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HomeMy WebLinkAbout13-7568 0 Supreme C, nnsylvania COu leas For Prothonotary Use Only ti I t Docket No: Cu a County} 1 fr The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: El Complaint ® Writ of Summons ® Petition © Transfer from Another Jurisdiction ® Declaration of Taking Lead Plaintiff s Name: Lead Defendant's Name: Nationwide Insurance Co. Inc. Bryce Keifer Dollar Amount Requested: Elwithin arbitration limits Are money damages requested? IM Yes ® No (check one) outside arbitration limits Is this a Class Action Suit? [3 Yes El No Is this an MDJAppeal? E3 Yes El No '! Name of Plaintiff /Appellant's Attorney: Miranda Lee, Esquire Check here if you have no attorney (are a Self- Represented [Pro Se] Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. 3'' TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ' ® Intentional ® Buyer Plaintiff Administrative Agencies Malicious Prosecution [3 Debt Collection: Credit Card ® Board of Assessment El Motor Vehicle Debt Collection: Other [3 Board of Elections Nuisance Dept. of Transportation Premises Liability Statutory Appeal: Other ► +� © Product Liability (does not include mass tort) Employment Dispute: © Slander/Libel/ Defamation Discrimination Q Other: l3 Employment Dispute: Other Q Zoning Board �. El Other: ® Other: MASS TORT ® Asbestos ,= 0 Tobacco l3 Toxic Tort -DES 0 Toxic Tort -Implant REAL PROPERTY MISCELLANEOUS E3 Toxic Waste © Ejectment [3 Common Law /Statutory Arbitration ® Other: ® Eminent Domain/Condemnation ® Declaratory Judgment ` © Ground Rent Mandamus � :4 Landlord/Tenant Dispute Non- Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY Q Warranto Mort Foreclosure: Commercial 0 Dental 0 Partition 13 Replevin Legal ® Quiet Title Other: Medical Other: ® Other Professional: Updated 1/1/2011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION — LAW NATIONWIDE INSURANCE CO. INC. n Plaintiff DOCKET NO. V . BRYCE KEIFER CIVIL ACTION Defendant NOTICE TO DEFEND AND CLAIM RIGHTS 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 fining in writing with the court your defenses or objections to the claims set forth again 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 of 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 (OR CANNOT AFFORD ONE), GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING 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 REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 TELEPHONE: (717) 249 -3166 or (800) 990 -9108 (in PA only) Rrc. Act 44 r0 MILLER, QUIGG & AHERN, LLC :.. BY. Miranda Lee, Esquire - PA ID: 313509 2906 William Penn Highway 3 ff " Attorney for Plaintiff Suite 210 Easton, PA 18045 Telephone: 610 - 438 -8755 Facsimile: 610 - 438 -8756 IN THE COURT OF COMMON PLEASE FOR CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — LAW Nationwide Insurance Co. Inc. Plaintiff No. V . Bryce Keifer CIVIL ACTION Defendant COMPLAINT 1. Plaintiff Nationwide Insurance Co. Inc. is an provider of, inter alia, motor vehicle insurance to its customers, headquartered at One Nationwide Plaza, Columbus, Ohio 43215 and doing business in Pennsylvania including Cumberland County. 2. That the Plaintiff insured James Marshall under a contract of insurance and that said contract of insurance was in full force and effect at the time of the accident hereinafter referred to. 3. That pursuant to the aforesaid contract of insurance, the Plaintiff is entitled to claim and pursue subrogation rights against third parties responsible for losses paid out under said contract of insurance. 4. Defendant, Bryce Keifer, is an adult individual who is domiciled with a permanent address of 1005 Walnut Street, Lemoyne, PA 17043. FACTS 5. On or about December 23, 2011, Defendant was operating a 2011 Dodge Ram traveling in a westerly direction on Lowther Street, a public road in Leymoyne, Pennsylvania. 6. That at the time and place relevant hereto, Plaintiff is informed and believes the Defendant, Bryce Keifer ( "Defendant- owner ") was the owner of that certain motor vehicle which was being operated by the Defendant, Bryce Keifer. 7. On or about December 23, 2011, Plaintiffs Insured, James Marshall, while in the exercise of due care, was operating his automobile, a 2011 Toyota Camry, on said Lowther Street heading East. 8. The vehicle owned and operated by Defendant Keifer did negligently collide with and strike the rear of Plaintiffs Insured James Marshall's automobile on said date, damaging Plaintiffs Insured. 9. That Plaintiff is informed and believes that on or about December 23, 2011, the Defendant operator caused the vehicle he was operating to suddenly and without warning, violently collide with and crash into the Plaintiffs insured vehicle, thereby proximately causing the property damages complained of herein, and for which Plaintiff was required to pay. COUNT ONE NATIONWIDE V. KEIFER NEGLIGENCE 10. Plaintiff incorporates paragraphs one (1) through nine (9) herein by reference as though set forth in full. 11. That the damages for which Plaintiff was responsible under the aforesaid contract of insurance was directly caused and occasioned by the negligent, willful, wanton, reckless and grossly negligent manner in which the Defendant - operator was operating the vehicle he was driving upon the highways of this State, in one or more of the following particulars, to wit: (a) In failing to keep a proper lookout and decrease speed as required by the traffic circumstances then and there present: (b) In operating a vehicle in a reckless and unlawful manner; (c) In operating a vehicle without proper brakes or other mechanical devices which would have enabled said vehicle to be maintained under control or to be stopped at the time and place relevant hereto, or, if it were so equipped, in failing to properly use such mechanical devices; (d) In operating a motor vehicle, an inherently dangerous instrument, in a public area in complete and utter disregard for the rights of others using the same public area; (e) In failing and proper lookout; (f) In operating a motor vehicle at a speed which was too fast for conditions; (g) In failing to yield the right of way; (h) In failing to bring the motor vehicle to a stop, or to change, alter or divert the course of same when the insured vehicle was observed, or in the exercise of ordinary care and diligence, should have been observed by a person possessed of ordinary physical characteristics and abilities; and (1) In failing to exercise that degree of care and caution as would a reasonably prudent person under the same or similar circumstances; all of which are in violation of the laws governing operation of motor vehicles on public roads in the Commonwealth of Pennsylvania. 12. That the aforesaid tortious acts of the Defendant operator are imputed and attributable to the Defendant - owner, in addition, the Defendant -owner was willful, wanton, reckless, careless, negligent and grossly negligent in the following particulars, to wit: (a) In failing and omitting to properly inspect, service and/or otherwise maintain the brakes of said motor vehicle so as to make reasonably certain said vehicle was in safe operating condition; (b) In failing and omitting to properly inspect, service and or otherwise maintain the steering equipment of said motor vehicle so as to make reasonably certain said vehicle was in safe operating condition; and (c) In entrusting a motor vehicle, an inherently dangerous instrumentality, to one who was incompetent to operate it safely. 13. That as the result of the negligence of the Defendant, Plaintiff has caused to be paid to, or on behalf of, it's insured the total amount of $12,289.90, for which amount Plaintiff now seeks judgment against the Defendants (See attached hereto marked as "Exhibit A "). WHEREFORE, Plaintiff demands judgment against the Defendants above named, jointly and severally, for: (A) The principal due and owing by Defendant(s) in the amount of Twelve Thousand, Two Hundred, Eighty -Nine Dollars and Ninety cents. ($12,289.90). (B) Plaintiff's continuing interest on Defendant's outstanding balance in the amount of 1 I /2 % per month or 18% per annum from date of loss. (C) Plaintiff's continuing costs and attorney fees at 25% of principal; (D) Such further relief as the Court may deem equitable and just. MILLER, QUIGG & AHERN, LLC DATE: a - - l3 BY: MIRANDA E. LEE, ESQUIRE ATTORNEY FOR PLAINTIFF EXHIBIT "A" 01/10/2012 12:15 7176977509 PAGE 06/07 WEST SHORE REGIONAL POLICE DEPARTMENT Police Crash Report Form Crash 0 - ? 5 Incident # ZQ( -12 -37 Agency Code 21VO3 West Shore Regional police Department Date: 1Z 17-31 _ Arrival ime z� _Inve stigating Ofbcer (�� �Cl/11 G 11+ badge #- r J u l Y l F 1� 3 a o fi I' 1 �v U oI d VAtj 1 � WSRPD FORM 01 -2009 (DPC 2009) 01/10/2012 12:15 7176977509 PAGE 05/07 METRO THE HARRISBURG AREA POLICE INFORMATION RESOURCE SYSTEM (CRSIPINC) PAGE: 4 CRASH REPORT 01/03/12 MJK1 WSR2 CRASH NUMBER: F0013035 INCIDENT NUMBER: 20111200379 WSR * * * * * * *- *- *Y *y * - *- `^- `-- *- *- *- *- *- *- *-- *- * - - - *_ PEOPLE INFORMATION PERSON TYPE: 1=DRIVER 2= PASSENGER 7= PEDESTRIAN 8 =OTHER 9 =UNKNOWN INJ SEVERITY: O =NONE 1= KILLED 2 =MAJOR INJ 3= MODERATE 4 =MINOR 9 =UNK UNIT NO: 01 PERSON NO: 01 TYP: 1 INJ SEVERITY: 0 DOB: 19820525 SEX: M NAME (L,F,M,S) : KEIFER BRYCE A ADDRESS: 1005 WALNUT ST PHONE: 7173506214 LEMOYNE PA 17043 DRIVER LICENSE: PA 26038185 SEAT POSN: 01 SAFE- EQ1,2: 03 10 EJECT: 0 EJ -PATH: 0 EXTRIC: 0 TRANSP: N UNIT NO: 02 PERSON NO: 01 TYP: 1 INJ SEVERITY: 0 DOB: 19380311 SEX: M NAME (L, F, M, S) : MARSHALL JAMES E ADDRESS: 1309 WARWICK RD PHONE: 7177611732 CAMP HILL PA 17011 DRIVER LICENSE: PA 09694645 SEAT POSN: 01 SAFE- EQ1,2: 03 10 EJECT: 0 EJ -PATH: 0 EXTRIC: 0 TRANSP: N 01/10/2012 12:15 7176977509 PAGE 04/07 METRO THE HARRISBURG AREA POLICE INFORMATION RESOURCE SYSTEM (CRSIPINC) PAGE: 3 CRASH REPORT 01/03/12 MJK1 WSR2 CRASH NUMBER: F0013035 INCIDENT NUMBER: 20111200379 WSR y- -- __ + _--- y- _-- y_- y- _-- y- _y__ ^_-yry -_ UNIT NUMBER: 02 TYPE: 01 COMMERCIAL VEH: N OWNR NAME: MARSHALL JAMES E 7177611732 OWNR ADDR: 1309 WARWICK RD CAMP HILL PA 17011 VIN: 4T1BK3EK5BU621644 YR: 2011 MAKE: 49 LIC PLATE: HRV8317 PA TRAV SPD: 035 INS CO,PO,PH: NATIONWIDE MUTUAL INS 5837318978 8004213535 TOW TO,BY,PH: 50 MARKET ST, LEMOYNE, PA CANNADAY TOWG 7177632023 # TRL UNITS: 0 TYP UNIT: TAG NO,YR,ST: TYP UNIT: TAG NO,YR,ST: VEHICLE COL: 07 TYP: 01 SPEC USAGE: 00 ROLE: 2 POSITION: 03 INIT IMP PT: 11 DAMAGE: 3 DIR TRAY: E MOVEMENT: 01 GRAD: 1 ALIGNM: 1 ALCOH,DRG SUSP: 1 TEST TYP: 0 RESULT: PHYSICAL COND: 0 OWNER /DVR CD: 01 DVR PRESENCE: 1 PEDESTRIAN SIGNAL: PED LOC: VIOLATION CD: CHARGED: HARM EVENT 1: 11 L /R: MHE: Y UTIL POLE #: DRIVER ACTION 1: 19 HARM EVENT 2: L /R: MHE: UTIL POLE #: DRIVER'ACTION 2: HARM EVENT 3: L /R: MHE: UTIL POLE #: DRIVER ACTION 3: HARM EVENT 4: L /R: MHE: UTIL POLE#: DRIVER ACTION 4: VEH FAILURES: 00 PEDEST ACTION (45F1) DVR RESTRICTIONS COMPL: DVR ENDORSEMENT COMPL: DVR LICENSE COMPL: AVOIDANCE MANEUVER: UNDER RIDE INDICATOR: EMERGENCY USE: DRUG TEST TYPE: RESULTS: PRINCIPLE IMPACT PT: 01/10/2012 12:15 7176977509 PAGE 03/07 METRO THE HARRISBURG AREA POLICE INFORMATION RESOURCE SYSTEM (CRSIPINC) PAGE: 2 CRASH REPORT 01/03/12 MJK1 WSR2 CRASH NUMBER: F0013035 INCIDENT NUMBER: 20111200379 WSR ------------------------------------------ THOUGHT THE VEHICLE MAY HAVE BEEN IN THE AREA OF KFC. SUDDENLY UNIT 1 APPROACHED TRAVELING WEST AND, ACCORDING TO MARSHALL, WAS TRAVELING AT A HIGH RATE OF SPEED. UNIT 1 SWERVED INTO THE EASTBOUND LANES TO AVOID STRIKING THE VAN AND THEN SEEMED TO LOSE CONTROL, SWERVING BACK AND FORTH. MARSHALL TRIED TO SWERVE AWAY FROM UNIT 1 BUT COULDN'T AVOID CONTACT. UNIT 1 STRUCK UNIT 2 CAUSING SEVERE DAMAGE TO UNIT 2. I 'THEN SPOKE WITH WITNESS, TRACY HEINZE. SHE SAID THAT SHE WAS TRAVELING EAST AND SUDDENLY SAW A VAN BACK OUT OF A DRIVEWAY IN THE 300 BLOCK OF LOWTHER STREET. SHE SAW UNIT 1 APPROACHING AND THE VEHICLE HAD NO CHOICE BUT TO SWERVE TO AVOID CONTACT WITH THE VAN. UNIT 1 THEN WENT INTO THIS OPPOSITE LANE OF TRAVEL AND STRUCK UNIT 2. HEINZE SAID THAT IT DID NOT LOOK LIKE UNIT 1 WAS TRAVELLING TOO FAST. I THEN SPOKE AGAIN WITH KEIFER AND HAD HIM TELL ME WHAT HAPPENED. HE SAID HE WAS TRAVELING WEST ON LOWTHER STREET WHEN HE SAW A VAN BACK OUT OF A DRIVEWAY IN FRONT OF HIM. THERE WAS A VEHICLE TO HIS RIGHT SO HE HAD TO SWERVE TO THE LEFT TO AVOID HITTING THE VAN. WHEN HE DID HE WENT INTO THE OPPOSITE LANE OF TRAVEL AND THEN SAW UNIT 2 COMING TOWARDS HIM. HE SAW UNIT 2 START TO SWERVE AWAY FROM HIM AND HE TRIED TO GO BACK TO THE RIGHT. UNIT 1 THEN STRUCK UNIT 2. KEIFER SAID HE THOUGHT THAT HE WAS GOING TO HIT UNIT 2 HEAD ON. I ASKED KEIFER HOW FAST HE WAS GOING. HE SAID HE WAS TRAVELING ABOUT 40 MILES PER HOUR. HE SAID THAT HE WAS COMING OFF THE HIGHWAY AND HAD BEEN STOPPED AT THE RED LIGHT AT THE INTERSECTION OF SOUTH 3RD AND LOWTHER STREETS BEFORE THE CRASH. BOTH VEHICLES WERE TOWED FROM THE SCENE BY CANNADAY TOWING. UNIT NUMBER: 01 TYPE: 01 COMMERCIAL VEH: N OWNR NAME: KEIFER BRYCE A 7173506214 OWNR ADDR: 1 -005 WALNUT ST LEMOYNE PA 17043 VIN: 1D7RV1GT5BS543016 YR: 2011 MAKE: 07 LIC PLATE; YSA9508 PA TRAV SPD: 040 INS CO,PO,PH: GEICO 4063953659 8008413000 TOW TO,BY,PH: 50 MARKET ST, LEMOYNE, PA CANNADAY TOWG 7177632023 # TRL UNITS: 0 TYP UNIT: TAG NO,YR,ST: TYP UNIT: TAG NO,YR,ST: VEHICLE COL: 05 TYP: 04 SPEC USAGE: 00 ROLE: 1 POSITION: 07 INIT IMP PT: 11 DAMAGE: 3 DIR TRAV: W MOVEMENT: 08 GRAD: 1 ALIGNM: 1 ALCOH,DRG SUSP: 1 TEST TYP: 0 RESULT: PHYSICAL COND: 0 OWNER /DVR CD; 01 DVR PRESENCE: 1 PEDESTRIAN SIGNAL: PED LOC: VIOLATION CD; CHARGED: HARM EVENT 1: 02 L /R: MHE; Y UTIL POLE #: DRIVER ACTION 1: 18 HARM EVENT 2: L /R: MHE: UTIL POLE #: DRIVER ACTION 2: HARM EVENT 3: L /R: MHE: UTIL POLE #: DRIVER ACTION 3: HARM EVENT 4: L /R: MHE: UTIL POLE #: DRIVER ACTION 4: VEH FAILURES: 00 PEDEST ACTION . (45F1) DVR RESTRICTIONS COMPL: DVR ENDORSEMENT COMPL: DVR LICENSE COMPL: AVOIDANCE MANEUVER; UNDER RIDE INDICATOR: EMERGENCY USE: DRUG TEST TYPE: RESULTS: PRINCIPLE IMPACT PT: 01/10/2012 12:15 7176977509 PAGE 02/07 METRO THE HARRISBURG AREA POLICE INFORMATION RESOURCE SYSTEM (CRSIPINC) PAGE: 1 CRASH REPORT 01/03/12 MJK1 WSR2 CRASH NUMBER: F0013035 INCIDENT NUMBER: 20111200379 WSR CASE CLOSED: Y ---------------------------------------------------- AGENCY: 21503 WEST SHORE REGIONAL DISP -TM: 1323 ARRV -TM: 1326 PATROL -ZN: 02 PRECINCT: 510 HERMAN AVE INV -DT: 12 -23 -2011 INVESTIGATOR: HAIR, DANIEL L BADG: 3206 APP -DT: 12 -28 -2011 REVIEWER: HOPE, MICHAEL L BADG: 3201 COUNTY: 21 CUMBERLAND MUNICIPALITY: 403 LEMOYNE CRS --DT: 12 -23 -2011 TM: 1320 #UNIT: 2 #PEOP: 2 #INJ: #KILL: REPORTABLE: Y NOTIF HIWY MAINT: N PENNDOT PROP: N SCH BUS RELATED: N SCH ZON RELATED: N FOLLOW UP: N CITY PROP DAM: Z CRASH DESC: 6 REL TO RDWY: 1 ILLUM: 1 WEATHER: 1 RDWY SURF COND: 0 INTERS TYP: 00 SPEC LOC: 0 SPEC JURIS: RDWY SURF TYPE: PRINC RD - CNTY: 21 RT #: SEG: #LNS: 04 SPD LIM: 35 ORIENT: W STR NM: LOWTHER ST HOUSE #: 00500 RT S INSEC RD - CNTY: RT #: SEG: #LNS: SPD LIM: ORIENT: STR NM: RT SIGN: LANDMARKI - RT#: MILEPOST: 0000 SEG MARKER: ORIENT: STR NM: DIST FR CRASH - FT: MI: .0 LANDMARK2 - RT #: MILEPOST: 0000 SEG MARKER: ORIENT: STR NM: TRAF CONTROL DEVICE TYPE: 0 FUNCTIONING: 0 WORK ZONE - TYP: LOC: SPEED LIM: WORKERS PRES: LN CLOS: RD CL /DETOUR: SHLD /MED WK: MOVING WK: FLAGGER: OTHER: LANE CLOSED DUE TO CRS: 1 DIRECT: 6 TRAP DETOUR: N EST TM CLOSE: 2 FIRST HARMFUL EV: 02 UN #: 01 MOST HARMFUL EV: 02 UN #: 01 ENV /RDWY FACTORS: 00 PRIME FACTOR: D 19 UN #: 02 WITNESS: TRACY M HEINZE PH: 7178297046 ADDR: 616 ERFORD RD, CAMP HILL,PA 17011 ON FRIDAY, DECEMBER 23, 2011 AT 1323 HOURS I WAS DISPATCHED TO THE 300 BLOCK OF LOWTHER STREET FOR A REPORTED HIT AND RUN CRASH. THE INFORMATION PROVIDED AT THE TIME WAS THAT A GOLD COLORED VAN WAS INVOLVED AND FLED THE SCENE AND WAS LAST SEEN ON S. 3RD STREET HEADING TOWARDS NEW CUMBERLAND BOROUGH. I HAD COUNTY CONTROL ADVISE NEW CUMBERLAND TO BE ON THE LOOK OUT FOR THAT VEHICLE. I ARRIVED ON THE SCENE AT 1326 HOURS. AS I WAS TRYING TO EXIT MY PATROL VEHICLE I WAS ADVISED BY A PERSON ON THE SCENE THAT THE VAN WAS NOW TRAVELING WEST ON LOWTHER STREET AT A HIGH RATE OF SPEED. I ATTEMPTED TO LOCATE THE VAN WITH NO LUCK. I RETURNED TO THE CRASH SCENE AND HAD COUNTY CONTROL DISPATCH THE FIRE DEPART- MENT AND FIRE POLICE FOR TRAFFIC CONTROL AND DEBRIS REMOVAL. I WAS DIRECTED BY ANOTHER PASSERBY TO AN OLDER WHITE MALE WHO WAS TO BE OPERATING ONE OF THE INVOLVED VEHICLES. THE PASSERBY DID NOT WITNESS THE CRASH. THE MALE WAS THE OPERATOR OF UNIT 2 AND IDENTIFIED AS JAMES E MARSHALL, 1309 WARWICK RD, CAMP HILL, PA 17011. I ASKED MARSHALL IF HE WAS INJURED AND HE SAID NO. MARSHALL SAID THAT HE WAS TRAVELING EAST ON LOWTHER STREET WHEN HE SAW A VEHICLE AHEAD OF HIM THAT APPEARED TO BE TRYING OR WAITING TO TURN LEFT. HE .., J Actions Loss ink Rptd By,/ / "tness'Infn PH N A COS Info CLASS Loss Desa'ipt on: CV MADE UNSAFE LANE CHANGE, STRUCK IV. CC /GEICO PAID LIMITS. PURUSING CVD /O KEIFER. COLL: 11944.90 AFTER LIMITS PAID DED REMAItNING: 345.00 TOTAL: 12289.90 Loss toe: '' LOWTHER ST LEYMONE PA17043CUMBERLAND Loss: 12-23-2011 Tsrne 13:24 Rpt -23 -2011 Wit: Y cat d4 , Prior Ckrns Y Fault: U E anch Neg: � Policefte: COUN201112379 Non MN'Owner: Non NW veh: k K: f " CERTIFICATE OF SERVICE I, Miranda Lee, Esquire, attorney for the Plaintiff, hereby certify that a true and correct copy of the foregoing Complaint has been served on Defendant and all counsel of record, if any by United States First Class Mail, according to the Pennsylvania Rules of Civil Procedure, on the 19th day of December, 2013. BRYCE KEIFER 1005 WALNUT STREET LEMOYNE, PA 17043 Respectfully Submitted, By: kL� Miranda Lee, Esquire Attorney for Plaintiff