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Home My WebLink About02-5943KRAFT & KRAFT, P.C. BY: Robert E. Cherwony, Identification No. 17623 1311 Spruce Street Philadelphia, PA 19107 (215) 546-5100 Esquire Attorney for Plaintiff(s) ALLSTATE INSURANCE COMPANY, SUBROGEE OF VERNON & THELMA SANDERS 3800 Electric Road Roanoke, VA 24018 vs. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION AT LAW TIMOTHY FREEMAN 322 Market Street Lemoyne, PA 17043 CIVIL ACTION COMPLa?WT "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 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. "AVISO" "Le han demandado a usted en la corte. Si usted quiere defenderse de este demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demands y la notification. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a 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 continuar la demanda en contra suya sin previo aviso o notification. Ademas, la corte puede decidir a favor dei demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u ostros derechos importantes para usted. "LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFIICINA CUYA DIRECCION SE ENCUENTRA ESRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL." Court Administrator Courthouse, 4th Floor 1 Courthouse Square Carlisle, PA 17013 KRAFT & KRAFT, P.C. BY: Robert E. Cherwony, Attorney No. 17623 1311 Spruce Street Philadelphia PA 19107 (215) 546-5100 Esquire Attorney for Plaintiff(s) ALLSTATE INSLTRANCE COMPANY, SUBROGEE OF VERNON & THELMA SANDERS 3800 Electric Road Roanoke, VA 24018 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION AT LAW TIMOTHY FREEMAN 322 Market Street Lemoyne, PA 17043 CIVIL ACTION No. above. Plaintiff is a corporation with an address as set forth 2. Defendant is an individual who resides at the address set forth above. 3. On or about 11/11/01 due to defendant,s negligence and carelessness, plaintiff's insured sustained damages in the sum of $8,065.77. 4. Although demand has been made, defendant has failed and refused to compensate plaintiff. WHEREFORE, plaintiff claims of the defendant(s) the sum of $8,264.77 plus interest in the amount of $497.84, for a total of $8,554.61 plus court costs, all of which are justly due and owing from the defendant(s) to the plaintiff. KRAFT & KRAFT, P.C,. /~ Robert E. Cherwony, Esquire Attorney for Plaintiff DE~K: F4K 513 16674~1 3 DOL: ID: 61 VERNON PROP/HONEOflNER HONE PHONE: DATE: 12 - 87 - 2881 INVOLVED PERSON STRTEflENT - 2681 INSD: VERNON SOHOERS BUS PHONE: (717)737-8693 STHT EHPL NONE: STRTEHENT TYPE: PAGE: I OF 1 SANDERS EFFECT OH INSD LIAO AND/OR CLNT DANOGES: NOTIFY: ANALYSIS: neu file reo'd in rnscc cause of loss: CLNT UPSTAIRS PLACED ASHES IN TRASH CON AND STRRTED FIRE. property dm§ to insds kitchen: theory of liability: elmt careless uith use of cigarette: chain of evidence: draft, estieate and neus article fire report ordered. (to follou) parties notified: tleothy freeman 62 total amount ~1989.27 inelu dod $258.88 statue expires 11/!1/84 x-letting file to ebe. their phone # is 888-222-1211 changed desk Ice. and eatergory, data sheet completed, insddn and eletee Itrs generated. HAS: 18 - 9P SUBRO CONNENTS (8=NONE 1=FRY 2= UNFRV) PFS-SCHED F/U PFT-BRCKWD PF8-FRWD PFg-PRINT PFII-PREV STNT PF12-NEXT STNT *** IF YOU CONTINUE. ONLY YOU RILL BE ALLOflED TO UPDATE THIS STATENENT *** D~SN: F~IK INVOLVED PERSON STATEMENT PAGE: ! OF 513 1667~I~ 3 DOL: 11 - II - 2681 INSD: VERNON SUNDERS ID: 81 VERNON SBNDERS PROP/HONEOflNER HOUE PHONE: (717)73~-z!5~5 BUS PHONE: (717)737-8693 HAS: 18 - 9P STHT ENPL NONE: YVETTE SIENKIEHICZ DOTE: 11 - 17 - 2681 STATEMENT TYPE: SUBRO COHHENTS EFFECT ON INSD LIAB AND/OR CLMT DAMAGES: (8=NONE 1;FAV ~= UNFAV) NOTIFY: ON~LYSI$: SUBRO YES RECOVERY RILL BE SLIM. FZRE STARTED IN UNiT ABOVE INSDS. 82 flINTEO LANE. TENANT. TIMOTHY FREEMAN iS APPARENTLY UNINSD. HE HOD LIVED ZN THIS UNiT FOR BPPROX I§ YEARS. ! HAVE A COPY OF THE PATRIOT NEXS. 11/13/81 STATING THOT THE TOP FIRE HBRSHRLL FOR E PENNSBORO JANES BUNGORDNEO. AND THE Trip DETECTIVE. JOSEPH LANDIS. STATED THE LOUSE OF LOSS fiRS CIGARETTE BUTT IN TRNSH CAN OF MR FREEMRN'S KITCHEN. 3 PFS-SCHED F/O PF7-ONCNND PFB-FRHD PFg-PflINT PFII-PREV STILT PFI~-NEXT STILT ONLY EMPLOYEE HDMT CAN UPDATE THE STATEMENT YOU HAVE SELECTED *** B 1 2 · THE PATRIOT-NEWS · TUESDAY, NOVEMBER 13, 2005 POLICE ROUNDUP Franklin County Veterans FATAL ACCIDENT: State police at Chambersburg are investigat- ing a one-car crash that killed a Met;,mnellsburg man early yes- Timothy B. McQuade, 40, of the 200 block of Crystal Drive, was pronounced dead just after midnight after the car he was driving east on Route 80 in Hamilton Twp. crossed the lanes of travel and left the road police said. Police said the car went dow] a bank, became airborne and struck a tree, ejecting McQuade. Cumberland County HIGH SPEED CHASE: A Gettys* burg lllan was in Cumberland County Prison yesterday after leading police on a two-county cha~e that ended shortly after his car struck a Gettysburg Po- lice cai' Police said Michael Small, 34, was driving errati rally on interstate 81 Middleton Twp, at 1:40 a.m. ' mrday. When police attem !. stop him, Small lefi the high ~a.x and drove south on '~4. then south on Route 15 Adams County at very t'ates (ff speed, police said. H~s Buick hit a Small continued driving for tnnp until he abandoned and tried to run away, police said. After his capture, he was treated for facial injuries at C-ettysburg Hospital. Small is charged with reck- less endangering, fleeing or at- tempting to elude a police offi- cer resisting arrest and driving ~[~th a suspended license, among other charges. SUSPECT CHASED: Police were led on a wild chase through Carlisle early yesterday as they tailed a suspect down the wrong sides of roads, along rail- road tracks and even down a four-foot block wall. ,Iohn Mollison, 37, of the first block of Bonnybrook Road, was in Cumberland County Prison yesterday on charges of reck- less endangering, fleeing police, driving under the influence of alc~)hol and other charges in- ,qudinc those stemming from A search of their car revealed roamed in critical conditioni a chunk of crack cocaine with a yesterday n the Penn State street value of $1,000. Police Milton S. Hershey Medical Cen- charged Neely with possession ter. i receive with intent to deliver crack co- Kendra Binkley, 11, of ,Jones caine. Street. a passenger in Horst's The men were arraigned be- vehicle, was upgraded to serb fore District ,Justice Tom ous condition, while passenger Placey and placed in Cum- Victoria Binkley, 9, remains listed in fair condition. Malaya Binkley. 7, another passenger, 17men 'graduate' units in the Summerdale Apart. [ was discharged Sunday. from high schools merits complex in East Penns- I Killed in the accident were boro Twp. were temporarily [Claylon Geesaman, 17, of the homeless after a Sunday-night [40e block of Jones Street, Leba- Dy SYEVE SSYOeB fire that started in a kitchen Ipon, a passenger in Horst's car, A~D ~OS~CA VO~ DOeE~ECK trash can. Brmn S. Rothenberger, 85, Of OUR LEBANON BUREAU Township firefighters were ;outh Felty Road, Pine called to 82 Winter Lane at 9:47 driver of a truck with LEBANON -- Lebanon p.m. after fire was discovered hich Horst's car collided. School's alma mater refer~ in the kitchen of Timothy Free- Also still in critical condition "her valiant sons so true." man's apartment, according to was Arlene Gettler, I Seven of those sons c~ police and fire reports, of L~banon, whose vehicle i home yesterday to receive t Township Fire Marshall head-on Friday morn. James Bumgardner said fire- into a pickup driven by' left school early to fight. fighters needed about 15 min- Shearer, 30, of Harris- i win, World War II. utes to control the flames, and "I never expected a ceren confined fire damage to the said Gettler's car was i like this," Army veteran kitchen. ' in the wrong lane of ilam Fritz said. "I though: The remainder of Freeman's Man~ Avenue about ahalf just get a diploma.' apartment sustainedsmokeand ile west of Myerstown in! The nine diplomas -- water damage, and water dam- ckson Twp. Shearer was were presented to widm~ aged an apartment below Free- and released Friday at veterans -- were awarded man's, ing a one-hour ceremony Township Detective Joseph included a video clip f Landis said cigarette ashes of 18 employees at the "Band of Brothers," the were placed in the trash can Rush Cabaret in Lockdale ! television miniseries a which caught the container on Friday night came because World War IFs Easy Com~ fire and then spread to the were dancing to-the legendary 506th Regit kitchen cabinets. ' nude, state police said. of the Army's 101st Airb ) mJurms This was in violation of a sec- Division. VAHDAL$ SOUSHT: Vandals arm- tion of the Pennsylvania Dick Winters. the ce~ ed with a pellet BB gun shot out Crimes Code which regulates character in the 10-part mi windows on 15 vehicles in Me- activities within bottle clubs, ties and a resident of Her: chanicsburg during the week- establishments where patrons was one of the witnesses end. bring .their own alcoholic bev- day. Police said the damage oc- erages. This day, however, bdo curred between 11 p.m. Satur- "Topless" dancing is not pro- to Fritz and his lbllow vete~ "I look out in the audito day and 4 a.m. Sunday and in- hibited by the code as long as and see the pupils here volvedEast andVehicleSwest MarbleParked Street,al°rig ered.the dancer's nipples are cov- think, I wa,s that old wi West Keller Street and East A Pennsylvania Liquor Con- went over,' said Fritz, Main Street. trol Board employee said served in Germany, whe~ Readers with information earlier that topless clubs were ,, met his wife Selma that might assist the investiga- often bottle clubs since it meant [ "You had such a big des tion may call police at 691-3300. they could avoid stricter Liquor do something," ~¥itz said DffiV£~ CHA~ED: A 16-year-old Control Board regulations, ucation was second; cot Hampden Twp. teen-ager was All the employees, including came first." arrested Friday night after po- cashiers and security person- After the war. Fritz w, lice said he drove past Cum- nel, were arrested due to a sec- in the Cornwall ore mine berland Valley High School in tion of the law which states no and Selma raised two chi Silver Spring Twp. at speeds in one can operate or work in an Joann Zimmerman, ate excess of 100 mph. establishment where some em- and Annville Twp. comm l The teen, who police said was ployees are totally nude, said er, and William ,Jr., a lan( driving with the vehicle's head- State Police Sgt. Adam Kis- er. The family include.- .t.~... ~randchildreo and four facts set forth in the foregoing Complaint are true and correct to the best of my knowledge or information and belief. I make this Verification subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I knowingly make false statements, I may be subject to criminal penalties. Signature JUL 1 7 2002 SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-05943 p COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ALLSTATE INSUR3~NCE COMPANy VS FREEMAN TIMOTHY 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 FREEMAN TIMOTHY unable to locate Him COMPLAINT & NOTICE but was in his bailiwick. He therefore returns the the within named DEFENDANT , NOT FOUND , as to , FREEMAN TIMOTHY PER JEFF NELL WHO WORKS AT NEW INSIGHTS AT 322 MARKET STREET LEMOYNE, PA NEVER HEARD OF TIMOTHY FREEMAN, Sheriff s Costs: Docketmng Service Not Found Surcharge 18.00 9.66 5.00 10.00 .00 42.66 Sheriff of Cumberland County KRAFT & KP~AFT i2/1 /2002 Sworn and subscribed to before me this ~ day of '~ _ ~ ~ A.D. Pr6thonotary ,