The URL can be used to link to this page

Home My WebLink About01-05949 (,'<1,_,._ ,_,_!" . .' KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff ~'''---- '1 CAROL K. STEVENSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 4t tJl- 5tJ~1f ~ L & K MILLS, INC., Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO DEFEND TO THE DEFENDANT NAMED HEREIN: 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 is 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 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 (717) 249-3166 1-800-990-9108 "-""I '-< -!-" ;1 ~I '"r"'''WW;''~(;.''''''' ,...",.."",,", '.~. ~ ~. ~~~. '. ~ ~ ~ .~... .. KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for plaintiff CAROL K. STEVENSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. S o/-$Lf1 C(I.J(/ L & K MILLS, INC., Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED COM P L A I N T Carol K. Stevenson, by her attorney, Kenneth F. Lewis, files this Complaint and avers as follows: 1. The plaintiff, Carol K. Stevenson, resides at 346 Brokers Drive, Hummelstown, Dauphin county, Pennsylvania 17036. 2. The defendant, L & K Mills, Inc., is a corporation with its principal place of business located at R.D. 1, Box 18, Benton, Columbia County, Pennsylvania 17814. 3. On or about October 22, 1999, plaintiff was a passenger in a vehicle driven by Mai Carl, that was headed south on Interstate 83 in the Borough of Lemoyne in Cumberland County. 4. The vehicle in which plaintiff was riding was struck from behind by a truck owned by Defendant and operated by Defendant's agent, Donald R. Tripp. 5. The collision occurred in Cumberland County, the borough of Lemoyne on Interstate 83. 'Of""'< ''''''~.':'',..'' " . 1,. ',":'.U' ". 6. Plaintiff, without any fault on her part, was injured by the collision described above. 7. The defendant, by its agent, drove the said vehicle (a 1994 Freightliner) carelessly, negligently, and recklessly, following too closely behind the vehicle in which Plaintiff was a passenger without lawful regard for the rights of the Plaintiff in violation of the provisions of the Motor Vehicle Code, including but not limited to 75 Pa.C.S.A. S3310. 8. Defendant's agent's negligence and/or recklessness, was a direct and proximate cause of the collision described above. 9. As a result of the negligence and/or recklessness of Defendant's agent described above, plaintiff was violently knocked and jostled about in her car, whereby she suffered, and continues to suffer, injuries to her neck and back. 10. Plaintiff has incurred expenses for medical treatment, and will incur additional expenses in the future, as a direct result of the above-described injuries. 11. The amount in controversy in this matter exceeds the amount which would require submitting this case to arbitration. WHEREFORE, Plaintiff requests judgment in an amount to be determined at trial, plus costs and such further relief as this Honorable Court deems just. DATE: 10/15/01 Respectfully submitted, K.f~~" Attorney for Plaintiff 'M~~1I<l_~_ ,_., j'"" I' G"'~' """""."'- ,~, -- .- c~1jL,) VERIFICATION I hereby verify that the statements made in the foregoing document are true and correct. We understand that false statements herein are made subject to the penalties of 18 Pa.C.S. section 4904, relating to unsworn falsification to authorities. Dated: jO!JS/O j ~,JJ/e:~~~ OL K. STEVENSON "F'" .., ~" I' ~',,,,, ,,~ ". ",. ~- ,~, e ~ f " ~ ~ ~ ~' ~ ~ ~ 2 0 0 ~. ''rl ~ ~ ;;;;: C> .,. ~. i%~~ (") :!:. ---. -I -i ':; ,-;'~; '" Z-" -- \ ze' ", ~~l r:~' "-J \ -:Q ;;, 0-' . ',,' _.-~ !;215 ':J,r~.1 '-.l ~ "'" ~~~ ~ , ~8 _'0' , )>c C? ~ ~ -' ~ c:.~ ..". ":0 .+:'" ::<: t I""....., _...1111,..0.. . """"'" ,'",.,."..' .""u, ~'- .."",,<<<,Jlt~~llt~n,~ . '" ", ",_lTr,~""","'i-~'''' y. 1TTr~~'f""""~'1<< _' ,_, _ "'1"'1i;~J:->' ;:i?~it~~"~~lfti.,"f( ',- ,Af~~lf,~J;~~ " __~~lJ~~p~~_~- .-,~.!:f CAROL K. STEVENSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-5949 civil L & K MILLS, INC., Defendant : CIVIL ACTION - LAW JURY TRIAL DEMANDED IMPORTANT NOTICE TO: L & K Mills, Inc. R.D. #1 Box 18 Benton, PA 17814 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 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 OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 DATE: 11/16/01 ~kM KE NE F. LEWIS, ESQ. Attorney for Plaintiff 1.0. #69383 1101 N. Front st. Harrisburg, FA 17102 (717) 234-3136 hi!lf.!'P!:y",'e,,,~ '~~.- c '0' <, ,-.- - - '00'. '. ,-, - CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of the within Important Notice upon Defendant by mailing same by u.s. Mail, postage prepaid at Harrisburg, Pennsylvania addressed to: L & K Mills, Inc. R.D. #1 Box 18 Benton, PA 17814 K~ LEWIS, ESQUIRE Attorney for Plaintiff Dated: 11/16/01 ''$:'1-'/[1,<-., -- ~~,',-',,-J~"'!- ,-<,,,"-""-"'V" .,r.- ~ 1'-' I' . -,,- ., ,,, , -'" -," ,~ -"- " Cs glJ - . ~~ " ,-"~ "< =-'&'~~' . '<<"l> '" ~-'.'''.","~'e",,, ,.-.,. -~ ~~~"P..._.~.....~".- '--,'''' "(r~,:i: g g: -ace rnr10 Z"""-1 -'-C ~~:. ~C:i ~O >'2 :z: -1 -<. c::' - (~ .1"_ ,"", '::;; CJ', '"'-'),'8 ""':l ::~ '._~; ~~l, ,---"q .~~S?, .,~ :';Q -< -- .. ,:- ~~~'lfTl;I;i!,"~ ~ rr;]:lI!," ~!",,~!"il'Wifi'1iV~1&"~;;-i"":W;WlJ:n\1;:"""-"""::";>-1'3:-'["fi'~"""V("~~,,,*,~,#H"'!'~wmll'W1\~'~~~! r SHERIFF'S RETURN - OUT OF COUNTY . " " , CASE NO: 2001-05949 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STEVENSON CAROL K VS L & K MILLS INC 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: L & K MILLS INC but was unable to locate Them in his bailiwick. He therefore deputized the sheriff of COLUMBIA County, Pennsylvania, to serve the within COMPLAINT & NOTICE On November 13th, 2001 , this office was in receipt of the attached return from COLUMBIA Sheriff's Costs: Docketing Out of County Surcharge Dep Columbia Co 18.00 9.00 10.00 57.00 .00 94.00 11/13/2001 KENNETH LEWIS '~ R. h'omas -Kline --- . .' . Sheriff of Cumberland County Sworn and subscribed to before me this ~ ;It., ~ day of I1.MuM' L~ dlKJ/ A.D. ~.L- 0 )y,.Jp,. ~~ Prothonota ""W":''O''?~'~W ,~ ". ~- I ' -. " ~"~~ "-""T"'"~'">"'_ .. ~"" :. HARRY A. ROADARMEl, JR. . PH"" 15701.,.5611 SHERIFF OF COLUMBIA COUNTY COURT HOUSE. '.0. 80X 310 BLOOMSBURG. PA 11815 'AX: (J1Qj ,..,-4I1J1 24 HOUI PHONE 15:"81'.....100 CAROL K. STEVENSON Docket # 5949CFW2001 VS NOTICE & COMPLAINT L&KMILLS SHERIFF'S COST $57.00 PAID AFFIDAVIT OF SERVICE NOW, THIS WEDNESDAY, OCTOBER 17, 2001, AT 5:00 PM, SERVED THE WITHIN NOTICE & COMPLAINT UPON L & K MILLS AT RD I BOX 18, BENTON BY HANDING TO CHALRES LITWHILER A TRUE AND ATTESTED COPY OF THE ORIGINAL WRIT AND MADE KNOWN TO THEM THE CONTENTS THEREOF. SWORN AND SUBSCRIBED BEFORE ME THIS THURSDAY, NOVEMBER 08, 2001 ~..J- F. v}'I...I,J N TARYPUBLIC SO ANSWERS, \l \i.~~} ;HE~Y A. ROADARMELJR - ~. ~ NOTARIAL SEAL JANET E. WEEKS, Notary Public lbwn of Bloomsburg, Columbia Co., PA ~"Ii~ . DBCl8, 2004 ~: J Rl R - EPUTY SHERIFF iF:''''l''~__",:~,_J_,,_:,._ _ '__,.'\ .~ '-, " -I I ~ ' . """'-"',:: ;] '-'."" In The Court of Common Pleas of Cumberland County, Pennsylvania Carol K. Stevenson VS. L & K Mills, Inc. SERVE: same No. 01 5949 civil Now, October 16, 2001 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Columbia County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~~~~-4? Sheriff of Cumberland County, PA Affidavit of Service Now, ,20_,at o'clock M. served the within upon at by handing to a copy of the original and made !mown to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this _ day of ,20_ COSTS SERVICE MILEAGE AFFIDA VIT $ $ 'j:~'%-~, " ~ -" .~ f' r,-'-, ~,