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Home My WebLink About11-3393EtLED-OFFICE GF THE PROTHONOTARY 2011 APR - i AM 10: 32 CUMBERLAND COUNTY PENNSYLVANIA William C. Dissinger, Esquire 400 South State Road Marysville, PA 17053 (717) 957-3474 - Voice (717) 957-2316 - Fax STELLA SCHROYER, b05 Linden AWP1aintiff gv1'11e, P P+ 17659 VS. MATTHEW POWERY 11 &tenmQuhDefendant o- 7W. 2 ftola , ?4 I-)6) g IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION AT LAW NO. 13393 Ci PRAECIPE FOR WRIT OF SUMMONS TO The Prothonotary: Please issue writ of summons in the above-captioned civil action. Respectfully Submitted Dissinger & Dissinger By ? William Dissinger Supreme Kurt ID# 27737 400 South State Road Marysville, PA 17053 (717) 957-3474 ??a ooR1 Q a r38_'4?1o Q as-7 3y1 STELLA SCHROYER, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY PENNSYLVANIA VS. CIVIL ACTION AT LAW MATTHEW POWERY Defendant NO. WRIT OF SUMMNS TO Matthew Powery: You are notified that Stella Schroyer, the Plaintiff, has commenced an action against you. DATE: , Y' ` - Seal ;, the Court] )'(? Pr o t a r y By (Deputy) William C. Dissinger Attorney for Plaintiff Supreme Court ID# 27737 400 South State Road Marysville, PA 17053 (717) 957-3474 A William C. Dissinge.r, Esquire 400 South State Road Marysville, PA 17053 (717) 957-3474 - Voice (717) 957-2316 - Fax STELLA SCHROYER, Plaintiff VS. MATTHEW POWERY Defendant 6 JUN 14 PM 2: ; ?IENN'-_YUVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION AT LAW NO. 11-3393 JURY TRIAL DEMANDED N O T I C E T O D E F E N D 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 32 SOUTH BEDFORD STREET CARLISLE PA 17013 1-800-990-9108 717-249-3166 l ' illiam C. issnger, Esqu' e Attorney f Plaintiff William C. Dissinger, Esquire 400 South State Road Marysville, PA 17053 (717) 957-3474 - Voice (717) 957-2316 - Fax STELLA SCHROYER, Plaintiff VS. MATTHEW POWERY Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION AT LAW NO. 11-3393 JURY TRIAL DEMANDED COMPLAINT AND NOW comes the Plaintiff, Stella Schroyer, by and through their attorneys, Dissinger and Dissinger, and represent the following: 1. The Plaintiff is Stella Schroyer, who resides at 605 Linden Avenue, Marysville, Perry County, Pennsylvania 17053. 2. The Defendant is Matthew Powery, who resides at 71 Greenmont Drive, Enola, Cumberland County, Pennsylvania 17025. 3. On or about April 3, 2099, the Plaintiff was lawfully and carefully operating 2001 Saturn vehicle in a westbound direction on Wertzille Road in Cumberland County, Pennsylvania. 4. At the time, date and place, defendant negligently, recklessly and carelessly operated a 2000 Hyundai vehicle in a westbound direction so as to cause his car to collide with plaintiff's vehicle, causing serious injuries to plaintiff, as more fully describe herein. 5. At the time of the accident, the defendant was negligent, reckless and careless under the circumstances in: a. Failing to have his motor vehicle under proper and reasonable control; b. Operating his motor vehicle in such a manner as to cause it to collide into and against plaintiff's vehicle; c. Failing to give prompt, proper and adequate warning of his approach; d. Operating his motor vehicle without due regard to the presence and safety of the plaintiff; e. Failing to bring his motor to a stop in time to avoid the collision; f. Failing to operate his motor vehicle in a safe and proper manner; g. Failing to comply with the laws, rules and regulations of the Pennsylvania Motor Vehicle Code and the ordinances of the East Pennsboro Township pertaining to the operation of motor vehicles in or about the public highways; and h. Operating his motor vehicle at a high and excessive rate of speed under the circumstances. 6. As a result of the negligence, recklessness and carelessness of the defendant, the plaintiff was violently shaken and suffered severe and serious injuries to the bones, cartilages, ligaments, muscles, nerves and tissues of the body, including, strain and damage to the muscles of back and neck, spasms, and leg pain, all of which may be permanent. Plaintiff also suffered a sudden and violent shock to the nervous system, as well as aches, pains, mental anguish, shock and disability. 7. As a result of his injuries, plaintiff has been unable to undertake her normal duties and believes that she will continue to suffer impairments and disabilities in the future which will result in a decrease in her earnings and earning capacity. 8. As a further result of her injuries, plaintiff has sustained a diminution in her abilities to enjoy life and life's pleasures. WHEREFORE, the Plaintiff demands judgment against defendant in an amount in excess of $50,000.00, plus interest and costs. Respectfully submitted, DISSINGER & DISSINGER William C. i s n Esquir Attorney for Plaintiff Supreme Court ID # 27737 400 South State Road Marysville, PA 17053 (717) 957-3474 VERIFICATION I, Stella Schroyer, verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification. CAf 4L")(A tel a ch oye`, Plaintiff William C. Dissinger, Esquire 400 South State Road Marysville, PA 17053 (717) 957-3474 - Voice (717) 957-2316 - Fax STELLA SCHROYER, Plaintiff VS. MATTHEW POWERY Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION AT LAW NO. 11-3393 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE On this I ?E day of , 2011, I William C. Dissinger, Esqui e do hereby certify that I served a true and correct copy of Plaintiff's Co plaint upon the following and in the manner indicated below. Service was made by First Class Mail, addressed as follows: Joseph R. D'Annuzzio, Esquire 4309 Linglestown Road Suite 211 Harrisburg, PA 17112 Date: William C. issinger, Es r 0 William C. Dissinger, Esquire 400 South State Road Marysville, PA 17053 (717) 957-3474 - Voice (717) 957-2316 - Fax V,?, -g-OFFICE FIDN "fAR'? ur 20? F?a -a aM ?? oa CugERt Y?u ANuAj*y PENMS STELLA SCHROYER, Plaintiff VS. MATTHEW POWERY Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION AT LAW NO. 11-3393 JURY TRIAL DEMANDED PRAECIPE TO SETTLE, DISCONTINUE AND END Dear Sir: Please mark the above captioned case, settled, discontinued and ended. Respectfully submitted, DISSINGER & DISSINGER William C/ psi, E„e(uire Attorney or Plaintif Supreme Court ID # 27737 400 South State Road Marysville, PA 17053 (717) 957-3474 BY. Joseph R. D Annunzio Law Office of Joseph R. D Annunzio Identification No. 23384 4309 Linglestown Road, Suite 211 Harrisburg, PA 17112 (717) 901-5002 Fax: (717) 901-5012 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STELLA SCHROYER, Plaintiff, V. MATTHEW POWERY, Defendant. NO. 11-3393 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE i, Jessica Kurtz, do hereby certify that on this day of 6rocl^i- , 2012, I caused a true and correct copy of the Praecipe to Settle, Discontinue and End, to be served upon the following person listed below via first class United States mail, postage prepaid: William Dissinger, Esquire Dissinger Dissinger 400 South State Road Marysville, PA 17053 LAW OFFICE OF JOSEPH R. D'ANNUNZIO BY: J ssica Kurtz, Legal Secretary