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HomeMy WebLinkAbout95-06459 " !; " ~ (\ " , " ',' ,1 I I 1'1 , 'i , , " , , , ," ' ,:11/,/ ,1(' '~". ,. II' '- "\'i~i' /' I' , I} ',I " , , .t I, " " " '/"/1 ,.;;1- r, i I 'I '" " '" ! 'I! :,1 I , ' il'-I'I " , I' " , , ' , I' , , , I' , " , ,',I " .. (I " , , , ,,' I' ,.Hi " \ " I' " " , ", Ii! IU , I :1 i' I'i 1,1 I . ,~ )! ,jj " I! , , " I,' I, ,', '1\1i 'J '....,' II. I'"~ ,,' , , i,J. '/ !",I ,1;; \it " , I "I,' Ilii , I, " I"! , " " I " 'I"~ rl'I'/ , , , , , 11 .', , ",I " " 'I,d I' !I '"I 1'1' I, ,i " " Ii' , ,i) t ,~ ,I " ',' , , , , ,,' I \ 'I, " " " II , " tl.; ',i , .d' 'Ir "1 l.l; ,'1,1, " " '" " ," , I " " 0"1 "I' " , " I, .) , II! " " "II, 'I 1,1\ " " , , , I, ,I" " "I, " ,I .il , , , " , " '.,1 " I, 'I ',It'I' !'Il;l.; ,1,;- '.,1. 1"\:,;':,' . , , , , ' ill,I!-', ~,,: , lil.' '" " , " " " II' , \,1. I' "J' I': ,I, _,I " , " :1' ''''1 " " " 1,1 , " 11, , " II' I" " ,j;, " " " " , , I' I, , , , " I " I I, 1" I, " !':I " , i , '" " " ',i L(,; " !I, " ,!t.i',' r ',I I',' , , ';j" " , , " , , " "'1'1 ;', " , 2:' , 'l!). ,d , j'I'I_l'. :r!' ,lQ' ~il " ';1 , , , , Ii, I' -'I , " 'I , , ': , " ,I ,,, " " " ,iI \ " I, " ,1'1 " L , , n r I '" II, , ' , ,i' I, I.,' I I' \' I, ,'y, " 1,\ II ,,' " , " ,d Ilj,. , BOWARD POTTEIGER, Pla int if f IN THE COURT OF COMMON I?LEAS OF CUMaEI~LAND COUNTY, PBNNOYL'/ANIA and BOWARD AND ANQBLA PO~rEIQER, Natural Parente of ALYSSA M, and JOSHUA R. PO'l'TE IOBR, P.laintHfs NO, tIS' - c, Lf 5"1 d.~ 1L\'~- VS, HOWARD STUCK, Defendant ACTION - LAW JURY TRIAL DEMANDED NOTICE YOU HAVE BEEN SUBD IN COURT. If you wish to defend againet the claims set fort;h in the follol'ling pagee, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney llnd 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 eo 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 TAKB THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORl) ONE, GO TO OR TBLEPHONE 'rHE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, COURT ADMINISTRATOR FOURTH Ft,OOR 1 COURTHOUSE SQUARE CARLISLE, PENNSYLVANIA 17013-3387 (717) 240-6200 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas eiguintes, usted tiene viente (20) dies de plaza al partir de la techa de la demanda y la notificacion. Usted debe presentar una apariencia elcrita 0 en persona 0 por abogado y archivar en 1a corte en torma escri,ta llUS detensas 0 /IUS objeciones alas demandas en contra de su persona, Sea aviaado que /Ii usted no /Ie detiende, 1a corte tomera medidas y puede entrar una orden ~ontra usted sin previo avi/lo 0 notiticacion y por eualquier quejn 0 a1ivio que e/l pedido en 1a petie ion de demanda. Usted puede perder dinero 0 sus propiedade/l 0 otros derec~os importantes para u/lted. LLBVB BSTA OBMANDA A UN ABOGADO 1MMBD1ATAMBNTE, 81 NO T1BNS ABOOAOO 0 SI NO TIBNE BL OINERO SUFIC1EN1'E DE PA(JAR TAl, SERVT.CIO, VAYA BN PBRSONA Q LLAME POR TEI,SFONO A LA OF1CINA CUYA DIRBCC10N SB ENCUBNTRA BSCRITA ABAJO PARA AVERIGUI\R DONDE SIf, PUBDE CONSEGUIR ASISTBNCIA LBGAL. COURT I\DMINIS'rRA'rOR FOURTH FLOOR 1 COURTHOUSE SQUARE CARLISLE, PENNSYLVANIA 17013.3387 (717) 240-6200 " , ' " , I ,I , , BDWARD POT1'BIGBR, Plaintiff IN THB COURT OF COMMON PLEAS OF CUMBBRLAND COUNTY / PENNSYLVANIA and BOWARD AND ANGELA POTTBIGBR, Natural parents of ALYSSA M. NO. and JOSHUA R, POTTEIGBR, Plaintif.fs vs. HOWARD STUCK / Defendant ACTION . LAW JURY TRIAL DEMANDED COMPLAINT 1. Plaintiff Edward Potteiger is an adult individual residing at 1606 Letchworth Road, Camp Hill, Cumberland County, Pennsylvania 17011, 2, Plaintiffs F.:dward Potteiger and Angela Potteiger are husband and wife residing at 1606 Letchworth Road, Camp Hill, Cumberland County, Pennsylvania 17011 and are the parents of Alyssa M, potteiger, born March 3, 1993, and Joshua R. Potteiger, born August 14, 1994 with whom they reside, 3. Defendant Howard Stuck is an adult individual residing at 894 Woodbury Road, York, York County, Pennsylvania, 4, On May 28, 1995, at approximately 4:35 P.M., Plaintiff Edward potteiger was operating a 1990 Chevrolet in Bast pennsboro Township, Cumberland County, Pennsylvania. 5, Plaintiff Edward Potteiger'S two children, Alyssa M. and Joshua R, Potteiger, were riding as passengers, Joshua being in the 1 back left seat and Alyssa being in the back right seat. aoth were wearing safety restraints. 6, Said vehicle was being driven in a Boutherly direction on S,R, 15 approaching the exit to S.R. 581. 7, At said date and time Defendant wall driving a 1992 Oldsmobile in a southerly direction on S.R. 15. 8, At said date and time the Plaintiff was in the Bouthbound right lane on S.R, 15 behind the Defendant. 9. As the Plaintiff approached the ramp to S,R. 581 the Defendant went into the left lane and slowed down. 10, The Plaintif t slowed down as well, at which time the Defendant increased his speed and moved across from the left lane into the path of the Plaintiff who was travelling southbound in the right hand lane. 11. The Defendant's vehicle r.:ollided with the Plaintiff I S vehicle hitting the driver side of. the car and pushing the Plaintiff's car off of the road and into a road sign. 12. Said negligent acts of the Defendant caused said collision which resulted in injuries to Plaintiff and Plaintiff's two minor children, namely, Alyssa M. and Joshua R. potteiger. 13, At the time of said accident, the negligence of the Defendant consisted of the following: a) Driving too fast for conditionsl b) Speeding; 2 0) Dd ving from the left hand lane into the right hand I ~: I lane I , , t,1) rail in9 to keep a careful and dili.gent watoh on the roadwayr e) railing to slow or to bring hill vehicle to a stop so as to avoid the impact with the Plaintiff I s vehicler f) railing to maintain his vehicle under proper and adequate control at the timer g) operating his automobile without due regard for the rights, safety, well-being, and position of plain- tiffs under the aforesaid circumstancesr and h) Failing to use his turn signalsr i) Such other acts of negligence, carelessness Iilnd recklessness as may be determined thr.ough the process of discovery and at trial, COUNT I BDWARD POTTEIGER v, HOWARD STUCK Negligence 14. Paragraphs 1 through 13 of this Complaint are incorpor- ated herein by reference as if set forth at length. 15. Due to the negligence of the Defendant, as aforesaid, Plaintiff suffered the following injuries, which were and are 3 ..dou. t a) Neok sprain, b) Shoulder sprain I 0) Lcw baok sprain I d) Muscl" strain in the lower backr and e) Muscle sprain of the lower back. 16. All of the aforesaid injuries were caused solely by the Defendant, acting and failing to act, as aforesaid, and were in no way caused by any' act, or failure to act, on the part of plaintiff, 17 . As a further resul t of the conduct of Defendant, as aforesaid, Plaintiff has Buffered medically determinable physical impairn~nts which have prevented him, and continues to prevent him, from performing all of the normal acts and duties which constitute his usual and customary and daily activities. 18, As a further resul t of the conduct of the Defendant;, plaintiff lost considerable work because of his injuries at his usual employment at Christian publication. 19, As a further result of the conduct of the Defendant, Plaintiff has incurred substantial medical expenses to treat his injuries suffered in said accident and will contj,nue to incur medical expenses for the treatment of said injuries, all due to Defendant's negligence. 20, As a further result of the conduct of the Defendant, 4 Plaintiff haa experienced severe pain and SUffering, mental anguillh and humiliation and, in the future, may continue to do so, WHBRBPORB, Plaintiff demands judgment against Defendant i.n an amount in excess of Twenty Thousand ($20,000) Dollan, plus interest and costs, CQUNT II BOWARD AND ANGELA POTTBIGBR, Natural Parents of ALYSSA M. POTTEIGER 21. Paragraphs 13 through 20 of this complaint are incorpor- ated herein by reference as if set forth at length, 22, As a result of the conduct of Defendant I Alyssa M, potteiger suffered and has suffered pain and suffering, mental anguish ~nd humiliation, faar, and 1n the future, may continue to do so. 23. All of the aforasaid injuries were caused solely by the Defendant, acti.ng and failing to act, as aforesaid, and were in no way caused by any act, or failure to act I on the part of Plaintiff, WHEREFORE Plaintiffs demand judgment against Defendant in an amount in excess of Twenty Thousand ($20,000) Dollars, plus interest and costs, 5 COUN'J' II t SOWARD AND ANGELA POTTEIGER, Natural Parents ot JOSHUA R. POTTEIGER 24, Paragraphs 21 through 23 of this Complaint are incorpor- ated herein by r.eference as if Bet forth at length. 25, AB a result of the conduct of Pefendant, JOBhua R, Potteiger BuUered and has fluf fered pain amt Buf faring, mental anguish and humiliation, fear, and in the future, may continue to do eo, 26, All of the aforesaid injuries were caused solely bY the Oetendant, acting and failing to act, as aforesaid, and were in no way caueed by any act, or failure to act, on the part of Plaintiff. WHERBFORE, Plaintiffs demand judgment against Defendant in an amount in excess of Twenty Thousand ($20/000) Dollars, plue interest and costs, COUNT IV NEGLIGENT INFLICTION OF EMOTIONAL DISTRBSS 27, Paragraphs 24 through 26 of thiB Complaint are incorpor- ated herein by reference as if set forth at length, 28. AB a result of the conduct of the Defendant, Plaintiff experienced substantial emotional distress, anguish, fear and anxiety because his children who were injured aB Bet forth above 6 . ~ t . ). ,... ~ \$ ~ .~ - ~ ,... " "- ... '"'If f"\ , .. Bt~ ~ ~~ I'" e ., , o lJ) ~ '. ....) ::t-- ~ 't :') ';'~ " , " ! . 'I' " I , I ., '.'1 . , ., " . " ]I , \, ., ", :!, , SHERIFF'S RETURN - OUT OF COUNTY CASE Nul 19ge-064e9 P 88Dn~VW~~L~tl"i~Rr~"~SYLVANIAI i,' ~TT~IQER EDWARD ET AL VB. . I2TUCK HOWARD R. Thoma. Klin~ . Sheriff, who b~ing duly 8worn ac~crding to law, .ay., that he made ~ diligent aearch and inquiry for the vithin ,i named defendant, to wit I STUCK HQWARD but va. un.blll to 100ate __ Him deputized the 8h~riff of YORK to .erYe the within CO"PLAINT in hie bailiwiok. He therefore County, Penneylvania. On Deoember 14th. 1995 the attached return from YORK . thin offioe was in receipt of County. Pennsylvania. Sheriff'. CostBI Dock..ting Out of County Surcharge YORK COUNTY 18.00 9.00 2.00 16.00 So answey. I ,;<,.j..,;.____,h~ lr."'nio~8H iu: ;ne. ,",...-r;.:.,.;' Sheriff 845.00 L. REX BICKLEY 12/14/1995 Swcrn and Bub8cribed to before me thh ,k-!::. day of ~'n..t<. --' 19 q( A.D. Ch'~ Qr~~~~' .. . . I."I.OII.~'.''''''''''''' "..,.... .'. ,'.. ,'.." i. In The Court or C.:'mmon Flac:s or C:.Jt',::':~"It'I=nd c.;.:lu:-t~.y, Pannsyl'lc:nla Itdwllrd l'ot:telger Iwd ~~dwelr<l & Angelll "ol:leluer, Nlltllr1l1 I'llrl!nt:a of AJYIIBII M. nnd .JOBhllll/s~l. Pottelger Boward fltllck ~Ol 'I ') - (,4 5'J C 1 ~.!.l '1' Q rill ---. '0 ."- ;.rClW, Novell1bl;lr 14. 199~ ~g_ I. S~':F 0'5' Cmr.Bz:iU.A.'ro COt.~'l"Y, PA.. ~Q York ~W1rr 10 =.IlC :!:la W:!t, h=-by cieru= rbo SbcJ4 al t':Ls ~u=CDu btb{ ~ ill t3 r::jUCSt =i ~.Jk Clf :h= ~W::C5. ...,,,.-r.' .~ r'" f::tt'.;?--J<'.. :.cI~ ShIll'U! at ~u:::!llllU.lld C~W1t7. Plio Afiidl!l.nt or Sem= ;.row, , !9 . ~t Cl'.:!aa ~[. a=:".-d :!:ewltl:!n . 'lplD ~c 'by \.,,"rfl..'g to " c:::py of ce a rioi=-'ll .. :I.IId c:w:c lcl.owu :0 :he ..::cne:u:s t..~l:::':{. So 1ImW=' SI1c:6 of Cowu.,. P:a. Sworu 0:1.1I11 Illl::sc::bed bc!Ol'tl == :!:!s _ ~y af 19_ ccsrs SD.V1CZ ~CI:U:AGE ,""-:"7!DA vrr s """'---- s r_.~ . Sheriff's Office of York County KENNITH L. MARKaL . IlHUI" IOWAI'D o. ROIERTS IOUCITO" loon .. SHEWELL CHII' DI'UTY 'i. .,~ YOIlK COUNTY COUIlT ItoUI. YORK, PA. mOl EDWARD I'01'rEIGER / E'1' All ., VS. , Ha-Il\llD STUCK WALLIS W. RHItI. "UL IlrArl DI'UTY I t I I I I I I I I I I I I I I I I I I IN 'l'HE COU~ OF ~ PLEI\S CUMBERLAND C'OUN'l'V, PENNSYLVANIA NO. 95-6459 I\FPIDAVIT OF SERVICE I, Kenneth L. Markel/ Sheriff of the County of York, Commonwealth of Penneylvania, after diligent search and inquiry as to the defendant, Howard stuck, the w.lthin named defendant, do hereby return, C'OIlillaint, NOr FOUND in !lork County, Defendant is deceased. Sheriff's Cost $16.00 So Answers, ~~ SHERIPF COUNTY OF YORK SWorn and subscribed to before me this 1st day of December 1995 ultdIh It! IlL. NOTARIAL SEAL W.1II1 W. Rhine. NOIIIV Public 'I'orIl. VoIll County, Penn,vlv.nl. Mv t:ommllllon IIopl,... Milch 25. 1 S99 IJDWJ\RD pO'r'l'JJ:lGl~H, Pla.lntiff IN 'l'IIL'l CO@'l' Ol!' COMMON l'I.,EI\S OF CUMBlERLANP COUN'l'Y, l'llNNSU,yJ\NIA and EDWARD ANP ANGELA pOT1'BIG2R, Natural Parents of ALYSSA M. and JOSHUA R. pO'l"1'B IGER, plaintiffs NO. '1.s- - ~ IfS-? ~)..~ T~'vl.-/ vs. HOWARD STUCK, Defendant ACTION - LAW JURY '1'RIAL DBMANDED t10'rIC6 YOU HAVB BEEN SUED IN COUR'1'. If you wish to defend against the claims set forth in the following pages, you must take act.ioll within twenty (20) days after this Complaint and Notice are served, by entering a wdtte>n 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 th(~ Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or othet' rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU PO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TEI,EpHONE TilE OFFICE SE'1' FOR'rH BEI.OW TO FIND OUT WHERE YOU CAN GET LBGAL HELl? COURT ADMINISTRATOR FOURTH FLOOR 1 COURTHOUSB SQUARB CARLISLE, PENNSYLVANIA 17013-3387 (717) 240-6200 NOTICIA Le han demandado a usted en la corte, Si usted quiere defenderse de estas demandas expuestas en las paginas siguintes, usted tiene viente (20) dias de plaza al partir de la fecha de la demanda y la notificacion. Usted debe preflentar una apariencia TRUE COpy FROM RECORD In Testimony whereof, I here unto set my hand and ltIe aeal 01 said Col.Ir.t al Carlisle, P,il. ~,~~ ~t-~~li. Q'J(~lft~ 1~~. .} ProthonotlllY SOWARD pQ'rTE IGIER, plaintiff IN 'rillE CQUR'1' OF C()MMON Pl,EAS OF CUMBERLAND COUN'l'Y, PENNSY1,vANIA and EDWARD AND ANGELA PO'l'TEIGER, Natural parents of ALYSSA M. NO. and JOSHUA R. PO'l'TBIGBR, Plaintiff.s vs. HOWARD STUCK, Defendant ACTION - LAW JURY TRIAL DEMANDED COMPLAINT 1. Plaintiff Edward potteiger is Bn adult individual residing at 1606 Letchworth Road, Camp lIill, Cumberland County, Pennsylvania 17011. 2, plal,ntiffs I3dward potteiger and Angela potteiger are husband and wife residing at 1606 Letchworth Road, Camp lIill, Cumberland County, Pennsylvania 17011 and are the parents of Alyssa M. potteiger, born March 3, 1993, and Joshua R, potteigor, born August 14, 1994 with whom they reside, 3. Defendant Howard Stuck is an adult individual residing at 894 Woodbury Road, York, York County, Pennsylvania. 4. On May 28, 1995, at approximately 4:35 P.M" Plaintiff Bdward potteiger was operating a 1.990 Chevrolet in Bast Pennshoro Township, Cumberland County, Pennsylvania. 5. Plaint~ff Edward potteiger's two children, Alyssa M. and Joshua R. potteiger, were riding as passengen, Joshua being in the 1 back. len seat and Alyssa being in the back right seat, Both were wearing safety restraints. 6, Said vehicle was being driven in a southerly direction on S.R, 15 approaching the exit to S.R. 581. 7. At said date and time Defendant was driving a 1992 Oldsmobile in a southerly direction on S.R. 15. 8. At said date and tJ'lle the Plaintiff was in the southbound right lane on S,R. 15 behind the Defendant, 9, As the Plaintiff approached the ramp to S.R. 581 the Defendallt went into the left lane and fllowed down. 10. 'I'hl!! plaintiff slowed down as well, at which time the Defendant increased hi~ speed and moved across from the left lane into the path of the plaintiff who was travelling southbound in the right hand lane. 11. The Pefendant' s vehicle call ided with the plaintiff I S vehicle hitting the driver side of the car and pushing the plaintiff's car off of the road and into a road sign. 12. Said negligent acts of the Defendant caused said collision which resulted in injuries to plaintiff and Plaintiff's two minor children, namely, Alyssa M. and Joshua R. potteiger. 13. At the time of said accident, the negligence of the Defendant consisted of the following: a) DrivJ.ng too fast fOl- conditionSI b) Speeding; 2 0) Driving ~rom the le~t hand lane into the right hand lanel d) Pailing to lteep a car('jful and dil igent watch on the roadway I e) Failing to slow or to bring his vehicle to a stop so as to avoid the impact with the plaintiff's vehiclel f) Pailing to muintain his vehicle under propel' and adequate control at the time; g) operating his automobile without due regard for the rights, safety, well-being, and position of plain- tiffs under the aforesaid circumstances; and h) Failing to llse hJ.s turn signals; i) Such other acts of negligence, carelessness and recklessness as may be determined through the process of discovery and at trial, ~OUNT I EDWARD POTTEIGER v. HOWARD STUCK Ne9ligence 14. Paragraphs 1 through 13 of this Complaint are incorpor- ated herein by reference as if set forth at length. 15. Due to the negl igence of the pefendant, as aforesaid, plaintiff suffered the following injuries, which were and are 3 Beri~ulll a) Neck sprain, b) Shoulder sprain, c) Low back Bprainl d) Muscle strain i.n the lower baolq and e) Muscle sprain of the lower back. 16. All of the afor.esaid injuries were caused solely by the Defendant, acting and failing to act, as aforesaid, and were in no way caused by any act, or failure to act, on the part of plaintiff. 17. As a fur.ther result of the conduct of Defendant, as aforesaid, plaintiff has lIuffered medically determinable physical impairments which have prevented him, and conl;inues to prevent him, from performing all of the normal acts and duties which constitute hill ullual anll cllstomary and daily activities, 16. fIB a further result of the comiuct of the Defendant, Plaintiff lost considerable work becauue of his injuries at his usual employment at Christian publication. 19. AB a further resul t of the conduct of the Defendant I Plaintiff has incurred substantial medical expenses to treat his injuries Buffered in said accident and will continue to incur medical expenses for the treatment of said injuries, all due to Defendant' B negligence, 20. AB a further result of the conduct of the Defendant, 4 ~,I i,) i'l I,', I, ) , , Plaintiff has experienced oevere pain and BUffering, mental anguish and humiliation and, in the future, may oontinue to do so. WHBRBJ.l'ORB, Plaintiff demands judgment against Defendant in an amount in excess of Twenty Thouesnd ($20,000) Dollars, plus interest and costs. COUNT I I EDWARD AND ANGBLA POTTBIGBR, Natural Parents of ALYSSA M. POTTBIGBR 21. Paragraphs 13 through 20 of this Complaint are incorpor- ated herein by reference as if set forth at length. 22. As a reoult of the conduct of Defendant, Alyssa M. Potteiger suffered and has suffered pain and SUffering, mental anguish and humiliation, fear, and in the future, may continue to do so. 23, All of the aforesaid injuries were caused solely by the Defendant, acting and failing to act, as aforesaid, and were in no way caused by any act, or failure to act, on the part of Plaintiff. WHBREFORB, Plaintiffs demand judgment against Defendant in an amount in excess of Twenty Thousand ($20,000) DOllars, plus interest and costs, 5 COtJllT II I , EDWARD AND ANGELA Po~rEIGB~, Notu~al Pa~ents of JOSHUA R, PO~rBIGBR ~4. Paragraphs 21 th~ough 23 of this complaint a~e inaorpor~ ated herein by reference as if set forth at length. 25. As l\ result or. the conduct of Defendant, Joshua R, potteiger suffered and has suffered pain and suffering, mental anguish and humiliation, fear, and in the future, may continue to do so. 26. All of the aforesaid injuries were aaused solely by the Defendant, acting and failing to act, as aforesaid, and were in no way caused by any act, o~ failure to act, on the part of Plaintiff. WHBRBFORE, Plaintiffs demand judgment against Defendant in all amount in excess of Twenty Thousand ($20,000) Dollars, plus interest and costs. COUNT IV NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS 27. Paragraphs 24 through 26 of this Complaint are in.corpor- ated herein by reference as if set forth at length. 28. As a result of the conduct of the Defendant, plaintiff experienced substantial emotional distress, anguish, fear and anxiety because hie children who were injured as set forth above 6 . II, n ! VERI FICA'i'I~1i I' We, Edward and Angela Potteiger, verify that the statelllellt~ made in thlB Complaint are true and correct to the best of our information, knowledge and bolief. We further undel.'stand that I false statements made herein are subject to the penalties of 18 Po. C.S. ~4904 relating to unsworn falsification to authorities. Date ~ ///9 Jq!J' Date~ IIjq/115 I, 8 .' IJI"': ,. " " Ii tll/v 1'1 /I 1'1 ,:/ .!,I t ~1 /, " " , " , " iI " ''I ' , , , , . , "