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Home My WebLink About09-5908C WILLIAM A. ADDAMS ATTY. I.D. # 06265 43 W. South St. P.O. BOX 261 CARLISLE, PA. 17013 717-243-7638 GEICO ASO/Paul Plaintiff VS. JANAKKUMA PATEL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNY, PENNA. CIVIL ACTION LAW No. 6? - 57 jO P 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 (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 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 r¢ 717-240-6200 log William A. Addams Attorney for Plaintiff I w COMPLAINT AND NOW, comes the Plaintiff, GEICO AS SUBROGREE OF Paul Gutheinz, 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 Boulevard, Fredericksburg, VA 22412-0001. 2. The defendant is Janakkuma Patel, an adult individual residing at 324 Pegasus Road, Piscataway, New Jersey 08854. 3. The plaintiff issued a policy of automobile insurance to Paul Gutheinz of Durhamville, New York 13054, which was in effect on September 3, 2008. 4. Mr. Gutheinz is the owner of a 2005 Dodge Ram, which he was driving on September 3, 2008, traveling North on I. 81 in Hampden or East Pennsboro Township, Cumberland County, PA. in the right hand lane 5. At said time, the defendant, Janakkuma Patel, was driving a vehicle in the center of the three northbound lanes when he negligently and carelessly swerved to his right to avoid a fire tread on the road and collided with the Dodge Ram causing the damages hereinafter set forth. 6. The defendant was negligent and careless in: a. failing to observe the fire tread on the road in time to avoid a collision; b. failing to have his vehicle under control. c. swerving into the other lane when it was not safe to do so. 7. As a result of the negligence and carelessness of the defendant, the vehicle owned by Mr. Gutheinz sustained damage in the amount of $7, 031.43 and he incurred rental expense of $252.84. 8. The plaintiff's insurance policy provided coverage for the loss and has made payment to its insured, Paul Gutheinz. WHEREFORE, the plaintiff demands judgment against the defendant in the amount of $7,284.27, plus interest and costs of suit, an amount with the jurisdiction of arbitration under the local rules of court. William ddams Attorney for the Plaintiff VERIFICATION Paul Gutheinz 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. Date Paul Gutheinz C,I) ALE r"'r Or THE 2099 fi UG 280 ki ICS: a li CU",._ /?l? d7?r9J(s Sheriffs Office of Cumberland County R Thomas Kline FILEa v RCE Sheriff i trru,l,?r OF THE PROTHONOTARY Ronny R Anderson Chief Deputy 2009 SEP -8 AM 10: 3 S Jody S Smith Civil Process Sergeant F ?5t ?i f?? it ;.;O NTY PEMSYNAW Edward L Schorpp Solicitor Geico a/s/o Paul Gutheinz I Case Number vs. 2009-5908 Janakkuma Patel SHERIFF'S RETURN OF SERVICE 08/28/2009 On this date R. Thomas Kline, Sheriff mailed the within complaint and notice by certified mail, return receipt requested to Janakkuma Patel a/k/a Jay Patel. 08/31/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he served the within Writ of Summons upon the within named defendant, Janakkuma Patel a/k/a Jay Patel, in the following manner: On August 28, 2009 the Sheriff mailed by certified mail, return receipt requested a true and correct copy of the within Complaint and Notice to the defendant's last known address of 324 Pegasus Road Piscataway, NJ 08854. The certified mail return receipt card was received by the Cumberland County Sheriff's Office signed by an adult in charge on August 31, 2009. SHERIFF COST: $33.54 September 03, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: JANAKKUMA PATEL a/k/a JAY PATEL 324 PEGASUS ROAD PISCATAWAY, NJ 08854 A Signature X ? Agent ? Addressee B. Received by (Anted Name) I ?e / )` ;q of all D. Is delivery d item 1? ? Yes If YES, ter live low: ? No Z 3. Service Type'-;-- M Certified Mail ? Express Mail ? Registered ? Return Receipt for Merchandise am-510? ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Number (transfer from service fabeq 7004 1350 0003 7145 8206 now" Ps Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 --- toss WILLIAM A. ADDAMS ATTY. I.D. # 06265 43 W. South St. P.O. BOX 261 CARLISLE, PA. 17013 717-243-7638 GEICO ASO/Paul Gutheinz IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNY, PENNA. Plaintiff VS. CIVIL ACTION LAW JANAKKUMA PATEL No. 2009-5908 Defendant To: Curt Long, Prothonotary PRAECIPE Sir: Please mark this action discontinued without prejudice. William A. A ams, Esquire Attorney for Plaintiff 43 W. South St. Carlisle, PA 17013 717-243-7638 Dated: October 28, 2009 Elf EG-CIF, #CJE C} T F PP'-'!TH ''l IO ARY 2009 OCT 28 M I *. 4 6