HomeMy WebLinkAbout08-4954LLOYD RAMMING, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. D8 ' yq5? Ci v?l T rm
CAPITAL CITY CAR WASH, CIVIL ACTION - LAW
Defendant
NOTICE TO DEFEND
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 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 MAY GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PA 17013
(800) 990-9108
NOTICIA
LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse
de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de
plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una
apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus
defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si
usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin
previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de
demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes
para usted.
LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO
TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL
SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA
DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE
PUEDE CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PA 17013
(800) 990-9108
.4-
LLOYD RAMMING,
Plaintiff
V.
CAPITAL CITY CAR WASH,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - LAW
COMPLAINT
AND NOW comes the Plaintiff, by his attorneys, Wix, Wenger & Weidner and
sets forth the following Complaint:
1. The Plaintiff is an adult individual residing at 846 Rudytown Road, New
Cumberland, Pennsylvania 17070.
2. Defendant Capital City Car Wash is a corporation having its principal
offices located at 3525 Hartzdale Drive, Camp Hill, Pennsylvania 17011.
3. On or about January 3, 2008, Plaintiff was the owner of a 2002 Toyota,
which he took to the Defendant's place of business for purposes of having the car
washed.
4. After Plaintiff had paid the money to have a car wash, the machinery did
not begin the washing process, and Plaintiff reported same to Defendant's employee.
5. Defendant's employee went into the control room and did something to
cause the machinery to damage the Plaintiffs vehicle.
6. After the initial damage, the manager of the car wash then took some
action in the control room which caused additional damage to Plaintiffs vehicle.
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7. During this washing process the Plaintiff's vehicle was damaged, and
Plaintiff incurred expenses of $1,952.00 in order to have his vehicle repaired.
8. Defendant through its manager indicated that it was responsible for the
damages and would pay to have Plaintiff's vehicle repaired, but Defendant has refused
to make payment for the amounts incurred in repairing Plaintiffs vehicle.
WHEREFORE, Plaintiff demands judgment against the Defendant in an amount
not in excess of mandatory arbitration limits.
Respectfully submitted,
WIX, WENGER & WEIDNER
By
Richard H. Wix, Esq., ID #07274
Attorneys for Plaintiff
4705 Duke Street
Harrisburg, PA 17109-3041
(717) 652-8455
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Dated. . g j
2
VERIFICATION
I, Lloyd Ramming, have read the foregoing Complaint, which has been drafted by
my counsel. The factual statements and/or denials contained therein are true and correct
to the best of my knowledge, information and belief. I am authorized to make this
verification.
This verification is made only as to the factual averments contained therein and
not to legal conclusions and averments authorized by counsel in his capacity as attorney
for the party or parties hereto.
This verification is made subject to the penalties of 18 PA. C.S. Section 4904,
relating to unsworn falsification to authorities, which provides that if I knowingly made
false averments, I may be subject to criminal penalties.
Date:
Lloyd amming
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-04954 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
RAMMING LLOYD
VS
CAPITAL CITY CAR WASH
NOAH CLINE , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
rADTTAT. rTTV rAR WAgW the
DEFENDANT , at 1120:00 HOURS, on the 4th day of September, 2008
at 3525 HARTZDALE DRIVE
CAMP HILL, PA 17011 by handing to
ROB STAIGER
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 18.00
Service 14.00
Affidavit .00
Surcharge 10.00
911?/i? F- 00
42 . 00
Sworn and Subscibed to
before me this day
of ,
So Answers:
20,
'7 0'
R. Thomas Kline
09/05/2008
WIX WENGER WEIDNER
By :
Deputy Sheriff
A. D.
1n. avid D. Bueff
Prothonotary
KirkS. Sohonage, ESQ
Solicitor
lfnee X Simpson
15` Deputy 1TrotFionotary
Irene E. Worrow
2"d Deputy (Prothonotary
office of the Prothonotary
Cumberland County, Pennsylvania
QA- J. Q?'7 CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 25TH DAY OF OCTOBER, 2011, 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,
DAVID D. BUELL
PROTHONOTARY
One Courthouse Square • Suite 100 • CarCisCe, PA 17013 • (717) 240-6195 0 Fax (717 240-6573