The URL can be used to link to this page

Home My WebLink About12-5262 ~f _ _ i 1 t ` ttz-a~ry~y r ALViN C. KRANTZ, ESQUIRE t~ , Identification No. 25348 ~ ~ ? 2 ~~J ~ ! ! • ~ 1515 Market Street ~ Suite 1807 `~~~;.~~=~2L~4'Q COUNTY ~~"t~S LVgMdA Philadelphia, PA 19102 (215) 557-0300 Attorney for Plaintiff 11TAM KWAK COURT OF COMMON PLEAS 41 BLUE SPRUCE DRIVE Cumberland County, PA ENOLA, PA 17025 Civil Trial Division V. VIVIAN ANNE JONES 1385 GERMANTOWN ROAD BLAIN, PA 17006 AND BRADLEY ALAN JONES 1385 GERMANTOWN ROAD BLAIN, PA 17006 No. S ~ ~ ~Ut NOTICE ADVISO You have been sued in court. If you wish to defend against the claims set Le hen demandado a usted en la torte. Si usted quiere fenderae de Batas forth in the following pages, you moat take action within twenty (20) days demandas expuestas en les paginae aiguientas, usted ti ne veinte (20) dies after this complaint and notice ere served by entering a written appearance de piezo al partir de la fecha de la demands y la notifi cion. Hate faits personally or by attorney and filing in writing with the court your defenses asentar una comparencia eacrita o en persona o con un ado y entregar or objections to the claims set forth against you by the court without further a la torte en forma eacrita sus defenses o sus objecionea lea demendas en Aotice for any money claimed in the complaint or for any other claim or relief contra de au persona. See avdeado que ai usted no ae efienda, la torte requested by the plaintiff. You may lose money or property or other rights tomara medides y puede continuer la demands en con a soya sin previo important to you. aviso o notification. Ademas la torts purde decidrr a fav r del demandante y requiere que uated cumpia con todea las proviaiones a seta demands. Ueted puede perder dinero o Bus propiedndea u otros de ethos importantea YOU SHOULD TAKE THIS TO YOUR LAWYER AT ONCE. IF YOU DO NOT pare usted. HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELE-PHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LLEVE ESTA DEMANDA A UN ABROGADO IMMEDIA AMENTE. SI NO LEGAL HELP. TIENE ABROGADO O SINO TIENE ELDINERO SUFIC NTE DE PAGAR CUMBERLAND COUNTY BAR ASSOCIATION TAL SERVICO. VAYA EN PERSONA O LLAME POR LEFONO A LA LAWYER REFERRAL and INFORMATION OFICINA CUYA DIRECCION SE ENCUENTRA ESC ABAJO PARR 32 S. Bedford Street AVERIGUAR DONDE SE PUEDE CONSRGUIR ASIS NCIA LEGAL. Carlisle, PA Asociecion De Licenciados De Cumberl d (717) 249-3166 Servicio De Referencia E Information L el 32 S. Bedford Street, Carlisle, Pennayly 'a Telefono: (717) 249-3166 p3, ~S asp # a II - _ ~ ALVIN C. KRANTZ, ESQUIRE Identification No. 25348 1515 Market Street Suite 1807 Philadelphia, PA 19102 (215) 557-0300 Attorney for Plaintiff NAM COURT OF COMMON PLEAS 41 BLUE SPRUCE DRIVE Cumberland County, PA ENOLA, PA 17025 Civil Trial Division V. . VIVIAN ANNE JONES 1385 GERMANTOWN ROAD BLAIN, PA 17006 . AND . BRADLEY ALAN JONES 1385 GERMANTOWN ROAD BLAIN, PA 17006 No. CIVIL ACTION 2V -MOTOR VEHICLE 1. Plaintiff, Nam Kwak, is an individual who resides at 41 Blue Spruce Drive, Enola, PA 17025. 2. Defendant, Vivian Anne Jones, is an individual who resides at 1385 Germantown Road, Blain, PA 17006. 3. Defendant, Bradley Alan Jones, is an individual who resides at 1385 Germantown Road, Blain, PA 17006. 4. On January 31, 2011, plaintiff, Nam Kwak, did own, operate, possess and control a certain motor vehicle, which was involved in the accident hereinafter more fully set forth. II _ T i 5. On January 31, 2011, defendant, Vivian Anne Jones, did operate, possess and control a certain motor vehicle, which was involved in the accident hereinafter more fully set forth. 6. On January 31, 2011, defendant, Bradley Alan Jones, did own, posses and control a certain motor vehicle, which was involved in the accident hereinafter more fully set forth. 7. It is believed and averred that the defendant owner, Bradley Alan Jon s negligently and carelessly entrusted the aforesaid motor vehicle involved in this accident to defendant operator, Vivian Anne Jones. 8. On January 31, 2011, the motor vehicle owned and operated by plaintiff, Nam Kwak, was proceeding in a southerly direction on East Penn Drive at r near its intersection with Wertzville Road, public highways in the Township of East Pennsboro, County of Cumberland, Commonwealth of Pennsylvania, at which time plaintiff's motor vehicle was struck by the motor vehicle so carelessly and negligent y being operated by defendant, Vivian Anne Jones and owned by defendant, Bradley Alan Jones, which said motor vehicle was proceeding in a easterly direction on Wertzville Road, failed to stop for a red traffic signal. As a result of this severe collision, plaintiff, Nam Kwak, sustained a serious impairment of a bodily function, hereinafter more specifically set forth. 9. At the time and place aforesaid, the carelessness and negligence of th defendant consisted of the following: (a) Operating the said motor vehicle at a rate of speed which was hig and dangerous under the circumstances; II _ _ _ ~ i (b) Failing to have said motor vehicle under proper and adequate control; (c) Failing to give proper and sufficient notice of its approach; (d) Failing to exercise due care and caution under the circumstances; (e) Operating the said motor vehicle without due regard for the rights safety and position of the plaintiff; (f) Failing to keep a proper lookout under the circumstances; (g) Violating the various Ordinances and Laws of the County of Cumberland, and the Statutes of the Commonwealth of Pennsylvania pertaining to the operation and control of motor vehicles; (h) Violating the Assured Clear Distance Rule; 10. As a direct result of the carelessness and negligence of the defendant as aforesaid, plaintiff, Nam Kwak, sustained severe and permanent internal and external injuries in and about the head, body and limbs, more particularly: right shoulder, low back, neck, chest and a severe and permanent shock to plaintiffs nerves and nervous system, all of which have caused her and will continue to cause her great pain and agony, and have prevented her and will continue to prevent her i the future from attending to his daily duties and activities, all to plaintiffs great financial damage and loss. 11. Plaintiff, Nam Kwak, avers that as a direct result of the carelessness negligence of the defendants as aforesaid, she has sustained injuries, as a result of which, she has been required and obliged to receive and undergo medical attentio II _ _ ~ and care, and will incur various medical expenses, to which plaintiff is entitled to recover. ! 12. As a result of the accident aforesaid, plaintiff, Nam Kwak, has and will hereinafter incur additional financial expenses or losses, which will exceed amount which plaintiff may otherwise be entitled to recover under the Pennsylvania Financ al Responsibility Act. 13. As a further result of the accident hereinbefore described, plaintiff, N Kwak, was the owner of a 2004 Nissan Murano automobile, which was in excellent physical and mechanical condition. As a direct result of the carelessness and negligence of the defendants, plaintiffs automobile sustained extensive damage, requiring repair and replacement parts, in addition to labor charges, in the amount f $17,163.76, and declared a total loss, all to plaintiffs great financial damage and los . WHEREFORE, plaintiff, Nam Kwak, demands judgment against the defendants, Vivian Anne Jones and Bradley Alan Jones, jointly and severally in an amount in excess of Fifty Thousand Dollars ($50,000.00), plus interest and costs. r ALVIN ~ SQUIRE Attorney for Plaintiff r VERIFICATION m verifies that the statements made in th attached pleading are true and correct. Verifier understands that any fats statements herein are made subject to the penalties of 18 Pa. C.S. X4904 , relatin to unsworn falsifications to authorities. (Seal) DATE: I ~'Z ALVIN C. KRANTZ, ESQUIRE Identification No. 25348 '! 1515 Market Street Suite 1807 Philadelphia, PA 19102 (215) 557-0300 NAM KWAK V. . VIVIAN ANNE JONES AND . BRADLEY ALAN JONES COURT OF COMMON PLEAS Cumberland County, PA Civil Trial Division No. 12-5262 Civil PRAECIPE TO REINSTATE CIVIL ACTION COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint In Civil Action in the above matter. ALVIN-C. KRANTZ, ESQUIRE Attorney for Plaintiffs DATE : 10/ 19/ 12 ~~i M~ ~~'~,7.5~) a Q ~.~. ~ ~a c~~~