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HomeMy WebLinkAbout10-3813. F:\FILES\Clients\3050Donega(\Current\61T3050.617.complaint Created: 6/5/03 5:31:16 PM Revised:5/21/103:20:11 PM 3050.617 ~~€ !_~}-;, --,tip- 1 ~ i I.,.. 1 f J.'.. George B. Faller, Jr., Esquire `~~ .)rye."~ ` ' ~ '~';,':~Y I.D. No. 49813 j MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALL)~`~I~ •~U=~ '~ ~ ~'~ .~~ MARTSON LAW OFFICES 10 East High Street C~"~ ~~ ~ "~' w'~:~Y Carlisle, PA 17013 Nc~ ~ "~~/'~~~/ ,~ (717) 243-3341 Attorneys for Plaintiff JACQUELYN ANDERSON, Plaintiff, v. STEFANIE M. COWLES, Defendants. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2®~ 3 ~~ ~ cv ~-tcrr- CIVIL ACTION -LAW JURY TRIAL DEMANDED NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiffs. 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 REDUCE FEE OR NO FEE: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 s9~.as~'d~~ ~~~,~s 97 /C~ a.y3 ~ ~rl ~-•c~4 George B. Faller, Jr., Esquire I.D. No. 49813 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JACQUELYN ANDERSON, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA NO. ~©-~ 313 c r~'~ I -I-rJ,K, v. CIVIL ACTION -LAW STEFANIE M. COWLES Defendants. JURY TRIAL DEMANDED COMPLAINT 1. The Plaintiff Jacquelyn Anderson is an adult individual residing at 4220 Crooked Hill Road, Dauphin County, Harrisburg, Pennsylvania 17110. 2. The Defendant Stefanie M. Cowles is an adult individual residing at 509 East Elmwood Avenue, Apt. 3, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. On or about September 28, 2009, Plaintiff was operating her 2001 Mitsubishi Galant traveling less than 10 miles an hour as she was preparing to exit the Forest Hills Executive Suites parking lot. 4. At that time, a 2009 Volkswagen Jetta owned by Benjamin L. Cowles and operated by Defendant Stefanie M. Cowles backed out of a parking space causing the left rear of the Defendant's vehicle to strike the right front portion of the Plaintiff s vehicle. 5. As a direct and proximate result of the collision, Plaintiff s vehicle, which had a fair market value of $4,009.98, was a total loss. The Plaintiff was able to sell the vehicle for a net salvage recovery of $424.00. A true and correct copy of the estimate is attached hereto as Exhibit "A." 6. In addition, Plaintiff incurred a rental expense in the amount of $516.00. A true and correct copy of the rental invoice is attached hereto as Exhibit "B." 7. Therefore, Plaintiffs damages are in the amount of $4,101.98. 8. The aforementioned damage was caused solely as a result of the negligence, recklessness and carelessness of the Defendant Stefanie M. Cowles in that she: a. Failed to yield the right of way to Plaintiff's vehicle; b. Failed to properly keep a lookout while backing out of a parking space; c. Failed to properly observe Plaintiff s vehicle; and, d. Failed to properly brake her vehicle to avoid striking Plaintiff s vehicle. 10. As a direct and proximate result of the negligence of the Defendant, Plaintiffincurred the damages set forth herein. WHEREFORE, Plaintiff Jacquelyn Anderson demands judgment against Defendant Stefanie Cowles in an amount of $4,101.98, plus costs, interest, and any other relief that the court deems appropriate. MAR By LAW OFFICES Date: June 8 , 20 l o Attorneys for Plaintiff I.D. No. 49813 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Claim: PAG-PA-01-09- Autosource Valuation 2001 Mitsubishi Galant AS Request: 25585680 0097434 ... ~~d~f~x Autosource Valuation SO%rRCDY.~ Jack Chiara Donegal Insurance Group Marietta Branch 1195 RNer Road Marietta PA 17547 ........ ...................... Vlf~f 4A3AA46G31 E216178 Decodes! ate 2001 Mitsubishi Galant ES 4D Sedan AcWtt~cyr:: Decodes Correctly F-kigtWy: Activity was reported o Autosource activity: (NONE). o Autotrak activity: (NONE). o Audatex/Estimating activity: Reported by DONEGAL INSURANCE GROUP-MARIETTA on March 3, 2009. Call them regarding Claim: PAG-PA-01-09-0072352. DOL:03/0?JZ009 with a primary impact point of Left Slda o Sales history activity: (NONE) No Vehicles Advertised at (717) 903-9620 No Vehicles Advertised at (717) 525-7383 No Branded title history found for this VIN. Processed on 10/05/09 5:55 AM. Title History is powered by Experian AutoCheCk. The Experian data contained in this report involves the conveyance of information provided to Experian by other sources. Accordingly, neither Experian nor Audatex can, or will, be an insurer or guarantor of the accuracy or reliability of the Experian data. See N.A.D.A See Valuation Autosource/ Value Section Detail Sectbn N.A.D.A. . ~ $4,425 $3,726 $4,076 bmefst! -700 -915 -808 ~ipmBnt 500 430 465 Version: 1 Page: 1 10/05/09 05:55 Exhibit "A" Claim: PAG-PA-01-09- Autosource Valuation 2001 Mitsubishi Galant AS Request: 25585680 0097434 ~uggBS~BIi TntB(~bt1~~p0 Adf~. 50 • ~ • - • $3,783 1 . ~; .. ~ :. `t~ene~158ias Tax ~ % 'Tithe F'ee The market value displayed may not Tranrfer Pea reflect the activity detected by VINSOURCE and/or NICB research. Dedut;iibie $ -v Please contact client services at `' ,.;,.. 1-800-351-3133 for review. ', :: ., .: 5a#~agelQi#ier ~~..~.~........ a•a ~ The Autosource database contains inspected dealer inventories, dealer advertisements, phone verified vehcles, and private party advertisements from thousands of sources including automotive publWations, newspapers and Web sites. Autosource uses vehicles comparable in year, make and model within the specified market area, expanding as necessary, to determine the loss vehicle's local market value. This valuation includes a representative sample of the vehicles used to calculate the typical starting price. The market search originated from Zip Code 17110, as determined by the vehicle owner's principaly garaged area. Autosource located 30, 2001 Mitsubishi Galant vehicles which were used to determine the typical vehicle price. Adjustments have been made to the comparable vehicles for value differences in vehicle description as indicated in the "Veh Adj" field. The sum of the 30 comparable vehicles is $124,216 for an average pr'~ce of $4,141. The asking or actual sale price is displayed for each vehicle. If a vehicle has been sold, the sold price is displayed with an (S) indicator. The selling price may be substantially less than the asking price. In the case of this 2001 Mitsubishi Galant, the difference between the asking price and selling price is generally 10°~. This selling price adjustment has been applied to the typical price. Additional adjustments have been made to the typical vehicle price taWng into consideration the loss vehicle's mileage, equipment and condition. All adjustments are vehicle specific and reflect driving habits and conditon for the vehicle's market. A mileage adjustment of 2.50 cents per mile has been applied. Taking Into consideration the vehicle specifics, the fair market value is $3,783. ~±lt~:~1~)~ati~ar~ t~otar( ...:. ; _. 2~1 f4il:~i~tt~# ~ala~rt ~1tyt5~tt#: Harrisburg, PA ,, .. :,: »~'.Ice: $3,726 Harrisburg, PA $3,726 Enain~ 4 Cylinder 2.4 Engine Transmiss~ra~ 4 Speed Automatic Cvldr Not Applicable Od~~st~r105,395 Mf(Typical) 2001 Mitsubishi Galant ES 4D Sedan 2WD 4 Cylinder 2.4 Engine 0 4 Speed Automatic 0 DOVER WHITE PEARL MET 142,081 Mi(Actual) -915 Version: 1 Page: 2 10/05/09 05:55 Claim: PAG-PA-01-09- Autosource Valuation 2001 Mitsubishi Galant AS Request: 25585680 0097434 • ~. ConvenlettCe (~ptitsri~, Air Conditioning Air Conditioning Tilt Steering Wheel Tilt Steering Wheel Cruise Control Cruise Con[rol Rear Window Defroster Rear Window Defroster Rem Trunk-UGate Release Rem Trunk-UGate Release Other Optional Equipment Tinted Glass Tinted Glass Anti-lock Brakes 0 Center Console Center Console Fog lights Fog Lights Intermittent Wipers intermittent Wipers Keyless Entry System Keyless Entry System Side Airbags 0 Dual Airbags Dual Airbags Tachometer Tachometer Leather Steering Wheel 0 PgwiQr Accessories; Power Mirrors Heated Power Mirrors 0 Power Windows Power Windows Power Steering Power Steering Power Door Locks Power Door Locks Power Brakes Power Brakes RadiglPhone/Alarrtt aptlorts Infinity Sound System 0 AM/FM CD Player AM/FM CD Player Alarm System 0 Rggf C'~tlttrts~ Power Moonroof 140 Seat moo; VeloudCbth Seats Vebur/Cloth Seats Wheei Qp~}orrs Aluminum/Alloy Wheels 0 Packagds Premium Package 290 ` A~tasaiFra~ 1~ahe ~ettare Corrd~iort A~justmerits: 3,241 ' ; ;~e~'. Minor Wear Minor Wear Carpels Minor Wear Minor Wear lnt Tclrrti Mtnor Damage Minor Damage f atass:Good Good Headlirrer Good Good • BOC~y Minor Damage Minor Damage P2fint. Minor Wear Minor Wear Feet ~tl[tt Good Good ;', ~ii~liie: Minor Wear Minor Wear Tra~f~Eri19t# Minor Wear Minor Wear <Ffro~#:1'1r Good New 50 F4a8t Tits Good Good • • 50 l~r-13r iarr-ag~t 0 Cii©t~.Ad~usttrre~t 50 Version: 1 Page: 3 10/05/09 05:55 Claim: PAG-PA-01-09- Autosource Valuation 2001 Mftsubishi Galant AS Request: 25585680 0097434 Net ~djtfsted Vaiue~.,,,.,.....,.,,.,,.:) ...........J $aiv61g~t1ier; ' The market area identified has multiple tax jurisdictions. Please see valuation notes for explanation. e , Ind ~ : ""N.A.D.A. Vehicle Description: 2001 MIT Galant-4 Cyl. Sedan 4D ES N.A.D.A. values are as of September, 2009 from the Official Older Used Car Guide, National Edition. Baas Yajkie 34,425 MAChartieat Engln~: 30 Transmissiion 30 Equipment Alumfnum/A(tgy Wheeig 125 infinity Sterea Sys' 150 Power Sur<rao# 225 Equipment Sttbtvt$I 3500 N~#ea$e: f4$,d$t:,~ 3.700 $4,225 These current N.A.D.A. values are furnished under license from NADASC. All values Copyright ®NADASC 2009. The values in the N.A.D.A. guide assume a vehicle in clean condition. Appropriate deductions should be made to put a vehicle in salable condition. Special Note on Older Vehicles: N.A.D.A.'s editors believe that most optional equipment has little or no value on older vehicles. This is especially true of options that cost relatively little to begin with and which deteriorate with age or use. ..,.-,. 2~~ i<At~e=:ct#tti ~atattt z#s1€d~ ~b~ r:.::::. Adjustments of Special Note No special adjustments were made for this vehicle. Information provided by Donegal Insurance Group Loss vehicle description was provided by Donegal Insurance Group d All values are in U.S. dollars. Autosource Valuation Process ~ Over.3,400,000 vehicles are entered weekly into the database used for researching this value. This database includes dealer inspected, dealer Inventory, dealer advertised, phone verified and advertised private party vehcles. The or'~ginating search area for this valuation was Harrisburg, Pennsyhrania. Version: 1 Page: 4 10/05/09 05:55 Claim: PAG-PA-01-09- 0097434 Autosource Valuation 2001 Mitsubishi Galant AS Request: 25585680 ~ The value of the Package adjustments displayed Include only those items that cannot be purchased individually. Other equipment items included in the package that can be purchased separately are adjusted with the vehicle equipment, and these adjustments are noted by the applicable options. ~ The market area identified has multiple tax jurisdictions. Autosource was unable to identify which county or city was applicable to the total loss vehicle. However, special tax calculation rules apply to vehicle sales in this jurisdiction (such as limits, caps, exemptions, etc.) and Autosource was able to correctly establish the tax amount of $197 o Other Adjustments or Comments n A mileage adjustment of 2.50 cents per mile/kilometer has been applied. This adjustment is based on the vehicle year, vehicle category and market area. Mileage adjustments are capped at 40°/a of the vehicle's starting value. • Dual Airbags STD Power Door Locks STD ' Fog Lights STD Power Mirrors STD Gold Package $160 Power Steering STD ' Intermittent Wipers STD Power Windows STD ' Keyless Entry System STD ~ittt-AtRiert<i:e Op>dt~ns ' Leather Steering Wheel Air Conditioning STD ' Side Airbags Cruise Control STD Rear Spoiler $433 Rear Window Defroster STD ' Tachometer STD Rem Trunk-UGate Release STD C~tltt~tP;~ces ' Premium Package $2,600 Includes Power Glass Moon Roof; Garage Door Opener; Anti Lock Brakes; Side Impact Air Bag Restraint System; Alloy Wheels; Alarm System; Dual Heated Power Mirrors. blase retaiEprie~: $18,962 Editions available for the same body style (in order of original cost, Increasing): DE, 'ES, ES V6, LS, GTZ ' Indicates loss vehicle equipment. :... < Mt~StUbtSYt~:t`xaiittsit ; ~~ H~i.£efm5 :.<>. <.. 2flQ1 Nat'l. Highway Traffic Safety Admin (US) has issued a total of 1 recall bulletin that may apply to this vehicle. ~ 01V069 Dat@'fyig~gt~ 03/01 /01 Quantity Affeate~192 Dates OP Manufacture. February 2001 Version: 1 Page: 5 10/05/09 05:55 Claim: PAG-PA-01-09- Autosource Valuation 2001 Mitsubishi Galani AS Request: 25585680 0097434 DefeGtOn certain passenger veh~les, a bulge in the fuel tank caused by the manufacturing process resulted in thinning of the material during a welding operation, increasing the risk of fuel leakage. :Fuel leakage in the presence of an ignition source could result in a fire. ~iernedy Dealers will replace the fuel tank assembly. The manufacturer has not yet provided an owner notificatbn schedule. After your claim is settled, Autosouroe provides free assistance in locating your next vehicle. Your request can be submitted online 24hrs. per day at www.support.audatex.us/vls.asp. Please click the Online Submission link and then ci'x;k the Vehicle Locator Service Form link to complete the VLS form. Or you can call us Monday through Friday, between 8:00 AM and 5:00 PM, Pacific time at (800)351-3133, ext 7428. Our specialists will work with you to find a new or used vehicle in your area. ~i Yi~tft~.~i~tx3~iib<tt.. ~.< '. ? ~~ 1U4tiss~s.~ This report contains proprietary informaton of Audatex and shall not be disclosed to any third party (other than the insured or claimant) without Audatex's prior written consent. If you are the insured or claimant and have questlons regarding the description of your vehicle, please contact the Insurance company that is handling your claim. Information within VlNsource/NICB is provided solely to identify potential duplicative claims activity. User agrees to use such information solely for lawful purposes. Tax rates contained herein are based on general sales tax data provided by Vertex Inc. Excise, use, registratlon, licensing and other taxes and fees that may be applicable are not included. Audatex makes no representations or warranties concerning the applicability or accuracy of such tax data. Report Generated by Audatex, a Solera Company © 2009 Audatex North America, Inc. All Rights Reserved. Version: 1 Page: 6 10/05/09 05:55 /.~A. INSURANCE AU1t7 AUC:7iON5 Insurance Auto Auctions, inc. Attn: Settlement Group 15369 Dunnings Hwy East Freedom, PA 16637 Phone: (814) 695-0776 Fax: (814) 695-3116 E-mall: IAA_ASAP_AltoonaQiaa i. com Salvaoe Information IAA Stock # 000-06060099 IAA Branch: Harris~rg Fed. Tax I.D. 954455113 Adjuster: Kristi Steech Insured: Jacquelyn Cheny Owner: Jacquelyn Cherry Claim #: PAGPA01090097434 Policy #: Vehicle: 2001 MITSUBISHI GALANT Damage; Front end ViN: 4A3AA46G31E216178 ACV: $3,783.00 NICE Date: 11/6/2009 Bever Information Gotden Chariot Motors 822 W. Division St. Dover, DE 19901 Resale Certificate # :510412997 (PA) Elaosad Days Analvaia Date of Event:. Loss Date 9/28/2009 D,wa Assigned 10!12/2009 15 Released 10112/2008 1 Pickup 10/13/2009 2 Title Recd 10119!2009 7 Sale Doc. Recd 10/26!2009 8 Auction Date 11/4/2009 10 Buyer Payment 11/5/2009 2 Remittance 11/6/2009 2 Elapsed Total Days: 40 IAA Ooe. RP002.tpt REMITTANCE: 5898763 DATE: 11 /06/2009 Remittance Payable To: Atlanac States Insurance Company 1195 River Rd Box 302 Marietta, PA 17547-0302 Attn: Salvage Dept Account of Sale T°tal A ~ 9~ ACV Sales l C $550.00 14.54 IAA Charges Consignment Flat Fee $120.00 3.17 Tow $0.00 0.00 Re•Run Fee $0.00 0.00 Storage Fee $0.00 0.00 IAA -Title Processing Fee $6.00 0.16 Bundled Enhancement Fee $0.00 0.00 less IAA Charges ($126.00) (3.33) Net IAA Return $424.00 i 1.21 Payment Amount $424.00 11.2196 11/09/2009 01:02 PM E5C85 16346 ~R~til~ ~ -Automated Rental Management System ® Donegal Insurance Page 1 of 1 Rental Comparry: ENTERPRISE RENT-A-CAR Invoice: D684957-5765 BIII To: DONEGAL INSURANCE ATTN: KRISTI STEECH P. O. BOX 302, ROUTE 441 MARIETTA , PA 17547 RENTER INFORMATION: Renter: CHERRY, JACQUELYN RENTAL INFORMATION: Rental Branch Location: ENTERPRISE RENT-A-CAR (5765) 801 S CAMERON ST HARRISBURG, PA 171041710 (717) 238-7541 ADDITIONAL CLAIM INFORMATION: Claim Number :PAGPA01090097434 Claim Type: Insured Vehicle Condition: Non-Driveable Date Of Loss: 9/28/09 Insured Name: Owners Vehicle: 2001 MITSUBISHIGALAN Additional Driver: Repair Facility: TOTAL LOSS MECHANICSBURG, PA 17055 (999) 999-9999 VEHICLES RENTED: Effective Date Year Make Model VIN Starting Ending Mileage and Time Mileage Mileage 9/29/09 9:21 AM 2010 FORD MUST 1ZVBP8ANXA5114425 15000 15651 651 Rental Invoice Billing Detail: Rental Period: 9/29/09 to 10/13!09 (15 days) Billed Period: 9/29/09 to 10/13/09 (15 days) Description Rate: Amount: 15 DAYS ~ $30.00 $450.00 15 PTA TAX $2.00 $30.00 1 VRT %2.00 $9.00 1 SALES TAX %8.00 $27.00 TOTAL CHARGES: $516.00 Less Amount Received: $66.00 AMOUNT DUE.......... $450.00 Please Retum This Portion with Remittance Make Payment To: ENTERPRISE RENT-A-CAR COMPANY {5799) 2625 MARKET PLACE HARRISBURG„ PA 17110 Federal I D:26-4528440 Total Charges: Less Amount Received: Total Amount Due.... $516.00 $66.00 5480.00 Please include on your check: Invoice: D684957-5765 https: //www.enterprise.com/armsweb/closedcustomerf le. do 10/30/2009 Exhibit "B" VERIFICATION The foregoing Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. %~ Jacc~elvn Anderson F:\FILES\CGents\3050 Donegal\Cwrent\61 T3050.617.complaint ~ €_- J .. L g ~~,~ ;'ic-i~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~9~``ttp Qt ~MirriG,~~,f~~rQ ~., :'~~ ~1~.4-~~{ r t S.Y[. 2UIU ~L~EY 25 ~~ ~: l ~' Jacquelyn Anderson vs. Stefanie M. Cowles Case Number 2010-3813 SHERIFF'S RETURN OF SERVICE 06/22/2010 08:11 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on June 22, 2010 at 2006 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Stephanie M. Cowles, by making known unto herself personally, at 509 E. Elmwood Avenue Apartment 3, 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: $37.44 June 23, 2010 RYAN BURGETT, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF .r` Cow?iyS,~ite Sherd. Teieoso`t. Inr,. F:IFILES\Clients\3050 Donegal\Cuuent\617\3050.617.pral/nlm Revised' 9/27/10 4:15PM 3050.617 C") Cz ? George B. Faller, Jr., Esquire v I.D. No. 49813 ' r: T MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER r' MARTSON LAW OFFICES ' co '_' D 10 East High Street _ ' i Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JACQUELYN ANDERSON, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. STEFANIE M. COWLES, Defendants. TO THE PROTHONOTARY: NO. 10-3813 CIVIL ACTION - LAW : JURY TRIAL DEMANDED PRAECIPE Enter default judgment in the above-captioned action in favor of Plaintiff and against Defendant Stephanie M. Cowles in the amount of $4,101.98, plus interest and costs of suit as prayed for in the Complaint, for failure to file an Answer to Plaintiffs Complaint. I do hereby certify that a written notice of intention to file this Praecipe, in the form attached hereto, was mailed to the Defendant at the address indicated thereon, on August 18, 2010, which date was subsequent to the date default occurred and at least ten (10) days prior to the date of the Praecipe. Dated: September 27, 2010 By MARTS-ON LAW OFFICES George B. ler, Jr., Esquire I.D. No. 49913 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff s'ly. o QPd a?Y sg 3 413 George B. Faller, Jr., Esquire I.D. No. 49813 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JACQUELYN ANDERSON, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 10-3813 CIVIL ACTION - LAW STEFANIE M. COWLES, Defendants. JURY TRIAL DEMANDED AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA ) SS COUNTY OF CUMBERLAND ) George B. Faller, Jr., Esquire, being duly sworn according to law, deposes and says that he is an employee of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, attorneys for the Plaintiff in the above captioned matter and that pursuant to the provisions of the Pennsylvania Rules of Civil Procedure, a notice of intention to enter default judgment against the Defendant was given to him by mail on August 18, 2010. Sworn to and subscribed before me this A7 day of'2 { C4 , 2010. yby1?-- otary ublic George B. Faller, Jr., ,lam agwno",o01?'?+wo) %; d'G? N .g?? SNAA 4 George B. Faller, Jr., Esquire I.D. No. 49813 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JACQUELYN ANDERSON, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. STEFANIE M. COWLES, Defendants. NO. 10-3813 CIVIL ACTION - LAW JURY TRIAL DEMANDED AFFIDAVIT AS TO MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ) :SS. COUNTY OF CUMBERLAND George B. Faller, Jr., Esquire, being duly sworn according to law, deposes and says that he has authority to make this affidavit on behalf of his client, and to the best of his knowledge, information and belief, the Defendant above named is not in the military service of the United States of America, that he has knowledge that the said Defendant is now living at: 501 E. Elmwood Avenue, Apt. 9, Mechanicsburg, PA 17055. Said Defendant's place of employment is unknown. Sworn to and subscribed before me this d?l day of, 2010. otary tublic PTILEST ients\3050 IbneSai\Cutxcm?61713050.617.noticc of inten0de Revised: 8/18/10 10:21 AM George B. Faller, Jr., Esquire I.D. No. 49813 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JACQUELYN ANDERSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. STEFANIE M. COWLES, NO. 10-3813 : CIVIL ACTION - LAW Defendant : JURY TRIAL DEMANDED IMPORTANT NOTICE TO: STEFANIE M. COWLES, DEFENDANT DATE OF NOTICE: AUGUST 18, 2010 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 VE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS (? FICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO OVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL !jRVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE, DAMAGES WILL BE ASSESSED AGAINST YOU IN THE AMOUNT OF THE REPAIR ESTIMATE UNLESS YOU FILE A WRITTEN PRAECIPE WITHIN TEN (10) DAYS REQUESTING A TRIAL ON DAMAGES. Cumberland. County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone:(717) 249-3166 MARTS L W ES By George B. Faller, Jr., Esq ire F TILESIChent0050 DoncVOCurnazt\6173050.617-aM Raised: 7.13/10 325FM z George B. Faller, Jr., Esquire I.D. No. 49813 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JACQUELYN ANDERSON, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 10-3813 CIVIL ACTION - LAW STEFANIE M. COWLES, Defendants JURY TRIAL DEMANDED AFFIDAVIT OF APPRAISER I do depose and state that I am a licensed appraiser; that the appraisal of $4,009.98 attached hereto is true and correct and accurately sets forth the damages to the value of the 2001 Mitsubishi Galant ES 41) Sedan owned by Jacquelyn (Cherry) Anderson and; that I have been engaged in the appraisal business for If years and am qualified and capable to evaluate the appraisal as attached; and the repairs were necessary and the value indicated thereon was the amount by which the damages to this automobile would fairly and reasonably have been evaluated. This statement and appraisal are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. Signature (.?d %-"- Jack Claim: PAG-PA-01.09- Autosaurce Valuation 2001 Mitsubishi Ga" AS Request: 25WaSo 0097434 ---------------------- Aua Autosource Valuation Jack Chtara Donegal Insurance Group Marlette Branch I195 River Fload Marlette PA 17547 Cherry, Jacquelyn PAG-PA-0148.0097434 09128MIM PAG-3079956 2001 Mbubl hl Galsnt ES 40 Sedan Decodes Convoly Act** was reported o Autoeoaroe activity: (NOME). o Autolnk activity: (NOM o AudatetgEadnrating aotivily: Reported by DONEGAL INIMMI CE GROUPLMARNMA an &UVIa 9, 2WL Call them regarding Claim: PA&PAr01-0a00 IIIIS . DOLMIMMM with a primary in"d point of Lee Sfda1 0 Sales history activity: (NONE) No Vehkfes Advertised at (717) 903 9820 No Vehicles Advertised at (717) 525-7383 No Branded title hMW found for this VIN. Processed on 10M09 5:55 AM. Tide HhlUory Is powered by Experlan AutcChedt. The Expsrian da4 contained M this report Involves the conveyanm of Informallon provided to Expel by other sources. Acoordingly, neither Experlan nor Audawx can, or will, be an Insurer or guamMx of the smirary or rellaMilly of the Experlen data. See N.A.D.A See Valuation AutosotrMW Value Section DOW 8aotion N.A.D.A. Exhibit "A" 'Claim: PAQ-PA-01-09- Aulosource Valuation 2001 Mitsubishi Galant AS Request: 25585880 0097434 Sti .:....... ..:.. 50 59,783 The market value dieple may not rtlmal?4lit ¢ acthrlty detected by retlsct tine PItCsreases ch vlwsotn+M and/or s contact Client servic" at Plan _ 1-800.351-3133 far mview. -- ------- ------- The Autosource dohtbase contains Inspected doalsr itvenlorlm dealer adimosorner% phone vww vehicles, and priest, party advertisements trorn Mousarxls of sources Inctudng aulomodw pubAarons, nowspap" and Web spas. Aulosowq use vehicles comparable In year, make and model within the specified market ants, expanding as neossary, to detem kw the loss vehicle's local market value. This valuation Includss a mWesentatlw sample of the vehktisa used 10 calculate the typltxl starting prkx. The madcet search originated from Zip Cods 17110, ae determined by the vehicle owner's prlndp* garaged aroa Aubm"woe located 30.2001 MlbublW Galant vehicles which wers used to ddwmkw the typical vehicle pdoL nls have been made to the comparable vehicles for value dffhrences in vehkdo description an indcatad in the "Veh Ad fbld The sum of the 30 comparable vehicles Is $124.218 for an average prix of $4,141. The asking or actual sole price Is displayed for each vehicle. If a vehicle has bean sold, the sold price Is displayed with an (S) Indloo1w. The the as selling prprice May ice and selling e su price Ids generally ss than ft 10% a" ?. In the can of this 2001 MbLftM Clalant, the d ference selling price adXnintsM has been applied to the typical price. Additional adoitmsnte have been made to the typical vehicle price taking Into consideration the lose vehicle's mileage, equipment and condition. An adWansnts are vehicle speeMb and reflect driving habits and condition for the vehicle's market. A mileage ad(ustment of 2.50 cents par mile has been appil" Taking Into consideration the vehicle specifics, the tai market value is $3,788. Harrisburg. PA Harrisburg, PA $3,720 $3,720 2001 2001 Mitsubishi Mitsubishi Galant Galant ES ES 40 40 Sedan Sedan 2WD 2WD 4 Cylinder 2.4 Engine 4 Cylinder 2.4 Engine 0 4 Speed Autiom * 4 Speed Automado 0 Not Applicable DOVER WHITE PEARL MET 106,395 tAI(Typlcal) 142081 MI(Actual) -915 Version: I Pope. 2 10/05/09 05:55 Claim: PAG3-PA-01-09- AutosmMe Valuation 2001 Mitsubishi aaleM AS Request: 25585880 0097434 version:1 Air Condidoning Tit StearkV Wheel Cruise Control Raw Window Defroster Rem Trunk UGats Release TIMW Glase Cenw Console Fop Lights Intermittent Wiper Keyless Entry System Dual Aftep Tachometer k Pourer wrors Power Steering Power Door L.odke Power Brakes AWFM CD Player Vslourtclodt Sam Minor wear Minor Wear Minor Damage Good Good Minor Damage Minor wear Good Mirror wear Minor wear { Good Good Pepe: 3 Ai Cornddloning TIt Steering Wheel Cruise Control Rear Window Dehoater Rem Trunlt•UGate Release Tinted Glaser Anti-lock Brakee Center Consols Fog Lids Inmost Wipers Keylsee Entry System Skis AMMigs Dual Airbags Tachometer Leather Steering Mod Hued Pow Mhor Power Wkndows Power SbWrlrng Power Door Locke Power Brakes Infinity Sound System ALV M CD Player Alarm System Power Moonrooi Veloudclom Seats AlumbnumIANoy Wheele Premksn Package Minor weer Minor Wes Minor Damage Good Goad MkW Damage Minor Wekr Good Minor wear Minor Wear Were Good 0 0 0 0 0 0 140 0 290 3,241 50 0 50 1 OWN 0535 Claim. PAG•PA-01-09- Autosmme Valuation 2001 Mitsubishi CUM AS Request: 25585680 0097434 refilad the acth?ity detected by VW*IOURCE andlor NCO research. ••N.A.D.A. Vehide Description: 2001 MIT Gak t-4 Cyl. Sedan 4D ES N.A.DJL values are as of September, 2009 from the OMcial Older Used Car Quids, National Edltlon. 00 so l4MQE111111Ci 1213 how. 150 f 'IMP 226 f?'s < ............. =-700 These current N.A.D.A. values are furnished under kense from NADASC. AN Values Copyright ® NADASC 2009. The values in the N.A.D.A. guide assume a vehicle In clean condition. Appropriate deductions should be made to put a vehicle In salable condition. Special Note on alder Vehklse: N.A.D.A.'s editors bsNeve that mast optional 9WIprnent has Me or no value on older vehicles. This is especially true of options that coat relatively little lo begin with and which deteriorate with age or use. o Adjustments of Special Hots ¦ No special ad)Atmente were made for this vehleia o information provkfed by Donegal Ineunwas, Group Loss vehicle description was provided by Donegal Insursr>ca Group All values are In U.S. dollars. o Autosource Vahudlon Process ¦ Over 3,400,000 vehicles are entered wsft Into the database used for ressarchkp this value. This database includes dealer inspected, dealer inventory, dealer advertised, phone vsrtiled and advertised private party vehicles. ¦ The originating search area for this valuation was Harrisburg, Penneylvenla. Version: I Pape: 4 10/06/09 06:66 • The market area IdentMed has multiple tax judedle m Please see valuation notes for explanation. Claim: PAG-PA-01.09- Autoscurce Valuation 2001 Mbubishi Galant AS Request: 25585880 0097434 CJOW. On certain passenger vehicles, a bulge in the fuel tank caused by the manufacturing process resulted in thinning of the material during a welding operation, Increasing the risk of fuel leakage, Fuel leakage in the presence of an ignition source could result in a fire. Poked : Dealers will replace the fuel tank assembly. The manufacturer has not yet provided an owner . notification schedule. After your claim is settled, Aubsource provides free assistance In locating your next vehkge. Your request can be submitted onfine Mrs. per day at www-support sudatsx.usNILasp. Pleass dick the Online Submission link and linen click the Vehicle Locator Service Form link to complete the VLS form. Or you can call us Monday through FrWay, between 8:00 AM and 5:00 PM, Pacific time at (800)381-3133, ext 7428. Our specialists wig work with you to find a new or used vehicle In your area. I This report contains proprietary Information of Audatex and shall not be disclosed to any third party (other then the Insured or dalmw* wMxm Auxidmft prior wrttisn consent. If you are the insured or cliallmd and have queaft s regarding the description of your vehicle, pleas contact the Insurance company that is handling your daft Information w*dn Vftmu oeMICB is provided solely b ids" potential duplicative claims activity. User ogre" to use such information solely for lawful purposes. Tax rata contained herein are based on general a" tax data provided by Vertex inc. Excise, use, registration, licensing and other tars and fees that may be apple" are not Included. Audatex makes no representstiom or warandes concerning the applicability or accuracy of such tax dets. Report Generated by Audetex, a Soles Company ® 2009 Audatex North America, Inc. AN Rights Ressrved. Version: l Pepe: 6 10/009 06:55 Claim: PAG-PA-01-09- Autosource Valuation 2001 Mitsubishi Galaet AS Request: 25585680 0097434 The value of the Package adjustments displayed include only those Items that cannot be purchased Individually. Other equipment Items Included In the package that can be purchased separately are adjusted with the vehicle equipment, and these adjustments are notsd by the applicable options. ¦ The market area Identified has multiple tax Judadkxtons. Autoscurce was unable to Ident9y, which county or city was appilo" to the total less vehicle. However, special tax calculation noise apply to vehicle sales in this jurisdiction (such as iimita, caps, exemptions, etc.) and Autoeomme was able to correctly establielt the tax amount of $197 o Other Adjusitriw is or Comments ¦ A mleage adjustment of 250 cants per mile/kilometer has been applied. This adjustmertt Is based on the vehicle year, vehicle category and market area. MNeage adjustments are capped at 40% of the vehicle's staring value. NOW :... • 4 Cy1nder 24 Engine STD 4 Speed Automdb STD X! X :>:•: i6PY1!!' iliMllE< ' Anti-bclk Brakes Heated Power Mirrors • Center Console STD ' Power Brakes STD • Dual Aldop STD • Power Door Locks STD ' Fop Lights STD Power Mirrors STD Gold Package $180 • Power steering STD • IntermittentVY"fa STD PowerWlndows STD • Keyless Entry System STD •.........:.•:: Cant?ltltllilir role fOp.......... . • Leather Stesting Whed ' Air Cortdtiorting STD • Skf:a Airbags • Cruise Control STD Rear Spoiler $433 • new Wktdow Defroster STD • Tachometer STD ' Rem Trurlk-L/Gate Release STD • Tinted Glen STD ' Tilt Steering Wheel STD • Alarm System • Power Moonroof $8ti0 • AWFM CO Player 3T0 :.. , ....::. . Compact Disc Changer $557 VokxWCblh Seats STD • ity nd 3 Infin Sou • Afuminum/Alloy Wheels :.opt":. • Premium Package $2,800 Includes Power Glen Moon Root Garage Door Opener And Lock Brakes; Sloe Impact Air Bag Restrai nt System; Alloy Wheeb; Alarm System; Duel Heated Power Mirrors. ::: ... .. 18 982 $ , Editions available for the sams body We an order of original cost, it to rig): DE, 'ES, E8 V8, LS, GTZ • Indcates loos vehicle equipment Naft Highway Traffic Safely Admin (US) has Issued a total of 1 recall bulletin that may apply to this vehicle. 01 VON a3rotrot j 192 t ftt February 2001 Version: I Pape: 5 1 N&09 05:55 I A ko INSURANCE AIJ10 AUCTiO 4 Irmuranoe Aufw Auctions. Inc. Attn: Settlement Group 15368 ounn ngs furry East Freedom, PA 1683, Phone: (814) 8954778 Few: (814) t38b-3116 E-mdl: IAA ASAP_AI1DOns®Ied.cm I?i4A? Stoc6 IAA Branch, Harrisburg Fed. Tax LO. 954455113 Adjuster. Krkd Stesch Insured: Jacquelyn Chaffy Owner Jalxluelyn Cherry Claim 0. PAGPAOIO We7434 Pdlcy S: Vehide: 2001 MITSUBISHI GALANT Oamage.. Front and VIN: 4AMA48O31 E2161.78 ACV: $3.783.00 Y NICE De.. 1116/2009 8l171t??19'!/?10a. Golden Chat M010M 822 W. Division St. Down. DE 19901 Resale CertlAc:de 0 : 510412997 (PA) Lose 9J28/Z009 - Assigned 1412/2009 15 Released 1412/2009 1 Pickup 10113/2008 2 Title Redd 1418d20O9 7 Sate Doc. Redd 142612009 a Auction Oats 111412008 10 Buyer Payment 1102008 2 Remittance 11!6/2009 2 01spa W Total Days: -' 40 IM Doe. RPM-10 REMITTANCE: 5898753 DATE: 11106/2009 Remlthnce Pay" To: Aaenrc Shoe iraurenos COmpeny 1196 River Rd Box 302 Marhw. PA 17547-030 Alin: Shcvegs Dept XOM 8etN $550.00 14.54 IAA Chugs! Consignment Flat Fee $120.00 317 TOW $0.00 0.00 Re4 w Fee 50.00 0.00 Storage Fee $0.00 0.00 IAA • T18e Processing Fee $8.00 0.16 Bundled Enhamxment Fee $0.00 0.00 Less LAA Charges ($126.00) (3.33) Net 1AA Return $424.00 11.21 1 Payment Amount $424.00 11.21% 1110912009 01:02 PM E5C85 16346 Rental Company: ENTERPRISE RENT-A-CAR e Donegal Insurance Invoice: D884957-5785 131f1 To: DONEGAL INSURANCE ATTN: KRISTI STEECH P. O. BOX 302, ROUTE 441 MARIETTA, PA 17547 RENTER INFORMATION: Renter. CHERRY, JACQUELYN RENTAL INFORMATION: Rental Branch Location: ENTERPRISE RENT-A-CAR (5785) e01 3 CAMERON Or HARRISBURG, PA 171041710 (717) 238.7541 ADDITIONAL CLAIM INFORMATION: Claim Number :PAGPA01090097434 Claim Type: Insured VehWs Condition: Non-Driveable Dab Of Loss` 9V26/09 Insured Name: Owners Vehicle: 2001 MITSUBISHIGALAN Additional Driver. Repair Facility: TOTAL LOSS MECHANICSSURG, PA 17055 (969) 999-9999 Billing Detail: Rental Period: 9 IMM to 10113!09 (15 days) Billed Period: 9/2901 to 10M 3109 (15 days) Description Rate: Amount 15 DAYS a $30.0 $450.00 15 PTA TAX $2.00 $30.00 1 VRT %2.00 $0.00 BALES TAX %9.00 $71.00 TOTAL CHARGES- $516.00 Leas Amount Received: $86.00 AMOUNT DUE.......... $450.00 VEHICLES RENTED: ?? Year Make Model VIN Sterling owing WIMP an 912901 9:21 AM 2010 FORD MUST 1ZVSP8ANXA5114425 15000 15651 851 Rental Invoice Plans Relxn Thls Porlon with Ramlttance Make Payment To: Total Chargaz $518.00 ENTERPRISE RENT-A-CAR COMPANY (5781t) Lees Amount Received: $88.00 2825 MARKET PLACE Total Amount Due .................... $450.00 HARRISBURG,, PA 17110 Federal ID:264526440 Please Indude on yar cho&.. Invoices D684957-5785 https://www.enterprise.com/armsweb/closedcustomerfdo.do 10/30/2009 Exhibit "B" CERTIFICATE OF SERVICE I, Nichole L. Myers, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Ms. Stephanie Cowles 501 E. Elmwood Avenue Apt. 9 Mechanicsburg, PA 17055 MARTSON LAW OFFICES By 1?11?f,?1 1 ?v Nichole L. Myers Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: September 27, 2010 George B. Faller, Jr., Esquire I.D. No. 49813 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JACQUELYN ANDERSON, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 10-3813 CIVIL ACTION - LAW STEFANIE M. COWLES, Defendants. JURY TRIAL DEMANDED TO: STEFANIE M. COWLES, Defendant NOTICE OF ENTRY OF DEFAULT JUDGMENT You are hereby notified that on the day of Se c,4es-, 2010, the following Judgment was entered against you in the above-captioned action: judgment in the amount of $4,101.98, plus interest and costs of suit as prayed for in the Complaint for failure to file an Answer to Plaintiff's Complaint. Date: 6?_ - oLd / d 4thPronotary I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Ms. Stephanie Cowles 501 E. Elmwood Avenue Apt. 9 Mechanicsburg, PA 17055 FAFILES1Clients0 050 Donega10050 Current \ 3050.6170050.6 I 7.aff2.wpd Revised: 4/14/14 I 1:43AM George B. Faller, Jr., Esquire I.D. No. 49813 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff l'''- ; PR 267/ Ar-. 'I 1 5 f p1 , 1 : c- -z- Li :,,: JACQUELYN ANDERSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 10-3813 : CIVIL ACTION - LAW STEFANIE M. COWLES, Defendants JURY TRIAL DEMANDED AFFIDAVIT OF MOTOR VEHICLE ACCIDENT COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF On September 28, 2010, a Praecipe to enter default judgment in the above captioned action was entered in favor of Plaintiff and against Defendant Stefanie M. Cowles in the amount of 4,101.98, plus interest, attorney's fees and costs of suit and said judgment is the result of a motor vehicle accident which occurred on September 28, 2009. I make these statements pursuant to 18 Pa. Cons. Stat. §4904 relating to unsworn falsification to authorities and understand that false statements may subject me to criminal penalties under that statute. Sworn to and subscribed before me this tay of Apr I , 2014. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Margaret Ann Nash, Notary Public Carlisle Bora, Cumberland County My Commission Expires June 29, 2015 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES George a ler, Jr., Esquire oy,kk CL ao- &:yiSt 3