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Home My WebLink About06-5738 ~ \ WILLIAM A. ADDAMS, ESQUIRE ATTORNEY ill # 06265 27W. HIGH ST. P.O. BOX 261 CARLISLE PA 17013 TELEPHONE 717-243-7638 r.GEICC'fAs-CYffMMIE..lf..NAIfGLE...................T............ln..the...Court..orCommon..Pleas...or..........J I I CUMBERLAND COUNTY, I I Plaintiff 1 Pennsylvania I I VS. No.Df--S'1:lP e~<tT~ I LOUIS A, ULRICH and QUALITY : : GREENHOUSES & PERENNIAL i L~::::._...g~~~~~.==-__I NOTICE You have been sued in Court. If you wish to defend against the class 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 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 HA VE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Fourth Floor Cumberland County Court House Carlisle P A 17013 717-240-6200 ~ c:::::.;::.:" .. '/' _ , William A, Addams Attorney for Plaintiff '\ AND now comes the plaintiff, GEICO, by its attorney, William A, Addams, and makes the following COMPLAINT 1. The plaintiff is GEICO, 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, V A 22412-0001. 2, The defendant, Louis A, Ulrich, is an adult individual residing at 207 South Sporting Hill Road, Mechanicsburg, Cumberland County, P A, 3. The defendant, Quality Greenhouses & Perennial Farm, Inc" is a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its offices and principal place of business at 250 Union Church Road, Dillsburg, York County, PA. 4, The plaintiff issued a policy of automobile insurance to Jimmie B. Naugle of Lemoyne, P A, which was in effect on February 4, 2005. 5. Jimmie B. Naugle was the owner of a 1998 Jeep Wrangler which he was driving on February 4, 2005, at about 5:30 P,M. traveling East on Trindle Road in Hampden Township, and was stopped in the left turn lane for a red light at the intersection with Sporting Hill Road, 6, At said time and place, the defendant, Louis A, Ulrich was driving a truck in the course of his employment with defendant, Quality Greenhouses & Perennial Farm, Inc., when he negligently and carelessly collided with the rear of the jeep causing the damages hereinafter set forth, 7, Defendant Ulrich, and Defendant Quality Greenhouses, through the conduct of its agent, servant and employee were negligent and careless in: a. Driving while intoxicated; b. Traveling too fast for conditions; c. Failing to observe the jeep in time to avoid a collision; d. Failing to have the vehicle under control. 8. Defendant, Quality Greenhouses, was also negligent and careless in entrusting its vehicle to a driver who was a known inebriate and unfit to drive. 9, As a result of the negligence and carelessness of the defendants, Mr, Naugle sustained severe bodily injury, 10, As a result of the negligence and carelessness of the defendants, the jeep sustained damage in the amount of $6,197,83 and Mr, Naugle incurred rental expense of $934.48, , 11, The plaintiff's insurance policy provided uninsured motorist coverage, and as a result of the defendants operating an uninsured automobile, paid $18,000 to Mr, Naugle to conclude his uninsured motorist claim and also paid for the damage to the jeep and rental expense under its collision coverage. WHEREFORE, the plaintiff demands judgment against the defendants in the amount of $25,126.31, plus interest and costs of suit, an amount within the jurisdiction of arbitration under the local rules of court. ~~~L William A. adams Attorney for the Plaintiff . VERIFI CATION Stephen W, Remick, Supervisor, GEICO, 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. Section 4904 relating to unsworn falsification to authorities. Dated: 9 <2.4 - o~ ~~ Stephen W. Remick Supervisor, GEICO 't-\~ ~Q ~\J ~~ :t:> -J:- ---- ~ 6' ~ -- ~ 0 c? --n c.... ~ ~~.,~..~~ ' 'J ",U '\ ...... ,J \.D () C) ~ .j.~ ~, 5~\\ _ .:.:.t ,. J;"; ::.! so;,; L:., ..;2 N .1;.'- SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2006-05738 P ~OMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GEICO VS ULRICH LOUIS A ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and , to wit: and inquiry for the within named DEFENDANT QUALITY GREENHOUSES & but was unable to locate Them deputized the sheriff of YORK PERENNIAL FARM INC in his bailiwick. He therefore County, Pennsylvania, to serve the within COMPLAINT & NOTICE 24th , 2006 , this office was in receipt of the On October attached return from YORK Sheriff's Costs: Docketing 6.00 Out of County 9.00 Surcharge 10.00 Dep York County 43.03 Postage 1.02 69.05'/ Cf- 10/24/2006 WILLIAM ADDAMS Sworn and subscribe to before me this day of A.D. ~ ~-- - _ Tho;;:~Kl~n;; Sheriff of Cumberland County III (')Sl b(., SHERIFFrs RETURN - REGULAR CASE NO: 2006-05738 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GEICO VS ULRICH LOUIS A ET AL VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ULRICH LOUIS A the DEFENDANT , at 1959:00 HOURS, on the 18th day of October 2006 at 207 SOUTH SPORTING HILL ROAD MECHANICSBURG, PA by handing to LOUIS A ULRICH a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff1s Costs: Docketing Service Affidavit Surcharge 18.00 10.56 .00 10.00 .00 38.567 i II f)~fbl, So Answers: ~,- "'7...,.y7 .'~ .,/;~~ ":7'" (.;....:~..;.....~" #-~ ~ ~~~ ~ ~, '" -~/p. ~:.4' 7 /,..~.;..:....~ 8 ,. ",,",'. -'- R. Thomas Kline q,~ 10/24/2006 WILLIAM ADDAMS Sworn and Subscibed to By: /d-- ~ Deput~heriff before me this day of A.D. ~ YORKTOWNE BUSINESS FORMS, INC. ph. (717),645-5955 Fax (717) 848-8936 email: ybf@blazenetnet ~ COUNTY OF YORK 1/ OFFICE OF THE SHERIFF SERVICE CALL (717) 771-9601 45 N. GEORGE ST., YORK, PA 17401 SHERIFF SERVICE PROCESS RECEIPT and AFFIDA VIT OF RETURN INSTRUCTIONS PLEASE TYPE ONLY LINE 1 THRU 12 DO NOT DETACH ANY COPES 1 PLAINTlFF/S! 2 COURT NUMBER Geico aso Jimmie B. Naugle -5738 r.jvi] 4 .TXP.J<. O~ ~lt&OR,cOW'J.AINT 3 DEFENDANT/S! 1'1 U ILL. t L. 1 L. 1-\ Louis A. Ulrich et al Notice and Complaint SERVE { 5 NAME OF INDIVIDUAL, COMPANY. CORPORATION. HC TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED.' ATTACHED. OR SOLD . Quality Greenhouses & Perennial Fann Inc 6 ADDRESS (STREET OR RFO WITH BOX NUMBER, APT NO, CITY, BORO. TWP. STATE AND ZIP CODE) AT 250 Union Church Road Dillsburg, PA 17019 7 INDICATE SERVICE Q PERSONAL W OTHER NOW October 5 York COUNTY to execute thIS to law. This depulization being made at the request and risk of the plaintiff, 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITINCOtffVltfF CO UN T Y ADVANCE FEE PAID BY ATTY. Please mail return of service to Cumberland County Sheriff. Thank you. NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN. Any deputy shenff levy,ng upon or attachlll9 any property under wIthin wnt may leave same without a watchman. in custody of whomever is found in possessIon. aher nollfylng person of levy or attachment. wIthout Iiabtlify on the part of such depufy or the sheflff to any plalnllff herein for any loss. destnlcllon. or removal of any property before sheriffs sale Ihereof 9. TYPE NAME and ADDRESS of ATTORNEY / ORIGINATOR and SIGNATUREW ILL I AM SA. ADD A M S , 27 W. HIGH ST, PO BOX 261, CARLISLE, PA 17013 E ( (1)0. TELEPHONE NUMBER 717-243-7638 11 DATE FILED 9/29/2006 12 SEND NOTICE OF SERVICE COpy TO NAME AND ADDRESS BELOW (ThIs area must be completed If noltce IS 10 be mailed) CUMBERLAND CO. SHERIFF SPACE BElOW FOR USE OF THE SHERFF - DO NOT WRITE BElOW TitS LINE 13. I acknowledge receIpt ofthe wrJf 14 OA TE RECEIVED 15 Explration/Heanng Date orcomplallltasmdicatedabove MJ MCGILL YCSO 0/10/2006 10/29/2006 16. HOW SERVED PERSONAL ( RESIDENCE ( ) POSTED ( POE( . SHERIFF'S OFFICE ( ) OTHER ( SEE REMARKS BELOW 41 AFFIRMED and $ubSCfibed to belor 42 dayol QCJ;''-:20-0~3' r,~ ~~) ~.f\I'~ ;..:\:,~ S L/\L t "\ '_ ['')\1.'1\1'.\;, ~j:JT!>}::,Y PUBLIC C:T'y '..:-)~ Y<JR~<' '(Of',K COUNTY ,.., ,~." <::/.;,,;:::3/.UG. 12,2009 45. D/b~f3'-~ 47 DATE 23 Advance Costs t:.n , A,....,.:rr'ttJlrrn, _L K.JL. . ..~. ,... ... Ir- F"'l .....,........_. __. .~.. ....._.._ WILLIAM A, ADDAMS, ESQUIRE ATTORNEY ill # 06265 57 W, Pomfret St. P.O. BOX 261 CARLISLE PA 17013 TELEPHONE 717-243-7638 !...GEICC)""ASCf}fMWE..lf..NAUGLE.....................r..........ln..fue...Courforcommon..pfe....s..or..........\ I I CUMBERLAND COUNT I \ VS. ~IDntiff\ N:':::::L I I LOUIS A. ULRICH and QUALITY I I ! GREENHOUSES & PERENNIAL ! ! I FARM, INC. I Ovil Action Law i 1........................................................................................................Q~t.~~9.:~!~..I....................................................................................................................................................1 PRAECIPE Sir: To: Curt Long, Prothonotary Dated: AprilS, 2007 ',; " ,}r-l \ j-'\ to._ ':'.:1"..\ \;/,\\:\;,'\ ;\-:j:\:,\.J'-.) ~ ." .,.. ,.. .--,/1(\ 1 p\lr<r:'('. ,"~\=Y'\~~ 1 /\..0.1'1, ,.. lS:\ Hd 6- Ud~ LGUZ i' '..1\ ('x,it\.! ,..C:Hd 3\-\1 :\0 I\t1V.l-V1"v1 ....~-l .,,,,,!.n-Qjlb ::ld\..'...'"