HomeMy WebLinkAbout09-8418HAGELGANS & VERONIS
Nicholas A. Veronis, Esquire
Identification No.: 46523
223 N. Duke Street
Lancaster, PA 17602
Telephone: (717) 295-7009 Attorney for Plaintiffs
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
MAURA A. and
BRIAN C. FRY,
1755 Milton Grove Road .-
Mount Joy, PA 17552 OQ ` $4l$ w?l I ertn
Plaintiffs
VS. Civil Action No.: CI-09-
PENSKE TRUCK LEASING CO., L.P.,
and
LIT INDUSTRIAL, LTD.
Defendants . 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 with 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(s). You may lose money or property or other rights that are 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. 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 Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone No.: (717) 249-3166 or 1-800-990-9108
BY:
Date: /,z-'3 -0-'
HAG G S & VE NIS
?o
N h las A. Veronis
Attorney for Plaintiffs
Attorney I.D. No.: 46523
223 North Duke Street
Lancaster, PA 17602
Telephone: (717) 295-7009
HAGELGANS & VERONIS
Nicholas A. Veronis, Esquire
Identification No.: 46523
223 North Duke Street
Lancaster, PA 17602
Telephone: (717) 295-7009 Attorney for Plaintiffs
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
MAURA A. and
BRIAN C. FRY, .
1755 Milton Grove Road
Mount Joy, PA 17552 .
Plaintiffs
VS. Civil Action No.: CI-09-
PENSKE TRUCK LEASING CO., L.P.,
and
LIT INDUSTRIAL, LTD.
Defendants JURY TRIAL DEMANDED
COMPLAINT
1. Plaintiffs, Maura A. and Brian C. Fry, (hereinafter referred to as "Plaintiffs Fry"),
are adult individuals and husband and wife residing at 1755 Milton Grove Road, Mount Joy,
Pennsylvania 17552.
2. Defendant, Penske Truck Leasing Co., L.P., (hereinafter referred to as "Defendant
Penske") is a corporation believed to be incorporated in the Commonwealth of Pennsylvania
with a principal place of business located at 6 Logistics Drive, Carlisle, Cumberland County,
Pennsylvania 17013.
3. Defendant, LIT Industrial Ltd., (hereinafter referred to as "Defendant LIT"), is a
Delaware partnership with a principal place of business located at 3141 Hood Street, Suite 700,
Dallas, Texas 75219.
4. On or about August 5, 2008, Plaintiff, Brian C. Fry, was working in his capacity
as a self-employed tractor-trailer driver and was assigned by Defendant Penske to pick up a
loaded trailer at 6 Logistics Drive in Carlisle, Pennsylvania 17013 (hereinafter referred to as the
"subject property").
5. At the foregoing time and place, Plaintiffs believe and therefore aver that the
subject property was leased and/or under the supervision and control of Defendant Penske and/or
owned by Defendant, LIT.
6. Plaintiff, Brian C. Fry, was picking up a load at night in an area where he was
instructed to hook up his tractor to a trailer on a designated concrete landing pad made available
by Defendant Penske.
7. At the foregoing time and place, Plaintiff Fry, while hooking up his tractor-trailer,
walked several feet off of the landing pad to go around his truck and stepped into a hole which
was close to the concrete landing pad causing him to injure his left leg and knee.
8. At the foregoing time and place, when Plaintiff Fry stepped into the hole, the area
was very poorly lit and there was no way Plaintiff could discern that there was a dangerous and
unreasonable condition on the "subject property" controlled by Defendant Penske and/or owned
by Defendant, LIT.
9. As a result of the unreasonably dangerous condition maintained by Defendants on
the subject property located at 6 Logistics Drive, Carlisle, Pennsylvania, Plaintiff Fry sustained
serious injury to his left leg and knee.
10. At all times relevant hereto, Defendants, Penske and LIT, Ltd., had actual and/or
constructive notice of the hole on the subject property and took no actions to remove or correct
the unreasonably dangerous condition on the "subject property" despite knowing that
independent truckers such as Plaintiff Fry would walk and work on the "subject property".
2
11. At all times relevant hereto Plaintiff Fry was a "business invitee" of Defendants
and was permitted to go on the "subject property" to hook up his tractor with said trailers.
PLAINTIFFS, MAURA A. AND BRUN_C. FRY vs.
DEFENDANT, PENSKE TRUCK LEASING CO., L.P.
NEGLIGENCE
12. Paragraphs 1 through 11 of Plaintiffs' Complaint are incorporated by reference as
though set forth in their entirety herein.
13. Defendant Penske was negligent, careless, and reckless in causing the accident
sustained by Plaintiff Fry on August 5, 2008 in one or more of the following particulars:
(a) In creating and allowing an unreasonably dangerous condition including a
hole to exist in an area in close proximity to the landing pad when it knew
truckers such as Plaintiff Fry would be using said area to hook up their
tractors to trailers;
(b) In failing to regard the rights, safety, and position of the Plaintiff in and
about an area in which Defendant knew truckers such as Plaintiff Fry
would be using to hook up their trailers;
(c) In permitting an unreasonably dangerous condition to exist on or about
Defendant's premises where the Defendant knew or should have known
that persons would be subject to walking in said hole and sustaining
injury;
(d) In failing to inspect, maintain, and/or repair holes on property which was
under Defendant's control and/or ownership so as to permit a dangerous
condition to exist which could subject truckers including Plaintiff Fry to
injury;
3
(e) In failing to properly illuminate and provide adequate lighting in the area
of the foregoing accident;
(f) In failing to fill in and/or remove holes in the area of the foregoing
accident in a reasonable, adequate, and prudent manner;
(g) In failing to issue adequate warnings either, verbal or written, to persons
such as Plaintiff Fry who would likely encounter the dangerous condition
in hooking up his tractor to trailers;
(h) In permitting and allowing business invitees, like Plaintiff Fry, to walk
and ambulate in and about the area of the "subject accident" when said
Defendant knew or should have known of the dangerous condition on its
property;
(i) In failing to post adequate warning signs, warning cones, illumination
warnings, barriers, and/or some type of barricade in an effort to alert
persons including Plaintiff Fry of the dangerous condition that existed on
the "subject property";
0) In failing to utilize reasonable care in the inspection, maintenance, and/or
repair of the premises;
(k) In failing to request, institute, and/or supervise periodic inspections of the
"subject property" so as to discover conditions that would be dangerous to
persons such as Plaintiff Fry who were using the property with
Defendant's permission;
(1) In failing to utilize reasonable care in the inspection, maintenance, and/or
repair of the hole in the area where Plaintiff fell;
(m) In failing to request, institute, and/or supervise periodic inspections of the
lighting in the area where Plaintiff fell;
4
(n) In failing to keep reasonable, adequate, and organized maintenance,
inspection and/or logs of the condition of the area where Plaintiff fell; and
(o) In failing to place proper lighting in the area of the landing pad where
Plaintiff fell so Plaintiff could have seen the hole which he fell in.
14. The accident and injuries hereinafter set forth were caused solely by the
negligence of Defendant, Penske, and were in no way due to any act or failure to act on the part
of Plaintiff Fry, who was merely carrying out his job duties as an independent trucker in an area
designated by Defendant that was poorly lit and in an area which had an unreasonably dangerous
condition unknown to Plaintiff Fry.
15. At all times relevant hereto, Plaintiff Fry was a business invitee of Defendant and
as such was entitled to all rights afforded by business invitees under Pennsylvania law.
16. As a direct and proximate result of the foregoing negligence of Defendant Penske,
Plaintiff, Brian C. Fry, sustained personal injuries to his left leg and knee, including but not
limited to the following:
(a) Injury to his left knee including damage to the cartilage, ligaments, bones,
and muscles of his left knee resulting in the need for three separate
surgeries performed on November 7, 2008, March 6, 2009, and June 8,
2009;
(b) A permanent partial impairment and disability to his left knee as a result
of his three surgeries which may result in the need for a future knee
replacement;
(c) Permanent scarring and disfigurement to his left knee from the three
surgeries;
(d) Injuries to the muscles, bones, ligaments, tendons, and nerves of his left
knee; and
5
(e) Various abrasions and contusions.
17. As a direct and proximate result of the foregoing accident and resulting injuries,
Plaintiff Fry, has suffered and will continue to suffer pain, discomfort, humiliation,
inconvenience, loss of enjoyment of life, permanent scarring and disfigurement, and a permanent
partial impairment and disability, for all of which excess damages are claimed.
18. As a direct and proximate result of the foregoing accident and resulting injuries,
Plaintiff Fry has incurred medical and hospital bills in excess of $40,000.00 and may in the
future incur additional medical expenses which are deemed recoverable under Pennsylvania law
and for all of which excess damages are claimed.
19. As a direct and proximate result of the foregoing accident and resulting injuries,
Plaintiff Fry, has incurred lost wages since the accident in excess of $71,224.40, has suffered a
loss of earning capacity and may in the future continue to suffer financial losses which may be
deemed recoverable under Pennsylvania law and for all of which excess damages are claimed.
20. Plaintiff Fry avers that his injuries and damages exceed the applicable limits of
arbitration; therefore, a jury trial is hereby demanded.
WHEREFORE, Plaintiffs, Maura A. and Brian C. Fry, demand judgment in their favor
and against Defendant, Penske Truck Leasing Co., L.P., for an amount in excess of Fifty
Thousand ($50,000.00) Dollars together with interest and costs as allowed by law.
COUNT II
PLAINTIFFS, MAURA A. AND BRIAN C. FRY, vs.
DEFENDANT, LIT INDUSTRIAL, LTD.
NEGLIGENCE
21. Paragraphs 1 through 20 of Plaintiffs' Complaint are incorporated by reference as
though set forth in their entirety herein.
6
22. Defendant LIT was negligent, careless, and reckless in causing the accident
sustained by Plaintiff Fry on August 5, 2008 in one or more of the following particulars:
(a) In allowing an unreasonably dangerous condition including a hole to exist
on its property in an area in close proximity to the landing pad when it
knew truckers such as Plaintiff Fry would be using said area to hook up
their tractor-trailers;
(b) In failing to regard the rights, safety, and position of the Plaintiff in and
about an area in which Defendant knew truckers such as Plaintiff Fry
would be using to hook up their tractor trailers;
(c) In permitting an unreasonably dangerous condition to exist on or about
Defendant's property where the Defendant knew or should have known
that persons would be subject to falling and sustaining injury
(d) In failing to inspect, maintain, and/or repair holes on property under
Defendant's control and/or ownership so as to permit a dangerous
condition to exist which could subject truckers including Plaintiff Fry to
injury;
(e) In failing to properly illuminate the area of the foregoing accident in a
reasonable, adequate, and prudent manner;
(f) In failing to fill in and/or remove holes on Defendant's property in the
area of the foregoing accident in a reasonable, adequate, and prudent
manner;
(g) In failing to issue adequate warnings, verbal, and/or written, to persons
such as Plaintiff Fry who would likely encounter the dangerous condition
including the subject hole which Plaintiff stepped into;
7
(h) In permitting and allowing business invitees, like Plaintiff Fry, to walk
and ambulate in and about the area of Plaintiff's foregoing accident when
Defendant knew or should have known of the dangerous condition of the
hole that existed on Defendant's property;
(i) In failing to post adequate warning signs, warning cones, illumination
warnings, barriers, and/or some type of barricade in an effort to alert
persons including Plaintiff Fry of the dangerous condition that existed on
said Defendant's property;
0) In failing to utilize reasonable care in the inspection, maintenance, and/or
repair of the "subject property;
(k) In failing to request, institute, and/or supervise periodic inspections of the
premises in question so as to discover holes that would be dangerous to
persons such as Plaintiff Fry who were using the property with
Defendant's permission;
(1) In failing to utilize reasonable care in the inspection, maintenance, and/or
repair of the hole in the area where Plaintiff fell;
(m) In failing to request, institute, and/or supervise periodic inspections of the
lighting in the area where Plaintiff fell;
(n) In failing to keep reasonable, adequate, and organized maintenance,
inspection and/or logs of the condition of the area where Plaintiff fell; and
(o) In failing to place proper lighting in the area of the landing pad where
Plaintiff fell so Plaintiff could have seen the hole which he fell in.
8
23. The accident and injuries hereinafter set forth were caused solely by the
negligence of Defendant, LIT, and were in no way due to any act or failure to act on the part of
Plaintiff Fry, who was merely carrying out his job duties in an area that was poorly lit and in an
area which had an unreasonably dangerous condition unknown to Plaintiff Fry.
24. At all times relevant hereto, Plaintiff Fry was a business invitee of Defendant and
as such was entitled to all rights afforded by business invitees under Pennsylvania law.
25. As a direct and proximate result of the foregoing negligence of Defendant LIT,
Plaintiff, Brian C. Fry, sustained personal injuries including but not limited to the following:
(a) Injury to his left knee including damage to the cartilage, ligaments, bones,
and muscles of his left knee resulting in the need for three separate surgeries performed on
November 7, 2008, March 6, 2009, and June 8, 2009;
(b) A permanent partial impairment and disability to his left knee as a result
of his three surgeries which may result in the need for a future knee
replacement;
(c) Permanent scarring and disfigurement to his left knee from the three
surgeries;
(d) Injuries to the muscles, bones, ligaments, tendons, and nerves of his left
knee; and
(e) Various abrasions and contusions.
26. As a direct and proximate result of the foregoing accident and resulting injuries,
Plaintiff Fry, has suffered and will continue to suffer pain, discomfort, humiliation,
inconvenience, loss of enjoyment of life, permanent scarring and disfigurement, and a permanent
partial impairment and disability, for all of which excess damages are claimed.
9
27. As a direct and proximate result of the foregoing accident and resulting injuries,
Plaintiff Fry has incurred medical and hospital bills in excess of $40,000.00 and may in the
future incur additional medical expenses which are deemed recoverable under Pennsylvania law
and for all of which excess damages are claimed.
28. As a direct and proximate result of the foregoing accident and resulting injuries,
Plaintiff Fry, has incurred lost wages since the accident in excess of $71,224.40, has suffered a
loss of earning capacity and may in the future continue to suffer financial losses which may be
deemed recoverable under Pennsylvania law and for all of which excess damages are claimed.
29. Plaintiff Fry avers that his injuries and damages exceed the applicable limits of
arbitration; therefore, a jury trial is hereby demanded.
WHEREFORE, Plaintiffs, Maura A. and Brian C. Fry, demand judgment in their favor
and against Defendant, LIT Industrial, Ltd., for an amount in excess of Fifty Thousand
($50,000.00) Dollars together with interest and costs as allowed by law.
COUNT III
PLAINTIFF, MAURA A. FRY, vs. DEFENDANTS,
PENSKE TRUCK LEASING CO., L.P. AND LIT INDUSTRIAL, LTD.
LOSS OF CONSORTIUM
30. Paragraphs 1 through 29 of Plaintiffs' Complaint are incorporated by reference as
though set forth in their entirety herein.
31. At the time of the foregoing accident, Plaintiffs, Brian C. and Maura A. Fry, were
married and living together.
32. As a result of the negligence of Defendants, Penske Truck Leasing Co., L.P. and
LIT Industrial, Ltd., as set forth in Count I and II, Plaintiff, Maura A. Fry has lost the services,
companionship, society, and consortium of her husband, for all of which damages are claimed.
to
WHEREFORE, Plaintiff, Maura A. Fry, demands judgment in her favor and against
Defendants, Penske Truck Leasing Co., L.P. and LIT Industrial, Ltd., for an amount in excess of
Fifty Thousand ($50,000.00) Dollars together with interest and costs as allowed by law.
HAGELGANS & VERONIS
Date: _ 12--3-0 By:
Nicho as A. Veronis
Attorney for Plaintiffs
Attorney I.D. No. 46523
223 North Duke Street
Lancaster, PA 17602
Telephone: (717) 295-7009
II
VERIFICATION
We, Maura A. and Brian C. Fry, verify that the facts set forth in the foregoing Complaint
are true and correct to the best of our knowledge, information and belief. We understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
DATED: /; " I " D 'T
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HAGELGANS & VERONIS
Nicholas A. Veronis, Esquire
Attorney I.D.#: 46523
223 North Duke Street
Lancaster, PA 17602
Telephone: (717) 295-7009 Attorney for Plaintiffs
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION -LAW
MAURA A. and
BRIAN C. FRY,
Plaintiffs ~~~~
vs. Civil Action No.: CV-09-~4~9-
PENSKE TRUCK LEASING CO., L.P.,
and
LIT INDUSTRIAL, LTD.
Defendants JURY TRIAL DEMANDED
NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 237.1(a)(2)
TO: LIT INDUSTRIAL, LTD.
2650 Cedar Springs Road, Suite 850
Dallas, TX 75201-1494
IMPORTANT NOTICE
You are in default because you have failed to enter a written appearance personally or by
attorney and file in writing with the Court your defenses or objections to the claims set forth against
you. Unless you act within ten days from the date of this notice, a judgment maybe entered against
you without a hearing and you may lose your property or other important rights.
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 maybe 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 South Bedford Street
Carlisle, PA 17013
Telephone: 717-249-3166
Date: ~2 ! g I d
HAGE AN VERONIS
By: ~~ro
Nic o s A. Veronis, Esquire
Attorney I.D. No. 46523
223 North Duke Street
Lancaster, PA 17602
Telephone: (717) 295-7009
Facsimile: (717) 396-9746
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on this date, a true and correct copy of the foregoing
Notice of Praecipe to Enter Judgment by Default Pursuant to Pennsylvania Rule of Civil Procedure
237.1(a)(2) was served by mailing, first class mail, postage prepaid, to the following:
LIT Industrial, Ltd.
2650 Cedar Springs Road, Suite 850
Dallas, TX 75201-1494
HAGELGANS & VERONIS
By:
Nicho s A. Veronis, Esquire
Attorney for Plaintiffs
I.D. No.:46523
223 North Duke Street
Lancaster, PA 17602
Telephone: (717) 295-7009
Facsimile: (717) 396-9746
Date: ~ ~ 9-l~
WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP
Michael S. Takacs, Esquire Attorneys for Defendant
Identification No. 78409 LIT Industrial, Ltd.
Nicole Perez, Equire
Identification No. 207450
The Curtis Center, Suite 1130 East
Independence Square West
Philadelphia, PA 19106
215 627 6900
MAURA A. and BRIAN C. FRY, COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
~' Plaintiffs
~~ vs. CNIL ACTION -LAW
n _~
c°
PENSKE TRUCK LEASING CO., L.P., NO. 09-8418 <<~ ~ ~
~_;~
' and ~ nfr-~ ` =~ r--
LIT INDUSTRIAL, LTD. ~~~? `~ ~ -`'~'
Defendants _... `
~-~c,~ C7 Jr
dt •~-3
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
V l
Kindly enter our appearance on behalf of Defendant, LIT Industrial, Ltd., in the above-captioned
matter.
WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP
By: ~w-~ S~Q
Michael S. Takacs, Esquire
Nicole Perez, Esquire
Attorneys for Defendant
LIT Industrial, Ltd.
Date: March 3, 2010
411415.1
CERTIFICATE OF SERVICE
I, Michael S. Takacs, Esquire, attorney for Defendant, LIT Industrial, Ltd., hereby certify that I
have served a true and correct copy of the foregoing Entry of Appearance to the attorneys listed herein via
United States Mail, First Class, Postage Prepaid, on the date referenced below.
Nicholas A. Veronis, Esquire
Hagelgans &Veronis, LLP
223 North Duke Street
Lancaster, PA 17602
Attorney for Plaintiffs
Christopher M. Reeser, Esquire
Marshall Dennehey Warner Coleman & Goggin
4200 Crums Mill Road Suite B
Harrisburg, PA 17112
By: ~~ S (°~
Michael S. Takacs, Esquire
Date: March ~' , 2010
411415.1
OF THE PROTHONoTAR
Y
2010 DEC -7 AM 11: 16
OUMBERLAND COUNTY
PENNSYLVANIA
HAGELGANS & VERONIS
Nicholas A. Veronis, Esquire
Attorney I.D.#: 46523
223 North Duke Street
Lancaster, PA 17602
Telephone: (717) 295-7009 Attorney for Plaintiffs
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
MAURA A. and
BRIAN C. FRY,
Plaintiffs
VS. Civil Action No.: CV-09-8418
PENSKE TRUCK LEASING CO., L.P.,
and
LIT INDUSTRIAL, LTD.
Defendants JURY TRIAL DEMANDED
PRAECIPE TO DISCONTINUE
TO THE PROTHONOTARY:
Please mark the above matter settled, ended, discontinued
Nichoas A. Veronis
Attorney for Plaintiff
DISCONTINUANCE CERTIFICATE
AND NOW, this day of,] 2010, this suit has been marked as above directed.
Pr onotary
l
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on this date, a true and correct copy of the foregoing
Praecipe to Discontinue was served by mailing, first class mail, postage prepaid, to the following:
William D. Kennedy, Esquire
White & Williams
1235 Westlakes Drive, Suite 310
Berwin, PA 19312
Christopher M. Reeser, Esquire
Marshall, Dennehey, Warner, Coleman & Goggin
4200 Crums Mill Road, Suite B
Harrisburg, PA 17112
Curtis N. Stambaugh, Esquire
McNees, Wallace & Nurick
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108-1166
Wayne A. Graver, Esquire
Labin, O'Neil, Ricci, Cedrone & DiSipio
Suite 500, 190 North Independence Mall West
6`h and Race Streets
Philadelphia, PA 19106
HAGELGANS & VERONIS
By: / 1 2z ? LA 69- -; I ?
Nic 1 A. Veronis, Esquire
Attorney for Plaintiffs
I.D. No.:46523
223 North Duke Street
Lancaster, PA 17602
Telephone: (717) 295-7009
Facsimile: (717) 396-9746
Date: /'2 - 1 0