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HomeMy WebLinkAbout14-4796 Oreme P Vennsylvania COUI'l f.C&minIo Pleas For Prothonotary Use Only: Civi4lI iC., over�S eet , Docket No: S? i CU Rt ia+Nt7 f; COunty z The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S El Complaint M Writ of Summons El Petition Transfer from Another Jurisdiction [3 Declaration of Taking E C Lead Plaintiffs Name: Lead Defendant's Name: STATE FARM MUTUAL AUTOMOBILE INSURANCE COI JESSICA BRADY T Dollar Amount Requested: M within arbitration limits I Are money damages requested? ED Yes El No check one Q ( ) outside arbitration limits N Is this a Class Action Suit? [3 Yes El No Is this an MDJAppeal? Q Yes El No .A Name of Plaintiff/Appellant's Attorney: BENJAMIN W. LAWRENCE,209032 Check here if you have no attorney(are a Self-Represented IPro 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 E3 Intentional ® Buyer Plaintiff Administrative Agencies ® Malicious Prosecution 0 Debt Collection:Credit Card Board of Assessment Motor Vehicle [3 Debt Collection:Other Board of Elections n Nuisance Dept.of Transportation E] Premises Liability R, Statutory Appeal:Other S Product Liability(does not include E mass tort) � Employment Dispute: � Slander/Libel/Defamation Discrimination C M Other: Employment Dispute:Other Zoning Board T SUBROGATION Other: T [J Other: O MASS TORT Asbestos N Tobacco Toxic Tort-DES Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS M Toxic Waste Other: 0 Ejectment El Common Law/Statutory Arbitration 13 Eminent Domain/Condemnation Q Declaratory Judgment Q Ground Rent Mandamus Li ® Landlord/Tenant Dispute 0 Non-Domestic Relations 0 Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY Q Mortgage Foreclosure:Commercial El Quo Warranto Dental El Partition n Replevin El Legal rl Quiet Title Q Other: Medical [3Other: Other Professional: Updated 11112011 ,•a Pi PRO ftjo�vo� PENNS Y( V 4P0UN T Y IA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION State Farm Mutual Automobile Insurance Company S Plaintiff NO: vs . COMPLAINT IN CIVIL ACTION JESSICA BRADY Defendant 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 20574074 C Y Jer HOH S ot IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION State Farm Mutual Automobile Insurance Company Plaintiff VS. Civil Action No JESSICA BRADY Defendant COMPLAINT AND 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 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 s WELTMAN,WEINBERG&REIS CO.,L.P.A. BY: Benjamin W. Lawrence, Esquire Attorney for Plaintiff(s) Pa. Identification No.209032 325 Chestnut Street, Suite 501 Philadelphia, PA 19106 Phone: 215.599.1500 Fax: 215.599.1505 File #20574074 STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY Court of Common Pleas CUMBERLAND County vs. JESSICA BRADY NO. CIVIL ACTION — COMPLAINT 1. Plaintiff is a business organization licensed and authorized to conduct business in the State of Illinois with a place of business located at P.O. BOX 2371, BLOOMINGTON, IL 61702. 2. Defendant is an adult individual who at all time pertinent hereto resided at 646 FISHING CREEK RD, NEW CUMBERLAND, PA 17070. 3. Plaintiff issued a policy of motor vehicle insurance whereby Plaintiff agreed to insure the motor vehicle involved in this incident ("Insured Vehicle"), owned by Plaintiff's insured. 4. On or about August 25, 2013 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 200 block of South 3rd Street, West Shore, 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 Plaintiff Insured's vehicle sustained property damage and/or incurred rental charges in the. total amount of $7,031.30. 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 Plaintiff and as a result of the aforesaid payment, Plaintiff became subrogated to the claim of its Insured against Defendant. WHEREFORE, Plaintiff demands Judgment against Defendant in the amount of $7,031.30 plus interest and costs. WELTMAN, WEINBERG & REIS, CO., L.P.A. BenjaminJ2 )3 nce, Esquire PA I.D. # 325 Chest Suite 501 Philadelphia, PA 19106 (215) 599-1500 WWR#20574074 EXHIBIT 1 STATE FARM INSURANCE COMPANIES LIKE A GOOD NEIGHBOR,STATE FARM IS THERE 1 STATE FARM DRIVE CONCORDVILLE, PA 19339 PHONE(800)839-8050—FAX ALL SUPPLEMENT REQUESTS TO(800)916-0342 ***ESTIMATE " 09/07/2013 11:29 AM Owner Owner: TYLER N HOWARD Address: 3145 BROOKFIELD RD Work/Day: Home/Day: (717)497-0280 City State Zip: HARRISBURG, PA 17109-1904 Cell: Control Information Claim#: 38-31312-69601 Insured Policy#: Loss Date/Time: 08/25/2013 Loss Type: Collision Deductible: $100.00 Ins.Company: State Farm Insured: TYLER N HOWARD Home/Day: (717)497-0280 _Claim Rep: Team CP Unit C4 ACC PA NJ Address: Work/Day: (888)713-4694 L Inspection _._. _.._...... ,_._...... ._ _ _F.. _........... _..:.. _..,,..... _ w_ ,.._ .,.._ . Inspection Date: 09/07/2013 11:24 AM Inspection Type: Field Address: 795 Sipe Rd Home/Day: City State Zip: York Haven, PA 17370 Primary Impact: Front Secondary Impact: Driveable: No Rental Assisted: Assigned Date/Time: Received Date/Time: 09/06/2013 12:59 PM First Contact Date/Time: Appointment Date/Time: 09/06/2013 06:00 AM Company: Appraiser License#: 133454 Contact: DAVID MICKLEY Repairer Address: 795 Sipe Rd Home/Day: City State Zip: York Haven, PA 17370 FAX: Remarks .,.—. ,�..�.�.. ..-.�.._.� .�...�. �....-�.._... .....,. .�.....m...�.,.. .���,.w.._... ESTIMATE WAS PREPARED BY DAVID L.MICKLEY(ELECTRONIC SIGNATURE) SUPPLEMENTAL REQUEST MUST BE FAXED TO 1-800-916-0342 PRIOR TO STARTING THOSE REPAIRS.IF NO FAX,CALL 1-800-839-8050 ANY SUPPLEMENT TO THIS ESTIMATE REQUIRES THE APPROVAL OF A STATE FARM REPRESENTATIVE PRIOR TO THE PERFORMANCE OF THAT REQUEST. 09/09.!2013 07:58 AM Page 1 of 8 2007 Dodge Caliber SXT 4 DR Hatchback Claim#: 38-3B12-69601 09/0712013 11:29 AM Vehicle 2007 Dodge Caliber SXT 4 DR Hatchback 4cyl Gasoline 2.0 Continuously Variable Tr Uc Expire: VIN: 1 B3HB48B67D375793 Prod Date: Mileage: 138,585 Veh Insp#: Mileage Type: Actual Condition: Code: N22038 Ext.Color: blue Int.Color: Ext.Refinish: Two-Stage Int.Refinish: Two-Stage Options AM/FM CD Player Air Conditioning Alarm System Automatic Dimming Mirror Bodyside Moldings Bucket Seats Center Console Cruise Control Dual Airbags Fog Lights Garage Door Opener Head Airbags Intermittent Wipers Keyless Entry System Lighted Entry System Power Brakes Power Door Locks Power Mirrors Power Steering Power Windows Rear Spoiler Rear Window Defroster Rear Window Wiper/Washer Side Airbags Tachometer Theft Deterrent System Tilt Steering Wheel Tinted Glass Tire Pressure Monitor Velour/Cloth Seats Damages Line Op Guide MC Description MFR.Part No. Price ADJ% B% Hours R Unibody/Frame 1 1 M00 Unibody-Frame Incl Setup Sublet Repair $260.00* FR* » Rt Rail Sway-Lt Rail Sway and Sag Stripes And Mouldings 2 RI 426 Mldg,Front Door Side RT R& I Assembly 0.5 SM Front Bumper 3 E 74 Cover,Front Bumper 5183394AE $472.00 1.3 SM 4 L 74 Cover,Front Bumper Refinish 3.1 RF 2.6 Surface 0.5 Two-stage 5 E 5 Reinf,Front Bumper 5303764AE $270.00 2.8 SM 6 L 5 Reinf,Front Bumper Refinish 0.8 RF 0.7 Surface 0.1 Two-stage 7 E 7 Absorber,Front Bumper 68018830AB $23.75 INC SM Front End Panel And Lamps 8 E 28 01 Grille Assembly 68050326AA $219.00 INC SM 9 N 43 Fog Lamps Aim ADDITIONAL OPERATION 0.3 SM 10 N 973 Headlamps Aim ADDITIONAL OPERATION 0.4 SM 11 E 41 01 Lens,Headlamp LT 5303739AJ $204.00 INC SM 12 E 42 01 Lens,Headlamp RT 5303738AJ $204.00 INC SM 13 N 45 Lamp Assembly,Fog LT ADDITIONAL OPERATION INC SM 14 N 46 Lamp Assembly,Fog RT ADDITIONAL OPERATION INC SM 15 RI 22 Lens,Fog Lamp LT R&I Assembly INC SM 16 RI 23 Lens,Fog Lamp RT R&I Assembly INC SM 0910912013 07:56 AM Page 2 of 8 J 2007 Dodge Caliber SXT 4 DR Hatchback Claim#: 8-3812-69601 09/07,2013 11:29 AM Radiator Support 17 E 89 Panel,Grille Mounting 5116131AB $53.95 0.3 SM 18 E 92 07 Crsmbr,Rad Pnl Lower 5115402AH $177.00 2.8 SM 19 L 92 Crsmbr,Rad Pnl Lower Refinish 0.6 RF 0.5 Surface 0.1 Two-stage 20 E 1016 Label,Radiator Support 5058519AA $4.35 0.1 SM Cooling And Air Conditioning 21 EC 755 Radiator **NON-OEM PART $167.00* INC SM »Located LKQ 250 Harrisville,OH 1-877-391-2727 Quote#2899300 22 E 748 Motor,Cooling Fan RT 68031873AA $267.00 INC SM 23 E 756 Shroud,Radiator 68031872AA $123.00 0.6 SM 24 N 968 A/C Evac Rechrg&Rcvr ADDITIONAL OPERATION 1.8 ME 25 EC 731 Condenser,A/C **NON-OEM PART $156.00* 0.8 ME » Located LKQ 250 Harrisville,OH 1-877-391-2727 Quote#2899300 26 E 1703 Hose,Trans Oil Cooler 5191278AA $125.00 0.2 ME Front Body And Windshield 27 BR 83 Panel,Hood Blend Refinish 1.6 RF 1.1 Blend 0.5 Two-stage 28 1 103 Fender,Front LT Repair 2.0* SM 29 L 103 Fender,Front LT Refinish 2.2 RF 1.8 Surface 0.4 Two-stage 30 E 104 Fender,Front RT 5115660AD $429.00 2.0 SM 31 L 104 Fender,Front RT Refinish 2.6 RF 1.7 Surface 0.5 Edge 0.4 Two-stage 32 RI 103 Front Fender R&I LT R&1 Assembly 1 A SM 33 RI 112 Mast,Antenna RT R& I Assembly 0.1 SM 34 RI 1025 Cover,Antenna RT R& I Assembly INC SM 35 RI 365 Guard,Fender Mud LT R& I Assembly 0.2 SM 36 RI 366 Guard,Fender Mud RT R& I Assembly INC SM Front Body Interior Sheetmetal 37 RI 1068 Battery R&I LT R&I Assembly 02 SM 38 E 66 07 Reinf,Side Rail LT 5115353AB $35.60 0.5 SM 39 66 Reinf,Side Rail LT Refinish INC RF 40 E 67 07 Reinf,Side Rail RT 5115352AB $35.60 0.5 SM 41 67 Reinf,Side Rail RT Refinish INC RF 42, E 138 Skirt,lnner Fender LT 5303867AF $53.00 INC SM 43 RI 138 Skirt,lnner Fender LT R&1 Assembly INC SM 44 E 139 Skirt,lnner Fender RT 5303866AE $53.00 INC SM 45 1 113 07 Side Member Assembly LT Repair 2.0* SM 46 L 113 Side Member Assembly LT Refinish 0.6 RF 0.5 Surface 0.1 Two-stage 47 1 114 07 Side Member Assembly RT Repair 1.5* SM 48 L 114 Side Member Assembly RT Refinish 0.6 RF 0.5 Surface 0.1 Two-stage »Refinish with-in panel boundaries. 49 RI 1172 Shield,Engine Lower R&1 Assembly 0.4 ME Roof 50 RI 347 Midg,Roof Side LT R& I Assembly 0.2 SM 51 RI 348 Mldg,Roof Side RT R&I Assembly 0.2 SM Front Doors 52 BR 32 13 Pnl,Front Door Outer RT Blend Refinish 2.0 RF 09/09/2013 07:58 AM Page 3 of 8 2007 Dodge Caliber SXT 4 DR Hatchback Claim 9: 38-3812-69601 09/07!2013 1129 AM 0.9 Blend 0.6 Two-stage setup 0.5 Two-stage 53 RI 300 Mirror,Outer RIC RT R&I Assembly 0.3 SM 54 RI 203 Bezel,Mirror LT R&I Assembly SM 55 RI 204 Bezel,Mirror RT R& I Assembly SM 56 RI 228 Handle,Front Door Otr RT R&I Assembly 0.5 SM Rear Doors 57 RI 308 Pnl,lnner Door Trim RT R&I Assembly 0.9 SM Manual Entries 58 N Car Covers ADDITIONAL OPERATION $5.00* 0.2* SM* 59 N Clean for Delivery ADDITIONAL OPERATION 0.3* SM* 60 N Corrosion Protection ADDITIONAL OPERATION 0.6* RF* 61 N Flex Additive ADDITIONAL OPERATION $6.00* SM* 62 N Hazardous Waste ADDITIONAL OPERATION $3.00* SM* 63 N Nib Sanding-Denib ADDITIONAL OPERATION 0.7* RF* 64 1 Pinch Weld(s) Repair 0.5* SM* 65 L Pinch Weld(s) Refinish 0.5* RF* 66 N Refrigerant ADDITIONAL OPERATION $14.00* INC* SM* 67 N Refrigerant Oil ADDITIONAL OPERATION $2.85* INC* SM* 68 N Retape Mldgs-Emb ADDITIONAL OPERATION 0.4* RF* 69 N Touch Up Bolts ADDITIONAL OPERATION 0.1* RF* 69 Items MC Message 01 CALL DEALER FOR EXACT PART#/PRICE 07 STRUCTURAL PART AS IDENTIFIED BY I-CAR 13 INCLUDES 0.6 HOURS FIRST PANEL TWO-STAGE ALLOWANCE Estimate Totaf&Entries Gross Parts $2,749.25 Other Parts $353.85 Paint Materials $45920 Parts&Material Total $3,562.30 Tax on Parts&Material @ 6.000% $213.74 Labor Rate Replace Repair Hrs Total Hrs Hrs Sheet Metal(SM) $50.00 15.4 7.2 22.6 $1,130.00 MechtElec(ME) $50.00 1.4 1.8 3.2 $160.00 Frame(FR) $52.00 Refinish(RF) $50.00 14.6 1.8 16.4 $820.00 Paint Materials $28.00 Labor Total 42.2 Hours $2,110.00 Tax on Labor @ 6.000% $126.60 Sublet Repairs $260.00 Gross Total $6,272.64 Less: Deductible $100.00- Net Total $6,172.64 0910912013 07-58 AM Page 4 of 8 2007 Dodge Caliber SXT 4 DR Hatchback Claim#: 38-3612-69601 09107/2013 11:29 AM For more information regarding State Farm's promise of satisfaction relating to new non-original ' equipment manufacturer(non-OEM)and recycled parts, please visit:htto://st8.fm/7X4 or QR code. 0 . .. y� Register online to check the status of your claim and stay connected with State Farm®.To register,go to statefarm.com and select Check the Status of a Claim.If you are already registered,thank you!Not available in New Mexico. Alternate Parts Y/00100/00/00/00 CUM 00/00/00/00/00 Zip Code: 17404 HARRISBURG Audatex Estimating 7.0.019 ES 09109/2013 07:58 AM REL 7.0.019 DT 08/01/2013 Copyright(C)2013 Audatex North America,Inc. 3.3 HRS WERE ADDED TO THIS ESTIMATE BASED ON AUDATEX'S TWO-STAGE REFINISH FORMULA. Op Codes * = User-Entered Value E = NEW PART NG= Replace NAGS EC= **NON-OEM PART ET= Partial Replace Labor EP= **NON-OEM PART EU= RECYCLED PART TE= Partial Replace Price PM= REMAN/REBUILT PART UM= REMAN/REBUILT PART L = Refinish PC= RECOND PART UC= RECOND PART TT =Two-Tone SB= Sublet Repair N = ADDITIONAL OPERATION BR= Blend Refinish I = Repair IT = Partial Repair CG= Chipguard RI = R&I Assembly P = Check RP= RP-RELATED PRIOR This report contains proprietary information of Audatex and may not be disclosed to any third party(other than the insured,claimant and others on a need to know basis in order to effectuate the claims process)without O'A Au datex Audatex's prior written consent. m, Copyright(C)2013 Audatex North America,Inc. Audatex Estimating is a trademark of Audatex North America, Inc. 09109/2013 07:58 AM Page 5 of 8 • 2007 Dodge Caliber SXf 4 DR Hatchback Gm i?ai : 8-3612-63601 09107/201311:29 AM Estimate Summary Page Gross Total $6,272.64 Less: Deductible $100.00- Net Total $6,172.64 Audatex Estimating 7.0.019 ES 09/0912013 07:58 AM REL 7.0.019 DT 08/01/2013 Copyright(C)2013 Audatex North America,Inc. SM-SHEET METAL ME-MECHJELEC FR-FRAME RE-REFINISH SY-SYSTEM THIS IS AN ESTIMATE. REPAIR FACILITIES MUST INSPECT THE VEHICLE TO DETERMINE IF ANY REPAIRS NOT LISTED ARE REQUIRED, AND TO CONTACT STATE FARM BEFORE MAKING SUCH REPAIRS. REPAIRER ALSO IS RESPONSIBLE FOR CONDUCTING ANY NECESSARY INSPECTION AND SAFETY CHECKS PRIOR TO AND AFTER COMPLETING REPAIRS. IF THIS APPRAISAL HAS BEEN PREPARED BASED ON THE USE OF AFTERMARKET CRASH PARTS, AND IF THE USE OF ANY 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. 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. ANY PERSON WHO KNOWINGLY AND WITH 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. YOU ARE UNDER NO REQUIREMENT TO USE ANY SPECIFIC REPAIR FACILITY TO PERFORM REPAIRS TO YOUR VEHICLE. COSTS ABOVE THE APPRAISED AMOUNT MAY BE THE RESPONSIBILITY OF THE VEHICLE OWNER. INFORMATION REGARDING REPAIR FACILITIES WHICH WILL BE ABLE TO REPAIR THE VEHICLE FOR THE APPRAISED AMOUNT IS AVAILABLE FROM YOUR CLAIM HANDLER OR ONLINE AT WWW.STATEFARM.COM THIS APPRAISAL INCLUDES ONLY THOSE INCIDENTAL CHARGES, KNOWN AND AGREED UPON BY THE APPRAISER AT THE TIME OF APPRAISAL, INCLUDING TOWING, PROTECTIVE CARE, CUSTODY STORAGE, DEPRECIATION, BATTERY AND TIRE REPLACEMENT. ANY TOWING, STORAGE, OR OTHER INCIDENTAL CHARGES KNOWN BUT NOT LISTED ON THE ESTIMATE ARE FORWARDED TO THE CLAIM HANDLER FOR DISPOSITION. FAILING TO PRESENT THIS ESTIMATE TO THE REPAIRING FACILITY BEFORE A REPAIR MAY RESULT IN ADDITIONAL EXPENSE TO YOU. 09/09.2013 07:58 AM Page 6 of 8 2007 Dodge Caliber SXT 4 DR Hatchback Claim#: 38-3812-69601 09!071201311:29 AM COPY OF THE FORM(S) WAS SENT/GIVEN TO THE CONSUMER ON 09/09/2013 07:58 AM Page 7 of 8 2007 Dodge Caliber SXT 4 DR Hatchback Claim#: 38-3812-69601 09107/20131129 AM NON-ORIGINAL EQUIPMENT REPLACEMENT PARTS INFORMATION Whenever**appears next to the description of a part which is to be replaced,this means: THIS APPRAISAL HAS BEEN PREPARED BASED ON THE USE OF AFTERMARKET CRASH PARTS. 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. 09109/2013 07:58 AM Page 8 018 09/09/13 04 :59 AUTOSOURCE Page 1 Via: Direct AS Request: 33060210 Version: 1 ADMINISTRATIVE DATA 2007 DODGE CALIBER SXT 4D HATCHBACK David Mickley Claimant: State Farm Insurance Insured:Howard , Tyler Concordville Branch Claim: 38-3B12-69601 PO Box 106106 Loss Date: 08/25/2013 Atlanta GA 30348 Loss Type:Collision Policy: Other: Appraiser License: 133454 Owner Name: HOWARD Owner Address : 3145 BROOKFIELD RD Owner City: HARRISBURG Owner State: PA Owner Zip: 17109-1904 Primary Impact: 12 VALUATION SUMMARY 2007 DODGE CALIBER SXT 4D HATCHBACK See N.A.D.A See Valuation Autosource/ Value Section Detail Section N.A.D.A. N.A.D.A. Retail Autosource Average ------------------------------------------ Base Price: $8 , 500 $9 , 090 $8 , 795 Engine: Transmission: Odometer: -2 , 000 -1 , 285 -1 , 643 Equipment: 0 135 68 Value Before Adjustments : $6 , 500 $7 , 940 $7 , 220 --------------------------- --------------------------- Value Before Condition Adjs . : $7 , 940 $7 , 220 Suggested Total Condition Adj . : 110 Total Condition Adjusted Mkt Val : -- $7 , 330 General Sales Tax: * 6 . 0001-- 439 . 80 Title Fee: 0 . 00 Transfer Fee: 55 . 00 Deductible: -100 . 00 Net Adjusted Value: 7 , 724 . 80 Salvage/Other: - * The market area identified has multiple tax jurisdictions . 09/09/13 04 :59 AUTOSOURCE Page 2 Via: Direct AS Request: 33060210 Version: 1 VINSOURCE ANALYSIS 2007 DODGE CALIBER SXT 4D HATCHBACK VIN: 1B3HB48B67D375793 Decodes as: 2007 Dodge Caliber SXT 4D Hatchback Accuracy: Decodes Correctly History: Activity was reported AudaVIN: No o AUTOSOURCE ACTIVITY: Reported by Safe Auto Insurance Company in Columbus, OH on August 28 , 2013 . Call them at (800 )723-3288 regarding Claim: 640173-CV (Request : 33018325 DOL: 08/25/2013 Odometer: 138 , 585 ) . o AUTOTRAK ACTIVITY: (NONE) . o AUDATEX/ESTIMATING ACTIVITY: Reported by SAFE AUTO INSURANCE COMPANY _ on August 28 , 2013 . Call them regarding Claim: 640173-CV. DOL:08/25/2013 with a primary impact point of FRONT CENTER. o SALES HISTORY ACTIVITY: (NONE) REPORTED PHONE NUMBER ANALYSIS 2007 DODGE CALIBER SXT 4D HATCHBACK No Vehicles Advertised at (717) 497-0280 N.A.D.A. VALUE** 2007 DODGE CALIBER SXT 4D HATCHBACK **N.A.D.A. Vehicle Description: 2007 DODGE Caliber-4 Cyl . Wagon 4D SXT 2 . 0 N.A.D.A. values are as of August , 2013 from the Eastern Edition. -----------Base Value---- ------- $8 , 500 -----------Mechanical----------- Engine: 80 Transmission: $0 -----------Equipment------------ -------Equipment Subtotal------- $0 ------Mileage: 138 , 585 Mi------- $ -2 , 000 -------------- -------------- Adjusted Total $6 , 500 These current N.A.D.A. values are furnished under license from NADASC. All values Copyright (C) NADASC 2013 . The values in the N.A.D.A. guide assume a vehicle in clean condition. Appropriate deductions should be made to put a vehicle in salable condition. SPECIAL NOTE ON OLDER VEHICLES: N.A.D.A. ' s editors believe that most optional equipment has little or no value on older vehicles . This is especially true of options that cost relatively little to begin with and which deteriorate with age or use. 09/09/13 04 :59 AUTOSOURCE Page 3 Via: Direct AS Request: 33060210 Version: 1 LOSS VEHICLE VALUATION 2007 DODGE CALIBER SXT 4D HATCHBACK The Autosource database contains inspected dealer inventories , dealer advertisements , phone verified vehicles , and private party advertisements from thousands of sources including automotive publications, newspapers and Web sites . Autosource uses vehicles comparable in year, make and model within the specified market area, expanding as necessary, to determine the loss vehicle ' s local market value. This valuation includes a representative sample of the vehicles used to calculate the typical starting price. The market search originated from Zip Code 171091904, as determined by the vehicle owner' s principally garaged area. Autosource located 41 . 2007 Dodge Caliber vehicles which were used to determine the typical vehicle price . Adjustments have been made to the comparable vehicles for value differences in vehicle description as indicated in the "Veh Adj " field . The sum of the 41 comparable vehicles is $395 , 606 for an average price of $9 , 649 . The asking or actual sale price is displayed for each vehicle . If a vehicle has been sold, the sold price is displayed with an (S) indicator. The selling price may be substantially less than the asking price. In the case of this 2007 Dodge Caliber, the difference between the asking price and selling price is generally 60. This selling price adjustment has been applied to the typical price. Additional adjustments have been made to the typical vehicle price taking into consideration the loss vehicle' s mileage, equipment and condition. All adjustments are vehicle specific and reflect driving habits and condition for the vehicle ' s market . A mileage adjustment of 2 . 50 cents per mile has been applied. Taking into consideration the vehicle specifics , the fair market value is $7 , 330 . VEHICLE VALUATION DETAIL 2007 DODGE CALIBER SXT 4D HATCHBACK Typical Vehicle Typical Vehicle Loss Vehicle Adjustment ---------------------- -------------------- ---------- City/State:Harrisburg, PA Harrisburg, PA Price: S9 , 090 $9 , 090 ----Description----- Year: 2007 2007 Make:Dodge Dodge Model :Caliber Caliber Edition:SXT SXT Door:4D 4D Body:Hatchback Hatchback Drive:2WD 2WD Engine:4 Cylinder 2 . 0 Engine 4 Cylinder 2 . 0 Engine 0 09/09/13 04 :59 AUTOSOURCE Page 4 Via: Direct AS Request: 33060210 Version: 1 VEHICLE VALUATION DETAIL (continued) 2007 DODGE CALIBER SXT 4D Typical Vehicle Loss Vehicle Adjustment Transmission:Continuously Variable Continuously Variable 0 Color:Not Applicable Blue Odometer: 87, 178 Mi(Typical ) 138 , 585 Mi(Actual) -1 , 285 -----Equipment------ Convenience Options: Automatic Dimming 0 Air Conditioning Air Conditioning Garage Door Opener 0 Rear Window Defroster Rear Window Defroster Cruise Control Cruise Control Tire Pressure Monitor 0 Tilt Steering Wheel Tilt Steering Wheel Other Optional :Bodyside Moldings Bodyside Moldings Fog Lights 20 Tachometer Tachometer Dual Airbags Dual Airbags Head Airbags Head Airbags Intermittent Wipers Intermittent Wipers Keyless Entry System Keyless Entry System Lighted Entry System Lighted Entry System Center Console Center Console Tinted Glass Tinted Glass Rear Spoiler Rear Spoiler Side Airbags Side Airbags Rear Window Rear Window Power Accessories:Power Windows Power Windows Power Steering Power Steering Power Door Locks Power Door Locks Power Brakes Power Brakes Power Mirrors Power Mirrors Radio/Phone/Alarm:AM/FM CD Player AM/FM CD Player Theft Deterrent System Theft Deterrent Alarm System Alarm System Seat Options:Velour/Cloth Seats Velour/Cloth Seats Bucket Seats Bucket Seats Packages: Driver Convenience 85 YES Essentials Bckt 30 Autosource Value Before Condition Adjustments: 7 , 940 ------Interior------ Seats:Minor Wear Moderate Wear -130 Carpets:Minor Wear Minor Wear Int Trim:Minor Damage Moderate Damage -50 G1ass:Good Good Headliner:Good Minor Wear -50 ------Exterior------ Body:Minor Damage Good 205 Paint:Minor Wear Good 135 Ext Trim:Good Good 09/09/13 04 :59 AUTOSOURCE Page 5 Via: Direct AS Request: 33060210 Version: 1 VEHICLE VALUATION DETAIL (continued) 2007 DODGE CALIBER SXT 4D Typical Vehicle Loss Vehicle Adjustment -----Mechanical----- Engine:Minor Wear Minor Wear Transmission:Minor Wear Minor Wear -------Tires-------- Front Tires:Good Good Rear Tires:Good Good Total Condition Adjustments": 110 Prior Damage: 0 Condition Adjustment: 110 Net Condition Adjustment: 110 Total Condition Adjusted Market Value: $8 , 050 VALUATION NOTES 2007 DODGE CALIBER SXT 4D HATCHBACK o Loss vehicle description was provided by State Farm Insurance o Adjustments of Special Note - A mileage adjustment of 2 . 50 cents per mile/kilometer has been applied. This adjustment is based on the vehicle year, vehicle category and market area. Mileage adjustments are capped at 40a of the vehicle ' s starting value . - No special adjustments were made for this vehicle . - All values are in U. S . dollars . o Autosource Valuation Process - Over 3 , 800 , 000 vehicles are entered weekly into the database used for researching this value. This database includes dealer inspected, dealer inventory, dealer advertised , phone verified and advertised private party vehicles . - The originating search area for this valuation was Harrisburg, Pennsylvania. - This vehicle was previously valued by Autosource . If this vehicle was valued by another company for the same loss , any differences in value are due to the differences in the reporting of the loss vehicle information, market area or methodology. If this was valued for a different loss date, differences in value would be due to the differences in the time frame. 09/09/13 04 :59 AUTOSOURCE Page 6 Via: Direct AS Request: 33060210 Version: 1 VALUATION NOTES (continued) 2007 DODGE CALIBER SXT 4D o Other Adjustments or Comments - The market area identified has multiple tax jurisdictions . Autosource was unable to identify which county or city was applicable to the total loss vehicle . However, each of the counties have the identical tax amount , therefore , the valuation was completed using this identical amount. o Conditioning Notes - INTERIOR * SEATS: Considerable fading or discoloration. * CARPETS: Slight stains . 1-3 burn marks or holes smaller than a dime. * INT TRIM: Multiple surface cracks no greater than 1 credit card in size. Shiter console wear * GLASS: No obvious damage. Numerous small pits . Light scratches visible on close inspection. * HEADLINER: Slight stains . - EXTERIOR * BODY: No visible damage . 1-3 small dings possible on close inspection. * PAINT: 1-3 very small chips . 1-3 small scratches , no greater than 1 credit card in size , only noticeable on close inspection that can be polished out . * EXT TRIM: No damage. No dents . No impact damage . Good shine on chrome or bumper covers. Color-keyed sections in good condition. - TIRES * FRONT TIRES: 30-790 of tread remains . * REAR TIRES: 30-790 of tread remains . ORIGINAL EQUIPMENT GUIDE 2007 DODGE CALIBER SXT 4D HATCHBACK ----------Engine Options----------- -------Transmission Options-------- 4 Cylinder 1 . 8 Engine STD 5 Speed Manual STD * 4 Cylinder 2 . 0 Engine $100 * Continuously Variable Tr $1 . 000 -----Other Optional Equipment------ --------Convenience Options-------- Anti-Lock Brakes $400 * Air Conditioning STD * Bodyside Moldings $40 * Automatic Dimming Mirror * Center Console STD * Cruise Control $250 * Dual Airbags STD * Rear Window Defroster STD Engine Block Heater $35 Daytime Running Lights $40 * Fog Lights $85 Floor Mats $50 * Head Airbags STD * Garage Door Opener * Intermittent Wipers STD Smokers Package 530 * Keyless Entry System STD Strg Wheel Radio Control $135 09/09/13 04 :59 AUTOSOURCE Page 7 Via: Direct AS Request: 33050210 Version: 1 ORIGINAL EQUIPMENT GUIDE (continued) 2007 DODGE CALIBER SXT 4D * Lighted Entry System STD * Tire Pressure Monitor Leather Steering Wheel * Tilt Steering Wheel STD Pearlescent Paint $150 -----Radio/Phone/Alarm Options----- * Rear Window Wiper/Washer STD * Alarm System STD * Side Airbags STD Boston Acoustic Speakers * Rear Spoiler STD In-Dash CD Changer &Tape $300 * Tachometer STD * AM/FM CD Player STD Tonneau/Cargo Cover $75 AM/FM In-dash CD Changer $200 * Tinted Glass STD MP3 Player $120 Camper/Towing Package $130 Sirius Satellite Radio $195 Upgraded/Add ' 1 Speakers $360 Subwoofer ---------Power Accessories--------- * Theft Deterrent System STD * Power Brakes STD -----------Seat Options------------ • Power Door Locks STD * Bucket Seats STD * Power Mirrors STD Heated Front Seats $250 * Power Steering STD Leather Seats * Power Windows STD * Velour/Cloth Seats STD -----------Roof Options------------ -----------Wheel Options----------- Power Moonroof $750 Aluminum/Alloy Wheels $400 ------------------------------Option Packages------------------------------- • Driver Convenience Group $400 Includes Automatic Dimming Mirror, Garage Door Opener, Tire Pressure Monitor Hands-Free Communication $275 Leather Interior Group $1 , 045 Includes Heated Front Seats , Leather Steering Wheel , Leather Seats , Strg Wheel Radio Control Musicgate Sound System $495 Includes Leather Steering Wheel , Subwoofer, Strg Wheel Radio Control , Upgraded/Add ' l Speakers , Boston Acoustics Speakers Security Group $275 Includes Alarm System, Tonneau/Cargo Cover, Air Filtration Sport Appearance Group $645 Includes Aluminum/Alloy Wheels , Fog Lights * YES Essentials Bckt $150 Base retail price: $15 , 985 Loss Vehicle manufacturer ' s suggested retail price as reported: $18 , 010 Editions available for the same body style (in order of original cost , increasing) : SE, *SXT, R/T * Indicates loss vehicle equipment. 09/09/13 04 :59 AUTOSOURCE Page 8 Via: Direct AS Request: 33060210 Version: 1 VEHICLE LOCATOR SERVICE 2007 DODGE CALIBER SXT 4D HATCHBACK After your claim is settled, Autosource provides free assistance in locating your next vehicle . Your request can be submitted online 24hrs . per day at http://www. support .audatex.us . Under Additional Services click the Autosource Vehicle Locator Service Form link to complete the VLS form_ Or you can call us Monday through Friday, between 8 : 00 AM and 5:00 PM, Pacific time at ( 800 ) 351-3133 , ext 7428 . Our specialists will work with you to find a new or used vehicle in your area. PENNSYLVANIA REGULATORY STATEMENT 2007 DODGE CALIBER SXT 4D HATCHBACK 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 . Any person who knowingly and with 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 the payment of a fine of up to $15 , 000 . ABOUT YOUR VALUATION 2007 DODGE CALIBER SXT 4D HATCHBACK This report contains proprietary information of Audatex and shall not be disclosed to any third party (other than the insured or claimant) without Audatex' s prior written consent . If you are the insured or claimant and have questions regarding the description of your vehicle , please contact the insurance company that is handling your claim. Information within VINsource/NICB is provided solely to identify potential duplicative claims activity. User agrees to use such information solely for lawful purposes . Tax rates contained herein are based on general sales tax data provided by Vertex Inc . Excise, use, registration, licensing and other taxes and fees that may be applicable are not included. Audatex makes no representations or warranties concerning the applicability or accuracy of such tax data_ 09/09/13 04 :59 AUTOSOURCE Page 9 Via: Direct AS Request : 33060210 Version: 1 Report Generated by Audatex, a Solera Company US Pat. No 7912740B2 US Pat_ No 8200513B2 US Pat. No 8468038B2 (C) 2013 Audatex North America, Inc . All Rights Reserved. v • y 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. BenJanIA W. Lawrence Date �, l Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFF Iwo QF T,1- ti 1 IF.R t.,11-1 OCT —1 Pfd 2: >; ? CUMBERLAND COUNTY PENNSYLVANIA State Mutual Automobile Insurance Company vs. Case Number Jessica Brady 2014-4796 SHERIFF'S RETURN OF SERVICE 08/14/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Jessica Brady, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Complaint & Notice according to law. 08/25/2014 The requested Complaint & Notice returned by the Sheriff of York County, the within named Defendant Jessica Brady, not found. Richard P. Keuerleber, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $37.00 SO ANSWERS, September 23, 2014 (c) CountyStlite Sh,arlf`, Tele oso RONNY R ANDERSON, SHERIFF SHERIFF'S OFFICE OF YORK COUNTY Richard P KeuerleberPETER J. MANGAN, ESQ. Sheriff �� .�.�T� Solicitor Michael S. Hose Richard E Rice, II Chief Deputy, Operations c" Chief Deputy, Administration STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY VS. JESSICA BRADY Case Number 14-4796 CIVIL SHERIFF'S RETURN OF SERVICE 08/19/2014 11:30 AM - DEPUTY TAYLOR ECK, BEING DULY SWORN ACCORDING TO LAW, ATTEMPTED SERVICE TO THE DEFENDANT, TO WIT: JESSICA BRADY AT 646 FISHING CREEK ROAD, NEW CUMBERLAND, PA 17070. THE DEFENDANT WAS FOUND TO HAVE MOVED. (PER RESIDENT) 08/25/2014 I, RICHARD P KEUERLEBER, SHERIFF, WHO BEING DULY SWORN ACCORDING TO LAW, STATES HE MADE DILIGENT SEARCH AND INQUIRY FOR THE WITHIN NAMED DEFENDANT TO WIT: JESSICA BRADY, BUT WAS UNABLE TO LOCATE THE DEFENDANT IN HIS BAILIWICK. THE SHERIFF THEREFORE RETURNS THE WITHIN REQUESTED COMPLAINT & NOTICE AS "NOT FOUND" AT 646 FISHING CREEK ROAD, NEW CUMBERLAND, PA 17070. PER POST OFFICE CHECK, MAIL IS DELIVERED TO ADDRESS GIVEN. SHERIFF COST: $41.89 September 22, 2014 RICHARD P KEUERLEBER, SHERIFF Affirmed and subscribed to before me this 22ND day of SEPTEMBER NOTARY 2014 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sheila E. Cook, Notary Public City of York, York County My Commission Expires Feb. 1, 2017 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES (c) CourllySuiLe Sher€f1, Tetecsa=t_ tnc:.