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Home My WebLink About12-6395I 2138914 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Attorney for Plaintiff Nr-- - ?? cn Gc:; sv* P. n 3 Government Employees Insurance Company, Individually and as Subrogee on behalf of Travis K Goss One Geico Blvd COURT OF COMMON PLEAS CUMBERLAND COUNTY Fredericksburg VA 22412 and Travis K Goss 2773 Sparrow Hill Drive Columbus OH 43219 V5. CD T? DOCKET NO. : 102- U39 S 8-vi' ( Charles E Way 224 Reno Ave Apt A New Cumberland PA 17070 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 JUDGEMENT 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 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 CMk g?o3?'??? (,'Kul-1?'?(v 33 1 P4-- arn 19 U COMPLAINT IN CIVIL ACTION 1. Travis K Goss (the "Plaintiff"), is an adult individual residing at the address above captioned. 2. Plaintiff, Government Employees Insurance Company (`GEICO"), is a corporation duly authorized to conduct business within the Commonwealth of Pennsylvania, and is subrogated to the rights of the Plaintiff arising out of the within claim. 3. Charles E Way, (the "Defendant"), is an individual residing at the above-captioned address. 4. On or about October 14, 2010, the Plaintiff did own and possess a certain motor vehicle, involved in the accident hereinafter referred to. 5. On or about October 14, 2010, the Defendant did operate and control a certain motor vehicle, involved in the accident hereinafter referred to. 6. On or about October 14, 2010,the vehicle of the defendant was being operated in such a negligent and careless manner that it came into violent contact with the plaintiff's vehicle causing property damage to the Plaintiff's motor vehicle. 7. At the time and place aforesaid, the negligence and carelessness of the Defendant consisted of the following: a. Operating said vehicle at a high and excessive rate of speed under the circumstances; b. Failing to give proper and sufficient warning of the approach of said vehicle; C. Failing to have said vehicle under proper and adequate control at the time; d. Operating said motor vehicle without due regard for the rights, safety and position of the Plaintiff herein at the point aforesaid; e. Failing to sound a horn or other signaling device as to give warning to the plaintiff; f. Violating the rules and regulations of the road, ordinances of the County of CUMBERLAND, and the statutes of the Commonwealth of Pennsylvania; and g. Operating said vehicle without observing and heeding the road and traffic conditions then and there existing. 8. As a result of Defendant's negligent and careless operating of the motor vehicle, the plaintiff's motor vehicle sustained damages in the amount of $4,052.47 and Plaintiff sustained injuries resulting in a direct pay to Plaintiff by GEICO of $500.00 for medical expenses 9. At all times material hereto the plaintiff was insured by plaintiff, GEICO. 10. As a further result of the defendants' negligence, GEICO has made compensation for said property loss and medical expenses to the plaintiff. 11. Plaintiff GEICO individually and as subrogee on behalf of the plaintiff, Travis K Goss has paid money to the plaintiff for property damage and medical expenses in the amount of $4302.47. Travis K Goss paid a deductible in the amount of $250.00 for which plaintiff demands remuneration from the defendant. WHEREFORE, Plaintiff, Government Employees Insurance Company, claims damages from the Defendant, in the amount of $4,552.47, and/or any other damages this Honorable Court deems just and proper, including attorney's fees and court costs from the Defendant, for arbitration purposes only. GORDON & WEINBERG, P.C. BY: FREDERIC WEI ERG, ESQUIRE JOEL M. (LIN ESQUIRE Attorney r Plaintiffs POld 2138914 10/12/2012 11:05, „ .5402867295 GEICO PRU PAGE 06/06 --?-?' VERIFICATION a? (name) hereby states that he/she 3.s the /t?'CDr/el?`?? ?Sd? for the Plaintiff (a) in this action and verifies that the statements made In the foregoing ;:lead.in?? are true and correct to the best of his/her knowledge, information and belief. The. c.cndersigned understands that the statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to un:wo?rTI fal.si.fic,ation to authoritieo. (name) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~ ;.. ~; F Sheriff ~ `' ` t`I `' r ;= ~ `" f~~ ~r~r~ i ~~~~~~ ~ :,~ Jody S Smith ='~~' ~ ° ~ i i'R ~, ti' Chief Deputy L~ « (~(; ~ ~ ~ ~~ ~~ ~ ~ Richard W Stewart ~I~~g~iC~~l'~~ G~~~ i.` solicitor ~='E'r'~NS Y~.l,/{~ i°~ ( A Government Employees Insurance vs. Charles Way Case Number 2012-6395 SHERIFF'S RETURN OF SERVICE 10/22/2012 07:26 PN1 -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 22, 2012 at 1926 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Charles Way, by rriaking known unto himself personally, at 224 Reno Avenue, Apartment B, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to him personally the said true and correct copy of the same. = ~ .., r ..- ~ ~-_-_. ~. OAH CLINE, DEP SHERIFF COST: $45.00 October 23, 2012 SO ANSWERS, /~ , RON R ANDERSON, SHERIFF