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HomeMy WebLinkAbout14-3500 JUN/12/2014/THU 08: 59 AM Bromberg & Miller FAX No. 4122320344 P. 001 Supreme Cit nnsylvania Co f o leas pr �libt�efb Cuy�"� srly, h�,i�r j `pit;'M' S(i •,•w;. :i'";<' ~' f. County The information collected on this form is used solely for court adminisiration purposes. This form does not supplement or replace thefiling and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: ,a t. Complaint Writ of Summons Q Petition 1 Transfer from Another Jurisdiction [� Declaration of Taking Lead Plaintiff's Name: Lead Defendant's Name_ =. GOODVILLE MUTUAL CASUALTY COMPANY CODY SIGMUND - � Dollar Amount Re uested: vvithin arbitration limits Are looney damages requested? ®Yes © No (check one)4 ©outside arbitration limits r x;�t!j�iilt Is this a Class Action Suit? [J Yes El No Is this an MDJ Appeal? 1 Yes 0 No ' Ila, Name of Plaintiff/AppeIlant's Attorney: GEORGE A. MILLER, ESQ, Check here if you have no attorney(area Self-Represented [Pro Se) Litigant) atare:.of the-.:Caw: Place'An'°`X'.'.to the1eft 0'f kie ONY case.:catc Qry th :ra atost;aceivately: sY cribes .oar :. .. PTr31V19R 'DISE:ff you are n alLtngmm 'than tme. of cl Checl .the bne thaC ,. you cotisYder,rriost.iinportant '..., TORT(do nor includeMass Ton) CONTRACT(do not Include Judgments) CIVIL APPEALS Intentional 0 Buyer Plaintiff Administrative Agencies Malicious Prosecution El Debt Collection:Credit Card b Board of Assessment Motor Vehicle ©Debt Collection:Other Q Hoard of Elections aa Q Nuisance g Dept.of Transportation Premises Liability H Statutory Appeal:Other jai g .0 Product Liability(does not include G� mass Tort) 0 Praployment Dispute: Slander/Libel/Defamation Discrimination IQ Other: Employmmit Dispute:Other Zoning Board I' Other: p Other: Qn; MASS TORT [] Asbestos L' 0 Tobacco R; Toxic Tort-DES © Tonic Tort-Implant REAL PROPERTY MISCELL 4N'EMS Toxic Waste Othcr: Ejectment Common Law/Statutory Arbitration Eminent Domatn/Conde=ation E3 Declaratory judgment Ground Rent Mandamus Landlord/Tcnant Dispute 0 Non-Domestic Relations Ej Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL L_A LIT'Y Mortgage Foreclosure:Commercial d Quo Warranto Dental d partition 0 Replevin Legal El Quiet Title d Other: © Medical [] Other: © Other Professional: Updated 1/1/011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GOODVILLE MUTUAL CASUALTY COMPANY, as subrogee for BARBARA M. and JOHN B. SWARNER, 5so V No. Plaintiff, ) VS. CODY SIGMUND, Defendant. cil ) �� NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defense 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 BRING 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 PROVICE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITHI 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 ST. CARLISLE, PA 17013 > 800-990-9108 717-249-3166 � �a er-4 Loo 13 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GOODVILLE MUTUAL CASUALTY COMPANY, as subrogee for No. BARBARA M. and JOHN B. SWARNER, Plaintiff, VS. CODY SIGMUND, Defendant. COMPLAINT IN CIVIL ACTION AND NOW come(s) GOODVILLE MUTUAL CASUALTY COMPANY, as subrogee for BARBARA M. and JOHN B.SWARNER,Plaintiff,by and through their attorney, GEORGE A. MILLER, ESQ., and BROMBERG & MILLER, Attorneys at Law, and file(s) the within COMPLAINT IN CIVIL ACTION as follows: 1. The Plaintiff is Goodville Mutual Casualty,a corporate entity having a mailing address as 625 W. Main Street,New Holland, PA 17557. 2. Defendant is Cody Sigmund,an adult individual whose address is 71 Fairview Street, Carlisle, PA 17015. 3. The Plaintiff was, at all time pertinent hereto, the insurer of Barbara M. and John B. Swarner, Plaintiff's subrogor/s. 4. On or about July 25,2013,Defendant operated his motor vehicle along York Road, South Middletown Township,Cumberland County,in such fashion as to collide with the rear of the motor vehicle of Barbara M. and John B. Swarner, being then and there operated by Barbara M. Swarner, who was stopped due to traffic. 5. Defendant's actions were negligent as more specifically described below: a. In failing to exercise due care; b. In being inattentive; C. In failing to fulfill the requirements of the Pennsylvania Motor Vehicle Financial Responsibility Law; d. In failing to maintain control of motor vehicle; e. In failing to keep a proper look out; and f. In operating the motor vehicle in a careless and reckless fashion. 6. As a direct and proximate result of the negligence of the Defendant, Plaintiff's subrogors sustained damages totaling $6,787.13. 7. Plaintiff paid said amount, less any deductible,to or on behalf of Plaintiff's subrogors, and now seeks to recoup said amount, including any deductible, from the Defendant,by right of subrogation. 8. Demand has been made upon the Defendant for payment,however Defendant has refused to pay such sum due. 9. Plaintiff intends to offer the attached Police Report, Repair Estimates and Rental Invoice at trial, collectively marked as Exhibit"A,"pursuant to Pa. R.C.P. Rule 1305. The motor vehicle was repaired. 2 WHEREFORE, the Plaintiff demands judgment against the Defendant in the sum of$6,787.13, together with costs of suit. Respectfully submitted, BROMBERG& MILLER BY: GEORGE A. MILLER, Esquire GOODVILLE MUTUAL CASUALTY, as subrogee for BARBARA M. and JOHN B. SWARNER, Plaintiff 3 VERIFICATION The undersigned, �Sa t400 ye*— does hereby verify that he/she isthe (?J&At� ICQ'qxPS'P"-JJyl- of Plaintiff herein,that he/she is authorized.to make this verification on behalf of the Plaintiff,and that the facts contained in the foregoing COMPLAINT IN CIVIL ACTION are true and correct to the best of his/her knowledge and belief. This statement is made subject to the penalties of 18 Pa.C.S.. Section 4904 relating to unsworn falsification to authorities. GOODVILLE MUTUAL CASUALTY By: 1' Title File No. 58562 AA-500 TX Incident Number: H02.2224609 Commonwealth of Pennsylvania PAGE 1 `crash Involves: Police Crash Report REPORTABLE CRASH DUI 0 Fatality 0 Hit and Run 0Commercial Vehicle 0 State Pollee Vehicle Local Police Vehicle 0 NIA 0 Work Zone 0 ATV Snowmobile 0 Commonwealth Vehicle Q Local Gov vehicle Agency Name Case Closed Patrol Zone Invesligation Date o PA STATE POLICE-CARLISLE YES 24 07125/2013 r � Dispatch Time Arrival Time Investigator Badge Number a 12:43 hrs 12:49 hrs, BEYNON,DONALD 06896 Approval Date Reviewer Reviewer Badge Number 0 0810112013 STONEROAD,HEIDI N 10406 11 a Data of Crash Time of Crash Day of the Week Crash Description 0712612013 12:42 hrs. THURSDAY REAR END County Municipality CUMBERLAND SOUTH MIDDLETON TWP 0 Weather Conditions Relation to Roadway o NO ADVERSE CONDITIONS ON TRAVEL LANES r Illumination Road Surface Conditions DAYLIGHT DRY #of Units #of People #of Injured Killed EMS Agency Medical Facility 002 002 002 000 CUMBERLAND EMS CARLISLE REGIONAL HOSPITAL School Bus Related School Zone Related 1PennDOT Notified Type of Intersection Special Location NO NO NO MIDBLOCK NOT APPLICABLE m Work Zone Work Zone Type Wherein Work Zone o NO N Speed Umit Workers Present Officer present Work Zone Characteristics C Road Closed Work on Shoulder Intermittent or Flogger 3 [:]Lane Closure 0 with Detour ❑or Median 1:1Moving Work ElControl Other Route Signing Route Number Segment Number Travel Lenes Speed Limit Orientation 0 STATE HIGHWAY 0074 02 30 MPH EAST House Number Street Name St.Ending z 190 YORK ROAD a d Route Signing Route Number Segment Number Travet Lanes Speed limit Orientation a Used in E Intersection Crashes Street Name St.Ending Ls m c a Route Number Or Mile Post Tenths Or Segment Marker Romp Use Only Feet E a a EE c L) a Street Name Ending Or Miles Tenths E9 3 6 Y Route Number Or Mile Post Tenths Or Sagmenl Marker Remp Use Only The above entry is the m distance from the Crash s` C Street Name Street Ending Scene t0 Landmark 1 a m D j J Decim N Degrees Minutes Seconds Decimal Degrees Minutes a Seconds al IL Latitude: 40 11 , 42 122 Longitude: C5 77 10 a 03 970 o Traffic Control Device Traffic Control Functioning FU NOT APPLICABLE -NO CONTROLS c Lane Closed Lane Closure D'eaction Traffic Detoured Estimated Tlme Closed FULLY EAST NO <30 MIN. Environmental I Roadway Potential Factors JEIR) Factor 1 Factor 2 Factor 3 NONE g First Harmful Event in the Crash Most Harmful Event in the Crash C Unit Number Harmful Event Unit Number armful Event Fb 001 HIT UNIT 2 001 HIT UNIT 2 c „ indicated Prime Factor Unit Number Prima Factor Driver Action c DRIVER ACTION 001 DRIVER WAS DISTRACTED w Prima Factor EnviromenlaURoadway Prima Factor Vehicle Failure Pnma Factor Pedestrian Action Road Surface Type EXHIBIT Printed At: PA STATE POLICE.CARLISLE 8126120 Form 0 H02-2224609 E9 AA-500 TX Incident Number: M02-2224609 Commonwealth of Pennsylvania PAGE 2 Crash Involves: Police Crash Report REPORTABLE CRASH DUI 0 Fatality Hit and Run OCommsrclal Vehicle { State Police Vehicle Local Police Vehicle N)A Work Zone 0 ATV 0Snowmobile 0 Commonwealth Vehicle �Local Gov Vehicle Unit Number Type Unit Commercial Vehicle 1 Motor Vehicle In Transport No First Name IMI Last Nama Suffix DOB Telephone Number CODY SIGMUND 110128111989 (717)712-5218 Street Address City State Zip Code 71 FAIRVIEW STREET CARLISLE PA 17015 Gender License Number License State Class Expiration Date Owner/Driver M 29540484 PA C 11012912016 PRIVATE VEHICLE OWNEDILEASED BY DRIVER c Driver Presence Physical Coition Primary Vehicle Code Violation Person Charged 0 DRIVER OPERATED VEHICLE ILLEGAL DRUG USE PAVC 3714,CARELESS DRIVING YES .q IAlcohoVDrugs Suspected Alcohol Test Type Alcohol Test Results o ILLEGAL DRUGS TEST NOT GIVEN c Driver Action DRIVER WAS DISTRACTED N m gPedestrian Action Pedestrian Signa'.s Pedestrian Clolhing Pedestrian Location `o 1st Harmful Event Left or Right Siqle. Most Harmful UtiLly Pole Number HIT UNIT 2 YES 2nd Harmful Event Left or Right Side Most Harmful Ufltiy Pole Number 3rd Harmful Event Left or Right Side Most Harmful Uiiity Pole Number 4th Harmful Event Left or Right Side Most Harmful UGkly Pole Number Owner First Name Owner MI Owner Last Name or Business Name suffix CODY SIGMUND Street Address cats State Zip Code 71 FAIRVIEW STREET CARLISLE PA 17015 Vehicle Type Spacial Usage Government Equipment Number AUTOMOBILE NOT APPLICABLE Madel Year lVehicla Make Vehide Model Vehicle Color VIN 1996 HONDA CIVIC GREEN 1HGEJ8146TLO14007 icense Plate Reg.State Est.Speed Vehicle Towed Towed By JH02702 PA 040 YES BOORES TOWING Insurance Insurance Company Policy Number Expiration Date NO Direction of Travel Vsh;de Position Vehlda Movement Initial Impact Point e EAST RIGHT LANE"CURB" GOING STRAIGHT 12 O'CLOCK 0 Damage Indicator Goadient Road Alignment Possible Vehicle Failures DISABLING LEVEL STRAIGHT NONE E #of Units Type Unit 1 Tag Number Tag Year Tag State u 0 S Unit Make Unit Owner a p 'c Type Unit 2 Tag Number Tag Year Tag State ►� Unit Meka Unit Ovine f Engine Size Passenger? Saddle eagrrrunk? Trailer? Driver Education? cc m Driver Helmet Type Helmet Stayed On? DOT/Snell Designation? Eye Protection? Long Sleeves? Long Pants? Over Ankle Boots? O Passenger Hemet Type Helmet Stayed On? DOT/Snell Designation? Eye Protection? Long Sleeves? Long Pants? Over Ankle Boots? m Passenger? Helmet? V V Head Lights? Rear Reflectors? m o. Printed At: PA STATE POLICE-CARLISLE 8126/2013 3:13 PM 2 Form# H02-2224609 AA-500 TX Incldent Number: H02.2224809 Commonwealth of l"ennsylvania PAGE 3 Crash Involves- Police Crash Report REPORTABLE CRASH DUI 0 Fatality 0 Hit and Run Q Commercial Vehicle a State Police Vehicle Local Police Vehicle 0 N)A 0 Work Zone �ATV 0 Snowmobile �Commonwealth Vehicle 0 Local Gov Vehicle Unit Number Type Vnil Commercial Vehicle 2 Motor Vehicle In Transport No First Name Ml Last Name Suffix DOB Telephone Number BARBARA M SWARNER 02106N944 (717)662-4495 Street Address City State Zip Code 1196 PISGAH STATE RD SHERMANS DALE PA 1 17090 Gander License Number License State Class Expiration Date Owner/Driver F 11075666 PA C 02/0712016 -PRIVATE VEHICLE NOT OWNEDILEASED BY DRIVER c Driver Presence Physical Condition Primary Vehicle Code Violation Person Charged DRIVER OPERATED VEHICLE APPARENTLY NORMAL NONE NO a Alcohol/Drugs Suspected Alcohol Test Type Alcohol Test Results e NO TEST NOT GIVEN Driver Action NO CONTRIBUTING ACTION N s Pedestrian Action Pedestrian Signals Pedestrian Clothing Pedestrian Location QIL 0 1st Harmful Event Left or Right Side: Most Harmful Wilily Pole Number STRUCK 13Y UNIT 1 r. YES 2nd Harmful Event Left or Right Side Most Harmful Utility Pole Number 3rd Harmful Event Left or Righl Side Most Harmful Utility Pole Number 4th Harmful Event Left or Right Side Most Harmful Utility Pote Number Owner First Name Owner Ml Owner Last Name or Business Name Suffix BARBARA M SWARNER, Street Address City - Stals Zip Code 1196 PISGAH STATE RD SHERMANS DA4:E'" PA 17090 Vehicle Type Special Usage Government Equipment Number SMALL TRUCK NOT APPLICABLE Model Year Vehide Make Vehicle Model Vehicle Color VIN 2010 FORD RANGER RED 1FTLR4FE6APA29736 License Plate Reg.State Est.Speed Vehicle Towed Towed By YBA9828 PA 000 NO Insurance Insurance Company Policy Number Expiration Date YES GOODVILLE MUTUAL PA770701 11!0112013 Direction of Travel Vehicle Position Vo hide Movement Initial Impart Point c EAST RIGHT LANE"CURB" STOPPED IN TRAFFIC LANE 6 O'CLOCK 0 m Damage indicator Gradient lRoad Alignment Possible Vehicle Failures € FUNCTION LEVEL STRAIGHT NONE . #of Units Type Unit 1Tag Number Tag Year Teg State Y D Unit Make Uniz Owner. c O1 Types Unit 2 Tap Number Tag Year Tag States c r; Unit Make UnitOwner Engine Size PassengeR Saddle BagfTrunk? Trailer? Driver Education? cc Driver Helmet Type Helmet Stayed On? DOT/Snell Designation? Eye Protection? Long Sleeves? Long Pants? Over Ankle Boots? gL' s Passenger Helmet Type Helmet Stayed On? DOT/Snell Designation? Eye Protection? Long Sleeves? Long Pants? Over Ankle Boots? m Passenger? Helmet? v r U c Head Lights? Rear Reflectors? r>,. Printed At: PA STATE POLICE-CARLISLE 8/2612013 3:13 PM 3 Form# H112-2224609 AA-500 TX IncldentNumber: H02-2224609 Commonwealth of.Pennsylvania PAGE 4 Crash Involves: Police Crash Report REPORTABLE CRASH DUI 0 Fatality 0 Hit and Run Commercial Vehlcle State Police Vehicle Local Police Vehicle 0 N/A 0 Work Zone 0 ATV r)SnowmoEille Commonwealth Vehicle 0 Local Gov Vehicle Unit# Person No. First Name MI Leat Name: Suffix DOB 001 001 CODY I I SIGMUNR 1012811989 Street Address City State Zip Code 71 FAIRVIEW STREET CARLISLE I PA 17015 aPhone Number EMS Transport Person Type Gander Injury Severity (717)712-5218 YES DRIVER M MINOR INJURY 2 Seal Position Safety Equipment 1 DRIVER-ALL VEHICLES LAP AND SHOULDER BELT USED o Safety Equipment 2 Extrication a a MULTIPLE AIRBAGS DEPLOYED NOT EXTRICATED Ejection E)action Path NOT EJECTED NOT EJECTEDINOT APPLICABLE Unit# Person No. First Name MI Last Name, Suffix DOB 002 002 BARBARA M SWARNR 0210611944 Street Address City State Zip Code 1196 PISGAH STATE RD SHERMANS DALE, PA 17090 Phone Number EMS Transport Person Type Gander liniury Severity € (7171582-4425 YES DRIVER F MINOR INJURY Seat Position Safety Equipment 1 8 DRIVER•ALL VEHICLES LAP,..AND SHOULDER BELT USED c Safety Equipment 2 Extrication a AIR BAG NOT DEPLOYED-SWITCH ON NOT EXTRICATED Ejection Ejection Path NOT EJECTED NOT EJECTEDINOT APPLICABLE PersonlBusinesa Notified Phone Number Date Notified Time Notified hrs. o Reason for Nolilrcation z j. Printed At; PA STATE POLICE-CARLISLE 8!26/2013 3:13 PM A Form# H02-2224609 AA-500 TX Incident Number; H02-2224609 Commonwealth of Pennsylvania PAGE 5 crash Involves: Police Crash Report REPORTABLECRASH DUI Q Fatality 0 Hit and Run Ocommerclal Vehicle 0 State Police Vehicle a Local Police Vehicle • NIA 0 Work Zone 0 ATV C)Snowmoblla 0 Commonwealth Vehicle �Local Gov Vehicle ARLISLE BOROUGH,APPROX. 1!2 IPIILE UNiT#2 E ISO c YORK ROAD INITIAL 161PAC7 YORK ROA4 FINAL REST OF UNIT42 FJNAL REST OF UNIT41 NARRATIVE Crash Synopsis This crash occurred as Unit#1 was traveling east In the area of 190 York Road., South Middleton Twp, Cumberland County. The operator of Unit#1 failed to observe Unit#2 stopped fit the traffic lane due to traffic,crashing into the rear of Unit#2 Crash Details This crash occurred as Unit#1 was traveling east In the area of 190 York Road., South Middleton Twp,Cumberland County. The operator of Unit#1 failed to observe Unit#2 stopped in the traffic lane due to traffic, crashing into the rear of Unit#2 On 07125/13 @ approximately 1243hrs,I was assigned to respond to 190 York Road, South Middleton Twp, Cumberland County for a two vehicle crash. Upon my arrival, I observed Unit#1 at final rest still In the travel lane. I observed Unit#2 just east of Unit#1 off the south side of the roadway. On 07/25/13 @ approximately 1250hm, I spoke with the operator of Unit#2 at the scene and she related that she was stopped in the traffic lane due to traffic when she was struck in the rear by Unit#1. On 07125/13 a@ approximately 1300hrs, I spoke with the operator of unit91 at the scene and he related that he was east on York Road when his car popped out of gear.The operator.of Unit#1 related that he looked down to put the car back in gear and failed to observe Unit#2 stopped in traffic, crashing into the rear of Unit#2.(let Printed At: PA STATE POLICE•CARLISLE 8/2612013 3:13 PM 5 Farm N H02-2224509 AA-500 TX Incident Mrnber: H02-2224909 Commonwealth o$Pennsylvania PACE 6 Crash Involves: Police Crash Report REPORTABLE CRASH DUI O Fatality O Hit and Run OCommercielVehicle a State PalluVehicle O Local Police Vehicle ONIA 0 Work zona 0 ATV 0 Snowmobile 0 Commonwealth Vehicle V Local Gov Vehicle Crash Details it be noted,just prior to me speaking with the operator of unit#1,I overheard him tell EMS that he had smoked marijuana last night at approximately 2300hrs).That statementwas confirmed by this Trooper, reference intoxication report, H02-2224609 On 07/26/13 @ approximately 1100hrs, I spoke with operator#1's insurance company, the general, policy#PN1536175 and they advised me that operator#1's insurance policy expired on 06124113 for non payment Unit#1 was towed from the scene by Boores towing and-both.operators were transported to Carlisle Regional Hospital for minor injuries. Operator#1 was cited for PAVC 3714, Careless Driving and PAVC 1786F, Required Financial Responsibility. Notice of crash investigation issued to both drivers. Crash release submitted. ` ''41 Printed At: PA STATE POLICE-CARLISLE 8/26/2013 3:13 PM 6 Form# H02.2224609 fff Date: 8/12/201312: Estimate IDs 2373 Estimate Version: 0 Preliminary Profile ID: Mitchell Ed's Auto Body PO BOX 203 400 EAST WATER STREET,LANDISBURG,PA 17040 (717)789-4656 Fax: (717)789;3273 Email. edsautobody@kuhnconi.net Tax ID: 25-1604738 EPA#:,PAR000503581 Damage Assessed By: #664513 Ed Deiter Type of Loss: Collision Condition:Code: Good Date of Loss: 712512013' Deductible: WAIVED Payer:. Insurance Claim Number: 5428934 Policy No: 770701 Owner: BARBARA 8 JOHN SWARNER Address: 1196 PISGAH STATE RD,SHERMANS DALE,PA 17090 Telephone: Home Phone: (717)582.4495 Mitchell Service:. 917623 . Description: 2010 Ford Ranger XLT Drive Train: 4.OL Inj 6 Cyl 4WD Body Style: .4D PkupXCb 6^Bed 125"WB. License: YBA9828 PA VIN: 1FTLR4FE6APA29735 Mileage: 29,243 Search Code: B826908 OEM/ALTs A Options: PASSENGER AIRBAG,DRIVER AIRBAG,POWER LOCK,,POWER WINDOW,POWER STEERING MANUAL AIR,CONDITION,CRUISE CONTROL,TILT STEERING COLUMN,ANTI-LOCK BRAKE SYS. FOG LIGHTS,PICKUP TRUCK BED LINER,ALUM/ALLOY WHEELS,.AUXILIARY INPUT LEATHER STEERING WHEEL,SATELLITE RADIO,V6 ENGINE,TOW HITCH RECEIVER FRONT AIR DAM,TINTED GLASS,SIDE AIRBAGS,ANTI-THEFT SYSTEM AM/FM STEREO CDIM P3 PLAYER,.ELECTRONIC STABILITY CONTROL,FRONT KEYLESS ENTRY SYSTEM, OWER DISC BRAKES,STEERING WHEEL MOUNTED SPLIT ONTROLS EAT Line Item Part Typel Dollar Labor Line Entry Labor Part Number Amount Units Item Number Type Operation Description Pickup Bed C 8.5 # 1 700203 REF REFINISH Pickup Bed Components 0.2 2 BDY REMOVEIINSTALL Upr Tailgate Moulding Qual Recycled Part 1,500.00 * 2.5 3 700211 BDY REMOVEIREPLACE Replace Pickup Bed Assy 4 Aumilier Auto Salvage @ 800-692-7463 ***END OF.ATG SECTION*** 5 Cab Cab Back Panel Outside C 0.8* 6 701756 REF BLEND Existing 1.0*# 7 701766 BDY REPAIR Cab Back Panel Pickup Bed 0.2 8 705796 BDY REMOVEIINSTALL R Pickup Bed Moulding 0.2 9 705797 BDY REMOVE/INSTALL L Pickup Bed Moulding 0.2 10 704889 BDY REMOVEIINSTALL R Tie Down Hook 0.2 11 704890 BDY REMOVE/INSTALL L Tie Down Hook 6L5Z 9925622 AB 54.62 0.2 12 706663 BDY REMOVEfREPLACE R Pickup Bed Decal Body Components 13 931072 FRM REMOVEIREPLACE Frame Qual Recycled Part 500.00 * 8.0* 14 Rear Section of Frame 15 Aumilier Auto Salvage @ 800-692-7463 Pickup Bed 16 706664 BDY REMOVEIREPLACE L Pickup Bed Decal 6L5Z 9925622 AB 54.62 0.2 17 705491 BDY REMOVEIINSTALL Tailgate Handle Tailate Existing 0.4 r ESTIMATE RECALL NUMBER: 0811212013 07:21:21 2373 Mitchell Data Version: OEM: JUL_13_V MAPP:JUL_13 V Copyright(C)1994-2013 Mitchell International Page 1 of 3 Software Version: 7.0.487 All Rights Reserved Date: 8/121201312:. Estimate ID: 2373 Estimate Version: 0 Preliminary Profile ID: Mitchell 18 ,a 195 BOY REMOVE/INSTALL Tailgate Adhesive Emblem Existing U.t 19 706171 BOY REMOVE/INSTALL Tailgate Adhesive Nameplate Existing 0.2 r Rear Lamos 20 701505 BOY REMOVE/INSTALL R Rear Combination Lamp 02 21 701506 BOY REMOVE/INSTALL L Rear Combination Lamp 0.2 Rear Bumper 22 BOY OVERHAUL Rear Bumper Assy 0.7 23 704908 BOY REMOVE/REPLACE Rear Bumper Face Bar 4L5Z 17906 DA 429.00 INC 24 REF REFINISH Rear Face Bar C 1.6 25 703328 BOY REMOVE/REPLACE Rear Bumper Step Pad ORDER FROM DEALER 110:67 INC 26 701543 BOY REMOVE/REPLACE R Rear Bumper Mounting Ann F37Z 17787 A 22.55 INC 27 701544 BOY REMOVE/REPLACE L Rear Bumper Mounting Ann F37Z 17788 A 22.55 INC 28 703283 BOY REMOVE/REPLACE R Rear Otr Bumper Bracket ORDER FROM DEALER 15.00 INC 29 703284 BOY REMOVE/REPLACE L Rear Otr Bumper Bracket ORDER FROM DEALER 14.75 INC 30 704827 BOY REMOVEIREPLACE Rear Bumper Stabilizer 41-5Z 1713826 AA 268.50 INC MANUAL ENTRIES 31 900500 BOY * REMOVEIREPLACE Trailer Hitch Assembly XL5Z17D826AB 173.33 * 0.3* 32 900500 BOY * ADD'L LABOR OP REMOVE ADHESIVES Existing 0.2* 33 900500 BOY * REMOVE/REPLACE ADHESIVE MLDG TAPE New 2.00 * 0.0* 34 900500 BOY * ADD'L LABOR OP RETAPE MLDGS Existing 0.1* 35 900500 BOY ' ADD'L LABOR OP CLEAN CAR FOR DELIVERY Existing 0.5* Additional Operations 36 933006 FRM ADD'L OPR Frame/Rack Set Up 0.00 * 20* 37 933034 FRM ADD'L OPR Pull For Sag 2,0* 38 REF ADD'L OPR Clear Coat 2.8 39 933005 BOY ADD'L OPR RESTORE CORROSION PROTECTION 20.06 * 0.1* 40 933017 REF ADD'L OPR FINISH SAND AND BUFF 1.0* MANUAL ENTRIES 41 900500 REF * REMOVEIREPLACE CAR COVER New 5.00 * 0.2* Additional Operations 42 933026 BOY ADD'L OPR LKQ Part Cleanup 1.0* MANUAL ENTRIES 43 900500 BOY * REMOVE/INSTALL Bed Liner Existing 0.5* r Additional Costs&Materials 44 ADD'L COST Paint/Materials 389.20 * 45 ADD'L COST Hazardous Waste Disposal 3.00 * * -Judgment Item #-Labor Note Applies C-Included in Clear Coat Calc r.-CEG R&R Time Used For This Labor Operation Estimate Totals Addy Labor Sublet I. Labor Subtotals Units Rate Amount Amount Totals 11. Part Replacement Summary Amount Body 9.5 48.00 20.00 0.00 476.00 T Taxable Parts 3,172.59 Refinish 14.9 48.00 0.00 0.00 715.20 T Parts Adjustments(Cost Plus) 500.00 Frame 12.0 50.00 0.00 0.00 600.00 T Sales Tax @ 6.000% 220.36 Taxable Labor 1,791.20 Total Replacement Parts Amount 31892.95 Labor Tax @ 6.000% 107.47 Labor Summary 36.4 1,898.67 ESTIMATE RECALL NUMBER: 06/12/2013"07:21:21 2373 Mitchell Data Version: OEM: JUL 13_V MAPP:JUL7_13_V Copyright(C)1994-2013 Mitchell International Page 2 of 3 Software Version: 7.0.487 All.Rights'Reserved Date: 8/12/201312: r /12/201312:?' Estimate ID: 2373 Estimate Version: 0 Preliminary Profile ID: Mitchell III. Additional Costs Amount IV. Adjustments Amount Taxable Costs 392.20 Insurance Deductible WAIVED Sales Tax @ 6.000% 23.53 Customer Responsibility 0.00 Total Additional Costs 415.73 Paint Material Method:Rates Init Rate=28.00 ,init Max Hours=99.9,Add[Rate 0.00 1. Total Labor. 1,898.67 ll. Total Replacement Parts: 3,892.95 Ill. Total Additional Costs: 415.73 Gross Total: 6,207.35 IV. Total Adjustments: 0.00 Net Total: 6,207.35 This is a preliminary estimate. Additional changes to the estimate may be required for the actual repair. Point(s)of impact 6 Rear Center(P) Insurance Co: Goodviile Mutual Casualty Company Address: 625 West Main St PO Box 489 New Holland,PA 17557 Telephone: (800)448-4622 ext.280 Fax Phone: (717)354-2330 ANY PERSON WHO KNOWINGLY AND WITH INTENT TO DEFRAUD ANY INSURANCE COMPANY OR OTHER PERSON FILES AN APPLICATION FOR INSURANCE OR STATEMENT OF CLAIM CONTAINING ANY MATERIALLY FALSE INFORMATION OR CONCEALS FOR THE PURPOSE OF MISLEADING, INFORMATION CONCERNING ANY FACT MATERIAL THERETO COMMITS A FRAUDULENT INSURANCE ACT, WHICH IS A CRIME AND SUBJECTS SUCH PERSON TO CRIMINAL AND CIVIL PENALTIES. SELECTION OF THE REPAIR SHOP IS THE RESPONSIBILITY OF THE VEHICLE OWNER. VEHICLE OWNER IS UNDER NO OBLIGATION TO USE ANY SPECIFIC REPAIR SHOP. THIS ESTIMATE MAY HAVE BEEN PREPARED BASED ON THE USE OF AUTOMOBILE PARTS NOT MADE BY .THE ORIGINAL, MANUFACTURER. PARTS USED IN THE REPAIR OF YOUR VEHICLE BY OTHER THAN .THE ORIGINAL MANUFACTURER ARE REQUIRED TO BE AT LEAST EQUAL IN LIKE KIND AND QUALITY IN TERMS OF FIT, PERFORMANCE AND. WARRANTIES TO REPLACEMENT PARTS AVAILABLE FROM THE ORIGINAL MANUFACTURER. ESTIMATE RECALL NUMBER: 08112/201307:21:21 2373 Mitchell Data Version: OEM: JUL 13 V MAPP:JUL 13_V Copyright(C)1994-2013 Mitchell International Page 3 of 3 Software Version: 7.0.487 All Rights Reserved Rental Company:ENTERPRISE RENT-A-CAR VIN OAR NWWOWGOODIVILLE MUTUAL Invoice: D752634-5710 Bill To: GMC5712 RENTAL DETAIL: GOODVILLE MUTUAL ATTN: LISA HOOVER Rental Period: 7/26/13 to 8/14/13(20 days) PO BOX 489 Billed Period: 7126113 to 8114113(20 days) NEW HOLLAND, PA 17557 RENTER INFORMATION: Products and Services Rate Amount Renter: SWARNER, BARB/JOHN 20 DAYS @ 24.99 $499.80 RENTAL INFORMATION: Taxes and Surcharges Rental Branch Location: 20 PTA TAX 2.00 $40.00 ENTERPRISE RENT-A-CAR(5710) 1 VRT 2.00% $10.00 800 NORTH HANOVER ST CARLISLE, PA 170131538 1 SALES TAX 6.00% $29.98 (717)258-4495 Total Charges: $579.78 ! ADDITIONAL CLAIM INFORMATION: € Less Amount Received: $0.00 Claim Number:428934 Claim Type:Insured Total Amount Due: $579.78 Vehicle Condition: Driveable Date Of Loss:7/25/13 Insured Name: Owner's Vehicle: Additional Driver: Repair Facility: ED'S AUTOBODY LANDISBURG, PA 17040 (717)789-4656 VEHICLES RENTED: Effective Date and Year Make Model VIN Starting Ending Mileage Time Mileage Mileage 7/26/13 1:09 PM 2013 KIA FORT KNAFU4A26D5740115 8404 8681 277 Rental Invoice Please Return This Portion with Remittance Make Payment To: Total Charges: $579.78 ENTERPRISE RENT-A-CAR(5799) Less Amount Received: $0.00 2625 MARKET PLACE Total Amount Due.................... $579.78 HARRISBURG, PA 17110 Please include on your check: Federal ID:43-0724835 Invoice: D752634-5710 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief DeputytC 20 F`I 2 :- Richard W Stewart L,' r p.� Solicitor ,:,Fr Ccp €=,Fc �i,°1 � 1� Ew1WU �� vE ..i. PENNSYLVANIA Goodville Mutual Casualty Company Case Number vs. Cody Alan Sigmund 2014-3500 SHERIFF'S RETURN OF SERVICE 06/12/2014 08:03 PM - Deputy Christopher Sharpe, being duly sworn according to law, served the requested Complaint& Notice by"personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Cody Alan Sigmund at 71 Fairview Street, South Middleton Township, Carlisle, PA 17015. ISTD E SHARPE, DEPUTY SHERIFF COST: $34.78 SO ANSWERS, June 13, 2014 RONO R ANDERSON, SHERIFF LEL 2014 JUL 24 PM 2: PENNNS YC V NIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GOODVILLE MUTUAL CASUALTY CASE NO. 2014-3500 COMPANY SUBROGEE FOR BARBARA M. AND JOHN B. SWARNER CODE NO. Plaintiff, TYPE OF PLEADING: vs. PRAECIPE TO ENTER DEFAULT JUDGMENT CODY SIGMUND FILED ON BEHALF OF: Defendant, GOODVILLE MUTUAL CASUALTY COMPANY COUNSEL OF RECORD FOR THIS PARTY: GEORGE A. MILLER, ESQUIRE Pa. I.D. No. 22525 BROMBERG & MILLER FIRM I.D. No. 937 1030 Fifth Avenue, Ste 102 PITTSBURGH, PA 15219 (412) 232-0440 File No. 58562 CLH- (gctict (n,SD-pd°I.111 R-11 3o$alej IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GOODVILLE MUTUAL CASUALTY COMPANY SUBROGEE FOR BARBARA M. AND JOHN B. SWARNER Plaintiff, No. 2014-3500 vs. CODY SIGMUND Defendant, PRAECIPE TO ENTER DEFAULT JUDGMENT TO: PROTHONOTARY, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY KINDLY ENTER DEFAULT JUDGMENT IN THE ABOVE CASE AGAINST THE DEFENDANT(S), CODY SIGMUND, in the amount of SIX THOUSAND SEVEN HUNDRED EIGHTY SEVEN DOLLARS AND THIRTEEN CENTS ($6787.13) plus costs and interest from the date of entry, the Defendant(s) having failed to file an Answer to the Complaint. More than ten (10) days have elapsed since serving the Defendant(s) with a copy of the "IMPORTANT NOTICE," a copy of said Notice with the PROOF OF SERVICE being attached hereto as Exhibit "A. BY: Respectfully submitted, G RGE A. MILLER, Esquire, Attorney for GOODVILLE MUTUAL CASUALTY COMPANY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GOODVILLE MUTUAL CASUALTY COMPANY AS SUBROGEE FOR BARBARA M. AND JOHN B. SWARNER, vs. Plaintiff, NO. 2014-3500 CODY SIGMUND Defendant. TO: CODY SIGMUND Date of Notice: JULY 9, 2014 IMPORTANT NOTICE 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 800-990-9108 (717) 249-3166 eorge A. Miller, Esquire 1030 Fifth Avenue, Ste 102 Pittsburgh, PA 15219 2014-3500 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GOODVILLE MUTUAL CASUALTY COMPANY AS SUBROGEE FOR BARBARA M. AND JOHN B. SWARNER, vs. CODY SIGMUND Plaintiff, Defendant. NO. 2014-3500 PROOF OF SERVICE THE UNDERSIGNED, George A. Miller, Attorney for Plaintiff herein, does hereby verify that the IMPORTANT NOTICE, a copy of which is attached hereto, was mailed to the Defendant(s) herein on JULY 9, 2014, by U.S. Mail, First Class, Postage Paid. This statement is made subject to the penalties of 18 Pa. C.S., Section 4904, relating to unsworn falsifications to authorities. eorge A. Miller, Esquire IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GOODVILLE MUTUAL CASUALTY COMPANY SUBROGEE FOR BARBARA M. AND JOHN B. SWARNER Plaintiff, vs. CODY SIGMUND Defendant, CASE NO.: 2014-3500 NOTICE OF JUDGMENT TO: DEFENDANT (S) ABOVE NAMED: CODY SIGMUND 71 FAIRVIEW STREET CARLISLE, PA 17015 TAKE NOTICE, that on ,2004 , JUDGMENT was entered against you and in favor of the Plaintiff (s) in the amount of SIX THOUSAND SEVEN HUNDRED EIGHTY SEVEN DOLLARS AND THIRTEEN CENTS ($6787.13 plus costs and interest from date of entry. PROTHONOTARY By: r ' s 1 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GOODVILLE MUTUAL CASUALTY CASE NO.: 2014-3500 COMPANY SUBROGEE FOR BARBARA M. AND JOHN B. CODE NO. SWARNER TYPE OF PLEADING: Plaintiff, AFFIDAVIT IN SUPPORT OF CERTIFICATION OF MOTOR VS. VEHICLE JUDGMENT CODY SIGMUND. FILED ON BEHALF OF: Defendant. GOODVILLE MUTUAL CASUALTY COMPANY SUBROGEE FOR BARBARA M. AND JOHN B. SWARNER COUNSEL OF RECORD FOR THIS PARTY: GEORGE A. MILLER, ESQUIRE Pa. I.D. No. 22525 BROMBERG&MILLER FIRM I.D. No. 937 1030 Fifth Avenue, Suite 102 S � � PITTSBURGH, PA 15219 ajxx� l� File No. 58562 (412) 232-0440 I - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GOODVILLE MUTUAL CASUALTY COMPANY, Case No. 2014-3500 SUBROGEE FOR BARBARA M. AND JOHN B. SWARNER, Plaintiff, VS. CODY SIGMUND Defendant AFFIDAVIT IN SUPPORT OF CERTIFICATION OF MOTOR VEHICLE JUDGMENT COMMONWEALTH OF PENNSYLVANIA, SS: COUNTY OF ALLEGHENY, I,GEORGE A.MILLER,ESQUIRE,being duly sworn according to law,depose and state: 1. I am an attorney in good standing, admitted to practice in the courts of this Commonwealth, and am counsel of record for the Plaintiff-judgment creditor, GOODVILLE MUTUAL CASUALTY COMPANY, in the above-captioned matter. 2. I am authorized to make this Affidavit on behalf of the Plaintiff. 3. The address of the Plaintiff is 633 W. MAIN ST., NEW HOLLAND, PA 17557 4. The last-known address of the Defendant, 71 FAIRVIEW STREET, CARLISLE, PA 17015 5. The judgment reflected at Docket No.3500 of 2014 of the Court of Common Pleas of Cumberland County,PA is in the amount of$6787.13,is valid,enforceable and unsatisfied, and is the result of a motor vehicle accident upon which suspension of driver's operating privileges is authorized. GEORGE A. MILLER, ESQUIRE SWORN TO and subscribed before nj this /.Sfk day of 2843.;.2 0 / tary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seat Laura D.Miller,Notary Public Ross Twp.,Allegheny county My Commission Expires March 28,2016 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES