HomeMy WebLinkAbout07-0994PAUL F. D'EMILIO, ESQUIRE
ATTORNEY I.D.# 16654
905 W. SPROUL ROAD SUITE 105
SPRINGFIELD, PA 19064
(610) 338-0338
ATTORNEY FOR PLAINTIFF
THIS IS AN ARBITRATION MATTER
ERIE INSURANCE GROUP : COMMON PLEAS COURT OF
AS SUBROGEE OF PRESTON BRANDT : CUMBERLAND COUNTY
4901 LOUISE DRIVE
MECHANICSBURG, PA 17055
VS.
ALEXANDER GOULD
1408 REGINA STREET
HARRISBURG, PA 17103
AND
NO. 99
VALARIE C. GOULD
1408 REGINA STREET
HARRISBURG. PA 17103 CIVIL ACTION
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 CLAIM 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„ GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU
WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE
MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT
AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 Bedford Street
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
AVISO
Le han demandado a usted an la corte. Si usted quiere defenderse
de estas demandas expuestas an las paginas siguientes, usted tiene
(20) dias de plazo a partir de la fecha de la demanda y la notificacion.
Usted debe presentar una apariencia escrita o en persona o por
abogado y archivar en la corte sus defensas o sus objeciones a las
demandas encontra de su persona. Sea avisado que si usted no se
defiende, la corte tomara medidas y puede entrar una orden contra
usted sin previo aviso o notificacion o por cualgier queja o alivio qua
espedido an la peticion de demanda. Usted puede perder dinero, sus
propiedades o otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI
NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE
PARA PAGAR TAL SERV1C10, VAYA EN PERSONA O LLAME POR
TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA
ESCRITA ABAJO PARA AVERIGUAR DONDE USTED PUEDE
CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
32 Bedford Street
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
PAUL F. D-EMILIO, ESQUIRE
ATTORNEY I.D.# 16654
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064
(610) 338-0338
ATTORNEY FOR PLAINTIFF
THIS IS AN ARBITRATION MATTER
ERIE INSURANCE GROUP : COMMON PLEAS COURT OF
AS SUBROGEE OF PRESTON BRANDT : CUMBERLAND COUNTY
4901 LOUISE DRIVE
MECHANICSBURG, PA 17055
VS. NO.
ALEXANDER GOULD
1408 REGINA STREET
HARRISBURG, PA 17103
AND
VALARIE C. GOULD
1408 REGINA STREET
HARRISBURG. PA 17103 CIVIL ACTION
NOTICE UNDER THE FAIR DEBT COLLECTION PRACTICES ACT,
15 U.S.C. §1601 (AS AMENDED)
THE PENNSYLVANIA UNFAIR TRADE PRACTICES ACT
AND CONSUMER PROTECTION LAW,
73 PA.CON.STAT.ANN. §201, ET. SEQ. ("THE ACTS")
INASMUCH AS THE ACTS MAY APPLY, PLEASE BE ADVISED
THAT THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
COMPLAINT
The Plaintiff, Erie Insurance Group by its attorney Paul F. D'Emilio, Esquire,
bring this action upon a cause whereof the following is a statement:
The Plaintiff, Erie Insurance Group is a Corporation, having an office at 4901
Louise Drive, Mechanicsburg, PA 17055.
Plaintiff brings this action as subrogee of Preston Brandt, (herein the "Insured")
under a policy of insurance # Q051905481, issued by Plaintiff.
2. Defendant, Alexander Gould, is an individual residing at 1408 Regina Street,
Harrisburg, PA 17103.
3. Defendant, Valarie C. Gould, is an individual residing at 1408 Regina Street,
Harrisburg, PA 17103.
4. At all times hereinafter mentioned the Defendant, Alexander Gould was
the agent, workman, servant and employee of the Defendant, Valarie C. Gould then
and there in engaged in the business of the Defendant, Valarie C. Gould within the
course and scope of his employment
5. On or about October 5, 2005 a motor vehicle owned by the Defendant, Valarie
C. Gould and operated by the Defendant, Alexander Gould, was traveling on Rt. 581,
Camp Hill PA when it tried to change lanes and struck the Insured's vehicle causing the
damages hereinafter set forth.
6. As a result, Plaintiffs Insured's suffered a right shoulder recurrent SLAP tear and
right shoulder chondromalacia glenohumeral joint.
7. Plaintiff avers that the motor vehicle of the Insured was damaged as a result of
the occurrence hereinbefore mentioned, the reasonable costs of repairs thereto being is
Three Thousand Fifteen and 54/100 ($3,015.54) Dollars plus the Insured's deductible
of Five Hundred and 001100 ($500.00) Dollars plus the cost of a replacement vehicle
being Four Hundred and 00/100 ($400.00) for a total of Three Thousand Nine
Hundred Nineteen and 54/100 ($3,915.54) Dollars. A true and correct copy of the
checks issued is attached hereto, made part hereof and marked Exhibit "A."
8. As a result of the injuries to Plaintiffs Insured's and Defendant's failure to
maintain financial responsibility as required by law, Plaintiff may be obligated to paid to
the Insured a sum not in excess of Twenty Five Thousand and 00/100 ($25,000.00)
Dollars pursuant to the uninsured motorist's provisions of its insurance policy.
Count I
Erie Insurance Group v. Alexander Gould
9. Plaintiff, Erie Insurance Group, incorporates by reference all of the allegations
2
contained in paragraphs 1 through 8 inclusive of this Complaint as fully as though same
were herein and set forth at length.
10. The said occurrence was due solely to the negligence of the Defendant,
Alexander Gould in that he:
a. did fail to have the motor vehicle under proper and adequate control;
b. did operate the motor vehicle at an excessive rate of speed;
C. did fail to apply the brakes in time to avoid the collision;
d. did negligently apply the brakes;
e. did fail to operate the vehicle in accordance with existing conditions;
f. did fail to drive at a speed and in the manner that would allow him to stop
within the assured clear distance ahead;
g. did fail to keep a reasonable lookout for other vehicles lawfully on the
road;
h. did operate the motor vehicle without due regard for the rights, safety and
position of the Insured at the point of aforesaid;
i. did fail to maintain financial responsibility as required by the Laws of the
Commonwealth of Pennsylvania; and
j. did violate the various statutes and laws of the Commonwealth of
Pennsylvania and County of Cumberland pertaining to the operation of motor vehicles.
Count II
Erie Insurance Group v. Valarie C. Gould
11. Plaintiff, Erie Insurance Group, incorporates by reference all of the allegations
contained in paragraphs 1 through 10 inclusive of this Complaint as fully as though
same were herein and set forth at length.
12. The said occurrence was do to the negligence of the Defendant, Valarie C.
Gould, in that she:
a. negligently entrust her vehicle to another operator for use when she knew,
3
or with a reasonable exercise of due care should have known, that the operator was not
capable of operating the motor vehicle properly;
b. negligently entrust her motor vehicle to a person which she knew, or in the
exercise of reasonable care should have known, was an incompetent driver;
C. negligently entrust her motor vehicle to a person known, should have
known or in the exercise of reasonable care would have known, was going to drive the
vehicle in an improper, dangerous or reckless manner;
d. negligently entrust her motor vehicle to another person who she knew,
should have known or in the exercise of due care would have known would cause
damages to another;
e. negligently entrust the motor vehicle to a person who did not maintain
financial responsibility as required by the laws of the Commonwealth of Pennsylvania;
and
f. failing to maintain financial responsibility as required by the laws of the
Commonwealth of Pennsylvania.
WHEREFORE, Plaintiff demands judgment against the Defendants upon each
count in an amount not in excess of Fifty Thousand and 00/100 ($50,000.00) dollars
together with costs of suit.
a6.1'f ??QL ?'
L F. ILIO, ESQUIRE
ATTORNEY FOR PLAINTIFF
4
VERIFICATION
I, , Subr
PLAINTIFF in the above captioned
foregoing Complaint are true and
made subject to the penalties of 1 8
falsification to authorities.
DATE:
ogation Representative with Erie Insurance Group,
matter verifies that the facts contained in the
correct. I understand that false statements herein are
Pa. C.S. Section 4904 relating to unsworn
- a\,? ay?A
Subrogation Representative
Exhibit "A"
p,.f
08/22/2006 Claims Management System
09:48 Check Print
CSPP032B
Page: 1
Req: ROWLES ,C
-------------------------------------------------------------------------------
CHECK NO 17308100 CMS NO Q308100 DATE 10/17/2005
Pay THREE THOUSAND FIFTEEN AND 54/100
$$$$$$3,015.54
PRESTON V. & SHARON L. BRANDT AND
CLARK'S AUTO BODY Operator Loss Date
To The 924 BALTIMORE STREET 273MURLATT 10/05/2005
Order GARDNERS, PA. 17324
of Claim Tax Id No
010170830887
For PAYMENT OF
COLLISION
1997 FORD F-150 TRK
Cashed
C 10/26/2005
-------------------------------------------------------------------------------
CHECK NO 17357060 CMS NO Q357060 DATE 10/28/2005
Pay FOUR HUNDRED AND 00/100
ENTERPRISE RENT-A-CAR
PF.NRAr TWC
Order HARRISBURG, PA 17106 1770
of
For PRESTON BRANDT/D706537-5710/57MA-002112
TRANSPORTATION EXPENSE - COLLISION
C
$$$$$$$$400.00
T.n?G T)r7tP.
1v) V.J J, L'VVJ
Tax Id No
5216906650
Cashed
11/04/2005
-------------------------------------------------------------------------------
CHECK NO 21123696 CMS NO U123696 DATE 06/05/2006
Pay FORTY-THREE AND 79/100
$$$$$$$$$43.79
FIRST CHOICE REHABILITATION
SPECIALISTS PC Operator Loss Date
To The 550 N 12TH STREET_ ##100 2N5SHISTLE 10/05/2005
Order LEMOYNE, PA 17043 1242
of Claim Tax Id No
010170830887 2324893250
For PAYMENT FOR COST OF COPYING MEDICAL RECORDS
OF PRESTON BRANDT. Cashed
C 06/12/2006
c. i ? ll ltl : ? . i 1 .L
Claim
010170830887
08/22/2006 Claims Management System CSPP032B
09:48 Check Print Page: 2
Req: ROWLES ,r
------- ----------------------------------
CHECK NO 21260142 ----------------------
CMS NO U260142 DATE ----------------
06/26/2006
Pay FORTY-ONE AND 44/100
$$$$$$$$$41.44
CHARTONE INC
PO BOX 152471 Operator Loss Date
To The IRVING, TX 75015 2471 2N5REYNOLDS 10/05/2005
Order
of Claim Tax Id No
010170830887 9433606910
For PAYMENT FOR COPYING MEDICAL RECORDS OF
PRESTON BRANDT. Cashed
------- INV##: 101085-1-126313
---------------------------------- C
----------------------- 07/05/2006
---------------
------- ----------------------------------
CHECK NO 21430685 -----------------------
CMS NO U430685 DATE ---------------
08/15/2006
Pay TWE NTY-FIVE THOUSAND AND 00/100
$$$$$25,000.00
PRESTON BRANDT
924 BALTIMORE PIKE
D
erator
D
Loss to
a .?
...: al .-. _ .r, ?.• L - L7 ?J "Y a..ai-. rraal rriL+. 11. ?`v.i, v .?
Order
of Claim Tax Id No
010170830887
For FINAL SETTLEMENT OF UNINSURED MOTORIST CLAIM
------- FOR INJURIES SUSTAINED IN LOSS ON
---------------------------------- 10/5/05.
-----------------------
---------------
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PAUL F. D'EMILIO, ESQUIRE THIS IS AN ARBITRATION MATTER
ATTORNEY I.D.# 16654
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064
(610) 338-0338
ATTORNEY FOR PLAINTIFF
ERIE INSURANCE GROUP : COMMON PLEAS COURT OF
AS SUBROGEE OF PRESTON BRANDT : CUMBERLAND COUNTY
VS. : NO. 07-994
ALEXANDER GOULD
AND
VALARIE C. GOULD CIVIL ACTION
PRAECIPE FOR JUQGMENT AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY, C.P.:
Enter Judgment in the above entitled matter in-favor of the Plaintiff, Erie
Insurance, and against the Defendants, Alexander Gould and Valarie Gould, for want of
an answer, and assess Plaintiffs damages in the sum of $28,915.54 in accordance with
a Complaint filed.
AUL F. D' MILIO, ESQUIRE
ATTORNEY FOR PLAINTIFF
ATTORNEY I.D. #16654
Prothy a esses Plai ffs damages in the sum of $28,915.54.
PRO 7Y
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III : l! JV 8- OW LOOZ
PAUL F. D'EMILIO, ESQUIRE
ATTORNEY I.D.# 16654
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064
(610) 338-0338
ATTORNEY FOR PLAINTIFF
THIS IS AN ARBITRATION MATTER
ERIE INSURANCE GROUP' .
AS SUBROGEE OF PRES*ON BRANDT
VS. :
ALEXANDER GOULD .
AND .
VALARIE C. GOULD
COMMON PLEAS COURT OF
CUMBERLAND COUNTY
NO. 07-994
CIVIL ACTION
AFFIDAVIT OF LAST KNOWN MAILING
ADDRESS OF DEFENDANTS AND PLAINTIFF
Paul F. D'Emilio, Esquire, attorney for Plaintiff in the above-entitled matter
hereby certifies that the following is the last known mailing address of the Defendants
and Plaintiff:
DEFENDANTS
ALEXANDER GOULD
1408 RE INA STREET
HARRISBURG PA 17103
VALERIE C. GOULD
1408 REG INA STREET
HARRISB URG, PA 17103
PLAINTIFF: ERIE INSP RANCE GROUP
4901 LO ISE DRIVE
MECHA ICSBURG, PA
SWORN TO AND SUB CRI ED
BEFORE ME THIS 3Oh DAY
OF APRIL, 2007
NOTARY PUBLIC
17055
(?,)4j :k??
PAUL F. D'EMILIO, ESQUIRE
ATTORNEY FOR PLAINTIFF
91 :I1'V 8- P'tr LOR
A URIC' ]Hi E0
PAUL F. D'EMILIO, ESQUIRE
ATTORNEY I.D.# 16654
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064
(610) 338-0338
ATTORNEY FOR PLAINTIFF
ERIE INSURANCE GROUP'
AS SUBROGEE OF PRESTON BRANDT
COMMON PLEAS COURT OF
: CUMBERLAND COUNTY
VS. NO. 07-994
ALEXANDER GOULD
AND
CIVIL ACTION
AFFIDAVIT AS TO NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
: SS
COUNTY OF CUMBERLAND
PAUL F. D'EMILIO, being duly sworn according to law, deposes and says that he
is the agent for the Plaintiff a ove-named and is authorized to and does make this
Affidavit on its behalf; and t at he has knowledge of the facts set forth herein:
That Defendants, AleXlander Gould and Valarie C. Goud, are over twenty-one
years of age and that they are not in the military service of the United States or
otherwise within the provisions of the Soldier's and Sailor's Civil Relief Act of 1940
as amended.
SWORN TO AND SUBSCRI ED
BEFORE ME THIS ; oOfh DRAY
OF APRIL, 2007
NOTARY PUBLIC -
J
P L F. 'E ILIO, ESQUIRE
THIS IS AN ARBITRATION MATTER
S I: I I 'v1 ' 8-,Viii [lo 0Z
7,Hi JG
PAUL F. D'EMILIO, ESQUIRE
ATTORNEY I.D.# 16654
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064
(610) 338-0338
ATTORNEY FOR PLAINTIFF
THIS IS AN ARBITRATION MATTER
ERIE INSURANCE GROUP'
AS SUBROGEE OF PRESTON BRANDT
VS.
ALEXANDER GOULD
AND
VALARIE C. GOULD
COMMON PLEAS COURT OF
CUMBERLAND COUNTY
NO. 07-994
CIVIL ACTION
T
I, PAUL F. D'EMILIO, ,ESQUIRE, attorney for the Plaintiff, Erie Insurance
Group, does hereby certify that a Notice of Intent to Enter Default Judgement was
mailed on April 4, 2007 to the Defendants listed below by Certificate of Mailing; a copy
of the Notice and the originall, certification of mailing are attached hereto, made a
part hereof, and marked Exhibit "A".
Alexander Gould Valerie C. Gould
1408 Regina Street 1408 Regina Street
Harrisburg, PA 17103 Harrisburg, PA 17103
PAUL F. D'EMILIO, ESQUIRE
ATTORNEY FOR PLAINTIFF
t
! :11 7 8- ?VW L001
ElHi JO
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION- LAW
(Rule of Civil Procedure No. 236)
ERIE INSURANCE GROUP', : COMMON PLEAS COURT OF
AS SUBROGEE OF PRESTON BRANDT : CUMBERLAND COUNTY
VS.
ALEXANDER GOULD
: NO. 07-994
AND ,
VALARIE C. GOULD CIVIL ACTION
Notice is given that a judgment in the above captioned matter has been entered
against you and 2007.
Prothonotary
If you have any questions concerning the above please contact:
Paul F. D'Emilio. Esquire
Attorney or Party Filing
905 West Sproul Road. Suite 105
Address
Springfield, PA 19064
City, State, Zip
(610) 338-0338
Telephone Number
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION- LAW
(Rule of Civil Procedure No. 236)
ERIE INSURANCE GROUP : COMMON PLEAS COURT OF
AS SUBROGEE OF PRESTON BRANDT : CUMBERLAND COUNTY
VS. NO. 07-994
ALEXANDER GOULD
AND
VALARIE C. GOULD CIVIL ACTION
Notice is given that a ?udgment in the above captioned matter has been entered
against you on p( , 2007.
Prothonotary
If you have any questions concerning the above please contact:
Paul F. D'Emilio. Esquire
Attorney or Party Filing
905 West Sproul Road, Suite 105
Address
Springfield. PA 19064
City, State, Zip
(610) 338-0338
Telephone Number
EXHIBIT "A"
?- v
U.S. POSTAI
w
PF
OF
LAW OFFICE
PAUL F. D'EMILIO
905 WEST SPROUL ROAD, SUITE 105
SPRINGFIELD, PENNSYLVANIA 19(
One piece of ordinary mail addressed to:
Mr. Alexander Gould
1408 Regina Street
Harrisburg, PA 17103
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PS Form 3817, January
PAUL F. D'EMILIO, ESQUIRE
ATTORNEY I.D.# 16654
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064
(610) 338-0338
ATTORNEY FOR PLAINTIFF
THIS IS AN ARBITRATION MATTER
ERIE INSURANCE GROUP : COMMON PLEAS COURT OF
AS SUBROGEE OF PRESTON BRANDT : CUMBERLAND COUNTY
VS. : NO.
ALEXANDER GOULD
AND
VALARIE C. GOULD : CIVIL ACTION
DATE OF NOTICE: APRIL 4, 2007
TO: ALEXANDER GOULD
1408 REGINA STREET
HARRISBURG, PA 17103
NOTICE OF INTENT TO ENTER DEFAULT JUDGMENT
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING
WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET
FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE
DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING
A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
LAWYER REFERRAL SERVICE
FOR CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
PAUL F. D'EMILIO, ESQUIRE
905 West Sproul Road, Suite 105
Springfield, PA 19064
(610) 338-0338
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U.S. POSTAL SERVICE
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LAW OFFICE
PAUL F. D'EMILIO
905 WEST.SPROUL ROAD, SUITE
SPRINGFIELD, PENNSYLVANIA
One piece of ordinary mail addressed to: c^ Dv O
Ms. Vala,'rie C. Gould ? ?../
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Harrisburg, PA 17103
PS Form 3817, January
PAUL F. D'EMILIO, ESQUIRE
ATTORNEY I.D.# 16654
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064
(610) 338-0338
ATTORNEY FOR PLAINTIFF
THIS IS AN ARBITRATION MATTER
ERIE INSURANCE GROUP : COMMON PLEAS COURT OF
AS SUBROGEE OF PRESTON BRANDT : CUMBERLAND COUNTY
VS. : NO.
ALEXANDER GOULD
AND
VALARIE C. GOULD : CIVIL ACTION
DATE OF NOTICE: APRIL 4, 2007
TO: VALARIE C. GOULD
1408 REGINA STREET
HARRISBURG, PA 17103
NOTICE OF INTENT TO ENTER DEFAULT JUDGMENT
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING
WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET
FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE
DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING
A LAWYER.
LAWYER REFERRAL SERVICE
FOR CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-31
L F. 'EMILI , ESQUIRE
9'65 West Sproul Road, Suite 105
Springfield, PA 19064
(610) 338-0338
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2007-00994 P
P COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ERIE INSURANCE GROUP
VS
GOULD ALEXANDER ET AL
R. Thomas Kline , Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT to wit:
GOULD ALEXANDER
but was unable to locate Him in his bailiwick. He therefore
deputized the sheriff of DAUPHIN County, Pennsylvania, to
serve the within COMPLAINT & NOTICE
On March 7th , 2007 , this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs: So answer
Docketing 18.00
Out of County 9.00 ::x?
Surcharge 10.00 R. Thomas Klin
Dep Dauphin County 35.25 Sheriff of Cumberland County
Postage 2.31
74.56 V 31-1,0 1.4 7
03/07/2007
PAUL D'EMILIO
Sworn and subscribe to before me
this day of ,
A.D.
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2007-00994 P
'COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ERIE INSURANCE GROUP
VS
GOULD ALEXANDER ET AL
R. Thomas Kline , Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT to wit:
GOULD VALARIE C
but was unable to locate Her in his bailiwick. He therefore
deputized the sheriff of DAUPHIN County, Pennsylvania, to
serve the within COMPLAINT & NOTICE
On March 7th , 2007 , this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs: So answer
Docketing 6.00
Out of County .00
Surcharge 10.00 R. Thomas ne
.00 Sheriff of Cumberland County
.00
16.00 ? 31aeol
03/07/2007
PAUL D'EMILIO
Sworn and subscribe to before me
this day of
A. D.
In The Court of Common Pleas of Cumberland County, Pennsylvania
Erie Insurance Group
VS.
Alexander Gould et al No. 07-994 civil
SERVE. Alexander Gould
Now, February 22, 2007 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Dauphin County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
Affidavit of-Service
Now, , 20 , at o'clock M. served the
within
upon
at
by handing to
a
and made known to
So an swers,
Sheriff of
COSTS
Sworn and subscribed before SERVICE $
me this day of , 20 MILEAGE
- AFFIDAVIT
copy of the original
the contents thereof.
County, PA
(§)ffite of tke S§4-rrt-ff
Mary Jane Snyder
Real Estate Deputy
William T. Tully
Solicitor
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 780-6590 fax: (717) 255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania ERIE INSURANCE GROUP ETC
vs
County of Dauphin GOULD ALEXANDER
Sheriff's Return
No. 0279-T - - -2007
OTHER COUNTY NO. 07 994
Charles E. Sheaffer
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
AND NOW:February 28, 2007 at 9:22AM served the within
NOTICE & COMPLAINT
GOULD ALEXANDER
upon
by personally handing
to SUZANNA GOULD 1 true attested copy(ies)
of the original NOTICE & COMPLAINT and making known
to him/her the contents thereof at 1408 REGINA STREET
HARRISBURG, PA 17103-0000
Sworn and subscribed to
before me this 1ST day of MARCH, 2007
11-0 X?(/
NOTARIAL SEAL
MARY JANE SNYDER, Notary Public
Highspire, Dauphin County
My Commission Expires Sept. 1, 2010
So Answers,
? )( e,;?
Sheriff of Dauphin County, Pa.
s
By
Deputy Sheriff
Sheriff's Costs:$35.25 PAID BY COUNTY
MARTIN
In The Court of Common Pleas of Cumberland County, Penlasylvanla
Erie Insurance Group
vs.
Alexander Gould et al
SERVE: Valarie C. Gould No. 07-994 civil
Now, February 22, 2007 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of DauplAn County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
Affidavit of Service
Now,
within
upon
at
by handing to
a
and made known to
20 , at o'clock M. served the
copy of the original
So answers,
the contents thereof.
Sheriff of
Sworn and subscribed before
me this day of , 20
COSTS
SERVICE _
MILEAGE _
AFFIDAVIT
County, PA
mif-tre of t4e ?*4eriff
f
Mary Jane Snyder
Real Estate Deputy
William T. Tully
Solicitor
Dauphin County
Harrisburg, Pennsylvania 17101
ph:(717)780-6590 fax:(717)255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania ERIE INSURANCE GROUP ETC
vs
County of Dauphin GOULD ALEXANDER
Sheriff's Return
No. 0279-T - - -2007
OTHER COUNTY NO. 07 994
Charles E. Sheaffer
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
AND NOW:February 28, 2007 at 9:22AM served the within
NOTICE & COMPLAINT
GOULD VALARIE
upon
by personally handing
to SUZANNA GOULD 1 true attested copy(ies)
of the original NOTICE & COMPLAINT and making known
to him/her the contents thereof at 1408 REGINA STREET
HARRISBURG, PA 17103-0000
Sworn and subscribed to
before me this 1ST day of MARCH, 2007
Z! [/
NOTARIAL SEAL
MARY JANE SNYDER, Notary Public
Highspire, Dauphin County
My Commission Expires Sept. 1, 2010
So Answers,
? ?* e,??
Shexiff of Dauphin County, Pa.
By _
Deputy Sheriff
Sheriff's Costs:$35.25 PAID BY COUNTY
MARTIN