HomeMy WebLinkAbout00-08733
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HARRY D. GOOD and
ANNA M. GOOD,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
v.
NO. 00-;>133 CIVIL TERM
ROBERT M. WHITE,
Defendant
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 A LAWYER AT ONCE.
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
THE OFFICE SET FORTH BELOW TO FIND OUR WHERE YOU
LEGAL HELP.
IF YOU DO
TELEPHONE
CAN GET
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Telephone:
(717) 249-3166
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HARRY D. GOOD and
ANNA M. GOOD,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
v.
NO. 00- Y'733 CIVIL TERM
ROBERT M. WHITE,
Defendant
COMPLAINT
AND NOW, come the Plaintiffs, Harry D. Good and Anna M.
Good, by their attorneys, Addams & Rundle, and make the following
complaint:
1. The Plaintiffs are Harry D. Good and Anna M. Good,
adult individuals residing at 604 N. Middle Road, Newville,
Cumberland County, PA 17241.
2. The Defendant is Robert M. White, an adult individual
residing at 390 Stonehouse Road, Carlisle, Cumberland County, PA
17013 .
3. On June 20, 2000, the Plaintiffs were the owners of a
1991 Jeep Cherokee which, at about 6:30 p.m. was being operated
by Anna Marie Good traveling South on Stonehouse Road approaching
the intersection with Mooredale Drive.
4. At said time and place, the Defendant was driving a 1987
Ford F250 truck owned by Cheryl A. Funk, westbound on Mooredale
Drive, which is controlled by a stop sign.
5. The Defendant negligently and carelessly failed to stop
or remain stopped for the stop sign and entered the intersection
causing a collision with the Plaintiffs' vehicle resulting in the
damages hereinafter set forth.
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6. The Defendant was negligent and careless in:
A. Failing to obey the stop sign.
B. Failing to yield the right of way.
C. Failing to observe the Plaintiffs' vehicle in time
to avoid a collision.
D. Failing to have his vehicle under control.
7. As a result of the negligence and carelessness of the
Defendant, the Plaintiffs' vehicle was rendered a total loss.
The vehicle had an actual cash value of $5,223.56 and a net
salvage value of $47.50 resulting in a loss in the amount of
$5,176.06.
8. In addition, the Plaintiffs incurred rental expense of
$600, and Anna Marie Good sustained bodily injury and is
subrogated to her insurance carrier in the amount of $250.
WHEREFORE, the Plaintiffs demand judgment against the
Defendant in the amount of $6,026.06, plus interest and costs of
suit, an amount within the jurisdiction of arbitration under the
local rules of court.
ADDAMS & RUNDLE
By:
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Willi . Addams
Supreme Court I.D. No. 06265
28 South Pitt Street
Carlisle, PA 17013
(717) 249-8300
Attorneys for Plaintiffs
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VERIFICATION
Harry D. Good and Anna M. Good hereby verify that the facts
set forth in the foregoing Complaint are true and correct to the
best of their knowledge, information and belief, and understand
that false statements herein are made subject to the penalties of
18 Pa. C.S. ~4904 relating to unsworn falsifications.
DATE: 1;f'tPd
,d,rtJ;2 Ft.".,e
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SHERIFF'S RETURN - REGULAR
/
CASE NO: 2000-08733 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GOOD HARRY D ET AL
VS
WHITE ROBERT M
WILLIAM DIEHL
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
WHITE ROBERT M the
DEFENDANT , at 0015:34 HOURS, on the 29th day of Dec~mber , 2000
at 390 STONEHOUSE RD.
CARLISLE, PA 17013
by handing to
ROBERT M. WHITE
a true and attested copy of COMPLAINT,& NOTICE
together with
.
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
4.34
.00
10.00
.00
32.34
So Answers:
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R. Thomas Kline
01/02/2001
ADDAMS & RUNDLE
Sworn and Subscribed to before
By:
1\
me this 3AAC.. day of
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~prothonotary
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HARRY D. GOOD and
ANNA M. GOOD,
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-8733 CIVIL TERM
ROBERT M. WHITE,
Defendant
PRAECIPE
Sir:
Please mark this action settled and discontinued.
ADDAMS & RUNDLE
By:
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Willia A. Addams
Supreme Court I.D. No. 06265
28 South Pitt Street
Carlisle, PA 17013
(717) 249-8300
Attorneys for Plaintiffs
TO: Curtis R. Long, Prothonotary
DATE: March 7, 2001
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MAR 0 6 ZOOI~
JULIE A. BANKES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
CIVIL ACTION - LAW
ROBERT E. BANKES,
Defendant
NO. 00 - 8833 CIVIL
IN CUSTODY
COURT ORDER
AND NOW, this )J day of March, 2001, after the Conciliator being advised that the parties
have reached an agreement, the Conciliator relinquishes jurisdiction.
BY THE COURT,
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01 MAR -8 PH 12: 54
CUMBERLAND COUN1Y
PENNSYLVANIA
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