HomeMy WebLinkAbout95-00873
.Q)
c..;:
(...t.-
.-
""
o
-7
1
(
:
i
.
I
"
~
p
J
6 ..~. -
I ceoz-.tc.t (.La..t)
!I90.lJ VNNEld'eYnsSOltMfOElW
OVaf11IH eNWlOdS Hl.I1OSB:
MV1.lVYaaSNnooONVAaN1:lQUV ,
HOVe .W sawvr
(7t7) , .737-2033
JAMES M.BACH
AlTORNEY AND COUNSElOR AT LAW
352 SOlTTH SPORTING HILL ROAD
MECHANICSBURG, PENNA 17055
.
,
- -
,
,
.
~
I
I
i
~- --,i
I
I
,
"
~
I
I
I
I
,
JURAJ GASPAR,
plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 'I i). f 7.3 CIVIL -r..u-rv'
CIVIL ACTION - LAW
v.
.
CHARLES L. GRIFFIE,
Defendant
JURY TRIAL DEMANDED
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 have been
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 judgement 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 TAXE 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
One courthouse square
Carlisle, PA 17013
Telephone (717) 240-6200
JURAJ GASPAR,
plaintiff
.
.
.
.
.
.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No.9;')' 7.3 CIVIL 'r~
CIVIL ACTION - LAW
v.
CHARLES L. GRIFFIE,
Defendant
JURY TRIAL DEMANDED
COMPLAINT
AND NOW, comes the PLAINTIFF, JURAJ GASPAR, by and through his
attorney James. M. Bach, and files the within Complaint.
1. PLAINTIFF, JURAJ GASPAR, is an adult individual residing
at 209 W South Street, CarliSle, cumberland County, Pennsylvania.
2. Defendant Charles L. Griffie is an adult individual
residing at 118 Oak Hill Road, Carlisle, cumberland County,
Pennsylvania.
3.
January
Trindle
County,
The facts and occurrences hereafter stated, took place on
24, 1995 at or about 2:55 P.M. at the intersection of
Road and Sporting Hill Road, Hampden TownShip, cumberland
Pennsylvania.
4. At the aforesaid time and place, in adequate distance
before the intersection, having an intention to turn left on the
Sporting Hill Road, PLAINTIFF turned on the left signal on his
vehicle and moved to the left lane. Because of the red traffic
signal at the intersection PLAINTIFF stopped his vehicle before the
intersection. staying with his vehicle in the left lane he waited
for the green traffic signal.
5. At the aforesaid time and place, when the green arrow
appeared on the traffic signal allowing PLAINTIFF enter the
intersection, Defendant Charles L. Griffie, coming with his vehicle
from opposite direction, crossed the yellow line and collided with
PLAINTIFF'S vehicle.
6. At the aforesaid time and place, PLAINTIFF was in his
proper lane of the traffic, right before the intersection.
PLAINTIFF'S vehicle was not moving at the time of the impact.
7. The aforesaid collision was a direct and proximate result
of the neqliqence and carelessness of the Defendant which
consisted in this:
(A)
Defendant failed to have his automobile under proper and
adequate control at the time of the accident.
Defendant did operate said automobile at hiqh and
excessive rate of speed under the circUlDstances.
Defendant did operate said automobile without due reqard
for the riqhts, safety and position of PLAINTIFF'S
vehicle, which was waitinq in proper manner in lane of
traffic.
(B)
(C)
(D)
Defendant failed to exercise hiqh deqree of care at
street intersection under all circUlDstances.
(E) Defendant failed to operate the vehicle in proper lane
of the traffic.
8. As a result of the aforesaid collision, PLAINTIFF'S
vehicle suffered serious damaqes includinq but not limited to the
followinq:
(A) Front left fender damaqed
(B) Front left wheel and tire damaqed
(C) Driver's door damaqed
(D) Broken transmission
9. The damaqes repair were estimated by L.E. SLOOP Service
Center in approximate amount of $ 2,620, not includinq possible
subsequent clutch damaqe of $ 200. (exhibit No 1 and No 2)
WHEREFORE, the PLAINTIFF, JURAJ GASPAR, demands judqement
of the Defendant in an amount of excess TWo Thousand and Eiqht
Hundred ($2,800) Dollars in the amount requirinq compulsory
arbitration.
2
Respectfully sUbmited,
__::I=:L~ )_'Ji=_2i-jJ7 i1-r .
J~~' ~as~~l'
Plaintiff
209 W South Street
CARLISLE, PA 17013
(717) 245-2367
~_:.::~_~_~!1196"
es K. Bach
Attorney for Plaintiff
Attorney I.D. 18727
352 S. Sporting Hill Rd.
Kechanicsburg, PA 17055
(717) 737-2033
Ii
!:
r
I
I
f
I
I
~
I
!
,
"
3
-.
t
, .L e. Sloop Stlllt'U Cllftl
12 South Spring Glrden Street
Carlisle. PI, 17013
PHONE 249.7964
-.
~o I
AUTO REP~IR
ESTIMATE
J::)(.f.t 11(\ IT'
N~ tJOl
OWNER
I"Q,
ADDRESS
" (.J
Co... f,~/(
j6\4~~
PA
s-l,
PHO..&
INSURANCE CO.
PHOtCl
LIUUr. NUWlU
ADDRESS
wue. 0' "'''
WOOEL
c..~bo...." G:rS
nAR
IUIAL NO.
W'LUU
EXHIe.11 NO ~
oqo ~ ~ . .
..( n:
S (Y) \- ! \l' , ~ ~~ ~
II)
~ to ~I I . ;~i ,
~ ~ .....
N .~: "IS ~
~
f--
!I S ~ , i I ;1 I ~ ~~
I , 0 ~
I ~. ~ ~ i i
i :.:
. ~ ~
tI g I 1) . i=
0 '\
~ .
~ ~
i ~ ~ ,
~ ..; 1. ,
~ ~ m~i 0
I::~ ~ L ; . Zi~I'S
. '~ t i 1-
if., : ~ drAll
tU i ~N ~~ ~. , -htl
g
~~~ J ~ ~ . 0 !'hlbl
, . i
. i1ifl
~ g -i' ~: . en
\.:: ~ . . Il :11
w ~ ... ..
I , .. 6 en
('~ ,'" t% l i 1 0 ... ~ IH.lii
, ~ 0 ~
~I 0 i . ~ ..
I ~ ~~ S 0 z;ri1i
.' ! uI
0: 0: ~
, -,; I~ ~i w 5 5 Il'lill i
...
(\ 3 ...
t-~ 0 . . I I I
, I _ IIz!.
I\,
,
10..
,
.
.
~ iO" t::
..... I~ '" ~ ~
~ r- liJ 11 t::~- ~ ,... ~
I~ Q:::t l ~I'- ' u ~
~. '" \-.~ D ~ ~
I ; (':> ~
\.1-
~ ,.; . . ~ l'-- ..............
... . f-,; _ I '<::: ~ t ~ ("~
.J 'I ~ ~ ~ I~ · J ; ~ ..: ~ ~ '-, :::.
~ .J~ I "'" ~ ~ S ~ ~ (
l ~ "~I :s ~ l'
'" ~ N~'" ~~
'" "
.
.
.
.
6
i
*
_ i
In
W
a:
o
!!I
o
~
...
~
JURAJ GASPAR . IN THE COURT OF COMMON PLEAS OF
.
PLAINTIPP . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. . 95 - 8?3, CIVIL TERM
.
.
.
CHARLES L. GRIFFIE .
.
DBPBNDANT . JURY TRIAL DEMANDED
.
PRAECIPB
'f,(;,
KINDLY MARK THE WITHIN CASE SETTLED, SATISFIB9 AND DISCONTINUED.
Respectfully submitted,
DATE
2-/z-~;Pr
I '
e"'~~
S M. BACR, BSQ.
ttorney I.D. No. 1872?
352 S. Sporting Hill ~pd
Mechanicsburg, PA'170!t~
717-737-2033=-:
-~~
,
""
'"
-,