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Home My WebLink About99-03180 DOUGLAS, DOUGLAS & DOUGLAS 27 W. HIGH ST. POII 261 CARLISLE. PA 17013 Tr;I.EPIIONE 717-243.1790 MARY A. REDD, 5510 Campbell Avenue, Richmond, VA 23231, WILLIAM P. DOUGLAS, ESQ. _$_ Supreme Court I.G,H 37926 GEORGE K DOUGLAS, III, ESQ. Supreme Court LOA 61896 .... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA PLAINTIFF 1999- 3180 CIVIL TERM u, PILOT CORPORATION, 5508 Lonas Road, Knoxville, IN 37909, To: Curtis R. Long, Prothonotary CIVIL ACTION LAW PRAECYPE Please issue a writ of summons in a civil action against the within-named defendant, Pilot Corporation. DOUGLAS, DOU AS & DOUGLAS Date: May 25, 1999 by ?... Attorney for the Pla tiff f rn r Wo a zq? c a Mary A. Redd 5510 Campbell Avenue Richmond, VA 23231 County of Cumberland (SEAL) (xtis_ R? ACTL4--------------------------- Prothonotary Pilot Corporation 5508 Lonas Road Knoxville, TN 37909 Commonwealth of Pennsylvania Court of Common Pleas VL No. -----------x ?Qt To ---Pilot-CcvgPoratiott--------------------- You are hereby notified that --------------------------- Mary-A.-Redd --------------------------------------- the Plaintiff hag commenced an action in __.__ Ciyil Law---------------------- against you which you are required to defend or a default judgment may be entered against you. Date -------MU-Z. ---------------- 19.29_ By --`S.c??d?v1.t1'--------'--' Deputy z ?i c RC 0 O .r, J a •O N ? b i ri M i i O ;?Na cry ? ; a ? ?3 ? x N C] ? ? N V MARY A. REDD IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA V. CIVIL ACTION - LAW NO. 99-3180 CIVIL TERM PILOT CORPORATION JURY TRIAL DEMANDED PROOF OF SERVICE Please file this proof of service on the defendant, Pilot Corporation, in this case. DOUGLAS, DOUGLAS & DOUGLAS By us 1 qa June 4, 1999 William P. Douglas, Esquire Attorney for Plaintiff Atty. I.D. #37926 27 West High Street P.O. Box 261 Carlisle, PA 17013 717-243-1790 2forNmtloerl I aim with to receive the 1 4o & b. , - following services lfor an extra raw...r w+. larm se tlnt we em d :., feel: e item of dr "WAPIM. er m dr bsek M specs 1. QQ A ddr ease's Address / Atpwwb"antne MSlpeoebebwtM ertlAenuniber ? • 2. W'1ReetrOcted DOWNY e I iamore ixvmOrMrarbe?waen CormiAt sterforfee. o: ed ta t ei' 4s, 4cpcie Nwnber 1?1-. 3 4b. Service Type, 0.S r„ 1 Insured n cReowo er"w o cW +??e 13 Ewes ma Q 11 110%Pt for - Merehs 16 3 7. Dots of Delivery a. Adtlroaaee'e Address (Drdy if relpreeted and fee It peld) h ti9t avaaearteteadratd DOMESTIC. RETURN RECEIPT r r r N n uJ l) LI: U. ij. uj U CP i 6 6040 T. A WILLIAM P. DOUGLAS, ESQUIRE ATTY. I.D. # 37926 DOUGLAS, DOUGLAS & DOUGLAS 27 W. HIGH ST. POB 261 CARLISLE PA 17013 TELEPHONE 717-243-1790 ATTORNEY FOR PLAINTIFF MARY A. REDD V. PILOT CORPORATION IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW NO. 99-3180 CIVIL TERM JURY TRIAL DEMANDED 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. Legal Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 DOUGLAS, DOUGLAS &DOUGLAS Dated: _ OCT (? ?2 1poo C ' By William P. Douglas, Esquire Attorney for Plaintiff % COMPLAINT 1. The plaintiff, Mary A. Redd, is an individual residing at 5406 Campbell Avenue, P.O. Box 38104, Richmond, VA 23231. 2. The defendant, Pilot Corporation, has a facility located at 1165 Harrisburg Pike, Carlisle, Cumberland County, Pennsylvania, with a service address of 5508 Lonas Road, Knoxville, TN 37909. 3. Suit was started by writ of summons on May 26, 1999, and was served by certified mail, return receipt requested, on June 1, 1999. Proof of Service was filed with the Prothonotary on June 4, 1999. 4. At or about 7:30 A.M. on September 20, 1997, the plaintiff was driving a truck for Prime, Inc., and stopped at the Pilot facility in Middlesex Township, Cumberland County, Pennsylvania. While walking in front of her truck, she slipped on an oily-like substance which had been allowed to accumulate. As a direct and proximate result of the defendant's negligence, the plaintiff fell on her hands and knees at the Pilot facility. 5. The defendant knew or should have known that an oily-like substance had collected on the walk area of the island, and posed a danger to their business invitees. 6. The defendant took no corrective actions and failed to warn their customers of the dangerous condition with respect to the accumulation of an oily-like substance on the walk area open to customers. 7. As a direct and proximate result of the accident, the plaintiff was injured. Those injuries include, but are not limited to, her wrist/hand and knee. 8. As a direct and proximate result of the injuries suffered by the plaintiff, she has undergone and will continue to undergo great pain, suffering, aggravation, inconvenience, embarrassment, mental anguish, emotional and psychological trauma, and loss of life's pleasures. 9. The plaintiff has incurred, and may continue to incur, expenses to assist her in her day-to-day living. 10. As a direct and proximate result of the accident, the plaintiff has lost wages, may continue to do so in the future, and her economic horizons may be limited. WHEREFORE, it is prayed that judgment be entered in favor of the plaintiff and against the defendant in an amount in excess of that requiring compulsory arbitration under the Local Rules of Court. A jury trial is hereby demanded. DOUGLAS, DOUGLAS & DOUGLAS By William. P. Douglas, Esquire Attorney for Plaintiff 27 West High Street Carlisle, PA 17013 717-243-1790 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS. VERIFICATION I verify that the statements made in the foregoing document are true and correct, to the best of my knowledge, information, and belief. I understand that false statements herein made are subject to the provisions of 18 Pa. C.S.A. § 4904 relating to unworn falsification to authorities. ®C 1 R Aq Date AAR-Jed a "' M J Ci I O C? pOn U MARY A. REDD, Plaintiff V. PILOT CORPORATION, Defendant Sir: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3180 CIVIL TERM JURY TRIAL DEMANDED PRAECIPE Please enter our appearance for the defendant. ADDAMS & RUNDLE By: wlliaM A. Addams Supreme Court I.D. No. 06265 28 South Pitt Street P.O. Box 208 Carlisle, PA 17013 (717) 249-8300 TO: Curtis R. Long, Prothonotary DATE: November 4, 1999 o5 n MARY A. REDD, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-3180 CIVIL TERM PILOT CORPORATION, Defendant JURY TRIAL DEMANDED ANSWER AND NOW, comes the Defendant, Pilot Corporation, by its attorneys, Addams & Rundle, and makes the following answer to the Plaintiff's complaint: 1. Admitted. 2. Admitted. 3. Admitted. 4. After reasonable investigation, the Defendant is without knowledge sufficient to form a belief as to the truth of the averments. The same are therefore denied. 5. Denied in accordance with Pa. R.C.P. 1029(e). 6. Denied in accordance with Pa. R.C.P. 1029(e). 7. After reasonable investigation, the Defendant is without knowledge sufficient to form a belief as to the truth of the averments regarding the Plaintiff's injuries and damages. The same are therefore denied. 8-10. The answer to Paragraph 7 is incorporated herein by reference. WHEREFORE, the Defendant requests the complaint be dismissed. ADDAMS & RUNDLE O William A. Addams Supreme Court I.D. No. 06265 28 South Pitt Street P.O. Box 208 Carlisle, PA 17013 (717) 249-8300 Attorneys for Defendant CERTIFICATE OF SERVICE AND NOW, this 12th day of November, 1999, I, William A. Addams, of Addams & Rundle, attorneys for Defendant Pilot Corporation, hereby certify that I have served a copy of the Answer by mailing a copy of the same by United States mail, postage prepaid, addressed as follows: William P. Douglas, Esquire Douglas, Douglas & Douglas 27 West High Street P.O. Box 261 Carlisle, PA 17013 r',7 MARY A. REDD, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. PILOT CORPORATION, NO. 99-3180 CIVIL TERM Defendant : JURY TRIAL DEMANDED PRAECIPE Please withdraw the appearance of Addams & Rundle and enter the appearance of the Law Office of Michael J. Hanlt for Defendant Pilot Corporation in the above captioned matter. LAW OFFICE OF MICHAEL J. HANFT By: William A.*Addams Attorney I.D. No. 06265 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013 (717) 249-5373 TO: Curtis R. Long, Prothonotary DATE: April 6, 2001 F:WU r F.Ida:m IkwdWUVII].1'pnmipe.. pd ?- ff? I, l\' ?T ?? ,1? •_? _7 `. ? _ '.f 7 1 :7 c ii;i L.- IIL ? ? .) ; f. .;,_? i? PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) M THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: (Check one) ( X) for JURY trial at the next term of civil court. ( ) for trial without a jury. ----------------------------------------- CAPTION OF CASE (entire caption must be stated in full) (check one) MARY A. REDD, (Plaintiff) VS. PILOT CORPORATION (Defendant) VS. ( X) Civil Action - Law ( ) Appeal from Arbitration (other) The trial list will be called on ?6J 8/14/01 Trials camience on 9/10/01 Pretrials will be held on 8/22/01 (Briefs are due 5 days before pretrials.) (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214.1.) No. 3180 Civil 19 99 Indicate the attorney who will try case for the party who files this praecipe: William A. Addams for the Defendant Indicate trial counsel for other parties if known: William P. Douglas, Esq. for the Plaintiff This case is ready for trial Signed: Print Name: William A. Addams Defendant fate: 6/15/2001 Attorney for: ?. ,., r ??. -? s _ ,; ?_ ,, ? ?, - `i t - ?_? :., .? •_ ?? <? DOUGLAS, DOUGLAS & DOUGLAS 27 W. HIGH ST. x WILLIAM P. DOUGLAS, ESQ. POB 261 Supreme Court LOO 37926 CARLISLE PA 17013 TELEPHONE 717.243.1790 GEORGE F. DOUGLAS, BI, ESQ, Supreme Court I.D.# 61886 .__ _......_..... IN THE .................... OF COURT OF LEAS MARY A. REDD, COMMONP CUMBERLAND COUNTY PENNSYLVANIA i PLAINTIFF 1999- 3180 CIVIL TERM PILOT CORPORATION, CIVIL ACTION LAW To: Curtis R. Long, Prothonotary PRAECIPE Please mark the above-captioned matter settled and discontinued with prejudice. DOUGLAS, DO S & UGLAS Date: August 13, 2001 by1 Attorney for the Plai tiff Cr dl • t'. -C .n C : ?') ?.r „ t c_; CJ'+ ..... . "' _] ` "1: . it ]_ ! i __ ' .) . Ci (?