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HomeMy WebLinkAbout02-2217KELLY L. WEAVER, Plaintiff DENISE HOWARD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 02 /cr IL : NO. - 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 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 fights important to you. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT }lAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPItONE THE OFFICE SET FORTH BELOW TO FIND OUT WI-IERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association Lawyer Referral Service 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Plaintiff DENISE HOWARD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-2217 CIVIL TERM Sir: PRAECIPE Please reinstate the Complaint to serve Defendant Denise Howard at her place of employment at Fades Em All at 29 East North Street, Carlisle, PA 17013. HANFT & KNIGHT, P.C. To: Curtis R. Long, Prothonotary Date: June 20, 2002 William ~F'. Addams Attorney I.D. No. 06265 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013 (717) 249-5373 Attorney for Plaintiff KELLY L. WEAVER, Plaintiff DENISE HOWARD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-,,7,a / 7' CIVIL TERM . . COMPLAINT AND NOW, comes the Plaintiff, Kelly L. Weaver, by her attorney, William A. Addams, of Hanft & Knight, P.C., and makes the following Complaint: 1. The Plaintiff is Kelly L. Weaver, an adult individual residing at 6315 Forrest Drive, Mechanicsburg, PA 17050. 2. The Defendant is Denise Howard, an adult individual residing at 726 Cumberland Point Circle, Mechanicsburg, Cumberiand County, PA 17055. 3. The Plaintiff is the owner of a 1994 Nissan Pathfinder which was being driven by Billy Sheaffer on June 2, 2001 at about 11:45 a.m. traveling West on Trindle Road in Silver Spring Township, Cumberland County, Pennsylvania. 4. At said time the place the Defendant was driving an automobile traveling East on Trindle Road when she negligently and carelessly attempted a left turn into the driveway at 1350 West Trindle Road and collided with the Plaintiff's automobile causing the damages hereinafter set forth. 5. The Defendant was negligent and careless in: B. C. D. Attempting a left turn in the face of oncoming traffic. Failing to yield the right-of-way. Failing to observe the Plaintiff's vehicle in time to avoid a collision. Failing to have her vehicle under control. 6. As a result of the negligence and carelessness of the Defendant, the Plaintiff's automobile sustained damage in the amount of $3,502.91. WHEREFORE, the Plaintiff demands judgment against the Defendant in the amount of $3,502.91 plus interest and costs of suit, an amount within the jurisdiction of arbitration under the local rules of court. HANFT & KNIGHT, P.C. 6. As a result of the negligence and carelessness of the Defendant, the Plaintiff's automobile sustained damage in the amount of $3,502.91. WHEREFORE, the Plaintiff demands judgment against the Defendant in the amount of $3,502.91 plus interest and costs of suit, an amount within the jurisdiction of arbitration under the local rules of court. HANFT & KNIGHT, P.C. ~illim'~ A. Addams Attorney I.D. No. 06265 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013 (717) 249-5373 Attorney for Plaintiff VERIFICATION Kelly L. Weaver hereby verifies that the facts set forth in the foregoing Complaint are tree and correct to the best of her knowledge, information and belief, and understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsifications to authorities. DATE: Kel~/L. V~ave~' SHERIFF'S RETURN - CASE NO: 2002-02217 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NOT FOUND WEAVER KELLY L VS HOWARD DENISE R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT HOWARD DENISE but was unable to locate Her in his bailiwick. COMPLAINT & NOTICE , He therefore returns the , NOT FOUND , as to the within named DEFENDANT , HOWARD DENISE MOVED FROM MECHANICSBURG TO SALVATION ARMY IN CARLISLE. SHE MOVED OUT OF THERE 3 MONTHS AGO. ADDRESS UNKNOWN. Sheriff's Costs: Docketing 18.00 Service 3.45 Not Found 5.00 Surcharge 10.00 .00 36.45 R. Thomas Kline Sheriff of Cumberland County WILLIAM ADDAMS 05/09/2002 Sworn and subscribed to before me this 3~ day of C~ _ Prothonotary KELLY L. WEAVER, Plaintiff DENISE HOWARD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA i NO. 02- °'q~! ~TcIvIL TERIvl 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 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 TIlE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association Lawyer Referral Service 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 [RUE COPY FROM RECORD Testimony whereof, I ~ere unto set my hanc KELLY L. WEAVER, Plaintiff DENISE HOWARD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02- CIVIL TERM COMPLAINT AND NOW, comes the Plaintiff, Kelly L. Weaver, by her attorney, William A. Addams, ofHanft & Knight, P.C., and makes the following Complaint: 1. The Plaintiff is Kelly L. Weaver, an adult individual residing at 6315 Forrest Drive, Mechanicsburg, PA 17050. 2. The Defendant is Denise Howard, an adult individual residing at 726 Cumberland Point Circle, Mechanicsburg, Cumberland County, PA 17055. 3. The Plaintiff is the owner of a 1994 Nissan Pathfinder which was being driven by Billy Sheaffer on June 2, 2001 at about 11:45 a.m. traveling West on Trindle Road in Silver Spring Township, Cumberland County, Pennsylvania. 4. At said time the place the Defendant was driving an automobile traveling East on Trindle Road when she negligently and carelessly attempted a left turn into the driveway at 1350 West Trindle Road and collided with the Plaintiff's automobile causing the damages hereinafter set forth. 5. The Defendant was negligent and careless in: B. C. D. Attempting a left turn in the face of oncoming traffic. Failing to yield the right-of-way. Failing to observe the Plaintiff's vehicle in time to avoid a collision. Failing to have her vehicle under control. 6. As a result of the negligence and carelessness of the Defendant, the Plaintiff's automobile sustained damage in the amount of $3,502.91. WHEREFORE, the Plaintiff demands judgment against the Defendant in the amount of $3,502.91 plus interest and costs of suit, an amount within the jurisdiction of arbitration under the local roles of court. HANFT & KNIGHT, P.C. ~illi~im~A. Addams Attorney I.D. No. 06265 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013 (717) 249-5373 Attorney for Plaintiff VERIFICATION Kelly L. Weaver hereby verifies that the facts set forth in the foregoing Complaint are true and correct to the best of her knowledge, information and belief, and understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsifications to authorities. Kel~fL. W~aver DATE: z]/o//~- ~..2_ SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-02217 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WEAVER KELLY L VS HOWARD DENISE R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT HOWARD DENISE but was unable to locate Her in his bailiwick. COMPLAINT & NOTICE , He therefore returns the the within named DEFENDANT , HOWARD DENISE , NOT FOUND , as to NO LONGER EMPLOYED AT FADES EM ALL. SHE IS BELIEVED TO BE LIVING AT SAFE HARBOR. Sheriff's Costs: Docketing 18.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 31.45 So answers.~ /' / ~ ~ R. Thomas Kline Sheriff of Cumberland County WILLIAM ADDAMS 06/27/2002 Sworn and subscribed to before me this ~ day of ~__ 2 o-oD. A.D. Prgt h'onot ary