HomeMy WebLinkAbout06-37620•
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JAMES H. SLYDER,
Plaintiff _ 37GZ /t o
No. ?.W?C?
V. Civil Action - Law
DICKINSON TOWNSHIP; DANIEL E.
WYRICK; THOMAS E. PATTERSON;
AND RAYMOND L. JONES,
Defendants
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT 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 STREET
Carlisle, PA 17013-3302
(717) 249-3166 or 1-800-990-9108
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JAMES H. SLYDER,
Plaintiff
V.
No. 06- .376,E ? T.,?,?..
Civil Action - Law
DICKINSON TOWNSHIP; DANIEL E.
WYRICK; THOMAS E. PATTERSON;
AND RAYMOND L. JONES,
Defendants
NOTICIA
Les han demandado a usted en la corte. Se usted guiere defenderse de estas demandas
expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de
la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por
abogado y archhivar en la corte en forma escrita sus defensas o sus objeciones a las demandas
en conra de su persona. Sea avisado qui si usted no soe defiende, la corte tomara mmedidas y
purde entrar una orden contra usted sin previo aviso o notoficacion y pro cualquier queja o
alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades
o otros derechos importantes para usted.
LLEVE ESTA DEMANDO A UN ABODAGO IMMEDIATEMENTE. SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA 0 LLAME FOR TELEFONO A LA OFICIAN CUYA DIRECCION
SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE
CONSGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
Carlisle, PA 17013-3302
(717) 249-3166 or 1-800-990-9108
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JAMES H. SLYDER,
Plaintiff
No.L -296z-
V. Civil Action - Law
DICKINSON TOWNSHIP; DANIEL E.
WYRICK; THOMAS E. PATTERSON;
AND RAYMOND L. JONES,
Defendants
COMPLAINT
&?,( %m,,
Plaintiff, by his attorney, Debra K. Wallet, Esquire, brings the following cause of
action under the Pennsylvania Whistleblower Law, 43 P.S. § 1421 et seq., [hereinafter
Whistleblower Law]:
1. Plaintiff James H. Slyder [hereinafter Slyder] is an adult individual who resides
at 429 Chestnut Street, Mount Holly Springs, Pennsylvania 17065.
2. Defendant Dickinson Township is a municipality within the County of
Cumberland, Commonwealth of Pennsylvania, and is a "public body" as that term is defined in
the Whistleblower Law, with a mailing address of 219 Mountainview Road, Mt. Holly
Springs, PA 17065.
3. Defendant Daniel E. Wyrick [hereinafter Wyrick] is an adult individual sued in
his official capacity as a Dickinson Township Supervisor.
4. Defendant Thomas E. Patterson [hereinafter Patterson] is an adult individual
sued in his official capacity as a Dickinson Township Supervisor.
5. Defendant Raymond L. Jones [hereinafter Jones] is an adult individual sued in
his official capacity as a Dickinson Township Supervisor.
6. Dickinson Township, Wyrick, Patterson, and Jones were employers of Slyder as
that term is defined in the Whistleblower Law until Slyder was discharged from employment
by letter from the three supervisors dated January 3, 2006.
Slyder was hired by Dickinson Township in April 2004 as Road Master of
Dickinson Township and served in this capacity until his discharge on January 3, 2006.
8. Slyder was an employee of Dickinson Township and was supervised by the
elected township supervisors until he was discharged on January 3, 2006.
9. In April 2005, Slyder was appointed Dickinson Township Office Manager, a
position he held in addition to his duties as Road Master.
10. As Office Manager, Slyder reviewed and signed time sheets for Dickinson
Township employees.
11. Shortly after his appointment as Office Manager, Slyder became aware that
Wyrick was submitting time sheets to be paid for work which had not been authorized by the
Board of Supervisors.
12. Slyder did not approve these time sheets and expressed his concern directly to
Wyrick that it was not lawful or ethical for Wyrick to receive payments in 2004 and 2005 over
and above the stipend Wyrick received as a township supervisor and especially for him to
receive payments for work performed without authorization.
13. Wyrick denied that he was doing anything improper, illegal, or unethical.
14. In or about July 2005, Slyder made a good faith report both verbally and by
sworn written complaint to the Pennsylvania State Ethics Commission, an "appropriate
authority" as that term is defined in the Whistleblower Law, about the practices of Wyrick in
submitting the timesheets and in engaging in other unlawful or unethical practices.
15. Slyder alleged "wrongdoing," as that term is defined in the Whistleblower Law,
which was not of a merely technical or minimal nature but rather constituted wrongdoing or
waste causing the direct misuse and loss of public township funds.
16. Slyder is a "whistleblower" as that term is defined in the Whistleblower Law.
17. On or about September 19, 2005, the three township supervisors at that time,
including Wyrick and Patterson, placed Slyder on probation from his employment for a period
to end December 31, 2005.
18. Wyrick was instrumental in placing Slyder on probation and did so in retaliation
for Slyder's calling Wyrick's attention to the submission of time sheets which Slyder believed
to be improper.
19. Prior to the end of his probation, in or about mid December 2005, Slyder
received satisfactory performance evaluations signed by the two other Dickinson Township
Supervisors at the time, namely Patterson and August Ginter.
20. Of the three elected supervisors in mid-December 2005, only Wyrick was
critical of Slyder's work performance and deemed him to be unsatisfactory.
21. Slyder satisfactorily completed his probationary period on December 31, 2005
and was not terminated from his employment until January 3, 2006.
22. Raymond Jones was elected Dickinson Township Supervisor in November, 2005
to replace August Ginter and Jones begin serving his term on January 1, 2006.
23. As of the date of Slyder's termination on January 3, 2006, Jones had no direct
knowledge of Slyder's work performance and had not supervised him.
24. Raymond Jones relied on the opinions of Wyrick about Slyder's work
performance.
25. Patterson has now stated in writing that he has no memory of signing Slyder's
termination letter and that the termination letter does not reflect Patterson's opinion of Slyder's
performance.
26. Defendants discharged Slyder from his employment and otherwise retaliated
against Slyder as a direct result of Slyder's complaints about the actions of Wyrick and not
because of any legitimate work-related reason.
27. The three individual Defendant public officials violated the anti-retaliation
provisions of the Public Official and Employee Ethics Act, 65 Pa. C.S. § 11080), by
discharging Slyder from his employment and otherwise retaliating against him for filing a
complaint with the State Ethics Commission and for providing information to that
Commission.
28. Wyrick has claimed that Slyder's termination resulted from "openly lying to a
Township resident during a public meeting while on probation."
29. The reasons given by Wyrick are mere pretext for Wyrick's retaliation against
Slyder for Slyder's complaints about Wyrick's actions.
30. Defendants had no separate and legitimate work-related reasons to terminate
Slyder.
31. The amount claimed exceeds the jurisdictional amount requiring arbitration.
WHEREFORE, Plaintiff requests this Honorable Court to enter an order in favor of
Plaintiff and against Defendants as follows:
A. Directing the immediate reinstatement of Slyder to his position as Road Master
and Office Manager;
B. Awarding to Slyder the payment of his back wages, fringe benefits, and
seniority from the date of his termination to the date of his reinstatement to employment as
Dickinson Township Road Master and Office Manager;
C. Finding that Wyrick has violated the Whistleblower Law and is liable for a civil
fine of $500.00 to be paid to the State Treasurer for deposit into the General Fund;
D. Awarding to Plaintiff his reasonable legal fees and costs in connection with the
bringing of this action; and
E. Granting such other relief as the Court may deem appropriate under the
circumstances.
Respectfully submitted,
lQt ". ll. 4k..u.*r
Debra K. Wallet, Esq.
24 N. 32nd Street
Camp Hill, PA 17011
(717) 737-1300
I.D.k 23989
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JAMES H. SLYDER,
Plaintiff
No.
V. Civil Action - Law
DICKINSON TOWNSHIP; DANIEL E.
WYRICK; THOMAS E. PATTERSON;
AND RAYMOND L. JONES,
Defendants
VERIFICATION
I verify that the statements made in the foregoing Complaint are true and correct to the
best of my knowledge, information and belief. I understand that false statements made herein
are made subject to the penalties of 18 Pa. C.S. §4904, relating to unworn falsification to
authorities.
3v ? _
DATE JAM .SLYDER
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. ASS ".t
X26_A\LIAB\MTRILEY\LLPG\807168\MMKISSLING?05130\00000
MARSHALL, DENNEHEY, WARNER
COLEMAN & GOGGIN
BY: MARK T. RILEY, ESQUIRE
IDENTIFICATION NO. 49427
620 Freedom Business Center, Suite 300
King of Prussia, PA 19406
(610) 354-8259
Attorney for Defendants
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
JAMES H. SLYDER
V.
NO.: 06-3762
DICKINSON TOWNSHIP,
DANIEL E. WYRICK,
THOMAS E. PATTERSON, and
RAYMOND L. JONES
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of Defendants Dickinson Township, Daniel E. Wyrick, Thomas
E. Patter and Raymond L. Jones in the above captioned matter.
DATE: / G 6 v
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOGGIN
MARK T. RILEY
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X26 AV.IAB\MTRILEY\DISC\807171\MMKISSLING\05130W0541
MARSHALL, DENNEHEY, WARNER Attorney for Defendants
COLEMAN & GOGGIN
BY: MARK T. RILEY, ESQUIRE
IDENTIFICATION NO. 49427
620 Freedom Business Center, Suite 300
King of Prussia, PA 19406
(610) 354-8259
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
JAMES H. SLYDER
V.
DICKINSON TOWNSHIP,
DANIEL E. WYRICK,
THOMAS E. PATTERSON, and
RAYMOND L. JONES
NO.: 06-3762
CERTIFICATE OF SERVICE
MARK T. RILEY, ESQUIRE, being duly sworn and according to law hereby certifies that a true and
correct copy of Defendant's Damage Interrogatories, Expert Witness Interrogatories and Request for
Production of Documents to Plaintiff were forwarded to counsel on July 26, 2006 and said documents were
sent first class mail, postage prepaid, to the last known address of the other parties or their representatives.
Debra K. Wallet, Esquire
24 N. 32nd Street
Camp Hill, PA 17011
MARSHALL, DENNEHEY, WARNER,
COLEMAN &? GOGGIK
BY:
MARK T.
Attorney for Defendants
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TO: PLAINTIFFS
YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE
ENCLOSED AN WE T I N E W 11 WITH [ DAYS FROM
SERVICE HEREOF OR AAJACME TAY BE ENTERED AGAINST YOU.
BY: f
ARK T. RILE Y, ESQUIRV
ATTORNEY FOR DEFENDANTS
126_A\LMB\MMLEY\LLPG\807178NMKLSSLING\05130W0000
MARSHALL, DENNEHEY, WARNER Attorney for Defendants
COLEMAN & GOGGIN
BY: MARK T. RILEY, ESQUIRE
IDENTIFICATION NO. 49427
620 Freedom Business Center, Suite 300
King of Prussia, PA 19406
(610) 354-8259
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
JAMES H. SLYDER
V.
NO.: 06-3762
DICKINSON TOWNSHIP,
DANIEL E. WYRICK,
THOMAS E. PATTERSON, and
RAYMOND L. JONES
ANSWER AND NEW MATTER OF DEFENDANTS TO PLAINTIFF'S COMPLAINT
Defendants, Dickinson Township, Daniel E. Wyrick, Thomas E. Patterson and Raymond L. Jones, by
and through their attorneys, Marshall, Dennehey, Warner, Coleman & Goggin hereby answers Plaintiffs
Complaint with New Matter as follows:
1. Denied. After reasonable investigation, Answering Defendants are without sufficient knowledge
or information to form a belief as to the truth or falsity of the matters alleged herein and, hence, same are denied
with strict proof thereof demanded at the time of trial.
2-10. Admitted.
11-14. Denied. The matters alleged herein are denied pursuant to Pa. R.C.P. 1029(e).
15. Denied. The matters alleged herein are conclusions of law to which no responsive pleadings are
required under the Pennsylvania Rules of Civil Procedure and are, therefore, deemed Denied. The matters
alleged herein are denied pursuant to Pa. R.C.P. 1029(e).
16. Denied. The matters alleged herein are conclusions of law to which no responsive pleadings are
required under the Pennsylvania Rules of Civil Procedure and are, therefore, deemed Denied. The matters
alleged herein are denied pursuant to Pa. R.C.P. 1029(e).
17. Admitted.
18-25. Denied. The matters alleged herein are denied pursuant to Pa. R.C.P. 1029(e).
26. Denied. The matters alleged herein are conclusions of law to which no responsive pleadings are
required pursuant to the Pennsylvania Rules of Civil Procedure and are, therefore, deemed denied. To the
extent that an Answer may be required, said allegations are denied pursuant to Pa. R.C.P. 1029(e).
27. Denied. The matters alleged herein are conclusions of law to which no responsive pleadings are
required under the Pennsylvania Rules of Civil Procedure and are, therefore, deemed Denied. The matters
alleged herein are denied pursuant to Pa. R.C.P. 1029(e).
28. Admitted.
29. Denied. The matters alleged herein are conclusions of law to which no responsive pleadings are
required pursuant to the Pennsylvania Rules of Civil Procedure and are, therefore, deemed denied. To the
extent that an Answer may be required, said allegations are denied pursuant to Pa. R.C.P. 1029(e).
30. Denied. The matters alleged herein are conclusions of law to which no responsive pleadings are
required pursuant to the Pennsylvania Rules of Civil Procedure and are, therefore, deemed denied. To the
extent that an Answer may be required, said allegations are denied pursuant to Pa. R.C.P. 1029(e).
31. Denied. The matters alleged herein are preliminary jurisdictional allegations which require no
responsive pleadings pursuant to the Pennsylvania Rules of Civil Procedure. Hence, same are deemed Denied.
The matters alleged herein are denied pursuant to Pa. R.C.P. 1029(e).
WHEREFORE, Answering Defendants demand judgment in their favor and against the Plaintiff.
NEW MATTER
32. To the extent that Plaintiffs claims are barred and/or limited to any applicable statute of
limitations, Defendants claim same.
33. Plaintiffs Complaint fails to state a cause of action against Defendants.
34. To the extent that Plaintiffs claims are barred and/or limited pursuant to the Pennsylvania
Whistleblower Law, Defendants claim same.
35. At no time did Plaintiff suffer any loss of pay, demotion, loss of hours or loss of employment
with regard to any alleged complaints that he made.
36. If Plaintiff sustained any damages as alleged in his Complaint, which is strictly denied, then they
were caused by individuals or entities over whom Answering Defendants had no control nor right to control.
WHEREFORE, Answering Defendants pray that Plaintiffs Complaint be dismissed with costs and
prejudice.
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOGGIN
Mark T. Riley, Esquire
Attorney for Defendants
Date: 9/704
VERIFICATION
I}1?r[ 2; rgjhing duly sworn according to law deposes that he/ a is A e A and that he/)&- / is
authorized to take this verification on behalf of Defendant Dickson Township and that the facts set forth in the
foregoing Answer to Plaintiff's Complaint with New Matter are true and correct to the best of his/her
knowledge, information, and belief. The undersigned understands that the statements therein are made subject to
the penalties of 18 Pa.C.S. §4904, which provides for certain penalties for making false statements.
VERIFICATION
THOMAS E. PATTERSON hereby states that he is a Defendant in this action and verifies that the
statements made in the foregoing Answer to Plaintiffs Complaint with New Matter are true and correct to
the best of his knowledge, information and belief. The undersigned understands that the statements therein are
made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unworn falsification to authorities.
THOMAS E. PATTERSON
VERIFICATION
RAYMOND L. JONES hereby states that he is a Defendant in this action and verifies that the
statements made in the foregoing Answer to Plaintiffs Complaint with New Matter are true and correct to
the best of his knowledge, information and belief. The undersigned understands that the statements therein are
made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unworn falsification to authorities.
RAYMOND L. JOKES
VERIFICATION
DANIEL E. WYRICK hereby states that he is a Defendant in this action and verifies that the
statements made in the foregoing Answer to Plaintiffs Complaint with New Matter are true and correct to
the best of his knowledge, information and belief. The undersigned understands that the statements therein are
made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unswom falsification to authorities.
ANIEL E. CK
\26 A\LIAB\MIRILEY\DISC\807171\MMKISSLING\05130\00541
MARSHALL, DENNEHEY, WARNER Attorney for Defendants
COLEMAN & GOGGIN
BY: MARK T. RILEY, ESQUIRE
IDENTIFICATION NO. 49427
620 Freedom Business Center, Suite 300
King of Prussia, PA 19406
(610) 354-8259
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
JAMES H. SLYDER
V.
DICKINSON TOWNSHIP,
DANIEL E. WYRICK,
THOMAS E. PATTERSON, and
RAYMOND L. JONES
NO.: 06-3762
CERTIFICATE OF SERVICE
MARK T. RILEY, ESQUIRE, being duly sworn and according to law hereby certifies that a true and
correct copy of Defendants Answer and New Matter to Plaintiffs' Complaint was forwarded to counsel on
August 7, 2006 and said documents were sent first class mail, postage prepaid, to the last known address of the
other parties or their representatives.
Debra K. Wallet, Esquire
24 N. 32nd Street
Camp Hill, PA 17011
MARSHALL, DENNEHEY, WARNER,
COLEM
BY:
MARK T. RILEY, ESQZqE
Attorney for Defendants
n o C?
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IN THE COURT OF COMMON PLEA
CUMBERLAND COUNTY, PENNSYLVA
JAMES H. SLYDER,
Plaintiff
No. 06-3762
V. Civil Action - Law
DICKINSON TOWNSHIP; DANIEL E.
WYRICK; THOMAS E. PATTERSON;
AND RAYMOND L. JONES,
Defendants
ANSWER TO NEW MATTER
P, l?
Plaintiff, by and through his attorney, Debra K. Wallet, Esq., responds to the New
Matter pleaded by Defendants as follows:
32. This paragraph represents a LEGAL CONCLUSION to which no responsive
pleading is required. To the extent that it is deemed factual, the complaint was filed within the
applicable statute of limitations.
33. This paragraph represents a LEGAL CONCLUSION to which no responsive
pleading is required. To the extent that it is deemed factual, plaintiff has stated a cause of
action under the Pennsylvania Whistleblower Law.
34. This paragraph represents a LEGAL CONCLUSION to which no responsive
pleading is required. To the extent that it is deemed factual, Plaintiff's claims are neither
barred nor limited.
35. This paragraph represents a LEGAL CONCLUSION to which no responsive
pleading is required. To the extent that it is deemed factual, Plaintiff's loss of pay, loss of
hours, loss of employment, and loss of benefits are directly related to the complaints made by
Plaintiff.
36. This paragraph represents a LEGAL CONCLUSION to which no responsive
pleading is required. To the extent that it is deemed factual, the answering defendants
constitute the body which terminated Plaintiff's employment.
WHEREFORE, Plaintiff requests this Honorable Court to enter an order in favor of
Plaintiff and against Defendants
Respectfully submitted,
4 ,6- ie.
Debra K. Wallet, Esq.
24 N. 32nd Street
Camp Hill, PA 17011
(717) 737-1300
I.D.# 23989
Attorney for Plaintiffs
2
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JAMES H. SLYDER,
Plaintiff
No. 06-3762
V. Civil Action - Law
DICKINSON TOWNSHIP; DANIEL E.
WYRICK; THOMAS E. PATTERSON;
AND RAYMOND L. JONES,
Defendants
VERIFICATION
I verify that the statements made in the foregoing document are true and correct to the
best of my knowledge, information and belief. I understand that false statements made herein
are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to
authorities.
Ste, I nook,
?? ??
DATE S H. SLYDER
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JAMES H. SLYDER,
Plaintiff
No. 06-3762
V. Civil Action - Law
DICKINSON TOWNSHIP; DANIEL E.
WYRICK; THOMAS E. PATTERSON;
AND RAYMOND L. JONES,
Defendants
PROOF OF SERVICE
I, Debra K. Wallet, Esquire, hereby certify that on September 7, 2006, I served a true
and correct copy of the attached ANSWER TO NEW MATTER by first class mail, postage
pre-paid, addressed as follows:
Mark T. Riley, Esquire
MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN
620 Freedom Business Center, Suite 300
King of Prussia, PA 19406
jum. x. -
Debra K. Wallet, Esq.
24 N. 32nd Street
Camp Hill, PA 17011
(717) 737-1300
I.D.# 23989
Attorney for Plaintiff
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SHERIFF'S RETURN - REGULAR
.,CASE NO: 2006-03762 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SLYDER JAMES H
VS
DICKINSON TOWNSHIP ET AL
RONALD HOOVER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
DICKINSON TOWNSHIP the
DEFENDANT
, at 0925:00 HOURS, on the 5th day of July , 2006
at 219 MOUNTAINVIEW ROAD
MT HOLLY SPRINGS, PA 17065 by handing to
RON WOLFE. OFFICE MANAGER, ADULT IN CHARGE
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So Answers:
Docketing
Service 18.00
5.28
Postage .39
Surcharge 10.00 R. Thomas Kline
.00
33.67./ 07/05/2006
7/,_,/(,6 DEBRA WALLET
Sworn and Subscibed to By:
before me this day Deputy Sheriff
of A.D.
SHERIFF'S RETURN - REGULAR
1 CASE NO: 2006-03762 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SLYDER JAMES H
VS
DICKINSON TOWNSHIP ET AL
RONALD HOOVER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
WYRICK DANIEL E the
DEFENDANT
, at 0925:00 HOURS, on the 5th day of July , 2006
at 219 MOUNTAINVIEW ROAD
MT HOLLY SPRINGS, PA 17065
RON WOLFE, OFFICE MANAGER,
by handing to
ADULT IN CHARGE
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So Answers:
Docketing 6.00
Service .00
Affidavit 00?y?
Surcharge 10.00 R. Thomas Kline
.00
16.00 07/05/2006
7DEBRA WALLET
Sworn and Subscibed to By:
4
a5;??e
before me this day Deputy Sheriff
of A.D.
SHERIFF'S RETURN - REGULAR
1 CASE NO: 2006-03762 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SLYDER JAMES H
VS
DICKINSON TOWNSHIP ET AL
RONALD HOOVER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
PATTERSON THOMAS E the
DEFENDANT , at 0925:00 HOURS, on the 5th day of July , 2006
at 219 MOUNTAINVIEW ROAD
MT HOLLY SPRINGS, PA 17065
RON WOLFE, OFFICE MANAGER
by handing to
ADULT IN CHARGE
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So Answers:
Docketing 6.00
Service .00 Affidavit .00
Surcharge 10.00 R. Thomas Kline
.00
16.00 ? 07/05/2006
q./(,04 DEBRA WALLET
Sworn and Subscibed to By:?
before me this day Deputy Sheriff
of A.D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-03762 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SLYDER JAMES H
VS
DICKINSON TOWNSHIP ET AL
RONALD HOOVER
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
JONES RAYMOND L
the
DEFENDANT , at 0925:00 HOURS, on the 5th day of July 2006
at 219 MOUNTAINVIEW ROAD
MT HOLLY SPRINGS, PA 17065
by handing to
RON WOLFE, OFFICE MANAGER, ADULT IN CHARGE
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
4-
Sworn and Subscibed to
before me this
So Answers:
6.00
.00
00
10.00 R. Thomas Kline
.00
16.00,/ 07/05/2006
DEBRA WALLET
By:
day Deputy Sheriff
of A. D.
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22 C71
IN THE MATTER OF: COURT OF COMMON PLEAS
JAMES H. SLYDER TERM,
CUMBERLAND
-VS- CASE NO: 06-3762
DICKINSON TOWNSHIP, ET AL
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of ALLYSON M. ROSSEEL, ES
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
DATE: 10/04/2006
?% CS on behalf o l ^?
RO SE
Attorn y for DEFENDANT C%/I
R1.18 133-H DE11-0649674 34152-LO1
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
JAMES H. SLYDER
-VS-
DICKINSON TOWNSHIP, ET AL
COURT OF COMMON PLEAS
TERM,
CASE NO: 06-3762
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
PLASTERER EQUIPMENT CO., INC. EMPLOYMENT
TO: DEBRA WALLET, ESQUIRE, PLAINTIFF COUNSEL
MCS on behalf of ALLYSON M. ROSSEEL, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice period is
waived or if no objection is made, then the subpoena may be served. Complete
copies of any reproduced records may be ordered at your expense by completing
the attached counsel card and returning same to MCS or by contacting our local
MCS office.
DATE: 09/14/2006
CC: ALLYSON M. ROSSEEL, ESQ. - 05130-00541
Any questions regarding this matter, contact
MCS on behalf of
ALLYSON M. ROSSEEL, ES
Attorney for DEFENDANT
THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
R1. 15S 133-H DE02-0341716 34152 -COl
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
JAMES H. SLYDER
VS.
File No. 06-3762
DICKINSON TOWNSHIP, ET AL
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for PLASTERER EQUIPMENT CO INC
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: ****SEE ATTACHED RIDER****
at The MC 7rojW- Inc.- 1601 Market Street. Suite 800, Philade42hia PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: ALLYSON M. ROSSEEL ES
ADDRESS: 620 FREFDOM R1TRTNRCR C
& NU UP TSSIA PA 12406
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: _ Defendant
Date:
Seal of the Court
BY THE COURT:
Pro onotary/ r c, ivil Di sion
Deputy
34152-01
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
PLASTERER EQUIPMENT CO., INC.
640 LOWTHER ROAD
LEWISBERRY, PA 17339
RE: 34152
JAMES H. SLYDER
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Any and all employment records, applications, files, memoranda, compensation,
time and attendance records, personnel records, payroll and salary reports and
all medical records as an employee, including any and all such items as may be
stored in a computer database or otherwise in electronic form, pertaining to:
Dates Requested: up to and including the present.
Subject : JAMES H. SLYDER
429 CHESTNUT STREET, MT. HOLLY SPRINGS, PA 17065
Social security #: XXX-XX-5441
R1.15S 133-H SU10-0643006 34152-LO1
f- ?
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\26 A\LIAB\STSTADELMAN\LLPG\832287\EMSASSU\05130\00541
MARSHALL, DENNEHEY, WARNER
COLEMAN & GOGGIN
BY: MARK T. RILEY, ESQUIRE
IDENTIFICATION NO. 49427
620 Freedom Business Center, Suite 300
King of Prussia, PA 19406
Telephone: (610) 354-8259
Fax: (610) 354-8299
Email: mtriley(i,mdwcg com
Attorney for Defendants
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
JAMES H. SLYDER
V.
NO.: 06-3762
DICKINSON TOWNSHIP,
DANIEL E. WYRICK,
THOMAS E. PATTERSON, and
RAYMOND L. JONES
MOTION OF DEFENDANTS TO STRIKE PLAINTIFF'S OBJECTIONS
TO CERTAIN DISCOVERY REQUESTS AND COMPEL PLAINTIFF'S
PRODUCTION OF ANY AND ALL MATERIALS RELATED TO THE
COMPLAINT HE FILED TO THE PENNSYLVANIA STATE ETHICS COMMISSION
Defendants, by and through their attorneys, Marshall, Dennehey, Warner, Coleman &
Goggin, hereby submit this Motion to Strike Plaintiffs Objections and Compel Production of
Documents regarding Plaintiffs Complaint to the Pennsylvania State Ethics Commission and
aver as follows:
1. On or about June 30, 2006, Plaintiff filed a Complaint generally alleging
Defendants violated the Pennsylvania Whistleblower Law, 43 P.S. §1421, et seq. (A true and
correct copy of Plaintiff Complaint is attached here and incorporated as Exhibit "A").
2. Paragraph 14 of Plaintiffs Complaint states:
"In or about July 2005, Slyder made a good faith report both
verbally and by sworn written complaint to the Pennsylvania State
Ethics Commission an 'appropriate authority' as that term is
defined in the Whistleblower Law, about the practices of Wyrick
in submitting the time sheets and engaging in other unlawful or
unethical practices"
See Exhibit "A" at paragraph 14.
3. Plaintiff goes on to generally state that as a result of this complaint, he was
wrongfully discharged from his duties as a civil servant for the Township of Dickinson. See
Exhibit "A", generally.
4. On or about July 26, 2006, Defendants forwarded to Plaintiffs counsel Damage
Interrogatories, Expert Witness Interrogatories and Request for Production of Documents. (A
true and correct copy of Defendants' Certificate of Service for such discovery is attached hereto
and incorporated as Exhibit "B")
5. Defendants' First Request for Production of Documents asks that Plaintiff produce
the following:
"1. All written statements (signed or unsigned), descriptions,
statements records and written accounts of investigation, directly
or indirectly related to the matter set forth in Plaintiffs' Complaint."
(A true and correct copy of Defendants' Request for Production of Documents and Things
Addressed to Plaintiff is attached hereto and incorporated as Exhibit "C").
6. Defendants' seventh Damage Interrogatory directed to Plaintiff requests the
following:
117. Set forth a full and complete description of any and all
complaints made by Plaintiff to the Pennsylvania State Ethics
Commission, including but not limited to the following:
(a) The date each such complaint was made;
(b) To whom each such complaint was made;
(c) Whether each such complaint was verbal or written,
if written, attach a copy hereto;
(d) The substance of each such complaint;
(f) Whether Plaintiff advised anyone, other than the
State Ethics Commission, that he had made such complaint and, if
so, the identity of the person whom Plaintiff so advised and the
date on which each such person was so advised."
(A true and correct copy of Defendants' Damage Interrogatories Directed to Plaintiff is attached
hereto and incorporated as Exhibit "D")
7. In response to Defendants' First Request for Production of Documents and
Things, Plaintiff responded, in pertinent part, as follows:
"Plaintiff objects to producing the complaint made to the State
Ethics Commission and the documents relating to his complaint,
including the correspondence from the Ethics Commission
because: (1) the specifics of the charge and the investigation of
that charge are not relevant to the subject matter involved in the
pending action and beyond the scope of discovery pursuant to
Pa.R.C.P. 4003.1(a); only the facts that the charge was made, when
it was made, and against whom it was made are relevant and (2)
disclosure would subject Plaintiff to penalties for violating the
confidentiality provisions of the State Ethics Act, 65 Pa. C.S.
§ § 1108(k) and 1109(e)."
(A true and correct copy of Plaintiffs response to Defendant's Request for Production of
Documents and Things is attached hereto and incorporated as Exhibit "E").
8. Similarly, Plaintiff s response to Defendants' seventh Damage Interrogatory states,
in pertinent part, as follows:
"Plaintiff cannot divulge this information without violating the
confidentially provisions of the State Ethics Act. If and when the
State Ethics Commission makes this a public matter, then I will be
at liberty to provide the specifics. It is believed that Mr. Wyrick
has sufficient information about the nature of the complaint based
upon the written communication with him by the Ethics
Commission."
(A true and correct copy of Plaintiffs Response to Defendants' Damage Interrogatories is
attached hereto and incorporated as Exhibit "F").
9. Defendants respectfully move that Plaintiffs objections to Defendant's First
Request for Production of Documents and Things, and Defendants' seventh Damage
Interrogatory be stricken and that Plaintiff be required to provide all documents responsive to
Request for Production No. 1, and a full and complete verified answer to Damage Interrogatory
No. 7 within ten (10) days from the date of the Order. Alternatively, Defendants respectfully
request that this Court enter an Order prohibiting Plaintiff from introducing into evidence any
and all documentation concerning his complaint to the Pennsylvania State Ethics Commission
and/or testifying regarding the complaint he made to the Pennsylvania State Ethics Commission.
10. Plaintiff first objects to Defendants' request for discovery concerning Plaintiffs
complaint to the Pennsylvania State Ethics Commission because such discovery request,
according to Plaintiff, is beyond the scope of discovery pursuant to Pa.R.C.P. 4003.1(a). See
Exhibits "E" and "F"
11. Pa.R.C.P. 4003.1(a) generally states that a party seeking discovery may obtain
discovery regarding any matter, not privileged, which is relevant to the subject matter involved
in the pending action, including the description, nature and content of documents, or other
tangible things. Pa.R.C.P. 4003.1(a), generally.
12. It is the law of this Commonwealth that documents requests be reasonably
calculated to lead to the discovery of admissible evidence in order to be allowed. Defendants'
discovery request here is reasonably calculated to lead to the discovery of admissible evidence
because Plaintiff complains that as a result of the good faith verbal and written complaint he filed
to the Pennsylvania State Ethics Commission, he was terminated. See Exhibit "A". Clearly, any
documents related to the Pennsylvania State Ethics Commission Complaint and/or investigation
are reasonably calculated to lead to the discovery of admissible evidence, as such documents are
the foundation for what Plaintiff alleges led to his dismissal.
13. Furthermore, 43. P. S. §1424 (Whistleblower Law) provides in section (d) that an
employee covered by civil service who contests a civil service action, believing it to be
motivated by his having made a good faith report, verbally or in writing, of an instance of wrong
doing or waste, may submit as admissible evidence any or all material relating to the action as
whistleblower and to the resulting alleged reprisal. See 43 P.S. §1424(d).
14. Here, if Plaintiff is to be allowed to submit any or all verbal or written material of
what he alleged to be a good faith report under the Pennsylvania Whistleblower Law, in this case
such report being made to the Pennsylvania State Ethics Commission (as alleged in paragraph 14
of Plaintiffs Complaint), then Plaintiff must allow Defendants discovery of such material and
information. Alternatively, Plaintiff must be precluded from introducing any evidence or
material relating to the complaint and/or investigation of the Pennsylvania State Ethics
Commission.
15. Plaintiff next objects that only the facts that the charge was made, when it was
made, and against whom it was made are relevant. See Exhibit "E".
16. As previously stated, Defendants are entitled to discover any and all documents,
information or the like that is reasonably calculated to lead to the discovery of admissible
evidence. Clearly, the verbal and/or sworn written complaint that Plaintiff made to the
Pennsylvania State Ethics Commission, which Plaintiff alleges led to his allegedly improper
dismissal, is reasonably calculated to lead to the discovery of admissible evidence. Such
documentation would provide evidence of potential statements made by Defendants and/or
Plaintiff, conduct of Defendants and/or Plaintiff, witnesses to the alleged conduct, as well as
other pertinent information.
17. Plaintiff next objects that if he were to produce any documents or answer any
Interrogatories regarding his complaint to the Pennsylvania State Ethics Commission, he would
be violating the confidentiality provisions of the State Ethics Act, 65 Pa. C. S. §§I 108(k) and
1109(e).
18. The Public Official and Employee Ethics Act, 65 Pa. C. S. §1101, et seq. provides
in section 1108(k) as follows:
"CONFIDENTIALITY. - - As a general rule, no person shall
disclose or acknowledge to any other person any information
relating to a complaint, preliminary inquiry, investigation, hearing
or petition for reconsideration which is before the commission.
However, a person may disclose or acknowledge to another person
matters held confidential in accordance with this subsection when
the matters pertain to any of the following:
(1) final orders of the commission as provided in subsection (h);
(2) hearings conducted in public pursuant to subsection (g);
(3) for the purpose of seeking advice of legal counsel;
(4) filing an appeal from a commission order;
(5) communicating with the commission or its staff, in the course
of a preliminary inquiry, investigation, hearing or petition for
reconsideration by the commission;
(6) consulting with a law enforcement official or agency for the
purpose of initiating, participating in or responding to an
investigation or prosecution by the law enforcement official or
agency;
(7) testifying under oath before a governmental body or a similar
body of the United States of America;
(8) any information, records or proceedings relating to a
complaint, preliminary inquiry, investigation, hearing or petition
for reconsideration which the person is the subject of; or
(9) such other exceptions as the commission by regulation may
direct.
65 Pa. C. S. §1108(k).
19. If, as Plaintiff contends this provision applies to prevent him from disclosing the
requested information pursuant to the Pennsylvania Rules of Civil Procedure and common law
regarding discovery of an action which he has brought, then clearly, he would also be prohibited
from disclosing any and all information or material at the time of trial in this matter and
Defendants respectfully request that this Honorable Court enter an Order precluding Plaintiff
from introducing into evidence or testifying regarding any and all information regarding the
Pennsylvania State Ethics Commission.
20. 65 Pa. C. S. §I 109(e) provides generally that any person who violates the
confidentiality of a Commission proceeding pursuant to § 1108 commits a misdemeanor. See 65
Pa. C. S. §1109(e).
21. Again, if Plaintiff is truly prevented from producing any evidence that related to
the Pennsylvania State Ethics Commission complaint and/or investigation, then he must be
precluded from introducing any such evidence or testimony at trial, and paragraph 14 should be
stricken from the Complaint.
22. Counsel for Defendants has requested that opposing counsel of record answer the
above discovery without objection, but opposing counsel maintains their objections.
WHEREFORE, Defendants respectfully request that this Honorable Court enter an Order
in the form attached hereto and order Plaintiff to produce all records and answer all discovery
related to his complaint to the Pennsylvania State Ethics Commission, or, alternatively, enter an
Order precluding Plaintiff from introducing or testifying about any evidence of a complaint filed
with the Pennsylvania State Ethics Commission at the time of trial.
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOGGIN
BY:
ARK T. RILEY, ES UIRE
Attorney for Defendants
Date: I/16-h
VERIFICATION
Mark T. Riley, Esquire, hereby states that he is the attorney for the defendants in
this action and verifies that the statements made in the foregoing Motion to Strike Plaintiffs
Objections to Certain Discovery Requests and Compel Plaintiffs Production of any and all
Materials related to the Complaint he filed with the Pennsylvania State Ethics Commission
are true and correct to the best of his knowledge, information and belief. The undersigned
understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. §4904
relating to unworn falsification to authorities.
MARK, E
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JAMES H. SLYDER,
Plaintiff
No.
V. Civil Action - Law
DICKINSON TOWNSHIP; DANIEL E.
WYRICK; THOMAS E. PATTERSON;
AND RAYMOND L. JONES,
Defendants
Plaintiff, by his attorney, Debra K. Wallet, Esquire, brings the following cause of
action under the Pennsylvania Whistleblower Law, 43 P. S. § 1421 et seq., [hereinafter
Whistleblower Law] :
1. Plaintiff James H. Slyder [hereinafter Slyder] is an adult individual who resides
at 429 Chestnut Street, Mount Holly Springs, Pennsylvania 17065.
2. Defendant Dickinson Township is a municipality within the County of
Cumberland, Commonwealth of Pennsylvania, and is a "public body" as that term is defined in
the Whistleblower Law, with a mailing address of 219 Mountainview Road, Mt. Holly
Springs, PA 17065.
3. Defendant Daniel E. Wyrick [hereinafter Wyrick] is an adult individual sued in
his official capacity as a Dickinson Township Supervisor.
4. Defendant Thomas E. Patterson [hereinafter Patterson] is an adult individual
sued in his official capacity as a Dickinson Township Supervisor.
/06 FRI 08:57 [TY/R-X NO 81211
fCl d3?c'
5. Defendant Raymond L. Jones [hereinafter Jones] is an adult individual sued in
his official capacity as a Dickinson Township Supervisor.
6. Dickinson Township, Wyrick, Patterson, and Jones were employers of Slyder as
that term is defined in the Whistleblower Law until Slyder was discharged from employment
by letter from the three supervisors dated January 3, 2006.
7. Slyder was hired by Dickinson Township in April 2004 as Road Master of
Dickinson Township and served in this capacity until his discharge on January 3, 2006.
8. Slyder was an employee of Dickinson Township and was supervised by the
elected township supervisors until he was discharged on January 3, 2006.
9. In April 2005, Slyder was appointed Dickinson Township Office Manager, a
position he held in addition to his duties as Road Master.
10. As Office Manager, Slyder reviewed and signed time sheets for Dickinson
Township employees.
11. Shortly after his appointment as Office Manager, Slyder became aware that
Wyrick was submitting time sheets to be paid for work which had not been authorized by the
Board of Supervisors.
12. Slyder did not approve these time sheets and expressed his concern directly to
Wyrick that it was not lawful or ethical for Wyrick to receive payments in 2004 and 2005 over
and above the stipend Wyrick received as a township supervisor and especially for him to
receive payments for work performed without authorization.
13. Wyrick denied that he was doing anything improper, illegal, or unethical.
14. In or about July 2005, Slyder made a good faith report both verbally and by
sworn written complaint to the Pennsylvania State Ethics Commission, an "appropriate
07/14/06 FRI 08:57 (TX/RX No 81211
authority" as that term is defined in the Whistleblower Law, about the practices of Wyrick in
submitting the timesheets and in engaging in other unlawful or unethical practices.
15. Slyder alleged "wrongdoing," as that term is defined in the Whistleblower Law,
which was not of a merely technical or minimal nature but rather constituted wrongdoing or
waste causing the direct misuse and loss of public township funds.
16. Slyder is a "whistleblower" as that term is defined in the Whistleblower Law.
17. On or about September 19, 2005, the three township supervisors at that time,
including Wyrick and Patterson, placed Slyder on probation from his employment for a period
to end December 31, 2005.
18. Wyrick was instrumental in placing Slyder on probation and did so in retaliation `.
for Slyder's calling Wyrick's attention to the submission of time sheets which Slyder believed
to be improper.
19. Prior to the end of his probation, in or about-mid December 2005, Slyder
received satisfactory performance evaluations signed by the two other Dickinson Township
Supervisors at the time, namely Patterson and August Ginter.
20. Of the three elected supervisors in mid-December 2005, only Wyrick was
critical of Slyder's work performance and deemed him to be unsatisfactory.
21. Sfyder satisfactorily completed his probationary period on December 31. 2005
and was not terminated from his employment until January 3, 2006.
22. Raymond Jones was elected Dickinson Township Supervisor in November, 2005
to replace August Ginter and Jones begin serving his term on January 1, 2006.
23. As of the date of Slyder's termination on January 3, 2006, Jones had no direct
knowledge of Slyder's work performance and had not supervised him.
07/14/06 FRI 08:57 [TX/RX NO 51211
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M JI4\IIIXAi IF. lit 1 7 4 3 o 8.4
24. Raymond Jones relied on the opinions of Wyrick about Slyder's work
performance.
25. Patterson has now stated in writing that he has no memory of signing Slyder's
termination letter and that the termination letter does not reflect Patterson's opinion of Slyder's
performance,
26. Defendants discharged Slyder from his employment and otherwise retaliated
against Slyder as a direct result of Slyder's complaints about the actions of Wyrick and not
because of any legitimate work-related reason.
27. The three individual Defendant public officials violated the anti-retaliation
provisions of the Public Official and Employee Ethics Act, 65 Pa. C.S. § 11080), by
discharging Slyder from his employment and otherwise retaliating against him for filing a
complaint with the State Ethics Commission and for providing information to that
Commission.
28. Wyrick has claimed that Slyder's termination resulted from "openly lying to a
Township resident during a public meeting while on probation."
29. The reasons given by Wyrick are mere pretext for Wyrick's retaliation, against
Slyder for Slyder's complaints about Wyrick's actions.
30. Defendants had no separate and legitimate work-related reasons to terminate
Slyder.
31. The amount claimed exceeds the jurisdictional amount requiring arbitration.
07/14/06 FRI 08:57 (TX/R1 NO 81211
S
. WHEREFORE, Plaintiff requests this Honorable Court to enter an order in favor of
Plaintiff and against Defentdacts as follows:
A. Directing the immediate reinstatement of Slyder to his position as Road Master
and Office Manager;
B. Awarding to Slyder the payment of his back wages, fringe benefits, and
seniority from the date of his termination to the date of his reinstatement to employment as
Dickinson Township Road Master and Office Manager;
C. Finding that Wyriek has violated the Whistleblower Law and is liable for a civil
fine of $500.00 to be paid to the State Treasurer for deposit into the General Fund;
D. Awarding to Plaintiff his reasonable legal fees and costs in connection with the
bringing of this action; and
E. Granting such other relief as the Court may deem appropriate under the
circumstances.
Respectfully submitted,
?C1t t„d K. 6kaA,4-
Debra K. Wallet, Esq.
24 N. 32nd Street
Camp Hill, PA 17011
(717) 737-1300
l.D•# 23989
Attorney for Plaintiff
07/14/06 FRI 08:57 (TX/RX NO 8121;
/( r
r.;,- -4
\26 A\L1AB\MTRILEY\DISC\807171\MMKISSLMGM130\00541
MARSHALL, DENNEHEY, WARNER
COLEMAN & GOGGIN
BY: MARK T. RILEY, ESQUIRE
IDENTIFICATION NO. 49427
620 Freedom Business Center, Suite 300
King of Prussia, PA 19406
(610) 354-8259
Attorney for Defendants
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
JAMES H. SLYDER
V.
NO.: 06-3762
DICKINSON TOWNSHIP,
DANIEL E. WYRICK,
THOMAS E. PATTERSON, and
RAYMOND L. JONES
CERTIFICATE OF SERVICE
MARK T. RILEY, ESQUIRE, being duly sworn and according to law hereby certifies that a true and
correct copy of Defendant's Damage Interrogatories, Expert Witness Interrogatories and Request for
Production of Documents to Plaintiff were forwarded to counsel on July 26, 2006 and said documents were
sent first class mail, postage prepaid, to the last known address of the other parties or their representatives.
Debra K. Wallet, Esquire
24 N. 32nd Street
Camp Hill, PA 17011
MARSHALL, DENNEHEY, WARNER,
COLEMAN GOGG
BY:
MARK T. RILEY,
Attorney for Defendants
X26 A\LIAB\MTRILEY\DISC\207171\MMKISSLQIG\05130\00541
MARSHALL, DENNEHEY, WARNER Attorney for Defendants
COLEMAN & GOGGIN
BY: MARK T. RILEY, ESQUIRE
IDENTIFICATION NO. 49427
620 Freedom Business Center, Suite 300
King of Prussia, PA 19406
(610) 354-8259
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
JAMES H. SLYDER
V.
. . NO.: 06-3762
DICKINSON TOWNSHIP,
DANIEL E. WYRICK,
THOMAS E. PATTERSON, and
RAYMOND L. JONES
REQUEST FOR PRODUCTION OF DOCUMENTS AND THINGS
OF DEFENDANTS ADDRESSED TO PLAINTIFF
With respect to the matters referred to in Plaintiffs Complaint, please note that you are directed to produce
for purposes of inspection and/or copying, the following items, all of which relate to the matter referred to in
Plaintiffs Complaint. These items must be produced no later than thirty days from the date of the filing of this
request. Same may be provided by forwarding copies to the office of the undersigned at 620 Freedom Business
Center, Suite 300, King of Prussia, PA 19406.
These requests are not directed merely to the person or party whose name appears above, but are meant to
include that person's or party's agents, servants, insurers, employers, employees, investigators, attorneys, and others
similarly situated to the named party or person.
In addition„ although the request seeks these documents within the next thirty (30) days, the request should
also be deemed continuing, in that if there are further
come under the purview of any of these
state, federal, or local agencies who have investigated the incident described in Plaintiffs Complaint, and which
data or reports are in your possession.
10. If the incident described in Plaintiffs Complaint has as its background, a construction project or a series
of negotiations leading up to a particular transaction or a series of meetings, memoranda, records, drawings,
contracts, minutes, and other documents or records which pertain to that underlying project or transaction which
bear upon or have reference to the incident described in Plaintiffs Complaint.
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOGGIN
BY:
MARK T. RILEY-,f3QbUP
Attorney for Defendants
Date: 07/26/06
3
X26 AILIABUNTRILEYIDISC1$07171VNMKISSLING\05130\00541
MARSHALL, DENNEHEY, WARNER
COLEMAN & GOGGIN
BY: MARK T. RILEY, ESQUIRE
IDENTIFICATION NO. 49427
620 Freedom Business Center, Suite 300
King of Prussia, PA 19406
(610) 354-8259
Attorney for Defendants
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
JAMES H. SLYDER
V.
NO.: 06-3762
DICKINSON TOWNSHIP,
DANIEL E. WYRICK,
THOMAS E. PATTERSON, and
RAYMOND L. JONES
DEFENDANTS' DAMAGE INTERROGATORIES DIRECTED TO PLAINTIFF
Defendants, by and through its attorneys, MARSHALL, DENNEHEY, WARNER, COLEMAN &
GOGGIN, hereby propound the following interrogatories under and pursuant to Pennsylvania Rules of Civil
Procedure No. 4005. These interrogatories are to be deemed continuing so as to require further answer from
now until the time of trial without further notice, if you learn further information called for herein. These
interrogatories are addressed to you as a party to this action, and answers shall be based upon the information
known to you, your attorney, or other representatives.
The terms accident or incident refer to the occurrence described in Plaintiffs' Complaint which Plaintiffs
allege gave rise to Plaintiffs' injuries and/or damages.
These interrogatories must be answered separately and fully by you in writing under oath.
The answers must be signed by you and under Pennsylvania Rules of Civil Procedure No. 4006 you
must serve the answers on the attorney
>ervice of these interrogatories.
Please disregard any gaps in numbering.
1. - Definitions:
A. "You" or "your" shall mean the person or entity to whom these interrogatories are addressed; or any
agent or person acting on your behalf.
B. "Person" or "persons" shall mean any natural individual or any corporation, firm, partnership,
proprietorship, association, entity, joint venture, or other business organization.
C. "Document" shall mean any original written, typewritten, handwritten, printed or recorded material
as well as all tapes, non-duplicate copies and transcripts, now or at any time in your possession, custody or
control. Without limitation of the term "control" as used in the preceding sentence, a document is deemed to be
in your control if you have the right to secure the document or a copy thereof from another person, of public or
private entity which has actual possession thereof. If a document was, but is no longer in your possession or
subject to your control, state what disposition was made of it, by whom and the date or dates, or approximate
date or dates, on which such disposition was made and why.
II. Instructions:
In responding to these interrogatories, respondent shall follow the instructions set forth below:
A. The person to whom these interrogatories are addressed shall answer the interrogatories below
under oath within thirty (30) days of service hereof, or such shorter time as the Court may order.
B. In answering these interrogatories, each answering party shall furnish all information available at the
time of answering.
2
C. If you do not answer an interrogatory in whole or in part because of a claim of privilege, set for the
privilege claimed, identify the facts upon which you rely to support the claim of privilege, and identify all
documents for which such privilege is claimed.
D. When a natural person is required to be identified, state his name, business and/or residence address.
E. "Or" shall be construed either conjunctively or disjunctively to bring within the scope of these
interrogatories any information which might otherwise be construed outside their scope.
F. The singular includes the plural, and vice versa, the masculine includes the feminine and neuter
genders. The past tense includes the present time where the meaning is not distorted by a change of time.
G. When and if the responding party to these interrogatories answers any interrogatory with the phrase
"see medical records" or like answer, then with respect to such medical records, identify the specific record, the
type of document, its date and title and its present location.
III. INTERROGATORIES
In the above entitled matter, addresses the following interrogatories to be answered under oath:
1. You have indicated that certain losses have been sustained by you because of the matter or matters
declared upon in your Complaint. Set forth fully, completely, and with absolute precision, the factual basis upon
which you arrived at the allegations of damages. In so doing, be sure to give an express accounting and breakdown
by category, such as labor costs, replacement value, actual cash value, materials used, business losses, and any
other category of loss which can be quantified. It is the purpose of the party submitting these interrogatories that the
party answering state every basis and fact that will be set forth at trial to prove damages.
2. With regard to the information and facts set forth in the preceding interrogatory, please identify all
documents, records, data, recordings, maps, charts, photographs, electronically stored data, work sheets, diagrams,
blueprints, memoranda, and any and all other forms of printed, photographed, and/or electronically stored data that
you will use to support these allegations. In lieu of identifying these requested items, you may attach copies to
these answers to interrogatories, taking care to make reference to them in the body of your answer to this question.
With regard to the information supplied in the preceding two interrogatories, please identify fully,
by giving name, home address, business address, and any other necessary identifying information about the
person or persons who will be able to testify in support of your damage allegations, and state with regard to
each person, the information supplied by that person, its source, and a brief description of what that person
would testify to at trial, if called to so testify.
4
4. Please-set forth each and every factual basis for Plaintiffs contentions in paragraph 25 of
Plaintiffs Complaint and attach a copy of the writing referred to therein.
5. State when you contend that Daniel Wyrick learned that Plaintiff had made a complaint with the
State Ethics Commission and set forth each and every factual basis for said contention in detail and with
specificity and attach any supporting documents hereto.
6. Se forth each and every factual basis for the contentions set forth in paragraph 24 of Plaintiffs
Complaint in detail and with specificity and attach any supporting documents hereto.
7. Set forth a full and complete description of any and all complaints made by Plaintiff to the
Pennsylvania State Ethics Commission, including but not limited to the following:
(a) The date each such complaint was made;
5
(b) -To whom each such complaint was made;
(c) Whether each such complaint was verbal or written and, if written, attach a copy hereto.
(d) The substance of each such complaint;
(f) Whether Plaintiff advised anyone, other than the State Ethics Commission, that he had
made such complaint and, if so, the identity of the person whom Plaintiff so advised and the date on which each
such person was so advised.
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOGGIN
BY:
,
MARK T.
LEY
Attorney for Defendants
Date: 7/26/06
6
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JAMES H. SLYDER,
Plaintiff
No. 06-3762
V. Civil Action - Law
DICKINSON TOWNSHIP; DANIEL E.
WYRICK; THOMAS E. PATTERSON;
AND RAYMOND L. JONES,
Defendants
PLAINTIFF'S RESPONSE TO DEFENDANT'S REQUEST FOR PRODUCTION
OF DOCUMENTS AND THINGS
Plaintiff, by his attorney Debra K. Wallet, makes the following response, including
certain limited objections, to Defendant's requests:
1. The Patterson statement is attached. Some newspaper articles saved by the
Plaintiff are attached.
Parties to this action and persons aware of some of the incidents referred to in the
Complaint testified at an unemployment compensation hearing on May 15, 2006 and gave
statements as part of documents submitted in these unemployment compensation proceedings.
It is believed that Defendants have copies of the transcript of the hearing and those other
documents made a part of the unemployment compensation proceedings. If not, the transcript,
correspondence, and exhibits will be made available for inspection and copying.
Plaintiff objects to producing the complaint made to the State Ethics Commission and
the documents relating to his complaint, including the correspondence from the Ethics
Commission because: (1) the specifics
of that charge are
not relevant to the subject matter involved in the pending action and are beyond the scope of
discovery pursuant to Pa. R.C.P. 4003.1(a); only the facts that the charge was made, when it
was made, and against whom it was made are relevant and (2) disclosure would subject
Plaintiff to penalties for violating the confidentiality provisions of the State Ethics Act, 65 Pa.
C.S. §§ 1108(k) and 1109(e).
2. None as of the date of this answer.
3. None.
4. None except for the Dickinson Township Personnel Manual and the tax returns,
including W-2 statements, attached in response to number 6 below.
5. A copy of pay stubs in the possession of Plaintiff are attached. Defendants have
the Dickinson Township Personnel Manual, but this will be produced for inspection and
copying if they do not.
6. A copy of Plaintiffs joint federal tax returns for the years 2004 and 2005 are
attached. A W-2 statement from Dickinson Township is attached to the 2004 and 2005
returns. Plaintiff objects to the production of the tax returns for any year prior to his
employment with Dickinson Township because they are irrelevant and beyond the scope of
discovery under Pa. R.C.P. 4003.1(a).
7. None. No expert has been retained.
8. After reasonable investigation, it has been determined that there are none which
are responsive to this request except for the Patterson statement being produced, and notes
made by Attorney Debra K. Wallet in interviewing her client or as part of the unemployment
compensation proceedings, which notes are privileged.
2
9. After reasonable investigation, it has been determined that there are no
governmental or quasigovernmental agencies which investigated any matters except for the
unemployment compensation authorities and the State Ethics Commission. See the answer to
number one herein with respect to the unemployment compensation authorities. The Plaintiff
has no report from the State Ethics Commission.
10. None. This is not a construction project.
Respectfully submitted,
04%., K. UM&J-
Debra K. Wallet, Esq.
24 N. 32nd Street
Camp Hill, PA 17011
(717) 737-1300
I.D.# 23989
Attorney for Plaintiffs
3
IS
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-
Officials consider supervisor pay
? At issue is when elected officials should receive supplementary income.
m i
By Jennifer Marrs between June 1, 2004, and June 1, 2005.
Sentinel Reporter
Imarrs@cumbedink.com That's in addition to his supervisor's pay, which
amounts to $1,875 a year.
A worker's compensation audit revealed that a Wyrick said he records time he spends in rown-
Dickinson Township supervisor has been submit- ship staff meetings because he takes time out of
t ting bills for work he said goes beyond the usual his work schedule as a commissioned salesman to
usual supervisory duties. attend the meetings.
The records show that Supervisor Dan Wyrick
billed the township $1,310 in hourly wages • See Dickinson, 85
L
.n+Yo 11%. wuuu LULCO wCallug a was when authorities whisked
Utreetly below htiteman s Ucwic. Jcuivu says.
S
Dickinson sad
"e
dui
• Continued from Bi
er's compensation coverage is
Township Supervisors (PSATS)
Wyrick said auditors set wages e?
going up by $6 a year because of about the pay issue more than a for supervisors as "part-time sta
He said the staff meetings are the additional wages paid to year ago and was told he could be employees" outside of supervi- bli
necessary to conduct business Wyrick compensated fo!additional duties sory duties so they can claim Fa
because the township doesn't have Dickinson Township Solicitor outside of his normal supervisory additional wages "if they come ye.
a manager who would take care of Marcus McKnight III said later he duties. in and work for the township" Fo
the tasks addressed at the meet- was unaware until the meeting that He said PSATS told him there is on various jobs, "whatever that -I
ings. s
" Wyrick was "seeking pay for stag' "a fine line" between supervisory job may be."
w h
Nothing's been done wrong," meetings." duties and work as an employee, But S 1 y de r, whose duty as
-
Wyrick said. "Supervisors have During the meeting, McKnight but since Dickinson doesn't have a office manager includes signing
known this since last year .. said he will call Selective Insur- township manager, the "role is off on time sheets, said he told
He also questioned the $1,310 ance and report back to supervi- being filled by supervisors filling Wyrick in June or July of this
figure, and thinks it may include sors in the future. in at staff meetings:' year that he believed the charges
his attendance at "authorized
" "We'll have to talk about this," Holly Fishel, director of research were "inappropriate," as his
meetings
such as the Pennsylva- he said to Wyrick. and policy development for understanding is that supervi-
ma State Association of Township The other two supervisors, PSATS, said the "basic rule" is sors should not receive addition- cat
Supervisors' annual convention in August Ginter and Thomas Patter- that any additional payment would al wages for anything other than the
Hershey. son, said they have not received be appropriate if a supervisor is serving on the road crew. the
Selective Insurance, which con- pay for attending staff meetings, employed by the other supervisors Slyder said Wyrick's response
ducted the worker's compensation' though Ginter, who works full- for a certain job and the board of was that he had checked with
auidt, had no comment on the time on the township road crew, auditors authorizes and sets the PSATS and the extra charVs
issue when reached by a reporter said he takes "comp time" for wage. She said supervisors should were permitted rrs
Wednesday them. not be paid additional wages for Slyder said he wouldn't sign n0
Wyrick said supervisors make Patterson said later that he never work that is a supervisory duty. off on any of the time sheets. ad'
"somewhere around $15 per hour" charged for attending the meetings Fishel wouldn't comment on though Wyrick continued to rile 8;
for part-time work at the township
outside of their supervisor
duties because he "hasn't been able to
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" specifics with the Dickinson them. V'
y
. [Ha
e most o
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em. Township case. Slyder, who is also township
Letter discussed He said he would have no fur- She added that organization's roadmaster, said supervisors a
Township office manager Jim Cher comment until he hears the
solicitor's report role is to "try to veer supervi-
sors in the right direction" but Wyrick and Patterson were
appointed as part-time road tc
Slyder presented a letter from
Selective Insurance at this week's
Differing views not to give "legal advice."
Township solicitors provide the crew workers in case their assis-
tance is needed during emergen- er.
th,
supervisors' meeting, indicating, Wyrick said he called the Penn- legal advice, she said. cies, while Ginter is a full-time PI)
the township's premium for. yg#,, ;. AY-i ?anii State.Associatipq of , After.
4his wpek's meeting,
, paid member of the road crew.
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-onesday, October S. 2005 Local
www.cumbertink.com
DICKINSON TOiVvsrfIP
Township officials clash
? A reprimand that was supposed to stay
private prompts the solictor to criticize a
supervisor.
By Jennifer Marrs
Sentinel Reporter
jmarrs@cumbef ink.eom
Dickinson Township Solicitor
Marcus McKnight III said he
"can't trust" Supervisor Dan
Wyrick after he disclosed private
information to a newspaper
reporter.
Upset over the leak and over
other issues involving Wyrick.
Marcus McKnight spent 30 min-
utes delivering one, two and then
a third punch Wyrick's wav at
Monday's meeting of the board of
supervisors.
"You've crossed the tine in this
township with me," McKnight
said later in the meeting despite
Wyrick's denials of the allega-
dons.
Letter leaked
McKnight said he gave Wyrick
a letter concerning a private repri-
mand issued to township Road-
master Jim Slyder during an exec-
utive session.
He said he believes Wyrick is
responsible for the leak because
he gave him the only unsigned
copy of the letter- the same let-
ter that showed up in the hands of
a reporter.
Of the other two copies, which
were signed. one went into a file
and one went to Slyder. McKnight
later said.
"?hat creates a real problem for
me:' McKnight said. "Confiden-
tial information can no longer be
given to Mr. Wyrick."
Wyrick said he did not give the
letter to the reporter. He also men-
tioned the Sunshine Act, which he
said states "disciplining an
employee must occur in a public
meeting."
"It was improper to give this to a
reporter privately," McKnight told
Wyrick. "I can't trust you now:'
McKnight said Tuesday that
Wyrick may not have "physically"
given the paper to the reporter but
he may have given the letter to
someone else to give away.
"He disclosed it, there's no
question in my mind:' McKnight
said.
Because, of the leak. McKnight
said he had no choice but to make
the reprimand known, explaining
that Roadmaster Slyder took some
actions that "either directly or
indirectly benefited himself."
Slyder used township labor and
machinery to remove trees that
"happened to be on some of his
rental property" in Mt. Holly
Springs. took a tree he cut down
for a township resident onto his
property and used some money
from recycling leftover township
metal to pay for a party with some
of the township staff.
The roots of the trees in Mt.
Holly were "causing problems for
the sewer system in the borough,"
he later said.
McKnight said Slyder admitted
his error in judgment and apolo-
gized. He will reimburse the
township $393.28.
"He is on probation until the end
of the year," the solicitor said.
Pay for meetings
Also Monday, McKnight
addressed the issue of Wyrick
putting in for compensation
beyond his annual supervisory
pay of $1,875 for attending staff
meetings.
A workers' compensation audit
last month. showed that Wyrick
billed the township $1,310 from
June 2004 to June 2005 for attend-
ing the meetings.
"Compensation has to be set by
auditors," McKnight said, adding
that the board of supervisors must
authorize a supervisor for a posi-
tion that would draw any addition-
al pay. Supervisors can also
receive compensation for attend-
ing authorized conventions, the
solicitor said.
McKnight said Wyrick talked
with the Pennsylvania State Asso-
ciation of Township Supervisors
(PSATS), which can give advice,
but never came to him for legal
advice
"Had he asked, I would have
looked into it and have been able
to take care of it," McKnight said.
He said the annual salary of a
supervisor remains the same no
matter how many hours he works.
This, he says, has always been the
case and he doesn't know why it
is a "mystery" to Wyrick.
Wyrick questioned the accuracy
of McKnight's comments during i
Monday's meeting. The supervi-
sor said the $1,310 cited the audit
included time he spent at autho-
rized conventions.
He has acknowledged he did put
in hours for attending staff meet-
ings, saying he do so because he
had a "different interpretation" of
when he could put in for compen-
sation.
Concern over reports
McKnight also expressed con-
cern over reports that Wyrick led
Ray Jones, who won both the
Republican and Democratic nomi-
nation for supervisor in this year's
primary election, into the town-
ship late at night to look through
files.
"We know he has a political
alliance with Ray Jones:" McK-
night said.
Wyrick's comeback was that
the "accusation" is a "bald-faced
lie:'
Jones also spoke publicly, citing
his steadfast attendance at town-
ship meetings and denying ever
coming to the building to look
through files.
"My main concern is it doesn't
happen again;'. McKnight said
Tuesday, adding that if Jones says
he didn't do it, then he believes
him.
McKnight concluded his
remarks Monday by advising
supervisors, "Don't ask for com-
pensation you know you're not
entitled to" and "let the staff do
their jobs."
He cited ongoing tension
between Wyrick and the township
staff, adding that many staffers
think Wyrick and Jones, if elected,
will decide to fire all of the staff
members and replace them.
"Unfortunately," McKnight said
"there's been confrontation time
and time again."
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Dickinson
• Continued from B1
'-temporary' posts
Other changes passed 2-1,
with Patterson voting "no,"
included an up to 120-day tem-
porary reappointments of Bertha
MWer;as secretaryand Jonathan
Re?sj SC s sewage 4:jXprci
ment officer, zoning officer,
codes enforcement officer and
building codes official.
"Why are you making tempo-
rary appointments?" resident
Norm Elam asked. "Politics
should not be a reason. You're
talking about these guys' bread
and butter.... I'm 100 percent
against what you are doing."
Wyrick said the action was
taken "so all positions can be
looked at," adding the board
hasn't "had a chance" to look at
possible choices "so we can
have the best person we can
have in this township."
Solicitor removed
Supervisors unanimously
appointed former solicitor Ed
Schorpp as their new solicitor
and voted 2-1 for Keith Brene-
mann to serve as solicitor for
the planning commission. McK-
night had served as solicitor of
both.
Patterson questioned the
removal of McKnight, although
he agreed Schorpp is also quali-
fied.
"Marcus has served the town-
ship well," Wyrick said, adding
Schorpp "did also for 12 years."
Planning commission member
Tim Hoffman said McKnight's
been a joy to work with."
However, McKnight said he's
"always" looked at his position
with the township as a "tempo-
rary one," adding, "If' you find
someone you like better, by all
means make the appointment.
You've made that decision, I'm
fine with it."
He added his time serving the
township has "never been boring."
Supervisors also:..
• Reinstated Robe:, O'Brien
as solicitor for the zoning hear-
ing board.
• Reappointed Thomas Masten
and replaced current member
Ward Cooper with Bob Shields
on the planning Qommission.
• Named Troy Fuss and Allen
Light as park and recreation
board members to replace Larry
Foote and Scott Hackenburg,
both of whom wanted to end
their service.
• Raised wages from $200 to
$300 per quarter for Ivan and
Greg Bretzman, who were rein-
stated as fire chief and assistant
fire chief, respectively.
• Selected Rettew Associates
of Camp Hill as township engi-
neer, replacing Brehm-Lebo.
Disagree with changes
Regarding the changes made
by supervisors, Hoffman said
they shouldn't replace Cooper
"just because he doesn't always
agree" with them on "issues."
"It seems like there are double
standards when it suits your
agenda," said Hoffman's wife,
Lori.
She wondered why supervi-
sors gave temporary appoint-
ments to some while replaced
others right away.
"You're putting old people
back in," she said.
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Ncv4room a-mail: fi mtd com
Sports e-mail: sporWoor®cumberUt&com
SENTINEL .EDITORIAL
Let the sun shine.
Dickinson Township supervisors ensure the citizens would have the
went into executive session for 20 benefit of differing viewpoints and
minutes on Monday. then, finally, call for a vote.
As mandated by the Sunshine Law, Instead they voted a secret action in
they gave one of the established rea- public, only advising anyone attend-
sons for discussing business behind in 'a the meeting that the vote was
closed doors. The one used was "per- about what officials talked about,
sonnel." Other. exceptions could be when they left the public meeting
contract negotiations and litigation. room.
When they came out of the private Dickinson residents should object...
meeting, they held a vote. loudly.
Supervisors Dan Wyrick and Ray Questioned this morning, township
Jones voted "yes" and Supervisor solicitor Ed Schorpp said "confiden-
Tom Patterson voted "no." tial information on personnel mat-
And so what the trio discussed out- ters" cannot be divulged without per-
side of the hearing of the public was mission from the employee involved.
approved 2-1. Since the township hasn't hired
Do you feel informed? anyone to "hire, fire, supervise and
Hardly. discipline," he says the supervisors
On the surface, the supervisors fol- had to vote publicly on what they dis-
lowed the law by not trying to vote cussed in executive session.
on the issue while still in executive Schorpp says the township will
session. soon hire a permanent township man-
However, they did not in any way ager who can deaf with such issues
meet the intent of Pennsylvania's outside of public meetings.
Open Meeting Act, also known as the That doesn't. wash with us.
Sunshine"Law. Moves such as this one are clearly
Prior to a vote, the officials had an designed to circumvent the spirit of
obligation to make a motion and have the law. The citizens have been
someone second it during the public locked out as information was hidden
portion of the meeting explaining the in plain sight - information that is
issue, hold public discussion to rightfully theirs to know.
k
? LIll;?
;,?,0r;
- -_1 .
Drcatrvsorv TOwsare
Supervisors give
explanation
for'secreY vote. A
By-Jennifer Marrs
Sentinei Reporter
jmarrs@cumberiink.com
Dickinson Township Supervisor Dan Wyrick issued a press
release this morning to clarify the vague motion offered publicly
by supervisors Feb. 6 following an executive session about a per-
sonnel matter.
Following the executive session, Wyrick and Supervisor Ray
Jones voted for a motion to enact "what we discussed" during
executive session, while supervisor Tom Patterson voted against
it.
"It is regrettably unfortunate that the action.... raised uncertainty
as to. the manner of conducting township affairs," Wyrick said in
this morning's release.
"Due to extremely sensitive considerations and legal ramifica-
tions which may not be openly discussed, and upon the advice of
the solicitor, it was deemed inappropriate to provide the specific
substance of the motion," he said.
Vote topic to come up again
But "because of the subsequent questions which have been
raised," he offered clarification on the action, which he says will
be "re-taken at a future meeting."
Wyrick said the board authorized the township's special per-
sonaeLcounsel, Campbell, Durrant and Beatty, "to provide legal
e See Vote, B3
.:,,-2--.-1 - (f `%4?
Vote -
n a • Continued from B1
Hers
nes services with respect to a per-
es" sonnel matter involving the
are position of township secretary.
Those services may or may not
tu- lead to future action by the
-v) board relating to the position."
of He adds supervisors have
"previously and publicly
engaged the services of this firm
to provide advice on personnel
matters, and the vote on Feb. 6
may very well have been unnec-
essary"
Nevertheless, upon the advice
of the solicitor, "it was taken to
remove any uncertainty as to the
scope of the prior engagement."
Wyrick also said the two.other
supervisors, Jones and Patter-
n
son, were aware that he was
issuing the clarification of the
board's action.
Reached yesterday. township
secretary Bertha Miller said she
is having health problems and i,
on sick leave" due to "stress."
She does not know when she
may return to work and said she
has no further comment at this
time.
. c? r -?
B4 THE PATRIOT-NEWS THURSDAY, FEBRUARY 9, 2006 F
DICKINSON TWP.
Board keeps reason
behind vote a secret
BY ANDREA CICCOCIOPPO
Of Our Carlisle Bureau
CARLISLE • The ethics and le-
gality of action taken Monday
by the Dickinson Twp. super-
visors might be challenged be-
cause it could violate state
law.
After a late-night executive
session, the supervisors voted
2-1 on a personnel matter, but
provided residents with no
discussion or explanation of
the vote.
"That's not sufficient. They
have to disclose what they're
voting on," said Terri Hen-
ning, media law counsel for
the Pennsylvania Newspaper
Association. "They must take
action in front of the public.
They're not taking the action
in public if they're not telling
the jublic what they're voting
on."
She said the vote. is subject
to challenge.
Supervisors Ray Jones and
Dan Wyrick voted in favor of
a motion to take action on the
personnel issue, which had
been discussed during an ex-
ecutive session.. Supervisor
Tom Patterson voted against
it.
Wyrick said he was advised
by the township solicitor, Ed
Schorpp, to keep it nonde-
script. "It was extremely
vague and intentionally so,"
he said.
When asked if the vote was
legal, Wyrick replied, "I'm not
an attorney, but I believe and
understand that it is and it
was; otherwise I would not
have. done it as such."
Since its reorganization last
month, the board has ad-
dressed several personnel is-
sues. It has replaced the engi-
neer, solicitor, road master
and assistant sewage enforce-
ment officer, placed the sew-
age enforcement officer and
secretary/treasurer on
120-day interim positions; and
hired two part-time office
managers.
The board also hired a tem-
porary assistant treasurer and
temporary clerical help.
The board meets at 7 p.m.
Feb. 20 in the township build-
ing on Mountain View Road.
ANDREA CICCOCIOPPO: 249-2006
or aciccocioppo@patriot-news.com
i P -` .)10 5
m
? O
?N Z
3M
DISPUTE: He's frozen out by colleagues, supervisor says
Continued from Page BI
His frustration is the latest in a string of re-
cent flaps in Dickinson initiated by supervi-
sors Dan Wyrick and Ray Jones.
In January, Wyrick and Jones dismissed the
township engineer, solicitor, road master and
assistant sewage enforcement officer. They
put two employees on probation and hired
former supervisors Ron Wolfe and Bob Liv-
ingston to run the office and carry out such
duties-as signing employee paychecks. Patter-
son voted against the personnel changes but
was overruled by Wyrick and Jones.
Last month, the board had to revote on a
personnel matter because they failed to dis-
close specifics of the action as required by the
state open records Sunshine Act.
Wyrick said the decision to change the locks
was made by "the majority of the board along
with the office managers," and done to make
certain areas of the building more secure..
Patterson said he knew locks were to be
changed, but wasn't given a date and no one
offered him a key.
Jones said everyone had to sign for new
keys and, had he not attended a parks and rec-
reation committee meeting and picked up his
key, he, too, would have been locked out.
Patterson said he's tired of being forced to
snoop around for public records. "They
DICKINSON TWP.
Colleagues
supervisor
BY ANDREA CICCOCIOPPO
Of Our Carlisle Bureau
should be offered to me 'as an elected public
official," he said. "We are 'all elected supervi-
sors. If they are informed anymore than I am,
we've dot a problem."
Wyrick countered that it's up'to Patterson
to take the initiative. "One has to be proactive
and participate," he said. : .
Wyrick questioned why, Patterson failed to
attend Monday's board meeting.,
Patterson said his absence was due to illness
and he called township staff in advance. Wy-
rick and Jones, however, told residents at
Monday's meeting that they, didn't know. why
Patterson was absent.
"I heard the phone ringing. There probably
was a message on there. I didn't follow up on
it," Jones said yesterday.
Patterson doesn't know. why he's being shut
out. "They've kept people in the dark of what
they're doing in this township," he said. "I feel
no matter what I say anymore, I'm being push-
ed into a corner." ! , I
Jones said "There's no friction at all. We're
trying to find a way to get him in with us."
"I'm not going to be part of a clique," Patter-
son responded. "1'm not changing my philoso-
phy or character to suit them.:I'm just trying
to do my job."
ANDREA CICCOCIOPPO' 249-2006 or
aciccocloppo@patriot-news.com
isolate hiffi),
complains
issues, and they don't give
him official records of past
meetings.
This weekend, on his usual
trip to the municipal building
to bone up on issues that,will
rnme before the board, he dis-
CARLISLE * Longtime Dickin-
son Twp. Supervisor Tom
Patterson says his colleagues
1_:__ .. .....-.e?;1.lo fir
tsw etFtrra. m. •?+•?
THE PATRIOT-NEWS TUESDAY, MARCH 21, 2006 65
DICKINSON TWP.
Supervisors
dismiss
secretary
BY ANDREA CIC60CIOPPO
Of Our Carlisle Bureau
CARLISLE a The Dickinson
Twp. supervisors last night
unanimously agreed to fire
township secretary Bertha
Miller.
The board also announced
it has forwarded to the Cum-
berland County District At-
torney's office the results of
an examination of township
records by the office manag-
ers and auditors.
Supervisor Dan Wyrick de-
clined to provide details. "It's
in the hands of the district at-
torney's office," Solicitor Ed
Schorpp said.
Wyrick said Miller has tak-
en unspecified legal action ;
against him and he has asked.
her to drop her lawsuit.
Miller couldn't be reached
for comment last night.
Miller's. dismissal is the lat-
est in a series of firings that
began in January, when the
board dismissed the township
engineer, solicitor, road mas-
ter and assistant sewage en-
forcement officer; put two
employees on probation; and
hired former supervisors Ron
Wolfe and Bob Livingston to
run the office and carry out
such duties as signing em-
ployee paychecks.
ANDREA CICCOCIOPPO: 249-2006
or aciccocioppo@patriot-news.com
DICKINSON TWP.
tm
I!Z&M
0
N
•C V
Former
treasurer
charged
in theft
BY MATE MILLER
AND ANDREA CICCOCIOPPO
Of Our Carlisle Bureau ,
MOUNT HOLLY' SPRINGS e A month after
being fired, `former - Dickinson Twp.
secretary-treasurer Bertha R. Miller
has been charged ;with. embezzling
nearly $15,000 and forging insurance
documents.
The charges, filed yesterday by a
Cumberland County detective, stem
from a probe sought by, township su-
pervisors.
"I had questioned her competen-
cy," Supervisor Chairman Dan Wy-
rick said. "I wouldn't have thought
her incompetency went any further,
than that."
Miller„ 57, of South 'Middleton
Twp., faces 22 forgery counts, 11
counts of theft by deception and sin-
gle counts of insurance-fraud, tam-
pering with public records, and se-
curing execution of documents by
deception. She is to be arraigned
Monday.
Miller wouldn't comment on the
case, but in aletter to supervisors
wrote, "I am so sorry for betraying
the trust you bestowed upon me.
"I did not set out to hurt or embar-
rass anyone and, in the end, I have
only hurt myself,,." she wrote. "I will
take every step within my power to
repay all of the township money that
Thn-l, --n- T-"
r?
84
Former employee's suit
claims firing was illegal
BY ANDREA CICCOCIOPPO
Of Our Carlisle Bureau
CARLISLE • Dickinson Twp.
and its three supervisors are
being sued by a former town-
ship employee who claims he
was illegally fired for being a
whistle-blower.
James Slyder was a road
master and part-time office
manager until January, when
he was discharged.
In a lawsuit filed in Cum-
berland County Court; Slyder
claims the supervisors - Dan
Wyrick, Ray Jones and Thom-
as Patterson - had no legiti-
mate work-related reasons to
fire him.
In his suit, Slyder- allegges
that he was terminated be-
cause he challenged Wyrick
when the supervisor filed
time sheets. Slyder believed to
ife
An essential part of Iffe
Sunday through Friday
_ ..-QIt Pa.ftiot 1kuji
Now you knew
be improper.
Slyder claims that shortly
after being appointed part-
time office manager in April
2005, he learned that Wyrick
was submitting requests to be
paid for work that the board
of supervisors had not author-
ized.
Slyder expressed concern
to Wyrick that it was not law-
ful or ethical for Wyrick to re-
ceive payments in 2004 and
2005 above the stipend Wy-
rick received as a supervisor.
It was especially improper for
Wyrick to receive pay for
work performed without au-
thorization, Slyder said.
According to township. re-
cords, in August 2005 Wyrick
billed the township $1,310 in
addition to his annual super-
visor's pay of $1,875.
At the time, Wyrick denied
that he was doing anything
improper, illegal or unethical,
claiming he charged for staff
meetings in addition to super-
visors meetings, which are
covered by his regular salary.
Slyder claims he received
satisfactory performance eval-
uations signed by Patterson
and former Supervisor August
Ginter, and was removed
from probationary status
three days before he was let
go by the new board of Patter-
son, Wyrick and Jones, which
took office in January.
Contacted yesterday, Wy-
rick had little to say about the
suit. "I have been made aware
of it, but rve seen no docu-
mentation," he said, declining
further comment.
Slyder is asking the court to
reinstate him to both jobs,
with back pay, and legal fees.
The suit is the latest epi-
sode in the turmoil that has
wracked Dickinson.
Since January, the supervi-
sors also have dismissed the
township engineer, solicitor
and assistant sewage enforce-
ment officer.
In March, they fired
secretary/treasurer Bertha
Miller. A month later, a coun-
ty detective charged Miller
with embezzling nearly
$15,000 in township funds and
forging insurance documents.
Her case is pending before the
county court.
Miller filed a notice in
county court early this year to
sue Wyrick, but withdrew it
just before her firing.
ANDREA CICCOCIOPPO: 249-2006
or aciccocioppo@patriot-news.com
DICKINSON TWP. ?
ay' dUyY 8; 2006
Sa?rd
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DICKINSON TOWNSHIP
Employee SSN Status (Fed/State) Allowances/Extra--3
86
9
Slyder, James H. 429 Chestnut Street Mt Holly Springs, PA 17065 178-38-5441 MamedrWithhold -
-
Fed-210/PA-0/0
Pay Period: 12/3112004 - 01/1312005 Pay Date: 01/1412005
Earnings and Hours Oty Rate Current YTD Amounts
487.180 Holiday Pay 8:00 18.72 149.76 149.76
430.13 Road Crew Wages 63:00 18.72 1,179.36 1,179.36
430.131 Road Crew OT 7:00 28.08 196.56 196.56
432.131 Snow Removal OT 3:15 28.08 91.26 91.26
438.13 Road Maint Wages 8:00 18.72 149.76 149.76
1,766.70 1,766.70
Taxes Current YTO Amounts
Local Tax -28.27 -28.27
UC Employee Tax -1.59 -1.59
Federal Withholding -154.00 .154.00
Social Security Employee -109.54 -109.54
Medicare Employee -25.62 -25.62
PA - Withholding -54.24 -54.24
-373.26 -373.26
Net Pay 1,393.44 1,393.44
Non-taxable Company Items Current YTO Amounts
P.M.R.S. Company Contributio 176.67 176.67
DICKINSON TOWNSHIP GENERAL FUND, 219 MOUNTAIN VIEW ROAD. MT. HOLLY SPRINGS, PA 17065 717-486-7424, DICKINSON TOWNSHIP CUMBERLAND COU
ACKINSON TOWNSHIP
4029
Employee SSN Status (Fed/State) Allowances/Extra
Slyder, James H, 429 Chestnut Street, Mt Holly Springs, PA 17065 178-38-5441 Mamed/Withhold Fed-2/0/PA-0/0
Pay Period: 01/14/2005 - 0112712005 Pay Date: 0112812005
Earnings and Hours Qty Rate Current YTO Amounts
430.13 Road Crew Wages 46:30 18.72 870.48 2.049.84 Non-taxable Company Items Current YTD Amounts
430.131 Road Crew OT 3:00 28.08 84.24 280.80 P M.R.S. Company Contributio 182.52 359.19
432.13 Snow Removal Wages 8:00 18.72 149.76 149.76
432.131 Snow Removal OT 18:00 28.08 505.44 596.70
487.177 Sick Pay 3:30 18.72 65.52 65.52
433.13 Signs Wages 2:00 18.72 37.44 37.44
438.13 Road Maint Wages 6:00 18.72 112.32 262.08
487.180 Holiday Pay 149.76
1,825.20 3.591.90
Taxes Current YTD Amounts
Local Tax -29.20 -57.47
UC Employee Tax -1.64 -3.23
Federal Withholding -163.00 -317.00
Social Security Employee -113.16 -222.70
Medicare Employee -26.46 -52.08
PA - Withholding -56.03 -110.27
-389.49 -762.75
Net Pay 1,435.71 2,829.15
Paid Time Off Used Available
Sick 3:30 -3:30
DICKINSON TOWNSHIP GENERAL FUND. 2 19 MOUNTAIN VIEW ROAD, MT. HOLLY SPRINGS, PA 17065 717486-7424, DICKINSON TOWNSHIP CUMBERLAND COU
)ICKINSON TOWNSHIP
4082
Employee SSN Status (Fed/State) Allowances/Extra
Slyder. James H. 429 Chestnut Street, ML Holly Springs. PA 17065 178-38-5441 Married/Withhold Fed-210/PA-0/0
Pay Period: 01/28/2005 - 02110/2005 Pay Date: 02111/2005
Eamings and Hours Qty Rate Current YTD Amounts
430.13 Road Crew Wages 37:00 18.72 692.64 2.742.48
432.13 Snow Removal Wages 3:00 18.72 56.16 205.92
439.13 Road Construction Wa 15:00 18.72 280.80 280.80
432.131 Snow Removal OT 7:30 28.08 210.60 807.30
409.12 Building Hourly Pay 1:00 18.72 18.72 18.72
487.177 Sick Pay 16:00 18.72 299.52 365.04
430.131 Road Crew OT 3:00 28.08 84.24 365.04
487.180 Holiday Pay 149.76
438.13 Road Maint Wages 262.08
433.13 Signs Wages 37.44
1,642.68 5,234.58
Taxes Current YTD Amounts
Local Tax -26.28 -83.75
UC Employee Tax -1.48 -4.71
OPT -10.00 -10.00
Federal Withholding -135.00 -452.00
Social Security Employee -101.84 -324.54
Medicare Employee -23.82 -75.90
PA - Withholding -50.43 -160.70
-348.85 -1,111.60
Net Pay 1,293.83 4,122.98
Paid Time Off Used Available
Sick 19:30 -19:30
Non-taxable Company Items Current YTO Amounts
P.M.R.S. Company Conthbutio 164.27 523.46
TOWNSHIP CUMBERLAND COU
IICKINSON TOWNSHIP
Employee SSN Status (Fed/State) AllowancoWExtra 4123
James H Slyder, 429 Chestnut Street, Mt Holly Springs. PA 17065 178-38-5441 MamedlWithhold Fed-2101PA-0/0
Pay Period: 02/11/2005 - 02124/2005 Pay Date: 02/25/2005
Earnings and Hours Qty Rate Current YTD Amounts
438.13 Road Maint Wages 15:00 18.72 280.80 542.88 Net Pay 1,337.81 5,460.79
439.13 Road Construction Wa 26:30 18.72 496.08 776.88
430.13 Road Crew Wages 17:00 18.72 318.24 3.060.72 Paid Time Off YTD Used Available
437.13 Repairs 3 Maint Wage 1:30 18.72 28.08 28.08 Sick 25:30 -25:30
430.131 Road Crew OT 5:00 28.08 140.40 505.44
433.13 Signs Wages 1:00 18.72 18.72 56.16 Non-taxable Company Items Current YTO Amounts
432.131 Snow Removal OT 7:30 28.08 210.60 1.017.90 P M.R.S. Company Contributio 168.95 692.41
409.12 Building Hourly Pay 1:30 18.72 28.08 46.80
487.177 Sick Pay 6:00 18.72 112.32 477.36
439.131 Road Construction O 2:00 28.08 56.16 56.16
487.180 Holiday Pay 149.76
432.13 Snow Removal Wages _ 205.92
1,689.48 6,924.06
Taxes Current YTD Amounts
Local Tax -27.03 -110.78
UC Employee Tax -1.52 -6.23
Federal Withholding -142.00 -594.00
Social Security Employee -104.75 -429.29
Medicare Employee -24.50 -100.40
PA - Withholding -51:87 -212.57
OPT -10.00
-351.67 -1,463.27
DICKINSON TOWNSHIP GENERAL FUND. 219 MOUNTAIN VIEW ROAD, MT. HOLLY SPRINGS, PA 17065 717-486-7424, DICKINSON TOWNSHIP CUMBERLAND COU
)ICKINSON TOWNSHIP
4160
Employee SSN Status (Fed/State) Allowances/Extra
James H Slyder, 429 Chestnut Street. Mt Holly Springs. PA 17065 178-38-5441 Married/Withhold Fed-2/0/PA-0/0
Pay Period: 02/25/2005 - 03/1012005 Pay Date: 03!11/2005
Earnings and Hours Qty Rate Current YTO Amounts
432.13 Snow Removal Wages 23:00 18.72 430.56 636.48 Net Pay 1,422.30 6,883.09
430.13 Road Crew Wages 28:00 18.72 524.16 3.584.88
432.131 Snow Removal OT 11:00 28.08 308.88 1,326.78 Paid Time Off YTO Used Available
487.177 Sick Pay 5:00 18.72 93.60 570.96 Sick 30:30 -30:30
438.13 Road Maint Wages 10:00 18.72 187.20 730.08
437.13 Repairs & Maint Wage 1:00 18.72 18.72 46.80 Non-taxable Company Items Current YTO Amounts
439.13 Road Construction Wa 13:00 18.72 243.36 1,020.24 M.R.S. Company Contributio 180.65 873.06
487.180 Holiday Pay 149.76
430.131 Road Crew OT 505.44
433.13 Signs Wages 56.16
409.12 Building Hourly Pay 46.80
439.131 Road Construction 0 56.16
1.806.48 8,730.54
Taxes Current YTD Amounts
Local Tax -28.90 -139.68
UC Employee Tax -1.63 -7.86
Federal Withholding -160.00 -754.00
Social Security Employee -112.00 -541.29
Medicare Employee -26.19 -126.59
PA -Withholding -55.46 -268.03
OPT -10.00
-384.18 -1,847.45
DICKINSON TOWNSHIP GENERAL FUND, 219 MOUNTAIN VIEW ROAD, MT. HOLLY SPRINGS. PA 17065 7171386-7424, DICKINSON TOWNSHIP CUMBERLAND COU
ACKINSON TOWNSHIP
SSN Status (Fed/State) Alk wances/F_xtra .4241
Employee
James H Slyder, 429 Chestnut Street ML Holly Springs, PA 17065 5441 Mamed/Withhold Fed-2/0/PA-0/0
Date: 04/08/2005
P
Pay Period: 03125/2005 - 04107/2005 ay
Earnings and Hours Qty Rate Current YTD Amounts Medicare Employee -28.16 -172.60
487.180 Holiday Pay 8:00 18.72 149.75 299.52 PA - Withholding -59.63 -365.45
436.13 Storm Drain Wages 2:00 18.72 37.44 37.44 OPT -10.00
439.13 Road Construction Wa 26:30 18.72 496.08 2.508.48 1421.03 -2,494.24
430.13 Road Crew Wages 11:00 18.72 205.92 3,828.24
438.13 Road Maint Wages 1:00 18.72 18.72 823.68 Net Pay 1,521.17 9,409.34
487.177 Sick Pay 3:30 18.72 65.52 711.36
448.13 Water System Wages 4:00 18.72 74.88 74.88 Paid Time Off YTD Used Available
433.13 Signs Wages 3:00 18.72 56.16 112.32 Sick 38:00 -38:00
487.176 Personal 2:00 18.72 37.44 37.44
439.131 Road Construction O 45 28.08 49.14 119.34 Non-taxable Company Items Current YTO Amounts
409.121 Building Maint OT 30
%I 28.08 519.48 519.48 P.M.R.S. Company Contributio 194.22 1,190.36
430.131 Road Crew OT- 15 28.08 231.66 737.10
432131 Snow Removal OT 1,326.78
432.13 Snow Removal Wages 673.92
409.12 Building Hourly Pay 46.80
437.13 Repairs & Maint Wage 46.80
1,942.20 11,903.58
Taxes Current YTD Amounts
LocaiTax -31.08 7190.45
UC Employee Tax -1.75 -10.72 rJ r ?l
Federal Withholding -180.00 -1.007.00
Social Security Employee -120.41 -738.02
_._.....__.. _ .._. ....?. ?. ., ?, ., . .? "^I -u Afki VIC\u o nen UT Nni i v SPRINGS. PA 1717165 717486-7424, DICKINSON TOWNSHIP CUMBERLAND COU
)ICKINSON TOWNSHIP
EmplOYee SSN Status (Fed/State) AllowanceslExtra 42Q1
James H Slyder, 429 Chestnut Street. Mt Holy Springs, PA 17065 '^-"•5441 MamedM/ithhold Fed-2/0/PA-0/0
Pay Period: 04/08/2005.04121r"5 Pay Date: 04/2212005
Earnings and Hours Qty Rate Current YTO Amounts PA -Withholding -57.33 -422.52
430.13 Road Crew Wages 25:00 18.72 468.00 4,296.24 OPT -10.00
439.13 Road Construction Wa 45:00 18.72 842.40 3,350.88 -400.74 -2,892.93
439.131 Road Construction 0 13.30 28.08 379.08 1,009.48
438.13 Road Maint Wages 1:00 18.72 18.72 842.40 Net Pay 1,466.58 10,869.55
430.131 Road Crew OT 3:00 28.08 84.24 821.34
436.13 Storm Drain Wages 4:00 18.72 74.88 112.32 paid Time Oft YTO Used Available
487.180 Holiday Pay 299.52 Sid- 38:00 -38:00
432.131 Snow Removal OT 1,326.78
432.13 Snow Removal Wages 673.92 Non-taxable Company Items Current YTD Amounts
487.177 Sick Pay 711.36
P.M.R.S. Company Contributio
186.73
1,376.25
433.13 Signs Wages 1 1 2.32
409.12 Building Houdy Pay 46.80
437.13 Repairs & Maint Wage 46.80
448.13 Water System Wages 74.88
487.176 Personal 37.44
1,867.32 13,762.48
Taxes Current YTO Amounts
Local Tax -29.88 -220.19
UC Employee Tax -1.68 -12.39
Federal Withholding -169.00 -1.175.00
Social Security Employee -115.77 -853.27
Medicare Employee -27.08 -199.56
DICKINSON TOWNSHIP GENERAL FUND, 219 MOUNTAIN VIEW ROAD, MT. HOLLY SPRINGS, PA 17065 717-486-7424, DICKINSON TOWNSHIP CUMBERLAND COU
)ICKINSON TOWNSHIP
4328
Employee SSN Status (Fed/State) Allowances/Extra
James H Slyder, 429 Chestnut Street, Mt Holly Springs, PA 17065 " ="-5441 Mamed/Withhold Fed-2/0/PA-0/0
Pay Period: 04/2212005 - 05/0512005 Pay Date: 0510612005
Eaminas and Hours ON Rate Current YTD Amounts Federal Withholding -189.00 -1.364.00
439.13 Road Construction Wa 56:00 18.72 1,048,32 4,399.20 Social Security Employee -124.19 -977.46
439.131 Road Construction 0 10:30 28.08 294.84 1,304.32 Medicare Employee -29.04 -228.60
438.131 Road Maint OT 4:00 28.08 112.32 112.32 PA - Withholding -61.49 -484.01
430.46 Meetings & Training 1:30 18.72 28.08 28.08 OPT -10.00
427.13 Trash Collection Wage 2:00 18.72 37.44 37.44 -437.57 -3,330.50
430.13 Road Crew Wages 19:00 18.72 355.68 4,651.92
433.13 Signs Wages 1:00 18.72 18.72 131.04 Net Pay 1,565.47 12,435.02
430.131 Road Crew OT 2:30 28.08 70.20 891.54
438.13 Road Maint Wages 2:00 18.72 37.44 879.84 Paid Time Off YTO Used Available
487.180 Holiday Pay 299.52 Sick 38:00 -38:00
432.131 Snow Removal OT 1,326.78
432.13 Snow Removal Wages 673.92 Non-taxable Company Items Current YTO Amounts
487.177 Sick Pay 711.36 P.M.R.S. Company Contributio 200.30 1,576.55
409.12 Building Hourly Pay
437.13 Repairs & Maint Wage 46.80
436.13 Storm Drain Wages 112.32
448.13 Water System Wages 74.88
487.176 Personal 37.44
2.003.04 15,765.52
Taxes Current YTD Amounts
Local Tax -32.05 -252.24
UC Employee Tax -1.80 -14.19
DICKINSON TOWNSHIP GENERAL FUND, 2 19 MOUNTAIN VIEW ROAD, MT. HOLLY SPRINGS, PA 17065 717-486-7424, DICKINSON TOWNSHIP CUMBERLAND COU
DICKINSON TOWNSHIP
4364
Employee SSN Status (FedlState) Allowances/Extra
429 Chestnut Street Mt Holly Springs, PA 17065
James H Slyder -5441 Marned/Withhold Fed-210/PA-0/0
, Pay Period: 0510612005 - 05119/2005 Pay Date: 05/20/2005
Earnings and Hours Qty Rate Current YTO Amounts
430.13 Road Crew Wages 32:00 18.72 599.04 5.250.96
439.13 Road Construction Wa 21:00 18.72 393.12 4,792.32
448.13 Water System Wages 4:30 18.72 84.24 159.12
430.131 Road Crew OT 2:30 28.08 70.20 961.74
487.180 Holiday Pay 8:00 18.72 149.76 449.28
448.131 Water System OT 3:00 28.08 84.24 84.24
438.13 Road Maint Wages 5:00 18.72 93.60 973.44
439.131 Road Construction 0 0:30 28.08 14.04 1,326.78
432.131 Snow Removal OT 1,326.78
432.13 Snow Removal Wages 673.92
487.177 Sick Pay 711.36
433.13 Signs Wages 131.04
409.12 Building Hourly Pay 46.80
437.13 Repairs & Maint Wage 46.80
436.13 Storm Drain Wages 112.32
487.176 Personal 37.44
438.131 Road Maint OT 112.32
430.46 Meetings & Training 28.08
427.13 Trash Collection Wage 37.44
1,488.24 17,262.18
UC Employee Tax
Federal Withholding
Social Security Employee
Medicare Employee
PA - Withholding
OPT
Net Pay
-1.34 -15.54
•112.00 -1.477.00
-92.28 -1.070.26
-21 58 -250.30
-45.69 -529.96
-10.00
_
-296.70 -3.629.25
Taxes Current YTO Amounts
Local Tax -23.81 -276.19
1,191.54 13.632.93
Paid Time Off IT'D Used Available
Sick 38:00 -38:00
Non-taxable Company Items Current YTD Amounts
P.M.R.S. Company Contributio 148.82 1.726.21
i () f rI -_ t 7
n1nK1NCnN TnwNSHiP GENERAL FUND. 219 MOUNTAIN VIEW ROAD, MT. HOLLY SPRINGS, PA 17065 717-486-7424, DICKINSON TOWNSHIP CUMBERLAND COU
DICKINSON TOWNSHIP
ammgs urs ON Rate Current YTD Amount
430.13 Road Crew Wages 40:00 18.72 748.80 8,433.36
438.13 Road Maint Wages 17:00 18.72 318.24 1,404.00
448.13 Water System Wages 3.00 18.72 56.16 318.24
430.131 Road Crew OT 15:30 28.08 435.24 1,705.86
439.13 Road Construction Wa 8:00 18.72 149.76 6.121.44
436.13 Storm Drain Wages 5:00 18.72 93.60 786.24
487.180 Holiday Pay 748.80
432.131 Snow Removal OT 1,326.78
432.13 Snow Removal Wages 673.92
487.177 Side Pay 711.36
433.13 Signs Wages 131.04
409.12 Building Hourly Pay 252,72
437.13 Repairs & Maint Wage 121,68
439,131 Road Construction 0 1,509.30
487.176 Personal 37.44
409.121 Building Maint OT 56.16
438.131 Road Maint OT 112.32
430.46 Meetings & Training 28,08
427.13 Trash Collection Wage 37.44
448.131 Water System OT 84.24
437.131 Repairs & Maint OT 28.08
436.131 Storm Drain OT 14.04
1.801.80 24,642.54
Taxes Current YTD Amount
Local Tax -28.83 394.27
UC Employee Tax -1.62 -22.19
Federal Withholding -159.00 -2,055.00
Social Security Employee -111.71 -1,527.84
Medicare Employee -26.13 -357.32
PA -Withholding -55.32 -756.55
OPT -10.00
-382.61 -5,123.17
Net Pay 1,419.19 19,519.37
Paid Time Off YTO Used Available
Side 38:00 -38:00
Non-taxable Company Items Current YTD Amount
P.M.R.S.CompanyContnbution 180,18 246424
DICKINSON TOWNSHIP GENERAL FUND, 219 MOUNTAIN VIEW ROAD, MT. HOLLY SPRINGS, PA 17065 717-486-7424, DICKINSON TOWNSHIP CUMBERLAND COU
DICKINSON TOWNSHIP
Eamrntls and Hours ON Rate Current YTD Amount
430.13 Road Crew Wages 49;30 18.72 926.64 10,286.64
430.131 Road Crew OT 2:00 28.08 56.16 1,818.18
436.13 Storm Drain Wages 3:00 18.72 56.16 898.56
438.13 Road Maint Wages 10:00 18.72 187.20 1,778.40
439.13 Road Construction Wa 6:00 18.72 112.32 6.346.08
448.13 Water System Wages 4:00 18.72 74.88 468.00
437.13 Repairs & Maint Wage 4:00 18.72 74.88 271.44
487.180 Holiday Pay 748.80
432.131 Snow Removal OT 1,326.78
432.13 Snow Removal Wages 673.92
487.177 Sick Pay 711.36
433.13 Signs Wages 131.04
409.12 Building Hourly Pay 252.72
439.131 Road Construction 0 1,509.30
487.176 Personal 37.44
409.121 Building Maint OT 56.16
438.131 Road Maint OT 112.32
430.46 Meetings & Training 28,08
427.13 Trash Collection Wage 37.44
448.131 Water System OT 84.24
437.131 Repairs & Maint OT 28.08
436.131 Storm Drain OT 14.04
1,488.24 27,619.02
Taxes Current YTD Amount
Local Tax -23.81 -441.89
UC Employee Tax -1.34 -24.87
Federal Withholding -112.00 -2.279.00
Social Security Employee -92.27 -1,712.38
Medicare Employee -21.58 -400.48
PA -Withholding -45.69 -847.93
OPT -10.00
-296.69 -5,716.55
Net Pay 1,191.55 21,902.47
Paid Time Off YTO Used Available
Sidi 38:00 -3800
Non-taxable Company Items Current YTO Amount
P.M-RS. Company Contribution 148.82 2,761.88
DICKINSON TOWNSHIP GENERAL FUND. 219 MOUNTAIN VIEW ROAD, MT. HOLLY SPRINGS, PA 17065 717-486-7424, DICKINSON TOWNSHIP CUMBERLAND COU
DICKINSON TOWNSHIP
Employee SSN Status (FedlState) Allowances/Extra 4698
James H Slyder, 429 Chestnut Street Mt Holly Springs, PA 17065 "-5441 Married/Withhold Fed-2/0/PA-0/0
Pav Period: 0910912005 - 09122/2005 Pav Date: 09/2212005
Earnings and Hours ON Rate Current YTO Amount
430.13 Road Crew Wages 30:00 18.72 561.60 11,456.64
438.13 Road Maint Wages 14:30 18.72 271.44 2,199.60
454.13 Park Maint Wages 8:00 18.72 149.76 149.76
448.13 Water System Wages 2:00 18.72 37.44 430.56
433.13 Signs Wages 2:00 18.72 37.44 224.64
436.13 Storm Drain Wages 1:00 18.72 18.72 954.72
438.131 Road Maint OT 1:00 28.08 28.08 140.40
409.12 Building Hourly Pay 8:00 18.72 149.76 402.48
487.177 Sick Pay 13:30 18.72 252.72 1,113.84
430.131 Road Crew OT 6:30 28.08 182.52 2,197.26
487.180 Holiday Pay 898.56
432.131 Snow Removal OT 1,326.78
432.13 Snow Removal Wages 673.92
439.13 Road Construction Wa 6,327.36
437.13 Repairs & Maint Wage 271.44
439.131 Road Construction 0 1,509.30
487.176 Personal 37.44
409.121 Building Maint OT 56.16
430.46 Meetings & Training 28.08
427.13 Trash Collection Wage 37.44
448.131 Water System OT 84.24
437.131 Repairs & Maint OT 28.08
Employee SSN Status (FedfState) Allowances/Extra 4559
James tt Slyder, 429 Chestnut Street. Mt Holly Springs. PA 17065 -5441 MamedlWithhold Fed-2/0/PA-0/0
Pay Period: 07115/2005.07/2812005 Pay Date: 07129/2005
E and Ho
Employee SSN Status (Fed/State) Allowances/Extra 4575
James H Slyder, 429 Chestnut Street, ML Holly Springs, PA 17065 "-5441 Mamed>wthhold Fed-2/0/PA-0/0
Pay Period: 07129/2005 - 0811112005 Pay Date: 08/12/2005
436.131 Storm Drain OT 14.04
1,689.48 30.562.74
Taxes Current YTO Amount
Local Tax -27.03 488.99
UC Employee Tax -1.52 -27.52
Federal Withholding -142.00 -2,498.00
Social Security Employee -104.75 -1.894.89
Medicare Employee -24.50 -443.16
PA - Withholding -51.87 -938.30
OPT -10.00
-351.67 -6.300.86
Net Pay 1,337.81 24,261.88
Paid Time Off YTD Used Available
Sick 59:30 -59:30
Non-taxable Company Items Current YTD Amount
P.M.R.S. Company Contribution 168.95 3,056.26
cl?,f?'
DICKINSON TOWNSHIP
Employee Status (Fed/State) Allowances/Extra 4751
James H Slyder, 429 Chestnut Street. ML Holly Springs, PA 17065 -RA-5"i Mamed/wthhold Fed-2/0/PA-0/0
Pay Period: 09/2312005 - 10/06/2005 Pay Date: 10/0712005
Earnings and Hours Qty Rate Current YTO Amount
409.12 Budding Hourly Pay 1:00 18.72 18.72 421.20
430.13 Road Crew Wages 42:00 18.72 786.24 12,242.88
438.13 Road Maint Wages 12.00 18.72 224.64 2,424.24
430.131 Road Crew OT 14:30 28.08 407.16 2.604.42
487.177 Sick Pay 5.00 18.72 93.60 1,207.44
439.13 Road Constriction Wa 5.:00 18.72 93.60 6,420.96
430.17 Training 8:00 18.72 149.76 149.76
487.180 Holiday Pay .898.56
432.131 Snow Removal OT 1,326.78
432.13 Snow Removal Wages 673.92
433.13 Signs Wages 224.64
437.13 Repairs & Maint Wage 271.44
439.131 Road Constriction O 1,509.30
436.13 Storm Drain Wages 954.72
448.13 Water System Wages 430.56
487.176 Personal 37.44
409.121 Building Maint OT 56.16
438.131 Road Maint OT 140.40
430.46 Meetings & Training 28.08
427.13 Trash Collection Wage 37.44
448.131 Water System OT 84.24
437.131 Repairs & Maint OT 28.08
436.131 Storm Drain OT 14.04
454.13 Park Maint Wages 14916
1,773.72 32,336.46
Taxes Current YTO Amount
Local Tax -28.38 -517.37
UC Employee Tax -1.60 -29.12
Federal Withholding -155.00 -2,653.00
Social Security Employee -109.97 -2,004.86
Medicare Employee -25.72 -468.88
PA -Withholding -54.45 -992.75
OPT -10.00
-375.12 -6,675.98
Net Pay 1,398.60 25,660.48
Paid Time Off YTD Used Available
Sick 64:30 -64:30
Non-taxable Company Items Current YTO Amount
P.M.R.S. Company Contribution 177.37 3,233.63
DICKINSON TOWNSHIP GENERAL FUND, 219 MOUNTAIN VIEW ROAD, MT. HOLLY SPRINGS, PA 17065 717-486-7424, DICKINSON TOWNSHIP CUMBERLAND COU
DICKINSON TOWNSHIP
Employee SSN Status (Fed/State) Allowances/Extra 4813
James H Slyder, 429 Chestnut Street Mt Holly Springs, PA 17065 "-5441 Mamed/Withhold Fed-2/01PA-0/0
Pay Period: 10/21/2005 - 11/03/2005 Pay Date: 1110412005
Earnings and Hours Qty Rate Current YTO Amount
430.13 Road Crew Wages 32:00 18.72 599.04 14,096.16
430.131 Road Crew OT 5:30 28.08 154.44 2,983.50
409.12 Building Hourly Pay 4:00 18.72 74.88 496.08
436.13 Storm Drain Wages 6:00 18.72 112.32 1,067.04
438.13 Road Maint Wages 8:00 18.72 149.76 2.574.00
487.177 Sick Pay 10:30 18.72 196.56 1,404.00
437.13 Repairs & Maint Wage 2:00 18.72 37.44 308.88
487.176 Personal 1:00 18.72 18.72 56.16
439.13 Road Construction Wa 10:00 18.72 187.20 6.626.88
487.180 Holiday Pay 898.56
432.131 Snow Removal OT 1,326.78
432.13 Snow Removal Wages 673.92
433.13 Signs Wages 224.64
439.131 Road Construction 0 1,509.30
448.13 Water System Wages 430.56
409.121 Building Maint OT 56.16
438.131 Road Maint OT 308.88
430.46 Meetings & Training 28.08
427.13 Trash Collection Wage 37.44
448.131 Water System OT 84.24
437.131 Repairs & Maint OT 28.08
436.131 Storm Drain OT 14.04
454.13 Park Maint Wages 149.76
430.17 Training 149.76
1,530.36 35,532.90
Taxes Current YTO Amount
Local Tax -24.49 -568.52
UC Employee Tax -1.38 -32.00
Federal Withholding -118.00 -2,910.00
Social Security Employee -94.88 -2,203.04
Medicare Employee -22.19 -515.23
PA - Withholding -46.98 -1,090.88
OPT -10.00
-307.92 -7,329.67
Net Pay 1,222.44 28.203.23
Paid Time Off YTO Used Available
Sidi 75:00 -75:00
Non-taxable Company Items Current YTO Amount
P.M.R.S. Company Contribution 153.04 3,553.28
DICKINSON TOWNSHIP GENERAL FUND, 219 MOUNTAIN VIEW ROAD, MT. HOLLY SPRINGS, PA 17065 717-486-7424, DICKINSON TOWNSHIP CUMBERLAND COU
KINSON TOWNSHIP
4858
Employee SSN Status (Fed/State) Allowances/Extra
James H Slyder, 429 Chestnut Street Mt Holly Springs, PA 17065 "' "-5441 Married/Withhold Fed-210/PA-0/0
Pay Period: 11/04/2005 -11/17/2005 Pay Date: 11/1812005
Eaminas and Hours Oly Rate Current YTD Amount
430.13 Road Crew Wages 36:00 18.72 673.92 14.770.08 454.13 Park Maint Wages 149.76
409.12 Building Hourly Pay 10:00 18.72 187.20 683.28 430.17 Training 149.76
487.180 Holiday Pay 16:00 18.72 299.52 1,198.08 487.179 Vacation 196.56
438.13 Road Maint Wages 14:00 18.72 262.08 2.836.08 1,497.60 37,030.50
439.13 Road Construction Wa 4:00 18.72 74.88 6,701.76
430.131 Road Crew OT 2,983.50 Taxes Current YTO Amount
432.131 Snow Removal OT 1,326.78 weal Tax -23.96 -592748
432.13 Snow Removal Wages 673.92 UC Employee Tax -1.35 -33.35
487.177 Sick Pay 1,207.44 Federal Withholding -113.00 -3.023.00
433.13 Signs Wages 224.64 Social Security Employee -92.85 -2,295.89
437.13 Repairs & Maint Wage 308,88 Medicare Employee -21.71 -536.94
439.131 Road Construction O 1,509.30 PA -Withholding -45.98 -1,136.86
436.13 Storrs Drain Wages 1,067.04 OPT -10.00
448.13 Water System Wages 430.56 -298.85 -7,628.52
487.176 Personal 56.16
409.121 Building Maint OT 56.16 Net Pay 1,198.75 29.401.98
438.131 Road Maint OT 308.88
430.46 Meetings & Training 28.08 Paid Time Off YTD Used Available
427.13 Trash Collection Wage 37.44 Sick 64:30 -04:30
448.131 Water System OT 84.24 Vacation 10:30 -10:30
437.131 Repairs & Maint OT 28.08
436.131 Storm Drain OT 14.04 Non-taxable Company Items Current YTO Amount
P.M.R.S. Company Contribution 149.76 3,703.04
DICKINSON TOWNSHIP GENERAL FUND, 219 MOUNTAIN VIEW ROAD, MT. HOLLY SPRINGS, PA 17065 717-486-7424, DICKINSON TOWNSHIP CUMBfRio1? M
PICKIN50N TOWNSHIP
Employee SSN Status (Fed/State) Allowances/Extra _
James H Slyder, 429 Chestnut Street Mt Holy Springs. PA 17065 "'- -5441 ManiedlWithhold Fed-2101PA-0/0
Pay Period: 11/18/2005 - 12/01/2005 Pay Date: 12/02/2005
Earnings and Hours ON Rate Current YTO Amount
430.13 Road Crew Wages 14:00 18.72 262.08 15.032.16 437.131 Repairs & Maint OT 28.08
438.13 Road Maint Wages 6:00 18.72 112.32 2,948.40 436.131 Stone Drain OT 14.04
430.131 Road Crew OT 2:00 28.08 56.16 3.039.66 430.17 Training 149.76
436.13 Storm Drain Wages 2:00 18.72 37.44 1,104.48 1,553.76 38,584.26
437.13 Repairs& Maint Wage 1:00 18.72 18.72 327.60
454.13 Park Maint Wages 1:00 18.72 18.72 168.48 Taxes Current YTO Amount
487.177 Sick Pay 8:00 18.72 149.76 1,357.20 Local Tax -24.86 -617.34
487.180 Holiday Pay 16:00 18.72 299.52 1,497.60 UC Employee Tax -1.40 -34.75
487.179 Vacation 32:00 18.72 599.04 795.60 Federal Withholding -122.00 -3,145.00
432.131 Snow Removal OT 1,326.78 Social Security Employee -96.33 -2,392.22
432.13 Snow Removal Wages 673.92 Medicare Employee -22.53 -559.47
433.13 Signs Wages 224.64 PA -Withholding -47.70 -1,184.56
439.13 Road Constriction Wa 6,701.76 OPT -10.00
409.12 Building Hourly Pay 683.28 -314.82 -7,943.34
439.131 Road Construction 0 1,509.30
448.13 Water System Wages 430.56 Net Pay 1,238.94 30.640.92
487.176 Personal 56.16
409.121 Building Maint OT 56.16 Paid Time Off YTD Used Available
438.131 Road Maint OT 308.88 Sick 72:30 72:30
430.46 Meetings & Training 28.08 Vacation 42:30 -42:30
427.13 Trash Collection Wage 37.44
448.131 Water System OT 84.24 Non-taxable Company Items Current YTD Amount
P.M.R.S. Company Contribution 155.38 3.858.42
DICKINSON TOWNSHIP GENERAL FUND, 219 MOUNTAIN VIEW ROAD. MT. HOLLY SPRINGS, PA 17065 717-486-7424, DICKINSON TOWNSHIP CUMBERLAND COU
DICKINSON TOWNSHIP
4925
Employee SSN Status (Fed/State) Allowances/Extra
James H Slyder, 429 Chestnut Street, Mt Holly Springs. PA 17065 "' "-5441 MamedfWithhold Fed-2/01PA-0/0
Pay Period: 12/0212005 - 12/15/2005 Pay Date: 12/1612005
Earnings and Hours Oty Rate Current YTD Amount
430.13 Road Crow Wages 42:30 18.72 795.60 15,827.76 437.131 Repairs & Maint OT 28.08
487.176 Personal 10:30 18.72 196.56 252.72 436.131 Stone Drain OT 14.04
432.13 Snow Removal Wages 14:30 18.72 271.44 945.36 430.17 Training 149.76
430.131 Road Crew OT 5:30 28.08 154.44 3.194.10 1,886.04 40,470.30
438.13 Road Maint Wages 2:00 18.72 37.44 2,985.84
454.13 Park Maint Wages 1:00 18.72 18.72 187.20 Taxes Current YTO Amount
487.179 Vacation 13:00 18.72 243.36 1,048.32 Local Tax -30.18 -647.52
432.131 Snow Removal OT 6:00 28.08 168.48 1,495.26 UC Employee Tax -1.70 -36.45
487.180 Holiday Pay 1,497.60 Federal Withholding -172.00 -3,317.00
487.177 Sick Pay 1,347.84 Social Security Employee -116.94 -2.509.16
433.13 Signs Wages 224.64 Medicare Employee -27.35 -586.82
439.13 Road Construction Wa 6,701.76 PA - Withholding -57.90 -1,242.46
409.12 Building Hourly Pay 683.28 OPT -10.00
437.13 Repairs & Maint Wage 327.60 -406.07 -8,349.41
439.131 Road Construction 0 1,509.30
436.13 Stone Drain Wages 1,104.48 Net Pay 1,479.97 32.120.89
448.13 Water System Wages 430.56
409.121 Building Maint OT 56.16 Paid Time Off YTD Used Available
438.131 Road Maint OT 308.88 Sick 72:00 -72:00
430.46 Meetings & Training 28.08 Vacation 56:00 -56:00
427.13 Trash Collection Wage 37.44
448.131 Water System OT 84.24 Non-taxable Company Items Current YTO Amount
P.M.R.S. Company Contribution 188.60 4,047.02
DICKINSON TOWNSHIP GENERAL FUND, 219 MOUNTAIMIEW ROAD, MT. HOLLY SPRINGS, PA 17065 717-486-7424, DICKINSON TOWNSHIP CUMBERLAND COU
DICKINSON TOWNSHIP
499
SSN Status (FediState) AlkrwanceslExtm
Employee
James H Syder, 429 Chestnut Street ML Holly Spnrlgs. PA 17065
s Fed-2f0/PA-010
Pay Date: 1213012
005
: 12/16/2005 - 12!2912005
Pay Period
Earnings and Hours ON Rats Current YTD Amount 131 Repairs& Maint OT
437 28.08
432.13 Snow Removal Wages 30:00 18.72 561.60 1,506.98 .
131 Stone Drain OT
438 14.04
432131 Snow Removal OT 8:15 28.08 231.66 1,726.92 .
13 Park Maim Wages
454 187.20
487.176 Personal 10:00 18.72 187.20 439.92 .
17 Train
430 149.76
487.179 Vacation 40:00 18.72 748.80 1,797.12 . 1,841.58 42,311.88
131 Road Maint OT
438 4:00 28.08 112.32 421.20
.
487.180 Holiday Pay 1,497.80
Tax" Current YTD Amount
430.13 Road Crew Wages 15,827.76
Local Tax -29.47 -676.89
430.131 Road Crew OT 3,194.10
985
84
2
UC Employee Tax 1.66 38,11
438.13 Road Maint Wages .
,
347
64
1
Federal Withholding -165.00 -3,482.00
4
Pay
487.177 i .
,
224
84 Social Security Employee .18 2.623.3
s W
ages
433.13 Signs .
701.78
6
Medicare Employee -26
.70
-28 -613.52
00
1
2
439.13 Road Construction We ,
683.28 PA - Withholding 58.54 .
.
1010
00
409.12 Building Hourly Pay 60
327 OPT .
-
437.13 Repairs & Maint Wage . -393.55 -8,742.96
439.131 Road Construction O 1,509.30
436.13 Storm Drain Wages 1,104.48
Net Pay 1,448.03 33, 568.92
13 Water System Wages
448 430.56
.
409.121 Building Maint OT 56.18
08
28
Paid Time Off YTO Used Available
430.46 Meetings & Training .
Sick 72:00
7 •72:00
427.13 Trash Collection Wage 37.44
Vacation 6:00 -96:00
448.131 Water System OT 84.24
17065 717-486-7424, DICKINSON TOWNSHIP CUIOB€'it1?1N?O0O'?
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rum ¦ rrv V..7• II14AMMYQI II a errs I GA F%WW I I I RAY rT ri IRS U116 Only - Oo not weft or ]tapla in aft Bran.
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fs"k wumora) NAMES H SLYDER 178-38-5441
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M3 11011101. MARY C SLYDER 182-46-2781
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or type. 429 CHESTNUT ST You must social
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Election
HOLLY SPRINGS
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REBECCA E SLYDER 205-74-5314 ...
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see kntrucoons. n ... r.._
- ap•? . 7
7 Winges, safeties, tiP61 Farm(s) *2 ......................................... 7 47,765.
?It CM lie 8a TwwMe Atach fa B if required ......................................... Sa 41.
b Tans."empt interest Do inckde an line 8a ............. 8b
Aftwh Faint(s) 9a Ordinary divide. B If required .......... .. ................... 9a 4.
91.2 here. Abe b WN, awl 9
14
ad" Ferale
11-W aad 10l9-R ........ .......
19 Tsubb nr0 l i. Qsdirs, or ...............................
stir aed Wal it wo ton (see lisb dons) ...................... 16 610.
8 test tree nifhbeid. 11 Afrrnorty received ........ ......................................................... 11
did ad 12 Business inoonte or Schedule C or C-EZ 12
? a *2. 13 Camel qeh sr (lees). M Sch it Ind regd. dt bee ......................... W. Q 13 -3,000.
see insinrm m 14 Other gains or (fosses). Form 4197 ........... .............................. 14
1IIi PA dbtribtdim .. TS0 b Thxsble amount (seer irises) . 15b
160 Perrskx and arxadtles ..
160
b Taxable amount ('es enters) .. -
16 _
17 Raninl reel asbaI partr?ersfrps, S carpNraft s, busK sic. Attach Sduduls E .. 17 3,298.
6lelneR letds 18 Farm bun, lf a (foss). Schedule F ............................................ 18
rot aWdl ay 19 U nempioynmrt .... ............... .............................. 19 3,213.
piep
F
1 29a Sodd secm* benefits .... L2ft] J b Taxable arnaurd (see inaiss) .. 20
ont
G10-V.
21 Mw lessee _ _
_ _ _ _ _ 21
22 Arid the-an rolsds in ihf _ _
column for lines 7 21. This is isotal ineaerne ?
22
51 931 .
23 Educsbr .................... 23
Adf tamed 24 Cu to btreialeI d
;; pertarmilq srftls? and lbo basis
CalOSS ?I?It Atlerb 06 or Z106?EZ .................... 24
111COIt1e 26 IRA ds&wdon (use ) .......................... 25
25 Student loan interest (see h*uCU") .......... 26
27 Tuffion and to iruhx:dwu) ............... 27
2111 HMold n savirlpe account Attach Farm 81189 ........ 2R
29 Moving ercpfnses. F 3343 ...................... 29
30 One4 aff at self tax. Adach Sdnedule SE ....... 38
31 Seff- Wnpiorysd tltmlOn dedtxuw (see insirs) ....... 31
32 Self-ernpicyed SEP, artd qualified plans .......... 32
33 Penalty on early d saving .................... 33
34a AGnrsny paid b kdpfws ? 340
33 Add Oise 23.*oudt 34a ..... ......................................................... 3B
35' Subhad fine 35Tran I This is irreww ..................... ? 3B 51. 931.
BAA For Olsdoscsia, POwwy Act Orld Act 111dics, ales babtldlaw POW112 11110M Form 1040 004)
100 1 0
a C ilrof No. b EIN 23---M5882 OMB No. 1S45.Ogp8
C EmploWs meta, address. and ZIP coda This * da low is tseinug lanbhmd to to alts. If you are rokMnied b fib a lax alum. a negligence penalty or
offer sanction
W ' an you f this No= is toxabla and fail b Won't.
mW you,
M 1 wgi, dos, oew ca p 2 Fed We tax w4 2 3 social seamy wages
W-2
DICKINSON TOWNSHIP CU
BERLAN 26467.73 352.00 26467.73 Form
219 MOUNTAIN VIEW ROAD 4 ss w Wiew 5 Abaora wsgea e, tim 6 Mnxdloae taxes-iMld Wage and
MT. HOLLY SPRINGS, PA 17065 1641.00 26467.73 383.78 T
ax
7 social secutty tips 8 Albeabd tips 9 Advance EIC payment
d F?enplayes's sell _ Statement
178-38-5"1 10 DoOd care beneft 11 NWWm l ad plans 123
e Employee's name, address, and ZIP code 2004
13 14 slow 12b
JAMES H SLYDER Statutory a0'"ee ? UC Tax 23.81
12c Copy C For
429 CHESTNUT STREET
Retirement plan • .. 0 EMPLOYEE'S
RECORDS.
MT. HOLLY SPRINGS, PA 17065 12d ?
to
sick vav E
e,
15 state EmpioWs stab 10 No. tips
16 stale 17 stab irX=nne tax 18 local "ages, tips, etc 1 19, ocal aRccome tax 20 Uicaiiy name
PA 1566
5946 6
M.6 812 54
7 26467.731 ____ 423.49 DICKIN
_
_
___ 7
____ ______
Instructions
(Also see Notice to Employee) l E • Elective dah ab under a sec 403(b) salary reduction agreement
Runt 1. Enter fhb amount on the wages line of your tax retain. 4I F - EMe1M deferais order a Sae 408(h)(6) salary reduction 3EP
box 2 Enter ft amart an alt Federal income tax w*ftld fins of reb.m. G - Elective defsnab and employer amilrrbutiors (ndrdng rwrelsetira 1-11 b) to a
floc 8. This amount is not included in bones 1.3. S. or 7. For into on b noel tips on See 457(b) deNned comMaation plan
your tax ret rm see your Form 1040 nabs. H . Elective daterals to a See 501(c)(18)(D) tax-xampt Or ion phn
floc 9. Enter On amour on alt advance EIC payments line of your 040 or (sea 'Adluabd Gron Income' in en Form 1040 irsbs for how b kisclrc0
Form 10W& i . Nodmble sick pay (ado only, not "riled in bogies 1. 3. or 5)
P" 1L This amokrt is Ou WIN dmpmndart care burueAb ypr ?upteyar pim b you or
monad an your bthelt (( amants from a sae 1?S (t5lsiris) ptft)• Anti remark K - 20% emcee tsar w excenyalbn paradwAa paynsnts (see Tdal Tax' n 0+e
over $5.000 *0 is inbox 1. You lrttrmt eaa,pbb Seh 2 ?ergt 10}0x1) at ram 2141. Form 1040 hobs)
Chid and Oepatdotd Can Expe ew b oomprb any taaabla and L . Substanfiximl employee business expense rsimbusomo nts (nontaxable)
Ow 11. Thb amount is (a) reported in boa 1 i x Is a dib&IdW b tram a
or SK 4SJtp) 4n) ineltdmd in M - Uncollected social seoaily or RATA tax on taxable coo of gnanp•Mrm We imurance
box 3 ardkr 5 if a is a prim yew dslannl order a nepusi l@d or See ) pM tat over 350.000 (former employers only) (see Toll Tad is the Farm LOW ins
tMearna taxable for soasl seouily and Iladieara bass m!F yes is no a N . Uncollected I1 1, tax an Womble coat of orouplenn 6b insunratas over $50,01M
a bManYM risk of lontn'Yre at you right to ft dabrnd aaud. (former employees only) (sea Total Tea' in die arm 1040 hobs)
Roc 12 TIM iq ist sxpbinu alt codas shoat in be 12 You fh'us iota to
tf P - Eaeldmb a moving eapeas rvin6careme nb paid drectly to employee (not andWad
eanpbtm yyook?r Wx mien EYetlve dabmab (codes 0. E. (1. H. and am plans an
geteaNy Untied to 13AW ($16.000 for See 4030) is is -"w Nngo ava nbetea 1, 3,m
axplnoirlmd n Pub itsenavar, i yeswan at Mat 500 R . Employer canYibati, b your Archero" (sae Fwa 8= AMtW MSAS and
allowed an addl om Ambtral of up to $3.000 ($1,5go'?or Sae 401 1) ) Lang-Tama Cora insurance Cmntacbg
P.1-011 sdditonM dMarfW amokant is not sullbct b tlto gvsla/ dalmmaM. ?l?
alts tim8 on tlst tivs daMnls may b ?tighmr for ft IM bdms yea S - Emtpimyee sm" radurclbrn cnntrubu llors under a Sac 40e(p) SWKE (not included in V
radl rstiwrrand age Gaubert yyeptrrr orn adnaigabr for mere Amounts in tea 1)
eseM of rfts everN ebWve caterer intnt marl tea iruelydmd in ft Wager, Z
Salerno, Tips. Ni rite r ins for your tax relre. T - Adoption beneib (mat inoloded in boa 1). You want oarngids ram 11M QueWied
149W. 9 a yaw fotim cods 0. E F. G. H. or 3. you nods a moke-0 ambition Adaptiat EWews, to wtnpuM any taxabM sad rwdaablm amours J
Am a prlOr year(s) ow you rile in, Wftj Service. To lique 411C11115 V - Income from enrOn of marnstabtbty dock option(s) (lnridmd in b=as 1. 3 (up to
AefaraM. eelMidmr inns aatarts for to yo% shown, not fie anod ) or ne year is social sec ro wags besa). and 5) Q
sAerwt. f!M cvrnbnbrrtias as fs alb oxcart year. ? Kd poqftilpn to you 11abt Savings Aec9tat (sae now Form 8819. Halh C IN - % Am ftFss TOup
dm cwr?r or WrA tax an tips Melde tie la m 1040. Sea ToM1 ?a?t ??, M al? L
-L, I 104Q rYa s a??fax?on pas (Irnclda !IM In an Form 1010 Tax in the tea 3" IRAYOU ? d? Special ? ?erne on amount of LU
3 rMMApplIf&to
.I naw ?ay?brtn G? nwanca over $50,01M (hick," ' 1.3 (up to &KIE§2??,fX d O
Y
740tka to baEmpf"" 401 R or allq ckW?rw seed e a ?st? hiomnmtbn fa Merrubirs orgy and
W
lehad. Even !=w do not have b ftim a tax rmlrlt,) a afcokid t1M b if boa 2 Wpgous Nblws.
haws Federal tams wNmmld, or n you can rely alb EIC. Cetme/orta y? name. or ad*azis is -?r-
Samed bteorrla aadk 41="? You must fk a tax telut i say uaoart' in box 9. b My whit dM soaN10
In q?yq?soaa1 J.
IOU be .
a .Z eminwetro Sea epaR? In asanad as to
800 nz-1213
,+i i1 a? y rata, yaud Idask for a nmoarr?or0 at y or
YOU U
mom
d+itdrfn Tumt • Y
Was ' 7y' oa-M, iiA ? went w-ulftyou." Q
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evi
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yaw s a ar? givirq t Cu u?a9 be Mid
d
d?lSr PleasR Nob SSA welaila at Ww+raeairMasMy.yoMaayloyer b amexb and rim eMdmrdaW'fil in' Q
Dm?a nab nnded to aonuplele Farm W-2 is given in a saparab 2089 verstorM d FamM W2 and WJ
axbuwllrs fs Fame WF2 and W 4L You an oiler -robe sd lamb by ouw dabs. Fwnwh Copies iL C. and 2 b the a vpbyae go-A by -IMMY 31. 2005.
te
0101110111 ino 18110 TAX fdiM p800829-36761. You can am got ixms from the FrTr B CpyA wily M SSA gpn@m% by Fabn y 2a. 2W5., Send aA CopiN A Wilh Fenn
is W W ec a
ause t ww alb Ys.Yov SSA . ploemtmas witit iM yK? Transmitlal d Ways ad Tax SMMasab. Fb-er, 0 you Me Mmebmniesiy (not by
SA Forms W W.-2 2 and a pips lane by msdinna. you mspMlb ntmdM). the due dab b tnrteclt 31.2005
9A For 1W3 tied you onnnt nom tin IRS MNb Site. usaalb lMbat.
Act wildbPapl w" Reducdon ACA NCU . We eM ins oa ai?,s?eOOi f?a?oirlalon and
?n?OOrn?onOSx
ON y1f- .0 Ott To ?MranayV we to d it ?? b mtalat ? allwass
drP nQ a itutividual
wroaryvs?arncs??t>yok r aw. ? p ban a The tbM m e b okxn0ists and Me 9sss form we vary
?inlraM,,raaarm..,irrararaunaaardddm(M?yp?vda irnb a iMt is tlM annnrteruers.The ssibnow ava" tlmna an:.F N4Z' 30 n> aF -j CC -- a sM tarn,dMr?Wmb ,aarv,r?mdas iantner. v?oy raoa W-3 - 29 mimnms M you for n mminarmMrMnWme tr Rx., sl p 110 mSOMMOCY of 111100 dole _
Area J
Mrtii in tea «aNMtis> ton?ntud?any Recrrtur laafaarre read pv w + you Yes can vm* to to Tax Product ComdialYnO CantMMo. Western
xgraNr. ya o no and tna Id ols lis0 shrfniurt yo 61 r turn to . to OU ddr Cantor. Renews Cordova CA po 001. Oe mot sand Fom for IN 2 F and W-3
s 6103 allows Il qns oq ratan toad?os? ittstaod. we 1rlMn is So an an pa0m 2 of 8M ltmtruelleeM (or farts W-2
IMF as desonbsd n ortexample. Wa soy drlrloas ywr Well V" 0
Forth ?4? pmartment of ft Treasury - Irternel Rew to Ser%lm
U.S. Individual Income Tax Return
99 IRS Use Only - not write or staple in this space.
2005
For the year Jo i - Dee 31. 2005, or other tax year beginning , 2005, ending '20 OWS No. I545-0074
Label You first none MI Last name Your social security member
(See instructions.) JAMES H SLYDER 178-38-5441
If a joint return, spouse's first name MI Last name spouse's social security manber
Use the
IRS label.
MARY C SLYDER
182-46-2781
Otherwise, Fiafie address (number and street). If you hem a P.O. box, we instnxbons. Apartment no. You must enter your
please print
429 CHESTNUT ST social security
or type. number(s) above.
City. town or post office. If you haw a foreupi address. see Instructions. State ZIP code ow will not
C
hecking u
?
a
::J
Paesidenoall
MT HOLLY SPRINGS r
r .
t o
yo
change
PA 17065
Election
Campaign , Check here if you, or your spouse if filing jointly, want $3 to go to this fund? (see instructions) ................ i [] You Spouse
Filing Status 1 Single 4 Head of household (with qualifying person). (See
instructions.) If the qualifying person is a child
2 X Married filing jointly (even if only one had incorrle) but not your dependent, enter this child's
3 Married filing separately. Erfler spouse's SSN above & full name here. 0'
Check only
one box. narne here 5 n Qualifying widow(er) with dependent decd (see instructions)
Exemptions
m Boxes Yourself. If someone can claim you as a dependent, do not check box 6a . .... cm 6* wW `r`rr, .. 2
6a
...................................
b X Spouse- . ................ ........ I ..
...................................... No. of d" of
....... I .............. I ........
(2) Dependent's (3) Dependent's (4) if an 6c who:
av.d
c Dependents: socia l security relationship qualifying
di
Y°" 2
?
number to you
it *
iax cred
First name Last name
not
(see ins") a" OM you
ADAM J SLYDER 172-74-4313 Son X d1sepera 1e
REBECCA E SLYDER 205-74-53141 Dau hter X (??
DeperrdetAs
De
If more than on
c =
e to above .
four dependents,
see instructions n
I I *Ad number
.
d Total number of exemptions claimed ..... .....
7 Wages, salaries, tips, etc. Attach Form(s) W-2 . .................. 7 61,247.
income
8a Taxable interest. Attach Schedule 8 if required .......................... ..............
8a
19.
b Tax-exempt interest. Do not include on line 8a ............. I 8bi
h form(s) 9a Ordinary dividends. Attach Schedule 8 if required ......................................
Atta
9a _
23.
c
W-2 here. Also b ( °ra°as ............ 9bi
attach Forms ..................... .....
credits, or offsets of state and local incorre taxes (see instructions) ......................
10 Taxable refunds
10
,
W-2111 and 10WR
11 Alimony received ....................................... ............................
if tax was withheld 11 '
.
12 Business income or (loss). Attach Schedule C or C-EZ .................................
you did not
13 Capital gain or (loss). An Sch D if regd. It not read, ck here ............... _ ........ ?
9
f
2 12
13 5,200.
640.
get ?
1
,
-
.
see Instructions. 14 Other gains or (losses). Attach Form 4797 .............................................
14
15a IRA distributions ............ 15a b Taxable amount (see instrs) .. 15b
16a Pensions and annuities .... 16a b Taxable amount (see instrs) .. 16b
17 Rental, real estate, royalties, partnerships, S corporations, trusts, etc. Attach Schedule E .. 4,304.
but do 18 Farm income or ('loss). Attach Schedule F .............................................
Enclose
,
not ate any 19 Unemployment compensation ...............................
R- ?4
p?
20a Social seartity bmis ......... 120al b Taxable amount (see instrs) .. 420b
_
use
Form 21 Otherirrcan
__ ___________ ______ 22 Add the amonts in hrow h 21. This is our total income 71, 433.
23 Educator expenses (see instructions) ...................... 23 i
Adjusted 24 Certain business apllr a of mesavists, performing artists, and fee-basis
Gross government o(fidals. ABadf Form 2106 or 2106-Q ....................
24 j
!
Income 25 Health savings account deduction. Attach Form 8889 .... .. 25
26 Moving expenses. Attach Form 3903 ....................... 26
27 One-half of self-employment tax. Attach Schedule SE ....... 27 368.
28 Self-employed SEP, SIMPLE, and qualified plans ........... 28
29 Self-errlployed health insurance deduction (see instructions) ............. 29
30 Penalty on early withdrawal of savings ..................... 30 !
31 a Alimony paid b Redpierrt's SSN .... 0" .. 31 a
32 IRA deduction see instructions ............ 32
33 Student loan interest deduction (see instructions) .......... 33
34 Tuition and fees deduction (see instructions) ....... ........ 34
35 Domestic production activities deduction. Aftaaat Form 89M ... ...... .. 35
36 Add lines 23 - 31a and 32 - 35 .............................. 36 368.
37 Subtract tine 36 from line 22. This is your adjusted gross inc ome . ... .. .. 10 - 37 71, 065.
8AA For Disclosure. Privacy Act, and Paperwork Reduction AC. Notice, see instructions. FolA01 12 MOMS Form 1040 (2005)
71
0 a Cawa Nn
: Hm knee! nawUe, aAdrem ati AP V110e
r
pwo uI KT HSON TOWN°,HIP CUMBERLANI
r ,19 ?I+)UI•ITAIN VIEW ROAD
HT. HOLL-1 3PRING , PA 17065
t d Emptny-+'a :SN
118-38-5441
_
e L'r,ploye. t name, addrvss. aM 71P r M
O J,?1•+E' N SLYnER
M 429 C"T;-iBUT STP.EE"
MT. Hui ? Y SPRINGS, PA 17065
_? 15 slalc Employers stag icy Wo: -S'iale ?va,res^.?Sl'etc
2r. 156.6b446 42211.88
our _?- -- - --- ---- - -
M
b Ernbwv irienhhatl0n ntanoa tEtt+) 2 3- 6 0 0 5 8 8 2 !-ra+n ra, i sas moos
7hrs 0dartaaettn R Gxq AnnNled lu ft ME, lf you are rowKed b lots a t-m retun. a necthaMe penally or
oYwr faMtien mey be 1ff=%*d en Yoe it the stcome is bxxaeb and you Wd b is 't.
1 Yvgs, ups, oYw coma 2 Fed me tax wd#*,v 3 swat seuriiy arepea
42311.881 34,92 - 00 42311. uw Form rr-2
4 ss tax v* M 5 Wedicam „apes S 6 laemc ne tax weft4d Wage and
2:523.34 42311.88 b1-?.5Tax
7 Soren :eerily bps 8 AW,Wted tips - 9 A:>•:,cv Ek payment Statement
10 Dept" can oenehN 11 "a??7ra;NeO plans 12a
-- 2005
13 14 co., 12b
SlabdeP, ernakly ee E] T)C Teux 39-11 1 py
OFT 10. CC 12C I OYESS
F.INe,r+rt ;:tan J I RECORDS.
-? 12d (See Notice to
i CM
- P(° e')
7b kd•pmty sits pay f - -
'- atoll 0.w M ow---- 11LA.. r W.L r,Ae.^_![ 19-4UG.l nx??+a mx 20 t•waWy name
1295_UU?__-- 42311-80 _ 7v
_ i
'T1 cauaZx: o-rjerns
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JAMES H. SLYDER,
Plaintiff
No. 06-3762
V. Civil Action - Law
DICKINSON TOWNSHIP; DANIEL E.
WYRICK; THOMAS E. PATTERSON;
AND RAYMOND L. JONES,
Defendants
VERIFICATION
I verify that the statements made in the foregoing document are true and correct to the
best of my knowledge, information and belief. I understand that false statements made herein
are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to
authorities.
S&J?r. 1 200" 4:?? =-'?
DATE - J SLYDER
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JAMES H. SLYDER,
Plaintiff :
No. 06-3762
V. Civil Action - Law
DICKINSON TOWNSHIP; DANIEL E.
WYRICK; THOMAS E. PATTERSON;
AND RAYMOND L. JONES,
Defendants
PROOF OF SERVICE
I, Debra K. Wallet, Esquire, hereby certify that on September 7, 2006, I served a true
and correct copy of the attached PLAINTIFF'S RESPONSE TO DEFENDANT'S REQUEST
FOR PRODUCTION OF DOCUMENTS AND THINGS by first class mail, postage pre-paid,
addressed as follows:
Mark T. Riley, Esquire
MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN
620 Freedom Business Center, Suite 300
King of Prussia, PA 19406
40-1 V. w(aa. e-
Debra K. Wallet, Esq.
24 N. 32nd Street
Camp Hill, PA 17011
(717) 737-1300
I.D.# 23989
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JAMES H. SLYDER,
Plaintiff
No. 06-3762
V. Civil Action - Law
DICKINSON TOWNSHIP; DANIEL E.
WYRICK; THOMAS E. PATTERSON;
AND RAYMOND L. JONES,
Defendants
PLAINTIFF'S RESPONSE TO DEFENDANT'S
DAMAGE INTERROGATORIES
1. - You have indicated that certain losses have been sustained by you because of the
matter or matters declared upon your Complaint. Set forth fully, completely, and with
absolute precision, the factual basis upon which you arrived at the allegations of damages. In
so doing, be sure to give an express accounting and breakdown by category, such as labor
costs, replacement value, actual cash value, materials used, business losses, and any other
category of loss which can be quantified. It is the purpose of the party submitting these
interrogatories that the party answering state every basis and fact that will be set forth at trial
to prove damages.
ANSWER:
I have lost all wages and benefits since January 3, 2006. I calculate my losses for
wages only as follows:
Gross annual pay for 2005 $42,311.88
Anticipated wages for 2006 with 3 % increase $43,581.23
It is difficult for me to calculate all of the losses of benefits, but they include:
Pension Contribution (10% of annual pay) 4,358.10
Family health benefits - estimated 9,000.00
Accrued vacation 80 hrs/year Cad $19.09 1,527.50
Sick leave, 12 paid holidays, and 3 personal days per year
I have lost the use of this money throughout the course of the time I have been off and I have
been required to use personal savings to provide for my family.
2
2. With regard to the information and facts set forth in preceding interrogatory,
please identify all documents, records, data, recordings, maps, charts, photographs,
electronically stored data, work sheets, diagrams, blueprints, memoranda, and any and all
other forms of printed, photographed, and/or electronically stored data that you will use to
support these allegations. In lieu of identifying these requested items, you may attach copies to
these answers to interrogatories, taking care to make reference to them in the body of your
answer to this question.
ANSWER:
I have relied upon my final 2005 pay stub, my experience with respect to average
yearly wage increases and other benefits, and the Dickinson Township Personnel Manual.
3
With regard to the information supplied in the preceding two interrogatories,
please identify fully, by giving name, home address, business address, and any other necessary
identifying information about the person or persons who will be able to testify in support of
your damage allegations, and state with regard to each person, the information supplied by that
person, its source, and a brief description of what that person would testify to at trial, if called
to so testify.
ANSWER:
I am the source of this information. I may need to call a representative of Dickinson
Township, such as the Office Manager, to confirm the pay and benefits information.
4
4. Please set forth each and every factual basis for Plaintiffs contentions in
paragraph 25 of Plaintiffs Complaint and attach a copy of the writing referred to therein.
ANSWER:
This is what Mr. Patterson has told me and what he wrote in his written
statement dated February 5, 2006.
5
5. State when you contend that Daniel Wyrick learned that Plaintiff had made a
complaint with the State Ethics Commission and set forth each and every factual basis for said
contention in detail and with specificity and attach any supporting documents hereto.
ANSWER:
I believe that Mr. Wyrick learned of the complaint in November, 2005. This is when
the Ethics Commission notified me that there would be a full investigation of my charges and
that both parties had been notified of the investigation. These were the same charges that I
raised with Mr. Wyrick when I met with him in June or July of 2005.
6
6. Set forth each and every factual basis for the contentions set forth in paragraph
24 of Plaintiff's Complaint in detail and with specificity and attach any supporting documents
hereto.
ANSWER:
Mr. Raymond Jones never supervised me nor worked with me since I have been
employed by Dickinson Township. He had no first-hand information about my job
performance. Mr. Jones and Mr. Wyrick are political colleagues in that Mr. Wyrick
campaigned for Mr. Jones. Because the other two supervisors had given me favorable
performance evaluations and Mr. Wyrick was the only one who had expressed any
dissatisfaction with my work, I must conclude that Mr. Jones relied on Mr. Wyrick's opinions
of my work performance.
7
7. Set forth a full and complete description of any and all complaints made by
Plaintiff to the Pennsylvania State Ethics' Commission, including but not limited to the
following:
a. The date each such complaint was made;
b. To whom each such complaint was made;
C. Whether each such complaint was verbal or written and, if written,
attach a copy hereto;
d. The substance of each such complaint;
e. Whether Plaintiff advised anyone, other than the State Ethics
Commission, that he had made such complaint and, if so, the identity of the person whom
Plaintiff so advised and the date on which each such person was so advised.
ANSWER:
a. On or about July 28, 2005.
b. Pennsylvania State Ethics Commission
C. Written
d. Plaintiff cannot divulge this information without violating the confidentiality
provisions of the-State Ethics Act. If and when the State Ethics Commission makes this a
public matter, then I will be at liberty to provide the specifics. It is believed that Mr. Wyrick
has sufficient information about the nature of the complaint based upon the written
communications with him by the Ethics Commission.
8
e. No one, other than my wife. I made it known to others that I did not believe
that Mr. Wyrick was following the law when he took certain compensation, so others may
have known the general nature of my ethics concerns but I never told these persons that I had
actually filed an ethics complaint.
Respectfully submitted,
Q40'.. U. O&M- -
Debra K. Wallet, Esq.
24 N. 32nd Street
Camp Hill, PA 17011
(717) 737-1300
I.D.# 23989
Attorney for Plaintiffs
9
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JAMES H. SLYDER,
Plaintiff
No. 06-3762
v. Civil Action - Law
DICKINSON TOWNSHIP; DANIEL E.
WYRICK; THOMAS E. PATTERSON;
AND RAYMOND L. JONES,
Defendants
VERIFICATION
I verify that the statements made in the foregoing document are true and correct to the
best of my knowledge, information and belief. I understand that false statements made herein
are made subject to the penalties of 18 Pa. C.S. §4904, relating to unworn falsification to
authorities.
Ste. -+. aoo+.
DATE S H. SLYDER
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JAMES H. SLYDER,
Plaintiff
No. 06-3762
V. Civil Action - Law
DICKINSON TOWNSHIP; DANIEL E.
WYRICK; THOMAS E. PATTERSON;
AND RAYMOND L. JONES,
Defendants
PROOF OF SERVICE
I, Debra K. Wallet, Esquire, hereby certify that on September 7, 2006, I served a true
and correct copy of the attached PLAINTIFF'S RESPONSE TO DEFENDANT'S DAMAGE
INTERROGATORIES by first class mail, postage pre-paid, addressed as follows:
Mark T. Riley, Esquire
MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN
620 Freedom Business Center, Suite 300
King of Prussia, PA 19406
Debra K. Wallet, Esq.
24 N. 32nd Street
Camp Hill, PA 17011
(717) 737-1300
I.D.# 23989
Attorney for Plaintiff
\26 A\L1AB\STSTADELMAN\LLPG\832287\EMSASSLT\05130\00541
MARSHALL, DENNEHEY, WARNER
COLEMAN & GOGGIN
BY: MARK T. RILEY, ESQUIRE
IDENTIFICATION NO. 49427
620 Freedom Business Center, Suite 300
King of Prussia, PA 19406
Telephone: (610) 354-8259
Fax: (610) 354-8299
Email: mtrileyC&,mdwcg com
Attorney for Defendants
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
JAMES H. SLYDER
V.
NO.: 06-3762
DICKINSON TOWNSHIP,
DANIEL E. WYRICK,
THOMAS E. PATTERSON, and
RAYMOND L. JONES
MEMORANDUM OF LAW IN SUPPORT OF MOTION OF DEFENDANTS TO
STRIKE PLAINTIFF'S OBJECTIONS
TO CERTAIN DISCOVERY REQUESTS AND COMPEL PLAINTIFF'S
PRODUCTION OF ANY AND ALL MATERIALS RELATED TO THE
COMPLAINT HE FILED TO THE PENNSYLVANIA STATE ETHICS COMMISSION
Defendants, by and through their attorneys, Marshall, Dennehey, Warner, Coleman &
Goggin, hereby submit this Memorandum of Law in support of Motion to Strike Plaintiffs
Objections and Compel Production of Documents regarding Plaintiffs Complaint to the
Pennsylvania State Ethics Commission and aver as follows:
I. FACTUAL AND PROCEDURAL BACKGROUND:
On or about June 30, 2006, Plaintiff filed a Complaint generally alleging Defendants
violated the Pennsylvania Whistleblower Law, 43 P. S. §1421, et seq. (A true and correct copy of
Plaintiff Complaint is attached here and incorporated as Exhibit "A"). Plaintiff goes on to
generally state that as a result of this complaint, he was wrongfully discharged from his duties as
a civil servant for the Township of Dickinson. See Exhibit "A", generally.
On or about July 26, 2006, Defendants forwarded to Plaintiffs counsel Damage
Interrogatories, Expert Witness Interrogatories and Request for Production of Documents. (A
true and correct copy of Defendants' Certificate of Service for such discovery is attached hereto
and incorporated as Exhibit "B"). Moving Defendants discovery requests sought, amongst other
things, information in plaintiffs possession regarding his complaint to the Ethics Commission.
Plaintiff responded, in pertinent part, as follows:
"Plaintiff objects to producing the complaint made to the State
Ethics Commission and the documents relating to his complaint,
including the correspondence from the Ethics Commission
because: (1) the specifics of the charge and the investigation of
that charge are not relevant to the subject matter involved in the
pending action and beyond the scope of discovery pursuant to
Pa.R.C.P. 4003.1(a); only the facts that the charge was made, when
it was made, and against whom it was made are relevant and (2)
disclosure would subject Plaintiff to penalties for violating the
confidentiality provisions of the State Ethics Act, 65 Pa. C.S.
§ § 1108(k) and 1109(e)."
(A true and correct copy of Plaintiffs response to Defendant's Request for Production of
Documents and Things is attached hereto and incorporated as Exhibit "E").
Defendants respectfully move that Plaintiffs objections to discovery seeking information
related to Plaintiffs complaint to the State Ethics Commission be stricken. Alternatively,
Defendants respectfully request that this Court enter an Order prohibiting Plaintiff from
introducing into evidence any and all documentation concerning his complaint to the
Pennsylvania State Ethics Commission and/or testifying regarding the complaint he made to the
Pennsylvania State Ethics Commission.
II. LEGAL ANALYSIS
Plaintiffs objections to Defendant's First Request for Production of Documents and
Things, and Defendants' seventh Damage Interrogatory must be stricken. Plaintiff must be
required to provide all documents responsive to Request for Production No. 1, and a full and
complete verified answer to Damage Interrogatory No. 7. Alternatively, Plaintiff must be
prohibited from introducing into evidence any and all documentation concerning his complaint to
the Pennsylvania State Ethics Commission and/or testifying regarding the complaint he made to
the Pennsylvania State Ethics Commission or its investigation.
Plaintiff must answer the above discovery requests because they are reasonably
calculated to lead to the discovery of admissible evidence. Plaintiffs first objection is the
Moving Defendant's discovery requests are beyond the scope of discovery pursuant to Pa.R.C.P.
4003.1(a). See Exhibits "E" and "F". Pa.R.C.P. 4003.1(a) generally states that a party seeking
discovery may obtain discovery regarding any matter, not privileged, which is relevant to the
subject matter involved in the pending action, including the description, nature and content of
documents, or other tangible things. Pa.R.C.P. 4003.1(a), generally. It is the law of this
Commonwealth that documents requests be reasonably calculated to lead to the discovery of
admissible evidence in order to be allowed. Defendants' discovery request here is reasonably
calculated to lead to the discovery of admissible evidence because Plaintiff complains that as a
result of the good faith verbal and written complaint he filed to the Pennsylvania State Ethics
Commission, he was terminated. See Exhibit "A". Clearly, any documents related to the
Pennsylvania State Ethics Commission Complaint and/or investigation are reasonably calculated
to lead to the discovery of admissible evidence, as such documents are the foundation for what
Plaintiff alleges led to his dismissal.
Furthermore, 43. P.S. §1424 (Whistleblower Law) provides in section (d) that an
employee covered by civil service who contests a civil service action, believing it to be
motivated by his having made a good faith report, verbally or in writing, of an instance of wrong
doing or waste, may submit as admissible evidence any or all material relating to the action as
whistleblower and to the resulting alleged reprisal. See 43 P.S. §1424(d). Here, if Plaintiff is to
be allowed to submit any or all verbal or written material of what he alleged to be a good faith
report under the Pennsylvania Whistleblower Law, in this case such report being made to the
Pennsylvania State Ethics Commission (as alleged in paragraph 14 of Plaintiffs Complaint), then
Plaintiff must allow Defendants discovery of such material and information.
Plaintiffs second objection is that only the facts that the charge was made, when it was
made, and against whom it was made are relevant. See Exhibit "E". As previously stated,
Defendants are entitled to discover any and all documents, information or the like that is
reasonably calculated to lead to the discovery of admissible evidence. Clearly, the verbal and/or
sworn written complaint that Plaintiff made to the Pennsylvania State Ethics Commission, which
Plaintiff alleges led to his allegedly improper dismissal, is reasonably calculated to lead to the
discovery of admissible evidence. Such documentation would provide evidence of potential
statements made by Defendants and/or Plaintiff, conduct taken by Defendant and/or Plaintiff,
witnesses to the alleged conduct, as well as other pertinent information.
Plaintiffs third objection is that if he were to produce any documents or answer any
Interrogatories regarding his complaint to the Pennsylvania State Ethics Commission, he would
be violating the confidentiality provisions of the State Ethics Act, 65 Pa. C.S. §§ 1108(k) and
1109(e). The Public Official and Employee Ethics Act, 65 Pa. C.S. §1101, et seq. provides in
section 1108(k) as follows:
"CONFIDENTIALITY. - - As a general rule, no person shall
disclose or acknowledge to any other person any information
relating to a complaint, preliminary inquiry, investigation, hearing
or petition for reconsideration which is before the commission.
However, a person may disclose or acknowledge to another person
matters held confidential in accordance with this subsection when
the matters pertain to any of the following:
(1) final orders of the commission as provided in subsection (h);
(2) hearings conducted in public pursuant to subsection (g);
(3) for the purpose of seeking advice of legal counsel;
(4) filing an appeal from a commission order;
(5) communicating with the commission or its staff, in the course
of a preliminary inquiry, investigation, hearing or petition for
reconsideration by the commission;
(6) consulting with a law enforcement official or agency for the
purpose of initiating, participating in or responding to an
investigation or prosecution by the law enforcement official or
agency;
(7) testifying under oath before a governmental body or a similar
body of the United States of America;
(8) any information, records or proceedings relating to a
complaint, preliminary inquiry, investigation, hearing or petition
for reconsideration which the person is the subject of; or
(9) such other exceptions as the commission by regulation may
direct.
65 Pa. C. S. §1108(k).
If, as Plaintiff contends this provision applies to prevent him from disclosing the requested
information pursuant to the Pennsylvania Rules of Civil Procedure and common law governing
discovery in an action which he brought, then clearly, he would also be prohibited from
disclosing any and all information or material at the time of trial in this matter.
Plaintiff also points out that 65 Pa. C. S. §I 109(e) provides generally that any person who
violates the confidentiality of a Commission proceeding pursuant to § 1108 commits a
misdemeanor. See 65 Pa. C.S. §1109(e). Again, if Plaintiff is truly prevented from producing
any evidence that related to the Pennsylvania State Ethics Commission complaint and/or
investigation, then he must be precluded from introducing any such evidence or testimony at
trial, and paragraph 14 should be stricken from the Complaint.
III. CONCLUSION
Moving Defendants respectfully request that this Honorable Court enter an Order in the
form attached hereto. Furthermore, Plaintiff must be required to produce all records and answer
all discovery related to his complaint to the Pennsylvania State Ethics Commission because such
discovery is reasonably calculated to lead to the discovery of admissible evidence. Alternatively,
Plaintiff must be precluded from introducing or testifying about any evidence of a complaint
filed with the Pennsylvania State Ethics Commission at the time of trial.
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOGGIN
BY:
MARK T. RILEY, ESQtqRE
Attorney for Defendants
Date: //W/` ?-?
\26 A\LIAB\STSTADELMAMLLPG\832287\EMSASSU\05130\00541
MARSHALL, DENNEHEY, WARNER
COLEMAN & GOGGIN
BY: MARK T. RILEY, ESQUIRE
IDENTIFICATION NO. 49427
620 Freedom Business Center, Suite 300
King of Prussia, PA 19406
Telephone: (610) 354-8259
Fax: (610) 354-8299
Email: mtrileya,mdwcg com
Attorney for Defendants
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
JAMES H. SLYDER
V.
DICKINSON TOWNSHIP,
DANIEL E. WYRICK,
THOMAS E. PATTERSON, and
RAYMOND L. JONES
NO.: 06-3762
CERTIFICATE OF SERVICE
MARK T. RILEY, ESQUIRE, being duly sworn and according to law hereby certifies
that a true and correct copy of Defendants' Motion to Strike Plaintiff s Objections to Certain
Discovery Requests and Compel Plaintiffs Production of any and all Materials related to the
Complaint he filed with the Pennsylvania State Ethics Commission was forwarded to counsel on
, 2007, and said document was sent first class mail, postage prepaid,
to the last known address of the other parties or their representatives.
Debra K. Wallet, Esquire
24 N. 32nd Street
Camp Hill, PA 17011
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOGGIN
BY:
MARK T. , UIRE
Attorney for Defendants
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JAMES H. SLYDER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. : CIVIL ACTION - LAW
: NO. 06-3762 CIVIL
DICKINSON TOWNSHIP,
DANIEL E. WYRICK, THOMAS E.:
PATTERSON and RAYMOND L.
JONES,
Defendants
IN RE: MOTION OF DEFENDANTS TO STRIKE PLAINTIFF'S OBJECTIONS
TO CERTAIN DISCOVERY REQUESTS AND COMPEL PLAINTIFF'S
PRODUCTION OF ANY AND ALL MATERIALS RELATED TO THE COMPLAINT HE
FILED WITH THE PENNSYLVANIA STATE ETHICS COMMISSION
ORDER
AND NOW, this 25t" day of January, 2007, a brief argument on the above-captioned
motion of the defendants is set for Thursday, March 29, 2007, at 9:30 a.m. in Courtroom Number
4, Cumberland County Courthouse, Carlisle, PA.
BY THE COURT,
Debra K. Wallet, Esquire
For the Plaintiff
Mark T. Riley, Esquire
For the Defendants
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JAMES H. SLYDER,
Plaintiff
No. 06-3762
V. Civil Action - Law
DICKINSON TOWNSHIP; DANIEL E.
WYRICK; THOMAS E. PATTERSON;
AND RAYMOND L. JONES,
Defendants
PLAINTIFF'S RESPONSE TO MOTION OF DEFENDANTS TO STRIKE
PLAINTIFF'S OBJECTIONS TO CERTAIN DISCOVERY REQUESTS AND COMPEL
PLAINTIFF'S PRODUCTION OF ANY AND ALL MATERIALS RELATED
TO THE COMPLAINT HE FILED WITH THE PENNSYLVANIA
STATE ETHICS COMMISSION
Plaintiff James H. Slyder, by his attorney Debra K. Wallet, Esquire, responds to the
Defendants' motion to strike and compel production as follows:
1. ADMITTED.
2. ADMITTED.
3. ADMITTED.
4. ADMITTED.
5. ADMITTED.
6. It is ADMITTED but the fifth subsection should be labeled "(e)" rather than
"(f)". There was no subsection (f) in the seventh damage interrogatory.
7. ADMITTED.
8. It is ADMITTED that the quoted response is the response to subsection (d) of
paragraph 7. Plaintiff answered subsections a, b, c, and e. The stated objection relates only to
subpart d which requested "the substance of each such complaint."
9. It is DENIED that Defendants are entitled to the requested relief. Plaintiff is
prevented from divulging the substance of his complaint with the State Ethics Commission
based upon both statute and the opinion of the Chief Counsel of the State Ethics Commission.
Plaintiff will produce any and all documents so long as he is ordered to do so by this Court
because he believes he may comply with a valid Order. To make out a prima facia case under
the Whistleblower Act, Plaintiff must establish that he made a good faith complaint.
Prohibiting Plaintiff from introducing the fact that he made the complaint (i.e. paragraph 14 of
his complaint) would deny Plaintiff the opportunity to establish one of the elements of his
whistleblower action.
10. ADMITTED.
11. ADMITTED.
12. The provisions of this paragraph constitute a CONCLUSION OF LAW to which
no responsive pleading is required. Defendants fail to explain what admissible evidence they
believe will be obtained by Plaintiff's production of the complaint to the State Ethics
Commission.
Defendants are also prevented by statute from disclosing or acknowledging any
information relating to Plaintiff's complaint unless it is done pursuant to a valid court order.
Defendants may allege that it is "clear" that the request is calculated to lead to admissible
evidence, but Defendants fail to explain exactly how this is so.
13. The provisions of this paragraph constitute a CONCLUSION OF LAW to which
no responsive pleading is required. Plaintiff does not understand how a provision relating to
an employee covered by Civil Service is relevant to the instant matter when Plaintiff was not
covered by Civil Service when employed by Dickinson Township.
14. The provisions of this paragraph constitute a CONCLUSION OF LAW to which
no responsive pleading is required. Plaintiff intends only to introduce the final order of the
State Ethics Commission which, in and of itself, establishes the making of the complaint and
the "public" aspects of the State Ethics Commission's holding.
15. ADMITTED.
16. The provisions of this paragraph constitute a CONCLUSION OF LAW to which
no responsive pleading is required. Defendants fail to explain what admissible evidence they
believe will be obtained by Plaintiff's production of the complaint to the State Ethics
Commission. Defendants are also prevented from disclosing or acknowledging any
information relating to Plaintiff's complaint, including any other person's statements, unless
the disclosure is done pursuant to a valid court order. Defendants may allege that it is "clear"
that the request is calculated to lead to admissible evidence but Defendants fail to explain
exactly how this is so.
17. ADMITTED.
18. ADMITTED.
19. The provisions of this paragraph constitute a CONCLUSION OF LAW to which
no responsive pleading is required. It is ADMITTED that Plaintiff is prohibited from
disclosing the requested information during discovery or at trial, with the exception of the final
order.
20. ADMITTED.
21. The provisions of this paragraph constitute a CONCLUSION OF LAW to which
no responsive pleading is required. It is DENIED that the allegations contained in paragraph
14 violate the State Ethics Act. To the contrary, the allegations in paragraph 14 provide only
those elements required to make out a case under the Whistleblower Act.
22. ADMITTED.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court refuse the
relief requested by Defendants. Plaintiff will produce any and all documents in his possession
related to his complaint to the Pennsylvania State Ethics Commission only to comply with a
Court Order sufficiently specific to protect him from engaging in unlawful acts or subjecting
him to the penalties for committing a misdemeanor. Plaintiff specifically objects to any
striking of paragraph 14 of Plaintiff's complaint inasmuch as the facts pleaded in paragraph 14
are necessary to establish his whistleblower action and do not violate the State Ethics Act.
Respectfully submitted,
Debra K. Wallet, Esquire
24 North 32' Street
Camp Hill, PA 17011
(717) 737-1300
I.D. No. 23989
Attorney for Plaintiff
s
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JAMES H. SLYDER,
Plaintiff
No. 06-3762
V. Civil Action - Law
DICKINSON TOWNSHIP; DANIEL E.
WYRICK; THOMAS E. PATTERSON;
AND RAYMOND L. JONES,
Defendants
PROOF OF SERVICE
I, Debra K. Wallet, Esquire, hereby certify that on February 2, 2007, I served the
attached PLAINTIFF'S RESPONSE TO MOTION OF DEFENDANTS TO STRIKE
PLAINTIFF'S OBJECTIONS TO CERTAIN DISCOVERY REQUESTS AND COMPEL
PLAINTIFF'S PRODUCTION OF ANY AND ALL MATERIALS RELATED TO THE
COMPLAINT HE FILED WITH THE PENNSYLVANIA STATE ETHICS
COMMISSION by first class mail, postage prepaid, addressed to:
Mark T. Riley, Esquire
MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN
620 Freedom Business Center, Suite 300
King of Prussia, PA 19406
JAAG. x. 1-4 ?
Debra K. Wallet, Esquire
24 North 32nd Street
Camp Hill, PA 17011
(717) 737-1300
I.D. No. 23989
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JAMES H. SLYDER,
Plaintiff
No. 06-3762
V. Civil Action - Law
DICKINSON TOWNSHIP; DANIEL E.
WYRICK; THOMAS E. PATTERSON;
AND RAYMOND L. JONES,
Defendants
PLAINTIFF'S MOTION FOR
RESCHEDULING OF ORAL ARGUMENT
The Plaintiff, James H. Slyder, by his counsel, Debra K. Wallet, Esquire, hereby
requests that the argument scheduled for Thursday, March 29, 2007 at 9:30 a.m. be continued
for the following reasons:
1. By Order dated January 25, 2007, the Court scheduled an argument for
Thursday, March 29, 2007 at 9:30 a. m.
2. Counsel for the Plaintiff has previously signed up for, and paid for, a
Mediation/Labor Relations Board Conference scheduled for March 29, 2007 from 7:30 a.m. to
4:00 p.m. in Harrisburg, Pennsylvania. [A copy of the Notice and the acknowledgment of
payment is attached hereto and made a part hereof) .
3. The Attorney for the Defendants, Mark T. Riley, has no objection to this
request for rescheduling.
4. Counsel for the Plaintiff suggests that she be responsible to arrange a new date
suitable to the Court and all parties and that she do so within three days of the receipt of this
motion.
5. The undersigned counsel apologizes for any inconvenience this continuance
request may cause the Court.
WHEREFORE, Plaintiff respectfully requests that the oral argument be rescheduled to
a mutually convenient date arranged by counsel for the Plaintiff.
Respectfully submitted,
Debra K. Wallet, Esquire
24 North 32' Street
Camp Hill, PA 17011
(717) 737-1300
ID #23989
Attorney for Plaintiff
Dated: February 16, 2007
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LAQOR & "11Y1N1S't'RY
WAV-sr.A1,rn nr rrVNAVIV,%NVA
Ms. Debra K. Wallet, Esquire
24 North 32nd Street
Camp Hill, PA 17011
Dear Ms. Wallet:
PENNSYLV:kNIA LAHoi2 RFLAT7ONs BOARD
419 L,\80 K ANr, INDUSTRY BUILDING
SF..VENTFI AND FORSTER'STREETS
HA RRISRURG, PA 17120
717-7,V7 1091
www,dfi.aatc,rtt,u?
February 15, 2007
This is to acknowledge that we have received your paid registration on
January 5, 2007 for the '70 Years of Working Together Pennsylvania Bureau of
Mediation and the Pennsylvania Labor Relations Board Conference' being held
on March 29, 2007 at the Crowne Plaza in Harrisburg.
Vevy eiy, M.`Plorence
Administrative Officer
An Equa; Opportwnny Fmoover"
'Auxilary aids and services are avclWt?e upon Wuenr to Indivlouds with d Wb Ilfes"
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JAMES H. SLYDER,
Plaintiff
No. 06-3762
V. Civil Action - Law
DICKINSON TOWNSHIP; DANIEL E.
WYRICK; THOMAS E. PATTERSON;
AND RAYMOND L. JONES,
Defendants
PROOF OF SERVICE
I, Debra K. Wallet, Esquire, hereby certify that on February 16, 2007, I served a
copy of the attached PLAINTIFF'S MOTION FOR RESCHEDULING OF ORAL
ARGUMENT by first class mail, postage prepaid, addressed as follows:
Mark T. Riley, Esquire
MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN
620 Freedom Business Center, Suite 300
King of Prussia, PA 19406
LaA..& W • J*"04-
Debra K. Wallet, Esquire
24 North 32nd Street
Camp Hill, PA 17011
(717) 737-1300
I.D. No. 23989
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANI.
JAMES H. SLYDER,
Plaintiff
No. 06-3762
V. Civil Action - Law
DICKINSON TOWNSHIP; DANIEL E.
WYRICK; THOMAS E. PATTERSON;
AND RAYMOND L. JONES,
Defendants
ORDER
AND NOW, this day of fz lg?gj::?j , 2007, upon consideration
of Plaintiff's Motion for Rescheduling of Oral Argument, the Court hereby issues the
following:
The oral argument previously set for Thursday, March 29, 2007 at 9:30 a.m. is
rescheduled for the ? day of , 2007, at o'clock /'.M.
Debra K. Wallet, Esquire
For the Plaintiff
Mark T. Riley, Esquire
For the Defendants
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BY THE COURT:
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JAMES H. SLYDER,
Plaintiff
No. 06-3762
V. Civil Action - Law
DICKINSON TOWNSHIP; DANIEL E.
WYRICK; THOMAS E. PATTERSON;
AND RAYMOND L. JONES,
Defendants
JOINT MOTION FOR ENTRY OF STIPULATED ORDER
TO RESOLVE DISCOVERY DISPUTE
AND REQUEST TO CANCEL THE
APRIL 5, 2007 ARGUMENT DATE
The Plaintiff, James H. Slyder, by his counsel, Debra K. Wallet, Esquire, and
Defendants, by and through their attorneys, Marshall, Dennehey, Warner, Coleman & Goggin,
hereby request that the Court enter an Order resolving the parties' discovery dispute and state
in support of their request as follows:
1. The Court has set a brief argument on Defendants' motion to strike Plaintiff's
objections to certain discovery requests and compel Plaintiffs production of any and all
materials related to the complaint he filed with the Pennsylvania State Ethics Commission for
April 5, 2007 at 2:30 p.m. in Courtroom #4, Cumberland County Courthouse, Carlisle,
Pennsylvania.
2. On January 15, 2007, Defendants filed a motion to strike Plaintiff's objections
to certain discovery requests.
3. On February 5, 2007, Plaintiff filed a response explaining that he was prevented
from divulging the substance of his complaint with the State Ethics Commission based upon
both statute and the opinion of the Chief Counsel of the State Ethics Commission.
4. Plaintiff has always been willing to produce any and all documents so long as he
is ordered to do so by this Court so that he is protected from penalties under the State Ethics
Act.
5. The parties are satisfied with the entry of the Order attached hereto as Exhibit A
and request that the Court enter this Order.
6. Entry of the attached Order will resolve all matters currently before the Court
regarding outstanding discovery.
7. Entry of this Order will obviate the need for the scheduled argument.
8. In the event that the Court chooses not to enter the attached Order, counsel for
Plaintiff is otherwise unavailable on April 5 at 2:30 p.m. because of an arbitration in
Lycoming County which was scheduled prior to the Court's February 26 scheduling Order.
(See Exhibit B attached hereto and made a part hereof).
9. In the event that the Court wishes to hear oral argument, Plaintiff respectfully
requests that it be rescheduled for a date on which she is available. Counsel for the Defendants
has no objection to this request.
10. Counsel for the Plaintiff suggests that she be responsible to arrange a new date
suitable to the Court and all parties and that she do so within three days of the receipt of this
motion.
! 3,'21/2007 WED :.5:12 FAY f.110 292 0410 MDWC'G tiORRISTOWN
WHEREFORE, Plaintiff and Defendants request that the Court enter the attached Order
or, in the alternative, that the oral argument be rescheduled to a mutually convenient date
arranged by counsel for the Plaintiff.
Respectfully submitted,
'Am le . 6 LL,,,*
Debra K. Wallet, Esquire
24 North 32d Street
Vamp Hill, PA 17011
(717) 737-1300
ID #23989
Attorney for Plaintiff
--7
Mark T. Riley, Esquire
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOGGIrir
620 Freedom Business Center, Suite 300
King of Prussia, f'A 19406
(610) 354-8299
ID #49427
Attomey for Defendants
Dated: March 21, 2007
RE: BOARD OF ARBITRATORS
IN THE COURT OF COMMON PLEAS OF LYCOMING COUNTY, PENNSYLVANIA
ALEX A. KASCHOCK,
Plaintiff
VS. NO. 06-01,490
LYCOMING COUNTY,
Defendant
TO: Debra K. Wallet, Esq. V
24 North 32nd Street, Camp Hill PA 17011
Robin A. Read, Esq.
ARBITRATORS: James R. Protasio
Richard A. Gahr
Brad Hillman
SUBSTITUTE ARBITRATOR: Lester L. Greevy, Jr.
NOTICE OF ARBITRATION HEARING
Notice is hereby given that an arbitration hearing in the
above matter has been rescheduled for Thursday, April 5, 2007
at 1:00 p.m. in the Basement Conference Room #03 of the
Lycoming County Courthouse, 48 West Third Street, Williamsport,
PA 17701 at which time all parties may appear to present their
evidence.
The substitute arbitrator shall keep his/her schedule open
on the day and time of the scheduled arbitration hearing in the
event that a member of the original arbitration panel is unable
to serve. The substitute arbitrator will be notified by the
Court Administrator's Office in the event a s bst'tution is
necessary.
Betty R. uckle
Court Administrator's Office
Dated: February 16, 2007 (570) 327-2318
NOTE: UPON SETTLEMENT OF AN ARBITRATION CASE PRIOR TO DATE OF
HEARING, ATTORNEYS ARE REQUESTED TO NOTIFY THE COURT
ADMINISTRATOR'S OFFICE AND THE ARBITRATORS APPOINTED TO HEAR
THEIR CASE. THANK YOU.
Exhibit B
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JAMES H. SLYDER,
Plaintiff
No. 06-3762
V. Civil Action - Law
DICKINSON TOWNSHIP; DANIEL E.
WYRICK; THOMAS E. PATTERSON;
AND RAYMOND L. JONES,
Defendants
PROOF OF SERVICE
I, Debra K. Wallet, Esquire, hereby certify that on March 21, 2007, I served a
copy of the attached JOINT MOTION FOR ENTRY OF STIPULATED ORDER TO
RESOLVE DISCOVERY DISPUTE AND REQUEST TO CANCEL THE APRIL 5, 2007
ARGUMENT DATE by first class mail, postage prepaid, addressed as follows:
Mark T. Riley, Esquire
MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN
620 Freedom Business Center, Suite 300
King of Prussia, PA 19406
James H. Slyder
429 Chestnut Street
Mount Holly Springs, PA 17065
1 DOA4 V. Q"A,*-
Debra K. Wallet, Esquire
24 North 32`d Street
Camp Hill, PA 17011
(717) 737-1300
I.D. No. 23989
Attorney for Plaintiff
MAR 8 3 2007 tfi
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JAMES H. SLYDER,
Plaintiff
No. 06-3762
V. Civil Action - Law
DICKINSON TOWNSHIP; DANIEL E.
WYRICK; THOMAS E. PATTERSON;
AND RAYMOND L. JONES,
Defendants
ORDER
AND NOW, this z I' day of 2007 it is ORDERED that
Plaintiff shall provide a full, complete, and verified answer to Defendants' damage
interrogatory number 7 within ten (10) days from the date of this Order. This Court is
satisfied that compliance with this Order will not subject the Plaintiff to penalties under the
Pennsylvania State Ethics Act.
The oral argument set for the 5' day of April, 2007 at 2:30 o'clock p.m. in Courtroom
#4, Cumberland County Courthouse, Carlisle, Pennsylvania is hereby canceled.
BY THE COURT:
Xebra K. Wallet, Esquire
For the Plaintiff
dark T. Riley, Esquire
V'l For the Defendants
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CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA ORIGIK
PURSUANT TO RULE 4009.22 "'q
IN THE MATTER OF: COURT OF COMMON PLEAS
JAMES H. SLYDER TERM,
CUMBERLAND
-VS- CASE NO: 06-3762
DICKINSON TOWNSHIP, ET AL
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of MARK T. RILEY, ES
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
DATE: 03/26/2007
MICS% on behalf of
Attorney for DEFENDANT
R1.17s 133-H DE11-0678818 34152 -LO2
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
JAMES H. SLYDER
-VS-
DICKINSON TOWNSHIP, ET AL
COURT OF COMMON PLEAS
TERM,
CASE NO: 06-3762
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
JCB; INC.
EMPLOYMENT
TO: DEBRA WALLET, ESQUIRE, PLAINTIFF COUNSEL
MCS on behalf of MARK T. RILEY, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice period is
waived or if no objection is made, then the subpoena may be served. Complete
copies of any reproduced records may be ordered at your expense by completing
the attached counsel card and returning same to MCS or by contacting our local
MCS office.
DATE: 03/06/2007
CC: MARK T. RILEY, ESQ. - 05130-00541
Any questions regarding this matter, contact
MCS on behalf of
MARK T. RILEY, ESQ.
Attorney for DEFENDANT
THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
R1.25 133-H DE02-0356542 34152 -COl
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
JAMES H. SLYDER
VS.
DICKINSON TOWNSHIP, ET AL
File No. 06-376
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for JCB IN
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: ****SEE ATTACHED RIDER****
at The MCS Groun Inc 1601 market S=et Suite 800.Philadelphia. PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within, twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: ALLYSON M. ROSSEE
ADDRESS: 620 FREEDOM BUSIIVI
KING OF PRUSSIA. PA 19406
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
MAR 2 6 2007
Date:
Seal of the Court
BY THEC,0URT:
Prot}aonotary/Cler ision
Deputy
34152-02
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
JCB, INC.
CAMP HILL, PA
RE: 34152
JAMES H. SLYDER
Prior approval is required for fees in excess of $150.00 for
hospitals, $100.00 for all other providers.
INCLUDING VACATION & SICK DAY USAGE. PERFORMANCE REVIEWS, DISCIPLINARY
ACTIONS/WARNING & REWARDS, ETC
Any and all employment records, applications, files, memoranda, compensation,
time and attendance records, personnel records, payroll and salary reports and
all medical records as an employee, including any and all such items as may be
stored in a computer database or otherwise in electronic form, pertaining to:
Dates Requested: up to and including the present.
Subject : JAMES H. SLYDER
429 CHESTNUT STREET, MT. HOLLY SPRINGS, PA 17065
Social Security #: XXX-XX-5441
R1.17S 133-H SU10-0674146 34152-LO2
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CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22 ORIGINAL
IN THE MATTER OF:
JAMES H. SLYDER
DICKINSON TOWNSHI
As a prerequisite
to Rule.4009.22
COURT OF COMMON PLEAS
TERM,
CUMBERLAND
-VS- CASE NO: 06-3762
P, ET AL
to service of a subpoena for documents and things pursuant
MCS on behalf of MARK T. RILEY, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
DATE: 06/30/2008
C on behalf f /7
K T. RILEY; ES /
Q
Attorney for DEFENDANT
R1.73 133-H DE11-0759376 34152-L03
16 y
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
JAMES H. SLYDER
-VS-
DICKINSON TOWNSHIP, ET AL
COURT OF COMMON PLEAS
TERM,
CASE NO: 06-3762
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
MARCUS MCKNIGHT, ESQ. LEGAL RECORDS
TO: DEBRA WALLET, ESQUIRE, PLAINTIFF COUNSEL
MCS on behalf of MARK T. RILEY, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice period is
waived or if no objection is made, then the subpoena may be served. Complete
copies of any reproduced records may be ordered at your expense by completing
the attached counsel card and returning same to MCS or by contacting our local
MCS office.
DATE: 06/10/2008
CC: MARK T. RILEY, ESQ. - 05130-00541
Any questions regarding this matter, contact
DEBRA WALLET, ESQUIRE
24 N. 32ND STREET
CAMP HILL, PA 17011
MCS on behalf of
MARK T. RILEY, ESQ.
Attorney for DEFENDANT
THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
R1.60S 133-H DE02-0395518 34152-COl
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
JAMES H. SLYDER
VS.
DICKINSON TOWNSHIP, ET AL
File No. 06-3762
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for MARCUS MCKNIGHT. ESQ.
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: **** SEE ATTACHED MER ****
at The MCS troun. Inc.. 1601 Market Street, Suite 800, P ilad jpl?iaPA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it. ,
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: MARK T. RILEY. ES
ADDRESS: 620 FREEDOM BUS]
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
BY ML a
Pro notary/ Civi ivision
JUt 3 0 2008 Deputy
Date: 2n,68
Seal of the Court
34152-03
. %
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
MARCUS MCKNIGHT. ESQ.
IRWIN & MCKNIGHT
60 W. POMFRET STREET
CARLISLE. PA 17013
RE: 34152
JAMES H. SLYDER
Prior approval is required for fees in excess of $150.00 for
hospitals, $100.00 for all other providers.
ANY/ALL DOCUMENTS RETAINED AND/OR IN YOUR POSSESSION AS A RESULT OF
YOUR POSITION AS TWP. SOLICITOR FOR DICKERSON TWP. REGARDING THE
EMPLOYMENT OF JAMES SLYDER BY DICKERSON TWP. INCLUDING, ANY AND ALL
CORRESPONDENCE BETWEEN YOURSELF & MR. & MRS. PETE SHELLMAN
Dates Requested: up to and including the present.
Subject : JAMS H. SLYDER
429 CHESTNUT STREET, MT. HOLLY SPRINGS, PA 17065
Social Security #: XXX-XX-5441
R1-60S 133-H
SU10-0737874 34152-L03
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
JAMES H. SLYDER,
CASE NO: 06-3762
Plaintiff,
V.
DICKINSON TOWNSHIP; DANIEL
E. WYRICK; THOMAS E. PATTERSON;
AND RAYMOND L. JONES,
Defendants.
PRAECIPE FOR WITHDRAWAL OF APPEARANCE
TO: PROTHONOTARY OF CUMBERLAND COUNTY
Kindly withdraw the appearance of MARK T. RILEY, ESQUIRE and
MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN on behalf of
THOMAS E. PATTERSON, one of the defendants.
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOGG
i
B. .
MARK T. RILEY, ESQUIRE
r
PRAECIPE FOR ENTRY OF APPEARANCE
TO: PROTHONOTARY OF CUMBERLAND COUNTY
Kindly enter the appearance of MARK R. HAMILTON, ESQUIRE and
CIPRIANI & WERNER, P.C. on behalf of THOMAS E. PATTERSON, one of the
defendants.
CIPRIANI & WERNER, P.C.
By:
MARK R. HAMILTON, ESQUIRE
Attorneys for Thomas E. Patterson,
Defendant.
A JURY TRIAL IS DEMANDED
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David L. Schwalm, Esquire
I.D. #32574
THOMAS, THOMAS & HAFER, LLP
305 North Front Street
P. O. Box 999
Harrisburg, PA 17108
(717) 255-7643
Attomevs for Defendant Raymond L. Jones
JAMES H. SLYDER,
V.
Plaintiff,
DICKINSON TOWNSHIP, DANIEL E.
WYRICK, THOMAS E. PATTERSON, and
RAYMOND L. JONES,
Defendants
No. 06-3762
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter the appearance of David L. Schwalm, Esquire and the law firm of
Thomas, Thomas & Hafer, LLP on behalf of Defendant Raymond L. Jones in this
matter.
Respectfully submitted,
THOMAS, THOMAS & HAFER, LLP
Date: February 3, 2009
David . Schwalm, Esquire
I.D. #32574
305 North Front Street
P.O. Box 999
Harrisburg, PA 17108
(717) 255-7643
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
PRAECIPE FOR WITHDRAWAL OF APPEARANCE
Kindly withdraw the appearance of Mark T. Riley, Esquire and the law firm of
Marshall, Dennehey, Warner, Coleman & Goggin on behalf of Raymond L. Jones in this
matter.
Respectfully submitted,
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOGGIN
By:
T. Riley, squire
I.D. #49427
620 Freedom Business Center
Suite 300
King of Prussia, PA 19406
(610) 354-8259
664458.1
2
CERTIFICATE OF SERVICE
AND NOW, this 13th day of February, 2009, I, David L. Schwalm, Esquire, hereby
certify that I sent a true and correct copy of the foregoing document by placing a copy of
the same in the United States Mail, postage prepaid, to the following:
Debra K. Wallet, Esquire
24 N. 32nd Street
Camp Hill, PA 17011
Attorneys for Plaintiff
Mark T. Riley, Esquire
Marshall, Dennehey, Warner, Coleman & Goggin
620 Freedom Business Center, Suite 300
King of Prussia, PA 19406
Attorneys for Dickinson Township
Mark R. Hamilton, Esquire
Cipriani & Werner
650 Washington Road, Suite 700
Pittsburgh, PA 15228
Attorneys for Thomas Patterson
Anthony R. Sherr, Esquire
Mayers, Mennies & Sherr, LLP
3031 Walton Road, Suite 330
P.O. Box 1547
Blue Bell, PA 19422-0440
Attorneys for Daniel E. Wyrick
OMAS, THOMA HAFER, LLP
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CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF: COURT OF COMMON PLEAS
JAMES H. SLYDER TERM,
CUMBERLAND
-VS-
CASE NO: 06-3762
DICKINSON TOWNSHIP, ET AL
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of MARK T. RILEY, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
MCS on behalf of
DATE: 03/17/2009
MARK T. RILEY, ESQ.
Attorney for DEFENDANT
R2.07 116-H
DE11-0868107 34152-LO4
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
JAMES H. SLYDER
-VS-
DICKINSON TOWNSHIP, ET AL
COURT OF COMMON PLEAS
TERM,
CASE NO: 06-3762
NOTICE OF INTUIT TO SERVE A SUBPOIFA TO PRODUCE DOCUKMO AND
TSINGO FOR DISCOVERY PUROV TO RULE 4009.21
G.E. GILLESPIE
SERVICE RECORDS
TO: DEBRA WALLET, ESQ., PLAINTIFF COUNSEL
MCS on behalf of MARK T. RILEY, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice period is
waived or if no objection is made, then the subpoena may be served. Complete
copies of any reproduced records may be ordered at your expense by completing
the attached counsel card and returning same to MCS or by contacting our local
MCS office.
DATE: 02/23/2009
MCS on behalf of
MARK T. RILEY, ESQ.
Attorney for DEFENDANT
CC: MARK T. RILEY, ESQ.
DEBRA WALLET, ESQ.
L/O OF DEBRA WALLET
24 N. 32ND STREET
CAMP HILL, PA 17011
05130-00541
THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
R1.81S 116-H Ds02-0476806 34152-CO1
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
JAMES H. SLYDER
VS.
DICKINSON TOWNSHIP, ET AL
File No. 06-3762
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for G.E. GILLESPIE
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: **** SEF ATTACHED RIDER ****
at The MCS GrmW, Inc., 1601 Market Street, Suite 800, P it d lhi , PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME:
ADDRESS:
TELEPHONE:. (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
BY COURT:
onotary/ i fivision
*R 171009
Date: F 19 ?1Y9?'
Deputy
Seal of the Court
34152-04
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
G.E. GILLESPIE
10108 GOLF COURSE ROAD
FAYETTEVILLE, PA 17222
RE: 34152
JAMES H. SLYDER
Prior approval is required for fees in excess of $150.00 for
hospitals, $100.00 for all other providers.
INCLUDING ALL DOCUMENTS AND INFORMATION IN YOUR POSESSION INCLUDING
THOSE DOCUMENTS GENERATED AND/OR OBTAINED FOR THE PURPOSES OF
GENERATING A FINANCIAL STATUS AND/OR FOR COMPLETING TAX DOCUMENTS.
ANY AND ALL SERVICE RECORDS PERTAINING TO:
Dates Requested: up to and including the present.
Subject : JAMES H. SLYDER
429 CRESTNU STRBET, MT. HOLLY SPRINGS, PA 17065
Social Security #: XXX-XX-5441
R1.81S 116-H SU10-077412o 34152-LO4
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
JAMES H. SLYDER
V.
NO.: 06-3762
DICKINSON TOWNSHIP,
DANIEL E. WYRICK,
THOMAS E. PATTERSON, and
RAYMOND L. JONES
PRAECIPE TO SETTLE. DISCONTINUE & END
TO THE PROTHONOTARY:
Kindly mark the above matter, Settled, Discontinued and Ended with prejudice upon
receipt of your costs.
BY: -?I le. Klux &
DEBRA K. WALLET ESQUIRE
Attorney for Plaintiff
DATED: 0144 20, Aooq
26/ 1285224.v 1 05130-541
IL
L
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JAMES H. SLYDER,
Plaintiff
No. 06-3762
V. Civil Action - Law
DICKINSON TOWNSHIP; DANIEL E.
WYRICK; THOMAS E. PATTERSON;
AND RAYMOND L. JONES,
Defendants
CERTIFICATE OF SERVICE
I, Debra K. Wallet, Esq., hereby certify that on May 21, 2009, I served a copy of the
attached PRAECIPE TO SETTLE, DISCONTINUE & END by first class mail, postage
prepaid, addressed to:
Mark T. Riley, Esquire
MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN
620 Freedom Business Center, Suite 300
King of Prussia, PA 19406
David L. Schwalm, Esquire
THOMAS, THOMAS & HAFER, LLP
305 North Front Street
P.O. Box 999
Harrisburg, PA 17108
Anthony R. Sherr, Esquire
MAYERS, MENNIES & SHERR, LLP
3031 Walton Road, Building A, Suite 330
P.O. Box 1547
Blue Bell, PA 19422
Mark R. Hamilton, Esquire
CIPRIANI & WERNER, P.C.
650 Washington Road, Suite 700
Pittsburgh, PA 15228
444. 4, v . "At+..l-
Debra K. Wallet, Esquire
24 North 32`d Street
Camp Hill, PA 17011
(717) 737-1300
I.D. No. 23989
Attorney for Plaintiff
OF