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Home My WebLink About12-6450• IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Plaintiff(s) & Address(es) Selective Insurance Company of America a/s/o Tawnie Mills 40 Wantage Avenue Branchville, NJ 07890 Case No. 1,2 - &y_JjQ Civil Term VS. Civil Action Defendant(s) & Address(es) Fred A. Paulus 1130 McLaughlin Road -??=? _.; Fairfield, PA 17320 ;- PRAECIPE FOR WRIT OF SUMMONS ? r' =Z TO THE PROTHONOTARY/CLERK OF SAID COURT: r Issue summons in the above case Writ of Summons shall be issued and forwarded to Attornev/Sb c choice t Date : October 4, 2012 Signature o ttorney Print Name: Marc Myer quire Address: 309 Fellowship Road, Suite 330 Mt. Laurel, NJ 08054 .(856) 778-3220 Telephone #_ Supreme Court ID Number: 24853 • • • • • WRIT OF SUMMONS To: Fred A. Paulus YOU O .E NOTIFIED THA T THE ABOVE-NAMED PLAINTIFF(S) HASMAVE COMMENCED AN AC'?ION AGAINST YOU, Prothonotary/Clerk, Civil Division Date b Deputy 0 . 163.75 PD 10CFF Clo7-701 gopa &';&2009 ZIRULNIK SHERLOCK & DEMILLE Marc Myers, Esquire 13 AP'P, _3 IDENTIFICATION NO.: 24853 309 Fellowship Road, Suite 330 =' L��t;' ) C y Mt. Laurel,NJ 08054 y! ' (856) 778-3220; (856) 778-3222 fax Attorney for Plaintiff, Selective Insurance Company a/s/o Tawnie Mills SELECTIVE INSURANCE COMPANY COURT OF COMMON PLEAS a/s/o TAWNIE MILLS CUMBERLAND COUNTY 40 Wantage Avenue Branchville,NJ 07890 NO: 2012-06450 Plaintiff V. FRED A. PAULUS 1130 McGlaughlin Road Fairfield, PA 18320 Defendant NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES,YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY AN 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 PROCEEDWITHOUT 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 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 REDUECED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 ZIRULNIK SHERLOCK& DEMILLE Marc Myers, Esquire IDENTIFICATION NO. 24853 309 Fellowship Road, Suite 330 Mt. Laurel,NJ 08054 (856) 778-3220; (856) 778-3222 fax Attorney for Plaintiff, Selective Insurance Company a/s/o Tawnie Mills SELECTIVE INSURANCE COMPANY COURT OF COMMON PLEAS a/s/o TAWNIE MILLS CUMBERLAND COUNTY 40 Wantage Avenue Branchville,NJ 07890 NO: 2012-06450 Plaintiff V. FRED A. PAULUS 1130 McGlaughlin Road Fairfield, PA 18320 Defendant COMPLAINT Plaintiff, Selective Insurance Company of America as subrogee of Tawnie Mills, by and through their counsel, aver the following: 1. Plaintiff, Selective Insurance Company of America is an insurance company duly licensed within the Commonwealth of Pennsylvania located at 40 Wantage Avenue, Branchville, New Jersey 07890. 2. On all dates relevant hereto, Tawnie Mills was a policy holder of Selective Insurance Company. 3. Fred Paulus is an adult individual who at all times relevant hereto resided at 1130 McGlaughlin Road, Fairfield, PA 17320. 4. On or about January 29, 2011, Defendant was the operator of a motor vehicle who was operating his vehicle in the vicinity of South Morris Street and West King Street in Shippensburg Borough, Cumberland County. 5. At the aforesaid time and place, Defendant so negligently and carelessly operated his vehicle such as to collide with the cement wall owned by Tawnie Mills located on South Morris Street such as to cause it damage in the amount of$981.87. 6. The aforesaid damages to the property of Tawnie Mills was a direct and proximate result of the negligent and careless operation of his motor vehicle by Defendant as follows: (a) Failure to avoid contacting Plaintiff's property; (b) Failure to keep his vehicle under control; (c) Failure to operate his vehicle at a reasonable speed under the circumstances; (d) Failing to take proper precautions to avoid striking the Plaintiff's property; (e) Failing to keep a proper lookout. 7. As a result of the damage to the property of Tawnie Mills, Selective Insurance Company of America was required to pay the amount of$981.87 for said property loss. 8. As a result of the aforementioned payment, Plaintiff has become subrogated to the rights and causes of action of its insured. WHEREFORE, Plaintiff demands judgment in its favor in the amount of$981.87. Respectfully submitted, ZIRULNIK SHERLOCK& DeMILLE By: MARC MYERS, ESQUIRE Attorney for Plaintiff VERIFICATION I, MARC MYERS,ESQUIRE,hereby state that I am the attorney for the Plaintiff in the within action and verify that the averment or denial of facts contained in the foregoing Complaint are true and correct based upon my personal knowledge,information and belief. If the foregoing contains averments which are inconsistent in fact,I have been unable,after reasonable investigation,to ascertain which of the inconsistent averments are true,but do have knowledge and information sufficient to form a belief that one of them is true. This Verification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. -W "44 MARC MYERS, ESQUIRE ZIRULNIK SHERLOCK& DEMILLE Marc Myers, Esquire IDENTIFICATION NO. 24853 309 Fellowship Road, Suite 330 Mt. Laurel,NJ 08054 (856) 778-3220; (856) 778-3222 fax Attorney for Plaintiff, Selective Insurance Company a/s/o Tawnie Mills SELECTIVE INSURANCE COMPANY COURT OF COMMON PLEAS a/s/o TAWNIE MILLS CUMBERLAND COUNTY 40 Wantage Avenue Branchville,NJ 07890 NO: 2012-06450 Plaintiff V. FRED A. PAULUS 1130 McGlaughlin Road Fairfield, PA 18320 Defendant CERTIFICATE OF SERVICE I, MARC MYERS, ESQUIRE,hereby certify that on the 1St day of April, 2013, a true and correct copy of the foregoing Complaint was served by United States mail, certified, first class, postage prepaid, upon the following parties: Fred A. Paulus 1130 McGlaughlin Road Fairfield, PA 18320 ZIRULNIK SHERLOCK& DeMILLE By: "/W/V MARC MYERS, ESQUIRE Attorney for Plaintiff ZIRULNIK SHERLOCK&DEMILLE Marc Myers, Esquire IDENTIFICATION NO. 24853 309 Fellowship Road, Suite 330 Mt. Laurel,NJ 08054 -' ' I'i l v ;;f ONO TA, ;; 856-778-3220 (phone); 856-778-3222 (fax) t 2:Attorney for Plaintiff CU(1€$FRI AND co T ` : COURT OF COMMON §YLVANIA SELECTIVE INSURANCE COMPANY CUMBERLAND COUNTY a/s/o TAWNIE MILLS Plaintiff • DOCKET NO: 2012-06450 v. • FRED A. PAULUS Defendant WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY. Kindly withdraw my Appearance as Counsel on behalf of Plaintiff, Selective Insurance Company a/s/o Tawnie Mills, in the above-captioned case. 41 Marc 1� ers Es uire i (13 Y � q ZIRULNIK SHERLOCK& DEMILLE John J. Duffy, III, Esquire IDENTIFICATION NO 31263 c + i fit e, 309 Fellowship Road, Suite 330 Mt. Laurel,NJ 08054 2E3 3 OCT 1 7 PM 2: 6 856-778-3220 (phone); 856-778-3222 (fax) UMBEtL��dD COUNTY for Plaintiff PENNSYLVANIA SELECTIVE INSURANCE COMPANY COURT OF COMMON PLEAS : CUMBERLAND COUNTY a/s/o TAWNIE MILLS Plaintiff : DOCKET NO: 2012-06450 v. • • FRED A. PAULUS • Defendant ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my Appearance as Counsel on behalf of Plaintiff, Selective Insurance Company a/s/o Tawnie Mills, in the above-captioned case. 14rd Jo • . uf , II, Erire , }! U1 !' 1k E PRUTHWI U A,, ZIRULNIK SHERLOCK& DEMILLE John J. Duffy, III, Esquire 20 13 OCT 17 PIM 2: 37 IDENTIFICATION NO. 31263 309 Fellowship Road, Suite 330 CUMBERLAND COUNTY Mt. Laurel,NJ 08054 PENNSYLVANIA 856-778-3220 (phone); 856-778-3222 (fax) Attorney for Plaintiff SELECTIVE INSURANCE COMPANY : COURT OF COMMON PLEAS a/s/o TAWNIE MILLS : CUMBERLAND COUNTY Plaintiff, • v. : NO: 2012-06450 FRED A. PAULUS • Defendant. • PRAECIPE FOR DISCONTINUANCE TO THE PROTHONOTARY: Kindly mark the above captioned action discontinued without prejudice. ZIRULNIK SHERLOCK& DeMILLE By: � / _,///L , I Ada or �UF'� , i rUI'rney or , si tf