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HomeMy WebLinkAbout99-06927MORGAN & MORGAN, P.C. BY: SCOTT W. MORGAN. ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 JAMES YOUNG 324 Lincoln Way West Chambersburg, PA 17201, v. WILLIS VANCE PERSON 331 Meadow Lane Shippensburg, PA 17257 and BETTY J. BASS 137 Oak Flat Road Newville, PA 17241, NOTICE ai?LL 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. ATTORNEYS FOR PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. Plaintiff : NO. 1 "l - kP7 CIVIL ACTION - LAW JURY TRIAL DEMANDED • `J Defendants- Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AVI O Le han demandado a usted en la corte. Si usted defenderse de estas demandas expuestas en law paginas siguientes, usted tiene veinte (20) dins de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, is corte tomara medidas y puede continuer is demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decodor a favor del demandante y requiere que usted cumpla con todas law provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE ELDINERO SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 MORGAN & MORGAN, P.C. BY: SCOTT W. MORGAN. ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 ATTORNEYS FOR PLAINTIFF JAMES YOUNG : IN THE COURT OF COMMON PLEAS 324 Lincoln Way West : CUMBERLAND COUNTY, PENNA. Chambersburg, PA 17201, Plaintiff N0. 9 `1 • ("7 -2 7 ?'-""r T'`•`"' V. CIVIL ACTION - LAW WILLIS VANCE PERSON JURY TRIAL DEMANDED 331 Meadow Lane Shippensburg, PA 17257 and BETTY J. BASS 137 Oak Flat Road Newville, PA 17241, Defendants COMPLAINT Plaintiff, by and through his attorneys, Morgan & Morgan, P.C., hereby complains against Defendants and avers as follows: 1. Plaintiff is an adult individual residing at the above address. 2. Defendants are adult individuals residing at the above addresses. 3. On or about August 31, 1998, Plaintiff was operating a motor vehicle, and was stopped at the intersection of North Main Street and King Street in Chambersburg, Pennsylvania, when he was struck in the rear by a vehicle owned by Defendant Bass and operated by Defendant Person. -_ :'2 * ...? 4. As a result of the collision, Plaintiff suffered severe and disabling injuries, which are continuing. 5. At all times material hereto, Defendant person operated the vehicle owned by Defendant Bass with the latter's knowledge and consent. 6. As a result of the accident, Plaintiff injured his nerves, bones, muscles, joints and fascia, suffered pain and suffering, mental and emotional distress, which is continuing. 7. As a result of his injuries, Plaintiff incurred medical bills for care, treatment and rehabilitation, he lost earnings and/or earning capacity, and suffered loss of life's pleasures and diminution of daily activities, which are continuing. 8. Asa further result of the accident, Plaintiff incurred financial loss due to the damage and loss of use of the vehicle he was operating. COUNTI PLAINTIFF v. DEFENDANT PERSON 9. Plaintiff incorporates herein by reference the allegations of paragraphs I through 8, as if fully set forth at length. 10. Plaintiffs injuries and damages were due to the negligence of Defendant, individually, jointly and/or severally, including: A. Failing to keep a proper lookout; B. Striking the rear of Plaintiffs vehicle; C. Traveling at an unsafe speed; D. Failing to keep his vehicle under proper and adequate control; E. Failing to slop his vehicle in the assured clear distance ahead; F. Failing to warn Plaintiff of an unreasonable risk of harm; G. Violating state laws and local ordinances relative to the above allegations of negligence. WHEREFORE, Plaintiff demands judgment against Defendant, individually, jointly and/or severally, in an amount in excess of $25,000.00, exclusive of interest, costs and delay damages. COUNT II PLAINTIFF v. DEFENDANT BASS 11. Plaintiff incorporates herein by reference the allegations of paragraphs 1 through 10, as if fully set forth at length. 12. Plaintiffs injuries and damages were due to the negligence of Defendant, individually, jointly and/or severally, including, allowing Defendant Person to operate her vehicle with actual or constructive knowledge that he was incapable or incompetent of safely operating the vehicle. WHEREFORE, Plaintiff demands judgment against Defendant, individually, jointly and/or severally, in an amount in excess of $25,000.00, exclusive of interest, costs and delay damages. MORGAN & MORGAN, P.C. By // S tt W Morgatt?, Es uir DATED: Atto eys for Plaintiff, James Young .:: wrJ VERIFICATION James Young states that he is Plaintiff in this matter, and that the statements made in the foregoing Complaint are true and correct to the best of his knowledge, information and belief. He understands that the statements in said pleading are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. ]am Young 1v-as-?s?9 -Pi F ''1 n t- _ u r?' c= cr3p??? Q J (y X 8 nc s QJ rO ? W (f n - a z? c? V .fir ,..*t MORGAN & MORGAN, P.C. BY: SCOTT W. MORGAN, ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 JAMES YOUNG Plaintiff ATTORNEYS FOR PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. V NO. 99-6927 Civil CIVIL ACTION - LAW WILLIS VANCE PERSON and JURY TRIAL DEMANDED BETT Y J. BASS Defendants PLAINTIFF'S REPLY TO NEW MATTER . OF DEFENDANT BETTY J. BASS Plaintiff, through his attorneys Morgan & Morgan, P.C., hereby responds to New Matter of Defendant Betty Bass, and avers as follows: 13-19. The allegations of these paragraphs are denied as conclusions of law to which no answer is required and they are deemed denied. Plaintiff incorporates herein by reference the allegations of his complaint. MORGAN & MORGAN, P.C. By cott . Mor an, squire Attorneys for Plaintiff, James Young DATED: January 31, 2000 QR CERTIFICATE OF SERVICE I, Michele E. Neff, of the firm Morgan & Morgan, P.C., hereby certify that service of a true and correct copy of the within Plaintiff's Reply to New Matter was made on this day of January, 2000, to the persons below named, by First Class United States Mail, postage prepaid. Karen Durkin, Esquire JAMES, SMITH, DURKIN & CONNELLY, LLP P. O. Box 650 Hershey, PA 17033-0650 MORGAN & MORGAN, P.C. Michele P. Neff, Legal Assistt to Scott W. Morgan, Esquire 120 South Street Harrisburg, PA 17101-1210 (717) 236-7959 Attorneys for Plaintiff :: ;i- -? ::'; " _ ?•5: _ .__ lJ S I i?) L ?.I L_ _ I •.. °7 ? - ? ? :> I . ..::,.: .......... _ ___i-,._-_ _._._ MORGAN & MORGAN, P.C. BY: SCOTT W. MORGAN, ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 ATTORNEYS FOR PLAINTIFF JAMES YOUNG 324 Lincoln Way West Chambersburg, PA 17201, v. WILLIS VANCE PERSON 331 Meadow Lane Shippensburg, PA 17257 and IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. Plaintiff NO. 99-6927 Civil Defendants : CIVIL ACTION -LAW JURY TRIAL DEMANDED PRAECIPE TO REINSTATE COMPLAINT BETTY J. BASS 137 Oak Flat Road Newville, PA 17241, TO THE PROTHONOTARY: Kindly reinstate the Complaint against Defendant Willis Vance Person, in the above-captioned matter. MORGAN & MORGAN, P.C. By Sc tt W. Morga , uire Attorneys for Plaintiff, James Young DATED: April 3, 2000 ? F .; r- --*V - m v: n -' CS i W D, MORGAN & MORGAN, P.C. BY: SCOTT W. MORGAN, ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236.7959 ATTORNEYS FOR PLAINTIFF JAMES YOUNG : IN THE COURT OF COMMON PLEAS 324 Lincoln Way West : CUMBERLAND COUNTY, PENNA. Chambersburg, PA 17201, Plaintiff NO. 99-6927 Civil V. : CIVIL ACTION - LAW WILLIS VANCE PERSON JURY TRIAL DEMANDED 331 Meadow Lane Shippensburg, PA 17257 and BETTY J. BASS 137 Oak Flat Road Newville, PA 17241, Defendants PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint against Defendant Willis Vance Person, in the above-captioned matter. MORGAN & MORGAN, P.C. By ott . Morga squire Attorneys for Plaintiff DATED: January _j_, 2000 r O n . , i CASE NO: 1999-06927 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND YOUNG JAMES VS PERSON WILLIS VANCE CHRISTOPHER EVANS Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within NOTICE & COMPLAINT was served upon BASS BETTY J the DEFENDANT , at 0019:00 HOURS, on the 24th day of November , 1999 at 137 OAK FLAT ROAD NEWVILLE, PA 17241 by handing to BETTY BASS a true and attested copy of NOTICE & COMPLAINT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service 8.06 Affidavit .00 Surcharge 8.00 .00 22.06 Sworn and Subscribed to before me this day of n a o-o-0 A.D. a f ?1t 100 (Prothonotary So Answers: R. Thomas Kline 12/30/1999 MORGAN & MOR By: ?isZ Deputy Sheriff SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1999-06927 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND YOU14G JAMES VS PERSON WILLIS VANCE 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: PERSON WILLIS VANCE but was unable to locate Him deputized the sheriff of FRANKLIN serve the within NOTICE & COMPLAINT County, Pennsylvania, to On December 30th , 1999 , this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge . 8.00 DEP. FRANKLIN CO 26.70 .00 61.70 12/30/1999 MORGAN & MORGAN So ans ers: R. Thomas Kline Sheriff of Cumbecland County Sworn and subscribed to before me this /Z_ day of ,7.07ro A.D. C, Yk-?'J Prothonotary in his bailiwick. He therefore 11 SHERIFF'S RETURN - NOT FOUND I' CASE NO: 1999-06927 T COMMONTWEALTH OF PENNSYLVANIA COUNTY OF FRANKLIN YOUNG JAMES I VS PERSON WILLIS VANCE ETAL ROBERT WOLLYUNG Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named to wit: PERSON WILLIS VANCE but was unable to locate Him in his bailiwick. He therefore returns the the within named NOT FOUND , as to PERSON WILLIS VANCE USED TO LIVE W/HEATHER BASS UNTIL 5/99 BOTH MOVED AND LEFT NO FORWARDING ADDRESS Sheriff's Costs: So answers: Docketing 9.00 Service 5.00 Affidavit 4.00 I i Surcharge .00 er o yung, ZI1 Mileage 8.70 --Zb.7U- CJBE$LAND COUNTY SHERIF 12/17/1999 Sworn and subscribed to before me this ZaTH day of DECEMBER A.D. 11 ?_ NOTARIAL SEAL PATRICIA A. STRINE. Notary Public Chambersburg, Franklin County M commission Ex fires Nov. 4.2000 In The Court of Common Pleas of Cumberland County, Pennsylvania James Young vs. Willis Vance Person, et. al. Serve: Willis Vance Person No. 99-6927 Civil Now, 11/18/99 , 19_, I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Vumherland County, PA Affidavit of Service Now, 19_, at o'clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sheriff of COSTS Sworn and subscribed before SERVICE me this - day of , 19 MILEAGE _ AFFIDAVIT County, PA 1 $ o ? U ICY' V ? t 3 ? z LL O `U c? U JAMES YOUNG, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-6927 CIVIL WILLIS VANCE PERSON and BETTY J. : CIVIL ACTION - LAW BASS, Defendants JURY'fRIAL DEMANDED NOTICE TO PLEAD To: James Young and his attorney, Scott W. Morgan and Willis Vance Person YOU ARE HEREBY NOTIFIED to file a written response to the enclosed Answer with New Matter and Crosselaim within twenty (20) days from service hereof or ajudg;ment may be entered against you. Respectfully submitted, JAMES, SMITH, DURKIN & CONNELLY, LLP Dated: By: 'RKIN, ESQUIRE OAttomcyl.D. 429 563 3 JOHN J. MCNALLY, III, ESQUIRE Attorney I.D. #52661 P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Defendant Bass JAMES YOUNG. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-6927 CIVIL WILLIS VANCE PERSON and BETTY J. BASS, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED ANSWER WITH NEW MATTER AND CROSSCLAIM OF DEFENDANT BETTY J. BASS AND NOW, comes the Defendant, Betty J. Bass, by and through her attorneys, James, Smith, Durkin & Connelly, LLP, to Answer Plaintiffs Complaint and aver New Matter and Crossclaim as follows. Admitted. 2. Admitted. 3. Admitted. 4. Denied. After reasonable investigation, the Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of paragraph four (4) and strict proof of the same is demanded at trial. 5. Denied. It is specifically denied that Defendant Person operated the vehicle with the knowledge and consent of the Answering Defendant, and strict proof thereof is demanded at trial. 6. Denied. After reasonable investigation, the Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of paragraph six (6) and strict proof of the same is demanded at trial. Denied. Alter reasonable investigation, the Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of paragraph seven (7) and strict proof of the same is demanded at trial. 8. Denied. After reasonable investigation, the Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of paragraph eight (8) and strict proof of the same is demanded at trial. COUNTI PLAINTIFF v. DEFENDANT PERSON 9. The answers in paragraphs one (1) through eight (8) are incorporated herein by reference. 10. The averments in paragraph ten (10) are directed to a party other than the Answering Defendant, and no responsive pleading is required. WHEREFORE, Defendant Betty J. Bass respectfully requests that this Honorable Court enterjudgment in her favor and against the Plaintiff, together with costs. COUNTII PLAINTIFF v. DEFENDANT BASS 11. The answers in paragraphs one (1) through ten (10) are incorporated herein by reference. 12. Denied. The averments in paragraph twelve (12) as to negligence are conclusions of law to which no responsive pleading is deemed necessary, and strict proof thereof is demanded at trial. By way of further answer, it is specifically denied that the Answering Defendant allowed Defendant Person to operate said vehicle. WHEREFORE, Defendant Betty J. Bass respectfully requests that this Honorable Court enter judgment in her favor and against the Plaintiff, together with costs. NEW MATTER II The answers in paragraphs one (1) through twelve (12) are incorporated herein by reference. 14. Plaintiffs alleged injuries and damages were caused or contributed to by the negligent acts and/or omissions of individuals other than the Answering Defendant. 15. The Plaintiffs actions are barred or limited pursuant to the terms of the Pennsylvania Motor Vehicle Responsibility Act. 75 Pa.C.S. § 1701 et seg., the provisions of which are incorporated herein by reference. 16. Plaintiffs Complaint fails to state a claim upon which relief can be granted. IT At no time did Defendant Bass give permission to Defendant Person to operate her vehicle. 18. On August 31, 1998, Defendant Person operated Defendant Bass's vehicle without her knowledge or permission. 19. On August 31, 1998, Defendant Person was not an agent, servant or employee of Defendant Bass. NEW MATTER IN THE NATURE OF A CROSSCLAIM PURSUANT TO Pa.R.C.P. 2252(d) BETTY.1. 13ASS v. WILLIS VANCE PERSON 20. The averments in paragraphs thirteen (13) through nineteen (19) are incorporated herein by reference. 21. If Plaintiff sustained damages, said damages were caused in whole or in part by the negligence of Defendant Willis Vance Person, which is set forth in Count I of Plaintiffs Complaint, and which is incorporated herein for purposes of this Crossclaim. 19. Defendant Bass joins Defendant Person to preserve her right of contribution or indemnification. 20. If liability is found on the part of Defendant Bass, such liability being specifically denied, then Defendant Person is solely or jointly liable, or liable over to Defendant Bass for contribution, indemnification or both, plus costs. WEIEREFORE, Defendant Betty J. Bass respectfully requests judgment in her favor and against the Plaintiff. In the alternative, it is respectfully requested that this Honorable Court enter judgment in favor of Defendant Bass and against Defendant Willis Vance Person as being jointly or severally liable or liable over to Defendant Bass for contribution, indemnification or both. Dated: Respectfully submitted, JAMES, SMITH, DURKIN & CONNELLY, LLP By: A IN, ESQUIRE A orney ID #29563 JOHN J. MCNALLY, III, ESQUIRE Attorney ID 952661 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 Attorneys for Defendant M VERIFICATION The undersigned, BETTY J. BASS, hereby verifies that the facts set forth in the Answer with New Matter are true and correct to the best of her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. 6 _ / BETTY J!Ba S CERTIFICATE OF SERVICE 1, KAREN DURKIN, ESQUIRE, do hereby certify that I served a true and correct copy of the foregoing Answer with New Matter and Crossclaim upon the following below-named individual(s) by depositing same in the U.S. Mail, postage pre-paid at Ilershey, Dauphin County, Pennsylvania this _;&y day of January, 2000. SERVED UPON: Scott W. Morgan, Esquire Morgan & Morgan, P.C. 120 South Street Harrisburg, PA 17101-1210 L K D -in, squire AMES, SMITH, DURKIN & CONNELLY, LLP '' C?, U' UJIP C"] h CL- LO -- 1..8W a o z 7 z ON 6 a W 2 h JAMES YOUNG. V. : IN TIIE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6927 CIVIL WILLIS VANCE PERSON and BETTY J. CIVIL ACTION - LAW BASS, Defendants JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the undersigned on behalf of Defendant Betty J. Bass only, with respect to the above-captioned matter. Respectfully submitted, JAMES, SMITH, DURKIN & CONNELLY, LLP Dated: / 3 #j By. 0 URKIN, ESQUIRE Attorney I.D. #29563 JOHN J. MCNALLY, Ill, ESQUIRE Attorney I.D. #52661 P.O. Box 650 1lershey, PA 17033-0650 (717) 533-3280 Attorneys for Defendant Bass CERTIFICATE OF SERVICE 1, KAREN DURKIN. ESQUIRE, do hereby certify that I served a true and correct copy of the foregoing Entry of Appearance upon the following below-named individual(s) by depositing same in the U.S. Mail, postage pre-paid at Hershey. Dauphin County. Pennsylvania this /_3 day of January, 2000. SERVED UPON: Scott W. Morgan, Esquire Morgan & Morgan, P.C. 120 South Street Harrisburg, PA 17101-1210 aren Durkin, Esquire JAMES, SMITH, DURKIN & CONNELLY, LLP NIORGAN & MORGAN. P.C. BY: SCOTT W. MORGAN. ESQUIRE IDENTIFICATION NO. 367221 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 JAMES YOUNG, Plaintiff V. WILLIS VANCE PERSON and BETTY J. BASS, Defendants ATTORNEYS FOR PLAINTIFF IN TI-IE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 99-6927 Civil CIVIL ACTION - LAW JURY TRIAL DEMANDED AFFIDAVIT OF SERVICE OF COMPLAINT ON DEFENDANT WILLIS PERSON TO THE PROTHONOTARY: rtifies that pursuant to Pa.R.C.P. 403, he did serve by The undersigned hereby ce certified mail, return receipt requested, a copy of the complaint in this action on Willis Vance Person at General Delivery, Creedmore, NC 27522, on or about March 9, 2000; and, that the Defendant Willis Vance Person refused the certified mailing as is evidenced by the attached notation on the envelope from the U.S. Postal Service, attached hereto as Exhibit 'IN'; and, that the undersigned thereafter served the complaint on Defendant Willis Vance Person by sending the complaint to him at the above address by regular mail on April 11, 2000, and that the mailing was not returned within fifteen (15) days after the said date of mailing. Sworn to and subscribed before me this ??ay of 6 L 2000. ?/ ???0-r-1/?,a l? Notar Public F My Commission Expires: MORGAN & MORGAN, P.C. ,w. for NOTARIAL SEAL MICHELE E. NEFF, NOTARY PUBLIC HARRISBURG, DAUPHIN COUNTY MY COMMISSION EXPIRES MAY 9, 2002 c N l IiI 1 I _1 I c G a ? Q' N H N z a >, u z a o In N U a > u; H o m U a z z ? z G] G A < O L] V' CQ C ^ C m Er, r.• N 3 C7 U C L r ,r. a > L - v O Q N L1 W ? O G' C? a v 1. 11 EXHIBIT "All tr r i i i ; MORGAN & MORGAN, P.C. BY: SCOTT W. MORGAN. ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 ATTORNEYS FOR PLAINTIFF JAMES YOUNG : IN THE COURT OF COMMON PLEAS 324 Lincoln Way West : CUMBERLAND COUNTY, PENNA. Chambersburg, PA 17201, Plaintiff : NO. 99-6927 Civil V. : CIVIL ACTION -LAW WILLIS VANCE PERSON : JURY TRIAL DEMANDED 331 Meadow Lane Shippensburg, PA 17257 and BETTY J. BASS 137 Oak Flat Road Newville, PA 17241, Defendants PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint against Defendant Willis Vance Person, in the above-captioned matter. MORGAN & MORGAN, P.C. By ?i Scott W. Morgan Esquire Attorneys for Plaintiff, James Young DATED: May 15, 2000 IJ!C? C; la. Cl c? S Cr J MORGAN & MORGAN, P.C. BY: SCOTT W. MORGAN, ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 ATTORNEYS FOR PLAINTIFF JAMES YOUNG IN THE COURT OF COMMON PLEAS 324 Lincoln Way West CUMBERLAND COUNTY, PENNA. Chambersburg, PA 17201, Plaintiff NO. 99-6927 Civil V. : CIVIL ACTION- LAW WILLIS VANCE PERSON JURY TRIAL DEMANDED 331 Meadow Lane Shippensburg, PA 17257 and BETTY J. BASS 137 Oak Flat Road Newville, PA 17241, Defendants PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint against Defendant Willis Vance Person, in the above-captioned matter. MORGAN & MORGAN, P.C. ) By -&A Scott W. Morgan, Esquir Attorneys for Plaintiff, James Young DATED: June 9- 2000 C\ r ti. C7 1 Ild I III YHIIlI11I®1111 MORGAN & MORGAN, P.C. BY: SCOTT W. MORGAN, ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG. PA 17101-1210 (717) 236-7959 ATTORNEYS FOR PLAINTIFF JAMES YOUNG : IN THE COURT OF COMMON PLEAS 324 Lincoln Way West : CUMBERLAND COUNTY, PENNA. Chambersburg, PA 17201, Plaintiff NO. 99-6927 Civil V. : CIVIL ACTION - LAW WILLIS VANCE PERSON JURY TRIAL DEMANDED 331 Meadow Lane Shippensburg, PA 17257 and BETTY L BASS 137 Oak Flat Road Newville, PA 17241, Defendants PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint against Defendant Willis Vance Person, in the above-captioned matter. MORGAN & MORGAN, P.C. By ? u. Scot . Morg squire Attorneys for Plaintiff, James Young DATED: July 11, 2000 y C`.; CV n. t .. v U SHERIFF'S RETURN - NOT FOUND CASE NO: 1999-06927 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND YOUNG JAMES VS PERSON WILLIS VANCE 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 PERSON WILLIS VANCE but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , REINSTATED , NOT FOUND , as to the within named DEFENDANT , PERSON WILLIS VANCE DEFT. DOES NOT RESIDE AT EITHER ADDRESS STATED, UNEMPLOYED, PAPER COULD NOT BE SERVED PRIOR TO EXP. Sheriff's Costs: So ans s: Docketing 18.00 Service 7.44 ?f NOT FOUND RETURN 5.00 RI/Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 40.44 MORGAN & MORGAN 06/22/2000 Sworn and subscribed to before me this 4 G day of .2&&d A.D. ?Q71e OP•,o". PYoLYhonotary ' 1 MORGAN & (ORGAN, P.C. BY: SCOTT W. MORGAX, ESQU12 E IDENTIFICATION NO. 36721 120 SOUTH STREET H-•1RRISBURG, PA 17101-1110 (717) 236-7959 ATTORNEYS FOR PLAINTIFF JAMES YOUNG : IN THE COURT OF COMMON PLEAS 324 Lincoln Way West : CUMBERLAND COUNTY, PENNA. Chambersbur„ PA 17201, Plaintiff : NO. C 1 - k l LL V. CIVIL ACTION - LAW rr- WILLIS VANCE PERSON JURY TRIAL DEMANDED 331 Meadow Lane Shipoensburg, PA 17257 and BETTY" J. BASS 137 Oak Flat Road Ne•.vviile. PA 17241. JCL %. j^ y-=?J^ pj De:endaets u 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 (30) days after this complaint and notice are served, by entering a written appearance oersonaily or by attorney and filing in writing with the tour your defenses or objections to the claims se., 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 tour without further notice for any monev claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights imponartr to You. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT F.AVE A LAWYER OR CANNOT AFFORD ONE. CO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO ::.,ND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AVIS Le ban demandado a usted en la corte. Si usted defenderse•de estas demandas expuestas en law paginas siguientes, usted tiene veime (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la come en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, is come tomara medidas y puede continuer is demanda en contra suya sin previo aviso o notificacion. Ademas, la cone puede decodor a favor del demandante y requiere que usted cumpla con todas law provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importances para usted. LLEVE ESTA DENIANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE ELDINERO SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 MORGAN & MORGAN, P.C. BY: SCOTT W. MORGAN. ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717)1236-7959 JAMES YOUNG 324 Lincoln Way West Chaanbersburg, PA 17201, v. WIL-LIS VANCE PERSON 331 Meadow Lane Shippensburg, PA 17257 and BETTY J. BASS 137 Oak Flat Road Nevrville. PA 17241, ATTORNEYS FOR PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA. Plaintiff Defendants : NO. CIVIL ACTION - LAW JURY TRIAL DEMANDED COMPLAINT Plaintiff, by and through his attorneys, Morgan & Morgan, P.C., hereby complains against Defendants and avers as follows: 1. Plaintiff is an adult individual residing at the above address. 2. Defendants are adult individuals residing at the above addresses. 3. On or about August 31, 1998, Plaintiff was operating a motor vehicle, and was stopped at the intersection of North Main Street and King Street in Chambersburg, Pennsylvania, when he was struck in the rear by a vehicle owned by Defendant Bass and operated by Defendant Person. 4. As a result of the collision, Plaintiff suffered severe and disabling injuries, which are continuing. 5. At all times material hereto, Defendant person operated the vehicle owned by Defendant Bass with the latter's knowledge and consent. 6. As a result of the accident, Plaintiffinjured his nerves, bones, muscles, joints and fascia, suffered pain and suffering, mental and emotional distress, which is continuing. 7. As a result of his injuries, Plaintiff incurred medical bills for care, treatment and rehabilitation, he lost earnings and/or earning capacity, and suffered loss of life's pleasures and diminution of daily activities, which are continuing. 8. As a further result of the accident, Plaintiff incurred financial loss due to the damage and loss of use of the vehicle he was operating. COUNTI PLAINTIFF v. DEFENDANT PERSON 9. Plaintiff incorporates herein by reference the allegations of paragraphs I through 8, as if fully set forth at length. 10. Plaintiffs injuries and damages were due to the negligence of Defendant, individually, jointly and/or severally, including: A. Failing to keep a proper lookout: B. Striking the rear of Plaintiffs vehicle; C. Traveling at an unsafe speed; D. Failing to keep his vehicle under proper and adequate control; E. Failing to stop his vehicle in the assured clear distance ahead; F. Failing to warn Plaintiff of an unreasonable risk of harm; G. Violating state laws and local ordinances relative to the above allegations of negligence. WHEREFORE, Plaintiff demands judgment against Defendant, individually, jointly and/or severally, in an amount in excess of $25,000.00, exclusive of interest, costs and delay damages. COUNT II PLAINTIFF v. DEMNI ANT BASS 11. Plaintiff incorporates herein by reference the allegations of paragraphs I through 10. as if fully set forth at length. 12. Plaintiffs injuries and damages were due to the neglieence of Defendant. individually, jointly and/or severally, including, allowing Defendant Person to operate her vehicle with actual or constructive knowledge that he was incapable or incompetent of safely operating the vehicle. WHEREFORE, Plaintiff demands judgment against Defendant, individually, jointly and/or severally, in an amount in excess of $35,000.00, exclusive of interest, costs and delay damages. MORGAN & MORGAN. P.C. By - Scott Wiblorgati?-Es uir DATED' Attoteevs for Plaintiff. James Young VERIFICATION James Young states that he is Plaintiff in this matter, and that the statements made in the foregoing Complaint are true and correct to the best of his knowledge, information and belief. He understands that the statements in said pleading are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. • ?t James Young L• a J - :::ice ? Nor - '` 14 I I , ry-. '? li?lr I17 1.Sf.? MORGAN & MORGAN. P.C. BY: SCOTT W. MORGAN. ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 ATTORNEYS FOR PLAINTIFF JAMES YOUNG : IN THE COURT OF COMMON PLEAS 324 Lincoln Way West : CUMBERLAND COUNTY, PENNA. Chambersburg, PA 17201, Plaintiff NO. 99-6927 Civil V. : CIVIL ACTION -LAW WILLIS VANCE PERSON JURY TRIAL DEMANDED 331 Meadow Lane Shippensburg, PA 17257 and BETTY J. BASS 137 Oak Flat Road Newville, PA 17241, Defendants T PRAECIPE TO REINSTATE COMPLAIN TO THE PROTHONOTARY: Kindly reinstate the Complaint against Defendant Willis Vance Person, in the above-captioned matter. MORGAN & MORGAN, P.C. By Scott W. M r?;an, Esquire Attorneys f Plaintiff lames Young DATED:j,Iq(3Sfi?ICDO -' .. ._.. e si.? :? SHERIFF'S RETURN - NOT FOUND CASE NO: 1999-06927 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND YOUNG JAMES VS PERSON WILLIS VANCE 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 PERSON WILLIS VANCE but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , PERSON WILLIS VANCE DEFT. COULD NOT BE LOCATED AT ADDRESS STATED PRIOR TO EXPIRATION DATE OF 8/10/00, NO FWDG Sheriff's Costs: So answ : Docketing 18.00 Service 3.10 NOT FOUND RETURN 5.00 R. Thomas Klin - Surcharge 10.00 Sheriff of Cumberland County .00 36.10 MELISSA MERRITTS RIVERA 08/10/2000 Sworn and subscribed to before me this /yam day of .2o-vz) A. D. Pro otary MORGAN & MORGAN, P.C. BY: SCOTT W. MORGAN, ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 JAMES YOUNG 324 Lincoln Way West Chambersburg, PA 17201, Plaintiff V. WILLIS VANCE PERSON 331 Meadow Lane Shippensburg, PA 17257 and BETTY J. BASS 137 Oak Flat Road Newville, PA 17241, Defendants ATTORNEYS FOR PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA. NO. q4 0 7 : CIVIL ACTION -LAW JURY TRIAL DEMANDED - •, j.-n ?-7 b 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 AN GET LEGAL HELP. TRUE COPY FROtA R_ &4E In Tost ..1ony Vli10n1o1, l he,a unto SQt 7ny hand attt d tYe seal of said Coo (;artsio, Pa. LT By honorary Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AVISO Le han demandado a usted en la corte. Si usted defenderse• de estas demandas expuestas en law paginas siguientes, usted tiene veinte (20) dins de plazo al partir de la fecha de la demanda y la notification. Hace falta asentar una comparencia escrim o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, is corte tomara medidas y puede continuer is demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decodor a favor del demandame y requiere que usted cumpla con todas law provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importances para usted. LLEVE ESTA DENIANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE ELDINERO SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 MORGAN & MORGAN, P.C. BY: SCOTT W. MORGAN, ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 JAMES YOUNG 324 Lincoln Way West Chambersburg, PA 17201, v. WILLIS VANCE PERSON 331 Meadow Lane Shippensburg, PA 17257 and BETTY J. BASS 137 Oak Flat Road Newville, PA 17241, Plaintiff Defendants ATTORNEYS FOR PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. : CIVIL ACTION -LAW JURY TRIAL DEMANDED COMPLAIN T Plaintiff, by and through his attorneys, Morgan & Morgan, P.C., hereby complains against Defendants and avers as follows: 1. Plaintiff is an adult individual residing at the above address. 2. Defendants are adult individuals residing at the above addresses. 3. On or about August 31, 1998, Plaintiff was operating a motor vehicle, and was stopped at the intersection of North Main Street and King Street in Chambersburg, Pennsylvania, when he was struck in the rear by a vehicle owned by Defendant Bass and operated by Defendant Person. 4. As a result of the collision, Plaintiff suffered severe and disabling injuries, which are continuing. 5. At all times material hereto, Defendant person operated the vehicle owned by Defendant Bass with the latter's knowledge and consent. 6. As a result of the accident, Plaintiff injured his nerves, bones, muscles, joints and fascia, suffered pain and suffering, mental and emotional distress, which is continuing. 7. As a result of his injuries, Plaintiff incurred medical bills for care, treatment and rehabilitation, he lost earnings and/or earning capacity, and suffered loss of life's pleasures and diminution of daily activities. which are continuine. S. As a further result of the accident, Plaintiff incurred financial loss due to the damage and loss of use of the vehicle he was operating. COUNT I PLAINTIFF v. DEFENDANT PERSON 9. Plaintiff incorporates herein by reference the allegations of paragraphs 1 through S, as if fully set forth at length. 10. Plaintiffs injuries and damages were due to the negligence of Defendant, individually, jointly and/or severally, including: A. Failing to keep a proper lookout; B. Striking the rear of Plaintiffs vehicle; C. Traveling at an unsafe speed; D. Failing to keep his vehicle under proper and adequate control; E. Failing to stop his vehicle in the assured clear distance ahead; F. Failing to warn Plaintiff of an unreasonable risk of harm; G. Violating state laws and local ordinances relative to the above allegations of negligence. WHEREFORE, Plaintiff demands judgment against Defendant, individually, jointly and/or severally, in an amount in excess of $25,000.00, exclusive of interest, costs and delay damages. COUNT II PLAINTIFF v. DEFENDANT BASS 11. Plaintiff incorporates herein by reference the allegations of paragraphs i through 10, as if fully set forth at length. 12. Plaintiffs injuries and damages were due to the negligence of Defendant. individually, jointly and/or severally, including, allowing Defendant Person to operate her vehicle with actual or constructive knowledge that he was incapable or incompetent of safely operating the vehicle. i I:WHEREFORE, Plaintiff demands judgment against Defendant, individually, jointly f and/or severally, in an amount in excess of $25,000.00, exclusive of interest, costs and delay _ t damages, t°r MORGAN & MORGAN, P.C. By Z?t _ Scott W Morgan; €s uir DATED: Ph fir AttoTfi-e*s for Plaintiff, James Young ,i 1{ Y 'i i VERIFICATION James Young states that he is Plaintiff in this matter, and that the statements made in the foregoing Complaint are true and correct to the best of his knowledge, information and belief. He understands that the statements in said pleading are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. i James Young oA 1 Hay a 2B 2 u, n C ?o? NI-n 4 AUG 1 5 200kJ LI MORGAN & MORGAN, P.C. BY: SCOTT W. MORGAN, ESQUIRE IDENTIFICATION NO. 36721 BY: MELISSA MERRtTTS RIVERA, ESQUIRE IDENTIFICATION NO. 70303 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 JAMES YOUNG 324 Lincoln Way West Chambersburg, PA 17201, V. WILLIS VANCE PERSON 331 Meadow Lane Shippensburg, PA 17257 and BETTY J. BASS 137 Oak Flat Road Newville, PA 17241, Plaintiff Defendants ATTORNEYS FOR PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 99-6927 Civil : CIVIL ACTION -LAW JURY TRIAL DEMANDED ORDER AND NOW, this I6?% day of , 2000, it is hereby ORDERED that Plaintiff's Motion to Serve Process on Defendant, Willis Vance Person, by Publication is GRANTED. BY TH R . J. NO Previ Refillne pj% Mwg 1 error AUG l 5 2000?J MORGAN & MORGAN, P.C. BY: SCOTT W. MORGAN, ESQUIRE IDENTIFICATION NO. 36721 BY: MELISSA MERRITTS RIVERA, ESQUIRE IDENTIFICATION NO. 70303 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 ATTORNEYS FOR PLAINTIFF JAMES YOUNG : IN THE COURT OF COMMON PLEAS 324 Lincoln Way West : CUMBERLAND COUNTY, PENNA. Chambersburg, PA 17201, Plaintiff N0. 99-6927 Civil V. CIVIL ACTION - LAW WILLIS VANCE PERSON JURY TRIAL DEMANDED 331 Meadow Lane Shippensburg, PA 17257 and BETTY J. BASS 137 Oak Flat Road Newville, PA 17241, Defendants ORDER AND NOW, this l6, day of &Un , 2000, it is hereby ORDERED that Plaintiff's Motion to Serve Process on Defendant, Willis Vance Person, by Publication is GRANTED. BY TH R • J. NO _. ? .. -_ . !' Q L??J ?LI^.t ! ?? i 11 •}. .Iv MORGAN & MORGAN, P.C. BY: SCOTT W. MORGAN, ESQUIRE IDENTIFICATION NO. 36721 BY: MELISSA MERRITTS RIVERA, ESQUIRE IDENTIFICATION NO. 70303 120 SOUT11 STREET IIARRISBURG, PA 17101-1210 (717) 236-7959 ATTORNEYS FOR PLAINTIFF JAMES YOUNG IN THE COURT OF COMMON PLEAS 324 Lincoln Way West CUMBERLAND COUNTY, PENNA. Chambersburg, PA 17201, Plaintiff NO. 99-6927 Civil V. : CIVIL ACTION -LAW WILLIS VANCE PERSON JURY TRIAL DEMANDED 331 Meadow Lane Shippensburg,PA 17257 and BETTY J. BASS 137 Oak Flat Road Newville, PA 17241, Defendants PLAINTIFF'S MOTION TO SERVE PROCESS ON DEFENDANT WII LIS VANCE PERSON. BY PUBLICATION 1. Plaintiff, James Young, filed this action against Defendant Betty J. Bass and Willis Vance Person, for damages stemming from personal injuries. 2. Plaintiff has been unable to perfect service on Defendant, Willis Vance Person. 3. Service has been perfected on Betty J. Bass, in connection with this litigation and her discovery deposition has been obtained. 4. Plaintiff has reinstated said Complaint, attached hereto as Exhibit "A," seven (7) times, while searching for an address on Willis Vance Person as follows: A. A Shippensburg address was provided by the police accident report and the sheriff attempted service but was unable to deliver. Attached hereto as Exhibit "B." B. Plaintiff then hired API Investigations, who conducted computer traces. API Investigation found a social security number with a North Carolina address. Attached as Exhibit "C." C. Plaintiff served Defendant, Person by way of registered mail and the document was returned to us by U.S. Postal Service, showing that it was refused. Affidavit of Service is attached hereto as Exhibit "D." D. Plaintiff was advised by counsel to Bass that Defendant Person was employed in the Carlisle, PA area and, Ave were given a Carlisle, PA home address. Once again, the sheriff attempted service at both addresses and was unable to serve Defendant Person. Sheriffs return, not found attached hereto as Exhibit "E." E. Plaintiff conducted the deposition of Betty J. Bass and learned that Defendant Person was living in the Carlisle, PA area but she did not have a specific address. Transcript excerpt attached hereto as Exhibit "F." F. Plaintif7'then conducted the deposition of Heather Marie Bass, Heather Bass gave Plaintiffa description of an address in Carlisle, PA. She also informed Plaintiff that Mr. Person is aware that a lawsuit has been filed against him because she informed him. Transcript excerpt attached hereto as Exhibit "G." G. Once attain, Cumberland County Sheriff has attempted service in Carlisle, PA. On Wednesday, August 9, 2000, Plaintiff received verbal confirmation from the Sheriff that service was not perfected. 5. Plaintiff is represented by this counsel and Defendant Bass is represented by Karen Durkin, Esquire, P. O. Box 650, Hershey, PA 17033-0650. Defendant Person is unrepresented to our knowledge. WHEREFORE, Plaintiff requests this court to enter an Order allowing service on Defendant, Willis Vance Person by way of publication. Respectfully submitted, MORGAN & MORGAN, P.C. By :g , Meliss Merritts Rivera, Esquire DATED: August 11, 2000 Attorneys for Plaintiff, James Young MORGAN & MORGAN, P.C. BY: SCOTT W. MORGAN, ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG. PA 17101-1210 ATTORNEYS FOR PLAINTIFF -- - (717) 236-7959 JAMES YOUNG : IN THE COURT OF COMMON PLEAS 324 Lincoln Way West : CUMBERLAND COUNTY, PENNA. Chambersburg, PA 17201, Plaintiff NO. Cl V. CIVIL ACTION - LAW WILLIS VANCE PERSON JURY TRIAL DEMANDED _ = J 331 Meadow Lane = Shippensburg, PA 17257 and BETTY J. BASS _ 137 Oak Flat Road Newville. PA 17241, 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 vou. 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 [he 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 RFI ()W TO FIND OUT WHI tx 6.AN GET LEGAL HELP. EXHIBIT "A" IJC- CC?Y Fsot.1 R: La "X.10??'"'it•°.I?t i i;fs:2 UP?7 £:ii ?,•pi13t3d i C?ayid Codf' u,;5?t, nolarY a Cy C6 r r*6 2? 1J a? c' _ S y J ?---- - ';r ?-- ?'- ---- ice. _ a. r J-d 2 CG o 0 r ? c? ? y 13 y SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1999-06927 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND YOUNG JAMES VS PERSON WILLIS VANCE R. Thomas Kline Sheri -f 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: PERSON WILLIS Vp_NCE but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within NOTICE & COMPLAINT On December 30th X999 this Of f.'1CE SJdS in reCElpt OL the attached return from FPANKLIN Sheriff's Costs: Docketing 18.00 Out of Countv 9.00 Surcharge 8.00 DEP. FRnVKLIN CO 26.70 .00 0'1.70 12/30/.1999 MORGAN & MORG< R. Thomas Kline Sheriff of Cumberland Count:v Sworn and subscribed to before me this day of A. D. Prcthonotarv EXHIBIT "B" So ansv?ers SHERIFF'S RETURN - NOT FOUND CASE NO: 1999-06927 T COMMONTWEALTH OF PEWSYLVANIA COUNTY OF FRANKLIN YOUNG JAMES VS PERSON WILLIS VPVCE ETAL ROBERT WOLLYUNG Deoucv according. to.-law.,- says,. that he. made- a. the within named to ' PERSON WILLIS VANCE unable to locate Him in his bailiwick Sheriff, diligent ,/it: He the who being duly sworn search. for but was refore returns the NOT FOUND , as to PERSON WILLIS VPVCE the within named USED -TO LIVE W/HEATHER BASS UNTIL 5/99 BOTH MOVED AND LEFT NO FORWARDING ADDRESS Sheriff's Costs: So answers: Docketing 9.00 Service 5.00 Affidavit 4.00 R3oer? o__yurc sne Surcharge .00 Mileage 8.70 zo. /u CLTMEE/?D COUNTY SHERI?_ Sworn and subscribed to before me this Z?ITH day of DECEMBER AID. NOTARIAL SEAL PATRICIA A. STRINE. Notary Public Chambarsburq. Franklin County My Commission t::oires Nov. 4. 2000 NVESTIGATIONS s« icing PA, NY, b10, 01;, N,1, WV, FL, DE, RI & VA License #11-2843 Vishnesky & Associates ' - P.O. 13ox 129 • Marysville, Pennsylvania 17053"-- (717) 957-3900 • 1.800-745-8236 INVESTIGATION REPORT FAX (717) 957-4218 / FAX 1.800-379-7891 Willis Vance Person Case No: 08MOR01-5919-00 January 26, 2000 Assionment On January 10, 2000, Scott Morgan of Morgan & Morgan, requested an investigation on Willis Vance Person. Mr. Morgan's office was updated on January 26, 2000. This file is on hold. Synopsis Computer traces were conducted on the Subject to obtain a current address. The Subject's social security number which is 293-31- 6787 was obtained. The last reported address for the Subject was General Delivery, Creedmoor, NC 27522 as of December 1998. No other addresses were reported. File Report 1 L:\?10R5418.-%M0R ?000 Invns: 500 0005 EXHIBIT "C" MORGAN & NIORGAN. P.C. BY: SCOTT W. NIORGAN. ESQUIRE IDENTIFICATION NO. 367,21 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 ATTORNEYS FOR PLAINTIFF JAMES YOUNG, Plaintiff V. WILLIS VANCE PERSON and BETTY J. BASS, Defendants IN THE COURT OF COMMOLq LEA CUMBERLAND COUNTY, PI{[a1 <.. NO. 99-6927 Civilc :n CIVIL ACTION - LAW JURY TRIAL DEINIANDED AFFIDAVIT OF SERVICE OF COMPLAINT ON DEFENDANT WILLIS PERSON TO THE PROTHONOTARY: The undersigned hereby certifies that pursuant to Pa.R.C.P. 403, he did serve by certified mail, return receipt requested, a copy of the complaint in this action on Willis Vance Person at General Delivery. Creedmore. NC 27522, on or about March 9, 2000; and. that the Defendant Willis Vance Person refused the certified mailing as is evidenced by the attached notation on the envelope from the U.S. Postal Service, attached hereto as Exhibit "A"; and, that the undersigned thereafter served the complaint on Defendant Willis Vance Person by sending the complaint to him at the above address by regular mail on April 11, 2000, and that the mailing was not returned within fifteen ( l5) days after the said date of mailing. Sworn to and subscribed NIORGAN & MORGAN. P.C. before me this "-,'"day of ?24:r.l 2000. B r-, Scott W. iVlor=an,,Esquire :\Jorvy Public =DAUPHIN evs for Plaintiff AL - Viv Commission Expires: RY PUBLIC EXHIBIT "D" IN COUNTY MAY 9.2002 ?J L 47 /t ?I HI L. Z Z N V] N L- t C >. to ZI t.. cl G N UI Sn > C U ? ? Z G Z `I b G; - `' L•• V1j C7 L n., < c co 72 I n r? I z 1 r L .. i \ i f i ? r t S EXHIBIT "A" .CASE NO: 1999-06927 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND YOUNG JAMES VS PERSON WILLIS VANCE 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 but was PERSON WILLIS VANCE unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE REINSTATED NOT FOUND , as to the within named DEFENDANT PERSON WILLIS VANCE DEFT. DOES NOT RESIDE AT EITHER ADDRESS STATED, UNEMPLOYED, PAPER COULD NOT BE SERVED PRIOR TO EX P. Sheriff's Costs: So answ- Docketing 16.00 Service 7.44 NOT FOUND RETURN 5.00 R. Thomas Kline Surcharge 10.00 Sherif-- of Cumberland County .00 40.44 MORGAN & MORGAN 06/22/2000 Sworn and subscribed to before me EXHIBIT "E" this day of A.D. Prothonotary 1 1 JAMES YOUNG, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA 2 VS. NO. 99-6927 CIVIL 3 WILLIS VANCE PERSON CIVIL ACTION - LAW -A _ -and-BETTY J'. BASS; JURY-TRIAL--DEMANDED --- ---"- Defendants. 5 6 a'G??pL O 7 8 9 Deposition of: BETTY J. BASS 10 Taken by: Plaintiff 11 Before: Susan O'Hara, RPR, RMR Notary Public 12 Date: June 19, 2000, 10:00 a.m. 13 Location: Morgan & Morgan 14 120 South Street Harrisburg, Pennsylvania 15 16 17 APPEARANCES: 18 MORGAN & MORGAN 19 3Y: MELISSA MERRITTS RIVERA, ESQUIRE FOR - PLAINTIFF 20 KAREN DURKI N, ESQUIRE EXHIBIT "F" 21 FOR - DEFENDANTS 22 ALSO PRESENT: 23 DICK?-, McCAMEY & CHILCOTE BY: BRANT T. MILLER, ESQUIRE 24 FOR - UNI-MART 25 1 1 L 1 1 li 11 1! 2( 2: 2: 2: 2? 2` 6 1 A. I'm just saying possibly then. I'm not 2 really sure. "s Q. Okay. Now, did Mr. Person ever stay over at 4 your home? i A. Not that I ca:i recall. i Q. Okay. How often in 1998 would you see Mr. Person? 3 A. On an average of once a week. 3 Q. What would be the nature of your visit with him? A. He would come down to our place with my daughter when she come down to visit. Q. Do you still see Mr. Person today? A. Not for a while r haven't. Q. When was the last time you saw him? A. It's probably been two months. Q. And the last time you saw him, approximately two months ago, what was the nature of your visit then? A. He was visiting with my daughter's baby, which is his. Q. Does your daughter still have a relationship with Mr. Person? A. No, just visitation rights for the baby. Q. Do you know where Mr. Person resides right now? 1 A. All I know, Carlisle. 2 Q. Okay. Now, on August 31, '98, you owned a 3 1994, is it Hyundai Ela, E-1-a? -- - 4 -- - ---A•- -Elantra- -- -- -- -- -- -'-- 5 Q. Did you own any other vehicles at that time? 6 A. well, no, not in my name. 7 Q. In your name? 8 A. No. 9 Q. Okay. 10 A. I'm trying to think. 11 Q. On August 31, 198, your Elantra was involved 12 in an accide nt. Are you aware of that? 13 A. Yes. 14 Q. Can you tell me who was driving your car at 15 the time the accident occurred? 16 A. All I know is what I was told that Willis 17 Person was d riving. 19 Q. Who told you that? 19 A. I had a police officer call me. 20 Q. Was anybody in the car with Mr. Person at the 21 time of the accident? 22 I cannot tell you. • 23 Q. i Back in zkugust of 198, can you tell me who 24 would common ly drive your Elantra besides vou? Who else 25 would drive the car? 1 2 3 -A 5 6 7 e 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 JAMES YOUNG, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-6927 Civil WILLIS VANCE PERSON : CIVIL ACTION - LAW --and--BET-TY -J.- BASS,- - Defendants. JURY TRIAL DEMANDED _II 111 1L? Deposition of: HEATHER MARIE BASS Taken by: Plaintiff Before: Amy R. Fritz, Notary Public Registered Professional Reporter Date: July 6, 2000, 2:40 p.m. Place: Morgan & Morgan 120 South Street Harrisburg, Pennsylvania APPEA-4ANCES : MORGAN & MORGAN BY: MELISSA MERR I TTS -RIVERA, ESQUIRE FOR - PLAINTIFF JAMES, SMITH & DURKIN c ? !f BY: KAREN DURKIN, ESQUIRE [?61 h)i t 11 FOR - DEFENDANT a Court Reportinq Services (800)863-3657 or (717)258-3657 or fastfngers@aol.com 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. No. Q. Do you know where he's employed? A. Not at the moment. His father just passed away. He had to lose the job he did have. Q. How did you learn that his father passed away and that he lost his job? A. I mean, he calls me every night to see what his daughter's doing. Q. Do you know the telephone number from where he calls you? A. Yeah. It's 241-4471. Q. Do you ever see him in person with your daughter? A. When I take her down there. Q. When you take her down there to see him, where do you meet up with him? A. In Carlisle on the main street. I don't know many streets. I'm not very good. Q. Do you know his Social Security number? A. No. Q. Do you know his birthday? A. 7/1, I'm guessing it's 163. He just turned -- I think he just turned 37. Q. Just a couple days ago? A. Yeah. central eennsylvania Court Reporting Services (800)863-3657 or (7:7)258-3657 or fastfngers@aol.com U 12 1 Q. Do you know who that gentleman is that he lives 2 with? 3 A. It's a long story; it's just a friend of his. 4 Q. Do you know that person's name, is what I'm 5 wondering. 6 A. They call him Tommy. 7 Q. Do you know his official name? 8 A. No. I don't know it because it's Chinese. He's 9 Chinese. I don't know. 10 Q. Okay. Is it in an apartment complex or on a 11 main street? Do you know that? 12 A. It's on a main street. It's, like, on the third 13 floor. 14 Q. Is it -above any particular -- you know how they 15 have window fronts along the main streets? 16 A. Yeah. 17 Q. is it above any particular store or anything? 18 A. There's a tattoo place down below. 19 Q. Do you know the name of the tattoo place? 20 A. No. 21 Q. Do you know if it's on a corner of a main street 22 and another street? 23 A. It's right up from where they recently had that 24 fire at Classic Rags and that movie theater, that old movie 25 theater. Central Pennsylvania Court Reporting Services (800)863-3657 or (717)258-3657 or fastfngers@aol.com u I3 1 Q. Have you ever been up into the apartment? 2 A. Yeah. 3 Q. Anybody else live there besides Mr. Person and 4 Tommy? 5 A. My sister did, but she just recently moved out. 6 Q. What is your sister's name? 7 A. Susan'Bass. That's her maiden name. Her 8 married name is Little. 9 Q. The tattoo parlor that the apartment is above, 10 is that on a corner? 11 A. No. 12 Q. Do you know what the intersecting street is with 13 the main street that's closest to that tattoo place? 14 A. There's a -- I know there's -- I think it's Pitt 15 Street. And I think the street that they're on, it's West 16 High Street, I think. I'm not actually sure. I do 17 remember them saying that. 18 MS. RIVERA: Thank you. 19 MS. DURKIN: I have a couple questions for you, 20 Heather. 21 BY MS. DURKIN: 22 Q. You said your mom bought the car for you? 23 A. Yeah. 24 Q. Did she buy the car for you before or after you 25 moved in with Mr. Person? Central Pennsylvania Court Reporting Services (800)863-3657 or (717)258-3657 or fastfngers@aol.com 17 1 A. If he knew how to drive a car. 2 Q. Yes. How would he know how to drive a car if he 3 never had a car, he never had a license? ------q-- ------- P_: -He-had-a-car. down. in_North-.Carolina. _ But since 5 he's been up here, he hasn't had one. 6 Q. So he's driven a car before? 7 A. Down in North Carolina. 8 Q. Does Mr. Person know that there's been a lawsuit 9 filed against him? 10 A. Yeah. 11 Q. How does he know that? 12 A. I told him. 13 Q. Did he ever tell you whether he knew he should 14 not have been driving the car at the time of the accident? 15 A. He apologized to my mother and myself. 16 Q. When did he polocize? 17 A. Right after the accident. 18 Q. And what did he say? 19 A. He just said I'm sorry. 20 Q. Did he say he was sorry for the accident or he 21 was sorry for taking your car? 22 P-. Sorry for the accident, just -- he was just 23 sorry, I guess, period. He didn't really say which. 24 Q. At the time you were living with him, did he 25 1 have a job? Central Pennsylvania Court Reporting Services (800)863-3'057 or (717)258-3657 or fastfngers@aol.com CERTIFICATE OF SERVICE 1, Michele E. Neff, Legal Assistant for Melissa Merritts Rivera, Esquire, hereby certify that service of the original within Motion to Serve Process on Defendant by Publication, and proposed Order, was made on this 11 ih" day of August, 2000, to the persons below named, by First Class United States Mail, postage prepaid. Karen Durkin, Esquire JAMES, SMITH, DURKIN & CONNELLY, LLP P. 0. Box 650 Hershey, PA 17033-0650 MORGAN & MORGAN, P_ C. ylu Michele E. Neff, Legal Assis ai t to Melissa Merritts Rivera, Esquire 120 South Street Harrisburg, PA 17101-1210 (717) 236-7959 Attorneys for Plaintiff MORGAN & MORGAN, P.C. BY: SCOTT W. ,MORGAN, ESQUIRE IDENTIFICATION NO. 36721 BY: MELISSA MERRITTS RIVERA. ESQUIRE IDENTIFICATION NO. 70303 120 SOUTH STREET HARRISBURG, PA 17101-1210 (7I? 236-7959-----_.--- JAMES YOUNG 324 Lincoln Way West Chambersburg, PA 17201, Plaintiff V. WILLIS VANCE PERSON 331 Meadow Lane Shippensburg, PA 17257 and BETTY J. BASS 137 Oak Flat Road Newville, PA 17241, Defendants ATTORNEYS FOR PLAINTIFF-- IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 99-6927 Civil CIVIL ACTION - LAW JURY TRIAL DEMANDED PLAINTIFF'S MOTION TO SERVE PROCESS ON DEFENDANT, WILLIS VANCE PERSON BY PUBLICATION Plaintiff. James Young, tiled this action against Defendant Betty J. Bass and Willis Vance Person, for damages stemming from personal injuries. 2. Plaintiff has been unable to perfect service on Defendant, Willis Vance Person. 3. Service has been perfected on Betty J. Bass, in connection with this litigation and her discovery deposition has been obtained. P_ - y"Cm 4. Plaintiff has reinstated said Complaint, attached hereto as Exhibit "A," seven (7) times, while searching for an address on Willis Vance Person as follows: A. A Shippensburg address was provided by the police accident report and the sheriff attempted service but was unable to deliver. Attached hereto as Exhibit "B." B. Plaintiff then hired API Investigations, who conducted computer traces. API Investigation found a social security number with a North Carolina address. Attached as Exhibit "C." C. Plaintiff served Defendant. Person by wav of registered mail and the document was returned to us by U.S. Postal Service, showing that it was refused. Affidavit of Service is attached hereto as Exhibit "D." D. Plaintiff was advised by counsel to Bass that Defendant Person was emploved in the Carlisle, PA area and, we were given a Carlisle, PA home address. Once again, the sheriff attempted service at both addresses and was unable to serve Defendant Person. Sheriffs return, not found attached hereto as Exhibit "E." E. Plaintiff conducted the deposition of Betty J. Bass and learned that Defendant Person was living in the Carlisle, PA area but she did not have a specific address. Transcript excerpt attached hereto as Exhibit "F." F. Plaintiff then conducted the deposition of Heather Marie Bass, Heather Bass gave Plaintiffa description of an address in Carlisle, PA. She also informed Plaintiff that Mr. Person is aware that a lawsuit has been filed against him because she informed him. Transcript excerpt attached hereto as Exhibit "G." G. Once again, Cumberland County Sheriff has attempted service in Carlisle, PA. On Wednesday, August 9, 2000, Plaintiff received verbal confirmation from the Sheriff that service was not perfected. __5.- Plaintiffis-represented.by-this.counsel-and-Defendant Bass-is represented Karen Durkin, Esquire, P. 0. Box 650, Hershey, PA 17033-0650. Defendant Person is unrepresented to our knowledge. WHEREFORE, Plaintiff requests this court to enter an Order allowing service on Defendant, Willis Vance Person by way of publication. Respectfully submitted, MORGAN & MORGAN, P.C. By ?? '-•? ' Me iss Merri is Rivera, Esquire DATED: August 11, 2000 Attorneys for Plaintiff, James Young; CERTIFICATE OF SERVICE I, Michele E. Neff, Legal Assistant for Melissa Merritts Rivera, Esquire, hereby certify that service of the original within Motion to Serve Process on Defendant by Publication, and proposed Order, was made on this ( I"v day of August, 2000, to the persons below named, by First Class United States Mail, postage prepaid. Karen Durkin, Esquire JAMES. SMITH. DURKIN & CONNELLY. LLP P. 0. Box 650 Hershey, PA 17033-0650 MORGAN & MORGAN. P.C. J Nlichel'e E. Neff, Legal Assistant to Melissa Merritts Rivera. Esquire 120 South Street Harrisburg, PA 17101-1210 (717) 236-7959 Attorneys for Plaintiff V c, C> =s c7 %cn ? `?... t j _3L u f QQ Q ?N vJ ti JAMES YOUNG, V. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6927 CIVIL WILLIS VANCE PERSON and BETTY J BASS, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED VANCE PERSON BY PUBLICATION I - 5. Admitted. By way of further answer, Defendant Betty J. Bass joins with Plaintiff in his request upon the Court to enter an Order allowing service on Defendant Willis Vance Person by way of publication. WHEREFORE, Defendant Betty J. Bass requests this Court to enter an Order allowing service on Defendant Willis Vance Person by way of publication. Respectfully submitted, JAMES, SMITH, DURKIN & CONNELLY, LLP Dated: - / KAREN-DURKIN, ESQUIRE Attorney I.D. #29563 JOHN J. MCNALLY, III, ESQUIRE Attorney I.D. #52661 P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Defendant Bass CERTIFICATE OF SERVICE I, KAREN DURKIN, ESQUIRE, do hereby certify that I served a true and correct copy of the foregoing Motion upon the following below-named individual(s) by depositing same in the U.S. Mail, postage pre-paid at Hershey, Dauphin County, Pennsylvania this . 3' day of X000. SERVED UPON: Scott W. Morgan, Esquire Morgan & Morgan, P.C. 120 South Street Harrisburg, PA 17101-1210 Kder-LDtirkin, Esquire JAMES, SMITH, DURKIN & CONNELLY, LIT MORGAN & MORGAN, P.C. BY: SCOTT W. MORGAN, ESQUIRE IDENTIFICATION N0.36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 JAMES YOUNG 324 Lincoln Way West Chambersburg, PA 17201, Plaintiff V. WILLIS VANCE PERSON 331 Meadow Lane Shippensburg, PA 17257 and BETTY J. BASS 137 Oak Flat Road Newville, PA 17241, Defendants ATTORNEYS FOR PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 99-6927 Civil CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint against Defendant Willis Vance Person, in the above-captioned matter. MORGAN & MORGAN, P.C. By co W Mo g n, Esquire Attorneys for Plaintiff James Young DATED: September 5, 2000 - _? ;: _ _. = ; . .:, ,:_ , 4 ,,, Jt _. ?,: .. ?•_ '-i _. iJ MORGAN & MORGAN, P.C. BY: SCOTTW. MORGAN. ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 ATTORNEYS FOR PLAINTIFF JAMES YOUNG : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA. Plaintiff : NO. 99-6927 Civil V. : CIVIL ACTION -LAW WILLIS VANCE PERSON JURY TRIAL DEMANDED and BETTY J. BASS Defendants ORDER TO SETTLE DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above matter settled, discontinued and ended upon payment of your costs, only. MORGAN & MORGAN, P.C. S . Morg, Esquire Attorney for Plaintiff DATED: March U 1 2001 :n T ?? c.. , .J? .? 1? ?) '?? ?? ?? '.? _i U 'i J#4 .r TO LAW OFFICE .. YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED WITHIN JAMES, SMITH, DURKIN & CONNELLY, LLP A TRUES ANDS CORECTTCOTHE PYOF WITHIN TWENTY IEOI DAYS OF SERVICE HER WITHIN THE A DEFAULT JUDGMENT MAY BE ENTERED ORIGINAL AGAINST FILED IN THIS ACTION. YOU. P. Q bOX 650 . BY BY AM.NEY HERSHEY, PENNSYLVANIA 17033-0650 ATIOFNEY 4:uou¢"`tir? t Y 1 I '.r ?. t i 1 E n i t