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Home My WebLink About01-0247 FX .', ' , I" ",' ' 'h:' -. ';":',~ .,'::: . ." .' IN THE COURT OF COMMON PLEAS OFCUMBERLmleUNTY, PENNSYLVANIA ..~' . CIVIL DIVISION 'FileNo. 01-247 Civil Term PRAECIPE ,FOR JUDGMENT TO THE PROTHONOTARY OF SAID COURT: Enter Judgment in favor of Plaintiff~land against: Defendant Robert A. Wancho fur want of failure to answer compLaint ( X) Assess damages as follows: Debt-----------------'-------'-----------'------------ $ 12,976.79 Interest from -------- A tto rney' s Com miss io n,--------------------------'--- TOT A L ---______,.,,______,___________,_______________ $ 12, 976 . 79 ( X) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain for the complaint. ( X) Pursuant to Pa.R.C.P. 237 (notice of praecipe, for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. ( x) Pursuant to Pa.R.C.P. 237.1, I certify that written notice of the intent to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occurred and at st ten days rior to the date of the filing of this praecipe and a copy' of the notice is attached. DATE: 'r/zJ;;1... Signature: Print Na . L. Attorne. for: P1a' 1ffs Address: P.O. Box 1995 A11ent01m, PA Telephone: (610) 437-5001 Supreme Court ID No.: 68774 nston, Jr., Esquire 18105-1995 NOW, "'- JL.lA.)~ ;L 7 ,'VI.266:t. ,JUDGMENT IS ENTERED AS ABOVE. '\ (Rev.4/97) ,--_By: .40.-,. (J _P 7fC/(/J<"rrl>-) Deputy '!:;1ll!;~ ,.... ---r< '? . -,';'j!G ~~ , < ..' ,," ,,'-- ~ " L. Paul Johnston, Jr., Esquire Attorney I.D. No. 68774 1144 West Hamilton St., P.O. Box 1995 Allentown, PA 18105-1995 (610) 437-5001 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW NICOLE YEAGER and NATIONWIDE INSURANCE COMPANY, as subrogee No.: 01-247 Civil Term of plaintiff Nicole Yeager, Plaintiffs, vs. ROBERT A. W~-NCHO and DEBRA WANCHO, May 15, 2002 Defendants. TO DEFENDANT ROBERT A. WANCHO: IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 170 800-990-9108 P OHNSTON, JR., ESQUIRE .' .~, -, "~, t,,"; I -, '-' ..~, .; :. ", " :,"" .'_. ' -~' . IN THE COURT OF COMMON PLEAS OFCUMBERLAOOUNTY. PENNSYLVANIA CIVIL DIVISION NICOLE YEAGER and NATIONWIDE INSURANCE COMPANY, as subrogee of Plaintiff N~COLE YEAGER, Plaintiff(s) vs. File No. 131-247 civil Term ROBERT A. WANCHO and DEBRA WANCHO, : NOTICE OF FILING JUDGMENT Defendant(s): ( X) Notice is hereby given that a Judament in the above captioned matter has been entered against you in the amount of $12,976.79 onJ~L ~,7 .ICCJ2002 ( X) A copy of all documents filed with the Prothonotary in support of the within judgment is/are enclosed. By: If you have any questions regarding this Notice, please contact the filing party: NAME: L. PAUL JOHNSTON, JR., ESQUIRE ADDRESS: P.O. Box 1995 Allentown, PA 18105-1995 TELEPHONE NO. (610) 437-5001 (This Notice is give in accordance with Pa.R.C.P. ~ 236.) ,-.-- -I " , I' ~ ",~ ~ .. ^ --. ,-,,0--. -- "'~'"L h'__'.' ,"f "'-"l<<''' "--, ',.1":< --,~, "r--.'d:-'>(;,~ .",,,,C_, ";''---'''k''hS:.iJ'--''''''--'''''''''"~r"flTilli''''jlrfhlIt''~""J"::""Y'f . .. t 7V (::) .lq. ft:- 'i :-G 't ~ B () C) 0 ~ - C :",..) f - -. ,'J ~ ~ ~l '--- ~::-i --V -,il , f'; ;~,~-~~ L, \'- r Z:l~; "'''- -0 zr--' 1,-> :-J J ~ 2i?2: -'7'...~ .-.1 .-....' '~.- 1- ~~:' -0 '~":::(~) IJ 1- -,. -..t: _fu. ~5.~1;j ):o:E! -,71..,.,1 f; ;..;) (~5n-1 Z ....-1 -;J N :> :0 -, -< 1 .",~., .,,_,,_" ~ 1!l9~~'!;,~".di)l._4;1'$~~ _, =.Q!f~1I11I'!rm'!'!'}'!'r.'j'Ij;_"'''0E'~~''''11:\';~r';-~';'_'"'--'''''J''',";'NH"!;j~"fli/'M"'",,_W'1ljt->~I.\j'*,;<'!{'-':'I'*-1<-~"li:f(,Mi''*f<lM~..~~, ,,~ ,j COMPLAINT - CIVIL ACTION L. PAUL JOHNSTON, JR., ESQUIRE P.O. BOX 1995 ALLENTOWN, PA 18105-1995 Attorney J.D. # 68774 (610) 437,5001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NICOLE YEAGER 137 Joya Circle Harrisburg, Pennsylvania 17112, and c::...- NATIONWIDE INSURANCE No.: 01- :l47 CtcA "l~ P.O. Box 2655 Harrisburg, Pennsylvania 17105-2655 as subrogee of Plaintiff Nicole Yeager, Plaintiff, vs. ROBERT A. W ANCHO 335 Cartref Road Etters, Pennsylvania 17319, and DEBRA WANCHO 335 Cartref Road Etters, Pennsylvania 17319 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 an 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 that 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY A VENUE CARLISLE. PA 17013 (717) 249-3166 800-990,9108 I v " ,j COMPLAINT - CIVIL ACTION L PAUL JOHNSTON, JR., ESQUIRE P.O. BOX 1995 ALLENTOWN, PA 18105,1995 Attorney I.D. # 68774 (610) 437-5001 i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NICOLE YEAGER 137 Joya Circle Harrisburg, Pennsylvania 17112, and NATIONWIDE INSURANCE No.: CJI- :L'I7 ~ y~ P.O. Box 2655 Harrisburg, Pennsylvania 17105-2655 as subrogee of Plaintiff Nicole Yeager, Plaintiff, vs. ROBERT A. W ANCHO 335 Cartref Road Etters, Pennsylvania 17319, and DEBRA W ANCHO 335 Cartref Road Etters, Pennsylvania 17319 Defendants. COMPLAINT NOW COME the Plaintiffs, by and through their attorney, L Paul Johnston, Jr., and bring this civil action against the Defendants, Robert A. Wancho, and Debra Wancho, upon a cause of action whereof the following is a statement: 1. Plaintiff Nicole Yeager is an adult individual residing at 137 Joya Circle, Harrisburg, Dauphin County, Pennsylvania 17112. (Hereinafter "Plaintiff Yeager") 2. Plaintiff Nationwide Insurance, with a principal place of business at P.O. Box 2655 Harrisburg, Pennsylvania 17105-2655, is registered with the Pennsylvania Insurance Department to do business in Pennsylvania, providing insurance coverage for a variety of different risks. (Hereinafter "Plaintiff Nationwide") 3. Defendant Robert A. Wancho is an adult individual residing at 335 ':~J:I .. A.ijjf ~"'1 'I Ii Cartref Road, Etters, York County, Pennsylvania 17319. (Hereinafter "Defendant Robert Wancho") 4. Defendant Debra Wancho is an adult individual residing at 335 Cartref III Road, Etters, York Connty, Pennsylvania 17319. (Hereinafter "Defendant Debra Wancho") l' 5. Plaintiff Nationwide brings this action as subrogee of Plaintiff Yeager, pursuant to its right of subrogation as contained in a motor vehicle liability policy issued to Plaintiff Yeager, which, at all times relevant hereto, was in full force and effect, and also pursuant to other writings and releases between the Plaintiffs, and also pursuant to Pennsylvania law. 6. On or about AprilS, 1999, at or about 5:13 PM Plaintiff Yeager was the owner and operator of a 1992 Honda Civic motor vehicle which was traveling west on Wertzville Road, near the intersection with Pine Hill Road, in East Pennsboro Township, Cumberland County. (Hereinafter "the Yeager vehicle") 7. At the date and time aforesaid, Defendant Debra Wancho was the owner of a 1989 Plymouth Voyager SE motor vehicle, which was being operated by Defendant Robert Wancho with the permission and authority of Defendant Debra Wancho and which was traveling east on Wertzville Road near the intersection with Pine Hill Road in East Pennsboro Township, Cumberland Connty. (Hereinafter "the Wancho vehicle") l 8. As Plaintiff Yeager operated the Yeager vehicle, legally and with due and proper care, Defendant Robert Wancho operated the Wancho vehicle in such a negligent and careless manner that he crossed the center line on Wertzville Road near the intersection with Pine Hill Road in East Pennsboro Township, Cumberland County and impacted with the Yeager vehicle, causing damages as are hereinafter more fully set forth. f~"''''t:.I (J,"l) . " ..~, l F':~" '1 ,~ 9. The collision set forth above and the resulting damages were caused in no manner by any act or failure to act on the Plaintiffs' behalf. 10. At the date and time said collision took place, Defendant Robert A. Wancho was an uninsured driver as is defmed in the Motor Vehicle Financial Responsibility Law as is codified in 75 Pac C.S.A. COUNT IS NICOLE YEAGER AND NATIONWIDE INSURANCE AS SUBROGEE OF PLAINTIFF NICOLE YEAGER VS. ROBERT A. W ANCHO 11. Plaintiffs hereby incorporate by reference paragraphs 1-10 of the within Complaint as if the same were more fully set forth at length herein. 12. The said negligence and carelessness of Defendant Robert A. Wancho consisted of: A) Operating the Wancho vehicle at an excessive rate of speed under the circumstances; B) Failing to maintain the Wancho vehicle under proper and adequate control; C) Failing to maintain an adequate and proper lookout for the legally proceeding Yeager vehicle; D) Failing to keep the Wancho vehicle in its designated lane of travel; E) Failing to give due regard to the rights. safety, and position of other users of the public streets, highways, and intersections; F) Being otherwise negligent; G) Otherwise, violating the laws of the Commonwealth of Pennsylvania relative to the operation and control of motor vehicles. 13. Solely as a result of the aforesaid collision, caused by the negligence and '~~~ ~ ~~ ~. 1tI!lIml" [,,"_, .--1.' .'--- ""~l~ ~". '~~ ....1 ,; carelessness of Defendant Robert A. Wancho, the Yeager vehicle was damaged, the repair of which cost the Plaintiffs the sum of $4,976.79, which Plaintiffs now claim as damages. WHEREFORE, the Plaintiffs hereby demand of the Defendant Robert A. Wancho, the sum of $4,976.79, together with interest and costs and such other further relief as this Court may deem necessary and appropriate. COUNT IB NICOLE YEAGER AND NATIONWIDE INSURANCE AS SUBROGEE OF PLAINTIFF NICOLE YEAGER VS. ROBERT A. W ANCHO 14. Plaintiffs hereby incorporate by reference paragraphs 1-13 of the within Complaint as if the same were more fully set forth at length herein. 15. As a direct, legal, proximate and efficient result of the aforementioned collision, Plaintiff Yeager suffered personal injuries, some or all of which may be permanent in nature. 16. As a further direct, legal, proximate, and efficient result of the aforementioned collision, Plaintiff Yeager suffered bodily pain and suffering, and mental nervousness and anxiety. 17. As a further direct, legal, proximate, and efficient result of the aforementioned collision, Plaintiff Yeager incurred medical bills and expenses, and may require further treatment for the injuries. 18. As a further direct, legal, proximate, and efficient result of the aforementioned collision, Plaintiff Yeager suffered an interruption of usual occupation and daily pursuits, and a loss of earnings and/or earning capacity. 19. Plaintiff Nationwide is now entitled to collect from Defendant Robert ,~oy _ T ---;> ~ ~~ Ij Wancho all payments, judgments and/or settlements of any kind made to Plaintiff Yeager pursuant to the uninsured/underinsured motorist provisions of the above-referenced policy with Plaintiff Yeager due to Plaintiff Nationwide's status as subrogee of Plaintiff Yeager. II ,I $8,000, which Plaintiff Nationwide now claims as damages. 20. Plaintiff Nationwide has, in fact paid to Nicole Yeager the sum of :1 'I WHEREFORE, the Plaintiffs hereby demand of the Defendant Robert Wancho, I i the sum of $8,000, together with interest and costs and such other further relief as this Court I may deem necessary and appropriate. COUNT IIA NICOLE YEAGER AND NATIONWIDE INSURANCE AS SUBROGEE OF PLAINTIFFS NICOLE YEAGER VS. DEBRA W ANCHO 21. Plaintiffs hereby incorporate by reference paragraphs 1-20 of the within Complaint as if the same were more fully set forth at length herein. 22. The said negligence and carelessness of the Defendant Debra Wancho consisted of: A) Negligently entrusting the Wancho vehicle to Defendant Robert A. Wancho when Defendant Debra Wancho knew or reasonably should have known that Defendant Robert A. Wancho was incapable of safely and carefully operating same, and specifically knowing that Defendant Robert A. Wancho had a propensity to commit the same negligent acts described in this Complaint; B) Negligently supervising Defendant Robert A. Wancho, as Defendant Robert A. Wancho was an agent, employee, or servant of Defendant Debra Wancho acting in the furtherance of the duties of said position. 23. Solely as a result of the aforesaid collision. caused by the negligence and carelessness of Defendant Debra Wancho, the Yeager vehicle was damaged, the repair of I,~- ~;'P'-~."" " 'n,' I,,,,, , ,~, . ~~~ -~~"~" . ,; which cost the Plaintiffs the sum of $4,976.79. WHEREFORE, the Plaintiffs hereby demand of the Defendant Debra Wancho, the sum of $4,976.79, together with interest and costs and such other further relief as this II Court may deem necessary and appropriate. COUNT lIB i NICOLE YEAGER AND NATIONWIDE INSURANCE AS SUBROGEE OF PLAINTIFFS NICOLE YEAGER VS. DEBRA W ANCHO 24. Plaintiffs hereby incorporate by reference paragraphs 1,23 of the within i Complaint as if the same were more fully set forth at length herein. 25. As a direct, legal, proximate and efficient result of the aforementioned collision, Plaintiff Yeager suffered personal injuries, some or all of which may be permanent in nature. 26. As a further direct, legal, proximate, and efficient result of the aforementioned collision, Plaintiff Yeager suffered bodily pain and suffering, and mental nervousness and anxiety. 27. As a further direct, legal, proximate, and efficient result of the aforementioned collision, incurred medical bills and expenses, and may require further treatment for the injuries. 28. As a further direct, legal, proximate. and efficient result of the aforementioned collision, suffered an interruption of usual occupation and daily pursuits, and a loss of earnings and/or earning capacity. 29. Plaintiff Nationwide is now entitled to collect from Defendant Debra Wancho all payments, judgments and/or settlements of any kind made to Plaintiff Yeager ,t~ 11 _. ,_ , 'I J' ~ --, - 1~ Ii pursuant to the uninsured/underinsured motorist provisions of the above-referenced policy with Plaintiff Yeager due to Plaintiff Nationwide's status as subrogee of Plaintiff Yeager. 30. Plaintiff Nationwide has, in fact paid to Nicole Yeager the sum of ! $8,000, which Plaintiff Nationwide now claims as damages. WHEREFORE, the hereby demand of the Defendant Robert A. Wancho, the sum of $8,000, together with interest and costs and such other further relief as this Court may deem necessary and appropriate. BY J HNS N, JR., ESQUIRE Y for amtiffs Attorney J.D. No.: 68774 P.O. Box 1995 Allentown, PA 18105,1995 (610) 437,5001 i~~ lil_. '1""-'-- I~ " AFFIDA VIT COMMONWEALTH OF PENNSYLVANIA SS.: COUNTY OF CUMBERLAND I, L. PAUL JOHNSTON, JR., ESQUIRE, being duly sworn according to law, depose and state I am the attorney for the Plaintiffs, and that I make this Affidavit on their behalf. and that the facts set forth in the foregoing are true and correct to the best of counsel's knowledge, information and belief. This verification is made pursuant to Pa.R.C.P. 1024 and is based on interviews, conferences, reports, records and other investigatory materials in the file. This verification was executed by Plaintiffs' counsel due to Plaintiffs unavailability to appear in Plaintiffs' counsel's office in the time required for filing, and can be replaced with a verification executed by the actual Plaintiffs upon written requesL SWORN TO AND SUBSCRIBED before me this g th day ~~-j;(j)9u~ Notary Public T My Commission Expires: ~D=~~="l _on, llll1Igh County MY COmrTW1lSlon E):pires AfJf. 15, 20ft.? i "".ffiii'ibill', PllMSY~;a,iiil~M\~;;w,1ii$ N5T , JR., ESQUIRE . No. 774 1144 W. . on 5L, P.O. Box 1995 Allentown, PA 18105-1995 (610) 437,5001 r~~ ", .- ~'1 "-'<-1--' -, 6~' I ":" ~~ l.( l'jIml ~ ~~:,,~.l,IDMf' '~ J' J ,~""'~""""-'~"'-~' <i~ - C) -0 Y - ~ ~ -G9- ..!:: .~ C3 :Lfi? ~1- ~ ',"~ ,,", I',~,. -tQ ~~ ~0 ,- ""~~-", ~ ~jt,' ~J~; \ ~ ~:>".' " .,:':-..-, )> n " ~ ~;;. -< --il , , .. '.'-' (:....' ~ _i., ---<" !II!\. .,..,,''''Wi'''UI$R'''',-~,~'''''','';,i''''''lI''~\'''''l1\'",H;'~J'!1;lIWi;lli"lR~~[,!i,,;r't*",,,~1ll-i'i~_~,$ " !i!/lQl.,~~,g,""'':'F_ 1l<f1mlll..".~", '""T" ~~ , , SHERIFF'S RETURN - OUT OF COUNTY . CASE NO: 2001,00247 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND YEAGER NICOLE ET AL VS WANCHO ROBER1' A 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: WANCHO ROBER1' A but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania, to serve the within COMPLAINT & NOTICE On January 25th , 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 39.04 .00 76.04 01/25/2001 L. PAUL JOHNSTON, ~~ R Thomas Kl i, Sheriff of Cumberland County JR Sworn and subscribed to before me this lid- day of j~ ~I A.D. ~ (l ~,eO. . 1l~4; prothonotaiy """'>l""'~W ~ c "1'" " ~ ~~ ~. ,~. SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2001-00247 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND YEAGER NICOLE ET AL VS WANCHO ROBERT A 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: WANCHO DEBRA but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania, to serve the within COMPLAINT & NOTICE On January 25th , 2001 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing Out of county Surcharge 6.00 .00 10.00 .00 .00 16.00 01/25/2001 L. PAUL JOHNSTON, :~~ R. homas Kline Sheriff of Cumberland County JR Sworn and subscribed to before me this /..r day of d..ll"",.." J J..eJ-o I * A.D. {2 ~ A~,a; Prothonoca y '-.,Q~I'l"'I~WW'V ~ .!l_~ COUNTY OF YORK 1 of 2 OFFICE OF THE SHERIFF SERVICE CALL (717) 771-9601 28 EAST MARKET ST" YORK, f'A 17401 1. PLAlNTJFF/Sf Nicole Yea er 3, DEFENDANTIS/ et. al. '".,'."" ...:.INSTFlJJCrION~<, " " , ..,:j:>l.:.g4~grxj:>gQNI"Y)..INI5~1ro 12 "'/ ../.O:QNQT[)g"f4:CI-iANYCQj:>I~~., 2. COURT NUMBER 4, TYPE OF WAlT OR COMPLAINT Notice & SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN SERVE . AT Robert { A. Wancho. et. Al. 5. NAME OF INDIVIDUAL, COMPANY, CORPORATI9N, ETC. TO SERVE OR DESCRIPTION OF PROP TYTO BE LEVIED, ATfACHED, OR SOLD. Robert A. Wancho 6. ADDRESS (STREET OR RFD WlTH BOX NUMBER, APT NO., CITY, BORD, -fWP., STATE AND ZIP CODE 31, r~rtrpf Rn Rrr~r~ Dn '7319 7. INDICATE SERVICE: a PERSONAL 1:1 PERSON IN CHARGE DEPUTIZE Curnil3l~.M.M.ld 0 1ST CLASS MAIL NOW 1/1? In1 19~I.SHERIFFOFYbfHo(cO__'" ",' ,do hereby Vnrk COUNTYtoe~' t ,ke to law. This deputation being made at the request and risk of the plalntiff.1:~ ", HEAIFF F' 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: o POSTED Q OTHER e the sheriff of ~f according Cumberland OUT OF COUNTY CUMBERLMil) ADVANCED FEE PAID BY ATTY. NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found In possession, after notifying person of levy c,r attachment, without liability on the part of such deputy or Ihe sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriff's sale thereof. 9. TYPE NAME ANO ADORESS 01 ATTORNEY/ORIGINATOR and SIGNATURE PO BOX 1995 10, TELEPHONE NUMBER 'l._Df'IIO.~'iED L.PAULJOHNSTON, JR. ESQ. 1144 W. HAMILTON S1. ALLENTQ\'IN, PA uno 610-437-5001, xxx*xx 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed if notice Is to be mailed). CUMBERLAND CO. SHERIFF '.SPACEBELOW FOR U.S,E OF ,THE SHERIFF ONLY "00 NOT WRITE BELOW THIS LINE ' SIGNATURE OF AUTHORIZED CLERK 14. Date Received 13. I acknowledge receipt of the writ or complaint as indicated above. 16,HOW SERVED: PERSONAL ( ) POSTED( ) POEt ) 1-16-01 SHERIFFS OFF ( ) OTHER 9Q SEE REMARKS r!\ :H: (~"/OJ r/~'1c~1. Refund 41.AFFIRM 47.Da ,9 o( 48. Date 42. day of 43. 1/22/01 49. Date 46. Signature 0 orelgn Coun Sheriff 50.1 ACKNOWlEDGE RECEIPT OF T SHERIFF'S RETURN SIGNATURE OF AUTHORIZED ISSUING AI)THORITY AND TlTLE 1, WHITE - Issuing Authority 2. PINK - Attorney 3. CANARY - Sheriff's Office - 4. BLUE - Sheriff's Office 51. Date Received H. __, ~,~,~ 171'7' ~'''~ ~ '.. /,17 2I lJd BI NUi' EO, Vd 'iWOA .:UI!l3HS .:10 301.:L'J ,,03.1.13:):!" .,j',".. . > ' ., -~, '!' , ..=~~~~~~:. .m~~ffiIiI'fajj~~~*'r!Jji:;Y;;fb"!if-!t~',)'\P'-"j'" """"'-""'-"-!""-''i'''f!l!Vi<,'\""",~('':!ii'--W'~!':;~'T''',:,j ~ ~ " "'_"i~"~-;jj_~!:,~' "'4 -'~ -i--"-- ~ ---- ~-_.~: ;-:;.o':":'.~-----:~-.~,~ ) ,~-,:.'~ .~: 'Ii,;' ~ COUNTY OF YORK -''';~ ~- .~ ",",. , ' OFFICE OF THE SHERIFF ~,:f J .' ;" ; -. -, 'f""~ J 'J";' . --IlB EAST MARKETST., VOFiK,PA 17401 , ' I SERVICE CALL (717) 771,9601 :y ',;; ~',,~ ,L-ef ? ~,,~. '''':; ;~, ~. "'..,."- "". ',;r.. SHERIFF SERVICE ,~~PROCESS RECEIPT, and AFFIDAVIT OF RETURN ~..,.. 1'"' _ ...; f-~' .".- ;.. t. INSTRUCTIONS PLEASE TYPE ONLY LINES 1 TO 12 00 NOT [)EI~CH ANY COPIES. . ' ,-:..-;-. ,,' ! ;"W .~ ~ .11- 'Cumberland 'QUT OF COUNTY CUMBERLAND ADVANCED FEE PAID' BY ATTY. ~, ~'" NOTE ONL>rAPPLlCABLE ON WRIT OF EXECUTION: N.S. WAWER O~ WATCHMAN - Any deputy ~ heriff levylng_ upon or attaching any property under within writ may leave same withoUfa watchman, in cUstody or whomever is round in possession, after notifYing person of levy 1)( att~chment, without liability on the part of such deputy or the sheriff to any plaintiff here!~.for any loss, destruction, or removal of any property before sheriff's sale thereof. "",' . .~.. . . 9: TYPE NA~E AND ADDRTSS 01 ATTORNEY/ORIGINATOR and SIGNA'('FiE Pq BD)< 1995" 10, TEL'El>IOj,fE"I'JUM~ER L.PAU~OH~STON. JR. ESQ. 1144 W. HAMIlTON ST. ALLENTOWN, PA'18i05 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed). clJMBE;<UIAD CO. SHERI FF ' , , ' ,.' .~ ' ~~:; ,r~~ACJ;.e!:I,.OW EQB]f..s...I;.MI!:f~$tlERiFF' ONl.y,-I~!U.IQJ" WBIT!:i!~.I"Qw..1:HJ$ L11\1~ 13. I aCkn~~iadge receipt of the writ SIGNATURE OF AUTHOR1ZED CLERK 14. Date Received 15. Expiration/Hearing Date or compiarnt as indicated above. 610~437-50[\1 l':.~"i~OJl:ED bUill ".;~;:' '1;; ---=-~';. ..:L ;;-"', .:(:'. ,. " Int. 16- HOW SEj&ED: PERSONAL ( ) POsTED ( ) POE ( )-:., _1h_111 SHERJ~f'S OFF ( ) ? 10 n SEE REMARKS .J ~ " ~' ';or" .-.i~At , -",," --":":": .~-" J-. ,(\\ ,',.1 " ~,-;-----_. / <"~'.l---q..':J 1/22/01 49. Date 15~.~ate.~~cewe~ . .... . ~\' .--.. 1,"1"" .'_...._~--=-_t~,"___ COUNTY OF YORK 2 of 2 OFFICE OF THE SHERIFF SERVICE CALL (717) 771-9601 28 EAST MARKET ST., YORK, F'A 17401 . ~ . SHERIFF SERVICE INSTRUCTIONS PROCESS RECEIPT, and AFFIDAVIT OF RETURN PLEASE TYPE ONLY LINES 1 TO 12 DO NOT DETACH ANY COPIES. 1. PLAINTIFF1S! ._.._~ ~2: COURT NUMBER 0 1. - 2 4 7 Civil Nicole Yeager, et. al. 4. TYPE OF WRIT OR COMPLAINT 3. DEFENDANTIS/ , - Notice & Complaint Robert A. Wancho, et. a!. 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF P'FtOPE-~ TO BE LEVIED, ATTACHED, OR SOLD. { DphrR WRn~hn 6. ADDRESS (STREET OR RFD_WITH BOX NUMBER, APT NO., CITY, BORD, TWP., STATE AND ZIP CODe ~~~ r~rrrAr Rn PrrAre p~ 17~1Q 7. INDICATE SERVICE: 0 PERSONAL a PERSON IN CHARGE . Q DEPUTIZE CumiIJI~ M4l1d. a 1ST CLASS MAIL NOW 1. /12 /01 ,19 "i, SHERIFF OF YOf.II~~6Y d York ""COUNTYtoexej:. r to law. This deputation being made at the request and risk of the piafiiHfC-;;OO ---1- SEAl 8. SPECIAL INSTRUCTIONS OR OTHER INI=ORMATION THAT WILL ASSist IN -E){PE-OITlNG SERVICE: - o POSTeD 0 OTHER the sheriff of !paccording SERVE . AT ;y Cumberland OUT OF COUNTY 'CUr~BERLANn ADAVANCED FEE PAID BY ATTY. NOTE ONLY APPUCABLE ON WRIT OF EXECUTION: N.S. WAIVER OF WATCHMAN ~ Any deputy sheriff levying upon or' attaching- any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy (lr 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 ofATTOANEV/ORIGINATOR and SIGNATuRE 10. TELEPHONE NUMBER 11. DATE FILED L. PAUL JOHNSTON, JR. ESQ. 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRl:SS BELOW: (This area must be oomp'leted If notice Is'to be mailed). CUMBERLAND CO. SHERIFF 1-11-n1 -iit_S SPACE BELOW FORlJSE OF THE StlERIFF ONl:\'-LlO"NOTWRITE BELOW THIS LiNE SIGNATURE Of AUTHORIZED CLERK 14. Date Received 15. Expiration/Hearing Date R. AHRENS 1-16-01 2-10-01 13.1 acknowledge receipt of the writ or complaint as indicated above. 21. ATTEMPT PQSTEQ ( ) POEt ) SHERIFF'S OFF ( ) OTHER ( ) SEE REMARKS 22. REMARKS: 41.AFFIR 47. Qat7' /:1. C7( 48_ Date 42. day of 43, FOR 46. Signature 0 Foreign MY COMM SION EXPIRES Coun Sheriff 50.1 ACKNOWLEDGE RECEIPT OF T E SHERIFF'S RETURN SIGNATURE OF AUTHo.RIZED ISSUING AUTHORITY AND TITLE - 1. WHITE - Issuing Authority 2. PINK. Attorney 3. CANARY - Sheriffs Office 4. BLUE - Sheriff's Office 1/22/01 49. Date =, ~ "~ ,e' 1,1, 2T Wd 911~Ur TO, Vd')l(lOA :J:J1(l3HS dO 301d:JO "a3^1303lJ " t.. i!l!M~4n~li[QI'~_l~_jll,Alli!11Ii!1-'!l,~I~~R<:~~l\l!''ij~~_'ft!X~IL~;j;\;}ti~?'i--%ii<iH\'he.::,'r'f';<{fi~"k!:f,i,~W"H~I'!"F;tf{1:\$~M'<>~-'"-ii" ,ic_"~",,, """\\~'1I-'f:;';~if'"J~f,'t~:' --....... - .--.#- < '=-:~-"~"'-:---::;"-------:-:-,-~~,"~';'i-- - ~ , COUNTY"OF YORK "",' , , OFFICE OF THE SHERIFF ~i SERVICE CALL (717) 771,9601 , 2 of 2 ~:~.:.. ..~' 28 EAST MARt<ET ST" YORK, PA 17401 , ;.,'~ >-', INSTRUCTIONS ';:' ,SHERIFF SERVICE , 'PROCESS RECEIPT, and AFt=IOAVIT OF RETURN PLEASE TYPE ONLY LINES 1 TO 12 , , DO NQT DEJ,\CH ANY COPIES. 1. PLAINTlFFISI 2,COURTNUMBER 01-?47 riv; 1 _ :Nicole Yeager, et ...,.;.a1. 4. TYPE OF WRIT OR COMPLAINT 3. OEFENDAl\ITlS/ ' , Notice & Complaint Robert A. Wancho. et. al. SERVE 5. NAME OF INDIVIDUAL, COMPANY, COFIPORATION, ETC. TO SERVE OR DESCRIP1"ION:Oi= PROPERTY TO-SE LEVIED, ATTACHED, OR SOLD. . f)phrr- W""n....hn - - - , " - . 6. ~DAESS (STREET OR RFD WITH BOX NUMBER, APT NO., CITY, BORO, -rwE, STATE AND ZIP CODE , " AT ,,- ?,,:/:s, r;n-i--ro.4= p" '"'t-i..o..,...~ rn 1'1~10 . . -a PERSON,IN QHAAGE~ ~ DEPUTiZECu_mtlQItRX:!f~t;;l C11ST CLAS!?.MAIL a POSTED CI OTHER 19 -=---:'r.SHERIFF'OF 'r,Qajiic()uNTv. pA. do hereby deputize the sheriff of, York ~,' COuill'rYto exec'ute this W,'il'and make rehirn thereof accordlng to law. Th,rs deputation being made atthe request and risk of the plaintiff.' "- - , - ,_ SHERIFF OF ';(Mi"KX'cOUNTY 8. SPECIAL iNSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: ,. Cumberland 7,INDlCATILlil;flVICE: 0 PERSONAL I'!OW 1'1 "/01 ~ r ADAVANC!D FEE PAID BY ATTY. ODT of' COUNTY CUMBl:RLAND ~~,. NOTE ON}..Y APPUCABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN" Any deputy s1eriff levying upon'or attaching an~ property under within writ may leave "....' same withoUt a watchman, in cuslody .of whomever is feund in possession, after netifying persen of levy Cor attachment, without liabifity .on the part of such deputy .or the sheriff t.o any ',~~,,:Z, plaIntiff herelnter any Joss, destruction, .or remeval of any preperty befere sheriff's saJe thereof. " " . . ~u 9. TYPE NAME: AND ADDRESS of ATTORNEY/ORIGINATOR and SIGNATbRE'~ 10_ TELEPHONE NUMBER 11. DATE FILED .'-;~ .~ ,)' L. PAUL=JOHNSTON, JR. ESQ. . 12. SEND NOJiCE OF SERVICE !=OPYTO NAME AND ADDRESS BELOW: (This area must be completed-If notice is to be mailed). CUMBERLAND CO. SHt:RI FF ", , " 1-11-01 13. I acknowlEl:11ge receipt of the writ or compla~~t as indicated above. j.;" E,'""SPACE .SELOW fOR US~ OETI:IESHERIF.f Ql'<!LY: [rOJIIOTWRITE BELO\.I'THIS LIlliE SIGNATutte Or AOrnof:llZEo CLERK. 14. bate Received 15. 'Expiration/Hearing Dale R. AHRENS .~..'---;:"7_ . ~~.. RESIDENCE)>'.) POSTED ( )' .'>;", pd("'1 1-16-01 ; ,\. SHERIFF'S OFF ( ) OTHER ( 2-10-01 ) SEE.REMARKS (S~ remarks below.) 19. Dale of Service 20. Time of Service '/19,.6 ( " 'f ! ;;1' '<;,,+ ~ 23. Advance Costs ~ .~~ 'ji .' i / ?1'/'/ r l I -j-, /1"" " -,"" . '~,",' .~' ":: "" ,oi ~ ~..:: i~1 34. ForeJgn CQunty Costs 35. Advance- Costs ~, ' :""~ ' ~ '\. '~.i) .-' ''''i/.r'',~ l :....___. '~".,c'~.', 4l.AFFIRM~~'and :S'~b~9 1'0 befo'~' rfi~}l),~~'" ,?ND 42,dayof '4J"~.RY '"., ,~2001 45,SColgnatursehof,~o /, , / /. unty ert!)"' . 43, ' r,,- '- I roR wILLIAM M.fK)SE {;;.,._ _ .:,',<.:"~_p.ce ",~~iuyJ~lJp'l!c 46. ignatureof oraign MY COMMtS"g- O'N EXPIR S-- _' :__"-' LJ ,/.1';:" Cou Sheriff 50.1 ACKNCWLEDGE RECEIPl OF TH~ SHERIFPS RETURN SIGNATURE OF AUTHQfllZED ISSUING AUTHORITY AND TITLE 1. WHITE M Js~uing Authority 2. PJNK MAlIomey 3: CANARY" SheriWs_Offioo '4. BLiJE';~-Sheriffs'OfficE~' :;''-' ,:-'::0 _'" (.-/ .:>>:~<' r<:/ i..,.,,,- "~' - ..il/v/, '-(" ;/ 1/22/01 49. Date 151. Date Rece,ived ,.I..::-,./I-::/~'---;-': .""~.~ " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NICOLE YEAGER and NATIONWIDE INSURANCE COMPANY, as subrogee: of Plaintiff NICOLE YEAGER, No.: 01-247 Civil Term Plaintiffs, Vs. ROBERT A. WANCHO and DEBRA WANCHO, Defendants. TO THE PROTHONOTARY: The above-captioned case was due to a motor vehicle accident. o STON, JR., ESQUIRE or Plaintiffs Attorney I.D. No. 68774 1144 West Hamilton Street P.O. Box 1995 Allentown, PA 18105-1995 (610) 437-5001 !$,!!I31 ".., ""'^ !1',~, . '- '". ~. .' .,...~.... >,-' " ",., "",r-1 pm ,c' '-'" '. , ,'-"""'" ~ ' --'" 0 CJ ~ ,,~ ~ I~"',) -on en L;C~~ C'1 ~g,; 'U Z L. C":~ (C, ,,' .~< r:; :>, . L_ l,,_-, j~ ,,,., ~<) C.". --I -;~' -''', :~i 'ji ::.JJ_ 01 -<. iIiII~!*lj!~,i!fjlW~"%'~~~~~\)-'1i"'Pi~$lm!~~~"'~>lJ~ ,,,,,,,,,,,,,,,_,,i