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Home My WebLink About07-4600WILLIAM A. ADDAMS, ESQUIRE ATTORNEY ID # 06265 43 W. SOUTH ST. P.O. BOX 261 CARLISLE PA 17013 TELEPHONE 717-243-7638 You have been sued in Court. If you wish to defend against the class 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 maybe entered against you by the Court without further notice for any money claimed in 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. Court Administrator Fourth Floor Cumberland County Court House Carlisle PA 17013 717-~4n_h~nn vvilliam A. Addams Attorney for Plaintiff ,_ AND now comes the plaintiff, MICK D. SPANGLER by his attorney, William A. Addams, and makes the following COMPLAINT 1. The plaintiff Mick D. Spangler, an adult individual, residing at 196 Evergreen Road, New Cumberland, PA 17070. 2. The defendant, Joe Prentice, is an adult individual residing at 2000 Hill St., Lebanon, PA 17046. 3. The plaintiff was the owner of a 2001 Mitsubishi Eclipse which he was driving in the left lane of Interstate 581 about 1/2 mile East of the Carlisle Pike Interchange on October 3, 2006, passing a tractor trailer owned and operated by defendant Prentice. 4. At that time and place, the defendant negligently and carelessly attempted to enter the left lane, collided with the plaintiff's vehicle and forced it into a concrete barrier. 5. The defendant was negligent and careless in: a• Failing to observe the plaintiff's vehicle in time to avoid a collision; b• Failing to have the vehicle under control; c• Attempting to change lanes when the movement could not be made in safety. 6• As a result of the negligence and carelessness of the defendant, the plaintiff's vehicle was a total loss. The Eclipse had an actual cash value of $9,509.37 and a net salvage value of $690, resulting in a loss in the amount of $8,819.37. WHEREFORE, the plaintiff demands judgment against the defendant in the amount of $8,819.37, plus interest and costs of suit, an amount within the jurisdiction of arbitration under the local rules of court. r .~~~ William A. Addams Attorney for the Plaintiff ., ,. VERIFICATION Mick D. Spangler hereby verifies that the facts set forth in the foregoing complaint are true and correct to the best of her knowledge, information and belief, and understands that false statements herein are made subject to the penalties of 18 PA. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: ~/v2~o ~ 9u O W Gp ~ ~ ~ ~ ~~: °~~ t•; ""f a. ? ~ ~ ~~ 0 v~> ;'fit a ~ a -_:_ c cJ 1 - v -~ -,' ~ ~ ~ ~ ~ ~ ~ ~ tss -< t ~ SHERIFF'S RETURN - OUT OF COUNTY CASE N0: 2007-04600 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPANGLER MILK D VS PRENTICE JOE 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 PENTICE JOE but was unable to locate Him deputized the sheriff of LEBANON to wit: in his bailiwick. He therefore serve the within COMPLAINT & NOTICE County, Pennsylvania, to On August 29th 2007 this office was in receipt of the attached return from LEBANON Sheriff's Costs: So answer~-~/~~-!~--- Docket ing 18.0 0 ,,~~ _ Out of County 9.00 '~ f Surcharge 10.00 R. -Thomas Klin POSTAGE .58 Sheriff of Cu nand County DEP LEBANON CO 42.35 79.93 ,/ 9~0~~0~ 4,,.. 00/00/0000 WILLIAM ADDAMS Sworn and subscribe to before me this day of A.D. r .~ • In The Court of Common Pleas of Cumberland County, Pennsylvania Mick D. Spanglsr VS. JoQ Pr~ticg 07-4600 civil No. Now, August 7, 2007 _ , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of iQbanon County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ,~ Sheriff of Cumberland County, PA Please mail return of service to Cumberland County Sheriff. Thank you. Affidavit of Service Now, within upon at by handing to a and made known to So answers, the contents thereof. Sheriff of Sworn and subscribed. before me this day of , 20 copy of the original COSTS SERVICE _ MILEAGE _ AFFIDAVIT County, PA 20 , at o'clock M. served the _~__ t- CML COMPLAINT N0.2007~600 Mick D. Spangler vs. Joe Prentice STATE OF PENNSYLVANIA } COUNTY OF LEBANON } SS: Cumberland County Sheriffs Office Fourth Floor Carlisle, PA 17013 (717) 2446200 (Return to Cumberland County) Docks! Page 25835 David A. Heath, Deputy Sheriff, being duly sworn acoorrling th ~rw, deposes and says that he served the within CIVIL COMPLAINT upon JOE PRENTICE, the within named DEFENDANT, by handing a true and attested copy thereof, personally: to SANDRA PRENTICE, she being his VNife and Person in Charge at the time ~ service on August 9, 2007 at 3:10 P.M., at 2000 HiN Street, Lebanon (North Lebanon Township), Lebanon County, Pennsyhrania, and by making known to her the contents of the same. Sworn to and subscribed before me this 20'" day of August, 2007 Notary Public NOTARIAL SEAL MELISSA A ZERBE Notary Public LEBANON CITY, LEBANON COUNTY My Commluion Ezpi~~,;j~~~} Advanced Costs paid on Costs lncumed: Amount of Refund: SO ANSWERS, ~~~ ~- ~'-~~ mz DEPUTY SHERIFF ~,sz-e~-Ica--- mz SHERIFF ~ !N ABOVE PROCEEDINGS Check No. 59774 Amount $ 150.00 Amount $ 42.35 Check No. Z09l~ Amount $ 107.65 All Sheriff's Costs shall be due and payable when servits3s are performed, and it shaft be lawful for him to demand and receir-e from the party instihating the proceedings, or any party liable for the costs thereof, ail unpaid sheriff's fees on the same before he sha!! be obligated by law to make return thereof. Sec. 2, Act of June 20, 1911, P.L. 1072 ~ r- - , ,. _.. ~, s WILLIAM A. ADDAMS ATTY. I.D. # 06265 43 W. South St. P.O. BOX 261 CARLISLE, PA. 17013 717-243-7638 MICK D. SPANGLER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Vs. NO. 07-4600 CIVIL ACTION LAW JOE PRENTICE PRAECIPE TO THE PROTHONOTARY: Please enter a default judgment in the amount of $8,819.37 against the defendant for failure to enter an appearance or file an Answer to the Complaint endorsed with a Notice to Defend. The undersigned hereby certifies that the attached written Notice of Intention to file the Pracipe was mailed to the Defendant on the date shown thereon, which was after the default occurred and at least ten (10) days prior to the filing of this Praecipe. William A. A dams Attorney for Plaintiff To Curtis Long, Prothonotary Dated: November 5, 2007 WILLIAM A. ADDAMS ATTY. I.D. # 06265 43 W. South St. P.O. BOX 261 CARLISLE, PA. 17013 717-243-7638 MICK D. SPANGLER : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Vs. NO. 07-4600 CIVIL ACTION LAW JOE PRENTICE TO: JOE PRENTICE 2000 Hill St., Lebanon, PA. 17046 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. 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 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 FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET HELP. Court Administrator Fourth Floor Cumberland County Court House Carlisle, Pa 17013 717-240-6200 William A. Addams Attorney for Plaintiff Dated: October 22, 2007 / ~ s Z w~ A~ A ^~.a Q C,. c~~ "t"t _ --..a ` ~ _ ~r ~ ~ - (T6 - ~ i _, , ,, o ~- ~o ~- ~- ~, ~ , Q 1 ~ -y-~°t_'- ~ ~jri'Y ~ ~ }~ ~ ~ ~G ~~