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Civil Cover Sheet E-Filing Number: 2010005141

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Civil Cover Sheet E-Filing Number: 2010005141 Court of Common Pleas of Philadelphia County For Prothonotary Use Only (Docket Number) Trial Division Civil Cover Sheet E-Filing Number: 2010005141 PLAINTIFF'S NAME DEFENDANT'S NAME JANE DOE C.B THE DEVEREUX FOUNDATION PLAINTIFF'S ADDRESS DEFENDANT'S ADDRESS 1650 MARKET STREET 52ND FLOOR 444 DEVEREUX DRIVE PHILADELPHIA PA 19103 VILLANOVA PA 19805 PLAINTIFF'S NAME DEFENDANT'S NAME JANE DOE BB THE HELENA DEVEREUX FOUNDATION PLAINTIFF'S ADDRESS DEFENDANT'S ADDRESS 1650 MARKET STREET 52ND FLOOR 444 DEVEREUX DRIVE PHILADELPHIA PA 19103 VILLANOVA PA 19085 PLAINTIFF'S NAME DEFENDANT'S NAME JANE DOE RC DEVEREUX PROPERTIES, INC. PLAINTIFF'S ADDRESS DEFENDANT'S ADDRESS 1650 MARKET STREET, 52ND FLOOR 19 S WATERLOO ROAD PHILADELPHIA PA 19103 DEVON PA 19333 TOTAL NUMBER OF PLAINTIFFS TOTAL NUMBER OF DEFENDANTS COMMENCEMENT OF ACTION X Complaint Petition Action Notice of Appeal 13 21 Writ of Summons Transfer From Other Jurisdictions AMOUNT IN CONTROVERSY COURT PROGRAMS Arbitration Mass Tort Commerce Settlement $50,000.00 or less X Jury Savings Action Minor Court Appeal Minors X More than $50,000.00 Non-Jury Petition Statutory Appeals W/D/Survival Other: CASE TYPE AND CODE 2O - PERSONAL INJURY - OTHER STATUTORY BASIS FOR CAUSE OF ACTION RELATED PENDING CASES (LIST BY CASE CAPTION AND DOCKET NUMBER) IS CASE SUBJECT TO COORDINATION ORDER? YES NO TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Plaintiff/Petitioner/Appellant: JANE DOE C.B , JANE DOE BB , JANE DOE RC , JOHN DOE LC , JANE DOE TC , Papers may be served at the address set forth below. NAME OF PLAINTIFF'S/PETITIONER'S/APPELLANT'S ATTORNEY ADDRESS KRISTEN M. FEDEN 2005 MARKET ST SUITE 2600 PHONE NUMBER FAX NUMBER PHILADELPHIA PA 19103 (215)564-8076 (215)564-8120 SUPREME COURT IDENTIFICATION NO. E-MAIL ADDRESS 307206 [email protected] SIGNATURE OF FILING ATTORNEY OR PARTY DATE SUBMITTED KRISTEN FEDEN Monday, October 05, 2020, 08:51 am PRELIMINARY COPY (For Approval by the Prothonotary Clerk) COMPLETE LIST OF PLAINTIFFS: 1. JANE DOE C.B 1650 MARKET STREET 52ND FLOOR PHILADELPHIA PA 19103 2. JANE DOE BB 1650 MARKET STREET 52ND FLOOR PHILADELPHIA PA 19103 3. JANE DOE RC 1650 MARKET STREET, 52ND FLOOR PHILADELPHIA PA 19103 4. JOHN DOE LC 1650 MARKET STREET, 52ND FLOOR PHILADELPHIA PA 19103 5. JANE DOE TC 1650 MARKET STREET, 52ND FLOOR PHILADELPHIA PA 19103 6. JANE DOE PG 1650 MARKET STREET, 52ND FLOOR PHILADELPHIA PA 19103 7. JANE DOE TH 1650 MARKET STREET, 52ND FLOOR PHILADELPHIA PA 19103 8. JANE DOE DJ 1650 MARKET STREET, 52ND FLOOR PHILADELPHIA PA 19103 9. JANE DOE KM 1650 MARKET STREET, 52ND FLOOR PHILADELPHIA PA 19103 10. JANE DOE BP 1650 MARKET STREET, 52ND FLOOR PHILADELPHIA PA 19103 11. JANE DOE LT 1650 MARKET STREET, 52ND FLOOR PHILADELPHIA PA 19103 12. JANE DOE MW 1650 MARKET STREET, 52ND FLOOR PHILADELPHIA PA 19103 13. JANE DOE YZ 1650 MARKET STREET, 52ND FLOOR PHILADELPHIA PA 19103 COMPLETE LIST OF DEFENDANTS: 1. THE DEVEREUX FOUNDATION 444 DEVEREUX DRIVE VILLANOVA PA 19805 2. THE HELENA DEVEREUX FOUNDATION 444 DEVEREUX DRIVE VILLANOVA PA 19085 3. DEVEREUX PROPERTIES, INC. 19 S WATERLOO ROAD DEVON PA 19333 4. DEVEREUX SCHOOLS, INC. 19 S WATERLOO ROAD DEVON PA 19333 5. DEVEREUX ADVANCED BEHAVIORAL HEALTH 444 DEVEREUX DRIVE VILLANOVA PA 19085 6. DEVEREUX ADVANCED BEHAVIORAL HEALTH 230 HIGHLAND AVENUE DEVON PA 19333 7. DEVEREUX 340 SAINT DAVIDS ROAD NEWTOWN SQUARE PA 18940 8. DEVEREUX ADVANCED BEHAVIORAL HEALTH PENNSYLVANIA 444 DEVEREUX DRIVE VILLANOVA PA 19085 9. DEVEREUX WHITLOCK CENTER 139 LEOPARDS ROAD BERWYN PA 19312 10. WHITLOCK CENTER 139 LEOPARDS ROAD BERQYN PA 19312 11. DEVEREUX PENNSYLVANIA 444 DEVEREUX DRIVE VILLANOVA PA 19355 12. DEVEREUX BENTO CENTER 655 SUGARTOWN ROAD BOX 297 MALVERN PA 19355 13. DEVEREUX CHILDRENS BEHAVIORAL HEALTH SERVICES A/K/A CBHS 655 SUGARTOWN ROAD BOX 297 MALVERN PA 19355 14. DEVEREUX FOUNDATION- GATEWAY SCHOOL 3240 SAINT DAVIDS ROAD NEWTOWN SQUARE PA 18940 15. DEVEREUX FOUNDATION-STONE AND GABLES 3240 SAINT DAVIDS ROAD NEWTOWN SQUARE PA 18940 16. CHILDRENS BEHAVIORAL HEALTH SERVICES BRANDYWINE PROGRAMS 444 DEVEREUX DRIVE VILLANOVA PA 19085 17. DEVEREUX CHIL BEH HEALTH CTR AKA DCBHC AKA DCBHC ACUTE CARE 655 SUGARTOWN ROAD BOX 297 MALVERN PA 19355 18. EVEROL DAVID BRACKETT 1730 S EASTON ROAD DOYLESTOWN PA 18901 19. THE CORSON FOUNDATION 2300 NORTH OFFICE BUILDING HARRISBIRG PA 18120 20. JOHN DOE (1-10) 444 DEVEREUX DRIVE VILLANOVA PA 19085 21. THE DEVEREUX FOUNDATION 139 LEOPARDS ROAD BERWYN PA PA THIS IS NOT AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING IS REQUESTED. SALTZ, MONGELUZZI & BENDESKY, P.C. ATTORNEYS FOR BY: ROBERT J. MONGELUZZI, ESQUIRE, ANDREW PLAINTIFFS DUFFY, ESQUIRE, KRISTEN FEDEN, ESQUIRE, DANIEL CEISLER, ESQUIRE IDENTIFICATION NO.: 36283/77121/307206/326798 1650 MARKET STREET 52ND FLOOR PHILADELPHIA, PA 19103 (215) 496-8282 HELM LAW GROUP d/b/a TOPDOG LAW BY: JAMES D. HELM, ESQUIRE IDENTIFICATION NO.: 326181 1333 RACE STREET, 2ND FLOOR PHILADELPHIA, PA 19107 P: (215) 600-3660 JANE DOE C.B. 1650 Market Street, 52nd Fl PHILADELPHIA COUNTY Philadelphia, PA 19103 COURT OF COMMON PLEAS LAW DIVISION And JANE DOE B.B. 1650 Market Street, 52nd Floor Philadelphia, PA 19103 OCTOBER TERM, 2020 And No. JANE DOE R.C. 1650 Market Street, 52nd Fl Philadelphia, PA 19103 And JOHN DOE L.C. 1650 Market Street, 52nd Fl Philadelphia, PA 19103 JURY TRIAL DEMANDED And JANE DOE T.C. 1650 Market Street, 52nd Fl Philadelphia, PA 19103 And JANE DOE P.G. 1650 Market Street, 52nd Fl Philadelphia, PA 19103 And JANE DOE T.H. 1650 Market Street, 52nd Fl Philadelphia, PA 19103 And JANE DOE D.J. 1650 Market Street, 52nd Fl Philadelphia, PA 19103 And JANE DOE K.M. 1650 Market Street, 52nd Fl Philadelphia, PA 19103 And JANE DOE B.P. 1650 Market Street, 52nd Fl Philadelphia PA 19103 And JANE DOE L.T. 1650 Market Street, 52nd Fl Philadelphia, PA 19103 And JANE DOE M.W. 1650 Market Street, 52nd Fl Philadelphia, PA 19103 And JANE DOE Y.Z. 1650 Market Street, 52nd Fl Philadelphia, PA 19103 v. THE DEVEREUX FOUNDATION 444 Devereux Drive Villanova, PA 19085 And THE DEVEREUX FOUNDATION 139 Leopards Road Berwyn, PA 19312 And THE HELENA DEVEREUX FOUNDATION 444 Devereux Drive Villanova, PA 19085 And DEVEREUX PROPERTIES, INC. 19 S Waterloo Road Devon, PA 19333 And DEVEREUX SCHOOLS, INC. 19 S Waterloo Road Devon, PA 19333 And DEVEREUX ADVANCED BEHAVIORAL HEALTH 444 Devereux Drive Villanova, PA 19085 And DEVEREUX ADVANCED BEHAVIORAL HEALTH 230 Highland Avenue Devon, PA 19333 And DEVEREUX 340 Saint David’s Road Newtown Square, PA 18940 And DEVEREUX ADVANCED BEHAVIORAL HEALTH PENNSYLVANIA 444 Devereux Drive Villanova, PA 19085 And DEVEREUX WHITLOCK CENTER 139 Leopards Road Berwyn, PA 19312 And WHITLOCK CENTER 139 Leopards Road Berwyn, PA 19312 And DEVEREUX PENNSYLVANIA 444 Devereux Drive Villanova, PA 19355 And DEVEREUX BENTO CENTER 655 Sugartown Road Box 297 Malvern, PA 19355 And DEVEREUX CHILDREN’S BEHAVIORAL HEALTH SERVICES a/k/a CBHS 655 Sugartown Road Box 297 Malvern, PA 19355 And DEVEREUX FOUNDATION- GATEWAY SCHOOL 3240 Saint David’s Road Newtown Square, PA 18940 And DEVEREUX FOUNDATION-STONE AND GABLES 3240 Saint David’s Road Newtown Square, PA 18940 And CHILDREN’S BEHAVIORAL HEALTH SERVICES BRANDYWINE PROGRAMS 444 Devereux Drive Villanova, PA 19085 And DEVEREUX CHILDREN’S BEHAVIORAL HEALTH CENTER a/k/a DCBHC a/k/a DCBHC ACUTE CARE 655 Sugartown Road Box 297 Malvern, PA 19355 And EVEROL DAVID BRACKETT 1730 S Easton Road Doylestown, PA 18901 And THE CORSON FOUNDATION 2300 North Office Building Harrisburg, PA 18120 And JOHN DOE (1-10) COMPLAINT – CIVIL ACTION “NOTICE “AVISO “You have been sued in court. If you wish to defend “Le han demandado en corte. Si usted against the claims set forth in the following pages, you must quiere defenderse contra las demandas nombradas en las páginas take action within twenty (20) days after this complaint and siguientes, tiene veinte (20) dias, a partir de recibir esta demanda notice are served, by entering a written appearance y la notificatión para entablar personalmente o por un abogado personally or by an attorney and filing in writing with the una comparecencia escrita y tambien para entablar con la corte en court your defenses or objections to the claims set forth forma escrita sus defensas y objeciones a las demandas contra against you. You are warned that if you fail to do so the case usted. Sea avisado que si usted no se defiende, el caso puede may proceed without you and a judgement may be entered continuar sin usted y la corte puede incorporar un juicio contra against you by the court without further notice for any money usted sin previo aviso para conseguir el dinero demandado en el claimed in the complaint or for any other claim or relief pleito o para conseguir culquier otra demanda o alivio solicitados requested by the plaintiff. You may lose money or property por el demandante. Usted puede perder dinero o propiedad u or other rights important to you. otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU “YOU SHOULD TAKE THIS PAPER TO YOUR ABOGADO INMEDIATAMENTE. SI USTED NO LAWYER AT ONCE. IF YOU DO NOT HAVE A TIENE ABOGADO (O NO TIENE DINERO LAWYER OR CANNOT AFFORD ONE, GO TO OR SUFICIENTE PARA PARGAR A UN ABOGADO), VAYA TELEPHONE THE OFFICE SET FORTH BELOW TO EN PERSONA O LLAME POR TELEFONO LA FIND OUT WHERE YOU CAN GET LEGAL HELP. OFICINA NOMBRADA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA THIS OFFICE CAN PROVIDE YOU WITH LEGAL. ESTA OFICINA PUEDE PROPORCIONARLE INFORMATION ABOUT HIRING A LAWYER. LA INFORMACION SOBRE CONTRATAR A UN IF YOU CANNOT AFFORD TO HIRE A LAWYER, ABOGADO.
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