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HomeMy WebLinkAbout01-1214F T1LES\DATAFILE\DONEGAL.DOC\176-cam. U.A Created 01/09/0109.5200AM Revised 02/28/010348.13 PM 3050170 JEFFREY P. FITTING, Plaintiff V. JOELLE CRABBS-MILLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION-LAW NO. r(- /,) f /' JURY TRIAL OF TWELVE 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 MARTSON DEARDORFF WILLIAMS & OTTO By G e B. Faller, Jr., Esqui I.D. Number 49813 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Jeffrey P. Fitting Date: mm { 0 l JEFFREY P. FITTING, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION-LAW : NO. d/ /e2 / Y G'u' P Tu JOELLE CRABBS-MILLER, Defendant JURY TRIAL OF TWELVE DEMANDED COMPLAINT 1. Plaintiff is an adult individual residing at 610 Thrush Court, Mechanicsburg, Cumberland County, PA 17055. 2. Defendant is an adult individual residing at 308 South Market Street, Mechanicsburg, Cumberland County, PA 17055. 3. On or about March 10, 2000, Plaintiff's vehicle, a 1994 Toyota Pickup, was involved in a single car accident while being driven by Defendant Crabbs-Miller. 4. On or about March 10, 2000, Defendant Crabbs-Miller was traveling west on Carlisle Road, Camp Hill, Cumberland County, PA when the vehicle swerved to the right, jumped the curb and struck a tree. 5. The aforesaid accident occurred solely as a result of the negligence, recklessness and carelessness of Defendant Crabbs-Miller and was due in no manner whatsoever on the part of the Plaintiff. 6. The aforementioned negligence, recklessness and carelessness of Defendant Crabbs- Miller consisted of the following: a. failure to have vehicle under proper control; b. driving in a reckless and careless manner; C. failure to exercise reasonable care in operation of the vehicle; and d. driving while under the influence of controlled substances and prescription drugs. 7. As a result of the negligence, recklessness and carelessness of Defendant Crabbs- Miller, Plaintiff's vehicle was damaged in the amount of $6,196.07. See attached invoice as Exhibit "A„ 8. Plaintiff also incurred reasonable rental expenses in obtaining a substitute vehicle, for use while his vehicle was being repaired, in the amount of $449.24. See attached invoice as Exhibit "B". WHEREFORE, Plaintiff Jeffrey P. Fitting, demands judgement against Defendant Joelle Crabbs- Miller in the amount of $6,645.31. WILLIAMS & OTTO By G g. Faller, Jr., Esc I.D. Number 49813 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff Jeffrey P. Fitting Date: a? ?? U I 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. Jeffrey P. F `--) . o r- CZ I r . r .p fiFr7"I L F E B 4 2001 NADWr JEFFREY P. FITTING, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 01-1214 CIVIL TERM JOELLE CRABBS-MILLER, Defendant : JURY TRIAL DEMANDED ANSWER AND NOW, comes the Defendant, Joelle Miller, and makes the following answer to the Plaintiff's complaint: 1. Admitted. 2. Admitted, except the Defendant now resides in Shermans Dale, Pennsylvania. 3. Admitted. 4. Denied as stated. The Defendant swerved to avoid an oncoming vehicle. 5. The conclusion of law is denied. 6. Denied in accordance with Pa. R.C.P. 1029(e). 7. After reasonable investigation, the Defendant is without knowledge sufficient to form a belief as to the truth of the averment regarding the Plaintiff s damages, and the same is therefore denied. 8. The answer to Paragraph 7 is incorporated herein by reference. WHEREFORE, the Defendant requests the complaint be dismissed. LAW OFFICE OF MICHAEL J. HANFT By: William`.. Addams Attorney I.D. No. 06265 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013 (717) 249-5373 Attorneys for Defendant VERIFICATION Joelle Miller hereby verify that the facts set forth in the foregoing Answer are true and correct to the best of her knowledge, information and belief, and understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsifications 1 o --k I 1 l ? dfl ) DATEA D a ?/ ??Q/ 'ri she Court of Common "leas of Cumberland County, Pennsylvania Jeffrey P. Fitting vs. Joelle Crabbs-Mill_er Na. 01-1214 civil Now, 3/16/01 120 0 0, I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Perry County to execute this Writ, this deputation being made at the request and risk of thePlaintiff. Shariff of Cumberland County, PA Affidavit of Serviee Now, March 27, 20 01 at 3:55 o'clock P M. served the within Notice & Complaint Joelle Crabbs-Miller upon at 5095 Spring Rd. Shermansdale, Pa. 17090 by handing to Joelle Crabbs-Miller a True&Attested copy of the original Notice&Complaint and made known to her so S, James C. Deputy Sheriff of Sworn and subscribed before me this cVM day of J&??jj__ ; 209/ ?/ I GG?,?(d1 u {??} + Qtc U 14 ARIALSFAL SJ ?)l MARGANETF.FLICIONGER;NOTARYPUBLIC I BLOUMFIELOBORO:,PERRY000NTY I MY COMMISSION EXPIRES FEB. 16.2004 the contents thereof. Wilson Perry COSTS SERVICE 18.00 MILEAGE 27.60 AFFIDAVIT 2.00 County, PA 3P?Q,s S &7.60 cc :c SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2001-01214 P COMMONWEALTH OF PENNSYLVANIA.: COUNTY OF CUMBERLAND FITTING JEFFREY P VS CRABBS-MILLER JOELLE R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named PLAINTIFF , to wit: CRABBS-MILLER JOELLE but was unable to locate Her in his bailiwick He therefore deputized the sheriff of PERRY County, Pennsylvania, to serve the within COMPLAINT & NOTICE On March 30th , 2001 , this office was in receipt of the attached return from PERRY Sheriff's Costs: So answers: Docketing 18.00 / Out of County 9.00 Surcharge 10.00 R. Thomas K it ner" DEP. PERRY CO 47.60 Sheriff of Cumberland County .00 84.60 03/30/2001 MARTSON, DEARDORFF, WILLIAMS Sworn and subscribed to before me this // ?7-' day of C4i-4' 2vv/ A. D. Prothonotary ., JEFFREY P. FITTING, Plaintiff v. i JOELLE CRABBS-MILLER, Defendant IN THE COURT OF COHMON PLEAS OF CL14BERLAND COUNTY, PENNSYLVANIA NO. 01-1214 CIVIL 19 RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE. THE JUDGES OF SAID COURT: George B. Faller, Jr., Esquire , counsel for the plaintiff/dATACbfCACO(0C in the above action (h1YXAXX1M=), respectfully represents that: 1. The above-captioned action. (}{}v{%oWxM) is ()g* at issue. 2. The claim of the plaintiff in the action is S 6,645.31 The counterclaim of the defendant in the action is The following attorneys are interested in the case(s) as counsel or are other- wise disqualified to sit as arbitrators: William A. Addams, Esquire WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully sub tted, / ORDER OF COURT Oka r/- AND NOW, ??J7 ? ?, in consideration `6f the foregoing petition,\Lr,? /f/LLrlirO?irL Esq., ?L^r? F ^C???7 Esq., and fXiS? .Esq., are appointed arbitrators in the , above-captioned action (or actions) as prayed for. By the Court, ?/ ^ P. J. JEFFREY P. FITTING, Plaintiff V. JOELLE CRABBS-MILLER, Defendant IN THE COURT OF COMMON PLEAS OF MBERLAND COUNTY, PENNSYLVANIA' NO. 01-1214 CIVIL 19 RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the following form; PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE. THE JUDGES OF SAID COURT: George B. Faller, Jr., Esquire , counsel for the plaintiff/dWJAMWM= in the above action (I&XINXIMA), respectfully represents that: 1. The above-captioned action Osovojg ) is tgfAh at issue. 2. The claim of the plaintiff in the action is $ 6,645.31 The counterclaim of the defendant in the action is The following attorneys are interested in the case(s) as counsel or are other- wise disqualified to sit as arbitrators: William A. Addams, Esquire WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully sub 'tted, I ORDER OF COURT AND NOW, in consideration bf the foregoing petition, Esq., V-41? Esq., and Ce?rcl???r ,Esq., are appointed arbitrators in the above-captioned action (or actions) as praved for. By the CourtL. 4 ^ P. J. J ;"?? . N ? J I? ? C '? C: ?- _._ ri '? ?: ; ??c _"_ =c i' c' ?.? .1 :' i l . (7? .. ANDREWS & JOHNSON Attorneys at Law 78 West Pomfret Street Carlisle, PA 17013 TAYLOR P. ANDREWS RONALD E. JOHNSON Telephone (717) 243-0123 Telefax (717) 243-0061 FAX TRANSMITTAL SHEET TO: George B. Faller, Jr., Esquire William A. Addams, Esquire (Arbitrator) Stephen Banko, Esquire (Arbitrator) Susan H. Confair, Esquire FROM: Taylor P. Andrews, Chairman DATE: June 22, 2001 TOTAL PAGES IN THIS TRANSMISSION: 1 V 243-1850 249-0457 \6 975-8124 / 763-1907 V RE: Jeffrey P. Fitting vs. Joelle Crabbs-Miller Schedule of Arbitration hearing Unfortunately, we have star[ over again with new dates, therefor, dates for you to check your calendars and advise as to which dart ?(aa?o r Y- ??? August 23rd at 10 a.m or 2 p.m._ 6K, August 31'at lb a. . or 2 p.m. September 10"' at 10 a.m. or 2-pan. Fgll2.r Vto Wddua s n 0 Septen,Lui 13" at 10 a.m. or 2 p.m. ??v £adc?.cng n.? Please advise at your earliest convenience the dates that you are available. Please provide more than one date if possible. X SENT BY FAX ONLY INITIAL AS PROOF OF FAXING u ORIGINAL TO FOLLOW BY MAIL ,Nutt-,TUN 22 '01 02:25PM MPRGOLIS EDELSTEIN SOH ANDREWS & JOHNSON Attorneys at Law 78 West Pomfret Street Carlisle. PA 17013 'i AYI.OR P. ANDREWS RONALD E. JOHNSON FAX TRANSMITTAL SHEET TO: lip... e!i I Jr., F04ul" 2437 Mdf lis.. . nddlln,o, I:squbo 2491" V-' )?i, (Arbitrator) Stephen Banko, Esquire 975.8124 (Arbitrator) SIIC9? *r -r-P.? E_W-An I e r Taylor P. Andrews, Chairman DATE; June 22, 2001 TOTAL PAGES IN THIS TRANSMISSION: I RF: Jeffrey P. Fitting vs. Joelle Crobbi,-Miller Schedule of Arbitration hearing Telephone (717) 243-0123 Telefax (717) 243-0001 Unforturtately', we have start over again with new dates, therefore. I ant providing the following dates for you to check your calendars and advise as to which dates you are available. August 23"' at 10 a.m. or 2 p.m, August 3l" at 10 a.m. or 2 p,m. (? 1+ September 10" at 10 a.m. or 2 p.m. September 13" at 10 a.m. o. 2 p.m. Please advise at your earliest convenience the dates that you are available. Please provide more than one date if possible. SENT 13Y FAX ONLY INITIAL AS PROOF I f OF FAXING LL_???1f ORIGINAL TO FOLLOW BY MAIL 717 2430961 "" F.2/c g?;'2r1'Gl'91 1::4^c. 71 !2431367 MDWO ,,,?n--c. -ni a a .3T c?M Ali:o 13EWS B. SOHN 3oH ANDREWS & JOHNSON Attorneys at Low 78 West Pomfret Street Carlisle, PA 17013 I-AYLOR P. ANDREWS RONALD n. JOHNSON F,AX TWSMITTAL SIIRET TO: g4xge B. Fidler, Jr., Esquire 1)0.1 [ ?lllam A. Addams, Esquire 249-0497 (Arbitrator) Stephen Boako, Esquire 973-9124 (Arbitrator) Susan H. Confeir, Esquire 763.1407 FROM: Taylor F. Andrews, Chairman DATE: June 22, 2001 TOTAL PAGES IN THIS TRANSMISSION: 1 RE.: Jeffrey P. Fining vs. Jnalle Crabbs-Miilcr Schedule efArbitention hearing Telephone (717) 241-0123 TOCfax (717) 243.0061 1;nfertunately, we have start over again with new dates, therefore, lam provldiny, the following dates for you to check your calendars and advise as to which dates you are available. August 23ed at 10 am. or 2 p.m. August 31" at 10 a.m. or 2 p.m. !-P-:0viac mk Il' W u, ?0 1 a.t,,. ur Z ?7.ia,. 1*4 Please advise at your earliest convenience the dates that you are available. Plemore than one date if possible. r- SENT 13Y FAX ONLY INI'tiAT. AS PROOF Or TAXING ORIGINAL TO FOLLOW $Y MAIL PAGE 01161 TIT 243006w1 r.01 HE IY'' G1 13: ae i17249U457 HAryFTLAWp PFA PAGE UI/51 JUN-22-C3 11;ae PM '.REW9 G JpNN50N 11• s<Ebb63 P. PI ANDREWS & JOHNSON Attorneys At Law 78 West Pumlrot Suter Carligle, PA 170'.3 TAYLOR P. ANDREWS Telephone (717) 243.0123 RONALD 13. fOHNSON Telefaa (717) 243-0061 FAX TRANSMITTAL SHEET TO:: George 8. Faller, Jr.. F.egosre 243.1,850' ??-,,,,?- William A. Add¦ms, Esquire 249-0457 ?- (Arbitrator) Stephen Bunke. Esquire 975-8124 (Arbitrator) Susan H. Confair, Esquire 763-1907 FROM: TayJor P. Andrews, Chairman DATE; June 22, 2001 TOI"AL PAGES IN THIS TRANSMISSION: i RF: Jeffrey P. Fitting vs. Juelle Crabby ,Miller Schedule of Arbitration hearing VMbltunatcly, we have start o%vrapain with new dates. therefore, I am pruviding the following dates for you to chuck your calcadars and udvise as to which dates you are available. August 23'st 10 a.m. or I p.m. August 31 ° at 10 a.m. o: 2 p.m. Sep -nber 10"' at 10 u,m, or 2 p.m. *LCI .La U'"at 10..N,..,. t P.mr c luwc advisa at you, earliest convenience the dates that you am available, Please provide more thm one date if possible. pit SCNT BYFAX ONLY INITIAL AS PROO.f OF FAXNO ORIGINAL TO FOLLOW 3Y MAIL 06/22!2991 11:14 7172431UU, VM10 JUN-23-01 39!28 AM ANDREWS & JOHNSON ANDREWS d& JOHNSON Atturneys at Law 79 West Pornttet Street Carlisle, PA 17013 TAYLOR R ANDREWS RONALD E. JOHNSON FAX TRANSMITTAL SHEET TO: George B. Faller, Jr., Esquire 243-1850 William A. Addems, Esquire 249-0457 (Arbitrator) Stephen Bonko, Esquire 975-8124 (Arbitrator) Susan H. Confair, Esquire 763-1907 FROM. Taylor P. Andrews, Chairman DATE: June 22, 2001 TOTAL PACES IN THIS TRANSMISSION: 1 RF: Jeffrey P. Fitting vs. Joelle Crsbbs-,Mtller Schedule of Arbitration bearing Telephone (717) 243-0123 Telefax (717) 243.0061 I am providing the following dates for you to check your calendars and advise as to which dates you are available. July 91' 2t100r?"prtT. ` July 20 at 10 .. 2 p.1n. r July 266"' at 10 a.m. 2 A m• July 77" at 10 2.-1 m or nr 2 p ? A O CaJUly 30"'at 10 &1' m. or p.m. 41145 AwV' -"" tf 10 A 59 Please advise at your, earliest convenience the dz?? th??at,?,you arc available. Please provide more than one date if possible, G t? ?w'f'n+ Q `?/? X SrNT BY FAX ONLY /T? ?3 4Mti 0re//gINITIAI. AS PROOF Of i AX1NC ORIGINAL TO FOLLOW MA 4 _ S ?,? dam, n< ?n•t ? 6W1 bt^ 6 m PAGE ©1/01 TIT 2480081 P.01 2E/2:'2P@1 1C,:29 71-2490457 rNF'ILAW ZRM RAGE 61/01 w?-tea-o. ov:ze wn .."Ewa a JOHNSON va'+ 24300.1 e.n1 ANDREWS & JOHNSON Attorneys at Low 78 West Pomfret Street Carlisle, PA 17013 TAYLOR P. ANDREWS Tc]aphoraw (717) 243-0123 RONALD h, JOHNSON Telefax (717) 243.0061 j'AJf TRANSMITTAL SHEET TO: George M Faller, Jr., Raquiw 243.19 William A. Addama, Esquire 249.0457 (Arbitrator) Stephen Banlro, Eequlre 975.8124 (Arbitrator) Susan H. Coufair, Esquire 713.1907 FROM: Taylor P. Andrews, Chairmen DATE: June 22, 2001 TOTAL PAGES IN THIS TRANSMISSION: I RE: Jeffrey P. Bitting vs. Joelia Crubbe-Miller Schedule of Arbitration hearing I am providing the following dates for you to chook your calendars and advise as to which dates you = ovailable. WV/.91' al 10 e.rn. - 2 r..... sd 9 aw. ar '- P.M. July 261, of 10 a.m. or 2 P.M. July 27' at 10 A. m, or 2 g.m. July 30'"al 10 a.m. or 2 p.m. August 3" at 10 a.m. Please odvlso at your earliest convenience the data Nat you are available. Please provide more then one date if possible. ?X SENT BY FAX ONLY INITIAL AS PROOF OP FAXING ORIGINAL TO FOLLOW BY MAIL suN-TUN 22 'Ci1 19:0,1Ai MAPGO-IS EDELSTEINNSON ANDREWS & JOHNSON Attorneys at Law 78 West Pomfret Street Carlisle, PA 17013 T1T 2430061 P 2'.aP. 01 I*AYLOR P. ANDREWS RONALD E. JOIf.NSON FAX TRANSMITTAL SHEET i /`( n"' Arbitrator) Stephen Reako, Esquire 973.8124 (Arbitrators rw--' It "W"% V. fo FIR Eft. Taylor P. AbdrOws, Chairman DATE: Juaa 22, 2001 TOTAL PAGES IN THIS TRANSMISSION: 1 RF:: Jeffrey P. Fitting vs. Joelle Crabba-Miller Schedule of Arbitration hearing Telephone (717) 243-0123 Tolefox (717) 243-0061 I am providing the fohowing dates for you to check your ealeadses and advise as to which dates you are available. July 9" at 10 a.m. or 2 p.m. July 26 or p.m.OK July 3&'at 10 a.m. or 2 p,m c Il, August 3" at 10 a,m. „bj< Please advise at your earliest convenience the dates that you arc available. Plcasc provide more titan one dato if possible. X SlNT BY PAX ONLY INII'W. AS PROOF I I OF FAXING ORIGINAL TO FOLLOW BY MAIL ANDREWS & JOHNSON Attorneys at Law TAYLOR P. ANDREWS RONALD E. JOHNSON (Arbitrator) Susan H. Confair, Esquire 763-1907 FAX TRANSMITTAL SHEET TO: George B. Faller, Jr., Esquire 243-1850 William A. Addams, Esquire 249-0457 (Arbitrator) Stephen Banko, Esquire 975-8124 ?/ FROM: Taylor P. Andrews, Chairman DATE: June 22, 2001 TOTAL PAGES IN THIS TRANSMISSION: 1 RE: Jeffrey P. Fitting vs. Joelle Crabbs-Miller Schedule of Arbitration hearing Telephone (717) 243-0123 Telefax (717) 243-0061 I am providing the following dates for you to check your calendars and advise as to which dates you are available. 78 West Pomfret Street Carlisle, PA 17013 July 91 at 10 a.m. of 2 p.itt. July 23" at 10 a.m. or 2 p.m. July 26' at 10 a.m. or 2 p.m. ,i,ly 77?h nt ltl n m or I p M; July 30'at 10 a.m. of 2 p.m. August 3`d at 10 a.m. IrJQ ???k? r, ? AdJc'?n,,ng t? /P.?_a-v?ko ? o W r\?,2... nJ el (L Please advise at your earliest convenience the dates that you are available. Please provide more than one date if possible. X SENT BY FAX ONLY INITIAL AS PROOF OF FAXING C? ORIGINAL TO FOLLOW BY MAIL JEFFREY P. FITTING, : IN THE COURT OF COMMON PLEAS -- Plaintiff . OF CUMBERLAND COUNTY, PENNSVYLANAI V. : NO.01-1214 CIVIL JOELLE CRABBS-MILLER, Defendant oo?? ORDER AND NOW, this o? 7 day of 2001, Stephen L. Banko, Jr., Esquire, having been appointed Arbitrator in the above-captioned matter, is excused and Rolf E. Kroll, Esquire, is hereby appointed by the Court to serve in the above-captioned action in Stephen L. Banko, Jr.'s place. BY THE COURT: Geor E f , s nntJu e ) In The Court of Common Pleas of Cumberland County, Pennsylvania No < /2,/y j2a OATH We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constit Zion of this ommon- wealth and that we will discharge the duties of ou i lity. for Chairman / / v c- rv ?. Rock Kcbi/ AWARD We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be q separately stated.) Wffle? I ()?r?C'?)JtE'y?T +6??(nQ«/ fi c7 cd gSt cv[ applicable.) . Arbitrator, dissent, Date of Hearing: "2? j;Czairmaa Date of Award: NOTICE OF ENTRT-OF AWARE Now, the, day of A?? ??5? at L.M., the above award was entered upon the dZet and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ j90.,00 othon tart' Deputy ?? a ?? ? ? ? a'? `' V Z. L1 N R oU ? _. ?.._. . ?. _. _ ?? . _,... .. _._.?.- . Z ?? ? r? 1 III??V 4? ? . _ / ? .. ... _1 .?Y.... « ... .. __. _. .._.. ?... Z N \ L^ 3 1 C ? ? y?? _ \\' ?? __ t0 F: WILES\DATAFILE\DONEOAL. DOC\ 176-pea. 1/ma . Geated 01M9/0109. 5200 AM Revised 11/16/010858.08AM 3050176 JEFFREY P. FITTING, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW NO. 01-1214 JOELLE CRABBS-MILLER, Defendant JURY TRIAL OF TWELVE DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please enter judgment on the Arbitrator's Award against the Defendant in the amount of $6,645.31. MARTSON DEARDORFF WILLIAMS & OTTO By Ge rge B. aller, Jr., Vscqi ire I.D. Number 49813 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff Jeffrey P. Fitting Date: November 16, 2001 In The Court of Common Pleas, of Cumberland County, Pennsylvania NO. OATH We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitutioa of this-.-Common- wealth and that we will discharge the duties of out f th idelity. TRUE COPY FROM RECORD r f Chairman in Testimony whereof, I here unto set my hand and the sal of said rt at sle, Pa. This fO` Slay l Prothonotary AWARD We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) 1?., ?? 't..zC??, ?i '?-- ?l. 1,C C7 ?..n L. cc c5 3V applicable.) Arbitrator, dissent ii Date of Hearing: c l ' Chairman Date of Award: "1> i Z i} s L v r r OF ENTRY OF AWARD i t7 vgOTIC.. Now, the a' ff?day of /a1!i(.t ig4,01 , at ?.;i., the above award was entered upon the ddcket and notice thereof given by mail to the parties or their attornevs. Arbitrators' compensation to be paid upon appeal: $ ?/yo Uo c . -r f- ?° othongtary By Deputy- CERTIFICATE OF SERVICE I, Melinda A. Hall, an authorized agent for Martson Deardorff Williams & Otto, 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: William A. Addams, Esquire LAW OFFICE OF MICHAEL J. HANFT 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013 MARTSON DEARDORFF WILLIAMS ' & OTTO By (f - /T d dv Melinda 11. Hall Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: November 16, 2001 ?? ?J ? ? \7 .? P 1PIL6.S0ATAPjLF,MNRGAL,D0O 106-aH.I/m,h Ge & 01/09/0109:52:00AM Revised' 01/29/0202:51:05PM 3050.1]6 JEFFREY P. FITTING, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW NO. 01-1214 JOELLE CRABBS-MILLER, Defendant JURY TRIAL OF TWELVE DEMANDED AFFIDAVIT The Judgment in the above captioned action arose from a motor vehicle accident. MARTSON DEARDORFF LLIAMS & OTTO By, David R. Galloway, squire I.D. Number 87326 v Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff Jeffrey P. Fitting Date: January 29, 2002 DL-201 (10-97) Bureau of Driver Licensing CERTIFICATION OF P.O. Box 60037 MOTOR VEHICLE JUDGMENT Harrisburg, PA 17106-0037 TO THE SECRETARY OF TRANSPORTATION COURT INFORMATION COURT CIVIL ACTION COUNTY CUMBERLAND NUMBER 01-1214 YEAR 2001 This is to certify that on November 16, 2001 a judgment for $ 6,645.31 plus $interest & cost was entered against the following: (AMOUNT) (COST) (Please use a separate form for each) JUDGMENT DEBTOR (Please Print or Type) NAME SEX DATE OF BIRTH FIRST MIDDLE LAST MONTH DAY YEAR Joelle Crabbs-Miller F 08 15 68 ADDRESS 5090 Spring Road I- 1 SECURITY NUMBER CITY STATE I ZIP E I I SOCIAL Shermansdale PA 17090 DRIVER NUMBER STATE DATE OF ACCIDENT CLAIM NUMBER 21 627 986 PA March 10, 2000 PAE0527623(77) ? Check this block if defendant is a resident of another state REPRESENTATIVE FOR THE JUDGMENT JUDGMENT CREDITOR CREDITOR (if applicable) Mr. Jeffrey P. Fitting c/o Donegal Companies C,org,- R- Fa77Pr, .7r-, RRr711lrP (NAME) (NAME) P.O. Box 302 Ten East High Street (STREET ADDRESS) (STREET ADDRESS) Marietta, PA 17547 Carlisle, PA 17013 (CITY & STATE) (ZIP) (CITY & STATE) (ZIP) (717) 426-1931 (717) 243-3341 _ (TELEPHONE NUMBER) (TELEPHONE NUMBER) THE ABOVE MENTIONED JUDGMENT AROSE FROM A MOTOR VEHICLE ACCIDENT. SIXTY DAYS HAVE ELAPSED SINCE THE ENTRY OF SAID JUDGMENT, AND THE SAME HAS NOT BEEN SATISFIED OF RECORD AND NO APPEAL HAS BEEN TAKEN THEREFROM. IN WITNESS WHEREOF, I have hereunto affixed my hand and seal of the court this Day of 19____ (SIGNATURE OF CLERK OR JUDGE OF THE COURT IN WHICH THE JUDGMENT WAS RENDERED) SEAL (TYPE OR PRINT NAME) RETURN COMPLETED Bureau of Driver Licensing, P.O. Box 60037, FORM TO: Harrisburg, Pennsylvania 17106-0037 W r1 F:\FILES\Donega13050\Current%176\3050.176 pra JEFFREY P. FITTING, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 01 - 1214 CIVIL TERM JOELLE CRABBS-MILLER, Defendant : JURY TRIAL DEMANDED PRAECIPE To the Prothonotary: Please mark the above-captioned matter settled and discontinued, and the judgment satisfied. MARTSON LAW OFFICES By Christopher E. Rice, Esquire Attorney I.D. No. 90916 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Date: 7_0-07 na o ? t c? Q Z