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Home My WebLink About96-00192 ~, \ d1 c - 'c,.. l5 3 . 7' ~i I "..~ i< ~, , , '" ~ oj ~ o } 1 : j! , I l j " "-'< 'i , i~ ! .' I , I , , , ! i I , , ..'~ j " ! /'"" ), I ' !.-;' ~ q, Jl , nJ 0- - , ~ 0- I ! ,I I CHAMP, 0' 10llIO, McCONCIIJ E (, Jo'OIWBS, P,C, BY: GARY C, llJ:;NUWl, BSUUllll~ M"J'OIlNEY I ,U, NO, 30~OO 215 NOH'I'II OLIVE S'!'IlEE'!' MEDIA, PA 1906J (610) %5-1700 , ,I I MONICA A. GUNNELLS 1105 Galway Court lIummelstown, PA 1'/036 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. CIVIL ACTION - LAW vs. JEFFREY WOTIUNG 5424 Springtide Drive Harrisburg, PA 17109 Defendant NO. 96- ~--.lLA IN'}' 1, The Plaintiff Monica A. Gunnells is an adult individual residing at 1105 Galway Court, Hummelstown, Pennsylvania 17036. 2. The Defendant Jeffrey Wotring is an adult individual residing at 5424 Springtide Drive, Harrisburg, PA 17109. 3, On or about January 21, 1994, the Plaintiff Monica A. Gunnells was traveling on Route 581 when she stopped behind a line of vehicles which had stopped due to icy conditions in Camp Hill, Cumberland County, Pennsylvania. 4. At the same time and place, the Defendant Jeffrey Wotring was traveling on Route 581 when he collided with the driver's door of Plaintiff's stopped vehicle, causing injuries to the Plaintiff as more specifically described herein. 5. Defendant Jeffrey Wotring was negligent in that he: ( a) operated his vehicle at a high and excessive rate of speed, under the circumstances; (b) failed to keep his vehicle under proper and adequate control; -2- (c) failed to keep a careful look-out on the roadway for other occupants of the roadway, of which Plaintiff was one; (d) operated his vehicle in violation of the traffic laws of Pennsylvania designed for the safe and smooth flow of traffic upon the highways; (e) operated his vehicle in a careless, negligent and wantonly reckless manner with respect to Plaintiff; (f) failed to use due care under all of the circumstances; and (g) was otherwise grossly negligent and reckless with respect to Plaintiff, wantonly 6. As a result of the Defendant's aforesaid negligence, Plaintiff Monica A. Gunnells suffered permanent internal and external injuries which rendered her sick, sore, lame and disabled. She was hurt, wounded, cut and bruised in and about her head, limbs and body, and more particularly, she sustained an aggravation to her neck. She also suffered injuries to her nerves and nervous system together with severe nervous shock. 7. As a further result of the Defendant's aforesaid negligence, Plaintiff has been and will be obliged to receive medical treatment and incur various medical expenses for injuries she has suffered. 8, As a further result of the Defendant's aforesaid negligence, Plaintiff has suffered and continues to suffer severe physical pain, disability, mental anguish and humiliation, all of which Plaintiff believes and therefore avers will be permanent. " -J- 9. As a further result of the Defendant's aforesaid negligence, Plaintiff has been unable to attend to her usual duties and occupation and will, in the future continue to be so disabled, all to her great damage, injury and loss. 10. As a further result of the Defendant's aforesaid negligence, Plaintiff has suffered a loss of wages and a loss of wage earning capacity, and will, in the future, continue to suffer an impairment of wage earning capacity. 11. Some or all of Plaintiff's injuries are permanent and her expenses, loss earning capacity, loss of life's pleasures and disabilities are permanent, 12. None of the aforesaid injuries sustained by Plaintiff were due, in any part, to any negligence on the part of Plaintiff, but rather due solely and exclusively to the negligence, carelessness, and recklessness of the Defendant, WHEREFORE, Plaintiff Monica A. Gunnells demands jUdgment against the Defendant in an amount in excess of Twenty-Five Thousand ($25,000.00) DOllars, plus costs. Cramp, D'Iorio, McConchie & Forbes, P,C. ) n BY:~~ GARY C. BENDER, ESQUIRE Attorney for Plaintiff ~ C\J ~. ,'r; lO (-. j:~ wP ().. . ~r..- f'; 2~ _J;l, '..0 IfL G'.:!': r-' :2j .. . . '.'. I )Ll '1"-, .....:.. .~. ~ :;~ '.j'l)) J:: ,...... .:;,'1 ;:,'''' ". c \') :-.) (...\ t.J \ <.r') . ~/ ~l -, c; ~'} \~ p (\~ ..J r" L.-;, 0(,) ....... ~ ~ f") rJ) en 1"1 )/llr to' (I. is I ftj (. (7 ' '- I ) -, t' I ' , nv- t llll ~.L-, f'-. tL_I\.L lLCtL., ),0 lL-l / I; j l t.t,'''', ''0 ' . \ .~i(f 71L'1 u I~ IV. ('iq, f jr;IVY'U-1 r{l}{'!'~, /lH' lu_.tK~tL~L \ 'd..,U! r' if-lt\. LL , - . ~= w ~ ~re QJ'" - z >0 ~ cJ lit; ~. 'M.-i Po ~~ III I.ll' I c:l.-i ~ ' ~ w ~ I~I t.!l QJ E-< ;~~. ~ li!l'tll<l: li!l OlD ~ ~ lC 8 i H Uli!l ~'.::JPo j ~~~:;i~ uf~ t.!l E-< tll . 0... 0 ci; III , Ol:ltll !i! bQ~z':~5 ra. E-< , Ul ~'M I.l 0 o ~ 1<1: > I.l ::l U ~~ C ~ ~. >< p",Q ~1Il~ tj ~IIlUl 'M a: ~ H !::",I.l U o!~ ~ NI.l :II ~"'rtl uuu ltllIl '. \ 01. -:=:.\'\ . - o ~C)~ -- . ' ,I 'I' . :IfEl\lfT':, 1:1'1'11"'1 1 q lilli' \. tilJlITY C/\'':':E NIt: lq'l("\.O~>'ll:I~"\ l' Cnt1l'!(INW!-:AI.T11 Ui' "I,:tH/::Yl,VA/l 1,\, CliUllTY 111' lUMIlEhLANl' GUNNEI.I.'-, tll.lNlCA A ._~.._._.. .___.a_. __._ _ ._. . V ~~J. !'IQTh IIILi JEI'TIIEY "R: .Tt'~IIl!~iP J\t.i nl~. ShOTi ft, whu bVlnu duly sworn according " to t,lW, Ui:l}'U, lh.:1t hc) I1lj'H..h? a dl1inpnt uEiiJrch Hod i.nquiry Lor the within na'll\~d df:,Jt:.odrtfl l, t (I w j t: ....w.PTJjJJ~G~, }~~fEH.E;_Y.."...,._,^ ~"'___'"_'>__'''''~_'._H_.'_''___'___'''__~_..'__~.'_'' bu I lIijG unab 1(' t l) local<' __,______,__ JUJ1.1..____,__, ] n tllS b,n J i>r 1 c:1<, He thc'refore dpplltl~:<<d Ii'll' ulH:'nif oJ ___ ,__,,_JJ_I\jlI'Jli!.L_~__________,__ Counti'. Pf!nnsyJvanin, to sIn VI- t hl' W 1 t h j n __Q:1!:!f'J,AJ.ll.I_ __,.., ____...____..,.___..______,_________.____..,_______M_______h On r'-?~.r..l~a.ryn_ ?_tl~",_.1 '~~1I~. lhic office waD in receipt of thl? nltactll_-'d return fl'l~m .*.Pl\q['H 1.N" H_'_'~_____' __.._..'~.. Cnu III i'. Peonsi'l Vtlrl 1 a. Sht!riff's Coctu: So anfJW.~:l ~1: DClCk....U flU !Jut of CotuJt,}' SUl"charrp=, DAUPIl r II COUlny jI), I/I,~ 9.0l"t ;,,00 J~', ~jO ':,'j"l;!j('J I~RAl1P {>' IOJ,Hl MCCIlNCHIE FORBES (1:-: / ('7 / 11)':')(; " , /'" (.;,~~ -~,y.~_/ .- ,.-.... I ,;.oo:._r ....,- .' ff., / - #-,,) . f. . . ..., .. R, ""li"um"" --riTTii,;;--~SlIE'rTrr------ Sworn Hl1li nUbt.5Cr-lbl.?d t.IJ ['1:'1 or ~:,. f1\f' IJ;.. _I thilJ1~_,___ da}' of ,;.~tH!(l'J ,_______.._H, 19___'/c.... A,('I, n L<- (/, )H'-';.~ 1\..(lf"''J, ---..~-_.~---.~T'(--~ltli(:lni~;('~il.); (- . . 'fn The Court CT C.:mmO:i Fl=:s or C:Jr,::..-:~!t'i=nd C'::l.l:-;~'YI Panr:syl'lcni: Moneia ft. Gunnells 'IS. Jeffrey Wotring ::-fo, c)fi-192 C;j\1il rr~rrn ---. :~--- ~OWt .1Bnunrv 17. tgqfj '9 T S._""--- 0- "'~""-:-:lT """ CO'........... :::l" ~ . _ _, .~~:' = _.........;:)..::.._~,JJ "-.,. _, ..~ i;Q =:=y c!..ruci:::: d:: Sh:tE ol nRllphin C~u.:ty :0 ~~::-Jt: ::is '.V:::, :!::s L-puc.:icu b=r _",.l_ u :::: ~ =.ci ~..sk ~i :he ?!3!::i. ...,. ,~ _~....'-;1 ,. , ." , --::,,,,-- '-.1:,"- ,..,/ ./'/./_ _~. "' ;' ...:::::.:;:,,~,r~ 7 ....::::--.:..! SlI~ at C=:!lu'..JI:d C~W1n'. :':10 . Amcavit of Sem= :iow, ~9 .. o'dea ~L 1=.-= . .. == ~t!:iD 'JpcllI ~~ =r =c:i!:1r :0 a. c::pr oi == :)::;:....,. .. :lZld ::&ci: lc:awu :0 . :.~::::i. ::e -==:t:::S So UlSW=, ShCa' at eoWlrr. 1:10 =: :!::s _ ,:.,y oi !9_ COSTS sza,'..,,.,CZ ~!!U,AGE A~:jJJA""11' s Swcr: =d SlI!:sc-.bd ee:~ --""""----. s r_ ---t CRAMP, D'IORIO, McCONCHIE & FORBES, P.C. BV: GARV C, BENDER, ESQUIRE ATTORNEV 1.0, NO. 30408 215 NORTH OLIVE STREET MEDIA, PA 19063 (610) 565-1700 MONICA A. GUNNELLS , COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNA. . . . vs. . CIVIL ACTION - LAW . JEFFREY WOTRING (l'tllt,J~ Defendant . NO. 96- /(i2- . NOT ICE 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(s). 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 LAWVER 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 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 TAUE COPY PROM RECORD In Ttsttmonv wllIraaI, IIln _ lit ,'v hand IllCII ~I of sa II CarlisI., P~'I" 04 {. lla . 19-p- '. CRAMP, D'IORIO, McCONCHIE & FORBES, BY: GARY C, BENDER, ESQUIRE ATTORNEY 1.0, NO, 30408 215 NORTH OLIVE STREET MEDIA, PA 19063 (610) 565-1700 P.C. MONICA A, GUNNELLS 1105 Galway Court Hummelstown, PA 17036 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA, CIVIL ACTION - LAW vs. JEFFREY WOTRING 5424 Springtide Drive Harrisburg, PA 17109 Defendant NO. 96- COMPJ.AINT 1. The Plaintiff Monica A. Gunnells is an adult individual residing at 1105 Galway Court, Hummelstown, Pennsylvania 17036, 2, The Defendant Jeffrey Wotring is an adult individual residing at 5424 springtide Drive, Harrisburg, PA 17109. 3. On or about January 21, 1994, the Plaintiff Monica A, Gunnells was traveling on Route 581 when she stopped behind a line of vehicles which had stopped due to icy conditions in Camp Hill, CUmberland County, Pennsylvania. 4. At the same time and place, the Defendant Jeffrey Wotring was traveling on Route 581 when he collided with the driver's door of Plaintiff's stopped vehicle, causing injuries to the Plaintiff as more specifically described herein. 5. Defendant Jeffrey wotring was negligent in that he: (a) operated his vehicle at a high and excessive rate of speed, under the circumstances; (b) failed to keep his vehicle under proper and adequate control; -2- (c) failed to keep a careful look-out on the roadway for other occupants of the roadway, of which Plaintiff was one; (d) operated his vehicle in violation of the traff ic laws of Pennsylvania designed for the safe and smooth flow of traffic upon the highways; (e) operated his vehicle in a careless, negligent and wantonly reckless manner with respect to Plaintiff; (f) failed to use due care under all of the circumstances; and (g) was otherwise grossly negligent and wantonly reckless with respect to Plaintiff. 6. As a result of the Defendant's aforesaid negligence, Plaintiff Monica A, Gunnells suffered permanent internal and external injuries which rendered her sick, sore, lame and disabled, She was hurt, wounded, cut and bruised in and about her head, limbs and body, and more particularly, she sustained an aggravation to her neck. She also suffered injuries to her nerves and nervous system together with severe nervous shock. 7. As a further result of the Defendant's aforesaid negligence, Plaintiff has been and will be obliged to receive medical treatment and incur various medical expenses for injuries she has suffered, 8. As a further result of the Defendant's aforesaid negligence, Plaintiff has suffered and continues to suffer severe physical pain, disability, mental anguish and humiliation, all of which Plaintiff believes and therefore avers will be permanent. -J- 9, As a further result of the Defendant's aforesaid neqliqence, Plaintiff has been unable to attend to her usual duties and occupation and will, in the future continue to be so disabled, all to her qreat damaqe, injury and loss. 10, As a further result of the Defendant's aforesaid neqligence, Plaintiff has suffered a loss of wages and a loss of waqe earninq capacity, and will, in the future, continue to suffer an impairment of wage earning capacity. 11. Some or all of Plaintiff's injuries are permanent and her expenses, loss earning capacity, loss of life's pleasures and disabilities are permanent. 12, None of the aforesaid injuries sustained by Plaintiff were due, in any part, to any neqligence on the part of Plaintiff, but rather due solely and exclusively to the negligence, carelessness, and recklessness of the Defendant. WHEREFORE, Plaintiff Monica A. Gunnells demands jUdgment against the Defendant in an amount in excess of Twenty-Five Thousand ($25,000.00) Dollars, plus costs. cramp, D'Iorio, Mcconchie & Forbes, P.C, ) BY: ( '..;;ve. c2 GARY C. BENDER, ESQUIRE Attorney for Plaintiff f. ~- J:l \ ' , ~o( O~ Q)'" C ePo :>0 w Ul ........ - I ~r- :~~ ~ 1:1.... ~ cJ alii . i UQ) ~~jW ~ o I ~'tll( ~ .ff! 1 ~ I ~ ~8li: '... Po U p\-IJ H 011I ~)( ~ E-t t1I . ~ jill: ~:iil:!i uf~ . Ol:t1I !212zoci~1ll ~ fJ 0( . ~.... ~ ~ U! ~ ::l c.~~~.: !i o 0( tJ :> >< o..c 0 ::lUlU! u , c/O ~. f;llllo-1 '... 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