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Home My WebLink About96-06300 \ , .~ \ i::. ~ ~ ~ ~ ~ ~ ~ ~ ~ " I I " .I , ., ,.\; -I' "I,t ,. ., " I' 'iI "I' ., , " ~ I' " I '11,t , I, , , I' " " .,' J " " " 1:1 " " g " , " , I C't") II' I .,' I'f " II' ~ I , , ,\ ,I . .... ()o , , " . , , ~ " ~L:~ik.:}i: t,lt' ilJr' 'i I t~rTh~\i)''' ',; -'11-1;1 ~l.qi,r!"'il'-"i'_ h;!l'-\'--'~:;n'-'_' ,.\It(f.<..,\-,.-;l' a;,~i}I;:I;;if',jr\':i: II },,,,,-,',-.I.-,'__ '.1 :lWIr;_I~~~~11.1\;J,' :','1," r! 1/ 0'/1'_"';' ,F "'II' .i'1l/"!"p' !;i li;'t:'I~>];i;: 'I:: i':I,,',1 1 ~j 'Ill, ,'.',i-!' {h'f" " , I, I ,I, I' ,Ii, , i ",i ,11 J"f 'I,; ij , , ' '''!:!' I '\ !'I , , r.;I', ", 'j'" '" " . .' 'I) I ;01 , I )', ,i' :' , ' I; II " , ~~,~ , . iO 1., ,'f0 '<:i ~ ~ "'~ . ,~ . ~~~ ,I [I ~~ '- ........ 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II:' I , , I' .',,'1 " /, " ., ,,' " " II', .,,',-:'f'.1 " I, I "l " " I, "I' 'Ilj 'i I' " I , , II, :,/ t'," I 'iLl I , ' '~ i ,1,1.,' , " 'I j,I", 'I,'"~ " " , , iil,1, ii' " " ,-" " !i i', I -'f " I ~ ' .1;'1 ;II,} !!' I .. , , i' d .\, I', '().)"I.\ ,,' ~ !: ' ,-, . 1:,1 ,.1" _J'(-; '1, ," ':. IN TIm COllin OF COMMON PI,8AS OF CLJMll~;IU,ANlJ COUNTY, PI;;NNSyr..vANIA E'I'/lEIJ r::. OARItE'I"I', Civil Action . Law l'laint if f vs, No, 96-6300 civil BELEN 1;;, /lARA'l'INE / Defendant JURY 'l'IUI\t, Or.MANDED DIPlNOAltt!Jl ANBWIlR AND lOW HATTIR TO P~AlijIl~JLCOMP~AINT AND NOW, come/:! the Defendant, Belen E. Bantine / by ann through her attorneys, Charles B. Calkins and Michael B. Scheib, Griffith, Strickler, Lerman, Solymos & Calldns, and fillls this Answer and New Matter in response to Plaint iff 'II Complaint / and atates as followsl 1, Denied. Answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations contained in paragx'aph 1 and the same are denilld and strict proof thereof is demanded. 2. Admitted. 3. Admitted. 4. Admitted in part and denied in part. It is admitted that Ms. Garrett was traveling southbound on North Twelfth Street and that Ms. Harat ine was traveling northbound on North Twol fth Street at the time of the accident. It is also admitted that the vehicles came into contact with one another. The remaining allegations are denied. After reaaonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations contained in paragraph 4 of Plaintiff's Complaint and the same are denied and strict proof , thereof ia dema~dod. 5, Denied. After reallonllole invellt igat ion, Iln/Jwering Defendant is without k~owledge or informat ion suf fici':II1t to form 8 belief aa to the truth or veracity of the allegationa contained in paragraph 5 of Plaintiff's Complaint and the same ore denied and strict proof thereof: iu demanded. IS, Oenied. It iu denied that Defendant J/aratine wa/J negligent, caraless and/or recldess, It ia further denied that Defendant Haratine was negligent, careless and/or reckless bYI (8) failing to remain in her own lone of: tr.afficl (b) crossing ovar the double-yellow line and entering the opposing lane of trafficl (c) operating her vehicle too fast for th.e prevailing conditionsl (d) (e) exceeding the posted speed limitl failing to maintain her car under proper and lawful control I (f) failing to stop before causing an accident I (g) failing to keep a proper lookout I (h) failing to see what she should have seenl (ll failing to notice the imminence of an accident and taking the necessary stepa to avoid the samel (j) operating her vehicle at an unsafe speed, and (h) acting without regard for the safety and rights of the Plaintiff, On the contrary, and at all times ralevant, Defendant Haratine 3 acted in a lllwful, cllrtlful, Ullfo /llId pUldont 11111111101' /llId with dUll care BU required by the circulI1utlll1CUil. 7. Llented, II; ia apecifically denied that Pefendallt Haratine Wile negligent, cnrelouu ond/or recklouu, On the contrllry, Bnd at 1111 timEw ral.evallt, IJlltendunt lIurlltinll ucted in a lawful, careful, aafe and prudent m/'lIl1ler and with duo care all required by the circull1lltanCQIl, In addition, lifter reasonable investigation, answering Defendant in without knowledge or information sufficient to form a belief as to the truth or veracit:, of the allegatiotlll contained in paragraph 7 of Plaintiff's Complaint and the sall1u are denied and atrict proof thereof is demanded. 8. Denied, It is specifically denied that Defendant Haratine wall negllgunt, carelellll and/or recklellll. On the contrary, and at all times relevant, Defendant Haratine acted in a lawful, careful, safe and prudent manner and with due care as required by the circumolancell. In addition, of tel reaaonabl.e investigation, answering Defendant is without knowledge or information Ilufficient to form a belief aa to the truth or veracity of the allegntions conta ined in paragraph 8 of PJ.aintiff' s Complaint and the same Bre denied and strict proof thereof is demanded. 9. Denied. It is specifically denied that Defendant Haratine was negligent, caruleas and/or reckless. On the contrary, and at all timell relevant, Defendant Haratine acted in a lawful, careful, safe and prudent manner and with due care as required by the circumstances. In addition, after reasonable investigation, answering Defendant ia without knowledge or information sufficient 4 t<) form Il belief as to the truth or veracity of the clllegatiolHl contllined in parllgraph 9 of Plaintiff's Complaint and the same are denied and strict proof thereof is demanded. 10, Denied. It is specifically denied that Defendant Harlltine WIlS negligent, careless Ilnd/or reckless, On the contrary, Ilnd at all timen relevant, Defondant Haratine acted in a lawful, careful, Sllfe and prudent manner and with due care IlS required by the circumstances. In addition, after reueonable investigation, answnring Defendant is without knowledge or informlltion sufficient to form a belief IlB to the truth or veracity of the allegations contained in paJ.'"Bgraph 10 of Plaintiff's Complaint and the same are denied and strict proof thereof is demanded. 11, Denied, It is speci fically denied that DefQ!ndant Harat ine was negligent, careless and/or reckless, On the contrl\r.y, and at all times relevant, Dofendant Haratine acted in a lawful, careful, safe and prudent manner and with due care as required by the circumstancea. In addition, after reasonable investigation, anawering Defendant ia without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations contained in paragraph 11 of flaintiff' B Complaint and the same are denied and strict proof thereof is demanded. 12. Denied. It is specifically denied that Defendant Haratine waa negHgent, careless and/or reckless. On the contrary, and at all times relevant, Defendant Haratine acted in a lawful, careful, safe and prudent manner and with due care as required by the circumatances. In addition, after reasonable inveBtigation, 5 answeJ."ing Defendunt ill without knowlodgl! or information Ilufficlent to form a bellef BIl to the truth or veracl,ty of the allegationa contained in parcjgraph 12 of Ph int if f 'Il Compla int and the llama ore denied and strict proof thereof ill demanded. 13. Denied, It ill specifically denied that Daf-endant Haratine was negligent, carelellll and/or 1'l!ckleBIl. On the contrary, and at all timeD relevant, Defendant f1nratine acted in a lawful, careful, safe and prudent manner and with due care as required by the circumstances. In addition, after reaBonable inveatigation, anllwering Defendant is without knowledge or information sufficient to form a pfllief as to the truth or veracity of the alll'Jglltionu conta ined in paragraph 13 of Pln int if f' s Complaint and the same are denied and strict proof thereof is demanded, WHEREFORE, Defendant Haratine rellpectfully requests this Honorable Court to enter judgment in her favor and against the Plaintiff together with the coot of this lawsuit. By way of further defense. ~IlW HATUR OF DIlFlNDANT HARATINB 14. Paragraphs 1 through 13 of Defendant's Answer and New Matter are incorporated hereln by reference all though fully set forth at length. 15. Plaintiff's injuries, if any, were caused by the acts or events which pre-dated the motor vehicle accident which is the subject of this lawsuit. 16, Plaintiff's injuries, if any, were caused by acts or events which post-dated the motor vehicle accident which is the 6 i 1 , '1) ], \' ," ,'J 't ,,'" 'I ,i"1 :I,r ,',," I, j, " i" ',' " I' I ,I, ;', ilt " " " ,t", I, " ,I I' , , Ij 'I I, , I' II' I,l" j' " i' , I, " I, )1 "i , , ," 'I , "il 'I \' I ,'I I I " ';( ,\ " " , ,(I ,'I I " I': I , " ii";' ,"', " , .' ,I , I,'i 'I', 1 I ,I"~ , " '" " , , , " ,I 'I I" 1/,1,'" .il 'I J I' , oIr: " ,,1 ,I " , "I ; ,,' ., i.J 1',,~.,"'~1 .. 'I' .. I I I' ," , -Ii , , ,\ " ! " " 1 , , , , ~, " " 'I "111, " ,I ,! ,.t, " I' ., " 'I,r, 'i ilt , \ " t'llr " I I, 'I.' 1I'I , ' 1,1 /I-'! I,;' , ,I, \! 'Ii " , , , .. ,I " 'I I' q , , " ri.' , \;,;,It_l, .. . ~ I . " , II; " " , , rlfl.' Il,j ;;'! I '.,' , ,/ !, " II , '. I." " ;I 'i' fd I' I I J 'I ,,/11 ,,' ',' I, " ,,'j,'.' '.'t " " " " , "I ,-I I ,I'