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Home My WebLink About95-04812 '.... FRANCIS M. SCOTT Plaintiff I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTYL PBNNSYLVANIA I a '1- Cu...J-r. I NO. IS" - 4-~ 1992 ' ~ I I CIVIL ACTION - LAW I IN ARBITRATION VS. ALLENBERRY PLAYHOUSE Defendant IlOTICB You have been sued in Court. If you wish to defend againat the claims Bet forth in the following pageB, you mu.t take action within twsnty (20) days after the Complaint and Notice are .erved, by entering a written appearance or objection. to the claim. ..t forth againBt you. You are warned that if you fail to do .0, the ca.e may procesd without you and a judgment may be entered againat you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief reque.ted by the right. Plaintiff. You may lOBe money or property or other important to you. YOU SHOULD TAD THIS PAPBR TO YOUR LAWYIIR AT ONCI. IP YOU DO NOT HAVB A LAWYIIR OR CAIIIlO'1' AFPORD on, GO TO OR TBLBPHOn TBB OFFICI SET PORTH BILOW TO FIIlD OUT WBBRB YOU CAll GB'1' LEGAL BBLP. Court Administrator Cumberland County Courthouse One Courthouse Square Carlisls, PA 17013 (717) 240-6200 vs. I IN THB COURT OF CONNON PLBAS OF I CUMBERLAND COUNTY, PBNNSYLVANIA I I NO. 1992 I I CIVIL ACTION - LAW I FRANCIS M. SCOTT Plaintiff ALLBNBBRRY PLAYHOUSB Defendant COIIPLAIII'1' DD 1fOW, comes the Plaintiff, Franoie M. Scott, by her attorneys, The Law Offices of Patrick F. Lauer, Jr., and avere the following I 1. Plaintiff, Francie M. Scott, ie an adult individual reeiding st 5420 North 24th Strest, Arlington, Virginia. 2. Defendant, Allenberry Playhouse, is a Penneylvania oorporation with its principle place of bueiness looated at RR 1, Box 7, Boiling Springs, Cumberland County, Pennsylvania. 3. On or about August 4, 1994, Plaintiff was a patron at Defendants eetablishment which oonsiets of a playhouse and inn in which guests are able to remain overnight. 4. Plaintiff was present on Defendants premiees .e a business invitee taking advantage of a paokage deal offered through a looal travel group in Arlington, Virginia. 5. On or about August 4, 1994 the weather was rainy and Mrs. Scott was leaving her guest room located in one building on the property of Defendant in order to attend the play being presented in the playhouse whioh was located in a separate building on the Defendants property. i I II ,I ij I, I , I! II I' I I i over to one of the windows in order to look outside to .ee how far I I 6. Plaintiff came into the lobby area of the inn and walked shs would have to travel so ehe could decide whether or not ehe would get an umbrella or some other rain gsar. 7. To go to the window, it was necelesry for her to walk behind a couch which wal placed in front of the window. 8. Next to the couch was an end table upon which a table lamp relted. 9. The table lamp was plugged into an electrical socket in the wall in which the window was located. 10. The puwer cord to ths lamp wae not long enough to reach the locket and therefore eUlpended a few inchee above the carpeted floor. 11. As Mrs. Scott walked towards the window, her foot got caught on the suepended power cord and Ihe fell. 12. As a reeult of Plaintiffe fall, Plaintiff suffered a fracture of the shaft and neck of ths fifth mstatareal of her right foot. 13. Defendant wae negligent in the following manner I a. Placement of the couch and end table at euch a distance from the window and wall al to invite patrone to walk behind eaid couch in order to look out the window, b. Placement of the lamp on the end table which would require a power cord to be plugged into the wall and laid power cord traversing a possible area of travel by busines. invitees to Plaintiffs premises, c. Placement of a lamp with a power cord not long enough to be secured to the floor but rather suspended a few inches above the floor thus creating a hazard to Defendant'. business invitees. 14 . Defendant's negligence was the direct and proximate cau.e of Plaintiff's injury as set forth above. 15. As a result of Plaintiff's injuries caulsd by Defendant's negligence, Plaintiff was unable to attend the play which .he traveled to Allenberry Playhoule to see. 16. Furthermore, as a result of Defendant'l negligence eauling Plaintiffs injury, Plaintiff was unable to attsnd a eecond planned vacation to the New England area the expenle which had already been incurred. 17. As a result of Defendant's negligence which cau.ed the Plaintiff's injury, Plaintiff has suffered great pain, humiliation and embarraesment. And claim is made therefore. 18. Due to Defendant's negligence which caused Plaintiffs injury, Plaintiff has incurred medical expenses in the amount of $131. 38. WHBRBFORB, Plaintiff demand. judgement again.t Defendant. Relpectfully lubmitted, ) (... ? Dr J. Puhala, Sr., Bequire Law Office. of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennlylvania 17011-4706 10' 52677 Tel. (717) 763-1800 Date I ,,/.../P\- 'j-:;, l.,..o" ~' " '~'. :/-'1 t ~ // . -: I .I ....-:J;~ ~ c::- ~rancis M. Scott VBRIPICATIOII I, Francie M. Scott, state that I am the Plaintiff in the above-captioned case and that the facts set forth in the above Complaint are true and correct to the beet of my knowledge, information, and belief. I realize that false statement. herein are subject to the penalties for unsworn falsification to authorities under l8 Pa. C.s. S 4940. 'l", .". Datelt"> 1/:I~-:1/- 1 ~I I r/~::.r ! . I SHERIFF'S RETURN - REGULAR CASE NOI 1995-04812 P COMMONWEALTH OF PENNSYLVANIAl COUNTY OF CUMBERLAND SCOTT FRANCIS M VS. ALLENBERRY PLAYHOUSE LEROY HIPPENSTEEL. III , Sheriff or Deputy ShE'riff of CUMBERLAND County, PE'nnsylvania, who bE'ing duly sworn according to law, says, thE' within COMPLAINT IN ARBITRATION was servE'd upon ALLENBERRY PLAYHOUSE thE' dE'fendant, at 845100 HOURS, on the 15th day of SE'ptember I9~ at RR 1 BOX 7 BOILING SPRINGS. PA 17007 . CUMBERLAND County. PE'nnsylvania, by handlng to MARJORIE LEHMAN. BOOKKEEPER & ADULT IN CHARGE a true and attestE'd copy of the ~PLAINT IN ARBITRATION together with NOTICE and at the samE' time d1rE'cting Her. attention to the contents t.hereo!. Sheriff's CoStSI Docketing ServicE' Affidavit Suroharge 18,00 2,80 ,00 2.00 622, 00 So answerSl h~' </ ~ -~. , ~~-...4'<, ;- Thomas-,(\T1n, er ~ PATfllCK F, LAUER 09/20/1995 by ~ LJ .J 61 .L....h.. .... 17~ ' . ~uly ~.U1 Sworn and subscribed t.o before me this -is!!: day of J~,r;:::I.. ~ 19 IJr' A. d. <....}"..... Gr 'H~~---, tJ)r~ rothonotur FRANCIS M. SCOTT Plaintiff I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I I NO. 95-4812 CIVIL TERM I I CIVIL ACTION - LAW I IN ARBITRATION VS. ALLENBERRY PLAYHOUSE Defendant PRAECIPE TO DISHISS TO THE PROTHONOTARY I Kindly mark the above-captioned matter settled, clo.ed, and dismissed. Respectf~:~submitted, / c; Date I z.I,lfG: Bri J. Puhala, Sr., Eequire Law Office. of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 lOll 52677 Tel. (717) 763-1800 ;.-"",",,,,,,,~~ ...... :_cL;q;;'~~_"-~/~J-~'~. f - A~ ::- ~ .. ...... .,.. ., .~ Riff =' Cl.: t5.~ , t'\ '" 'C "" ~Jf".~ ..lp..J III , "",:- iJ.i ~ f.jJ;;'? /.U "1';;> & to;.- (9fJ..J , /il ti