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HomeMy WebLinkAbout10-4642Firm File No.: 01-10-109 THE LAW OFFICES OF STEWART C. CRAWFORD & ASSOCIATES By: Stewart C. Crawford, Sr., Esquire F?' F 11c Ti-'E „'F?Y Attorney Id. No.: 09827 223 North Monroe Street ZO .j,!f 14 : J Media, PA 19063 Telephone: (877)-992-6311, ext. 21 Web: www.subrolaw.us E-Mail: sccrawfordna_,subrolaw.us Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW ALLSTATE INSURANCE COMPANY IN CIVIL ACTION 309 Lakeside Drive, Suite 100 Horsham, PA 19044 V. HEATHER BEHRENS 2137 Newville Road Carlisle, PA 17013 And MAURICE CUTLER 2137 Newville Road Carlisle, PA 17013 NO.. 1b - i464A NOTICE TO DEFEND 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 an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are further warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYEROR 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 32 SOUTH BEDFORD STREET CARLISLE PA 17013 1-800-990-9108 717-249-3166 Cwa-gm Le ban demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dial de plaza al partir de la fecha de Is demanda y la notificacion. Hace faita asentar una comparencia escrita o en persona o con on abogado y entregar a la torte en forma sus defenses o sus objectiones a las demandas en contra de su persona. Ses avisado que si usted no se defiende la corte tomara modidas ypuede continuar ila demanda en contra suya sin previo aviso o notificacion. Ademas, la Corte puede decidir a favor del demandante y requiera que usted cumpia con todas las provisions de esta demanda. Usted puede perder dinero o sus propiedaces u otros derechos importantes pain usted. USTED DEBE LLEVAR ESTA AVISO A UN ABOGADO ENESEQUIDA. SI USTED NO TIENE UN ABOGADO Y NO PUEDEPAGAR LOS SERVICIOS DE UN ABOGADO, DEBE COMUNICARSE CON LA SIGUIENTE OFICINA PARA AVERIGUAR DONDE PUEDE OBTENER AYUDA LEGAL. 0 OA-00 PD ATE`/ C* 1'180y .U 3 R.* c2gS Firm File No.: 01-10-109 THE LAW OFFICES OF STEWART C. CRAWFORD & ASSOCIATES By: Stewart C. Crawford, Sr., Esquire Attorney Id. No.: 09827 223 North Monroe Street Media, PA 19063 Telephone: (877)-992-6311, ext. 21 Web: www.subrolaw.us E-Mail: sccrawfordna_,subrolaw.us Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW ALLSTATE INSURANCE COMPANY IN CIVIL ACTION 309 Lakeside Drive, Suite 100 Horsham, PA 19044 V. NO.. HEATHER BEHRENS 2137 Newville Road Carlisle, PA 17013 And MAURICE CUTLER 2137 Newville Road Carlisle, PA 17013 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, Heather Behrens, is an adult individual and was the owner of the motor vehicle involved in this incident on March 25, 2009, and at all times pertinent hereto resided at the above-captioned address. 3. Defendant, Maurice Cutler, is an adult individual and, at all times pertinent hereto resided at the above-captioned address and was the operator of 1 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 Nancy Speck, 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 legally parked in the 100 Block on E. High Street in the Borough of Carlisle in Cumberland County, Pennsylvania. The defendant vehicle was traveling in the 100 Block on E. High Street. The defendant carelessly left the travel portion of the roadway and struck the insured vehicle causing damages. 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. 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; c. did not operate their vehicle with a speed calculated to avoid collision with another vehicle or in a manner consistent with their duty to exercise caution at an intersection in violation of 75 Pa.C.S. § 3361; d. in addition to traditional negligence, defendant is negligent per se for violating the above referenced statutes; 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. § 3714 and 75 Pa.C.S. § 3361. 8. Plaintiff became liable for damages that arose out of this accident. 2 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$2,532.62. WHEREFORE, Plaintiff demands judgment for $2,532.62 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. MAURICE CUTLER 11. Plaintiff incorporates paragraphs 1 through 10 inclusive as if fully set for that length herein. 12. Defendant is liable as the negligent driver. WHEREFORE, Plaintiff demands judgment for $2,532.62 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. HEATHER BEHRENS 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. 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 $2,532.62 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. 3 Stewart C. Crawford, Sr., Esquire Date: q -6?610 Attorney for Plaintiff . , 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 unworn falsification to authorities. JY/ Stewart C. Crawford, Sr., Esquire Attorney for Plaintiff oau,1 9 )6-ib 5 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart SOiICItOr i ., S,: ~', ~~~~ p. ;,! r - f, _ ,~ -~. Allstate Insurance Company Case Number vs. Maurice Cutler (et al.) 2010-4642 SHERIFF'S RETURN OF SERVICE 07/19/2010 08:30 PM -Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on July 19, 2010 at 2030 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Heather M. Behrens, by making known unto Elen Paulus, Mother of defendant at 2137 Newville Road, Carlisle, Cumberland County, Pennsylvania 17013 its contents and t t e s e time handing to her personally the said true and correct copy of the same. M RK CONKLIN, DEPUTY 07/20/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Maurice Cutler, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Maurice Cutler. Elen Paulus current resident of 2137 Newville Road, Carlisle, PA 17013 advised Deputies, Maurice Cutler has never resided at this address, and he is thought to be residing at 605 Willow Street, Highspire, PA 17034. SHERIFF COST: $54.40 July 20, 2010 SHERIFF'S OFFICE OF CUMBERLAND COUNTY [ ~atr a~' ~it~6rrf~ (cj CountySwte Shenff. Teleosoft. Inc. SO ANSWERS, RON R ANDERSON, SHERIFF Fil QF THE o . F: t~u~. ~ :~';~Tf~RY Firm File No.: 01-10-109 THE LAW OFFICES OF STEWART C. CRAWFORD & ASSOCIATES ~~~~ ~~~~ _ _ ~°' ~~ ~ ~ By: Stewart C. Crawford, Sr., Esquire Attorney Id. No.: 09827 CC~°96EF'_ ," ; [ d~1JiyTY 223 North Monroe Street R E N i - , __ . `.=~; F (~, Media, PA 19063 Telephone: (877)-992-6311, ext. 21 Web: www.subrolaw.us E-Mail: sccrawfordnsubrolaw.us Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW ALLSTATE INSURANCE COMPANY IN CIVIL ACTION 309 Lakeside Drive, Suite 100 Horsham, PA 19044 NO.: 2010-04642 v. HEATHER BEHRENS 2137 Newville Road Carlisle, PA 17013 And MAURICE CUTLER 2137 Newville Road Carlisle, PA 17013 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate this complaint an additional thirty (30) days. THE LAW OFFICES OF STEWART C. CRAWFORD ASSOCIATES Stewa C. Crawford, Esquire O Attorney for Plaintiff ~o.oo pD A`nY Dated: 6 0 '`~ C~ ISo28/ Q.~o4~i55$ SHERIFF'S OFFICE OF CUMBERLAND COUNTY , ,-, Ronny R Anderson , 4 Sheriff ue??rf tr of 1, _` - «- T Jody S Smith $ 4164 t Chief Deputy Richard W Stewart -"? -7) Solicitor f"CE OF THE S14ERIFF x `j Allstate Insurance Company vs. Case Number Maurice Cutler (et al.) 2010-4642 SHERIFF'S RETURN OF SERVICE 11/04/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Maurice Cutler, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint and Notice according to law. 11/09/2010 08:55 AM - Dauphin County Return: And now November 9, 2010 at 0855 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Maurice Cutler by making known unto Valdez Fisher, Brother of defendant at 555 Willow Street, Apartment E, Highspire, PA 17034 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 November 16, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySuite ShenR, Teleosoft. Inc. t -T-r.t of t4 e "*cri William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin ALLSTATE INSURANCE COMPANY VS MAURICE CUTLER Sheriff s Return No. 2010-T-3394 OTHER COUNTY NO. 20104642 And now: NOVEMBER 9, 2010 at 8:55:00 AM served the within NOTICE & COMPLAINT upon MAURICE CUTLER by personally handing to VALDEZ FISHER 1 true attested copy of the original NOTICE & COMPLAINT and making known to him/her the contents thereof at 555 WILLOW STREET, APT E HIGHSPIRE PA 17034 BROTHER Sworn and subscribed to before me this 10TH day of November, 2010 -)P*Z COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County M Commission Expires Au ust 172014 So Answers, °1c- , Pa. Sheriff of Dauphin Count?- By DeputyMriff Deputy: S SCHAEFFER Sheriffs Costs: $47.25 11/8/2010 Firm File No.: 01-10-109 THE LAW OFFICES OF STEWART C. CRAWFORD & ASSOCIATES By: Stewart C. Crawford, Sr., Esquire Attorney Id. No.: 09827 - , 223 North Monroe Street ) c c , ,,, Media, PA 19063 c _ -n Telephone: (877)-992-6311, ext. 21 Web: www.subrolaw.us CIO E-Mail: sccrawford@subrolaw.us o -? Attorney for Plaintiff ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN c1 PENNSYLVANIA ``` CIVIL ACTION-LAW I hereby certify that pursuant to Local Rule of Court sent Notice to Defendant STEWART C. CRAWFORD, ESQUIRE Attorney for Plaintiff I.D. # 09827 ENTRY OF DEFAULT JUDGMENT AND NOW, to wit, this j ? day of ?ruav? , 2011 a Default Judgment is entered as above, namely in favor of the Plaintiff and agai 7ttheDefendant. DEPUTY PROTHONOTARY ALLSTATE INSURANCE COMPANY IN CIVIL ACTION V. HEATHER BEHRENS & MAURICE NO.: 2010-04642 CUTLER PRAECIPE FOR DEFAULT JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter a Default Judgment in favor of the Plaintiff and against the Defendant(s) HEATHER BEHRENS AND MAURICE CUTLER, in the amount of $2,532.62 for failure to Answer the Complaint in Civil Action within twenty (20) days from the date of service. of C9 intent to take Default. See attached. "I __4 m -0 rn :Poc:; n? ?r 7 ? rr Gtn?+ =i4.,.qa R??55 ??cc Firm File No.: 01-10-109 THE LAW OFFICES OF STEWART C. CRAWFORD & ASSOCIATES By: Stewart C. Crawford, Sr., Esquire Attorney Id. No.: 09827 223 North Monroe Street Media, PA 19063 Telephone: (877)-992-6311, ext. 21 Web: www.subrolaw.us E-Mail: sccrawfordksubrolaw.us Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW ALLSTATE INSURANCE COMPANY IN CIVIL ACTION v. HEATHER BEHRENS & MAURICE NO.: 2010-04642 CUTLER NOTICE Pursuant to Rule of Civil Procedure No. 236, Notice is given that a Default Judgment and Assessment of Damages in the above-captioned matter has been entered against you on T-60 _12. df1( 9 File #01-10-109 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ALLSTATE INSURANCE COMPANY IN CIVIL ACTION V. HEATHER BEHRENS & MAURICE NO.: 2010-04642 CUTLER AFFIDAVIT UNDER SOLDIERS'AND SAILORS' CIVIL RELIEFACT OF 1940 AS AMENDED STATE OF PENNSYLVANIA : COUNTY OF DELAWARE SS Stewart C. Crawford, Esquire, being duly sworn according to the law that HEATHER BEHRENS AND MAURICE CUTLER is/are not in the military service of the United States of America as defined by the Soldiers' and Sailors' Civil Relief Act of 1940 as amended; that said Defendant(s) is/are over 18 years of age and is/are employed. i STEWART C. CRAWFORD, Esquire Subscribed and sworn to before me this day of 11L l? A d NoTary Publi6,-'Mate of PenrfsyWania My commission is permanent / expires: or ar?v NOTARIAL SEAL DONNA J. HOCHBERG, Notary Public Media Boro., Delaware County i sion_Exl*es May 18, 2014 File #01-10-109 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ALLSTATE INSURANCE COMPANY IN CIVIL ACTION V. HEATHER BEHRENS & MAURICE NO.: 2010-04642 CUTLER AFFIDAVIT OF MAILING NOTICE COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF DELAWARE Stewart C. Crawford, Esquire, being duly sworn according to law, deposes and says that he is attorney for Plaintiff and that on December 21, 2010 he sent by certified mail, return receipt requested, to the Defendant(S) HEATHER BEHRENS AND MAURICE CUTLER the repair estimate, together with a notice that damages would be assessed on or after January 7, 2011 in the amount of the repair estimate unless prior to that date the Defendant(s) had, by written Praecipe, filed with the Prothonotary a request for trial on the issue of damages. Stewart C. Crawford, Esquire Attorney for Plaintiff(s) Subscribed and sworn to before me this day of 2011. NoTary Public,?tate of Pennsy"nia My commission is permanent / expires: COMMONWEALM Ord PM*Wf .VAM^ NOTARIAL SEAL DONNA J. HOCHBERG, Notary Public Media Boro., Delaware County 14 Firm File No.: 01-10-109 THE LAW OFFICES OF STEWART C By: Stewart C. Crawford, Sr., Esquire Attorney Id. No.: 09827 223 North Monroe Street Media, PA 19063 Telephone: (877)-992-6311, ext. 21 Web: www.subrolaw.us E-Mail: sccrawford&subrolaw.us Attorney for Plaintiff CRAWFORD & ASSOCIATES IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW ALLSTATE INSURANCE COMPANY IN CIVIL ACTION V. HEATHER BEHRENS & MAURICE CUTLER NO.: 2010-04642 TO: MAURICE CUTLER 555 Willow Street, Apt. E Highspire, PA 17034 DATE OF NOTICE: December 21, 2010 IMPORTANT NOTICE You are in default because you have failed to take action required of you in this case. Unless you act within Ten (10) Days from the date of this notice as set forth above, 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. Cumberland County Lawyer Referral Service Taryn Dixon, Court Administrator One Courthouse Square Carlisle, PA 17013 (717) 240-6200 STEWART C. CRAWFORD, ESQUIRE Attorney for Plaintiff(s) Firm File No.: 01-10-109 THE LAW OFFICES OF STEWART C By: Stewart C. Crawford, Sr., Esquire Attorney Id. No.: 09827 223 North Monroe Street Media, PA 19063 Telephone: (877)-992-6311, ext. 21 Web: www.subrolaw.us E-Mail: sccrawford&subrolaw.us Attorney for Plaintiff CRAWFORD & ASSOCIATES IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW ALLSTATE INSURANCE COMPANY IN CIVIL ACTION V. HEATHER BEHRENS & MAURICE CUTLER NO.: 2010-04642 TO: HEATHER BEHRENS 2137 Newville Road Carlisle, PA 17013 DATE OF NOTICE: December 21, 2010 IMPORTANT NOTICE You are in default because you have failed to take action required of you in this case. Unless you act within Ten (10) Days from the date of this notice as set forth above, 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. Cumberland County Lawyer Referral Service Taryn Dixon, Court Administrator One Courthouse Square Carlisle, PA 17013 (717) 240-6200 STEWA C. RA ORD, ESQUIRE Attorney for Plaintiff(s) THE LAW OFFICES OF STEWART C. CRAWFORD & ASSOCIATES 223 NORTH MONROE STREET P.O. BOX E MEDIA, PA 19063 Tel: (610) 565-7050 Fax: (610) 565-5348 Toll Free: (877) 992-6311 www.subrolaw.us Stewart C. Crawford, Esquire Direct E-Mail: sccrawford@subrolaw.us Direct Phone: 610-565-7050, Ext. 21 December 21, 2010 VIA CERTIFIED MAIL HEATHER BEHRENS 2137 Newville Road Carlisle, PA 17013 Re: Allstate Insurance Company v. Behrens and Cutler Cumberland C.C.P. No.: 2010-04642 Our file: 01-10-109 Dear Ms. Behrens: Please be advised that I represent Allstate Insurance Company concerning property damage to their insured vehicle that occurred on March 25, 2009. I enclose herewith a copy of the Affidavit of Repairman, together with the appraisal indicating that the cost to repair the insured's property totals $2,532.62. I intend on filing a Praecipe for Assessment of Damages under Pennsylvania Rules of Civil Procedure No. 1037 and have the Prothonotary assess damages in that amount on January 7, 2011, unless prior to that date, by written Praecipe, you file with the Prothonotary a request for trial on the issue of damages. Very truly yours, Stew rd, Esquire SCC/ras Enclosures THE LAW OFFICES OF STEWART C. CRAWFORD & ASSOCIATES 223 NORTH MONROE STREET P.O. BOX E MEDIA, PA 19063 Tel: (610) 565-7050 Fax: (610) 565-5348 Toll Free: (877) 992-6311 www.subrolaw.us Stewart C. Crawford, Esquire Direct E-Mail: sccrawford@subrolaw.us Direct Phone: 610-565-7050, Ext. 21 December 21, 2010 VIA CERTIFIED MAIL MAURICE CUTLER 555 Willow Street, Apt. E Highspire, PA 17034 Re: Allstate Insurance Company v. Behrens and Cutler Cumberland C.C.P. No.: 2010-04642 Our file: 01-10-109 Dear Mr. Cutler: Please be advised that I represent Allstate Insurance Company concerning property damage to their insured vehicle that occurred on March 25, 2009. I enclose herewith a copy of the Affidavit of Repairman, together with the appraisal indicating that the cost to repair the insured's property totals $2,532.62. I intend on filing a Praecipe for Assessment of Damages under Pennsylvania Rules of Civil Procedure No. 1037 and have the Prothonotary assess damages in that amount on January 7, 2011, unless prior to that date, by written Praecipe, you file with the Prothonotary a request for trial on the issue of damages. Very truly yours, Stewart C. Xrawfoquire SCC/ras Enclosures File #01-10-109 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ALLSTATE INSURANCE COMPANY IN CIVIL ACTION V. HEATHER BEHRENS & MAURICE NO.: 2010-04642 CUTLER AFFIDAVIT OF VALUE OF REPAIRMAN Under PRCP # 1037 (b) (2) (ii) THE REPAIRMAN'S AFFIDAVIT Stewart C. Crawford, duly being sworn according to law, deposes and says that he/she is a representative for Allstate Insurance Company and has for many years, reviewed appraisals and estimates and damage documents on property and that the repairs itemized on the attached estimate were necessary to restore the property of the owner to the condition which existed immediately preceding the damage and that the prices set forth on the estimate for parts and labor were fair and reasonable and customarily charged at the time the attached repair estimate was prepared; or that the property was a total loss and the attached sheets correctly state the value of the property at the time of loss, less any salvage value. That the attached repair estimate was prepared by a qualified and licensed estimator or field claim representative. Subscribed and sworn to before me this _ day of ?(]2 ?__ ,2010. otary P 1"ic, State o- P sylvania My commission is permanent / expires: (14 W Search Financial Log > Financial Log Found: 2 Displaying: 1 - 2 Currency for Show Totals: USD??$how Total ............... «« Total Issued By / Type Date Payee Status Amount Payment DARREN G. BIRD NANCY R. SPECK and FA... Transaction: Posted 1,771.56 3127/2009 Check: Printed Recon: Cleared Financial Category Participant I Coverage Transaction Reason PAC Amount Loss Payment NANCY R. SPECK/Collision Regular Collision 1,771.56 Payment SYSTEMATIC PAYMENTS ENTERPRISE RENT-A-CAR Transaction: Posted 280.00 Check: N/A Recon: Cleared Financial Category Participant / Coverage Transaction Reason PAC Amount Loss Payment NANCY R. SPECK/Rental Reimburse... Rental Reimbursement 280.00 Modify Search ALLSTATE INSURANCE COMPANY HARRISBURG MCO 6345 FLANK DRIVE HARRISBURG, PA 17112 (717) 540-7500 SUPPLEMENT HOTLINE: (800) 726-8890 EXT.7580 *** ESTIMATE *** 03/27/200910:04 AM Owner Owner: NANCY SPECK Address: 172 E HIGH ST Work/Day: Home/Evening: (717)243-0275 City State Zip: CARLISLE, PA 17013 FAX: Email: NANCYSPECK@AOL.COM Control information Claim # : 000133639229D01 Loss Datelrime: 03/25/2009 Deductible: $500.00 Ins. Company: Allstate Insurance Company Insured: NANCY SPECK Address: 172 E HIGH ST City State Zip: CARLISLE, PA 17013 Email: NANCYSPECK@AOL.COM Insured Policy # : 000028923256 Loss Type: Collision Work/Day: Home/Evening: (717)243-0275 FAX: Inspection Inspection Date: Inspection Location: City State Zip: Primary Impact: 03/27/2009 172 a high st Carlisle, PA 17013 Left Rear Side Inspection Type: Field Contact: FAX: Secondary Impact: Left Side Assigned Date/Time: Appraiser Name Address City State Zip Email DARREN G BIRD 6345 FLANK DRIVE HARRISBURG, PA 17112 oddmf@allstate.com Received Date/Time: 03/27/2009 10:01 AM Appraiser License # : 150766 Work/Day: (717)805-5990 FAX: (717)540-7515 Repairer Address: 2 ROADWAY DR (717)254-0041 City State Zip: Carlisle, PA 17015 Target Complete Date/Time: Days To Repair: 5 Remarks ALL SUPPLEMENTS MUST CALL 540-7580 LIC# 150766 VISIBLE DAMAGE ONLY Vehicle 2000 Plymouth Voyager Grand SE 4 DR Passenger Van 6cyl Gasoline 3.3 4 Speed Automatic Lic.Plate: DRS-3298 Lic State: PA Lic Expire: VIN: 2P4GP44G7YR649011 Prod Date: Mileage: 105,748 03/27200911:11 AM Page 1 of 6 2000 Plymouth Voyager Grand SE 4 DR Passenger Van Claim # : 000133639229D01 03/27/200910:04 AM Veh Insp# : Condition: Good Ext. Color: green Ext. Refinish: Two-Stage Options Mileage Type: Actual Code: O6624B Int. Color: Int. Refinish: 7 Passenger Seating AM/FM Stereo Tape Air Conditioning Anti-lock Brakes Cruise Control Dual Airbags Heated Power Mirrors Intermittent Wipers Power Brakes Power Door Locks Power Steering Power Windows Rear Window Defroster Rear Window Wiper/Washer Roof/Luggage Rack Sliding Driver Side Door Sunscreen Glass Tachometer Tilt Steering Wheel Velour/Cloth Seats r Damages _ Line Op Guide MC Description MFR.Part No. Price ADJ% B% Hours R 1 EU 911 46 Wheel,Rear LT RECYCLED PART $50.00* +25.00 0.3 SM >> New Cumberland Auto Parts USA-PA(New-Cumberland) E-mail 1-717-774-1190 2 E 1853 Valve Stem LT 2073355 $3.15 -5.00 SM 3 PC 927 Cover,Rear Wheel LT Replace PXN Reconditioned $62.00 SM 4 E 258 01 MIdg,Front Door Side LT PJ87SJ3 $102.00 -5.00 0.3 SM 5 1 227 Door Shell,Rear LT Repair 1.0* SM 6 L 227 # Door Shell,Rear LT Refinish 3.2* RF 2.0 Surface 0.6 Two-stage setup 0.6 Two-stage # = 10, 13 7 E 268 01 Mldg,Rear Door Lower LT PJ89SJ3 $102.00 -5.00 0.4 SM 8 RI 307 Pnl,lnner Door Trim LT R & I Assembly 0.4 SM 9 1 295 Glass,Rear Door T LT Repair 0.3* SM » backtape 10 RI 321 Handle,RR Door Outer LT R & I Assembly 0.2 SM 11 1 389 Panel,Bodyside Outer LT Repair 7.0* SM 12 L 389 10 Panel,Bodyside Outer LT Refinish 3.5* RF 3.0 Surface 0.5 Two-stage 13 BR 394 Door,Fuel Filler LT Blend Refinish 0.1 RF 0.1 Blend 14 RI 394 Door,Fuel Filler LT R & I Assembly 0.3 SM 15 E 404 01 MIdg,Body Side Lower L/F PJ93SJ3 $53.45 -5.00 0.5 SM 16 RI 460 Panel,Bodyside Trim LT R & I Assembly 0.8 SM 17 RI 431 Glass, Bodyside Rear T LT R & I Assembly 0.8 SM 18 RI 392 Track,Sliding Door LT R & I Assembly 2.3 SM 19 RI 346 Cover,Sliding Dr Guide LT R & I Assembly 0.2 SM 20 EU 533 Taillamp Assembly LT RECYCLED PART $35.00* +25.00 0.2 SM » New Cumberland Auto Parts USA-PA(New-Cumberland) E-mail 1-717-774-1190 » qt# 36495 21 EP 553 Cover,Rear Bumper COMPETITIVE PART $297.75 1.2 SM 22 EC M14 Corrosion Protection COMPETITIVE PART $10.00* RF 23 L M15 Color Tint Refinish 0.5* RF 24 EC M17 Cover Car Exterior COMPETITIVE PART $5.00* SM 25 EC M25 Tire-Left Rear,Balance COMPETITIVE PART $119.95- 0.3* SM 26 EC M60 Hazardous Waste Removal COMPETITIVE PART $3.00* SM 27 SB 4 WHEEL ALIGNMENT Sublet Repair $59.95* SM 27 Items MC Message 01 CALL DEALER FOR EXACT PART # / PRICE 10 INCLUDES AUDATEX TIME TO CLEAR ENTIRE PANEL 13 INCLUDES 0.6 HOURS FIRST PANEL TWO-STAGE ALLOWANCE 46 PRINTABLE ALTERNATE PARTS COMPARE Estimate Total & Entries 031271200911:11 AM Page 2 of 6 2000 Plymouth Voyager Grand SE 4 DR Passenger Van Claim # : 000133639229D01 03/27/200910:04 AM Gross Parts $260.60 Other Parts $582.70 Paint Materials $160.60 Line Item Discount $13.03- Line Item Markup $21.25 Parts & Material Total $1,012.12 Tax On Parts Only @ 6.000% $51.09 Labor Rate Replace Hrs Repair Hrs Total Hrs Sheet Metal (SM) $43.00 8.2 8.3 16.5 $709.50 Mech/Elec (ME) $43.00 Frame (FR) $43.00 Refinish (RF) $43.00 7.3 7.3 $313.90 Paint Materials $22.00 Labor Total 23.8 Hours $1,023.40 Tax on Labor @ 6.000% $61.40 Sublet Repairs $59.95 Tax on Sublet @ 6.000% $3.60 Towing $60.00 Gross Total $2,271.56 Less: Deductible $500.00- Net Total $1,771.56 Customer Owes $500.00 Alternate Parts Y/03/02/00/01/00 CUM 03/02/00/01/00 Zip Code: 17112 NE HBG S 1ST 03/07 Audatex Estimating 5.0.421 ES 03127/200911:11 AM REL 5.0.421 DT 02/01/2009 Copyright (C) 2008 Audatex North America, Inc. 1.7 HRS WERE ADDED TO THIS ESTIMATE BASED ON AUDATEX'S TWO-STAGE REFINISH FORMULA. IMPORTANT INFORMATION ABOUT ALLSTATE'S CHOICE OF PARTS POLICY THIS ESTIMATE MAY LIST PARTS FOR USE IN THE REPAIR OF YOUR VEHICLE THAT ARE MANUFACTURED BY A COMPANY OTHER THAN THE ORIGINAL MANUFACTURER OF YOUR VEHICLE. THESE PARTS ARE COMMONLY REFERRED TO AS AFTERMARKET PARTS OR COMPETITIVE PARTS, AND MAY INCLUDE COSMETIC OUTER BODY CRASH PARTS SUCH AS HOODS, FENDERS, BUMPER COVERS, ETC. ALLSTATE GUARANTEES THE FIT AND CORROSION RESISTANCE OF ANY AFTERMARKET/COMPETITIVE OUTER BODY CRASH PARTS THAT ARE LISTED ON THIS ESTIMATE AND ACTUALLY USED IN THE REPAIR OF YOUR VEHICLE FOR AS LONG AS YOU OWN IT. IF A PROBLEM DEVELOPS WITH THE FIT OR CORROSION RESISTANCE OF THESE PARTS, THEY WILL BE REPAIRED OR REPLACED AT ALLSTATE'S EXPENSE. THIS GUARANTEE IS LIMITED TO THE REPAIR OR REPLACEMENT OF THE PART. HOWEVER, IF YOU CHOOSE NOT TO USE ONE OR MORE OF THE AFTERMARKET/COMPETITIVE OUTER BODY CRASH PARTS THAT MAY BE LISTED ON THIS ESTIMATE IN THE REPAIR OF YOUR VEHICLE, ALLSTATE WILL SPECIFY THE USE OF ORIGINAL EQUIPMENT MANUFACTURER PARTS, EITHER NEW OR RECYCLED AT ALLSTATE'S OPTION, AT NO ADDITIONAL COST TO YOU. ALLSTATE DOES NOT SEPARATELY GUARANTEE THE PERFORMANCE OF ORIGINAL EQUIPMENT MANUFACTURER PARTS, AND MAKES NO REPRESENTATION ABOUT THE AVAILABILITY OF ANY MANUFACTURER'S GUARANTEE. 03/271200911:11 AM Page 3 of 6 2000 Plymouth Voyager Grand SE 4 DR Passenger Van Claim # : 000133639229D01 03/27/200910:04 AM Op Codes . = User-Entered Value EC = COMPETITIVE PART ET = Partial Replace Labor TE = Partial Replace Price L = Refinish TT = Two-Tone BR = Blend Refinish CG= Chipguard AA = Appearance Allowance E =Replace OEM OE = Replace PXN OE Srpis EP = COMPETITIVE PART PM = Replace PXN Reman/Reblt PC = Replace PXN Reconditioned SB = Sublet Repair I = Repair RI = R & I Assembly RP = Related Prior Damage NG = Replace NAGS UE = Replace OE Surplus EU = RECYCLED PART UM= Replace Reman/Rebuilt UC = Replace Reconditioned N = Additional Labor IT = Partial Repair P =Check This report contains proprietary information of Audatex and may not be disclosed to any third party (other than T Aur?? the insured, claimant and others on a need to know basis in order to effectuate the claims process) without 11``11 Audatex's prior written consent. a Sote,.v coorpjny Copyright (C) 2008 Audatex North America, Inc. Audatex Estimating is a trademark of Audatex North America, Inc. 03/27/200911:11 AM Page 4 of 6 • 2000 Plymouth Voyager Grand SE 4 DR Passenger Van Claim # : 000133639229D01 03/27/2009 10:04 AM Estimate Summary Page DARREN G BIRD Gross Total $2,271.56 Less: Deductible $500.00- Net Total $1,771.56 Customer Owes $500.00 Audatex Estimating 5.0.421 ES 03/27/200911:11 AM REL 5.0.421 DT 02/01/2009 Copyright (C) 2008 Audatex North America, Inc. TO ALL REPAIR FACILITIES: BEFORE USING AN AFTERMARKET SHEETMETAL PART, BE SURE TO LOOK FOR THE CAPA SEAL. THIS IS NOT AN AUTHORIZATION FOR REPAIR. SUPPLEMENTS MUST BE APPROVED PRIOR TO REPAIR. IF YOUR CAR IS OF UNITIZED CONSTRUCTION, IN SOME CASES THE REPAIR SHOP MAY NEED SPECIAL EQUIPMENT TO PROPERLY REPAIR THE CAR. YOU SHOULD DETERMINE IF THE SHOP YOU SELECT TO COMPLETE THE REPAIRS IS PROPERLY EQUIPPED. ALLSTATE WILL NOT BE RESPONSIBLE FOR ANY RELATED TOWING SERVICES OR STORAGE CHARGES, KNOWN AT THE TIME.OF APPRAISAL, AFTER AFTER WHICH THE CHARGES WILL BE THE RESPONSIBILITY OF THE CONSUMER. THIS ESTIMATE HAS BEEN PREPARED BASED ON THE USE OF AFTERMARKET CRASH PARTS. IF THE USE OF AN AFTERMARKET CRASH PART VOIDS THE EXISTING WARRANTY ON THE PART BEING REPLACED OR ANY OTHER PART, THE AFTERMARKET CRASH PART SHALL HAVE A WARRANTY EQUAL TO OR BETTER THAN THE REMAINDER OF THE EXISTING WARRANTY. WARRANTIES APPLICABLE TO AFTERMARKET CRASH PARTS ARE PROVIDED BY THE MANUFACTURER OR THE DISTRIBUTOR OF THESE PARTS NOT THE ORIGINAL MANUFACTURER OF YOUR VEHICLE. ANY PERSON WHO KNOWLINGLY AND WITH INTENT TO INJURE OR DEFRAUD ANY INSURER FILES AN APPLICATION OR CLAIM CONTAINING FALSE, INCOMPLETE OR MISLEADING INFORMATION SHALL, UPON CONVICTION, BE SUBJECT TO IMPRISONMENT FOR UP TO SEVEN YEARS AND PAYMENT OF A FINE UP TO $15,000 IT IS TO OUR MUTUAL INTEREST THAT YOU RECEIVE PROMPT AND COURTEOUS SERVICE ALONG WITH QUALITY REPAIR WORK AT A FAIR PRICE. IF YOU HAVE A PREFERENCE FORA PARTICULAR SHOP, YOUR ADJUSTER WILL WRITE OR APPROVE AN ESTIMATE OF REPAIRS WITH THAT SHOP BASED ON COMPETITIVE PRICES IN THE AREA. INFORMATION REGARDING REPAIR FACILITIES, WHICH MAY BE ABLE TO REPAIR THE VEHICLE FOR THE APPRAISED AMOUNT, IS AVAILABLE FROM YOUR ADJUSTER OR INSURER. HOWEVER, THERE IS NO REQUIREMENT TO USE ANY SPECIFIED SHOP. COSTS ABOVE THE APPRAISED AMOUNT MAY BE THE RESPONSIBILITY OF THE VEHICLE OWNER. ALL SUPPLEMENTS MUST BE APPROVED PRIOR TO REPAIR. AFTERMARKET CRASH PARTS ARE IDENTIFIED IN THIS ESTIMATE WITH THE SYMBOL "EC", 'EP" (COMPETITIVE PART) AND "EU" (RECYCLED PART) AN "AFTERMARKET CRASH PART" IS A NON-ORIGINAL MANUFACTURER (NON-OEM) REPLACEMENT PART, EITHER NEW OR USED, FOR ANY OF THE NON-MECHANICAL PARTS THAT GENERALLY CONSTITUTE THE EXTERIOR OF THE MOTOR VEHICLE, INCLUDING INNER AND OUTER PANELS. NEW, ORIGINAL EQUIPMENT MANUFACTURER, REPLACEMENT PARTS ARE IDENTIFIED BY THE LETTER "E" AND CAN BE LOCATED AT THE ORIGINAL EQUIPMENT MANUFACTURER PARTS 3/ZIIZU 8 11:11 AM Page 5 of 6 2000 Plymouth Voyager Grand SE 4 DR Passenger Van Claim # : 000133639229D01 03/27/2009 10:04 AM DEALER. ADJUSTER LICENSE # DATE 03/27/200911:11 AM Page 6 of 8 ®ALLSTATE INSURANCE ---a- - -- - Rental ENTERPRISE RENT-A- Company: CAR Invoice: D725330-5710 Bill To: ALLSTATE INSURANCE ATTN: PAULA SHARP 6345 FLANK DR STE 1000 HARRISBURG, PA 17112 RENTER INFORMATION: Renter: SPECK, NANCY RENTAL INFORMATION: Rental Branch Location: ENTERPRISE RENT-A-CAR (5710) 800 NORTH HANOVER ST CARLISLE, PA 170131538 (717) 258-4495 ADDITIONAL CLAIM INFORMATION: Claim Number :0133639229 Claim Type: Insured Vehicle Condition: Driveable Date Of Loss: 3/25109 Insured Name: NANCY SPECK Owner's Vehicle: 2000 PLYMGRND V Additional Driver: Repair Facility: PENDING SHOP MECHANICSBURG, PA 17055 (717) 795-0900 VEHICLES RENTED: Billing Detail: Rental Period: 3/26/09 to 4/8/09 (14 days) Billed Period: 3/26/09 to 4/8/09 (14 days) Description Rate: Amount: 14 DAYS @ $24.00 $336.00 14 PTA TAX $2.00 $28.00 1 VRT %2.00 $6.72 1 SALES TAX %6.00 $20.16 TOTAL CHARGES: $390.88 Less Amount Received: $110.88 AMOUNT DUE.......... $280.00 Effective Date and Year Make Model VIN Starting Ending Mileage Rate Time, Mileage Mileage Charged 3/26/09 2008 SUZU FORE 0 0 0 $24.00 Rental Invoice Please Return This Portion with Remittance Make Payment To: ENTERPRISE RENT-A-CAR COMPANY P.O. BOX 840086 KANSAS CITY, MO 64184 Federal ID: 43-0724835 Total Charges: $390.88 Less Amount Received: $110.88 Total Amount Due .................... $280.00 Please include on your check: Invoice: D725330-5710 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ?,??+'?" ?iubrrf??? !C:,, OFFICE OF TKE S``ERIFF Allstate Insurance Company vs. Case Number Maurice Cutler (et al.) 2010-4642 SHERIFF'S RETURN OF SERVICE 11/04/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Maurice Cutler, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint and Notice according to law. 11/09/2010 08:55 AM - Dauphin County Return. And now November 9, 2010 at 0855 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Maurice Cutler by making known unto Valdez Fisher, Brother of defendant at 555 Willow Street, Apartment E, Highspire, PA 17034 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 November 16, 2010 SO ANSWERS, , j?" RON R ANDERSON, SHERIFF (C) CountySulte Shent Teleosofl, Inc. William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin ALLSTATE INSURANCE COMPANY VS MAURICE CUTLER Sheriff s Return No. 2010-T-3394 OTHER COUNTY NO. 20104642 And now: NOVEMBER 9, 2010 at 8:55:00 AM served the within NOTICE & COMPLAINT upon MAURICE CUTLER by personally handing to VALDEZ FISHER 1 true attested copy of the original NOTICE & COMPLAINT and making known to him/her the contents thereof at 555 WILLOW STREET, APT E HIGHSPIRE PA 17034 BROTHER Sworn and subscribed to before me this l OTH day of November, 2010 _)P? Z COMMONWEALTH OF PENNSYLVANIA - - NOTARIAL- SEAL- - Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County M Commission Expires Au st 17, 2014 So Answers,( Sheriff of Dauphin County, Pa. By Deputy heriff Deputy: S SCHAEFFER - Sheriff s Costs: $47.25 11/8/2010 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith :r°4" ?tuarrbrffi>r Chief Deputy Richard W Stewart . Solicitor CFFICE OF TKE SHERIFF Allstate Insurance Company I vs. Maurice Cutler (et al.) Case Number 2010-4642 SHERIFF'S RETURN OF SERVICE 07/19/2010 08:30 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on July 19, 2010 at 2030 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Heather M. Behrens, by making known unto Elen Paulus, Mother of defendant at 2137 Newville Road, Carlisle, Cumberland County, Pennsylvania 17013 =CONKLIN, e time handing to her personally the said true and correct copy of the sam07/20/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Maurice Cutler, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Maurice Cutler. Elen Paulus current resident of 2137 Newville Road, Carlisle, PA 17013 advised Deputies, Maurice Cutler has never resided at this address, and he is thought to be residing at 605 Willow Street, Highspire, PA 17034. SHERIFF COST: $54.40 July 20, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySuite ShenH, Teleosofl. Inc. Robert W. Claypole, Esquire Attorney ID 47956 120 Ivy Mills Road Glen Mills, PA 19342 610-358-2732 Attorney for Plaintiff ALLSTATE INSURANCE COMPANY VS. HEATHER BEHRENS et. al. Jr Tr`OFFI pF�p,7oCUr 217111 AUG Phi 2: CUMBERLAND C©Uf,TY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Case No. 2010-04642 ENTRY OF APPEARANCE AS COUNSEL OF RECORD FOR PLAINTIFF Please enter my appearance as counsel of record for plaintiff, Allstate Insurance Company in the above matter. Date: July 28, 2014 I R(Iert W. Claypole squire WITHDRAW AS COUNSEL OF RECORD FOR PLAINTIFF Please withdraw my appearance as counsel of record for plaintiff, Allstate Insurance Company in the above matter. Date: May 13, 2014 Stewart C. Crawford, Jr., squ e Robert W. Claypole, Esquire Attorney ID 47956 120 Ivy Mills Road Glen Mills, PA 19342 610-358-2732 Attorney for Plaintiff Pic& 201 HONO PM 2:46 CUITBERL AND COU,§1IY PENNS YLVAN A ALLSTATE INSURANCE COMPANY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. HEATHER BEHRENS et. al. Case No. 2010-04642 AFFIDAVIT OF MOTOR VEHICLE ACCIDENT I, Robert W. Claypole, Esquire am the attorney for the plaintiff and this lawsuit involves a claim for damages arising out of a motor vehicle accident on March 25, 2009. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa.C.A. Section 4904, relating to unsworn falsification to authorities. Date: July 28, 2014 .16 Agd Ref•ert W. Cla