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Home My WebLink About02-4049 ******************** Paqe 25 7730/2002 084029073002 *STATEMENT OF COSTS* CCS746 Case No. 2002-01263 To: Dennis E. Lebo Cumberland County - Clerk of Courts 1 Courthouse Square Carlisle, Pa I7013 GETZ STANLEY FRED 1903 HOLLY STREET HARRISBURG, PA 17104 Date Transaction Debit Credit Balance 07/24/02 COURT COSTS 24.90 24.90 Totals 24.90 24.90 07/24/02 SHERIFFS COST 1.50 1.50 Totals 1.50 1.50 CUMBERLAND COUNTY ADULT PROBATION VS. Stanley Fred Getz 1903 Holly St. Harrisburg, PA 17104 Plaintiff IN THECOURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW NO. (~),2-~O~ CIVIL TERM Defendant RE: NO. 02-1263 CRIMINAL TERM PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: Enter judgment in favor of plaintiff, Cumberland County Adult Probation, and against Defendant in the amount of $ 2,382.50 pursuant to 42 Pa. C.S.A. Section 9728 as set forth in the attached statement of certified case costs and fines. Dennis E. Lebo, Clerk of Court Date: August 26, 2002 ENTRY OF .JUDGMENT AND NOW, this ~ay of .~_ __t ~ ,~[~)judgment is entered in favor of the Plaintiff and against the Defendant-in t~ amount set forth above. Attachment cc: Defendant Probation Curtis R. Long, Prothonotary 084029073002 ******************** Paqe 26 CCS746 *STATEMENT OF COSTS* 7730/2002 Case No. 2002-01263 To: Dennis E. Lebo Cumberland County - Clerk of Courts 1 Courthouse S~uare Carlisle, Pa I7013 GETZ STANLEY FRED 1903 HOLLY STREET HARRISBURG, PA 17104 Totals 200.00 200.00 07/24/02 ST - O.S.F. 75.00 75.00 Totals 75.00 75.00 07/24/02 CO - O.S.F. 75.00 75.00 Totals 75.00 75.00 07/24/02 COURT COSTS 8.00 8.00 Totals 8.00 8.00 07/24/02 AUTOMATION FEE 5.00 5.00 Totals 5.00 5.00 07/24/02 LOCAL-DUI 150.00 150.00 Totals 150.00 150.00 07/24/02 DUI PRISON MNT 75.00 75.00 Totals 75.00 75.00 07/24/02 DUI DRUG/ACHOL. 75.00 75.00 Totals 75.00 75.00 07/24/02 EMS 10.00 10.00 Totals 10.00 10.00 07/24/02 CAT FUND 200.00 200.00 Totals 200,00 200.00 07/24/02 ADMIN. FEE 40.00 40.00 Totals 40.00 40.00 07/24/02 LOCAL FINES 500.00 500.00 Totals 500.00 500.00 084029073002 ******************** Paqe 27 CCS746 *STATEMENT OF COSTS* 7?30/2002 Case No. 2002-01263 To: Dennis E. Lebo Cumberland County - Clerk of Courts 1 ~our~nouse ~quare Carlisle, Pa I7013 GETZ STANLEY FRED 1903 HOLLY STREET HARRISBURG, PA 17104 07/24/02 STATE FINES 500.00 500.00 Totals 500.00 500.00 07/24/02 EMS 10.00 10.00 Totals 10.00 10.00 07/24/02 CAT FUND 30.00 30.00 Totals 30.00 30.00 Case Totals 2382.50 .00 2382.50 You are liable for the above costs Pursuant to Title 42 of Judiciary and Judicial procedure, 42 PA CSA 9728, the Prothonotary is authorized to confess judgment on all unpaid costs and issue an execution and place same in tSe 5ands of the Sheriff for the cOllection. We trust you will give the above account your prompt attention. A TRUE COPY FROM RECORD In Testimor~/whereof, I here unto set my h~nd CUMBERLAND COUNTY ADULT PROBATION VS. Stanley Fred Getz 1903 Holly Street Harrisburg, PA 17104 Plaintiff Defendant/Address IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW NO. CIVIL TERM 02-4049 RE: NO. CRIMINAL TERM 02-1263 PRAECIPE TO SATISFY JUD~ TO THE PROTHONOTARY: Please mark satisfied the judgment, in favor of 1 ' ' Probation and against the ab,, ....... ~ .... p amt~ff Cumberland County Ara,I+ ~-~--~u~u ae~enaant re ' -~ ..... C S A ' , p xaously entered pursuant to 42 Pa · · · Section 9728. Also, please prepare a Certificate of Satisfaction. D~e: December 17, 2002 Dennis E. Lelir~, Clerk of Court Charles R. Gert~w, Esqdre Solicitor for the Clerk of Court of Cumberland County, Pennsylvania cc: Defendant Probation Clerk of Court II LAW OFFICES D~LORETO, COSENT~qO & BOL~X~ER PC 330 LINCOLN WAY EAST P.O. BOX 866 CHAMBERSBURG, PA 17201 Terry L. Hockensmith and Darlene K. Hockensmith, Plaintiffs VS, J. H. Rose Truck Lines, Inc., Ryszard Glowinski, Daily Express, Inc., and Harold Eugene Pryor, Defendants In The Court of Common Pleas of Cumberland County No. 2002-4089 CIVIL TERM in Civil Action - Law 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 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 claims 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 CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 LAW OFFICES D~Lo~mO, COSENT~O & BOLINGER PC UNCOLN WAY EAST P.O. BOX 866 CHAMBEI~BURG, PA '1720'1 Terry L. Hockensmith and Darlene K. Hockensmith, Plaintiffs In The Court of Common Pleas of Cumberland County VS, J. H. Rose Truck Lines, Inc., Ryszard Glowinski, Daily Express, Inc., and Harold Eugene Pryor, Defendants No. 2002-4089 CIVIL TERM in Civil Action - Law COMPLAINT' NOW come the Plaintiffs, Terry L. Hockensmith and Darlene K. Hockensmith, through their attorney, Denis M. DiLoreto, Esquire, of DiLoreto, Cosentino & Bolinger, PC and for cause of action against the E)efendants say: 1. The Plaintiff, Terry L. Hockensmith, is a sui juris adult individual living and residing at 330 Shively Road, Chambersburg, Franklin County, Pennsylvania, 17201. 2. The Plaintiff, Darlene K. Hockensmith, is a sui juris adult individual living and residing at 330 Shively Road, Chambersburg, Franklin County, Pennsylvania, 17201. 3. At all times relevant to this cause of action, Terry L. Hockensmith and Darlene K. Hockensmith were husband and wife. 4. The Defendant, J. H. Rose Truck Lines, Inc., is a Texas corporation. Its last known address was 425 North Motel Boulevard, Las Cruces, New Mexico 88055. LAW OFFICES DILORETO, COSENTINO & BOUNC~m PC 330 LINCOLN WAY EAST P.O. BOX 86~ OHAMBER~BUR~, PA 17~01 The Defendant, Ryszard Glowinski, is a sui juris adult individual living and residing at 250 Mt. Vernon Place, Apartment 12-K, Newark, New Jersey 07106. 6. The Defendant, Daily Express, Inc., is a Pennsylvania corporation with an office at 1072 Harrisburg Pike, Carlisle, Pennsylvania 17013. 7. The Defendant, Harold Eugene Pryor, is a sui juris adult individual living and residing at P.O. Box 98, Pratt, West Virginia 25162. 8. At all times relevant to this cause of action, the Defendant, Ryszard Glowinski, was the owner of a 2000 Freightliner tractor-trailer licensed in the state of New Jersey with registration plate number AE506M. 9. At all times relevant to this cause of action, the Defendant, J. H. Rose Truck Lines, Inc., was a licensed Interstate Commerce Commission carrier and was the lessee of the 2000 Freightliner tractor-trailer owned by the Defendant, Ryszard Glowinski. 10. At all times relevant to this cause of action, the Defendant, Ryszard Glowinski, was the agent, servant and employee of the Defendant, J. H. Rose Truck Lines, Inc., acting within the scope of his authority. 11. At all times relevant to this cause of action, the Defendant, Harold Eugene Pryor was the driver of a 1999 International tractor-trailer licensed in the state of Illinois with registration plate number P323333. 12. At all times relevant to this cause of action, the Defendant, Daily Express, was a licensed Interstate Commerce Commission carrier and was the owner of the 1999 International tractor-trailer driven by the Defendant, Harold Eugene Pryor. ~W OFFICES DILo~"ro, COSENT~NO & Be. aceR PC 330 LINCOLN WAY EAST P.O. BOX 866 CHN~IBERSBURG, PA 17201 13. At all times relevant to this cause of action, the Defendant, Harold Eugene Pryor, was the agent, servant and employee of the Defendant, Daily Express, Inc., acting within the scope of his authority. 14. On September 20, 2000 at about 6:14 p.m., the Plaintiff, Terry L. Hockensmith, was operating a 1999 Volkswagen automobile in a southerly direction in the left hand southbound lane of Interstate 81, near mile post 46, in the Borough of Carlisle, Cumberland County, Pennsylvania. 15. On the same date and time, the Defendant, Harold Eugene Pryor was operating the 1999 International tractor-trailer owned by Daily Express, Inc., in a southerly direction in the left southbound lane of Interstate 81, near mile post 46, immediately behind the Volkswagen automobile driven by the Plaintiff, Terry L. Hockensmith. 16. On the same date and time, the Defendant, Ryszard Glowinski was operating his 2000 Freightliner tractor-trailer, leased to J. H. Rose Truck Lines, Inc., in a southerly direction in the left southbound lane of Interstate 81, near mile post 46, immediately behind the tractor-trailer operated by the Defendant, Harold Eugene Pryor. 17. On the date and at the time above mentioned there was construction work in the southbound lanes of Interstate 81 with signs indicating that the right lane was closed ahead. 18. On the date and at the time above alleged,, the Plaintiff, Terry L. Hockensmith, brought his vehicle to a stop behind a tractor-trailer in the left southbound lane of Interstate 81 in a line of traffic stopped for construction ahead. LAW OFFICES D~LoRErO, COSENT~NO & ~3{.INGER PC ~30 LINCOLN WAY EAST P.O. BOX 866 CHAMBERSBUBG, PA 17201 19. On the date and at the time above mentioned, the Defendant, Ryszard Glowinski, drove his 2000 Freightliner tractor-trailer, leased to the Defendant, J. H. Rose Truck Lines, Inc., into the rear of the 1999 International tractor-trailer driven by Harold Eugene Pryor and owned by Daily Express, causing that tractor-trailer to collide with the rear of the automobile driven by the Plaintiff, Terry L. Hockensmith, and pushing it under a tractor trailer in front of the Plaintiff's vehicle. 20. On the date and at the time above mentioned, the Defendant, Harold Eugene Pryor, drove his 1999 International tractor-trailer, owned by the Defendant, Daily Express, into the rear of the automobile driven by' the Plaintiff, Terry L. Hockensmith, pushing it under a tractor-trailer in front of the Plaintiff's vehicle. 21. As a result of the collisions above alleged, the Plaintiff, Terry L. Hockensmith sustained the following personal injuries: a. closed head injury; b. hard, spondylotic degenerative disc herniation at C5-C6 with impingement on the subarachnoid space and spinal cord requiring cervical discectomy and fusion at C5-C6 with iliac bone crest grafting and structural allografting with an anterior cervical docking plate; c. left temperoparietal cephalohematoma; d. left auricle hematoma requiring excision; e. left sided hearing loss from ossicular disruption; f. bilateral brachial plexus traction injury; g. cervical spine myelopathy; h. complex regional pain syndrome, Type I, whole body; i. scalp laceration; j. major depressive disorder, recurrent, severe; k. post traumatic stress disorder; LAW OFFICES D~Lo~-TO, COS~nNO & BaJ~C,E~ PC 3,30 UNCOLN WAY EAST P.O. BOX 8~ GHAMBERSBURG, PA 1720'1 I. severe exacerbation of gastroesophogeal reflux disease; m. nervous shock 22. As a result of his injuries, the Plaintiff, Terry L. Hockensmith, received medical attention and care, incurring liability for payment of medical bills for that medical attention with the medical providers, on the dates and in the amounts as follows: Provider Date of Service Amount Cumberland Goodwill Fire September 20, 2000 $290.00 West Shore EMG - Carlisle Septernber 20, 2000 $477.21 Hershey Medical Center, (Hsp. Acct) 500 University Drive Hershey, PA 17033 September 20, 2000 $2,865.00 September 20, 2000 to Septernber 24,2000 $4,948.80 September 20, 2000, October 1, 2000 and October 2, 2000 $7,670.25 October 1, 2000 to October 3, 2000 $2,089.25 November 16, 2000 $22.00 November 16, 2000 $293.00 December 7, 2000 $151.00 January 15, 2001 to January 21,2001 January 18,2001 January 18,2001 January 20,2001 January 20,2001to January 26,2001 January 26, 2001 February 15, 2001 February 15, 2001 February 22, 2001 March 10, 2001 March 16, 2001 March 22, 2001 May 8, 2001 August 7, 2001 August 8, 2001 $14,846.20 $483.00 $1,105.00 $306.00 to $8,465.60 $251.00 $278.00 $128.00 $99.00 $1,327.00 $168.00 $99.00 $99.00 $3,553.24 LAW OFFICES D~LORETO, COSEm~O & BO~R PC 3~0 UNCOLN WAY EAST P.O. BOX 866 CHAMBERSBUFIG, PA ~7201 Hershey Medical Center, (Phys. Acct) August 7, 2001 August 8, 2001 August 7, 2001 August 8, 2001 September 4, 2001 September 11,2001 November 21, 2001 April 2,. 2002 April 19, 2002 to April 2'1,2002 May 24, 2002 July 10, 2002 September 25, 2002 Se)tember 20. Se )tember 20. Se )tember 20. Se ~tember 20. Se )tember 20. Se ~tember 20 Se)tember 20 Se ~tember 20 Se :)tember 20 Se ~tember 20 Se ~tember 20 Se ~tember 21 Se 3tember 21 Se 3tember 21 Se3tember 21 Se 3tember 22 Se ~tember 23 Se 3tember 23 Se 3tember 24 October 1 2000 October 1 2000 October 2 2000 October 2 2000 October 2 2000 October 2 2000 October 3 2000 October 17, 2000 November 16, 2000 November 16, 2000 November 30, 2000 2000 2000 2000 2000 2000 2000 2000 2000 2000 2000 2000 2000 2000 2000 2000 2000 2000 2000 2000 to $2,375.49 $1,177.75 $143.00 $220.O0 $2,300.00 $143.00 $7,633.38 $1o8.oo $68.oo $113.00 $2,500.00 $53.00 $74.00 $41.00 $53.00 $52.00 $189.00 $275.00 $291.00 $236.00 $142.00 $98.00 $74.00 $74.00 $140.00 $98.00 $98.00 $98.00 $115.00 $170.00 $189.00 $74.00 $320.00 $390.00 $306.00 $115.00 $66.00 $185.oo $48.00 $80.00 LAW OFFICES DILORErO, COSE~NO & BOL~,mER Pc LINCOLN WAY .EAST P.O. BOX 866 CHAMBERSBURG, PA 17201 December 7, 2000 December 11, 2000 January 2, 2001 January 2, 2001 January 9, 2001 January 10, 2001 January 15, 2001 January 18, 2001 January 18, 2001 January 18, 2001 January 19, 2001 January 19, 2001 January 19, 2001 January 19, 2001 January 19, 2001 January 19, 2001 January 19, 2001 January 19, 2001 January 19, 2001 January 19, 2001 January 19, 2001 January 20, 2001 January 22, 2001 January 23, 2001 January 24, 2001 January 25, 2001 January 26, 2001 February 15, 2001 February 15, 2001 February 22, 2001 March 10 March 10 March 10 March 10 March 16 March 22 March 27, 2001 2001 2001 2001 2001 2001 2001 April 20, 2001 May 8, 2001 May 10, 2001 May 113, 2001 June 6, 2001 July 11,2001 July 20, 2001 $140.00 $165.00 $65.00 $70.00 $120.00 $235.00 $52.00 $252.00 $231.00 $66.00 $6,835.00 $6,868.00 $5,783.00 $2,650.00 $1,207.00 $97.00 $2,051.00 $63.00 $63.00 $63.00 $74.00 $306.00 $196.00 $133.00 $133.00 $98.00 $115.00 $48.00 $175.00 $74.00 $82.00 $265.00 $275.00 $79.00 $120.00 $74.00 $70.00 $85.00 $74.00 $48.00 $85.00 $70.00 $70.00 $89.00 LAW OFFICES D~LoRE~O, COSEm~NO & ~3J.INGER PC ~0 LINCOLN WAY EAST P.O. BOX 866 CHAMBERSBUBG, PA 17201 Keystone Health Center 820 Fifth Avenue Chambersburg, PA 17201 Physical Therapy Associates of Chambersburg 1007 Wayne Avenue Chambersburg, PA 17101 Chambersburg Hospital 112 North Seventh Street Chambersburg, PA 17201 Wide Open MRI of Chambersburg 405 Phoenix Drive, Unit A Chambersburg, PA 17201 Chambersburg Imaging 25 Penncraft Avenue Chambersburg, PA 17201 August 7, 2001 August 8, 2001 August 8, 2001 August 17, 2001 September 4, 2001 September 4, 2001 November 16, 2001 Decernber 21, 2001 January 18, 2002 February 15, 2002 March 15, 2002 April 2, 2002 September 11,2002 October 2, 2002 October 30, 2002 September 26, 2000 October 9, 2000 October 16, 2000 October 19, 2000 October 10, 2000 - November 9, 2001 (Physical Therapy) October 23, 2000 - December 3, 2001 (Occupational Therapy) October 17, 2000 December 17, 2000 March 10, 2001 October 18, 2000 October 17, 2000 $170.00 $599.00 $206.00 $89.00 $53.00 $53.00 $126.00 $89.00 $89.00 $89.00 $89.00 $53.00 $95.00 $95.00 $95.00 $50.00 $70.00 $70.00 $110.00 $11,720.00 $11,323.22 $145.00 $1,544.00 $2,615.00 $905.00 $41.00 LAW OFFICES D~LORETO, COSE~NO & B~.~t,a~ ~c 33O UNCOLN WAY EAST P.O. BOX 866 CHNdBERSBURG, PA 17201 Cumberland Valley Neurosurgical 764 Lincoln Way East Chambersburg, PA 17201 Kreamer Medical December 17, 2000 December 23, 2000 March 10, 2001 December 11,2000 January 26, 2001 $300.00 $198.63 $280.00 $135.00 $143.78 Yakov Vorobeychik, M.D. MCP Hahnemann University Department of Neurology Mail Stop 423 245 N. 15th Street, Suite 1702 Philadelphia, PA 19102 August 5, 2002 $220.00 Prescription Medicine Expenses WalMart Pharmacy September 24, 2000 to September 28, 2000 $197.50 Third Party Solutions September 26, 2000 to October 8, 2000 $212.49 Progressive Medical, Inc. October 9, 2000 to April 2, 2001 $5,859.44 CVS Pharmacy September 24, 2000 $42.59 23. As a result of his injuries, the Plaintiff, Terry L. Hockensmith, will require additional medical attention and care in the future at a cost now undetermined. 24. By reason of the injuries sustained by the Plaintiff, Terry L. Hockensmith, as above set forth, he has endured severe physical, emotional and mental pain, suffering and inconvenience, and will continue to endure physical, emotional and mental pain, suffering and inconvenience for the remainder of his life. LAW OFFICES D~LORE~O, & BOL~.,ER PC 330 LINCOLN WAY EAST P.O. BOX 866 CHAMBERSBURG, PA 17201 25. On the date of the occurrence above set forth, the Plaintiff, Terry L. Hockensmith, was employed by Effective Software Products, Inc., 2038-A Lincoln Way East, Chambersburg, Pennsylvania 17201-3362, working as a software engineer earning an average weekly wage of $1,290.03. 26. As a result of the injuries he sustained, 'the Plaintiff, Terry L. Hockensmith, was totally disabled during the period from September 20, 2000 through November 14, 2000, inclusive, and from May 27, 2002 through the present and continuing into the indefinite future. During the period from November 15, 2001 through May 27, 2002 the Plaintiff, Terry L. Hockensmith worked at reduced earnings as a result of his injuries suffering a partial loss of wages. 27. As a result of the injuries he has sustained, the Plaintiff, Terry L. Hockensmith, has suffered a total destruction of his future earning capacity and the loss of all employee benefits associated with his .employment. 28. As a result of the injuries he sustained, the Plaintiff, Terry L. Hockensmith, will require modifications to his home in order to make it handicap accessible, or will be required to purchase a new handicap accessible residence at a cost undetermined at this time. Terry L. Hockensmith, Plaintiff COUNTONE LAW OFFICES D~LoREro, COS~NmO UN~LN WAY ~T P.O. BOX ~ C~BE~BU~, PA 1~01 VS. J. H. Rose Truck Lines, Inc., and Ryszard Glowinski, Defendants 29. The Plaintiff in this count, Terry L. Hockensmith, incorporates by reference the allegations contained in paragraphs 1 through 28, inclusive, as fully as though set out at length herein. 30. The collision above alleged was proximately caused by the negligence of the Defendant, Ryszard Glowinski, the agent, servant and employee of the Defendant, J. H. Rose Truck Lines, Inc., said negligence consisting of the following: a. Failing to have the 2000 Freightliner tractor-trailer under such control as would allow him to bring it to a stop without colliding with the 1999 International tractor-trailer driven by Harold Eugene Pryor; b. Failing to bring the 2000 Freightliner tractor-trailer to a stop before colliding with the International tractor-trailer operated by the Defendant, Harold Eugene Pryor; c. Driving at a speed that would not permit him to bring the vehicle he was operating to a stop without colliding with the vehicles in front of him in his lane of travel; d. Operating his vehicle in careless disregard for the safety of persons or property in violation of Section 3714 of the Vehicle Code, 75 Pa. C.S.A. Section 101 et. seq.; e. Following the International tractor-trailer driven by the Defendant, Harold Eugene Pryor, more closely than was reasonable and prudent, having full regard for the speed of the vehicles, the traffic backup on the highway, and the condition of the highway, in violation of Section 3310 of the Vehicle Code, 75 Pa. C.S.A. Section 101 et. seq. WHEREFORE, the Plaintiff, Terry L. Hockensmith, demands damages of the Defendants, Ryszard Glowinski and J. H. Rose Truck Lines, Inc., in a sum in excess of the jurisdictional amount requiring arbitration and cost of suit. Darlene K. Hockensmith, Plaintiff COUNT TWO LAW OFFICES D~LORETO, COSEm'~O & BO~.~'C_,ER PC 330 MNCOI..N WAY ~T P.O. BOX ~6 C~gE~BURG, PA VS, J. H. Rose Truck Lines, Inc., and Ryszard Glowinski, Defendants 31. The Plaintiff in this count, Darlene K. Hockensmith, incorporates by reference the allegations contained in paragraphs 1 through 28, inclusive, and paragraph 30, as fully as though set out at length herein. 32. At all times relevant to this cause of action, the Plaintiff, Darlene K. Hockensmith, was the wife of the Plaintiff, Terry I_. Hockensmith, residing with him at 330 Shively Road, Chambersburg, Pennsylvania 17201. 33. As a consequence of the injury sustained by the Plaintiff, Terry L. Hockensmith, as above set forth, the Plaintiff, Darlene K. Hockensmith, has been deprived of the services of her husband, and his society and the comfort of his presence from the date of the accident alleged, and will continue to be so deprived for the remainder of his life. WHEREFORE, Plaintiff, Darlene K. Hockensmith, demands damages of the Defendants, Ryszard Glowinski and J. H. Rose Truck Lines, Inc., in a sum in excess of the jurisdictional amount requiring arbitration, and costs of suit. LAW OFFICES DILORETO, 330 UNCOLN WAY ~T P.O. ~X ~6 CH~BE~BURG, PA 1~ Terry L. Hockensmith, COUNT THREE Plaintiff VS. Daily Express, Inc. and Harold Eugene Pryor., Defendants 34. The Plaintiff in this count, Terry L. Hockensmith, incorporates by reference the allegations contained in paragraphs 1 through 28, inclusive, as fully as though set out at length herein. 35. The collision above alleged was proximately caused by the negligence of the Defendant, Harold Eugene Pryor, the agent, servant and employee of the Defendant, Daily Express, said negligence consisting of the following: a. Failing to have the 1999 International tractor-trailer under such control as would allow him to bring it to a stop without colliding with the Volkswagen automobile driven by the Plaintiff, Terry L. Hockensmith; b. Failing to bring the 1999 International traCtor-trailer to a stop before colliding with the Volkswagen automobile operated by the Plaintiff, Terry L. Hockensmith; c. Driving at a speed that would not permit him to bring the vehicle he was operating to a stop without colliding with the vehicles in front of him in his lane of travel; d. Operating the 1999 International tractor-trailer in careless disregard for the safety of persons or property in violation of Section 3714 of the Vehicle Code, 75 Pa. C.S.A. Section 101 et. seq.; e. Following the Volkswagen automobile driven by the Plaintiff, Terry L. Hockensmith, more closely than was reasonable and prudent, having full regard for the speed of the. vehicles, the traffic backup on the highway, and the condition of the highway, in violation of Section 3310 of the Vehicle Code, 75 Pa. C.S.A. Section 101 et. seq. LAW OFFICES D~LoREro, COSE~T~O & Be.ac. ER ,c 330 UNCOI. N WAY EAST P.O, BOX 866 CHAMBERSBURG, PA 17201 WHEREFORE, the Plaintiff, Terry L. Hockensmith, demands damages of the Defendants, Harold Eugene Pryor, and Daily Express, in sum in excess of the jurisdictional amount requiring arbitration, and costs of suit. Darlene K. Hockensmith, Plaintiff COUNT FOUR LAW OFFICES D~LORE~O, Cosa~ao & BOL~ ~ 3,30 UNCOI. N WAY EAST P.O. BOX 866 CHN~IBERSBURG, PA 17201 VS, Daily Express, Inc. and Harold Eugene Pryor, Defendants 36. The Plaintiff in this count, Darlene K. Hockensmith, incorporates by reference the allegations contained in paragraphs 1 through 28, inclusive, and paragraph 35 as fully as though set out at length herein. 37. At all times relevant to this cause of action, the Plaintiff, Darlene K. Hockensmith, was the wife of the Plaintiff, Terry L. Hockensmith, residing with him at 330 Shively Road, Chambersburg, Pennsylvania 17201. 38. As a consequence of the injury sustained by the Plaintiff, Terry L. Hockensmith, as above set forth, the Plaintiff, Darlene K. Hockensmith, has been deprived of the services of her husband, and his society and the comfort of his presence from the date of the accident alleged, and will continue to be so deprived for the remainder of his life. WHEREFORE, Plaintiff, Darlene K. Hockensmith, demands damages of the Defendants, Harold Eugene Pryor and Daily Express, Inc., in a sum in excess of the jurisdictional amount requiring arbitration, and costs of suit. DILORETO, COSENTINO & BOLINGER PC Date: December 27, 2002 Denis M. DiLoreto, Esquire Attorney for Plaintiffs Supreme Court ID #: 16311 DiLoreto, Cosentino & Bolinger, PC 330 Lincoln Way East P.O. Box 866 Chambersburg, PA 17201 (717) 264-2096 LAW OFFICES D~Lo~-ro, C, osa~o & BOLSTER ,C 330 UNCOI. N WAY EAST P.O. BOX 866 CHAMBERSBURG, PA 17201 II Verification LAW OFFICES DILORETO, COSENTINO & BOLINGER PC 330 LINCOLN WAY EAST P.O. BOX 866 CHNdBERSBURG, PA 17201 We, Terry L. Hockensmith and Darlene K. Hockensmith, the plaintiffs herein, hereby affirm that the facts set forth in the foregoing Complaint are based upon information which we have furnished to counsel, as well as information which has been gathered by counsel and/or by others acting on our behalf in preparation of this Complaint. The language of the Complaint is that of our counsel and not our own. We have read the Complaint and, to the extent that it is based upon information which we have given to counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the Complaint is that of counsel, we have relied upon such counsel in making this verification. We hereby acknowledge that the facts set forth in the aforesaid Complaint are made subject to the penalties of 18 Pa.C.$. Section 4904, relating to unsworn falsification to authorities. T(~rry .L~Hockensmith, Plaintiff Date: /~,/~,~//~.. Darlene K. Hockensmith, Plaintiff