The URL can be used to link to this page

Home My WebLink About04-2490LAWRENCE CHEVROLET, INC., Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. C?q , 0;? `/(f o C ; I- i / %u+ r JESSE A. WOODROW, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO DEFEND TO: Jesse A. Woodrow 116 Peach Lane Carlisle, PA 17013 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. 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 Bar Association 32 S. Bedford Street Carlisle, PA 17013 717-249-3166 Steven D. Snyder, Esquire Supreme Court I.D. #34344 Hawke McKeon Sniscak & Kennard LLP 100 North Tenth Street PO Box 1778 Harrisburg, PA 17105-1778 717-236-1300 Dated: June 2, 2004 LAWRENCE CHEVROLET, INC., V. JESSE A. WOODROW, Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. O It - d- 441 o c, %V rr/ 2 v M CIVIL ACTION - LAW JURY TRIAL DEMANDED COMPLAINT AND NOW, comes the Plaintiff, Lawrence Chevrolet, Inc., by its attorneys, Hawke McKeon Sniscak & Kennard LLP, and in support of its complaint avers as follows: 1. The Plaintiff, Lawrence Chevrolet, Inc., is a Pennsylvania corporation with its principal place of business at 6445 Carlisle Pike, Mechanicsburg, Pennsylvania, Cumberland County, Pennsylvania, 17050. 2. The Defendant, Jesse A. Woodrow, is an adult individual, residing at 116 Peach Lane, Carlisle, Cumberland County, Pennsylvania, 17013. 3. The facts and events referred to herein occurred on or about June 81 2002, at approximately 2:00 a.m. 4. At the above-referenced date and time, the Defendant was driving a 2000 Mitsubishi Eclipse GS westbound on East Trindle Road near the intersection of East Trindle Road and South Sheeley Lane in Cumberland County, Pennsylvania. 5. The car being operated by the Defendant at the above stated date and time was owned by the Plaintiff and was being used by the Defendant without permission. 6. At the above-stated date and time, the Defendant lost control of the car he was driving while turning from East Trindle Road onto Sheeley Lane and the car collided with a utility pole located on South Sheeley Lane, resulting in damages to the Plaintiffs car, as set forth hereinafter. 7. The collision was caused by the carelessness and negligence of the Defendant, which negligence consisted of the following: (a) he failed to maintain control over the vehicle he was driving; (b) he failed to keep a proper lookout for other traffic on the highway; (c) he operated his vehicle carelessly and recklessly; (d) he failed to obey the traffic laws and statutes of the Commonwealth of Pennsylvania; (e) he did not operate the vehicle he was driving in a reasonable manner; (f) he failed to stay in his lane of traffic; and (g) he was otherwise negligent under the circumstances. 8. As a result of the Defendant's negligence and carelessness as aforesaid, the Plaintiff s car was damaged to such a degree that it was a total loss, resulting in total damages to the Plaintiff in the amount of $12,375.00. 2 WHEREFORE, the Plaintiff demands judgment in its favor and against the Defendant in the amount of $12,375.00, plus costs, interest, and such other relief as the Court deems necessary and proper. Hawke McKeon SSniisscak & Kennard LLP BY: *Steve ?) _Snyder U Supreme Court Attorney I.D. #34344 Hawke McKeon Sniscak & Kennard LLP 100 North Tenth Street PO Box 1778 Harrisburg, Pennsylvania 17105-1778 (717) 236-1300 Attorneys for Plaintiff Lawrence Chevrolet, Inc. DATED; June 2, 2004 3 VERIFICATION I verify that the statements made in the foregoing complaint which are within the personal knowledge of the undersigned, are true and correct, and as to the facts based on the information of others, the undersigned, after diligent inquiry, believes it to be true. And further, I signed this Verification on the recommendation of our attorneys, who advised me that the allegations and language in this document are required legally to raise issues for resolution at trial, by the Court, or by continuing investigation and preparation for trial. I understand that some of these allegations may prove inappropriate after investigation and trial preparation are complete, and I leave determination of these matters to our attorneys on their advice. I understand that all statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unworn falsification to authorities. Lawrence Chevrolet AIWA-- y: Robert Blocher, General Manager By' Date: 616'4 V J Z" G 0 U? cl) lJ ll? ?i C f.a SHERIFF'S RETURN - NOT FOUND CASE NO: 2004-02490 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LAWRENCE CHEVROLET INC VS WOODROW JESSE A R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT WOODROW JESSE A but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE NOT FOUND , as to the within named DEFENDANT WOODROW JESSE A 116 PEACH LANE CARLISLE, PA 17013 DEFENDANT MOVED OUT 3 WEEKS AGO. NO FORWARDING ADDRESS LE AT POST OFFICE Sheriff's Costs: Docketing 18.00 Service 4.14 Not Found 5.00 Surcharge 10.00 .00 37.14( So ff of Cumberland County LAWRENCE CHEVROLET 06/30/2004 Sworn and subscribed to before me this 7 " day of d,00A. D. A 04 P roth i otary SHERIFF'S RETURN - REGULAR CASE NO: 2004-02496 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BENDER RUTH ET AL VS WOOD DONALD SR SHAWN HARRISON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, says, the within COMPLAINT - EJECTMENT was served upon the DEFENDANT at 1824:00 HOURS, on the 24th day of June 2004 at 700 HIGH STREET WEST FAIRVIEW, PA 17025 by handing to BARB WOOD, WIFE a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.35 Affidavit .00 Surcharge 10.00 .00 38.35 Sworn and Subscribed to before me this 76 day of ,2 A.D. i rothonotary who being duly sworn according to law, So Answers: R. Thomas Kline 06/28/2004 CHARLES PETRIE c By: ey Sheriff Renee K. Simpson Deputy Prothonotary Curtis R. Long prothonotary cc of -rotbouotarP c?fft ?h Curaberlaub COMO John E. Slike Solicitor CIVIL TERM ORDER OF TERMINATION OF COURT CASES ILING NOTICE OF STx DAY OF NOVEMBER 2007 AFTER NS THE ABOVE AND NOW THIS RECEIVING NO RESPONSE - CE WITH PA AND WITH PREJUDICE IN ACCORDANCE INTENTION TO YTERMINATED CASE IS HEREB R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY Pennsylvania 17013 (71?) 2`x'6195 • Fax (717 240'6573 n.,p Courthouse Square • Carlisle,