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Home My WebLink About08-6542-t Brian J. Walker, Esquire Hennessy & Walker Group, P.C. 142 W. Market Street West Chester, PA 19382 610-431-2727 Attorney I.D. 71927 Attorney for Plaintiffs State Farm Mutual Automobile Insurance company A/S/O Roberta. D Bainum P O Box 2373 Bloomington, IL 61702 VS Hollee Repman 90 Tip Top Circle Carlisle, PA 17105 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 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. Cumberland County Bar Association 32 S. Bedford St. Carlisle, PA 17013 717-249-3166 800-990-9108 . In the Court of Common Pleas : Cumberland County, Pennsylvania : Civil Action Law 0, 1% 1 AVISO Le ban demandado a usted en la torte. Si usted quiere defenderse de estas demandas expuestas en las pAginas siguientes, usted tiene veinte (20) dias de plazo ai partir de la fecha de la demanda y la notification. Hace faita asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defenses 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 continuar la demanda en contra s!rya sin previo aviso o notification. Ademas, la corte puede decidir a favor del demandante y requiere que ust-vd cumpla con todas las provisioner de esta demanda. Usted puede perdee dinero o sus propiedades u otros derechos importantes para usted. Lleva este denianda a un abogado inmediatamente. Si no dene abogado o si no dene el dinero suficiente de pagar tal servielo. Vaya en persona o llame por telifono a la oficina cuya direction se eneuentra encuentra escrita abojo para averiguar ddnde se puede conseguir asistencia legal. Cumberland County Bar Association 32 S. Bedford St. Carlisle, PA 17013 717-249-3166 800-990-9108 Brian J. Walker, Esquire Hennessy & Walker Group, P.C. 142 W. Market Street West Chester, PA 19382 610-431-2727 Attorney I.D. 71927 Attorney for Plaintiffs State Farm Mutual Automobile Insurance company A/S/O Roberta D Bainum P O Box 2373 Bloomington, IL 61702 VS Hollee Repman 90 Tip Top Circle Carlisle, PA 17105 In -the Cnurt of Common Pleas : Cumberland County, Pennsylvania Civil Action Law No: 0F- 6 COMPLAINT 1. Plaintiff State Farm Mutual Automobile Insurance company is an insurance carrier licensed and authorized to conduct business in the Commonwealth of Pennsylvania and having as one of its principal places of business the above captioned address. 2. Roberta D Bainum an adult individual insured with Plaintiff State Farm Mutual Automobile Insurance company on 04/07/2008. 3. Defendant Hollee Repman is an adult individual residing at the above captioned address. 4. On or about 04/07/2008, Plaintiff State Farm Mutual Automobile Insurance company insured Roberta D Bainum with personal automobile policy. claim number -59 Z933 826 said policy covering a -2001 Volvo and carrying with same, collision coverages. 5. On or about 04/07/2008 at or near the inter--otion of 100 Block of Cherry Street, Carlisle, Cumberland County, PA. Defendant Hollee Repman while operating a -1999 Honda bearing PA tag -GXJ 4929 did negligently or recklessly strike/collide into Plaintiff's insured's 2001 Volvo- causing damages to same in the r . .f. amount of $8,361.61. 6. The negligence of the Defendant consisted of a) failing to yield right of way; b) being inattentive; c) striking another motor vehicle lawfully upon the roadway; d) failing to give due regard to the rights, safety point and position of Plaintiff's insured's vehicle; e) failing to maintain control of said vehicle so as to be able to stop within the assured clear distances ahead; f) improper turning methods, g) failing to give proper signal h) improper methods of passing i) striking a stationary vehicle: j) other such negligence that may be developed through continuing discovery and trial of this matter. 7. The aforesaid collision resulted solely from the negligent acts and/or failure to act on part of Defendant named herein and was due in no manner whatsoever to any act and/or failure to act on part of Plaintiff's insured. 8. As a result of the aforesaid collision, Plaintiff' State Farm Mutual Automobile Insurance company settled the collision claim of Roberta. D Bainum in the amount of $8,361.61 (said figure includes the first party deductible) representing fair and reasonable reimbursement for the damages sustained. 9. Pursuant to the aforesaid policy of insurance, State Farm Mutual Automobile Insurance company is subrogated to Roberta D Bainum for this loss WHEREFORE, Plaintiffs demand judgment against the Defendant in the amount of $8,361.61 together plus costs, interest and such other relief this Court finds equitable and just. Brian J. Jalk*4'r, Esquire Hennessy& Walker SUM-19373-PA COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CHESTER : ss The undersigned verifies that the facts contained herein are true and correct. The undersigned understands that false statements herein are made subject to the penalties of 19 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. If applicable, this affidavit is made on behalf of the Plaintiff(s); that the said Plaintiff(s) is/are unable and unavailable to make this verification on its/his/her own behalf within the time allotted for filing of this pleading, and the facts set forth in the foregoing pleading are true and correct to the best of counsel's knowledge, information and belief. This verification is made pursuant to Pa. R.C.P. 1024 and is based on interviews, conferences, reports, records and other investigative material in the file Dated: 1o12- 3 e? 'r wa&Z4, Brian J. W ker, Esq. Hennessy & Walker Group, P.C. ? 000 SLs W ? t- rs Q -on m C, J 'N ? CZ) •e SHERIFF'S RETURN - REGULAR CASE NO: 2008-06542 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STATE FARM MUTUAL AUTOMOBILE VS REPMAN HOLLEE TIMOTHY R BLACK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon REPMAN HOLLEE the DEFENDANT , at 0016:40 HOURS, on the 1st day of December-, 2008 at 501 BURGNERS ROAD CARLISLE, PA 17015 by handing to HOLLEE REPMAN DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Additional Comments DEFENDANT MOVED FROM ADDRESS YOU PROVIDED OF 90 TIP TOP CIRCLE, CARLISLE, PA TO 501 BURGNERS ROAD, CARLISLE, PA. Sheriff's Costs: Docketing 18.00 Service 5.40 Affidavit .00 Surcharge 10.00 .00 33.40 Sworn and Subscibed to before me this day of So Answers: R. homas Kline 12/02/2008 HENNESSY & WALKER By. De uty Sheriff A. D. STEPHEN L. BANKO, JR., ESQUIRE Pa. Supreme Court I. D. No. 41727 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17011 Telephone: (717) 760-7501 FAX: (717) 975-6124 Attorney for Defendant E-mail: sbanko(aamargolisedelstein.com Hollee Repman TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA: Kindly enter my appearance on behalf of Defendant, Hollee Repman, in the above-captioned matter. : I) .1) Date: S EDELSTEIN N L. BANKO, JR. for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing on all counsel of record by placing the same in the United States mail at Camp Hill, ,-nb =----? Pennsylvania, first-class postage prepaid, on the day of 2008, and addressed as follows: Brian J. Walker, Esquire Hennessy & Walker Group, P.C. 142 W. Market Street West Chester, PA 19382 (Counsel for Plaintiff) Roxanne K. Weller, Secretary -, ?? r? t._ _ ., _.. .Y ?_ Brian J. Walker, Esquire Hennessy & Walker Group, P.C. 142 W. Market Street West Chester, PA 19382 610-431-2727 Attorney I.D. 71927 Attorney for Plaintiffs State Farm Mutual Automobile Insurance company A/S/O Roberta D Bainum P O Box 2373 Bloomington, IL 61702 VS Hollee Repman 501 Burgners Road Carlisle, PA 17015 In the Court of Common Pleas : Cumberland County, Pennsylvania Civil Action Law No: 08-6542 Praecive to Reinstate To The Prothonotary: Please reinstate the Complaint on the above-captioned action. Please forward to the Sheriff for service. V 1. Bri /JW4alCer, Esquire Attorney for Plaintiff 406- r4 ± ? ? Est STEPHEN L. BANKO, JR., ESQUIRE Pa. Supreme Court I. D. No. 41727 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17011 Telephone: (717) 760-7501 FAX: (717) 975-8124 Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY A/S/O DOCKET NO. 08-6542 ROBERTA D. BAINUM Plaintiff CIVIL ACTION - LAW V. HOLLEE REPMAN, JURY TRIAL DEMANDED Defendant NOTICE TO PLEAD TO: Brian J. Walker, Esquire Hennessy & Walker Group, P.C. 142 W. Market Street West Chester, PA 19382 Attorney for Plaintiff You are hereby notified to file a written response to the enclosed New Matter within twenty (20) days from service hereof or a default judgment may be entered against you. t Date: By: MAI? ?I EDELSTEIN t j) STEPHEfiL. B,?NKO, JR. Attorney for Defendant STEPHEN L. BANKO, JR., ESQUIRE Pa. Supreme Court I. D. No. 41727 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17011 Telephone: (717) 760-7501 FAX: (717) 975-8124 E-mail: sbanko(a margolisedelstein.com Attorney for Defendant Hollee Repman IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE FARM MUTUAL AUTOMOBILE DOCKET NO. 08-6542 INSURANCE COMPANY A/S/O ROBERTA D. BAINUM Plaintiff CIVIL ACTION - LAW V. JURY TRIAL DEMANDED HOLLEE REPMAN, Defendant ANSWER AND NEW MATTER OF DEFENDANT, HOLLEE REPMAN, TO PLAINTIFF'S COMPLAINT 1. Admitted. Upon information and belief, the averments contained in this paragraph appear to be true. 2. Denied. After reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph and, therefore, they are denied. 3. Denied. Defendant currently resides at 501 Burgners Road, Carlisle, PA. 4. Denied. The Answer contained in paragraph No. 2 hereof is incorporated herein by reference as if set forth in its entirety. 5. Admitted in part and denied in part. Pursuant to a Stipulation entered into between counsel for the parties, the allegation of "reckless" has been withdrawn from this paragraph and as it may appear elsewhere in the Complaint. Accordingly, and upon advice of counsel, no Answer on the part of Defendant with regard to the allegation of "reckless" is necessary. By way of further Answer, the remaining allegations in this paragraph state a legal conclusion to which no response is necessary. Further, to the extent an Answer is deemed to be required, Defendant specifically denies that she was negligent. With regard to the amount of damages allegedly incurred as a result of the conduct of the Defendant, after reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of said averment and, therefore, it is denied. 6.(a-i) Denied. The Answer contained in paragraph 5 hereof is incorporated herein by reference as if set forth in its entirety. 6.0) Pursuant to a Stipulation entered into between counsel for the parties, this allegation has been withdrawn from Plaintiff's Complaint. Accordingly, and upon advice of counsel, no Answer on the part of Defendant is required. 7. Denied. The Answer contained in paragraph 5 hereof is incorporated herein by reference as if set forth in its entirety. 8. Denied. The Answer contained in paragraph 5 hereof is incorporated herein by reference as if set forth in its entirety. 9. Denied. The allegations contained in this paragraph state a legal conclusion to which no response is necessary. By way of further Answer, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph and, therefore, they are denied. WHEREFORE, Defendant, Hollee Repman, demands judgment in her favor and against Plaintiff. NEW MATTER 10. The Answers contained in paragraphs 1 through 9 hereof are incorporated herein by reference as if set forth in its entirety. 11. Plaintiffs claim, if any, may be barred by the applicable statute of limitations. WHEREFORE, Defendant, Hollee Repman, demands judgment in her favor and against Plaintiff. Date: MARGOLIS EDELSTEIN VERIFICATION I, Hollee Repman, have read the foregoing Answer and New Matter to Plaintiff's Complaint. The factual statements contained therein are known by me and are true and correct to the best of my knowledge, information and belief. This statement and verification is made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsifications to authorities, which provides that, if I knowingly make false averments, I may be subject to criminal penalties. Date: 4oeeepman CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing on all counsel of record by placing the same in the United States mail at Camp Hill, Pennsylvania, first-class postage prepaid, on the day of , 2009, and addressed as follows: Brian J. Walker, Esquire Hennessy & Walker Group, P.C. 142 W. Market Street West Chester, PA 19382 (Counsel for Plaintiff) el?P Roxan a K. Weller, Secretary ? c7 a ?r a n I ) Y V SHERIFF'S RETURN - REGULAR CASE NO: 2008-06542 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STATE FARM MUTUAL AUTOMOBILE VS REPMAN HOLLEE 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 REPMAN HOLLEE the DEFENDANT , at 2106:00 HOURS, on the 21st day of January , 2009 at 501 BURGNERS ROAD CARLISLE, PA 17015 HOLLEE REPMAN by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscibed to before me this of So Answers: 18.00 10.80 f- .00 10.00 R. Thomas Kline .00 38.80 01/22/2009 HENNESSY & WALKER GROUP By: e- ..? day Deputy Sheriff , A.D. Po syw„? Brian J. Walker, Esquire Hennessy & Walker Group, P.C. 142 W. Market Street West Chester, PA 19382 610-431-2727 Attorney I.D. 71927 OF WOOTSW 1010JAN-5 AM11:45 Attorney for Plaintiffs State Farm Mutual Automobile Insurance company A/S/O Roberta D Bainum :In The Court of Common Pleas P O Box 2373 Bloomington, IL 61702 VS Hollee Repman 90 Tip Top CIrcle Carlisle, PA 17105 Praecive To The Prothonotary: :Cumberland County, Pennsylvania :Civil Action Law No: 08-6542 Please mark the above captioned case as Dismissed without Preju Brian lk , Esq. SUM-19373