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Home My WebLink About08-0655 H OF PENNSYLVANIA COURT OF COMMON PLEAS Judicial District, County Of NOTICE OF APPEAL FROM f DISTRICT JUSTICE JUDGMENT I 4 COMMON PLEAS No. NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case referenced below. O-Z A I [a?' 6anLgite W I 1i IF' ADDRESS CRY TATE iY'l jAZ JU ?Wr THE CASE-OF DOCKET 40. U Y 14 K A Y OR AGENT ev,VY)CP In I /I . / This block will be signed ONLY when this notation is required under Pa. R.C.P.D.J. No. 1008B. This Notice of Appeal, when received by the District Justice, will operate as a SUPERSEDEAS to the judgment for possession in this case. Sonahm or Proo"WI ry or Do" If D.J. No. 1001(6) in before a District Justice, A COMPLAINT MUST BE FILED within twenty (20) days after filing the NOTICE of APPEAL. PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rule upon (Common Pleas No. appellee(s), to file a complaint in this appeal ) within twenty (20) days after service of rule or suffer entry of judgment of non pros. aff--y-agent RULE: To (1) You are notified that a rule is hereby entered upon tlbu to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) if you do not file a complaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailing. Date: V CL ^ 3 (} , 20 IJ py? 4 ? w. Of Proffmcdoy or oeA„ry YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312-02 WHITE - COURT FILE TO BE FILED WITH PROTHONOTARY GREEN - COURT FILE YELLOW - APPELLANTS COPY PINK -COPY TO BE SERVED ON APPELLEE GOLD -COPY TO BE SERVED ON DISTRICT JUSTICE PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing of the notice of appeal. Check applicable boxes.) COMMONWEALTH OF PENNSYLVANIA COUNTY OF ; ss AFFIDAVIT: I hereby (swear) (affirm) that I served ? a copy of the Notice of Appeal, Common Pleas upon the District Justice designated therein on (date of service) 20 ? by personal service ? by (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name) , on ,20 ? by personal service ? by (certified) (registered) mail, sender's receipt attached hereto. (SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF 20 Signature of affiant Signature of official before whom affidavit was made Title of official My commission expires on 20 _S -6- --? ?/ viNWASWd 40 .C Nd 0C Nvr 8002 RUV1? .10 L COIAMONWEALTH OF PENNSYLVANIA COONV OR CUMBERLAW Mag. Dist. No.: 09-1-02 MDJ Name: Hon. ROBERT V. CLOVE Address: 1901 STATE ST CAM HILL, PA Telephone: (717 ) 761-05:83 17011-0000 CHRISTY SHANANESSE 285 SERNAL LN ETTERS, PA 17319 THIS IS TO NOTIFY YOU THAT: DEFAULT _ JUDGWIMT _ PLTF rte- !? S s U,? ? ? -? NOTICE OF JUDGM SETITRANSCRIOi- CIVI C PLAINTIFF: NAME and ADDRESS --I r®EICO ASO KIMBERLY. LONG 2719 SEECEWM AVE SALTINORR, 1® 2114 L VS. J DEFENDANT: NAME and ADDRESS rS-HANANESSE, CHRISTY, 8T AL. 285 KZRILAL LN .BTTZRS, PA 17319 L J Docket No.: CV-0000411-07 Date Filed: 11/20/07! .? I (Date of Judgment) 1/03/0.8 _ 'Juogment. GEICO ASO BI=zRLY LONG Judgment was entered for: (Name) ® Judgment was entered against: (Name) SHAWA'ld1ESSE1 CHRISTY in the amount of $ 6,905.8 6,769.30 Amount of Judgment $? r] Defendants are jointly and severally liable. Judgment Costs Interest on Judgment $ 000 Damages will be assessed on Date & Time Attorney Fees $ This case dismissed without prejudice. Total - $ . 6,905.80 Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 Post Judgment Credits $ $ Post Judgment Costs $ CC ?- Portion of Judgment for physical damages arising out. of Total $ residential lease $ Certified ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENThRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. { Date I c rtif that this is a tr pate , My commission expires first Monday of January, 2012 • roceedind s contain ,Mai AOPC 315-07 DATE PRINTED: 1/03/08 11:03:00 AK g,tI1,C judgment. " aterial`0ptrict Judge a? L +. ,'"'SEAL PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing of the notice of appeal. Check applicable boxes.) COMMONWEA TH OF PENNSYLV NIA COUNTY OF ; ss AFFIDAVIT: I hereby (swear) (affirm) that I served ? a copy of the Notice of Appeal, Common Pleas .?' upon the District Justice designated therein on (date of servicey??? , 20 A , ? by personal service Y by (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name) An 0 20e)v ? by personal service by (certified) (registered ail, send rs receipt attached hereto. (SWORN) (AFFIRMED) AND?SCRIBED BEFORE ME T IS DAY OF_- 201. I, s r Signature of official before w m affidavit was made N", f Title of official My commission expires on `4 20 NOTARIAL SEAL CLAUDIA A. BREWBAKER, NOTARY PUSUC Carlisle Boro. Cumberland County -My Commission Expires April 4, 2009 Signature of affiant eu 0 C ? j i` -n M , mr_= M c rM J (.n ' _ - C GOMMONWEALTti Ul" PhNNSYLY COURT OF COMMON PLEAS Judicial District, County Of NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT I ) COMMON PLEAS No. - » "" NOTICE OF APPEAL 'w) Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case referenced below. u1 jam. L; r a K This block will be signed ONLY when this notation is required under Pa. R.C.P.D.J. No. 10086. This Notice of Appeal, when received by the District Justice, will operate as a SUPERSEDEAS to the judgment for possession in this case. If appellant waa` Claimant (see Pa. R.G.P.D.J. No. IUM(b) in action before a District Justice, ^COMPLAINT MUST BE FILED within twenty (20) days after filing the NOTICE of APPEAL. $Waftr?dProd-W-y-o puy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see PA.R.C.P.D.J. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rule upon appellee(s), to file a complaint in this appeal (Common Pleas No. 0 V 40 5"5 Z.r-v , ! ) within twenty (20) days after service of rule or suffer entry of judgment of non pros. / Signature of attorney or agent RULE: To ff ?? t.7" e. ac.v /y /-t-SO appellee(s) N Name of appeNee(s) ) r, (1) You are notified that a rule is hereby entered upon u to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a oomplaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailing. , p( Date: 3,0 , 20 Ll Signature of P or OaPuty YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENTITRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312-02 WHITE - COURT FILE TO BE FILED WITH PROTHONOTARY GREEN - COURT FILE YELLOW - APPELLANTS COPY WILLIAM A. ADDAMS, ESQUIRE ATTORNEY ID # 06265 43 W. South St. P.O. BOX 261 CARLISLE PA 17013 TELEPHONE 717-243-7638 .................................................................................................. .................................................................................................: KIMBERLY LONG ............In .the Court of Common Pleas of Plaintiff Cumberland County Pennsylvania Vs. No. 08-655 CHRISTY SHAWANESSE Defendant Civil Action Lave : . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .............. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............... . . . . . ................ . ........................ . ...................................................... . ...................... . . . . . . . . . ................ NOTICE 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 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 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 DATE: February 26, 2008 WILLIAM A. ADDAMS, ESQUIRE ATTORNEY ID # 06265 43 W. South St. P.O. BOX 261 CARLISLE PA 17013 TELEPHONE 717-243-7638 ............. . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . ............................................................. : GEICO ASO/KIMBERLY LONG In tie Court of Common Pleas of Plaintiff Cumberland County Pennsylvania Vs. No 08-655 CHRISTY SHAWANESSE Defendant l Civil Action Law . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . : COMPLAINT AND NOW, comes the Plaintiff, GEICO, by its attorney, William A. Addams, and files the following complaint. 1. The plaintiff is GEICO, a corporation authorized to conduct insurance business in the Commonwealth of Pennsylvania with its offices and principal place of business at One GEICO Boulevard, Fredericksburg, VA 22412-0001. 2. The defendant is Christy Shawanesse, an adult individual residing at 285 Kernel La., Etters, PA 17319. 3. The plaintiff, GEICO, issued a policy of automobile insurance to Kimberly Long of Baltimore, MD. which was in effect on July 17, 2006. 4. On that date, Ms. Long was driving her 2005 Scion on Route 83 at Exit 41 A in Lemoyne, PA when the Defendant Shawanesse, driving a vehicle owned by Viktor Chiwaka, a/k/a Vitombiko Chiwaka, negligently and carelessly rear ended the Scion. 5. The defendant was negligent and careless in: a. traveling too fast for conditions; b. Failing to see the other vehicle in time to avoid a collision. c. Following too closely, and d. Failing to have her vehicle under control. 6. As a result of the negligence and carelessness of the defendant, the Scion was a total loss. The vehicle had an actual cash value of $13,247.30 and a net salvage value of $2,020.96, resulting in a loss in the amount of $11,226.34. In addition there was rental expense of $233.96 for total damages of $11,460.30. 7. GEICO paid Ms. Long's loss under its collision coverage. 8. The amount of $4,691 has been paid on behalf of the defendant, leaving a balance due of $6,769.30. WHEREFORE, the plaintiff demands judgment against the defendant in the amount of $6,769.30, 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 compliant are true and correct to the best of his knowledge, information, and belief. I understand that false statements herein made are subject to the provisions of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. February 26, 2008 i?? d - Date William A. dams, Esquire Attorney for Plaintiff .Tt - 1i -r, it in the Court of Common Pleas of Cumberland County, Pennsylvania Plaintiff VS. No. 08-655 Civil CHRISTY SHAWANESSE 285 Kernel Lane Civil Action Law Etters, PA 17319 Defendant To Curtis R. Long Praecipe Cumberland County Prothonotary: Please withdraw my appeal in this matter. (SEAL) Chawanesse Dated: March2.4,2008 L? rv r r.-? _ ?'? C=::) `? ?? -:? ? ? i ? ?: ,.:.? r? -?:. - - _.. - =?; ;- ?, ;, ? a ?? .n..? - d