HomeMy WebLinkAbout00-00237
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
NO. ~CXX> - ;<2 7 Q~l{
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CHRISTINE A. ASCHERL and
SIEGFRIED A. ASCHERL,
Plaintiffs
:
v.
CIVIL ACTION - LAW
:
ELLEN CRACK,
Defendant
JURY TRIAL DEMANDED
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against
the claims set forth against you 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
default 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 YOUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THIS OFFICE SET FORTH BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
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CUMBERLAND COUNTY BAR ASSOCIATION
Lawyer Referral Service
Two Liberty Street
Carlisler Pennsylvania 17013
(717) 249 - 3166
1-800-990-9108
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LAw OFFICES 01'"
)ALE E. ANSTINE, P. C.
TWO WEST MARKET STREET
POST OFFICE ElOX9S2
Yoa><, Pl;:Nl<Svx.VANL\. 17406
1717)846_060""
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ELLEN CHACK,
Defendant
JURY TRIAL DEMANDED
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CHRISTINE A. ASCHERL and
SIEGFRIED A. ASCHERL,
Plaintiffs
: NO.
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v.
CIVIL ACTION - LAW
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USTED HA smo DEMANDADO EN IA CORTE. Si usted desea defenderse de
las quejas expuestas en las paginas siguientes, debe tomar acd6n dentro de veinte (20) dias
a partir de la teeha en que recibi6 la demanda y el aviso. Usted debe presentar
comparecencia escrita en persona 0 por abogado y presentar en la Corle por escrito sus
defensas 0 sus objeciones alas demandas en su contra.
Se Ie avisa que.si no se defiende, el caso puede proceder sin usted y la Corle puede
decidir en su contra sin mas aviso 0 notificad6n por cualquier dinero reclamado en la
demanda 0 por cualquier otra queja 0 compensad6n reclamados por el Demandante.
USfED PUEDE PERDER DINERO, 0 PROPRIEDADFS U arROS DERECHOS
IMPORTANfES PARA USTED.
LLEVE ESTA DEMANDAA UN ABOGADO INMEDIATAMENTE.
SI USTED NO TIENE 0 NO CONOCE UN ABOGADO, V AYA 0 LLAME A IA
OHONA EN IA DIRECaON ESCRITAABAJO PARA A VERlGUAR DONDE
PUEDE OBTENERASISTENOA LEGAL
CUMBERLAND COUNTY BAR ASSOOATION
Lawyer Referral Service
Two liberty Street
Carlisle, Pennsylvania 17013
(717) 249 - 3166
1.aoo-99O-9108
LAW OFFICES OF
)ALE E. ANSTINE, P. C.
TWO WESt MARKET ST~EET
POSTC)FFICE: SOX 952
YORK, PE'<NSYLVANIA 11405
(71-n",46-0606
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHRISTINE A. ASCHERL and
SIEGFRIED A. ASCHERL,
Plaintiffs
NO. 02.0-0-0' 2.3'7 C~ 14-
v.
CIVIL ACTION - LAW
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ELLEN CRACK,
Defendant
JURY TRIAL DEMANDED
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COMPLAINT
1. The Plaintiffs, Christine A. Ascherl and Siegfried A.
Ascherl, wife and husband, are adult individuals residing at 341
an automobile.
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Lexington Way, Littlestown, Pennsylvania 17340.
2. The Defendant, Ellen Chack, is an adult individual
residing at R.D. 4, Box 900, Mifflintown, Pennsylvania 17059.
3. On December 26, 1998, Plaintiff Christine A. Ascherl
was a front seat passenger of a 1999 Toyota Corolla bearing Pa.
registration plate BSR 6568, which was being operated by
Plaintiff Siegfried A. Ascherl.
4. On December 26, 1998, the Defendant was the operator of
5. On December 26, 1998, at approximately 3:00 p.m., the
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Plaintiff's vehicle was stopped preparatory to making a turn into
the Capital City Mall, located at 3506 Capital Mall Drive, Camp
Hill, Pennsylvania 17011.
6. At that same time and placer the Defendant was
LAW OFFICICS OF
)ALE E. ANSTINE, P. Co
TWOWES,. MARKET STREET operating her automobile directly behind the Plaintiff's vehicle
POSTC)FFICE BOX 952
YORK, Pl':'m"SYLVANIA 17405
(71'7)"46-0505 when she failed to stop before striking the rear of Plaintiff's
vehicle, resulting in injuries and damages to the Plaintiffs.
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7. This accident occurred as a result of the negligence of
the Defendant and was due in no manner to any act, or failure to
act, on the part of the Plaintiffs.
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8. This matter is alleged to exceed the applicable limits
of arbitration, and a jury trial is hereby demanded.
COUNT I
CHRISTINE A. ASCHERL
v.
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ELLEN CHACK
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9. The allegations contained in paragraphs 1 through 8 are
incorporated herein and made part hereof as fully as though set
forth at length.
lO. The negligence of the Defendant consisted of the
following:
a) Failing to properly operate and control
her motor vehicle;
b) Failing to keep alert and maintain a
proper lookout for the presence of other
motor vehicles on the streets and
highways;
c) Operating her motor vehicle with
careless disregard for the safety of
others, and the Plaintiff in particular,
in violation of 75 Pa.C.S. ~3714;
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Failing to have her vehicle under
control so as to bring it to a stop
within the assured clear distance ahead,
in violation of 75 Pa.C.S ~3361;
l-AWO"FICESOF
[)ALE E. A.NSTINE. P. C.
TWO WEST ~~ARKET STREET
POST OH-ICE SOX 9S~
YORK, PENNSYLVANU- 1740l';
(717)646-0606
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e)
Operating her vehicle too fast for
conditions then and there existing,
violation of 75 Pa.C.S. ~3361;
the
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Following too closely
vehicle, in violation
~3310; and
to Plaintiff's
of 75 Pa.C.S.
g)
Failing to stop or take
action before striking
Plaintiff's vehicle.
other evasive
the rear of
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11. As a result of the negligence of the Defendant,
Plaintiff Christine A. Ascherl suffered serious and permanent
injuries, including but not limited to, cervical, thoracic, and
lumbar strain/sprain, and a severe shock to her nerves and
nervous system.
12. As a result of the negligence of the Defendant, the
Plaintiff was forced to incur medical bills and expenses for the
injuries she has suffered, the cost or reasonable value of which
is, or may be, in excess of the sum recoverable under the
Pennsylvania Motor Vehicle Financial Responsibility Law, and she
will continue to incur medical expenses in the future.
earnings and impairment of her earning capacity.
This loss of
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13. As a result of the negligence of the Defendant, the
Plaintiff has suffered, or may suffer, a severe loss of her
income and impairment of earning capacity has exceeded, or may
exceed, the sum recoverable under the Pennsylvania Motor Vehicle
LAW OFFICE:S OF
[)ALE E. .l\.NSTINE. P. C.
TWO WEST MARKET STREET
POSTOfoFICE SOX9">!
YOBX, P"><NSYLVANL/L 17405
(7'7)646_0506
Financial Responsibility Law, and the loss of income and
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impairment of earning capacity will, or may, continue in the
future.
14. As a result of the negligence of the Defendant, the
Plaintiff has undergone, and in the future may undergo, great
mental and physical pain and suffering, mental anguish and
humiliation, loss of life's pleasures, and a severe limitation in
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her pursuit of daily activities, all to her great loss and
detriment.
WHEREFORE, Plaintiff respectfully requests this Honorable
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Court to enter judgment against the Defendant in an amount in
excess of the mandatory arbitration limits.
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COUNT I I
SIEGFRIED A. ASCHERL
ELLEN CRACK
15. The allegations contained in paragraphs 1 through 14
are incorporated herein and made part hereof as fully as though
set forth at length.
16. Solely as a result of the negligence of the Defendant,
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LAW\)FF1CES OF
)ALE E. ANSTINE. P. C.
TWOWESTMARKE:T STREET
POSTOFTICE BOX"S~
YORK, PENNSYLVANIA. 1740~
17'7)646-0605
and the resulting injuries to his spouse, Plaintiff Siegfried A.
Ascherl has been deprived of the assistance, companionship and
consortium of his wife, all of which has been to his great loss
and detriment. Said losses may continue for an unknown time into
the future.
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LAW OFFICES OF
[)A.LE E. ANSTINE, P. C.
TWO WEST "ARKET STREET
POST OFFICE SOX"""
YOlU<, PENlOSYLV.AN(A 1740~
17)7) S46-OBOB
WHEREFORE, Plaintiff respectfully requests this Honorable
Court to enter judgment against the Defendant in an amount in
excess of the mandatory arbitration limits.
RESPECTFULLY SUBMITTED:
LAW OFFICES OF DALE E. ANSTINE, P.C.
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Gregory'E. Martin, Esquire
Attorfiey I.D. #38894
Two West Market street
P.O. Box 952
York, PA 17405
(717) 846 - 0606
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LAW OFFICES OF
DALE E. ANSTINE, P. Co
TWOWE:ST MARKET STREET
POST OFFICE BOX 9,.",
YOm<, PENNSYLVANLlo. 1740tl
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VERIFICATION
I HEREBY VERIFY that the information set forth in the foregoing Complaint is true
and correct to the best. of my knowledge, information and belief. I understand that any false
. statements contain:edhe~in are subjeet to the pem:1tiesof 18 Pa.C.S. ~4904, relating to unsworn
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falsification to authorities.
0~ Q. CwchvA1. ~
Christine A. Ascher!
Date: $an_6 2pqO
Jan 6 2000
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CHRISTINE A. ASCHERL and
SIEGFRIED A. ASCHERL,
Plaintiffs
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL V AN1A
: NO. 2000-237 CIVIL TERM
v.
: CIVIL ACTION - LAW
ELLEN CHACK,
Defendant
: JURY TRIAL DEMANDED
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance on behalf of Defendant, Ellen Chack, in the above-
captioned case.
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOGGIN
BY;
THEW L. 0 S, ESQUIRE
100 Pine Street, 4th Floor
P.O. Box 803
Harrisburg, P A 17108-0803
LD. No. 76080
(717) 232-9324
DATE: l.1 10' 0 ()
Attorneys for Defendant
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SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2000-00237 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ASCHERL CHRISTINE A ET AL
VS
CHACK ELLEN
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
, to wit:
CHACK ELLEN
but was unable to locate Her
in his bailiwick. He therefore
deputized the sheriff of JUNIATA
County, Pennsylvania, to
serve the within COMPLAINT & NOTICE
On February 9th, 2000 , this office was in receipt of the
attached return from JUNIATA
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep. Juniata Co
l8.00
9.00
10.00
20.30
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57.30
02/09/2000
DALE E. ANSTINE
So ans~j#
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R. <homas Kline
Sheriff of Cumberland
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Sworn and subscribed to before me
this
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Prothonotary
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In The Court of Common Pleas of Cumberland County, Pennsylvania
Christine A. Ascherl, et. al.
VS.
Ellen Chack
No: 20-237 Civil
Now,
1/21/2000
, 20I2D-, I, SHERIFF OF CUMBERLAND COUNTY, PA,do
hereby deputize the Sheriff of Juniata
County to execute this Writ, this
, deputation being made at the request and risk of the Plaintiff.
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Affidavit of Service
Now,
January 28
2000 at 11:30 o'clock A. M. served the
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within
NOTICE & COMPLAINT
upon
Ellen Chack
at RR 4, Box 900, Mifflintown, Juniata County, Pennsylvania
by handing to
Evelyn Robinson, mother of defendant
a ' +rue and attest.ed
copy of the original Notice & Complaint
and made known to
her
the contents thereof.
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COSTS
SERVICE
MILEAGE
AFFIDAVIT
.
, Sworn a3/ s~scr. ibe...~... [o.re.' "
me this ~day of .... .,20 at
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Y 'j' ..^,;r" . ~0Q4
FirsfM.9n~!\y, )fiA!\ll. .. '
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"0 REFUND
$ 18.00
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$ 20.30
$ 54.70
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\05 _A ILlABIMLOILLPG\43974\SXW\19183\00686
CHRlSTINE A. ASCHERL and
SIEGFRIED A. ASCHERL,
Plaintiffs
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLV AN1A
: NO. 2000-237 CIVIL TERM
v.
: CIVIL ACTION - LAW
ELLEN CRACK,
Defendant
: JURY TRIAL DEMANDED
NOTICE TO PLEAD
TO: PLAINTIFFS
You are hereby notified to plead to the enclosed New Matter within twenty (20) days
from service hereof or a default judgment may be filed against you.
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOG
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By:M- j-
MATTHEWL. 0 S, QUIRE
100 Pine Street, Fourth Floor
P.O. Box 803
Harrisburg, P A 171 08-0803
J.D. No. 76080
(717) 232-9324
Attorneys for Defendant,
Ellen Chack
DATE: z.f 1..! I 0 ()
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105 _^ ILIABIMWILLPG\43957\SXW\19183100999
CHRISTINE A. ASCHERL and
SIEGFRIED A. ASCHERL,
Plaintiffs
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLV ANlA
: NO. 2000-237 CIVIL TERM
v.
: CNIL ACTION - LAW
ELLEN CRACK,
Defendant
: JURY TRIAL DEMANDED
ANSWER WITH NEW MATTER OF DEFENDANT.
ELLEN CHACK, TO PLAINTIFFS' COMPLAINT
AND NOW, comes Defendant, Ellen Chack (hereinafter "Defendant"), by and
through the undersigned counsel who answers Plaintiffs' Complaint as follows:
1. Denied. Defendant lacks knowledge sufficient to form a belief as to the
truth ofthe allegations contained in Paragraph 1, and therefore, the same is denied with strict
proof thereof required at trial.
2. Admitted.
3. Denied. Defendant lacks knowledge sufficient to form a belief as to the
truth of the allegations contained in Paragraph 3, and therefore, the same is denied with strict
proof thereof required at trial.
4. Admitted.
5. Denied. Defendant lacks knowledge sufficient to form a belief as to the
truth of the allegations contained in Paragraph 5, and therefore, the same is denied with strict
proof thereofrequired at trial.
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6. Denied. Paragraph 6 contains conclusions oflaw to which no response is
required, and therefore, the same allegations are denied with strict proof thereof required at trial.
7. Denied. Paragraph 7 contains conclusions oflaw to which no response is
required, and therefore, the same allegations are deuied with strict proof thereof required at trial.
8. Denied. Paragraph 8 contains conclusions oflaw to which no response is
required, and therefore, the same allegations are denied with strict proof thereof required at trial.
COUNT I
CHRISTINE A. ASCHERL V. ELLEN CHACK
9. Responding Defendant incorporates by reference her responses to
Paragraphs I through 8 of Plaintiffs , Complaint as if set forth herein at length.
10. (a) - (g). Denied. Paragraph 10(a) - (g) contains conclusions oflaw to
which no response is required, and therefore, the same allegations are denied with strict proof
thereof required at trial.
11. Denied. Paragraph 11 contains conclusions of law to which no response is
required, and therefore, the same allegations are denied with strict proof thereof required at trial.
12. Denied. Paragraph 12 contains conclusions oflaw to which no response is
required, and therefore, the same allegations are denied with strict proof thereof required at trial.
13. Denied. Paragraph 13 contains conclusions oflaw to which no response is
required, and therefore, the same allegations are denied with strict proof thereof required at trial.
14. Denied. Paragraph 14 contains conclusions of law to which no response is
required, and therefore, the same allegations are denied with strict proof thereof required at trial.
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WHEREFORE, Defendant respectfully requests judgment in her favor and against
the Plaintiffs together with such costs this Honorable Court deems appropriate.
COUNT II
SIEGFRIED A. ASCHERL V. ELLEN CHACK
15. Responding Defendant incorporates by reference her responses to
Paragraphs 1 through 14 of Plaintiffs , Complaint as if set forth herein at length.
16. Denied. Paragraph 16 contains conclusions of law to which no response is
required, and therefore, the same allegations are denied with strict proof thereof required at trial.
WHEREFORE, Defendant respectfully requests judgment in her favor and against
the Plaintiffs together with such costs this Honorable Court deems appropriate.
NEW MATTER DIRECTED TO PLAINTIFFS
17. Plaintiffs' claims are barred by the applicable statute of limitations.
18. Plaintiffs have failed to state a cause of action upon which relief can be
granted.
19. Plaintiffs are barred and/or limited by all applicable provisions of the
Pennsylvania Motor Vehicle Financial Responsibility Law.
20. No act or omission on the part of the Defendant was a substantial or
contributing factor in bringing about Plaintiffs' alleged injuries and/or damages, all said injuries
and/or damages being expressly denied.
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21. Any and all injuries and/or damages as described by Plaintiffs in their
Complaint, the same being expressly denied, were caused in whole or in part by acts or
omissions on the part of others over whom Defendant had no control or right of control.
22. Plaintiffs' claims are barred and/or limited by the doctrine of res judicata
and/or collateral estoppel.
23. Defendant breached no duty of care owed to Plaintiffs under the
circumstances.
24. Plaintiffs' claims are barred and/or limited by the Pennsylvania
Comparative Negligence Act.
25. Plaintiffs' comparative negligence was the substantial factor in bringing
about any injuries and/or damages alleged in the Complaint, said injuries and/or damages being
expressly denied.
26. Plaintiffs' claims are barred and/or limited by the applicable provisions of
the Pennsylvania Worker's Compensation Act.
27. Plaintiffs' injuries, if any, were pre-existing and not caused by any act or
omission on the part of the Defendant.
28. At all times material hereto, Defendant acted in a safe, legal and non-
negligent manner.
29. Plaintiffs assumed the risk for their activities on the day in question with
regard to the litigation at hand.
30. Plaintiffs' claims are barred and/or limited by Plaintiffs' contributory
negligence.
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31. Because Plaintiffs chose the limited tort option enumerated in the
Pennsylvania Motor Vehicle Financial Responsibility Act, (75 Pa.C.S.A. S 1701, et ~),
Plaintiffs are balTed as a matter oflaw from recovering any damages.
32. Plaintiffs' negligence was the sole and proximate cause of the alleged
injuries and damages.
33. Plaintiff, Siegfried Ascherl's claim for loss of consortium is derivative,
and is barred as a matter oflaw.
34. Plaintiffs' claims are barred by the doctrine of sudden emergency.
35. Plaintiffs' claims and/or Complaint is barred and/or limited by the
provisions of Act 6 and more specifically, the selection of limited tort on the applicable
insurance policy.
WHEREFORE, Defendant respectfully requests judgment in her favor and against
the Plaintiffs together with such costs this Honorable Court deems appropriate.
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GO
BY:
NL\TTHEWL.OVVENS,ESQlITRE
100 Pine Street, Fourth Floor
P.O. Box 803
Harrisburg, P A 17108-0803
J.D. No. 76080
(717) 232-9324
Attorneys for Defendant,
Ellen Chack
DATE: 'L { ~ t ( fJ 0
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VERIFICATION
The undersigned hereby verifies that the statements in the foregoing Answer with New
Matter to Plaintiffs' Complaint are based upon information which has been furnished to counsel
by me and information which has been gathered by counsel in the preparation of the defense of
this lawsuit. The language of the Answer with New Matter to Plaintiffs' Complaint is that of
counsel and not my own. I have read the Answer with New Matter to Plaintiffs' Complaint, and
to the extent that it is based upon information which I have given to counsel, it is true and correct
to the best of my knowledge, information and belief. To the extent that the contents of the
Answer with New Matter to Plaintiffs' Complaint are that of counsel, I have relied upon my
counsel in making this verification. The undersigned also understands that the statements therein
are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to
authorities.
DATE: d- J '> / ~~
W t..'''-- Cl,'t ~
ELLEN CRACK
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CERTIFICATE OF SERVICE
I, Susan M. Williams, an employee ofMarsha1l, Dennehey, Warner, Coleman & Goggin,
do hereby certifY that on this ~L\"t~ay of February, 2000 served a copy of the foregoing
document via First Class United States mail, postage prepaid as follows:
Gregory E. Martin, Esquire
LAW OFFICES OF DALE E. ANSTINE, P .C.
Two West Market Street
P.O. Box 952
York,PA17405
j\loouf\l..~)~~
SUSAN M. WILLIAMS
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LAW OFFICES OF
DALE E. ANSTINE. P. C.
TWO WEST MARKET STREET
POST OFFICE sox 952
YOl<K, PENNSYLVANIA 174011
(7'7) S45-0SOS
IN THE COURT OF COMMON PLEAS OF CUMBERLAND CO., PENNSYLVANIA
CHRISTINE A. ASCHERL AND
SIEGFRIED A. ASCHERL
Plaintiffs
v.
ELLEN CHACK
Defendant
: 2000-237 CIVIL TERM
: Civil Action - Law
: Jury Trial Demanded
PLAINTIFFS' REPLY TO NEW MATTER OF DEFENDANT
17. Paragraph 17 states a conclusion of law to which no responsive pleading is
required.
18. - 19. Paragraphs 18 and 19 state a conclusion of law to which no responsive
pleading is required.
20. Denied. It is specifically denied that no act or omissions on behalf of
Defendant was a substantial contributing factor in bringing about Plaintiff's injuries. On the
contrary, Defendant's actions were the cause of this accident.
21. Denied. After reasonable investigation, Plaintiff is without sufficient
information to form a belief as to the truth or falsity of the averments contained in
Paragraph 21, and therefore, it is specifically denied and strict proof thereof is demanded
at trial.
22. Paragraph 22 states a conclusion of law to which no responsive pleading is
required. To the extent that such a responsive pleading is required, it is denied and strict
proof thereof is demanded at trial.
23. - 26.
Paragraphs 23 through 26 state a conclusion of law to which no
responsive pleading is required. To the extent that such a responsive pleading is required,
it is denied and strict proof thereof is demanded at trial.
LAW OFFICES OF
DALE E. ANSTINE. P. C.
TWO WEST MARKET STREET
POST OFFICE BOX 952
YOBX, P"NNSn.VA>i:lA 17405
(717)645_0505
27. Denied. It is strictly denied that Plaintiff's injuries were not caused by any act
or omission on the part of the Defendant, or that Plaintiff's specific injuries were pre-
existing.
28. - 30. Paragraphs 28 through 30 state a conclusion of law to which no
responsive pleading is required. To the extent that such a responsive pleading is required,
it is denied and strict proof thereof is demanded at trial.
31. Denied, Plaintiff has full tort coverage.
32. - 35. Paragraphs 32 through 35 state a conclusion of law to which no
responsive pleading is required. To the extent that such a responsive pleading is required,
it is denied and strict proof thereof is demanded at trial.
WHEREFORE, Plaintiffs respectfully request judgment in their favor and against
the Defendant together with costs and interest as allowed by law,
Respectfully submitted,
LAW OFFICES
DALE E. ANSTINE, P.C.
: Grego E. Martin, Esquire
LD. NO: 38894
Two West Market Street
P.O. Box 952
York PA 17405
(717) 846-0606
LAW QFFICE:S OF
DALE E. ANSTINE, P. C.
TWOWE:ST MARKE:TSmE:E:T
POST OFFICE BOX 9S2
Yom<, PENNSYlNAlltL!. 17401>
(717)B4s-0eoe
VERIFICATION
I HEREBY VERIFY that the information set forth in the foregoing Reply to New
Matter is true and correct to the best of my kno'Yledge, information and belief. I understand
that any' false statements contained herein are subject to the penalties of 18 Pa.C.S. fi4904,
relating to unsworn falsification to authorities.
0lvt~ o. (kchuJ._
Christine A. Ascher!
Date: l1'aI.rc,!l11',2000
Barch 17 2000
Date: , . .
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LAW OFFICES OF
DALE E. ANSTINE. P. C.
TWO WEST MARKET STREET
POST OFFICE BOX 952
YOBK, PENNSYLVANIA 17405
17'7)646_0606
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CERTIFICATE OF SERVICE
AND NOW, this 17th day of March, 2000, I, Gregory E. Martin, Esquire, a
member of the Law Offices of Dale E. Anstine P,C., hereby certify that I have, this date,
served a copy of the within and foregoing Plaintiff's Reply to New Matter of Defendant
first class United States Mail, postage, pre-paid, addressed to the party or attorney of
record as follows:
Matthew Owens, Esquire
100 Pine Street, 4th Floor
P.O. Box 803
Harrisburg PA 17108-0803
Respectfully submitted,
/
BY,13regory E. Martin, Esquire
1.0. NO: 38894
Two West Market Street
P.O. Box 952
York PA 17405
(717) 846-0606
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Christine A. Ascherl and
Siegfried A. Ascherl
No: 2000-237
v
Ellen Chack
CIVIL ACTION - LAW
PRAECIPE TO REMOVE
To the Prothonotary: Stacia N. Gates
(X) Please mark the above captioned action SETTLED AND SATISFIED
OR
( ) Please mark the above captioned judgment or lien settled and satisfied.
,~.
Grego}YE. Martin, Esquire
Attorney for the Plaintiffs
1.0. No: 38894
CC: Matthew L. Owens, Esquire
PLEASE ISSUE A CERTIFICATE OF SETTLEMENT AND SATISFACTION TO
ATTORNEY MARTIN.
DALE E. ANS'l'INIll. P. C.
YO"K,PENNSYLVANiA 1740(1
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