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HomeMy WebLinkAbout14-5444 Supreme Co» ennsylvania Cour df Conmo leas For Prothonotary Use Only: �•� :S C - >�l'COer. h . t El Docket No:County /` // r v /4 l L The information collected on this form is used solely for court administration purposes. This form does not supplement or re lace the filing and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: S ED Complaint E3 Writ of Summons ® Petition E ® Transfer from Another Jurisdiction ® Declaration of Taking C Lead Plaintiff's Name: Lead Defendant's Name: T Douglas Wotring Margaret Stuski I Dollar Amount Requested: within arbitration limits Are money damages requested? Yes No O (check one) x;outside arbitration limits N Is this a Class Action Suit? [3 Yes El No Is this an MDJAppeal? [3 Yes ll No A Name of Plaintiff/Appellant's Attorney: Vincent M. Monfredo Check here if you have no attorney(are a Self-Represented [Pro Se] Litigant) Nature of the Case: Place an "X"to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim,check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS El Intentional © Buyer Plaintiff Administrative Agencies © Malicious Prosecution Q Debt Collection:Credit Card ® Board of Assessment Motor Vehicle ®Debt Collection:Other Nuisance ® Board of Elections Dept.of Transportation Premises Liability Statutory Appeal:Other S ® Product Liability(does not include Emass tort) [3 Employment Dispute: ® Slander/Libel/Defamation Discrimination C ®Other: Employment Dispute:Other Zoning Board T ® Other: I Other: O MASS TORT ® Asbestos N [3 Tobacco Toxic Tort-DES 13 Toxic Tort-Implant REAL PROPERTY ® Toxic Waste MISCELLANEOUS Other: ® Ejectment 0 Common Law/Statutory Arbitration B [3 Eminent Domain/Condemnation [3 Declaratory Judgment 0 Ground Rent M Mandamus ® Landlord/Tenant Dispute Non-Domestic Relations ® Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY ®Mortgage Foreclosure:Commercial 13 Quo Warranto ® Dental ® Partition ®Replevin ® Legal ® Quiet Title [3 Other: 0 Medical Other: Other Professional: Updated 1/1/2011 DOUGLAS WOTRING, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET NO.: MARGARET STUSKI, and CIVIL ACTION—LAW _7 DANIEL HAIR as an individual ' w' and in his capacity as an officer for the West Shore Regional Police and MICHAEL HOPE as an individual = ` r , r..;Ti and in his capacity as an officer for ,--1-1 the West Shore Regional Police, _c ws Defendants JURY TRIAL DEMANDED NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following Complaint, you must take action within twenty(20) days after this Complaint and Notice are served,by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so,the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD ST. CARLISLE,PA 17013 1-800-990-9108 717-249-3166 //s- 7r�V/ r3 ! /0 7,6 DOUGLAS WOTRING, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET NO.: MARGARET STUSKI, and CIVIL ACTION-LAW DANIEL HAIR as an individual and in his capacity as an officer for the West Shore Regional Police and MICHAEL HOPE as an individual and in his capacity as an officer for the West Shore Regional Police, Defendants JURY TRIAL DEMANDED COMPLAINT AND NOW,comes Plaintiff, DOUGLAS WOTRING, by and through his counsel, Vincent M. Monfredo, Esq., and submits the following: INTRODUCTION 1. This is an action for money damages brought pursuant to common law of the Commonwealth of Pennsylvania, Title 18 Pa.C.S.A. Section 5725 along with counts for money damages brought pursuant to 42 U.S.C. Sections 1983 and 1988 and the Fourth and Fourteenth Amendments of the United States Constitution. 2. Jurisdiction is based upon 28 U.S.C. Sections 1331 and 1343, and on the pendent jurisdiction of the Court to entertain claims arising under state law. 3. Section 5725 states "Any person whose wire, electronic or oral communication is intercepted, disclosed or used in violation of this chapter shall have a civil cause of action against any person who intercepts, discloses or uses or procures any other person to intercept, disclose or use, such communication; and shall be entitled to recover from any such person." 4. It is alleged that Defendant Stuski intercepted numerous e-mail communications of the Plaintiff's and without his consent provided them to the West Shore Regional Police Department who then viewed and used the e-mail communications without warrant and in violation of the Plaintiff's Constitutional rights. PARTIES 5. Douglas Wotring(hereinafter Plaintiff)is an adult individual residing at 11 Clifton Rd. Camp Hill, PA 17011 in Cumberland County. 6. Margaret Stuski (hereinafter Defendant Stuski) is an adult individual believed to be residing at 908 W. Walnut St. Wormleysburg, PA 17043 in Cumberland County. 7. Daniel Hair(hereinafter Defendant Hair) is an adult individual believed to be employed as an Officer of the West Shore Regional Police Department located at 510 Herman Ave. Lemoyne, PA 17043. 8. Chief Michael Hope (hereinafter Defendant Hope) is an adult individual believed to be employed as an Officer of the West Shore Regional Police Department located at 510 Herman Ave. Lemoyne, PA 17043. FACTS 9. Previous paragraphs are incorporated by reference as if fully set forth herein. 10. The Plaintiff and Defendant Stuski were previously involved in a civil matter regarding the ownership rights of two dogs at Cumberland County Civil Docket number 13-380 which also resulted in Defendant Stuski having criminal charges brought against the Plaintiff. 11. On or about October 7, 2012, Defendant Stuski provided the West Shore Regional Police Department with numerous emails that were from Plaintiff's email account. (See, Exhibit "A"; Defendant Hair's report). 12. Plaintiff did not provide Defendant Stuski with these emails,nor were the majority of them from Plaintiff to Defendant Stuski. 13. It is believed Defendant Stuski intercepted the emails by illegal means. 14. Defendant Hair reviewed the emails and notes in his report that he "reviewed each of the emails"and that he "only found a small few that actually mentioned her" and that"most were about Wotring's work and him contacting others about his right to the dogs." (See Exhibit"A"). COUNT UNLAWFUL INTERCEPTION,DISCLOSURE OR USE OF ELECTRONIC COMMUNICATION UNDER TITLE 18 PA.C.S.A. SECTION 5723 AGAINST DEFENDANT STUSKI 15. Previous paragraphs are incorporated herein by reference as if fully set forth herein. 16. Defendant Stuski intercepted emails belonging to the Plaintiff without his permission. 17. Defendant Stuski then disclosed said emails to the West Shore Regional Police Department. 18. Most of the emails provided are believed to be between Plaintiff and third parties. 19. Defendant Stuski had no right to intercept or disclose any of the emails between Plaintiff and third parties. 20. Title 18 Pa.C.S.A Section 5703 states that it is a felony of the third degree for a person to intercept or disclose any electronic communication. 21. Section 5725 states that the Plaintiff shall be entitled to recover"Actual damages,but not less than liquidated damages computed at the rate of$100 a day for each day of violation, or$1,000,whichever is higher." 22. Section 5725 further states that the Plaintiff shall be entitled to recover punitive damages and reasonable attorney's fee and other litigation costs reasonably incurred." 23. Plaintiff has incurred filing fees associated with the filing of this Complaint along with attorney's fees due to undersigned counsel. 24. The actions of Defendant Stuski were outrageous and shocking and constituted willful and malicious conduct for which punitive damages are applicable as she is alleged to have committed a felony of the third degree. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Judgment in his favor in an amount in excess of the limits for compulsory arbitration, along with punitive damages, costs, interest, and attorney's fees against Defendant Stuski. COUNT II UNLAWFUL INTERCEPTION,DISCLOSURE OR USE OF ELECTRONIC COMMUNICATION UNDER TITLE 18 PA.C.S.A. SECTION 5723 AGAINST DEFENDANT HAIR AND DEFENDANT HOPE 25. Previous paragraphs are incorporated by reference as if fully set out herein. 26. Defendant Hair was acting as an officer of the West Shore Regional Police Department under color of state law at all times. 27. Defendant Stuski intercepted emails belonging to the Plaintiff without his permission. 28. Defendant Stuski then disclosed said emails to the West Shore Regional Police Department. 29. Most of the emails provided were between Plaintiff and third parties. 30. Defendant Stuski had no right to intercept or disclose any of the emails between Plaintiff and third parties. 31. Defendant Hair reviewed all the emails disclosed to him by Defendant Stuski. (Exhibit 32. Title 18 Pa.C.S.A Section 5703 states that it is a felony of the third degree for a person to intercept or disclose any electronic communication. 33. Further, Title 18 Pa.C.S.A. Sections 5708 and 5709 sets forth the rules for requiring written application for an order authorizing the interception of electronic communication. 34.No order was ever applied for or received by the Defendant Hope or Defendant Hair. 35. It is noted that Defendant Hope provided the emails to Defendant Hair. (Exhibit"A"). 36. Defendant Hope was the supervising officer of Defendant Hair. 37. Defendant Hope directly caused the Constitutional violations and state violations to Plaintiff by accepting the emails and providing them to his subordinate to review. 38. Section 5725 states that the Plaintiff shall be entitled to recover"Actual damages, but not less than liquidated damages computed at the rate of$100 a day for each day of violation, or$1,000, whichever is higher." 39. Section 5725 further states that the Plaintiff shall be entitled to recover punitive damages and reasonable attorney's fee and other litigation costs reasonably incurred." 40. Section 5725 further states that the doctrine of sovereign immunity is waived. 41. Plaintiff has incurred filing fees associated with the filing of this Complaint along with attorney's fees due to undersigned counsel. 42. The actions of Defendant Hair were outrageous and shocking and constituted willful and malicious conduct for which punitive damages are applicable. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Judgment in his favor in an amount in excess of the limits for compulsory arbitration, along with punitive damages, costs, interest, and attorney's fees against Defendant Hair as an adult individual and in his capacity as an officer for the West Shore Regional Police Department. COUNT III ILLEGAL SEARCH AND SEIZURE UNDER 42 U.S.C. SECTION 1983 AGAINST DEFENDANT HAIR AND DEFENDANT HOPE 43. Previous paragraphs are incorporated by reference as if fully set out herein. 44. At all times Defendant Hair and Defendant Hope were acting under color or state law. 45. Defendant Hair and Defendant Hope deprived the Plaintiff of his Fourth and Fourteenth rights under the Federal Constitution to be free from unreasonable searches and seizures of his property. 46. Defendant Hair and Defendant Hope reviewed email communication by the Plaintiff without a warrant or privilege. 47. The viewing of the emails by the Defendants was illegal. 48. Plaintiff informed the Defendants that the emails were taken without his permission and requested that Defendant Stuski be charged. 49.No charges were ever brought against Defendant Stuski. 50. It is believed that favorable treatment was given to Defendant Stuski due to her local position as a Borough Councilperson. 51. Undersigned counsel informed Defendant Hope by letter dated December 24, 2013 of the violations of the West Shore Regional Police and of Defendant Stuski. (Exhibit`B"). 52. It is noted that Defendant Hope provided the emails to Defendant Hair. (Exhibit"A"). 53. Defendant Hope was the supervising officer of Defendant Hair. 54. Defendant Hope directly caused the Constitutional violations and state violations to Plaintiff by accepting the emails and providing them to his subordinate to review. 55. The acts of Defendant Hope and Hair directly violated the Plaintiff's rights under the United States Constitution and the Pennsylvania State Constitution to be free of unlawful searches and seizures and Plaintiff's right to privacy was violated. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Judgment in his favor in an amount in excess of the limits for compulsory arbitration, along with punitive damages, costs, interest, and attorney's fees against all Defendants. COUNT IV PUNITIVE DAMAGES AGAINST ALL DEFENDANTS 56. Previous paragraphs are incorporated by reference as if fully set out herein. 57. The conduct of all defendants was outrageous. 58. Defendant Stuski is a licensed attorney and should have been familiar with the fact that it is a crime to disclose or intercept electronic communication. 59. All Defendants should have been aware of the criminal statutes in Pennsylvania,the Pennsylvania State Constitution, and the United States Constitution. 60. Defendant Stuski should have reasonably known she could not intercept or disclose the email communication of the Plaintiff. 61. Defendant Police Department and Defendant Hair should have reasonably known they needed to apply for the right to search or seize the Plaintiff's email communication. 62. The Defendants acted maliciously, wantonly, willfully, oppressively, or showed reckless indifference to the interest of others. 63. The Defendants should be punished for their actions. 64. Punitive damages would appropriately punish the Defendants and deter them and others from committing similar acts. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Judgment in his favor in an amount in excess of the limits for compulsory arbitration, along with punitive damages, costs, interest, and attorney's fees against all Defendants. Respectfully submitted, Monfredo & Mandarino Law Date: Vincent M. Monfredo, Esquire 3300 Trindle Rd. Second Floor Camp Hill, PA 17011 (717) 585-2064 Supreme Court ID#20664 Attorney for Plaintiff }METRO' THE HARRISBURG AREA POLICE INFORMATION RESOURCE SYSTEM (ICRIPINC) 2013021706DLH3 WSR2 PAGE: 3 INC#: WSR 20121000138 DT,TM: 2012 06 17 1817 -------------- ---------------------------------------- STATUS: 0 REPORTNO01ICINITIAL CRIME ^------^--------------------- -------------------------------- - -------------- 00908 - ---�---- LEMOYNE PA 0105 LOC, GRID: WALNUT ST 10/07/12 1400 PLAT: SECT: P REPORT OFF: 3206 DANIEL L HAIR VEH INFO: INS,OUT: I LIGHT: G WEATHER: C TEMP: 999 F 00/00/00 DUE: ASSIGN OFF: APPROV OFF: 3201 MICHAEL L HOPE 00/00/00 CV HANDBK: N PCCD V/W FORM: N DOM RELAT FORM: N EXT SIGNED DOC: N DEFERR PROSECUT: N DA REQ FOR HEAR: STMT / CONFESS: SEC SURVEY: N AC SURVEY: : Y FURTHER ARRESTS: N CRIM SUMMONS: N WARRANT- Y FOLLOW UP: N REC ASSIGN TO: NCIC GRIM HIST: N CITY PROP DAM: ON OCTOBER 8, 2012 T WAS ADVISED BY CHIEF HOPE THAT MARGARET STUSKI HAD DROPPED OFF NUMEROUS EMAILS THAT WERE FROM DOUGLAS WOTRING'S EMAIL ACCOUNT. SHE SAID THAT SHE IS STILL BEING HARASSED BY WOTRING THROUGH THIRD PARTY CONTACTS. WOTRING IS TO BE CONTACTING PEOPLE AND FILING COMPLAINTS WITH THEM WHICH IN TURN IS CAUSING PROBLEMS FOR STUSKI . I REVIEWED EACH OF THE EMAILS TO DETERMINE IF THERE WAS ANY IN THEM PERTAIING TO STUSKI. I ALSO ATTEMPTED TO CALL CARYN LANGE, WHO I BELIEVED TO BE A FRIEND OF STUSKI'S. LANGE HAS ALSO BEEN CONTACTED BY WOTRING AND HAS HAD POLICE DEALINGS WITH HIM IN CARLISLE. LANGE ADVISED ME THAT SHE DOES NOT KNOW STUSKI PERSONALLY AND HAS NEVER SPOKEN TO WOTRING ABOUT STUSKI. I ATTEMPTED TO CALL STUSKI TO GET MORE INFORMATION FROM HER BUT HAD TO LEAVE A VOICE MAIL TO CALL ME BACK. I ALSO ATTEMPTED TO CONTACT WOTRING TO HAVE HIM COME IN AND TALK TO ME ABOUT THIS ONGOING ISSUE AND ALSO HAD TO LEAVE A MESSAGE FOR HIM TO CALL ME. I EVENTUALLY DID RECEIVE A CALL BACK FROM STUSKI. I ADVISED HER THAT I REVIEWED EACH OF THE EMAILS AND ONLY FOUND A SMALL FEW THAT ACTUALLY MENTIONED HER OR REFERENCED HER. I ADVISED HER THAT MOST WERE ABOUT WOTRING'S WORK AND HIM CONTACTING OTHERTHESESDOESHHEUESTIONS ABOUT MENTION STUSKIHIS OR THEHT TO THE LOCATION OF THE ONE OF THE DO S STUSKI MENTIONED AN EMAIL TO REPRESENTATIVE DELOZIER AND STUSKI SAID THAT WOTRING SENT THAT EMAIL TO HER BECAUSE STUSKI RAN AGAINST DELOZIER IN THE LAST ELECTION. I AGAIN TOLD HER THAT THERE DELOZIERSSOOIMDIDION NOTOFEELROR THATHER HE WASRTARGETINGHIS STUSKICONTACTS WITH IN ANY WAY WITH THIS PARTICULAR EMAIL. I DID TELL STUSKI THAT I WILL BE CHARGING WOTRING IN SOME MANNER BUT AM TRYING TO DETERMINE WHAT CHARGE TO BRING. I ASKED HER IF THERE WAS ANYONE ELSE THAT WOTRING CONTACTED AND SHE ADVISED THAT HE HAS BEEN IN CONTACT WITH STUSKI 'S NEIGHBORS AND SHE FEELS THAT THIS IS A VIOLATION. I ALSO HAD RECEIVED A COPY OF A LETTER THAT WOTRING HAD FAXED TO HARRISBURG CITY ALLEGING VIOLATIONS BY STUSKI AT AN ADDRESS IN HARRISBURG CITY. THESE WERE FALSE ALLEGATIONS AND PART OF THE ONGOING HARASSMENT BY WOTRING. t METRO THE HARRISBURG AREA POLICE INFORMATION RESOURCE SYSTEM 170(ICRIPWSR2 PAGE: 4 INC#: WSR 20121000138 DT,TM: 2012 06 17 1817 ^-y__-J ^_ REPORT rNO^ . 01-------------------------------- ICINITIAL CRIME -------------------------------------STATUS:--------0 _- r^__r ^--_____-STATUS_^O THIS CASE DID BEGIN IN JUNE OF THIS YEAR., WHEN STUSKI HAD REPORTED TO THIS OFFICER, THAT WOTRING HAD STARTED SENDING HER HARASSING TEXT MESSAGES AND EMAILS. AT THAT TIME WOTRING WAS CONTACTED AND TOLD TO CEASE THE ACTIVITY. I ALSO HAD SEVERAL MORE CONTACTS FROM STUSKI ABOUT THIS CONTINUED ACTIVITY AND AT TIME NOTHER ABLEADE TO MAKEACT OT CONTACTTIEDIDELEAOVETACT WITH RING, MESSAGE TO CEASE ALL SUCH ACTIVITY. THE LAw OFFICE VINCENT Mo MONFREDO r�a�a�Fx.�3 cr rasa{,zo,z� td{)Ritter Rd. TO:717,585.'064 s�sal, ia3-ccroairaxr: �ac�o.cxrrxa :iitite2,02 l'ax:888.959.1331 PX 171.)55 December 24, 2013 Chief Michael Hope West Shore Regional Police Dept. 510 Herman Ave. Lemoyne,PA 17043 Dear Chief Hope, I have been retained by Douglas Wotring in regards to a potential law suit against your department and Officer Daniel Hair in relation to Mr. Wotring's arrest on or about October 16,2012. Please consider this a formal request to have your insurer/attorney contact me to discuss this matter. To briefly sum up the situation, Mr. Wotring was arrested for the alleged harassment of local attorney Margaret Stuski. As part of the investigation Ms. Stuski provided your department with numerous emails which were taken from Mr. Wotring's email account without his permission. He has informed your department of this. However,nothing has been done. The emails used in your department's arrest of Mr. Wotring are clearly emails exchanged between Mr. Wotring and third parties. The emails I am referencing do not contain Ms. Stuski as a party to the emails. Ms. Stuski illegally obtained these emails by accessing Mr. Wotring's email account without his permission. Her defense that they shared a computer makes little sense and the sharing of a computer would not permit her to access his emails. Ms. Stuski is clearly in violation of the law. At the very least she has violated 18 Pa.C.S.A. 5703, but your department refused to charge her and instead used the illegal emails in his prosecution. 18 Pa.C.S.A. 5725 allows for a civil action to be brought for the unlawful interception of any electronic communication. Further, the statute specifically states the Commonwealth is not immune from suit and punitive damages and attorneys are collectible if successful. , 0 www.vincentmonfredoxom We intend to bring a civil action under that section, section 1983, and under any other state and federal law that may be applicable. We continue to request that Ms. Stuski be prosecuted for illegally obtaining and providing you with Mr. Wotring's electronic communication,but that time seems to have passed. I respectfully request you have your insurer or attorney contact me to discuss this matter further as we intend to file suit within fourteen(14)days from the date of this letter. Thank you for your time. SiVincent l Monfredo,Esquire cc—Office of Attorney General County Commissioner's Office Douglas Wotring VERIFICATION I verify that I am the Plaintiff and that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904,relating to unsworn falsification to authorities. Date: D. Wotring DONALD L. CARMELITE, ESQUIRE ID No: 84730 Marshall, Dennehey, Warner, Coleman & Goggin 100 Corporate Center Drive, Suite 201 Camp Hill, PA 17011 (717) 651-3504 Attorney for Defendants Daniel Hair and Michael Hope DOUGLAS WOTRING, Plaintiff v. MARGARET STUSKI, AND DANIEL HAIR AS AN INDIVIDUAL AND IN HIS CAPACITY AS AN OFFICER FOR THE WEST SHORE REGIONAL POLICE AND MICHAEL HOPE AS AN INDIVIDUAL AND IN HIS CAPACITY AS AN OFFICER FOR THE WEST SHORE REGIONAL POLICE, Defendants it.to-orFic,E Lib- HE pRorHali Alf 201 SEP 24 Pt! 2: 28 CURL ANC) COUNT PE,NSYLVANIA : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA : CIVIL ACTION : NO. 2014-5444 : JURY TRIAL DEMANDED PRAECIPE TO REFLECT NOTICE OF REMOVAL TO UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA TO THE PROTHONOTARY: Kindly mark the docket to reflect that on September 22, 2014, Defendant filed a Notice of Removal of this case with the United States District Court for the Middle District of Pennsylvania at No. 14-ev- 0/8 43 . A copy of the Notice is attached hereto. MARSHALL, DENNEHEY, WARNER. COL N & GOGGIN DONALD L. CI-RMELITE, ESQUIRE Attorneys for Defendants, Daniel Hair and Michael Hope Dated: September a.D, , 2014 05/1284547M CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Praecipe was served by First Class mail, postage prepaid, on the following counsel of record: Dated: September 05/1284547.v1 Vincent M. Monfredo, Esquire Law Office of Vincent M. Monfredo 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 , 2014 Margaret Stuski 908 W. Walnut Street Wormleysburg, PA 17043 MARSHALL, DENNEHEY, WARNER. COLEMAN & GOGGIN DOi ALD L. Attorneys for Hope RMELITE, ESQUIRE endants, Daniel Hair and Michael Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 09 11 CII itibe 1.1-? •?, • , '44444,4-4,;4,4«,`211, OFCE• OF fl SkERV, r Lt..L JI L., THE PROTHONOTAi;'!' 2514 OCT PH 2: 37 CUMBERLAND COUNTY PENNSYLVANIA Douglas Worting vs. Margaret M. Stuski (et al.) Case Number 2014-5444 SHERIFF'S RETURN OF SERVICE 09/18/2014 10:35 AM - Sheriff Ronny R. Anderson, being duly sworn according to law, served the requested Complaint & Notice by handing a true copy to a person representing themselves to be Chief Michael Hope, who accepted as "Adult Person in Charge" for Daniel Hair at 510 Herman Avenue, Lemoyne. Borough, Lemoyne, PA 17043. RN?R. ANDERSON, SHERIFF 09/18/2014 10:35 AM - Sheriff Ronny R. Anderson, being duly sworn according to law, served the requested Complaint & Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Michael Hope at 510 Herman Avenue, Lemoyne Borough, Lemoyne, PA 17043. RONIWR. ANDERSON, SHERIFF 09/23/2014 08:10 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Complaint & Notice by handing a true copy to a person representing themselves to be Craig Bond, Husband, who accepted as "Adult Person in Charge" for Margaret M. Stuski at 908 Walnut Street, Wormleysburg Borough, Wormleysburg, PA 17043. SHERIFF COST: $96.65 SO ANSWERS, September 24, 2014 (c) CountySuito Sheriff, Toleosoft, Inc. RON R ANDERSON, SHERIFF