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   HOLZINGER v. HOLZINGER
              (Continued)
 
2.  Charles H. Holzinger and Millicent B. Holzinger
(hereinafter referred to as "CHARLES" and "MILLICENT")
are adult individuals, husband and wife, who reside at
365 Sylvan Retreat Road, Columbia, Pennsylvania  17512.
 
3.  CHARLES and MILLICENT are REBECCA'S natural
parents.
 
4.  During 2001, REBECCA began to recall various
disconnected events from her childhood.
 
5.  Because REBECCA found some of these events to be
disturbing, in January 2002, she sought professional
assistance from Evergreen Counseling Associates.
 
6.  On or about April 14, 2002, REBECCA read an e-mail
sent to her and the other immediate members of her
family, from her former sister-in-law concerning
certain activities by that woman's former husband,
Tom, REBECCA'S brother.
 
7.  Over the next two weeks, REBECCA experienced
severe emotional distress as she realized that some
of the childhood events she had started to recall
were connected to improper sexual contact by CHARLES.
 
8.  REBECCA recalled an incident from her childhood
when she woke up with CHARLES over her touching her
breasts after having opened her pajama top, while
MILLICENT was present.  The next day when she
confronted MILLICENT about the incident, MILLICENT
told her that it was his {CHARLES} house and he
could do whatever he wanted.
 
9.  REBECCA also recalled an incident when she
awakened to CHARLES touching her breasts, and
MILLICENT telling REBECCA that she {MILLICENT}
was present to make sure CHARLES did not go too far.
 
10.  The conduct of CHARLES and MILLICENT described
above is extreme and outrageous.
 
11.  The extreme and outrageous conduct of CHARLES
and MILLICENT described above caused REBECCA 
severe emotional distress beginning sometime after
April 14, 2002 and which continues to cause REBECCA 
severe emotional distress.
 
12.  The severe emotional distress suffered by
REBECCA as a result of the extreme and outrageous
conduct of CHARLES and MILLICENT described above
has been diagnosed as an adjustment disorder,
depression and post-traumatic stress disorder.
 
13.  The actions of CHARLES and MILLICENT as set
forth above were malicious, wanton, willful, cruel,
oppressive and/or exhibited a reckless indifference
to the rights of REBECCA.
 
WHEREFORE, REBECCA R. HOLZINGER,
demands judgement for compensatory damages
against CHARLES H. HOLZINGER and MILLICENT
B. HOLZINGER, jointly and severally, in an
amount in excess of $50,000 and judgement for
punitive damages against CHARLES H. HOLZINGER and
MILLICENT B. HOLZINGER, jointly and severally,
in an amount in excess of $50,000 plus costs.
 
                  By:  David S. Dessen, Esquire
                  DESSEN, MOSES & SHEINOFF
                  Attorney for Plaintiff
 
           VERIFICATION
 
I, REBECCA R. HOLZINGER, hereby certify
that I am the Plaintiff in the within civil
action and state that the facts set forth in
the foregoing Complaint are true and correct to
the best of my knowledge, information and belief. 
I understand that the statements made herein
are made subject to the penalties of 18 Pa.
C.S.A. & 4904 relating to unsworn falsification
to authorities.
 
Signed by REBECCA R. HOLZINGER on May 3, 2004.
 
 



 

|Please Page Down| |Welcome| |CONTACT US| |THE CABLE GUY| |GRAND JURY| |LANCASTER LYNCHING - 1| |LANCASTER LYNCHING - 2| |LANC. LYNCHING - 3| |LANC. LYNCHING - 4| |LANC. LYNCHING - 5| |LANC. LYNCHING - 6| |DR. FRAUD GETS SMART| |TRIBUNE DAYS - 3| |KRUSHINSKI - 1| |KRUSKINSKI - 2| |KRUSHINSKI - 3| |NOTES - FEB 7-13| |BRIEF OF APPELLEES| |LANCASTER| |TRIBUNE DAYS| |TRIBUNE DAYS - 2| |HOW I GOT SMART/PARODY| |APPEAL/SUPERIOR COURT| |CHARLIE'S PROMISE - 3| |JUDGE'S OPINION| |DEFENDANTS' REPLY| |APPEAL| |PLAINTIFF'S ANSWER| |MEMORANDUM OF LAW| |PRELIMINARY OBJECTIONS| |MAN ON THE SIDEWALK| |HOLZINGER v. HOLZINGER| |THE LETTERS| |TWO EMAILS| |DIPLOMATS 2| |DIPLOMATS SPEAK| |PLANNED PARENTHOOD| |CHARLIE'S PROMISE-1| |CHARLIE'S PROMISE - 2| |DR. FRAUD ON CLYDE| |LETTERS/EDITOR| |NAME CHANGE| |TWILIGHT ZONE| |JOURNEY| |A SIMPLE, SAD STORY| |A FAMILY TRAGEDY| |A FAMILY TRAGEDY-2| |A FAMILY TRAGEDY - 3| |A FAMILY TRAGEDY - 4| |TO MY BROTHERS AND SISTERS| |PUPPIES 4 SALE| |PUPPIES - 2| |ECLIPSE| |CLYDE'S COFFEE| |TALKBACK| |KASEY1| |OPEN LETTER| |ALICE 1| |Best/Worst 3-7 to 13| |Best/Worst 1-16 to 1-10| |REVIEW/POIST ON HARPER| |EMILY LETTER| |NEIGHBORS LETTER| |FAMILY LETTER - 2| |Ph.D DOCUMENT| |TROUBLE'S COMING| |CORTNEY FRY - 1| |CORTNEY FRY - 2| |UNGODLY SILENCE| |HEATHER NUNN - 1| |CORTNEY FRY - 3| |FAMILY LETTER - 3| |ALICE POEMS| |DALRYMPLE V. BROWN| |SUPERIOR COURT| |F&M & INCEST| |NOTES - 1| |NOTES - 2| |NOTES -3| |NOTES - 4| |NOTES - 5| |NOTES - 6| |NOTES - 7| |FAMILY LETTER - 2| |RACIAL INCIDENT| |SUPREME COURT| |SUPREME COURT 2| |LETTER TO JOHN FRY| |TALKBACK| |THANK YOU - LIP NEWS| |CORTNEY FRY - GRAND JURY| |LOUIS FARINA - FIND JURY| |TERRIBLE POLICE WORK| |DO ME A FAVOR| |GAMBLING CRACKDOWN| |GODVOICEHOLZINGER| |VERBAL - TOM CRUISE| |MAYOR STEALING CABLE?| |TED BYRNE| |THE BYRNE GUY|