HomeMy WebLinkAbout06-1054COMMONWEALTH OFPENNSYLVI
COURT OF COMMON PLEAS
Judicial District, County Of
Cumberland
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No. Q W&-
NOTICE C tv.I
NOTICE OF APPEAL F b, aa. ?od(F
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on
the date and in the case referenced below.
NOTICE OF APPEAL
FROM
Raymond H. Bowers 09-1-01 Charles A. Clement, Jr.
ADDRESS OF APPELLANT CITY STATE ZIP CODE
901 Wakefield Avenue Mechanicsburg PA 17055
DATE OF JUDGMENT IN THE CASE OF (Plaintiff) (Defendant(
2-06-06 Robert M. Steiger V, Raymond E. Bowers
DOCKET No. SIGNATURE OF APPELLANT OR ATTORNEY OR AGENT
CV-15-06 ///) P p1 ,,
This block will be signed ONLY when this notation is required under Pa. If appellant was Claimant (see Pa. R.C.P.D.J. No. 1001(6) in action
R.C.P.D.J. No. 10088.
This Notice of Appeal, when received by the District Justice, will operate as a before a District Justice, A COMPLAINT MUST BE FILED within twenty
SUPERSEDEAS to the judgment for possession in this case.
(20) days after filing the NOTICE of APPEAL.
Synatore of Prothonotary or Deputy
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before District Justice. IF
NOT USED, detach from copy of notice of appeal to be served upon appellee.
PRAECIPE: To Prothonotary
Enter rule upon. _ Robert M. Steiger appellee(s), to file a complaint in this appeal
Name of appellee(s)
(Common Pleas No. ;Qp(,, _ I QsL, 't y ` ) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
i i
. i Signature of appellant or attorney or agent
RULE: To g `???//1111
Robert -K. Staffer appellees)
Name of appellee(a)
(1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service
of this rule upon you by personal service or by certified or registered mail.
(2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAYBE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of the mailing.
Date: 2q% n
Signature of Prof on faryrDeputy
YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL.
AOPC 312-02
COURT FILE TO BE FILED WITH PROTHONOTARY
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(Thus proof of service MUST BE FILED WiTN(tV TEN 100) DAYS APJ ER filing of f x nonce rr'
COMMONWEALTFt OF PENNSYLVANIA
COUNTY OF , _3
AFFIDAVIT: I hereby (swear) (affirm) that I served
f a capy of the Notice of Appeal. Common Fieas No . uprn the Gis!r r 1?
(date of'setvice) , 20 El by personal Se; V ce r ,c
sender s receipt attached hereto, and upon the appellee, (naive) -
20 Ell, by personal service by !r=rtliied} ;rt,g it red;, mars
se:?der's receipt attached hereto.
(SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME
THS DAY OF .20 Sif7oatwe of oHlcot before whop; nXldevit was mede
Title of oryfcw)
c->
MV commission expires art 20
71
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_ c
A6PC 312A-02.
N,
COMMONWEALTH OF PENNSYLVANIA
rrni INITV nG CUMBERLAND
IA,' Darn ",
09-1-01
Mr," Nar" I+o,
CHARLES A. CLEMENT, JR
400 BRIDGE ST
OLDS TOME COMMONS -SUITE 3
NEW CUMBERLAND, PA
pra„e (717) 774-5989 17070
NOTICE OF JUDGMENT/TRANSCRIPT
PLAINTIFF CIVIL CASE
;,.oorr.:e
FSTAIGER, ROBERT M
5141 KYLOCK ROAD
MECHANICSBURG, PA 17055
L
V&
Nnw[,irn AUDOESS
J
DEFENDANT:
FBOWERS, RAYMOND H
901 WAKEFIELD AVE
MECHANICSBURG, PA
17055
7
RAYMOND B. BOWERS (_ J
901 WAKEFIELD AVE Docket No.i CV-0000015-06
MECHANICSBURG, PA 17055 Date Filed: 1106106
?'99Y
THIS IS TO NOTIFY YOU THAT:
Judgment: D$FAULT JUDGMSrs7T PLTF
® Judgment was entered for: (Name) Sir+ER _RnARRT M
® Judgment was entered against: (Name) HOWERg, gATri nIM H
in the amount of $ 4 _ n37 _ n2 on: (Date of Judgment)
? Defendants are jointly and severally liable. (Date & Time)
D Damages will be assessed on:
? This case dismissed without prejudice.
Amount of Judgment Subject to
? Attachment/42 Pa.C.S. § 8127 $
Portion of Judgment for physical
damages arising out of residential
lease $
Amount of Judgment $
Judgment Costs $
Interest on Judgment $
Attorney Fees $
Total $
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total $
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTtTRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE
JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST
COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IM THE JUDGMENT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL.
SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT.
Date
Magisterial District Judge
I certify that this is a true and correct copy of the record of the proceedings containing the judgment.
Date , Magisterial District Judge
My commission expires first Monday of January, 2008 . SEAL
AOPC 915 o5 DATE PRINTED: 2/16/06 12:05:35 PM
i U
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1-7
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PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
('fftls prooF of eenrice MUST f3E FILED WITHIN TEN ftD) DAYS AFTER filing of tha notice of appeal Check 2npficsbkr boxes.}
COMMONNFALTH OF PENNSYLVANIA
COUNTY OF Cumberland ss
AFFIDAVIT: I nerepy (swear') (affirm) that I served
a copy of the Notice of Appeal, Common Pieces No. 2006-1054 poo the District Jasece destpnoted therein c,n
(dale otservice) February 22 , 20 06 ? ® by personal service L.J h'9 (certilied7 (reyisfefredj wail,
sender's recetpi attached hereto, and Upon the all*iee, (name) Robert M. S taiger - `-"'
February 23 ' 20 06 by personal service cv tcert fled) (testeFi.) mail,
sender's receipt attached hereto.
(SWORN) (FIRMED) AND SUOSTIBED 6EF(AE ME
THIS DAY 4F '.C ?rr'1^ 20 CMG'..
C9 LU
,S(pnatm ofof/forl before whom afh'Cavitwas ma<fe
?'itle of otRCia)
My commission expires on .20
M EALTH OF PENNSYLVANIA
NOW sow
MCI m A. Srh*, NoWy Pudic
Cow Boo, 0AThwwtd County
W4mExpirmJon.19,2010
M"jW hnmylvaWA AWNWIM ol NouAM
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ADPG 312A -02
COMMONWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS
Judicial District, County Of
NOTICE OF APPEAL
FROM
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No.
NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on
the date and in the case referenced below.
IN THE
This block will be signed ONLY when this notation is required under Pa.
R.C.P.D.J. No. 10088.
This Notice of Appeal, when received by the District Justice, will operate as a
SUPERSEDEAS to the judgment for possession in this case.
sgrmuro o/ pmthono my or Depury
was Claimant
in action
before a District Justice, A COMPLAINT MUST BE FILED within twenty
(20) days after filing the NOTICE of APPEAL.
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before District Justice. IF
NOT USED, detach from copy of notice of appeal to be served upon appellee.
PRAECIPE: To Prothonotary
Enter rule upon
(Common Pleas No.
appellee(s), to file a complaint in this appeal
) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
Signature o/appellant or attomay reagent
RULE: To
(Dereneanp'
Name of appellee(s)
Name of ap appellee(s)
appellee(s)
(1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service
of this rule upon you by personal service or by certified or registered mail.
(2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAYBE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of the mailing.
Date: - 20'l. Signature o/Pmthonotary or Deputy
YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENTITRANSCRIPT FORM WITH THIS NOTICE OF APPEAL.
AOPC 312-02
COURT FILE
CERTIFIEC
(Domestlc mail of
m
m
a
Postage $
rR
O Certified Fee
C
C3 Return Reciept Fee
(Endorsement Required)
C3 Restricted Delivery Fee
r=i
(Endorsement Required)
C3
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Total Postage & Fees 1
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0 Cot To
0
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s2.c0 0013
1,4 Po k
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¦ Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
¦ Print your name and address on the reverse
so that we can return the card to you.
¦ Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to
A Sigrlix e
P. Received by (Pooled Name) C. Date of Delivery
? ?`F>•i tM?ill?r?7f? I
D. Is delivery address tlHfereM from illation 1? ? Y
y address below:
If\ A er
GA
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3.
-? V MU L.L JLU aR'g0 Express Mall
0 R afBtl-?' EI Return Receipt for Merchandise
0 Insured Mail 0 C.O.D.
4. Restricted Delivery? (Extra Feel 0 Yes
2. Article Number
(Transfer liom s e label) 7003 1010 0001 1188 9006
PS Form 3811, February 2004 Domestic Return Receipt 102595-02-10-1540
5i k Lb?IL Inc
MICHAEL L. BANGS, ESQUIRE
I.D. #41263
429 SOUTH 18Te STREET
CAMP HILL, PA 17011
(717) 730-7310
ATTORNEY FOR PLAINTIFF
ROBERT M.STAIGER, )
Plaintiff )
VS. )
RAYMOND H. BOWERS, )
Defendant )
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 2006-1054 CIVIL
CIVIL ACTION
NOTICE
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 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.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
MICHAEL L. BANGS, ESQUIRE
I.D.#41263
429 SOUTH 18TH STREET
CAMP HILL, PA 17011
(717) 730-7310
ATTORNEY FOR PLAINTIFF
ROBERT M. STAIGER, )
Plaintiff )
vs. )
RAYMOND H. BOWERS, )
Defendant )
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 2006-1054 CIVIL
CIVIL ACTION
COMPLAINT
AND NOW comes the Plaintiff, Robert M. Staiger, by and through his attorney Michael
L. Bangs, Esquire, and files the following Complaint:
1. Plaintiff, ROBERT M. STAIGER, is an adult individual who resides at 5141 Kylock
Road, Mechanicsburg, Cumberland County, Pennsylvania.
2. Defendant, RAYMOND H. BOWERS, is an adult individual who resides at 901
Wakefield Avenue, Mechanicsburg, Cumberland County, Pennsylvania.
3. Plaintiff was the owner of a 1994 Honda Accord vehicle ("Vehicle").
4. On or about November 6, 2005, Plaintiffs daughter, Ashlee Staiger, was operating
Plaintiffs Vehicle.
5. Ashlee Staiger was on her way home when she proceeded to the intersection of
Gettysburg Road and Wesley Drive in Upper Allen Township, Mechanicsburg, Pennsylvania.
6. On November 6, 2005, Ashlee Staiger attempted to make a left hand turn from
Gettysburg Road onto Wesley Drive.
7. Ashlee Staiger proceeded into the intersection under the green light permitting her to
make that turn.
8. On November 6, 2005, Defendant was operating his vehicle in a northerly direction on
Wesley Drive.
9. As Defendant approached the intersection of Wesley Drive and Gettysburg Road, a
red light was directing him to stop in his lane of travel.
10. Defendant failed to stop and slammed into the side of the vehicle operated by Ashlee
Staiger.
11. Defendant had a duty to operate his motor vehicle in a safe manner and in
accordance with the mandates of the Motor Vehicle Code.
12. Defendant breached that duty by operating his motor vehicle in a negligent manner
which consisted of, but is not limited to, the following:
A. He failed to stop at the red stop light at the intersection of Wesley
Drive and Gettysburg Road;
B. He failed to operate his vehicle at a safe speed so as to allow him to
stop his vehicle in a reasonably prudent manner;
C. He was operating his vehicle at a time when he was incapable of safe
driving due to his infirmities or other physical problems;
D. He failed to operate his motor vehicle in accordance with the mandates
of the Motor Vehicle Code.
13. As a result of the negligence of the Defendant, the Vehicle owned by Plaintiff was
totaled.
14. Plaintiff was damaged by the negligence of Defendant by the total destruction of his
Vehicle.
15. The value of Plaintiffs Vehicle on the date and time in which it was destroyed by
Defendant was $5,000.00.
16. Plaintiff has been damaged by the negligence of Defendant in the amount of
$5,000.00 which represents the value of the Vehicle at the time that it was destroyed in the motor
vehicle accident.
17. Plaintiffs daughter, Ashlee Staiger, acted in a reasonably prudent manner and in
accordance with the mandates of the Motor Vehicle Code on November 6, 2005, and her actions
in no way played any part in causing the motor vehicle accident.
18. Defendant is liable to Plaintiff in the amount of $5,000.00 which represents the value
of Plaintiffs Vehicle which was destroyed by the negligence of Defendant as stated herein.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of
$5,000.00, plus interest, plus costs of suit. The amount claimed is within the arbitration limits of
this Court.
Respectfully submitted,
MICHAEL L. BANGS
Attorney for Plaintiff C
429 South 18th Street
Camp Hill, PA 17011
(717) 730-7310
Supreme Court ID #41263
VERIFICATION
I hereby verify that the statements made in the foregoing Complaint are true and correct.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section
4904, relating to unsworn falsification to authorities.
Date: ROBERT M.S AI
4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this day served the foregoing COMPLAINT, by
depositing a copy of the same in the United States mail, postage prepaid, at Camp Hill,
Pennsylvania, addressed to the following:
Hillary A. Dean, Esquire
Martson Deardorff Williams & Otto
10 East High Street
Carlisle, PA 17013
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cy?
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73,
l y
George B. Faller, Jr., Esquire
MARTSON DEARDORFF WILLIAMS & OTTO
I.D. No. 49813
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Defendant
ROBERT M. STAIGER,
Plaintiff
V.
RAYMOND H. BOWERS,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-1054
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
As a prerequisite to service ofa subpoena for documents and things pursuant to Rule 4009.22,
Defendant certifies that:
(1) a notice of intent to serve the subpoena with a copy of the subpoena attached thereto was
mailed or delivered to each party at least twenty days pri or to the date on which the subpoena is sought
to be served,
(2) a copy of the notice of intent, including the proposed subpoena, is attached to this
certificate,
(3) no objection to the subpoena has been received, and
(4) the subpoena which will be served is identical to the subpoena which is attached to the
notice of intent to serve the subpoena.
Date: April 3, 2006
MARTSO Y EAO ? W ILA-MS & OTTO
By -/ ` VA.
George B. Faller, Jr., Esquire
I.D. No. 49813
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Attorneys for Defendant
P\I ILES\DATAPILE\Tm,,I,,,Y)90\Curtan\Pb5\'_0 Day \N¢c)nxrv
Cr.,ar d 1']2/97 014^_4 AiM
Rr%ts.d. 03,13 00 02 21 11 PN
J090 818
George B. Faller, Jr., Esquire
MARTSON DEARDORFF WILLIAMS & OTTO
LD. No. 49813
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Defendant
ROBERT M. STAIGER,
Plaintiff
V.
RAYMOND H. BOWERS,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-1054
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NOTICE OF INTENT TO SERVE A SUBPOENA TO
PRODUCE DOCUMENTS AND THINGS FOR
DISCOVERY PURSUANT TO RULE 4009.21
Defendant intends to serve a subpoena identical to the one that is attached to this notice. You have
twenty (20) days from the date listed below in which to file ofrecord and serve upon the undersigned an
objection to the subpoena. If no objection is made, the subpoena may be served.
MARTSON DEARDORFF WILLIAMS & OTTO
By
George B. Faller, Jr., Esquire
I.D. No. 49813
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Attorneys for Defendant
Date: March 13, 2006
C01440@1W rH OF PENNSYLVANIA
COUNTY OF CL24BERLAND
Robert M. Staiger,
Plaintiff,
V.
Raymond H. Bowers,
Defendant.
File No. 2006-1054 - Civil
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
Mr. Bill Smith, Pennsylvania Peres, Inc.
TO: 6375 Baseshore Road, Suite 8, Mechanicsburg, PA 17050
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following documents or things: Any and all records with regard to the traffic
signal at the intersection of Wesley Drive and Gettysburg Road in Lower Allen Township --
including but not limited to the Intersection Diagram, timing records, control box indicator,
Nn,.cmhar Fi 2
at Mattson Deardorff Williams & Otto, 10 East High Street, Carlisle, PA 17013
(Address)
You may deliver or mail legible copies of the documents or produce things requested by
this subpoena, together with the certificate of compliance, to the party making this
request at the address listed above. You have the right to seek in advance the reasonable
cost of preparing the copies or producing the things sought.
If you fail to produce the docunents or things required by this subpoena within twenty
(20) days after its service, the party serving this subpoena may seek a court order
ocmpellirg you to omply with it.
THIS SUBPOENA WAS ISSUED AT THE RECAJEST OF 1HE FOLLOWING PERSON:
NAME: George B. Faller, Jr., Esquire_
ADDRESS: 10 East High Street
Carlisle, PA 17013
TELEPHONE: 717-243-3341
SUPREME COURT ID # 49813
ATTORNEY FOR: Defendant
BY THE COURT:
DATE: March 13, 2006 Prothonotary/Clerk, Civil Division
Seal of the Court
Deputy
(Eff. 7/97)
CERTIFICATE OF SERVICE
I, Melissa A. Scholly, an authorized agent for Martson Deardorff Williams & Otto, hereby certify
that a copy of the foregoing Certificate Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22
was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid,
addressed as follows:
Michael L. Bangs, Esquire
BANGS LAW OFFICE
429 South 18th Street
Camp Hill, PA 17011
MARTSON DEARDORFF WILLIAMS & OTTO
Melissa A. Scholly
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: April 3, 2006
I ? ^I?
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:, ,? ; - ?11 1a:;7
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F\PILESVDATAEILE\Tmvdevs3090ACm.emv838V9nsI1vjt
Created 3/28/06 2 35PM
Revised. 3@9/06 3.14PM
3090 838
MARTSON DEARDORFF WILLIAMS & OTTO
George B. Faller, Jr., Esquire
I.D. No. 49813
Hillary A. Dean, Esquire
I.D. No. 92878
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Defendant
ROBERT M. STAIGER,
Plaintiff
V.
RAYMOND H. BOWERS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-1054
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
DEFENDANT'S ANSWER WITH NEW MATTER AND COUNTERCLAIM TO
PLAINTIFF'S COMPLAINT
TO: ROBERT M. STAIGER, Plaintiff, and his attorney, MICHAEL L. BANGS, ESQUIRE
YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED
NEW MATTER AND COUNTERCLAIM WITHIN TWENTY (20) DAYS FROM SERVICE
HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST YOU.
AND NOW comes Defendant, Raymond H. Bowers, by and through his attorneys, MARTSON
DEARDORFF WILLIAMS & OTTO, and hereby responds to Plaintiff's Complaint as follows:
L After reasonable investigation, Defendant is without knowledge or information sufficient to
form a belief as to the truth of the allegation of paragraph one.
2. Denied. On the contrary, Raymond H. Bowers is an adult individual who resides at 20
North 121h Street, Lemonye, Pennsylvania 17043.
Denied. After reasonable investigation, Defendant is without knowledge or information
sufficient to form a belief as to the truth of the allegation of paragraph three. Strict proof thereof is
demanded.
4. Admitted in part and denied in part. It is admitted that on November 6, 2005, Ashley
Staiger was operating a 1994 Honda Accord. Defendant lacks knowledge or information sufficient to form
a belief as to the owner of said vehicle.
5. Admitted in part and denied in part. It is admitted that Ashley Staiger's vehicle did proceed
to the intersection of Gettysburg Road and Wesly Drive. After reasonable investigation, Defendant lacks
knowledge or information sufficient to determine what destination Ashley Staiger was traveling to at the
time.
Admitted. Byway of further answer, Ashley Staiger attempted to make a left-hand turn
from Gettysburg Road onto Wesly Drive while the traffic light controlling that intersection was red.
7. Denied. On the contrary, Ashley Staiger proceeded into the intersection under a red light,
which prohibited her to make a left turn.
8. Admitted.
9. Denied. On the contrary, as Defendant approached the intersection of Wesley Drive and
Gettysburg Road, a green light was directing him to proceed through the intersection.
10. Denied. The allegation ofparagraph 10 is specifically denied and strictproofis demanded.
11. Denied. The allegation of paragraph I I is a conclusion of law to which no response is
required.
12. Denied. The allegation of paragraph 12 is a conclusion of law to which no response is
required.
13. Denied. The allegation ofparagraph 13 is a conclusion of law to which no response is
required.
14. Denied. The allegation of paragraph 14 is a conclusion of law to which no response is
required.
15. Denied. The allegation ofparagraph 15 is a conclusion of law to which no response is
required.
16. Denied. The allegation ofparagraph 16 is a conclusion of law to which no response is
required.
17. Denied. The allegation of paragraph 17 is a conclusion of law to which no response is
required.
18. Denied. The allegation ofparagraph 18 is a conclusion of law to which no response is
required.
WHEREFORE, Defendant Raymond H. Bowers respectfully requests that this Court dismiss
Plaintiff's Complaint with prejudice and enter judgment in his favor and against Plaintiff.
NEW MATTER
19. The averments of paragraphs 1 through 18 are incorporated herein by reference.
20. Plaintiff s recovery is barred or reduced by the Pennsylvania Motor Vehicle Financial
Responsibility Law as amended.
21. Plaintiffor his representatives chose the limited tort option by signing a valid selection form.
22. Plaintiff's injuries do not involve death, serious impairment ofbodilyfunctionorpermanent
disfigurement.
WHEREFORE, Defendant Raymond H. Bowers respectfully requests that this Court dismiss
Plaintiff's Complaint with prejudice and enter judgment in his favor and against Plaintiff.
COUNTERCLAIM
23. The averments of paragraphs 1 through 22 are incorporated herein by reference.
24. On or about November 6, 2005, Defendant Raymond H. Bowers was operating a2004
Buick LeSabre in a northerly direction on Wesley Drive.
25. As he approached the intersection of Wesley Drive and Gettysburg Road, Defendant
proceeded through the intersection of Wesley Drive and Gettysburg Road under a green light.
26. At or around the same time, Plaintiff's daughter, Ashley Staiger, was operating a vehicle
on Gettysburg Road.
27. As Ashley Staiger proceeded to the intersection of Wesley Drive and Gettysburg Road,
she proceeded to make a left-hand turn onto Wesley Drive under a red light which was directing her to stop
in her lane of travel.
28. The automobiles did collide at the intersection of Wesley Drive and Gettysburg Road.
29. Ashley Staiger breached her duty to operate her motor vehicle in a safe and prudent
mannerby operating hermotor vehicle in an negligent manner, which consisted of, but is not limited to the
following:
(a) Failure to stop her vehicle at the red light at the intersection of Wesley Drive and
Gettysburg Road;
(b) failure to operate her vehicle at a safe speed so as to allow her to stop her vehicle in a
reasonably prudent manner;
(c) failing to have her car under proper and adequate control at the time of the collision;
(d) operating her vehicle inacarelessandrecklessmannerwithoutdueregard fortherights
and safety of those lawfully upon the roadway, one of whom was Defendant Raymond Bowers;
(e) failing to see that the car which Defendant was operating had come to a stop;
(f) failing to stop her vehicle prior to colliding with the car driven by Defendant;
(g) failing to prevent a collision with Defendant's car when there was sufficient time and space
to either stop or avoid colliding with Defendant's car.
30. By reason of the aforesaid carelessness, recklessness and negligence of the Plaintiff's
daughter, Ashley Staiger, Defendant Raymond H. Bowers' vehicle was damaged.
31. Defendant's vehicle has been damagedby the negligence of Plaintiff in the amount of
$10,358.36.
WHEREFORE, Defendant demands judgment against Plaintiff in the amount of $10,358.36 plus
interest, cost of suit and any other remedies as this Court may see fit. The amount claimed is within the
arbitration limits.
MARTSON DEARDORFF WILLIAMS & OTTO
Date: 4U k u
By ( ` it L ?d? 1
eorge B. Fall Jr., Es'qeire
I.D. No. 49813
Hillary A. Dean, Esquire
I.D. No. 92878
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Attorneys for Defendant
VERIFICATION
The foregoing Answer with New Matter and Counter Claim is based upon information which has
been gathered bymy counsel in the preparation of the lawsuit. The language of the document is that of
counsel and not my own. I have read the document and to the extent that it is based upon information
which 1 have given to my counsel, it is true and correct to the best of my knowledge, information and belief.
To the extent that the content of the document is that of counsel, I have relied upon counsel in making this
verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities, which provides that ifImake knowingly false averments, I
may be subject to criminal penalties.
Raym d H. Bowers
F\FILESVDATAFILEAT,xllilrsJ090ACu,,n1A838AansI
CERTIFICATE OF SERVICE
I, Ami J. Thumma, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that
a copy of the foregoing Answer with New Matter and Counter Claim to Plaintiff s Complaintwas served
this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed
as follows:
Michael L. Bangs, Esquire
BANGS LAW OFFICE
429 South 18`x' Street
Camp Hill, PA 17011
MARTSON DEARDORFF WILLIAMS & OTTO
By:
Arm J. Thu ma
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: Cl/lo o (D
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3090 838
MARTSON DEARDORFF WILLIAMS & OTTO
George B. Faller, Jr., Esquire
I.D. No. 49813
Hillary A. Dean, Esquire
I.D. No. 92878
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Defendant
ROBERT M. STAIGER,
Plaintiff
V.
RAYMOND H. BOWERS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-1054
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
DEFENDANT'S AMENDED ANSWER TO PLAINTIFF'S COMPLAINT
WITH NEW MATTER
TO: ROBERT M. STAIGER, Plaintiff, and his attorney, MICHAEL L. BANGS, ESQUIRE
YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED
NEW MATTER WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A JUDGMENT
MAY BE ENTERED AGAINST YOU.
AND NOW comes Defendant, Raymond H. Bowers, by and through his attorneys, MARTSON
DEARDORFF WILLIAMS & OTTO, and hereby responds to Plaintiff's Complaint as follows:
After reasonable investigation, Defendant is without knowledge or information sufficient to
form a belief as to the truth of the allegation of paragraph one.
2. Denied. On the contrary, Raymond H. Bowers is an adult individual who resides at 20
North 12' Street, Lemonye, Pennsylvania 17043.
Denied. After reasonable investigation, Defendant is without knowledge or information
sufficient to form a belief as to the truth of the allegation of paragraph three. Strict proof thereof is
demanded.
l
4. Admitted in part and denied in part. It is admitted that on November 6, 2005, Ashley
Staiger was operating a 1994 Honda Accord. Defendant lacks knowledge or information sufficient to form
a belief as to the owner of said vehicle.
Admitted in part and denied in part. It is admitted that Ashley Staiger's vehicle did proceed
to the intersection of Gettysburg Road and Wesly Drive. After reasonable investigation, Defendant lacks
knowledge or information sufficient to determine what destination Ashley Staiger was traveling to at the
time.
6. Admitted. Byway of further answer, Ashley Staiger attempted to make a left-hand turn
from Gettysburg Road onto Wesly Drive while the traffic light controlling that intersection was red.
Denied. On the contrary, Ashley Staigerproceeded into the intersection under a red light,
which prohibited her to make a left turn.
Admitted.
9. Denied. On the contrary, as Defendant approached the intersection ofWesleyDrive and
Gettysburg Road, a green light was directing him to proceed through the intersection.
10. Denied. The allegation ofparagraph 10 is specifically denied and strict proofis demanded.
11-18. Denied. The allegations ofparagraphsllthrough 18areconclusions oflawtowhich no
response is required.
WHEREFORE, Defendant Raymond H. Bowers respectfully requests that this Court dismiss
Plaintiff's Complaint with prejudice and enter judgment in his favor and against Plaintiff.
NEW MATTER
19. Plaintiff's damages were caused bythe negligence ofAshley Staiger, who is not presently
a party to this litigation.
Respectfully Submitted,
Date: 5 Ia`+? Q
MARTSON DEARDORFF WILLIAMS & OTTO
BY
G rge B. Faller, J , Esquire
. . No. 49813
Hillary A. Dean, Esquire
I.D. No. 92878
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Attorneys for Defendant
VERIFICATION
The foregoing Amended Answer is based upon informationwhichhas been gathered by my counsel
in the preparation of the lawsuit. The language ofthe document is that of counsel and not my own. I have
read the document and to the extent that it is based upon information which I have given to my counsel, it
is true and correct to the best ofmy knowledge, information and belief. To the extent that the content of
the document is that of counsel, I have relied upon counsel in making this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unswom falsification to authorities, which provides that ifI make knowingly false averments, I
maybe subject to criminal penalties.
nd H. Bowers
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CERTIFICATE OF SERVICE
I, Ami J. Thumma, an authorized agent for Martson Deardorff'Williams & Otto, hereby certify that
a copy ofthe foregoing Amended Answer to Plaintiffs Complaint was served this date by depositing same
in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows:
Michael L. Bangs, Esquire
BANGS LAW OFFICE
429 South 18" Street
Camp Hill, PA 17011
MARTSON DEARDORFF WILLIAMS & OTTO
By: aNk
Ami J. Th a
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: 6x(410 (p
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MICHAEL L. BANGS, ESQUIRE
I.D. No. 41263
429 South 18s' Street
Camp Hill, PA 17011
(717) 730-7310
ATTORNEY FOR PLAINTIFF
ROBERT M. ST
Plaintiff
IN THE COURT OF COMMON
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 2006-1054
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
VS.
RAYMOND H. BOWERS,
Defendant
PLAINTIFF'S ANSWER TO DEFENDANT'S NEW MATTER
PLEAS
19. Denied. It is specifically denied that Plaintiffs damages were caused by the
negligence of Ashley Staiger.
Respectfully submitted,
MICHAEL L. BANGS
Attorney for Plaintiff i
429 South 18th Street
Camp Hill, PA 17011
(717) 730-7310
Supreme Court ID #41263
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this day served the foregoing Answer to New Matter
by depositing a copy of the same in the United States mail, postage prepaid, at Camp Hill,
Pennsylvania, addressed to the following:
Hillary A. Dean, Esquire
Martson, Deardorff, Williams & Otto
10 East High Street
Carlisle, PA 17013
DATE: lQ ?? 4N
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R.,wd 6/15/06 9:39AM
George B. Faller, Jr., Esquire
Hillary A. Dean, Esquire
MARTSON DEARDORFF WILLIAMS & OTTO
I.D. Nos. 49813 and 92878
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Defendant Raymond H. Bowers
ROBERT M. STAIGER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
RAYMOND H. BOWERS,
Defendant
V.
ASHLEE STAIGER,
Additional Defendant
NO. 2006-1054
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NOTICE
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 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 Plaintiffs. 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE:
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
ROBERT M. STAIGER,
Plaintiff
V.
RAYMOND H. BOWERS,
Defendant
V.
ASHLEE STAIGER,
Additional Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-1054
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
ADDITIONAL DEFENDANT COMPLAINT
AND NOW, comes Defendant, Raymond H. Bowers, by and through his attorneys, MARTSON
DEARDORFF WILLIAMS & OTTO, and files the within Additional Defendant Complaint as follows:
Plaintiff Robert M. Staiger is an adult individual, who resides at 5141 Kylock Road,
Mechanicsburg, Cumberland County, Pennsylvania.
2. Defendant Raymond H. Bowers is an adult individual, who resides at 901 Wakefield
Avenue, Mechanicsburg, Cumberland County, Pennsylvania.
3. Additional Defendant Ashlee Staiger, is a minor individual who resides at 5141 Kylock
Road, Mechanicsburg, Cumberland County, Pennsylvania.
4. Plaintiff filed a Complaint on March 15, 2006, alleging damage to his automobile in an
automobile accident which occurred on November 6, 2005. (A copy ofPlaintiff s Complaint is hereby
attached as Exhibit "A").
5. In that Complaint, Plaintiffalleges that his daughter, Ashlee Staiger,was operating Plaintiffs
vehicle at the time of the automobile accident.
6. On or about May 24, 2006, Defendant filed an Amended Answer to Plaintiff's Complaint.
WHEREFORE, Defendant Raymond H. Bowers respectfully requests that the Court enter
judgment in its favor and against Additional Defendant Ashlee Staiger together with all allowable costs.
COUNTI
The averments of paragraphs 1 through 6 are hereby incorporated by reference.
8. At the time ofthe accident, Ashlee Staiger proceeded to make a left-hand turn onto Wesley
Drive under a red light which was directing her to stop in her lane of travel.
9. If Plaintiff is entitled to recover from any party, which has been expressly denied in
Defendant's Answer, the liability is the sole liability of Additional Defendant Ashlee Staiger. In the
alternative, Additional Defendant Ashlee Staiger is liable over, jointly and severally liable and/or liable for
contribution and/or indemnity.
10. Additional Defendant was negligent as she failed to: (a) yield her vehicle Defendant
Bowers' vehicle in violation of 75 Pa. CSA 3324; (b) properly stop at the red light in violation of the PA
Motor Vehicle Code; (c) failed to observe that Mr. Bowers' vehicle in time to avoid a collision.
WHEREFORE, Defendant Raymond H. Bowers respectfully requests that the Court enter
judgment in its favor and against Additional Defendant Ashlee Staiger together with all allowable costs.
COUNT II
COUNTERCLAIM
11. The averments of paragraphs 1 through 10 are hereby incorporated by reference.
12. As a direct result ofthe negligence ofAshlee Staiger, Bowers' vehicle was damaged in the
amount of $10,358.36. (See estimate attached here to as Exhibit `B").
WHEREFORE, Defendant Raymond H. Bowers demands judgment against Defendant Ashlee
Staiger in the amount of $10,358.36 with all allowable costs.
MARTSON jFARDORF?WAIj,IAMS & OTTO
- By.
Georgd EVFaller, Jr., Esquire
Hillary A. Dean, Esquire
MARTSON DEARDORFF WILLIAMS & OTTO
I.D. Nos. 49813 and 92878
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Date: (pl 15/Ot i Attorneys for Defendant
???b;f ?
;MICHAEL L. BANGS, ESQUIRE
1.D.=41263
429 SOUTH 18"" STREET
CAMP HILL. PA 17011
(717)730-7310
ATTORNEY" FOR PLAINTIFF
ROBERT M.STAIGER, )
Plaintiff )
v?. )
RAYMOND H. BOWERS, )
Defendant )
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 2006-1054 CIVIL
CIVIL ACTION
NOTICE
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 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.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
MMIBIT fie
MICHAEL L. BANGS, ESQUIRE
I.D. #41263
429 SOUTH 18 "" STREET
CAMP HILL, PA 17011
(717) 730-7310
ATTORNEY FOR PLAINTIFF
ROBERT M.STAIGER,
Plaintiff
VS.
RAYMOND H. BOWERS,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 2006-1054 CIVIL
CIVIL ACTION
COMPLAINT
AND NOW comes the Plaintiff, Robert M. Staiger, by and through his attorney Michael
L. Bangs, Esquire, and files the following Complaint:
1. Plaintiff, ROBERT M. STAIGER, is an adult individual who resides at 5141 Kylock
Road, Mechanicsburg, Cumberland County, Pennsylvania.
2. Defendant, RAYMOND H. BOWERS, is an adult individual who resides at 901
Wakefield Avenue. Mechanicsburg, Cumberland County, Pennsylvania.
3. Plaintiff was the owner of a 1994 Honda Accord vehicle ("Vehicle").
4. On or about November 6, 2005, Plaintiff's daughter, Ashlee Staiger, was operating
Plaintiff's Vehicle.
5. Ashlee Staiger was on her way home when she proceeded to the intersection of
Gettysburg Road and Wesley Drive in Upper Allen Township, Mechanicsburg, Pennsylvania.
6. On November 6, 2005, Ashlee Staiger attempted to make a left hand turn from
Gettysburg Road onto Wesley Drive.
7. Ashlee Staiger proceeded into the intersection tinder the green light permitting her to
make that turn.
8. On November 6, 2005, Defendant was operating his vehicle in a northerly direction on
Wesley Drive.
9. As Defendant approached the intersection of Wesley Drive and Gettysburg Road, a
red light was directing him to stop in his lane of travel.
10. Defendant failed to stop and slammed into the side of the vehicle operated by Ashlee
Staiger.
11. Defendant had a duty to operate his motor vehicle in a safe manner and in
accordance with the mandates of the Motor Vehicle Code.
12. Defendant breached that duty by operating his motor vehicle in a negligent manner
which consisted of, but is not limited to, the following:
A. He failed to stop at the red stop light at the intersection of Wesley
Drive and Gettysburg Road;
B. He failed to operate his vehicle at a safe speed so as to allow him to
stop his vehicle in a reasonably prudent manner;
C. He was operating his vehicle at a time when he was incapable of safe
driving due to his infirmities or other physical problems;
D. He failed to operate his motor vehicle in accordance with the mandates
of the Motor Vehicle Code.
13. As a result of the negligence of the Defendant, the Vehicle owned by Plaintiff was
totaled.
14. Plaintiff was damaged by the negligence of Defendant by the total destruction of his
Vehicle.
15. The value of Plaintiff s Vehicle on the date and time in which it was destroyed by
Defendant was $5,000.00.
16. Plaintiff has been damaged by the negligence of Defendant in the amount of
$5,000.00 which represents the value of the Vehicle at the time that it was destroyed in the motor
vehicle accident.
17. Plaintiff s daughter, Ashlee Staiger, acted in a reasonably prudent manner and in
accordance with the mandates of the Motor Vehicle Code on November 6, 2005, and her actions
in no way played any part in causing the motor vehicle accident.
18. Defendant is liable to Plaintiff in the amount of $5,000.00 which represents the value
of Plaintiff's Vehicle which was destroyed by the negligence of Defendant as stated herein.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of
$5,000.00, plus interest, plus costs of suit. The amount claimed is within the arbitration limits of
this Court.
Respectfully submitted,
MICHAEL L. BANGS
Attorney for Plaintiff
429 South 18th Street
Camp Hill, PA 17011
(717) 730-7310
Supreme Court ID #41263
VERIFICATION
I hereby verify that the statements made in the foregoing Complaint are true and correct-
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section
4904, relating to unworn falsification to authorities.
Date: - G;(?, I?•? %,cc.??"- -
ROBERT M. STAICYRR
4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this day served the foregoing COMPLAINT, by
depositing a copy of the same in the United States mail, postage prepaid, at Camp Hill,
Pennsylvania, addressed to the following:
Hillary A. Dean, Esquire
Martson Deardorff Williams & Otto
10 East High Street
Carlisle, PA 17013
DATE:;
WENDY K. STRAUB
Legal Assistant
i?A ?n ?LEDP
,
TRAVELERS
CLAIM DEPARTMENT
1105 BERKSHIRE BOULEVARD
WYOMISSING, PA 19610-1222
(800) 842-9897
CD LOG NO 913
CLAIM INFORMATION
-0
CORRECTED ESTIMATE
11-08-05 11:46 AM
CLAIM # SUD6719001 POLICY # OPH606029469183101
COMPANY D/R 11/07/05 D/A 11/07/05 CLAIM REP LISA YOUNG 3964
INSURED RAYMOND H BOWERS LOSS DATE 11-06-05
CLAIMANT RAYMOND H BOWERS LOSS TYPE COLLISION
LOSS PAYEE ACCT # P04-S02-DN-R16
INSPECTION
TYPE
PRIMARY POI
APPRAISER NAME
LICENSE #
WORK PHONE
ADDRESS
CITY STATE
ZIP
OWNER
REPAIR
FIELD
FRONT END LEFT
MICHAEL MILKOVICH
264366
(610) 736-2527
PO BOX 11
HIGHSPIRE
17034-1208
RAYMOND H BOWERS
20 NORTH 12TH ST
LEMOYNE PA 17043-0000
ATTN GARY
FORBES CHEVROLET INC.
3400 HARTZDALE DRIVE
CAMP HILL PA 17011-
SHOP PHONE (717) 761-0600
SHOP LIC#
CAR IN
CAR OUT
REPAIR DAYS
REG. ID 231947103
FAX (717) 441-1367
VEHICLE
2004 BUICK LE SABRE CUSTOM 4 DR SEDAN
6CYL GASOLINE 3.8
OPTIONS
TWO-STAGE - EXTERIOR SURFACES TWO-STAGE - INTERIOR SURFACES
DRIVER POWER SEAT REMOTE KEYLESS ENTRY SYSTEM
ALARM SYSTEM STRG WHEEL MTD RADIO CONTROLS
BODY COLOR WHITE MILEAGE 23,668
CONDITION GOOD VIN 1G4HP52K444108190
LICENSE # WED49 CODE 5434
LICENSE STATE PA VEH INSP #
PA
REMARKS:
*******ALL SUPPLEMENTS MUST BE REPORTED DIRECTLY TO THE SUPPLEMENT DESK******
***APPRAISER AT 800-842-9897 X 2552 FOR APPROVAL BEFORE REPAIR IS AUTHORIZED*
LKQ SEARCH:AUMILLER WEST, NEWBERRYTOWN
24 HR CONTACT: CALLED LEFT AFTERNOON, CONTACT 7:OOPM EVENING
OWNER NOT PRESENT,ESTIMATE MAILED TO OWNER
OWNER APPROVES VIA PHONE TO SEND CAR TO DRP SHOP FOR TEAR DOWN POSSIBLE TTL
SECOND POI FRONT END RIGHT
FAX (717) 986-0368
INSP DATE 11-08-05
PA LOCATION BECKERS TOWING
CITY STATE CAMP HILL
WORK#
HOME#(717) 763-0252
EXHIBIT "B"
COMSEARCH STOYSTOWN 3/4 FRONT ONLY $2500 + 25% +RECON + CUT & TRIM
COST INEFFECTIVE
OP CODES:
* = USER-ENTERED VALUE
EC = REPLACE AFTERMARKET
EU = SALVAGE PART
PM = AFTERMARKET RECON
IT = PARTIAL REPAIR
E = REPLACE OEM
UC = REMAN/REBUILT OEM
EP = AFTERMARKET NEW
TE = PARTL REPL PRICE
I = REPAIR
-1-
NG = REPLACE NAGS
UM = AFTERMARKET REMAN
PC = RECON OEM PART
ET = PARTL REPL LABOR
L = REFINISH
2004 BUICK LE SABRE
CLAIM # SUD6719001
BR = BLEND REFINISH
SB = SUBLET
P = CHECK
UP = UNRELATED PRIOR
CUSTOM 4 DR SEDAN
LOG 913 -0
TT = TWO-TONE CG
N = ADDITIONAL LABOR RI
AA = APPEAR ALLOWANCE RP
OP GDE MC DESCRIPTION
-- --- -- -----------
PC 0006 COVER,FRONT BUMPER
L 0006 COVER,FRONT BUMPER
RI 0100 EXTN,FRONT BUMPER 0 RT
RI 0099 EXTN,FRONT BUMPER 0 LT
RI 0799 DEFL,FRONT BUMPER LWR
E 0007 ABSORBER,FRONT ENERGY
RI 0011 GRILLE ASSEMBLY
PC 0041 HEADLAMP ASSY,HALOG LT
PC 0042 HEADLAMP ASSY,HALOG RT
E 0045 PANEL,HEADLAMP MTG
RI 0059 PARKLAMP ASSEMBLY LT
RI 0060 PARKLAMP ASSEMBLY RT
E 0083 PANEL,HOOD
L 0083 PANEL,HOOD
0010 PLATE,HOOD LATCH MTG
RI 0086 PAD,INSULATOR HOOD
RI 0142 W/STRIP,HOOD PANEL
E 0153 ROD,HOOD HYDRAULIC RT
I 0071 07 PANEL,RADIATOR SUPT
>> AFTER PULL
L 0071 PANEL,RADIATOR SUPT
E 0080 CRSMBR,RAD PANEL UPR
L 0080 CRSMBR,RAD PANEL UPR
RI 0755
RI 0764
N 0980
EP 0731
E 0105 07
L 0105
RADIATOR
TANK,000LANT RECOVERY
A/C EVAC RECHRG & RCV
CONDENSER,A/C
PNL ASSEMBLY,INR FN LT
PNL ASSEMBLY,INR FN LT
I 0106 07 PNL ASSEMBLY,INR FN RT
>>AFTER PULL
MFR.PART NO.
RECON OEM PART
REFINISH
2.6 SURFACE
0.6 TWO-STAGE SETUP
0.5 TWO-STAGE
R&I ASSEMBLY
R&I ASSEMBLY
R&I ASSEMBLY
25649528 GM PART
R&I ASSEMBLY
RECON OEM PART
RECON OEM PART
25771738 GM PART
R&I ASSEMBLY
R&I ASSEMBLY
25752376 GM PART
REFINISH
3.0 SURFACE
1.2 EDGE
0.8 TWO-STAGE
REPLACE OEM
R&I ASSEMBLY
R&I ASSEMBLY
25698053 GM PART
REPAIR
REFINISH
1.2 SURFACE
0.2 TWO-STAGE
25706782 GM PART
REFINISH
0.2 SURFACE
R&I ASSEMBLY
R&I ASSEMBLY
ADDITIONAL LABOR
AFTERMARKET NEW
12482072 GM PART
REFINISH
0.4 SURFACE
REPAIR
11-08-05 11:46 AT
= CHIPGUARD
= R&I ASSEMBLY
= RELATED PRIOR
PRICE AJ% B% HOURS I
----- --- -- ----- -
314.00 1.3
3.7
INC
INC
INC
122.42 INC
INC
182.25 INC
182.25 INC
206.92 1.1
INC
INC
580.22 1.3
5.0
INC
0.4
INC
56.84 0.1
2.0*
1.4
53.70 0.4
0.2
1.5
0.2
1.8
177.76 1.1
166.78 6.1
0.5
2.0*
L '0106 PNL ASSEMBLY,INR FN RT REFINISH
0.4 SURFACE
0.1 TWO-STAGE
I 0033 07 BRKT,SIDE•MEMBER LT REPAIR
L 0033 BRKT,SIDE MEMBER LT REFINISH
0.4 SURFACE
0.1 TWO-STAGE
I 0034 07 BRKT,SIDE MEMBER RT REPAIR
L 0034 BRKT,SIDE MEMBER RT REFINISH
0.4 SURFACE
0.1 TWO-STAGE
E 0103 FENDER,FRONT LT 25661833 GM PART
L 0103 FENDER,FRONT LT REFINISH
1.8 SURFACE
0.5 EDGE
0.5 TWO-STAGE
I 0104 FENDER,FRONT RT REPAIR
L 0104 FENDER,FRONT RT REFINISH
1.8 SURFACE
-2-
255.31
0.5
1.0*:
0.5 ,
1.0*
0.5 <
1.5
2.8
2.0*
2.2
2004 BUICK LE SABRE CUSTOM 4 DR SEDAN
CLAIM # SUD6719001 LOG 913 -0
0.4 TWO-STAGE
RI 0452 EMBLEM,FRONT FENDER LT R&I ASSEMBLY
RI 0453 EMBLEM,FRONT FENDER RT R&I ASSEMBLY
RI 0111 SKIRT,INNER FENDER LT R&I ASSEMBLY
RI 0112 SKIRT,INNER FENDER RT R&I ASSEMBLY
E 0115 07 SIDE MEMBER ASSEMBL LT 12481570 GM PART
L 0115 SIDE MEMBER ASSEMBL LT REFINISH
0.6 SURFACE
0.1 TWO-STAGE
I 0116 07 SIDE MEMBER ASSEMBL RT REPAIR
L 0116 SIDE MEMBER ASSEMBL RT REFINISH
0.6 SURFACE
0.1 TWO-STAGE
RI 0776 ENGINE & TRANSAXLE AS R&I ASSEMBLY
RI 0699 HOUSING,AIR CLEANER R&I ASSEMBLY
SB 0143 WINDSHIELD,TINTED SUBLET
>>SCOTT KINGS GLASSWORKS 717-732-8865 MOBILE
RI 0149 RESERVOIR,W/S WASHER R&I ASSEMBLY
E 0910 CLOCK SPRING 26089985 GM PART
E 1193 FRAME,INST PANEL MTG 25723897 GM PART
E 0821 MODULE,AIRBAG CONTROL 12227650 GM PART
E 0899 01 PAD,INSTRUMENT PANEL 25710844 GM PART
E 0826 AIRBAG,INSTRUMENT PNL 25729327 GM PART
E 0878 01 AIRBAG,STEERING WHEEL 25732240 GM PART
RI 0180 MLDG,ROCKER PANEL LT R&I ASSEMBLY
RI 0181 MLDG,ROCKER PANEL RT R&I ASSEMBLY
EC M07 PINSTRIPES-TAPE IkEPLACE AFTERMARK
N M14 CORROSION PROTECTION ADDITIONAL LABOR
EC M17 COVER CAR EXTERIOR REPLACE AFTERMARK
I M18 SET-UP AND MEASURE REPAIR
EC M20 ANTI-FREEZE-COOLANT REPLACE AFTERMARK
EC M21 REFRIGERANT REPLACE AFTERMARK
N M67 RESET ELECTRICAL COMPO ADDITIONAL LABOR
E FLEX ADDITIVE REPLACE OEM
SB HAZARDOUS WASTE SUBLET
I COLLISION PULL REPAIR
N STRIPE RMOVAL ADDITIONAL LABOR
70 ITEMS
11-08-05 11:46 Al
330.74
0.2
0.2
INC
0.3
6.1
0.7
2.0*
0.7
9.2
0.3
227.00*
717-503-8865
148.06
373.06
295.42
449.31
694.16
679.22
15.00*
3.00*
12.00*
35.00*
5.00*
3.00*
0.1
0.2
5.6
1.6
0.4
0.2
INC
INC
0.4
0.5*
0.3*
2.0*
0.5*
4.0*
0.2*
MC MESSAGE
01 CALL DEALER FOR EXACT PART # / PRICE
07 STRUCTURAL PART AS IDENTIFIED BY I-CAR
FINAL CALCULATIONS & ENTRIES
PARTS
GROSS PARTS $ 4,417.16
OTHER PARTS $ 921.26
PAINT MATERIAL $ 374.00
ADJUSTMENTS DISCOUNT MARKUP
PARTS & MATERIAL TOTAL $ 5, 712.42
TAX ON PARTS & MATERIAL @ 6.000q $ 342.75
LABOR RATE REPLACE HRS REPAIR HRS
1-SHEET METAL $ 40.00 22.1 12.5 $ 1,384.00
2-MECH/ELEC $ 45.00 18.2 2.3 $ 922.50
3-FRAME $ 42.00 4.0 $ 168.00
4-REFINISH $ 40.00 18.7 $ 748.00
5-PAINT $ 20.00
LABOR TOTAL $ 3, 222.50
TAX ON LABOR @ 6.000% $ 193.35
SUBLET REPAIRS $ 279.95
TAX ON SUBLET @ 6.000% $ 16.80
TOWING $ 325.00
-3-
2004 BUICK LE SABRE CUSTOM 4 DR SEDAN
CLAIM # SUD6719001 LOG 913 -0
STORAGE
11-08-05 11:46 Al
GROSS TOTAL $ 10,092.77
LESS: DEDUCTIBLE UNKNOWN- 4,7 7
NET CORRECTED TOTAL $ 10,092.77 1 o /
PXN Y/04/09/00/00/00 CUM 04/04/00/00/00 GEOCODE: 17325 C' A
ADP PENPRO W0410 CES LOG913 -0 11-08-05 20:28:40 REL 4.10 SW12/04 DT10/?
(C) 1993 - 2004 ADP CLAIMS SOLUTIONS GROUP, INC.
3.6 HRS WERE ADDED TO THIS EST. BASED ON ADP'S TWO-STAGE REFINISH FORMULA.
OEM PARTS ARE AVAILABLE AT MANUFACTURERS' DEALERSHIPS.
-ADDNL=ADDITIONAL, ADP=AUTOMATIC DATA PROCESSING,, AJ%=ADJUSTMENT PERCENTAGE,
B$=BETTERMENT PERCENTAGE, C=CORRECTION, CAPA=CERTIFIED AUTOMOBILE PARTS
ASSOCIATION, ELEC=ELECTRICAL, GDE=GUIDE, HRS=HOURS, MC=MESSAGE CODE,
MECH=MECHANICAL, MFG=MANUFACTURING, MFR=MANUFACTURER, NAGS=NATIONAL AUTOMOTIV]
GLASS ASSOCATION, #=NUMBER, OEM=ORIGINAL EQUIPMENT MANUFACTURER, OP=OPERATION,
PRT=PART, PARTL=PARTIAL, PX=PARTS EXCHANGE, PXN=PARTS EXCHANGE NEW, R=RATE,
REPL=REPLACE, R&I=REMOVE AND INSTALL, S=SUPPLEMENT, SPL=SUPPLIER, SPPL=SALVAG)
COSTS ABOVE THE APPRAISED AMOUNT MAY BE THE RESPONSIBILITY OF THE VEHICLE
OWNER.
THERE IS NO REQUIREMENT THAT THE VEHICLE OWNER USE ANY SPECIFIED REPAIR SHOP.
SHOP.
WE WILL PROVIDE INFORMATION REGARDING REPAIR FACILITIES THAT WILL REPAIR THE
VEHICLE FOR THE APPRAISED AMOUNT IF NECESSARY.IF THE APPRAISAL SPECIFIES USED
PARTS THE PARTS MUST.BE OF LIKE KIND AND QUALITY OR BETTER THAN THOSE BEING
REPLACED.
AFTERMARKET CRASH PART - A NONORIGINAL EQUIPMENT MANUFACTURER (NON-OEM)
REPLACEMENT PART, EITHER NEW OR USED, FOR ANY OF THE NONMECHANICAL PARTS THAT
GENERALLY CONSTITUTE THE EXTERIOR OF THE MOTOR VEHICLE, INCLUDING INNER AND
OUTER PANELS. THIS APPRAISAL WILL INDICATE IF AFTERMARKET CRASH PARTS ARE
SPECIFIED. IF THE USE OF SUCH PARTS VOIDS THE WARRANTY ON THE PART BEING
REPLACED OR ON ANY OTHER PART, THE AFTER MARKET CRASH PART WILL BE WARRANTED
BY THE MANUFACTURER OR INSURANCE COMPANY EQUAL TO OR BETTER THAN THE REMAINDEI
OF THE EXISTING WARRANTY.
THIS ESTIMATE HAS BEEN PREPARED BASED ON THE USE OF AFTERMARKET CRASH PARTS
AND/OR OTHER QUALITY REPLACEMENT PARTS SUPPLIED BY A SOURCE OTHER THAN THE
MANUFACTURER OF YOUR MOTOR VEHICLE.
ANY PERSON WHO KNOWINGLY AND WITH INTENT TO INJURE OR 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
FRAUDUENT INSURANCE ACT, WHICH IS A CRIME AND SUBJECTS THE PERSON TO CRIMINAL
AND CIVIL PENALTIES.
WRITTEN BY:
APPRAISER LIC. #
------------------------------------------------------------------------------
THIS ESTIMATE MAY HAVE BEEN PREPARED BASED ON THE USE OF OTHER AFTERMARKET
PARTS SUPPLIED BY A SOURCE OTHER THAN THE ORIGINAL MANUFACTURER.
SUPPLEMENTAL REPAIR CHARGES MAY BE REJECTED UNLESS APPROVED BY THE TRAVELERS
PRIOR TO REPAIRS. THIS INSTRUMENT IS NOT AN AUTHORIZATION TO REPAIR. REPAIR
MUST BE AUTHORIZED BY THE OWNER.
-4-
CD LOG NO 913 -0 DATE 11-08-05
VEHICLE
2004 BUICK LE SABRE CUSTOM 4 DR SEDAN
6CYL GASOLINE 3.8
OPTIONS
TWO-STAGE - EXTERIOR SURFACES
DRIVER POWER SEAT
TWO-STAGE - INTERIOR SURFACES
REMOTE KEYLESS ENTRY SYSTEM
SUPPLIER PART
PART DESCRIPTION NUMBER
FRONT BUMPER
COVERIFRONT BUMPER
GM1000583R
SUBSTITUTED FOR
OEM PART
NUMBER
12335610
SUPPLIER CLS SRC
CODE
>004 R 3
GM1000583R 12335610 >005
GM1000583R 12335610 >008
FRONT END PANEL AND LAMPS
HEADLAMP ASSY, HALOOEN LT
25713359 25769601 >007
25713359 25769601 >006
HEADLAMP ASSY, HALOGEN RT
25713360 25769600 >007
25713360 25769600 >006
COOLING AND AIR CONDITIONING
CONDENSER,A/C
CNDDP14950 52482155 >001
V2163 52482155 003
CNDDP14950 52482155 >002
> = ESTIMATE TOTAL IS BASED ON PRICE QUOTED BY THIS SUPPLIER
KEY TO CLASSIFICATION/SOURCE CODES
CLS = CLASSIFICATION CODE:
C - CAPA CERTIFIED PART QUOTED BY LISTED SUPPLIER
M - REMANUFACTURED/REBUILT PART
R - RECONDITIONED PART
SRC = SOURCE CODE:
1 - NON ORIGINAL EQUIPMENT MANUFACTURER PART
3 - ORIGINAL EQUIPMENT MANUFACTURER (OEM) PART
DETAILED DISTRIBUTOR LIST
001 - PXN0024 KEYSTONE AUTO
BOX 3658 ROUTE 378
BETHLEHEM, PA 18015
(800) 441-4200 (610) 866-0313
002 - PXN0025 KEYSTONE AUTO
575 MARYLAND AVENUE
YORK, PA 17404
(800) 524-4349 (717) 843-8927
003 - PXN4460 CANFIELD RADIATOR
15 E. 18TH STREET
ERIE, PA 16501
(800) 234-5520 (814) 454-3865
004 - PXN5024 KEYSTONE AUTO RCND
BOX 3658 ROUTE 378
BETHLEHEM, PA 18015
(800) 441-4200 (610) 866-0313
-1-
R 3
R 3
M 3
R 3
M 3
R 3
1
1
1
575 MARYLAND AVENUE
YORK, PA 17404
(800) 524-4349 (717) 843-8927
006 - PXN6809 R P W HEADLAMPS RCND
1809 N 9TH ST PO BOX 125
INDIANOLA, IA 50125
(800) 336-4028 (515) 961-0517
007 - PXN9064 R P W HDLMPS RMFD
1809 N 9TH ST PO BOX 125
INDIANOLA, IA 50125
(800) 336-4028 (515) 961-0517
008 - PXN9119 KEYSTONE NWPP RCND
575 MARYLAND AVENUE
YORK, PA 17404
(800) 524-4349 (717) 843-8927
ADP PENPRO W0410 CES LOG913 -0 11-08-05 20:28:40 REL 4.10 SW12/04 DT10/(
GEOCODE: 17325 SA: CENTRAL PA
(C) 1993 - 2004 ADP CLAIMS SOLUTIONS GROUP, INC.
-2-
TRAVELERS
CLAIM DEPARTMENT
1105 BERKSHIRE BOULEVARD
WYOMISSING, PA 19610-1222
(800) 842-9897
CD LOG NO 1066 -1 11-08-05 11:46 AM
SUPPLEMENT S1 12-07-05 9:52 PM
:LAIM INFORMATION
CLAIM # SUD6719001 POLICY # OPH606029469183101
COMPANY D/R 11/07/05 D/A 11/07/05 CLAIM REP LISA YOUNG 3964
INSURED RAYMOND H BOWERS LOSS DATE 11-06-05
CLAIMANT RAYMOND H BOWERS LOSS TYPE COLLISION
LOSS PAYEE ACCT # P04-S02-DN-R17
INSPECTION
TYPE
PRIMARY POI
APPRAISER NAME
LICENSE #
WORK PHONE
ADDRESS
CITY STATE
ZIP
OWNER
REPAIR
FIELD
FRONT END LEFT
MICHAEL MILKOVICH
264366
(610) 736-2527
PO BOX 11
HIGHSPIRE
17034-1208
RAYMOND H BOWERS
20 NORTH 12TH ST
LEMOYNE PA 17043-0000
ATTN GARY
FORBES CHEVROLET INC.
3400 HARTZDALE DRIVE
CAMP HILL PA 17011-
SHOP PHONE (717) 761-0600
SECOND POI FRONT END RIGHT
FAX (717) 986-0368
INSP DATE 11-08-05
PA LOCATION BECKERS TOWING
CITY STATE CAMP HILL
WORK#
HOME#(717) 763-0252
SHOP LIC#
CAR IN
CAR OUT
REPAIR DAYS
REG. ID 231947103
FAX (717) 441-1367
VEHICLE
2004 BUICK LE SABRE CUSTOM 4 DR SEDAN
6CYL GASOLINE 3.8
OPTIONS
TWO-STAGE - EXTERIOR SURFACES TWO-STAGE - INTERIOR SURFACES
DRIVER POWER SEAT REMOTE KEYLESS ENTRY SYSTEM
ALARM SYSTEM STRG WHEEL MTD RADIO CONTROLS
PA
BODY COLOR WHITE MILEAGE 23,668
CONDITION GOOD VIN 1G4HP52K444108190
LICENSE # WED49 CODE S434
LICENSE STATE PA VEH INSP #
REMARKS:
***APPRAISER AT 800-842-9897 FOR APPROVAL BEFORE REPAIR IS AUTHORIZED*,
SUPPLEMENT: PAY SHOP DIRECT $81.62
*******ALL SUPPLEMENTS MUST B TED DIRECTLY TO THE SUPPLEMENT DESK******
LKQ SEARCH:AUMILLER WEST, NEWBERRYTOWN
24 HR CONTACT: CALLED LEFT AFTERNOON, CONTACT 7:OOPM EVENING
OWNER NOT PRESENT,ESTIMATE MAILED TO OWNER
2004 BUICK LE SABRE CUSTOM 4 DR SEDAN 11-08-05 11:46 Al
C LAIM # S UD6719001 LOG 1066 -1 Sl 12-07-05 9:52 PP
IT = PARTI AL REPAIR I = REPAIR L = REFINISH
BR = BLEND REFINISH TT = TWO-TONE CG = CHIPGUARD
SB = SUBLE T N = ADDITIONAL LABOR RI = R&I ASSEMBL Y
P = CHECK AA = APPEAR ALLOWANCE RP = RELATED PRI OR
UP = UNREL ATED PRIOR
OP
-- GDE MC
--- -- DESCRIPTION
----------- MFR.PART NO.
------------ PRICE AJ% B% HOURS I
PC
0006
COVER,FRONT BUMPER
RECON OEM PART ----- --- --
314.00
Sl ----- -
1.2
L 0006 COVER,FRONT BUMPER REFINISH 3.7
2.6 SURFACE
0.6 TWO-STAGE SE TUP
0.5 TWO-STAGE
RI 0100 EXTN,FRONT BUMPER 0 RT R&I ASSEMBLY INC
RI 0099 EXTN,FRONT BUMPER 0 LT R&I ASSEMBLY INC
RI 0799 DEFL,FRONT BUMPER LWR R&I ASSEMBLY INC
E 0007 ABSORBER,FRONT ENERGY 25649528 GM PART 127.32* -10 Sl INC
RI 0011 GRILLE ASSEMBLY R&I ASSEMBLY INC
E 0041 HEADLAMP ASSY,HALOG LT 25769601 GM PART 189.50* -10 S1 INC
E 0042 HEADLAMP ASSY,HALOG RT 25769600 GM PART 189.50* -10 Sl INC
N 0973 HEADLAMPS AIM ADDITIONAL LABOR S1 0.4
E 0045 P.ANEL,HEADLAMP MTG 25771738 GM PART 206.92 -10 S1 1.1
RI 0059 PARKLAMP ASSEMBLY LT R&I ASSEMBLY INC
RI 0060 PARKLAMP ASSEMBLY RT R&I ASSEMBLY INC
E 0083 PANEL,HOOD 25752376 GM PART 580.22 -10 S1 1.3
L 0083 PANEL,HOOD REFINISH 5.0
3.0 SURFACE
1.2 EDGE
0.8 TWO-STAGE
E 0159 STRIKER,HOOD LATCH 25711274 GM PART 19.01 -10 S1 INC
0010 PLATE,HOOD LATCH MTG REPLACE OEM INC S1
E 0052 HINGE,HOOD PANEL LT 10355392 GM PART 16.40 -10 Si 0.1
L 0052 HINGE,HOOD PANEL LT REFINISH S1 0.2
0.2 SURFACE
E 0053 HINGE,HOOD PANEL RT 10355391 GM PART 16.87 -10 S1 0.1
L 0053 HINGE,HOOD PANEL RT REFINISH S1 0.2
0.2 SURFACE
E 0084 HINGE,HOOD PANEL LT 12481362 GM PART 18.15 -10 S1 INC
L 0084 HINGE,HOOD PANEL LT REFINISH S1 0.2
0.2 SURFACE
E 0085 HINGE,HOOD PANEL RT 12481361 GM PART 18.15 -10 S1 INC
L 0085 HINGE,HOOD PANEL RT REFINISH S1 0.2
0.2 SURFACE
RI 0086 PAD,INSULATOR HOOD R&I ASSEMBLY 0.4
RI 0142 W/STRIP,HOOD PANEL R&I ASSEMBLY INC
E 0152 ROD,HOOD HYDRAULIC LT 25698053 GM PART 56.84 -10 S1 INC
>> AFTER PULL
L 0071 PANEL,RADIATOR SUPT REFINISH 1.4
1.2 SURFACE
0.2 TWO-STAGE
E 0080 CRSMBR,RAD PANEL UPR 25706782 GM PART 53.70 -10 S1 0.4
L 0080 CRSMBR,RAD PANEL UPR REFINISH 0.2 ,
0.2 SURFACE
RI 0755 RADIATOR R&I ASSEMBLY 1.5
RI 0764 TANK,OOOLANT RECOVERY R&I ASSEMBLY S1 INC
N 0980 A/C EVAC RECHRG & RCV ADDITIONAL LABOR 1,8 ;
EP 0731 CONDENSER,A/C AFTERMARKET NEW 177.76 1.1
E 0105 07 PNL ASSEMBLY,INR FN LT 12482072 GM PART 166.78 -10 S1 6.0
L 0105 PNL ASSEMBLY,INR FN LT REFINISH 0.5
0.4 SURFACE
0.1 TWO-STAGE
E 0106 07 PNL ASSEMBLY,INR FN RT 12482071 GM PART 166.78 -10 S1 4.9
L 0106 PNL ASSEMBLY,INR FN RT REFINISH 0.5
0.4 SURFACE
0.1 TWO-STAGE
E 0134 07 REINF,INNER FENDER LT 25645786 GM PART 19.85 -10 S1 2.5
L 0134 REINF,INNER FENDER LT REFINISH S1 0.1 <
-2-
2004 BUICK LE SABRE CUSTOM 4 DR SEDAN 11-08-05 11:46 Al
CLAIM # SUD6719001 LOG 1066 -1 S1 12-07-05 9:52 PP
0.1 SURFACE
E 0157 07 REINF,INNER FENDER LT 12480929 GM PART 29.66 -10 S1 2.5 .
L 0157 REINF,INNER FENDER LT REFINISH S1 0.2
0.2 SURFACE
I 0033 07 BRKT,SIDE MEMBER LT REPAIR 1.0*
L 0033 BRKT,SIDE MEMBER LT REFINISH 0.5 <
0.4 SURFACE
0.1 TWO-STAGE
I 0034 07 BRKT,SIDE MEMBER RT REPAIR 1.0*:
L 0034 BRKT,SIDE MEMBER RT REFINISH 0.5
0.4 SURFACE
0.1 TWO-STAGE
E 0103 FENDER,FRONT LT 25661833 GM PART 255.31 -10 Si 1.5 .
L 0103 FENDER,FRONT LT REFINISH 2.8 .
1.8 SURFACE
0.5 EDGE
0.5 TWO-STAGE
I 0104 FENDER,FRONT RT REPAIR 2.0*
L 0104 FENDER,FRONT RT REFINISH 2.2 .
1.8 SURFACE
0.4 TWO-STAGE
RI 0104 FRONT FENDER R & I RT R&I ASSEMBLY S1 1.4
RI 0452 EMBLEM,FRONT FENDER LT R&I ASSEMBLY 0.2
RI 0453 EMBLEM,FRONT FENDER RT R&I ASSEMBLY 0.2
RI 0111 SKIRT,INNER FENDER LT R&I ASSEMBLY INC
RI 0112 SKIRT,INNER FENDER RT R&I ASSEMBLY S1 INC
E 0115 07 SIDE MEMBER ASSEMBL LT 12481570 GM PART 330.74 -10 S1 6.1
L 0115 SIDE MEMBER ASSEMBL LT REFINISH 0.7
0.6 SURFACE
0.1 TWO-STAGE
I 0116 07 SIDE MEMBER ASSEMBL RT REPAIR 2.0*
L 0116 SIDE MEMBER ASSEMBL RT REFINISH 0.7
0.6 SURFACE
0.1 TWO-STAGE
SB 0143 WINDSHIELD,TINTED SUBLET 227.00*
>>SCOTT KINGS GLASSWORKS 71 7-732-8865 MOBILE 717-503-8865
RI 0149 RESERVOIR,W/S WASHER R&I ASSEMBLY 0.1
E 0367 PANEL,COWL TOP 10382560 GM PART 100.36 -10 S1 0.4
E 0910 CLOCK SPRING
E 1193 FRAME,INST PANEL MTG
E 0821 MODULE,AIRBAG CONTROL
E 0899 01 PAD,INSTRUMENT PANEL
I 0865 BEZEL,INSTRUMENT PNL
E 0826 AIRBAG,INSTRUMENT PNL
E 0878 01 AIRBAG,STEERING WHEEL
RI 0180 MLDG,ROCKER PANEL LT
RI 0181 MLDG,ROCKER PANEL RT
EC M07 PINSTRIPES-TAPE
N M14 CORROSION PROTECTION
EC M17 COVER CAR EXTERIOR
I M18 SET-UP AND MEASURE
EC M20 ANTI-FREEZE-COOLANT
EC M21 REFRIGERANT
N M67 RESET ELECTRICAL COMPO
E FLEX ADDITIVE
SB 2 WHEEL ALIGNMENT
SB HAZARDOUS WASTE
I COLLISION PULL
N STRIPE RMOVAL
86 ITEMS
26089985 GM PART 148.06 -10 S1 0.2
25723897 GM PART 373.06 -10 S1 5.6
12227650 GM PART 295.42 -10 S1 1.6
25710844 GM PART 449.31 -10 S1 0.4
REPAIR SI 2.0*.
25729327 GM PART 694.16 -10 S1 0.2
25732240 GM PART 694.16* -10 S1 INC
R&I ASSEMBLY INC
R&I ASSEMBLY S1 INC
REPLACE AFTERMARK 15.00* 0.5*
ADDITIONAL LABOR 0.3*
REPLACE AFTERMARK 3.00*
REPAIR 2.0*
REPLACE AFTERMARK 12.00*
REPLACE AFTERMARK 35.00*
ADDITIONAL LABOR 0.5*;
REPLACE OEM 5.00* -10 S1
SUBLET 49.95*
SUBLET 3.00*
REPAIR 4.0*:
ADDITIONAL LABOR 0.2*
MC MESSAGE
01 CALL DEALER FOR EXACT PART # / PRICE
07 STRUCTURAL PART AS IDENTIFIED BY I-CAR
-3-
2004 BUICK LE SABRE CUSTOM 4 DR SEDAN
CLAIM # SUD6719001 LOG 1066
FINAL CALCULATIONS & ENTRIES
PARTS
GROSS PARTS
OTHER PARTS
PAINT MATERIAL
ADJUSTMENTS DISCOUNT MARKUP
LINE ITEMS $ 529.18
PARTS & MATERIAL TOTAL
TAX ON PARTS & MATERIAL @ 6.000%
11-08-05 11:46 At
-1 S1 12-07-05 9:52 PP
$ 5,291.84
$ 556.76
$ 396.00
$ 5,715.42
$ 342.93
LABOR RATE REPLACE HRS REPAIR HRS
1-SHEET METAL $ 40.00 32.8 12.9 $ 1,828.00
2-MECH/ELEC $ 45.00 9.0 2.3 $ 508.50
3-FRAME $ 42.00 4.0 $ 168.00
4-REFINISH $ 40.00 19.8 $ 792.00
5-PAINT $ 20.00
LABOR TOTAL $ 3,296.50
TAX ON LABOR @ 6.0008 $ 197.79
SUBLET REPAIRS $ 279.95
TAX ON SUBLET @ 6.000% $ 16.80
STORAGE
GROSS TOTAL
LESS: DEDUCTIBLE
$ 10,174.39
UNKNOWN-
NET TOTAL $ 10,174.39
RATES/TAXES ADJUSTMENT S1
LESS: PREVIOUS NET TOTAL $ 10,092.77-
NET SUPPLEMENT TOTAL
81.62
PXN Y/02/00/00/02/02 CUM 04/02/00/02/02 GEOCODE: 17325 CENTRAL PA
ADP PENPRO W0410 S1 LOG1066 -1 12-08-05 09:53:15 REL 4.10 SW12/04 DT11/(
(C) 1993 - 2004 ADP CLAIMS SOLUTIONS GROUP, INC.
3.6 HRS WERE ADDED TO THIS EST. BASED ON ADP's TWO-STAGE REFINISH FORMULA.
OEM PARTS ARE AVAILABLE AT MANUFACTURERS' DEALERSHIPS.
-ADDNL=ADDITIONAL, ADP=AUTOMATIC DATA PROCESSING,, AJ%=ADJUSTMENT PERCENTAGE,
B$=BETTERMENT PERCENTAGE, C=CORRECTION, CAPA=CERTIFIED AUTOMOBILE PARTS
ASSOCIATION, ELEC=ELECTRICAL, GDE=GUIDE, HRS=HOURS, MC=MESSAGE CODE,
MECH=MECHANICAL, MFG=MANUFACTURING, MFR=MANUFACTURER, NAGS=NATIONAL AUTOMOTIVI
GLASS ASSOCATION, #=NUMBER, OEM=ORIGINAL EQUIPMENT MANUFACTURER, OP=OPERATION,
PRT=PART, PARTL=PARTIAL, PX=PARTS EXCHANGE, PXN=PARTS EXCHANGE NEW, R=RATE,
REPL=REPLACE, R&I=REMOVE AND INSTALL, S=SUPPLEMENT, SPL=SUPPLIER, SPPL=SALVAGI
PART PRICE LOCATOR, VIN=VEHICLE IDENTIFICATION NUMBER
COSTS ABOVE THE APPRAISED AMOUNT MAY BE THE RESPONSIBILITY OF THE VEHICLE
OWNER.
THERE IS NO REQUIREMENT THAT THE VEHICLE OWNER USE ANY SPECIFIED REPAIR SHOP.
SHOP.
WE WILL PROVIDE INFORMATION REGARDING REPAIR FACILITIES THAT WILL REPAIR THE
VEHICLE FOR THE APPRAISED AMOUNT IF NECESSARY.IF THE APPRAISAL SPECIFIES USED
PARTS THE PARTS MUST BE OF LIKE KIND AND QUALITY OR BETTER THAN THOSE BEING
REPLACED.
AFTERMARKET CRASH PART - A NONORIGINAL EQUIPMENT MANUFACTURER (NON-OEM)
REPLACEMENT PART, EITHER NEW OR USED, FOR ANY OF THE NONMECHANICAL PARTS THAT
GENERALLY CONSTITUTE THE EXTERIOR OF THE MOTOR VEHICLE, INCLUDING INNER AND
OUTER PANELS. THIS APPRAISAL WILL INDICATE IF AFTERMARKET CRASH PARTS ARE
-4-
2004 BUICK LE SABRE CUSTOM 4 DR SEDAN 11-08-05 11:46 AI
CLAIM # SUD6719001 LOG 1066 -1 S1 12-07-05 9:52 P1
SPECIFIED. IF THE USE OF SUCH PARTS VOIDS THE WARRANTY ON THE PART BEING
REPLACED OR ON ANY OTHER PART, THE AFTER MARKET CRASH PART WILL BE WARRANTED
BY THE MANUFACTURER OR INSURANCE COMPANY EQUAL TO OR BETTER THAN THE REMAINDE'
OF THE EXISTING WARRANTY.
THIS ESTIMATE HAS BEEN PREPARED BASED ON THE USE OF AFTERMARKET CRASH PARTS
AND/OR OTHER QUALITY REPLACEMENT PARTS SUPPLIED BY A SOURCE OTHER THAN THE
MANUFACTURER OF YOUR MOTOR VEHICLE.
ANY PERSON WHO KNOWINGLY AND WITH INTENT TO INJURE OR DEFRAUD ANY INSURANCE
COMPANY OR OTHER PERSON FILES AN APPLICATION FOR INSURANCE OR STATEMENT OF
OF MISLEADING, INFORMATION CONCERNING ANY FACT MATERIAL THERETO COMMITS A
FRAUDUENT INSURANCE ACT, WHICH IS A CRIME AND SUBJECTS THE PERSON TO CRIMINAL
AND CIVIL PENALTIES.
WRITTEN BY:
APPRAISER LIC. #
1 _ _ _ _ _ _ _ _ _ _ _
THIS ESTIMATE MAY HAVE BEEN PREPARED BASED ON THE USE OF OTHER AFTERMARKET
PARTS SUPPLIED BY A SOURCE OTHER THAN THE ORIGINAL MANUFACTURER.
SUPPLEMENTAL REPAIR.CHARGES MAY BE REJECTED UNLESS APPROVED BY THE TRAVELERS
PRIOR TO REPAIRS. THIS INSTRUMENT IS NOT AN AUTHORIZATION TO REPAIR. REPAIR
MUST BE AUTHORIZED BY THE OWNER.
-5-
CD LOG NO 1066 -1 DATE 12-08-05
VEHICLE
2004 BUICK LE SABRE CUSTOM 4 DR SEDAN
6CYL GASOLINE 3.8
OPTIONS
TWO-STAGE - EXTERIOR SURFACES TWO-STAGE - INTERIOR SURFACES
VERIFICATION
George B. Faller, Jr., Esquire, ofthe firm ofMARTSON DEARDORFF WILLIAMS & OTTO,
attorneys for Defendant Raymond H. Bowers in the within action, certifies that the statements made in the
foregoing Additional Defendant Complaint are true and correct to the best ofhis knowledge, information
and belief. He understands that false statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904 relating to unworn falsificatioi
F.MLFS\ ATAnUL Tmwlm30W\Cw \833\adddefconp
CERTIFICATE OF SERVICE
I, Ami J. Thumma, an authorized agent forMartson Deardorff Williams & Otto, hereby certifythat
a copy ofthe foregoing Additional Defendant Complaint was served this date by depositing same in the
Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows:
Michael L. Bangs, Esquire
BANGS LAW OFFICE
429 South 18th Street
Camp Hill, PA 17011
MARTSON DEARDORFF WILLIAMS & OTTO
By
R w2s' ML
Ami J. Th
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: 0l ( s/b
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Created. 4/11/06 254PM
Revised: 6/28/06 9.IIAM
George B. Faller, Jr., Esquire
Hillary A. Dean, Esquire
MARTSON DEARDORFF WILLIAMS & OTTO
I.D. Nos. 49813 and 92878
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Defendant Raymond H. Bowers
ROBERT M. STAIGER,
Plaintiff
V.
RAYMOND H. BOWERS,
Defendant
v.
ASHLEE STAIGER,
Additional Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-1054
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
PRAECIPE
To the Prothonotary:
Please substitute the attached Verification ofRaymond H. Bowers for the attorney Verification filed
with the Additional Defendant Complaint.
& OTTO
By 1't ' U
George B. Faller, Jr., quire
Hillary A. Dean, Esquire
MARTSON DEARDORFF WILLIAMS & OTTO
I.D. Nos. 49813 and 92878
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Date: ?¢ /3010el Attorneys for Defendant
VERIFICATION
The foregoing Additional Defendant Complaint is based upon information which has been gathered
bymy counsel in the preparation ofthe lawsuit. The language of the document is that of counsel and not
my own. I have read the document and to the extent that it is based upon information which I have given
to my counsel, it is true and correct to the best ofmy knowledge, information and belief. To the extent that
the content of the document is that of counsel, I have relied upon counsel in making this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unswom falsification to authorities, which provides that ifl make knowingly false averments, I
may be subject to criminal penalties.
Raymon . Bowers
FiFILES\OATAFlLE\Tmvdees3M9 Cu t\838\adddefcom
CERTIFICATE OF SERVICE
I, Mary M. Price, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that
a copy ofthe foregoing Praecipe to substitute Verification was served this date by depositing same in the
Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows:
Michael L. Bangs, Esquire
BANGS LAW OFFICE
429 South 18th Street
Camp Hill, PA 17011
MARTSON DEARDORFF WILLIAMS & OTTO
By / A , ? Atc )
Maryrice
Ten Eas High Street
Carlisle, PA 17013
(717) 243-3341
Dated: G 13 f) 10?
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Johnson, Duffle, Stewart & Weidner
By: Kelly L. Bonanno
I.D. No. 200811 Attorneys for Additional Defendant
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
klb@jdsw.com
ROBERT M. STAIGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2006-1054
RAYMOND H. BOWERS, CIVIL ACTION - LAW
Defendant
JURY TRIAL DEMANDED
V.
ASHLEE STAIGER,
Additional Defendant
APPEARANCE
AND NOW, this 2y4 4 1day of July, 2006, enter the appearance of KELLY L. BONANNO,
I.D. 200811, on behalf of Additional Defendant in the above captioned suit.
JOHNSON, DUFFIE, STEWART & WEIDNER
By:
Kelly L. o anno
:279820
22740-2113
CERTIFICATE OF SERVICE
AND NOW, this a)? 'day of July, 2006, the undersigned does hereby certify that she did
this date serve a copy of the foregoing document upon the other parties of record by causing
same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne,
Pennsylvania, addressed as follows:
Michael L. Bangs, Esquire
429 South 1 e Street
Camp Hill, PA 17011
George B. Faller, Jr., Esquire
Hillary A. Dean, Esquire
Martson, Deardorff, Williams & Otto
10 East High Street
Carlisle, PA 17013
JOHNSON, DUFFLE, STEWART & WEIDNER
By: O;'/
ichelle H. Spangler
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Johnson, Duffle, Stewart & Weidner
By: Kelly L. Bonanno
I.D. No. 200811
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
klb@jdsw.com
ROBERT M. STAIGER
v
Plaintiff
RAYMOND H. BOWERS
Defendant
V.
ASHLEE STAIGER,
Additional Defendant
NOTICE TO PLEAD
TO: Robert M. Staiger
c/o Michael L. Bangs, Esquire
Raymond H. Bowers
c/o George B. Faller, Jr., Esquire
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
AND NOW, this 71?(' day of September, 2006, you are hereby notified to plead
responsively within twenty (20) days of the date of service hereof, or judgment may be entered
against you.
:279802
Attorneys for Additional Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-1054
JOHNSON, DUFFIE, STEWART & WEIDNER
By:
Kelly onanno
Johnson, Duffle, Stewart & Weidner
By: Kelly L. Bonanno
I.D. No. 200811
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
klb@jdsw.com
Attorneys for Additional Defendant
ROBERT M. STAIGER
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-1054
v
RAYMOND H. BOWERS
CIVIL ACTION - LAW
Defendant
V.
ASHLEE STAIGER,
Additional Defendant
JURY TRIAL DEMANDED
ANSWER WITH NEW MATTER TO ADDITIONAL DEFENDANT COMPLAINT
AND NOW, comes the Additional Defendant, Ashlee Staiger, by and through her
attorney, Kelly L. Bonanno and Johnson, Duffle, Stewart & Weidner, and files the following
Answer and New Matter to Plaintiffs Additional Defendant Complaint as follows:
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted.
5. Admitted.
6. Admitted.
WHEREFORE, the Additional Defendant Ashlee Staiger respectfully requests that this
Honorable Court enter judgment in her favor and that Defendant's Additional Defendant
Complaint be dismissed with prejudice.
COUNTI
CONTRIBUTION OR INDEMNITY
7. Denied. The averments contained in Paragraph 7 are such that no response is
required. To the extent that a response is deemed to be required, the averments contained
therein are specifically denied.
8. Denied. After reasonable investigation, the Additional Defendant it without
sufficient knowledge or information to form a belief as to the truth of the averments of Paragraph
8 and the same are therefore denied.
9. Denied. After reasonable investigation, the Additional Defendant it without
sufficient knowledge or information to form a belief as to the truth of the averments of Paragraph
9 and the same are therefore denied.
10. Denied. After reasonable investigation, the Additional Defendant it without
sufficient knowledge or information to form a belief as to the truth of the averments of Paragraph
10 and the same are therefore denied.
WHEREFORE, the Additional Defendant Ashlee Staiger respectfully requests that this
Honorable Court enter judgment in her favor and that Defendant's Additional Defendant
Complaint be dismissed with prejudice.
COUNT II
COUNTERCLAIM
11. Denied. The averments contained in Paragraph 11 are such that no response is
required. To the extent that a response is deemed to be required, the averments contained
therein are specifically denied.
12. Denied. After reasonable investigation, the Additional Defendant it without
sufficient knowledge or information to form a belief as to the truth of the averments of Paragraph
12 and the same are therefore denied.
WHEREFORE, the Additional Defendant Ashlee Staiger respectfully requests that this
Honorable Court enter judgment in her favor and that Defendant's Additional Defendant
Complaint be dismissed with prejudice.
NEW MATTER
By way of additional answer, the Defendant interposes the following New Matter
Defenses:
16. The Defendant has failed to state a cause of action for which relief may be
granted.
17. The Additional Defendant was in no way negligent.
18. That Defendant's alleged cause of action may be barred in whole or in part by
the Pennsylvania Comparative Negligence Act.
19. That the Defendant's comparative negligence included:
a. failing to observe oncoming traffic, entering the intersection lawfully with a
green light;
b. carelessness in entering the intersection;
C. inattentiveness and reckless disregard for others also lawfully in the
roadway; and
20. That the Defendant's comparative negligence was a substantial factor, or factual
cause, in the alleged accident and injuries.
21. That if it should be found that the Additional Defendant was negligent, which is
denied, then Additional Defendant's negligence was not a substantial factor, nor factual cause
of Defendant's alleged damages.
WHEREFORE, the Additional Defendant Ashlee Staiger, respectfully requests that this
Honorable Court enter judgment in her favor and that Defendant's Additional Defendant
Complaint be dismissed with prejudice.
Respectfully submitted,
JOHNSON, DUFFIE, STEWART & WEIDNER
By
' KellyN Bbnanno'
Attorneys I.D. #: 200811
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
e-mail: klb@jdsw.com
Date: " 7, Z604, Attorneys for Additional Defendant
VERIFICATION
The undersigned says that the facts set forth in the foregoing document are true and
correct. This verification is made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to
unsworn falsifications to authorities.
Ashlee Staiger
Dated: A-im st aaQnf a
-z
CERTIFICATE OF SERVICE
AND NOW, this ? day of September, 2006, the undersigned does hereby certify that
she did this date serve a copy of the foregoing document upon the other parties of record by
causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne,
Pennsylvania, addressed as follows:
Michael L. Bangs, Esquire
429 South 18th Street
Camp Hill, PA 17011
George B. Faller, Jr., Esquire
Hillary A. Dean, Esquire
Martson, Deardorff, Williams & Otto
10 East High Street
Carlisle, PA 17013
JOHNSON, DUFFIE, STEWART & WEIDNER
By:
chelle H. Spangler
ct? 'T -ra
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MICHAEL L. BANGS, ESQUIRE
I.D. No. 41263
429 South 18'h Street
Camp Hill, PA 17011
(717) 730-7310
ATTORNEY FOR PLAINTIFF
ROBERT M. STAIGER,
Plaintiff
vs.
RAYMOND H. BOWERS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-1054 CIVIL
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
vs.
ASHLEE STAIGER
RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the following form:
PETITION FOR APPOINTMENT OF ARBITRATORS
TO THE HONORABLE, THE JUDGES OF SAID COURT:
MICHAEL L. BANGS, counsel for the Plaintiff in the above action, respectfully represents that:
1. The above-captioned action is at issue.
2. The claim of the Plaintiff in the action is $5,000.00, plus interest plus costs of
suit. The counterclaim of the Defendant in the action is $10,358.36, plus interest and costs of
suit.
The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators:
Michael L. Bangs, Esquire (attorney for Plaintiff); George B. Faller, Jr., Esquire (attorney for Defendant); and
Kelly L. Bonanno, Esquire (attorney for Additional Defendant).
WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the
case shall be submitted.
Respectfully submitted,
Z
MICHAEL L. BA
ORDER OF COURT
AND NOW, , 2006, in consideration of the foregoing petition,
Esquire, , Esquire, and
Esquire, are appointed arbitrators in the above-captioned action (or actions) as prayed for.
BY THE COURT,
P.J.
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MICHAEL L. BANGS, ESQUIRE
I.D. No. 41263
429 South 180' Street
Camp Hill, PA 17011
(717) 730-7310
ROBERT M. STAIGER,
Plaintiff
vs.
RAYMOND H. BOWERS,
Defendant
ATTORNEY FOR PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-1054 CIVIL
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
vs.
ASHLEE STAIGER
RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the following form:
PETITION FOR APPOINTMENT OF ARBITRATORS
TO THE HONORABLE, THE JUDGES OF SAID COURT:
MICHAEL L. BANGS, counsel for the Plaintiff in the above action, respectfully represents that:
1. The above-captioned action is at issue.
2. The claim of the Plaintiff in the action is $5,000.00, plus interest plus costs of
suit. The counterclaim of the Defendant in the action is $10,358.36, plus interest and costs of
suit.
The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators:
Michael L. Bangs, Esquire (attorney for Plaintiff); George B. Faller, Jr., Esquire (attorney for Defendant); and
Kelly L. Bonanno, Esquire (attorney for Additional Defendant).
WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the
case shall be submitted.
Respectfully submitted, Z A-.?7
MICHAEL L. BA
ORDER OF COURT
ND NOW, ah- f 1 , 2006, in considerat of the foregoing petition,
Esquire, 4kTL*u4, U. , Esquire, and .6
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are a pointed arbitrators in the above- ptioned?etie? (or actions) as prayed for"
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Created: 4/17/06 2:54PM
Revised. 10/6/06 9:50AM
George B. Faller, Jr., Esquire
I.D. No. 49813
Hillary A. Dean, Esquire
I.D. No. 92878
MARTSON DEARDORFF WILLIAMS & OTTO
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Defendant Raymond H. Bowers
ROBERT M. STAIGER,
Plaintiff
V.
RAYMOND H. BOWERS,
Defendant
V.
ASHLEE STAIGER,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2006-1054
CIVIL ACTION - LAW
Additional Defendant : JURY TRIAL DEMANDED
DEFENDANT'S REPLY TO ADDITIONAL DEFENDANT'S
ANSWER WITH NEW MATTER TO DEFENDANT'S COMPLAINT
AND NOW, comes Defendant, Raymond H. Bowers, by and through his attorneys, MARTSON
DEARDORFF WILLIAMS & OTTO, and avers as follows:
16-21. Denied pursuant to Pa. R.C.P. 1029 (e). Averments 16-21 are denied as conclusions of
law to which no response is required.
WHEREFORE, Defendant Raymond H. Bowers, respectfully requests that this Honorable Court
enter judgment in his favor.
MARTSO ARDORFF WILL S OTTO
By
George B. F r, Jr., Esquire
Hillary A. Dean, Esquire
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Date: October 6, 2006 Attorneys for Defendant Raymond H. Bowers
A
CERTIFICATE OF SERVICE
I, Melissa A. Scholly, an authorized agent for Martson Deardorff Williams & Otto, hereby certify
that a copy of the foregoing Defendant's Reply to Additional Defendant's Answer with New Matter to
Defendant's Complaint was served this date by depositing same in the Post Office at Carlisle, PA, first
class mail, postage prepaid, addressed as follows:
Michael L. Bangs, Esquire
BANGS LAW OFFICE
429 South 18th Street
Camp Hill, PA 17011
Counsel for Plaintiff
Kelly L. Bonanno, Esquire
JOHNSON DUFFIE STEWART & WEIDNER
301 Market Street
P.O. Box 109
Lemoyne, PA 17043
Counsel for Additional Defendant Ashlee Staiger
MARTSON DEARDORFF WILLIAMS & OTTO
Byf ?{? ti t 1
Melissa A. Scholly
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: October 6, 2006
na
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4?_7 y9
ROBERT M. STAIGER, COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
RAYMOND H. BOWERS,
DEFENDANTS 06-1054 CIVIL TERM
ORDER OF COURT
AND NOW, this 2nd day of January, 2007, the appointment of
John E. Slike, Esquire, as chairman on the Board of Arbitrators in the above-captioned
case, IS VACATED. Thomas E. Flower, Esquire, is appointed in his place.
By t rt,
C,
Edgar B. Bayley, J.
Xhomas E. Flower, Esquire
Court Administrator
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ROBERT M. STAIGER
V.
RAYMDM H- BOWERS
In The Court of Common Pleas of Cumberland
County, Pennsylvania No. 06 - 1054
Plaintiff
Defendant
V.
ASHLEE STAIGER
Oath
We do solemnly swear (or affirm) that we will sup
States and the Constitution of this Co n a
'th fidelity.
Signature Si ture
Thomas E. Flower
Name (Chairman)
SAIDIS, FLOWER &
Law Firm LINDSAY
2109 Market Street
Address
Camp Hill, PA 17011
City, zip
Civil Action - Law.
port, obey and defend the Constitution of the United
and that we will discharge the duties of our office
Dennis J. Bonetti
Name
CIPRIANI & WERM
Law Firm
1011 Mmma Road
Address ui-te 201
TPxocVntzpA 17043
City, Zip
A",
gnature
Philip C. Brigan i
Name
TAW OFFTCT- or PHTT.TP C.
Law Firm BRIGANI'I
74 W. Pomfret Street
Address
Carlisle, PA 17013
City, Zip
. r?vi?rator, aissents. kmsert name it applicable.)
Date of Hearing:1 3 p 14 Date of Award: 6 11o3 "A')49 -
p
Notice of Entry of Award
Now, the d Yday of , 20 07 , at 161!40 , P M., the above award was
entered upon the docket and notice thereof given by mail to the parties or their attorneys.
Arbitrators' compensation to be paid upon appeal: $ p796. 00
By:
7-Prothonotary
Deputy
Award
We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the
following award: (Note: If damages for delay are awarded, they shall be separately stated.)
640
V
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MICHAEL L. BANGS, ESQUIRE ATTORNEY FOR PLAINTIFF
I.D. NO. 41263
429 South 18'' Street
Camp Hill, PA 17011
(717) 730-7310
ROBERT M. STAIGER, ) IN THE COURT OF COMMON PLEAS
Plaintiff ) OF CUMBERLAND COUNTY,
PENNSYLVANIA
VS. )
NO. 2006-1054
RAYMOND H. BOWERS, )
Defendant ) CIVIL ACTION - LAW
VS. ) JURY TRIAL DEMANDED
ASHLEE STAIGER, )
Additional Defendant )
PRAECIPE
TO THE PROTHONOTARY:
Please mark the above-referenced matter satisfied and discontinued.
Respectfully submitted,
MICHAEL L. BANG
Attorney for Plaintiff
429 South 18th Street
Camp Hill, PA 17011
(717) 730-7310
Supreme Court ID #41263
Date: "' dko_
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ROBERT M. STAIGER In The Court of Common Pleas of Cumberland
Plaintiff
V.
RAYMOND H. BOWERS
Defendant
V.
ASHLEE STAIGER
Oath
We do solemnly swear (or affirm) that we will sup
States and the Constitution of this Com n a
th fidelity.
Signature Si ture
Thomas E. Flower
Name (Chairman)
SAIDIS, FLOWER &
Law Firm LINDSAY
2109 Market Street
Address
Camp Hill, PA 17011
City, Zip
County, Pennsylvania No. 06 - 1054
Civil Action - Law.
port, obey and defend the Constitution of the United
and that we will discharge the duties of our office
Dennis J. Bonetti
Name
CIPRIANI & WERNER
Law Firm
1011 Mmna Road
Address ulte 201
T.e= ne., PA 17043
City, zip
gnature
Philip C. Briganti
Name
LAW OFFICE OF PHTT.TP C.
Law Firm BRIGANTI
74 W. Pomfret Street
Address
Carlisle, PA 17013
City, zip
# 18898 -4 1031 `7
IMal Award
We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the
following award: (Note: If damages for delay are awarded, they shall be separately stated.)
. Arbitrator, dissents. (Insert name if applicable.)
3 D
Date of Hearing: e 1 1/0
Date of Award: C Q
Notice of Entry of Award
90
Now, the o?3"d day of \JanLzu , 2007 , at /a'qO , _•M., the above award was
entered upon the docket and notice thereof given by mail to the parties or their attorneys.
Arbitrators' compensation to be paid upon appeal: $ 00.00
By:
Prothonotary Deputy
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