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HomeMy WebLinkAbout91-3053 CivilAPOCALYPTIC THINKER Shiloh Harry William Theriault, for Himself and as Fiduciary for ; Others as a Class of Plaintiffs and Petitioners V. PRE-APOCALYPTIC THINKERS, as Themselves and as a Class of Defendants and Respondents, Including but Not Limited to the : Following Residents and/or Officials of the Commonwealth ; or State of Pennsylvania, United : States of America: (1) RAYMOND L. : GOVER,Publisher, THE PATRIOT-NEWS : COMPANY; (2) PETE SHELLEM, Reporter; (3) IRVIN KITTRELL, III, Reporter; (4) JOHN TROUTMAN, ; City Editor; (5) DALE A. DAVENPORT, Editor; (6) JOHN A. KIRKPATRICK, Editor; (7) DONALD : A. GRIES, SR., Usurpator, WORLD : OF CARPETS, INC.; (8) LLOYD H. ; MORGAN, Co-Usurpator; (9) BENJAMIN R. JONES a/k/a "Major Zero"; (10) ARTHUR T. McDERMOTT & ASSOCIATES, Attorneys; (11) Squire JOHN L. PERRY; (12) GREGORY J. TRAYER; (13) DAVE WILEY; (14) SANDY: SGRIGNOLI; (15) WILLIAM J. KING, : JR., Esquire; (16) SIDNEY I. KELLAM, Owner of Summerdale Plaza; : (17) SHIRLEY E. KELLAM, Wife of : Owner, Summerdale Plaza; (18) Policeman MICHAEL GWIRTZ of : West Fairview Borough; (19) Mayor : EUGENE SHADLE, West Fairview; (20) Policeman FLOYD MORROW, of : Wormleysburg Borough; (21) Chief : RICHARD DOUGHERTY of East Pennsboro-Township; (22) JOHN FREY,: Chief of Detectives, East Pennsboro; (23) Detective LANDIS, : East Pennsboro; (24) ROBERT V. MANLOVE, District Justice of Camp Hill; (25) Squire JOHN M. SHUGARS; : (26) Squire HERSCHEL LOCK; (27) CAROL J. LINDSAY, Esquire of : "FLOWER, KRAMER, MORGENTHAL & FLOWER"; (28) Squire MARKIAN R. SLOBODIAN OF "McNEES, WALLACE & NURICK"; (29) Chief Public . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Defender and Candidate Judge ; TAYLOR P. ANDREWS of Cumberland : County; (30) ELLEN BARRY, Assistant: Public Defender; (31) ROBERT B. : MacINTYRE, Esquire of "MacINTYRE & : MacINTYRE";(32) GUY J. DePASQUALE, : Esquire; (33) SHAWN WAGNER, Esquire, District Attorney's : Office, Cumberland County; : (34) Sheriff TOM KLINE of : Cumberland County; (35) Judge : EDGAR BAYLEY of Cumberland County; : (36) Judge GEORGE HOFFER of Cumberland County; (37) Judge KEVIN HESS, Cumberland County; (38) President Judge HAROLD SHEELY of Cumberland County; (39) SCOTT D.: MOORE, Assistant Public Defender; (40) H. ANTHONY ADAMS, Assistant Public Defender; (41) ANDREA I. : KONOW, Assistant Public Defender; (42) TIMOTHY L. CLAWGES,Assistant Public Defender; (43) Banker : WILLIAM J.KING, SR.; (44) DAVID R. : GETZ, Esquire of "WIX, WENGER, : WEIDNER, FENSTERMACHER & GUNNISON";: (45) DONEGAL MUTUAL INSURANCE : COMPANY; (46) Ex -Governor RICHARD ("DICK") THORNBURGH; (47) Governor ROBERT CASEY; (48) BARBARA J. : SMITH, Chief of Equity, DEPARTMENT OF EDUCATION; (49) SCHOOL DISTRICT FOR CUMBERLAND COUNTY NO. 3053 CIVIL 1991 IN RE: DEFENDANTS' PRELIMINARY OBJECTIONS BEFORE OLER, J. ORDER OF COURT AND NOW, this 3 r�L day of November, 1993, upon consideration of certain Defendants' Preliminary Objections to Plaintiff's Complaint, as well as the briefs submitted on the matter, the preliminary objections are GRANTED as indicated in the accompanying Opinion, and Plaintiff's Complaint is DISMISSED as to those Defendants. BY THE COURT, J esley Oler, J J. r Court Administrator Cumberland County Court House Carlisle, PA 17013 Shiloh Harry William Theriault, Plaintiff No. 90987-131 P.O. Box 700 Minersville, PA 17954 Craig J. Staudenmaier, Esq. North Market Square Bldg. P.O. Box 840 Harrisburg, PA 17108 Attorney for Defendants Glover, Shellem, Kettrell, Troutman, Davenport, Kirkpatrick Arthur McDermott, Esq. 50 East High Street Carlisle, PA 17013 Attorney for Defendants Donald Gries, Sr., Morgan, Perry Benjamin R. Jones 417 State Road West Fairview, PA 17025 Gregory J. Trayer c/o World of Carpets 4735 Enola Road Newville, PA 17241-9748 Dave Wiley c/o World of Carpets 4735 Enola Road Newville, PA 17241-9748 Sandy Sgrignoli c/o World of Carpets 4735 Enola Road Newville, PA 17241-9748 Thomas A. French, Esq. 1 South Market Square P.O. Box 1146 Harrisburg, PA 17108-1146 Attorney for Defendants William J. King and William J. King, Jr. Carol Lindsay, Esq. 11 East High Street Carlisle, PA 17013 Attorney for Defendants Sidney I. Kellam and Shirley E. Kellam Frank J. Lavery, Jr., Esq. 130 Locust Street P.O. Box 811 Harrisburg, PA 17108-0811 Attorney for Defendants Gwirtz, Shadle, Morrow, Dougherty, Frey, Landis John Shugars, Esq. 3207 North Front Street Harrisburg, PA 17110 Herschel Lock, Esq. 3207 North Front Street Harrisburg, PA 17110 David E. Lehman, Esq. and Michael R. Kelley, Esq. 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 Attorneys for Defendant Slobodian David J. Lanza, Esquire C. Roy Weidner, Jr., Esq. 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Attorney for Defendants Andrews, Barry, Kline, Moore, Adams, Konow, Clawges Howard M. Holmes, Esq. Office of Pennsylvania Courts 1515 Market Street, Suite 1414 Philadelphia, PA 19102 Attorney for Defendants Bayley, Hoffer, Hess, Sheely, Manlove David R. Getz, Esq. 508 North Second Street P.O. Box 845 Harrisburg, PA 17108-0845 Michael S. Grab, Esq. 109 S. Market Street Elizabethtown, PA 17022 Attorney for Defendant Donegal Mutual Insurance Company Richard Thornburgh, Esq. 240 North Third Street Harrisburg, PA 17101 Amy Putnam, Esq. 17th F1. Harristown II 333 Market Street Harrisburg, PA 17101 Attorney for Defendants Casey, Smith Joseph A. Ricci, Esq. 1323 North Front Street Harrisburg, PA 17102 Attorney for Defendant MacIntyre :rc APOCALYPTIC THINKER Shiloh Harry William Theriault, for Himself and as Fiduciary for Others as a Class of Plaintiffs and Petitioners V. PRE -APOCALYPTIC THINKERS, as : Themselves and as a Class of Defendants and Respondents, : Including but Not Limited to the Following Residents and/or Officials of the Commonwealth or State of Pennsylvania, United States of America: (1) RAYMOND L. GOVER,Publisher, THE PATRIOT -NEWS COMPANY; (2) PETE SHELLEM, : Reporter; (3) IRVIN KITTRELL, : III, Reporter; (4) JOHN TROUTMAN, City Editor; (5) DALE A. : DAVENPORT, Editor; (6) JOHN A. : KIRKPATRICK, Editor; (7) DONALD A. GRIES, SR., Usurpator, WORLD : OF CARPETS, INC.; (8) LLOYD H. MORGAN, Co-Usurpator; (9) BENJAMIN R. JONES a/k/a "Major Zero"; : (10) ARTHUR T. McDERMOTT & : ASSOCIATES, Attorneys; (11) Squire JOHN L. PERRY; (12) GREGORY J. : TRAYER; (13) DAVE WILEY; (14) SANDY: SGRIGNOLI; (15) WILLIAM J. KING, : JR., Esquire; (16) SIDNEY I. : KELLAM, Owner of Summerdale Plaza; (17) SHIRLEY E. KELLAM, Wife of Owner, Summerdale Plaza; : (18) Policeman MICHAEL GWIRTZ of West Fairview Borough; (19) Mayor EUGENE SHADLE, West Fairview; : (20) Policeman FLOYD MORROW, of Wormleysburg Borough; (21) Chief RICHARD DOUGHERTY of East : Pennsboro'Township; (22) JOHN FREY,: Chief of Detectives, East Pennsboro; (23) Detective LANDIS, East Pennsboro; (24) ROBERT V. MANLOVE, District Justice of Camp Hill; (25) Squire JOHN M. SHUGARS; (26) Squire HERSCHEL LOCK; (27) CAROL J. LINDSAY, Esquire of "FLOWER, KRAMER, MORGENTHAL & FLOWER"; (28) Squire MARKIAN R. SLOBODIAN OF "McNEES, WALLACE : & NURICK"; (29) Chief Public IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Defender and Candidate Judge TAYLOR P. ANDREWS of Cumberland : County; (30) ELLEN BARRY, Assistant: Public Defender; (31) ROBERT B. : MacINTYRE, Esquire of "MacINTYRE & : MacINTYRE";(32) GUY J. DePASQUALE, : Esquire; (33) SHAWN WAGNER, : Esquire, District Attorney's : Office, Cumberland County; (34) Sheriff TOM KLINE of : Cumberland County; (35) Judge : EDGAR BAYLEY of Cumberland County; : (36) Judge GEORGE HOFFER of : Cumberland County; (37) Judge : KEVIN HESS, Cumberland County; (38) President Judge HAROLD SHEELY of Cumberland County; (39) SCOTT D.: MOORE, Assistant Public Defender; (40) H. ANTHONY ADAMS, Assistant Public Defender; (41) ANDREA I. : KONOW, Assistant Public Defender; (42) TIMOTHY L. CLAWGES,Assistant Public Defender; (43) Banker : WILLIAM J.KING, SR.; (44) DAVID R. GETZ, Esquire of "WIX, WENGER, : WEIDNER, FENSTERMACHER & GUNNISON";: (45) DONEGAL MUTUAL INSURANCE : COMPANY; (46) Ex -Governor RICHARD ("DICK") THORNBURGH; (47) Governor ROBERT CASEY; (48) BARBARA J. : SMITH, Chief of Equity, DEPARTMENT OF EDUCATION; (49) SCHOOL DISTRICT FOR CUMBERLAND COUNTY Oler, J. NO. 3053 CIVIL 1991 IN RE: DEFENDANTS' PRELIMINARY OBJECTIONS BEFORE OLER, J. OPINION AND ORDER OF COURT At issue in the present case are preliminary objections by many of the numerous defendants named in a Complaint filed by Shiloh Harry William Theriault (Plaintiff). More specifically, the following defendants have filed preliminary objections to the No. 3053 Civil 1991 Complaint that are now to be disposed of:' Michael Gwirtz, Mayor Eugene Shadle, Richard Dougherty, John Frey, Detective Landis, Floyd Morrow, Robert MacIntyre, Barbara J. Smith, Robert P. Casey, Carol J. Lindsay, David R. Getz, Richard Thornburgh, Sidney I. Kellam, Shirley E. Kellam, William J. King, William J. King, Jr., Donegal Mutual Insurance Company, Markian R. Slobodian, McNees, Wallace & Nurick, Hershel Lock, John M. Shugars, Guy J. DePasquale, Raymond L. Gover, The Patriot News Company, Pete Shellem, Irvin Kittrell, III, John Troutman, John A. Kirkpatrick, Dale A. Davenport, Judges Edgar B. Bayley, George E. Hoffer, Kevin A. Hess, and Harold E. Sheely, and District Justice Robert V. Manlove. With the exception of Michael Gwirtz, Mayor Eugene Shadle, Richard Dougherty, John Frey, Detective Landis and Floyd Morrow, the above- named defendants have all filed preliminary objections in the form of a motion to dismiss Plaintiff's Complaint due to improper service of process. These preliminary objections are based upon the fact that a copy of the Complaint was served upon the defendants via "First Class U.S. Mail."' Additionally, Defendants Gwirtz, Shadle, Dougherty, Frey, Landis and Morrow have filed a preliminary objection in the nature of a demurrer. 1 Other preliminary objections which may have been filed in this case have not yet been listed for argument and, therefore, are not before the Court at this time. See Order of Court, July 7, 1993. 2 Plaintiff's Petition, paragraph 22. 4 No. 3053 Civil 1991 In response to these preliminary objections, Plaintiff has filed a "Rule 401(b)(1) Motion or Petition and Supporting Brief to Strike All Pleadings of All Defendants," contending that this Court "is without jurisdiction over the defendants to hear their responses ....i3 For the reasons set forth in this Opinion, the defendants' preliminary objections are granted. On September 5, 1991, Plaintiff filed a 230 -page Complaint which contained 482 paragraphs and named fifty-two parties as defendants. Plaintiff allegedly brought this action as a representative of "all putative members of the aggrieved class,i" with this class being designated as "the first Apocalyptarians on this planet, because they are beginning to think Apocalyptically.i' In his Complaint, Plaintiff sets forth "the simplest definition of a beginning Apocalyptarian (as] somebody who knows the difference between the FALSE FIRST COMMANDMENT of the jealous preacher Moses, *'I the Lord you God am a jealous God,' and the REAL FIRST COMMANDMENT of our eternally unjealous Creator, '*Let there be light.ir6 Plaintiff avers that each of the fifty-two defendants named in his Complaint "is a person or individual who does not yet know or understand the Apocalyptic difference between the False 3 Plaintiff's Petition, paragraph 3. ° Plaintiff's Complaint, paragraph 3. 5 Plaintiff's Complaint, paragraph 6. 6 Plaintiff's Complaint, paragraph 9. 3 No. 3053 Civil 1991 First Commandment of the jealous politician Moses ... and the Real First Commandment of their eternally unjealous Creator."' Thus, Plaintiff avers, "each such defendant is a worshipper of Jealousy, ... and this is what they are enforcing through their behavior as their religion and politics against the plaintiffs and others, sincerely believing it to be God in many instances, whereas it is the devil, since jealousy never did any good in this world, and is incapable of doing good.i8 Plaintiff's Complaint also sets forth thirty-four Counts against the numerous defendants in which Plaintiff alleges causes of action ranging from libel, unfair trade practices and monopolizing competition methods, perjury, subornation of crimes, theft by deception and deprivation of property, retail theft, unauthorized use of business insignia, credit card fraud and company telephone abuse, public nuisance erection and utility pole violations, false arrest, intentional abuse of eavesdropping law, attorney malpractice, and manipulation of evidence and time by judges and others.' Additionally, Plaintiff is seeking "monetary, injunctive, declaratory, equitable or mandatory relief ... ' Plaintiff's Complaint, paragraph 35. 8 Plaintiff's Complaint, paragraph 36. ' By no means is this meant to be an exhaustive list of the causes of action which Plaintiff attempts to set forth in his Complaint. 4 No. 3053 Civil 1991 exceeding more than a Half Billion Dollars ($500,000,000).1110 Initially, the Court will address the motion to dismiss due to improper service of process which has been filed by most of the defendants." Pennsylvania Rule of Civil Procedure 400(a) provides that "original process shall be served within the Commonwealth only by the sheriff." In this regard, "[t]he rules relating to service of process must be strictly followed, and jurisdiction of the court over the person of the defendant is dependent upon proper service having been made." Sharp v. Valley Forge Medical Center and Heart Hospital, Inc., 422 Pa. 124, 127, 221 A.2d 185, 187 (1966). Furthermore, "the return [of service] itself is required to set forth service in conformance with the Rules." Id. On this issue, the Commonwealth Court of Pennsylvania has recently held that dismissal of a complaint is proper when it was sent to the defendant via certified mail because such service did not comply with the requirements set forth in Rule 400. Mooney v. Commonwealth of Pennsylvania, Borough of West Mifflin, 134 Pa. Commw. 557, 578 A.2d 1384 (1990). In light of the requirements of Rule 400, and in light of the case law applying this rule, the defendants' motion to dismiss Plaintiff's Complaint due to improper service of process must be granted. Plaintiff sent copies of his Complaint to the above named 10 Plaintiff's Complaint, paragraph 2. 11 See text following note 1 supra. 5 No. 3053 Civil 1991 defendants via the mail. As stated in Mooney, such method of service renders the Plaintiff's Complaint subject to dismissal." With respect to the demurrer filed by Defendants Gwirtz, Shadle, Dougherty, Frey, Landis, and Morrow, it is well settled in Pennsylvania that, to sustain a preliminary objection in the nature of a demurrer, the Court must find that, "on the facts averred, the law says with certainty that no recovery is possible, and where a doubt exists as to whether a demurrer should be sustained, this doubt should be resolved in favor of overruling it." Scarpitti v. Weborg, 530 Pa. 366, 369, 609 A.2d 147, 148-49 (1992). In light of this standard, the allegations of Plaintiff's Complaint, as they relate to these particular defendants, may be summarized as follows: In Count XX of his Complaint, Plaintiff avers that Defendants Gwirtz, Shadle, Dougherty, Frey, Landis, and Morrow have committed "Taciteer Influenced Political Corruption", by "remain[ing] silent or unspoken to the public about the ways in which the taciteers are tiping one another off behind the scenes of government or any part of the system of Civilization to do uncivilized things to others ...."13 Moreover, Plaintiff avers, the defendants "traspassed on 12 It should also be noted that this Court has not been provided with a return or proof of service indicating that service has been made upon the defendants in conformance with the Rules of Civil Procedure. 13 Plaintiff's Complaint, paragraph 313. 6 No. 3053 Civil 1991 the rights and violated the equity that the Apocalyptically thinking plaintiffs herein are constitutionally entitled to enjoy, ... since all of the defendants have, in one way or another, refused to adhere to the Stable Definition Factor in the public laws which writtenly guarantee the human rights transgressed defendantly.i14 In this Count, Plaintiff demands "Declaratory Judgment and Ancillary Relief against the defendants requiring them to adhere to the STABLE DEFINITION FACTOR in the public laws."" In Count XXII of the Complaint, Plaintiff avers that Defendants Gwirtz and Morrow, while wearing their police uniforms "along with handcuffs and very `bad attitudes' showing in their faces and way of swaggering, huffing and a -puffing, did intensely burst through the front door of [Plaintiff's] World of Carpets enterprise and menacingly [approached] the supreme decision -maker of such private enterprise, [Plaintiff].i16 At this time, Plaintiff avers, Defendants Gwirtz and Morrow prevented Plaintiff from proceeding to his office, and thus frustrated Plaintiff's attempts to comply with an alleged court order.17 In Count XXIII of his Complaint, Plaintiff avers that 14 Plaintiff's Complaint, paragraph 314. In paragraphs 316 through 319 of his Complaint, Plaintiff attempts to set forth an explanation of the Stable Definition Factor. 15 Plaintiff's Complaint, Count XX, Wherefore clause. 16 Plaintiff's Complaint, paragraph 336. 17 Plaintiff's Complaint, paragraph 340. 7 No. 3053 Civil 1991 Defendants Gwirtz, Morrow, Dougherty, Frey and Landis falsely arrested him on May 2, 1991.18 In so contending, Plaintiff challenged the warrant upon which his arrest was based by stating that District Justice Robert V. Manlove signed the criminal complaint as the Complainant and also as the Issuing Authority.19 As such, Plaintiff contends, the "Warrant was invalid at the time of the arrest. I"' In this Count, Plaintiff also avers that Defendant Shadle's "taciteer influence and political corruption caused the police deterioration in West Fairview borough that Patrolman Gwirtz was now running for Shadle as the chief of the only police left in that borough: Gwirtz himself. "21 Additionally, Plaintiff contends that "he was cast in [the Cumberland County Prison] and kept from posting any sort of reasonable bail by every unconstitutional tactic their corrupt political machine could conjure up with their pre -Apocalyptic thinking and the Jealousy of the devil on which it fed. ,22 Under Section 221(1) of the Political Subdivision Tort Claims Act, "no local agency shall be liable for any damages on account of an injury to a person or property caused by any act of the local 18 Plaintiff's Complaint, paragraph 343. 19 Plaintiff's Complaint, paragraph 344. 20 id. 21 Plaintiff's Complaint, paragraph 347. 22 Plaintiff's Complaint, paragraph 350. C No. 3053 Civil 1991 agency or an employee thereof or any other person." Act of October 5, 1980, P.L. 693, 42 Pa. C.S. §8541. Moreover, "[a]n employee of a local agency is liable for civil damages on account of any injury ... caused by acts of the employee which are within the scope of his office or duties only to the same extent as his employing local agency." Id., 42 Pa. C.S. §8545. In this regard. where an action is "brought against an employee of a local agency for damages on account of an injury ... based upon claims arising from, or reasonably related to, the office or the performance of the duties of the employee, the employee may assert ... ... [t]he defense that the conduct of the employee which gave rise to the claim was authorized or required by law, or that he in good faith reasonably believed the conduct was authorized or required by law. Act of October 5, 1980, P.L. 693, 5221(1), 42 Pa. C.S. 58546. Furthermore, the defense of "[official] immunity may be raised by preliminary objections in the nature of a demurrer where it is apparent on the face of the pleading that the cause of action does not fall within any of the exceptions to [official] immunity." Gallagher v. City of Phila., 142 Pa. Commw. 487, 492, 597 A.2d 747, 749 (1991x. The Act further provides eight specific acts by a local agency which "may result in the imposition of liability on a local agency," 23 and specifically states that the official immunity 23 See 42 Pa. C.S. 58542(b). 0 No. 3053 Civil 1991 provided therein shall not apply where "it is judicially determined that the act of the employee caused the injury and that such act constituted a crime, actual fraud, actual malice or willful misconduct." Id. Act of October 5, 1980, P.L. 693, §221(1), 42 Pa. C.S. §8550. These exceptions to the rule of immunity "must be narrowly interpreted given the expressed legislative intent to insulate political subdivisions from tort liability." Mascaro v. Youth Study Center, 514 Pa. 351, 361, 523 A.2d 1118, 1123 (1987). In light of the specific provisions of the Political Subdivision Tort Claims Act, and in light of the requirement that the exceptions to official immunity be narrowly construed, this Court cannot say that Plaintiff's Complaint has pled facts sufficient to avoid the immunity created by the Act or, for that matter, to state a recognizable cause of action. Initially, it should be noted that there is no duty imposed upon Defendants to "adhere to the Stable Definition Factor." Moreover, the conduct of which Plaintiff complains does not fit into one of the eight acts for which local agency immunity has been waived. Finally, the actions of Defendants Gwirtz, Morrow, Dougherty, Frey and Landis were conducted pursuant to a warrant signed by District Justice Manlove, and, as such, this Court cannot say that such actions constituted a crime, actual fraud, actual malice or willful misconduct. Consequently, the preliminary objection of Defendants Gwirtz, Shadle, Dougherty, Frey, Landis and Morrow must be 10 No. 3053 Civil 1991 sustained. ORDER OF COURT AND NOW, this 312e& day of November, 1993, upon consideration of certain Defendants' Preliminary Objections to Plaintiff's Complaint, as well as the briefs submitted on the matter, the preliminary objections are GRANTED as indicated in the accompanying Opinion, and Plaintiff's Complaint is DISMISSED as to those Defendants. BY THE COURT, J Wesley Oler Jr. J. Court Administrator Cumberland County Court House Carlisle, PA 17013 Shiloh Harry William Theriault, Plaintiff No. 90987-131 P.O. Box 700 Minersville, PA 17954 Craig J. Staudenmaier, Esq. North Market Square Bldg. P.O. Box 840 Harrisburg, PA 17108 Attorney for Defendants Glover, Shellem, Kettrell, Troutman, Davenport, Kirkpatrick Arthur McDermott, Esq. 50 East High Street Carlisle, PA 17013 Attorney for Defendants Donald Gries, Sr., Morgan, Perry 11 No. 3053 Civil 1991 Benjamin R. Jones 417 State Road West Fairview, PA 17025 Gregory J. Trayer c/o World of Carpets 4735 Enola Road Newville, PA 17241-9748 Dave Wiley c/o World of Carpets 4735 Enola Road Newville, PA 17241-9748 Sandy Sgrignoli c/o World of Carpets 4735 Enola Road Newville, PA 17241-9748 Thomas A. French, Esq. 1 South Market Square P.O. Box 1146 Harrisburg, PA 17108-1146 Attorney for Defendants William J. King and William J. King, Jr. Carol Lindsay, Esq. 11 East High Street Carlisle, PA 17013 Attorney for Defendants Sidney I. Kellam and Shirley E. Kellam Frank J. Lavery, Jr., Esq. 130 Locust Street P.O. Box 811 Harrisburg, PA 17108-0811 Attorney for Defendants Gwirtz, Shadle, Morrow, Dougherty, Frey, Landis John Shugars, Esq. 3207 North Front Street Harrisburg, PA 17110 12 No. 3053 Civil 1991 Herschel Lock, Esq. 3207 North Front Street Harrisburg, PA 17110 David E. Lehman, Esq. and Michael R. Kelley, Esq. 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 Attorneys for Defendant Slobodian David J. Lanza, Esquire C. Roy Weidner, Jr., Esq. 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Attorney for Defendants Andrews, Barry, Kline, Moore, Adams, Konow, Clawges Howard M. Holmes, Esq. Office of Pennsylvania Courts 1515 Market Street, Suite 1414 Philadelphia, PA 19102 Attorney for Defendants Bayley, Hoffer, Hess, Sheely, Manlove David R. Getz, Esq. 508 North Second Street P.O. Box 845 Harrisburg, PA 17108-0845 Michael S. Grab, Esq. 109 S. Market Street Elizabethtown, PA 17022 Attorney for Defendant Donegal Mutual Insurance Company Richard Thornburgh, Esq. 240 North Third Street Harrisburg, PA 17101 Amy Putnam, Esq. 17th Fl. Harristown II 333 Market Street Harrisburg, PA 17101 Attorney for Defendants Casey, Smith 13 No. 3053 Civil 1991 Joseph A. Ricci, Esq. 1323 North Front Street Harrisburg, PA 17102 Attorney for Defendant MacIntyre :rc 14