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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA
KAREN J. ANDREWS, . CIVIL ACTION - LAW
.
plaintiff I (i ~ ll-l-t. d L L-/l\...'
I c; ~- - 1-/frc'
v. . NO.
.
I
DONALD C. SIEG,
Defendant JURY TRIAL DEMANED
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against
the claims set forth in the follo",ir.g pages, you must take action
within twenty (20) days after this complaiut and Notice 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 Defendant. 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 Fl.
carlisle, PA 17013
(717) 240-6200
NOTtCIA
Le han demaandado a usted en la corte. si usted quieie
defenderse de estas demandas expuestas en las paginas siguientes,
usted tiene viente (20) dias de plazo al partir de la fecha de la
demanda Y la notificacion. usted debe presentar una apariencia
escrita 0 en persona 0 por abogado Y archivar en la corte enforma
escrita sus defensas 0 sus objections alas demandas en contra de
su persona. Sea ayisado que si usted no se defiende, la corte
tomara medidas Y puede entrar una orden contra usted sin previo
aviso 0 notificacion Y port cualquier queja 0 alivio que es
pedido en la peticion de demanda. Usted puede perder dinero 0
sus propiedades 0 otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO INMEOIATAMENTE. SI NO TIENE
ABOGADO 0 SI NO TIENE EL OINERO SUFICIENTE DE PAGAR TAL SEVICIO,
VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION
SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE
CONSEGUIR ASISTENCIA LEGAL.
Court Administrator
Cumberland county Courthouse, 4th Fl.
Carlisle, PA 17013
(717) 240-6200
Date: ~. 2S;,1'l'rf"
G~ESqUlre
2423 North Third Street
Harrisburg, PA 17110
(717) 238-0434
Attorney 1.0. No. 23705
W THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA
KAREN J. ANDREWS . CIVIL ACTION - LAW
.
plaintiff .
.
I
V. I NO.
.
.
DONALD C. SIEG .
.
Defendants . JURY TRIAL DEMANDED
.
COMPLAINT
COMES NOW, the Plaintiff, KAREN J. ANDREWS, by and through
her attorney, Gregory R. Reed, Esquire, and for her cause of
action alleges:
1. Plaintiff, KAREN J. ANDREWS, (hereinafter referred to as
"plaintiff") is an adult individual, residing at 420 Gettysburg
Pike, Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. Defendant, DONALD C. SIEG, (hereinafter referred to as
"Defendant") is an adult individual, residing at 34 Junction
Road, Dillsburg, York County, Pennsylvania 17019.
3. The facts and occurrences hereinafter related took place
on or about July 5, 1995 at the intersection of Carlisle pike
(SR0011) and conodoguinet Avenue in Hampden Township, Cumberland
County, Pennsylvania.
4. At that time and place Plaintiff was the operator of a
1987 Jetta and was traveling east on the Carlisle Pike.
5. At that time and place Defendant was the operator of a
1992 Ford Thunderbird and was traveling west on the Carlisle
Pike.
6. At that time and place Defendant turned his vehicle
directly into the path of Plaintiff's vehicle.
7. At that time and place the vehicle operated by Defendant
was caused or allowed to crash into the vehlcle driven by
Plaintiff.
8. The aforesaid collision and all the herein mentioned
injuries and damages sustained by Plaintiff are the direct result
of the negligence, carelessness and recklessness of Defendant as
follows:
(a)
(b)
(c)
(d)
(e)
(f)
(g)
(h)
(i)
( j )
In failing to keep alert and maintain a proper
lookout for the presence of other motor vehicles
on the highway;
In failing to keep proper and adequate control
of his vehicle;
In failing to stop for oncoming traffic;
In turning left directly into the path
of plaintiff's vehicle;
In failing to exercise the degree of care
required at an intersection;
In failing to maintain a proper lookout
for traffic at said intersection;
In failing to yield the right-of-way to the
Plaintiff's vehicle;
In failing to apply his brakes in time to
avoid striking plaintiff's vehicle;
Ln failing to take measures to avoid striking
plaintiff's vehicle;
In driving his vehicle in a reckless manner and
with careless disregard for the rights and safety
of others and in otherwise operating his vehicle
upon the highway in a manner endangering persons
and property and in violation of the motor vehicle
code of the Commonwealth of Pennsylvania.
g. As a result of the aforesaid collision Plaintiff was
thrown and jostled about, thereby sustaining painful, permanent,
severe and disabling injuries and serious impairment of function
including, but not to limited to, the following:
(a)
(b)
(c)
(c)
(d)
Open laceration on the medial aspect of
the talonavicular joint of the right foot;
Swelling of the right foot;
stiffness and discomfort about the subtalar
region of her right foot;
Open laceration exposed the articular cartilage
of the taylor head; and
Right open subtalar dislocation.
10. Plaintiff has been advised and therefore avers that the
aforesaid injuries are permanent in nature, and claim is made
therefore.
11. By reason of the aforesaid injuries sustained by
Plaintiff she was forced to incur liability for medical
treatment, medicine, physical therapy, and similar miscellaneous
expenses in and about an effort to restore herself to health;
and because of the nature of said injuries she is advised, and
therefore avers, that she will be forced to incur similar
expenses in the future, and claim is made therefore.
12. As a result of said injuries Plaintiff has undergone and
.~ j
i
in the future will undergo great mental and physical pain and
sUffering, great inconvenience in carrying out her daily
activities, loss of life's pleasures and enjoyment and claim is
IIIlIde therefore.
13. As a result of the said injuries Plaintiff has been, and
in the future will be subject to great humiliation and
embarrassment, and claim is IIIlIde therefore.
14. As a result of said injuries Plaintiff has sustained a
loss of earnings and claim is made therefore.
15. As a result of said injuries Plaintiff has sustained a
perlllllnent impairment of earning power and earning capacity, and
claim is IIIlIde therefore.
16. The injuries sustained by Plaintiff are such that she is
permitted to file suit pursuant to 75 Pa. C.S.A. 11705 in that
Plaintiff sustained serious bodily injury.
WHEREFORE, Plaintiff, KAREN J. ANDREWS, delllllnds jUdgment
against the Defendant, DONALD C. SlEG, in an amount in excess of
the jurisdictional amount requiring compulsory arbitration in
Cumberland County, Pennsylvania.
i
I
I
I
Date: ~ .'7~ Iff's--
Gr-e~~'1re
Attorney for Plaintiffs
2423 North Third Street
Harrisburg, PA 17110
(717) 238-0434
Attorney ID. No. 23705
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1:1 The Court cT C:::mmO:1 Flec:s of C:Jr,'::'::::lt'i::l1d C;,::u:-;~'YI Panr:sylvc:r.io
Karen J. Andrews
'is.
Donald C. Sieg
95-5160 Civil Term
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Affida.vit or Se:-ri~
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October 5
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Notice Eo complaint
..1poD
Donald c. Sieg .
1t 14 .1IJn~t:ion Road. Dlllsbura. PA
by::u:ci!:1;:o
Donald C. Sleg
~ true and attested
cpr of ==
o::~-~I at York County Courthouse, 2B
. E. Market St., York CounJ;.y, PA
:md _,r. bawu :0
him
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COSTS
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NOTARIAL sEAb-:: llJA"v .
Wall.. "" Rhine, NOllry Public
rk, York County. Pennsylvanil
.1 I :':lIlllnISSIOn EJlplre.. March 25. 1999
S 20.0'0
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LAW OmCES OF
BARRINGTON, KAUFFMAN" SIIILLING
A1TORNEY: Howard D. Kauffman, Eaqulre
SUPREME COURT LB. NO.: 31%3
100 PINE STREET, SUITE 300
IIA1lRWBURG, PA 17101
(717) 726-0700
A1TORNEY FOR:
Defendant
KAREN ], ANDREWS
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VI
DONALD C. SIEa
Defendant
DOCKET NO. 95-5160 CIVIL TERM
PRAECIPE FOR ENTRY OF APPEARANCE
TO TIlE PROTHONOTARY:
Kindly er.ter the appearance of Hvward D. Kauffinan, Esquire on behalf of Defendant
Donald C. Sieg in the above-captioned litigation.
H?--=~9mLrnO
Howard D. Kauffinan, Esquire
LAW OFFICES OF
BARRINGTON. KAUFFMAN A SHILLING
ATI'ORNEY: Howard D. KaulTmaD. Eaqulre
SUPREME COURT LD. NO.: 38963
100 PINE STREET. SUITE 300
HARRISBURG. PA 17101
(717) 720-0700
ATJ'ORNEY FOR:
nercDdlDt
KAREN J. ANDREWS
Plaintiff
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V ANlA
VI
DONALD C. sma
Defendant
DOCKET NO. 95-5160 CIVIL TERM
~ERTIFICATE OF SERVICE
AND NOW, this 14 ~day of ~ . 1995, I, Howard D. Kauffinan,
Eaqulre, attorney for Defendant Donald C. Sieg affinn that I served the Praecipe for Entry of
Appearance by depositing same in the United States Mail, postage prepaid, in Harrisburg,
Pennaylvania, addressed to:
Gregory R. Retd, Esquire
2423 North Third Street
Harrisburg, PA 17110
...----.
Howard D.
LAW OFFICES OF
HARRINGTON, KAUFFMAN .. SHILLING
ATIORNEY: Howard D. Kauffmao, [,quire
SUPREME COURT LD. NO.: 38963
100 PINE STREET, SUITE 300
HARRISBURG, PA 17101
(717) 720-0700
ATIORNEY FOR:
Berendant
KAREN 1. ANDREWS
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
DONALD C, sma
Defendant
DOCKET NO. 95-5160 CIVIL TERM
STlPULA T10l't{
It i. hereby agreed by and between the partie. through their respective counsel that
parage.phl B(e), 8(i) and B(j) ofPlaintitr. Complaint are stricken with prejudice.
Respectfully submitted,
~2~mf~
Or ory . Reed, Esquire
Counsel for Plaintiff
/'
--,
//' /, , '
i t,. )(;~r) /p-/__---- '.
Howard-D. Kauffinan. Esquire
Counsel for Defendant
LAW OFFICES OF
HARlUNGTON, KAUFFMAN A SHILLING
ATIORNEY: Howard B. Kauffman, Elqulre
SUPREME COURT LB. NO.: 38963
100 PINE STREET, SUITE 300
HARRISBURG, PA 17101
(717) 720-0700
A TIORNEY FOR:
~rendant
KAREN J, ANDREWS
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VI
DONALD C. sma
Defendant
DOCKET NO. 95-5160 CIVIL TERM
~ERT1F1CA TE OF SERVICE
~l~
AND NOW, this"" day of ~ , 1995,1, Howard D. Kauffinan.
Esquire, attorney for Defcndant Donald C. Slcg affinn that 1 served thc Stipulation by dcpositlng
same In the United Statcs Mail, postagc prcpaid, In Harrisburg, pcnnsylvanla, addressed to:
Grcgory R. Reed, Esquirc
2423 North Third Street
Harrisburg. P A 17110
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Howard tr.'Kauffman, Esquirc
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LAW oma:s OF
HARRINGTON, KAUFFMAN " SHILLING
ATrORNEYI Howard D. Kaumnan, Elqulre
SUPREME COURT LD. NO.1 31963
100 PINE STREET, SUITE 300
HARRISBURG, PA 17101
(717) 711).0700
ATrORNEY FOR:
Dereadaat
K.AREN 1, ANDREWS,
Plalntlft'
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VI
I
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DONALD C, SIEG,
Defendant
DOCKET NO. 9S.S 160 CIVIL TERM
~RTIFICATE OF SERVICE
AND NOW, thll 30th day of1anuary, 1996,1, Howard D, Kauffinan. Esquire, attorney
for Defendant Donald C, Sieg affinn that I ICrved the Response to Request for Production of
Documents by depoliting aame in the United States Mai1, postage prepaid. in Harrisburg,
Pennsylvania, addressed to:
,
I
,
,
Gregory R. Reed, Esquire
2423 Nonh Third Street
Harrisburg, PA 17110
Esquire
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LAW oFFICES or
HARRINGTON, KAUJl'Jl'MAN " SHILLING
ATTORNEY: Boward D. Kaull'llla., Elqulre
SUPREME COURT LD. NO.: 31963
100 PINE STREET, sum 300
HARRISBURG, PA 17101
(717) 720.0700
ATTORNEY rOR:
Dert.dID'
KAREN J, ANDREWS.
plalntift'
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. pENNSYLV MUA
VI
DOCKET NO, 95-5160 CIVIL TERM
JURY TRIAL DEMANDED
DONALD C, smG,
Defendant
~OTlCE TO PLEAD
TO: plalntiff
YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE
ENCLOSED ANSWER AND NEW MATTER WITHIN TWENTY (20) DAYS FROM
SERVICE HEREOF OR A JUDGMENT MAY BE BNTERED AGAINST YOU,
HARRINGTON. KAUFFMAN & SHILLING
#~
Howard D. Kauffinan. Esquire
8. Denied. It II denied that Anlwcring Defendant wu nesJIgent. careIcu or recldeu
in any IlWlIICI' whatlOCVer. On the contrary, Anlwcring Defendant acted reuonably and
prudently WIder the clrCUl1lltanCel. Further. after reuonable invOItlgatlon, Anlworlng Defendant
II without IUffidont lnfonnatlon or knowledge with which to fonn a belief u to the truth of tho
remaining avonnontl ofthil paragraph and they are accordingly denied.
.. Denied. On the contrary, Anlwcring Defendant acted reuonably and
prudently under the clrcunutlllCel;
b. DenIed. On tho contrary, Anlwering Defendant acted reuonablyand
prudently under the circulllllanCel;
c, DenIed. On tho contrary, Answering Defendant acted reuonablyand
prudently under the cirCUffiltances;
d. DenIed. On tho contrary, Anlwering Defendant acted reuonably and
prudently WIder the cirCUlllllancel;
e. Stricken by Stipulation;
f. Denied. On tho contrary, Answering Defendant acted reasonably and
prudently under the circulllllanCel;
g. Denied. On tho contrary, Answering Defendant acted reasonably and
prudently under the cirCUlllllancel;
h. Denied. On the contrary, Answering Defendant acted reasonably and
prudently under tho circumatancel;
i. Stricken by Stipulation;
j. Stricken by Stipulation.
9, Denied, After reuonable investigation, Answerins Defendant i. without sufficient
Information or knowledge with which to fonn a beliefu to the truth of the averment. ofthl.
paragraph,
10, Denied. After reuonable inveatigadon, Anawerins Defendant I. withoutsuftlcient
information or knowledge with which to fonn a belief u to the truth of the avermenll ofthl.
paragraph,
II. Denied. After reuonable invelligation, An.wering Defendant i. without sufficient
information or knowledge with which to fonn a belief aa to the truth of the averment. ofthl.
paragraph.
12, Denied. After reuonable inveatigatlon, An.wering Defendant I. without sufficient
Informalion or knowledge with which to fonn a belitfaa to the truth of the averment. ofthl.
paragraph.
13. Denied. After reuonable inveatigation, Answering Defendant I. without sufficient
Informalion or knowledge with which to fonn a belief as to the truth of the averment. of this
paragraph.
14. Denied. After reuonable investigation, Answering Defendant I. without sufficient
information or knowledge with which to fonn a beliefu to the truth of the averments of this
paragraph.
IS, Denied. After reuonable investigation, Answering Defendant is without sufficient
information or knowledge with which to fonn a belief as to the truth of the averment. of this
paragraph.
16. DenIed. After reuonable inveatisatlon, Anawering Defendant i. without aufficlent
information or knowledlJO with which to fonn a belief u to the truth of the avennentJ ofthl.
paraaraph.
WHEREFORE, Defendant deniea that Plaintift'i. entitled to judgment against the
defendant in the unount apecificd, or to any sum of money whataocver, or to interest or coat. and
praya that judgment be entered in Defendant'. favor and against the Plaintiff' and for her coat. and
feea and for auch other relief u the Court deems appropriate.
DEFENDANT DEMANDS TRIAL BY JURY.
NEW MATTER
17. If it i. determined that the Answerins Defendant i. liable under the Plaintifr. cauae
of action, the Anawerins Defendant aven that the Plaintifr. recovery should be eliminated or
reduced in accordance with Pcnnaylvania Comparative Negligence Act, 42 Pa. C.S.A. 17102
becauae Plalntitr.
a. Failed to keep alert and maintain a proper walch of the presence of other
motor vehidea on the highway;
b. Failed to apply her brakea in sufficient time to avoid striking Answering
Defendant'. vehicle;
c. Failed to travel at a safe speed;
d. Failed to keep proper and adequate control over the vehicle;
e. Failed to operate the steering of the vehicle in such a manner 10 that she
could maneuver her vehlcle to avoid a collision.
18. It i. f\u1her averred that if the PWntift"suffcrcd any injuriealdamagea u alleged.
they were cauaed IOldy and prinwily by the Plaintiff'. own cardeuneu and neg\igence becauae
the PWntiff.
a. FaI1ed to keep aim and maintain a proper watch of the preaence of other
motor vchlclea on the highway;
b, Failed to apply her brakea in auftlcicnt time to avoid atriking Anawering
Defendant'. vehicle;
c. Failed to travel at a we .peed;
d. Failed to keep proper and adequate control over the vehicle;
e, FaI1ed to operate the .teeOl1g of the vehicle in auch a manner 10 that ahe
could JlW)CUver her vehicle to avoid a colllsion.
19. It i. further .verred by the Anawering Defendant that ifPlaintiffauffered any
injuriealdamagea u alleged, laid Plaintiff, by her conduct, IllUmed the riak ofthoae
injuriealdamagea becauae:
a, Failed to keep almlllld maintain a proper watch of the prcacnce of other
motor vehiclea on the highway;
b. Failed to apply her brake. in aufficient time to avoid striking Anawering
Defendant'. vehicle;
c. Failed to travel at a we speed;
d. Failed to keep proper and adequate control over the vehicle;
e. Failed to operate the steering of the vehicle in auch a manner so that ahe
could maneuver her vehicle to avoid a colllsion,
20. Anawerins Defendant wert. all the defcwel, \imitations and excluuonsavailable
under the Motor vehicle Financial ResporllibiUty Law, 75 Pa. C,S,A. fi1701 et. seq. and aver.
that p\a1ntift'may not plead, prove, Introduce Into evidence or recovery any benefit. paid or
payable under the Motor Vehicle Financlll Rcsporllibllity Law.
21. Some or 111 of plaintiff's clail1ll may be barred or limited by Plaintiff'. selection of
the Umlted Tort Option of her illlUl'ance COverage, pursuant to the PeMlylvanla Motor vehicle
Fitw1cial Responsibility Law, Pa. C.S.A. fi 1701 !!t. seq.
22. Defendant reserves the right to challenge any award of delay damages In thi. case.
23. Defendant demands that appropriate hearings be conducted in this case prior to
any award of delay dama8es.
24. Rule 238 of the pennsylvania Rules of Civil Procedure, on its face, and II applied
is violative of the Due Proceu and Equal Protection clauses of the Fourteenth Amendment to the
Collltitutlon of the United States, t1983 of Tide 42 oCthe United States Code and Article I, fil,
6, 11 and 26 and Article V, fi 1 0( c) of the Pennsylvania Constitution and imposea a chilling effect
on the exercise by Defendant of its constitutional rights.
25. Plalntiffclail1ll for punitive damages violate Article I, Section 13 oCthe
pennsylvania Collltitution and the Eighth Amendment to the United States Constitution in that
punitive damages, II awardOO in pennsylvania, without any defined method for the jury to
corllider II a IlU1ldard, are croel, unusual, excessive, arbitrary and capricious and collltitutes croel
and unusual puniahment.
26. plaintiff clail1ll for punitive damages are violative of the Fifth and Fourteenth
Amendment. to the Constitution of the United States and Article I, Sections 1 and 11 of the
pennsylvania Constitution in that they violate substantive and procedurll due proceSl because
punitive damagea, II awarded in the Pennsylvania, without any defined method for the jury to
contldel' II a atandard are CIlIOl, unuaual, exceuive, ubItrary and capriciou..
27, Plaintift' cIaimI for punitive damages are violative of the Fifth and Fourteenth
Amendment. to the COIIItitutlon of the United States and Article I, SectiollJ 1 and 11 of the
PeMI)'lvania COIIItitution in that they violate subllantive and procedural due prOCOll beefll''''
punitive damagea, II awarded in Pennsylvania, do not provide for any po.t-verdict review
procedurea, control. and/or guidelines to determine whether the amount awarded by the jury WII
exceuive, arbitrary and/or capricious and, therefore, COlIJtitutes cruel and unusual punishment.
28. Plaintift' claiRII for punitive damages violate Article I, Section 13 of the
PeMI)'lvanla Constitution and the Eighth Amendment to the United States Collltitutlon in that
punitive damagea, II awarded in Pennsylvania, do not provide for any post-verdict view
procedurea, control. and/or guidelines to detennine whether the amount awarded by the jury WII
exceuive, arbitrary and/or caplicious and, therefore, colIJtitutes cruel and unusual punislunent.
29. Plaintlft' claim for punitive damages cannot be sustained because an award of such
exemplary relief, without proof of every element beyond a reasonable doubt, would violate
Defendant due procell rights under the Fourteenth Amendment to the United States COlIJtitution
and under the provisiollJ of the Pennsylvania Constitution. Alternatively, unte.. Defendant'.
liability for punitive damages and the appropriate amount of such damages arc required to be
established by the Plaintift'by clear and convincing evidence, any award of punitive damages
would violate Defendant due proce.. rights guaranteed by the Fourteenth Amendment to the
United States Constitution and by the provisiollJ of the PeMsylvania Constitution,
WHEREFORE, Defendant denies that Plaintift'is entitled to judgment agaillJt the
defendant in the amount specified. or to any sum of money whatsoever. or to interest or costs and
praya that Judament be entered in Defendant'. favor and againat the !'laintift' and foc her coati and
feea and for IUCII other relief u the Court deema appropriate,
DEFENDANT DEMANDS TRIAL BY JURY.
HARRINGTON, KAUFFMAN I/: SHD..LING
~
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How . ffinan, Eaqulre
LAW omcu OF
IlARRINGTON. KAUFFMAN a SHILLING
ATrORNJ:YI How..... B. )(all....... Elqulre
SUPIlEMJ: COURT LB. NO.: 31963
180 PINE STREET. sum: 300
IlAlUUSBURG. PA 17101
(717) 720-8700
A TrORNJ:Y FOR:
Deladut
KAREN J, ANDREWS,
plaintift'
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VI
DONALD C. sma,
Defendant
DOCKET NO. 95-5160 CIVIL TERM
CERTIFICATE OF SERVICE
, AND NOW, thi..l!!L day of Februarv
. 1996, I, Howard D. Kauffinan,
"
Eaqulre, attorney for Defendant Donald C. SieS affinn that 1 served the Anlwer and Now Matter
, by' 4epoM11l8 III1lC in the United St.te. Mail, poltage prepaid, in Harrisburg, PeMlY1vanla,
addreucd to:
Gregory R. Reed, Esquire
2423 North Third Street
Harrilburg, P A 1711 0
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA
KAREN J. ANDREWS I CIVIL ACTION - LAW
Plaintiff I
v. NO. 95-5160
.
.
DONALD C. SIEG .
.
Defendants JURY TRIAL DEMANDED
PLAINTIFF'S REPLY TO NEW MATTER
17. Denied. Defendant's allegation is an averment or
conclusion of law to which no response is required. Never-
theless, it is denied that Plaintiff was negligent, careless or
reckless in any nature whatsoever. On the contrary, Plaintiff
acted reasonably and prudently under the circumstances.
(a) Denied. On the contrary Plaintiff acted
reasonably and prudently under the circumstances.
(b) Denied. On the contrary Plaintiff acted
reasonably and prudently under the circumstnnces.
(c) Denied. On the contrary Plaintiff acted
reasonably and prudently under the circumstances.
(d) Denied. On the contrary Plaintiff acted
reasonably and prudently under the circumstances.
(e) Denied. On the contrary Plaintiff acted
reasonably and prudently under the circumstances.
lB. Denied. Defendant's allegation is an averment or
conclusion of law to which no response is required. Never-
theless, it is denied that Plaintiff was negligent, careless or
,
reckless in any nature whatsoever. On the contrary, Plaintiff
acted reasonably and prudently under the circumstances.
19. Denied. Defendant's allegation is an averment or
conclusion of law to which no response is required. Never-
theless, it is denied that Plaintiff was negligent, careless or
reckless in any nature whatsoever. On the contrary, Plaintiff
acted reasonably and prudently under the circumstances.
20. Defendant's allegation is a conclusion or averment of
law to which no responsive pleading is required.
21. Defendant's allegation is a conclusion or averment of
law to which no responsive pleading is required. In addition,
Plaintiff's injuries are serious and permanent and as such are
not bound or limited by a Limited Tort option.
22. Defendant's allegation is a conclusion or averment of
law to which no responsive pleading is required. In addition,
Plaintiff's injuries are serious and permanent and as such are
not bound or limited by a Limited Tort option.
23. Defendant's allegation is a conclusion or averment of
law to which no responsive pleading is required. In addition,
Plaintiff's injuries are serious and permanent and as such are
not bound or limited by a Limited Tort option. Furthermore,
Defendant is not entitled to any further hearing.
.
24. Defendant's allegation is a conclusion or averment of
law to which no responsive pleading is required. In addition,
Plaintiff's injuries are serious and permanent and as such are
not bound or limited by a Limited Tort option. Furthermore,
Defendant is not entitled to any further hearing.
.
25. Plaintiff makes no claim for punitive damages.
Nevertheless, Defendant's allegation is a conclusion or averment
of law to which no responsive pleading is required.
26. Plaintiff makes no claim for punitive damages.
Defendant's allegation is a conclusion or averment of law to
which no responsive pleading is required.
27. Plaintiff makes no claim for punitive damages.
Defendant's allegation is a conclusion or averment of law to
which no responsive pleading is required.
28. Plaintiff makes no claim for punitive damages.
Defendant's allegation is a conclusion or averment of law to
which no responsive pleading is required.
29. Plaintiff makes no claim for punitive damages.
Defendant's allegation is a conclusion or averment of law to
which no responsive pleading is required.
WHEREFORE, Plaintiff demands judgment against Defendant and
for Plaintiff together with
costs, interest and delay damages.
4~-f>--
Attorney for Plaintiff
2423 North Third street
Harrisburg, PA 17110
(717) 238-0434 - Atty I.O. 23705
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LAW OmCES OF
IlAlUUNGTON, KAUFFMAN 1& SHILLING
A1TORNEY: Howard D. Kauffman, Esquire
SUPREME COURT LD. NO.: 31963
100 PINE STREET, SUITE 300
HARRISBURG, PA 17101
(717) 720-0700
A TfORNEY FOR:
Derenda.t
KAREN J. ANDREWS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
DONALD C. SIEG,
Defendant
DOCKET NO. 95-5160 CIVIL TERM
CERTIFICATE OF SERVICE
~
AND NOW, thi.;[: day of February, 1996, I, Howard D. Kauffinan, Esquire, attorney
for Defendant Donald C. Sieg affirm that I served the Response to Interrogatories by depositing
aame in the United States Mail, postage prepaid, in Harrisburg, Pennsylvania, addressed to:
Gregory R. Reed, Esquire
2423 North Third Street
Harrisburg, PA 17110
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LAW OFFICES OF
HARRINGTON, KAUFFMAN &. SIIILLING
ATfORNEYI Boward D. Kauffman, Esquire
SUPREME COURT LD. NO.1 38963
100 PINE STREET, SUITE 300
HARRISBURG, PI. 17101
(717) 720-0700
ATfORNEY FOR:
Defendant
KAREN J, ANDREWS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
VI
DONALD C. SIEG,
Defendant
DOCKET NO. 95-5160 CIVIL TERM
S:;ERTIFlCATE OF SERVICE
AND NOW, this Way of June. 1996, I, Howard D. Kauffinan, Esquire, attorney for
Defendant Donald C. Sieg affirm that I served the Notice of Deposition by depositing same in the
United States Mail, postage prepaid. in Harrisburg. Pennsylvania, addressed to:
Gregory R. Reed, Esquire
2423 North Third Street
Harrisburg. PA 17\10
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA
KAREN J. ANDREWS
: CIVIL ACTION - LAW
plaintiff
.
.
v.
: NO. 95-5160
I
I
Defendants: JURY TRIAL DEMANDED
DONALD C. SIEG
PLAINTIFF'S RESPONSE TO DEFENDANT'S MOTION TO STRIKE
FROM THE TRIAL LIST
1. Admitted.
2. Denied. An IME had been scheduled by Defendant for
september, 1996 with full knowledge that plaintiff intended to
list the case for trial. plaintiff's counsel had intended to
list the case for trial in' September, 1996 but chose not to at
the request of Defendant's counsel because Defendant's counsel
was going to be on vacation. A copy of Defendant's counsel's
letter agreeing to a November trial is attached hereto, marked
Exhibit "1" and incorporated herein by reference. The IME was
cancelled by Defendant or his insurance carrier without any
communication with plaintiff. plaintiff's counsel had nothing
whatsoever to do with the September IME being rescheduled for
January of 1997.
3. Admitted.
4. Defendant scheduled a second IME to be performed in
Wyomissing, pennsylvania at great inconvenience to Plaintiff.
Furthermore, the IME is scheduled for January 9, 1997, three and
one-half months (3 1/2) after the first IME was cancelled by
Defendant for no apparent reason. This is unreasonable and
represents dilatory conduct.
5. plaintiff respectfully requests this Honorable court to
keep th~s case on the trial list.
Respectfully submitted,
dr~e
Attorney for plaintiff
2423 North Third street
Harrisburg, PA 17110
(717) 238-0434
Attorney I.D. No. 23705
I
I
,
i
,i
CERTIFICATE OF SERVICE
AND NOW, this ~~ day of september, 1996, I, Gregory R.
Reed, Esquire, Attorney for plaintiff, does hereby certify that I
have served by first class mail, a copy of the attached
Plaintiff's Response to Defendant's Motion to strike From the
Trial List, this day to the following address:
Howard D. Kauffman, Esquire
Harrington, Kauffman & Shilling
100 pine street, suite 300
Harrisburg, PA 171001
cr~+ ,
Attorney for Plaintiff
2423 North Third street
Harrisburg, pennsylvania 17110
(717) 238-0434
Attorney 1.0. 23705
.
~.
LAW omCES OF
BARRINGTON, KAUFFMAN" SHILUNG
ATfORNEY: Howard D. Kauffman, Elqulre
SUPREME COURT LD. NO.: 38963
100 PINE STREET, SUITE 300
HARRISBURG, PA 17101
(717) 720-0700
ATIORNEY FOR:
Defendant
KAREN J. ANDREWS,
PlaintilT
IN THE COURT OF COMMON PLEAS OF
CUMBERLANDCOUNTy,PENNSYLV~A
v.
DONALD C, SmG,
Defendant
DOCKET NO. 95-5160 CIVIL TERM
pEFENDANT'S MOTION TO STRIKE FROM TilE TRIAL LIST
1. PlaintilT filed a Praecipe to list this case for trial on or about September 4, 1996.
However, a copy was not received by defense counsel until September 13, 1996.
2. Shortly before defense counsel went on vacation on September 13, 1996, defense
counsel infonned Plaintiff. counsel that although an lME was scheduled, the adjuster of the
Defendant'. insurance carrier wanted to resolve the case without further expense.. The 1MB was,
therefore, postponed.
3. Defendant has made an olTer to PlaintilTto resolve the case.
4. In the even the case is not resolved, defense counsel has scheduled an Independent
medical examination with Dr. EUi. Friedman for January 9, 1997.
5. The Defendant, therefore. respectfully request. this case be stricken from the trial
Ii.t until discovery Is completed,
Respectfully submitted.
HARRINGTON, KAUFFMAN & SHILLING
~~--
Howard D. KaulTman, Esquire
,
LAW OFFICES OF
BARRINGTON, KAUFFMAN & SHILLING
ATrORNEY: Howard D. Kauffman, E.qulre
SUPREME COURT LD. NO.: 38963
100 PINE STREET, SUITE 300
HARRISBURG, PA 17101
(717) 710-0700
A TrORNEY FOR:
Defendant
KAREN J. ANDREWS,
PIa1ntift'
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
DONALD C. sma,
Defendant
DOCKET NO, 95-5160 CIVIL TERM
~ERTIFlCATE OF SERVICE
AND NOW, this ~ day of {l;ZildA ~ ,1996, I, Howard D. KaulTman,
Eaquire, attomey for Defendant Donald C. Sicg affmn that I served the Motion to Strikeby
depositing aamc In the United States Mail, postage prepaid, In Harrisburg, Pennsylvania,
addressed to:
Gregory R. Reed, Esquire
2423 North Third Street
Harrisburg, P A 17110
Cout Administrator
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA
KAREN J. ANDREWS . CIVIL ACTION - LAW
.
Plaintiff .
.
.
.
v. I NO. 95-5160
DONALD C. SIEG I
Defendants . JURY TRIAL DEMANDED
.
-
ORDER
--.
AND NOW, this ____ day of
, 1996, in
consideration of Plaintiff's Motion In Limine, it is hereby
ORDERED AND DECREED that, at and during the trial of the above-
captioned case, no defense counsel, witness or exhibit shall
refer to, allude to, show, depict or refer to police officers or
police vehicles at Plaintiff's home.
J.
L-CA.-S C'
SC'\ r \t'<
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA
KAREN J. ANOREWf'I
: CIVIL ACTION - LAW
plaintiff :
v.
NO. 95-5160
DONALD C. SIEG
Defendants: JURY TRIAL DEMANDED
.
.
MOTION IN LIMINE
1. On Tuesday, October 15, 1996, Defendant's counsel gave
to Plaintiff's counsel a surveillance video together with a
written report of the private investigator's activities.
2. The video is approximately thirty-five (35) minutes
long.
3. A few minutes of the video includes the scene of a
police car at plaintiff's home and plaintiff talking to someone
in the police car.
4. The police were at plaintiff's home to speak to her
about her juvenile son, and his friend who used another friend's
pick-up truck.
5. The private investigator verified that the police were
not investigating plaintiff as evidenced by page B of his
surveillance Report, a copy of which is attached hereto, marked
.
Exhibit "I" and incorporated herein by reference.
6. The presence of a police vehicle and the apparent
questioning of Plaintiff on the surveillance video will be highly
prejudicial to Plaintiff if seen by a jury in that they could
wrongly and incorrectly conclude that plaintiff was under
.
investigation or being arrested for a crime.
7. The portion of the video showing the police vehicle is
very brief and do not show any conduct helpful to Defendant's
defense.
8. Defendant could easily edit the video with no prejudice
to his defense.
9. Allowing the video to show police vehicles or police
officers will require plaintiff to explain the incident thus
alluding to the identity of the juveniles.
WHEREFORE, plaintiff respectfully requests your Honorable
Court to enter an order preventing Defendants, during the trial
.
of this matter, from showing any portion of a video which
includes police officers or police vehicles and to further
prevent any defense witnesses from being asked or referring to
police officers or police vehicles at Plaintiff's residence.
~/1,/Y?{'
/
Gre ry R. Ree , Esqu re
Attorney for Plaintiff
2423 North Third street
Harrisburg, PA 17110
(717) 238-0434
East Coast luvestl~a ous,lue.
,
SURVEILLANCE REPORT
Subject: Andrews, Karen 1.
Claim II: 2600AL282368
DlA: 07/05/95
ECI file II: SH.00221-1
PAGE I
Injuries: Alleges right foot I ankle
Dates of investigation: 03106196 to the present
DETAn..s OF INVESTIGATION
Prior to conducting nei~hborhood handling and in order to more fully identify the subject and
to associate any vehicles WIth the subject, the following record sources were contacted:
PA DEPARTMENT OF MOTOR VEHICLES
Harrisburg, P A
Drivin~ Record Section: The subject is fully identified as Karen J. Andrews with a date of
birth of 07119/49. Records show Andrews' address as 420 Gellysburg Pike, Mechanicsburg, PA
17055.
yehicle Re~istration Section: Currently, we find two vehicles registered to Karen Andrews:
a 1983 Ford atat:on wagon bearing PA tag XGN-313 with an expiration date of 04/96 and a 1987
Volkswagen bearing PA tag AXG-323I with an expiration date of 05/96.
In checking with local Directory Assistance, we find a listing for a K. 1. Andrews at
420 Gellysburg Pike, Mechanicsburg, PA 17055 with a telephone number of (717) 691-1607.
.........................................................
SURVEILLANCE
Dale:
Time:
Weather:
Visibility:
03/14/96 (Thursday)
06:30 AM - 09:30 AM
Mostly sunny and cool
Good
Investigator:
SAS
.
06:30 AM Investigator proceeded to the subject's believed resident address located at
420 Gellysburg Pike, Mechanicsburg. PA 17055. Infonnatively, the subject's residence can best
be described as being a split level, individual residence with dark yellow exterior and blue and
white trim. This residence was set approximately 200 to 250 yards from the main road and not
visible from Gettysburg Pike. There was an allached garage at the left front of the residence and a
stoncldirt drive that lead from the main road to this garage. A walkway lead from the driveway to a
few wooden steps and a small wooden front porch which was surrounded by shrubs. There was
also a rear porch. This residence was located in a predominantly white, rural but developing area
and ap,peared to be in a fair state of repair. No outside activity was noted and a position of
surveillance was established along the subject's most likely avenue of exit.
09:00 AM In an effort to develop infonnalion regarding the subject, we made
inquiries at neighborhood residences with our results noted below:
EXHIBIT "1"
East Coast luvestl~a ous.lue.
SURVEILLANCE REPORT
PAGE 2
Subject: Andrews, Karen 1.
Claim II: 2600AL282368
D1A: 07/05/95
ECllile II: SH-00221-1
UNIDENTIFIED WHITE FEMALE
Vicinity of the 400 block of Gcllysburg Pike
Mechanicsburg, PA 17055
This source confirmed the subject's residence and stated "they work
during the day and the kids go to school", In closing, this individual mentioned that the
surrounding farmland belonged to her and not the Andrews. With no further information being
provided, our conversation was discontinued.
UNIDENTIFIED WHITE MALE
Vicinity of the 400 block of Gcllysburg Pike
Mechanicsburg, PA 17055
This individual had lived in the area for 30 to 40 years but was not
familiar with many of his neighbors, including the Andrews family. With no further information
being provided, our conversation was discontinued.
Other neighbors in the area were contacted but our inquiries met with negative results as no one
responded.
09: 15 AM In an attempt to positively identify the subject and determine her presence
within the residence, we made an inquiry at the 420 Gcllysburg Pike residence, We noted a blue
Ford station wagon with no tag parked to the left of the dwelling. After several knocks at the front
door of the residence, our inquiry went unanswered.
09:20 AM We placed a telephone call to the subject's residence utilizing telephone
numbcr (717) 691-1602 in an allemptto determine her presence inside. After numerous rings, our
call went unanswered.
.
09:30 AM Due to the above mentioned information and with the subject apparently
conducting her activities away from the residence, we discontinued surveillance.
.........................................................
SURVEILLANCE
Date:
Time:
Weather:
Visibility:
03/24/96 (Sunday)
07:30 AM .03:00 PM
Sunny and warm
Excellent
Investigator:
RJC
07:30 AM Investigator proceeded to the subject's resident address located at
420 Gettysburg Pike, Mechanicsburg, PA 17055. Upon arrival, a blue slation wagon wilh no tag,
II red Toyota pickup truck (tag obscured), a full sized Chevrolet station wagon (tag obscured) and a
gray Volkswagen lella bearing PA tag AXG-323I were all located in the driveway of the
residence. With no activity noted, a position most advantageous for surveillance was established.
East Coast 'u~'e8tlgaoa8. lae.
SURVEILLANCE REPORT
PAGE 3
Subject: Andrews, Karen J.
Claim II: 2600AL282368
[},A: 07/05195
ECI file II: SH-00221-1
09:24 AM A white female, believed to be the subject and who will be referred to as
such or Andrews hereafter, drove the gray Volkswagen Jella bearing PA tag AXG-323I from the
area and turned left onto Gettysburg Pike,
09:42 AM After utilizing Route 114 E and Lewlsberry Road I Route 382 S.the
subject arrived at the RED LAND VALLEY CHURCH. Andrews exiled the driver's side of the
vehicle and proceeded inside and out of view. Informatively. the subject can best be described as
being approximately 5'6" to 5'8" tall, weighing 130 to 140 pounds, with curly dark hair.
Andrews was allired in a light colored rain jacket, black sweater. white blouse, black pants. black
shoes and wore correclive eyeglasses. The subject wore no visible braces, utilized no visible
means of orthopedic support and appeared to move in a free and easy manner. It should be noted
that church services began at 10:30 AM and Sunday School at 09:30 AM,
(video obtained)
12: 16 PM Andrews exited the previously mentioned chulth and proceeded into the
driver's side of the Volkswagen ]ella. The subject then drove from the area.
12:35 PM After utilizing Lewisberry Road I Route 382 N. Route 114 W and
Ocllysburg Pike, Andrews arrived back at her residence. The subject exited her vehicle and
entered the residence out of view. .
01:30 PM Once again. the subject drove the Volkswagen ]elta from the area and
continued north on Gettysburg Pike.
01 :33 PM After utilizing Gellysburg Pike. Andrews arrived at a GIANT grocery
store. The subject exited the driver's side of the vehicle and entered the aforementioned store out
of view.
01 :55 PM Andrews exited the GIANT grocery store and proceeded across the
parking lot as she pushed a grocery cart.
01 :56.01 :57 PM The subject opened the trunk of the vehicle and loaded several bags of
groceries into lhe trunk. Andrews closed the trunk and pushed the cart across the parking lot. The
subject then walked back to the vehicle. entered and later drove from the area.
(video obtained)
02:00 PM
After utilizing Gellysburg Pike. the subject arri~ed back at the residence.
02:02 - 02:04 PM Andrews exited the vehicle. opened lhe trunk and placed the groceries on
the ground. The subject then carried the bags across the front lawn and inSIde the residence out of
view.
(video obtained)
02:23 PM An unidentified individual drove a while Volvo slation wagon (lag
obscured) into the subject's driveway. This individual exited the vehicle and enlered the subject's
East Coast I,.vestl,ca .oas.lne.
SURVEILLANCE REPORT
PAGE 4
Subject: Andrews, Karen J.
Clwm 1#: 2600AL282368
D/A: 07/05195
ECI file II: SH-00221-1
residence out of view.
02:36 PM Andrews and an unidentified individual exited the residence and walked to
the before mentioned Volvo, The subject entered the passenger side of the vehicle with the
previously mentioned individual entering the driver's side of the Volvo slation wagon. II should
be noted that the subject no longer wore the black swealer. The unidentified individual then drove
the vehicle from the area wilh the subject in the passenger seat.
(video obtained)
02:38 PM The aforementioned vehicle was lost from view due to a traffic control
device. A brief grid search of the area was conducted but met with negative results in that we
could not locate the white Volvo station wagon.
02:50 PM Investi~ator returned to the residence but we were unable to locate the
white stat.ion wagon in the vieimty of the residence.
03:00 PM Wilh the subject apparently conducting her activities away from the
residence, surveillance was discontinued.
RESULTS: Approximately 2 minutes of VHS-C videotape was obtained utilizing a
fully automatic Panasonic camcorder, equipped with a 120: I auto zoom lens.
.........................................................
Date:
Tunc:
Weather:
Visibility:
SURVEll..LANCE
03130196 (Saturday) Investigator: SAS
08:00 AM - 02:00 PM and 03:00 PM - 05:00 PM
Mostly sunny and mild
Good
08:00 AM Investigator proceeded tv the subject's resident address located at
420 Gellysburg Pike, Mechanicsburg, PA 17055. Upon arrival, we located the following vehicles
parked in the vicinity of the subject's residence: the previously mentioned blue Ford station wagon
(no tag), a two toned beigcJbrown Chevrolet station wagon (tag obscured), a dark pickup truck
with body work bearing PA tag ZF-75203 and the subject's associated gray Volkswagen lella
bearing PA tag AXG-323I. No outside activity was noted and a position most advanlageous for
surveillance was established,
10:00 AM In an allemptlo determine the subject's presence within the residence. we
placed a lelephone call to the residence utilizing telephone number (717) 691-1607. Our call was
answered by a female voice who identified herself as Karen Andrews. Our conversation was kept
brief and discontinued shortly thereafter.
10:02 AM
Two unidentified white males drove the dark pickup truck bearing PA tag
East Coast I.n..estl~a .ous.lo".
SURVEILLANCE REPORT
PAGE 5
Subject: Andrews, Karen 1.
Claim II: 2600AL282368
D1A: 01/05/95
EClfilell: SH.OO221.1
ZF.15203 from the area.
10:26 AM An Up~r Allen Township police department vehicle arrived at the
subject's residence. An unidenufied white male police officer exited his vehicle and entered the
subject's residence out of view.
10:36 AM The aforementioned Upper Allen Townshippolice officer exited the
residence, followed by the subject and entered the police vehicle.
10:31 AM Andrews stood at the driver's side of the police vehicle and appeared to
converse with the officer. A short time later, the subject walked to and entered the residence out of
view while the Upper Allen Township police officer drove from the area.
(video obtained)
1 1:46 AM Once again, an Upper Allen Township police department vehicle arrived at
the subject's residence. An unidentified white male police officer e:tited this vehicle with papers in
his left hand and walked toward the subject's residence out of view.
1 1:51AM Andrews and the Upper Allen Township police officer stood by the
passenger side of the police vehicle and conversed. Later. the subject walked to and entered her
residence via the front door as the Upper Allen Townsilip police officer entered and drove his
vehicle from the area. The subject was attired in a pink, long sleeved shirt, maroon pants and wore
corrective eyeglasses. Andrews wore no visible braces, utilized no visible means of orthopedic
supports or devices and appeared to move about in a free and easy manner. It should be noted that
there was laundry hanging on a clothesline in the rear yard,
(video obtai ned)
12: I I PM The two previously mentioned unidentified white males drove the pickup
trUck back into the area and parked in front of the residence. These two white males moved in and
out of view perfonning unidentified tasks to the pickup truck. It should be noted that the garage
door was now open.
12:19 PM An Upper Allen Township police department vehicle arrived at the
subject's residence. The Upper Allen Township police officer exited his vehicle and entered the
residence. It should be noted that only one of the unidentified white males was now working on
the pickup truck.
12:34 PM The Upper Allen Township police officer exited the subject's residence,
entered his vehicle and drove from the area. Once again. we noted both unidentified white males
moving in and out of view as they appeared to conduct body work on the aforementioned pickup
truck.
12:52- 12:51 PM Andrews exited the rear of the residence with various clothes and laundry
items and hung them on the line. The subject bent over numerous times and straightened up as she
raised her hands and arms above her shoulders to place the laundry on the line. Later, the subject
East Coast I.....el!itl~a ;oos,lu".
SURVEILLANCE REPORT
PAGE 6
Subject: Andrews, Karen J.
Claim II: 2600AL282368
DlA: 07/05195
ECI file II: SH-00221-1
walked toward the front of the garage and out of view briefly. Andrews walked in and out of view
on the left side of the residence and later entered the garage,
(video obtained)
01:00 PM A position most advantageous for surveillance was relocated on foot in a
nearby wooded area.
01:06 - 01 :26 PM During this time frame, the subject moved in and out of view as she
retrieved items from the garage and placed them to the left of the residence. Andrews bent over at
the waist numerous limes. at various degrees, as she reached and stretched 10 retrieve and place the
items outside the garage. At one point, the subject untangled and rolled up a hose inside the
garage. Sometime later, Andrews entered the residence out of view through a garage door.
(video obtained)
01 :34 . 0 1:40 PM D-Jring this time, the subject made numerouslrips from the rear of the
residence and carried or drug large unidentified items (possible carpeting) utilizing both hands and
placed them in a pile 10 the left of the garage. Later, Andrews carried two unidentified items
toward the aforementioned p'ickup truck where the two unidentified white males continued to work
on this vehicle. An unidenufied white female drove the aforementioned red Toyota pickup truck
(tag obscured) into the area and parked in front of the garage. The subject walked to the driver's
side of this vehicle, bent at the waist, straightened up and then spoke to the unidentified white
female who later exited the vehicle. Andrews walked into the garage out of view and into the
residence.
01:41 PM
door.
(video obtained)
The unidentified white female entered the residence through the garage
02:00 PM
discontinued.
Due to increased activity in the area, our surveillance was temporarily
03:00 PM We reestablished a {'Osition of surveillance on foot in a wooded area in the
vicinity of the subject's residence. Upon arnval, the subject's Volkswagen Jella was repositioned
as was the dark colored pickup truck. We also noted a blue Cadillac bearing PA tag XGN-313
parked in the driveway of the residence. It should be noted that the before mentioned red Toyota
pickup truck was no longer parked in the vicinity of the residence. No outside activity was noted
on the part of the subject, nor were any other individuals outside the residence.
03:09 PM An unidentified white male exited the residence, entered the
aforementioned blue Cadillac and drove it from the area.
03: I 5 PM The same unidentified white male drove the blue Cadillac bearing PA tag
XGN-313 into the area, parked in front of the residence, exited and entered the residence through
the garage.
. , '
East Coast ItI"estl_a .ous,lue.
SURVEILLANCE REPORT
PAGE 7
Subject: Andrews, Karen J.
Claim 1#: 2600AL282368
DlA: 07/05195
Eel file 1#: SH-00221-1
03: 17 PM The subject exited from the rear of the residence with a basket in her
hands and began to remove clothes from the line.
03:18 - 03:19 PM Andrews moved in and out of view as she removed clolhesllaundry from
the line. The subject placed some of the items on her shoulders and also bent over numerous times
to place the laundry inside the basket. Laler. Andrews picked up the basket. walked to and entered
the residence through the rear door out of view,
(video obtained)
03:21 PM The aforementioned unidentified while male exited the residence and
walked toward Gettysburg Pike out of view.
03:36 PM Another unidentified while female drove into the area in a blue Buick
bearing P A tag AXD-8502. She exiled the vehicle and entered the residence through the front
door.
03:56 PM The same unidentified white female exited the residence, removed a full
laundry basket from the Buick and reentered the residence.
03:58 PM The same unidentified white male walked into the area with an
unidentified item in his hand and enlered the garage,
04:00 PM At this time and throughout the afternoon. the unidentified white male
performed maintenance on the two toned Chevrolet station wagon which was parked in front of the
residence.
04: 18 PM The previously mentioned unidenlified white female drove the red Toyota
pickup truck into the area, parked near the residence, exited and entered the residence through the
front door.
04:32 PM The aforementioned unidenlified white female exiled from the rear of the
residence and hung laundry on the clothesline. She later rcenlered the residence.
05:00 PM
With the subject apparently confining her activities within the residence,
surveillance was discontinued.
RESULTS: Approximately 25 minutes and 45 seconds of VHS-C videotape was
obtained utilizing a fully automatic Panasonic camcorder, equipped with a 40: I auto zoom lens.
........................................................t
In an effort to develop infonnation regarding the Upper Allen Township police department's
involvement at the subject's residence, the following source was conlacted:
CERTIFICATE OF SERVICE
AND NOW, this ~ay of October, 1996, I, Gregory R. Reed,
Esquire, Attorney for plaintiff does hereby certify that I have
served by first class mail, a copy of the attached Motion In
Limine this day to the following address:
Howard D. Kauffman, Esquire
Harrington, Kauffman & Shilling
100 pine street, suite 300
Harrisburg, PA 17101
..~f..Ul'.
2423 North Third street
Harrisburg, pennsylvania 17110
(717) 238-0434
Attorney 1.0. 23705
IN THE COURT OF coMMON PLEAS OF CUMBERT~ COUNTY. PENNSYLVANIA
KAREN J. ANDREWS . CIVIL ACTION - LAW
.
plaintiff .
.
.
.
v. . NO. 95-516D
.
.
.
DONALD C. SIEG .
.
Detendants . JURY TRIAL DEMANDED
.
ORDER
AND NOW, this day of ' 1996, in
-
consideration ot Plaintitf's Motion In Limine, it is hereby
ORDERED AND DECREED that, at and during the trial of the above-
captioned case, no defense counsel, witness or exhibit shall
refer to, allude to, show, depict or refer to police officers or
police vehicles at plaintiff's home.
J.
IN THE COURT or COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA
KAREN J. ANDREWS
: CIVIL ACTION - LAW
plaintiff
.
.
v.
: NO. 95-5160
DONALD C. SIEG
.
.
Defendants: JURY TRIAL DEMANDED
MOTION IN LIMINE
1. On Tuesday, October 15, 1996, Defendant's counsel gave
to plaintiff's counsel a surveillance video together with a
written report of the private investigator's activities.
2. The video is approximately thirty-five (35) minutes
long.
3. A few minutes of the video includes the scene of a
police car at plaintiff's home and plaintiff talking to someone
in the police car.
4. The police were at plaintiff's home to speak to her
about her juvenile son, and his friend who used another friend's
pick-up truck.
5. The private investiga~or verified that the police were
not investigating plaintiff as evidenced by page 8 of his
surveillance Report, a copy of which is attached hereto, marked
.
Exhibit "1" and incorporated herein by reference.
6. The presence of a police vehicle and the apparent
questioning of plaintiff on the surveillance video will be highly
prejudicial to plaintiff if seen by a jury in that they could
~/~/Y?{
/
wrongly and incorrectlY conclude that Plaintiff was under
.
investigation or being arrested for a crime.
7. The portion of the video showing the police vehicle is
very brief and do not shoW any conduct helpful to Defendant's
defense.
B. Defendant could easily edit the video with no prejudice
to his defense.
9. Allowing the video to show police vehicles or police
officers will require Plaintiff to explain the incident thus
alluding to the identity of the juveniles.
WHEREFORE, Plaintiff respectfullY requests your Honorable
court to enter an order preventing Defendants, during the trial
.
of this matter, from showing any portion of a video which
includes police officers or police vehicles and to further
prevent any defense witnesses from being asked or referring to
police officers or police vehicles at plaintiff'S residence.
Gre ry R. Ree , Esqu~re
Attorney for Plaintiff
2423 North Third street
Harrisburg, PA 17110
(717) 238-0434
PAGEl
Subject: Andrews, Karen J.
Claim #: 2600AL282368
DlA: 07/05/95
ECI file #: SH-00221-1
Injuries: Alleges right foot I ankle
Dates of Investigation: 03106/96 to the present
DET An.'\ OF INVESTIGATION
Prior to conducting nei~hborhood handling and in order to more fully identify the subject and
to associate any vehicles with the subject, the following record sources were contacted:
PA DEPARTMENT OF MOTOR VEHICLES
Harrisburg, PA
Drivin~ Record Section: The subject is fully identified as Karen J. Andrews with a date of
birth of 07/19/49. Records show Andrews' address as 420 Geuysburg Pik.:, Mechanicsburg, PA
17055.
Vehicle Re~istration Section: Currently, we find two vehicles registered to Karen Andrews:
a 1983 Ford station wagon bearing P A tag XGN-313 with an expiration date of 04/96 and a 1987
Volkswagen bearing PA tag AXG-323I with an expiration date of 05196.
In checking with local Directory Assistance, we find a listing for a K. J, Andrews at
420 Gettysburg Pike, Mechanicsburg, P A 17055 with a telephone number of (717) 691-1607,
.........................................................
SURVEILLANCE
Date:
Tune:
Weather.
Visibility:
03/14/96 (Thursday)
06:30 AM - 09:30 AM
Mostly sunny and cool
Good
Investigator:
SAS
.
06:30 AM Investigator proceeded to the subject's believed resident address located at
420 Gettysburg Pike, Mechanicsburg, PA 17055. Informatively, the subject's residence can best
be described as being a split level, individual residence with dark yellow exterior and blue and
white trim. This residence was set approximately 200 to 250 yards from the main road and not
visible from Gettysburg Pike. There was an attached garage at the left front of the residence and a
stone/dirt drive that lead from the main road to this garage, A walkway lead from the driveway to a
few wooden steps and a small wooden front porch which was surrounded by shrubs. There was
also a rear porch, This residence was located in a predominantly while, rural but developing area
and ap,peared to be in a fair state of repair. No outside activity was noted and a position of
surveillance was established along the subject's most likely avenue of exit.
09:00 AM In an effort to develop information regarding the subject, we made
inquiries at neighborhood residences with our results noted below:
EXHIBIT "I"
East Coast lu",estllloCa oDs,IDe.
SURVEILLANCE REPORT
PAGE 2
Subject: Andrews. Karen 1.
Claim #: 2600AL282368
DlA:. 07/05195
ECIfile #: SH-00221-1
UNIDENTIFIED WHITE FEMALE
Vicinity of the 400 block of Gettysburg Pike
Mechanicsburg. PA 17055
This source conlinned the subject's residence and stated "they work
during the day and the kJds go to school". In closing. this individual mentioned that the
surrounding fann1and belonged to her and not the Andrews. With no further infonnation being
provided. our conversation was discontinued.
UNIDENTIFIED WHITE MALE
Vicinity of the 400 block of Gettysburg Pike
Mechanicsburg, P A 17055
This individual had lived in the area for 30 to 40 years but was not
familiar with many of his neighbors, including the Andrews family. With no further Infonnation
being provided. our conversation was discontinued.
Other neighbors in the area were contacted but our inquiries met with negative results as no one
responded.
09: IS AM In an altCmpt to positively identify the subject and detennine her presence
within the residence, we made an Inquiry at the 420 Gettysburg Pike residence. We noted a blue
Ford station wagon with no tag parked to the left of the dwelling. After several knocks at the front
door of the residence, our inquiry went unanswered.
09:20 AM We placed a telephone call to the subject's residence utilizing telephone
number (717) 691-1602 in an attempt to detennine her presence inside. After numerous rings, our
call went unanswered.
.
09:30 AM Due to the above mentioned Infonnation and with the subject apparently
conducting her activities away from the residence, we discontinued surveillance.
.........................................................
SURVEILLANCE
Date:
TlIllC:
Weather:
Visibility:
03/24/96 (Sunday)
07:30 AM .03:00 PM
Sunny and warm
Excellent
Investigator:
RlC
07:30 AM Investigator proceeded to the subject's resident address located at
420 Gettysbur~ Pike, Mechanicsburg. PA 17055. Upon arrival. a blue station wagon with no tag.
a red Toyota pIckup truck (tag obscured), a full sized Chevrolet station wagon (lag obscured) and a
gray Volkswagen Jetta bearing PA tag AXG-323I were all located in the driveway of the
residence. With no activity noted. a position most advantageous for surveillance was established.
East Coast 10vestllloCa .005. IDe.
SURVEILLANCE REPORT
PAGE 3
Subject: Andrews, Karen J.
Claim It: 2600AL282368
DlA:. 07/05195
ECI file H: SH-00221.1
09:24 AM A white female, believed to be the subject and who will be referred to as
such or Andrews hereafter, drove the gray Volkswagen Jena bearing PA tag AXG-323 I from the
area and turned left onto Gettysburg Pike.
09:42 AM After utilizing Route 114 E and Lewisberry Road 1 Route 382 5, the
subject arrived at the RED LAND V ALLEY CHURCH. Andrews exited the driver's side of the
vehicle and proceeded inside and out of view. Infonnatively, the subject can best be described as
being approximately 5'6" to 5'8" tall, weighing 130 to 140 pounds, with curly dark hair.
Andrews was attired in a light colored rain jacket, black sweater, white blouse, black pants, black
shoes and wore corrective eyeglasses. The subject wore no visible braces, utilized no visible
means of OIthopedic support and appeared to move in a free and easy manner. It should be noted
that church services began at 10:30 AM and Sunday School at 09:30 AM.
(video obtained)
12: 16 PM Andrews exited the previously mentioned church and proceeded into the
driver's side of the Volkswagen Jetta. The subject then drove from the area.
12:35 PM After utilizing Lewisberry Road 1 Route 382 N, Route 114 W and
Gettysburg Pike, Andrews arrived back at her residence. The subject exited her vehicle and
entered the residence out of view. .
01:30 PM Once again, the subject drove the Volkswagen Jena from the area and
continued north on Gettysburg Pike.
01 :33 PM After utilizing Gettysburg Pike, Andrews arrived at a GIANT grocery
store. The subject exited the driver's side of the vehicle and entered the aforementioned store out
of view.
01:55 PM Andrews exited the GIANT grocery store and proceeded across the
parking lot as she pushed a grocery cart.
01 :56 _ 0 I :57 PM The subject opened the trunk of the vehicle and loaded several bags of
groceries into the trunk. Andrews closed the trunk and pushed the cart across the parking lot. The
subject then walked back to the vehicle, entered and later drove from the area.
(video obtained)
02:00 PM
After utilizing Gettysburg Pike, the subject arrived back at the residence.
02:02 _ 02:04 PM Andrews exiled the vehicle, opened the trunk and placed the groceries on
the ground. The subject then carried the bags across the front lawn and inSide the residence out of
view.
(video obtained)
02:23 PM An unidentified individual drove a white Volvo station wagon (tag
obscured) into the subject's driveway. This individual exiled the vehicle and entered the subject's
.
East Coast bvestllloCa .00s,loe.
SURVEILLANCE REPORT
PAGE 4
Subject: Andrews, Karen J.
Claim It: 2600AL282368
DlA:. 07/05195
Eel file H: SH-00221-1
residence out of view.
02:36 PM Andrews and an unidentified individual exited the residence and walked to
the before mcntioned Volvo. Thc subjcct entered the passengcr ~ide of the vchlcle with the
previously mentioned individual cntcring thc driver's side of thc Volvo station wagon. It should
be noted that the subject no longer wore the black sweater, The unidentified individual then drove
thc vehiclc from the area with the subject In the passenger seat,
(video obtained)
02:38 PM The aforemcntioned vehicle was lost from view due to a traffic control
dcvice. A brief grid search of the area was conducted but met with negative results in that we
could not locate the white Volvo station wagon.
02:50 PM Investi$ator returned to the residence but we were unable to locate the
white station wagon in the vicimty of the residence.
03:00 PM With the subject apparently conducting her activities away from the
residence, surveillance was discontinued.
RESULTS: Approximately 2 minutes of VHS-C videotape was obtained utilizing a
fully automatic Panasonic camcorder, equipped with a 120: 1 auto zoom Icns.
.........................................................
Date:
T1/llC:
Weather:
Visibility:
SURVEILLANCE
03130196 (Saturday) Investigator: SAS
08:00 AM .02:00 PM and 03:00 PM .05:00 PM
Mostly sunny and mild
Good
08:00 AM Investigator proceeded to thc subject's resident address located at
420 Gettysburg Pike, Mechanicsburg, P A 17055, Upon arrival, we located the followin~ vchicles
parked in the vicinity of the subject's residence: the previously mentioned bluc Ford statton wagon
(no tag), a two toned belgelbrown Chevrolct station wagon (tag obscured), a dark pickup truck
with body work bearing PA tag ZF-75203 and the subject's associatcd gray Volkswagen Jetta
bearing PA tag AXG-3231. No outside activity was noted and a position most advantageous for
surveillance was established.
10:00 AM In an allcmptto determine the subject's presence within the residence, we
placed a telephone call to the residence utilizing telephone number (717) 691-1607. Our call was
answered by a female voice who identified hcrself as Karen Andrews. Our conversation was kcpt
brief and discontinued shortly thereafter.
10:02 AM
Two unidentified white males drove the dark pickup truck bearing PA tag
. .
~ast Coast In"estllloCa .005. IDe.
SURVEILLANCE REPORT
.
PAGE 5
Subject: Andrews, Karen 1.
Claim H: 26OOAL282368
DlA:. 07/05/95
ECI file /I: SH-00221-1
ZF- 75203 from the area.
10:26 AM An Up~r Allen Township police department vehicle arrived at the
subject's residence. An unidentified white male police officer exiled his vehicle and entcred the
subject's residence out of view,
10:36 AM The aforemcntioned Upper Allen Township pol ice officer exited the
residence, followed by the subject and entered the police vchicle.
10:37 AM Andrews stood at the drivcr's side of the police vehicle and appeared to
converse with the officer. A short time later, the subject walked to and entered the residence out of
view while the Upper Allen Township police officer drove from the area.
(video obtained)
11:46 AM Once again, an Upper Allen Township police department vehicle arrived at
the subject's residence. An unidentified white male police officer exited this vehicle with papers in
his left hand and walked toward the subject's residence out of view.
11:51 AM Andrews and the Upper Allen Township police officer stood by the
passenger sidc of the police vehicle and conversed. Later. the subject walked to and entered her
residence via the front door as the Upper Allen Township police officer entered and drove his
vchicle from the area. The subject was attired in a pink. long sleeved shin. maroon pants and wore
corrective eyeglasses. Andrews wore no visible braces. utilized no visible means of orthopedic
supports or devices and appeared to move about in a free and easy manner. It should be noted that
there was laundry hanging on a clothesline in the rear yard.
(video obtained)
12: II PM The two previously mentioned unidentified white males drove the pickup
truck back into the area and parked in front of the residencc. These two white males moved in and
out of view perfonning unidentified tasks to the pickup truck. It should be noted that the garage
door was now open.
12: 19 PM An Upper Allen Township police department vehiclc arrived at the
subject's residence. The Upper Allen Township police officer exiled his vehicle and entered the
residence. It should be noted that only one of the unidentified while males was now working on
the pickup truck.
12:34 PM The Upper Allen Township police officer exited the subject's residence,
entcred his vchicle and drove from the area. Once again. we noted both unidentified whitc malcs
moving in and out of view as they appeared to conduct body work on the aforemcntioncd pickup
truck.
12:52- 12:57 PM Andrews exited the rear of the residence with various clothes and laundry
items and hung them on the line. The subject bent ovcr numerous times and straightened up as she
raised her hands and arms above her shoulders to place the laundry on the line. Later, the subject
East Coast luvestllloCa .ous. IDe.
SURVEILLANCE REPORT
PAGE 6
Subject: Andrews, Karen J.
Claim It: 2600AL282368
DlA:. 07/05195
Eel file H: SH.00221.1
walkcd toward the front of the garage and out of view briefly. Andrews walked in and out of vicw
on the left side of the residence and later entcred the garage,
(video obtained)
01 :00 PM A posilion most advantageous for surveillance was relocated on foot in a
nearby wooded area.
01:06 - 0 I :26 PM During this time frame, the subject moved in and out of vicw as she
retrieved ilems from the garage and placed them to the left of the residence. Andrews bent over at
the waist numerous timcs, at various degrees, as she renchcd and stretched 10 retrieve and place the
ilems outside the garage. At onc point, the subject untangled and rolled up a hose inside lhe
garage. Sometime later, Andrews enlered the residence out of view through a garage door.
(video obtained)
01 :34 - 0 1:40 PM During this time, the subject made numerous trips from the Orear of thc
residence and carried or drug large unidentified ilems (possible carpeting> utilizing both hands and
placed them in a pile to the left of the garage. Later, Andrews carried two unidentified items
toward the aforementioned p'ickup truck where the two unidentified white males continued to work
on this vehicle. An unidentified while female drove the aforementioned red Toyota pickup truck
(tag obscured) into the area and parked in front of the garage. The subject walked to the driver's
side of this vehicle, bent at the waist, straightened up and then spoke to the unidenlified white
female who later exited the vehicle. Andrews walked into the garage out of view and into the
residence,
01:41 PM
door.
(video obtained)
The unidentificd white femalc entered the residence through the garage
02:00 PM
discontinued.
Due to increased activity in the area, our surveillance was temporarily
03:00 PM We reestablished a position of survcillance on foot in a wooaed area in the
vicinity of the subject's residence. Upon amval, the subject's Volkswagen Jena was reposilioned
as was the dark colored pickup truck. We also noted a bluc Cadillac bearing PA tag XGN-313
parked in the driveway of the residence. It should be noted that the before mentioned red Toyota
pickup truck was no longer parked In the vicinity of the residence. No outside activity was noted
on the part of the subject, nor were any other individuals outside the residence.
03:09 PM An unidentified white male exiled lhe residence, entered the
aforementioned bluc Cadillac and drove it from the area.
03: I 5 PM The same unidentified white male drove the blue Cadillac bearing PA tag
XGN-313 inlo the area, parked in front of the residence, exited and entered the residence through
the garage.
.
., .
East Coast 11l"estllloCa .00s.lue.
SURVEILLANCE REPORT
PAGE 7
Subject: Andrews, Karen J.
Claim It: 2600AL282368
DI A:. 07105195
ECI file II: SH-00221.1
03: 17 PM The subject exited from thc rear of the residence with a baskct in her
hands and began to remove clothes from the line.
03:18.03:19 PM Andrews moved in and out of view as she removed c10thcsllaundry from
the line. The subject placed some of the items on her shoulders and also bent ovcr numcrous times
to place the laundry inside the baskct. Later, Andrews picked up the basket, walked to and entered
the residcnce through thc rear door out of view. .
(video obtained)
03:21 PM The aforementioned unidentified white male exited the residence and
walked toward Gettysburg Pike out of view.
03:36 PM Anothcr unidentified white female drove into the area in a blue Buick
bearing PA tag AXO-8502, She exited the vehicle and entered the residence through the front
door.
03:56 PM Thc same unidentified white female exited the residence, removed a full
laundry basket from the Buick and reentcred the residence.
03:58 PM The same unidcntified white male walked into the area with an
unidentified itcm in his hand and cntered the garage.
04:00 PM At this time and throughout the afternoon, the unidentified white male
perfonned maintenance on the two toned Chcvrolet station wagon which was parked in front of the
residence.
04: 18 PM The previously mentioned unidentified white female drove the red Toyota
pickup truck Into the area. parked near the residence, exited and entered the residence through the
front door.
04:32 PM The aforemcntioned unidentified white female exited from the rear of the
residcnce and hung laundry on the clothesline, She later reentered the residence.
05:00 PM
With the subject apparently confining her activities within the residcnce,
surveillance was discontinued.
RESULTS: Approximately 25 minutes and 45 seconds of VHS-C videotape was
obtained utilizing a fully automatic Panasonic camcorder, equipped with a 40: I auto zoom lens.
.........................................................
In an cffort to develop infonnation regarding the Upper Allen Township police departmcnt's
involvemcnt at the subject's rcsldcncc, the following source was contacted:
OCT 2 ? fQgfJ.ff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANYA
KAREN J. ANDREWS . CIVl:L ACTION - LAW
.
Plaintiff .
.
.
.
v. . NO. 95-5160
.
.
.
DONALD C. SIEG .
.
Defendants . JURY TRIAL DEMANDED
.
ORDER
AND NOW, this ____ day of , 1996, in
consideration of Plaintiff's Motion In Limine, it is hereby
ORDERED AND DECREED that, at and during the trial of the above-
captioned case, no defense counsel, witness or exhibit shall
refer to, allude to, show, depict or refer to police officers or
police vehicles at Plaintiff's home.
J.
.'
LAW omcr.s OF
ILUUUNGTON. KAUFPMAN A SBlLLING
ATrOIlNEYI B_ard D. Kaufl'.... Eaqulre
SUPRJ:MJ: COURT LD. NO.1 31963
100 pINJ: STREET, sum 300
IIAlUUSBURG. PA 17101
(717) 7ZM700
ATrORNEY FOR:
Deleada.t
KAREN J. ANDREWS,
plaintIlf
IN nIB COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VI
DONALD C, SIEG,
, ~,'lt
DOCKET NO. 95-5160 CIVIL TERM
CERTIFICATE OF SERVICE
('. .':; AND NOW, this /:IJ!: day of ~ 1997, I, Howard D. Kauffman,
EsquIre, attorney for Defendant Donald C. Sicg affirm that I served the Praecipe by depositing
ume in the United States Mai1, postage prepaid, in Harrisburg, Pennsylvania, addreued to:
Oresory R. Reed, Esquire
2423 North Third Street
Harrlaburs. PA 1711 0
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