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Home My WebLink About00-02644 ~. ~iIlI~ ~, - ,~,-~",,,-,,,I , . ERIC D. PAULES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, NO. 2000-;204'1 CIVIL TERM SCOTT L. KRAMER, 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 ~ ~~ . " -""'~ ~iIo.k!A.j', " ERIC D. PAULES, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000- il,t.11- CIVIL TERM SCOTT L. KRAMER, Defendant COMPLAINT AND NOW, comes the Plaintiff, Eric D. Paules, by his attorneys, Addams & Rundle, and makes the following complaint: 1. The plaintiff is Eric D. Paules, an adult individual residing at 71 Arlington Drive, Warren, PA 16365-3423. 2. The Defendant is Scott L. Kramer, and adult individual residing at 6982 Milbrook Park Drive, Apt. 1B, Baltimore, Maryland 21215-1129. 3. The Plaintiff is the owner of a 1995 Ford Windstar minivan which was being operated by Karen L. Paules at about 4:00 p.m. on July 8, 1998, traveling North on Interstate 83 approaching the Capital Beltway in Cumberland County, Pennsylvania. 4. At said time and place, the Plaintiff's vehicle slowed for traffic. 5. The Defendant was also traveling North on Route 83 behind the Plaintiff's vehicle, failed to slow down and negligently and carelessly collided with the rear of the Plaintiff's vehicle causing the damages hereinafter set forth. 6. The Defendant was negligent and careless in: A. Traveling too fast for conditions. B. Following the vehicle ahead too closely. ~. ~~~~ . - ,-- "-']>'I~, : " C. Failing to observe the Plaintiff's vehicle in time to avoid a collision. D. Failing to have his vehicle under control. 7. As a result of the negligence and carelessness of the Defendant, the Plaintiff's vehicle sustained damage in the amount of $942.75. WHEREFORE, the Plaintiff demands judgment against the Defendant in the amount of $942.75 plus interest and costs of suit, an amount within the jurisdiction of arbitration under the local rules of court. ADDAMS & RUNDLE BY:~~ will am 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 Eric D. Paules 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. 9~~) a / DATE: ,j///~ ___'-!ili\li[!li@lililb~~~'ill<"JiJ.'ifl'!'!1t-;;"'",",iJ"'ili~W'1Sib'<i,~~~~"",,,,,;;;..;j<i'.~:ill&JllJ!Wiil';j(~IIl;~!:m~ .AJ ~ J::) ..r:: .-C q3 ~ ]"':. -W ....-- ...i:) <L> }J W'l!IllUIT ~!IlfI~~iI>~~~-' ....c- ( Il.....r::: ()) Y'O ~~~~ 0~lS Jl} g~ j~ c"; ~ ;gi:.< 5:P-- (r) ,~ -, -<.'-' ~'~: L~ ~~: (" ~.,:-: ):,,..~' --~'-~~ c_ , ~,,' ~~ -',.~ --'1 -" :::j -<: .~..) (j'l " - L~ ^~ l...,".,"", r ., SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE NO: 2000-02644 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAULES ERIC D VS. KRAMER SCOTT L R. Thomas Kline , Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,KRAMER SCOTT L by United States Certified Mail postage prepaid, on the 2nd day of May ,2000 at 0008:00 HOURS, at 6982 MILBROOK PARK DRIVE APT 1B BALTIMORE, MD 21215-1129 , a true and attested copy of the attached COMPLAINT & NOTICE Together with The returned receipt card was signed by SCOTT KRAMER 05/10/2000 on Additional Comments: Docketing Cert. Mail Affidavit Surcharge 18.00 3.56 .00 10.00 .00 31.56 so~..~ rlomas Kl~ Sheriff of Cumberland County Sheriff's Costs: Paid by ADDAMS & RUNDLE on 05/18/2000 . Sworn and subscribed to before me this .J.</,e: day of ~ .:2.cnnJ A.D. ~Q<~~ P othonotary , o Compl9te ifems 1 and/or 2 for addition~1 services. Complete items S, 4a, and 4b. o Print your name and address on the reverse of this fonn so that we can retum this card to you. a Attach this form to the front of the mailpiece, or em the back if space does not permit. o Write "Retum Receipt Requested" on the mailpiece below the article number. c a The Retum Receipt will show to Whom the article was dellverad and the date o delivered. !! 3. Article Addre&.ed to: m C. E o .. i ....~. .. .. ~ i m = Qt~':" ScottI;. Kramer 6982~lbrook Park Drive Apt lB'! Baltimore, MD 21215-1129 6. Signature (Addressee or Agent) l.' - "- /aIso~t\l~""lh~fQJI~- I, ing .e_"""an """" ie<>): 1, 0 Addressee's Address 2, 0 Restricted De/iveIV 3 9-01 ,..erCertified o Insured o COD jf requested and ,J.!i 1U2S~~a~ !'lece! , . IIIIIIIIIIIIIII ,; ., " ,jf I I J ! - - '.""'., < , ~ ERIC D. PAULES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-2644 CIVIL TERM SCOTT L. KRAMER, Defendant PRAECIPE Sir: Please enter a default judgment in the amount of $942.75 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: ~~ Wlllia . Addams Supreme Court I.D. No. 06265 Attorneys for Plaintiff 28 South Pitt Street P.O. Box 208 Carlisle, PA 17013 (717) 249-8300 TO: Curtis R. Long, Prothonotary DATE: July 13, 2000 ~~rk..1..", , '--~ '-....- ERIC D. PAULES, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-2644 CIVIL TERM SCOTT L. KRAMER, Defendant NOTICE TO TAKE DEFAULT JUDGMENT TO: Scott L. Kramer 6982 Milbrook Park Drive, Apt. 1B Baltimore, Me 21215-1129 DATE OF NOTICE: June 23, 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. Court Administrator Fourth Floor Cumberland County Courthouse Carlisle, PA 17013 . (717) 240-6200 ADDAMS & RUNDLE By: . William A. Addams Attorneys for Plaintiff 28 South pitt Street P.O. Box 208 Carlisle, PA 17013 (717) 249-8300 -- .,~-_-.._,. ,1- -. ." ,--, ,- ,_"", _",_~~"',",",._y,,,,,,_"_ _,7.__" ",',,'-,'- l\1Ii_~~ ,.- .', -,,~, '0" ~ ,'''"" ""If~ t f ~ fli ~ ~ o o ~ <:J~ ~ 700 th-~ ~ ~ - -0 6' ''';; '-'<C', ~ () a C a s:: ;geG ~ -z.fJl l~ 65~" --< 0.. c.-o ~CJ ~c ::E $0 -a.. c:: - z .. =<:..> c.;, ., -"~- '" ,. ." <.-''''' ,,--, ~~ -,-.' :-'-~.;Jl .-')!:!J /]i':~ ~~?d C-';:rTi ~ -<: ~~~",.~- J1 ~~. . "'~ ....'" ~ """'_""""'-~=!L,.",~," ERIC D. PAULES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-2644 CIVIL TERM SCOTT L. KRAMER, Defendant AFFIDAVIT The undersigned hereby deposes and says that the judgment entered in the above captioned matter was as a result of a motor vehicle accident. ADDAMS & RUNDLE By: /~~ Supreme Court I.D. No. 06265 28 South Pitt Street Carlisle, PA 17013 (717) 249-8300 Attorneys for Plaintiff Sworn to and subscribed before me this 13th day of September, 2000 'tfJi 'f4 O~ Notarial Seal Mary M. 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