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HomeMy WebLinkAbout14-3459 Supreme Coo ennsylvania s�� COU P_ O,nl IIl40 leas For Prothonotary Use Only: Cil Okver Sheet �tTF '_ � a Docket No: STl t CU . -NIS- County 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 bylaw or rules of court. Commencement of Action: S 0 Complaint ® Writ of Summons [3 Petition E Transfer from Another Jurisdiction ® Declaration of Taking C Lead Plaintiff s Name: Lead Defendant's Name: ERIE INSURANCE EXCHANGE LAMONT B. HOLLINGWORTH Dollar Amount Requested: El within arbitration limits I Are money damages requested? 10 Yes © No (check one) Eloutside arbitration limits U N Is this a Class Action Suit? [3 Yes EI No Is this an MDJAppeal? 0 Yes El 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 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) CONTRACT (do not include Judgments) CIVIL APPEALS ® Intentional [I Buyer Plaintiff Administrative Agencies [3 Malicious Prosecution El Debt Collection:Credit Card ® Board of Assessment 0 Motor Vehicle ® Debt Collection:Other ® Board of Elections ® Nuisance Dept.of Transportation ® Premises Liability U Statutory Appeal:Other S Product Liability(does not include E mass tort) ® Employment Dispute: Slander/Libel/Defamation Discrimination l] C [ Other: ® Employment Dispute:Other Zoning Board T ® Other: I 0 Other: O MASS TORT ® Asbestos N © Tobacco ® Toxic Tort-DES ® Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS Toxic Waste ®i Other: ® Ejectment ® Common Law/Statutory Arbitration B l3 Eminent Domain/Condemnation ® Declaratory Judgment 0 Ground Rent Mandamus [I Landlord/Tenant Dispute ®Non-Domestic Relations Ll Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABILITY 8 Mortgage Foreclosure:Commercial 0 Quo Warranto l3 Dental ® Partition 13 Replevin ® Legal ® Quiet Title ®Other: Medical l3 Other: ® Other Professional: Updated 1/1/2011 PAUL F. D'EMILIO, ESQUIRE THIS IS AN ARBITRATION MATTER ATTORNEY I.D. #16654 OUR FILE NO.: WILBE-2014-082 PAUL M. SCHOFIELD, JR., ESQUIRE ATTORNEY I.D. #81894 905 W. SPROUL ROAD, SUITE 105 ATTORNEY FOR PLAINTIFF SPRINGFIELD, PA 19064 (610) 338-0338 ERIE INSURANCE EXCHANGE COMMON PLEAS COURT OF / AS SUBROGEE OF SARA L. WHEELER CUMBERLAND COUNTY 136 JAYCEE DRIVE, SUITE 40 / JOHNSTOWN, PA 15904 2 VS. LAMONT B. HOLLINGSWORTH �- %'�_ 513 SENECA STREET 4 HARRISBURG, PA 17110 r AND SCD HATA HRNJIC < 5 SUSSEX DRIVE CIVIL ACTION CARLISLE, PA 17013 NOTICE AVISO YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND Le han demandado a usted en la corte. Si usted quiere defenderse AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, de estas demandas expuestas en las paginas siguientes,usted tiene YOU MUST TAKE ACTION WITHIN TWENTY(20)DAYS AFTER (20)dias de plazo a partir de la fecha de la demanda y la notificacion. THIS COMPLAINT AND NOTICE ARE SERVED,BY ENTERING A Usted debe presentar una apariencia escrita o en persona o por WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND abogado y archivar en la corte sus defensas o sus objeciones a las FILING IN WRITING WITH THE COURT YOUR DEFENSES OR demandas encontra de su persona. Sea avisado que si usted no se OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU defiende,la corte tomara medidas y puede entrar una orden contra ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY usted sin previo aviso o notificacion o por cualgier queja o alivio que PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED espedido en la peticion de demanda. Usted puede perder dinero,sus AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE propiedades o otros derechos importantes para usted. FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE IMPORTANT TO YOU. PARA PAGAR TAL SERVICIO,VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. ESCRITA ABAJO PARA AVERIGUAR DONDE LISTED PUEDE IF YOU DO NOT HAVE A LAWYER„GO TO OR TELEPHONE THE CONSEGUIR ASISTENCIA LEGAL. 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 Cumberland County Bar Association MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT 32 Bedford Street AGENCIES THAT MAY LEGAL PERSONS AT A REDUCOED FFER FEE OR NO FEEICES TO ELIGIBLE Carlisle, PA 17013 (717) 249-3166 Cumberland County Bar Association (800) 990-9108 32 Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 ' ( wL� u1b,?'IST4 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 ATTORNEY FOR PLAINTIFF SPRINGFIELD, PA 19064 (610) 338-0338 ERIE INSURANCE EXCHANGE COMMON PLEAS COURT OF AS SUBROGEE OF SARA L. WHEELER CUMBERLAND COUNTY 136 JAYCEE DRIVE, SUITE 40 JOHNSTOWN, PA 15904 NO. VS. LAMONT B. HOLLINGSWORTH 513 SENECA STREET HARRISBURG, PA 17110 AND HATA HRNJIC 5 SUSSEX DRIVE CIVIL ACTION CARLISLE, PA 17013 NOTICE UNDER THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §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. COMPLAINT The Plaintiff, Erie Insurance Exchange, by its attorney Paul F. D'Emilio, Esquire, bring this action upon a cause whereof the following is a statement: 1. The Plaintiff, Erie Insurance Exchange ("Plaintiff'), is a Corporation authorized to do business in the Commonwealth of Pennsylvania, having an address of 136 Jaycee Drive, Suite 40, Johnstown, PA 19504. Plaintiff brings this action as subrogee of Sara L. Wheeler, ("Insured") under a. policy of insurance issued by Plaintiff. 2. Defendant, Lamont B. Hollingsworth is an individual residing at 513 Seneca Street, Harrisburg, PA 17110. 3. Defendant, Hata Hrnjic, is an individual residing at 5 Sussex Drive, Carlisle, PA 17013. 4. At all times hereinafter mentioned the Defendant Lamont B. Hollingsworth was the agent, workman, servant and employee of Defendant Hata Hrnjic and was engaged in the business of Defendant Hata Hrnjic and was acting within the course and scope of her employment. 5. On or about July 24, 2012, a motor vehicle owned by the Defendant Hata Hrnjic by the Defendant Lamont B. Hollingsworth, was traveling west on County Road T000 at or near the intersection of Valley Street, South Middleton Township, Cumberland County, Pennsylvania when he rear-ended Plaintiff's Insured's vehicles causing the damages hereinafter set forth. 6. As a result of the injuries to Plaintiff's Insured and Defendant's failure to maintain financial responsibility as required by law, Plaintiff has been obligated to pay to the Insured a sum of Twelve Thousand Five Hundred and 00/100 ($12,500.00) Dollars pursuant to the uninsured motorist's provisions of the insurance policy. 7. The Insured's vehicle was a total loss and Defendant is liable to Plaintiff'for the damages as allowed by law thereto being is Five Thousand Six Hundred Ninety Six and 46/100 ($5,696.46) Dollars plus the cost of a rental vehicle being Seven Hundred Sixteen and 40/100 ($716.40) Dollars for a total of Six Thousand Four Hundred Twelve and 86/100 ($6,412.86) Dollars. Count I Erie Insurance Exchange v. Lamont B. Hollingsworth 8. Plaintiff, Erie Insurance Exchange incorporates by reference all of the allegations contained in paragraphs 1 through 7 inclusive of this Complaint as fully as though same were herein and set forth at length. 9. The said occurrence was due to the negligence of the Defendant, Lamont B. Hollingsworth in 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 regard 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 Delaware and Section 3714 of the Motor Vehicle Code, pertaining to the operation of motor vehicles. Count II Erie Insurance Exchange v. Hata Hrnjic 10. Plaintiff, Erie Insurance Exchange, incorporates by reference all of the allegations contained in paragraphs 1 through 9 inclusive of this Complaint as fully as though same were herein and set forth at length. 11. The said occurrence was do to the negligence of the Defendant Hata Hrnjic, in that he/she: a. negligently entrusted his/her vehicle to another operator for use when he/she 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/her motor vehicle to a person which he/she knew, or in the exercise of reasonable care should have known, was an incompetent driver; C. negligently entrusted his/her motor vehicle to a person which he/she knew, 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, and d. negligently entrusted his/her motor vehicle to another person who he/she knew, should have known or in the exercise of due care would have known would cause damages to another; and e. negligently entrust his/her 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 Defendants upon each count in an amount not in excess of Fifty Thousand and 00/100 ($50,000.00) dollars together with costs of suit. June 5, 2014 Paul . D'Emili s re Ide tification o.: 16654 e ail address: pauld@demiliolaw.com auI 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 VERIFICATION I, Paul M. Schofield, Jr., Esquire, certify that I am the attorney for the Plaintiff in this matter and certify and do verify that the statements made in the foregoing pleading or document or response are true and correct to the best of my knowledge, information and belief. I further understand that false statements therein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. A representative for the Plaintiff was unavailable in this jurisdiction to execute this verification within the time required by the rules of civil proced A substituted verification will be filed as soon as it arrives in Plaintiff's Cou s s office. Date: June 5, 2014 Pa6ul F. 'Emilio, Esquire dentification No.: 16654 e-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 - - SHERIFF'S OFFICE OF CUMBERLAND COUNTY - - Ronny RAnders �on Sheriff L� �\i� 'nv JodyS5mith Chief Deputy �". . Richard W Stewart Solicitor OFFICE OpTJK.��smIFp ~- Lvr^```' Erie Insurance Exchange assubrogee ofSara LWheeler Case Number vs. | 2014'3459 Hata Hnjic(et ai) | SHERIFF'S RETURN OF SERVICE 06/10/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Lamont B Hollingsworth, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Complaint QNotice according tolaw. 06/10/2014 OS,16PK8-Deputy Christopher Sharpe, being duly sworn according bzlaw, served the requested complaint&Notice by handing atrue copy to a person representing themselves to be LUod Jrrjic. Fother, who accepted as"Adult Person in Charge"for Hata Hrniioat6 Sussex Drive, Cad/o|o Bnnough, Cad(s|e, PA 17013. CMIST 06/20/2014 The requested Complaint& Notice returned by the Sheriff of Dauphin County, the within named Defendant Lamont B Hollingsworth, not found. Jack Lotwick, Sheriff, Return of Service attached to and made part ofthe within record. SHERIFF COST: $6378 SO ANSWERS, June 20, 2014 xuwm, R*muEuSum. SHERIFF Ic)CoumySuiwe����,Mr. s o ` Shelley Ruhl Jack Duignan Real Estale Deputy Chief Deputy Matthew L. Owens Michael W. Rinehart Solicitor Assistant Chief Deputy Dauphin County 101 Market Street Harrisburg,Pennsylvania 17101-2079 ph:(717)780-6590 fax:(717)255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania ERIE INSURANCE EXCHANGE A/S/O SARA L. WHEELER VS County of Dauphin LAMONT B. HOLLINGSWORTH Sheriff s Return No. 2014-T-1773 OTHER COUNTY NO. 2014-3459 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for LAMONT B. HOLLINGSWORTH the DEFENDANT named in the within NOTICE& COMPLAINT and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, JUNE 17, 2014. 6/13%14 09:00 -PROPERTY AT ADDRESS 513 SENECA STREET, HARRISBRUG, PA 17110 IS VACANT. POSSIBLE ADDRESS PER JNET IS 1442 MARKET STREET, HARRISBURG, PA 17103. SENT BACK OUT W/DEPUTIES 6/17/14 13:30 -PER RESIDENT OF ADDRESS 1442 MARKET STREET, HARRISBURG, PA 17103, THE DEFENDANT DOES NOT RESIDE THERE. Sworn and subscribed to So Answers, ! before me this 19TH day of June, 2014 1� Sheriff ofuphin C , Pa. Nt1 By COMMONWEALTH OF PENNSYLVANIA Dep heriff NOTARIAL.SEAL De : J FRUHWIRTH Karen M.Hoffman,Notary Public Sheriff s Costs: $47.25 6/12/20.14 City of Harrisburg,Dauphin County My Commission Expires January 8,2018 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 ERIE INSURANCE EXCHANGE AS SUBROGEE OF SARA L. WHEELER 136 JAYCEE DRIVE, SUITE 40 JOHNSTOWN, PA 15904 VS. LAMONT B. HOLLINGSWORTH 513 SENECA STREET HARRISBURG, PA 17110 AND HATA HRNJIC 5 SUSSEX DRIVE CARLISLE, PA 17013 1Ct 0 NOTARY 20'JUL 21 AN 10: CUMBERLAND COUNTY PENNSYLVANIA COMMON PLEAS COURT OF CUMBERLAND COUNTY NO. 14-3459 CIVIL ACTION PRAECIPE FOR JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY, C.P.: Enter Judgment in the above entitled matter in favor of the Plaintiff, Erie Insurance Exchange as subrogee of Sara L. Wheeler and against the Defendant Hata Hrnjic, for want of an answer, and assess Plaintiff's damages in the sum of $18,912.86 in accordance with a Complaint filed. Prothy ass- damag PRO L F. TORN ATTOR , ESQUIRE R PLAINTIFF Y I.D. #16654 the sum of $18,912.86 2.42os-ri? \\)bh.c.0 hiC;Aded 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 ERIE INSURANCE EXCHANGE AS SUBROGEE OF SARA L. WHEELER 136 JAYCEE DRIVE, SUITE 40 JOHNSTOWN, PA 15904 VS. LAMONT B. HOLLINGSWORTH 513 SENECA STREET HARRISBURG, PA 17110 AND HATA HRNJIC 5 SUSSEX DRIVE CARLISLE, PA 17013 COMMON PLEAS COURT OF CUMBERLAND COUNTY NO. 14-3459 CIVIL ACTION 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 Hata Hrnjic, 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. /, P A rL F. D'EMILIO, ESQUIRE A ' ORNEY FOR PLAINTIFF PAUL F. D'EMILIO, ESQUIRE ATTORNEY I.D. #16654 PAUL M. SCHOFIELD, JR, ESQUIRE ATTORNEY LD. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 ERIE INSURANCE EXCHANGE COMMON PLEAS COURT OF AS SUBROGEE OF SARA L. WHEELER CUMBERLAND COUNTY 136 JAYCEE DRIVE, SUITE 40 JOHNSTOWN, PA 15904 VS. LAMONT B. HOLLINGSWORTH 513 SENECA STREET HARRISBURG, PA 17110 AND HATA HRNJIC 5 SUSSEX DRIVE CARLISLE, PA 17013 NO. 14-3459 CIVIL ACTION AFFIDAVIT OF NOTICE OF INTENT TO ENTER DEFAULT JUDGMENT I, PAUL F. D'EMILIO, ESQUIRE, attorney for the Plaintiff, Erie Insurance Exchange as subrogee of Sara L. Wheeler, does hereby certify that a Notice of Intent to Enter Default Judgment was mailed on July 3, 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". HATA HRNJIC 5 SUSSEX DRIVE CARLISLE PA 17013 AUL F. D'EMILIO, ESQUIRE TTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF Cumberland County, PENNSYLVANIA CIVIL ACTION- LAW (Rule of Civil Procedure No. 236) ERIE INSURANCE EXCHANGE AS SUBROGEE OF SARA L. WHEELER 136 JAYCEE DRIVE, SUITE 40 JOHNSTOWN, PA 15904 VS. LAMONT B. HOLLINGSWORTH 513 SENECA STREET HARRISBURG, PA 17110 AND HATA HRNJIC 5 SUSSEX DRIVE CARLISLE, PA 17013 COMMON PLEAS COURT OF CUMBERLAND COUNTY NO. 14-3459 CIVIL ACTION Notice is given that a judgment in the above captior d matter has been entered against you on 2014. Prothonota 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 I.D. #81894 905 W. SPROUL ROAD, SUITE 105 SPRINGFIELD, PA 19064 (610) 338-0338 ERIE INSURANCE EXCHANGE AS SUBROGEE OF SARA L. WHEELER 136 JAYCEE DRIVE, SUITE 40 JOHNSTOWN, PA 15904 VS. LAMONT B. HOLLINGSWORTH 513 SENECA STREET HARRISBURG, PA 17110 AND HATA HRNJIC 5 SUSSEX DRIVE CARLISLE, PA 17013 COMMON PLEAS COURT OF CUMBERLAND COUNTY NO. 14-3459 CIVIL ACTION CERTIFICATION AS TO ADDRESS OF DEFENDANT I hereby certify the address of Defendant is as follows: HATA HRNJIC 5 SUSSEX DRIVE CARLISLE PA 17013 F riPTILIO, ESQUIRE A ORNEY 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 ERIE INSURANCE EXCHANGE AS SUBROGEE OF SARA L. WHEELER 136 JAYCEE DRIVE, SUITE 40 JOHNSTOWN, PA 15904 VS. LAMONT B. HOLLINGSWORTH 513 SENECA STREET HARRISBURG, PA 17110 AND HATA HRNJIC 5 SUSSEX DRIVE CARLISLE, PA 17013 COMMON PLEAS COURT OF CUMBERLAND COUNTY NO. 14-3459 CIVIL ACTION CERTIFICATION AS TO ADDRESS OF PLAINTIFF I hereby certify the address of Plaintiff, Erie Insurance Exchange as subrogee of Sara L. Wheeler is as follows: 136 Jaycee Dr Ste 40 Johnstown PA 15904 PA A . D'EMILIO, ESQUIRE ORNEY FOR PLAINTIFF 7. 8. Name and Address of Sender •1, ; Tote' Number Listed by Se r Article Number is Form 3877 -Fe rua 2002 (Page Of 2) Check type of Mail or service: 0 0 Certified 0 (Delivery Confirmation COD r_0 L.7 Recorded Delivery (International) Registered kt 0 Express Mall 0 Return Receipt for 0 Ire nsud 0 Signature Confirma - Addressee (41rne, Street, 6,, State, ig ZIP Cafe) ,A.16-rldo yr F c,k i -r-t) f9A / 1 e 7- / 5 i7-17 4-1)- fi041° ( r of Pieces ost Office -.Se tion Postage r Affix (IfStamp Here issued as a certificate of rnalOng, Or for additional copies of this bill) Postmark and Date of Reoei. Fee Handling Charge et a Ili& 44 3 Complete b pewriter, Ink, or Ball Point Pen See Privacy Act Statement on Reverse 1l -r 4-6 ,C11 c K 9 reAnd hp 4 „Li / T A5df; rd I z- ,111111p - e of receivin employee) tqr 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 ERIE INSURANCE EXCHANGE AS SUBROGEE OF SARA L. WHEELER 136 JAYCEE DRIVE, SUITE 40 JOHNSTOWN, PA 15904 VS. LAMONT B. HOLLINGSWORTH 513 SENECA STREET HARRISBURG, PA 17110 AND HATA HRNJIC 5 SUSSEX DRIVE CARLISLE, PA 17013 COMMON PLEAS COURT OF CUMBERLAND COUNTY NO. 14-3459 CIVIL ACTION DATE OF NOTICE: July 3, 2014 TO: HATA HRNJIC 5 SUSSEX DRIVE CARLISLE PA 17013 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 Paul 7. � PAUL F. D'EMILIO, ESQUIRE 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 ERIE INSURANCE EXCHANGE AS SUBROGEE OF SARA L. WHEELER 136 JAYCEE DRIVE, SUITE 40 JOHNSTOWN, PA 15904 VS. LAMONT B. HOLLINGSWORTH 513 SENECA STREET HARRISBURG, PA 17110 AND HATA HRNJIC 5 SUSSEX DRIVE CARLISLE, PA 17013 THIS IS AN ARBITRATION MATTER ATTORNEY FOR PLAINTIFF COMMON PLEAS COURT OF CUMBERLAND COUNTY NO. 14-3459 Civil CIVIL ACTION •-‹ PRAECIPE TO REINSTATE THE COMPLAINT TO THE PROTHONOTARY, C.P.: Kindly reinstate the Complaint in the above -captioned matter. PAUL F. D'EMILIO, ESQUIRE ATTORNEY FOR PLAINTIFF II /15 pi A11 -I C40484(4 p,* tOgOqg Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY r 1LEfD-U f I[;;:_ OF THE PROTHDNDT=:f:` 2014 AUG 22 PM 3: 10 CO PENN YLVAN ARTY Erie Insurance Exchange as subrogee of Sara L. Wheeler vs. Lamont B Hollingsworth (et al.) Case Number 2014-3459 SHERIFF'S RETURN OF SERVICE 07/28/2014 Sheriff Ronny R Anderson, being dully sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Lamont B Hollingsworth, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Lancaster, Pennsylvania to serve the within Complaint & Notice according to law. 08/15/2014 02:27 PM - The requested Complaint & Notice returned by the Sheriff of Lancaster County, the within named Defendant Lamont B Hollingsworth, not found. Timothy Stauffer, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $37.00 SO ANSWERS, August 15, 2014 RONNTY R ANDERSON, SHERIFF i,c) CountySuite Shonlf, Teleosofi, Inc. Mark S. Reese Sheriff SHERIFF'S OFFICE OF LANCASTER COUNTY r Brad Harris Solicitor Marc Lancaster "-,; Charles Hamilton Chief Deputy Lieutenant ERIE INSURANCE EXCHANGE vs. LAMONT B HOLLINGSWORTH Case Number 2014-3459 SHERIFF'S RETURN OF SERVICE 08/01/2014 02:27 PM - I, 'DEPUTY TIMOTHY STAUFFER, BEING DULY SWORN ACCORDING TO LAW, STATES I MADE DILIGENT SEARCH AND INQUIRY FOR THE WITHIN NAMED DEFENDANT TO WIT: LAMONT B HOLLINGSWORTH, BUT WAS UNABLE TO LOCATE THE DEFENDANT. THE SHERIFF THEREFORE RETURNS THE WITHIN REQUESTED COMPLAINT & NOTICE AS ''NOT FOUND" AT 640 EMERALD DRIVE, LANCASTER, PA 17603. CHECKED RESIDENCE, CURRENT TENANT (DENZEL ROSS) RELATES HE DOESN'T KNOW THE DEFENDANT AND THAT THEY MUST HAVE BEEN THE PREVIOUS TENANT. TIMOTHY STAUFFER, DEPUTY SHERIFF COST: $44.30 SO ANSWERS, August 14, 2014 MARK S. REESE, SHERIFF COSTS DATE CATEGORY MEMO CHK # DEBIT CREDIT 07/29/2014 Advance Fee 07/29/2014 Receiving, Docketing & Return 07/29/2014 Service 07/29/2014 Affidavit 07/29/2014 Deputy Time 07/29/2014 Copies 08/01/2014 Service Mileage 08/14/2014 Not Found Return 08/14/2014 Refund Advance Fee 24846 $0.00 $150.00 $9.00 $0.00 $9.00 $0.00 $2.50 $0.00 $10.00 $0.00 $6.00 $0.00 $2.80 $0.00 $5.00 $0.00 $105.70 $0.00 BALANCE: $150.00 $150.00 $0.00 [Plaintiff Attorney LAW OFFICE PAUL F. D'EMILIO, LLC, 905'WEST SPROUL ROAD, SUITE 105, SPRINGFIELD, PA 19064 (c) CountySuite Sheriff, Teleosoft, Inc.