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KENNETH G. METTLER and
SHERYL METTLER, his wife,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-3303
v.
CIVIL ACTION - LAW
U-HAUL CO. OF CONNECTICUT
and ALEXANDER H. DEMPSEY,
Defendants
JURY TRIAL DEMANDED
ENTRY/WITHDRAWAL OF APPEARANCE
TO: PROTHONOTARY OF CUMBERLAND COUNTY
Kindly withdraw the appearance of Lynn F. Reutelhuber,
Esquire and substitute the appearance of David M. Green, Esquire,
both of whom are with the same firm, on behalf of Defendant in
connection with the above-captioned case.
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOGGIN
DATE: If (Ji~) err
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ID M. GREEN, SQUIRE
100 Pine Street - 4th Floor
P.O. Box 803
Harrisburg, PA 17108-0803
I.D. 47381
(717) 232-9325
r.A_
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5, On the aforesaid date, Defendant, U-Haul Co. of
Connecticut, was the owner of a 1989 International truck that was
involved in the collision described herein.
6. On the aforesaid date, Defendant, Alexander H. :J'~lOpsey,
was the owner of the trailer and driver of the truck that were
involved in the collision described herein.
7. Prior to the collision herein described, Plaintiffs
elected the full tort option in their motor vehicle insurance
policy, which was in effect at the time of the collision set forth
herein.
8, On the aforesaid date, at approximately 5:45 a.m"
Plaintiff, Kenneth G, Mettler, was operating his motor vehicle in
a southerly direction on, and in the left hand lane of, State Route
81 in Middleton Township, Cumberland County, Pennsylvania, at, or
about, the 475th segment marker of State Route 81, when his vehicle
struck Defendant, Alexander H. Dempsey's, trailer, which was
unattended, unlit, and detached from the U-Haul truck that
Defendant, Alexander H, Dempsey, was driving at the time of the
collision and that Defendant, U-Haul Co. of Connecticut, owned and
was leasing to said driver at the time of said collision.
2
9, At the time of the collision herein described, Plaintiff,
Kenneth G. Mettler, was traveling at a speed that was in compliance
with the posted speed limit and, prior to impact, had safely
changed from the right lane to the left lane of State Route 81
before colliding with said trailer.
10. As a direct and proximate result of the collision and
Defendants' negligent and reckless conduct, Plaintiff, Kenneth G.
Mettler, has suffered, and will suffer in the future, pain, agony,
irritation, and inconvenience.
11, As a direct and proximate result of the collision and
Defendants' negligent and reckless conduct, Plaintiff, Kenneth G.
Mettler, has been prevented from attending to his usual duties as
senior buyer for United Defense, L. P./ to his great detriment,
damage and loss.
12. As a direct and proximate result of the collision and
Defendants' negligent and reckless conduct, Plaintiff, Kenneth G.
Mettler, has incurred great expenses for medical treatment and
physical therapy, which expenses may continue into the futuce.
3
(e) towing a trailer without the statutorily required
rear lighting system and reflectors. (75 Pa. Cons.
Stat.~4303);
(f) failing to use statutorily required safety chains
while pulling a trailer. (75 Pa. Cons Stat. ~ 4905);
(g) towing a trailer without the statutorily required
safety chains. (75 Pa. Cons. Stat. ~ 4905);
(h) failing to remove unattended vehicle fl"om l'o3iway.
(75 Pa. Cons. Stat. ~ 3709);
(i) unlawfully depositing a dangerous material on a
highway. (75 Pa. Cons. Stat. ~ 3709).
15. As a direct and proximate result of the collision and
Defendant's negligent and reckless conduct Plaintiff, Kenneth G.
Mettler, sustained severe injuries to muscles, blood vessels,
tendons, connective tissues, bones, and or~ans of his body,
including, but not limited to, a traumatic dislocation and fracture
of his right patella and injuries to his neck, back, and head.
WHEREFORE, Plaintiff demands carnages from Defendant an amount
in excess of $25,000, exclusive of interest and costs.
5
(e) allowing Defendant, Alexander Dempsey, to tow said
trailer on the roadways of the Commonwealth of
Pennsylvania without inspecting said trailer prior
thereto;
(f) failing to inspect said trailer for a rear lighting
system, reflectors, and safety chains, all of which are
required by statutes in the Commonwealth of
Pennsylvania;
(g) allowing Defendant, Alexander Dempsey, to lease its
truck to tow a trailer, through the Commonwealth of
Pennsylvania, without a proper rear lighting system,
reflectors, and adequate safety chains.
18. Defendant is liable for Plaintiff's injuries resulting
from the negligent and reckless conduct of Defendant, Alexander
Dempsey, inasmuch as Defendant, U-Haul Co. of Connecticut,
negligently provided Defendant, Alexander Dempsey, with a truck to
tow said trailer.
19. As a direct and proximate result of the negligen~e of
Defendant, Plainti ff sustained severe injuries to rr.usd",,,. C" )('d
vessels, tendons, connective tissues, bones, and Ol'aan" C~ !118
body, including, but not limited to, a traumatic dislocatIon and
7
WHEREFORE, Plaintiff demands damages from Defendant in an
amount in excess of $25,000, exclusive of interest and costs.
Respectfully Submitted,
HANDLER &. WIENER
Date:
1,1/711
By: riA
David H. Ros ES1.
I. D. No. 20 9
319 Market:Stl~et
Harrisburg: PA 17]) ::77
Telephone No. 711,2 0,:000
Attorney for Plaint fEs
10
VERIFICATION
THE UNDERSIGNED hereby verify that the statements 1n the
foregoing are based on information that was gathered by counsel in
preparation of this lawsuit,
The language of the foregoing
document is of counsel and not ours.
We have read the said
document and, to the extent that it is based on information that we
gave to counsel, it is true and correct to the best of our
knowledge, information and belief, To the extent that the contents
of the said document is that of counsel, we have relied upon our
counsel in preparing this Verification.
THE UNDERSIGNED also understand that the statements the1"ein
are made subject to the penalties of 18 Pa.R.C.P. 2252 (dl C.S.
Section 4904, relating
to ~nsworn falsificati~~uthor1ties.
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June /.4, 1997
U-HAUL CO. OF CONNECTICUT
174 Boston Post Rd.
Orange, CT 06471
ATTENTION: Office of tlw Leg,d Coutwel or'
Adminintration
Re: Mettler. et ux. V~_!Lll,,"1 Co. of Connccti.l:.!.!L,cUl'j
Alexander II, n,'lIIlJlJeY
Court of Common Ple,IIl, Cumberland County, 1'''lllluylv''lIia
No. 97-3303 Civil
Civil Action - Law; ,Jury Tdal Demanded
Dear Sir 01' Madam:
In connection with the dlJovc~-J'!fe}"ellc,-~d rnatt(~}", !'llc'llJ:jl.,d plt,'due
find a Complaint that we filed with the COUI'I: 01 ('011I111011 I'l,',," in
Cumberland County, Penllsylvani.:., Oll behalf of OUt. ,.} i"III, Mr.
Kenneth Mettler. We are servin(.~ thin Complaint on you, "illt'l! you
are one of the Defendants in thin mattel', being I hI' OWIl"t. "I the
trailer involved in an accident au dellcl:ib,>d in Ih,' ,.tH'lnned
Complaint.
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Please provide this Complaint to YOlJl' coun,,,,1 <llld;,,, illlJllldllCe
company and have them cOlltact Ull au 130011 <lU pOll" ild,'. II y"" helVe
any questions or require <lny additiollal illtonnal.joll, 1'1".11," d,,/ llOt
hesitate to contact me. Thallk you [01' YOUI' al.I."1111011 10 this
matter.
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V"ry truly y(AI1 Il,
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HANDLER) and. WIENER
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KENNETH G. METTLER and
SHERYL METTLER, his wife,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97.3303
v.
U-HAUL CO. OF CONNECTICUT
and ALEXANDER H. DEMPSEY,
Defendants
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
ORDER
AND NOW, this day of
, 1997, it is
hereby ORDERED and DECREED thut the Preliminary Objections of
Defendant U-Haul Co. of Connecticut are hereby GRANTED, and the
objectionable Paragraphs of Paragraph 17, including Subparagraph
17 (a) and (c), and Paragraph 18 of Plaintiffs' Complaint, are
stricken from Plaintiffs' Complaint, with prejudice.
J.
KENNETH G. METTLER and
SHERYL METTLER, his wife,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-3303
v.
CIVIL ACTION - LAW
U-HAUL CO. OF CONNECTICUT
and ALEXANDER H. DEMPSEY,
Defendants
JURY TRIAL DEMANDED
PRELIMINARY OBJECTIONS OF DEFENDANT
U-HAUL CO. OF CONNECTICUT
TO PLAINTIFFS' COMPLAINT
Defendant, U-Haul Co. of Connecticut (hereinafter referred
to as "U-Haul"), hereby submits to this Honorable Court the
following Preliminary Objections to Plaintiffs' Complaint, and in
support thereof, avers as follows:
1. Plaintiffs Kenneth G. Mettler and Sheryl Mettler
(hereinafter referred to collectively as "Plaintiffs"),
instituted the current Civil Action by filing a Complaint on or
about June 20, 1997, against Defendants.
(A true and correct
copy of Plaintiffs' Complaint is attached hereto as Exhibit "A").
2. Plaintiff's Complaint appears to have been served upon
Defendant U-Haul on June 26, 1997.
3. U-Haul therefore submit these timely Preliminary
Objections to Plaintiffs' Complaint.
4. Plaintiffs' allegations stem from an alleged collision
on September 18, 1996, on Interstate 81 South in Cumberland
County, Pennsylvania, between the vehicle being driven by
Plaintiff Kenneth Mettler and a trailer allegedly owned by
Defendant Alexander Dempsey.
5. Plaintiff alleges that he incurred injuries/damages due
to said collision.
6, Plaintiffs allege in Paragraph 17, in part:
The occurrence of the aforesaid collision and
the resultant injuries to Plaintiff were
caused directly and proximately by the
negligent entrustment of Defendant [U-Haul]
generally, and, more specifically as set
forth below:
(a) allowing Defendant, Alexander
Dempsey, to use its truck in a
careless, reckless, and negligent
manner;
(c) allowing Defendant, Alexander
Dempsey, to lease its truck to tow
a trailer in a careless, reckless,
and negligent manner;
(See Paragraph 17 of Plaintiffs' Complaint, including Sub-
Paragraphs (a) and (c), which is attached hereto as Exhibit "A".)
7. Plaintiffs allege in Paragraph 18, as follows:
Defendant [U-Haul] is liable to Plaintiff's
injuries resulting from the negligent and
reckless conduct of Defendant, Alexander
Dempsey, inasmuch as Defendant, U-Haul Co. of
Connecticut, negligently provided Defendant,
Alexander Dempsey, with a truck to tow said
trailer.
(See Paragraph 18 of Plaintiffs' Complaint, which is attached
hereto as Exhibit "A".)
8. Defendant U-Haul Co. of Connecticut objects to
Paragraph 17, in particular the phrase of "generally", Sub-
-2-
Paragraphs (a) and (c) of Paragraph 17, and Paragraph 18 of
Plaintiff's Complaint, for their failure to comply with Pa,R.C.P.
1019 and 1028(a) (3), which require pleading with factual
particularity and specificity.
9. These aforesaid Paragraphs and Sub-Paragraphs are
objectionable and must be stricken pursuant to Connor v.
Alleahenv General Hospital, 501 Pa. Super. 306, 461 A,2d 600
(1983), and its progeny.
WHEREFORE, Defendant, V-Haul Co. of Connecticut, hereby
requests, for the reasons set forth above, that this Honorable
Court strike those aforementioned objectionable Paragraphs and
Sub-Paragraphs, of Plaintiffs' Complaint, with prejudice.
MARSHALL, DENNEHEY, WARNER,
COLEMAN AND GOGGIN
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BY: .
Ly"F. Re telhuber
I, '. II 66887
100 Pine Street - Fourth Floor
Harrisburg, PA 17108
(717) 232-4641
,
Attorneys for Defendant
V-Haul Co. of Connecticut
DATE: July 16, 1997
-3-
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S. On the aforesaid date, Defendant, U-Haul Co. of
Connecticut, was the owner of a 1989 International truck that WAS
involved in the collieion desoribed herein.
6. On the aforesajd data, nBfendan~. Alexander H. Dempsey,
was the owner of the trailer and driver of the truck that were
involved ~n the collision dCGcribed herein.
7. Prior to the COllision herein described, Plaintiffs
sleeted the full t.ort option in their nlOt.:>r vehicle insurance
policy, which was in effect at' the time of the collision set forth
herein.
8, On the aforesaid date, at approximately 5:45 a.ra.,
Plaintiff, Kenneth G. Mattler, was operating his motor vehicle in
a southerly direction on, and in the left hand lane of, State Route
81 in Middleton Township, CUmberland county, Pennsylvania, at, or
about, the 41Sth segment marker of State Route 81, when his vehicle
struck Defendant, Alexander H. Dempsey's, trailer, which was
unattended, unlit, and detached. from the U-Haul truck that
Oefendane, Alexander H. ~psey, was driving at the time of the
collision and that Defendant, U-Haul Co. of Connecticut, owned and
was leaSing to said driver at the time of said collision.
2
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lBOLXQ2N'CS
Plaintiff. Kennnth G. Mettler v. Defandane. Alexander D@~Bev
13. The allegations contained 1n paragraphs 1-12 are
incorporated herein by reference as though S6t forth at length.
14. The col11810n was directly and proKimately ~aueed by the
negligence and carelessness of Defendant, Alexander H. Dempsey,
which consisted, among other thingg, of the following:
(al towing a trailer 1n a careless. reckless, and
negligent .manner;
(b) failing 1:0 properly attach trailel' to truck.;
(c) failing to inspect said trailer for defects (75 pa.
Cons. 'Stat. S -\5251;
(d) failing to properly use 8t.atutorUy requirod rellr
lighting system and reflectors while towing a trailer
(75 p_, cona. Stat_ S -\303)1
4
(8) towing a trailer without the statutorily r~quired
rear ),j,ght.1ng system and reflectors. (75 P". COll!l.
Stat. 14303);
(f) fa~~ing to use statutorily roquired safety chains
. while pulling a trailer: (75 Pa. Cons Stnt. i 1905);
(9) towing a trailer without the statutorily requi red
safety chains. (75 Pa. Cone. Sta:. S 4905);
(h) failing to .remove unattended vehicle frC'l!!! rQ,~1wi\V,
(75 Pa. Cons. Stat,S 3709);
(i) unlawfully depositing a dangerous macerial on a
highway. (75 Pa. Cons. Selle, !i 3709).
15. A$ a direct and proximate result of the collision and
Defendant's negligent and reckless conduct Plaintiff. Kenneth G,
Mettler. sustained severe injuries to muscles. blood vassels,
tendons, connllct1ve tissues, bones, and organs of his body,
inclUding. but not limited to, a craumatic dislocation and fracture
of his right patella and 1njuricD to his neck. back. and hoad.
WKEREP'ORB,. Pla1nC:iff demands damages from Detendant an amount
in excess of $25,000, exclusive of interest and c06tS.
5
. COUN'I.' IX
NKGL to"...... ElITRO'll'J'lllm'1l
Plaintiff. Jtennet:h G. Mott]@r v. DAtendane. U-Hn\ll Co. of ~onn.
1S. The allegations eoneained in PB~agraphB I-1S are
incorpOrated herein by reference ao though oot forth at length,
17. The occurrence of the aforesaid co1l1sion and the
resultant injuries to Plaintiff were caused directly and
proximately by the negligent entrustment of Defendant generally,
and, more 9pec1t~eally as set forth below:
Ca1 allo~lng Defendane. Alexander DemFsclY. to use its truclc:
in & careles~, reckless, ~ ~gligent manner;
(b) allowing Defendant, Alexander Dempsey, to improperly
attach said t~ailer to itu truok,
(el allawiug Defendant. Alexander Dempsey, to leaeB its
truck to tow a trailer in a careless; reckless, and
negligent manner;
Cd) failing to inspect said trailer for defect.lI. b<!!fnr..
allowing Defendant, Alexander ~.1lIp8ey, \:0 lease its
truck for the purpOSe of towing ,aid trailer;
6
YQ.:rFI~T:rON
'1'BE llNDE!l8Xam:D herllby varify that the stst:ement:8 ~n t:he
foregoing are baaed on information that was gathered by counsel in
preparation of this lawsuie.
The language o~ thlt foregoing
document io of counoel and not ourB.
We have read the said
document and, to the extene th~t it is based Cn information that we
gave to counI;el, it 16 true and correct to the beBt of our
knowledge. information and belief. To tho extent that the cont~nt6
of the said document is that of counsel. we have reliOd upon our
counsol in preparing chis Verification,
TB:B mmnslGNKD also understand cllcl.t the lltllCemclll:U t:hp.rej n
are made subject to che penalt:l.eo of 18 Pa.R.C,p, '-252cdl e.S.
Sect1.on 4904.
relating to unsworn falBifiCatlon~~uthoritiQs.
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KENNETH G. METTLER and
SHERYL METTLER, his wife,
Plaintiffs
tN TilE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-3303
v.
CIVIL ACTION - I.AW
U-HAUL CO. OF CONNECTICUT
and ALEXANDER H. DEMPSEY,
Defendants
JURY TRIAL DEMANDED
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of Defendants, U-Haul
Co. of Connecticut and Alexander H. Dempsey, in the above-
referenced case.
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOGGIN
DATE: j,,1l114 I IClCri
Floor
17108
ATTORNEYS FOR DEFENDANTS
David H. Rosenberg, Esquire
HANDLER & WIENER
319 Market Street
Harrisburg, PA 17108
,
CERTIFICATE OF SERVICE
I, Susan M. Williams, an employee of the law firm of
Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify
that on this 14th day of July, 1997 served a copy of the
foregoing document via First Class United States mail, postage
prepaid as follows:
~ f'v!, tJilAAMJMJ
SUSAN M, WILLIAMS
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KENNETH G. METTLER and
SHERYL METTLER, his wife,
Plaintiffs,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO. 97-3303 CIVIL
CIVIL ACTION - LAW
U-HAUL CO. OF
CONNECTICUT and
ALEXANDER H. DEMPSEY,
Defendants
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 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.
Cumberland County Court Administrator
Fourth Floor
Cumberland County Courthouse
Carlisle, PA 17013
Telephone (717) 240-6200
HANDLER AND WIENER
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BYdL .
David H
1.0. # 69
31 9 Market Street
P.O. Box 1177
Harrisburg, PA 17108
(717) 238-2000
DATE: "/IY 1'17
Attorney for Plaintiffs
5. ~n the aforesaid date, Defendant, U-Haul Co, of
Connecticut, was the owner of a 1989 International truck that was
involved in the collision described herein.
6. On the aforesaid date, Defendant, Alexander H. Dempsey,
was the owner of the trailer and driver of the truck that were
involved in the collision described herein.
7. Prior to the collision herein described, Plaintiffs
elected the full tort option in their motor vehicle insurance
policy, which was in effect at the time of the collision set forth
herein.
8. On the aforesaid date, at approximately 5: 45 a. m. ,
Plaintiff, Kenneth G. Mettler, was operating his motor vehicle in
a southerly direction on, and in the left hand lane of, State Route
81 in Middleton Township, Cumberland County, Pennsylvania, at, or
about, the 475th segment marker of State Route 81, when his vehicle
struck Defendant, Alexander H. Dempsey's, trailer, which was
unattended, unlit, and detached from the U-Haul truck that
Defendant, Alexander H. Dempsey, was driving at the time of the
collision and that Defendant, U-Haul Co. of Connecticut, owned and
was leasing to said driver at the time of said collision.
2
9, At the time of the collision herein described, Plaintiff,
Kenneth G, Mettler, was traveling at a speed that was in compliance
with the posted speed limit and, prior to impact, had safely
changed from the right lane to the left lane of State Route 81
before colliding with said trailer,
10. As a direct and proximate result of the collision and
Defendants' negligent and reckless conduct, Plaintiff, Kenneth G,
Mettler, has suffered, and will suffer in the future, pain, agony,
irritation, and inconvenience.
11. As a direct and proximate result of the collision and
Defendants' negligent and reckless conduct, Plaintiff, Kenneth G.
Mettler, has been prevented from dttending to his usual duties as
senior buyer for United Defense, L. P., to his great detriment,
damage and loss.
12. As a direct and proximate result of the collision and
Defendants' negligent and reckless conduct, Plaintiff, Kenneth G.
Mettler 1 has incurred great expenses for medical treatment and
physical therapy, which expenses may continue into the future.
COUNT I
NEGLIGENCE
Plaintiff. Kenneth G. Mettler v. Defendant. Alexander Dempsev
3
13, The allegations contained in paragraphs 1-12 are
incorporated herein by reference as though set forth at length.
14, The collision was directly and proximately caused by the
negligence and carelessness of Defendant, Alexander H. Dempsey,
which consisted, among other things, of the following:
(a) failing to properly attach trailer to truck;
(b) failing to inspect said trailer for defects (75 Pa.
Cons. Stat. ~ 4525);
(c) failing to properly use statutorily required rear
lighting system and reflectors while towing a trailer
(75 Pa. Cons. Stat. ~ 4303);
(d) towing a trailer without the statutorily required
rear lighting system and reflectors. (75 Pa. Cons.
Stat. ~ 4303);
(e) failing to use statutorily required safety chains
while pulling a trailer. (75 Pa. Cons Stat. ~ 4905);
(f) towing a trailer without the statutorily required
safety chains. (75 Pa. Cons. Stat. ~ 4905);
4
lB. Defendant is liable for Plaintiff's injuries resulting
from the negligent and reckless pulling of a trailer lacking a rear
lighting system, reflectors, and adequate safety chains by
Defendant, Alexander Dempsey, inasmuch as Defendant, U-Haul Co. of
Connecticut, negligently entrusted to Defendant, Alexander Dempsey,
a truck to tow said trailer.
19, As a direct and proximate result of the negligence of
Defendant, Plaintiff sustained severe injuries to muscles, blood
vessels, tendons, connective tissues, bones, and organs of his
body, including, but not limited to, a traumatic dislocation and
fracture of his right patella and severe injuries to his neck,
back, and head.
WHEREFORE, Plaintiff demands from Defendant an amount in
excess of $25,000, exclusive of interest and costs.
COUNT III
LOSS OF CONSORTIUM
Plaintiff. Sheryl Mettler v, Defendant. Alexander Dempsev
20. The allegations contained in paragraphs 1-19 are
incorporated herein by reference as though set forth at length.
7
consortium of her husband, Plaintiff, Kenneth G. Mettler, to her
great detriment and loss.
26. As a result of Defendant's negligence, Plaintiff has
incurred large medical bills and expenses to treat her husband's
injuries.
27. As a result of Defendant's negligence, Plaintiff has
suffered a disruption in her daily habits and pursuits and a loss
of enjoyment of life.
WHEREFORE, Plaintiff demands damages from Defendant in an
amount in excess of $25,000, exclusive of interest and costs.
Respectfully Submitted,
HANDLER & WIENER
Date: 1/ll{97
By:
Davi Esq.
1.0. No.2
319 Marke
Harrisbu , PA 17108-1177
Telepho, e No. 717-238-2000
Attorney for Plaintiffs
9
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HANDLER AND WIEt-:ER
ATTORNEYS.AT-LAW
P.O. BOX 1177, 318 MARKET STREET
HARRIBBURG. PENNSYLVANIA 17108
TELEPHONE: (717) 238.2000
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KENNETH G. METTLER and
SHERYL METTLER,
his wife,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PE~~SYLVANIA
Plaintiffs
v.
NO. 97-3303
U-HAUL CO. OF
CONNECTICUT and
ALEXANDER DEMPSEY,
Defendants
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
AFFIDAVIT OF SERVICE
****
STATE OF TENNESSEE :
}
COUNTY OF :I:>9/J/ .tJS(J/V
AND NOW, this3l~ayofJULY ,1997, I
hereby certify that I served the Amended Complaint in the above-
captioned matter on Alexander D~!llPsey, !:lY perso~~ly handing a
clocked-in copy of the same to t!:1t("'ELLC VL;4~:SCV and makj.J1g
k99wn to hi~ the conte?ts the~~of ~t the address of ~~:3 ?~~C~
/corlD -.4(pJtJk' //H_~I 'Tv. ..",SV73 ~ /11/;=0 /J1/C'deL~c ~y.
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OR
AND NOW, this _ day of , 1997, I
hereby certify that I attempted to serve Alexander Dempsey at the
address {es} of
but was unable to effect service.
.
LEGAL EAGLES ATTO EY SERVICE
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BY: ,,-:;;-?{ /' ~~~
Edward Leje ne,
Process Server
3656 Mayflower Place
Nashville. TN 37204-3835
Sworn to before me 'f h.
and subscribed this 't day
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of /1"; " r t. 1997.
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CERTIFICATE OF SERVICE
AND NOW, this 21'1 day of Oetober, 1997, I hereby eertify that I have
served the foregoing Answer with New Matter on the fOllowing by depositing a true and
eorreet eopy of same in the United States mails, postage prepaid, addressed to:
David H. Rosenberg, Esquire
HANDLER & WIENER
319 Market Street
Harrisburg, PA 17108
Lynn F. Reutelhuber, Esquire
P.O. Box 803
Harrisburg, PA 17108-0803
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