HomeMy WebLinkAbout94-02556
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.lOON S. LODHOLZ I IN THE COURT OF COMMON PLEAS
PlaintUf I CUMBEILAND COUNTY, PENNSYLVANIA
I
I (14 - .~ <') i)" 6- C I VI I If( 11'1
VI. I No.
.
.
I
RICHARD B. UDLI, .II. I CIVIL ACTION - LAW
Defendant I .IUIY TRIAL DEMANDED
NOTICE TO DEFEND
You have been sued In court. It you wish to detend against the
clai.. set torth In the tollowlng pages, you must take action within
twenty (ZO) days atter this complaint and notice are served, by
entering a written appearance personally or by attorney and tiling in
writing with the court your detenses or objections to the c1al.s set
torth against you. You are warned that It you tall to do so the case
.ay proceed without you and a Judgement may be entered against you by
the court without turther notice tor any money claimed in the
co.plalnt or tor any other claim or reliet requested by the
plaintitt. You .ay lose money or property or other rights I.portant
to you.
YOU SHOULD TAKE TillS 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 WIIERE YOU CAN GET LEGAL IIELP,
Cumberland County Court Administrator
Cu.berland County Courthouse
Carlisle, Pennsylvania 17013
(717) 240-1133
5. At the aforesaid time and place, the Plaintiff, John S.
Lodholz, was operatin~ his 1985 Oldsmobile Calais coupe on the
aforesaid entrance ramp where he was stopped at a stop si~n, which
wa. in place due to construction, waiting on traffic and preparing to
enter the ncrth bound lanes of Interstate 81.
6. Also at the aforesaid time and place, the Defendant,
H. Nier1e, Jr., was driving his aforesaid Chevrolet sedan
aforesaid entrance ramp some distance behind the Plaintiff.
Richard
on the
7. At the aforesaid time and place, the Defendant proceeded to
cause his vehicle to approach the Plaintiff's vehicle without any
apparent attempt to slow his vehicle.
8. The Defendant then caused his vehicle to violently collide
with the rear portion of the Plaintiff's stopped vehicle.
9. Said motor vehicle collision and all of the hereinafter
related injuries sustained by the Plaintiff are the direct result of
the careless, wanton, reckless, and ne~ll~ent manner in which the
Defendant operated his vehicle as follows:
(a) fallln~ to keep alert and maintain a proper lookcut tor the
presence of other vehieles ;
(b) tailing to keep proper and adequate control over his
vehicle;
(c) tai1ln~ to have his vehicle under such control so as to be
able to stop within the assured clear distance ahead;
(d) talllnr to apply brakes In sutticlent time to avoid the
collision between the two vehicles;
(e) tailing to take any, or at least sutficlent, action or
actions to avoid the eo11lslon between the two vehicles;
(t) otherwise drlvlnK his vehle1e upon the highway In a manner
endangering persons and property and in a reckless manner and with
careless disregard tor the riKhts and safety ot others, and In
violation at the Motor Vehicle Code ot the Comaonwealth of
Pennsylvania,
10. As a result ot the atorementioned actions ot the
Richard H, Nlerle, Jr" and the resulting collision, the
John S. Lodho1z, suftered numerous injuries including
strain Injury, thoracle strain, and traumatic Injury
mandibular tlrst molar.
Detendant,
Plalntitt,
a cervical
to the
11, As a result at the atorementloned Injury, P1alntltt has
undergone and In the tuture will underro substantial mental anguish,
physleal pain and sutterlng, Inconvenience In executing his daily
activities, loss at Iltc's pleasures and enjoyment and elaim Is made
theretor.
12. As a result at the atorementioned Injuries sustained by the
Plalntltt, John S, Lodholz, certain expenses tor medical treatments,
medication, medical consultations, physlea1 therapy, and similar
miscellaneous expenses, 8S well 8S similar expenses In the tuture,
have been Ineurred and may continue to be Incurred, and claim Is made
..
JOHN S, LODHOLZ, I IN THE COURT OF COMMON PLEAS
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
v, I NO. 94-2556 CIVIL TERM
:
RICHARD H, NIERLE, JR" CIVIL ACTION - LAW
Defendant JURY TRIAL DEMANDED
ENTRY OP APPEARANCE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please enter my appearance on behalf of Defendant, Richard H.
Nierle, Jr., in the above captioned matter,
Respectfully submitted,
CALDWELL , KEARNS
,,~ G.
s G, Nealon, III, Esqu re
A orney I,D, "46457
Attorneys for Defendant
3631 North Front Street
Harrisburg, PA 17110
(717) 232-7661
Dated: June 15, 1994
JGNIIl/tck
32231,1
JOHN S. LODHOLZ, . IN TilE COURT 0.' COMMON 1't.EAS OF
.
PlaintlU DAUPIIIN COUNTY, PENNSYLVANIA
vs. .
.
. No. 04 - 2556 Civil Tera
.
RICHARD II. NIERLE, JR. , I
Defendant I CIVIL ACTION - AT LAW
PRAECI.fJt...T.2- ENTER SATI SFACTl.Qll.QL RECORD
TO TilE PROTIIONOTARY:
Please enter satisfaction and payment In full of all claims made
on behalf of the aforesaid Plaintiff on the doeket
of
the
above-captioned
a e t Ion
at
law
and
enter
the
wi thdrawal,
diseontinuanee, and termination of said aetlon at law upon said
docket,
Also please Issue a Certificate of Settlement to Plaintiff's
counsel of record,
To: Lawrence E, Welker
Cumberland County Prothonotary
Dated: September 28, 1004
1,0, II: 41080
Corporate Plaza, Sultc 205
2040 Llng1estown Road
lIarrlsburg. Pcnnsylvanla t7110
(717) 545-5000