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Home My WebLink About10-29782069267 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 ' 484/351-0500 Attorney for Plaintiff R T T, WESTFIELD INSURANCE CO., COURT OF COMMON PLEAS ','- -`--, Individually and as Subrogee CUMBERLAND COUNTY -c? on behalf of Donna and Harry { Arnold ' 201 East Oregon Road w Lancaster PA 17604 and Donna and Harry Arnold, indiv. and as h/w 406 Brickchurch Road Enola, PA 17025 VS. DOCKET NO. : 1p - AQg8 0-AV" I (ew MATTHEW A. LONGWELL 126 VALLEY VIEW DRIVE MECHANICSBURG PA 17050 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 JUDGEMENT 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, 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 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 Qs 32 S. BEDFORD STREET 4Qa.00 PD ATrY CARLISLE, PA 17013 (717) 249-3166 12p*1188(0(0 # lq l5Yo(p COMPLAINT IN CIVIL ACTION 1. Donna and Harry Arnold (the "Plaintiffs"), are adult individuals residing at the address above captioned. 2. Plaintiff, WESTFIELD INSURANCE CO., is a corporation duly authorized to conduct business within the Commonwealth of Pennsylvania, and is subrogated to the rights of the Plaintiff arising out of the within claim. 3. MATTHEW A. LONGWELL, (the "Defendant"), is an individual residing at the above-captioned address. 4. On or about May 8, 2008, the Plaintiff did own and possess a certain motor vehicle, involved in the accident hereinafter referred to. 5. On or about May 8, 2008, the Defendant did operate and control a certain motor vehicle, involved in the accident hereinafter referred to. 6. On or about May 8, 2008,the vehicle of the defendant was being operated in such a negligent and careless manner that it came into violent: contact with the plaintiff's vehicle causing property damage to the Plaintiff's motor vehicle. 7. At the time and place aforesaid, the negligence and carelessness of the Defendant consisted of the following: a. Operating said vehicle at a high and excessive rate of speed under the circumstances; b. Failing to give proper and sufficient warning of the approach of said vehicle; C. Failing to have said vehicle under proper and adequate control at the time; d. Operating said motor vehicle without due regard for the rights, safety and position of the Plaintiff herein at the point aforesaid; e. Failing to sound a horn or other signaling device as to give warning to the plaintiff; f. Violating the rules and regulations of the road, ordinances of the County of CUMBERLAND, and the statutes of the Commonwealth of Pennsylvania; and g. Operating said vehicle without observing and heeding the road and traffic conditions then and there existing. 8. As a result of Defendant's negligent and careless operating of the motor vehicle, the plaintiff's motor vehicle sustained damages in the amount of $6,912.18. 9. At all times material hereto the plaintiff was insured by plaintiff, WESTFIELD INSURANCE CO.. 10. As a further result of the defendants' negligence, WESTFIELD INSURANCE CO. has made compensation for said property loss to the plaintiff. 11. Plaintiff WESTFIELD INSURANCE CO. individually and as subrogee on behalf of the plaintiff, Westfield Insurance Co. indiv. has paid money to the plaintiff for property damage in the amount of $6,912.18 for which plaintiff demands remuneration from the defendant. e. WHEREFORE, Plaintiff, WESTFIELD INSURANCE CO., claims damages from the Defendant, in the amount of $6,912.18, and/or any other damages this Honorable Court deems just and proper, including attorney's fees and court costs from the Defendant, for arbitration purposes only. GORDON & WEINBERG, P.C. BY: G, ESQUIRE FREDERIC I. VK,UIRE JOEL M. FLI Attorney foiffs P01d 2069267 FREDERIC I. WEINBERG, ESQUIRE, hereby states that he is the attorney for the Plaintiff(s) in this action and verifies that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned. understands that the statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. FREDERIC I. (?EIN RG, ESQUIRE SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor ~Q~ti~+ts of ~u~r~ficr~i~d~ ~, - ..y; C:~FF:CE ~F -mac F6RIFF ,-~ ,r ? 1_t ~. ~ 7 r~-- r, ~Y ~ .... "J Z~1~ iii r ~~ h~i $~ rJ~I Ci.)f~ t. .t ~~.~"dTY Westfield Insurance Co. Case Number vs. Matthew A. Longwell 2010-2978 SHERIFF'S RETURN OF SERVICE 05/18/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Matthew A. Longwell, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Matthew A. Longwell. William Foltz, current homeowner of 126 Valley View Drive, Mechanicsburg, PA 17050 advised Deputies, Matthew A. Longwell is currently incarcerated at SCI Mercer 801 Butler Pike, Mercer, PA 16137. SHERIFF COST: $42.00 SO ANSWERS, May 18, 2010 RON R ANDERSON, SHERIFF ~ci CauntySuite Sheriff. Teleosoft. h7C. 2069267 r, C_ GORDON. & WEINBERG, P.C. Mco BY: FREDERIC I . WEINBERG, ESQUIRE ;r-m M identification No. : 41360 � Ci JOEL M. FLINK, ESQUIRE —' Identification No. : 41200 '� 1001 E. Hector Street, Ste 220 =c-- s;k. Conshohocken, PA 19428 � �Y Donna and Harry Arnold COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. DOCKET NO. 2010-2978 MATTHEW A. LONGWELL PRAECIPE TO WITHDRAW COMPLAINT TO THE PROTHONOTARY: Kindly withdraw the above-captioned action, without prejudice. GORDON & WEINBERG, P. C. BY: FREDERIC I . WEINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P006 CERTIFICATION OF SERVICE I, FREDERIC I . WEINBERG, ESQUIRE, hereby certify that I, on .the date. below, served a copy of the Praecipe to Withdraw Complaint to Pa.R.C. P. 1028 (c) (1) , via First Class Mail, postage pre-paid, . to all other parties or their counsel of record. FREDERIC I. WEINBERG, ESQUIRE Dated �/