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Home My WebLink About05-5330 File #03-05-207 LAW OFFICES OF STEWART C. CRAWFORD BY: Stewart C. Crawford, Esquire ATTORNEY J.D. #09827 223 North Monroe Street P.O. Box E Media, P A ] 9063 Telephone: (610) 565-7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW ALLSTATE INSURANCE COMPANY a/s/o DOMINIC J. DePALMA, JR. 309 Lakeside Drive, Suite 100 Horsham, P A 19044 vs. GLADYS HILL 600 Willow Street, Apt. A Highspire, P A 17034 IN CIVIL LAW NO. 66-- )330 ~~ NOTICE TO DEFEND You Im\'C been sued in court. If you wish 10 defend against the claims sel forth in the tallowing 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 sel forth against you, You aTC furtner warned that ifYQU fail to do so the case may proceed without you and a judgment may he 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 UA VE A LA WYEROR (' ANNCT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU ('AN GET LEGAL HELP Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expueslas en las paginas siguientes, usled tiene veinte (20) dias de plaza al partir de \a fecl)a de la demanda y \a notificacion. Hace Faila asenUlr una comparencia escrita 0 en persona o con un abogado y entrebrar a la corte en forma sus deFensas o sus objectiones alas demandas en contra de su persona. Ses avisado que si usted no se deliende ]a corte !Omara modidas ypuede continuar ila demanda en contra suya sin previa aviso a notificacion. Ademas. ]a corte puede decidir a favor del demandanle y requiera que usted cumpia con todas las provisions de esta demanda. Usted puede perder dinero 0 sus propiedaces u alros derechos importantes para usted. USTED DEBE LLEV AR EST A A vIsa A UN A80GADO ENESEQUIDA. SI USTED NO TIENE UN A80GADO Y NO PUEDEPAGAR LOS SERVICIOS DE UN ABOGAOO. DEBE COMUNICARSE CON LA SIGUIENTE OFICINA PARA A VERIGUAR OONDE PUEDE ORTENER A YUDA LEGAL. Cumberland County Court of Common Pleas Court Administrator One Courthouse Square Carlisle, PA 17013 (717) 240-6200 File #03-05-207 LAW OFFICE OF STEW ART C. CRAWFORD & ASSOCIATES BY: Stewart C. Crawford, Esquire ATTORNEY I.D. NO. 09827 223 North Monroe Street Attorney for Plaintiff Media, P A 19063 Telephone: (610) 565-7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW ALLST ATE INSURANCE COMP ANY a/s/o DOMINIC J. DePALMA, JR. 309 Lakeside Drive, Suite 100 Horsham, P A 19044 IN CIVIL LAW NO. 05- 3' 33t:> (i.;;J -r ~ vs. GLADYS HILL 600 Willow Street, Apt. A Highspire, P A 17034 COMPLAINT Motor Vehicle Property Damage 1. Plaintiff is an insurance company licensed and authorized to do business in the Commonwealth of Pennsylvania with one of its principle places of business at the above-captioned address. 2. Defendant, Gladys Hill, was the operator of a motor vehicle involved in an incident on August 31, 2004, and at all times pertinent hereto resided at the above-captioned address. 3. On the aforesaid date, Plaintiff had a policy of insurance with Dominic J. DePalma, Jr., hereinafter referred to as named insured. 4. On the aforesaid date, a motor vehicle insured by Plaintiff, hereafter the insured vehicle was involved in an incident with Defimdant. 5. On the aforesaid date, the insured vehicle was stopped facing southbound on Route 83 in the right lane at or near the Camp Hill exit in Camp Hill, Pennsylvania, when the Defendant, who was traveling southbound on Route 83 directly behind a vehicle that was traveling behind the insured vehicle, failed to maintain a safe following distance and to avoid rear ending the vehicle in front of her, she veered onto the shoulder of the road and careened back, striking the insured vehicle on the passenger side causing damage. 6. The Defendant was negligent and careless and the sole cause of this incident in that Defendant: (a) operated the vehicle at an unsafe rate of speed; (b) was inattentive; (c) failed to make proper observation; (d) violated local laws and the laws of the Commonwealth of Pennsylvania. 7. Pursuant to the aforesaid policy of insurance, Plaintiff became liable for damages that arose out of this accident. 8. Due to this incident, expenses were incurred for damage to the insured vehicle, towing, storage and car rental. 9. Pursuant to the aforesaid policy of insurance, the Common Law and governing statutes, Plaintiff is subrogated for all money paid and seeks recovery of these sums totaling $5,678.12. WHEREFORE, Plaintiff demands judgment for $5,678.12 plus interest and costs of suit. 2 Date: VERIFICATION The undersigned hereby states that he is an authorized agent of Plaintiff insurance company in this action and verifies that the statements contained in the foregoing Complaint are true and correct. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. /(i/?ir . . ART C. C Attorney for Plaintiff 3 ~ "rV ~ (- ...\r -~ ~""""'. ~ ~~~ Co Y ffi. C C) c," l'"~." ~~:~ <J' o c:> --~ (~ C) -n .--1 ".'"~ i'/j p.,:::, :r:," .....f? L~':; \..D SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2005-05330 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ALLSTATE INSURANCE COMPANY VS HILL GLADYS R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT / to wit: HILL GLADYS but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT & NOTICE On October 24th , 2005 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin County Postage 18.00 9.00 10.00 35.25 .37 72.62 10/24/2005 STEWART CRAWFORD So answers: (... ~)~......~. ..C.... .::. .<_...,. ,--.'" ',/' ,~-' L_.'---. .,' <C.. ,,.-/,- . . R. Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this "tt:;:.. ji- day of ~ d- / '"'p~~jY In The Court of Common Pleas of Cumberhmd County, Pennsylvania Allstate Insurance Company VS. Gladys Hill No. 05-5330 civil Now, October 12, 200~ , I, SHERIFF OF CUMJ3ERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk ofthe Plaintiff. ~~~ee.c4a..R Sheriff of Cumberland County, PA Affidavit of Service Now, ,20_, at 0' clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this _ day of ,20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ -' @flite of tfp~ ~4~riff William T. Tully Solicitor Charles E. Sheaffer Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 1710 I ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania ALLSTATE INSURANCE COMPANY vs County of Dauphin HILL GLADYS Sheriff's Return No. 1774-T - -2005 OTHER COUNTY NO. 05-5330 AND NOW:October 18, 2005 at 9: OOAM served the within COMPLAINT upon HILL GLADYS by personally handing to GLADYS HILL DEFT 1 true attested copy(ies) of the original COMPLAINT and making known to him/her the contents thereof at 600 WILLOW ST APT A HIGHSPIRE, PA 17034-0000 Sworn and subscribed to So Answers, Jf~ before me this 19TH day of OCTOBER, 2005 Sheriff of Dauphin County, Pa. ~~ NOTARIAL SEAL MARY JANE SNYDER. Notary Public Highspire, Dauphin County My Commission Expires Sept. 1, 2006 ~,..". .1,L J. "'~<;, 1\,.,.4J____ ~fF--'c;,.<~~. I /.~ ...._.Y....."-.~; //> Deputy Sheriff Sheriff's Costs: $35.25 PD 10/14/2005 RCPT NO 211343 By SS 03-05-207 LAW OFFICE OF STEWART C. CRAWFORD & ASSOCIATES BY: Stewart C. Crawford, Esquire ATTORNEY J.D. #09827 223 North Monroe Street Attorney for Plaintiff P.O. Box E Media, Pennsylvania 19063 Telephone: (610) 565-7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ALLSTATE INSURANCE COMPANY aJs/o DOMINIC J. DEPALMA, JR. NO. 05-5330 v. GLADYS HILL IN CIVIL ACTION PRAECIPE FOR DEFAULT JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter a Default Judgment in favor of the Plaintiff and against the Defendant(s) GLADYS HILL in the amount of$5,678.12 for failure to Answer the Complaint in Civil Action within twenty (20) days from the date of service. I hereby certify that pursuant to Local Rule of Court, I sent Notice to Defendant of intent to take Default. See attached. i '7. it.. .... //. ,:. .... ., J~. 'Ii..., / , 111::( 1/, '.cIZa7;; ( / '-stewart C. Crawford, Esqirire Attorney lor Plaintiff J.D. #09827 ENTRY OF DEFAULT JUDGMENT AND NOW, to wit, this.;?~ 0;\)8:- , 2005 a Default Judgment is entered as above, namely in favor of the Plaintiff and against the Defend). ( ~ '. . (iJ~ . . ROTH ARY ( 03-05-207 LAW OFFICE OF STEWART C. CRAWFORD & ASSOCIATES BY: Stewart C. Crawford, Esquire ATTORNEY J.D. #09827 223 North Monroe Street Attorney for Plaintiff P.O. Box E Media, Pennsylvania 19063 Telephone: (610) 565-7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ALLSTATE INSURANCE COMPANY aJs/o DOMINIC J. DEPALMA. JR. NO. 05-5330 v. GLADYS HILL IN CIVIL ACTION NOTICE Pursuant to Rule of Civil Procedure No. 236, Notice is given that a Default Judgment and Assoment of Damages in the above-captioned matter has been entered agamst you on ~ C d.D :::J IV"-, , I 03-05-207 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION-LAW ALLSTATE INSURANCE COMPANY aJs/o DOMINIC 1. DEPALMA, JR. NO. 05-5330 v. GLADYS HILL IN CNIL ACTION AFFIDAVIT UNDER SOLDIERS' AND SAILORS' CNIL RELIEF ACT OF 1940 AS AMENDED ST ATE OF PENNSYLVANIA : SS COUNTY OF CUMBERLAND : Stewart C. Crawford, Esquire, being duly sworn according to the law that GLADYS HILL is/are not in the military service of the United States of America as defined by the Soldiers' and Sailors' Civil Relief Act of 1940 as amended; that said Defendant(s) is/are over 18 years of age and is/are employed. .C-'..I./. ~',; _ \. .v!. ~. I ki/1Jtll. /ii1U0~:1~ / . Stewart C. Crawford, ES9l;i).te Attorney for Plaintiff #01[827 Sworn to and subscribed Before me this /51-1\.. day Of /}w}// mi 2005, :if{JJJ f(jj:7)-- ARY _.~)~,~h'IU.NWf_^...(h Qi peNNS','LVANIA. NOTARIAL SEAl. SUSAN E HOST Notary Public Madia Bora Delaware County My CommiS$1OO expires May 17. 2\XJl 03-05-207 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW ALLSTATE INSURANCE COMPANY aJs/o DOMINIC J. DEPALMA, JR. NO. 05-5330 v. GLADYS HILL IN CIVIL ACTION AFFIDAVIT OF MAILING NOTICE COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF CUMBERLAND Stewart C. Crawford, Esquire, being duly sworn according to law, deposes and says that he is attorney for Plaintiff and that on November 28, 2005 he sent by certified mail, return receipt requested, to the Defendant(S) GLADYS HILL the repair estimate, together with a notice that damages would be assessed on or after December 12, 2005 in the amount of the repair estimate unless prior to that date the Defendant(s) had, by written Praecipe, filed with the Prothonotary a request for trial on the issue of damages. . 'I ., \ ~ /;f1I.... I \ / ,'. "I), /',-1,1 ) . /1' ,//:{ ff;?2 .Stewart C. Crawford, EMuire Attorney for Plaintiff(s) / Sworn to and Subscribed Before me this /[,1-4.. day OftW.M,OJl,2005. /(j;)f// Pril NOTARY f C0MMONW~~~:~I~: ;~~NSYL.VAN'A I SUSAN E HOST Notary Publtc Media 80m Delaware County I My Conmssion Exptres May 17, 2tnl 03-05-207 LAW OFFICE OF STEWART C. CRAWFORD & ASSOCIATES BY: Stewart C. Crawford, Esquire ATTORNEY J.D. # 09827 223 North Monroe Street ATTORNEY FOR PLAINTIFF Media, PAl 9063 Telephone: (610) 565-7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW ALLSTATE INSURANCE COMPANY alslo DOMINIC J. DEPALMA, JR. IN CIVIL ACTION VS. GLADYS HILL NO: 05-5330 CIVIL TO: GLADYS HILL 600 WILLOW STREET APT. A HIGHSPlRE, PA 17034 DATE OF NOTICE: NOVEMBER I 1,2005 IMPORTANT NOTICE You are in default because you have failed to take action required of you in this case. Unless you act within Ten (10) Days from the date of this notice, a Judgment will be entered against you without a hearing and you may lose property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or can not afford one, go to or telephone the following office to find out where you can get legal help: Cumberland County Lawyer Referral Service Taryn Dixon, Court Administrator One Courthouse Square Carlisle, PAl 70 13 (7 I 7) 240-6200 STEWART C. CRAWFORD, ESQ. Attorney for Plaintiff(s) @ffitr of t11I~ ~4eriff William T. Tully Solicitor Charles E. Sheaffer Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania ALLSTATE INSURANCE COMPANY vs County of Dauphin HILL GLADYS Sheriff's Return No. 1774-T - -2005 OTHER COUNTY NO. 05-5330 AND NOW:October 18, 2005 at 9:00AM served the within COMPLAINT upon HILL GLADYS by personally handing to GLADYS HILL DEFT 1 true attested copy(ies) of the original COMPLAINT and making known to him/her the contents thereof at 600 WILLOW ST APT A HIGHSPIRE, PA 17034-0000 Sworn and subscribed to So Answers, JR~ before me this 19TH day of OCTOBER, 2005 Sheriff of Dauphin County, Pa. ~~ By / P Jco.JJ- A _~'d,o.~d-- ~ ~j Deputy Sheriff Sheriff's Costs: $35.25 PD 10/14/2005 RCPT NO 211343 NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County My Commission Expires Sept. 1,2006 SS '>;;C> (":> u u. T\t- ~l1-1t:.. r ~ ~ ~ ~~ ~~ -lLj. :-0 \) \Y ~ g -.....L C) C~ <--> ,:~;;:. r.."::::J -::]'1 (-=' f" e, N C;:) ~, o -n ..... :L-n f\1r~ ~L!,tS : ~~,/) or; ""1'\ (' in r'0 ~'-'-1 :-is .-< c:::J \ '", . 03-05-207/mvg LAW OFFICE OF STEWART C. CRAWFORD BY: Stewart C. Crawford, Esquire ATTORNEY I.D. #09827 223 North Monroe Street P.O. Box E Media, Pennsylvania 19063 Telephone: (610) 565-7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW ALLSTATE INSURANCE CO. A/S/O DOMINIC J. DEPALMA, JR. 05-5330 VS. GLADYS HILL IN CIVIL ACTION STIPULATION TO RE-INSTATE DRIVING PRIVILEGES TO THE PROTHONOTARY: It is hereby STIPULATED by the parties through the undersigned, that the driving privileges of GLADYS BILL be reinstated and remain so as long as the defendant abides by the terms of the attached Conditional Release. If the defendant fails to keep payments up to date, her driving privileges will then be suspended. ~CJ STEWART C. CRAWFORD, ES Attorney for Plaintiff ;Jtffi .. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE RE: ALLSTATE A/S/O DEPALMA VS. HILL OUR FILE# 03-05-207 CT# 05-5330 CONDITIONAL RELEASE WHEREAS GLADYS HILL (hereinafter referred to as Defendant(s)} of 600 WILLOW STREET, APT. A, HIGHSPIRE, PA 17034 is indebted to ALLSTATE INSURANCE COMPANY (hereinafter referred to as Plaintiff (s)) in the sum of $5,678.12 (full indebtedness sum) because of damages negligently caused to the Plaintiff and/or Plaintiff's insured(s) on or about AUGUST 31, 2004 at or near ROUTE 83, CAMP HILL, PA. WHEREAS the Safety Responsibili ty Division of the Department of Transportation of the Commonwealth of pennsylvania has revoked the operating privileges of the said Defendant(s) and WHEREAS Plaintiff is willing to accept payments of the said indebtedness in monthly installments. NOW, THEREFORE, it is agreed by and between Plaintiff and Defendant (s) that for and in consideration of the sum of $5,678.12 receipt whereof is hereby acknowledged, and in consideration of the payment of $50.00 per month between the first and last day of each month after the date hereof until the sum of $5,678.12 shall have been paid, Plaintiff has released Defendant (s) from any and all responsibility arising out of a collision of a motor vehicle owned and/or operated by Defendant(s) and damages sustained by Plaintiff. In the event that Defendant should fail in making payments as set forth above, the entire unpaid balance of the Settlement Sum shall immediately become due and owing at the option of the Plaintiff, who explicitly reserves the right to continue prosecution of its claim/enforcement of its Judgment for the aforementioned full indebtedness sum in lieu of enforcement of the Settlement Agreement recited in the preceding paragraph. Gr P[N~\;8YtVA.N~r~> !VdIV'ihL SUIt -1 MIL[JI'[~~~ :','f:I!)ON(;f)O, Noti'lry f-'i.mlie ~ do"" Dauphi\; CC.\:I,;~V ~ L0nlJm$~:'i.G~ fYi'1ire$ Sept. 10. /OlO ~ - ,,-..-.--.-.-...., --_..~_._..._-~ hand and ,2007. IN WITN~SS: wner~of, the parties hereunto ha e seal Shls \,.J\~Y(/~ day of 3 f1r-l4D~~G WITNESS IF YOUR PAYMENT IS NOT RECEIVED BY THE END OF EACH MONTH THERE IS A $5.00 LATE CHARGE, $10.00 MISSED PAYMENT CHARGE AND $25.00 FOR EACH BOUNCED CHECK. THIS WILL BE CALCULATED EACH AND EVERY MONTH AND ALL CHARGES MUST BE PAID IN FULL BEFORE CASE CAN BE CONCLUDED. ~ ';3 ~ ?J ~ ~:Q \ ,. r-: - ~q o <'2)S~~~ i.:')~ 7\..~ :,:~t\ o ~ ~ ~ ~ - -