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HomeMy WebLinkAbout05-3374WILLIAM A. ADDAMS, ESQUIRE ATTORNEY ID # 06265 27 W. HIGH ST. P.O. BOX 261 CARLISLE PA 17013 TELEPHONE 717-243-7638 NANCY HANNAH vs CHRISTIAN CAIN In the Court of Common Pleas of Plaintiff Cumberland County, Pennsylvania Defendant NOTICE No. C6-3V ivil Term Civil action law 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 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, 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 i William A. A dams Attorney for Plaintiff DATE: July 1, 2005 And now comes the plaintiff, Nancy Hannah by her attorney, William A. Addams, and makes the following Complaint The plaintiff is Nancy Hannah, an adult individual residing at 3008 Iona Terrace, Baltimore, MD 21214. 2. The Defendant is Christian Cain, an adult individual residing at 44 E. Frederick St., Dallastown, York County, Pennsylvania 17313. 3. The plaintiff is the owner of a Dodge Voyager which she was driving South on Route 24 at about 1:45 P.M. on July 3, 2003. 4. The defendant, Christian Cain, was traveling north when he negligently and carelessly attempted to turn left into Coventry at Waterford and collided with the Dodge causing the damages hereinafter set forth. 5. The defendant was negligent and careless in: a. failing to yield the right of way, b. turning left in the face of oncoming traffic, c. failing to have his vehicle under control, d. failing to observe the other vehicle in time to avoid a collision. As a result of the negligence and carelessness of the defendant, the plaintiffs vehicle sustained damage in the amount of $3,074.85, and the plaintiff incurred rental expense of $122.59. WHEREFORE, the plaintiff demands judgment in the amount of $3,197.44 plus interest and costs of suit, an amount within the jurisdiction of arbitration under the local rules of court. William A. Addams Attorney for Plaintiff VERIFICATION I, William A. Addams, do hereby verify that I am the Attorney of Record for the pleading party herein, and that the facts set forth in the foregoing pleading are true to the best of my knowledge, information, and belief, upon information supplied, and the verification of the party cannot be obtained within the time allowed for filing of the pleading. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unworn falsification to authorities. July 1, 2005 William A. Addams Attorney for Plaintiff 27 West High Street P.O. Box 261 Carlisle, Pa. 17013 717-243-7638 6- s 0 N Can ? -L F (,lJ SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2005-03374 P COMMOILTWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HANNAH NANCY VS CAIN CHRISTIAN R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT N CHRISTIAN but was unable to locate Him , to wit: in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania, to serve the within COMPLAINT & NOTICE On August 8th , 2005 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 York County 26.08 .00 63.08 08/08/2005 WILLIAM A. ADDAMS So answers R. Thomas Klink Sheriff of Cumberland County Sworn and subscribed to before me this - day of A.D. AA rdthonota COUNTY OF YORK OFFICE OF THE SHERIFF 45 N. GEORGE ST., YORK, PA 17401 SERVICE CALL (717) 771-9601 SHERIFF SERVICE I PLEASE WSTRWTIONS TYPE OONL L ft 1 THFdJ 12 PROCESS RECEIPT and AFFIDAVIT OF RETURN DO NOT DETACH ANY COPIES 1 PLAINTIFF/SI Nancy Hannah 2 COURT NUMBER 3. DEFENDANT/Sr - I rrc yr vw`u. vN t.vmrl_,slrv I Christian Cain Notice & Ccxnplaint SERE 5 NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED. ATTACHED. OR SOLD Christian Cain 6. ADDRESS (STREET OR RFD WITH BOX NUMBER. APT NO., CITY, BORO. TWP. STATE AND ZIP CODE) AT 44 E. Frederick Street Dallastown, PA 17313 7. INDICATE SERVICE'. ? PERSONAL U PERSON IN CHARGE DEPUTIZE 'U ERT. IL U 1ST CLASS MAIL U POSTED U OTHER NOW Ju1V 6 2005 I, SHERIFF OF COUNTY, PA, do hereby deputize the sheriff of York COUNTY to execute trt?plfmake return 'according to law. This deputization being made at the request and risk of the plaintiff., p 8. SPECIAL INFORMATION THAT WILL 4ef lll?_ Please mail return of service to Ctunberland r?r . q PTM r t Sheriff. Thank you. NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment. without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriffs sale thereof. 9. TYPE NAME and ADDRESS of ATTORNEY / ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER t 1. DATE FILED m. d7V?• i 4 • . 21x1lten?.r.,G P,¢170/3 aN3--71?3? 7-?-QS 12. SEND N TICE OF SERVICE OPY TO NAME AND AD ESS BELOW-. (This area must be co ete0 i notice is to be mailed). SPACE BELOW FOR USE OF THE SW W - 00 NOT BELOW THS LIE 13. I acknowledge int receipt the cum tt.,?(1TE RECE-If{ED ti q Islglll 19 Date or complaint as as moi ®ted above. // I 0' h 16 MOW SERVED: PERSONAL (y 17 RESIDENCE (;f POSTED( I POE ( ) SHERIFF'S OFFICE ( ) OTHER ( ) SEE REMARKS BELOW 17. ? 1 h e certify and return a FIIOT FOUND because Lam unable to locate the individual, company, etc. named above. (See remarks below.) / I I I Lit OF I AL SERVED / LIST R SS HERE I NOT SMO BO (Relationship to Defendant) 19. a of nice 20.7 of Se 21. ATTEMPTS Date Time de Int. Date Time Miles Int. Date Time Miles Inl Dale Time Mies Int Date Timell Miles! I Int. Dale Time Miles Int. 22. REMARKS: 23. v CCosts 211 $prvice Cysts L s 25. N/F 26, Mileage L 27. Postage 28. Su ? I 29. Pound 30 Noary 31. Surchg. 32 Td. Costs 33 Costs Du RNun ck N , O ( e ? o , I i 34. Foreign County Costa 35 Advance Costs ic 36. Serv Costs 37. Notary Cent. 38. MileageiPostage/No t Found 39. Total Costs 41:2 40 Costs Due or Refund 9 RS . :2 *1 SEAL N. p. Seri Of Oeig Sheriff - ? y q?q ?? CdY of York. YOrk Co, My COmmission Expires Apnl 20, 2006 TARY 46. Signature of YoAK County Sheriff 47. AT t?ILLiANI 1 'HOSE SiT1hI?IFFY s? 7/25/05 , / 48. Signature of Foreign 49 DATE (_ Y County Sheriff cwc rtcr.ur I ur I Nt antmr7-a Nt 1 DHN blUNAI URt 151. DATE RECEIVED AUTHORIZED ISSUING AUTHORITY AND TITLE 1. WHITE - Isawng Authority 2. PINK - Attorney 3. CANARY - Sheriffs Office 4 . BLUE - Sheriffs Office I E: I d L- k7 SOOT rd ', U.] A I 5 r.l WILLIAM A. ADDAMS, ESQUIRE ATTORNEY ID # 06265 27 W. HIGH ST. P.O. BOX 261 CARLISLE PA 17013 TELEPHONE 717-243-7638 NANCY HANNAH vs CHRISTIAN CAIN Sir: In the Court of Common Pleas of Cumberland County, Pennsylvania No 05-3374Civil Term Civil Action law PRAECIPE Please enter a default judgment in the amount of $3,197.44 in favor of the Plaintiff and against the Defendants for failure to enter an appearance or file an Answer to the Complaint endorsed with a Notice to Defend. The undersigned hereby certifies that the attached written notice of intention to file this praecipe was mailed to the defendant on the date shown thereon, which was after the default occurred and at lease ten (10) days prior to the filing of this praecipe. William A. Ad-dams Attorney for Plaintiff 27 W. High St. Carlisle, PA 17013 717-243-7638 TO: Curt Long, Prothonotary Plaintiff Defendant DATE: September 27, 2006 r t 1 WILLIAM A. ADDAMS, ESQUIRE ATTORNEY ID # 06265 27 W. HIGH ST. P.O. BOX 261 CARLISLE PA 17013 TELEPHONE 717-243-7638 NANCY HANNAH In the Court of Common Pleas of Plaintiff Cumberland County, Pennsylvania vs No 05-3374Civil Term CHRISTIAN CAIN Civil action law Defendant TO: Christian Cain 44 E. Frederick St. Dallastown, PA 17313 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET HELP. Cumberland County Bar Association 32 S. Bedford Street Carlisle PA 17013 717-249-3166 William A. Addams Attorney for Plaintiff DATE: September 13, 2006 (zl 21 ?? (Y : - c-a-a 0 C.11 -n -4 z? N -jj C tT`k "- % 644A aaI{T 05- 33-7 Z VERIFICATION William A. Addams hereby verifies that the judgment entered in the above captioned case was as a result of an automobile accident, which occurred July 3, 2003, and that the facts set forth are true and correct, to the best of his knowledge, information, and belief and understands at false statements herein made are subject to the provisions of 18 Pa. C.S.A. § 4904 relating to unworn falsification to authorities. September 27, 2006 Williaml A. c? :C r V ? ti f? a fV ° p c' cr% R -il -n C-) 6'1'1 f ? Cn o rn o CIA ^? WILLIAM A. ADDAMS, ESQUIRE ATTORNEY ID # 06265 43 W. South St. P.O. BOX 261 CARLISLE PA 17013 TELEPHONE 717-243-7638 NANCY HANNAH In the Court of Common Pleas of Plaintiff I Cumberland County, Pennsylvania vs No 05-3374Civi1 Term CHRISTIAN CAIN Defendant PRAECIPE Civil Action law Sir: Please mark this action settled and discontinued, and the judgment satisfied. William A. Addams Attorney for Plaintiff 43 W. South St. Carlisle, PA 17013 717-243-7638 TO: Curt Long, Prothonotary DATE: November 9, 2007 C?