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Home My WebLink About94-01864 .11 c.. 'f: ~ ~ ;,/ ( JI J ~ ~ -..... ,.... _.._...........:......_...~....;,;,;....;J."', . _ +.. ~.. I. I':.:.~"..:O:; ,:, .., . '. . ," ..... .J,. ".'.: I..;.. . ;.;.,;;..,;;~...........~.;_.1.........1.....,..... '....h......_.....,.:;."'...__............ , SIII':IIII'I":-; /lJmJIIN ~'11l 01' PENNSYLVANIAl CCllINI'Y OF Clt>lBERLIINO Bethlee I. Whitmiro In tho Court of Common Pleas of Cumborland County, Pennsylvania No, 94-1864 Civil Term, Complaint in Civil Action Law and Notice VS Joel Lee Whitmire Audrey O. Adams , l6OerZiitkU1CDeputy Sheriff of CUnberland County, Pennsylvania, who that he SOlVed tho within Complaint Joel Leo Whitmire beIng duly swom according to law, says, in Civil Action Law and Notice upon , the defendant, at 11150 April "0 'clock A .M. ij.'l/8c I EDS'I', on the 18th day of House, Carlisle , 1994 at Cumberland County Shoriff, Court . . Cumberland County, Pennsylvania, by handing 1:0 Joel Loe Whitmire a true and attosted copy of the Complaint and Notice . and at the same t imo direcl: 111g his attention to the contents thereof and the "Notice to Plelld" onclonll:xl lhernon. SherHf's COlltSl Docketing Service Af fidav Jt Surchal,"ge 14.00 So answers. ." ~/ ...., .~,' .. ~.:-'" .......'..' ..~,... .t (."J~ ....:.. ... t...~ "to..;i'.:",;;'_,,,1' ~_.. ... /.."...... ~ ,'. . 2,00 16,00 Pd. by Atty. 4-18-94 I~. 'rhanas Kline. Sheriff by . ~ 0 ' ({ll"~~ . Jl(lr<~ Deput ,Sheriff Swom and subscribed to hel:l)/"O II>:! thia .Jo ~ day of (y:.u..L.___ 19 r; 'I A.D. ~Y'~ o )h.~~~'f~-- Prothonotary , . ' , ~- ~)o ... -a. ~ l.. 3; ,...", ~ 0 N .. .,-- 8 Iii 8~ :'f ("( ~ l\.il'(,", ..--:!' ~ :!~~. :r ~ Ii) N) "'j- It) Q ".f~" '.~.- .0.... R ." :.';.:;.::! -:r - " I'" 00 ,j":Q':Z ~ '" '~"'Jl,,~,:X: l"-t ::t;;:"i.U ~ ":tt - . ;~:z;:Q.. ...- '.~B ~ "-.. .... ..",. C> Q Z < ...:l ... rn !ii~a f{j ~S~<~ ~ ~~I;i~;1j It OOXLLlr::' o Q=Oll.;:::: ~ ... o:E~;;; j ;l~:i!!l~ ~ ",;Ix ~ M<ll. ~ u Q ... < rn --:4.~._ _ v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 9~./'tlDL( CIVIL 19 CIVIL ACTION - LAW JURY TRIAL DEMANDED BETHLEE I. WHITMIR~, Plaintiff JOEL LEE WHITMIRE, Defendant 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 of 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 CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse Fourth Floor Carlisle, PA 17013 (717) 240-6100 SAIDIS, GUIDO & SAmIS. mlluo " MASt.ANU 2,. W, IIl,h 'IH't'1 C.,lhll',.t^ By: Edward E. Guido, Esquire Supreme Ct. 1.0. # 21206 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiff t~.:,<~,~./~~ BETHLEE I. WHITMIRE, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL 19 CIVIL ACTION - LAW JOEL LEE WHITMIRE, Defendant JURY TRIAL DEMANDED COMPLAINT AND NOW, comes Plaintiff through her attorneys, SAlOIS, GUIDO & MASLAND, and avers the following causes of action: 1. Plaintiff is Bethlee I. Whitmire, an adult individual who currently resides at 945 Ridge Road, Mt. Holly Springs, Cumberland County, Pennsylvania. 2. Defendant is Joel Lee Whitmire, an adult individual who currently resides at 945 Ridge Road, Mt. Holly Springs, Cumberland County, Pennsylvania. 3. The events hereafter complained of occurred on or about January 21, 1993 at approximately 3:45 p.m. on Mountain Road (T548), South Middletown Township, Cumberland County, SAID IS, GUIDO '" MASLAND 26 W, High Slr<<. Carli.le, PA Pennsylvania, approximately 2.5 miles west of Boiling Springs, Pennsylvania. 4. At said time and place Plaintiff was a passenger in a 1977 Chevrolet El Camino which was being operated by Defendant along said Mountain Road in a general easterly direction. 5. At said time and place the Defendant lost control of the vehicle, left the roadway and collided into a bridge culvert. 2 SAID IS, GUIDO '" MASLAND 26 W, Hlah 51r<<:1 Carli.I., P ^ 6. The injuries and damages to Plaintiff as hereinafter set forth were the direct and proximate result of the negligence of Defendant, then and there occurring. 7. Defendant, Joel Lee Whitmire, was negligent generally and in the following particulars: (a) In operating his vehicle in a reckless manner; (b) In failing to maintain a proper lookout; (c) In failing to have his vehicle under proper control; (d) In failing to keep his vehicle on the roadway; (e) In traveling too fast for conditions; and (f) In failing to stop before colliding with the culvert and/or bridge abutment. 8. As a direct and proximate result of the negligence of Defendant, Plaintiff sustained the following serious and severe injuries, some or all of which may be permanent: (a) Injuries and damages in and about the left foot, leg and ankle (including, but not limited to, dislocation fractures of the foot, leg and ankle); (b) Numerous scrapes, abrasions and contusions; (c) Shock and injuries to the nerves and nervous system; (d) Injuries in and about her hip and hip joint; and (e) Scaring and permanent disfigurement. 3 9. As a result of the injuries aforesaid, Plaintiff has been damaged as follows: (a) She has suffered and will continue to suffer great pain, inconvenience, embarrassment, mental anguish, discomfort, distress and humiliation; (b) She has been and will be required to expend large sums of money for surgical and medical attention in excess of the first party benefits payable under the Motor Vehicle Financial Responsibility Law; and (C) She has been and will be deprived of her ability to enjoy life and its pleasures. WHEREFORE, Plaintiff demands judgment against Defendant in an amount in excess of $25,000.00, plus costs of this action. A jury trial is demanded. Respectfully submitted, By: Edward E. Guido, Esquire Supreme Ct. 1.0. # 21206 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiff SAIDIS. GUIDO &: MASLANJ) 26 W, Hlsh S".., Carli.le, PA 4 VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. DATED: J.j / 1/ /'1'-/ ~f2r~ It JL_~ Bethlee . Whitmire SAIDIS, GUIDO '" MASLAND 26 W. High S".., Carlisle. PA 5 LAW OI'PlCBS SAIDIS, GUIDO, SIIlJlI1I' . MASLAND . 26 W, IROH STJUlIIT CARUSLB, PSNNA. 17013 PHONS (717) 243-6222 CBRTIFtBDc:OPY,... r.J " 'h..... "'\} 4-- v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-1864 CIVIL TERM CIVIL ACTION - LAW BETHLEE I. WHITMIRE, plaintiff JOEL LEE WHITMIRE, Defendant JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: Please mark the above-captioned matter settled and discontinued. Da~e: &!rJd ~4 0,,) ...;,;.'i... SAlOIS, GUIDO, SHUFF & MASLAND By,4~ Edward E. Guido, Esquire Supreme Ct. 1.0. # 21206 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiff SAIDlS, GUIDO, SHUFF & MASLAND 26 W. 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