PLAINTIFF,

VS.

SHERYL DELEY, ET AL

DEFENDANTS.

The Defendant, SHERYL DELEY, whose last known address 4604 Rhode Island, #8, Youngstown, Ohio 44515, otherwise whose address is unknown, and cannot with the exercise of reasonable diligence be ascertained and upon whom service of summons cannot be had in the State of Ohio, will hereby take notice that on the 17th day of August, 2004, the Plaintiff, Christine Malcomson, filed a Complaint in Tort in the Court of Common Pleas of Mahoning County, Ohio, the same being Case Number 04CV 2886 in said Court, against Sheryl Deley, alleging that

On or about August 19, 2002, Plaintiff was the operator of a certain motor vehicle, which was travelling west on Mahoning Avenue in the City of Austintown, County of Mahoning and State of Ohio. At approximately the same time and place, the Defendant, Sheryl Deley, was operating her motor vehicle and negligently operated such so as to forcibly collide with the Plaintiff's automobile in which Plaintiff was the driver, thereby causing Plaintiff serious and permanent injuries and damages. It was the duty of Defendant, Sheryl Deley, to operate her motor vehicle with due care and caution and in accordance with the applicable statutes and ordinances in effect at the aforesaid time and place. Defendant, Sheryl Deley, failed to use due care and caution and in accordance with applicable statutes and ordinances when she negligently, carelessly, and/or recklessly struck Plaintiff's motor vehicle in the rear. As a direct and proximate result of the Defendant, Sheryl Deley's aforesaid negligence and as a direct and proximate result of the collision, Plaintiff sustained injuries of a personal and pecuniary nature, including but not limited to, medical expenses, lost wages, pain and suffering and physical and emotional trauma. Furthermore, Plaintiff has suffered pain and will, with reasonable certainty, continue to so suffer in the indefinite future. As a direct and proximate result of the Defendant, Sheryl Deley's negligence, Plaintiff was required to obtain hospital and medical care for her injuries and to expend sums of money therefore, and she will, with reasonable certainty, continue to require further medical care and treatment and pay additional sums therefore in the indefinite future.

The prayer of the Complaint is for judgment against the Defendant in an amount which will fully, fairly, and completely compensate the Plaintiff pursuant to the laws of State of Ohio in excess of $25,000.00 for the costs in this action and interest.

You are required to answer Plaintiff's Complaint within Twenty-eight (28) days from the last date of publication of this notice, which will be published for six (6) successive weeks, said answer day being the 1st day of November, 2005.

In case of your failure to answer or otherwise respond as required by the Ohio Rules of Civil Procedure, judgment by default will be rendered against you for the relief demanded in the Complaint.

ZUZOLO, ZUZOLO & ZUZOLO

BY:  RALPH A. ZUZOLO,

  Plaintiff's Attorney.

Aug 30; Sep 6,13,20,27; Oct 4, 2005   05-01545