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Home My WebLink About01-0153DOUGLAS, DOUGLAS & DOUGLAS 27 W. HIGH ST. POB 261 CARLISLE PA 17013 TELEPHONE 717-243-1790 JOHN W. DUTREY and BARBARA L. DUTREY, 336 Wilson Street, Carlisle, PA 17013, VS JAIME REYNA JUAREZ, 246 Walnut Street, Carlisle, PA 17013, X WILLIAM P. DOUGLAS, ESQ. Supreme Court I.D.# 37926 GEORGE F. DOUGLAS, HI, F~Q. Supreme Court I.D.# 61886 IN THE COURT OF COMMON PLEAS CF CUMBERLAND COUNTY PENNSYLVN,~A PLAINTIFF 2001 - ~ CIVILTEF~I CIVIL ACT]ON LAW DEFENDANT To: Curtis R. Long, Prothonotary PRAECIPE Please issue a writ of summons in a civil action against the within-named defendant, Jaime Reyna Juarez. Date: January 9, 2001 DOUGLAS, DOUGI~S & DOUGLAS Commonwealth of Pennsylvania County of Cumberland JOHN W. DUTREYAND BARBARA L. DUTREY, 336 Wilson Street Carlisle, PA 17013 JAIME REYNAJUAREZ 246 Walnut Street, Carlisle, PA 17013 Court of Conzmon Plea~ No ..... 9! _- _~9_3_ _ _c _~y~ _~ _ _~_e_~ ............ l~ .... ~n ..... c- ~YAt- - Ac-t- ~9A -: - -zP-- -~- .................. You are hereby notified that ...... g_°_~_ ~'_ _ ~_c~e_y_ _a~ q_ ~ _ee_ a__~_a_ _~_ _'_ _~ c_ ~e_~. ............................................... the Plaintiff haS commenced an action in .___C_i_¥il___A_c_t_~_o_rl__-__~l__h/ ............................... against you which you are required to defend or a default judgment may be entered against you. (SEAL) Prothonotary SHERIFF'S CASE NO: 2001-00153 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DUTREY JOHN W ET AL VS JUAREZ JAIME REYNA RETURN - REGULAR ROBERT L. FINK Cumberland County, Pennsylvania, says, the within WRIT OF SUMMONS JUAREZ JAIME REYNA DEFENDANT , at 0020:00 HOURS, at 246 WALNUT STREET CARLISLE, PA 17013 J~MIE JAUREZ a true and attested copy of WRIT OF SUMMONS Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 16th day of January by handing to 2001 together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.10 Affidavit .00 Surcharge 10.00 .00 31,10 Sworn and Subscribed to before me this ~y ~' day of t F~rothonotary So Answers: R. Thomas Kline 01/16/200 DOUGLAS & DOUGLAS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOHN W. DUTREY, DUTREY and BARBARA Plaintiffs JAIME REYNA JUAREZ, Defendant NO. 01-153 PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Dennis E. Reinaker of the Law Firm of Eager, Reinaker & Spinello as attorney of record on behalf of Defendant in the above captioned action. EAGER, REINAKER & SPINELLO D ire Attorney for Defendant I.D. No. 25971 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Praecipe for Entry of Appearance upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: William P. Douglas, Esquire Douglas, Douglas & Douglas 27 West High Street Carlisle, PA 17013 EAGER, REINAKER & SPINELLO quire ATtorney for Defendant I.D. No. 25971 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOHN W. DUTREY, DUTREY and BARBARA Plaintiffs Vo JAIME REYNA JUAREZ, Defendant NO. 01-153 PRAECIPE FOR RULE TO FILE COMPLAINT TO: Curtis R. Long, Prothonotary, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387 Please enter a Rule upon the Plaintiff to file a Complaint in the above captioned matter within twenty (20) days of the Rule or suffer a judgment of non pros. EAGER, REINAKER & SPINELLO De~~er,~Squlre\ At6orney for Defendant I.D. No. 25971 1347 Fruitville Pike Lancaster, PA 17601 {717) 290-7971 AND NOW, this~day of 3~ , 2001, has been entered upon the Plaintiff as ~ove directed. Prothonotary ~ a Rule CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Praecipe for a Rule to File a Complaint upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: William P. Douglas, Esquire Douglas, Douglas & Douglas 27 West High Street Carlisle, PA 17013 EAGER, REINAKER & SPINELLO uire A~rney for Defendant I.D. No. 25971 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 EAGER, REINAKER, & SPINELLO ATTORNEYS AT LAW 1347 FR~ LANCASTER, PENNSYLVANIA 17601 PHONE (717) 290-7971 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNS'fLVANIA CIVIL ACTION I,AW JOHN W. DUTREY, DUTREY and BARBARA Plaintiffs JAIME REYNA JUAREZ~ Defendant NO. 01-153 CERTiFiCATE OF SERVICE I HEREBY CERTIFY that I have this day served a true s~nd correct copy of Defendanu's Request for Production and Copying of Documents - Set No. 1 Directed to Plaintiffs upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: William P. Douglas, Esquire Douglas, Douglas & Douglas 27 West High Snreet Carlisle, PA 17013 EAGER, REINAKER & SPINELLO E. Reir~aker Esquire A[torney for Defendan% I~D. No· 25971 1347 Frumtvil!e Pike Lancaster, PA 17601 (717) 290-7971 IEAGER, REINAKER, & SPINEl_LO ^TT~O~_kF~ ^T LAW 1347 FRUITVILLE PiKE LANCASTER, PENNSYLVANIA 17601 PHONE (717) 290-7971 IN THE COURT OF COHHON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW JOHN W. DUTREY, DGTNEY and BARBARA Plaintiffs JAIME REYNA JUAREZ, Defendant ' '5t NO. 01 ~ - CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have ~:n].s day served an oriqina! of InEerrogatories t s o~ Defendan~ Addressed to Plaintiffs upol the persor'~ se~ forth below and in the manner indicated: First class mail, postage pre pa~d: William P. Douglas, Esquire Douglas, Douglas & Douglas 27 West High Street Carlisle, PA 17013 ~EAGER, REINAKER & SPiNELLO Dennis E. Reinaker, Nsauire Attorney for Defendant I.D. No. 25971 1347 Fruitvi!le Pike Lancaster, PA 17601 {717} 290 7971 JOHN W. DUTREY"AND BARBARA L. DUTREY, PLAINTIFFS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. 2001 -153 CIVIL TERM JAIME REYNA JUAREZ, DEFENDANt.T_..; NOTICE 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 (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. Legal Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 Dated: DOUGLAS, DOUGLAS & DOUGLAS Attorney for Plaintiffs ~ COMPLAINT 2. 3. 4. The plaintiff, Barbara L. Dutrey, is an adult individual residing at 336 Wilson Street, Carlisle, Cumberland County, Pennsylvania. The plaintiff, John W. Dutrey, is an adult individual residing at 336 Wilson Street, Carlisle, Cumberland County, Pennsylvania. The Defendant, Jaime Reyna Juarez, is an adult individual residing at 246 Walnut Street, Carlisle, Cumberland County, Pennsylvania. On or about February 23, 1999, the plaintiff, Barbara L. Dutrey, was operating her motor vehicle in a westerly direction on West High Street in the vicinity of Wilson Street. At or about the same time and place, the defendant was operating his motor vehicle in a westerly direction on West High Street. As plaintiff, Barbara L. Dutrey, attempted to make a left-hand turn onto Wilson Street, the back of her vehicle struck by the vehicle operated by the defendant. The accident in question was caused solely by the negligence of the defendant. The defendant was negligent in the following respects: (a) failure to drive within the assured clear distance ahead; (b) failure to maintain a proper lookout; (c) failure to operate the vehicle in a careful and prudent mantlet. 10. Count 1 - Barbara L. Dutrey v laime Reyna Juarez Paragraph numbers 1 through 7 are incorporated herein and reference is made there to. As a direct and proximate result of the accident, Barbara L. Dutrey was injured. Those injuries include, but are not limited to, injury to her shoulder and neck. As a direct and proximate result of the accident, Barbara L. Dutrey has incurred medical expenses in the past and may continue to do so into the future. 11. 12. As a direct and proximate result of the negligence of the defendant, Barbara L. Dutrey has suffered and may continue to suffer in the future, pain, aggravation and inconvenience, loss of life's pleasures, loss of wages, and her economic horizons may be limited. The plaintiff has incurred and may continue to incur expenses to assist her in her day-to-day living. WHEREFORE, it is prayed that judgment be entered in favor of the plaintiff, Barbara L. Dutrey, and against the defendant in an amount in excess of that requiring compulsory referral to arbitration. A jury trial is hereby demanded. Count 2 - John W. Dutrey v Iaime Reyna Juarez 13. The allegations of paragraphs 1 through 12 are incorporated herein and reference is made thereto. 14. At all times pertinent hereto, plaintiff, John W. Dutrey, was and is the husband of plaintiff, Barbara L. Dutrey. 15. As a direct and proximate result of the injuries suffered by his wife, the plaintiff, John W. Dutrey hereby claims a loss of consortium as a result of her injuries, in that, said injuries have had a detrimental and substantial impact upon the marriage of the parties. WHEREFORE, it is prayed that judgment be entered in favor of the plaintiff, John W. Dutrey, and against the defendant in an amount in excess of that requiring compulsory referral to arbitration. A jury trial is hereby demanded. DOUGLAS, DOUGLAS & DOUGLAS William P. Douglas, ~squire Attorney for Plaintiffs 27 West High'~gtreet Carlisle, PA 17013 717-243-1790 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. VERIFICATION I verify that the statements made in the foregoing document are true and correct, to the best of my 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, CIVIL ACTION - LAW JOHN W. DUTREY, DUTREY and BARBARA Plaintiffs JAIME REYNA JUAREZ, Defendant AND NOW COMES DEFENDANT, PENNSYLVANIA NO. 01-153 ANSWER BY AND THROUGH HIS ATTORNEY, DENNIS E. REINAKER, AND FILES THE FOLLOWING ANSWER: 1.- 2. Denied in accordance with Pennsylvania Rules of Civil Procedure 1029(e). 3. Admitted. 4. Denied in accordance with Pennsylvania Rules of Civil Procedure 1029(e) . 5. Admitted. 6.- 7. Denied in accordance with Pennsylvania Rules of Civil Procedure 1029(e). WHEREFORE, Defendant asks that judgment be entered in his favor and against the Plaintiffs on all claims set forth in Plaintiffs' Complaint. COUNT I Barbara L. Dutrey v. Jaime Reyna Juarez 8. Paragraphs 1 through 7 inclusive above are incorporated herein by reference and made a part hereof, 9.- 12. Denied in accordance with Pennsylvania Rules of Civil Procedure 1029(e). WHEREFORE, Defendant asks that judgment be entered in his favor and against the Plaintiffs' Complaint. John W. Plaintiffs on all claims set forth in COUNT II Dutrey v. Jaime Reyna Juarez 13, Paragraphs 1 through 12 inclusive above are incorporated herein by reference and made a part hereof. 14.- 15. Denied in accordance with Pennsylvania Rules of Civil Procedure 1029(e). WHEREFORE, Defendant asks that judgment be entered in his favor and against the Plaintiffs on all claims set forth in Plaintiffs' Complaint. EAGER, REINAKER & SPINELLO uire ~%~torney for Defendant I.D. No. 25971 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Answer upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: William P. Douglas, Esquire Douglas, Douglas & Douglas 27 West High Street Carlisle, PA 17013 EAGER, REINAKER & SPINELLO uire A%to~ney for Defendant I.D. No. 25971 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 John W. Dutrey and Barbara Lynne Dutrey h/w In The Court of Common Pleas of Cumberland County, Pennsylvania VS Jaime Reyna Juarez Plaintiffs c~ No. 01-- 153 Defendants >. Civil Action -- Law Praecipe to Settle and Discontinue Dear Mr. Long: Please mark the above captioned matter settled and discontinued with prejudice. March 13, 2002 William ~ Douglas Attorney fo~..~laintiffs