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Home My WebLink About04-2928IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GENERAL CASUALTY INSURANCE COMPANY, a/s/o JAIN H. LIN, Plaintiff, PRAMINE RODNEY RISHER, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED TO: Pramine Rodney Risher 460 Sumner Road Carlisle, Pennsylvania 17013 NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the foregoing 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 OR KNOW A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE 'IHE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County BarAssociation 2LibertyAvenue Carlisle, Pennsylvania 17013 (800) 990-9108 GRIFFITH~ By:SO~ Chablo41 *RICKLER, ~ERMAN, S & CALK1NS I ' ~uire Attorney for Plaintiff Supreme Court I.D. #36208 110 South Northern Way York, Pennsylvania 17402 Telephone: (717) 757-7602 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 escrita en persona o por 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 defienda, 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 otto 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 INMEDIATEMENTE. SI USTED NO TIENE O NO CONOCE UN ABOGADO, VAYA O LLAME A LA OFICINA EN LA DIRECCION ESCRITA ABA JO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GENERAL CASUALTY INSURANCE COMPANY, a/s/o JAiN H. L1N, Plaintiff, PRAMINE RODNEY RISHER, Defendant CIVIL ACTION - LAW No.: ~:, q~. ~.-a~-$'~ JURY TRIAL DEMANDED COMPLAINT AND NOW, this .~3 day of ~_D/3 e. , 2004, comes the Plaintiff, General Casualty Insurance Company aYs/o Jain H. Lin, by and through its attorneys, GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, and Charles B. Calkins, Esquire, and files its Complaint against the Defendant, Pramine Rodney Risher, and avers as follows: 1. Plaintiff, General Casualty Insurance Company a/s/o Jain H. Lin, is an insurance company, licensed to do business in the Commonwealth of Pennsylvania, whose primary business address is P.O. Box 519, 86 Hop Meadow Street, Simsbury, Connecticut 06070. 2. Defendant, Pramine Rodney Risher, is an adult individual residing at 460 Sumner Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. At all times pertinent hereto, Plaintiff was the automobile insurance carrier for Jain H. Lin, and has paid for damages resulting from the accident described herein and demands its subrogation interest. 4. The automobile accident occurred on or about January 31, 2003 on Interstate 695, Exit 21 at Wenona, Maryland. 5. On the date previously set forth, Jain H. Lin was operating his 2001 Toyota Corolla on Interstate 695 when he was struck from behind and pushed into a vehicle in front of his vehicle. Mr. Lin's vehicle was struck by a vehicle operated by Pramine Rodney Risher, Defendant herein. 6. The aforesaid action occurred as a result of the carelessness, recklessness and negligence of the Defendant, Pramine Rodney Risher and consisted of the following: a. Failing to properly operate and control his vehicle at all times; b. Failing to keep alert and maintain a proper lookout for the presence of other vehicles on the highway; c. The accident was caused solely as a result of the negligence of the Defendant. 7. As a direct and proximate result of the negligence of the Defendant, Plaintiff has suffered damages as follows: a. $9,500.00 paid to Jain H. Lin for bodily injuries and lost wages; b. $3,334.74 for damages to the vehicle of Jain H. Lin. Due to the foregoing, the Defendant remains owing a total of $12,834.74 to the Plaintiff. 10. Plaintiff has demanded payment of the amotmt due from the Defendant, but Defendant has refused and continues to refuse to pay the same or any part thereof. 11. The amount in controversy herein requires mandatory reference to arbitration. WHEREFORE, Plaintiff demands judgment against the Defendant, Pramine Rodney Risher, for the sum of $12,834.74, together with interest and costs of suit. GRIFFITH, STRICKLER, LERMAN, SOLYMdSi CAiKINS By: CH~k~~C/~~KiNS, ESQUIRE Supreme Cour["I.D. #36208 Attorney for Plaintiff 110 South Northern Way York, PA 17402 (717) 757-7602 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 'GENERAL CASUALTY INSURANCE COMPANY, a/s/o J'A/N H. LIN, Plaintiff, Vo PRAMINE RODNEY RISHER. Defendant CIVIL ACTION - LAW No.: JURY TRIAL DEMANDED VERIFICATION I, ~r~>'~ ~'0 I~_~-_C' , hereby vefi~ ~at ~e atat~ents made in ~e forego~g docment ~e ~e ~d co~ct ~o ~e best of my p~on~ ~owl~ge or ~omafion ~d belief, as well as r~o~, record, ~erences ~d o~ ~vestigato~ mt~al made av~lable m me. To the e~t ~at ~e foregoing cent.s avem~ts w~ch ~e ~consistent in f~t, I v~iff ~at my ~owl~ge or ~fo~afion is sufficient to fern a be~ef ~at one or more of thru is ~e. ~ou~ I m cu~tly unable, after reasonable inv~figafion, to ~c~n which of · e ~consistent ave~ts ~ To the ext~t ~at ~e foregoing ~n~s legal conclusio~ or option, I hereby state ~at my Vehfication is made upon ~e ad.ce of co.scl, upon whom I ~ve relied ~ ~e fil~g of~s docment. ~s Verification is made subj~t to ~e pen~fies of 18 P~C.S. ~4904 related~ unswom f~sifications~to authodaos.(~, ~ ~ BY: ~~~~ DATED:~ General C~u~ty hs~ce Co. SHERIFF'S RETURN - CASE NO: 2004-02928 P COMMONWEALTH OF PENNSYL~%NIA: COUNTY OF CUMBERLAND GENERAL CASULATY INS CO VS RISHER PRAMINE RODNEY REGULAR RONALD HOOVER , Cumberland County, Pennsylvania, says, the within COMPLAINT & NOTICE was served upon RISHER PRAMINE RODNEY DEFENDANT , at 1007:00 HOURS, on the 22nd day of July at 844 FORBES ROAD CARLISLE, PA 17013 PRAMINE RODNEY RISHER Sheriff or Deputy Sheriff of who being duly sworn according to law, CARLISLE BARRACKS by handing to a true and attested copy of COMPLAINT & NOTICE the 2004 together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.70 Affidavit .00 Surcharge 10.00 .00 31.70 Sworn and Subscribed to before me this ~?~ day of C~P~ ~2~;~ ~ A.D.____ ~'~! ~r~hc~'n moEar~y(~', ~ So Answers: R. Thomas Kline o7/2 /2oo4 GRIFFITH STRICKLER LERMAN SOLY By: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GENERAL CASUALTY INSURANCE COMPANY, a/s/o JA1N H. LIN, Plaintiff, CIVIL ACTION - LAW No.: 2004-02928 JURY TRIAL DEMANDED PRAMINE RODNEY RISHER, Defendant PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT ENTER JUDGMENT in the above case pursuant to the attached Notice of Intention To Enter Default Judgment filed with the Cumberland County Court of Common Pleas in favor of Plaintiff, General Casualty Insurance Company a/s/o Jain H. Lin Against PRAMINE RODNEY RISllER in the sum of $12,834.74 together with interest plus costs of suit. Total: $12,834.74 plus interest and costs of suit I hereby certify that the attached Notice of Intention To Enter Default Judgment is a true and correct copy of the original Notice of Intention To Enter Default Ju~n~nt that was mailed to the Defendant on August 16, 2004, pursuant to Pa.R.C.P. 237.1.~h~a°r~i'in~t f / ~ fEfsquire ,,( jo 200)~4 entered the this day to the Judgment by Prothonotary according tenor of the ,~oove sttftement. Cumbcq:land County Prothohot~'"~'~''~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GENERAL CASUALTY INSURANCE COMPANY, a/s/o JAIN H. LIN, Plaintiff, PRAMJNE RODNEY RISHER, Defendant CIVIL ACTION - LAW No.: 2004-02928 JURY TRIAL DEMANDED NOTICE OF INTENTION TO ENTER DEFAULT JUDGMENT TO: Pramme Rodney Risher 844 Forbes Road Carlisle Barracks Carlisle, Pennsylvania 17013 DATE OF NOTICE: August 16, 2004 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 MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR 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 TItE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 t~Pd~F:m, STmCK~ EX, LERMAN, Ii SOI_YMOS & CA/~K1NS S, SQUIRE Attorney foYPltflnfi4tt ' Supreme Court I.D. #36208 1 l0 South Northern Way York, Pennsylvania 17402 Telephone: (717) 757-7602 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GENERAL CASUALTY INSURANCE COMPANY, aYs/o JAIN H. LIN, Plaintiff, PRAMINE RODNEy RISHER, Defendant CIVIL ACTION - LAW No.: 2004-02928 JURY TRIAL DEMANDED IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GENERAL CASUALTY INSURANCE COMPANY, a/s/o JAIN H. LIN, Plaintiff, PRAMINE RODNEY RISHER, Defendant CERTIFICATE OF SERVICE CIVIL ACTION - LAW No.: 2004-02928 JURY TRIAL DEMANDED AND NOW, this 16th day of August, 2004, I, Charles B. Calkins, Esquire, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, hereby certify that I have this date served a copy of the NOTICE OF INTENTION TO ENTER DEFAULT JUDGMENT by United States Mail, addressed to the party or attorney of record as follows: Pramine Rodney Risher 844 Forbes Road Carlisle Barracks Carlisle, Pennsylvania 17013 By: GRIFFITH, STRICKLER, LERMAN, ~OL~t Mos & CALKINS 7- !41ALKINS, ESQUn / Supreme C&ltt I D. #36208 Attorney for Plait~tiff 110 South Northekn Way York, PA 17402 (717) 757-7602 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GENERAL CASUALTY INSURANCE COMPANY, aJs/o JAIN H. LIN, Plaintiff, PRAM1NE RODNEY RISHER, Defendant CIVIL ACTION - LAW No.: 2004-02928 JURY TRIAL DEMANDED TO THE PROTHONOTARY: ( X ) Notice is hereby given that a JUDGMENT in the above-captioned matter has been entered against you in the amount of $12,834.74 plus interest and costs of suit on ( X ) A copy of all documents filed with the Prothonotary in support of the within judgment is enclosed. Prothonotary Civil Div. BY: If you have any questions regarding this Notice, please contact the filing party: NAME: ADDRESS: TELEPHONE NO: (This Notice is given in accordance with Pa.R.C.P.236) Charles B. Calkins, Esquire 110 South Northern Way York, Pennsylvania 17402 (717) 757-7602 Notice sent to: Pramine Rodney Risher 844 Forbes Road Carlisle Barracks Carlisle, Pennsylvania 17013 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GENERAL CASUALTY INSURANCE COMPANY, a/s/o JAIN H. LIN, Plaintiff, PRAMINE RODNEY RISHER, Defendant CIVIL ACTION - LAW No.: 2004-02928 JURY TRIAL DEMANDED AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA : COUNTY OF YORK : ss Charles B. Calkins, Esquire, being duly sworn according to law, deposes and says that he is counsel for Plaintiff in the above-captioned matter; that he personally knows the Defendant, Pramine Rodney Rishcer, whose last known address is 844 Forbes Road, Carlisle Barracks, Carlisle, Pennsylvania 17013, is over the age of 18 years; and that they are employed at unknown. Charles B. Calkins, Esquire, further avers that Defendant is not in the Military Service or in any branch of the Armed Forces of the United States or its Allies or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its Amendments. Charles B. Calkins, Esquire, further avers that Defendant, Pramine Rodney Risher, has not filed an appeal with the Cumberland County Court of Common Pleas, in Cumberland County, Pennsylvania. GRIFFI~FH, ST/LICKLER, LERMAN, By: C~, Ctkls~Esquire Supreme CduWI.Xt~. h 36208 Attorney for Plaintiff' 110 South Northern Way Sworn to and subscribed York, Pennsylvania 17402 befo, r,e me this 7& day Telephone: (717) 757-7602 No ia Seal I Tiffany K. Witcoskie, Notary Public My Commission Expires: ! M Cffn~ssTioWPn 'f~xY~[~ County tkw - F:\WPDOC\cbc\Linql. isher-236Notice.d[~ y p s Aug. 5, 2007 Member, Pennsylvania Association of No.ties IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GENERAL CASUALTY INSURANCE COMPANY, a/s/o JAIN H. LIN, Plaintiff, Vo PRAM1NE RODNEY RISHER, Defendant CIVIL ACTION - LAW No.: 2004-02928 JURY TRIAL DEMANDED AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA : : COUNTY OF YORK : SS The Judgment in the above reference matter entered against the Defendant is based upon damages sustained by the Plaintiff as a result of a motor vehicle accident. Swom and subscribed to beforfikme this ._~__t~-day of '_/z~/~'_ , 2004. ~~io~ Expire~' GRIFF I/T ,H, ~JYR]i C I~~~j~q~AN, By:~ C~ES~'./C ./~fLKINS, ESQUIRE Supreme Couff~.D. ~36208 Attorney for Plaintiff 110 South No,hem Way York, PA 17402 (717) 757-7602 COMMONWEALTH OF PEI,~,,~" I Notarial Seal Tiffany K. Witoo~kie, NotaB. · York _Twp., Y~ Count) My Commission ~ Au~. 5, 2007