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HomeMy WebLinkAbout04-0547 COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS SS.~5 Judicial District, County Of NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. tJ.I/- 5 '17 ~ NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case referenced below. -} NNanHttLANT 6lad~ AtORESS OF APPELLANT 6 ~ifQDGMEUJ(t ~q m1e~'N ~1~r. OF (PI.'"tiff) }- J') '0 LJ I t rf€ ..')Y1J,u \71 nrt' DOCK~ v- OC() 0 3cr5-o3 I MA"(J(td'O I r;'"f/,s(.p I N$~;L74 ,i ZIP CODE i7N~ (Defendant) " A la tU L A/u,l/ SIGNATURE OF APPEl~T OR A~~RNEY oHbNT vf\a~b ~l{llj. This block will be signed QNL Y when this notation is required under Pa. If appellant was Claimant (see Pa. R.C.P.D.J. No. 1001(6) in action R.C.P.D.J. No. 1008B. This Notice of Appeal, when received by the District Justice. will operate as a before a District Justice, A COMPLAINT MUST BE FILED within twenty SUPERSEDEAS to the judgment for possession in this case. (20) days after filing the NOTICE of APPEAL. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONL Y when appellant was DEFENDANT (see Pa.R.CPD.J. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary t'l'(-(> ~Cl'f(UtCR Co appellee(s), to file a complaint in this appeal Enter rule upon Name of appel/ee(s) (Common Pleas No. tW -.5L/7 ) within twenty (20) days after service of rule or suffer entry of judgment of non pros. '-1\ o..,vUt.t... (bl~nalu" or appallanl orattomay or aganl RULE: To CXifktOl'LC.p.....(.0, Name of appel/ee(s) , appellee(s) (1) You are notified that a rule is hereby entered upon you to fiie a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not fiie a complaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailing. Date: i':f..dr 9 ' 200,/ YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENTfTRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312.02 COURT FILE TO BE FILED WITH PROTHONOTARY PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT {This proof of sent/co MUST BE FILED WITHfN TEN (10) DA YS AFTER filing of the notice of apJJeai Check appJicabfe boxes, COMMONWEAL TH OF PENNSYLVANiA COUNTY OF , ss AFFIDAVIT: ! !lcreby (swear; (affJrm) that 1 served copy of the Notice of Appeal. Common Picas No (dale of service) o by personal service Jpon the District JustIce desionatod then31n Oi by (certified) (registered) mal: .20 sender's receipt attached hereto, and upon the appellee, (name) 20 by personal service by (certified) (registered! mal!, sender's receIpt mtacntJd hereto (SWORN) (AEFIRMED) AND SUBSCRIBED BEFORE MF THIS DAY OF Signatvre of official before whom affidavit was mtlda Title of offici a! My commission expires on .20 ~J \. \ \~'\ , '\ ~ '1; ~, 0', ~ ~ 11:, ....... ~. ~ ~', L} I/' \ ~ ~ l l~ t l ~ ~ , ~ ~ ""- AOPC 312A 02 c.... ~~. 1 (') c: -n': n'. " ~~'i: <Jj ,,;- c:':~. ,,-~ , ,,:-/'., :~~:~" -/ :::"'"1 -< Signature d affiant ...., = = .x:- .." f"'I"'""i OJ I U) o -n ---l -,- I~~~ :JJ q. ~,'--i', O:Il -",0 Oni ---I ~ :< ?; CD N CO l Fen OS 04 0~;31a PCORREAL 717-240-7821 p.l COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND ~"'Di"NO 09-2-01 OJ Name: Nor PAULA P. CORREAL , -" 1 "'''''''''00'" "'''ARB I CARLISLE. PA I I T"'P"O"' (717) 240-6564 17013-0000 NOTICE OF JUDGMENTITRANSc.RIPT CIVIL CASE . PLAINTIFF: NAME andll.,QDRESS FERIE INSURANCE CO.. ~ % ROB EDWARDS PO BOX 302 tPILLSBURG, PA 17019 .J VS. DEFENDANT: 'BLACK. NANITA 2260 WAGGONERS GAP RD CARLISLE. PA 17103-8307 L NAME and ADDRESS ., PAULA P. CORREAL 1 COURTHOUSE SQUARE CARLISLE, PA 17013-0000 : Docket No.: i Date Filed: I CV-0000395-03 10/23/03 ..1, , THIS IS TO NOTIFY YOU THAT: JJdgment: [!J Judgment was entered for: FOR PT.lI.INTTl>P (Name) RRTR INflTTIlANr'R ('.0 _ . 00 Judgment was entered against: (Name) -.1lT.l\CK, 1ITl\NITl\ in the amount 01 $ (Date of Judgment) 1/12/04 ":\/1?,~qO on: o o o Defendants are jOintly and severally liable. (Date & Time) r--- i Amount of Judgment i Judgment Costs I Interest on Judgment I Attorney Fees I Total I I Post JJdgment Credits I Post Judgment Costs lCertitied Judgment Total $ Damages will be assessed on: $ 3.026.5J! $ 97,40 $ ;00 $ .00 $ 3.123.90 This case dismissed without prejudice, o Amount of Judgment Subject to Attachment/42 Pa.CS. ~ 8127 $ $ $ C Portion 01 Judgment for physical , damages arising out of residential lease $ ---------._-- ------------ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FiLING A NOTiCE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIViSION. YOU MUST INCLUOE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITIo< YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRiCT JUSTICES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COU~T OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE DISTRICT JUSTICE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WiTH THE DISTRICT JUSTICE IF TIo<E JUDGMENT DE8TOR PAYS IN FULl, SETTLES, OR OTHERWiSE COMPLIES WiTH THE JUDGMENT. 1I12/04 Date. C:4...J'. _~~~ , ~.oistncfJuSlice I certify that this is a true and correct'c9PY otthe reco,b oj)~e 8roCeedlngs;:ontil'i~~~ the_Judgment. , / / (/ - . /"" 1/12/01, Date )x:~,' I, ,,?<... -t.:;. . , ' t , 1" \_ :"~' _; Oistn:t Justice My commiSSion expires lirs; Monday of January, 2006 \ \.:: 'SEAL.' Aope 315.03 "/" '!'III'" 1/12/04 T\&I'Jl~ 'P'RTN'I'ED: 10:57:45 AM .,..-,., ..,..-., PROOF OF SERVICE OF OF APPEAL AND RULE TO FilE COMPLAINT (This proof of seIVice MUST BE FiLED WITHIN TEN (10) DA YS AFTER filing of the notice of appeal. Check opplicohie hox!),) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CU YVJf:;erhd . S8 AFFIDAVIT: I hereby (swear) (affirm) that I served o a copy of the Notlce of Appeal, Common Pleas No. , upc-n the District Justice designated therein on (date a/seIVies) ?-.l<i' .2009 by personal,srvice ~y (cortllled) (registered) mali. sender's rcwipt attached hereto, and upon 1I1e appellee, ' on .20 o by persona! servicE, o by (certified) (registered) mall. sender's receipt attached hereto, '-11cuu~ f2:i .1. ~_..-.-...._._.__.._~....__._._."___e.~_~.L_....._...__....,,.~..._......-...-........-. SignDtvre of Dffhmt (SWORN) ~Ff1jlJV1ED) ANQ-SYElSC. R.IBED BEFOR.. ~ ~ THIS. 10 " b~Y OFT. on.x:tY1j20 0,-/ rub I/~ 0 ....., 0 = C = ." =-::'" .::- -"_11,':':' .." ~ Fir ('T'I m:!J ~2- CO r -om (fl ro 96 -< r;: :r-ri ~~8 "'" - --n :;,t: qo >c ':? orn z =;;! =<! w 'Xl "'" '< ilia ofofficiaJ My commission expires onM LI. 2rDS NOTARIAL SEAL JODY S. SMITH, NOTARY PUBLIC Carlisle Bora, Cumberland County My CommiSSion Expires April 4, 2005 _.~'~---~-~=='- y,"~ ~ '1't ~~~ "tI AOPC 312A. 02 rr"r,"~,"'"' io' '"7"""~",1''''', ,~ .,. '",'1" ",""",V," "1'~~~~' ''',:,~"w-,_.~,~,,,,,....~.~....,,,____..______~_"_,"~,,"__,,_..__.._,, COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS '('j" .', , ' /.~' \...- V > O(.'~_) judicial District, County Of NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. tJ.I/- 5 '-17 C.tt~ NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case referenced below. -} MAG. 0151, NO, Oq'd'OI IT\- &'S(.p ZIP CODE 170!"..J " NT This block will be signed ONLY when this notation is required under Pa. If appellant was Claimant (see Pa. R.G.P.D.J. No. 1001(6) in action R.C.P.D.J. No. 1008B. This Notice of Appeal, when received by the District Justice, will operate as a before a District Justice, A COMPLAINT MUST BE FILED within twenty SUPERSEDEAS to the judgment for possession in this case. 110 n.~ k, ~/t(J, (20) days after filing the NOTICE of APPEAL. Signature of Prothonotary or Daputy l PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONL Y when appel/anf was DEFENDANT (see Pa.R.CP.D.J. No. 1001(lj,in acfion before District Uustice. IF NOT USED, detach from copy of notice of appeal to be served upon appel/ee. J PRAECIPE: To Prothonotary Enterruleupon t'f(f ~~O'\a~ll.f Co Name of appel/ee(s) appellee(s), to file a complaint in this appeal iW -.5~7 ) within twenty (20) days after service of rule or sUffe,r entry of judgment of non pros. '.- f' ell ute (Qf {etv . . Signature of appel/tmt or.attomey or agent (Common Pleas No. RULE: To C l^i t ~(\11 tl U _ (6, Neme of appel/ee(s) , appellee(s) (1) You are notified I!)at a [ule is h~reby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule Upon you bY'I'ersonal service orby certified or registered mail. .,', 'f'J (2) If you do'Aotfile a complaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The da,te. of service of this'rule jf servj~e:was by mail is the date of the mailing. Date: 1-49 ,20CJ9' / Signal of Prothonotary or Deputy :J YOU MUST INCLUDE A COpy OF THE NOTICE OF JUDGMENTITRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. 0'-' ,- AOPC 312-02 COURT FILE Benjamin D. Andreozzi, Esquire Goldberg, Katzman & Shipman, P.c. PO Box 1268 Harrisburg, PA 17108-1268 717-234-4161 Attorneys for Plaintiff ERIE INSURANCE EXCHANGE, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA Plaintiff :NO. 04- SI.J7 r!./ulL ~~ v. NANITA BLACK, : CIVIL ACTION - LAW Defendant NOTICE TO: Nanita Black 2260 Waggoner's Gap Road Mechanicsburg, P A 17055 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 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 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, e4usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus de fens as o sus objectiones alas demandas en contra de su persona. Sea adisado que si usted no se defiende, la sin previo aviso 0 notificacion y por cualquier quja 0 puede perder dinero o sus propiedades 0 otros derechos importantes para usted. LLEVEESTADEMANDAAUNABOGADOIMMEDIATAMENTE. SINO TIENEABOGADO 0 SINOTIENE ELDINERO SUFICIENTE DE PAGAR TAL SERVICIO, V AYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 TELEPHONE: (717) 249-3166 Benjamin D. Andreozzi, Esquire Goldberg, Katzman & Shipman, P.c. PO Box 1268 Harrisburg, PA 17108-1268 717-234-4161 Attorneys for Plaintiff ERlE INSURANCE EXCHANGE, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, P A Plaintiff : NO. 01.[- SI.{'i (l./~l/~ v. NANITA BLACK, : CIVIL ACTION - LAW Defendant COMPLAINT AND NOW, comes the plaintiff, Erie Insurance Exchange, by and through its counsel, Goldberg, Katzman & Shipman, P.e., and flIes the following Complaint avernng: 1. Plaintiff Erie Insurance Exchange (hereinafter "Erie") is a corporation organized and existing under the laws of Pennsylvania, with a place of business located at 4901 Louise Drive, PO Box 2013, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant Nanita Black (hereinafter "defendant Black") is an adult individual who to all belief and knowledge resides at 2260 Waggoner's Gap Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. Defendant purchased homeowner's insurance from plaintiff. A copy of the declarations page is attached hereto as Exhibit "A". 4. At all times relevant to this cause of action, the insurance policy issued by 4. At all times relevant to this cause of action, the insurance policy issued by plaintiff to defendant was valid. 5. On or about May 28, 1998, defendant represented to plaintiff that her home was broken into and that certain items of property were stolen from the residence. 6. Plaintiff's policy provided coverage for incidents involving theft, and accordingly, plaintiff agreed to reimburse defendant for her alleged loss by theft. 7. Plaintiff issued a check to defendant in the amount of $3,026.50. 8. At or about the time of the alleged loss, defendant and her husband were involved in hostile divorce negotiations. 9. Plaintifflearned that the items which defendant claims were stolen were in fact taken from her house by her son. 10. Plaintiff contacted defendant and requested that the money paid to defendant be reimbursed to plaintiff. Defendant and her attorney made repeated promises to plaintiff that the money would be repaid after the divorce agreement was completed. 11. Defendant has refused to make payment. COUNT I ERIE INSURANCE EXCHANGE v. NANITA BLACK INSURANCE FRAUD 12. Defendant knowingly and with intent made false, incomplete and misleading statements to plaintiff with the intent to defraud plaintiff. 13. Specifically, defendant stated that her personal property was stolen. 14. The items she claimed were stolen were in fact not stolen but rather, were taken by her son. Defendant further stated that she would repay plaintiff for the money that plaintiff issued to defendant as a result of the alleged theft and subsequent loss. 15. Defendant has refused to make this repayment. Defendant's actions are in violation of 18 Pa.C.S.A. 4117 and have caused plaintiff to suffer monetary damages. WHEREFORE, plaintiff respectfully requests that this Honorable Court enter judgment in its favor for $3,026.50 plus reasonable investigation expenses, costs of suit, and attorney's fees. COUNT II ERIE INSURANCE EXCHANGE v. NAN ITA BLACK BREACH OF CONTRACT 16. Plaintiff and defendant were involved in a contractual relationship at the time of the incident giving rise to this cause of action. 17. Defendant breached the expressed terms of this agreement. 18. Defendant breached the implied terms of this agreement. 19. Defendant was unjusdy enriched as a result of her failure to reimburse plaintiff for money it paid to her. WHEREFORE, plaintiff respectfully requests that this Honorable Court enter judgment in its favor in the amount of $3,026.50. COUNT III ERIE INSURANCE EXCHANGE v. NANITA BLACK FRAUDULENT MISREPRESENTATION 20. Defendant made misrepresentations to plaintiff, plaintiffs agents and to defendant's own attorney. 21. More specifically, defendant stated that she was the victim of theft and that she would repay plaintiff for reimbursement due to the alleged loss. 22. Plaintiff relied upon these fraudulent misrepresentations to its detriment. As a result of this reliance, plaintiff suffered damages. WHEREFORE, plaintiff respectfully requests that this Honorable Court enter judgment in its favor in the amount of $3,026.50. GOLDBERG, Ki\TZMAN &SHIPMAN,P.C. Benjamin D. Attorney ID PO Box 126 Harrisburg, P 717-234-4161 Attorneys for Plaintiff ....----- /' <:. // -7 By: Date: March 23, 2004 VERIFICATION I, Benjamin D. Andreozzi, hereby acknowledge that Erie Insurance Exchange is the Plaintiff in this action and that I am authorized to make this verification on its behalf; that I have read the foregoing Complaint, that the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa.e.S. ~ 4904, relating to unsworn falsification to authorities. By: GOLDBERG KATZMAN & SHIPMAN, P.e. >> L-?- Benjamin D. AndJe6zzi sqwre Attoreny~ ID. 9271 P.O. Box 1 8 Harrisbur , P 7108-1268 (717) 234- 61 Attorneys for Plaintiff Date: March 23, 2004 107689.1 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing Praecipe upon all parties or counsel of record by depositing a copy of same in the United States Mail at Harrisburg, Pennsylvania, with first-class postage, addressed to the following: Nanita Black 2260 Waggoner's Gap Road Mechanicsburg, P A 17055 GOLDBERG, KATZMAN & SHIPMAN, P.e. By ~~ Date: March 23, 2004 107689.1 <-' r~ 2::. J~- 'i, . ."',. SJ ~'.~ +- -l.' ~. );,. -<. N c) .'1"1 .-:-~ f\~! _...,j-;J '. -", c:c) . ~_ i:j C> ;' ~, U:Jclce I 100. ~Jf - 547 ci uJ fr/e Jnf,urmJ{;f fJtdw2q-e v. 77aJ'ut{ Black ?~(nbff Nanita Black 2260 Waggoners Gap Carlisle, PA 17013 March 12,2004 , oL?~I1C~i1 t .I1Yl0WfV I. Admitted. 2. Admitted 3. Admitted 4. Admitted 5. Admitted. Furthermore, defendant told the insurance company that she thought it was her husband 6. Admitted. 7. Admitted. 8. Admitted 9. Denied. Husband stole items. The son was a minor in husband's custody and mayor may not have been present. 10. Denied. Defendant never promised to pay money back. Defendant's attorney was incorrect. 11. Admitted. COUNT I - INSURANCE FRAUD 12. Denied. Defendant made no such false, incomplete or misleading statements and her intent was never to defraud. 13. Admitted. Furthermore, defendant told them ofhusband's suspected involvement. 14. Denied. Items were taken by husband, not the son, and defendant never promised to repay plaintiff. 15. Denied. It is denied that defendant has violated the law. Wherefore, defendant respectfully requests judgment in her favor. COUNT Il- BREACH OF CONTRACT 16. Admitted. 17. Denied that defendant breached the agreement. 18. Denied that the defendant breached the agreement. 19. Denied that defendant was unjustly enriched. Wherefore, defendant respectfully requests judgment in her favor. COUNT III - FRAUDULENT MISREPRESENTATION 20. Denied that the defendant made any misrepresentations to plaintiff, plaintiff's agents or to defendant's own attorney. 21. Denied. Defendant was victim of a theft and she never promised to repay plaintiff. 22. Denied that any misrepresentations were made by defendant or that plaintiff suffered any damages. Wherefore, defendant respectfully requests judgment in her favor. llcvllitLL Q. ~&1l1~ rlf;ulIJ. :)(01 C) ,..., 0 c::.:) C = .1 -."- -=- ~~ ...... -, -r" -0 mp :;0 -nf'11 ""6 N ,-, :'::J-1'i -0 ;,:.:.;. ::J ;~~,~?, W ,-' ~~ r- ::n co -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND coUNTY, PENNSYLVANIA ERIE INSURANCE EXCHANGE. Plaintiff NO. 547 CIVIL 2004 v. NANITA RLACK. Defend8nt RULE 1312.1. The Petition for Appointment of Arbitrators shall be substantially in the following fonn: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: llenjamin D. Andreozzi ' counsel for the plaintiffllJlJi'.."'..... in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is ( are) at issue. 2. The claim oflhe plaintiff In the action is $ 3.026.50 The counterclaim of the defendant in tile action is The following attorneys are interested in the case(S) as counselor are otherwise disqualified to sit as arbitrators: Ren;!l1IIin D. AndT'p.n'7.y.i. F..AoniT'p. WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. 1'.d(JV ,-t9 t:-, in c ESQUIRE foregoing petition, ~ Esq., and 'f:!(/JI"'J actions) as prayed for. Esq., , Esq., are appointed arbitrators i the above captioned action (or P.J. '/Ii\\'/fU\SNN:,id I '''n.~. ,'" " ""l .... '.' '.'-. ."'1....0 IUJ'Ji .I,.(.J ~" .:""":-{/\!f i ~2:1 ~Id 2-imr~aaz )"bVLOJ'\i'OHLOb'd 3141 :10 -"'I.Q{'1.f131H :JJ,..>_,vu .... f ~ (.) ~ 1 .Vl B ~ ...... ~ ~ ~ '" = 0 ",-" -,., r-- ~ -=- <- :;:! r-- ~ c:: {' "'Q <:.. Filfri - -om :00 " -r- 0' --<6 ~ 3! :;~7i' c~. -- <::> ,-- ':'? ~5rn '-- " ._,';-',. ~ -<:"'- ',' -., -< c..:i -,-, ~ ERIE INSURANCE EXCHANGE : IN THE COURT OF COMMON PLEAS OF CIVIL ACTION - LAW NO. 04-547 CIVIL TERM V. NANITA BLACK IN RE: ARBITRATION PANEL ORDER OF COURT AND NOW, June 29, 2004, the Court having been informed that Karen Koenigsberg, Esquire, is unavailable for the above-captioned arbitration hearing, Kara Haggerty, Esquire, is appointed in her stead. By the Court, P.J. Austin Grogan, Esquire Coyne and Coyne 3901 Market Street Camp Hill, PA 17011-4227 ~ bfJ (, . ,;)9- 0 'f Court Administrator s!.-- ^JJ~rlCi' -:;AJY) c; r, :('\ HI-l 67 ~,ltp,-' h,nnZ _ _ c... ,.,._, v \',_, ""',, & ;<'I!f I rJtJ . Co. Plaintiff In The Court of Common Pleas of Cumberland County, Pennsylvania No.o tl ~ s-z.t7 v~. N,4", ''-11 J2; ~ (..-1<"" . Defendant Civil Action - Law. Oath We do solenmly swear (or affum) that we will support. obey and dcfc:n.d the Constitution of the United States t!11d the Constitution of this Commonwealth and that we will discharge the duties of our office with fidelity. N~ S#-NJ SigDllture ~1{LtC I-hat!/di- . Signature [W ~ (f KIIM !lA.i(/~ Name A6DM.. ~ t4-fLUA~~1 uJ Law Finn 3~ 5. fhM~ ~ Adc;b;r:s$ AtfAev Kof/Aj J{Q1I1t4J'1 Name (Cbairman) Law FiIm j ~ D if ~IOO /) ,4,,<< Address .su , "'fC ~ OV - .. e~p Ii/I PA- Il:JII City, Zip ~Lll~ ~l'lol3 City, Zip Sipatu:re /}ujJ7d r Name CrJ'IA/~ f CC"/d? e.. Law,FJttn 3qCJ/.AI~4' ~ Addte.u CltzqfJ 11// OJ /71//1 City, ZiP' Award W c, the undersigned arbitrators, having been duly appointed and swom (or s.fiimJ.ed), make the following a.waId: ~te: If damages for de~ are a.VJaIded, they shall be separately stated.) f}v..;A{L1 ':J _ll~ft , SD.. fotL E".~"w :l:~U ~ CA;).- .. - .... !S. (Insert name if applicable.) . Date of Hearing: Jlll":~/-~c..f .. Date of Award: 11/ 2-),/.0'1. .' . ~~.~ ,~ ~c.: ,;)..3 ~ 1../1. di: c -0 Now, the . . day of /1t1tJ. } 20t?f . at ;;:/> I P.M., the above~d wir entered upon the docket and notice thereof given by mail to the parties or their attorneys. . . 2 ~ ~ U1 Notice of Entry of Award Amitrators' compensation to be paid upon appeal: $ . ~O - OL1 ~{ ad.:~~ proth.onota1jf o -(I -4 ::r.:....... ~r~~-' :.0 ~ 'j 0" -;",Q ~") 1" ':::::, ):;>- :::q ..J'~ By: ~~./ -~ .~-~h,~ t7 Deputy -- II-as.o!' ~ -t- &t.d d~ /1.;)3'~'I C~~ ;?"~ cv;?; ~- . . Thomas E. Brenner, Esquire Goldberg Katzman, P.c. PO Box 1268 Harrisburg, P A 17108-1268 717-234-4161 Attorneys for Plaintiff ERIE INSURANCE EXCHANGE, : IN THE COURT OF COMMON PLEAS ; CUMBERLAND COUN1Y, P A Plaintiff ; NO. 04.547 v. NANITA BLACK, : CIVIL ACTION. LAW Defendant PRAECIPE TO THE PROTHONOTARY; Please enter jud.l,>ment of record on the Award of Arbitrators entered on November 23,2004 against Defendant Nanita Black in the amount of$3,026.50. A copy of the Award is attached hereto as Exhibit "A". GOLDBERG KATZMAN, P.e. By G;;Je___ Thomas E. Brenner, Esquire Attorney ID #32085 PO Box 1268 Harrisburg, PA 17108.1268 717.234-4161 Attorneys for Plaintiff Date: May 13,2005 122034.1 . , rtl?/rf oJ". Co- Plaintiff In The Court of Common Pleas of Cumberland 0'15'1-7' COll.llty, Pennsylvania No ~ Oath We do solem.oly swear (or affinn) thll! we will support, obey and defemd the Constitution of the United States !Old the Constitution of this Connnonwealth and that we will discharge the duties of Out office with fidelity. Nil S #-Iv.! Vj, N/lfI/ /..,-,4 P;L.t~ <--K_ Der-Jonl Civil Action - Law. / . , ~lalO Hflfai f . Signature . /' i 0 K.RI'2A NtUje.t/:f'1Q1./ Name c . , A&DK. ~ KU-rLUA/!./J;./ uJ LawFi:Jm 3(.-, S. Ihll1Cl~ 5;r. AOdr..s Sign.we "'1 Aey Kef/IV J{,;;l'ItldJ'1 N=e (c:hainnon.) Law Film j /9..'" ~L10 fJ Ave" Addr... Se ,'tC; I'e,/ ei40~;:? /.1 // P4 ("vi f City, Zip ~iJ {cl I?.tnc 13 City, Zip C.O,/Nt;<I c.(')L/;#? C Law.Finn ' ,.5qi?/ /1.{#fL,f4" 4-.- AdOt.... C#t'rt' #// J.lIr7tJ/! City, :np Anrd We, the undersigned arbitrators, hs.ving been duly a:ppointed and swam (or s.ffirmed), make the following award: , ~te: If damages for de~ are a'WaId';i they shall be separately stated.) /lvJA<L1J ~,^.:lt" , SO h> (l... t::"f4 w '1jj L C-b;. - sco.ts. (Insert name if applicable.) Date of Hearing: Illv~1 oLf I Date of Award: 11/ 1--J.! o'-{ ( - zr;: N "!J~..;-' .W r:'-" r~~: .....3,.1 ~/1 . . L> ~~. -.:; Now,the 0' day of dtft). ,200,,',at J.f.i<;, ,~,M.,theabove@~dw[f entered upon the docket and notice thereof given by mail to the parties or their attorneYt'o . -- ~ '::: ::;: U1 o -r\ .... ~"'~p2 ::r:J o :l ... o':U --r(.) ;s:=-)(-n ~I ;;g. ", Notice of Ell try of Award Arbitrators' compensation to be paid upon appeal: $ ~a. Cd .;sf ~. /)0h;- , prothon.ctaI)' By: ~- . ...~" "_~4/f::';J / to' ,k"- /'Y?L& j9~ Deputy ~ ~ ~ EXHIBIT A . , ~:ERTIFICATE OF SERVICE I HEREBY CERTII'Y that I served a true and correct copy of the foregoing document upon all parties or counsel of record by depositing a copy of same in the United States Mail at Harrisburg, Pennsylvania, with first-class postage prepaid, addressed to the following: Nanita Black 2260 Waggoner's Gap Road Carlisle, P Anon GOLDBERG KATZMAN, P.e. -'" By: (/ ~JZ~ Thomas E. Brenner, Esquire Date: May 13, 2005 122034.1 ~ () -D c~'i~ ~-~-cJ ~ ~ f r ~ U{ CY 12- ~ r ~ r---- :l C) r:..::> ~ '(;-) . ,;,,", #2.-;\ 'f~. /\~:~2(, ~ ,~? "'. t.~ ' . .. "' ... Thomas E. Brenner, Esquire Goldberg Katzman, P.e. PO Box 1268 Harrisburg, PA 17108-1268 717-234-4161 Attorneys for Plaintiff ERIE INSURANCE EXCHANGE, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA Plaintiff : NO. 04-547 v. NANIT A BLACK, : CIVIL ACTION - LAW Defendant RULE 236 NOTICE This 12-~ay of fYl ';J i ,2005, Judgment has been entered against Nanita Black. Prothonotary Thomas E. Brenner, Esquire Goldberg Katzman, r.c. PO Box 1268 Harrisburg, PA 17108-1268 717-234-4161 Attorneys for Plaintiff ERIE INSURANCE EXCHANGE, : IN THE COURT OF CO.i\lMON PLEAS : CUiVfBERLAND COUNTY, PA Plaintiff : NO. 04-547 v. NANITA BLACK, : CIVIL A.CTION - LA \Xi Defendant PRAECIPE TO THE PROTHONOTARY: Please mark this judgment satisfied and the docket closed. GOLDBERG I<-ATZMAN, P.c. Date: December 4, 2006 ) -+2039.1 By: ~~_ Thomas E. Brenner, Esquire ,-\ ttorney ID #32085 PO Box 1268 Harrisburg, PA 17108-1268 717-234-4161 Attorneys for Plaintiff CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all parties or counsel of record by depositing a copy of same in the United States ~1ail at Harrisburg, Pennsylvania, with first-class postage prepaid, addressed to the following: N anita Black 2260 Waggoner's Gap Road Carlisle, PA 17013 GOLDBERG I.c:\TZ~1AN, P.e. 2;i~ By: Thomas E. Brenner, Esquire Date: December 4, 2006 142039.1 (") ~ ("'0" 0:;~ ; ~~.~ ..-.-' --< ,...", = c.::> C'" o II :2 m~ -ry ;T1 ;:!2q ~:~() r- ~ '!", ;.c;~ f~; ~fTl ::~'I ?is .< o ri"1 c-.> I U1 -0 :J:": N r \D