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Home My WebLink About11-22-04 Exhibtis EXHIBIT j ~ I L--. TUESDAY, AUGUST 19, 2003 &'i David M. Gross David M. Gross, 45, of Camp Hill, diod SWlday. August 17, 2003 in the Holy Spirit HospifiU, Camp Hill. :.:: 80m in Hattisburg, he gr&i. Uated from Central Dauphi:Q High School, ClCtSs of 1375; He had vari. ' , OUS sales posi- tions in the Harrisburg area, Was a lo- cal Model, and a former em. ployee of the ' Harrisburg GROSS ...- State Hospital. fIe was kind. sensitive and loved all people:: He was a member of 81. Cath- erine LaboUre Catholic Church, st. Joseph Cathoiic Church. Mechanicsburg, Knights of C0- lumbus and CoS11lopolitan In- ternational. Sw-viving are his mother, Ra- mona B, Zelinski Gross of Harrisburg; a brother; AnUlony Gross ofPll1.ladelphia; a sisterJ Mary Ellen Brouse of MarysViIle; a brother, Brian Gross of Dilkburg; nieces, Dan- ielle BroU$C. Celeste and DottU- ' nque Gross; a nephew; Joel GroBSi his flaD.cee', Elizabeth I Barth, with whom he lived; nu- I :~~ous aunts, uncles and ~~- Mass of Christian Burial w;i.ll be celebrated at 11 a.m. Thurs~ /' day, at St. Catherine Labogre Catholic Church, 400Q Derry I Strflet. Harrisburg. Burial' M1.l be in Holy Cross Cemete-~f' Viewing will be held from ,,-"9 p.rn.. Wednesday, at the Ne.Ul Funeral Rome, 3501 Def)::y Street; Harrisburg. Recitat;,2n of tile Rosary will ,be at 8.:jO P~.W~~Myatfuefun~~ home. ' Memorial contr1butions tnay I be made to the Disabled Ameri. can Veterans, 4219 Trin~Je Road, Camp H1ll, P A 17011. ':, I WWW.neillih.com " ,:0:: " WWW.pennlive.coInlopits::; "~:.~~;~.i~\~~,,/ 1 \~". ',:.1'~~~"~ ,:;W~':i.t:.J, '~"~" ~.r :, ~::~J:,:~\' ,\'. Ji,I , _.' I EXHIBIT ~'2- L-.. .... TUESDAY, AUGUST 19, 2003 61 ~:< David M. Gross DaVid M. Gl"CSS, 45, of Camp HUl, diod Sunday, Aueust 17, 2003 in the Holy Spirit HospifliJ., Camp Hill. ::: Born :In Hattisburg, he sril1l. \Ul.ted trom Central I>au.phm High $chool, ClaSs ail.975. He hal1 varj. , ous sales posi. tions ill the Harrt-sburg area, was a lo- cal Model, and a former em. ployee of the ' Harrisburg GROSS - State Hospital. lie was kind. sensitive and loved all people:: He was a member of Sf. Cath- erine LaboUre Catholic Church, St. Joseph Cathoilc Churcl]., Mechaniasburg, .Knights of C0- lumbUs and Cosmopolitan In- ternational. '. Surviving are his mother, Ra- J mana B, Zelinski Gross of Harrisburg; a brother; Anthony Gross o!'PbUadelPhia; a sisterJ Mary Ellen Broun of MarysVme; a brother, Brfa'h Gross of Dilli:burg; nieoes, Dan- ielle BroUSe, Celeste and Dom'i. . nque Gross; a nephew; Joel GroSSi his fiancee', Elizabeth . ~ With whom he lived; nu- merous aunts, uncles and cous- ins. . Mass of Christian Burial w.fll be calebrated at 11 a.m. Thurs- /' day, at St. Catherine Labo-gre Catholic Church, .400Q Derry I Str~t, Hanisburg. Burial' ~ be in naly Cross Cemetery. , Viewing will be held from ...'laB p.m. Wednesday, at the Ne.Ul Funeral Rome, 8501 DerA)" Street; Harrisburg. Rec1ta~Qn of the Rosary will .be at ~:JO pm.W~~~at~eftm~~ home. . MemOrIal contr1bUUons tnay be made to the Disabled Ameri. can Veterans, 4219 Trin~)e Road, Camp H1ll, P A 17011. '." I WWW.nellJ1h.co.m '.:':} " www,p6nntlve.coinlopits." ~;'Jh{;..' '~~~i;\ I f~:\- ~ r) . Thi;; is [0 certify char rht, informatioll bere gjYt~n is correctly ("/,it'd from :w orlgina' certiii;;ltc of dC:Jth duly filed vijtil nl'.' a!, L(~a1, Regi,tI'Qr.' The original cenifJcare wi!! 'he /orwardrd to the \c.m: \/ilal r~t'co,.(h (.1/tlU: 1;:11 pel'manl~1)( Iliing, WARNING: It is Illegal to duplicate this copy by photostat or photograph. f~ Fct' fell' thi!. certificate, $2,00 t...Jo, ;fii;Ii;;;;;;;"..../..;;.,~..' .,(o\f,,\I.\1!Lllf PEl""';. l~'}~' ' . "~f:;.\ ~.,\ ~I . "".~ " \<;;;;') i~. . \ ,~~ ~c::i ' ~_."- l: '-' .:..e..... ~ ~ . ~ ~*f, .~.'k! );,*', /"'''':-10/ ':'t~ ~"" '.,. ....._~.,,~~/~ 'C_ .:q!,,t' ,._-, ~~ ~ . '~~> .'"fNT t)\",,'f.'" ~~t:L!!!f..,' ~'j /~ . ~ /'7'. , ,'.r.. , '--___ '~ t'" P 9701E;78 (> -- ) ~:\ /' 'J --_.~---'{ -~_l'" ~ '~~2_._ ~. ~<lt"'.. H1OS,1<U Rev. US? COMMONWEALTH OF PENNSYLVANIA' DEPARTMENT OF HEALTH' VITAL RECORDS CERTIFICATE OF DEATH TY...."'NT IN ... !NlAHeHT IUA:K INII -' ., Il,f,n; 01' BIIlTH 1-.00\'. Y..r) -0 ~o RACE.__.-._...; (St>odfrl WHiTE; IVRVMNG SPOIISE ........................, Iwp "'-.eyht __ "onr, ....".. _Ie -.... e- UNOElU. VING CAUl! Illioo... or tnjo,ry . --...... '........ on ....111 ) LAlIT WAS AI< AUTOPSY WERE ,wTOPSY FIHOINOS PERFORMED? AV_E PRIOR TO COMPLETION Of CAUSE Of DEATH1 I: DUE TO (~A11 A CONIEQUENCE OfJ; 14~(; P,. 17/11 RY sr. UA! I"..c. DA 0 -. Oor. Y_) Ub, Uc. WAS CASE I\EFERRED TO A MEOtCAL EXAMINER 1CDRa.ER1 25, Va 0 No il :~ Purr.: Olherllgn__-..nv..-.... ;=:=. ... ,--.......~ _.... it PART I. ; h ;f~~ ;,(~cftY~/<" o AI A. COHIEOUEHCE OFf: _NER OF DEATH Y.. 0 Ho~ VOID NoD Hlkonl Addont - ~ o o - Poncllng -1iV1""" Could nor be d.l~ DATE OF I'IJURY -1Iar,yow) o o -D~O O )Oa. 3Gb. M. )Oc. PlACE Of INJURY ./oJ -.,...... _~ "*'Y. __ ........_.fJ.~' JOo. T1I.lE OF INJURY INJURY AT WOIIK1 DESCRIBE HOW INJURY OCCURRED, n, W~ ~ rt-l u, I EXH'IIT f.~1? r) Thj:; is LO ccrtifv thaI' rhe information here givnl IS correctly 'nf,ied frum :111 urlglfl<ll Lt'I"tJ11::llr o{ c1c:JtJ. duly filed viirh 111<' a.' Lq.'aJ' Regi~traL The original certificate will he forwarded tn rJH \(;1((: \lita! r(('cord,-; ()ffiu: i;" perm;inenl filing. WARNING; 11 is illegal to duplicate this copy by photostat or photogmph. ((0 l'-.Jo, . _ ;;ii"r;i'iIii;~-:"~.~:;;,~. '. -<,i/' \',\111I1F P[-'-c. ,;.f,l~~..",~,:.--""", "....14f \;, J ~.lr,,/ ,,' ,_ ..~_(I};~} ~""iti,' . m;;'" , \~~~ f~' I. ,.,\ \~t ., <::'J )_',. ~~ 'A~ \ *" .,).... 'Il *' ~~ \'~;'...~L,;;;;..\~\Y \,.- ~.(.>/8';" .,", ~'<.. ' ,I\' "<.l!7fNT n\ """"' -"':~~!:'!!!!.~::L~!.'l!.. - ~ (/~i//'/ -.L.~ ~ ~/7~' , -.d4#- . ,/ " '. _____ ",>C~ / Fee fell' rhis certificate. $2,00 F' S 7' 0 1 t~ (' b (>" ! r.:\ /" 'J ___.___....i:L.~~~_Z'._r - '~_~~2'__ ;H ~;_-~ r!;" H1D5.H3 Rev. 2/87 COMMONWEALTH OF PENNSYLVANIA' OEPARTMENT OF HEALTH' VITAL RECOROS CERTIFICATE OF DEATH TYPElPRINT IN J- :!RMANENT SLACK ',..K BIRTHPLACE (CMy... SI_'. or Far.ton Country) HARltiSI!>"'Ali, fA. ::." 0 RACE._ _n.1IJod<. While...' (Sl>o<ify) WHiTE SVRV1V1NG SPOUSE I......... "*""__) ""', /7111 '7"1 $eQu.nlilly litl conditio,.. if any, ".q to i"nrMdYle cauw. EN., UNDERLYING CAUSE (Dis.... orlnjlny 1hM "'leCl eyenlJ, ,MUtI...g on d..th ) LAST W/>,S N< AUTOPSV WERE AUTOPSV FINO'NGS PERFORMED? AVAIlABLE PRIOR TO COMPlET'ON OF CAUSE OF DEATH? [ : Z3b. 230. W/>,S CASE REFERRED TO A MEDiCAl. EXAMINER /CORONER? 26. V" 0 No ~ ~ ~le PART U; 0Chef .ignific:;;ara c:oncRcklnI CClnlrtbuIinf 10 dMEh. but :=:~= not'lWtunofnl'Mt~caUMgiveni1PARTI. , h',J~~ ~~cfO('~J/ DUE TO lOA AS" CONiEOUEHCE OFI; DUE TO (OR AS A CONSEQUENCE OF): .........NER OF OEA TH NllunIl Qg o o Homldde Pending InYasttglUoo CoukI nol be determined OA TE OF INJURV ("'onI1.08Y, y...., o o o TIME OF 'NJURV INJURV AT WORK? DESCRIBE HOW INJURV OCCURRED. Accident Ve. 0 No iZJ V.,o NoD Suocid. 30.. 3Gb. he. PlACE OF INJURY. AI home, llrm. """l. t&aory. otke kIUlhg. ,"c:. ISpedyl 30.. 2t. :J oJ , :.~ .ME.OtcAl EXAMINER/COROHER ':.:::'::::':,:,'e";~'.~~~'~~ .~~~~~ ~~~.~~.'~..~~~~~:. ~ :::~.~"'.~~::...~~.'~ ::~~.'::~~.~. ~.'. ~ lime. .~'~:.~~~ .~'~.~~.: ~~~.~.~~..I~ .I~~. .~~,~~.:~.(:'.~~.. 0 31~ . REGISTRAR'S SIGNATUkE AND HUMBER Wj1. f.r-I 3<4. I (~ T A f 0 rp n t r If H P ot t h r (J r P P tan' AFFIDAVIT OF COMMON LAW MARRIAGE HEALTHAMERICA HEALTHAsSURANCE We, the undersigned, being of lawful age, attest to the following facts: 1. We have lived together continuously as husband and wife from _~..J~/, 'Jqq~ to the present time. During this period we have professed to be husband and wife and we have held ourselves out to the community as being married. 2. That we are 18 years of age or older or, if between the ages of 16 and 18, have obtained appropriate parental or guardian consent. 3. There is no legal impediment to our marriage, including, but not limited to, a prior: marriage of either party that has not been legally terminated by death 'or divorce. 4. We intend to be legally bound as husband and wife and in full recognition of the rights, duties, obligations associated therewith. We have evidenced by words in the present tense, uttered with a view of purpose of establishing the relation- ship of husband and wife. 5. The following children have been born to us and we hereby aCknowledge such . children to be our lawful children. NO C/;zabe+-L M. ful+-l Name of Employee . '. 'j\ttv/d M. (koss Name of Spouse loyee s~d.~ Da~ · J rx-. Date Subscribed and sworn before me this ~0- xI~ 8XHISrr I R.e-.~., .tf-f-2... ~~ day of tly; //.; J If-g-2 . , 20c?::b My commission expires: {~ -/J-O'/ Date ' NOTARIAl SEAL Judy s. Grdlan. Notary Public Lemoyne Borough. County of Cumberland My Commission ExpIres Jun. 7, 2004 2575 Interstate Dri\'c, Harrisburg. PA 17110 800.788-6445 . 717-540-4260 . www.hcalthamerica.cvt}..com (~ r A Co yen try Heal th Core Pion. AFFIDAVIT OF COMMON LAW MARRIAGE HEALTHAMERICA HEALTHAsSURANCE We, the undersigned, being of lawful age, attest to the following facts: 1. We have lived together continuously as husband and wife from ~/~/ "Jqq~ to the present time. During this period we have professed to be husband and wife and we have held ourselves out to the community as being married. 2. That we are 18 years of age or older or, jf between the ages of 16 and 18, have obtained appropriate parental or guardian consent. 3. There is no legal impediment to our marriage, including, but not limited to, a prior marriage of either party that has not been legally terminated by death or divorce. 4. We intend to be legally bound as husband and wife and in full recognition of the rights, duties, obligations associated therewith. We have evidenced by words in the present tense, uttered with a view of purpose of establishing the relation- ship of husband and wife. 5. The following children have been born to us and we hereby acknowledge such . children to be our lawful children. NO EI izahe+L M - ful+-l Name of Employee . ., l~~v/d NL. Name of Spouse 8-ross Jrx-. s~d~~ Date Date Subscribed and sworn before me this ~~x1~ EXHIBIT I ~ti J!l Jf-i-2-. ~~ day of tly; ~ If-g-2 . , 200.2 My commission expires: (17 -/}-oy Date ' II J.2. 0+ M..i+ NOTARIAL SEAL Judy S. Grdjan, Notary Public Lemoyne Borough, County of Cumberland My CommissIon F..xpkes Jun. 7, 2004 2575 interstate Dri\'c, Harrisburg, PA 17110 800-788-6445 . 717-540-4260 . w\vw.hcalthamerica.cvt)'.com '~(Q)~Y DAVID GROSS, PLAINTIFF IN THE COURT OF COMMON PLEP.S DAUPHIN COUNTY, PENNSYLVANIA '. V NO. 2601 S 1999 ARCHIBALD BUILDERS, DEFENDANT JURY TRIAL DEMANDED DEPOSITION OF: DAVID GROSS TAKEN BY: DEFENDANT BEFORE: DIANE F. FOLTZ, RMR NOTARY PUBLIC DATE: MAY 12, 2000, 11:36 A.M. PLACE: GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 MARKET STREET HARRISBURG, PENNSYLVANIA F...PPEARANCES: LITVIN, BLUMBERG, MATUSOW & YOUNG BY: DONALD E. MATUS OW , ESQUIRE FREDRIC S. EISENBERG, ESQUIRE FOR - PLAINTIFF GOLDBERG, KATZMAN & pHIPMAN, P.C. BY: JOHN A. STATLER, ESQUIRE FOR - DEFENDANT 2080 LinglestDwn Road · Suite 103 · Harrisburg; PA 17110 717.540.0220 · fax 717.540.0221 · Lancaster 717.393.s 101 I EXHIBIT , DAVID GROSS MAY 12,2000 Multi-Page™ ., Page 6 I A We moved into there the 4th of July weekend, I 2 1998. 2 3 Q So it's coming up on two years? 3 4 A Yes. 4 5 Q And where did you and Elizabeth live before that? 5 6 A We lived at 2524 South Market Street, 6 7 Mechanicsburg. 7 8 Q How long has Elizabeth Barth been your fiancee? 8 9 A Since carly 1996. 9 10 Q Okay. How long have you been dating Elizabeth JO I I Barth? 1 J 12 A Since 1995. 12 13 Q Is she employed') 1 J 14 A Yes. 14 15 Q Where does she work? 15 16 A Capital Recovery Associates. 16 17 Q Is that a collection agency? J 7 18 A Yes. J8 19 Q And what does she do for them? 19 20 A Oh, she just got a promotion. She's an upper 20 21 level manager. 21 22 Q How long has she worked for Capital Recovery 22 23 Associates') 23 24 A Either earlier this year or latc last year, 24 25 somewhere around the holidays. 25 Page 7 1 Q Okay. Where was she employed before Capital 2 Recovery Associates') 3 A Morrison-Voss Eye Associates. 4 Q And what did she do for them') 5 A Office manager. 6 Q And how long u approximately how long did she 7 work for Morrison Eye Associates? 8 A A couple of years. 9 Q Is that where she was working when you met her') 10 A No 11 Q Where was she working when you met her? 12 A She worked for White Pines Banquet and Catering. 13 Q And what did she do for them? 14 A She was the banquet and catering manager. ] 5 Q Okay. Has Elizabeth Barth ever been married? 16 A No. 17 Q Howald is she? 18 MR MA1lJSOW: And we're not going to tell her you 19 had to stop and think about it. I mean, Fred might, but 20 I'm not going to. 21 THE WITNESS: Somewhere around 30 years old. 122 MR. STATLER: Okay. 23 MR. MAruSOW: Now she's going to know. 24 BY MR. STATLER: 25 Q We won't send her the transcript. Have you ever Page 6 - Page 9 been married? A Yes, Q Okay. When were you married? A November the 9th, 1985. Q And did that marriage:end in divorce? A Yes. Q When were you divorced? A In the spring of either "91 or '92. Q Was that your first and only marriage? A Yes. Q And who were you married to? A Wendy Kay. ' Q K as in the initial K? A K"a-y. Do you want her maiden name? Q Yes. A Felker, F-e-l-k-e-r. Q Okay. Is she remarried? A I'm not sure. Q Did you have any children to that marriage? A No. Q Do you have any children? A No. R Do you know where Wendy Kay Felker lives? A Presently? Q Yes. Page g Page 9 ] A Somewhere in York County. 2 Q Is she employed') 3 A I don't know 4 Q Was she ever employed while you were married? 5 A Yes. 6 Q What was -- to your knowledge, where did she last 7 work? 8 A I'm not sure, but I believe she worked [or an 9 Insurance company, 10 Q Like in an agency or -- 11 A She was a clerk in an insurance company. That's 12 all I know. 13 Q You don't know what insurance company it was? 14 A No. It's been awhile, an~ we were separated. 15 Q All right. Let me start with some questions 16 about your education. You graduated from Central Dauphin 17 High School? 18 AYes. 19 Q What year? 20 A 1975. 21 Q And did you have any schooling beyond high 22 school? 23 A Yes. J attended HarrisbUrg Area COImnunity 24 College in 1976. 25 Q Okay. HUGHES, ALBRIGHT, FOLTZ & NATALE 717-540-0220\717-393-5101 rc(Q)fJY DAVID GROSS, PLAINTIFF IN THE COURT OF COMMON PLEF.S DAUPHIN COUNTY, PENNSYLVANIA " V NO, 2601 S 1999 ARCHIBALD BUILDERS, DEFENDANT JURY TRIAL DEMANDED DEPOSITION OF: DAVID GROSS TAKEN BY: DEFENDANT BEFORE: DIANE F. FOLTZ, RMR NOTARY PUBLIC DATE: MAY 12, 2000, 11:36 A.M. PLACE: GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 MARKET STREET HARRISBURG, PENNSYLVANIA F.-PPEARANCES : LITVIN, BLUMBERG, MATUSOW & YOUNG BY: DONALD E. MATUSOW, ESQUIRE FREDRIC S. EISENBERG, ESQUIRE FOR - PLAINTIFF GOLDBERG, KATZMAN & $HIPMAN, P.C. BY: JOHN A. STATLER, ESQUIRE FOR - DEFENDANT EXHIBIT I eu- 5 2080 Linglesrown Road · Suite 103 · Harrisburg; PA 17110 717.540.0220 · fax 717.540.0221 · Lancaster 717.393.5101 ~ D~ VID GROSS MAY 12,2000 Page 6 I A We moved into there the 4th of July weekend, 2 ]998. 3 Q So it's corning up on two years? 4 A Yes. 5 Q And where did you and Elizabeth live before that? 6 A We lived at 2524 South Market Street, 7 Mechanicsburg. 8 Q How long has Elizabeth Barth been your fiancee? 9 A Since carly 1996. 10 Q Okay. How long have you been dating Elizabeth 11 Barth? 12 A Since 1995. 13 Q Is she employed? 14 A Yes. 15 Q Where does she work'] 16 A Capital Recovery Associates. 17 Q Is that a collection agency? 18 A Yes. 119 Q And what does she do for them? 20 A Oh, she just got a promotion. She's an upper 21 level manager. 22 Q How long has she worked for Capital Recovery 23 Associates? 24 A Either earlier this year or latc last year, 25 somewhere around the holidays. Page 7 I Q Okay. Where was she employed before Capital 2 Recovery Associates? 3 A Morrison-Voss Eye Associates. 4 Q And what did she do for them') 5 A Office manager. 6 Q And how long -- approximately how long did she 7 work for Morrison Eye Associates? 8 A A couple of years. 9 Q Is that where she was working when you met her? ]0 A No. 11 Q \Vhere was she working when you met her? 12 A She worked for White Pines Banquet and Catering. 13 Q And what did she do for them? 14 A She was the banquet and catering manager. ] 5 Q Okay. Has Elizabeth Barth ever been married? 16 A No. 17 Q How old is she? 18 MR MATUS OW And we're not going to tell her you 19 had to stop and think about it. I mean, Fred might, but 20 I'm not going to. 21 THE WITNESS: Somewhere around 30 years old. ,22 MR. STATLER Okay. 123 MR. MATUSOW: Now she's going to know. 24 BY MR. STATLER: 25 Q We won't send her the transcript. Have you ever Page 6 - Page 9 MuIti- Page ™ :1 Page g 1 been married? 2 AYes. 3 Q Okay. When were yoU: married? 4 A November the 9th, ] 985. 5 Q And did that marriage:end in divorce? 6 A Yes. 7 Q When were you divorced? 8 A In the spring of either "91 or '92. 9 Q Was that your first and only marriage? ]0 A Yes. 11 Q And who were you married to? 12 A Wendy Kay. . 13 Q K as in the initial K? ] 4 A K-a-y. Do you want her maiden name? ]5 Q Yes. 16 A Felker, F-e-l-k-e-r. 17 Q Okay. Is she remarried? ]8 A I'm not sure. 19 Q Did you have any children to that marriage? 20 A No. 21 Q Do you have any children? 22 A No. ~3 9 Do you know where Wendy Kay Felker lives? 24 A Presently? 25 Q Yes. Page 9 1 A Somewhere in York County. 2 Q Is she employed? 3 A I don't know. 4 Q Was she ever employed while you were married? 5 A Yes. 6 Q What was -- to your knowledge, where did she last 7 work? 8 A I'm not sure, but I believe she worked for an 9 Insurance company. 10 Q Like in an agency or -- 1] A She was a clerk in an insurance company. That's 12 all I know. 13 Q You don't know what insurance company it was? 14 i\ No. It r s been awhile, an? we were separated. 15 Q All right. Let me start with some questions 16 about your education. You graduated from Central Dauphin 17 High School? 18 AYes. 19 Q What year? 20 A 1975. 21 Q And did you have any schooling beyond high 22 school? 23 A Yes. I attended HarrisbUrg Area Community 24 College in 1976. 25 Q Okay. HUGHES, ALBRIGHT, FOLTZ & NATALE 717-540-0220\717-393-5101 I IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA '--' ~ J cl. '-1- 0 i ~~ 'T-;"' 6 --+- ''v^- <0 ~ ~ ~ \.' ~ ~J ~ \) ~ '-" <:S'" - J ~. C t::\ '-+- ) <.: I:V .:::;::: ~\ "C" ~ 1 ~: --!' DAVID GROSS, _---- Plaintiff CIVIL ACTION - LAW vs. NO. 2601 S 1999 ARCHIBALD Bq~~QERS, Defendant JURY TRIAL DEMANDED - RAMONA GROSS ------ Defendant Deposition of: Taken by --- --- Date --- Novmeber 12, 2003, 12:05 p.m. --------.-". ------..--------- - ----,.- - ~ ....... Place 5007 Virginia Avenue Harrisburg, Pennsylvania Before Ann M. Wetmore Reporter - Notary Public APPEARANCES: LITVIN, BLUMBERG, MATUSOW & YOUNG By: FREDRIC S. EISENBERG, ESQ. For - Plaintiff .~ ~/ '1..., '^ GOLDBERG, KATZMAN & SHIPMAN, P.C. By: THOMAS E. BRENNER, ESQ. For - Defendant '-' /...~ ( -<{ (0// IILlUS_I~Md[/CAS J<r~J(.!/n?~,'c SU<V/CE, /.'vL ______-\_,c::::.--.. Uilrns!Jllrs ;] /-],"i(,-Oh23 YOrh /1/ ~~4<)-6-11S PA J~~WO-23.1-Y.1:::'- ~ ~ 10 11 12 '-" 13 14 15 16 17 18 19 20 21 22 23 '-' 1 A. 2 Q. 3 A. 4 Q. 5 A. 6 7 Q. 8 9 A. Q. A. Q. A. Q. A. Q. 24 A. 25 Q. Exam./Brenner - Gross 5 And Brian. f-Lt. ~ Brian? -- Urn-hum. How old is Brian? Brian Gross, he's about -- they were 17 months apart, about a year I guess. We are here to discuss David and we appreciate unfortunately that he passed away and the questions I don't mean to be insensitive. I'm going to inquire into certain areas and if there are things that you know, tell me that, and if there are things you don't know, that's fine and we'll move on. As I understand it, David prior to his death had a girlfriend of a couple of years. ------------------------------ -- ---- --------- Is that correct? Yes. ---- I think her name was Elizabeth. Is that correct? ----..---- Elizabeth. ~--'~~----. Did you know Elizabeth? ---------..-- Yes. Had they been here to visit at the house? Oh, sure. - How long had Elizabeth and David been friends? That I couldn't tell you. _._...-----_._-~.. .'. --- ------ They were not married, as I understand it, as of -..--.------- FILIUS [~McLUCAS REPORTING SERVICE, INC. l-lnlT,dlJl1'(' 717-216-0()2,1 )'nr],: 717-845-6418 rJA ].ROO<:n3-9.'L!.7 .' - 10 11 12 '-- 13 14 15 16 17 18 19 20 21 "-' 1 2 A. 3 Q. 4 A. 5 Q. 6 7 A. 8 Q. 9 A. Q. A. Q. A. Q. A. Q. 22 I A. 23 Q. 24 25 Exam./Brenner - Gross 6 the time of David's death. Is that correct? . _.__._---"'""'---~--,._...- -_.--~----.------_... ,~-"_.~. - Right. "--~- Had David ever had any children? No. .--- I understand that he had been married and divorced several years ago. Is that correct? Yes. Did he have any ongoing contact with his former wife that you are aware of? No. Do you remember what her first name was? Wendy. wendy. [H,,,,":._o.t'_ten -. let's go back let's say the ~ast two' years, with what frequency would you see ~~~'~~.J Almost every day or every other day. ------ - And why was that? He would just com~ in and visit me or he would take me to the store or to the doctors. -- -...---.----. ..-- When he would take you to the store or the doctors, would he drive? He would drive, yes'. Now, you're aware he was involved in an accident where he fell at a construction site. Is that correct? FILIUS & McLUCAS J\EPORTlNG SERVICE, ["Ie Hnrr;sllllrx 717-236-0623 1'01'1,717-845-6418 PA 1-800-2.33-9327