Loading...
HomeMy WebLinkAbout94-02746 ts. ( j 1> ( I (J ..-1 ~ - .....9 ::r- C- <l5 -:r il,' r~ en " - -. \ ~ ...~ f ~ \-0 N} = ., ,. - ~ . . , , -....::::r- w M N \ Jil ...:) ~ r'"l 00 ~ .-J - ~ ~ _r '.' ~ -d- ~ -:1.-= G \~--:j ~ ........ r\\ - --.. ~ ....... 00 ~ ~ ~ -- ~r:;S "'6 ...... . ~ . ~ ., . . 0 rail w it w N ... ~ a ~ ~ 0 ~ ~ < 0 III ... . i 0 Eo . 0 ... ~ 0 ~ 0 u rIl Ii j;: a w .. ~ <( U .. 5 of % i;; ~ < . " Z ~ '" 0 Z ;: 0( . ~ :n " E p., ... ~ 0 ~ .. J III rail . ~ ,;'l < = . ;, '. ,.... 'f', " oj- .OJ ....,.... ~ll (~l.... .M t\..,. l~"f10t0f O)A~ l,nllJUl'li1,. 1'5 JERI E. STUMPF. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO'q4__ al7!;f,t, C'~.:J CIVIL ACTION - LAW V. DINA SAKSON, Defendant JURY TRIAL DEMANDED NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth against you 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 default 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 LAWVER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THIS OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6200 u".... K. .\~M"I'IS..I'. f:. ,.,... l.u....~&... ,...... JERI E. STUMPF, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. V. DINA SAKSON, Defendant CIVIL ACTION. LAW JURY TRIAL DEMANDED COMPLAINT 1. Plaintiff, JERI E. STUMPF, is an adult individual residing at 308 N. 7th St., Wrlghtsville, York County, Pennsylvania, 2. Defendant, DINA SAKSON, is an adult individual residing at 133 Forest Dr., Camp Hill, Cumberland County, Pennsylvania. 3. On April 19, 1993, Plaintiff was the owner and operator of a 1989 Chevrolet Camaro with Pennsylvania registration number STUMPF. 4. On April 19, 1993, Defendant was the operator of a 1988 Volkswagen Cabriolet with Pennsylvania registration number AAC9289 with consent and permission of the owner of said motor vehicle, Robert J. Sakson, of the same address. 5. On April 19, 1993, at approximately 8:45 a.m., Plaintiff was operating his motor vehicle in a northerly manner, in the right hand lane of SR 83, immediately north of Exit 19 in Lower Allen Township, Cumberland County, Pennsylania. Defendant, entering SR 83 North on the Exit 19 entrance ramp, failed to slow down UA..K Yo. .\ !'I'MT'!\o' K. II, C:. for congested traffic, and struck a motor vehicle, driven by Darcy A. Hoyle, in the ,."..,................'" rear, causing said vehicle to strike that of Plaintiff's vehicle in the rear as well. 6. Said collision resulted from the negligence and recklessness of the Defendant, and was due in no manner whatsoever to any act or failure to act on the part of the Plaintiff. 7. The negligence and recklessness of the Defendant consisted of the following: a. Failure to properly operate and control said motor vehicle; b. Failure to keep alert and maintain a proper lookout for the presence of other motor vehicles on the streets and highways; c. Careless driving in violation of 75 Pa.C.S.A. ~3714 and 4703(a). 8. As a result of the negligence of the Defendant, Plaintiff suffered serious and permanent injuries Including, but not limited to, severe emotional distress and damage, cervical and lumbar strain/sprain, contusions to the left knee, and contusions to the right thumb resulting in traumatic tendonitis. 9. As a result of the negligence of the Defendant, Plaintiff was forced to incur medical bills and expenses for the injuries he has suffered, the cost or reasonable value of which is, or may be, In excess of the sum recoverable under the Pennsylvania Financial Responsibility Act, and he will continue to incur medical expenses in the future. 10. As a result of the negligence of the Defendant, Plaintiff has, or may ,I ...0'''.... d IJ...L~_,~:.:~~~~'.~.~: I'. C:. suffer a severe loss of his earnings and impairment of his earning capacity. Said ,-.... l'.u~.....,. ...'... loss of income and Impairment of earning capacity has, or may, exceed the sum 2 , :1 q i ".c...,...." ;:..j IJ"L~.~:::~,~:-~~.~~,.I.. C:. :1 ~'".. '.I.U....... "..... " I I 1 ,; recoverable under the Pennsylvania Financial Responsibility Act, and said loss of income and impairment of earning capacity will, or may, continue In the future. 11. As a further result of the negligence of the Defendant, Plaintiff has undergone, and in the future may undergo, great mental and physical pain and suffering, mental anguish and humiliation, loss of life's pleasures, and a severe limitation In his pursuit of daily activities, all to his great loss and detriment. 12. This matter is alleged to exceed the applicable limits of arbitration and a Jury trial is hereby demanded. WHEREFORE, Plaintiff respectfully requests This Honorable Court to enter Judgment against the Defendant in an amount in excess of the mandatory arbitratio limits. Respectfully submitted, Da E. Anstin , Esquire Attorney I.D. 22487 Two West Market Street P.O. Box 952 York, PA 17405 (717) 846-0606 3 VERIFICATION I HEREBY VERIFY that the information set forth in the foregoing COMPLAINT is true and correct to the best of my knowledge. information and belief. I understand that any false statements contained herein are subject to the penalties 0 18 Pa.C.S. ~4904. relating to unsworn falsification to authorities. Date: ~, ~'II'?Y UALR ~. .\~"TIN'..lt. C:. ""'-..'.........,.,..."" SHERIFF'S RETURN COMMONWEALTH OF PENNSYLVANIA In The Court of Common Pleas of Cumberland County, Pennsylvania COUNTY OF CUMBERLAND No. 94-2746 Civil Term Complaint in Civil Action Law Jeri E. Stumpf and Notice to Defend VS Dina Sakson R. THOMAS KLINE, Sheriff, who being duly sworn according to law, says, that he made diligent search and inquiry for the within named defendant to wit: Dina Sakson but was unable to locate her in his bailiwick. He therefore returns the Complaint and Notice NOT FOUND, as to the within named defendant. Dina Sakson. Defendant's address is located in York Countv. PA I . Sheriff's Costs: Docketing Service Affidavit Surcharge So answers: 14.00 8.40 2.00 24.40 Pd. by Atty. 5-27-94 j 'R. , ./>_.~ '-A; ''-;-f'.-' /ti~::-- THOMAS KLINE, Sheriff Sworn and subscribed to before me this tL 13 ~ day Of~ A.D. 19 9'( (h', () }n.Li~~." A.~r., y , , Prothonotary . .....\.... ~.'.\. ." ... )(3 JERI E. STUMPF. Plaintiff i IN THE COURT OF COMMON PLEAS OF i CUMBERLAND COUNTY. PENNSYLVANIA I NO'14- .)74~ ~-lI0jV CIVIL ACTION - LAW ' V. DINA SAKSON, Defendant JURY TRIAL DEMANDED NOTiCE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth against you 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 I you fail to do so, the case may proceed without you and a default judgment may be : I ! 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THIS OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. ,....-..- Lawyer Referral Service Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6200 TRUE COPY FROM RECORD In Testimony whBreDf, I here unto set my hand and the seal of sai C at Carlisle, ~~Yi Th da _ 19~ ._...oC.... AL. S. .\:VNTUI.. P. c. .__..'_1......' -.............. -..,P......l"..,.._ \ ) .-........... ........-..,....... -.......-.... ~.......u...,.._ .....-.-. }<3 JERI E. STUMPF. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA I NO. tj'4- .)74 ~ ~JVVJ-jJ CIVIL ACTION. LAW V. DINA SAKSON. Defendant JURY TRIAL DEMANDED NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth against you 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 I you fail to do so, the case may proceed without you and a default judgment may be . I 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 OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THIS OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6200 TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of sai C at Carlisle, ~a,f, Th da 19..:z:;c... \ , I I JERI E. STUMPF. I Plaintiff Iv. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA NO. CIVIL ACTION - LAW DINA SAKSON. Defendant JURY TRIAL DEMANDED AVISO USTED HA SIDO DEMANDADO EN LA CORTE. SI usted desea defenderse de I las quejas expuestas en las p~glnas siguientes. debe tomar acci6n dentro de velnte (20) dras a partir de la fecha en que recibl6 la demanda V el avlso. Usted de be presentar comparecencia escrlta en persona 0 por abogado V presentar en la Corte por escrlto sus defensas 0 sus objeciones alas demand as en su contra. i Se Ie avlsa que sl no se defiende. el caso puede proceder sin usted V la Corte i I ! puede decidir en su contra sin mas aviso 0 notificaci6n por cualquier dinero I I reclamado en /a demanda 0 por cualquier otra queja 0 compensaci6n reclamados por I I el Demandante. USTED PUEDE PERDER DINERO. 0 PROPRIEDADES U OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE 0 NO CONOCE UN ABOGADO. VAYA 0 LLAME A LA OFICINA EN LA DIRECCION ESCRITA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. ~_."ocno. .....-..... Lawver Referral Service Cumberland Countv Courthouse 1 Courthouse Square Carlisle. PA 17013 (717) 240-6200 .-................. -.............. ..................,- JERI E. STUMPF, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA NO. V. DINA SAKSON. Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED COMPLAINT 1. Plaintiff, JERI E. STUMPF, is an adult individual residing at 308 N. 7th St., Wrightsville, York Countv, Pennsvlvania. 2. Defendant, DINA SAKSON, is an adult individual residing at 133 Forest Dr., Camp Hill, Cumberland Countv, Pennsvlvania. 3. On April 19, 1993, Plaintiff was the owner and operator of a 1989 Chevrolet Camaro with Pennsvlvania registration number STUMPF. 4. On April 19, 1993, Defendant was the operator of a 1988 Volkswagen Cabriolet with Pennsvlvania registration number AAC9289 with consent and permission of the owner of said motor vehicle, RObert J. Sakson, of the same address. 5. On April 19, 1993, at approximate1v 8:45 a.m., Plaintiff was operating his motor vehicle in a norther1v manner, in the right hand lane of SR 83, immediate IV north of Exit 19 in Lower Allen Township, Cumberland Countv, Pennsvlanla. Defendant, entering SR 83 North on the Exit 19 entrance ramp, failed to slow down '_."ocno' for congested traffic, and struck a motor vehicle, driven bV Darcv A. Hovle, in the o.u.. B. .\:WNTUf.. P. (:. .-.....-........, -............. ......h....\.ft...._ rear, causing said vehicle to strike that of Plaintiff's vehicle in the rear as well. 6. Said collision resulted from the negligence and recklessness of the Defendant, and was due in no manner whatsoever to anv act or failure to act on the part of the Plaintiff. 7. The negligence and recklessness of the Defendant consisted of the following: a. Failure to properlv operate and control said motor vehicle; b. Failure to keep alert and maintain a proper lookout for the presence of other motor vehicles on the streets and highwavs; c. Careless driving in violation of 75 Pa.C.S.A. ~3714 and 4703(a). 8. As a result of the negligence of the Defendant, Plaintiff suffered serious and permanent injuries including, but not limited to, severe emotional distress and damage, cervical and lumbar strain/sprain, contusions to the left knee, and contusions to the right thumb resulting in traumatic tendonitis. 9. As a result of the negligence of the Defendant, Plaintiff was forced to Incur medical bills and expenses for the injuries he has suffered, the cost or reasonable value of which is, or mav be, in excess of the sum recoverable under the PennsVlvania Financial Responsibility Act, and he will continue to incur medical expenses in the future. 10. As a result of the negligence of the Defendant, Plaintiff has, or mav '_.">en.., DAL. e. .':"t"Tn, at P. C. suffer a severe loss of his earnings and impairment of his earning capacity. Said .-....-.......... -............. ....r......\.ft...,_ loss of income and impairment of earning capacity has, or mav, exceed the sum ,....-..... 2 recoverable under the Pennsvlvania Financial Responsibility Act, and said loss of income and impairment of earning capacity will, or mav, continue In the future. 11. As a further result of the negligence of the Defendant, Plaintiff has undergone, and in the future mav undergo, great mental and phvsical pain and suffering, mental anguish and humiliation, loss of life's pleasures, and a severe limitation in his pursuit of dailv activities, all to his great loss and detriment. 12. This matter is alleged to exceed the applicable limits of arbitration and a jury trial is herebv demanded. WHEREFORE, Plaintiff respectfullv requests This Honorable Court to enter judgment against the Defendant in an amount in excess of the mandatorv arbltratio limits. Respectfullv submitted, Da E. Anstin , Esquire Attornev 1.0. 22487 Two West Market Street P.O. Box 952 York, PA 17405 (717) 846-0606 ._...oe.... ALa .0 .\"NTIH., P. C. .-....-........ -...-....... _..r...........,II_ ,....-.-. 3 VERIFICATION I HEREBY VERIFY that the Information set forth in the foregoing COMPLAINT is true and correct to the best of mv knowledge, information and belief. I understand that anv false statements contained herein are subject to the penalties 0 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. Date: ~,~~; I~?Y' ._...oe.... BALa So "'''..TUf., P. C. .-....-.,...... -.............. ............0....._ '. ~ ,-. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 1 I , JERI E. STUMPF No. 94. 2746 CIVIL TERM Term. 19_ VS. DINA SAKSON CIVIL ACTION - LAW PRAECIPE TO REMOVE - To the Prothonotary: ( X ) Please mark the above captioned action SETTLED AND SATISFIED OR ( I Please mark the above captioned judgment or lien settled an Auaust 30 . 19~ ***PLEASE PREPARE A CERTIFICATE OF SATISFACTION. ***