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HomeMy WebLinkAbout14-3369E C T i 0 N A B Supa;eme Court:of Pennsvlvania • Cou hof Com on Pleas f.1; C,ovei' Sheet CUMBERLAND \," `� County 20281428 C Y Jer HOH WWR # For Prothonotary Use Only: Docket No: The information collected on this form is used soler: 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: if Complaint 0 Writ of Summons — T ---� - . A„nthar Tnricd.irtiOn Progressive Advanced Insurance Company Plaintiff Are money damages requested? El Yes ❑ Petition • Declaration of Taking Lead Defendant's Name: SARAH WRIGHT Cl No Dollar Amount Requested: 0 within arbitration limits (check one) ❑ outside arbitration limits Is this a Class Action Suit? ❑ Yes al No Is this an MDJ Appeal? 0 Yes al No Name of Plaintiff /Appellant's Attorney: Benjamin W. Lawrence,209032 0 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. TORT (do not include Mass Tort) Intentional Malicious Prosecution ❑ Motor Vehicle ❑ Nuisance ❑ Premises Liability ❑ Product Liability (does not include Mass tort) ❑ Slander/Libel/Defamation La Other: 5A1) yL yXk b'k MASS TORT ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort — Implant ❑ Toxic Waste ❑ Other: PROFESSIONAL LIABILITY ❑ Dental ❑ Legal ❑ Medical ❑ Other Professional: CONTRACT (do not include Judgments) ❑ Buyer Protection ❑ Debt Collection: Credit Card ❑ Debt Collection: Other ❑ Employment Dispute Discrimination ❑ Employment Dispute: Other O Other: REAL PROPERTY ❑ Ejectment In Eminent Domain/Condemnation ❑ Ground Rent ❑ Landlord/Tenant Dispute o Mortgage Foreclosure: Residential ❑ Mortgage Foreclosure: Commercial ❑ Partition ❑ Quiet Title ❑ Other: CIVIL APPEALS Administrative Agencies ❑ Board of Assessment ❑ Board of Elections ❑ Dept. of Transportation ❑ Statutory Appeal: Other ❑ Zoning Board ❑ Other: MISCELLANEOUS ❑ Common Law/Statutory Arbitration ❑ Declaratory Judgment ❑ Mandamus o Non -Domestic Relations Retraining Order O Quo Waranto ❑ Replevin O Other: Updated 1/1/2011 ct!t lid r1. ,11 ii LAP NS. CC0Y/.VA �f "T, 1: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Progressive Advanced Insurance Company Plaintiff vs. SARAH WRIGHT Defendant CIVIL DIVISION COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Benjamin W. Lawrence,209032 WELTMAN, WEINBERG & REIS CO., L.P.A. 325 CHESTNUT STREET SUITE 501 PHILADELPHIA, PA 19106-2614 215-599-1500 FAX: 215-599-1505 20281428 C Y Jer HOH JO.7�p eukiI(e1y9 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION d Civil Action No COMPLAINT AND NOTICE TO DEFEND Progressive Advance Insurance Company Plaintiff vs. SARAH WRIGHT Defendant 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 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. 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 CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. BY: Benjamin W. Lawrence, Esquire Pa. Identification No.209032 325 Chestnut Street, Suite 501 Philadelphia, PA 19106 Phone: 215.599.1500 Fax: 215.599.1505 File #20281428 Attorney for Plaintiff(s) PROGRESSIVE ADVANCED INSURANCE COMPANY vs. SARAH WRIGHT Court of Common Pleas Cumberland County NO. CIVIL ACTION — COMPLAINT 1. Plaintiff is a business organization licensed and authorized to conduct business in the State of Ohio with a place of business located at 5920 Landerbrook Drive, Mayfield Heights, Ohio 44124. 2. Defendant is an adult individual who at all time pertinent hereto resided at 267 Wyoming Avenue, Enola, Pennsylvania 17025. 3. Progressive issued a policy of motor vehicle insurance whereby Progressive agreed to insure the motor vehicle involved in this incident ("Insured Vehicle"), owned by Plaintiff's insured. 4. On or about August 25, 2012 Defendant was the operator of a motor vehicle which vehicle did negligently, recklessly and/or carelessly collide with the Plaintiff Insured's vehicle at or near Annette Drive and Randi Road, East Pennsboro, Pennsylvania. 5. The negligence and/or carelessness of the Defendant consisted of the following: a. Failing to have his motor vehicle under such control as the situation warranted; b. Operating his motor vehicle in complete disregard of the point and position of Plaintiff's vehicle; c. Failing to keep a proper lookout; d. Traveling too fast for conditions; e. Disregarding traffic control devices; f. Failing to abide by the Rules of the Road and the Motor Vehicle Code of Pennsylvania; g. Being otherwise negligent under the circumstances; and, h. Being negligent as a matter of law as may be relevant through discovery and/or at the time of trial. 6. As a direct and proximate result of Defendant's negligence, the Progressive Insured's vehicle sustained property damage and/or incurred rental charges in the total amount of $4,091.42. See attached as Exhibit "1" a copy of the damage documentation which documents Plaintiff further intends to introduce at the arbitration in this matter. 7. Pursuant to the insurance policy issued by Progressive and as a result of the aforesaid payment, Progressive became subrogated to the claim of its Insured against Defendant. WHEREFORE, Plaintiff demands Judgment against Defendant in the amount of $4,091.42 plus interest and costs. WELTMAN, WELD B & REIS, CO., L.P.A. Benjamin W " awrence, Esquire PA I.D. # 2 9032 325 Chestnut Street Suite 501 Philadelphia, PA 19106 (215) 599-1500 WWR#09293502 E_1 Claim Payment Detail Claim Payment Detail ( 12-3539510 ) — Payment Information Disbursement Number: EFT Trace Number: Paid To: Mailing Address: In Payment Of: 766309639 711247067 BIKS AUTO COLLISION LLC 1101 BERRYHILL ST HARRISBURG, PA 17104 USA Progressive Invoice Number: 7386908 Total Amount: Invoice Number: Page 1 of 1 $3,232.11 7386908 --Vendor Information Name: Type: 1099 Required: No — Reviewed Summary Issuing Rep: Issue Date: Last Updated Rep: SDW0004 09-11-12 SDW0004 Approved By: Review Date: Reviewed By: — Bank Information Type: Stop Reason: Stop Date: Loss Bank Code: Cleared: CTB 09-12-12 —Exposure Detail: COLL Party Name: Property Description: Payment Type: CARBAUGH, AMANDA L 09 HYUND SONATA FINAL PAYMENT Amount Paid: Deductible Taken: Property Damage: Rental: $3,232.11 $500.00 $3,232.11 $0.00 http://claimspayments/Alpha/ClaimsPaymentsWeb/default.aspx?page=ClaimPaymentDeta... 1/10/2014 Claim Payment Detail Claim Payment Detail ( 12-3539510 ) Payment Information Disbursement Number: EFT Trace Number: Paid To: Mailing Address: In Payment Of: —Vendor Information Name: Type: 766330196 Page 1 of 1 Total Amount: Invoice Number: ENTERPRISE RENT -A -CAR ENTERPRISE RENT -A -CAR 3950 HARTZDALE DR CAMP HILL, PA 17011-7828 ENTERPRISE RENT -A -CAR RENTAL INVOICE # 57PRD009458 $359.31 ENTERPRISE RENT... GLASS SHOP 1099 Required: --Reviewed Summary Issuing Rep: Issue Date: Last Updated Rep: —Bank Information Type: Stop Reason: Stop Date: A091257 09-17-12 A091257 Approved By: Review Date: Reviewed By: Loss Bank Code: Cleared: CTB 09-19-12 —Exposure Detail: RENTAL Party Name: CARBAUGH, AMANDA L Property Description: 09 HYUND SONATA Payment Type: FINAL PAYMENT Amount Paid: Deductible Taken: Property Damage: Rental: $359.31 $0.00 $0.00 $359.31 http://claimspayments/Alpha/ClaimsPayments Web/default.aspx?page=ClaimPaymentDeta... 1/10/2014 ARMS® - Automated Rental Management System MSPROGRESSIVE Page 1 of 1 Rental Company:ENTERPRISE RENT -A -CAR Invoice: D009458-57PR Bill To: PGR5701 PROGRESSIVE ATTN: CHRISTINA INCH 3950 HARTZDALE DRIVE CAMPHILL , PA 17011 RENTER INFORMATION: Renter: CARBAUGH, AMANDA RENTAL INFORMATION: Rental Branch Location: ENTERPRISE RENT -A -CAR (57PR) 3950 HARTZDALE DR CAMP HILL, PA 170117828 (717) 730-1460 ADDITIONAL CLAIM INFORMATION: Claim Number :12-3539510 Claim Type: Insured Vehicle Condition: Driveable Date Of Loss: Insured Name: Owner's Vehicle: 2009 HYUNDAI SONAT Additional Driver: Repair Facility: PROGRESSIVE BODY SHOP CAMP HILL, PA 17011 (717) 730-1460 VEHICLES RENTED: RENTAL DETAIL: Rental Period: 8/29/12 to 9/10/12 (13 days) Billed Period: 8129112 to 9/10/12 (13 days) Products and Services 13 DAYS Rate Amount 23.74 $308.62 Taxes and Surcharges 13 PTA TAX 2.00 1 SALES TAX% ....__...`:........_......_8.00% Total Charges: Less Amount Received: Total Amount Due: $26.00 $24.69 . ........................ $359.31 $0.00 $359.31 Effective Date and Time Year Make Model VIN Starting Mileage Ending Mileage Mileage Rate Charged 8/29/12 3:24 PM 2012 NISN SENT 3N1AB6APXCL656262 21626 22221 595 $23.74 Please Return This Portion with Remittance Make Payment To: ENTERPRISE RENT -A -CAR P.O. BOX 840086 KANSAS CITY, MO 64184-0086 Federal ID: 43-0724835 Rental Invoice https://www.armsweb.com/armsweb/closedcustomerfile.do Total Charges: $359.31 Less Amount Received: $0.00 Total Amount Due $359.31 Please include on your check: Invoice: D009458-57PR 1/10/2014 BIKS AUTO COLLISION 1101 BERRYHILL STREET, HARRISBURG, PA 17104 (717) 2345615 Damage Assessed By: 135817- Mike Nagurney Type of Loss: Date of Loss: Deductible: Claim Number: Insured: Owner: Address: Telephone: Description: Body Style: VIN: Mileage: OEM/ALT: Color: Options: Property Damage 8/25/2012 500.00 12-3539510-01 AMANDA CARBAUGH AMANDA CARBAUGH 267 WYOMING AVE, ENOLA, PA 17025 Home Phone: (717) 343-8972 Contact Phone: (717) 623.4310 Appraised For: ALLISON GAYER (717) 730-1575 Mitchell Service: 910551 Date: Estimate ID: Estimate Version: Committed Profile ID: Cell Phone: (717) 623-4310 2009 Hyundai Sonata GLS Vehicle Production Date: 7/08 4D Sed Drive Train: 2.4L In) 4 Cyl 5A FWD 5NPET46C89H487048 License: HWD-6779 PA 59,630 A Search Code: 8995974 SILVER PASSENGER AIRBAG, DRIVER AIRBAG, POWER LOCK, POWER WINDOW, REAR WINDOW DEFOGGER MANUAL AIR CONDITION, CRUISE CONTROL, TILT STEERING COLUMN, ANTI-LOCK BRAKE SYS. TRACTION CONTROL, FOG LIGHTS, AUXILIARY INPUT, SATELLITE RADIO AUTOMATIC TRANSMISSION, FRONT AIR DAM, TINTED GLASS, VARIABLE ASSISTED STEERING SIDE AIRBAGS, ANTI -THEFT SYSTEM, SIDE HEAD CURTAIN AIRBAGS DAYTIME RUNNING LIGHTS, AM/FM STEREO CD/MP3 PLAYER, ELECTRONIC STABILITY CONTROL FRONT BUCKET SEATS, INTERIOR AIR FILTER, KEYLESS ENTRY SYSTEM, POWER DISC BRAKES POWER HEATED EXTERIOR MIRRORS, POWER LIFTGATEITRUNK STEERING WHEEL MOUNTED CONTROLS Line Entry Labor Item Number Type Operation 1 900500 FRM * ALIGN 2 900500 FRM * REPAIR 3 003176 BDY REMOVE/REPLACE 4 002121 REF 5 002129 BDY 6 002131 BDY BLEND REMOVE/INSTALL REMOVE/INSTALL 7 900500 BDY * REMOVE/INSTALL 8 002145 BDY REMOVE/INSTALL 9 900500 BDY * ADD'L LABOR OP 10 900500 BDY * ADD'L LABOR OP 11 900500 BDY * ADD'L LABOR OP 12 900500 BDY * REMOVE/INSTALL 13 001754 BDY REPAIR Line Item Description Part Type/ Part Number 9/4/2012 10:20 AM 12-3539510-01 0 CPA: All Parts MANUAL ENTRIES TIE DOWN AND MEASURE PULL/ALIGN REAR UNIBODY Exhaust Rear Exhaust Muffler Rear Door R Rear Door Outside R Rear Otr Belt Moulding R Rear Door Moulding MANUAL ENTRIES CLEAN AND RETAPE DOOR MOLDING Rear Door R Rear Otr Door Handle REMOVE STRIPES ON RR DR & RT QTER MANUAL ENTRIES ADHESIVE STRIPES - ONE SIDE R & I DOOR EDGE GUARD (TAPED) CLEAN AND RETAPE DOOR MOLDING Quarter Panel R Quarter Outer Panel ESTIMATE RECALL NUMBER: 09/04/2012 10:20:22 12-3539510-01 Mitchell Data Version: OEM: AUG_12_V0830 MAPP:AUG_12V Software Version: 7.0.480 _ Copyright (C) 1994.2012 Mitchell International All Rights Reserved Existing Existing 28700-3K520 Sublet Existing Sublet Existing Sublet Existing Dollar Labor Amount Units 1.0* 2.0* 492.65 0.7 C 0.9 0.2 # 0.2 2.00 * 0.3* 10.00 * 2.00 * 1.8 # 0.4* 0.3' 0.3* 0.3* 6.0*# Page 1 of 6 14 REF REFINISH 15 16 002472 BOY REMOVE/REPLACE 17 900500 BDY * ADD'L LABOR OP 18 900500 BDY * REMOVE/INSTALL 19 002780 BDY 20 001758 BDY 21 REF REMOVE/INSTALL REPAIR REFINISH/REPAIR 22 003752 BDY REPAIR 23 24 25 26 27 28 29 30 31 32 33 34 REF REFINISH/REPAIR 001931 BDY REF REF 002436 BDY 900500 900500 900500 REF BDY * BDY * BDY REMOVE/REPLACE REFINISH REFINISH REPAIR REFINISH/REPAIR ADD'L LABOR OP ADD'L LABOR OP ADD'L LABOR OP 35 900500 REF * REMOVE/REPLACE 36 900500 BDY * ADD'L LABOR OP 37 900500 BDY * ADD'L LABOR OP 38 39 40 41 42 43 44 45 46 47 48 001959 003838 003839 002738 002173 002175 002176 002177 002178 900500 BOY BDY BDY BDY BDY BDY BDY BDY BDY BDY * 49 003923 REF 50 003924 REF 51 003855 BDY 52 003871 BDY 53 REF 54 003887 BDY 55 936012 REMOVE/INSTALL REMOVERNSTALL REMOVE/INSTALL REMOVE/INSTALL REMOVE/INSTALL REMOVE/INSTALL REMOVE/INSTALL REMOVE/INSTALL REMOVE/INSTALL ALIGN BLEND BLEND OVERHAUL REMOVE/REPLACE REFINISH REMOVE/REPLACE ADD'L COST 56 REF ADD'L OPR 57 ADD'L COST R Quarter Panel Outside AFTER PULL (UPPER/LOWER) R Quarter Stone Shield R & I W/O MLDG MANUAL ENTRIES CLEAN AND RETAPE W/O MOLDING Quarter Panel R Quarter Applique R Quarter Lamp Mount Panel R Quarter Lamp Mount Panel Luggage Lid Luggage Lid Panel BOTTOM HALF ONLY Luggage Lid Panel MODIFIED REFINISH WITH FULL CLEAR COAT Rear Bodv Rear Body Panel Rear Body Panel Add For Edge & Inside Rear Body Floor Pan AFTER PULL Rear Body Floor Pan CORROSION PROTECTION WELD THRU PRIMER CAR COVER MANUAL ENTRIES FLEX ADDITIVE SEAM SEALER UNDERCOATING Rear Bodv Ctr Rear Body Trim Panel R Rear Body Side Trim Panel L Rear Body Side Trim Panel Lwr Rear Body Spare Tire Cover INC SPARE TIRE ASSY Rear Lamps R Rear Otr Combination Lamp R Rear Inr Combination Lamp L Rear Inr Combination Lamp R License Lamp L License Lamp LICENSE PLATE Rear Bumper R Rear Bumper Moulding L Rear Bumper Moulding Rear Bumper Cover Assy Rear Bumper Cover Rear Bumper Cover Rear Bumper Under Cover HAZARDOUS WASTE DISPOSAL ADDITIONAL OPERATIONS Clear Coat Additional Costs & Materials Paint/Materials ESTIMATE RECALL NUMBER: 09/04/2012 10:20:22 12-3539510-01 Mitchell Data Version: OEM: AUG_12_V0830 MAPP:AUG 12_V Software Version: 7.0.480 Date: Estimate ID: Estimate Version: Committed Profile ID: 84221-31(000 Existing Sublet Existing Existing Existing 69100-3K010 Existing Sublet Sublet Sublet Sublet Sublet Sublet Existing Existing Existing Existing Existing ** Non -OEM CAPA 86691-31(001 9/ 4/2012 10:20 AM 12.3539510-01 0 CPA: All Parts C 2.2 22.66 0.2 0.2* 2.00 * 0.2* 0.2 r 1.5*# 0.3* 2.5* # C 1.0* 167.05 9.0 C 1.6 1.0 4.0* # 0.5* 15.00 " 0.2* 8.00 * 0.2* 4.00 * 0.2* 8.00 * 0.0* 32.00 * 0.0* 10.00 " 0.2* INC r 0.3 r 0.3 r 0.3* INC INC # INC # 0.2 # 0.2 # 0.1* C 0.2 C 0.2 0.7 # 242.00 INC # C 2.4 19.60 INC 3.00 * 317.50 " 2.4 Copyright (C) 1994 - 2012 Mitchell International Page 2 of 6 All Rights Reserved Date: Estimate ID: Estimate Version: Committed Profile ID: 9/ 412012 10:20 AM 12-3539510.01 0 CPA: All Parts * - Judgment Item # - Labor Note Applies ** Non -OEM CAPA - Non -Original Equipment Manufacturer Replacement Part, CAPA Certified C - Included in Clear Coat Calc r - CEG R&R Time Used For This Labor Operation KEYSTONE AUTOMOTIVE 3221 ESPRESSO WAY YORK PA 17404 (717) 843-8927 (800) 524-4349 52 " HY1100166C 242.00 Prior Damage: ALL WHEEL COVERS,SCRATCHES ALL OVER ENTIRE CAR,HEADLIGHTS,GRILLE ASSY,HOOD,W/S,ALL DOORS,LF ROCKER & QTERROOF AND TRUNK. SEE PICTURES ALL MANUFACTURERS REQUIREMENTS REGARDING SEATBELT AND SUPPLEMENTAL RESTRAINT SYSTEM REPLACEMENT MUST BE ADHERED TO. IF ADDITIONAL PARTS OR OPERATIONS ARE NECESSARY TO PROPERLY ACCOMPLISH THIS, PLEASE CONTACT THE ESTIMATING CLAIMS REPRESENTATIVE. THIS IS A DAMAGE ASSESSMENT ONLY - NOT AN AUTHORIZATION TO REPAIR -BASED ON DAMAGE VISIBLE OR CERTAIN AT THE TIME IT WAS WRITTEN. IF FRAME OR UNIBODY REPAIR IS INCLUDED ON THIS ESTIMATE, THE AMOUNT SHOWN INCLUDES TIME OR ALLOWANCE FOR MEASURING BEFORE, DURING AND AFTER THOSE REPAIRS. YOU ARE UNDER NO REQUIREMENT TO USE ANY SPECIFIED REPAIR SHOP. INFORMATION REGARDING REPAIR FACILITIES WHICH WILL BE ABLE TO REPAIR THE VEHICLE FOR THE APPRAISED AMOUNT IS AVAILABLE FROM THE INSURANCE COMPANY. TO ENSURE PROPER AND PROMPT PAYMENT FOR ADDITIONAL DAMAGE DISCOVERED DURING THE COURSE OF REPAIRS, CONTACT PROGRESSIVE FOR SUPPLEMENT HANDLING PROCEDURES. ESTIMATE RECALL NUMBER: 09/04/2012 10:20:22 12-3539510-01 Mitchell Data Version: OEM: AUG_12_V0830 MAPP:AUG_12_V Software Version: 7.0.480 — Copyright (C) 1994 - 2012 Mitchell International All Rights Reserved Page 3 of 6 Date: Estimate ID: Estimate Version: Committed Profile ID: Estimate Totals 914/2012 10:20 AM 12-3539510-01 0 CPA: All Parts Add'' Labor Sublet 1. Labor Subtotals Units Rate Amount Amount Totals 11. Part Replacement Summary Body Refinish Frame 31.2 12.7 3.0 46.00 46.00 48.00 Taxable Labor Labor Tax Labor Summary 46.9 III. Additional Costs Taxable Costs Sales Tax 0.00 85.00 0.00 0.00 0.00 0.00 @ 6.000 % 1,520.20 T Taxable Parts 584.20 T Sales Tax 144.00 T 2,248.40 134.90 2,383.30 Amount IV. Adjustments Insurance Deductible @ 6.000% Total Replacement Parts Amount 320.50 @ 6.000% 19.23 Total Additional Costs 339.73 Paint Material Method: Rates !nit Rate = 25.00 Customer Responsibility Total Labor: Total Replacement Parts: Total Additional Costs: Gross Total: IV. Total Adjustments: Net Total: THIS ESTIMATE HAS BEEN PREPARED BASED ON THE USE OF AFTERMARKET CRASH PARTS SUPPLIED BY A SOURCE OTHER THAN THE MANUFACTURER OF YOUR VEHICLE. THE AFTERMARKET CRASH PARTS USED IN THE PREPARATION OF THIS ESTIMATE ARE WARRANTED BY THE MANUFACTURER OR DISTRIBUTOR OF SUCH PARTS, RATHER THAN THE MANUFACTURER OF YOUR MOTOR VEHICLE. Point(s) of Impact 6 Rear Center (P) Insurance Co: PROGRESSIVE INSURANCE Inspection Site: BIKS AUTO COLLISION LLC (Service Center Only) Address: 1101 BERRYHILL ST Harrisburg, PA 17011 (717) 730-1410 (717) 730-1410 Inspection Date: 8/31/2012 ESTIMATE RECALL NUMBER: 09/04/2012 10:20:22 12-3539510-01 Mitchell Data Version: OEM: AUG_12_V0830 MAPP:AUG_12_V Software Version: 7.0.480 Copyright (C) 1994 - 2012 Mitchell International All Rights Reserved Amount 951.96 57.12 1,009.08 Amount 500.00- 500.00- 2,383.30 1,009.08 339.73 3,732.11 500.00- 3,232.11 Page 4 of 6 Date: Estimate ID: Estimate Version: Committed Profile ID: 9/4/2012 10:20 AM 12-3539510-01 0 CPA: All Parts PROGRESSIVE HONORS THE PREVAILING LABOR MARKET RATE IN YOUR AREA FOR YOUR PROPERTY. IF YOU CHOOSE A SHOP THAT CHARGES IN EXCESS OF PREVAILING LABOR MARKET RATES OR ADDITIONAL COSTS ABOVE THE APPRAISED AMOUNT, YOU WILL BE RESPONSIBLE FOR THE DIFFERENCE. LIFETIME GUARANTEE FOR SHEET METAL AND PLASTIC BODY PARTS The replacement parts written on the estimate are intended to return your vehicle to its pre -loss condition with proper installation. After repair, if any sheet metal or plastic body part included in the estimate fails to return your vehicle to its pre -loss condition (assuming proper installation), in terms of form, fit, finish, durability or functionality, Progressive will arrange and pay for the replacement of the part, to the extent not covered by a manufacturer's or other warranty. This service will be performed at no cost to you (including associated repair and rental car costs). To obtain service under this Guarantee, call Progressive at 1-800-274-4641. This Guarantee applies as long as you own or lease the vehicle. This Guarantee is not transferable and terminates if you sell or otherwise transfer your vehicle. THIS GUARANTEE DOES NOT COVER NORMAL WEAR AND TEAR OR DAMAGE CAUSED BY IMPROPER MAINTENANCE, NEGLECT, ABUSE OR SUBSEQUENT ACCIDENT. THIS GUARANTEE IS LIMITED TO ARRANGING FOR THE SELECTION OF REPAIR PARTS THAT WILL RETURN YOUR VEHICLE TO ITS PRE -LOSS CONDITION. ACCORDINGLY, PROGRESSIVE WILL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL OR CONSEQUENTIAL DAMAGES THAT RESULT FROM THE INSTALLATION OR USE OF THESE PARTS. Part Type Terms and Abbreviations NEW and OEM or part number displayed - These refer to a new, original equipment manufacturer part. NON -OEM and A/M and Qual REPL - These refer to an after -market part, which is a new, non -original equipment manufacturer part. USED/RECYCLED and LKQ - These refer to a used OEM part. REMANUFACTURED and RECOND. and RECORE - These refer to used/recycled OEM parts that have been refurbished. BDY=BODY, BDS=BODY STRUCTURE, REF=REFINISH, GLS=GLASS, FRM=FRAME, MCH=MECHANICAL, ADD'L COST=ADDITIONAL COST, ADD'L OPR=ADDITIONAL OPERATION, FRT=FRONT, RR=REAR, L=LEFT, R=RIGHT,UPR=UPPER,LWR=LOWER, OTR=OUTER, INR=INNER, ASSY=ASSEMBLY, SUSP=SUSPENSION, EXT=EXTENSION, BRK=BRACKET, INST=INSTRUMENT, ATG=ASSEMBLY TIME GUIDE. IF THIS APPRAISAL HAS BEEN PREPARED BASED UPON THE USE OF AFTERMARKET CRASH PARTS, AND 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. REPAIR SHOP'S AUTHORIZED REPRESENTATIVE'S SIGNATURE INDICATING AGREEMENT ON COST TO RETURN THE VEHICLE TO PRE -LOSS CONDITION ESTIMATE RECALL NUMBER: 09/04/2012 10:20:22 12-3539510-01 Mitchell Data Version: OEM: AUG_12_V0830 MAPP:AUG_122V Software Version: 7.0.480 Copyright (C) 1994 - 2012 Mitchell International All Rights Reserved Page 5 of 6 Date: Estimate ID: Estimate Version: Committed Profile ID: INCLUDING TOW/STORAGE CHARGES: SHOP SIGNATURE: EST. COMPLETION DATE: 9/ 412012 10:20 AM 12-3539510-01 0 CPA: All Parts ANY PERSON WHO KNOWINGLY AND WITH THE INTENT TO INJURE OR DEFRAUD ANY INSURER FILES AN APPLICATION OR CLAIM CONTAINING ANY FALSE, INCOMPLETE, OR MISLEADING INFORMATION SHALL, UPON CONVICTION, BE SUBJECT TO IMPRISONMENT FOR UP TO SEVEN YEARS AND PAYMENT OF A FINE OF UP TO $15,000. APPRAISER SIGNATURE ESTIMATE RECALL NUMBER: 09/041201210:20:22 12-3539510-01 Mitchell Data Version: OEM: AUG_12_V0830 MAPP:AUG 12 V Software Version: 7.0.480 _ Copyright (C) 1994 - 2012 Mitchell International All Rights Reserved Page 6 of 6 VERIFICATION I, Benjamin W. Lawrence, Esquire, attorney for the Plaintiff(s) do hereby swear and affirm that the averments in the attached Complaint are true and correct to the best of my knowledge, information and/or belief. These averments are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date BenjamiLawrence SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson PLED -OFFICE Sheriff i i .I�w PROTHCNOTr'; Y Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFICE OF THE SHERIFF f114 vlL;l 13 P11 2: 0..2 J CUMBERLAND COUNTY PENNSYLVANIA Progressive Advanced Insurance Company vs. Sarah Wright Case Number 2014-3369 SHERIFF'S RETURN OF SERVICE 06/09/2014 04:08 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Sarah Wright, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Found" at 267 Wycoming Avenue, East Pennsboro, Enola, PA 17025. Deputies were advised by the current tenant that the defendant moved out in October 2012. SHERIFF COST: $49.95 SO ANSWERS, June 10, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuite Sheriff. Teleosoft, Inc. OFP/C of: TOE PROTHON 204 SEP I S 43 CU,kIBERL4NO COTY PEN/iSYLVANIA UN IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE ADVANCED INSURANCE COMPANY Plaintiff vs. SARAH WRIGHT Defendant No. 14-3369 CIVIL PLAINTIFF'S MOTION FOR ALTERNATE SERVICE AND NOW, comes Plaintiff, by counsel, Wellman, Weinberg & Reis Co., L.P.A. and requests this Honorable Court to enter an Order allowing the Plaintiff to make service upon Defendant, SARAH WRIGHT , by first class, United States mail, postage -prepaid and Certified U.S. Mail, addressed to SARAH WRIGHT at 267 WYOMING AVE, ENOLA, PA 17025 averring in support thereof the following: 1. Plaintiff initiated this Civil Action -Complaint against Defendant and attempted service pursuant to Pennsylvania Rules of Civil Procedure 400 and 402; however, the sheriff was unable to successfully effectuate service upon Defendant. 2. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff now moves this Honorable Court for permission to serve Defendant via regular and certified mail. Attached hereto is Plaintiff counsel's affidavit setting forth the nature and extent of the investigation that has been made to deteimine the whereabouts of Defendant. 3. Based on the attached affidavit and supporting documents thereto, it is respectfully requested that Plaintiff's motion be granted and Plaintiff be permitted to serve Defendant via regular and certified mail. WHEREFORE, Plaintiff requests this Honorable Court to enter an Order pursuant to PA.R.C.P. 430(a), authorizing the Plaintiff to serve Defendant by first class, United States mail, postage -prepaid and Certified U.S. Mail sent at 267 WYOMING AVE, ENOLA, PA 17025. Michael J. Dougherty, Esquire PA I.D. 76046 WELTMAN, WEINBERG & REIS CO., L.P.A. 325 Chestnut Street, Suite 501 Philadelphia, PA 19106 WELTMAN, WEINBERG, & REIS, CO. L.P.A. By: Michael J. Dougherty, Esquire I.D. 76046 325 Chestnut Street, Suite 501 Philadelphia, PA 19106-2611 Phone: 215.599.1500 Fax: 215.599.1505 File No. 20281428 Attorney(s) for Plaintiff(s) PROGRESSIVE ADVANCED INSURANCE COMPANY Plaintiff vs. SARAH WRIGHT Defendant Cumberland County Court of Common Pleas No. 14-3369 CIVIL MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION FOR ALTERNATE SERVICE Pennsylvania Rule of Civil Procedure 430 provides: If service cannot be made under the applicable rule the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation that has been made to deteimine the whereabouts of the defendant and the reasons why service cannot be made. Pa.R.Civ.P. 430. An illustration of a good faith effort to locate the defendant includes: 1. Inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265; 2. Inquiries of relatives, neighbors, friends and employers of the defendant; and, 3. Examinations of local telephone directories, voter registration records, local tax records and motor vehicle records. Note to Rule 430. In the present matter, Plaintiff has taken the necessary steps to verify the address of Defendant pursuant to Rule 430. See attached Affidavit. WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant Plaintiff's motion for alternative service. WELTMAN, WEINBERG & REIS CO., L.P.A. By Michael J. Dougherty, Esquire IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE ADVANCED INSURANCE COMPANY Plaintiff vs. SARAH WRIGHT Defendant No. 14-3369 CIVIL AFFIDAVIT PURSUANT TO PA R.C.P. 430 (a) I, Michael J. Dougherty, do hereby swear and affirm that the following averments are true and correct to the best of my knowledge, information, and belief. 1. Pursuant to Pennsylvania Rules of Civil Procedure 400 and 402, Plaintiff attempted to personally serve Defendant with its Civil Action -Complaint but was unsuccessful. See attached as Exhibit 1, a copy of the sheriff's return of service and/or the docket printout evidencing the sheriffs return of service. 2. As a result of the sheriff's unsuccessful attempt at service, Plaintiff requested current address information from the following sources, which request for information, confirmed the current address for Defendant as being 267 WYOMING AVE, ENOLA, PA 17025. a United States Postal Service - Marked as Exhibit "2", and made a part hereof. b. Accurint - Marked as Exhibit "3", and made a part hereof. c. LexisNexis -Marked as Exhibit "4", and made a part hereof. 3. After the foregoing investigation, the plaintiff avers that, the exact whereabouts of the Defendant is 267 WYOMING AVE, ENOLA, PA 17025. These averments are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. WELTMAN, WEINBERG & REIS, CO., L.P.A. Michael J. Dougherty, Esquire EXHIBIT 1 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFFS OFFICE OF CUMBERLAND COUNTY Of C1111141,1 f 0141CF 114E SliERIr-F Progressive Advanced Insurance Company vs. Sarah Wright Case Number 2014-3369 SHERIFF'S RETURN OF SERVICE 06/09/2014 04:08 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Sarah Wright, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Found" at 267 VVycoming Avenue, East Pennsboro, Enola, PA 17025. Deputies were advised by the current tenant that the defendant moved out in October 2012. SHERIFF COST: $49.95 SO ANSWERS, June 10, 2014 BONNY R ANDERSON, SHERIFF (c,1 County -Suite Sharitl, Teteosalt, Inc. EXHIBIT 2 Postmaster ENOLA, PA 17025 Date: June 24, 2014 REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDERIINFORMATION NEEDED FOR SERVICE OF LEGAL PROCESS Please furnish the new address or the name and street address (if a boxholder) for the following: Name: SARAH WRIGHT 267 WYOMING AVE Address: ENOLA, PA 17025 Note: Only one request may be made per completed form. The name and last known address are required for change of address information. The name, if known, and Post Office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265,6(d)(5)(ii). There is no fee for providing boxholder or change of address information. 1. Capacity of requester (e.g., process server, attorney, party representing self): ATTORNEY 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se -except a corporation acting pro se must cite statute): 3. The names of all known parties to the litigation: SARAH WRIGHT, PROGRESSIVE ADVANCED INS 4. The court in which the case has been or will be heard: PROTHONOTARY CUMBERLAND C 5. The docket or other identifying number (a or b must be filled out): X a. Docket or other identifying number: #14-3369 CIVIL b. Docket or other identifying number has not been issued 6. The capacity in which this individual is to be served (e.g., defendant or witness): DEFENDANT WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OR LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE l8 U.S.C. SECTION 1001). I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in conjunction with actual or prospective libation. Signature WELTMAN, WEINBERG & REIS CO., L.P.A. Michael J. Dougherty, Esquire/ PA 1D# 76046 325 Chestnut Street, Suite 501 Attorney Philadelphia, PA 19106 Printed Name WWR File No. 20281428 User: KMH No change of address order on file:. _ Moved, left no forwarding address: No such address: 0,061 41=O2 CSE, 690/19000147 FOR POST OFFICE USE ONLY NEW ADDRESS OR BOXHOLDER'S NAME POSTMARK AND STREET ADDRESS EXHIBIT 3 Page 1 of 1 Name(s) - SARAH A WRIGHT SARAH WRIGHT Gender - Female 267 WYOMING AVE ENOLA, PA 17025-2433 Dates - Oct 2009 - Jun 2014 7 W BEALE AVE ENOLA, PA 17025-2806 Dates - Apr 2010 - May 2014 SSN(s) - xxx-xx LexID - 148813319445 DOB/Age - https://secure.accurint.com/app/bps/main 7/23/2014 EXHIIT 4 Page 1 Search: Terms: No., Full Name Public Records : Locate a Person (Nationwide) first-name(SARAH) Jast-name(WRIGHT) street address(267 WYOMING AVE) city(ENOLA) state(PA) radius(30) WRIGHT, SARAH A WRIGHT, SARAH t(Ander. Female) Search: Terms: Date/Time: Permissible Use: Address/Phone SSN 267 WYOMING AVE ENOLA, PA 17025-2433 CUMBERLAND COUNTY (10/2009 -Current) 7 W BEALE AVE ENOLA, PA 17025-2806 CUMBERLAND COUNTY (04/2010-05/2014) • (PA:1e92-1994) LextD(sm):148813319445 Public Records : Locate a Person (Nationwide) first-name(SARAH) last-name(WRIGHT) street address(267 WYOMING AVE) city(ENOLA) state(PA) radius(30) Wednesday, July 23, 2014 2:36 PM DPPA - Debt Recovery/Fraud GLBA - Legal Compliance Copyright © 2014 LexisNexis, a division of Reed Elsevier Inc. All Rights Reserved. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL DIVISION PROGRESSIVE ADVANCED INSURANCE COMPANY Plaintiff No. 14-3369 CIVIL vs. SARAH WRIGHT Defendant VERIFICATION I, Michael J. Dougherty, Esquire, attorney for the Plaintiff(s) do hereby swear and affirm that the averments in the attached Motion for Alternative Service are true and correct to the best of my knowledge, information and/or belief. These averments are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Michael J. Dougherty, Esquire Attorney for Plaintiff CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of the within Motion for Alternate Service was served on they day of p1ZWA1iLQ,r; 2014, by first class, U.S. Mail, postage -prepaid, addressed as follows: SARAH WRIGHT 267 WYOMING AVE ENOLA, PA17025 Attorney for Plaintiff PROGRESSIVE ADVANCED : IN THE COURT OF COMMON PLEAS OF INSURANCE COMPANY : CUMBERLAND COUNTY, PENNSYLVANIA V. SARAH WRIGHT : NO. 2014 — 3369 CIVIL TERM : CIVIL ACTION — LAW ED-OF:71C" ri PROF[4.0NQ SEP 24 PH 3: 1 3 CUMBERLAND COUNTY PENNSYLVANIA ORDER OF COURT AND NOW, this 22" day of SEPTEMBER, 2014, upon consideration of the foregoing Motion for Service of the Complaint Pursuant to Special Order of Court and attached supporting affidavit, it is hereby ORDERED, ADJUDGED AND DECREED that the service of the complaint in Civil Action may be made on Defendant SARAH WRIGHT, by publication and by permitting the Plaintiff to mail a copy of the Complaint to the Defendant at the last known addresses being 267 WYOMING AVENUE, ENOLA, PA 17025 AND 7 WEST BEALE AVENUE, ENOLA, PA 17025 by first class, United States mail, postage -prepaid and Certified U.S. Mail. Service to be completed upon mailing and publication in accordance with the Rules of Civil Proceeding. Edward E. Guido, J. ec- Pat' LEL R4I7 a .-3G4.0.41dy -C\-aiza141‘6- glIc WELTMAN, WEINBERG & REIS CO., L.P.A. BY: Benjamin W. Lawrence, Esquire ID. No.209032 325 Chestnut Street, Suite 501 Philadelphia, PA 19106 Phone: 215.599.1500 Fax: 215.599.1505 File # 20281428 Attorney for Plaintiff(s) PROGRESSIVE ADVANCED INSURANCE COMPANY Cumberland County Court of Common Pleas vs. SARAH WRIGHT NO. 14-3369 CIVIL PRAECIPE TO REINSTATE TO THE PROTHONOTARY: Kindly reinstate the Complaint in Civil Action in the above -captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By Be 'n W. Lawrence, Esquire Attorney for Plaintiff 3- 1/4.0 Crr C.J1 cum+ WELTMAN, WEINBERG & REIS CO., L.P.A. BY: Michael J. Dougherty, Esquire I.D. No. 76046 325 Chestnut Street, Suite 501 Philadelphia, PA 19106 Phone: 215.599.1500 Fax: 215.599.1505 File # 20281428 Attorney for Plaintiff(s) PROGRESSIVE ADVABCED INSURANCE COMPANY vs. SARAH WRIGHT TO THE PROTHONOTARY: tr) in i C c3'1 1: C) C.. CD CUMBERLAND County Court of Common Pleas No.: 14-3369 CIVIL CERTIFICATE OF SERVICE On November 25, 2014 Plaintiff served?its Reinstated Complaint in Civil Action upon Defendant, Sarah Wright at 267 Wyoming Avenue, Enola, PA 17025 and 7 West Beale Avenue, Enloa, PA 17025 by certified mail, return receipt requested and first class, United States mail, postage -prepaid. WELTMAN, WEINBE3 & REIS CO., L.P.A. By Michael J. Dougherty, Esquire Attorney for Plaintiff WELTMAN, WEINBERG & REIS CO., L.P.A. BY: Michael J. Dougherty, Esquire I.D. No. 76046 325 Chestnut Street, Suite 501 Philadelphia, PA 19106 Phone: 215.599.1500 Fax: 215.599.1505 File # 20281428 r!'1r Attorney for Plaintiff(s) PROGRESSIVE ADVANCED CUMBERLAND COUNTY INSURANCE COMPANY COURT OF COMMON PLEAS v. No.: 14-3369 CIVIL SARAH WRIGHT CERTIFICATE OF SERVICE TO THE PROTHONOTARY: Pursuant to Court Order dated September 22, 2014, Plaintiff posted its Notice to Defend via publication in The Cumberland Law Journal on December 12, 2014. WELTMAN, WEINBERG & REIS CO., L.P.A. By Michael J. Doug rty, Esquire Attorney for Plaintiff PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA . ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz December 12, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 12 day of December, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO., CUMBERLAND CNTY My Commission Expires Apr 28. 2018 CUMBERLAND LAW JOURNAL SERVICE BY PUBLICATION In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Division NO. 14-3369 CIVIL PROGRESSIVE ADVANCED INSURANCE COMPANY, 5920 LANDERBROOK DR., MAYFIELD HEIGHTS, OH 44124 Plaintiff v. SARAH WRIGHT, 267 WYOMING AVE., ENOLA, PA 17025 Defendant NOTICE OF CIVIL ACTION COMPLAINT IN CIVIL ACTION NOTICE TO: Sarah Wright, 267 Wyo- ming Ave., Enola, PA 17025 YOU HAVE BEEN SUED IN COURT. NOTICE IS HEREBY GIVEN that Progressive Advanced Insur- ance Company filed a Complaint in Civil Action against you in the Court of Common Pleas of Cumberland County, Pennsylvania, Case No. 14-3369 Civil. If you wish to defend, you must enter awritten appearance personally or by attorney and file your defenses or objections in writ- ing with the court. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you without further notice for the relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH 8 INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A RE- DUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Further inquiry can be directed to counsel for Plaintiff as follows: MICHAEL J. DOUGHERTY, ESQUIRE PA ID No. 76046 WELTMAN, WEINBERG & REIS CO., L.P.A. 325 Chestnut Street Suite 501 Philadelphia, PA 19106 Tel. (215) 599-1500 Dec. 12 LB -OFF -ICE v F THE PROTHONOTARY D 2g1ti DEC 24 PM; .1: 01 P20 CUMBERLAND COUNTY JENNIFER L. STRINE, p E N N S y LVp, N I A : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION — LAW DUSTIN M. STRINE, : NO. 2014-4136 CIVIL TERM Defendant : 1N DIVORCE PETITION FOR ALIMONY PENDENTE LITE AND NOW comes Petitioner, Jennifer L. Strine, by and through her counsel of record, Hannah Herman -Snyder, Esquire, and petitions the Court as follows: 1. Your Petitioner is the above-named Plaintiff, Jennifer L. Strine, an adult individual currently residing at 40 Marilyn Drive, Carlisle, Cumberland County, Pennsylvania. 2. Your Respondent is the above-named Defendant, Dustin M. Strine, an adult individual currently residing at 254 G Street, Carlisle, Cumberland County, Pennsylvania. 3. The divorce action filed to the above docketed number in the Court of Common Pleas of Cumberland County requests a divorce based upon Section 3301(c) of the Divorce Code of 1980 as amended. 4. Petitioner filed a Petition for Economic Relief, including a request for alimony pendente lite, simultaneously with the filing of this Petition. 5. Petitioner has employed counsel and incurred certain costs and expenses in pursuit of the aforementioned divorce action, but is without sufficient assets or income to support herself, pay for the attorney's fees, and pay for the costs and expenses associated with this action. 6. Respondent has sufficient income, as well as assets, to support Petitioner, or to assist in supporting Petitioner, and to pay alimony pendente lite to Petitioner. WHEREFORE, Petitioner requests your Honorable Court to enter an Order requiring Respondent to pay alimony pendente lite to Petitioner. Respectfully submitted, Hannah Herman -Snyder, Esquike Attorney for Plaintiff Supreme Court ID No. 91537 GRIFFIE & ASSOCIATES, P.C. 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 VERIFICATION I verify that the statements made in the foregoing document are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: JENNIFER . STRINE, Plaintiff JENNIFER L. STRINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION -LAW DUSTIN M. STRINE, : NO. 2014-4136 CIVIL TERM Defendant : 1N DIVORCE CERTIFICATE OF SERVICE I, Hannah Herman -Snyder, Esquire hereby certify that I did, the „4,94-- day of December, 2014, cause a copy of Petitioner's Petition for Alimony Pendente Lite to be served upon the Respondent, Dustin M. Strine, by serving his counsel of record, Hubert X. Gilroy, Esquire, by first class mail, postage prepaid, at the following address: DATE: ► 3.:-a Lt - i 4 Hubert X. Gilroy, Esquire Martson Law Offices 10 East High Street Carlisle, PA 17013 d Hannah Herman -Snyder, Esqui4e Attorney for Plaintiff Supreme Court ID No. 91537 GRIFFIE & ASSOCIATES, P.C. 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 JENNIFER L. STRINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION—LAW : NO. 2014-4136 CIVIL TERM v. DUSTIN M. STRINE, Defendant : IN DIVORCE DRS Attachment for APL Proceedings PETITIONER NAME: Jennifer L. Strine ADDRESS: 40 Marilyn Drive, Carlisle, Pennsylvania, 17013 BIRTH DATE: June 25, 1972 SOCIAL SECURITY NUMBER: 187-60-6341 HOME PHONE: 422-5725 WORK PHONE: 226-8202 (cell) EMPLOYER NAME: Carlisle Area School District EMPLOYER ADDRESS: 623 West Penn St., Carlisle, PA 17013 JOB TITLE/POSITION: Personal Care Aide GROSS PAY: $1,319.56/month (as per Order of November 26, 2014 — PACSES Case Number 001114984) NET PAY: $1,065.03/month (as per Order of November 26, 2014 — PACSES Case Number 001114984) OTHER INCOME: None ATTORNEY'S NAME: Hannah Herman -Snyder, Esquire ATTORNEY'S ADDRESS: Griffie & Associates, P.C., 200 North Hanover Street, Carlisle, PA 17013 ATTORNEY'S PHONE NUMBER: (717) 243-5551 RESPONDENT NAME: Dustin Strine ADDRESS: 25 G Street, Carlisle, PA 17013 BIRTH DATE: October 9, 1973 SOCIAL SECURITY NUMBER: 204-58-7754 HOME PHONE: (717) 422-5725 EMPLOYER NAME: Lift, Inc. EMPLOYER ADDRESS: 3745 Hempland Road, Mountville, PA 17554 JOB TITLE/POSITION: Forklift Mechanic DATE EMPLOYMENT COMMENCED: February 2010 GROSS PAY: $23.75/hour NET PAY: OTHER INCOME: V/A Disability ($1,281.00/month) ATTORNEY'S NAME: Hubert X. Gilroy, Esquire ATTORNEY'S ADDRESS: Martson Law Offices, 10 East High St., Carlisle, PA, 17013 ATTORNEY'S PHONE NUMBER: (717) 243-1850 MARRIAGE INFORMATION DATE OF MARRIAGE: March 17, 1994 PLACE OF MARRIAGE: Okaloosa County, Florida DATE OF SEPARATION: July 2014 ADDRESS OF LAST MARITAL HOME: 254 G Street, Carlisle, PA, 17013 DESCRIPTION OF DOCUMENT RAISING APL CLAIM: Petition for Economic Relief DATE APL FILED: December 24, 2014