
717.585.2064
Supreme Court ID#206671
Attorney for Plaintiff
DOUGLAS WOTRING, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. DOCKET NO.: 13-380
MARGARET STUSKI CIVIL ACTION—LAW
Defendant
PLAINTIFF'S MOTION TO COMPEL DISCOVERY 'c-) �
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AND ;��
TO SET A PRETRIAL SCHEDULE
AND
MOTION TO REQUEST VISITATION
AND NOW, comes Plaintiff,Douglas Wotring,by and through his counsel,
Vincent M. Monfredo,Esq., and submits the following answers:
HISTORY
1. This case has been handled previously by the Honorable Judge Albert H.
Masland.
2. Plaintiff initiated this action in replevin on or about January 22, 2013 by filing a
Complaint against Defendant.
3. Plaintiff filed an Amended Complaint on or about February 12, 2013.
4. Plaintiff then filed a Motion for Writ of Seizure on or about February 14, 2013.
5. The Honorable Albert H. Masland entered an order on March 14, 2013 setting a
schedule to follow for the upcoming hearing on the writ of seizure.
6. A hearing was then held before the Honorable Albert H. Masland on April 26,
2013 and Plaintiff's motion for a writ of seizure was denied.
7. On or about June 5, 2013 the Plaintiff by way of undersigned counsel served via
mail upon the Defendant written interrogatories and production of document
requests. (Attached as Exhibit A.)
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8. To this date,the Defendant has yet to respond to the discovery requests.
MOTION TO COMPEL DISCOVERY AND SET SCHEDULE
9. Previous paragraphs are incorporated herein as if full set forth.
10. "...a party may obtain discovery regarding any matter, not privileged, which is
relevant to the subject matter involved in the pending action, whether it relates to
the claim or defense of the party seeking discovery or to the claim or defense of
any other party, including the existence, description, nature, content, custody,
condition and location of any books, documents, or other tangible things and the
identity and locations of persons having knowledge of any discoverable material."
Pa.R.Civ.P. 4003.1(a).
11. "...any party may serve upon any other party written interrogatories to be
answered by the party served..." Pa.R.Civ.P. 4005(a).
12. "The answering party shall serve a copy of the answers, and objections if any,
within thirty days after the service of the interrogatories." Pa.R.Civ.P.
4006(a)(2).
13. "Unless the court upon motion, for the convenience of parties and witnesses and
in the interests of justice, orders otherwise,methods of discovery may be used in
any sequence and the fact that a party is conducting discovery, whether by
deposition or otherwise, shall not operate to delay any other party's discovery."
Pa.R.Civ.P. 4007.3.
14. Undersigned counsel has e-mailed the Defendant twice to request the discovery
and to request deposition dates. (Attached as Exhibit B).
15. Defendant has not responded to the discovery requests and Defendant has stated
she has no available dates for her deposition to be taken in either August or
September.
16. Defendant continues to make no effort to participate in discovery and undersigned
counsel believes the Defendant will make no effort unless there is court
intervention.
17. Plaintiff believes that this Court should set a schedule and timetable for this case
up and through trial.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court
grant his motion to compel discovery and that this Honorable Court set a
timetable for the completion of the case through trial.
MOTION TO ORDER VISITATION
18. Previous paragraphs are incorporated herein by reference as if full set forth.
19. This case ultimately involves the issue of the ownership of two dogs, Oreo and
Casey.
20. Plaintiff is concerned about the ages of the dogs and that he will not get to see
them because of the delay in this trial.
21. Plaintiff is seeming a visitation schedule so that he may able to spend some
time with the dogs.
22. Plaintiff was the previous caretaker at the very least, although our position
remains that the Plaintiff is the rightful owner of the dogs.
23. Defendant continues to delay the litigation process in order for a judge or jury to
determine who rightfully owns the dogs.
WHEREFORE,Plaintiff respectfully requests that this Honorable Court
grant this motion and set a visitation schedule for Plaintiff to see the dogs named
r
Oreo and Casey.
Respectfully Submitted,
Date: _ Li
Vincent M. Monfredo,Esquire
5000 Ritter Rd
Suite 202
Mechanicsburg, PA 17055
717.585.2064
Supreme Court ID#206671
Attorney for Plaintiff
THE LAW OFFICE OF
VINCENT loo MONFRED0
vrmonl'redo @ginail.com 5000 Ritter Rd. Tel: 717.585.2061
www.vincenlmonfredo.com Smite 202 Fax: 888.959.1331
Medhanicsburg;PA 17055
June 5, 2013
Margaret M. Stuski, Esq.
908 W. Walnut St.
Wormleysburg,PA 17043
RE: Doug Wotring v. Margaret Stuski
Docket No.: 13-380
Dear Attorney Stuski:
Enclosed please find a time-stamped copy of the Plaintiff's Answers filed in
response to your preliminary objections.
Also enclosed are two(2) copies of Plaintiff's First Interrogatories and two (2)
copies of Plaintiff's request for production of documents. Please respond to them and
return them to me in accordance and within the time limits set by the Pennsylvania Rules
of Civil Procedure.
Once again, my client asks that you reconsider and work out a visitation
agreement with him in regards to the dogs. We believe this is not only in the best
interests of the parties but of the dogs. If you wish to work out a visitation agreement
please do not hesitate to e-mail me at vmonfredo @gmail.com.
Sincerely,
Vincent M. Monfredo, Esquire
cc: Doug Wotring
www.vincentmonfredo.com
(I J t4—
4
DOUGLAS WOTRING, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. DOCKET NO.: 13-380
MARGARET STUSKI CIVIL ACTION—LAW
Defendant
PLAINTIFF'S FIRST SET OF INTERROGATORIES
TO: Margaret M. Stuski, Esq.
908 W. Walnut St.
Wormleysburg, PA 17043
PLEASE TAKE NOTICE that you are hereby required, pursuant to Pennsylvania Rules of
Civil Procedure No. 4001 et seq., to serve upon the undersigned, within thirty (30) days after
service of this Notice, your answers in writing under oath to the following Interrogatories.
DEFINITIONS AND INSTRUCTIONS
(A) Whenever the term "document" is used herein,it includes (whether or not
specifically called for)all printed,typewritten, handwritten, graphic or recorded matter,
however produced or reproduced and however formal or informal.
(B) Whenever you are asked to "identify" a document,the following information
should be given as to each document of which you are aware, whether or not you have
possession, custody or control thereof
(1) The nature of the document, letter, memorandum, computer print-out,
minutes, resolution,tape recording, etc.); Its date (or if it bears no date, the date when it was
prepared);
(2) The name, address, employer and position of the signer or signers (or if
r there is no signer, of the person who prepared it);
(3) The name,address, employer and position of the person, if any,to whom
the document was sent;
(4) If you have possession, custody or control of the document,the location
and designation of the place or file in which it is contained, and the name, address and
position of the person having custody of the document;
(5) If you do not have possession,custody or control of the document,the
present location thereof and the name and address of the organization having possession,
custody or control thereof, and
(6) A brief statement of the subject matter of such document.
(C) Whenever you are asked to "identify" an oral communication,the following
information should be given as to each oral communication of which you are aware,whether or
not you or others were present or participated therein:
(1) The means of communication(telephone,personal conversation,etc.);
(2) Where it took place;
(3) Its date;
(4) The names,addresses, employers and positions(a)of all persons who
participated in the communication; and(b)of all other persons who were present during or
who overheard that communication;
(5) The substance of who said what to whom and the order in which it was
said; and
(6) Whether that communication or any part thereof is recorded, described or
referred to in any document(however informal)and, if so, an identification of such
document in the manner indicated above.
(D) If you claim that the subject matter of a document or oral communication is
privileged, you need not set forth the brief statement of the subject matter of the document, or the
substance of the oral communication called for above. You shall, however, otherwise "identify"
such document or oral communication and shall state each ground on which you claim that such
document or oral communication is privileged.
(E) Whenever you are asked to "identify" a person,the following information should
be given:
(1) The name,present address and present employer and position of the
person; and
(2) Whether the person has given testimony by way of deposition or
otherwise in any proceeding related to the present proceeding and/or whether that person
has given a statement whether oral, written, or otherwise, and if so,the title and nature of
any such proceeding,the date of the testimony,whether you have a copy of the transcript
thereof,the name of the person to whom the statement was given, where the statement is
presently located if written or otherwise transcribed, and the present location of such
transcript or statement if not in your possession.
(F) The term "you" shall be deemed to mean and refer to the party to whom these
Interrogatories have been propounded for and shall also be deemed to refer to,but shall not be
limited to, your attorneys, consultants, sureties, indemnitors, insurers, investigators, and any
1 f
other agents insofar as the material requested herein is not privileged.
(G) The word "incident" shall be deemed to mean and refer to the incident as
alleged to have occurred and as set forth in the Complaint.
These Interrogatories shall be deemed to be continuing Interrogatories. Between the
time of your answers to said Interrogatories and the time of trial, if you or anyone acting in
your behalf learns the identity or whereabouts of other witnesses not disclosed in your
answers, or if you obtain or learn of additional infonnation requested herein,but not supplied
in your answers,then you shall promptly furnish a supplemental under oath containing the
same.
a y
INTERROGATORIES
1. State the following:
a. Your full name and any other name by which you are or have been known;
b. Date and place of your birth;
c. Your present home address;
d. Your present business address;
e. Your present occupation.
2. For each occupation you have had over the last ten(10)years, please identify:
a. The name and address of your employer;
b. The dates of each employment;
c. The nature of your occupational duties; and
d. The reason for the termination of employment.
3. For each address you have resided at(either full or,part-time) over the last ten(10)years,
please identify:
a. The complete address;
b. The dates of residence; and
c. Identify every individual who resided with you at that location.
4. Have you ever been married? If so please identify:
a. The name of each spouse;
b. The date and place of each marriage;
c. The date of termination of each marriage, if applicable;
d. State the period of time of any separate from your current spouse.
5. Were there occasions where you would reimburse the Plaintiff for Oreo and Casey's
expenses? If the answer to this interrogatory is yes,then please provide the following:
a. The date on which the reimbursement was made, what specifically the Plaintiff
was being reimbursed for,the total amount of the reimbursement,and the form of
payment.
6. Please identify every individual or expert you expect to call as a witness at the trial in this
matter and for each state:
a. Each individual's name, address, telephone number and present employer;
b. His or her relationship to you, if any;
c. Each fact the individual has told you or your representative about this case.
7. Did you give the Plaintiff permission to use any of your financial accounts? If so please
state:
a. The name of the financial institution and type of account;
b. The purposes for which you gave permission to the Plaintiff to use this account;
c. The time period for which you gave the Plaintiff permission to use the account;
d. For each transaction in which the Plaintiff used the account,please state the date,
the amount spent, and the purpose of the transaction.
Respectfully Submitted,
Date: �� ,�0 3 Y---
Vincent M. Monfredo,Esquire
5000 Ritter Rd.
Suite 202
Mechanicsburg,PA 17055
717.585.2064
Supreme Court ID#206671
Attorney for Plaintiff
DOUGLAS WOTRING, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA
V. DOCKET NO.: 13-380
MARGARET STUSKI CIVIL ACTION—LAW
Defendant
CERTIFICATE OF SERVICE
1,Vincent M. Monfredo,Esquire, do hereby certify that I served a copy of the Plaintiff's
Interrogatories upon the following by depositing same in the United States snail, postage
prepaid, , at Carlisle,Pennsylvania., addressed as follows:
Margaret M. Stuski,Esq.
908 W. Walnut St.
Wormleysburg,PA 17043
Respectfully Submitted,
Date: t
Vincent M. Monfredo,Esquire
5000 Ritter Rd.
Suite 202
Mechanicsburg,PA 17055
717.585.2064
Supreme Court ID#206671
Attorney for Plaintiff
DOUGLAS WOTRING, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA
V. DOCKET NO.: 13-380
MARGARET STUSKI CIVIL ACTION—LAW
Defendant
PLAINTIFF'S FIRST REQUEST FOR
PRODUCTION OF DOCUMENTS
TO: Margaret M. Stuski,Esq,
908 W. Walnut St.
Wormleysburg,PA 17043
Defendant is hereby requested to produce, in accordance with the Pennsylvania Rules of
Civil Procedure,the below listed documents and/or items. The documents and/or items will be
examined and/or photocopied; photograph negatives will be processed and photographs
reproduced;tapes shall be heard and a copy made. The below listed documents and/or items are
to be produced at the Law Office of Vincent M. Monfredo at 5000 Ritter Rd. Suite 202,
Mechanicsburg,PA 17055.
DEFINITIONS
A. "You," "your" or"Plaintiff"refer to Defendant,Home Depot U.S.A, and to all.
other persons acting or purporting to act on behalf of Plaintiff, including,without
limitation, agents, representatives or attorneys.
B. "Communications" shall mean all inquiries, discussions, conversations,
negotiations, agreements, understandings, meetings,telephone conversations, letters,
correspondence, notes,telegrams,telexes, advertisements, or other forms of verbal
intercourse.
ti
C. Documents" shall mean all written or graphic matter of every kind or
description,however produced or reproduced, whether draft or final, original or
reproduction signed or unsigned, and regardless of whether approved, signed, sent,
received, redrafted, or executed, including but not limited to written communications,
letters, correspondence, memoranda, minutes,notes, films, recordings of any type,
transcripts, contracts, agreements, purchase or sales orders, memoranda of telephone
conversations of personal conversations, diaries, desk calendars, inter-office communications,
reports, studies,bills, receipts, checks, checkbooks, invoices, requisitions or
material similar to any of the foregoing,however denominated,by whomever
prepared,and to whomever addressed,which are in your possession, custody or
control or to which you have had or can obtain access.
D. "Persons" means an individual, corporation,partnership,trust,
associations, company, organization, or any form of business or commercial entity.
E. "Identify" when used with respect to an individual, means to state
(1)his name;
(2)business affiliation and officialtitle; and,
(3)his last known address.
F. ddentify " when used with respect to a document,means to state
(1)the type of document(e.g., letter, memorandum, handwritten note);
(2) its date;
(3) its author and addressee;
(4) its subject matter and size. In lieu of identifying any
documents, you may attach a copy of it to your answer, indicating the
question to which it is responsive.
G. "Identify" when used with respect to a company or other business entity,
means to state,
(1)the company's legal name and the name under which it does
business;
(2)the address of its principal place of business;and
(3)the identity of its chief executive officer.
H. "Relate to" means consist of, refer to, reflect or be in any way logically or
factually connected with the matter discussed.
I. These requests are to be deemed continuing in effect and should any
documents that are requested herein become available, if not presently available, such
documents are to be furnished immediately upon their availability. If any document is
not available, a statement is requested explaining why it is not available when it will
become available, if ever.
J. If any document requested to be produced is not in your possession,
custody or control, identify each person who has possession, custody or control of the
original or any copy of the document; if the document requested to be produced was,
but no longer is, in your possession, state the disposition of it and the reasons for such
disposition-, if the document requested to be produced has been destroyed, state the
time the document was destroyed,the reason for its destruction,and the identity of the
person who destroyed the document and the identity of any person who directed that
the document be destroyed.
r
,t t � •
DOCUMENTS TO BE PRODUCED
1. Any and all financial documents, including but not limited to receipts, cancelled checks,
cashed checks, copies of checks, and any other document which shows Defendant's
reimbursement to Plaintiff for expenses the Plaintiff paid in regards to Oreo or Casey.
2. Any and all financial documents, including but not limited to receipts, cancelled checks,
cashed checks, copies of checks, and any other document which shows Defendant's
payment of expenses for Oreo and Casey.
3. Copies of any and all records in regards to Casey and/or Oreo, including but limited to
their adoption contracts,their grooming, medical, and veterinary records, licenses, and
their vaccination records, during the time period since they were adopted.
4. Any and all copies of your EZ Pass records during the time in which you worked in or
near Philadelphia.
5. Any and all documents you plan to introduce at trial as evidence.
Respectfully submitted,
Vincent M. Monfredo,Esquire
5000 Ritter Rd.
Suite 202
Mechanicsburg,PA 17055
717.585.2064
Supreme Court ID 4 206671
Attorney for Plaintiff
Dated: h
DOUGLAS WOTRING, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. DOCKET NO.: 13-380
MARGARET STUSKI CIVIL ACTION—LAW
Defendant
CERTIFICATE OF SERVICE
I, Vincent M. Monfredo,Esquire, do hereby certify that I served a copy of the Plaint's
Production of DocuTnents upon the following by depositing same in the United States mail,
postage prepaid, , at Carlisle,Pennsylvania, addressed as follows:
Margaret M. Stuski,Esq.
908 W. Walnut St.
Wormleysburg, PA 17043
Respectfully Submitted,
Date:
Vincent M. Monfredo,Esquire
5000 Ritter Rd.
Suite 202
Mechanicsburg,PA 17055
717.585.2064
Supreme Court ID#206671
Attorney for Plaintiff
811/13 Gmail-Wotring v StusW
M-0 I
Wotring v. Stuski
Vincent Monfredo <vmonfredo @gmail.com> Thu, Jul 18, 2013 at 8:26 AM
To: Margaret Stuski <mstuski @yahoo.bom>
Bcc: Doug Wotring <tekebird@yahoo.com>
Attorney Stuski,
I served you with interrogatories and production of document requests over thirty days ago. If you could kindly
return the answer to me to avoid any further litigation that would be appreciated.
If I do not hear from you within seven (7)days I will look to file a motion to compel.
I would also like to schedule your deposition and if you would like to depose Mr. Wotring or anyone else we can
set that up to.
For your deposition could you kindly provide me dates in August when you may be available?
Lastly, if you have considered a visitation schedule my client would still be open to that. Thank you,
Sincerely,
Vincent M. Monfredo, Esq.
The Law Office of Vincent M. Monfredo
5000 Ritter Rd.
Suite 202
Mechanicsburg, PA 17055
Tel: 717.585.2064
Fax: 888.959.1331
vmonfredo @gmaii.com
www.\Ancentmonfredo.com
CONFIDENTIALITY NOTICE: This e-mail transmission (and/or the attachments accompanying it) may contain.
confidential information belonging to the sender which is protected by the attorney-client privilege. The information
is intended only for the use of the intended recipient. If you are not the intended recipient, you are hereby notified
that any disclosure, copying, distribution or the taking of any action in reliance on the contents of this information
is strictly prohibited. Any unauthorized interception of this transmission,is illegat If you have received this
transmission in error, please promptly notify the sender by reply e-mail, and then destroy all copies of the
transmission.
Margaret Stuski <mstuski @yahoo.com> Fri, Jul 19, 2013 at 9:22 AM
Reply-To: Margaret Stuski <mstuski @yahoo.com>
To: Vincent Monfredo<vmonfredo@gmail.com>
Attorney Mondfredo,
T . have no available dates in August or September . j
://mail.google.oorrVmail/u/0/?ui=2&ii-d677216930&Vevv--pt&q=stus16&qs=true&searcF--querW& F IM W1253aa485 x (d!� 1/2
8/1/13 Gmail-Wotring v.Stusl6
There is no visitation schedule with a person who stalked me and
has committed the offenses that your client has done . These are
my dogs and not his, as the Court has stated.
Sincerely,
Margaret M. Stuski, Esq.
From: Vincent Monfredo <umonfredo @gm ail.corn>
To: Margaret Stuski <mstuski @yahoo.com>
Sent: Thursday, July 18, 2013 8:26 AM
Subject: Wotring v Stuski
[Quoted text hidden]
Vincent Monfredo <vmonfredo @gmail.com> Wed, Jul 31, 2013 at 10:55 AM
To: Margaret Stuski <mstuski @yahoo.com>
Attorney Stuski,
Do you have any dates available in October or November?
Do you plan on responding to my discovery requests?
[Quoted text hidden]
https://mail.google.conVrrtail/u/0/?ui=2&it c—d677216930&wew=pt&q=stusl4&qs=true&search=q uerAth=13ff1b(1253aa485 W
DOUGLAS WOTRING, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. DOCKET NO.: 13-3 80
MARGARET STUSKI CIVIL ACTION—LAW
Defendant
CERTIFICATE OF SERVICE
I, Vincent M. Monfredo,Esquire, do hereby certify that I served a copy of the
Answers to Preliminary Objections upon the following by depositing same in the United
States mail,postage prepaid, , at Carlisle,Pennsylvania, addressed as follows:
Margaret M. Stuski, Esq.
908 W. Walnut St.
Wormleysburg,PA 17043
i
Respectfully Submitted,
Date:
Vincent M. Monfredo,Esquire
5000 Ritter Rd.
Suite 202
Mechanicsburg,PA 17055
717.585.2064
Supreme Court ID#206671
Attorney for Plaintiff
DOUGLAS WOTRING, IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V. : DOCKET NO.: 13-380
MARGARET STUSKI : CIVIL ACTION—LAW
Defendant
-ORDER OF COURT
AND NOW,this 34day of 2013, after review of Plaintiff's
Motion to Compel Discovery a hearing is hereby set to be held in Courtroom# at the
Cumberland County Courthouse in Carlisle, PA at a.m./pAn. on the 40 day of
2013.
By the Co
Distribution:
Vincent M. Monfredo,Esq., 155 S. Hanover St. Carlisle,PA 17013
ourt Administration Cumberland County
Margaret Stuski,Esq., 1.908 W. Walnut St. Wormleysburg,PA 043
'
MCD
� X113
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C:)
C-> 2- A
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
CD
C-? .y
s�
Mm ^"�r
DOUGLAS WOTRING �' ' "-
Plaintiff DOCKET NO: 13-380
CD
V. n `-D
MARGARET STUSKI CIVIL ACTION—LAW t
Defendant
DEFENDANT'S ANSWER TO PLAINTIFF'S MOTION TO COMPEL DISCOVERY AND TO SET A PRETRIAL
SCHEDULE AND MOTION TO REQUEST VISITATION
Defendant,Margaret M.Stuski, Esq., ("Stuski") pro se,files this Answer to Plaintiff's Motion to
Compel Discovery and To Set a Pretrial Schedule and Motion to Request Visitation and in support
thereof avers as follows:
1.) Admitted.
2.) Admitted.
3.) Admitted.
4.) Admitted.
5.) Admitted.
6.) Admitted.
7.) Admitted.
8.) No response is necessary. By way of further answer, Defendant was in the process of
responding and has now responded to the discovery requests. (See attached Exhibit showing
emails between counsel.)
9.) No response is necessary.
10.) No response is necessary as the paragraph calls for a conclusion of law.
11.) No response is necessary as the paragraph calls for a conclusion of law.
12.) No response is necessary as the paragraph calls for a conclusion of law.
13.) No response is necessary as the paragraph calls for a conclusion of law.
14.) Admitted. Stuski answered the first email and did not have time to respond to the second
email as Plaintiffs counsel filed this Motion the very next day. In contrast,Stuski filed
Preliminary Objections on March 20,2013 and no response was received by Plaintiffs counsel
until June 5, 2013. Stuski did not file a Motion to Compel,against Plaintiffs counsel.
15.) Admitted in part and denied in part. Stuski has responded to the discovery requests and still
does not have available dates in August and September,2013 for depositions.
16.) Denied. Strict proof thereof is demanded at trial. By way of further answer, Plaintiffs counsel
conveniently fails to mention that Preliminary Objections are outstanding in this matter. Stuski
has asked the Court to list them and decide them on the Briefs. If granted,they are in the form
of a demurrer and would resolve this litigation in favor of Stuski.
17.) Denied. By way of further answer,Stuski asks that the dispositive Preliminary Objections be
resolved prior to further expense and burden to Stuski.
18.) No response is necessary to this paragraph.
19.) Admitted in part,denied in part. By way of further answer,Oreo has passed away and any
issues concerning his ownership are now moot.
20.) No response is necessary.
21.) No response is necessary.
22.) No response is necessary as the paragraph calls for a conclusion of law.
23.) Denied. Strict proof thereof is demanded at trial. By way of further answer,Stuski
would like to have the Preliminary Objections ruled in her favor so this matter can be resolved
and she can live in peace without the continued harassment by Wotring in pursuing a non-
existent legal theory.
WHEREFORE, Defendant asks this Honorable Court to dismiss the Amended Complaint with
prejudice and to award Stuski any appropriate remedy that this Honorable Court may see fit.
Respectfully Submitted,
-fIARGAR T M.ST Slel, ESQUIRE
PA Supreme Court ID 42478
908 W.Walnut Street
Wormleysburg, PA 17043
(717) 599-2429
Pro Se Defendant
DATED: August 6, 2013
VERIFICATION
I,Margaret M. Stuski, Esq. Pro Se Defendant verify that the statements made in this
Answer to Plaintiff's Motion to Compel Discovery and to set a Pretrial Schedule and Motion to
Request Visitation are true and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unsworn falsification to
authorities.
Date: August 6, 2013
argaret M.Stuski, sq
CERTIFICATE OF SERVICE
Pursuant to Pa.R.C.P. 440,the undersigned does hereby verify that a true and correct copy of the
within Answer to Plaintiff's Motion to Compel Discovery and to set a Pretrial Schedule and
Motion to Request Visitation was served on August 6,2013 on the following by'first-class mail,
email or by personal service,to
Vincent Monfredo, Esq.
5000.Ritter Road, Suite 202
Mechanicsburg,PA 17055
Date: 08/06/13
&__�
argaret M. Stuski,tse
Attorney ID 42478
908 Walnut Street
Wormleysburg,PA 17043
717-599-2429
717-730-9891 (Fax)
817/13 Print
Subject: Re: Wotring v. Stuski
From: mstuski (mstuski@yahoo.com)
To: vmonfredo@gmaii.com;
Date: Monday, August 5, 2013 9:56 AM
Thank you for your response to resolve this discovery matter.
Sent from my Galaxy SUIT
Thank you for your response to resolve this discovery matter.
Sent from my Galaxy SOM
-------- Original message --------
From Vincent Monfredo<vmonfredo@grnailcon-f>
Date:08/05/2013 9:26 AM (GMT-05-00)
To:Margaret Stuski<rnstuski@yahoo.com>
Subject:Re:Wotring v. Stuski
Look in the mirror.
On Mon,Aug 5, 2013 at 9:25 AM, Margaret Stuski<rnstuski@yahoo.com>wrote:
I am sure the Court appreciate your manner .
Margaret M. Stuski
From: Vincent Monfredo <vmonfredo@grnaiI.corn>
To: Margaret Stuski <mstuski@yahoo.com>
Sent: Monday, August 5, 2013 9:23 AM
Subject: Re: Wotring v. Stuski
My motion to compel was filed because it has been well over 30 days and there has been no response.
On Aug 5, 2013 9:18 AM, 'Margaret StuskP<mstuski@yahoo.com>wrote:
Obviously because I did not respond within one day of your
email, then it was necessary for you to file a Motion to Compel .
I am asking for sanctions in my Answer . This is a blatant abuse
of the judicial system destined to further cause me economic
aboutblark 117
81711 3 Print
damage and to attempt to paint me in a bad light to the Court .
It is not me who stalked Wotring, it is he who committed the
criminal offense .
Margaret M. Stuski . Esq.
From: Vincent Monfredo <vmonfredo @gmail.com>
To: Margaret Stuski <mstuski @yahoo.com>
Sent: Wednesday, July 31, 2013 10:55 AM
Subject: Re: Wotnng v. Stuski
4 � Attorney Stuski,
Do you have any dates available in October or November?
Do you plan on responding to my discovery requests?
4
On Fri, Jul 19, 2013 at 9 : 22 AM, Margaret Stuski
<mstuski @yahoo . com> wrote :
Attorney Mondfredo,
I have no available dates in August or September .
There is no visitation schedule with a person who stalked me
and has committed the offenses that your client has done .
These are my dogs and not his, as the Court has stated.
4'
Sincerely,
Margaret M. Stuski, Esq.
From: Vincent Monfredo <vmonfredo @gmail.com>
To: Margaret Stuski <mstuski @yahoo.com>
Sent: Thursday, July 18, 2013 8:26 AM
Subject: Wotnng v. Stuski
Attorney Stuski,
I served you with interrogatories and production of document
requests over thirty days ago . If you could kindly return the
answer to me to avoid any further litigation that would be
appreciated.
If I do not hear from you within seven (7) days I will look to
file a motion to compel .
abudtlank 2(7
8/1/13 Print
I would also like to schedule your deposition and if you would
i like to depose Mr . Wotring or anyone else we can set that up
to .
For your deposition could you kindly provide me dates in August
when you may be available?
; Lastly, if you have considered a visitation schedule m
would still be open to that . Thank you Y client
i ,
4
Sincerely,
Vincent M. Monfredo, Esq.
The Law Office of Vincent M. Monfredo
5000 Ritter Rd.
Suite 202
Mechanicsburg, PA 17055
Tel : 717 . 585 . 2064
Fax: 888 . 959 . 1331
vmonfredo @gmail . com
www.vincentmonfredo . com
f CONFIDENTIALITY NOTICE: This e-mail transmission
(and/or the attachments
accompanying it) may contain confidential information belonging to the sender
which is protected by the attorney-client privilege. The information is
¢ intended only for the use of the intended recipient. If you are not the intended recipient, you are hereby notified that any disclosure, copying,
distribution or the taking of any action in reliance on the contents of this
information is strictly prohibited. Any unauthorized interception of this
transmission is illegal. If you have received this transmission in error,
please promptly notify the sender by reply e-mail, and then destroy all copies
of the transmission.
Sincerely,
X
Vincent -M Monfredo, Est
The Law Office of Vincent M. Monfredo
5000 Ritter Rd.
Suite 202
Mechanicsburg, PA 17055
Tel : 717 . 585 . 2064
Fax: 888 . 959 . 1331
abart:biank
3/7
W/13 Print
vmonfredo @gmail . com
www.vincentmonfredo . com
CONFIDENTIALITY NOTICE: This e-mail transmission (and/or the attachments
accompanying it) may contain confidential information belonging to the sender
which is protected by the attorney-client privilege. The information is intended
only for the use of the intended recipient. If you are not the intended
recipient, you are hereby notified that any disclosure, copying, distribution or
the taking of any action in reliance on the contents of this information is
strictly prohibited. Any unauthorized interception of this transmission is
illegal. If you have received this transmission in error, please promptly notify
the sender by reply e-mail, and then destroy all copies of the transmission.
Sincerely,
Vincent M. Monfredo, Esc
The Law Office of Vincent M. Monfredo
5000 Ritter Rd.
Suite 202
Mechanicsburg, PA 17055
Tel- 717.585.2064
Fax: 888.959.1331
vmonfredo @gmaiLcom
www.vincenhmnfredo.com
CONFIDENTIALITY NOTICE: This e-mail transmission (and/or the attachments accompanying it) may contain
confidential information belonging to the sender which is protected by the attorney-client privilege. The information is
intended only for the use of the intended recipient. If you are not the intended recipient, you are hereby noted that any
disclosure, copying, distribution or the taking of any action in reliance on the contents of this information is strictly
prohibited. Any unauthorized interception of this transmission is illegal. If you have received this transmission in error,
please promptly notify the sender by reply e-mail, and then destroy all copies of the transmission.
Look in the mirror.
On Mon, Aug 5, 2013 at 925 AM, Margaret Stuski<MStuski @yahoo.com>wrote:
I am sure the Court appreciate your manner.
Margaret M. Stuski
abwt:blank 4P
8(7/13 Print
From Vincent Monfredo<vmonfredo@grnailcom>
To:Margaret Stuski<mstuski@yahoo.con-i>
Sent:Monday, August 5, 2013 9:23 AM
Subject:Re:Wotring v. Stuski
My motion to compel was filed because it has been well over 30 days and there has been no response.
On Aug 5, 2013 9:18 AM, 'Margaret Stusk?'<mstuski@yahoo.com>wrote:
Obviously because I did not respond within one day ofyour email, then it was necessary for you to file a Motion
to Compel. I am asking for sanctions in my Answer. This is a blatant abuse of the judicial system destined to
further cause me economic damage and to attempt to paint me in a bad light to the Court. It is not me who
stalked Wotring it is he who committed the criminal offense.
Margaret M. Stuski Esq.
From Vincent Monfredo<vmonfredo@gm;aIcom>
To:Margaret Stuski<rristuski@yahoo.com>
Sent:Wednesday, July 31, 2013 10:55 AM
Subject:Re:Wotring v. Stuski
Attorney Stuski,
Do you have any dates available in October or November?
Do you plan on responding to my discovery requests?
On Fri, Jul 19, 2013 at 9:22 AM,Margaret Stuski<mstuski@yahoo.com>wrote:
Attorney Mondfredo,
I have no available dates in August or September.
There is no visitation schedule with a person who staked me and has committed the offenses that your client has
done. These are my dogs and not his, as the Court has stated.
Sincerely,
Margaret M. Stuski, Esq.
From Vincent Monfredo<vmonfredo@gmailcom;>
To:Margaret Stuski<mstuski@yahoo.coM>
Sent:Thursday,July 18, 2013 8:26 AM
Subject:Wotring v. Stuski
about:biank
817/13 Print
Attorney Stuski,
I served you with interrogatories and production of document requests over thirty days ago. If you could kindly
return the answer to me to avoid any further litigation that would be appreciated.
If I do not hear from you within seven(7) days I will look to file a motion to compel.
I would also hike to schedule your deposition and if you would like to depose Mr. Wotring or anyone else we
can set that up to.
For your deposition could you kindly provide me dates in August when you may be available?
Lastly, if you have considered a visitation schedule my cfient would still be open to that. Thank you,
Sincerely,
Vincent M. Monfredo, Esq.
The Law Office of Vincent M. Monfredo
5000 Ritter Rd.
Suite 202
Mechanicsburg, PA 17055
Tel: 717.585.2064
Fax:888.959.1331
vonfredo@gmail.com
www.vincentmonfredo.com
CONFIDENTIALITY NOTICE:This e-mail transmission(and/or the attachments accompanying it)may
contain confidential information belonging to the sender which is protected by the attorney-client privilege. The
information is intended only for the use of the intended recipient. If you are not the intended recipient,you are
hereby notified that any disclosure, copying., distribution or the taking of any action in reliance on the contents of
this information is strictly prohibited. Any unauthorized interception of this transmission is illegal. If you have
received this transmission in error,please promptly notify the sender by reply a-mail, and then destroy all copies
of the transmission.
Sincerely,
aboutblank W
8(7/13 Print
Vincent M. Monfredo,Esq.
The Law Office of Vincent M. Monfredo
5000 Ritter Rd.
Suite 202
Mechanicsburg, PA 17055
Tel- 717.585.2064
Fax: 888.959.1331
vmnfredo@gmicom
www.vincentrnonfredo.com
CONFIDENTIAUTY NOTICE:This e-mail transmission(and/or the attachments accompanying it)may
contain confidential information belonging to the sender which is protected by the attorney-client privilege. The
information is intended only for the use of the intended recipient. If you are not the intended recipient,you are
hereby notified that any disclosure, copying distribution or the taking of any action in reliance on the contents of
this information is strictly prohibited. Any unauthorized interception of this transmission is illegal. If you have
received this transmission in error,please promptly notify the sender by reply e-mail, and then destroy all copies
of the transmission.
Sincerely,
Vincent M. Monfredo, Esq.
The law Office of Vincent M. Monfredo
5000 Ritter Rd.
Suite 202
Mechanicsburg, PA 17055
Tel 717.585.2064
Fax:888.959.1331
vmonfredo@grmicom
www.vincentrnonfredo.com
CONFIDENTIALITY NOTICE:This e-mail transmission(and/or the attachments accompanying it)may
contain confidential information belonging to the sender which is protected by the attorney-client privilege. The
information is intended only for the use of the intended recipient. If you are not the intended recipient you are
hereby notified that any disclosure, copying, distribution or the taking of any action in reliance on the contents of
this information is strictly prohibited. Any unauthorized interception of this transmission is illegal If you have
received this transmission in error,please promptly notify the sender by reply e-rnaiL and then destroy all copies
of the transmission.
about:blank 7/7
elk
PRAECIPE.EQts�S•Ttl�i6
(Must be typewritten and submitted in triplicate)
TO THE PROTHONOTARY OF CUMBERLAND COUNTY: (List the within matter for the next
Argument Court.) r
CAPTION OF CASE
(entire caption must be stated in full) ' �' `
° C) .
Douglas C. Wotring
'"T
{M}
vs. _CD CD 1,
Margaret M. Stuski �-
No. 13-380 Term
1. State matter to be argued (i.e., plaintiffs motion for new trial,defendants demurrer to
complaint, etc.):
Preliminary Objections of Defendant
2. Identify all counsel who will argue cases:
(a) for plaintiffs:
Vincent Monfredo, Esq.
(Name and Address)
5000 Ritter Road, Suite 202, Mechanicsburg, PA 17055
(b) for defendants:
Margaret M. Stuski, Esq.
(Name and Address)
908 W. Walnut Street, Wormleysburg, PA 17043
3. 1 will notify all parties in writing within two days that this case has been listed for
argument.
4. Argument Court Date:
September 27,2013 1 am requesting that the matter be decided on Briefs.
nature
Print you ame �l
Defendant
Date:
August 1, 2013 Attorney for
INSTRUCTIONS:
1.Original and two copies of all briefs must be filed with the COURT
ADMINISTRATOR(not the Prothonotary) before argument.
2.The moving party shall file and serve their brief 14 days prior to argument.
3.The responding party shall file their brief 7 days prior to argument.
4. If argument is continued new briefs must be filed with the COURT
ADMINISTRATOR(not the Prothonotary)after the case is relisted.
am� iq9.7.5p�1�-
C'I�ae�dP
�� a 9yal g
DOUGLAS WOTRING, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
MARGARET STUSKI,
Defendant 13-0380 CIVIL TERM
ORDER OF COURT
AND NOW, this 20th day of September, 2013 , before the
Court is Plaintiff ' s Motion to Compel Discovery, and To Set a
Pretrial Schedule, and Motion to Request Visitation, to which the
Defendant filed an Answer on August 9 , 2013 . The Defendant has
also filed a Praecipe listing her preliminary objections for
argument on August 9 , 2013 , which would be heard by the Court on
September 27 , 2013 . However, the Defendant having failed to appear
and having given no explanation for her absence, the Court finds it
appropriate to enter the following order:
1 . Defendant ' s preliminary objections are overruled.
Argument shall not occur on September 27, 2013 .
2 . Although some relief may be warranted with respect
to Defendant ' s Motion, we find it more expedient to
direct the parties to appear for a final hearing
on the merits of this case on Friday, November 1,
2013 , at 9 : 00 a.m. , in Courtroom No. 1, at which
time the Court will receive evidence and arguments
from the parties and issue a final decree .
By the Court,
cu -,-
r
> N CD CD
CD
Albert H. Mas nd, J.. {
-- W
u
(Wotring v. Stuski, Docket No. 2013-0380 Civil)
Vincent M. Monfredo, Esquire
For the Plaintiff
/
argaret M. Stuski, Esquire
Pro Se Defendant
:vae
q7C ES / '[�..,�
;,V/3
DOUGLAS WOTRING, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
MARGARET STUSKI,
Defendant NO. 13-0380 CIVIL TERM
ORDER OF COURT
AND NOW, this 1st day of November, 2013 , Count 1
having been rendered moot because of the death of the Old
English Sheepdog Oreo and Count 3 having been withdrawn by
Plaintiff, before the Court is solely Count 2 relating to the
Old English Sheepdog Casey. Because we find Plaintiff has
failed to meet his burden, we rule as follows :
1 . The Defendant is the owner of the Old English
Sheepdog named Casey.
2 . The Defendant did not gift or otherwise transfer
ownership of Casey to Plaintiff.
3 . Judgment is entered in favor of Defendant .
4 . No further relief is granted to either party.
By the Court,
Albert H. Ma and,
� Vincent M. Monfredo Esquire
F9r Plaintiff
Margaret M. Stuski, Esquire -p
Pro Se Defendant x� p °ter=
prs gip. . C)
co