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Home My WebLink About10-0948PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFILED, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 THIS IS AN ARBITRATION MATTER ATTORNEY FOR PLAINTIFF ERIE INSURANCE EXCHANGE AS COMMON PLEAS COURT SUBROGEE OF LEO PISCIONERI AND CUMBERLAND COUNTY LEO PISCIONERI AND MARIE PISCIONERI P.O. BOX 2013 MECHANICSBURG, PA 17055 VS. CRAIG WILLIAM HARDCASTLE 309 HUMMEL AVENUE, APT 2 LEMOYNE, PA 17043 I_TTE NO. ?? - 4Slg U J f D Z :i O D JL" c? v ? RICKY JAMES SISCO ; 1003 WALNUT STREET LEMOYNE, PA 17043 NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES. YOU MUST TAKE ACTION WITHIN TWENTY ((20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRfTTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER„ GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 Lawyer Referral Service 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 CIVIL COMPLAINT AVISO Le han demandado a usted an Is torte. Si usted quiers defenderse de estas demandas expuestas on las paginas siguientes, usted tiene (20) dies de plazo a partir de Is fecha de Is demands y Is notification. Listed debe presenter una apariencia eaaita o an persona o por abogado y archivar an Is torte sus defenses o sus objeciones a [as demandas encontra de su persona. Sea avisado quo si usted no se defiende, Is Corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notficacion o por c usIgier queja o alivio qua espedido an Is petioioon de demands. Usted puede perder dinero, sus propiedades o otros derechos importantes pars usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE PARA PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE USTED PUEDE CONSEGUIR ASISTENCIA LEGAL. Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 Lawyer Referral Service 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 S z'4a. acs i?? ?? e ?. ?oryd l? a2 3 7?, U PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFILED, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 THIS IS AN ARBITRATION MATTER ATTORNEY FOR PLAINTIFF ERIE INSURANCE EXCHANGE AS COMMON PLEAS COURT SUBROGEE OF LEO PISCIONERI AND CUMBERLAND COUNTY LEO PISCIONERI AND MARIE PISCIONERI P.O. BOX 2013 MECHANICSBURG, PA 17055 VS. CRAIG WILLIAM HARDCASTLE NO. 309 HUMMEL AVENUE, APT 2 / LEMOYNE, PA 17043 AND RICKY JAMES SISCO 1003 WALNUT STREET LEMOYNE, PA 17043 CIVIL COMPLAINT NOTICE UNDER THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.U. §1601 (AS AMENDED) THE PENNSYLVANIA UNFAIR TRADE PRACTICES ACT AND CONSUMER PROTECTION LAW, 73 PA.CON.STAT.ANN.§201, ET. SEQ. ("THE ACTS") IN AS MUCH AS THE ACTS MAY APPLY, PLEASE BE ADVISED THAT THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. The Plaintiff, Erie Insurance Exchange, by its attorney Paul F. D'Emilio, Esquire bring action upon a cause whereof the following is a statement: The Plaintiff. Erie Insurance Exchange ("Plaintiff'), is a corporation authorized to do business in the Commonwealth of Pennsylvania, having an mailing address of P.O. Box 2013, Mechanicsburg, PA 17055. Plaintiff brings this action as subrogee of Leo Piscioneri and Marie Piscioneri, herein the ("Insured") under a policy of insurance issued by Plaintiff. 2. Defendant, Craig William Hardcastle, is an individual residing at 309 Hummel Avenue, Apt. 2, Lemoyne, PA 17043. 3. Defendant, Ricky James Sisco, is an individual residing at 1003 Walnut Street, Lemoyne, PA 17043. 4. At all times hereinafter mentioned Defendant Craig William Hardcastle was the agent, workman, servant, employee of Defendant Ricky James Sisco then and there in engaged in the business of Defendant Ricky James Sisco within the course and scope of his employment. 5. On or about February 23, 2008, a motor vehicle owned by Defendant Ricky James Sisco and operated by Defendant Craig William Hardcastle was traveling westbound on Simpson Ferry Road, Lower Allen Township, Pennsylvania when he attempted to make a left turn in front of Plaintiffs Insured's vehicle causing the vehicle to collided and causing the damages hereinafter set forth. 6. Plaintiff avers that the personal property of the Insured was damaged as a result of the occurrence hereinbefore mentioned, the reasonable costs of repairs thereto being is Three Thousand Eight Hundred Seventy Five and 03/100 ($3,875.03) Dollars plus the Insured's deductible of Two Hundred Fifty and 001100 ($250.00) Dollars for a total of Four Thousand One Hundred Twenty Five and 03/100 ($4,125.03) Dollars. A true and correct copy of the estimate is attached hereto, made part hereof and marked Exhibit "A." Count I Erie Insurance Exchange v. Craig William Hardcastle 7. Plaintiff, incorporates by reference all the allegations contained in paragraphs 1 through 6 inclusive of this Complaint as fully as though same were herein and set forth at length. 8. The said occurrence was due to the negligence of Defendant, Craig William Hardcastle, in that he: a. did fail to have the motor vehicle under proper and adequate control; b. did operate the motor vehicle at an excessive rate of speed; C. did fail to apply the brakes in time to avoid the collision; d. did negligently apply the brakes; e. did fail to operate the vehicle in accordance with existing conditions; f. did fail to drive at a speed and in the manner that would allow him to stop within the assured clear distance ahead; g. did fail to keep a reasonable lookout for other vehicles lawfully on the road; h. did operate the motor vehicle without due regards for the rights, safety and position of the Insured at the point of aforesaid; did operate the vehicle without Insurance; did fail to maintain financial responsibility; and k. did violate the various statutes and laws of the Commonwealth of Pennsylvania and County of Cumberland pertaining to the operation of motor vehicles. Count II Erie Insurance Exchange v. Ricky James Sisco 9. Plaintiff, incorporates by reference all the allegations contained in paragraphs 1 through 8 inclusive of this Complaint as fully as though same were herein and set forth at length. 10. The said occurrence was due to the negligence of Defendant, Ricky James Sisco, in that he: a. negligently entrusted his vehicle to another operator for use when he knew, or with a reasonable exercise of due care should have known, that the operator was not capable of operating the motor vehicle properly; b. negligently entrusted his motor vehicle to a person which he knew, or in the exercise of reasonable care should have known, was an incompetent driver; C. negligently entrusted his motor vehicle to a person known, should have known or in the exercise of reasonable care would have known, was going to drive the vehicle in an improper, dangerous or reckless manner; d. negligently entrusted his motor vehicle to another person who he knew, should have known or in the exercise of due care would have known would cause damages to another; and e. negligently entrusted his motor vehicle to a person who did not maintain financial responsibility as required by the laws of the Commonwealth of Pennsylvania. WHEREFORE, Plaintiff demands judgment against the Defendant upon each court in an amount not in excess of Fifty Thousand and 00/100 ($50,000.00) dollars together with costs of suit. Date Aao'.'a'_ Paul F. D'Emilio, Esquire Identification No. 16654 E-mail address: pauld -demiliolaw.com Paul M. Schofield, Jr., Esquire Identification No. 81894 E-mail address: gauls _demiliolaw.com 905 W. Sproul Road, Suite 105 Springfield, PA 19064 Telephone No.: 610-338-0338 Fax no.: 610-338-0303 //I? VERIFICATION (,bltSllage-e ,W 4"" /,-S , Subrogation Specialist with Erie Insurance Exchange in the above captioned matter verifies that the facts contained in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalites of 18 pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: Subrogation Specialist Exhibit "A" 0 • 03/17/2008 Claims Management System CSPP032B 09:29 Check Print Page: 1 Req: ROWLES C -------------------------------------------------------------------------------- CHECK NO 26576021 CMS NO Z576021 DATE 03/06/2008 Pay THREE THOUSAND EIGHT HUNDRED SEVENTY-FIVE AND 03/100 $$$$$$3,875.03 LEO V PISCIONERI & MARIA T PISCIONERI Operator Loss Date To The 1807 WILLOW RD 35NMURLATT 02/23/2008 Order CAMP HILL PA 17011-7453 of Claim Tax Id No 017-010170966678 For PAYMENT OF COLLISION 1996 TOYOTA CAMRY LE 4D SED MAT 18LTR 0 0 03/06/2008 AT 10:46 AM Req: ROWLES ,C 010170966678001 ERIE INSURANCE GROUP HARRISBURG OFFICE P.O. BOX 621 BOILING SPRINGS, PA 17007-0621 (717)486-8756 FAX: (717)486-4056 ESTIMATE OF RECORD WRITTEN BY: C. STEINER #152145 03/06/2008 10:35 AM ADJUSTER: C. STEINER #152145 (717)486-8756 INSURED: OWNER: ADDRESS: EVENING: DAY: LEO PISCIONERI LEO PISCIONERI MARIA T PISCIONERI 1807 WILLOW RD CAMP HILL, PA 17011-0000 (717)763-5507 (717)506-3010 INSPECT MARIA T PISCIONERI LOCATION: 1807 WILLOW RD CAMP HILL, PA 17011-0000 REPAIR FREYSINGER PONTIAC, INC. FACILITY: ATT: BODY SHOP 100 E. 15TH STREET NEW CUMBERLAND, PA 17070 1996 TOYO CAMRY LE 4-2 VIN: 4T1BG12K5TV781986 CONDITION: GOOD AIR CONDITIONING CRUISE CONTROL BODY SIDE MOLDINGS POWER STEERING POWER LOCKS AM RADIO CASSETTE CLOTH SEATS AUTOMATIC TRANSMISSION EVENING: (717)763-5507 HOME BUSINESS: (717)774-7346 5 DAYS TO REPAIR LICENSE # 231491072 2L-FI 4D SED BEIGE INT:TAN LIC: DAF5182 PA PROD DATE: 04/1996 ODOMETER: 31150 REAR DEFOGGER INTERMITTENT WIPERS DUAL MIRRORS POWER BRAKES POWER ANTENNA FM RADIO DRIVER AIR BAG BUCKET SEATS OVERDRIVE TILT WHEEL TINTED GLASS CLEAR COAT PAINT POWER WINDOWS POWER MIRRORS STEREO PASSENGER AIR BAG RECLINE/LOUNGE SEATS FULL WHEEL COVERS --------- NO. ------- OP. -------------------------------- DESCRIPTION ----- ---- QTY -- ------------ EXT. PRICE ---------------- LABOR PAINT --------- 1 ------- -------------------------- INFORMATION LABELS - -- ----------- ---------------- 2 RPL INFORMATION LABELS 0.3 3 REPL INFO LABEL MAINTENANCE LABEL 1 3.00 INCL. 4 REPL EMISSION LABEL 4 CYLINDER 1 4.63 INCL. FEDERAL 5 REPL VACUUM DIAGRAM 4 CYLINDER 1 3.32 INCL. MANUAL TRANS 6 FRONT BUMPER iH BUMPER ASSY 2.8 :4 k RE?", A j l1 BUMPER COVER i 195. 0 0 i:NCL. 2. 5 CLAIM #010170966678001 POLICY #Q061402335 DATE OF LOSS: 02/23/2008 AT 03:24 PM TYPE OF LOSS: COLLISION POINT OF IMPACT: 12. FRONT 0 0 03/06/2008 AT 10:46 AM Req: ROWLES ,C 010170966678001 ESTIMATE OF RECORD 1996 TOYO CAMRY LE 4--2.2L-FI 4D SED BEIGE INT:TAN --------- NO. ------- OP. ---------------------------- ---- DESCRIPTION -------------------- ---- QTY ----- ------------------ EXT. PRICE LABOR ----------------- -- -- -------- PAINT -------- --------- 9 ------- ------------ ADD FOR CLEAR COAT 1.0 10** REPL A/M LT END SUPPORT 1 16.00 INCL. ll** REPL A/M END SUPPORT RETAINER 1 17.00 INCL. UPPER US BUILT 12** REPL A/M END SUPPORT RETAINER LOWER 1 21.00 INCL. 13 REPL FILLER 1 18.12 INCL. 14** REPL A/M ABSORBER US BUILT 1 80.00 INCL. 15** REPL A/M UPPER REINF US BUILT 1 53.00 INCL. 1.0 16 ADD FOR CLEAR COAT 0.4 17 REPL UPPER REINF SEAL 1 1S.92 INCL. 18** REPL A/M RT EXTENSION US BUILT 1 38.00 INCL. N 19* REPL USED REINF BEAM +25$ 1 125.00* INCL.* 20** REPL A/M LT EXTENSION US BUILT 1 38.00 INCL. 21** REPL A/M RT ARM 1 27.00 INCL. 22** REPL A/M LT ARM 1 27.00 INCL. 23 GRILLE 24** REPL A/M GRILLE US BUILT 1 46.00 INCL. 0.8 25 R&I EMBLEM GOLD PACKAGE INCL. 26 FRONT LAMPS 27 R&I RT HEADLAMP ASSY US BUILT INCL. 28 REPL LT HEADLAMP ASSY US BUILT 1 265.79 INCL. 29 AIM HEADLAMPS 0.5 30 RADIATOR SUPPORT 31 0/H RADIATOR SUPT S 8.5 32 REPL UPPER TIE BAR 1 168.76 SINCL. 0.4 33 REPL LT SIDE SUPPORT 1 19.13 SINCL. 0.3 34 REPL LATCH SUPPORT 1 31.33 INCL. 35 REPL LT GUSSET 1 44.16 SINCL. 0.3 36 REPL LT DEFLECTOR SIDE 1 30.09 0.2 37 REPL DEFLECTOR LOWER 1 25.01 0.2 38 COOLING 39 R&I RADIATOR ASSY AUTO TRANS MINCL. M 40 AIR CONDITIONER & HEATER 41 REPL EVACUATE & RECHARGE 1 M 1.4 M 42 REPL REFRIGERANT RECOVERY 1 M 0.4 M 43 R&I CONDENSER 4 CYLINDER US BUILT MINCL. M 44 HOOD 45 REPL HOOD 1 523.14 1.2 3.0 46 OVERLAP MAJOR NON-ADJ. PANEL -0.2 47 ADD FOR CLEAR COAT 0.6 4S ADD FOR UNDERSIDE(COMPLETE) 1.5 49 REPL INSULATOR RETAINER 5 3.55 50 FENDER 51 BLND LT FENDER 1.2 N 52* RPR RT FENDER. 0.3* 1.3* 5? OVERLAP MAJOR ADJ. PANEL -0.4 -; ADD FOR -'LEAR COAT 0. 3 5 Kc= FT FENDER LIiIER i£TCL r ? 03/06/2008 AT 10:46 AM Req: ROWLES ,C 010170966678001 ESTIMATE OF RECORD 1996 TOYO CAMRY LE 4-2.2L-FI 4D SED BEIGE INT:TAN --------- NO. ------- OP. ------------------------------- DESCRIPTION -------------- ---- QTY ----- ------------ EXT. PRICE ----------- ---------------- LABOR PAINT ------------- --------- 56 ------- R&I ----------------- LT FENDER LINER --- INCL. 57 R&I RT UPPER MOLDING ALL US BUILT 0.3 58 R&I LT UPPER MOLDING ALL US BUILT 0.3 59 R&I RT MUD GUARD 0.3 60 R&I LT MUD GUARD 0.3 61* RPR LT SIDE RAIL S 1.0* 0.4* 62 REPL LT EXTENSION 1 30.09 63 REPL RT FRONT PLATE 1 40.10 64 REPL LT FRONT PLATE 1 40.10 654 MISCELLANEOUS OPERATIONS 1 66# FLEX AGENT 1 6.00 T 674 WELD THRU PRIMER 1 1.00 T 68# COVER CAR 1 5.00 T 0.2 69# R134 FREON 1 15.00 T 70# MASK JAMBS 1 T 0.4 71# HAZARDOUS WASTE 1 3.50 T 72# SHORT SET / COLLISION PULL 1 1.0 F 73# ALIGN FRONT SHEET METAL 1 T 1.0 F --------- -------- ------------------------------- SUBTOTALS ==> ----- -------- 1979.74 --- ---------------- 20.6 14.9 LINE 19 : USED PARTS FROM: AUMILLERS WEST, PH #800-521-0261 SPOKE W/BARRY REFERENCE QUOTE #306BB LINE 52 : NOTE!! SUFFICIENT AREA TO REFINISH COLOR BY BLEND WITHIN PANEL. -------------------------------------------------------------------------------- ESTIMATE NOTES: AGREED PRICE FIGURE / REPAIR CYCLE TIME OF ( 8 ) DAYS REVIEWED WITH OWNER AND SHOP MANAGER: DICK WOLL PARTS 1949.24 BODY LABOR 16.8 HRS 'i$ 44.00/HR 739.20 PAINT LABOR 14.9 HRS Q$ 44.00/HR 655.60 MECHANICAL LABOR 1.8 HRS C$ 54.00/HR 97.20 FRAME LABOR 2.0 HRS 'a$ 46.00/HR 92.00 PAINT SUPPLIES 14.9 HRS ?$ 22.00/HR 327.80 SUBLET/MISC. -- -- - ---- ------- - 30.50 - --- -- ---- SUBTOTAL -- -- ---- ---------- $ -------- 3891.54 SALES TAX $ 3891. 54 5 . ?:1G0 233.49 TOTAL COST OF REPAIRS $ 4125.03 ADJ?TS'-J-MFNTS . DE D CT 13LE !;' . ; f) s 03/06/2008 AT 10:46 AM • Req: ROWLES ,C 010170966673001 ESTIMATE OF RECORD 1996 TOYO CAMRY LE 4-2.2L-FI 4D SED BEIGE INT:TAN ---------------------------------------------------- TOTAL ADJUSTMENTS $ 250.00 NET COST OF REPAIRS $ 3875.03 THIS IS NOT AN AUTHORIZATION TO REPAIR. THE VEHICLE OWNER MUST AUTHORIZE ALL REPAIRS. ERIE INSURANCE RESERVES THE RIGHT TO REINSPECT ALL SUPPLEMENTS BEFORE PAYMENT IS MADE. COSTS ABOVE THE APPRAISED AMOUNT MAY BE THE RESPONSIBILITY OF THE VEHICLE OWNER. THERE IS NO REQUIREMENT TO USE ANY SPECIFIED REPAIR SHOP. INFORMATION REGARDING REPAIR FACILITIES WHICH WILL BE ABLE TO REPAIR THE VEHICLE FOR THE APPRAISED AMOUNT MAY BE AVAILABLE FROM ERIE INSURANCE ON REQUEST. ABBREVIATIONS WHICH MAY HAVE BEEN USED IN THIS APPRAISAL ARE DEFINED AS FOLLOWS: D = DISCONTINUED PART, A = APPROXIMATE PRICE, B = BODY LABOR, D = DIAGNOSTIC, E = ELECTRICAL, F = FRAME, G = GLASS, M = MECHANICAL, P = PAINT LABOR, S = STRUCTURAL, T = TAXED MISCELLANEOUS, X = NON TAXED MISCELLANEOUS, ADJ = ADJACENT, A = ALIGN, A/M = AFTERMARKET, BLND = BLEND, CAPA = CERTIFIED AUTO PARTS ASSOCIATION, D&R = DISCONNECT AND RECONNECT, EST = ESTIMATE, EXT. PRICE = UNIT PRICE MULTIPLIED BY THE QUANTITY, INCL = INCLUDED, MISC = MISCELLANEOUS, NON - ADJ = NON ADJACENT, O/H = OVERHAUL, OP. = OPERATION, NO. = LINE NUMBER, QTY = QUANTITY, QUAL RECY = QUALITY RECYCLED PART, QUAL REPL = QUALITY REPLACEMENT PART, RECOND = RECONDITION, REFN = REFINISH, REPL = REPLACE, R&I = REMOVE AND INSTALL, R&R = REMOVE AND REPLACE, RPR = REPAIR, RT = RIGHT, SECT = SECTION, SUBL = SUBLET, USED = RECYCLED PARTS OF LIKE KIND AND QUALITY, OR BETTER, E.P.C. = ENVIRONMENTAL PROTECTION CHARGE, LT = LEFT, W/O = WITHOUT, W/ = WITH/, # = MANUEL LINE ENTRY, * = OTHER [ I.E., MOTORS DATABASE INFORMATION WAS CHANGED], ** = DATABASE LINE WITH AFTERMARKET PART INCLUDED, N= NOTES ATTACHED TO LINE. 0 03/06/2008 AT 10:46 AM • Req: ROWLES ,C 010170966678001 ESTIMATE OF RECORD 1996 TOYO CAMRY LE 4-2.2L-Fl 4D SED BEIGE INT:TAN ANY PERSON WHO KNOWINGLY AND WITH INTENT TO DEFRAUD ANY INSURANCE COMPANY OR OTHER PERSON FILES AN APPLICATION FOR INSURANCE OR STATEMENT OF CLAIM CONTAINING ANY MATERIALLY FALSE INFORMATION OR CONCEALS FOR THE PURPOSE OF MISLEADING, INFORMATION CONCERNING ANY FACT MATERIAL THERETO COMMITS A FRAUDULENT INSURANCE ACT, WHICH IS A CRIME AND SUBJECTS THE PERSON TO CRIMINAL AND CIVIL PENALTIES. ANY PERSON WHO KNOWINGLY AND WITH INTENT TO INJURE OR DEFRAUD ANY INSURER FILES AN APPLICATION OR CLAIM CONTAINING ANY FALSE, INCOMPLETE OR MISLEADING INFORMATION SHALL, UPON CONVICTION, BE SUBJECT TO IMPRISONMENT FOR UP TO SEVEN YEARS AND PAYMENT OF A FINE OF UP TO $15,000. THE FOLLOWING IS A LIST OF ABBREVIATIONS OR SYMBOLS THAT MAY BE USED TO DESCRIBE WORK TO BE DONE OR PARTS TO BE REPAIRED OR REPLACED:D=DISCONTINUED PART A=APPROXIMATE PRICE B=BODY LABOR D=DIAGNOSTIC E=ELECTRICAL F=FRAME G=GLASS M=MECHANICAL P=PAINT LABOR S=STRUCTURAL T=TAXED MISCELLANEOUS X=NON TAXED MISCELLANEOUS ADJ=ADJACENT ALGN=ALIGN A/M=AFTERMARKET BLND=BLEND CAPA=CERTIFIED AUTOMOTIVE PARTS ASSOCIATION D&R=DISCONNECT AND RECONNECT EST=ESTIMATE EXT. PRICE=UNIT PRICE MULTIPLIED BY THE QUANTITY INCL=INCLUDED MISC=MISCELLANEOUS NON-ADJ=NON ADJACENT 0/H=OVERHAUL OP=OPERATION NO=LINE NUMBER QTY=QUANTITY QUAL RECY=QUALITY RECYCLED PART QUAL REPL=QUALITY REPLACEMENT PART COMP REPL PARTS=COMPETITIVE REPLACEMENT PARTS RECORD=RECONDITION REFN=REFINISH REPL=REPLACE R&I=REMOVE AND INSTALL R&R=REMOVE AND REPLACE RPR=REPAIR RT=RIGHT SECT=SECTION SUBL=SUBLET LT=LEFT W/O=WITHOUT W/_=WITH/_ #=MANUAL LINE ENTRY *=OTHER [IE..MOTORS DATABASE INFORMATION WAS CHANGED]. **=DATABASE LINE WITH AFTERMARKET N=NOTES ATTACHED TO LINE NAGS=NATIONAL AUTO GLASS SPECIFICATIONS. MQVP=MANUFACTURER'S QUALITY AND VALIDATION PROGRAM.OPT OEM=ORIGINAL EQUIPMENT MANUFACTURER PARTS EITHER OPTIONALLY SOURCED OR OTHERWISE PROVIDED WITH SOME UNIQUE PRICING OR DISCOUNT. NWCPP=NATIONWIDE CRASH PARTS PROGRAM. THE ATTACHED ESTIMATE REPRESENTS AN APPRAISAL OF THE COST OF REPAIR FOR THE VISIBLE DAMAGE TO THE VEHICLE NOTED AT THE TIME OF INSPECTION NECESSARY TO RETURN THE VEHICLE TO ITS PREDAMAGED CONDITION. COSTS ABOVE THE APPRAISED AMOUNT MAY BE THE RESPONSIBILITY OF THE VEHICLE OWNER. THERE IS NO REQUIREMENT THAT THE VEHICLE OWNER USE ANY SPECIFIED REPAIR SHOP. INFORMATION REGARDING REPAIR FACILITIES WHICH WILL BE ABLE TO REPAIR THE VEHICLE FOR THE APPRAISED AMOUNT IS AVAILABLE FROM THE INSURANCE COMPANY. IF USED PARTS ARE SPECIFIED, THEY ARE REQUIRED TO BE OF LIKE KIND AND QUALITY TO THOSE BEING REPLACED. INCIDENTAL CHARGES SUCH AS TOWING, PROTECTIVE CARE, CUSTODY, STORAGE, DEPRECIATION, BATTERY AND TIRE REPLACEMENT ARE NOTED WHEN APPLICABLE. AFTERMARKET CRASH PART - A NONORIGINAL EQUIPMENT MANUFACTURER (NON-OEM) REPLACEMENT PART, EITHER NEW OR USED, FOR ANY OF THE NONMECHANICAL PARTS THAT GENERALLY CONSTITUTE THE EXTERIOR OF THE :MOTOR. VEHICLE, INCLUDING INNER AND CUTER PANELS. THIS APPRAISAL WILL INDICATE IF AFTERMARKET CRASH PARTS ARE SPECIFIED. IF THE USE OF SUCH PARTS VOIDS THE WARRANTY ON THE PART BEING REPLACED OR ON ANY OTHER PART, THE AFTER MARKET CRASH PART WILL BE WARRANTED BY THE MANUFACTURER OR INSURANCE COMPANY EQUAL TO OR BETTER THAN THE REMAINDER OF THE EXISTING WARRANTY. 0 03/06/2008 AT 10:46 AM Req: ROWLES ,C 010170966678001 ESTIMATE OF RECORD 1996 TOYO CAMRY LE 4-2.2L-FI 4D SED BEIGE INT:TAN IF THIS ESTIMATE INDICATES "USED" PARTS WERE SPECIFIED, THEY ARE TO BE OF LIKE KIND AND QUALITY, OR BETTER. IF THIS ESTIMATE INDICATED "A/M"', AFTERMARKET CRASH PARTS WERE SPECIFIED, THESE REPLACEMENT PARTS ARE FROM NONORIGINAL EQUIPMENT MANUFACTURERS. USUALLY, AFTERMARKET PARTS ARE USED ON THE EXTERIOR OF THE MOTOR VEHICLE, INCLUDING INNER AND OUTER PANELS. IF THIS APPRAISAL INDICATES IT INCLUDES AFTERMARKET CRASH PARTS, AND IF THE USE OF AFTERMARKET CRASH PART OR PARTS VOIDS THE EXISTING WARRANTY ON THE PART BEING REPLACED, OR ANY OTHER PART, THE AFTERMARKET CRASH PART SHALL HAVE A WARRANTY EQUAL TO OR BETTER THAN THE REMAINING WARRANTY OF THE PART BEING REPLACED, PROVIDED BY THE PART MANUFACTURER AND ERIE INSURANCE. ESTIMATE BASED ON MOTOR CRASH ESTIMATING GUIDE. UNLESS OTHERWISE NOTED ALL ITEMS ARE DERIVED FROM THE GUIDE AEM8498, CCC DATA DATE 02/01/2008, AND THE PARTS SELECTED ARE OEM-PARTS MANUFACTURED BY THE VEHICLES ORIGINAL EQUIPMENT MANUFACTURER. OEM PARTS ARE AVAILABLE AT OE/VEHICLE DEALERSHIPS. OPT OEM (OPTIONAL OEM) OR ALT OEM (ALTERNATIVE OEM) PARTS ARE OEM PARTS THAT MAY BE PROVIDED BY OR THROUGH ALTERNATE SOURCES OTHER THAN THE OEM VEHICLE DEALERSHIPS. OPT OEM OR ALT OEM PARTS MAY REFLECT SOME SPECIFIC, SPECIAL, OR UNIQUE PRICING OR DISCOUNT. OPT OEM OR ALT OEM PARTS MAY INCLUDE "BLEMISHED" PARTS PROVIDED BY OEM"S THROUGH OEM VEHICLE DEALERSHIPS. ASTERISK (*) OR DOUBLE ASTERISK (**) INDICATES THAT THE PARTS AND/OR LABOR INFORMATION PROVIDED BY MOTOR MAY HAVE BEEN MODIFIED OR MAY HAVE COME FROM AN ALTERNATE DATA SOURCE. TILDE SIGN M ITEMS INDICATE MOTOR NOT-INCLUDED LABOR OPERATIONS. NON-ORIGINAL EQUIPMENT MANUFACTURER AFTERMARKET PARTS ARE DESCRIBED AS AM, QUAL REPL PARTS OR COMP REPL PARTS WHICH STANDS FOR COMPETITIVE REPLACEMENT PARTS. USED PARTS ARE DESCRIBED AS LKQ, QUAL RECY PARTS, RCY, OR USED. RECONDITIONED PARTS ARE DESCRIBED AS RECOND. RECORED PARTS ARE DESCRIBED AS RECORE. NAGS PART NUMBERS AND BENCHMARK PRICES ARE PROVIDED BY NATIONAL AUTO GLASS SPECIFICATIONS. LABOR OPERATION TIMES LISTED ON THE LINE WITH THE NAGS INFORMATION ARE MOTOR SUGGESTED LABOR OPERATION TIMES. NAGS LABOR OPERATION TIMES ARE NOT INCLUDED. POUND SIGN (#) ITEMS INDICATE MANUAL ENTRIES. SOME 2006 VEHICLES CONTAIN MINOR CHANGES FROM THE PREVIOUS YEAR. FOR THOSE VEHICLES, PRIOR TO RECEIVING UPDATED DATA FROM THE VEHICLE MANUFACTURER, LABOR AND PARTS DATA FROM THE PREVIOUS YEAR MAY BE USED. THE PATHWAYS ESTIMATOR HAS A COMPLETE LIST OF APPLICABLE VEHICLES. PARTS NUMBERS AND PRICES SHOULD BE CONFIRMED WITH THE LOCAL DEALERSHIP. CCC PATHWAYS - A PRODUCT OF CCC INFORMATION SERVICES INC. 0 03/06/2008 AT 10:46 AM 0 Req: ROWLES ,C 010170966678001 ESTIMATE OF RECORD 1996 TOYO CAMRY LE 4-2.2L-FI 4D SED BEIGE INT:T_zLN ALTERNATE PARTS SUPPLIERS 24 A/M GRILLE US BUILT PART NO. T01200188 PRICE 46.00 KEYSTONE - COMPLETE (800)438-2510 320 DOBSON ST. (814)467-5531 WINDBER, PA 15963 KEYSTONE - COMPLETE (800)390-4600 822 CENTRAL AVE. (410)636-4600 LINTHICUM, MD 21090 KEYSTONE - COMPLETE (800)441-4200 3658 ROUTE 378 (610)866-0313 BETHLEHEM, PA 18015 KEYSTONE - COMPLETE (800)524-4349 S75 MARYLAND AVENUE (717)843-8927 YORK, PA 17404 KEYSTONE - COMPLETE (800)446-7066 433 LAWRENCE STREET (717)457-6464 OLD FORGE, PA 18518 KEYSTONE - COMPLETE (877)708-4700 MARKET AT JEFFERSON ST. (856)829-4700 PALMYRA, NJ 08065 8 A/M BUMPER COVER PART NO. 8181 904 PRICE 195.00 10 A/M LT END SUPPORT PART NO. 8181 227 PRICE 16.00 11 A/M END SUPPORT RETAINER UP PART NO. 8181 7501 PRICE 17.00 12 A/M END SUPPORT RETAINER LO PART NO. 8181 759 PRICE 21.00 14 A/M ABSORBER US BUILT PART NO. 8181 241 PRICE 80.00 15 A/M UPPER REINF US BUILT PART NO. 8181 223 PRICE 53.00 18 A/M RT EXTENSION US BUILT PART NO. 8181 756 PRICE 38.00 20 A/M LT EXTENSION US BUILT PART NO. 8181 755 PRICE 38.00 21 A/M RT ARM PART NO. 8181 752 PRICE 27.00 22 A/M LT ARM PART NO. 8181 751 PRICE 27.00 ACTION CRASH PARTS OF CENTRAL PA (388)803-8592 269 RIVER ROAD YORK HAVEN, PA 17370 7 03/06/2008 AT 10:46 AM • Req: ROWLES ,C 010170966678001 ESTIMATE OF RECORD 1996 TOYO CAMRY LE 4-2.2L-FI 4D SED BEIGE INT:TAN ALTERNATE PARTS USAGE AFTERMARKET PARTS AFTERMARKET SELECTION METHOD: AUTOMATICALLY LIST NO. OF TIMES USER WAS NOTIFIED THAT AN AFTERMARKET PART WAS AVAILABLE: 20 NO. OF AFTERMARKET PARTS THAT APPEAR IN THE FINAL ESTIMATE: 11 OPTIONAL OEM PARTS OPTIONAL OEM SELECTION METHOD: MANUALLY LIST NO. OF TIMES USER WAS NOTIFIED THAT AN OPTIONAL OEM PART WAS AVAILABLE: 0 NO. OF OPTIONAL OEM PARTS THAT APPEAR IN THE FINAL ESTIMATE: 0 RECONDITIONED PARTS RECONDITIONED SELECTION METHOD: MANUALLY LIST NO. OF TIMES USER WAS NOTIFIED THAT A RECONDITIONED PART WAS AVAILABLE: 1 NO. OF RECONDITIONED PARTS THAT APPEAR IN THE FINAL ESTIMATE: 0 RECYCLED PARTS NO. OF TIMES USER WAS NOTIFIED THAT A RECYCLED PART WAS AVAILABLE: 7 NO. OF RECYCLED PARTS THAT APPEAR IN THE FINAL ESTIMATE: 1 3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff LW FLED- ? F. C7A W THE Jody S Smith Chief Deputy Edward L Schorpp Solicitor 2014 FEB 16 P 2:12 F-i Erie Insurance Exchange vs. Craig William Hardcastle Case Number 2010-948 SHERIFF'S RETURN OF SERVICE 02/05/2010 03:10 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on March 5, 2010 at 1510 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Craig William Hardcastle, by making known unto herself personally, at 1003 Walnut Street, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. 02/09/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Ricky James Sisco, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Ricky James Sisco. The Lemoyne Postmaster has advised the defendant's new address is 1505 Crums Mill Road, Harrisburg, PA 17110. SHERIFF COST: $77.80 February 09, 2010 SERS, ROY ANDERSON, SHERIFF By 40'01X De ty Shari_ff Coum SuRe Shenft. ieeo.=.ott Inc, PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFILED, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 THIS IS AN ARBITRATION MATTER ATTORNEY FOR PLAINTIFF ERIE INSURANCE EXCHANGE AS COMMON PLEAS COURT SUBROGEE OF LEO PISCIONERI AND CUMBERLAND COUNTY LEO PISCIONERI AND MARIE PISCIONERI P.O. BOX 2013 MECHANICSBURG, PA 17055 VS. CRAIG WILLIAM HARDCASTLE 309 HUMMEL AVENUE, APT 2 LEMOYNE, PA 17043 AND RICKY JAMES SISCO 1003 WALNUT STREET LEMOYNE PA 17043 NO. 10-948 Civil Term c- - ?J CIVIL COMPLAINT G? PRAECIPE TO REINSTATE THE COMPLAINT TO THE PROTHONOTARY, C.P.: Kindly reinstate the Complaint in the above-captioned matter. ftVL F. D'EMILIO, ESQUIRE ATTORNEY FOR PLAINTIFF 0 c_f r7i $10. 00 PZ AT-rf Ce 10,7 48 I? a sw (o7 1 PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFILED, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 THIS IS AN ARBITRATION MATTER ATTORNEY FOR PLAINTIFF ERIE INSURANCE EXCHANGE AS COMMON PLEAS COURT SUBROGEE OF LEO PISCIONERI AND CUMBERLAND COUNTY LEO PISCIONERI AND MARIE PISCIONERI P.O. BOX 2013 . MECHANICSBURG, PA 17055 VS. . CRAIG WILLIAM HARDCASTLE NO. 10-948 -CIVIL 12!R W 309 HUMMEL AVENUE, APT 2 LEMOYNE, PA 17043 t 211 ; , AND r% _, .. _.. RICKY JAMES SISCO 1003 WALNUT STREET .. ± LEMOYNE, PA 17043 CIVIL COMPLAINT c PRAECIPE FOR JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY, C.P.: Enter Judgment in the above entitled matter in-favor of the Plaintiff, Erie Insurance Exchange, and against the Defendant, Craig William Hardcastle, for want of an answer, and assess Plaintiffs damages in the sum of $4,125.03 in accordance with a Complaint filed. PAUL F. D'EMIL O, SQUIRE ATTORNEY FOR PLAINTIFF ATTORNEY I.D. #16654 Pr assesses Plaintiffs damages in the sum of $4,125.03. PRO ROTHY $I4.oo PO A WY W11087 e 09013 A , PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFILED, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 THIS IS AN ARBITRATION MATTER ATTORNEY FOR PLAINTIFF ERIE INSURANCE EXCHANGE AS COMMON PLEAS COURT SUBROGEE OF LEO PISCIONERI AND CUMBERLAND COUNTY LEO PISCIONERI AND MARIE PISCIONERI P.O. BOX 2013 MECHANICSBURG, PA 17055 VS. CRAIG WILLIAM HARDCASTLE NO. 10-948 -CIVIL TERM 309 HUMMEL AVENUE, APT 2 LEMOYNE, PA 17043 AND RICKY JAMES SISCO 1003 WALNUT STREET LEMOYNE, PA 17043 CIVIL COMPLAINT AFFIDAVIT OF LAST KNOWN MAILING ADDRESS OF DEFENDANT AND PLAINTIFF Paul F. D'Emilio, Esquire, attorney for Plaintiff in the above-entitled matter hereby certifies that the following is the last known mailing address of the Defendant and Plaintiff: DEFENDANT: CRAIG WILLIAM HARDCASTLE 1003 WALNUT STREET LEMOYNE, PA 17043 PLAINTIFF: ERIE INSURANCE EXCHANGE P.O. BOX 2013 MECHANICSBURG, PA 17055 ?k'Afi" PAUL F. D'EMILIO, ESQUIRE ATTORNEY FOR PLAINTIFF I 1- PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFILED, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 THIS IS AN ARBITRATION MATTER ATTORNEY FOR PLAINTIFF ERIE INSURANCE EXCHANGE AS COMMON PLEAS COURT SUBROGEE OF LEO PISCIONERI AND CUMBERLAND COUNTY LEO PISCIONERI AND MARIE PISCIONERI P.O. BOX 2013 MECHANICSBURG, PA 17055 VS. CRAIG WILLIAM HARDCASTLE NO. 10-948 -CIVIL TERM 309 HUMMEL AVENUE, APT 2 LEMOYNE, PA 17043 AND RICKY JAMES SISCO 1003 WALNUT STREET LEMOYNE, PA 17043 CIVIL COMPLAINT AFFIDAVIT AS TO NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF DELAWARE PAUL F. D'EMILIO, being duly sworn according to law, deposes and says that he is the agent for the Plaintiff above-named and is authorized to and does make this Affidavit on its behalf; and that he has knowledge of the facts set forth herein: That Defendant, Craig William Hardcastle, is over twenty-one years of age and that he is not in the military service of the United States or otherwise within the provisions of the Soldier's and Sailor's Civil Relief Act of 1940 as amended. PAUIL F. D' ILIO, ESQUIRE SWORN TO AND SUBSCRIBED BEFORE ME THIS Ij DAY OF MARCH, 2010. cc mowmzA rr orr v" " NOTARIAL SEAL MELISSA O'NEILL, NOWY Pu* DdwmCaft NOTARY PUBLIC T"'p'' 6. A- . PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFILED, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 THIS IS AN ARBITRATION MATTER ATTORNEY FOR PLAINTIFF ERIE INSURANCE EXCHANGE AS COMMON PLEAS COURT SUBROGEE OF LEO PISCIONERI AND CUMBERLAND COUNTY LEO PISCIONERI AND MARIE PISCIONERI P.O. BOX 2013 , MECHANICSBURG, PA 17055 VS. , CRAIG WILLIAM HARDCASTLE NO. 10-948 -CIVIL TERM 309 HUMMEL AVENUE, APT 2 , LEMOYNE, PA 17043 , AND , RICKY JAMES SISCO , 1003 WALNUT STREET , LEMOYNE, PA 17043 CIVIL COMPLAINT AFFIDAVIT OF NOTICE OF INTENT TO ENTER DEFAULT JUDGEMENT I, PAUL F. D'EMILIO, ESQUIRE, attorney for the Plaintiff, Erie Insurance Exchange, does hereby certify that a Notice of Intent to Enter Default Judgement was mailed on February 25, 2010 to the Defendant listed below by Certificate of Mailing; a copy of the Notice and the original certification of mailing are attached hereto, made a part hereof, and marked Exhibit "A". Craig William Hardcastle 1003 Walnut Street Lemoyne, PA 17043 PAUL F. D'EMILIO, ESQUIRE ATTORNEY FOR PLAINTIFF 0- r Exhibit "A" PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFILED, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 THIS IS AN ARBITRATION MATTER ATTORNEY FOR PLAINTIFF ERIE INSURANCE EXCHANGE AS COMMON PLEAS COURT SUBROGEE OF LEO PISCIONERI AND CUMBERLAND COUNTY LEO PISCIONERI AND MARIE PISCIONERI P.O. BOX 2013 MECHANICSBURG, PA 17055 VS. CRAIG WILLIAM HARDCASTLE NO. 10-948 Civil Term 309 HUMMEL AVENUE, APT 2 LEMOYNE, PA 17043 AND RICKY JAMES SISCO 1003 WALNUT STREET LEMOYNE, PA 17043 CIVIL COMPLAINT DATE OF NOTICE: FEBRUARY 26, 2010 TO: CRAIG WILLIAM HARDCASTLE 1003 WALNUT STREET LEMOYNE, PA 17043 NOTICE OF INTENT TO ENTER DEFAULT JUDGMENT YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE FOR CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-316 ( i.,Aj 6 6" P UL F. D'EMILIO, ESQUIRE 07009?'G9 uivrr?osTarES =`` rasrac scare. ° "' ` f_nr4:fi.-eke ne ¦?:i Law Offices of Paul F. D'Emilio, LLC 905 W. Sproul Rd., Suite 105 'T Springfield, PA 19064 pA is I-JASLER tG (m C, To: Craig William Hardca a r0 1 u, ?' sv ? Cs7 III s 100, Wa mitt Lemoyne, PA 17043 2 ?Q € 6> ° ?? PS Form 3817, April 2007 PSN 7530-02-000-9065 US POSTAGE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW (Rule of Civil Procedure No. 236) ERIE INSURANCE EXCHANGE AS COMMON PLEAS COURT SUBROGEE OF LEO PISCIONERI AND CUMBERLAND COUNTY LEO PISCIONERI AND MARIE PISCIONERI P.O. BOX 2013 . MECHANICSBURG, PA 17055 VS. CRAIG WILLIAM HARDCASTLE NO. 10-948 -CIVIL TERM 309 HUMMEL AVENUE, APT 2 LEMOYNE, PA 17043 . AND RICKY JAMES SISCO 1003 WALNUT STREET . LEMOYNE PA 17043 CIVIL COMPLAINT Notice is given that a judgment in the above captioned matter has been entered against you on M ?h 11 , 2010. Prothonotary If you have any questions concerning the above please contact: Paul F. D'Emilio. Esauire Attorney or Party Filing 905 West Sproul Road. Suite 105 Address Springfield, PA 19064 City, State, Zip (610) 338-0338 Telephone Number SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson R.EQ-0FFXE Sheriff ? olt, at 4?e?raGrrf???? Jody S Smith `? 2010 MAR 22 AM 8: 39 OF 71-1E: Fpl?)? In, Chief Deputy Edward L Schorpp Solicitor ' Erie Insurance Group Case Number vs. 2010-948 Craig William Hardcastle (et al.) SHERIFF'S RETURN OF SERVICE 02/26/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Ricky James Sisco, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint and Notice according to law. 03/03/2010 Dauphin County Return: And now, March 3, 2010 I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Ricky James Sisco the defendant named in the within Complaint and Notice and that I am unable to find him in the County of Dauphin and therefore return same NOT FOUND. Chris Lattig, current resident of 1505 Crums Mill Road, Harrisburg, PA 17110 advised Deputies he collected Ricky James Sisco's mail while he was incarcerated. Ricky James Sisco does not reside at 1505 Crums Mill Road, Harrisburg, PA 17110 and Chris Lattig is not aware of his current whereabouts. SHERIFF COST: $37.00 March 19, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF 'C? I,0U'9tySu1tF_ ShP.1 ff_ TeIa;SOff MG PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFILED, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 THIS IS AN ARBITRATION MATTER ATTORNEY FOR PLAINTIFF ERIE INSURANCE EXCHANGE AS COMMON PLEAS COURT SUBROGEE OF LEO PISCIONERI AND CUMBERLAND COUNTY LEO PISCIONERI AND MARIE PISCIONERI P.O. BOX 2013 MECHANICSBURG, PA 17055 VS. CRAIG WILLIAM HARDCASTLE NO. 10-948 Civil Term 309 HUMMEL AVENUE, APT 2 • LEMOYNE, PA 17043 AND RICKY JAMES SISCO n ~ n ~ ~~~ 1003 WALNUT STREET CIVIL COMPLAI LEMOYNE PA 17043 ~~'' N`~~ ~- ._; f rX_.- .. PRAECIPE TO REINSTATE THE COMPLAINT ~y a ~ , r-~_ `Q ~ ` o TO THE PROTHONOTARY, C.P.: Kindly reinstate the Complaint in the above-captioned matter. '~1(.Cil L F. 'EMILIO, ESQUIRE ATTORNEY FOR PLAINTIFF $10•~O Pp pTM 2~ PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFILED, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 THIS IS AN ARBITRATION MATTER ATTORNEY FOR PLAINTIFF ERIE INSURANCE EXCHANGE AS COMMON PLEAS COURT SUBROGEE OF LEO PISCIONERI AND CUMBERLAND COUNTY LEO PISCIONERI AND MARIE PISCIONERI P.O. BOX 2013 . MECHANICSBURG, PA 17055 VS. . CRAIG WILLIAM HARDCASTLE NO. 10-948 Civil Term ~ ~ `~ 309 HUMMEL AVENUE, APT 2 ~ ~"` ~' -:~ "~ i '~'~ LEMOYNE, PA 17043 ~ _ l ~ AND ~Fw c{~;~ %i ~ . , .~ ~ ~ ~ ~ , _ ~ RICKY JAMES SISCO ~ .=__ 1003 WALNUT STREET ~ ~ - ~ < LEMOYNE. PA 17043 CIVIL COMPLAINT cs • - PRAECIPE TO REINSTATE THE COMPLAINT TO THE PROTHONOTARY, C.P.: Kindly reinstate the Complaint in the above-captioned matter. ~/'' AUL F. D'EMILIO, ESQUIRE ATTORNEY FOR PLAINTIFF O ~ lo. op P o A'1r/ ~~ 13090 ~.~ as ~ ss,~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Erie Insurance Company vs. Craig William Hardcastle (et al.) SHERIFF'S RETURN OF SERVICE F IL E:D-O FICE O-THONOTARY 4010 Stc? 20 PM 2: 2 1 - s; BERLAND COUN i Case Number 2010-948 09/08/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Ricky James Sisco, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint and Notice according to law. 09/13/2010 08:06 AM - Dauphin County Return: And now September 13, 2010 at 0806 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Ricky James Sisco by making known unto himself personally, at 4207 King George Drive #8, Harrisburg, PA 17109 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 September 17, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (J)tfirk Of the- *herrij Mary Jane Snder Real Estate Deputy William T. Tully Solicitor f t Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin ERIE INSURANCE COMPANY VS RICKY JAMES SISCO Sheriff s Return No. 2010-T-2948 And now: SEPTEMBER 13, 2010 at 8:06:00 AM served the within COMPLAINT upon RICKY JAMES SISCO by personally handing to RICKY JAMES SISCO 1 true attested copy of the original COMPLAINT and making known to him/her the contents thereof at 4207 KING GEORGE DR, # B HBG PA 17109 OTHER COUNTY CASE # 2010948 So Answers, kSheriff of Dauphin County, Pa. Deputy: W CONWAY Plaintiff: ERIE INSURANCE COMPANY Sheriffs Costs: $47.25 9/10/2010 Out Of County Cost: Sworn to and subscri d before me this ) da ?n ?! j-ern ' r A 1C) r COMMISSION EXFtRES 1ST MONDAY JANUARY, 20 'i_F0-0FFIC»: C+ " 'r N6 -- F' roT?1c?iOT;t R`? 2010 0 C T 12 1111 : 17 MJN5FRLP-.ND COUI1 PEHIN!cY! !1AH1IA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ERIE INSURANCE EXCHANGE AS CIVIL DIVISION SUBROGEE OF LEO PISCIONERI AND LEO PISCIONERI AND MARIE No.: 10-948 PISCIONERI, Plaintiff, PRAECIPE FOR APPEARANCE V. (Jury Trial Demanded) CRAIG WILLIAM HARDCASTLE AND RICKY JAMES SISCO, Defendants. Filed on Behalf of Defendant: Ricky Allen Sisco, incorrectly designated as Ricky James Sisco Counsel of Record for This Party: Jeffrey C. Catanzarite, Esquire PA I. D. #72765 Summers, McDonnell, Hudocik, Guthrie & Skeel, P.C. Firm No. 911 Gulf Tower, Suite 2400 707 Grant Street Pittsburgh, PA 15219 (412) 261-3232 #18138 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ERIE INSURANCE EXCHANGE AS CIVIL DIVISION SUBROGEE OF LEO PISCIONERI AND LEO PISCIONERI AND MARIE No.: 10-948 PISCIONERI, Plaintiff, v CRAIG WILLIAM HARDCASTLE AND RICKY JAMES SISCO, Defendants. PRAECIPE FOR APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the undersigned, Jeffrey C. Catanzarite, Esquire, of the law firm of Summers, McDonnell, Hudock, Guthrie & Skeel, P.C., on behalf of the Defendant, Ricky Allen Sisco, incorrectly designated as Ricky James Sisco, in the above case. JURY TRIAL DEMANDED Respectfully submitted, Su ers, McDonnell, Hudock, Guthrie Skeel, P.C. By: '?Lw Jeffa C. Catanzarite, Esquire Co el for Defendant, Ricky Allen Sisco, in rectly designated as Ricky James CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the within Praecipe for Appearance was served upon the following counsel of record on the 8t' day of October, 2010, by U.S. First Class Mail, postage prepaid: Paul M. Schofield, Jr., Esquire 905 W. Sproul Road, Suite 105 Springfield, PA 19064 By: immers, McDonnell, Hudock, Guthrie & $ "ell, P.C. Jeffr . Catanzarite, Esquire Cou s for Defendant, Ricky Allen Sisco, inc rr ctly designated as Ricky James IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ERIE INSURANCE EXCHANGE AS CIVIL DIVISION SUBROGEE OF LEO PISCIONERI AND LEO PISCIONERI AND MARIE No.: 10-948 PISCIONERI , ANSWER, NEW MATTER AND NEVI ~ ~ _ MATTER CROSS-CLAIM PURSU T~ ~_,., Plaintiff Pa. R.C.P. 1031.1 `~'_~~~ {~ 'mar= , .-..'~ 4~ v. (Jury Trial Demanded)`~~- ._ = ~ ~ `""'` CRAIG WILLIAM HARDCASTLE ~-~ ~ ~,, ~,-Y, AND RICKY JAMES SlSCO, _ _ ,a._ a~~ ~ _ . d ~~ Defendants. Filed on Behalf of Defendant: Ricky Allen Sisco, incorrectly designated as Ricky James Sisco Counsel of Record for This Party: Jeffrey C. Catanzarite, Esquire PA I.D. #72765 Summers, McDonnell, Hudock, Guthrie & Skeel, P.C. Firm No. 911 Gulf Tower, Suite 2400 707 Grant Street Pittsburgh, PA 15219 (412) 261-3232 TO: PLAINTIFF You are hereby notified to file a written response to the enGosed Answer, New Matter and New Matter Cross-Claim Pu nt Rule 1031.1 within twenty (20) days from se ice he eof or a judgm~t maw e~3ered against you. HUDOCK, #18138 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ERIE INSURANCE EXCHANGE AS CIVIL DIVISION SUBROGEE OF LEO PISCIONERI AND LEO PISCIONERI AND MARIE No.: 10-948 PISCIONERI, Plaintiff, v. CRAIG WILLIAM HARDCASTLE AND RICKY JAMES SISCO, Defendants. ANSWER, NEW MATTER AND NEW MATTER CROSS-CLAIM PURSUANT TO Pa. R.C.P. 1031.1 Defendant, Ricky Allen Sisco, incorrectly designated as Ricky James Sisco, by and through his attorneys, Summers, McDonnell, Hudock, Guthrie & Skeel, P.C., and Jeffrey C. Catanzarite, Esquire, files the following Answer, New Matter and New Matter Cross-Claim Pursuant to Pa. R.C.P. 1031.1: I. ANSWER 1. After reasonable investigation, the Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 1 and therefore, said allegations are denied and strict proof thereof is demanded at the time of trial. 2. After reasonable investigation, the Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 2 and therefore, said allegations are denied and strict proof thereof is demanded at the time of trial. 3. Denied. To the contrary, Defendant Sisco is an individual residing at 4207B King George Drive, Harrisburg, Pennsylvania 17109. 4. Denied. To the contrary, Defendant Sisco never provided permission to Defendant Hardcastle to operate the vehicle and, as such, Defendant Hardcastle was not acting as Defendant Sisco's agent, workman, servant, or employee on the date of the subject accident. The remaining allegations are denied pursuant to Rule 1029(d) and (e) of the Pennsylvania Rules of Civil Procedure. 5. The allegations of Paragraph 5 are conclusions of law to which no response is required. To the extent that a response is necessary, said averments are generally denied pursuant to Rule 1029(d) and (e) of the Pennsylvania Rules of Civil Procedure. 6. After reasonable investigation, the Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 6 and therefore, said allegations are denied and strict proof thereof is demanded at the time of trial. Count I Erie Insurance Exchange v. Craig William Hardcastle 7. Paragraphs 1 through 6 are herein incorporated by reference. 8. The allegations of Paragraph 8 and its subparts are not directed to this Defendant. Accordingly, no response is required from this Defendant. Count II Erie Insurance Exchange v. Ricky James Sisco 9. Paragraphs 1 through 8 are herein incorporated by reference. 10. The allegations of Paragraph 10 and its subparts are conclusions of law to which no response is required. To the extent that a response is necessary, said averments are generally denied pursuant to Rule 1029(d) and (e) of the Pennsylvania Rules of Civil Procedure. WHEREFORE, Defendant, Ricky Allen Sisco, incorrectly designated as Ricky James Sisco, demands judgment in his favor and against Plaintiff. II. NEW MATTER 11. Paragraphs 1 through 10 are herein incorporated by reference. 12. On February 23, 2008, Defendant, Ricky Allen Sisco, was incarcerated in the Cumberland County Prison. As a result, this Defendant was unable to provide permission to Co-Defendant, Craig William Hardcastle, to operate the motor vehicle on that date. 13. This Defendant avers that Defendant, Craig William Hardcastle, was not operating the vehicle as Defendant. Sisco's agent, workman, servant, or employee, or within the course and scope of any employment of Defendant Sisco on the date of the subject accident. 14. The Plaintiffs claims are barred by the applicable statute of limitations. 15. To the extent developed in discovery, this Defendant pleads all defenses applicable under Pa. R.C.P. 1030, including, but not {invited to, accord and satisfaction, arbitration and award, consent, discharge in bankruptcy, duress, estoppel, failure of consideration, fair comment, fraud, illegality, immunity from suit, impossibility of performance, justification, laches, license, payment, privilege, release, res judicata, statute of frauds, statute of limitations, and truth and waiver. 16. If the Plaintiff sustained damages as alleged in the Complaint, which is not admitted, the Plaintiffs injuries and damages were caused solely by the actions and/or inactions of parties other than Defendant, Ricky Allen Sisco, incorrectly designated as Ricky James Sisco, over whom Defendant Sisco exercised no control and for whose actions Defendant Sisco cannot be liable. WHEREFORE, Defendant, Ricky Allen Sisco, incorrectly designated as Ricky James Sisco, demands judgment in his favor and against Plaintiff. III. NEW MATTER CROSS-CLAIM PURSUANT TO RULE 1031.1 17. Paragraphs 1 through 16 are herein incorporated by reference. 18. In the event Plaintiff is entitled to recover from any Defendant, which is denied, then Defendant, Craig William Hardcastle, is directly and solely liable to the Plaintiff. 19. In the alternative, to the extent Plaintiffs allegations are true, which are admitted only to the extent set forth above, the Co-Defendant, Craig William Hardcastle, is jointly liable with Sisco and Sisco is entitled to contribution from Hardcastle. 20. To the extent Plaintiffs allegations are true, which are admitted only to the extent set forth above, Co-Defendant, Graig William Hardcastle, is {iable over to Sisco, and Sisco is entitled to indemnification from Hardcastle. WHEREFORE, Defendant, Ricky Allen Sisco, incorrectly designated as Ricky James Sisco, demands judgment in his favor. JURY TRIAL DEMANDED By: Respectfully submitted, Summers, McDonnell, Hudock, Guthrie & Skeel, P.C. l/L- r y C. Catanzarite, Esquire nsel for Defendant, Ricky Allen Sisco, orrectly designated as Ricky James isco VERIFICATION Defendant verifies that he/she is the Defendant in the foregoing action; that the foregoing Answer, New Matter and New Matter Cross-Claim Pursuant to Pa. R.C.P. 1031.1 is based upon information which he/she has furnished to his/her counsel and information which has been gathered by his/her counsel in the preparation of the lawsuit. The language of the Answer, New Matter and New Matter Cross-Claim Pursuant to Pa. R.C.P. 1031.1 is that of counsel and not of the Defendant. Defendant has read the Answer, New Matter and New Matter Cross-Claim Pursuant to Pa. R.C.P. 1031.1 and to the extent that the Answer, New Matter and New Matter Cross-Claim Pursuant to Pa. R.C.P. 1031.1 is based upon infom~ation which he/she has given to his/her counsel, it is true and correct to the best of his/her knowledge, information and belief. To the extent that the content of the Answer, New Matter and New Matter Cross-Claim Pursuant to Pa. R.C.P. 1031.1 is that of counsel, he/she has relied upon counsel in making this Affidavit. Defendant understands that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: / ~ d Ricky All Sisco, I Ricky James Sisco incorrectly designated as #18138 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the within Answer and New Matter was served upon the foNowing counsel of record on the ~~~'tlay of ~G~~ ~~~ , 2010, by U.S. First Class Mail, postage prepaid: Paul M. Schofield, Jr., Esquire 905 W. Sproul Road, Suite 105 Springfield, PA 19064 Craig William Hardcastle 309 Hummel Avenue, Apt. 2 Lemoyne, PA 17043 Summers, McDonnell, Hudock, Guthrie & Skeel, P.C. By: ~ J ey C. Catanzarite, Esquire unsel for Defendant, Ricky Allen Sisco, correctly designated as Ricky James Sisco d PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFILED, JR.., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 THIS IS AN ARBITRATION MATTER ATTORNEY FOR PLAINTIFF ERIE INSURANCE EXCHANGE AS SUBROGEE OF LEO PISCIONERI AND LEO PISCIONERI AND MARIE PISCIONERI VS. CRAIG WILLIAM HARDCASTLE AND RICKY JAMES SISCO CD COMMON PLEAS CT5 _ Y CUMBERLAND CO cn C " : 10-948 - CIVIL TEIgA NO . CIVIL COMPLAINT AFFIDAVIT MOTOR VEHICLE ACCIDENT hereby certify that the Judgment debtor, Craig William Hardcastle, is the same person who is the Defendant in the Cumberland County Common Pleas Action No. 10- 948, which was a result of a motor vehicle accident on February 23, 2008. P ML F. D'EMILIO, ESQUIRE SWORN TO AND SUBSCRIBED BEFORE ME THIS %t-t DAY OF eC 2010. NOTARY PUBLIC ??- m?. d' ?%LrH OF PENNSYLVANIA ITARIAL SEAL 01NEILL, Notary Public d T%,p., Delaware County I Ex iris Cecember 6-20-1 1 -4 5.00 p, r-, C' Issoo f PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFILED, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 THIS IS AN ARBITRATION MATTER ATTORNEY FOR PLAINTIFF ERIE INSURANCE EXCHANGE AS SUBROGEE OF LEO PISCIONERI AND LEO PISCIONERI AND MARIE PISCIONERI VS. CRAIG WILLIAM HARDCASTLE AND RICKY JAMES SISCO -v COMMON PLEAS Ct tT;;l r,- CUMBERLAND COIL( C° 'r Q NO 10-948 Civil Term; ° = . CIVIL COMPLAINT REPLY TO NEW MATTER The Plaintiff, Erie Insurance Exchange, by its attorney, Paul F. D'Emilio, Esquire, replies to the New Matter of the Defendant in the above-captioned matter and sets forth as follows: 11. Plaintiff incorporates by reference the allegations in the Complaint in paragraphs 1 through 10 inclusive as fully as though the same where herein set forth at length. 12. Denied. After a reasonable investigation, Plaintiff is without any knowledge or information sufficient to form a belief as to the truth of the averment and strict proof thereof is demanded at trial if relevant to the issue. 13. Denied. The allegation is a conclusion of fact and law and the facts upon which it is based are not pleaded with particularity as required by the Pennsylvania Rules of Civil Procedure. 14-16. Denied. The allegations are a conclusion of law to which no response is required by the Pennsylvania Rules of Civil Procedure. WHEREFORE, Plaintiff respectfully requests that the New Matter filed by the Defendant be stricken. Respectfully submitted, Paul F. D'Emilio, Esquire Attorney for Plaintiff 2 VERIFICATION Paul F. D'Emilio, Esquire, attorney for Plaintiff in the above-captioned matter verifies that the facts contained in the foregoing Reply to New Matter are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATE: 16A Paul F. UEmilio. Esquire Attorney for Plaintiff PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFILED, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 THIS IS AN ARBITRATION MATTER ATTORNEY FOR PLAINTIFF ERIE INSURANCE EXCHANGE AS COMMON PLEAS COURT SUBROGEE OF LEO PISCIONERI AND CUMBERLAND COUNTY LEO PISCIONERI AND MARIE PISCIONERI : VS. CRAIG WILLIAM HARDCASTLE NO. 10-948 Civil Term AND RICKY JAMES SISCO CIVIL COMPLAINT CERTIFICATE OF SERVICE I, Paul F. D'Emilio, Esquire, hereby certify that a true and correct copy of Plaintiff's Reply to New Matt in the above-entitled matter has been served upon the following person on the ?? day of January, 2011 by first-class U.S. Mail, postage prepaid: Jeffrey C. Catanzarite, Esquire Summers, McDonnell, Hudock, Guthrie & Skeel, P.C. Gulf Tower Suite 2400 77 Grant Street Pittsburgh, PA 15219 (412) 261-3232 ?y Paul F. D'Emilio, Esquire Attorney for Plaintiff PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFILED, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 THIS IS AN ARBITRATION MATTER cs ATTORNEY FOR PLAINTIFF- inn r N -n a rv ERIE INSURANCE EXCHANGE AS COMMON PLEAS C SUBROGEE OF LEO PISCIONERI AND CUMBERLAND COU LEO PISCIONERI AND MARIE PISCIONERI so VS. CRAIG WILLIAM HARDCASTLE NO. 10-948 Civil Term AND RICKY JAMES SISCO CIVIL COMPLAINT PRAECIPE TO SATISFY THE JUDGMENT TO THE PROTHONOTARY, P.C.: Satisfy the judgment against Craig William Hardcastle in the above-entitled matter upon payment of your costs only. N r•; C1.) -n zF -x' ul F. D'Emilio, Esquire Attorney for Plaintiff Qµt+ &R. b pi a#xl ?S3o3 Qrs. a55 476) PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFILED, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 THIS IS AN ARBITRATION MATT, W'. " C ) -vim -n : rn rn r? ° ? ro ATTORNEY FOR PLAINTIFe: 0, ERIE INSURANCE EXCHANGE AS COMMON PLEAS COW N ...? SUBROGEE OF LEO PISCIONERI AND CUMBERLAND COU .,., LEO PISCIONERI AND MARIE PISCIONERI : --l C:) VS. CRAIG WILLIAM HARDCASTLE NO. 10-948 Civil Term AND . RICKY JAMES SISCO CIVIL COMPLAINT ORDER TO SETTLE. DISCONTINUE AND END TO THE PROTHONOTARY, P.C.: Kindly mark the above entitled matter settled, discontinued and ended upon payment of your cost only. 90&14 Paul F. D'Emilio, Esquire Attorney for Plaintiff