HomeMy WebLinkAbout01-03379
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L. PAUL JOHNSTON, JR., ESQUIRE
. Attorney for Plaintiffs
! Attorney J.D. # 68774
1144 W. Hamilton St., P.O. Box 1995
Allentown, PA 18105-1995
.\ (610) 437-5001
ARBITRATION
Ii ASSESS. DAMAGE HEARING REQUIRED
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION - LAW
CAROL A. BENTZ, 759 Carl St., York,
PA 17404 and NATIONWIDE INSURANCE
COMPANY, P.O. Box 2655, Harrisburg, PA
17105, as subrogee of Plaintiff Carol A. Bentz, '--r:'
Plaintiffs No.: 01- 3271 CiU'l( lee.
vs.
JEREMIAS SANTIAGO, 14220 SW 88th Ave.,
Miami, FL 33176, JORGE IBANEZ, 1029
Oliver St., Elizabeth, NJ 07011, and QUICK
TRANSPORT TRUCKING, 8115 Lakepoint Dr.,
Plantation, FL 33322
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 AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
(800) 990-9108
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L. PAULJOHNSTON, JR., ESQUIRE
Attorney for Plaintiffs
Attorney I.D. # 68774
1144 W. Hamilton St., P.O. Box 1995
Allentown, PA 18105-1995
(610) 437-5001
ARBITRATION
ASSESS. DAMAGE HEARING REQUIRED
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION - LAW
CAROL A. BENTZ, 759 Carl St., York,
PA 17404 and NATIONWIDE INSURANCE
COMPANY, P.O. Box 2655, Harrisburg, PA
17105, as subrogee of Plaintiff Carol A. Bentz,
Plaintiffs
No.: 0 J- 33 79 ~"-u..-
vs.
JEREMIAS SANTIAGO, 14220 SW 88th Ave.,
Miami, FL 33176, JORGE IBANEZ, 1029
Oliver St., Elizabeth, NJ 07011, and QUICK
TRANSPORT TRUCKING, 8115 Lakepoint Dr.,
Plantation, FL 33322
Defendants.
COMPLAINT
NOW COME the Plaintiffs, Carol A. Bentz and Nationwide Insurance Company, by
and through their attorney, L. Paul Johnston, Jr., and bring this civil action against the
Defendants, Jorge Ibanez, Jeremias Santiago, and Quick Transport Trucking, upon a cause of
action whereof the following is a statement:
1. Plaintiff Carol A. Bentz is an adult individual residing at 759 Carl S1., York,
PA 17404. (Hereinafter "Plaintiff Bentz")
2. Plaintiff Nationwide Insurance Company is a corporation, registered with the
Pennsylvania Insurance Department to do business in Pennsylvania, providing insurance
coverage, including but not limited to, automobile insurance coverage, with an address of P.O.
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Box 2655, Harrisburg, PA 17105. (Hereinafter "Plaintiff Nationwide")
3. Defendant Jeremias Santiago is an adult individual residing at 14220 Southwest
88th Avenue, Miami, Florida 33176. (Hereinafter "Defendant Santiago")
4. Defendant Jorge Ibanez is an adult individual residing at 1029 Oliver Street,
Elizabeth, New Jersey 07011. (Hereinafter "Defendant Ibanez")
5. Defendant Quick Transport Trucking is believed to be a Florida business entity
with an address registered with the Interstate Commerce Commission and the United States
Department of Transportation of 8115 Lake Point Drive, Plantation, Florida 33322.
(Hereinafter "Defendant Quick")
6. At all times relevant hereto, Plaintiff Bentz was insured by Plaintiff Nationwide
for motor vehicle liability and/or loss.
7. Plaintiff Nationwide brings this action as subrogee of Plaintiff Bentz, pursuant
to its right of subrogation as contained in a motor vehicle liability policy issued to Plaintiff
Bentz, 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.
8. On or about December 7, 1999, at or about 7:15 a.m., Plaintiff Bentz was the
owner and operator of a 1993 Ford Aerostar, which was covered under the above-referenced
policy, and which was traveling north on Route 83, in the right lane, at or near exit 19 in
Lower Allen Township, Cumberland County. (Hereinafter "the Bentz vehicle")
9. At the date and time aforesaid, Defendant Ibanez was the owner of a 1999
Freightliner FLT with a trailer attached. (Hereinafter "the tractor trailer")
10. At the date and time aforesaid, the tractor trailer was marked with USDOT
number 76491 and ICC number 344184, which were registered to Defendant Quick, and
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I which tractor trailer was flagged as belonging to Defendant Quick, as indicated by markings
on and in the tractor trailer.
11. At the date and time aforesaid, Defendant Santiago was operating the tractor
trailer as an employee, agent, or contractor-lessee of both Defendants Ibanez and Quick.
12. At the date and time aforesaid, Defendant Santiago was operating the tractor
trailer in furtherance of his duties as employee, agent, or contractor-lessee of both Defendants
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I Ibanez and Quick on Route 83 north, in the right lane, at or near exit 19 in Lower Allen
Township, Cumberland County.
13. As Plaintiff Bentz operated the Bentz vehicle, legally and with due and proper
care, Defendant Santiago operated the tractor trailer in such a negligent and careless manner
that he struck the rear of the Bentz vehicle, pushing the Bentz vehicle into the rear of the
automobile that was traveling directly in front of her on Route 83 north.
14. The aforementioned negligence of Defendant Santiago also caused damages as
are hereinafter more fully set forth.
15. 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.
16. Defendant Quick was, by the actions of its employee, agent, or contractor-
lessee Defendant Santiago, and by the markings in and on the tractor trailer, representing itself
to the public as the carrier of goods.
17. At all times relevant hereto, Defendant Quick was acting as a public common
motor carrier of interstate commerce, as the same are recognized under applicable
Pennsylvania and Federal law.
18, At all times relevant hereto, Defendants Ibanez, Santiago, and Quick were
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undertaking a joint business operation, in which liability for loss or casualty was shared
equally among all parties.
19. Under applicable law, when a vehicle is being operated with ICC and USDOT
endorsements, the carrier is responsible for the negligence of the operator, regardless of
whether the operator is in the service of the carrier, or if the vehicle involved is owned by the
carrier, a lessor, or even the operator himself.
20. A public common motor carrier can only be certified by a public authority, and
as it involves an unreasonable risk of harm to the public, it is subject to liability for physical
harm caused to the public by the negligence of even a contractor.
21. Under federal law , when a party is uninsured, any remaining parties are
primarily liable pursuant to the MCS-90 endorsement issued to all public common motor
carriers.
22. Plaintiffs believe and therefore aver that both Defendants Santiago and Ibanez
are uninsured.
23. Under federal law, all leases of equipment involved in interstate commerce must
be in writing and provide for public liability protection in the event one or more parties
becomes uninsured.
24. The instant defendants failed to reduce their agreements to writing, in violation
of federal law , or alternatively, failed to provide the necessary public liability protection.
25. If in fact it is determined that Defendant Quick is not a public common carrier
for the purposes of the trip that resulted in the collision, Plaintiffs alternatively aver that
Defendant Quick was the owner of the trailer portion of the tractor trailer.
26. Under Federal law , where an accident arises out of the use of a tractor trailer it
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arises out of both tractor and trailer regardless of which part of the unit was involved in the
accident.
27. Therefore, Defendant Quick would be liable for all damages resulting from the
above described collision.
28. The said negligence and carelessness of Defendant Santiago consisted of:
A) Operating the tractor trailer at an excessive rate of speed under the
circumstances;
B) Failing to maintain the tractor trailer under proper and adequate
control;
C) Failing to maintain an adequate and proper lookout for other vehicles;
D) Following traffic too close;
E) Failing to give due regard to the rights, safety, and position of the
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.
29. Defendants Ibanez and Quick are additionally liable for failure to properly
supervise, train, and/or instruct Defendant Santiago in the proper and safe method of
transporting interstate commerce.
30. All Defendants are jointly and severally liable for the collision and resulting
damage.
31. Solely as a result of the aforesaid collision, caused by the negligence and
carelessness of all Defendants, the Bentz vehicle was damaged, the repair of which cost the
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Plaintiffs the sum of $3,867.83.
32. As a result of the actions of the Defendants, Plaintiff Bentz sustained personal
injuries to the head, neck, back, and well as other injuries, some or all of which may be
permanent in nature.
33. As a result of the actions of the Defendants, Plaintiff Bentz has suffered bodily
pain and suffering, as well as mental anxiety and nervousness, to her great detriment and loss.
34. As a result of the actions of the Defendants, Plaintiff Bentz has incurred medical
bills and expenses and may require further treatment for his injuries.
35. As a result of the actions of the Defendants, Plaintiff Bentz has suffered an
interruption of usual occupation and daily pursuits and a loss of earnings andlor earning
capacity .
36. Plaintiff Nationwide is now entitled to collect from Defendants Ibanez,
Santiago, and Quick all payments, judgements andlor settlements of any kind made to Plaintiff
Bentz pursuant to the uninsured/underinsured motorist provisions of the above-referenced
policy with Plaintiff Bentz due to Plaintiff Nationwide's status as subrogee of Plaintiff Bentz.
37. Plaintiff Nationwide has, in fact, paid to Plaintiff Bentz the sum of $7,000.00
pursuant to the uninsured/underinsured motorist provisions of the above-referenced policy with
Plaintiff Bentz and is now entitled to collect this amount from Defendants.
38. Due to the multiple violations of Federal and Peunsy1vania law, Plaintiffs may
also be entitled to punitive damages, special damages, interest, costs, and attorney's fees.
WHEREFORE, Plaintiffs Nationwide Insurance Company and Carol A. Bentz
demand judgment against the Defendants, a sum in excess of $10,867.83, but not to exceed the
jurisdictiona11imit for compulsory arbitration, together with interest and costs and such other
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further relief as this Court may deem necessary and appropriate.
Respectfully submitted
L. PAl HNSTON, JR., ESQUIRE
Attorney for Plaintiffs
Attorney J.D. # 68774
1144 W. Hamilton St., P.O. Box 1995
Allentown, PA 18105-1995
(610) 437-5001
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AFFIDAVIT
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 is executed because the Plaintiffs can not reach Plaintiffs'
counsel's office in time for personal execution and this verification can be replaced by one
signed by an actual party upon any written request.
o STON, JR., ESQUIRE
Att .. No, 68774
44 W. Hamilton St., P.O. Box 1995
Allentown, PA 18105-1995
(610) 437-5001
SWORN TO AND SUBSCRIBED
before me thi~ day
Of~ 2001.
. Notary Public
My Commission Expires:
NoIa11al5eal
~D. Roemor, NotalYPubIIc
_. LehIgh County
MyClo1m11lolilon E>l>i"'!\pr. 15, 2002
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L. PAUL JOHNSTON, JR., ESQUIRE Attorney I.D. # 68774
1144 WEST HAMILTON STREET, P.O. BOX 1995
ALLENTOWN, PA 18105-1995 (610) 437-5001
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CAROL A. BENTZ and NATIONWIDE
INSURANCE COMPANY, as subrogee of
Plaintiff CAROL A. BENTZ,
No.: 2001-03379
Plaintiffs,
vs.
JEREMIAS SANTIAGO, JORGE IBANEZ,
and QUICK TRANSPORT TRUCKING,
Defendants.
PRAECIPE TO REINSTATE OR REISSUE
TO THE PROTHONOTARY:
--X-REINSTATE the Complaint in the above-captioned matter
____REISSUE the Writ of Summons in the above-captioned matter
____OTHER:
Date: '7-/I~/ll L
L. AUL N, JR., ESQUIRE
Atto aintiffs
Attorney ID Number: 68774
1144 West Hamilton Street
P.O. Box 1995
Allentown, PA 18105-1995
(610) 437-5001
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AFFID.SER/FORMS/5/28/02 LPJ:mdo
IN COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NATIONWIDE :
as subrogee:
A. BENTZ,
CAROL A. BENTZ and
INSURANCE COMPANY,
of Plaintiff CAROL
No.: 2001-03379
Plaintiffs,
Vs.
JEREMIAS SANTIAGO, JORGE
IBANEZ and QUICK TRANSPORT
TRUCKING,
Defendants.
AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P. 403(1) and 404(2)
I, L. PAUL JOHNSTON, JR., ESQUIRE, Attorney for the
Plaintiffs, being duly sworn and according to law, depose and say
that I served the Complaint for the above-captioned matter on
Quick Transport Trucking, pursuant to Pa.R.C.P. 403(1) and 404(2)
governing service of legal papers other than original process, by
mailing a copy of said Complaint by certified mail, postage
prepaid to Quick Transport Trucking on the 12th day of June,
2001, to their known address of 8115 Lakepoint Drive, Plantation,
FL 33322. A copy of the service letter and certified receipt are
SWORN TO AND SUBSCRIBED
BEFORE ME THIS O?Cf
DAY OF May, 2002.
, 01tP
e a part hereof.
attached hereto, marked Exhibit
Date: ;;;i"1-
1995
NoIaJtaI Seal
Michelle D. 011, No1IlIy Public
at}' 01 AIIenloYm, lehigh County
My Commisslon ElcpIms ~r. 15, 2006
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LAw OFFICil:S
L. PAUL JoHNSTON. JR.
MAILING ADOR...
P.O. Box 19915
ALLENTOWN,PA.18101S
(610) 437-5001
FAX (610) 437-5190
WWW.LAWYERS.CoMlLPJESQ
LPJJRESQO"'OL.COM
June 12, 2001
CERTIFIED MAIL
RETURN RECEIPT REOUESTED
Quick Transport Trucking
8115 Lakepoint Drive
Plantation, FL 33322
~e: Bentz et al. vs. Santiago et al.
CCP. cumberland Countv No.: 2001-03379
Dear Sir or Madame:
Enclosed please find a Complaint with regard to the
above-captioned matter.
We are serving same upon you pursuant to applicable
rules of Civil Procedure.
LPJ:mdo
~UL/JOHNSTON, JR.
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Enclosure
cc: Ms. Karen Grace
Claim No.: 58 37 C 728032 12071999 01
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IN THE COURT OF COMMON PLEAS OItUMBERLAmPUNTY, PENNSYLVANIA
CIVIL DIVISION
CAROL A. BENTZ and NATIONWIDE
INSURANCE COMPANY, as subrogee
of Plaintiff CAROL A. BENTZ,
..: Plaintiffs,
Vs.
JEREMIAS SANTIAGO, JORGE
IBANEZ AND QUiCK TRANSPORT
TRUCKING,
Defendants.
. File No. 2001-03379
PRAECIPE .FOR JUDGMENT
TO THE PROTHONOTARY OF SAID COURT:
Enter Judgment in favor of Plaintiff/DimlliilillilXand against:
Defendant Jorge Ibanez and Defendant QuiCk Transport Trucking
for want of fai lure to answer comPlaint.
( X) Assess damages as follows:
De b t ----------------------------------------------------- $ 1 0 , 8 6 7 . 8 3
Interest from ---------
A tto rn ey' s Com miss io n ----------------------------~--
TOT A L ----------------------------------------------- $ 10, 867 . 83
( 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 al!;ainst whom judl!;ment is to he entered and to
his/her Attorney of Record, if any, after the default occurred and at tea. days prior to the date
of the filinl!; of this praecipe and a copy of the notice is attached.
DA TE: . fa /;10 L. . . Signature:
/ Print Name:
Attorney fj r:
Address:
. Pa I Johnston, Jr., Esquire
PI iffs
.0. Box 1995
Allentown, PA 18105-1995
Telephone: (610) 437-5001
Supreme Court ID No.: 68774
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Deputy
(Rev.4/97)
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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
CIVIL DIVISION - LAW
NATIONWIDE :
as subrogee:
A. BENTZ,
COUNTY, PENNSYLVANIA
CAROL A. BENTZ and
INSURANCE COMPANY,
of Plaintiff CAROL
No.: 2001-03379
Plaintiffs,
Vs.
.
JEREMIAS SANTIAGO, JORGE
IBANEZ and QUICK TRANSPORT
TRUCKING,
Defendants. May 28, 2002
TO DEFENDANT JORGE IBANEZ:
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 17013
717-249-3166
BY:
L.
JR., ESQUIRE
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L. Paul Johnston, Jr., Esquire
Attorney I.D. No. 68774
1144 West Hamilton St., P.O. Box 1995
,Allentown, PA 18105-1995
I (610) 437-5001
I
IN THE COURT OF COMMON PLEAS OF CUMBERLAND
CIVIL DIVISION - LAW
NATIONWIDE :
as subrogee:
A. BENTZ,
Attorney for Plaintiff
COUNTY, PENNSYLVANIA
CAROL A. BENTZ and
INSURANCE COMPANY,
of Plaintiff CAROL
No.: 2001-03379
Plaintiffs,
Vs.
JEREMIAS SANTIAGO, JORGE
IBANEZ and QUICK TRANSPORT
TRUCKING,
Defendants. May 28, 2002
TO DEFENDANT QUICK TRANSPORT TRUCKING:
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 17013
717-249-3166
BY:
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IN THE COURT OF COMMON PLEAS O{t:UMBERLAN@OUNTY. PENNSYLVANIA
CIVIL DIVISION
CAROL A. BENTZ and NATIONWIDE
INSURANCE COMPANY, as subrogee
of Plaintiff CAROL A. BENTZ,
Plaintiff(s)
vs.
JEREMIAS SANTIAGO, JORGE
IBANEZ and QUICK TRANSPORT
TRUCKING,
File No,
2001-03379
NOTICE OF FILING JUDGMENT
Defendant(s):
( x ) Notice is hereby given that a Judgment
in the above captioned matter has been entered against you in the amount of
$}0;867.83 on_J/u')fi. 27 .ll9C2002
( 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 JDHNSTDN, 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. S 236.)
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IN THESlR.CUITCOURT, IN AND
FOR tw~P'~COUNTY, P~QI~ID,^, .
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Pfl>intiff,
CASE NO:
,;zo 0/- D.J.?"7 '1
vs.
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.;tLJG~ls~ILQ/'j..QE B~M:Sa!.!EIg.x
DefendElnt
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by and thrQugll their \mdersigned r,;ollnSet,
Defend1ilnt'
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Jlereby fife this $llggestion of Bankn.lptcy flncl as grounos tI'lerefore would state the fOllOWing:
1. Dafendants fflecl Ii! CI1apter 13 with the Bankruptcy Cowt 'lfI_1. {) ~ -z.- 2-/0, "2..
2. The 'flllng of the 8ankruptcy PetitIon operates as an Automatfc Stay agaInst all actiol1s.
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proceedings and enforcement against tho Debtor. 11 U,S.C. Sec. 362.
WHEREFORE. Defendants S\,ggasts that this actil)O be stayed.
! H. ERF.:SY CERTIFY th~t a true and CQrrect CQPY of me foregOing St,rgglill!ltion of 8anknlptcy ill bl,ing
furnished by U.S. Mail to:. t-, /',If!lL. JMI~J'V'b4j~;.e~ 4r4' /'0, g' 0)( /99Vj AtUf'I/!'(flJj;~/,t4-,
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ARNOLD HECKER, ESQ.
Attorney for Defendant
Telephone:
Florida 8ar#0'123438
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CA~E NO: 2001-03379 P
~ COMMONWEALTH OF PENNSYLVANIA
I
COUNTY OF CUMBERLAND
SHERIFF'S RETURN - U.S. CERTIFIED MAIL
BENTZ CAROL A ET AL
VS.
SANTIAGO JEREMIAS ET AL
R. Thomas Kline
, Sheriff
of Cumberland
County, Pennsylvania, who being duly sworn according to law served the
within named DEFENDANT
,SANTIAGO JEREMIAS
by United States Certified Mail postage
prepaid, on the 22nd day of February ,2002 at 0000:00 HOURS, at
14220 SW 88TH AVENUE
MIAMI, FL 33176
, a true
and attested copy of the attached COMPLAINT & NOTICE
Together
with
The returned
receipt card was signed by RETURNED: ATTEMPTED NOT KNOWN on
00/00/0000
Additional Comments:
Sheriff's Costs:
Docketing
Cert Mail
Affidavit
Surcharge
18.00
4.17
.00
10.00
.00
32.17
~o ans s: /~. ... 0 o__-:>/~
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.~ o. o.
R. Thomas Kline
Sheriff of Cumberland County
Paid by L PAUL JOHNSTON JR
on 03/04/2002 .
Sworn and subscribed to before me
this /3'b" day of~
OJttv~ A. D.
~ (2 ")-)"h,.J~'
P othonotary I
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SHERIFF'S RETURN - U.S. CERTIFIED MAIL
- ,
CASE NO: 2001-03379 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
BENTZ CAROL A ET AL
VS.
SANTIAGO JEREMIAS ET AL
R. Thomas Kline
, Sheriff
of Cumberland
County, Pennsylvania, who being duly sworn according to law served the
within named DEFENDANT
,IBANEZ JORGE
by United States Certified Mail postage
prepaid, on the 22nd day of February ,2002 at 0000:00 HOURS, at
8043 LAKEPOINTE DRIVE
PLANTATION, FL 33322
, a true
and attested copy of the attached COMPLAINT & NOTICE
Together
with
The returned
receipt card was signed by J. IBANEZ
02/25/2002
on
Additional Comments:
Sheriff's Costs:
Docketing
Cert Mail
Aff idavi t
Surcharge
s: _~-?
-C'~ --
So ans
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6.00
4.17
.00
10.00
.00
20.17
"~
R. Thomas K ~
Sheriff of Cumberland County
Paid by J PAUL JOHNSTON JR on 03/07/2002 .
Sworn and subscribed to before me
this /3~ day of ~J../
;LlJtJdJ A.D.
~"-' () )u ,Ct,.) A~n'J
othonotary /
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