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Home My WebLink About09-5691IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JAMIE FORREY and CHASTITY M. FORREY, Husband and wife, residing at 100 Wertz Run Road, Carlisle, Cumberland County, Pennsylvania 17013 Plaintiffs vs. JOHN V. PRICE, an individual residing at 1075 Sadler Drive, Carlisle, Cumberland County, Pennsylvania 110j.3 and JOHN ERIC GATES, an individual residing at 407 S. Pitt Street, Carlisle, Cumberland County, Pennsylvania, i 7013 Defendants No. Civil Action - Law Equity PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue writ of summons in the above-captioned action. 2009 _X Writ of Summons shall be issued and forwarded to ( ) Attorney ( X ) Sheriff David W. Knauer David W. Knauer. P.C. 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 Names/Address/Telephone No. of Attorney ignature of;Wr ey Supreme Court ID No. 21582 Date / 7j -7_-J4 f WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANTS: YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFFS HAVE COMMENCED AN ACTION AGAINST YOU. Prothonotary Date: 7 By: Deputy ? ( ) Check here if reverse is issued for additional information PROTHON. - 55 OF 4VPTP'Allll, r, 2009 AUG 17 Pfd 4.21 CuW6, 'ter JtJ VflVNfl J P?1ti1ni??'?[.Uri:I'J? s 7 ?-, -6 P 1 n Locf 4 ?}SS0 C, c1-4 r 7 Q- G l -/s- X)L-9 313 Sheriffs Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor oMC F M, >?.?k F r T}'F F 2D9 S`?1' 21 11: t? L Jamie Forrey I Case Number vs. 2009-5691 John V. Price SHERIFF'S RETURN OF SERVICE 08/27/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: John Eric Gates, but was unable to locate him in his bailiwick. He therefore returns the within Writ of Summons as not found as to the defendant John Eric Gates. The Carlisle Postmaster has advised the defendant is not known at 407 S. Pitt Street Carlisle, PA 17013. An exact address is not available. 09/04/2009 Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on September 4, 2009 at 1459 hours, he served a true copy of the within Writ of Summons, upon the within named defendant, to wit: John V. Price, by making known unto himself personally, at 67 Media Road Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $60.24 September 08, 2009 SO ANSWERS, 00 ?rrlrK • R THOMAS KLINE, SHERIFF A"jklQ'-d ?- Deputy Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMIE FORREY and CIVIL DIVISION CHASTITY M. FORREY, husband and wife, NO. 09 - 5691 Plaintiffs, PRAECIPE FOR APPEARANCE V. JOHN V. PRICE and JOHN ERIC GATES, Defendants. (Jury Trial Demanded) Filed on Behalf of the Defendants Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, P.C. Firm #911 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 (717) 901-5916 #17383 L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMIE FORREY and CIVIL DIVISION CHASTITY M. FORREY, husband and wife, Plaintiffs, NO. 09 - 5691 V. (Jury Trial Demanded) JOHN V. PRICE and JOHN ERIC GATES, Defendants. PRAECIPE FOR APPEARANCE TO: THE PROTHONOTARY Kindly enter the Appearance of the undersigned, Kevin D. Rauch, Esquire, of the law firm of Summers, McDonnell, Hudock, Guthrie & Skeel, P.C., on behalf of the Defendants, John V. Price and John Eric Gates, in the above case. JURY TRIAL DEMANDED Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C,, By: in D. f Rauch, Esquire nseFfor Defendants CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing PRAECIPE FOR APPEARANCE has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this 24TH day of September, 2009. David W. Knauer, Esquire David W. Knauer, P.C. 411-A East Main Street Mechanicsburg, PA 17055 SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. By: K vin D. Bauch, Esquire ounsel for Defendants FLED r M9 Sv I' 25 Fi f 2• .: u W.Y. _ 5 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMIE FORREY and CIVIL DIVISION CHASTITY M. FORREY, husband and wife, Plaintiffs, NO. 09 - 5691 V. JOHN V. PRICE and JOHN ERIC GATES, Defendants. (Jury Trial Demanded) RULE AND NOW, this asp day of Q rrn r 2009, upon consideration of Defendant's Praecipe for Rule to File a Complaint, a Rule is hereby granted upon Plaintiffs to file a Complaint within twenty (20) days of service, or suffer judgment Non Pros. Rule issued this day of S?gh, ? , 2009. Prothonota DXA Distribution to: Kevin D. Rauch, Esquire Summers, McDonnell, Hudock, Guthrie & Skeel, P.C. 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 David W. Knauer, Esquire David W. Knauer, P.C. 411-A East Main Street Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMIE FORREY and CIVIL DIVISION CHASTITY M. FORREY, husband and wife, NO. 09 - 5691 Plaintiffs, PRAECIPE FOR RULE V. TO FILE COMPLAINT JOHN V. PRICE and (Jury Trial Demanded) JOHN ERIC GATES, Defendants. Filed on Behalf of the Defendants Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, P.C. Firm #911 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 (717) 901-5916 #17383 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMIE FORREY and CIVIL DIVISION CHASTITY M. FORREY, husband and wife, Plaintiffs, NO. 09 - 5691 V. (Jury Trial Demanded) JOHN V. PRICE and JOHN ERIC GATES, Defendants. PRAECIPE FOR RULE TO FILE COMPLAINT TO: The Prothonotary Kindly rule the Plaintiffs, Jamie Forrey and Chastity M. Forrey, to file a Complaint in Civil Action within twenty (20) days. Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE & S,K&U. P.C. By: in D. Roch, Esquire nsel for Defendants CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing PRAECIPE FOR RULE TO FILE COMPLAINT has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this 24TH day of September, 2009. David W. Knauer, Esquire David W. Knauer, P.C. 411-A East Main Street Mechanicsburg, PA 17055 SUMMERS, McDONNELL, HUDOCK, GUTHRIE & WEEL P.C. By. vK;v .41v K vin D. uch, Esquire ounsel for Defendants Y f.. O s tti_ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JAMIE FORREY and CHASTITY M. FORREY, Husband and wife, No. 09-5691 Plaintiffs Civil Action - Law vs. JOHN V. PRICE, and JOHN ERIC GATES Defendants NOTICE TO DEFEND AND CLAIM RIGHTS 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, 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 LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle, PA 17013-3302 (717) 249-3166 NOTICIA LISTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta comparecencia escrita y radicando en la Corte por escrito sus defenses de, y objecciones a, las demandas presentadas aqui en contra suya. Se le adviote de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMATION A CERCA DE COMP CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle, PA 17013-3302 (717) 249-3166 Date: 19" DAVID W. KNAUER, L.S.C. David W. Knauer, Esquire Attorney for the Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JAMIE FORREY and CHASTITY M. FORREY, Husband and wife, Plaintiffs vs. JOHN V. PRICE, and JOHN ERIC GATES No. 09-5691 Civil Action - Law Defendants COMPLAINT COUNTI JAMIE FORREY V. JOHN ERIC GATES NEGLIGENCE WITH COMPENSATORY AND PUNITIVE DAMAGES 1. The Plaintiff Jamie Forrey is an adult individual with an address of 100 Wertzville Run Road, Carlisle, Pennsylvania 17013. 2,. The Plaintiff, Chastity Forrey, is an adult individual and the wife of the Plaintiff, Jamie Forrey, and resides with him a this aforesaid address. 3. The Plaintiff, Chastity Forrey, was the owner of a certain 2000 Ford Taurus vehicle at all ties relevant herein. 4. The Defendant, John V. Price, was the owner of a certain 2003 Cavalier Chevrolet at all times relevant herein. 5. In the alternative, at all times relevant herein, the Defendant, John Eric Gates, was the agent, servant, workman or employee of the Defendant, John V. Price, and was then and there engaged on behalf of the Defendant, John V. Price, and within the scope of the aforesaid relationship. 6. On or about 9:00 a.m. on August 18, 2007, the Plaintiff, Jamie Forrey, was the operator of the aforesaid Ford Taurus. 7. At the aforesaid time and date, the Defendant, John Eric Gates, was the operator of the aforesaid Chevrolet Cavalier. 8. The Plaintiff, Jamie Forrey, on the aforesaid date and time was lawfully proceeding on Carlisle Pike and the intersection of Woods Drive in Silver Spring Township, Cumberland County, Pennsylvania. 9. At the aforesaid date, time and location, the Defendant, John Eric Gates, was following the Plaintiff's aforesaid vehicle in the aforesaid Chevrolet Cavalier and so operated his vehicle that it ran into the rear of the aforesaid Ford Taurus. 10. After striking the Plaintiff's aforesaid vehicle, the Defendant, John Eric Gates, did not stop but fled the scene at a high rate of speed. 11. When the Plaintiff, Jamie Forrey, saw the Defendant Gates flee the scene of the collision at a high rate of speed, the Plaintiff gave chase. 12. The Defendant, John Eric Gates, in attempting to flee tried to make a ninety degree left turn at or near 261 Woods Drive, lost control of the Chevrolet Cavalier and the police report states that: Unit #1 failed to negotiate a 90 degree left turn in the roadway at #261 Woods Dr., and slide sideways striking a mailbox post with the right side of the vehicle. The car continued up a slight embankment and ran through a planted soybean field for approximately 75 yrds. before (sic) coming to rest. 2 The Plaintiffs mark as Exhibit "A", attach hereto and incorporate herein by reference thereto a true and correct copy of the aforesaid Police Report. 13. At all times relevant, the Defendant, John Eric Gates, did not have a valid driver's license. 14. In the alternative, the aforesaid collision was caused solely by the carelessness, recklessness and negligence of the Defendant, John Eric Gates, in that he: a.) was operating the aforesaid Chevrolet Cavalier without a valid driver's license; b.) failed to keep an assured clear distance in violation of the statutes of the Commonwealth; c.) was operating the aforesaid Chevrolet Cavalier at an excessive rate of speed in violation of the posted speed limit; d.) failed to keep violent; e.) failed to use the brakes on the aforesaid Chevrolet; f.) failed to see the Plaintiff's vehicle; g.) failed to avoid striking the Plaintiff's vehicle; h.) struck the Plaintiff's vehicle; i.) was otherwise negligent; j.) failed to stop after the accident but fled the scene. 15. The Defendant, John Eric Gates, intentionally fled the scene of the collision in violation of the laws of the Commonwealth of Pennsylvania thereby evidencing a reckless disregard for the rights of the Plaintiff. 3 16. Solely as a result of the carelessness, recklessness and negligence of the Defendant, John Eric Gates, the collision occurred and the Plaintiff suffered severe and sundry injuries to his person some or all of which are permanent. 17. Solely as a result of the carelessness, recklessness and negligence of the Defendant, John Eric Gates, the accident occurred and the Plaintiff suffered the aforesaid injuries and is entitled to the following past and future elements of damage: a.) medical expenses; b.) pain and suffering; c.) wage loss: d.) emotional distress; e.) loss of enjoyment of life; f.) punitive damages because the Defendant, John Eric Gates, evidenced a reckless disregard for the Plaintiff's and other motorists rights when he was operating a motor vehicle without a license in violation of the laws of the Commonwealth of Pennsylvania, failed to stop after the accident and fled the scene of the accident. WHEREFORE, the Plaintiff demands judgment in his favor and against the Defendant for both compensatory and punitive damages. COUNT II JAMIE FORREY V. JOHN V. PRICE NEGLIGENT ENTRUSTMENT WITH COMPENSATORY AND PUNITIVE DAMAGES 18. Pursuant to Pa.R.C.P. No. 1019(g), the Plaintiff incorporates herein by reference thereto paragraph 1 through 16 inclusive as if more fully set forth herein. 4 19. The Defendant, John V. Price, placed the vehicle he owned in the hands of an unlicensed driver. 20. In the alternative, the Defendant, John V. Price, was negligent in that he: a.) failed to determine if the Defendant, John Eric Gates, had a valid driver's license in his possession before allowing him to drive his aforesaid Chevrolet; b.) failed to determine if the Defendant, John Eric Gates, was competent to drive the aforesaid Chevrolet in accordance with the statutes of the Commonwealth of Pennsylvania; c.) allowed the Defendant, John Eric Gates, to drive his aforesaid vehicle without confirming his ability to operate a motor vehicle; d.) allowed the Defendant, John Eric Gate, to drive his aforesaid vehicle without a valid driver's license; e.) was otherwise negligent/; 21. Solely or jointly with the Defendant, John Eric Gates, the accident occurred and was the result of the Defendant, John V. Price, entrusting his aforesaid vehicle to the Defendant, John Eric Gates, whose carelessness, recklessness and negligence caused the accident in which the Plaintiff suffered the aforesaid injuries and the Plaintiff is entitled is to the following past and future elements of damage: a.) medical expenses; b.) pain and suffering; c.) wage loss: d.) emotional distress; e.) loss of enjoyment of life; 5 f.) punitive damages because the Defendant, John Eric Gates, evidenced a reckless disregard for the Plaintiff's and other motorists rights when he was operating a motor vehicle without a license in violation of the laws of the Commonwealth of Pennsylvania, failed to stop after the accident and fled the scene of the accident. WHEREFORE, the Plaintiff demands judgment in his favor and against the Defendant for both compensatory and punitive damages. COUNT III JAMIE FORREY V. JOHN ERIC GATES RESPONDEAT SUPERIOR 22. Pursuant to Pa.R.C.P. No. 1019(g), the Plaintiff incorporates herein by reference thereto paragraph 1 through 21 inclusive as if more fully set forth herein. 23. Pursuant to the doctrine of respondeat superior, the Defendant, John V. Price, is liable for the negligence of his agent, servant, workman or employee, John Eric Gate, who caused the aforesaid collision that injured the Plaintiff, Jamie Forrey. WHEREFORE, the Plaintiff demands judgment in his favor and against the Defendant for both compensatory and punitive damages. COUNT IV CHASTITY FORREY V. JOHN ERIC GATES LOSS OF CONSORTIUM 24. Pursuant to Pa.R.C.P. No. 1019(g), the Plaintiff incorporates herein by reference thereto paragraph 1 through 23 inclusive as if more fully set forth herein. 6 25. Solely as a result the recklessness, negligence of the Defendant, John Eric Gates, the Plaintiff has suffered the loss of consortium. WHEREFORE, the Plaintiff demands judgment in his favor and against the Defendant for both compensatory and punitive damages. COUNT IV CHASTITY FORREY V. JOHN V. PRICE LOSS OF CONSORTIUM 26. Pursuant to Pa.R.C.P. No. 1019(g), the Plaintiff incorporates herein by reference thereto paragraph 1 through 25 inclusive as if more fully set forth herein. 27. Solely and/or jointly with the Defendant, John Eric Gates, whose carelessness, recklessness, negligence caused the aforesaid collision, the Plaintiff has suffered the loss of consortium. WHEREFORE, the Plaintiff demands judgment in his favor and against the Defendant for both compensatory and punitive damages. Date: M Q/- Ag/- Respectfully submitted, KNAUER & ASSOCIATES, L.S.C. avid W. Knauer, Esquire Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 Knauer@early.com (717) 795-7790 FAX: (717) 795-7793 7 NOTIFICATION. OF ACCIDENT INVESTIGATION (717) 97-0607 SILVER"SPRING TOWNSHIP POLICE DEPARTMENT (711) 766.-0178 (717)Z38-9676 fi475 Carlisle Pike, Mechanicsburg, PA 17050 Fax: (717) 766-5984 REPORTABLE: Notice is hereby given that the accident indicated below is being investigated by Silver Spring Township Police Depart- merit and that tt?B,,Commonweaith.ot Pennsylvania PoNce Accident Report ; will be submitted as prescribed by Secti6n 3746(c) of the Vehicle-Code NON-REPORTARLE; This is a.NON-REPORTABLE accident as pFescribed by the vehicle Code_ The information submitted below is obtained by the;Otticer for yo6r convenience in having the propel information for, your insurance company. THIS IS THE ONLY INFORMATION THE POLICE WILL HAVE. NO.REPORT WILL SE MADE. pOUCE N?CIDENF NJMBER PATROL ZONE 11ME ANQ DATE OF ACCIDENT SII? '20137-08-00535, 0202 • 0900 . hrs.::. 8/18/07 LOCATION OF ACCIDENT OFFICER'S NAME . 261 Woods Dr.- Mechbcr. Det. D' E. Sabadish UNIT # 1 UNIT # 2 36. 37. ATT ESR- J 2 9 u 38P$TATE l?? 36. LEGALLY Y N 37. REG. DA 13 38• STATE PARKED? O ? PL P ARKED? Q PLATE PA 39_ PA TITLE OR OUT-OF-STATE VIN 1 G 1 j F 5 4 F 4_ 7 2 4 2 2 7 5 39. PA TITLE OR OUT ;OF-STATE VIN 1 FAF P 5 5 2 3 Y A 17 4 0 41 40. ow1rER John V. PRICE 40, OWNER 41. OWNER. ADDRESS 1075 SadI(er Dr. RESS 100 -Wert _..Run Rd.----_- 42.6ZIPCCSTE ODE Carlisle, PA 17013 42.'&Z CODE Carlisle PA 17013 43. YEAR 2)0031 44. MAKE Chevrolet 43. YEAR 2 0 44. MAKEFord 45. MODEL (NOT BODY TYPE) Cavalier 48. I 'm N D UNK n 45. MODEL INOT Taurus BODY TYPE) 46_ INS N 0 uNlc ? 47. BODY 46. SPECIAL 49. VEHICLE 47. BODY 48. SPECIAL 6 VEHICLE TYPE 4 d.r USAGE SI OWNERSHIP TYPE 4 d r. USAGE b I u OWNERSHIP SO. INITIAL pAPACT POINT x.12 51. VEHICLE STATUS towed 52. TRAVEL SPEED 50. INITIAL IMPACT POINT #6 51. VEHICLE STATUS drive Il 52- TRAVEL SPEED 53. VEHICLE 54. DRIVER D 55. DRIVER 53. VEHICLE I 54. DRIVER O S. DRIVER GRADIENT PRESENCE CONDITION GRAD ENT PRESENCE CONDITION -56 . ? LID only) ## 27318525 57. STATE PA 56- DRIVER NUMBER 24018919 5 STATE A 5e. "M DRIVER ,john Eric GATES 58. DRIVER Jamie E. FORREY 59. DRIVER 407 S. Pit_ Street ADDRESS ? 59. DRIVER 100 Wertz Run Rd. ADDRESS 60. CITY, STATE &DPCODE Carlisle PA 17013 60. CITY, STATE &ZIPCODE Carlisle PA 17013 61. SEX h1 62. OI 10/21/82 64 91 6/8/76 960 9742 -b5 i BIRTH - 64. COMM. VEH. 65. DRIVER -DRIVER 64. COMM. VEH. 65. DRIVER 66. OMER Y 0 N n CLASS SS O Y L N G CLASS SS 67. CARRIER 67. CARRIER E"Iel 68. CARRIER ADDRESS 68. CASPIER ADDRESS 69. CITY. STATE CITY_STATE__°_- .._?. ?.- & ZIP CODE & ZIP-CODE 10. USDOT / ICC 0 PLIC t 70_ USDOT t FCC R f2. VEH. 73. CARGO 74, OVwR 72 VEH. 73. CARGO 74, GVWR CONFlG. BODY TYPE CONFlG. BODY TYPE 75. NO. OF 76. HAZARDOUS 77. RELEASE OF HAZ MAT 75. NO-. OF 76. HAZARDOUS 71. RELEASE OF MAT AXLES MATERIALS Y 0 N 0 UNK f? AXLES MATERIALS Y-0 N cv, - UNK 0 INSURANCE COMPANY State Farm Mutual (570) 724- TO COMPANY Progressive 1-800^776-4737 INFORMATION INFORMA N -UNIT- POLICY NO. 657 6929--B13-38W 3364 -UNIT-" POLICY NO. 65511438-8 8'1?06TWGTPOWI,263,265 Woods. Drive, and :lawn @ 265, field & crop Damage at I ADDRESS OWNER Multiple - see police report PHONE accident scene. AwnmtwFUIwnw:_Driver of unit #1. hit the rear end of unit #2 on the Carlisle Pike at.. the intersection with Woods Drive. Driver of. unit #2 Pulled over and the driver of unit #1 fled the scene at a high rate.of speed. The driver of Unit ##2 pursued. Th.e,:drlver of Unit ##1 failed to negotiate a 90 degree. left turn in the roadv,Tay at #261 Woods Dr., and slide sideways striking a mailbox post with the right side o' the vehicle. The car continued up a slight embankment and ran through a planted soybea°f'°'T'ie•ld for approximately 75 yrds. before coming to rest. The driver of L* unit # 1 does not have a drivers license. SSTPDPID01 CERTIFICATE OF SERVICE 1, David W. Knauer, Esquire, hereby certify that a true and correct copy of 1 `k the within document was served on the day of October, 2009 via U.S. First Class Mail, postage prepaid, on the following individual: Kevin D. Rauch, Esquire SUMMERS, McDONNELL, HUDOCK GUTHRIE & SKEEL, L.L.P. 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 KNAUER & ASSOCIATES, L.S.C. B / Y• David W. Knauer, Esquire Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 OP THE PPCT#'MTARY 2009 OCT 26 PM 2., 00 CUN1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JAMIE FORREY and CHASTITY M. FORREY, Husband and wife, vs. JOHN V. PRICE, and JOHN ERIC GATES Plaintiffs No. 09-5691 Civil Action - Law PRAECIPE TO ATTACH VERIFICATION TO THE PROTHONOTARY: Please attach the Verifications attached hereto to the Complaint filed in this matter. Date: 4" 3-W, Respectfully submitted, KNAUER & ASSOCIATES, L.S.C. uer, Esquire WavidW. Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 Knauer@early.com (717) 795-7790 FAX: (717) 795-7793 VERIFICATION Subject to the penalties of 18 Pa.C.S.A. 4904 relating to unsworn falsification to authorities, I certify that the facts in the foregoing pleading are true and correct to the best of my information and belief. Date: J 0 LL5- VERIFICATION Subject to the penalties of 18 Pa.C.S.A. 4904 relating to unsworn falsification to authorities, I certify that the facts in the foregoing pleading are true and correct to the best of my information and belief. Date: I -CERTIFICATE OF SERVICE I, David W. Knauer, Esquire, hereby certify that a true and correct copy of the within document was served on the 3rd day of November, 2009 via U.S. First Class Mail, postage prepaid, on the following individual: Kevin D. Rauch, Esquire SUMMERS, McDONNELL, HUDOCK GUTHRIE & SKEEL, L.L.P. 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 KNAUER & ASSOCIATES, L.S.C. BY:- EV" V -,r,6rV-Af10'11-- David W. Knauer, Esquire Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 OF THE 1 ;71-', ` NOTARY 2009 NOY -5 PH 1= 4 9 utIl 1 _ JU IIFy' r- I pC' at <rS JAMIE FORREY and CHASTITY M. IN THE COURT OF COMMON PLEAS FORREY, husband and wife, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. NO. 09-5691 JOHN V. PRICE and JOHN ERIC GATES, Defendants CIVIL ACTION - LAW PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of David Knauer, Esquire, for Plaintiffs in the above matter. KNAUER & ASSOCIATES, LSP r c David W. auer, Esquire Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 Date 4k4a I) ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Plaintiffs with regard to the above- captioned matter. Date: '?" 2` 4?-w NESTICO`, DRUBY & HILDABRAND, PC Karl R. Hildabrand, Esquire Attorney I.D. No. 30102 840 East Chocolate Avenue ?q ca ' -n Hershey, PA 17033 'r rte- ::; c (717) 533-5406 - Ica 1 77" -c3 ?- CD CD c CERTIFICATE OF SERVICE I, Karl R. Hildabrand, Esquire of the law firm Nestico, Druby & Hildabrand, LLP, hereby certify that I served a true and exact copy of the foregoing document referenced to the foregoing action by First Class Mail, postage prepaid, this 2- t day of September 2010, on the following: Kevin D. Rauch, Esquire Summers McDonnell Hudock Guthrie and Skeel 1017 Mumma Road, Suite 300 Lemoyne, PA 17043 Hildabrand Karl R. Hildabrand, Esquire 7' M 3.'.*- rTi c`= -Tj Lavery Faherty Patterson v'? ?' ' ;? cox 225 Market Street, Suite 304 -?C -- P.O. Box 1245 <CD " ? ?. Harrisburg, PA 17108-1245 (717) 233-6633 (telephone) : = { ;, (717) 233-7003 (facsimile) Atty No. PA30102 -?: khildabrand@laverylaw.com Atty for Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JAMIE FORREY and CHASTITY M., Plaintiff NO. 09-5691 CIVIL ACTION - LAW V. JOHN PRICE and JOHN ERIC GATES, Defendant PRAECIPE TO WITHDRAW AND ENTER APPEARANCE PRAECIPE TO WITHDRAW APPEARANCE TO THE PROTHONOTARY: Kindly withdraw the appearance of Karl R. Hildabrand, Esquire and Nestico, Druby & Hildabrand, PC, as counsel for Plaintiffs, John V. Price and John Eric Gates, in the above matter. Respectfully submitted, NESTICO, DRUBY & HILDABRAND, PC By: Karl R. Hildabrand, Esquire Attorney I.D. No. 30102 840 East Chocolate Avenue Hershey, PA 17033 (717) 533-5406 (717) 533-5717 Date: May 10, 2012 Attorney for Plaintiffs PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Plaintiffs, John V. Price and John Eric Gates, in the above matter. Respectfully submitted, Lavery Faherty Patterson "-Karl R. Hildabrand, Esquir 225 Market Street, Suite 304 P.O. Box 1245 DATE: May 10, 2012 Harrisburg, PA 17108-1245 (717) 233-6633 (telephone) (717) 233-7003 (facsimile) Atty No. PA30102 khildabrand@laverylaw.com Atty for Plaintiffs CERTIFICATE OF SERVICE I, Janice L. Holzer, an employee with the law firm of Lavery Faherty Patterson, do hereby certify that on this 10th day of May, 2012, I served a true and correct copy of the foregoing Praecipe to Withdraw and Praecipe to Enter Appearance, via U.S. First Class mail, postage prepaid, addressed as follows: Kevin D. Rauch, Esquire Summers McDonnell Hudock Guthrie & Skeel 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 J ice L. Holzer, Legal Secreky to Karl R. Hildabrand, Esquire