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Home My WebLink About94-07058 fi: a. '-- U': ". " .)...f' ,.- ~p - -,):j: -c: -~ ):~ fEr' Q: 01 ~ ..J ~' .:;~ ,. ,.... I ~'.. (. N '- -', _JI, C..:, ': '('1 u: ' lu , !l.l.. r. I.L. I "_ r- "', U '" ,~) ~ the front left of the Plaintiff's truck. Plaintiff was In the driver's seat wearing his seatbelt. Defendant has admitted liability. II. ISSUES AS TO LIABILITY AND DAMAGES Defendant has admitted liability and therefore, the only Issue at trial will concern the amount of damages to which the Plaintiff Is entitled. While the accident occurred on March 15, 1993, Plaintiff did not seek any medical treatment until two days later. On March 17, 1993, Plaintiff reported to the York Memorial Hospital, where he was treatfld and released. Five days later, he began treating with Michael Warner, D.C. He was complaining of headaches, neck pain, right shoulder pain, and low back pain radiating Into his left leg. Dr. Warner diagnosed the Plaintiff as suffering from a "whiplash type" Injury coupled with a lumbosacral sprain/strain and headaches. Since 1993, Plaintiff has continued to undergo chiropractic treatment on a periodic basis. In addition to Chiropractor Warner, the Plelntlff was evaluated by Robert Kaneda, 0.0.., an orthopadlc surgeon. This evaluation took place on June 19, 1996. Plaintiff had complaints of neck pain and right shoulder pain with numbness in the right Index finger. He also complained of seme left hip pain. Dr. Kaneda felt the Plaintiff had evidence of degenerative joint disease In the cervical spine as documented on an MRI performed on November 16, 1995. Dr. Kaneda did not feel the discogenlc chenges identified on the MRI were clinically significant. He felt the automobile accident aggravated the Plaintiff's underlying degenerative joint disease, but he did not .2. . recommond any surgical Intervantion. Dr. Kaneda merely recommended that the Plaintiff continue with chiropractic treatment on e pm basis. All of the Plaintiff's medical end chiropractic bills have been paid by his first perty benefits carrier, Erie Insurance Company and his private health Insurer, tha Building Trade Health end Welfare Fund. Accordingly, pursuant to 75 Pa. C.S.A. ~ 1722, Plaintiff Is precluded from recovering the medical/chiropractic expenses in this action. In addition, at the time of this eccldent, the Plaintiff was employed a8 a superintendent at H. B. Alexander, a general contractor. Plaintiff has not missed eny thlle from work since the automobile accident and there is no claim for any past lost of earnings. III. IDENTIFICATION OF WITNESSES Defendant does not Intend to call any witnesses. Defendant will rely upon the cross-examination of Plaintiff and Plaintiff's medical/damages wltnessas. IV. EXHIBITS None. V. ~ETTLEMENT NEGOTIATIO~ Plaintiff has submitted a demand of $35,000.00. Defendant has made an offer of $7,500.00. .3. ~-' '.' , r.:....., $j -""......... '- .j .~ 'v-, ~.\ V'\ ::::----- \.")- .....~ ') ..;t, -' r-- "-..:, f\~ l./"J '" ,':::J '" 'Zj -- I'- G '-" \0 "- . -\ '\ .-.~ .....- ._1 $ r- U\ "--' .:....:. ~ II " ---J -7fl.t'If..- ...z. ((ir;S- 1 JV ^' L 'I ~J u>'->~"", /!.;'--"~A. ,:)rkL p/ /.,L..7J.hfJ. tL ~ III 9 o - ll! 3; Iii ~ w :s ~ i :I:... I:: ~ii! ~S~~ en III w _ :; s: Ii w ii: I-' .... . , 0-, tw.. (onn... -..- A",--nul... 1l'tIl4f..uU1'ln..1 t.........n'_.n401 ""_..fJlll.....'"" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RAYMOND H. GETZ, I No. q~ lOSt OLfJ-~ Ld plaintiff I I VB. I I GLENN W. HELD, I Defendant I CIVIL ACTION - LAW PRAECIPE FOR ISSUANCE OF WRIT OF SUMMONS TO THE PROTHONOTARY I Issue Writ of Summons in the above-referenced matter to: GLENN li. HELD 24 GRANGE AVENUE MECHANICSBURG, PENNSYLVANIA 17055 x -- Writ of Summons shall be issued and forwarded to Attorney/Sheriff GRIEST, HIMES, GETTLE, HERROLD , SWIFT By: ~t: - Gre ry J:; Supreme urt I.D. #65600 129 East Market street York, Pennsylvania 17401 (717) 846-8856 Attorney for Plaintiff Date: /'}.(1()",b;, f!. I)' , 1994 ***** SUMMONS IN CIVIL ACTION TO: GLENN W. HELD YOU ARE HEREBY NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. Pro Date:~~~-- /0,1994 By: DATE PRDCESSEO OATE RECEIVED SHERIFF'S DEPARTMENT ADAMS COUNTY, PENNSYLVANIA COURTHOUSE. GETTYSBURG, PA 17325 -------..-.--- INSTRUCTIONS: Huo "INHTnUCTlONS ron SERVICE OF PROCESS OV TIll: mIEIHIT" 1l11lho ftlYtlflil1 nllho lil!lt (Nu 51 copy ollhlllo,m, Plo.IO tYllll III pfinllfllJ'hl'l. IIHIUlln{) flhulatllUlv 01 all Copl.. On 11111 tlulilch /IllY cnpltlll ACSO ENV,f SHERIFF SERVICE PROCESS RECEIPT', and AFFIDAVIT OF RETURN 1, PLAINTlFF/SI n~nd 11. o.ts 3. DEFENDANT/SI OlelU1 \/. neld 6 NAME OF INDIVIDUAl. -~.~. .-----..--..----.. 2 counT NUMBER 9~705ll_.c:i,,!1 Te~ .__ 4 TYPE or WAIT on COMPLAINT \/rit ot ~na ._--~------ ~-._' _.._.,_..._~---------_...- .---."---'---"--' ----. ..- .-,--_...----- +,'."------'.'-' COMPANY, COf\POFlATlOtJ. ErG, 10 S[llVICL 011 D[!JCI\IPTlON Of PROPEIlTV TO ur. l[Vlr:O, ATTACHED OR SOLO IERVE . .. -- --" 6. ADORESS (S11801 Of RFD, Apartmonl No, Clly. 0010, TWI!. fillllo IIntl ZIP COOL) OhlU1 W. lIeld AT __54? ~nk VieW _Jloil.r!_~o'i":(!lp~~He;-P^' .-------. 7. INDICATE UNUSUAL SERVICE: : PERSONAL PERSON IN_ Ct.!!'~.Qf:.....~_!~~r~~TI~f-.. .__g~~.l~~~--~-~~-~J~!ER~'p~AIl. 1_1_~9~~~P~1_~.!-':!~f~ Now, ___ 19 _n , I. SHERIFF OF ADAMS COUNTY. PA" do heroby doputlze the Snerilf of __._________ County to execute this Writ and make return thoro! according to law. This deputation being made at the request and risk of the plaintllf. _....____n_ -- .------..--- -- .--- ---- .."- ------ ---------- :>t~IJ~!.. OF A[)AIJ5 COUNTY ._---------_._-_.~- 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION HIAT WII.l ASSIST IN EXPEDITING SERVICE NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N B WAIVeJl or WATCHMAN--Any tlopuly ShtHllllovying upon or anachlng any property undor wllhin writ may loavo 18mo wilhoul B walchman. In cuslody ot~omova' II round In posael1lll0n, aller notllylng pallion ol101'Y or allachmonl. wlthoulliablhly on Iho purl 01 such dopuly or Ihe ahorilllo. any plalnUIf herein lor any loss, desllucllon or romoval 01 any such plOpOlly bolOlo roholU!'s liato Il1elool --_.~---~-~-_._--~- --. _ -------.-----..- ..--.-..------.-- g. SIGNATURE 01 ATTORNEY or olhol ORIOINATOR IOquostlno servico on bohall 01: to. TELEPHONE NUMBER X j PLAINTIFF Ore/lOI'1 B. Gettle, Esq. f1 DEFENDANT (717) B46-SBS6 BELOW FOB_US!: OEltI:lJ;.BIFF Or"I!,_Y_=-ltO.1lQ-L.WB!TE E 12. I acknowledge rocelpl 01 the writ SIGNATURE 01 AUlhorizcd ACSD Depuly or Clerk and Tltlo 13. Dato Recelvod Of complalnl as Indicated abovo. 11. DATE I.lliE 14. Ell.pirahon I HOllling dale 15. I hereby CERTIFY and RETURN lhall havo personally sOfvod,' hllVU surved porson In chOlgo, i 1 have logal OVldonco 01 sOllJico as shown in "Remarks" (on loverso) rl have poslod lhe abovo descrlbod propelly wllh lho wrll or complnllll dor.cribod on Iho indIVidual. company, cOlporation, ole.. allho Jtddross shown abolJo or on Iho IndivIdual, company. corporallon, ale, altho addloss insurted below by hilndlngJol POlillng II TRUE and ATTESTED COPY Ihorol ,. ~ I hOloby cor1ily and loluln a NOT FOUND becauso lilIn unab~?1~~_dlvidual, compMy. cotpofullon. ole., namod abovo. ~Seo remarks below) 17. Name and hllo 01 indllJiduol sOlvod 18 A Iltlllon 01 lUllanle age and dllcfllMn , {tilt" rlllld,ng In ItllI derllndanl'l ulual . . Jleellol.bOde IJ 19. Address of whole sOrY'ed (completo only it dillolonlthan shown abovo) (Slrool 01 RFD. Apnrlmonl No, Cily, BolO. Twp., 2,.0 Oalo 01 80"'IC8[1 Tlmo Slato and ZIP CODE) I1I'J4ARKSI Defendant hall IlIOved a: lett. no tonlBrdinll' lIddrellB 22. AnEMPTS D.p,lnt. Dale Mile. Road Ordor II O.p.lnl. 23. Advance Cosls 25. AFFIRMED and aubllcribod to belolo mo thjs_+-~'-H/A-----'-'--------- ------------/: . . ' . ~ Isr..t1fi I P.m1 Shf!rl'~l tfllllne Punl rK l~p'l de 01 19 ,XXXXXX ~ V __nO . --,,--- - _____nn -.--!lttrliard-V.-HUler- ! Signaluro ~I ShOllll Oalo .....14195 Oalo .---_.----_._--~+----- --~-._.--ji,Oit~~;;;;-;-flr)lfj~I;~ji;it~;;t;.r~ -1',;tJi;~;' SItERlFF OF ADAMS COUNTY MY COMMISSION EX!?~~._~.~ .________"__ I ACKNOWLEDGE nECEIPr or HtE SHERIFF'S RETURN SIGNATURE OF AUTHORIZCD ISSUltm AUTHOfllTV ANn TITLE -_.-~-_._---_.,-_._. - L-------------- ~U.._:.il~~_~~~~I~O~ OATE AECEIVEO OATE PROCESSED SHERIFF'S DEPARTMENT ADAMS COUNTY, PENNsvLVANIA COURTHOUSE, GETTYSBURG, PA 17325 SHERIFF SERVICE PROCESS RECEIPT;'8nd AFFIDAVIT OF RETURN INSTRUCTIONS: So. "INSrnUCTlONS FOR SERVICE OF PROCESS eY Tilt mIEFUH" on tho ,oV8rsO otlhs laBI (No 5) copy 01 lhi, fotm. Pl.... 1~1)(1 III pllnlloUI!lly, 11lllUlino roadability ot all copies OUllol chllllch any CUl'lltB ACSD ENV.I I. PLAINTIFF/51 2 COUnT NUMDEA Ib\yII(md II. Gets____ __ _9_4.-1.Q~__c:!".!:J._'!'!~_________ 3_ DEFENDANT/SI " TYPE OF WfUT on COMPLAINT. Glenn W. Held.. .____~l'_l~_~!_~~~nll_.._______ 5 NAME OF INOIVIDUAL;COMPA-NV:CORPOIlAIION. ETC. TO minvlci on DESCRIPTION OF PIlOPEArv TO UE LEVIED. ATTACHED 011 SOLO SERYE . Glenn W. Helll AT 6 ADDRESS (Stlllel or AFO, Allarhnolll No, City, UIlfO. Twll, filalt) llr\tlllP CODE) . " . !14:> _!,!!,~Yl.., flond', Yorl. f1Pl"i'nli,!_,_ p~_____ ___~___ 7. INDICATE U.~YQUA~J!~~Y.IC[: II ')r:nSm"AlL!J?.f:.U~9~..!!!.E!!.~nO~~_I~~~!!!IZEJ.J..f~m M~_t!:.11 FH:GtSTEnEO MAIL:, POSTED:' OTHER Now, _______ __ 19 _ _... _._ . I, SHERIFF OF ADAMS COUNTY, PA., do hereby deputize Ihe Sheriff of _~_____.___.__ __ __~__~_ County 10 execule this Wrll end make relurn therof according 10 law. This deputallon being made ellhe request and risk ollhe plaintiff. !iHfHIFF OF AOAM5 COUNTY 8, SPECIAL INSTRUCTIONS OR OrtlER INFORMATION THAT WIt.L ASSIST IN EXPEDITING SEfWICE NOTE ONLY APPLICABLE ON wrm OF EXECUTION: N,D. WAIVER OF WA reHMAN-AnV dtlpuly shotllllo....Ylng upon or ollilclung any propolly undor Wlll11n writ may 10.0.'18 lame wilhoul a walrhman. in cualady ol4~~meV8r Ie launcH" possOlIlion. allor- nollf)1ng po",on 0110'1)' or allachmonl, wllhoul Iiabllily ontll., pari 01 6uch dopuly or Iho. aherllllo any plalnllff heroin lor any 10SI, deslruclion or removal of Bny 8ueh proporlV bolOlD IhOlill'8 ..,10 Iholool g, SIGNATURE 01 ATTORNEY or 011101 ORIGINATOR roquesllng 50lvice on behalf 01: Zl PLAINTIFF I I DEFENDANT 10 TELEPHONE NUMOER 11. DATE 0re1lD~ u. Gettle, EIIq. SPACE BEL (717) Bli6-0856 12. I acknowledge receipt 01 the writ or complaInt .. Indicated abova, E OF SHERIFF 9Nl.Y-=-_D.2-NPT_WBtTE BELOW TI:I SIGNATURE 01 A~:~rlle~_~_~_~~~~~_~:~r _~I~'.:,~~~I:~O___.___L 13. 0.110 Received LINE 14. Ellpiralion' tlearlng dale Hi. I heleby CERTIFY and RETURN Ihatl I I havo pe,sonally 8U1\1od. I " hMO SOl\lod pOIson in eha/go, I ! ha\lo lugal evidunco 01 sOl\lico as shown In "Romarka" (on roverlo) n have polled Ihe abo\lo doscrlbed propolly With lhu WIll or complaint dusCllbod on Iho individual, company. corporal ion, otc.. I\ltl1o addloss ahown abovo or on tho Individual. company. corporation, otc_. ollho address lnsorlod bolow bV handing/or PosliIlg a TRUE and ATTESTED COPY Iholol. 18. 1 I hereby cOWIy and rolum a NOT FOUND becauso I om unabla 10 loculo Iho indlviduul, comp<1nY, corporll~~~_~C_, n~~_d nbo\le_ (Soo romarkl bolow) 17, ame and title ollndivldualsorvod lB A Pillion olIUII,b!O AU. .nd d,tclot,on t"lInrOlldlr1\JUIlhllderondllnl'lulull ".' 'pl.uof~l:. Reod Ordor LI ., 18. Addreaa 01 where aONed (complete only II dillerenllhon shown abo\lollSlroot or RFD. Aparlmonl No.. Cily. Boro, Twp, 61110 Ind ZIP CODE) 20, Dole 01 Servlco 21. Tlmo RIlMARKHI Detandunt hall moved a: 1ett no torwarding nddreul 22. ATTEMPTS Dep.lnt. ""J."l.':'T""'l."r"'T.. I"'" J.''T'" "'" ~., 25. fTe 27, T."I Co,,, J 2~~~EFUNO L ----- 2S_,4~Pd.-4N!}; Go Ck..---J,',l6o.29 so ANSWER. 23. Adyance Costa AFFIRMED end lublCrlb&d 10 beloro me Ihl, --H/^ . .. ... '":"" ,~ I ,- ny (Shlnll' ~!)ljrJII.il Pflfll'oIl1~) Oalo Bernlll'd--V.G-lil-leso:----'''';-- ~195 SlonalulQ 01 Shellll ~.. Oalo :':' - m-~;t~n-;;f d~ ~~AM~ ~~~~;:--~:-- --- . .. ....,.'_n__ -'-----1' L.__________ .. ~ . -, ~.'SU. Dllto nocolvlld -, -.___,_ __. _____._ __,....._ __"_,_'u,_'__._,____ day 01 10 PIOlhOo<,t.,.,lOejlulylNo1.ry i.;rt;I~--------- MY COMMISSION EXPIRES ------------,--------- . I ACKNOWLEDGe ReCEIPT OF HiE SHERIFF'S RETURN SIGNATURe OF AUTHORIZED ISSUING AUTIlORlTY AND TITlE \~ Lrl en M =c &:.l._ ." " .:J' "J <'-.l ", . . :'.l..:: tL ~ III 9 _ ~ ;r Iii ~ a: :s ~ :! ~ ~ I i ~i~1 en .. III Ii w ~ i! :; s: Ii w ii: I-' 'J 1....'.......I..m.. ~..I.'" ""'.""\11... l:ttu'W...,""", "......._n'....."..ll l\",.....11111""'..\& IN THB COURT OJ' COMMON PLEAS OF CUMBERLAND COUNTY, PBNN8YLVAIlIA RAYMOND H. OETZ, I NO. '''-8U-7058 civil Te1'll Plaintiff I I va. I civil Aotion - La. I GLBNN W. HELD, I Defendant I Jury Trial Demanded TOI Glenn W. Held Williams Grove AmuBement Park Williams Grove Road MeohanioBburg, PennBylvania 17055 NOTICB 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 notice and complaint are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse 4th Floor 1 Courthouse squaro carlisle, Pennsylvania 17013 Telephone: (717) 240-6200 , HERROLD & SWIFT By: ~ . Gettle, Esqu re Atto ne for Plaintiff ID #65600 1 ".....Is-,Ii.m.. U__.. I.... "m_..n..I... l~t.ulM...u"ro.., "......._n_....'I.ll TluN_IfllI,..,,"" IN THE COURT 01' COMMON PLEAS 01' CUMBERLAND COUNTY, PDOlSYLVANIA RAYMOND H. GETZ, I NO. !I4-8U-705. civil Tera plaintiff I I VB. I civil Aotion - La.. I GLENN W. HELD, I Defendant I Jury Trial Deaanded QQHl'LAINT AND NOW, this ;'-<111 ;) day of , 1995, comes /))////-/ the plaintiff, Raymond H. Getz, by and through his attorneys, Griest, Himes, Gettle, Herrold & swift, by Gregory E. Gettle, Esquire, who bring thjs complaint against the above-named Defendant, upon a cause of action whereof the fOllowing is a statement: 1. Plaintiff, Raymond H. Getz, is an adult individual residing at 25 Dorseys Lane, Dillsburg, York county, Pennsylvania 17019. 2. Defendant, Glenn W. Held, is an adult individual originally residing at 24 Grange Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055, thereafter residing at 542 peakview Road, York springs, Adams County, Pennsylvania, and finally residing at his place of employment at Williams Grove Amusement Park, Williams Grove Road, Mechanicsburg, Cumberland county, Pennsylvania 17055. 3 (;-..........1;,'".. 11__ a....., Am..."..l... 11'ItAnlof"'"'''''' '"..,......."1.....11"11 nt.......IIPI.......\f\ IK TBB COURT or COHHON PLEAS or CUMBERLAND COUNTY, PEHN8YLVAHIA J\A YXOND H. OETZ, I plaintiff I I va. I I OLBNN W. HBLD, I Defendant I g4-11-7058 civil Tera CIVIL ACTION - LAW PETITION FOR ALTERNATIVE 8ERVlQA BY PUBLICATION 1. The Plaintiff, Raymond H. Getz, resides at 25 Dorseys Lane, Dillsburg, York County, Pennsylvania 17019. 2. The Defendant is Glenn W. Held who resided at the time of thiB accident as set forth below at 24 Grange Avenue, Mechanicsburg, Cumberland county, Pennsylvania 17055. It is believed that hiB last known address is 542 peakview Road, York springs, AdamB County, Pennsylvania. 3. On March 15, 1993, at approximately 6:45 p.m., Plaintiff was traveling north on Williams Grove Road (SR 2011) in cis 1993 Ford Truck. Defendant, operating the 1978 Chevy Nova in a southerly direction on Williams Grove Road (SR 2011), operated the Chevy Nova at an unsafe speed and under the influence of alcohol and as a result thereof, the Defendant lost control of the Chevy Nova, crossed into the northbound lane of travel lawfully occupied by the Plaintiff and smashed into the Plaintiff's vehicle. 4. Service of process was attempted on Defendant at 24 Grange Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055 by the Sheriff of Cumberland county, Pennsylvania. The Sheriff'B Return indicating that the Defendant was not found is marked Exhibit "A" and attached hereto and made part hereof by reference. In addition, the Sheriff indicated that the Defendant may be residing in Adams county. 5. Thereafter, the Adams county Sheriff was deputized and the service of process was attempted on Defendant at 542 Peak View Road, York Springs, Adams county, Pennsylvania by the Sheriff of Adams County, Pennsylvania. The Sheriff's Return indicating that the Defendant was not found is marked Exhibit liB" and attached ~ i )10 ~ g 1lI (' (" (" r: r: I(j () 1(.)0 (j o ~ 0 () .- . ... , "'1, '. . ,r. .0 ,. .............41..~ ,'.. \-:,~.. . ~r,}. ~""" .-, . . ,........... --_. _"__.__~__'-...._ - ___0._________ _._. DATE RECEIVEO -- -..---:-:-:.-- DATE PROCESSED SHERIFF'S DEPARTMENT ADAMS COUNTY, PENNSYLVANIA COURTHOUSE, GETTYSBURG, PA 17325 INSTRUCTIONS: s.o "INSTRUCTIONS FOR SERVICE OF PROCESS SY THE SHERIFF" on ~h. ,......... 0' thl 1.1' (No. D) copy ollhlt lorm. Pl.u. type Of print legibly, insuring ,tadabUlty 0' III COpl... Do nol detl'" any c:optI.. ACID ENY,' 1. PLAINTlFF/BI 2. COURT NUMSER nd H. Getz 4- 058 CiVil TenD 3. OEFENIlANT/BI .. TYPE OF WRIT OR COMPLAINT: Glenn W. He'ii1 Wr1 t ot SuIIIIIone 5. NAME OF INDIVIOUAL. COMPANY. CORPORATION. E~C.. TO SERVICE OR OESCRIPTlON OF PROPERTY TO SE LEVIEO, ATTACHEO OR SOLO, SHERIFF SERVICE PROCESS RECEIPT, end AFFIDAVIT OF RETURN SERVE . AT Glenn W. Held 5. ADORESS (Sir"' '" RFD. Apanmen. No,. City. Boro. Twp.. SII" and ZlP CODE) >fl' 542 Peak View Road, York Spr1ngs, PA 7. INOlCAT!! UNUSUAL SERVICE: D PERSONAL D PERSON IN CHARGE D DEPUTIze D CERT. MAIL D REGISTERED MAIL D POSTED D OTHER Now, 19 , I, SHERIFF OF ADAMS COUNTY, PA., do hsreby deputize the Sheriff 01 County to execute lhls Writ snd mske return therol according to law. This deputation being made at the request and risk 01 the plaintiff. . ,,' ':' SHEAIFF OF ADAMS COUHTV 5. SPECIAL INsmucnoNs OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE. NOT!! ONLY APPUCABLE ON WRIT OF EXECUTION: N.S. WAIVER OF WATCHMAN-Any d.puty aherln lovylng upon 0< ....hlng any properly under wnhln writ may la..o 11m. Without I walchman, In CU'lody 01 whomever it 'ound In poue..kln, Iltor notifying p'I(Ion of levy 01 Inlehmenl, without llability on .&h. pll1 0' IUch d.puly or the &h.n" to any plaintiff herein for any lou, dutrudion 01 removaJ 0' any luch property btlor. ahertlfl ..Ie lh.reof. " Il. SIGNATUR! 01 AnORN!Y 0< OIh. ORIGINATOR roq_1nll IOI\'k:o on boha" of: 10. T!!LfPHONE NUMBER 11. OAT!! . XI PLAINTIFF . Gregory B: Ge~~, Esq. D DEF~NDANT (717) BI!6-8856 14. ExplraUon' H'arlng dill .,' ...... .....,... " . '. 15. II1lJ<Oby Cl!RTIFY ond Il!TIIRN iha. I D hove penonoIly MMd. D ,",ve 1OfVOd' pO;..", In d1UllO. D' hlive'logaI OvIdOnc:o 01_ 10 ''''';'' In "Ramatkl" (on roveIM) o havw poIIld lhe e..bcrw dMQ'ibed propIftt wtth !h. wrtt 01 complaint dtlCl1bld on the 5ndMduaJ, oompany, cafporlUon,' elC., ai' lhIlddi... Ihown above or on th. InclIvIduol. """'llO"Y. _allon. OlD.. &llho _Inoottad bolow by handlng/o< Foaling a mUE and ATTEST!II'COPY thoro!. . . . . . 'e,.ID I hereby Willy and relum. HOT FOUND blcauae I am unable 10 local. the IndMdual, company, .oorporlllon, ltC" named above. (S.. r.nwka bllow) '7. HarM and Ude oIlndMduaI MrWd 'I. A per'Ml\ af........ 8QtI1ftd dlectMlon theft ~ WI the 6ItendMt'.....,., P*lI III mode. C 20. DIl. of SIMce 21. 11m. Road Order o ,a, Addrlll of whit. aervld (camplell only II diff....nllhan Ihown above) (Slr"1 or RFD, ~ment No., City, Bora. Twp., Slalo and ZIP CODE) . REMARKS I Detendant hu IIlOved a: let't no torwarding address 22. ATTEMPTS Dlp,lnL olt. Mil" D.p,!nt. Dap.lnL 25. BO ANSWI!R. . "FFlRMED Ind aublCObed 10 before m. lhll NA IIY 0' " Pnll:~~IIyP'utIIG BHEllIFF O~ ADAIIS COUNTY ~Y COMMISSION EXPIRES I,ACKNOWLEOOE RECEIPT OF THE SHEllIFF'S R!T1JRN BIGNAT1JRE i (') .. . . Ms. Danlelle Brown February 7, 1995 Page Two RE: Subject: Glenn W. Held A manager from Williams Grove Amusement Park advised this investigator that Glenn Held is no longer employed with their business and does not know where the subject currently resides. An interview was conducted with Debra Meyers who advised the subject is currently employed at Williams Grove Amusement Park, and is receiving compensation for his services under the table. Ms. Meyers also advised Mr. Held had previously resided at a residence within the Amusement Park; however, she does not know where Mr. Held currently resides. DETAILS OF INVESTIGATION A computer search was generated by Social Security Number 167-54-7122 which listed Glenn W. Held as the subscriber and provided the following addresses: 542 Peakview Road, York Springs, Pennsylvania; 24 Grange Avenue, Mechanlcsburg, Pennsylvania; 3506 Briarwood, Apartment #1, Dumfries, Virginia; and 1762 Skyline Drive, Pittsburgh, Pennsylvania. A computer search was conducted by name and address for Glenn Held at 542 Peakview Road, York Springs, Pennsylvania; however, no information regarding the subject was obtained. A computer search was conducted by name and address for Glenn Held at 24 Grange Avenue, Mechanicsburg, Pennsylvania; however, no Information regarding the subject was obtained. The names, addresses, 'and available telephone numbers of three residents on Grange Avenue were provided. A computer search was conducted by name and address for Glenn Held at 3506 Briarwood Street, Dumfries, Virginia; however, tha subject's name did not appear on the computer response. The names, addresses, and available telephone numbers of six residents at 3506 Briarwood Street were provided. A subsequent computer search was conducted by name and address for Glenn Held at 17 Capitol Hill Road, Dillsburg, Pennsylvania, which is the reported address of Mr. Held's girlfriend, Debra Meyers. The computer response listed Nancy L. Smith as the head of household at 17 Capitol Hili Road, Dillsburg, Pennsylvania. The names, addresses, and available telephone numbers of five neighboring residents were also provided. .. " Ms. Danlelle Brown February 7, 1995 Page Three RE: Subiect: Glenn W. Held On January 26, 1995, I contacted Directory Assistance for the (717) Area Code and an operator advised there is no listing for Glenn Held in tho York Springs or Mechanicsburg area. She further advised there is nq listing for Debra Meyers in the Dillsburg grea. I contacted Directory Assistance for the (703) Area Code where an operator advised there are no listings for Glenn Held or Debra Meyers In Dumfrles, Virginia. Attempts were made to contact neighboring residents in the apartment building at 3506 BrialWood Drive, Dumfrles, Virginia, using the telephone numbers provided In our computer search; however, three of the telephone numbers were dis~onnected, and there were no answers at the remaining three addresses. I traveled to Williams Grove Amusement Park, Speedway Drive, Mechanicsburg, Pennsylvania, In an effort to verify the subject's current employment status. The Amusement Park and Speedway were closed for the season and due to locked gates at the entrance, I was unable to enter the Amusement Park. I contacted Directory Assistance and an operator advised there is no listing for Williams Grove Amusement Park; however, there is a listing for the Williams Grove Speedway of (717) 697-5000. I placed a telephone call to Williams Grove Speedway at the above telephone number and no answer was received. I traveled to the reported residence of Debra Meyers on Capitol Hili Road. The residence is a single story, ranch-style residence situated in a low to moderate income area. A private driveway, approximately twenty feet long, extends from the road to a garage attached to the residence. A sign displaying Smith's Dog Grooming was at the end of the driveway. While in the area, a neighborhood Inquiry was conducted. At the Myers residence, 14 Franklin Road, I Interviewed Ms. Myers. She stated Jeff Diller and Debra Meyers resided at 17 Capitol Hill Road; however, they moved from the residence approximately two years ago. She advised Mr. Diller and Ms. Meyers had relations and resided there with Ms. Meyers' two teenage daughters. She stated she hed heard from neighboring residents Mr. Diller and Ms. Meyers are currently residing in Franklintown, Pennsylvania. She advised '~l , Ms. Danielle Brown February 7, 1995 Page Four RE: Subiect: Glenn W. Held Mr. Diller was a truck driver and when he traveled for days at a time, an unidentified white male with a thin build and dark hair would stay at the residence. Ms. Myers further stated Mr. Diller's parents provided the down payment for the mortgage on the residence at Capitol Hill Road; however, Mr. Diller and Ms. Meyers could not afford the mortgage payments. As a result, they were forced to move into a rental property in Franklinlown. She did advise Mr. Diller's parents currently reside in Georgia. She concluded by stating Debra spells her last name M-E-Y-E-R-S. I searched the telephone book for the Dillsburg and Franklintown area; howaver, thare were no listings for Debra Meyers or Jeff Diller. At the Lawver residence, 23 Capitol Hill Road, I interviewed an unidentified white male, approximately ten years old. He stated Debra Meyers and Jeff Diller resided at17 Capitol Hill Road appioximately two to three years ago; however, they moved to Franklintown. He stated he does not know Glenn Held. As I walked from the area, Ms. Lawver exited 23 Capitol Hill Road and questioned my presence ill the area. She advised Deb Meyers and Jeff Diller had resided at17 Capitol Hill Road; however, they moved from that residence to an unidentified residence In Frankiintown. She stated she occasionally observed an unidentified male filling the claimant's description at the residence. She further stated she does not know any residents on Capitol HIli Road named Glenn Held. Attempts were made to contact the residents at 14, 17, and 25 Capitol Hill Road; however, no answers were received. I traveled to the Adams County Courthouse on Baltimore Street In Gettysburg, Pennsyivania, and researched records at the Clerk of Courts, Voters' Registration, Recorder of Deeds, and Adult Probation Offices; however, no information regarding Mr. Held was obtained. On January 30, '1995, I contacted Williams Grove Amusement Park at telephone number (717) 697-8266, and spoke to Ms. Sally Loh who Identified herself as one of the managers of the Park. She advised Mr. Held had worked at the Amusement Park; however, he was laid off approximately one year ago. She stated the subject had resided at a residence within the Park while employed . . ~ Ms. Danielle Brown February 7, 1995 Page Five RE: Subiect: Glenn W. Held there. She stated she has not seen the subject since he was laid off, and she does not know where he currently resides. She advised she would contact this investigator if she could locate a forwarding addressjor Mr. Held in her records. On January 31, 1995, I contacted a confidential source who advised Glenn Held no longer resides at 542 Peakview Road, York Springs, Pennsylvania. He advised Harold Davis of Bell Real Estate Company currently owns the property. He then provided Mr. Davis' telephone number as (717) 528-4144. I placed a telephone call to Bell Real Estate at (717) 528-4144. I spoke to Wayne Ogburn who identified himself as Mr. Davis' brother-in-law and a broker of the aforementioned company. He advised Mr. Davis was not available to speak with this investigator at t/:lis time, due to the fact he does not start his work shift until 6:00 p.m. Mr. Ogburn advised Glenn Held had resided at 542 peakview Road with an unidentified white male. He further stated Mr. Held moved out of the residence in the middle of the night approximately one week before the end of December, 1994. He advised he does not know Mr. Held's current whereabouts, and stated Mr. Davis had sold the property on Peakview Road a few weeks ago to Stanley Bobbs who Is currently residing at the residence. He provided this investigator with Mr. Davis' home telephone number of (717) 432-8784. I placed a telephone call to Harold Davis' residence at (717) 432-8784; however, the call was Intercepted by an answering machine. I traveled to the York Springs Branch of the United States Post Office where a postal clerk advised Mr. Held moved from the residence at 542 Peakview Road and left no forwarding address. She provided this Investigator with directions to Peakview Road. I proceeded to the area of the claimant's former residence on Peakview Road which is a aluminum-sided mobile home situated in a rural, low income area. A private driveway, approximately sixty yards long, extends from the road to the residence. A green Dodge sedan and a pickup truck with a cap were parked in the driveway. While In the area of the residence, a neighborhood inquiry was conducted. At the Fickel residence, 544 Peakview Road, I interviewed Ms. Darlene Fickel. She advised two while males in their thirties had lived at 542 Peakview Road; . . . . Ms. Danielle Brown February 7, 1995 Page Six RE: Subiect: Glenn W. Held however, they moved from the residenc.e approximately one month ago. She stated one of the unidentified males had brown hair and a thin build. She advised Stanley Bobbs and his wife currently reside at the aforementioned residence. She further stated 542 Peakview Road is a residence which is usually rented by transient individuals. She concluded by stating Mr. Held's former residence was burglarized approximately two weeks ago prior to the Bobbs moving into the residence. At 492 Peakview Road, I interviewed an unidentified white female in her fifties. She advised she does not know Glenn Held or any of the individuals who currently reside at 542 Peakview Road. She advised this investigator the Pennsylvania State Police had contacted her approximately two years ago and questioned her about the residents at 542 Peakview Road; however, she told the police she keeps to herself, and as a result, she does not know any of her neighbors. At the Beers residence, 56B Peakvlew Road, I interviewed Mr. and Ms. Beers. Mr. Beers advised Mr. Held moved out of the residence abruptly, approximately two months ago. He stated he had come home during an afternoon In November or December and observed a U-Haultruck parked in the subject's driveway. He advised Mr. Held and an unidentified white male had resided at 542 Peakview Road for approximately six months. Ms. Beers stated Mr. Held and his roommate frequently had parties at the residence which involved loud music and, on one occasion, the police had responded to the residence and advised Mr. Held to turn the music down. She lItated Mr. Held and his roommate were strange individuals, and as a result she rareiy spoke to them. Mr. Beers advised he does not know where Mr. Held currently resides. He further stated the residence at 542 Peakview Road was burglarized approximately two weeks ago, and some of the neighbors believed it was Mr. Held who had broken into the residence in an effort to retrieve some of his personal items which he had left behind. He described Mr. Held as a white male in his thirties with long, light brown hair and a thin build. He also advised the subject frequently wears a baseball cap, and drives a two-tone blue Ford F-150 pickup truck. Attempts were made to contact the residents at 490, 502, 520, and 545 Peakview Road; however, no answers were received. .' ~ . . . . . . Ms. Danlelle Brown February 7,1995 Page Seven RE: Sublect: Glenn W. Held On February 1, 1995, I placed a call to the Harold Davis r~sldence at telephone number (717) 432.8784; however, the call was again intercepted by an answering machine. I traveled to the Dillsburg Branch of the United States Post Office where a postal clerk advised she could not provide this investigator with a forwarding address for Ms. Meyers from the Capitol Hill Road residence. I contacted a reliable confidential source who advised the last known address for Debra Meyers is 2 Baltimore Street, Franklintown, Pennsylvania, with a telephone number of (717) 432-9047. I traveled to the residence at 2 Baltimore Street, Franklintown, Pennsylvania, which is an apartment situated on the second floor of the building housing the Franklintown Post Office. I attempted to contact Ms. Meyers; however, no answer was received. I knocked on the door of the apartment situated directly across the hallway from Ms. Meyers' residence. I spoke to an unidentified white female In her twenUes who advised Debra Meyers resides In the apartment with her two daughters and Jeff Diller. She advised Ms. Meyers frequently travels to and from the residence during the day; however, she does not know if Ms. Meyers is currently employed. I entered the Franklintown Post Office and spoke to the postal clerk. She advised Ms. Meyers resides In the apartment on the second floor directly above the Post Office. She stated Ms. Meyers is usually home during the mornings and occasionally during the afternoon. She further stated she does not know if Ms. Meyers is currently employed. During the evening hours, I contacted the Meyers residence at telephone number (717) 432-9047. Ms. Meyers advised she has been trying to contact Mr. Held for the last several weeks because he owes her money. She stated she had contacted Williams Grove Park two weeks ago, and Sally Loh had advised her Glenn Held is still employed at the Amusement Park; however, he was not available to speak on the phone at that Ume. She stated Ms. Loh would not provide her with Mr. Held's current place of residence. She stated Ms. Loh and the owners of Williams Grove Park are very dishonest individuals, and frequenUy provide false information to law enforcement officials in order to protect the subject. 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CLJmf/-.?lej thMIL. ;) If /5 Itllj;llc 31j c1e/7t'~tI f~81':;- ((/~s o/Jdea.- fI;e (1J!ltdllv(.. d F oleOh"j 5'/1cl CA,M'S ec;).:9~k... c>l' C)fM''-~ rJlVCf a- /J/rJ/OI<- vd lile 8'):r AiPv-G A/O MrJttlk1ft-. V Jellied, :T' (I/JfJ5 /Je/(~12- ,ci7/2eI6'~ /IIo,e. .Reekk:;{ I~ r .f,0'~ IIJCJ Ill/JcJw!f;J{/;r-. 0/ m~{lcc~1 ,.6;IIs' CJ~ l-fiji'I2J flt6'1 lU/15 '!>uWl2.ei by r/L. ?/ftt/J/oNd 4e/~ 02063 answer, it Is specificelly denied that Plaintiff was operating his vehicle In a "careful and prudent manner" and proof Is demanded. Moreover, it Is speclfl~ally denied that Defendant was negligent, careless, reckless end/or operated the Chavy Nova In an Intentional and outrageous manner and proof Is demanded. Dafendant admits that an impact occurred between the vehicle being operated by Defendant and Plaintiff's vehicle. It Is further edmltted that this impact occurred In the northbound lane of SR 2011. It is, however, specifically denied that the impect was attributable to Defendant's being under the influence of alcohol and/or operating the vehicle at an unsafe speed. To the contrary, the accident was due to savere road conditions, including but not limited to drifting snow and Ice in Defendant's lane of travel. 6. Denied. The avarments of Paragraph 6 constitute legal conclusions to which no rasponse is required. By way of furthar answer, the averments are specifically denied and proof Is demanded. 7. The averments of Paragraph 7 including subparagraphs (a) through (i) constitute legal conclusions to which no response Is required. By way of further answer, it Is specifically denied that Defendent's conduct was negligent, careless, reckless, intentional and outrageous In the manner set forth In subparegraphs (a) through (i) and proof Is demanded. 8. Denied. The averments of Paragraph 8 constitute legal conclusions to which no response Is required. It is, however, speciflcelly denied that Defendant acted in a negligent, careless, reckless, Intentional and outrageous manner and proof - 2 - Is demanded. The remaining portions of this averment are speclflcelly denied since after reasonable Investigation, Defendant is without knowledge or Information sufficient to form a belief as to the truth of the everments and proof is demanded. 9. Denied. The averments of Paragraph 9 constitute legal conclusions to which no response Is required. It Is, however, specifically denied that Defendant acted In a nagligent, carelass, reckless, Intentional and outrageous manner and proof Is demanded. The remaining portions of this averment are speclflcelly denied since after reasonable Investigation, Defendent is without knowledge or information sufficient to form a belief es to the truth of the averments end proof is demanded. 10. Denied. The averments of Paragraph 10 constitute legal conclusions to which no response is required. It is, however, specifically denied that Defendant ected in a negligent, careless, reckless, Intentional and outrageous manner and proof is demanded. The remaining portions of this averment are specifically denied since after reasonable Investigation, Defendant is withou( knowledge or Information sufficient to form a belief as to the truth of the averments and proof is demandlld. 11. Denied. The averments of Paragraph 11 constitute legal conclusions to which no response Is required. It is, however, specifically denied that Defendant acted In a nagligent, carelass, reckless, intentlonel and outrageous manner and proof Is demanded. The remaining portions of this averment are specifically denied since after reasonable Investigation, Defendant Is without knowledge or Information sufficient to form a belief as to the truth of the everments and proof is demanded. - 3 - 12. Denied. After reasonable Investigation, Defendant is without knowledga or Information sufficient to form a belief as to tha truth of the averment and proof Is demanded. 13. No response required. WHEREFORE, Defendant Glenn W. Held requests that judgment be entered In hie favor and against Plaintiff Raymond H. Getz. NEW MATTER 14. Any and all damages, injuries and losses allegedly sustained by Plaintiff are due to the negligence and carelessness of Plaintiff and such conduct serves to reduce or bar his recovery pursuant to the terms of the Pennsylvanio Comparative Negligence Act, 42 Pa. C.S. H102. 15. Plaintiff assumed the risk. 16. Any recovery to which Plaintiff may be entitled Is limited by provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law Including but not limited to 75 Pa. C.S. ~ 1705 and ~ 1722. 17. The alleged conduct of Defendant Glenn Held was not the proximate cause of any injuries and/or damages sustained by the Plaintiff. 18. The Injuries allegedly sustained by the Plaintiff in the impact of March 15, 1993 are the result of pre-existing conditions and not the result of the accident occurring on March 15, 1993. - 4 - c-."-Grnu, ~....,. "",_".rl... IJtLu'WlAU'Iln.-t 'l'...........nulult<<1l ,.._..\,.'I....UWO IN TUB COURT OF COHHON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RAYMOND U. GETZ, I No. U-SU-7058 civil Tera Plaintiff I I va. I Civil Action - Lav I GLENN W. HELD, I Defendant I Jury Trial Demanded REPLY TO NEW HATTER AND NOW, to wit, this SO-lhday of June, 1995, comes the Plaintiff, Raymond H. Getz, by his attorneys, Griest, HimeB, Gettle, Herrold & Swift, Esquires, by Gregory E. Gettle, Esquire, and files the following Reply to New Matter of the Defendant, Glenn W. Held, whereof the fOllowing is a statement: 1 - 13. The allegations alleged in paragraphs 1 through 13 of Defendant's Answer and New Matter are Defendant's Answers to Plaintiff's Complaint and, as such, Plaintiff is not required to answer such allegations. To the extent that plaintiff is required to answer, Plaintiff denies all allegations and demands strict proof thereof. NEW HATTER 14. Denied. It is denied that the damages, injuries and losses sustained by Plaintiff are due to the negligence and carelessness of Plaintiff. The remaining portion of paragraph 14 is a conclusion of law to which no response is required. 1 U_.M-.&tTTU, --.."...., 4rn_ll.,I.. Il'Ir.u'W............, y,....I'....m...nll<<l1 nt_..III"......" 15 - 17. The allegations contained in paragraphs 15 through 17 are conclusions of law to which no responseB are required. To the extent that Plaintiff is required to answer, Plaintiff specifically denies the allegations contained in these paragraphs and demands strict proof thereof. 18. Denied. The injuries sustained by the Plaintiff in the accident of March 15, 1993, are not the result of any pre-exiBting conditions but rather the direct and proximato result of the accident on March 15, 1993. 19. Denied. It is specifically denied that the chiropractic treatment rendered to the Plaintiff was unreasonable, unnecessary and not causally related to the automobile accident of March 15, 1993. To the contrary, said treatment was reasonable, necessary and causally related to the automobile accident of March 15, 1993. 20 - 21. The allegations contained in paragraphs 20 through 21 are conclusions of law to which no responses are required. To the extent that Plaintiff is required to answer, plaintiff specifically denies the allegations contained in these paragraphs and demands strict proof thereof. 22. Admitted in part and denied in part. It is admitted that Plaintiff has not missed any time from work to date and has not sustained any lost wages to date. It is denied that Plaintiff has not suffered a loss of "future" wages and/or earning capacity. To the contrary, Plaintiff has or may have sustained a loss of future wages/earning capacity as a direct and proximate result of the accident of March 15, 1993. The remaining allegation iB a 2 ~,"""G6'm.a, ............ Am_".,La_ IltI.ufNUUfInM'f ",,&.""'n...,...I"OI r..__ClIfl'*'"eue :IN TUIl COURT OJ' COMMON PLEAS OJ' CUMBERLAND COUNTY, PBNNSYLVAJfIA ItA YKO!ID H. GIlTI, I No. 14-SU-7058 civil 'l'era Plaintiff I I va. I civil Action - La. I GLBNN W. HELD, I Defendant I Jury Trial Demanded CERTIFICATE OP SERVICE I, Gregory ~. Gettle, Esquire, Stlt, day of /jul1e... , do hereby certify that on the 1995, I served by U.S. Mail, postage pre-paid, a copy of Reply to New Matter upon the following attorneys and/or individuals of record. Karen S. Coates, Esquire Thomas, Thomas & Hafer 305 North Front street P.O. Box 999 Harrisburg, Pennsylvania 17108-0999 GRIEST, HIMES, GETTLIl, HERROLD , SWII"1' By: I Gregory e Supreme Cou t .D. #65600 129 East Market Street York, Pennsylvania 17401 (717) 846-8856 Attorney' for Plaintiff 5 o..J. ....onn.e. -.-- ""..."uLA_ l"ilAnW-._ "........n.-.11<101 T'Il_111'........". IX THB COURT or COKNOX PLBA8 or COKBZRLAHD COUMTY, P...8YLvaMIA RAYMOND H. OIT., I )10. U-8U-7058 Civil Ten Plaintiff I I v.. I Civil Aotion - Law I OLJDl)( W. HELD, I Defendant I Jury Trial D...nded CERTIFICATB or SERVICB I, Gregory E. Gettle, Esquire, do hereby certify that on the 26th day of January 1996, I served by U.S. Mail, postage pre-paid, a Notice of Deposition upon the following attorneys and/or individuals of record. Karen S. coates, Esquire Thomas, Thomas , Hafer 305 North Front street P.O. Box 999 Harrisburg, Pennsylvania 17108-0999 Attorney for Defendant, Glenn W. Held GRIB8T, HIHBS, OBTTLB, HERROLD , 8WIlT By: G e ory . Gettle, Esqu re Supreme Court I.D. #65600 129 East Market street York, Pennsylvania 17401 (717) 846-8856 Attorney for Plaintiff =':: , [I. a i", ... IJ.J~:: c'') (:-ll " L.. i - '.J 9(" '- 0,._ r;) ; ~, ~.~ Lu::. "".J ~!I . LL. 1-; ! > ,... "- ") -' c..: t:; \ ..,.. ~ '. i :!.,,Jr. t.. . ,-- C II .. ~. ; ~ 1~ (). F' , . " "'j C?\ C::-l ; r~ ll" .:.1, ,- <,.. I Li 1.-. .1.- t' ; , , : ) , J , I) , I , , . L' , ! ' f!".! (' , I":. .. II r , '-~ . ..-' l., , ,-'