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Home My WebLink About10-5271PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFIELD, JR., ESQUIRE ATTORNEY I.D. #81894 906 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 ERIE INSURANCE GROUP AS SUBROGEE OF JASON URSO AND KRISTEN URSO P.O. BOX 2013 MECHANICSBURG, PA 17055 VS. DONNA M. DICKENS WATSON AKA DONNA JACOX AND JEFFREY JACOX INDIVIDUAL AND AS NATURAL GUARDIANS OF TAKAYLA JACOX 312 WALNUT STREET, APT. D LEMOYNE, PA 17043 AND TAKAYLA JACOX 312 WALNUT STREET, APT. D LEMOYNE, PA 17043 NOTICE IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 Lawyer Referral Service 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 THIS IS AN ARBITRATION MATTER ATTORNEY FOR PLAINTIFF COMMON PLEAS COURT OF CUMBERLAND COUNTY NO. 10 - 5&'71 0,1v it T+ew / ` 1 rs? is _J r CIVIL ACTION s. "ISO Le han demandado a usted on la carte. Si usted quiere defendarse de estes demendas expueates en las peginos siguient, usted tiene (20) dies de plazo a partir de la feeha de la demands y Is rwVcwjon. Usted debe preaerdar una apanencia eserda o en ppeerrseoonnaa o por abogado y archiver on la oorte sus defenses o sus Zeci" alas dsmandes encontre de su persona. Sea evisedo qua si uVed Zed" detrende, la carts tomes medidas y puede entrer uns order cordm usted sin previo aviso o notification o por cuMgier queo o ablo quo espedido an le petition do demands. Usted puede perder drnero, sus propiedadss o otros derechos importentes pare usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE PARA PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION BE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE USTED PUEDE CONSEGUIR ASISTENCIA LEGAL. Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 Lawyer Referral Service 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 O +ga.00 Pri ATE`/ e,-l IA-7 85 oacl (Wa 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. PAUL F. D-EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFIELD, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 ERIE INSURANCE GROUP AS SUBROGEE OF JASON URSO AND KRISTEN URSO P.O. BOX 2013 MECHANICSBURG, PA 17055 THIS IS AN ARBITRATION MATTER ATTORNEY FOR PLAINTIFF COMMON PLEAS COURT OF CUMBERLAND COUNTY VS. DONNA M. DICKENS WATSON AKA DONNA JACOX AND JEFFREY JACOX INDIVIDUAL AND AS NATURAL GUARDIANS OF TAKAYLA JACOX 312 WALNUT STREET, APT. D LEMOYNE, PA 17043 NO. AND TAKAYLA JACOX 312 WALNUT STREET, APT. D CIVIL ACTION LEMOYNE, PA 17043 NOTICE UNDER THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1601 (AS AMENDED) THE PENNSYLVANIA UNFAIR TRADE PRACTICES ACT AND CONSUMER PROTECTION LAW, 73 PA.CON.STAT.ANN. §201, ET. SEQ. ("THE ACTS") IN AS MUCH AS THE ACTS MAY APPLY, PLEASE BE ADVISED THAT THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. COMPLAINT The Plaintiff, Erie Insurance Group, by its attorney Paul F. D'Emilio, Esquire, bring this action upon a cause whereof the following is a statement: The Plaintiff, Erie Insurance Group ("Plaintiff'), is a Corporation authorized to do business in the Commonwealth of Pennsylvania, having an mailing address of P.O. Box 2013, Mechanicsburg, PA 17055. Plaintiff brings this action as subrogee of Jason Urso and Kristen Urso, herein the ("Insured") under a policy of insurance issued by Plaintiff. 2. Defendants, Donna M. Dickens Watson aka Donna Jacox and Jeffrey Jacox, are individuals residing at 312 Walnut Street, Apt. D, Lemoyne, PA 17403. 3. Defendant, Takayla Jacox, is an individual residing at 312 Walnut Street, Apt. D, Lemoyne, PA 17403. 4. Upon information and belief, Defendants Donna M. Dickens Watson aka Donna Jacox and Jeffrey Jacox are the parents of the Defendant Takayla Jacox. 5. At all times hereinafter mentioned the Defendant Takayla Jacox was the agent, workman, servant and employee of Defendants Donna M. Dickens Watson aka Donna Jacox and Jeffrey Jacox and was engaged in the business of Defendants Donna M. Dickens Watson aka Donna Jacox and Jeffrey Jacox and was acting within the course and scope of her employment. 6. On or about May 21, 2009, a motor vehicle owned by the Defendants Donna M. Dickens Watson aka Donna Jacox and Jeffrey Jacox and operated by the Defendant Takayla Jacox was traveling on Walnut Street, Lemoyne, Pennsylvania, she struck Plaintiff's Insured's vehicle which was legally parked causing the damages herein after mentioned. 7. Plaintiff avers that the personal property of the Insured was damaged as a result of the occurrence hereinbefore mentioned, the reasonable costs of repairs thereto being is One Thousand Five Hundred Three and 12/100 ($1,503.12) Dollars plus the Insured's deductible of Two Hundred Fifty and 00/100 ($250.00) Dollars for a total of One Thousand Seven Hundred Fifty Three and 12/100 ($1,753.12) Dollars. A true and correct copy of the estimate is attached hereto, made part hereof and marked Exhibit "A." Count I Erie Insurance Group v. Takayla Jacox 8. Plaintiff, Erie Insurance Group, incorporates by reference all of the allegations contained in paragraphs 1 through 7 inclusive of this Complaint as fully as though same were herein and set forth at length. 9. The said occurrence was due solely to the negligence of the Defendant, Takayla Jacox, in that she: a. did fail to have the motor vehicle under proper and adequate control; b. did operate the motor vehicle at an excessive rate of speed; C. did fail to apply the brakes in time to avoid the collision; d. did negligently apply the brakes; e. did fail to operate the vehicle in accordance with existing conditions; f. did fail to drive at a speed and in the manner that would allow her to stop within the assured clear distance ahead; g. did fail to keep a reasonable lookout for other vehicles lawfully on the road; h. did operate the motor vehicle without due regard for the rights, safety and position of the Insured at the point of aforesaid; L did operate the vehicle without Insurance; j. did fail to maintain financial responsibility; and k. did violate the various statutes and laws of the Commonwealth of Pennsylvania and County of Philadelphia pertaining to the operation of motor vehicles. Count II Erie Insurance Group v. Donna M. Dickens Watson aka Donna Jacox and Jeffrey Jacox 10. Plaintiff, Erie Insurance Group, incorporates by reference all of the allegations contained in paragraphs 1 through 9 inclusive of this Complaint as fully as though same were herein and set forth at length. 11. The said occurrence was due to the negligence of the Defendant, Donna M. Dickens Watson aka Donna Jacox and Jeffrey Jacox, in that they: a. negligently entrusted their vehicle to another operator for use when they knew, or with a reasonable exercise of due care should have known, that the operator was not capable of operating the motor vehicle properly; b. negligently entrusted their motor vehicle to a person which they knew, or in the exercise of reasonable care should have known, was an incompetent driver; C. negligently entrusted their motor vehicle to a person known, should have known or in the exercise of reasonable care would have known, was going to drive the vehicle in an improper, dangerous or reckless manner; d. negligently entrusted their motor vehicle to another person who they knew, should have known or in the exercise of due care would have known would cause damages to another; and e. failed to properly supervise the driver of their vehicle who was driving with a learners permit at the time; and f. negligently entrusted their motor vehicle to a person who did not maintain financial responsibility as required by the laws of the Commonwealth of Pennsylvania. Count III Erie Insurance Group v. Donna M. Dickens Watson aka Donna Jacox and Jeffrey Jacox Liability for Tortious Acts of Children 23 Pa.C.S.A. § 5501 et. seq. 12. Plaintiff, Erie Insurance Group, incorporates by reference all of the allegations contained in paragraphs 1 through 11 inclusive of this Complaint as fully as though same were herein and set forth at length. 13. The parents of Defendant are liable to the Plaintiff for the tortious acts of their child under 23 Pa.C.S.A. § 5504. 14. As the damages paid by Plaintiff to its insured exceed the monetary limits of liability, Plaintiff demands the maximum limit of monetary damages on Count II of Two Thousand Five Hundred ($2,500.00) under 23 Pa.C.S.A. § 5505. WHEREFORE, Plaintiff demands judgment against the Defendants upon each count in an amount not in excess of Fifty Thousand and 00/100 ($50,000.00) dollars together with costs of suit. Date: Paul F. D'Emilio, Esquire Identification No.: 16654 e-mail address: pauld@demiliolaw.com Paul M. Schofield, Jr., Esquire Identification No.: 81894 e-mail address: pauls@demiliolaw.com 905 W. Sproul Road, Suite 105 Springfield, PA 19064 Telephone No.: 610-338-0338 Fax No.: 610-338-0303 VERIFICATION 6"4"" ' eO?AJIO?S, Subrogation Representative with Erie Insurance Group in the above captioned matter verifies that the facts contained in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. DATE: rogation Represents e Exhibit "A" 0 • Req: ROWLES 05/28/2009 AT 09:18 AM JOB NUMBER: L B SMITH FORD INC. FEDERAL ID #:251601197 THE HOUSE THAT SERVICE BUILT 12TH & MARKET ST P.O. BOX #138 LEMOYNE, PA 17043-0606 (717)761-6700X3216 FAX: (717)761-6829 ESTIMATE OF RECORD WRITTEN BY: MIKE NAGURNEY #135817 05/28/2009 09:11 AM ADJUSTER: LUCKENBAUGH, MARY S (717)795-8200 INSURED: OWNER: ADDRESS: CELLULAR: EVENING: INSPECT LOCATION: KRISTEN URSO & KRISTEN URSO & JASON URSO 313 WALNUT ST LEMOYNE, PA 17043-0000 (724)263-0660 (717)695-2106 INSURANCE ERIE INSURANCE GROUP COMPANY: 4901 LOUISE DR. MECHANICSBURG, PA 17055-0606 2001 DAEW LEGANZA CDX VIN: KLAVA69271B291295 AIR CONDITIONING CRUISE CONTROL KEYLESS ENTRY CONSOLE/STORAGE FOG LAMPS POWER BRAKES POWER DRIVER SEAT HEATED MIRRORS STEREO CD PLAYER PASSENGER AIR BAG BUCKET SEATS ALUMINUM/ALLOY WHEELS NO. OP. CLAIM #010171036359001 POLICY #Q060120113 DEDUCTIBLE: $250.00 ,C DATE OF LOSS: 05/21/2009 AT 05:00 PM TYPE OF LOSS: COLLISION POINT OF IMPACT: 9. LEFT T-BONE (LE BUSINESS: (717)795-8200 6 DAYS TO REPAIR 4-2.2L-FI 4D SED SILVER INT:GRAY LIC: EKC6747 PA PROD DATE: DEFOGGER INTERMITTENT WIPERS THEFT DETERRENT/ALARM ELECTRIC GLASS SUNROOF CLEAR COAT PAINT POWER WINDOWS POWER ANTENNA AM RADIO CASSETTE ANTI-LOCK BRAKES (4) 4 WHEEL DISC BRAKES AUTOMATIC TRANSMISSION DESCRIPTION 07/2000 ODOMETER: TILT WHEEL CLIMATE CONTROL DUAL MIRRORS TRACTION CONTROL POWER STEERING POWER LOCKS POWER MIRRORS FM RADIO SEARCH/SEEK DRIVER AIR BAG LEATHER SEATS OVERDRIVE 65275 QTY EXT. PRICE LABOR PAINT ------------------------------------------------------------------------ 1 FRONT BUMPER 2 R&I R&I FRONT BUMPER 1.0 3 FRONT LAMPS 4 R&I LT HEADLAMP ASSY 0.3 5 FENDER 6* RPR LT FENDER 3.5* 2.0 1 L _ 05/28/2009 AT 09:18 AM • Req: ROWLES ,C JOB NUMBER: ESTIMATE OF RECORD 2001 DAEW LEGANZA CDX 4-2.2L-FI 4D SED SILVER INT:GRAY NO. --- OP. ----- ------------------------------- DESCRIPTION --------------------------- --------------- QTY EXT. PRICE -------- LABOR --------- PAINT 8* R&I ---- LT NAMEPLATE "CDX" --- SAVE --------------- * -------- 0.2* --------- (CAN'T GET) 9# REPL CLEAN RETAPE EMBLEM & DR MLDGS 1 10.00 0.6 10 R&I LT MUD GUARD 0.3 11 FRONT DOOR 12* RPR LT OUTER PANEL 5.0* 2.2 13 OVERLAP MAJOR ADJ. PANEL -0.4 14 ADD FOR CLEAR COAT 0.4 15 R&I LT APPLIQUE 0.2 16* R&I LT SIDE MOLDING 0.2* 17* REFN LT SIDE MOLDING 0.3* 18 R&I LT MIRROR ASSY POWER 0.3 19 R&I LT HANDLE, OUTSIDE 0.3 20 BLND LT HANDLE, OUTSIDE 0.2 21 R&I LT R&I TRIM PANEL 0.4 22 R&I LT BELT W'STRIP 0.3 23 REAR DOOR 24* RPR LT OUTER PANEL 1.0* 2.0 25 OVERLAP MAJOR ADJ. PANEL -0.4 26 ADD FOR CLEAR COAT 0.3 27 R&I LT BELT W'STRIP 0.2 28 R&I LT APPLIQUE 0.3 29* R&I LT SIDE MOLDING 0.3* 30* REFN LT SIDE MOLDING 0.3* 31 R&I LT HANDLE, OUTSIDE 0.3 32 REFN LT HANDLE, OUTSIDE 0 4 33 OVERLAP MINOR PANEL . -0.2 34 ADD FOR CLEAR COAT 0 1 35 R&I LT R&I TRIM PANEL 0.4 . 36 QUARTER PANEL 37* RPR LT QUARTER PANEL 1.5* 2 2 38 OVERLAP MAJOR ADJ. PANEL . -0.4 39 ADD FOR CLEAR COAT 0 4 40 ELECTRICAL . 41 R&I ANTENNA, POWER M 0.6 M 42 REAR LAMPS 43 R&I LT COMBO LAMP ASSY 0.5 44 REAR BUMPER 45 R&I R&I REAR BUMPER 1.0 46# REPL MASK JAMBS, PER PANEL 2 T 0 4 47# REPL RESTORE CORROSION 1 5.00 T . 0.1 PROTTECTION/RUST PROOF PER PANEL 48# REPL COVER CAR/BAG & MASK 1 5.00 T 0.2 49# HAZARDOUS WASTE REMOVAL FEE -------------------------- 1 3.50 T --- SUBTOTALS ==> ---------------- 23.50 -------- 19.4 ------- 10.2 05/28/2009 AT 09:18 AM 11 • Req: ROWLES ,C ESTIMATE OF RECORD JOB NUMBER: 2001 DAEW LEGANZA CDX 4-2.2L-FI 4D SED SILVER INT:GRAY PARTS BODY LABOR 18.8 HRS ®$ 46.00/HR 10.00 864 80 PAINT LABOR MECHANICAL LABOR 10.2 HRS @$ 46.00/HR . 469.20 PAINT SUPPLIES 0.6 HRS 10.2 HRS @$ ®$ 52.00/HR 26 00/HR 31.20 2 SUBLET/MISC . . 65.20 - 13.50 SUBTOTAL SALES TAX ---- $ 1653.90 ------- $ @ 6.0000% 1653.90 99.23 GRAND TOTAL ----- ---- --------$ '1 753.13 ADJUSTMENTS: DEDUCTIBLE -- 250.00 CUSTOMER PAY INSURANCE PAY $ 250.00 $ 1503.13 3 05/28/2009 AT 09:18 AM Req: ROWLES ,C JOB NUMBER: ESTIMATE OF RECORD 2001 DAEW LEGANZA CDX 4-2.2L-FI 4D SED SILVER INT:GRAY ANY PERSON WHO KNOWINGLY AND WITH INTENT TO DEFRAUD ANY INSURANCE COMPANY OR OTHER PERSON FILES AN APPLICATION FOR INSURANCE OR STATEMENT OF CLAIM CONTAINING ANY MATERIALLY FALSE INFORMATION OR CONCEALS FOR THE PURPOSE OF MISLEADING, INFORMATION CONCERNING ANY FACT MATERIAL THERETO COMMITS A FRAUDULENT INSURANCE ACT, WHICH IS A CRIME AND SUBJECTS THE PERSON TO CRIMINAL AND CIVIL PENALTIES. THE FOLLOWING IS A LIST OF ABBREVIATIONS OR SYMBOLS THAT MAY BE USED TO DESCRIBE WORK TO BE DONE OR PARTS TO BE REPAIRED OR REPLACED:D=DISCONTINUED PART A=APPROXIMATE PRICE 13=BODY LABOR D=DIAGNOSTIC E=ELECTRICAL F=FRAME G=GLASS M=MECHANICAL P=PAINT LABOR S=STRUCTURAL T=TAXED MISCELLANEOUS X=NON TAXED MISCELLANEOUS ADJ=ADJACENT ALGN=ALIGN A/M=AFTERMARKET BLND=BLEND CAPA=CERTIFIED AUTOMOTIVE PARTS ASSOCIATION D&R=DISCONNECT AND RECONNECT EST=ESTIMATE EXT. PRICE=UNIT PRICE MULTIPLIED BY THE QUANTITY INCL=INCLUDED MISC=MISCELLANEOUS NON-ADJ=NON ADJACENT O/H=OVERHAUL OP=OPERATION NO=LINE NUMBER QTY=QUANTITY QUAL RECY=QUALITY RECYCLED PART QUAL REPL=QUALITY REPLACEMENT PART COMP REPL PARTS=COMPETITIVE REPLACEMENT PARTS RECORD=RECONDITION REFN=REFINISH REPL=REPLACE R&I=REMOVE AND INSTALL R&R=REMOVE AND REPLACE RPR=REPAIR RT=RIGHT SECT=SECTION SUBL=SUBLET LT=LEFT W/O=WITHOUT W/ =WITH/_ #=MANUAL LINE ENTRY *=OTHER [IE..MOTORS DATABASE INFORMATION WAS CHANGED]. **=DATABASE LINE WITH AFTERMARKET N=NOTES ATTACHED TO LINE NAGS=NATIONAL AUTO GLASS SPECIFICATIONS. MQVP=MANUFACTURER'S QUALITY AND VALIDATION PROGRAM.OPT OEM=ORIGINAL EQUIPMENT MANUFACTURER PARTS EITHER OPTIONALLY SOURCED OR OTHERWISE PROVIDED WITH SOME UNIQUE PRICING OR DISCOUNT. NWCPP=NATIONWIDE CRASH PARTS PROGRAM. THE ATTACHED ESTIMATE REPRESENTS AN APPRAISAL OF THE COST OF REPAIR FOR THE VISIBLE DAMAGE TO THE VEHICLE NOTED AT THE TIME OF INSPECTION NECESSARY TO RETURN THE VEHICLE TO ITS PREDAMAGED CONDITION. COSTS ABOVE THE APPRAISED AMOUNT MAY BE THE RESPONSIBILITY OF THE VEHICLE OWNER. THERE IS NO REQUIREMENT THAT THE VEHICLE OWNER USE ANY SPECIFIED REPAIR SHOP. INFORMATION REGARDING REPAIR FACILITIES WHICH WILL BE ABLE TO REPAIR THE VEHICLE FOR THE APPRAISED AMOUNT IS AVAILABLE FROM THE INSURANCE COMPANY. IF USED PARTS ARE SPECIFIED, THEY ARE REQUIRED TO BE OF LIKE KIND AND QUALITY TO THOSE BEING REPLACED. INCIDENTAL CHARGES SUCH AS TOWING, PROTECTIVE CARE, CUSTODY, STORAGE, DEPRECIATION, BATTERY AND TIRE REPLACEMENT ARE NOTED WHEN APPLICABLE. 0 05/28/2009 AT 09:18 AM • Req: ROWLES ,C JOB NUMBER: ESTIMATE OF RECORD 2001 DAEW LEGANZA CDX 4-2.2L-Fl 4D SED SILVER INT:GRAY ESTIMATE BASED ON MOTOR CRASH ESTIMATING GUIDE. UNLESS OTHERWISE NOTED ALL ITEMS ARE DERIVED FROM THE GUIDE ARC2601, CCC DATA DATE 04/01/2009, AND THE PARTS SELECTED ARE OEM-PARTS MANUFACTURED BY THE VEHICLES ORIGINAL EQUIPMENT MANUFACTURER. OEM PARTS ARE AVAILABLE AT OE/VEHICLE DEALERSHIPS. OPT OEM (OPTIONAL OEM) OR ALT OEM (ALTERNATIVE OEM) PARTS ARE OEM PARTS THAT MAY BE PROVIDED BY OR THROUGH ALTERNATE SOURCES OTHER THAN THE OEM VEHICLE DEALERSHIPS. OPT OEM OR ALT OEM PARTS MAY REFLECT SOME SPECIFIC, SPECIAL, OR UNIQUE PRICING OR DISCOUNT. OPT OEM OR ALT OEM PARTS MAY INCLUDE "BLEMISHED" PARTS PROVIDED BY OEM'S THROUGH OEM VEHICLE DEALERSHIPS. ASTERISK (*) OR DOUBLE ASTERISK (**) INDICATES THAT THE PARTS AND/OR LABOR INFORMATION PROVIDED BY MOTOR MAY HAVE BEEN MODIFIED OR MAY HAVE COME FROM AN ALTERNATE DATA SOURCE. TILDE SIGN C) ITEMS INDICATE MOTOR NOT-INCLUDED LABOR OPERATIONS. NON-ORIGINAL EQUIPMENT MANUFACTURER AFTERMARKET PARTS ARE DESCRIBED AS AM, QUAL REPL PARTS OR COMP REPL PARTS WHICH STANDS FOR COMPETITIVE REPLACEMENT PARTS. USED PARTS ARE DESCRIBED AS LKQ, QUAL RECY PARTS, RCY, OR USED. RECONDITIONED PARTS ARE DESCRIBED AS RECOND. RECORED PARTS ARE DESCRIBED AS RECORE. NAGS PART NUMBERS AND BENCHMARK PRICES ARE PROVIDED BY NATIONAL AUTO GLASS SPECIFICATIONS. LABOR OPERATION TIMES LISTED ON THE LINE WITH THE NAGS INFORMATION ARE MOTOR SUGGESTED LABOR OPERATION TIMES. NAGS LABOR OPERATION TIMES ARE NOT INCLUDED. POUND SIGN M ITEMS INDICATE MANUAL ENTRIES. SOME 2009 VEHICLES CONTAIN MINOR CHANGES FROM THE PREVIOUS YEAR. FOR THOSE VEHICLES, PRIOR TO RECEIVING UPDATED DATA FROM THE VEHICLE MANUFACTURER, LABOR AND PARTS DATA FROM THE PREVIOUS YEAR MAY BE USED. THE PATHWAYS ESTIMATOR HAS A COMPLETE LIST OF APPLICABLE VEHICLES. PARTS NUMBERS AND PRICES SHOULD BE CONFIRMED WITH THE LOCAL DEALERSHIP. CCC PATHWAYS - A PRODUCT OF CCC INFORMATION SERVICES INC. 5 0 0 05/28/2009 AT 09:18 AM Req: ROWLES ,C JOB NUMBER: ESTIMATE OF RECORD 2001 DAEW LEGANZA CDX 4-2.2L-FI 4D SED SILVER INT:GRAY ALTERNATE PARTS USAGE AFTERMARKET PARTS AFTERMARKET SELECTION METHOD: AUTOMATICALLY LIST NO. OF TIMES USER WAS NOTIFIED THAT AN AFTERMARKET PART WAS AVAILABLE: 0 NO. OF AFTERMARKET PARTS THAT APPEAR IN THE FINAL ESTIMATE: 0 OPTIONAL OEM PARTS OPTIONAL OEM SELECTION METHOD: AUTOMATICALLY LIST NO. OF TIMES USER WAS NOTIFIED THAT AN OPTIONAL OEM PART WAS AVAILABLE: 0 NO. OF OPTIONAL OEM PARTS THAT APPEAR IN THE FINAL ESTIMATE: 0 RECONDITIONED PARTS RECONDITIONED SELECTION METHOD: AUTOMATICALLY LIST NO. OF TIMES USER WAS NOTIFIED THAT A RECONDITIONED PART WAS AVAILABLE: 0 NO. OF RECONDITIONED PARTS THAT APPEAR IN THE FINAL ESTIMATE: 0 RECYCLED PARTS NO. OF TIMES USER WAS NOTIFIED THAT A RECYCLED PART WAS AVAILABLE: 4 NO. OF RECYCLED PARTS THAT APPEAR IN THE FINAL ESTIMATE: 0 6 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~4~,,~tr p{ 4~unbrl~l~~~ J~ ~{,f cr~~~E ,~,~; ~ ~~~ e,»~~~~F ~~~.EQ'QEE~~E ~ THE f'RT~iO~:'OTr'~RY Jody S Smith Chief Deputy Richard W Stewart Solicitor Erie Insurance Exchange vs. Donna M. Dickens Watson (et al.) f~EN~dSYt..~1~-~~~1~ Case Number 2010-5271 SHERIFF'S RETURN OF SERVICE 08/26/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Donna M. Dickens Watson, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Donna M. Dickens Watson. Request for service at 312 Walnut Street, Apartment D, Lemoyne, PA 17043 the defendant was not found. The Lemoyne Postmaster has advised Donna M. Dickens Watson has moved and left no forwarding address. 08/26/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Jeffrey Jacox, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Jeffrey Jacox. Request for service at.312 Walnut Street, Apartment D, Lemoyne, PA 17043 the defendant was not found. The Lemoyne Postmaster has advised Jeffrey Jacox has moved and left no forwarding address. 09/10/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on September 10, 2010 at 1505 hours, he was unable to serve a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Takayla Jacox. After several attempts the Complaint and Notice has expired. SHERIFF COST: $113.20 October 12, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (c) GountySulte Sheriff. T'eleosoft, Inc. PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFIELD, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 ERIE INSURANCE GROUP AS SUBROGEE OF JASON URSO AND KRISTEN URSO P.O. BOX 2013 MECHANICSBURG, PA 17055 VS. DONNA M. DICKENS WATSON AKA DONNA JACOX AND JEFFREY JACOX INDIVIDUAL AND AS NATURAL GUARDIANS OF TAKAYLA JACOX 312 WALNUT STREET, APT. D LEMOYNE, PA 17043 AND THIS IS AN ARBITRATION MATTER ATTORNEY FOR PLAINTIFF COMMON PLEAS COURT OF CUMBERLAND COUNTY _.. ?M NO. 10-5271 r a > TAKAYLA JACOX . 312 WALNUT STREET, APT. D CIVIL ACTION LEMOYNE, PA 17043 PRAECIPE TO REINSTATE THE COMPLAINT TO THE PROTHONOTARY, C.P.: Kindly reinstate the Complaint in the above-captioned matter. (a I e'e " - PAUL F. 'E ILIO, ESQUIRE ATTORNEY FOR PLAINTIFF PO ATM e a7oo-7 to PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFIELD, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 ERIE INSURANCE GROUP AS SUBROGEE OF JASON URSO AND KRISTEN URSO P.O. BOX 2013 MECHANICSBURG, PA 17055 VS. DONNA M. DICKENS WATSON AKA DONNA JACOX AND JEFFREY JACOX INDIVIDUAL AND AS NATURAL GUARDIANS OF TAKAYLA JACOX 312 WALNUT STREET, APT. D LEMOYNE, PA 17043 AND TAKAYLA JACOX 312 WALNUT STREET, APT. D LEMOYNE, PA 17043 THIS IS AN ARBITRATION MATTER ATTORNEY FOR PLAINTIFF COMMON PLEAS COURT' OF CUMBERLAND COUN r°?? elr_ zN r- p' NO. 10-5271 CIVIL ACTION PRAECiPE TO DISCONTINUE AND END TO THE PROTHONOTARY, P.C.: Kindly mark the above entitled matter discontinued and payment of your cost only. V f?e.yy i V for Plaintiff