The URL can be used to link to this page

Home My WebLink About98-01333 "j ~ ~ I: d' n .. Ii! ~ -..t' ~ ~ ) 1 "",. a ::t r .. 'l! - '- :) ".. \J r<) CY) I'/) ....... \ 0... (}. ti \~ . ~. -. . - ..~-=~... - - "--,-"".,, !::....~~..: .". ," ' _,' '..'~: . ',,~':":""~';." f"/.'.f.'l~"'~li,;;~!.r<:J...t~"':'i' U' "I',' "~'" ,. , , , ','.' '\' " ,/.,:,,' "1~,)i\'11"'~I\'~\':r\;"-:~~'~~;""Hj..';("~;"1;".;~r..' :::,.....{.II~. ,"." ,^ ,I,..,:;,": I .. . I,' r./.': ';l':::I...:...:,_~:.!~;;:;/,:.:~.)~..,I'.:t;~.,~1;~).;:~~;~;:~f":':.i.~;r.~t.1'~~:,::..::~"J.;..'~,"::';>" '." .,'. ,......" . _.. ,~".c :.\\\0 .:) . :"";".:.,, ;:' ,-u r.:~. .. ' ..). \. .~: (:':1 Y.':,', - ::: '". t. ..'''' , , () ",;~:~:~"."..:~,:/\\~.:.,.:. ""1 :,' ~';J.'l~ 6J.{~ i!t~... -d; cf4 ~ &. ..,) 91 ~~u /..tZ~ -d- d{ f:Jth~ .. '~ . . ... " Helga Hood, individually; Anne M. Cox, Administratrix of the estate of Gunnar Hood, deceased, in their own capacity and as assignees of CNA Insurance Company In the Court of Common Pleas of Cumberland County Pennsylvania Plaintiff vs 1998 -/333 Civil Term Sheila I, Kuhns, in her capacity as Administratrix of the Estate of John W. Kuhns Defendant Jury Trial Demanded Civil Action Law AFFIDAVIT I hereby swear or affirm that the Foregoing is true and correct to the best of my knowledge and/or information and belief. This is made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. .' ". ~ 'I. ~-~~------~----- sIgnature May 26, 1998 . WiIIl.m 1'. Dougl.s. Ilsq. Supreme Courtl.D,H 37926 Dougl.s. Dougl.s & Dougl.s 27 W. High St. POD 261 C.rllsle I'. 17013 Telephooe 717-243-1790 ....Helga..Hoo.a;..in.a1'viduallYi.Ann'e..M':..........'..ln..the..Co.urt"of'Comm'on..Pl'eas..of'...... COX, Administratrix of the estate of Cumberland County Pennsylvania Gunnar Hood, deceased, in their own capacity and as assignees of CNA Insurance Company Plaintiff vs 1998 -1333 Civil Term Sheila I. Kuhns, in her capacity as Administratrix of the Estate of John W. Kuhns Defendant Jury Trial Demanded Civil Action Law ................................................................................................................".........."................................................................................................ COMPLAINT NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN TIlE FOLLOWING PAGES, YOU MUST TAKE AC/'ION WmUN 'IWENTY DAYS AFrER THIS COMPLAINT AND N011CE ARE SERVED, BY ENTERING A WRIITEN APPEARANCE PERSONALLY OR BY A'J1'ORNEY AND FILING IN WRITING wrrn THE COURT YOUR DEFENSES OR OBJEC'nONS TO THE CLAIMS SET FORTIl AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO, TIlE CASE MAY PROCEED WITHOur YOU AND A JUDGMENT MAYBE ENTERED AGAINST YOU BY THE COURT WITHOUr FURTHER NOTICE FOR ANY MONEY CLAIMED IN TIlE COMPLAINT OR FOR ANY OTIlER 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 AFFOR/) ONE, GO TO OR TELEI'HONE THE OFFICE SET FORTH IIELOW TO FIN/) OUT WHERE YOU CAN GET LEGAL HELl'. Cumberland County Bar Association 2 Liberty A venue Carlisle, PA 17013 717.249.3166 Date: March 2,1998 By~LQ\~~ o .. .. Complaint 1. The plaintiffs are, Helga Hood, Individually, and Anne M. Cox, Administratrix oE the Estate of Gunnar Hood, in their own capacity and as assignees of CNA Insurance Company, have a mailing address of 27 W. High St., Carlisle, Cumberland County, Pennsylvania. 2. The defendant is, Sheila I. Kuhns, In her capacity as Administratrix of the Estate of John W. Kuhns, appointed by the Hegister of Wills in and for Northumberland County, Pennsylvania, with an address oE 315 Patton Road, Northumberland County, Pennsylvania. 3. On or about October 9, 1996, the decedent, Gunnar Hood, was operating a motor vehicle In an easterly direction on Walnut Bottom Road, Shippensburg Township, Cumberland County, Pennsylvania, 4. On or about October 9, 1996, the decedent, John W. Kuhns, was operating a motor vehicle In an westerly direction on Walnut Bottom Road, Shippensburg Township, Cumberland County, Pennsylvania. 5. The vehicle operated by John W. Kuhns crossed the centerline and colIided with the Hood vehicle. Both drivers were killed as a result of the injuries they sustained in the accident. 6. The vehicle, operated by John W. Kuhns, that struck and killed Gunnar Hood, was owned by Jess Jones d/b/a J&J Carbide. 7. The accident was caused by the negligence of John W. Kuhns and he was negligent in the following respects: a) in failing to maintain a proper lookout; b) in falling to yield one half of the roadway to oncoming traffic; c) in falling to operate his vehicle in the proper lane of travel. 8. Gunnar Hood is survived by his mother, Helga Hood. 9. Anne M. Cox was appointed Administratrix of the Estate of Gunnar Hood by the Cumberland County Register of Wills on November 7, 1996. DOUGLAS, DOUGJ.AS & DOUm.AS 27 W. IIIGII ST. POD 261 CARLlSI.E PA 17013 TELEPIIONE 717.243.1790 x WILLIAM P. DOUGLAS. ESQ. Supreme Court J.D.# 37926 GEORGE F, DOUGLAS. 11/. ESQ, Supreme Court J.D.# 61886 HELGA HOOD, INDIVIDUALLY; ANNE M. COX, ADMINISTRATRIX OF lliE ESTATE OF GUNNAR HOOD, DECEASED, IN TliEIR OWN CAPACITY AND AS ASSIGNEES OF CNA INSURANCE COMPANY, IN lliE CoURT OF CoMMON PLEAS a= OJMBERlAND CoUNTY PENNSYLVANIA 1998 - 1333 CIVIL TERM PLAINTIFF VS OVIL ACTION LAW SHEILA I. KUHNS, IN HER CAPACfTY AS ADMINISTRATRIX OF TliE ESTATE a= JOHN W. KUHNS, DEFENDANT To: Curtis R. Long, Prothonotary PRAECIPE For and in consideration of the sum of $35,000.00, the above-captioned claim is settled, satisfied.and discontinued with prejudice. Date: !J -- clC) ~ OCJ DOUGLAS, DOUGLAS & DOUGLAS By Attorney for Plaintiffs -~.'..1 (' , (:.: ~;~ C.:..;, , -, -., rn ,-I .. l.J '- :~: , , ;....." .!:; r-' .' c;: " -. , ,-' , ..... .~ ..::-;- .. j" ::) '- ..' ..... c' ,. C.l -. s:~~ 1':-.' ) I , : .'- => ::.:-! =< :iJ -.