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Home My WebLink About08-6852 WILLIAM A. ADDAMS, ESQ. 43 W. SOUTH ST. POB 261 CARLISLE PA 17013 Attorney ID#: 06265 TELEPHONE 717-243-7638 GEICO ASO/ Tunde B. Nabbie Plaintiff vs KELLY HOCKER Defendant Sir: In the Court of Common Pleas of Cumberland County, PA No. N - (08502 (21vi l Terw? Civil Action Law PRAECIPE Please issue a Writ of Summons against Kelly Hocker, 505 Third St., Apt. 2, Enola, Pa 17025. William A. Addams, Esquire Attorney for Plaintiff 43 W. South St., Carlisle, PA 17013 717-243-7638 To: Curt Long, Prothonotary Date: November 19, 2008 WILLIAM A. ADDAMS, ESQ. 43 W. SOUTH ST. POB 261 CARLISLE PA 17013 Attorney ID#: 06265 TELEPHONE 717-243-7638 GEICO ASO/Tunde B. Nabbie Plaintiff vs KELLY HOCKER Defendant In the Court of Common Pleas of Cumberland County, PA No. 0$ - (og,5a lest- vi I (erw? Civil Action Law WRIT OF SUMMONS TO: Kelly Hocker, 505 Third St, Apt. 2, Enola, PA 17025 And now, this Aday of November, 2008, a Writ of Summons is issued in accordance with the attached praecipe, and you are hereby notified that GEICO ASO/Tunde B. Nabbie has commenced an action against you. Date: NovemberZ,2008 , cj? 'Curt Long, Prothonotdly 6 E 13 '? 00 ? W Q W ?o a C 4 Q ? t7 ? ma'r` ? ?[3 RED -? SHERIFF'S RETURN - REGULAR CASE NO: 2008-06852 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GEICO VS HOCKER KELLY RONALD E HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon T4nrWRR KRT TAY the DEFENDANT , at 0019:58 HOURS, on the 24th day of November-, 2008 at 505 THIRD STREET APT 2 ENOLA, PA 17025 by handing to TUNDE NABBIE ADULT IN CHARGE a true and attested copy of WRIT OF SUMMONS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 13.50 Affidavit .00 Surcharge 10.00 R. Thomas Kline Postage .42 41.92 12/01/2008 WILLIAM ADDAMS Sworn and Subscibed to By: C?;;? before me this day Deputy Sheriff of A.D. WILLIAM A. ADDAMS, ESQ. 43 W. SOUTH ST. POB 261 CARLISLE PA 17013 Attorney ID#: 06265 TELEPHONE 717-243-7638 GEICO ASO/ Tunde B. Nabbie Plaintiff vs No. 08-6852 CIVIL KELLY HOCKER Defendant In the Court of Common Pleas of Cumberland County, PA Civil Action Law COMPLAINT 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 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 South Bedford Street Carlisle PA 17013 717-249-3166 Dated: June 2, 2009 William A'A` aims Attorney„ for Plaintiff 144 Z- ?'^i 6r Z u?. COMPLAINT AND NOW, comes the Plaintiff, GEICO ASO/Tunde B. Nabbie, by its attorney, William A. Addams, and files the following complaint. 1. The plaintiff is GEICO, a corporation authorized to conduct insurance business in the Commonwealth of Pennsylvania with its offices and principal place of business at One GEICO Blvd., Fredericksburg, VA 22412-0001. 2. The defendant is Kelly Hocker, an adult individual, residing at 505 Third St., Apt. 2, Enola, Pa 17025. 3. The plaintiff issued a policy of automobile insurance to Tunde B. Nabbie of Camp Hill, PA, which was in effect on December 1, 2006. 4. Tunde B. Nabbie was the owner of a 2006 Ford Escape, which was at the apartment complex on Richland Lane in Camp Hill, PA, on December 1, 2006. 5. At that time and place, the defendant was driving a vehicle on Richland Lane when she negligently, carelessly and recklessly drove into the Ford causing the damage hereinafter set forth. 6. As a result of the negligence, carelessness and recklessness of the defendant, the automobile owned by Tunde B. Nabbie sustained damage in the amount of $8,032.53. 7. The defendant has acknowledged liability and has paid $990 of the loss. WHEREFORE, the plaintiff demands judgment against the defendant in the amount of $7,042.53, plus interest and costs of suit, an amount within the jurisdiction of arbitration under the local rules of court. Will am A. Addams Attorney for the Plaintiff VERIFICATION William A. Addams hereby verifies that the facts set forth in the foregoing compliant are true and correct to the best of his knowledge, information, and belief. I understand that false statements herein made are subject to the provisions of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Tune 2, 2009 ?' //' lee - Date Wi iam A. Addams, Esquire Attorney for Plaintiff WILLIAM A. ADDAMS, ESQ. 43 W. SOUTH ST. POB 261 CARLISLE PA 17013 Attorney ID#: 06265 TELEPHONE 717-243-7638 GEICO ASO/ Tunde B. Nabbie Plaintiff vs In the Court of Common Pleas of Cumberland County, PA No. 08-6852 CIVIL KELLY HOCKER Defendant Civil Action Law CERTIFICATE OF SERVICE AND NOW, this 2nd day of June, 2009, I, William A. Addams, Esquire, hereby certify that I have this date mailed a copy of the complaint to the defendant at the following address: Kelly Hocker 505 Thid St., Apt. 2 Enola, PA 17025 William A. Addams Attorney for Plaintiff 43 W. South St. Carlisle, PA 17013 717-243-7638 z z- H,I'ii 6 a 0 Z 1 WILLIAM A. ADDAMS ATTY. I.D. # 06265 43 W. SOUTH ST. P.O. BOX 261 CARLISLE, PA. 17013 717-243-7638 Plaintiff' CUMBERLAND County Pennsylvania vs KELLY HOCKER Defendants No. 08-6852 Civil Action Law To: Curtis Long, Prothonotary: PRAECIPE Sir: Please enter a judgment in the amount of $7,042.53 in favor of the plaintiff and against the defendant for failure to enter an appearance or file an Answer to the Complaint endorsed with a Notice to Defend. The undersigned hereby certifies that the attached written Notice of Intention to File this Praecipe was mailed to the defendant on the date show thereon, which was after the default occurred and at least ten (10) days prior to the filing of this Praecipe. William A. A dams, Esquire Attorney for Plaintiff 43 W. South St. Carlisle, PA 17013 717-243-7638 August 10, 2009 WILLIAM A. ADDAMS ATTY. I.D. # 06265 43 W. SOUTH ST. P.O. BOX 261 CARLISLE, PA. 17013 717-243-7638 CO ASO / TUNDE B. NABBIE In the Court of Common Pleas of Plaintiff CUMBERLAND County Pennsylvania VS KELLY HOCKER Defendants No. 08-6852 Civil Action Law To: Kellv Hocker 505 Third St., Apt. 2 Enola, PA 17025 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET HELP. Legal Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 WILLIAM A. ADDAMS, ESQUIRE Attorney for Plaintiff 43 W. South St. Carlisle, PA 17013 717-243-7638 July 27, 2009 FILED--C. _f "t- `` ?G09 A"J'G 12 !1111 : 12 Lid: ?r?r I'c(. I E" Q /'f UU e? 3y4? a d 9>/v