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HomeMy WebLinkAbout09-3887 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ERIE INSURANCE EXCHANGE, ) CIVIL DIVISION, ARBITRATION subrogee of CORBINS AUTOMOTIVE ) AND STATUTORY APPEALS ONLY PAINT AND REPAIR and ) BARBARA ANN CORBINS, ) NO.: CQ - 388 7 0,wo-bro, ISSUE NO. Plaintiff, ) TYPE OF PLEADING: Complaint in Civil Action vs. ) STEVEN EBERLY and ) RUSSELL MOORE, ) CODE: Defendants. ) FILED ON BEHALF OF: Plaintiff, Erie Insurance Exchange, subrogee of Corbins Automotive Paint and Repair and Barbara Ann Corbins COUNSEL OF RECORD FOR THIS PARTY: Reed J. Davis Pa. I.D. #00501 jdQddgpc.com DAVIS DAVIS ATTORNEYS a professional corporation 383 Vanadium Road, Suite 300 Pittsburgh, PA 15243 412-344-0400 F:\DOCS\21151\090047\09060801.COM lad IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ERIE INSURANCE EXCHANGE, subrogee of CORBINS AUTOMOTIVE PAINT AND REPAIR and BARBARA ANN CORBINS, CIVIL DIVISION, ARBITRATION AND STATUTORY APPEALS ONLY Plaintiff VS. STEVEN EBERLY and RUSSELL MOORE, Defendants. 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 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ERIE INSURANCE EXCHANGE, subrogee of CORBINS AUTOMOTIVE PAINT AND REPAIR and BARBARA ANN CORBINS, Plaintiff CIVIL DIVISION, ARBITRATION AND STATUTORY APPEALS ONLY P - No.: O 5'- 3 51"1 VS. STEVEN EBERLY and RUSSELL MOORE, Defendants. COMPLAINT IN CIVIL ACTION AND NOW comes the Plaintiff, Erie Insurance Exchange, subrogee of Corbin Automotive Paint and Repair and Barbara Ann Corbins, by and through its counsel, Davis Davis Attorneys, a professional corporation, and Reed J. Davis, Esquire, and makes this Complaint against the named Defendants as follows: 1. Plaintiff is a corporation duly authorized to do business in the Commonwealth of Pennsylvania and has and maintains one of its offices at 307 South Sporting Hill Road, Mechanicsburg, Pennsylvania 17050-9338; hereinafter "Erie." 2. Corbins Automotive Paint and Repair is or was a business entity solely owned and operated by Barbara Ann Corbins, both of whom have a last known address of 40 Oak Knoll Estates, Elizabethtown, Pennsylvania 17022 and are hereinafter collectively referred to as "Corbin." 3. Defendants are as follows: a. Steven Eberly ("Eberly") is an individual whose last known address is 7 Vicksburg Court, Mechanicburg, Pennsylvania 17050. b. Russell Moore ("Moore") is an individual whose last known address is 122 Creekside Drive, Enola, Pennsylvania 17025. The Defendants are collectively referred to as "Defendants." 4. At all times relevant to the within action, Corbins was the owner of a 1999 Ford E-150 Club Wagon bearing the serial number 1FMRE11 W5XHB86322. 5. At all times pertinent hereto the said Corbins maintained insurance on the vehicle, which insurance was provided by Erie, the Plaintiff herein. 6. At all times pertinent hereto, the Defendant Eberly was the owner of a 1996 Ford F250 vehicle, which was being operated by the Defendant Moore, the agent, servant, and employee of Eberly. 7. On or about February 12, 2008, at or about 12:45 P.M., Corbins vehicle was being operated by John Corbins at or about 332 Ridge Hill Road in Mechanicburg, Pennsylvania, in a careful and lawful manner. 8. At the same time and place, the Defendant Moore was operating the Eberly vehicle in the opposite direction of the Corbins vehicle when the vehicle veered across the center line and struck the Eberly vehicle causing severe damage, resulting in the total loss of the vehicle. 9. The collision, aforesaid, was caused solely by the careless, reckless, negligent, improper and unlawful action of Moore and through Morre by Eberly resulting in total loss of the vehicle, which had a value of $7,681.29 less salvage of $1,580.00 for a net loss of $6,101.29. 10. Eberly had negligently entrusted his vehicle to Moore who had no valid drivers license when he knew or should have known that it was unlawful to have Moore operate the vehicle and that there would be no insurance coverage on the vehicle as required under the Pennsylvania Motor Vehicle Financial Responsibility Act. 11. Under the terms of the insurance policy and by operation of law, Plaintiff is subrogated to the rights of its insured, Corbins, against the Defendants. WHEREFORE, Plaintiff Erie Insurance Exchange, subrogee of Corbins Automotive Paint and Repair and Barbara Ann Corbins, claims damages of the Defendants and each of them jointly and severally in the amount of $6,101.29 with costs of suit. DAVIS DAVIS ATTORNEYS a profes ' corpora By: Rep. Da-; squire PA I.D. #00501 Attorney for Plaintiff 393 Vanadium Road, Suite 300 Pittsburgh, PA 15243 (412) 344-0400 jd&ddapc.com VERIFICATION I, Reed J. Davis, Esquire, state that I am not a party to the action but that at the request of the Plaintiff, and based upon knowledge, information, records, and documents supplied to me by the Plaintiff, the averments set forth in the foregoing Complaint are true. A Verification executed by Plaintiff can be supplied at time of trial or upon request. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unworn falsification to authorities. 0 OF THE PMT' 2009 UN I I PM 1: 19 PE.;dPeSYLYA IA *q8.5D PO A-M ao 5q(o q3 R."T* aalo &CO Sheriffs Office of Cumberland County R Thomas Kline ,,I, ofar?rrt? y f Edward L Schorpp Sheriff ?1d Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE ' Civil Process Sergeant Erie Insurance Exchange Case Number vs. Steven Eberly 2009-3887 SHERIFF'S RETURN OF SERVICE 06/23/2009 08:55 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on June 23, 2009 at 2055 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Steven Eberly, by making known unto himself personally, defendant at 7 Vicksburg Court Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. 06/26/2009 04:00 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Russell Moore, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Russell Moore. Angel Moyer current resident of 122 Creekside Drive Enola, PA 17025 states the defendant does not live at the address anymore. The Enola Postmaster has advised the defendant is not known at address. An exact address is not available. SHERIFF COST: $71.50 June 26, 2009 SO ANSWERS, 00 R THOMAS KLINE, SHERIFF 2yy Sherif Cl) C N -D C- MM o Y c co J . s 110 GG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY-, PENNSYLVANIA ERIE INSURANCE EXCHANGE, subrogee of CORBINS AUTOMOTIVE PAINT AND REPAIR and BARBARA ANN CORBINS, Plaintiff, CIVIL DIVISION, ARBITRATION AND STATUTORY APPEALS ONLY NO.. CQ - C' W;1 Ierw ISSUE NO. TYPE OF PLEADING: Complaint in Civil Action VS. STEVEN EBERLY and RUSSELL MOORE, CODE: Defendants F:\DOCS\21151\090047\09060801.COM lad FILED ON BEHALF OF: Plaintiff, Erie Insurance Exchange, subrogee of Corbins Automotive Paint and Repair and Barbara Ann Corbins COUNSEL OF RECORD FOR THIS PARTY: Reed J. Davis Pa. I.D. #00501 rid&dd4pc.com DAVIS DAVIS ATTORNEYS a professional corporation 383 Vanadium Road, Suite 300 Pittsburgh, PA 15243 412-344-0400 MWE COPY MONO RECORD In Totiy whereof, I here unto set ray twd 08 of said WLi at Catk,. e, Nf 1, y? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ERIE INSURANCE EXCHANGE, subrogee of CORBINS AUTOMOTIVE PAINT AND REPAIR and BARBARA ANN CORBINS, CIVIL DIVISION, .ARBITRATION AND STATUTORY APPEALS ONLY Plaintiff vs. STEVEN EBERLY and RUSSELL MOORE, Defendants 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 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNT.', PENNSYLVANIA ERIE INSURANCE EXCHANGE, subrogee of CORBINS AUTOMOTIVE PAINT AND REPAIR and BARBARA ANN CORBINS, CIVIL DIVISION, ARBITRATION AND STATUTORY APPEALS ONLY Plaintiff VS. STEVEN EBERLY and RUSSELL MOORE, Defendants. No.. COMPLAINT IN CIVIL ACTION AND NOW comes the Plaintiff, Erie Insurance Exchange, subrogee of Corbins Automotive Paint and Repair and Barbara Ann Corbins, by and through its counsel, Davis Davis Attorneys, a professional corporation, and Reed J. Davis, Esquire, and makes this Complaint against the named Defendants as follows: Plaintiff is a corporation duly authorized to do business in the Commonwealth of Pennsylvania and has and maintains one of its offices at 307 South Sporting Hill Road, Mechanicsburg, Pennsylvania 17050-9338; hereinafter "Erie." 2. Corbins Automotive Paint and Repair is or was a business entity solely owned and operated by Barbara Ann Corbins, both of whom have a last known address of 40 Oak Knoll Estates, Elizabethtown, Pennsylvania 17022 and are hereinafter collectively referred to as "Corbins." 3. Defendants are as follows: a. Steven Eberly ("Eberly") is an individual whose last known address is 7 Vicksburg Court, Mechanicburg, Pennsylvania 17050. b. Russell Moore ("Moore") is an individual whose last known address is 122 Creekside Drive, Enola, Pennsylvania 17025. The Defendants are collectively referred to as "Defendants." 4. At all times relevant to the within action, Corbins was the owner of a 1999 Ford E-150 Club Wagon bearing the serial number 1FMRE11W5XHB86322. 5. At all times pertinent hereto the said Corbins maintained insurance on the vehicle, which insurance was provided by Erie, the Plaintiff herein. 6. At all times pertinent hereto, the Defendant Eberly was the owner of a 1996 Ford F250 vehicle, which was being operated by the Defendant Moore, the agent, servant, and employee of Eberly. 7. On or about February 12, 2008, at or about 12:45 P.M., Corbins vehicle was being operated by John Corbins at or about 332 Ridge Hill Road in Mechanicburg, Pennsylvania, in a careful and lawful manner. 8. At the same time and place, the Defendant Moore was operating the Eberly vehicle in the opposite direction of the Corbins vehicle when the vehicle veered across the center line and struck the Eberly vehicle causing severe damage, resulting in the total loss of the vehicle. 9. The collision, aforesaid, was caused solely by the careless, reckless, negligent, improper and unlawful action of Moore and through Morre by Eberly resulting in total loss of the vehicle, which had a value of $7,681.29 less salvage of $1,580.00 for a net loss of $6,101.29. 10. Eberly had negligently entrusted his vehicle to Moore who had no valid drivers license when he knew or should have known that it was unlawful to have Moore operate the vehicle and that there would be no insurance coverage on the vehicle as required under the Pennsylvania Motor Vehicle Financial Responsibility Act. 11. Under the terms of the insurance policy and by operation of law, Plaintiff is subrogated to the rights of its insured, Corbins, against the Defendants. WHEREFORE, Plaintiff Erie Insurance Exchange, subrogee of Corbins Automotive Paint and Repair and Barbara Ann Corbins, claims damages of the Defendants and each of them jointly and severally in the amount of $6,101.29 with costs of suit. DAVIS DAVIS ATTORNEYS a proles ' corpora 'o By: Re W. Davis' squire PA I.D. #00501 Attorney for Plaintiff 393 Vanadium Road, Suite 300 Pittsburgh, PA 15243 (412) 344-0400 rjd(a,ddapc.com VERIFICATION I, Reed J. Davis, Esquire, state that I am not a party to the action but that at the request of the Plaintiff, and based upon knowledge, information, records, and documents supplied to me by the Plaintiff, the averments set forth in the foregoing Complaint are true. A Verification executed by Plaintiff can be supplied at time of trial or upon request. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ERIE INSURANCE EXCHANGE, subrogee of CORBINS AUTOMOTIVE PAINT AND REPAIR and BARBARA ANN CORBINS, CIVIL DIVISION, ARBITRATION AND STATUTORY APPEALS ONLY NO.: 09-3887 Civil Plaintiff, VS. STEVEN EBERLY and RUSSELL MOORE, Defendants ISSUE NO. TYPE OF PLEADING: Motion for Substitute Service Pursuant to Pa. R.C.P. No. 430 CODE: FILED ON BEHALF OF: Plaintiff, Erie Insurance Exchange, subrogee of Corbins Automotive Paint and Repair and Barbara Ann Corbins COUNSEL OF RECORD FOR THIS PARTY: Reed J. Davis Pa. I.D. #00501 DAVIS DAVIS ATTORNEYS a professional corporation 393 Vanadium Road Suite 300 Pittsburgh, PA 15243 412-489-1400 F:\DOCS\21151\090047\09070202.SubSvc ]ad IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ERIE INSURANCE EXCHANGE, subrogee of CORBINS AUTOMOTIVE PAINT AND REPAIR and BARBARA ANN CORBINS, CIVIL DIVISION, ARBITRATION, AND STATUTORY APPEALS ONLY NO.: 09-3887 Civil Plaintiff, vs. STEVEN EBERLY and RUSSELL MOORE, Defendants. MOTION FOR SUBSTITUTED SERVICE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 430 AND NOW, comes the Plaintiff, Erie Insurance Exchange, subrogee of Corbins Automotive Paint and Repair and Barbara Ann Corbins, by and through their attorneys, Davis Davis Attorneys, a professional corporation, and hereby moves the Court for substitute service pursuant to Pennsylvania Rule of Civil Procedure 430 and in support thereof avers as follows: 1. On or about June 11, 2009, Plaintiff filed a Complaint in Civil Action against the Defendants, Steven Eberly and Russell Moore, hereinafter referred to as "Defendants" at the above-captioned term and number. 2. The last known address of the Defendant, Russell Moore, is 122 Creekside Drive, Enola PA 17025. 3. Pennsylvania Rule of Civil Procedure 430(a) permits original process to be served by having the sheriff hand a copy to the defendant or hand a copy to an adult member of the family or an adult person in charge of the residence of the defendant. 4. A true and correct copy of the Complaint in Civil Action was sent to the Sheriff of Cumberland County for service on the Defendant, Russell Moore, at the address of 122 Creekside Drive, Enola PA 17025, to serve the same in accordance with Pennsylvania Rule of Civil Procedure 402. 5. A sheriff s return was received stating "not found." A true and correct copy of said Sheriff s Return is marked Exhibit "A," attached hereto and made a part hereof. 6. Plaintiff was advised by United States Postal Authorities that the Defendant, Russell Moore, receives mail at the address of 122 Creekside Drive, Enola PA 17025 and that no change of address order is on file. A true and correct copy of said Postmaster letter is marked as Exhibit "B," attached hereto and made a part hereof. g 7. Plaintiff was advised by LexisNexis that the Defendant, Russell Moore, resides at the address of 122 Creekside Drive, Enola PA 17025. A true and correct copy of said LexisNexis report is marked as Exhibit "C," attached hereto and made a part hereof. To date, the Plaintiff has been unable to effect service on the Defendant, Russell Moore. WHEREFORE, Plaintiff respectfully requests this Court to enter an order authorizing service of the Complaint in Civil Action on the Defendant, Russell Moore, by Plaintiffs counsel mailing by Certified Mail, Return Receipt Requested and by regular United States Mail using Post Office Form 3817, Certificate of Mailing, to the Defendant's last known address of 122 Creekside Drive, Enola PA 17025. DAVIS DAVIS ATTORNEYS a professi nal corporation By: e . Davis Attorneys for the Plaintiff 393 Vanadium Road Suite 300 Pittsburgh, PA 15243 (412) 489-1400 Sh-iff s Office of Cumberland Cou..,.cy R Thomas Kline , of t ?FS,rrt. Edward L Schorpp Solicitor Sheriff Ronny R Anderson Jody S Smith Chief Deputy OFHCE F' ` 6trR1Fr Civil Process Sergeant Erie Insurance Exchange I Case Number vs. 2009-3887 Steven Eberly SHERIFF'S RETURN OF SERVICE 06/23/2009 08:55 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on June 23, 2009 at 2055 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Steven Eberly, by making known unto himself personally, defendant at 7 Vicksburg Court Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. 06/26/2009 04:00 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Russell Moore, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Russell Moore. Angel Moyer current resident of 122 Creekside Drive Enola, PA 17025 states the defendant does not live at the address anymore. The Enola Postmaster has advised the defendant is not known at address. An exact address is not available. SHERIFF COST: $71.50 SO ANSWERS, June 26, 2009 R THOMAS KLINE, SHERIFF eputy S erif June 8, 2009 POSTMASTER Enola PA 17025 Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a boxholder) for the following: Name: Russell L. Moore a/k/a Address: 122 Creekside Drive. Enola PA 17025 NOTE: The name and last known address are required for change of address information. The name, if known, and the post office box address post required for boxholder information. The following information is provided in accordance with 39 CFR 265.6 (d))(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manuel 352.44a and b. 1. Capacity of requester (e.g., process service, attorney, party representing himself): Paraleaa_I 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se - except a corporation acting pro se must cite statute): NA 3. The names of all knowing parties to the litigation : Erie Insurance Exchange, subrogee of Corbins Automotive Paint and Repair and Barbara Ann Corbin vs. Steven Eberly and Russell Moore. 4. The court in which the case has been or will be heard: Common Pleas of Cumberland County. Pennsvlvania. 5. The docket or other identifying number if one has been issued:. 6. The capacity in which this individual is to be served (e.g. defendant or witness): defendant. WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRDIINAL PENALTIES INCLUDING A FINE OF UP TO $10,000.00 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). I certify that the above information is true and that the address information is needed and must be used solely for service of legal process in connection with actual or prospective litigation. DAVIS DAVIS ATTORNEYS 393 Vanadium Road, Suite 300 Pittsburgh, PA 15243-1478 X FOR POST OFFICE USE ONLY AD?DR? OR BOXHOLDER'S POSTMARK Receives mail at address given. Not known at address given. Moved, left no forwarding address. No such address. Forwarding order expired. Forwarding order address: F:\DOCS\21151\090047\09060802.POV lad CURRENT NAME AND STREET ADDRESS PHYSICAL ADDRESS PLEASE *Any additional information to assist in locating addressee: ??X64 I.-B+, Results a View: Results List I Full Visual Report 1 of 9 NEXT Search: Public Records > Comprehensive Person Report Search 11 > Search Results > Person Report Request Terms: first-name(russell) last-name(moore) city(enola) state(PA) radius(30) ( Edit Search I New Search ) Report Contents Page 1 of 5 Save as Alert Select for Delivery FOR INFORMATIONAL PURPOSES ONLY Top of Report Copyright 2009 LexisNexis Subject Summary a division of Reed Elsevier Inc. All Rights Reserved. Others Using SSN Full Name Address County Phone Address Summary (8) MOORE, RUSSELL L 122 CREEKSIDE DR CUMBERLAND None Listed ENOLA, PA 17025-2917 Voter Registrations Driver Licenses ADDITIONAL PERSONAL INFORMATION Professional Licenses _ SSN DOB Gender Health Care Providers 203-64-XXXX 4/1968 Health Care Sanctions Pennsylvan,d: 1985-1987) (Age: 41 Pilot Licenses Subject Summary Sport Licenses Name Variations Vlew_Ail Name Variations Source..s. Weapon Permits Real Property Assets 1: MOORE, RUSS Motor Vehicle Registrations 2: MOORS, RUSSELL 3: MOORE, RUSSELL L Boats Aircraft SSNs Summary View All SSN Sources Bankruptcy Information No. SSN State Iss. Date Iss. Warnings Jud?m_e..n_.ts/LienS_(1_). Most frequent SSN at tributed to subject: UCC Liens is 203-64-XXXX Pennsylvania 1985-1987 Potential Relatives (3) DOGS View All DOB Sources Business Associates Person Associates Reported DOSS: NeighborsJl0), 4/1968 Employment Locator Sources _(0.) Address Summary - 8 records found for subject. View All Address Variations Sources No, Address Actions Further Searches 1; 122 CREEKSIDE DR Get Report Health Care Providers _. _ ENOLA, PA 17025-2917 Health Care Provider CUMBERLAND COUNTY View Details 2: 505 3RD ST APT 3 Get Report Sanctions ? ENOLA, PA 17025-3133 Patriot Act CUMBERLAND COUNTY View Details Marriage and DIVOrCeS 3: .1911 CHATHAM DR Get Report __ CAMP HILL, PA 17011-5917 Foreclosure Activity 'CUMBERLAND COUNTY View Details Status Report 4: 403 2ND ST Get Report ENOLA, PA 17025-3113 Real Property.. Voluntary CUMBERLAND COUNTY View Details Lien Transaction Report, 5: 403 HIGH ST Get Report ENOLA, PA 17025-3104 $ CUMBERLAND COUNTY View Details 6: 225 HERMAN AVE APT 2ND Get Report LEMOYNE, PA 17043-1938 CUMBERLAND COUNTY View Details 7: 1497 SIMPSON FERRY RD Get Report NEW CUMBERLAND, PA 17070-1572 CUMBERLAND COUNTY View Details 8: 164 S 2ND ST Get Report STEELTON, PA 17113-2503 DAUPHIN COUNTY View Details Address Details 1: 122 CREEKSIDE DR ENOLA, PA 17025-2917 Address Dates Phone Actions 122 CREEKSIDE DR 5/2009 Get Report ENOLA, PA 17025-2917 CUMBERLAND COUNTY Neighbors 10 .? Census Data for Geographical Region P ?( Ibl Median Head of Household Age: 37 https://r3.lexis.comllexispnnalReportResults.aspx?docID=1 &nextReportDocID=2&previousReportDocID... 6/6/2009 AFFIDAVIT COMMONWEALTH OF ) PENNSYLVANIA ) SS: COUNTY OF ALLEGHENY ) Before me the undersigned authority, a Notary Public in and for said county and State, personally appeared Reed J. Davis, who being duly sworn according to law, deposes and says that, pursuant to Pennsylvania Rule of Civil Procedure 402, he was informed that the Sheriff of Cumberland County was unable to personally serve the Complaint upon the Defendant, Russell Moore, at his last known address of 122 Creekside Drive, Enola PA 17025 as evidenced on the Sheriffs Return. A true and correct copy of the Sheriffs Return is attached to the Motion as Exhibit "A." He further deposes and says that he was informed by the United States Post office and LexisNexis that the Defendant receives mail and resides at the address. A true and correct copy of the Post Office Letter and LexisNexis report are marked as "Exhibit "B" and "C" respectively and also attached to the Motion. Reed J. Davis Sworn to and subscribed before me rw this day of July, 2009. FILL r OF THE u t`(?"rV ,y JU- - o 4. 2009 a r ti IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ERIE INSURANCE EXCHANGE, subrogee of CORBINS AUTOMOTIVE PAINT AND REPAIR and BARBARA ANN CORBINS, CIVIL DIVISION, ARBITRATION AND STATUTORY APPEALS ONLY NO.: 09-3887 Civil Plaintiff, vs. STEVEN EBERLY and RUSSELL MOORE, Defendants. ISSUE NO. TYPE OF PLEADING: Praecipe to Settle and Discontinue with Prejudice CODE: FILED ON BEHALF OF: Plaintiff, Erie Insurance Exchange, subrogee of Corbin Automotive Paint and Repair and Barbara Ann Corbins COUNSEL OF RECORD FOR THIS PARTY: Reed J. Davis Pa. I.D. #00501 DAVIS DAVIS ATTORNEYS a professional corporation 393 Vanadium Road Suite 300 Pittsburgh, PA 15243 412-489-1400 F:\DOCS\21151\090047\09070901.5&D lad IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ERIE INSURANCE EXCHANGE, subrogee of CORBINS AUTOMOTIVE PAINT AND REPAIR and BARBARA ANN CORBINS, CIVIL DIVISION, ARBITRATION AND STATUTORY APPEALS ONLY NO.: 09-3887 Civil Plaintiff, vs. STEVEN EBERLY and RUSSELL MOORE, Defendants. PRAECIPE TO SETTLE AND DISCONTINUE WITH PREJUDICE TO: Prothonotary SIR: Please settle and discontinue the above-captioned action with prejudice as to the Defendants, Steven Eberly and Russell Moore, and mark the docket accordingly. DAVIS DAVIS ATTORNEYS a professional corporation By: Sworn to and subscribed before me Attorney fof'Plaintiff 393 Vanadium Road Suite 300 Pittsburgh, PA 15243 412-489-1400 this_f-day of Jam, 2009 4GI" t44k Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Rebecca Wakroha, Notary Public Scott Twp., Allegheny County My Cornmisdon Expires Jan. 9, 2012 Member, Pennsylvania Associabon of Notaries X099 J U L 13 i '1 3: 2 i i E?