HomeMy WebLinkAbout01-2376SHEILA C. O'CONNOR,
Plaintiff
V.
DENISE M. COLEMAN,
Defendants
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. OI
· CIVIL ACTION - LAW
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,
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
Telephone 717-249-3166 or 800-990-9108
HANDLER, ~/~
1300 Linglest
Harrisburg, PA 17~
(717) 238-2000/
Attorney for Plaintiff
ERG
SHEILA C. O'CONNOR,
Plaintiff
V
DENISE M. COLEMAN,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:NO. o/-
: CIVIL ACTION - LAW
: JURY TRIAL DEMANDED
COMPLAINT
AND NOW, comes the Plaintiff, Sheila C. O'Connor, by and through her attorneys,
HANDLER, HENNING & ROSENBERG, by W. Scott Henning, Esquire, and bring the within
Complaint against the Defendant, Denise M. Coleman, and aver as follows:
1. Plaintiff; Sheila C. O'Connor, is an adult individual who currently resides at 15
Aspen Drive, Narragansett, Rhode Island, 02882.
2. Defendant, Denise M. Coleman, is an adult individual who ctm'ently resides at
665 Gregs Drive, Apartment No. 93, Harrisburg, Dauphin County, Pennsylvania, 17111.
3. At all times material hereto, Plaintiff; Sheila C. O'Connor, was the owner and
operator of a 1999 Nissan Altima, bearing Pennsylvania Registration Number BXM 1045.
4. At all times material hereto, Defendant, Denise M. Coleman, was the owner and
operator ora 1996 Saturn SL2, bearing Pennsylvania Registration Number ALW 2800.
5. At all times material hereto, there were no adverse weather conditions and the
road surface was dry.
6. On or about May 11, 1999, at approximately 10:30 a.m., Plaintiff, Sheila C.
O'Connor, was stopped at a red light on the southbound Wesley Drive ramp of Routes I 1/15 in
Lower Allen Township, Cumberland County, Pennsylvania.
7. On or about May 11, 1999, at approximately 10:30 a.m., Defendant, Denise M.
Coleman, was traveling on the southbound Wesley Drive ramp of Routes 11/15 in Lower Allen
Township, Cumberland County, Pennsylvania.
8. At approximately the same time and place, Defendant failed to observe that
Plaintiff' s vehicle had stopped at a red light then and there existing. Suddenly and without warning,
Defendant failed to bring her vehicle to a halt and a violent collision resulted. Upon impact,
Defendant's vehicle struck the rear end of Plaintiff's vehicle.
9. The aforementioned collision caused extensive property damage and was so
severe that the Plaintiff required medical attention.
10. Prior to the aforementioned collision, Nationwide Insurance Company issued a
policy of automobile insurance to Plaintiff, Sheila C. O'Connor. Said policy was in effect on May
11, 1999, the date of the collision and the limited tort option was selected. Plaintiff remains eligible,
pursuant to 75 Pa. C.S.A. §1705(d), to seek compensation for non-economic losses due to the
serious nature of the injuries and the serious permanent disfigurement sustained by her.
11.
12.
COUNT I
SHEILA C. O'CONNOR v. DENISE M. COLEMAN
NEGLIGENCE
Paragraphs 1-9 are incorporated herein as if set forth at length.
The occurrence of the aforementioned collision and the resultant injuries to
Plaintiff, Sheila C. O'Connor, were the direct and proximate result of the negligence of Defendant,
Denise M. Coleman, generally and more specifically, as set forth below:
(A)
(B)
(c)
(D)
(E)
(F)
(G)
(H)
In failing to operate her vehicle at a safe speed, in violation of 75 Pa. C.S.A.
§3361;
In failing to operate said vehicle in such a manner that would allow her to
apply the brakes and stop before striking Plaintiff's vehicle;
In failing to operate her vehicle under proper and adequate control so that she
could have avoided striking Plaintiff's vehicle;
In failing to maintain proper and adequate observation of the existing traffic
patterns, namely, stopped traffic;
In failing to keep a proper lookout for vehicles lawfully on the highway;
In failing to operate her vehicle at a speed at which she could stop within the
assured cleared distance ahead, in violation f75 Pa. C.S.A. §3310;
In failing to be reasonably vigilant to observe Plaintiff's vehicle; and
In ailing to exercise reasonable care in the operation and control of her
vehicle, in violation of 75 Pa. C.S.A. §3714.
13. As a direct and proximate result of the negligence of the Defendant, Denise M.
Coleman, the Plaintiff, Sheila C. O'Connor, has suffered personal injuries including, but not limited
to, cervical myofascial pain syndrome, associated vertigo and chronic headaches, post-concussion
syndrome, torn lateral meniscus of right knee, cervical sprain with inner spinous ligament injury,
lumbar sprain with radiculitis, and SI joint dysfunction.
14. As a direct and proximate result of the negligence of the Defendant, Denise M.
Coleman, the Plaintiff, Sheila C. O'Connor, sustained serious personal injuries requiring emergency
medical treatment, surgical intervention and continuing medical treatment.
15. As a direct and proximate result of the negligence of the Defendant, Denise M,
Coleman, the Plaintiff, Sheila C. O'Connor, has been, and will in the future be, hindered from
attending to her daily activities and duties, to her great detriment, loss, humiliation and
embarrassment.
16. As a direct and proximate cause of the negligence of the Defendant, Denise M.
Coleman, the Plaintiff, Sheila C. O'Connor, has suffered great physical pain, discomfort,
humiliation, and mental anguish, and will continue to endure the same for an indefinite period of
time in the future, to her physical, emotional, and financial detriment and loss.
17. As a direct and proximate result of the negligence of the Defendant, Denise M.
Coleman, the Plaintiff, Sheila C. O'Connor, has been compelled, in order to effect a cure for the
aforesaid injuries, to expend money for medical attention. Plaintiff continues to take medications
and incur medical expenses for said injuries, and will continue to do so in the future, to her great
detriment and loss.
18. As a direct and proximate result of the negligence of the Defendant, Denise M.
Coleman, the Plaintiff, Sheila C. O'Connor, has suffered a loss of life's pleasures, and she will
continue to suffer the same in the future, to her great detriment and loss.
19. As a direct and proximate result of the negligence of the Defendant, Denise M.
Coleman, the Plaintiff, Sheila C. O'Connor, sustained a loss of wages, and she will continue to suffer
the same in the future, to her great detriment and loss.
20. Plaintiff, Sheila C. O'Connor, believes, and therefore avers, that her injuries are
permanent in nature.
WHEREFORE, Plaintiff, Sheila C. O'Connor, seeks damages from Defendant, Denise M.
Coleman, in an amount in excess of Twenty-Five Thousand ($25,000.00) Dollars, exclusive of
interest and costs, and demands a trial by jury.
Respectfully submitted,
HANDLER, HENNING & ROSENBERG
Attorney I.D. No. 32/298
1300 Linglestown lq[cm~
Harrisburg, PA 17108
(717) 238-2000
Attorney for Plaintiff
VERIFICATION
The undersigned hereby verifies that the statements in the foregoing document
are based upon information which has been furnished to counsel by me and
information which has been gathered by counsel in the preparation of this lawsuit.
The language of the document is of counsel and not my own. I have read the
document 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 contents of the document are that of counsel, I have relied upon
my counsel in making this Verification. The undersigned also understands that the
statements made therein are made subject to the penalties of 18 Pa. C.S. Section
4904, relating to unsworn falsification to authorities.
cC -
SHEILA O'CONNOR
Date:
SHEILA C. O'CONNOR,
Plaintiff
V,
DENISE M. COLEMAN,
Defendants
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. Ol-
: CIVIL ACTION - LAW
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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
Telephone 717-249-3166 or 800-990-9108
HANDLE~E~NBERG
BYw. s~ttH~i~nin ,~Esq./
1300 L'mglestown/~Sad
Harrisburg, PA ~110
(717) 238-200~
Attorney for Plaintiff
SHEILA C. O'CONNOR,
Plaintiff
v
DENISE M. COLEMAN,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO.
:
: CIVIL ACTION - LAW
: JURY TRIAL DEMANDED
COMPLAINT
AND NOW, comes the Plaintiff, Sheila C. O'Connor, by and through her attorneys,
HANDLER, HENNING & ROSENBERG, by W. Scott Henning, Esquire, and bring the within
Complaint against the Defendant, Denise M. Coleman, and aver as follows:
1. Plaintiff, Sheila C. O'Connor, is an adult individual who currently resides at 15
Aspen Drive, Narragansett, Rhode Island, 02882.
2. Defendant, Denise M. Coleman, is an adult individual who currently resides at
665 Gregs Drive, Apartment No. 93, Harrisburg, Dauphin County, Pennsylvania, 17111.
3. At all times material hereto, Plaintiff, Sheila C. O'Connor, was the owner and
operator of a 1999 Nissan Altima, bearing Pennsylvania Registration Number BXM 1045.
4. At all times material hereto, Defendant, Denise M. Coleman, was the owner and
operator of a 1996 Saturn SL2, bearing Permsylvania Registration Number ALW 2800.
5. At all times material hereto, there were no adverse weather conditions and the
road surface was dry.
6. On or about May 11, 1999, at approximately 10:30 a.m., Plaintiff, Sheila C.
O'Connor, was stopped at a red light on the southbound Wesley Drive ramp of Routes 11/15 in
Lower Allen Township, Cumberland County, Pennsylvania.
7. On or about May 11, 1999, at approximately 10:30 a.m., Defendant, Denise M.
Coleman, was traveling on the southbound Wesley Drive ramp of Routes 11/15 in Lower Allen
Township, Cumberland County, Pennsylvania.
8. At approximately the same time and place, Defendant failed to observe that
Plaintiff's vehicle had stopped at a red light then and there existing. Suddenly and without warning,
Defendant failed to bring her vehicle to a halt and a violent collision resulted. Upon impact,
Defendant's vehicle struck the rear end of Plaintiff' s vehicle.
9. The aforementioned collision caused extensive property damage and was so
severe that the Plaintiffrequired medical attention.
10. Prior to the aforementioned collision, Nationwide Insurance Company issued a
policy of automobile insurance to Plaintiff, Sheila C. O'Connor. Said policy was in effect on May
11, 1999, the date of the collision and the limited tort option was selected. Plaintiff remains eligible,
pursuant to 75 Pa. C.S.A. §1705(d), to seek compensation for non-economic losses due to the
serious nature of the injuries and the serious permanent disfigurement sustained by her.
1I.
12.
COUNT I
SHEILA C. O'CONNOR v. DENISE M. COLEMAN
NEGLIGENCE
Paragraphs 1-9 are incorporated herein as if set forth at length.
The occurrence of the aforementioned collision and the resultant injuries to
Plaintiff, Sheila C. O'Connor, were the direct and proximate result of the negligence of Defendant,
Denise M. Coleman, generally and more specifically, as set forth below:
(A) In failing to operate her vehicle at a safe speed, in violation of 75 Pa. C.S.A.
{}3361;
(B) In failing to operate said vehicle in such a manner that would allow her to
apply the brakes and stop before striking Plaintiff's vehicle;
(C) In failing to operate her vehicle under proper and adequate control so that she
could have avoided striking Plaintiff's vehicle;
(D) In failing to maintain proper and adequate observation of the existing traffic
patterns, namely, stopped traffic;
(E) In failing to keep a proper lookout for vehicles lawfully on the highway;
(F) In failing to operate her vehicle at a speed at which she could stop within the
assured cleared distance ahead, in violation f 75 Pa. C.S.A. {333 l 0;
(G) In failing to be reasonably vigilant to observe Plaintiff's vehicle; and
(H) In ailing to exercise reasonable care in the operation and control of her
vehicle, in violation of 75 Pa. C.S.A. {}3714.
13. As a direct and proximate result of the negligence of the Defendant, Denise M.
Coleman, the Plaintiff, Sheila C. O'Connor, has suffered personal injuries including, but not limited
to, cervical myofascial pain syndrome, associated vertigo and chronic headaches, post-concussion
syndrome, torn lateral meniscus of right knee, cervical sprain with inner spinous ligament injury,
lumbar sprain with radiculitis, and SI joint dysfunction.
14. As a direct and proximate result of the negligence of the Defendant, Denise M.
Coleman, the Plaintiff, Sheila C. O'Connor, sustained serious personal injuries requiring emergency
medical treatment, surgical intervention and continuing medical treatment.
15. As a direct and proximate result of the negligence of the Defendant, Denise M.
Coleman, the Plaintiff, Sheila C. O'Connor, has been, and will in the future be, hindered from
attending to her daily activities and duties, to her great detriment, loss, humiliation and
embarrassment.
16. As a direct and proximate cause of the negligence of the Defendant, Denise M.
Coleman, the Plaintiff, Sheila C. O'Connor, has suffered gmat physical pain, discomfort,
humiliation, and mental anguish, and will continue to endure the same for an indefinite period of
time in the future, to her physical, emotional, and financial detriment and loss.
17. As a direct and proximate result of the negligence of the Defendant, Denise M.
Coleman, the Plaintiff, Sheila C. O'Connor, has been compelled, in order to effect a cure for the
aforesaid injuries, to expend money for medical attention. Plaintiff continues to take medications
and incur medical expenses for said injuries, and will continue to do so in the future, to her great
detriment and loss.
18. As a direct and proximate result of the negligence of the Defendant, Denise M.
Coleman, the Plaintiff, Sheila C. O'Connor, has suffered a loss of life's pleasures, and she will
continue to suffer the same in the future, to her great detriment and loss.
19. As a direct and proximate result of the negligence of the Defendant, Denise M.
Coleman, the Plaintiff, Sheila C. O'Connor, sustained a loss of wages, and she will continue to suffer
the same in the future, to her great detriment and loss.
20. Plaintiff, Sheila C. O'Connor, believes, and therefore avers, that her injuries are
permanent in nature.
WHEREFORE, Plaintiff, Sheila C. O'Connor, seeks damages from Defendant, Denise M.
Coleman, in an amount in excess of Twenty-Five Thousand ($25,000.00) Dollars, exclusive of
interest and costs, and demands a trial by jury.
Respectfully submitted,
HANDLER, HENNING & ROSENBERG
W. Scott H~
Attorney I.D. ~8 /
1300 Linglestown Road/
Harrisburg, PA 17108~/
(717) 238-2000
Attorney for Plaintiff
VERIFICATION
The undersigned hereby verifies that the statements in the foregoing document
are based upon information which has been furnished to counsel by me and
information which has been gathered by counsel in the preparation of this lawsuit.
The language of the document is of counsel and not my own. I have read the
document and to the extent that it is based upon information which I have given to
counsel, it is true and correct to the best of my knowledge, information and belief. To
the extent that the contents of the document are that of counsel, I have relied upon
my counsel in making this Verification. The undersigned also understands that the
statements made therein are made subject to the penalties of 18 Pa. C.S. Section
4904, relating to unsworn falsification to authorities.
SHEILA O'CONNOR
Date:
SHEILA C. O'CONNOR,
Plaintiff
V
DENISE M. COLEMAN,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 01-2376
:
: CIVIL ACTION - LAW
PRAECIPE TO REINSTATE
TO THE PROTHONOTARY:
Please reinstate the above-captioned Complaint in order that Defendant Denise M.
Coleman can be served accordingly.
Date:
Respectfully submitted,
HANDLER, HENNING & ROSENBERG
By: ~~q e~
D.$o. 3. .98
1300 Ling sl~to~ Roa,
Harrisburg, PA 17108
(717)238-2000
Attorney for Plaintiff
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2001-02376 P
COMMONWEALTH OF PENNSYLVA~NIA
COUNTY OF CUMBERLAND
O'CONNOR SHEILA C
VS
COLEMAN DENISE M
Thomas Kline
duly sworn according to law, says, that he made a diligent
inquiry for the within named defendant, DEFENDANT
COLEMAN DENISE M
unable to locate Her
,Sheriff or Deputy Sheriff, who being
search and
but was
in his bailiwick. He therefore returns the
COMPLAINT & NOTICE
the within named DEFENDANT
COLEMAN DENISE M
NOT POUND , as to
Sheriff's Costs:
Docketing 18.00
Service .00
Affidavit .00
Surcharge 10o00
Dep. Dauphin Co. 29.25
57.25
~her~ of Cumberland County
HAND~ ~ZHENNING & ROSENEERG
o5/2 OOl
Sworn and subscribed to before me
this 3D~ day of ~
~/ A.D.
~honotary '
Mary Jane Snyder
Real Estate Deputy
William T. Tully
Solicitor
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 255-2660 fax: (717) 255-2889
Jack Lotwick
Sheriff
J. Daniel Basile
Chief Deputy
Michael W. Rmehart
Assistant Chief Deputy
Commonwealth of Pennsylvania : O'CONNOR SHEILA c
VS
County of Dauphin : COLEMAN DENISE M
Sheriff's Return
No. 1247-T - - -2001
OTHER COUNTY NO. 01-2376
I, Jack Lotwick, Sheriff of the County of Dauphin, State of
Pennsylvania, do hereby certify and return, that I made diligent
search and inquiry for COLEMAN DENISE M
the DEFENDANT named in the within NOTICE & COMPLAINT IN CIVIL ACTION
and that I am unable to find him/her in the County of Dauphin, and
therefore return same NOT FOUND, May 18, 2001
EXPIRED BEFORE DEFENDANT COULD BE FOUND.
Sworn and subscribed to
before me this 18TH day of MAY, 2001
!
PROTHONOTARY
So Answers,
Sheriff of Dauphin County, Pa.
By
Deputy Sheriff
Sheriff's Costs: $29.25 PD 05/04/2001
RCPT NO 149467
~ d
.tn T. be Coat; of Common Pleas of Cnmner~an County, Pennsy~vanka
Shei]a C. O'Connor VS.
Denise M. Coleman
01-7376
NOW, 4 / 24 / 01 ,20 ~ ~, I, SHERIFF OF CIYMBERLAND COIJi'JTY, p~a., do
hereby deputize the Sheriff of Dauphin COllllty to execute this Wri% this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland Count'y, PA
~,IOW,
upon
at
by handing to
a
and made lmown to
Affidavit of Ser~r~ce
,20 ,at
o'clock
copy of the ori~nal
~O ai1swers,
1VI. served the
the contents thereof.
Sworn and subscr/bed before
me ~3fis__ day of
,20__
Sheriff of
COSTS
SERVICE
MILEAGE
.A~FIDAV-IT
CounTy, FA
SHEILA C. O'CONNOR,
Plaintiff
V,
DENISE M. COLEMAN,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-2376 CIVIL TERM
CIVIL ACTION - LAW
:
: JURY TRIAL DEMANDED
PRAECIPE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA:
Please re-issue the Complaint in the above referenced matter. Please instruct
the Sheriff of Cumberland County to attempt service of the Complaint upon the
Defendant Denise M. Coleman a/k/a Denise M. Garver a/k/a Denise M. Anderson at the
following address:
665 Gregs Drive
Harrisburg, PA 17111
HANDLER, HENNING & ROSENBERG
Date:
W. Scott H/ef~nin~l', :.s4.
I.D. #322~8 / /
1300 Ling~n/F )ad
Harrisburg,~A 17110
(717) 238-2000
Attorney for Plaintiff
SHERIFF'S RETURN - OUT OF COIAWTY
CASE NO: 2001-02376 P
COMMONWEALTH OF PENNSYLVAiWIA:
COUNTY OF CUMBERLAND
O'CONNOR SHEILA C
VS
COLEMAN DENISE M
R. Thomas Kline
duly sworn according to law,
and inquiry for the within named DEFENDANT
COLEMAN DENISE M
but was unable to locate Her
deputized the sheriff of DAUPHIN
serve the within COMPLAINT
, Sheriff or Deputy Sheriff who being
says, that he made a diligent search and
to wit:
in his bailiwick.
County,
& NOTICE
He therefore
Pennsylvania, to
On July 26th , 2001 , this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs:
Docketing 18.00
Out of County 9.00
Surcharge 10.00
Dep Dauphin Co 29.25
.00
66.25
07/26/2001
So answer~: / i
R. /Thomas Kline
Sheriff of Cumberland County
HANDLER HENNING & ROSENBERG
Sworn and subscribed to before me
this ~ ~ day
A.D.
Prothonotary
Mary Jane Snyder
Real Estate Deputy
William T. Tully
Solicitor
Dauphin Coumy
Han'isburg, Pennsylvania 17101
ph: (717) 255-2660 fax: (717) 255-2889
Jack Lotwick
Sheriff
J. Daniel Basile
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
Commonwealth of Pennsylvania
County of Dauphin
AND NOW: July 18, 2001
NOTICE & COMPLAINT
COLENLAN DENISE M
to HER
of the original
to him/her the contents thereof at 665 GREGS DRIVE
HARRISBURG, PA
: O'CONNOR SHEILA C
VS
: COLEMAN DENISE M
Sheriff's Return
No. 1898-T - -2001
OTHER COUNTY NO. 01-2376
at 8:40AM served the within
upon
by personally handing
0 true attested copy(ies)
NOTICE & COMPLAINT and making known
17111-0000
Sworn and subscribed to
before me this 23RD day of JULY, 2001
PROTHONOTARY
So Answers,
Sher' f of Dauphin Coun , Pa.
Sheriff's Costs: $29.25 PD 07/13/2001
RCPT NO 151912
MLYNEK
In The Court of Common Pleas of Cumberland County, Pennsylvania
Sheila C. O' Connor
VS.
Denise M. Coleman
Serve: Denise M. Coleman No. 01 2376 civil
NOW, July 10, 2001 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Deuph~n County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
Now,
within
upon
at
by handing to
a
and made kmown to
Affidavit of Service
,20 , at
o'clock
copy of the original
So answers,
M. served the
the contents thereof.
Sworn and subscribed before
me this __ day of
,2O
Sheriffof
COSTS
SERVICE
MILEAGE
AFFIDAVIT
County, PA