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HomeMy WebLinkAbout14-7359 Supreme Court o ennsylvania Con -Com mon Pleas For Prothonotary Use Only: CIAl Cbec$h t Docket No: , C ' llandt County 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 x' Complaint M Writ of Summons Petition Transfer from Another Jurisdiction r,1 Declaration of Taking E `-, Lead Plaintiff's Name: Lead Defendant's Name: Geico a/s/o Sandra Harper Anthoney Gusler T Dollar Amount Requested: Swithin arbitration limits I Are money damages requested? El Yes 0 No (check one) J outside arbitration limits O N Is this a Class Action Suit? El Yes 0 No Is this an MDJAppeal? Yes El No A Name of Plaintiff/Appellant's Attorney: William A.Addams 0 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 ® Intentional 0 Buyer Plaintiff Administrative Agencies ® Malicious Prosecution 0 Debt Collection:Credit Card ©J Board of Assessment x� Motor Vehicle 13 Debt Collection:Other 0 Board of Elections Nuisance Dept.of Transportation 13 Premises Liability Statutory Appeal:Other S ® Product Liability(does not include E mass fort) 0 Employment Dispute: C [ISlander/Libel/Defamation Discrimination Other: 0 Employment Dispute:Other 0 Zoning Board � Other: ,I, I ril Other: O MASS TORT D Asbestos N Tobacco Toxic Tort-DES 0 Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS 13 Toxic Waste 0 Ejectment 13 Common Law/Statutory Arbitration B n Other: Eminent Domain/Condemnation r_1 Declaratory Judgment 0 Ground Rent [ Mandamus 13 Landlord/Tenant Dispute 0 Non-Domestic Relations Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY Mortgage Foreclosure:Commercial 0 Quo Warranto ® Dental Partition 0 Replevin ® Legal Quiet Title ®Other: Medical Other: Other Professional: Updated 1/1/2011 J w r IN THE COURT OF COMMON PLEAS OF CUMBERLAND No. COUNTY,PENNSYLVANIA Geico a/s/o Sandra J. Harper 3 Plaintiff c—) r vs _ Civil Action - Law Anthony D. Gusler .s - Defendant w _; 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 AN 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH 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 REDUECED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE,PA 17013 1-800-990-9108 717-249-3166 S ` Q � �Z.�31y q oS ATTORNEY ID#06265 10 W.HIGH ST. CARLISLE PA 17013 TELEPHONE 910-553-4127 GEICO as subrogee of Sandra J. In the Court of Common Pleas of Harper, Cumberland County, Pennsylvania Plaintiff vs. No. Anthony D. Gusler, Defendant Civil Action-Law COMPLAINT AND now comes the plaintiff, GEICO,by its attorney,William A. Addams, and respectfully represents the following: 1. The plaintiff, GEICO, is a corporation authorized to conduct insurance business in the Commonwealth of Pennsylvania with its offices and principal place of business at One GEICO Boulevard,Fredericksburg,VA 22412-0001. 2. The defendant, Anthony D. Gusler, is an adult individual residing at 29 Riverview Drive, Enola,PA 17025 3. The plaintiff issued a policy of automobile insurance covering Sandra Harper of Enola,Pa. which was in effect on January 14, 2014. 4. Ms. Harper was the owner of a 2010 Nissan which, on the aforesaid date, was traveling north on Magaro Road in East Pennsboro Township approaching the intersection with Riverview Drive. 5. At that time and place Defendant Gusler was driving a Volvo traveling west on Riverview approaching the stop sign on Magaro Road when he negligently and carelessly failed to stop and collided with the Nissan causing the damages hereinafter set forth. 6. The defendant was negligent and careless in: a. Failing to maintain a proper lookout; b. Failing to yield the right of way; C. Failing to observe the other vehicle in time to avoid a collision; d. Failing to have the vehicle under control; and e. Failing to stay in the correct lane of traffic. 7. As a result of the negligence and carelessness of the defendant, the Nissan was a total loss. The vehicle had an actual cash value of $12,587.29 and a net salvage value of $598.00 resulting in a loss of $11,989.29. In addition there was rental expense of$1737.38. 8. Geico paid the above losses and is subrogated to the rights of its insured. WHEREFORE, the plaintiff demands judgment against the defendant in the amount of $13,726.67 plus interest and costs of suit, an amount within the jurisdiction of arbitration under the local rules of court. William A. Addams Attorney for the Plaintiff December 23, 2014 VERIFICATION William A. Addams hereby verifies that he is the attorney for the Plaintiff corporation, which is outside the jurisdiction of the court, that he is authorized to and does make this verification on its behalf, and that the facts set forth in the foregoing Complaint are true and correct to the best of his knowledge, information and belief. He understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsifications to authorities. Date: December 23, 2014 . Wiliam A. Addams Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY QFFICE TV, uk`ZIFF J' —7 f'i' 2: fir r`3 a,jri••—r L.U�'iQLr\LA1`:J &. U'j : 3 PENNSYLVANIA Geico a/s/o Sandra J. Harper vs. Anthony D. Gusler Case Number 2014-7359 SHERIFF'S RETURN OF SERVICE 12/29/2014 09:00 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Anthony D. Gusler, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Found" at 29 Riverview Drive, East Pennsboro Township, Enola, PA 17025. Deputies were advised by defendant's aunt that the defendant moved out a year ago and is believed to be residing in Marysville, PA but she was unsure of the address. SHERIFF COST: $50.44 SO ANSWERS, December 30, 2014 RONNY R ANDERSON, SHERIFF (c) CourtySuiie Sheriff, Teleosoft, Inc.