HomeMy WebLinkAbout09-2596WILLIAM A. ADDAMS, ESQUIRE
ATTORNEY ID # 06265
43 W. South St.
P.O. BOX 261
CARLISLE PA 17013
TELEPHONE 717-243-7638
DI
Plaintiff
In the Court of Common Fleas of
Cumberland County Pennsylvania
vs
No. 6f . a? S96&,?;(
MAURICE VIANEY
Defendant
Civil Action Law
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.
Court Administrator
Fourth Floor
Cumberland County Court House
1 Court House Square
Carlisle, Pa. 17013
717-240-6200
WILLIAM A?TDDAMS, ESQUIRE
DATE: APRIL 24, 2009
WILLIAM A. ADDAMS, ESQUIRE
ATTORNEY ID # 06265
43 W. South St.
P.O. BOX 261
CARLISLE PA 17013
TELEPHONE 717-243-7638
...................................................................................... ........................
YOLANDA DICKEY In the Court of Common Pleas of
Plaintiff Cumberland County Pennsylvania
vs
No. D F-
MAURICE VIANEY
Defendant
Civil Action Law
.
. ........... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...................................... : . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .............................................................. . ...............
COMPLAINT
AND NOW, comes the Plaintiff, Yolanda Dickey by her attorney, William
A. Addams, and files the following complaint.
1. The plaintiff Yolanda Dickey, an adult individual residing at 119
Worchester Ave., Apt. 10, Harrisburg, PA 17011.
2. The defendant is Maurice Vianey, an adult individual residing at 710
Hanover Manor, Carlisle, PA 17013.
3. The plaintiff was the owner of a 1995 DAt. Caravan, which on May
14, 2007, at about 8 A.M. was traveling North on near Regina St. in
Harrisburg, and slowed for traffic..
4. At the same time the defendant was operating a vehicle behind the
plaintiff when he negligently and carelessly collided with the rear of the
plaintiff's vehicle causing the damages hereinafter set forth.
5. The defendant was negligence and careless in:
Tom...
a. Traveling too fast for conditions,
b. Following too closely,
b. Failing to have his vehicle under control.
6. As a result of the defendant's negligence and carelessness, the
plaintiff's Dodge was a total loss. The vehicle had an actual cash value of
$1,783.03, and a net salvage value of $131.50 for a loss of $1,651.53. In addition,
the plaintiff incurred rental expense of $238.59.
WHEREFORE, the plaintiff demands judgment against the defendant in
the amount of $1,890.12 plus interest and costs, an amount within the jurisdiction
of arbitration under the local rules of court.
v?
William A. A dams
Attorney for Plaintiff
4
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.
April 24, 2009
William A. Addams
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WILLIAM A. ADDAMS, ESQUIRE
ATTORNEY ID # 06265
43 W. South St.
P.O. BOX 261
CARLISLE PA 17013
TELEPHONE 717-243-7638
PRAECIPE
To Prothonotary:
Sir:
Please reinstate the complaint.
July 19, 2012
To: David G. Buell
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p
William A. A ams
Attorney for Plaintiff
43 W. South St.
Carlisle, PA 17013
717-243-7638
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
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Yolanda Dickey
vs.
Maurice Vianey
Case Numbl
2009-2596
SHERIFF'S RETURN OF SERVICE
08/01/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent sE
and inquiry for the within named defendant to wit: Maurice Vianey, but was unable to locate him in hi
bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Mai
Vianey. Request for service at 1582 Holly Pike #2, Carlisle, Pennsylvania 17015 the Defendant was
found. Deputies were advised, current owner of this residence has owned this property for five years
has never heard of the Defendant.
SHERIFF COST: $39.45
August 01, 2012
SO ANSWERS,
RONNY R ANDERSON, SHERIFF
j OU!liy Suite, Shenff. TQILOSO(t. Ili-'