HomeMy WebLinkAbout11-2034
CUMBERLAND-DAUPHIN
HARRISBURG TRANSIT
AUTHORITY,
Vs.
Plaintiff
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CIVIL ACTION-LAW
DONNA RECORD,
Defendant
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NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set faith
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 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
MID PENN LEGAL SERVICES
231A NORTH FRONT STREET
HARRISBURG, PA 17107
(717) 232-0581
THOMAS J. R CHFORD, UIRE
ATTORNEY FOR PLAINTIFF
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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CUMBERLAND-DAUPHIN
HARRISBURG TRANSIT
AUTHORITY,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
Plaintiff
Vs.
DONNA RECORD,
Defendant
CIVIL ACTION-LAW
COMPLAINT
And Now, comes the Plaintiff CUMBERLAND-DAUPHIN HARRISBURG TRANSIT
AUTHORITY, by and through its COUNSEL, THOMAS J. RATCHFORD JR, ESQUIRE,
and hereby complains of the Defendant as follows:
1.) The Plaintiff is CUMBERLAND-DAUPHIN HARRISBURG TRANSIT
AUTHORITY, a local agency having a registered office located at 901 N. Cameron Street,
Harrisburg, PA 17105-1571.
2.) The Defendant is Donna Record, an adult and competent individual residing at 9310
FM 2004, Santa Fe, Texas 77510.
3.) On February 12, 2010, the Plaintiff was the owner ofa GilIig bus, which was lawfully
traveling South on Interstate I-81, near Exit 52, Cumberland County, when suddenly and without
warning, the Defendant, Donna Record, rear ended a third vehicle traveling in front of her, which in
turn caused Plaintiff's bus to collide with the Defendants vehicle, causing substantial damage to the
Plaintiff's bus as set forth below.
4.) The negligence of the Defendant, Donna Record consisted of the following:
( a ) Traveling at an excessive rate of speed;
( b ) Failure to maintain a proper lookout;
( c ) Failure to have her vehicle under proper and adequate control.
5.) As a direct and proximate result of the Defendant's negligence, Plaintiff's bus
sustained property damage totaling $10,365.55.
Wherefore, Plaintiff demands judgment in its favor and against the Defendant in the
amount of $10,365.55 together with costs of suit and delay damages, all of which is within the
applicable arbitration limits for Cumberland County, Pennsylvania.
Respectfully Submitted,
THOMAS J. RATCHFORD JR., ESQUIRE
Wei .
I, MICHAEL HENRY, hereby verify that I am a duly authorized agent of the
Plaintiff in the present action; that I have reviewed the facts set forth In the
foregoing complaint and that they are true and correct to the best of my
knowledge, information and belief. I understand that false statements
made herein are subject to the penalties of 18 PA. C.S.A. Section 4904
relating to unswom falsification to authorities.
MICHAEL HENRY
CUMBERLAND-DAUPHIN
HARRISBURG TRANSIT
AUTHORITY,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
Plaintiff
Vs.
CIVIL ACTION-LAW
DONNA RECORD,
Defendant
PRAECIPE TO DISCONTINUE
To the Prothonotary:
11-2034
Please mark the above-entitled action Settled, Ended, and Discontinued with Prejudice.
By:
Thomas J. tchford, Jr. squ e
Attorney for Plaintiff
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