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Home My WebLink About11-4991FILED -Gr i` i`. T'I`DE I' O TH1;Il''Ti°:i t } ! JUN 16 AM 11 ' CUMBERLAND C01'NT PF NNSYLV 1414 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 FRANCES E. COFFMAN, Plaintiff V. MORGAN LEE HARRIS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. //- Vf 9 / &OAJ 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 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 MAY BE 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 2 Liberty Avenue Carlisle, PA 17013 D (717) 249-3166 9a •oo pd• 4 ? ;2 G 4sv!r 46850 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se persentan mds adelante en las siguientes pdginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despuds de la notificaci6n de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar acci6n como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamaci6n o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Used puede perder dinero o propiedad u otros derechos importantes para used. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 46850 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 FRANCES E. COFFMAN, Plaintiff V. MORGAN LEE HARRIS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. JURY TRIAL DEMANDED COMPLAINT 1. Plaintiff Frances E. Coffman is an adult individual and citizen of the Commonwealth of Pennsylvania who resides at 610 South Broad Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant Morgan Lee Harris is an adult individual and citizen of the Commonwealth of Pennsylvania who resides at 1974 Randall Road, Enola, Cumberland County, Pennsylvania 17025. 3. The facts and occurrences hereinafter related took place on July 1, 2009, at the intersection of Route 114 and Shadow Oaks Drive, in Silver Spring Township, Cumberland County, Pennsylvania. 4. The intersection of Route 114 and Shadow Oaks Drive is controlled by a traffic signal. 5. At that time and place, Plaintiff Frances E. Coffman was driving a 2007 Subaru Forester on Shadow Oaks Drive attempting to cross Route 114 traveling east to west on a green traffic signal. 46850 6. At that time and place, Defendant Morgan Lee Harris was driving a 2002 Chevrolet Impala South on Route 114. 7. At that time and place, Defendant Morgan Lee Harris would have been approaching and facing a steady red signal 8. At that time and place, Defendant Morgan Lee Harris made a right hand turn onto Shadow Oaks Drive on a steady red light, entered the intersection and violently collided with the car Plaintiff Frances E. Coffman was driving. 9. The foregoing accident and all of the injuries and damages set forth hereinafter sustained by Plaintiff Frances E. Coffman are the direct and proximate result of the negligent, careless and reckless manner in which Defendant Morgan Lee Harris operated his vehicle as follows: (a) failure to appropriately stop for red traffic signal; (b) failure to remain stopped and yield the right-of-way to Plaintiff who was proceeding through the intersection on a green light; (c) failure to keep alert and maintain a proper watch for the presence of other motor vehicles on the highway; (d) failure to apply his brakes in sufficient time to avoid the colliding with the Plaintiff's vehicle; (e) failure to drive his vehicle with due regard for the highway and traffic conditions which were existing and of which he was or should have been aware; (f) failure to have proper and adequate control over his vehicle; (g) failure to take reasonable evasive action to avoid the accident and (h) driving his 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. 46850 10. As a direct and proximate result of the aforementioned accident, Plaintiff Frances E. Coffman sustained painful and severe injuries which include but are not limited to neck pain with numbness going down through the fingers, left wrist, elbow and left shoulder pain, headaches, and an aggravation of a previous back injury, trauma to her ribs as well as shock to her nervous system. 11. By reason of the aforesaid injuries sustained by Plaintiff Frances E. Coffman, she was forced to incur liability for medical treatment, medications, hospitalizations, physical therapy and similar miscellaneous expenses in an effort to restore herself to health and claim is made therefor. 12. Because of the nature of her injuries, Plaintiff Frances E. Coffman has been advised and, therefore, avers that she may be forced to incur similar expenses in the future, and claim is made therefor. 13. As a result of the aforementioned injuries, Plaintiff Frances E. Coffman 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. 14. As a result of the aforesaid injuries, Plaintiff Frances E. Coffman has been and in the future will be subject to great humiliation and embarrassment, and claim is made therefor. 15. Plaintiff Frances E. Coffman continues to be plagued by persistent pain and limitation and, therefore, avers that her injuries may be of a permanent nature, causing residual 46850 problems for the remainder of her lifetime, and claim is made therefor. WHEREFORE, Plaintiff Frances E. Coffman demands judgment against Defendant Morgan Lee Harris in an amount in excess of Fifty Thousand ($50,000.00) Dollars, exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. AN NER, P.C. ichael E. osik, Esquire I.D. 36513 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Attorney for Plaintiff 46850 VERIFICATION I, FRANCES E. COFFMAN, 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. WI S ?; ? Dated: ) a.?Q 14 Z0 ( j 203648 SHERIFF'S OFFICE OF CUMBERLAND COUNTY P, Ronny R Anderson .OX _ --? Sheriff Aop at 4? n,brr, r rn Jody S Smith t ?, Chief Deputy t CD ? 7f, U- --q CD -Ii- -'n Richard W Stewart > s? Solicitor F . aEF ,, r M _ c ra Frances E. Coffman I Case Number vs. 2011-4991 Morgan Lee Harris SHERIFF'S RETURN OF SERVICE 06/22/2011 09:22 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on June 22, 2011 at 2122 hours, she served a true copy of the within Complaint and Notice, upon the within namec defendant, to wit: Morgan Lee Harris, by making known unto himself personally, at 1974 Randall Road, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. MICHELLE GUTSHALL, DEPUTY SHERIFF COST: $43.44 June 23, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF ;Cj Coi.u,tyjuite Shf;riift. T2!?.^soft Inr,. David D. Buelr Prothonotary Office of the (Prothonotary Cum5errand County, Pennsylvania rkS. Sofionage, ESQ Solicitor th" '1/9 9/ CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE — THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square 0 Suite100 ® CarfiisCe, TA 0 (Phone 717 240-6195 0 Ea.,717 240-6573