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Home My WebLink About01-4852IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE INSURANCE COMPANIES, Subrogee of Todd Frey, Plaintiff, GARY REED, Defendant. CASENO: t:~//~ q¢~ ~ TYPE OF PLEADING: COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: SHERRY D. LOWE, ESQUIRE Pa. I.D, #66096 WELTMAN, WE1NBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR # 02306448 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE INSURANCE COMPANIES, Subrogee of Todd Frey, Plaintiff, VS. GARY REED, Defendant. CaseNo.: (~[- t~Sc) ~--i'~iI NOTICE TO DE__FEND_ 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FiND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE INSURANCE COMPANIES, ) Subrogee of Todd Frey, ) ) Plaintiff, ) ) v. ) ) GARY REED, ) ) Defendant. ) CASE NO: COMPLAINT IN CML ACTION AND NOW COMES, Plaintiff, Progressive Insurance Companies, Subrogee of Todd Frey, by and through its counsel, Sherry D. Lowe, Esquire and WELTMAN, WE1NBERG & REIS, CO., L.P.A., and hereby files this Complaint against Defendant, Gary Reed. In support thereof, Plaintiff avers as follows: 1. Plaintiff, Progressive Insurance Company, (hereinafter referred to as Progressive"), is a corporation with registered office located at P.O. Box 43258, Richmond Heights, Ohio. 2. Defendant, Gary Reed, is an adult individual with a last known address of 2 Stuart Street, Apt. 2, Mount Holly Springs, Cumberland County, Pennsylvania 17065. 3. Progressive issued a policy of insurance where Progressive agreed to insure a 199I Suzu Swift GT, V1N# 2S2AC34S9M6601404 ("Insured Vehicle"), owned by Plaintiff's insured, Todd Frey. 4. At all times mentioned herein, Progressive's insured was the owner of said Insured Vehicle and Progressive's Insured had insurance coverage for his wife, Zoann Frey. 5. At all times mentioned herein, it is believed and therefore averred that Defendant Gary Reed ("Defendant Owner") was the owner and driver of a Chevy s-10 Blazer ("Defendant Owner's Vehicle"). 6. At all times mentioned herein, Defendant Owner did not have valid insurance coverage in violation of Pennsylvania's Motor Vehicle FinanciaI Responsibility Law, 75 Pa.C.S.A. Section 1785. 7. On or about August 22, 1999, Defendant Owner negligently operated Defendant Owner's Vehicle causing damage to the vehicle owned and operated by Progressive's insured by striking the Insured Vehicle. 8. As a direct and proximate result of Defendant's negligence, the vehicle owned by Progressive's Insured sustained property damages in the amount of $292.71. 9. As a direct and proximate result of Defendant's negligence, Progressive's Insured's wife sustained bodily injury in the amount of $2,349.12 for which Plaintiff's insured made a claim for uninsured coverage since Defendant did not have insurance coverage at the time of the accident. 10. Pursuant to the terms and conditions of the insurance policy, Progressive paid the sum of $2,641.83, which represents the property damages sustained to its Insured's Vehicle and uninsured motorist claim by its Insured, as a result of Defendant's negligence. A true and correct copy of the record of the drafts paid by Progressive to and on behalf of its Insured is attached hereto as Exhibit "A" and made a part hereof. 11. Under the terms of the insurance policy issued by Progressive, its insured also sustained damages in the amount of $500.00, which represents the deductible amount under the policy of insurance. 12. Pursuant to the insurance policy issued by Progressive and as a result of said aforesaid payment, Progressive became subrogated to the claim of its Insured against Defendant. 13. Pursuant to Progressive's right of subrogation, Progressive is presently due and owed from Defendant the sum of $3,141.83, which represents the property damage claim of $292.71, uninsured benefits of $2,349.12 and the deductible payment of $500.00 suffered by Plaintiff's insured. 14. Repeated demands have been made upon Defendant for payment of the aforesaid sum; however, Defendant has ~villfully failed and refused to pay the sum due and owing to Progressive. WHEREFORE, Plaintiff, Progressive Insurance Companies, Subrogee of Todd Frey, demands Judgment against Defendant, Gary Reed, in the amount of $3,41.83 and costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. Respectfully Submitted: WELTMAN, WE1NBERG & REIS, CO., L.P.A. She~e, Esquire PA I.D. # 66096 Weltman, Weinberg & Reis, Co., L.P.A. 2718 Koppers Bldg. 436 7th Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR # 02306448 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities, she is an attomey for the Plaintiff herein; makes this Verification based upon the facts as supplied to her by the Plaintiff and/or its agents and because the Plaintiffis outside the jurisdiction of the court and the Plaintiffs Verification cannot be obtained within the time allowed for filing of this pleading, and that the facts set forth in the foregoing pleading are true and correct to the best of her knowledge, information and belief. Sherry D. Lowe, Esquire SHERIFF'S RETURN - CASE NO: 2001-04852 P COMMONWEALTH OF PENNSYLVAi~IA COUNTY OF CUMBERLAND NOT FOUND PROGRESSIVE INSUP~ANCE COMPANIE VS REED GARY R. Thomas Kline duly sworn according to law, says, that he made a diligent inquiry for the within named defendant, DEFENDANT REED GARY ,Sheriff or Deputy Sheriff, who being search and but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , the within named DEFENDANT , REED GARY , NOT FOUND , as to PER POST OFFICE, MOVED LEFT NO FORWARDING ADDRESS. Sheriff's Costs: Docketing Service Not Found Surcharge 18 00 4 55 5 00 10 00 00 37 55 Sheriff of Cumberland County WELTMAN WEINBERG & REIS 08/30/2001 Sworn and subscribed to before me this /~ day of~ ~n/ A.D. ~othonotary 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DMSION PROGRESSIVE INSURANCE COMPANIES, SUBROGEE OF TODD FREY Plaintiff VS. GARY REED Defendant No. 01-4852 Civil PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: SHERRY D. LOWE, ESQUIRE PA I.D.#66096 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 4344955 WWR#02306448 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE INSURANCE COMPANIES, SUBROGEE OF TODD FREY Plaintiff VS. GARY REED Defendant Civil Action No. 01-4852 Civil PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WE1NBERG & REIS CO., L.P.A. By: ~ SHERRY D. LOWE, ESQUIRE PA I.D.#66096 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02306448 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE INSURANCE COMPANIES, SUBROGEE OF TODD FREY Plaintiff VS. GARY REED Defendant No. 01-4852 Civil PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: SHERRY D. LOWE, ESQUIRE PA I.D.#66096 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02306448 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE iNSURANCE COMPANIES, SUBROGEE OF TODD FREY Plaintiff VS. GARY REED Defendant Civil Action No. 01-4852 Civil PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: SHERRY D. LOWE, ESQUIRE PA I.D.#66096 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #02306448 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE INSURANCE COMPANIES, Subrogee of Todd Frey, VS. GARY REED, Plaintiff, Defendant. No. 01-4852 Civil PRAECIPE TO REINSTATE COMPLAINT IN CIVIL ACTION Filed by plaintiff counsel Gerianne Hannibal Esquire PA ID 66622 (412) 434-7955 Weltman Weinberg & Reis Co LPA 2718 Koppers Building 436 7th Ave Pittsburgh PA 15219 WWR #02306448 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE INSURANCE COMPANIES, Subrogee of Todd Frey, Plaintiff, VS. GARY REED, Defendant. No. 01-4852 Civil PRAECIPE TO REINSTATE THE COMPLAINT IN CIVIL ACTION TO THE PROTHONOTARY: Kindly reinstate the Complaint in Civil Action in the above-captioned action. '~ ~J/~i I~4qBER ~ ~.~ .IS CO., L.P.A. G'EI:~ HANNIBAL PA I.D. #66622 Weltman, Weinberg & Reis C., L.F.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #02306448 SHERIFF'S RETURN - REGULAR CASE NO: 2001-04852 P COMMONWEALTH OF PENNSYLVANIA: COITNTY OF CUMBERLA/WD PROGRESSIVE INSURANCE COMPANIE VS REED GARY VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon REED GARY the DEFENDANT , at 1813:00 HOURS, on the 16th day of December , 2002 at 1135 EASY ROAD CARLISLE, PA 17013 by handing to GARY REED a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.14 Affidavit o00 Surcharge 10.00 .00 32.14 Sworn and Subscribed to before me this 2~ day of A.D. /P~othonotary f / 7 So Answers: R. Thomas Kline 12/17/2002 WELTMAN WEINBERG REIS ~3epury SherRzf, f~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE INSURANCE COMPANIES, SUBROGEE OF TODD FREY Plaintiff VS. GARY REED Defendant No. 01-4852 Civil PRAEClPE FOR DEFAULT JUDGMENT 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 Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02306448 THISIS AN ATTEMPTTO COLLECT A DEBT AND ANYINFORMATION OBTAINED SHALL BE USED FOR THATPURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE INSURANCE COMPANIES, SUBROGEE OF TODD FREY Plaintiff VS. GARY REED Civil Action No. 01-4852 Civil Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, Gary Reed, above named, in the default of an Answer, in the amount of $3,141.83 computed as follows: Amount claimed in Complaint Interest from ihe date of Judgment at the legal interest rate of 6% per annum TOTAL $3,141.83 I hereby certify that appropriate Notice of Default, as attached has been mailed in accordance with PA R.C.P. 237.1 on the date indicated on the Notice. WELTMAN~ WEI~BE/~G & REIS CO~4 G ERIAN~f~I~'~IBAL, ESQUIRE PA I.D.#66622 Weltman, Weinberg & Reis Co., L.P.,~. 2718 Koppers BIdg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WW R#02306448 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 th 7 Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 1135 Easy Road, Carlisle, PA 17013 $3,141.83 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE INSURANCE COMPANIES, Subrogee of Todd Frey, Plaintiff vs. GARY REED Civil Action No. 01-4852 Civil Defendant IMPORTANT NOTICE TO: Gary Reed 1135 Easy Road Carlisle, PA 17013 YOU ARE ~1 DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY A'ND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 co... By: / ( / G e r ~::u::~'"~a n~ i b a I, ,~r~ ' PA I.D. #66622 WELTMAN, WEINBERG & REIS CO., L.P.A./ 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #02306448 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, that the parties against whom Judgment is to be entered according to the Praecipe attached are not members of the Armed Forces of the United States or any other military or non-military service covered by the Soldiers and Sailors Civil Relief Act of 1940. The undersigned further states that the information is true and correct to the best of the undersigned's knowledge and belief and upon information received from others. W ELTMAN,/V~Eq~N Bf RG¢ REIS CO., L.P./~ GERIA_NI31E ~IANi~II'B/AL, ESQUIRE PA I.D.¢~66622 / Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WW R#02306448 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE CASUALTY INS. CO. a/s/o Todd Frey Plaintiff VS, GARY REED Defendant No. 01-4852 PRAECIPE FOR SATISFACTION OF JUDGMENT 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#02306448 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE CASUALTY INS. CO. a/s/o Todd Frey Plaintiff VS. GARY REED Defendant Civil Action No. 01-4852 PRAEClPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMABy: ~~t~/~EiN E ( G E RIA~N"r~ II~ANI(II BA~ PA. I.D.#66622 .O., LP.A. ESQUIRE WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR02306448 Sworn to~d sub¢~--~::l before r~e tl~is ~ day ~vla~ NOTARY~P__U~LIC ~ t~