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Home My WebLink About09-8073WILLIAM A. ADDAMS ATTY. I.D. # 06265 43 W. South St. P.O. BOX 261 CARLISLE, PA. 17013 717-243-7638 Andrew Pisano and Elaine Pisano: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNY, PENNA. Plaintiff VS. CIVIL ACTION LAW Marlee Blose No. Ow i C Defendant 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 717-240-6200 William A. Ad ams Attorney for Plaintiff COMPLAINT AND NOW, comes the Plaintiff, Andrew and Elaine Pisano by their attorney, William A. Addams, and files the following complaint. 1. The plaintiffs are Andrew and Elaine Pisano, adult individuals residing in Falllston, Maryland 21047. 2. The defendant is Marlee Blose,an adult individual residing at 103 North Second St., Landisburg, Perry County, PA 17040. 3. The plaintiffs are the joint owners of a 2005 Acura MDX which on April 22, 2009, Elaine Pisano was driving North on Route 114 and was stopped in a left turn lane, waiting to turn left onto Pleasant Grove Road in Silver Spring Township. 4. At said time, the defendant, Marlee Blose, was driving a vehicle a Toyota 4-Runner, also traveling North on Route 114 when she negligently and carelessly collided with the plaintiff's vehicle causing the damages hereinafter set forth. 5. The defendant was negligent and careless in: a. traveling too fast for conditions. b. failing to observe the plaintiff's vehicle in time to avoid a collision. c. failing to have her vehicle under control. 6. As a result of the negligence and carelessness of the defendant, the plaintiff's vehicle sustained damage in the amount of $11,940.82 and they incurred rental expense of $1,454.70. WHEREFORE, the plaintiffs demand judgment against the defendant in the amount of $13,395.52, plus interest and costs of suit, an amount with the jurisdiction of arbitration under the local rules of court. William A. A ams Attorney for the Plaintiff VERIFICATION I, William A. Addams, verifies that the facts set forth in the Answer are true and correct to the best of my knowledge and/or information and belief. I understand that false statements are subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. William A. A dams Date: //- /L 65?9 s FILE JrF.GE qtr .1-;FE p, T'Jn`,?` 1 My 200° N0, 20 P#I I : 03 t „_, SD ;?I- "I e? 3sY3 ??a3 a8? WILLIAM A. ADDAMS ATTY. I.D. # 06265 43 West .South St. CARLISLE, PA. 17013 717-243-7638 ._.. -.._. ~`f 2~~~i~;.'.` -4 ~'z i~~ u j -.'; _ ____ Andrew Pisano and Elaine Pisano: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNY, PENNA. Plaintiff VS. CIVIL ACTION LAW Marlee Blose No. ~ ~ " ~U ~ 3 ~ ~' ; ~ Defendant JURY TRIAL DEMANDED PREACIPE SIR; Please enter a default judgment in the amount of $13,395.52 in favor of the Plaintiffs for failure to enter an appearance or file an answer to the complaint endorsed with a notice to defend. The undersigned hereby certifies that the attached written notice of the intention to file this Praecipe was mailed to the Defendant on the date shown thereon, which was after the default occurred and at least ten days prior to the filing of this Praecipe. May 3, 2010 6G William A. Addams Attorney for Plaintiff 43 W. South St. Carlisle, PA 17013 717-243-7638 ~ ~ 36a~ ~-~ ~yISY~ /~yfte .t1a./~~C 1NILLIAM A. ADDAMS ATTY. LD. # 06265 43 West .South St. CARLISLE, PA. 17013 717-243-7638 Andrew Pisano and Elaine Pisano: IN THE COURT OF COMMON PLEAS OF CUMBER LAND COUNY, PENNA. Plaintiff VS. CIVIL ACTION LAW 2009-8073 Marlee Blose No. Defendant JURY TRIAL DEMANDED TO: Marlee Blose 103 North Second Street Apartment B Newport, PA 17074 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET HELP. LAWYER REFERRAL SERVICE YORK COUNTY COURT HOUSE 137 E. MARKET ST. YORK PA 17401 717-854-8755 William A. Addams Attorney for Plaintiff 43 W. South St. Carlisle, PA 17013 717-243-7638 April 20, 2010