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HomeMy WebLinkAbout03-65941N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSiVE CASUALTY INS. CO. As subrogee of Faith Wait Plaintiff, MELONIE SALADA, A minor Defendant. TYPE OF PLEADING: COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: GERIANNE HANNIBAL, ESQUIRE Pa. I.D. #66622 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #03337763 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSWE CASUALTY INS. CO. As subrogee of Faith Wait Plaintiff, CASE NO: TYPE OF PLEADING: COMPLAINT IN CML ACTION MELONIE SALADA, A minor 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 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 thrther 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 fights 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 4th floor Cumberland County Courthouse Carlisle PA 17103 717 240-6200 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CiVIL DiVISION PROGRESSiVE CASUALTY INS. CO. As subrogee of Faith Wait Plaintiff, MELONIE SALADA, A minor Defendant. CASE NO: TYPE OF PLEADING: COMPLAINT IN CIVIL ACTION COMPLAINT IN CML ACTION AND NOW COMES, Plaintiff by and through its counsel, WELTMAN, WEINBERG & REIS, CO., L.P.A., and hereby files this Complaint against Defendants. In support thereof, Plaintiff avers as follows: I. Plaintiff, Progressive Casualty Insurance Company ("Progressive"), is a corporation with a registered office located at P.O. Box 43258, Richmond Heights, Ohio. 2. Defendant, Melonie Salada, upon information and belief is a minor a last known address of 1812 Carlisle Road, Camp Hill PA 17070. 3. Progressive issued a policy of insurance where Progressive agreed to insure a 1996 Dodge ("Insured Vehicle"), owned by Plaintiff's insured. 4. At all times mentioned herein, Progressive's insured was the owner of said Insured Vehicle. 5. On or about January 10, 2002, Defendant Melonie Salada took the Progressive insured vehicle without permission and thereafter negligently, recklessly and carelessly operated the vehicle causing damage to same on Woodland Drive in Riverview, PA. 6. As a direct and proximate result of Defendant's negligence, the Progressive vehicle sustained property damage in the amount of $5,299.21. 7. Pursuant to the terms and conditions of the insurance policy, Progressive paid the sum of $5,299.21. A true and correct copy of the drafts paid by Progressive to and on behalf of its Insured are attached hereto as Exhibit "1" and made a part hereof. 8. 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. 9. Pursuant to Progressive's right of subrogation, Progressive is presently due and owed from Defendant the sum of $5,299.21. 10. Repeated demands have been made upon Defendant for payment of the aforesaid sum; however, Defendant have willfully failed and refused to pay the stun due and owing to Progressive. WHEREFORE, Plaintiffdemands Judgment against Defendant, for $5,299.21 and costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. Respect fully S//¢b~ny,7/~ Weltman, Weinberg & Reis, Co., L.P.A. 2718 Koppers Bldg. 436 7th Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03337763 SUBROGATION ~0o7/oo$ 12/12/2003 12:21 FAX 0,406035255 Page: 1 Document Name: urltitled CMSD2340 7CMSM2340 P A C M A N OPID: JXF0094 CLAIM PAYS~ENT INQUIRY INSD: WAIT, FAITH DOL : JAN 10 02 PA~HARRIS-BRIq- CLM: 027618559 ACTIVE SEP 30 03 12:03 TERMID: VT630228 POL: 50381660-2 REP: N MCFLALE PAY TO THE ORDER OF: TOTAL DP. APT AMOUNT: 5,784.21 LINE LINE 2: LINE 3: AMERICREDIT FINANCIAL SERVICES, ACCT.%409588837 INC., ONLY ***************** ADDRESS: ATTN: PAYMENT PROCESSING P.O.BOX 99605 CITY: ARLINGTON ST/PR* TX ZIP/CPC: 76096 IN PAYMENT OF: PMT-T/L'96 DODGE STRATU~ LESS DED/PROG.OBT.SALVAGE 1099 ? N FEDER3%L TAX ID: CDS CODE * 12 PCL EFT TR/kCE #: BANK CODE* AS2 ISSUE DATE : JAN 22 02 STATE * PA Ai~EA * 252 STOP RSN * DRAFT ~ : 423422983 LAST UPDT REP: NJS0003 ISSUING REP: N MCHALE APPROVED BY: REVIEW DATE: 00 00 REVIEWED BY: CNTRY* USA COMMAND: Date: 09/30/2003 Time: 12:03:i8 PM SUBROGATION ~005/008 __ .12/12/2003 12:21 FAI 4406035255 Page: 1 Document Name: untitled CMSD2360 ~CMSM2360 P A C M A N OPID: JXF0094 LOSS PAYMENT INQUIRY INSD: WAIT, FAITH DOL : JAN 10 02 PA-KARRIS-BRN- CLM: 027618559 DRAFT#: 423489356 TOTAL DRAFT AMOUNT: NAME: WAIT, FAITH DED TAKEN: PD AMOUNT: TOW AMOUNT: NAME: DED TAKEN: PD AMOUNT: TOW AMOUNT: NAME: DED TAKEN: PD AMOUNT: TOW AMOUNT: DC912747 ONLY PAGE COMMAND: L/COV: COLL MED: PARTS DISC: RENTALAMT: RENTAL DAYS: L/COY: MED: PARTS DISC: RENTAL DAYS: L/COY: MED: PARTS DISC: RENTAL AMT: RENTAL DAYS: ACTIVE SEP 30 03 - 12:03 TER~ID: VT630228 POL: 50381660-2 REP: N MCHALE 335.00 TYP* S AMT PAID: WC TYP* WAGE: USED PARTS AMOUNT: MISC AMOUNT: PROCESS* TYP* AMT PAID: WC TYP* WAGE: USED PARTS AMOUNT: MISC AMOUNT: PROCESS* TYP* AMT PAID: WC TYP* WAGE: USED PARTS AMOUNT: MISC AMOUNT: PROCESS* 335.00 Date: 09/30/2003 Time: 12:03:15 PM .12/~20__03 12:21. FAX 4406035255 S[rBROGATION ~005/008 Page: i Document Name: untitled CMSD2340 7CMSM2340 P A C M A N OPID:' JXF0094 CLAIM PAYMENT INQUIRY INSD: WAIT, FAITH DOL : JAN !0 02 PA-~iARRIS-BRN- CLM: 027618559 ACTIVE SEP 30 03 12:03 TERMID: VT630228 POL: 50381660-2 REP: N MCHALE PAY TO THE ORDER OF: TOTAL DRAFT AMOUNT 335.00 LINE 1: LINE 2: LINE 3: SALVAGE DIRECT, ******************************************** ADDP~ESS: 116 CALDWELL STREET CITY: TITUSVILLE ST/PR* PA ZIP/CPC: 16354 IN PAYMENT OF: S/D/A $ 9267 * IV * '96 DODGE STRATUS C~TRY* USA 1099 ? N FEDERAL TAX ID: CDS CODE * 12 PCL EFT TRACE #: BAAIK CODE* AS2 ISSUE DATE : JAN 29 02 STATE * PA AREA * 254 STOP RSN * DRAFT # : 423489356 LAST UPDT REP: AXS0016 ISSUING REP: A SNYDER APPROVED BY: REVIEW DATE: 00 00 REVIEWED BY: COMMAND: Date: 09/30/2003 Time: 12:03:13 PM 12/12/2003 12:21 FAX 4406035255 SUBROGATION Page: 1 Document Name: untitled CMSD2360 /CMSM2360 P A C M A N OPID: JXF0094 LOSS PAYMENT INQUIRY INSD: WAIT, FAITH DOL : JA/~ 10 02 PA-F~RRIS-BR/~- CLM: 027618559 ACTIVE ~008/005 SEP 30 03 12:03 TERMID: VT630228 POL: 50381660-2 REP: N MCHALE DRAFT~: 423422983 NAME: WAIT, FAITH DED TAKEN: PD AMOUNT: TOW AMOUNT: NAME: DED TAKEN: PD AMOUNT: TOW A~OUNT: NAME: DED TAKEN: PD A~OUNT: TOW AMOUNT: DC912747 ONLY PAGE COMMAND: TOTAL DRAFT AMOUNT: L/COV: COLL M~D: PARTS DISC: RENTAL AMT: RENTAL DAYS: L/COY: MED: PARTS DISC: Pd~NTAL AMT: RENTAL DAYS: L/COY: MED: PARTS DISC: RENTAL AMT: RENTAL DAYS: 5,784.21 TYP* F AMT PAID: WC TYP* WAGE: USED PARTS AMOUNT: MISC AMOUNT: PROCESS* TYP* AMT PAID: WC TYP* WAGE: USED PARTS AMOUNT: MISC AMOUNT: PROCESS* TYP* AMT PAID: WC TYP* WAGE: USED PARTS AMOUNT: MISC AMOUNT: PROCESS* 5,784.21 Date: 09/30/2003 Time: 12:03:20 PM 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 other knowl~,!>e, information and belief. ./ a e I Geriafl~--e'Flarmi al, uire IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DWISION PROGRESSIVE CASUALTY 1NS. CO. As subrogee of Faith Wait Plaintiff, Vs MELONIE SALADA, A minor Defendant, Case No.: 03-6594 TYPE OF PLEADING: PRAECIPE TO SUBSTITUTE VERIFICATION FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: GERIANNE HANNIBAL, ESQUIRE Pa. I.D, #66622 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-795:5 WWR #02645029 IN THE COURT OF COMMON PLEAS OF CUMBERLAND cOUNTY, PENNSYLVANIA cWIL DWISION PROGRESSIVE CASUALTY 1NS. CO As subrogee of Faith Wait, Plaintiff, Case No.: 03-6594 VS. TYPE OF PLEADING: MELONIE SALADA, A minor Defendant, pRAECIPE TO sUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached verification to plaintiff's Cotnplaint, which was previously filed with the Court. WELTMP }I-TWEINBERG/~ REIS, CO., L.P.A. Ge [d~ibal, Esqu~ PA ID 66622 2718 Koppers Building 436 Seventh Avenue pittsburgh, PA 15219 (412) 434-7955 DEC-18-2803 14:38 4904 T', ITeL P. ~6 SHERIFF'S RETURN - NOT FOUND CASE NO: 2003-06594 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PROGRESSIVE CASUALTY INS CO VS SALADA MELONIE Thomas Kline ,Sheriff or Deputy Sheriff, who being a diligent search and duly sworn according to law, says, that he made inquiry for the within named DEFENDANT SALADA MELONIE unable to locate Her COMPLAINT & NOTICE in his bailiwick. but was He therefore returns the the within named DEFENDANT SALADA MELONIE 1812 CARLISLE ROAD C~24P HILL, PA 17011 MOVED, NO FORWARDING ADDRESS ON FILE AT POST OFFICE. , NOT FOUND , as to Sheriff's Costs: Docketing 18.00 Service 10.35 Not Found 5.00 Surcharge 10.00 .00 43.35 SO answers__~_...~-~ j~J~ R. Thomas Kline Sheriff of Cumberland County WELTMAN WEINBERG REIS 01/05/2004 Sworn and subscribed to before me this /~ ~ day of ~ ~ A.D. ProthOnotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE CASUALTY INSURANCE COMPANY, SUBROGEE OF FAITH WAIT, Plaintiff VS. MELONIE SALADA, a minor, Defendant No. 03-6594 PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Gerianne Hannibal PA I.D. #66622 WELTMAN, WEINBERG & REIS, CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03337763 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE CASUALTY INSURANCE COMPANY, SUBROGEE OF FAITH WAIT, Plaintiff VS. MELONIE SALADA, a minor, Defendant Civil Action No. 03-6594 PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, W~INBEF:~ &,~EIS CO., L.P.A. Gerianne-~a~al ! PA I.D. #66622 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #03337763 SHERIFF'S RETURN - REGULAR CASE NO: 2003-06594 P C©MMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PROGRESSIVE CASUALTY INS CO VS SALADA MELONIE BRIAN BARRICK Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE SALADA MELONIE DEPENDANT , at 1230:00 HOURS, at 541 HERMAN AVENUE LEMOYNE, PA 17043 CARLA SALADA, MOTHER a true and attested copy of COMPLAINT & NOTICE was served upon the on the 26th day of January , 2004 together with by handing to and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18 00 11 04 00 10 00 00 39 04 Sworn and Subscribed to before me this J[~L~ day of gPtothonotary So Answers: Thomas Kline Deputy Sheriff 04HB-00018 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Melonie Salada PROGRESSIVE CASUALTY INS. Co. AS SUBROGEE OF FAITH WAIT, PLAINTIFF VS. MELON1E SALADA A MINOR~ DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-6594 CIVIL ACTION - LAW JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance in the above-captioned matter on behalf of the Defendant, Melonie Salada. The Defendant reserves the right to otherwise plead in this matter. Date: March 4, 2004 Respectfully submitted, / Attorney for Defend~t Co~ I.D.39126 04HB-00018 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Melonie Salada PROGRESSIVE CASUALTY INS. CO. AS SUBROGEE OF FAITH WAIT, PLAINTIFF VS. MELONIE SALADA A MINOR, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY~ PENNSYLVANIA No. 03-6594 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Doter, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached Entry o£Appearance to be served by regular first class mail upon: Date:_ March 4, 2004 Gerianne Hannibal, Esquire Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Building Donald R. Dorer, Esquire Attorney for Defendant 04HB-00018 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant PROGRESSIVE CASUALTY INS. CO, AS SUBROGEE OF FAITH WAIT~ PLAINTIFF VS. MELONIE SALADA, A MINOR DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 03-6594 CIVIL ACTION - LAW JURY TRIM, DEMANDED ANSWER OF DEFENDANT, MELONIE SALADA, TO PLAINTIFF'S COMPLAINT 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Denied. Paragraphs 5 through 10 of PlaintiWs Complaint are generally denied pursuant to Pa.R.C.P. §1029(e). WHEREFORE, the Defendant respectfully prays this Honorable Court to dismiss Plaintiff's Complaint, and to enter judgment against the Plaintiflgs and in favor of the Defendant. Date: April 8, 2004 Respectfully submitted, LA A TES B~'~"~~ / ~" Donald R.~I~orer, Esquire Identification No. 39126 A~omey for Dofond~t 04HB-00018 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant PROGRESSIVE CASUALTY INS. CO, AS SUBROGEE OF FAITH WAIT, PLAINTIFF VS. MELONIE SALADA, A MINOR DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERL3~D COUNTY~ PENNSYLVANIA No. 03-6594 CIVIL ACTI[ON - LAW JURY TRIAL DEMANDED VERIFICATION I, Melonie Salada, verify that the statements made in the foregoing Answer of Defendant, Melonie Salada, to Plaintiff's Complaint , which are within the personal knowledge of the undersigned, are true and correct, and as to the facts based on the information of others, the undersigned, after diligent inquiry, believe them to be true. And further, this Verification is signed on the recommendation of my attorneys, who advise me that the allegations and language in this document are required legally to raise issues for resolution at trial, by the Court, or by continuing investigation and preparation for trial. I understand that some of these allegations may prove inappropriate after investigation and trial preparation are complete and I leave the determination of these matters to my attorneys on their advice. I understand that all statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsifications to authorities. Dated: Melonie Saladfi 04HB-00018 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Melonie Salada PROGRESSIVE CASUALTY INS. CO. AS SUBROGEE OF FAITH WALT, PLAINTIFF VS. MELONIE SALADA A MINOR~ DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY~ PENNSYLVANIA No. 03-6594 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached Answer of Defendant, Melonie Salada, to Plaintiff's Complaint to be served by regular first class mail upon: Date: April 8, 2004 Gerianne Hannibal, Esquire Weltman, Weinberg & Reis Co., L.P.A. 2718 K°ppers Buildini (_/~~ 436 Seventh ~ e~ t Pittsburgh, ld~R. Dorer, Esquire Attorney t3r Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLltND COI/NTY, PENNSYLVANIA CIVIL DIVISION' Progressive Casualty Ins. Co, Subrogee of Faith Wait, Plaintiff VS. Melonie Salada, a minor Defendant as : File No. 2003-6594 WRIT TO JOIN ADDITIONAL DEFENDANT PP~AECIPE ] TO THE PROTHONOTARY OF SAID COURT: Issue writ to join the following as additional defendant: in the above-captioned case: Clifford Jensen, 1103 Bridqe Street, New Cumberland, Cumberland County, Pennsylvania. Counsel for Plaintiff is: Gerianne Hannibal, Esquire Counsel for Additional Defendant (if knownand verified) is: ~ Date: ADril 21, 2004 Signature:~f~ ~ Print Nam~:~x-B6nald squire Address: 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Supreme Court ID No. 39126 Telephone No. (717) 731-0988 WRIT OF SUMMONS TO ADDITIONAL DEFENDANT TO: Clifford Jensen YOU ARE NOTIFIED THAT the Defendant, Melonie Salada HAS JOINED YOU AS AN ADDITIONAL DEFENDANT IN THIS ACTION, WHICH YOU ARE REQUIRED TO DEFEND. ~ Date: Prothonotary By: Deputy 04HB-000'I 8 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Melonie Salada PROGRESSIVE CASUALTY INS. CO. AS SUDROGEE OF FAITH WAIT, PLAINTIFF VS. MELONIE SALADA A MINOR~ DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-6~;94 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Doter, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a, true and correct copy o£the attached Praecipe for Writ to Join Additional Defendant to be served by regular first class mail upon: Date: April 21, 2004 Gerianne Hannibal, Esquire Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 Donald R. Dorer, Esquire Attorney for Defendant Cumberland County, ss: The Commonwealth of Pennsylvania to Clifford Jensen (,Name of Ad~li~ional Defendant) You are notified that Melonie ~]mdm (Name (s) of Defendant (s) ) has (have) joined you as an additional defendant in this action, which you are re- quired to defend. Date April 22, 2094 Curtis R. ~mn~ Clifford Jensen 1103 Bridge Street New Cumberl~nnd, PA SHERIFF'S RETURN - REGULAR CASE NO: 2003-06594 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PROGRESSIVE CASUALTY INS CO VS SALADA MELONIE SH3tNNON SHERTZER Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to says, the within WRIT TO ADD'L DEFEN. was served upon JENSEN CLIFFORD ADD'L DEFENDANT, at 1930:00 HOURS, on the 27th day of April at 1103 BRIDGE STREET NEW CUMBERLAND, PA 17070 by handing to CLIFFORD JENSEN a true law, the , 2004 and attested copy of WRIT TO ADD'L DEFEN. together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18 Service 11 Affidavit Surcharge 10 39 O0 73 O0 O0 O0 73 Sworn and Subscribed to before me this 2g~ day of ~f~ 6'D ,~ A.D. ' t~rothonotary So Answers: R. Thomas Kline 04/28/2004 NATIONWIDE INSURANCE Deputy Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSlCE CASUALTY INSURANCE, CO.. SUBROGEE OF FAITH WATT., Plaintiff VS. MELONIE SALADA, A MINOR Defendant No. 03-6594 PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Gerianne Hannibal, Esquire PA. I,D.#66622 WELTMAN, WEINBERG & REIS CO., UP,A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03337763 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSlCE CASUALTY INSURANCE, CO., SUBROGEE OF FAITH WATT., Plaintiff vs. Civil Action No. 03-6594 MELONIE SALADA, A MINOR Defendant PRAEClPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILl= TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Settle, Discontinue and End the above-captioned matter upon the records of the Court without prejudice to refile and mark the costs paid. SWORN TO AND SUBSCRIBED before me this c~[ day WELTMAN, WEINBEF~G,&~REiS CO., By' ~a Ge'rianne I, Esquire PA. I.D.#66622 L.P.A. WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WVVR#03337763 04HB-00018 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Melonie Salada PROGRESSIVE CASUALTY INS. CO. AS SUBROGEE OF FAITH WAIT, PLAINTIFF VS. MELONIE SALADA A MINOR, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-6594 CIVIL ACTION - LAW JURY TRIAl[, DEMANDED PRAECIPE TO WITHDRAW WRIT TO JOIN ADDITIONAL DEFENDANT TO THE PROTHONOTARY: Kindly withdraw of record the Writ to Join Additional Defendant filed with this Corm on April 21, 2004. Respectfully subn~titted, LAW O~lflCES OF :tACOI~S 84]ASSOCIATES Donald Ri l~orer, Esa)tf~-e Identification No. 39126 Attorney for Defendant Date: June 30, 2004 04HB-00018 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Melonie Salada PROGRESSIVE CASUALTY INS. CO. AS SUBROGEE OF FAITH WAIT, PLAINTIFF VS. MELONIE SALADA A MINOR~ DEFENDANT IN THE CO1URT OF COMMON PLEAS CUMBERLAND COUNTY~ PENNSYLVANIA NO. 03-6594 CIVIL ACTION - LAW JURY TRIA]L DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached Praecipe to Withdraw Writ to Join Additional Defendant to be served by regular first class mail upon: Gerianne Hannibal, Esquire Weltman, Weinberg & Reis Co., [,.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 Date: June 30, 2004 Clifford Jensen 1103 Bridge Street New Cumberland, PA 1707~: /.~~~~ DO~'R. Dore~r, Esquire Attorney for Defendant