Opinion
2 JD 2020
03-24-2021
IN RE: Judge Thomas A. Placey Court of Common Pleas 9th Judicial District Cumberland County
RESPONDENT'S PRE-TRIAL MEMORANDUM
AND NOW, this 24th day of March, 2021, comes Respondent, Judge Thomas A. Placey, by any throught counsel, Heidi F. Eakin, and files this Pre-trial Memorandum. A. TRIAL WITNESS LIST
Respondent may call some of the following witnesses at trial: 1. Judge Thomas A. Placey
Judge Placey may testify regarding the issues raised in the Board Complaint. 2. Bryan Bartosik-Velez, Esquire
Attorney Barosik-Velez may testify regarding the issues raised in the Board Complaint. 3. Respondent may call all witnesses identified in the Judicial Conduct Boards Pre-trial memorandum. 4. Respondent specifically reserves the right to supplement the witness list with reasonable notice to the Court and the Board. B. BOARD EXHIBITS Respondent has no objection to the Board Exhibits as outlined in its Pre-trial memorandum. C. STIPULATIONS The Board and counsel for Respondent are actively preparing Joint Stipulations. D. DISCOVERY Respondent acknowledges receipt of full discovery to date.
Respectfully submitted,
Heidi F. Eakin, Esq.
2807 Market Street
First floor
Camp Hill, PA 17011
(717)602-0581
heidieakin@gmail.com
Sup. Ct ID 43893 CERTIFICATE OF SERVICE
I, Heidi F. Eakin, Esquire, attorney for Defendant, do hereby certify that a true and correct copy of this Respondent's Pretrial Memorandum served upon the following individuals be delivering same to the following person at the address below on the below date: Melissa L. Norton
Deputy Counsel
Pa. Supreme Court ID 46684
Judicial Conduct Board
Pennsylvania Judicial Center
Harrisburg, PA 17106 Court of Judicial Discipline
601 Commonwealth Avenue
Harrisburg, PA 17120
BY:
Heidi F. Eakin, Esquire Date: 3-24-2021 CERTIFICATE OF COMPLIANCE
I hereby certify that this filing complies with the provisions of Public Access Policy of the Unified Judicial System of Pennsylvania: Case Records of the Appellate and Trial Courts that requires filing confidential information and documents differently than non-confidential information and documents.
Respectfully submitted,
/s/_________
Heidi F. Eakin
Attorney for Defendant
2807 Market Street
Suite 1
Camp Hill, PA 17011
Sup. Ct. #43893
717-602-0581
heidieakin@gmail.com