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Home My WebLink About02-0489 .... v ORIGINAL Joseph G, Muzic, Jr., Esquire NIKOLAUS & HOHENADEL, LLP 2 I 2 North Queen Street Lancaster, P A 17603 (717)299-3726 FAX (717)299-1811 E-mail: jmuzic@nikolaushohenadel.com Attorney LD, No: 55919 Attorney for Plaintiff DANIELLE M. ARNSPERGER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVIL DIVISION - LAW vs, GREGORY A RADER, Defendant No, 02-00489 PRAECIPE FOR ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against Defendant, Gregory A, Rader, in the amount of $12,865.75 for failure to file an Answer to Plaintiffs Complaint, pursuant to Pa. R.C.P, No. 236 and Pa. R,C.P, No, 237.1. A copy o/the Important Notice and Certification is attached hereto, Respectfully submitted, NIKOLAUS & HOHENADEL, LLP \ I I By:-A Jos#h G. Muzic, Jr., Esquire Date: f 'i / ~ . ... , , EXHIBIT "A" . '. ".. '" tf"""OP'" :\:,P"..' ./ Joseph G, Muzic, Jr., Esquire NIKOLAUS & HOHENADEL, LLP 212 N onh Queen Street Lancaster, P A 17603 (717) 299-3726 FAX (717) 299-1811 E-mail: jmuzic@nikolaushohenadeLcom Attorney LD, No: 55919 Attorney for Plaintiff DANlELLE M. ARNSPERGER Plaintiff vs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVIL DMSION - LAW GREGORY A. RADER, Defendant No, 02-00489 IMPORTANT NOTICE YOU ARE IN DEF AUL T BECAUSE YOU HAVE F AlLED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTO&'ffiY 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 JUDGlVIENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORT ANT RIGHTS. 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 INFO&"v1ATION 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, Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania (717) 249-3166 NIKOLAUS & HOHENADEL, LLP Date: Q/)7/o1- I , JO~",," k, E"l'"" BY: II>- . EXHIBIT "B" .. Joseph G, Muzic, Jr., Esquire NIKOLAUS & HOHENADEL, LLP 2 I 2 North Queen Street Lancaster, PAl 7603 (717)299-3726 FAX (717)299-1811 E-mail: jmuzic@nikolaushohenadeLcom Attorney LD, No: 55919 Attorney for Plaintiff DANIELLE M. ARNSPERGER Plaintiff vs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVIL DIVISION - LAW GREGORY A. RADER, Defendant No, 02-00489 CERTIFICATE I, Joseph G, Muzic, Jr., Esquire, hereby certify that Defendant Gregory A. Rader, was served with an Important Notice/Default Notice by first-class mail, postage prepaid on the date set forth to his last known address of: Gregory A. Rader 4 Hillcrest Drive Mechanicsburg, PA 17055 NIKOLAUS & HOHENADEL, LLP ,) BY: i, J'\,. Josep,K G, Muzic, Jr., Esquire Date: 9/27/04 p p ~ c ,- '.> \- ..0 ,\ ~ _...~ 9- () - 0 ~ ~ " .. -J -J. ')- - - r- ~ -.(,j ~ .,... -!:: b ~ ~ +- ,- . ~ 'f- --L.. ORIGINAL Office oj'Prothonotary of Court of Common Pleas of Cumberland County, Pennsylvania NOTICE OF ENTRY OF JUDGMI<:NT Danielle M, Amsperger No: 02-489 Civil Term v, Gregory A. Rader TO: Defendant Gregory A. Rader Pursuant to requirements of the Pennsylvania Rules of Civil Procedure, Rule No. 236, you are notified that there was entered in this office today, in the above-captioned case: Judgment in the amount of $12,865.75 for Plaintiff and against Defendant. BY THE PROTHONOTARY: Dated:0.E:c I "II lMS o 4 I . , , CMJ:(jf > Joseph G, Muzic, Jr" Esquire NIKOLAUS & HOHENADEL, LLP 212 North Queen Street Lancaster, PA 17603 (717) 299-3726 FAX (717)299-1811 E-mail: jmuzic@nikolaushohenadeLcom Attorney ID, No: 55919 Attorney for Plaintiff vs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVIL DIVISION - LAW DANlELLE M. ARNSPERGER Plaintiff GREGORY A. RADER, Defendant No, 02-00489 PROOF OF SERVICE TO THE PROTHONOTARY: Pursuant to an Order entered August 27, 2004 regarding service upon the Defendant, it is hereby submitted that Plaintiff, by and through her counsel, has served Defendant Gregory A. Rader, by (1) Publication in the Cumberland Law Journal and iin The Sentinel, a newspaper of general circulation in Cumberland County (proof attached as Exhibit "A"), and (2) by first-class mail to Defendant's last known address of 4 Hillcrest Drive, Mechanicsburg, Pa" 17055 (proof attached as Exhibit "B"), Respectfully submitted, NIKOLAUS & HOHENADEL, LLP BY: qG.Mu."J'.._ Date: q/dj/O<! I / EXIDBIT A PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), p, L1784 STATE OF PENNSYLVANIA : SS. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2,1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz SEPTEMBER 17,2004 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter ofthe aforesaid notice or advertisernent, and that all allegations in the foregoing statements as to time, place and character of publication are true. TO AND SUBSCRIBED before me this day of SEPTEMBER. 2004 ~. t ~...).,J' NOTA IAL SEAL LOIS E SNYDER, Notary Public Carlisle Bora, Cumbe~and County My Commission Expires March 5, 2005 > - CUMBERLAND LAW JOURNAL SERVICE OF COMPLAINT NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law No.: 02-489 Civil Term Danielle M. Arnsperger, Plaintiff v. Gregory A. Rader, Defendant NOTICE TO: GREGORY A RADER, DEFEN- DANT You are hereby notified that Plain- tiff, Danielle M. Arnsperger filed a Civil Action Complaint endorsed with a Notice to Defend against you for property damage resulting from a motor vehicle accident on or about February 27, 2000, while Plaintiffs vehicle was parked on North Front Street in Wormleysburg Borough, Cumberland County, Pennsylvania. You are hereby notified to plead to the above referenced Complaint on or before twenty (201 days from the date of this publication or a Judg- ment will be entered against you. If you wish to defend, you must enter a written appearance person- ally or by attorney and file your de- fenses or objections in writing with the court. You are warned that if you fail to do so the case may pro+ ceed without you and a Judgment may be entered against you without further notice for the relief re+ quested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS NO- TICE TO YOUR lAWYER AT ONCE. IF YOU DO NOT HAVE A lAWYER, GO TO OR TELEPHONE THE OF- FICE SET FORTH BELOW. THIS OFFICE CAN PFtOVlDE 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 LE- GAL SERVICES TO ELIGIBLE PER- SONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Uberty Avenue Carlisle, PA (717) 249-3166 JOSEPH G.\IUZIC, JR, ESQUIRE NIKOlAUS & HOHENADEL, LLP Attorneys for Plaintiff 212 N. Queen Street Lancaster, PA 17603 (717) 299..3726 Sept 17 3 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Tammy Shoemaker, Customer Care/Sales Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following date(s) September 04, 2004 COPY OF NOTICE OF PUBLICATION ~.'" .",'c~ Of" " ' ._YLYAIlIA -uw No, <l2~ CML TERM , -~'1l"r"PIaIntIII ,;,., ::',.:NJ,y. ,'-, G1wgoiJ'A'.'IlotIw,_, ',.. ..~ ,... IIpDllI TO: GRE!iORY ~~.,DEFENDAI'jT YOU_-""~"'t'S;M, . Arntjl8rgerWaCMl~~", ~, -", . tr.::., tiE, 11, .,.....,' : AIIIi\laiJ~2lIdf..' '..' _....~ OItNo/l!1Front....,.!I'~!!'"bU'll_uglr. " CU__Iloumy,~,".,.,_nla, YOU~=""Ih.Bl>oVa"ronced =t_~~~ '. ,.'~o ~~\VfJt~ you. " ' , , ' "" ,- ::":~:!"'~;,~':hX,,:,:-,.Y_:",",::,t:;:\} ~~ Plaintiff. You may Iose,money orpropei1y or rights imj)ortanllO you. ' ~=-~,~t,~~~s~~ l'ORTHIlEI.OW. THSOIiFICECAHPfIOWlE YOU WITH INFORMATIOtlABOOT ....GlALAWW;F1, IF YOO CA!INOT Al'FQRQ A LA_Ill, TMIlUlFFICE MA V, BE, -.ri,lO,f'fIliM..'. , ,,',.. '''',r' INFOIlMrATIOlI_AG ,'liIill[~i,.r. OF/!EFI llIlIWlm;S'PE\WllMl' ATAR~'FEE,ClFINOFEE," . Cumberlond l;j)unty Bar Assocfatk!n ,.,~ "," .' Affiant further deposes that he/ she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of :I:~~ Sworn to and subscribed before me this 08th day of September. 2004 ~r-d.-I rl') tJu <] J Notary Public My commission expires: .lJ, 1("-",'7 Notarial Seal , Cyndi ,M. W"ighl. NotaJy Public SIlver Sprtn, '!\vI',. Cumberland County My Commission iExpires Apr. J5, 2001 Member, Penney'v""i. ASllOClationotNoIaJjes EXHIBIT B DONALD H. NIKOLAUS JOHN ~ HOHENADEL MATTHEW J. CREME, JR. JOHN F. MARKEL PAULA Q. MUNSON RICHARD G. GREINER JEFFREY A. MILLS MICHAEL S. GRAB MICHAEL A. VANASSE .JOSEPH G. MUZ1C, .JR. JAMES R. CLARK NIKOLAUS & HOHENAOEL, LLP ATTORNEYS AT LAW 212 NORTH QUEEN STREET LANCASTER, PA. 17603 copy COUNSEL .JOSEPH .J. LOMBARDO 717/299-3726 FAX 717/288-1811 September I, 2004 327 LOCUST STREET COLUMBIA, PA. 17512 [717) 684-4422 FAX 717/684-6099 dkreider@nikolaushohenadel.com BERNADETTE M. HOHENADEL ANTHONY MARC HOPKINS .JOHN C. HOHENADEL LlSA.J. McCOY WANDA S. WHAAE NADINE C. SMITH* KRISTEN L. GODDARD . ALSO ADMITTED TO NEW YORK STATE BAR Gregory A Rader 4 Hillcrest Drive Mechanicsburg, P A 17055 Re: Arnsperger v. Rader Cumberland County Court of Common Pleas No: 02-489 Dear Mr, Rader: Enclosed please find a copy ofPlaintitI's Complaint, as well as a Notice to Defend against you in the above matter. Please read these documents carefully and act accordingly, Very truly yours, ~~/J(~~ Denise M. Kreider Paralegal /dmk Enclosure r--- ~ ~ 7]' .;;;.- o c ~t -otp ..-rtfr. 'Z~.~'1 :z::t;: <3-';' ;;:c) ~O .;;.0 ....c ~ ~ ..., ~ q, ~,..., ~~ :<;lIQ 6n -~,;.y, 6}} .",CJ f~ .~"l'\ o ......l To" .lJ. -<. .-,:> "$ N .' ;:' - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW DANIELLE M. ARNSPERGER 369 Harrisburg Street Steelton, Pennsylvania 17113 Plaintiff NO.: 6.2- 4JXt ~ vs. GREGORY A. RADER 6 Umberto Avenue New Cumberland, Pennsylvania 17070 Defendant NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth against you in the following pages, you must take action within (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 defense 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 claims or relief requested by the 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 HAVE A LAWYER OR CANNOT AFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 a(4Cf - ~ ll.# Respectfully submitted, Date: NIKOLAUS & HOHENADEL, LLP By: C~~/]P~ Anthony Marc Hopkins, Esquire Attorney I.D. #47394 Attorney for Plaintiff 212 North Queen Street Lancaster, PA 17603 (717) 299-3726 Joseph G. Muzic, Jr., Esquire NIKOLAUS & HOHENADEL, LLP 212 North Queen Street Lancaster, PA 17603 (717) 299-3726 FAX (717) 299-1811 Email: jmuzic@nikolaushohenadel.com Attorney I.D. No. 55919 Attorney for Plaintiff DANIELLE M. ARNSPERGER Plaintiff In the Court of Common Pleas of Cumberland County, Pennsylvania CIVil- ACTION - LAW vs. GREGORY A. RADER Defendant NO.: 02-00489 PRAECIPE TO REINSTATE COMPLAll!:T TO THE PROTHONOTARY: Please reinstate the Complaint in the referenced matter. NIKOLAUS & HOHENADEL, LLP By: J seph G. Muzic, Jr., Esquire Attorney for Plaintiff Date: /} I/~ 101 I ' "" =. C) <= TI J:- ""t.~ <- --< n-', c: I .,'n r~"- nl;Q , , ~Gl,l (fJ ~(l7 ..r \JO r-' , ~j;:) .' .. :::::> {~;~~j ,.-" , ":;;JO 5- (.. w () :'ij :;.~: -j --', ""~" -( :-n w ~-,;. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW DANIELLE M. ARNSPERGER 369 Harrisburg Street Steelton, Pennsylvania 17113 NO.: OJ-- 4 5~ Plaintiff vs. GREGORY A. RADER 6 Umberto Avenue New Cumberland, Pennsylvania 17070 Defendant COMPLAINT NEGLIGENCE 1. The Plaintiff in this matter is Danielle M. Arnsperger who resides at 369 Harrisburg Street, Steelton, Pennsylvania 17113. 2. The Defendant in this case is Gregory A. Rader who resides at 6 Umberto Avenue, New Cumberland, Pennsylvania 17070. 3. On February 27, 2000, the Plaintiff's vehicle was parked on North Front Street in Wormleyburg Borough, Cumberland County, Pennsylvania. 4. The Defendant was operating his vehicle in a northerly direction on North Front Street. 5. The Defendant lost control of his vehicle and hit Plaintiff's parked vehicle, in doing so, Plaintiff violating duties owed Plaintiff various sections of the Motor Vehicle Code specifically: (a). The Defendant was driving under the influence of alcohol, violating Section 3731(al-4i) of the Motor Vehicle Code. (b). The Defendant negligently operated his vehicle in that he failed to maintain a proper lookout and was operating under the influence of alcohol. (c). Defendant failed to keep his vehicle under control. 6. Plaintiff's vehicle suffered damages in the amount of$12,865.75. 7. The Defendant's negligence was the proximate cause of the accident in which Plaintiffs vehicle was damaged. 8. The Plaintiff's vehicle was damaged in the amount of $12,865.75, an amount within the jurisdictional limits of mandatory arbitration in Cumberland County. WHEREFORE, Plaintiff demands judgment against the Defendant in the amount of $12,865.75, plus costs of suit and other costs allowed by law. Respectfully submitted, NIKOLAUS & HOHENADEL, LLP Date: By: Anthony Marc Hopkins, Attorney I.D. #47394 Attorney for Plaintiff 212 North Queen Street Lancaster, PA 17603 (717) 299-3726 VERIFICATION I, the undersigned, verify that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I acknowledge that had I knowingly made false statements in this document, I would be subject to the penalties of a misdemeanor of the third class pursuant to 18 Pa. C.S.A. ~4904 regarding unsworn falsification to authorities. l(;iJJAul/i ~1-M4/Yd4~'\ Danielle M. Arnsp rger J Date: 11/0/ ~R ~ C) C ...J -t\ p ~. c1; ~l ~ o.~ _.-1 m e () c <- -of.(. (!lfll Z-'''I Z-"~ Cl)~ ~"' ;.::::0 ~C )>0 C -". =? ..... ~ <=> N L- ::r..:.:- Z 9 ,"""" f'::;:' N co 'on ::....:t :;:: ~ ~ (1'\ ~d -71 ;:.::::, c-.5 h~ ':;:,1 55 -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW DANlELLE M. ARNSPERGER 369 Harrisburg Street Steelton, Pennsylvania 17113 NO.: DJ - Jff9 ~ Plaintiff vs. GREGORY A. RADER 6 Umberto Avenue New Cumberland, Pennsylvania 17070 Defendant PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Nikolaus & Hohenadel, LLP by Anthony Marc Hopkins, Esquire, on behalf of the Plaintiff, in the above-captioned case. NIKOLAUS & HOHENADEL, LLP By: Date: 212 North Queen Street Lancaster, PA 17603 (717 299-3726 . (") 0 0 C N -'",} $: C- -U'fr{ ;po ::2J ~:n ::e C:, Zt;::. N ":'-';Q OJ ~Z ';p ~O -0 )~ ::H ~C -> ZC) -0 W ,.,-~m >c ~ ~ N :0 0'\ -< SHERIFF'S RETURN - OUT OF COUNTY CA~E NO: 2002-00489 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ARNSPERGER DANIELLE M VS RADER GREGORY A 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: RADER GREGORY A but was unable to locate Him In his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania, to serve the within COMPLAINT & NOTICE On February 22nd, 2002 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing Out of County Surcharge Dep York County 18.00 9.00 10.00 30,60 .00 67.60 02/22/2002 NIKOLAUS & So answer '~, ,// /,/', /", ,/~::::/' [ ;;:~;:?2______~ R. homas Kline Sheriff of Cumberland County HOHENADEL Sworn and subscribed to before me this / JJJ- , day of ~-^-' J..w:U A.D. qQ' ~ 0/1~ Y1A ,l',...I ~ prothonotar .. . c?A-f 36410 COUNTY OF YORK OFFICE OF THE SHERIFF SERVICE CALL (717) 771-960 1 28 EAST MARKET ST., YORK, PA 17401 SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN 2. COURT NUMBER 02-489 civil 4. TYPE OF WRIT OR COMPLAINT Arnsperger 7. INDICATE SERVICE: NOW 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: OUT OF COUUY CUMBERLAND ADVANCED FEE PAID BY ATTY. NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN. Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the/sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriff's sale thereof. 9. TYPE NAME AND ADDRESS of ATTORNEY I ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER 11. DATE FILED NIKOLAUS & HOHEN ADEL 212 N. QUEEN ST. LANCASTER. PA 17603 12. SEND NOTICE OF SERVICE COPY NAME AND ADDRESS BELOW: (This area must be completed If notice IS to be mailed). 299-3726 1-28-02 CUMBERLAND CO. SHERIFF R. AHRENS 16. HOW SERVED: PERSONAL ( ) RESIDENCE ( POSTED ( ) POE ( ) SHERIFF'S OFF ( ) OTHER ( 17. I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, etc. named above. (See remarks below.) 18. AME AND TITLE OF INDIVIDUAL SERVED I LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) SEE REMARKS I-lOVED, NO FORWARDING ADDRESS - - C) 3. AdVt'5"~ 8ffts 41. AFFIRMED and subscribed to before me this 19TH 44. Signature of Dep. Sheriff 45. Signature of York . County Sheriff FOR WILLIAM M. 47. DATE ~ HOSEl. ?-; ?;::;. 9/02 51. DATE RECEIVED 1. WHITE. Issuing Authority 2. PINK. Attorney 3. CANARY. Sheriff's Office 4. BLUE - Sheriff's Office "~-~ 1. ~' .""-- 'j /:,i,';! j"'''H' J~11 ,~ "'-". "'"' '.1"'2 ':"''''ll3'"''' ~ 'n M>I':,~j::,r,i!!liij,j;_, [I N' ~ """," .{ ~ ,~, i I: '3ti 'cUl)..} '~1! i1 ~':.r'llil df""'lo~ ': , ,~. ~.. ~,.~ C" 1~ .." F :::iC=.I\;j)q ';,OJll1! the' ,'" ,.....', .' -,II- ,; .',"' jAl ;t; " ! ::l>:~;it:;l\1 T(;'.P,c' \(~ ;'-.' 'it; -:t i;':tft~w;i~F' t1 t!'\~ t~f"f'; ]::,:\;w' '< "", ~ ;:i;"1 ,fIl';:fHdI0 ~t H lfJ ;::--:;1 !;; lH ~~':l ,.}/":J' "iI) !,: .Ib ~,~i.,.'f::i: l' '~:.'! .'!, L J: w;;" " it" ' "I ':.c'~ 1 >.u [J :: !' . ,-;" .t:l'~\-.! r,'l 't:,,,,_'()t'll ' ..-,,' ! t, '''I ~, I' I' . :, '. . ,'; : ~ i: t~! " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW DANIELLE M. ARNSPERGER 369 Harrisburg Street Steelton, Pennsylvania 17113 NO. : OJ. - JJf( ~ Plaintiff vs. -<O;.D o rrl m ;:000 A""TJ~ ~ - (f)< ::3 v :I: m :t>mo "'"" ;:0; N - ""TJ YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forItagainst"TJ you in the following pages, you must take action within (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 defense 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 claims or relief requested by the Plaintiff. You may lose money or property or other rights important to you. Defendant . t::) N ...., ,-,., c:::o "'"" c..> o ""1 .,., GREGORY A. RADER 6 Umberto Avenue New Cumberland, Pennsylvania 17070 NOTICE TO DEFEND YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Respectfully submitted, Date: By: NIKOLAUS & HOHENADEL, LLP {UktWM ht I ]p ~ Anthony Marc Hopkins, Esquire Attorney I.D. #47394 Attorney for Plaintiff 212 North Queen Street Lancaster, PA 17603 (717) 299-3726 rv IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW DANIELLE M. ARNSPERGER 369 Harrisburg Street SteeIton, Pennsylvania 17113 NO,: Plaintiff vs. GREGORY A. RADER 6 Umberto Avenue New Cumberland, Pennsylvania 17070 Defendant COMPLAINT NEGLIGENCE I. The Plaintiff in this matter is Danielle M. Arnsperger who resides at 369 Harrisburg Street, Steelton, Pennsylvania 17113. 2. The Defendant in this case is Gregory A. Rader who resides at 6 Umberto Avenue, New Cumberland, Pennsylvania 17070. 3. On February 27, 2000, the Plaintiff's vehicle was parked on North Front Street in Wormleyburg Borough, Cumberland County, Pennsylvania. 4. The Defendant was operating his vehicle in a northerly direction on North Front Street. 5. The Defendant lost control of his vehicle and hit Plaintiff's parked vehicle, in doing so, Plaintiff violating duties owed Plaintiff various sections of the Motor Vehicle Code specifically: (a). The Defendant was driving under the influence of alcohol, violating Section 3731(al-4i) of the Motor Vehicle Code. (b), The Defendant negligently operated his vehicle in that he failed to maintain a proper lookout and was operating under the influence of alcohol. (c). Defendant failed to keep his vehicle under control. 6. Plaintiff's vehicle suffered damages in the amount of$12,865.75. 7. The Defendant's negligence was the proximate cause of the accident in which Plaintiffs vehicle was damaged. 8. The Plaintiffs vehicle was damaged in the amount of $12,865.75, an amount within the jurisdictional limits of mandatory arbitration in Cumberland County. WHEREFORE, Plaintiff demands judgment against the Defendant in the amount of $12,865.75, plus costs of suit and other costs allowed by law, Respectfully submitted, NIKOLAUS & HOHENADEL, LLP Date: By: Anthony Marc Hopkins, Attorney I.D. #47394 Attorney for Plaintiff 212 North Queen Street Lancaster, PA 17603 (717) 299-3726 VERIFICATION I, the undersigned, verify that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I acknowledge that had I knowingly made false statements in this document, I would be subject to the penalties of a misdemeanor of the third class pursuant to 18 Pa, C,S.A. ~4904 regarding unsworn falsification to authorities. .(2oAI/lh (!t1/V714fJVrr4/-~'\ Danielle M. Arnsp rger :::; Date: 11/0l ~\H~ ^1.),S~H3d :\"' '--'~ ,"-\ ~ 1,:,'; ,"'\ ,. ",."' \..I 7.0. V\~ 5S b G~ "'f ,l..\..liilC~' A\,'.lJrHIO :a:llll'ilHS 3lil. dO :;nIHO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CML DIVISION - LAW DANIELLE M. ARNSPERGER 369 Harrisburg Street Steelton, Pennsylvania 17113 NO.: 02-00489 - CIVIL Plaintiff vs. GREGORY A. RADER 6 Umberto Avenue New Cumberland, Pennsylvania 17070 Defendant PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the referenced matter. NIKOLAUS & HOHENADEL, LLP By: 0frVV1~ ~ Anthony Marc Hopkins, Esquire I.D. #47394 Attorney for Plaintiff 212 North Queen Street Lancaster, PA 17603 (717) 299-3726 Date: 3j'OJlo '""L, (') c < ""(1 t~;'":. n;J(: :::: :~r E1:t'} -<:.- f:':'; ~,. ~.~,. .....~ <.., j~~.~ .,;".- =2 "....'<._,..~ ,...::::~; hJ """ no ,,~ l i"<'; .,. ~,) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW DANIELLE M. ARNSPERGER 369 Harrisburg Street Steelton, Pennsylvania 17113 NO.: 02-00489 - CIVIL Plaintiff vs. GREGORY A. RADER 6 Umberto Avenue New Cumberland, Pennsylvania 17070 Defendant PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the referenced matter. NIKOLAUS & HOHENADEL, LLP By: ~ Anthony Marc Hopkins, Esquire I.D. #47394 Attorney for Plaintiff 212 North Queen Street Lancaster, PA 17603 (717) 299-3726 Date: (") c: <.~ -0 ;~~:':\ mi','o z:::::~ zr- (j) "-. -'< r:::: ~~r~: :;;.~~E ::2 o N if) rt1 -0 1 0-" () -n ;! ;" !~ ~'lt~:~ .::~ ~:';"(') .~~ ~'i; .:::'1 "'C N ,......", <r.:_;... :< SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2002-00489 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ARNSPERGER DANIELLE M VS RADER GREGORY A 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: RADER GREGORY A but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT & NOTICE On October 2nd , 2002 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin Co 18.00 9.00 10.00 25.50 .00 62,50 10/02/2002 NIKOLAUS & S~~? R. Thomas Kline Sheriff of Cumberland County HOHENADEL Sworn and subscribed to before me this ~ '7 - day of (])~ _ d.kJ.:L A,D, ~. () 'fh,;c" , .~ Prothonotary @ffitt of tqc ~4~Xiff William T. Tully Solicitor J. Daniel Basile Chief Deputy Mary Jane Snyder Rea] Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 171 0 1 ph: (7] 7) 255.2660 fax: (717) 255.2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania ARNSPERGER DANIELLE M County of Dauphin vs RADER GREGORY A Sheriff's Return No. 2153-T - -2002 OTHER COUNTY NO. 02-489 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for RADER GREGORY A the DEFENDANT named in the within COMPLAINT and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, September 26, 2002 NO LONGER WORKS AT THIS ADDRESS Sworn and subscribed to lefore me this 26TH day CJf" SEPTEMBER, 2002 ! \ /) ,.\ f \ ....~,-I-:- f t ,-j~{Yta/rc) C:. (hO/r.l,MJ So Answers, JK~~ Sheriff of Dauphin County, Pa. PROTHONOTARY By Deputy Sheriff Sheriff's Costs: $25.50 PD 09/12/2002 RCPT NO 169102 In' The Court of Common Pleas of Cumberland County, Pennsylvania Danielle M. Arnsperger VS. Gregory A. Rader SERVE: Gregory A. Rader No. 02 489 civil Now, September 9, 2002 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ....""./ r0' ~~~/~....... Sheriff of Cumberland County, PA Affidavit of Service Now, ,20_, at 0' clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this day of , 20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ Joseph G. Muzic, Jr., Esquire NIKOLAUS & HOHENADEL, LLP 212 North Queen Street Lancaster, PA 17603 (717) 299-3726 (717) 299-1811-FAX Attorney I.D. No. 55919 Attorney for Plaintiff DANIELLE M. ARNSPERGER Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. vs. CIVIL ACTION - LAW GREGORY A. RADER Defendant NO.: 02-00489 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the referenced matter. NIKOLAUS & HOHENADEL, LLP -----.. ' ~. By: Date: J1-/7~o3 (") c <.~ -Uf;. rn;-;. Zc:' 65,~.;: -<.:' r::c ?;o ~(-"' Pc: Z :;J , ~n ,-, -, :[i -" SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-00489 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ARNSPERGER DANIELLE M VS RADER GREGORY A 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 RADER GREGORY A but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , RADER GREGORY A 4 HILLCREST DRIVE MECHANICSBURG, PA 17055 JOHN ESLINGER, CURRENT RESIDENT, SAYS RADER MOVED OUT 6 MONTHS AGO. POST OFFICE SAYS MAIL IS DELIVERED TO GIVEN ADDRESS. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 6.90 5.00 10.00 .00 39.90 So answers :..-;;r"""""'~ c:::;;::.':..::~~?' .~~_/ -R. Thomas Kline Sheriff of Cumberland County NIKOLAUS & HOHENADEL 12/11/2003 Sworn and ~ubscribed to before me h this I ~-.({ day Of_~~ d:.. DV~ Alf A r j~J1/:;~ Joseph G. Muzic, Jr., Esquire NIKOLAUS & HOHENADEL, LLP 212 North Queen Street Lancaster, PA 17603 (717) 299-3726 (717) 299-1811 - FAX Attorney J.D. No. 55919 Attorney for Plaintiff DANIELLE M. ARNSPERGER Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. vs. CIVIL ACTION -- LAW GREGORY A. RADER Defendant NO.: 02-00489 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the referenced matter. NIKOLAUS & HOHENADEL, LLP By: Date: i.J. -I't-{)} 0 ... ~:,:; ~ C'" C'.::> ,J <.-.> .,., C' --I c, r":: ::r:: C.-;" ~J..""n , 'f-':: r'~' :98 rv ~....J .. C)<S .--'\ .-,.--"]'; ;:~:??5 c.,) ;:,jITo .~ .' , CD Joseph G. Muzic, Jr., Esquire NIKOLAUS & HOHENADEL, LLP 212 North Queen Street Lancaster, P A 17603 (717) 299-3726 (717) 299-1811 - FAX Attorney LD. No. 55919 Attorney for Plaintiff DANIELLE M. ARNSPERGER Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. Ys. CIVIL ACTION - LAW GREGORY A. RADER Defendant NO.: 02-00489 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the referenced matter. NIKOLAUS & HOHENADEL, LLP /-;l0-0,-/ Jos h . Muzic, Jr., Esquire to ey for Plaintiff -----~ " ----- By: Date: ,-, "::::::> S:~2 <..- ",,'"- N (1: C) c..;'; () --;-\ ::;1 G'1?~ -r'lrn ;;,;~ -':"J,r;' Joseph G. Muzic, Jr., Esquire NIKOLAUS & HOHENADEL, LLP 212 North Queen Street Lancaster, P A 17603 (717) 299-3726 (717)299-1811-FAX Attorney J.D. No. 55919 Attorney for Plaintiff DANIELLE M. ARNSPERGER Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. vs. CIVIL ACTION - LAW GREGORY A. RADER Defendant NO.: 02-00489 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the referenced matter. NIKOLAUS & HOHENADEL, LLP By: Date: c2. - J. 0- Ot..j 0 ...., 0 C:.:l c.' c:::> .1 , .-< -;",.-: ...., :C rr; -n CO rn r ;"...) -qrn 'Jr 0 ~~U ~_. .....- " '.' ~~';2f~ !'., <'1:':1 '":-l :~ {^'> :I? <.oJ Joseph G. Muzic, Jr., Esquire NIKOLAUS & HOHENADEL, LLP 212 North Queen Street Lancaster, P A 17603 (717) 299-3726 (717) 299-1811 - FAX Attorney I.D. No. 55919 Attorney for Plaintiff DANlELLE M. ARNSPERGER Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. vs. CIVIL ACTION - LAW GREGORY A. RADER Defendant NO.: 02-00489 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the referenced matter. NIKOLAUS & HOHENADEL, LLP By: ( Date: 3-}Q-OLf Ins h . uzic, Ir., Esquire Attorney for Plaintiff --:: ,-..,:. C) C~) .:-;., c_~ ;: ,J :",,) (.~) r~~;~ Joseph G. Muzic, Jr., Esquire NIKOLAUS & HOHENADEL, LLP 212 North Queen Street Lancaster, P A 17603 (717) 299-3726 (717) 299-1811 - FAX Attorney I.D. No. 55919 Attorney for Plaintiff DANIELLE M. ARNSPERGER Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. vs. CIVIL ACTION - LAW GREGORY A. RADER Defendant NO.: 02-00489 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the referenced matter. NIKOLAUS & HOHENADEL, LLP By: Date: 1.-/ ' 2../- D tf C-", '>'1 '\' g .... ~ c::> ~ ;:: ~ ~:n ~! ::0 ~~ N ~Z N ~O 0 '<: -0 ~8 ::J: ~rn W ~ ~ w ~ .- -< Joseph G. Muzic, Jr., Esquire NIKOLAUS & HOHENADEL, LLP 212 North Queen Street Lancaster, PA 17603 (717) 299-3726 (717) 299-1811 - FAX Attorney J.D. No. 55919 Attorney for Plaintiff DANIELLE M. ARNSPERGER Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. vs. CIVIL ACTION -. LAW GREGORY A. RADER Defendant NO.: 02-00489 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the referenced matter. NIKOLAUS & HOHENADEL, LLP By: ---/ :5 ~ ;;;-/- D L./ . Muzic, Jr., Esquire for Plaintiff Date: Q fu 'JU 0)q- ~~... ~;=.', =,-, r~, :< ...., = <= :- :x -;p. -< o -n :r. -r, rnp -rom :o? go :1: :r.; ~~o ~lril 'Xi :..:.. N U1 ;0.- ;2: '2 U1 N Joseph G. Muzic, Jr., Esquire NIKOLAUS & HOHENADEL, LLP 212 North Queen Street Lancaster, P A 17603 (717) 299-3726 (717) 299-1811-FAX Attorney I.D. No. 55919 Attorney for Plaintiff DANlELLE M. ARNSPERGER Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. vs. CIVIL ACTION - LAW GREGORY A. RADER Defendant NO.: 02-00489 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the referenced matter. NIKOLAUS & HOHENADEL, LLP Date: ~~"J-'-DL/ /~r--------" BY:_~/ Jos h . Muzic, Jr., Esquire At ey for Plaintiff ....., 0 => c.;) ~rl ...- --I (.,- " :;::.~ hl :!J r- .urn N :oy N '~l~) -c ~~~~\ :r; ~;:. l"-' '< :::::1 Lrt 'C -< -~;:. .:;..- SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-00489 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ARNSPERGER DANIELLE M VS RADER GREGORY A 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 RADER GREGORY A but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , RADER GREGORY A 4 HILLCREST DRIVE MECHANICSBURG, PA 17055 RESIDENT, ESLINGER, CLAIMS THAT RADER LIVES IN MECHANICSBURG AREA BUT DOES NOT KNOW HIS ADDRESS, RADER DOES NOT LIVE AT GIVEN ADDRESS. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 7,40 5.00 10.00 .00 40.40 S~J?~:-~ ~~~'~---'~ , R. Thomas Kline Sheriff of Cumberland County NIKOLAUS & HOHENADEL 07/16/2004 Sworn and subscribed to before me this "JIA..JI- day of ~ .;Lw 'I A , D . n. ~ (j >h~;~,~. ~ ~honotary Joseph G. Muzic, Jr., Esquire NIKOLAUS & HOHENADEL, LLP 212 North Queen Street Lancaster, PA 17603 (717) 299-3726 FAX (717) 299-1811 Emai1: jmuzic@nikolaushohenadel.com Attorney LD. No. 55919 Attorney for Plaintiff DANIELLE M. ARNSPERGER Plaintiff vs. GREGORY A. RADER Defendant In the Court of Common Pleas of Cumberland County, Pennsylvania CIVIL ACTION ~ LAW NO.: 02-00489 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the referenced matter. Date: '6-/(,,-0'-1 NIKOLAUS & HOHENADEL, LLP By: ~.~--,..-._._'''.--- ---~.~---- (". " ..----- \..._, ./'4- ---"""""'-' C) c:; (;<: (,.l C) Joseph G. Muzic, Jr., Esquire NIKOLAUS & HOHENADEL, LLP 212 North Queen Street Lancaster, P A 17603 (717) 299-3726 FAX (717) 299-1811 E-mail: jmuzic@nikolaushohenadel.com Attorney I.D. No: 55919 Attorney for Plaintiff DANIELLE M. ARNSPERGER Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVIL DIVISION - LAW GREGORY A. RADER, Defendant No. 02-00489 PLAINTIFF'S MOTION FOR SERVICE ]'URSUANT TO SPECIAL ORDER OF COURT-PUBLICATION AND NOW, by and through her attorney, Nikolaus & Hohenadel, LLP, PlaintiffDanielle M. Amsperger, comes to respectfully request this Court issue an Order allowing Service by Publication for the following reasons: 1. Plaintiff initiated the instant action against Defendant on December 12, 2001. 2. On February 27,2000, Defendant was operating a motor vehicle when, while under the influence of alcohol, he hit Plaintiff's parked vehicle causing damages in the amount of$12,865.75. 3. Plaintiff believes, and therefore avers, that according to the police accident report, Defendant's address at the time of the accident 6 Umberto Avenue, New Cumberland, Pa. 4. On January 28, 2002, Plaintiff attempted to serve Defendant a copy of the Complaint through the Cumberland County Sheriff's office at his address of6 Umberto Avenue, New Cumberland, Pa. 5. It was learned that Defendant no longer resided at 6 Umberto Avenue and Plaintiff subsequently obtained information regarding Defendant's place of employment. Plaintiff attempted to serve the Defendant, through the Dauphin County Sheriff's office at his place of employment, Jack Barton Construction, North Cameron Street, Harrisburg, Pa. Service was not made upon Defendant as the sheriff's service form indicated that Defendant was no longer an employee. 6. On or about October, 2003, Plaintiff subpoenaed the Pennsylvania Department of Transportation, Bureau of Driver Licensing records for Defendant Gregory A. Rader. PennDOT's records indicate that Defendant's current address is 4 Hillcrest Drive, Mechanicsburg, Pa. 7. On or about October, 2003, Plaintiff attempted to secure a current address through the United States Postal Service, which indicates that Defendant's address is 4 Hillcrest Drive, Mechanicsburg, Pa. Plaintiff again attempted service of the Complaint upon Plaintiff at this address, howevl~r, the resident of 4 Hillcrest Drive, Mechanicsburg, Pa., indicated that the o,~fendant had moved out of the residence six (6) months prior. 8. Again in June, 2004, Plaintiff subpoenaed the Pennsylvania Department of Transportation, Bureau of Driver Licensing records for Defendant Gregory A. Rader and the last known address was 4 Hillcrest Drive, Mechanicsburg, Pa. 9. On or about June, 2004, Plaintiff attempted to secure a current address through the United States Post Service, which indicates that Defendant is still receiving mail at the address of 4 Hillcrest Drive, Mechanicsburg, Pa. 10. Plaintiff again has attempted service of the Complaint on Defendant, the latest attempt being July 15,2004. 11. The Cumberland County Sheriff's office, in their attempt to serve Defendant with the Complaint, spoke with the resident at 4 Hillcrest Drive, Mechanicsburg, Pa., a gentleman who indicated that he knew of the Defendant but was unaware of his current address. 12. Plaintiff's counsel has verified through the Cumberland County Real Estate Tax Office that Defendant does not own any real estate in Cumberland County. 13. Pursuant to Pa. R.C.P. 430(a), Plaintiff has made a good-faith effort in attempting to locate Defendant through the U.S. Postal Service, as well Pennsylvania Department of Transportation, Bureau of Driver Licensing and the Cumberland County Tax Office. 14. Although all available means of service have been attempted to locate the Defendant, Plaintiff is unable to serve the Defendant with a copy of the Complaint. WHEREFORE, Plaintiff, Danielle M. Amsperger, hereby respectfully requests this Honorable Court to enter an Order allowing Service by Publication upon Defendant, Gregory A. Rader. Date: Respectfully submitted, NIKOLAUS & HOHENADEL, LLP BY: aMmo, k, """'" ?5 J:)3/D4 / I Joseph G. Muzic, Jr., Esquire NIKOLAUS & HOHENADEL, LLP 212 North Queen Street Lancaster, P A 17603 (717) 299-3726 FAX (717) 299-1811 E-mail: jmuzic@nikolaushohenadel.com Attorney I.D. No: 55919 Attorney for Plaintiff DANlELLE M. ARNSPERGER Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVIL DIVISION - LAW GREGORY A. RADER, Defendant No. 02-00489 AFFIDAVIT I, Joseph G. Muzic, Jr., Esquire, an attorney with the law firm of Nikolaus & Hohenadel, LLP, hereby state that attempts to serve the Defendant, Gregory A. Rader, have been unsuccessful. A good-faith effort to locate the current address of Defendant have been attempted through the United States Postal Service, as well as the Pennsylvania Department of Transportation, Bureau of Driver Licensing and the Cumberland County Tax Office, with no success. Respectfully submitted, NIKOLAUS & HOHENADEL, LLP BY: ~,.".-"' Date: "6 b3/0 1 J I r:: ;",) .....1 . DANIELLE M. ARNSPERGER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW GREGORY A. RADER, Defendant NO. 02-489 CIVIL TERM ORDER OF COURT AND NOW, this 27th day of August, 2004, upon consideration of Plaintiffs Motion for Service Pursuant to Special Order of Court - Publication, it is ordered and directed that service of the complaint in this matter shall be: by (I) publication once in the Cumberland Law Journal and in a newspaper of general circulation in Cumberland County, and (2) first-class mail addressed to Defendant at his last known address. BY THE COURT, !~ph G. Muzic, Jr., Esq. ~lKOLAUS & HOHENADEL, LLP 212 North Queen Street Lancaster, PA 17603 Attorney for Plaintiff > ~ og-l*-o) :rc 'q'\\'N^",^SNN3Q J.jNfla:) ON'f"\\:B9Viro l \ :, \4c:1 L' 9n~ ~QOl ^tN1OOOW:~ 3t\l 5J ~B;l~ ' Joseph G. Muzic, Jr., Esquire NIKOLAUS & HOHENADEL, LLP 212 North Queen Street Lancaster, PA 17603 (717) 299-3726 FAX (717) 299-1811 E-mail: jmuzic@nikolaushohenadel.com Attorney I.D. No: 55919 Attorney for Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVil- DIVISION - LAW DANlELLE M. ARNSPERGER Plaintiff GREGORY A. RADER, Defendant No. 02-00489 PRAECIPE FOR ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against Defendant, Gregory A. Rader, for failure to file an Answer to Plaintiff's Complaint, pursuant to Pa. R.C.P. No. 236. A copy of the Important Notice is attached hereto. Respectfully submitted, NIKOLAUS & HOHENADEL, LLP BY: Date: /O/7fi Jose~ . Muzic, Jr., Esquire ~O"P\::" ":~ ~f/-- Joseph G. Muzic, Jr., Esquire NIKOLAUS & HOHENADEL, LLP 212 North Queen Street Lancaster, PA 17603 (717) 299-3726 FAX (717) 299-1811 E-mail: jmuzic@nikolaushohenade1.com Attorney LD. No: 55919 Attorney for Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVIL DMSION - LAW DANIELLE M. ARNSPERGER Plaintiff GREGORY A. RADER, Defendant No. 02-00489 IMPORTANT NOTICE YOU ARE IN DEF AUL T 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 IMPORT ANT RIGHTS. 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 ELlGffiLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania (717) 249-3166 Date: q)17/o1- BY: NIKOLAUS & HOHENADEL, LLP JO~"",' J'., E.,llire ---"----_._...~..~_."..._.,_..- Joseph G. Muzic, Jr., Esquire NIKOLAUS & HOHENADEL, LLP 212 North Queen Street Lancaster, PA 17603 (717)299-3726 FAX (717)299-1811 E-mail: jmuzic@nikolaushohenadeI.com Attorney I.D. No: 55919 Attorney for Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVIL DIVISION - LAW DANIELLE M. ARNSPERGER Plaintiff GREGORY A. RADER, Defendant No. 02-00489 CERTIFICATE OF ADDRESS I, Joseph G. Muzic, Jr., Esquire, hereby certifY that Defendant Gregory A. Rader, has been served with an Important NoticelDefault Notice by first-class mail, postage prepaid at his last known address of: Gregory A. Rader 4 Hillcrest Drive Mechanicsburg, PA 17055 NIKOLAUS & HOHENADEL, LLP BY: / /,,; Joseph G. ~Jr., Esquire Date: J{1ffi Ctv [:) ~ ~ It- 1'\~ "6 F -- . C> ~ \lJ -u j Crl~ Q. IV' tI) ~ r~ ~--l::.~::p E1' .:r-~ ~ Joseph G. Muzic, Jr., Esquire NIKOLAUS & HOHENADEL, LLP 212 North Queen Street Lancaster, P A 17603 (717) 299-3726 FAX (717) 299-1811 E-mail: jmuzic@nikolaushohenadel.com Attorney J.D. No: 55919 Attorney for Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVIL DIVISION - LAW No. 02-00489 DAN1ELLE M. ARNSPERGER Plaintiff GREGORY A. RADER, Defendant CERTIFICATE OF ADDRESS I, Joseph G. Muzic, Jr., Esquire, hereby certify that Defendant Gregory A. Rader, was served with an Important Notice/Default Notice by first-class mail, postage prepaid at his last known address of: Gregory A. Rader 4 Hillcrest Drive Mechanicsburg, PA 17055 NIKOLAUS & HOHENADEL, LLP /.--------..,. BY: Date: 9/27/04 ORIGINAL Joseph G. Muzic, Jr., Esquire NIKOLAUS & HOHENADEL, LLP 212 North Queen Street Lancaster, P A 17603 (717) 299-3726 FAX (717) 299-1811 E-mail: jmuzic@nikolaushohenadel.com Attorney LD. No: 55919 Attorney for Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVIL DIVISION - LA W DANIELLE M. ARNSPERGER GREGORY A. RADER, No. 02-00489 AFFlDA VIT/CERTlFICATlON TO THE PROTHONOTARY: I, Joseph G. Muzic, Esquire, attorney for Plaintiff hereby certify judgment should be entered against Defendant Gregory A. Rader in the amount of twelve thousand, eight hundred sixty-five dollars and seventy-five cents ($12,865.75) because of a motor vehicle accident. Respectful1y submitted, BY: NIKOLAUS & HOHENADEL, LLP , ,,;.J.""b' \... ........ /'\ Jos ph ;. Muzic, Jr., Esquire Attorney for Plaintiff Date: December 13,2005 , ~ , \." t ~ p -v )':,.. '~II::- (fl -:1 - ...c.. 'E '0 tyJ 'W ...c:.. 4:;.. t,.J . \> Q -J i" 1 t. ..I:-- , ~ -----