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Home My WebLink About02-0326LAW OFFICES OF YOUNG K. PARK BY: YOUNG K. PARK, ESQUIRE ATTORNEY I.D. NO. 60928 BY: JEFFREY S. WILSON, ESQUIRE ATTORNEY I.D. NO. 50503 1700 MARKET STREET, SUITE 2631 PHILADELPHIA, PA 19103 215-851-9740 ATTORNEY FOR PLAINTIFFS SEONG K. BAEK 75-06 Woodside Avenue, Apt. 2G Elmhurst, NY 11373 Vo Gui Nam Chung 4116 Parsons Blvd., Flushing, NY 11355-1914 COURT OF COMMON PLEAS CUMBERLAND COUNTY TERM. 2002 NO. PRAECIPE TO ISSUE WRIT OF SUMMONS TO THEPROTHONOTARY: Kindly issue a Writ of Summons - Civil Action to Gui Nam Chung in the above- captioned matter. Dated: January 17, 2002 LAW OFFICES OF YOUNG K. PARK ~_~omeys for Plaintiff Commonwealth of Pennsylvania County of Cumberland SEONG K. BAEK 75-06 WOODSIDE AVENUE, APT. 2G EL~URST, NY 11373 4116 PARSONS BLVD Flushing, NY 11355-1914 Court of Conunon Plea~ No. _ _2_ O p2:_ 3 _2 _6_ _c_ _i._v_iA .................. ~ .... In _ _ _CiYJ3. _b~ ............................... To -Gg- -'~ -N- -i~- - - -eli -u-Dq ............................. You are hereby notified that . __ _s_ _eP_ _n3_ _ _~_'_ ~ _a_e_k ............................................................................... the Plaintiff ha $ commenced an action in .... -C--i-v-i_l__A-_c_t_i_qg_-L-a-w- ................................ against you which you are required to defend or a default judgment may be entered against you. (SEAL) Date- _ _ _J_a_n_ _u_a_r~ _ _1_8.,_ _ _2 _0_0_2_ ....... 19 .... LAW OFFICES OF YOUNG K. PARK BY:YOUNG K. PARK, ESQUIRE ATTORNEY I.D. 60928 1700 MARKET STREET, SUITE 2631 PHILADELPHIA, PA 19103 2!5-851-9740 THIS IS NOT AN ARBITRATION MATTER Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SEONG K. BAEK 75-06 Woodside Avenue, Apt. 2G Elmhurst, NY 11373 NO. 2002-326 GUI NAM CHUNG 4116 Parsons Blvd. Flushing, PA 11355-1914 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 LAWYER REFERENCE SERVICE 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 LAW OFFICES OF YOUNG K. PARK BY: YOUNG K. PARK, ESQUIRE ATTORNEY I.D. 60928 1700 MARKET STREET, SUITE 2631 PHILADELPHIA, PA 19103 215-851-9740 THIS IS NOT AN ARBITRATION MATTER Attomey for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SEONG K. BAEK 75-06 Woodside Avenue, Apt. 2G Elmhurst, NY 11373 NO. 2002-326 GUI NAM CHUNG 4116 Parsons Blvd. Flushing, PA 11355-1914 CIVIL COMPLAINT 1. Plaintiff, Seong K. Baek is an adult individual residing at 75-06 Woodside Avenue, Apartment #2G, Elmhurst, NY, 11373. 2. Defendant, Gui Nam Chung is an adult individual residing at 4116 Parsons Blvd., Flushing, NY 11355-1914. 3. On or about January 23, 2000, Seong K. Baek was in the front passenger seat of the vehicle owned and operated by Gui Nam Chung traveling eastbound in the right lane on the SR-76 in Cumberland County when Gui Nam Chung lost control of the vehicle causing it to cross both lanes where it struck the concrete medial barrier. After the 1s~ impact, it spun 180 degree crossed both eastbound lanes resulting in a second impact with the concrete guard rail on the south beam. 4. Defendant had a duty of care towards Seong K. Baek and Defendant breached said duty negligently and carelessly causing serious injury and harm to Seong K. Baek. 5. Defendant breached the duties to Seong K. Baek and otherwise acted negligently and recklessly in the following particulars but not limited to: a) driving at unsafe speeds; b) driving in a manner whereby she did not have control over her vehicle; c) causing the collision with concrete medial barrier and concrete guard mil; d) failure to avoid the collision with concrete medial barrier and concrete guard rail; e) failure to operate the aforesaid motor vehicle at a safe speed under the conditions prevailing; d) failure to maintain proper and adequate control of the aforesaid motor vehicle; e) failure to be attentive while operating the aforesaid motor vehicle; f) Any additional causes in the control of or created by Defendant that contributed to Seong K. Baek's injuries; g) Any additional acts of negligence that may be discovered in the course of discovery or trial of this matter. 6. Defendant breaches of duties to Seong K. Baek and related acts of negligence and recklessness have caused Seong K. Baek severe, serious injuries and harm that constitute serious and permanent impairment of body function. 7. As a result of said accident, Seong K. Baek has and will continue to suffer from serious, severe and permanent injuries including but not limited to cervical spine derangement, bilateral rib contusion, low back derangement, right hip and femur strain, and post traumatic headaches. 8. As a result of the injuries aforementioned, the Plaintiff has suffered great physical pain and mental anguish and he will continue to suffer for an indefinite time in the future, to his great detriment and loss. 9. As a result of the injuries aforementioned, the Plaintiff has suffered a marked loss of earnings and diminution of his earning capacity for an indefinite time in the future, to his great detriment and loss in an amount which is or may be in excess of provision of 75 Pa. C.S. Section 1711. 10. As a further result of the injuries aforementioned, the Plaintiff has been unable to perform his usual and daily duties, occupations, avocations and labors, and he will continue to be so disabled for an indefinite time in the future, to his detriment and loss. 11. As a further result of the injuries aforementioned, the Plaintiff has been obliged to expend various and diverse sum of money in and about an effort to cure himself of his ills and injures and he will continue to be so obliged for an indefinite time in the future to his great detriment and loss in an amotmt which is or may be in excess of the provision of 75 Pa. C.S. Section 1711. 12. Further, the Plaintiff has suffered a loss of the enjoyment of his usual duties, life's pleasures and activities and a shortening of his life expectancy to his great detriment and loss. WHEREFORE, Plaintiff, Seong K. Baek respectfully request the Court enter an award of damages in his favor against Defendant, Gui Nam Chung in amounts in excess of Twenty Five 4 Thousand ($25,000.00) Dollars together with interest, cost, and any other relief the Court deems appropriate. Dated: February ~t, 2002 LAW OFFICES OF YOUNG K. PARK ~--~1 ~0°0mM~Y~fk°ertPi~ie~et~Suite 2631 Philadelphia, PA 19103 (215) 851-9740 5 VERIFICATION I, Seong K. Back, being duly sworn according to law depose and say that the facts set forth in the foregoing are tree and correct to the best of my knowledge, information and belief. This statement in made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unswom falsification to authorities. Seong K. Baek LAW OFFICES OF YOUNG K. PARK BY:YOUNG K. PARK, ESQUIRE ATTORNEY I.D. 60928 1700 MARKET STREET, SUITE 2631 PHILADELPHIA, PA ! 9103 215-851-9740 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW SEONG K. BAEK 75-06 Woodside Avenue, Apt. 2G Elmhurst, NY 11373 GUI NAM CHUNG 4116 Parsons Blvd. Flushing, PA 11355-1914 NO. 2002-326 ORDER TO MARK ACTION SETTLED, DISCONTINUE D AND ENDED TO PROTHONOTARY: Please mark the above action settled, discontinued and ended. Dated: June I~, 2002 ¢..rl