HomeMy WebLinkAbout14-0535 Supreme Cour`.t , Pennsylvania
Court;ofCommon,Pleas For Prothonotary Use Only:
Ci,il'Cover Sheet
(< Docket No:
Cumberland` County lt/._
77 a7
The information collected on this form is used solely court administration. purposes. This form does not
supplement or replace the and service of pleadings or other papers as required by late or rules of court.
Commencement of Action:
S E Complaint El Writ of Summons El Petition
Transfer from Another Jurisdiction ❑ Declaration of Taking
E
C Lead Plaintiff's Name: Lead Defendant's Name:
State Farm Mutual Automobile Insurance Co. James Miller et al
T Dollar Amount Requested: ❑x within arbitration limits
I Are money damages requested? ❑x Yes ❑ No (check one) ❑outside arbitration limits
O
N Is this a Class Action Suit? ❑ Yes E No Is this an MDJAppeal? ❑ Yes Z No
A Name of Plaintiff /Appellant's Attorney: Paul F. D'Emilio, Esquire
❑ Check here if you have no attorney (are a Self- Represented (Pro Sel 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.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
❑ Intentional ❑ Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment
❑x Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
Nuisance ❑ Dept. of Transportation
Premises Liability ❑ Statutory Appeal: Other
S ❑ Product Liability (does not include
E mass tort) El Employment Dispute:
❑ Slander/Libel /Defamation Discrimination
El C El Other: Employment Dispute: Other El ZoningBoard
El
,
I ❑ Other:
O MASS TORT
Asbestos
N ❑ Tobacco
Toxic Tort - DES
❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
Toxic Waste
Other: El Ejectment El Common Law /Statutory Arbitration
B ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment
❑ Ground Rent ❑ Mandamus
El Landlord /Tenant Dispute ❑ Non - Domestic Relations
❑ Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABLITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto
❑ Dental ❑ Partition ❑ Replevin
❑ Legal ❑ Quiet Title ❑ Other:
❑ Medical ❑ Other:
❑ Other Professional:
Updated 1/1/2011
PAUL F. D'EMILIO, ESQUIRE THIS IS AN ARBITRATION MATTER
ATTORNEY I.D. #16654
PAUL M. SCHOFIELD, JR., ESQUIRE
ATTORNEY I.D. #81894
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064 ATTORNEY FOR PLAINTIFF
(610) 338 -0338
STATE FARM MUTUAL AUTOMOBILE COMMON PLEAS COURT
INSURANCE COMPANY AS SUBROGEE OF : CUMBERLAND COUNTY
AMY BERKHEIMER
112 E. WASHINGTON STREET DTB 8
BLOOMINGTON, IL 61701
VS.
JAMES MILLER NO.
40 TRUDY CIRCLE
MECHANICSBURG, PA 17050
AND c
ANDREW MILLER
Mw
40 TRUDY CIRCLE Cn
MECHANICSBURG, PA 17050 CIVIL COMPLAINT r � -�
E , )
NOTICE AVISO >�
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND LE HAN DEMANDADO A USTED EN LA CORTt1SI U 2ED
AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, QUIERE DEFENDERSE DE ESTAS DEMANDAtEXPUESTAS -EN
YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER LAS PAGINAS SIGUIENTES, USTED TIENE (20) DIAS DE PLAZO
THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A A PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION.
WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA O EN
FILING IN WRITING WITH THE COURT YOUR DEFENSES OR PERSONA 0 POR ABOGADO Y ARCHIVAR EN LA CORTE SUS
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU DEFENSAS 0 SUS OBJECIONES A LAS DEMANDAS ENCONTRA
ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY DE SU PERSONA. SEA AVISADO QUE SI USTED NO SE
PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR
AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE UNA ORDEN CONTRA USTED SIN PREVIO AVISO 0
FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY NOTIFICACION O POR CUALQIER QUEJA O ALIVIO QUE
OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. ESPEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE
YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS PERDER DINERO, SUS PROPIEDADES O OTROS DERECHOS
IMPORTANT TO YOU. IMPORTANTES PARA LISTED.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI
IF YOU DO NOT HAVE A LAWYER„ GO TO OR TELEPHONE THE NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE
OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU PARA PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR
WITH INFORMATION ABOUT HIRING A LAWYER. TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA
ESCRITA ABAJO PARA AVERIGUAR DONDE USTED PUEDE
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE CONSEGUIR ASISTENCIA LEGAL.
MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT
AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association
32 S. Bedford Street
Cumberland County Bar Association Carlisle, PA 17013
32 S. Bedford Street (717) 249 -3166 Carlisle, PA 17013 (800) 990 -9108 QD
(717) 249 -3166 `�
(800) 990 -9108 t��
ck-� a..3sys
, b0.0 S
PAUL F. D EMILIO, ESQUIRE THIS IS AN ARBITRATION MATTER
ATTORNEY I.D. #16654
PAUL M. SCHOFIELD, JR., ESQUIRE
ATTORNEY I.D. #81894
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064 ATTORNEY FOR PLAINTIFF
(610) 338 -0338
STATE FARM MUTUAL AUTOMOBILE COMMON PLEAS COURT
INSURANCE COMPANY AS SUBROGEE OF : CUMBERLAND COUNTY
AMY BERKHEIMER
112 E. WASHINGTON STREET DTB 8
BLOOMINGTON, IL 61701
VS.
JAMES MILLER NO.
40 TRUDY CIRCLE
MECHANICSBURG, PA 17050
AND
ANDREW MILLER
40 TRUDY CIRCLE
MECHANICSBURG, PA 17050 CIVIL COMPLAINT
NOTICE UNDER THE FAIR DEBT COLLECTION PRACTICES ACT,
15 U.S.U. §1601 (AS AMENDED)
THE PENNSYLVANIA UNFAIR TRADE PRACTICES ACT
AND CONSUMER PROTECTION LAW,
73 PA.CON.STAT.ANN. §201, ET. SEQ. ( "THE ACTS ")
IN AS MUCH AS THE ACTS MAY APPLY, PLEASE BE ADVISED
THAT THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
The Plaintiff, State Farm Mutual Automobile Insurance Company, by its attorney
Paul F. D'Emilio, Esquire, bring this action upon a cause whereof the following is a
statement:
1. The Plaintiff, State Farm Mutual Automobile Insurance Company, ( "Plaintiff') is a
Corporation authorized to do business in the Commonwealth of Pennsylvania, with a
address of 112 E. Washington Street, DTB 8, Bloomington, IL 61701.
Plaintiff brings this action as subrogee of Amy Berkheimer the ( "Insured ") under
a policy of insurance issued by Plaintiff.
2. Defendant, James Miller, is an individual residing at 40 Trudy Circle,
Mechanicsburg, PA 17050.
3. Defendant, Andrew Miller, is an individual residing at 40 Trudy Circle,
Mechanicsburg, PA 17050.
4. At all times hereinafter mentioned Defendant James Miller was the agent,
workman, servant, employee of Defendant Andrew Miller then and there in engaged in
the business of Defendant Andrew Miller within the course and scope of his
employment.
5. On or about March 12, 2012 a motor vehicle owned by Defendant Andrew Miller
and operated by Defendant James Miller on E Trindle Road, Mechanicsburg,
Pennsylvania when he rear -ended Plaintiff's Insured's vehicle causing the damages
hereinafter set forth.
6. The Insured's vehicle was a total loss and Defendant is liable to Plaintiff for the
damages as allowed by law thereto being is Six Thousand Two Hundred Seventy
Five and 40/100 ($6,275.40) Dollars plus the Insured's deductible of Five Hundred
and 00/100 ($500.00) Dollars plus the costs of a rental vehicle being Two Hundred
Fifteen and 62/100 ($215.62) less salvage received of Six Hundred Thirty Six 50/100
($636.50) Dollars for a total of Six Thousand Three Hundred Fifty Four and 54/100
($6,354.52) Dollars.
Count I
State Farm Mutual Automobile Insurance Company v. James Miller
7. Plaintiff, incorporates by reference all the allegations contained in paragraphs 1
through 6 inclusive of this Complaint as fully as though same were herein and set forth
at length.
8. The said occurrence was due to the negligence of Defendant, James Miller that
he:
a. did fail to have the motor vehicle under proper and adequate control;
b. did operate the motor vehicle at an excessive rate of speed;
C. did fail to apply the brakes in time to avoid the collision;
d. did negligently apply the brakes;
e. did fail to operate the vehicle in accordance with existing conditions;
f. did fail to drive at a speed and in the manner that would allow him to stop
within the assured clear distance ahead;
g. did fail to keep a reasonable lookout for other vehicles lawfully on the
road;
h. did operate the motor vehicle without due regards for the rights, safety
and position of the Insured at the point of aforesaid;
i. did operate the vehicle without Insurance;
j. did fail to maintain financial responsibility; and
k. did violate the various statutes and laws of the Commonwealth of
Pennsylvania and County of Cumberland pertaining to the operation of motor vehicles.
Count II
State Farm Mutual Automobile Insurance Company v. Andrew Miller
9. Plaintiff, incorporates by reference all the allegations contained in paragraphs 1
through 8 inclusive of this Complaint as fully as though same were herein and set forth
at length.
10. The said occurrence was due to the negligence of Defendant, Andrew Miller, in
that he:
a. negligently entrusted his vehicle to another operator for use when
he knew, or with a reasonable exercise of due care should have known, that the
operator was not capable of operating the motor vehicle properly;
b. negligently entrusted his motor vehicle to a person which he
knew, or in the exercise of reasonable care should have known, was an incompetent
driver;
C. negligently entrusted his motor vehicle to a person known, should
have known or in the exercise of reasonable care would have known, was going to drive
the vehicle in an improper, dangerous or reckless manner;
d. negligently entrusted his motor vehicle to another person who he
knew, should have known or in the exercise of due care would have known would
cause damages to another; and
e. negligently entrusted his motor vehicle to a person who did not
maintain financial responsibility as required by the laws of the Commonwealth of
Pennsylvania.
WHEREFORE, Plaintiff demands judgment against the Defendant upon each
court in an amount not in excess of Fifty Thousand and 00/100 ($50,000.00) dollars
together with costs of suit.
Date P I F. E ilio, Esquire
'ratification No. 16654
-mail address: pauld demiliolaw.com
Paul M. Schofield, Jr., Esquire
Identification No. 81894
E -mail address: pauls -demiliolaw.com
905 W. Sproul Road, Suite 105
Springfield, PA 19064
Telephone No.: 610 - 338 -0338
Fax no.: 610 - 338 -0303
1 I S l.T
Automobile Insurance Company in the above captioned matter verifies that the facts
contained in the foregoing Complaint are true and correct. I understand that false
statements herein are made subject to the penalties of 18 pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: �f ��a o� C ��
Subroga ion eciali
ar. +:+ +:;anmfia
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff c- +,,� ;��,�?
0i cluriber,Jody S Smith 1Q 14 F
Chief Deputy € 20 Pf f 2,
Richard W Stewart Fh( yr COUNT
r�s ,
Solicitor - '
State Farm Mutual Automobile Insurance Company a/s/o Amy Berkheimer Case Number
vs.
James Miller(et al.) 2014-535
SHERIFF'S RETURN OF SERVICE
01/31/2014 11:16 AM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Complaint&
Notice by handing a true copy to a person representing themselves to be Melissa Miller, Wife, who
accepted as"Adult Person in Charge"for James Miller at 40 Trudy Circle, Hampden Township,
Mechanicsburg, PA 17050. p
UTSHAL EPUTY
02/11/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit:Andrew Miller, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Complaint& Notice as"Not Served" at 40
Trudy Circle, Hampden Township, Mechanicsburg, PA 17050. Defendant is active military and is currently
deployed in Iraq.
SHERIFF COST: $55.30 SO ANSWERS,
February 11, 2014 RoN101 RANDERSON, SHERIFF
PAUL F. D'EMILIO, ESQUIRE
ATTORNEY I.D. #16654
PAUL M. SCHOFIELD, JR, ESQUIRE
ATTORNEY I.D. #81894
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064
(610) 338-0338
STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY AS SUBROGEE OF :
AMY BERKHEIMER
112 E. WASHINGTON STREET DTB 8
BLOOMINGTON, IL 61701
VS.
•
•
PROTHON
11114 SEP
CU,��E 22 Pt/ 1' �� 1
PENN Y
� L' D OU` Y
l�1,4
COMMON PLEAS COURT
CUMBERLAND COUNTY
JAMES MILLER NO. 14-535
40 TRUDY CIRCLE
MECHANICSBURG, PA 17050
AND
ANDREW MILLER •
40 TRUDY CIRCLE
MECHANICSBURG, PA 17050 CIVIL COMPLAINT
PRAECIPE FOR JUDGMENT AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY, C.P.:
Enter Judgment in the above entitled matter in favor of the Plaintiff, State Farm
Mutual Automobile Insurance Company as subrogee of Amy Berkheimer and against
the Defendant James Miller, for want of an answer, and assess Plaintiffs damages in
the sum of $6,354.52 in accordance with a Complain
AUL F. D'EMILIO, ESQUIRE
ATTORNEY FOR PLAINTIFF
ATTORNEY I.D. #16654.
Prothy assesses Plaintiff's damage n the sum of $6,354.52
PRO PROTHY- -
�`" h
oivtAIRJ
PAUL F. D'EMILIO, ESQUIRE
ATTORNEY I.D. #16654
PAUL M. SCHOFIELD, JR, ESQUIRE
ATTORNEY I.D. #81894
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064
(610) 338-0338
STATE FARM MUTUAL AUTOMOBILE •
INSURANCE COMPANY AS SUBROGEE OF :
AMY BERKHEIMER •
112 E. WASHINGTON STREET DTB 8
•
BLOOMINGTON, IL 61701
VS.
JAMES MILLER NO. 14-535
40 TRUDY CIRCLE •
MECHANICSBURG, PA 17050
AND
ANDREW MILLER •
40 TRUDY CIRCLE
•
MECHANICSBURG, PA 17050 CIVIL COMPLAINT
COMMON PLEAS COURT
CUMBERLAND COUNTY
AFFIDAVIT AS TO NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
: SS
COUNTY OF DELAWARE
PAUL F. D'EMILIO, being duly sworn according to law, deposes and says that he
is the agent for the Plaintiff above-named and is authorized to and does make this
Affidavit on its behalf; and that he has knowledge of the facts set forth herein:
That Defendant James Miller, is over twenty-one years of age and is not in the
military service of the United States or otherwise within the provisions of the Soldier's
and Sailor's Civil Relief Act of 1940 as amended.
PAUL F. D'EMILIO, ESQUIRE
ATTORNEY FOR PLAINTIFF
PAUL F. D'EMILIO, ESQUIRE
ATTORNEY LD. #16654
PAUL M. SCHOFIELD, JR, ESQUIRE
ATTORNEY I.D. #81894
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064
(610) 338-0338
STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY AS SUBROGEE OF
AMY BERKHEIMER
112 E. WASHINGTON STREET DTB 8
BLOOMINGTON, IL 61701
VS.
JAMES MILLER
40 TRUDY CIRCLE
MECHANICSBURG, PA 17050
AND
ANDREW MILLER
40 TRUDY CIRCLE
MECHANICSBURG, PA 17050
COMMON PLEAS COURT
CUMBERLAND COUNTY
NO. 14-535
CIVIL COMPLAINT
AFFIDAVIT OF NOTICE OF INTENT TO ENTER DEFAULT JUDGMENT
I, PAUL F. D'EMILIO, ESQUIRE, attorney for the Plaintiff, State Farm Mutual
Automobile Insurance Company as subrogee of Amy Berkheimer, does hereby
certify that a Notice of Intent to Enter Default Judgment was mailed on March 7,
2014 to the Defendant listed below by Certificates of Mailings; a copy of the Notice and
the original certifications of mailings are attached hereto, made a part hereof, and
marked Exhibit "A".
JAMES MILLER
40 TRUDY CIRCLE
MECHANICSBURG, PA 17050
F. D'EMILIO, ESQUIRE
ORNEY FOR PLAINTIFF
IN THE COURT OF COMMON PLEAS OF Cumberland County, PENNSYLVANIA
CIVIL ACTION- LAW
(Rule of Civil Procedure No. 236)
STATE FARM MUTUAL AUTOMOBILE COMMON PLEAS COURT
INSURANCE COMPANY AS SUBROGEE OF : CUMBERLAND COUNTY
AMY BERKHEIMER
112 E. WASHINGTON STREET DTB 8
BLOOMINGTON, IL 61701
VS.
JAMES MILLER
40 TRUDY CIRCLE
MECHANICSBURG, PA 17050
AND
ANDREW MILLER
40 TRUDY CIRCLE
MECHANICSBURG, PA 17050
NO. 14-535
CIVIL COMPLAINT
Notice is given that a judgment in the above ptio d m has been ered
against you on q , 2014. ,
Prothopot
If you have any questions concerning the above please contact:
Paul F. D'Emilio, Esquire
Attorney or Party Filing
905 W. Sproul Road, Suite 105
Address
Springfield, PA 19064
City, State, Zip
(610) 338-0338
Telephone Number
PAUL F. D'EMILIO, ESQUIRE
ATTORNEY I.D. #16654
PAUL M. SCHOFIELD, JR, ESQUIRE
ATTORNEY ID. #81894
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064
(610) 338-0338
STATE FARM MUTUAL AUTOMOBILE COMMON PLEAS COURT
INSURANCE COMPANY AS SUBROGEE OF CUMBERLAND COUNTY
AMY BERKHEIMER
112 E. WASHINGTON STREET DTB 8
BLOOMINGTON, IL 61701
VS.
JAMES MILLER
40 TRUDY CIRCLE
MECHANICSBURG, PA 17050
AND
ANDREW MILLER
40 TRUDY CIRCLE
MECHANICSBURG, PA 17050
NO. 14-535
CIVIL COMPLAINT
CERTIFICATION AS TO ADDRESS OF DEFENDANT
I hereby certify the address of Defendant is as follows:
JAMES MILLER
40 TRUDY CIRCLE
MECHANICSBURG, PA 17050
PAUL' 10, ESQUIRE
ATTORNEY FOR PLAINTIFF
PAUL F. D'EMILIO, ESQUIRE
ATTORNEY I.D. #16654
PAUL M. SCHOFIELD, JR, ESQUIRE
ATTORNEY I.D. #81894
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064
(610) 338-0338
STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY AS SUBROGEE OF :
AMY BERKHEIMER
112 E. WASHINGTON STREET DTB 8
BLOOMINGTON, IL 61701
VS.
JAMES MILLER
40 TRUDY CIRCLE
MECHANICSBURG, PA 17050
AND
ANDREW MILLER
40 TRUDY CIRCLE
MECHANICSBURG, PA 17050
COMMON PLEAS COURT
CUMBERLAND COUNTY
NO. 14-535
CIVIL COMPLAINT
CERTIFICATION AS TO ADDRESS OF PLAINTIFF
i hereby certify the address of Plaintiff, State Farm Mutual Automobile Insurance
Company as subrogee of Amy Berkheimer is as follows:
PO Box 2371
Bloomington IL 61702-2371
PAUL . D'EMILIO, ESQUIRE
ATTORNEY FOR PLAINTIFF
rtreandAddrassof Sender
Check type of mail or service:
❑ Certified 0 Recorded Delivery (International)
❑ COD 0 Registered
❑ Delivery Confirmation 0 Return Receipt for Merchandise
❑ Express Mail 0 Signature Confirmation
❑ Insured
Affix Stamp Here
(lf issued as a
� 131. - } k r •,.017H 15526041
certificate of mailing,
or for additional
copies of this bill)
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PAUL F. D'EMILIO, ESQUIRE
ATTORNEY I.D. #16654
PAUL M. SCHOFIELD, JR., ESQUIRE
ATTORNEY I.D. #81894
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064
(610) 338-0338
THIS IS AN ARBITRATION MATTER
ATTORNEY FOR PLAINTIFF
STATE FARM MUTUAL AUTOMOBILE COMMON PLEAS COURT
INSURANCE COMPANY AS SUBROGEE OF : CUMBERLAND COUNTY
AMY BERKHEIMER
112 E. WASHINGTON STREET DTB 8
BLOOMINGTON, IL 61701
VS.
JAMES MILLER
40 TRUDY CIRCLE
MECHANICSBURG, PA 17050
AND
ANDREW MILLER
40 TRUDY CIRCLE
MECHANICSBURG, PA 17050
NO. 14-535
. CIVIL COMPLAINT
DATE OF NOTICE: March 7, 2014
TO: JAMES MILLER
40 TRUDY CIRCLE
MECHANICSBURG, PA 17050
NOTICE OF INTENT TO ENTER DEFAULT JUDGMENT
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS
NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING
AND YOU•MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
FOR CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Pad 7.V'Emilio
PAUL F. D'EMILIO, ESQUIRE