HomeMy WebLinkAbout04-6085COMMONWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS NOTICE OF APPEAL
Judicial District, County Of FROM
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No. Of - (o" r-3,
NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on
th to and ' t eferen below.
AME OF APPELLANT I MAG STiO® NAME OF?j40 401e
ADDRESS OF APPELLANT'' G CITY p/`'??J SITEn C•,nC ZIP CODE
o? i?S6??ul ? 1717- ?11i S?2T•t,t? S / ci,
DATE OF JUDGMENT IN THE CASE OF (Plaintiff) U U T /J { (Defenda(nt))'
SIGNATURE OF APPELLANT OR IByfX EL
DOCKET No. Y OR44GENT
J?
This block will be signed ONLY when this notation is required under Pa. If appellant was Claim ( Pa. R.C.P.D.J. No. 1001(6) in action
R.C.P.D.J. No. 1008B.
This Notice of Appeal, when received by the District Justice, will operate as a before a District Justice, A COMPLAINT MUST BE FILED within twenty
SUPERSEDEAS to the judgment for possession in this case.
(20) days after filing the NOTICE of APPEAL.
Signature of Prothonotary or Deputy
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before District Justice. IF
NOT USED, detach from copy of notice of appeal to be served upon appellee.
PRAECIPE: To Prothonotary
Enter rule upon
Name of appellee(s)
(Common Pleas No.
appellee(s), to file a complaint in this appeal
) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
Signature of appellant or attorney or agent
RULE: To
Name of appellee(s)
, appellee(s)
(1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service
of this rule upon you by personal service or by certified or registered mail.
(2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAYBE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of the mailing.
Date: 20
Signature of Prothonotary or Deputy
YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL.
AOPC 312-02
COURT FILE TO BE FILED WITH PROTHONOTARY
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing of the notice of appeal. Check applicable boxes.)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF -,ss
AFFIDAVIT. I hereby (swear) (affirm) that I served
? a copy of the Notice of Appeal, Common Pleas No. , upon the District Justice designated therein on
(date of service) 20 ? by personal service ? by (certified) (registered) mail,
sender's receipt attached hereto, and upon the appellee, (name) on
20 ? by personal service ? by (certified) (registered) mail,
sender's receipt attached hereto.
(SWORN) (AFFIRMED) AND SUBSCRIBE[ BEFORE ME
THIS DAY OF 20
Signature of official before whom affidavit was made
Title Of official
My commission expires on
AOPC 312A - 02
,20
Signature of affiant
?
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COMMONWEALTH OF PENNSYLVANIA NOTICE OF JUNG ' •WT/TRANSCR'IP
COUNTY OF. CLl .MERLAM CIf {
VIL
Maq. Dial No.
09-2-01 PLAINTIFF:
'
N .and ADDRESS
-SLOOP JR . , HWLD L.
DJ Name: Hon. 42 8 CHESTNUT STRNAT,;. '
,.
PAMA P. CORREAL .
., .a
MT. HOLLY S PRIi?t3+ , ` ' 0 5
. Aiidtaaa: I CMTROUSE SQUARE L
=LISLE, PA VS.
DEFENDANT: NAME and ADDRESS
Te{eph6w (717) 240-6564 17013- 0000 rSTRINGHM, SNMW H.
10 SHER&TON CIRCLE
CARLISL$, PA, 17013
L
RMOLD L. SLOOP JR.
428 CRES!1%WJT STREET DocketNo.: CV-0000330.4'
MT. HOLLYI. SPRINGS, PA 17065 Date Filed: 9/02/04
THIS IS TO NOTIFY YOU THAT:
-- Judgment: R
LX-] Judgment was entered for: (Name) RTRT'N OIRAN, STMW 'K.
Judgment was entered against: (Name) 4iTMP j&_ , RA^nTtTT T..
in the amount of $ _.pp on: (Date of Judgment) 11J9/na
? Defendants are jointly and severally liable. (Date & Time)
? Damages will be assessed on: Amount of Judgment $ • QO
Judgment Costs $ • 00
Interest on Judgment $ • 00
? This case dismissed without prejudice. Attorney Fees $ .00
Total $ .00
? Amount of Judgment Subject to
Attachment/42 Pa.C.S. § 8127 $ Post Judgment GI`6& "' $
Portion of Judgment for physical Post Judgment Costs $
damages arising out of residential _?^? ?
lease $ Certified Judgmerrt'T6*'
ANY PARTY HAS THE RIGHT TO APPEAL WITH$N 34 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERIC OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE, OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, I THEE JUDGMENT HOLDER
ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COMI^ FROM THE COURT
OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE DISTRICT JUSTICE
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES,
OR OTHERWISE COMPLIES WITH THE JUDGMENT.
11-3.9--44 Date District Justice
I certify that this is a tru d correct or he proc di s containing the judgment.
11-19-04 Dat District Justice
My commission expires first Monday of January, 2006. SEAL.,
AbPC 315-03 DATE PRIAtTF.D : 11/22/04 8 : 01 r ? 7 AV
COMMONWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS NOTICE OF APPEAL
Judicial District, County Of FROM
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No.
NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on
th 0ac+1"n tFjeferencad below.
NAME OF APPELLANT `•! /[ MAG. DIST. NO. 14AME .J.
G v _oiw'? ot,1,4a 4vlz/1ed
AD RESS OF APPELLANT _ CITY STATE ZIP CODE 57, 07'- S /1 i ti s 4. 17 OIyS
DATE OF JUDGMENT IN THE CASE OF (PlainhM (Defendant)
This block will be signed ONLY when this notation is required under Pa.
R.C.P.D.J. No. 10088.
This Notice of Appeal, when received by the District Justice, will operate as a
SUPERSEDEAS to the judgment for possession in this case.
Signature of Prothonotary or Deputy
If appellant was Claim t ( e Pa. R.C.P.D.J. No. 1001(6) in action
before a District Justice,vC` O?IIE FILED within twenty
(20) days after Wing the NOTICE of APPEAL.
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before District Justice. IF
NOT USED, detach from copy of notice of appeal to be served upon appellee.
PRAECIPE: To Prothonotary
Enter rule upon appellee(s), to file a complaint in this appeal
Name of appellee(s)
(Common Pleas No.. ) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
Signature of appellant or attorney or agent
RULE: To appellee(s)
Name of appellee(s)
(1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service
of this rule upon you by personal service or by certified or registered mail.
(2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAYBE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of the mailing.
Date: 20
Signature of Prothonotary or Deputy
YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL.
AOPC 312-02
COURT FJLE .
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b
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PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE FILED WITHIN TEN (10) LAYS AF7 ER filing of the notice of appeal. Check applicable boxes)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF
,??r ss
AFFIDAVIT: I hereby (swear) (affirm) that I served
a copy of the Notice of Appeal, Common Pleas NP???""`'upon the District Jestict I therein on
(date of service) 3 20 p y . ? by personal service V by (certified) (registered) mail,
sender's receipt attached hereto, and upon the appellee, (name)s?kd A J/lL? t Or
V/ 0-C, 3 : 200Y ? by personal service by (certified) (registered) mail,
/ '?
sender's receipt attached hereto.
(SWOR,N) (AFFIRMED) AN SUBSCRIBED BEFO E E
'bA THIS r..r?r 3 _ C}AYOF LA'?ti>? 2!0
0
-u2 ?laia
r, re of q icoa! before whom affidavit was made
Title of official
My commission expires on Ll •-?' 20 U ?`H
of afliant
f?17111;-
NOTARIALSEAL -
CLAUQIA A. BREWBAKER, NOTARY PUBLIC.
Carlisle Boro, Cumberland County
My Commission Expires April 4, 2005
AOPC 312A - 02
I-Darold L. ooP; ??.
q 2 8 (Ihe.stnu-t St,
rnt, kO<<q SprInry, Pa, 19015
19SP-Odanf-,
SV-Nand 4 Strln koLn
10 She.('eA-ton C"trae
0,OV-11'Sle-, PO( . i'7 v 13
oq - eog5
r
?p?iC.? Cat ? 0 mint
t?Qason oT Cornp)cun?) fror-' Pla.iotiff ?)arOIJ L. Sloop Ir
S acc i de.n-t a y n L,)h ('.k \6 e-Pe n dan-t 5 h o„ oL 14
Str'ln9han erOSSe-d it!-o -rhe- po-th d? the- !01a;nt f`-F ?%n Ljh C6
LVe. p). AA ?then SlrucA -?,k.e. ?l e?t?ndar? ? s eo.r, Thus eAus?n
? a loss o? P1 a-i nil -Ws Gar w h; e. -&h e: p 1 ain -t,,C; WaS
dr`, v n S r' ?? ?h -1-1?rvuc?h -?IIQ n-Le (` s e_G41 6-y) w M bh c
l Gh-? juSL u'cn'i nc, e-110t) OS we- /30?h -2ri-ter,ect o Ms4
the ?o I R-e porgy :s pate s L-ha? also. P 1 ain-LW
14 a(-old L. Sloop -Sr. See K'Ina S l 125. X1:5 -Por- Loss o-F Car-,
-
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\05_A\LIAB\DNC\LLPG\171615UMF\21234\00113
HAROLD L. SLOOP, JR.,
Plaintiff
V.
SHAND H. STRINGHAM,
Defendant
TO THE PROTHONOTARY:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-6085
CIVIL ACTION - LAW
ENTRY OF APPEARANCE
Kindly enter the appearance of the undersigned as counsel on behalf of the Defendant,
Shand H. Stringham, with respect to the above-referenced matter.
DATE: I )_ ? x`31 M
Respectfully ,submitted,
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOGGIN
BY:
D LD L. CARMELITE, ESQUIRE
I.D. No. 84730
4200 Crums Mill Road, Suite B
Harrisburg, PA 17112
(717) 651-3504
Attorney for Defendant,
Shand H. Stringham
HAROLD L. SLOOP, JR.,
Plaintiff
V.
SHAND H. STRINGHAM,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-6085
CIVIL ACTION - LAW
CERTIFICATE OF SERVICE;
I, Joanne M. Parr, an employee of Marshall, Dennehey,, Warner, Coleman & Goggin, do
hereby certify that on this c`? day of December 2004, served a copy of the foregoing
document via First Class United States mail, postage prepaid as follows:
Harold L. Sloop, Jr.
428 Chestnut Street
Mt. Holly Springs, PA 17065
A., 1\\ -V"A
nne M. Parr
P'a
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\05_A\LIAB\DNC\LLPG\171605VMF\21234\00113
HAROLD L. SLOOP, JR.,
Plaintiff
V.
SHAND H. STRINGHAM,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-6085
CIVIL ACTION - LAW
PRELIMINARY OBJECTIO14S
OF DEFENDANT, SHAND H. STRINGHAM,
TO PLAINTIFF'S NOTICE OF COMPLAINT
1. On December 15, 2004 Plaintiff filed a "Notice of Complaint" with the
Prothonotary's Office of the Court of Common Pleas of Cumberland County. A copy of
Plaintiffs Notice of Complaint is attached hereto as Exhibit "A".
2. Defendant Shand H. Stringham files these timely Preliminary Objections
for the reasons set forth below.
3. Defendant, Shand H. Stringham, hereby submits Preliminary Objections
pursuant to Pa.R.C.P. 1028(a)(4) in the nature of a demurrer to Plaintiffs Notice of Complaint.
4. Plaintiffs Notice of Complaint is handwritten and in its entirety states as
follows:
Notice of Complaint
Reason of Complaint, from Plaintiff Harold L. Sloop Jr is
due to accident 7-7-04 in which Defendant Shand H. Stringhan
crossed into the path of the plaintiff in which the plaintiff then
struck the Defendants [sic] car. Thus causing total loss of
Plaintiffs car while the Plaintiff was driving straight through the
intersection with the light just turning yellow as we Both [sic]
entered. Also the police Report states that also. Plaintiff Harold L.
Sloop Jr. seeking $1125.45 for Loss [sic] of Car [sic].
See, Plaintiffs Notice of Complaint attached hereto as Exhibit "'A".
5. Plaintiffs Notice of Complaint fails to set forth a cause of action against
Defendant.
6. Plaintiffs Notice of Complaint fails to comply with Pa.R.C.P. 1019(a)
such that it fails to set forth materials on which a cause of action is based in a concise and
summary form.
7. Plaintiffs Notice of Complaint fails to comply with Pa.R.C.P. 1022 such
that it is not divided into consecutively numbered paragraphs, each containing one materials
allegation.
8. Plaintiffs Notice of Complaint fails to comply with Pa.R.C.P. 1021(a)
because it fails to set forth a prayer for relief.
9. Plaintiffs Notice of Complaint fails to comply with Pa.R.C.P. 1021(c)
such that it fails to state whether the amount claimed does or does not exceed the jurisdictional
amount requiring Arbitration in Cumberland County.
WHEREFORE, Defendant Shand H. Stringham respectfully requests that this Honorable
Court grant his Preliminary Objections in the nature of a demurrer as against Plaintiff Harold L.
Sloop, Jr. and dismiss this action with prejudice.
DATE: t
Respectfully submitted,
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOGGIN ITIC\
BY:
DO LD L. CARMELITE, ESQUIRE
I.D. No. 84.730
4200 Crurns Mill Road, Suite B
Harrisburg,, PA 17112
(717) 651-3504
Attorney for Defendant,
Shand H. Stringham
L 0.? rl ? t t-?.
I-?arold Sloop; __Sr.
y2 8 (!,he.s-tnut St,
rn-L, kc) l ly Spr' n3S, Pa. 1901.5
Sand Str+nc ht-n
t® 'Shw.f-(Aon Circe.
PGs l r7v /3
Oq -X085
_ f_-3
wov i c:..e. CA Cor)VIOL'Int
QaSor1 of Comp)o,'nt -iron, Pia..%,nt iff ? Ianold t. Sluff
is A?Q_ to acC l ae.n-t r1- rl- o y ; n uoh ic h'b(?-Pendant 5 h. an, 4.
Str?r)3haii e('osSed iiliio- he_ p h c)f -&he pla;ot%4 in c.)hI,c6
Lh e- p loa:(n- IA hen slf-ud. +,h4p- e?en??r?? s Ga.r. I hus ca us??
?o-fQ? lvsS c Plo:inb"s Co-(- LAIle_ -the P1ainti-F-P was
???vw?n S?rc??h-?-1-?nrvuc?h -ham n'?ec-S ec;-I i()-,n we'M 0e.
L iGh juS? -LLx tl ins qe ttow oS w c f3o-th enj ?-ect p /t?I Q
c e- Re por-?T ?-ta-Le s that also. P l oLin
IA arvl cl ?. Sloop 3 ?-- see K'lna ! 12?. y?5 -?or LOSS o-F Car.,
OX
HAROLD L. SLOOP, JR., IN THE COUIP;T OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 04-6085
SHAND H. STRINGHAM, CIVIL ACTION - LAW
Defendant
CERTIFICATE OF SERVICE
I, Joanne M. Parr, an employee of Marshall, Dennehey, Warner, Coleman & Goggin, do
hereby certify that on this ?3 day of December 2004, served a copy of the foregoing
document via First Class United States mail, postage prepaid as follows:
Harold L. Sloop, Jr.
428 Chestnut Street
Mt. Holly Springs, PA 17065
?""" x ?wq
nne M. Parr
C7 ?`' O
"' 03 C>
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:
? Pre-Trial Argument Court
® Argument Court
--------------------------------------------------•--------------------
CAPTION OF CASE
(entire caption must be stated in full)
HAROLD L. SLOOP, JR.,
Plaintiff
V.
SHAND H. STRINGHAM,
Defendant
No.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-6085
CIVIL ACTION - LAW
6085 Civil Term 20 04
1. State matter to be argued (i.e., plaintiffs motion for new trial,
defendant's demurrer to compliant, etc.): Defendant Shand H. Stringham's Preliminary
Objections to Plaintiffs Notice of Complaint.
2. Identify counsel who will argue case:
(a) Harold L. Sloop, Jr. (pro se) - 428 Chestnut Street, Mt. Holly Springs, PA
17065
(b) for Defendant, Shand H. Stringham: Donald L. Carmelite, Esquire - 4200
Crums Mill Road, Suite B, Harrisburg, PA 17112
3. I will notify all parties in writing within two days that this case has been listed for argument.
4. Argument Court Date: February 2, 2005
Donald L. Carmelite
(Attorney for Defendant, Shand H. Stringham)
Dated: 12/23/04
\05_A\L1AB\DNC\LLPG\l 71653VMF\21234\00113
HAROLD L. SLOOP, JR., IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAI\TD COUNTY, PENNSYLVANIA
V. NO. 04-6085
SHAND H. STRINGHAM, CIVIL ACTION - LAW
Defendant
CERTIFICATE OF SERVICE
I, Joanne M. Parr, an employee of Marshall, Dennehey, Warner, Coleman & Goggin, do
1`5-k
hereby certify that on this ;,,")3 day of December 2004, served a copy of the foregoing
document via First Class United States mail, postage prepaid as follows:
Harold L. Sloop, Jr.
428 Chestnut Street
Mt. Holly Springs, PA 17065
\11?? M'9-%11?1
J nne M. Parr
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HAROLD L. SLOOP, JR. IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY., PENNSYLVANIA
V.
SHAND H. STRINGHAM : NO. 2004-6085 CIVIL TERM
IN RE: DEFENDANT'S PRELIMINARY OBJECTIONS
BEFORE GUIDO, J.
ORDER OF COURT
AND NOW, this 7TH day of FEBRUARY, 2005, Defendant's Preliminary
Objections are GRANTED. Plaintiff is given twenty (20) days from receipt of this order
within which to file an amended complaint.
Edward E. Uuido. J.
hIarold L. Sloop, Jr.
428 Chestnut Street
Mt. Holly Spring, Pa. 17065
onald L. Carmelite, Esquire
4200 Crums Mill Road, Suite B
Harrisburg, Pa. 17112
:sld
IP' _ V
0D- 09 05
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are
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-?i
Harold L. Sloop Jr.
Plaintiff
V.
Shand H. Stringhan
Defendant
Complaint
In The Court of Common Pleas
Cumberland County, Pennsylvania
No. 04-6085
Civil Action-Law
1. Plaintiff Harold L. Sloop Jr. is an adult individual residing at 428
Chestnut Street, Mount Holly Springs Cumberland County
Pennsylvania 17065.
2. Defendant Shand H. Stringhan located at 10 Sheraton Circle,
Cumberland County Carlisle, Pennsylvania 17013.
3. Plaintiff Harold L. Sloop Jr., on July 9th, 2004, while driving south
from Carlisle on South Hanover Street, at the speed limit of 35 mph,
entered the intersection at South Hanover Street and Noble Street to
proceed straight through the intersection.
4. Upon entering the intersection, the traffic light: turned yellow at
which time the Defendant Shand H. Stringhan turned left onto Noble
Street into the path of the Plaintiff Harold L. Sloop Jr. At which time,
the Plaintiff then struck the Defendant's car just behind the passenger
front side door. Therefore, causing total loss of Plaintiff's car.
5. As a result of the unsafe action of Defendant Shand H. Stringhan's
failure to yield to right of way at the intersection of South Hanover
Street and Noble Street, thus causing the accident:.
6. Plaintiff Harold L. Sloop Jr., therefore, respectfully request this
Honorable Court to enter judgment in my favor and against the
Defendant Shand H. Stringhan in the amount of ,$1,125.00 plus any
other relief that this Honorable Court finds appropriate.
Verification
I, Harold L. Sloop Jr., hereby verify the averments of the foregoing
document are true and correct to my personal knowledge, information
and belief. I understand that false statements herein are made subject
to the penalties of 18 Pa. C. S. Sec. 4904, relating to unsworn
falsification to authorities.
b0f % Borough of CaAlsle
e Carlisle Police/Accident Exchange of Information Form
116+ Incident Er
?• =Lr;i'!±5l Date i `ti Location SAlAsx)lair'_) VI)a(r.
Odad
Officer r ^, ` 7) - .? r, , Date" 12t, Badge 'sf5, Time Occurred k J.2.t
Primary Rd Speed T/C,ID/ # of Lanes
Intersecting Rd Speed T/C,ID/ µ? # of Lanes k
Unit # i k Vehicle Registration State'i_"I\
Vehicle Owner t Aojc,u; ?.. a, Address L C2, ( kv. cL ° Phone
Year S Make! ;, Color n' VIN °
Operator G 611ul L ?i. OLN 66?1 ?` DOB °1jk7,EStated.
Addresst .9 ,?. Phone 'SB'A A/B
Insurance Co. `- - -Policy # f, \2, 1%01 )15 IV\ -Co. Phone (1 L, 12," ``61
Occupant Unit # Name - DOB SB A/B
Address Phone - Seat Position
Witness(es)
Unit # f?-- Vehicle Registration '? i-iC State
Vehicle Owner ':'ohtyo 1- ? `° Address G aE a ?.; zee r-, a.?_? « APhone i, r'i ?' wA
ob Make ,u. Color VIN 032-'-_N' '(i
Year 2,
Operator{ OLN , d,. % DOB State
Address tL 7c,.,A?_N,,... 1n.r_L.i'.r, Phone ,,t? c'SB- ',-
Insurance Co. Policy # l 5 ?. ` 1 1 -
kcr, - `a 3l
Co. Phone \
' a K
-
Occupant Unit # _ 5- Name V-) n ;t,k,A ?• . ?? . , r,_c ,, DOB /B
Address ltt l ,(4?w ?=Lj r _
k-)l, Phone 1 'r i g, "?
Seat Position t,n
r IL
Witness(es)
Additional OIITtatlOn s),,n.rc':-... L zx»?c? r;c,! `c'>C???.:t 1rf. -"".:5?.r?3lf..Y. 'lc f' •.,Nir? )r ?P,c-'
t risn ?'
RDYIV Vl -?? 1[? t<C'? - `) i • ? C `.. 6 5,. 4: •--• P 1" , iTS.6-c`c,?;?. 01.._e'-'1 E::.c in?.z? h ,r kc «^.
NOTICE: Copies of accident reports are available by mail only, unless emergency circumstances prevail.
Enclose a check or money order in the amount of $15.00 and send to:
Carlisle Police Department, 53 W. South Street, Carlisle, PA 17013, (717) 243-5252
(Please allow seven (7) days for processing and return of accident form)
Reportable ? Non-Reportable
r
White Copy - Reporting Officer Canary Copy - Unit 1 Pink Copy - Unit 2
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V05_AVL1A8ADNCALLPGA177608VMF\21234\00113
HAROLD L. SLOOP, JR.,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
SHAND H. STRINGHAN,
Defendant
NO. 04-6085
CIVIL ACTION - LAW
NOTICE TO PLEAD
TO: Plaintiff, Harold L. Sloop, Jr.
428 Chestnut Street
Mount Holly Spring, PA 17065
You are hereby notified to plead to the enclosed New Matter within twenty (20) days
from service hereof or a default judgment may be filed against you.
Respectfully submitted,
MARSHALL, DENNEHEY, WARNER,
CO7LD DATE: BY:
D CARMELITE, ESQUIRE
I.D. No. 84730
4200 Crums Mill Road, Suite B
Harrisburg, PA 17112
(717) 651-3504
Attorney for Defendant,
Shand H. Stringham
4
M AALIABADNCALLPGA177083VMF\21234V00113
HAROLD L. SLOOP, JR.,
Plaintiff
V.
SHAND H. STRINGHAN,
Defendant
NO. 04-6085
CIVIL ACTION - LAW
ANSWER WITH NEW MATTER
OF DEFENDANT SHAND H. STRINGHAM
TO PLAINTIFF'S COMPLAINT
1. Admitted in part; denied in part. It is admitted only that Plaintiff is who
he says he is. All remaining allegations of this Paragraph are denied in accordance with
Pa.R.C.P. 1029(c).
2. Denied as stated. It is denied that Shand H. Stringhan is located at 10
Sheraton Circle, Cumberland County Carlisle, Pennsylvania 17013. By way of further answer,
Shand H. Stringham does live at this address.
3. Denied. The averments set forth in this Paragraph are denied in
accordance with Pa.R.C.P. 1029(e).
4. Denied. The averments set forth in this Paragraph are denied in
accordance with Pa.R.C.P. 1029(e). By way of further answer, it is denied that Shand H.
Stringhan or Shand H. Stringham was operating either of the motor vehicles involved in the
accident which gives rise to Plaintiffs Complaint.
5. Denied. The allegations set forth in this Paragraph constitute conclusions
of law to which no further responsive pleading is required and accordingly these allegations are
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
denied in accordance with the provisions of Pa.R.C.P. 1029(e) and proof thereof is demanded at
the time of trial, if relevant. By way of further answer, it is denied that Shand H. Stringhan or
Shand H. Stringham was operating either of the vehicles which were involved in the accident
that give rise to Plaintiffs Complaint.
6. Denied. The allegations set forth in this Paragraph constitute conclusions
of law to which no further responsive pleading is required and accordingly these allegations are
denied in accordance with the provisions of Pa.R.C.P. 1029(e) and proof thereof is demanded at
the time of trial, if relevant. By way of further answer, it is denied that Shand H. Stringhan or
Shand H. Stringham was operating either of the vehicles which were involved in the accident
that give rise to Plaintiffs Complaint.
WHEREFORE, Defendant Shand H. Stringham demands judgment in his favor and
against Plaintiff Harold L. Sloop, Jr. together with such other relief as this Court shall deem
appropriate.
NEW MATTER DIRECTED TO PLAINTIFF
7. Plaintiffs Complaint fails to state a cause of action against Defendant
upon which relief may be granted as a matter of law.
8. Plaintiffs claims may be barred and/or limited by the applicable
provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law.
9. No act or omission on the part of Defendant was a substantial contributing
factor in bringing about Plaintiffs injuries and/or damages, all such injuries and/or damages
being expressly denied.
10. Defendant breached no duty of care owed to Plaintiff under the
circumstances described in Plaintiffs Complaint as a matter of law.
11. The motor vehicle accident described in Plaintiffs Complaint was caused
by the negligence, recklessness and/or carelessness on the part of Plaintiff Harold L. Sloop, Jr. in
the operation of a motor vehicle on July 9, 2004 and not by any act or omission on the part of
Defendant.
12. Shand H. Stringhan is an unknown person.
13. Shand H. Stringham owned one of the vehicles involved in the motor
vehicle accident which gives rise to Plaintiffs Complaint.
14. Shand H. Stringham's son, Caleb Stringham, was operating one of the
motor vehicles involved in the accident which gives rise to Plaintiffs Complaint.
WHEREFORE, Defendant Shand H. Stringham demands judgment in his favor and
against Plaintiff Harold L. Sloop, Jr. together with such other relief as this Court shall deem
appropriate.
DATE:
Respectfully submitted,
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOGGIN
BY:
DO D L. CARMELITE, ESQUIRE
DOZD L. CARMELITE, ESQUIRE
I.D. No. 84730
4200 Crums Mill Road, Suite B
Harrisburg, PA 17112
(717) 651-3504
Attorney for Defendant,
Shand H. Stringham
VERIFICATION
The undersigned hereby verifies that the statements in the foregoing Answer with New
Matter are based upon information which has been furnished to counsel by me and information
which has been gathered by counsel in the preparation of the defense of this lawsuit. The
language of the Answer with New Matter is that of counsel and not my own. I have read the
Answer with New Matter, and to the extent that it is based upon information which I have given
to counsel, it is true and correct to the best of my knowledge, information and belief. To the
extent that the contents of the Answer with New Matter are that of counsel, I have relied upon
my counsel in making this verification. The undersigned also understands that the statements
therein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn
falsification to authorities.
BY:
DATE: L2- Q??
HAROLD L. SLOOP, JR., IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 04-6085
SHAND H. STRINGHAM, CIVIL ACTION - LAW
Defendant
CERTIFICATE OF SERVICE
I, Joanne M. Parr, an employee of Marshall, Dennehey, Warner, Coleman & Goggin, do
hereby certify that on this& day of February 2005, served a copy of the foregoing Answer
with New Matter via First Class United States mail, postage prepaid as follows:
Harold L. Sloop, Jr.
428 Chestnut Street
Mt. Holly Springs, PA 17065
1?une M. Parr
4?
Harold L. Sloop Jr. In The Court of Common Pleas
Plaintiff Cumberland County, Pennsylvania
V.
Caleb C. Stringham No. 04-6085
Defendant Civil Action-Law
Complaint
1. Plaintiff Harold L. Sloop Jr. is an adult individual residing at 428
Chestnut Street, Mount Holly Springs Cumberland County
Pennsylvania 17065.
2. Defendant Caleb C. Stringham, last known address 10 Sheraton
Circle, Cumberland County Carlisle, Pennsylvania 17013.
3. Plaintiff Harold L. Sloop Jr., on July 9th, 2004, while driving south
from Carlisle on South Hanover Street, at the speed limit of 35 mph,
entered the intersection at South Hanover Street and Noble Street to
proceed straight through the intersection.
4. Upon entering the intersection, the traffic light turned yellow at
which time the Defendant Caleb C. Stringham turned left onto Noble
Street into the path of the Plaintiff Harold L. Sloop Jr. At which time,
the Plaintiff then struck the Defendant's car just behind the passenger
front side door. Therefore, causing total loss of Plaintiff's car.
5. As a result of the unsafe action of Defendant Caleb C. Stringham's
failure to yield to right of way at the intersection of South Hanover
Street and Noble Street, thus causing the accident, and thus being the
cause of action against the Defendant, upon which relief may be granted
to the Plaintiff as a matter of law.
6. Plaintiff Harold L. Sloop Jr., therefore, respectfully request this
Honorable Court to enter judgment in my favor and against the
Defendant Caleb C. Stringham in the amount of $1,125.00 plus any
other relief that this Honorable Court finds appropriate.
Verification
1, Harold L. Sloop Jr., hereby verify the averments of the foregoing
document are true and correct to my personal knowledge, information
and belief. I understand that false statements herein are made subject
to the penalties of 18 Pa. C. S. Sec. 4904, relating to unsworn
falsification to authorities.
fie - ie Borough of Carlisle
Carlisle Police/Accident Exchange of Information Form
o b? incident (L-h L( i"Ix)) Date 4-`t'<j 4.# LnCat4or>=s_.G1 ANtl(?a _ ??e, 1?,<L
04dad 11
officer' Date'f `t? Badge Time Occurred I <;
Primary Rd ?', . a >nvt h ?`: ?n Speed T/C/D/ # of Lanes
IntersectingRd Speed ?6 T/C/D/ l tic?G? : # of Lanes 1 "I
Unit # l Vehicle Registration L ItA ( y ! " t State
Vehicle Owner s-lA-uc, ?JJ , .1,k-Lu, Address to ` T i1 1. l\(Kl Phone
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Address tt r ?. , _ 1,1 , Phone S/B, AB
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Insurance Co. . r_ Policy #? 1q,9
Co. Phone
Occupant Unit # Name
Address
Phone
Witness(es)
DOB SB A/B
Seat Position
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Unit #
Vehicle Registration
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Vehicle Owner -'?w ? t1.`;?4«a, Address ''k0 4 of)(Iu,l ? nc.__??? (?F<Phonel ?'L'"?fit {;` 01
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Insurance Co. 2 I-a Policy # t` !',f 1f 15 t Co. Phone ? S?w, 22 2' 2
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Occupant Unit # 'I Name QVa'?k,u, kLce,`•` DOB
AddressW l t? k, 1t1r ?, _. k't Phone l 'I _,c " 11 `i -J Seat Position y'o• _.r- ??c?, R
Witness(es)
Additional informabon! f 1- VZ 0 -r f I".?c C"<.*' L•,bd 1. -; c.'??-a1t? l ,. - ?1i< ?.JC X44
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?( .e.., 1, k tAhY)AI<lt cti Y l,.C>l.) ,J YJ tS 1 V'f7 e., 16-, t tat+ 'n c1 U/V.
NOTICE: Copies of accident reports are available by mail only, unless emergency circumstances prevail.
Enclose a check or money order In the amount of $15.60 and send to:
Carlisle Police Department, 53 W. South Street, Carlisle, PA 17013, (717) 243-5252
(Please allow seven (7) days for processing and return of accident form)
P•Reportable ?Non-Reportable
1
White Copy - Reporting Officer Canary Copy - Unit 1 Pink Copy - Unit 2
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I
\5 A\L1AB\nNC\LLPG\182462VMF\21234\00113
HAROLD L, SLOOP, JR.,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
CALEB C. STRINGHAM,
Defendant
NO. 04-6085
CIVIL ACTION - LAW
NOTICE TO PLEAD
TO: Plaintiff, Harold L. Sloop, Jr.
428 Chestnut Street
Mount Holly Spring, PA 17065
You are hereby notified to plead to the enclosed New Matter within twenty (20) days
from service hereof or a default judgment maybe filed against you.
DATE: r 1l ? /C?-r
Respectfully submitted,
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOGGIN
BY: -.
D. CARMELITE, ESQUIRE
I.D. No. 84730
4200 Crams Mill Road, Suite B
Harrisburg, PA 17112
(717) 651-3504
Attorney for Defendant,
Caleb C. Stringhant
V05 A\L1ABVDNC\LLPGA180197VMF\21234V00113
HAROLD L. SLOOP, JR.,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
CALEB C. STRINGHAM,
Defendant
NO. 04-6085
CIVIL ACTION - LAW
ANSWER WITH NEW MATTER OF
DEFENDANT CALEB C. STRINGHAM
TO PLAINTIFF'S COMPLAINT FILED MARCH 9, 2005
1. Admitted in part; denied in part. It is admitted only that Plaintiff is who
he says he is. All remaining allegations of this Paragraph are denied in accordance with
Pa.R.C.P. 1029(c).
2. Admitted.
3. Denied. The averments set forth in this Paragraph are denied in
accordance with Pa.R.C.P. 1029(e).
4. Denied. The averments set forth in this Paragraph are denied in
accordance with Pa.R.C.P. 1029(e).
5. Denied. The averments set forth in this Paragraph are denied in
accordance with Pa.R.C.P. 1029(e).
6. Denied. The averments set forth in this Paragraph are denied in
accordance with Pa.R.C.P. 1029(e).
WHEREFORE, Defendant Caleb C. Stringham demands judgment in his favor and
against Plaintiff Harold L. Sloop, Jr. together with such other relief as this Court shall deem
appropriate.
NEW MATTER DIRECTED TO PLAINTIFF
7. Plaintiffs Complaint fails to state a cause of action against Defendant
upon which relief may be granted as a matter of law.
8. Plaintiffs claims may be barred and/or limited by the applicable
provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law.
9. No act or omission on the part of Defendant was a substantial contributing
factor in bringing about Plaintiffs injuries and/or damages, all such injuries and/or damages
being expressly denied.
10. Defendant breached no duty of care owed to Plaintiff under the
circumstances described in Plaintiffs Complaint as a matter of law.
11. The motor vehicle accident described in Plaintiffs Complaint was caused
by the negligence, recklessness and/or carelessness on the part of Plaintiff Harold L. Sloop, Jr. in
the operation of a motor vehicle on July 9, 2004 and not by any act or omission on the part of
Defendant.
WHEREFORE, Defendant demands judgment in his favor and against Plaintiff Harold L.
Sloop, Jr. together with such other relief as this Court shall deem appropriate.
Respectfully submitted,
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOGGIN
DATE: el/lq 0- BY:
111 DO LD L. CARMELITE, ESQUIRE
I.D. No. 84730
4200 Crums Mill Road, Suite B
Harrisburg, PA 17112
(717) 651-3504
Attorney for Defendant
VERIFICATION
The undersigned hereby verifies that the statements in the foregoing Answer with New
Matter are based upon information which has been furnished to counsel by me and information
which has been gathered by counsel in the preparation of the defense of this lawsuit. The
language of the Answer with New Matter is that of counsel and not my own. I have read the
Answer with New Matter, and to the extent that it is based upon information which I have given
to counsel, it is true and correct to the best of my knowledge, information and belief. To the
extent that the contents of the Answer with New Matter are that of counsel, I have relied upon
my counsel in making this verification. The undersigned also understands that the statements
therein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom
falsification to authorities.
BY: ( 2 E12 / G ??
CALEB STRINGHAI
DATE:
HAROLD L. SLOOP, JR., IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 04-6085
SHAND H. STRINGHAM, CIVIL ACTION - LAW
Defendant
CERTIFICATE OF SERVICE
I, Joanne M. Parr, an employee of Marshall, Deimehey, Warner, Coleman & Goggin, do
hereby certify that on this ? day of April 2005, served a copy of the foregoing Answer with
New Matter of Defendant Caleb C. Stringham to Plaintiffs Complaint filed March 9, 2005 via
First Class United States mail, postage prepaid as follows:
Harold L. Sloop, Jr.
428 Chestnut Street
Mt. Holly Springs, PA 17065
C,
Jo e M. Parr
?.., n? C)
? ,r ?7
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P-;? _
. ?r
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C.7?;. 7
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Lt? O
`,?
HAROLD L. SLOOP, JR.,
Plaintiff
V.
CALEB C. STRINGHAM,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-6085
CIVIL ACTION - LAW
MOTION OF DEFENDANT, CALEB C. STRINGHAM, TO
COMPEL DISCOVERY RESPONSES FROM PLAINTIFF
Defendant, Caleb C. Stringham, (hereinafter "Defendant"), by and through his counsel,
Marshall, Dennehey, Warner, Coleman and Goggin, hereby moves this Honorable Court to
compel Pro Se Plaintiff, Harold L. Sloop, Jr., (hereinafter "Plaintiff') to respond to Defendant's
Interrogatories and Request for Production of Documents and in support thereof asserts the
following:
Plaintiff, Harold L. Sloop, Jr. is proceeding Pro Se.
2. On or about December 15, 2004, Plaintiff instituted this action by filing a Notice
of Complaint in the Court of Common Pleas of Cumberland County, Pennsylvania and captioned
Harold L. Sloop, Jr. v. Shand H. String-ham.
3. On or about December 23, 2004, Defendant, Shand H. Stringham, filed
Preliminary Objections to Plaintiffs Notice of Complaint.
4. On or about January 18, 2005, Defendant, Shand H. Stringham, filed a Brief in
support of his Preliminary Objections to Plaintiffs Notice of Complaint.
5. On or about February 7, 2005, by way of Court Order, Defendant's Preliminary
objections were granted, and Plaintiff was given twenty (20) days in which to file an Amended
Complaint.
6. On or about February 9, 2005, Plaintiff filed a Complaint against Defendant,
Shand H. Stringham.
7. On or about March 1, 2005, Defendant, Shand H. Stringham, filed an Answer
with New Matter to Plaintiff s Complaint, pointing out to this Pro Se Plaintiff that Shand
Stringham was the incorrect Defendant.
On or about March 9, 2005, Plaintiff filed a Complaint against Defendant, Caleb
C. Stringham.
9. On or about April 13, 2005, Defendant, Caleb C. Stringham, filed an Answer with
New Matter to Plaintiffs Complaint.
10, On or about May 6, 2005, Defendant, Caleb C. Stringham, served Plaintiff with
interrogatories and Request for Production of Documents. (A true and correct copy of
Defendant's Interrogatories and Request for Production of Documents are attached hereto as
Exhibit "A".)
11. On or about July 7, 2005, counsel for Defendant, Caleb C. Stringham, reminded
Plaintiff that he had not responded to written discovery and asked Plaintiff to respond to
Defendant's Interrogatories and Request for Production of Documents by Friday, July 22, 2005
in order to avoid the filing of a Motion to Compel Discovery. (A true and correct copy of this
correspondence is attached hereto as Exhibit "B".)
2
12. To date, Plaintiff has failed to respond, either by Answer or Objection, to
Defendant's Interrogatories and Request for Production of Documents.
13. The Pennsylvania Rules of Civil Procedure, specifically Rules 4006 and 4009.12,
require the party upon whom Interrogatories and Request for Production of Documents is served
to file Answers and/or Objections within thirty (30) days from the receipt of said discovery
requests.
14. Under the Pennsylvania Rules of Civil Procedure, Plaintiff should have responded
to Defendant's Interrogatories and Request for Production of Documents on or about June 6,
2005.
15. Plaintiff has failed to answer or otherwise respond to Defendant's discovery
requests and hence is in violation of the foregoing Rules of Civil Procedure.
16. Therefore, Defendant, Caleb C. Stringham, requests that this Court enter an Order
compelling Plaintiff to provide full and complete Answers to the Interrogatories and to provide
full and complete Responses to the Request for Production of Documents at the risk of such
further sanction in the event of further non-compliance as this Court may deem appropriate.
17. Defendant believes that Plaintiff does not concur with this Motion due to
Plaintiffs failure to respond to counsel's July 7, 2005 correspondence attached hereto as Exhibit
"B."
WHEREFORE, Defendant, Caleb C. Stringham, hereby moves this Honorable Court to
issue an Order compelling Plaintiff to respond to Defendant's Interrogatories and Request for
Production of Documents within twenty (20) days or suffer sanctions upon further application to
this Court.
DATE: ? , ),)" , O'
Respectfully submitted,
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOG
BY: %6k ?- -
D01q'ALD L. CARMELITE, ESQUIRE
I.D. No. 84730
4200 Crams Mill Road, Suite B
Harrisburg, PA 17112
(717) 651-3504
Attorney for Defendant,
Caleb C. Stringham
HAROLD L. SLOOP, JR.,
Plaintiff
V.
CALEB C. STRINGHAM,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-6085
CIVIL ACTION - LAW
INTERROGATORIES OF DEFENDANT,
CALEB C. STRINGHAM, ADDRESSED TO PLAINTIFF
Defendant, Caleb C. Stringham, by his counsel, Marshall, Dennehey, Warner, Coleman
& Goggin, propounds the following Interrogatories upon the Plaintiff, Harold L. Sloop, Jr., to be
answered under oath, within thirty (30) days after service hereof.
Definitions. -- The following definitions are applicable to these interrogatories:
"Document" means any written, printed, typed, or other graphic matter of any kind or
nature, however produced or reproduced, including photographs, microfilms, phonographs, video
and audio tapes, punch cards, magnetic tapes, discs, data cells, drums, and other data
compilations from which information can be obtained.
"Identify" or "Identity" means when used in reference to --
(1) A natural person, his or her:
(a) Full name; and
(b) Present or last known residence and employment address (including street
name and number, city or town, and state or county);
(2) A document:
(a) Its description (e.g., letter, memorandum, report, etc.), title, and date;
1 ?
e
(b) Its subject matter;
(c) Its author's identity;
(d) Its addressee's identity;
(e) Its present location; and
(f) Its custodian's identity;
(3) An oral communication:
(a) Its date;
(b) The place where it occurred;
(c) Its substance;
(d) The identity of the person who made the communication;
(e) The identity of each person to whom such communication was made; and
(f) The identity of each person who was present when such communication
was made;
(4) A corporate entity:
(a) Its full corporate name;
(b) Its date and place of incorporation, if known; and
(c) Its present address and telephone number;
(5) Any other context: A description with sufficient particularity that the thing may
thereafter be specified and recognized, including relevant dates and places, and
the identification of relevant people. entities, and documents.
"Incident" or "accident" means the occurrence that forms the basis of a cause of action or
claim for relief set forth in the complaint or similar pleading.
2
"Person" means a natural person, partnership, association, corporation, or governmental
agency.
Instructions. -- The following instructions are applicable to these interrogatories:
(1) Duty to answer. -- The interrogatories are to be answered in writing, verified, and
served upon the undersigned within thirty (30) days of their service on you. Objections must be
signed by the attorney making them. In your answers, you must furnish such information as is
available to you, your employees, representatives, agents, and attorney. Your answers must be
supplemented and amended as required by the Pennsylvania Rules of Civil Procedure.
(2) Claim of privilege. -- With respect to any claim of privilege or immunity from
discovery, you must identify the privilege or immunity asserted and provide sufficient
information to substantiate the claim.
(3) Option to produce documents. -- In lieu of identifying documents in response to
these interrogatories, you may provide copies of such documents with appropriate references to
the corresponding interrogatories.
These Interrogatories shall be deemed to be continuing and any information secured
subsequent to the filing of answers, which would have been includable in the answers had it been
known or available, shall be supplied by supplemental answers as soon as such information
becomes known or available, and in all events, prior to the trial of this action, pursuant to Pa.
R.C.P. 4007.3.
3
INTERROGATORIES
State:
(a) Your full name;
(b) The name of your spouse at the time of the accident and the date and place
of your marriage to such spouse;
(c) The address of your present residence and the address of each other
residence which you have had during the past five years;
(d) Your present occupation and the name and address of your employer;
(e) Date of your birth;
(f) Your Social Security number;
(g) Your military service and positions held, if any; and
(h) The schools you have attended and the degrees or certificates awarded, if
any.
4
2. If you are covered by any type of insurance, including any excess or umbrella
insurance, that might be applicable to the incident in this matter, state the following with respect
to each such policy:
(a) The name of the insurance carrier which issued the policy;
(b) The named insured under each policy and the policy number of each
policy;
(c) The type(s) and effective date(s) of each policy;
(d) The amount of coverage provided for injury to each person, for each
occurrence, and in the aggregate for each policy; and
(e) Each exclusion, if any, in the policy which is applicable to any claim
thereunder and any reasons, if any, why you or the carrier claim the
exclusion is applicable.
5. State with particularity the factual basis for each claim or defense you are
asserting in this case.
6. Witnesses. -
(a) Identify each person who
(1) Was a witness to the incident through sight or hearing and/or
(2) Has knowledge of facts concerning the happening of the incident
or conditions or circumstances at the scene of the incident prior to,
at the time of, or after the incident.
(b) With respect to each person so identified, state that person's exact location
and activity at the time of the incident.
9
If you know of anyone that has given any statement (as defined by the Rules of
Civil Procedure) concerning this action or its subject matter, state:
(a) The identity of such person;
(b) When, where, by whom, and to whom each statement was made, and
whether it was reduced to writing or otherwise recorded; and
(c) The identity of any person who has custody of any such statement that was
reduced to writing or otherwise recorded.
10
8. Identify the documents (except reports of experts subject to Pa.R.C.P. No. 4003.5)
which describe the incident or the cause thereof.
11
9. If you have been charged with any criminal violations as a result of the incident,
describe the charges and identify all documents filed or served in connection with those charges.
12
10. If you know of the existence of any photographs, motion pictures, video
recordings, maps, diagrams, or models relevant to the incident, state:
(a) The nature or type of such item;
(b) The date when such item was made;
(c) The identity of the person that prepared or made each item; and
(d) The subject that each item represents or portrays.
13
11. If you, or someone not an expert subject to Pa.R.C.P. No. 4003.5, conducted any
investigations of the incident, identify:
(a) Each person, and the employer of each person, who conducted any
investigation(s); and
(b) All notes, reports or other documents prepared during or as a result of the
investigation(s) and the persons who have custody thereof.
14
12. Identify each person you intend to call as a non-expert witness at the trial of this
case, and for each person identified state your relationship with the witness and the substance of
the facts to which the witness is expected to testify.
15
13. Identify each expert you intend to call as a witness at the trial of this matter, and
for each expert state:
(a) The subject matter about which the expert is expected to testify; and
(b) The substance of the facts and opinions to which the expert is expected to
testify and a summary of the grounds for each opinion. (You may file as
your answer to this interrogatory the report of the expert or have the
interrogatory answered by our expert.)
16
14. Identify all exhibits that you intend to use at the trial of this matter and state
whether they will be used during the liability or damages portions of the trial,
17
15. If you consumed any alcoholic beverage, sedative, tranquilizer, marijuana,
cocaine, hashish, or other drug, medicine or pill during the eight hours immediately preceding
the incident, state:
(a) The nature, amount, and type of item consumed;
(b) The amount of time over which consumed;
(c) The identity of any and all persons who have any knowledge as to the
consumption of those items; and
(d) The identity of the physician or medical practitioner or other person who
gave, purchased or prescribed any of said items, if any.
18
16. If you were under any physical or mental disability at the time of the incident,
explain the disability.
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOGGIN
DATE: S? d s BY:
DO D L. CARMELITE, ESQUIRE
I.D. No. 84730
4200 Crums Mill Road, Suite B
Harrisburg, PA 17112
(717) 651-3504
Attorney for Defendant
Caleb C. Stringham
19
HAROLD L. SLOOP, JR., : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 04-6085
CALEB C. STRINGHAM, CIVIL ACTION -LAW
Defendant
CERTIFICATE OF SERVICE
L Susan M. Williams, an employee of Marshall, Dennehey, Warner, Coleman & Goggin,
do hereby certify that on this V'?' day of May, 2005, served a copy of the foregoing Request
for Production of Documents of Defendant, Caleb C. Stringham, Addressed to Plaintiff, via First
Class United States mail, postage prepaid as follows:
Harold L. Sloop, Jr.
428 Chestnut Street
Mt. Holly Springs, PA 17065
SUSAN M. WILLIAMS
HAROLD L. SLOOP, JR.,
Plaintiff
V.
CALEB C. STRINGHAM,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-6085
CIVIL ACTION - LAW
REQUEST FOR PRODUCTION OF DOCUMENTS OF
DEFENDANT, CALEB C. STRINGHAM, ADDRESSED TO PLAINTIFF
PLEASE TAKE NOTICE that you are hereby requested to produce for inspection and
other purposes, including copying, pursuant to the Pennsylvania Rules of Civil Procedure, at the
office of the counsel for the requesting party, or at such other location as may be mutually
agreeable between counsel for you and counsel for the requesting party, not less than thirty (30)
days after service of these requests, documents herein cited. The word "document" or
"documents" as herein used includes but is not limited to photographs, video tapes, drawings,
reports, statements and memoranda, as well as all other documents as defined in the Rules.
Copies of all statements, memoranda, summaries of other writings, documents,
diagrams and pictures obtained from your investigation or your insurance company's
investigation into the incident involved.
2. All documents in your possession, custody or control prepared in anticipation of
litigation or trial of this case.
3. To the extent that you have not already provided the same in response to previous
requests herein, all statements obtained from any witnesses or memoranda of conversations with
witnesses or recordings of witnesses' statements, memoranda, or recordings made by parties to
this lawsuit or their representative.
4. To the extent not already provided in response to previous requests herein, all
statements made by any party to this action, including written statements signed or otherwise
adopted or approved by the person making it or stenographic, mechanical, electrical, or other
recording or transcription thereof, which is a substantially verbatim recital of an oral statement
and contemporaneously recorded, as allowed by Pennsylvania Rules of Civil Procedure No.
4003.4.
5. To the extent that you have not already provided the same, copies of all records,
documents and memoranda, which have any bearing upon the matters alleged against the
requesting party or upon the responsibility of the requesting party for the matters alleged against
the requesting party.
6. To the extent not already provided, all reports of those experts who are to be
called by you as witnesses at trial, which reports made or secured by you in connection with your
investigation of the matters relating to this lawsuit.
7. To the extent not already provided, copies of all experts' reports made or secured
by you in connection with your investigation of the matters relating to this lawsuit.
8. To the extent not already provided, all photographs, diagrams, maps, surveys,
plans and models of the site of the incident in question that are in your possession.
9. To the extent not already provided, all documents containing the names and
addresses of witnesses or potential witnesses with the exception of material described above,
specifically correspondence privileged by the above rules.
2
10. To the extent not already provided, copies of all exhibits which you intend to
offer into evidence at the trial of this matter.
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOGGIN
DATE: j 0.5r BY:
DO L. C ELITE, ESQUIRE
I.D. No. 84730
4200 Crums Mill Road, Suite B
Harrisburg, PA 17112
(717) 651-3504
Attorney for Defendant
Caleb C. Stringham
HAROLD L. SLOOP, JR., IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v, : NO. 04-6085
CALEB C. STRINGHAM, CIVIL ACTION -LAW
Defendant
CERTIFICATE OF SERVICE
I, Susan M. Williams, an employee of Marshall, Dennehey, Warner, Coleman & Goggin,
do hereby certify that on this L+' day of May, 2005, served a copy of the foregoing Request
for Production of Documents of Defendant, Caleb C. Stringham, Addressed to Plaintiff, via First
Class United States mail, postage prepaid as follows:
Harold L. Sloop, Jr.
428 Chestnut Street
Mt. Holly Springs, PA 17065
- 2UAL
SUSAN M. WILLIAMS
' • A REGIONAL ?ENSE LITIGATION LAw FIRM
MARSHALL, DENNEHEY, WARNER, COLEMAN 8 GOGGIN Pa,mitown
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Bethlehem
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Bile
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A P It O P E! S I G N A L C O g P O R A T 1 0 N vvw.marshau&nneheyxom Harrisburg
Nutria.
Philadelphia
4200 Crams Mill Road, Suite B • Harrisburg, PA 17112 Pittsburgh
Plymouth Meeting
(717) 651-3500 • Fax (717) 651-9630 se„n,im
St.. vapor,
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Cherry EBII
Rou, and
Direct Dial: 717-651-3504 ° m° n
Email: dearmelite@mdwcg.com 0M
PLOp,DA
Pt. Lauderdale
JacEaonvJle
July 7, 2005 T mpdo
Harold L. Sloop, Jr.
428 Chestnut Street
Mt. Holly Springs, PA 17065
Re: Harold L. Sloop, Jr. v. Caleb C. Stringham
CCP (Cumberland County),No.: 04-6085
Our File No: 21234-00113
Dear Mr. Sloop:
On or about May 3, 2005, I forwarded to you Defendant's Interrogatories and Request for Production of
Documents with regard to the above-referenced matter.
According to the Pennsylvania Rules of Civil Procedure, you are required to provide written responses
to the Interrogatories and Request for Production of Documents within thirty (30) days of receipt of the
discovery requests. To date, I have not received your written responses to Defendant's discovery requests.
Please provide me with written responses by Friday, July 22, 2005, or I will be filing a Motion to Compel your
responses to Defendant's Interrogatories and Request for Production of Documents with the Court.
Your attention to this matter is appreciated.
VeV
DO ARM
ELITE
DLC:smw
HAROLD L. SLOOP, JR., IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 04-6085
CALEB C. STRINGHAM, CIVIL ACTION -LAW
Defendant
CERTIFICATE OF SERVICE
I, Susan M. Williams, an employee of Marshall, Dennehey, Warner, Coleman & Goggin,
do hereby certify that on this"-day of August, 2005, served a copy of the foregoing Motion
of Defendant, Caleb C. Stringham, to Compel Discovery Responses from Plaintiff, via First
Class United States mail, postage prepaid as follows:
Harold L. Sloop, Jr.
428 Chestnut Street
Mt. Holly Springs, PA 17065
o,)j1 r?ktt 1 I ? ? W l?Gl??
SUSAN M. WILLIAMS
HAROLD L. SLOOP, JR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
CALEB C. STRINGHAM, :
Defendant NO. 04-6085 CIVIL TERM
ORDER OF COURT
AND NOW, this 26"' day of August, 2005, upon consideration of the Motion of
Defendant, Caleb C. Stringham, To Compel Discovery Responses from Plaintiff, a Rule
is hereby issued upon Plaintiff to show cause why the relief requested should not be
granted.
RULE RETURNABLE within 20 days of service.
BY THE COURT,
Harold L. Sloop, Jr.
428 Chestnut Street
Mount Holly Springs, PA 17065
Plaintiff, pro se
Donald L. Carmelite, Esq.
4200 Crums Mill Road
Suite B
Harrisburg, PA 17112
Attorney for Defendant
s. 9 of
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3NU a0
?rr
HAROLD L. SLOOP, JR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
CALEB C. STRINGHAM, :
Defendant NO. 04-6085 CIVIL TERM
ORDER OF COURT
AND NOW, this 26`h day of August, 2005, upon consideration of the Motion of
Defendant, Caleb C. Stringham, To Compel Discovery Responses from Plaintiff, a Rule
is hereby issued upon Plaintiff to show cause why the relief requested should not be
granted.
RULE RETURNABLE within 20 days of service.
BY THE COURT,
Harold L. Sloop, Jr.
428 Chestnut Street
Mount Holly Springs, PA 17065
Plaintiff, pro se
Donald L. Carmelite, Esq.
4200 Crums Mill Road
Suite B
Harrisburg, PA 17112
Attorney for Defendant
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HAROLD L. SLOOP, JR., IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 04-6085
CALEB C. STRINGHAM, CIVIL ACTION - LAW
Defendant
MOTION FOR SANCTIONS OF
DEFENDANT, CALEB C. STRINGHAM
Defendant, Caleb C. Stringham, by and through his counsel, Marshall, Dennehey,
Warner, Coleman & Goggin, hereby moves this Honorable Court to Sanction Plaintiff for failure
to respond to Defendant's discovery requests and comply with this Honorable Court's August 26,
2005, and in support thereof assert the following:
On or about May 6, 2005, Defendant served Plaintiff with Interrogatories and
Request for Production of Documents.
2. On or about August 24, 2005, Defendant filed with the Cumberland County Court
of Common Pleas a Motion to Compel Discovery Responses from Plaintiff, along with a
proposed Order.
3. On or about August 24, 2005, Defendant served Plaintiff with a copy of the
Motion to Compel Discovery Responses from Plaintiff, along with the proposed Order.
4. On August 26, 2005, this Honorable Court issued a Rule upon Plaintiff to Show
Cause why the relief requested by Defendant should not be granted.
On September 1, 2005, a copy of the executed Rule to Show Cause was served
upon Plaintiff.
6 Plaintiff has failed to respond to the Rule to Show Cause why the relief requested
by Defendant should not be granted, and more than twenty (20) days have passed since the Order
was executed.
Concurrent with the filing of this Motion, Defendant filed a Motion to Make Rule
Absolute, which Rule was issued by the Honorable J. Wesley Oler, Jr. on August 26, 2005 and
pertained to Defendant's Motion to Compel Discovery Responses from Plaintiff.
8. Defendant anticipates that this Honorable Court will grant his Motion to Make
Rule Absolute and as such, seeks the sanctioning of Plaintiff as requested in his Motion to
Compel Discovery Responses from Plaintiff.
WHEREFORE, Defendant, Caleb C. Stringham, respectfully requests that this Honorable
Court grant his Motion for Sanctions and bar Plaintiff from introducing any evidence that would
have been responsive to Defendant's discovery requests.
Respectfully submitted,
DATE:
MARSHALL, D HEY, WARNER,
COLEMAN O GIN
S
bbl rg?O BY:
DO LD L. CARMELITE, ESQUIRE
I.D. No. 84730
4200 Crums Mill Road, Suite B
Harrisburg, PA 17112
(717) 651-3504
Attorney for Defendant
Caleb C. Stringham
2
HAROLD L. SLOOP, JR., IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 04-6085
CALEB C. STRINGHAM, CIVIL ACTION -LAW
Defendant
CERTIFICATE OF SERVICE
I, Susan M. Williams, an employee of Marshall, Dennehey, Warner, Coleman & Goggin,
do hereby certify that on this )?+k day of October, 2005, served a copy of the foregoing Motion
for Sanctions of Defendant, Caleb C. Stringham, via First Class United States mail, postage
prepaid as follows:
Harold L. Sloop, Jr.
428 Chestnut Street
Mt. Holly Springs, PA 17065
&a I -1. ,4)a)
SUSAN M. WILLIAMS
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HAROLD L. SLOOP, JR.,
Plaintiff
V.
CALEB C. STRINGHAM,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-6085
CIVIL ACTION - LAW
MOTION OF DEFENDANT CALEB C.
STRINGHAM, TO MAKE RULE ABSOLUTE
On or about May 6, 2005, Defendant served Plaintiff with Interrogatories and
Request for Production of Documents.
2. On or about August 24, 2005, Defendant filed with the Cumberland County Court
of Common Pleas a Motion to Compel Discovery Responses from Plaintiff, along with a
proposed Order.
3. On or about August 24, 2005, Defendant served Plaintiff with a copy of the
Motion to Compel Discovery Responses from Plaintiff, along with the proposed Order.
4. On August 26, 2005, this Honorable Court issued a Rule upon Plaintiff to Show
Cause why the relief requested by Defendant should not be granted.
5. On September 1, 2005, a copy of the executed Rule to Show Cause was served
upon Plaintiff. (A true and correct copy of this correspondence is attached hereto and marked as
Exhibit "A.")
Plaintiff has failed to respond to the Rule to Show Cause why the relief requested
by Defendant should not be granted, and more than twenty (20) days have passed since the Order
was executed.
Defendant respectfully request that this Honorable Court make the rule absolute.
WHEREFORE, Defendant, Caleb C. Stringham, respectfully requests that this Honorable
Court grant Defendant's Motion to Compel Discovery Responses from Plaintiff.
Respectfully submitted,
MARSHALL, DENNEHEY, WARNER,
COLEMAN & COGGIN
DATE: BY:
DO ALD L. CARMELITE, ESQUIRE
I.D. No. 84730
4200 Crums Mill Road, Suite B
Harrisburg, PA 17112
(717) 651-3504
Attorney for Defendant
Caleb C. Stringham
?`
A REGIONAL
MARSHALL, DENNEHEY, WARNER, COMIAN 999GINj
A Pno a es s 1 o N.L Co xPo B ATt 0N www.mmshaff&nnehey.cotn
4200 Crums Mill Road, Suite B a Harrisburg, PA 17112
(717) 651-3500 • Fax (717) 651-9630
Direct Dial: 717-651-3504
Email: dcarmelite@mdwcg.com
September 1, 2005
Harold L. Sloop, Jr.
428 Chestnut Street
Mt. Holly Springs, PA 17065
Re: Harold L. Sloop, Jr, v. Caleb C. Stringham
CCP (Cumberland County) No.: 04-6085
Our File No: 21234-00113
Dear Mr. Sloop:
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Harrisburg
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Plymouth Meering
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Enclosed please find an Order of Court regarding my Motion to Compel Discovery Responses from you
in the above-referenced matter.
Thank you for your attention to this matter.
Very y ours,
DO FALD L. CARMELITE
DLC:smw
)TENst LITIGATION LAW FIRM
Enclosure
HAROLD L. SLOOP, JR., IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 04-6085
CALEB C. STRINGHAM, CIVIL ACTION -LAW
Defendant
CERTIFICATE OF SERVICE.
I, Susan M. Williams, an employee of Marshall, Dennehey, Warner, Coleman & Goggin,
do hereby certify that on this gl day of October, 2005, served a copy of the foregoing Motion
of Defendant, Caleb C. Stringham, to Make Rule Absolute, via First Class United States mail,
postage prepaid as follows:
Harold L. Sloop, Jr.
428 Chestnut Street
Mt. Holly Springs, PA 17065
SUSAN M. WILLIAMS
= o
r-D
r.?
HAROLD L. SLOOP, JR., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
11 Wesley Oler; Jr., J.
I
CALEB C. STRINGHAM,
Defendant NO. 04-6085 CIVIL TERM
ORDER OF COURT
AND NOW, this 27th day of October, 2005, upon consideration of Defendant's
motion to make rule absolute and motion for sanctions, it is ordered and directed as
follows:
1. With respect to the motion for sanctions, the motion is denied; and
2. With respect to the motion to make the rule absolute, the motion is
granted, the rule issued on August 26, 2005 is made absolute, and Plaintiff
is directed to respond, without objection, to Defendant's Interrogatories and
Request for Production of Documents, within twenty (20) days of the date
of this order.
BY THE COURT,
Xrold L. Sloop, Jr.
428 Chestnut Street
Mount Holly Springs, PA 17065
Plaintiff, pro se
onald L. Carmelite, Esq.
Suite B
4200 Crams Mill Road
Harrisburg, PA 17112
Attorney for Defendant
C w?'
? ,.
?
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?
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,
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,t\ ___
_-
HAROLD L. SLOOP, JR.,
Plaintiff
V.
CALEB C. STRINGHAM,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-6085
CIVIL ACTION - LAW
MOTION FOR SANCTIONS OF
DEFENDANT, CALEB C. STRINGHAM
Defendant. Caleb C. Stringham, by and through his counsel, Marshall, Dennehey,
Warner, Coleman & Goggin, hereby moves this Honorable Court to Sanction Plaintiff for failure
to respond to Defendant's discovery requests and comply with this Honorable Court's August 26,
2005, and in support thereof assert the following:
On or about May 6, 2005, Defendant served Plaintiff with Interrogatories and
Request for Production of Documents.
2. On or about August 24, 2005, Defendant filed with 'the Cumberland County Court
of'( onnuon Pleas a Motion to Compel Discovery Responses from Plaintiff, along with a
proposed Order.
3. On or about August 24, 2005, Defendant served Plaintiff with a copy of the
Motion to Compel Discovery Responses from Plaintiff, along with the proposed Order.
4. On August 26, 2005, this Honorable Court issued a Rule upon Plaintiff to Show
Cause why the relief requested by Defendant should not be granted.
5. On September 1, 2005, a copy of the executed Rule to Show Cause was served
upon Plaintiff.
6 Plaintiff has failed to respond to the Rule to Show Cause why the relief requested
by Defendant should not be granted, and more than twenty (20) days have passed since the Order
was executed.
7 On October 21, 2005, Defendant filed a Motion to Make Rule Absolute, which
Rule was issued by the Honorable J. Wesley Oler, Jr. on August 26, 2005 and pertained to
Defendant's Motion to Compel Discovery Responses from Plaintiff.
8. On October 27, 2005, this Honorable Court issued an Order granting Defendant's
Motion to Make Rule Absolute and directing Plaintiff to respond, without objection, to
Defendant's Interrogatories and Request for Production of Documents within twenty (20) days of
the date of the Order.
9. Plaintiff has failed to respond to this Honorable Court's October 27, 2005 Order.
10. Defendant has incurred attorney's fees in the amount of $232.50 associated with
the filing of the Motion to Compel Discovery Responses from Plaintiff. (A true and correct copy
of a redacted Invoice for attorney's fees is attached hereto as Exhibit "A").
11. Defendant has incurred attorney's fees in the amount of S 197.00 associated with
the Filing of the Motion to Make Rule Absolute. (A true and correct copy of a redacted Invoice
for attorney's fees is attached hereto as Exhibit "B").
12. Defendant has incurred attorney's fees in the amount of $96.50 associated with the
tiling of the Motion for Sanctions. (A true and correct copy of a redacted Invoice for attorney's
fees is attached hereto as Exhibit "C")
WHEREFORE, Defendant, Caleb C. Stringham, respectfully requests that this Honorable
Court grant his Motion for Sanctions, bar Plaintiff from introducing any evidence that would
2
have been responsive to Defendant's discovery requests, and award attorney's fees and costs
associated with the filing of this Motion for Sanctions, as well as the Motion to Compel
Discovery Responses and Motion to Make Rule Absolute, in the amount of $526.00.
Respectfully submitted,
MARSHALL, DENNEHEY, WARNER,
COL
DATE: BY:
4200 Crums Mill Road, Suite B
Harrisburg, PA 171 12
(717) 651-3504
Attorney for Defendant
Caleb C. Stringham
I.D. No. 84730
G1f??? ?
??
DATE.... PTTY DESCRIPTION ..............
09/01/05 729 CORRESPONDENCE TO HAROLD
SLOOP REGARDING ORDER OF
COURT REGARDING MOTION TO
COMPEL DISCOUERY RESPONS
ES
09/30/05 729 RECEIPT AND REUIEWED ORDE
R OF COURT FROM JUDGE OLE
R ISSUING RULE UPON PLAIN
TIFF TO SHOW CAUSE WHY MO
TION TO COMPEL DISCOVERY
RESPONSES SHOULD NOT BE G
RANTED
VALUE
13.00
6.50
DATE.... ATTY DESCRIPTION ..............
AND LISTING FOR ARGUMENT
08/22/05 729 DRAFTED REVISIONS TO DEFE
NDANT'S MOTION TO COMPEL
DISCOVERY RESPONSES PROM
PLAINTIFF
08/22/05 729 CORRESPONDENCE TO CUMBERL
AND COUNTY PROTHONOTARY R
E= FILING MOTION TO COMPE
L DISCOVERY RESPONSES FRO
M PLAINTIFF
08/18/05 729 REUIEW AND ANALYSIS OF FI
LE MATERIALS INCLUDING PL
EADINGS AND CORRESPONDENC
E IN ORDER TO DRAFT ADDIT
IONAL ALLEGATIONS FOR MOT
ION TO COMPEL DISCOVER RE
VALUE
26.00
13.00
26.00
DATE.... ATTY DESCRIPTION____________
SPONSES RE: FILE
08/18/05 729 DRAFTED ADDITIONAL ALLEGA
TIONS TO DEFENDANT'S MOTI
ON TO COMPEL DISCOVERY RE
SPONSES
08/18/05 729 REUIEWED CUMBERLAND COUNT
Y RULES OF COURT RE: FILI
NG MOTION TO COMPEL DISCO
VERY RESPONSES
08/09/05 R42 REUIEWED MOTION TO COMPEL
DRAFTED BY PARALEGAL
08/09/05 729 CONFERENCE WITH DONALD L.
CARMELITE RE: MOTION TO
UALUE
32.50
13.00
37.50
6.SO
DATE.... ATTY DESCRIPTION ..............
COMPEL DISCOUERY RESPONSE
S
08/08/05 729 REVIEW AND ANALYSIS OF FI
LE INFORMATION IN ORDER T
0 LOCATE AND IDENTIFY DOC
UMENTS AND INFORMATION NE
CESSARY TO DRAFT A MOTION
TO COMPEL DISCOVERY RESP
ONSES
08/08/05 729 DRAFTED DEFENDANT'S MOTIO
N TO COMPEL DISCOUERY RES
PONSES FROM PLAINTIFF
08/08/05 729 DRAFTED ORDER FOR MOTION
TO COMPEL DISCOUERY RESPO
NSES FROM PLAINTIFF
UALUE
19.50
32.50
6.50
I + ?F
DATE.... ATTY DESCRIPTION ..............
11/01/05 A42 RECEIPT AND REVIEWED JUDG
E OLER'S ORDER GRANTING M
OTION TO MAHE RULE ABSOLU
TE; DENY MOTION FOR SANCT
IONS
10/18/05 729 DRAFTED DEFENDANT'S MOTIO
N TO MAHE RULE ABSOLUTE R
E: ORDERING PLAINTIFF TO
RESPOND TO DEFENDANT'S DI
SCOUERY REQUESTS
10/18/05 729 DRAFTED PROPOSED ORDER RE
: DEFENDANT'S MOTION TO M
VALUE
25.00
58.50
13.00
DATE.... ATTY DESCRIPTION ..............
10/18/05 729 CORRESPONDENCE TO CUMBERL
AND COUNTY PROTHONOTARY R
E: FILING DEFENDANT'S MOT
ION TO MAHE RULE ABSOLUTE
AND MOTION FOR SANCTIONS
10/17/05 A42 REVIEWED MOTION TO MAHE R
ULE ABSOLUTE AND MOTION T
UALUE
13.00
62.50
DATE.... ATTY DESCRIPTION .............. VALUE
0 COMPEL DISCOVERY BY PAR
ALEGAL REGARDING PLAINTIF
FS' FAILURE TO RESPOND TO
DISCOVERY REQUESTS
10/10/05 A42 TELEPHONE CALL TO JUDGE 0 25.00
YLER'S CHAMBERS REGARDING
OUTSTANDING MOTION TO CO
MPEL
I?FXlv; 6 1)'7(- L
DATE.... ATTY DESCRIPTION ..............
11/29/05 A42 REVIEWED MOTION FR SANCTI
ONS PREPARED BY PARALEGAL
11/29/05 729 DRAFTED ORDER RE: MOTION
FOR SANCTIONS
11/29/05 729 DRAFTED DEFENDANT'S MOTIO
N FOR SANCTIONS AGAINST P
LAINTIFF FOR FAILURE TO A
NSWER DISCOUERY REQUESTS
VALUE
25.00
13.00
58.50
HAROLD L. SLOOP, JR., IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 04-6085
CALEB C. STRINGHAM, CIVIL ACTION - LAW
Defendant
CERTIFICATE OF SERVICE
I, Susan M. Williams, an employee of Marshall, Dennehey, Warner, Coleman & Coggin,
do hereby certify that on this p p+K day of December, 2005, served a copy of the foregoing
Motion for Sanctions of Defendant, Caleb C. Stringham, via First Class United States mail,
postage prepaid as follows:
Harold L. Sloop, .Ir.
428 Chestnut Street
Mt. Holly Springs, PA 17065
SUSAN M. WILLIAMS
;:',
HAROLD L. SLOOP, JR., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
CALEB C. STRINGHAM,
Defendant NO. 04-6085 CIVIL TERM
ORDER OF COURT
AND NOW, this 16th day of December, 2005, upon consideration of Defendant's
Motion for Sanctions, a hearing is scheduled for Wednesday, the 291h day of March,
2006, at 2:30 p.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle,
Pennsylvania.
Harold L. Sloop, Jr.
428 Chestnut Street
Mount Holly Springs, PA 17 65
Plaintiff, pro se
Donald L. Carmelite, Esq.
Suite B
4200 Crums Mill Road
Harrisburg, PA 17112
Attorney for Defendant
J.
:rc
BY THE COURT,
OS 14J 1 ? 0710UHU
{
HAROLD L. SLOOP, JR.,
Plaintiff
v
CALEB C. STRINGHAM,
Defendant
IN RE
IN THE COURT OF COMMON PLEAS OF
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
04-6085 CIVIL TERM
MOTION FOR SANCTIONS
ORDER OF COURT
AND NOW, this 29th day of March, 2006, upon
consideration of Defendant's Motion for Sanctions in the
above-captioned matter, and following a hearing, and the
Court finding that the Plaintiff has not responded to the
interrogatories served upon him by Defendant, but claims
that he did not receive the interrogatories, and Defendant's
counsel having in open court now served the interrogatories
upon him, it is ordered and directed as follows:
1. Plaintiff is directed to pay attorney's
fees in connection with this motion to Defendant's counsel
in the amount of $526.00 within 30 days of today's date; and
2. Plaintiff is directed to furnish, in
verified form, and without objection, answers to Defendant's
interrogatories within 30 days of today's date.
By the Court,
rO
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J, ?".-_
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y_.
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f
R
Harold L. Sloop, Jr.
428 Chestnut Street
Mount Holly Springs, PA 17065
Plaintiff, pro se
Donald L. Carmelite, Esquire
Suite B
4200 Crums Mill Road
Harrisburg, PA 17112
For Defendant
:mae
Curtis R. Long
Prothonotary
office of the Protbonotarp
Cumberfanb Countp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
0H - jo CVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2.
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573