HomeMy WebLinkAbout10-7513tVILLIA~I A. ADDAMS, ESQUIRE
ATTORNEY ID # 06265
43 W. SOUTH ST.
P.O. BOX 261
CARLISLE PA 17013
TELEPHONE 717-243-7638
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ZQIO DEC -6 AM 9:29
rUMBERLAND C~IUN' ~'
~'ENNSY~Y~;Nl;
GEICO as subrogee of TREVOR M. In the Court of Common Pleas of
HART'I~ORD Cumberland County, Pennsylvania
Plaintiff Civil Action -Law
VS.
MATTHEW R. BITTER
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 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 OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Legal Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
71.7-249-3166 ~
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William A. dams
Attorney for Plaintiff
43 W. South St. ~
No. 10- X5/3 Civil Term
Defendant
Carlisle, PA 17013 /~ /'~ ~ ~~n ~~/~~1
717-243-7638 /~- % " "7
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ttiILLIAl\1 A. ADDAMS, ESQUIRE
A'l~TOR~E1' ID ~ 06265
4 3 W. SOUTH ST.
P.O. BOX 261
CARLISLE PA 17013
TELEPHONE 717-243-7638
GEICO as subrogee of TREVOR 1V1
HARTFORD
Plaintiff
VS.
.....................................................................................................................................
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Civil Action -Law
No. 10- ~,~~i3 Civil Term
MATTHEW R. BITTER
Defendant
AND now comes the plaintiff GEICO by his attorney, William A.
Addams, and make the following:
COMPLAINT
1. The plaintiff is GEICO, a corporation authorized to conduct insurance
business in the Commonwealth of Pennsylvania with its office in Pennsylvania
with its offices and principal place of business at 1 GEICO Boulevard,
Fredericksburg, VA 22142-0001.
2. The Defendant is Matthew R. Ritter, an adult individual residing at 12
Spinning Wheel Road, Duncannon, Perry County, PA 17020.
3. The Plaintiff issued a policy of automobile insurance to Trevor M.
Hartford of Harrisburg, PA which was in effect on September 14, 2010.
4. Mr. Hartford was the owner of a 2006 VW Jetta which, on September
14, 2010 he was driving traveling north in the 600 block of Enola Road in Enola,
PA and was slowing down and pulling off to the side of the road.
5. At that time the Defendant was driving a Chrysler behind Mr. Hartford when
he negligently and carelessly collided with the rear of the Jetta causing the
damage hereinafter set forth.
6. The Defendant was negligent in careless in:
a. Being inattentive;
b. Failing to observe the Jetta in time to avoid a collision; and
c. Failing to have his vehicle under control.
7. As a result of the negligence and carelessness of the Defendant, the
Jetty vas a total loss. The vehicle had an actual cash value of $14,154.23 and net
salvage value of $4,688.00 resulting in a loss of $9,465.23. In addition, there ~-vas
rental expense of $246.25.
8. The Plaintiff's insurance policy provided coverage for the collision loss
and rental expense. The Plaintiff made payment to its insured, Trevor Hartford,
and is subrogated to the rights of its insured.
WHEREFORE Plaintiff demands judgment against the Defendant in the
amount of $9,711.48 plus interest and costs of suit an amount within the
jurisdiction of arbitration under the local rules of court.
,~
William A. A ams
Attorney for Plaintiff
43 W. South St.
Carlisle, PA 17013
717-243-7638
VERIFICATION
William A. Addams hereby verifies that he is the attorney for the Plaintiff, which is
outside the jurisdiction of the court, that he is authorized to and does make this verification on
its behalf, and that the facts set forth in the foregoing Complaint are true and correct to the
best of his knowledge, information and belief. He understands that false statements herein
are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsifications to
authorities
Date: December 1, 2010 ~~i ~~ .,~;~._
Willia ~ A. Addams
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny RAnderson , ,, i ILFF-O FIC
Sheriff =.'t THE Fr
Ht ; ^ r
Jody S Smith
?? 2?
Chief Deputy PH c;
Richard W Stewart 'U"BERL D ,e r; a
Solicitor PENNS
Geico
vs Case Number
.
Matthew R. Ritter 2010-7513
SHERIFF'S RETURN OF SERVICE
12/07/2010 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 R. Ritter, but was unable to locate him in his
bailiwick. He therefore deputized the Sheriff of Perry County, Pennsylvania to serve the within Complaint
and Notice according to law.
12/10/2010 Perry County Return: And now, December 10, 2010 I, Carl E. Nace, Sheriff of Perry County,
Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Matthew R. Ritter
the defendant named in the within Complaint and Notice and that I am unable to find him in the County of
Perry and therefore return same NOT FOUND. Request for service at 12 Spinning Wheel Road,
Duncannon, Pennsylvania 17020 the defendant was not found.
SHERIFF COST: $37.44
December 15, 2010
SO ANSWERS,
RONf`T R ANDERSON, SHERIFF
SHERIFF'S RETURN
In the Court of Common Pleas
Of the 41st Judicial District
of Pennsylvania-
Perry County Branch
No. 2010-7513 Cumberland County
Geico Subrogee Trevor Hartford
VS
Matthew R. Ritter
12 Spinning Wheel Road
Duncannon, PA 17020
Carl E. Nace, Sheriff, who being duly sworn according to law, says that he made a
diligent search and inquiry for the within named Defendant(s) to wit Matthew R. Ritter,
but was unable to locate him/her in his bailiwick. He therefore returns the within
Complaint for the above named Defendant(s) Matthew R. Ritter at 12 Spinning Wheel
Road, Duncannon, PA 17020. NOT FOUND. NO LONGER LIVES AT THIS
ADDRESS.
Sincerely,
Sworn and subscribed to before me
this __/grr4day of &&,2?, 2010.
JOY S.
MY
SEAL
ITARY PUBLIC
PERRY COUNTY
S MARCH 6, 2014
Z0261 4r, Aft0a
Carl E. Nace
Sheriff of Perry County
DavidD. Buell
Prothonotary
Office of the Prothonotary
Cum6er[and County, Pennsylvania
KirkS. Sohonage, ESQ,
Solicitor
�c —145f3 CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 28TH DAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE —THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH
PA R.C.P.230.2.
BY THE COURT,
DAVID D. BUELL
PROTHONOTARY
One Courthouse Square • Suite100 • Carlisle, TA • Phone 717 240-6195 • T. 717 240-6573