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Home My WebLink About01-05990 KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01- 5116 civil CAROL K. STEVENSON, Plaintiff E & J TRUCKING, 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 10se 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 '''',~.:r'' . -~''";-'"-''-- - ~,_"' ",-"'::-'-"'F''f:-'-';~'',;, I'" ,--~pr--. .'- ,"-'- , _7=" KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01- SCI~()Civi1 CIVIL ACTION - LAW JURY TRIAL DEMANDED CAROL K. STEVENSON, Plaintiff E & J TRUCKING, INC. Defendant COMPLAINT 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. Defendant E & J Trucking, Inc., is a corporation with its corporate address listed as Loudenslager Road, RR1, Box 6B, Liberty, Tioga County, Pennsylvania 16930. 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 operated by Donald R. Tripp and owned by L & K Mills, Inc., the collision occurring in Cumberland County, the borough of Lemoyne, on Interstate 83. 5. The Defendant had a relationship with L & K Mills, Inc. whereby it paid for the use of the above-mentioned truck. "',\\~r,ll' "--" '," ~-. . ""', ., -j ,- ,~,'~ ." ~ ". -~ m~~'__ _ :'Jlt?;:.lJ..ll,.- 6. Donalq R. Tripp was employed by and was the agent of E & J Trucking, Inc. at the time of the subject collision. 7. Plaintiff, without any fault on her part, was injured by the collision described above. 8. Defendant's agent drove the said truck, a 1994 Freightliner, carelessly, negligently, and recklessly, following too closely behind the vehicle in which Plaintiff was a passenger without regard for her rights, violating the provisions of the Motor Vehicle Code, including but not limited to 75 Pa.CSA S3310. 9. Defendant's agent's negligence and/or recklessness, was a direct and proximate cause of the collision described above. 10. Defendant's agent's actions resulted in plaintiff being violently knocked and jostled about in her car, whereby she suffered, and continues to suffer, injuries to her neck and back. 11. Plaintiff has incurred expenses for medical treatment, and will incur additional expenses in the future, as a direct result of the above-described injuries. 12. 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: 10/17/01 Respectfully submitted, ~~' L""'S, ESQ, Attorney for Plaintiff < cl '- " _ ..", ~_ ~.~r '0' > ;" ., 'i VERIF:ICATION 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: 10/17/01 Ce&uI ~~~~ CAROL K. STEVENSON ~!'-_:~_,,,,.JJI~,_ </^' -----~~ 'I ~ -~ ,-,'..' "' ~.~o- ~" --.~"_,..,".",_' ,~w ,_, C' ",",';'" ,,~,..~-~ - "1If @ \\\ ilP ~~ ~ -- c Q.j ~ ~ ~ ~ ~ tj (') c.) CO) C -~, :r .:::> ""OF"', -[ m/.j C') t ~:::.1 29: --I 'r"" ZI-" r-~ '1 0')3> Co C':) --< ~:' ~C) C; S>C\ """ " :~:J - ~C~ C) Pc C;') i:-:j-rn ~ :..) ,:;; ~" (.n ::0 ,-< $ f c" 0- ~<>,,, ,_. ,J"ID, 11!.,!11_!~~~*1~iffl'~~!tJll~'-_~'!',_"_-,.',7\: ~",,~r_~'_~~~"'ij',"";"!''',J1i:,,*.~t;i''''(I'''-'iin-',"~-j'-~'';;'-<1!'i%~~~~ifml~/_~~~l\1!'i~,~>c ma SHERIFF'S RETURN - OUT OF COUNTY CASE.NO: 2001-05990 P €OMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STEVENSON CAROL K VS E & J TRUCKING 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: E & J TRUCKING INC but was unable to locate Them in his bailiwick. He therefore deputized the sheriff of TIOGA County, Pennsylvania, to serve the within COMPLAINT & NOTICE On October 30th , 2001 , this office was in receipt of the attached return from TIOGA Sheriff's Costs: Docketing Out of County Surcharge Dep Tioga Co So 18.00 9.00 10.00 41.20 .00 78 .20 10/30/2001 KENNETH LEWIS R. Thomas Kl1.ne Sheriff of Cumberland County Sworn and subscribed to before me this tj"t;; day of 7llrwd,,, / .2..0.01 A.D. ~Q-~~ Prothonotary "''':''1''CJ~","j;,!~__",t 1J:~1IlJ1I IT _ ~~ _~ =~ ,". ~ __ t- ,W""'~~." ~ 0"""""""""'" . "~~ In The Court of Common Pleas of Cumberland County, Pemusylvania p Carol K. Stevenson VS. E & J Trucking, Inc. Serve: same No. 01 5990 civil Now, October 22, 2001 , I, SHERIFF OF CUl\tIBERLAND COUNTY, P A, do hereby deputize the Sheriff of Tioga County to execute this Writ, this deputation being made at the request and risk ofthe Plaintiff. ,./:if y.4f? ~ ~ ~..A!::i.---R" Sheriff of Cumberland County, P A Affidavit of Service Now, October 25, ,20~, at 4: 20 0' clock P M. served the within Notice To Defend; Complaint upon E & J Trucking, Inc. at RR 1, Box6-B, Liberty, PA Liberty Township by handing to James Route, Owner a true & Attested copy of the original Notice & Complaint and made known to him the contents thereof. So answers, dZLdJ~ 7Pe~L Sheriff of Tioga Edward S; McCabe, Chief Deputy County, PA Sworn and sUbscri~ore me~4iyo . WL/,20~ COSTS SERVICE 18.00 $ :rv11LEAGE 20.70 AFFIDA VIT 2.50 41. 20 $ "-_~"%JWf,\,:"lil~~__t!1. " - . - r --"1---~'< "'~" ,~. d ,-,-,,~_= 'r.-"-'-_~ - ,.. "'"''''-'''!1m''~:T'~l'!';' '1 , I tf) 0) <J~ ,c,rl\ll<!~"'!!1<l~!l'i~~~-.,~,..,~!Jtffl,~~iI#i~l;t~.~,o;m'::Wli~J!:~:r~~Dml1l1!.~f*;->fJf>ll!'!li'~"'''ii'iJt:;:;\''%f.F''i'- '''''-'Y''"'rs'''W!'i_;'''r"i'"''':-'_'';,'',f,!;f0\WW,nj;!;;:'T,'f)i}'0)~Wf','1!i':Wi~~~~!ir;C ~ - ,- ~ ,,~, . CAROL K. STEVENSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-5990 civil E & J TRUCKING, INC. Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED IMPORTANT NOTICE TO: E & J Trucking, Inc. RR 1, Box 6B Liberty, PA 16930 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 KE NET F. LEWIS, ESQ. Attorney for Plaintiff 1.D. #69383 1101 N. Front st. HarriSburg, PA 17102 (717) 234-3136 ':'f~lJli"l.\.", ."" __<_ " ~. ~~ .- -~ -,--. ., , ~ ~ - r '," '~--"-"-~ ,- ""---"" .~~= 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: E & J Trucking, Inc. RR 1, Box 6B Liberty, PA 16930 ~L,"IS' ESQUIRE Attorney for Plaintiff Dated: 11/16/01 ,'- ,- ,,"; ",--' '~--;" - '" - - ,- ,'"" , ,o,~, _ ~",' ,~_" E5 B"i ."~. _~,_ .." 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