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Home My WebLink About02-5602 02HB-00170 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, P A 17011 Telephone Number: (717) 731-0988 Attorneys for Plaintiff Nationwide Mutual Insurance Company NATIONWIDE MUTUAL INSURANCE COMPANY, A1s/o KATIE S. KNAUB, (PLAINTIFF) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY , PENNSYLVANIA VS. No. C;( - S'''6~ e~~L YUt.~ CLASSIC MOTOR LINES, INC. (DEFENDANT) CIVIL ACTION - LAW JURY TRIAL DEMANDED 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 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 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 CAN GET LEGAL HELP, CUMBERLAND COUNTY Cumberland County Bar Association 2 Liberty A venue Carlisle, P A 17013 (717) 249-3166 1-800-990-9108 02HB-00170 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, P A 17011 Telephone Number: (717) 731-0988 Attorneys for Plaintiff Nationwide Mutual Insurance Company NATIONWIDE MUTUAL INSURANCE COMPANY, A/S/O KATIE S. KNAUB, (PLAINTIFF) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. O.J. - 5t.D~ C~: ( ~tR."'t CLASSIC MOTOR LINES, INC. (DEFENDANT) CIVIL ACTION - LAW JURY TRIAL DEMANDED PLAINTIFF'S COMPLAINT I, Plaintiff Nationwide Mutual Insurance Company is an Ohio Corporation with offices at P,O. Box 2655, 1000 Nationwide Drive, Harrisburg, Dauphin County, Pennsylvania 17105. 2, Defendant Classic Motor Lines, Inc. is a corporation with offices at P.O. Box 703, 501 Adler Street, Phillipsburg, Pennsylvania 16866. 3. At all times relevant hereto, Katie S. Knaub was insured by Plaintiff Nationwide Mutual Insurance Company with collision damage coverage for her automobile, which policy was issued in accordance with the Pennsylvania Motor Vehicle Financial Responsibility Law. 4. The events hereinafter described occurred on or about May 29 , 2002 at approximately 12:12 p.m, on the exit ramp from SR 581 to southbound SR 15 in or near the City of Camp Hill, Pennsylvania. 5. At all times relevant hereto, Plaintiff's insured, Katie S. Knaub, was lawfully operating her 1998 Dodge pick-up and was stopped in a line of traffic exiting SR 581 east and waiting to enter southbound SR 15. 6. At the above place and time, a truck owned by Defendant Classic Motor Lines, Inc., and operated in the course of Defendant's business by one of its agents, servants, workmen, or employees, was also exiting Eastbound SR 581 to travel southbound on SR 15. 7. At the above place and time, the Defendant's agent, servant, workman, or employee failed to slow or stop her 2000 Peterbilt tractor trailer and drove it into the rear of the vehicle owned by Katie S. Knaub and insured by Plaintiff. The collision resulted in damage to Katie S. Knaub's vehicle in the amount of$12,385.18. 8. The collision and damages were solely the result ofthe negligence of the agent, servant, workman or employee of Defendant Classic Motor Lines, Inc. and was not caused by any fault of the Plaintiff's insured, 9. The negligence ofthe agent, servant, workman or employee of Defendant Classic Motor Lines, Inc. consisted ofthe following: (a) Following too closely; (b) Failing to maintain a proper lookout for traffic and road conditions ahead; (c) Failing to slow Defendant's vehicle as it exited the highway; (d) Driving the Defendant's vehicle into the rear of the vehicle insured by the Plaintiff; and (e) Being otherwise careless and negligent. 2 10. Defendant Classic Motor Lines, Inc. is vicariously liable for the negligent acts of its employees. 11. Plaintiff is entitled to recover from the Defendant the amount it was required under the policy to pay for the damage to its insured's vehicle caused by the Defendant's employee, WHEREFORE, Nationwide Mutual Insurance Company respectfully requests this Honorable Court to enter judgment in its favor and against Defendant Classic Motor Lines, Inc. in the amount of$12,385.18, together with costs, interest and such other relief as deemed appropriate by this Honorable Court. Respectfully submitted, LAW OFFICES OF JACOBS & SABA Date: November 19, 2002 By: JoAnne . Attorney' r Plaintiff Identification No.55453 3 02HB-00170 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, P A 17011 Telephone Number: (717) 731-0988 Attorneys for Plaintiff Nationwide Mutual Insurance Company NATIONWIDE MUTUAL INSURANCE COMPANY, A/S/O KATIE S. KNAUB, (PLAINTIFF) IN THE COURT OF COMMON PLEAS YORK COUNTY, PENNSYLVANIA No, VS. CLASSIC MOTOR LINES, INC. (DEFENDANT) CIVIL ACTION - LAW JURY TRIAL DEMANDED VERIFICA TION I, Randy Rulapaugh, verify that the statements made in the foregoing Plaintif(s Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of Pa.C.S.A. 54904, relating to unsworn falsification to authorities. Dated: /() );)r'A~ k#~~o,^~ -h ~~~.~ Randy ulapaugh, Representative 0 Nationwide Mutual Insurance Company jCJ(:J~ ~ i ~ .......... -a e" ~ __ 0 ~~~ ~J- r ~ ~ N~TIO~1DE MUT\J~L lNS~CE coNtI> ~N'l, NS/O l(AT1B S. RN~UB, I>laintiff . IN r\lB COUR1 01' COWAON pLEAS " C\Jl.IBBJU..Al'lD coUJ'TI, PENNS'iL\1 A.NU' C~SE NO. 02.-560'2. CIV1L TERM CIV1L ~CTION - 1~ W v. CL~SSlC NtOTOR LINES, U'lC" Defendant ~~ 10 TIlB PROTIlON01p.R'i OF r\lB COUR1 OF coWAON pJ.,E"S' "" ",oceedi"'" ",neeon'" ,he ""o,,,"f-oed ",tion ,boula be ,taye<! pur"''''' \0 ,be filing ofa Petition unae' CbaI',e< I I oftbe Uni,e<! State' ,,-"'" co<\e in tbe wadle Di,^"et ofpe_yl,ania \0 c"e No. 1-02-0291 I, by CI""e Molo' tin<', Ine., \be Defenaant in \be ",i\bin ",tion. "eor>Y of ",eh petition i, .n",be<\. Tbi' Notiee i' ente<e<! fo' the li""te<! puq>o", of pro",ai"" notiee of \be penmng CbaI',e< II ,,"''''''''' ease an<\ i, not inten<le<l to be '" entri of .pp",ance by \be una""igne<\. ResllectfullY submitted, C\JNNU'lGllAM & CllERNlCOFF, I> .C. "y,4 w J(A)- () enrY W. Eck, Esquire I>ennsylvania ~ttorney Id. NO, 83087 2.32.0 North Second Street I>. O. BoX 60457 llarrisburg, I> ~ 17106-0457 (717) 2.38-6570 Date', December 9, 2.002. CERTIFICATE OF SERVICE -= I, Holly P. S;ekenn,", P","ega!, hereby eemry tha, 00 Decemb", 9, 2002, a /rue ,"d eo""" eopy of the focegomg NOnCE OF STAY Was '<Wed by fi"'-e1"" mail, postage prepaid on the following: JoAnne E. Kinzel, Esquire Law Offices of Jacobs & Saba 214 Senate Avenue Suite 503 Camp Hill, PA 17011 CUNNINGHAM & CHERNICOFF, P.C, By: J't~lLii.., l ~ULt' t I/l \.A.'--. Holly P.CSiekennall, Paralegal , I, , \ \ \ i \ \ \ \ g 0 0 N -1'l S- O -,..) -on] ,-" -""(I mIc- e") .. z....,... - .;t? z( (J) 0"':' I" ~~~~J, =<-" ~c.~: -:") .L...-n -~ .~ -~ ;'~;;~~) 'tW""\.- ; - ,;_~\~n ,,::...C' 5>-C 1',1 ~\ .,- ~ :? :it Iv SHERIFF'S RETURN - OUT OF COUNTY --- CASE NO: 2002-05602 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NATIONWIDE MUTUAL INSURANCE CO VS CLASSIC MOTOR LINES INC 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: CLASSIC MOTOR LINES INC but was unable to locate Them in his bailiwick. He therefore deputized the sheriff of CENTRE County, Pennsylvania, to serve the within COMPLAINT & NOTICE On December 18th, 2002 , this office was In receipt of the attached return from CENTRE Sheriff's Costs: Docketing Out of County Surcharge Dep Centre Co 18.00 9.00 10.00 42.50 .00 79.50 12/18/2002 NATIONWIDE ~ . lnomas i:;ne - . ~ Sheriff of Cumberland County INSURANCE Sworn and subscribed to before me thl' s 3 d f ,/] .<.--J- ay 0 ~. A. '" -7 )1JV3 A.D. ~O. ~ -, prothonoc~ ::1i- / '1 a,3 In The Court of Common Pleas of Cumberland County, Pennsylvania Nationwide Mutual Insurance Company VS. Classic Motor Lines, Inc SERVE: sane No. 02 5602 civil Now, November 26, 2002 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Centre County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~ .,/A.,.' ,f'....%/" .""'" -,p.o...." .~ ~""..~"''':.C, '-l-.".e.::-.,,-.t"~ Sheriff of Cum berland County, P A Affidavit of Service Now, VeCM1.Jer .'/ ,20 ~;z., at i3;':3 7 o'clock 7 M. served the within CI'UYlp J4)/J-! upon C/~,Jt,'c. M..trhr L//)~~, -7':;,c... , at ~ / A/d~r Sfr~e-6,. P/;'l~.s./v'7' ~. by handing to ~ kis ~. g erh-rJ If " It rP-tt..C a copy of the original c,Mf' 4:~1 I- and made known to /-PUI'.f"t: &rlb'~Av , the contents thereof So answers, -"-;;dd IT W(!'~vt'r '?)/S,P~r ,fH/FJe,r:-,.-:: Sheriff of County, PA , 20 0;1- COSTS SERVICE MILEAGE ,2J UP AFFIDA VIT ,1.,..JZ> /q.QP $ ~ 2.J/l> Sworn and subscribed me this ~ day of ~r Belk'f~nte Bo~;"Centre County ;.iJ~' 11~ J ~~~.~'.?~:,::~~n E~~~::~~.pt 5, 2005 ~\)J ~ . MBnl.}~ t, rennSyrV8llia Association of Notaries $ 02HB-00 170 LA W OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, P A 17011 Telephone Number: (717) 731-0988 Attorneys for Plaintiff Nationwide Mutual Insurance Company NATIONWIDE MUTUAL INSURANCE COMPANY, Als/O KATIE S. KNAUB, (PLAINTIFF) IN THE COURT OF COMMON PLEAS YORKCOVNTY, PENNSYLVANIA VS. No. 02-5602 CIVIL TERM CLASSIC MOTOR LINES, INC. (DEFENDANT) CIVIL ACTION - LAW JURY TRIAL DEMANDED ~ PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please mark the above-captioned case settled, discontinued and ended. LA W OFFICES OF JACOBS & SABA Date: January 27,2003 ~ ; .1 By: \ JoAnne b~ 'nzel, Esquire 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Te1ephoneNo. (717) 731-0988 Identification No. 55453 (Attorney for Plaintiff) o c:: < "'T] t~i~' me:: z.. ?'):I: v.. -. r:: ~2 ~-/ "-, =2 o (......:' , ,:,;-:.no ".) CD !:"" ::< 01