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4,
The plaintiff North and South Lines, Inc" was the owner of the tractor and trailer
operated by plaintiff Lay at the time and place above alleged,
5,
On or about May 9,1996, at or about 12:18 a.m., defendant Max Transport, Inc.,
by and through Its agent, servant, and employee, Klem Prum Tran was operating a
tractor-trailer, bearing a California registration number of SP48174 and was operating
said tractor-trailer in a northbound direction on SR 81, (Interstate 81) in the South
Newtown Township, Cumberland County, Pennsylvania,
6,
At the time and place above alleged, plaintiff Phillip E, Loy and defendant Klem
Prum Tan were involved in a collision, which resulted In personal injury to plaintiff Loy,
and property damage to plaintiff North and South Lines, Inc" which collision occurred in
the following manner:
a. Both units were traveling northbound in the right lane of SR 81
(Interstate 81) in heavy rain.
b, The North and South Lines, Inc, tractor-trailer operated by
plaintiff Loy was traveling at below the speed limit, at
approximately 60 to 63 miles per hour,
c, The Max Transport tractor-trailer had either stopped upon the
highway or was traveling at approximately 0 to 5 miles per hour,
if it was even moving at all, and it had no rear lights visible on the
trailer.
d. Both vehicles were in the right-hand lane; and
e, The plaintiff North and South's tractor-trailer, operated by plaintiff
Phillip E. Loy, collided with the rear of defendant's tractor-trailer,
7,
The accident above alleged resulted solely from the negligence and recklessness
of the defendant Klem Prum Tran and was due in no manner whatsoever to any act or
failure to act on the part of the plaintiff Loy or plaintiff North and South Lines, Inc,
".
8,
The accident above alleged and all of the herein mentioned Injuries and damages
sustained by both plaintiffs are the direct and proximate result of the careless, reckless,
and negligent manner in which defendant Klem Prum Tran operated the tractor-trailer of
defendant Max Transport, Inc" which carelessness, recklessness and negligence Is
more fully set forth as follows:
a. In failing to keep alert and maintain a proper lookout for the
presence of other motor vehicles lawfully on the highway being
traveled by plaintiff Phillip E. Loy;
b, In stopping upon the traveled portion of the highway, or in driving
at a greatly reduced rate of speed upon the highway;
c, In failing to keep proper and adequate control of the motor vehicle
that the defendant was driving;
d, In operating a tractor-trailer upon the highway with no lights on the
rear of the tractor in violation of 75 Pa, C, S. Section 4303(B);
e. In failing to activate his vehicular hazard signal lamps as required
by 75 Pa. C,S, Section 4305 (b)(1) when his speed was below
25 miles per hour;
f. In failing to activate his vehicular hazard signal lamps while operating
below the minimum speed on an Interstate Highway as required by
75 Pa, C.S, Section 4305(c);
g. In operating his tractor-trailer at a speed that was such a slow speed
as to Impede the normal and reasonable flow of traffic in violation of
75 Pa. C,S, Section 3364 (a);
h, In failing to move his tractor-trailer off the roadway and onto the berm
or shoulder of the highways as required by 75 Pa, C.S, Section 3364(b);
i. In stopping his tractor-trailer upon the highway when it was practical
to park or stop the tractor-trailer off the highway, in violation of 75 Pa.
C.S, Section 3351 (a).
9,
At all times alleged herein, defendant Klem Prum Tran was the employee, agent,
and servant of defendant Max Transport, Inc" was acting within the scope and course of
his employment, and was subject to defendant Max Transport Inc.'s direction and
control.
COUNT I
Phillip E. Loy,
Plaintiff
vs.
Max Transport, Inc"
Defendant
Negligence
10.
Paragraphs 1 through 9 are Incorporated herein by reference,
11.
The plaintiff in this Count is Phillip E. Loy.
12.
As a direct result of the negligence of the defendant as above alleged, plaintiff
Phillip E, Loy has suffered injuries which are serious, and may be permanent and
disabling, which injuries are as follows:
a, A partial traumatic laceration of his quadriceps tendon in his
right knee and a significant medial col/ateralllgament joint
sprain; and
b. Lacerations throughout his face;
c. Injuries to his mouth and teeth.
b, H,M,H,T,T,C, Response Team Incorporated Invoice
number R-1249 dated May 2, 1996 In the amount of
$1,452,20,
21,
As a direct result of the negligence of the defendant as above alleged, it was
necessary for plaintiff to have the tractor-trailer towed from the scene of the collision,
and the following expense was thus Incurred:
a, D & R Lehman, Chambersburg, Pennsylvania,
order number 4119, dated May 9, 1996, In the amount
of $310,00 for going to the scene and towing the
damaged tractor-trailer.
WHEREFORE, plaintiff North and South Lines, Inc, demands damages against
the defendant In the amount of $66,749,17, together with interest and delay damages as
prescribed by Pa, R.C.P. 238 and costs of suit as allowed by law,
And the plaintiffs will ever pray, etc,
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David C. Cleaver
Attorney for Plaintiffs
OF COUNSEL:
David C, Cleaver & Associates, P,C,
1035 Wayne Avenue
Chambersburg, PA 17201
717-264-1110
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We verify that the statements made In this Complaint are true and correct, We
understand that false statements herein are made subject to the penalties of perjury
contained in 18 Pa, C,S, Section 4904, relating to unSWOrn falsification to authorities,
Date: JLl.;;3\Qr-.:r
North and South Lines, Inc.
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COi'!;':nNWEAL.rH OF rE~!NS:"{L'li\:jl A:
COU1~'rY Ol~ CU~IOER1~^r~D
ti9RTfLAtJI~-':301-.1TfI LI liES ltIC_.J;J~
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MAX TRANSrORT IlIe ET AL
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CUNBERL/\ND COUn~}'. Pt,:rJnsi'1....3ni;~j, ',;h.:; b'.:.~ln0 dull' :J..'uI:n '-1CC01dill9 to 10.....,
served thf? within n;Jn1(ld [lEFE!lrjAI'n~ TRt\r, J\IE~! Ff,Utl
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by Uni tl~'d Sl;::it..;"s CertiiiC?d tf.:il.l p(l~5t.:JiJj:> prc:p-:3id, un UJ~_'
6th
d:a)' of
February
199.'3
,1t 110D:00 llOUES, :Jt c/o tlAi: THtdt:S.f'Dh'T
1300 1I0RTH JUANITA
SAN JACINTO, eA 92383
a true and ."Jtti:....St.20 1~";')P>' IJ.l lhr:;-. att::)cl1(~>d .-C.QL1PLAII~T
tog€.,ther \o'it.h 1I0TICE
The returned r,?c'Jipl card ""J;O "iSlfj"',J by 1,.. \;)llTJil':EF
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ON FED. ::J, 1998 OUI~ OFFICi:: EECEIVE.D TilE UliC'PEf-i[r,o LET7EE THJ\T HAS
ADDRESSED TO I\IEI'I PF:UI'j TfiAIl ,:'/,j l'iil:: THJ,i;:,PUF:T IHTlI IIOTJ\TICiH I'lfd~I\E['
"fiG LONGER HEf\E."
Sh~rifl'3 Costs:
DOC'l:E.Clting
Ci?rtified 1'la:1.1
J\iiicf;'3vit
Surch.:J rg'.?
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: 9R-711 r~"~l Term
'Compl". ht"" 1 and'CM' tlor 8dlJU&l.I UMltt.'
lComplet,lllml3, .".nd .b,
'Print Vout name Ind add,... on thl "W/'I' o'lhll ronn 10 ChIt WI can rtfum Ihlt
card 10 you,
'Anach thIt ronn 10 IhI front of IhlInllIJHct. Of on thl blc:k IItplc. doH not
'~RIlUmR~ R~'<<I"on thl mI.~ biaow thlartldt nurntMr.
'The Rllum Receipt Wlllhow to whom Ihlll1~W. dtnv.r.d and thl dill
dIItvtrld.
3. elo re..ed 10:
Max Transport, Inc,
1300 North Juanita
San Jacinto, CA 92383
5, RecolVod By: (Ptfnt Name)
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, 01110 wish to reco'vo 1110
following sorvfcos (for on
oxtra fool:
" Cl Addressoo's Addro..
2, Cl Roslrlct.d Dollvory
Consull posllnosl.r for foo,
40, AlUcl. Number
Z 013 269 917
4b, S.rvfc. Typo ri
Cl Roglst.red c.lUn&d
Cl Expr... Moll Insured
Cl Rslum Rocolpl 'or MerchandllO Cl COD
7,0 ~i'~ry-
8. Addro....'s Addr.ss (Only /I requ..tod
and '.01. psJd)
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'02595..',."l7. Domestic Retum ace pt
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.......,....11. ami r _nMOf lor addilIMi1 iiMcel,
lCompl.ltt,me 3. .at and .b.
'Pltnt )"DUI'f\lm1 and .deI,... on lhI "".,.. of lhit fomllO that WI can r.hmtNt
card 10 you,
'AnKh thIalorm to IIw front of the InIIlpIeoI, Of on the bide H 'P'ce daM not
pormlt
aWrfl,"R.wm R~pt R<<llJelt<</"on the maJf~ below the Irtldll'llJrOOtr.
'The Rltum Receipt WlIIhow to vmom the artld. Wit dtUvem and thl datI
doI/vorod,
3, A71Ielo Addr.ssod to:
Kiem Prum Tran
232 Gen Stillwell N.E.
Albuquerque, NM 87112
!l 8, Slgnatur.: (A
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, , PS Form 3811, Dec.mbor 1994
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I oIso wish to rocolv. 111.
following servfces (lor on
.xtra leo):
1, Cl Addr.sse.'s Addre..
2. Cl Roslrlctod Dsllvory
Consult poslmaot.r 10, 190,
48, AlUel. NUmb.r
Z 013 270 OOl
4b, S.rvfc. Typ.
Cl Roglsl.red CelUftod
Cl Expr... Moll Cl Insured
Cl Rslum Rocolplfor Merchandise Cl COD
7. 0 ot .lIvsry
'025.S-.',."". Domestic Retum Recept
: 98..711 Civil TErm
eComplICIIllml1 ancUot 2101 addItionaIHMeel,
lComJl'etllllme 3. 4a. and 4b.
.Ptlnl your nune and add,... on Ihe revert. olthlt Iomiso thai we can retum thl,
card 10 )'Cu. i -.. I
'Attach IhlI form to lhIi front oIlhI mallp1ece, or on hblick llaplC8 doe, not
_. (\1,
eWrtl,.RItum RlOeIpt RfHllJBlt<<1" on the mallplI9I below the anlcl. number,
'The Rllum Receipt w1llhow 10 whom the llltld' ~'a. delivered and the dale
delivered.
3, A71Ielo Addross.d to:
Kiem Prum Tran
C/O Nax Transport. Inc.
1300 North Juanita
San Jacinto, CA 92383
, 5, RecsIVod By: (Ptfnt Nam.)
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I also wish 10 r.c.lve 111.
lollowlng s.rvfcos (lor on
oxtra fO.):
1. Cl Addr.ssa.'s Addrs..
2, Cl Rostrlct.d Dollvory
Consult poslmaSI.' 10' f..,
40. AlUel. Numb.,
Z 013 270 002
4b. S.MC. Typ. _ ./'"
Cl R.glsl.rod j.J'COrtlft.d
Cl Expr.ss Mall Cl Insurod
Cl Relum Rocolplfor MerchandilO Cl COD
7. Dol D.llv.ry
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8. Addro..eo'o Addr... (Only /I requested
and I.. Is psJd)
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10259S.97.8.Q179
Domestic Return Receipt
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
North and South Lines, Inc., and
Phillip E, Loy,
: Civil Action - Law
Plaintiffs
No. A. D, 19~ - 7f I (}_v~~
vs.
Max Transport, Inc"
Kiem Prum Tran,
Jury Trial Demanded
Defendants
Legal Action
NOTICE TO DEFEND AND CLAIM RIGHTS
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 an 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 BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE PA 17013
(717) 249 3166
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
North and South Lines, Inc" and
Phillip E. Loy,
Civil Action - Law
Plaintiffs
No, A. D, 1997.
vs.
Max Transport, Inc"
Kiem Prum Tran,
Jury Trial Demanded
Legal Action
Defendants
COMPLAINT
NOW come the Plaintiffs, North and South Lines, Inc, and Phillip E. Loy, by their
attorney, David C. Cleaver, and for cause of action against the Defendant says:
1.
The Plaintiffs are Phillip E, Loy, a sui juris adult, who lives and resides at 487
North Water Street, Woodstock, Virginia, 22664, and North and South Lines, Inc" a
Virginia corporation with offices located in Harrisonburg, Virginia and post office address
of P.O, Box 49, Harrisonburg, Virginia, 22801.
2,
Defendant Max Transport, Inc" is a California corporation with offices located at
1300 North Juanita, San Jacinto, California, 92383 which defendant conducts business
in Pennsylvania, Defendant Kiem Prum Tran is a sui juris adult who is employed by
defendant Max Transport, Inc. and lives and resides at 232 Gen Stillwell, N.E"
Albuquerque, New Mexico,
3.
On or about May 9, 1996, at or about 12:18 a.m" plaintiff Loy driving a tractor-
trailer upon SR 81 (Interstate 81) in a northbound direction in South Newtown
Township, Cumberland County, Pennsylvania.
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9,
At all times alleged herein, defendant Kiem Prum Tran was the employee, agent,
and servant of defendant Max Transport, Inc" was acting within the scope and course of
his employment, and was subject to defendant Max Transport Inc.'s direction and
control.
COUNT I
Phillip E. Loy,
Plaintiff
vs,
Max Transport, Inc"
Defendant
Negligence
10,
Paragraphs 1 through 9 are incorporated herein by reference.
11,
The plaintiff in this Count is Phillip E, Loy,
12,
As a direct result of the negligence of the defendant as above alleged, plaintiff
Phillip E. Loy has suffered injuries which are serious, and may be permanent and
disabling, which injuries are as follows:
A partial traumatic laceration of his quadriceps tendon In his
right knee and a significant medial collateral ligament joint
sprain; and
b, Lacerations throughout his face:
a,
c,
Injuries to his mouth and teeth.
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13,
As a direct result of the negligence of the defendant as above alleged, plaintiff
Loy has incurred various medical and hospital expenses for treatment of the plaintiff by
physicians and hospitals,
14.
As a direct result of the negligence of the defendant as above alleged, plaintiff
Loy has incurred and undergone, and in the future will incur and undergo, great mental
and physical pain and suffering, great inconvenience in carrying out his daily activities,
loss of life's pleasures and enjoyment, and will continue to incur such losses for an
indefinite time in the future,
15,
As a direct result of the negligence of the defendant as above alleged, plaintiff
Loy has suffered a severe loss of earnings and earning capacity and power, which loss
Is permanent and severe.
16.
The injuries to the plaintiff Loy have resulted in permanent damage to the nerves
of his right lower extremity, which damage is permanent, irreparable, and severe, which
Injuries have resulted in a permanent, partial disability,
WHEREFORE, plaintiff Phillip E. Loy demands damages in an amount in excess
of $25,000.00 together with interest, delay damages as prescribed by Pa, R.C,P. 238,
and costs of suit as allowed by law.
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COUNT /I
North and South Lines, Inc"
Plaintiff
vs,
Max Transport, Inc"
Kiem Prum Tran,
Negligence
Defendants
17.
Paragraphs 1 through 9 are incorporated herein by reference,
18.
The plaintiff In this Count is North and South Lines, Inc.
19.
As a direct result of the negligence of the defendant as above alleged, plaintiff
North and South Lines, Inc, has suffered the total destruction of their tractor.trailer and
its cargo and thus sustained damages which are itemized as follows:
a. Total loss of the tractor which was involved in the above
mentioned accident in the amount of $58,000.00;
b. Cargo that was in the trailer and destroyed in the above
mentioned accident in the amount of $1,124.11,
20.
As a direct result of the negligence of the defendant as above alleged, it was
necessary for plaintiff to incur expenses for the removal of hazardous material from the
accident scene, which expenses are as follows:
a, H,M.H.T,T.C, Response Team Incorporated invoice
number R.1228, dated May 13, 1996 in the amount of
$5,862,86:
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b. H,M,H.T,T.C, Response Team Incorporated invoice
number R-1249 dated May 2, 1996 in the amount of
$1,452.20.
21,
As a direct result of the negligence of the defendant as above alleged, It was
necessary for plaintiff to have the tractor-trailer towed from the scene of Ihe collision,
and the following expense was thus incurred:
a. D & R Lehman, Chambersburg, Pennsylvania,
order number 4119, dated May 9, 1996, in the amount
of $310,00 for going to the scene and towing the
damaged tractor-trailer.
WHEREFORE, plaintiff North and South Lines, Inc. demands damages against
the defendant in the amount of $66,749.17, together with interest and delay damages as
prescribed by Pa. R.C,P. 238 and costs of suit as allowed by law.
And the plaintiffs will ever pray, etc,
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-'-David C. Cleaver
Attorney for Plaintiffs
OF COUNSEL:
David C. Cleaver & Associates, P.C.
1035 Wayne Avenue
Chambersburg, PA 17201
717-264-1110
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We verify that the statements made in this Complaint are true and correct. We
understand that false statements herein are made subject to the penalties of perjury
contained in 18 Pa, C,S, Section 4904, relating to unsworn falsification to authorities,
Date: II \~.3\g-:r
North and South Lines, Inc,
By
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TO: AU.PANT/h'S
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STOLARSKI, GILLESPIE & O'NEILL
BY: EDWARD J, STOLARSKI, ESQUIRE
IDENTIFICATION NO,: 40535
2005 MARKET STREET - SUITE 2030
PHILADELPHIA, PA 19103
(215) 564-7630
NORTH AND SOUTH LINES, INC.
and PHILLIP E. LOY
Plaintiffs
ATTORNEY FOR DEFENDANT:
~I/\:\ 'l'IlANSI'OHT, INC. ANIl
I\JgM Pltur.i THAN
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
v.
JURY TRIAL DEMANDED
MAX TRANSPORT, INC, and
KIEM PRUM TRAN
Defendants
NO, AD. 1998-711 Civil
ANSWER OF DEFENDANTS MAX
TRANSPORT, INC, AND KIEM PRUM TRAN WITH NEW MATTER
The defendants, Max Transport, Inc. and Kiem Prum Tran, by their attorney,
Edward J. Stolarski, hereby answer the Complaint of the plaintiffs as follows:
1. Denied, Mter a reasonable investigation, answering defendant is without
knowledge or information sufficient to form a belief as to the truth or falsity of the
averments contained in this paragraph and, therefore, answering defendant denies
the allegations contained therein.
2, D!!ni!!d, 'I'he IIllegnt.ions contllin!!d in this Ilnl'lIgl'llllh Ill'!! conclusions of lnw
to which no 1'!!sllOnsive Illcnding is I'equired IIUI'SUllnt to the I'cnnsylvllnia Rules of
Civil Procedlll'e nnd nre, therefore, d(mied,
3. Denied, After a rensonable investigntion, answering defendant is without
knowledge 01' information sufficient to form a belief as to the truth 01' falsity of the
averments contained in this paragraph and, therefore, answering defendant denies
the allegations contained therein,
4, Denied, After a reasonable investigation, answering defendant is without
knowledge 01' information sufficient to form a belief as to the truth or falsity of the
averments contained in this paragraph and, therefore, answering defendant denies
the allegations contained therein.
5. Denied. The allegations contained in this paragraph are conclusions of law
to which no responsive pleading is required pursuant to the Pennsylvania Rules of
Civil Procedure and are, therefore, denied,
G. Denied. After a reasonable investigation, answering defendant is without
knowledge or information sufficient to form a belief as to the truth of the averments
contained in this paragraph and. therefore, answering defendant denies the
allegations. Moreover, the allegations contained in this paragraph are conclusions
11. Denied, The allegations containec! in this pal'l1grllph me l:onclusions of law
to which no responsive plellding is l'eqllirec!llIll'slIlInt to the Pennsylvllnill Rules of
Civil Procedul'C and arc, therefore, denied,
12, Denied, After a reasonable investigation, answering defendant is without
knowledge or information sufficient to form a belief as to the truth of the averments
contained in this paragraph and, therefore, answering defendant denies the
allegations. Moreover, the allegations contained in this paragraph are conclusions
of law to which the Pennsylvania Rules of Civil Procedure require no responsive
pleading and are, therefore, denied.
13, Denied. After a reasonable investigation, answering defendant is without
knowledge or information sufficient to form a belief as to the truth of the averments
contained in this paragraph and, therefore, answering defendant denies the
allegations, Moreover, the allegations contained in this paragraph are conclusions
of law to which the Pennsylvania Rules of Civil Procedure require no responsive
pleading and are, therefore, denied.
14. Denied, After a reasonable investigation, answering defendant is without
knowledge or information sufficient to form a belief as to the truth of the averments
contained in this paragraph and, therefore, answering defendant denies the
allegations. Moreover, the allegations containcci in this paragraph are conclusions
of Il\w to which the Pennsylvl\nil\ /lules of Civil /'I'ocl!llurc rCCluil'c no responsive
pleading l\nd lire, therefol'e, lIeni!!d,
15, Denied, After a reasonabl!! investiglltion, answ!!l'ing defendant is without
knowledge 01' inforlllation sufficient to forlll a belief as to th!! truth of the aVerlllents
contained in this paragraph and, therefore, answering defendant denies the
allegations. Moreover, the al/egations contained in this paragraph are conclusions
of law to which the Pennsylvania Rules of Civil Procedure require no responsive
pleading and are, therefore, denied,
16. Denied, After a reasonable investigation, answering defendant is without
knOWledge 01' information sufficient to forlll a belief as to the truth of the averlllents
contained in this paragraph and, therefore, answering defendant denies the
allegations, Moreover, the allegations contained in this paragraph are conclusions
of law to which the Pennsylvania Rules of Civil Procedure require no responsive
pleading and are, therefore, denied,
COUNT II
NOR'l'H AND SOU'1'1l LINES, INC.
v. MAX 'l'RANSPORT, INC, AND KIEM PRUM 'I'HAN
NEGLIGENCE
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17, The defendants incorporate by reference their answers to paragl'aphs 1
through 16 of plaintiff's Complaint as though same were set forth fully herein at
length.
18. Denied, The allegations contained in this paragraph are conclusions of law
to which no responsive pleading is required pursuant to the Pennsylvania Rules of
Civil Procedure and are, therefore, denied.
19. Denied, Mter a reasonable investigation, answering defendant is without
knowledge or information sufficient to form a belief as to the truth of the averments
contained in this paragraph and, therefore, answering defendant denies the
allegations, Moreover, the allegations contained in this paragraph are conclusions
of law to which the Pennsylvania Rules of Civil Procedure require no responsive
pleading and are, therefore, denied.
20. Denied. Mter a reasonable investigation, answering defendant is without
knowledge or information sufficient to form a belief as to the truth of the averments
contained in this paragraph and, therefore, answering defendant denies the
allegations, Moreover, Uw allegn!.ions c:ont.nined in t.his pnl'agrllph arc conclusions
of law t.o which t.I11! Pennsylvnnin HuleR of Civil Procedure I'c!quire no responsive
pleading nnd are, t.herefore, denied,
21. Denied, Mt.er a reasonable investigation, answering defendant is without
knowledge 01' information sufficient to form a belief as to the truth of the averments
contained in this paragraph and, therefore, answering defendant denies the
allegations, Moreover, the allegations contained in this paragraph are conclusions
of law to which the Pennsylvania Rules of Civil Procedure require no responsive
pleading and are, therefore, denied.
WHEREFORE, the answering defendants respectfully request that this
Honorable Court grant judgment in their favor and dismiss the Complaint of the
plaintiffs in their entirety.
NEW MATTER
1. Plaintiffs Complaint fails to set forth a cause of action upon which relief can
be granted,
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S'I'OLARSKI, G1LLESpm & O'NI~ILL
BY: EDWARD J, STOLARSKI, ESQUIRE
IDEN'I'WICNI'ION NO,: ,105:15
2001i MARKE'I' S'I'lml~'I' - SUI'I'E 20:10
PHILADELPHIA, PA 1!110:l
(215) 1i64-7630
NORTH AND SOUTH LINES, INC,
and PHILLIP E, LOY
Plaintiffs
A'lv.'OItNEY FOIt DEI"I~NDAN'I':
I\IAX 'l'IlANHI'OIl'l', INC, ANIl
1(11':1\1 I'IlU~1 'I'IlAN
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
JURY TRIAL DEMANDED
v.
MAX TRANSPORT, INC, and
KIEM PRUM TRAN
Defendants
NO, A.D, 1998-711 Civil
~THDRAWALOFAPPEARANCE
Kindly withdraw my Appearance on behalf of defendants, Max Transport,
Inc. and Kiem Prum Tran, in the above captioned matter.
ENTRY OF APPEARANCE
Please enter my Appearance on behalf of defendants, Max Transport, Inc.
and IG.em Prum Tran, in the above captioned matter.
'lJ4 4 ~
,.
THOM~S ~. ~RCHER, ESQUIRE
Date: ']..-/8-1'7
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