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HomeMy WebLinkAbout07-0112DEBRA LYNN SLIMA, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO: - 6 7- //-?- l / DOUGLAS JAMES WANCZA C, Defendant JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS To the Prothonotary: Please issue a writ of summons in the above captioned action. Writ of Summons shall be issued and forwarded to the Cumberland County Sheriffs Office. Respectfully submitted, ROMINGER & WHARE I Date: January 5, 2007 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID 4 81924 Attorney for Plaintiff WRIT OF SUMMONS To The Above Named Defendants: Douglas James Wanczak 40 Thompson Creek Drive Shippensburg, Pennsylvania 17257 YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. Prothonotary Date: /-J- p By: ty n ra SHERIFF'S RETURN - REGULAR CASE NO: 2007-00112 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SLIMA DEBRA LYNN VS WANCZAK DOUGLAS JAMES WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon WANCZAK DOUGLAS JAMES the DEFENDANT , at 1038:00 HOURS, on the 5th day of February , 2007 at 40 THOMPSON CREEK DRIVE SHIPPENSBURG, PA 17257 RON MOWERY, ROOMMATE by handing to ADULT IN CHARGE a true and attested copy of WRIT OF SUMMONS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 33.44 Postage .39 Surcharge 10.00 .00 z11y16 7 q? 61.83 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 02/06/2007 ROMINGER & WHARE By ` eputy Sheriff A. D. DEBRA LYNN SLIMA, Plaintiff V. DOUGLAS JAMES WANCZAK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW No. D7-/IZ 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. IN THE COURT OF COMMONS L O NIA DEBRA LYNN SLIMA, CUMBERLAND COUNTY, PE Plaintiff CIVIL ACTION -LAW V. DOUGLAS JAMES WANCZAK, NO. C7 -?' Defendant COMPLAINT intiff Debra Lynn Shma, by their attorney, Karl E. Rominger, The above-referenced Pla Esquire, respectfully sets forth the following cause of action: PARTIES hereinafter "Plaintiff') is an individual residing at 212 West 1. Plaintiff, Debra Lynn Shma Catherine Street, Chambersburg, Pennsylvania 17201. 2. Defendant, Douglas James Wanczak (hereinafter "Defendant") is an individual residing at 40 Thompson Creek Drive, Shippensburg, PA 17257• VENUE this action because the causes of action arose with Defendant in 3. Venue is appropriate for thi Cumberland County, Pennsylvania. FACTS uar 27, 2005, Plaintiff was at Defendant's residence, 40 Thompson 4. On or about JanY ve Shi pensburg, PA 17257 where she was residing at the time. Creek Dn p 5. Defendant returned home at around 2:30 a.m. after having been drinking at a bar until it closed. 6. At around 5:30 a.m. Defendant and Plaintiff were having a conversation. 7. Defendant, without provocation, viciously punched Plaintiff across the face. 8. As a direct result of the Defendant's punch, Plaintiff lost two teeth, suffered a fractured bone, and bruising on her face. COUNT I - ASSAULT AND BATTERY 9. Paragraphs 1 through 8 are incorporated by reference thereto as if fully set forth herein. 10. Defendant intentionally punched Plaintiff in the face. 11. Defendant's punch was not consented to, nor a result of self-defense. 12. Defendant's punch caused Plaintiff to lose teeth, suffer bruising and fracturing on her face. 13. Plaintiff, as a result of Defendant's actions, has present and future medical bills. 14. Plaintiff, as a result of Defendant's actions, has suffered mentally and emotionally. 15. Plaintiff, as a result of Defendant's actions, had pain and suffering both at the time and in the future. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an award in her favor in an amount not in excess of the statutory limits for compulsory arbitration, including costs of this suit and attorney fees, and punitive damages. PUNITIVE DAMAGES 16. Paragraphs 1 through 15 are incorporated by reference thereto as if fully set forth herein. 17. The conduct of Defendant was shocking and outrageous. 18. The Defendant acted with a bad motive. 19. The Defendant's intentional conduct was the factual cause of Plaintiff's injuries. 20. The Defendant should be punished in order to deter the Defendant and others from committing similar wanton and willful acts. 21. The Plaintiff is entitled to punitive damages. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an award in her favor in an amount not in excess of the statutory limits for compulsory arbitration, including costs of this suit and attorney fees, and punitive damages. Dated:&* Respectfully Submitted, ROMINGER & ASSOCIATES Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 Tel: (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff ATTORNEY VERIFICATION Karl E. Rominger, Esquire, states that he is the attorney for, Debra Slima, in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. Pa.C.S. §4904, relating to unworn falsification to authorities. Date: O Karl E. ominger, Esquire Attorney for Plaintiff DEBRA LYNN SLIMA, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. : DOUGLAS JAMES WANCZAK, Defendant :NO. 07 - f / Z, CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, do hereby certify that I served a copy of the Complaint upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Douglas James Wanczak 40 Thompson Creek Shippensburg, PA 17257 Dated: Vd4l )- ? 2 06 7 Respectfully submitted, ROMINGER & ASSOCIATES Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff "-?' ?. ,_, <- ?.:? - ; ?-, YsA..J /?.? •??? ?? NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 WOLF & WOLF 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR DEFENDANT DEBRA LYNN SLIMA, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW V. : NO. 2007 - 0112 CIVIL TERM DOUGLAS JAMES WANCZAY, Defendant PRAECIPE FOR ENTRY OF APPEARANCE OF COUNSEL OF RECORD TO THE PROTHONOTARY: Please enter the appearance of NATHAN C. WOLF, ESQUIRE, as attorney for the Defendant, Douglas James Wa.nczak, in this matter. JANUARY " , 2008 64- Carlisle, PA 17013 717-241-4436 SUPREME COURT ID NO. 87380 T-l • ' DEBRA LYNN SLIMA, Plaintiff VS. DOUGLAS JAMES WANCZAK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW :NO: 07-0112 JURY TRIAL DEMANDED STATEMENT OF INTENTION TO PROCEED TO THE PROTHONOTARY: ,? v T Please note that the Plaintiff intends to proceed with the above captioned matter. Respectfully submitted, Rominger & Associates Date: C 0 I-- Z' y? Vincent M. Monfredo, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court I.D. # 206671 Attorney for Plaintiff DEBRA LYNN SLIMA, Plaintiff V. DOUGLAS JAMES WANCZAK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. CERTIFICATE OF SERVICE I, Vincent M. Monfredo, Esquire, do hereby certify that I served a copy of the Intention to Proceed upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Douglas James Wanczak c/o Nathan Wolf, Esquire 10 W. High Street Carlisle, PA 17013 Respectfully submitted, ROMINGER & ASSOCIATES Dated: ?O- 2'(- ( Vincent M. Monfredo, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 206671 Attorney for Plaintiff �� Davit!D. Buell'Trothonotaly ~ ~- Sohonage, ESQ theSolicitor /�~`f� fn,�/ [D/��0��/u~/��YY�~~. � `� � ��� /��� Cumberland County, /' Tennsyfriania Co'7 //7 , CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE—THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH BY THE COURT DAVID D. BUELL PROTHONOTARY One Courthouse Square 0 Suite100 e Can��1).A 0 (Phone 717 240-6195 0 9a,c71724O6573