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Home My WebLink About00-00224 _,u"" , " , -,~:. WILLIAM B. COBB, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000- .;J.:J,/ CIVIL TERM MARC J. WINDISH, Defendant NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO A LAWYER AT ONCE. NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR THE OFFICE SET FORTH BELOW TO FIND OUR WHERE YOU LEGAL HELP. IF YOU DO TELEPHONE CAN GET Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 -......... - WILLIAM B. COBB, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000- ';;.:2'1 CIVIL TERM MARC J. WINDISH, Defendant COMPLAINT AND NOW, comes the Plaintiff, William B. Cobb, by his attorneys, Addams & Rundle, and makes the following complaint: 1. The Plaintiff is William B. Cobb, an adult individual residing at 38 Iroquois Drive, Royersford, Pennsylvania 19468, formerly of 708 16th Street, New Cumberland, Cumberland County, Pennsylvania. 2. The Defendant is Marc J. Windish, an adult individual residing at 95 Deerfield Road, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The Plaintiff is the owner of a 1988 Ford Festiva which, at about 8:00 p.m. on May 17, 1998, was parked along the curb near his residence on 16th Street in New Cumberland. 4. At said time and place, the Defendant was backing a 1989 Lincoln Town Car out of a driveway when he negligently and carelessly backed into the Plaintiff's vehicle, which was parked on the opposite side of the street. 5. The Defendant was negligent and careless in: A. Backing his vehicle when said movement could not be made in safety. B. Failing to observe the Plaintiff's vehicle in time to avoid a collision. ~- ~-= ~ ~ -, ~~~~, ~'" C. Failing to have his vehicle under control. 6. As a result of the negligence and carelessness of the Defendant, the Plaintiff's automobile sustained damage in the amount of $1,110.88. WHEREFORE, the Plaintiff demands judgment against the Defendant in the amount of $1,110.88 plus interest and costs of suit, an amount within the jurisdiction of arbitration under the local rules of court. ADDAMS & RUNDLE BY:~~ Willi A. Addams Supreme Court I.D. No. 06265 28 South pitt Street P.O. Box 208 Carlisle, PA 17013 (717) 249-8300 Attorneys for Plaintiff '" '". ." VERIFICATION William B. Cobb hereby verifies that the facts set forth in the foregoing complaint are true and correct to the best of his knowledge, information and belief, and understands that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsifications. ~PJ~ DATE: 1\5"\00 ;ijilJ;lf.liil;tje._Uill~~;_iiil9"-'^~~."-=liI~~~'-'ilE!~I'-''i<'~I~~~~' ~~ -.. --0 UI; ~ ~ "- ~ "WJ!l',lt '~""""t~"""",~,I,,,"__ _'~Q~="~'."' " ",,' ,=. " .' " ~, -~ '" ~. '1'7 , . (') co 0 ~ CO ..., If L --; ::... or Z 'i'i-:D 'r- !'\) i'8f? :... ~C; Ig :z: ;:J;"'" <;,,;::!.! '!} ~~ ~ g N ~ -.. Q) ~ J ~ .f:: v~ p & e t r CASE NO: 2000-00224 P SHERIFF'S RETURN - REGULAR ~!l..: COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COBB WILLIAM B VS WINDI SH MARC J ROBERT FINK , Sheriff or Deputy Sheriff of Cumberland County, pensylvania, who being duly sworn according to law, says, the within NOTICE & COMPLAINT was served upon WINDISH MARC J the DEFENDANT 2000 , at 0019:00 HOURS, on the 14th day of January at 95 DEERFIELD ROAD CAMP HILL, PA 17011 by handing to JUDY WINDISH (WIFE) a true and attested copy of NOTICE & COMPLAINT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 10.54 .00 10.00 .00 38.54 Sworn and Subscribed to before So Answers: rfk{:.e<",<~i R. Thomas Kline 01/18/2000 ADDAMS & RUNDLE BY~~~ Deputy Sheriff ~ ~" 1- J - .~ ,. E .. .. ; WlLLlAM B. COBB, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-00224 CIVIL TERM MARC J. WINDISH, Defendant PRAECIPE Sir: Please enter a default judgment in the amount of $1,110.88 in favor of the plaintiff and against the defendant for failure to enter an appearance or file an answer to the complaint endorsed with a notice to defend. The undersigned hereby certifies that the attached written notice of intention to file this Praecipe was mailed to the defendant on the date shown thereon, which was after the default occurred and at least ten (10) days prior to the filing of this Praecipe. ADDAMS & RUNDLE By: ~~~ Attorneys for Plaintiff 28 South Pitt Street P.O. Box 208 Carlisle, PA 17013 (717) 249-8300 To: Curtis R. Long, Prothonotary Date: March 23, 2000 - "', c, I .. :1 i: j: i' .. WILLIAM B. COBB, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-00224 CIVIL TERM MARC J. WINDISH, Defendant NOTICE TO TAKE DEFAULT JUDGMENT TO: Marc J. Windish 95 Deerfield Road Camp Hill, PA 17011 DATE OF NOTICE: February 14, 2000 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 ADDAMS & RUNDLE By: William A. Addams Attorneys for Plaintiff 28 South Pitt Street P.O. Box 208 Carlisle, PA 17013 (717) 249-8300 ." .'<~ ,,;,' ","I~...,,~k, _.J , ..... ~-~ _.1ifirIllU6i1likrra1i1il~"'''''~'''''' . "",,' -, (S)~~ ~ ~ 0;,} y ~ --- ~ ~ ~ 6- ~ ~ W ~ i .." '.. '-', ,,-,' .' --,~. I g 0 ~ '1:13: 0 !pO; ::J: .--e fn ",. -,~ Z;l;] :=0 fh:n w5.; N r- '"nIT; -<2: W :Ul? k'O f---"" ~ "'" '=i?, )>8 :.::t ?=-rl c C5 ;;;2(') Z om ~ N ;g Ul -< ! Deft 7'1v ~. ;lXV &;J I.fl....,. iJi , , , , i I I I , I , i , , , -~" ~.~ _.~ ~ William B. Cobb, VB Marc J. Windish, PUf AFFIDAVIT The undersigned hereby certifies that the attached Certification of Motor Vehicle Judgment is as a result of a motor vehicle accident that occurred on May 17, 1998. ~~~ Willia A. Addams COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this, the 23rd day of May, 2000, before me, the undersigned officer, personally appeared William A. Addams, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have set my hand and official seal. ~} 'ft. O~ [SEAL] Notarial Seal Mary M. Price. Notary Public Carlisle Boro, Cumberland County My Commission Expires Aug. 18, 2003 - '!i_M~iItIIIMilBIIi!ifMIlIIIS~w.M.-m~D~~,*"!&lil\$'Olllii'.&~,k- r% ..., W T~L^ , ,~'"'''". - ~~~.-' " " .- ,. ~. d,~_ " ~ ~ ~"'-~lililillWtl ~' . ~. ;:2 (."? ;,J 0 ., 55 =rr: :',;:1 -c :;t-;.. ..n rri r~ ' -" .. ;= 2: C f0 ;'n (j) CA;' ,:;57 ,-< r'.'. "~~C) ~ '_.' ~ ~~ ::E.: c} :(.; () > ~ ,- -,I Z ;''0,) "> --. ~ -< C) ~ .. '" a ~ ,~=" ~ - WILLIAM A. ADDAMS, ESQUIRE ATTORNEY !.D. # 06265 27 West High St. P.o. Box 261 Carlisle, Pa. 17013 Telephone: 717-243-7638 Attorney for Plaintiff WILLIAM B. COBB : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND, PENNSYLVANIA : NO. 2000 - 00224 Civil VS. MARC J. WINDISH Defendant PRAECIPE To: Curt Long, Prothonotary Please mark this action settled and discontinued and the judgment satisfied. ~ illiam . Addams Attorney for the Plaintiff 27 W. High St., Carlisle, P A 17013 717-243-7638 Date: June 20, 2005 , ~~~ , , , i: ~!im.~,......JlIIJIlIIIilI!iM~l:!f!liiI__~iIlI"''''""'-'bil&t4ulill'iJ''''~''''~'~''' -_..~'" =~"",ri . ~~ (") "'" = 0 C = ." ;0>- en ~~~f~ '- :t c:: z n,--n r- 0:;:;-' N -om :uo ~.r---'" Q6 r:.::c: ,~(':' -c C3~ 3: --( , ~m Pc r:-? u ' Z; -! =< N 5:i -' -< ~