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Home My WebLink About03-1280CUMBERLAND COUNTy ADULT PROBATION VS. Robert A. Leonard 436 Spring House Road Camp Hill, PA 17011 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTy PENNSYLVANiA CIVff~ ACTION _ LAW NO. .. iO)o d) Crv'n_, TER Defendant RE: NO. 02-2366 CRIMINAL TERM PRAEcIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: Enter judgment in favor of plaintiff, Cumber/and County Adult Probation, and against Defendant in the amount of $ 2268.47 pursuant to 42 Pa. C.S.A. Section 9728 as set forth in the attached statement of certified case costs and fines. Date: March 24, 2003 Dennis E. Lebo, Clerk of Court E__NTRY OF JUDGMENT AND NOW, this. o2z/' day of ~~, ~__~__,judgrnent is entered in favor of the Plaintiff and against the Defendant m the amount set forth above. Curtis R. Long, Prothonotary Attachment cc: Defendant Probation Clerk of Court CCS746 Case No. 2002-02366 LEONARD ROBERT 436 SPRING HOUS~ RD CAMp HILL, PA 17011 *STATEMENT ***********~.COSTs* ****** To: Dennis E. Lebo Cumberland County _ 1 Courthouse S Carli Ware Sle, Pa ~7013 Clerk Paqe 6 2728/2003 of Courts 10/30/02 RESTITUTioN 71.50 Balance ----_ Totals 71.50 71.50 71.50 10/30/02 CONT SER SURG Totals 5.00 5.00 ~lZo6zo2 CASH BONn 11/06/02 PYMT/CASH BOND Totals llZ°6Z°2 POUNDAGE 11/06/02 PYMT/CASH BOND Totals 02/07/03 SHERIFFS COST Totals 02/20/03 6UTOMATZoN FEE Totals 02/20/03 COURT COSTS Totals 02/20/03 SHERIFFS COST Totals 02/20/03 STATE COST A Totals )2/20/03 STATE COST B Totals 2/20/03 JCP FEE Totals 95.00 95.00 5.00 5.00 40.07 40.07 5.00 5.00 15.84 15.84 1.50 1.50 6.33 6.33 6.33 6.33 1.50 1.50 5.00 5.00 95.00 95.00 95.00 · 00 .00 5.00 5.00 5.00 .00 .00 40.07 40.07 5.00 5.00 15.84 15.84 1.50 1.50 6.33 6.33 6.33 6.33 1.50 1.50 CCS 746 Case No. 2002-02366 LEONARD ROBERT A 436 SPRING HOUSE RD CAMp HILL, PA 17011 02/20/03 02/20/03 02/20/03 02/20/03 02/20/03 02/20/03 DISTRICT ATTy Totals PLEA Totals COURT COSTS Totals LOCAL FINEs Totals STATE FINEs Totals EMS Totals 02/20/03 ~T FUND orals 02/20/03 ADMIN. FEE Totals 02/20/03 LOCAL FINES Totals }2/20/03 STATE FINES Totals 2/20/03 EMS Totals 2/20/03 EAT FUND ~Otals ******************** *STATEMENT OF COSTS, To: Dennis E. Lebo Cumberland Coun ~gUrthouse ~ - l_, ~d 17013 Clerk of Page 7 2728/2003 Courts 15.00 15.00 125.00 125.00 8.00 8.00 500.00 500.00 500.00 500.00 10.00 10.00 30.00 30.00 40.00 40.00 150.00 150.00 150.00 150.00 10.00 10.00 30.00 30.00 15.00 15.00 125.00 125.00 8.00 8.00 500.00 500.00 500.00 500.00 10.00 10.00 30.00 30.00 40.00 40.00 150.00 150.00 150.00 150.00 10.00 10.00 30.00 30.00 ~ ~ uou;z2803 CCS746 Case No. 2002-02366 LEONARD ROBERT A 436 SPRING HOUSE RD CAMp HILL, PA 17011 To: Dennis E. Lebo Cumberland County _ 1 Courthouse S u Carli are ale, Pa ~7013 Clerk of Paqe 8 2728/2003 Courts 02/20/03 02/20/03 02/20/03 LOCAL FINEs Totals STATE FINES Totals 150.00 150.00 150.00 150.00 150.00 150.00 RESTITUTION Totals 211.40 211.40 211.40 211.40 02/24/03 SHERIFFs COST Totals 36.00 36.00 36.00 Case Totals 36.00 2368.47 100.00 150.00 150.00 2268.47 ................. You are liable for th Pursuant -7 ............. e above c PA CSA 9 to Tztle 42 7-7 ............. oats un · 728, the Pro of Judlclar Paid cgsts and ' thonotary is Y ~nd Judicia ............... the Sherl iSSue an .authorize _1 proqedu ff for th _~ecutlo _ d to coif . _ re,. 42 We tru-~ _ ~ col~eunlon, n and place same ~st~d~~ o~ all ou you will give the above account your nrom~ ~us or ~ '"~ ~uuention A TRUE COPY FROM RECORD In Testimony whereof, I hem unto se~ my Ita/M a nd the seal of said Court at ~ PA, JAMES E. McCAFFERY, Plaintiff COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1880 CIVIL ACTION - LAW JURY TRIAL DEMANDED 21. 22. 23. 24. 25. 26. 27. 28. 29. condition. REPLY TO NEW MATTER Defbndant states a conclusion of law to which no response Defendant states a conclusion of]aw to which no response Defendant states a conclusion of law to which no response required. required. required. Defendant states a conclusion of law to which no response ~s required. Defendant states a conclusion of law to which no response Is required. Defendant states a conclusion of law to which no response is required. Defendant states a conclusion of law to which no response is required. Defendant states a conclusion of law to which no response Is required. Denied. The Commonwealth Defendant had actual notice of the dangerous With regard to whether it possessed written additional notice of the dangerous condition, after reasonable investigation, Plaintiff is without kno~vledge or information sufficient to form a belief as to the troth of this averment and strict proof thereof is demanded. 30. Denied for the reasons stated in 29, above. 31. Defendant states a conclusion of law to which no response is required. 32. Defendant states a conclusion of law to which no response is required. 33. Defendant states a conclusion of law to which no response is required. 34. Denied. The conditions attributed to Defendant's negligence did cause Plaintiff's losses for the reasons stated in the Complaint. 35. Denied. The roadway and grate were dangerous for the reasons stated in Plaintiff's Complaint, which are incorporated herein. 36. Defendant states a conclusion of law to which no response ~s required. 37. Defendant states a conclusion of law to which no response is required. 38. Defendant states a conclusion of law to which no response is required. 39. Defendant states a conclusion of law to which no response is required. 40. Defendant states a conclusion of law to which no response ~s required. 41. Defendant states a conclusion of law to which no response is required. By way of further response, Plaintiff at all relevant times exercised due care in his own behalf. 42. Denied. Plaintiff at all relevant times exercised due care in his own behalf. The balance of this averment is denied as a conclusion of law. 43. Defendant states a conclusion of law to which no response is required. 44. Defendant states a conclusion of law to which no response is required. 45. Denied. Plaintiff at all relevant times exercised due care in his own behalf and made reasonable efforts to mitigate his losses. 46. a. Denied that Plaintiff failed to exercise due care when bicycling. b. Denied that Plaintiff failed to exercise proper look out. c. Denied that Plaintiff operated his bicycle at a speed which was too fast for conditions then and there existing. d. Denied that Plaintiff failed to keep a careful and vigilant watch on the highway. 264663 1 ~JMM\RT 2 e. Denied that Plaintiff inattentively operated the bicycle. f. Denied that Plaintiff was negligent per se in failing to operate his bicycle in the same direction as vehicle operate on the roadway in violation of 75 Pa.C.S.A. § 3505(b). Moreover, Defendant states a conclusion of law to which no response is required. By way of further response, the direction which Plaintiff was riding did not play a causative role in the accident. h. (sic) Defendant states a conclusion of law to which no response is required. It is specifically denied that Plaintifl's use or non-use of a front lamp was negligent per se as a matter of law or contributed to the happening of this accident. i. Denied that Plaintiff failed to observe the rules of the road or violated an acts of assembly. WHEREFORE, Plaintiff demands judgment against Defendant. Respectfully submitted, ANGiNO & ROVNER, P.C. Date: November 24, 2003 elillo, Esquire ). No. 26211 4503 North Front Street Harrisburg, PA 17110 (717) 238-6791 Attorney for Plaintiff 264663. I LIMIVBRT 3 VERIFICATION I, James McCaffery, Plaintiff, have read the foregoing and do hereby declare and affirm that the facts set forth therein are true and correct to the best of my knowledge, information and belief. I understand that this Verification is made subject to the penalties of 18 Pa.C.S. § 4904, relating to unswom falsification to authorities. WITNESS: James McCaffe~ ~-2~ Date: CERTIFICATE OF SERVICE AND NOW, this lst day of December, 2003, I, Shirley Corman, an employee of the law firm of Angino & Rovner, P.C., hereby certify that a true and correct copy of the foregoing document was sent to the following counsel of record by placing same in the first class, United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: Steven C. Gould, Esquire Deputy Attomey General Torts Litigation Section 15th Floor, Strawberry Square Harrisburg, PA 17120 ' Shirle~J~orman