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MARY L. STRINGFELLOW,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA
v.
GERALD A. NASH, JR.,
JERRY A. NASH, JR., and
PAGE TRANSPORTATION, INC.
Defendants
CIVIL ACTION - LAW
NO.
JURY TRIAL DEMANDED
COMPLAINT
AND NOW, comes the Plaintiff,MARY L. STRINGFELLOW, by and
through her attorneys, SCHMIDT AND RONCA, P.c., and respectfully
sete forth as follows:
1. The Plaintiff, MARY L. STRINGFELLOW, is an adult
individual who currently resides at 13 Channel Drive, Carlisle,
Cumberland County, Pennsylvania 17013.
2. The Defendant, GERALD A. NASH, JR., is an adult
individual currently residing at 113 Beechwood Avenue, Liverpool,
NY 13088.
3. The Defendant, JERRY A. NASH, JR., is an adult
individual currently residing at 405 Buckley Road, Liverpool, NY
13088.
4. The Defendant PAGE TRANSPORTATION, INC., is a New York
corporation, licensed and/or transacting business in the
Commonwealth of Pennsylvania with a principal business address at
P,O. Box 920, 2758 Trombley Road, Weedsport, NY 13166.
5. The events hereinafter described took place on or about
December 22, 1994, on SR11, near its intersection with south
Middlesex Road in Middlesex Township, Cumberland County,
Pennsylvania.
6. At the aforesaid time and place, the Plaintiff, MARY L.,
STRINGFELLOW, was operating a 1993 Eagle Vision, Pennsylvania
plate registration number ARM7480, traveling south on US 11 in
the left lane and approaching the intersection with south
Middlesex Road.
7. At the aforesaid time and place, the Defendant, GERALD
A. NASH, JR., was operating a 1992 Kenworth Convention tractor
trailer, New York registration plate number PP8795 and traveling
south on SR11 in the left lane behind the Plaintiff STRINGFELLOW,
also approaching South Middlesex Road.
8. At the aforementioned time and place, the Defendant,
GERALD A. NASH, JR., was operating the tractor trailer with the
permission of its owner, Defendant JERRY A. NASH, JR., and acting
as an agent, servant, or employee of Defendant PAGE
TRANSPORTATION, INC.
9. At the aforesaid time and place, the Plaintiff activated
her left turn signal and stopped while she waited for traffic to
clear, so she could turn left onto South Middlesex Road.
10. At the aforesaid time and place, the Defendant, GERALD
A. NASH, JR., failed to observe the Plaintiff who had signaled
and stopped causing him to collide with the rear of the
Plaintiff'S vehicle.
11. As the sole and proximate result of being struck in the
rear by the Defendant, GERALD A. NASH, JR., the Plaintiff's
vehicle was, spun coun~erclockwise until i~ ended up a~ res~ in
~he left nor~hbound lane of US 11.
COUNT I
.ealiaeDoe
Mary L. .~riDafellow Y. Gerald A. .ash. Jr.
12. Paragraphs 1 ~hrough 11 are incorporated herein by
reference and made a par~ thereof as if set for~h in full.
13. The accident was caused solely by the negligence,
carelessness, or recklessness of the Defendant, GERALD A. NASH,
JR., and was in no way caused or contributed to by the Plaintiff,
MARY L. STRINGFELLOW.
14. The Defendant, GERALD A. NASH, JR.'s negligence,
carelessness, and recklessness consisted of:
(8) Failing to have his vehicle under proper and
adequate control;
(b) Failinq to observe the Plaintiff's vehicle lawfully
on the roadway;
(c) F~iling to operate his vehicle in accoI'dance with
existing traffic conditions and traffic controls;
(d) Failing to exercise the high degree of care
required of a motorist approaching an intersection;
(e) Failing to keep a reasonable lookout for other
vehicle. lawfully on the road;
(f) Failing to properly ob.erve and s~op a~ a alearly
m~rked intersection thereby causing the accident;
(q) Operating his vehicle at an excessive rate ot speed
under the circumstances;
(h) Negligently applying the brakes;
(i) Oper.ting his vehicle so as to create a dangerous
situation tor other vehicles lawtully on the roadway;
(j) Failing to drive his vehicle at a speed and in a
manner that would allow him to stop within the assured clear
distance ahead; and
(k) Operating his motor vehicle in violation ot the
pennsylvania Motor Vehicle Code 53714 which is negligence
per se.
15. As the sole and proximate result of the Defendant,
GERALD A. NASH, JR.'s negligence, carelessness, and recklessness,
the plaintitf, MARY L. STRINGFELLOW, suftered severe and
permanent injuries which include:
(a) Pain in her neck, shoulder blades, and upper
thoracic spine;
(b) Central disc herniation of the C5-6 interspace;
(c) Headaches;
(d) Left shoulder pain; and
(e) Anterior cervical discectomy and tusion;
16. As the sole and proximate result of the Defendant,
GERALD A. NASH, JR's negligence, the Plaintiff, MARY L.
STRINGFELLOW, has incurred medical expenses in excess of $10,000
to date and will continue to incur medical expenses into the
tuture.
17. A8 the sole and proximate result of the Defendant,
GERALD A. NASH, JR.'B negligence the Plaintiff, MARY L.
STRINGFELLOW has been obliged to inour the aforementioned
expenseB for medical attention and treatment and may hereinafter
incur the same in the future, and which exceed the BllmB not
recoverable under the limitations of the PennBylvania Motor
Vehicle Financial Responsibility Act.
18. As the sole and proximate result of the Defendant,
GERALD A. NASH, JR.'s negligence, the Plaintiff, MARY L.
STRINGFELLOW, has incurred a loss of income and earning capacity
and will continue to Buffer the Bame in the future and thus
claim for past and future lost wages is made, including a lOBS of
present and future loss of earnings c~pacity.
19. As the sole and proximate result of the Defendant
GERALD A. NASH, JR.'s negligence, the Plaintiff, MARY L.
STRINGFELLOW, has undergono in the past and will continue to
undergo in the future great pain and suffering.
20. As the Bole and proximate result of the Defendant
GERALD A. NASH, JR.'s negligence, the Plaintiff, MARY L.
STRINGFELLOW, suffered a permanent diminution of her ability to
enjoy life and life's pleasures.
WHEREFORE, the Plaintiff, MARY L. STRINGFELLOW, demand.
jUdqment of the Defendant, GERALD A. NASH, JR., in the amount in
exce.. of the amount requiring compulsory arbitration.
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SHERIFF'S RETURN - U.S. CERTIFIED "AIL
_SE NO. 1996-e3e43 P
IBDa~~W~~L~tl"~~R[fa~SYLVANIA'
ITRINGFELLOW "ARY L
VS.
NASH GERALD JR ET AL
R. Tho",.. Klin.
. Sheriff or Deputy Sheriff of
CU"BERLAND County, Penn.ylvania, who being duly .worn according
.erved the within naMed DEFENDANT. PAGE TRANSPORTATION INC
,
by United Stat.. Certified "ail po.tage prepaid, on the 31.t
"av . 1996. at 11ee.ee HOURS, at 27~8 TRO"BLEY ROAD
pO BOX 92e
to law,
J
day of
WEEDSPORT. NY 13166
a true and att.e.ted oopy of the attaoh.d CO"PLAINT
together with NOTICE
The returned receipt card wa. .igned by DON FETER
.
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on 6/13/1996.
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Sheriff'. CO.t.1
Docketing
Servioe
Affidavit
Suroharge
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~CH"IDT A
06/10/199
~~~~~"J1~~~:~r~~e<t tt. .~efore Me
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MARY L. STRINGFELLOW,
PLAINTIFF
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96-3043 CIVIL
CIVIL ACTION - LAW
GERALD A. NASH, JR.,
JERRY A. NASH, JR., and
PAGE TRANSPORTATION, INC.:
DEFENDANTS:
JURY TRIAL DEMANDED
ANSWER WITH NEW MATTER OF DEFENDANT.
PAGS TRANSPORTATION. IN~.. TO PLAINTIFF'S COMPLAINT
1. Denied. Answe~ing Defendant, Page Transportation, Inc.
(hereinafter "Answering Defendant") is without information
sufficient to form a belief as to the truth of these allegations
and accordingly, the same are denied and the same are denied and
atrict proof thereof is demanded at trial.
2. Denied upon information and belief.
3. Denied upon information and belief.
4 . Admitted.
,5. Denied upon i:1formation and belief.
6. Denied upon information and belief.
7. Denied upon information and belief.
8. Denied. Answering Defendant denies after reasonable
investigation and inquiry that Defendant Gerald A. Nash, Jr. was
operating a tractor trailer with the permission of its owner,
Defendant, Gerald A. Nash, Jr., on the basis that Answering
Defendant lacks information sufficient to form a belief as to the
truth of these allegations and accordingly, these are denied and
strict proof thereof. is demanded at trial. By way of further
answer, Answering Defendant, Page Transportation, Inc.,
specifically denies that Defendant, Gerald A. Nash, Jr., was
acting as an agent, servant or employee of Answering Defendant,
Page Transportation, Inc. To the contrary, Defendant, Gerald A.
Nash, Jr. was engaged in activities outside the scope of any
employment with Answering Defendant, Page Transportation, Inc. at
the time of the incident described in Plaintiff's Complaint.
9. Denied upon information and belief.
,
10. Denied upon information and belief.
11. Denied. The allegations of this paragraph constitute
conclusions of law to which no responsive pleading is required
and accordingly the same are denied and strict proof thereof. is
demanded at trial.
COUNT I.
NEGLIGENCE
MARY L. STRINGFELLOW v. GERALD A. NASH. JR.
12. Answering Defendant incorporates by reference its
responses to paragraphs 1 through 11 above as if set forth at
length herein.
13. The allegations of this paragraph are directed to a
Defendant other than Answering Defendant and accordingly, no
response is required.
-2-
14. The allegations of this paragraph are directed to a
Defendant other than Answering Defendant and accordingly, no
response is required.
15. The allegations of this paragraph constitute
conclusions of law to which no responsive pleading is required
and accordingly, the same are denied and strict proof thereof is
demanded at trial.
16. The allegations of this paragraph constitute
conclusions of law to which no responsive pleading is required
and accordingly, the same are denied and strict proof thereof is
demanded at trial.
17. The allegations of this paragraph constitute
conclusions of law to which no responsive pleading is required
and accordingly, the same are denied and strict proof thereof is
demanded at trial.
18. The allegations of this paragraph constitute
conclusions of law to which no responsive pleading is required
,
and accordingly,' the same are denied and strict proof thereof is
demanded at trial.
19. The allegations of this paragraph constitute
conclusions of law to which no responsive pleading is required
and accordingly, the same are denied and strict proof thereof is
demanded at trial.
20. The allegations of this paragraph constitute
conclusions of law to which no responsive pleading is required
-3-
and accordingly, the same are denied and strict proof thereof is
demanded at trial.
WHIRIPORI, Answering Defendant, Page Transportation, Inc.,
demands judgment in its favor and against all other parties.
COUNT II.
NEGLIGBNCB - RBSPONDBAT SUPERIOR
21. Answering Defendant, Page Transportation, Inc.,
incorporates by reference its responses to paragraphs 1 through
20 of Plaintiff's Complaint as if set forth at length herein.
22. Denied. The allegations of this paragraph constitute
conclusions of law to which no responsive pleading is required
and accordingly, the same are denied and strict proof thereof is
demanded at trial. By way of further answer, and to the extent
that any answer is deemed required, Page Transportation, Inc.
denies that at all times subject to the accident described by
Plaintiff in her Complaint, Defendant, Gerald A. Nash, Jr. was an
agent, servant, employee or ostensible agent of Page
Transportation, Inc. To the contrary, Page Transportation, Inc.
avers that Defendant, Gerald A. Nash, Jr., at all times subject
to the accident described by Plaintiff in her Complaint was
acting outside the scope of any employment with Defendant, Page
Transportation, Inc.
WHBRBFORB, Defendant, Page Transportation, Inc. demands
judgment in its favor and against all other parties, together
with such other relief as this Court shall deem appropriate.
NEW MATTER DIRBCTED TO PLAINTIFF
-4-
23. Plaintiff's claims are barred and/or limited by the
applicable provisions of the Pennsylvania Motor Vehicle Financial
Responsibility Law.
24. Plaintiff's Complaint fails to state a cause of action
upon which relief can be granted.
25. Plaintiff's claims are barred and/or limited by the
doctrines of res judicata and/or collateral estoppel.
26. Plaintiff's injuries and/Qr damages, the same being
expressly denied, were caused in whole or in part by acts and/or
omissions on the part of entities other than Answering Defendant
and over whom Answering Defendant had neither control nor right
of control.
WHEREPORE, Defendant, Page Transportation, Inc. demands
judgment in its favor and against all other parties, together
with such other relief as this Court shall deem appropriate.
NEW MATTER PURSUANT TO PA.R.C.P. 2251l9l
DIRECTED TO DEPENDANTS. GERALD A. NASH. JR.
AND JERRY A. NASH. JR.
27. Defendant, Page Transportation, Inc., incorporates by
reference the material allegations of Plaintiff's Complaint, all
such allegations being denied.
28. Defendant, Gerald A. Nash, Jr., at the time of the
accident described by Plaintiff in her Complaint was acting
outside the course and scope of any employment with Page
Transportation, Inc. and accordingly, Defendant, Gerald A. Nash,
-5-
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Timothy J. McMahon, Esquire, a member of the law firm of
MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN, attorneys for
DEFENDANT, PAGE TRANSPORTATION, INC., verifies that the
foregoing, ANSWER WITH NEW MATTER TO PLAINTIFF'S COMPLAINT is
tr'ue to the best of his knowledge, information and belief. If
the above statements are not true, the deponent is subject to the
penalties of 18 Pa.C.S. ~4904 relating to unswor.n falsification
to authorities.
DATE:
7-~-9~
TIM
CBRTIPICATB OP SBRVICB
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I, Robin K. Nelson, an employee of Marshall, Dennehey,
Warner, Coleman & Goggin, do hereby certify that on this 8th day
of July, 1996 served a copy of the foregoing document via First
Class United States mail, postage prepaid as follows I
JAMES R. RONCA, ESQ.
209 STATE STREE'r
HARRISBURG, PA 17101
ATTORNEY POR PLAINTIPP
"
Gerald A. Nash, Jr.
113 Beechwood Ave.
Liverpool, NY 13088
I,
Jerry A. Nash, Jr.
405 Buckley Road
Liverpool, NY 13088
~'J{., Q<. f,^~
CBIN K. NELSO
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PRAlCIP. POR APP.ARAKC.
/
TOI Lawrence E. Welker, Prothonotary
KINDLY ENTER OUR AFPEARANCE on behalf of the Defendant
Gerald A. Nash, Jr. a/k/a Jerry A. Nash, Jr. in connection with. the
above-captioned action.
A JURY TRIAL IS DDCAND.D.
,
RIC '
S ,. ASSOCIAT.S
suire
ald A. Nash,
A. N sh, Jr.
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AND NOW, this ~I '/ll'l~ay of
R.Ronca, ESqUire':: ~~to:t'ney for ~~~~
that I have, this day, served th~ tor~o
~
, 1996, I, James
iff, hereby certify
depositinq a copy
of the same in the United states Mail, postage prepaid, at
Harrisburq, Pennsylvania, addressed to:
Timothy J. McMahon, Esquire
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOGGIN
100 Pine Street
P.O. Box 803
Harrisburq, PA 17108
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SCHMIDT AND RONCA, P.C.
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ames R.
Attorney tor Plaintiff
I. D. No. 25631
209 State street
Harrisburq, PA 17101
(717) 232-6300
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ANSWIlR AND mrw MATTIR
AND NOW, comes Defendant, Gerald A. Nash, Jr., a/k/a
Jerry A. Nash, Jr., by and through his attorneys, Richard J. Mills
& Associates, and files this Answer and New Matter to the
Plaintiff's Complaint, averring as follows:
1. The allegations contained in paragraph 1 are denied
in that, after reasonable investigation, this Defendant is without
knowledge or .information sufficient to form a belief as to the
truth of the averments contained therein and, the same are deemed
to be denied, placed at issue, and strict proof thereof is demanded
at time of trial,
2. The allegations contained in paragraph 2 are denied
as stated. Defendant Gerald A. Nash, Jr. is an adult individual
currently residing at 405 Buckley Road, Liverpool, New York 13088.
3. The allegations contained in paragraph 3 are
admitted with the clarification that Gerald A. Nash, Jr, and Jerry
A. Nash, Jr. are the same person. Gerald A. Nash, Jr. a/k/a Jerry
A. Nash, Jr. is an adult individual currently residing at 405
Buckley Road, Liverpool, New York 13088.
4. Admitted.
5. The allegations contained in paragraphs 5 through 6
are denied, generally, pursuant to Pa,R.C.P. 1029(e).
7. Admitted.
8. The, allegations contained in paragraph 8 are
admitted in part and denied in part, It is admitted that, at the
referenced time and place, Gerald A. Nash. Jr, was operating the
subject tractor-trailer which he then owned, and was then and there
acting as an agent, servant, or employee of Defendant Page
Transportation, Inc. Any implication contained in paragraph 0 that
Gerald A. Nash, Jr. and Jerry A. Nash, Jr. are two different people
is denied.
9. The allegations contained in paragraphs 9 through 20
are denied, generally, pursuant to Pa.R.C.P. 1029(e).
10., In response to the incorporation set forth at
paragraph 21, this Defendant hereby incorporates his responses to
paragraphs 1 through 20 of the Plaintiff's Complaint as though the
same were more fully set forth at length herein.
11. The allegations contained in paragraph 22 are
admitted,
WHEREFORE, this Defendant, Gerald A. Nash, Jr. a/k/a
Jerry A. Nash, Jr., respectfully requests your Honorable Court to
dismiss the claims here brought against him and enter judgment in
his favor and against the Plaintiff.
NEW MATTER
AND NOW, comes the Defendant, Gerald A. Nash, Jr-, a/k/a
Jerry A. Nash, Jr" and files this New Matter to the Plaintiff's
Complaint, averring as follows:
12. The Plaintiff is barred from recovery of non-
economic damages as a result of her election of the limited tort
option pursuant to 75 Pa,C.S.A. 51705,
13. This Defendant pleads the affirmative defenses of
assumption of the rhk, compara';ive negligence and contributory
negligence as per Pa.R.C.P. 1030(b).
14. The Plaintiff's action is barred by the applicable
statute of limitations,
WHEREFORE, this Defendant, Gerald A. Nash, Jr. a/k/a
Jerry A, Nash, Jr., respectfully requests your Honorable Court to
dismiss the claim here brought against him and enter judgment in
his favor and against the Plaintiff.
Respectfully submitted,
By:
Au
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Jr. a
& ASSOCIATES
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This is to certify that a true and correct copy of the
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served upon
(ill.
counsel of
within ANSWER AND NEW MATTER has been
r4;:~, by U. S. mail,
,- ,1996, at
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the following address:
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JAMES R. RONCA, ESQUIRE
209 STATE STREET
HARRISBURG, PA 17101
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, ,PENNSYLVANIA
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MARY L. STRINGPILLOW,
Plaintiff,
CIVIL DIVISION
No. 96-3043
v,
Code:
, ,
GIRALD A. NASH, JR., JIRRY
A. NASH, JR. and PAGI
TRANSPORTATION, INC.,
VERIPICATION TO DIPINDANT'S
ANSWER AND NBW MATTIR
1
Defendants.
Filed on behalf of
GlRALD A. NASH, JR.
JERRY A. NASH,
Defendants
a/k/a
JR.,
.
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Counsel of Rtlcord for this
party:
\'
AUSTIN P. HENRY
Pa. I. D, #58278
'.'
RICHARD J, MILLS &
ASSOCIATES
200 Benedum Trees Building
223 Pourth Avenue
Pittsburgh, Pa 15222
,.;
,
(412) 471-2442
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CIRTI'ICATI 0' SIRVICI
This is to certify that a true and correct copy of the
within VlRI'ICATION TO DZPINDANT'S ANSWER AND NBW MATTIR has been
,
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served upon counsel of record, by U. S. mail, postage prepaid, this
olo~ day of c~tA...",,^-- ,1996, at the following address I
JAMES R. RONCA, ESQUIRE
209 STATE STREET
HARRISBURG, PA 17101
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
MARY L. STRINGFELLOW,
Plaintiff,
CIVIL DIVISION
No. 96-3043
v.
Code:
GlRALD A. NASH, JR., J1iRRY
A. NASH, JR. and PAGI
TRANSPORTATION, INC.,
NOTICI OF SIRVICS OF
DIFENDANT NASH'S
INTIRROGATORIIS AND RSQUlST
FOR PRODUCTION OF DOCUMlNTS
DIRECTED TO THS PLAINTIFF
Defendants.
Filed on behalf of
GSRALD A. NASH, JR. a/k/a
JSRRY A. NASH, JR.,
Defendants
Counsel of Record for this
party:
AUSTIN P. HENRY
Pa. I.D, #58278
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RICHARD J, MILLS &
ASSOCIATES
200 aenedum Trees Building
223 Fourth Avenue
Pittsburgh, Pa 15222
(412) 471-2442
, .
CIRTIFICATI OF SIRVICI
This is to certify that a true and correct copy of the
within NOTICI or SBRVICI or INTBRROGATORIIS AND RIQUlST FOR
PRODUCTION OF DOCUMBNTS has been served upon counsel of record, by
U. S. mail, postage prepaid, this Ii ~n... day of ~~"
1996, at the following address:
JAMES R. RONCA, ESQUIRE
209 STATE STREET
HARRISBURG, PA 17101
TIMOTHY J. McMAHON, ESQUIRE
MARSHAt,L, DENNEHEY, WARNER, COLEMAN & GOGGIN
100 PINE STREET
P.O. BOX 803
HARRISBURG, PA 17108-0803
RIC
&: ASSOCIATES
,,'..51 'N-~'SP~C'r.L'l';O"IQ. ,INT
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MARY L. STRINGFELLOW/
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA
v.
CIVIL hCTION - LAW
GERALD A. NASH, JR.,
JERRY A. NASH, JR., and
PAGE TRANSPORTATION, INC.
Defendants
NO. 96-3043 CIVIL
JURY TRIAL DEMANDED
PLAINTI..'. RIPLY TO NIW MATTIR
o. Ca...DART NAIK
12. Denied. On the contrary, it i~ averred that Plaintiff
has serious injuries.
13. Paragraph 13 is a conclusion of law which require. no
answer.
14. Paraqraph 14 is a conclusion of law which require. no
answer.
WHEREFORE, Plaintiff respectfully requests judgment of the
Defendant as more specifically averred in the Complaint.
Respectfully submitted,
SCHMIDT AND R CA, P.C.
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By
James Ronca
Attor Y. tor Plaintiff
IDI 25 1
209 S te street
HarrL$burq, PA 17101
(717) 232-6300
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~TlrICAT~Or~
AND NOW, thiJ day of u'(!.~ ~ L-' 1996, I, Jam..
R. Ronca, Esquire, attorney tor the Plaintitf, hereby certify
that I have, this day, served the foreqoinq by depositinq a copy
of the same in the United states Mail, postaqe prepaid, at
Harri8burq, Pennsylvania, addressed to:
Timothy J. McMahon, Esquire
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOGGIN
100 pinoll street
P.O. Box 803
Harrisburq, PA 17108
AU8tin P. HQnry, Esquire
RICHARD J. MILLS & ASSOCIATES
200 Benedum Trees Buildinq
223 Fourth Avenue
Pittsburqh, PA 15222
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SCHMI~D R
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By
James R. onca
Attorne or Plaintiff
I. D. No. 25631
209 State Street
Harrisburq, PA 17101
(717) 232-6300
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MARY L. STRINGFELLOW,
PLAINTIFF
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96-3043 CIVIL
GERALD A. NASH, JR.,
JERRY A. NASH, JR., and
PAGE TRANSPORTATION, INC.:
DEFENDANTS:
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
fRAICIPI TO SITTLE. DISCONTINUE ~ aND
TO: CUMBERLAND COUNTY PROTHONOTARY
Kindly mark the above-captioned matter SETTLED, DISCONTrNUED
and ENDED, with prejudice.
L___
DATE' July ,-, I ,qqy
BY'
JANIS R. RONCA, ESQ.
209 STATE STR
rISG,
(717 32-6300
A ORNBY POR PLAINTIPPS
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