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Home My WebLink About14-0985 Supreme Co c6 ennsylvania Cour Comm -o leas For Prothonotary Use Only: T C it 6S t •�--i y Docket No: ;y d County ( JJ The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: S Complaint 0 Writ of Summons Petition E Transfer from Another Jurisdiction Declaration of Taking C Lead Plaintiff's Name: Lead Defendant's Name: T Michelle Bishop Larry Hunte Dollar Amount Requested: Mwithin arbitration limits I Are money damages requested? 0 Yes 0 No (check one) Qoutside arbitration limits O N Is this a Class Action Suit? M Yes El No Is this an MDJAppeal? 0 Yes [0 No A Name of Plaintiff /Appellant's Attorney: Eric B. Brauer, Esquire ® Check here if you have no attorney (are a Self - Represented [Pro Se] Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS J Intentional Ell Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution F11 Debt Collection: Credit Card 0 Board of Assessment Motor Vehicle Debt Collection: Other El Board of Elections Nuisance rJ; Dept. of Transportation S Premises Liability Statutory Appeal: Other Product Liability (does not include r711 Employment Dispute: E mass tort) Slander/Libel /Defamation Discrimination C Other: ( Employment Dispute: Other El Zoning Board T Other: I Q Other: O MASS TORT ril Asbestos N Tobacco J Toxic Tort - DES Toxic Tort -Implant REAL PROPERTY MISCELLANEOUS Toxic Waste 0 Ejectment Common Law /Statutory Arbitration B I Other: 0 Eminent Domain /Condemnation E Declaratory Judgment 0 Ground Rent 0 Mandamus Fil Landlord /Tenant Dispute Non - Domestic Relations n Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY M Mortgage Foreclosure: Commercial Quo Warranto L- Dental _ 1 Partition Replevin 17 Legal [3 Quiet Title Other: 0 Medical 0 Other: 3 Other Professional: Updated 1 /1/2011 LAW OFFICES OF ERIC B. BRAUER FL-6 20 PH 1 6 By: Eric B. Brauer, Esquire CL'HBERLA Identification No. 43624 PENNSYL r"GUNTY 638 Newtown Yardley Road ANl Suite 2B Newtown, PA 18940 (215) 953 -9100 Attorney for Plaintiff, Michelle Bishop MICHELLE BISHOP COURT OF COMMON PLEAS 47 E. Penn Street CUMBERLAND COUNTY Carlisle, PA 17013 Civil Division VS. LARRY HUNTE 19 E. Orange Street Shippensburg, PA 17013 and CARISSA LAMEREAUX 19 E. Orange Street Q�j �V 1 Shippensburg, PA 17013 NO. 1 oCC77 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 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 32 South Bedford Street Carlisle, PA 17013 (717) 249 -3166 CA 61�6p-lsq d uff (� 3 �o I 8� 5 LAN's' OFFICES OF ERIC B. BRAUER • 777 TOWNSHIP LINE ROAD SUITE 120 • YARDLEY PA 19067 LAW OFFICES OF ERIC B. BRAUER By: Eric B. Brauer, Esquire Identification No. 43624 638 Newtown Yardley Road Suite 2B Newtown, PA 18940 (215) 953 -9100 Attorney for Plaintiff, Michelle Bishop MICHELLE BISHOP COURT OF COMMON PLEAS 47 E. Penn Street CUMBERLAND COUNTY Carlisle, PA 17013 Civil Division VS. LARRY HUNTE 19 E. Orange Street Shippensburg, PA 17013 and CARISSA LAMEREAUX 19 E. Orange Street Shippensburg, PA 17013 NO. CIVIL ACTION COMPLAINT 1. Plaintiff, Michelle Bishop, is an adult individual and citizen of the Commonwealth of Pennsylvania who resides therein at 47 E. Penn Street, Carlisle, Pennsylvania 17013. 2. Defendant, Larry Hunte, is an adult individual and citizen of the Commonwealth of Pennsylvania who resides therein at 19 E. Orange Street, Shippensburg, Pennsylvania 17257. 3. Defendant, Carissa Lamereaux, is an adult individual and citizen of the Commonwealth of Pennsylvania who resides therein at 19 E. Orange Street, Shippensburg, Pennsylvania 17257. LAW OFFICES OF ERIC B. BRAUER • 777 TOWNSHIP LINE ROAD • SUITE 120 • YARDLEY, PA 19067 { 4. At all times material to Plaintiff's cause of action, Defendant, Carissa Lamereaux, was the owner and Defendant, Larry Hunte, was the operator, possessor, maintainer and /or in control of a certain motor vehicle being then and there operated by said Defendant. 5. At all times material to this cause of action, Plaintiff selected the full tort option under 75 Pa.C.S. §1705 on her applicable insurance policy. 6. On or about April 17, 2012, Plaintiff, Michelle Bishop, was the operator of a certain motor vehicle which was lawfully and properly stopped on W. North Street at or near its intersection with N. Hanover Street in Carlisle, Cumberland County, Pennsylvania. 7. On the date aforesaid, Defendant, Larry Hunte, was traveling at a high rate of speed on N. Hanover Street at or near its intersection with W. North Street in Carlisle, Cumberland County, Pennsylvania. 8. On the. aforesaid date and location, Defendant, Larry Hunte, in a negligent and careless manner, while fleeing from the police, attempted to turn onto W. North Street and struck the Plaintiff's vehicle head on, as a result of which, Plaintiff, Michelle Bishop, was caused to suffer severe and permanent personal injuries as more particularly described below. 9. The negligence and carelessness of the Defendant consisted of the following: (a) failing to maintain an assured clear distance ahead; LA«v OFFICES OF ERIC B. BRAUER • 777 TOWNSHIP LINE ROAD • SUITE 120 • YARDLEY, PA 19067 (b) failing to maintain a proper lookout; (c) failing to have the vehicle under proper and adequate control; (d) operating the vehicle at a high and excessive rate of speed; (e) failing to regard the rights, safety and position of the Plaintiffs at the point aforesaid; (f) violating the statutes of the Commonwealth of Pennsylvania. relating to the operation of motor vehicles; (g) otherwise failing to exercise due care under the circumstances; (h) negligence, carelessness and recklessness in other acts as may be determined during the course of discovery to be conducted pursuant to the Pennsylvania Rules of Civil Procedure. Count I Plaintiff, Michelle Bishop vs,. Defendant, Larry Hunte 10. Plaintiff, Michelle Bishop, hereby incorporates by reference thereto, paragraphs one (1) through nine (9), inclusive,- as. if they were fully set forth at length herein. 11. As a result of the aforesaid, Plaintiff, Michelle Bishop, sustained injuries to her head, neck, back, body and limbs, her bones, cells, nerves, tissues, muscles and functions, including, -but not limited to, acute lumbar sprain and strain, lower extremity radiculopathy and acute L5 -S1 disc bulge and facet arthropathy resulting LA« OFFICES OF ERIC B. BRAUER • 777 TOWNSHIP LINE ROAD SUITE 120 • YARDLEY, PA 19067 in bilateral neuroforaminal sten03i3 some or all of which Plaintiff has been advised are or may be permanent in nature. 12. As a result of the accident aforesaid, Plaintiff has undergone great physical pain and mental anguish, and she will continue to endure same for an indefinite time in the future, to her great detriment and loss. 13. As a result of the accident aforesaid, Plaintiff has been compelled to expend large sums of money for medicine and medical care and attention in an effort to effect a cure of her aforesaid injuries, said expenses have or may exceed the sum recoverable under the limits in 75 P.S. §1711, and she will be compelled to continue to expend such sums for the same purposes for an indefinite time in the future, to her great detriment and loss. 14. As a result of the accident aforesaid, the Plaintiff has been unable to attend to her usual and daily duties and occupation, and she will be unable to attend to the same for an indefinite time in the future, to her great detriment and loss. 15. As a further result of the aforesaid, Plaintiff has suffered a loss and depreciation of her earnings and earning power, and she may continue to suffer same for an indefinite time in the future, to her great detriment and loss. WHEREFORE, Plaintiff, Michelle Bishop, claims damages against the Defendant, Larry Hunte, in an amount not in excess of Fifty Thousand ($50,000.00) Dollars, plus the costs of suit and such other further relief as is just and proper. LA« OFFICES OF ERIC B. BRAUER • 777 TOWNSHIP LINE ROAD • SUITE 120 • YARDLEY, PA 19067 Count II Plaintiff, Michelle Bishop vs. Defendant, Carissa Lamereaux 16. Plaintiff, Michelle Bishop, (hereinafter "Plaintiff ") hereby incorporate by reference hereto, paragraphs one (1) through nine (9), inclusive, as if they were fully set forth at length herein. 17. Defendant, Carissa Lamereaux, gave Defendant, Larry Hunte, permission to operate the aforesaid vehicle, a reasonable prudent person in said Defendant's position would not have granted such permission because of the incompetence of Defendant, Larry Hunte, to operate the aforesaid vehicle. 18. Plaintiff avers that all of Plaintiff's injuries and damages were directly and proximately caused by Defendant, Carissa Lamereaux's, negligent entrustment of the aforesaid vehicle to Defendant, Larry Hunte. 19. Plaintiff hereby incorporates by reference hereto, paragraphs ten (10) through fifteen (15), inclusive, -as if they were fully set forth at length herein. WHEREFORE, Plaintiff, Michelle Bishop, claim damages against the Defendant, Carissa Lamereaux, in an amount not in excess of Fifty Thousand ($50,000.00) Dollars, plus the costs of suit and such other further relief as is just and proper. E is B. trauer, Esquire Attorney for Plaintiff LANK OFFICES OF ERIC B. BRAUER • 777 TOWNSHIP LINE ROAD • SUITE 120 • YARDLEY, PA 19067 VERIFICATION MICHELLE BISHOP, Plaintiff herein, verifies that the facts set forth in the foregoing Civil Action are true and correct to the best of her knowledge, information and belief, and that false statements herein are made subject to the penalties of 18 Pa.'C.S. §4904, relating to unsworn falsification to authorities. V MICHELLE BISHOP DATE: LAW OFFICES OF ERIC B. BRAUER • 777 TOWNSHIP LINE ROAD - SUITE 120 • YARDLEY, PA 19067 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson E Sheriff '1'HE PRO H ONO I. yy,„,,of Jody S Smith Chief Deputy �` 38 Richard W Stewart Y `mY CUMBERLAND COUNTY Solicitor PENNSYLVANIA Michelle Bishop Case Number vs. 2014-985 Carissa Lamereaux(et al.) SHERIFF'S RETURN OF SERVICE 02/24/2014 02:02 PM-Deputy Dennis Fry, being duly sworn according to law, served the requested Complaint& Notice by handing a true copy to a person representing themselves to be Keisha Lamereaux, daughter, who accepted as"Adult Person in Charge"for Carissa Lamereaux at 19 E. Orange Street, Shippensburg, PA 17257. / DE IS FRY, 1 PU 02/24/2014 02:02 PM- Deputy Dennis Fry, being duly sworn according to law, served the requested Complaint& Notice by handing a true copy to a person representing themselves to be Keisha Lamereaux, adult in charge, who accepted as"Adult Person in Charge"for Larry Hunte at 19 E. Orange Street, Shippensburg Boro, Shippensburg, PA 17257. DE IS FRY UTY SHERIFF COST: $67.06 SO ANSWERS, February 25, 2014 RONNY R ANDERSON, SHERIFF ;LI^t- uh..,Sne. `eeosc. ....,. MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Allison M. Domday, Esquire PA ID No. 307547 Suite 201 100 Corporate Center Drive Camp Hill, PA 17011 Ph. 717-651-3538 Fax 717 -651 -3707 email: amdomday @mdwcg.com Our File No. 13166 -tba AMD Attorney for Defendants MICHELLE BISHOP COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. No. 14- 985 -Civil LARRY HUNTE and CARISSA LAMEREAUX CIVIL ACTION — LAW Defendants JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the undersigned on behalf of Defendants, Larry Hunte and Carissa Lamereaux, in the above captioned case. By: MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN Allison M. Domday, Esquire PA ID #307547 Attorney for Defendants Suite 201 100 Corporate Center Drive Camp Hill, PA 17011 Ph. 717 - 651 -3538 Fax 717- 651 -3707 Email: amdomday @mdwcg.com Dated: March 18, 2014 u.4 MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Allison M. Domday, Esquire PA ID No. 307547 Suite 201 100 Corporate Center Drive Camp Hill, PA 17011 Ph. 717-651-3538 Fax 717-651-3707 email: amdomday@mdwcg.com Our File No. 13166-tba AMD Attorney for Defendants MICHELLE BISHOP COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. No. 14-985-Civil LARRY HUNTE and CARISSA LAMEREAUX CIVIL ACTION — LAW Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Allison •M. Domday, Esquire, of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on March 18, 2014, I served a copy of Defendants' Entry of Appearance via First Class United States mail, postage prepaid as follows: Eric B. Brauer, Esquire 638 Newtown Yardley Road, Suite 2B Newtown, PA 18940 Attorney for Plaintiffs Allison M. Domday, Esquire LAW OFFICES OF ERIC B. BRAUER By: Eric B. Brauer, Esquire Identification No. 43624 638 Newtown Yardley Road Suite 2B Newtown, PA 18940 (215) 953-9100 Attorney for Plaintiff, Michelle Bishop MICHELLE BISHOP COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. Civil Division LARRY HUNTE and CARISSA LAMEREAUX NO. 2014-985 ORDER TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above -captioned matter SETTLED, DISCONTINUED and ENDED upon payment of your costs only. Eric B. Brauer, Esquire Attorney for Plaintiff LAW OFFICES OF ERIC B. BRAUER • 638 NEWTOWN YARDLEY ROAD • SUITE 2B • NEWTOWN, PA 18940