Loading...
HomeMy WebLinkAbout08-2854 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL Civil Division AUTOMOBILE INSURANCE COMPANY, No. OS +.28s?I ?? u t Plaintiff, COMPLAINT IN CIVIL ACTION V. IRDIZ HRNJIC and RAMIZA HRNJIC, Defendants. (Jury Trial Demanded) Filed on behalf of: State Farm Mutual Automobile Insurance Company, Plaintiff. Counsel of Record for this Party: Stephen J. Summers, Esquire Pa. I.D. #40213 Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, MCDONNELL, HUDOCK GUTHRIE & SKEEL, L.L.P. Firm # 911 2400 Gulf Tower 707 Grant Street Pittsburgh, PA 15219 (412) 261-3232 #16212 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Plaintiff, V. IRDIZ HRNJIC and RAMIZA HRNJIC, Defendants. Civil Division No. 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 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 COURT ADMINISTRATOR 4T" FLOOR, CUMBERLAND COUNTY COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PA 17013 (717) 240-6200 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Plaintiff, V. IRDIZ HRNJIC and RAMIZA HRNJIC, Defendants. Civil Division No. 1-9 Q - -? S,3-T al-4 7-ct,,_ COMPLAINT IN CIVIL ACTION AND NOW, comes the Plaintiff, State Farm Mutual Automobile Insurance Company, by and through its attorneys, Summers, McDonnell, Hudock, Guthrie & Skeel, L.L.P., and Stephen J. Summers, Esquire, and Kevin D. Rauch, Esquire, and files the following Complaint in Civil Action, and in support thereof avers as follows: 1. Plaintiff, State Farm Mutual Automobile Insurance Company (hereinafter "State Farm"), is an Illinois mutual company with a principal place of business in Bloomington, Illinois. Plaintiff is licensed to transact insurance business in the Commonwealth of Pennsylvania. 2. Defendants, Irdiz and Ramiza Hrnjic are adult individuals who reside at 6 Kingsbridge Circle, Carlisle, Pennsylvania 17013. 3. At all times relevant hereto, Defendants insured a 2002 Mercedes Benz ML500 under a policy of insurance issued by Plaintiff which provided collision coverage. 4. On May 3, 2006, the Defendants' vehicle was damaged. 5. Defendants subsequently made a claim to Plaintiff for the property damage and were issued two checks by State Farm totaling $2,746.63. 6. In the spring of 2007, the Defendants' vehicle was repossessed by Citadel Federal Credit Union. It was at this point that Plaintiff learned that the repairs for which Defendants received payment were never made. 7. Citadel Federal Credit Union sought the difference between the remaining loan amount and the actual cash value of the vehicle at the time of its repossession. Thus, Plaintiff made a second payment in the amount of $2,746.63, despite having issued a payment in this amount previously. 8. As Plaintiff made a double payment on the same vehicle, Defendants have been unjustly enriched. WHEREFORE, Plaintiff, State Farm Mutual Automobile Insurance Company seeks judgment in its favor and against Defendants in the amount of $2,746.63 plus attorney's fees, interest and costs. Respectfully submitted, SUMMERS, MCDONNELL, HUDOCK, GUTHP)E & SKEEL,?,.L.P. BY: 'St phen J. ummers, Esquire K vin D. R uch, Esquire A orneys for Plaintiff, State Farm Mutual Automobile Insurance Co. VERIFIED STATEMENT I, Kevin D. Rauch, Esquire, being the attorney for the Plaintiff, Kevin D. Rauch, Esquire, in the within action, am duly authorized to make this Verified Statement on the Plaintiffs behalf. I hereby verify that the statements set forth in the foregoing COMPLAINT IN CIVIL ACTION are true and correct to the best of my information and belief based upon knowledge obtained from the Plaintiff. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsifications to authorities. D. Raucq, Esquire el for Plaintiff Dated: ?? ccy d Cl) P- ' f N ?,^ CASE NO: 2008-02854 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STATE FARM MUTUTAL AUTO INS CO VS HRNJIC IRDIZ ET AL BRIAN BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according says, the within COMPLAINT & NOTICE to law, was served upon HRNJIC IRDIZ DEFENDANT the at 2058:00 HOURS, on the 12th day of May at 6 KINGSBRIDGE CIRCLE 2008 CARLISLE, PA 17013 RAMIZA HRNJIC by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents Additional Comments thereof. 'T'RANSLATED BY ALDIN BAJRIC Sheriff's Costs: Docketing Service 18.00 Postage 5.00 Surcharge 5 10.00 0 -1 `55-p ?/ . 00 33 . 5 9 Sworn and Subscibed to before me this day of So Answers: t R. Thomas Kline 05/13/2008 SUMMERS MCDONNELL HUDOCK By: ? Deputy Sheriff A.D. .r SHERIFF'S RETURN - REGULAR CASE NO: 2008-02854 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STATE FARM MUTUTAL AUTO INS CO VS HRNJIC IRDIZ ET AL BRIAN BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according says, the within COMPLAINT & NOTICE to law, was served upon HRNJIC RAMIZA the DEFENDANT at 2058:00 HOURS, on the 12th day of May at 6 KINGSBRIDGE CIRCLE 2008 CARLISLE, PA 17013 by handing to RAMIZA HRNJIC a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Comments TRANSLATED BY ALDIN BAJRIC Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 00 J 1 0 So Answers: Sworn and Subscibed to before me this day of R. Thomas Kline 05/13/2008 SUMMERS MCDONNELL HUDOCK By: Deputy Sheriff A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL Civil Division AUTOMOBILE INSURANCE COMPANY, No. 08-2854 Plaintiff, PRAECIPE FOR DEFAULT V. JUDGMENT AGAINST DEFENDANT RAMIZA HARNJIC IRDIZ HARNJIC and RAMIZA HARNJIC, Defendants. (Jury Trial Demanded) Filed on behalf of: State Farm Mutual Automobile Insurance Company, Plaintiff. Counsel of Record for this Party: Stephen J. Summers, Esquire Pa. I.D. #40213 SUMMERS, MCDONNELL, HUDOCK GUTHRIE & SKEEL, L.L.P. Firm # 911 2400 Gulf Tower 707 Grant Street Pittsburgh, PA 15219 (412) 261-3232 #16212 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE COMPANY, Plaintiff, V. IRDIZ HARNJIC and RAMIZA HARNJIC, Defendants. Civil Division No. 08-2854 PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: MICHAEL LAMB, PROTHONOTARY Kindly enter a Default Judgment against Defendant, Ramiza Harnjic, and in favor of the Plaintiff in the amount of $2,746.63 plus attorney's fees, interest and costs in the above captioned matter. Attached hereto is a copy of the 10-Day Important Notice that was served upon the Defendant by U.S. Mail on June 4, 2008. Respectfully submitted, SUMMERS, MCDONNELL, HUDOCK, GUTHRIE & SKEEL, L.L.P. BY: ?- ? Stephe J. Summ squire Attorneys for Plai iff, State Farm Mutual Automobile Ins. Co. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Plaintiff, V. IRDIZ HARNJIC and RAMIZA HARNJIC, Defendants. 00,1'6212 Civil Division No. 08-2854 TEN DAY NOTICE TO DEFENDANT RAMIZA HARNJIC (Jury Trial Demanded) Filed on behalf of: State Farm Mutual Automobile Insurance Company, Plaintiff. Counsel of Record for this Party: Stephen J. Summers, Esquire Pa. I.D. #40213 SUMMERS, MCDONNELL, HUDOCK GUTHRIE & SKEEL, L.L.P. Firm # 911 2400 Gulf Tower 707 Grant Street Pittsburgh, PA 15219 (412) 261-3232 } IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE COMPANY, Plaintiff, V. IRDIZ HARNJIC and RAMIZA HARNJIC, Defendants. TO: Ramiza Harnjic 6 Kingsbridge Circle Carlisle, PA 17013 DATE OF NOTICE: June 4, 2008 Civil Division No. 08-2854 IMPORTANT NOTICE YOU ARE IN DEFAULT because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this paper to your lawyer at once. If you do not have a lawyer, go to or telephone the office set forth below. This office an 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 reduced fee or no fee. CUMBERLAND COUNTY COURT ADMINISTRATOR 4T" FLOOR, CUMBERLAND COUNTY COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PA 17013 (717) 240-6200 SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, L.L.P. BY: Stephen J. Summers, Esquire Attorneys for Plaintiff, State Farm Mutual Automobile Insurance Company. CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the within TEN DAY NOTICE, was served upon Defendant by mailing the same via first class mail, postage pre-paid, this 4"' day of June, 2008, addressed as follows: Ramiza Harnjic 6 Kingsbridge Circle Carlisle, PA 17013 SUMMERS, MCDONNELL, HUDOCK, GUTHRIE & SKEEL, L.L.P. k BY: ephen J. Summers, Esquire Attorneys for Plaintiff, State Farm Mutual Automobile Insurance Co. 6?- CD == rri ` r Rs , i , i4 11 1+! P-a C .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE COMPANY, Plaintiff, V. IRDIZ HARNJIC and RAMIZA HARNJIC, Defendants. Civil Division No. 08-2854 NOTICE OF ORDER. DECREE OR JUDGMENT TO: ( ) Plaintiff (XX) Defendant ( )Garnishee ( )Additional Defendant You are hereby notified that the following Order, Decree or Judgment has been entered against you on -T o8 () Decree Nisi in Equity. () Final Decree in Equity. (XX) Judgment of ( ) Confession () Verdict () Court Order (XX) Default () Non-Suit ( ) Non-Pros () Arbitration Award (XX) Judgment in the amount of $ plus costs. () District Justice Transcript of Judgment in the amount of $ plus costs. (XX) If not satisfied within sixty (60) days, your motor vehicle operator's license will be suspended by the Pennsylva ' ep Transportation. RO O ARY By. Deputy If you have any questions concerning the above, please contact: Name of (Attorney/Filing Party) Erin M. Braun, Esquire Address The Gulf Tower, Suite 2400, 707 Grant St. Pittsburgh, PA 15219 Telephone Number (412) 261-3232 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL Civil Division AUTOMOBILE INSURANCE COMPANY, No. 08-2854 Plaintiff, PRAECIPE FOR DEFAULT V. JUDGMENT AGAINST DEFENDANT IRDIZ HARNJIC IRDIZ HARNJIC and RAMIZA HARNJIC, Defendants. (Jury Trial Demanded) Filed on behalf of: State Farm Mutual Automobile Insurance Company, Plaintiff. Counsel of Record for this Party: Stephen J. Summers, Esquire Pa. I.D. #40213 SUMMERS, MCDONNELL, HUDOCK GUTHRIE & SKEEL, L.L.P. Firm # 911 2400 Gulf Tower 707 Grant Street Pittsburgh, PA 15219 (412) 261-3232 #16212 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE COMPANY, Plaintiff, V. IRDIZ HARNJIC and RAMIZA HARNJIC, Defendants. Civil Division No. 08-2854 PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: MICHAEL LAMB, PROTHONOTARY Kindly enter a Default Judgment against Defendant, Irdiz Hamjic, and in favor of the Plaintiff in the amount of $2,746.63 plus attorney's fees, interest and costs in the above captioned matter. Attached hereto is a copy of the 10-Day Important Notice that was served upon the Defendant by U.S. Mail on June 4, 2008. Respectfully submitted, SUMMERS, MCDONNELL, HUDOCK, GUTHRIE & SKEEL, L.L.P. BY: Stephen J. Sumord, Esquire Attorneys for PI intiff, State Farm Mutual Automobile Ins. Co. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Plaintiff, V. IRDIZ HARNJIC and RAMIZA HARNJIC, Defendants. #16212 Civil Division No. 08-2854 TEN DAY NOTICE TO DEFENDANT IRDIZ HARNJIC (Jury Trial Demanded) Filed on behalf of: State Farm Mutual Automobile Insurance Company, Plaintiff. Counsel of Record for this Party: Stephen J. Summers, Esquire Pa. I.D. #40213 SUMMERS, MCDONNELL, HUDOCK GUTHRIE & SKEEL, L.L.P. Firm # 911 2400 Gulf Tower 707 Grant Street Pittsburgh, PA 15219 (412) 261-3232 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE) Civil Division COMPANY, ) Plaintiff, V. IRDIZ HARNJIC and RAMIZA HARNJIC, Defendants. TO: Irdiz Hamjic 6 Kingsbridge Circle Carlisle, PA 17013 DATE OF NOTICE: June 3, 2008 No. 08-2854 IMPORTANT NOTICE YOU ARE IN DEFAULT because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this paper to your lawyer at once. If you do not have a lawyer, go to or telephone the office set forth below. This office an 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 reduced fee or no fee. CUMBERLAND COUNTY COURT ADMINISTRATOR 4T" FLOOR, CUMBERLAND COUNTY COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PA 17013 (717) 240-6200 SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, L.L.P BY: Stephen J. Summers, Esquire Attorneys for Plaintiff, State Farm Mutual Automobile Insurance Company. CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the within TEN DAY NOTICE, was served upon Defendant by mailing the same via first class mail, postage pre-paid, this 4t' day of June, 2008, addressed as follows: Irdiz Harnjic 6 Kingsbridge Circle Carlisle, PA 17013 SUMMERS, MCDONNELL, HUDOCK, GUTHRIE & SKEEL, L.L.P. BY: i7 Stephen J. Summers, Esquire Attorneys for Plaintiff, State Farm Mutual Automobile Insurance Co. o O (7 OO t t G ? T^e C.0 :.L3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE COMPANY, Civil Division Plaintiff, V. No. 08-2854 IRDIZ HARNJIC and RAMIZA HARNJIC, Defendants. NOTICE OF ORDER, DECREE OR JUDGMENT TO: ( ) Plaintiff (XX) Defendant ( )Garnishee ( )Additional Defendant You are hereby notified that the following Order, Decree or Judgment has been entered against you on 61/1,7110, () Decree Nisi in Equity. () Final Decree in Equity. (XX) Judgment of ( ) Confession () Verdict () Court Order (XX) Default () Non-Suit ( ) Non-Pros () Arbitration Award (XX) Judgment in the amount of $ oo? 746, L3 , plus costs. () District Justice Transcript of Judgment in the amount of $ plus costs. (XX) If not satisfied within sixty (60) days, your motor vehi le operator's license will be suspended by the Pennsylva ' De Transportation. O By. Deputy If you have any questions concerning the above, please contact: Name of (Attorney/Filing Party) Erin M. Braun, Esquire Address The Gulf Tower, Suite 2400, 707 Grant St. Pittsburgh, PA 15219 Telephone Number (412) 261-3232 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL Civil Division AUTOMOBILE INSURANCE COMPANY, No. 08-2854 Plaintiff, V. PRAECIPE TO SATISFY JUDGMENT AND SETTLE AND DISCONTINUE IKDIZ HARNJIC and RAMIZA HARNJIC, Defendants. (Jury Trial Demanded) Filed on behalf of: State Farm Mutual Automobile Insurance Company, Plaintiff. Counsel of Record for this Party: Stephen J. Summers, Esquire Pa. I.D. #40213 SUMMERS, MCDONNELL, HUDOCK GUTHRIE & SKEEL, L.L.P. Firm # 911 2400 Gulf Tower 707 Grant Street Pittsburgh, PA 15219 (412) 261-3232 #16212 I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE COMPANY, Plaintiff, V. IRDIZ HARNJIC and RAMIZA HARNJIC. Defendants. Civil Division No. 08-2854 PRAECIPE TO SATISFY JUDGMENT AND SETTLE AND DISCONTINUE TO: Prothonotary: Kindly mark the judgment in the above captioned case SATISFIED and mark the docket "Settled and Discontinued." Respectfully submitted, SUMMERS, MCDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. BY: Erin M. Braun, Esquire Attorneys for Plaintiff, State Farm Mutual Automobile Company. MD-t ?i JCE OF THE PROTHONOTARY 2009 SEP -8 PM 3' 00 f a =JUUs?ST PENNSYLVANIA.