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Home My WebLink About00-07024 ; : . "-,'- "" .-",,'.",,--- ,', ,.",---,.....,"", ANDREWS & JOHNSON Attorneys at Law 78 West Pomfret Street Carlisle, PA 17013-3216 TAYLOR P. ANDREWS RONALD E. JOHNSON Telephone (717) 243-0123 Telefax (717) 243-0061 January 9, 2001 Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, P A 17013 RE: Brown vs. Schlager, et al No: 00-7024 Dear Sir or Madam: 1 am returning herewith the file for the above captioned matter on which I had previously been appointed chairman of the board of arbitrators. The Plaintiff has advised me that this case has been settled and I have instructed her that she should file a Praecipe with the Prothonotary indicating that the action has been settled and discontinued. Accordingly, there is no further action necessary on my part. Should you have any questions, please feel free to contact me. Very truly yours, REJ:ss Enclosure cc: Rick Pierce ANDREWS & JOHNSON ~o~~ - " I -" -" 0"- J _, ~~___, ANDREWS & JOHNSON Attorneys at Law /'--~''''''' ((,. \\.J ~./ ;. 7~..~.,.. ,.;;;:'.f :) ': - i l.~ L 78 West Pomfret Street Carlisle, PA 17013-3216 TAYLQRP. ANDREWS RONALD E. JOHNSON Telephone (717) 243-0123 Telefax (717) 243-0061 December 29, 2000 Leslie A. Brown 140 Hill Lane Mechanicsburg, P A 17050 Dear Ms. Brown: I have been appointed Chairman of the Board of Arbitrators to hear your suit against Megan ScWager, et al. However, in going through the file I do not find a phone number for you and I will need one in order to attempt to schedule a time and date for a hearing. I would appreciate it if you would kindly call my office and leave a phone number where you can be reached during the day so that we can then proceed with scheduling a time for the hearing. Very truly yours, ANDREWS & JOHNSON Ronald E. Johnson REJ:ss Enclosure --"'"',''' L.i- --I ,-,,c,, Le~ie A. 'BfDWfj Ra,rl\{+. vs. M~n 9c.rl~ex-) 'Thomas S:t,1~ 'fuytayo ~~/ ; te(eV\~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CNIL ~ C,OOO 00 - 1024 RULE 1312.1. The Petition for Appointment of Arbitrators sball be substantially in the following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: ghc.e ofliar LeslIe A. 'Bawn,ellllAD81fertheplaintiff(~ . respectfully represe~ts lhat:. 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of tbe plaintiff in the action is $ 91- fj. 53 The counterclaim of tbe defendant in tbe action is ~ ~1lII1 in the above action (or actions), The following attorneys are interested in the case(s) as counselor are otherwise disqualified to sit as arbitrators: baVIr!:1. Freed WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case sball be submitted. RIzs]t:ed' . ORDER OF COURT c2. / .:u'frO ,~_, in consideration of the ~ Esq., ~~.~ Esq., and actions) as prayed for. , Esq., are appointed arbitrators in the above captioned action (or PJ. ! ._ "~~~, . ~, . Yo",,',;...' "" _ .~. -"' _c~~'>., 1);_: ~T ~\)~,Cf;:-lCt .. L:..~.,..,..,. ::"I'!('JT~"v :_",',-, .1_"'",'_.,,1,\\\ 1 ~\, "', ..,. 0 I ..,. nr(' 2 \ \"1"1.)'.' ell UtI.., '" CU\\jieEHJ~,iD COUNT'< PENNSYLVmlA ct C}f P- g: '>- (') ~ ~ S? c Z5 ~.:-:- N 6~ n LLi':=;: ':;1;"'=:, :>1: 0:;7 ~ L-.~-- ~- G.. ,~::J ... ~ '-'"~- ::?:U5 , 0 r"_ 5z ,~" <""-1 & ~, r XZ il~ '-., UJUJ ;i W :nn.. F":"- 0 :?: '6i: , 0 :::J ,-, 0 ~> C) ~--~ - " ;;- ~_. .. . ~~"".., ,,' , '-'--' - -'~., -"'."- -,".,,~.~ ~".,"&'~'." ,"-- .=<~, == _Hr. !If!IlI~~ilk'm!!<~ljj'l'i!l~~~~4, _ _iJrr~Em~..' ~ I'n~ . l:.Jij . ~ -,"~ 1',~",,,,, . COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS NOTICE OF APPEAL FROM JUDICIAL DISTRICT DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. (X)- 700lt..f ~ NOTICE OF APPEAL ~ .,~ /011.;;1100 Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case mentioned below. OTY ~{\\~(i ~UJ0 vs. OONAT~Ej;Z~] , ~ CV 12 ()(X)(J 25(j)-Q) LT 19 This block will be signed ONLY when this notation is required under Po. R.c.P.JP. No. 1008B. This Notice of Appeal, when received by the District Justice, will operate as a SUPERSEDEAS 10 the judgment for possession in this case. Signature of Prothonotary or Deputy If appellant was CLAIMANT (see Pa. R.G.P.J.P. No. 1001 (6) in action before District Justice, he MUST FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see Pa. HC.P.J.P. No. 1001 (7) in action before District Justice. IF NOT USED, detach /rom copy of notice of appeal to be served upon appellee). PRAECIPE: To Prothonotary Enter rule upon , appellee(s), 10 file 0 complaint in this oppeal Name of appe!lee(s) (Common Pleas No. ) within twenty (20) days ofter service of rule or suffer entry of judgment of non pro~ Signature of appeHant 01 his attorney 01 agent RULE: To Name of appel/fre(s) , appellee(s). (1) You are notified that a rule is hereby entered upon you 10 file 0 complaint in this oppeal within twenty (20) days after the dote of service of this rule upon you by personal service or by certified or registered moiL (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL 8E ENTERED AGAINST YOu. (3) The date af service of this rule if service was by mail is the date of moiling. Date: ,19_. Signature oIl'rot1lot101wy or Deputy AOPC 312-84 COURT FILE TO BE FILED WITH PROTHONOTARY - -~~j~II1iiJllW~~iIf"'II4~~~l\liI"""&f""""'="''''"':t:liIli~ .~ ~'-- ~ . - ,- . PROOF OF SERVI(CE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DA YS AFTER filing the notice of appeal, Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA COI.\j,!:rv OF ; .. AFFIDAVIT:' I hereby swear or affirm that I served a copy 01 the Noliceof Appeal. Common Pleas, No. , upon the District Justice designated therein on (date of service) 0 by personal service 0 by (certified) (registered) mail, sender's receipt attached 11ereto, and upon the appeilee.(name) , on . 19_~ 0 by personal service 0 by (certified) (registered) mail, sender's receipt attached hereto. and further that I served the Rule to File a Complaint accompanying the above Notice of Appeal upon the appellee(s) to whom the Rule was addressed on , 19~ 0 by personal service 0 by (certified) (registered) maii, sender's attached hereto. SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF ~____. 19__. Signature of affiant Signature of offiCla! before whom affldi'1vit was made Title of official My commission OKpires on _ ,19~_ 0 a ~,? c 0 ~: ~ "- a "55 n mil" " < \ zx: --l ~ ~ Z,- -:::'!F~ eJ) ,"::- N -<~~: ;5. ~~ ~\..--' \ -,.;; ;<:.\lD ~ \ zC: :E 0 6 6rn ~c ~ Z .-~ =< t',J 55 'D -< " ~ ..... ~, ~ ~ '\j ~ ~ ~ .~o _ ~ - ,-~ "" ~ '""C~~~~, .~"~.~."_ .. __ '_ ..~~h,.4 ", <~".",_~ . . ~_L, .1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mag. Disl. No.: 09-1-02 OJ Name: Hon. ROBERT V. MANLOVE Add",,, 1901 STATE STREET CAMP HILL, PA T",phoo, (717) 761- 0583 17011- 0000 LESLIE A. BROWN 140 HILL LN MECHANICSBURG, PA 17050 THIS IS TO NOTIFY YOU THAT: Judgment: [i] Judgment was entered for: l... "_'___.,,_ NOTICE OF JUDGMENTITRANSCRJPT CIVIL CASE PLAINTIFF: NAME and ADDRESS 'BRoWN, LESLIE A 140 HILL LN MECHANICSBURG, PA 17050 L VS. DEFENDANT: NAME and ADDRESS IsCHLAGER, MEGAN E, ET AL. 2157 DOUGLASS DR CARLISLE, PA 17013 L Docket No.: cv- 0000256 - 00 Date Filed: 7/17/00 FOR DEFENDANT (Name) !'lC'In,lInRR, T",nMlI!'l P [i] Judgment was entered against: (Name) RROWN, T.RIH.n: 1I in the amount of $ 00 on: o Defendants are jointly and severally Iiaole. o Damages will be assessed on: o This case dismissed without prejudice. O Amount of Judgment Subject to AttachmenV Act 5 of 1996 $ o Levy is stayed for days or 0 generaliy stayed. o Objection to levy has been filed and hearing will be held: -- . . - Date: Place: Time: q~J(JD Date My commission expires first Monday of January, AOPC 315-99 (Date of Judgment) q/?%o . . (Date & Time) Amount of Judgment $ .00 Judgment Costs $ .00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ .00 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified JudgJ:llent Total $ < THE ENTRY OF JUDGMENT BY FILING A NOTICE OF COMMON PLEAS, CIVIL DIVISION. YOU SCRIPT FORM WITH YOUR NOTICE OF APPEAL. , District Justice of the proceedings containing the jUdgment. , District Justice 2006 SEAL -- ~_L COMMONWEALTH OF PENNSYL VANIA' COUNTY OF: CUMBERLAND 09-1-02 NbTICE OF JUDGMENTITRANSCRIPl CIVIL CASE PLAINTIFF: NAME and ADDRESS 'BROWN, LESLIE A 140 HILL LN MECHANICSBURG, PA 17050 L Mag. Qis!. No,' OJ Name, HOIl Address: ROBERT V. MANLOVE 1901 STATE STREET CAMP HILL, PA VS. r,I'pho", (717) 761-0583 17011-0000 DEfJ;NDANT: NAME and ADDRESS 'sChLAGER, MEGAN E, ET AL. 2157 DOUGLASS DR CARLISLE, PA 17013 L Docket No.: CV- 0000256.00 Dat<l Filed: 7/17/00 &~- ~ LESLIE A. BROWN 140 HILL LN MECHANICSBURG, PA 17050 THIS ISTO NOTIFY YOU THAT: Judgment: [i] Judgment was entered for: (Name) [i] Judgment was entered against: (Name) . FOR DEFRNDANT Q~HT.l\~11.R. ~l\R~l\Rl\ l\ RROWN, r,EQT.T1>: l\ in the amount of $ on on: (Date of Judgment) Q/'20/00 . D Defendants are jointly and severally liable. D Damages will be assessed on: (Date & Time) D Amount of Judgment Subject to Attachment/Act 5 of 1996 $ Amount of Judgment $ .00 Judgment Costs $ .00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ .00 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ D This case dismissed without prejudice. D Levy is stayed for days or D generally stayed. o .objection to levy has been filed and.hearing will be held: -- Date: Place: Time: ANY PARTY HAS THE RIGHT TO API'! OF APPEAL WITH THE PRO THO T MUST INCLUDE A COPY OF AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU NT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. q~J{j[) , I Date , District Justice record of the proceedings containing the judgment. , District Justice My commission expires first Monday of January, 2006 SEAL AOPC 315-99 THIS ISJONOTIFY_YOU THAT: Judgment: FOR DEFENDANT ~ Judgment was entered for: (Name) !'lC'JH.lIaF.R, MF.aUl F. ~ Judgment was entered against: (Name) BROWN, I.F.SI.TF. A " -' .r COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mag, Disl. No. 09-1-02 OJ Name, Hon ROBERT V. MANLOVE Add"" 1901 STATE STREET CAMP HILL, PA Tel'phoco (717) 761- 0583 17011- 0000 LESLIE A. BROWN 140 HILL LN MECHANICSBURG, PA 17050 in the amount of $ 00 on: o Defendants are jointly and severally liable. o Damages will be assessed On: o This case dismissed without prejudice. O Amount of Judgment Subject to Attachment/Act 5 of 1996 $ o Levy is stayed for days or 0 generally stayed. o Objection to levy has been tiied and hearing will ge held: - , Date: Place: Time: .' ~~:< NOTICE OF JUDGMENTITRANSCRIPl CIVIL CASE PLAINTIFF: NAME alld ADDRESS 'BROWN, LESLIE A 140 HILL LN MECHANICSBURG, PA 17050 L VS. DEFENDANT: NAME and ADDRESS 'sCHLAGER, MEGAN E, ET AL. 2157 DOUGLASS DR CARLISLE, PA 17013 L Docket No.: CV - 0000256 - 00 Date Filed: 7/17/00 (Date of Judgment) Q/20/00 . . (Date & Time) Amount of Judgment $ .00 Judgment Costs $ .00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ .00 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ RY OF JUDGMENT BY FILING A NOTICE RT OF 0 MON PLEAS, CIVIL DIVISION. YOU ORM WITH YOUR NOTICE OF APPEAL. , District Justice c d of the proceedings containing the judgment. , District Justice My commission expires first Monday of January, AOPC 315-99 2006 SEAL ",~ ... ,~ ~I ,liD ,-, ~]"t:ll ,m 1_rV""q", ,I~~"\,,~r,,,~::;.~."~ I,',:!, ':"f.:, -,", -" ): ~r:,,": "lr!I!~.~.'M~~~~~~I~II'~1'l~1,"i, i' ' , "" .~ ' :A~" ~'.!::r ;~"':: ~~~'~"l~O;'" Ii:':' ; I::"~; :i;! . 'I i Ii I 'I. PROOF OF SERVICE OF NOTICE Of APPEAL AN~ f(IJIL~Jc>h~:!!IIC9MPLAIN" . (This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTERfifing fhe n1fide'@fSP+a'f:I'f1eCkSPPfiCSble bo~es) COMMONWEALTH OF PENNSYLVANIA' 'I' Cu.m ~rla1Jd ; s. l COUNTY OF , , , "" i ! AFFIDAVIT: I herebyswear or affirm that I served."I., , ,.' ii" 1li!l. a copyof the Noti'}e of ~P'la.II.. &.<::! ommon ~asNo, DD.- W>. . :,~.'.,. ...... .......'... ..p...Qr.:. In. e.. i~jld.j.~.'.]i.i,',.~.u..s...t..io....a desillnated therein on (dste of service) M c...a:D!lX,~OOOIX ~Y~~~siall!serj(;~IIIR,iq :i(!~111,~~' d)~~register.ed) mail, senders rieiPo~~eto. and upon the appellee, (name) .' I' ,I II. .~o i ::::,,;, I !,:: '" ' on \ . '.~ 15 by personal service o by. (c~~!lje )(Ireglst~r~~} rr~ \1, .,~er'sreceiptattachedhereto la. and further that I served the Rulplo File a compIpJnla~oompanYi~:.~ II... '. .ati.pve'.N~.;,.l\:.~. Qf ~." '. .ponllheap~.ellee(S) to"whorn the. Rule was addr~ssed on J~ DdO~: '. ~~,; I:,'~: ; b~ p~rf~nal: ' I: "~' ~'~: by (certi~ied) (rfi8i'~tsl f! a).. mall, sender's receipt attached hereto. ,~.:i '1" . "Ii' I, . SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS ! 14' . DAY OFtf2:7t4...:" ~~ m;(i:~;~.~./~-~ Signature ~f offipart:iiHare who My commiss16[l t:~tres or-> , I' -- ~. NOTARIAL SEAL PATAICIA A. SHATTO. Notary Public . Oarll810 BOlO, Cumberland County . ~y CommisSion Expires DeCllmber 17. 2001, gniltii}e of sffiant 0';:1 n . -t 'riiJJ r- -,1'11: -.J ::50 06 ~ ~~ 3m :;! w :0 H' -< nus of offi";ial I r U.S. Postal Service CERTIFIED MAiL liECIEIPT (Domes/x Mati Only; No Insurance Coverage ProvIded) 'iI:., '" ru =r '" C Postage $ lr U1 ' Certified Fee ...ll, Return Receipt Fee U1 ;1 (Endorsement Required) .-'l Dr RestrictedDeliveryFee CJ (Endorsement Required) D Total Postage & Fees $ CJ ;;;~;":(P~iti[fb~ta;f~ lr St'2t~loS~as. unre . mHm ~ .tir*f\~St~m"~Am.m\~Oi3....mm....m -- -.0"" - J ~- ',"ill ~~~~\%J;;i~~t~:*'~!;P~j':~"'''-~ii':N#f~';~I'-~~~;''-'";$?':fi-~~':>~i~~~~~!,.}~~'I!~i~~~'~~;~:,J~~~~~~,~~-~~tllM:.~~~,i,;J(i1f!y;U"W!.~~~':,' . . NOTICE OF APPEAL COMMONWEALTH OF PENN$YLVAN'A COURT OF COMMON PLEAS FROM JUDICIAL DISTRICT DISTRICT JUSTICE JUDGIllIENT COMMON PLEAS No. W~ 70;;1 '-I &L!~ NOTICE OF APPEAL ~~,k,1l 10/ WJa.0 Notice is given that the appellant has filed in the above Caurt af Camman Pleas an appeal from the judgment rendered by the District Justice on the date and in the case mentioned below. ""TEOf f~ CV 12 ()(X)(:) 25(j)~'cO LT 19 This black will be signed ONLY when this. natation is required under Pc.. R.c.P.JP. No.' 10081\- This Notice of Appeal, when received by the District Justice, will operate as a SUPERSEDEAS to' the judgment for possession in this case. OTY NIl e ('\\21 (I \Csbu ( <) ""i:;xow n MAG. 015T. NQ OR NAME OJ. 09, \ -02- ATEeR ""\ (Delent:kntj vs. \X\ 8(\ ~::(Y\ \ r SIGNATURE Of tPPElLA7, HIS n EY n AGENT ~~( Q1. .it};" w .~. plcu __ If appellant was CLAIMANT (see Pa. R.cP.JP. No. 1001 (6) in action before District Justice, he MUST FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. ZP CODE nD~O OAIM Signature of Prothonotary or Deputy P"~ECIPE'TO EIl.lTERIU:JLE TO FILE COM~LAINT AND RULE TO FILE (This section of fonn tbbe used ONLY when appellant was DEFENDANT (see Pa. RCP.JP. No. 1001(7) in action before Disuict Justice. IF NOr USED, detach trom copY' of notice of appeai to be served upon appellee). ., PRAECIPE: To Prothonotary Name of appellee(S) , appellee(s)..to.file a cornp1aiht in..ihis appeal Enter rule upon (Cornmon Pleas No. ) within twenty (20) days after service of rule or suffer. entry (W;~dgm!!l\t of non pro~ Signature of appeIfant or his attorney or agent RULE: To Name of _eM , appellee(s). (1) You are natified that a rule is hereby entered upan you to file a camplaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do nat file a complaint within this ~me, a JUDGMENT OF NON PROS WILL 8E ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of mailing. Date" ,-,j '-. ,19_. Sig1alure of AothonoIwy or Depuly J N:)PC 31:f_84 COURT FILE ..-.... ....... .. . ..... - ,,,,'of".., -_'",~,:.,,-.'''' ,- ',>'_~ , " ..~' - " '" "I" -, '," w="'~" ",-_0, ;:, _";",, <,;-,;- ,.~ ",~-''''J.;':_ ,:~'>:,;~,;';;'~,,'~i~~'~-,;,.i''-,::- "",""", ' " < "'J"": ~ LESLIE A. BROWN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO.: 00-7024 MEGAN SCHLAGER, THOMAS SCHLAGER, AND BARBARA SCHLAGER Defendants CIVIL ACTION. LAW JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendants, Megan Schlager, Thomas Schlager and Barbara Schlager, with regard to the above- captioned matter. Respectfully submitted, NEALON & GOVER By: .J:>-\.~ David J. Freed, Esquire Attorney 1.0. #76622 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 .'< ,-,~,--" '-". -" ".-- ," ~--~ "' " ~ ,-,;;' - .,} , -,,:-<. ,~- ~, -~"" '-""'" . ~;;, : - - '-"',;:J .. CERTIFICATE OF SERVICE AND NOW, this 1st day of December, 2000, I hereby certify that I have served the foregoing Praecipe entering my appearance on the following by depositing a true and correct copy of the same in the U.S. Mail, post prepaid, addressed to: Leslie A. Brown 140 Hill Lane Mechanicsburg, PA 17050 3\~~ David J. Freed, Esquire , .',' -"",""',-,,,",,,', '~, ,_ -' -0 - '.w'- ' >"" ....-- .' ,. Leslie A. Brown Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA NO. 00-7024 VS. Megan ScWager, Thomas ScWager, Barbara ScWager Defendants 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 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. PA LAWYER ASSISTANCE SERVICE (800) 692-7375 NOTICIA Le han demandado a usted en lacorte. Si quiere defenderse de e estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. U sted debe presentar una aparlencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandaas en contra 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 0 nitificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted pueded perder dinero 0 sus propiedades 0 otros derechos imprtantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO, VA Y A EN PERSONA 0 LLAME POR TELEFONO A LA OFICIANA CUY A DIRECCION SE ENCUENTRA ESCRIT A ABAJO PAP A A VERIGUAR DONDE SE PUEDE CONSEGUlR ASISTENCIA LEGAL. PA LAWYER ASSISTANCE SERVICE (800) 692-7375 ~,.,~-- ,~' ,. " _ ~ __ t -,.,,--, ",-'- .' ~~',';j ~ Leslie A. Brown IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. NO: 00-7024 Megan ScWager, Thomas Schlager Barbara ScWager Defendants COMPLAINT 1 - Plaintiff, Leslie A. Brown of 140 Hill Lane, Mechanicsburg P A 17050 is filing a civil complaint against 2 - Defendants, Megan E. ScWager, Thomas P. ScWager, and Barbara A. Schlager all residing at 2157 Douglas Drive, Carlisle PA 17013 3 - Insurance company of defendants is Allstate Insurance - policy # 052612350 06/09 4 - Insurance Company of the Plaintiff is State Farm 5 - Plaintiff vehicle is a 1990 Mazda Miata MX-5 bearing PA registration. FPI0543 (this vehicle was bearing a registration plate ofPA - CCZ 9866) 6 - Defendants vehicle is a 1996 Pontiac Sunfrre bearing P A registration YKJ498 7 - Tuesday, 20 June, 2000 at 0752 hours, Defendant, Megan ScWager and Plaintiff were involved in an accident. 8 - This accident occurred on Interstate 81 North between mile marker 62 and 63. 9 - Both vehicles were traveling northbound at approx. 70 MPH. This was admitted by both parties in Court. 10 - Plaintiffs vehicle was traveling in the far right lane of travel. 11 - Defendants vehicle was traveling in the middle lane of travel. 12 - Plaintiffs vehicle was slightly behind the Defendants vehicle when the Defendant swerved over the dotted white line for the first time. 13. - The Defendant, Megan, then drove back into the middle lane of travel and continued driving there. ~~ ",..,,- "~., .' -b" ,", ".'."}'-':'_ "- " ~-, ,,' '~,,,i ,-~.-" ",,+>1 ~ - 14 - The Plaintiff moved to the side of the Defendants vehicle. The vehicles were being driven side by side. 15. The Defendant then moved her vehicle into the right lane of travel, striking the drivers side of the Plaintiffs vehicle. 16 - The Plaintiff was forced to the berm of the roadway and began to slow. The Defendant continued to drive northbound on Interstate 81. 17 - The Plaintiff gave chase and followed the Defendants vehicle until they both pulled to the side of the roadway to exchange information. This was approximately one-half to one (1/2 - 1) mile from where the accident occurred. 18 - The Police were not called to the scene of the accident as there were no injuries reported at the time and neither vehicle required towing. *NOTE* - The Plaintiff is a Police Officer and was in full uniform at the time of the accident. 19 - After exchanging information, both parties left the scene. 20 - Plaintiff contacted State Farm insurance and was told Allstate would be handling this claim as the defendant was clearly at fault for the accident. State Farm did take note of the claim and filed this accident under claim # 381379747. 21 - Plaintiff then contacted Allstate Insurance Company and was given a claim number of 1553828474 by Kim Troup, Claims Adjuster for Allstate. 22 - A taped statement was taken and the Plaintiff was told to take the vehicle to the Claims Office at 6415 Carlisle Pike, Mechanicsburg for evaluation. 23 - The Plaintiff had obtained two (2) written estimates on the damage to the vehicle before taking the vehicle to the Claims Office. Freysinger Mazda had given an estimate to the Plaintiff in the amount of $701.08 and Dellingers Auto Body Inc. had given an estimate in the amount of $795.82. 24 The Plaintiff went to Allstate Claims Office on 6 July, 2000 at 0930 hours and met with Leuny Kemble, Appraiser. 25 - Kemble called Freysinger Mazda and got an estimate of$616.50. Kemble stated that this is an insurance discounted price and if Freysinger works directly with Allstate, this is the price that Allstate will pay. 26 - Kemble then told the Plaintiff that Allstate Claims had not yet given permission for the Plaintiffs vehicle to be repaired. A copy of the Allstate estimate was given to the Plaintiff. The Plaintiff was informed that Allstate would be contacting her to give fmal approval for the vehicle repair. _H .'- -A ,-~ - ,'''~ . I ,'. ~,'- ~- -- , T -. 27 - On approximately 20 July, 2000, Kim Troup, Allstate Agent, again called the Plaintiff. The Plaintiff was informed that although Allstate was accepting responsibility for the accident, they would only pay ninety percent (90%) of the Allstate estimate and only ninety percent (90%) of a rental vehicle. The Plaintiff was informed that the reason for this was because of the speed involved. According to Ms. Troup, the Plaintiff should have slowed her vehicle to allow the Defendant to move into her lane of travel. 28 - The Plaintiff informed Allstate Claims Rep, Ms. Troup that this was an unacceptable offer, since Megan ScWager admitted fault for the accident and Allstate agreed. The Plaintiff was informed that this was their only offer and they would not negotiate another. 29 - After contacting State Farm Insurance again, the Plaintiff was informed that one of the options for retrieving money for damages due was to sue the owners and the driver of the striking vehicle in civil court. 30 - The Court case was set for 7 September, 2000 at 1400 hours, at District Justice Manloves office (District Court 09-1-02). 31 - At the hearing, the Defendant, Megan Schlager, stated on the witness stand that she, "did not see the other car and when I changed lanes, I hit her." 32 - The District Justice found for all three Defendants. The Plaintiff and the Defendants Attorney were informed of this decision via the US Mail. 33 - The lowest estimate for which the Plaintiff would be able to have the vehicle fixed is the estimate received through Freysinger Mazda at $701.08. 34 - The Plaintiff is also seeking monetary damages for a vehicle rental while the Mazda Miata is in the garage. An estimate through Enterprise rent a car was for an economy vehicle at a cost of $29.95 a day. For a five day repair, the rental vehicle would cost $149.75. 35 - The Plaintiff is therefore seeking damages in the amount of $850.83 plus reimbursement for court costs. Respectfully Subrnitte kL Q. Officer Leslie A. Brown ~,-",,-,' r-','",,";'i!""-'liWilii_~ " "=~~- '-~ -A1lii!l1ltig' ~iitii'li!!2;i;~I~jr;w;.gM-lw.1iIii~ . -, . -" "~'>"'- . ,'" ,"~ " ',~ .. , ~,,~ '-'''" ,~, ~ lMil" "~,-'" >~Ii!'iIli ...;,~'"~-~~""" ~, () ~ "TJ fY; n'1""r zii zr- U) _<",7' ~~:: '7 =< o ~ "' "~ ~- 'I ~ o o o CJ -< Q " --1 -q 1-'-..0.;; 2; ......; ; :~2 ".-:._~ < (-j ", ~-'--n C..-I' :::..~ ~::::) -< ", -~,~ ;:- <:::> OM ,> ."- '- ,~,' ~ '~- , ~?,'," '_'__' -' ,_ ~,_" ;__m - --"", ---,.',',,' O-"C~'I I -_, r LESLIE A. BROWN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 00-7024 v. MEGAN SCHLAGER, THOMAS SCHLAGER, AND BARBARA SCHLAGER Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED ANSWER TO THE COMPLAINT AND NOW, Comes Megan Schlager, Thomas Schlager and Barbara Schlager, by and through their attorneys, Nealon & Gover, P.C., and file the following Answer: 1. Admitted, upon information and belief. 2. Admitted. 3. Admitted. 4. Admitted, upon information and belief. 5. Admitted, upon information and belief. 6. Admitted. 7. Admitted. 8. Admitted. 9. Admitted in part and denied in part. It is admitted that both vehicles were traveling northbound. The remainder of this paragraph is denied pursuant to Pa. R.C.P. 1029(e). 10-11. Upon reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment and proof is demanded at trial. . --~ ""' ,~, ","- ~>' ^ " ,~". ''-',~ ~ " 12. Denied, pursuant to Pa. RCP. 1029(e). 13. Denied, pursuant to Pa. RC.P. 1029(e). 14. Admitted in part and denied in part. It is admitted that Plaintiffs vehicle and the Schlager vehicle were beside each other prior to the collision. The remainder of the paragraph is denied pursuant to Pa. R.C.P. 1029(e). 15. Admitted in part and denied in part. It is admitted that a collision occurred between Plaintiff and the Schlager vehicle. The remainder of this paragraph is denied pursuant to Pa. RC.P. 1029(e). 16. Admitted in part and denied in part. It is admitted that the Plaintiff pulled over. It is denied that the Defendant continued to drive northbound on Interstate 81. To the contrary, she pulled over when it was safe to do so. 17. Denied. See answer to Number 16. 18. Admitted. 19. Admitted. 20-26. Upon reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment and proof is demanded at trial. 27. Admitted in part and denied in part. Defendants believe and, therefore, aver that an offer in settlement was made to the Plaintiff. Defendants are without knowledge or information sufficient to form a belief as to the remainder of this paragraph and proof is demanded at trial. ,." ,. - - ,~-, ~ "_ '__r - ",,", ;,< ,~,_ _. .;",. 28-29. Upon reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment and proof is demanded at trial. 30. Admitted. 31. Denied. Defendants specifically deny that the statement alleged herein was made. By way of further answer, Megan Schlager did state that a collision occurred as Plaintiff was passing her on her right. 32. Admitted. 33. Upon reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment and proof is demanded at trial. 34. Admitted in part and denied in part. Defendants admit that Plaintiff is undoubtedly seeking additional damages. The Defendants are without knowledge or information sufficient to form a belief as to the actual amounts expended, if any, and proof is therefore demanded at trial. 35. Admitted. Respectfully submitted, NEALON & GOVER BY:~~ David J. Freed, Esquire Attorney 1.0. #76622 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 ,.--. ..." " ~'" ..-""' .,'-' ~~,'~ ^ - .' " ',' ~"-i",", >.n__", '> '~'-"_ ," '.-, <~ ~,";;;_\j,;;~;;';',~:c'.,' ';,. ___;co--' ,--;,;'\,;,-j! VERIFICATION We, verify that the statements made in the foregoing Answer to the Complaint are true and correct. We understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to unsworn falsification to authorities. Dated: lJ.)" Jov I f .JJ+' eg n chlager - Dated: J2lll1 C5(J \ Thomas Schlager \;( ~- ~ /1 Dated:). 1m _&A~~JJr Barbara Schlager . -:~";-'-~"'_ff."" ;~'.", -,,'.'.----,,-- ..'""", .'. -- ",;.,; '~'- ' -,',-'".." '''-,,' CERTIFICATE OF SERVICE AND NOW, this 18th day of December, 2000, I hereby certify that I have served the foregoing Answers to the Complaint on the following by depositing a true and correct copy of the same in the U.S. Mail, post prepaid, addressed to: Leslie A. Brown 140 Hill Lane Mechanicsburg, PA 17050 -~\~ David J. Freed, Esquire . '. LESLIE A. BROWN V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 00-7024 CIVIL MEGAN SCHLAGER, THOMAS SCHLAGER, and BARBARA SCHLAGER IN RE: APPOINTMENT OF ARBITRATORS ORDER OF COURT AND NOW, January 10, 2000, the Court having been informed that the above- captioned action has been settled, the panel of arbitrators previously appointed is vacated. By the Court, . Ho er, P.J. t~~ 01-10 -0 / ~J(5 Court Administrator Ronald Johnson, Esquire Chairman