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Home My WebLink About98-01081 .. ~ ~ ~, o c3 .~ ~ t <t .~ .. ;:j ~ fI / { \. ,~ . :-.... .~ I '-JI ~I C\I ....... ' I , I Co a- 'I ~ Shrager, McDaid, Loftus, Flum & Spivey ny, DANtnL 3. W1!INSTOCK,llSQUIRE IDEN11I~CA1l0N NUMIII!R 729<40 32Ad fLOOR lWO COMMI!RCE SQUARE 2001 MARKIIT SllUlL'1' PIIIUDEI.PIIIA, PIlNNSYLV ANIA 19103 (21') 568.ml CLAUDIA M. QUIRAMA CUMBERLAND COUNTY 1224 East Derry Street Hershey, PA 17033 } COURT OF COMMON PUAS Plelntlfl CIVIL DIVISION LAW VS. } TERM, ERIC D. COOK No: qp -lOP J 149 Timber Lane } Shlppensburg, PA 17257 and GERALD R. COOK } 1905 Reclwoocl Avenue Wyomlsslng, PA 19610 and } JOAN COOK 1905 Reclwoocl Avenue Wyomlsslng, PA 19610 } and PAUL E. GROCE PO Box 733 } Key Port, NJ On35 Defendants NOT ICE 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 Bar Association, Two Liberty Avenue, Carlisle, PA 17013; (717) 249-3166. , I" t.,: Shrager, McDaid, Loftus, Flum & Spivey BY, DANIEL S. WBINSTOCK.I!SQUIRIl lDBNTIFlCA nON NUMBER 72940 32nd FLOOR lWO COMMERCB SQUARIl 2001 MARKET S11U!1!T PlULADBLPlIIA. PBNNSY\.VANIA 19103 (215) 561.ml CLAUDIA M. aUIRAMA 1224 East Deny Street Hershey, PA 17033 , " CUMBERLAND COUNTY ; V I ; I COURT OF COMMON PLEAS CIVIL DIVISION LAW } } } } } } } , , . Plaintiff VS. TERM. No: qf'-/D?/ CiOlllrA."l ERIC D. COOK 149 Timber Lane Shlppensburg, PA 17257 and GERALD R. COOK 1905 Redwood Avenue Wyomlsslng. PA 19610 and JOAN COOK 1905 Redwood Avenue Wyomlsslng. PA 19610 and PAUL E. GROCE PO Box 733 Key Port. NJ On35 , I , , Defendants COMPLAINT . CIVIl. ACTION Plaintiff, by her attorneys, Shrager, M~Daid, Loftus, Flum & Spivey, hereby demands damages of the defendants herein in a sum in excess of twenty-five thousand ($25,000.00) dollars, exclusive of interest, costs, and damages for pre-judgment delay, upon causes of action of which the following are statements: 11 ,/ Ii " i 1. Plaintiff, Claudia M. Quirama, an adult individual, -2- is a citizen of the Commonwealth of Pennsylvania, residing therein at 1224 East Derry Street, Hershey. 2. Defendant, Eric D. CooK, an adult individual, is a citizen of the commonwealth of Pennsylvania, residing therein at 149 Timber Lane, Shippensburg. 3. Defendant, Gerald R. CooK, an adult individual, is a citizen of the Commonwealth of pennsylvania, residing therein at 1905 Redwood Avenue, wyomissing. 4. Defendant, Joan CooK, an adult individual, is a citizen of the Commonwealth of Pennsylvania, residing therein at 1905 Redwood Avenue, wyomissing. 5. Defendant, Paul E. Groce, an adult individual, is a citizen of New Jersey, residing therein with an address of P.O. Box 733, Key Port. 6. The facts giving rise to this action, as described below, tooK place in the Municipality of Shippensburg borough, County of Cumberland. 7. At all times pertinent hereto, defendants COOK and Groce were operating motor vehicles within the County of Cumberland, Commonwealth of Pennsylvania, and were obliged to operate said motor vehicles in a reasonably safe and prudent manner; said defendants were further obliged to assure proper maintainence, repairs and inspections were perf erred upon the motor vehicles they operated. 8. At all times pertinent hereto, defendants Gerald R. COOK and Joan COOK owned a motor vehicle which was operated -3- .". within the County of Cumberland, Commonwealth of Pennsylvania, by their actual or apparent agent, servant, and/or employee, Eric D. CooK; as such, Gerald R. COOK and Joan COOK were obliged to assure proper maintainence, repairs and inspection were performed upon said motor vehicle and to assure that the motor vehicle was operated only by individuals competent to safely do so. Gerald R. COOK and Joan COOK are further responsible for the conduct of their actual or apparent agents, servants, and/or employees, including Eric D. CooK, pursuant to Pennsylvania Law. 9. On or about March 3, 1996, the plaintiff was an authorized passenger, situated in the bacK seat in a 1995 Jeep wrangler which was being operated by defendant, Paul E. Groce. 10. On the aforementioned date, at approximately 1:47 a.m., the Groce vehicle was travelling north on South Queens Street, approaching the intersection of East King Street. 11. Simultaneously, defendant, Eric D. CooK, was operating a 1987 VOlKswagon owned by defendants Gerald R. COOK and Joan CooK, eastbound on East King Street, approaching the intersection of South Queens Street. \ .1 12. The above intersection was regulated by flashing red and/or flashing yellow traffic signals. 13. Defendant, Paul E. Groce and/or defendant, Eric D. CooK, entered the intersection of South Queens Street and East King Street in violation of the above traffic signal, causing a violent collision resulting in the plaintiff being ejected from the Groce vehicle, causing her to sustain serious and life ., -4- threatening injuries, including intracranial bleeding. 14. As a result of the foregoing collision, the plaintiff was forced to undergo a crainectomy with evacuation of hemotoma, and has sustained serious and permanent injury. 15. The foregoing collision and injuries to the plaintiff were solely the result of the tortious conduct of th~ defendants and were in no way due to any conduce or misconduct on the part of the plaintiff. 16. The tortioug conduct of defendants, Eric D. COOK and/or Paul E. Groce included the following: (a) operating a motor vehicle without proper regard for the safety of persons and property; (b) failing to appreciate, aCKnowledge and react to a flashing red and/or flashing yellow traffic signal and the fact that another vehicle was approaching the intersection; (c) failing to properly maintain a motor vehicle under adequate control; (d) failing to note the point and position of other motor vehicles on the road; (e) operating a motor vehicle in a speed in excess of that which was reasonable and prudent under the circumstances; (f) failing to stop a motor vehicle or taKe other evasive measures in order to avoid the aforementioned collision; (g) failing to warn the plaintiff of an impending collision; (h) operating a motor vehicle under the influence of alcohol; (i) failing to properly inspect a motor vehicle or assure the proper inspection and maintainence thereof; -5- (j) operating a motor vehicle which was Known or should have been Known to be in an improper state of repair; and (K) violating the statutes of the Commonwealth of pennsylvania with reference to the operation of motor vehicles. 17. In addition to being vicariously liable for the conduct of defendant, Eric D. CooK, defendants Gerald R. COOK and Joan COOK were themselves negligent in the following respects: (a) failing to properly maintain in a safe condition and repair their motor vehicle or to provide for the proper maintainence and repair thereof; (b) failing to properly inspect or provide for the inspection of their motor vehicle; (c) tortiously entrusting defendant, Eric D. Cook, to operate a motor vehicle when they knew or should have known of his incompetence to safely do so; and (d) permitting defendant, Eric D. Cook, to operate a motor vehicle which they knew or should have known were not in a proper state of repair. 18. As a result of the foregoing collision, the plaintiff has been obliged to receive and undergo medical and surgical attention and care, and to expend various sums of money for the injuries which she has suffered and she will be obliged to continue to expend such sums and incur such expenses for an indefinite period of time. 19. As a further result of the foregoing collision, the plaintiff has suffered a great loss and depreciation of her earnings and earning capacity and she will continue to suffer such loss for an indefinite period of time. 20. As a further result of the foregoing collision, the -6- plaintiff has been unable to attend to her usual daily activities, occupations, labors and leisure pursuits and she will be unable to attend to same for an indefinite period of time. 21. As a further result of the foregoing collision, the plaintiff has been obliged to endure severe physical pain, mental anguish, emotional distress and cosmetic disfigurement and she will continue to suffer same for an indefinite period of time. 22. As a further result of the foregoing collision, the plaintiff has suffered a severe diminution i.n the ability to enjoy the pleasures of life, and she will continue to suffer such loss for an indefinite period of time. WHEREFORE, plaintiff, by her attorneys, Shrager, McDaid, Loftus, Flum & Spivey, hereby demands damages of the defendants herein, jointly and severally, in a sum in excess of twenty-five thousand ($25,000.00) dollars, exclusive of interest, costs and damages for pre-judgment delay. SHRAGER, cDA D, LOFTUS, FLUM & SPIVEY '..,; Daniel S. Attorneys W instocK for Plaintiff -7- ~ ~ A;0 ~~ ~ . p:~ 0") o . () C9 () I f - tr'- ....... VI ~ ...0 P- ~ ~ ~ ~ ~ --t- , . () U"J () r:~ 0:' 'rr -':':1 ...., -., ~q ". :rJ t I ~ ,. - ; , ',J .n,--=_ , . , .'J .",'] €) ( I:." ~ ~', c::: '.'<'.) ,- f.l ~ j I , . . .'IJ " ~ _.'e:) ;, :3 O'n c =i:J ~, :'J :.) :n ..... '0 --<; .' '" Shrager, McDaid, Loftus, Flum & Spivey BY' DANIEL S. Wl!lNSTOCK. ESQUIRE IDBm1FICAll0N NUMBER 729-40 32nd FLOOR TWO COMMERCE SQUARE 2001 MARKET 511IEIlT PlllLADELPllIA. PENNSYLVANIA 19103 (215) 568.7771 CLAUDIA M. aUIRAMA Plaintiff va. } ERIC D. COOK and } GERALD R. COOK and } JOAN COOK and PAUL E. GROCE Defendants CUMBERLAND COUNTY COURT OF COMMON PLEAS ClV/L OMS/ON LAW No: 98.1081 PRAECIPE TO SUBSTITUTE VERIF1CATION TO THE PROTHONOTARY: Kindly substitute the attached Verification of Claudia. M. Quirama to plaintiff's complaint for that of Daniel S. Weinstock. SHRAGER, McDAID, LOFTUS, FLUM & SP'VEY \, '( Da el S. W instocK. Esquire Attorney for plaintiff to " " , .. VERIFICATION CLAUDIA M. QUIRAMA, being duly sworn according to law, deposes and states that she is the plaintiff in the foregoing action; that the attached Civil Action Complaint is based upon information which she has furnished to her counsel and information which has been gathered by her counsel in the preparation of the lawsuit. The language of the Complaint is that of counsel and not of plaintiff. Plaintiff has read the Complaint and, to the extent that it is based upon information which she has given to her counsel, is true and correct to the best of her knowledge, information and belief. To the extent that the content of the Complaint is that of counsel, she has relied upon counsel in making this Verification. This Statement is made subject to the penalties of 18 Pa, C.S. Section 4904, relating to unsworn falsification to authorities. t},",~~ iiJ)_u-uJ ~AUDIA M. QU Sworn to and SUbSC~ before me this~) day (, 0/ntuCL , 1998. i ~ 'H-cdcl.-- '. NOTARIAL SEAL tIVI>l:A 11'\ ANN SAWYER, Notaly Pubo" . Cllyell'l1..IIeV..... PhIla. County I _~~!rion-EP.!!os A~ 20,2001 '"' Shrager, McDaid, Loftus, Flum & Spivey BY, DANIEL S. WEINSTOCK. ESQUIRE IDBm1FICAll0N NUMBER 729-40 32nd FLOOR TWO COMMERCE SQUARE 2001 MARKET 511IEIlT PlllLADELPllIA, PENNSYLVANIA 19103 (215) 568.7nt CLAUDIA M. aUIRAMA Plaintiff va. } ERIC D. COOK and } GERALD R. COOK and JOAN COOK } and PAUL E. GROCE Defendants CUMBERLAND COUNTY COURT OF COMMON PLEAS ClV/L OMS/ON LAW No: 98-1081 CERTIFICATE OF SERVICE I hereby certify that on this 3rd day of April, 1998, a true and correct copy of the foregoing Praecipe to Substitute Verification was forwarded via United States mail, first class, postage prepaid, upon the following: Eric D. COOK 1905 Redwood Avenue wyomissing, PA 19610 Gerald R. COOK 1905 Redwood Avenue wyomissing, PA 19610 Joan Cook 1905 Redwood Avenue Wyomissing, PA 19610 Paul E. Groce P.O. Box 733 Key Port, NJ 07735 SHRAGER, McDAID, LOFTUS, FLUM & SPIVEY '~~UG~ Dan'el . WeinstocK, Esquire Attorney for Plaintiff ) (') .0 () f~ c:. -n 'boo :c-J ""t, l_~ " -0 ! l1;EJ ttlt to, ~:J ..r:::::] ; I .~.,fTl . .;" ,'~ "6 ~1~':':; "....! ..... "it :;':>-0 -11 ,_'_.~ -'-. -- -- ~~C) r .~ t. ' ~',~-c) - c.jrn .- :..~ .. -, ~" .;; r:- ~ .. -~ C,oJ --<; ~ r r , , Shrager, McDaid, Loftus, Flum & Spivey BY' DANlELS.Wl!lNSTOCK.BSQUnua IDBm1FICAll0N NUMBER 729-40 32nd FLOOR TWO COMMERCE SQUARE 2001 MARKET S1RBBT PHILADELPHIA. P1!NNSYLV ANIA 19103 (215) S6B.7771 ;' ~ J ) CLAUDIA M. aUIRAMA CUMBERLAND COUNTY Plaintiff } COURT OF COMMON PLEAS va, ClV/L OMS/ON LAW ERIC D. COOK and } it GERALD R. COOK and } No: 98-1081 JOAN COOK and PAUL E. GROCE Defendants PRAECIPE TO FILE PROOF OF SERVICE \ , I TO THE PROTHONOTARY: j , Please file with the Court the attached Proof of Service for defendants, Eric D. CooK, Gerald R. COOK and Joan Cook. SHRAGER, McDAID, LOFTUS, FLUM & SPIVEY Attorneys for plaintiff , " Shrager, McDaid, Loftus, Flum & Spivey BY, DANIEL S. WEINSTOCK, ESQUIRE IDBm1FICAll0N NUMBER 72940 32nd FLOOR TWO COMMERCE SQUARE 2001 MARKET 511IEIlT PlllLADELPHIA, PENNSYLVANIA 19103 (215) 568-7771 CLAUDIA M. aUIRAMA Plaintiff va, } ERIC D. COOK and } GERALD R. COOK and JOAN COOK } and PAUL E. GROCE Defendants CUMBERLAND COUNTY COURT OF COMMON PLEAS ClV/L DlV/S/ON LAW No: 98-1081 CERTIF1CA TE OF SERVICE I hereby certify that on this 3rd day of April, 199B, a true and correct copy of the foregoing praecipe to File Proof of Service was forwarded via united States mail, first class, postage prepaid, upon the following: Eric D. Cook 1905 Redwood Avenue wyomissing, PA 19610 Gerald R. COOK 1905 Redwood Avenue wyomissing, PA 19610 Joan Cook 1905 Redwood Avenue Wyomissing, PA 19610 Paul E. Groce P.O. Box 733 Key Port, NJ 07735 SHRAGER, McDAID, LOFTUS, FLUM & SPIVEY '~PIL~ ~ I ^/( ~ Daniel S. 4instock, Esquire Attorney for Plaintiff SHERIFF OF BERKS COUNTY 633 Court Street Reading, Pennsylvania 19601 BARRY J, JOZWIAK SHERIFF PHONE (810) 478.8240 FAX (810) 478.8222 ANDREW G. HUGHES CHIEF DEPUTY SHERIFF'S RETURN DOCKET NO. 981081 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BERKS :55: Personally appeared before me, PATRICIA A. DONATO, Deputy for Barry J. Jozwiak, Sheriff of Berks County, Pennsylvania, who being duly sworn according to law, deposes and says that on MARCH 18, 1998 at 5:43 p.M.,he served the annexed COMPLAINT IN CIVIL ACTION upon GERALD R. COOK, within named defendant, by handing to him Personally, a copy thereof at 1905 REDWOOD AVENUE, WYOMISSING, Berks County, Pa, and made known to def dant the contents thereof. BERKS CO., PA ,. ../ I , , ( I ~ PA Service made as set forth above. III f""\. S6fo\all Pu~\'" Btl\"~'^' ~COIl~\"j,Pt. I\ellli~' tr-QIlt' ,.ft.~1)I)l\ !ll/ClJIIIIf'''lOlI So Answers. ..b",j oo..,tt ../ $ $ $- .00 .00 .00 - Sheriff's Costs in Above Proceedings DEPOSIT ACTUAL COST OF CASE REFUND ATTACHED All Sheriff's Costs shall be due and payable when services are performed, and it shall be lawful for him to demand and receive from the party instituting the proceedings, or any part liable for the costs thereof, all unpaid sheriff's fees on the same before he shall be obligated by law to make return thereof. ___Sec. 2, Act of June 20, 1911, P.L. 1072 SHERIFF OF BERKS COUNTY 633 Court Street Reading, Pennsylvania 19601 BARRY J. JOZWIAK SHERIFF PHONE (610) 476.6240 FAX (610) 476.6222 SHERIFF'S RETURN DOCKET NO. 981081 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BERKS :55: Personally appeared before me, PATRICIA A. DONATO, Deputy for Barry J. Jozwiak, Sheriff of Berks County, Pennsylvania, who being duly sworn according to law, deposes and says that on MARCH 18. 1998 at 5143 P.M.,he served the annexed COMPLAINT IN CIVIL ACTION upon JOAN COOK, within named defendant, by handing to GERALD R. COOK, her husband, a copy thereof at 1905 REDWOOD AVENUE, WYOMISSING, B~rks County, Pa, and made known to\d~~a~t_ the co~~ thereof. .' l X?~M,-:....Ed /. ?--n~ DEPUTY SHERrF'F OF BERKS CO., PA swo~n and SUbscri~e before me t~!s 19th day of A CH, 1998 i ' '. \ ~?TARY - AD., BERKS CO., PA V NOTARI,t/ 6 NO~PUbIIC Service made as set forth above. 6ERNAOEm M, GAllO PA So Answers. Rnding. Ilerlls County. 000 My CQlMlisslOn Elpifl$ 1.6.2 $ .00 $_.00 $ .00 - Sheriff's Costs in Above Proceedings DEPOSIT ACTUAL COST OF CASE REFUND ATTACHED All Sheriff's Costs shall be due and payable when services are performed. and it shall be lawful for him to demand and receive from the party instituting the proceedings, or any part liable for the costs thereof, all unpaid sheriff's fees on the same before he shall be obligated by law to make return thereof. ___Sec. 2, Act of June 20, 1911, P.L. 1072 ANDREW G. HUGHES CHIEF OEPUTY ~: . n ,I') () C' :;:.J '- "n .' :t'~ -".,. :-;1 6'1 f~' : ~I ::';;.;1;: ~-J i'"ii?J ~~! ~~:: , ~,..I.n IXl ::i~ t:.: ;~~' ~.:.? ( "':. ::r? .':!jJ '"".r.... _" (-, . 3~; ;~ .;.,~ r~) '-- =:-.) (jtn ...:. :n :;j =< =.n l::l -< t ;":. ~ ~.~ .~..' .....,..~.._.---.... : '.:,!i:~~~';:;':~'\ ' "'I ._-"'-~ ~~::~~. ,-! Shrager, McDaid, Loftus, Flum & Spivey BY' DANIEL S. WEINSTOCK. ESQUIRE IDEtmFlCAll0N NUMBER 729-40 32nd FLOOR TWO COMMERCE SQUARE 2001 MARKET STREET PIllLADELPHIA. PENNSYLVANIA 19103 (215) 568.7771 CUMBERLAND COUNlY CLAUDIA M, aUIRAMA Plaintiff vs, } ERIC D. COOK and } GERALD R. COOK and } JOAN COOK and PAUL E. GROCE Defendants COURT OF COMMON PLEAS CIVIL DlVISION LAW No: 98-1081 PRAECIPE TO REINST ATE CIVIl. ACTION COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the attached Civil Action complaint in the above captioned case. SHRAGER, McDADE, LOFTUS, FLUM & SPIVEY BY: (,/ / /........., Dan' 1 S. wein 'ock, Esquire Attorneys for plaintiff ~ U) 0 C) ." :::- -l -CUI -0 :t::!I [T'l" ;.0 ~~ 7';51 :..r.;( . N 0~; -.J ;11 0 r-';l:.~ -0 :.:J:H ~<J ::=: ~ja ~o C!J ?rn ~c.-: ~ .? 'l. :=J U1 ~ .... ...J -< ~ / ,( IlL i ' I i, r . ~ Ms, Knthlccl1 CUI111nl1c Allslnlc Mnrkcl Clnim omcc 1655 Vnllcy CCl1tcr Pnrkwny Suitc 200 Bcthlchcm, PA 18017 SIIragcr, Spil'cy, SocIIs & Weimtock BY:~~~ Dnl1lcl S. WClI1stock ...... Attorllcys for Pia/miff 2 n r~., c} C ., " -J" '" d r;; i-q .., -;0'(.: , " 't} ;;", ;.:..~ f'- t" " (I,. r- " 'J ~I::.: ...J -" , ~ ) "~-C -:. " cr..:C'" ~'. ~,2 (-J ......f:= ':! (.'jl " -.- :~I ::,j -... .r.- 5 ..< . ), :1 [I I. I t, .lJ :1'''' i\+ , . ~1lj '(" ".".. I ,_,~ " I/t 'I'" \ ~ r' '! " '" I ~ r r r f f , { 4 I :1 ( \ ! 1 " 1 I \.".................. ~!I ~ ! ~~l_ n:o \w-:"~~m~ w~, .,,'~: ~~ \ :"II.... 1,;_ i'i-i!h}'j.~,,::-..~, g:~ l~l) _ ~ , 4 \ 1 :1 0: -:l ci W -'W OCl >-0 W:> -,-:l CIl W ~ -; W 0: < :>M o~ CIl::! w~ ~a: o . J:w ....-' o:!!l :>-' 00: u5 W z o ;-? (I M , w u~ <:::> ,~ ~ '~ i'J ~ ~-- ,-:I &.0 ~':Z ~~ , ol o ... I ~ 'Iol !~ ol III .J H ILCl 0: 0:0: III Z<1ll ZCl 03~ olffi o:glll NUl IllILUl o Cl 00 IIOO 1111- 01-1- r- 11\2 Cllll2 IUO: II.JII:J r-:J <Illl- oll- ~~Ill III O:JII II IL o 2 f, J :i ;, \ ", ~ ) 'I =2 :: :] ..:: ..:: :: - jJ Ji ~I ==1 i - , ;\ i I 1":' I 1'.1 ,', " I '. ::a /, " i'.l ': " il 'f'l I' [I' I~ -- " \, , ..'!" 'W " " i~ t , ' \ ' I) ~I ' I I '. ~,..t\'.<. .1\ ".'1 it.':. /, ~ V". \ . .. .;n~:i':" ':~" ,.' . -,' . 't/ll, . " hl< ~ fl ,~ ,7 .~ 1 ,'\ , I ~- " . . .~.-f~~c.A~ e ~ ')r. ....._"....,. , .,'t.. ",~... .. . ;'.. , ...,.,. -'-. .,~:~ ~'./ ',')' ': ,,,,.-.t":,',, rile . ;.~ ~ -4"; ~. " :: . -it., 'h" ":,.,' "1' ) I I ), \ 'l /' "'I' t ,"' ; 'I"'~ I,,', .. 1 '. .~ :',/11 '''.'' " ,~ " . ....,'... . 1"1 ~~,7 , . r ~~ 1t., . , .;~~ '. ~, , . , ' ) ,114. C.....' ./' . 'I ~' '~..6 " " , , .,~ r. \, ,. I ;10 - .to., ":.~ ".. .-." CLAUDIA M. QUIRAMA, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW ERIC D. COOK, GERALD R. and JOAN COOK, and PAUL E. GROCE, DEFENDANTS 98-1081 Civil Term ORDER OF COURT AND NOW, this 30th day of October, 2001, in the case of Quirama versus Cook at No. 98-1081 Civil Term, and it appearing that docKet activity has recently occurred in the case, the case is stricKen from the purge list and shall remain active. By the Court, Daniel S. WeinstocK, Esquire 2001 Market Street, 32nd Fl. Philadelphia, PA 19103 For the Plaintiff jl6p;'" 1fl~ U II -;'/d)} (sK5 Eric CooK, Defendant Pro Se 149 Timber Lane Shippensburg, PA 17257 Gerald R. CooK, Defendant Pro Se 1905 Redwood Ave. Wyomissing, PA 19610 Joan CooK, Defendant Pro Se 1905 Redwood Ave. Wyomissing, PA 19610 C) .:;.' , (..~ "t, -,... "'rJt'-j" :':"j "-11: .,;; :i"d ?;.;;~' <t :1:=9 V,)" '.0 " ~(: .:''-;{:' -, :;::,", ...:< ..-'-; ,~;t""" (' ',..Q ;Sr', "'0 ;pc: '& c'j/n ~ --i :::J '" j:J 'JI -< pcb