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Home My WebLink About04-5635 File #02-04-140 LAW OFFICES OF STEWART C. CRAWFORD BY: Stewart C. Crawford ATTORNEY I.D.: 09827 223 North Monroe Street P.O. Box E Media, P A 19063 Telephone: (610) 565-7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW Allstate Insurance Company als/o Christel A. Gill 309 Lakeside Drive, Suite 100 Horsham, P A 19044 IN CIVIL ACTION NO: C>L4 - ~"35 CIOitT~ vs. Ethelinda L. Adams 1131 Route 419 Womelsdorf, PA 19567 and Fernando Genao 1427 Regina Street Harrisburg, PAl 7103 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 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 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 CANNOT PROVIDE YOU WITH INFORMATION ABOUT HIRING A LA WYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGABLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File # 02-04-140 LAW OFFICES OF STEW ART C. CRAWFORD BY: Stewart C. Crawford, Esquire ATTORNEY I.D. # 09827 223 North Monroe Street P.O. Box E Media, PA 19063 Telephone: (610) 565-7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION-LAW Allstate Insurance Company als/o Christel A. Gill 309 Lakeside Drive, Suite 100 Harsham, P A 19044 IN CIVIL ACTION NO: 04 - S-f-~ LJL~~tTttL~ vs. Ethelinda L. Adams 1131 Route 419 Womelsdorf, PA 19567 and Fernando Genao 1427 Regina Street Harrisburg, PA 17103 COMPLAINT 1. Plaintiff is an insurance company licensed and authorized to do business in the Commonwealth of Pennsylvania with one of its principle places of business at the above captioned address. 2. Defendant Ethelinda Adams is an adult individual and was the owner of the motor vehicle involved in this accident on May 18,2003, and at all times pertinent hereto resided at the above-captioned address. 3. Defendant Fernando Genao is an adult individual and at all times pertinent hereto resided at the above captioned address and was the operator of Defendant owner's motor vehicle and did so as an agent, servant, workman or employee on behalf of the owner. 4. On May 18, 2003, a motor vehicle insured by the Plaintiff, hereafter the insured vehicle, was involved in an incident with Defendants. 5. On the aforesaid date, the insured vehicle was legally parked on South Front Street near the intersection with First A venue in W ormleysburg, Pennsylvania when the Defendant, who was traveling down South Front Street, carelessly struck the insured vehicle and pushing it into another vehicle causing damages to the insured vehicle. 6. Defendant driver was negligent and careless and the sole cause of this incident in that Defendant: (a) operated the vehicle at an unsafe rate of speed; (b) was inattentive; (c) failed to make proper observation; (d) violated local laws and the laws of the Commonwealth. 7. Pursuant to the aforesaid policy of insurance, Plaintiff became liable for damages that arose out of this incident. 8. Due to this incident, expenses were incurred for damage to the insured vehicle, towing, storage and car rental. 9. Pursuant to the aforesaid policy of insurance, the Common Law and governing statutes, Plaintiff is subrogated for all money paid and seeks recovery of these sums totaling $4,565.54. COUNT I PLAINTIFF vs. FERNANDO GENAO 10. Plaintiff incorporates paragraphs 1 through 9 inclusive as if fully set forth at length herein. 11. Defendant is liable as the negligent driver. 12. Defendant is liable for failing to stop at the intersection. WHEREFORE, Plaintiff demands judgment for $4,565.54 plus interest and costs of suit. COUNT II PLAINTIFF vs. ETHELINDA ADAMS 13. Plaintiff incorporates paragraphs 1 through 12 inclusive as if fully set forth at length herein. 14. Defendant owner is liable under the Doctrine of Respondent Superior for the negligence of Defendant driver. 15. Defendant owner was negligent in entrusting this motor vehicle to someone who Defendant knew or could have known was a dangerous, unlicensed, inexperienced or careless with a motor vehicle. WHEREFORE, Plaintiff demands judgment for $4,565.54 plus interest and costs of suit. ~, ~ ,'I / 11 ~{'& V~ STEWART C. CRAWFORD, ESQUIRE Attorney for Plaintiff VERIFICATION The undersigned verifies that the statements contained in the foregoing Complaint are true and correct. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa. c.s. Section 4904, relating to unsworn falsification to authorities. /I-~ f.& ~ ~ STEWART C. CRA WFORD,~7 Allstate Insurance Company iV \ .(g. ~ lI'l 0 !--3 = 0 I: c." ,CI1 '7, ,'~ "j.- 11 ;;: ;,; :;.~~ -t - lI{ c::. :1: :n ........ -.:: rnf-'- E Crt ~ ~ I ~m ~ ...0 I.D :o)? ~ () 8 ,,^\<'.J tf' ~ x'" ....i- "'-rl ;.... --n :~~ ': J (') 0 :,:-1"1:1 1- . ,~ .. ~s ~ <::0 -< FORRY, ULLMAN, ULLMAN & FORRY, PC By: Patricia Meshon, Esquire Attorney I.D. No. 65216 One Montgomery Plaza Suite 900 Norristown, PA 19401 (610) 278-7520 NOtiCE TO PLEAD STAMP TO: P/-.AlttoF:li'. . . . . . . YOU AFIE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED JUa<I ~ WITH TWENTY (20) DAYS FROM SERVICE HEREOF OR A JUDGEMENT MAY BE ENTERED AGAINST YOU. 1/1 "" 1.. _ N~:Yar~ Attorney for Defendant Ethelinda L. Adams Allstate Insurance Company a/s/o Christel A. Gill vs COURT OF COMMON PLEAS CUMBERLAND COUNTY, P A Ethelinda L. Adams and Fernando Genao CIVIL ACTION - LAW DOCKET NO.: 04-5635 DEFENDANT'S, ETHELINDA L. ADAMS, ANSWER WITH NEW MATTER TO PLAINTIFFS' COMPLAINT Defendant, Ethelinda L. Adams, by and through her attorneys, Forry, Ullman, Ullman & Forry, PC, hereby files this Answer with New Matter to Plaintiffs' Complaint: 1. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in paragraph 1 and therefore, Answering Defendant denies the allegations. 2. Admitted in part. Denied in part. It is admitted that Answering Defendant, Ethelinda L. Adams, is an adult individual. It is denied that Ms. Adams resides at the address listed on Plaintiffs' Complaint. To the contrary, Ms. Adams resides at 12 Castlegate Court, Towson, Maryland. It is specifically denied that Answering Defendant was the owner of the motor vehicle involved in this accident. To the contrary, Rudolph Adams was the owner of the motor vehicle. 3. Admitted in part. Denied in part. It is admitted that Defendant Fernando Genao was the non-permissive operator of Defendant's motor vehicle at the time of this accident. It is speicifically denied Defendant Fernando Genao was the agent, sl~rvant, workman or employee of the owner. To the contrary, Defendant Fernando Genao took possession of the motor vehicle without permission of the owner. By way of further answer, these allegations constitute conclusions of law to which no responsive pleading is required. 4. Denied. It is specifically denied that a motor vehicle insured by Plaintiff was involved in an incident with Answering Defendant Ethelinda L. Adams. To the contrary, Answering Defendant Ethelinda L. Adams was not involved in any incident of any kind with a motor vehicle insured by Plaintiff. 5. Denied. It is specifically denied that Answering Defendant Ethelinda L. Adams was involved in a motor vehicle accident on May 18,2003. To the contrary, Answering Defendant Ethelinda L. Adams was neither a operator or occupant of the motor vehicle at the time of this incident. 6. Denied. It is specifically denied Answering Defendant Ethelinda L. Adams was negligent and careless in the operation of this motor vehicle. To the contrary, Answering Defendant Ethelinda L. Adams was not an operator or occupant of the motor vehicle at the time of this alleged incident. By way of further answer, these allegations constitute conclusions of law to which no.responsive pleading is required. 7. Denied. After reasonable investigation, Answering Defendant Ethelinda L. Adams is without knowledge or information sufficient to form a belief as to the truth of the averments contained in paragraph 7, and therefore, Answering Defendant Ethelinda L. Adams denies the allegations. Moreover, the allegations contained in paragraph 7 are conclusions of law to which the Pennsylvania Rules of Civil Procedure require no responsive pleadings and are therefore denied. 8. Denied. After reasonable investigation, Answering Defendant Ethelinda L. Adams is without knowledge or information sufficient to form a belief as to the truth of the averments contained in paragraph 8, and therefore, Answering Defendant Ethelinda L. Adams denies the allegations. Moreover, the allegations contained in paragraph 8 are conclusions of law to which the Pennsylvania Rules of Civil Procedure require no responsive pleadings and are therefore denied. 9. Denied. After reasonable investigation, Answering Defendant Ethelinda L. Adams is without knowledge or information sufficient to form a belief as to the truth of the averments contained in paragraph 9, and therefore, Answering Defendant Ethelinda L. Adams denies the allegations. Moreover, the allegations contained in paragraph 9 are conclusions of law to which the Pennsylvania Rules of Civil Procedure require no responsive pleadings and are therefore denied. COUNT 1- Plaintiffv. Fernando Genao 10.-12. Denied. These paragraphs are not directed to Answering Defendant Ethelinda L. Adams and therefore no responsive pleading is required. WHEREFORE, Answering Defendant Ethelinda L. Adams requests judgment in her favor and against Plaintiff and Co-Defendant together with attomeys fees, interest and costs. COUNT II - Plaintiffv. Ethelinda L. Adams 13. Answering Defendant Ethelinda L. Adams incorporates by reference its answers to paragraphs 1 through 12, inclusive, as fully as though the same were herein set forth at length. 14. Denied. It is specifically denied Defendant Fernando Genao was operating the motor vehicle at the time of this incident with the permission of the owner. To the contrary, Defendant Fernando Genao was a non-permissive user ofthe vehicle at the time of this incident. By way of further answer, these allegations constitute conclusions of law to which no responsive pleading is required. 15. Denied. It is specifically denied Defendant Fernando Genao was operating the motor vehicle at the time of this incident with the permission ofthe owner. To the contrary, Defendant Fernando Genao was a non-permissive user ofthe vehicle at the time of this incident. By way of further answer, these allegations constitute conclusions of law to which no responsive pleading is requiredo WHEREFORE, Answering Defendant Ethelinda L. Adams requests judgment in her favor and against Plaintiff and Co-Defendant together with attorneys fi~es, interest and costs. NEW MATTER AGAINST PLAINTIFFS 16. Plaintiffs cause of action is or may be barred or otherNise limited by the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa. C.S.A. Section 1701, et seq., as amended. 17. Pursuant to the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa. C.S.A. Section 1701 et seq., as amended, Plaintiff is precluded from pleading, introducing into evidence, providing or recovering the amount of benefits paid or payable under said Act up to and including the limit of required benefits under said Act. Answering Defendant hereby asserts all the defenses, limitations, and immunities available to him under said Act. 18. Plaintiffs cause of action is or may be barred or otherwise limited by the doctrine of comparative negligence. 19. The injuries sustained by Plaintiff, if any, were caused by the negligence of others over whom the Answering Defendant has no control or whose conduct they had no reason to anticipate. 20. Plaintiffs Complaint fails to state a cause of action upon which relief may be granted. 21. Answering Defendant Ethelinda L. Adams was not th~~ owner ofthe subject vehicle on May 18,2003. 22. Defendant Fernando Genao was a non-permissive user of the vehicle on May 18,2003 at the time of this incident. NEW MATTER CROSSCLAIM AGAINST DEFENDANT FERNANDO GENAO 23. Answering Defendant incorporates Paragraphs 1 through 22 above as though fully set forth herein at length. 24. Answering Defendant Ethelinda L. Adams was not th~~ owner of the subject vehicle on May 18,2003. 25. Defendant Fernando Genao was a non-permissive user of the vehicle on May 18,2003 at the time of this incident. 26. Answering Defendant asserts that if in fact the allegations contained within Plaintiffs' Complaint are true, then Defendant Fernando Genao is alone liable to Plaintiffs. 27. In the alternative, should Answering Defendant be found liable, she avers that Defendant Fernando Genao is jointly and severally liable or liable over to Answering Defendant. 28. Any liability on Answering Defendant is specifically denied. WHEREFORE, Answering Defendant demands judgment in her favor and in the alternative demands judgment by way of contribution and/or indemnity or liability over from Defendant Fernando Genao. FORRY, ULLMAN, ULLMAN & FORRY, PC BY: ~~~HO(1~ Date: I:) -;)0- 04 VERIFICATION I, Patricia Meshon, Esquire, being duly sworn according to law, depose and state that I am authorized to take this Verification on behalf of Detl:::ndant, Ethelinda L. Adams, , and that the facts set forth in the Defendant's Answer with New Matter to Plaintiffs Complaint are true and correct to the best of my knowledge, information and belief. 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. p=s~ Date: December 29,2004 FORRY, ULLMAN, ULLMAN & FORRY, PC By: Patricia Meshon, Esquire Attorney I.D. No. 65216 One Montgomery Plaza Suite 900 Norristown, PA 19401 (610) 278-7520 Attorney for Defendant Ethelinda L. Adams Allstate Insurance Company a/s/o Christel A. Gill vs COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Ethelinda L. Adams and Fernando Genao CIVIL ACTION - LA W DOCKET NO.: 04-5635 CERTIFICATE OF SERVICE: I, Patricia Meshon, Esquire, hereby certify that a copy of the Defendants' Answer with New Matter to Plaintiffs' Complaint was forwarded, this date, by 1irst-class mail, postage prepaid, addressed as follows: Stewart C. Crawford, Esquire 223 North Monroe Street Media, PA 19063 ~d1;,W7Al ~ Pa ricia Meshon, Esquire Date: December 29, 2004 -" r~ " f' :> ,~. r,. " '> c.:" ~. ~. q ~.~,: <" r-J .-_~ C..:::> c:.n <- ~; - I W :: \ -<. -? _.~ -.... ~ .-\ :t;-!J fl P;, -rJ!:-., ""t1~ "') l'1(~ ~'C -1) ~;;O f~~rn ~::, s;? c..n N -'p. '--1 ::<. FORRY, ULLMAN, ULLMAN & FORRY, PC By: Patricia Meshon, Esquire Attorney I.D. No. 65216 One Montgomery Plaza Suite 900 Norristown, P A 19401 (610) 278-7520 Allstate Insurance Company alslo Christel A. Gill vs Ethelinda L. Adams and Fernando Genao Attorney for Defendant Ethelinda L. Adams COURT OF COMMON PLEAS CUMBERLAND COUNTY, P A CIVIL ACTION - LAW DOCKET NO.: 04-5635 AGREEMENT PURSUANT TO RULE 237.2 TO EXTEND TIME TO PLEAD FOLLOWING TEN-DAY NOTICE It is agreed that Defendant, Ethelinda L. Adams, is gmnted an extenstion of time through FE8Rv4~..,::JO Jo~'5in which to file: o a Complaint L an Answer an Answer or Preliminary Objections After the above date, a judgment of non pros or by default, as may be appropriate, may be entered upon praecipe without further noticeo Date: /J-(-J() (0 ~ Date: I:;> /31 /v'-/ MAl3qA At Stewart C. Crawford, Esquire Attorney for Plaintiffs (7.~ ~ Patricia Meshon, Esquire Attorney for Defendant Ethelinda L. Adams o ~ Q1F' /:,.- ;--" L... __.. (..to"; .'. ~:i~.' . ~- zE )>~ "':.. =<' '" c=:> = c;.rl c.:.... ;p.o Z , .r:- ~ --I :r:-n fl1F "'Or11 :n9 r)_) ~c :..-,..l.-! ,- .., ~ ~,?C) f~m :::~ :s; ~ 'i? o 0"\ '~\'] :< FORRY, ULLMAN, ULLMAN & FORRY, PC By: Patricia Meshon, Esquire Attorney I.D. No. 65216 One Montgomery Plaza Suite 900 Norristown, PA 19401 (610) 278-7520 Attorney for Defendant Ethelinda L. Adams Allstate Insurance Company a/s/o Christel A. Gill vs COURT OF COMMON PLEAS CUMBERLAND COUNTY, P A Ethelinda L. Adams and Fernando Genao CIVIL ACTION - LAW DOCKET NO.: 04-5635 PRAECIPE TO SUBSTITUTE VERn~ICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification of Ethelinda Adams, for the attorney's Verification to the Answer and New Matter, which was filed on or about January 3, 2005, in the above-captioned action. Respectfully submitted, FORRY, ULLMAN, ULLMAN & FORRY, PC BY: 7dtlZiUlj~ P A TRlCIA MESHO , ESQUIRE Date: January 6, 2005 VERIFICATION I, Ethelinda L. Adams, defendant, verify that Defendant's Answer and New Matter with New Matter Crossclaim to Plaintiffs Complaint is true and correct to the best of my knowledge, information and belief. I understand that falsie statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. ~-~ --L1: ~/~~ , Ethelinda L. Adams Date: 0\ FORRY, ULLMAN, ULLMAN & FORRY, PC By: Patricia Meshon, Esquire Attorney I.D. No. 65216 One Montgomery Plaza Suite 900 Norristown, P A 19401 (610) 278-7520 Attorney for Defendant Ethelinda L. Adams Allstate Insurance Company a/s/o Christel A. Gill vs COURT OF COMMON PLEAS CUMBERLAND COUNTY, P A Ethelinda L. Adams and Fernando Genao CIVIL ACTION - LA W DOCKET NO.: 04-5635 CERTIFICATE OF SERVICE I, Patricia Meshon, Esquire, hereby certify that a copy of the within Praecipe to Substitute Verification was forwarded on this date, by first-class mail, postage prepaid, addressed as follows: Stewart C. Crawford, Esquire 223 North Monroe Street Media, PA 19063 FORRY, ULLMAN, ULLMAN & FORRY, PC BY: J~L~ PATRICIA MESHON, ESQUIRE Date: January 6, 2005 , jt, r Cli, -' C; '-- () C t-' = 5~ '- :,:-~ ;.t:: ....-i c::> n ;01'1 ::2 -n rn---: -n2: ~0~;: j C~; -r"!-i :::-!\ :~ ::~:: ~? \..0 -, .I } 1: :!':lcJS!:-:l:3 ",','.,1",-, A ((s{a:k. ;DISufaJ?ce C, {'<-/Jar uIp (lV(" Ie I A G- 1/( IN 'fhL c\.. "JRT {j~ "i':" , CI)i'I-~}:i}":;';I, ',,\';": 'V), NO O~-Sb35 E.-ft,e-Ln d ~ L ;1dQ/11) 6cI'\J FQrnCAndu Ge.no.~ Rl,..~LE t~t!.,,! . fhe Petition for Appolntmeor of ArbitrlJtor~; ;;h~:l\ be 1": ) >~ (;:,j\ PETITION FOR APPOINTMENT OF AI!.mTI~/oln'H/ iU THf: d'L",)RABLE, THE JUDGES OF SAID COURT: ?~~~};~;~:,~~~1.JTl+___, coun~d lor ,he The aboveMcaptioned action (or acl1oJ1s) is (~..ll"e~ ,H ;f,~-"if 1'1>, claim of the plaintiff illtbc acti<.>tl if $..':45~5,5L:L .. i'h" f.::otll1tct:"'..:1aim of the de.fendant in ~ht' wJ:Ol~ :.',:: de~~~rh.;HnL Ii" (h~~~';:',H\lwn,,;' ,1tliJrh~YS arc interested in the case(s) as (;!,\I~lir.el nr ~,rcJthe.I'-,.';$\':.~ ," " '-;l!~ PO-if!.c \c-.[y:te~o..C\."C5t,-_.ol'(j1.ALl!9~(I1J!rfla.<<41t5.S(.,lc.dt.. ~{)vi-le q W~;J~rr\rf~(J,,[1 J ~A,I(ND I ,',;Lt'-"llt7;",i, ','.; ~.j ;';,!<CH_':d-;J , ,\'c1tlr p{~H'ilJne;r pnl)'S your HonQrable emir! flJ HJ.-~p~)int. tr1Y,"'l_~::; .';l ,~r:'~~',(L'h,'j:;: tl~! -,.C,_ n(!~; ij",;e: . jl""""dfulh "0'),""<'. () 1>WC. 7{ ORDI<~R Of CmiRI " \if) NOW, _._ 19.._ ,__ m l\"tl'~;'~;!";" I;' \f" ;'},., f'" t ,l::.ion! "__"___"_"_'~__._____...~____________,,_~__ Jnd - ~________________,__' Esq., an!" applJintf.:d :l:'bi_kdt(~r;.; it nKi ::.lHi\ (: f. ~; ;L U_l',r..!n ;,!.C. IHaVE'd RilL ''.'If;' (:i~;_;~-~ . p\.J~ ~ 'i ~ -- -- (Y ~~-v ~--.Jp- ~ ~ l8: V\ .." '"'"' 0:> N .c- ~ s N W { ~ ; ,.. j';:),-; 71 i';~'~(jtii:, i'J r;..,:::: :T~I!'";'f; At(s1aJ(! ;Dr>ura.170? C('<.jJtV'Lv r;/<p (/v,Sfe t .A . G- /I! ( \/5. U"'"1 ({ -",iRf ~, ,,' C,,'/ J.!';tb:?~::;;.1., ." :<T: F(i M- S Cc,35 or' , t1h~I:n clk... L AdcuIo15 6-"J re(f\c..,,~U Gef)o..~ ,4{i'}LF t3l-.~.1 'flu': Petition for Appointment of Arbi['rHtcf~~ ;;~'Idj be ", ,I,,, ;",oIl, PETITION FOR APPOlNTMEN'f or I',RmTl~Fi(i,fI.:', :.'.J TllF dl,~!ORABLE. THE JUDGES OF SAID COURT: SklilU{tC,_Crc~t'J)i+. _.__. counsellof eM nicwrih' i"l' ;'('pn:~wnt~. th"u: The: Hhove-captim-,ed acticn (or acJlons) )s (~ji.'e) ;H~'S1-,'iit' Th, claim of \he plaintiff ill the actiol1. i~, $.=45_bf).5'":!_ The o;.o~lnterdf.lim of fjle def!::odant in i:he n:-.tlcr.~~,;_,..,,,_ ii" ~b4' ,- ,,-;. (1:(; :"OH(hVt'iJ;', ,1H\)rrL~Y$ arc interested in the ca~le(s) as cnPiI.::.d J.'lr nrc: 'Jth.~r./j(,;e,', r:l, ,'1', ;\~I~ Pa.1\'ic ~0-..[y-'kSbw:l,C'>t,,_..Ohd'I)~At~L"1-e.crf[(l'44~S.~\!,le.dtS-l.)v'1e q CQ.N~rrirf~W'11 ~A, N'lo I \-\'.1:,~-t(I~H H-d." :hJu,r p~:titiQnei prays your HOr1orable CO\.Ht h,) Dpp:JI_M tkl'.~~;i ;;~;::';;_~ :~;'i,T" ~i") ,,;- :'!f"T;', ll~-!( -~ ""b!"\ii.:J~,j" ~NiC'\t',~ ORl>ER OF eOliR'! \\ID NOW, J~L_..__._......._ .....' f'j.~t~ 'in c..'",,;;,:",,,;,',,,,,'' ,j.. ) , '\ l i/ / --b' !:J'i'''',:~;~:,;.; 1~'.'.i.,.I..i.~ /A~"~' '-"7'ti.._~f.,.~ ;;~UK ,----",q ,~ M<(UdU _ _ ~H_~"""-L/..:.._ -,--1-4 __ __ ,Esq" are nFPoint;~d 3rbi_h:ltf!r:;~ it lh::: ,J_<ti,(: ,~"u:: ;)::~o)t,~:, ~,-L., IJ1Zt'fed" L .c-'. P7' Ilf '''''1 :""" " , ~.'...., 'I ' ',;:1 C,:_-,' C '::'. : .:~ ~'" pr.J~ ~ 'l ~ -- -- \:J ~~-v ~---Jp- ~ ~ ~ k.I'\ '"" '" 0> N .c- ~ o N <:..,:\ SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-05635 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ALLSTATE INSURANCE COMPANY ASO VS ADAMS ETHELINDA L ET AL 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: ADAMS ETHELINDA L but was unable to locate Her In his bailiwick. He therefore deputized the sheriff of BERKS County, Pennsylvania, to serve the within COMPLAINT & NOTICE On December 15th, 2004 , this office was In receipt of the attached return from BERKS Sheriff's Costs: Docketing Out of County Surcharge Dep Berks County 18.00 9.00 10.00 57.00 .00 94.00 12/15/2004 STEWART CRAWFORD So answers..:-----.-~ - _....~:~~~~~--- ') .-.... ...C/ c-..:--.... . ....:._.'''. _A/ 'C~.~~ R. Thomas Kline Sheriff of Cumberlan Sworn and this (,. 5;:. subscribed to before 7 day of Lk".AJ I me 2Pv-.5 A.D. ClYJ-- 0 ~-<.J~ ~ I Prothonotary) SHERIFF'S RETURN - OUT OF COUNTY .. CASE NO: 2004-05635 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ALLSTATE INSURANCE COMPANY ASO VS ADAMS ETHELINDA L ET AL 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: GENAO FERNANDO but was unable to locate Her ln his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT & NOTICE On December 15th, 2004 , this office was ln receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin County 6.00 9.00 10.00 26.25 .00 51.25 12/15/2004 STEWART CRAWFORD So answers:'? "/<. ,-~;:;~('/.~ i:7 R / Thomas Kl ine ( Sheriff of Cumberland County Sworn and subscribed to before this I. ~. day of (}~"I :J.A/CJ ,<) A . D . L'4~ Q~ hAf..P", ~~ I Prothonotary' me in The Court of Common Pleas of Cumberland County, Pennsylvania Allstate Insurance Company VS. Ethelinda L. Adams et al SERVE: Ethelinda L. Adams No. 04-5635 civil Now, November 10, 2004 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Berks County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~,""'" u? /...//':.~' ~ ~...1" ..;f'~:f' ..;~;;,,-.,.,..~..,.fF" ."..r; . ...;.<i~., ......c:":_..,,.. {$" i.-'....-<.,..f? .1 . - -' ~/ ...'..,"'...,.,-~. Sheriff of Cumberland County, P A Affidavit of Service ,20_, at o'clock M. served the Now, 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 AFFIDA VIT $ $ SHERIFF OF BERKS COUNTY 633 Court Street, Reading, PA 19601 Phone: 610-478-6240 Main Fax: 610-478-6222 Sheriff Fax: 610-478-6072 Barry Jozwiak, Sheriff Eric J Weaknecht, Chief Deputy AFFIDAVIT OF SERVICE DOCKET NO. 04-5635 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BERKS Personally appeared before me, FREDERICK SMITH, Deputy for Bany J. Jozwiak, Sheriff of Berks County, 633 Court Street, Reading, Pennsylvania, who being duly sworn according to law, deposes and says that on NOVEMBER 29, 2004 at 7:00 PM, he served the annexed COMPLAINT IN CIVIL ACTION upon ETHELINDA L. ADAMS, within named defendant, by handing a copy thereof to PAULINE L. ADAMS, ADULT MEMBER OF HOUSEHOLD (MOTHER), at 1131 RTE 419, WOMELSDORF, Berks County, Pa., and made known to defendant the contents thereof. ~~~ DEPUTY SHERIFF OF BERKS CO., P A and subscribed before me day of DECE BER, 2004 S CO., PA Service made as set forth above. NOTARIAL SEAL Tammy Rodriguez. Notary Public Reading, Bcd;s County My commissi?n,~~xpire~.Oclober6,2007 So Answers, R,~ (] (k.../ Sheriffs Costs in Above Proceedings $ 75.00 DEPOSIT $ 57.00 ACTUAL COST OF CASE $ 18.00 AMOUNT OF REFUND All Sheriff's Costs shall be due and payable when services are performed, and it shall be lawful for him to demand and receive from the party instituting the proceedings, or any part liable for the costs thereof, all unpaid sheriffs fees on the same before he shall be obligated by law to make return thereof _Sec. 2, Act of June 20, 1911, p.L/IOn In The Court of Common Pleas of Cumberland County, Pennsylvania Allstate Insurance Company VS. Ethelinda L. Adams et al SERVE: Fernando Genao No. 04-5635 civil Now, November 10, 2004 , 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. ~ _,r,' ~. .- ,~<---::;(' _ ~~ R ~ _..,~ t"" .-"- . ".;.*~"",-;:s?J.4__ .'1'. /~~....~.6 ~l ....,,""l~. . ........ Sheriff of Cumberland County, P A Affidavit of Service ,20_, at 0' clock M. served the Now, 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 AFFIDA VIT $ $ . .. @Hite of tq~ ~lr~:r-iff William T. Tully Solicitor J. Daniel Basile Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania ALLSTATE INSURANCE COMPANY vs County of Dauphin GENAO FERNANDO Sheriff's Return No. 6955-T - -2004 OTHER COUNTY NO. 04 5635 AND NOW:Novernber 17, 2004 at 10: 03AM served the within COMPLAINT upon GENAO FERNANDO by personally handing to ANGELICA MATEO-SISTER 1 true attested copy(ies) of the original COMPLAINT and making known to him/her the contents thereof at 1427 REGINA STREET HARRISBURG, PA 17103-0000 Sworn and subscribed to So Answers, JR~ before me this 18TH day of NOVEMBER, 2004 ~ By Sheriff of Dauphin County, Pa. ~f!::L Sheriff's Costs:$26.25 PD 11/16/2004 RCPT NO 201585 NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County My Commission Expires Sept. 1,2006 KC FORRY, ULLMAN, ULLMAN & FORRY, PC By: Patricia Meshon, Esquire Attorney 1.D. No. 65216 One Montgomery Plaza Suite 900 Norristown, PA 19401 (610) 278-7520 Attorneys for Defendant, Ethelinda L. Adams and Plaintiff, State Farm Insurance Company Allstate Insurance Company a/s/o Christel A. Gill vs COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Ethelinda 1. Adams and Fernando Genao CIVIL ACTION - LAW and DOCKET NO.: 04-5635 and 05-1473 State Farm Insurance Company vs. Fernando Genao and Allstate Insurance Company PETITION TO CONSOLIDATE I. The above-captioned actions arise out of the same motor vehicle accident that occurred May 18,2002. See copies of the Complaints at Exhibit "A" and "8" attached. 2. The above-captioned actions arc both arbitration matters pending bel'ore Cumberland County Court of Common Pleas. 3. The parties in both actions are identical. 4. There are common questions of fact and law in both actions. 5. The consolidation of these matters will be convenient for all parties, witnesses and counsel. 6. The consolidation of these matters will save time and money for the parties and witnesses. 7. The consolidation ofthese matters will avoid duplicative and/or inconsistent Rulings, Orders or Judgment. 8. The consolidation of these matters will not prejudice any of the parties. 9. If these matters are not consolidated, the parties may be prejudiced. 10. The consolidation of these matters will result in judicial efficiency and economy. WHEREFORE, Plaintiff State Farm and Defendant Adams respectfully rcqucst this Honorable Court consolidate the above-captioned matters into one case. Respectfully submitted, FORRY, ULLMAN, ULLMAN & FORRY, Pc. By: .) . - .' P~I~I~~~S~O~, ~Q~~~ DATE: ;; - 2../ -c\ FORRY, ULLMAN, ULLMAN & FORRY, PC By: Patricia Meshon, Esquire Attorney J.D. No. 65216 One Montgomery Plaza Suite 900 Norristown, PA 19401 (610) 278-7520 Attorneys for Defendant, Ethelinda L. Adams and Plaintiff, State Farm Insurance Company Allstate Insurance Company a/s/o Christel A. Gill vs COURT OF COMMON PLEAS CUMBERLAND COUNTY. PA Ethelinda L. Adams and Fernando Genao CIVIL ACTION - LAW and DOCKET NO.: 04-5635 and 05-1473 State Farm Insurance Company vs. Fernando Genao and Allstate Insurance Company MEMORANDUM OF LAW IN SUPPORT OF PETITION TO CONSOLIDATE FACTS These actions concern a motor vehicle accident that occurred on May 18. 2003. Defendant Fernando Genao took the vehicle insured by State Farm and owncd by Defendant Ethelinda Adams' father without permission. Defendant Genao struck the vehicle owned by Christel Gill and insured by Allstate Insurance Company. Allstate and State Farm have each brought subrogation actions to recover for the property damage claims which they have paid to their respective insureds. LAW These actions arise out of the same motor vehiclc accident that occurred May 18,2003. Pursuant to Pa R.C.p. 213(a) these matters should be consolidated to avoid unnecessary cost or delay. Pursuant to Pa R.C.P. 213.I(c) these matters should be consolidated for the following reasons: I. There are common questions of fact and law. 2. Consolidation will result in convenience to the parties, witnesses, and co unse 1. 3. Consolidation will result in saving time and money for the parties. 4. Consolidation will prevent duplicative and/or inconsistent Rulings. Orders or Judgments. 5. Consolidation will result in judicial efficiency and economy. CONCLUSION For the reasons stated above, this Honorable Court should order consolidation as per the proposed order. Respectfully submitted, By: FORRY, ULLMAN, ULLMAN & FORRY. P.c. ,/} .' j......: /~. Ie { . '-. ,.1 ,. .1 .' ._' '.' / .; _-/, C I 'Cc __C/t ___, _0<:.___ C, } ,_j PATRICIA MESHON, ESQUIRE EXHIBIT" A" 12/27/~004 15:32 Ibl~tttLq~~ 12/23/04 THU ~6'lg FAX 610 1173 1"2/22/2554 23: 55 717Ek_~395 ........ ./ ~ ..... . __.o_ I ......'~." - ~002 . PAGE Bl READING I<E\.l.. V PARKS 02-04-140 LAW OFFICE OF STEWART C. CRAWFORD & ASSOCIATES BY' Stewart c. CrawtitId, Hsquire ATrORNBY LD. # 09827 223 North Momoc StRlct ATTORNEY FOR. PUJ:NT1FF Media. PA ISlO63 Te~h~:~I~S6>7050 dl.. 3f. f) /93,';; aJ-t" tf(/ IN""rHIieoURTOFCOMMON PLEAS OF CUMBBlU.ANDCOUNTY, PENNSYLVANIA C1VlL ACTION-LAW ALLSTATE INSURANCE COMPANY 81s1o CHRISTEL A. GILL : IN CML ACTION VS. ETBELINDA L. ADAMS It. FERNANDO GENAO NO: 04-5635 TO: E'1HB1JNDAL. ADAMS 1131 RTE419 WOMBLSDORl<.PA 19.567 .- -.---.- DATE OF NOTICE: DBCBMBER 21. 2004 IMPOIt1'ANT NOTICJ You are in defiwlt because you have. failed to 1IlCe actionrequircd of you in this ClI8t\. Unl_ you act within Ten (10) o.,.:A-om the dale of!.f1is DOtille, alvdgmcntwill be ...llW~ against you without a heating IlIld you may 10Ie property or other inJportant rights. You should.take this notice 1tJ a Jawyer at once. If you do not have a lawyer or can not llfford one. go to f1( telephone the following offi" to find out w1tere you 0lIIl get lcpl hc:lp: CllmberJaud COWlty Lawyer :\tefom.l Serville Taryn Di1UlJl, Court Administrator ~ Courthouse Squs:e Cllflisle, PA 17013 (717) 240-6200 b k riJf CnJ,J SnWAR: C. CRA ,ESQ. Attornc:y for PWn~8) i ......' ......~ v"t! .........1,.(> r'-'1A lI.LU.,J I .L.L.L f.J -~._-- 12/~2/2B84 23:91 7176569395 KEU. y PARKS PAGE '1l2 , ' rUB #02-04-140 UWOflOlCE5 OF STEWART C. CRAWFOlW :::0 BY: SiewlIrt C. Crllwt'ord .m A'ITORNEYloP.: 091121 (") 223 NllI1h Moutoe Street !:!!. P.O. BOll B < . Me4ioo, PA 1!1063 m Tclcplooae: (610) S6S-7l>50 '0 '*' 1N'l'BE C01JllT OF COMMONJ."L):.;.S OF ~COUN1T,l'ENNSYL~ CIVIL AcrION.LAW - .8 ~ n ocr. c:;:::t: :z rrt. -t:::";." -<~ 0"'" ""'0 =-" rn"Tl ;;g- ;:or;M en"" = .= """ N "t) Ans-Insunm:e Company aJslo CJuistIel A. GlII 309 Lakeside Drl"., Sui1e 100 1ioToboto, PA 19044 IN C1VIL ACTION NO: O'l - J:t.."JS Q;.~...L IE~~ V8. Ell>..1i.riA L. Adams 1131 ao-419 WOlVI'I""-f. PA 19567 and TRUE COPY rr.1'1')~o~ P,fiOORD Il\TtoSdIMI:ywhDr~>' . _ . 'j,i'.Hit:A1Y" i'?~ 01 SJj~. . .a WlIiM. Pa. - ~ .~ ~:~i,,~ Fll1DllIJdo G.mIo 1427 RJlsiua ~ Harriaburg, l"A 17103 NOTICE T9 D~ You have been SI2l!d in court. If you wish to defend agaillSt the clainu set forth in the following p8gC8, you must tab action within twenty (20) da:ys after this complaint and notice are -II, . by euterizlB a wnttan appelIZ'lII!CCl.persolIIllly or by an attomey and filing in writing with the court your defcolles or objections to the clldms set fonh agaiJIst you. Yau _ wemed 1hat iEyOU iioil to do so tile lllISe may proceed wi1hout you and ajudgmcmt may be enteJ;ed IlglUnst you by the C01Itt 'IlVllbi>Ur fI1rlher notice for 11II)' money claimed in the complaint at" for lQ\Y ether relief mqui!$tCd by :the plaUrtiff. Yau may lose moDey or property or other rights imporlllDt to you. YOU SHOULD TAKE nus PAPER TO YOUR LA WYBR A.T ONCE. IF YOU DO NOT HAVE A. LAWYER, GO TO OK TELEPHONE THE OFFICE SET FORTH BELOW. TInS OFFIC};; CANNOT PROVIDE YOU wrrn'INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER. nus OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCmS THAT MAY OFFER LEGAL SERVICES TO ELIGABLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAA ASSOCIATION 32 soum BEDFORD STREET 'CARL1.ISLE,PA 17013 (717) ;l49-3166 (800) !/9()..!JI01l ..L..I....I Vii .1":: Hf tr"U 610J711173 blAl.c J:n.&"UU. ....~,_ 12/02/2664 23:~1 71786S5395 KE1..L '/ PARKS PAGE: 113 File # 02.04-140 LAW Ol'l'lCES.OF sn;w ART c. CRAWFORD _BY: Blewitt C. Cr&wflml.Ellquin: ATIORNEYI.D. #-09827. 223 North Monroe S1reet P.O, Box E Media, PA 19063 '!"elephonc: (610~ 565-7050 IN TBE COUkT OF COMMONPUAS. OP CIl'MBERI.1.ND CQDNn". J'ENN$YLV ANL\ CIVIL AcrION-UW ~ lI>surIwoe eompe..y ""slo ~lA.GiU :309 ~idc Drive. Suite 100 -Horsbmn. PA 19044 IN CIVIL ACTION NO: vs. ~1h14a L. Admns 1131 Route41~ W0III81edorf. P A 19S67 ad !I'emaDdo Geuao 1427 R.cl8iDa S1Ject HsmIburg.PA 17]03 'COMPLAINT 1. Plaintiff is an.insunulce contpanY licensed and lLUThori:zed to -do business in tba Commonw.:altb of'Pennsylvania with one of its princ;Xple pW:es of business at tha above captioned acldreso 2. Defendant Etbelinda Adams is an adult individual and was the owner of the motal" vehicle involved in fIili, w.:cidcnt 011 May 18. 2003, lIlld ~ all 'limes pertinent heret<> l"e3ided at the above-captioned lIddre&s. 3. Defendant F Bt%I8XIdo Genao is an adult individual and at all times pertinent hereto res.idcd at the above captioned llddress II.l1d was the opc:raror of DefimtlAnt OWllClr' 5 motor vehicle and did so lIS 'lLl1 agent, 5el:VImt, workman pr exnployee on behalf of the ownCCo .l"(~"/U~ i4:19 ~'AX 6103711173 ~1.Al.o rJ1.l\JU I . .a.!~.... On May 18. Z003, & mJ ~"le inaU!ed by the P1am~ berllSfierthe I inaun:d vehicle, was UtvolVed in an incident with Deflmdants. On the afore8!lid eWe. tb~insured vehicle _legally parked on South . FrDJl.t Street = the ~on with First Avc:uue in Worm1eysburg. l'czmsyJvania whClfl the DlmOndant. wIlo 1I/&g tnM:line down south Front S1reet, oare1aa1y struok ~ insured wbicl" IIDd pushitJg it into l1I1Otb.cr vebicle causing dl!magelllto the in.sured vehicle. , . Dc:fend.'lt driver,.-us netfugent SDd careless and the sole cause ofthi& lmrident in that D~ (a) operated the vehicle at all unsafe om: of speed; (b) was ~ve; (c) failedto~properob5erv~on; (d) violated ~ laws and the lilWll of the Commonwealth. PumJant to tho; ai'onlSIUJ policy of insurance, Plairrtif'fbceame liable for damaa.... that arose out Jthis incident Due to this inciclent. + ware iI1l:umld for ~!V' to the iDsuzecl vemck, lOwing, stora211 ~ ac re111al. . PumIant w the aforesaid policy of iDsurance, the Common Law lUId govemiJIg statutes. PI~ is subrogated for all money paid aDd seeks recovery ofthcse IJUlm tbtwmg $4,565.54. I I , I COVNTI Pt..AlN11'FF VI. FERNANDO GENAO I Plaintiff iDcotpOrates pmg:raphs I through 9 inclusive lIS if fUlly set forth at length herein. I Defendanl is liable as die negligent driver. I 1:Z. Defendant is liable :fur OOing to stop at the intersection. WHEREFORE, pJAI_lf'f ,l~J". judgment for $4,565.54 plus interest and oasts {Jf wit. 12/82/2804 23:01 10. 11. 7179669395 KEU.. Y PARKS p~ "'4 4. 3. 6. 7. i. 9. 12/22/04 12:19 FAX 6103711173 - ---- STATE FARM INS 12/62/2664 23:B1 7178669395 KEU. V PARKS PAGE 85 'COUNT~ 1'LAINTlFF1n. ETHELINDA ADAMS 13, ~1..w;ffinco1'pOf8leS ~ 1 through 12 inclusive as iffully set forth << Ic:ugth herein. 14. t>efimdaut CJWIIet" is li8ble'undc:r the Docttine of~ Superior for ,the uegIigenc:e ofDefwd'lIJ!. driver. 15. DefeDchmt owzuor was negligent in mnusting this motor ~c1e to wmeone who Dc:fewlallt knew or could have k:llown WBS a dangerous. ,unlicensed, inexperi8l1Ced or careless with a motor vehicle. WHEItBFORB. l?laintifl' <I",",*OIl~ judgtttent far 54,565.54 plus inllerest aad costs ofsuit. , ~ .Jt-~c7& STEWART C. CRAWFORD. ESQ AtlDmey for Plaintiff .lVl:V041 12:20 FAX 6103711173 SrAn~,; 1'JUU1 ..1J.'1":) .2/62/2~~4 23;61 7179&.9395 KEll. V PARKS FAa: 86 .. . VERIFICATION The lIlIdetsignecl verifies:that tbe statements contah1cd in the ~ing COIlIplaint lII"C-nue lIIlC1 ~..~C;t. The t1lldersigued UDderstands :that false statelMrI%s b-m are made subject to tile peaa1ties of 18 Pa. C.S. SeetiOll 4904,...JstlDa to UDS\VOltI f8Jsi1ic;etiOIt to authori1ics. ~/ e:rt__~ STEWART C. CRAWFORD, ES Al1state Irmmmce COlI1JllUlY \ E1(l:llBl'f "u>' FORRY, ULLMAN, ULLMAN & FORRY, P.C. BY: PATRICIA MESHON, ESQUIRE Attorney I.D. No. 65216 One Montgomery Plaza, Suite 900 Norristown, PA 19401 Attorneys for Plaintiff, State Farm Insurance Company : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA. STATE FARM INSURANCE COMPANY NEWTOWN SQUARE 8 CAMPUS BLVD. PO BOX 499 NEWTOWN SQUARE, PA 19073 : NO.: vs. FERNANDO GENAO 1427 REGINA STREET. HARRISBURG,PA 17103 And ALLSTATE INSURANCE COMPANY 309 LAKESIDE DRIVE SUITE 200 HaRSHAM PA 19044 9226 ROOSEVELT BLVD. PHILA., PA NOTICE YOU HAVE BEEN SUED IN COURT, If you wish to defend against the claims set forth in the foregoing pages, you must lake 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 clams 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 OR KNOW A LAWYER, THEN YOU SHOULD GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service ]00 West airy Street (Rear) Norristown, P A 19404-0268 Telephone No. (6]0) 279-9660, Ex!. 20] FORRY, ULLMAN, ULLMAN & FORRY, P.Co BY: PATRICIA MESHON, ESQUIRE Attorney LD. No. 65216 One Montgomery Plaza, Suite 900 Norristown, PA 19401 Attorneys for Plaintiff, State Farm Insurance Company STATE FARM INSURANCE COMPANY NEWTOWN SQUARE 8 CAMPUS BLVD. PO BOX 499 NEWTOWN SQUARE, PA 19073 ; IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA. : NO.: vs. FERNANDO GENAO 1427 REGINA STREET HARRISBURG, PA 17103 And ALLSTATE INSURANCE COMPANY 309 LAKESIDE DRIVE SUITE 200 HORSHAM PA 19044 9226 ROOSEVELT BLVD. PHILA., PA COMPLAINT I. Plaintiff is an insurance company licensed and authorized to do business in the Commonwealth of Pennsylvania with one of its principle places of business at the above captioned address. 2. Defendant, Fernando Genao, is an adult individual and was the non- permissive driver of the motor vehicle involved in this accident on May 18, 2003, and at all times pertinent hereto resided at the above-captioned address. 3. Defendant, Allstate Insurance Company, is an insurance company licensed and authorized to do business in the Commonwealth of Pennsylvania with one of its principle places of business at the above-captioned addresses. 4. On May 18, 2003, a motor vehicle insured by the Plaintiff, hereafter the insured vehicle, was involved in an accident after Defendant, Fernando Genao, took this , vehicle without permission of the insured. 5. On the aforesaid date, the insured vehicle was driven by Defendant, Fernando Genao, into vehicles parked on South Front Street near the intersection with First Avenue in Wormleysburg, Pennsylvania when the Defendant, Fernando Genao, who was traveling down South Front Street, carelessly struck one vehicle and pushed it into another vehicle causing damages to the insured vehicle. COUNT I PLAINTIFF vs. FERNANDO GENAO 6. Plaintiff incorporates paragraphs I through 5 inclusive as if fully set forth at length herein. 7. Defendant, Fernando Genao, was negligent and careless and the sole cause of this incident in that Defendant; (a) operated the vehicle at an unsafe rate of speed; (b) was inattentive; (c) failed to make proper observation; (d) violated local laws and the laws of the Commonwealth. 8. Defendant is liable as the negligent driver. 9. Defendant is liable for failing to stop at the intersection. 10. Pursuant to the aforesaid policy of insurance, Plaintiff paid for property damages to the insured vehicle that arose out of this incident. 1 1. Due to this incident, expenses were incurred for damage to the insured vehicle, towing, storage and car rentaL 12. Pursuant to the aforesaid policy of insurance, the Common Law and governing statutes, Plaintiff is subrogated for all money paid and seeks recovery of these sums totaling approxirnately $13,000.00. 13. Plaintiff also has incurred attorney's fees and costs to recover the money paid due to Defendant, Fernando Genao's negligence and non-permissive use. WHEREFORE, Plaintiff requests Judgment against Defendant, Fernando Genao, in the amount of$13,OOO.OO together with attomey's fees plus interest and costs of suit. COUNT II PLAINTIFF vs. ALLSTATE INSURANCE COMPANY 14. Plaintiff incorporates paragraphs I through 13 inclusive as if fully set forth at length herein. 15. As a result of the motor vehicle accident of May 18,2003, Defendant, Allstate Insurance Company, asserted a claim for subrogation against Plaintiff, State Farm Insurance Company. 16. Dcfcnda..*1t, ..A..llstate Insurance Company, filed suit in the Court of Common Pleas of Cumberland County on or about November 12,2004, captioned Allstate Insurance Comoanv als/o Christel A. Gill v. Ethelinda Adams and Femando Genao. No. 04-5635 Civil Term. (See copy of Complaint at Exhibit "A".) 17. The vehicle driven by Defendant, Fernando Genao, was insured by Plaintiff State Farm Insurance Company. 18. Defendant, Allstate Insurance Company, and Plaintiff, State Farm 'Insurance Company, are signatories of the Inter-Company Arbitration Agreement. 19. Defendant, Allstate Insurance Company's suit against Plaintiff, State Farm Insurance Company's insured, Ethelinda Adams, is in violation of the Inter-Company Arbitration Agreement. 20. Defendant, Allstate Insurance Company, has failed to exhaust all its administrative remedies by filing a suit pursuant to the rnotor vehicle accident of May 18, 2003. 21. As a result of Defendant, Allstate Insurance Company's failure to comply with the Inter-Company Arbitration Agreement, Plaintiff, State Farm Insurance Company, has incurred attorney's fees and .costs to defend the matter of Allstate v. Adams and Genae, No. 04-5635 Civil Term. 22. Plaintiff, State Farm Insurance Company, is entitled to attorney's fees and costs of suit for the defense of the matter Allstate v. Adams and Genao pursuant to the Inter-Company Arbitration Agreement. 23. Plaintiff, State Farm Insurance Company, is entitled to attorney's fees and costs of suit for the defen~e of the matter of Allstate v. Adams and Genao as a matter of law, WHEREFORE, Plaintiff demands judgment against, Defendant, Allstate Insurance Company, for attorney's fees plus interest and costs of suit. FORRY, ULLMAN, ULLMAN & FORRY, P.c. ~. BY;, ,ll,I'i" ,_ ' Patricia Meshon, Esquire VERIFICATION I, Patricia Meson, attorney for Plaintiff, State Farm Insurance Company, verifY that !the facts set forth in Plaintiffs Complaint are true and correct to the best of my knowledge, i information and belief. I understand that false statements herein are made subject to the penalties of 1 8 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. FORRY, ULLMAN, ULLMAN & FORRY, P.C. ~1- ..' By: , I'C;/&!l4 /1// /.2/'I1";T\ Patricia Meshon, Esquire VERIFICATION 1, Patricia Meshon, Esquire, being duly sworn according to law, depose and state that I am authorized to take this Verification on behalf of Defendant, Ethelinda 1. Adams, and Plaintiff. State Farm Insurance Company, that the facts set forth in the Petition to Consolidate and Memorandum of Law in Support of Petition to Consolidation are true and correct to the best of my knowledge, information and belief. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Ii'.. I / i . { . 12-1 2 ( (' (/\ / .j.:.'!c ( PATRICIA MESHON, ESQUIRE ,,'\../ FORRY, ULLMAN, ULLMAN & FORRY, PC By: Patricia Meshon, Esquire Attorney I.D. No. 65216 One Montgomery Plaza Suite 900 Norristown, PA 19401 (610) 278-7520 Attorneys for Defendant, Ethelinda 1.. Adams and Plaintiff, State Farm Insurance Company Allstate Insurance Company a/s/o Christel A. Gill vs COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Ethelinda 1. Adams and Fernando Genao CIVIL ACTION - LAW and DOCKET NO.: 04-5635 and 05-1473 State Farm Insurance Company vs. Fernando Genao and Allstate Insurance Company CERTIFICATE OF SERVICE I, Patricia Meshon, Esquire, hereby certify that a copy of the Petition to Consolidate and Memorandum of Law in Support of Petition to Consolidate was forwarded, this date, by first- class maiL postage prepaid, addressed as follows: Stewart C. Crawford, Esquire 223 North Monroe Street Media, PA 19063 1/ l' . /.'-/ I '. . . /., '. ( ! ('flL/, (~JA ( f Patricia Meshon, Esquire Date: March 21, 2005 \~} o ." .--' ;~, 'JJ , 'r--'~ \ C'" c,.) f" / RECEIVED MAY 092005 Y j FORRY, ULLMAN, ULLMAN & FORRY, PC By: Patricia Meshon, Esquire Attorney J.D. No. 65216 One Montgomery Plaza Suite 900 Norristown, PAl 9401 (610) 278-7520 Attorneys for Defendant, Ethelinda L. Adams and Plaintiff, State Farm Insurance Company Allstate Insurance Company a/s/o Christel A. Gill vs COURT OF COMMON PLEAS CUMBERLAND COUNTY. PA Ethelinda L. Adams and Fernando Genao and CIVIL ACTION - LAW DOCKET NO.: 04-563~ 05- 1 473 State Farm Insurance Company vs. Fernando Genao and Allstate Insurance Company ORDER And now this 10 day of ~ ,2005 upon consideration of the Petition to Consolidate and any responses thereto it is hereby ORDERED and DECREED that the above-captioned matters are consolidated for all purposes, including arbitration and trial. All pleadings shall be filed pursuant to the Court term and I}umber of State Farm v. Genao and Allstate., b , {" f I tJf' , ~ .._/.//1 J, ~ ~~;. 1 '1\~:,~ j-. q,... LJ 0-' 1J') ,,:) C> '",-- ~':~::~ C.:::> 1;:-> 02-04-140 LAW OFFICE OF STEWART C. CRAWFORD & ASSOCIATES BY: Stewart C. Crawford, Esquire ATTORNEY J.D. #09827 223 North Momoe Street Attorney for Plaintiff P.O. Box E Media, Pennsylvania 19063 Telephone: (610) 565-7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION - LAW ALLSTATE INSURANCE COMPANY als/o CHRISTEL A. GILL NO. 2004-05635 v. ETHELINDA 1. ADAMS & FERNANDO GENAO IN CNIL ACTION PRAECIPE FOR DEFAULT JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter a Default Judgment in favor of the Plaintiff and against the Defendant(s) FERNANDO GENAO in the amount of $4, 565.54 for failure to Answer the Complaint in Civil Action within twenty (20) days from the date of service. I hereby certify that pursuant to Local Rule of Court, I sent Notice to Defendant of intent to take Default. See attached. . (! a ENTRY OF DEFAULT JUDGMENT AND NOW, to wit, thi~y OfJ0'-f ,2005 a Default Judgment is entered as above, namely in favor of the Plaintiff and agaihst the efendant. 02-04-140 LAW OFFICE OF STEWART C. CRAWFORD & ASSOCIATES BY: Stewart C. Crawford, Esquire ATTORNEY 1.0. #09827 223 North Monroe Street Attorney for Plaintiff P.O. Box E Media, Pennsylvania 19063 Telephone: (610) 565-7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION - LAW ALLSTATE INSURANCE COMPANY als/o CHRISTEL A. GILL NO. 2004-05635 v. ETHELINDA 1. ADAMS & FERNANDO GENAO IN CNIL ACTION NOTICE Pursuant to Rule of Civil Procedure No. 236, Notice is given that a Default Judgment and Assrs1ent of Damages in the above-captioned matter has been entered against you on, " y ;)/0 d()&c; , I 02-04- 1 40 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION-LAW ALLSTATE INSURANCE COMPANY als/o CHRISTEL A. GILL NO. 04-05635 v. ETHELINDA 1. ADAMS & FERNANDO GENAO IN CNIL ACTION AFFIDAVIT UNDER SOLDIERS' AND SAILORS' CNIL RELIEF ACT OF 1940 AS AMENDED STATE OF PENNSYLVANIA : SS COUNTY OF CUMBERLAND : Stewart C. Crawford, Esquire, being duly sworn according to the law that FERNANDO GENAO is/are not in the military service of the United States of America as defined by the Soldiers' and Sailors' Civil Relief Act of 1940 as amended; that said Defendant(s) is/are over 18 years of age and is/are employed. art C. Crawford, Esquire Attorney for Plaintiff#09827 Sworn to and subscribed Before me this,:J I Jr day Of v?L L:J 2005. '/~/i&/JiJ~ NOTARY Notarial Seal Laureen Dufrayne. Not3ry Public Upper Da~b>: Twp., Delaware County My Commu;slOfl Expires Aug. 6, 2006 02-04-140 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION-LAW ALLSTATE INSURANCE COMPANY als/o CHRISTEL A. GILL NO. 2004-05635 v. ETHELINDA 1. ADAMS & FERNANDO GENAO IN CNIL ACTION AFFIDAVIT OF MAILING NOTICE COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF CUMBERLAND Stewart C. Crawford, Esquire, being duly sworn according to law, deposes and says that he is attorney for Plaintiff and that on June 28, 2005 he sent by certified mail, return receipt requested, to the Defendant(S) FERNANDO GENAO the repair estimate, together with a notice that damages would be assessed on or after July 12, 2005 in the amount of the repair estimate unless prior to that date the Defendant( s) had, by written Praecipe, filed with the Prothonotary a request for trial on the issue of damages. tewart C. Crawford, Esqui Attorney for Plaintiff( s) Sworn to and Subscribed Before me this cd / jt day Ofv'{jy ,2005. (~i#/Ld~ NOTARY Nou;j;J S~l;-I-~'-"~~' OC.^. l l.al.lreen Dufrayne, NOI[<ry p,II:,,'.' ~ Upper Da:b~ Twp..~e1aw2re Ch,::.':' I My CommlsslOu Explre:,~~6, :J'\J~;~J 02-04- 1 40 LAW OFFICE OF STEW ART C. CRAWFORD & ASSOCIATES BY: Stewart C. Crawford, Esquire ATTORNEY 1.0. # 09827 223 North Monroe Street ATTORNEY FOR PLAINTIFF Media, P A 19063 Telephone: (610) 565-7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW ALLSTATE INSURANCE COMPANY als/o CHRISTEL A. GILL : IN CNIL ACTION VS. ETHELINDA 1. ADAMS & FERNANDO GENAO NO: 04-5635 TO: FERNANDO GENAO 1427 REGINA STREET HARRISBURG, P A 17103 DATE OF NOTICE: DECEMBER 21, 2004 IMPORT ANT NOTICE You are in default because you have failed to take action required of you in this case. Unless you act within Ten (10) Days from the date of this notice, a Judgment will be entered against you without a hearing and you may lose property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or can not afford one, go to or telephone the following office to find out where you can get legal help: Cumberland County Lawyer Referral Service Taryn Dixon, Court Administrator One Courthouse Square Carlisle, PA 17013 (717) 240-6200 STEW ART C. CRAWFORD, ESQ. Attorney for Plaintiff(s) -ic& 0-c t~\t> ......... \) - J:: V - ~ \). \~ f:;~~ "j -::J ~t \If r ~-, (:) (:. g .1 ,.- <-..n --' fC' M;f6 ~..... ) O-l:_-=-:, ...,., -" r:,:l "" (.;.., - Stewart C. Crawford LAW OFFICE OF STEWART C. CRAWFORD & ASSOCIATES 223 NORTH MONROE STREET P. O. BOX E MEDIA, PA 19063 E-MAIL ADDRESS:SCRAWF5518@AOL.COM Tel: (610) 565-7050 Fax: (610) 565-5348 lid (i elf') Renee A. Stevens Legal Assistant, Ext. 15 Rachael Farren Legal Secretary, Ext. 16 Gina Valletti Legal Secretary, Ext. 18 Michelle Sim Bookkeeper, Ext. 17 Leslie S. Britt Admitted in PA & NJ Laureen DuFrayne Paralegal, Ext. 13 June 28, 2005 Lisa Griffith Secretary, Ext. 18 VIA CERTIFIED MAIL Fernando Genao 1427 Regina Street Harrisburg, PAl 7103 Re: Allstate a/s/o Christel A. Gill vs. Ethelinda 1. Adams & Fernando Genao C.C.P. - Cumberland County - No.: 04-5635 Our file: 02-04-140 Dear Mr. Genao: Please be advised that I represent Allstate Insurance Company a/s/o Christel A. Gill concerning property damage to her vehicle that occurred on May 18,2003. I enclose herewith a copy of the Affidavit of Repairman, together with the appraisal indicating that the cost to repair the insured's property totals $4,565.54. I intend on filing a Praecipe for Assessment of Damages under Pennsylvania Rules of Civil Procedure No. 1037 and have the Prothonotary assess damages in that amount on July 12, 2005, unless prior to that date, by written Praecipe, you file with the Prothonotary a request for trial on the issue of damages. Very truly yours, e. Stewart C. Crawford SCC:gv Enclosure 02-04-140 IN THE COURT OF COMMON PLEAS OF CIVIL ACTION-LAW COUNTY,PA ALLSTATE INSURANCE COMPANY a/s/o CHRISTAL GILL vs. ETHELINDA ADAMS & FERNANDO GENO IN CIVIL LAW AFFIDAVIT OF VALUE OF REP ALMAN Under PRCP # (b) (2) (ii) THE REP AIRMAN'S AFFIDAVIT II! ({f/At-:c 7/11t:--""Z _ . duly being sworn accordin$to law, deposes and says that he/she is a claim representative for ,4;/.r ;~ A:.. insurance company and has for many years, reviewed appnusals and estimates and damage documents on property and that the repairs itemized on the attached estimate were necessary to restore the property of the owner to the condition which it existed immediately preceding the damage and that the prices set forth on the estimate for parts and labor were fair and reasonable and customarily charged at the time the attached repair estimate was prepared; or that the property was a total loss and the attached sheets correctly state the value of the property at the time of the loss, less any salvage value. That the attached repair estimate was prepared by a qualified and licensed estimator or field claim representative. P{/~ Sworn to & subJ~rjbed Before me ~iSOEa. day Ofj'/l/"'(/' , 2004. \/\.. ~/,J}t:...A./1 ! \ ' " I '- ! Ii., \ hi L1l& /! i l ;WV~II;;) .' NOTARY I I Notarial Seal LDebora/1 M, Donofrio, Notary Public ,?wer Paxton Twp" Dauphin County .ilIY CommiSSion EXpires July 2, 2006 Member, Pennsylvania ASSOCIatIOn Of Notaries r ; )(13 '- , -, ~. AlIs1'8'l'8. You're In good hllnds. SUBROGATION DEMAND ~ Allstate. '<'oll'nt In good ",..n<\a Claim Number: Date: 8/12/2003 Our insured's vehicle was a total loss. Documentation is attached. Basis for our claim is as follows (settlement summary): Agreed Actual Cash Value PLUS Sales Tax PLUS Licensemtle Fee (if applicable) + + Total Additions Sub-Total LESS Salvage Recovery or PLUS Salvage Loss + PLUS Pre-Paid Towing & Storage Charges + PLUS Rental Reimbursement + Subrogation Demand Insured's Deductible Amount is: Comments: ! _.~-.------ -~._..._-_..- -:.....-,..---~- ,n - 'n : ...1 -~ \ CD ' . ~( t C) 1, eD ~h ( '---. .- od" ~.:;! \ ~ <8 u.;f) \ r'- en ~ (\") \ffi ~CDf3 f ~ -c l"-" '" \ in ::> < ::> )-' ~ z u: :; l:; Z (3 0- '" <t: f ;g ~ " U- \ to a;; ~ :E: i'- 0 Ci '4. w ~ \ z uJ u 1 0 ::;; to: '" <! 0 Z W Z 'I 'W l; u \ ~ >- \ ,....;t z Z 0 \ ::> 5 ;i <t: I; 11"" ::;; ;:;:: Z l~ ..\'5 0 ::; "" ~ .:r~ 0 Z \ \ ....-~ ~ '!2 \ ...~ ~ ""'W W 0 1 w "'''~ i- >-" r-"l <t: 0.." I <I l- O~ '-" ...l U~ 1 ...l '" .<J: u.J ~. I I ...J~ I I -> u..u: 1 \ E I '" ci 1 '" '" I \ " z " ,\ " '" '" I, I '" " e- I \ z '" i I, e- j: \ t.:, ill 'Z \ \ji \ ( w '" r .<1" "- e- """" g ! 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I ~ (;) a z ~ \ w ! , a ;;~:5 w i \ . ------ -' _..--~.-._~- "1 ___o~_.._'-" \ . "!:~., ,- ( ( OS/21/03 07:33 Via: MULTIPLE ADP/AUTOSOURCE INSTANT VALUATION Request Number: 10685928 ADP Page 1 Version: 2 ADMINISTRATIVE DATA Mark Houser Allstate Insurance Company Harrisburg MCO Branch 6345 Flank Drive Ste 1000 Harrisburg PA 17112 Claimant: Insured: CHRISTEL GILL Claim: 1554627164D01 Loss Date: 05/18/03 Loss Type: COLLISION Policy: 001810557 Other: VINSOURCE ANALYSIS VIN: 1G1JF5249T7259770 Decodes as: Accuracy: History: 1996 Chevrolet Cavalier LS 4D Sedan DECODES CORRECTLY ACTIVITY WAS REPORTED ADP/AUTOSOURCE TOTAL LOSS ACTIVITY: (NONE) AUTOTRAK TOTAL LOSS ACTIVITY: (NONE) AUDATEX ESTIMATE ACTIVITY: November 19, 1999. Claim FRONT CORNER. Reported by MOTORISTS INSURANCE - PITTSBURGH on #: 3--472482, DOL: 11/17/99. point of Impact: LEFT AUDATEX ESTIMATE ACTIVITY: Reported by MOTORISTS INSURANCE - PITTSBURGH on August 7, 2001. Claim #: 3--574029. DOL: 07/24/01. point of Impact: RIGHT REAR SIDE. SALES HISTORY ACTIVITY: (NONE) NICB REPORT Loss Date: NICB Member: Phone: Type Of Loss: 07/24/2001 Claim #: 3574029 M033 MOTORISTS MUTUAL INSURANCE COMPANY NICB File#: H0083687128 PROPERTY/CASUALTY Point of Impact: Loss Date: NICB Member: Phone: Type Of Loss: 11/19/2002 A007 ALLSTATE 7175407591 ESTIMATE Claim #: INSURANCE COMPANY NICB File#: point of Impact: 1554505840001 H0083687128 RIGHT FRONT SIDE Loss Date: NICB Member: Phone: Type Of Loss: 03/27/2003 A007 ALLSTATE 8007268890 ESTIMATE Claim #: INSURANCE COMPANY NICB File#: point of Impact: 1554593341H01 H0083687128 NON-COLLISION (' ( OS/21/03 07:33 via: MULTIPLE ADP/AUTOSOURCE INSTANT VALUATION Request Number: 10685928 ADP Page 2 Version: 2 **96 CHEVROLET CAVALIER LS 4D SEDAN BOOK AVERAGING WORKSHEET **N,A,D,A. Vehicle Description: 1996 CHEV CAVALIER LS-L4 SED 4D N.A.D.A. values are as of May 2003 from the Eastern Edition. Red Book value was calculated by Allstate Insurance Company. NADA RETAIL Automobile Red Book RETAIL BASE VALUE ENGINE: 4cyl Gasoline 2.2 TRANSMISSION: 4 Speed Automatic $3,725 Incl Incl $4.725 Incl Incl EQUIPMENT: EQUIPMENT SUBTOTAL MILEAGE: 72,702 o 450 ----------- ----------- ----------- ----------- ADJUSTED TOTALS $4,175 $4,725 AVERAGE $4,450.00 OTHER ADJUSTMENTS --341. 00 ADJUSTED AVERAGE $4,109.00 SALES TAX cP" 7...<fV.g( "L I',g; (}; I.f,~i"r-,of -~ OTHER P fIN ADJUSTED AVERAGE ----------- ----------- \. D'? (A'\. .n. r;;.' '0 \.. ,,01.. 5Q- DEDUCTIBLE NET COMPUTED VALUE €I> '"s.? N. CIf , @ These fully adjusted current N.A.D.A. values are furnished from NADASC. All values Copyright (C) NADASC 2003. under license The values in the N.A.D.A. guide assume a vehicle is clean. Appropriate deductions should be made to put a vehicle in salable condition. SPECIAL NOTE ON OLDER VEHICLES: N.A.D.A.'s editors believe that most optional equipment has little or no value on older vehicles. This is especially true of options which cost relatively little to begin with and which deteriorate with age or use. .. , ( , T , OS/21/03 07:33 Via: MULTIPLE ADP/AUTOSOURCE INSTANT VALUATION Request Number: 10685928 ADP Page 3 Version: 2: VALUATION NOTES 96 CHEVROLET CAVALIER LS 4D SEDAN Other Adjustments - Other adjustment of $-341 was specified for PRIOR DAMAGE ESTIMATE. - The dollar amount listed was provided by Allstate Insurance Company. Autosource Notes - AS reported by Mark Houser on OS/21/03, Autosource has revalued the loss vehicle with revised base. This report contains proprietary information of ADP and shall not be disclosed to any third party (other than the insured or claimant) without ADP's prior written consent. If you are the insured or claimant and have questions regarding the description of your vehicle, please contact the insurance company that is handling your claim. Information within VINsource/NICB is provided solely to identify potential duplicative claims activity. User agrees to use such information solely for lawful purposes. Copyright (c) 2003 ADP Claims Solutions Group, Inc. All Rights Reserved. "'-- ( "Pennsylvanias Largest Auto Salvage AuctionN Date Stock Number Sale Number Sale Date 07/22/2003 00424390 439 07/22/2003 795 Sipe Road PO, Box 397 York Haven, PA 17370-0397 717/938-1879 FAX 717/938-2851 800/772-9277 ( Year Make Model Note 1996 Color: GOLD CHEVROLET CAVALIER LS 4DR VIN IGIJF5249T7259770 Tires 4 Mileage 72,702 Radio Yes Row L--042 Battery: Airbag Yes Keys Yes Mea 4380 Total Advance Total Pool "'"~'?tOCIlS\'I Total Paid RECEI'JEO: ;;>uP Curren t Due JUL 2 9 'lO\)j NAlAE:--- ALLl 'ALLSTATE INSURANCE COMPANY POBOX 27 TOWING 5/18-5/20 PENNSBURG, PA 18073 OWV A ;::::'::0::" ;';;,;;;;oHoSulfu X' G Date of Loss 05/18/2003 Policy Holder: GILL CHRISTEL ~ :::::. b. "V"::':'::-:::':bOV' """ ~'[,,~~ sold on our most recent sale. The outstanding charges exceeded the amount of the high bid, leaving a balance due as shown on the right. Please pay from this invoice, PAl D Thank you for allowing Central Penn Sales, LLC to selJUl 3 1 2003 your vehicle. Your patronage is appreciated. Buyer Information WAGAMAN'S AUTO 520 HONDA RD SALVAGE LITTLESTOWN, FA 17340 Advance Charges 3 days 25/DAY Sale Information High Bid Advance Chgs Tow In CPS Handling Title Fee Cars tart Express Tow 125.00 75.00 150.00 200.00 52.00 47.00 5.00 15.00 12,50 .00 .00 .00 ,00 .00 ,00 200.00 131.50 .00 181. 50 Central Penn Sales. LLC Pennsylvania's Largest Auto Salvage Auction Tax ID 23-3065101 Questions? E-mail us at www. central-penn. com .,LSTATE INSURANCE COMPANY ( \, HARRISBURG MCO 6345 FLANK DRIVE HARRISBURG, PA 17112 (717) 540-7500 SUPPLEMENT HOTLINE: (800) 726-8890 EXT.3030 , ,"\ CD LOG NO 974 -0 05-21-03 8: 02 AM ESTIMATE CLAIM INFORMATION CLAIM # 1554627164D01 INSURED CHRISTEL GILL CLAIMANT POLICY # 001810557 LOSS DATE 05-18-03 LOSS TYPE COLLISION INSPECTION TYPE FIELD INSP STATION PRIMARY POI REAR END LEFT APPRAISER NAME MARK HOUSER LICENSE # 151187 WORK PHONE (717) 540-7500 ADDRESS 6345 FLANK DRIVE CITY STATE HARRISBURG ZIP 17112~ OWNER SECOND POI FRONT END LEFT FAX INSP DATE 05-21-03 PA LOCATION FIC CITY STATE CHRISTEL GILL 2840 OLD HARRISBURG PIK GETTYSBURG PA 17325-7531 WORK#(717) 732-0700 HOME#(717) 730-0412 REPAIR VEHICLE 1996 CHEVROLET CAVALIER LS 4 DR SEDAN 4CYL GASOLINE 2.2 OPTIONS TWO-STAGE - EXTERIOR SURFACES FRONT MUD GUARDS ANTI-LOCK BRAKE SYSTEM AIR CONDITIONING CRUISE CONTROL TWO-STAGE - INTERIOR SURFACES HEATED BACK GLASS TRACTION CONTROL SYSTEM AUTOMATIC TRANS BODY COLOR CONDITION LICENSE # LICENSE STATE GOLD FAIR NONE MILEAGE VIN CODE VEH INSP 72,702 1G1JF5249T7259770 U234 # 5,008. REMARKS: ALL SUPPLEMENTS MUST CALL HOT LINE AT 1-800-726-8890 EXT. 3030. SUPPLEMENT MAY NOT BE HONORED IF YOU FAIL TO CALL. COVERS VISABLE DAMAGE ONLY. ESTIMATE WRITTEN TO TOTAL LOSS . ADDITIONAL DAMAGE MAY EXIST. LKQ PARTS AT NEW CUMBERLAND AUTO PARTS, 717-774-1190. OP CODES: * = USER-ENTERED VALUE EC = COMPETITIVE PART EU = RECYCLED PART PM = PXN REMAN/REBUILT IT = PARTIAL REPAIR BR = BLEND REFINISH SB = SUBLET P = CHECK UP = UNRELATED PRIOR E = REPLA,CE OEM UC = RECONDITIONED PRT EP = COMPETITIVE PART TE = PARTL REPL PRICE I = REPAIR 'rT = TWO-TONE N = ADDITIONAL LABOR AA = APPEAR ALLOWANCE NG = REPLACE NAGS UM = REMAN/REBUILT PRT PC = PXN RECONDITIONED ET = PARTL REPL LABOR L = REFINISH CG = CHIPGUARD RI = R&I ASSEMBLY RP = RELATED PRIOR OP GDE MC DESCRIPTION MFR,PART NO, PRICE AJ% B% HOURS R -In 1996 CHEVROLET CAVALIER { . CLA~ # 1554627164DOl \ -- --- EU 0049 L 0049 , N 0973 N 0932 EU 0207 L 0207 EU 0287 L 0287 EU 0616 L 0616 EU 0479 L 0479 E 0514 L 0514 E 0494 L 0494 EU 0533 EU 0566 L 0566 4 DR SEDAN LOG 974 ( J5-21-03 -0 ----------- SECT,3/4 FRT BODY 0 LT SECT,3/4 FRT BODY 0 LT RECYCLED PART REFINISH 6.2 Surface 0.6 Two-stage setup 1.2 Two-stage HEADLAMPS AIM ADDITIONAL LABOR A/c EVAC RECHRG & RCV ADDITIONAL LABOR DOOR ASSEMBLY, FRONT LT RECYCLED PART DOOR SHELL,FRONT LT REFINISH 1.7 Surface 1. 0 Edge 0.5 Two-stage DOOR ASSEMBLY,REAR LT RECYCLED PART DOOR SHELL,REAR LT REFINISH 1.7 Surface 1. 0 Edge 0.5 Two-stage SECTION,QUARTER PAN LT RECYCLED PART SECTION, QUARTER PAN LT REFINISH 3.4 Surface 0.7 Two-stage RECYCLED PART REFINISH 2.1 Surface 1. 0 Edge 0.3 Two-stage 22582361 GM PART REFINISH 0,9 Surface 0,5 Edge 0.3 Two-stage 12335397 GM PART REFINISH 1. 5 Surf ace 0.3 Two-stage LT RECYCLED PART RECYCLED PART REFINISH 2.6 Surface 0.5 Two-stage DEOK LID ASSEMBLY LID,REAR DECK PANEL,REAR BODY PANEL,REAR BODY PAN, REAR FLOOR PAN,REAR FLOOR TAILLAMP ASSEMBLY BUMPER ASSEMBLY,REAR COVER,REAR BUMPER 19 ITEMS FINAL CALCULATIONS & ENTRIES PARTS GROSS PARTS OTHER PARTS PAINT MATERIAL 400.00' +25 350.00* +25 350.00' +25 200.00* +25 400,00* +25 182,27 -10 834.86 -10 50.00* +25 200.00* +25 $ 1,017.13 $ 1,950.00 $ 400.00 ** ADJUSTMENTS DISCOUNT MARKUP LINE ITEMS $ 101. 71 $ 487.50 PARTS TOTAL $ 3,752,92 TAX ON PARTS & MATERIAL @ 6.000% $ 225. 18 LABOR RATE REPLACE HRS REPAIR HRS I-SHEET METAL $ 36,00 40.4 0.5 $ 1,472,40 2-MECH/ELEC $ 36,00 1.9 $ 68,40 3- FRAME $ 36.00 4-REFINISH $ 36.00 28,5 $ 1,026,00 5-PAINT $ 16.00 LABOR TOTAL $ 2,566.80 TAX ON LABOR @ 6.000% $ 154,01 -2- 8: 02 AM 3,2 1 8.0 4 0.5 1 1.92 2.8 1 3.2 4 2.0 1 3.2 4 11. 4 1 4.1 4 0,6 1 3.4 4 INC 1 1. 7 4 20.4 1 1.8 4 INC 1 INC 1 3.1 4 1996 CHEVROLET CAVALIER CLAI~ # 1554627164D01 TAX bN SUBLET @ SUBLET REPAIRS TOfUNG STORAGE GROSS TOTAL LESS: DEDUCTIBLE 4 DR SEDAN LOG 974 -0 ( J5-21-03 8: 02 AM 6,000% NET TOTAL $ 6,698.91 $ 500.00- $ 6,198.91 Run ACV PXN Y(02/00/00/02/00 CUM 02/00/00/02/00 Geocode: 17112 HARRISBURG SPPL Yes Geocode: 17010 HARRISBURG ADP PENPRO W0405 ES LOG974 -0 05-21-03 10:41:34 REL 4.05 SW01/03 DT05/03 IC) 1993 - 2002 ADP CLAIMS SOLUTIONS GROUP, INC. ** USER-ESTABLISHED THRESHOLD FOR PAINT MATERIAL HAS BEEN REACHED AND CALCULATED IN THIS ESTIMATE. ANY ADDITIONAL MATERIALS MAY REQUIRE FURTHER APPROVAL. ** 4.9 HRS WERE ADDED TO THIS EST. BASED ON ADP' S TV/a-STAGE REFINISH FORMULA. ESTIMATE CALCULATED USING THE 2.5 HOUR MAXIMUM ALLOWANCE FOR TWO-STAGE REFINISH OF NON-FLEX, EXTERIOR SURFACES. -3- 1996 CHEVROLET CAVALIER:' 4 DR SEDAN CLAIM # 1554627164D01 \ LOG 974 Estimate Summary MARK HOUSER -0 Page (' ,J5-21-03 8:02 AM ""'j GROSS TOTAL $ 6,698.91 LESS: DEDUCTIBLE $ 500.00-- NET TOTAL $ 6,198.91 ADP PENPRO W0405 ES LOG974 -0 05-21-03 10:41:34 REL 4.05 SW01/03 DT05/03 (C) 1993 - 2002 ADP CLAIMS SOLUTIONS GROUP, INC, TO ALL REPAIR FACILITIES: BEFORE USING AN AFTERMARKET SHEETMETAL PART, BE SURE TO LOOK FOR THE CAPA SEAL. THIS IS NOT AN AUTHORIZATION FOR REPAIR. SUPPLEMENTS MUST BE APPROVED PRIOR TO REPAIR, IF YOUR CAR IS OF UNITIZED CONSTRUCTION, IN SOME CASES THE REPAIR SHOP MAY NEED SPECIAL EQUIPMENT TO PROPERLY REPAIR THE CAR. YOU SHOULD DETERMINE IF THE SHOP YOU SELECT TO COMPLETE THE REPAIRS IS PROPERLY EQUIPPED. ERVICES OR STORAGE R W S". ~ - "- THIS ESTIMATE HAS BEEN PREPARED BASED ON THE USE OF AFTERMARKET CRASH PARTS IF THE USE OF AN AFTERMARKET CRASH PART VOIDS THE EXISTING WARRANTY ON THE PART BEING REPLACED OR ANY OTHER PART, THE AFTERMARKET CRASH PART SHALL HAVE A WARRANTY EQUAL TO OR BETTER THAN THE REMAINDER OF THE EXISTING WARRANTY. WARRANTIES APPLICABLE TO AFTERMARKET CRASH PARTS ARE PROVIDED BY THE MANUFACTURER OR THE DISTRIBUTOR OF THESE PARTS NOT THE ORIGINAL MANUFACTURER OF YOUR VEHICLE, ALL CHAR CHARGES WILL BE THE RESPONSIBILITY OF THE CONSUMER. ANY PERSON WHO KNOWLINGLY AND WITH INTENT TO INJURE OR DEFRAUD ANY INSURER FILES AN APPLICATION OR CLAIM CONTAINING FALSE, INCOMPLETE OR MISLEADING INFORMATION SHALL, UPON CONVICTION. BE SUBJECT TO IMPRISONMENT FOR UP TO SEVEN YEARS AND PAYMENT OF A FINE UP TO $15,000 IT IS TO OUR MUTUAL INTEREST THAT YOU RECEIVE PROMPT AND COURTEOUS SERVICE ALONG WITH QUALITY REPAIR WORK AT A FAIR PRICE, IF YOU HAVE A PREFERENCE FOR A PARTICULAR SHOP, YOUR ADJUSTER WILL WRITE OR APPROVE AN ESTIMATE OF REPAIRS - WITH THAT SHOP BASED ON COMPETITIVE PRICES IN THE AREA. INFORMATION REGARDING REPAIR FACILITIES, WHICH MAY BE ABLE TO REPAIR THE VEHICLE FOR THE APPRAISED AMOUNT, IS AVAILABLE FROM YOUR ADJUSTER OR INSURER. HOWEVER, THERE IS NO REQUIREMENT TO USE ANY SPECIFIED SHOP. COSTS ABOVE THE APPRAISED AMOUNT MAY BE THE RESPONSIBILITY OF THE VEHICLE OWNER. ALL SUPPLEMENTS MUST BE APPROVED PRIOR TO REPAIR. AFTERMARKET CRASH PARTS ARE IDENTIFIED IN THIS ESTIMATE WITH THE SYMBOL "EC", 'EP" (COMPETITIVE PART) AND "EU" (RECYCLED PART) AN "AFTERMARKET CRASH PART" IS A NON--ORIGINAL MANUFACTURER (NON-OEM) REPLACEMENT PART, EITHER NEW OR USED, FOR ANY OF THE NON-MECHANICAL PARTS THAT GENERALLY CONSTITUTE THE EXTERIOR OF THE MOTOR VEHICLE, INCLUDING INNER AND OUTER PANELS NEW, ORIGIN. LETTER irE" DEALER. LICENSE J ~ '\ \ ~ ""-- DATE [ ~,!S) EQUIPMENT MANUFACTURER, REPLACEMENT PARTS ARE IDENTIFIED BY THE CAN BE LOCATED AT THE ORIGINAL EQUIPMENT MANUFACTURER PARTS ADJUSTER -4- XBNC-" COMP1\N1' NO 585 P 11 ,MAY. 21. 2003 11: 28AM ALLSTATE lNS, Hbg flCiRG MCO ., , 6345 FL!\m: DF.IVE ( .( 'HARRISBURG, PA 17112 (717) 540-7500 SuPPLEMENT HOTLINE: (800) 726-8890 EXT.3030 CD LOG NO 975 -0 ESTIMATE 05-21-03 8:17 AM CLAIM lNFORJo!1\.TION CLAlM # 1554627164PD1 INSURED CHRISTEL ~ILL CLAlWlNT . INSPECTION TYI'E nELD INSP STATION PRIMARY POI NON-COLLISION APPRAISER NAME Ml\Rl( HOt/SER LICENSE # 151187 WORK PHONE (717) 540-7500 ADDRESS 6345 FLANK DRIVE CITY STATE HARRISBURG ZIP 17112- OWNER POLICY # 001910557 LOSS DATE 05-18-03 LOSS TYPE COLLISION SECOND POI FAX INSP DATE 05-21-03 PA LOCATION FIC CITY STATE CE:RISTEL GILL 2840 OLD HARRISBURG PIK GETTYSBURG PA 17325-7531 WORK#(717) 732-0700 HOME#(717) 730-0412 REPAIR VEHICLE 1996 CHEVROLET CAVALIER LS 4 4CYL GASOLINE 2.2 OPTIONS TWO-STAGE- EXTERIOR SUR~CES FRONT MUD GuARDS ANTI-LOCK BRAKE SYSTEM AIR CONDITIONING CRUISE CONTROL DR SEDAN TWO-STAGE - INTERIOR SURFACES HEATED BIl.CK GLASS TAACTION CONTROL SYSTEM AUTOMATIC TRANS BODY COLOR CONDITrON LICENSE # GOLD FAIR NONE MILEAGE VIN CODE 72,702 1G1JF5249T7259770 u234 REMllRKS : THIS IS A PRIOR DAMAGE ESTIMATE. OP CODES: * ~ TJSER-ENTERED VALUE EC = COMPETITIVE PART ETJ = RECYCLED PAAT PM ~ PXN REMAN/REBUILT IT ~ PARTIAL REPAIR BR ~ BLEND REFINISE SB ~ SUBLET I' ~ CHECK UP ~ UNRELATED PRIOR E = REt'LACE OEM UC = RECONDITIONED FRT EP ~ COMPETITIVE PART TE ~ PARTL REPL PRICE I = REPAIR TT = TWO-TONE N ~ ADDITIONAL LABOR AA = APPEAR ALLOWANCE NG = REPLACE NAGS OM = REMAN/REBUILT PRT PC ~ t'XN RECONDITIONED ET ~ PARTL REPL LABOR L = REFINISH CG = CHIPGt1AR:D RI ~ R~I ASSEMBLY RP = RELATED PRIOR OP GD8 MC DESCRIPTION MFR. PART NO. PRICE AJ% 13% HOURS R I 0208 DOOR SHELL, FRONT RT REPAIR 0.5*1 LOCATION:7179328902 RX TIME OS/21 '03 12:09 NO, 585 p, 12 05-21-03 8,17 AM MAY, 21. 2003'1l11:28AM CAV1ALLS~ATE INS, Hbg FIe \..J.""-l'l 11 l,,04627164PD1 LOG 975 -0 (' >>RE:PAiR SCRATCHES AA ,IO<:S. L 0208 10 DOOR SHELL,FR0~T RT REFINISH 2. 0* Surface 0.6 Two-stage setup 0.4 Two-stage MC MESSAGE 10 INCLUDES 1\DP TIME TO CLE:AR ENTIRE PANEL. FINAL CALClJLl\TIONS & ENTRIES PMtTS GR.OSS PARTS OTHER PARTS P1l.INT MllTERIAL S ADJUSTMENTS DISCOUNT ffi\RKUP PARTS TOTAL T1\X ON P1l.RTS & MllTERIllL @ 6.000% Ll\EOR I-SHEET METAL 2-MECH/ELEC 3- FRAME <I-REFINISH 5-PAINT LASOR TOTAL T1\X ON :LABOR TAX ON SUBLET SUBLU REPAiRS TOWING STORAGE GROSS TOTAL LESS: DEDUC'l'IBLE >>PAINT ABOVE MLDG. I 0288 DOOR. SHELL,REAR RT REPAIR >>RE?AIR SCRATCHES AND NICKS. L 0288 10 DOOR. SHELL,IlEAl< RT REFINISH I 2.0* Surface 0.3 Two-stage >>PAINT ABOVE MLDG. 4 ITEMS RATE REPLACE Hl\S REPAIR HR.S S 36.00 1.0 $ S 36.00 $ 36.00 S 36.00 5,3 $ S 18.00 @ 6.000% @ 6.000% NET TOTAL 3.0*4 0.5*1 2.3*~ 95.40 S ~5.40 S 5.72 36,00 190.80 S 226.80 S 13.61 $ 341. S3 NONE- 341. 53 $ FXN YfOO/OOfOO/OO/OO CUM 00/00/00/00/00 Geocode: 17112 HARRISBURG SPPL Yes Geocode: 17010 HARRISEURG ADP PENPRO W0405 ES LOG975 -0 05-21-03 10:04:48 REL 4,05 SW01f03 DT05/03 (C) 1993 - 2002 AD? CLAI~S SOLUTIONS GROUP, INC. 1,3 llRS WERE ADDED TO TRIS EST. SllSED ON ADP' S TWO-STAGE REFINISH FORMULA. --------------------------------------------------~---------------------------- LOCATION:717932S902 RX TIME OS/21 '03 12:09 MAY, 21, 2003iJ11 : 28AIVr CAwALLS:ATE lNS, Hbg flC C~~ # I554627164~D1 ' LOG 975 -0 '\. .stilnate Sununary ~age MARK HOUSER NO. 585 P. 13 C )5-21-03 8:17 AM ., GROSS TO~AL $ 341.53 LESS: DEDUC'J'tBLE NONE- NET TOTAL $ 341.53 AD~ ~ENPRO W0405 ES LOG975 -0 05-21-03 10:04:48 REI. 4.05 SWOI/OS DT05/03 (C) 1993 - 2002 ADP CIJUMS SOLU'rIONS GROUP, INC. TO ALL REPA.IR FAC,IJ;,rrIijS: BEFORE USING AN AFTERWU>.KEl' SHEEnlETAL EMT, BE S\T.RE TO LOOK FOR THE CAl'A SEIU.. THIS IS NOT AN .!l.U'rHORIZATION FOR REPAIR. SUPPUMENTS MtlST BE 1U'l'ROVED PRIOR TO REPJl.IR. IF YOUR CAR IS OF UNrl'IZED CONSTRllCnON, IN SOME CASES THE REPAIR SHOP MJ\.Y NEED Sl?ECIlU, EQtJII:'MENT TO PROPERLY REPaIR THE CAR. YOU SHOULD DETERMINE IF THE SHOI' YOU SELEC'.!' TO COM~LETE THE REPAJ:RS J:S PRO~ERLY EQUIPPED. . Co bES, KNOWN AT T~W. '\'"rM'i' Q~ --e~GE~ ",~~L BE THE ~SPONSIBILITY OF THE CONSUMER, THIS ESTrMATE HAS BEEN PREPARED BASED ON THE USE OF AFTERMAR1<ET CMSH P.ARTS IF THE USE 0.. AN IUTEro'll'IRKET CRASH PAAT VOIDS THE EXISTING iilARItl\NTY ON 'l:!lE PART BEING REPtACJ;:;D OR ANY OTHER PART, THE AFTERMARKET CRllSH PAAT SlffiLL HAVE A WARRANT;: EQUAL TO OR BB'l:TER TlilIN THE REMAINIlEll OF THE EXISTING WAB.FANTY, WARRANTIES APPLICAELE TO AFn:!OO\RKET CRASH P.ARTS ARE PROVI:oED B;: IRE MANUFACTURER OR THE DISTRIBUTOR OF IHESE PARTS NOI THE ORIGINAL MAN\.lI;'ACTURER OF YOUR VEHIC~. ANY PJ::RS<JN WHO J:<J:<rojqLINGLY AND WITH INrelVT TO INJURE OR :oEFRAUD ANY INSURER FILES AN APPLICATION OR CLAIM CONTAINING FALSE. INCOMPLETE OR MISLEADING J:NFO~T!ON SHALL, UPON CONVJ:CTIOM. BE SUBJECT TO IMPRISONMEN:L' FOR UP TO SEVEN YElARS AND PAYMENT OF A FINE UP TO $15,000 IT IS TO OUR MUTUAL INT&U;ST THAT YOU RECEIVE PROMPT AND COURTEOUS SERVICE .ALONG WITH QUALITY REPAIR WORK AT A V.U\ PRICE. IF YOU HAVE .ll. pl\E:FERENCE FOR A PAATICULAR SHOP, YOUR ADJUSTER WILL WRITE OR APPROVE AN ESTIMATE OF REPAIRS - WITH THAT SHOP B.ll.SED ON COMPETITIVE PRICES IN THE AREA. INFORMATION REGJU\IJING REPAIR FACILrTIES, WHICH MAY eli: ABLE TO REPAIR THE VmUCLE FOR THE APPRAISED AMOUNT, IS AVAILABLE FROM YOUR ADJUSTER OR INSU1\ER' HOWEVER. THERE IS NO REQUIREMENT TO Il'SE ANY SPECIFIED SHOP. COSTS MOVE THE APPAAISED AMOUN'l' MAY BE THE RESPONSIBILITY OF TIlE VEHICLE OWNER. ALL SUPPLEMENTS MtlST BE APPROVED PRIOR TO REPAIR. AFTEroIARKET CRASH PAR'l'S ARE IDENTIFIED IN THIS ESTIMATE WITH THE: SYMBOL "Ee", 'EP" (COMPETITIVE PART) AND "EU" (RECYCLED P.ART) AN "AFTEF.l!:lAMET CAASH PART" IS A NON-ORJ:GINAL WlNUFACTtlRER (NON-OEM) REPIJICEMENT PMT, EITHER NEW OR USED, FOR AN'{ OF THE NON-MECIDlNICAL PAR'l'S THAT GENERALLY CONSTITUTE 'l'HE EXTERIOR OF THE MOTOR VEHICLE. INCLIJJ)ING INNER AND OUTER PAm:LS NEW, ORIGINAL EQUIPMEN'1' WlNUFACTURER, REPIJICEMENT P.ARTS :/'IRE IlJENTIFIEO BY THE: LETTER "E" CIlN BE: LOCATED AT :!'HE ORIGINAL EQUIPMENT MANTJ:E'ACTURER P.ARTS DEAr.ER. ' n C\. ADJUS1'"ER LICENSE # 1 ~ \ \ ~.J "JI-o] PATE LOCATION:7179328902 RX TIME OS/21 '03 12:09 FILE # 02-04-140/ RF LAW OFFICES OF STEWART C. CRAWFORD & ASSOCIATES BY: Stewart C. Crawford, Esquire ATTORNEY LD. NO. 09827 223 North Monroe Street ATTORNEY FOR PLAINTIFF Media, P A 19063 Telephone: (610) 565-7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION LAW ALLSTATE INSURANCE COMPANY als/o CHRISTEL A. GILL IN CIVIL ACTION VS. NO. 2004-05635 ETHELINDA L. ADAMS & FERNANDO GENAO PRAECIPE TO ORDER TO SETTLE. DISCONTINUE AND END TO THE PROTHONOTARY: Please mark the record for Defendant, Ethelinda L. Adams only in the above- captioned matter as "Settled, Discontinued and Ended" upon payment of costs. ~k STEW AR C. CRA WF RD, Q. Attorney for Plaintiff @~~ --~ 5 ~\ cd y 0') - ~ ~ Q, cg.. -:? :c.. ~,,~ G" -}},K' """ .,f:) ~ob ::?;~l\ -0 6?; -:;;;. ~~' <.? ~ <f' ::<c (f'