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ALICE L. WALLACE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION . LAW
:1'1- ;J.LfOlf tu~ -r~
: NO. CIVIL 1994
VS.
KRAVITZ PROPERTIES, INC.,
Defendant
: IN TRESPASS
: JURY TRIAL DEMANDED
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
selVed, by entering a written appearance personally or by an attorney and filing in writing with the
court your defenses or objections to the claims set forth against you. You are warned that if you
fail to do so the case may proceed without you and a judgment may be entered against you by the
court without further notice for any money claimed in the complaint or for any other claim or
relief requested by the plaintiff. You may lose money or property or other rights important to
you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
Court Administrator
Fourth Floor
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
,.
ALICE L. WALLACE,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
: CIVIL ACTION - LAW
VS.
: NO. CIVIL 1994
KRAVITZ PROPERTIES, INC.,
Defendant
: IN TRESPASS
: JURY TRIAL DEMANDED
COMPLAINT
NOW comes Alice L. Wallace, plaintiff, by her attorneys, Irwin, Itwin & McKnight, and
files this complaint against Kravitz Properties, Inc., defendant, representing as follows:
I. Plaintiff is Alice L. Wallace, an adult individual residing at 940 Cavalry Street, Carlisle,
Cumberland County, Pennsylvania 17013.
2. Defendant is Kravitz Properties, Inc., a Pennsylvania corporation with offices at Suite
2634,1700 Market Street, Philadelphia, Pennsylvania 19103.
3. On October 18, 1992, plaintiff was on the premises known as the Camp Hill Shopping
Center, Camp Hill, Cumberland County. Pennsylvania at or near the southeastern entrance to the
shopping mall.
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..
4. Said shopping center was owned and maintained at that time by the defendant, Kravitz
Properties, Inc.
s. At said place and during the normal business hours of defendant's mall, plaintiff was
walking along the sidewalk adjacent to the Camp Hill Shopping Center on the western side of the
walk and the driveway and parking lot of the mall on the eastern side of the walk.
6. Said sidewalk was the usual and customary place for business guests of the defendant
to walk along and enter the shopping mall and the place designed intended the defendant for its
customers to walk into and along the building.
7. At said time and place. there existed on the walk a defective concrete sidewalk slab
that had separated from its adjoining segments and was raised up from the level of the adjoining
segments creating a one and one-half to two inch raised crack between it and its adjoining
segments.
8. The raised crack was not readily observable to the plaintiff who was walking along the
walkway intending to go into the shopping mall.
9. At said time and place. plaintiff's heel caught on the edge of the raised crack causing
her to loose her balance and fall face forward to the sidewalk and resulting in various physical
injuries and other damages as hereinafter set forth.
10. Subsequent to the incident above described. defendant attempted to repair the
defective sidewalk by filling in the raised crack.
i~;;;.
.....n. ~........~;,
II. The incident above described and the injuries suffered by the plaintiff were solely due
to the carelessness, recklessness and negligence of defendant. including but not limited to the
following:
A. Failing to properly maintain its sidewalk;
B. Permitting an unreasonably dangerous condition to exist upon its premises;
C. Failing to warn plaintiff and its other business guests of the dangerous
condition upon the premises;
D. Failing to exercise due care to its business guests; and
E. In otherwise failing to give due concern to the rights and safety of plaintiff
and its other business guests lawfully on its premises.
12. As the direct result of defendant's negligence and carelessness as aforesaid and the
incident that resulted therefrom, plaintiff suffered serious personal injuries including, but not
limited to a fractured right wrist and left fifth finger, various bruises and a soft tissue injury to her
neck and back.
13. As the direct result of defendant's negligence and carelessness as aforesaid and the
incident and personal injuries that resulted therefrom, plaintiff suffered serious pain and suffering,
loss of life's pleasures, temporary inability to pursue her employment and disruption of her normal
activities of housework and other ordinary matters.
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14. As the direct result of defendant's negligence and carelessness as aforesaid and the
incident and personal injuries that resulted therefrom, plaintiff incurred various expenses for the
care and treatment of and rehabilitation from her injuries as aforesaid.
15. As the direct result of defendant's negligence and carelessness as aforesaid and the
incident and personal injuries that resulted therefrom, plaintiff incurred wage losses during the
time she was unable to return to work.
WHEREFORE, plaintiff demands judgment against the defendant in an amount in excess
of Twenty-five Thousand and no/100 ($25,000.00) Dollars, plus costs of this action and delay
damages.
IRWIN, IRWIN & McKNIGHT
I
~_.AS r>'J
HAR D S. IRWIN, 1
Attorney for plaintiff
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, PA 17013
(717)249-2353
Supreme Court ID No. 29920
The foregoing complaint is based upon information which has been gathered by my
counsel in the preparation of this lawsuit. The language of the document is the language of my
counsel and not my own. I have read the answer and to the extent that it is based upon
information which I have given to my counsel. it is true and correct to the best of my knowledge.
information and belief. To the extent that the content of the answer is that of counsel, I have
relied upon counsel in making this verification. I understand that false statements made herein are
subject to the penalties of 18 Pa.C.S.A. Section 4094, relating to unsworn falsification to
authorities.
April ~7 . 1994
/' y / .
r..Lk...u j I( ct..tfk/-
ALICE L. WALLACE
,.
SIlERIFF'S RETURN
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
In the Court of Common Pleas of
Cumberland County, Pennsylvnaia
No. 94-2404 Civil Term
Civil Action Law Complaint in
Trespass Notice
Alice L. Wallace
VS
Kravitz Properties Inc.
R. THOMAS KLINE, Sheriff, who being duly sworn according to law,
says, that he made diligent search and inquiry for the within named
defendant, to wit:
Kravitz Properties Inc.
but was unable to locate
them
in his bailiwick. He therefore
deputized the sheriff of
Philadelphia
County, Pennsylvania,
to serve the within
Civil Action Law Complaint in Trespass
Notice
On
June 6, 1994
, this office was in receipt of
the attached return from Philadelphia
County, Pennsylvania.
Sheriff's Costs:
Docketing 14.00
Out of County 5.00
Surcharge 2.00
Phila Co. 59.00
90.00 -Pd. by Atty
Sworn and subscriu, ! to betore me
So answers:
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THOMAS KLINE, Sheriff
6-6-94
this
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COMMON PLEAS NO.
COUNTY COURT
VERSUS
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Alice L. Wallace
'is.
Kravitz
Properties
Inc.
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ALICE L. WALLACE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
VI.
: CIVIL ACI'ION - LAW
KRAVITZ PROPERTIES, INC.,
Defent/ant
: NO. 94-2404 CIVIL TERM
: IN TRESPASS
: JURY TRIAL DEMANDED
PRAECIPE
TO LAWRENCE E. WEI.KER, PROTHONOTARY::
Please reinstate the complaint in this matter and direct the sheriff to serve the complaint
upon the defendant at 555 East City Line Avenue, Suite 460. Bala Cynwyd, Pennsylvania 19004.
August 16, 1994
~~'11
HAROLD s. lRW~I1I ).
Attorney for plainti
36 South Pitt Street .
Carlisle, PA 17013
(717) 243-6090
Supreme Court 1.0. NO. 29920
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SHERIFF'S RETURN
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
In the Court of Common Pleas of
Cumberland County, Pennsylvnaia
No. 94-2404 Civil Term
Complaint in Civil Action Law
and Notice
Alice L. Wallace
VS
Kravitz Properties, Inc.
R. THOMAS KLINE, Sheriff, who being duly sworn according to law,
says, that he made diligent search and inquiry for the within named
defendant, to wit:
Kravitz Properties, Inc.
but was unable to locate
them
in his bailiwick. He therefore
deputized the sheriff of Philadelphia County, Pennsylvania,
to serve the within Complaint in Civil Action Law and Notice
On
September IS, 1994
, this office was in receipt of
the attached return from
Philadelphia
County, Pennsylvania.
Sheriff's Costs:
Docketing
Out of County
Surcharge
Philadelphia County
$
Sworn and subscribed
So answers:
14.00
5.00
2.00
59.00
80.00 pd. by
to before me
/",' '/
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/- y~~...-........-..... --: ',,..-'4-
R. THOMAS KLINE, Sheriff
atty
9-15-94
this
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,
19~~, A.D.
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Alice L. Wallace
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Kravitz Properties, Inc.
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s
ALICE L. WALLACE,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
VS.
: CIVIL A<;.nON - LAW '.
: fib. tl'f-J..4-0'1- Cu4i I~
: NO. CIVIL 1994
KRA VITZ PROPERTIES, INC.,
Defendant
: IN TRESPASS
: JURY TRIAL DEMANDED
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 an 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 mIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
Court Administrator
Fourth Floor
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACI10N - LAW
ALICE L. WALLACE,
VS.
: NO. CIVIL 1994
KRAVITZ PROPERTIES, INC.,
Defendant
: IN TRESPASS
: JURY TRIAL DEMANDED
COMPLAINT
NOW comes Alice L, Wallace, plaintiff, by her attorneys, Irwin, Irwin & McKnight, and
files this complaint against Kravitz Properties, Inc" defendant, representing as follows:
1. Plaintiff is Alice L, Wallace, an adult individual residing at 940 Cavalry Street, Carlisle,
Cumberland County, Pennsylvania 17013,
2, Defendant is Kravitz Properties, Inc" a Pennsylvania corporation with offices at Suite
2634,1700 Market Street, Philadelphia, Pennsylvania 19103,
3. On October 18, 1992, plaintiff was on the premises known as the Camp Hill Shopping
Center, Camp Hill, Cumberland County, Pennsylvania at or near the southeastern entrance to the
shopping mall.
4. Said shopping center was owned and maintained at that tilne by the defendant, Kravitz
Properties, Inc.
S. At said place and during the nonnal business hours of defendant's mall, plaintiff was
walking along the sidewalk adjacent to the Camp Hill Shopping Center on the western side of the
walk and the driveway and parking lot of the mall on the eastern side of the walk.
6. Said sidewalk was the usual and customary place for business guests of the defendant
to walk along and enter the shopping mall and the place designed intended the defendant for its
customers to walk into and along the building,
7, At said time and place, there existed on the walk a defective concrete sidewalk slab
that had separated from its adjoining segments and was raised up from the level of the adjoining
segments creating a one and one-half to two inch raised crack between it and its adjoining
segments.
8. The raised crack was not readily observable to the plaintiff who was walking along the
walkway intending to go into the shopping mall.
9. At said time and place, plaintifl's heel caught on the edge of the raised crack causing
her to loose her balance and faIl face forward to the sidewalk and resulting in various physical
injulies and other damages as hereinafter set forth.
10. Subsequent to the incident above described, defendant attempted to repair the
defective sidewalk by filling in the raised crack.
11. The incident above described and the injuries suffered by the plaintiff were solely due
to the carelessness, recklessness and negligence of defendant, including but not limited to the
following:
A. Failing to properly maintain its sidewalk;
B. Pennitting an unreasonably dangerous condition to exist upon its premises;
C. Failing to warn plaintiff and its other business guests of the dangerous
condition upon the premises;
D. Failing to exercise due care to its business guests; and
E. In otherwise failing to give due concern to the rights and safety of plaintiff
and its other business guests lawfully on its premises,
12. As the direct result of defendant's negligence and carelessness as aforesaid and the
incident that resulted therefrom, plaintiff suffered serious personal injuries including, but not
limited to a fractured right wrist and left fifth finger, various bruises and a soft tissue injury to her
neck and back.
13. As the direct result of defendant's negligence and carelessness as aforesaid and the
incident and personal injuries that resulted therefrom, plaintiff suffered serious pain and suffering,
loss of life's pleasures, temporary inability to pursue her employment and disruption of her DOnna1
activities of housework and other ordinary matters,
-''--
:
"
14. As the direct result of defendant's negligence and carelessness as aforesaid and the
incident and personal injuries that resulted therefrom, plaintiff incurred various expenses for the
care and treatment of and rehabilitation from her injuries as aforesaid.
15, As the direct result of defendant's negligence and carelessness as aforesaid and the
incident and personal injuries that resulted therefrom, plaintiff incurred wage losses during the
time she was unable to return to work.
WHEREFORE, plaintiff demands judgment against the defendant in an amount in excess
of Twenty-five Thousand and nol100 ($25,000.00) Dollars, plus costs of this action and delay
damages.
JRWlN, IRWIN & McKNIGHT
icl1JJni? p
HAROLD s. IRWIN, 111
Attorney for plaintiff
West Pomftet Professional Building
60 West Pomftet Street
Carlisle, PA 17013
(717)249-2353
Supreme Court ID No. 29920
"
The foregoing complaint is based upon infonnation which' has been gathered by my
counsel in the preparation of this lawsuit. The language of the document is the language of my
counsel and not my own, I have read the answer and to the extent that it is based upon
infonnation which I have given to my counsel, it is true and correct to the best of my knowledge,
infonnation and belief. To the extent that the content of the answer is that of counsel, I have
relied upon counsel in making this verification. I understand that false statements made herein are
subject to the penalties of 18 Pa,C,S.A. Section 4094, relating to unsworn falsification to
authorities,
April ~q . 1994
c2&t' /, ,,( If ~d!~";-,::-
ALICE L. WALLA E
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ALICE L WALLACE,
PII/intiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
YS.
: CIVIL ACTION - LAW
KRAVITZ PROPERTIES, INC.,
IJefemll/nt
: NO. 94-2404 CIVIL TERM
: IN TRESPASS
: JURY TRIAL DEMANDED
PRAECIPE
TO LAWRENCE E. WELKER, PROTHONOTARY::
Please reinstate the complaint in this matter and direct the sheriff to serve the complaint
upon the defendant at 555 East City Line Avenue, Suite 460, Bala Cynwyd, Pennsylvania 19004.
September 21,1994
HAROLD S. lR
Attorney for plaintiff
36 South Pitt Street
Carlisle, PA 17013
(717) 243-6090
Supreme Court I.D. NO. 29920
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SHERIFF'S RETURN
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
In the Court of Common Pleas of
Cumberland County, Pennsylvnaia
No. 94-2404 Civil Term
Alice L. Wallace
Reinstated Complaint and
Notice
VS
Kravitz Properties, Inc.
R. THOMAS KLINE, Sheriff, who being duly sworn according to law,
S3YS, that he made diligent search and inquiry for the within named
defendant, to wit:
Kravitz Properties, Inc.
but was unable to locatethem
in his bailiwick. He therefore
Montgomery
deputized the sheriff of
County, Pennsylvania,
to serve the within
Reinstated Complaint and Notice
On
October 7, 1994
, this office was in receipt of
the attached return from
Montgomery
County, Pennsylvania.
Sheriff's Costs:
Docketing
Out of County
Surcharge
Montgomery County
So answers:
14.00
5.00
2.00
28.00
49.00 pd. by
to befor~t~M 10-7-94
$
Sworn and subscribed
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R. THOMAS KLINE, Sheriff
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this
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Prothonotary
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SHERIFF'S RETURN
PROTHONOTARY #:
COST S
DEFENDANT
DOCUMENT SERVED
INDIVIDUAL SERVED
RELATIONSHIP TO DEFENDANT
Q- 5773
Kravitz Properties
Civil
Evelyn O'Rear
Person In Charge
DATE AND PREVAILING TIME
LOCATION
September 28. 1994 @ 13:00
555 East City Line Ave, Suite 460. Bala Cynwyd. PA
THE ABOVE DOCUMENT WAS SERVED ON THE DEFENDANT AS PER INFORMATION LISTED ABOVE IN
THE COUNTY OF MONTGOMERY, COMMONWEALTH OF PENNSYLVANIA.
AFFIRMED AND SUBSCRIBED BEFORE ME ON
THIS DAY,
SO ANSWERS,
~&'-~~
FRANK p, LALLEY "1
SHERIFF OF MONTGOMERY COUNTY
OY ~:.~~
Conway
September 30. 1994
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NOT RY PUBLIC
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so '0'''' 036.1 JUNE 86
.~.'."""."~'''''''''''-''''''.''.''.'',,,....,'.''
In The Court cr C.::rnmO:1 ?1:::5 01 C=.Jr.~:"-::.::ri=nd (;.::t.::-;.I'~/, ?snr:syl'/c:nio
-
Alice L. Wallace
Kravitz Properties,
'is.
Ine;.
~o.
94-2404 ~ivil Term
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:-iow, September 22. 1994
:9_ !. SEZ?~:;' 0:' C~G...:.:'.!..A..'fD COt.-:-f":? ?o\..., co
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Montoompry
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ALICE L. WALLACE,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
PlaintilT
: CIVIL ACTION - LAW
VS.
: NO. 94-2404 CIVIL 1994
KRAVITZ PROPERTIES, INC.,
: IN TRESPASS
Defendant
PRAECIPE TO SETTLE AND DISCONTINUE
To the Prothonotary:
Please mark the above action settled and discontinued.
November ~ (7, 1994
M)/U-Ti.'4?
HAROLD S. IRWIN, II
Attorney for plaintiff
36 South Pitt Street
Carlisle, PA 17013
(717) 243-6090
Supreme Court ID No. 29920
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