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Home My WebLink About04-4641Benjamin D. Andreozzi, Esquire Goldberg Katzman, P,C. PO Box 1268 Harrisburg, PA 17108-1268 717-234-4161 Attorneys for Plaintiff ERIE INSURANCE GROUP a/s/o ROGER L. MYERS, Plaintiff NORMAN LIVINGSTON, Defendant. : : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA. 6q - qt,.qt : : CIVIL ACTION - LAW NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the daims set forth in the following paged, 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 daims set forth against you. You are warned that if you fad 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 HF.I.P. Cumberland County Lawyer Referral Service Cumberland County Bar Association Carlisle, PA 17013 5717) 232-7536 Benjamin D. Andreozzi, Esquire Goldberg Katzman, P.C. PO Box 1268 Harrisburg, PA 17108-1268 717-234-4161 Attorneys for Plaintiff ERIE INSURANCE GROUP a/s/o ROGER L. MYERS, Plaintiff NORMAN LIVINGSTON, Defendant. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA. : :NO. : : CIVIL ACTION - LAW . NOTICIA Le has demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguintes, useted tiene viente (20) dias de plaza al partir de las fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o pot abogado y archivar en la cot're en forma escrita sus defensas o sus objectiones a las demandas en contra de su persona. Sea adisado que si usted no se defiende, la sin previo aviso o notificacion y pot cualquier quja o puede petder dinero o sus propiendades o otros derechos importantes para usted. LLEVE ESTADEMANDAAUN ABOGADO IMMF]DIATAMF, NTE. SINO TIENE ABOGADO O SI NO TIENE EL DINERO SUGICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O IJ./kM~ POR TELEFONO A LA OPICINA CUYA DIRECCI9ON SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEQUIR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Cumberland County Bar Association Carlisle, PA 17013 (717') 232-7536 Benjamin D. Andteozzi, Esquire Goldberg Katzrmn, P.C. PO Box 1268 Harrisburg, PA 17108-1268 717-234-4161 Attorneys for Plaintiff ERIE INSURANCE GROUP a/s/o ROGER L. MYERS, Plaintiff NORMAN LIVINGSTON, Defendant. : : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA : NO. - Go : CIVIL ACTION - LAW COMPLAINT AND NOW, comes the Plaintiff, Erie Insurance Exchange, by its counsel, Goldberg Katzman, P.C. who states: 1. Plaintiff Erie Insurance Exchange is a business entity authorized to issue policies of insumce within the Commonwealth of Pennsylvania, with an address of 4901 Louise Drive, P.O. Box 2013, Mechanicsburg, Pennsylvania, 17055-0710. 2. At all times relevant hereto, Plaintiff Erie Insurance Exchange provided insurance for the vehicle owned by Roger L. Myers. 3. To all belief and knowledge, Defendant is an adult individual who resides at 2503 Heidlersburg Road, Gettysburg, Pennsylvania 17325. 4. Plaintiff's insured, Roger L. Myers and Defendant were involved in an automobile accident on June 23, 2003, just outside of Carlisle, Pennsylvania, where Walnut Bottom Road meets Montsera Road and Old York Road. 5. Moments before impact, Defendant moved his vehicle forward from a stop sign on Montsera Road and into the direct lane of travel of oncoming Walnut Bottom Road traffic. Accordingly, Plaintiff, who was operating his vehicle eastbound on Walnut Bottom, was forced to collide with Defendant's vehicle which had unexpectedly pulled directly into his lane of travel. 6. Defendant's actions were negligent in that he: a. Failed to keep a proper lookout; b. Failed to yield the fight-of-way; c. Allowed his vehicle to be in the direct lane of travel of oncoming traffic; and d. Was otherwise negligent in the operation of his vehicle as may be discovered in future litigation of this matter. 7. Defendant's negligence was the sole and proximate cause of the damages to the vehicle owned by Plaintiff's insured, Roger L. Myers. WHEREFORE, Plaintiff, Efie Insurance Exchange, respectfully requests judgment in its favor in the amount of $2,465.64, thereby submitting this matter to compulsory arbitration. 2 4. Plaintiff's insured, Roger L. Myers and Defendant were involved in an automobile accident on June 23, 2003, just outside of Carlisle, Pennsylvania, where Walnut Bottom Road meets Montsera Road and Old York Road. 5. Moments before impact, Defendant moved his vehicle forward from a stop sign on Montsera Road and into the direct lane of travel of oncoming Walnut Bottom Road traffic. Accordingly, Plaintiff, who was operating his vehicle eastbound on Walnut Bottom, was forced to collide with Defendant's vehicle which had unexpectedly pulled directly into his lane of travel. 6. Defendant's actions were negligent in that he: a. Failed to keep a proper lookout; b. Failed to yield the tight-of-way; c. Allowed his vehicle to be in the direct lane of travel of oncoming traffic; and d. Was otherwise negligent in the operation of his vehicle as may be discovered in future litigation of this matter. 7. Defendant's negligence was the sole and proximate cause of the damages to the vehicle owned by Plaintiff's insured, Roger L. Myers. WHEREFORE, Plaintiff, Erie Insurance Group, respectfully requests judgment in its favor in the amount of $2,465.64, thereby submitting this matter to compulsory arbitration. 2 Date: September i~, 2004 GOLDBERGKATZMAN, P.C. Attorney ID PO Box 1268/ // Harrisburg P1~17108-1268 717-234-4161 Attomeys for Plaintiff VERIFICATION I, ~l/~~ . hereby acknowledge that I am and authorized representative o retie Insurance Exchange the Plaintiffin this action; that I have read the foregoing Complaint, and that the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa.C.S. ~ 4904, relating to unswom falsification to authorities. Date: ERIE INSURANCE EXCHANGE By: HARRISBURG CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a tree and correct copy of the foregoing document upon all counsel of record by depositing the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: Norman Livingston 2503 Heidlersburg Road Gettysburg, PA 17325 Date: September 14, 2004 By: GOLDBERG KATZMAN, P.C. ~Andreozzi, Esquire Benjamin D. Andreozzi, Esquire Goldberg Katzman, P.C. PO Box 1268 Harrisburg, PA 17108-1268 717-234-4161 Attorneys for Plaintiff ERIE INSURANCE GROUP a/s/o ROGER L. MYERS, Plaintiff V0 NORMAN LIVINGSTON, Defendant· · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PA · NO. 04-4641. · CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: Please reinstate the Complaint in By: this matter for service upon the defendant· GOLDBE, RG I~"1TZMAN, P.C. Benjarfifn D./(kndr/e/o .zzi, Esquire Attorney I 1J~?.JO~f271 PO Box 1268 Harrisburg, PA 17108-1268 717-234-4161 Attorneys for Plaintiff Date: December 17, 2004 116929.1 Douglas C. Lovelace, Jr., Esquire Attorney Identification Number: 83889 36 Donegal Drive Carlisle, PA 17013 (717)245-4089 Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYL VANIA ERIE INSURANCE GROUP als/o ROGER 1. MYERS, v. : CIVIL ACTION - IN LAW NORMAN LIVINGSTON, Defendant NO. 04-4641 PRAECIPE TO ENTER APPEARA~ To The Prothonotary: Please enter my appearance as attorney for NORMAN LIVINGSTON, Defendant in the above captioned matter. Date: January 18,2005 {;)~~ ~tI~ DOUGLAS C. LOVELACE, JR., Esquire Attorney Identification Number: 83889 36 Donegal Drive Carlisle, P A 17013 (717) 245-4089 :~! c,-, c;, Douglas C. Lovelace, Jr., Esquire Attorney Identification Number: 83889 36 Donegal Drive Carlisle, P A 17013 (717)245-4089 ERIE INSURANCE GROUP alslo ROGER L. MYERS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA v. : CIVIL ACTION - IN LAW NORMAN LIVINGSTON, Defendant NO. 04-4641 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 counterclaim 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 counterclaim or for any other claim or relief requested by the counterclaim plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 ~rr~lI. DOUGLAS C. LOVELACE, JR., Esquire Attorney Identification Number: 83889 36 Donegal Drive Carlisle, PA 17013 (717)245-4089 Douglas C. Lovelace, Jr., Esquire Attorney Identification Number: 83889 36 Donegal Drive Carlisle, PA 17013 (717)245-4089 ERIE INSURANCE GROUP aJsJo ROGER 1. MYERS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA v. : CIVIL ACTION - IN LAW NORMAN LIVINGSTON, Defendant NO. 04-4641 NOTICIA LE RAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas dernandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe pr1esentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defenses 0 sus objections a las demandas en contra de su persona. Sea avisado que si ust(:d no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivo que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedadas 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE P AGAR TAL SERVICIO, VA Y A UN PERSONA 0 LLAME POR TELEPHONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PENNSYL V MilA 17013 (717) 249-3166 ~tf?~/~ DOUGLAS C. LOVELACE, JR., Esquire Attorney Identification Number: 83889 36 Donegal Drive Carlisle, PA 17013 (717)245-4089 Douglas C. Lovelace, Jr., Esquire Attorney Identification Number: 83889 36 Donegal Drive Carlisle, PA 17013 (717)245-4089 ERIE INSURANCE GROUP alslo ROGER L. MYERS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA v. CIVIL ACTION - IN LAW NORMAN LIVINGSTON, Defendant NO. 04-4641 ANSWER. NEW MATTER. AND COUNTERCLAIM AND NOW, January 18, 2005, Norman Livingston, by his attorney, Douglas C. Lovelace, Jr., files this Answer, New Matter, and Counterclaim and avers as follows: Answer 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted in part and denied in part. By way of further answer, the Defendant admits he and the Plaintiff's insured were involved in an automobile accident on June 23, 2003; however, the Defendant avers the accident occurred at the: intersection of State Roads 465 and 174. 5. Denied. The Defendant was stopped in the proper lane of traffic, at the stop sign on State Road 174 where it intersects with State Road 465 when Plaintiff's insured carelessly operated his automobile so as to collide with Defendant's automobile. By way offurther answer, the Defendant did not pull his automobile forward from where he had stopped it at the stop sign at any time before the automobile operated by the Plaintiff's insured crashed into the Defendant's automobile. 6. Denied. The averments of paragraph 6 appear to set forth conclusions of law or facts to which no further response is required or appropriate. In the event and to any extent any of the averments are not found to be a conclusion oflaw or fact, it is averred that the Defendant was in no way negligent and proof to the contrary is demanded, if relevant. By way of further answer: a. the Defendant kept a proper lookout and was aware of all traffic at the time and observed the automobile operated by the Plaintiff's insured approach the intersection at a high rate of speed and the Plaintiff's insured suddenly attempt an unsuccessful right turn to continue fOllowing State Road 174; b. the Defendant was stopped at the stop sign to yield right of way, as appropriate; c. at no time befure the Plaintiff's insured operated his automobile so as to crash into the Defendant's automobile did the Defendant proceed into the intersection and in no way did he position his automobile into a proper lane of travel for oncoming traffic; and d. the Defendant was in no way negligent in the operation of his automobile. 7. Denied. The averments of paragraph 7 appear to set forth a conclusion of law or fact to which no further response is required or appropriate. In the event and to any extent any of the averments are not found to be a conclusion of law or fact, it is averred that the Defendant was in no way negligent and proof to the contrary is demanded if relevant. 2 New Matter 8. The Defendant incorporates herein by reference the averments contained in paragraphs 1 through 7, inclusive, of the Defendant's Answer as fully as though the same were set forth herein at length. 9. The Plaintiff's insured operated his automobile negligently in attempting to make an abrupt, last-minute right turn at the intersection of State Roads 174 and 465 in that he: a. carelessly, negligently, and/or recklessly maneuvered his automobile into the lane of oncoming traffic, failed to operate his automobile in the right lane of traffic, crossed into the Defendant's lane of traffic, and crashed his automobile: into the Defendant's stopped automobile; b. operated his automobile in disregard of the rules of the road and the laws of the Commonwealth of Pennsylvania; c. failed to keep the proper lookout; d. failed to ensure the way was clear befofl~ operating his automobile into the lane of oncoming traffic; e. operated his automobile with no warning of intended direction; f. failed to see what he should have seen; g. failed to notice the motor vehicle of the Defendant, even though the Defendant's automobile was stopped at a stop sign and its turn signal was flashing; h. failed to adequately observe and assess the traffic conditions then and there existing; i. failed to notice the imminence of an acc:ident and to take the necessary steps to avoid the same; 3 J. failed to take evasive action to avoid impacting with the Defendant's automobile; k. failed to apply his brakes in time to avoid colliding with the Defendant's automobile; I. operated his automobile at an excessively high rate of speed for the maneuver he attempted; m. failed to use due care under the circumstances; n. operated his motor vehicle without due regard for the safety, position, and rights of the Defendant; and o. such other acts or omissions as may he revealed in the course of discovery or at the trial of this case. 10. The Plaintiff fails to state a cause of action for negligence. Counterclaim 11. The Defendant incorporates herein by reference the averments contained in paragraphs 1 through 10, inclusive, of the defendant's Answer and New Matter as fully as though the same were set forth herein at length. 12. The Defendant stopped his automobile at a stop sign facing generally northwest on State Road 174 where it intersects with State Road 465 and Walnut Bottom Road. 13. While stopped in his automobile, the Defendlmt observed the Plaintiff's insured approaching the intersection from the southwest at a high rate of speed, as ifhe intended to continue straight ahead on Walnut Bottom Road and State Road 465. 14. Defendant observed the Plaintiff's insured abruptly turn right so as to continue on State Road 174, without the use of a turn signal. 4 .. 15. The Plaintiff's insured was operating his automobile at too high a rate of speed to successfully execute the last-minute turn, swung wide into the oncoming lane of traffic, and caused his automobile to crash into the Defendant's automobile. 16. The Plaintiff's insured operated his automobile: negligently in attempting to make an abrupt, last-minute right turn at the intersection of State Roads 174 and 465 in that he: a. carelessly, negligently, and/or recklessly maneuvered his automobile into the lane of oncoming traffic, failed to operate his automobile in the right lane of traffic, crossed into the Defendant's lane of traffic, and crashed his automobile into the Defendant's stopped automobile; b. operated his automobile in disregard of the rules of the road and the laws of the Commonwealth of Pennsylvania; c. failed to keep the proper lookout; d. failed to ensure the way was clear before: operating his automobile into the lane of oncoming traffic; e. operated his automobile with no warning of intended direction; f. failed to see what he should have seen; g. failed to notice the motor vehicle of the Defendant, even though the Defendant's automobile was stopped at a stop sign and its turn signal was flashing; h. failed to adequately observe and assess the traffic conditions then and there existing; 1. failed to notice the imminence of an accident and to take the necessary steps to avoid the same; J. failed to take evasive action to avoid impacting with the Defendant's 5 automobile; k. failed to apply his brakes in time to avoid colliding with the Defendant's automobile; 1. operated his automobile at an excessively high rate of speed for the maneuver he attempted; m. failed to use due care under the circumstances; n. operated his motor vehicle without due regard for the safety, position, and rights of the Defendant; and o. such other acts or omissions as may be r,evealed in the course of discovery or at the trial of this case. 17. The Plaintiff's insured's negligence was the sole and proximate cause of the damages to the Defendant's automobile. 18. As a consequence of the Plaintiff's insured's negligence, the Defendant suffered $2,100.00 damage to his automobile. WHEREFORE, the defendant respectfully requests that this Honorable Court enter judgment in his favor in the amount of $2, I 00.00 on his Counterclaim and against the Plaintiff on the Complaint, for a total amount that is less than the compulsory arbitration ceiling. ~.r'~(/, Douglas C. Lovelace, Jr., Esquire Attorney for Defendant Attorney Identification Number: 83889 36 Donegal Drive Carlisle, PA 17013 (717)245-4089 6 .' VERIFICATION Norman Livingston hereby states that he is the DeJi~ndant in this action and that the statements offact made in the foregoing Defendant's Answer, New Matter, and Counterclaim are true and correct to the best of his personal knowledge, information, and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa. C.S.A. ~ 4904 relating to unsworn falsification to authorities. Date: January 18,2005 , '" {}j~~ ~o::' ~.~ Norman Livingston ~ CERTIFICATE OF SERVICE I, Douglas C. Lovelace, Jr., attorney for Defendant, Norman Livingston, hereby certifY that on January 18,2005, I served a true and correct copy of the foregoing Defendant's Answer, New Matter, and Counterclaim upon the following below named individual by depositing the same in the United States mail, first class, postage prepaid,. at Carlisle, Cumberland County, Pennsylvania. SERVED UPON: Benjamin D. Andreozzi, Esquire Goldberg Katzman, P.C. P.O. Box 1268 Harrisburg, Pennsylvania 17108-1268 Attorney for Plaintiff LJ~fGtf, Douglas C. Lovelace, Jr., Esquire Attorney Identification Number: 83889 36 Donegal Drive Carlisle, PA 17013 (717)245-4089 , '.,:1 C ..-1 c~, ERIE INSURANCE GROUP a/s/o ROGER L. MYERS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUN1Y, P A v. : NO. 04-4641 NORMAN LIVINGSTON, : CIVIL ACTION - LAW Defendant. PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please mark the above-captioned matter settled and discontinued. GOLDBERG KATZMAN, P.e. t / Date: ~J7ID ~ By: Benjamin D. An eozzi, Esquire Attorney # 271 PO Box 1268 Harrisburg, PA 17108-1268 717-234-.4161 Attorneys for Plaintiff ~t'@rt/, Douglas e. Lovelace, Jr., Esquire 26 Donegal Drive Carlisle, P A 17013 Attorney for Defendant Date: 118262.1 ... ,~ f'~ ~ ;"1 I \.L SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04641 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ERIE INSURANCE GROUP VS LIVINGSTON NORMAN R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: LIVINGSTON NORMAN but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of ADAMS County, Pennsylvania, to serve the within COMPLAINT & NOTICE On December 30th, 2004 , this office was in receipt of the attached return from ADAMS Sheriff's Costs: Docketing Out of County Surcharge Dep Adams County 18.00 9.00 10.00 25.48 .00 62.48 12/30/2004 GOLDBERG KATZMAN So answer:?r .., ..' .~<<.</~ /~~~ R. homas Kline Sheriff of Cumberland County Sworn and subscribed to before /"} this f.. "':. day of ~ ~ ~i)()5 A.D. ~12~/~ Prothonotary me In Tbe Court of Common Plea.s of Cumberland County, Pennsylvania Erie Insurance Group VS. NaIman Livingston No. 04-4641 civil December 22, 2004 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do Now, hereby deputize the Sheriff of Adams County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~" ~~,.? 6. ,",..,j-' ,.,.;.' ___ ~ '"" nF'~~:>~' .-!; ~ ~_ ~,.,_.:'11;':'~,~ -;t' ..../"..,---.......'7 r -<Or ~"~.,,,........-.- '.- Sheriff of Cumberland County, PA Affidavit of Service Now, December 27 , 20~, at 5:50 o'clock P. M. served the within Reinstated Complaint in Civil Action upon Norman Livingston at 2503 Heidlersburg Road, Gettysburg, PA by handing to him a true and attested copy of the original complaint and made lrnown to him the contents thereof. ~ Adams County, PA Sworn and subscribed before methis_dayof N/A ,20_ COSTS SERVICE MILEAGE AFFIDAVIT $ 18.00 7.48 $25.48 R:l. J2/28/0< ~ ~ \.f"-.. ; ",J_j .: ! , ._-;-";~:..., ,..) o c: :;:1 c:I L Z IJO ~JQZ ,. -'~ ':1 " '. > .~.j ',J SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04641 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ERIE INSURANCE GROUP VS LIVINGSTON NORMAN R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: LIVINGSTON NORMAN but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of ADAMS County, Pennsylvania, to serve the within COMPLAINT & NOTICE On December 30th, 2004 , this office was in receipt of the attached return from ADAMS Sheriff's Costs: Docketing Out of County Surcharge Dep Adams County 18.00 9.00 10.00 25.48 .00 62.48 12/30/2004 GOLDBERG KATZMAN So ~.~ ->---- ~- - ---.-,"- ---,..-/,~~-::<:: .~. L:- R. homas Kline Sheriff of Cumberland County Sworn and subscribed to before this ,~ day of ~ ~ ;J()fJ0 A. D. ~12~~/~ Prothonotary me In The Court of Common Pleas of Cumberland County, Pennsylvania Erie Insurance Group VS. Norman Livingston No. 04-4641 civil December 22, 2004 Now, , T, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Adams County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ,~?' /~. ~~~~- ,- ~~~~~~. ~r ,;"......~~__d~., <l"'4~~'::.-:'::~R Sheriff of Cumberland County, PA Affidavit of Service Now, December 27 , 20~, at 6:50 o'clock P. M. served the within Reinstated Complaint in Civil Action upon Norman Livingston at 2503 Heidlersburg Road, Gettysburg, PA by handing to him a true and attested copy of the original complaint and made lmown to him the contents thereof. ~ Adams County, PA Sworn and subscribed before methis_dayof N/A ,20_ COSTS SERVICE MILEAGE AFFIDA VIT $ 18.00 7.48 $25.48 Ri. 12/28/04 . j ,-".1 !" ..., _-1 ~~, ~.:., "~ 0':" :(:1 d L7 ~JO '"01 ..... ,J,:.l! li.JIL _". I' .~, -