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Home My WebLink About05-5901 File #07-05-557 LAW OFFICES OF STEW ART C, CRAWFORD BY: Stewart C. Crawford, Esquire ATTORNEY J.D. # 09827 223 North Monroe Street P,O. Box E Media, P A 19063 Telephone: (610) 565-7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION-LAW ALLSTATE INSURANCE COMPANY a/s/o RONALD POTTER 309 Lakeside Drive, Suite 100 Horsham, P A 19044 vs. RAYMOND S, HOLLOWAY, JR. 39 Mountain Road Carlisle, PA 17013 IN CIVIL LAW NO. O~ - SCf6{ Clu;L~~~ NOTICE TO DEFEND You have been sued in court. I[you wish to defend against the claims sel forth in the following pages, you must take action within twenty (20) days after this Complaint and nolice 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 furtherwamed 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 fOf 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 LA WYER AT ONCE. IF YOU DO NOT HAVE A LA WYEROR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plaza al partir de la fecha de la demanda y la notifieaeion. Haee faita asentar una comparencia escrita 0 en persona o con un ahogado y entre gar a la corte en forma sus defensas o sus ohjectiones alas demandas en contra de su persona. Ses avisado que si usted no se defiende la corte tomara modidas ypuede continuar ila demanda en contra suya sin previo aviso 0 notificacioll. Ademas, la corte puede decidir a favor del demandante y requiera que usted cumpia con todas las provisions de esta demanda. Uslcd puede perder dinero 0 sus propiedaces u otros derechos importantes parausted. USTED DEBE LLEV AR ESTA A VI SO A UN ABOGADO ENESEQUIDA. 51 U5TED NO TIENE UN ABOGADO Y NO PlJEDEPAGAR LOS SERVICI0S DE UN ABOCiADO, DEBE COMUNICAR5E CON LA SIGUIENTE OFlCINA PARA A VERIGUAR DONDE pUEDE OBTENER A YUDA LEGAL Cumberland County Court of Common Pleas Court Administrator One Courthouse Square Carlisle, PA 17013 (717) 240-6200 File #07-05-557 LAW OFFICE OF STEWART C, CRAWFORD & ASSOCIATES BY: Stewart C. Crawford, Esquire ATTORNEY J.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 ALLSTATE INSURANCE COMPANY als/o RONALD POTTER 309 Lakeside Drive, Suite 100 Horsham, P A 19044 IN CIVIL LAW NO. Dr; - /,-90/ c ,;,l ~ tA...>rj vs, RAYMOND S. HOLLOWAY, JR. 39 Mountain Road Carlisle, P A 17013 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, Raymond S, Holloway, Jr., was the operator of a motor vehicle involved in an incident on October 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 Ronald Potter, 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 Defendant. suit. 5. On the aforesaid date, the insured vehicle was traveling westbound on Route 114 in Mechanicsburg, Pennsylvania, in the right lane and merged into the left lane when the Defendant, who was traveling westbound on Route 114 in the left lane, carelessly struck the insured vehicle 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 $2,429.00. WHEREFORE, Plaintiff demands judgment for $2,429,00 interest and costs of ( 2 VERIFICATION The undersigned hereby states that he is an authorized agent of PlaintitY 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. 11'/ ./ .'J" Date:~ 3 0 ~ ,-' ~ 7J U/ C::".::.< \ ,.~";1 C..f' ~ !.0 c::; ....':-. L0 ~ ~ \>e) .!;; .:{ _.~:} \) U{ ~ -"" es. --::t (:'? :g - ~ c. --.L.... /-/---- File #07-05-557 LAW OFFICES OF STEW ART C, CRAWFORD BY: Stewart C, Crawford, Esquire ATTORNEY J.D. # 09827 223 North Monroe Street P.O. Box E Media, P A 19063 Telephone: (610) 565-7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION-LAW ALLSTATE INSURANCE COMPANY a/s/o RONALD POTTER 309 Lakeside Drive, Suite 100 Horsham, P A 19044 IN CIVIL LAW NO.: 05-5901 Civil Term vs. RAYMOND S, HOLLOWAY, JR. 39 Mountain Road Carlisle, P A 17013 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate this Complaint an additional thirty (30) days. Dated: 4f~ ~ / ~, ~-' WARTC~pn~ffi> Attomey for Plaintiff SHERIFF'S RETURN - REGULAR CASE NO: 2005-05901 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ALLSTATE INSURANCE COMPANY VS HOLLOWAY RAYMOND S JR SHARON LANTZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HOLLOWAY RAYMOND S JR the DEFENDANT , at 1548:00 HOURS, on the 3rd day of May , 2006 at 4005 RIDER LANE MECHANICSBURG, PA 17055 by handing to RAYMOND S HOLLOWAY JR a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 21.12 .00 10.00 .00 49.12 .:r'~~"'~~ R. Thomas Kline 05/04/2006 STEWART CRAWFORD me this II {It day of M O-~~p Pro ota A.D. Sworn and Subscribed to before By: , I 07-05-557 LAW OFFICE OF STEW ART C. CRAWFORD & ASSOCIATES BY: Stewart C. Crawford, Esquire ATTOR,.l\fEY LD. #09827 223 North Monroe Street Attorney for Plaintiff P.O. Box E Media, Pennsylvani.a 19063 Telephone: (610) 565-7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PE1\TNSYL VANIA CIVIL ACTION - LA W ALLSTATE INSURANCE COMPANY alslo RONALD POTTER NO.: 05-5901 v. RAYMOND S. HOLLOWAY, JR. IN CIVIL ACTION PRAECIPE FOR DEF AUL T JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter a Default Judgment in favor of the Plaintiff and against the Defendant(s) RAYMOND S. HOLLOW A Y, JR. in the amount of $2,429.00 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. s~~~ Stewart C. Crawford, Esquire Attorney for Plaintiff I.D. #09827 ENTRY OF DEFAULT JUDGMENT AND NOW, to wit, this day of ,2006 a Default Judgment is entered as above, namely in favor of the Plaintiff and against the Defendant. ARY 07-05-557 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW ALLSTATE INSURANCE COMPANY alslo RONALD POTTER NO.: 05-5901 v. RAYMOND S. HOLLOWAY, JR. IN CIVIL ACTION AFFIDAVIT OF MAILING NOTICE COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE Stewart C. Crawford, Esquire, being duly sworn according to law, deposes and says that he is attorney for Plaintiff and that on June 13,2006 he sent by certified mail, return receipt requested, to the Defendant(S) RA YMOND S. HOLLOWAY, JR. the repair estimate, together with a notice that damages would be assessed on or after June 27,2006 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. ~AAJJlAt C S wart: C. Crawford, Esquire Attorney for Plaintiff(s) Sworn to and Subscribed Befo;:~e this f>K,- day Of &1#-, 2006. ~/f~ .. ALTH Of' PENNIIYLVANfA NOTAAJAl SEAL GINA M V~J;HocIry PubIc . Medi;I SOra., Del.... County ~ CommissIon e'F .c. 2OtO J;.";. " 07-05-557 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION-LAW ALLSTATE INSURANCE COMPANY als/o RONALD POTTER NO.: 05-5901 v. RAYMOND S. HOLLOWAY, JR. IN CIVIL ACTION AFFIDAVIT UNDER SOLDIERS' AND SAILORS' CIVIL RELIEF ACT OF 1940 AS AMENDED STATE OF PENNSYLVANIA: SS COUNTY OF DELAWARE Stewart C. Crawford, Esquire, being duly sworn according to the law that RAYMOND S. HOLLOWAY, JR. 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. s ( Sworn to and subscribed BefoAe.0tfte }his Sy? day Of (!!~- 2006. ,/ /I..~I/ f/ j{fS~.'/ l~TARY . . . File #07-05-557 LAW OFFICE OF STEW ART C. CRAWFORD & ASSOCIATES BY: Stewart C. Crawford, Esquire ATTORNEY LD. # 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, PENNSYLVANIA CIVIL ACTION-LAW ALLSTATE INSURANCE COMPANY alslo RONALD POTTER N CIVIL ACTION VS. RAYMOND S. HOLLOWAY, JR. NO. 05-5901 CIVIL TERM TO: RAYMOND S. HOLLOWAY, JR. 4005 RIDER LANE MECHANICSBURG, PA 17055 DATE OF NOTICE: MAY 24, 2006 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 fmd out where you can get legal help: Cumberland County Lawyer Referral Service Taryn Dixon, Court Administrator One Courthouse Square Carlisle, P A 17013 (717) 240-6200 STEWART C. CRAWFORD, ESQ. Attorney for Plaintiff( s ) SHERIFF'S RETURN - REGULAR , , CASE NO: 2005-05901 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ALLSTATE INSURANCE COMPANY VS HOLLOWAY RAYMOND S JR SHARON LANTZ , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HOLLOWAY RAYMOND S JR the DEFENDANT , at 1548:00 HOURS, on the 3rd day of May at 4005 RIDER LANE , 2006 MECHANICSBURG, PA 17055 by handing to RAYMOND S HOLLOWAY JR a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 21.12 .00 10.00 .00 49.12 .~~~ , j R. Thomas Kline 05/04/2006 STEWART CRAWFORD A.D. Sworn and Subscribed to before By: me this day of Prothonotary OJJ -- r~ Ij. I-W~ G 7':) ~ ~ 1L ^ ~ ~ \l D - C> r ........ """-- C' " " ~ ~ I ~_. ......,1 c..~ '11 t= ~ ' ,.-', ---1 j _-rr. 0 ::1 IV -=i -.... -- J - f'"" E: -...... -"'.," -.- (' -- .- .- c; - ~ ' 07-05-557 LAW OFFICE OF STEWART C. CRAWFORD & ASSOCIATES BY: Stewart C. Crawford, Esquire ATTORNEY I.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 - LA W ALLSTATE INSURANCE COMPANY a/s/o RONALD POTTER NO.: 05-5901 v. RAYMOND S. HOLLOWAY, JR. IN CIVIL ACTION NOTICE Pursuant to Rule of Civil Procedure No. 236, Notice is given that a Default Judgment and AS\1sment of Damages in the above-captioned matter has been entered against you on - €..F II i :l t:;Xj~ , (!~~t PR6THONOTARY Stewart C. Crawford LAW OFFICE OF STEWART C. CRAWFORD & ASSOCIATES 223 NORTH MONROE STREET P. O. BOX E MEDIA, P A 19063 E-MAIL ADDRESS:SCCRAWFORD@SUBROLAW.US Tel: (610) 565-7050 Fax: (610) 565-5348 Leslie S. Britt Admitted in PA & NJ June 13, 2006 MR RAYMOND S. HOLLOWAY, JR. 4005 RIDERS LN MECHANICSBURG P A 17055-5582 Re: Allstate Insurance Company a/s/o Ronald Potter v. Raymond s. Hollow1iY, Jr. C.CP. - Cumberland County - No.: 05-5901 Civil Term Our file: 07-05-557 Dear Mr. Holloway: Please be advised that I represent Allstate Insurance Company alslo Ronald Potter concerning property damage to his vehicle that occurred on October 31, 2004. I enclose herewith a copy of the Affidavit of Repainnan, together with the appraisal indicating that the cost to repair the insured's property totals $2,429.00. I intend on filing a Praecipe for Assessment of Damages under Pennsylvania Rules of Civil Procedure No.1 037 and have the Prothonotary assess damages in that amount on June 27,2006, unless prior to that date, by written Praecipe, you file with the Prothonotary a request for trial on the issue of damages. Very truly yours, ~~!/a1~ SCC/lg Enclosure f'i/J- FILE # 07-05-557 IN THE COURT OF COMMON PLEAS OF COUNTY, PA CNIL ACTION-LAW ALLSTATE INSURANCE CO. a/s/o RONALD E. POTTER VS. RAYMOND S. HOLLOWAY, JR. IN CNIL LAW AFFIDAVIT OF VALUE OF REPAIRMAN Under PRCP # 1037 (b) (2) (ii) THE REPAIRMAN'S AFFIDAVIT rll{' fill E {.. lit L b'1<-- , duly being sw rn }lccording to law, deposes and says that he/she is a claim representative for I J .-! insurance company and has for many years, reviewed ap aisals and estimates and damage documents on property and that the repairs itemized on the attached estimate were necessary to restore the property of the owner to the condition which existed immediately preceding the damage and that the prices set forth on the estimate for parts and labor were fair and reasonable and customarily charged at the time the attached repair estimate was prepared; or that the property was a total loss and the attached sheets correctly state the value of the property at the time of loss, less any salvage value. That the attached repair estimate was prepared by a qualified and licensed estimator or field claim representative. 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' ~ H cnc::t' HO HO HC't 0- UM 0 ('f'l <I ~- 0 00 r- I.\.t""" """ ,V1.\.t ~ a 0 Pol d) U ~~ \0 - ~~ P4H ~~ .' 01 ~H a ~\ .'" '0 ~ 0 ~ II) Q) II) II) Q) ro ~ d) ''if ,4 1 ~ oj? ~ " " r~ ----" (717) 540-7500 ALLSTATE INSURANCE,COMPANY HARRISBURG MCO ' 6345 FLANK DRIVE HARRISBURG, PA 17112 SUPPLEMENT HOTLINE: (800) 726-8890 EXT.7580 CD LOG NO 1187 -0 11-04-04 9:33 AM ESTIMATE CLAIM INFORMATION CLAIM # 1554996410D01 COMPANY ALLSTATE INSURANCE COMPANY INSURED POTTER, RONALD E CLAIMANT POLICY # 008293529 CLAIM REP LOSS DATE 10-31-04 LOSS TYPE COLLISION I!'JSPECTION TYPE PRIMARY POI APPRAISER NAME LICENSE # WORK PHONE ADDRESS CITY STATE ZIP DRIVE IN LEFT QUARTER PANEL DK ERB 151887 (800) 726-8890 6345 FLANK DR HARRISBURG 17112- SECOND POI FAX INSP DATE LOCATION CITY STATE (800) 541-8196 11-04-04 WEST SHORE PA OWNER POTTER, RONALD E 60 GREEN PARK RD GREEN PARK PA 17024-9074 WORK# HOME#(717) 789-3917 REPAIR SHOP PHONE (717) 789-3109 SHOP LIC# CAR IN CAR OUT REPAIR DAYS REG.ID 23-2214890 FAX ATTN MILT MILT'S BODY SHOP RD 1 BOX 816C LANDISBURG PA 17040- '-- VEHICLE 2001 FORD TAURUS SES 4 DR SEDAN 6CYL GASOLINE 3.0 FLEX OPTIONS TWO-STAGE - EXTERIOR SURFACES KEYLESS ENTRY SYSTEM ANTI-LOCK BRAKE SYSTEM DRIVER POWER SEAT POWER DOOR LOCKS CRUISE CONTROL DDC0164 PA MILEAGE VIN CODE VEH INSP # 50,494 1FAFP552X1A246763 P353 BODY COLOR CONDITION LICENSE # LICENSE STATE WHITE REMARKS: ATTN REPAIR FACILITY:ALL SUPPLEMENT REQUESTS MUST BE PLACED THROUGH 1-800-726-8890X7580. FAILURE TO DO SO WILL RESULT IN NON-PAYMENT OF NON -1- (- , 2'001' FORD TAURUS SES 4 DR SEDAN CLAIM # 1554996410D01 LOG 1187 -0' 11-04-04 9:33 AM APPROVED REQUESTS. ALL SUPPLEMENTS MUST BE APPROVED BEFORE REPAIRS. PLEASE DO NOT CALL ADJUSTER. INSPECTED IN RAIN OP CODES: * == USER-ENTERED VALUE E = REPLACE OEM EC == COMPETITIVE PART UC = RECONDITIONED PRT EU == RECYCLED PART EP = COMPETITIVE PART PM == PXN REMAN/REBUILT TE = PARTL REPL PRICE IT == PARTIAL REPAIR I = REPAIR BR == BLEND REFINISH TT = TWO-TONE SB == SUBLET N = ADDITIONAL LABOR P == CHECK AA APPEAR ALLOWANCE UP == UNRELATED PRIOR OP GDE MC DESCRIPTION MFR. PART NO. ----------- ------------ RI EU E L LT BLEND REFINISH 0.8 Blend 0.6 Two-stage setup 0.4 Two-stage PANEL, QUARTER LT RECYCLED PART PARTS AT NEW CUMBERLAND AUTO PARTS 774-1190 PANEL, QUARTER LT REFINISH 2.2 Surface 1.0 Edge 0.4 Two-stage >>REFINISH TIMES INCLUDE: COLOR, BLEND, CLEAR 0383 MAST,ANTENNA QTR PN LT R&I ASSEMBLY 0533 TAILLAMP ASSEMBLY LT RECYCLED PART 0566 COVER,REAR BUMPER 2F1Z17K835CA 0566 tOVER,REAR BUMPER REFINISH 2.6 Surface 0.5 Two-stage SUPT,RR BUMPER COVE LT 3F1Z17D995AA FLEX ADDITIVE COMPETITIVE PART CAR COVER SUBLET PINSTRIPE-TAPE SUBLET 4 WHEEL ALIGNMENT SUBLET >>LABOR TIMES INCLD R&I NECESSARY TRIM HAZ MAT SUBLET ROUGH PULL & ALIGN ADDITIONAL LABOR TRIM LKQ 1/4 PANEL REPAIR BR 0287 DOOR SHELL,REAR EU 0389 >>LKQ L 0389 E EC SB SB , SB 0342 M03 SB N I 15 ITEMS FINAL CALCULATIONS & ENTRIES PARTS GROSS PARTS OTHER PARTS PAINT MATERIAL ADJUSTMENTS MARKUP DISCOUNT -2- NG = REPLACE NAGS UM ::::: REMAN/REBUILT PRT PC == PXN RECONDITIONED ET ::::: PARTL REPL LABOR L ::::: REFINISH CG ::::: CHIPGUARD RI R&I ASSEMBLY RP ::::: RELATED PRIOR PRICE AJ% B% HOURS R ----- ----- - 1.8 4 350.00* +25 18.6 1 3.6 4 75.00* +25 253.21 0.2 1 INC 1 0.2 1 3.1 4 18.45 6.00* 5.00* 10.00* 49.95* 0.2 1 4 1 0.3*1* 1 3.00* 1 2.0*3* 3.0*1* $ $ $ 271.66 431.00 161.50 " ;' ioOl'PORD TAURUS SES 4 DR SEDAN CLAIM: # 1554996410D01 LOG 1187 -0' LINE ITEMS $ 106.25 PARTS TOTAL TAX ON PARTS & MATERIAL @ 6.000% 11-04-04 9:33 AM $ $ 970.41 58.22 LABOR 1-SHEET METAL 2-MECH/ELEC 3-FRAME 4-REFINISH 5-PAINT RATE $ 38.00 $ 38.00 $ 38.00 $ 38.00 $ 19.00 REPLACE HRS REPAIR HRS 19.2 3.3 $ 2.0 $ 8.5 $ 855.00 76.00 323.00 LABOR TOTAL TAX ON LABOR TAX ON SUBLET SUBLET REPAIRS TOWING STORAGE @ 6.0,00% @ 6.000% $ 1,254.00 $ , 75.24 $ 4.08 $ 67.95 GROSS TOTAL LESS: DEDUCTIBLE $ 2,429.90 $ 500.00- ~lS 1 7'J:-r2--HAR.1n SBURG NET TOTAL PXN Y/OO/OO/OO/OO/OO CUM 00/00/00/00/00 Geocode: SPPL Yes Geocode: 17112 HBG ADP PENPRO W0405 ES LOGl187 -0 11-04-04 09:48:18 REL (C) 1983 - 2003 ADP CLAIMS SOLUTIONS GROUP, 4.05 SW07/04 DT10/04 INC. 1.9 HRS WERE ADDED TO THIS EST. BASED ON ADP'S TWO-STAGE REFINISH FORMULA. IMPORTANT INFORMATION ABOUT ALLSTATE'S CHOICE OF PARTS POLICY THIS ESTIMATE MAY LIST PARTS FOR USE IN THE REPAIR OF YOUR VEHICLE THAT ARE MANUFACTURED BY A COMPANY OTHER THAN THE ORIGINAL MANUFACTURER OF YOUR VEHICLE. THESE PARTS ARE COMMONLY REFERRED TO AS AFTERMARKET PARTS OR COMPETITIVE PARTS, AND MAY INCLUDE COSMETIC OUTER BODY CRASH PARTS SUCH AS . HOODS, FENDERS, BUMPER COVERS, ETC. ALLSTATE GUARANTEES THE FIT AND CORROSION RES ISTANCE OF ANY AFTERMARKET/COMPETITIVE OUTER BODY CRASH PARTS THAT ARE LISTED ON THIS ESTIMATE AND ACTUALLY USED IN THE REPAIR OF YOUR VEHICLE FOR AS LONG AS YOU OWN IT. IF A PROBLEM DEVELOPS WITH THE FIT OR CORROSION RESISTANCE OF THESE PARTS, THEY WILL BE REPAIRED OR REPLACED AT ALLSTATE'S EXPENSE. THIS GUARANTEE IS LIMITED TO THE REPAIR OR REPLACEMENT OF THE PART. HOWEVER, IF YOU CHOOSE NOT TO USE ONE OR MORE OF THE AFTERMARKET/COMPETITIVE OUTER BODY CRASH PARTS THAT MAY BE LISTED ON THIS ESTIMATE IN THE REPAIR OF YOUR VEHICLE, ALLSTATE WILL SPECIFY THE USE OF ORIGINAL EQUIPMENT MANUFACTURER PARTS, EITHER NEW OR RECYCLED AT ALLSTATE'S OPTION, AT NO ADDITIONAL COST TO YOU. ALLSTATE DOES NOT SEPARATELY GUARANTEE THE PERFORMANCE OF ORIGINAL EQUIPMENT MANUFACTURER PARTS, AND MAKES NO REPRESENTATION ABOUT THE AVAILABILITY OF ANY MANUFACTURER'S GUARANTEE. ------------------------------------------------------------------------------- -3- . , (- c ,- , . '! 2001'FORD TAURUS SES 4 DR SEDAN CLAIW # 1554996410D01 LOG 1187 -0' Estimate Summary Page DK ERB GROSS TOTAL $ 2,429.90 LESS: DEDUCTIBLE $ ~QJ)'c'-PO- NET TOTAL $/---1,929. 9h ADP PENPRO W04 05 ES LOG1187 - 0 11- 04 - 04 09: 48: 18 RE-b--4";-05--swb 7/04 DT1 0/04 (C) 1993 - 2003 ADP CLAIMS SOLUTIONS GROUP, INC. TO ALL REPAIR FACILITIES: BEFORE USING AN AFTERMARKET SHEETMETAL PART, BE SURE TO LOOK FOR THE CAPA SEAL. THIS IS NOT AN AUTHORIZATION FOR REPAIR. SUPPLEMENTS MUST BE APPROVED PRIOR TO REPAIR. IF YOUR CAR IS OF UNITIZED CONSTRUCTION, IN SOME CASES THE REPAIR SHOP MAY NEED SPECIAL EQUIPMENT TO PROPERLY REPAIR THE CAR. YOU SHOULD DETERMINE IF THE SHOP YOU SELECT TO . COMPLETE THE REPAIRS IS PROPERLY_EQUIPPED. 11-04-04 9:33 AM ALLSTATE WILL NOT BE RESPONSIBLE FOR ANY RELATED TOWING SERVICES OR STORAGE CHARGES, KNOWN AT THE TIME OF APPRAISAL, AFTER of; , AFTER WHICH THE CHARGES WILL BE THE RESPONSIBILITY OF THE CONSUMER. ~ THIS ESTIMATE 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. WARRANTIES APPLICABLE TO AFTERMARKET CRASH PARTS ARE PROVIDED BY THE MANUFACTURER OR THE DISTRIBUTOR OF THESE PARTS NOT THE ORIGINAL MANUFACTURER OF YOUR VEHICLE. ANY PERSON WHO KNOWLINGLY AND WITH INTENT TO INJURE OR DEFRAUD ANY INSURER FILES AN APPLICATION OR CLAIM CONTAINING FALSE, INCOMPLETE OR MISLEADING INFORMATION SHALL, UPON CONVICTION, BE SUBJECT TO IMPRISONMENT FOR UP TO SEVEN YEARS AND PAYMENT OF A FINE UP TO $15,000 IT IS TO OUR MUTUAL INTEREST THAT YOU RECEIVE PROMPT AND COURTEOUS SERVICE ALONG WITH QUALITY REPAIR WORK AT A FAIR PRICE. IF YOU HAVE A PREFERENCE FOR A PARTICULAR SHOP, YOUR ADJUSTER WILL WRITE OR APPROVE AN ESTIMATE OF REPAIRS WITH THAT SHOP BASED ON COMPETITIVE PRICES IN THE AREA. INFORMATION REGARDING REPAIR FACILITIES, WHICH MAY BE ABLE TO REPAIR THE VEHICLE FOR THE APPRAISED AMOUNT, IS AVAILABLE FROM YOUR ADJUSTER OR INSURER. HOWEVER, THERE IS NO REQUIREMENT TO USE ANY SPECIFIED SHOP. COSTS ABOVE THE APPRAISED AMOUNT MAY BE THE RESPONSIBILITY OF THE VEHICLE OWNER. ALL SUPPLEMENTS MUST BE APPROVED PRIOR TO REPAIR. AFTERMARKET CRASH PARTS ARE IDENTIFIED IN THIS ESTIMATE WITH THE SYMBOL "EC", IEP" (COMPETITIVE PART) AND "EU" (RECYCLED PART) AN "AFTERMARKET CRASH PART" IS A NON-ORIGINAL MANUFACTURER (NON-OEM) REPLACEMENT PART, EITHER NEW OR USED, FOR ANY OF THE NON-MECHANICAL PARTS THAT GENERALLY CONSTITUTE THE EXTERIOR OF THE MOTOR VEHICLE, INCLUDING INNER AND OUTER PANELS. NEW, ORIGINAL EQUIPMENT MANUFACTURER, REPLACEMENT PARTS ARE IDENTIFIED BY THE -4- . . ( , 2001 'FO&D,TAURUS SES 4 DR SEDAN CLAIMr # 1554996410D01 LETTER "E" AND CAN BE LOCATED AT DEALER. ADJUSTER cA( b rJ . LOG 1187 . -0' . 11-04-04 9:33 AM THE ORIGINAL EQUIPMENT MANUFACTURER PARTS LICENSE # / S (0-81 DATE (( ~Oi~ P ( -5- ( , '.-::3 \~ \:::... " i. :.1 ~. ' 07-OS-557/djh THE LAW OFFICES OF STEWART C By: Stewart C. Crawford, Sr., Esquire Attorney Id. No.: 09827 223 North Monroe Street Media, Pa 19063 Telephone: (877)-992-6311, ext. 21 Web: www.subrolaw.us E-Mail: sccrawford a~,subrolaw.us :`--~' - CRAWFORD & ASSOCIATES ,. r., ~,, i" vU __. .._ r,~., ~ ~+ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW ALLSTATE INSURANCE COMPANY : NO: OS-5901 A/S/O RONALD POTTER VS. RAYMOND S. HOLLOWAY, JR. :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 RAYMOND S. HOLLWAY, JR. be reinstated and remain so as long as Defendant abides by the terms of the attached Conditional Release. If the Defendant fails to keep payments up to date, his driving privileges will then be suspended. STEWART C. C ORD, ESQUIRE Attorney for Plaintiff ~„ f~~%! RAYM S. HOLLOWAY, JR'. ~ INSTALLMENT AGREEMENT TO PAY DAMAGES This agreement made and entered into thi~O~~ day ol~.~.~~, 20~~ witnesses that I, Raymond S. Holloway, Jr. understand, admit, agree, and promise as follows: 1. That, I, while operating a vehicle on or about 31'` day of October 2004, caused damages for $2,429.00 to the motor vehicle insured by Allstate Insurance Company. Said damages are complained of in civil action number OS-5901 in the Court of Common Pleas of Cumberland County, Pennsylvania. I hereby admit that a judgment for those damages has been entered against me in that matter and that I am responsible for such damage, but do not have available funds to pay such damage in a lump sum. However, I agree to pay Allstate Insurance Company this debt by making consecutive monthly payments, through their attorneys, the Law Offices of Stewart C. Crawford & Associates, P.O. Box E, and Media, Pennsylvania, 19063 for a total sum of $2,922.12. 2. That, I agree to pay a minimum of $100.00 per month to be paid on or before the 1'` day of each month, commencing on the date that I sign this agreement, until such time as the total sum of $2,922.12 has been paid in full, at which time a release of Allstate Insurance Company's subrogation interest will be executed and delivered to me if requested in writing. 3. That, I understand that this agreement shall be used to meet the requirements of the applicable motor vehicle safety and financial responsibility laws so as to allow me to have my driver's license and vehicle registration privileges reinstated. 4. That, I agree to toll the applicable statute of limitations until such time as this debt is satisfied. 5. That, I agree that all payments required herein shall be sent directly to the Law Offices of Stewart C. Crawford & Associates, P.O. Box E, Media, Pennsylvania, 19063 and made payable to Allstate Insurance Company, unless otherwise directed by Allstate Insurance Company through their attorneys. 6. That, I agree that, in the event of a failure to make payment as set forth in this agreement, the entire unpaid balance of the total sum indicated in the first paragraph above shall become immediately due and that Allstate Insurance Company, through their attorneys, may at their option, prosecute a claim against me for the unpaid balance of the aforementioned total sum plus costs, interest from the date of the loss, and attorneys fees. It is further understood that Allstate Insurance Company, through their attorneys, may notify the applicable department of transportation of my default and that my driver's license shall be suspended as provided under the applicable motor vehicle safety and financial responsibility laws. 7. That, I agree that payments are to be mzde in U.S. currency by personal check, cashier's check, money order, credit card, debit card, or electronic funds transfer. I further agree that if a personal check tendered by me or on my behalf is returned or bounced for any reason, a $35.00 fee will be added to the principal balance owed by me and that Allstate Insurance Company, through their attorneys may refuse to accept payment by personal check within the context of this agreement. 8. That, I agree that if a monthly payment is not received within 30 days of it becoming due, a $15.00 late charge fee may, at the option of Allstate Insurance Company, through their attorneys, be added to the principal balance owed by me. 07-OS-557 All a/s/o Potter v. Holloway I further agee that if there are three (3) consecutive late payments in a given twelve (12) month period, said late payments will constitute a breach of this ageement and render the undersigned in default of this ageement. 9. That, I agee not to discharge this debt in any manner whatsoever in any bankruptcy or other form of insolvency proceeding which may be filed at any time after the date of the execution of this document by me or by anybody acting on my behalf. 10. That, I agee that a particular waiver of any of the aforementioned conditions by Allstate Insurance Company, by its attorneys, the Law Offices of Stewart C. Crawford & Associates, will not be construed as a continuous waiver of that condition. 11. That, I agree that if any provision of this ageement is subsequently held invalid or unenforceable by a Court of competent jurisdiction, the remainder of the ageement shall not be affected thereby and that the Court making that determination shall have the power to modify the offensive provision, or to delete specific words or phrases, and in its reduced form such provision shall then be enforceable to the fullest extent permitted by law. valid: 12. Ail information including the date n-~ast be filled in and notarized to make agreement 13. If Payments are made on time the interest amount will be reduced as follows: Total balance of judgment equals $2,429.00, Interest equals $493.1.2, discount of total interest $246.56 for a total payment to make of $2,675.51. ~ated this 2br~day of- ,~,up~-~ , 20~~j 1 /~/~ r mond. S. Holloway, Jr. %~a? l 3 ~. G 9~,1o Sf~C-CC~~-1 ~~'C l~~ I ~c~o-~ t~ddress ~~~~ /~s ate of Birth QO ,a ~ 'ver's License Number ~~- ~~3^ ~I~~3 ephone Number •-I ~~~-hod" ~~~~~ ocial Security Number subscribed and sworn to before me this ,~~day of l~~- r 20~~ Notary Public, State of ` ~} My commission is permanent /expires: ~ ~ ~ ~ 07-OS-557 All a/s/o Potter v. Holloway COMMONWEALTH OF PENNSYLVANIA N CITARIAL SEAL Brandy M. Wood-Notary Public SWATARA TWP., DAUPHIN COUNTY MY COMMISSION EXPIRES AUG. 05, 2012 S~~zz N CrS