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Home My WebLink About08-0135F:\FILES\Clients\Donegal3050\Cu ent\500\3050.500.corn 1\mas Created: 9/20/04 0:06PM Revised: 1/7/08 2:51PM 3050.500 George B. Faller, Jr., Esquire I.D. No. 49813 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JANICE MAZOCK, IN THE COURT OF COMMON PLEAS OF 251 South Hanover Street CUMBERLAND COUNTY, PENNSYLVANIA Carlisle, PA 17013 Plaintiff V. NO. (`? eCr. CIVIL ACTION - LAW VLADMIR NHUTIN and WEST POINT TRANSPORTATION, 6520 Fisher Road Edmonds, WA 98026 Defendants. JURY TRIAL DEMANDED NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiffs. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 George B. Faller, Jr., Esquire I.D. No. 49813 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JANICE MAZOCK, 251 South Hanover Street Carlisle, PA 17013 Plaintiff V. VLADMIR NHUTIN and WEST POINT TRANSPORTATION, 6520 Fisher Road Edmonds, WA 98026 Defendants. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 - 0 13 S` c ?J ( -f ct n?, CIVIL ACTION - LAW JURY TRIAL DEMANDED COMPLAINT AND NOW comes the Plaintiff, Janice Mazock, by and through her counsel, MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, and hereby avers the following: 1. Plaintiff Janice Mazock is an adult individual residing at 251 South Hanover Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant Vladmir Nikitin is an adult individual residing at 6520 Fisher Road, Edmonds, Snohomish County, Washington 98026. 3. Defendant West Point Transportation is a trucking company with an address at 6520 Fisher Road, Edmonds, Snohomish County, Washington 98026. 4. On or about June 8, 2007, Janice Mazock parked her 2001 Chevy S-10 in front of a jewelry on Hanover Street in the Borough of Carlisle. 5. At that time, Defendant Vladmir Nikitin was operating a tractor trailer in the scope of his employment with Defendant West Point Transportation heading north on Hanover Street. 6. At that time, Defendant Nikitin caused the right side of his truck to strike the left side of the Plaintiff's parked vehicle. 7. As a direct and proximate result of the collision, Plaintiff's vehicle was damaged in the amount of $2,552.72. A copy of that property damage estimate totaling $2,552.72 is attached hereto as Exhibit "A." WHEREFORE, Plaintiff demands judgment against the Defendants, jointly and severally, in the amount of $2,552.72. By MARTSON LAW OFFICES Geor Faller, Jr., Esquire I.D. No. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Date: January 7, 2008 Attorneys for Plaintiff R-CLEO PAPER RECYCLABLE E--Xkibl-t A DONEGAL INSURANCE GROUP 1195 RIVER ROAD P. 0. BOX 302 MARIETTA, PA 17547-0302 (717) 426-1931 FAX: (717) 426-7023 *** ESTIMATE *** 06/142007 01:40 PM • Owner: MICHAEL & JANICE MAZOCK Address: 251 S HANOVER ST Home/Day: (717)241-0606 City State Zlp: CARLISLE, PA 17013 Control Information Claim #: PAE-PA-01-07-0001236-101 Insured Policy #: PAE 0507792 Loss Date/Time: 06/082007 Loss Type: Collision Deductible: $500.00 File #: Accounting #- 4255 Ins. Company: Donegal Mutual Insurance Group Agent: ANGELA CHEVAUX Address: Work/Day: (800)877-0600x7435 Email: angelachevaux@dcnegalgroup.com Insured: MICHAEL & JANICE MAZOCK Address: Home/Day: (717)241-0606 Claim Rep: ANGELA CHEVAUX Address: Work/Day: (800)877-0600x7435 Email: angelachevaux@donegalgroup.com Loss Payee: PSECU Inspection Inspection Date: 06/112007 12:16 PM Inspection Type: Field Inspection Location: Owner's residence Contact: MICHAEL OR JANICE MAZOCK Address: 251 S HANOVER ST Home/Day: (717)241-0606x City State Zip: CARLISLE, PA 17013 Primary Impact: Left Front Corner Secondary Impact: Left Rear Side Driveable: Yes Rental Assisted: Assigned Date/Time: Received DateMme: 06/112007 12:25 PM First Contact Date/Time: Appointment Date/Time: 06/12/2007 12:00 PM Appraiser Name: JACK CHIARA Appraiser License #: 416512 Address: P.O. BOX 567 Work/Day: (717)737-5757 CityState Zip: NEW CUMBERLAND, PA 17070 FAX: (717)737-7501 RED2 Repairer: RUFE CHEVROLET Contact: Address: 1601 RITNER HIGHWAY Work/Day: (717)243-5021 City State Zip: CARLISLE, PA 17013 FAX: (717)243-1089 License #: Regulation ID: 231275566 Target Complete Date/Time: Days To Repair: 6 06/142007 01:40 PM Paqe 1 of 5 Exhibit "A" 2001 Chevrolet S10 LS 2 DR Ext Cab 06/14/2007 01:40 PM Claim 0: PAE-PA-01-07-0001236-101 2001 Chevrolet S10 LS 2 DR Ext Cab 4cyl Gasoline 2.2 FLEX 4 Speed Automatic Llc.Plate: YHG-8065 Llc State: PA Llc Expire: VIN: 1GCCS195X1K104836 Prod Date: Mileage: 27.317 Veh Insp#: Mileage Type: Actual Condition: Good Code: U8544A Ext. Color: RED TINT PEARL MET Int. Color: Ext. Reflnish: Three-Stage UserDefined Int. Refinish: Ext. Paint Code: 86/379E Int. Trim Code: Air Conditioning Aluminum/Alloy Wheels Anti-lock Brakes Compact Disc Player Digital Clock Dual Airbags Intermittent Wipers Lighted Entry System Power Brakes Power Steering Rear Jump Seat(s) Rear Step Bumper Split Front Bench Seat Tinted Glass Velour/Cloth Seats •. •• a: 1 I 7 Bumper,Front Repair 2.0" SM 2 L 7 14 Bumper,Front Refinish 2.5 RF 1.1 Surface 1.0 Three-stage setup 0.4 Three-stage 3 N 92 Front Bumper Overhaul Additional Labor 2.3 SM 4 BR 83 Panei,Hood Blend Refinish 2.0 RF 1.0 Blend 1.0 Three-stage 5 EU 103 Fender,Front LT LIKE KIND & QUAL.PRT $100.00* +25 2.1 SM » PARTS LOCATED AT CARLISLE AUTO SALVAGE 717-249-3486 6 L 103 Fender,Front LT Refinish 3.4 RF 1.8 Surface 1.0 Edge 0.6 Three-stage 7 EU 198 Flare,Wheel Opening LT LIKE KIND & QUAL.PRT 0.3 SM » INC W/LKQ FENDER 8 L 198 Flare,Wheel Opening LT Refinish 0.9 RF 0.9 Surface 9 RI 198 Flare,Wheel Opening LT R & I Assembly INC SM 10 RI 1032 Nozzle,W/S Washer LT R & I Assembly 0.1 SM 11 RI 1033 Nozzle,W/S Washer RT R & I Assembly 0 1 SM 12 1 96 Pnl,Cab Side Outer LT Repair . 1.0 * SM 13 L 96 Pnl,Cab Side Outer LT Refinish 2.7 RF 2.0 Surface 0.7 Three-stage 14 RI 373 Nameplate,Cab Rear LT R & I Assembly 0 2 SM 15 EU 207 Door Assembly,Front LT LIKE KIND & QUAL.PRT $250.00 +25 . 2.5 SM » PARTS LOCATED AT CARLISLE AUTO SALVAGE 717-249.3486 16 L 207 Door Shell,Front LT Refinish 3.6 RF 1.9 Surface 1.0 Edge 0.7 Three-stage 06/14/2007 0 1:40 PM Pape 2 of 5 2001 Chevrolet S10 LS 2 OR Ext Cab 06/1412007 01:40 PM Claim 8: PAE-PA-01-07-0001236-101 L41 5?- 17 RI 241 W/Strip,Belt Outer LT R & I Assembly INC SM 18 RI 231 Pnl,lnner Door Trim LT R & I Assembly 0.1 SM 19 RI 357 N/Plate,Front Door LT R & I Assembly 0.2 SM 20 EU 229 Mirror,Outer Standard LT LIKE KIND & QUAL.PRT 535.00 +25 INC SM » PARTS LOCATED AT CA RLISLE AUTO SALVAGE 717-249-3 486 21 RI 229 Mirrar.Outer Standard LT R & I Assembly INC SM 22 RI 227 Handle,Front Door Otr LT R & I Assembly INC SM 23 1 389 Panel,Bedside LT Repair 2.0" SM 24 L 389 Panel,Bedside LT Refinish 4.1 RF 3.0 Surface 1.1 Three-stage » BLEND WITHIN PANEL 25 N 975 Bed Assembly,Set Back Additional Labor 2.0 SM 26 BR 397 Door,Fuel Filler LT Blend Refinish 0.2 RF 0.1 Blend 0.1 Three-stage 27 N FRONT END ALIGNMENT Additional Labor $49.95 SM* 28 EC CAR COVER Replace Economy $5.00 SM* 29 EC FLEX Replace Economy $8.00 SM* 30 EC CORROSION PROTECTIO Replace Economy $8.00' SM* 31 EC PINSTRIPES - TAPED Replace Economy $12.00" 0.3" SM* 32 SB HAZARDOUS WASTE Sublet Repair $3.00" SM* 32 Items 14 INCLUDES 1.0 HOURS FIRST PANEL THREE-STAGE ALLOWANCE E ti t T t l & E i s ma e o a ntr Other Parts es $467.95 Paint Materials $388.00 Line Item Markup $96.25 Parts & Material Total $952.20 Tax on Parts & Material 6.000% $57.13 Sheet Metal (SM) $42.00 5.9 93 15.2 $638.40 Mech/Elec (ME) $45.00 Frame (FR) $48.00 Refinish (RF) $42.00 19.4 19.4 $814.80 Paint Materials $20.00 Labor Total 34.6 Hours $1,453.20 Tax on Labor IT 6.000% $87.19 Sublet Repairs $3.00 Gross Total $2,552.72 Less: Deductible $500.00- Net Total $2,052.72 Altemate Parts Y/00/00/00100/00 CUM 00/00/00/00/00 Zip Code: 17111 HARRISBURG Audatex Estimating 4.0.484 ES 06/14/2007 01:40 PM REL 4.0.484 DT 0510112007 Da 06/08/2007 Copyright (C) 2006 Audatex North America, Inc. 06/14/2007 01:40 PM Paqe 3 of 5 VERIFICATION The foregoing Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. Janice ock F: \FILES\Clients\Donegal3 050\Cuttent\500\3050.500. com I -TI co - - J J ,v ` F: \FILES\Clients\Donegal3050\C utrent\500\3050.500. pra l \tnas Created: 9/20/04 0:06PM Revised: 2/15/08 11: 28AM 3050.500 George B. Faller, Jr., Esquire I.D. No. 49813 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JANICE MAZOCK, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : V. NO. 08-0135 CIVIL ACTION - LAW VLADMIR NHUTIN and WEST POINT TRANSPORTATION, Defendants. : JURY TRIAL DEMANDED PRAECIPE TO THE CUMBERLAND COUNTY PROTHONOTARY: Please reinstate the attached Complaint in reference to the above-captioned action and return to our office for service. Thank you. By Z,<,,?/l ' J', George W Faller, Jr I.D. No. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Dated: February 15, 2008 MARTSON LAW OFFICES C (4 CID A O C%j r-33 ?. ' r c- `4? W F:\FTLES\Clients\Donegal3050\Current\500\3050.500.amended commas Created: 9/20/04 0:06PM Revised: 5/7108 4:17PM 3050.500 George B. Faller, Jr., Esquire I.D. No. 49813 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JANICE MAZOCK, 251 South Hanover Street Carlisle, PA 17013 Plaintiff V. VLADMIR NIKITIN and WEST POINT TRANSPORTATION, 6520 Fisher Road Edmonds, WA 98026 and SUMMIT TRANSPORTATION and VYACHESLAV VOLKOV 1715 E 40`x' Avenue Spokane, WA 99203 Defendants. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-0135 CIVIL ACTION - LAW : JURY TRIAL DEMANDED NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiffs. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 George B. Faller, Jr., Esquire I.D. No. 49813 Seth T. Mosebey, Esquire I.D. No. 203046 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JANICE MAZOCK, 251 South Hanover Street Carlisle, PA 17013 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-0135 CIVIL ACTION - LAW VLADMIR N CTIN and WEST POINT TRANSPORTATION, 6520 Fisher Road Edmonds, WA 98026 and SUMMIT TRANSPORTATION and VYACHESLAV VOLKOV 1715 E 40`' Avenue Spokane, WA 99203 Defendants. JURY TRIAL DEMANDED AMENDED COMPLAINT AND NOW comes the Plaintiff, Janice Mazock, by and through her counsel, MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, and hereby avers the following: 1. Plaintiff Janice Mazock is an adult individual residing at 251 South Hanover Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant Vladmir Nikitin is an adult individual residing at 6520 Fisher Road, Edmonds, Snohomish County, Washington 98026. 3. Defendant West Point Transportation is a trucking company with an address at 6520 Fisher Road, Edmonds, Snohomish County, Washington 98026. 4. Defendant Summit Transportation is a trucking company with an address at 1715 E 40`h Avenue, Spokane, Washington 99203. 5. Defendant Vyacheslav Volkov is an adult individual with an address at 1715 E 40`h Avenue, Spokane, Washington 99203. 6. On or about June 8, 2007, Janice Mazock parked her 2001 Chevy S-10 in front of a jewelry store on Hanover Street in the Borough of Carlisle. COUNTI Janice Mazock v. Vladmir Nikitin and West Point Transportation 7. Paragraphs 1 through 6 are incorporated herein by reference as though fully set forth below. 8. On or about June 8, 2007, Defendant Vladmir Nikitin was operating a tractor trailer in the scope ofhis employment with Defendant West Point Transportation heading north on Hanover Street. 9. At that time, Defendant Nikitin caused the right side of his trailer to strike the left side of the Plaintiff's parked vehicle. 10. Defendant Nikitin's negligence was the direct and proximate cause of the damage to Plaintiff's vehicle. 11. Defendant West Point Transportation is liable for Defendant Nikitin's negligence under a theory of vicarious liability. 12. As a direct and proximate result of the collision, Plaintiff's vehicle was damaged in the amount of $2,552.72. A copy of that property damage estimate totaling $2,552.72 is attached hereto as Exhibit "A." WHEREFORE, Plaintiff demands judgment against the Defendants, jointly and severally, in the amount of $2,552.72. COUNT II Janice Mazock v. Summit Transportation and Vyacheslav Volkov 13. Paragraphs 1 through 12 are incorporated herein by reference as though fully set forth below. 14. On or about June 8, 2007, Defendant Vyacheslav Volkov was operating a tractor trailer in the scope of his employment with Defendant Summit Transportation heading north on Hanover Street. 15. At that time, Defendant Volkov caused the right side of his trailer to strike the left side of the Plaintiff's parked vehicle. 16. Defendant Volkov's negligence was the direct and proximate cause of the damage to Plaintiff's vehicle. 17. Defendant Summit Transportation is liable for Defendant Nikitin's negligence under a theory of vicarious liability. 18. As a direct and proximate result of the collision, Plaintiff's vehicle was damaged in the amount of $2,552.72. A copy of that property damage estimate totaling $2,552.72 is attached hereto as Exhibit "A." WHEREFORE, Plaintiff demands judgment against the Defendants, jointly and severally, in the amount of $2,552.72. MARTSON LAW OFFICES By J George B. Faller, Jr., Esquire I.D. No. 49813 Seth T. Mosebey, Esquire I.D. No. 203046 10 East High Street Carlisle, PA 17013 (717) 243-3341 Date: //?? Attorneys for Plaintiff EXHIBIT "A" J DONEGAL INSURANCE GROUP 1195 RIVER ROAD P O. BOX 302 %IARIET'A, PA 17547-03(22 (717) 426-1531 FAX (717) 426-7023 `** ESTIMATE *** 06/142007 01 40 PM • Owner: MICHAEL & JANICE MAZOCK Address: 251 S HANOVER ST Home/Day: (717,241-0606 City State Zip: CARLISLE, PA 17013 ntrol Information Claim#: PAE-PA 01-07-0001236-101 Insured Policy M. PAE 0507792 Loss Date)Time: 06108/2007 Loss Type: Collision Deductible: $500.00 File #: Accounting M 4255 Ins. Company: Donegal Mutual Insurance Group Agent: ANGELA CHEVAUX Address: Email: angelachevauxo_donegalgroup.com Insured: MICHAEL & JANICE MAZOCK Address: Claim Rep: ANGELA CHEVAUX Address: Email: angelachevauxQdonegaigroup.com Loss Payee: PSECU Work/Day: (800)877-0600x7435 Home/Day: (717)241-0606 Work/Day: (800)877-0600x7435 Inspection Date: 06/11/2007 12:16 PM Inspection Type: Field Inspection Location: Owner's residence Contact: MICHAEL OR JAN ICE MAZOCK Address: 251 S HANOVER ST Home/Day: (717)241-0606x City State Zip: CARLISLE, PA 17013 Primary Impact: Left Front Corner Secondary Impact: Left Rear Side Driveable: Yes Rental Assisted: Assigned Date/Time: Received Date/Time: 06/111200712.2513M First Contact DatelTlms: Appointment DatelTime: 06/122007 12:00 PM Appraiser Name: JACK CHIARA Appraiser License #: 416512 Address: P O. BOX 567 Work/Day: (717;737-5757 City State Zip: NEW CUMBERLAND, PA 17070 FAX: (717;737-7501 • Repairer: RUFE CHEVROLET Contact: Address: '601 RITNER HIGHWAY Work,,Day: r7 243-5)21 City State Zip: CARLISLE, PA 17013 FAX: X7'7'2-43-1`,019 License #: Regulation ID: 73'275 36 Target Complete DateiTime: Days To Repair: 6 '6-, 14,2 CC7C'4)PM °?qe ct 5 Exhibit "A" 2001 Chevrolet S10 LS 2 CR Ext Cab '6t14,2CC7 C1 40 PM Claim V: PAE-PA-CI-07-0001236- 01 2CC1 Chevrolet S10 LS 2 DR Ext Cab 4cyl Gasol re 2.2 FLEX 4 Speed Automatic Lic.Plate: YHG-8065 Llc State: PA Llc Expire: VIN: 1GCCS195X1K1C4836 Prod Date: Mileage: 27,317 Veh Insp#: Mileage Type: Actual Condition: Good Code: U8544A Ext. Color: RED TINT PEARL MET Int. Color: Ext. Refinish: Three-Stage UserDefined Int. Refinish: Ext. Paint Code: 861379E In(. Trim Code: IF. Air Conditioning Aluminum/Alloy Wheels Antl4ock Brakes Compact Disc Player Digital Clock Dual Airbegs Intermittent Wipers Lighted Entry System Paver Brakes Power Steering Rear Jump Seat(s) Rear Step Bumper Split Front Bench Seat Tinted Glass Velour/Cloth Seats 1 I 7 Bumper,Front Repair 2.0* SM 2 L 7 14 Bumper,Front Refinish 2.5 RF 1.1 Surface 1.0 Three-stage setup 0.4 Three-stage 3 N 92 Front Bumper Overhaul Additional Labor 2.3 SM 4 BR 83 Panel,Hood Blend Refinish 2.0 RF 1.0 Blend- 1.0 Three-stage 5 EU 103 Fender,Front LT LIKE KIND & QUAL,PRT $100.00 +25 2.1 SM » PARTS LOCATED AT CARLISLE AUTO SALVAGE 717-249- 3486 6 L 103 Fender,Front LT Refinish 3.4 RF 1.8 Surface 1,0 Edge 0.6 Three-stage 7 EU 198 Flare,Wheel Opening LT LIKE KIND & QUAL.PRT 0.3 SM » INC W/LKQ FENDER 8 L 198 Flare,Wheel Opening LT Reflnish 0.9 RF 0.9 Surface 9 RI 198 Flare,Wheel Opening LT R & 1 Assembly INC SM 10 RI 1032 Nozzle,W/S Washer LT R & I Assembly 01 SM 11 RI 1033 Nozzle,W/S Washer RT R & I Assembly 0 1 SqA 12 1 96 Pnl,Cab Side Outer LT Repair 1.0' SM 13 L 96 Pnl,Cab Side Outer LT Refinish 2.7 RF 2.0 Surface 01 Three-stage 14 RI 373 Narrep:ate,Cab Rear LT R & I Assembly 0.2 SM 15 EU 207 Coor Assembly,Front LT LIKE KIND & QUAL.PRT $250 )0' +25 2 5 SSA PARTS LOCATED AT CARLISLE AUTO SALVAGE 717-249-3486 16 L <07 D3or Sheil,Frent LT Refinish - 1.9 Surface ; 10 Edge 0.7 Three-stage CA' 14/2007 01.44) Pit F sae ' :1 5 2C01 Chevrolet S410 LS 2 CR Ed Cab J6r14,"2007 C1 40 PM Claim •: PAE-PA-01-07-000123641 17 RI 241 W/Stnp,Be:t Cuter LT R & I Assembly INC SM 18 RI 231 Pnl,inner Door Trim LT R & I Assembly 0.1 SM 19 RI 357 NiPlate,Front Door LT R & I Assembly 112 SM 20 EU 229 Mirror.Outer Standard LT LIKE KIND & QUAL.PRT S35.J0' *25 Nc SM » PARTS LOCATED AT CA RLISLE AUTO SALVAGE 717-249-3486 21 RI 229 Mirror,Cuter Standard LT R & I Assembly :NC SM 22 RI 227 Handle.Front Door Otr LT R & I Assembly iNC SM 23 l 389 Panel,Bedside LT Repair 2.0' SM 24 L 389 Panel,Bedside LT Refinish 4.1 RF 3.0 Surface 1.1 Three-stage >> BLEND WITHIN PANEL 25 N 975 Bed Assembly,Set Back Additional Labor 2.0 SM 26 BR 397 Door,Fuel Filler LT Blend Refinish 0.2 RF 0.1 Blend 0.1 Three-stage 27 N FRONT END ALIGNMENT Additional Labor $49.95' SM' 28 EC CAR COVER Replace Economy $5.00" SM' 29 EC FLEX Replace Economy $6.00' SM' 30 EC CORROSION PROTECTIO Replace Economy $8.00' SM' 31 EC PINSTRIPES- TAPED Replace Economy 512.00• 0.3 SM' 32 SS HAZARDOUS WASTE Sublet Repair $3.00 SM' 32 items 14 INCLUDES 1.0 HOURS FIRST PANEL THREE-STAGE ALLOWANCE Estimate • Other Parts 546715 Paint Materials $388.00 Line Item Markup $96.25 Parts & Material Total $952.20 Tax on Parts & Material 6.00044_ $57.13 Sheet Metal (51111) $42.00 5.9 9.3 15.2 $638.40 MectV09c (ME) $45.00 Frame (FR) $48.00 Refinish (RF) $42.00 19.4 19.4 $814.80 Paint Materials $20.00 Labor Total 34.6 Hours $1,453.20 Tax on Labor 6.000° $87.19 Sublet Repairs 53.00 Gross Total $2,552.72 Less: Deductible $500.00- Net Total $2,052.72 A ternate Farts Y,OC,,' 30ICCa;0,00 CUM 00100/00;,1)100 Zip Code: '7111 HARRISBL,RG Audatex Estimating 4.0.484 ES 06/1412007 01:40 PM REL 4.0.484 DT 05XV2007 D8 06/0812007 Copyright (C) 2006 Audatex North America, Inc. 06:14!'C0 ' 01 4) F M C 1qe 3 VERIFICATION The foregoing Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. Janice Ntaiock F:\FILES\Clienro\Donega13050NCurrent\50013050.500.com 1 r CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent for Martson Law Offices, hereby certify that a copy of the foregoing Amended Complaint was served this date by depositing same in the Post Office at Carlisle, PA, certified mail, postage prepaid, return receipt requested, addressed as follows: Mr. Vladmir Nikitin 6520 Fisher Road Edmonds, WA 98026 West Point Transportation 6520 Fisher Road Edmonds, WA 98026 Mr. Vyacheslav Volkov 1715 E. 40`h Avenue Spokane, WA 99203 Summit Transportation 1715 E. 40"' Avenue Spokane, WA 99203 MARTSON LAW OFFICES By: ?'f 0'ac& Mary Uce Ten Egh Street Carlisle, PA 17013 (717) 243-3341 Dated: 1-5J Y C vp Cl> ,1 . co C ft F:\FILES\Clients\Donegal3050\Current\500\3050.500.affidavitl\fm Created: 9/20/04 0:06PM Revised: 6/16/09 10: 24AM 3050.500 George B. Faller, Jr., Esquire I.D. No. 49813 Seth T. Mosebey, Esquire I.D. No. 203046 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JANICE MAZOCK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-0135 CIVIL ACTION -LAW VLADMIR NIKITIN and WEST POINT TRANSPORTATION, and SUMMIT TRANSPORTATION and VYACHESLAV VOLKOV, Defendants : JURY TRIAL DEMANDED AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) . SS. COUNTY OF CUMBERLAND The Complaint was originally served upon Defendants Vladmir Niktin and West Point Transportation via certified mail, return receipt requested and returned by the Post Office marked unclaimed. Therefore, the reinstated Complaint was mailed via regular first class mail on Tuesday, February 19, 2008, upon Defendants VladmirNikitin and West Point Transportation at 6520 Fisher Road, Edmonds, Washington 98026, and was received by them as acknowledged by copy of the attached letter dated April 11, 2008, signed by Defendant Vladmir Nikitin, owner of West Point Transport. MARTSON LAW OFFICES By J . George B. Faller, Jr., Es ire I.D. No. 49813 Seth T. Mosebey, Esquire I.D. No. 203046 10 East High Street Carlisle, PA 17013 (717) 243-3341 Sworn tos?c?,nd subscribed before me this day of June, 2008. COMMONWEALTH OF PENNSYLVANIA JAe ` NotaA Mary M. Prlae, NoW Auo r Notary Pubic Cadisle Boro, Cumberland County No ublic My Cam" m E*Wft Aug. 18, 2011 Member, Pennsylvania Association d NotarNa r April 11, 2008 To Whom It May Concern: My name is Vladimir Nikitin, owner of the company West Point Transport. I am writing you because I received a letter from your law office stating that a suit was being filed against me. Your client Janice Mazock claims that my trailer struck her vehicle on June 8th, 2007 in the city of Carlisle, Pennsylvania. I have a police report from that day saying someone saw the incident and then followed the truck and trailer, but only managed to get the license plate of the trailer which belongs to West Point Transportation. In the report they said they could not make out the truck that was pulling the trailer, and could not get a license number. I was pulling the trailer up to Carlisle but never made it, because my truck broke down on eastbound 1-76, mile marker 217 around 6:00 am on June 8`h. My truck was then towed to a Freightliner repair shop in Harrisburg, Pennsylvania. I left with the tow truck driver and went to the shop, but my trailer still had to be dropped off in Carlisle for the unload process. I work for Summit Transportation under contract which is based out of Spokane, Washington. Summit Transportation makes all the arrangements for the load. They are my dispatcher and they answer for the load I am carrying. Summit Transportation made arrangement for my trailer on June 8th to be towed from mile marker 217 to Carlisle where it could be unloaded. My trailer was left on 1-76 in a pocket right by mile marker 217 and then picked up later that day by a driver hired by Summit Transportation. I do not have the information of the driver that was pulling my trailer; please contact Summit Transportation for that information. My trailer was then dropped off near the Freightliner shop where my truck was being diagnosed. From my understanding the person who was pulling my trailer is to blame. I did not know of the incident until I received an insurance claim from Mrs. Mazock's insurance company stating that I struck her vehicle. When my trailer was returned to me it was undamaged. I have a receipt from my tow company saying where and when I got picked up, my truck was in Harrisburg, as was I, for six days until they could diagnose my truck; which needed a new engine so it couldn't have towed my trailer. All claims should go to Summit Transportation and the driver they hired to pull my trailer. Attached is my tow receipt and Summit Transportation's information. I await your reply. Summit Transportation Vyacheslav Volkov E 1715 40th Ave Spokane, WA 99203 Sincerely, 1 V. (?Ul' Vladimir Nikitin RECEIVE APR 2 3 2008 NAARTSO rI CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, hereby certify that a copy of the foregoing Affidavit of Service was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Mr. Vladmir Niktin West Point Transportation 6520 Fisher Road Edmonds, WA 98026 MARTSON LAW OFFICES By /( - ONiaij N# Price Dated: G 1161 0 r.a -Q i c . r7l war T ? ?? ? Ga "? ~ F:\FILES\Clients\Doneo3050\Current\500\3050.500.aff.serv3\rrias Created: 9/20/04 0:06PM Revised: 6/16108 10:37AM 3050.500 George B. Faller, Jr., Esquire I.D. No. 49813 Seth T. Mosebey, Esquire I.D. No. 203046 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JANICE MAZOCK, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VLADMIR NWdTIN and WEST POINT TRANSPORTATION, and SUMMIT TRANSPORTATION and VYACHESLAV VOLKOV, Defendants NO. 08-0135 CIVIL ACTION -LAW JURY TRIAL DEMANDED AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) . SS. COUNTY OF CUMBERLAND I hereby certify that a copy of the Complaint in the above captioned matter was mailed to Mr. Vyacheslav Volkov, 1715 East 40"' Street, Spokane, WA 99203, by certified mail, return receipt requested, on May 9, 2008. Attached is the Post Office return receipt signed and dated May 13, 2008. MARTSON LAW OFFICES Sworn to and subscn ed before me this day of June, 2008 ' A'w Not j ublic By oz" Seth T. Mosebey, Es ire Attorney I.D. No. 203046 Ten East High Street Carlisle, PA 17013 (717) 243-3341 COMMONWEALTH OF PENNSYLVANIA NotaAd Sad Mary M. Prins, Notary PtbAc L04mrsim ne eoro, cWtorland C=* EWM Auy.18, 2011 Member, PenneylVenle Maoelatlon of NZIea _y • compk" mama t #'C' a" Ju desU ' -- Rem 4 if Restricted DelKwy Is the reverse ¦ Print your name and address On so that we can retum the card to you- • Attach this cmd to the back of the mailpiece, A. V ?d4 Cam`W"ai pm ?I'M3 a. rw ua..p.... ^- 70D6 0610 0000 7873 8494 = .. * - _r ? (Domestic Mail Only; No Insurance C overage Provi ded) W N •11 , Postage $ tl C3 Certified Fee $2,45 ? C3 0 Retum Receipt Fee (Endorsement Required) ' 1` C ? &e O r-a ResMoted Deifvery•Fee (Endorsement Regwred) $ i it. ; CO C3 Total Postage & Fees !1 . M ant or PO Box PAGW Ps Fam 3b11, F?bruery oom. ilahrn CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, hereby certify that a copy of the foregoing Affidavit of Service was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Mr. Vyacheslav Volkov 1715 East 40`h Street Spokane, WA 99203 MARTSON LAW OFFICES By it - Mary rice Dated: re % Q4F> rv ` t ?; ? , ?? ?' ? ? J ?.. ?ii // P-' _ ! . ? ? ? ?J i ? ? J i ?. F:\FILES\Clients\Donegal3050\Cutrent\500\3050.500.aff.serv2\nias Created: 9/20/04 0:06PM Revised: 6/16/08 10: 34AM 3050.500 George B. Faller, Jr., Esquire I.D. No. 49813 Seth T. Mosebey, Esquire I.D. No. 203046 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JANICE MAZOCK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-0135 CIVIL ACTION -LAW VLADMIR NIKITIN and WEST POINT TRANSPORTATION, and SUMMIT TRANSPORTATION and VYACHESLAV VOLKOV, Defendants : JURY TRIAL DEMANDED AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND ) I hereby certify that a copy of the Complaint in the above captioned matter was mailed to Summit Transportation, 1715 East 40`' Street, Spokane, WA 99203, by certified mail, return receipt requested, on May 9, 2008. Attached is the Post Office return receipt signed and dated May 13, 2008. MARTSON LAW OFFICES Sworn to and subscn ed before me this J day of June, 2008. 94?.2?- Not6eublic By -D-/,& I ?? Seth T. Mosebey, Esquire Attorney I.D. No. 203046 Ten East High Street Carlisle, PA 17013 (717) 243-3341 COMMONWEALTH OF PENNSYLVANIA Notarial Seel Mary M. Price, Notary PLkk Carlisle Boro, Ctrrtbe land Co x tY MY Corti I E)om Aug. 18, 2011 Member, Penn0vanla Assodatton of Notaries Complete items 1, 2, and 3. AI?OMP? iNAM 4 if Restricted Delivery 1A Print your name and address on the reverse go that we can return the Crud to you. ¦ Attach this card to the back of the maiipiece, or on the front if space Perrnits- 1. Article Addmsssd to: G? V? A. 0 Nord X ? Addresses C. Date of Delivery a. Received by 0 Yes D. delivery address ditiererlt from tt X14 p No If YES, enter delivery add? f l S [? /?Ja3 3i= Type Mail I ° Merchandise ,? Rewgmewfed / ? insured Mail 0 C. . . 4. Restricted DONVOry? P" Feel Yea 2. Armt•??+?w? 7Oa6 Owl DODO 7873 8364 ,aa ar?+a te?o (li,,,r+?,,?oa+..riMr.,lre+$ Dw ww Ratwn Pm )W P8 Form 3811, FebnwY 20t4 us Postal Servlc?', x CERTIFIED • m (Domestic CO ISO ?j x ^;, co Efi,S Postage $ / C3 O Certified Fee $2 `65 Q d Return Receipt Fee d C3 (Endorsement Required) ted Delivery Fee tri R { {} ? ?`? r-I es c (Endorsement Required) . {. 1 cc O Total Postage & Fees ,? c'' 38 i?. t TO " ° 3iiae,aat CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, hereby certify that a copy of the foregoing Affidavit of Service was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Summit Transportation 1715 East 40th Street Spokane, WA 99203 MARTSON LAW OFFICES By VAW)/f < p M . Price /?G/LO Dated: ° ' 1 C ,? ?` ? t'? ?- ??? ? " ? L.? ?: ? ?? 1 ?'1 1 ?q .? ; s? ? ,,_?. t ....? r 44 w,r+` te" , lI . . ;? L J ? . y f ?? ? y y ® ?Y ! F:\FILES\Clients0onega13050\Current\500\3050.500.pra2.wpd\mas Created: 9/20/04 0:06PM Revised. 8/28/08 9:08AM 3050.500 George B. Faller, Jr., Esquire I.D. No. 49813 Seth T. Mosebey, Esquire I.D. No. 203046 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JANICE MAZOCK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-0135 CIVIL ACTION - LAW VLADMIR NIKITIN, WEST POINT TRANSPORTATION, SUMMIT TRANSPORTATION and VYACHESLAV VOLKOV, : Defendants. JURY TRIAL DEMANDED PRAECIPE TO THE CUMBERLAND COUNTY PROTHONOTARY: Kindly mark the above-referenced matter as settled, discontinued and ended. MARTSON LAW OFFICES By. George B. Faller, Jr., Esquire I.D. No. 49813 Seth T. Mosebey, Esquire I.D. No. 203046 10 East High Street Carlisle, PA 17013 (717) 243-3341 Dated: August 28, 2008 CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Mr. Vladmir Niktin 6520 Fisher Road Edmonds, WA 98026 West Point Transportation 6520 Fisher Road Edmonds, WA 98026 Summit Transportation 1715 East 40t' Street Spokane, WA 99203 Vyacheslav Volkov 1715 East 40`' Street Spokane, WA 99203 MARTSON LAW OFFICES LA -) By / M . Price Dated: a< 02S/ 0 d _ r-0 co t 3i L!4 ?f