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Home My WebLink About11-8354 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL CIVIL DIVISION - ARBITRATION AUTOMOBILE INSURANCE COMPANY, No.: ' `. 3 S4 Plaintiff, , vs. CIVIL COMPLAINT -Z i< , CD C-) OLEKSANDR KOLBASIN and w :ZF ' s n? ANB LOGISTICS, INC., Defendants. Filed on behalf of Plaintiff Counsel of Record for this Party: Travis L. McElhaney, Esquire PA I.D. # 204023 Christopher P. Deegan, Esquire PA I.D. #85635 WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY, LLP Firm #594 Two Gateway Center 14th Floor Pittsburgh, PA 15222 (412) 281-4541 (412) 281-4547 fax osw? W, P8 mi? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Plaintiff, vs. OLEKSANDR KOLBASIN and ANB LOGISTICS, INC., Defendants. CIVIL DIVISION - ARBITRATION No.. 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 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, TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street, Carlisle, PA 17013 Telephone: (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, CIVIL DIVISION - ARBITRATION No.. Plaintiff, vs. OLEKSANDR KOLBASIN and ANB LOGISTICS, INC., Defendants. COMPLAINT AND NOW, comes Plaintiff, State Farm Mutual Automobile Insurance Company, by and through its counsel, Travis L. McElhaney, Esquire, Christopher P. Deegan, Esquire and the law firm of Weber Gallagher Simpson Stapleton Fires & Newby, LLP, and files the following Complaint: 1. Plaintiff, State Farm Mutual Automobile Insurance Company ("State Farm"), is a company doing business within the Commonwealth of Pennsylvania and has a place of business at P.O. Box 2371, Bloomington, Illinois 61702-2371. 2. Defendant, Oleksandr Kolbasin ("Kolbasin"), is an adult individual residing at 1207 West 16t" Street, Vancouver, Washington 98660. 3. Defendant, ANB Logistics, Inc. ("ANB"), is a corporation doing business within the Commonwealth of Pennsylvania and has a place of business located at 982 South Buffalo Grove Road, Buffalo Grove, Illinois 60089. 4. At all times relevant hereto, Scott Powers ("Powers") was the owner of a 2004 Kia Rio automobile. 5. At all times relevant hereto, Powers maintained a policy of automobile insurance with State Farm which covered his aforementioned vehicle. 6. Pursuant to its policy of insurance, State Farm retains subrogation rights against any party liable for causing damage to Powers' aforementioned vehicle. 7. At all times relevant hereto, ANB was the owner of a 2005 Volvo tractor-trailer. 8. At all times relevant hereto, Kolbasin was an employee and/or agent and/or representative of ANB and was operating ANB's aforementioned tractor-trailer within the course and scope of his employment and/or agency and/or representation. 9. On or about October 13, 2010, Powers vehicle was legally parked and unoccupied on Prince Street in Shippensburg, Cumberland County, Pennsylvania, near its intersection with Garfield Street. 10. Suddenly and without warning, Kolbasin, who had traveling on Prince Street, did strike Powers' legally parked and unoccupied vehicle, causing damage thereto. 11. At all times relevant hereto, Powers vehicle was legally parked and unoccupied. 12. Pursuant to its policy of insurance with Powers, Plaintiff State Farm paid sum- certain damages in the amount of $2,506.07 as a result of the aforementioned damage to Powers' vehicle. COUNT I - NEGLIGENCE State Farm Mutual Automobile Insurance Comnany vs Oleksandr Kolbasin 13. Paragraphs 1-12 above are incorporated by reference herein as if more fully set forth at length below. 14. The careless, negligent and reckless conduct of Kolbasin was the direct and proximate cause of the damages suffered by Plaintiff, and that conduct is more particularly set forth in the lettered paragraphs below: a. In failing to control the vehicle; b. In failing to look or watch where the vehicle was being operated; In failing to keep a safe and proper lookout as he traveled; d. In failing to remain alert to existing road and traffic conditions; e. In attempting a wide-right turn when he knew or should have known that it was not safe to do so; f. In traveling on a road not suitable for tractor-trailer traffic; g. In striking Powers' legally parked and unoccupied vehicle; h. In failing to avoid striking Powers' legally parked and unoccupied vehicle; i. In traveling too close to Powers' vehicle; In failing to use the brakes or braking mechanisms; k. In operating the vehicle in violation of the Pennsylvania Motor Vehicle Code; and In failing to provide Plaintiff with the standard of care owed to it under the existing circumstances. WHEREFORE, Plaintiff, State Farm Mutual Automobile Insurance Company, demands judgment in its favor and against the defendant, Oleksandr Kolbasin, in the amount of $2,506.07, exclusive of interest and costs. COUNT II - NEGLIGENCE State Farm Mutual Automobile Insurance Company vs. ANB Lo istics Inc. 15. Paragraphs 1-14 above are incorporated by reference herein as if more fully set forth at length below. 16. The careless, negligent and reckless conduct of ANB, by and through its employees and/or agents and/or representatives, was the direct and proximate cause of the damages suffered by Plaintiff, and that conduct is more particularly set forth in the lettered paragraph,, below: a. In failing to properly train its employee and/or agent and/or representative; b. In failing to properly supervise its employee and/or agent and/or representative; In allowing and/or permitting its employee and/or agent and/or representative to act or omit to act as described in paragraph 14; d. Pursuant to common law respondeat superior; e. Pursuant to common law vicarious liability; and f. In failing to provide Plaintiff with the standard of care owed to it under the existing circumstances. WHEREFORE, Plaintiff, State Farm Mutual Automobile Insurance, demands judgment in its favor and against the defendant, ANB Logistics, Inc., in the amount of $2,506.07, exclusive of interest and costs. Respectfully Submitted, WEBER GALLAGHER SIMPSON S. ETON FI & NEWB-YLLP r By: Tr i L. McElhaney, quire CUiistopher P. Deeg Esquire CIounsel for Plaintiff VERIFIED STATEMENT I, Travis L. McElhaney, Esquire, being the attorney for plaintiff in the within action, am duly authorized to make this Verified Statement on its behalf, and make this Verified Statement due to the fact that plaintiff's Verified Statement cannot be obtained within the time limits necessary for filing this pleading, and I hereby verify that the statements set forth in the foregoing Complaint are true and correct to the best of my information and belief based upon knowledge obtained from plaintiff. I uciderstand that false statements made herein are subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsifications to authorities. Ja-vis LIMcElh y, Esquire Dated: ?? EUD-UFiCE OF THE PROTHONOTARY 2012 JAN -5 Ate 11--55 cUMBERLAND COOTY ?ENNSYLVANSR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL CIVIL DIVISION - ARBITRATION AUTOMOBILE INSURANCE COMPANY, No.: 11-8354 Civil Plaintiff, VS. PLAINTIFF'S PRAECIPE FOR DEFAULT JUDGMENT PURSUANT OLEKSANDR KOLBASIN and TO Pa.R.C.P. 1037(b) ANB LOGISTICS, INC., Filed on behalf of Plaintiff Defendants. Counsel of Record for this Party: Travis L. McElhaney, Esquire PA I.D. #204023 Christopher P. Deegan, Esquire PA I.D. #85635 WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY, LLP Firm #594 Two Gateway Center 14`h Floor Pittsburgh, PA 15222 Telephone: (412) 281-4541 Fax: (412) 281-4547 ark $ I to,'<L Pd C?? 301 toy ?N\aa- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Plaintiff, vs. OLEKSANDR KOLBASIN and ANB LOGISTICS, INC., Defendants. CIVIL DIVISION - ARBITRATION No.: 11-8354 Civil PLAINTIFF'S PRAECIPE FOR DEFAULT JUDGMENT PURSUANT TO PaJLC.P.1037(b) To the Prothonotary: Kindly enter judgment in favor of plaintiff State Farm Mutual Automobile Insurance Company and against defendant Oleksandr Kolbasin ONLY for failure to file an Answer or otherwise respond in the above-captioned action within twenty (20) days of the date of service of the Complaint, and assess plaintiff's damages against defendant in the amount of $2,506.07. I certify that a written notice of intention to file this praecipe was mailed to defendant after the default had occurred and at least ten (10) days before the date of the filing of this praecipe. A copy of this notice is attached. I further certify that the defendant is not in active military service. The undersigned verifies that the statements of fact in the Praecipe are true and correct and are made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsifications to authorities. Respectfully submitted, WEBER GALLAGHER SIMPSON STAPLETON FiRFc & NEWBY LLP,4 / -7 t Travis L. M Dated: 7' Z 11 Counsel for IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, CIVIL DIVISION - ARBITRATION No.: 11-8354 Civil Plaintiff, vs. OLEKSANDR KOLBASIN and ANB LOGISTICS, INC., Defendants. TO: Oleksandr Kolbasin 9646 Edgefield Roscoe, IL 61073 Date of Notice: December 15, 2011 IMPORTANT NOTICE 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Telephone: (800) 990-9108 WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY LLP Travis L. McElhaney, Esquire Counsel for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, CIVIL DIVISION - ARBITRATION No.: 11-8354 Civil Plaintiff, VS. OLEKSANDR KOLBASIN and ANB LOGISTICS, INC., Defendants. AFFIDAVIT OF NON MILITARY SERVICE The undersigned, being duly sworn, according to law, deposes and says that the Defendant (s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; That Defendant, Oleksandr Kolbasin, age unknown, has a place of residence at 9646 Edgefield, Roscoe, Illinois 61073. Trav L. McElh ey, quire Attorney for Plain Attorney I.D.# 204023 Two Gateway Center, Suite 1450 603 Stanwix Street Pittsburgh, PA 15222 Phone: (412) 281-4541 Sworn to and subscribed before me this tx day of December, 2011 A.D. Notary Public _ Y? "ANPA ,; h,otanes CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing Plaintiff's Praecipe for Default Judgment Pursuant to Pa.R.C.P. 1037(b)was served upon the following defendant by Certified U.S. Mail, postage prepaid, this ?7 r day of December, 2011, to the following: Oleksandr Kolbasin 9646 Edgefield Roscoe, IL 61073 Travis L. McElhane , Es uire Counsel for Plaintif IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Plaintiff, VS. OLEKSANDR KOLBASIN and ANB LOGISTICS, INC., Defendants. To: 01eksandr Kolbasin 9646 Edgefield Roscoe, IL 61073 CIVIL DIVISION - ARBITRATION No.: 11-8354 Civil 236 NOTICE NOTICE IS GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST YOU. David Buell Prothonotary IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: la is ---- /441 f A42 L. McElh y squire PA I.D. No.: 204 WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY LLP Two Gateway Center - Suite 1450 603 Stanwix Street Pittsburgh, PA 15222 (412) 281-4541 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL CIVIL DIVISION - ARBITRATION AUTOMOBILE INSURANCE COMPANY, No.: 11-8354 Civil _w :t" Plaintiff, -a E5 VS. PROOF OF SERVICE OLEKSANDR KOLBASIN and ANB LOGISTICS, INC., Filed on behalf of Plaintiff Defendants. Counsel of Record for this Party: Travis L. McElhaney, Esquire PA I.D. # 204023 Christopher P. Deegan, Esquire PA I.D. #85635 WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY, LLP Firm #594 Two Gateway Center 14th Floor Pittsburgh, PA 15222 (412) 281-4541 (412) 281-4547 fax IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, CIVIL DIVISION - ARBITRATION No.: 11-8354 Civil Plaintiff, VS. OLEKSANDR KOLBASIN and ANB LOGISTICS, INC., Defendants. PROOF OF SERVICE I, Travis L. McElhaney, Esquire, counsel for plaintiff in the above-captioned case, hereby certify that a copy of the Complaint was served upon defendant, ANB Logistics, Inc., by Certified Mail, Return Receipt Requested. A copy of the Return Receipt from such Certified Mailing, showing that the Complaint was delivered on January 12, 2012, is attached hereto as Exhibit "A". I also verify that the statements in this Proof of Service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A.§ 4904 relating to Unworn Falsification to Authorities. Respectfully submitted, Dated: 1 2e 1/1Z WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY LLP Travis L. McElhaney, Esquire Counsel for Plaintiff ¦ Complete items 1, 2, and 3. Also complete item 4 if Reebicted Delivery is desked. ¦ Print your name and address on the reverse so at we can return the card to you. ¦ AtWh this card to the hack of the mallplece, or the lka t N space pemtits. 1. Art` a Addressed to: ANB Lo9isfics, JnC . 4cnr Road Uni+ log a sip - Q ftent )C ? Addressee B. stewed by ( Printed Name) C. D to of livery ?f? I Z 2 D. Is de"y address different from ltem t O If YES, enter delivery address below: 0 No i //?? I ' I rrSendce Type Ito G ro V c j I ?. (600,59 Kcatilled Mail [i Registeted ? insured man 4. Restricted Delius 2. Article Number ?009 2820 0001 8192 (Tratrsl?rfigm se?vke Attu) Ps Form 3811, Pebruary 2004 Domestic Return Receipt 0 Express (Wail ,KPAkm Receipt for Merchandise 0 C.O.O. Y? P ft Fee) 0 Yes 9640 102595.02-M-1644 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Plaintiff, VS. OLEKSANDR KOLBASIN and ANB LOGISTICS, INC., Defendants. CIVIL DIVISION - ARBITRATI -+ -mr'1 r i __ No.: 11-8354 Civil > n -r Cn PLAINTIFF'S PRAECIPE FOR DEFAULT JUDGMENT PURSUANT TO Pa.R.C.P. 1037(b) To the Prothonotary: Kindly enter judgment in favor of plaintiff State Farm Mutual Automobile Insurance Company and against defendant ANB Logistics, Inc. ONLY for failure to file an Answer or otherwise respond in the above-captioned action within twenty (20) days of the date of service of the Complaint, and assess plaintiff's damages against defendant in the amount of $2,506.07. I certify that a written notice of intention to file this praecipe was mailed to defendant after the default had occurred and at least ten (10) days before the date of the filing of this praecipe. A copy of this notice is attached. I further certify that the defendant is not in active military service. The undersigned verifies that the statements of fact in the Praecipe are true and correct and are made subject to the penalties of 1.8 Pa.C.S.A. § 4904 relating to unsworn falsifications to authorities. Respectfully submitted, WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY LLP Travis L. McElhane squire V 41?? 77 ' '6^ Dated: Counsel for Plaintiff U S° Pa a U Ck-?3U3s? 14 J? 71 1Y.05 ov? ??Ua IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Plaintiff, vs. OLEKSANDR KOLBASIN and ANB LOGISTICS, INC., Defendants. TO: ANB Logistics, Inc. 113 McHenry Road, Unit 109 Buffalo Grove, IL 60089 Date of Notice: February 6, 2012 CIVIL DIVISION - ARBITRATION No.: 11-8354 Civil IMPORTANT NOTICE 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Telephone: (800) 990-9108 WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY LLP Travis L. McElhaney, Esquir Counsel for Plaintiff CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing Plaintiff's Praecipe for Default Judgment Pursuant to Pa.R.C.P. 1037(b) was served upon the following ? defendant by Certified U.S. Mail, postage prepaid, this'? _ day of February, 2012, to the following: ANB Logistics, Inc. 113 McHenry Road, Unit 109 Buffalo Grove, IL 60089 Tra s L. McElh y, squire Counsel for Plainti IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Plaintiff, VS. OLEKSANDR KOLBASIN and ANB LOGISTICS, INC., Defendants. To: ANB Logistics, Inc. 113 McHenry Road, Unit 109 Buffalo Grove, IL 60089 CIV IL DIVISION - ARBITRATION No.: 11-8354 Civil 236 NOTICE NOTICE IS GIVEN THAT A JUDGMENT IN THE AB VE CAPTIONED MATTER HAS BEEN ENTERED AGAINST YOU. David Buell Prothonotary IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: -- 014"'-h Travis L. McElhane , Es Lire PA I.D. No.: 204023 WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY LLP Two Gateway Center - Suite 1450 603 Stanwix Street Pittsburgh, PA 15222 (412) 281-4541 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY as subrogee of Scott Powers, Plaintiff, vs. OLEKSANDR KOLBASIN and ANB LOGISTICS, INC., Defendants. CIVIL DIVISION - ARBITRATION No.: 11-8354 Civil Term -+J t _ c c, ;> c < c. AFFIDAVIT I, Travis L. McElhaney, Esquire, do hereby certify that the judgment entered against the above named defendant, Oleksandr Kolbasin, was the result of a motor vehicle accident that occurred on or about October 13, 2011. I also verify that the statements in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A.§ 4904 relating to Unworn Falsification to Authorities. Date: J5 Travis L. McElhaney, squire PA I.D. No.: 204023 WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY LLP Two Gateway Center - Suite 1450 603 Stanwix Street Pittsburgh, PA 15222 (412) 281-4541 Sworn to and Su scribed before me this /-#6- day of Njay 2012 VAI H OT Pubi1c City of Pittsburgh, Alleghen County MY Commission Expires Feb. 11, 2013 Member, Pennsylvania Association of Notaries pvkk4' s'-1 SF? pV w 307? °`"`1 P, *o? 7N ? `I r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL CIVIL DIVISION AUTOMOBILE INSURANCE COMPANY, No.: 11-8354 Plaintiff, ` .: s PRAECIPE TO SATISFY JUDGMEPar-,, r= vs. Cl3?" OLEKSANDR KOLBASIN, Filed on behalf of Plaintiff Q - -. CZ) - Defendant. Counsel of Record for this Party: ' w Travis L. McElhaney, Esquire PA I.D. #204023 Christopher P. Deegan, Esquire PA I.D. #85635 WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY, LLP Firm #594 Two Gateway Center 141" Floor Pittsburgh, PA 15222 (412) 281-4541 (412) 281-4547 fax pl?sq.??. j2 I?-?1 too ? a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, CIVIL DIVISION No.: 11-8354 Plaintiff, vs. OLEKSANDR KOLBASIN, Defendant. PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly satisfy the judgment in the above captioned matter. Respectfully Submitted, WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY LLP By: Travis L. McElh a squire Christopher P. Deegan, Esquire Counsel for Plaintiff Dated S 7 ) Z