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HomeMy WebLinkAbout10-3379FLED ;? T [ ^= 201011 'i'1' 2 0 Fi'i 2: 16 METZGER, WICKERSHAM, P.C. By: Michael J. Boone, Esquire Attorney I.D. No. 208925 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 CU1M-1 ji'?Ty Attorney for Plaintiffs Derek E. Stum and Valerie Stum DEREK E. STUM and VALERIE STUM, his wife, Plaintiffs vs. HUEY STANLEY, JR, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10 - ZW9 0-t V i Ier m CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO DEFEND TO: Defendant Huey Stanley, Jr. 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 Plaintiffs. 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. Mid Penn Legal Services 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 *qa. P4 AT" CV-1 'S-au a I P,4 aya4ol(o 441300-1 AVISO USTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion dentro de veinte (20) dias a partir de la fecha en que recibio la demanda y el aviso. Usted debe presentar comparecencia esrita en persona o po abogado y presentar en la Corte por escrito sus defensas o sus objeciones a las demandas en su contra. Se le avisa que si no se defiende, el caso puede proceder sin usted y la Corte puede decidir en su contra sin mas aviso o notificacion por cualquier dinero reclamado en la demanda o por cualquier dinero reclamado en la demanda o po cualquier otra queja o compensacion reclamados por el Demandante. USTED PUEDE PERDER DINERO, O PROPIEDADES U OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI USTED NO TIENE O NO CONOCE UN ABODAGO, VAYA O LLAME A LA OFICINA EN LA DIRECCION ESCRITA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Mid Penn Legal Services 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 441140 -1 METZGER, WICKERSHAM, P.C. By: Michael J. Boone, Esquire Attorney I.D. No. 208925 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiffs Derek E. Stum and Valerie Stum DEREK E. STUM and VALERIE STUM, his wife, Plaintiffs vs. HUEY STANLEY, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW JURY TRIAL DEMANDED COMPLAINT AND NOW, comes the Plaintiffs, Derek E. Stum and Valerie Stum, by and through their attorneys, Metzger, Wickersham, Knauss & Erb, and respectfully represent the following: FACTS APPLICABLE TO ALL COUNTS 1. Plaintiffs Derek E. Stum and Valerie Stum, husband and wife are adult individuals who reside at 31 Summer Lane, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant Huey Stanley, Jr. is an adult individual residing at 404 Bently Drive, Martinsburg, Berkeley County, West Virginia. 3. The facts and circumstances hereinafter set forth occurred on May 25, 2009 on Interstate 81 South, Silver Spring Township, Cumberland County, Pennsylvania. 4. At the aforesaid time and place, Plaintiff Derek E. Stum was the operator of a 2007 Dodge Grand Caravan bearing Pennsylvania License Plate No. FPS 1477. 5. At the aforesaid time and place, Defendant Huey Stanley, Jr. was the operator of a 2007 Chevrolet Silverado bearing West Virginia License Plate Number 9LS221. 44/300-/ 6. At the aforesaid time and place, Plaintiff Derek E. Stum was traveling southbound on Interstate 81 and proceeded to slow down to pull over onto the right shoulder of the highway in order to assist a stranded motorist. 7. At the aforesaid time and place, Defendant was also traveling southbound on Interstate 81 behind the vehicle being operated by Plaintiff. 8. At the aforesaid time and date, Defendant failed to slow the vehicle he was operating and hit the rear of the vehicle being operated by Plaintiff. 9. Following the collision between the vehicles, Defendant fled the scene of the accident and was eventually apprehended by the Silver Spring Township police. COUNTI Plaintiff Derek E. Stum v. Defendant Huey Stanley, Jr. 10. Paragraphs 1 through 9 of Plaintiffs' complaint are incorporated herein by reference as if fully set forth. 11. Defendant owed a duty to Plaintiff and other lawful users of the roadways in the Commonwealth of Pennsylvania to operate the vehicle he was driving in such a way as not to cause harm or damage to said other persons and to the Plaintiff in particular. 12. The aforesaid collision was the direct and proximate result of the negligence of the Defendant Huey Stanley, Jr. in operating his vehicle in a careless and negligent manner as follows: (a) Failing to observe Plaintiff's vehicle on the roadway; (b) Following too closely to Plaintiff's vehicle in violation of 75 Pa.C.S.A. §3310 and applicable law; (c) Failing to slow or stop the vehicle he was operating so as to avoid a rear-end collision; 441300-1 (d) Failing to maintain and stop the vehicle he was operating within the assured clear distance ahead in violation of 75 Pa.C.S.A. §3361 and applicable law; (e) Failing to apply the brakes to the vehicle he was operating or take other evasive action to avoid the collision with the rear of Plaintiff's vehicle; (f) Failing to maintain adequate control of the vehicle he was operating in order to avoid a collision; (g) Failing to give warning to Plaintiff of his impending collision with his vehicle; (h) Operating his vehicle in careless disregard for the safety of persons and/or property in violation of 75 Pa.C.S.A. §3714 and applicable law; (i) Failing to keep his vehicle under proper and adequate control so as not to expose other users to an unreasonable risk of harm; (j) Operating his vehicle too fast for the conditions existing at the aforesaid time and place in violation of 75 Pa.C.S.A. §3361 and applicable law; (k) Failing to keep alert and maintain a proper lookout for the presence of other motor vehicles on the streets and highways; (1) Exceeding the applicable maximum speed limit in violation of 75 Pa.C.S.A. §3362 and applicable law; (m) In operating the vehicle so as to create a dangerous situation for other vehicles on the roadway; (n) Failing to maintain a safe following distance; (o) Failing to observe slowing traffic; (p) Rear-ending Plaintiff's vehicle; (q) Failing to stay alert to traffic patterns; (r) Not rendering aid at the scene; 441300-1 (s) Failing to keep his eyes on the roadway; and (t) Otherwise operating his vehicle at an unsafe speed. 13. As a direct and proximate result of the collision and the negligent and careless conduct of Defendant, Plaintiff sustained and in the future may sustain, serious and debilitating injuries, some of which are or may be permanent, an aggravation and/or exacerbation of pre- existing conditions, and which include, but are not limited to, the following: (a) Cervical spine strain/sprain; (b) Thoracic spine strain/sprain; (c) Lumbar spine strain/sprain; (d) Neck pain; (e) Mid back pain; (f) Low back pain; (g) Muscle spasms; (h) Headaches; 14. As a direct and proximate result of the aforesaid collision, negligence and carelessness of Defendant, Plaintiff has undergone and in the future will undergo physical pain, mental anguish, discomfort, inconvenience, distress, embarrassment and humiliation, past, present and future loss of his ability to enjoy the pleasures of life and limitations in his pursuit of daily activities all to his great loss and detriment. 15. As a direct and proximate result of the aforesaid collision, negligence and 441300-1 carelessness of Defendant, Plaintiff has and/or may in the future incur expenses for medical treatment, surgery and rehabilitation for which damages are claimed. 16. As a direct and proximate result of the aforesaid collision, negligence and carelessness of Defendant, Plaintiff has suffered and will continue to suffer a loss of earnings for which damages are claimed. 17. As a direct and proximate result of the aforesaid collision, negligence, carelessness and recklessness of Defendant, Plaintiff has and/or may in the future incur a loss of earning capacity, loss of household services and other economic damages for which damages are claimed. 18. As a direct and proximate result of the aforesaid collision and the negligence and carelessness of Defendant, Plaintiff sustained incidental costs and losses to include, but not limited to, past and future medication costs and medical appliances. 19. Plaintiff was the named insured on a policy of insurance issued to him by Nationwide Insurance bearing the policy number 58 37 D 578511 05252009 01 which was in effect on the date of the above referenced collision. Plaintiff selected the full tort option regarding that policy. A copy of the declaration page of said policy is attached hereto and incorporated by reference herein as Exhibit "A". Therefore, Plaintiff remains eligible to claim compensation for non economic loss and economic loss sustained in this collision pursuant to the applicable tort law. WHEREFORE, Plaintiff demand judgment in his favor and against the Defendant for the aforesaid damages in an amount in excess of the limits of compulsory arbitration in Cumberland County, Pennsylvania plus interest and/or damages for delay and costs for prosecution. 44!300-/ COUNT II Plaintiff Valerie Stum v. Defendant Huey Stanley, Jr. 20. Paragraphs 1 through 19 of Plaintiffs' complaint are incorporated herein by reference as if fully set forth. 21. During all relevant times Plaintiffs Derek E. Stum and Valerie Stum, were husband and wife, and solely as a result of the collision, the aforesaid negligence and carelessness of Defendant, Huey Stanley, Jr. and as a result of the injuries to Plaintiff Derek E. Stum, the Plaintiff Valerie Stum has been deprived of the assistance, companionship, consortium and society of her husband and has lost his services to her which may continue indefinitely. WHEREFORE, Plaintiff Valerie Stum demands judgment in her favor and against the Defendant Huey Stanley, Jr., for the aforesaid damages in an amount in excess of the limits of compulsory arbitration in Cumberland County, Pennsylvania plus interest and/or damages for delay and costs for prosecution. METZGER, CKERSHAM, KNAUSS & ERB, P.C. By Micha J. Boone, Esquire I.D. No. 208925 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Date: May '7, 2010 Attorney for Plaintiffs 441300-1 VERIFICATION I, Derek E. Stum, hereby certify that the following is correct: The facts set forth in the foregoing Complaint are based upon information which I have furnished to counsel, as well as upon information which has been gathered by counsel and/or others acting on my behalf in this matter. The language of the Complaint is that of counsel and not my own. I have read the Complaint, and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the content of the Complaint is that of counsel, I have relied upon such counsel in making this Verification. I hereby acknowledge that the facts set forth in the aforesaid Complaint are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities. Dated: s - i a - % o J!!) a-'? % t: Derek E. Stum 441140 -1 VERIFICATION I, Valerie Stum, hereby certify that the following is correct: The facts set forth in the foregoing Complaint are based upon information which I have furnished to counsel, as well as upon information which has been gathered by counsel and/or others acting on my behalf in this matter. The language of the Complaint is that of counsel and not my own. I have read the Complaint, and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the content of the Complaint is that of counsel, I have relied upon such counsel in making this Verification. I hereby acknowledge that the facts set forth in the aforesaid Complaint are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Dated: --5/13//o 00"-'A'S Valerie Stum 441140 -1 CERTIFICATE OF SERVICE I, Michael J. Boone, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb, P.C., hereby certify that I served a true and correct copy of Plaintiff's Complaint with reference to the foregoing action by first class mail, postage prepaid, this _ day of , 2010, on the following: BY CERTIFIED MAIL Defendant Huey Stanley, Jr. 404 Bently Drive Martinsburg, WV 25401 '?' ",' Q(2 Mich el J. Boone, Esquire 441300-1 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL r0VFR RHFFT vr. -amm yr JUUR.IHL KtGUKUS USt UNLY PLAINTIFFS' NAME DEFENDANT'S NAME DEREK E. STUM and VALERIE STUM HUEY STANLEY, JR. PLAINTIFF'S ADDRESS DEFENDANTS ADDRESS 31 Summer Lane, Mechanicsburg, PA 17050 404 Bently Drive, Martinsburg, WV 25401 PLAINTIFF'S NAME DEFENDANTS NAME PLAINTIFF'S ADDRESS DEFENDANT'S ADDRESS PLAINTIFF'S NAME DEFENDANT'S NAME PLAINTIFF'S ADDRESS DEFENDANT'S ADDRESS TOTAL NUMBER OF PLAINTIFFS TOTAL NUMBER OF DEFENDANTS COMMENCEMENT OF ACTION 2 1 Complaint efition Action Notice of Appeal Writ of Summons Transfer from other'urisdictions COURTPROGRAMS AMOUNT IN CONTROVERSY Arbitration Jury Non-Jury Petition Minor Court Appeal Statutory Appeals In Ex ' dictional Amount? Other Yes No CASE TYPE AND CODE (SEE INSTRUCTIONS NGL/MVA STATUTORY FOR CAUSE OF ACTION (SEE INSTRUCTIONS) REMARKS: TO THE CLERK OF JUDICIAL RECORDS Please enter my appearance on behalf of Plaintiff Papers may be served at the address set forth below NAME OF PLAINTIFF'S ATTORNEY OR PRO SE PLAINTIFF ADDRESS Michael J. Boone, Esquire METZGER WICKERSHAM KNAUSS & ERB, P.C. P O BOX 5300, HARRISBURG, PA 17110-0300 PHONE NUMBER FAX NUMBER 717 238-8187 717 234-9428 SUPREME COURT IDENTIFICATION NO. E-MAIL ADDRESS 208925 mjb@mwke.com SIGNATURE DATE 402655-1 ,~ 2010 Jul ! 7 Phi 3~ G CUf~~r.~ _ ;~~)tr1~ i Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEREK E. STUM and VALERIE STUM, CIVIL DIVISION his wife, Plaintiffs, NO. 10-3379 v. PRAECIPE FOR APPEARANCE HUEY STANLEY, JR., (Jury Trial Demanded) Defendant. Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, P.C. Firm #911 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 (717) 901-5916 #17924 v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEREK E. STUM and VALERIE STUM, his wife, Plaintiffs, CIVIL DIVISION NO. 10-3379 v. HUEY STANLEY, JR., Defendant. (Jury Trial Demanded) PRAECIPE FOR APPEARANCE TO: THE PROTHONOTARY Kindly enter the Appearance of the undersigned, Kevin D. Rauch, Esquire, of the law firm of Summers, McDonnell, Hudock, Guthrie & Skeel, P.C., on behalf of the Defendant, Huey Stanley, Jr., in the above case. JURY TRIAL DEMANDED Respectfully submitted, SUMMERS, McDONNEL HUDOCK, GUTHRIE ~ ~KEE~. P.~ By: n D. Rauch, Esquire ~sel for Defendant J - CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing PRAECIPE FOR APPEARNCE has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this 16th day of June, 2010. Michael J. Boone, Esquire Metzger Wickersham 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (Attorney for Plaintiffs) SUMMERS, McDONNELL, GUTHRIE & SUCE~I,. P.C. , By: vines. Rau ,Esquire unsel for efendants METZGER, WICKERSHAM, P.C. By: Michael J. Boone, Esquire Attorney I.D. No. 208925 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 ~., ._ TF-'~ o1p~ a AUG ll phl 3 ~ 3$ ,. ~ ~,. Attorney for ~f~ Derek E. Stum ands Valene'Stum DEREK E. STUM and VALERIE STUM, his wife, . Plaintiffs vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2010-CV-3379-CV CIVIL ACTION -LAW HUEY STANLEY, JR., Defendant JURY TRIAL DEMANDED PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint that was filed in the above-captioned action on May 20, 2010, a copy of which is attached hereto. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By: ,°r Michael J. oone, Esquire Attorney I.D. No. 208925 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Dated: ~kJ,,,t- i ~j"" d o i ~ Attorneys for Plaintiffs 449593 O ~l0•0o P~ A`fT'1 ~* t5N`1a~ Q~ aN(o[n(o0 y..a ..d . .~~p 0~~TAt~Y METZGER, WICKERSHAM, P.C. (~~ '[4-l~ ~''• ' ~' By: Michael J. Boone, Esquire 4; 0~ Attorney I.D. No. 208925 ~~ $EP '8 ~'~ 3211 North Front Street P.O. Box 5300 CUMV Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiffs Derek E. Stum and Valerie Stum DEREK E. STUM and VALERIE STUM, his wife, Plaintiffs vs. IN THE COURT OF COMMON YL~AS ur CUMBERLAND COUNTY, PENNSYLVANIA N0.2010-CV-3379-CV CIVIL ACTION -LAW HUEY STANLEY, JR., Defendant JURY TRIAL DEMANDED PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint that was filed in the above-captioned action on May 20, 2010, a copy of which is attached hereto. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By: Michael J. Boone, Esquire Attorney I.D. No. 208925 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Dated: S r~~:..~v ~ a' ` " Attorneys for Plaintiffs 449593 /0 / ©Q ~°~ ~~.~5~~~ ~"'` ~~i9~~' ,~., ~-C~1= FICA ~; ~~sQ S'r~ ~ I ~~~ 2~ f ~ G°' COJ''T'" i r-~ :IC`s 11n ~GI ~ METZGER, WICKERSHAM, P.C. By: Andrew W. Norfleet, Esquire Attorney I.D. No. 83894 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 DEREK E. STUM and VALERIE STUM, his wife, Plaintiffs vs. Attorney for Plaintiffs Derek E. Stum and Valerie Stum IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010-CV-3379-CV CIVIL ACTION -LAW HUEY STANLEY, JR., Defendant .iURY TRIAL DEMANDED SUBSTITUTION OF COUNSEL WITHOUT LEAVE OF COURT IRUL,E 1012(b)(2)(ii)1 PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of the Plaintiff, Derek Stum, in the above- captioned Action. I hereby certify that this change is not intended to, nor will it, delay this proceeding to the best of my knowledge, information and belief. Papers may be served at the address set forth below. as~~ao Date: ~~G/ ~~~ METZGER, WICKERSHAM, P.C. By: Andrew . Norfle ~r Attorney ID No.: 83894 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110 Telephone: (717) 238-8187 Fax: (717)234-9478 451821-] PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw my appearance on behalf of Plaintiff, Derek Stum. Michael J. Boone, Esquire Attorney ID No.: 208925 METZGER, WICKERSHAM, P.C. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110 Telephone: (717) 238-8187 Fax: (717) 234-9478 Date: N~ 1 ~ (1~ .:. 451488-1 451488-1 CERTIFICATE OF SERVICE I, Andrew W. Norfleet, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb, P.C., hereby certify that I served a true and correct copy of a Substitution of Counsel Without Leave of Court with reference to the foregoing action by first class mail, postage prepaid, thispZO day of ~ , 2010 on the following: VIA FIRST CLASS MAIL Defendant Huey Stanley, Jr. c/o Kevin D. Rauch, Esquire SUMMERS, MCDONNELL, HUDOCK, GUTHRIE AND SKEEL, P.C. 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. C Andrew W. Norfleet, Es uire 451488-1451488-1 METZGER, WICKERSHAM, P.C. By: Andrew W. Norfleet, Esquire Attorney I.D. No. 83894 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717} 238-8187 y Q~ ~ r~ 201 0 ~~ --~ ~ ~~~ ~,: 55 ~U~~~, ~.~g~g~.~`1 ~~~~~,~ money for Plaintiffs tJ ' ~ 1'~erek E. Stum and Valerie Stum DEREK E. STUM and VALERIE STUM, IN THE COURT OF COMMON PLEAS OF his wife, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs vs. HUEY STANLEY, JR., Defendant N0.2010-CV-3379-CV CIVIL ACTION -LAW JURY TRIAL DEMANDED PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint that was filed in the above-captioned action on May 20, 2010, reinstated on August 11, 2010 and reinstated again on September 8, 2010 a copy of which is attached hereto. METZGE I /~ ERB, P.C. f By: Andrew W. Norfleet, Esquire Attorney I.D. No. 83894 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717} 238-8187 Dated: l V ~~~0 Attorneys for Plaintiffs 449593 ,Nr ^~'\ ~~ ~~ ~~ ~~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~aiti~~tx uf' ~~titabr~f~~~ Jody S Smith Chief Deputy ~ ~' Richard W Stewart Solicitor c~F~~c~ --'~~~=~~-=~~~~= Derek E. Stum vs. Huey Stanley, Jr. Case Number 2010-3379 SHERIFF'S RETURN OF SERVICE 09/10/2010 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: Huey Stanley Jr., but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of York County, PA to serve the within Complaint and Notice according to law. 09/29/2010 York County Return: And now, September 29, 2010 I, Richard P. Keuerleber, Sheriff of York County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Huey Stanley Jr. the defendant named in the within Complaint and Notice and that I am unable to find her in the County of York and therefore return same NOT FOUND. Current resident of 186 Cherry Lane, Dillsburg, PA 17019 is the defendant's Aunt. She advised Deputies, Huey Stanley Jr. is thought to be residing in West Virginia. SHERIFF COST: $37.00 October 22, 2010 SO ANSWERS, "'..-° RON R ANDERSON, SHERIFF '~ ~ ~ ~ ; ~ --- ~ o ~ ~ ~ `-+ ~ `~ ~ cy~ ~~ , , ~_~ ~~ ' -``' ~;- ~~ .r- (ci CountySuite Sheriff. Telecsoft. h?c. SHERIFF'S OFFICE OF YORK COUNTY Y Richard P Keuerleber PETER J. MANGAN, ESQ. Sheriff Solicitor ,.,, Reuben B Zeager Richard E Rice, II Chief Deputy, Operations Chief Deputy, Administration DEREK E. STUM vs. Case Number HUEY STANLEY, JR. 10-3379 CIVIL SHERIFF'S RETURN OF SERVICE 09/29/2010 I, RICHARD P KEUERLEBER, SHERIFF, WHO BEING DULY SWORN ACCORDING TO LAW, STATES HE MADE DILIGENT SEARCH AND INQUIRY FOR THE WITHIN NAMED DEFENDANT TO WIT: HUEY STANLEY, JR., BUT WAS UNABLE TO LOCATE THE DEFENDANT IN HIS BAILIWICK. THE SHERIFF THEREFORE RETURNS THE WITHIN REQUESTED COMPLAINT IN CIVIL ACTION (CICA) AS "NOT FOUND" AT 186 CHERRY LANE, DILLSBURG, PA 17019. PER DEF AUNT WHO STATED THAT THE DEF LIVES IN WEST VIRGINIA AT AN UNKNOWN ADDRESS. SHERIFF COST: $40.94 SO SWE , October 20, 2010 RICHA D P K ERLEB ERIFF NOTARY Affirmed and subscribed to before me this 20th OCTOBER 2010 ///// C~%//~ n1~.;J~(~ ~r,?t1!'1. ~~~(lrCi:~Jf' 3l: / JU day of COMMONWV@ALfi QF F'~NaNIA NOTARIAL SEAL LISA L. THORP~, Nt~7ARY RUBL!C CITY OP YORK. YORK CQL'NTY MY COP.th?'^S51pN EX~~P,ES AUG. ' 2. 2013 METZGER, WICKERSHAM, P.C. By: Andrew W. Norfleet, Esquire .Attorney I.D. No. 83894 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 DEREK E. STUM and VALERIE q. his wife, Plaintiffs vs. HUEY STANLEY, JR., Defendant J v vlrlyrivt' 1. Ll..i 0 Vl' CUMBERLAND OUNTY, PENNSYLVANIA NO.2010-CV-337 -CV CIVIL ACTION - LAW JURY TRIAL DEMANDED T TO THE PROTHONOTARY: Please reinstate the Complaint that was filed in the above-captioned action on May 20, 2010, reinstated on August 11, 2010 and reinstated on September 8, 201 , and reinstated again on October 5, 2010 a copy of which is attached hereto. MET By: ? Dated: ? I ?\4 ? U, 449593 F OF THE 4 F? Attbrn y ford P(i fs Derek i Stum and Valerie Stum Andrew W. Norfleet, Esquire Attorney I.D. No. 83894 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiffs AUSS & ERB, P.C. METZGER, WICKERSHAM, P.C. By: Andrew W. Norfleet, Esquire Attorney I.D. No. 83894 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 :DEREK E. STUM and VALERIE STUM, his wife, Plaintiffs VS. HUEY STANLEY, JR., Defendant : TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010-CV-339-CV CIVIL ACTION LAW JURY TRIAL Please reinstate the Complaint that was filed in the actionon May 20, 2010, reinstated on August 11, 2010 and reinstated on September 8, 2010, and reinstated again on October 5, 2010 a copy of which is attached hereto. METZGER, WI Dated: // " /'a By: ?- Andrew W. Norfl?et, Esquire Attorney I.D. No. 83894 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiffs Attorn for Plaintiffs Derek y Stum and Valerie Stum USS & ERP, P.C. 449593 METZGER, WICKERSHAM, P.C. By: Andrew W. Norfleet, Esquire Attorney I.D. No. 83894 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 OF T11EP ROTh,,nNOTA q, 2"J" 0 DEC -3 AM B: 0 7 CUMBERLAND COUNTY PEN"YLVANIA Attorney for Plaintiffs Derek E. Stum and Valerie Stum DEREK E. STUM and VALERIE STUM, his wife, Plaintiffs vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010-CV-3379-CV CIVIL ACTION - LAW HUEY STANLEY, JR., Defendant JURY TRIAL DEMANDED PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint that was filed in the above-captioned action on May 20, 2010, reinstated on August 11, 2010 and reinstated on September 8, 2010, reinstated on October 5, 2010 and reinstated again on November 4, 2010, a copy of which is attached hereto. METZGER, W S AUSS & ERB, P.C. By: Andrew W. Norfleet, squire Attorney I.D. No. 83894 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Dated: IL Attorneys for Plaintiffs 449593 ?# o W77 METZGER, WICKERSHAM, P.C. By: Andrew W. Norfleet, Esquire Attorney I.D. No. 83894 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 _ r I ILL n t w{ 1 dE7 a i( FED 25 Phi 0 I, ; 11 Ill-, CN C 4§, for Plaintiffs Derek E. Stum and Valerie Stum DEREK E. STUM and VALERIE STUM, IN THE COURT OF COMMON PLEAS OF his wife, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs vs. HUEY STANLEY, JR., Defendant NO. 2010-CV-3379-CV CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint that was filed in the above-captioned action on May 20, 2010, reinstated on August 11, 2010, reinstated on September 8, 2010, reinstated on October 5, 2010, reinstated on November 4, 2010, and reinstated again on December 3, 2010 a copy of which is attached hereto. , KNAUSS & ERB, P.C. MET=Nosquire By: AndAttorney I.D. No. 83894 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 r (717) 238-8187 Dated: ZS 1/ Attorneys for Plaintiffs 449593 ak+ q 1Q.60 F 'Q1 afty " 9557 tog