HomeMy WebLinkAbout95-01904
J
-s.
.1;
-0
.;
~
c
C3
.
7
L.
Q)
~
. · ci)
N
~
I
JI
.
o
Z
;:;"2~,/J'I"dl ,,,.I,,/',,J,-rIlJ ,1,'iVl""1 "'I'
c, Failing to take steps in order to prevent the
accident, including failing to take steps to
maintain and repair the switch or to stop Plaintiff
from operating the switch;
d. Failing to inspect the switch so as to find the
defect and/or damage;
e. Failing to take adequate preventative measures to
correct the dangerous. or potent iall y dangerous,
condition of the switch;
f. Failing to properly supervise and warn the Plaintiff
so he would not be injured; and
g. Failing to take the defective switch out of service.
16. The aforementioned accident resulted solely from the
negligence, carelessness and recklessness of the Defendant as
aforesaid, and was not due to any act. or failure to act. on the
part of Plaintiff.
17. As a direct and proximate result of Defendant' s aforesaid
negligence, carelessness and recklessness, Plaintiff, Fred W.
Zeigler, sustained numerous severe injuries and symptoms,
18. including. but not limited to. left knee contusion and
severe pain in that knee.
4
/UJ'2I...,'!',," ,.,l,l"Io/,", 1,"'/'""1 '"I'
19. As a result of Defendant's negligence, plaintiff incurred
injuries which were and are severe, permanent and disabling in
nature.
20. As a result of his injuries and Defendant's negligence,
Plaintiff Fred W. Zeigler suffered and will continue to suffer in
the future, severe physical pain, suffering, mental anguish,
humiliation ~nd loss of life's pleasures.
21. As a result of his injuries and Defendant's negligence,
Plaintiff Fred W. Zeigler has suffered physical impairments which
have, and may continue to, hinder all or substantially all, of the
material duties that constitute his usual and customary daily
activities.
22. As a result of his injuries and Defendant's negligence,
Plaintiff Fred W. Zeigler has suffered and will continue to suffer
a severe and permanent loss of earnings and impairment of earnings
and impairment of his earning capacity.
22. As a result of his injuries and Defendant's negligence,
Plaintiff Fred W. Zeigler has been, and will be, obligated to
receive and undergo medical attention, care and therapy, and he has
incurred various expenses for said medical treatment and therapy,
5
.....
~
.',1
.,
,',..,
'.::-1
q
z
0( !
t:l
OC
0 ~ a
" w E
~
.
.ol! ~ < ~
Vl i'i
~ ~ > ,
<
0 . . ..
- oc . .8 ~ j::
0< ... ~
~ 0 , w
. ~ ~ " .
jVl . .,; .t 0
0 ~
c:i z .; ~
. ~
oc - a I-
~ .
.. .
<
OJ :>:
:c
..,
'r-
-.
.. --. ,..~.
FRED W. ZEIGLER,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v.
NO. 95-1904 CIVIL
CONSOLIDATED RAIL
CORPORATION,
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
I hereby certify that I have this c:Q f ~ day of September,
1995, served a Reauest for production of Documents upon counsel of
record by First Class U.S. Mail, addressed as follows:
David C. Eaton, Esquire
NAUMAN, SMITH, SHISSLER & HALL
122 Market Street
P. O. Box 840
Harrisburg, PA 17101
HEPFORD, SWARTZ & MORGAN
By: (/}_,/f, !tI-~
D~S w.~affer
Attorney 1.0. #39182
111 North Front Street
P. O. Box 889
Harrisburg, PA 17108-0889
Date: 9/ ~ , !q.,,-
ATTORNEYS FOR PLAINTIFF
'- .:-~
~c..>o
.... .....
:: ::c
'"
> ...
.
. ."
. 0
;;l ~ ,.
~ . - ~
P :t.
~ ... ... 0 Vl~
~ P .
, , ~ ~ .
~ , . )0 0
... . ~ ."
. ,. .
::; ~ .
. c ;H
f > 5 .
, ~ ll:o~
. !!'
~ i . :::
~
~ 0
,.
Cl
'" )0
7.
U'I
'"
-u
r-.J
r-..l
("0...)
l,J
""
~
:::<:
'<.0
,...,.,
'- c:...:.,
,- .....
'-' '"
:I: :r:
m
. ."
. ."
.
:; 0
;;l . = '"
e p
~ .
:l .0 "-
':! :0 e tIlr
0 .
, , p ;; ~ .
~ , > 0
.. . 8' ."
::; < . '" .
. . 0 ;:l ~
,
f ~ g; ~ Raii:
; '" ~
~ ::; : :::
~ ~
" 0
'"
Cl
.. >
'" "-
L/'2
'"
-u
r-.,
.-'.)
1')
..,
I..J
-0
::..:
-
l.D
l..T1