HomeMy WebLinkAbout04-0989CGMMONWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS NOTICE OF APPEAL
Judicial District, County Of FROM
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No. o 41- l F
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 d and in the se refe nced below.
NAM OF APP T MAG?GISTI. N"O / NAME OF D.J.
`S 'r?ri, it ?l tom. ??`l A? .0/ / 7?LS CITY V
ADDRESS OF APPELLANT __/ I?Z' / STATE ZIP CODE
DATE OF JUDG ENT INT CASE OF(Plai ito
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DOCKET No. /{[ /•}^//?`r-y"/, `Y^/'
tv-eDOaSy"6 - i3
(Defendant)' r
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NATURE OF APPELLANT-OR ATTORNEY OR AGENT
This block will be signed ONLY when this notation is required under Pa. If appellant was Claimant (see Pa. R.C.P.D.J. No. 1001(6) in action
R.C.P.D.J. No. 10088.
This Notice of Appeal, when received by the District Justice, will operate as a before a District Justice, A COMPLAINT MUST BE FILED within twenty
SUPERSEDEAS to the judgment for possession in this case.
(20) days after filing the NOTICE of APPEAL.
Sgnature of Prothonotary or Deputy
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 ZK
'? z , appellee(s), to file a complaint in this appeal
Name of appellee(s)
(Common Pleas No. 7 R Wei' ) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
,y Signature of appellant tionneyoragent
RULE: To I? appellee(s)
Name of appellee(s)
(1) You are notified that a rule is hereby entered upon you 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: /9/?... ,20 C I ?V ( Sig fPro otary or Deputy
YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENTITRANSCRIPT FORM WITH THIS NOTICE OF APPEAL.
AOPC 312-02
COURT FILE TO BE FILED WITH PROTHONOTARY
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(7his proot nt ser vice MUST BE FJi-EP WiTHiN FEN (I)) DAYS AFZER flung of the notice of apAoaf- Chech apidhcante boxes.;
COMMONWEALTH OF PENNSYLVANIA
COUNT" OF SS
AFFIDAVIT: i hereby isvear) ,affirm} that I served
El a copy of the Notice of Appeal. Common Pleas No . upon the District Je&tlce designated therein cn
;date of service; , 24 L1 by personai service i_-] by (ceRlfied) Ireylstf>reci) malt.
sender's receipt attached hereto, and upon the appellee, (name; . er.
20 by personal service by certified (registered) mar,
sonnet's recs= at attached hereto. --
SWORN) (AFFIRMED) AND SUBSCRiSED BEFORE ME na
THIS DAY OF ,20 - - -
- notura o aNi?oi
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Signature of oNlaef pefore whom affidavit was made ? :;u
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Title of offirlal
My commission expires on 20 ^ v F TI
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AOPC 312A - 02,
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CUMBERLAND
Mag. Dist. No.:
09-3-04
DJ Name. Hon.
THOMAS A. PLACEY
Address: 104 S SPORTING HILL RD
MECHANICSBURG, PA
Telephone: (717 ) 761-8230 17050
LARRY A. MORRISON, JR.
5 PENNY LANE
ENOLA, PA 17025
THIS IS TO NOTIFY YOU THAT:
Judgment:
NOTICE OF JUDGMENT/TRANSCRIPT
PLAINTIFF: CIVIL CASE
NAME and ADDRESS _
7HARRISON, KRISTINE L
-26 YORK CIRCLE
MECHANICSBURG, PA 17050
L J
VS.
DEFENDANT: NAME and ADDRESS
IMORRISON, JR., LARRY A, ET AL. 7
5 PENNY LANE
ENOLA, PA 17025
L J
IDocketNo.: CV-0000596-03I
Date Filed: 11/07/03
f
FOR DEFRNDANT
Y Judgment was entered for: (Name) AT,T.STA'PR TN,RTTRAYJCi COMPANY
7 Judgment was entered against: (Name) HARRTSON, KRTSTTNR L
in the amount of $ -of) on: (Date of Judgment) 2/26/04
El Defendants are jointly and severally liable.
E Damages will be assessed on:
El This case dismissed without prejudice.
Amount of Judgment Subject to
Attachment/42 Pa.C.S. § 8127 $
Portion of Judgment for physical
damages arising out of residential
lease $
(Date & Time)
Amount of Judgment $ .00
Judgment Costs $ .00
Interest on Judgment $ .00
Attorney Fees $ .00
Total $ .00
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total $
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 JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, 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 DISTRICT JUSTICE.
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 DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES,
OR OTHERWISE COMPLIES WITH THE JUDGMENT.
2, 21c ? 04 Date g 7 District Juss e n _
I certify that this is a true a correct?y of the rca containing the judgfn?ent:
'2 ` L 1 Date , Dist r1 Justice
My commission expires first Monday of January, 2010. SEAL"
AOPC 315-03 DATE PRINTED: 2/26/04 11:29:18 AM
-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 fhe notice of appeal ChWk appficablo boxes.)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ?? I.,-
SS
AFFIDAVIT: I hereby (swear) (affirm) that i served
a Cagy of the Notice of Appeal, Common Pleas No. ®'if IV1q
upon the District Justice designated therein on
(date of service) 3
20 D,?/, by personal service ? by (certified) (registered} mail,
sender's receipt attached hereto, and upon the appellee, (nalne)?,?y v
/' ,on 20 774tltl" ?3/ :
sender's receipt n, 03o( .? by personal service [k
by (certified) (registered) mail,
attached hereto
(SWOR ) {AFFIRMED) AND SUBSCRIBED BEFORE ME
THIS 7H`I- DAY OFgYj
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NOTARIAL SEAL
AUOIA A.BREWBAKER,NOTARY PUBLIC r
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Carlisle Bot0, Cumberland County
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ApPC 312A - 02
;OMMONWEALTH OF PENNSYLVI
COURT OF COMMON PLEAS
Judicial District, County Of
NOTICE OF APPEAL
FROM
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No. Q `'/ - 'f ? I
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 and in the?c se refe n?i beC B9 - 5 -- / y ?
..? .eeci i r w G ^T NO, NAME OF D J ZIA
J
,??4
y/za/'yam
KET NO.
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.
Sgnalure o/ Profhonofery or Oepaty
V
I
If appellant was uralmarn lace ra. ---
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
from copy of notice when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before District Justice. IF of appeal to be PRAECIPE: To Prothonotary
(This
NOT USED, of form to be used
Enter rule upon
Z.,
appellee(s), to file a complaint in this appeal
_
t, Name of WOWS)
(Common Pleas Np. o q 6 ) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
signetumofappellaant stromeyoragent
es? , appellee(s)
RULE: To
Name of eppellee(s)
(1) You are notified that a rule is hereby entered upon you 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 MAYBE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of the mailing. -
Date: 1/6' 20 Signatureo fonolaryor Deputy
YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENTITRANSCRIPT FORM WITH THIS NOTICE OF APPEAL.
AOPC 312-02
CWRT RILE
IN THE COURT OF COMMON :PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
Kristine Harrison,
Plaintiff,
vs.
: No. 04-989
Larry Morrison Jr, CIVIL ACTION-LAW
Defendant,
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 (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 far 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 CANNONT AFFORD ONE, FO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service of
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
Telephone No. (717) 240-6200
IN THE COURT OF COMMON :PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
Kristine Harrison,
Plaintiff,
vs.
No. 04-989
Larry Morrison Jr, CIVIL ACTION-LAW
Defendant,
NOTICIA
LES HAN DEMANDADO A USTED EN LA CORTE. Se usted guiere
defenderse de estas demandas expuestas en las paginas
siguientes, usted tiene viente (20) dias de plazo al partit de
la fecha de la demands. y la notificacion. Listed debe presentar
una apariencia escrita o en persona o por obogado y archhivar en
la corte en forma escrita sus defensas o sus objeciones a las
demandas en conra de su persona. Sea avisado qui si usted no sos
defiende, la corte tomarra immedidas y purde entrar usa orden
contra usted sin previo aviso o notoficacion y pro cualquier
queja o alivio que es pedido en la peticion de damanda. Usted
puede perder dinero o sus propiendades o otros derechos
importantes para usted.
LLEVE ESTA DEMANDO A UN ABOGADO IMMEDIATEMENTE. SI NO TIENE
ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL
SERCICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICIAN CUYA
DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SU
PUEDE CONSEGUIRE ASISTENCIA LEGAL.
Lawyer Referral Service of
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
Telephone No. (717) 240-5200
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
Kristine Harrison,
Plaintiff,
vs.
No. 04-989
Larry Morrison Jr,
Defendant,
CIVIL ACTION-LAW
COMPLAINT
AND NOW, COMES, the above-named Plaintiff files this Complaint against the above-
named Defendant, hereinafter sets forth the following:
1. Plaintiff is an adult individual residing at 26 York Circle, Mechanicsburg,
Cumberland County, Pennsylvania 17050.
2. Defendant is an adult individual with a last known residence of 5 Penny Lane,
Enola, Cumberland, Pennsylvania 17025 .
3. On November 11, 2001 Defendant was operating Plaintiff's vehicle.
4. While operating Plaintiff's vehicle, Defendant caused the vehicle to hit a
telephone pole.
5. While operating Plaintiff's vehicle, Defendant failed his duty to operate the
vehicle in a safe and conscientious manner.
6. Plaintiff's vehicle was deemed a total loss.
7. Defendant's actions where the direct cause of Plaintiff's damages.
WHEREFORE, Plaintiff, respectfully requests this Honorable Court to enter judgment
against Defendant in the amount of $6,077.30, together with interest, costs of this action,
attorney's fees and such other relief as this Honorable Court shall deem just and proper.
submitted,
Date: ?
Plaintiff
I verify that the statements made in this Complaint are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.SI. §4904, relating to unsworn
falsification to authorities.
Date:???
-.%iinea-m'son
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
Kristine Harrison,
Plaintiff,
Vs.
Larry Morrison Jr,
Defendant,
No. 04-989
CIVIL ACTION-LAW
CERTIFICATE OF SERVICE
I hereby certify, that on the date set forth below, a true and correct copy of the
foregoing Complaint was served upon the party listed below via first class, United States
Mail, postage prepaid.
Larry Morrison Jr.
5 Penny Lane
Enola, PA 17025
Date. -'. Ll
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
KRISTINE HARRISON,
VS. No. 04-939
LARRY MORRISON, JR. CIVIL ACTION - LAW
NOTICE TO PIS-AD
To: Kristine Harrison
26 York Circle
Mechanicsburg, PA 17050
You are hereby notified to file a written response to the
enclosed New Matter within twenty (20) days from service hereof
or a judgment may be entered against you.
REIDENBACH, HENDERSON & PECHT
By:
Herbert P. Henderson, II
36 East King Street
Lancaster, PA 17602
(717) 295-9159
I.D. 56304
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
KRISTINE HARRISON,
VS.
No. 04-989
LARRY MORRISON, JR. CIVIL ACTION - LAW
ANSWER TO COMPLAINT AND NEW MATTER
1. Admitted.
2. Denied. To the contrary the Defendant resides at 6901
Salem Park Circle, Mechanicsburg, Pennsylvania, 17050.
3. Admitted.
4. Admitted in part, denied in part. While it is admitted
that Defendant was operating Plaintiff's vehicle and it is further
admitted that the vehicle hit a telephone pole, it is specifically
denied that Defendant was the cause of the accident. To the
contrary, Plaintiff advised Defendant that she had been "drag
racing" the vehicle "all day" and Defendant believes, and therefore
avers, that the vehicle sustained mechanical damage during one of
the "drag races" which mechanical damage was a substantial
contributing factor to the accident. Strict proof otherwise is
demanded at the time of trial.
5. No answer required inasmuch as the allegation sets forth
a conclusion of law. To the extent an answer may be required,
same is Denied. To the contrary, Defendant did operate the vehicle
in a safe and conscientious manner, however, as set forth above,
the vehicle's mechanical condition was a substantial factor
contributing to the cause of the action. Strict proof otherwise is
demanded at the time of trial.
6. Admitted.
7. Denied. It is specifically denied that the Defendant's
actions were the direct cause of Plaintiff's damages. To the
contrary, the Defendant believes, and therefore avers, that as a
result of the heavy, excessive use of the vehicle by Plaintiff at
a "drag race", the vehicle suffered mechanical breakdown which was
the substantial contributing cause of the action. Strict proof
otherwise is demanded at the time of trial.
WHEREFORE, Defendant, Larry A. Morrison, Jr., demands
judgment in his favor and against Plaintiff, Kristine Harrison.
NEW MATTER
Paragraphs 1 through 7 are Defendant's Answer are incorporated
herein by reference as though set forth at length.
8. Plaintiff, in her Complaint, alleges that Defendant is
liable to her for damages she suffered as a result of Defendant's
alleged breach of a duty to operate her motor vehicle in a safe and
conscientious manner.
9. Plaintiff asked Defendant, and Defendant agreed, to
operate Plaintiff's motor vehicle on the date in question only
after Plaintiff advised Defendant she had automobile insurance.
10. Defendant owes no duty to Plaintiff.
11. At all times Defendant acted under the direct supervision
of Plaintiff.
12. Plaintiff has failed to state a claim upon which relief
may be granted.
13. Plaintiff was offered money from Defendant's insurance
company to compensate her for her loss and she refused to accept
the same.
14. Plaintiff's claim is barred by the Doctrine of Consent.
15. Plaintiff's claim is barred by the Doctrine of Estoppel.
16. Plaintiff's claim is barred by the Doctrine of
Justification.
17. Plaintiff's claim is barred by the Doctrine of
Consideration.
18. Plaintiff's claim is barred by the Doctrine of Laches.
19. Plaintiff's claim is barred by the Doctrine of License.
20. Plaintiff's claim is barred by the Statute of Frauds.
21. Plaintiff's claim is barred by the applicable Statute of
Limitations.
22. Plaintiff's claim is barred by the Doctrine of Privilege.
23. Plaintiff's claim is barred by the Doctrine of Labor.
24. By way of further defense, Defendant avers that, if the
Plaintiff sustained damages as alleged in Plaintiff's Complaint,
his insurance agent, and Allstate Insurance are jointly and
severally liable or liable over indemnification and/or contribution
for any liability on behalf of Defendant.
25. Defendant reserves the right to join Allstate Insurance
and its Agent pursuant to Pennsylvania Rules of Civil Procedure
2252(b).
WHEREFORE, Defendant denies he is liable to Plaintiff. He
avers that Allstate Insurance is liable to Plaintiff in the event
Plaintiff is successful in her Complaint.
REIDENBACH, HENDERSON & PECHT
4
By:
Herbert P. Henderson, II
Attorney I.D. No. 56304
36 East King Street
Lancaster, PA 17602
(717) 295-9159
Attorneys for Defendant
COMMONWEALTH OF PENNSYLVANIA, )
COUNTY OF LANCASTER, )
ss:
HERBERT P. HENDERSON, II, ESQUIRE:, being duly affirmed
according to law, deposes and says that he is the attorney for the
within-named Defendant; that he is authorized to make this
affidavit; that this affidavit is made by him and not the Defendant
as he is more familiar with the subject matter of the document than
the Defendant; being procedural matters involved in this document,
and that the facts set forth in the foregoing document are true and
correct.
Sworn and subscribed to
before me this 1?-1+nday
o?Jf???nY1r 2004.
Y Y I?I,I,N G 1 ?? ' 1
Notary Public
-1Z
Herbert P. Henderson, II
NOTARIAL SEAL
MAURA M. KEENER, NOTARY PUBLIC
CITY OF LANCASTER, LANCASTER CO.
[MY COMMISSION EXPIRES MAY 13 2006
CERTIFICATE OF SERVICEI
{h
I hereby certify that on this !y day of ? YII , 2004, a
true and correct copy of the foregoing document was served on the
following persons and in the following manner, which service
satisfies the requirements of Pennsylvania Rules of Civil Procedure
Rule No. 440.
Service by FIRST CLASS MAIL, addressed as follows:
Kristine Harrison
26 York Circle
Mechanicsburg, PA 17050
CHT
REIDE BACH, HENDERSON & PE'
By:
erbert P. Henderson, II
Attorney I.D. No. 56304
36 East King Street
Lancaster, PA 17602
(717) 295-9159
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
KRISTINE HARRISON,
VS. No. 04-989
LARRY MORRISON, JR.
PRAECIPE TO SUBSTITUTE VERI1?ICATION
TO THE PROTHONOTARY:
Kindly substitute the attached original Verification of Larry
A. Morrison, Jr. for the Attorney Verification of Herbert P.
Henderson, II, Esquire, in the Answer to Complaint and New Matter
filed in the Court of Common Pleas of Cumberland County,
Pennsylvania, on April 15, 2004.
REIDENBACH, HENDERSON 6 P HT
BY:
Herbert P. Henderson, II
36 East King Street
Lancaster, PA 17602
(717) 295-9159
Attorney I.D. No. 56304
VERIFICATION
I have read the foregoing and hereby affirm that it is true
and correct to the best of my personal know-ledge, information and
belief. This verification is made subject to the penalties of 18
Pa. C. S. Section 4904 relating to the unsworn falsification to
authorities.
V" O'iu
arry A. Morrison, Jr.
Dated: /10-U
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
Kristine Harrison,
Plaintiff,
vs.
No. 04-989
Larry Morrison Jr, CIVIL ACTION-LAW
Defendant,
RESPONSE TO NEW MATTER
AND NOW, COMES, the above-named Plaintiff files this Response to New Matter, sets
forth and answers the following:
8. Admitted.
9. Denied. To the contrary, Defendant asked Plaintiff if he could drive Plaintiff's
motor vehicle. It is specially denied that Defendant ever asked Plaintiff about insurance on
Plaintiff's motor vehicle.
10. No answer is required to the extent the averment states a conclusion of law. With
regard to any factual allegations the same are deemed denied. It is specifically denied that
Defendant owes no duty to Plaintiff to operate Plaintiff's vehicle in a safe and conscientious
manner, but rather to the contrary.
11. Denied. Defendant was in control of Plaintiff's vehicle and had a duty to operate
Plaintiff's vehicle in a safe and conscientious manner.
12. No answer is required to the extent the averment states a conclusion of law. With
regard to any factual allegations the same are deemed denied. By way of further answer
Defendant's failure to operate Plaintiff's vehicle in a safe and conscientious manner was the
direct cause of Plaintiff's damages.
13. Denied. Defendant's insurance company (Allstate) denied the claim and at no
time offered to compensate Plaintiff for her damages.
14-23. No answer is required as these averments state conclusions of law. By way of
further answer Plaintiff specially denies that the claim is barred by any Doctrine or Statute.
24. Plaintiff, after reasonable investigation, is without knowledge or information
sufficient to form a belief as to the truth of the averment.
25. No answer required. By way of further answer, Plaintiff, after reasonable
investigation, is without knowledge or information sufficient to form a belief as to the truth of
the averment.
WHEREFORE, Plaintiff, respectfully requests this Honorable Court to enter judgment
against Defendant in the amount of $6,077.30, together with interest, costs of this action,
attorney's fees and such other relief as this Honorable Court shall deem just and proper.
Date: V
I verify that the statements made in this Complaint are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn
falsification to authorities. 4
Date:
U me iso
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
Kristine Harrison,
Plaintiff,
vs.
Larry Morrison Jr,
Defendant,
: No. 04-989
: CIVIL ACTION-LAW
CERTIFICATE OF SERVICE
I hereby certify, that on the date set forth below, a true and correct copy of the
foregoing Complaint was served upon the party listed below via first class, United States
Mail, postage prepaid.
Herbert P. Henderson
Reindenbach, Henderson & Pecht
36 East King Street
Lancaster, PA 17602
Date ?
I??JJJ tine son
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Curtis R. Long
Prothonotary
office of the Protbonotarp
Cumberranb Countp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
QJ( - (78 2 CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2.
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573