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Home My WebLink About12-7312IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION n Plain't'iffD(s) & Address(es) (.~//J 7~j l ~Ct/ ~i~i~D ~ 5 ~e~ ~~~ ~• y ~r vs. Defendant(s) & Address(es) D a.-r l~I ~ ~~iQ>Gn,~~'la.~n Case No. 1 p~' ~ ~ ~ a Civil Term Civil Action -.. ~ _ !~'`~ ...,.,j ~ ~~ z" _~ ~ ~ ~- ~_. ~~,, -< i Z rTY r ,,- ~ w ~ c~ '~ C % .~ C~ ~. C.: -,~ .~~:~ .$:: ~' --+ ~ ' _~: cx~ ia~ ~~,~s d~~y ~ . /1leu.~ Cum b-er/~I ~~.. r7o7d ~ PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue summons in the above case Writ of Summons shall be issued and forwazded to Attorn /Sheriff. lease Circle choice Date:~~ ~Sif~ature of Attorney Print Name: ///~ -~ '~i C,~ ~~CL../ y^ Address: ~ ~D ~~'~j~~Tr! ~~e ~l.(..~ ~ ~ ~D La ,,. ~ flLl.~ ~el ~ ~~ Telephone #: CP /d - g' ~O S~DO r 9~a~ Supreme Court ID Number: ~ ~^7- ~o~ • • • • • J '~Q WRI/T OnFlS/UMMONS _ / /~yD /_ / TO: Tr)GZ-Cl C~~P-c~J C~7CCf~'1,u-~/ lQ/!7 ~l ~GC~1'~/P~Jt° ~/ ~Q`i7,f~-~J~/J YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENC AN ACTION AGAINST YOU. Prothonotary/Clerk, Civil Division Date:._~.~~ _ Deputy av~~ `103. a~ a~ a~~~~a COMMONWEALTH OF PENNSYLVANIA COUNTY OF PHILADELPHIA SS VERIFICATION I, Mitchell S. Clair, Esquire, hereby state that I am the attorney in this action and verify that the statements made in the foregoing Writ of Summons are true and correct to the best of my knowledge, information and belief. I understand that the statements therein are made subject to the penalties of 18 PA. C.S.A. 4904 relating to unsworn falsification to authorities. MITCHELL S. CLAIR, ESQUIRE ATTORNEY FOR PLAINTIFF(S) LAW OFFICES OF MITCHELL CLAIR ATTORNEY FOR PLAINTIFF(S) BY: MITCHELL CLAIR,ESQUIRE ATTORNEY I.D.#49492 790 PENLLYN PIKE, SUITE 206 BLUEBELL,PA 19422 (610) 940-5400 CYNTHIA CHANGO COURT OF COMMON PLEAS 65 RED BARBERRY DRIVE CUMBERLAND COUNTY ETTERS,PA 17318 V. NO: 12-7312 00 THADDEY CHAMBERLAIN C:) 103 LEWISBERRY ROAD C:) NEW CUMBERLAND, PA 17070 CIVIL ACTION COMPLAINT 1. Plaintiff, Cynthia Chango, is an adult individual who resides at the above captioned address. 2. Defendant, Thaddey Chamberlain, is an adult individual who resides at the above captioned address. 3. On or about December 6, 2010, defendant, Thaddey Chamberlain, was operating a motor vehicle exiting the 1-83 ramp to the stop sign at Lowther and Maple Streets in the borough.of Lemoyne, in Cumberland County, when he negligently caused a collision with the motor vehicle being operated by plaintiff, Cynthia Chango. 4. The negligence,recklessness, and carelessness of defendants consisted inter alia,of the following: a. Failure to stop at a properly marked stop sign; ^ ~ b. Failing to yield the right of way; c. Failing to observe mucronuding traffic conditions; d. Operating said motor vehicle at an excessive speed under the circumstances; o. Failing to have said motor vehicle under proper and adequate control at the time; f. Failing tV observe surrounding traffic conditions; g. Operating said motor vehicle in a reckless manner without regard for the rights and safety of those lawfully upon the highway; b. Failing 0o exercise due and proper care; i. Failing to give proper and an{fioimot warning of the approaching of said motor 5. Due to all the suffered severe and permanent 'injuries 1oher beaduechbacb shoulders,arms, legs,hips and body,bones nerves and tissues uf her head,neck back,posterior thighs, arms, legs,hips and body,permanent loss ofbodily functions, serious permanent disfigurement,nervous shock and aggravation and/or exacerbation of all known and unknown pre-existing medical conditions, internal 'injuries of an � unknown nature, severe aches, pains, mental anxiety and anguish and u severe shock tn her entire nervous system and other injuries dxofuOsxteotofwhiubiunotyetknowvo. She has io the past and will in the future undergo severe pain and suffering as u result of which bmhas been in the past and will io the future be unable to attend her usual duties,all to her great fivaouioldetriment and loss. ' 6. Due to all the foregoing,plaintiff,Cynthia Chango, has been compelled, in order tn effectuate m cure for the aforesaid injuries,toezyeud )azg:aoznoofozuoeyfhrmoudiuincundznodiva{atteotion and may\e required to expend additional sums for the same purpose in the future. 7. Due tu all the foregoing, pluiudff, CvuthiaCbaogo has been prevented from attending his usual daily activities and duties, and may be so prevented for an indefinite period of time in the future, all tobio utdehimoantuud loss. 8. Due to all the foregoing, plaintiff, Cynthia Chango, has suffered physical pain, mental anguish, humiliation, and loss of life's pleasures, and he may continue to suffer same for an indefinite period of time in the future. WHEREFORE, plaintiff, Cynthia Chango, demands judgment against the Defendants in an amount in excess of the arbitration limits, together with the costs and disbursements of this action, and delay damages. LAW OFFICES OF MITCHELL CLAIR MITCHELL S. CLAIR,ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I am the plaintiff in this action and verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief. I understand that the statements therein are made subject to the penalties of 18 PA. C.S., Section 4904, relating to unsworn falsification to authorities. MITCHELL S. CLAIR ATTORNEY FOR PLAINTIFF