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Home My WebLink About06-5810FILE #07-06-557 LAW OFFICES OF STEWART C. CRAWFORD & ASSOCIATES BY: Stewart C. Crawford, Esquire ATTORNEY I.D. #09827 ATTORNEY FOR PLAINTIFF 223 North Monroe Street Media, PA 19063 Telephone: (610) 565- 7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN CIVIL ACTION STATE FARM MUTUAL AUTOMOBILE : IN CIVIL ACTION INSURANCE COMPANY : a/s/o JEANNE E. BLAKESLEE P.O. Box 2371 Bloomington, IL 61702 : NO.: O` -- 5??? 1.1 u ti C, V. ; CARLISLE CARRIER CORPORATION 6380 Brackbill Boulevard Mechanicsburg, PA 17050 And RANDY L. SINGER 1525 Orrs Bridge Road Enola, PA 17025 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 further 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 LAWYEROR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Le ban demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plaza al partir de la fecha de la demanda y la notificacion. Hace faita asentar una comparencia escrita o en persona o con un abogado y entregar a la cone en form sus defensas o sus objections a las demandas en contra de su persona. Ses avisado que si usted no se defiende la cone tomara modidas ypuede continuar ila demanda en contra suya sin previo aviso o notificacion. Ademas, la cone puede decidir a favor del demandante y requiera que usted cumpia con todas las provisions de esta demanda. Usted puede perder dinero o sus propiedaces u otros derechos importantes parr usted. USTED DEBE LLEVAR ESTA AVISO A UN ABOGADO ENESEQUIDA. SI USTED NO TIENE UN ABOGADO Y NO PUEDEPAGAR LOS SERVICIOS DE UN ABOGADO, DEBE COMUNICARSE CON LA SIGUIENTE OFICINA PARA AVERIGUAR DONDE PUEDE OBTENER AYUDA LEGAL. TARYN DIXON, COURT ADMINISTRATOR ONE COURTHOUSE SQUARE CARLISLE, PA 17013 (717) 240-6200 FILE #07-06-557 LAW OFFICES OF STEWART C. CRAWFORD & ASSOCIATES BY: Stewart C. Crawford, Esquire ATTORNEY I.D. #09827 ATTORNEY FOR PLAINTIFF 223 North Monroe Street Media, PA 19063 Telephone: (610) 565- 7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN CIVIL ACTION STATE FARM MUTUAL AUTOMOBILE : IN CIVIL ACTION INSURANCE COMPANY : a/s/o JEANNE E. BLAKESLEE : P.O. Box 2371 Bloomington, IL 61702 : V. NO.. Dl. - S`??O CARLISLE CARRIER CORPORATION 6380 Brackbill Boulevard : Mechanicsburg, PA 17050 And COMPLAINT Motor Vehicle Property Damage atu?c-? 1. Plaintiff is an insurance company licensed and authorized to do business in the Commonwealth of Pennsylvania with one of its principle places of business at the above-captioned address. 2. Defendant, Carlisle Carrier Corporation, is a business entity authorized to do business in Pennsylvania and was the owner of the motor vehicle involved in this incident and, at all times pertinent hereto, had as a principle place of business the above-captioned address. 3. Defendant, Randy L. Singer, is an adult individual and at all times pertinent hereto resided at the above-captioned address and was the RANDY L. SINGER 1525 Orrs Bridge Road Enola, PA 17025 1 operator of Defendant owner's motor vehicle and did so as an agent, servant, workman or employee of the business and on the behalf of the Owner. 4. On January 28, 2005, Plaintiff had a written policy of insurance with Jeanne E. Blakeslee, hereinafter referred to as named insured, said policy is at present not available for attachment to this complaint. 5. On the aforesaid date, a motor vehicle insured by Plaintiff hereafter, the insured vehicle, was involved in an incident with Defendant's vehicle. 6. On the aforesaid date, the insured vehicle was traveling on Rossmoyne Road at the intersection with the ramp that leads to SRI 5 in Mechanicsburg, Pennsylvania, when the Defendant, who was traveling in the opposite direction on Wesley Drive/Rossmoyne Road, disregarded a red light and attempted to make a left turn onto the ramp that leads to SRI 5 North striking the insured vehicle in the intersection causing damage. 7. Defendant driver was negligent and careless and the sole cause of this incident in that Defendant driver: (a) operated the vehicle at an unsafe rate of speed; (b) was inattentive; (c) failed to make proper observation; (d) violated local laws of the Commonwealth of Pennsylvania. 8. Pursuant to the aforesaid policy of insurance, Plaintiff becomes liable for damages that arose out of this incident. 9. Due to this incident, expenses were incurred for damage to the insured vehicle, towing, storage and car rental. 10. Pursuant to the aforesaid policy of insurance, the Common Law and governing statutes, Plaintiff is subrogated for all money paid and seeks recovery of these sums totaling $4,622.92. 2 COUNTI PLAINTIFF V. RANDY L. SINGER 11. Plaintiff incorporates paragraphs 1 through 10 inclusive as if fully set forth at length herein. 12. Defendant is liable as the negligent driver. WHEREFORE, Plaintiff demands judgment for $4,622.92 plus interest and costs of suit. COUNT II PLAINTIFF V. CARLISLE CARRIER CORPORATION 13. Plaintiff incorporates paragraphs 1 through 12 inclusive as is fully set forth at length herein. 14. Defendant owner is liable under the Doctrine of Respondeat Superior for the negligence of the Defendant driver. 15. Defendant owner was negligent in entrusting this motor vehicle to someone who Defendant knew or could have known was a dangerous, unlicensed, inexperienced or careless motor vehicle operator. WHEREFORE, Plaintiff demands judgment for $4,622.92 plus interest and costs of suit. 7A STEWART C. CRAWFORD SQ. Attorney for Plaintiff 3 VERIFICATION The undersigned hereby states that he is an authorized agent of Plaintiff insurance company in this action and verifies that the statements contained in the foregoing Complaint are true and correct. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. All, S EWART C. CRAWFORD 'SW any for Allstate Insura ce Co any Date: KV9 "(70 4 N l? U-t - , ? I OV) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE : CIVIL ACTION INSURANCE COMPANY a/s/o JEANNE E. BLAKESLEE Plaintiff No. 06-5810 V. CARLISLE CARRIER CORPORATION, and RANDY L. SINGER Defendants ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of the Defendants in the above-captioned matter. Respectfully submitted, Sonya s Attorney ID # 92919 Marcello & Kivisto, LLC 1501 Commerce Ave. Carlisle, PA 17013 O: (717) 240-4686 F: (717) 258-4686 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE : CIVIL ACTION INSURANCE COMPANY a/s/o JEANNE E. BLAKESLEE Plaintiff No. 06-5810 V. CARLISLE CARRIER CORPORATION, and RANDY L. SINGER Defendants CERTIFICATE OF SERVICE I hereby certify that the foregoing Entry of Appearance in the within action was served upon the following by enclosing the same in an envelope addressed as follows, postage prepaid and depositing same in the United States Mail, First Class Mail, in Carlisle, PA on the 20th day of October, 2006. Stewart C. Crawford Law Offices of Stewart C. Crawford & Associates 223 North Monroe Street Media, PA 19063 Sonya s Marcello & Kivisto, LLC 1501 Commerce Ave. Carlisle, PA 17013 O: (717) 240-4686 F: (717) 258-4686 Cl ?z-t -n r 0 SHERIFF'S RETURN - REGULAR CASE NO: 2006-05810 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STATE FARM MUTUAL AUTOMOBILE VS CARLISLE CARRIER CORPORATION 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 CARLISLE CARRIER CORPORATION the DEFENDANT at 1541:00 HOURS, on the 19th day of October 2006 at 6380 BRACKBILL BOULEVARD MECHANICSBURG, PA 17050 by handing to SUE BAUM, COMPLIANCE MANAGER. ADTTT T TN f'NAR(;'F a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing Service 18.00 9.68 Affidavit .00 S h urc arge 10.00 R. Thomas Kline .00 37868,/ 10/20/2006 STEWART CRAWFORD Sworn and Subscibed to By: before me this day Deputy eriff of A.D. SHERIFF'S RETURN - REGULAR CASE NO: 2006-05810 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STATE FARM MUTUAL AUTOMOBILE VS CARLISLE CARRIER CORPORATION 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 SINGER RANDY L the DEFENDANT at 1541:00 HOURS, on the 19th day of October , 2006 at 6380 BRACKBILL BLVD MECHANICSBURG, PA 17050 SUE BAUM by handing to ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 6.00 Service .00 Affidavit .00 n Surcharge 10.00 R. Thomas Kline .00 16.00 ? 10/20/2006 %/`dal0(. STEWART CRAWFORD Sworn and Subscibed to By: ? ? before me this day Deputy Sheriff of A.D. FILE #07-06-557 LAW OFFICES OF STEWART C. CRAWFORD & ASSOCIATES BY: STEWART C. CRAWFORD, ESQUIRE ATTORNEY I.D. NO. 09827 223 NORTH MONROE STREET MEDIA, PA 19063 TELEPHONE: (610) 565-7050 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA, CIVIL ACTION LAW STATE FARM INSURANCE COMPANY NO.: 06-5810 a/s/o JEANNE E. BLAKESLEE V. CARLISLE CARRIER CORPORATION and RANDY L. SINGER PRAECIPE TO ORDER TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Please mark the record in the above-captioned matter as "Settled, Discontinued and Ended" upon payment of costs. S1EWAR C. C:RAWFORD, ESQUIRE DATE: 11 3? Ub Attorney for Plaintiff c? d7