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Home My WebLink About08-5445r -, t William P. Douglas, Esq. Supreme Court I.D. #37926 Douglas Law Office 43 W. South St. Carlisle, PA 17013 Telephone (717) 243-1790_ Monica Ditzler In the Court of Common Pleas of Plaintiff Cumberland County, Pennsylvania vs No. 08 -??lyS Civil Term Michelle Zerbe a/k/a Michelle Laudermilch Defendant Civil action law jury Trial Demanded Praecipe to Issue a Writ of Summons Dear Mr. Long: Please issue a writ of summons against the defendant, Michelle Zerbe a/k/a Michelle Laudermilch. William P. Douf Attorney for date: September 12, 2008 Ca ? Q rs } r r- ?°+-? g n i •'g id.J .r C3 Commonwealth of Pennsylvania County of Cumberland Monica Ditzler In the Court of Common Pleas of Plaintiff Cumberland County, Pennsylvania vs No. 08 - 5 g4jr Civil Term Michelle Zerbe a/k/a Michelle Laudermilch Defendant Civil action law Jury Trial Demanded Writ of Summons To: Michelle Zerbe a/ k/ a Michelle Laudermilch 58 Arthur Street Hummelstown, PA 17036 or 7044 Linglestown Rd. Harrisburg, PA 17112 You are hereby notified that Monica Ditzler has brought an action against you. Deputy Prothonotary date: September 12, 2008 William P. Douglas, Esq. Douglas Law Office 43 W. South St. Carlisle, PA 17013 717-243-1790 Attorney for Plaintiff ? a O 40- _ , rn cn c1i }vim " r ; N V) { -0 ?Tl Q VS CASE NO: 2008-05445 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DITZLER MONICA ZERBE MICHELLE A/K/A MICHELLE R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: ZERBE MICHELLE A/K/A MICHELLE LAUDERMILCH but was unable to locate Her in his baill',iwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within WRIT OF SUMMONS SHERIFF'S RETURN - OUT OF COUNTY On October 7th , 2008 , attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin County Postage 18.00 9.00 10.00 49.25 1Q is office was in receipt of t So answers: R. Thomas Klind Sheriff oflCumberland County 87.43 ? 10/07/2008 WM DOUGLAS LAW OFFICE Sworn and subscribe to before me this day of A. D. In- The Court of Common Pleas of Cumberland County, Pennsylvania Monica Ditzler v5. Michelle Zerbe a/k/a Michelle Laudermilch 08-5445 civil No. Now, September 18, 2008 , I, SHERIFF OF C lYMERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin - County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. 11 Sheriff of Cumberland County, PA Affidavit of Service Now, 20 , at o'clock M. served the within upon at by handing to a and made known to Sworn and subscribed before me this day of , 20 copy of the original the contents thereof. So answers, Sheriff of COSTS SERVICE MILEAGE, AFFIDAV T I County, PA a3AI30 I C :6 WV SZ AS 90 }4; f1 €',3Ii ?tln,'_? IRit°'?`; pe tjt.t of t4e 'sor*rf Mary Jane Snyder Real Estate Depu William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Z-- Commonwealth of Pennsylvania MONICA DITZLER VS County of Dauphin MICHELLE ZERBE A/K/A MICHELLE LAUDENMILCH Sheriffs Return No. 2008-T-2036 OTHER COUNTY NO 1085445 And now: SEPTEMBER 30, 2008 at 1:20:00 PM served the within WRIT OF SUMMONS upon MICHELLE ZERBE A/K/A MICHELLE LAUDENMILCH by personally handing to MICHELLE ZERBE A/K/A MICHELLE LAUDENMILCH 1 true attested copy of the original WRIT OF SUMMONS and making known to him/her the contents thereof at 10 S. HANOVER STREET HERSHEY PA 17033 Sworn and subscribed to before me this 30TH day of September, 2008 11? NOTARIAL SEAL. ARY JANE. SNYDER, Notary Public Highspire, Dauphin County M Commission Expires Sept 1 2010 So Answer Sheriff of By Deputy Sh Deputy: G Sheriffs C Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy $49.25 9/25/2008 SHERIFF'S RETURN - REGULAR CASE NO: 2008-05477 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND YORK UNITARY PRODUCTS GROUP VS A D D ENTERPRISE INC NOAH CLINE Cumberland County,Pennsylvania, Sheriff or Deputy Sheriff of who being dully sworn according to law, says, the within COMPLAINT & NOTICE was served upon A D D ENTERPRISE INC the DEFENDANT at 2000:00 HOURS, on the 2bd day of October , 2008 at C/O A DANE DERR - PRESIDENT 2116 CANTERBURY DRIVE MECHANICSBURG, PA 17055 by handing to A DANE DERR 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 20.00 Postage .59 Surcharge 10.00 .00 i6/o4lb,r, ?.,, 48.59 Sworn and Subscibed to before me this of So Answers: ?d R. Thomas Kline 10/07/2008 KODAK & IMBLUM By: day Deputy Sheriff A.D. Thomas J. Williams, Esquire I.D. No. 17512 Katie J. Maxwell, Esquire I.D. No. 206018 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs MONICA DITZLER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. MICHELLE ZERBE a/k/a MICHELLE LAUDERMILCH, Defendant TO THE PROTHONOTARY: NO. 08 - 5445 CIVIL TERM CIVIL ACTION - LAW : JURY TRIAL DEMANDED PRAECIPE Enter the appearance of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER on behalf of the Defendant in the above matter. Issue a rule upon the Plaintiff to file a Complaint within twenty (20) days from service thereof or suffer judgment of non pros. MARTSON LAW OFFICES By: Thomas J. liams, Es uire I.D. No. 1 512 Katie J. Maxwell, Esquire I.D. No. 206018 Attorneys for Plaintiff Dated: / RULE AND NOW, thisle?Iday of 40. , 2008, a Rule is issued upon the Plaintiff to file a Complaint within twenty (20) days from service hereof or suffer judgment of non pros. Prothonotary CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent for Martson Deardorff Williams Otto Gilroy & Faller, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: William P. Douglas, Esquire DOUGLAS LAW OFFICE 43 West South Street Carlisle, PA 17013 MARTSON LAW OFFICES By . 0-4,1CC M. Price Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: OP, r, ? ? "?"' ' `rte ' , ??t :- , William P. Douglas, Esq. Supreme Court I.D. 1137926 Douglas Law Office 43 W. South St. Carlisle, PA 17013 Telephone (717) 243-1790_ Monica Ditzler In the Court of Common Pleas of Plaintiff Cumberland County, Pennsylvania vs No. 08 - 5445 Civil Term Robin Meczywor Civil action law Jury Trial Demanded 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 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle PA 17013 717-249-3166 DATE: January 6, 2009 r BY Complaint 1. The plaintiff, Monica Ditzler is an adult individual residing at 536 Grahams Woods Road, West Pennsboro Township, Cumberland, Pennsylvania. 2. The defendant, Robin Meczywor, is an adult individual residing at 10 S. Hanover St, Hershey, Dauphin County, Pennsylvania. 3. On or about, December 23, 2004, the plaintiff Monica Ditzler, was operating her vehicle on the Carlisle Pike in Middlesex Township Coumberland County, Pennsylvania. 4. At about the same time and place, the defendant was operating her vehicle on the same roadway behind the plaintiff and proceeded to collide with the vehicle occupied by the plaintiff. 5. The impact occurred as a direct and proximate result of the defendant's negligence. 6. The defendant was negligent in the following respects: a) failing to maintain a proper lookout; b) failing to drive within the assured clear distance ahead; 7. As a direct and proximate result of the negligence of the defendant the plaintiff, Monica Ditzler, was injured. Her injuries, and/or aggravation of possible pre-existing condition(s), include but are not limited to: a) injury to her spine and supporting structures; b) injury to her nerves and nervous system; C) various sprains/ strains 8. As a result of her injuries, the plaintiff has incurred medical expenses in the past and may continue to incur the same in the future in amounts that may not be covered by the Pennsylvania Motor Vehicle Financial Responsibility Act. 9. As a result of her injuries, the plaintiff has incurred pain and suffering and may continue to incur the same in the future. 10. As a result of her injuries, the plaintiff has incurred aggravation, inconvenience, disability, and a loss of life's pleasures, and may continue to incur the same in the future. 11. As a result of the injuries the plaintiff sustained on December 23, 2004, the plaintiff may have lost wages and the plaintiff's economic horizons may be limited. 12. As a direct and proximate result of the negligence of the defendant the plaintiff was required to incur expenses not covered by automobile insurance. Wherefore it is prayed that judgment be entered in favor of the plaintiff and against the defendant in an amount in excess of that requiring compulsory referral to arbitration. A jury trial is hereby demanded. January 6, 2009 Res ectf 11 Y mitte , V William P. Douglas, Esq. Attorney for Plaintiff AFFIDAVIT I hereby swear or affirm that the foregoing is true and correct to the best of my knowledge and/or information and belief. This is made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: January 6, 2009 William P. Douglas Attorney for Plaintiff z" --r? '-? ` Y aw-t t CY? .. ?'? a = .... .Y,. William P. Douglas, Esq. Supreme Court I.D. #37926 Douglas Law Ofjrce 43 W. South St. Carlisle, PA 17013 Telephone (717) 243-1790 Monica Ditzler vs Michelle Zerbe a/k/a Michelle Laudermilch In the Court of Common Pleas of Plaintif j`' Cumberland County, Pennsylvania Defendant NQMCE Amended Complaint Civil action law Jury Trial Demanded Amended Complaint 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, GO TO OR TELEPHONE THE OFFICE STET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland CoMMy Bar Association 32 S. Bedford Sheet Carlisle PA 17013 717-249-3166 DATE: February 12,2W9 No. 08 -- 5445 Civil Term a.? e Amended Complaint 1. The plaintiff, Monica Ritzier is an adult individual residing at 536 Grahams Woods Load, West Pennsboro Township, Cumberland, Pennsylvania. 2. The defendant, Michelle Z,erbe a/k/a Midnelle Iaudermilch, is an adult individual residing at 10 S. Hanover St, Hershey, Dauphin County, Pennsylvania. 3. On or about, yember 14, 2006, the plaintiff Monica Ditzler, was operating her de on the Carlisle Pike in h iddlesex Township Commberland County, Pennsylvania. 4. At about the same time and place, the defendant was operating her vehicle on the same roadway behind the plaintiff and proceeded to collide with the vehicle occupied by the plaintiff. 5. The impact occurred as a direct and pr+oximabe result of the defendant's negligence. 6. The defendant was negligent in the following respects: a) failing to maintain a groper lookout; b) failing to drive within the assured dear distance ahead, 7. As a direct and proximate result of the negligence of the defendant the plaintiff, Monica Ditzler, was injured. Her injuries, and/or aggravation of pomble pre-existing condition(s), include but are not limited to: a) i nlury to her spine and supporting structures; b) injury to her nerves and nervous system; 0 various sprains/strains 8. As a result of her irquries, the plaintiff has incurred medical expenses in the past and may continue to incur the same in the future in amounts that may not be covered by the Pennsylvania Motor Vehicle Financial Responsibility Act. 9. As a result of her irquries, the plaintiff has incurred pain and suffering and may continue to incur the same in the future. 10. As a result of her injuries, the plaintiff has incurred aggravation, inconvenience, disability, and a loss of life's pleasures, and may continue to incur the same in the future. 11. As a result of the injuries the plaintiff sustained on September 14, 2006, the plaintiff may have lost wages and the plaintiff's economic horizons may be limited. 12. As a direct and proximate result of the negligence of the defendant the plaintiff was required to incur expenses not covered by automobile insurance. Wherefore it is prayed that judgment be entered in favor of the plaintiff and against the defendant in an amount in excess of that requiring compulsory referral to arbitration. A jury trial is hereby demanded. February 12, 2009 William P. Douglas, Attorney for Plai AFFIDAVIT I hereby swear or affirm that the foregoing is true and correct to the best of my knowledge and/or information and belief. This is made subject to the penalties of 18 Pa.C.S.A. §4904 reI to unworn falsification to authorities. 1 William P. Douglas Date: February 12, 2009 Attorney for plaintiff C'? ? t:?. ?? ? ',? ? ? I ? t c?.s ? i ? r ? ? `? .-?? ` - ? <; -r} ; .r? '?' ?? -? .-,? William P. Douglas, Esq. Supreme Court I.D. #'37926 Douglas Law Office 43 W. South St. Carlisle, PA 17013 Telephone (717) 243-1790_ Monica Ditzler in the Court of Common Pleas of Plaintiff Cumberland County, Pennsylvania vs No. 08 - 5445 Civil Term Michelle Zerbe a/k/a Michelle Laudermilch Defendant Civil action law Jury Trial Demanded Praecipe to Settle and Discontinue Dear Mr. Long: Please mark the above captioned matter settled and discontinued with prejudice. ?k Lh ---, William gla Esq. Attorney for Pl tiff date: June 16, 2009 OF THE-- I, !?7ARY 2009 JUN 17 Pf 3: 14