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HomeMy WebLinkAbout14-1402Supreme Court >of Pennsylvania Coin . oof Corn ion Pleas € vi1;Cover� Sheet 1114 re. C U MB ER-LAND LAND . ,.� � r County For Prothonotary Use Only: 1 �s'? Docket No: (11)4g 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 S C r I' Commencement of Action: Petition • ❑ Notice of Appeal Declaration of Taking ❑ Complaint X Writ of Summons • • Transfer from Another Jurisdiction • Lead Plaintiffs Name: Lead Defendant's Name: Adam E. Hummel 1 Joshua J. Kramarenko and Patrick J. Sheridan I Represented (Pro Se) Litigant • Check here if you are a Self- Name of Plaintiff /Appellant's Attorney: FrederiCk S. Long, Esquire Dollar Amount Requested: X within arbitration limits Are money damages requested? : RI Yes ❑ No (Check one) � outside arbitration limits Is this a Class Action Suit? • Yes © No S E C T I 0 N 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) Intentional ❑ Malicious Prosecution ❑ Motor Vehicle ❑ Nuisance ❑ Premises Liability ❑ Product Liability (does not include mass tort) ❑ Slander/Libel/ Defamation ❑ Other: C_ MASS TORT ❑ Asbestos ] Tobacco ] Toxic Tort - DES ❑ Toxic Tort - Implant ❑ Toxic Waste ❑ Other: PROFESSIONAL LIABLITY ❑ Dental ❑ Legal ❑ Medical ❑ Other Professional: f ) Pa.R.C.P. 205.5 CONTRACT (do not include Judgments) ❑ Buyer Plaintiff ❑ Debt Collection: Credit Card ❑ Debt Collection: Other ❑ Employment Dispute: Discrimination ❑ Employment Dispute: Other ❑ Other: REAL PROPERTY ❑ Ejectment ❑ Eminent Domain /Condemnation ❑ Ground Rent ❑ Landlord/Tenant Dispute ❑ Mortgage Foreclosure ❑ Partition ❑ Quiet Title ❑ Other: I - � CIVIL APPEALS Administrative Agencies ❑ Board of Assessment ❑ Board of Elections ❑ Dept. of Transportation ❑ Zoning Board ❑ Str atutory Appeal: Other f Judicial Appeals ❑ MDJ - Landlord/Tenant ❑ MDJ - Money Judgment ❑ Other: I � MISCELLANEOUS ❑ Common Law /Statutory Arbitration ❑ Declaratory Judgment ❑ Mandamus ❑ Non- Domestic Relations Restraining Order ❑ Quo Warranto ❑ Replevin ❑ Other: [ 1 2/2010 T IAL Frederick S. Long Pa.I.D. 314494 Siegrist, Koller, Brightbill, Long & Feeman 315 South Eighth Street Lebanon, PA 17042 Telephone: 717- 272 -6646 Facsimile: 717- 270 -9687 Email: flong @skblf.com f r'1 —° a.I' CE P 0 THi ONO TA IMF 1411AR —7 All 11: 3 CUMBERLAND COUNTY • PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ADAM E. HUMMEL, suijuris individual 128 Faith Circle Carlisle, PA 17013 Plaintiff Case No. q -' y r �12Civil Term Civil Acton in Tort V JOSHUA J. KRAMARENKO, suijuris individual; 24 Orchard Circle, Telford, PA 18969, and PATRICK J. SHERIDAN, suijuris individual; 4940 Grant Drive, Brookhaven, PA 19015, Defendants PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue summons in the above case. Writ of Summons shall be issued and forwarded to Sheriff. DATE: (344 1 rick S. Long 31 South Eighth Street banon, PA 17042 (717) 272 -6646 Supreme Court ID No. 314494 a,,4 CL4 J s &sa V__* 30aloao To: Joshua J. Kramarenko 24 Orchard Circle Telford, PA 18969 WRIT OF SUMMONS TO: Patrick J. Sheridan 4940 Grant Drive Brookhaven, PA 19015 You are hereby notified that Adam E. Hummel, plaintiff in the above matter, has commenced an action against you. Date:. Sh 2 Deputy PROTHONOTARY 1NAL Frederick S. Long Pa.I.D. 314494 Siegrist, Koller, Brightbill, 315 South Eighth Street Lebanon, PA 17042 Telephone: 717-272-6646 Facsimile: 717-270-9687 Email: flong@skblf.com ong & Feeman IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ADAM E. HUMMEL, sui juris individual 128 Faith Circle Carlisle, PA 17013 Plaintiff V JOSHUA J. KRAMARENKO, sui juris individual; 24 Orchard Circle, Telford, PA 18969, and PATRICK J. SHERIDAN, sui furls individual; 4940 Grant Drive, Brookhaven, PA 19015, Defendants Case No. /Civil Term Civil Acton in Tort ENTRY OF APPEARANCE TO THE PROTHONOTARY OF SAID COURT: Please enter the appearance of Frederick S. Long, Esquire, of Siegrist, Koller, Brightbill, Long & Feeman, whose address is 315 South Eighth Street, Lebanon, PA 17042, as Attorney for the Plaintiff, Adam E. Hummel, in the above captioned case. SIEGRIST, KOLLER, BRIGHTBILL, LONG AND FEEMAN By Date: f/, //L( Frederick ong, Esquire I.D. #314494 315 South Eighth Street Lebanon, PA 17042 (717) 272-6646 Attorney for Plaintiff, Adam E. Hummel Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard VVStewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY rh--O- -FC CI' THE PROTAO@O T��y �H\&&���� PH ^".,n/"�° ''' - -- CUMBERLAND OUNTY ot Cur ogFicE of THE *..HERvp Adam E Hummel vs. Joshua James Kramarenko (et al.) Case Number 2014-1402 SHERIFF'S RETURN OF SERVICE 03/10/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Joshua James Kramarenko, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Montgomery, Pennsylvania to serve the within Writ of Summons according to Iaw. 03/10/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Patrick J Shoridan, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Delaware, Pennsylvania to serve the within Writ of Summons according to law. 03/23/2014 12:26 PM - The requested Writ of Summons served by the Sheriff of Delaware County upon Unnamed Adult, who stated her realtionship to defendant was Mother, who accepted for Patrick J Sheridan, at 4940 Grant Drive, Brookhaven, PA1QU15. Joseph F. McGinn, Sheriff, Return of Service attached to and made part of the within record. 04/02/2014 07:20 AM - The requested Writ of Summons served by the Sheriff of Montgomery County upon Jim Kramanenko, who accepted for Joshua James Kramarenko, at 24 Orchard Circle, Telford, PA 18969. Russell Bono, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $62.49 SO ANSWERS, April 21, 2014 �DNNYR ANDERSON, SHERIFF itioo309S, Ronny R Anderson Sheriff Jody S Smith Chief Deputy *I= SHERIFF'S OFFICE OF CUMBERLAND COUNTY Q( Ciun OFFICE OF THE SHERIFF' Richard W Stewart Solicitor Adam E Hummel vs. Joshua James Kramarenko (et al.) Case Number 2014-1402 0 • ! • Service Details: • Category: • Manner: w Notes: a) co SERVICE COVER SHEET !Civil Action - Writ of Summons Deputize Expires: 04/04/2014 Zone: Warrant: I • Serve To: • Name: Joshua James Kramarenko cc 0 u. .Primary —J w Address: ui Phone: ce 3 Alternate O Address: ce I Phone: O Ottomey / Originator: 24 Orchard Circle Telford, PA 18969 DOB: [Final Service: Served: Adult In Charge: Relation: Date: Deputy: Personally Posted • Other Time: 5 Mileage: C■1 0 4 O KRAMARENKO1 JOSHUA J. Name: [Frederick S Long Service Attempts: Date: Time: Mileage: Deputy: Phone: - 4 717-272-6646 Notes / Special Instructions: ' - C.) MIC 3C) rn m c5 • *--1 I r I I Now, March 10, 2014 I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff ofrgory Carty tc (/) execute service of the documents herewith and make return thereof according to law. 1:9 rn Return To: Cumberland County Sheriffs Office One Courthouse Square Carlisle, PA 17013 (c)CourrySiure Sheriff, Te:eoson. Inc Ronny R Anderson, Sheriff Ronny R Anderson Sheriff Jody S Smith Chief Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY 41/15-‘r1iPt t7;7 7) 0,Aoy Qt Clunth,v.47 OFFICE OF TRE SRERIFF 347-1h/ tewart icitor Adam E Hummel VS. Joshua James Kramarenko (et al.) Case Number 2014-1402 rService Details: 0 0 I0 0 a) Category: Manner: Notes: SERVICE COVER SHEET Civil Action - Writ of Summons Deputize , Expires: 04/04/2014 Zone: Warrant: a. i- t Serve To: Name: 'Patrick J Sheridan Primary 4940 Grant Drive Address: IBrookhaven, PA 19015 0 0 ca Phone: LU ce Alternate o Address: 1- < Phone: DOB: 0 o LAItorney- Originator: Name: [Frederick S Long Service Attempts: Date: Csi Time: 0 Mileage: a Deputy: E2 <IC a, Now, March 10, 2014 I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of Delaware County to z execute service of the documents herewith and make return thereof according to law. E Return To: Cumberland County Sheriffs Office cn One Courthouse Square Carlisle, PA 17013 [final ServiCe: Served: Personally Adult In Charge Posted • Other Adult In Charge: Relation: Date: Deputy: Time: Mileage: Notes / Special Instructions: (e) CountyStae Stff. Teeozoli, inc. Ronny R Anderson, Sheriff ORIGINM, LONG BRIGHTBILL ATTORNEYS AT LAW FREDERICK S. LONG, ESQUIRE Attorney I.D. No. 314494 315 South Eighth Street Lebanon, PA 17042 Telephone No.: (717) 272-6646 Fax No.: (717) 270-9687 flong@skblf.com Attorney for Adam E. Hummel, Plaintiff ADAM E. HUMMEL, Plaintiff vs. JOSHUA J. KRAMARWNKO and PATRICK J. SHERIDAN, Defendants TO: JOSHUA J. KRAMARENKO 24 ORCHARD CIRCLE TELFORD, PA 18969 AND PATRICK J. SHERIDAN 4940 GRANT DRIVE BROOKHAVEN, PA 19015 FILED -OFFICE OF THE PROTHONOTARY 2014 OCT 10 PM 2 28 CUMBERLAND COUNTY PENNSYLVANIA : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, :PENNSYLVANIA : CIVIL TERM : File No. 14-1402 Civil Term 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 the 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 1 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 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 Frederick S. Long, Esquire (I.D. #314494) Long Brightbill Attorneys at Law 315 South Eighth Street Lebanon, PA 17042 Telephone (717) 272-6646 Attorney for Plaintiff, Adam E. Hummel AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Lebanon County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. 2 LONG BRIGHTBILL ATTORNEYS AT LAW FREDERICK S. LONG, ESQUIRE Attorney I.D. No. 314494 315 South Eighth Street Lebanon, PA 17042 Telephone No.: (717) 272-6646 Fax No.: (717) 270-9687 flong@skblf.com Attorney for Adam E. Hummel, Plaintiff ADAM E. HUMMEL, Plaintiff vs. JOSHUA J. KRAMARWNKO and PATRICK J. SHERIDAN, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, :PENNSYLVANIA : CIVIL TERM : File No. 14-1402 Civil Term COMPLAINT AND NOW, comes the Plaintiff, Adam E. Hummel, by and through his attorneys, Frederick S. Long, and the law firm of Long Brightbill, and respectfully presents the following: 1. Plaintiff is Adam E. Hummel, a sui juris individual, with an address of 1011 Bennett Avenue, Colorado Springs, Colorado, 2. Defendants are Joshua J. Kramarenko, a sui juris individual, with an address of 24 Orchard Circle, Telford, PA 18969, and Patrick J. Sheridan, a sui juris individual, with an address of 4940 Grant Drive, Brookhaven, PA 19015. 3. The events as described herein, excluding Plaintiff s treatment, all related to the instant Action, occurred on or about August 26, 2012 at or near the areas of 52 Richard Avenue 1 and 216 North Queen Street in Shippensburg, Cumberland County, Commonwealth of Pennsylvania, giving this Honorable Court jurisdiction over this matter. 4. On or about August 26, 2012, Plaintiff was lured to a residence located at or near 52 Richard Avenue. 5. Plaintiff was invited to the residence via a series of text messages being sent from Defendant Patrick J. Sheridan's cellular phone. 6. The aforementioned text messages, sent from Defendant Patrick J. Sheridan's cellular phone purported to be from a female that Plaintiff had accompanied to a local bar/restaurant the prior evening. 7. Upon arriving at the aforementioned residence, Plaintiff sent a text message to a telephone number that he believed belonged to the aforementioned friend, informing her that he had arrived at the residence. 8. Thereafter, Plaintiff received a text message in response, being sent from Defendant Patrick J. Sheridan's cellular phone, which advised Plaintiff to enter the residence. 9. Plaintiff entered the residence and was immediately assaulted. 10. The residents and/or occupants at 52 Richard Avenue, including Defendants herein, pulled Plaintiff inside the entryway of the residence and began punching and kicking Plaintiff on or about the head, torso, and legs. 11. While inside the entryway of the residence located at 52 Richard Avenue, Plaintiff dropped his cellular phone, which was later recovered by Plaintiff, but was no longer functional. 2 12. Plaintiff was able to break free from the assailants, including Defendants herein, and to retreat outside of the residence located at 52 Richard Avenue. 13. Upon retreating to the street on Richard Avenue, Defendants caught up to Plaintiff and pushed him to the ground. 14. While Plaintiff was on the ground, Defendants began kicking and punching Plaintiff in the head, face and torso areas. 15. During the altercation, Plaintiff suffered multiple injuries including, but not limited to, cuts to his face and head, a broken nose, and at least one broken rib. 16. Plaintiff was able to identify Defendant Joshua J. Kramarenko as a subject that assaulted him. 17. Plaintiff was able to identify Defendant Patrick J. Sheridan as a subject that assaulted him. 18. Defendant Joshua J. Kramarenko was charged criminally, and on December 17, 2013, he entered a guilty plea to Hindering Apprehension or Prosecution — False Information to a Law Enforcement Officer, pursuant to 18 Pa.C.S.A. § 5105(a)(5), and entered a Nolo Contendere plea to Simple Assault, pursuant to 18 Pa.C.S.A. § 2701(a)(1). 19. Defendant Patrick J. Sheridan was charged criminally, and on December 17, 2013, Defendant Patrick J. Sheridan entered a guilty plea to charges of Simple Assault, pursuant to 18 Pa.C.S.A. § 2701(a)(1), and Conspiracy to Commit Simple Assault, pursuant to 18 Pa.C.S.A. § 903(c)/§2701(a)(1). 3 20. Both Defendants named herein did commit acts intended to cause Plaintiff to suffer a harmful or offensive contact or to suffer apprehension that such contact was imminent. 21. Plaintiff did suffer harmful or offensive contact at the hands of both named Defendants. 22. Plaintiff was placed in fear that harmful or offensive contact was imminent. 23. The aforementioned harmful contact was the direct and proximate result of Defendants' intentional actions, more specifically described as follows: a. Luring Plaintiff to a residence with the intent of causing him harm; b. Pulling Plaintiff inside said residence with the intent to cause him harm; c. Striking and/or kicking Plaintiff on or about the head, face, and torso with the intent to cause him harm; d. Chasing Plaintiff into the street with the intent to cause him harm; e. Further striking and/or kicking Plaintiff on or about the head, face, and torso with the intent to cause him harm; f. Forcing Plaintiff to another residence with the intent to cause him harm; g. Further striking and/or kicking Plaintiff while forcing him to the second residence with the intent to cause him harm; 24. Defendants' intentional conduct was the direct and proximate cause of injuries suffered by Plaintiff 4 COUNT 1 25. Plaintiff incorporates by reference all of the preceding Paragraphs to this Complaint as if each and every one was individually set forth below. 26. As a direct and proximate result of Defendants' intentional actions, Plaintiff suffered severe injuries, including but not limited to: a. Broken nose; b. At least one broken rib; c. Severe bruising to the face; d. Excessive bleeding; e. Scratches to the face; f. Bruising on the chest; g. Bruising on the torso; 27. As a direct result of Defendants' intentional actions, Plaintiff has incurred medical bills and expenses and will require further treatment for his injuries in the future. 28. As a direct result of Defendants' intentional actions, Plaintiff has suffered, and may continue to suffer, a loss of earnings. 29. As a direct result of Defendants' intentional actions, Plaintiff has undergone in the past, and may continue to undergo in the future, continued great pain and suffering. 30. As a direct result of Defendants' intentional actions, Plaintiff may have suffered a permanent disability and a permanent impairment of his earning capacity. 5 31. As a direct result of Defendants' intentional actions, Plaintiff may have sustained a permanent diminution in the ability to enjoy life and life's pleasures. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter judgment in Plaintiff's favor and against Defendant in an amount in excess of $50,000.00 and in excess of the compulsory arbitration limits, plus fees, costs, and other relief as this Honorable Court may deem appropriate. Date: //A 40/V Respectfully submitted, LONG BRIGHTBILL By Frederick S. EVg,`Esquire (I.D. #314494) 315 South Eighth Street Lebanon, PA 17042 (717) 272-6646 Attorney for Plaintiff, Adam E. Hummel 6 VERIFICATION I, Adam E. Hummel, the undersigned, the within named Plaintiff, verify that the statements made in this document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn • falsification to authorities. Adam E. Hummel 7 LONG BRIGHTBILL ATTORNEYS AT LAW FREDERICK S. LONG, ESQUIRE Attorney I.D. No. 314494 315 South Eighth Street Lebanon, PA 17042 Telephone No.: (717) 272-6646 Fax No.: (717) 270-9687 flong@skblf.corn Attorney for Adam E. Hummel, Plaintiff ADAM E. HUMMEL, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, :PENNSYLVANIA vs. JOSHUA J. KRAMARWNKO and PATRICK J. SHERIDAN, Defendants : CIVIL TERM File No. 14-1402 Civil Term PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY OF SAID COURT: Please reinstate the Complaint and Notice in the above captioned matter, on behalf of the Plaintiff, Adam E. Hummel. Date: J / Cp �i y Respectfully submitted, LONG BRIGHTBILL By rederick S. Lo g, Esquire (I.D. #314494) 315 South Eighth Street Lebanon, PA 17042 �� (717) 272-6646 Attorney for Plaintiff, Adam E. 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