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Home My WebLink About08-6843?PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFIELD, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 THIS IS AN ARBITRATION MATTER ATTORNEY FOR PLAINTIFF ERIE INSURANCE EXCHANGE AS SUBROGEE OF MARK J. SALTUS 3410 W. 12T" STREET ERIE, PA 16505 VS. CHAD MUTZABAUGH 368 B S. RIVER ROAD HALIFAX, PA 17032 AND JOHN MEHASFIE 368 B S. RIVER ROAD HALIFAX. PA 17032 NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE 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. Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 Lawyer Referral Service 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 COMMON PLEAS COURT OF CUMBERLAND COUNTY NO. M-(08'3 Civil te' k CIVIL ACTION "ISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene (20) dial de plazo a partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte sus defensas o sus objeciones a las demandas encontra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion o por cualqier queja o alivio que espedido en la peticion de demanda. Usted puede perder dinero, sus propiedades o otros derechos importantes pare usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE PARA PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE USTED PUEDE CONSEGUIR ASISTENCIA LEGAL. Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 Lawyer Referral Service 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 PAUL F. D-EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFIELD, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 ERIE INSURANCE EXCHANGE AS SUBROGEE OF MARK J. SALTUS 3410 W. 12TH STREET ERIE, PA 16505 VS. CHAD MUTZABAUGH 368 B S. RIVER ROAD HALIFAX, PA 17032 AND THIS IS AN ARBITRATION MATTER JOHN MEHASFIE 368 B S. RIVER ROAD . HALIFAX, PA 17032 ATTORNEY FOR PLAINTIFF COMMON PLEAS COURT OF CUMBERLAND COUNTY NO. v?'` GFy3 `?? CIVIL ACTION NOTICE UNDER THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1601 (AS AMENDED) THE PENNSYLVANIA UNFAIR TRADE PRACTICES ACT AND CONSUMER PROTECTION LAW, 73 PA.CON.STAT.ANN. §201, ET. SEQ. ("THE ACTS") IN AS MUCH AS THE ACTS MAY APPLY, PLEASE BE ADVISED THAT THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. COMPLAINT The Plaintiff, Erie Insurance Exchange, by its attorney Paul F. D'Emilio, Esquire, bring this action upon a cause whereof the following is a statement: 1. The Plaintiff, Erie Insurance Exchange, ("Plaintiff') is a Corporation authorized to do business in the Commonwealth of Pennsylvania, with an address of 3410 W. 12 `h Street, Erie, PA 16505. Plaintiff brings this action as subrogee of Mark J. Saltus, herein the ("Insured") under a policy of insurance issued by Plaintiff. 2. Defendant, Chad Mutzabaugh, is an individual residing at 3410 W. 12th Street, Erie, PA 16505. 3. Additional Defendant, John Mehasfie, is an individual residing at 3410 W. 12th Street, Erie, PA 16505. 4. At all times hereinafter mentioned the Defendant Chad Mutzabaugh was the agent, workman, servant and employee of Defendant John Mehasfie and was engaged in the business of Defendant John Mehasfie and was acting within the course and scope of his employment. 5. On or about October 6, 2007 a motor vehicle owned by the Defendant John Mehasfie and operated by the Defendant Chad Mutzabaugh was traveling on Carlisle Pike, Mechanicsburg, Pennsylvania, when he attempted to make a turn and struck Plaintiffs Insured's vehicle causing the damages hereinafter set forth. 6. Plaintiff avers that the motor vehicle of the Insured was damaged as a result of the occurrence hereinbefore mentioned, the reasonable costs of repairs thereto being is Four Thousand Two Hundred Eighty Nine and 15/100 ($4,289.15) Dollars plus the Insured's deductible of Five Hundred and 00/100 ($500.00) Dollars for a total of Four Thousand Seven Hundred Eighty Eight and 15/100 ($4,789.15) Dollars. Count I Erie Insurance Exchange v. Chad Mutzabaugh 7. Plaintiff incorporates by reference all of the allegations contained in paragraphs 1 through 6 inclusive of this Complaint as fully as though same were herein and set forth at length. 8. The said occurrence was due to the negligence of the Defendant Chad Mutzabaugh, in that he: a. did fail to have the motor vehicle under proper and adequate control; b. did operate the motor vehicle at an excessive rate of speed; C. did fail to apply the brakes in time to avoid the collision; d. did negligently apply the brakes; e. did fail to operate the vehicle in accordance with existing conditions; f. did fail to drive at a speed and in the manner that would allow him to stop within the assured clear distance ahead; g. did fail to keep a reasonable lookout for other vehicles lawfully on the road; h. did operate the motor vehicle without due regard for the rights, safety and position of the Insured at the point of aforesaid; i. did operate his vehicle without Insurance; j. did fail to maintain financial responsibility; and k. did violate the various statutes and laws of the Commonwealth of Pennsylvania and County of Cumberland pertaining to the operation of motor vehicles. Count II Erie Insurance Exchange v. John Mehasfie 9. Plaintiff, incorporates by reference all of the allegations contained in paragraphs 1 through 8 inclusive of this Complaint as fully as though same were herein and set forth at length. 10. The said occurrence was do to the negligence of the Defendant John Mehasfie, in that he: a. negligently entrusted his vehicle to another operator for use when he knew, or with a reasonable exercise of due care should have known, that the operator was not capable of operating the motor vehicle properly; b. negligently entrusted his motor vehicle to a person which he knew, or in the exercise of reasonable care should have known, was an incompetent driver; C. negligently entrusted his motor vehicle to a person known, should have known or in the exercise of reasonable care would have known, was going to drive the vehicle in an improper, dangerous or reckless manner; and d. negligently entrusted his motor vehicle to another person who he knew, should have known or in the exercise of due care would have known would cause damages to another; e. negligently entrust his motor vehicle to another person who he knew, should have known or in the exercise of due care would have known was an excluded driver; and f. negligently entrust his motor vehicle to a person who did not maintain financial responsibility as required by the laws of the Commonwealth of Pennsylvania. WHEREFORE, Plaintiff demands judgment against the Defendants upon each count in an amount not in excess of Fifty Thousand and 00/100 ($50,000.00) dollars together with costs of suit. 6 1 atz?L Paul F. D'Emilio, Esquire Identification No.: 16654 e-mail address: pauld@demiliolaw.com Paul M. Schofield, Jr., Esquire Identification No.: 81894 e-mail address: pauls@demiliolaw.com 905 W. Sproul Road, Suite 105 Springfield, PA 19064 Telephone No.: 610-338-0338 Fax No.: 610-338-0303 VERIFICATION , Subrogation Representative with Erie Insurance Exchange in the above captioned matter verifies that the facts contained in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Secti4904 relaying to unsworn falsificatigm7to authorities. Ile DATA Subrogation epresentative F 00 3 O O n r-_ C, flo r=0 CD t-0 N £. J7 O --G 00 SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2008-06843 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ERIE INSURANCE EXCHANGE VS MUTZABAUGH CHAD ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: but was unable to locate Him deputized the sheriff of DAUPHIN serve the within COMPLAINT & NOTICE County, Pennsylvania, to On December 16th , 2008 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Dauphin Co unty 74.50 Postage 1.85 113.35 12/16/2008 PAUL D'EMILIO So answe R. Thomas Kl e Sheriff of Cumberland County /x m/off 9- Sworn and subscribe to before me this day of in his bailiwick. He therefore A. D. SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2008-06843 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ERIE INSURANCE EXCHANGE VS MUTZABAUGH CHAD ET AL R. Thomas Kline , duly sworn according to law, say and inquiry for the within named MEHASFIE JOHN but was unable to locate Him deputized the sheriff of DAUPHIN Sheriff or Deputy Sheriff who being that he made a diligent search and DEFENDANT to wit: in his bailiwick. He therefore County, Pennsylvania, to serve the within COMPLAINT & NOTICE On December 16th , 2008 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: So answer- Docketing 6.00 Out of County .00 Surcharge 10.00 R. Thomas Kline( .00 Sheriff of Cumberland County .00 16.00 ? /2i?q ?D n 12/16/2008 PAUL D'EMILIO Sworn and subscribe to before me this day of , A. D. In The Court of Common Pleas of Cumberland County, Pennsylvania Erie Insurance-Exchange vs. Chad Mutzabaugh et al SERVE: Chad Mutzabaugh No. 08-6843 civil Now, November. 20, 2008 hereby deputize the Sheriff of I, SHERIFF OF CUMBERLAND COUNTY, PA, do Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to a and made known to copy of the original So answers, the contents thereof. Sheriff of Sworn and subscribed before one this day of , 20 COSTS SERVICE _ MILEAGE _ AFFIDAVIT 20 , at o'clock M. served the County, PA tlitt u Mary Jane Snder Real Estate Depu William T. Tully Solicitor • Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin ERIE INSURANCE EXCHANGE VS CHAD MUTZABAUGH Sheriff s Return No. 2008-T-2450 OTHER COUNTY NO. 086843 And now: DECEMBER 9, 2008 at 9:44:00 AM served the within COMPLAINT upon CHAD MUTZABAUGH by personally handing to CHAD MUTZABAUGH 1 true attested copy of the original COMPLAINT and making known to him/her the contents thereof at 368 B S. RIVER ROAD HALIFAX PA 17032 Sworn and subscribed to before me this 10TH day of December, 2008 NOTARIAL SEAL ARY JANE SNYDER, Notary Publi Highspire, [Dauphin County M Commission Expires Set 1, 2010 So Answers, Sheriff of in o By Deputy Sheriff Deputy: G MILLER Sheriffs Costs: $74.5 11/26/2008 In The Court of Common Pleas of Cumberland County, P'eniisylvarila Erie Insurance Exchange vs. Chad Mutz'abaugh et al SERVE: John Mehasfie No, 08-6843 civil Now, November 20, 2008 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. f Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to a and made known to _ 20 , at o'clock copy of the original So answers, Sheriff of COSTS Sworn and subscribed before SERVICE me this day of , 20 MILEAGE _ AFFIDAVIT M. served the the contents thereof. County, PA $ C-Otlitt of the ?Sijerfrf Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin ERIE INSURANCE EXCHANGE VS CHAD MUTZABAUGH Sheriff s Return No. 2008-T-2450 OTHER COUNTY NO. 086843 And now: DECEMBER 10, 2008 at 10:14:00 AM served the within COMPLAINT upon JOHN MEHASFIE by personally handing to JOHN MEHASFIE 1 true attested copy of the original COMPLAINT and making known to him/her the contents thereof at DAUPHIN COUNTY SHERIFFS OFFICE FRONT AND MARKET STREETS HARRISBURG PR 17101 DEFENDANTS NEW ADDRESS IS 11 S. ELMER AVE. HARRISBURG, PA Sworn and subscribed to So Answers,! before me this 10TH day of December, 2008 lli? NOTARIAL SEAL ARY JANE SNYDER, Notary Publi Highspire, Dauphin County M Commission Expires Set 1, 2010 Sheriff, of Dauphi County, Pa B Depu Sheriff Deputy: KIMBERLtTO Sheriffs Costs: $74.5 11/26/2008 PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFIELD, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 THIS IS AN ARBITRATION MATTER ATTORNEY FOR PLAINTIFF ERIE INSURANCE EXCHANGE COMMON PLEAS COURT OF AS SUBROGEE OF MARK J. SALTUS CUMBERLAND COUNTY 3410 W. 12T" STREET ERIE, PA 16505 VS. NO. 08-6843 CIVIL TERM CHAD MUTZABAUGH 368 B S. RIVER ROAD HALIFAX, PA 17032 AND JOHN MEHASFIE ; 368 B S. RIVER ROAD CIVIL ACTION HALIFAX. PA 17032 PRAECIPE FOR JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY, C.P.: Enter Judgment in the above entitled matter in-favor of the Plaintiff, Erie Insurance Exchange, and against the Defendants, Chad Mutzabaugh and John Mehasfie, for want of an answer, and assess Plaintiffs damages in the sum of $4,789.15 in accordance with a Complaint filed. 104-1'4-1)a? /PAUL F. 'EMILIO, ESQUIRE ATTORNEY FOR PLAINTIFF ATTORNEY I.D. #16654 Proth ssesses PI ntiffs damages in the sum of $4,789.15. P OTHY PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFIELD, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 THIS IS AN ARBITRATION MATTER ERIE INSURANCE EXCHANGE AS SUBROGEE OF MARK J. SALTUS 3410 W. 12T" STREET ERIE, PA 16505 VS. CHAD MUTZABAUGH 368 B S. RIVER ROAD HALIFAX, PA 17032 AND JOHN MEHASFIE : 368 B S. RIVER ROAD HALIFAX. PA 17032 ATTORNEY FOR PLAINTIFF COMMON PLEAS COURT OF CUMBERLAND COUNTY NO. 08-6843 CIVIL TERM CIVIL ACTION AFFIDAVIT OF LAST KNOWN MAILING ADDRESS OF DEFENDANT AND PLAINTIFF Paul F. D'Emilio, Esquire, attorney for Plaintiff in the above-entitled matter hereby certifies that the following is the last known mailing address of the Defendant and Plaintiff: DEFENDANTS: CHAD MUTZBAUGH AND JOHN MEHASFIE 368 B S. RIVER ROAD 11 S. ELMER AVE. HALIFAX, PA 17032 HARRISBURG, PA 17106 PLAINTIFF: ERIE INSURANCE EXCHANGE 3410 W. 12T" STREET ERIE, PA 16505 PAUL F. D'EMILIO, ESQUIRE ATTORNEY FOR PLAINTIFF PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFIELD, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 THIS IS AN ARBITRATION MATTER ATTORNEY FOR PLAINTIFF ERIE INSURANCE EXCHANGE COMMON PLEAS COURT OF AS SUBROGEE OF MARK J. SALTUS CUMBERLAND COUNTY 3410 W. 12T" STREET ERIE, PA 16505 VS. CHAD MUTZABAUGH 368 B S. RIVER ROAD HALIFAX, PA 17032 AND NO. 08-6843 CIVIL TERM JOHN MEHASFIE 368 B S. RIVER ROAD CIVIL ACTION HALIFAX, PA 17032 AFFIDAVIT AS TO NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF DELAWARE PAUL F. D'EMILIO, being duly sworn according to law, deposes and says that he is the agent for the Plaintiff above-named and is authorized to and does make this Affidavit on its behalf; and that he has knowledge of the facts set forth herein: That Defendants, Chad Mutzabaugh and John Mehasfie, are over twenty-one years of age and that they are not in the military service of the United States or otherwise within the provisions of the Soldier's and Sailor's Civil Relief Act of 1940 as amended. `M'AUL F.-D'EMILIO, ESQUIRE SWORN TO AND SUBSCRIBED BEFORE ME THIS I DAY OF FEBRUARY, 2009. .11.1019.0 MELES e 00FILL, notari-'ubiic Suring Feld Tw ., D-lawar2 County a PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFIELD, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 THIS IS AN ARBITRATION MATTER ATTORNEY FOR PLAINTIFF ERIE INSURANCE EXCHANGE COMMON PLEAS COURT OF AS SUBROGEE OF MARK J. SALTUS CUMBERLAND COUNTY 3410 W. 12T" STREET ERIE, PA 16505 VS. NO. 08-6843 CIVIL TERM CHAD MUTZABAUGH 368 B S. RIVER ROAD HALIFAX, PA 17032 AND JOHN MEHASFIE 368 B S. RIVER ROAD CIVIL ACTION HALIFAX, PA 17032 AFFIDAVIT OF NOTICE OF INTENT TO ENTER DEFAULT JUDGEMENT I, PAUL F. D'EMILIO, ESQUIRE, attorney for the Plaintiff, Erie Insurance Exchange, does hereby certify that a Notice of Intent to Enter Default Judgement was mailed on January 16, 2009 to the Defendant listed below by Certificate of Mailing; a copy of the Notice and the original certification of mailing are attached hereto, made a part hereof, and marked Exhibit "A". Chad Mutzabaugh and John Mehasfie 368 B S. River Road 11 S. Elmer Avenue Halifax, PA 17032 Harrisburg, PA 17106 AESQUIRE REY FOR PLAINTIFF PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFIELD, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 THIS IS AN ARBITRATION MATTER ATTORNEY FOR PLAINTIFF ERIE INSURANCE EXCHANGE COMMON PLEAS COURT OF AS SUBROGEE OF MARK J. SALTUS CUMBERLAND COUNTY VS. NO. 08-6843 CIVIL TERM CHAD MUTZABAUGH AND JOHN MEHASFIE CIVIL ACTION DATE OF NOTICE: JANUARY 16, 2009 TO: CHAD MUTZABAUGH 368 B S. RIVER ROAD HALIFAX, PA 17032 NOTICE OF INTENT TO ENTER DEFAULT JUDGMENT 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 (10) 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. LAWYER REFERRAL SERVICE FOR CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 PAUL F. D'EMILIO, ESQUIRE 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFIELD, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 THIS IS AN ARBITRATION MATTER ATTORNEY FOR PLAINTIFF ERIE INSURANCE EXCHANGE COMMON PLEAS COURT OF AS SUBROGEE OF MARK J. SALTUS CUMBERLAND COUNTY VS. NO. 08-6843 CIVIL TERM CHAD MUTZABAUGH AND JOHN MEHASFIE CIVIL ACTION DATE OF NOTICE: JANUARY 16, 2009 TO: JOHN MEHASFIE 11 S. ELMER AVE. HARRISBURG, PA 17106 NOTICE OF INTENT TO ENTER DEFAULT JUDGMENT 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 (10) 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. LAWYER REFERRAL SERVICE FOR CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 PAUL F. D'EMILIO, 5S QUIRE 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 16 '1 PROVI W16,.*1 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY Br r LAW OI'I=ICI= Re PAUL F. D'EMILIO 905 WEST SPROUL ROAD, SUITE 105 p ?ASL_ER SPRINGFIELD, PENNSYLVANI `a T _y v ?. One piece of ordinary mail addressed to: C. a Chad Mutzabaugh Icy A 368 B S. River Road G ifax PA 17032 s US POSTAGE! PS Form 3577, January 2001 U.S. POSTAL SERVICE CERTIFICATE OF MAILING w PF LAW OFFICE PAUL F. D'EMILIO "R5 905 WEST SPROUL ROAD, SUITE 105, HASL.ER SPRINGFIELD, PENNSYLVANIA I9 IELD d QQ` ba ? • r _y N One piece of ordinary mail addressed to: ?6f _D C? p c0 I(a John ehasfie 11 S. Elmer Ave. 'd gb Harri Ghiirga PA 17106 US POS'TAGEI PS Form 3517, January 2001 44- WE 90 g t? N c:a _.ri C;J w 22 22 Lv r7 rn il?? IN THE COURT OF COMMON PLEAS OF BUCKS COUNTY, PENNSYLVANIA CIVIL ACTION- LAW (Rule of Civil Procedure No. 236) ERIE INSURANCE EXCHANGE COMMON PLEAS COURT OF AS SUBROGEE OF MARK J. SALTUS CUMBERLAND COUNTY 3410 W. 12TH STREET ERIE, PA 16505 . NO. 08-6843 CIVIL TERM VS. . CHAD MUTZABAUGH 368 B S. RIVER ROAD HALIFAX, PA 17032 AND JOHN MEHASFIE . 368 B S. RIVER ROAD CIVIL ACTION HALIFAX. PA 17032 Notice is given that a judgment in the above captioned matter has been entered against you on deb ISt' , 2009. P thonota If you have any questions concerning the above please contact: Paul F. D'Emilio. Esauire Attorney or Party Filing 905 West Sproul Road, Suite 105 Address Springfield, PA 19064 City, State, Zip (610) 338-0338 Telephone Number