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Home My WebLink About06-5660STATE FARM INSURANCE IN THE COURT OF COMMON PLEAS COMPANIES, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. V. CIVIL ACTION - LAW MONICA BROWN, Defendant 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (800) 990-9108 NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (800) 990-9108 STATE FARM INSURANCE COMPANIES, : Plaintiff V. MONICA BROWN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 010 CIVIL ACTION - LAW COMPLAINT 1. The Plaintiff is a corporation duly licensed in the Commonwealth of Pennsylvania to issue policies of automobile insurance, and having its home office located in Bloomington, Illinois 61702. 2. Defendant Monica Brown is an adult individual residing at 1517 Center Street, Enola, Pennsylvania 17025. 3. The facts and occurrences hereinafter related took place on or about November 5, 2005 on East Penn Drive in East Pennsboro Township, Cumberland County, Pennsylvania. 4. At the time and place aforesaid, Plaintiff insured a 2001 Pontiac sedan owned by Pamela Hoover. 5. At the time and place aforesaid, Pamela Hoover was driving the insured vehicle south on East Penn Drive when she brought her vehicle to a stop for a dog that ran into the street. 6. At the time and place aforesaid, Defendant was the owner and operator of a 1998 Mitsubishi sedan, which she drove into the rear of the Hoover vehicle causing substantial damages to the vehicle and personal injuries to Pamela Hoover. 7. The aforesaid accident and damages resulting therefrom were caused by the negligence of Defendant Brown in that she: a) failed to keep a proper lookout for other vehicles; b) failed to have her vehicle under control; and c) operated her vehicle at such a speed so as to be unable to stop within the assured clear distance ahead. 8. Solely as a result of the Defendant's negligence, Plaintiff was forced to expend SIX THOUSAND NINE HUNDRED SEVENTY-EIGHT and 61/100 ($6,978.61) DOLLARS on account of the injuries and damages sustained by its insured, Pamela Hoover. WHEREFORE, Plaintiff demands judgment against the Defendant in an amount not in excess of mandatory arbitration limits. Respectfully submitted, WIX, WENGER & WEIDNER By /R ?a,-JL R, Richard H. Wix, Esq., ID #07274 Attorneys for Plaintiff 4705 Duke Street Harrisburg, PA 17109-3099 (717) 652-8455 2 y% • - an employee of State Farm Insurances Companies, have read the foregoing Complaint, which has been drafted by counsel. The factual statements and/or denials contained therein are true and correct to the best of my knowledge, information and belief. I am authorized to make this verification. This verification is made only as to the factual averments contained therein and not to legal conclusions and averments authorized by counsel in his capacity as attorney for the party or parties hereto. This verification is made subject to the penalties of 18 Pp. C.S. Section 4904, relating to unsworn falsification to authorities, which provides that if I knowingly made false averments, I may be subject to criminal penalties. ?? 1 Date: /a (Signature) 7L VII l ? 7 iE? .rL^3 e?? ?"y SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-05660 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STATE FARM INSURANCE COMPANIES VS BROWN MONICA 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 BROWN MONICA but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFFNT)ANTT 1517 CENTER STREET ENOLA, PA 17025 BROWN MONICA NOT FOUND , as to PER PSOT OFFICE, DEFENDANT IS NOT KNOWN AT GIVEN ADDRESS. Sheriff's Costs: So answers: Docketing 18.00 ",.. Service 13.20 Not Found 5.00 R. Thomas n.o Surcharge 10.00 Sheriff of Cumberland County Postage .39 46.59/ WIX WENGER WEIDNER n 10/06/2006 Sworn and Subscribed to before me this day of A. D. STATE FARM INSURANCE COMPANIES, Plaintiff V. MONICA BROWN, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-5660 Civil Term : CIVIL ACTION - LAW PRAECIPE Please reinstate the Complaint in the above-captioned matter, which was filed on or about September 27, 2006. Respectfully submitted, WIX, WENGER & WEIDNER By /a`C?at•L k WX Richard H. Wix, Esq., ID #07274 Attorneys for Plaintiff 4705 Duke Street Harrisburg, PA 17109-3099 (717) 652-8455 Dated: August 3, 2007 b? ? a m SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2006-05660 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STATE FARM INSURANCE COMPANIES VS BROWN MONICA 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 to wit: BROWN MONICA but was unable to locate Her deputized the sheriff of DAUPHIN in his bailiwick. He therefore serve the within COMPLAINT & NOTICE County, Pennsylvania, to On September 26th , 2007 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: So answe a Docketing 18.00 Out of County 9.00 l Surcharge 10.00 R. Thomas Kline Dep Dauphin County 31.25 Sheriff of Cumberland County Postage 1.26 69.51 / 1oJoS?o1,? 09/26/2007 WIX WENGER WEIDNER Sworn and subscribe to before me this day of A. D. Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania STATE FARM INSURANCE COMPANIES vs County of Dauphin BROWN MONICA Sheriff's Return No. 1152-T - - -2007 OTHER COUNTY NO. 06 5660 CIVIL I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for BROWN MONICA the DEFENDANT named in the within NOTICE & COMPLAINT and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, August 31, 2007 AS PER WILLIAM BROWN(FATHER) DEF DOES NOT LIVE ADDRESS LEFT NOTE Sworn and subscribed to before me this 31ST day of AUGUST, 2007 NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County My Commission Expires Sept 1, 2010 ???tLE ?# t4je ?4-erfff So Answers, ? ?* er?? Sheriff of Dauphin County, Pa. By Deputy Sheriff Sheriff's Costs:$31.25 PAID BY COUNTY SCHEAEF