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HomeMy WebLinkAbout01-2376 FX ! . -. I'"." .. .. SHEILA C. O'CONNOR, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 0 I - .,;(;]1f.:.. C;oLl ~~ DENISE M. COLEMAN, CIVIL ACTION - LAW 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Telephone 717..249-3166 or 800-990-9108 ;' l' By W. Sco 1.0. #322 1 300 Linglesto Harrisburg, PA 1 (717) 238-2000 Attorney for Pia ntiff ;~~. ~., .,,---"",'-'..- _,',,'d_ YO->;'~,,,F,,,,,~j"I7"',_ ~_",,,P_"'L',,,,' -"7~,"'-_'~,_~_"^,, '_',"' ..'. __~_,__~_,~ ~~,. ,_,_^~",,_" .~, - - .~~ ._ ."H__, . " v : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 0/- 2. 3 '1~ &:uJ ~, SHEILA C. O'CONNOR, Plaintiff DENISE M. COLEMAN, Defendant : CIVIL ACTION - LAW : JURY TRIAL DEMANDED COMPLAINT AND NOW, comes the Plaintiff, Sheila C. O'Connor, by and through her attorneys, HANDLER, HENNING & ROSENBERG, by W. Scott Henning, Esquire, and bring the within Complaint against the Defendant, Denise M. Coleman, and aver as follows: 1. Plaintiff, Sheila C. O'Connor, is an adult individual who currently resides at 15 Aspen Drive, Narragansett, Rhode Island, 02882. 2. Defendant, Denise M. Coleman, is an adult individual who currently resides at 665 Gregs Drive, Apartment No. 93, Harrisburg, Dauphin County, Pennsylvania, 17111. 3. At all times material hereto, Plaintiff, Sheila C. O'Connor, was the owner and operator ofa 1999 Nissan Altima, bearing Pennsylvania Registration Number BXM 1045. 4. At all times material hereto, Defendant, Denise M. Coleman, was the owner and operator of a 1996 Saturn SL2, bearing Pennsylvania Registration Number AL W 2800. 5. At all times material hereto, there were no adverse weather conditions and the road surface was dry. '""~,, ,~.,', ,~," - '_,_-,-,,",~,_<~,__,,_,"",__, _~_ .,__,'_~ _ ~_,I~" ,__ ~~;""'__"~ ~~' ~ ~7_'~W, 6. On or about May 11, 1999, at approximately 10:30 a.m., Plaintiff, Sheila C. O'Connor, was stopped at a red light on the southbound Wesley Drive ramp of Routes 11/15 in Lower Allen Township, Cumberland County, Pennsylvania. 7. On or about May 11, 1999, at approximately 10:30 a.m., Defendant, Denise M. Coleman, was traveling on the southbound Wesley Drive ramp of Routes 11/15 in Lower Allen Township, Cumberland County, Pennsylvania. 8. At approximately the same time and place, Defendant failed to observe that Plaintiff s vehicle had stopped at a red light then and there existing. Suddenly and without warning, Defendant failed to bring her vehicle to a halt and a violent collision resulted. Upon impact, Defendant's vehicle struck the rear end of Plaintiff s vehicle. 9. The aforementioned collision caused extensive property damage and was so severe that the Plaintiff required medical attention. 10. Prior to the aforementioned collision, Nationwide Insurance Company issued a policy ofautomobile insurance to Plaintiff, Sheila C. O'Connor. Said policy was in effect on May 11, 1999, the date of the collision and the limited tort option was selected. Plaintiff remains eligible, pursuant to 75 Pa. C.S.A. S1705(d), to seek compensation for non-economic losses due to the serious nature of the injuries and the serious permanent disfigurement sustained by her. COUNT I SHEILA C. O'CONNOR v. DENISE M. COLEMAN NEGLIGENCE 11. Paragraphs 1-9 are incorporated herein as if set forth at length. 12. The occurrence of the aforementioned collision and the resultant injuries to t",,-^",,,,.,"'c""'~ '~--__'1'_;_,?, _"..__'C~,_"__~o__,__,:,_____"__,___~,,^>_,~_~_,,.I, ~Yc' 0'" I,e-L'," _'__~__'-_o-'_- "-f'~'''f-'''\''_'_'~ "'-_"_'_"',,~_J~_~""".T7'c_ ~_ _"_.~ "__, '."~"'~'_~~_'" Plaintiff, Sheila C. O'Connor, were the direct and proximate result of the negligence of Defendant, Denise M. Coleman, generally and more specifically, asset forth below: (A) In failing to operate her vehicle at a safe speed, in violation of75 Pa. C.S.A. 93361; (B) In failing to operate said vehicle in such a manner that would allow her to apply the brakes and stop before striking Plaintiffs vehicle; (C) In failing to operate her vehicle under proper and adequate control so that she could have avoided striking Plaintiffs vehicle; (D) In failing to maintain proper and adequate observation of the existing traffic patterns, namely, stopped traffic; (E) In failing to keep a proper lookout for vehicles lawfully on the highway; (F) In failing to operate her vehicle at a speed at which she could stop within the assured cleared distance ahead, in violation f 75 Pa. C.S.A. 93310; (0) In failing to be reasonably vigilant to observe Plaintiffs vehicle; and (H) In ailing to exercise reasonable care in the operation and control of her vehicle, in violation of75 Pa. C.S.A. 93714. 13. As a direct and proximate result of the negligence of the Defendant, Denise M. Coleman, the Plaintiff, Sheila C. 0' Connor, has suffered personal injuries including, but not limited to, cervical myofascial pain syndrome, associated vertigo and chronic headaches, post -concussion syndrome, torn lateral meniscus of right knee, cervical sprain with inner spinous ligament injury, lumbar sprain with radiculitis, and SI joint dysfunction. 14. As a direct and proximate result of the negligence of the Defendant, Denise M. r'o_..._ -".\ '<1,-,.;-""'"'_; _-<F'_~---''^''_W''-:'~-:;-__''_'__''''' ""_-,,?':7" -.,1""", '~~c--_"_~_'r_'" r_"" _,,~., ., '_P> . ,,... ,-"._ , __._ .e __ ' ,", '."' "", _'-""''''~'_ ~". ~,__ ,~ -,'. ."" d .'_~_ I ..0 ~,~~ '" ~- Coleman, the Plaintiff, Sheila C. 0' Connor, sustained serious personal injuries requiring ernergency medical treatment, surgical intervention and continuing medical treatment. 15. As a direct and proximate result of the negligence of the Defendant, Denise M. Coleman, the Plaintiff, Sheila C. O'Connor, has been, and will in the future be, hindered from attending to her daily activities and duties, to her great detriment, loss, humiliation and embarrassment. 16. As a direct and proximate cause ofthe negligence of the Defendant, Denise M. Coleman, the Plaintiff, Sheila C. O'Connor, has suffered great physical pain, discomfort, humiliation, and mental anguish, and will continue to endure the same for an indefinite period of time in the future, to her physical, emotional, and financial detriment and loss. 17. As a direct and proximate result of the negligence of the Defendant, Denise M. Coleman, the Plaintiff, Sheila C. O'Connor, has been compelled, in order to effect a cure for the aforesaid injuries, to expend money for medical attention. Plaintiff continues to take medications and incur medical expenses for said injuries, and will continue to do so in the future, to her great detriment and loss. 18. As a direct and proximate result of the negligence of the Defendant, Denise M. Coleman, the Plaintiff, Sheila C. O'Connor, has suffered a loss of life's pleasures, and she will continue to suffer the same in the future, to her great detriment and loss. 19. As a direct and proximate result of the negligence of the Defendant, Denise M. Coleman, the Plaintiff, Sheila C. O'Connor, sustained a loss of wages, and she will continue to suffer the same in the future, to her great detriment and loss. 20. Plaintiff, Sheila C. O'Connor, believes, and therefore avers, that her injuries are permanent in nature. , - """ ,'~-.", - ,~_.<,-~-" . ~-" ,0-_ ,~ "'/ -;~ ,,"I '- ",:",. "., "'1' c,_"." ''01,'".' - "", - I. ,.,r y.",,' , _" 1__ _' ,~,,_,~ _ ~_>_, _" _ -, ,~_, r, "~'__'~_- _< ~, _ -. . _"_n'_ :IT' ~~~ WHEREFORE, Plaintiff, Sheila C. O'Connor, seeks damages from Defendant, Denise M. Coleman, in an amount in excess of Twenty-Five Thousand ($25,000.00) Dollars, exclusive of interest and costs, and demands a trial by jury. Respectfully submitted, HANDLER, HENNING & ROSENBERG Date: f- /1-:200 r W. Scott Henning Attorney LD. No.3 1300 Linglestown Harrisburg, PA 17108 (717) 238-2000 Attorney for Plaintiff ;~. " .".-,,- ,-, ~ - _~"f,-';~-'""'.r..'''?~'".':-_"" ,,''''' .,;,:-~ ,'"e '. ':""""" ,,,,,",.,,,,.,,,1._,,""'"':_' ,'c-',~"'?'l-",-~ "~," _, .___,..__~o,,' "-'-8~<,,,c .~".", -,_ , - '" -"" "^~~ ~ ~ __ """__ _ .,--. ""~-, ,,~~ --" ~._- VERI FICA TION The undersigned hereby verifies that the statements in the foregoing document are based upon information which has been furnished to counsel by me and information which has been gathered by counsel in the preparation of this lawsuit. The language of the document is of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the document are that of counsel, I have relied upon my counsel in making this Verification. The undersigned also understands that the statements made therein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. ~~cooC~. SHEILA O'CONNOR Date: '-\\\ol.c \ -._~/, ,,"'"'~C'-, 0 __ . - fe'" -!"'_"'::I'-','":,'i~"--',_'/r~,- - ," . "']-1 -. ~-- " . n,~ '.'" ,_" ',< -"-1'-' ~ '^'~ .' '-:-<C~:1 - -.~, ",- , ~,,-'" , SHEILA C. O'CONNOR, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 01 - itJ7b Ct.u~ ~~ DENISE M. COLEMAN, CIVil ACTION - LAW 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Telephone 717-249-3166 or 800-990-9108 _,It CO. pY.~. R~..... '0""",, untO- my..... .T~Y'P\l~eof;.1 ~ ".-...,. PI.. ....-"-~f. ~~l~~!~ ~~;UFO' By W. Scott He I.D. #3229 1300 Linglestown Harrisburg, PA (717) 238-200 Attorney for Plaintiff '>~_,1'IIl!! ,-.," I ~ J _ , . ,"J 'I , SHEILA C. O'CONNOR, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v : NO. DENISE M. COLEMAN, Defendant : CIVIL ACTION - LAW : JURY TRIAL DEMANDED COMPLAINT AND NOW, comes the Plaintiff, Sheila C. O'Connor, by and through her attorneys, HANDLER, HENNING & ROSENBERG, by W. Scott Henning, Esquire, and bring the within Complaint against the Defendant, Denise M. Coleman, and aver as follows: 1. Plaintiff, Sheila C. O'Connor, is an adult individual who currently resides at 15 Aspen Drive, Narragansett, Rhode Island, 02882. 2. Defendant, Denise M. Coleman, is an adult individual who currently resides at 665 Oregs Drive, Apartment No. 93, Harrisburg, Dauphin County, Pennsylvania, 17111. 3. At all times material hereto, Plaintiff, Sheila C. O'Connor, was the owner and operator of a 1999 Nissan Altima, bearing Pennsylvania Registration Number BXM 1045. 4. At all times material hereto, Defendant, Denise M. Coleman, was the owner and operator of a 1996 Saturn SL2, bearing Pennsylvania Registration Number AL W 2800. 5. At all times material hereto, there were no adverse weather conditions and the road surface was dry. , <~'" ,~ ,,-, J ". .~__":'o. --~,- .'." , r.o l '--1 - , ~_"" " - ~ - , I'll , 6. On or about May 11, 1999, at approximately 10:30 a.m., Plaintiff, Sheila C. O'Connor, was stopped at a red light on the southbound Wesley Drive ramp of Routes 11/15 in Lower Allen Township, Cumberland County, Pennsylvania. 7. On or about May 11, 1999, at approximately 10:30 a.m., Defendant, Denise M. Coleman, was traveling on the southbound Wesley Drive ramp of Routes 11/15 in Lower Allen Township, Cumberland County, Pennsylvania. 8. At approximately the same time and place, Defendant failed to observe that Plaintiffs vehicle had stopped at a red light then and there existing. Suddenly and without warning, Defendant failed to bring her vehicle to a halt and a violent collision resulted. Upon impact, Defendant's vehicle struck the rear end of Plaintiff s vehicle. 9. The aforementioned collision caused extensive property damage and was so severe that the Plaintiff required medical attention. 10. Prior to the aforementioned collision, Nationwide Insurance Company issued a policy of automobile insurance to Plaintiff, Sheila C. O'Connor. Said policy was in effect on May 11, 1999, the date of the collision and the limited tort option was selected. Plaintiff remains eligible, pursuant to 75 Pa. C.S.A. S1705(d), to seek compensation for non-economic losses due to the serious nature of the injuries and the serious permanent disfigurement sustained by her. COUNT I SHEILA C. O'CONNOR v. DENISE M. COLEMAN NEGLIGENCE 11. Paragraphs 1-9 are incorporated herein as if set forth at length. 12. The occurrence of the aforementioned collision and the resultant injuries to , '-, _~; c, ..,. L,., " . ,-,., Plaintiff, Sheila C. O'Connor, were the direct and proximate result of the negligence of Defendant, Denise M. Coleman, generally and more specifically, as set forth below: (A) In failing to operate her vehicle at a safe speed, in violation of75 Pa. C.S.A. 93361; (B) In failing to operate said vehicle in such a manner that would allow her to apply the brakes and stop before striking Plaintiffs vehicle; (C) In failing to operate her vehicle under proper and adequate control so that she could have avoided striking Plaintiffs vehicle; (D) In failing to maintain proper and adequate observation of the existing traffic patterns, namely, stopped traffic; (E) In failing to keep a proper lookout for vehicles lawfully on the highway; (F) In failing to operate her vehicle at a speed at which she could stop within the assured cleared distance ahead, in violation f75 Pa. C.S.A. 93310; (0) In failing to be reasonably vigilant to observe Plaintiffs vehicle; and (H) In ailing to exercise reasonable care in the operation and control of her vehicle, in violation of75 Pa. C.S.A. 93714. 13. As a direct and proximate result of the negligence of the Defendant, Denise M. Coleman, the Plaintiff, Sheila C. O'Connor, has suffered personal injuries including, but not limited to, cervical myofascial pain syndrome, associated vertigo and chronic headaches, post-concussion syndrome, torn lateral meniscus of right knee, cervical sprain with inner spinous ligament injury, lumbar sprain with radiculitis, and SI joint dysfunction. 14. As a direct and proximate result of the negligence ofthe Defendant, Denise M. {~ ". ...", ~'"', . " -" "I' .~ " I"~ Coleman, the Plaintiff, Sheila C. O'Connor, sustained serious personal injuries requiring emergency medical treatment, surgical intervention and continuing medical treatment. 15. As a direct and proximate result ofthe negligence of the Defendant, Denise M. Coleman, the Plaintiff, Sheila C. O'Connor, has been, and will in the future be, hindered from attending to her daily activities and duties, to her great detriment, loss, humiliation and embarrassment. 16. As a direct and proximate cause of the negligence ofthe Defendant, Denise M. Coleman, the Plaintiff, Sheila C. O'Connor, has suffered great physical pain, discomfort, humiliation, and mental anguish, and will continue to endure the same for an indefinite period of time in the future, to her physical, emotional, and financial detriment and loss. 17. As a direct and proximate result of the negligence of the Defendant, Denise M. Coleman, the Plaintiff, Sheila C. O'Connor, has been compelled, in order to effect a cure for the aforesaid injuries, to expend money for medical attention. Plaintiff continues to take medications and incur medical expenses for said injuries, and will continue to do so in the future, to her great detriment and loss. 18. As a direct and proximate result of the negligence of the Defendant, Denise M. Coleman, the Plaintiff, Sheila C. O'Connor, has suffered a loss of life's pleasures, and she will continue to suffer the same in the future, to her great detriment and loss. 19. As a direct and proximate result of the negligence of the Defendant, Denise M. Coleman, the Plaintiff, Sheila C. O'Connor, sustained a loss of wages, and she will continue to suffer the same in the future, to her great detriment and loss. 20. Plaintiff, Sheila C. O'Connor, believes, and therefore avers, that her injuries are permanent in nature. ':. "~:C" , " ",,~,,~_, ,J ,.L,.." , ,~ ,., . WHEREFORE, Plaintiff, Sheila C. O'Connor, seeks damages from Defendant, Denise M. Coleman, in an amount in excess of Twenty-Five Thousand ($25,000.00) Dollars, exclusive of interest and costs, and demands a trial by jury. Respectfully submitted, HANDLER, HENNING & ROSENBERG Date: 1-lr~;pd / W. Scott He 'ng Attorney J.D. 8 1300 Linglestown Road Harrisburg, P A 171 08 (717) 238-2000 Attorney for Plaintiff ~~......, ". . " 1",.,0'"' _," .' , "' r VERI FICA TION The undersigned hereby verifies that the statements in the foregoing document are based upon information which has been furnished to counsel by me and information which has been gathered by counsel in the preparation of this lawsuit. The language of the document is of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the document are that of counsel, I have relied upon my counsel in making this Verification. The undersigned also understands that the statements made therein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. ~~.C.()C2VV^v~ SHEILA O'CONNOR Date: ,-\\\ok>\ t ' ~- ~ - -'-'-~-'" ., 1 ~ Ir~" -f ,. -- . ~ ~ '=-. !,~ i33 :~ lru,J I i I !~.. '" -~ "~,- ~, ~ -"'-." ~, "'-j"-~-."g',-,-, ~I ~~~ A"U S iHrid - -"'c"!~'\:\J0 ~ ! .:.., if'., _.1 10, Wd 911 E A.ll1fn':;'~ ,kHli3W: EZ, ~dV: .:JL -'; ~!:ij' ;(', ~,C;U.:W .',-", '~>l' ~ ~ "'"~-:'~"'j, , -'~'''~'-~~'~'M''-''T."f~J.~rtr'~r' "J"-'l:r'''''';'1-'!'1-b.", . ""'""'"-~ .."",- rio, ., _ "","J1l\l~,~ I!I'$L%~", . ~JrL _'~"'\'ffi!fl~3l'_,_ , m~fll'i.l!ffl?)~ f:'_~3':%lj-"',"I,t; n~';"'".'I,-"~~;",i('-; 'i4'ii"'"~i'>';;W~'~"l~'ij~f~:;',i1~I;iltw._"NII<!'" 'C-,"_'^,,'" ;~. c~ ':: :::-I:'../,O ~,~~~ =Z~Z .~~~r.no ~OOO ...:---r"'lC ' ;:::-1'1"7' ~--~;g3 :~-1 -' :;D >'.) en ?.::: '? '-'- ''''c-- ',,0 ~ ~~ r=' ~.. fii:;::" "',. ~-'-""'''''''''''~W:!1l!irffiiii!~~r",''' '-""'''''''''-'''"-''t^, .. .> SHEILA C. O'CONNOR, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 01-2376 DENISE M. COLEMAN, Defendant : CIVIL ACTION - LAW PRAECIPE TO REINSTATE TO THE PROTHONOTARY: Please reinstate the above-captioned Complaint in order that Defendant Denise M. Coleman can be served accordingly. Respectfully submitted, HANDLER, HENNING & ROSENBERO Date: ~- 1 7 ~dCJ7)( By: " :i: " Attorney for Plaintiff < - "--"0,~7 ,~_ -. n - - - ,-~, _ _~ _"X___~,^',,,~I ,-"':'~:'\ ~-~-_1"_<,' ~,-"^'1"--<~_,'~'_~__c:_',,~~r_"' '". _.,,_ .,> ._' , -,,-'c_ ,,<_,_, ~', ,_.,--,1 ,Y , ~._-~,.-,,~,,~,~->-- -~-- ."~"~-----,,,," "-~=~-- .-" '- ,-~, !ti i ~, ,?-!'<,'."'~ -~, "'0= , ~.' '_."," "r'",,',- _~o, ,,,,"_,__> _Co, ,'~ . "".."'...,,' ,.,' iltLMf ':" f-"it'r-~~('"'t' ". rr-"::-'~it '\c'" l'~r;;,!'ll7ill'- "';,-'- '.", ....~['~~:JmD?ij~ :'MiJ c ) $; ;~pr:i': _1r-, ::.:::~ .-;;..;::- gi/f .;:--. '-- !Ji ~j ~:5-: ~ -< 1'0 -. o -- ",. ~,,!'-~"-1"'~~""~~_~<~ .. C) -- c _.j "1 ~Tf: -.;: ,", (,)"'j -,.-, ;",~. i-I ::;-! <) ',J , \. )/n j~~ -,"1 -,:; >~';',td ~ .1~if]~:? SHERIFF'S RETURN - NOT FOUND .. CASE NO: 2001-02376 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND , O'CONNOR SHEILA C VS COLEMAN DENISE M 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 COLEMAN DENISE M but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , COLEMAN DENISE M Sheriff's Costs: Docketing Service Affidavit Surcharge Dep. Dauphin Co. 18.00 .00 .00 10.00 29.25 57.25 County HAND OS/2 & ROSENBERG Sworn and subscribed to before me this 3Ll~ day of J1...1 ~I A.D. QtL- (A /v,_of,." # P 0 honotary , '~.; ,~ ~'_~'C '" . " < ~ I @ffite of tlr~ ~1r~riff William T. Tully Solicitor J. Daniel Basile Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 171 0 1 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania O'CONNOR SHEILA C vs County of Dauphin COLEMAN DENISE M Sheriff's Return No. 1247-T - -2001 OTHER COUNTY NO. 01-2376 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for COLEMAN DENISE M the DEFENDANT named in the within NOTICE & COMPLAINT IN CIVIL ACTION , and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, May 18, 2001 EXPIRED BEFORE DEFENDANT COULD BE FOUND. Sworn and subscribed to So Answers, ?f~ before me this 18TH day of MAY, 2001 ~ C-. ~~M1.a) f PROTHONOTARY Sheriff of Dauphin County, Pa. By Deputy Sheriff Sheriff's Costs: $29.25 PD 05/04/2001 RCPT NO 149467 ;~~.., """," "-3",",' ,",or,'-,; <--,,~<l '~-' ,- ., I,,~ ,> --'J =?' ,or, ,~ - . In Tbe Court of Common Pleas of Cumbedand County, Pennsylvania Sheila C. O'Connor VS. Denise M. Coleman No. QJ -")376 Ci"i 1 Now, 4/24/01 , 20 10 (J, I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being rnade at the request and risk ofthe Plaintiff. .vI'~ . ~~~t Sheriff of Cumberland County, P A Affidavit of Service Now , ,20 , at o'clock M. served the within upon at by handing to copy of the original a and made Imown to the contents thereof. So answers, Sheriff of County, PA .70 ,-- COSTS SERV1CE MILEAGE i>,.FFIDA VIT $ Sworn and subscribed before me this _ day of $ \:r, ,. ,>". ", '-, ~. , ~'11'~, 'I ~I'~-l"~ --,- ! 1 ~- - " " !l1I 1- "1P!l~!!lMI~" ,'~ "~.. . 11I~ '" "'!~$g,Imlfl~, ~.. -- ,] --~, - , ,,~~ > 1!IIt,....,..~"_" ~ ,., ~~","",,-';<,:,%"';::;r'~~'-<i;"";~"-"H~:'~IH~' "~;')ii~ ,. ~ ~,.,,"", .- -. u'~~-"-n-"f",-'iii Q ,. CJ ~~ .-, :::0 :0- ~,. !::tl' '-" ;Jz::C> rn -0 ::ncf'TlC :;U -- ';0-13 (") N ~~g~:t ri\ CJ1 '=Z-n::;;;: ~.'-l '- ':'::"':(./'>0 ",. "".:',,00 ~ ..," :..c....,c 1""'= CO :-'_C:;~Z iil ::~~g~ G CO '- SHEILA C. O'CONNOR, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 01-2376 CIVIL TERM DENISE M. COLEMAN, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA: Please re-issue the Complaint in the above referenced matter. Please instruct the Sheriff of Cumberland County to attempt service of the Complaint upon the Defendant Denise M. Coleman a/k/a Denise M. Garver a/k/a Denise M. Anderson atthe following address: 665 Gregs Drive Harrisburg, PA 17111 HANDLER, HENNING & ROSENBERG Date: 7'-5 -J6!/ Attorney for Plaintiff \ '_\,o~, _.- ,- _ -"""'0'.,.,: ')(\'--,7~,',.__~_~~"'C1:_"'__ ," -i"_"~, "''''':_'''C_ - __'__",.,""I'''',~_ ,.,.<_~ ___d,,:",__,;,~. '" ,..".~__~~_. Lc7=< ,_ " ",,, _, _ _ _'K , ._~_ ,_ .~""_~_._~. _ ." ~ ~ _ " _ ~,_.,~" ',m .~.- ".' , "' .,,-~. _ .," -~." - . ,_, ,',.," F.;.. , .O~ --" , - "'~-,'''~~ L,.t"~:-",,.~_ ~--: , ~ .". . "0" '.'~'''' "' . ~,".,," . II .11 .!lL ,..,~~,!",,>;!~l\I,''1'''''1-~-n', (j ',,, C..= '-y' ,. ~. - "$'ltfnliiifrm'J"~ I tD ",' 'o.J (',,) p,~~. ~, -, '" -",-, ~~~~~~"'1~ o. SHERIFF'S RETURN - OUT OF COUNTY . CASE NO: 2001-02376 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND O'CONNOR SHEILA C VS COLEMAN DENISE M 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: COLEMAN DENISE M but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT & NOTICE On July 26th , 2001 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin Co 18.00 9.00 10.00 29.25 .00 66.25 07/26/2001 HANDLER HENNING s~/.~ .'/ ~-~~ R. Thomas Kline Sheriff of Cumberland County & ROSENBERG Sworn and subscribed to before me this (" eo- day of D'T'.J-' .2o-t>/ A . D . 01f" () nul,,~ . .~ Prothonotar """"""'f"""''''''''1WJI.. "~, ", ~ , 1 ~ , - "'~I' . 1,1 '1' . . . @ffite of tlrc~4criff William T. Tully Solicitor J. Daniel Basile Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistaut Chief Deputy Dauphin County Harrisburg, Peunsylvania 171 0 1 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania O'CONNOR SHEILA C vs County of Dauphin COLEMAN DENISE M Sheriff's Return No. 1898-T - -2001 OTHER COUNTY NO. 01-2376 AND NOW: July 18, 2001 at 8:40AM served the within NOTICE & COMPLAINT upon COLEMAN DENISE M by personally handing to HER o true attested copy(ies) of the original NOTICE & COMPLAINT and making known to him/her the contents thereof at 665 GREGS DRIVE HARRISBURG, PA 17111-0000 Sworn and subscribed to So Answers, Jf~ , Pa. O~'~..YP= I PROTHONOTARY Sheriff's Costs: $29.25 PD 07/13/2001 RCPT NO 151912 MLYNEK l' ,~ ,IT, ,--: '5~ q;, ~">'_~ ,-'1- _ _ '~-'_r." _'1''''._'_ ,_ "',<I' , . In The Court of Common Pleas of Cumberland County, Pennsylvania \ Sheila C. O'Connor VS. Denise M. ColEman Serve: Denise M. ColEman No. 01 2376 civil Now, July 10, 2001 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~~on:;<f{'~ 4"~.$' Sheriff of Cumberland County, PA Affidavit of Service Now, ,20_, at o'clock M. served the within upon at by handing to copy of the original a and rnade known to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before rnethis_dayof ,20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ ~'fi~ ~':"""~__ _ . ,. , "".,..,.( ,--' 1,-' '.., I , !:"' I r I I i I j I I ,1 . ''"''JUL" _...."~tI1!l~~ .~ ~'""~.-" "',~,,~ .~. ,'.'~'_-'_._~/' ~i""-.~"~_' . L' <.-, ,,,",~, Jf~"" .__r""H'_-"""-"'~ ,-,~",,,,., " .-.' ",,-,.,, --~-"'<_"'~'''''"'",'-i..'iY_'_'-_'~'''''''c" '-,;;'-'<1"'''',"""",, .~" w ~ =,,'. ""'''' -,,",'" - ":;'~i'fj''Y'"JY:''' , '0, I 9~ ! . 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