HomeMy WebLinkAbout96-04974
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LON C. STRAYER, IN THE COURT OF COMMON PLEAS
. CUMBERLAND COUNTY, PENNSYLVANIA
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Plaintiff, . 0ui!lflU-1
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v. . NO.
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. CIVIL ACTION - LAW
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THOMAS J. ADAMS, alkla .
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THOMAS ADAM, alkla ,
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THOMAS J, ADAM, ,
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. JURY TRIAL DEMANDED
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Defendant. .
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"_IIeIPB
TO THE PROTHONOTARY:
Please issue a Writ of Suaaons against the above-naaed
defendant at the following address:
SCI
State Correctional Institute
P.O. Box A
eres.on, Caabria County, PA 16699
Inaate NOI Ar8926
Respectfully subaitted,
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D~,
, lID''''' I nLLY
n
.. 3103
2233 North Front street
Harrisburg, PA 17110
(717) 23.-7051
Attorney for Plaintiff
DATIl <,l,/'IIt.
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LON C. STRAYER, , IN THE COURT OF COMMON PLEAS
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. CUMBERLAND COUNTY, PENNSYLVANIA
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plaintiff, ,
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v, . NO. 4974 CIVIL 96
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. CIVIL ACTION - LAW
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THOMAS J, ADAMS, ,
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. JURY TRIAL DEMANDED
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Defendant. :
COKPLAlft
AND NOW, cOlRes the Plaintiff, LON C. STRAYER, by and
through his attorneys, KANCKE, WAGNER, HERSHEY' TULLY, and files
the following Coaplaint:
1, The Plaintiff, LON C. STRAYER, is an adult
individual currently residing at 60 Pine Street, Dillsburg, York
county, Pennsylvania,
2. The Defendant, THOMAS J. ADAMS, alkla THOMAS ADAMS,
alkla THOMAS J, ADAM, is an adult individual having a. a last
known addre.. at 80 Regency South, Carlisle, cuaberland county,
Pennsylvania, but a aore current addre.s at SCI cresson, CAabria
county, Penn.yl vania, being incarcerated in a .tate correctional
institute.
3. The facts and occurranees herein occurred on or
about the 19th day of septeaber, 1994, at or about Market Street
in t.eJIOyne, C\Uaberland COW\ty, Penn.ylvania,
4. At the aforementioned time and place, the Plaintiff
herein, LON C, STRAYER, was operating a 1989 Chevrolet caprice in
an ea.terly direction on the 800 block of Market Street, Lemoyne,
cumberland County, Pennsylvania,
5, At the aforementioned time and place, the
Defendant, THOMAS J, ADAMS, was operating a 1994 Ford Ranger
Truck, also ea.tbound on the 800 block of Market Street.
6. At the aforementioned time and place, the Defendant
did violently collide with the vehicle operated by the Plaintiff
causing injuries to the Plaintiff herein.
7. The aforementioned colli.ion was as a direct re.ult
of the Defendant'. negligent and careless conduct as follows:
A. In operating hi. vehicle at a speed that prevented
him from stopping within the sure clear distance
ahead;
8. In operating hi. vehicle too fa.t for condition..
C. In failing to stop hi. vehicle before COlliding
with the vehicle of the Plaintiff;
D, In operating hi. vehicle in a fashion .0 .. not to
be able to stop hi. vehicle before colliding vith
the vehicle of the Plaintiff;
I. In failing to brake or to .pply the brake. .0 ..
to prevent the colli.ion with the Plaintiff'.
vehicle;
F. In failing to observe the vehicle of the Plaintiff
to avoid violently colliding with the vehicle of
the Plaintiff;
G. In failing to control his vehicle so as to prevent
his vehicle from striking that of the Plaintiff.
8. As a result of the aforementioned conduct of the
Defendant, which resulted in the aforementioned collision, the
Plaintiff herein did sustain and suffer the following injuries:
A. cervical strain;
8. Trauma to the cervical area;
C. Flexion/extension injury to his cervical spine;
D. Exacerbation of a pre-existing back condition.
9. As a result of the afor...ntioned injuries, the
Plaintiff has in the past and will in the future undergo great
pain and SUffering.
10. As a result of the afore.entioned injuries, the
Plaintiff has in the past and will in the future undergo alas.
of life's pleasures and inconvenience,
11. As a result of the afo~ntioned injuries, the
Plaintiff bas in the past and will in the future suffer 9~t
diacoafort.
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