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Home My WebLink About00-08359 7': '_' ^ "'7__"~ ,~. __-.'.". ~,<> _'C,,__,~~~_'~"'""'~_' ','*. . '-_,,,~,,,, ,:..,' ,_",;,.;,^,';;:Q,;. y__~"",___ -W,i ,. .. . ~' " ..... \ ~ MICHAEL SHEIBLEY Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. OC) - fJS'9 (]()~l y~ WILLIAM J. JAHN and, : CIVIL ACTION - LAW CHERYM. KING Defendants : JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please issue the Writs of Summons against the following Defendants and have the Sheriff of Cumberland County serve the Writs: o William J. Jahn 23 Hunt Street Fort Bragg, NC 28307 o Cheryl M. King 104 S. Locust Street Apartment 1B Shiremanstown, PA 17011 Respectfully submitted, HANDLER, HENNING & ROSENBERG Date: II - ;;l" on By: g M. eather, Esquire Supreme Court ID No. 79456 319 Market Street P.O. Box 1177 Harrisburg, PA 17108-1177 (717) 238-2000 Attorney for Plaintiff . "~ ~ ~1 4w,iM)." ~ - ... . Commonwealth of Pennsylvania County of Cumberland MICHAEL SHEIBLEY Plaintiff Court of Common Pleas YlJ, WILLIAM J. JAHN and CHERY M. KING Defendant No. 2000-8359 Civil Term ------------------------------------- ~--- In _n<::~~~_~~'!:!9!_!.:~~_m____m________m_ To . \'[J;LLIAM J_.__~~_~__~~.Y__~~nr<::!~~___ You are hereby notified that ._11J;~~_~J;6y~_X___________________________.________________________________________________ the Plaintiff h<6 commenced an action in _~-CI\.LI.L-AG'];IQN.~I.AW.-nnn-----u-h-_h____ against you which you are required to defend or a default judgment may be entered against you. (SEAL) CURTIS R. LONG Prothonotary Date _~~~~E_~P_'__~2P.9..________ 1&___ By mK~-~p~r~____ II] r ~U~'llIHII!l~Oi~ffi'fi!lli!ii---~~O$.i,>t-'-io!"''''_tWli;~''-lc'';l..gti-''.lii,,,.'tici:~mmM~iIl~~.ffl1~~1;!;i;~ ~-"'-1 .... - '- f.'.... , ~ , I I IN -[j;'dWUlCl 'n ~~ :;:: -...I . f-'CEll 'H H '0 f-';oO\O'd :< g '0 -...1;0. is ,H ~f::: '0 EffiElI ~ It< [';j " I en ~d '00 If) t< Iw ooc:x: I 1<J1 > ~e\f-'>-3~;S: :>-3 '-< f:iJ 1\0 H ",. S, o f-' ~ ~ H ~ t'l 10 O'd-...lUl t:l ~~ H ,f-'. j, O:J;o-...l >-3 >-3 , III ,~ EllHi ~ ~ If-'. f-' If-' I -...I t'lO , f-' >-3 .. ~ 'r+ , 0 e;~ == 1m , 00 '~ , , , . I I f-' t'l I f-' ~~ , I -...I ~ I -...I , I <J1H I I "'Ell I I I t p L~' C% (Y0)Jsn . _w ~ ~ ~ ~ ~ ~ ~,<~~, -,), ;}.J.J;",-,'&IT;_-",JrI!I~K.,.~,c','(,;~ ,_,_",-I~;r~~I.~"",,~ ";,,,l~~Lt-"):.J ;',~_ ;<-,.J" ,,-",J~ 1_, ,. . . ~'"_~~, 0 ,_ . ,~__,_,', "",,,,,,, "Z' -~-,~ "'J "' ""'~..~': SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-08359 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEIBLEY MICHAEL VS JAHN WILLIAM J ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT KING CHERYL M but was unable to locate Her in his bailiwick. He therefore returns the WRIT OF SUMMONS , NOT FOUND , as to the within named DEFENDANT , KING CHERYL M DEFT. MOVED, NOW RESIDING IN YORK CO., DID NOT RECEIVE ADDL FUNDS IN ORDER TO DEPUTIZE FROM ATTORNEY FEATHER PRIOR TO EXPIRATION DATE OF 12/29/00. Sheriff's Costs: Docketing Service Not Found Return Surcharge 6.00 6.20 5.00 10.00 .00 27.20 R. T'homas Kline - . Sheriff of Cumberland County HANDLER, HENNING & ROSENBERG 01/08/2001 Sworn and subscribed to before ilt!:' day Of~~,.. I me this ,wi A.D. Sl%f' () /UdP,., f~ P onotary I nIT . -- '" - , ; , _l ~~" ~]~JIIj__~": SHERIFF'S RETURN - U.S. CERTIFIED MAIL " CASE NO: 2000-08359 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHEIBLEY MICHAEL VS. JAHN WILLIAM J ET AL R. Thomas Kline , Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,JAHN WILLIAM J by United States Certified Mail postage prepaid, on the 1st day of December ,2000 at 0008:00 HOURS, at 23 HUNT ST FORT BRAGG, NC 28307 a true and attested copy of the attached WRIT OF SUMMONS Together with The returned receipt card was signed by 00/00/0000 on Additional Comments: RETURN CARD NEVER RECEIVED IN CUMBERLAND COUNTY SHERIFF'S OFFICE. Additional Comments Docketing Cert Mail Affidavit Surcharge 18.00 2.99 .00 10.00 .00 30.99 -~ --;? Sheriff's Costs: Thomas Kline Sheriff of Cumberland County Paid by HANDLER, HENNING & ROSENBERG on 01/08/2001 . Sworn and sUbscr~ed to before this n/b; day of . r'--J~A<l oPv-v1 A. D. Cj'J.I!'<~ a. nv;L.-~ ~.lr othonotary I me f , ".; ,->,,~,.'; TRUE COPY FROM RECORD I 111 TeStimonylitll8r8of. I here UlltOseit my haoo and IW.. of said.~. " ...81 Calf. .. PI. .. Thts ~~~~_ .~ '. . .. Prothonota~ Commonwealth of Pennsylvania County of Cumberland MICHAEL SHEIBLEY Plaintiff Court of Common Pleas va. WILLIAM J. JAHN and CHERY M. KING ( CherY~fendant No. 2000-8359 Civil Term ------------------------------------- ~--- In _ __ <:::rY.:J;,~ _!:~!9!'!..:.~___ _ _ _ _____ _______h_ __ To V{J;LLIAM J.--~~-~(~~:h,~I-~!~~--- You are hereby' notified that ._11J;(ij~~_S~J;6~~~___________________________._____________________________::_________________ the Plaintiff h<6 commenced an action in -SlJMMaIl5.~cr~I.-JIG];IQN.-I.AW.-----___h_____h________ against you which you are required to defend or a default judgment may be entered against you. (SEAL) CURTIS R. LONG Prothonotary Date _~?":~~_'::_~9_'__~?9_~________ Uk--- By ---i1~-1E-~J}~;---- Deputy ''''(-'if "o,.""'l:,,,,,,,,.6;~jjf'''''''''--~1Ia:liliil..~..I~~~gloJ' .<:100.~1 'I ~ ~!ii'OWgjGl ~~ :;: I 0 ,N " . I-' Ell ~ () H '0 1->::00\0'1:1 ;:T g '0 "",. i8 t:J "'t" '0 (1) ><:H t'il " tl~~1 ~ en 'i :;:~ :00 ~ ~ '< t" ,W ooc:>': .~ . IUl >- ~~I-'''~~ c.., ~ lID ~. ~ o I-' ~ H 10 S O'O"Ul tll ti~ ~ H ,I-" j 0):''''' I ~ tll ,<: ~ ~tJ~ ~ f;l 'I-" Z If-' I-' ., .. ~ ><: Irt o 0'" 1:1 ,(1) 00 - i~ , . I-' ~~ I-' I " ~ " ,"'c 'JlH I "'flj I , I ~ (~ cn:ro ~ ES lfij;v ~ 'Y~i- ~ @Iii) ~ ~ criiil ~" <: ,~.:'\" IlIlD.l1 ,- _~, c" """,,",..~J 'u . MICHAEL SHEIBlEY Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-8359 WilLIAM J. JAHN and, CHERYL M. KING CIVil ACTION - lAW Defendants JURY TRIAL DEMANDED PRAECIPE TO REINSTATE WRIT OF SUMMONS TO THE PROTHONOTARY OF DAUPHIN COUNTY: Please reinstate the above-named Petition in the above-captioned matter and have the Sheriff of Cumberland County deputize the Sheriff of York County and have the Sheriff of York County make service on Defendant, Cheryl M. King, at the address known to the Cumberland County Sheriff and have the Sheriff of York County serve Defendant, Cheryl M. King, at 57 Meadowbrook Court, New Cumberland, PA 17070 Respectfully submitted, Date: 1-1,/-0 I By: ! ~'.-- .l_~ ."~~~ .I""","~", SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2000-08359 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SHEIBLEY MICHAEL VS JAHN WILLIAM J ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: KING CHERYL M but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania, to serve the within WRIT OF SUMMONS On February 15th, 2001 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing Out of County Surcharge DEP. YORK CO 18.00 9.00 10.00 33.11 .00 70.11 02/15/2001 HANDLER, HENNING S R. Tomas Kline Sheriff of Cumberland County & ROSENBERG Sworn and subscribed to before me this Jo!:' day of ?J~ ~) A.D. q '( prSh?::;~~~y' '+fJ ~.f;~~~~" . . . '''''''''-'''lNlIIt ,I, " :o:t_I~~~~~I;-M~ij!IwJ,!'l@"f; COUNTY OF YORK OFFICE OF THE SHERIFF SERVICE CALL (717) 771-9601 28 EAST MARKET ST., YORK, PA 17401 SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN 2. OURT NUMBER 4. lYPE OF WRIT OR COMPLAINT Reissued Writ of 1. PLAINTIFF/51 Michael Sheible 3. DEFENDANTISJ William J. ,Jahn SERVE { 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERlY TO 8E LEVIED, ATTACHED, OR SOLD. . Cheryl M. Kinq , 6. ADDRESS (STREET OR RFD WITH BOX NUMBER, APT NO.. CllY, BORO, TWP., STATE AND ZIP CODE AT ">7 Meadowbrook Court, New Cumberberland, PA 17070 7. INDICATE SERVICE: a PERSONAL a PERSON IN CHARGE )Q DEPUTIZE('lImR.sJ;RT..IIH~ a 1ST CLASS MAIL NOW', 11?4/nl" 19~I,SHERIFFOFYO'eI<<C~U T'l ,do hereby VOrl< COUNTYto. ,', . ke to law. This deputation being made at the request and risk of the plaintiff; " SHERIFF OF 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDmNG SERVICE: a POSTED a OTHER the sheriff 01 1 according Cumberland ~-':'; ADVANCE FEE PAID BY CUMBERLAND COUNTY SHERIFF . .,.,p NOTE ONLY APPUCABLE ON WRIT OF EXECUTION: N.B. WAIVER OF -WATCHMAN - Any deputy sheriff-levying upon or attaching 'any property urii:ler within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the, sheriff to any plaintiff herein for any loss, destruction. or removal of any property before sheriff's sale thereof. - 9. TYPE NAME AND ADDRESS of ATTORNEY/ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER 11. DATE FILED 1/23/01 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed). CUMBERLAND COUNTY SH"'...RIFF 16. HOW SERVED: PERSONAL ( ) RESIDENCE POSTED ( . ) POEt ) SHERIFF'S OFF ( ) OTHER ( ) SEE REMARKS 21. ATTEMPTS Dale 22. REMARKS: ~ 44. Signature of De. heriff 45. Signature of York County Sheriff 43. WILLIAM M. HOSE ~_:' _ 46. Signature of Foreign MY COMMIS ION EXPIRES '., (): Coun Sheriff 50.1 ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE OF AUTHORIZED ISSUING AUTHORllY AND TITLE 1. WHITE - Issuing Authority 2. PINK - Attorney 3. CANARY - Sheriffs Office 4. BLUE. Sheriff's Office 48.Da e 2 12 01 49. Date 51. Date Received j ~ ~-" .~ .~= < .<"<.....m'l" ,,,,. ...."~..r..'.~...jl~.....c.. '''W "'~jT"'" ~'"IIffi'1 Ul 111 --''"iNl! Tr,ll' n ,\ ~'-.'"' j-: 1"'!F;j" i'>r:,-..;t.- I,..' OFfICE OF SHE\1:~F y.6RK. PA '01 JRN 25 Pr1 2 3Y n """~~ ,~ "~~'fl\f0f'1f"..~-w.r,o;w"W<i""H'''''''"~'''-'?'''''~IIIil~liJlij~!$:im~1W\i>~'O,<r"~',', " "",,.,~~ ~ \', " , 'C. . "C<' -""".;"~,. ,! i~' Wf~ \i)"'[!!:;~'~;!"'l!!it0M;~>'I">'!iI#'i'>;!:PP;'lJo cou:~h QFYORK~- ' OFFICE ElF THE SHERIFF "I' ,. 28 EAllT MARKE[.ST., YORK,'E'A 17401 < } ,;,;e',1 , SERVICE CALL (717) 771-9601 SHERIFF SERVICE , ' PRO.CESS FlECEII'r, and AFFIDAVIT OF $ETURN .'" ~ 2. COURT NUMBER _ i> .. 4. PE OF WRIT OR COMPLAINT Reissued Writ of 1.PLAINTIFF/S/, Michael Sheible 3. DEFENDANT/51 Will iam ,,]. ,1ahn i S, ,ER, V"E ,{,..",' ,', 5.', NA,MEOF,INDIVID,~,A,L' COMPANY, co"., RPORAT,ION, ETC. TO S~RVE OR DESC,pPrION OF PROP, ERlYTO BE LEVIED, ATTACHED, OR SOLD. ,~ ,',. ". Cheryl M.~Kin~" '''''''''- . ,,,,, ,,6. ADDRESS (STREIW,OR R 0 WITH BOX NUMBER, APT NO., CllY, BORO, ~ STATE AND ZIP CODE AT , ',', ,;,,, Meadqwb'rpok Cp,urt,New Cumberberland, PA .17070 7: INDICATE SERVICE:Q PERSONAL a ~ERliON INCHARGE XI DEPUTIZq-o..ml'lGlfl1-~\!I a 1 ST CLASS MAIL a POSTED , a OTHER NOW .' ,,:ll? 4 ('l'. . "',, . ,,'l!1---==I, SHEFjII:F OF XiliP;qO!lNJiY,I"A, <!9 herl'bydep!l~lAA'!/.111!lheri" 01, . ',' :, r' . .r"'YOi~' . <' .",.' <""""~"'~<"C"':'_ , C~UNTYto ':Xl!llute \hlsiiilriran(f'tnlike"retLl~n1lle~eolaccording to I~w. This deputation being ma eat thll ,requesl and risk 01 the plaintiff: i,SPECIAC1Ms-mo6TIONs.oR OTHER INFO~ATIONTi:tAT WILL ASSIST IN EXPEDITING SERVICE:' SHE R IFF- 0 F ~~ C 0 U N TY . " ". ',..,. '" 'i,'.,:,:' .,,'" ",.","c_' \ \'- \. Cumberland i ~_ , '. ADVANCE FEE PAID BY CUMBERLl\NDCOUNTY SHERIFF NOTE ONLV'APP:'1;.1CABLE.oN W"IT OF 'EXEC,UTION:. H.B., WAIVER, OF WATCHMAN. Any de;puty, sheiitt'levying upon or attaching any prop,erty under within writ may leave same, without 8' wa.~9nr'lC~n,' i~ custQdy 'of, who":1e\J~r i~ foung hi possession, after notifying person of levy or)lltachmerlt, w~it9-ut liability ,O[bthe,part o!..su-ch deputy or the sheriff to any plaintiff he~in 'ror.'a~Y:,I,o~;.,deStrYC:!\On'-9r r:em9\i'al:of. anYJ)f9perty bef~~'s~eriff's s~!e.thereof. . _" :>~-::,,;, -. ',0- :.:- -~": v'.;'''~.C'' -:~' " 9. TYPE NAMEll.NDA!lli"ESSbl'A:TTORIlEY/DRI$IN~R andSIGIIATIlRE" '~.., __"LEPHONE NUMBER 11. DATE FILED 1/23/01 12. SEND NOTICE OF'SERVlcE COpy TO NAME AND ADDRESS BELOW: (This area must becompleled I' notiee Is to be mail"'l)' , CUMBERLl\ND COUNTY SHER~FF SEE REMARKS 22. REMARKS: I \n 42. day of ,4pV~ 47'~!!'!~;;f/&' ' 48.,Oate 51. Date Received 4. BLUE - Sheriff's Office .... .. ".c. . . """'~, ^,', ,~ ~ '. .-, ,-O-"~ ___, L,,,',,~,,:, OlHB-OOOl8 . " LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendant, William J. Jahn MlCHAEL SHEmLEY, PLAINTIFF IN THE COURT OF COMMON PLEAS CuMBERLAND COUNTY, PENNSYLVANIA vs. No. 2000-8359 CIVIL TERM WILLIAM J. JAHN AND CHERYL M. KING, DEFENDANTS CIVJIL ACTION - LAW JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROmONOTARY: Kindly enter my appearance in the aboye-captioned matter on behalf of the Defendant, William J. Jabn. Respectfully submitted, LAW OFFICES OF JACOBS & By: Donald R. orer, Esquire Attorney for Defendant, William J. Jabn Identification No. 39126 Date: March 1. 2001 eI,=,"J'-- , OIHB-OOOI8 .. , LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendant William J. Jahn MICHAEL SHEmLEY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2000-8359 CIVIL TERM WILLIAM J. JAHN AND CHERYL M. KING, DEFENDANTS CIV\IL ACTION - LAw JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached Entrv of Aooearance to be served by regular first class mail upon: Gregory M. Feather, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 Date: March 1. 2001 Cheryl M. King 104 South Locust Street, Apt. 1 Camp Hill, PA 17011 //\UJ/} , . , " ,/ I.! ,I I , i onald R. Dorer, Esquire Attorney for Defendant, William J. Jahn /V} y ,~." ~,- ,~ 'l&;'M,,: 01HB-00018 ,. t ~ ,\ LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendaut, WiUiam J. Jahn MICHAEL SlIEIBLEY, I'LAINrIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2000-8359 CIVIL TERM WILLIAM J. JAHN AND CHERYL M. KING, DEFENDANTS CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTIIONOTARY: Please enter a RULE upon plaintiff to fIle a Co the entry of a Judgment of Non Pros. ( f or suffer Date: March 1. 2001 Do. Dorer, Esqu' Attorney for Defendant, William J. Jahn RULE TO FILE COMPLAINT AND NOW, this g day of ~. ,2001 a RULE is hereby entered upon the Plaintiff to fIle a Complaint herein within 20 days after service hereof or suffer the entry of a Judgment of Non Pros. p~~J -" , . ,",,-i-_,. ~;. '."~,f'.~- OlHB...oOOl8 '" .. LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendant, William J. Jahn MICHAEL SHEmLEY, PLAINTIFF IN THE COURT OF COMMON PLEAS CuMBERLAND COUNTY, PENNSYLVANIA vs. No. 2000-8359 CIVIL TERM WILLIAM J. JAHN AND CHERYL M. KING, DEFENDANTS CIVIL ACTION - LAw JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached PraeciDe for Rule to File ComDlaint to be served by regular first class mail upon: Gregory M. Feather, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 Cheryl M. King 104 South Locust Street, Apt. 1 Camp Hill, PA 17011 ,/'\/), "A -' ~ Date: March 1. 2001 onald R. Dorer, Esquire Attorney for Defendant, William J. Jalm '--- "- j,; ...... ,. Jeffe.son J. Shipman, Esquire LD. #51785 GOLDBBRG, KATZMAN & SHIPMAN, P.C. 320 Market Street P. O. Box 1268 Harri$burg, PA 17108-1268 (717) 234-4161 Counsel for Defendant, cheryl M. King - '< .-,_";"",",O_~''''C - ;,.'-".-_-_N."'"~,~~~ ~'.' _:.,.~'~" ~;_ "-"""'i..;";c c,,;.,_. ._,: i MICHAEL SHEIBLEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. WILLIAM J. JAHN and CHERYL M. KING, Defendants CIVIL ACTION - LAW NO. 2000-8359 CIVIL JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: PLEASE enter the appearance of the undersigned on behalf of the Defendant, Cheryl M. King, in the above-captioned matter. GOLDBERG, KATZMAN & SHIPMAN, P.C. DATE: April 24, 2001 62271.1 J fe son J. Ship an, Esquire Attorney I.D. 51785 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorneys for Defendant King _;,-_ '.'-_J" ,..-_1-'___ - '" ",'-/-,;,.,~-->" : -,- ~(,,", ,,' , _cO' "_>".'_~_'- r-'__"_~';: _.~ "":-~;;'~,,,:: "",,, ,-,c.",", ~ .. CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served on the following counsel of record, by depositing the same in the United States Mail, postage prepaid, in Harrisburg, Pennsylvania, on April 24, 2001: Gregory M. Feather, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 Attorneys for Plaintiffs Donald R. Dorer, Esquire Law Offices of Jacobs & Saba 214 Senate Avenue, Suite 503 Harrisburg, Pa 17011 Attorneys for Defendant, Jahn GOLDBERG, KATZMAN & SHIPMAN, P.C. Je fe son J. Shi I.D. #: 51785 P.O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendant, King 47022.1 ...,W' i................,........-........~..."'....Ii.i_......_""""'I. """TU"rW,"'" ~"'_ _'C'~___ ~~_,~~~~.~~=~, ~.. ,~ J ,~" "_~_ - " I ' "". ~. '^.~ fl~.~ '''''' ,'" .'"" .~. ., .. - (") 0 C. c: ~Tl s: """ "UFg .." m I" ::u .:0 Z::n r ..~ Ze' N -". ~.,..., (j), l:-- CT\ :..-:,-~~: ~"" __0 -0 ~::;j~: ~O -r.\"" ~i~-~ )>0 ~ ...--~fn c: ',,--.J Z C- v =< 55 0 -< 0' , ..... ' John R. Niposky, Esquire LD. i78000 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Counsel fo~ Defendant, Cheryl M. King " . ~-, - ",,",- ,- >, .<- ,-" '0 -"'-,J .; MICHAEL SHEIBLEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. WILLIAM J. JAHN and CHERYL M. KING, Defendants TO THE PROTHONOTARY: CIVIL ACTION - LAW NO. 2000-8359 CIVIL JURY TRIAL DEMANDED PRAECIPE PLEASE add the appearance of the undersigned on behalf of the Defendant, Cheryl M. King, in the above-captioned matter. DATE: May 8, 2001 62271. 2 GOLDBERG, KATZMAN & SHIPMAN, P.C. By fJ4 ;e(d~ John . Ninosky, Esqu re Attorney I.D. #: 78000 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorneys for Defendant King , ..,.' ",,~,"'A'<I'~ ~ ' '""" . . ... CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served on the following counsel of record, by depositing the same in the United States Mail, postage prepaid, in Harrisburg, Pennsylvania, on May 8, 2001: Gregory M. Feather, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 Attorneys for Plaintiffs Donald R. Dorer, Esquire Law Offices of Jacobs & Saba 214 Senate Avenue, Suite 503 Harrisburg, Pa 17011 Attorneys for Defendant, Jahn 62273.1 GOLDBERG, KATZMAN & SHIPMAN, P.C. By ~ Ild{~ John . Ninosky, Esqu're I.D. #: 78000 P.O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendant, King I;:"'J"~ "C""oF"d :r-~ ,'" ""'.,"__ '", , ~~'''' 'k",i..'->"',.."', ~y. "~,. ..~." ~"o--/t,;_._,,- ~ "",'1':.<0 '~'riil;...~IiIII'.... .- ,. ..c., ""',o_-':-~ "c __",~.,,~j, ,- '~,'/" 'c"-"""'m"'-"'- " ""."-,-,,," ,', '" r ." v.~. ^" o c -oft ~~-~ ~c; :>c, ~(~ )>~ =< ^' ~~,"'" ~ , - C) ~:; ..- ..".. .--j ~ ! \..0 '.,' ["J ''0 (,.) oJ - ,.. ~-~ "'~' ~- < ~ ,,"..,.,. ,~.-'.' ,-.'" MICHAEL SHEIBLEY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, NO. 00-8359 v. WILLIAM J. JAHN and CHERYL M. KING CIVIL ACTION - LAW JURY TRIAL DEMANDED Defendants NOTICE 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. DATE: <j/lr/o/ Attorneys for Plaintiff ~-- ~-<--', --,- ,--->-,...-~"., -,_,. '--'.<" ~. ."',,-_ " ,_ """_,',c.__i,_<,~;t_,"."",,,,r;;;_''-'G '--"C".",. "--""'ifi_i kas/compla i nVmva/sh eibley. wpd MICHAEL SHEIBLEY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, NO. 00-8359 v. WILLIAM J. JAHN and CHERYL M. KING CIVIL ACTION - LAW JURY TRIAL DEMANDED Defendants COMPLAINT AND NOW, comes the Plaintiff, Michael Sheibley, by and through his attorneys, HANDLER, HENNING, & ROSENBERG, by Gregory M. Feather, Esq., and makes the within Complaint against the Defendants, William J. Jahn and Cheryl M. King, as follows: 1. Plaintiff, Michael Sheibley, is an adult individual currently residing at 53 Meadowbrook Court, New Cumberland, York County, PA 17070. 2. Defendant, William J. Jahn , is an adult individual currently residing at 23 Hunt Street, Fort Bragg, North Carolina 28307. 3. Defendant, Cheryl M. King, is an adult individual currently residing at 57 Meadowbrook Court, New Cumberland, York County, PA 17070. 4. At all times material hereto, Defendant, William J. Jahn, was the operator of 1998 Ford Expedition bearing Pennsylvania registration number BLD0207. 5. At all times material hereto, Defendant, Cheryl King, was the owner and operator of 1990 Chevrolet Cavalier bearing Pennsylvania registration number BCV6401. 1 '" ~^^ , "< "-0 ",00' ,", ^' ."'-, ~,~",-,.,,~-, C"'""..' "~"-"~"-,,,,, _';-!!!bX;.c""~''':''''1:'.'_' _ ",i.'o1',,,,.,,,:;;'i 6. At all times material hereto, Plaintiff, Michael Sheibley, was a passenger in Cheryl King's vehicle, which was insured by State Farm Insurance Company under whose motor vehicle insurance policy the Plaintiff was covered by the full-tort option. 7, On or about December 5, 1998 at about 8:45 pm, Defendant Jahn was traveling northbound on Sporting Hill Road. Defendant Jahn came to a stop, so he could back into a private driveway. 8. At approximately that same time and place, Defendant King was traveling northbound on Sporting Hill Road. Defendant King did not see Defendant Jahn until it was too late to avoid the collision. 9. Defendant King struck the left front of Defendant Jahn's vehicle with the right front of her vehicle. 10. As a direct and proximate result of the negligence of the Defendants,the Plaintiff sustained extensive injuries as set forth more specifically below. COUNT I MICHAEL SHEIBLEY V. WILLIAM J. JAHN NEGLlGENCIE 11. Paragraphs 1-10 are incorporated herein as if set forth at length. 12. The occurrence of the aforementioned collision and all the resultant injuries to Plaintiff, Michael Sheibley, are the direct and proximate result of the negligence, carelessness, and/or recklessness of the Defendant, William J. Jahn, generally and more specifically as set forth below: 2 1" ; c<r -- ,,"~ <" , .' "'",.,.,:;,-~ '" ,- ,-,__"-~, ' .. '~d,V--J-_;':;";''c;;".~,,-~; ",,'/- (a) In failing to be reasonably vigilant to observe the roadway and the position of Plaintiff's vehicle; (b) In failing to operate his vehicle under proper and adequate control so that he could have avoided Plaintiff's vehicle; (c) In disregarding the speed of vehicles, the condition of the highway, and the traffic upon the highway, in violation of 75 Pa. C.SA S 3310; (d) In failing to maintain proper and adequate observation of the existing traffic conditions; (e) In failing to keep a proper lookout for vehicles lawfully on Sporting Hill Road; (f) In failing to exercise reasonable care in the operation and control of his vehicle, in violation of 75 Pa.C.SA S 3714; (g) In failing to be continuously alert, in failing to perceive any warning of danger that was reasonably likely to exist, and in failing to have his vehicle under such control that injury to persons or property could be avoided; and (h) In driving his vehicle upon the highway in a manner endangering persons and property and in a manner with careless disregard to the rights and safety of others in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 13. As a direct and proximate result of the negligence of the Defendant, William J. Jahn, the Plaintiff, Michael Sheibley, has suffered extensive and serious personal injuries, including, but not limited to, injuries to his right knee, head, and right eye. Surgical intervention was required to repair the eye injury. 3 ,""-"" '"^ ~,' .",^, ,- ~' c .' ," ~:--"" - .,'"""~,,,.,, 14. As a result of the negligence of Defendant, William J. Jahn, the Plaintiff, Michael Sheibley, has suffered lost wageslincome and will in the future continue to suffer a loss of income and/or loss of earning capacity. 15. As a result of the negligence of Defendant, William J. Jahn, the Plaintiff, Michael Sheibley, has suffered great physical pain, discomfort, and mental anguish, and he will continue to endure the same for an indefinite period of time in the future, to his great physical, emotional, and financial detriment and loss. 16. As a result of the negligence of Defendant, William J. Jahn, the Plaintiff, Michael Sheibley, has been compelled, in order to effect a cure for aforesaid injuries, to expend large sums of money for medicine and/or medical attention, and will be required to expend money for the same purposes in the future, to his great detriment and loss. 17. As a result of the negligence of Defendant, William J. Jahn, the Plaintiff, Michael Sheibley, has suffered a loss of life's pleasures, and he will continue to suffer the same in the future, to his great detriment and loss. 18. As a result of negligence of Defendant, William J. Jahn, the Plaintiff, Michael Sheibley, has been, and probably will in the future be, hindered from attending to his daily duties, to his great detriment, loss, humiliation, and embarrassment. 19. Plaintiff, Michael Sheibley, believes and, therefore, avers that his injuries are permanent in nature. WHEREFORE, Plaintiff, Michael Sheibley, seeks damages from Defendant, William J. Jahn, in an amount in excess of twenty-five thousand dollars ($25,000.00) exclusive of interest and costs, and demands a trial by jury. 4 - ~~~ -- >, ,,- '" -' ~' -C.,"" __e ~, '..J ". ,", ," _~"i:- ~' ; ,"_' l' "l;, ";A>"-,,,~,--,,,, " _ ", c''.----',''_"'', COUNT II MICHAEL SHEIBLEY V. CHERYL M. KING NEGLIGENCE 20. Paragraphs 1-19 are incorporated herein as if set forth at length. 21. The occurrence of the aforementioned collision and all the resultant injuries to Plaintiff, Michael Sheibley, are the direct and proximate result of the negiigence, carelessness, and/or recklessness of the Defendant, Cheryl M. King, generally and more specifically as set forth below: (a) In failing to operate her vehicle in such a manner that would allow her to apply the brakes and stop before striking Defendant Jahn's vehicle; (b) In failing to operate her vehicle under proper and adequate control so that she could have avoided striking Defendant Jahn's vehicle; (c) In disregarding the speed of vehicles, the condition of the highway, and the traffic upon the highway, in violation of 75 Pa. C.S.A. S 3310; (d) In failing to regulate the speed of her vehicle so as to prevent the collision; (e) In failing to operate her vehicle at a speed at which she could stop within the assured clear distance ahead, in violation of 75 Pa. C.S.A. S 3361; (f) In failing to maintain proper and adequate observation of the existing traffic conditions; (g) In failing to keep a proper lookout for vehicles lawfully on Sporting Hill Road; (h) In failing to exercise reasonable care in the operation and control of her vehicle, in violation of 75 Pa. C.S.A. S 3714; 5 ? ,~ < ,-. . ,'. ~~~ '<, -~.=. '-- ~ ' <- ,,'~- -" -' 0' "TI'j (i) In failing to be continuously alert, in failing to perceive any warning of danger that was reasonably likely to exist, and in failing to have her vehicle under such control that injury to persons or property could be avoided; and (j) In driving his vehicle upon the highway in a manner endangering persons and property and in a manner with careless disregard to the rights and safety of others in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 22. As a direct and proximate result of the negligence of the Defendant, Cheryl M. King, the Plaintiff, Michael Sheibley, has suffered extensive and serious personal injuries, including, but not limited to, injuries to his right knee, head, and right eye. Surgical intervention was required to repair the eye injury. 23. As a result of the negligence of Defendant, Cheryl M. King, the Plaintiff, Michael Sheibley, has suffered lost wages/income and will in the future continue to suffer a loss of income and/or loss of earning capacity. 24. As a result of the negligence of Defendant, Cheryl M. King, the Plaintiff, Michael Sheibley, has suffered great physical pain, discomfort, and mental anguish, and he will continue to endure the same for an indefinite period of time in the future, to his great physical, emotional, and financial detriment and loss. 25. As a result of the negligence of Defendant, Cheryl M. King, the Plaintiff, Michael Sheibley, has been compelled, in order to effect a cure for aforesaid injuries, to expend large sums of money for medicine and/or medical attention, and will be required to expend money for the same purposes in the future, to his great detriment and loss. 6 .. _'.' ~", _,_, ... _._ ,'~_ _,"__ w_ - ,-", ,- -~- 26. As a result of the negligence of Defendant, Cheryl M. King, the Plaintiff, Michael Sheibley, has suffered a loss of life's pleasures, and he will continue to suffer the same in the future, to his great detriment and loss. 27. As a result of negligence of Defendant, Cheryl M. King, the Plaintiff, Michael Sheibley, has been, and probably will in the future be, hindered from attending to his daily duties, to his great detriment, loss, humiliation, and embarrassment. 28. Plaintiff, Michael Sheibley, believes and, therefore, avers that his injuries are permanent in nature. WHEREFORE, Plaintiff, Michael Sheibley, seeks damages from Defendant, Cheryl M. King, in an amount in excess of twenty-five thousand dollars ($25,000.00) exclusive of interest and costs, and demands a trial by jury. HANDLER, HENNING & ROSENBERG Date: S /; f//; I , By: C~q~/U ~~ Gregory M. Feather, Esq. '7';1-/ Attorney 1.0. # 79456 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Attorneys for Plaintiff 7 '," , .' ".<' ~,' 'A_' . . " '__';.~w"_ ,4,',", ,"",,:;' '~'"o-. _', ~",>i.'>"'""'- '_;;'-,i;id.,,-.iI'A~-ii;,;o";.>,-;,":"- '-;"".. -- '<4.' _:':' ,_" CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was served on the Defendants, WilLIAM J. JAHN and CHERYL M. KING, by sending a copy of the same, by United States Mail, regular service, in Harrisburg, Pennsylvania on May li, 2001, to their counsel of record, as follows: Donald R. Dorer, Esq. 214 Senate Ave., Ste. 503 Camp Hill, PA 17011 Attorneys for Defendant William J. Jahn Michael E. Kosik, Esq. 4503 N. Front St. Harrisburg, PA 17110 Attorneys for Defendant Cheryl King ERG DATE: frlol By Gre 0 y . Fer, Esq. At r y 1.0. # 79456 P. . Box 1177 Harrisburg, PA 17108 (717) 238-2000 Attorneys for Plaintiff -, '~~' " - _'_"',~'~"M' .'," "" ':.""vO",'.."'""'.,'____.~'_...-"",","''''~ _ c;_ ~ VERIFICATION PURSUANT TO Pa. R.C.P. No. l024(c) GREGORY M. FEATHER, ESQ. states that he is the attorney for the party filing the foregoing document; that he makes this Complaint as an attorney and verifies that it is correct and accurate to the best of his knowledge, information and belief and that this statement is made subject to the penalties of 18 Pa. C.SA., Section 4904 relating to unsworn falsification to authorities. DATE: ~ ~~ ,0" .,n. ."',,( -='_~"~'=~_'~"__"'~,,, __,,__ __<';:'" CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was served on the Defendants, WilLIAM J. JAHN and CHERYL M. KING, by sending a copy of the same, by United States Mail, regular service, in Harrisburg, Pennsylvania on May _' 2001, to their counsel of record, as follows: Donald R. Dorer, Esq. 214 Senate Ave., Ste. 503 Camp Hill, PA 17011 Attorneys for Defendant William J. Jahn John R. Ninosky, Esq. GOLDBERG, KATZMAN & SHIPMAN, P.C. 320-E Market St. Harrisburg, PA 17101 Attorneys for Defendant Cheryl King DATE: 5!~1 HAN~~NIN .:::> - ~'.- "' "^~ ~ 'O~_'~C,&""_ ;="""': MICHAEL SHEIBLEY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, NO. 00-8359 v. WILLIAM J. JAHN and CHERYL M. KING CIVIL ACTION - LAW JURY TRIAL DEMANDED Defendants PRAECIPE TO THE PROTHONOTARY: Please mark the above-captioned matter settled and dismissed with prejudice. Respectfully submitted, Date: 4 -IS-ell By: ego . Feather, Esquire D. . 79456 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Attorney for Plaintiff - "','~""..,' 'm."."'~ ,'O__'''~ '_'~,,," '-'~'~'-""'"__hC_,,_ ,,,-,,' ,",__,,_/- 'j CERTIFICATE OF SERVICE AND NOW, this ~ day of June, 2001, I hereby certify that I have, on this date, served the within document upon the Defendant, by sending a true and correct copy of same to his attorney of record, and including a copy to all parties of interest via first class United States mail, postage prepaid, and addressed as follows: Donald R. Dorer, Esquire 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 John Ninosky, Esquire Goldberg, Katzman & Shipman, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 HANDLER, HENNING & ROSENBERG By: Pd...r'(:"~'5h"OCJ Patricia Kohn in