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Home My WebLink About04-1493DOUGLAS LAW OFFICE 27 W. HIGH ST. POB CARLISLE PA 17013 TELEPHONE 717-243-1790 WILLIAM P. DOUGLAS, ESQ. Supreme Court I.D.# 37926 John L. Shope, HI In the Court of Common Pleas of Plaintiff Cumberland County, Pennsylvania VS 4o. 04-- /qq3 Civil Term Robert L. Evans Defendant Civil action law Jury Trial Demanded 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 717-2,$9-3166 DATE: April 7, 2004 5. 6. 7. Complaint The plaintiff, John L. Shope, III, is an adult individual residing at 7 Pine Road, Apt. 607, Mt. Holly Springs, Cumberland County, Pennsylvania. The Defendant, Robert L. Evans, is an adult individual residing at 22620 Peachtree Road, P.O. Box 182, Clarksburg, Maryland, 20871. On or about, September 26, 2003, the plaintiff was sitting in his vehicle, on Pa. Route 34, in South Middleton Township, waiting to make a turn onto Pine Road. At about the same time and place, the defendant was operating his vehicle in a northerly direction on Route 34. The defendant failed to stop for plaintiff's vehicle, that was waiting to turn, and as a result struck the rear of the plaintiff's vehicle. The impact occurred as a direct and proximate result of the defendant's negligence. The defendant was negligent in the following respects: a) failing to maintain a proper lookout; b) falling to drive within the assured dear distance ahead; c) failing to operate his vehicle in a safe and prudent manner; d) falling to stop his vehicle before he collided with the plaintiff. As a direct and proximate result of the negligence of the defendant the plaintiff was injured, his injuries, and/or aggravation of unknown pre- existing condition(s), include but are not limited to: a) injury to his nerves and nervous system; b) injury to his spine and supporting structures; c) chronic pain; As a result of his injuries, the plaintiff has incurred medical expenses in the past and may continue to incur the same in the future in amounts in excess of that covered by the Pennsylvania Motor Vehicle Financial Responsibility Act. 10. As a result of his injuries, the plaintiff has incurred great pain and suffering and will continue to incur the same in the future. 11. As a result of his injuries the plaintiff has incurred aggravation, inconvenience, possible future disfigurement, disability, and a loss of life's pleasures, and will continue to incur the same in the future. 12. As a result of the injuries the plaintiff sustained on September 26, 2003, the plaintiff may have lost wages and the plaintiff's economic horizons may be limited. 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. April 7, 2004 Respectfully submitted, 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 unswom falsification to authorities. Date: April 7, 2004 John L. Shope, III Robert L. Evans Commonwealth of Pennsylvania County of Cumberland VS Plaintiff Defendant In the Court ot! Common Pleas of Cumberland County, Pennsylvania No. 04 -- 1493 Civil Term Civil action law Jury Tri,d Demanded Acceptance of Service Service of the writ of summons is hereby accepted and receipt of a copy of the writ is hereby acknowledged. 04HB-00069 LAW OFFICES OF JACOBS & ASSOCIATES Donald R. Dorer, Esquire 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Robert L. Evans JOHN L. SHOPE, III, PLAINTIFF VS. ROBERT L. EVANS, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY~ PENNSYLVANIA No. 04- 1493 CIVILTERM CIVIL ACTION - LAW JURY TRIAL. DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance in the above-captioned matter on behalf of the Defendant, Robert L. Evans. The Defendant reserves the right to otherwise plead in this matter. Respectfully submitted, LAW O~fflCES OF JAC~C 7 ASSOCIATES Donald R. Doter, Es~ alre Attorney for Defenda~at Identification No. 39126 Date: June 23, 2004 04HB-00069 LAW OFFICES OF JACOBS & ASSOCIATES Donald R. Dorer, Esquire 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Robert L. Evans JOHN L. SHOPE, III, PLAINTIFF VS. ROBERT L. EVANS, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-11493 CIVILTERM CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a tree and correct copy of the attached Entry of Appearance to be served by regular first class mail upon: Date: June 23, 2004 William P. Douglas, Esquire Douglas Law Office 27 West High Street Carlisle, PA 17013 ~/i Donald R. Dorer, Esquire Attomey tbr Defendant DOUGLAS LAW OFFICE 27 W. HIGH ST. POB 261 CARLISLE PA 17013 TELEPHONE 717-243-1790 William P, Douglas, Esq. Supreme Ct. ID # 37926 John L. Shope, III Robert L. Evans Plaintiff VS Defendant In the Court of Common Pleas of Cumberland County, Pennsylvania No. 04 --- 1493 Civil Term Civil action law Jury Trial Demanded Praecipe to Settle and Discontinue Dear Mr. Long, Please mark the above captioned matter settled and discontinued. November 1, 2004 William P. Douglas~l~sq. Attorney for Plafn~ff