HomeMy WebLinkAbout98-04321
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COMPLAINT
1. The plaintiff, Gary L. Seibel, is an adult individual residing at 30
Knoll Lane, Newville, Upper Prnnkford Township, Cumberland County,
Pennsylvania.
2. The defendant, Roy A. Snyder, Jr., is an adult individual residing
at 7330 Wertzville Road, Carlisle, Cumberland County, Pennsylvania.
3. On March 7, 1997, the plaintiff was operating his 1988 Dodge
Dakota south on SR 1025 - Erford Road, East Pennsboro Township,
Cumberland County, Pennsylvania.
4. At the same time and place, the defendant was operating a 1993
Plymouth Voyager in a northerly direction on said SR 1025 when he turned
left in front of the plaintiff, at which time the collision occurred.
5. The defendant was negligent in the following respects:
(a) in failing to properly maintain control of the vehicle;
(b) in making a left turn directly in the path of the plaintiff;
(c) in failing to yield the right-of-way, and
(d) in failing to maintain a proper lookout.
6. As a direct and proximate result of the accident, the plaintiff was
injured. Those injuries include but are not limited to muscular and low back
pain, and herniated disk at C5-6 pressing on the spinal column, making his
body numb.
7. As a direct and proximate result of the injuries suffered by the
plaintiff, he has undergone and will continue to undergo great pain,
suffering, aggravation, inconvenience, embarrassment, mental anguish, and
emotional and psychological trauma.
8. As a direct and proximate result of his injuries, the plaintiff has
been permanently disfigured.
9. As a direct and proximate result of the accident, the plaintiff has
incurred medical expenses, which may exceed those covered by the Motor
Vehicle Financial Responsibility Act.
COMMONWEALTH OF PENNSYLVANIA )
COUNTY or CUMBERLAND
SS.
)
VERI FICA TION
I verify that the statements made in the foregoing document are true
and correct, to the best of my knowledge, information, and belief. I
understand that false statements herein made are subject to the provisions of
18 Pa. C.S.A. S 4904 relating to unsworn falsification to authorities.
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