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HomeMy WebLinkAbout07-7498lk WILLIAM A. ADDAMS, ESQUIRE ATTORNEY ID # 06265 43 W. SOUTH ST. P.O. BOX 261 CARLISLE PA 17013 TELEPHONE 717-243-7638 D. Vs. KEEN TRANSPORT In the Court of Common Pleas of Cumberland County Pennsylvania NO. 01 11'!98 C•v< t-Tem Civil Action Law Plaintiff Defendant NOTICE 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 may be 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 717-240-6200 William A. Addams Attorney for Plaintiff 1kb AND now comes the plaintiff, Jeffrey D. Moore, by his attorney, William A. Addams, and makes the following COMPLAINT 1. The plaintiff Jeffrey D. Moore, an adult individual, residing at 221 Emerald St., Harrisburg, PA 17110. 2. The defendant is Keen Transport with offices and a principal place of business at 1951 Harrisburg Pike, Carlisle, PA 17015. 3. On July 26, 2007, the plaintiff was driving his 2007 Pontiac leaving the Keen Transport terminal and stopped in the right hand lane at Harrisburg Pike. 4. At that same time, a Keen tractor trailer operated by its agent, servant and employee, David Prisock, stopped in the left lane. Mr. Prisock then carelessly attempted to make a right turn onto the Harrisburg Pike, collided with the plaintiff's vehicle, and caused the dmage hereinafter set forth 5. As a result of the negligence and carelessness of the defendant, through the conduct of its servant, agent and employee, the plaintiff's vehicle sustained damage in the amount of $2,444.87. WHEREFORE, the plaintiff demands judgment against the defendant in the amount of $2,444.87, plus interest and costs of suit, an amount within the jurisdiction of arbitration under the local rules of court. William A. Addams Attorney for the Plaintiff VERIFICATION William A. Addams 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: December 13, 2007 William A. A` dams p fZ d oho O v D C7 ? Q C" l N Q W -C -Ctp) SHERIFF'S RETURN - REGULAR CASE NO: 2007-07498 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MOORE JEFFREY D VS KEEN TRANSPORT TIMOTHY BLACK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon Tl TCn T.-KT TDTTTQnn D'T the DEFENDANT , at 0915:00 HOURS, on the 26th day of December , 2007 at 1951 HARRISBURG PIKE CARLISLE, PA 17015 by handing to PETE TRIMBLE, SAFETY OFFICER, ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge So Answers: 18.00 5.76 .58 10.00 R. Thomas Kline .00 34.34 12/28/2007 WILLIAM ADDAMS Sworn and Subscibed to before me this of By: ?J day / ??epidty Sheriff A.D. WILLIAM A. ADDAMS, ESQUIRE ATTORNEY ID # 06265 43 W. SOUTH ST. P.O. BOX 261 CARLISLE PA 17013 TELEPHONE 717-243-7638 JEFFREY D.IVIOORE .................................. Iri the Court of Common 'Pleas _of ......... Cumberland County Pennsylvania Plaintiff NO. 0c -7y Vs. KEEN TRANSPORT Civil Action Law Defendant ....................................................................................................................... . . .. . .. . . .. . . . . . . . . . . . . . . .................................... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............... : PRAECIPE SIR: Please mark this action settled and discontinued. William A. AZIdams, Esquire Attorney for Plaintiff 43 W. South St. Carlisle, PA 17013 717-243-7638 Dated: ? ? G:? c_. .-? -?- "v .-. _? i^ ?.. '_ a??^! ?.... _ f..+ 1, •-f.