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HomeMy WebLinkAbout01-04852IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE INSURANCE COMPANIES, Subrogee of Todd Frey, CASE NO: Dl r ~t~5a A /I Plaintiff, 7 (~!r/~/' v. GARY REED, TYPE OF PLEADING: COMPLAINT IN CIVIL ACTION Defendant. FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: SHERRY D. LOWE, ESQUIItE Pa. LD, #66096 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 W WR # 02306448 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVH, DIVISION PROGRESSIVE INSURANCE COMPANIES, Subrogee of Todd Frey, Plaintiff, vs. GARY REED, Defendant. CaseNo.: ~ l- ~ ~J~a CIYt NOTICE TO DEFEND 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 objecfions 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 maybe entered against you by the court without further nofice 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE INSURANCE COMPANIES, Subrogee of Todd Frey, Plaintiff, CASE NO: ©/ ~ [~ ~~ ~ n ` - ~J v. GARY REED, Defendant. COMPLAINT IN CIVIL ACTION AND NOW COMES, Plaintiff, Progressive Insurance Companies, Subrogee of Todd Frey, by and through its counsel, Sherry D. Lowe, Esquire and WELTMAN, WEINBERG & REIS, CO., L.P.A., and hereby files this Complaint against Defendant, Gary Reed. In support thereof, Plaintff avers as follows: Plaintiff, Progressive Insurance Company, (hereinafter referred to as Progressive"), is a corporation with registered office located at P.O. Box 43258, Richmond Heights, Ohio. 2. Defendant, Gary Reed, is an adult individual with a last lmown address of 2 Stuart Street, Apt. 2, Mount Holly Springs, Cumberland County, Pennsylvania 17065. 3. Progressive issued a policy of insurance where Progressive agreed to insure a 1991 Suzu Swift GT, VIN# 2S2AC34S9M6601404 ("Insured Vehicle"), owned by Plaintiff s insured, Todd Frey. 4. At all times mentioned herein, Progressive's insured was the owner of said Insured Vehicle and Progressive's Insured had insurance coverage for his wife, Zoann Frey. 5. At all times mentioned herein, it is believed and therefore averred that Defendant Gary Reed ("Defendant Owner") was the owner and driver of a Chevy s-10 Blazer ("Defendant Owner's Vehicle"). 6. At all times mentioned herein, Defendant Owner did not have valid insurance coverage in violation of Pennsylvania's Motor Vehicle Financial Responsibility Law, 75 Pa.C.S.A. Section 1785. 7. On or about August 22, 1999, Defendant Owner negligently operated Defendant Owner's Vehicle causing damage to the vehicle owned and operated by Progressive's insured by striking the Insured Vehicle. 8. As a direct and proximate result of Defendant's negligence, the vehicle owned by Progressive's Insured sustained property damages in the amount of $292.71. 9. As a direct and proximate result of Defendant's negligence, Progressive's Insured's wife sustained bodily injury in the amount of $2,349.12 for which Plaintiff s insured made a claim for uninsured coverage since Defendant did not have insurance coverage at the time of the accident. 10. Pursuant to the terms and conditions of the insurance policy, Progressive paid the sum of $2,641.83, which represents the property damages sustained to its Insured's Vehicle and uninsured motorist claim by its Insured, as a result of Defendant's negligence. A true and correct copy of the record of the drafts paid by Progressive to and on behalf of its Insured is attached hereto as Exhibit "A" and made a part hereof. 11. Under the terms of the insurance policy issued by Progressive, its insured also sustained damages in the amount of $500.00, which represents the deductible amount under the policy of insurance. 12. Pursuant to the insurance policy issued by Progressive and as a result of said aforesaid payment, Progressive became subrogated to the claim of its Insured against Defendant. 13. Pursuant to Progressive's right of subrogation, Progressive is presently due and owed from Defendant the sum of $3,141.83, which represents the property damage claim of $292.71, uninsured benefits of $2,349.12 and the deductible payment of $500.00 suffered by Plaintiff s insured. 14. Repeated demands have been made upon Defendant for payment of the aforesaid sum; however, Defendant has willfully failed and refused to pay the sum due and owing to Progressive. WHEREFORE, Plaintiff, Progressive Insurance Companies, Subrogee of Todd Frey, demands Judgment against Defendant, Gary Reed, in the amount of $3,41.83 and costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. Respectfully Submitted: WELTMAN, WEINBERG & REIS, CO., L.P.A. Sh owe, Esquire PA I.D. # 66096 Weltman, Weinberg & Reis, Co, L.P.A. 2718 Koppers Bldg. 436 7~` Avenue Pittsburgh, PA 15219 (412)434-7955 WWR # 02306448 ro Pi "~ b w 'y ro y O w °' ~~ w r o C M ~K y y 3 y Y r Y IJ'~ r a Q~ i •• O r r N W Ill a O r a O /~/~ J 4i ' V O d C~ W O O W N m `~ O H z toil O v MN N A ^1 Y A 7 ~ K 3 N ~ ~ H a d R O N r M 0 H A N z o y n c ~ y 9 2 d R m w ~ ~ ~ N ~ ~ x w O N N N / "` o N y mo o ° a . o u, to 9 y 0 Y ~ N y rt Y N H N R N ~!? d ~ n '~ 0 ~ w m r ,~ G~ N O b w ~ rt ~' 'i n H * ~ ~ +E ro ~^ ~' ~ m ~P ~ ' a ~ 0 N q .p n ~ W ~ ~ ~ ~ to N N :t ~ m Y N y p~ N I f. O~`Z O N Z R y O A~ g~ YY ~-y7 K M ~O ~N In La y H b~ ~ ~ ~ yO.~~ ~ ro q i 0 O r O 'bl~ m ~ k '4 O ~ r Ol y ~ r o 0 :~ `c m K :+~ ~yy d m F~ ~ + ~ ~ O O } K y N 4 y' ~ * ~ Y ~ o k ~ ~' 3 *~ • ~ i ~ p 4 ~~ 'O b ~ ~ N w N ~ ~ ~ ajb 0 K 'V ~ p~ lwll ~ ~ ~ r d 7 H ~ a w ~y m 7 yy s Y. w o w °o V o N N m K r] w ~m oy o 7 ~ o R xmx ~ o a "" . ~~7L~ to L-~ £ z y H M y ~ ~ ~ O r3 K y Y ~fl y : %Q7 ~ _ + O ~ N N N O r , ~ * ~ o '~ o ~n V : K ~ ~ ~ \ a ~ w * y~l N d o ~ y ** W t ~ ~ * M * t m M ~ ~ i _ ~~ ~ k W O i h r •: ~ f 4 rt N < ~ i W • 4 :k ~}~ V~ k * ~ ~ k W ": ~ ,. h 2 ~ ~ ~ a -J O r a O r^^ ~uu 4/•~ V ~ya,~ d ~./ 0 N ~ O '~ N N C O H Cxil N O ro M H ~° r v ~ ~ 3 N H N H P• b R b H d ^+1 0 H p P N z d d O £ H z m d m m ~ ~ 2 Y N ~ O N N N M c m ~ r a m P b H m 0 r y `0 N H H ~ r N iy ~ n ~ N 0 ~ w " N ~ ri z d gg N Y ~ ~^ C m ~' w * ~ ~ Fl N %~ ro ~ ~ 1P * N a r 4 ro w ~ K' v rP %' R ~ N ~ ~ ~ N l0 J N N Y ~ N w VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, she is an attorney for the Plaintiff herein; makes this Verification based upon the facts as supplied to her by the Plaintiff and/or its agents and because the Plaintiff is outside the jurisdiction of the court and the Plaintiff s Verification cannot be obtained within the time allowed for filing of this pleading, and that the facts set forth in the foregoing pleading are true and correct to the best of her knowledge, information and belief. ~~- Sheny D. Lowe, Esquire ~ °~ ~~, i ~~J V D a~~+; m ;~ d ~/J r ~ ~~ ~ ~ ~ -_ ~~ , r~~~ 1 y ~ i _.. \~ -~ .~ =: ..0 . z ~~~ ~~ -, ~~,~~ o!C}m` ~; m~ ~~ - ~, 0' N. ~' ~ ° 70 ~ "t -< ^ 1~ -,~~~k ~..-~~.,_ ~ -~~.. r + SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-04852 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PROGRESSIVE INSURANCE COMPANIE VS REED GARY R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT REED GARY but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , the within named DEFENDANT REED GARY NOT FOUND as to PER POST OFFICE, MOVED LEFT NO FORWARDING ADDRESS. Sheriff's Costs: Docketing 18.00 Service 4.55 Not Found 5.00 Surcharge 10.00 nn J/JJ So answer R. homas Kline Sheriff of Cumberland County WELTMAN WEINBERG & REIS 08/30/2001 Sworn and subscribed to before me this J3~ day of ~-w, ~ A . D . ~~/D~. ~ othonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE INSURANCE COMPANIES, Subrogee of Todd Frey, Plaintiff, v. GARY REED, Defendant. CASE NO: ®~~ ~L~'sa L~ TYPE OF PLEADING: LUd^^ COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: SHERRY D. LOWS, ESQUHtE Pa. I.D, #66096 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 W WR # 02306448 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGI~ESSP/E INSURANCE COMPANIES, Case No.: Subrogee of Todd Frey, Plaintiff, vs. GARY REED, Defendant. NOTICE TO DEFEND 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 wriring with the court your defenses or objections to the claims set forth against you. You aze warned that if you fail to do so the case may proceed without you and a judgment maybe 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO F1ND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COLJN'1 Y, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE INSiTRANCE COMPANIES, ) Subrogee of Todd Frey, ) CASE NO: Plaintiff, ) v. ) GARY REED, ) ) Defendant. ) COMPLAINT IN CIVIL ACTION AND NOW COMES, Plaintiff, Progressive Insurance Companies, Subrogee of Todd Frey, by and through its counsel, Sherry D. Lowe, Esquire and WELTMAN, WEINBERG & REIS, CO., L.P.A., and hereby files this Complaint against Defendant, Gary Reed. In support thereof, Plaintiff avers as follows: 1. Plaintiff, Progressive Insurance Company, (hereinafter referred to as Progressive"), is a corporation with registered office located at P.O. Box 43258, Richmond Heights, Ohio. 2. Defendant, Gary Reed, is an adult individual with a last known address of 2 Stuart Street, Apt. 2, Mount Holly Springs, Cumberland County, Pennsylvania 17065. 3. Progressive issued a policy of insurance where Progressive agreed to insure a 1991 Suzu Swift GT, VIN# 2S2AC34S9M6601404 ("Insured Vehicle"), owned by Plaintiff s insured, Todd Frey. 4. At all times mentioned herein, Progressive's insured was the owner of said Insured Vehicle and Progressive'sInsuted had insurance coverage for his wife, Zoann Frey. 5. At all times mentioned herein, it is believed and therefore averred that Defendant Gary Reed ("Defendant Owner") was the owner and driver of a Chevy s-10 Blazer ("Defendant Owner's Vehicle"). 6. At all times mentioned herein, Defendant Owner did not have valid insurance coverage in violation of Pennsylvania's Motor Vehicle Financial Responsibility Law, 75 Pa.C.S.A. Section 1785. 7. On or about August 22, 1999, Defendant Owner negligently operated Defendant Owner's Vehicle causingidamage to the vehicle owned and operated by Progressive's insured by striking the Insured Vehicle. 8. As a direct and proximate result of Defendant's negligence, the vehicle owned by Progressive's Insured sustained property damages in the amount of $292.71. 9. As a direct and proximate result of Defendant's negligence, Progressive's Insured's wife sustained bodily injury in the amount of $2,349.12 for which Plaintiffls insured made a claim for uninsured coverage since Defendant did not have insurance coverage at the time of the accident. 10. Pursuant to the terms and conditions of the insurance policy, Progressive paid the sum of $2,641.83, which represents the property damages sustained to its Insured's Vehicle and uninsured motorist claim by its Insured, as a result of Defendant's negligence. A true and correct copy of the record of the drafts paid by Progressive to and on behalf of its Insured is attached hereto as Exhibit "A" and made a part hereof. 11. Under the terms of the insurance policy issued by Progressive, its insured also sustained damages in the amount of $500.00, which represents the deductible amount under the policy of insurance. 12. Pursuant to the insurance policy issued by Progressive and as a result of said aforesaid payment, Progressive became subrogated to the claim of its Insured against Defendant. 13. Pursuant to Progressive's right of subrogation, Progressive is presently due and owed from Defendant the sum of $3,141.83, which represents the property damage claim of $292.71, uninsured benefits of $2,349.12 and the deductible payment of $500.00 suffered by Plaintiff s insured. 14. Repeated demands have been made upon Defendant for payment of the aforesaid sum; however, Defendant has willfully failed and refused to pay the sum due and owing to Progressive. WHEREFORE, Plaintiff, Progressive Insurance Companies, Subrogee of Todd Frey, demands Judgment against Defendant, Gary Reed, in the amount of $3,41.83 and costs. m THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USEb FOR THAT PURPOSE. Respectfully Submitted: WELTMAN, WEINBERG & REIS, CO., L.P.A. She owe, Esquire PA I.D. # 66096 Weltman, Weinberg & Reis, Co., L.P.A. 2718 Koppers Bldg. 436 7`" Avenue Pittsburgh, PA 15219 (412)434-7955 W WR # 02306448 111Tesltleongwfirt -`, f ~ ~° o~', set my Er3a"fd 9nd i11e sca~1 of s,,; .i ; c~; ~ at CarlisEe, A~, ~ /la ..... day of......... .. ~~/ 9, ro b ro ~~ ~~ w y w w ,. ". ~ m o ~ w b O V O \K a N n K ~o G '' " ° O°1 OO 7 q ~' X~gp S+~/ k M nQ. l~+f ~ N L~ Y 2 f3 ~~ ~ b~KO o~ ~ 0 ~ t'' ~ » O 2 Q~ ~ O A ~' to w ~~ lJl J y. ~ O~ b ~ K ~' K M O r m r ~ c :~ ~ r °~ ~ oa o n Na #K ~ ~ y o m * ~ N rC O ~ yy a ~ m `'' s 4 ~ p WYY Ny ~ G ~ '~ 5 2. + ~ O O N ~ i K N N O C ^ ~ ~ Z S Y O ~'~ t .~ ~ o ~' : % .. z N * 3 rt C ~ ctl O W : m ~ w w , n ''z m r rv • O N ~ O N N N * ~ ro ° b .. „ . k « m A -J y -J M Q O r " m ~, ~~ d ~' y N -.] ~ d ~ n O ~ O n o. N o m ~ xd y„„~ n //^/`"''~ ~ .G N y n ~W H• ~ O n~ ~ ro ` V H tam * ~ m # P N 1~' ~ b IP O ~ ~ p H H 'd K. ro p. m ~ N n ~P W ~ ~ la1 ~ ~ ~ ~ t0 61 N G 3 N W A Y N i ~i ~~~`~ b r N N 0 W a'd K ~y ~r < ~ w. P 3 Y O~ wFff, . „ o= Ym z w v 7 r 'a O w ~ ~ n w ~ .~ y v y k'^'K O ~ m 7 AP's d ~' x ~ rt m O m g zp 22 K ' 5~ mOx ~ 2 Z Nag N• H ..e.~ m H K O y// r ~ e £ j o Y G H N O N n p lr W + O~ Y u 2 '~ 3 K m w r -~ wry' i `/~1 ~ p ~ w y P. v K * j~• Q7 ~ ` ~` p H ~ a ** x • C o z y~{ ~ W H e rt ~ p ;9 %. ~ * r m m m * k ~ z ~ • * H H O ~ ^ k u W £ r Y * ` * w r 2 O y * * P O w My ~ m O ~ ~ Z Y * * w H ° y N w * \ e ~ ° N Y ° ° •• . „ r ~ ~ ~ ~ ° y m N 'r4 a ~ a d o m Cd r ~ rt t' w m ~ ~ `~ ~ ~ O n ° __ ~ ~ ~ N O ~ µ ~ H zv N ~ b z A M / i+ 0 nn Q d q ", T µ H R H mN ~ ~ m /~ ~..{ l 1 ~/ ~ Y ~ N ~ ~, .~ ~ N ~ ^~ N N d ~ n ~F ~° w l31 r ce 7 ~ ~t ^ ~ G ~ N ~ T ~ ~ ~ ( ~ ~ N ~o F'~' l , N Y p $ ~ ~ ~ Y N VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsificatiorA to authorities, she is an attorney for the Plaintiff herein; makes this Verification based upon the facts as supplied to her by the Plaintiff and/or its agents and because the Plaintiff is outside the jurisdiction of the court and the Plaintiffls Verification cannot be obtained within the time allowed for filing of this pleading, and that the facts set Forth in the foregoing pleading are true and correct to the best of her knowledge, information and belief. Sherry D. Lowe, Esquire ;,§. ~.~ ., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSNE INSURANCE COMPANIES, SUBROGEE OF TODD FREY Plaintiff vs. GARY REED Defendant No. 01-4852 Civil PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plainriff COUNSEL OF RECORD OF THIS PARTY: SHERRY D. LOWE, ESQUIRE PA I.D.#66096 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02306448 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE INSURANCE COMPANIES, SUBROGEE OF TODD FREY Plaintiff vs. GARY REED Defendant Civil Action No. OI-4852 Civil PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: \ SHERRY D. LOWS, ESQUIRE PA I.D.#66096 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR #02306448 q. '4 C> n q C - _~, t ~ ~~ Q 7 y ~ ~.~, _-+ - - - ~~- ~ ~~ . -- SSA -gin ... isJ :,;: ~ C:1 L:- .Z ~ _` f G7 y 1 -C (~ .. _- -~ ,~. ~ ,~v., x~sa~.»se~a~ ee~ersa~~gs~t:~+ ,,, . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSNE INSURANCE COMPANIES, SUBROGEE OF TODD FREY Plaintiff vs. GARY REED Defendant No. 01-4852 Civil PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: SHERRY D. LOWE, ESQUIRE PA I.D.#66096 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02306448 :,~ ti. IN THE COURT OF COMMON PLEAS CiJMBERLAND COUN'T'Y, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE INSI7RANCE COMPANIES, SUBROGEE OF TODD FREY Plaintiff vs. GARY REED Defendant Civil Action No. 01-4852 Civil PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: <(7 ~J SHERRY D. LOWE, ESQUIRE PA I.D.#66096 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR #02306448 e? ~-. C:. i~.4 ~ T~ CI' t 1 l' ,_ - -" __ 7, . __ G" ~_ ~ ' ` _~~ L ~? ~~ ~. C.J -. , ~~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE INSURANCE COMPANIES, Subrogee of Todd Frey, Plaintiff, vs. GARY REED, Defendant. No. 01-4852 Civil PRAECIPE TO REINSTATE COMPLAINT IN CIVIL ACTION Filed by plaintiff counsel Gerianne Hannibal Esquire PA ID 66622 (412)434-7955 Weltman Weinberg & Reis Co LPA 2718 Koppers Building 436 7~' Ave Pittsburgh PA 15219 W WR #02306448 >~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE INSURANCE COMPANIES, Subrogee of Todd Frey, Plaintiff, vs. GARY REED, Defendant. No. 01-4852 Civil PRAECH'E TO REINSTATE THE COMPLAINT IN CIVIL ACTION TO THE PROTHONOTARY: Kindly reinstate the Complaint in Civil Acfion in the above-captioned action. CO., L.P.A. '/~~l~b~ GERLANNE HANNIBAL PA I.D, #66622 Weltman, Weinberg & Reis C ., L.P.A. 2718 Koppers Building 436 Seventh Avenue ~ Pittsburgh,PA 15219 (412)434-7955 W WR #02306448 ~. ~- : - r-~ f .. ., ~; .. ,- - -. ~_~ _ _ - "~ - _~~ ~~ ...~~n+gy~. i. ~b8~€s'v.r„,r.. a .,~,amrca~^m~x <,rc~,.,n_~.~ SHERIFF'S RETURN - REGULAR CASE NO: 2001-04852 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PROGRESSIVE INSURANCE COMPANIE VS REED GARY VALERIE WEARY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon REED GARY DEFENDANT the at 1813:00 HOURS, on the 16th day of December 2002 at 1135 EASY ROAD CARLISLE, PA 17013 by handing to GARY REED a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs Docketing 18.00 Service 4.14 Affidavit .00 Surcharge 10.00 .00 32.14 Sworn and Subscribed to before me this _n79~ day of n,~e~r.~X.~.. ~07JoL A . D . ~^ „a .c. >~ ~ A ~„ JP~rothonotary ~ 7"J So Answers: r ~~ R. Thomas Kline 12/17/2002 WELTMAN WEINBERG REIS By: eputy Sher' ~. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ~`` CIVIL DIVISION PROGRESSIVE INSURANCE COMPANIES, SUBROGEE OF TODD FREY Plaintiff vs GARY REED Defendant No. 01-4852 Civil PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: GERIANNE HANNIBAL, ESQUIRE PA LD.#66622 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, P,4 15219 (412)434-7955 W W R#02306448 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE INSURANCE COMPANIES, SUBROGEE OF TODD'FREY Plaintiff vs. GARY REED Defendant TO THE PROTHONOTARY: Civil Action No. 01-4852 Civil PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, Gary Reed, above named, in the default of an Answer, in the amount of $3,141.83 computed as follows: Amount clairrt$d in Complaint $3,141.83 Interest from the date of Judgment at the legal interest rate of 6% per annum TOTAL $3,141.83 I hereby certify that appropriate Notice of Default, as attached has been mailed in accordance with PA R.C.P. 237.1 on the date indicated on the Notice. WELTMAN, WEII~BE~f2G & REIS CO.,~L.~.A. By:~~.~~~~V~~v GERIAN IBAL, SE 4 IREU PA I.D.#66622 Weltman, Weinberg & Reis Co., L.P 2718 Koppers Bldg. 4 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02306448 Plaintiff's address is: c/p Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`" Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 1135 Easy Road, Carlisle, PA 17013 IN THE.000RT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE INSURANCE COMPANIES, Subrogee of Todd Frey, Plaintiff vs. GARY REED Defendant TO: Gary Reed Civil Action No. 01-4852 Civil IMPORTANT NOTICE 1135 Eas y Road Carlisle, PA 17013 Date of Notice: ~~ L YOU ARE DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR RY ATTORNEY AS;D FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166 WELTMAI~G4f~INBERG,& jQ~IS CO., L.P.A. ;: Ger annibal, ire PA I.D. #66622 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 W W R #02306448 .~ VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, that the parties against whom Judgment is to be entered according to the Praecipe attached are not members of the Armed Forces of the United States or any other military or non-military service covered by the Soldiers and Sailors Civil Relief Act of 1940. The undersigned further states that the information is true and correct to the best of the undersigned's knowledge and belief and upon information received from others. WELTMAN, ykEJ~16~RG/~ REIS CO., L.P By: YY r r v V GERI N ANNI AL, ESQUIRE PA LD.#66622 Wellman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 W W R#02306448 ~- G G ~ ~ -~~ a ~~ ~ ~ ^~ ~ ~.~ ~_ ~~; -~~~~ ~;, ~_ c~ ~_: s=: ;l,_ -,; _, ~.: ~S -{ ._, y; ~~, ~~ .. _ ~.w.wR=n . -i.ee°~:s'3sYt4Y~v8 .... '.N#HYb~ e,~",ir.: s ; , .,.:er. ~r'-'(.'a ',;~,cr 1F+A." .. a STATE AUTO MUTUAL INSURANCE COMPANY Plaintiff v. RICHARD BOTTORE Individually and Trading as IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.2002-5916 CIVIL TERM CIVIL DIVISION -LAW B & L GLASS SHOP Defendant TO: PROTHONOTARY, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PRAECIPE FOR DEFAULT NDGMEI~'T Enter judgme~rt in favor of Plaintiff and against Defendant(s) RICHARD BOTTORF Individually and Trading as B & L GLASS SHOP, named for fafiure to file within the required time an Answer to the Complaim in the above-captioned case and assess the Plaintiffs damages as follows: Amount claimed in Plaintiffs Complaim $1,274.40 Interest from January IS , 2002 at the legal rate of 6%per annum 76.46 Total $1,350.86 It is hereby certified that a written notice of intention to file this Praecipe was mailed to the Defendant(s) and his attorney of record, after the defauh occurred and at least ten (10) days prior to the date of the filing of this Praecipe. See Exhibits A & B attached. KNUPP, KOD LUM, P.C. By Robert D. Kodak, Attorney for Plaintiff a~ DATED:' I3 udgment ernered and damages assessed as above. Prothonotary` ~j~ f - LAW OFFICES OF A ~. KODAK &IMBLUM P.C. KNUPP " =Robert L. Knupp Robert D Kodak , , be E K . d . nupp Gary J. Imhlum q07 NORTH FRONT STREET (1909-1976) POST OFFICE BOX 11848 Of Counsel _ _ ___ HARRISBURG, PA 17108-1848 Robert H. Maurer Mark A. Mateya Telephone: 717/238-7159 (1923-1998) Facsimile: 717!238-7158 email: kki.law@verizon.net January 13, 2003 RICHARD BOTTORF IND & T/A B & L GLASS SHOP 902 E MARKET STREET LEMOYNE PA 17043 RE: State Auto Mutual Insurance Co. VS: Richard Bottorf Ind. & t/a B & L Glass Shop No. 2002-5916 Civil Term, Court of Common Pleas Cumberland County, Pennsylvania Our File No. 28731 Dear Mr. Bottorf:: In accordance with Pennsylvania Rules of Civil Procedure 237.1, we are enclosing herewith a Notice of a Praecipe for Entry of Default Judgment. According to the records as they are found in the Office of the Prothonotary of Cumberland County, you have not filed responsive pleadings to the Complaint filed against you to the above term and number, nor has any attorney entered an appearance on your behalf. Accordingly, we are forwarding to you the enclosed Notice which indicates that if you do not take action as set forth in this Notice, we, at the expiration of time indicated therein, will request the Office of the Prothonotary of Cumberland County, Pennsylvania, to enter Judgment against you in the amount as set forth in said Complaint. Very truly yours, KNUPP, KODAK &IMBLUM, P.C. Robert D. Kodak, Esq. THIS LETTER IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE RDK/kgb enclosure cc: CAMPBELL HIGHTOWER & ADAMS #56425 4645 S LAKESHORE DRIVE STE 11 EXHIBIT TEMPE AZ 85282-7127 ~ 4 STATE AUTO MUTUAL INSURANCE COMPANY Plaintiff v. *~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-5916 CIVIL TERM RICHARD BOTTORF Individually and Trading :CIVIL DIVISION -LAW B & L GLASS SHOP Defendant IMPORTANT NOTICE TO: RICHARD BOTTORF IND. & T/A B & L GLASS SHOP ,Defendant(s) DATE OF NOTICE: JANUARY 13. 2003 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 XOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A 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 TWO LIBERTY AVENUE CARLISLE PA 17013 (717)249-3166 NOTICIA IMPORTANTE A: RICHARD BOTTORF IIQD. & T/A B & L GLASS SHOP , Demandado(s) FECHA DE NOTICIA: JANUARY 13.2003 LISTED NO HA COMPLIDO CON EL AVISO ENTERIOR PORQUE HA FALTADO E~1 TOMAR MEDIDAS REQUERIDS RESPECTO A ESTE CASE. SI LISTED NO ACTUA DENTRO DE DIEZ (10) DIAS DESDE LA FECHA DE ESTA NOTICIA, ES POSIBLE QUE UN FALLO SEIA REGISTRADO CONTRA LISTED SIN UNA AUDIENCIA Y LISTED PODRIA PERDER SU PROPIEDAD O OSTROS DERECHOS IMPORTANTES. LISTED DEBE LLEVAR ESTA NOTICIA A SU ABOL;ADO EN SEGUIDA. SI LISTED NO TIENE ABOGADO O NO TIENE CON QUE PAGAR LOS_ SERVICIOS DE UN ABOGADO, VAYA O LLAME A LA OFICINA ESCRTTA ABAJO PARR AVERIGUAR A DONDE LISTED PUEDE OBTENER LA AYUDA LEGAC: CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 EXHIBIT STATE AUTO MUTUAL INSURANCE COMPANY Plaintiff v. RICHARD BOTTORF Individually and Trading as B & L GLASS SHOP Defendaut IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.2002-5916 CPJII. TERM CIVIL AIVISION -LAW To RICHARD BOTTORF IlVD AND T/A B & L GLASS SHOP, Defendant(s) You are hereby notified that on ~~ .3n , 204E the following (Judgment) has been entered against you in the above-captioned case. 7udg~ment entered in the amount of $1.350.86. DATE: `Prothonotary ~jYl I hereby certify that the name and addxess of the proper person(s) to receive this notice is: RICHARD BOTTORF IND & T/A B & L GLASS SHOP 902 E. MARKET STREET LEMOYNE PA 17043 A/RICHARD $OTTORF IIVll. & T/A B & L GLASS SHOP, Defendido/a Defendidos/as Por este medio se le esta notificando que el de del 20_, eUla siguiente(Fallo) ha lido anotado en contra soya en el caso mencionado en el epigrafe. FECHA: Protonotario Certificao que la siguiente direction es la del defendido/a segue indicada en el cetificado de residencia: RICHARD BOTTORF IND & T/A B & L GLASS SHOP 902 E. MARKET STREET LEMOYNE PA 17043 Abogado del Demandante N ~ w ~_ p~ ~ N ~a 0 ~ ~ -r, d n I~'~ v ,_, i ~ ~~~~~ ~~ C'. ~-i t-' __ ~ - ..,~.. .- ~ t C- i' y ...~ CO '`-~~~' C _~ ~ l Ul ''< f~ ~" 'i ... ®a N~F.S L:9PIFd8R4 Rnrv x ryx.~-{-:.. stern ~ K~x:e i -.ee~.+ x.tn ~:3T 'edP 1y^.Y.~ McCormick Crossing, a Pennsylvania General Partnership, Owner v. Wheatland Custom Homes, Inc. , Contractor IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. O3- ~{y/ /hLD STIPULATION AGAINST LIENS WHEREAS, McCormick Crossing, a Pennsylvania General Partnership of Pennsylvania is about to execute contemporaneously herewith, a contract with Wheatland Custom Homes, Inc. of Lebanon County, Pennsylvania, for the erection of a dwelling upon a lot of land situate as follows: ALL THAT CERTAIN tract ofland, situate in the Township ofMonroe, County of Cumberland, and Commonwealth of Pennsylvania, being more particularly bounded and described as follows, to wit: BEGINNING at a point on the eastern right-of--way line of Lucinda Lane at the corner of Lot No. 29 and Lot No. 30 as shown on the hereinafter mentioned plan of lots; thence along said right-of--way line by a curve having a radius of 225.00 feet and an arc length of 100.906 feet to a point; thence North 12 degrees 56 minutes 17 seconds West, a distance of 482.289 feet to a point; thence by a curve having a radius of 40.00 feet and an arc length of 65.538 feet to a point on the southernright-of--way line of Granda Flora Drive; thence along said right-of--way line of Granda Flora Drive North 80 degrees 56 minutes 16 seconds East, a distance of 251.593 feet to a point; thence South 09 degrees OS minutes 30 seconds East, a distance of 569.247 feet to a point at the dividing line between Lot No. 29 and land now or formerly of Donald C. Adams, Jr. and Margaret D. Adams; thence along said dividing line South 70 degrees 22 minutes 53 seconds West, a distance of 29.755 feet to a point; thence South Ol degree 13 minutcs 09 seconds West, a distance of 144.835 feet to a point at the dividing line between Lot No. 29 and Lot No. 30; thence along said dividing line North 75 degrees 58 minutes 16 seconds West, a distance of 241.849 feet to a point, said point being the place of BEGINNING. BEING Lot No. 29 on Subdivision Plan of Duffield Crossing, Phase IIIrecorded December 14, 2001 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 84, Page 78. BEING PART OF THE SAME PREMISES Harry H. Fox, Jr., a married man, by his deed dated July 9,1999 and recorded July 16,1999 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book 203, Page 1058, granted and conveyed unto McCormick Crossing, a Pennsylvania General Partnership, GRANTOR herein. UNDER AND SUBJECT to Declaration of Restrictive Covenants recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Miscellaneous Book 683, Page 461. UNDERAND SUBJECT to setbacks, easements, rights-of--way, conditions and restrictions as shown on the above plan of record. NOW, the 1~s~- day of January,2003, at the time of and immediatelybefore the execution of the principal contract, and before any authority has been given by the said McCormick Crossing, a Pennsylvania General Partnership, to the said Wheatland Custom Homes, Inc. to commence work on the said building, or purchase materials for the same in consideration of the making of the said contract with Wheatland Custom Homes, Inc. and the further consideration of One Dollar, to Wheatland Custom Homes, Inc. paid by McCormick Crossing, a Pennsylvania General Partnership, it is agreed that no lien shall be filed against the building by the contractor, or any sub-contractor, nor by any of the material men or workmen or any other person for any labor, or materials purchased, or extra labor or materials purchased for the erection of said building, the right to file such liens being expressly waived. WITNESS, our hand and seals the day and year aforesaid. SIGNED, SEALED AND DELIVERED IN THE PRESENCE OF > c~iu-t-e.~~. OWNER: McCo ck Crossing, a Pennsylvania Gen al Partnership n n.~iu ri CONTRACTOR: Wheatla~ ustom Homes, Inc. BY: if cx .. ~ r, c ~„ _. -> ., ~ c` r_• fi , W i~° r ' -° ~~ _ ~ ,..-t f1 i M Robert E. Young and Nancy R. Young, Owners v. Michael L. Martin, Inc., Contractor IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. (~3 ~yc7 ML,D STIPULATION AGAINST LIENS WHEREAS, Robert E. Young and Nancy R. Young, of Cumberland County, Pennsylvania, is about to execute contemporaneously herewith, a contract with Michael L. Martin, Inc. of York County, Pennsylvania, for the erection of a dwelling upon a lot of land situate as follows: ALL THAT CERTAIN Unit and the property known, named and identified in the Declazation referred to below as "Grandon Farms, Planned Community", located in Hampden Township, Cumbe rland C ounty,Pennsylvania, w hich h as h eretofore b een s ubmitted t o t he provisions of the PennsylvaniaUniform Planned Community Act, 68 Pa. C.S.A. § 5101, et seq., by the recordmg in the Office of the Recorder of Deeds of Cumberland County of a Declaration, dated October 23, 1997 and recorded November 3, 1997 in Miscellaneous Book 561, Page 56, which has been amended by a First Amendment to Declaration dated June 29,1998 and recorded on June 29, 1998 in Miscellaneous Book 580, Page 897, which has been further amended by a Second Amendment to Declazation dated December 11, 1998 and recorded on December 17, 1998 in Miscellaneous Book 597, Page 1144, which has been further amended by a Third Amendment to Declaration dated June 4, 1999 and recorded on June 25, 1999 in Miscellaneous Book 617, Page 426, which has been further amended by a Fourth Amendment to Declaration dated July 23, 1999, and recorded on July 29, 1999 in Miscellaneous Book 620, Page 644, as further amended by a Fifth Amendment to Declaration dated November 29, 1999 and recorded December 2, 1999 in Miscellaneous Book 632, page 186 and recorded on December 22, 1999 in Miscellaneous Book 634, Page 158, as further amended by a Sixth Amendment to Declaration dated August 1, 2000 and recorded August 10, 2000 in Miscellaneous Book 651, Page 665, as further amended by a Seventh Amendment to Declaration dated August 31, 2000 and recorded September 6, 2000 in Miscellaneous Book 654, Page 294, as further amended by an Eight Amendment to Declazationdated December 15, 2000 and recorded December 20, 2000 in Miscellaneous Book 662, Page 917, being and designated in such Declaration as Unit No. 117, which said Unit is more fully described in said Declaration and is shown on the Declaration Plan recorded in Right of Way Plan Book 11, Page 112, as amended by First Amendment to Declaration Plan recorded in Right of Way Plan Book 12, Page 6, as further amended by Second Amendment to Declaration Plan recorded in Right of Way Plan Book 12, Page 39, as further amended by a Third Amendment to Declaration Plan recorded in Right-of--Way Plan Book 12, a Page 66, as further amended by a Fourth Amendment to Declaration Plan recorded in Right of Way Plan Book 12, Page 85, as further amended by a Fifth Amendment to Declaration Plan recorded in Right of Way Plan Book 12, Page 102, as further amended by a Sixth Amendment to Declaration Plan recorded in Right of Way Plan Book 12, Page 109, as further amended by a Seventh Amendment to Declaration Plan recorded in Right of Way Plan Book 12, Page 121, as further amended by an Eighth Amendment to Declaration Plan recorded in Right-of--Way Plan Book 12, Page 143. NOW, the L `~~ day of January, 2003, at the time of and immediately before the execution oftheprincipal contract, andbefore any authorityhas been givenby the said Robert E. Young and Nancy R. Young, to the said Michael L. Martin, Inc. to commence work on the said building, or purchase materials for the same in consideration of the making of the said contract with Michael L. Martin, Inc. and the further consideration of One Dollar, to Michael L. Martin, Inc. paid by Robert E. Young and Nancy R. Young, it is agreed that no lien shall be filed against the building by the contractor, or any sub-contractor, nor by any of the material men or workmen or any other person for any labor, or materials purchased, or extra labor or materials purchased for the erection of said building, the right to file such liens being expressly waived. WITNESS, our hand and seals the day and year aforesaid. SIGNED, SEALED AND DELIVERED OWNER: IN THE PRESENCE OF r Robert E. Young Nancy R. Young CONTRACTOR: Michael L. BY: - 2 - .~ ~ V W `~: '~J C~ (Q~,,} (v ,~ (\ =' 1 Ci -F~ c- ~ ~; _ ~~~ . :: s ~ ~ . - ~ _ .,r, I !-' :...A X91 ~ ~, J,~.. __ ~ _ _ ~~~, ~ ~ ~ r r: ~ .i n ~~ ~' °" '< Y- BOROUGH OF MECHANICSBURG, Claimant v. Kirk Hassinger and Sue Ellen Hassinger, Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. Q3- ~F~`f M.L.D. MUNICIPAL LIEN MUNICIPAL LIEN FOR SEWER/WATER RATES NOW COMES the Borough of Mechanicsburg, Cumberland County, Pennsylvania, by its staff attorney David J. Spotts, Esquire, and files the within claim for charges assessed with respect to sewer and/or refuse rates against above named owner or owners and against the hereinafter described real estate as follows: STATEMENT OF CLAIM 1. This claim is filed by the Borough of Mechanicsburg, a borough organized and existing in accordance with the laws of the Commonwealth of Pennsylvania. 2. The owner or reputed owner of the property, or party or parties responsible or liable, for which this claim is filed is the Defendant(s). 3. The authority under which the sewer and/or refuse rates were charged and assessed is the Act of July 18, 1935, P.L. 1286, Section 1, 53 P.S. § 2231, as amended. 4. The authority under which this claim is.filed is the Act of May 16, 1923, P.L. 207, Section 9, etet seo•, 53 P.S. §7143, as amended. 5. A description of the property against which this claim is filed is: 238 West Simpson Street Borough of Mechanicsburg Cumberland County Pennsylvania 17055 TAX PARCEL NUMBER 20-23-0587-112 6. This claim has not been the subject of any previous claim and judgment in the Court of Common Pleas of Cumberland County for sewer and/or refuse charges. 7. The total amount of the charges for which this claim is filed is four hundred and thirty-three and 32/100 dollars ($433.32), plus costs and reasonable attorney's fees. The time period for which these charges are filed is July 1, 2001 to December 31, 2002 on Borough Sewer Account(s) 55-0005161. WHEREFORE, Claimant requests that a Municipal Lien be entered in its favor and against the Defendant in the amount of four hundred and thirty-three and 32/100 dollars ($433.32), plus costs and reasonable attorney's fees. BOROUGH OF MECHANICSBURG By: d~6 ~. David J. pott ,Esquire Supreme Court ID No. 69701 Borough of Mechanicsburg West Strawberry at North Market St. Mechanicsburg, PA 17055 (717)691-3310 Dated: January 28, 2003 -2- -.. cs ~ ~ cvs -n ~ i ~ , ~ ~ ~- ~ .~i j ~ 7 ~.<t ~ ~ J7 C ~ .. {_ ~ _ ~ ~ CJ V ~/ . .~.. "' 4Rk4°v Ns*FV.i..~t' n ,~:,.~.:~ .. *'~': 'FM Y:!°.^I.s~t?1R~fi^9EfR:3`~NBkh=EC ~ BOROUGH OF MECHANICSBURG, Claimant v. Carey H. Klinger, Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. D3 - y 4,~ M.L.D. MUNICIPAL LIEN MUNICIPAL LIEN FOR SEWERNVATER RATES NOW COMES the Borough of Mechanicsburg, Cumberland County, Pennsylvania, by its staff attorney David J. Spotts, Esquire, and files the within claim for charges assessed with respect to sewer and/or refuse rates against above named owner or owners and against the hereinafter described real estate as follows: STATEMENT OF CLAIM 1. This claim is filed by the Borough of Mechanicsburg, a borough organized and existing in accordance with the laws of the Commonwealth of Pennsylvania. 2. The owner or reputed owner of the property, or party or parties responsible or liable, for which this claim is filed is the Defendant(s). 3. The authority under which the sewer and/or refuse rates were charged and assessed is the Act of July 18, 1935, P.L. 1286, Section 1, 53 P.S. § 2231, as amended. 4 w .s 4. The authority under which this claim is filed is the Act of May 16, 1923, P.L. 207, Section 9, et se ., 53 P.S. §7143, as amended. 5. A description of the property against which this claim is filed is: 38 West Factory Street Borough of Mechanicsburg Cumberland County Pennsylvania 17055 TAX PARCEL NUMBER 19-22-0519-090 6. This claim has not been the subject of any previous claim and judgment in the Court of Common Pleas of Cumberland County for sewer and/or refuse charges. 7, The total amount of the charges for which this claim is filed is four hundred and thirty and 32/100 dollars ($430.32), plus costs and reasonable attorney's fees. 8. The time period for which these charges are filed is July 1, 2001 to December 31, 2002 on Borough Sewer Account(s) 55-0004300. WHEREFORE, Claimant requests that a Municipal Lien be entered in its favor and against the Defendant in the amount of four hundred and thirty and 32/100 dollars ($430.32), plus costs and reasonable attorney's fees. BOROUGH OF MECHANICSBURG BY~ ~~• avid J. pott ,Esquire Supreme Court ID No. 69701 Borough of Mechanicsburg West Strawberry at North Market St. Mechanicsburg, PA 17055 (717)691-3310 Dated: January 28, 2003 -2- i~ .~ .m ~y ~~ r= i? _ ~ C °° ~ N ~ ~ :~ ' x% ~. :~! .~" b~ J r _:~T~ i_ -;T'- 7 -< x€at~...-.;~.. , ..,:; . .:;:aPV.*~f*cer ~&-+m{"*'~ssR95~.... ,. BOROUGH OF MECHANICSBURG, Claimant v. Philip Smiley, Defendant(s) M IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.a3- ~~~ M.L.D. MUNICIPAL LIEN MUNICIPAL LIEN FOR SEWERNVATER RATES NOW COMES the Borough of Mechanicsburg, Cumberland County, Pennsylvania, by its staff attorney David J. Spotts, Esquire, and files the within claim for charges assessed with respect to sewer and/or refuse rates against above named owner or owners and against the hereinafter described real estate as follows: STATEMENT OF CLAIM 1. This claim is filed by the Borough of Mechanicsburg, a borough organized and existing in accordance with the laws of the Commonwealth of Pennsylvania. 2. The owner or reputed owner of the property, or party or parties responsible or liable, for which this claim is filed is the Defendant(s). 3. The authority under which the sewer and/or refuse rates were charged and assessed is the Act of July 18, 1935, P.L. 1286, Section 1, 53 P.S. § 2231, as amended. ~~ 4. The authority under which this claim is filed is the Act of May 16, 1923, P.L. 207, Section 9, et seo•, 53 P.S. §7143, as amended. 5. A description of the property against which this claim is filed is: 400 West Elmwood Avenue Borough of Mechanicsburg Cumberland County Pennsylvania 17055 TAX PARCEL NUMBER 20-24-0785-436 6. This claim has not been the subject of any previous claim and judgment in the Court of Common Pleas of Cumberland County for sewer and/or refuse charges. 7. The total amount of the charges for which this claim is filed is four hundred and ninety-nine and 40/100 dollars ($499.40), plus costs and reasonable attorney's fees. 8. The time period for which these charges are filed is October 1, 2001 to December 31, 2002 on Borough Sewer Account(s) 55-0005904. WHEREFORE, Claimant requests that a Municipal Lien be entered in its favor and against the Defendant in the amount of four hundred and ninety-nine and 401100 dollars ($499.40), plus costs and reasonable attorney's fees. BOROUGH OF MECHANICSBURG BY~ ~1 )c _.~ 9 ~. David J. offs, Esquire Supreme Court ID No. 69701 Borough of Mechanicsburg West Strawberry at North Market St. Mechanicsburg, PA 17055 (717)691-3310 Dated: January 28, 2003 -2- ~. 4• _~ ti '~ Fz. ~ v, U ~ ~ i-- - ~~ ~. ~ c. ~_ Pte-- ~;'; ~ c:~ .: i. C r p _ r ~-n ._ .:r ~ . fJ7 ~ 44 ~i yS ,, M. . _ ! .»mFr¢= rte •-: ^ ~_.. -ar.~> ~ c. a~~_wra+:a+_' .vmf°`~: "a3nrt^k39~59; '~ ~.. BOROUGH OF MECHANICSBURG, Claimant v. Anthony Hicks, Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, o3-4w'7 M.L.D. MUNICIPAL LIEN MUNICIPAL LIEN FOR SEWERNVATER RATES NOW COMES the Borough of Mechanicsburg, Cumberland County, Pennsylvania, by its staff attorney David J. Spotts, Esquire, and files the within claim for charges assessed with respect to sewer and/or refuse rates against above named owner or owners and against the hereinafter described real estate as follows: STATEMENT OF CLAIM 1. This claim is filed by the Borough of Mechanicsburg, a borough organized and existing in accordance with the laws of the Commonwealth of Pennsylvania. 2. The owner or reputed owner of the property, or party or parties responsible or liable, for which this claim is filed is the Defendant(s). 3. The authority under which the sewer and/or refuse rates were charged and assessed is the Act of July 18, 1935, P.L. 1286, Section 1, 53 P.S. § 2231, as amended. ~, 4. The authority under which this claim is filed is the Act of May 16, 1923, P.L. 207, Section 9, et se ., 53 P.S. §7143, as amended. 5. A description of the property against which this claim is filed is: 112 East Simpson Street Borough of Mechanicsburg Cumberland County Pennsylvania 17055 TAX PARCEL NUMBER 17-23-0565-211 6. This claim has not been the subject of any previous claim and judgment in the Court of Common Pleas of Cumberland County for sewer and/or refuse charges. 7. The total amount of the charges for which this claim is filed is five hundred and nine and 49/100 dollars ($509.49), plus costs and reasonable attorney's fees. 8. The time period for which these charges are filed is April 1, 2001 to December 31, 2002 on Borough Sewer Account(s) 55-0002321. WHEREFORE, Claimant requests that a Municipal Lien be entered in its favor and against the Defendant in the amount of five hundred and nine and 49/100 dollars ($509.49), plus costs and reasonable attorney's fees. BOROUGH OF MECHANICSBURG David J. ~otts, Esquire Supreme Court ID No. 69701 Borough of Mechanicsburg West Strawberry at North Market St. Mechanicsburg, PA 17055 (717)691-3310 Dated: January 28, 2003 -2- n C3 ~, ~ ~ 'S -:-~ v ~ = ~D ' . \ b '~ ` -~: ~~.Y Cv : O ~ ~'~ J ; ~~ ~ ` Y _~ ,.n S ~'~ ~+ "< ~~ '. .. zmn~~ms%s.a+. ,,*: ~~-.~i. ..aa -.:s~+ntC ~>s'cf£et~v'a~F e~ IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY CIVIL DIVISION PROGRESSIVE INS. CO. Subrogee of Todd Frey v. No. 01-4852 GARY REED AFFIDAVIT IN SUPPORT OF LICENSE SUSPENSION Before me, the undersigned authority, Gerianne Hannibal, being duly sworn according to law, deposes and says as follows:. I am counsel for plaintiff in the above entitled action. 2. The action was filed against Gary Reed for damages that occurred in an automobile accident on August 22, 1999. 3. A true and correct copy of an estimate of vehicle damages is attached hereto. 4. Upon information and belief the defendant had no liability. n rance on the date of the accident in violation of Pennsylvania law. ~; ~ /) i ~'~ Geri ne Hannibal Esq Ydy E ~ 4~. ~~... ,._,.~2.F Sworn to and sub ribed before this day of 2003., ~1' 01/14/2000 at 03:18 PM 61602 PROGRE3$IVE INSURANCE COMPANIES York 190 arsenal road York, PA 17404 Fax: (717)859-6535 ESTYNIATE OF RECORD Written by: CURTIS EVANS #126940 01/14/2000 03:18 PM Adjuster: KAREN RINEHART #134278 (717)849-2541 Insured: TODD FREY Owner: TODD FREY Address: 36 SECOND ST YORK HAVEN, PA 11370 (117)266-1435x0000 99-3444433-01 Claim #99-3444433-01 Policy #55612518-001 Date of Loss: 08/22/1999 at 05:00 PM Type of Loss: Collision Point of Impact: 6. Rear Inspect Location: Repair Facility: 91 SUZU SWIFT GT 4-1.3L-FI 3D RED Int: DRIVE_IN Days to Repair License # VIN: 2S2AC34S9M6601404 Lic: bbr5214 PA Prod Dat®: Odometer: 115280 Rear Defogger Intermittent Wipers Rear Window Wiper Tinted Glass Dual Mirrors Clear Coat Paint Power Brakes Power Mirrors 4 Wheel Disc Brakes Cloth Seats Bucket Seats Recline/Lounge Seats 5 Speed Transmission ------------------------------------------------------------------------------- N0. OP. DESCRIPTION QTY EXT. PRICE LABOR PAINT 1 REAR BUMPER 2* Repl LKQ Rr Bumper assy; +25% 1 218.75 1.0 2.5 3 Add for Clear Coat 1.0 4 LIFT GATE 5* Rpr Gate 3 door w/wiper 4.0 2.0 6 Overlap Major Non-Adj. Panel -0,2 1 ~°~ ,. OI/14/2000 at 03:18 PM 99-3444433-01 61602 EsT~sE of ~co~ 91 SUZU SWIFT GT 4-1.3L-FI 3D RED Int: ---------- N0. ------- OP. ------ ------------------------ DESCRIPTION ---- -----=--------- QTY EXT. PRICE ---------------- ----------------- LABOR PAINT ----------------- ---------- 7 ------- ------------------------- Add for Clear Coat 0.4 8 Repl Decal Suzuki 1 28.11 0.3 9 Repl Decal Swift 1.3 GT 1 31.28 0.3 ---------- ------- ----- ------------------------ Subtotals =_> ---------------- 278.14 ----------------- 5.6 5.7 Estimate Notes: PRIOR DMG - NONE LKQ BUMPER LOCATED AT CONDONS-800-543-7274, QUOTE #80620 Parts 278.14 Body Labor 5.6 hrs @ $ 34.00/hr 190.40 Paint Labor 5.7 hrs @ $ 34.00/hr 193.80 Paint Supplies ------- 5.7 hrs @ $ 15.00/hr 85.50 ----------- SUBTOTAL -------- -------- ----------- $ ------- 747.84 Sales Tax $ 747.84 @ 6.0000 44.87 TOTAL COST OF REPAIRS $ 792.71 ADJUSTMENTS: Deductible 500.00 TOTAL ADJUSTMENTS $ 500.00 NET COST OF REPAIRS $ 292.71 Appraiser Signature This estimate represents an AGREED PRICE based on all known damages at this 2 ~ Ul/14/2000 at 03:18 PM 99-3444433-01 61602 ESTINNI~TE OF RECORD 91 SUZU SWIFT GT 4-1.3L-FI 3D RED Int: time. The repairer agrees to complete and guarantee all listed repairs, and all towing and storage charges included in this estimate. THIS IS NOT AN AUTHORIZATION OF REPAIR. NO SOPPLEMENTS WITHOUT PRIOR AUTHORIZATION OR REINSPECTION. Repair Shop Manager's Signature The vehicle owner may be responsible for additional cost above the appraised amount. There is no requirement to use a specific repair shop, however, the insurer can provide a list of repair shops that will be able to repair the vehicle to its predamaged condition. This appraisal may include aftermarket crash parts as replacement parts. If the use of an aftermarket crash part voids the existing warranty on the part that it replaces, or any other part, then the aftermarket part listed on this estimate will have a warranty that meets or exceeds the warranty of the original manufacturer. Aftermarket part descriptions on this appraisal are preceded with A/M. An aftermarket crash part is a non original equipment manufacturer (Non-OEM) replacement part, either new or used, for any of the non mechanical parts that generally constitute the exterior of the motor vehicle, including inner and outer panels. Abbreviation legend: LKQ ~ like kind in quality, A/M = aftermarket, Recond = recondition, 0/H = overhaul, Repl = Replace, Rpr = Repair, Refn = Refinish, Sect = Section, R&I = Remove and install, Alqn = Align, Subl = Sublet, B1nd =.Blend. 3 3 ~~ 0./14/2000 at 03:18 PM 99-3444433-O1 61602 ESTIMATE OF RECORD 91 SUZU SWIFT GT 9-1.3L-FI 3D RED Int: ANY PERSON WHO KNOWINGLY AND WITH INTENT TO DEFRAUD ANY INSURANCE COMPANY OR OTHER PERSON FILES AN APPLICATION FOR INSURANCE OR STATEMENT OF CLAIM CONTAINING ANY MATERIALLY FALSE INFORMATION OR CONCEALS FOR THE PURPOSE OF MISLEADING, INFORMATION CONCERNING ANY FACT MATERIAL THERETO COMMITS A FRAUDULENT INSURANCE ACT, WHICH IS A CRIME AND SUBJECTS THE PERSON TO CRIMINAL AND CIVIL PENALTIES. THE FOLLOWING IS A LIST OF ABBREVIATIONS OR SYMBOLS THAT MAY BE USED TO DESCRIBE WORK TO BE DONE OR PARTS TO BE ,REPAIRED OF REPLACED: MOTORS: ABBREVIATIONS/SYMBOLS D = DISCONTINUED PART, A = APPROXIMATE PRICE LABOR TYPES: B = BODY LABOR D = DIAGNOSTIC E _ ELECTRICAL F = FRAME G = GLASS M = MECHANICAL P = PAINT LABOR S = STRUCTURAL T = TAXED MISCELLANEOUS X = NON TAXED MISCELLANEOUS PATHWAYS: ADJ = ADJACENT ALGN = ALIGN A/M = AFTERMARKET BLVD = BLEND CAPA = CERTIFIED AUTO PARTS ASSOCIATION D&R = DISCONNECT AND RECONNECT EST = ESTIMATE EXT. PRICE = UNIT PRTCE MULTIPLIED BY THE QUANTITY INCL = INCLUDED MISC = MISCELLANEOUS NON-ADJ = NON ADJACENT 0/H = OVERHAUL OP. = OPERATION NO. _ LINE NUMBER QTY = QUANTITY QUAL RECY = QUALITY RECYCLED PART QUAL REPL = QUALITY REPLACEMENT PART RECORD = RECONDITION REFN = REFINISH REPL = REPLACE R&I REMOVE AND INSTALL R&R = REMOVE AND REPLACE RPR = REPAIR RT = RIGHT SECT = SECTION SUBL = SUBLET LT = LEFT W/0 = WITHOUT W/_ = WITH/_ SYMBOLS: # = MANUAL LINE ENTRY * = OTHER [IE..MOTORS DATABASE INFORMATION WAS CHANGED]. ** = DATABASE LINE WITH AFTERMARKET N = NOTES ATTACHED TO LINE. Estimate based on MOTOR CRASH ESTIMATING GUIDE.- Non-asterisk(*) items are derived from the Guide ARS1425. Database Date 11/1999. Double asterisk(**) items. indicate parts supplied by a supplier other than the original equipment manufacturer. Pound sign (#) items indicate manual entries. CAPA items have been certified for fit and finish by the Certified Auto Parts Association. NAGS Part Numbers, Prices and Labor Times are provided from National Auto Glass Specifications, Inc. Pathways - A product of CCC Information Services Inc. 4 .,, f~ O ,~ ~ G ~ ~, z~ w ~ ~, ~ R`' ~.' ~'.~_ -. ~- _ ~ ~ _, ;- ~ ,~, ~.: ~.:_ - ~~ - .. ,,, ;,° ~' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE CASUALTY INS. CO. a/s/o Todd Frey Plaintiff vs. GARY REED Defendant No. 01-4852 PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: GERIANNE HANNIBAL,ESOUIRE PA. I.D.#66622 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R#02306448 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE CASUALTY INS. CO. a/s/o Todd Frey Plaintiff vs. GARY REED Defendant Civil Action No. 01-4852 PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMAI , By: REIS CO., L.P.A. GERIAA}N'E ~'ANI4IBAL,ESQUIRE PA. I . D.#66622 WELTMAN, WEINBERG &REIS CO., L.P.A. 2718 Koppers Building ~__ ;, ~~,,., 436 Seventh Avenue ~ wer,dyu.cu~,r~c~;~~~;c i Pittsburgh, PA 15219 City Ot Pittsburgh, k'~ r~eat~r Courr.,r (412) 434-7955 My Comrov~s'~~ ~ ~.--„ ~„~.h~y 15.2G~.. W W 802306448 Sworn to d sub before e t is day of ar , 04 f n,~ c~ ~ -; 7 '~ ~~~~ !V `' ' ~ a _.,- rt :'n ., t.> ~~~ . .. _e,