HomeMy WebLinkAbout95-06585
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2, The law,_..:l.....'I;;~ does not require that an abutting
landowner keep the parking lot which he owns free from snow and
ice at all times: to hold otherwise would require the impossible
in view of the climatic conditions. In fact, there is no abso-
lute duty on the part of the landowner to keep his premises and
sidewalks free from snow and ice at all times. These formations
are natural phenomena incidental to our climate.
Rinaldi v. Levine, 406 Pa. 74, 78,
176 A.2d 623, 625 (1962).
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WILLIAM J. RICCHIUTI and
IRENE RICCHIUTI,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 95-6585 civil Term
v.
EXEL LOGISTICS, INC.
Defendant
JURY TRIAL DEMANDED
DEFENDANT'S PROPOSED JURY INSTRUCTIONS
1. A possessor of land is required to remove ice and snow
which has accumulated on the public parking lot abutting his
property within a reasonable time after he is on notice that a
dangerous condition exists. To establish liability upon the
landowner the plaintiff must prove that each of the following
three essentials were present:
(1) That snow and ice had accumulated on the
sidewalk in ridges or elevations of such size and
character as to unreasonably obstruct travel and con-
stitute a danger to pedestrians traveling thereon;
(2) That the defendant property owner knew or
should have known of the existence of such conditions;
and
(3) That it was the dangerous accumulation of
snow and ice which caused the plaintiff to fall.
pennsvlvania Standard Jurv
Instruction 7.02.
2. The law, wisely, does not require that an abutting
~!-
~~(~ landowner keep the parking lot which he owns free from snow and
ice at all times: to hold otherwise would require the impossible
in view of the climatic conditions. In fact, there is no abso-
lute duty on the part of the landowner to keep his premises and
sidewalks free from snow and ice at all times. These formations
.,
are natural phenomena incidental to our climate.
Rinaldi v. Levine, 406 Pa. 74, 78,
176 A.2d 623, 625 (1962).
- 2 -
.
.
3. In order to recover under the facts of this case,
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Plaintiff must prove not only that there was an accumulation of
snow and ice in the parking lot, but that such accumulation,
whether in the form of ridges or other elevations, was of such
size and character to constitute a substantial obstruction to
travel. A mere uneven surface caused by persons walking on the
snow and ice as it freezes will not constitute such an obstruc-
tion to travel.
Rinaldi v. Levine, 406 Pa. 74, 79
176 A.2d 623, 626 (1962)
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,
.
~
WILLIAM J. RICCHIUTI and
IRENE RICCHIUTI,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 95-6585 Civil Term
v.
EXEL LOGISTICS, INC.
Defendant
JURY TRIAL DEMANDED
DEFENDANT'S PROPOSFD JURY INSTRUCTION~
1. A possessor of land is required to remove ice and snow
which has accumulated on the public parking lot abutting his
property within a reasonable time after he is on notice that a
dangerous condition exists. To establish liability upon the
landowner the plaintiff must prove that each of the following
three essentials were present:
(1) That snow and ice had accumulated on the
sidewalk in ridges or elevations of such size and
character as to unreasonably obstruct travel and con-
stitute a danger to pedestrians traveling thereon;
(2) That the defendant property owner knew or
should have known of the existence of such conditions;
and
(3) That it was the dangerous accumulation of
snow and ice which caused the plaintiff to fall.
pennsvlvania Standard Jurv
Instruction 7.02.
,
3. In order to recover under the facts of this case,
Plaintiff must prove not only that there was an accumulation of
snow and ice in the parking lot, but that such accumulation,
whether in the form of ridges or other elevations, was of such
size and character to constitute a substantial obstruction to
travel. A mere uneven surface caused by persons walking on the
snow and ice as it freezes will not constitute such an obstruc-
tion to travel.
Rinaldi v. Levine, 406 Pa. 74, 79
176 A.2d 623, 626 (1962)
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WILLIAM J. RICCHIUTI and
IRENE RICCHIUTI,
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PEm~SYLVANIA
v.
NO. 95-6585 CIVIL TERM
EXEL LOGISTICS, lNC.,
Defendant
JURY TRIAL DEMANDED
PLAINTIFFS'
REOUESTED POINTS FOR CHARGE
AND NOW, come the Plaintiffs, William J. Ricchiuti and Irene
Ricchiuti, by their attorneys, Fowler, Addams & Rundle, and
request Your Honorable Court to charge the jury as follows:
1. One in possession of land is required to remove ice and
snow which has accumulated on the public sidewalk abutting his
property within a reasonable time after he is on notice that a
dangerous condition exists. To establish liability upon the
landowner, the Plaintiff must prove that each of the following
three essentials were present:
(1) That snow and ice had accumulated on the sidewalk in
ridges or elevations of such size and character as to
unreasonably obstruct travel and constitute a danger to
pedestrians traveling thereon;
(2) That the defendant property owner knew or should have
known of the existence of such condition;
(3) That it was the dangerous accumulation of snow and ice
which caused the plaintiff to fall. Pa. SSJI (Civ) 57.02;
Rinaldi v. Levine, 406 Pa. 74, 78-79, 176 A.2d 623, 625-26
(1962) .
,;
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2. This law which applies to public sidewalks also applies
to parking lots. Roland v. Kravco. Inc., 355 Pa. Super. 493, 513
A.2d 1029 (1986).
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3. The damages recoverable by the plaintiff, William J.
Ricchiuti, in this case and the items that go to make them up,
each of which I will discuss separately, are as follows:
(a) medical expense
(b) future medical expense
(c) loss of earnings
(d) pain and suffering
(e) future pain and suffering
(f) disfigurement
(g) loss of life's pleasures.
In the event that you find in favor of the plaintiff, you
will add these items of damage together and return your verdict
in a single, lump sum. Pa. SSJI (Civ) 56.01.
4. The plaintiff is entitled to be compensated in the
i\
amount of all medical expenses reasonably incurred for the
diagnosis, treatment and cure of his injuries in the past. These
expenses, as alleged by the plaintiff, amount to $3,831.16; an
exhibit will be submitted to you, itemizing these costs, for your
consideration during deliberation. Pa. SSJI (Civ) 56.01A.
'). . /l\N"u 5.
tV\X~D medical
The plaintiff is entitled to be compensated for all
expenses which you find he will reasonably incur in the
future for the treatment and care of his continuing injuries.
Pa. SSJI (Civ) 56.018.
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6. The plaintiff is entitled to be compensated for the
amount of earnings that he has lost up to the time of the trial
as a result of his injuries. This amount is the difference
between what he probably could have earned but for the harm and
any less sum which he actually earned in any employment.
Mr. Ricchiuti alleges that he was Unable to work from February 14
to August 17, 1994, a period of atlittle over 26
lidO"/. '"
in loss of wages in the amount of~249.9'.
,
weeks, resulting
7. The plaintiff is entitled to be fairly and adequately
compensated for such physical pain, mental anguish, discomfort,
fJ inconvenience, and distress as you find he has endured, from the
time of the accident until today. Pa. SSJI ICivl 56.01E.
a. The plaintiff is entitled to be fairly and adequately
compensated for such physical pain, mental anguish, discomfort,
~ inconvenience, and distress as you believe he will endure in the
future as a result of his , injuries. Pa. SSJI ICivl S601F.
......-....- --
lal As stated earlier, you should include in your
,
. Jaward for the plaintiff a reasonable compensation for the pain
~~ ,f'j land suffering which you find the plaintiff has suffered and may
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~~~ suffer in the future as a result of the injuries he sustained in
the collision. In evaluating the amount to be awarded for pain
and suffering, you should consider the "infliction of pain means
the taking from a person what is his own to Possess and retain,
namely, health and well-being," and that the law allows for
compensation for this loss to the extent that tha~ loss may be
calculated in monetary damages. At arriving at your award for
pain and suffering, you should consider not only the physical
pain and suffering the plaintiff has undergone, but the extent to
which the injury has resulted in the loss or lessening of his
ability to engage in other activities which he enjoyed prior to
the accident. DiChiccrio v. Rockcraft Stone Products Co., 424
Pa. 77, 85, 225 A.2d 913 (1967); Corcoran v. McNeal, 400 Pa. 14,
161 A.2d 367 (1960).
(b) When considering the pain and suffering that has
been endured by the plaintiff, I instruct you that pain and
suffering are substantial losses and can be as much a disability
as a crippling fracture or dismemberment. Buraan v. Pitts, 378
Pa. 608, 107 A.2d 860 (1954); carminati v. Phila. Transit Co.,
405 Pa. 500, 176 A.2d 440 (1961). The loss of wellbeing is as
much a loss as an amputation. The inability to enjoy what one
keenly appreciated is pain which can be equated with the
inflictions of a positive hurt. Corcoran v. McNeal, 400 Pa. 14,
161 A.2d 367 (1960). It is your duty to consider the pain and
suffering that the plaintiff has suffered or will suffer in the
future and determine what is reasonable compensation for that
pain and suffering.
(c) There has been testimony from the plaintiff's
doctor, Gerald Rothacker, M.D., that the plaintiff will suffer in
the future and this condition is permanent. If you find that the
plaintiff's injuries will continue beyond today, you must fairly
and adequately compensate him for such physical pain, mental
anguish, discomfort, inconvenience, and distress as you believe
he will endure in the future as a result of these injuries.
Pa. SSJI (Civ) 56.21. Pa. SSJI 556.01F; 6.21.
9. The disfigurement which the plaintiff sustained as a
result of this accident is a separate item of damages recognized
by the law. Therefore, in addition to such sums as you award for
pain and suffering and for embarrassment and humiliation, the
\S plaintiff is entitled to be fairly and adequately compensated for
the disfigurement he has suffered in the past as a result of this
accident, and which he will continue to suffer during the future
duration of his life. Pa. SSJI (Civ) 56.01H.
10. The plaintiff is entitled to be fairly and adequately
compensated for past, present and future loss of his ability to
~ enjoy and of the pleasures of life as a result of his injuries.
Pa. SSJI (Civ) 56.011.
11. The plaintiff is entitled to recover damages for all
injuries which the defendant's negligence was a substantial
factor in producing. The defendant's negligence need not be the
sole cause of the injuries; other causes may have contributed to
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producing the final result. The fact that some other factor may
have been a contributing cause of an injury does not relieve a
defendant of liability, unless you find that such other cause
would have produced the injury complained of independently of its
negligence. Pa. SSJI (Civ) 56.30.
12. The Plaintiff's spouse is entitled to be compensated for
" the loss of the injured party's services to him (her) and the
~
loss of the companionship of his (her) spouse. Pa. SSJI 5601L.
The claim is for loss of consortium. It includes whatever aid,
assistance, comfort and society the injured spouse would be
expected to bestow on the other spouse. Consortium is an element
of damages which has no market value, and the amount to be
awarded is particularly for your common sense and sound judgment.
Burns v. PeDsi-Co1a Metrooo1itan Bott1inQ Co., 353 Pa. Super.
571, 510 A.2d 810 (1986).
Respectfully submitted,
FOWLER, ADDAMS & RUNDLE
By:
';~c-
Supreme Court I,D. No. 06265
28 South Pitt Street
P.O. Box 208
Carlisle, PA 17013
(717) 249-8300
Attorneys for Plaintiffs
WILLIAM J. RICCHIUTI and
IRENE RICCHIUTI,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 95-6585 civil Term
v.
EXEL LOGISTICS, INC.
Defendant
JURY TRIAL DEMANDED
+
DEFENDANT'S PROPOSED JURY INSTRUCTIONS
1. The Plaintiff claims that he was injured and sustained
damage as a result of the negligent conduct of the Defendant.
The Plaintiff has the burden of proving his claims.
The Defendant denies the Plaintiff's claims and asserts as
an affirmative defense that the Plaintiff was himself negligent
and that such negligence was a substantial factor in bringing
about Plaintiff's injuries. The Defendant has the burden of
proving this affirmative defense.
Based upon the evidence presented at this trial, the only
issues for you to decide in accordance with the law as I shall
give it to you are:
First: Was the Defendant negligent?
Second: Was the Defendant's conduct a substantial factor in
bringing about harm to the Plaintiff?
Third: Was the Plaintiff himself negligent and was such
negligence a substantial factor in bringing about Plaintiff's
injuries?
Pennsylvania Standard Jurv
Instruction 3.00.
3. You may find inconsistencies in the evidence. Even
~actual contradictions in the testimony of witnesses do not
~'
necessarily mean that any witness has been willfully false. Poor
memory is not uncommon. Sometimes a witness forgets/ sometimes
he remembers incorrectly. It is also true that two persons
witnessing an incident may see or hear it differently.
If different parts of a testimony of any witness Or
witnesses appear to be inconsistent, you the jury should try to
reconcile the conflicting statements, whether of the same or of
different witnesses, and you should do so if it can be done
fairly and satisfactorily. If, however, you decide that there is
a genuine and irreconcilable conflict of testimony, it is you~.
function and duty to determine which, if any, of the contradic-
tory statements you will believe.
Pennsvlvania Standard Jurv
Instruction 5.04.
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~
4.
If you decide that a witness has deliberately falsified
his testimony on a significant point, you should take this into
consideration in deciding whether or not to believe the rest of
his testimonYI and you may refuse to believe the rest of his
testimony, but you are not required to do so.
Penn.vlvant. Standard Ju~v
Instruction 5.05.
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A
5.
Defendant was not the insurer of Plaintiff's safety,
and the mere happening of this accident is not evidence or proof
of negligence on ita part.
Watkins v. Sharon Aerie No. 327,
423 Pa. 396, 398 (1966); O'Neill v.
Bachelor BrOB.. Inc. Funeral Homes,
421 Pa. 413, 416 (1966).
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7. Accordingly, you may not find Exel Logistics liable to
~ Plaintiffs unless you find that it was guilty of negligence and
that its negligence was a substantial factor in causing this
accident.
Hamil v. Bashline, 481 Pa. 256, 265
(1978); Burnside v. Abbott Laborat-
ories, 351 Pa. Super. 264, 274
(1985) .
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. . "'.'.,....,., ~..
~
~ 1 8. Exel Logistics is not liable to Plaintiff if you find
~).hat the danger involved in walking as he was at the time of his
fall would have been obvious to and discovered by a reasonable
L
person in plaintiff's position, exercising normal perception,
intelligence, and judgment.
Restatement (2dl of Torts, S343(a),
Comment B (1965); carrender v.
Fitterer, 503 Pa. 178 (1983).
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McNEES, WALLACE & NURICK
ATTORNEYS AT LAW
100 PINE STREET
p, O. BOX 1188
HARRISBURG, PA 17108.1188
T....IIO..,7I71232,8000 ruI7171237.5300
11000 STREET N,W,
SUITE 800
WASHINGTON, D,C, 2000e
T....IIo..,202143408;;1 r..,2021434,8707
hnpJ/WWW.mwn.com
MICHAEL R. KaLLay
D...CT DIALl 17.71 Q07.aDIiJU
B.MAIL Aoa....l W..LL.Y.NW".CON
November 5, 1996
The Honorable Harold E. Sheely
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
Re: Ricchiuti v. Exel Logistics, Inc.
C.P. CUmberland County No. 95-6585 civil term
Dear Judge Sheely:
Enclosed is Defendant's Trial Memorandum and Proposed Jury
Instructions on the "Hills and Ridges" doctrine which you
requested in the pre-trial order.
You will note that there is no discussion regarding the
admissibility of the medical and wage losses of Plaintiff. After
furth~r review of the statute and case law, Defendant agrees that
the medical expenses and evidence of lost wages are admissible.
There also is no discussion concerning the ability of Plaintiff
to present a future lost earning capacity claim without the
testimony of an expert. Plaintiff's counsel has agreed that such
testimony cannot be presented without an expert and that no
expert testimony will be presented on this issue.
Thank you for your consideration.
Sincerely,
MRK/djp
Enclosure
cc: William A.
MCNEEY1 WALrCEO& ~~~K rf)
By f I~cl... t r,-e (Jt.~
Michael R. Kelley ~
Addams, Esquire
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McNEE8, WALLACE II< NURICIC
.00 PIN. .Tltl",
NOV 0 6 199~~
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HA""I..U.... PA ",oe
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WILLIAM J. RICCHIUTI and
IRENE RICCHIUTI,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERIJ\ND COUNTY, PENNSYLVANIA
No. 95-6585 civil Term
v.
EXEL LOGISTICS, INC.
Defendant
JURY TRIAL DEMANDED
DEFENDANT'S TRIAL BRIEF
I . FACTUAL BACKGROUND
This case involves a slip and fall accident which occurred
on February 14, 1994. At that time, Plaintiff was operating a
tractor-trailer on the premises of Defendant. While attempting
to drop his trailer and disconnect it from the tractor, plaintiff
slipped on ice and snow and fell. The community where the
accident occurred had received heavy snowfall on a regular basis
for weeks prior to the date of the accident. Ice and snow had
accumulated throughout the community over the several week
period. On approximately February 11, 1994, another snowfall
of more than 8 inches fell in the community and at the facility
of Defendant. This snowfall was plowed on February 11 and
February 12, 1994. No further snow fell between that date and
the date of the accident and, while snow and ice did exist in the
parking lot area where the accident occurred, there were no
ridges or hills which obstructed either automobile traffic or
foot traffic.
"
Plaintiff claims that the previous snowfall on February 11,
1994 had not been plowed and that numerous ruts from tractor-
trailer traffic were made in the un-plowed lot when he arrived on
the morning of the accident. Nonetheless, he testified as his
deposition that he slipped and fell when he took a step into an
area that had several inches of snow on it and slipped due to ice
underneath the snow. Plaintiff specifically testified that there
were no ruts in the area where he slipped. Plaintiff is unsure
as to the amount of the snow in the parking lot, but believes
that it was no more than 6 or 8 inches.
I I . ARGUMENT
A. Hills And Ridqes Doctrine.
The seminal case in Pennsylvania on the "hills and ridges"
doctrine is Rinaldi v. Levine, 406 Pa. 74, 176 A.2d 623 (1962).
There the Supreme Court held:
In Pennsylvania, an abutting property owner is
orimarilv liable for the removal of ice and snow upon
the sidewalk. However the law, wisely, does not
require that such abutting owner keep the sidewalk free
from snow and ice at all timp.s: to hold otherwise
would require the impossible in view of the climatic
conditions. Whitton v. H.A. Gable Co., 331 Pa. 429,
431, 200 A.2d 644 clearly expresses the quantum of duty
imposed on the abutting owner: "There is no absolute
duty on the part of a landowner to keep his premises
and sidewalks free from snow and ice at all times.
These formations are natural phenomena incidental to
our climate. Snow and ice upon a pavement create
merely transient danger and the only duty upon the
property owner or tenant is to act within a reasonable
time after notice to remove it when it is in a danger-
ous condition. There is no liabilitv created bv a
qeneral sliooerv condition on sidewalks. It must
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aDDear that there were danaerous conditions due to
ridaes or elevations which were allowed to remain for
an unreasonable lenath of time. or were created bv
defendant's antecedent nealiaence."
406 Pa. at 77-78, 176 A.2d at 625 (citations omitted) (emphasis
added). The Supreme Court went on to state that:
Where a property owner is charged with negligence and
permitting the accumulation of snow or ice on his
sidewalk, the proof necessary to sustain such a charge
has been clearly defined by our decisional law. It is
encumbent upon a plaintiff in such situation to prove:
(1) that snow and ice had accumulated on the sidewalk
in ridges or elevations of such size and character as
to unreasonably obstruct travel and constitute a danger
to pedestrians traveling thereon; (2) that the property
owner had notice, either actual or constructive, of the
existence of such condition; and (3) that it was the
dangerous accumulation of snow and ice which caused the
plaintiff to fall. Absent proof of sll such facts,
plaintiff has no basis for recovery.
Moreover, the burden is upon a plaintiff to prove
not only that there was an accumulation of snow and ice
on the sidewalk but that such accumulation, whether in
the form of ridges or other elevations, was of such
size and character to constitute a substantial obstruc-
tion to travel. A mere uneven surface caused by per-
sons walking on the snow and ice as it freezes will not
constitute such an obstruction to travel.
406 Pa. at 78-79, 176 A.2d at 625, 626.
The law as set forth in Rinaldi has been applied to parking
lots as well. ~ Roland v. Kravco. Inc., 355 Pa. Super. 493,
513 A.2d 1029 (1986). In Roland, the court further explained
that in addition to the factors set forth in Levine, "[p]laintiff
must also show that these ridges or elevations were the cause of
the fall and in the absence of proof of this, the plaintiff has
no basis for recovery." 355 Pa. Super. at 498, 513 A.2d at 1032.
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~ aliQ Frederick v. Katsifis, 44 Cumbo 466, 468 (1995), citing
Rinaldi and Roland (defendant's motion for summary judgment
granted on basis that plaintiff had failed to show hills and
ridges as reason for slip and fall) .
Under the above authorities, where general slippery condi-
tions exist in the community, the plaintiff has the burden of
proving the existence of "hills and ridges" and that his fall was
caused by such hills or ridges. The facts which will be pre-
sented at trial will establish that general slippery conditions
prevailed in the community. The testimony will demonstrate that
the winter of 1994 wa6 one of the worst on record in Pennsyl-
vania. At the time of the accident, huge mounds of snow were
piled up allover the community and where the accident occurred,
including mounds of snow piled 8 and 10 feet high in the parking
lot at Exel Logistics. The Friday prior to the accident, which
occurred on a Monday morning, had seen approximately 9 inches of
snow fall in the community. Accordingly, Plaintiff must prove
that hills and ridges existed in the parking lot and that such
hills and ridges caused his fall.
The evidence presented at trial will establish that there
were no hills or ridges in the parking lot at Exel Logistics.
Defendant will present testimony that the parking lot had been
plowed prior to the arrival of Plaintiff. Such testimony will be
presented by witnesses and through the records of plowing by Exel
Logistics' snow removal contractor. These records indicate that
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the snowfall on February 11, 1994 was plowed on that day and on
February 12, 1994. Even assuming that the lot was not plowed,
ruts from traffic driving on several inches of snow does not
amount to an accumulation "of such size and character to consti-
tute a substantial obstruction to travel." At most, the tracks
in the snow amounted to a "mere uneven surface."
Even assuming, further, that the ruts in the snow constitute
"hills or ridges", Plaintiff's own testimony at his deposition
indicates that he did not slip and fall in the alleged ruts
created by traffic in the lot. His testimony was that he stepped
in several inches of snow and slipped because of ice underlying
that snow. Where general slippery conditions are in effect, and
absent a hill or ridge in the area of the fall, Plaintiff cannot
recover.
B. Status Of Plaintiff As A Business Visitor On The
Premises Of Exel Loqistics.
It is Defendant's position that Plaintiff was a business
visitor on the premises of Exel Logistics. Nonetheless, whether
Exel Logistics is liable for Plaintiffs' fall is to be determined
by the "hills and ridges doctrine" as set forth above. The
general rule with regard to the duty that a landowner owes to a
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business visitor is superseded by the "hills and ridges doctrine"
under the facts of this case.
Respectfully submitted,
McNEES,
By
& NURICK
.'
~.
M c ael R. Kelley
I.D. No. 58854
100 Pine Street
P. O. Box 1166
Harrisburg, PA 17108-1166
(717) 232-8000
Attorneys for Defendant
Exel Logistics, Inc.
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i
.
,
CERTIFICA~E OF SERVI~E
The undersigned hereby certifies that on this date the
foregoing document was served by first class mail, postage
prepaid, upon the fOllowing:
William A. Addams, Esquire
28 South Pitt Street
P. O. Box 208
Carlisle, PA 17013
~K~ie~
Dated: November~, 1996
Attorneys for Defendant
Exel Logistics, Inc.
WILLIAM J. RICCHIUTI and
IRENE RICCHIUTI,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 95-6585 Civil Term
v.
EXEL LOGISTICS, INC.
Defendant
JURY TRIAL DEMANDED
DEFENDANT'S TRIAL BRIEF
I. FACTUAL BACKGROUND
This case involves a slip and fall accident which occurred
on February 14, 1994. At that time, Plaintiff was operating a
tractor-trailer on the premises of Defendant. While attempting
to drop his trailer and disconnect it from the tractor, Plaintiff
slipped on ice and snow and fell. The community where the
accident occurred had received heavy snowfall on a regular basis
for weeks prior to the date of the accident. Ice and snow had
accumulated throughout the community over the several week
period. On approximately February 11, 1994, another snowfall
of more than 8 inches fell in the community and at the facility
of Defendant. This snowfall was plowed on February 11 and
February 12, 1994. No further snow fell between that date and
the date of the accident and, while snow and ice did exist in the
parking lot area where the accident occurred, there were no
ridges or hills which obstructed either automobile traffic or
foot traffic.
Plaintiff claims that the previous snowfall on February 11,
1994 had not been plowed and that numerous ruts from tractor-
trailer traffic were ma~e in the un-plowed lot when he arrived on
the morning of the accident. Nonetheless, he testified as his
deposition that he slipped and fell when he took a step into an
area that had several inches of snow on it and slipped due to ice
underneath the snow. Plaintiff specifically testified that there
were no ruts in the area where he slipped. Plaintiff is unsure
as to the amount of the snow in the parking lot, but believes
that it was no more than 6 or 8 inches.
II . ARGUMENT
A. Hills And Ridqes Doctrine.
The seminal case in Pennsylvania on the "hills and ridges"
doctrine is Rinaldi v. Levine, 406 Pa. 74, 176 A.2d 623 (1962).
There the Supreme Court held:
In Pennsylvania, an abutting property owner is
orimarilv liable for the removal of ice and snow upon
the sidewalk. However the law, wisely, does not
require that such abutting owner keep the sidewalk free
from snow and ice at all times: to hold otherwise
would require the impossible in view of the climatic
conditions. Whitton v. H.A. Gable Co., 331 Pa. 429,
431, 200 A.2d 644 clearly expresses the quantum of duty
imposed on the abutting owner: "There is no absolute
duty on the part of a landowner to keep his premises
and sidewalks free from snow and ice at all times.
Theoe formations are natural phenomena incidental to
our climate. Snow and ice upon a pavement create
merely transient danger and the only duty upon the
property owner or tenant is to act within n reasonable
time after notice to remove it when it is in a danger-
ous condition. There is no liabilitv created bv a
qeneral slippery condition on sidewalks. It must
- 2 -
aooear that there were danqerous conditions due to
ridqes or elevations which were allowed to remain for
an unreasonable lenqth of time. or were created bv
defendant's antecedent neqliqence."
406 Pa. at 77-78, 176 A.2d at 625 (citations omitted) (emphasis
added). The Supreme Court went on to state that:
Where a property owner is charged with negligence and
permitting the accumulation of snow or ice on his
sidewalk, the proof necessary to sustain such a charge
has been clearly defined by our decisional law. It is
encumbent upon a plaintiff in such situation to prove:
(1) that snow and ice had accumulated on the sidewalk
in ridges or elevations of such size and character as
to unreasonably obstruct travel and constitute a danger
to pedestrians traveling thereon; (2) that the property
owner had notice, either actual or constructive, of the
existence of such condition; and (3) that it was the
dangerous accumulation of snow and ice which caused the
plaintiff to fall. Absent proof of all such facts,
plaintiff has no basis for recovery.
Moreover, the burden is upon a plaintiff to prove
not only that there was an accumulation of snow and ice
on the sidewalk but that such accumulation, whether in
the form of ridges or other elevations, was of such
size and character to constitute a substantial obstruc-
tion to travel. A mere uneven surface caused by per-
sons walking on the snow and ice as it freezes will not
constitute such an obstruction to travel.
406 Pa. at 78-79, 176 A.2d at 625, 626.
The law as set forth in Rinaldi has been applied to parking
lots as well. See Roland v. Kravco. Inc., 355 Pa. Super. 493,
513 A.2d 1029 (1986). In Roland, the court further explained
that in addition to the factors set forth in Levine, "[p]laintiff
must also show that these ridges or elevations were the cause of
the fall and in the absence of proof of this, the plaintiff has
no basis for recovery." 355 Pa. Super. at 498, 513 A.2d at 1032.
- 3 --
~ dlgQ Frederick v. Katsifis, 44 Cumbo 466, 468 (1995), citing
Rinaldi and Roland (defendant's motion for summary judgment
granted on basis that plaintiff had failed to show hills and
ridges as reason for slip and fall) .
Under the above authorities, where general slippery condi-
tions exist in the community, the plaintiff has the burden of
proving the existence of "hills and ridges" and that his fall was
caused by such hills or ridges. The facts which will be pre-
sented at trial will establish that general slippery conditions
prevailed in the community. The testimony will demonstrate that
the winter of 1994 was one of the worst on record in Pennsyl-
vania. At the time of the accident, huge mounds of snow were
piled up allover the community and where the accident occurred,
including mounds of snow piled 8 and 10 feet high in the parking
lot at Exel Logistics. The Friday prior to the accident, which
occurred on a Monday morning, had seen approximately 9 inches of
snow fall in the community. Accordingly, Plaintiff must prove
that hills and ridges existed in the parking lot and that such
hills and ridges caused his fall.
The evidence presented at trial will establish that there
were no hills or ridges in the parking lot at Exel Logistics.
Defendant will present testimony that the parking lot had been
plowed prior to the arrival of Plaintiff. such testimony will be
presented by witnesses and through the records of plowing by Exel
Logistics' snow removal contractor. These records indicate that
- 4 -
the snowfall on February 11, 1994 was plowed on that day and on
February 12, 1994. Even assuming that the lot was not plowed,
ruts from traffic driving on several inches of snow does not
amount to an accumulation "of such size and character to consti-
tute a substantial obstruction to travel." At most, the tracks
in the snow amounted to a "mere uneven surface."
Even assuming, further, that the ruts in the snow constitute
"hills or ridges", Plaintiff's own testimony at his deposition
indicates that he did not slip and fall in the alleged ruts
created by traffic in the lot. His testimony was that he stepped
in several inches of snow and slipped because of ice underlying
that snow. Where general slippery conditions are in effect, and
absent a hill or ridge in the area of the fall, Plaintiff cannot
recover.
B. Status Of Plaintiff As A Business Visitor On The
Premises Of Exel Loqiotics.
It is Defendant's position that Plaintiff was a business
visitor on the premises of Exel Logistics. Nonetheless, whether
Exel Logistics is liable for Plaintiffs' fall is to be determined
by the "hills and ridges doctrine" as set forth above. The
general rule with regard to the duty that a landowner owes to a
- 5 -
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on this date the
foregoing document was served by first class mail, postage
prepaid, upon the following:
William A. Addams, Esquire
28 South pitt Street
P. O. Box 208
Carlisle, PA 17013
-vo/jdd K~ie~
Attorneys for Defendant
Exel Logistics, Inc.
-
Dated: November ~ , 1996
SHERIFF'S RETURN - REGULAR
CASE NO. 1995-e6585 P
CORRONWEALTH OF PENNSYLVANIA,
COUNTY OF CUKBERLAND
RICCHIUTI WILLIAK J
VS,
EXEL LOGISTICS INC
J. RICHAEL ICKES . Sheriff or Deputy Sheriff of
CURBERLAND County, Penn.ylvania, who being duly .worn according
to la.. .ay., the within CORPLAINT wa. .erved
upon EXEL LOGISTICS INC
defendant. at 1040.e0 HOURS, on the ~ day of Nove~ber
19~ at 260 SALEK CHURCH ROAD
RECHANICSBURG. PA 17e55 .CURBERLAND
County. Pennaylvania. by handing to KARLIN WOOD. DIRECTOR OF
RAIITENANCE & ADULT IN CHARGE
a true and atte.ted copy of the CORPLAINT .
and at the .a~e ti~e directing Ria attention to the content. thereof.
the
.
Sheriff'. Coat..
Docketing
Service
Affidavit
Surcharge
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fOWLER ADDAKS SHUGHART RUNDLE
11/2211995
by
f~t1~~
Sworn and .ubacribed to before me
thi. /I ~ day of I.l'l",,~
..-
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,
WILLIAM J. RICCHIUTI and
IRENE RICCHIUTI,
plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 95-6585 CIVIL TERM
EXEL LOGISTICS, INC.,
Defendant
JURY TRIAL DEMANDED
AND NOW, this
ORDER OF COURT
day of November, 1996, upon
consideration of the within motion, the trial of this case is
continued at the request of the plaintiff.
The prothonotary is directed to relist the case for trial
for the January, 1997 term.
By the Court,
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-
Distribution:
William A. Addams, Esquire
Michael R. Kelley, Esquire
J.
',j
.
WILLIAM J. RICCHIUTI and
IRENE RICCHIUTI,
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 95-6585 CIVIL TERM
EXEL LOGISTICS, INC.,
Defendant
JURY TRIAL DEMANDED
MOTION FOR CONTINUANCE
AND NOW, comes the Plaintiff, by his attorneys, Fowler,
Addams, Shughart & Rundle, and moves Your Honorable Court as
follows:
1. This case is on the November 12, 1996 trial list.
2. Plaintiff's worker's compensation carrier is asserting a
subrogation claim of $39,~31.53 which includes a commutated
settlement of $21,000 for 500 weeks partial disability.
3. Plaintiff'S medical evidence does not support a claim
for loss of future earning capacity.
4. In order to conduct meaningful settlement negotiations
with Defendant, the Plaintiff must attempt to reach agreement
with the carrier regarding its subrogation claim, but counsel is
advised that it "cannot locate the file."
5. Therefore, Plaintiff requests a continuance to the
January 1997 term.
<.liftl f<H~ h.
CERTIFICATE OF SERVICE
AND NOW, this 1st day of November, 1996, I, William A.
Addams, of Fowler, Addams, Shughart & Rundle, attorneys for
plaintiffs, hereby certify that I have served a copy of the
Motion for Continuance by Faxing to (717) 237-5300, and mailing a
copy of the same by united States mail, postage prepaid,
addressed as follows:
Michael R. Kelley, Esquire
McNees, Wallace & Nurick
P.O. Box 1166
Harrisburg, PA 17108-1166
~-:~~~
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~
WILLIAM J. RICCHIUTI and
IRENE RICCHIUTI,
plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 95-6585 CIVIL TERM
EXEL LOGISTICS, INC.,
Defendant
JURY TRIAL DEMANDED
ORDER OF COURT
AND NOW, this
day of November, 1996, upon
consideration of the within motion, the trial of this case is
continued at the request of the Plaintiff.
The Prothonotary is directed to relist the case for trial
for the January, 1997 term.
By the Court,
J.
Distribution:
William A. Addams, Esquire
Michael R. Kelley, Esquire
,NOV Ii ;
',.. ' l.....
IJ;.JU
W
WILLIAM J. RICCHIUTI and
IRENE RICCHIUTI,
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 95-6585 CIVIL TERM
EXEL LOGISTICS, INC.,
Defendant
JURY TRIAL DEMANDED
ORDER OF COURT
AND NOW, this
day of November, 1996, upon
consideration of the within motion, the trial of this case is
continued at the request of the Plaintiff.
The Prothonotary is directed to relist the case for trial
for the January, 1997 term.
By the Court,
J.
Distribution:
William A. Addams, Esquire
Michael R. Kelley, Esquire
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WILLIAM J. RICCHIUTI and
IRENE RICCHIUTI,
plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 95-6585 Civil Term :-,
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EXEL LOGISTICS, INC.
Defendant
JURY TRIAL DEMANDED
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DEFENDANT'S MOTION IN LIMINE TO PRECLUDE
INTRODUCTION OF SNOW REMOVAL RECORD DATED FEBRUARY 15, 'I994':!
Defendant anticipates that plaintiffs will attempt to
introduce into evidence a record of snow plowing at the Exel
Logistics' parking lot which was completed following plaintiff's
accident. Set forth more fully below, such evidence is
inadmissible as a subsequent remedial repair.
The Pennsylvania Supreme Court, in the cases Incollinao v.
Ewinq, 282 A.2d 206, 444 Pa. 263 (1971) and Pressler v. city of
pittsburqh, 214 A.2d 616, 419 Pa, 440 (1965), established that
evidence of subsequent remedial repairs is inadmissible for
purposes of proving negligence against the defendant. More
recent cases have continued to apply this rule with facts similar
to those involved in this case.
The superior Court recently held that a trial court abuses
its discretion when it admits evidence of subsequent remedial
measures to demonstrate prior negligence. In Armstrona v, Paoli
Memorial Hosoital, 633 A.2d 605, 430 Pa. Super. 36, aooeal
denied, 649 A.2d 666, 538 Pa. 663 (1993), the court considered
, )
"
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on this date the
foregoing document was served by first class mail, postage
prepaid, upon the following:
William A. Addams, Esquire
28 South pitt Street
P. O. Box 208
Carlisle, PA 17013
01
Dated:
1/21/n
Attorneys for Defendant
Exel Logistics, Inc.
WILLIMI J. RICCHIUTI and
IRENE RICCHIUTI,
plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 95-~,?S CIVIL TERM
EXEL LOGISTICS, INC.,
Defendant
: JURY TRIAL DEMANDED
COMPLAINT
AND NOW, come the plaintiffs, William J. and Irene
Ricchiuti, by their attorneys, Fowler, Addams, Shughart & Rundle,
and make the following complaint:
1. The plaintiffs are William J. Ricchiuti and Irene
Ricchiuti, adult individuals residing at 328 Arlington street,
Reading, PA 19611.
2. The defendant is Exel Logistics, Inc., a corporation
with its offices and principal place of business at 5023 Trindle
Road, Mechanicsburg, Cumberland County, Pennsylvania.
3. 'On February 14, 1994, the plaintiff, William J.
Ricchiuti was employed as a truck driver by John S. Ewell, Inc.
4. At about 6:00 a.m. on said date Mr. Ricchiuti was
assigned to drop an empty trailer and to pick up a loaded trailer
at the defendant's warehouse on Doughten Road, New Kingstown,
cumberland county, PA.
5. More than eight inches of snow had fallen on
February 11, 1994, and at the time the plaintiff arrived at the
defendant's warehouse, the parking lot was covered with snow and
ice which had not been cleared and which was extremely rough from
traffic.
6. The plaintitt backed his trailer into the only available
space. As he was unhooking the trailer he slipped and tell on
the rough ice resulting in the injuries hereinafter set forth.
7. The plaintitt's accident and resulting injuries were
caused by the negligence and carelessness ot the detendant in:
C.
Failing to clear the parking lot ot snow and ice.
Allowing the snow to thaw and retreeze and develop
into a condition of hills and ridges; and
Failing to provide an area for the plaintitt to
park that was free of snow and ice.
A.
B.
COUNT I
WILLIAM J. RICCHIUTI v. EXEL LOGISTICS. INC.
8. As a result of the negligence and carelessness of the
detendant, plaintiff william J. Ricchiuti sustained a severe
contueion with lateral epicondylitis of the right elbow and an
injury to his right ankle.
9. As a result of his injury the plaintiff incurred medical
expense ot $3,831.16.
10. As a result of his injury, the plaintiff was unable to
return to work until July 30, 1994 resulting in loss of earnings
ot $19,993.92.
11. As a result of his injury, the plaintiff has a
limitation at motion in his right elbow which may be permanent
and which will result in a loss of future earning capacity.
12. The plaintiff has undergone extreme pain and sUffering
and will be forced to underqo same in the future.
VERIFICATION
William J. Ricchiuti hereby verifies that the facts set
forth in the foregoing complaint are true and correct to the be.t
of hi. knowledge, information and belief, and understands that
fal.e .tatements herein are mads subject to the penalties of 18
Pa. C.S. 14904 relating to unsworn falsifications.
DATE: /lIl{/. 1'7. / t'h-
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WILLIAM J. RICCHIUTI and
IRENE RICCHIUTI,
plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANXA
v.
NO. 95-6585 CIVIL TERM
EXEL LOGISTICS I INC.,
Defendant
: JURY TRIAL DEMANDED
REPLY
AND NOW, come the plaintiffs, william J. and Irene
Ricchiuti, by their attorneys, Fowler, Addams, Shughart' Rundle,
and make the following reply to the defendant's answer with new
matter:
19.
The conclusion of law is denied.
Denied in accordance with Pa. R.C.P. 1029(e).
Denied in accordance with Pa. R.C.P. 1029(e).
The conclusion of law is denied.
The conclusion of law is denied.
Denied in accordance with Pa. R.C.P. 1029(e).
15.
16.
17.
18.
20.
WHEREFORE, the plaintiffs request that the new matter be
dismissed.
FOWLER, ADDAMS, SHUGHART , RUNDLE
BY~~
. am A. Addams
supreme court 1.0. No.06265
28 south Pitt Street
P.O. Box 208
Carlisle, PA 17013
(717) 249-8300
Attorneys for plaintiffs
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M~Nr::ES. WALLACt! 0. NURICK
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fIA""IBlSuno. PA 17108
averments of Paragraph 5 of the Complaint, and the same are
therefore denied.
6. Denied. After reasonable investigation, Defendant is
without knowledge or information sufficient to form a belief as
to the truth of the averments of Paragraph 6 of the Complaint,
and the same are therefore denied.
7. Denied. Pursuant to Pa. R. civ. P. 1029(e), all
allegations of negligence not admitted are hereby denied.
COUNT I
B. Denied. Pursuant to Pa. R. civ. P. 1029(e), all
allegations of negligence not admitted are hereby denied. After
reasonable investigation, Defendant is without knowledge or
information sufficient to form a belief as to the truth of the
remaining averments of Paragraph B of the Complaint, and the same
are therefore denied.
9.- 12. Denied. After reasonable investigation, Defendant
is without knowledge or information sufficient to form a belief
as to the truth of the averments of Paragraphs 9 through 12 of
the Complaint, and the same are therefore denied.
WHEREFORE, Defendant Exel Logistics, Inc. requests that this
Court dismiss Plaintiffs' complaint with prejudice, and award it
costs of suit.
- 2 -
COUNT II
13. Defendant incorporates Paragraphs 1-12 of its Answer as
if set forth fully.
14. Denied. After reasonable investigation, Defendant is
without knowledge or information sufficient to form a belief as
to the truth of the averments of Paragraph 6 of the Complaint,
and the same are therefore denied.
WHEREFORE, Defendant Exel Logistics, Inc. requests that this
Court dismiss Plaintiffs' Complaint with prejudice, and award it
costs of suit.
NEW MATTIR
15. The premises were in a reasonably safe condition at the
time of the alleged fall.
16. In the alternative, if it is determined that there was
snow and ice on the parking lot at the premises, Defendant avers
that this condition was open and obvious and should have been
discovered by Plaintiff prior to the alleged fall.
17. In the event it is determined that the Plaintiff
suffered any of the injuries or damages complained of in the
complaint, which is denied, then Defendant avers that said
damages were the direct and proximate result of the negligence,
carelessness, or recklessness of Plaintiff as follows:
- 3 -
(a) Failing to maintain a proper lookout for his own
safety;
Failing to pay proper attention; and,
Failing to properly observe the area where he was
(b)
(c)
walking.
lB. In the event it is determined that the area where
plaintiff allegedly fell was slippery, which is specifically
denied, then Plaintiff was negligent, in that he failed to
properly observe the conditions and avoid walking in that area.
19. The negligence of the plaintiff was the sole and
proximate cause of any of his alleged injuries, said injuries
being denied, and his negligence exceeded any negligence on the
part of the Defendant, any negligence by Defendant being
specifically denied. In the alternative, if it is determined
that plaintiff was negligent, but that his negligence did not
exceed that of the Defendant, the same being specifically denied,
then any award of damages must be reduced by the proportionate
share of plaintiff's comparative negligence.
20. In the event it is determined that the area of the
sidewalk where Plaintiff allegedly fell was slippery, which is
specifically denied, Defendants aver that said condition was open
and obvious, and that plaintiff assumed the risk of any injuries
by knowingly encountering and failing to avoid such condition.
- 4 -
. .
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on this date the
foregoing document was served by first class mail, postage
prepaid, upon the following:
William A. Addams, Esquire
2B South Pitt Street
P.O. Box 20B
Carlisle, PA
170Q
'itl~ A ",
C. 01 Ii. ~
Of Counsel to Defendant
Exel Logistics, Inc.
December 15, 1995
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WILLIAM J. RICCHIUTI and
IRENE RICCHIUTI,
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 95-65B5 CIVIL TERM
EXEL LOGISTICS, INC.,
Defendant
JURY TRIAL DEMANDED
PLAINTIFFS' PRETRIAL MEMORANDUM
1. FACTS: At about 6:00 a.m. on February 14, 1994, William
Ricchiuti delivered a trailer to the Defendant's warehouse in New
Kingstown. More than eight inches of snow had fallen three days
before. The parking lot was covered with snow and ice which had
not been cleared and which was rough from traffic. It was dark.
There was a light coat of new snow. As Mr. Ricchiuti turned to
unhook the fifth wheel, he slipped on a ridge of ice and landed
on his right elbow.
2. DAMAGES: The plaintiff sustained a severe contusion
with lateral epicondylitis of the right elbow and an injury to
his right ankle. The worker's compensation carrier paid
$3,B31.16 for medical expense and $35,BOO.37 for disability. He
is still precluded from heavy work. His average weekly wage was
$BOB.OB. His present earning capacity is $745.0B.
3. ISSUES: Liability and damages.
4. EVIDENCE: No problems are anticipated.
5. WITNESSES: William Ricchiuti
Irene Ricchiuti . ' ., ..r-#-,
Ted Schaffer, President of J. S. Ewell- It;;,.cf(':,' ,
William Lerch - Manager, Exel --
Kenneth J. Novacick, Jr. - Supervisor, Exel--
Gerald W. Rothacker, Jr., M. D., u I' 1 -' ~r1.,\ \ \
by deposition. l/ r ().( v-
WILLIAM J. RICCHIUTI and
IRENE RICCHIUTI,
plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 95-65B5 CIVIL TERM
EXEL LOGISTICS, INC.,
Defendant
JURY TRIAL DEMANDED
PLAINTIFFS' PRETRIAL MEMORANDUM
1. FACTS: At about 6:00 a.m. on February 14, 1994, William
Ricchiuti delivered a trailer to the Defendant's warehouse in New
Kingstown. More than eight inches of snow had fallen three days
before. The parking lot was covered with snow and ice which had
not been cleared and which was rough from trnffic. It was dark.
There was a light coat of new snow. As Mr. Ricchiuti turned to
unhook the fifth wheel, he slipped on a ridge of ice and landed
on his right elbow.
2. DAMAGES: The plaintiff sustained a severe contusion
with lateral epicondylitis of the right elbow and an injury to
his right ankle. The worker's compensation carrier paid
$3,B31.16 for medical expense and $35,BOO.37 for disability. He
is still precluded from heavy work. His average weekly wage was
$BOB.OB. His present earning capacity is $745.0B.
3. ISSUES: Liability and damages.
4. EVIDENCE: No problems are anticipated. The defendant
will stipulate to the medical expense in the amount of $3,B31.16.
5. WITNESSES: William Ricchiuti
Irene Ricchiuti
Ted Schaffer, President of J.S. Ewell
William Lerch - Manager, Exel
Kenneth J. Novacick, Jr. - Supervisor, Exel
Gerald W. Rothacker, Jr., M.D.,
by deposition.
6. EXHIBITS: Weather summary
Defendant's snow removal sheet
Findley Construction invoices for snow
removal
Statement of average weekly wage of $BOB.OB
Statement of medical expense and wage loss.
7. SETTLEMENT NEGOTIATIONS: The demand is $45,000. The
defendant has offered $10,000.
Respectfully submitted,
FOWLER, ADDAMS, SHUGHART & RUNDLE
~~
By'
. 1 a A. A ams
Supreme Court I.D. No. 06265
2B South Pitt Street
P.O. Box 20B
Carlisle, PA 17013
(717) 249-B300
Attorneys for Plaintiffs
Date: January 2, 1997
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McNEES, WALL^CE l1c NURICI<
tOO "INI!: IITnEET
OCT 2 2 19!JW IJ.
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WILLIAM J. RICCHIUTI and
IRENE RICCHIUTI,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 95-65B5 Civil Term
v.
EXEL LOGISTICS, INC.
Defendants
JURY TRIAL DEMANDED
D.rIHDAHT'S PR.TRIAL IIDIORANDUN
1. FACTS AS TO LIABILITY.
The accident occurred on February 14, 1994. At that time,
Plaintiff was operating a tractor-trailer on the premises of
Defendant. While attempting to drop off this trailer and
disconnect it from the tractor, Plaintiff slipped on ice and snow
and fell. The community where the accident occurred had received
heavy snow fall on a regular basis for weeks prior to the date of
the accident. Ice and snow had accumulated throughout the
community over that several week period. On approximately
February 11, 1994, another snow fall of more than eight inches
fell in the community and at the facility of Defendants. This
snow fall was plowed on February 12, 1994. No further snow fell
between that date and the date of the accident and, while snow
and ice did exist in the parking area where the accident
occurred, there were no ridges or hills which obstructed either
automobile traffic or foot traffic. Plaintiff was aware of the
general slippery conditions but nonetheless slipped.
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2 . DAMAGES.
aAA Pre-trial Memorandum of Plaintiffs. As set forth in the
plaintiff's pretrial Memorandum all the medical expenses and wage
losses have been covered by insurance. Such expenses therefore
are not recoverable in this action.
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PRINCIPAL ISSUES OF LIABILITY AND DAMAGES.
Defendant contests liability. General slippery conditions
were in effect at the time of the accident and there were no
3.
hills or ridges on the premises where the accident occurred.
Under Pennsylvania law, a landowner is not liable for a slip and
fall under such circumstances. ~ Fredrick v. Katsifis, 44
cumberland 466 (1995), a copy of which is attached hereto as
Exhibit nAn.
As to damages, Plaintiff cannot present evidence or seek
recovery for medical expenses or wage loss, as those items have
been covered by his workers' compensation carrier. See 75 Pa.
C.S.A. Section 1722; postorino v. Schrooe, 736, F. Supp. 639
(E.D. Pa. 1990).
4 . SUMMARY OF LEGAL ISSUES.
other than the matters raised under Item 3, none are
anticipated.
5. IDENTITY OF WITNESSES TO BE CALLED.
1. William Ricchiuti
2. William Lerch, manager from Exel Logistics, Inc.
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McNEES, WALLACE & NURICK
....TTORNEYS ....T L....W
100 PINE STREET
P.o. BOX IIBO
HARRISSURG. PA 17108,118"
TUIPHON111111232-8ooo FAX 17171237.15300
'200 G STREET N.W.
SUITE 800
WASHINGTON. D.C. 2000"'
TU..HONlIZOZI434,8&&\ r..IZOZI434,8707
http://WWW.mwn.com
MICIIABL R. KBLLBY
DI.acT DU~&.I (1111 007.aOQQ
&MAn. ADD....l "..loLa...eMW".cOM
December 24, 1996
The Honorable Harold E. Sheely
cumberland county Courthouse
1 Courthouse square
Carlisle, PA 17013
Re: Ricchiuti v. Exel Logistics, Inc.
C.P. cumberland County No. 95-65B5 Civil Term
Dear Judge Sheely:
The above-referenced case is scheduled for a pretrial
conference on January 2, 1997. As you may recall, this case was
continued from the previous trial term. We already had a
pretrial conference in this case prior to the last trial term.
I am scheduled to be on vacation from December 25, 1996
through January 6, 1997. It does not appear that another
pretrial conference is necessary. I have spoken with plaintiff's
counsel, Bill Addams, and he agrees.
Accordingly, unless Your Honor insists on having the
pretrial conference, we request that it be cancelled or
rescheduled to a date following January 6, 1997.
Thank you for your consideration.
Sincerely,
::.EEM::riJ .t~CKJL
Michael R. Kelley~
MRK/mrs
cc: William A. Addams, Esquire
nEe 3 0 19'11'
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WILLIAN J. aICCHIUTI and I IN mli COURT OF CONNON PLDS OF
IRJ:HJ: aICCBIUTI, I CUNBJ:RLAND COUN'l'Y, PJ:NNSYLVANIA
plaintiff8 I
I CIVIL ACTION - LAW
V. I
I 95-6585 CIVIL TliRH
U:liL LOGISTICS, INC., I
Def8ndant I JURY 'l'RIAL DJlllANDJ:D
IN aliI paB'l'RIAL CONPliallNCIi
At a pretrial conference held Wedne.day, October 23,
1996, before the Honorable Harold Ii. Sheely, pre.ident Judge,
pre.ent for the plaintiff wa. William A. Add..., Ii.quire.
a.pre.enting the Defendant wa. Michael a. Kelley, Ii.quire. 'l'hi.
i. a jury trial which .hould take two day. at lIIO.t, probably a
day and a half.
plaintiff wa. a truck driver employed by J.S.
Ilwel1 Trucking COIIpany, and on February 14th, 199., wa. driving
a tractor trailer to the prami.e. of the Defendant in New
lCing.town. A lot of .now had fallen in day. before February
1.th, and there,_y have been .ome new .now on that date. A.
the Defendant wa. in the proce.. of di.connecting the tractor
from the trailer, he .lipped on ice and .now and fell.
'l'he Plaintiff indicate. that a. a re.ult of the
fall the workman'. COllp carrier paid $3,831.16 for medical
expen.e., and $35,800.73 for lo.t wage. and po..ibly .ome for
future lo.t wage.. Plaintiff claim. that hi. weekly wage prior
to the accident wa. $808.08, and that after the accident hi.
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95-1585 CIVIL ~RM
wag.. .r. only '7.5.08 p.r w..k.
I would ..k th.t ..ch coun..l provide to .. .
propo..d charg. to the jury on the hill. and ridg.. doctrin.,
and on. or two r.c.nt c.... on th.t i..u.. I would al.o ..k
"
that coun..l provide to .. r.c.nt c.... .. to wh.th.r or not
plaintiff can r.cov.r ..dic.l and wag. 10.... that have b..n
paid for by hi. company'. workm.n'. comp.n..tion carri.r, and
.1.0 wh.th.r und.r the f.ct. of thi. ca.. Pl.intiff can mak. a
cl.ta for future lo.t ..rning c.p.city without the t..timony of
an exp.rt.
I would a.k that coun..l bri.f tho.. i..u.. and
give them to .. on or b.for. Tu..day, Novemb.r 5, 1991, .0 that
I ..y have an id.. a. to how I will b. d.ciding th... i..u... I
would .1.0 a.k coun..l bri.f for .. wh.th.r or not Mr. Ricchiuti
would b. d....d to b. . bu.in... vi.itor, and if .0, what the
liability i. of . prop.rty own.r for a bu.in... vi.itor on the
prop.rty.
Both p.rti.. plan to introduc. w..th.r .ummari..,
and I would ..k that th.y ..ch taka . look .t wh.t the oth.r
p.rty propo... to introduc., and if th.r.'. any obj.ction
th.r.to l.t .. know of th.t .1.0 by Novemb.r 5th, 1991, and I
will g.t coun..l in and w.'ll t.k. . look .t wh.t the obj.ction
i. about.
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95-1515 CIVIL ~RM
.
,
~ of the pretrial conference there ... no
.tipulation a. to the weekly ..ge. of the plaintiff, an4,
therefore, unle.. they agree to thi., the Plaintiff .hou14 have
.o.&ooe here froa hi. .-ployer to te.tify a. to tho.e .-aunt..
Plaintiff. 4eaan4 a. of now i. $150,000.00, &D4
the nefen4aDt ha. offera4 $10,000.00. Plaintiff i. .till
.-ploye4 by ....11 Trucking COIIpany, al though 1Ir. A4d-.-
iD4icate4 that he ia no longer able to 40 heavy lifting
involve4, an4 that'. the rea.on for the re4uce4 ..ekly .alary.
By the Court,
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Michael a. Kelley, ..quire
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WILLIAM J. RICCHIUTI and
IRBNE RICCHIUTI,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 95-65B5 Civil Term
v.
EXBL LOGISTICS, INC.
, Defendant
JURY TRIAL DEMANDED
DEFBNDANT'S MOTION IN LIMINE TO PRECLUDE
INTRODUCTION OF SNOW REMOVAL RECORD DATED FEBRUARY 15. 1994
Detendant anticipates that Plaintiffs will attempt to
introduce into evidence a record of snow plowing at the Exel
Logi.tic.' parking lot which was completed following Plaintiff's
accid.nt. Set forth more fully below, such evidence is
inadmi..ible a. a subsequent remedial repair.
The Pennsylvania Supreme Court, in the cases Incollinqo v.
.wina, ~8a A.~d a06, 444 Pa. 263 (1971) and Pressler v. City of
Pittaburah, ~14 A.2d 616, 419 Pa. 440 (1965), established that
evidence of subsequent remedial repairs is inadmissible for
purpo.e. of proving negligence against the defendant. More
recent cases have continued to apply this rule with facts similar
to thOle involved in this case.
The Superior Court recently held that a trial court abuses
its dilcretion when it admits evidence of subsequent remedial
mealure. to demonstrate prior negligence. In Armstronq v. Paoli
Memorial Hospital, 633 A.2d 605, 430 Pa. Super. 36, acceal
denied, 649 A.2d 666, 53B Pa. 663 (1993), the court considered
~
whether a subsequent change to a hospital policy was admissible
to show that the hospital failed in its obligation to plaintiff
prior to the change in policy. The court held:
When a trial court allows evidence of subsequent
remedial measures to be introduced to demonstrate prior
negligence, as it did here, it abuses its discretion.
633 A.2d at 607-0B.
subsequent remedial measures can be admissible to show
feasibility where a party claims that a repair was not feasible,
to show control, or to impeach relevant testimony. Leahart v.
Montour Railroad Co., 150 A.2d B36, 395 Pa. 469 (1959). None of
those factors are relevant in this case. The feasibility of
plowing the parking lot is not at issue. Obviously, it could be
plowed. There is no dispute about Exel Logistics' control over
the parking lot. Finally, Exel Logistics' expected testimony is
that the parking lot was plowed and that no dangerous hills or
ridges existed on the parking lot at the time of Plaintiff's
accident. The plowing invoice does not contradict this
statement, as the invoice refers to removal of snow and ice from
the dock areas in the parking lot, which were not involved in
Plaintiff'L accident.
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"
por the rea.one eet forth above, the snow removal invoice of
Pebruary 15, 1994 ie inadmissible and should not be presented as
evidenoe in thi. oase.
McNEES, w~~ & NURICK
By M.,LY ~. ~
c ael R. Kelley
Attorney I.D. No. 5BB54
100 Pine Street
P. O. Box 1166
Harrisburg, PA 1710B-1166
(717) 232-BOOO
Attorneys for Defendant
Exel Logistics, Inc.
Dated I '\1" In
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CmlnFlCATE OF SmlVICE
I hereby certify that on this date I have served a true and correct copy of the foregoinl
Praecipe by fint-class mail, postage prepaid, upon the followinl counsel of record:
Attornev for Plaintiff:
William A. Addams, Esquire
28 South Pitt Street
P.O. Box 208
Carlisle, P A 17013
.,
Dated: February~. 1997
/YJ..).JJ (? ~
Michael R. Kelley
Attorney for Defendant Exel Lopstics, Inc.
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