HomeMy WebLinkAbout99-07317i
DANIEL H. EICHENLAUB,
Plaintiff
V.
STEWART CRAIG,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1999- '73/7 CIVIL TERM
NOTICE
You have been sued in court. If you wish to def end 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 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 OUR WHERE YOU CAN GET
LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Telephone: (717) 249-3166
DANIEL H. EICHENLAUB, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 1999- 7,3/7 CIVIL TERM
STEWART CRAIG,
Defendant
COMPLAINT
AND NOW, comes the Plaintiff, Daniel H. Eichenlaub, by his
attorneys, Addams & Rundle, and makes the following complaint:
1. The Plaintiff is Daniel H. Eichenlaub, an adult
individual residing in Neelyton, Pennsylvania 17239.
2. The Defendant is Stewart Craig, an adult individual
residing at 16 Town Mills Mobile Home Park, Shippensburg,
Cumberland County, Pennsylvania 17257.
3. The Plaintiff is the owner of a 1993 Dodge Grand
Caravan which was being operated by Christina Marie Eichenlaub on
August 28, 1998 at about 4:30 p.m., traveling north on Route 11
in the Borough of Shippensburg, Cumberland County, Pennsylvania.
4. At said time and place, the Plaintiff's automobile was
stopped for traffic when the Defendant, operating a vehicle which
was also traveling north on Route 11, negligently and carelessly
collided with the rear end of the Plaintiff's vehicle causing the
damages hereinafter set forth.
5. The Defendant was negligent and careless in:
A. Traveling too fast for conditions.
B. Failing to observe the Plaintiff's vehicle in time
to avoid a collision.
C. Violating the assured clear distance ahead rule.
D. Failing to have his vehicle under control.
6. As a result of the negligence and carelessness of the
Defendant, the Plaintiff's vehicle sustained damage in the amount
of $5,419.
WHEREFORE, the Plaintiff demands judgment against the
Defendant in the amount of $5,419 plus interest and costs of
suit, an amount within the jurisdiction of arbitration under the
local rules of court.
ADDAMS & RUNDLE
By:
T William-K. Addams
Supreme Court I.D. No. 06265
28 South Pitt Street
P.O. Box 208
Carlisle, PA 17013
(717) 249-8300
Attorneys for Plaintiff
VERIFICATION
Daniel H. Eichenlaub hereby verifies that the facts set
forth in the foregoing Complaint are true and correct to the best
of his knowledge, information and belief, and understands that
false statements herein are made subject to the penalties of 18
Pa. C.S. §4904 relating to unsworn falsifications.
DATE: 102/399
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-07317 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
EICHENLAUB DANIEL H
VS.
CRAIG STEWART
DAWN KELL , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within NOTICE & COMPLAINT was served
upon CRAIG STEWART the
defendant, at 11:49 HOURS, on the 8th day of December
1999 at 16 TOWN MILLS MOBILE HOME PARK
SHIPPENSBURG, PA 17257 CUMBERLAND
County, Pennsylvania, by handing to COLLEEN CRAIG/WIFE
a true and attested copy of the NOTICE & COMPLAINT
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
13.02
.00
8.00 So answers:
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Thomas ine, e
2 DAMS
-1D/ 9/1999UNDLE
epu y 5 eri
Sworn and subscribe to before me
this 14 t- day o€?
],a ,9/t?a A.D.
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DANIEL H. EICHENLAUB, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. :NO. 1999-7317 CIVIL TERM
STEWART CRAIG,
Defendant
AFFIDAVIT
William A. Addams, being duly sworn according to law, deposes and says that the
judgment in the above captioned matter arises out of a motor vehicle accident.
HANFT & KNIGHT, P.C.
William A. Addams
Attorney I.D. No. 06265
19 Brookwood Avenue, Suite 106
Carlisle, PA 17013
(717) 249-5373
Sworn to and subscribed
before me this 4th day of June, 2002
f Al ) 7 ` • ?GCEi
Notary Public
rl Notarial soal
Mary M. Price, Nolary pubtlc
Carllsle Boro, Cumberland County
My Commission Expires Aug. I8, 219
° z?A
DL-201 (12.93)
Bureau of Driver Licensing
P.O. Box 60037
Harrisburg, PA 17106.0037
CERTIFICATION OF COURTC
MOTOR VEHICLE JUDGMENT COUNTY
NUMBER
IYEAR 1999
TO THE SECRETARY OF TRANSPORTATION
April 2, 2002 a judgment for S 2,481 •73 plus S 93.52
This is to certify that on (AMOUNT( (casT(
was entered against the following:
(Please use a separate form for each)
JUDGMENT DEBTOR
(Please Print or Type)
JUDGMENT CREDITOR
Daniel H. Eichenlaub
(NAME)
Box--46
(STREET ADDRESS)
Neelyton, PA 17239
(CITY L STATE) (ZIP(
ATTORNEY FOR
CREDITOR (if applicable)
William A. Addams
(NAME)
19 Brookwood Avenue, Suite 106
(STREET ADDRESS)
Carlisle, PA 17013
(CITY S STATE) (ZIP)
(717) 249-5373
(TELEPHONE NUMBER)
(TELEPHONE NUMBER)
THE ABOVE MENTIONED JUDGMENT AROSE FROM A MOTOR VEHICLE ACCIDENT. SIXTY DAYS HAVE ELAPSED SINCE
THE ENTRY OF SAID JUDGMENT, AND THE SAME HAS NOT BEEN SATISFIED OF RECORD AND NO APPEAL HAS BEEN
TAKEN THEREFROM.
IN WITNESS WHEREOF, I have hareunto affixed my hand and seat
or the court this Day of 19
SEAL
(SIGNATURE OF CLERK OR JUDGE OF THE
COURT IN WHICH THE JUDGMENT WAS RENDERED)
(TYPE OR PRINT NAME)
SEND THIS Bureau of Driver Licensing, P.O. Box 60037•
FORM TO: Harrisburg, Pennsylvania 17106.0037
? Check this block if defendant is a resident of another state
THE JUDGMENT
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