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Home My WebLink About11-3108ANGINO & ROVNER, P.C. Michael E. Kosik, Esquire Attorney ID# : 36513 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: mkosik@angino-rovner.com SEYEDEH HOSSEINI, Plaintiff V. PAMELA HAMMAKER, Defendant 21311 II AR 13 X1410: %5 0 ,CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. l k , 3169 Civi : JURY TRIAL DEMANDED NOTICE TO DEFEND 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 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 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 (717) 249-3166 457000 O t,v_ t S4 3I9 ?Z'Wps? -17S NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas sugnuientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEPFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEQUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 457000 ANGINO & ROVNER, P.C. Michael E. Kosik, Esquire Attorney ID# : 36513 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: mkosik@angino-rovner.com SEYEDEH HOSSEINI, Plaintiff V. PAMELA HAMMAKER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. JURY TRIAL DEMANDED COMPLAINT 1. Plaintiff Seyedeh Hosseini is an adult individual and citizen of Massachusetts, who resides at 218 Sheffield Avenue Long Meadow, Massachusetts 01106. 2. Defendant Pamela Hammaker is an adult individual and citizen of the Commonwealth of Pennsylvania, who resides at 218 North State Road, Marysville, Perry County, PA 17053. 3. The facts and occurrences hereinafter related took place on April 9, 2009, on Interstate 81 south near exit 45 in Cumberland County, Pennsylvania. 4. At that time and place, Plaintiff Seyedeh Hosseini was driving a 2000 Honda traveling south in the right travel lane. 5. At that time and place, Defendant Pamela Hammaker was driving a 2003 Mazda Prot6g6 traveling south in the left travel lane operating her vehicle at a high rate of speed and weaving in and out of traffic. 6. At that time and place, Defendant Pamela Hammaker suddenly and without warning, merged into the right travel lane directly in front of Plaintiff Seyedeh Hosseini and caused 457000 her to swerve in an attempt to avoid being struck by Defendant's vehicle causing Plaintiff Seyedeh Hosseini's vehicle to leave the roadway and roll onto the roof. 7. Defendant Pamela Hammaker fled the scene of the accident. 8. The foregoing accident and all of the injuries and damages set forth hereinafter sustained by Plaintiff Seyedeh Hosseini is the direct and proximate result of the negligent, careless and reckless manner in which Defendant Pamela Hammaker operated her vehicle as follows: (a) failure to signal when moving from one traffic lane to another and in violation of 75 Pa.C.S.A. 3334; (b) failure to properly overtake and pass Plaintiff's vehicle at a safe distance and until safely clear in violation of 75 Pa.C.S.A. 3303; (c) failure to travel at a safe speed; (d) failure to keep alert and maintain a proper watch for the presence of other motor vehicles on the highway; (e) failure to drive her vehicle with due regard for the highway and traffic conditions which were existing and of which she was or should have been aware; (f) failure to keep proper and adequate control over her vehicle; and (g) driving her vehicle upon the highway in a manner endangering persons and property and in a reckless manner with careless disregard to the rights and safety of others and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 9. Plaintiff sustained painful and severe injuries which include but are not limited to neck pain and left shoulder pain with radiating pain and numbness down left arm, post traumatic stress disorder and shock to her nervous system. 457000 10. By reason of the aforesaid injuries, Plaintiff Seyedeh Hosseini was forced to incur liability for medical treatment, medications, hospitalizations and similar miscellaneous expenses in an effort to restore herself to health, and claim is made therefor. 11. Because of the nature of her injuries, Plaintiff Seyedeh Hosseini has been advised and, therefore, avers that she may be forced to incur similar expenses in the future, and claim is made therefor. 12. As a result of the aforementioned injuries, Plaintiff Seyedeh Hosseini has undergone and in the future will undergo great physical and mental suffering, great inconvenience in carrying out her daily activities, loss of life's pleasures and enjoyment, and claim is made therefor. 13. Plaintiff Seyedeh Hosseini continues to be plagued by persistent pain and limitations and, therefore, avers that her injuries may be of a permanent nature, causing residual problems for the remainder of her lifetime and claim is made therefor. 14. As a result of the aforementioned injuries, Plaintiff Seyedeh Hosseini may sustain work loss, loss of opportunity and a permanent diminution of her earning power and capacity, and claim is made therefor. 15. As a result of the aforesaid injuries, Plaintiff Seyedeh Hosseini has sustained uncompensated work loss, and claim is made therefor. WHEREFORE, Plaintiff Seyedeh Hosseini demands judgment against Defendant Pamela Hammaker in an amount in excess of Fifty Thousand ($50,000.00) Dollars exclusive of interest 457000 and costs and in excess of any jurisdictional amount requiring compulsory arbitration. P.C. Michael E. Kosik, Esquire I.D. No. 36513 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiff 457000 VERIFICATION I, SEYEDEH HOSSEINI, do swear and affirm that the facts set forth in the foregoing COMPLAINT are true and correct to the best of my knowledge, information and belief. I understand that this verification is made subject to the penalties of the Rules of Civil Procedure relating to unworn falsification to authorities. WITNESS: S E EH HOSSEINI Dated: 203648 LAW OFFICES OF HUBSHMAN C_AREY & FLOOD By: JAMES M. FLOOD Attorney I.D.#70257 2200 Stafford Avenue, Suite 500 Scranton, PA 18505 Phone #570-961-7580 Attorney for Defendant SEYEDEH HOSSEINI Plaintiff VS. PAMELA HAMMAKER Defendant C ca -n m r ? rn `v Cn ?? "' pC7 <O --tp 2 -71 5 C Z C ) -? rn x0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW JURY TRIAL DEMANDED NO. 11-CIVIL-3108 PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Defendant, Pamela Hammaker, in the above-captioned matter. HUBSHMAN, CAREY & FLOOD Y• James M. Flood, Esquire Attorney for Defendant LAW OFFICES OF HUBSHMAN AREY & FLOOD By: JAMES M. FLOOD Attorney I.D.#70257 2200 Stafford Avenue, Suite 500 Scranton, PA 18505 Phone #570-961-7580 Attorney for Defendant SEYEDEH HOSSEINI Plaintiff vs. PAMELA HAMMAKER C"3 ev Sao s. ?-n r r -<> t rn ? o° Zp = a -tt n r-a a, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW JURY TRIAL DEMANDED Defendant NO. 11-CIVIL-3108 DEMAND FOR JURY TRIAL TO THE PROTHONOTARY: Defendant, Pamela Hammaker, hereby demands trial by twelve (12) jurors. HUBSHMAN, CAREY & FLOOD By: James M. Flood, Esquire Attorney for Defendant LAW OFFICES OF HUSSHMAN C_AREY & FLOOD By: JAMES M. FLOOD Attorney I.D.#70257 2200 Stafford Avenue, Suite 500 Scranton, PA 18505 Phone #570-961-7580 Attorney for Defendant SEYEDEH HOSSEINI Plaintiff vs. 0 C rv o -'per - -i (nr?- m z = S <Ct ? , =o 2p Z Z:- Qrn IN THE COURT OF COMMONOL OF CUMBERLAND COUNTY CIVIL ACTION - LAW JURY TRIAL DEMANDED PAMELA HAMMAKER Defendant NO. 11-CIVIL-3108 CERTIFICATE OF SERVICE I, JAMES M. FLOOD, ESQUIRE, do hereby certify that a true and correct copy of a Praecipe for Entry of Appearance and Demand for Jury Trial were served upon all parties this date via United States first class mail at the following address: Attorney for Plaintiff Michael E. Kosik, Esquire Angino & Rover, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 HUBSHMAN, CAREY & FLOOD Date: gy: JAM4-4(.n M. FLOOD, ESQUIRE Attorney for Defendant LAW OFFICES OF HUBSHMAN AREY & FLOOD By: JAMES M. FLOOD Attorney I.D.#70257 2200 Stafford Avenue, Suite 500 Scranton, PA 18505 Phone #570-961-7580 Attorney for Defendant SEYEDEH HOSSEINI Plaintiff VS. C7 0., rnw 2?s 'D A m O T ? C )-n C) CD _4m IN THE COURT OF COMMOOL 1 5 OF CUMBERLAND COUNTY CIVIL ACTION - LAW JURY TRIAL DEMANDED PAMELA HAMMAKER Defendant NO. 11-CIVIL-3108 CERTIFICATE OF SERVICE I, JAMES M. FLOOD, ESQUIRE, do hereby certify that Defendant's Interrogatories Addressed to Plaintiff and First Request for Production of Documents Addressed to Plaintiff were served upon all parties this date via United States first class mail at the following address: Attorney for Plaintiff Michael E. Kosik, Esquire Angino & Rover, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 HUBSHMAN, CAREY & FLOOD --I / 4) Date: By: 7 JAMES M. FLOOD, ESQUIRE Attorney for Defendant