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HomeMy WebLinkAbout09-5798IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JANICE ROGERS and BERNARD ROGERS, wife and husband, residing at 196 Edinburgh Road, Summerville, Dorchester County, South Carolina 29483, vs. Plaintiff JEFFREY KERCH, an individual residing at 1007 Armstrong Road, Carlisle, Cumberland County, Pennsylvania 17013: Defendant No. !07- -C L' L ?fJLr? Civil Action - ( X) Law ( ) Equity PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue writ of summons in the above-captioned action. X Writ of Summons shall be issued and forwarded to ( ) Attorney ( X ) Sheriff David W. Knauer David W. Knauer, P.C. 411-A East Main Street Mechanicsbura, PA 17055 (717) 795-7790 Names/Address/Telephone No. of Attorney ure-df mey Supreme Court ID No. 21582 Date: WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YO?4:r:o7&th ry Dater I :ZC By: Deputy ( ) Check here if reverse is issued for additional information PROTHON. - 55 2009 AUG 21 PM 3: 12 PENNSYLVANIA P7e. so P,4_ ccid I no R -A ;Z a f4l ? 4 , Sheriffs Office of Cumberland County R Thomas Kline Sheriff ??artiir dt ?u,r,Grrr??4 r Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor 2009 S E P - I A '11, Oa, 41 I', 1.117 _ ,i..r I ;\( r? Janice Rogers vs. Jeffrey Kerch Case Number 2009-5798 SHERIFF'S RETURN OF SERVICE 08/31/2009 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: Jeffrey Kerch, but was unable to locate him in his bailiwick. He therefore returns the within Writ of Summons as not found as to the defendant Jeffrey Kerch. The defendant's father advised Deputy's that Jeffrey Kerch had moved to Washington, DC over a year ago. An exact address is not available. SHERIFF COST: $38.84 SO ANSWERS, August 31, 2009 R THOMAS KLINE, SHERIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JANICE ROGERS and BERNARD ROGERS, wife and husband, residing at 196 Edinburgh Road, Summerville, No. 04 S'2929 Dorchester County, South Carolina 29483, : Plaintiff Civil Action - ( X) Law vs. ( ) Equity JEFFREY KERCH, an individual residing o at 1007 Armstrong Road, Carlisle, Cumberland County, Pennsylvania 17013: { Defendant cr. PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: %' Please issue writ of summons in the above-captioned action. _X_ Writ of Summons shall be issued and forwarded to ( ) Attorney ( X) Sheriff David W. Knauer - / David W. Knauer. P.C. r 411-A East Main Street ignature rney Mechanicsburg, PA 17055 (717) 795-7790 Supreme Court ID No. 21582 Names/AddresslTelephone No. of Attorney Date: WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. Date: QLe rothonota By: Deputy ( ) Check here if reverse is issued for additional information PROTHON. - 55 In Unto set my hand' antii 2 :eaf : ,,± art at Carlisle, Pa. C?......., This .40.-S.t d aye oirothonotary IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JANICE ROGERS, et vir., No. 09-7943 Plaintiffs Civil Action vs JEFFREY KERCH, Defendant MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT 1. The Plaintiffs commenced the above action by Praecipe for Writ of Summons on August 21, 2009 and on the same day the Prothonotary issued the Writ of Summons. The Plaintiff marks as Exhibit "A", attaches hereto and incorporates herein by reference thereto a true and correct copy of the Praecipe of Writ of Summons. 2. Plaintiff promptly delivered the Praecipe for Writ of Summons and the Writ of Summons to the Sheriff of Cumberland County and listed the Defendant's last known address as 1007 Armstrong Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. On August 31, 2009, the Sheriff of Cumberland County attempted to serve the aforesaid Praecipe for Writ of Summons and Writ of Summons on the Defendant at the aforesaid address. 4. The Sheriff of Cumberland County returned not found stating inter alia that: 1 I' "R. Thomas Line, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Jeffrey Kerch. The defendant's father advised Deputy's that Jeffrey Kerch had moved to Washington, DC over a year ago. An exact address is not available." The Plaintiff marks as Exhibit "B", attaches hereto and incorporates herein by reference thereto a true and correct copy of the Praecipe for Writ of Summons. 5. Based on the foregoing, Pa.R.C.P. No. 404 providing for "Service Outside the Commonwealth" is the governing rule that provides for service within ninety days and subsection "3" of the aforesaid rule provides that service may be made "in the manner provided by the law of the jurisdiction in which service is made for service in any action in any of its courts of general jurisdiction". 6. As more fully set forth in the Affidavit of Counsel attached hereto, the Plaintiffs' counsel has made a good faith attempt to locate the Defendant including a search of the records available in Cumberland County, through the internet White Pages through Intelius and by contact with the Erie Insurance Company adjuster assigned to the above case. Despite the Plaintiffs' counsel's good faith effort he has been unable to locate the Defendant. The Plaintiff marks as Exhibit "C", attaches hereto and incorporates herein by reference thereto a true and correct copy of the Intelius internet search. 7. On November 6, 2009, Plaintiff's counsel personally went to the Cumberland County Bureau of Elections and obtained a copy of that office's two pages of records with respect to the above Defendant. The first page states that on January 15, 2009, the said office cancelled the Defendant's Cumberland County registration on the basis that it had received "Confirmed Registered Out of State" registration and the second page was a form the Defendant completed stating that the Defendant is "registered to vote at another address in Virginia or in another state". The Plaintiff marks as Exhibit "D", attaches hereto and incorporates herein by reference thereto a true and correct copy of the Cumberland County Bureau of Elections records, 8. Based on the Sheriff of Cumberland County's and Plaintiffs' counsel's unsuccessful attempts to locate the Defendant, the Plaintiffs request a special order of service pursuant to Pa.R.C.P. No. 430. 9. Based on the information the Defendant's father provided to the Sheriff of Cumberland County that the Defendant had moved to Washington, DC, the Plaintiffs believe that the courts of general jurisdiction of the District of Columbia provide for service by publication. The Plaintiff marks as Exhibit "E", attaches hereto and incorporates herein by reference thereto a true and correct copy of Superior Court Rule--Civil (SCR-Civil) Rule 4-1 that provides for service by publication. 10. On November 6, 2009, the Plaintiff's counsel contacted the Commonwealth of Virginia's statewide election bureau and was told that Virginia law did not permit that office to provide any information on the voters registered in Virginia. 11. The Plaintiff marks as Exhibit "F", attaches hereto and incorporates herein by reference thereto the Affidavit of her undersigned counsel detailing the good faith efforts the Plaintiff made in attempting to obtain the Defendant's out of state address. 12. The Defendant's automobile insurer, Erie Insurance Company, has coverage for the above action and acknowledged the Defendant's liability for the vehicular accident. Further, it has already paid for the repair of the Plaintiff's vehicle. 13. Based on the foregoing, the Plaintiff requests that any order for publication be based on the District of Columbia's rules because the voter registration form noting that the Defendant was registered "in Virginia or in another state" is too vague to determine in which state notice should be published. However, utilizing the information that the Defendant's father provided to the Sheriff of Cumberland County that the Defendant had moved to the District of Columbia coupled with the notice that the Defendant was registered in Virginia or another state makes it likely that the Defendant is residing in the metropolitan Washington in its Virginia or other states suburbs and the publication in a newspaper of general circulation in that metropolitan area is most likely to give the Defendant notice of the institution of the above aciton. 14. On November 9, 2009, on the Plaintiff's Praecipe to Reissue Writ of Summons, the Prothonotary reissued the writ in the above matter. The Plaintiff marks as Exhibit "F", attaches hereto and incorporates herein by reference thereto true and correct copies of the Praecipe to Reissue Writ of Summons and the reissued Writ of Summons. 15. Although the Defendant's father did not provide the Sheriff of Cumberland County with he Defendants address, the Plaintiff believes that it would also be worthwhile to send a copy of any Order issued via first class mail with a Certificate of Mailing (PS Form 3817, Mar. 1989) in the hope that the Defendant's father would forward same to the Defendant 16. Prior to filing this motion, no judge has been involved in the above action. WHEREFORE, the Plaintiffs pray that Your Honorable Court will issue a special rule of service directing that the Plaintiff serve at the Plaintiff's last known address by United States first class mail with a Certificate of Mailing (PS Form 3817, Mar. 1989) a true and correct copy of the pleadings heretofore filed and this motion and to publish notice to the Defendant of the above action one time in the legal newspaper for the District of Columbia and one time in a paper of general circulation in the District of Columbia. Date: Respectfully submitted, K?NAUER & ASSOCIATES, L.S.C. avid W. Kna er, Esquire Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 Knauer@early.com (717) 795-7790 FAX: (717) 795-7793 , 1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JANICE ROGERS and BERNARD ROGERS, wife and husband, residing at 196 Edinburgh Road, Summerville, No.69-S4'25 2004 Dorchester County, South Carolina 29483, Plaintiff VS. JEFFREY KERCH, an individual residing at 1007 Armstrong Road, Carlisle, Cumberland County, Pennsylvania 17013: Defendant Civil Action - (X) Law ( ) Equit)P tD- rT . G" M F: ?- -,j M < t 0 . L : -7 f1 x' C c.? J rr? _ PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue writ of summons in the above-captioned action. ,X+ Writ of Summons shall be issued and forwarded to ( ) Attorney ( X ) Sheriff David W. Knauer David W. Knauer, P.C. 411-A East Main Street Signature of A or ey Mechanicsburg, PA 17055 (717) 795-7790 Names/Address(Telephone No. of Attorney Supreme Court ID No. 21582 Date: WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. Prothonota Date: l By: ( ) Check here if reverse is issued for additional information PROTHON. - 55 TRUE COPY FROM RECORD In Testimony whereof, I Ke; e unto set my hand and the seal of said court at Carlisle, Pa. w kt This ... ?da S I.A. ......, Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor Janice Rogers vs. Jeffrey Kerch etc' 0 z 2009 ."---r---s--as--------0. s'-LI, tit 'Clunk P roe, OF;4CE OF THE SHERIFF SHERIFF'S RETURN OF SERVICE {J U L_j N. -O r. ........ m Case Number 2009-5798 08131/2009 R. Thomas Kline, Sheriff, who being duly swom according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Jeffrey Kerch, but was unable to locate him in his bailiwick. He therefore returns the within Writ of Summons as not found as to the defendant Jeffrey Kerch. The defendant's father advised Deputy's that Jeffrey Kerch had moved to Washington, DC over a year ago. An exact address is not available. SHERIFF COST: $38.84 SO ANSWERS, August 31, 2009 R THOMAS KLINE, SHERIFF 1!?hnTELIUS Lim in the wow,' Your Report Summary Name: state: Report Contents ¦ People Search Report Name Addre ss !Phone Previous Cities Avg. Income Avg. Home Value Jeffrey W Kerch Address 1: Carlisle, PA Avgg tncome: More Info 1007 ARMSTRONG RD CARLISLE PA i ` See All Addresses 1 343,862 DOB: Dec 29, 1979 , 17013 I Avg. Home Value: $225,250 (717) 243-0410 AGE: 29 Years Old 1 RELATIVES: Jeffrey W Kerch Jeff Kerch Betsy L Kerch Julie M Kerch i Elizabeth L Kerch John J Kerch Jeffry L Kerch Address 1: Portage, PA Avg Income: More Info 2 D 367E PORTAGE, PA See All Addresses 330,741 DOB: May 10, 1958 15946 (814) 736-4124 Avg. Home Value: $58,800 2 AGE: 51 Years Old Address 2 Confirmed: RELATIVES: 326 ALLEN ST Jeffry L Kerch PORTAGE, PA Jeffrey L Kerch 15946 Wendy G Kerch (814) 736-4124 ' Kimberly Kerch Connected Jeffry Kerch Address Summerhill, PA Av Income: More Info SUMMERHILL, PA See Ali Addresses 32,287 1 3 DOB: May 10, 1958 15958 Avg. Home Value: $81,100 r AGE: 51 Years old RELATIVES: Jeffry Kerch 4Cn Order #24935927 What is a Current & Historical Residents Search? This section lists current and historical people search records that share the same name and state as your search subject. The People Search Summary can be helpful in providing a consolidated view of matching current and historical records for your subjects name across multiple public sources. Income & Home Value are compiled from property, demographic, census, $ other public record sources. Income & Home Value may contain specific household and area statistics associated with an individual or address. What is a Premium Confirmation Service? The Phone Numbers & Addresses listed in the report here were verified against public utility. All addresses and phone numbers WITH a verified resident and current phone connection are highlighted with red text. Some addresses and phone numbers may stilt be current but not confirmed via public utilities. People Search & Directory Services Powered By Intelius Page 1 of 1 nTE ' U S memoer otams n ur <,;nz: :y.von: tspn uutj I my mmikts ` Live at the mow.- Help (888) 4452727 View My Reports << Return to Home PEOPLE SEARCH RESULTS search.Again.». We found 8 people found that match Jeffrey Kerch in the state of Washington D.C.. Glick on the View Details or Get a Detailed Report link for more info. %40 =Available See Detail s on All 8 People! :Expanded Search Results a We searched Jeffrey Kerch and found 0 records in DC - -- ...... _........ .. . We searched Geoff Kerch and found 0 retorts in DC . We searched Geoffry Kerch and found 0 records in DC ,a We searched Geohey Kerch and found 0 records in DC ¦ We searched Jeff Kerch and found 0 records in DC ¦ We searched Jeffrey Kerch and found 8 records nationwide Name ( Age : Previous Cities ....... .....- } ! DOB Phone Address Avg. Income Avg. Home Value Relatives 1 Jeffrey Karl KeLSh Richard K Kerch Goldfield. IA Judy R Kerch t 39 Eagle Grove, A t-tait5 Rhonda R Kerch Hardy, IA I Judith Rae Kerch I Lindsay Kerch Jeff Kerch Jeffrey W Kerch EeLy L Werth 1 2 1 29 ',. Carlisle, -A _ ?t Y Yo Juie M Kerch Jeff Kerch EBzabeth L Kerch John J Kerch Jeffrey L Kerch _- - - ;Portage. PA _ '.. ,? iYendy G Kerch Jeffry L Kerch Klmberiy Keroh _ ' Jeffrey D Kerch _ _ .._...._ Paul C Kerch j , Trenton. NJ Edward M Kerch ., i€` V P c Kerch Edna C Kerch . Jeffrey D Kerch I Dmail5 47 Trenton. NJ ? i Lucy K Kerch JSffrElt.4 Ker.Ch anncetor: Junction. NJ 6 47 : Trenton, NJ u+-v, ?)emits y/ Y l Bordentown, NJ I i- --- I Jeffre D Kerch View D-tails Trenton, W %14 .. ................ ...._.__.._._. I Jeffrey Kerobey K ercrey K Kerch ! 39 . Eagle Grove, IA a Vicrv Details i 1 ;rk lme iu; I Help I About I Careers I Privacy I Contact Us I FAO I Terms 8 Condhions I Site Map I Affiliates I Directory I Volume Discounts F 2003-2009 1ntelius, Inc. t-'A TRUSTe III?® 4 Tapp ?? > , st t Report - Intelius.com O My Intelius Services Summary Background Report Order No. 24936296 Background Report - November 5, 2009 Your Report Summary Name: Jeffrey W Kerch Report Contents ¦ Personal Public Records Data ¦ Address History Property History Summary ¦ Single State Criminal Check ¦ Single State Civil Judgments ¦ People Search Report SEARCH Expires on Dec 06, 2009 Order #24936296 It is important to understand that public records are only as accurate as the agencies that input them. Please be sure to closely review the public information listed about the individual that you may be researching in the report. public Records Data Subject Name: Jeffrey W Kerch Listed Aliases: Jeffrey W Kerch, Julie M Kerch Listed Dates of Birth: Dec 29, 1979, Nov 09, 1965 Listed Ages: 29,43 Personal public record data can be inaccurate, so it's important to understand what is in the public records for Jeffrey W Kerch. Address History For Jeffrey W Kerch Address Phone Additional Reports 1 1007 Armstrong Rd li C l PA 17 13 Property Report ar s e, 0 - - ----------------- 2 937 Avila Harrisburg, PA 17109 (717) 540-8111 Pro a Rem - -- ------ --------- - -- } t -- 3 3631 Brookridg e (7171540-8111 Property Report Harrisburg, PA 17109 4 238 Saginaw Grantville PA 17028 i i (717) 540-8111 i Property Report , - _ t 5 133 48th #5 Harrisburg, PA 17111 (717) 540 8111 Property Report ? i - j 6 3660 Brookridge #202 ' (717 540$111_ Pr4p?rty Report - . Harrisburg, PA 17109 ' - 7 840 Stoney Creek #C ! (717) 540-8111 Property Report !. Dauphin, PA 17018 8 10r Wormleysburg, PA 17043 (717),540-8111 Property Report Page 1 of 7 Credits (1) What is a Background Report? A Background Report contains information collected from public records and publicly available data. The report is designed as a service to assist you in locating or verifying an individual's background information. The data within the report is compiled from thousands of different sources that include government, property, and other public record repositories. The Intelius service organizes and integrates information together as a convenient service for you. What is a Personal Public Records Data? Personal public records data refers to information such as aliases, birth dates, age and other data found to be connected to Jeffrey W Kerch in the public record. This information can further help you by identifying alternate and/or maiden names, age variations, and any other information that may be associated with Jeffrey W Kerch. What Is an Address History? This report section lists historical addresses associated with an individual from public records. An Address History can assist in flagging address exceptions that may exist in public records. The addresses and phone numbers are not listed in date order and should be individually reviewed. Report - Intelius.com Property History Summary ADDRESS & CONTACT INFO: 1007 Armstrong Rd Get A Complete Property Report Carlisle, PA 17013 (717) 243-0410 PROPERTY DETAR..S Owner Name Property Info 74, 17013 Kerch John J Assessed Value: $225.250 Sq. ft.: 2,268 Kerch Elizabeth L iTaxes: $4,383(2009) C 02M MewSkc *MOO N".Af-r NElGHFORS AROUND THE PROPER TY p ? wu Mc. ; l- 'Name Complete Property Reports Include: William S Walker 1003 Armstrong Rd Background Check • List of all 31 neighborhood Carlisle, PA 17013 sex offenders (717) 243-0256 • Sales History D M Cole • Mortgage Information 1010 Armstrong Rd • Satellite Image Carlisle: PA 17013 Background Check • And More (717) 258-8671 Get a Complete Jack K Callaghan 1002 Armstrong Rd Property Report Carlisle, PA 17013 Background Check 717 243-0363 Gregory Abein 1006 Armstrong Rd Background Check Carlisle:, PA 17013 717 249.6705 K,: -A IWE S h %,: S?C iA l a--: S Name Julie M Kerch ............... Background Check .......-. -- . ........... Jeff Kerch Background Check Elizabeth L Kerch Background Check John J Kerch Background Check AREA DA TA Total Avg House z Avg. Household Area Sex Population Price ......... -._....._.... Income _.. ......... Offenders ---- 52,064 5111,500 E ..-............. $43,862 31 ._ -...... ADDRESS & CONTACT INFO: 937 Avila Harrisburg, PA 17109 (717) 540-8111 79 NEIGH13ORS AROUND THE PROPER IY Name is ,17109 Progress, Vincent Roche PEVANIA 945 Avila Rd Background Check 130 DAlJP4$N Harrisburg, PA 17109 (7171671 71 m2WV Mk-ACq 006 NMRQ. Y.1/w Chad Lavia 931 Avila Rd Background Check Harrisburg, PA 17109 (717)412 Q386 J G Kehew 933 Avila Rd Background Check Harrisburg, PA 17109 ' _J§_57-5723 (717 r-- EJoyce Hare 4 937 Avila Rd Background Check j Lower Paxton, PA 17109 Page 2 of 7 What Is a Property History Summary? This section lists summary, neighbors, relatives and area data associated with the property when available. The Relatives and Associates section lists potential relatives or previous occupants associated with an individual and I or their address from public records. The Neighbors Around the Property section lists the immediate neighbors around the property. These sections can help confirm the people linked to your subject and provide additional people that may have current or forwarding information on the whereabouts of your subject. Report - Intelius.com ADDRESS & CONTACT INFO: 3631 Brookridge Harrisburg, PA 17109 (717) 540.8111 39 l' 22 17109 Progress, PENNS)iVANIA 230.. DAU40N 02009NimsatCM ?3QOS,_NpVX-Q ?W/. j. TNlMii.IRe. - ADDRESS & CONTACT INFO: 238 Saginaw Grantville, PA 17028 (717) 540-8111 DA.LIPHIN LEBANON 17020 PENNSYLV,AIMJ[ 02009 NkwfW CBIr 60006 MM1FQ, iM(M Fk-/?s?gic. . '. Complete Property Reports Include: • Get list of neighborhood sex offenders • Sales History • Mortgage Information • Satellite Image • And More Get a Complete Property Report 1(717) 6,71A130 Dense Burston 1 951 Zia Rd Lower Paxton, PA 17109 Background Check (7171540-0608 i i AREA DATA Total 1 Avg. House Avg. Household Area Sex Population ; Price Income Offenders --T .... . 23,356 $100,800 ..- $39,755 14 NEIGHBORS AROUND THE PROPERTY Name i Donza Sloane .3610 Brookridge Ter Harrisburg, PA 17109 Background Check 717 '3f? 5-9111 William Porter - - --- `- -- 3610 Brookridge Ter Background Check Harrisburg, PA 17109 '(717) 232-1606 - - - - ............ .............. Vincent Parker - .: 13610 Brookridge Ter Harrisburg PA 17109 eac ground Check . 717 6,.5>?549 David Moats -- 3610 Brookridge Ter Harrisburg, PA 17109 Background Check (717) 695-0279 J Cammack 3610 Brookridge Ter Harrisburg, PA 17109 Background Check (717) 657-3414 Total Avg. House Avg. Household Area Sex Population Price Income Offenders ' I 23,356 1100,800 $39,755 14 --------------- -1- - Get A Complete Property Report PROPERTY DETAILS -- .... -T.... ...... -- --- .............._... - _._......_? I Owner Name - I Property Info Assessed Value: $39, 100 Hooks Tammie Jo Sq. ft.: 1,568 Bedrooms: 3 Taxes: $1,004 (2009) NEIGH1ORS AROUND THE PROPERTY Name .......... -- -.......... _...... --? Kimi Miller Piegaro I 236 Saginaw St Background Check Graniviile. PA 17028 717 469-0787 Tammie Hooks 238 Saginaw St Background Check Grantville, PA 17028 j Charles Fidler 239 Saginaw Si Background Check Grantvlle, PA 17028 Page 3 of 7 Report - Intelius.com ADDRESS & CONTACT INFO: 133 48th #5 Harrisburg, PA 17111 (717) 540-8111 Linglestown t71rn, DAUPHIN 17111 Progress` [_ olgrri?p? VANIA ? .. SSCUOn Bt Sler r _`.: . h009 MwRSatCM'02006 WYRQ w1/,erT ; el waa i ?_ ADDRESS & CONTACT INFO: 3660 Brookridge #202 Harrisburg, PA 17109 (717) 540-8111 39 _... I 17109 ' Rogress ,? PENNSWVAM$A 230 AIN 1912009MN-I RCwr."O$ IwiEQ, N J. . kit 4ai,lnt. , Walter R Coelho 244 Saginaw St 3 Grantville, PA 17028 (717) 469-7123 j James Ammon 240 Saginaw St Grantville, PA 17028 (7?7).4b.?-t?zS RELATIVES & ASSOCIATES Name Julia M Kerch ----.--...... ..._....-- Background Check ------- AREA DATA .. ...F Total ? Avg. House --..-_-..-.---...._.._-..._...-.__ Avg. Household T ..............._-e Area Sex Population i Price Income Offenders C -.-- _......... ............ -- - - 3,769 $107,300 $46.761 1 RE€..A",!VES & ASSOS RTES Name Julia M Kerch i Background Check AREA DATA Total Avg. House Avg. Household Area Sex Population Price Income Offenders 27,111 -,111 $106,300 $47,666 - - 66 i NEIGHBORS AROUND THE PROPERTY Name j Sebastian Rogue 3640 Brookridge Ter Background Check Harrisburg, PA 17109 717 5-1410 Carmen Lopez 3640 Brookridge Ter Background Check Harrisburg, PA 17109 Robin Long 3640 Brookridge Ter Harrisburg, PA 17109 Background Check Georgetta Hamilton 3640 Brookridge Ter Background Check Harrisburg, PA 17109 0 (7171657-125 S Hackett 3640 Brookridge Ter Background Check Harrisburg, PA 17109 (717)545-5213 RELATIVES & ASSOCIATES Kerch Background Check AREA DATA otal Avg. House Avg. Household Area Sex Population Price Income Offenders I Name Julia M Page 4 of 7 Report - Intelius.com ADDRESS & CONTACT INFO: 840 Stoney Creek MC Dauphin, PA 17018 (717) 540-8111 PERRY- DAUPHIN 22 17018 22 PENNSYLVANIA tt ? fF., 01009 iawzseC ?0looe Nur-ieQ, WAt w 23.356 $100,800 I $39,755 14 Get A Complete Property Report PROPERTY DETAILS Owner Name Property Info Assessed Value: $167,200 Scott Matthew W Sq. ft.: 2,600 I Scott Shannon L Bedrooms: 8 Taxes: $3,495 (2009) NEIGHBORS AROUND THE PROPERTY Complete Property Reports Name Include: ?S Novosel --.- 832 Stoney Creek Dr • List of all 2 neighborhood Dauphin, PA 17018 Background Check sex offenders (717) 921-2134 • Sales History • Mortgage Information Joseph Mills • Satellite Image 816 Stoney Creek Dr ound Check Ba k • And More Dauphin, PA 17018 c gr 7t 17) 921-192 Get Craig Miller -- Property Report 824 Stoney Creek Dr , Dauphin, PA 17018 Background Check (717) 921-8291 ..... ....._.-.. ........... Eva Ferentz 816 Stoney Creek Dr Background Check Dauphin. PA 17018 717 921-1925 Ronald W Blaydon 828 Stoney Creek Dr Background Check Dauphin, PA 17018 7( 17) 21-8182 _ - AREA 11ATA Total Avg. House ........... .......... Avg. Household ! Area Sex Population Price ..... -..... Income Offenders ........... .. _ -- 4,020 $109.200 $53.397 2 ADDRESS & CONTACT INFO: 109 River Wormleysburg, PA 17043 (717) 540-8111 ......... tz)#r)q" .-:. AREA DATA . NAest -,. DAUPtIIN Fairview i Total Avg House Avg Household Area Sex tt 17043 Population Price Income Offenders ' 5,682 $93,700 $38,958 6 t PENNSYLYA*A 230 ---- --.......... ........ ....... •2009 MiMiM CM}4h0er iwran,ww ' - TN<qu wC. uti ... . Single State Criminal Check NATIONWIDE CRIMINAL CHECK OFFER "30% of people change their addresses nationwide each year especially criminals" G.et..$10 off on a Nationwide Criminal Check for Jeffrey IN Kerch now. CRIMINAL. CHECK FOR ALL JEFFREY W KFRCH W THE STATE OF PA Page 5 of 7 What is a Single State Criminal Chock? This section lists criminal records from county courts, department of corrections, administration of the courts, and other legal agencies for the selected state. The types of offenses include felonies, misdemeanors, sexual offenses, and Report - Intelius.com Page 6 of 7 more. Please closely review each We have searched the following for Jeffrey W Kerch in PA state: record as subjects with a common /case records 4fdisposition records name may return multiple criminal /sentencing records 4other criminal related records record results. No records were found. Positive or false matches within a criminal search may not provide confirmation of a criminal background. A state criminal check only searches records for the state requested. Click Here to conduct a National Criminal Check on Jeffrey W Kerch Criminal Check Disclaimer Customers are charged a search fee for executing a Criminal Check. The Criminal Check report returns results which may include all criminal records or no results found on the individual. In the event of using this service for criminal background checks, you should not assume that this data provides a complete or accurate history of any person's criminal history. You should use extreme caution when interpreting the results of a criminal background search for any type of personal verification. Positive or false matches in criminal searches may not provide confirmation of an individual's criminal background. Please reference the updated intelius User Agreement for additional restrictions regarding the usage of this data. Civil Judgment Report CI` U JUCzf,W ` JF !'PRE'P` KFRCH tN THE STATE OF PA what are Tax Lien, Bankruptcy, & Judgments? NAME: .fst` vs''N K;? ran This section lists civil records from STATE SEARCHED A county courts for the selected address. The types of records RESULT, include property tax liens, general tax liens, bankruptcies, small claims, We have searched the following for Jeffrey W Kerch in PA state: judgments, and more associated the selected address. Please with /tax lien filings /civil action records closely review each record as /small claims records /other civil judgment related records common addresses may return multiple civil record results. No records were found. Positive or false matches within a civil judgment search may not provide confirmation of a litigious civil background. A state civil judgment check only searches records for the state requested. Customers are charged a search fee for executing a Civil Judgment check. The Civil Judgment report returns results which may include all civil judgment records or no results found on the individual. In the event of using this service for civil background checks, you should not assume that this data provides a complete or accurate history of any person's civil judgment history. You should use extreme caution when interpreting the results of a civil judgment background search for any type of personal verification. Positive or false matches in civil searches may not provide confirmation of an individual's civil judgment background. Please reference the updated Intelius User agreement for additional restrictions regarding the usage of data. Current & Historical People Search Report Previous Avg. Income I Home What Is a Current & Historical Name i Address History Cities j Value Residents Search? This section lists current and Jeffrey W Kerch Y historical people search records that share the same name and state as DOB: Dec 29, Pro a your search subject. The People 1 1979 Carlisle, PA Avg. Income: Report Search Summary can be helpful in Address t 1 $43,862 providing a consolidated view of AGE: 29 Years Ol 1007 ARMSTRONG d matching current and historical RD subjects name records for your RELATIVES: i, CARLISLE, PA 17013 Avg. Home Value: Report - Intelius.com Betsy L Kerch (717) 243-0410 Julie M Ke c JeffKerr,h Elizabeth L Kerch John J Kerch $225,250 Page 7 of 7 across multiple public sources. Income & Home Value are compiled from property, demographic, census, & other public record sources. Income & Home Value may contain specific household and area statistics associated with an individual or address. n n O O z O T v m z 0 m T D T r D N W v? ?II s ?k 9 WW n, O W O s W 3 0 W CL d C) -D D mo ?l cr m z C; O pm r r m cn O Ste' Z c ? rN-D C -a O v r 3 7 _ y v mx Z m m ? jiJ ' j r m -? o O o u'r' 0J < m O o` '0 -4 m ° m .? m a m C ti:, Q €? ? m 0 V r CO) 0 O Q . " ms a •? G) 7 Z< ZF . $ O N /-n Can ? ? D M 0 Z-a N r0 T Cc 0 r m z \ M DC R RCP Rule 4-I Page I of I Superior Court Rules--Civil (SCR-Civil) Rule 4-I District of Columbia State Rules Currentness Superior Court Rules of Civil Procedure "® II. Commencement of Action; Service of Process, Pleadings, Motions, and Orders *Ruie 4-I. Service by Publication Notices relating to proceedings in this Court of which publication is required shall be published for the prescribed time in at least one legal newspaper or periodical of daily circulation and any other newspaper or periodical specifically designated by the Court. Publication shall be proved by affidavit of an officer or agent of the publisher stating the dates of publication with an attached copy of the order as published. For purposes of this rule, a legal newspaper or periodical of daily circulation shall mean a publication designated by the Court that is (1) devoted primarily to publication of opinions, notices and other information from the courts of the District of Columbia, (2) circulated generally to the legal community, and (3) published at least on each weekday that the Superior Court is in session. Civil Rule 4-I, DC R RCP Rule 4-I Current with amendments received through 7/1/2009 (c) 2009 Thomson Reuters END OF DOCUMENT (c) 2009 Thomson Reuters. No Claim to Orig. US Gov. Works. ............ E: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JANICE ROGERS, et vir., Plaintiffs vs JEFFREY KERCH, Defendant No. 09-7943 Civil Action 11 cry w -< PRAECIPE TO REISSUE WRIT OF SUMMONS T^v i HE PR^v T HOONO i ARY: Please, reissue the Writ of Summons in the above matter. Respectfully submitted, KNAUER & ASSOCIATES, L.S.C. David . Knauer, Esquire Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 Knauer@early.com (717) 795-7790 Date: / FAX: (717) 795-7793 ? '?? Fl - '?? v .?, i' , __ n. C' l,. qtr^'S r?? ..? y'" y t ?.' .; tJ L?;;; ku IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CA- 5?48 JANICE ROGERS, et vir., : No. 69r7?943? Plaintiffs vs JEFFREY KERCH, Defendant Civil Action PRAECIPE TO REISSUE WRIT OF SUMMONS TO THE PROTHOONOTARY: Please, reissue the Writ of Summons in the above matter. Respectfully submitted, Date: KNAUER & ASSOCIATES, L.S.C. David W. Knauer, Esquire Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 Knauer@ early.com (717) 795-7790 FAX: (717) 795-7793 FLED- ..'ir=il;; OF TPT 1 2009 KG -9 flip 50 410.,,C, PD AIW CA51A P--T' a33a&D IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 69- tVN8 JANICE ROGERS, et vir., No. Plaintiffs : Civil Action vs JEFFREY KERCH, Defendant AFFIDAVIT OF COUNSEL David W. Knauer, Esquire, duly affirms that he is Plaintiffs' counsel in the above matter; that he filed the Praecipe for Writ of Summons and Writ of Summons on August 21, 2009 with the Prothonotary of Cumberland County; that he promptly provided the Praecipe for Writ of Summons and Writ of Summons to the Sheriff of Cumberland County; that the Sheriff of Cumberland County on August 31, 2009 made a not found return and in his return stated that the Defendant's father had informed the deputy service who had attempted to make service on the Defendant that the Defendant had moved from the area to Washington, District of Columbia "over a year ago"; that on November 5, 2009, the affiant marks as Exhibit "A", attaches hereto and incorporates herein by reference thereto a true and correct copy of the Sheriff's return of service; that he contacted the Defendant's insurer, Erie Insurance Company, and spoke to Janet Covely, the adjuster assigned to the above case; that Ms. Covely informed him that the Defendant's policy had lapsed and that the only address she had was the address Plaintiffs' counsel had listed in the caption of the Praecipe for Writ of Summons and Writ of Summons, i.e. 1007 Armstrong Road, Carlisle, Cumberland County, Pennsylvania 17013; that he then used the White Pages search on the internet and through a service provider, Intelius, searched their data bases for the Defendant's name both nationally and for the District of Columbia and did not find any address for the Defendant, the affiant marks as Exhibit "B", attaches hereto and incorporates herein by reference thereto a true and correct copy of the Intelius research; that he also personally contacted the Cumberland County Elections Bureau office and was informed that the Defendant had been stricken from the voters rolls on January 15, 2009 because he had moved out of state; that the affiant went the Cumberland county Elections Bureau on November 6, 2009 and obtained from the Elections Bureau copies of their records documenting that the Defendant had moved out of the Commonwealth of Pennsylvania, the affiant marks as Exhibit "C", attaches hereto and incorporates herein by reference thereto a true and correct copy of the documents the Bureau of Elections provided to the affiant confirming that the Defendant had moved out of state; that he contacted the Virginia Bureau of Elections and was informed that under Virginia law they could not release the address of an individual; that the affiant on November 6, 2009 went to the Cumberland County Tax Claim Bureau and that office informed the Plaintiff that they had no record of the Defendant; that the affiant on November 6, 2009 went to the Cumberland County Personal Tax Office and was informed that that office had no record of the Defendant; that the affiant has made a good faith effort to obtain an address for the Defendant but was unsuccessful in locating a current address for the Defendant; that the deponent saith not further. Respectfully submitted, LUER & ASSOCIATES, L.S.C. David W. Knauer, Esquire Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 Knauer@early.com (717) 795-7790 Date: l l Y FAX: (717) 795-7793 60*-k Sheriffs Office of Cumberland County R Thomas Kline Sheri R A d ? F®r Ronny erson n ! ; . Chief Deputy S Smith Jod a vi) L? ?` ` = 1 y Civil Process Sergeant OPPICE 40F T.H,?. WEERIFF Edward L Schorpp - ------------- - ----•-- --.-- -°^ Solicitor - .- -°- Janice Rogers vs . Case Number Jeffrey Kerch 2009-5798 SHERIFF'S RETURN OF SERVICE 08/31/2009 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: Jeffrey Kerch, but was unable to locate him in his bailiwick. He therefore returns the within Writ of Summons as not found as to the defendant Jeffrey Kerch. The defendant's father advised Deputy's that Jeffrey Kerch had moved to Washington, DC over a year ago. An exact address is not available. SHERIFF COST: $38.84 SO ANSWERS, August 31, 2009 ?. R THOMAS KLINE, SHERIFF EXHIBIT ?t 4 /1 - inTELIUS Live in "know' Your Report Summary Name: effcr;,+ Kercti State: = ?? Report Contents ¦ People Search Report s L'' r Order #24935927 Name Address ! Phone Previous Cities Avg. Income ! Avg. Home Value Jeffrey W Kerch Address 1: Carlisle, PA Avg Income: 1007 $43,862 More Info ARMSTRONG RD See All Addresses CARLISLE, PA Avg. Home Value: DOB: Dec 29, 1979 17013 $225,250 (717) 243-0410 AGE: 29 Years Old 1 RELATIVES: Jeffrey W Kerch Jeff Kerch Betsy L Kerch Julie M Kerch Elizabeth L Kerch John J Kerch Jeffry L Kerch Address 1: Portage, PA Avg Income: 2 D 367E $30,741 More Info PORTAGE, PA See All Addresses 15946 Avg. Home Value: i i DOB: May 10, 1958 (814) 736-4124 $58,900 2 AGE: 51 Years Old Address 2 Confirmed: RELATIVES: 326 ALLEN ST Jeffry L Kerch PORTAGE, PA Jeffrey L Kerch 15946 Wendy G Kerch (814) 736-4124 Kimberly Kerch Connected Jeffry Kerch Address 1: Summerhill, PA Av . Income: BOX 127 32,287 More Info SUMMERHILL, PA See All Addresses 15958 Avg. Home Value: 3 DOB: May 10, 1958 $81,100 AGE: 51 Years Old RELATIVES: Jeffry Kerch n4 i.- What is a Current & Historical Residents Search? This section lists current and historical people search records that share the same name and state as your search subject. The People Search Summary can be helpful in providing a consolidated view of matching current and historical records for your subjects name across multiple public sources. Income & Home Value are compiled from property, demographic, census, & other public record sources. Income & Home Value may contain specific household and area statistics associated with an individual or address. What is a Premium k' Confirmation Service? K The Phone Numbers & z Addresses listed in the report i, here were verified against public utility. All addresses and phone numbers WITH a verified resident and current phone connection are highlighted with red text. Some addresses and phone numbers may still be current but not confirmed via public j = utilities. EXHIBIT 1\ /I --ZL- People Search & Directory Services Powered By Intelius will InTE1 IVSS uve in << Return to Home Page 1 of 1 member ataws: ba- nnauer L, ee::y. u:En LNlsi wy I my mienu5 Help: (888) 445-2727 1 View My Reports rr-UYLt SEARCH RESULTS Brorqh Again We found 8 people found that match Jeffrey Kerch in the state of Washington D.C.. ( Click on the View Details a Get a Detailed Report link for more info. Available See Details on All 8 People! Expanded Search Results • We searched Jeffrey Kerch and found 0 records in DC • We searched Geoff Kerch and found 0 records in DC i ¦ We searched Geoffry Kerch and found 0 records in DC • We searched Geofre Kerch and found 0 records in DC • We searched Jeff Kerch and found 0 records in DC • We searched Jeffrey Kerch and found 8 records nationwide Name -- - Aye Previous Cities DOB Phone Address i Avg. Income Avg. Home Value Relatives Jeffrey Karl Kerch _ Richard K Kerch Goldfield, IA - Judy R Kerch i t View Details 39 Eagle Grove, A J J V?1 / V Rhonda R Kerch i Hardy, IA - - Judith Rae Kerch Lindsay Kerch Jeff Kerch Jeffrey W Kerch i Betsy L Kerch Vi(- ,w Details 29 : Carlisle, PA ( J 1 J Jule M Kerch . V v Jeff Kerch i Elizabeth L' Kerch John J Kerch Jeffrey L Kerch "ii -w Details :Portage. PA i ! -00 Y Y ?t Wendy G Kerch J ff L K e ry erch Kimbeny Kerch Jeffrey R.Kgrgh ---? Paul C Kerch View Details Trenton, NJ y/ ! V p Y Edward IA Kerch P c Kerch . ' - ; Edna C Kerch effrev D Kerch View Details 47 Trenton, NJ J J L i ucy K Kerch Jeffrey DKerch Princeton Junction, NJ 6 View Details 47 i Trenton, NJ Bordentown, NJ Jeffrey D Kerch 7 View Details 47 :Trenton, NJ J _ 1 V I. ;Jeffrey K Kerch I ? 8 View Details i 39 'Eagle Grove, IA , I i . J1 I s v s v ?- l3cormerk Intelius I Help I About I Careers I Privacy I Contact Us I FAO I Terms & Conditions I Site Map I Affiliates Directory ! Volume Dismounts C 2003-2009 Intelius, Inc. TRUSTe I? 5la p h?ru. Report - Intelius.com My Intelius Services Summary © Background Report Order No. 24936296 Background Report - November 5, 2009 Your Report Summary Name: Jeffrey W Kerch Report Contents ¦ Personal Public Records Data ¦ Property History Summary ¦ Single State Civil Judgments ¦ Address History ¦ Single State Criminal Check ¦ People Search Report SEARCH Expires on Dec 06, 2009 Order #24936296 It is important to understand that public records are only as accurate as the agencies that input them. Please be sure to closely review the public information listed about the individual that you may be researching in the report. Personal Public Records Data Subject Name: Jeffrey W Kerch Listed Aliases: Jeffrey W Kerch, Julie M Kerch Listed Dates of Birth: Dec 29, 1979, Nov 09, 1965 Listed Ages: 29.43 Personal public record data can be inaccurate, so it's important to understand what is in the public records for Jeffrey W Kerch. Address History For Jeffrey W Kerch Address i Phone Additional Reports I 1 i 1007 Armstrong Rd j Carlisle, PA 17013 ?r4p_gQyRgp9rs 2 937 Avila { Harrisburg, PA 17109 (717) 540-8111 Property Report 3 13631 Brookridge Harrisburg, PA 17109 (717) 540-8111 1 Property Report i 4 %238 Saginaw Grantville, PA 17028 (717) 540-8111 Properly Report 1 133 48th #5 5 ' Harrisburg, PA 17111 I (717) 540-8111 Property Report j 3660 Brookridge #202 i 5 Harrisburg, PA 17109 (717)540-8111 Property Report 7 840 Stoney Creek #C i Dauphin, PA 17018 (717) 540111 % Property Report 8 109 River Wormteysburg, PA 17043 (7171540-8111 ; Property Report Page 1 of 7 Credits (1) What is a Background Report? A Background Report contains information collected from public records and publicly available data. The report is designed as a service to assist you in locating or verifying an individual's background information. The data within the report is compiled from thousands of different sources that include government, property, and other public record repositories. The Intelius service organizes and integrates information together as a convenient service for you. What is a Personal Public Records Data? Personal public records data refers to information such as aliases, birth dates, age and other data found to be connected to Jeffrey W Kerch in the public record. This information can further help you by identifying alternate and/or maiden names, age variations, and any other information that may be associated with Jeffrey W Kerch. What is an Address History? This report section lists historical addresses associated with an individual from public records. An Address History can assist in flagging address exceptions that may exist in public records. The addresses and phone numbers are not listed in date order and should be individually reviewed. Report Intelius.com Property History Summary ADDRESS & CONTACT INFO: 1007 Armstrong Rd Carlisle, PA 17013 (717) 243-0410 P E R R Y - 17013 \ ?yY j mevoas,?M. Complete Property Reports Include: • List of all 31 neighborhood sex offenders • Sales History • Mortgage Information • Satellite Image • And More Get a Cqm. ple(e Property Report ADDRESS & CONTACT INFO: 937 Avila Harrisburg, PA 17109 (717) 540-8111 Get A Complete Property Report PROPERTY DETAILS Owner Name i Property Info j i i Keroh John J Assessed Value: $225,250 1. 1 Kerch Elizabeth L Sq. ft.: 2,268 j Taxes: $4,383 (2009) NEIGHBORS AROUND THE PROPERTY j Name William S Walker j 1003 Armstrong Rd i Carlisle. PA 17013 Background Check C71.7.L?43702., D M Cole X1010 Armstrong Rd Carlisle, PA 17013 - @aCkground Check (717)258-8671 i Jack K Callaghan 1002 Armstrong Rd Carlisle, PA 17,313 Background Check (7171 243-0363 Gregory Abeln 1006 Armstrong Rd Carlisle, PA 17,313 Background Check (717) 249-6705 rt??ra ? tYtJ & NJSCI[;3A i t S Name Julie M Kerch Jeff Kerch Elizabeth L Kerch Background Check Background Check - Background Check John J Kerch Background Check AREA DATA Total Population Avg. House Price I Avg. Household Income Area Sex Offenders 52,064 5111,500 $43,862 31 NEIGHBORS AROUND THE PROPERTY Name i Vincent Roche 945 Avila Rd Harrisburg, PA 17109 B@Qkground Check (717) 671-0718 Chad Lavia 931 Avila Rd i Harrisburg, PA 17109 Background Check (717 412:6 i J G Kehew '933 Avila Rd Harrisburg. PA 17109 Background Check 1(7171657-572 3 Joyce Hare 937 Avila Rd Background Check Lower Paxton, PA 17109 Page 2 of 7 What is a Property History Summary? This section lists summary, neighbors, relatives and area data associated with the property when available. The Relatives and Associates section lists potential relatives or previous occupants associated with an individual and / or their address from public records. The Neighbors Around the Property section lists the immediate neighbors around the property. These sections can help confirm the people linked to your subject and provide additional people that may have current or forwarding information on the whereabouts of your subject. Report - Intelius.com ADDRESS $ CONTACT INFO: 3631 Brookridge Harrisburg, PA 17109 (717) 540-8111 39 _ X22 17109 ? ? Progress '? `° PENNb`WVANIA 1 230 UP.LIFi1N ®2009 aicwSOR Ceq 42008 NGVSEO.?nafor tee AM.Inc. - - ADDRESS 8 CONTACT INFO: 238 Saginaw Grantville, PA 17028 (717) 540-8111 DALptaN - LEBANO I 17028 x':. PENNSYL V,"X- ®2009 rN/Mferese®Yoos NAV .Vw/er te?Mhs;IK. Complete Property Reports Include: • Get list of neighborhood sex offenders • Sales History • Mortgage Information • Satellite Image • And More Get a Complete Property Repo. rt (717)671-1130 Dena. Burston 951 Avila Rd Lower Paxton, PA 17109 1 Background Check (717) 540-0608 i 1 AREA DATA Total Population Avg.HOUSe Price Avg. Household Income Area Sex Offenders 23,356 $100,800 $39.755 14 NEIGHBORS AROUND THE PROPERTY jName Donza Sloane - 3610 Brookridge Ter Harrisburg, PA 17109 Background Chi (717)635-9111 William Porter i 3610 Brookridge Ter Harrisburg, PA 17109 Background Check (717) 232-1606 - Vincent Parker ------------------- i 3610 Brookridge Ter Harrisburg, PA 17109 -Background Check (717) 651-0549 David Moats 13610 Brookridge Ter Harrisburg, PA 17109 Backgrgund Check (717) 695-0279 J Cammack 3610 Brookridge Ter Harrisburg, PA 17109 Background Check (7_ 17).6@7-41._4 Total Avg. House Avg. Household Area Sex 1 Population i Price Income Offenders 23.356 $100,800 $39,755 14 Get A Complete Property Report PROPERTY DETAILS Owner Name j Property Info I I Assessed Value: $39,100 i Hooks Tammie Jo Sq. ft.: 1,568 Bedrooms: 3 i i Taxes: $1,004 (2009) NEIGHBORS AROUND THE PROPERTY Name Kimi Miller Piegaro I 236 Saginaw St Grantville, PA 17028 Backgro and Check (717146M78 7 i ' Tammie Hooks 238 Saginaw St Background h k Grantville, PA 17028 Charles Fidler j 239 Saginaw St Background Check Grantville, PA 17028 Page 3 of 7 Report - Intelius.com ADDRESS B CONTACT INFO: 133 48th #5 Harrisburg, PA 17111 (717) 540-8111 Lingleslown 4 AUPHIN Progress 17111 o?errl?8bu?ig? Ntt?M i LVANIA ?=teelton B}pssler Y _ 1 0200,99 Mimes calpr®2006 NAnEQ ??/OI ADDRESS 8 CONTACT INFO: 3660 Brookridge #202 Harrisburg, PA 17109 (717) 540-8111 Waiter R Coelho 244 Saginaw St Grantville, PA 17028 { Background h k (717)469-7123 i James Ammon 240 Saginaw St Grantville, PA 17028 i 029liground Check (717)469-1325 j RELATIVES 8 ASSOCIATES j Name j Julia M Kerch Background Check AREA DATA Total E Avg. House Population Price Avg. Household Income Area Sex Offenders 3,769 j $107,300 $46,761 1 REL.A TIVES & ASSOCIATES Name Julia M Kerch Background Check AREA DATA Total Avg. House - -- Avg. Household Area Sex Population Price Income Offenders l 27,111 $106,300 ---- $47,666 ? 66 NEIGHBORS AROUND THE PROPERTY Name Sebastian Rogue 3640 Brookridge Ter Harrisburg. PA 17109 Background Check (717) 545-1410 Carmen Lopez 3640 Brookridge Ter Background Check Harrisburg, PA 17109 Robin Long 3640 Brookridge Ter Harrisburg, PA 17109 Background Check (717) 635-9670 Georgetta Hamilton 3640 Brookridge Ter Harrisburg, PA 17109 Background Check (717) 657-1250 S Hackett 3640 Brookridge Ter Harrisburg, PA 17109 Background Check I (717) 5d5 23 Population i Price Income Offenders , RELATIVES 8 ASSOCIATES Name Julia M Kerch Backer noy d„Chet`k AREA DATA Total Avg. House Avg. Household Area Sex Page 4 of 7 Report - Intelius.com 23,356 ADDRESS 8 CONTACT INFO: 840 Stoney Creek #C Dauphin, PA 17018 (717) 540-8111 $100,800 I $39,755 ( 14 Get A Complete Property Report ( PERRY PROPERTY DETAILS w2{ (', DAUPHIN 17018 Owner Name L IProperty Info I -- Assessed Value: $167,200 ?zT PENNSYLVANIA Scott Matthew W Scott Shannon L I Sq. ft.: 2,600 Bedroom 8 tt? ? ( s: Taxes: $3,495 (2009) _ m2009 kknsoS,C 42005 N ?Q:1fi7/N' Rle ?ws ?{ i NEIGHBORS AROUND THE PROPERTY Complete Property Reports j Name Include: S NI ovosel - • List of all 2 neighborhood 832 Stoney Creek Dr sex offenders i Dauphin, PA 17018 Background Check • Sales History 717 921-2134 • Mortgage Information Joseph Mills -'""- _--- • Satellite Image ' 816 Stoney Creek Dr • And More Dauphin, PA 17018 Background Check !(717)921-1925 Get a Complete Property Report Craig Miller 824 Stoney Creek Dr Dauphin, PA 17018 Background Check (717)_9.2..1_-8291. I Eva Ferentz 816 Stoney Creek D, Dauphin, PA 17018 Background Check 1(7171921-1925 i Ronald W Blaydon 828 Stoney Creek D, Dauphin, PA 17018 Background Cheek (717)921-8182 AREA DATA Total Avg. House Avg. Household Area Sex Population Price Income Offenders j 4.020 - 5109,200 $53,397_ 2 ADDRESS & CONTACT INFO: 109 River Wormleysburg, PA 17043 (717)540-8111 btf AREA DATA , West', Fe?vtew?? DAl1PFi[N 17043 Tote] P Avg. House Avg. Household Area Sex opulation Price Income Offenders r= ' - 5,682 $93,700 $38,958 6 A 230 f n , :.PENN J ,@2009.NNw{MCwr ®20 ,. NOY1W. w1/ '71k YUke- ?, 1171 Single State Criminal Check NATIONWIDE CRIMINAL CHECK OFFER - "30% of people change their addresses nationwide each year... especially criminals" Get 10 off on a Nationwide_Criminal_Ch- k,for"Jeffrey_W Kerch now., ,ec CRIMINAL CHECK FOR ALL JEFFREY W KERCH IN THE STATE OF PA Page 5 of 7 What is a Single State Criminal Check? This section lists criminal records from county courts, department of corrections, administration of the courts, and other legal agencies for the selected state. The types of offenses include felonies, misdemeanors, sexual offenses, and Report - Intelius.eom We have searched the following for Jeffrey W Kerch in PA state: -/case records -/disposition records -/sentencing records -/other criminal related records No records were found. Positive or false matches within a criminal search may not provide confirmation of a criminal background. A state criminal check only searches records for the state requested. Click Here to conduct a National Criminal Check on Jeffrey W Kerch Criminal Check Disclaimer Customers are charged a search fee for executing a Criminal Check. The Criminal Check report returns results which may include all criminal records or no results found on the individual. In the event of using this service for criminal background checks, you should not assume that this data provides a complete or accurate history of any person's criminal history. You should use extreme caution when interpreting the results of a criminal background search for any type of personal verification. Positive or false matches in criminal searches may not provide confirmation of an individual's criminal background. Please reference the updated Intelius User Agreement for additional restrictions regarding the usage of this data. Civil Judgment Report CIVIL JUDGMENTS FOR JEFFREY KERCH IN THE STATE OF PA NAME: Jeffrey W Kercn STATE SEARCHED: PA RESULT: We have searched the following for Je -rey W Kerch in PA stete: -/tax lien filings +fcivil action records ,/small claims records -/other civil judgment related records No records were found. Positive or false matches within a civil judgment search may not provide confirmation of a litigious civil background. A state civil judgment check only searches records for the state requested Customers are charged a search fee for executing a Civil Judgment check. The Civil Judgment report returns results which may include all civil judgment records or no results found on the individual. In the event of using this service for civil background checks, you should not assume that this data provides a complete or accurate history of any person's civil judgment history. You should use extreme caution when interpreting the results of a civil judgment background search for any type of personal verification. Positive or false matches in civil searches may not provide confirmation of an individual's civil judgment background. Please reference the updated Intelius User agreement for additional restrictions regarding the usage of data. Current & Historical People Search Report Previous ` Avg. Income I Home ' I i Name Address History i i 1 Cities Value I Jeffrey W Kerch ; E I DOB: Dec 29, I i op 1 1979 1 Carlisle, PA Avg. Income: ` P 1 Address 1 Reoort $43.862 AGE: 29 Years Old 1007 ARMSTRONG IRD 'RELATIVES: CARLISLE, PA 17013 Avg. Home Value: Page 6 of 7 more. Please closely review each record as subjects with a common name may return multiple criminal record results. What are Tax Lien, Bankruptcy, & Judgments? This section lists civil records from county courts for the selected address. The types of records include property tax liens, general tax liens, bankruptcies, small claims, judgments, and more associated with the selected address. Please closely review each record as common addresses may return multiple civil record results. What Is a Current & Historical Residents Search? This section lists current and historical people search records that share the same name and state as your search subject. The People Search Summary can be helpful in providing a consolidated view of matching current and historical records for your subjects name Report - Intelius.com Betsy K r h (717) 243-0410 Julie M Kerch ffKrh Elizabeth Krh John J Kerch $225,250 Page 7 of 7 across multiple public sources. Income & Home Value are compiled from property, demographic, census, & other public record sources. Income & Home Value may contain specific household and area statistics associated with an individual or address. EXHIBIT t\ U - o ? z - - < c; < ? o , m o N c Z i? u D 3 < ?\ < -D-i Z ?(D O 12 z W _ m m CL .-? O r` mm p me ° N ` 1`3 cmn o o ,? . z m Om m o m 3 m D Q ID a O N - C ?C) ? D .? ..? r ? N N co ° m d :.J ?VIJJ r r = lfl 0 v O O -? m ao o v ? ? m ? m " N ? O m __ '" T o CD ' 'ar, b'', '•Z C O ? :?u$ C N O Oi c.t? O fl. N w ? - c ?J ?ll o m a o:3 a m ° u m o (n ° O' w= w 4 C , . to - - N (? l J ? O ?, \ r m c 7e c ? t Fl! ?!r r. ^,P n r I . " ir r? NOV 0 9 2009 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 0q-5qq8 JANICE ROGERS, et vir., No.3 Plaintiffs Civil Action vs JEFFREY KERCH, : Defendant : ORDER AND NOW, this lb day of November, 2009, upon consideration of the attached Motion and Affidavit of Counsel attached hereto, it is hereby ORDERED and DECREED that this Court is satisfied that the Plaintiffs used their best good faith efforts to obtain a current address outside of the Commonwealth of Pennsylvania and that despite their efforts the Plaintiffs were unable to obtain the Defendant's current address and that said motion is GRANTED and further that the Plaintiff shall serve at the Plaintiff's last known address by United States first class mail with a Certificate of Mailing (PS Form 3817, Mar. 1989) a true and correct copy of the pleadings heretofore filed and this motion and to publish in conformance with the notice requirement of Pa.R.C.P.No. 430(b)(1) notice to the Defendant of the above action one time in the legal newspaper for the District of Columbia and one time in a paper of general circulation in the District of Columbia. By the Court, ? r L' O lv, 1 2 A ? j ~Q IN THE COURT OF COMMON PLEAS N CUMBERLAND COUNTY, PENNSYLVANIA ~ ~~ ~{-F ~! ~ ~ , JANICE ROGERS and BERNARD ~ ~ ~ c ~~ '~ '~~ ROGERS, wife and husband, residing _ _ at 196 Edinburgh Road, Summerville, 4 ~ 'O ~~ _ Dorchester County, South Carolina 29483: No. 09-5798 r> ~ - ~ ~'' ~ ~ ,: . Plaintiff ~ ~ ~~, :~ Civil Action -Law JEFFREY KERCH, an individual residing at 1007 Armstrong Road, Carlisle, Cumberland County, Pennsylvania 17011 Jury Trial Demanded Defendant NOTICE TO DEFEND AND CLAIM RIGHTS 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. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle, PA 17013-3302 (717) 249-3166 NOTICIA LISTED 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 notification de esta comparecencia escrita y radicando en la Corte por escrito sus defenses de, y objecciones a, las demandas presentadas aqui en contra suya. Se le adviote 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 reclamation 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. LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI LISTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMATION A CERCA DE COMP CONSEGUIR UN ABOGADO. SI LISTED 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 O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle, PA 17013-3302 (717) 249-3166 DAVID W. KNAUER, L.S.C. i; Date: David W'Knauer; E'~quire Attorney for the Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 David W. Knauer, Esquire Attorney I.D. No. 21582 Knauer 8~ Associates, L.S.C. 411-A E. Main Street Mechanicsburg, PA 17055 Knauer early.com 717-795-7790 717-795-7793 Fax IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JANICE ROGERS and BERNARD ROGERS, wife and husband, residing at 196 Edinburgh Road, Summerville, Dorchester County, South Carolina 29483: No. 09-5798 Plaintiff Civil Action -Law JEFFREY KERCH, an individual residing at 1007 Armstrong Road, Carlisle, Cumberland County, Pennsylvania 17011 Jury Trial Demanded Defendant COMPLAINT COUNTI JANICE ROGERS V. JEFFREY KERCH 1. The Plaintiffs Janice Rogers in and adult individual with an address of 196 Edinburgh Road, Summerville, South Carolina 29483. 2. The Plaintiff Bernard Rogers is the husband of the Plaintiff Janice Rogers and resides with her at the aforesaid address. 3. The Defendant Jeffrey Kerch is an adult individual with no known current address and a last know address of 1007 Armstrong Road, Carlisle, Pennsylvania 17013. 4. On September 4, 2007, the Plaintiffs Janice was lawfully operating her vehicle on Interstate 81 in Cumberland County traveling in a northerly direction. 5. On the aforesaid date, the Defendant was also operating his vehicle in a northerly direction on Interstate 81 in Cumberland County, Pennsylvania. 6. With out any warning and contrary to the vehicular laws of the Commonwealth of Pennsylvania, the Defendant crossed into the lane of travel the Plaintiff's vehicle was occupying and came into a sudden and violent collision with the Plaintiff's vehicle. 7. The aforesaid collision was caused solely by the carelessness, recklessness and negligence of the Defendant in that he: a.) crossed over the center lane without first looking to see if the Plaintiff's vehicle or any other vehicle was occupying the other lane of travel; b.) failed to utilize turn signals; c.) failed to see the Plaintiffs' vehicle that was then and there occupying the lane of travel that the Defendant wished to cross into with his vehicle; d.) failed to avoid striking the Plaintiff's vehicle; e.) struck the Plaintiff's vehicle; f.) was otherwise negligent. 8. Solely as a result of the carelessness, recklessness and negligence of the Defendant the Plaintiff has suffered severe and sundry injuries to her person. 9. Solely as a result of the carelessness, recklessness and negligence of the Defendant and the injuries he inflicted upon the Plaintiff the Plaintiff is entitled to both past and future damages under the laws of the Commonwealth of Pennsylvania to include: a:) pain and suffering; b.) emotional distress; c) loss of enjoyment of life; d.) medical expenses. 2 Wherefore, the Plaintiff demands judgment in her favor and against the Defendant tin an amount in excess of the amount for mandatory referral to arbitration. COUNT II BERNARD ROGERS V. JEFFREY KERCH 10. The Plaintiff incorporate herein by reference thereto paragraphs 1 through 9 herein as if more fully set forth herein by reference thereto. 11. Solely as a result of the carelessness, recklessness and negligence of the Defendant, the Plaintiff has suffered the loss of consortium. Date: ~ ~ Respectfully submitted, KNAUER & ASSOCIATES, L.S.C. David W. Hauer, Esquire Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 Knauer early.com (717) 795-7790 FAX: (717) 795-7793 3 CERTIFICATE OF SERVICE I, David W. Knauer, Esquire, hereby certify that a true and correct copy of the within document was served on the 27"' day of July, 2010 via U.S. First Class Mail, postage prepaid, on the following individual: Jefferson J. Shipman, Esquire JOHNSON DUFFIE STEWART & WEIDNER 301 Market Street P.O. Box 109 Lemoyne, PA 17043 KNAUER & ASSOCIATES, L.S.C. By: ~ ~ Davi .Knauer, Esquire Attorney for Plaintiff Attorney 1. D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 Johnson, Duffie, Stewart 8 Weidner By: Jefferson J. Shipman I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs cLDjdsw.com JANICE ROGERS and BERNARD ROGERS, wife and husband, Plaintiffs v. JEFFREY KERCH, Defendant NOTICE TO PLEAD TO: Janice Rogers and Bernard Rogers Go David W. Knauer, Esquire NO. 09-5798 CIVIL ACTION -LAW JURY TRIAL DEMANDED AND NOW, this q day of August, 2010, you are hereby notified to plead responsively within twenty (20) days of the date of service hereof, or judgment may be entered against you. JOHNSON, DUFFIE, STEWART & WEIDNER B e son J. S ipman n ~ ~ ___ Attorneys for Defendant ~_~ ~,,;a -, ~~-N . :_ _, ,_ r ~ :":~ c.~ IN THE COURT OF COMMON PLEAS bF CUMBERLAND COUNTY, PENNSYLVANIA :409350 r y Johnson, Duffle, Stewart ~ Weidner By: Jefferson J. Shipman I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs cLDjdsw.com JANICE ROGERS and BERNARD ROGERS, wife and husband, Plaintiffs v. JEFFREY KERCH, : Defendant CIVIL ACTION -LAW JURY TRIAL DEMANDED DEFENDANT'S ANSWER AND NEW MATTER TO PLAINTIFFS' COMPLAINT COUNTI Janice Ros~ers v. Jeffrey Kerch AND NOW, comes the Defendant, Jeffrey Kerch, by and through his counsel, Jefferson J. Shipman and Johnson, Duffle, Stewart & Weidner, and files the following Answer and New Matter to Plaintiffs' Complaint: 1. After reasonable investigation, Mr. Kerch is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 1. 2. After reasonable investigation, Mr. Kerch is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 2. Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-5798 3. Denied as to the address. 4. Admitted in part, denied in part. It is admitted that on September 4, 2007, Plaintiff Janice Rogers was operating a vehicle north on Interstate 81 in Cumberland County. The remaining averments of paragraph 4 are conclusions of law relative to whether the Plaintiff was operating her vehicle in a lawful manner and the same are therefore denied. 5. Admitted. 6. Denied. The averments contained in paragraph 6 are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. 7. Denied. The averments contained in paragraph 7 and subparagraphs (a) through (f) are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. (a) Denied. It is specifically denied that Mr. Kerch crossed over the center line without first looking to see if Plaintiffs' vehicle or any other vehicles occupying the other lane of travel; (b) Denied. It is specifically denied that Mr. Kerch failed to utilize a turn signal; (c) Denied. It is specifically denied that Mr. Kerch was negligent in allegedly failing to see Plaintiffs' vehicle that was then and there occupying the lane of travel that the Defendant wished to cross into with his vehicle; (d) Denied. It is specifically denied that Mr. Kerch was negligent in allegedly failing to avoid striking the Plaintiffs' vehicle. By way of further response, it was only after Plaintiff lost control of her vehicle that she collided with the median barrier and then made contact with Mr. Kerch's vehicle; (e) Denied. It is specifically denied that Mr. Kerch struck the Plaintiffs' vehicle; (f) Denied. It is specifically denied that Mr. Kerch was otherwise negligent. 8. Denied. The averments contained in paragraph 8 are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. 9. Denied. The averments contained in paragraph 9 are in part conclusions of law and fact to which no response is required. After reasonable investigation, Mr. Kerch is without sufficient knowledge or information to form a belief as to the truth of the remaining averments in paragraph 9 and the same are therefore denied and strict proof is demanded at the time of trial. WHEREFORE, Defendant Jeffrey Kerch respectfully requests that judgment be entered in his favor and that Plaintiffs' Complaint be dismissed with prejudice. COUNT II Bernard Rogers v. Jeffrey Kerch 10. Mr. Kerch incorporates herein by reference his answers to paragraphs 1 through 9 as though fully set forth herein. . , 11. Denied. The averments contained in paragraph 11 are in part conclusions of law and fact to which no response is required. After reasonable investigation, Mr. Kerch is without sufficient knowledge or information to form a belief as to the truth of the remaining averments in paragraph 11 and the same are therefore denied and strict proof is demanded at the time of trial. WHEREFORE, the Defendant Jeffrey Kerch respectfully requests that judgment be entered in his favor and that Plaintiffs' Complaint be dismissed with prejudice. NEW MATTER 12. That the Plaintiffs have failed to state a cause of action for which relief may be granted. 13. That the Defendant Jeffrey Kerch was never properly served with the Writ of Summons. 14. That if it should be found that there was any negligence on the part of Defendant Jeffrey Kerch, which is denied, then in that event, any such negligence was not a factual cause of Plaintiffs' alleged injuries. 15. That Plaintiffs' alleged injuries may have been pre-existing. 16. That the Plaintiffs' alleged cause of action may be barred in whole or in part by the Pennsylvania Motor Vehicle Financial Responsibility Law. 17. That the Plaintiff was herself contributorily negligent. 18. That the Plaintiffs own negligence was a factual cause of her harm. 19. That the Plaintiffs own negligence included the following: (a) failing to be attentive to road conditions; (b) failing to observe the Kerch vehicle; (c) failing to operate at a safe speed; (d) overreacting to the movements of the Kerch vehicle; (e) failing to properly bring her vehicle under control; and (f) failing to apply her brakes. 20. That the Plaintiffs alleged cause of action may have been caused by third parties or entities not presently involved in this action. WHEREFORE, the Defendant Jeffrey Kerch respectfully requests that judgment be entered in his favor and that Plaintiffs' Complaint be dismissed with prejudice. Date: 0/l~ :409350 JOHNSON, DUFFIE, STEWART & WEIDNER By. ffe on J. Ship an Attorney I.D. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant VERIFICATION The undersigned says that the facts set forth in the foregoing document are true and correct. This verification is made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unsworn falsifications to authorities. ,~ j` erch Dated: ~ ~~ ~~ 409350 CERTIFICATE OF SERVICE AND NOW, this ~ day of August, 2010, the undersigned does hereby certify that she did this date serve a copy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: David W. Knauer, Esquire David W. Knauer, P.C. 411-A East Main Street Mechanicsburg, PA 17055 :409350 JOHNSON, DUFFIE, STEWART & WEIDNER By: ~ 'chelle H. Spangler Johnson, Duffle, Stewart & Weidner By: Jefferson J. Shipman I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 7614540 jjs@jdsw.com JANICE ROGERS and BERNARD ROGERS, wife and husband, Plaintiffs V. JEFFREY KERCH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY!, PENNSYLVANIA NO. 09-57!98 CIVIL ACTION - LAW JURY TRIAL DEMANDED STIPULATION OF COUNSEL IT IS HEREBY STIPULATED AND AGREED by and between David W. Knauer, Esquire, counsel for Plaintiffs, and Jefferson J. Shipman, Esquire, counsel for Defendant Jeffrey Kerch, that subparagraph (f) only of paragraph 7 is hereby stricken and deleted from Plaintiffs' Complaint. DAVI W. KNAUER, P.C. :409356 B C- Y• David Hauer r JOHNSON, DUFFIE, STEWART & WEIDNER By - ffe on J. Shipman .~- OCT 22 PM 2~ 22 ^~wa ~„° JOHNSON, DUFFIE, STEWART ~ WEIDNER By: Julia A. Phillips, Esquire I.D. No. 307256 301 Market Street P. 0. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 jal@jdsw.com JANICE ROGERS anti BERNARD ROGERS, wife and hi.lsband, Plaintiffs v. JEFFREY KERCH, Defendant Attorneys for Defendant, Jeffrey Kerch IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-5798 CIVIL ACTION -LAW JURY TRIAL DEMANDED PRAECIPE TO SUBSTITUTE APPEARANCE TO THE PROTHONOTARY: Please substitute the appearance of Julia A. Phillips, Esquire of Johnson, Duffie, Stewart & Weidner, P.C., as the attorney for Defendant, Jeffrey K;erch, in the above-captioned matter. JOHNSON, DUFFIE, STEWART &WEIDNER ~~. ~-~, BY: ~ _ J h li s, E uire Att y I . D. 256 301 Market Street. P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Date: October 19, 2012 Attorneys for Defendant, Jeffrey Kerch 521343 CERTIFICATE OF SERVICE AND NOW, this 19'h day of October, 2012, the undersigned does hereby certify that she did this date serve a copy of the foregoing Praecipe to Substitute Appearance upon all counsel of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: David W. Knauer, Esquire Knauer & Associates, LSC 1542 Lookout Springs Drive Colorado Springs, CO 80921 (Counsel for Plaintiff) JOHNSON, DUFFIE, STE:WART & WEIDNER r, ----. BY: _ ra .Philp s 521343 1 4 c iAAi i.. ;%12 CCU ,i': 'Ely KNAUER&ASSOCIATES,L.S.C. By: David W. Knauer, Esquire 1,D, No. 21582 Attorneys for Plaintiffs 1542 Lookout Springs Drive Colorado Springs, CO 80921-4107 (719)203-5980(telephone) E-mail: knauer©juno.com JANICE ROGERS and BERNARD IN THE COURT OF COMMON PLEAS OF ROGERS,wife and husband, CUMBERLAND COUNTY, PENNSYLVANIA • Plaintiffs NO. 09-5798 • v. : CIVIL ACTION -LAW JEFFREY KERCH, JURY TRIAL DEMANDED Defendant • PR^EC!PE TO SETTLE. DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above-captioned matter'seiiled, discontinued and ended". KNAUER&ASSOCIATES, LSC r BY: ,:.1.. , t David W. nauer, Esquire KnauL:s &itSsti:I=alt-- LSC 1542 Lookout Springs Drive Colorado Springs, CO 80921-4107 (719)703,s980 Pk:phone) E-mail: knauer@juno.com Date: (4?44-- 2013 Attorneys for Plaintiffs 592996 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Praecipe to Settle, Discontinue and End has been duly served upon all counsel of record by depositing the same in the United States First Class Mail, postage prepaid, in Lemoyne, Pennsylvania, on November 27, 2013, as follows: David W. Knauer, Esquire David W. Knauer, P.C. 411-A East Main Street Mechanicsburg, PA 17055 (Counsel for Plaintiff) JOHNSON, DUFFIE, STEWART&WEIDNER BY: Urn Vk-k 'cv Y Connie S. Fritz .j 592995