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Home My WebLink About02-3920STATE FARM INSURANCE COMPANIES, Plaintiff HUI F. DONG and KAI CHEN, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. O~- CIVIL ACTION - LAW 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP. CUMBERLAND COUNTY REFERRAL SERVICE Court Administrator Cumberland County Courthouse Carlisle, PA 17013-3387 (717) 240-6200 NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y pot cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY REFERRAL SERVICE Court Administrator Cumberland County Courthouse Carlisle, PA 17013-3387 (717) 240-6200 STATE FARM INSURANCE COMPANIES, Plaintiff HUI F. DONG and KAI CHEN, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 1. The Plaintiff is a corporation duly authorized to conduct insurance business in the Commonwealth of Pennsylvania. 2. Defendant Hui F. Dong is an adult individual residing at 100 Stonehedge Drive, Carlisle, Pennsylvania 17013. 3. Defendant Kai Chen is an adult individual residing at 100 Stonehedge Drive, Carlisle, Pennsylvania 17013. 4. The facts and occurrences hereafter related took place on or about September 9, 2001 at the intersection of West Pomfret and South Orange Streets in Carlisle, Cumberland County, Pennsylvania. 5. At the time and place aforesaid, Roger L. Rickrode was operating a Ford Explorer which was insured by the Plaintiff. 6. At the time and place aforesaid, Defendant Dong was operating a 2000 Nissan Maxima owned by Defendant Chen when he went through a stop sign and collided with the vehicle owned by Rickrode and insured by State Farm. 7. Solely as a result of the aforesaid accident and negligence of the Defendants, Plaintiff was required to pay damages for the repair of its insured's vehicle in the total amount of FIVE THOUSAND THREE HUNDRED EIGHTY-ONE and 88/100 ($5,381.88) DOLLARS. 8. The aforesaid accident and damages resulting therefrom were caused by the negligence of Defendant Dong in that he: a) b) ¢) 9. were caused by the negligence of Defendant Chen in that he: a) allowed a person to use his vehicle when he knew such person was uninsured. failed to yield the right-of-way to the Rickrode vehicle; failed to stop for a stop sign in violation of the Motor Vehicle Code; and failed to keep a proper look out for other vehicles. The aforesaid accident and damages resulting therefrom that 10. Defendant Dong was the agent, servant or employee of Defendant Chen, and acting within the scope of such agency or employment. WHEREFORE, in an amount not Plaintiff demands judgment against the Defendants in excess of mandatory arbitration limits. Respectfully submitted, WIX, WENGER & WEIDNER Dated: Richard H. Wix, Esq., ID# 07274 Attorneys for Plaintiff 4705 Duke Street Harrisburg, PA 17109-3099 (717) 652-8455 VERIFICATION I, Richard H. Wix, Esquire, attorney for the Plaintiff in this matter, verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. The undersigned understands that his statements therein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. Richard H. Wix, Esquire Dated: SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-03920 P COMMONWEALTH OF PENIqSYLVANIA COUNTY OF CUMBERLAND STATE FARM INSURANCE COMPANIES VS DONG HUI F ET AL R. Thomas Kline duly sworn according to inquiry for the within named defendant, DEFENDANT DONG HUI F unable to locate Him COMPLAINT & NOTICE ,Sheriff or Deputy Sheriff, who being law, says, that he made a diligent search and in his bailiwick. He therefore returns but was the the within named DEFENDANT DONG HUI F , NOT FOUND as to NOT LOCATED AT 100 STONEHEDGE DRIVE CARLISLE. SUPPOSEDLY LIVING SOMEWHERE IN YORK COUNTY. Sheriff's Costs: Docketing 18.00 Service 3.45 Not Found 5.00 Surcharge 10.00 .00 36.45 · omas Klin~ Sheriff of CumDerland County WIX WENGER WEIDNER 09/27/2002 Sworn and subscribed to before me this y~ day of 0~- ~- A.D. Pr6t~non~tary SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-03920 p COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STATE FARM INSURANCE COMPANIES VS DONG HUI F ET AL R. Thomas Kline duly sworn according to law, inquiry for the within named defendant, CHEN says, that he made a diligent DEFENDANT ,Sheriff or Deputy Sheriff, who being search and but was He therefore returns the unable to locate Him in his bailiwick. COMPLAINT & NOTICE the within named DEFENDANT CHEN KAI NOT FOUND , as to NOT LOCATED AT 100 STONEHEDGE DRIVE CARLISLE. SUPPOSEDLY LIVING SOMEWHERE IN YORK COUNTY. Sheriff,s Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 .00 21.00 So answe~ _j. Thomas Kline Sheriff of Cumberland County WIX WENGER WEIDNER 09/27/2002 Sworn and subscribed to before me this ~ day of ~&Y3~ A.D. onotary STATE FARM INSUR/kNCE, : COMPANIES, : Plaintiff : V. : : HUI F. DONG and KAI CHEN, : Defendants : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3920 Civil Term PRA~CIPE Please reinstate the Complaint filed on or about August 16, 2002,in the above captioned case. Respectfully Submitted, Wix, Wenger & Weidner Richard H. Wix, Esq. ID# 07274 Attorneys for Plaintiff 4705 Duke Street Harrisburg, PA 17109-3099 (717) 652-8455 Dated: 10/10/02 SHERIFF,s RETURN _ CASE NO: 2002-03920 p COMMONWEALTH OF COUNTy OF PENNSYLvANiA: CUMBERLAND STATE FARM INSURANCE COMPANIES VS DONG HUI F ET AL REGULAR BRIAN BARRIcK _, Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly SWOrn according to law, Says, the within COMPLAINT & NOTICE DONG HUI F ~ was Served Upon DEFENDANT , at 1456:00 HOURs, on the the at POE' THE GREAT WA ~ day of October , 200~2 LL CARLISLE, PA 17013 9S0 WALNUT BOTTOM ROAD LING ZHANG, PERSo~ T~ ~- by handing to ...... , ~'~SON IN CHARGE AT BUSINESS a true and attested COpy of COMPLAINT & NOTICE ~ together with and at the Same time directing He~r attention to the COntents thereof. Sheriff,s Costs: Docketing Service Affidavit Surcharge 18.00 3.45 .00 10.00 .00 31.45 Sworn and Subscribed to before h~^ ~is ~ day of A.. Oe4 So Answers k.' Thomas w~_- ~ i0/i5/2002 WIX WENGER WEIDNER By:~ SHERIFF,s RETURN _ REGULAR CASE NO: 2002-03920 p COMMONWEALTH OF COUNTy OF PENNSYLvANiA: CUMBERLAND STATE FARM INSURANCE COMPANIEs VS DONG HUI F ET AL BRIAN BARRICK _, Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly SWOrn according to law, says, the within COMPLAINT & NOTICE CHEN KAI ~_~ was Served upon DEFENDANT , at 1456:00 HOURs, on the the at POE: THE GREAT WALL ~ day of October , 2002 CARLISLE, PA 17013 950 WALNUT BOTTOM ROAD by handing to LING ZHANG, PERSON IN CHARGE OF BUSINEss a true and attested Copy of COMPLAINT & NOTICE ~ together with and at the Same time directing He____r attention to the COntents thereof. Sheriff's Costs: Docketing Service Affidavit SUrcharge 6.00 .00 .00 10.00 .00 16.00 Sworn and Subscribed to before ~ this ~ day of A.D. So Answers: R. Dmas Kl~ne 10/15/2002 WIX WENGER WEI~NER ~ deputy Sheriff' v ~