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Home My WebLink About99-069980 'C! COUNTY OF CUMBERLAND : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. WILLIAM H. PALMER, 111 : CIVIL ACTION - LAW Defendant : NO. CIVIL 199 cQ4-G9 E'i' l?l6lt NOTICE TO DEFEND 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 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 J1 ,. COUNTY OF CUMBERLAND Plaintiff IN THE COURT OF CONNION PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. WILLIAM 1-1. PAU IER, 111 : CIVIL ACTION - LAW Defendant NO. CIVIL 1999- 6.,7 COMPLAIN' AND NOW, cones Robert C. Saidis, Esquire, Solicitor for the County of Cumberland, and avers the following cause of action as follows: I . Plaintiff is the County of Cumberland, a County of the Fourth Class, with its principle place of business at One Courthouse Square, Carlisle, Pennsylvania 17013. 2. Defendant, William li. Palmer, III resides at 40S N. West Street, Carlisle, PA 17013. 3. Plaintiff operates a transportation service for various eligible Cumberland County residents and utilizes various types of vehicles to provide said service. 3. On January 11, 1999, while driving a 1991 Cadillac on W. North Street in the Borough of Carlisle, Pennsylvania Defendant did hit Plaintiff's 1997 Ford small transit bus, number C2997, causing $430.60 ulanucge to Plaintiff's vehicle. A copy of the estimate for repairs is attached hereto and made a part hereof and marked Exhibit "A" 4. Defendant did execute a Statement of Responsibility dated January 15, 1999, accepting sole responsibility for the damage done to plaintiffs vehicle and promising to make payment for said damage in the amount of $430.60. A copy of said Statement of Responsibility is attached hereto and made a part hereof and marked Exhibit "B" 5. Said Statement of Responsibility states that the funds for the damage mist be paid to Plaintiff by February 3, 1999. 6. A letter was sent to Defendant dated May 7, 1999, from Robert C. Saidis, County Solicitor, requesting payment of the $430.60, attached hereto and made a part hereof and marked Exhibit "C". 7. As of the date of this Complaint no payment has been received by Plaintiff WHEREFORE, Plaintiff demands thatjudgment be entered in its favor and against the Defendant in the amount of 5430.60 plus costs. Respectfully sub 'tted Robert C. Saidis, Esquire Cumberland County Solicitor Attorney ID# 21453 Dille: '&' /? Iq " q VERIFICATION I, /)ev,,, e-e-1A _, i?r ?? t ?fLlEh^ 2J of County of Cumbc • . nd, the Plaintiff named in the foregoing Complaint, as such I am authorized to make this verification on Plaintiffs behalf and have knowledge of the facts set forth in the foregoing and that said facts are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of IS Pa. C. S. section 4904 relating to unswom falsification to authorities. Dated: AGy. A? 1999 O1:13168 11:00 FAX 717 240 6152 9AINIENANCE BAPN , MARTIN S PAINT BODY & TRIM 1419 TRINDLE ROAD CARLISLE, PA 17013 (717) 249-5351 FAX # (717) 249-0288 CD LOG NO 0003169 DATE 01/13/99 SHOP CONTACT: INSP DATE 01/13/99 OWNER CUMBERLAND COUNTY ADDRESS 1 COURTHOUSE SQUARE CITY STATE CARLISLE PA HOME PHONE ZIP 17013 WORY. PHONE 1001 LIC# VIN 1FDLE40F4VHB82820 E=NEW PART EC=ECONOMY PART EU=SALVAGE PART EPuSEE PX REPORT P=CHECK I-REPAIR/ALIGN/SUBLET L=REFINISH N-ADDN'L LABOR OPERATION TE=PART/PARTIAL REPLACE ET=LABOR/PARTIAL REPLACE IT=LABOR/PARTIAL REPAIR AA=APPEARANCE ALLOWANCE RP-RELATED PRIOR DAMAGE UP=UNRELATED PRIOR DAMAGE *=USER ENTERED VALUE 1997 FORD CLUB WAGON E350 P6157D/A OPTNS G/2 OPTIONS: TWO-STAGE - EXTERIOR SURFACES OP ODE MC DESCRIPTION MFG. PART NO. PRICE AJ% HOURS R I 207 DOOR SHELL,FRONT LT REPAIR/ALIGN 6.0*1 L 207 09 DOOR'SHELL,FRONT LT REFINISH 3.6 4 EC STRIPE ECONOMY PART 55.00* 1.0*1* 3 ITEMS MC MESSAGE 09 INCLUDES 0.6 HOURS MAJOR PANEL TWO-STAGE ALLOWANCE FINAL CALCULATIONS & ENTRIES GROSS PARTS OTHER PARTS PAINT MATERIAL PARTS TOTAL TAX ON PARTS LABOR RATE 1-SHEET METAL 30.00 2-MECH/IILEC 30.00 3-FRAME 30.00 4-REFINISH 30.00 S-PL7NT MATERIAL 16.00 GROSS' TOVA 55.00 57.60 112.60 @ .000w REPLACE HRS REPAIR HRS 1.0 6.0 210.00 3.6 108.00 Exhibit "A" 430.60 NANCY A. BESCH CHAIRMAN EARL R. KELLER VICE-CHAIRMAN MARCIA L. MYERS SECRETARY Carlisle - (717) 240-6340 Toll Free -1.800.315-2546 JOHN S. WARD CHIEF CLERK DENNIS R. MARION COUNTY ADMINISTRATOR NANCY K. OTSTOT DIRECTOR (IT 0-ountu Jaf auraberlartb Transportation Department Cumberland County Old Prison 37 E. High Street • Carlisle, PA 17013 (717) 697-0371, Ext 6340 - West Shore (717) 532-7286, Ext. 6FAX (717) 240-6479 STATEMENT OF RESPONSIBILITY January 15, 1999 I, William H. Palmed 7* 1 - 28 - /D3$ , accept sole responsibility for the damage done to Cumberland County Transportation Department's vehicle number C-2997 on January 11, 1999. 1 do hereby promise to make payment for said damage in the amount of $430.60. These funds are due to Cumberland County Transportation Department on February 3, 1999. Witness: Witness: Exhibit "B" William H. Palmer, III 408 N. West Street Carlisle, PA 17013 Dear Mr. Palmer: COMMISSIONGRS OF CUMIN-ULAND COUNTY One Courthouse Square • Carlisle, PA 17013 717-240.6150 • 697-0371, Ext.6150 532-7286,Ext.6150 • Fax:240.6448 May 7, 1999 RE: Damage to Cumberland County transportation vehicle number C-2997 Nancy A. Oescsi Chaff man Earl R. Keller We Chairman Marcia L Myers Seorewy Jahn S. Ward ChiefQerk Dennis H. Marlon Caunrymminhunnor Roben C. Saidis Solicitor Stephen D. Tiley Assnnant Sohdror The above referenced matter has been referred by the Cumberland County Transportation Department to the County Solicitor's Office for review and possible legal action. On January 15, 1999, you executed a Statement of Responsibility accepting sole responsibility for the damage done to Cumberland County Transportation Department's vehicle number C-2997 This accident occurred on January 11, 1999. According to that Statement you were to make payment for said damage in the amount of $430.60 on February 3, 1999. To date no payment has been received. To avoid possible legal action I am requesting that payment in the amount of $430.60 be made to Cumberland County within 15 days of receipt of this letter. Payment should be made to the Commissioners' Office, One Courthouse u e, Carlisle, PA 17013. I 1 crely, r Robert C. Saidis Solicitor cc: Nancy Otstot, Director CCTD Exhibit "C" Celebrate Cumberland County's 2501h Anniversary in the Year 2000 SHERIFF'S RETURN - REGULAR CASE NO: 1999-06998 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTY OF CUMBERLAND VS PALMER WILLIAM H III CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within NOTICE & COMPLA was served upon PALMER WILLIAM H III the DEFENDANT , at 0019:23 HOURS, on the 22nd day of December , 1999 at 408 N WEST CARLISLE, PA 17013 WILLIAM H. PALMER III a true and attested copy of by handing to ICE & COMPLAINT together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.10 Affidavit .00 Surcharge 8.00 .00 29.10 So Answers: R. Thomas Kline / 12/23/19 Sworn and Subscribed to before (T- me this V day of f'l.--u..7 ,7 trL"-' A.D. 724 (Pc.. L.?tJZ/ - UL, P'. - 'Prothonotary By: y