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Home My WebLink About04-3984 William P. Douglas, Esq. Supreme Court LD. #37926 Douglas Law Office 27 W. High St. Carlisle, PA 17013 Telephcme (717) 243-1790 Mary L. Rupp In the Court of Common Pleas of Plaintiff Cumberland County, Pennsylvania vs No.04- 39f>l{ Civil Term Caitlyn D. Bear 1097 Longs Gap Rd. Carlisle, PA 17013 Deferuklnt Civil action law Jury Trial Demanded Praecipe to Issue a Writ of Summons Dear Mr. Long: Please issue a writ of summons against the defendant, Caitlyn D. Bear. . 0\ q .\\ William P. Doug Attorney for date: August 12, 2004 fJ ~ ~7i~ 111 - -- C> g~~ ~ --c.. "_.~ "n ,:~ . It:) - i-' .. c Commonwealth of Pennsylvania County of Cumberland Mary L. Rupp In the Court of Common Pleas of Plaintiff Cumberland County, Pennsylvania vs No.04- J 9P'! Civil Term Caitlyn D. Bear 1097 Longs Gap Rd. Carlisle, P A 17013 Defendant Ovil action law Jury Trial Demanded Writ of Summons To: Caitlyn D. Bear 1097 Longs Gap Rd. Carlisle, P A 17013 You are hereby notified that Mary L. Rupp has brought an action against you. "--- ~n~P.L.rn-/1/2/VJ r De~~~ Prothonotary date: August 12, 2004 William P. Douglas, Esq. Douglas Law Office 27 W. High St. Carlisle, PA 17013-0261 717-243-1790 Attorney for Plaintiff SHERIFF'S RETURN - REGULAR CASE NO: 2004-03984 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND RUPP MARY L VS BEAR CAITLYN D SHANNON SUNDAY , Sheriff or Deputy Sheriff of Cumberland County, pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS BEAR CAITLYN D was served upon the DEFENDANT , at 1055:00 HOURS, on the 16th day of August , 2004 at CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 CAITLYN BEAR ONE COURTHOUSE SQUARE by handing to a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 .00 .00 10.00 .00 28.00 Sworn and Subscribed to before me this I~ day of J.f;t4..~~ d{}()'f A.D. /1 JJ a {h---j~ ~ '--t'1Prothonotary' So Answers: r~~~ R. Thomas Kline 08/17/2004 DOUGLAS LAW OFFICE By: ,,a~hf;,J~ Lrj~ -/~Pbty Sheriff J DOUGLAS LAW OFFICE 27 W. HIGH ST. POB 261 CARLISLE PA 17013 TELEPHONE 717-243-1790 WILUAM P. DOUGLAS, ESQ. Supreme Court I.D.# 37926 Mary L. Rupp In the Court: of Common Pleas of Plaintiff Cumberland County, Pennsylvania vs N o. ~l- 3984 Civil Term Caitlyn D. Bear Defendant Civil action law Jury Trial Demanded NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACfION WITHIN TWENTY DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATIORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECfIONS 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 MAYBE 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle PA 17013 717-249-3166 BY~~ DA IE: December 8, 2004 Complaint 1. The plaintiff, Mary L. Rupp, is an adult individual residing at 705 South Spring Garden St., Carlisle, Cumberland County, Pennsylvania. 2. The Defendant, CaitIyn D. Bear, is an adult individual residing at 1097 Longs Gap Rd., Carlisle, Cumberland County, Pennsylvania, 17013. 3. On or about, August 15, 2002, the plaintiff was a passenger in a vehicle, being operated in an northerly direction on SJR 0074 in the vicinity of the intersection with Easy Road. 4. At about the same time and place, the defendant was operating her vehicle in a northerly direction on the same roadway. 5. The defendant failed to control her vehicle and as a result struck the rear of the vehicle occupied by the plaintiff. 6. The impact occurred as a direct and proximate result of the defendant's negligence. 7. The defendant was negligent in the following respects: a) failing to maintain a proper lookout; b) failing to drive within the assured clear distance ahead; c) failing to operate her vehicle in a safe and prudent manner; d) failing to stop her vehicle before she collided with the plaintiff. 8. As a direct and proximate result of the negligence of the defendant the plaintiff was injured her injuries, include but are not limited to: a) injury to her nerves and nervous system; b) injury to her spine and supporting strudtures; c) chronic pain; d) damage to the patella requiring surgical removal e) torn rotator cuff requiring surgical repair. 9. As a result of her injuries, the plaintiff has incurred medical expenses in the past and may continue to incur the same in the future. 10. As a result of her injuries, the plaintiff has incurred great pain and suffering and will continue to incur the same in the future. 11. As a result of her injuries the plaintiff has incurred aggravation, inconvenience, disability, permanent scarring ~md a loss of life's pleasures, and will continue to incur the same in the future. 12. As a result of the injuries the plaintiff sustained, the plaintiff's economic horizons may be limited. Wherefore it is prayed that judgment be entered in favor of the plaintiff and against the defendant in an amount in excess of that requiring compulsory referral to arbitration. A jury trial is hereby demanded. December 8, 2004 AFFIDA VIT I hereby swear or affirm that the foregoing is true and correct to the best of my knowledge and/or information and belief. This is made subject to the penalties of 18 Pa.C.S.A. ~4904 relating to unsworn falsification to authorities. \"-~:- - Date: December 8, 2004 AFFIDAVIT I hereby swear or affirm that the foregoing is true and correct to the best of my knowledge and/or information and belief. This is made subject to the penalties of 18 Pa.C.S.A. ~4904 relating to unsworn falsification to authorities. W~~- Q ~ Date: December 8, 2004 ...., c) Q ,::..:."') -'1 c::Jo J;.- "-~ 0 "1'. -n '. , rq j;",- r~\~ '\ ( , C") 'T1 ~~"'~ r~~.) (.,.) ,) ~ ~j -11 \, " -.." "'., -~,. .i .j ~~~ ..-( -r-;" ~< N CO William P. Douglas, Esq. Supreme Court JD. # 37926 Douglas Law Office 27 W High St. Carlisle, PA 17013 Telephone (717) 243-1790 Mary 1. Rupp In the Court of Common Pleas of Plaintiff Cumberland County, Pennsylvania vs No. 04- 3984 Civil Term Caitlyn D. Bear 1097 Longs Gap Rd. Carlisle, PA 17013 Defendant Civil action law Jury Trial Demanded Praecipe to Settle and Discontinue Dear Mr. Long: Please mark the above captioned matter settled and discontinued. date: November 15, 2005 -;:,...., - 2j't "::. ~~!. u;l C:~ :..-- '6 "-( '-.. I-f'"? C~J 'R: