HomeMy WebLinkAbout04-3375 IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
ENTERPRISE RENT A CAR COMPANY
OF PITTSBURGH, INC.,
Plaintiff,
VS.
CIVIL ACTION - LAW
DAVID THOMAS UMPHRED,
Defendant.
NOTICE OF APPEAL FROM
DISTRICT JUSTICE JUDGMENT
Filed on Behalf of Plaintiff:
ENTERPRISE RENT A CAR COMPANY
OF PITTSBURGH, INC.
COUNSEL OF RECORD FOR THIS
PARTY:
Charles J. Vollmer
PA I.D. No. 22049
VOLLMER RULONG & KEATING, P.C.
Suite 1212
Grant Building
Pittsburgh, PA 1521 §
(412) 391-2121
Firm I.D. No. 916
COMMONWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS
Judicial District, County Of
CUMBERLAND COUNTY
NOTICE OF APPEAL
FROM 7//~m V
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No. ~ ~f~ ,~ 7.5' ~
NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on
the date and in the case referenced below.
N^ME Or ^P~EL~T I M^~. O~ST. "O
_Enterprise Rent A Car Co. of Pgh., Inc.I 09-1-01
ADORE$S OF APP£LLANT
c/o Vollmer Rulong
OAT~ OF JUDGMENT
6-29-04
I NAME Of D.J
Charles A. Clement, Jr.
CiTY STATE ZIP COOE
KeatingLP.C., Suite 1212 Grant Bldg. 330 Grant St. Ph., PA 15219
IN THE CASE OF (Plainti~) (Oefe~danl)'
Enterprise Rent A Car Company v. ~avid Thomas Umphred
SIGNATURE~.3~ ~ ~E~L~-- ~ j~Of APPE T OR ATTORNEY OR AGENT
This b,ock will be signed ONLY when this notation is required under Pa. Ifapp~ell~r~S~.P.D.J.
R.C.P.D.J. No. J008B.
This Notice of Appeal, when received by the District Justice. will operate as a
SUPERSEDEAS to the judgment for possession in this case.
No. 1001(6) in action
before a ~istdct Justice, A COMPLAINT MUST BE FILED within twenty
(20) days after filing the NOTICE of APPEAL.
PRAECIPE TO ENTER RULE TO FiLE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before District Justice. IF
NOT USED, detach from copy of notice of appeal to be served upon appellee.
PRAEClPE: To Prothonotary
Enter rule upon
(Common Pleas No.
appellee(s), to file a complaint in this appeal
Name of appellee(s)
) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
Signature of appel/ant or attorney or agent
RULE: To . appellee(s)
Name of appeileel$)
(1) Y~uaren~tifledthataruieisherebyenteredup~ny~ut~~~eac~mp~aintlnthisappeaiwithintwenty~2~)daysafterthedate~fservice
of this rule upon you by personal service or by certified or registered mail
(2) ff you do not fife a complaint within this time, a JUDGMENT OF NON PROS MAY ~E ENTERED AGAINST YOU,
(3) The date of service of this rule if service was by mai~ is the date of the mailing.
Date: ,20
Signature of Prothonotaq/ or Deputy
YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL.
AOPC 312-02
COURT FILE TO BE FILED WITH PROTHONOTARY
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MU$7 £~E: FILED WITHIN TEN (?0) DAYS AFTEJ~ flirt9 of lire nohce of a~pea Check a~piicabte be×es)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ;
AFFIDAVIT: [ hereby (swear) (affirm) that I served
a copy of the Notice of Appeal, Common Pleas No. , upon the District Just ce designated therein on
dale of sexy~ce) 20 [i~-~ by persona! se~vic,
sender's receipt attached hereto arid ~pon the appeftee ( ~ame} o
20 ~ by personal service [~] by (ce~ified) (registered~ mail,
se¢~der's receipt ~ttached hereto
(SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME
THIS DAY OF ,20
My commission expires on 20
AOPC 312A - 02
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: O~E~
09ol-01
CHARLES A. CLEMENT,
~,s 400 BRIDGE STP. EET
OLDE TOWNE COMMONS
NEW CUMBERLAND, PA
T,~o..~ (717) 774-5989
' SUITE 3
17070
ATTOP. NEY FOR PLAINTIFF :
VOLLMER RULONG & KEATING P C
GRANT BUILDING
SUITE 1212
PITTSBURGH, PA 15219
NOTICE OF JUDGMENT/TRANSCRIPT
CIVIL CASE
PLAINTIFF: NAME anO AD~RSS
~'ENTERPRISE KENT A CAR CO PITT INC 'q
GRANT BUILDING APT/STE 1212
VOLLMER RULONG KEATING PC
~ITTSBURGH, PA 15219
VS.
DEFENDANT: NAME anO ADDRESS
~UMPHRED, DAVID THOMAS
530 HUMMEL AVE APT/STE 2
LEMOYNE, PA 17043
Docket No.: CV- 0000158- 04
Date F [ed: 4/12/04
THis IS TO NOTIFY YOU THAT:
Judgment:
[] Judgment was entered for: (Name)
~'~ Judgment was entered against: (Name)
FOR DEF~-DANT
in the amount of $
. ~0 on:
(Date of Judgment)
~---~ This case prejudice.
dismissed
without
~--~ Amount of Judgment Subject to
Attachment/42 Pa.C.S. § 8127 $
~-~ Portion of Judgment for physical
damages arising out of residential
lease $
Defendants are jointly and severally liable.
Damages will be assessed on:
(Date & Time)
Amount of Judgment $ .0 0
Judgment Costs $ . O0
Interest on Judgment $ .0 0
Attorney Fees $ .00
Total $ .0 0
Post Judgment Credits
Post Judgment Costs
Certified Judgment Total
$
$
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY PILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEASI CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IF THE JUDGMENT HOLDER
ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT
OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED SY THE DISTRICT JUSTICE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS ANYONE INTERESTED N'[~'~ JUDGMENT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE DISTRICT JUSTICE IF THE JUDGMENT OES¥OR PA~s iN FULL, SETTLES,
OR OTHERWISE COMPLIES WITH THE JUDGMENT. ~
JUN 2 9 200/tOate . * ,D rictJustice
I certify that this is a true and correct copy of the record of the proceed ngs containing the judgment.
Date ~;: District Justice
My commission expires first Monday of January. 2008 .
AOPC 315-03 DATE PRINTED: 7/06/04 12:06:15
PM
SEAL
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA - CIVIL DIVISION
ENTERPRISE RENT A CAR COMPANY
OF Prl-rSBURGH, INC.
CIVIL ACTION - LAW
Plaintiff, No. 04-3375
VS.
COMPLAINT IN CIVIL ACTION
DAVID THOMAS UMPHRED,
Defendant.
CODE: 011
Filed on Behalf of Plaintiff:
ENTERPRISE RENT A CAR CO. OF
PITTSBURGH, INC.
COUNSEL OF RECORD FOR THIS
PARTY:
Charles J. Vollmer, Esquire
PA I.D. No. 22049
VOLLMER RULONG & KEATING, P.C.
Suite 1212, Grant Building
330 Grant Building
Pittsburgh, PA 15219
(412) 391-2121
(412) 391-3578 Fax
Firm I.D. INo. 916
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA -- CIVIL DIVlISION
ENTERPRISE RENT A CAR COMPANY
OF PITTSBURGH, INC.,
VS.
Plaintiff,
DAVID THOMAS UMPHRED,
Defendant.
Nc,, 04-3375
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claim set forth in
the following pages, you must take action within twenty (;!0) 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 withoL~t further notice for any money
claimed in the complaint or for any 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 LA~'ER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, THEN YOU SHOULD GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP:
Court Administrator
4th Floor, Cumberland County Cou~rthouse
Carlisle, PA 17013
(717) 240-6200
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA -- CIVIL DIVISION
ENTERPRISE RENT A CAR COMPANY
OF PITTSBURGH, INC.,
VS.
Plaintiff,
DAVID THOMAS UMPHRED,
Defendant.
)
)
)
)
)
)
)
)
)
)
CIVIL ACTION - LAW
Nc). 04-3375
COMPLAINT IN CIVIL ACTION
1. Plaintiff, ENTERPRISE RENT A CAR COMPANY OF PITTSBURGH, INC.
(hereinafter "Plaintiff"), is a corporation organized and operating under the laws of the
Commonwealth of Pennsylvania with offices located at 4489 Campbells Run Road,
Pittsburgh, Pennsylvania 15205.
2. Defendant, DAVID THOMAS UMPHRED (hereinafter" Defendant") is an
individual residing at: 530 Hummel Avenue #2, Lemoyne, PA 17043.
3. On or about July 6, 2000, the Defendant, while operating his vehicle
pulled out of a parking lot and collided with a vehicle owed by Plaintiff, Enterprise Rent
A Car Company of Pittsburgh, Inc..
4. Attached hereto, made a part hereof and marked as Exhibit "1" pages 1
through 2 are copies of the police accident report regarding the above described
accident.
5. Defendant owed Plaintiff a duty to operate his vehicle with reasonable
care and caution.
6. Defendant breached his duty of reasonablE: care while negligently
operating his vehicle on July 18, 2002 in the following respects:
a. in failing to keep the vehicle under proper control to prevent its
collision with another vehicle;
b. in failing to have his vehicle under adequate control.
c. in failing to have a valid license to operate a motor vehicle.
d. traveling at an unsafe speed
7. As a result of the aforesaid carelessness, recklessness and negligence of
Defendant, Plaintiff has sustained damages to its vehicle,.
8. Attached hereto, made a part hereof and marked as Exhibit "2" pages 1
through 3 are copies of the appraisal report and repair report regarding the Plaintiff's
2002 Chevrolet Express Van, VIN IGAHHG39RRR62212209718.
9. As a direct and proximate result of Defend-'~nt's above described
negligence, Plaintiff has sustained substantial damages in the amount of $2,167.34 as
set forth on Exhibit "2".
10. Plaintiff has demanded payment from Defendantl but he has failed or
refused to pay the same or any part thereof.
11. Plaintiff demands interest at the legal rate of 6% from a due date of
August 18, 2002.
WHEREFORE, the Plaintiff requests judgment in its favor, and against
Defendant, David Thomas Umphred in the amount of $2,167.34 with interest at six
percent (6%) from August 18, 2002 and costs.
VOLLMER RULONG &KEATING, P.C.
BY:
Pamela
~oyesky
FROM :SUPPORT SOLUTIONS INC
FRX N43. : 717~1~940
W~-~T ~HORE I~(~ZONAL
301 ~ ST~
L~E~ PA.
~HO~: (717) 737-8734
Date of Accident: --'
~oc.tion:3dO ~ ~. tO~H
Jul. 22 20~2 10:3~RM P2
Time of Accident: _/-,3'"
Municipality= ~lTi'hh ?~'~
sL A..?'r t ~ f-b r r '-'
. ~.o ~)u.~¢~ ¢,4 /
State:~P
Registration
PaSsengers:
~NIT
Address:
UNIT Name:
Address:
UNIT Name:
Address-
Phone N,,--her Operator
Phone number Operator
FROM :SUPPORT SOLUTIONS INC FAX NO. :71721BG940 Jul. 22 2~02 10:40AM PS
LOSS
88/07/2002 13:18 4122692555
STERLING AUTDBDDY
PAGE
AdJueter~
CompanF,
FM Radio
12 P&lee~ger Option Autom&~ic TranemiBmion Rally Wheels
NO, OP. DE$CRIPTZON QTY ~XT. PRICE LABOR PAINT
DB/07/2802 13:18 4i22692555 STERLING AUTOBODY PAGE
~/invoice.
1194.66
$ 1162.41 -6.0% -56.12
SUBTOTAL $ 2167,]%
QRAND TOTAL $ 2167.34
ADJUSTMENTS:
~8/07/20~2 13:10 ~1226~2555 STERLING AUTOBODY PAGE
FAX ~12-269-25S$
THIS ESTIMATE IS WANED ON OUR INITIAL INSPECTION AND UOgS NOT COVER ANY
ADDITIONAL ITEMS THAT MAT SE HEQUIRHD AFTEH REPAIRS HAVE REEN STARTED. PART
PHICRS ARE CURRENT AND ARE SUHJECT TO CNA~NOE WITH INVOICE.
WE CANNOT ACCEPT PERSONAL CHECKS OVE~, $S00.
ANY PERSON MHO KNOWINGLy AND WITH INTENT TO DEFRAUD ANY INSURANCE COMPANY OR
OTHER PERSOH FILES AN APPLICATION FOR INSURANCE OR STATEMENT OP CLAIM
CONTAIN~N~ &~y MATERIALLY FALSE IH~OHMATION OR CONCEALS FOR THE PURPOSE OF
MISbEAD~NG, INFORMATION CONCER~INO ANY FACT MATERIAL THERETO COMMITS A
FRAO~UbENT INSURANCE ACT, WHICH IS A CRIME AND SU~JECTE THE PERSON TO CRIMINAL
AND CIVI~ PKNALTIEE.
THE FOLLOWIN~ IS A LIST OF ARBREVIATIONS OR $~MSOLS THAT MAY HE USED TO
DESCRIH~ WORK TO RE DONE OR PARTS TO RE REPAIRED OR REPLACED: D=DI$CONTINUED
PART AaAPRROXIMATE P~ICE B=BODY LABOR D=DZAONOSTIC E~ELECTEZCAL ~ENAME ==~LASE
M~MEC~AN~CAL P~PAINT LABOR S=STRUCTURAL T=TAXED MISCELLANEOUS X~NON TAMED
MISCELLANEOUS ADJ=ADJACENT ALGN=ALI~N A/M~AFTERMAEEET BLND~H~END
CAPA=CERTfFIED AUTOMOTIVE PARTS ASSOCIATION N&R-DISCONIgECT AND NECONNECT
EST~ESTIMATE EXT. PRICE.UNIT PRICE MULTIPLIED ~y THE ~UANTITy INCh=INCLUDED
MISC~MISCELhAHEO~S NON-ADJ~NON ADJACENT O/N=OVERHAUL OP~=OPERATION NO=LINE
HUMB~R QTYaQOANTITY QUAL RECYz~UAL~TY RECYCLHD PART ~UAL REPL=QUALITy
REPLACEMENT PART RECONDmRNCONDIT~0N HEPN=REPiNISN R~PL=REPLACE N&=~RSMOVE AND
REPLACHD. INCIDENTAL CRARGS8 SUCH AS TOWING, PROTECTIVE CA~E, CUSTODY, STORAGE.
DEPRECIATION, SATTERY AND TI~E REPLACEMENT ARE NOTED WM~N APPLICABLE.
UNSWORN VERIFICATION
ENTERPRISE~T~'A CAR which is the Plaintiff, herein. I have reviewed the annexed
pleading and believe the facts contained therein are true and correct to the best of my
knowledge, information and belief, i believe that the corporation will be able to prove
these facts at trial.
THIS DECLARATION IS MADE BY ME WITH THE KNOWLEDGE THAT IT IS
SUBJECT TO THE PENALTIES OF 18 PA. C.S. §4904, RELATING TO UNSWORN
FALSIFICATION TO AUTHORITIES.
E NTE PJ~BI~'¢A
BY: ,~]~ ]~._.~v
TITLE:
,/.N.. THE COURT
OF-UMBERL,,.._ OF COMMas, .-. ~
"~o YL V~iA
ENTERPRISE ~T A ~ CO~p~
OF PI~SBU~GH, INC.
CIVIL ACTION_ tAW
VS.
DAVID THOMAS UMPh
Def.
No: 04-33 75
PROOF OF SERVI,~ .._
3OTtcE OF n'-- '"5
~o ~ ICE,iUDOMENT
Filed on Behaff of PI ·
~x~l-t, INC.
COUNSEL OF l?E .
PAI~Ty: CO/~D 1~0t~ THIS
Charles j. Vollmer
PA I.D. No. 22049
VOLL~E~ ~ULo~G ,~ ~FATI~G, p C
Suite 1212 . .
Gmat BUilding
Pittsburgh, DA 15219
(412) 391-2121
Firm I.D. No. 916
PROOF OF SERVICE OF NOTICE OF APPEAL ANO RULE:. TO FILE CO~APLAtN~
( Fhis proof ot ser¢ice MUS T BE FILED WlTHIN FEN ( l O) DA Y,~ AF ~ ~SR fifing of the nofice of apPeaL Chec. k ~pp icab/e boxes )
COMMONWEALTIfl OF PENNSYLVANIA
AFFIDAVIT: t heleby (swear) (affirm) thst l served
(date of service) ~ 2~-. ,20 ~/¥/, ['~ by personal sarvice {~(ceF¢~e(}(re9iste'e(}m~ii'
~ ~ ~ , 20 [~ by personal service ~ by (ceAified) (regi~te(ed) mail
(SWORN} ~IRMED) AN¢ ~tB¢iBED BEFOR~ ~E
My commissiop
AOPC 312A ~ 02
COMMONWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS
Judicial District, County Of
CUE~ EPJ~D COU~Y~
NOTICE OF APPEAL
FROM
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No. ~ y..~_~ 7S~ ~.~/ '~
NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on
the date and in the case referenced below.
F:.nterprise P, ent A Car Co. of Pgh,, Tnc. 09-1-01 Charles A. Clement, Jr.
ADDRESS OF APPELLANT
CITY
STATE ZiP CODE
c/o Vollmer RulonK A [eatinR~ P.C., Suite 1212 Grant Bldg., 330 Grant St. P~A. PA 15219
DATE OF JUOGMENT I IN THE CASE OF (Plaint~
(Defendant)'
6-29-04 Enterprise Rent A Car Company v. ~avtd Thomas Umphred
DOCKET NO
? ~ SIGNATURE OF ,~pp T OR ATTORNEY OR AGENT
R.C.P.D.J. No. 1008B. 's notation is required under Pa. If appelllt v~a$ ~P.D.~. ~o. 1001(6) in action
This Notice of Appeal, when received by the District Justice, will operate as a before a~District Justice,~COM~LA~VT M~IST BE FILED within twenty
SUPERSEDEAS to the judgment for possession in this case.
(20) days after filing the NOTICE ef APPEAL.
~ , j.,~ , PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of f~i'~n ~0 b~' U~e'd ONLY when aPPellant was DEFENDANT (see Pm.R.C.P.D.J. No. 1001(7) in ection before District Justice. IF
NOT USED, detach from copy of notice of appeal to be served upon appellee.~ -
PRAECIPE: To Prothonotary,~ [
Enter rule upon ~'---~ !\' !' ~ '!1
(Common Pleas No.
ii Name ofappellee($) ~'- ~; r, ~s appeal
_ ) w~th~n ~enty (20) days after se~f rule or ~er ent~ o[~m n p?s.
R~E: To , appellee(s)
(1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twen~ (20) days after the date of se~ice
of this rule upon you by personal se~i~ or by ce~ified or registered mail.
(2) If you do not file a ~mplaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU.
(3) The date of se~ice of this rule if se~ice was by mail is the date of the mailing.
Date: ,20
YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL.
AOPC 312-02
COURT FILE
C~AL US~
Celtl~ed Fee 2* 3 0
Postmark
(Endorsement Requimo) ] , --) ~' Here
[ ~ '.~-t.-;%;~ ......... ";'- __ ..........................................
m
[ ;t;'A~;~'~;,-' ................................. ~. ...........................
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
ENTERPRISE RENT A CAR COMPANY
OF PITTSBURGH, INC.,
VS.
Plaintiff,
DAVID THOMAS UMPHRED,
Defendant.
CIVIL ACTION - LAW
No. 04-3375
AFFIDAVIT OF SERVICE
Filed on Behalf of Plaintiff
ENTERPRISE RENT A CAR COMPANY
OF PITTSBURGH, INC.
COUNSEL ,OF RECORD FOR THIS
PARTY:
Charles J. Vollmer, Esquire
PA I.D. No. 22049
VOLLMER RULONG & KEATINO, P.C.
Suite 1212
Grant Building
Pittsburgh, PA 15219
(412) 391-2121
Firm I.D. No. 916
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA, CIVIL DIVISION
ENTERPRISE RENT A CAR COMPANY
OF PITTSBURGH, INC.,
VS.
Plaintiff,
DAVID THOMAS UMPHRED,
Defendant.
)
)
)
)
)
)
)
)
)
)
CIVIL ACTION - LAW
No. 04-3375
AFFIDAVIT OF SERVICE
1, the undersigned counsel, do hereby certify that a true and correct copy of Plaintiff's
Complaint in Civil Action was served on the Defendant, David Thomas Umphred, by regular first
class mailing and also by Certified Mailing, return receipt requested, return receipt no. 7002
3150 0000 8721 6037 on July 22, 2004 at the address listed below. Attached hereto, made a
part hereof, is a true and correct copy of the return receipts indicating that serivce of Plaintiff's
Complaint was accepted by David Thomas Umphred on July 27, 2004.
David Thomas Umphred
530 Hummel Avenue, Apt. 2
Lemoyne, PA 17043
1 UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE THE SUBJECT
OF THE PENALTIES OF PERJURY PURSUANT TO 18 PA. C.S. §4909, RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES.
Dated: July 30, 2004
VOLLMER RULONG & KEATING, P.C.
Charles J. ¥
1212 Gran~
Pittsburgh,,
Building
~A 15219
I hereby certify that Rule 237.1 has
been complied with and that notice
of intention to file Praecipe for
Default Judgment was mailed to
Defe .n'o'~fi~'-qn August 17, 2004
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA, CIVIL DIVISION
ENTERPRISE RENT A CAR
COMPANY OF PITTSBURGH INC.
CIVIL ACTION - LAW
Plaintiff, No: 04-3375
VS.
DAVID THOMAS UMPHRED
Defendant
PRAECIPE FOR DEFAULT
JUDGMENT
Filed on behalf of plaintiff
CERTIFICATE OF ADDRESS
ENTERPRISE RENT A CAR
COMPANY OF PITTSBURGH INC.
I hereby certify that the last
known address of the Plaintiff
and the Defendant are as follows:
Plaintiff:
4489 Campbells Run Road
Pittsburgh, PA 15205
COUNSEL OF RECORD FOR
THIS PARTY:
Pamela J. Wilson, Esquire
PA ID No. 77011
Defendant
530 Hummel Avenue Apt. 2
Lemoyne, PA 17043
A/ttorney for Plaintiff
VOLLMER RULONG & KEATING, P.C.
Suite 1212, Grant Building
330 Grant Street
Pittsburgh, PA 15219
(412) 391-2121
(412)391-3578 fax
Firm I.D. No. 916
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA CIVIL DIVISION
ENTERPRISE RENT A CAR COMPANY
OF PITTSBURGH INC.
VS.
Plaintiff,
DAVID THOMAS UMPHRED
Defendant
CIVIL DIVISION
No: 04-3375
PRAEClPE FOR DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Please enter judgment in favor of the plaintiff and against the defendant DAVID
THOMAS UMPHRED for failure of the defendant to file an Answer within the prescribed
period time.
Amount $2,167.34
6% Interest from 8/18/02
$ 794.14
TOTAL
$2,961.48 plus costs
VOLLMER RULONG & KEATING, P.C.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA, CIVIL DIVISION
ENTERPRISE RENT A CAR COMPANY
OF PITTSBURGH INC.
Plaintiff,
VS.
DAVID THOMAS UMPHRED
Defendant.
CIVIL ACTION - LAW
No. 04-3375
NOTICE OF PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT
TO: DAVID THOMAS UMPHRED
530 HUMMEL AVENUE APT, 2
LEMOYNE, PA 17043
DATE: AUGUST 17, 2004
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN DAYS FROM
THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT
ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET
LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(800) 990-9108
VOLLMER RULQNG & KEATING, P.C.
Suite 1 ng
330 Grant Street
Pittsburgh, PA 15219
(412) 391-2121
(412) 391-3578 fax