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Home My WebLink About12-1476PAUL F. D'EMILIO, ESQUIRE I'??S IS I?N ARBITRATION MATTER AIIU Nt 1. .1F10004 PAUL M SC OFIELD, JR., ESQUIRi= l?- M"`A 9: Z)IJ ATTORNEY I.D. #81894 CO t4 905W. SPROUL ROAD, SUITE 1051y[efNl??TORNEY FOR PLAINTIFF SPRINGFIELD, PA 19064 (610) 338-0338 ERIE INSURANCE EXCHANGE AS COMMON PLEAS COURT OF SUBROGEE OF BAU N. TRAN CUMBERLAND COUNTY P.O. BOX 2013 MECHANICSBURG, PA 17055 VS. NO. )61g-/V76 eivil CHANDRE SUMMERFORD 517 RITTENHOUSE SQUARE MECHANICSBURG, PA 17050 CIVIL ACTION NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE 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 NO FEE. Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 Lawyer Referral Service 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 AVISO Le han demandado a usted an la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene (20) dias de plazo a partir de la fecha de la demanda y la notificacion. Usted debe presenter una apariencia escrita o an persona o por abogado y archivar en la corte sus defensas o sus objeciones a las demandas encontra de su persona. Sea avisado qua si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion o por cualqier queja o alivio qua espedido an la peticion de demanda. Usted puede perder dinero, sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUACIENTE PARA PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITAABAJO PARAAVERIGUAR DONDE USTED PUEDE CONSEGUIR ASISTENCIA LEGAL. Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 Lawyer Referral Service 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 b atAl a )oy.?S 1 ?bk 187740 P-w ol 7a Ctj? PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFIELD, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 ERIE INSURANCE EXCHANGE AS SUBROGEE OF BAU N. TRAN P.O. BOX 2013 MECHANICSBURG, PA 17055 THIS IS ARBITRATION MATTER ATTORNEY FOR PLAINTIFF COMMON PLEAS COURT OF CUMBERLAND COUNTY VS. NO. CHANDRE SUMMERFORD 517 RITTENHOUSE SQUARE CIVIL ACTION MECHANICSBURG. PA 17050 NOTICE UNDER THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1601 (AS AMENDED) THE PENNSYLVANIA UNFAIR TRADE PRACTICES ACT AND CONSUMER PROTECTION LAW, 73 PA.CON.STAT.ANN. §201, ET. SEQ. ("THE ACTS") INASMUCH AS THE ACTS MAY APPLY, PLEASE BE ADVISED THAT THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE COMPLAINT The Plaintiff, Erie Insurance Exchange, by its attorney Paul F. D'Emilio, Esquire, bring this action upon a cause whereof the following is a statement: The Plaintiff, Erie Insurance Exchange, ("Plaintiff') is a Corporation authorized to do business in the Commonwealth of Pennsylvania, with an mailing address of P.O. Box 2013, Mechanicsburg, PA 17055. 2. Plaintiff brings this action as subrogee of Bau N. Tran (herein the "Insured") under a policy of insurance issued by Plaintiff and at all times hereinafter mentioned, Plaintiff's Insured is the real and registered owner of premises 100 Elicker Road, Monroe Township, Pennsylvania. 3. Defendant Chandre Summerford is a individual residing at 517 Rittenhouse Square, Mechanicsburg, PA 17050 and at all times hereinafter mentioned was a tenant or occupant of Plaintiff's Insured. 4. On or about July 2, 2010 the Defendant vacated the Insured's rental property and Plaintiff's Insured discovered water coming from the toilet which was stuffed with news papers and vandalism throughout the property. 5. Plaintiff avers that the personal property of the Insured was damaged as a result of the occurrence hereinbefore mentioned, the cost to repair the dwelling thereto being is Six Thousand Six Hundred Thirty Four and 26/100 ($6,634.26) plus the Insured's deductible of Two Thousand Five Hundred and 00/100 ($2,500.00) Dollars for a total of Nine Thousand One Hundred Thirty Four 26/100 ($9,134.26) Dollars. Count I Intentional Acts 6. Plaintiff, incorporates by reference all of the allegations contained in paragraphs 1 through 5 inclusive of this Complaint as fully as though same were herein and set forth at length. 7. At all times herein mentioned, Defendant acted intentionally, consciously, deliberately and with malice toward Plaintiffs insured. 8. At all times herein mentioned, Defendant acted intentionally, carelessly, and recklessly. 9. As a direct and proximate result of the conduct of the Defendant Plaintiffs insured sustained damages and incurred the above expenses. Count II Negligence 10. Plaintiff incorporates by reference all of the allegations contained in paragraphs 1 through 9 inclusive of this Complaint as fully as though same were herein and set forth at length. 11. The said occurrence was due to the negligence of the Defendant in that she: a. did vandalized Plaintiff's Insured's property without due regard for the rights, and safety of the insured's property, and b. did violate the various statutes and laws Commonwealth of Pennsylvania of the County of Cumberland regarding the treatment and security and safety of the Insured's property. 12. As a direct and proximate result of the conduct of the Defendants, Plaintiffs insured sustained damages and incurred the above expenses. WHEREFORE, Plaintiff demands judgment against the Defendants on each Count in an amount not in excess of Fifty Thousand and 00/100 ($50,000.00) dollars together with costs of suit. Date: Paul F. D' iYbEt'qu r re Identificatio 0.:16654 e-mail address: pauld@demiliolaw.com Paul M. Schofield, Jr., Esquire Identification No.: 81894 e-mail address: pauls@demiliolaw.com 905 W. Sproul Road, Suite 105 Springfield, PA 19064 Telephone No.: 610-338-0338 Fax No.: 610-338-0303 ti VERIFICATION utrti u S,647 , Subrogation Specialist with State Farm Fire and Casualty Company in the above captioned matter verifies that the facts contained in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: ZIU1iZ Subrogation Specialist Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY _tI- ILED ijr, tl!' Its llllllllj ,? .rA i NE F F, L0 i HOUNOT,;" ' t` 12 LIAR 16 AM 8: 45 C!. MBERLAt D L0U? 1 `!` PEN,11SYLVANIA Erie Insurance Exchange vs Case Number . Chandre Summerford 2012-1476 SHERIFF'S RETURN OF SERVICE 03/12/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Chandre Summerford, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Chandre Summerford. Request for service at 517 Rittenhouse Square, Mechanicsburg, Pennsylvania 17050 the Defendant was not found. Current occupant advised Deputies, they have resided at this address since 2010 and do not know the Defendant. SHERIFF COST: $43.00 SO ANSWERS, March 12, 2012 RON R ANDERSON, SHERIFF PAUL F. D'EMILIO, ESQUIRE 1,IS ARBITRATION MATTER ATTORNEY I.D. #16654 PAUL M. SCHOFIELD, JR., E UI 3 U, I ! ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE II'QBERLA10 COUVa T ATTORNEY FOR PLAINTIFF SPRINGFIELD, PA 19064 t:1EjWgSYL'VAN1A (610) 338-0338 ERIE INSURANCE EXCHANGE AS COMMON PLEAS COURT OF SUBROGEE OF BAU N. TRAN CUMBERLAND COUNTY P.O. BOX 2013 MECHANICSBURG, PA 17055 VS. NO. 12-1476 Civil CHANDRE SUMMERFORD 517 RITTENHOUSE SQUARE CIVIL ACTION MECHANICSBURG PA 17050 PRAECIPE TO REINSTATE THE COMPLAINT TO THE PROTHONOTARY, C.P.: Kindly reinstate the Complaint in the above-captioned NEY FOR PLAINTIFF Otuu? '? ? ? ? S ?1 ° C?? 14 ? 9a SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor # tV Of Cu1ubet.4t ry A '`fat orrice OF -r E Z?-ERIFr F !L. D-OFFiCz THE PfZ0TH0nCTAr..,,, 12 "A Y 22 AN 9.08 CUMBERLAND CoUNFY PENNSYLVANIA Erie Insurance Exchange VS. Chandra Summerford Case Number 2012-1476 SHERIFF'S RETURN OF SERVICE 05/17!2012 Ronny R. Anderson, Sheriff, who being duly swom according to law, states that he made a diligent search and inquiry for the within named defendant to wk: Chandra Surrsrwlbrd, but was unable to locate her in his baftick. He therefore returns the within Complaint and Notice as not found as to the defendant Chandra Surnmerford. Request for service at 100 Elicker Road, Apartment C, Care, Pennsylvania 17015 was vacant. The Carlisle Postmaster has confirmed, Chandra Summerford has moved and left no forwarding address. SHERIFF COST: $36.50 May 18, 2012 SO ANSWERS, RON ` R ANDERSON, SHERIFF (c) Ccunty5uite Sheriff, Teleosoft, Inc. PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFIELD, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 7 THIS IS ARBITRATION MATTER ATTORNEY FOR PLAINTIFF ERIE INSURANCE EXCHANGE AS COMMON PLEAS COURT OF SUBROGEE OF BAU N TRAN . CUMBERLAND COUNTY P.O. BOX 2013 MECHANICSBURG, PA 17055 C-) ; a VS. NO. 12-1476 Civil O CHANDRE SUMMERFORD P e- r-- 517 RITTENHOUSE SQUARE CIVIL ACTION MECHANICSBURG PA 17050 I M cszi PRAECIPE TO DISCONTINUE AND END Cn rri M TO THE PROTHONOTARY, P.C.: Kindly mark the above entitled matter discontinued and ended upon payment of your cost only. Paul ilio, Esquire Atto ly for Plaintiff