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HomeMy WebLinkAbout04-4031IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE HALCYON INSURANCE COMPANY, Subrogee of Patricia Bowermaster Plaintiff, CASE NO: O`! - z103l e,'u-,Lc-7& j v. HEATHER QUINN and DEBRA A. QUINN Defendants. TYPE OF PLEADING: COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: GERIANNE HANNIBAL, ESQUIRE Pa. I.D.#66622 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR # 03873154 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE HALCYON INSURANCE COMPANY, Subrogee of Patricia Bowermaster CASE NO: 014- Plaintiff, V. TYPE OF PLEADING: COMPLAINT IN CIVIL ACTION HEATHER QUINN and DEBRA A. QUINN Defendants. 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 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 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 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 NOR FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE PA 17013 (717) 249-3166 PROGRESSIVE HALCYON IN THE COURT OF COMMON PLEAS OF INSURANCE COMPANY, CUMBERLAND COUNTY, PENNSYLVANIA Subrogee of Patricia Bowermaster V. : CIVIL ACTION - LAIN NO. 04-4031 CIVIL TERM HEATHER QUINN IN RE: ARBITRATION PANEL ORDER OF COURT AND NOW, August 8, 2005, the appointment of Karen Koenigsberg, Esquire, as arbitrator in the above matter is vacated, and Michael Travis, Esquire, is appointed in his stead; Austin Grogan shall remain as chairman of the panel, and Craig Hatch shall remain as arbitrator. By the Court, Ge g offer, P.J. vKustin Grogan, Esquire, Chairman 3901 Market Street '1Camp Hill, PA 17011 4227 OS 09-G7S Court Administrator VlNVA kSJN V3d AINno nr ;r ,y t W(YJ s h :8 WV 6- 9nV SQ4t AMQNQHiO8d 3Hi 30 3011 ll3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE HALCYON INSURANCE COMPANY, Subrogee of Patricia Bowermaster n CASE NO: ©4'- C -E-W" Plaintiff, V. TYPE OF PLEADING: COMPLAINT IN CIVIL ACTION HEATHER QUINN and DEBRA A. QUINN Defendants. COMPLAINT IN CIVIL ACTION AND NOW COMES, Plaintiff, by and through its counsel, WELTMAN, WEINBERG & REIS, CO., L.P.A., and hereby files this Complaint against Defendants jointly and severally. In support thereof, Plaintiff avers as follows: Plaintiff, Progressive Halcyon Insurance Company ("Progressive"), is a corporation with a registered office located at P.O. Box 89480, Cleveland, Ohio, 44101. 2. Defendant, Heather Quinn, defendant driver, is an adult individual with a last known address of 203 Faith Circle, Carlisle PA 17013. 2a. Defendant, Debra A. Quinn, defendant owner, is an adult individual with a last known address of 33 Flower Road, Carlisle PA 17013. 3. Progressive issued a policy of insurance where Progressive agreed to insure a 1998 Chevrolet vehicle ("Insured Vehicle"), owned by Plaintiffs insured. 4. On or about August 25, 2002, Defendant driver negligently, recklessly and carelessly operated a Vehicle owned by Debra Quinn thereby colliding with the vehicle owned and operated by Progressive's insured in Carlisle PA. 4a. At all times material hereto defendant driver was acting as agent of or for the benefit of defendant owner. 5. As a direct and proximate result of Defendants' negligence, the Progressive insured vehicle sustained property damages of $7,693.34. 6. Pursuant to the insurance policy issued by Progressive and as a result of claim payment, Progressive became subrogated to the claim of its Insured against Defendants. 7. Progressive paid $7,443.34 for damages. 8. The insured incurred a $250 deductible expense. 9. Pursuant to Progressive's right of subrogation, Progressive is presently due and owed from Defendants the sum of $7,693.34. 10. Repeated demands have been made upon Defendants for payment of the aforesaid sum; however, Defendants have willfully failed and refused to pay the sum due and owing to Progressive. WHEREFORE, Plaintiff demands Judgment against Defendants jointlyAnd severally for $7,693.34 and costs. THIS IS AN ATTEMPT TO COLLECT A DEBT BE USED FOR THAT PURPOSE. PA6622 Wellffrgn, Weinberg & Reis, Co., L.P.A. 2718 Koppers Bldg. 436 7`s Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#003873154 SHALL 08/10/2004 14:24 FAY 4408037743 SUBROGATION 005 Page: 1 Document Name: untitled CMSD2340 /CMSM2340 P A C M A N AUG 09 04 - 12:53 OPID: TXP0043 CLAIM PAYMENT INQUIRY TERMID: VT640006 INSD: BOWERMASTER, PATRICIA POL: 57031387-0 DOL : AUG 25 02 PA-MECHAN-BRN- CLM: 028739981 ACTIVE REP: S HALLOCK PAY TO THE ORDER OF: TOTAL DRAFT AMOUNT: 1,222.86 LINE 1: H&H CHEVROLET ONLY**********************+++++++++++++++++*++ LINE 2: *+++++++++++++++++++++++++++++++++*++++*++**+++++++*+++*++++ LINE 3: ADDRESS: PO BOX 98 CITY: SHIPPENSBURG ST/PR* PA ZIP/CPC: 17257 CNTRY* USA IN PAYMENT OF: SUPP DMG TO 98 CHEVY BLAZER FRNT SUSP 1099 ? Y FEDERAL TAX ID: 251576345 LAST UPDT REP: RCT0003 CDS CODE * 12 PCL EFT TRACE #: ISSUING REP: R THOMPSON BANK CODE* AS2 ISSUE DATE OCT 09 02 APPROVED BY: STATE * PA AREA * 252 REVIEW DATE: 00 00 STOP RSN * DRAFT # 426337531 REVIEWED BY: COMMAND: Date: 08/09/2004 Time: 12:54:09 PM 08/10/2004 1424 FAX 4408037743 SLIBROGATION Page: 2 Document Name: untitled 0008 CMSD2340 /CMSM2340 P A C M A N AUG 09 04 - 12:53 OPID: TXP0043 CLAIM PAYMENT INQUIRY TERMID: VT640006 INSD: BOWERMASTER, PATRICIA POL. 57031387-0 DOL : AUG 25 02 PA-MECHAN-BRN- CLM: 028739981 ACTIVE REP. S HALLOCK PAY TO THE ORDER OF: TOTAL DRAFT AMOUNT: 993.78 LINE 1• H&H CHEVROLET ONLY++++++++++++++++++++++**+++++++++++*++++++ LINE 2: +++++++++++++++++++++++++++++++++++++++*+++*++++*++*++++*+++ LINE 3: ADDRESS: PO BOX 98 CITY: SHIPPENSBURG ST/PR* PA ZIP/CPC: 17257 IN PAYMENT OF: SUPP DMG TO 98 CHEVY BLAZER 1099 ? N FEDERAL TAX ID: LAST UPDT REP: RCT0003 CDS CODE * 12 PCL EFT TRACE #: ISSUING REP: R THOMPSON BANK CODE* AS2 ISSUE DATE SEP 25 02 APPROVED BY: STATE * PA AREA * 252 REVIEW DATE: 00 00 STOP RSN * DRAFT # 426163653 REVIEWED BY: COMMAND: CNTRY* USA Date: 08/09/2004 Time: 12:54:09 PM 08/10/2004 14:24. FAR 4408037743 SUBROGATION 007 Page: 3 Document Name: untitled CMSD2340 /CMSM2340 P A C M A N AUG 09 04 - 12:53 OPID: TXP0043 CLAIM PAYMENT INQUIRY TERMID: VT640006 INSD: BOWERMASTER, PATRICIA POL: 57 031387-0 DOL : AUG 25 02 PA-MECHAN-ERN- CLM: 028739981 ACTIVE REP: S HALLOCK PAY TO THE ORDER OF: TOTAL DRAFT AMOUNT: 111.00 LINE 1: H & H COLLISION CENTER ONLY LINE 2: LINE 3: ADDRESS: 129 PORTER, AVE CITY: CARLISLE ST/PR* PA ZIP/CPC: 17013 CNTRY* USA IN PAYMENT OF: TOW BILL FOR BLAZER 1099 ? Y FEDERAL TAX ID: 251576345 LAST UPDT REP: RCT0003 CDS CODE * 12 PCL EFT TRACE ISSUING REP: R THOMPSON BANK CODE* AS2 ISSUE DATE SEP 11 02 APPROVED BY: STATE * PA AREA * 252 REVIEW DATE: 00 00 STOP RSN * DRAFT # 425847335 REVIEWED BY: COMMAND: Date: 08/09/2004 Time: 12:54:09 PM 08/10/2004 14:21 FAR 4408037743 SLBROGATION Page: 4 Document Name:: untitled Z008 CMSD2340 /CMSM2340 P A C M A N AUG 09 04 - 12:53 OPID: TXP0043 CLAIM PAYMENT INQUIRY TERMID: VT640006 INSD: BOWERMASTER, PATRICIA POL: 57031387-0 DOL : AUG 25 02 PA-MECHAN-BRN- CLM: 028739981 ACTIVE REP: S HALLOCK PAY TO THE ORDER OF: TOTAL DRAFT AMOUNT: 848.37 LINE 1: H&H CHEVROLET ONLY****************************************** LINE 2; +*++++++*+++++++++++++++++*+++*++++*+++++*++*++***++**++***+ LINE 3: ADDRESS: PO BOX 98 CITY: SHIPPENSBURG ST/PR* PA ZIP/CPC: 17257 CNTRY* USA IN PAYMENT OF: SUPP DMG TO 98 CHEVY BLAZER 1099 ? Y FEDERAL TAX ID: 251576345 LAST UPDT REP: RCT0003 CDS CODE * 12 PCL EFT TRACE #: ISSUING REP: R THOMPSON BANK CODE* AS2 ISSUE DATE SEP 10 02 APPROVED BY: STATE * PA AREA * 252 REVIEW DATE: 00 00 STOP RSN * DRAFT # 425978182 REVIEWED BY: COMMAND. Date: 08/09/2004 Time: 12:54:09 PM 08/10/2004 14:24 FAR 4408037749 SUBROGATION Page: 5 Document Name: untitled Zoos CMSD2340 /CMSM2340 P A C M A N AUG 09 04 - 12:54 OPID: TXP0043 CLAIM PAYMENT INQUIRY TERMID: VT640006 INSD: BOWERMASTER, PATRICIA POL: 57031387-0 DOL : AUG 25 02 PA-MECHAN-BRN- CLM: 028739981 ACTIVE REP: S HALLOCK PAY TO THE ORDER OF: TOTAL DRAFT AMOUNT: 4,267.33 LINE 1: PATRICIA BOWERMASTER AND************:*++******a***t**t**** LINE 2: H&H COLLISION INC.<ONLY> LINE 3: ADDRESS: 129 PORTER AVE CITY: CARLISLE ST/PR* PA ZIP/CPC: 17013 IN PAYMENT OF: COLLISION DMG LOSS LESS DED AND BETTERMENT. 1099 ? N FEDERAL TAX ID: LAST UPDT REP: SJH0014 CDS CODE * 12 PCL EFT TRACE #: ISSUING REP: S HALLOCK BANK CODE* AS2 ISSUE DATE SEP 01 02 APPROVED BY: M MURRAY STATE * PA AREA * 252 REVIEW DATE: 00 00 STOP RSN * DRAFT # 425916360 REVIEWED BY: COMMAND: CNTRY* USA Date: 08/09/2004 Time: 12:54:09 PM JUL-19-2004 15:48 028633784 wwr 03678526 VERIFICATION PAGE P. 06/06 The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities, that he/she is 101-& S, , Subrogation Collector of Progressive Casualty Insurance Company, Plaintiff herein, and that he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of hisiher knowledge, information and belief. (Signature) TOTAL P.06 Cq ?a °? w P- SHERIFF'S RETURN - NOT SERVED CASE NO: 2004-04031 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PROGRESSIVE HALYCYON INSURANCE VS QUINN HEATHER ET AL R. Thomas Kline , Sheriff who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT to wit: QUINN HEATHER but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE NOT SERVED , as to the within named DEFENDANT QUINN HEATHER 03 FAITH ISLE, PA 17013 UNABLE TO SERVE DEFENDANT PRIOR TO EXPIRATION. Sheriff's Costs: So answe Docketing 18.00 Service 3.70 ?- Affidavit .00 R. Thomas Kli. - Surcharge 10.00 Sheriff of Cumberland County .00 31.70 WELTMAN WEINBERG REIS 09/20/2004 Sworn and subscribed to before me this a day of? A. D. LQ 1 ? Prothonotary SHERIFF'S RETURN - NOT FOUND CASE NO: 2004-04031 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PROGRESSIVE HALYCYON INSURANCE VS QUINN HEATHER ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT QUINN DEBRA A unable to locate Her in his bailiwick COMPLAINT & NOTICE but was He therefore returns the NOT FOUND , as to the within named DEFENDANT QUINN DEBRA A 33 FLOWER ROAD CARLISLE, PA 17013 RESIDENT AT LIVED FOR THREE YEARS AND NEVER HEARD OF DEFENDANT. NO FORWARDING AT P.O. Sheriff's Costs: Docketing 6.00 Service 3.70 Not Found 5.00 Surcharge 10.00 .00 24.70 So answer ls - ?? R. Thomas Kline Sheriff of Cumberland County WELTMAN WEINBERG REIS 09/20/2004 Sworn and subscribed to before me this _.73,cd day of° A.D. Pr onotar ? ? 00 ! ,ezsy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE HALCYON INSURANCE COMPANY, SUBROGEE OF PATRICIA BOWERMASTER Plaintiff vs. HEATHER QUINN AND DEBRA A. QUINN Defendants No. 04-4031 PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Benjamin R Bibler, Esquire PA. I.D. # 93598 William T. Molczan, Esquire PA I. D. #47437 WELTMAN, WEINBERG & REIS, CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03873154 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE HALCYON INSURANCE COMPANY, SUBROGEE OF PATRICIA BOWERMASTER Plaintiff vs. Civil Action No. 04-4031 HEATHER QUINN AND DEBRA A. QUINN Defendants PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBER?& REIS CO., L.P.A. By: I - u Benjamin R B' r, E quire PA I. D. #9 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #03873154 C7 cp C) FZ1f=: { "te ? r " -Tim T} CO t-I `Y S {_' min SHERIFF'S RETURN - REGULAR CASE N0: 2004-04031 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PROGRESSIVE HALYCYON INSURANCE VS QUINN HEATHER ET AL HAROLD WEARY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon QUINN HEATHER the DEFENDANT at 1900:00 HOURS, on the 6th day of January , 2005 at 700 NAILOR DRIVE APT 302 HILL, PA 17011 by handing to HEATHER QUINN a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 ??77 Service 10.36 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 38.36 01/07/2005 WELTMAN WEINBERG REIS Sworn and Subscribed to before me, this A_j_ day of 74, , By: Deputy-,Sheriff --?4 r ? SHERIFF'S RETURN - REGULAR CASE NO: 2004-04031 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PROGRESSIVE HALYCYON INSURANCE VS HEATHER ET AL MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon DEBRA A DEFENDANT the , at 1837:00 HOURS, on the 5th day of January , 2005 at 203 FAITH CIRCLE CARLISLE, PA 17013 by handing to DEBRA QUINN a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 3.70 .00 10.00 nn 1 J . / V Sworn and Subscribed to before me this C21_5i day of So Answers: R. Thomas Kline 01/07/2005 WELTMAN WEINBERG REIS By: Deputy Sher-Iff ,- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISON PROGRESSIVE HALCYON INSURANCE COMPANY SUBROGEE OF Patricia Bowermaster, Plaintiff CASE NO: 04-4031 Civil Term V. TYPE OF PLEADING: PRELIMINARY OBJECTIONS HEATHER QUINN and DEBRA A. QUINN, Defendants NOTICE TO PLEAD TO: James C. Warmbrodt, Esquire You are hereby notified to file a written response to the enclosed Preliminary Objections within twenty (20) days from service hereof or a judgment may be entered against you. Ily Submitted TURO I[AW OFFICES Date {}i/ J(a ?? Ron Turo, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISON PROGRESSIVE HALCYON INSURANCE COMPANY SUBROGEE OF Patricia Bowermaster, Plaintiff CASE NO: 04-4031 Civil Term V. TYPE OF PLEADING: PRELIMINARY OBJECTIONS HEATHER QUINN and DEBRA A. QUINN, Defendants PRELIMINARY OBJECTIONS OF THE DEFENDANTS' 1. Defendant Heather Quinn demurs to the complaint filed by the plaintiff which fails to state a cause of action against her and, more over, fails to allege any facts under which this Court could determine that she was negligent or liable to the plaintiff. 2. Defendant, Heather Quinn raises the legal insufficiency and lack of specificity of the complaint in that the complaint fails to state, with the required specificity, that she was, in fact, negligent and /or under a duty to plaintiff thus making her liable under the complaint. 3. Defendant, Debra Quinn demurs to the complaint as the complaint alleges that defendant, Heather Quinn "acting as an agent of or for the benefit of the defendant owner" which allegation does not allow for a cause of action by plaintiff and fails to state, with any specificity, any fact under which plaintiff claims that defendant, Heather Quinn was an agent of Debra A. Quinn. 4. Defendant Debra A. Quinn demurs to the complaint and also raises the issue that the complaint fails to state, with specificity, any facts alleged by the plaintiff that would allow her to be legally responsible to the plaintiff as a result of an automobile accident involving her daughter, defendant, Heather Quinn. WHEREFORE, for all the above reasons, defendants Heather Quinn and A. Quinn raise the enclosed Preliminary Objections to the complaint as filed Plaintiff and alternative, request this Court to dismiss the complaint filed against them or Debra by the , in the require that the plaintiff plead, with specificity as required by the Rules of Civil Procedure each and every factual and legal aljegaryon as to their liability to plaintiff in th? matter. Date ro, Esquire Tiro Law Offices 8 South Pitt Street Carlisle, PA 17013 (717) 243-9688 ext 31 VERIFICATION I verify that the statements made in the foregoing Preliminary Objections are true) and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsificat' o authorities. L Date CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Preliminary Objections upon James C. Warmbrodt, Esquire, by depositing same in the United States Mail, first class, postage pre-paid on the / day of {?°6 2005, -from Carlisle, Pennsylvania, addressed as follows: James C. Warmbrodt, Esquire Wellman, Weinberg & Reis Co., L.P.A 2718 Koppers Bldg., 436 7th Ave. Pittsburgh, PA 15219 LAW n Turo, Esquire South Pitt Street lisle, PA 17013 7) 245-9688 ext 31 NQ 03 QY N? C!? (- O L' -1t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE HALCYON INSURANCE COMPANY, Subrogee of Patricia Bowermaster Plaintiff, CASE NO: 04-4031 V. HEATHER QUINN and DEBRA A. QUINN Defendants. TYPE OF PLEADING: AMENDED COMPLAINT FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: MICHAEL J. DOUGHERTY, ESQUIRE Pa. I.D. #76046 WELTMAN, WEINBERG & REIS CO., L.P.A. 325 Chestnut Street Suite 1120 Philadelphia, PA 19106 (215) 599-1500 W WR #03873154 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE HALCYON INSURANCE COMPANY, Subrogee of Patricia Bowermaster Plaintiff, CASE NO: 04-4031 V. TYPE OF PLEADING: AMENDED COMPLAINT HEATHER QUINN and DEBRA A. QUINN Defendants. NOTICE TO DEFEND NOTICE 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 (20) days after this complaint and Notice are served, by entering a written appearance personally or by an attorney in filing in writing with the Court your defenses or objections to 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 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 LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: AVISO LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas demanddeas expuestas en las paginas siguientes, usted tiene veinte (20) dial de plaza al partir de la fecha dela demanda y la notificacion, Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. usted puede perder dinero o sus propiedadas u otros drechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTA. SI NO TIENE ABOGADO O SINO TIENE EL DINERO SUFFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME FOR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ADAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717.249.3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE HALCYON INSURANCE COMPANY, Subrogee of Patricia Bower-master Plaintiff, V. HEATHER QUINN and DEBRA A. QUINN Defendants. CASE NO: 04-4031 TYPE OF PLEADING: AMEDNED COMPLAINT COMPLAINT IN CIVIL ACTION 1. Plaintiff, Progressive Halcyon Insurance Company, is a corporation licensed and authorized to conduct business in the State of Ohio with a registered place of business located at P. O. Box 43258, Richmond Heights, Ohio. 2. Defendant, Heather Quinn, is an adult individual who at all times pertinent hereto resided at 203 Faith Circle, Carlisle, Pennsylvania 17013. 3. Defendant, Debra A. Quinn, is an adult individual who at all times pertinent hereto resided at 33 Flower Road, Carlisle, Pennsylvania 17013. 4. At all times pertinent hereto, Plaintiff, Progressive, issued a policy of motor vehicle insurance whereby Progressive agreed to insure a 1998 Chevrolet, which vehicle was owned by their insured. 5. On or about August 25, 2002 Defendant, Heather Quinn, was the operator of a motor vehicle owned by Defendant, Debra A. Quinn, which vehicle did negligently and carelessly collide with the Plaintiff Insured's vehicle at or near the intersection of East High and North Spring Garden Streets, Carlisle, Pennsylvania. COUNTI PROGRESSIVE v. HEATHER QUINN 6. Plaintiff hereby incorporates all preceding and forthcoming averments as if fully set forth at length herein. 7. The aforementioned accident was caused solely by the negligence of the Defendant, Heather Quinn, in failing to properly operate her motor vehicle at all times material hereto. 8. The negligence and carelessness of the Defendant, Heather Quinn, consisted of the following: a. Failing to have her motor vehicle under such control as the situation warranted; b. Operating her motor vehicle in complete disregard of the point and position of Plaintiff's vehicle; c. Failing to keep a proper lookout; d. Disregarding traffic control devices; e. Failing to abide by the Rules of the Road and the Motor Vehicle Code of Pennsylvania; f. Being otherwise negligent under the circumstances; and, g. Being negligent as a matter of law as may be relevant through discovery and/or at the time of trial. 9. As a of Defendant's negligence and pursuant to the terms and conditions of the policy of insurance issued by Progressive, Progressive paid the sum of $7,443.34 for damages to the Plaintiff insured's vehicle. A true and correct copy of the property damage estimate and payment documentation is attached hereto as Exhibit "I". 10. In addition to the aforesaid losses, Plaintiff's insured sustained damages in the amount of $250.00 representing a deductible for damages to his insured vehicle. 11. Pursuant to the terms and conditions of Progressive's policy of insurance, Progressive has been subrogated to the claim of its Insured against Defendant. 12. Pursuant to Progressive's right of subrogation, Progressive is presently due and owing $7,693.34 WHEREFORE, Plaintiff, Progressive Casualty Insurance Company, as subrogee of Patricia Bowermaster, demands that a judgment be entered against Defendant, Heather Quinn, in the amount of $7,693.34 plus interest and costs. COUNT II PROGRESSIVE v. DEBRA A. OUINN 13. Plaintiff hereby incorporates all preceding and forthcoming averments as if fully set forth at length herein. 14. At all times pertinent hereto, Defendant, Heather Quinn, was acting as the agent, servant, workman and/or employee of Defendant, Debra A. Quinn, in the course and scope of her employment and/or with the express and/or implied permission of Defendant, Debra A. Quinn. 15. Defendant, Debra A. Quinn, is liable for the acts and/or omissions of Defendant, Heather Quinn. 16. As a of Defendant's negligence and pursuant to the terms and conditions of the policy of insurance issued by Progressive, Progressive paid the sum of $7,443.34 for damages to the Plaintiff insured's vehicle. A true and correct copy of the property damage estimate and payment documentation is attached hereto as Exhibit "1". 17. In addition to the aforesaid losses, Plaintiff's insured sustained damages in the amount of $250.00 representing a deductible for damages to his insured vehicle. 18. Pursuant to the terms and conditions of Progressive's policy of insurance, Progressive has been subrogated to the claim of its Insured against Defendant. 19. Pursuant to Progressive's right of subrogation, Progressive is presently due and owing $7,693.34 WHEREFORE, Plaintiff, Progressive Casualty Insurance Company, as subrogee of Patricia Bowermaster, demands that a judgment be entered against Defendant, Debra A. Quinn, in the amount of $7,693.34 plus interest and costs. WELTMAN, WEINBERGc REIS CO., L.P.A. Michael J. Dougherty, Esquire Pa. I.D. #76046 325 Chestnut Street Suite 1120 Philadelphia, PA 19106 215.599.1500 WWR # 03873154 EXHIBIT 1 08%10/200'4 14:24 FAX 44060377,13 SUBROGATION 005 Page: 1 Document Name: untitled CMSD2340 /CM8M2340 P A C M A N AUG 09 04 - 12:53 OPID: TXP0043 CLAIM PAYMENT INQUIRY TERMID: VT640006 INSD: BOWER.MASTER, PATRICIA POL: 57031387-0 DOL : AUG 25 02 PA-MECHAN-BRN- CLM: 0287399BI ACTIVE REP: S HALLOCK PAY TO THE ORDER OF: TOTAL DRAFT AMOUNT: 1,222.86 LINE 1: H&H CHEVROLET ONLY*****************************+**+++**+***+ LINE 2: **++++,w+*+++++**+**,r+**++*+*+++t++**++***++*+++++++*++*,r++++ LINE 3; ADDRESS: PO BOX 98 CITY: SHIPPENSBURG ST/PR* PA ZIP/CPC: 17257 CNTRY* USA IN PAYMENT OF: SUPP DMG TO 98 CHEVY BLAZER FRNT SUSP 1099 ? Y FEDERAL TAX ID: 251576345 LAST UPDT REP: RCT0003 CDS CODE * 12 PCL EFT TRACE #: ISSUING REP: R THOMPSON BANK CODE* AS2 ISSUE DATE OCT 09 02 APPROVED BY: STATE * PA AREA * 252 REVIEW DATE: 00 00 STOP RSN * DRAFT # 426337531 REVIEWED BY: COMMAND: Date: 08109/2004 Time: 12:54:09 PM 08/10/200:1 14;24 FAX 4406037743 SUBROGATION BOOB Page: 2 Dccument Name: untitled CMSD2340 /CMSM2340 P A C M A N AUG 09 04 - 12:53 OPID: TXP0043 CLAIM PAYMENT INQUIRY TERMID: VT640006 INSD: BOWERMASTER, PATRICIA POL: 57031387-0 DOL : AUG 25 02 PA-MECHAN-BRN- CLM: 028739981 ACTIVE REP: S HALLOCK PAY TO THE ORDER OF: TOTAL DRAFT AMOUNT: 993.78 LINE 1: H&H CHEVROLET ONLY*********************************+x+*++++x LINE 2: **+x+++++x+++x+x++xx++x+++x+++++++++x**+x+x+++x*++++++**+*tx LINE 3: ADDRESS: PO BOX 98 CITY: SHIPPENSBURG ST/PR* PA ZIP/CPC: 17257 CNTRY* USA IN PAYMENT OF: SUPP DMG TO 98 CHEVY BLAZER 1099 ? N FEDERAL TAX ID: LAST UPDT REP: RCT0003 CDS CODE * 12 PCL EFT TRACE #: ISSUING REP: R THOMPSON BANK CODE* AS2 ISSUE DATE : SEP 25 02 APPROVED BY: STATE * PA AREA * 252 REVIEW DATE: 00 00 STOP RSN * DRAFT # 426163653 REVIEWED BY: COMMAND: Date: 08/09/2004 Time: 12:54:09 PM Ufi/?.o/2Up_1d:21. FAX 49060.77743 SUBROGATION z0n7 age: 3 Document Name: untitled CMSD2340 /CMSM2340 P A C M A N AUG 09 04 - 12:53 OPID: TXP0043 CLAIM PAYMENT INQUIRY TERMID: VT640006 INSD: BOWERMASTER, PATRICIA POL: 57031387-0 DOL : AUG 25 02 PA-MECHAN-BRN- CLM: 028739981 ACTIVE REP: S HALLOCK PAY TO TI4E ORDER OF: TOTAL DRAFT AMOUNT: LINE 1: H & H COLLISION CENTER ONLY LINE 2: LINE 3: ADDRESS: 129 PORTER AVE CITY: CARLISLE IN PAYMENT OF: TOW BILL FOR BLAZER, ST/PR- PA ZIP/CPC: 17013 1099 ? Y FEDERAL TAX ID: 251576345 LAST UPDT REP: RCT0003 CDS CODE * 22 PCL EFT TRACE ISSUING REP: R THOMPSON BANK CODE* AS2 ISSUE DATE SEP 11 02 APPROVED BY: STATE * PA AREA * 252 REVIEW DATE: 00 00 STOP RSN * DRAFT # 425847335 REVIEWED BY: COMMAND: 111.00 CNTRY* USA Date: 08/09/2004 Time: 12:54:09 PM 08/10/2004 14:24 Rkl 4408037743 S[TROGATIOti Z008 age: 4 Document Name: untitled CMSD2340 /CMSM2340 P A C M A N AUG 09 04 - 12:53 OPID: TXP0043 CLAIM PAYMENT INQUIRY TERMID: VT640006 INSD: BOWERMASTER, PATRICIA POL: 57031387-0 DOL : AUG 25 02 PA-MECHAN-BRN- CLM: 028739981 ACTIVE REP: S HALLOCK PAY TO THE ORDER OF: TOTAL, DRAFT AMOUNT: 848.37 LINE 1: H&H CHEVROLET ONLY****************************************+* LINE 2: *******+++*:r**++**++***+++*+++r+++++++++++,t++++***+++*++***+ LINE 3: ADDRESS: PO BOX 98 CITY: SHIPPENSBURG ST/PR* PA ZIP/CPC: 17257 CNTRY* USA IN PAYMENT OF: SUPP DMG TO 98 CHEVY BLAZER 1099 ? Y FEDERAL TAX ID: 251576345 LAST UPDT REP: RCT0003 CDS CODE * 12 PCL EFT TRACE #: ISSUING REP: R THOMPSON BANK CODE* AS2 ISSUE DATE SEP 10 02 APPROVED BY: STATE * PA AREA * 252 REVIEW DATE: 00 00 STOP RSN * DRAFT # 425978182 REVIEWED BY: COMMAND: Date: 08/09/2004 Time: 12:54:09 PM _R8 /?. 0; 200'1 14:24 FAT 44060377.13 SUBROGATION 0 009 Page: 5 Document Name_ untitled CMSD2340 /CMSM2340 P A C M A N AUG 09 04 - 12:54 OPID: TXP0043 CLAIM PAYMENT INQUIRY TERMID: VT640006 INSD: BOWERMASTER, PATRICIA POL: 57031387-0 DOL : AUG 25 02 PA-MECHAN-BRN- CLM: 028739981 ACTIVE REP: S HALLOCK PAY TO THE ORDER OF: TOTAL DRAFT AMOUNT: 4,267.33 LINE 1: PATRICIA BOWERMASTER AND********************************** LINE 2: H&H COLLISION INC.<ONLY> LINE 3: ADDRESS: 129 PORTER AVE CITY: CARLISLE ST/PR* PA ZIP/CPC: 17013 IN PAYMENT OF: COLLISION DMG LOSS LESS DED AND BETTERMENT. 1099 ? N FEDERAL TAX ID: LAST UPDT REP: SJH0014 CDS CODE * 12 PCL EFT TRACE ISSUING REP: S HALLOCK BANK CODE* AS2 ISSUE DATE SEP 01 02 APPROVED BY: M MURRAY STATE * PA AREA * 252 REVIEW DATE: 00 00 STOP RSN * DRAFT # 425916360 REVIEWED BY: COMMAND: CNTRY* USA Date: 06/09/2004 Time: 12:54:09 PM VERIFICATION I, Michael J. Dougherty, Esquire, attorney for the Plaintiff(s) do hereby swear and affirm that the averments in the attached Complaint are true and correct to the best of my knowledge, information and/or belief. These averments are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unswom falsification to authorities. Mi J. Dougherty Date 7 f yr `;; _, ?::, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COU CIVIL DIVISON PROGRESSIVE HALCYON INSURANCE COMPANY SUBROGEE OF Patricia Bowermaster, Plaintiff CASE NO: V. TYPE OF P PRELIMIN/ HEATHER QUINN and DEBRA A. QUINN, Defendants NOTICE TO PLEAD TO: Michael J. Dougherty, Esquire You are hereby notified to file a written response to the en Objections within twenty (20) days from service hereof or a judgme against you. Respectfully Submitted TURD LAW OFFICES c? S Date Ron Turo, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Defendants PENNSYLVANIA Civil Term DING: OBJECTIONS Preliminary may be entered IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. CIVIL DIVISON PROGRESSIVE HALCYON INSURANCE COMPANY SUBROGEE OF Patricia Bowermaster, Plaintiff CASE NO: V. TYPE OF PLEA PRELIMINAR HEATHER QUINN and DEBRA A. QUINN, Defendants Defendant, Heather Quinn raises the legal insufficiency and lai the complaint in that the complaint fails to state, with the requii she was, in fact, negligent and /or under a duty to plaintiff thus under the complaint and no proper verification was supplied. Defendant, Debra Quinn demurs to the complaint as the comp defendant, Heather Quinn "acting as an agent of or for the ber defendant owner" which allegation does not allow for a cause and fails to state, with any specificity, any fact under which pla defendant, Heather Quinn was an agent of Debra A. Quinn. Defendant Debra A. Quinn demurs to the complaint and also r the complaint fails to state, with specificity, any facts alleged b would allow her to be legally responsible to the plaintiff as a re automobile accident involving her daughter, defendant, Heathy WHEREFORE, for all the above reasons, defendants Heather A. Quinn raise the enclosed Preliminary Objections to the complai Plaintiff and request this Court to dismiss the complaint filed again alternative, require that the plaintiff plead, with specificity as requir Civil Procedure each and every factual and legal allegati ri as to t plaintiff inthis r. V41ZO-57- R p Date on r sq Turo Law Offic LVANIA 1 Civil Term ING: OBJECTIONS of specificity of specificity, that akinq her liable nt alleges that it of the action by plaintiff !iff claims that ses the issue that the plaintiff that ,jlt of an Quinn. jinn and Debra as filed by the them or, in the I by the Rules of it liability to 28 South Pitt St eet Carlisle, PA 17 13 (717) 243-9688 Of 31 1 CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the upon Michael J. Dougherty, Esquire, by depositing sam//e in the Ur class, postage pre-paid on the J _S? day of A, , Pennsylvania, addressed as follows: Michael J. Dougherty 325 Chestnut Street, Suite 1120 Philadelphia, PA 19106 TUR7LAW OFFICES uro, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 ext 31 inary Objections States Mail, first from Carlisle, r I VERIFICATION I, Ron Turo, Esquire, attorney for the Defendants' here n, have sufficient knowledge of the facts contained in this Preliminary Objections nd verify that the statements made in the foregoing Preliminary Objections are true and correct to the best of my knowledge, based upon information received from the PI intiff. I understand that false statements herein made are subject to the penalties of 1 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. A verification execute by the Plaintiff will be filed of record as soon as it becomes available. Date Ron Tuo, Esquire - ' c? ?, ? s ? ? __. ` ? _-„ "'?fi , ,'? ?'' try ?, t?? ,_ r. ?, ,, t . - ' ?; ? ': ,\ z- , :? 4r5 WELTMAN, WEINBERG & REIS CO., L.P.A. BY: Michael J. Dougherty, Esquire I.D. No. 76046 325 Chestnut Street, Suite 1120 Philadelphia, PA 19106 Phone: 215.599.1500 Fax: 215.599.1505 File # 03873154 Attorney for Plaintiff(s) } PROGRESSIVE HALCYON INS. CO. } A/s/o PATRICIA BOWERMASTER } vs. } } HEATHER QUINN and } DEBRA A. QUINN } Cumberland County Court of Common Pleas No. 04-4031 CIVIL TERM It is hereby stipulated by and between Plaintiff, Progressive Halcyon Insurance Company, as subrogee of Patricia Bowermaster, and Defendants, Heather and Debra A. Quinn, that Defendant, Debra A. Quinn, is dismissed with prejudice from the above- captioned action. Attorney for Plaintiff Esquire may.. for Defendants Y_? [ \ .J ('._7 ?. J ? ? _ ? (.? ti) t'r i V_? ?J ?) f.r 1? ?' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISON PROGRESSIVE HALCYON INSURANCE COMPANY SUBROGEE OF Patricia Bowermaster, Plaintiff CASE NO: 04-4031 Civil Term V. HEATHER QUINN and DEBRA A. QUINN, Defendants PRAECIPE TYPE OF PLEADING: PRELIMINARY OBJECTIONS TO THE PROTHONOTARY OF THE SAID COURT: Please withdraw with prejudice the Preliminary Objection filed by defendants to plaintiff's Amended Complaint in the above-captioned matter. y1oS ' Date Submitted Von Turo, Esquire 8 South Pitt Street Carlisle, PA 17013 (717) 245-9688 ext 31 Attorney for Defendant ,-? ?-i7 { - Z " .r. ?t . ('t ??. l`. .,,'J ??? ?•1? `a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE HALCYON INSURANCE COMPANY, Subrogee of Patricia Bowermaster No. 04-4031 Civil Term Plaintiff, VS. HEATHER QUINN Defendant PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Michael J. Dougherty, counsel for the Plaintiff in the above action, respectfully represents that: 1. The above-captioned action is at issue. 2. The claim of the plaintiff in the action is $7,693.34 The following attorney is interested in the case as counsel or is otherwise disqualified to sit as arbitrators: Ron Turo, Esquire. WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully P.A. I.D. #76046 , Esquire Weltman, Weinbe?g, & Reis, Co., L.P.A. 325 Chestnut Street, Suite 1120 Philadelphia, PA 19106 W WR# 03873154 CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of the within Petition for Arbitration was served on the Q day of 20 C& , by first class, U.S. Mail, postage-prepaid, addressed as follows: HEATHER QUINN CIO Ron Turo, Esquire Turo Law Offices 28 South Pitt Street Carlisle, PA 17013 7la o 5 Date Micho 17. Dougherty, Esquire ? CZ1 _. p -,` ? ?3 C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL, DIVISION PROGRESSIVE HALCYON INSURANCE COMPANY, Subrogee of Patricia Bowermaster Plaintiff, vs. HEATHER QUINN Defendant No. 04-4031 Civil Term ORDER OF COURT . Yw AND NOW, this ! i day of 2005, in consideration of the foregoing petition, sq., and Esq., and 91a y Esq., are appointed arbitrators in the above captioned action as prayed for. 7 WWWR# 03873154 .? ?? ?, ?;r,i' ?, , ? ,. PROGRESSIVE HALCYON : IN THE COURT OF COMMON PLEAS OF INSURANCE COMPANY, : CUMBERLAND COUNTY, PENNSYLVANIA Subrogee of Patricia Bowwermaster V. HEATHER QUINN IN RE: ARBITRATION PANEL CIVIL ACTION - LAW NO. 04-4031 CIVIL TERM ORDER OF COURT AND NOW, September 8, 2005, the appointment of Austin Grogan, Esquire, as Chairman of the Arbitration Panel in the above matter is vacated, and Henry Coyne, Esquire, is appointed in his stead; Michael Travis, Esquire, and Craig Hatch, Esquire, shad remain as arbitrators. By the Court, G or o er, P.J. Henry Coyne, Esquire Chairman of the Arbitration Panel 3901 Market Street Camp Hill, PA 17011-4227 Court Administrator A WELTMAN, WEINBERG & REIS CO., L.P.A. BY Michael J. Dougherty, Esquire Attorney for Plaintiff(s) I.D. No. 76046 325 Chestnut Street, Suite 1120 Philadelphia, PA 19106 Phone: 215.599.1500 Fax: 215.599.1505 File # 03873154 PROGRESSIVE HALCYON INSURANCE COMPANY, Subrogee of Patricia Bowermaster Cumberland County Court of Common Pleas vs. NO. 04-4031 HEATHER QUINN AND DEBRA A. QUINN PRAECIPE TO ENTER JUDGMENT ON REPORT AND AWARD OF ARBITRATORS AS TO HEATHER QUINN TO THE PROTHONOTARY: Kindly enter judgment on the Report and Award of Arbitrators entered on November 4, 2005 in favor of Plaintiff and against Defendant, Heather Quinn, in the amount of $7,693.34. Attached is the Report and Award of Arbitrators. WELTMAN, WEINBER & REIS CO., L.P.A. 7 4 Micpel J. Dougherty, Esquire Attorney for Plaintiff a w erM?gAtdn The Court of Common Pleas of Cumberland Plaintiff T Defendant County, Pennsylvania qp,IL_ Civil Action- Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office with fidelity. Signature *iY'U Name (Ch&=u) L? Si afore Name Signa e Name LRWFixm Law Firm Law irm 3R 13 Address Address - Address !LLt ??ci} rrio ??/?Od? (?v?a !h!/, ??t7vr1 Ct #Jt6- 14 City, Zip 17411-L12'enty, zip City, Zip Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) st Arbitrator, dissents. (Insert name if applicable. Date of Hearing: 2 6 m c P !A-,S u ;,F.h ' (Chairman) 4Rz;-" Date of Award: 7-6 a",5- Notice of Entry of Award Now, the v g, day of y2vc e, ?Gr , 20 05? , at ?; a 9 , P.M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ ,? 9e. cQ) By: rothonotary Deputy ? } r t Tt y"1 ill z a IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE HALCYON INSURANCE COMPANY, Subrogee of Patricia Bowermaster vs. NO. 04-4031 HEATHER QUINN AND DEBRA A. QUINN NOTICE OF JUDGMENT OR ORDER AS TO HEATHER QUINN TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on Z0 6S )Assumpsit Judgment in the amount of $ plus interest and costs. (XX) Trespass Judgment in the amount of $7,693.34 plus interest and costs. (XX) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession ( ) Default ( ) Verdict (xx) Arbitration Award ( ) By Consent Prothonotary Michael J. Dougherty, Esquire Wetman, Weinberg & Reis Co., LPA 325 Chestnut Street, Suite 1120 By: Philadelphia, PA 19106 PRO ONOT1YRY 215.599.1500 Our File No. 03873154 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE CASUALTY INSURANCE COMPANY, Subrogee of Troy Conger CASE NO: 04- l o 3 I Plaintiff, V. TYPE OF PLEADING: COMPLAINT IN CIVIL ACTION Heather Quinn Defendants. AFFIDAVIT I, August J. Ober, IV, Esq. hereby certify that a motor vehicle accident occurred on 08/25/2002. This statement is made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsifications to public authorities. Date: .:` rTl 1 3 , cr LA v µ. ,