The URL can be used to link to this page

Home My WebLink About10-6999FIFILES\Clients\3050 Donegal\Current\630\3050.630.complaint 1 Revised. 10/6/10 11:5 8AM 3050.630 George B. Faller, Jr., Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs ti -FFJC? THE P?D Ori O?40 TAR y ""D COUN Tv JANET M. WILEY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. CIVIL ACTION - LAW JONATHAN W. WOLLET, and PAMELA S. WOLLET, Defendants JURY TRIAL DEMANDED NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiffs. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 9a-odlod.4 a 4a3/9?r ? 5- 07D 7 George B. Faller, Jr., Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs JANET M. WILEY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. CIVIL ACTION - LAW JONATHAN W. WOLLET, and PAMELA S. WOLLET, Defendants JURY TRIAL DEMANDED COMPLAINT 1. The Plaintiff, Janet M. Wiley, is an adult individual residing at 208 South Second Street, Dillsburg, Pennsylvania 17019. 2. The Defendant, Jonathan M. Wollet, is an adult individual residing at 126 South Locust Street, Apt. 3 Rear, Shiremanstown, Pennsylvania 17011. 3. The Defendant, Pamela S. Wollet, is an adult individual residing at 10 Mocking Bird Road, Wellsville, Pennsylvania 17365. 4. On or about April 3, 2010, Plaintiff was traveling northbound on State Route 74 approaching the intersection with State Route 177. 5. At that time, the Defendant Jonathan W. Wollet was operating a 2001 Pontiac Grand Am owned by Defendant Pamela S. Wollet. 6. Defendant Jonathan W. Wollet, was traveling south on State Route 74 and attempted to make a left turn directly into the path of the Plaintiff's vehicle. 7. Immediately after the collision, Defendant continued traveling south in his vehicle driving over a curb onto a grassy area, through a parking lot, before exiting his vehicle and fleeing. 8. As a direct and proximate result of the collision, Plaintiff's vehicle, which had a fair market value of $3,614.60 was a total loss. 9. Plaintiff has also incurred charges for towing and storage, but was able to sell the vehicle for salvage, resulting in a net loss of $81.00. 10. Plaintiff also incurred rental expenses in the amount of $632.39. Therefore, Plaintiffs total damages are $4,327.99. COUNTI Janet M. Wiley v. Jonathan M. Wollet 11. The averments of paragraphs 1 through 10 are hereby incorporated by reference. 12. The collision and Plaintiff's damages were caused solely as the result of negligence of Defendant Jonathan M. Wollet in that he: a. failed to yield the right-of-way to Plaintiff's vehicle; b. made a left-hand turn directly into the path of Plaintiff's vehicle; C. failed to properly operate his vehicle in an order to avoid striking the Plaintiff's vehicle; and d. operated his vehicle under the influence of alcohol in violation of the laws of Pennsylvania. WHEREFORE, Plaintiff demands judgment against the Defendant Jonathan M. Wollet in the amount of $4,327.99, plus interest and costs. COUNT II Janet M. Wiley v. Pamela S. Wollet 13. The averments of paragraphs 1 through 12 are hereby incorporated by reference. 14. At the time of the collision, Defendant Jonathan M. Wollet's driver's license was suspended or revoked. 15. At the time of the collision, Defendant Pamela S. Wollet allowed Jonathan M. Wollet to operate her 2001 Pontiac Grand Am, while his driver's license was suspended or revoked. 16. Defendant Pamela S. Wollet is vicariously liable under the laws of Pennsylvania, specifically 75 Pa. C.S.A. § 1574 for the negligence of Defendant Jonathan M. Wollet. 17. In the alternative, Defendant Pamela Wollet negligently entrusted her vehicle to Jonathan Wollet when she knew or should have known he was incapable of safe driving. WHEREFORE, Plaintiff demands judgment against the Defendant Pamela S. Wollet in the amount of $4,327.99, plus interest and costs. MARTSQXL AW By Georg6B. Faller, Jr., Esq I.D. Number 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Date: /C)/a 9//6 Attorneys for Plaintiff C RFCYCUD PAPER R CYCEABIE E? Claim: PAF-PA-01-10- Autosource Valuation 1997 Oldsmobile Achieve 0125438 AS Request: 26696049 'Audatex Grieco Appraisal Serv Donegal Insurance Group Marietta Branch 1195 River Road Marietta PA 17547 Wiley, Allen & Janet PAF-PA-01-10-0125438 04/03/2010 Collision PAF-3067762 VIN:.1 G3NL52T2VM300544 iiacorles ais' 1997 Oldsmobile Achieva SL 4D Sedan rAEfy Decodes Correctly F15ttt No activity was reported No Vehicles Advertised at (717) 502-6426 No Branded title history found for this VIN. Processed on 04/13/10 9:04 AM. Title History is powered by Experian AutoCheck. The Experian data contained in this report involves the conveyance of information provided to Experian by other sources. Accordingly, neither Experian nor Audatex can, or will, be an insurer or guarantor of the accuracy or reliability of the Experian data. The Autosource database contains inspected dealer inventories, dealer advertisements, phone verified vehicles, and private party advertisements from thousands of sources including automotive publications, newspapers and Web sites. Autosource uses vehicles comparable in year, make and model within the specified market area, expanding as necessary, to determine the loss vehicle's local market value. This valuation includes a representative sample of the vehicles used to calculate the typical starting price. The market search originated from Zip Code 17019, as determined by the vehicle owner's principally garaged area. Autosource located 32, 1997 Oldsmobile Achieva vehicles which were used to determine the typical vehicle price. Adjustments have been made to the comparable vehicles for value differences in edition, doors and body style as indicated in the "Veh Adj" field. The sum of the 32 comparable vehicles is $86,900 for an average price of $2,716. The asking or actual sale price is displayed for each vehicle. If a vehicle has been sold, the sold price Is displayed with an (S) indicator. The selling price may be substantially less than the asking price. In the case of this 1997 Oldsmobile Achieva, the difference between the asking price and selling price is generally 10%. This selling price adjustment has been applied to the typical price. Additional adjustments have been made to the typical vehicle price taking into consideration the loss vehicle's mileage, equipment and condition. All adjustments are vehicle specific and reflect driving habits and condition for the vehicle's market. A mileage adjustment of 1.50 cents per mile/kilometer has been applied. Taking into consideration the vehicle specifics, the fair market value is $3,594. Version: 1 Autosource Valuation Page: 1 04/13110 09:04 Exhibit "A" Claim: PAF-PA-01-10- Autosource Valuation 1997 Oldsmobile Achieve 0125438 AS Request: 26698049 See N.A.D.A See Valuation Autosource/ Value Section Detail Section N.A.D.A. Retail . . SaS.f'tTt $2,450 $2,444 $2,447 Tt'$rtl3iri?i?tlii 575 980 778 +Ant -50 -80 -65 u [Flt3 88 141 ..*.. ttta $2,975 $3,344 $3,160 Vatut#i E eif ce i M"Ak : $3,944 63,160 "Wow:. 'E!(lti 250 • $3,410 Geeral;sG9 T;ax -'-" $ -500.00 :..............'`::?:?. . . ::::;:>:._<;:<>:<:::>:.::.tea.:: h::•?, ......`.....: Y........ ..........I........ C = ck to ins 250.60 . a ! v- yr x Typical Vehicle Loss Vehicle AdjUstment ?!?rteli3: $2,444 $2,444 Description .:1997 1997 M Oldsmobile Oldsmobile M601: Achieva Achieva Edwow SL SL Dor3r 4D 4D ;Sedan Sedan - 060::2WD 2WD Engine 4 Cylinder 2.4 Engine 4 Cylinder 2.4 Engine p Tran8tniW64 4 Speed Automatic 4 Speed Automatic p Cipipr Not Applicable Green 4datr iar 116,154 MI(Typical) EqUIpment 49,798 MI(Actual) 980 C01wo . i : Air Conditioning Air Conditioning Tilt Steering Wheel Tilt Steering Wheel Cruise Control 25 Rear Window Defroster Rear Window Defroster Rem Trunk-UGate Release Rem Trunk-UGate Release Other Optlonal Equpme"'t Anti-lock Brakes Anti-lock Brakes Center Console Center Console Version: 1 Page: 2 04/13/10 09:04 Claim: PAF-PA-01-10- Autosource Valuation 1997 Oldsmobile Achieve AS Request: 26696049 0125438 Intermittent Wipers Intermittent Wipers Lighted Entry System Lighted Entry System Tachometer Tachometer Dual Airbags Dual Airbags Tinted Glass Tinted Glass Traction Control System Traction Control System flower Accessories: Power Brakes Power Brakes Power Mirrors Power Mirrors Power Windows Power Steering Power Steering Power Door Locks Power Door Locks Radio/i'hone/AEstrrt QMW AM/FM Stereo Tape AM/FM Stereo $pat;. 00.5ti Velour/Cloth Seats Velour/Cloth Seats Wh Aluminum/Alloy Wheels Aluminum/Alloy Wheels .:.:::..: :. ::..: .: ...... .. . I......:... • ....:..; :; :• `exin 5 Dui :a 50 Moderate Wear Minor Wear Gam: Minor Wear Minor Wear Ih(.-T- ttx Minor Damage Minor Damage Gfact Good Good Hdtdlitti Good Good • <` Minor Damage Minor Damage i'atni Moderate Damage Minor Wear xC"rl. Minor Damage Minor Damage aatgih Minor Wear Well Maintained tt?tlSttii Minor Wear Well Maintained FCC: Tjt Good Good ii As" Good Good -35 -20 3,344 45 70 90 45 594 ..... . Bti C E t361: , . ' 6.0001/6 215.64 .......... .... Tjt1e ?eej . neducttilei -500.00 500 iiietjttatllitaer The market area identified has multiple tax jurisdictions. Please see valuation notes for explanation. Version: 1 Page: 3 04/13110 09:04 t3'Sfa $2,450 Mechanical Er19 $0 Transmisstt r $0 Equipment wtout cm %0.0 Ato -25 w/out Pawl 11V ..... ys -25 tfupnte?itubl[otel , $ -50 Allif1119 ?1iirs311 .. _ $575 These current N.A.D.A. values are furnished under license from NADASC. All values Copyright ® NADASC 2010. The values in the N.A.D.A. guide assume a vehicle in clean condition. Appropriate deductions should be made to put a vehicle in salable condition. Special Note on Older Vehicles: N.A.D.A.'s editors believe that most optional equipment has little or no value on older vehicles. This is especially true of options that cost relatively little to begin with and which deteriorate with age or use. o Adjustments of Special Note is A mileage adjustment of 1.50 cents per mile/kilometer has been applied. This adjustment is based on the vehicle year, vehicle category and market area. Mileage adjustments are capped at 40% of the vehicle's starting value. Q No special adjustments were made for this vehicle. o Information provided by Donegal Insurance Group o Loss vehicle description was provided by Donegal Insurance Group d All values are in U.S. dollars. o Autosource Valuation Process n Over 3,400,000 vehicles are entered weekly Into the database used for researching this value. This database includes dealer inspected, dealer Inventory, dealer advertised, phone verified and advertised private party vehicles. d The originating search area for this valuation was Dillsburg, Pennsylvania. o Other Adjustments or Comments n The market area identified has multiple tax jurisdictions. Autosource was unable to identify which county or city was applicable to the total loss vehicle. However, special tax calculation rules apply to vehicle sales in this jurisdiction (such as limits, caps, exemptions, etc.) and Autosource was able to correctly establish the tax amount of $216 ------------ 1f a .. S es s o ?} a y? i..., ragsanllar?:a',1liatel::<`:: <. :::... . .:. . . ..... 4 Cylinder 2.4 Engine STD 4 Speed Automatic STD 6 Cylinder 3.1 Engine $457 Ot#i r Opt10 Eq ti. In ' Anti-lock Brakes STD ' Center Console STD ' Dual Airbags STD Fog Lights ' Intermittent Wipers STD Keyless Entry System PrR?pg?$?jtfq Power Drivers Seat ' Power Brakes STD ' Power Door Locks STD ' Power Mirrors STD ' Power Steering STD Power Windows $340 Version: 1 Page: 4 04/13/10 09:04 Claim: PAF-PA-01-10- Autosource Valuation 1997 Oldsmobile Achieva AS Request: 26696049 0125438 ' Lighted Entry System STD ..:.., » Q tic ::: :.:.:.:...:........ Leather Steering Wheel ' Air Condidonin9 STD Rear Spoiler $170 Cruise Control $225 ' Tachometer STD ' Rear Window Defroster STD ' Traction Control System STD ' Rem Trunk-L/Gate Release STD ' Tinted Glass . .. STD ' Tilt Steering Wheel STD . .. Rai ii0/P'h0111 i *:0 IQtl .:..... SMt flplt?Ot?•>:: : <..:? •;:• :;: •::;:. :? Compact Disc W/T ape $260 : , . .. .... . : Split Folding Rear Seat $150 AM/FM Stereo Tape $220 Velour/Cloth Seats STD ' A M/FM Stereo STD .......:.:.:::...:..:::.. Power Moonroof $595 ' Aluminum/Alloy Wheels STD Convenience Package $395 Includes Illuminated Keyless Remote Control Ent System & 6-Way Power Drivers Seat Adjuster. Sport Package $255 Includes Rear Aero Wing Spoiler, Fog Lights & Leather Wrapped Steering Wheel. ......: _ _ 88BD#a?ffplfk;t. $15,750 Editions available for the same body style (in order of original cost, increasing): "SL Indicates loss vehicle equipment. ---------- ------------------- e r e t Nat'l. Highway Traffic Safety Admin (US) has issued a total of 2 recall bulletins that may apply to this vehicle. NHTSA ID f - 97VO59 BOW: 04)01t97 C?t?dtltiE :Aft ti9d 3,464 Manu#ak t Ntl D.tB': December 1996-January 1997 vetilcte IJesoripdan Passenger vehicles. Description Of D416a The protective cover for the underhood fuse center was omitted. Without this cover, the positive terminal bolt on the fuse block is exposed and can contact the insulated negative battery cable. If the insulation on the negative cable becomes sufficiently wom, an electrical short circuit can occur between the positive terminal and negative cable resulting in extremely high current flow. Consequence Of Dot This high current flow can cause arcing and result in an underhood fire. Correotive Aaddf Dealers will Inspect these vehicle for the presence of the protective cover and, If necessary, Install a protective cover to the underhood fuse center. NHTSA ID Number 02V070 Ittfi3ti8t(l 03101/02 C3uantiE}F $ p OE 1,589,948 Oates Of Manu# May 1994 - July 1997 DOf:On certain passenger vehicles, If the engine fails to start and the driver holds the key in the "Start" position for an extended period, high current flows through the ignition switch and sometimes produces enough heat to melt Internal switch parts. If the switch is damages, a fire could occur in the steering column, even with the engine off and the key removed. Remedy; Dealers will install a relay kit in these vehicles to prevent current from flowing through the ignition switch. The manufacturer has reported that owner notification began March 27, 2002. Owners who do not receive the free remedy within a reasonable time should contact Chevrolet at 1-800- 222-1020, Pontiac at 1-800-762-2737, Buick at 1-800-521-7300, or Oldsmobile at 1-800-442- 6537. Version: 1 Page: 5 04/13110 09:04 .1 A m INSURANCE AU10 AUCTIONS Insurance Auto Auctions, Inc. Attn: Settlement Group 5515 Susquehanna Trail Manchester, PA 17345 Phone: (717) 266-8701 Fax: (717) 266-8705 E-mail: IAA-ASAP_Hardsburg@iaai.com Salvage Inform IAA Stock # ation 000-06725673 IAA Branch: Harrisburg Fed. Tax I.D. 954455113 Adjuster. Elizabeth Conn Insured: ALLEN 8 JANET WILEY Owner: ALLEN & JANET WILEY Claim #: PAFPA01100125438 Policy #: Vehicle: 1997 OLDSMOBILE ACHIEVA Damage: Front end VIN: 1 G3N L52T2VM300544 ACV: $3,410.00 NICB Date: 6/18/2010 DEFICIT INVOICE: 51114778958 INVOICE DATE: 06/18/2010 Payment Due Date : 702010 Invoice To: Donegal Mutual Insurance Company 1195 River Rd Box 302 Marietta, PA 17547-0302 Attn: Salvage Dept Less Outside Charges $550.00 16.13 IAA Charges Consignment Flat Fee $120.00 3.52 Tow $0.00 0.00 Advance Chg Service Fee $0.00 0.00 Re-Run Fee $0.00 000 VIC/FIS/Smard-oss (tm) $0,00 0,00 Storage Fee $0.00 0.00 IAA - Title Processing Fee $6.00 0.18 Bandage $0.00 0.00 Bundled Enhancement Fee $0.00 0.00 Less IAA Charges ($126.00) (3.70) Net IAA Return $424.00 12.43 Outside Charges Advanced by IAA Storage $210.00 6.16 Advance Tow $295.00 8.65 Buyer Information LKO 250 Auto, Inc. 152 SR 250 Harrisville, OH 43974 Resale Certificate # : 4 Elapsed Days Analysis 1033327 (PA) Date of Eyenta" Loss Date 4/3/2010 Days - Assigned 4/6/2010 4 Released 4/8/2010 3 Pickup 4/8/2010 1 Title Recd 61712010 61 Sale Doc. Recd 6/10/2010 4 Auction Date 6/16/2010 7 Buyer Payment 6/16/2010 1 Invoice 6/18/2010 3 Elapsed Total Days: 77 IM Ox. RP002trpt 1= ($505.00) (14.81) L Amount Due to IAA $81.00 (2.38)96 For proper credit, include invoice number : S1114778958 and stock number. 000-06725673 on your payment check. 06/2112010 02:37 PM E5C85 19412 F CTR, INC. P.O. BOX 327 DILLSBURG, PA 17019 Date408 Tow Ticket # : 52292 (717) 432 : 04/03110 Year :1997 Name : WILEY, JANET Make : OLDSMOBILE Address :208 SOUTH 2ND STREET Model : ACHEIVA City : DILLSBURG Style State : PA Color : GREEN ZIP :17019 V.I.N 1G3NL52TVM300544 Home Phone - - License : HBM 7517 Work Phone _ State : PA Cash Value .00 Odometer : 0 Sale/Auction # Reason : ACCIDENT Sale Date P.O. # Call # :5068 Membership # Member Exp. Dispatch # Driver : JOEL KRAMER Need Release? :N Truck # :109 Release Date :04/08/10 Type of Tow ; RB FLATBED Release # Requested By : PENNSYLVANIA STATE POLICE/ YORK Released To Location : RT 74 8 RT 177 Destination : • Time of Call :09:38 Time Dispatch :09:49 Arrival Time : 03:00 Hook Tine Drop Time Cleared Time : 09:48 Total Hours 6.80 Hourly Rate $000 Billed To: PENNSYLVANIA STATE POLICE/ YORK Towing $250.00 Clean up $0.00 Signature: Labor $0.00 Winching $0.00 Mileage Summary Misc $0.00 Beginning Ending Total Miles Rate $0.00 0 0 0 $ 0.00 Unloaded $0.00 0 0 0 $ 3.50 Loaded $0.00 Discount $0.00 Subtotal $250.00 Credit $0.00 Storage Summary $0.00 Date In Date Out Total Days Rate Admin $45.00 04/03110 04108/10 6.0 $35.00 Storage $210.00 Payout $0.00 Thank You For Your Businessi Tax Total $0.00 $505.00 We realize you have a choice among Amount Paid 4505.00 towers. We appreciate you choosing ' Pay Method: K13384 us to do the job for you. Balance Due $0.00 :t Invoice Notes: <IAAI Tow 7002336#17568720 TOWDOCU> Stockti6?26678 Shop Remipt 06/21/2010 02:37 PM E5C85 19412 ARMS® - Automated Rental Management System ® Donegal Insurance Page 1 of 1 Rental Company: ENTERPRISE RENT-A-CAR Invoice: D232476-5701 Bill To: DONEGAL INSURANCE ATTN: ELIZABETH CONN P. O. BOX 302, ROUTE 441 MARIETTA, PA 17547 RENTER INFORMATION: Renter: WILEY, JANET RENTAL INFORMATION: Rental Branch Location: ENTERPRISE RENT-A-CAR (5701) 6515 CARLISLE PIKE MECHANICSBURG, PA 170502376 (717) 795-8500 ADDITIONAL CLAIM INFORMATION: Claim Number: 125438 Claim Type: Insured Vehicle Condition: Unknown Date Of Loss: 4/3/10 Insured Name: JANET WILEY Owners Vehicle: OLDSMOBILE Additional Driver: Repair Facility: TOTAL LOSS MECHANICSBURG, PA 17055 (999) 999-9999 VEHICLES RENTED: Billing Detail: Rental Period: 4/9/10 to 5/3/10 (25 days) Billed Period: 4/9/10 to 4/24/10 (16 days) Description Rate: Amount: 7 DAYS @ $24.99 $174.93 18 DAYS C $20.24 $364.32 25 PTA TAX $2.00 $50.00 1 SALES TAX% %8.00 $43.14 TOTAL CHARGES: $632.39 Less Amount Received: $392.39 AMOUNT DUE.......... $240.00 Effective Date and Time Year Make Model VIN Starting Ending Mileage Mileage Mileage 419110 3:00 PM 2010 HYUN SONA 5NPET4ACXAH584814 29855 29955 100 4/16110 3:00 PM 2009 NISN VERS 3N1BC13E79L452348 18396 18500 104 4/30/10 2:44 PM 2009 NISN VERS 3N1 BC11 E59L427516 2895 28992 26097 Rental Invoice Please Return This Portion with Remittance Make Payment To: ENTERPRISE RENT-A-CAR (57A1) P.O. BOX 3108 BOSTON,, MA 02241 Federal ID:26-4526440 Total Charges: $632.39 Less Amount Received: $392.39 Total Amount Due .................... $240.00 Please include on your check: Invoice: D232476-5701 https://www.enterprise.com/annsweb/payinvoice 5/4/2010 VERIFICATION The foregoing Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. J et M. Wiley FAFR.ES\Cliental3050 Donegal\Curtem\630\3050.630.complaintl SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ?- FILED-OFFICE CF THE F ;QTHI'01 ,-') Sheriff Y Jody S Smith (? _$ P # Chief Deputy Richard W Stewart CUMBERLAND Coot -' P7..dIlII,SyIw "A Is",7fll1 Solicitor Janet M. Wiley vs. Jonathan W. Wollet (et al.) Case Number 2010-6999 SHERIFF'S RETURN OF SERVICE 11/08/2010 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: Pamela S. Wollet, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of York County, PA to serve the within Complaint and Notice according to law. 11/17/2010 York County Return: And now, November 17, 2010 I, Richard P. Keuerleber, Sheriff of York County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Pamela S. Wollet the defendant named in the within Complaint and Notice and that I am unable to find her in the County of York and therefore return same NOT FOUND. Request for service at 10 Mocking Bird Road, Wellsville, Pennsylvania 17365 the defendant was not found. Deputies were advised Pamela S. Wollet currently resides at 247 Washington Avenue SW, Brewster, Ohio 44613 or 1241 Wilbur Avenue, Akron, Ohio 44301. 11/19/2010 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: Jonathan W. Wollet, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Jonathan W. Wollet. Current resident of 126 S. Locust Street, Apartment 3 Rear, Shiremanstown, PA 17011 advised Deputies the defendant has moved June 2010 and is thought to be residing in New Cumberland, Pennsylvania. However, to date The Camp Hill Postmaster is unable to provide a good forwarding address for Jonathan W. Wollet. SHERIFF COST: $71.94 December 06, 2010 SO ANSWERS, RONl`4 R ANDERSON, SHERIFF SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuedeber Sheriff Reuben B Zeager Chief Deputy, Operations PETER J. MANGAN, ESQ. Solicitor Richard E Rice, II Chief Deputy, Administration WILEY vs. JONATHAN W. WOLLET (et al.) Case Number 10-6999 CIVIL SHERIFF'S RETURN OF SERVICE 11/17/2010 I, RICHARD P KEUERLEBER, SHERIFF, WHO BEING DULY SWORN ACCORDING TO LAW, STATES HE MADE DILIGENT SEARCH AND INQUIRY FOR THE WITHIN NAMED DEFENDANT TO WIT: PAMELA S. WOLLET, BUT WAS UNABLE TO LOCATE THE DEFENDANT IN HIS BAILIWICK. THE SHERIFF THEREFORE RETURNS THE WITHIN REQUESTED COMPLAINT IN CIVIL ACTION (CICA) AS "NOT FOUND" AT 10 MOCKING BIRD ROAD, WELLSVILLE, PA 17365. PER POST OFFICE CHECK, NEW ADDRESS IS 247 WASHINGTON AVE., SW, BREWSTER, OH 44613-1319 OR 1241 WILBUR AVE., AKRON, OH 44301-1839. SHERIFF COST: $33.44 SO A S, November 29, 2010 RICHARD U RLEBER, S RIFF --------------- - ----- ----- ------------------------------------------------------------------------- --- ---- ----------------- NOTARY Affirmed and subscribed to before me this 29th day of NOVEMBER 2010 (c) CountySude Sheriff, Teieosoft In %CTARIAL SEAL _!A -j}-CRP=,"NOTARY PUBLIC GI`Y CP YORK YORK COUNTY MY cot,i 'iSSION EXPIRES AUG. 12, 2013 F:\F1LES\Clients\3050 Donegal\Current\630\3050.630.pral Revised: 1/27/11 0:03PM C O Mti a Mr- George B. Faller, Jr., Esquire RTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER x -am ?° MA MARTSON LAW OFFICES r .0 ° I.D. 49813 X= aF) 10 East High Street :?= W Carlisle, PA 17013 --- - (717) 243-3341 Attorneys for Plaintiffs IN THE COURT OF COMMON PLEAS OF JANET M. WILEY, Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 10-6999 CIVIL ACTION - LAW JONATHAN W. WOLLET, and PAMELA S. WOLLET, Defendants JURY TRIAL DEMANDED PRAECIPE TO THE CUMBERLAND COUNTY PROTHONOTARY: Please reinstate the attached Complaint in reference to the above-captioned action and return to our office for service. Date: 1/27/11 MARTS LAW F S By Geo ge B. Faller, Jr., s I.D. Number 49813 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff fl6i,06 11"A ???-sy 37y F:\FILES\Clients\3050 Donegal\Current\630\3050.630.pra2 Revised 3/3/11 2:27PM Iz? ? .. 4 3 ? ,? f f. F f George B. Faller, Jr., Esquire I MARTSON DEARDORFF WILLIAMS OTTO GILROY & FAL P` MARTSON LAW OFFICES 'I I.D. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs JANtl M. WILLY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. JONATHAN W. WOLLET, and PAMELA S. WOLLET, Defendants NO. 10-6999 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO THE CUMBERLAND COUNTY PROTHONOTARY: Please reinstate the attached Complaint in reference to the above-captioned action and return to our office for service. Date: 3/3/11 0 Ll MARTSON LAW OFFICES By Ar;q- George'g. F , Jr., Esquire I.D. Number 49813 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff F.\FILES\Clients\3050 Done0\Current\630\3050.630.pra3 Revised: 4/19/11 10.52AM C SRI 3s =C George B. Faller, Jr., Esquire zM "- a ..ter- MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER cti c - = MARTSON LAW OFFICES -4C:) I.D. 49813 3 ?-n 10 East High Street =C:) C) Carlisle, PA 17013 (717) 243-3341 " w Attorneys for Plaintiffs M._ JANET M. WILEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 10-6999 CIVIL ACTION - LAW JONATHAN W. WOLLET, and PAMELA S. WOLLET, Defendants JURY TRIAL DEMANDED PRAECIPE TO THE CUMBERLAND COUNTY PROTHONOTARY: Please reinstate the attached Complaint in reference to the above-captioned action and forward to the Sheriff for service upon Jonathan W. Wollet, who is currently in the State Correctional Facility at 500 East 4th Street, Chester, PA 19013-4551. By Date: 4/18/11 MARTS{' N LAW OFFICES GeoigL-'B. Faller, Jr., I.D. Number 49813 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff p'rA imb-M `t-4 a UA03a7t{ 1Z* 0158180 F,\FILES\Clients\3050 Donegal\3050.Current\3050.630\3050.630.atr2 -#rRevised- 2/27/12 1123AM George B. Faller, Jr., Esquire -oCa -n MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER m MARTSON LAW OFFICES X:- J ril I.D. 49813 r- 27 ~ i 10 East High Street >r, ? - Ti Carlisle, PA 17013 ; .. „ (717) 243-3341 C-D Attorneys for Plaintiffs JANET M. WILEY, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-6999 CIVIL ACTION - LAW JONATHAN W. WOLLET, and PAMELA S. WOLLET, Defendants : JURY TRIAL DEMANDED AFFIDAVIT OF SERVICE OF COMPLAINT COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND ) I hereby certify that a copy of the Complaint in the above captioned matter was mailed to Mrs. Pamela S. Wollet, 1241 Wilbur Avenue, Akron, OH 44301, by certified mail. Attached is the Post Office return receipt signed and dated June 11, 2011. MARTSON LAW OFFICES By George B. Fal r, Jr., Esquire Attorney ID No. 49813 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Sworn to and subscribed before me this day of JXl1htv,?'?, 2012. Nota u lic coMMONWEALlH OF PENNSYLVANIA Nt%?rial CeAI Margaret .Ann %1.4; 1n*:arv ??blic Cariisie Ebro, CurrberieaQ County My Commission Expires 3une 29, 2015 MEMBER, 1019116MAM ASSOCUTION OF NOTARIES -4 v C`- t3 r-1 4 (Domestic Mail Only; No Insurance Coverage Provided) jfl[ For delivery information visit our website at www.usps.com Postal Service ITIFIFD MAIL- RECEIF Postage I $ C3 Return Receipt Fee O (Endorsement Required) Restricted Delivery Fee p (Endorsement Required) Total Postage & Fees 0 rR r'l Iti S, ¦ Complete Items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: 11` '?) cli r, 0- S - V?o -?u- w n?< 'yon, 1^141 y?3c,1 ? Agent r-1 AAA- B. Received by( Printed Name) C. Date of Delivery jy '/I- /f D. Is delivery address different from Item 1? ? Yes If YES, enter delivery address below: ? No 3. S ice Type 0CCertified Mail ? Express Mail O Registered Return Receipt for Merchandise C3 Insured mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Number 701D 1060 0001 1047 7 919 (r?artsfer from service &W PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 FARLES\Clients\3050 Donegal\3050.Cutrent\3050.630\3050.630.pra4 Revised: 2/27/12 1054AM George B. Faller, Jr., Esquire di FE1B 28 °N 1; `r .- MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLEi MARTSON LAW OFFICES C U M B E R L LC1 1 I.D. 49813 10 East High Street PENNSYLVANIA Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs JANET M. WILEY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 10-6999 CIVIL ACTION - LAW JONATHAN W. WOLLET, and PAMELA S. WOLLET, Defendants JURY TRIAL DEMANDED PRAECIPE TO THE YORK COUNTY PROTHONOTARY: Enter default judgment in the above-captioned action in favor of Plaintiff and against Defendant Pamela S. Wollet in the amount of $4,327.99, plus interest and costs of suit as prayed for in the Complaint, for failure to file an Answer to Plaintiffs Complaint. I do hereby certify that a written notice of intention to file this Praecipe, in the form attached hereto, was mailed to the Defendant Pamela S. Wollet at the address indicated thereon, on December 29, 2011, which date was subsequent to the date default occurred and at least ten (10) days prior to the date of the Praecipe. MART N L ES By George . Faller, Jr., Esq re I.D. No. 49813 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: 2/27/12 Attorneys for Plaintiff c,? a14. so FA at? I F:\FILES\ClientsU050I)onegal\3050.Current\630\3050.630.tendaynotl George B. Faller, Jr., Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs JANET M. WILEY, Plaintiff IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA NO. 2010-6999 V. JONATHAN W. WOLLET, and PAMELA S. WOLLET, Defendants : CIVIL ACTION-LAW : JURY TRIAL DEMANDED IMPORTANT NOTICE TO: PAMELA S. WOLLET DATE OF NOTICE: December 29, 2011 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. DAMAGES WILL BE ASSESSED AGAINST YOU IN THE AMOUNT OF THE REPAIR ESTIMATE UNLESS YOU FILE A WRITTEN PRAECIPE WITHIN TEN (10) DAYS REQUESTING A TRIAL ON DAMAGES. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone:(717) 249-3166 MARTSON W OFF CE By George B. Faller ., Esquire I. D. Number 49813 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff F41LES\Clients\3050 Donegal\Current\630\3050.630.af}7 Revised: 12/21 /11 9 46AM George B. Faller, Jr., Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs JANET M. WILEY, V. IN THE COURT OF COMMON PLEAS OF Plaintiff YORK COUNTY, PENNSYLVANIA JONATHAN W. WOLLET, and PAMELA S. WOLLET, Defendants NO. 2010-6999 CIVIL ACTION - LAW : JURY TRIAL DEMANDED AFFIDAVIT OF VALUATION I do depose and state that the valuation of $3,114.60 attached hereto is true and correct and accurately sets forth the damages to the value of the 1997 Oldsmobile Achieva owned by Janet Wiley and; the repairs were necessary and the value indicated thereon was the amount by which the damages to this automobile would fairly and reasonably have been evaluated. This statement and appraisal are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. Print Name Claim: PAF-PA-01-10- 0125438 Autosource Valuation 1997 Oldsmobile Achieve AS Request: 26696049 ' Audatex Autosource Valuation --------------------- Acimir?rsfratlu? t3ata 1,33:T Oklsmobtfe Achieva Grieco Appraisal Serv Donegal Insurance Group Marietta Branch I195 River Road Marietta PA 17547 Wiley, Allen & Janet PAF-PA-01-10-0125438 04/03/2010 Collision PAF-3067762 ?t1N54iJ?t?lr:lir3aljrsFs ; . ,• , , : " 337' CTtcf?tc,bilFS Achieve YIN',:1 G3NL52T2VM300544 besi> 1997 Oldsmobile Achleva SL 4D Sedan Decodes Correctly No activity was reported r "red Pftoti0 WPTI"r Atwlyst& f +?{ fJl"?31nQi1atr? AGht?V? No Vehicles Advertised at (717) 502-6426 No Branded title history found for this VIN. Processed on 04/13/10 9:04 AM. Title History is powered by Experian AutoCheck. The Experian data contained in this report involves the conveyance of information provided to Experian by other sources. Accordingly, neither Experian nor Audatex can, or will, be an insurer or guarantor of the accuracy or reliability of the Experian data. ------------- ---- - ---------- --------------- The Autosource database contains inspected dealer inventories, dealer advertisements, phone verified vehicles, and private party advertisements from thousands of sources Including automotive publications, newspapers and Web sites. Autosource uses vehicles comparable in year, make and model within the specified market area, expanding as necessary, to determine the kiss vehicle's local market value. This valuation includes a representative sample of the vehicles used to calculate the typical starting price. The market search originated from Zip Code 17019, as determined by the vehicle owner's principally garaged area. Autosource located 32, 1997 Oldsmobile Achieva vehicles which were used to determine the typical vehicle price. Adjustments have been made to the comparable vehicles for value differences in edition, doors and body style as indicated in the "Veh Adr Hold. The sum of the 32 comparable vehicles is $88,900 for an average price of $2,716. The asking or actual sale price is displayed for each vehicle. It a vehicle has been sold, the sold price is displayed with an (S) Indicator. The selling price may be substantially less than the asking price. In the case of this 1997 Oldsmobile Achleva, the difference between the asking price and selling price is generally 10% This selling price adjustment has been applied to the typical price. Additional adjustments have been made to the typical vehicle price taking Into consideration the loss vehicle's mileage, equipment and condition. All adjustments are vehicle specific and reflect driving habits and condition for the vehicle's market. A mileage adjustment of 1.50 cents per mile/kilometer has been applied. Taking Into consideration the vehicle specifics, the fair market value is $3,594. Version: 1 Page: 1 04/1311009:04 -14 Claim: PAF-PA-01-10- 0125438 See Valuation Autosource/ Detail Section N.A.D.A. $2,450 575 -50 980 778 -80 -65 250 s3_ain = ux Eo ins 250.60 • A G1litlaf Diilsburg, PA Dlllsburg, PA $2,444 $2,444 !eat. 1997 1997 MW4 Oldsmobile Oldsmobile M Achieva Achleva lt X, x i#gt# SL SL for 4D 4D :Sedan Sedan trot 2WD 2WD Ehiit 4 Cylinder 2.4 Engine ' 4 Cylinder 2.4 Engine Tranam w. 4 Speed Automatic . 4 Speed Automatic 0 tl?pr: Not Applicable Green 0 116, 154 Mi(Typical) 49,798 Mt(Actual) 980 CGnv®rt ' Air Conditioning Air Conditioning Tilt Steering Wheel 7Ift Steering Wheel Cruise Control Rear Window Defroster Rear Window Defroster -25 Rem Trunk-UGate Release Rem Trunk-UGate Release Other Qptjonak EgUIPMO : And-lock Brakes Anti-lock Brakes Center Console Center Console Version: 1 Page: 2 04/13/1009:04 Autosource Valuation 1997 Oldsmobile Achieve AS Request: 26696049 See N.A.D.A Value Section Claim: PAF-PA-01.10- Autosource Valuation 1997 Oldsmobile Achieve AS Request: 26696049 0125438 8690. Moderate Wear GaE: Minor Wear Ir' E`tjtt Minor Damage f Good irk Good Intermittent Wipers Lighted Entry System Tachometer Dual Airbags Tinted Glass Traction Control System Power Brakes Power Mirrors Power Steering Power Door Locks AIWFM Stereo Velour/Cloth Seats Aluminum/Alloy Wheels Minor Wear Minor Wear Minor Damage Good Good Mirror Damage Moderate Damage Ott t'rt Mirror Damage ti E Minor Wear 'ralltiisli0 Minor Wear DW Good Fr1te Good Minor Damage Minor Wear Minor Damage Well Maintained Well Maintained Good Good -35 -20 3,344 45 70 90 45 Version: 1 Page: 3 04113110 09:04 The market area Identifled has multiple tax jurisdictions. Please see valuation notes for explanation. Claim: PAF-PA-01 - 10- Autosource Valuation 1997 Oldsmobile Achieva AS Request: 26696049 0125438 ------------------- • < r< ••N.A.D.A. Vehicle Description: 1997 OLDS Achieve SI- 4 Cyl. Sedan 4D N.A.D.A. values are as of April, 2010 from the Official Older Used Car Guide, National Edition. l3as8 Yal4e $2,450 Iltechanrcat Etlgttle? $0 Transmit $0 1:rpaipmert# WPout Crum Contrif -25 : . . . . . . .. . V. . I. 00-0. a..w?.:.Y.A..h... ..1. .W...... -25 rllllt!' Lllk $ -50 li;T9 iI $575 These current N.A.D.A. values are fumished under license from NADASC. All values Copyright® NADASC 2010. The values in the N.A.D.A. guide assume a vehicle In clean condition. Appropriate deductions should be made to put a vehicle in salable condition. Special Note on Older Vehicles: N.A.D.A.'s editors believe that most optional equipment has little or no value on older vehicles. This is especially true of options that cost relatively little to begin with and which deteriorate with age or use. ---------------- o Adjustments of Special Note A mileage adjustment of 1.50 cents per mile/kilometer has been applied. This adjustment Is based on the vehicle year, vehicle category and market area. Mileage adjustments are capped at 40% of the vehkNe's starting value. Q No special adjustments were made for this vehicle. o information provided by Donegal Insurance Group n Loss vehicle description was provided by Donegal Insurance Group All values are in U.S. dollars. o Autosource Valuation Process n Over 3,400,000 vehicles are entered weekly into the database used for researching this value. This database includes dealer inspected, dealer Inventory, dealer advertised, phone verified and advertised private party vehicles. The originating search area for this valuation was Dllisburg, Pennsylvania. o Other Adjustments or Comments n The market area identified has multiple tax jurisdiot ris. Autosource was unable to Identify which county or city was applicable to the total lose vehicle. However, special tax calculation rules apply to vehicle sales In this jurisdiction (such as limits, caps, exemptions, etc.) and Autosource was able to correctly establish the tax amount of $216 4 Cylinder 2.4 Engine STD 4 Speed Automatic STD 6 Cylinder 3.1 Engine $457 atkTVr $p#iWl ?gc??pen ::.... .' ..:.:::• p01 • Anti-lock Brakes STD Power Drivers Seat • Center Console STD Power Brakes STD • Dual Airbags STD ' Power Door Locks STD Fog Lights • Power Mirrors STD • Intermittent Wipers STD • Power Steering STD Keyless Entry System Power Windows $340 Version: 1 Page: 4 04/13/10 09:04 I- . Claim: PAF-PA-01-10- 0125438 Lighted Entry System Leather Steering Wheel Rear Spoiler Tachometer Traction Control System AS Request: 26696049 STD ::. C4fM1Y81ti C?Cli.t...... . Air Conditioning STD $170 Cruise Control $225 STD ' Rear Window Defroster STD STD ' Rem Trunk-UGate Release STD Editions available for the same body style (in order of original cost, increasing): 'SL Indicates loss vehicle equipment. -------------- - Natl. Highway Traffic Safety Admin (US) has issued a total of 2 recall bulletins that may apply to this vehicle. .1.. ) ..04!01/97 t:Af1 3,464 Manhhtai htpd tl?> December 1996-January 1997 Vehicle Despdpda Passenger vehicles. Desccipttotr Of 0* The protective ever for the underhood fuse center was omitted. Without this ever, the positive < terminal bolt on the fuse block is exposed and can contact the insulated negative battery cable. If the Insulation on the negative cable becomes sufficiently wom, an electrical short circuit can occur between the positive terminal and negative cable resulting in extremely high current Clow. Cansequence:Of D" h* This high current flow can cause arcing and result In an underhood fire. Corr ENr At Ci : Dealers will Inspect these vehicle for the presence of the protective cover and, I necessary, :;:Install a protective cover to the underhood fuse center. 02V070 De+ On certain passenger vehicles, if the engine fails to start and the driver holds the key In the "Start" position for an extended period, high current flows through the ignition switch and sometimes produces enough heat to met Intemal switch parts. It the switch Is damages, a fire could occur In the steering column, even with the engine off and the key removed. Rernscljt Dealers will Install a relay kit in these vehicles to prevent current from flowing through the ignition switch. The manufacturer has reported that owner notification began March 27, 2002. Owners who do not receive the free remedy within a reasonable time should contact Chevrolet at 1-800- 222-1020, Pontiac at 1-800-762-2737, Buick at 1-800-521-7300, or Oldsmobile at 1-800442- 6537. ii 0003/01/02 Quantity4*W 1,589,948 Oates of Mailer May 1994 - July 1997 Autosource Valuation 1997 Oldsmobile Achieve Version: I Page: 5 04113110 09:04 George B. Faller, Jr., Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs JANET M. WILEY, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-6999 CIVIL ACTION - LAW JONATHAN W. WOLLET, and PAMELA S. WOLLET, Defendants : JURY TRIAL DEMANDED AFFIDAVIT AS TO MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ) :SS. COUNTY OF CUMBERLAND ) George B. Faller, Jr., Esquire, being duly sworn according to law, deposes and says that he has authority to make this affidavit on behalf of his client, and to the best of his knowledge, information and belief, the Defendant Pamela S. Wollet above named is not in the military service of the United States of America, that he has knowledge that the said Defendant is now living at: 1241 Wilbur Avenue, Akron, 01144301. Said Defendant's ce of employment is unknown. Sworn to and subscribed before me thisr day of -? ? 2 , 2012. i G George B. aller, Jr., E quire NotaA, Pbbc COMMONWEALTH OF PENNSYLVANIA Notarial Seal LMargaret Ann Nash, Notary Public ar isle soro, Cumberiand County Commisslon eores ]une 29, 2015 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES George B. Faller, Jr., Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs JANET M. WILEY, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA JONATHAN W. WOLLET, and PAMELA S. WOLLET, Defendants NO. 10-6999 : CIVIL ACTION - LAW : JURY TRIAL DEMANDED AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA ) : SS COUNTY OF CUMBERLAND George B. Faller, Jr., Esquire, being duly sworn according to law, deposes and says that he is an employee of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, attorneys for the Plaintiff in the above captioned matter and that pursuant to the provisions of the Pennsylvania Rules of Civil Procedure, a notice of intention to enter default judgment against the Defendant Pamela S. Wollet was given to her by mail on December 29, 2011. ,, Geor, . Faller, K, Es'Sworn to and subscribed before me this day of -,-2012. Not*f P'iblic COMMONWEALTH OF PENNSYLVANIA Notarial Seal Margaret Ann Nash, Notary Public CarlMe Boro, Cumberland County My Conunisdon Expl eS line 29, 2015 MEMBER, PENNSYLVANIA Assoa ION OF NOTARIES CERTIFICATE OF SERVICE I, Nichol L. Myers, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Mrs. Pamela S. Wollet 1241 Wilbur Avenue Akron, OH 44301 MARTISOQN LAW OFFICES By ?l ? `61 ) Nichol L. Myers Ten Fast High Street Carlisle, PA 17013 (717) 243-3341 Dated: 2/27/12 George B. Faller, Jr., Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs JANET M. WILEY, V. IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA JONATHAN W. WOLLET, and PAMELA S. WOLLET, Defendants NO. 10-6999 CIVIL ACTION - LAW : JURY TRIAL DEMANDED TO: PAMELA S. WOLLET, Defendant NOTICE OF ENTRY OF DEFAULT JUDGMENT You are hereby notified that on the 4--200 day of _ RC , 2012, the following Judgment was entered against you in the above-captioned action: judgment in the amount of $4,327.99, plus interest and costs of suit as prayed for in the Complaint for failure to file an Answer to Plaintiff's Complaint. Date: a z > ?- 1 (a .% Prothonotary I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Mrs. Pamela S. Wollet 1241 Wilbur Avenue Akron, OH 44301 r. d +NtdM`y"js