HomeMy WebLinkAbout03-632308-03-538
LAW OFFICES OF STEWART C. CRAWFORD
BY: Stewart C. Crawford
ATTORNEY I.D.: 09827
223 North Monroe Street
P.O. Box E
Media, PA 19063
Telephone: (610) 565-7050
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
Allstate Insurance Company a/s/o
Jody Wagner
309 Lakeside Drive
Horsham, PA 19044
Donna Starner
3808 Glenwood Avenue
Camp Hill, PA 17011
IN CIVIL ACTION
NO: 03
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 an 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 ease may proceed without you and a judgment may be entered against you by the court
without further notice for any money claimed in the complaim or for any other 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 CANNOT 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 ELIGABLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
File # 08-03-538
LAW OFFICE OF STEWART C. CRAWFORD & ASSOCIATES
BY: Stewart C. Crawford, Esquire
ATTORNEY I.D. NO. 09827
223 North Monroe Street Attorney for Plaintiff
Media, PA 19063
Telephone: (610) 565-7050
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
Allstate Insurance Company As Subrogee of IN CIVIL ACTION
Jody Wagner
309 Lakeside Drive
Horsham, PA 19044
VS.
Donna Stamer
3803 Glenwood Avenue
Camp Hill, PA 17011
NO. 03 -
COMPLAINT
4030 Motor Vehicle Property Damage.
I. Pla'mtiffis an insurance company licensed and authorized to do business
in the Commonwealth of Pennsylvania with one of its principle places of business
at the above-captioned address.
2. Defendant, above-named, was the owner and the operator of a motor
vehicle involved in an incident on June 13, 2003 and at all times pertinent hereto
resided at the above-captioned address.
3. On the aforesaid date, Plaintiff had a policy of insurance with Jody
Wagner, hereinafter referred to as named insured.
4. On the aforesaid date, a motor vehicle insured by Plaintiff, hereafter the
insured's vehicle, was involved in an incident with Defendant.
5. On the aforesaid date, the insured's vehicle was North on Pennsylvania
Route 114 at the intersection with Sparring Green Drive in Silver Springs
Township, Pennsylvania when Defendant, who was traveling South, made a
sudden and illegal lef~ turn in front of the insured's vehicle striking and damaging
it.
6. The Defendant was negligent and careless and the sole cause of this
incident in that Defendant:
(a). Operated the vehicle at an unsafe rate of speed;
(b). was inattentive;
(c). failed to make proper observation
(d). violated local laws and the laws of the Commonwealth;
7. Pursuant to the aforesaid policy of insurance, Plaintiffbecame liable for
damages that arose out of this accident.
8. Due to this incident, expenses were incurred for, damage to the insured
vehicle, towing, storage and car rental.
9. Pursuant to the aforesaid policy of insurance, the Common Law and
governing statutes, Plaintiff is subrogated for all money paid and seeks recovery
of these sums totaling $I0, 303.49.
WHEREFORE, Plaintiff demands judgment for $10, 303.49 plus interest and
costs of suit.
Stewart C. Crawford, Esquire
Attorney for Plaintiff
VERIFICATION
The undersigned verifies that the statements contained in the foregoing
Complaint are true and correct. The undersigned understands that false
statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904,
relating to unswom falsification to authorities.
Stewart C. Crawford, Esquire for
Allstate Insurance Company
# 08-03-538
LAW OFFICES OF STEWART C. CRAWFORD
BY: Stewart C. Crawford, Esquire
ATTORNEY I.D. # 09827
223 North Monroe Street
P.O. Box E
Media, PA 19063
Telephone: (610) 565-7050
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
Allstate Insurance Company a/s/o
Jody Wagner
309 Lakeside Drive
Horsham, PA 19044
CIVIL ACTION
NO. 03-6323
Donna Stamer
3803 Glenwood Avenue
Camp Hill, PA 17011
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Kindly reinstate this Complaint an additional thirty (30) days.
Dated:
'STEWART C. CRAWFORD, ES~JI17,E
Attorney for Plaintiff
SHERIFF'S RETURN -
CASE NO: 2003-06323 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
NOT FOUND
ALLSTATE INSUP~ANCE CO ET AL
VS
STARNER DONNA
R. Thomas Kline
duly sworn according
inquiry for the within named DEFENDANT
STARNER DONNA
unable to locate Her in his bailiwick.
,Sheriff or Deputy Sheriff, who being
to law, says, that he made a diligent search and
but was
He therefore returns the
COMPLAINT & NOTICE
the within named DEFENDANT
3808 GLENWOOD AVENUE
CAMP HILL, PA 17011
NO SUCH ADDRESS
IN CUMBERLJ~ND COUNTY.
STARNER DONNA
NOT
FOUND , as to
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
18.00
10.35
5.00
10.00
.00
43.35
~. ~hS~a~k~ine
Sheriff of Cumberland County
STEWART C CRAWFORD
12/12/2003
Sworn and subscribed to before me
SHERIFF'S RETURN
cASE NO: 2003-06323 P
COMMONTWEALTH OF pENNSYLVANIA
COUNTY OF CUMBERLAND
- NOT FOb~D
ALLSTATE INSURANCE CO ET AL
VS
STARNER DONNA
R. Thomas Kline
duly sworn according to law,
inquiry for the within named DEFENDANT
STARNER DONNA
unable to locate Her in his bailiwick.
,Sheriff or Deputy Sheriff, who being
says, that he made a diligent search and
but was
He therefore returns the
COMPLAINT & NOTICE
the within named DEFENDANT
, STARNER DONNA
, NOT FOUND , as to
3808 GLENWOOD AVENUE
CAMP HILL, PA 17011
FORWARD ADDRESS OF 240 MATTIS AVENUE MIDDLETOWN,
PA 17057.
Sheriff's Costs:
Docketing 18,00
Service 13.80
Not Found 5.00
Surcharge 10.00
.00
46.80
So answers .... ~rr~ -~
R. Thomas Kline
Sheriff of Cumberland County
STEWART CRAWFORD
01/02/2004
Sworn and subscribed to before me
this ~ day of ~l,~7
Pro~h6not ary
SHERIFF'S RETURN
CASE NO: 2003-06323 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
- NOT FOUND
ALLSTATE INSURANCE CO ET AL
VS
STARNER DONNA
R. Thomas Kline
duly sworn according to law, says, that he made a diligent
inquiry for the within named DEFENDANT
STARNER DONNA
unable to locate Her in his bailiwick.
,Sheriff or Deputy Sheriff, who being
search and
but was
He therefore returns the
COMPLAINT & NOTICE
the within named DEFENDANT
3808 GLENWOOD AVENUE
CAMP HILL, PA 17011
ATTEMPTED SERVICE AT 3803
, STARNER DONNA
NOT FOUND as to
GLENWOOD AVE CAMP HILL & 205 ARCH ST
CARLISLE. FORWARDING OF 240 MATTIS AVE MIDDLETOWN, PA 17057.
Sheriff's Costs:
Docketing 18.00
Service 13.80
Not Found 5.00
Surcharge 10.00
.00
46.80
R. -Thoma~ XPine
Sheriff of Cumberland County
STEWART CP~AWFORD
01/26/2004
Sworn and subscribed to before me
this ~ [~ day of(' .~x~_7
/
~3y A.D.
· # 08-03-538
LAW OFFICES OF STEWART C. CRAWFORD
BY: Stewart C. Crawford, Esquire
ATTORNEY I.D. # 09827
223 North Monroe Street
P.O. Box E
Media, PA 19063
Telephone: (610) 565-7050
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
Allstate Insurance Company aYs/o
Jody Wagner
309 Lakeside Drive
Horsham, PA 19044
CIVIL ACTION
NO. 03-6323
Donna Starner
3803 Glenwood Avenue
Camp Hill, PA 17011
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Kindly reinstate this Complaint an additional thirty (30) days.
~TE~'ART C. ~RAWF~RD, ESQUI~
Attorney for Plaintiff
SHERIFF'S RETURN
CASE NO: 2003-06323 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ALLSTATE INSUPu~NCE CO ET AL
VS
ST~q/qER DONNA
- OUT OF COUNTY
R. Thomas Kline
duly sworn according to law,
and inquiry for the within named DEFENDANT
Sheriff or Deputy Sheriff who being
says, that he made a diligent search and
to wit:
in his bailiwick.
County,
the within COMPLAINT & NOTICE
STARNER DONNA
but was unable to locate Her
deputized the sheriff of DAUPHIN
serve
He therefore
Pennsylvania, to
On March 5th , 2004
attached return from DAUPHIN
Sheriff's Costs:
Docketing .00
Out of County 9.00
Surcharge .00
Dep Dauphin County 29.25
.00
38.25
03/05/2004
STEWART CRAWFORD
Sworn and subscribed to before me
this g~ day of )~
A.D.
Prothonotary
this office was in receipt of the
So answers:~ .3. >~ .
R./Thoma~ Kline
Sheriff of Cumberland County
TSe Court of Common Pleas of Cumberland County, Pennsylvania
Allstate Insurance Company a/s/o Jody Wagner
VS.
Donna Starner
SERVE: sa~e No. 03-6323 civil
}~ow, February-5, 2004
hereby deputize the Sheriff of
deputation being made at the request and risk of the Plaintiff.
Sheriffof Cumberland County, PA
, I, SHERIFF OF CUMBERLAND COUNTY, PA, do
County to execute this Writ, this
Now~
within
upon
at
by handing to
and made known to
Affidavit of Service
, 20__, at
o'clock M. served the
copy of the original
the contents thereof,
So answers,
Sworn and subscribed before
me this ___ day of
,20
Sheriff of County, PA
COSTS
SERVICE
MILEAGE
AFFIDAVIT
Mary Jane Snyder
Real Estate Deputy
William T. Tully
Solicitor
Dauphin County
Harrisburg, Pennsylvania 17101
ph:(717)255-2660 fax: (717) 255~2889
Jack Lotwick
Sheriff
1. Daniel Basile
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
Commonwealth of Pennsylvania
County of Dauphin
AND NOW:February 27, 2004
REINSTATED COMPLAINT
STAPLER DOlqlqA
to DEFENDANT
of the original REINSTATED COMPLAINT
to him/her the contents thereof at 240 MATTIS AVE
MIDDLETOWN, PA
ALLSTATE INSURANCE CO A/S/O
STARNER DONNA
Sheriff's Return
No. 0674-T - -2004
OTHER COUNTY NO. 03-6323
at 5:23PMserved the within
upon
by personally handing
1 true attested copy(les)
and making known
17057-0000
Sworn and subscribed to
before me this 2ND day of MARCH, 2004
PROTHONOTARY
Sheriff of Dauphin County,
Pa.
By f
Sheriff's Costs: $29.25 PD 02/09/2004
RCPT NO 188054
TQ
IN THE COURT OF COMMON PLEAS OF CRAWFORD COUNTY, PENNSYLVANIA
ALLSTATE INSURANCE
COMPANY a/s/o JODY
WAGNER,
CIVIL ACTION - LAW
No. 03-6323
Plaintiff,
DONNA STARNER,
Defendant.
PRAECIPE FOR APPEARANCE
(Jury Trial Demanded)
Filed on Behalf of Defendant,
Donna Starner
Counsel of Record for this Party:
Jeffrey C. Catanzarite, Esquire
Pa. I.D. #72765
SUMMERS, MCDONNELL, WALSH & SKEEL, L.L.P.
Firm #911
2400 Gulf Tower
707 Grant Street
Pittsburgh, PA 15219
(412) 261-3232
#12439
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ALLSTATE INSURANCE,
COMPANY a/s/o JODY
WAGNER,
Plaintiff,
CIVIL ACTION - LAW
No. 03-6323
JURY TRIAL DEMANDED
By:
Respectfully submitted,
SUMMERS, McDONNELL, WALSH & SKEEL, L.L.P.
J~otr~ /~./(~atanzarite, Esquire t( f~ a~rr~eDr efendant
DONNA STARNER,
Defendant.
PRAECIPE FOR APPEARANCE
TO THE PROTHONOTARY:
Kindly enter the appearance of the undersigned, Jeffrey C. Catanzarite,
Esquire, of the law firm of Summers, McDonnell, Walsh & Skeel, L.L.P., on behalf of
the Defendant, Donna Starner, in the above case.
CERTIFICATE OF SERVICE!
I HEREBY CERTIFY that a true and correct copy of the foregoing Praecipe for
Appearance has been mailed by U.S. Mail to counsel of record via first class mail,
postage pre-paid, this 17th day of March, 2004:
Stewart C. Crawford, Esquire
Law Offices of Stewart C. Crawford
223 North Monroe Street
P.O. Box E
Media, PA 19063
SUMMERS, McDONNELL, WALSH & SKEEL, L.L.P.
//~e'ffr/~C.- Catanzarite, Esquire Att ey for Defendant
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ALLSTATE INSURANCE CIVIL ACTION - LAW
COMPANY a/s/o JODY
WAGNER, No. 03-6323
Plaintiff,
DONNA STARNER,
Defendant.
ANSWER AND NEW MATTER
(Jury Trial Demanded)
Filed on Behalf of Defendant,
Donna Starner
Counsel of Record for this Party:
Jeffrey C. Catanzarite, Esquire
Pa. I.D. #72765
SUMMERS, MCDONNELL, WALSH & SKEEL, L.L.P.
Firm #911
2400 Gulf Tower
707 Grant Street
Pittsburgh, PA 15219
(412) 261-3232
TO: PLAINTIFF
You are hereby notified to
file a written response to
the enclosed Answer and New
Matter within twenty (20)
days from service hereof
st ,tFoo,,,,.. WALSH & SKEEL
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ALLSTATE INSURANCE, CIVIL ACTION - LAVV
COMPANY a/s/o JODY
WAGNER,
Plaintiff,
No. 03-6323
DONNA STARNER,
Defendant.
_ANSWER AND NEW MATT_ER
Defendant, Donna Starner, by and through her attorneys, Summers,
McDonnell, Walsh & Skeel, L.L.P., and Jeffrey C. Catanzarite, Esquire, files the
following pleading:
I. ANSWER
1. Admitted.
2. It is admitted that the Defendant was the owner and operator of a motor
vehicle involved in an accident on June 13, 2003 and that she resided in Camp Hill at
that time. The Defendant currently resides at 240 Mattis Avenue, Middletown,
Pennsylvania 17057.
3. After reasonable investigation, the Defendant is without knowledge or
information sufficient to form a belief as to the truth of the allegations of Paragraph 3
and therefore, said allegations are denied and strict proof: thereof is demanded at the
time of trial.
4. It is admitted that the Defendant was involved in a motor vehicle
accident with a vehicle operated by Jody Wagner. By way of further response, after
reasonable investigation, the Defendant is without knowledge or information
sufficient to form a belief as to the truth of the remaining allegations of Paragraph 4
and therefore, said allegations are denied and strict proof thereof is demanded at the
time of trial.
5. The allegations of Paragraph 5 are conclusions of law to which no
response is required. To the extent that a response is necessary, said averments are
generally denied pursuant to Rule 1029(d) and (e) of 'the Pennsylvania Rules of Civil
Procedure.
6. The allegations of Paragraph 6 and its subparts are conclusions of law to
which no response is required. To the extent that a response is necessary, said
averments are generally denied pursuant to Rule 1029(d) and (e) of the Pennsylvania
Rules of Civil Procedure.
7. After reasonable investigation, the Defendant is without knowledge or
information sufficient to form a belief as to the truth of -the allegations of Paragraph 7
and therefore, said allegations are denied and strict proof thereof is demanded at the
time of trial.
8. After reasonable investigation, the Defendant is without knowledge or
information sufficient to form a belief as to the truth of the allegations of Paragraph 8
and therefore, said allegations are denied and strict proof thereof is demanded at the
time of trial.
9. The allegations of Paragraph 9 are conclusions of law to which no
response is required. To the extent that a response is necessary, said averments are
generally denied pursuant to Rule 1029(d) and (e) of the Pennsylvania Rules of Civil
Procedure.
WHEREFORE, Defendant, Donna Starner, demands judgment in her favor and
against Plaintiff.
II. N__EW MATTER
10. Paragraphs 1 through 9 are herein incorporated by reference.
11. The Plaintiff was negligent and careless and the sole cause of this
accident in that she:
operated her vehicle at an unsafe rate of speed;
failed to pay attention to the roadway and other vehicles on the
roadway;
c. failed to operate her vehicle with her headlights engaged; and,
e. violated the local laws and laws of the Commonwealth.
12. Defendant claims the benefit of the applicable provisions of the
Pennsylvania Comparative Negligence Act as set forth in 42 Pa.C.S.A. § 102, et
seq., and pleads the same as an affirmative defense against any and all claims of the
Plaintiff.
WHEREFORE, Defendant, Donna Starner, demands judgment in her favor and
against Plaintiff.
JURY TRIAL DEMANDEr)
By:
Respectfully submitted,
SUMMERS, McDONNELl_, WALSH & SKEEL, L.L.P.
tt~¢/~ eof~a ~t~r°~efendant
VERIFICATION
Defendant verifies that he/she is the Defendant in the foregoing action; that
the foregoing ANSWER AND NEW MATTER is based upon information which he/she
has furnished to his/her counsel and information which has been gathered by his/her
counsel in the preparation of the lawsuit. The language of the ANSWER AND NEW
MATTER is that of counsel and not of the Defendant. Defendant has read the
ANSWER AND NEW MATTER and to the extent that the ANSWER AND NEW
MATTER is based upon information which he/she has given to his/her counsel, it is
true and correct to the best of his/her knowledge, information and belief. To the
extent that the content of the ANSWER AND NEW MATTER is that of counsel,
he/she has relied upon counsel in making this Affidavit. Defendant understands that
false statements herein are made subject to the penalties of 18 Pa.C.S. §4904,
relating to unsworn falsification to authorities.
onna 5tarner, Defendar~--
#12439
C_EERTIFICATE OF SERVIC~E
I HEREBY CERTIFY that a true and correct copy of the foregoing Answer and
New Matter has been mailed by U.S. Mail to counsel of record via first class mail,
postage pre-paid, this 29th day of March, 2004:
Stewart C. Crawford, Esquire
Law Offices of Stewart C. Crawford
223 North Monroe Street
P.O. Box E
Media, PA 19063
SUMMERS, McDONNELL, WALSH & SKEEL, L.L.P.
D "~/~" ~atanzarite, Esquire
~//~y for Defendant
~;~ Starner
: IN THE COURT OF COMMON PLEAS OF
~r~r.qTATE INSURANCE CO, ANY a/s/o JODY
: CUMBERLAND COUNTY, PENNSYLVANIA
WAGNER, :
Plaintiff, : NO. 6323 CIVIL [g 2003
EXDNNA STA~NER,
Defendant.
RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the following form:
PETITION FOR APPOINTMENT OF ARBITRATORS
TO THE HONORABLE, THE SUDGES OF SAID COURT:
Jeffrey C. Catanzarite
, counsel for the l~t~,~i~f/defendant in the above action
respectfully represents that:
1. The above-captioned action l~tr/'o~i,6,6~ is 641(~ at issue.
2. The claim of the plaintiff in the action is $ 10,303.49
The counterclaim of the defendant in the action is none
The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators:
WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be
submitted.
zarite, Esquire
ORDER OF COURT
AND NOW, (~-~4- ~ , l'SJ:~9-~, in consideration of the
foregoing petition,./~ 9 '~,,~ / ~ '~ /~ Esq., ~~;~Z;~/,
actions) ~ prayed for. ~
By the~
ALLSTATE INSURANCE
COMPANY a/s/o
JODY WAGNER
DONNA STARNER
: IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAVV
: NO. 03-6323 CIVIL TFRM
IN RE: ARBITRATION PANEL
ORDER OF COURT
AND NOW, July 30, 2004, the Court having been informed that Susan
Candiello, Esquire, is unavailable for the above-captioned arbitration hearing,
James Gault, Esquire, is appointed in her stead.
By the Court,
James D. Bogar, Esquire
One West Main Street
Shiremanstown, PA 1701
Court Administrator
ALLSTATE INSURANCE CfIqPANY
a/s/o JODY WAGNER
DONNA STARNER
: NO. __
IN THB coURT OF cOMMON PLEAS OF
CLrMBERLAND coUNTY, PENNSYLVANIA
Civil TERM
03-6323 ~ _~
OATH
We do solemnly swear (or affirm) that we will support, obey and. defend the Constitution of the
United States and the Constitution of this Commonwealth and that we will discharge the duties of
~~Esquire
~s G. 'Gault~ Esquire
AWARD
We, the undersigned arbih-ators, having been duly appointed and sworn (or affm'ned), make
the following award:
(Note: If damages for delay are awarded, they shall be separately stated.)
_. (insert name if~cable~)/}
Arbitrator, dissents.
Date of Award: . O[l'Ol[~ '~.., ~us~_.___Confair,._Esquire
NOTICE OF ENTRY OF AWJkRD
Now, the If day of ~,~207 .~, at _~:_(~/~ , &.~aM., the above award
.... ,,,a ~a/t~e thereof ~iven by mail to the parties or their attorneys.
was entered upon ~e OOCKer anu nuu~ m~ ~-
Artibitrators'compensation to be
Paid upon appeal:
$ 290.00
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ALLSTATE INSURANCE
COMPANY a/s/o JODY
WAGNER,
CIVIL ACTION - LAW
No. 03-6323
Plaintiff,
DONNA STARNER,
Defendant.
PRAEClPE FOR ENTRY OF JUDGMENT
(Jury Trial Demanded)
Filed on Behalf of Defendant,
Donna Starner
Counsel of Record for this Party:
Jeffrey C. Catanzarite, Esquire
Pa. I.D. #72765
SUMMERS, MCDONNELL, WALSH & SKEEL, L.L.P.
Firm #911
2400 Gulf Tower
707 Grant Street
Pittsburgh, PA 15219
(412) 261-3232
#12439
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ALLSTATE INSURANCE,
COMPANY a/s/o JODY
WAGNER,
Plaintiff,
DONNA STARNER,
Defendant.
CIVIL ACTION - LAW
No. 03-6323
PRAECIPE FOR ENTRY OF JUDGMENT
By:
Respectfully submitted,
SUMMERS, McDONNELL, WALSH & SKEEL, L.L.P.
efendant
JURY TRIAL DEMANDED
TO THE PROTHONOTARY:
Kindly enter judgment on behalf of Defendant, Donna Starner, and against
Plaintiff, per the Award of the Arbitrators in the above-captioned matter. A copy of
the Award of the Arbitrators is attached hereto.
15:19 SUMMERS MCDONNELL HUDOCK GUTHRIE a
HOME OFF[CE
N0.608
QO1
ALLSTATE II~SUI~ COMPANY
a/s/o JCOY W~.4qER
IN TH~ COURT OF COMMON PI~-~S
CUM3~ COUNTY,
NO 03-6323 , Civi~TERM
We do solemnly swear (or affirm) that we will suppo~ obe~ ~nd defcmd the Colm~tution of the
Uui2d Sts~cs and ~g Cons~Qn o£ this Commonwealth and tha~ we Mil discharge the du~ie~ of
AWARD
We. thc unders/gn~ arbitrators, having been duly appommd and ~wom (or afSrmcd), make
following award:
(Note: If damag~ for delto~ are awarde~d, they zhall bz ~partltely statzd.)
Date ot'Hearing:
was cntcrnd upon ~hc dooke~ and/notxce dmrcof I~ven by mail to the part/es or the/r attorneys.
Ara[bit,&tots'compensation ~:o be
Paid upon appeal:
S 290.00
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Praecipe for
Entry of Judgment has been mailed by U.S. Mail to counsel of record via first class
mail, postage pre-paid, this 17~h day of December, ;2004:
Stewart C. Crawford, Esquire
Law Offices of Stewart C. Crawford
223 North Monroe Street
P.O. Box E
Media, PA 19063
SUMMERS, McDONNELL, WALSH & SKEEL, L.L.P.
Catanzarite, Esquire
~/Att~rhey for Defendant
· Do/~na Starner