HomeMy WebLinkAbout95-04573
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LAW OfFICES OF
STBPHBN J. HOGG
401 E, LOUTHER STREET
CARLISLE, PA 17013
, .
6, At the aforesaid date, lime and place, the traffic signal was red
for vehicles traveling South on Route 15 and green for vehicles traveling
west and east on Llsburn Road,
7, At the aforesaid date, lime and place, Plaintiff Joan E, Fry was
lawfully traveling through the Intersection of Lisburn Road and Route 15
at a reasonable rate of speed when Defendant Joseph A, Moody
negligently, carelessly and recklessly drove through the red light for
southbound traffic on Route 15 and struck Plaintiff Joan E, Fry's vehicle.
8. Plaintiff Joan E, Fry's vehicle was struck by Defendant Joseph
A, Moody's vehicle on the passenger side and spun around ending up
on the northwest corner of the intersection of Route 15 and Lisburn
Road on a small embankment.
9, As a direct and proximate result of Defendant Joseph A.
Moody's negligence, carelessness and recklessness as aforesaid,
Plaintiff Joan E, Fry suffered severe and permanent bodily InjUry In the
form of a severely strained neck,
10, As a direct and proximate result of Defendant Joseph A,
Moody's negligence, carelessness and recklessness, Claimant Joan E,
Fry lost wages and wl\llose wages In the future because of her Injuries,
11, Defendant Joseph A. Moody negligently. carelessly and
recklessly caused the aforesaid collision with Plaintiff Joan E, Fry by:
(a) Falling to obey a traffic control device;
(b) Failing to operate his vehicle with due care for other vehicles
on the road;
(c) Failing to travel at a reasonable rate of speed;
(d) Failing to have and keep his vehicle under proper management
and control;
SHERIFF'S RETURN - OUT OF COUNTY
CASE NOI 1995-04573 P
COMMONWEALTH OF PENNSYLVANIA I
COUNTY OF CUMBERLAND
FRY DENNIS M & JOAN E
VS.
MOOOY JAMES & KATHLEEN ET AL
R. Thomas Kline . Sheriff, who being duly aworn according
to law, says, that he made u diligent search and inquiry for th~ within
named defendant, to witl MOODY JOSEPH A
but was unable to locate
Him
in his bailiwicll. He therefore
County, Pennsylvania.
deputized the sheriff of YORK
to serve the within COMPLAINT
On September 20th, 1995
the attached return from YORK
, this office was in receipt of
County, Pennsylvania.
Sheriff's Costs I
Docketing
Out of County
Surcharge
6.00
.00
2.00
So answe.;;.sv) '/
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R.t hamas Kline, Sher1:ff
GB.0~ STEPHEN HOGG
09/20/1995
Sworn and subscribed ffo before
this ,)l'of- day of ..J~t"k .
19 ~{ A.D.
me
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I'rothonot~'~/'
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lAW orncES Of
S'l'l!I'IIIlN J. 1I0GG
401 E. LOUTHER STREET
CARLISLE. PA 17013
6. At the aforesaid date, time and place, the traffic signal was red
for vehicles traveling South on Route 15 and green for vehicles traveling
west and east on Lisburn Road.
7. At the aforesaid date, time and place, Plaintiff Joan E. Fry was
lawfully traveling through the intersection of Llsburn Road and Route 15
at a reasonable rate of speed when Defendant Joseph A. Moody
negligently, carelessly and recklessly drove through the red light for
southbound traffic on Route 15 and struck Plaintiff Joan E. Fry's vehicle.
8. Plaintiff Joan E. Fry's vehicle was struck by Defendant Joseph
A. Moody's vehicle on the passenger side and spun around ending up
on the northwest corner of the intersection of Route 15 and Lisburn
Road on a small embankment.
9. As a direct and proximate result of Defendant Joseph A.
Moody's negligence, carelessness and recklessness as aforesaid,
Plaintiff Joan E. Fry suffered severe and permanent bodily Injury In the
form of a severely strained neck.
10. As a direct and proximate result of Defendant Joseph A.
Moody's negligence, carelessness and recklessness, Claimant Joan E.
Fry lost wages and will lose wages In the future because of her injuries.
11. Defendant Joseph A. Moody negligently, carelessly and
recklessly caused the aforesaid collision with Plaintiff Joan E. Fry by:
(a) Failing to obey a traffic control device;
(b) Falling to operate his vehicle with due care for other vehicles
on the road;
(c) Failing to travel at a reasonable rate of speed;
(d) Falling to have and keep his vehicle under proper management
and control;
CERTIFICATE OF SERVICE
I, Stephen J. Hogg, Esquire, Attorney for the Plaintiffs, do
hereby certify that I did on this day serve a copy of the attached
Complaint by United States Mail, first class postage, prepaid, from
Carlisle, Pennsylvania, addressed to the following:
James Moody
1 14 Walmah Manor
Dlllsburg, Pa 17019
Kathleen Moody
114 Walmah Manor
Dillsburg, Pa 17019
Joseph A. Moody
1 14 Walmah Manor
Dillsburg, Pa 17019
ate: (Ctt/! .:2. VI/PC! .s"
I I
Stephen J. g, Es,~ Ir
Attorney for lain tiff /
401 E. Louther Street
Carlisle, PA 17013
(717) 246-2698
LAW OfFICES OF
S'l'l!I'IIIlN J. 1I0GG
401 E. LOUTHEn STREET
CARLISLE. PA 17013
lAWOfrlCESor
S'l'l!l'IIEN J. 1I0GG
401 E. LOUTHER STREET
CARLISLE. PA 17013
6. At the aforesaid date, lime and place, the traffic signal was red
for vehicles traveling South on Route 15 and green for vehicles traveling
west and east on Lisburn Road.
7. At the aforesaid date, time and place, Plaintiff Joan E. Fry was
lawfuily traveling through the intersection of Llsburn Road and Route 15
at a reasonable rate of speed when Defendant Joseph A. Moody
negligently, carelessly and recklessly drove through the red tight for
southbound traffic on Route 15 and struck Plaintiff Joan E. Fry's vehicle.
8. Plaintiff Joan E. Fry's vehicle was struck by Defendant Joseph
A. Moody's vehicle on the passenger side and spun around ending up
on the northwest corner of the Intersection of Route 15 and L!sburn
Road on a small embankment.
9. As a direct and proximate result of Defendant Joseph A.
Moody's negligence, carelessness and recklessness as aforesaid,
Plaintiff Joan E. Fry suffered severe and permanent bodily Injury In the
form of a severely strained neck.
10. As a direct and proximate result of Defendant Joseph A.
Moody's negligence, carelessness and recklessness, Claimant Joan E.
Fry lost wages and will lose wages In the future because of her Injuries.
11. Defendant Joseph A. Moody negligently, carelessly and
recklessly caused the aforesaid collision with plaintiff Joan E. Fry by:
(a) Falling to obey a traffic control device;
(b) Failing to operate his vehicle with due care for other vehicles
on the road;
(c) Failing to travel at a reasonable rate of speed;
(d) Failing to have and keep his vehicle under proper management
and control;
lAWOfflCESOF
Sl'n1'III!N J. 1I0GG
401 E. LOUTHER STREET
CARLISLE. PA 17013
. .
6. At the aforesaid date, time and place, the traffic signal was red
for vehicles traveling South on Route 15 and green for vehicles traveling
west and east on L1sburn Road.
7. At the aforesaid date, time and place, Plaintiff Joan E. Fry was
lawfully traveling through the Intersection of L1sburn Road and Route 15
at a reasonable rate of speed when Defendant Joseph A. Moody
negligently, carelessly and recklessly drove through the red light for
southbound traffic on Route 15 and struck Plaintiff Joan E. Fry's vehicle.
8. Plaintiff Joan E. Fry's vehicle was struck by Defendant Joseph
A. Moody's vehicle on the passenger side and spun around ending up
on the northwest corner of the Intersection of Route 15 and L1sburn
Road on a small embankment.
9. As a direct and proximate result of Defendant Joseph A.
Moody's negligence, carelessness and recklessness as aforesaid,
,,'
Plaintiff Joan E. Fry suffered severe and permanent bodily Injury In the
form of a severely strained neck.
10. As a direct and proximate result of Defendant Joseph A.
Moody's negligence, carelessness and recklessness, Claimant Joan E.
Fry lost wages and will lose wages In the future because of her injuries.
11. Defendant Joseph A. Moody negligently, carelessly and
recklessly caused the aforesaid collision with Plaintiff Joan E. Fry by:
(a) Failing to obey a traffic control device;
(b) Failing to operate his vehicle with due care for other vehicles
on the road;
(c) Failing to travel at a reasonable rate of speed;
(d) Failing to have and keep his vehicle under proper management
and control;
.
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