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HomeMy WebLinkAbout12-4483PAUL 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 THIS IS AN ARBITRATION MATTER', ATTORNEY FOR PLAINTIFF AMERIPRISE AUTO & HOME INSURANCE : AS SUBROGEE OF DARNELL HYMANS AND: JENNIFER HYMANS 3500 PACKERLAND DRIVE DE PERE, WI 54115 VS. ROMAN A. PRICE 1751 GOLA DRIVE FAYETTEVILLE, NC 28301 AND INTEGRITY CARRIERS INC. 1751 GOLA DRIVE FAYETTEVILLE, NC 28301 COMMON PLEAS COURT CUMBERLAND COUNTY NO. ti? F.X r-n irm c= L4 q r- ll?l?? ? z CG z ? o ? rv 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. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI USTE QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUES' LAS PAGINAS SIGUIENTES, LISTED TIENE (20) DIAS DE A PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFIC LISTED DEBE PRESENTAR UNA APARIE~NCIA ESCRITA I PERSONA 0 POR ABOGADO Y ARCHIVAR EN LA CORTI DEFENSAS O SUS OBJECIONES A LAS DEMANDAS EN( DE SU PERSONA. SEA AVISADO QUE $I LISTED NO SE DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE EN- UNA ORDEN CONTRA LISTED SIN PREVIO AVISO O NOTIFICACION O POR CUALQIER QUEJA O ALIVIO QUE ESPEDIDO EN LA PETICION DE DEMANDA. USTED PUE PERDER DINERO, SUS PROPIEDADES O OTROS DEREI IMPORTANTES PARA USTED. 1711, -rl r.? AS EN EN SUS LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAME TE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICI NTE PARA PAGAR TAL SERVICIO, VAYA EN PERSONA O L ME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUE TRA ESCRITA ABAJO PARA AVERIGUAR DONDE USTED PU DE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 ?o37s? a? ask 1q? ?a PAUL F. D-EMILIO, ESQUIRE THIS IS AN ARBITRATION MATT 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 ATTORNEY FOR PLAINTIFF AMERIPRISE AUTO & HOME INSURANCE COMMON PLEAS COURT AS SUBROGEE OF DARNELL HYMANS AND: CUMBERLAND COUNTY JENNIFER HYMANS 3500 PACKERLAND DRIVE DE PERE, WI 54115 VS. ROMAN A. PRICE NO. 1751 GOLA DRIVE FAYETTEVILLE, NC 28301 AND INTEGRITY CARRIERS INC. 1751 GOLA DRIVE CIVIL ACTION FAYETTEVILLE, NC 28301 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") IN AS MUCH 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, Ameriprise Auto & Home Insurance, ("Plaintiff') by its attorney Poul F. D'Emilio, Esquire, bring this action upon a cause whereof the following is a statement: The Plaintiff, Ameriprise Auto & Home Insurance is a Corporation authorized do business in the Commonwealth of Pennsylvania, having an office at 3500 Packerland Drive, De Pere, Wi 54115. Plaintiff brings this action as subrogee of Darnell Hymans and Jennifer Hymanp, herein the ("Insured") under a policy of Insurance, Issued by Plaintiff. 2. Defendant, Roman A. Price, is an individual residing at 1751 Gola Drive, Fayetteville, NC 28301. 3. Defendant, Integrity Carriers Inc. is a business authorized to do business in the Commonwealth of Pennsylvania with its' principal office at 1751 Gola Drive, Fayetteville, NC 28301. 4. At all times hereinafter mentioned the Defendant, Roman A. Price was the agent, workman, servant and employee of the Defendant, Integrity Carriers Inc. then and there in engaged in the business of the Defendant, Integrity Carriers Inc. within the course and scope of his employment. 5. On or about March 28, 2011 a motor vehicle owned by the Defendant, Integrity Carriers Inc. and operated by the Defendant, Roman A. Price traveling on 1-91 southbound, Hampden Township, Pennsylvania when he rear-ended Plaintiff's Insured's vehicle causing the damages hereinafter set forth. 6. Plaintiff avers that the personal property of the Insured was damaged as a result of the occurrence hereinbefore mentioned, the reasonable costs of repairs thereto being is Four Thousand Three Hundred Forty Two and 591100 ($4,342.59 Dollars plus the Insured's deductible of Five Hundred and 001100 ($500.00) Dollar for a total of Four Thousand Eight Hundred Forty Two and 591100 ($4,842.59) Dollars. Count I Ameriprise Auto & Home Insurance v. Roman A. Price 7. Plaintiff, incorporates by reference all of the allegations contained in paragraphs 1 through 6 inclusive of this Complaint as fully as though same were herein and set forth at length. 8. The said occurrence was due solely to the negligence of the Defendant, Rom n 2 A. Price in that he: I a. did fail to have the motor vehicle under proper and adequate control; i b. did operate the motor vehicle at an excessive rate of speed; C. did fail to apply the brakes in time to avoid the collision; d. did negligently apply the brakes; e. did fail to operate the vehicle in accordance with existing conditions; f. did fail to drive at a speed and in the manner that would allow him to st p within the assured clear distance ahead; g. did fail to keep a reasonable lookout for other vehicles lawfully on the road; h. did operate the motor vehicle without due regard for the rights, safety a d position of the Insured at the point of aforesaid; i. did fail to maintain financial responsibility; and j. did violate the various statutes and laws of the Commonwealth of Pennsylvania and County of Cumberland pertaining to the operation of motor vehicles. Count II Ameriprise Auto & Home Insurance v. Integrity Carriers Inc. 9. Plaintiff, incorporates by reference all of the allegations contained in paragraphs 1 through 8 inclusive of this Complaint as fully as though same were herein and set forth at length. 10. The said occurrence was do to the negligence of the Defendant, Integrity Carriers Inc. in that they: a. entrusted its vehicle to an operator for use when it knew, or with a reasonable exercise of due care should have known, that the operator was not capable of operating the vehicle properly; b. negligently entrusted the vehicle to a person which it knew, or in the exercise of reasonable care should have known, was an incompetent driver; and 3 C. negligently entrusted its vehicle to a person known, should have known p in the exercise of reasonable care could have known, was going to drive the vehicle i an improper, dangerous or reckless manner; d. negligently entrust their motor vehicle to a person who did not maintain financial responsibility as required by the laws of the Commonwealth of Pennsylvani e. did violate the various statutes and laws of the County of Northampton, and Commonwealth of Pennsylvania pertaining to the operation of motor vehicles. WHEREFORE, Plaintiff demands judgment against the Defendants upon eac count in an amount not in excess of Fifty Thousand and 00/100 ($50,000.00) dollars together with costs of suit. Date: 1-1 7 - ?o rain r. u'tmiiio, tsqurre Identification No.: 16654 e-mail address: pauld@demiliolaw. Paul M. Schofield, Jr., Esquire Identification No.: 81894 e-mail address: pauls@demiliolaw. 905 W. Sproul Road, Suite 105 Springfield, PA 19064 Telephone No.: 610-338-0338 Fax No.: 610-338-0303 4 VERIFICATION , Subrogation Specialist with Ameriprise Auto & Home Insurance 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: Subrogation Specialist Common Pleas Court of Cumberland County, Pennsylvania AMERIPRISE AUTO & HOME INSURANCE AS SUBROGEI; OF' DARNELL HYMANS AND JENNIFER HYMANS {' ROMAN A. PR1CE AND h1TERGRITY CARRIERS 11VC. Case No : 12-4483 ``--- r^,~ = . ,.-~..- a ~, ....1 , , q..J -. . ~,. ~, Court Uate: at -~ -=~~ ,; ,~~; - ~ nn t..yr ~~° a - ~ 1 ^J ..~ r u i _ f f-... ~ - - y .1~ t_J ~.y~ _.~r -~ . :~~~ N ~V~ ~._~ AFFIDAVIT OF PERSONAL SERVICE; That 1. Jennifer Boyce, hereby solemnly declare under the penalties of perjury and upon personal knowledge that the contents of the following document are true and do affirm 1 am a competent person over 18 years of ale and not a party to this action. That on July 26, 2012 at 10:28 AM at 1751 Gola Drive, Fayetteville. NC 28301 [served Roman A. Price with the following list of documents: Civil Complaint by then and there personally delivering a truf: and correct copy of the documents into the hands of and leaving with Ramon A. Price. That the description of the person actually served is its follows; Gender: Male Race'Skin: black Hair: Black Glasses: Yes Age: 35--45 Height: 6'0 Weight: 260 That the tee for this service is X108.90 ~7 r ~ ,... i .--" / ~ / i .- ~ ~ ,~ ' nnifer Boy r Uue Process . A. Inc. ~ F xecuted on: 8950 Route 108, Suite 100 Columbia, MD 21045 (800) 228-04~4~ -.- S s ibed and swya-+~ to before me, a notary public, ~m this -~ _ day of __-~ ~... .2012. ~-'~- My Commission Expires: (-J~~~~~'. ~~~~ ~'•,~~f ~" tary Pub ``ttttlli 1N I t N/////~~/ \~,v~v ~yNflO~l //9/i r _ ~I'[8t1~3 =_ ~?Id10i~I .,( ~ 1 ID' 12-05031 ~ ~~~~~tilfltil1111111~ Client Reference: AFN11-2012-173 Common Pleas Court of Cumberland County, Pennsylvania AMERIPRISE AUTO & HOME INSURANCE AS )Case No.: 12-4483 SUBROGEE OF DARNELL HYMANS AND ) JENNIFER HYMANS ~ Court Date: at Plaintiff ) v. ) ROMAN A. PRICE AND INTERGRITY CARRIERS ) INC. ) Defendant ) ~, z cnt" z r~ ~o y„C z _~ x+~ c c~ lv -v N That I, Jennifer Boyce, hereby solemnly declaze under the penalties of perjury and upon personal knowledge that the co~ the following document aze true and do affirm I am a competent person over 18 years of age and not a party to this action. ', n~ r cs '1 t'r mts of That on July 26, 2012 at 10:28 AM at 1751 Gola Drive, Fayetteville, NC 28301 I served Intergrity Carriers Inc. with th following list of documents: Civil Complaint by then and there personally delivering a true and correct copy of the docume is into the hands of and leaving with Roman A. Price, whose Title is 5. Registered Agent. That Roman A. Price stated he/she had the authority to accept as the Legal Representative for the above listed person That the description of the person actually served is as follows: Gender: Male Race/Skin: Black Hair: Black Glasses: Yes Age: 35-45 Height: 6'0 Weight: 245-265 That the fee for this service is $108.90 'fer ce , ue Pr sUSA, Inc. 8950 Route 108, Suite 100 Columbia, MD 21045 (800)228-0484 Su cribed d swo t efo a me a notary public, on this ~ ~` day of Notary Publ My Commission Expires: ~~~~'a~~ [D:12-050313 Executed on: entity. PAUL F. D-EMILIO, ESQUIRE THIS IS AN ARBITRATION MATTER 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 ATTORNEY FOR PLAINTIFF AMERIPRISE AUTO & HOME INSURANCE COMMON PLEAS COURT OF AS SUBROGEE OF DARNELL HYMANS AND: CUMBERLAND COUNTY JENNIFER HYMANS vs. rT rn to ROMAN A. PRICE NO. 12-4483 -<> CD AND C-) INTEGRITY CARRIERS, INC. CIVIL ACTION 5c= PRAECIPE FOR JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY, C.P.: Enter Judgment in the above entitled matter in favor of the Plaintiff, Ameriprise Auto & Home Insurance as Subrogee of Darnell Hymans and Jennifer Hymans for want of an answer, and assess Plaintiff's damages against Defendants Roman A. Price and Integrity Carriers, Inc.in the sum of $4,842.59 in accordance with a Complaint filed. PAUL F E O, ESQUIRE ATTO OR PLAINTIFF F ATTOF FNEYY rID.R#16654 Prothy as sse IaiA"?Ii�s damage"i the sum of$4,842.59. S) PR JR �—L7 0"N o U, PAUL F. D'EMILIO, ESQUIRE THIS IS AN ARBITRATION MATTER 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 ATTORNEY FOR PLAINTIFF AMERIPRISE AUTO & HOME INSURANCE COMMON PLEAS COURT OF AS SUBROGEE OF DARNELL HYMANS AND: CUMBERLAND COUNTY JENNIFER HYMANS VS. ROMAN A. PRICE NO. 12-4483 AND INTEGRITY CARRIERS, INC. CIVIL ACTION AFFIDAVIT AS TO NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF DELAWARE PAUL F. D'EMILIO, being duly sworn according to law, deposes and says that he is the agent for the Plaintiff above-named and is authorized to and does make this Affidavit on its behalf; and that he has knowledge of the facts set forth herein: That Defendant, Roman A . Price, is over twenty-one years of age and that he is not in the military service of the United States or otherwise within the provisions of the Soldier's and Sailor's Civil Relief Act of 1940 as amended. PAUL F. D' ;EVUO, ESQUIRE SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF , 2013. NOTARY PUBLIC PAUL F. D'EMILIO, ESQUIRE THIS IS AN ARBITRATION MATTER 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 ATTORNEY FOR PLAINTIFF AMERIPRI97E— AUTO-& HOME INSURANCE COMMON PLEAS COURT OF AS SUBROGEE OF DARNELL HYMANS AND: CUMBERLAND COUNTY JENNIFER HYMANS VS. ROMAN A. PRICE NO. 12-4483 AND INTEGRITY CARRIERS, INC. CIVIL ACTION AFFIDAVIT OF NOTICE OF INTENT TO ENTER DEFAULT JUDGEMENT 1, PAUL F. D'EMILIO, ESQUIRE, attorney for the Plaintiff, Ameriprise Auto & Home Insurance, does hereby certify that a Notice of Intent to Enter Default Judgement was mailed on October 17, 2012 to the Defendants listed below by Certificate of Mailing; a copy of the Notice and the original certification of mailing are attached hereto, made a part hereof, and marked Exhibit "A". Roman A. Price 1751 Gola Drive Fayetteville, NC 28301 Integrity Carriers, Inc. 1751 Gola Drive Fayetteville, NJ 28301 PAUL F,431E ESQUIRE ATTO"fEY ffOR �LAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW (Rule of Civil Procedure No. 236) PAUL F. DEMILIO, ESQUIRE THIS IS AN ARBITRATION MATTER 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 ATTORNEY FOR PLAINTIFF AMERIPRISE AUTO & HOME INSURANCE COMMON PLEAS COURT OF AS SUBROGEE OF DARNELL HYMANS AND: CUMBERLAND COUNTY JENNIFER HYMANS VS. ROMAN A. PRICE NO. 12-4483 AND INTEGRITY CARRIERS, INC. i CIVIL ACTION Notice is given that a judgment in the above captio d m ter ha been entere ei against you on 12013. V Prothonot If you have any questions concerning the above please contact: Paul F. D'Emilio, Esquire Attorney or Party Filing 905 W. Sproul Road, Suite 105 Address Springfield, PA 19064 City, State, Zip (610) 338-0338 Telephone Number IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW (Rule of Civil Procedure No. 236) PAUL F. DEMILIO, ESQUIRE THIS IS AN ARBITRATION MATTER 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 ATTORNEY FOR PLAINTIFF AMERIPRISE AUTO & HOME INSURANCE COMMON PLEAS COURT OF AS SUBROGEE OF DARNELL HYMANS AND: CUMBERLAND COUNTY JENNIFER HYMANS VS. ROMAN A. PRICE NO. 12-4483 AND INTEGRITY CARRIERS, INC. CIVIL ACTION Notice is given that a judgment in the above captione mat ha entered against you on 2013. Prothonotar, If you have any questions concerning the above please contact: Paul F. DEmilio, Esquire Attorney or Party Filing 905 W. Sproul Road, Suite 105 Address Springfield, PA 19064 City, State, Zip (610) 338-0338 Telephone Number PAUL F. D'EMILIO, ESQUIRE THIS IS AN ARBITRATION MATTER 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 ATTORNEY FOR PLAINTIFF AMERIPRISE AUTO & HOME INSURANCE COMMON PLEAS COURT OF AS SUBROGEE OF DARNELL HYMANS AND: CUMBERLAND COUNTY JENNIFER HYMANS VS. ROMAN A. PRICE NO. 12-4483 AND INTEGRITY CARRIERS INC. CIVIL ACTION CERTIFICATION AS TO ADDRESS OF DEFENDANTS I hereby certify the addresses of Defendants are as follows: Roman A. Price 1751 Gola Drive Fayetteville, NC 28301 Integrity Carriers, Inc. 1751 Gola Drive Fayetteville, NC 26301 PAUL F. D' MILIO, ESQUIRE ATTORNEY FOR PLAINTIFF PAUL F. D'EMILIO, ESQUIRE THIS IS AN ARBITRATION MATTER 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 ATTORNEY FOR PLAINTIFF AMERIPRISE AUTO & HOME INSURANCE COMMON PLEAS COURT OF AS SUBROGEE OF DARNELL HYMANS AND: CUMBERLAND COUNTY JENNIFER HYMANS VS. ROMAN A. PRICE NO. 12-4483 AND INTEGRITY CARRIERS, INC. CIVIL ACTION CERTIFICATION AS TO ADDRESS OF PLAINTIFF I hereby certify the address of Plaintiff, Ameriprise Auto & Home Insurance is as follows: 3500 Packerland Drive De Pere, WI 54115 PAUL F. D'EMILJ , ESQUIRE ATTORNEY FOR PLAINTIFF EXHIBIT "A" Name and Address of Sender Check type of mail or service: Affix Stamp Here • •ti U.1 (if issued as a a te"a" 01.71415526041 0 ❑ Certified ❑ Recorded Delivery(International) certificate of mailing, ❑ CO ered or for additional * u� }- Delivery Confirmation �Return e r Merchandise copies of this bill) $3 .529 V1 Express Mail ure Confirma tio Postmark and t( 0 ❑ Insured Date of Receipt ti 10117/2012 a Article Number Addressee(Name,Street,City,State,&ZIP Code) Postage Fee Charge, Matted From 19064 1. f%Cii,,, a �atj 2. 1 c�� rr;erstJ�C. � 4 as 1nlP r S¢ � 74 y6z -fit �a� er sn ��•__ �J '� `�'1 . ' O?a, q,4 Tai r ►pA s _ a� Cv _ _ G�K B. �. I' n . qi cf Vev��. rr6 c5>k� A6� y� 1)C-4 hilt r' o, Total Number of Pieces Total Nurn4wof Pieces Postmast er(Name of ceiving employee) isted by Sender Receive ost Office See Privacy Act Statement on Reverse S Form 3877,February 2002(Page 1 of 2) Complete by Typewriter,Ink,or Ball Point Pen PAUL F. D'EMILIO, ESQUIRE THIS IS AN ARBITRATION MATTER 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 ATTORNEY FOR PLAINTIFF AMERIPRISE AUTO & HOME INSURANCE COMMON PLEAS COURT OF AS SUBROGEE OF DARNELL HYMANS AND CUMBERLAND COUNTY JENNIFER HYMANS 3500 PACKERLAND DRIVE DE PERE, WI 54115 VS. ROMAN A. PRICE NO. 12-4483 1751 GOLA DRIVE FAYETTEVILLE, NC 28301 AND INTEGRITY CARRIERS INC. 1751 GOLA DRIVE CIVIL ACTION FAYETTEVILLE, NC 28301 DATE OF NOTICE: October 17, 2012 TO: Roman A. Price 1751 Gola Drive Fayetteville, NC 28301 NOTICE OF INTENT TO ENTER DEFAULT JUDGMENT 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 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. DAUPHIN COUNTY LAWYER REFERRAL SERVICE 213 NORTH FRONT STREET HARRISBURG, PA 17101 (717) 232-7536 Pad 3. D 'sue PAUL F. D'EMILIO, ESQUIRE PAUL F. D'EMILIO, ESQUIRE THIS IS AN ARBITRATION MATTER 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 ATTORNEY FOR PLAINTIFF AMERIPRJSE AUTO & HOME INSURANCE COMMON PLEAS COURT OF AS SUBROGEE OF DARNELL HYMANS AND CUMBERLAND COUNTY JENNIFER HYMANS 3500 PACKERLAND DRIVE DE PERE, WI 64115 VS. ROMAN A. PRICE NO. 12-4483 1751 GOLA DRIVE FAYETTEVILLE, NC 28301 AND INTEGRITY CARRIERS INC. 1751 GOLA DRIVE CIVIL ACTION FAYETTEVILLE, NC 28301 DATE OF NOTICE: October 17, 2012 TO: Integrity Carriers, Inc. 1751 Gola Drive Fayetteville, NC 28301 NOTICE OF INTENT TO ENTER DEFAULT JUDGMENT 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 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. DAUPHIN COUNTY LAWYER REFERRAL SERVICE 213 NORTH FRONT STREET HARRISBURG, PA 17101 (717) 232-7536 P"I PAUL F. D'EMILIO, ESQUIRE PAUL F. D'EMILIO, ESQUIRE ATTORNEY LD. #16654 PAUL M. SCHOFIELD, JR, ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 ATTORNEY FOR PLAINTIFF THIS IS AN ARBITRATION MATTER AMERIPRISE AUTO & HOME INSURANCE : AS SUBROGEE OF DARNELL HYMANS AND: JENNIFER HYMANS COMMON PLEAS COURT OF CUMBERLAND COUNTY VS. ROMAN A. PRICE NO. 12-4483 AND INTEGRITY CARRIERS, INC. CIVIL ACTION AFFIDAVIT MOTOR VEHICLE ACCIDENT I hereby certify that the Judgment debtor, Roman A. Price is the same person who is the Defendant in the Cumberland County Common Pleas Action No. 12-4483, which was a result of a motor vehicle accident on March 28, 2011. SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF , 2014. NOTARY PUBLIC P;uI M cho ie d, Esq.