HomeMy WebLinkAbout08-6767
ROBERT D. KODAK, ESQUIRE
KODAK & IMBLUM, P.C.
407 N FRONT STREET, PO BOX 11848
HARRISBURG, PA 17108-1848
(717) 238-7159 Attorney for Plaintiff
SELECTIVE INSURANCE COMPANY
OF AMERICA
Plaintiff
v
IN THE COURT OF COMMON PLEAS OF
Cumberland COUNTY, PENNSYLVANIA
NO. ?S -?'IG7 •v? lF1L
RICHARD L. BARR and ANN D. BARR CIVIL ACTION - LAW
each individually and trading as RLB
Services
Defendant(s)
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim set
forth in the following pages, you must take action within twenty (20) days after this
complaint and notice are served, by entering a written appearance personally or by an
attorney and filing in writing with the court your defenses or objections to the claims set
forth against you. You are warned that if you fail to do so the 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, 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 REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
717-249-3166
AVISO
USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las
demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion
dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y
Aviso radicando personalmente o por medio de un abogado una comparencencia escrita
y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas
presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion
como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier
suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio
solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso
adicional. Usted puede perder dinero o propiedad u otros derechos importantes para
usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO
INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA
SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA
DE COMO CONSEGUIR UN ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES
POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE
AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A
PERSONAS QUE CUALIFICAN.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
717-249-3166
SELECTIVE INSURANCE COMPANY IN THE COURT OF COMMON PLEAS OF
OF AMERICA Cumberland COUNTY, PENNSYLVANIA
Plaintiff
NO. O ?• G 7 L l.(?•
v
RICHARD L. BARR and ANN D. BARR CIVIL ACTION - LAW
each individually and trading as RLB
Services
Defendant(s)
COMPLAINT
The Plaintiff, SELECTIVE INSURANCE COMPANY OF AMERICA, by its attorneys,
KODAK & IMBLUM, P.C., brings this action of Assumpsit against the Defendants to
recover the sum of SIX THOUSAND TWO HUNDRED EIGHTY-TWO DOLLARS
($6,282.00), along with interest thereon at the statutory rate from April 3, 2008, upon a
cause of action of which the following is a statement:
1. The Plaintiff, SELECTIVE INSURANCE COMPANY OF AMERICA, is a corporation
organized and existing under the laws of the State of New Jersey, having a principal
office and place of business at 40 Wantage Avenue, Brachville, NJ 07890.
2. The Defendant, RICHARD L. BARR, individually and trading as RLB Services, a
sole proprietorship, is an adult individual residing at 6996 Wertzville Road,
Mechanicsburg, Cumberland County, Pennsylvania 17050-1540.
3. The Defendant, ANN D. BARR, individually and trading as RLB Services, a sole
F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\SELECTIVE INS 34681.wpd 2
proprietorship, is an adult individual residing at 6996 Wertzville Road,
Mechanicsburg, Cumberland County, Pennsylvania 17050-1540.
4. An application for insurance was submitted by Defendants' agent, on behalf of
Defendants, to Plaintiff thereby creating the Contract in question.
COUNT I - POLICY #S1577408 EFFECTIVE 02/12/06 - SICSC
5. Plaintiff incorporates by reference the averments of Paragraphs 1 through 4 above
the same as if fully set forth at length herein.
6. Plaintiff, at Defendants' request, did provide Commercial Package insurance for the
benefit of Defendants for the period February 12, 2006 through February 12, 2007
for the total amount of Five Thousand Nine Hundred Seventy-Nine Dollars
($5,979.00). A true and correct copy of the Policy Declaration Page is attached
hereto, marked Exhibit "A" and made a part hereof.
7. The prices charged for said insurance coverage provided was just and reasonable,
was the legal and market prices therefor, and was the price which the Defendants
promised and agreed to pay Plaintiff.
8. Said policy was cancelled on or about March 13, 2008 at 12:01 a.m.
F:\USER\ROBIN\CCP&D] CMPS\CCP COMPLAINTS\SELECTIVE INS 34681.wpd 3
9. The total policy premium was Nine Thousand One Hundred Seven Dollars
($9,107.00) against which Defendants paid and/or received credits in the amount
of Six Thousand Six Hundred Sixty Dollars ($6,660.00), thereby leaving a balance
due and owing by Defendants to Plaintiff in the amount of Two Thousand Four
Hundred Forty-Seven Dollars ($2,447.00), as appears by Plaintiffs Billing Inquiry
statement attached hereto, marked as Exhibit "B" and made a part hereof.
10. The balance due and owing by Defendants to Plaintiff is the sum of Two Thousand
Four Hundred Forty-Seven Dollars ($2,447.00) as appears by Plaintiffs March 13,
2008 Statement of Account, a true and correct copy of which is attached hereto,
marked Exhibit "C" and made'a part hereof.
11. Plaintiffs complete policies and audits are not attached to this pleading due to the
voluminous nature of same and have previously been provided to Defendants.
12. Plaintiff frequently demanded payment from Defendants of said amount due and
owing as aforesaid, but Defendants refused and neglected and still refuse and
neglect to pay said amount or any part thereof.
WHEREFORE, Plaintiff brings this suit to recover from Defendants the sum of TWO
THOUSAND FOUR HUNDRED FORTY-SEVEN DOLLARS ($2,447.00), together with
interest as set forth herein.
F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\SELECTIVE INS 34681.wpd 4
COUNT II - POLICY #S1577408 - EFFECTIVE 02/12/07 - SICSC
13. Plaintiff incorporates by reference the averments of Paragraphs 1 through 12 above
the same as if fully set forth at length herein.
14. Plaintiff, at Defendants' request, did provide commercial package insurance for the
benefit of Defendants for the period February 12, 2007 through February 12, 2008
for the total amount of Seven Thousand Four Hundred Sixty-Two Dollars
($7,462.00). A true and correct copy of the Policy Declaration Page is attached
hereto, marked Exhibit "D" and made a part hereof.
15. The prices charged for said insurance coverage provided was just and reasonable,
was the legal and market prices therefor, and was the price which the Defendants
promised and agreed to pay Plaintiff.
16. Said policy was cancelled on or about March 13, 2008 at 12:01 a.m.
17. The total policy premium was Twelve Thousand Sixty-One Dollars ($12,061.00)
against which Defendants paid and/or received credits in the amount of Nine
Thousand Eight Hundred Fifty-Seven Dollars ($9,857.00),thereby leaving a balance
due and owing by Defendants to Plaintiff in the amount of Two Thousand Two
Hundred Four Dollars ($2,204.00), as appears by Plaintiffs Billing Inquiry statement
attached hereto, marked as Exhibit "E" and made a part hereof.
F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\SELECfIVE INS 34681.wpd 5
18. The balance due and owing by Defendants to Plaintiff is the sum of Two Thousand
Two Hundred Four Dollars ($2,204.00) as appears by Plaintiffs March 13, 2008
Statement of Account, a true and correct copy of which is attached hereto, marked
Exhibit "C" and made a part hereof.
19. Plaintiffs complete policies and audits are not attached to this pleading due to the
voluminous nature of same and have previously been provided to Defendants.
20. Plaintiff frequently demanded payment from Defendants of said amount due and
owing as aforesaid, but Defendants refused and neglected and still refuse and
neglect to pay said amount or any part thereof.
WHEREFORE, Plaintiff brings this suitto recoverfrom Defendants the sum of TWO
THOUSAND TWO HUNDRED FOUR DOLLARS ($2,204.00), togetherwith interest as set
forth herein.
COUNT III - POLICY #WC 7246916 - EFFECTIVE 02/12/06 - SICA
21. Plaintiff incorporates by reference the averments of Paragraphs 1 through 20 above
the same as if fully set forth at length herein.
22. Plaintiff, at Defendants' request, did provide workers Compensation insurance for
F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\SELECTIVE INS 34681.wpd , 6
the benefit of Defendants for the period February 12, 2006 through February 12,
2007 for the total amount of Four Thousand Two Hundred Forty-Seven Dollars
($4,247.00). A true and correct copy of the Policy Information Pages are attached
hereto, collectively marked Exhibit "F" and made a part hereof.
23. The prices charged for said insurance coverage provided was just and reasonable,
was the legal and market prices therefor, and was the price which the Defendants
promised and agreed to pay Plaintiff.
24. Said policy was cancelled on or about March 13, 2008 at 12:01 a.m.
25. The total policy premium was Five Thousand Seventy-Two Dollars ($5,072.00)
against which Defendants paid and/or received credits in the amount of Four
Thousand Two Hundred Thirty-Eight Dollars ($4,238.00), thereby leaving a balance
due and owing by Defendants to Plaintiff in the amount of Eight Hundred Thirty-Four
Dollars ($834.00) as appears by Plaintiffs Billing Inquiry statement attached hereto,
marked as Exhibit "G" and made a part hereof.
26. The balance due and owing by Defendants to Plaintiff is the sum of Eight Hundred
Thirty-Four Dollars ($834.00) as appears by Plaintiff's March 13, 2008 Statement
of Account, a true and correct copy of which is attached hereto, marked Exhibit "C"
and made a part hereof.
F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\SELECTIVE INS 34681.wpd
27. Plaintiffs complete policies and audits are not attached to this pleading due to the
voluminous nature of same and have previously been provided to Defendants.
28. Plaintiff frequently demanded payment from Defendants of said amount due and
owing as aforesaid, but Defendants refused and neglected and still refuse and
neglect to pay said amount or any part thereof.
WHEREFORE, Plaintiff brings this suit to recover from Defendants the sum of
EIGHT HUNDRED THIRTY-FOUR DOLLARS ($834.00), togetherwith interest as setforth
herein.
COUNT IV - POLICY #WC 7246916 - EFFECTIVE 02/12/07 - SICA
29. Plaintiff incorporates by reference the averments of Paragraphs 1 through 28 above
the same as if fully set forth at length herein.
30. Plaintiff, at Defendants' request, did provide workers Compensation insurance for
the benefit of Defendants for the period February 12, 2007 through February 12,
2008 for the total amount of Four Thousand Eighty-Eight Dollars ($4,088.00). A
true and correct copy of the Policy Information Page is attached hereto, marked
Exhibit "H" and made a part hereof.
31. The prices charged for said insurance coverage provided was just and reasonable,
F:\USER\ROBIN\CCP&D] CMPS\CCP COMPLAINTS\SELECTIVE INS 34681.wpd 8
was the legal and market prices therefor, and was the price which the Defendants
promised and agreed to pay Plaintiff.
32. Said policy was cancelled on or about March 13, 2008 at 12:01 a.m.
33. The total policy premium was Four Thousand Eight Hundred Seventy-Nine Dollars
($4,879.00) against which Defendants paid and/or received credits in the amount
of Four Thousand Eighty-Eight Dollars ($4,088.00), thereby leaving a balance due
and owing by Defendants to Plaintiff in the amount of Seven Hundred Ninety-One
Dollars ($791.00) as appears by Plaintiffs Billing Inquiry statement attached hereto,
marked as Exhibit "I" and made a part hereof.
34. The balance due and owing by Defendants to Plaintiff is the sum of Seven Hundred
Ninety-One Dollars ($791.00) as appears by Plaintiffs March 13, 2008 Statement
of Account, a true and correct copy of which is attached hereto, marked Exhibit "C"
and made a part hereof.
35. Plaintiffs complete policies and audits are not attached to this pleading due to the
voluminous nature of same and have previously been provided to Defendants.
36. Plaintiff frequently demanded payment from Defendants of said amount due and
owing as aforesaid, but Defendants refused and neglected and still refuse and
neglect to pay said amount or any part thereof.
F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\SELECTIVE INS 34681.wpd 9
WHEREFORE, Plaintiff brings this suit to recover from Defendants the sums:
A. Count I: Two Thousand Four Hundred Forty-Seven Dollars ($2,447.00); and
B. Count II: Two Thousand Two Hundred Four Dollars ($2,204.00); and
C. Count III: Eight Hundred Thirty-Four Dollars ($834.00); and
D. Count IV: Seven Hundred Ninety-One Dollars ($791.00); and
For a total balance due and owing to Plaintiff by Defendants in the amount of SIX
THOUSAND TWO HUNDRED EIGHTY-TWO DOLLARS ($6,282.00) plus interest as set
forth herein.
Respectfully submitted,
KODAK & IMBLUM, P.C.
Robert D. Kodak, squire
407 North Front Street
Post Office Box #11848
Harrisburg, PA 17108-1848
(717) 238-7159
Attorney ID No. 18041
Attorney for Plaintiff
F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\SELECTIVE INS 34681,wpd 10
Issued by The Stock Insurance Company Policy Number
LS 1577408
SELECTIVE INSURANCE COMPANY OF SOUTH CAROLINA
3420 TORINGDON WAY, CHARLOTTE, NC 28277
l:V1V11V1L' KIaAL YOLICY COMMON DECLAR ATION
Named Insured and Address Policy Period
RICHARD BARR AND ANN BARR From: FEBRUARY 12, 2006
6996 WERTZVILLE RD
MECHANICSBURG, PA 17050-1540 To: FEBRUARY 12, 2007
12:01 A.M Standard Time At
Location of Designated Premises.
Named Insured is: Producer Number:
INDIVIDUAL 00-02963-00000
Producer:
KNOLL INSURANCE AGENCY INC
PENNSYLVANIA
Schedule of Coverage
COMMERCIAL PROPERTY COVERAGE
COMMERCIAL GENERAL LIABILITY COVERAGE
COMMERCIAL AUTOMOBILE COVERAGE
COMMERCIAL INLAND MARINE COVERAGE
REFER TO THE ATTACHED IMPORTANT NOTICE CA7048 FOR
INFORMATION REGARDING COLLISION COVERAGE ON RENTAL VEHICLEk'
PREMIUM INCLUDES TERRORISM COVERAGE $123.00
In return for payment of the premium, and subject to all the terms of this policy, we agree with
you to provide the insurance indicated in the schedule above. Insurance is provided only for
those coverages for which a specific limit is shown on the attached coverage declaration(s).
PAYMENT METHOD Total Policy Premium $5,979.00
D/B - 10 (This premium may be subject to adjustment.)
Date Issued: FEBRUARY 27, 2006
Issuing Office: PENNSYLVANIA REGION
Authorized Representative
EXHIBIT "A"
Policy Number
S 1577408
SCHEDULE OF LOCATIONS
Policy Effective Date: FEBRUARY 12, 2006 Schedule Effective Date: FEBRUARY 12, 2006
No. Location
1 6996 WERTZVILLE RD
MECHANICSBURG, PA 17050
Bldg.
No. Occupancy
1 STORAGE
IL-7036 (01/93)
INSURED'S COPY
SELECTME
Policy Summary
Insured Name: RICHARD BARR AND ANN BARR RLB SERVICES D/B/A
Address: 6996 WERTZVILLE RD
MECHANICSBURG PA 17050-1540
Policy #: S 1577408
Status: LEGAL
Total Premium
Premium 9,107.00
- Paid 6,660.00
Remaining Balance 2,447.00
Effective Date: 02/12/2006
Pay Plan: 10 Pay
Policy is in external collections as of 04/28/2008
Type Transaction Transaction Process
Eff Date Amount Date
NEW POLICY PREMIUM 02/12/2006 5,979.00 02/27/2006
ENDORSEMENT 05/17/2006 382.00 05/17/2006
ENDORSEMENT 06/23/2006 22.00 06/30/2006
ENDORSEMENT 08/15/2006 74.00 09/06/2006
ENDORSEMENT 09/25/2006 223.00 09/26/2006
ENDORSEMENT 02/12/2006 229.00 01/29/2007
ENDORSEMENT 02/12/2006 -249.00 01/30/2007
AUDIT 02/12/2006 2,447.00 02/07/2008
9,107.00
EXHIBIT "B"
KNOLL INSURANCE AGENCY INC
704 BRIDGE ST
NEW CUMBERLAND, PA 17070-1623
Phone No. 717-774-8128
March 13, 2008
S EL ECT1V-E Page l
j/JJgJYlJfCB .
RICHARD BARR AND ANN BARR RLB SERVICES D
6996 WERTZVILLE RD
MECHANICSBURG PA 17050-1540
Iuilllu?Ilhudd?Runulld?ln6dlln?lduelhuihll
ACCOUNT 614-422-086 SUMMARY
Previous Amount Due ................... $ 9,836.00
Payment Received 03/05/08 Thank You $ -9,836.00
Minimum Amount Due By 04/03/08 $ 6,282.00
See back for details
IMPORTANT MESSAGES
Save Time In Your Day,
Use Seleditynw
Log onto www.selective.com or call
1-888-974-7400 to pay your bill,
Cancel pending on policy S 1577408. Full payment of $ 2,562.00 must be received by 03/30/08. A separate cancellation
notice has been issued on this policy. Full payment must be received prior to the cancellation due date. Contact your agent
for the status or for additional information regarding this policy.
Cancel pending on policy WC 7246916. Full payment of $ 930.00 must be received by 03/30108. A separate cancellation
notice has been issued on this policy. Full payment must be received prior to the cancellation due date. Contact your agent
for the status or for additional information regarding this policy.
Detach and return this portion with your payment. Please write your account number on your check.
----------------------------------------------------------- -
Name on Account Account Number Account Balance Minimum Amt. Due Due Date Amount Enclosed
RICHARD BARR AND A 614-422-086 S 24,403.00 $ 6,282.00 1 04/03/08 $
ware a-neck rayaDie to Sejective insurance Company of America Mail Payment To:
Selective Insurance Company of America
Box 371468
Pittsburgh PA 15250-7468
i?ulhl?hnhhlddlndnd?luhlhrhdnllnlohluhl
16144220860313200800006282nnnnnauun-2nnnnnnn
D840 (07!06) EXHIBIT "C" 2963-00000 614-422-086
DETAILS FOR M
614-422.086
/?1 S 1577408 Effective 02/12/06 SICK (? 1
l7? Commercial Package
RICHARD BARR AND ANN BARR RLB SERVICES D
S 1577408 Effective 02/12107 SICSC $
Commercial Package
RICHARD BARR AND ANN BARR RLB SERVICES D
S 1577408 Effective 02/12/08 SICSC
Cancel Pending
Commercial Package
RICHARD BARR AND ANN BARR RLB SERVICES D
- WC 7246916 Effective 02/12/06 SICA (z) $
Workers Compensation
RICHARD BARR AND ANN BARR RLB SERVICES D
WC 7246916 Effective 02/12/07 SICA $
Ck' Workers Compensation
RICHARD BARR AND ANN BARR RLB SER ICES D
WC 7246916 Effective 02/12/08 SICA
Cancel Pending
Workers Compensation
RICHARD BARR AND ANN BARR RLB SERVICES D
Installment Fee
2,447.00
Page 2
RECENT ACCOUNT ACTIVITY
Prior Account Balance
S 1577408 Eff. 02/12106 $ 2,447.00
S 1577408 Eff. 02/12/07 $ 2,204.00
S 1577408 Eff. 02/12/08 $ 13, 843.00
2,204-00 WC 724,6916 Eff. 02/12/06 $ 834.00
WC 7246916 Eff. 02/12/07 $ 791.00
WC 7246916 Eff. 02/12/08 $ 4,695.00
Total $ 25, 014.00
Payments and Adjustments
S 1577408 Eff. 02/12/06 $ -2,447.00
S 1577408 Eff. 02/12/07 $ -2,204.00
834.00 S 1577408 Eff. 02/12/08 $ -2,630.00
WC 7246916 Eff. 02/12/06 $ -834.00
WC 7246916 Eff. 02/12/07 $ -791.00
WC 7246916 Eff. 02/12/08 $ -930.00
791.00 Total $ -9,836.00
Refunds
Returned Payment $ 9,836.00
Total $ 91836.00
Policy Changes
S 1577408 Eff. 02/12/08 $ -611.00
Installment Fee $ 6.00
6.00 Total $ -605.00
MIN. AMOUNT DUE BY 04/03/08 $ 6,282.00
When you provide a check as payment, you authorize us either to use information from your check to make a one-time
electronic fund transfer from your account or to process the payment as a check transaction. When we use information
from your check to make an electronic fund transfer, funds may be withdrawn from your account as soon as the same day
we receive your payment, and you will not receive your check back from your financial institution.
ONE OR MORE OF SELECTIVE INSURANCE GROUP, INC.'S MEMBER INSURERS WHICH INCLUDE
SELECTIVE INSURANCE COMPANY OF AMERICA (SICA), SELECTIVE WAY INSURANCE COMPANY (SWIC),
SELECTIVE INSURANCE COMPANY OF SOUTH CAROLINA (SICSC), SELECTIVE INSURANCE COMPANY
OF THE SOUTHEAST (SICSE), SELECTIVE INSURANCE COMPANY OF NEW YORK (SICNY), SELECTIVE
INSURANCE COMPANY OF NEW ENGLAND (SICNE), AND SELECTIVE AUTO INSURANCE COMPANY OF
NEW JERSEY (SAICNJ) HAVE ISSUED YOUR POLICY TO WHICH THIS PREMIUM BILL PERTAINS.
CONTINUED ON NEXT PAGE
DB-47 (07106)
Page 3
BILL ACCOUNT 614-422-086
DB-48 (07.'06)
RECENT ACCOUNT ACTIVITY continued
Current Account Balance
S 1577408 Eff. 02/12/06 $ 2, 447.00
S 1577408 Eff. 02/12/07 $ 2,204.00
S 1577408 Eff. 02/12/08 $ 13, 232.00
WC 7246916 Eff. 02/12/06 $ 834.00
WC 7246916 Eff. 02112/07 $ 791.00
WC 7246916 Eff. 02/12/08 $ 4,895.00
Installment Fee $ 6.00
Total $ 24,409.00
Issued by The Stock Insurance Company =1-977408*c
umberSELECTIVE INSURANCE COMPANY OF SOUTH CAROLI
3426 TORINGDON WAY, CHARLOTTE, NC 28277
COMMERCIAL POLICY COMMON DF.C1,ARATION
Named Insured and Address Policy Period
RICHARD BARR AND ANN BARR RLB SERVICES D/B/A From: FEBRUARY 12, 2007
6996 WERTZVILLE RD To: FEBRUARY 12, 2008
MECHANICSBURG, PA 17050-1540
12:01 A.M Standard Time At
Location of Designated Premises.
Named Insured is: Producer Number:
INDIVIDUAL 00-02963-00000
Producer:
KNOLL INSURANCE AGENCY INC
PENNSYLVANIA
Schedule of Coverage
COMMERCIAL PROPERTY COVERAGE
COMMERCIAL GENERAL LIABILITY COVERAGE
COMMERCIAL AUTOMOBILE COVERAGE
COMMERCIAL INLAND MARINE COVERAGE
REFER TO THE ATTACHED IMPORTANT NOTICE CA7048 FOR
INFORMATION REGARDING COLLISION COVERAGE ON RENTAL VEHICLEk'
PREMIUM INCLUDES TERRORISM COVERAGE $153.00
In return for payment of the premium, and subject to all the terms of this policy, we agree with
you to provide the insurance indicated in the schedule above. Insurance is provided only for
those coverages for which a specific limit is shown on the attached coverage declaration(s).
PAYMENT METHOD Total Policy Premium $7,462.00
D/B - 10 (This premium may be subject to adjustment.)
Date Issued: DECEMBER 7, 2006
Issuing Office: PENNSYLVANIA REGION
Authorized Representative
EXHIBIT "D"
. I
Policy Number
S 1577408
SCHEDULE OF LOCATIONS
Policy Effective Date: FEBRUARY 12, 2007 Schedule Effective Date: FEBRUARY 12, 2007
Prem. Bldg.
No. Location No. Occupancy
1 6996 WERTZVILLE RD 1 OFFICE
MECHANICSBURG, PA 17050
2 54 E MAIN STREET (REAR) 1 CNTR STORAGE
NEW KINGSTOWN, PA 17072
IL-7036 (01/93)
INSURED'S COPY
SELECTIVE
Policy Summary
Insured Name: RICHARD BARR AND ANN BARR RLB SERVICES D/B/A
Address: 6996 WERTZVILLE RD
MECHANICSBURG PA 17050-1540
Policy #: S 1577408 Effective Date: 02/12/2007
Total Premium
Premium 12,061.00
- Paid 9,857.00
Remaining Balance 2,204.00
Status: LEGAL Pay Plan: 10 Pay
Policy is in external collections as of 04/28/2008
Type
RENEWAL POLICY PREMIUM
ENDORSEMENT
ENDORSEMENT
ENDORSEMENT
ENDORSEMENT
ENDORSEMENT
ENDORSEMENT
ENDORSEMENT
ENDORSEMENT
Transaction Transaction Process
Eff Date Amount Date
02/12/2007 7,462.00 12/07/2006
02/12/2007 240.00 01/29/2007
02/12/2007 -265.00 01/30/2007
03/05/2007 -64.00 03/13/2007
03/07/2007 792.00 03/22/2007
05/11/2007 123.00 05/23/2007
08/27/2007 1,698.00 09/19/2007
11/13/2007 -129.00 11/20/2007
02/12/2007 2,204.00 02/07/2008
.vv
-,--v
EXHIBIT E
Issued by The Stock Insurance Company WC 00 00 01 A
POLICY NUMBER PREVIOUS POLICY NUMBER
WC 7246916 NEW
SELECTIVE INSURANCE COMPANY OF AMERICA
40 WANTAGE AVE, BRANCHVILLE, NJ 07890
INFORMATION PAGE NCCI COMPANY NO. 11169
WORKERS COMPENSATION AND EMPLOYERS LIABILITY INSURANCE POLICY
ITEM 1. NAME OF INSURED & MAILING ADDRESS PRODUCER'S NAME AND MAILING ADDRESS
RICHARD BARR AND ANN BARR KNOLL INSURANCE AGENCY INC
6996 WERTZVILLE RD 704 BRIDGE ST
MECHANICSBURG, PA 17050--154 NEW CUMBERLAND, PA 17070-1623
INSURED IS: INDIVIDUAL FED ID NO. 251851763 AGENT NUMBER: 09-00-02963-00000
ITEM 2. POLICY PERIOD The Policy Period is from FEBRUARY 12, 2006 To FEBRUARY 12, 2007
12:01 A.M., standard time at the insured's mailing address.
ITEM 3. COVERAGE
A. Workers Compensation Insurance: Part One of the policy applies to the Workers Compensation law of the states listed here:
PA
B. Employers Liability Insurance: Part Two of the policy applies to work in each stated listed in Item 3.A.
The limits of our liability under Part Two are: Bodily Injury By Accident $100,000 each accident
Bodily Injury By Disease $100,000 each employee
Bodily Injury By Disease $500,000 policy limit
C. Other States Insurance: Part Three of the policy applies to the states, if any, listed here:
ALL STATES EXCEPT ND,OH,WA,WV & WY.
ITEM 4. PREMIUM: The premium for this policy will be determined by our manuals of rules, classifications, rates and rating plans. All
information required below is subject to verification and change by audit.
Code Premium Basis Rate Per Estimated
CLASSIFICATION No. Total Estimated $100 of Annual
Annual Remuneration Remuneration Premium
SEE ATTACHED SCHEDULE(S)
EXPENSE CONSTANT 0900 230
FOREIGN TERRORISM -PA $.040 9740 29
DOM TER, EARTH & CAT IND ACC- PA $.020 9741 15
PA EMPLOYER ASSESSMENT ( 1.91%) 0938 80
Minimum Premium $1,247 PENNSYLVANIA Total Estimated Cost $4,247
If indicated below, interim adjustments of premium shall be made:
Semi-Annually I I Quarterly Monthly Deposit Premium $4,247
This policy includes these endorsements and schedules: REFER TO WC-52
D/B - 10 - 614422086
Issue Date: FEBRUARY 28, 2006 Issuing Office: PENNSYLVANIA REGION, 18002-5333
Authorized Representative
Form-64 (11/88) Copyright 1987 National Council on Compensation Insurance.
EXHIBIT F
Attached to and Forming Part of
Policy Number WC 7246916
Name of Company Policy Effective Date 02/12/06
SELECTIVE INSURANCE COMPANY OF AMERICA
FED ID NO. 251851763
NCCI COMPANY NO. 11169 BUREAU FILE NO. 3037192
SCHEDULE OF OPERATIONS
Extension of Item Nn 4 of the Tnfnrmat;nn P.- wr_no-nn nt A
Location of Operations Insured's Name and State Location
RICHARD BARR AND ANN BARR
PENNSYLVANIA
Producer KNOLL INSURANCE AGENCY INC 09-00-02963-00000
Classification of Operations
Code No. Estimated Total
Remuneration Rate Per $100 of
remuneration Estimated
Premium
7C Annual 3 Year ]I Annual Ll 3 Year
LOCATION # 001
EXCAVATION NOC (00) 0609 55,200 10.17 5,614
CLERICAL OFFICE EMPLOYEES (00) 0953 18,200 .48 87
ESTIMATED ANNUAL PREMIUM 5,701
PREMIUM FOR INCREASED LIMITS PART TWO NONE
DEDUCTIBLE CREDIT (9664) NONE
PREMIUM SUBJECTED TO EXPERIENCE MODIFICATION 5,701
APPLICABLE EXPERIENCE MODIFICATION .843
PREMIUM ADJUSTED BY APPLICATION OF EXPERIENCE MODIFICATION (9898) 4,806
SCHEDULE MODIFICATION 19.00% (9887) ( 913)
CERTIFIED SAFETY COMMITTEE CREDIT (9890) NONE
CONSTRUCTION CREDIT (9046) NONE
PER CAPITA PREMIUM NONE
POLICY MINIMUM PREMIUM CHARGE (0990) NONE
TOTAL ESTIMATED STANDARD PREMIUM 3,893
PREMIUM DISCOUNT (0063) NONE
LARGE DEDUCTIBLE CREDIT NONE
PREMIUM SUBTOTAL 3,893
Issue Date: FEBRUARY 28, 2006 PA Authorized Representative
Form-63 (1 P88)
INSURED'S COPY
SCHEDULE OF LOCATIONS
Policy Number
WC 7246916
Policy Effective Date: FEBRUARY 12, 2006 Schedule Effective Date: FEBRUARY 12, 2006
EXTENSION OF INFORMATION PAGE
ITEM 1.
LOCATIONS OF THE INSURED
LOCATION NUMBER ADDRESS
001 6996 WERTZVILLE RD
MECHANICSBURG, PA 17050
WC-54 (03/99)
INSURED'S COPY
SELECTIVE
Policy Summary
Insured Name: RICHARD BARR AND ANN BARR RLB SERVICES D/B/A
Address: 6996 WERTZVILLE RD
MECHANICSBURG PA 17050-1540
Policy #: WC 7246916
Status: LEGAL
Effective Date: 02/12/2006
Pay Plan: 10 Pay
Policy is in external collections as of 04/28/2008
Type Transaction Transaction Process
Eff Date Amount Date
NEW POLICY PREMIUM 02/12/2006 4,247.00 02/27/2006
ENDORSEMENT 02/12/2006 -9.00 05/18/2006
AUDIT 02/12/2006 834.00 02/07/2008
5,072.00
EXHIBIT
r
Issued by The Stock Insurance Company WC 00 00 01 A
POLICY NUMBER PREVIOUS POLICY NUMBER
WC 7246916 WC 7246916
SELECTIVE INSURANCE COMPANY OF AMERICA
40 WANTAGE AVE, BRANCHVILLE, NJ 07890
INFORMATION PAGE NCCI COMPANY NO. 11169
WORKERS COMPENSATION AND EMPLOYERS LIABILITY INSURANCE POLICY
ITEM 1. NAME OF INSURED & MAILING ADDRESS PRODUCER'S NAME AND MAILING ADDRESS
RICHARD BARR AND ANN BARR RLB SERVICES KNOLL INSURANCE AGENCY INC
D/B/A 704 BRIDGE ST
6996 WERTZVILLE RD NEW CUMBERLAND, PA 17070-1623
MECHANICSBURG, PA 17050-1540
INSURED IS: INDIVIDUAL FED ID NO. 251851763 AGENT NUMBER: 09-00-02963-00000
ITEM 2. POLICY PERIOD The Policy Period is from FEBRUARY 12, 2007 To FEBRUARY 12, 2008
12:01 A.M., standard time at the insured's mailing address.
ITEM 3. COVERAGE
A. Workers Compensation Insurance: Part One of the policy applies to the Workers Compensation law of the states listed here:
PA
B. Employers Liability Insurance: Part Two of the policy applies to work in each stated listed in Item 3.A.
The limits ofour liability under Part Two are: Bodily Injury By Accident $100,000 each accident
Bodily Injury By Disease $100,000 each employee
Bodily Injury By Disease $500,000 policy limit
C. Other States Insurance: Part Three of the policy applies to the states, if any, listed here:
ALL STATES EXCEPT ND,OH,WA,WV & WY.
ITEM 4. PREMIUM: The premium for this policy will be detennined by our manuals of rules, classifications, rates and rating plans. All
information required below is subject to verification and change by audit.
Code Premium Basis Rate Per Estimated
CLASSIFICATION No. Total Estimated $100 of Annual
Annual Remuneration Remuneration Premium
SEE ATTACHED SCHEDULE(S)
EXPENSE CONSTANT 0900 230
FOREIGN TERRORISM -PA $.050 9740 37
DOM TER, EARTH & CAT IND ACC- PA $.020 9741 15
PA EMPLOYER ASSESSMENT ( 1.98%) 0938 79
Minimum Premium $1,199 PENNSYLVANIA Total Estimated Cost $4,088
If indicated below, interim adjustments of premium shall be made:
Semi-Annually I I Quarterly Monthly Deposit Premium $4,088
This policy includes these endorsements and schedules: REFER TO WC-52
D/B - 10 - 614422086
Issue Date: DECEMBER 19, 2006 Issuing Off-ice: PENNSYLVANIA REGION, 18002-5333
Authorized Representative
Form-64 (11/88) Copyright 1987 National Council on Compensation Insurance.
EXHIBIT ?_
ib 0
Attached to and Forming Part of
Policy Number WC 7246916
Name of Company Policy Effective Date 02 / 12 / 07
SELECTIVE INSURANCE COMPANY OF AMERICA
FED ID NO. 251851763
NCCICOMPANY NO. 11169 BUREAU FILE NO. 3037192
SCHEDULE OF OPERATIONS
F.xtencinn of Tt- Nn d of tho Tnf -+;-- to- mr nn nn ni e
Location of Operations Insured's Name and State Location
RICHARD BARR AND ANN BARR
PENNSYLVANIA
Producer KNOLL INSURANCE AGENCY INC 09-00-02963-00000
Classification of Operations
Code NO. Estimated Total
Remuneration Rate Per S 100 of
remuneration Estimated
Premium
Annual 3 Year 7C' Annual 3 Year
LOCATION # 001
EXCAVATION NOC (00) 0609 55,200 9.69 5,349
CLERICAL OFFICE EMPLOYEES (00) 0953 18,200 .49 89
ESTIMATED ANNUAL PREMIUM 5,438
PREMIUM FOR INCREASED LIMITS PART TWO NONE
DEDUCTIBLE CREDIT (9664) NONE
PREMIUM SUBJECTED TO EXPERIENCE MODIFICATION 5,438
APPLICABLE EXPERIENCE MODIFICATION .846
PREMIUM ADJUSTED BY APPLICATION OF EXPERIENCE MODIFICATION (9898) 4,601
SCHEDULE MODIFICATION 19.00% (9887) ( 874)
CERTIFIED SAFETY COMMITTEE CREDIT (9890) NONE
CONSTRUCTION CREDIT (9046) NONE
PER CAPITA PREMIUM NONE
POLICY MINIMUM PREMIUM CHARGE (0990) NONE
TOTAL ESTIMATED STANDARD PREMIUM 3,727
PREMIUM DISCOUNT (0063) NONE
LARGE DEDUCTIBLE CREDIT NONE
PREMIUM SUBTOTAL 3,727
Issue Date: DECEMBER 19, 2006 PA Authorized Representative
f=orm-63 (11/84)
INSURED'S COPY
SCHEDULE OF LOCATIONS
Policy Number
WC 7246916
Policy Effective Date: FEBRUARY 12, 2007 Schedule Effective Date: FEBRUARY 12, 2007
EXTENSION OF INFORMATION PAGE
ITEM 1.
LOCATIONS OF THE INSURED
LOCATION NUMBER ADDRESS
001 6996 WERTZVILLE RD
MECHANICSBURG, PA 17050
WC-54 (03/99)
INSURED'S COPY
? 4 e
+ SELECTIVE
Policy Summary
Insured Name: RICHARD BARR AND ANN BARR RLB SERVICES D/B/A
Address: 6996 WERTZVILLE RD
MECHANICSBURG PA 17050-1540
Policy #: WC 7246916
Effective Date: 02/12/2007
Total Premium
Premium 4,879.00
- Paid 4,088.00
Remaining Balance 791.00
Status: LEGAL
Pay Plan: 10 Pay
Policy is in external collections as of 04/28/2008
Transaction Transaction Process
Type Eff Date Amount Date
RENEWAL POLICY PREMIUM 02/12/2007 4,088.00 12/19/2006
ENDORSEMENT 02/12/2007 791.00 02/07/2008
4,879.00
EXHIBIT -3-:
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10(/3
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-06767 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SELELCTIVE INSURANCE COMPANY
VS
BARR RICHARD L ET AL
MARK CONKLIN
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
BARR RICHARD L
the
DEFENDANT
, at 2100:00 HOURS, on the 18th day of November , 2008
at 6996 WERTZVILLE ROAD
MECHANICSBURG, PA 17050-1540 by handing to
RICHARD BARR
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 11.00
Postage .76
Surcharge 10.00
.00
ifoS?DB?. 39.76
Sworn and Subscibed to
before me this day
So Answers:
R. Thomas Kline
11/19/2008
KODAK & IMBLUM
s..
By:
eput Sheriff
of A. D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-06767 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SELELCTIVE INSURANCE COMPANY
VS
BARR RICHARD L ET AL
MARK CONKLIN , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
BARR RICHARD L TRADING AS RLB SERVICES the
DEFENDANT , at 2100:00 HOURS, on the 18th day of November , 2008
at 6996 WERTZVILLE ROAD
MECHANICSBURG, PA 17050-1540 by handing to
RICHARD BARR
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
.00
10.00
.00
16.00
Sworn and Subscibed to
before me this
of
day
So Answers:
R. Thomas Kline
11/19/2008
KODAK & IMBLUM
By:
Deputy Sheriff
A. D.
r
CASE NO: 2008-06767 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SELELCTIVE INSURANCE COMPANY
VS
BARR RICHARD L ET AL
MARK CONKLIN , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
RAPP ANN n the
DEFENDANT , at 2100:00 HOURS, on the 18th day of November-, 2008
at 6996 WERTZVILLE ROAD
MECHANICSBURG, PA 17050-1540
by handing to
RICHARD BARR, HUSBAND
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
f?/o5/o f
6.00
.00
.00
10.00
.00
16.00
Sworn and Subscibed to
before me this
of
day
So Answers:
R. Thomas Kline
11/19/2008
KODAK & IMBLUM 000,
By:
eput Sheriff
A. D.
' CASE NO: 2008-06767 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SELELCTIVE INSURANCE COMPANY
VS
BARR RICHARD L ET AL
MARK CONKLIN , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
BARR ANN D TRADING AS RLB SERVICES the
DEFENDANT , at 2100:00 HOURS, on the 18th day of November-, 2008
at 6996 WERTZVILLE ROAD
MECHANICSBURG, PA 17050
RICHARD BARR, ANN'S HUSBAND
by handing to
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
i?/OswB ;,. .00
1
Sworn and Subscibed to
before me this day
of ,
So Answers:
R. Thomas Kline
11/19/2008
KODAK & IMBLUM
By:
De uty /Seriff
A. D.
SELECTIVE INSURANCE COMPANY OF AMERICA : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2008-6767 CIVIL
RICHARD L. BARR and ANN D. BARR each : CIVIL ACTION - LAW
individually and trading s RLB Services
Defendants
TO: PROTHONOTARY, COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
PRAECIPE FOR DEFAULT JUDGMENT
Please enter judgment in favor of Plaintiff and against Defendant(s) RICHARD L.
BARR and ANN D. BARR each individually and trading s RLB Services, named for failure
to file within the required time an Answer to the Complaint in the above-captioned case
and assess the Plaintiff's damages as follows:
Amount claimed in Plaintiffs Complaint for all counts $6,282.00
Interest at the statutory rate of 6% per annum from Ap 3, 2008 282.69
Total = $6,564.69
I hereby certify that a written Important Notice of the intent to file this Praecipe was
mailed or delivered to the Defendant(s) and/or his/her Attorney of Record, if any, after
the default occurred and at least ben (10) days prior to the date of the filing of this Praecipe
and a copy of the notice(s) is/ are attached.
KODAK & IMBL , P.C.
By
Robert D. Kodak, Attorney for Plaintiff
DATED: Judgment entered and dam ges assessed as above.
41. ? -
othonota
LAW OFFICES OF
KODAK & IMBLUM, P.C.
CAMERON MANSION Telephone
Robert D. Kodak 407 NORTH FRONT STREET 717.238.
Gary J. Imblum POST OFFICE BOX 11848 Facsimile
HARRISBURG, PA 17108-1848 717.238.7158
www.kodak-imbl um.com
December 12, 2008
RICHARD L BARR IATA
RLB SERVICES
6996 WERTZVILLE RD
MECHANICSBURG PA 17050-1540
RE: Selective Insurance Company of America FILE copy
VS: Richard L. Barr and Ann D. Barr a/i/a/t/a RLB Services
Our File No. 34681
No. 08-6767 Civil, Court of Common Pleas
Cumberland County, Pennsylvania
Dear Mr. Barr:
In accordance with Pennsylvania Rules of Civil Procedure 237.1, we are enclosing herewith a
Notice of a Praecipe for Entry of Default Judgment. According to the records as they are found in the
Office of the Prothonotary of Cumberland County, you have not filed responsive pleadings to the
Complaint filed against you to the above term and number, nor has any attorney entered an appearance
on your behalf.
Accordingly, we are forwarding to you the enclosed Notice which indicates that if you do not take
action as set forth in this Notice, we, at the expiration of time indicated therein, will request the Office
of the Prothonotary of Cumberland County, Pennsylvania, to enter Judgment against you in the amount
as set forth in said Complaint.
Very truly yours,
RDK/ bjh
enclosure
KODAK & IMBLUM, P.C.
Robert D. Kodak
Tobert.kodak@kodak-imblum.com
THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
cc FRANK VECCHIO
THE COMMERCIAL COLLECTION CORP OF NY
PO BOX 288
TONAWANDA NY 14150 533765/533767/533766/533784
SELECTIVE INSURANCE COMPANY OF AMERICA
Plaintiff
V.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08-6767 CIVIL
RICHARD L. BARR and ANN D. BARR each individually : CIVIL ACTION - LAW
and trading s RLB Services
Defendants
IMPORTANT NOTICE
FILE COPY
TO: RICHARD L. BARR I A T ARLBSERVICES Defendants
DATE OF NOTICE: December 12, 2008
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 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 REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
717-249-3166
LAW OFFICES OF
KODAK & IMBLUM, P.C.
CAMERON MANSION Telephone
Robert D. Kodak 407 NORTH FRONT STREET 717.238.
Gary J. Imblum POST OFFICE BOX 11848 Facsimile
le
HARRISBURG, PA 17108-1848 717.238.7158
www.kodak-imblum.com
December 12, 2008
FILE COPY
ANN D BARR IATA
RLB SERVICES
6996 WERTZVILLE RD
MECHANICSBURG PA 17050-1540
RE: Selective Insurance Company of America
VS: Richard L. Barr and Ann D. Barr a/i/a/t/a RLB Services
Our File No. 34681
No. 08-6767 Civil, Court of Common Pleas
Cumberland County, Pennsylvania
Dear Ms. Barr:
In accordance with Pennsylvania Rules of Civil Procedure 237.1, we are enclosing herewith a
Notice of a Praecipe for Entry of Default Judgment. According to the records as they are found in the
Office of the Prothonotary of Cumberland County, you have not filed responsive pleadings to the
Complaint filed against you to the above term and number, nor has any attorney entered an appearance
on your behalf.
Accordingly, we are forwarding to you the enclosed Notice which indicates that if you do not take
action as set forth in this Notice, we, at the expiration of time indicated therein, will request the Office
of the Prothonotary of Cumberland County, Pennsylvania, to enter judgment against you in the amount
as set forth in said Complaint.
Very truly yours,
RDK/ bjh
enclosure
KODAK & IMBLUM, P.C.
Robert D. Kodak
robert.kodak@kodak-imblum.com
THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
cc FRANK VECCHIO
THE COMMERCIAL COLLECTION CORP OF NY
PO BOX 288
TONAWANDA NY 14150 533765/533767/533766/533784
SELECTIVE INSURANCE COMPANY OF AMERICA : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 08-6767 CIVIL
RICHARD L. BARR and ANN D. BARR each individually : CIVIL ACTION - LAW
and trading s RLB Services
Defendants
IMPORTANT NOTICE
TO: ANN D. BARR I/ A/ T/ A RLB SERVICES, Defendant(s)
DATE OF NOTICE: December 12, 2008
FILE COPY
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 TUIS 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 REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
717-249-3166
144
p ? O
(n D
?7 ^J
P
- F-7
SELECTIVE INSURANCE COMPANY OF AMERICA : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 20084767 CIVIL
RICHARD L. BARR and ANN D. BARR each : CIVIL ACTION -LAW
individually and trading s RLB Services
Defendants
TO: RICHARD L. BARR I/AJT/A RLB SERVICES, Defendant(s)
You are hereby notified that on Jill 5 , 20pj the following
(judgment) has been entered against you in the above-captioned case.
Tndgment entered in the amount of $6.,%C 9
DATE:
othon
I hereby certify that the name and address of the proper person(s) to receive this notice is:
RICHARD L BARR IATA
RLB SERVICES
69% WERTZVILLE RD
MECHANICSBURG PA 17050-1540
SELECTIVE INSURANCE COMPANY OF AMERICA : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2008-6767 CIVIL
RICHARD L. BARR and ANN D. BARR each : CIVIL ACTION -LAW
individually and trading s RLB Services
Defendants
TO: ANN D BARR I J A/T/ A RLB SERVICES, Defendant(s)
You are hereby notified that on %?Ckn 5 , 20-0 the following
(judgment) has been entered against you in the above-captioned case.
Tudgment entered in the amount of $6,564.69
DATE:
thou ry
I hereby certify that the name and address of the proper person(s) to receive this notice is:
ANN D BARR IATA
RLB SERVICES
69% WERTZVILLE RD
MECHANICSBURG PA 17050-1540
_. 4
PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS)
P.R.C.P. 3101 to 3149
Selective Insurance Company of America IN THE COURT OF COMMON PLEAS OF
40 Wantage Ave, Brachville NJ 07890 Cumberland COUNTY, PENNSYLVANIA
Plaintiff Writ No. Term 20
vs No. 08-6767 Term 2008
Amount Due
Richard L. Barr and Ann D. Barr each ind 1/26/09 jdmt .............
& t/ a RLB Services
6996 Wertzville Road
Mechanicsburg PA 17050
DEFENDANT(S)
First National Bank of Pennsylvania
Garnishee
Interest from 1/5/09-1/26/09
1.06 per diem ..............
Attby's Commission
5/0 ......................
Costs (to be determined)
$ 6,564.69
$ 22.32
$ 328.24
TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER,
(1) Directed to the Sheriff of CUMBERLAND . Cour(ty, Pennsylvania
(2) against Richard L Barr and Ann D Barr each i/ a/ t/ a RLB Services
e en ants ;
(3) and against
Garnishee s ;
(4) and index this writ
(a) against Richard L Barr and Ann D Barr each i/ a/ t/ a RLB Services
Defendant(s) and
(b) against
arrusneeks),
as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows:
(Specifically describe property and note any specific direction to Sheriff) Furnish 4 copies for real estate levy):
LEVY UPON ALL PERSONAL PROPERTY OF THE ABOVE-LISTED DEFENDANT(S) AT THE ABOVE ADDRESS IN
CUMBERLAND COUNTY, INCLUDING BUT NOT LIMITED TO FURNITURE, JEWELRY, ELECTRONICS, SUPPLIES, ETC.,
(5) Exemption has (not) been waived.
Robert D. Kodak, Esquire
PO Box 11848
Harrisburg, PA 17108
(717) 238-7159
Dated 12 3 08 Attorney For Plaintiff(s)
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of sanssi liL" aqi uayM '(e)b0l £ a1nE 6q pazuoyine se pansap si `aouujnssi jo ?4unoa ayi ui suorinoaxa aqi;o 8uixapui;l ? luo paialdwoo aq plnoys (e)(b) ydeaSeied
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- 4
COMMONWEALTH OF PENNSYLVANIA) NO 08-6767 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due SELECTIVE INSURANCE COMPANY OF
AMERICA, Plaintiff (s)
From RICHARD L. BARR AND ANN D. BARR EACH IND. & T/A RLB SERVICES, 6996
WERTZVILLE ROAD, MECHANICSBURG, PA 17050
(1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL
PERSONAL PROPERTY OF THE ABOVE-LISTED DEFENDANT(S) AT THE ABOVE
ADDRESS IN CUMBERLAND COUNTY, INCLUDING BUT NOT LIMITED TO
FURNITURE, JEWELRY, ELECTRONICS, SUPPLIES, ETC. .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $6,564.69
L.L. $.50
Interest FROM 1/5/09-1/26/09 1.06 PER DIEM -- $22.32
Atty's Comm5 % $328.24 Due Prothy $2.00
Atty Paid $206.76 Other Costs
Plaintiff Paid
Date: JANUARY 27, 2009
(Seal)
Curtis R. Long, Prothonotary
By:
Deputy
REQUESTING PARTY:
Name ROBERT D. KODAK, ESQUIRE
Address: PO BOX 11848
HARRISBURG, PA 17108
Attorney for: PLAINTIFF
Telephone: 717-238-7151
Supreme Court ID No. 18041
r S 7t i, ..
&Thomas Kline, Sheriff, who being duly sworn according to law, states
r?is writ is returned STAYED, per request from attorney.
'Sheriff's Costs: Advance Costs: 150.00
Sheriff's Costs: 136.17
Docketing
Poundage
Advertising
Law Library
Prothonotary
Mileage
Surcharge
Levy
Certified Mail
Postpone Sale
Garnishee
Postage
TOTAL
18.00 13.83
2.67
10.00
.50
2.00, Refunded to Atty on 04/14/09
18.00
50.00
20.00
15.00
$ 136.17 ? y Jt4 So Answers;
R. Thomas Kline, Sheriff z
• By Sharon R. Lantz ?
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-6767 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due SELECTIVE INSURANCE COMPANY OF
AMERICA, Plaintiff (s)
From RICHARD L. BARR AND ANN D. BARR EACH IND. & T/A RLB SERVICES, 6996
WERTZVILLE ROAD, MECHANICSBURG, PA 17050
(1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL
PERSONAL PROPERTY OF THE ABOVE-LISTED DEFENDANT(S) AT THE ABOVE
ADDRESS IN CUMBERLAND COUNTY, INCLUDING BUT NOT LIMITED TO
FURNITURE, JEWELRY, ELECTRONICS, SUPPLIES, ETC. .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $6,564.69
L.L. $.50
Interest FROM 1/5/09-1/26/09 1.06 PER DIEM --$22.32
Atty's Comm5 % $328.24 Due Prothy $2.00
Atty Paid $206.76 Other Costs
Plaintiff Paid
Date: JANUARY 27, 2009
(Seal)
REQUESTING PARTY:
Name ROBERT D. KODAK, ESQUIRE
Address: PO BOX 11848
HARRISBURG, PA 17108
Attorney for: PLAINTIFF
Telephone: 717-238-7151
Curtis R. Long, Prothonotary
By:
Deputy
Supreme Court ID No. 18041