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Home My WebLink About02-5419STEPHEN M. VINSON, Plaintiff JANELLE MERCURIO Defendant IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA No. CIVIL ACTION - LAW NOTICE TO DEFEND 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 entedng a written appearance personally or by attomey and filing in wdting 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 YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP. CUMBERLAND COUNTY REFERRAl_ SERVICE Court Administrator Cumberland County Courthouse Cadisle, PA 17013-3387 (717) 240-6200 NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar un~, apadencia escdta o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY REFERRAl. SERVICE Court Administrator Cumberland County Courthouse Carlisle, PA 17013-3387 (717) 240-6200 STEPHEN M. VINSON, : Plaintiff : : JANELLE MERCURIO Defendant IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA No. CIVIL ACTION - LAW COMPLAINT 1. The Plaintiff is an adult individual resMing at 1106 Yverdon Drive, Apartment A6, Camp Hill, Pennsylvania 17011. 2. The Defendant is an adult individual residing at 2514 Market Street, Camp Hill, Pennsylvania 17011. 3. The facts and occurrences herein related took place on or about November 14, 2000, on Market Street in Camp Hill, Pennsylvania near its intersection with 19~ Street. 4. At the time and place aforesaid, Plaintiff was the owner and operator of a 1993 Ford Escort, which was then and there stopped in a line of traffic for a red traffic signal. 5. At the time and place aforesaid, Defendant was the owner and operator of a 1989 Pontiac Sunbird, which he caused or allowed to strike a vehicle that was standing behind Plaintiffs vehicle, causing such vehicle to strike the Plaintiffs vehicle and causing the damages hereinafter set forth. 6. The aforesaid accident and damages resulting therefrom were caused by the negligence of the Defendant in that she: a) failed to keep a proper look out for other vehicles; b) operated her vehicle at a speed too fast for conditions then and there existing; c) operated her vehicle at a speed so as to be unable to stop within the assured clear distance ahead; d) operated her vehicle in a careless and negligent manner so as to strike a stopped vehicle, which in turn was propelled into the Plaintiffs stopped vehicle. 7. Solely as a result of the Defendant's negligence, Plaintiff has sustained damages totaling FOUR THOUSAND ONE HUNDRED EIGHTY-ONE and 89/100 ($4,181.89) DOLLARS, which includes a rental b ill while Plaintiffs vehicle w as being repaired. WHEREFORE, Plaintiff demands judgment against the Defendant in an amount not in excess of mandatory arbitration limits. Dated: By Respectfully submitted, WiX, WENGER & WEIDNER Richard H. Wix, Esq., ID# 07274 Attomeys for Plaintiff 4705 Duke Street Harrisburg, PA 17109-3099 (717) 652-8455 2 VERIFICATION I, Stephen Vinson, have read the foregoing Complaint which has been drafted by my counsel. The factual statements and/or denials contained therein are true and correct to the best of my knowledge, information e~d belief. I am authorized to make this verification. This verification is made only as to the factual averments contained therein and not to legal conclusions and averments authorized by counsel in his capacity as attorney for the party or parties hereto. This verification is made subject to the penalties of 18 PA. C.S. Section 4904, relating to unsworn falsification to authorities which provides that, if I knowingly made false averments, I may be subject to criminal penalties. Date: n Vinson SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2002-05419 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND VINSON STEPHEN M VS MERCURIO JANELLE 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: MERCURIO JANELLE but was unable to locate Her deputized the sheriff of DAUPHIN in his bailiwick. He therefore County, Pennsylvania, to serve the within COMPLAINT & NOTICE On February 20th , 2003 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Mileage Dep Dauphin County 18.00 9.00 10.00 10.35 29.25 76.60 02/20/2003 WIX WENGER WEIDNER ~~So answe : . Thomas ~±f~ne Sheriff of Cumberland County Sworn and subscribed to before me this J7~ day of J~c~7 o2~ A.D. Prothonotary Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania : VINSON STEPHEN M vs COunty of Dauphin : MERCURIO JANELLE Sheriff' s Return No. 2626-T - - -2002 OTHER COUNTY NO. 02 5419civil I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for MERCURIO JANELLE the DEFENDANT named in the within NOTICE & COMPLAINT and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, December 20, 2002 COMPLAINT EXPIRED AS OF 12-20-02 Note: Dauphin Co. Deputies attempted service severaltime at address-left notes for def. to call our office - last 3 times de~lties were at address-note was still there. Sworn and subscribed to before me this 13TH day of FEBRUARY, 2003 PROTHONOTARY So Answers, Sheriff of Dauphin County, Pa. By Deputy Sheriff Sheriff's Costs: $29.25 PD 11/19/2002 RCPT NO 172045 In The Court of Common Pleas of Cumberland County, Pennsylvania Stepehn M. Vinson VS. Janelle Mercurio SERVE: s~ne No. 02 5419 civil Now, November 18, 2002 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA ]XlOW~ within Affidavit of Service ,20 , at o'clock M. served the 1/pon at By handing to and made known to copy of the original So answers, the contents thereof. Sworn and subscribed before me this ~ day of · , 20 Sheriff of COSTS SERVICE MILEAGE AFFIDAVIT County, PA