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Home My WebLink About10-1154110 Firm File No.: 01-09-49 ")TARY THE LAW OFFICES OF STEWART C. CRAWFORD & ASSOCI ff' a 18 Pi 2. 31 By: Stewart C. Crawford, Sr., Esquire Attorney Id. No.. 09827 223 North Monroe Street r Media, PA 19063 Telephone: (877)-992-6311, ext. 14 Web: www.subrolaw.us E-Mail: sccrawford&subrolaw.us Attorney for Plaintiff, State Farm Mutual Automobile Insurance Company IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW STATE FARM MUTUAL AUTOMOBILE : IN CIVIL LAW INSURANCE COMPANY P.O. Box 2371 Bloomington, IL 61702 NO. t0 - l t54 vi l lErbK V. NATALIE MINARDO 379 Melbourne Place Mechanicsburg, PA 17055 and SUSAN MINARDO 19 Argali Lane Mechanicsburg, PA 17055 COMPLAINT Motor Vehicle Property Damage 1. Plaintiff is an insurance company licensed and authorized to do business in the Commonwealth of Pennsylvania with one of its principle places of business at the above captioned address. 2. Defendant, Natalie Minardo, is an adult individual and was the owner of the motor vehicle involved in this incident on April 24, 2008, and at all times pertinent hereto resided at the above-captioned address. 0 *ga.oo Po ATTY &-r1wo4 0*-a 5'7'7s9 1 3. Defendant, Susan Minardo, is an adult individual and at all times pertinent hereto resided at the above-captioned address and was the operator of Defendant Owner's motor vehicle and did so as an agent, servant, workman or employee on behalf of the owner. 4. On the aforesaid date, Plaintiff provided insurance, insuring against the risk of loss to James Zinzi, hereinafter referred to as the named insured. 5. On the aforesaid date, a motor vehicle insured by Plaintiff hereafter, the insured vehicle, was involved in an incident with Defendant's vehicle. 6. On the aforesaid date, the insured vehicle was traveling eastbound on Market Street, waiting for traffic to clear and attempting to make a left turn into the parking lot located at 921 Market Street in Lemoyne, Pennsylvania. The defendant vehicle was also traveling eastbound on Market Street, failing to maintain a safe following distance from the insured, when the defendant vehicle struck the insured vehicle in the rear causing damages to the insured vehicle. 7. Defendant driver was negligent and careless and the sole cause of this incident in that Defendant driver: a. was careless, inattentive or distracted and otherwise operated their vehicle without regard for the safety of other persons or property in violation of 75 Pa.C.S. § 3714; b. operated their vehicle in reckless, willful, or wanton disregard for the safety of persons or property in violation of 75 Pa.C.S. § 3736; c. did not operate their vehicle in a manner that maintained an assured clear distance and disregarded the hazard created by other vehicles on the roadway and did not operate their vehicle in a reasonably and prudently safe manner with respect to those conditions in violation of 75 Pa.C.S. § 3361; d. followed closer than is reasonable and prudent, without regard for the speed of other vehicles and the traffic upon and the condition of the highway in violation of 75 Pa.C.S. § 3310(a); e. in addition to traditional negligence, defendant is negligent per se for violating the above referenced statutes; 2 E was otherwise negligent and/or violated local laws and the laws of the Commonwealth of Pennsylvania, including, but not limited to: 75 Pa.C.S. § 3310(a), 75 Pa.C.S. § 3361, 75 Pa.C.S. § 3714 and 75 Pa.C.S. § 3736. 8. Plaintiff became liable for damages that arose out of this incident. 9. Due to this incident, expenses were incurred for damages to the insured vehicle, towing, storage and car rental. 10. Pursuant to the principles of equity, the statutory and the common law, Plaintiff is subrogated for all money paid and seeks recovery of these sums totaling $20, 120.07. WHEREFORE, Plaintiff demands judgment for $20,120.07 in addition to interest from the date of the loss, the costs of this lawsuit, certain administrative costs, and whatever additional relief the Court may deem proper. COUNTI PLAINTIFF V. SUSAN MINARDO 11. Plaintiff incorporates paragraphs 1 through 10 inclusive as if fully set forth at length herein. 12. Defendant is liable as the negligent driver. WHEREFORE, Plaintiff demands judgment for $20,120.07 in addition to interest from the date of the loss, the costs of this lawsuit, certain administrative costs, and whatever additional relief the Court may deem proper. COUNT II PLAINTIFF V. NATALIE MINARDO 13. Plaintiff incorporates paragraphs 1 through 12 inclusive as if fully set forth at length herein. 14. Defendant owner is liable under the Doctrine of Respondeat Superior for the negligence of Defendant driver. 3 15. Defendant owner was negligent in entrusting this motor vehicle to someone who Defendant knew or could have known was a dangerous, unlicensed, inexperienced or careless with a motor vehicle. WHEREFORE, Plaintiff demands judgment for $20,120.07 in addition to interest from the date of the loss, the costs of this lawsuit, certain administrative costs, and whatever additional relief the Court may deem proper. Attorney for Plaintiff Date: 4 VERIFICATION The undersigned hereby states that he is an authorized agent of Plaintiff insurance company in this action and verifies that the statements contained in the foregoing Complaint are true and correct. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Stewart C. Crawford, Esquire Attorney for Plaintiff Date: 5 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor State Farm Automobile Insurance Company vs. Natalie Minardo (et al.) ~~~~ti~4 0{ 4~ur+t~~.rltl~r3 ~. ;, ,~ Case Number 2010-1154 SHERIFF'S RETURN OF SERVICE 02/22/2010 09:34 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on February 22 2010 at 2134 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Natalie Minardo, by making known unto herself personally, at 379 Melbourne Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. 02/23/2010 03:55 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on February 25, 2010 at 1555 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Susan Minardo, by making known unto herself personally, at 379 Melbourne Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $62.44 February 26, 2010 (r. CouoiySuite Shenff. Teieosoft, lien. ,~ 2010 ~IaR -9 ~~ $~ ~9 ~'U~ITI` a U~rLia ;J~~~~t~ ,'~ a SO ANSW RO ANDERSON, SHERIFF BY,'` ~~ Deput Sheriff Deputy heriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Plaintiff, CIVIL DIVISION V. NATALIE MINARDO and, No.: 2010-1154 SUSAN MINARDO, Defendants TO THE PROTHONOTARY: WITHDRAWAL OF APPEARANCE .?a t I Pi 2 62 `;RL? 7 COUNTY ,ANS'P LVANIA Kindly withdraw my appearance on behalf of Plaintiff, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, in the above-captioned matter. rawford, squi PA Supreme Court I.D. # 202188 223 North Monroe Street 40,nf (7. Dated: Z6?Z Media, PA 19063 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Plaintiff, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, in the above-captioned matter. Respectfully submitted, WEBER GALLAGHER SIMPSON STAPLETON F S& NEW?BBY r l? Travis L. McElhaney, Es re PA Supreme Court I.D. # 204023 Two Gateway Center, Suite 1450 L' l Pittsburgh, PA 15222 Dated: CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing PRAECIPE FOR WITHDRAWAUENTRY OF APPEARANCE was served upon the following party by first class mail, postage prepaid, this 1 3 day of April, 2012, to the following: Natalie Minardo 379 Melbourne Lane Mechanisburg, PA 17055 (Defendant) Susan Minardo 379 Melbourne Lane Mechanisburg, PA 17055 (Defendant) Travis L. McElh ey, squire Counsel for Plai of IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL CIVIL DIVISION - ARBITRATION AUTOMOBILE INSURANCE COMPANY, No.: 2010-1154 = rvi - Plaintiff 7, r - , vs. PLAINTIFFS PRAECIPE FOR bi i 71 ' DEFAULT JUDGMENT PURSUAA NATALIE MINARDO TO Pa.R.C.P. 1037(b) and SUSAN MINARDO Defendants. Filed on behalf of Plaintiff Counsel of Record for this Party: Travis L. McElhaney, Esquire PA I.D. #204023 Christopher P. Deegan, Esquire PA I.D. #85635 WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY, LLP Firm #594 Two Gateway Center 14`h Floor Pittsburgh, PA 15222 Telephone: (412) 281-4541 Fax: (412) 281-4547 a n"? Ib. SDP d o? Q L4 '7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Plaintiff, vs. NATALIE MINARDO and SUSAN MINARDO, Defendants. CIVIL DIVISION -- ARBITRATION No.: 2010-1154 PLAINTIFF'S PRAECIPE FOR DEFAULT JUDGMENT PURSUANT TO Pa.RC.P. 1037(b) To the Prothonotary: Kindly enter judgment in favor of plaintiff State Farm Mutual Automobile Insurance Company and against defendants Natalie Minardo and Susan Minardo for failure to file an Answer or otherwise respond in the above-captioned action within twenty (20) days of the date of service of the Complaint, and assess plaintiff's damages against defendant in the amount of $20,120.07. I certify that a written notice of intention to file this praecipe was mailed to defendant after the default had occurred and at least ten (10) days before the date of the filing of this praecipe. A copy of this notice is attached. I further certify that the defendant is not in active military service. The undersigned verifies that the statements of fact in the Praecipe are true and correct and are made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsifications to authorities. Respectfully submitted, WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY LLP Travis L. McElhane squire L Dated: a 7- Counsel for Plaintif IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Plaintiff, vs. NATALIE MINARDO and SUSAN MINARDO, Defendants. TO: Natalie Minardo 379 Melbourne Lane Mechanicsburg, PA 17055 Date of Notice: April 13, 2012 CIVIL DIVISION -- ARBITRATION No.: 2010-1154 IMPORTANT NOTICE 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 WEBER GALLAGHER SIMPSON STAPLETON F & NEEWnBY LL Travis L. McElhaney, E re Counsel for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Plaintiff, vs. NATALIE MINARDO and SUSAN MINARDO, Defendants. TO: Susan Minardo 379 Melbourne Lane Mechanicsburg, PA 17055 Date of Notice: April 13, 2012 CIVIL DIVISION -- ARBITRATION No.: 2010-1154 IMPORTANT NOTICE 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY 4P --"I - PIM "V?? Travis L. McElhaney, uire Counsel for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, CIVIL DIVISION -- ARBITRATION No.: 2010-1154 Plaintiff, vs. NATALIE MINARDO and SUSAN MINARDO, Defendants. AFFIDAVIT OF NON MILITARY SERVICE The undersigned, being duly sworn, according to law, deposes and says that the Defendant (s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; That Defendant, Natalie Minardo, age unknown, has a place of residence at 379 Melbourne Lane, Mechanicsburg, Pennsylvania 17055. --yyvAkZ Travis L. McElhaney s ire Attorney for Plaintd Attorney I.D.# 204023 Two Gateway Center, Suite 1450 603 Stanwix Street Pittsburgh, PA 15222 Phone: (412) 281-4541 Sworn to and subscribed before me this, I Uthday of April, 2012 A.D. N t JPub en?se ?lrfffian:5, hC,.13f't i'nbiic City of P:tt brirgh, ,iIIK;i3har!y Gouri,y My vomrnissic•n E,p-(#-,, fur; 11,_2(11 3_ Merni?er, Fennsylvarr?, , ...:rc;:ati^,n of Moianes IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, CIVIL DIVISION -- ARBITRATION No.: 2010-1154 Plaintiff, vs. NATALIE MINARDO and SUSAN MINARDO, Defendants. AFFIDAVIT OF NON MILITARY SERVICE The undersigned, being duly sworn, according to law, deposes and says that the Defendant (s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; That Defendant, Susan Minardo, age unknown, has a place of residence at 379 Melbourne Lane, Mechanicsburg, Pennsylvania 17055. Travis L. McElhaney, Es e Attorney for Plaintiff Attorney I.D.# 204023 Two Gateway Center, Suite 1450 603 Stanwix Street Pittsburgh, PA 15222 Phone: (412) 281-4541 Swoo-too and subscribed before me thisJU Th day of April, 2012 A.D. N LI rl VI? i'"CIVIVJ 1 6?v? Notarial Seal Denise M. Williams, Notary Public City of Pittsburgh, Allegheny County My Commission Expires Feb. 11, 2013 Member, CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing Plaintiff's Praecipe for Default Judgment Pursuant to Pa.R.C.P. 1037(b) was served upon the following defendant by Certified U.S. Mail, postage prepaid, this day of April, 2012, to the following: Natalie Minardo 379 Melbourne Lane Mechanicsburg, PA 17055 Susan Minardo 379 Melbourne Lane Mechanicsburg, PA 17055 1001 Ih Travis L. McE ane c Travis L. McElhane , quire Counsel for Plaintif Counsel for Plaintiff--" • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, CIVIL DIVISION -- ARBITRATION No.: 2010-1154 Plaintiff, vs. NATALIE MINARDO and SUSAN MINARDO, Defendants. To: Natalie Minardo 379 Melbourne Lane Mechanicsburg, PA 17055 236 NOTICE NOTICE IS GIVEN THAT A JUDGMENT IN TCAPT'IONED MATT HAS BEEN ENTERED AGAINST YOU. s ?ylia David D. Buell Prothonotary IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: Travis L. McElhaney, qui PA I.D. No.: 204023 WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY LLP Two Gateway Center - Suite 1450 603 Stanwix Street Pittsburgh, PA 15222 (412) 281-4541 • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, CIVIL DIVISION -- ARBITRATION No.: 2010-1154 Plaintiff, VS. NATALIE MINARDO and SUSAN MINARDO, Defendants. To: Susan Minardo 379 Melbourne Lane Mechanicsburg, PA 17055 236 NOTICE NOTICE IS GIVEN THAT A JUDGMENT IN THE OVE T D MATT HAS BEEN ENTERED AGAINST YOU. sly ,a ., David D. Buell Prothonotary IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: ? n^ *I Travis L. McElhaney, E qu' e PA I.D. No.: 204023 WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY LLP Two Gateway Center - Suite 1450 603 Stanwix Street Pittsburgh, PA 15222 (412) 281-4541 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL CIVIL DIVISION - ARBITRATION AUTOMOBILE INSURANCE COMPANY, No.: 2010-1154 [n , Plaintiff, ' - vs. PLAINTIFF'S PRAECIPE FOR DEFAULT JUDGMENT PURSUAA.- NATALIE MINARDO TO Pa.R.C.P. 1037(b) and SUSAN MINARDO, Defendants. Filed on behalf of Plaintiff Counsel of Record for this Party: Travis L. McElhaney, Esquire PA I.D. 4204023 Christopher P. Deegan, Esquire PA I.D. #85635 WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY, LLP Firm #594 Two Gateway Center 14th Floor Pittsburgh, PA 15222 Telephone: (412) 281-4541 Fax: (412) 281-4547 ?, *1b.SDP d o1 an )L-- 3/) ? a6 ? a?Ll j(0? Y1? OA 1e'j IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Plaintiff, vs. NATALIE MINARDO and SUSAN MINARDO, Defendants. CIVIL DIVISION -- ARBITRATION No.: 2010-1154 PLAINTIFF'S PRAECIPE FOR DEFAULT JUDGMENT PURSUANT TO Pa.R.C.P. 1037(b) To the Prothonotary: Kindly enter judgment in favor of plaintiff State Farm Mutual Automobile Insurance Company and against defendants Natalie Minardo and Susan Minardo for failure to file an Answer or otherwise respond in the above-captioned action within twenty (20) days of the date of service of the Complaint, and assess plaintiff's damages against defendant in the amount of $20,120.07. I certify that a written notice of intention to file this praecipe was mailed to defendant after the default had occurred and at least ten (10) days before the date of the filing of this praecipe. A copy of this notice is attached. I further certify that the defendant is not in active military service. The undersigned verifies that the statements of fact in the Praecipe are true and correct and are made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsifications to authorities. Respectfully submitted, WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY LLP Travis L. McElhane Vsquire 4-/ Dated: Abo/ ??- Counsel for Plaintif IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Plaintiff, vs. NATALIE MINARDO and SUSAN MINARDO, Defendants. TO: Natalie Minardo 379 Melbourne Lane Mechanicsburg, PA 17055 Date of Notice: April 13, 2012 CIVIL DIVISION - ARBITRATION No.: 2010-1154 IMPORTANT NOTICE 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 WEBER GALLAGHER SIMPSON STAPLETON F & NEWBY LL Travis L. McElhaney, E re Counsel for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Plaintiff, VS. NATALIE MINARDO and SUSAN MINARDO, Defendants. TO: Susan Minardo 379 Melbourne Lane Mechanicsburg, PA 17055 Date of Notice: April 13, 2012 CIVIL DIVISION -- ARBITRATION No.: 2010-1154 IMPORTANT NOTICE 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY 4P - ilm ?? ? ? Travis L. McElhaney, uire Counsel for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, CIVIL DIVISION -- ARBITRATION No.: 2010-1154 Plaintiff, Vs. NATALIE MINARDO and SUSAN MINARDO, Defendants. AFFIDAVIT OF NON MILITARY SERVICE The undersigned, being duly sworn, according to law, deposes and says that the Defendant (s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; That Defendant, Natalie Minardo, age unknown, has a place of residence at 379 Melbourne Lane, Mechanicsburg, Pennsylvania 17055. Travis L. McElhaney s ire Attorney for Plaintif Attorney I.D.# 204023 Two Gateway Center, Suite 1450 603 Stanwix Street Pittsburgh, PA 15222 Phone: (412) 281-4541 Sworn to and subscribed before me this,-1-Clhday of April, 2012 A.D. 'try t Ue .3 q Williari,;, N,la y Pubic City of P-ttsbwgh, AIkgherIIy County My Commission Expires F',o. t t, 2013 __..--__-- Men?hFr, r erns flaan? ? ?.:; si n of Notaries IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, CIVIL DIVISION -- ARBITRATION No.: 2010-1154 Plaintiff, vs. NATALIE MINARDO and SUSAN MINARDO, Defendants. AFFIDAVIT OF NON MILITARY SERVICE The undersigned, being duly sworn, according to law, deposes and says that the Defendant (s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; That Defendant, Susan Minardo, age unknown, has a place of residence at 379 Melbourne Lane, Mechanicsburg, Pennsylvania 17055. Travis L. McElhaney, EsVe Attorney for Plaintiff Attorney I.D.# 204023 Two Gateway Center, Suite 1450 603 Stanwix Street Pittsburgh, PA 15222 Phone: (412) 281-4541 Swo, to and subscribed before me thi,t day of April, 2012 A.D. (- _ Notarial Seal Denise M. Williams, Notary Public City of Pittsburgh, +lie!ti%eny County My Commission Expires Feb. 11, 2013 .. . e,- na?nc?warna Ass ciation of Notaries CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing Plaintiff's Praecipe for Default Judgment Pursuant to Pa.R.C.P. 1037(b) was served upon the following defendant by Certified U.S. Mail, postage prepaid, this day of April, 2012, to the following: Natalie Minardo 379 Melbourne Lane Mechanicsburg, PA 17055 Susan Minardo 379 Melbourne Lane Mechanicsburg, PA 17055 O Travis L. McElhane , quire Counsel for Plaintiff-/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, CIVIL DIVISION - ARBITRATION No.: 2010-1154 Plaintiff, VS. NATALIE MINARDO and SUSAN MINARDO, Defendants. To: Natalie Minardo 379 Melbourne Lane Mechanicsburg, PA 17055 236 NOTICE NOTICE IS GIVEN THAT A JUDGMENT IN TCAPTIONED MATT HAS BEEN ENTERED AGAINST YOU. ` David D. Buell Prothonotary IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: Travis L. McElhaney, qui PA I.D. No.: 204023 WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY LLP Two Gateway Center - Suite 1450 603 Stanwix Street Pittsburgh, PA 15222 (412) 281-4541 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Plaintiff, vs. NATALIE MINARDO and SUSAN MINARDO, Defendants. To: Susan Minardo 379 Melbourne Lane Mechanicsburg, PA 17055 CIVIL DIVISION -- ARBITRATION No.: 2010-1154 236 NOTICE NOTICE IS GIVEN THAT A JUDGMENT IN THE VE T D MATT HAS BEEN ENTERED AGAINST YOU. David D. Buell Prothonotary IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: i , A Travis L. McElhaney, PA I.D. No.: 204023 WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY LLP Two Gateway Center - Suite 1450 603 Stanwix Street Pittsburgh, PA 15222 (412) 281-4541