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Home My WebLink About08-0238IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DAWN R. KELLER 7 West Green Street Mechanicsburg, PA 17055 Plaintiff vs. NO. 08- aCIVIL NICHOLLE VAN-DENEEDEN 1802 Hunter Drive Mechanicsburg, PA 17050 Defendant PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY, Please issue a writ of summons upon the above captioned Defendant. Thank you for your prompt attention to this matter. Date: January 11, 2008 ID #38444 1237 Holly Pike Carlisle, PA 17013 (717) 249-2448 ?i . "Y7 1 ' ' w ,p _ } e 11 { Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS Court of Common Pleas Dawn R. Keller 7 West Green St. Mechanicsburg, PA 17055 Plaintiff Vs. No 08-238 Civil Term Nicholle Van-Deneeden 1802 Hunter Dr. Mechanicsburg, PA 17050 In CivilAction-Law Defendant To Nicholle Van-Deneeden, You are hereby notified that Dawn R. Keller the Plaintiff(s) has / have commenced an action in Civil Action-Law against you which you are required to defend or a default judgment may be entered against you. (SEAL) Cu AsR. r thono Date 01/14/2008 By Deputy Attorney: Joseph D. Buckley, Esq. Name: Joseph D. Buckley, Esq. Address: 1237 Holly Pike Carlisle, PA 17013 Attorney for: Plaintiff Telephone: (717)249-2448 Supreme Court ID No. 38444 Jeffrey T. McGuire, Esquire Attorney I.D. No. 73617 Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 (717) 232-2766 (fax) Attorneys for Nicolle Van-Deneeden IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DAWN R. KELLER vs. Plaintiff Case No. 08-238 Civil Term NICOLLE VAN-DENEEDEN Defendant. Civil Action - Law Jury Trial Demanded PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Nicolle Van-Deneeden, with regard to the above-captioned matter. submitted, Date: By: Jeffr . McGuire, Esquire Aft ey I. D. # 73617 C dwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110-1533 (717) 232-7661 Attorney for Defendant, Nicolle Van-Deneeden 06621-111-128350 CERTIFICATE OF SERVICE 1' '?ak... AND NOW, this oj) day of January 2008, 1 hereby certify that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.S. Mail at Harrisburg, Pennsylvania, postage prepaid, addressed to: Joseph D. Buckley, Esquire 1237 Holly Pike Carlisle, PA 17013 CALDWELL & KEARNS By: 4-4 ? " ` Shirley M. Erb, Secretary Sri { ril 6 7 `D ' Vii .. C- %ti 51- J LA SHERIFF'S RETURN - REGULAR CASE NO: 2008-00238 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND KELLER DAWN R VS VAN-DENEEDEN NICHOLLE WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon T Tm- -1T TTIT"PT-%1-1T7 TTTf'TJnT_T.V the DEFENDANT at 1642:00 HOURS, on the 18th day of January 2008 at 1802 HUNTER DRIVE MECHANICSBURG, PA 17050 by handing to NICHOLLE VANDENEEDEN a true and attested copy of WRIT OF SUMMONS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 12.48 Postage .58 Surcharge 10.00 R. Thomas Kline .00 40?(( . ti/ 41.06 01/22/2008 JOSEPH BUCKLEY Sworn and Subscibed to By: et Sheriff before me this day pu of , A.D. ,j Jeffrey T. McGuire, Esquire Attorney I.D. No. 73617 Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 (717) 232-2766 (fax) jmcguire@caldwellkearns.com Attorneys for Nicolle Van-Deneeden IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DAWN R. KELLER Plaintiff Case No. 08-238 Civil Term VS. NICOLLE VAN-DENEEDEN Defendant. TO THE PROTHONOTARY: Please issue a Rule upon Counsel for Plaintiff, Dawn R. Keller, to file a Complaint within twenty (20) days of service of said Rule, or suffer judgment of non PRAECIPE FOR RULE TO ISSUE COMPLAINT Civil Action - Law Jury Trial Demanded pros. ecuTiy su Date: April 1, 2008 By: y T. cGuire, Esquire y ,r. D. # 73617 Caldwe4 & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110-1533 (717) 232-7661 Attorney for Defendant, Nicolle Van-Deneeden 06621074/120828 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DAWN R. KELLER Case No. 08-238 Civil Term Plaintiff vs. NICOLLE VAN-DENEEDEN Defendant. Civil Action - Law Jury Trial Demanded RULE To: Joseph D. Buckley, Esquire 1237 Holly Pike Carlisle, PA 17013 A Rule is hereby issued upon you to file a Complaint within twenty (20) days of service hereof, or judgment of non pros will be entered against you. Pr honotary Dated: 'qhlat CERTIFICATE OF SERVICE AND NOW, this 1St day of April 2008, 1 hereby certify that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.S. Mail at Harrisburg, Pennsylvania, postage prepaid, addressed to: Joseph D. Buckley, Esquire 1237 Holly Pike Carlisle, PA 17013 CALDWELL & KEARNS By: r?-ry c"} f'l C..? :?? ?j s ?::1? - C?? ,wr7 .--E ,,'l ° ? Gr7 ? . • - { . `+ } :-4 -.., C? DAWN R. LLER, Plaintiff V. NICHOLLE VAN-DENEEDEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-0238 CIVIL TERM IMPORTANT NOTICE You ha e been sued in court. If you wish to defend against the claims set forth in the following p ges, you must take action within twenty (20) days after this complaint and notice are s rved, by entering a written appearance personally, or by attorney, and filing in writin with the court your defenses or objections to the claims set forth against you. You are arned that if you fail to do so the case may proceed without you by the court without f her notice for any money claimed in the complaint or for any other claim or. relief r quested by the plaintiff. You may lose money or property or other rights important to yo . YOU S OULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT AVE A LAWYER OR CANNOT AFFORD ONE, GO TO, OR TELEPHONE HE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEG L HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 DAWN R. KELLER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 'Plaintiff NO. 08-0238 CIVIL TERM V. NICHOLLE VAN-DENEEDEN, Defendant COMPLAINT AND NOW this 23RD day of April, 2008, comes Plaintiff, by and through his counsel, Josephb. Buckley, Esquire and complains of Defendant as follows: 1. Plaint?ff is an adult female currently residing at 7 West Green Street, Mechanicsburg, Cumberland County, PA 17055. 2. Defendant is adult female currently residing at 1809 Hunter Drive, Mechanicsburg, Cumberland County, PA 17050. 3. On or about the late evening of January 11, 2006, Plaintiff was a passenger in a motor vehicle traveling southbound on the Harrisburg-Carlisle Pike in Silver Spring Township, Cumberland County, PA. 4. At the same time, it was later discovered that Defendant was operating a motori, vehicle traveling northbound on Locust Point Road in Silver Spring Township, Cumberland County. 5. Defendant was operating the said vehicle in a negligent manner and at appro imately 11:30 PM caused an accident with the vehicle in which Plainti f was riding. 6. As a r sult of Defendant's negligent operation of the vehicle she was driving, i said vehicle struck the vehicle in which Plaintiff was riding. 7. At ?he time of the impact between the vehicle defendant was driving and the vehicle in which Plaintiff was riding, Plaintiff was not aware that she was inj used. 8. At the time of the said impact, Plaintiff was not aware who was operating the vehicle which Defendant was driving. 9. Plaintiff was taken to the Milton S. Hershey Medical Center in Hershey, PA arriving at approximately 0:30 AM January 12, 2008. 10. Upon arriving at the Medical Center, Plaintiff was amnesiac to the accident. 11. After being seen in the emergency room and receiving X-rays, on January 12, 2006„ Plaintiff discovered she had injured her right leg and had fractured several bones in her right foot. 12. Plaintiff sometime thereafter discovered that Defendant was the operator of the vehicle that had struck the vehicle in which Plaintiff was a passenger. 13. Priorl,to Janaury 12, 2006, after her arrival at the Hershey Medical Center, PlaiOff could not have reasonably ascertained that she was injured from the motor vehicle accident. 14. Prior jto Janaury 12, 2006, after her arrival at the Hershey Medical Center, Plain?iff could not have reasonably ascertained that she had been in an accident and who had caused the accident. 15. PlainOff discovered sometime on or after January 12, 2006 , that the ause and/or a substantial factor in causing the said accident was 16. failure to operate the vehicle she was driving in a safe and proper of the injuries Plaintiff discovered which included injury to her it right le and/or foot, Plaintiff has undergone many months of medical treatment, therapy'! and surgery to alleviate or correct the injuries she suffered. i 17. As 4 result of the accident caused by Defendant's negligent act or acts, Plaintiff can not return to work in her former capacity. 18. As result of the accident caused by Defendant's negligent act or acts, Plaintiff is permanently disabled. 19. As al result of the accident caused by Defendant's negligent act or acts and the injuries sustained therefrom, Plaintiff will have to endure intensifying pain in her right leg and/or foot. 20. Plaintiff has incurred medical bills in excess of thirty-five thousand dollars. 21. Plaintiff will incur future medical bills not in excess of thirty-five thousand dollars. 22. Plaintiff has suffered loss of wages not in excess of thirty-five thousand dollars. 23. Plain?iff will suffer future loss of wages in excess of thirty-five thousand dollarfs. 24. Plaintiff has suffered pain and suffering in excess of thirty-five thousand 25. Plaintiff will suffer future pain and suffering in excess of thirty-five thousand 26. Plaintiff has suffered loss of enjoyment of life in excess of thirty-five dollars. 27. Plaintiff will suffer future loss of enjoyment of life in excess of thirty-five dollars. WHER?FORE, Plaintiff prays that this Honorable Court enter a judgment in its favor as against Defendant in an amount in excess of one hundred thousand dollars ($100.000.00) tlogether with interest and costs of this action. Respectfully submitted, 1237 Holly Pike Carlisle, PA 17013 (717) 249-2448 JoeBLaw@aol.com VERIFICATION I, Dawn, R. Keller, verify that I have read the foregoing Complaint and to the best of my knowledge, information and belief the statements made therein are true and correct. I understand that the statement made herein are subject to the provisions and penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsifications to authorities. Date: q- J-5 -Ci ?Cr ?1 Dawn R. Keller NO. 08-0238 CIVIL TERM V. NICHOLLE V N-DENEEDEN, Defendant CERTIFICATE OF SERVICE I, Joseph D. Buckley, Esquire, hereby certify that a true and correct copy of the foregoing pleading in the above captioned matter was served on the following persons by means of United States First Class Mail, postage prepaid: Jeffrey T. McGuire, Esquire Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110-1533 Date:_ 3 zCti? 1237 Holly Pike Carlisle, PA 17013 (717) 249-2448 JoeBLaw@aol.com r._? ? 1 ' q -? fit... 1 .., .... ?? (....? .... ,' °'ti DAWN R. KELLER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 08-0238 CIVIL TERM V. NICHOLLE VAN-DENEEDEN, Defendant PRAECIPE TO WITHDRAW To the Prothonotary: Please withdraw the Complaint filed in the above captioned matter, with prejudice, as it has been resolved by the parties. Thank you. Respectfully submitted, Date: S - 2-3-,() 1237 Holly Pike Carlisle, PA 17013 (717) 249-2448 JoeBLaw@aol.com cz) -~