HomeMy WebLinkAbout00-04933
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FRANK NEAL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2000- .1/93,3 CIVIL TERM
v.
JASON GANPT,
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
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FRANK NEAL,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2000- L;tJ,33 CIVIL TERM
Plaintiff
v.
JASON GANPT,
Defendant
COMPLAINT
AND NOW, comes the Plaintiff, Frank Neal, by his attorneys,
Addams & Rundle, and makes the following complaint:
1. The Plaintiff is Frank Neal, an adult individual
residing at 295 Crowell Street, Hempstead, NY 11550-5321.
2. The Defendant is Jason Ganpt, an adult individual
residing at 1523 Terrace Avenue, Carlisle, Cumberland County,
PA 17013.
3. The Plaintiff is the owner of 1993 Lincoln Town Car
which he was driving South on Interstate 81 in the right hand
lane near Exit 17 in Cumberland County, PA on August 30, 1999.
4. At said time and place the Defendant was driving an
automobile also traveling South and attempted to pass the
Plaintiff's automobile.
5. The Defendant negligently and carelessly collided with
the left rear of the Plaintiff's automobile causing the damage
hereinafter set forth.
6. The Defendant was negligent and careless in:
A. Failing to have his vehicle under control;
B. Colliding with the rear of the Plaintiff's
automobile;
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C. Attempting to pass when said movement could not be
made in safety.
7. As a result of the negligence and carelessness of the
Defendant, the Plaintiff's automobile sustained damage in the
amount of $1,858.25.
WHEREFORE, the Plaintiff demands judgment against the
Defendant in the amount of $1,858.25 plus interest and costs of
suit, an amount within the jurisdiction of arbitration under the
local rules of court.
ADDAMS & RUNDLE
By:
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Wil 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
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VERIFICATION
Frank Neal 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.
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DATE: 1/1/cn:;
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2000-04933 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
NEAL FRANK
VS
GANPT JASON
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named defendant, DEFENDANT
GANPT JASON
but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT & NOTICE
, NOT FOUND , as to
the within named DEFENDANT
, GANPT JASON
DEFT. NO LONGER RESIDES AT ADDRESS STATED, LEFT
NO FORWARDING, PAPER EXPIRED ON 8/11/00.
Sheriff's Costs:
Docketing
Service
Not Found Return
Surcharge
18.00
3.10
5.00
10.00
.00
36.10
County
ADD & RUNDLE
09/11/2000
Sworn and subscribed to before me
this
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P t onotary