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Home My WebLink About06-1530 2023363 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No. : 81894 21 S. 21"' Street Philadelphia, PA 19103 (215) 988-9600 Attorney for Plaintiff Erie Insurance Company, Individually and as Subrogee on behalf of Janet Corl and Gary Corl 4901 Louise Drive Mechanicsburg PA 17055-0710 and Janet Corl and Gary Corl 3225 Andrea Avenue Harrisburg, PA 17109 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 01." - / SJ6 Cu~tr~ Russ Rineer 104 South 17 Street Camp Hill PA 17011 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 JUDGEMENT 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 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT IN CIVIL ACTION 1. Janet Corl and Gary Corl (the "Plaintiffs"), are adult individuals residing at the address above captioned. 2. Plaintiff, Erie Insurance Company, is a corporation duly authorized to conduct business within the Commonwealth of Pennsylvania, and is subrogated to the rights of the Plaintiff arising out of the within claim. 3. Russ Rineer, (the "Defendant"), is an individual residing at the above-captioned address. 4. On or about December 20, 2004, the Plaintiffs did own premises 3225 Andrea Avenue, Harrisburg, Pennsylvania, involved in the incident hereinafter referred to. 5. Defendant was hired by the Plaintiffs to perform remodeling work at their residence. 6. Defendant failed to finish said contracted work and, on or about December 20, 2004,as a result of Defendant's failure to complete the work, the water pipes in Plaintiffs' residence burst, causing damage to said premises. 7. As a result of Defendant's negligence, the Plaintiffs' residence sustained damages in the amount of $4,491.00. 8. At all times material hereto the plaintiffs were insured by plaintiff, Erie Insurance Company. 9. As a further result of the defendant's negligence, Erie Insurance Company has made compensation for said property loss to 2 ~ the plaintiffs. 10. Plaintiff Erie Insurance Company individually and as subrogee on behalf of the plaintiff, Janet Corl and Gary Corl has paid money to the plaintiffs for property damage in the amount of $4,491.00 for which plaintiff demands remuneration from the defendant. WHEREFORE, Plaintiff, Erie Insurance Company, claims damages from the Defendant, in the amount of $4,491.00, and/or any other damages this Honorable Court deems just and proper, including attorney's fees and court costs from the Defendant, for arbitration purposes only. GORDON & WEINBERG, P.C. P01d 2023363 FREDERIC I. W , ESQUIRE PAUL M. SCHOF ,JR., ESQUIRE Attorney for Plaintiffs BY: 3 .'~ VERIFICATION FREDERIC I. WEINBERG, ESQUIRE, hereby states that he is the attorney for the Plaintiff(s) in this action and verifies that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. ESQUIRE -rJ 8 ~ ~ 1- l.rl '" V\. -- .-> 0 ~ If\ (") Co::':':> C G.:~" -., ~ ,r -- ;,,,,, :,.: .-4 -.'.t -0(5"1 :c.." .c: rn~T ,>- 11'r:: tn --::z 7.'.1 ::0 -nrn ?- ..' - -Joe;? I)- ~';;.;:. 0' ,..... :.. ~ ~~~.-. :.~J~--:\ :r;:: --u :;~~7\ \) -~ ~0~ _.,. -=- :::-^\ r -r "D .4_ CO - :-2 (.,.; :..:; , -., GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No. : 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 \ / / I COURT OF CO MON PLEAS CUMBERLAND OUNTY Erie Insurance Company, Individually and as Subrogee on behalf of Janet Corl and Gary Corl 3225 Andrea Avenue Harrisburg, PA 17109 vs. DOCKET NO. Russ Rineer PRAECIPE FOR JUDGMENT 06-1530 The Prothonotary will please enter Judgment in the above matter by default for want of an answer against the Defe dant, Russ Rineer, and assesses the damages as per statement below. Principal Interest from December 20, @O% Total: E IRE $4,791.00 004 $.00 $4,791. 00 I hereby certify that written notice of the intention to file this Praecipe was mailed or delivered to the part'es against whom judgment is to be entered and to his attorney of ecord, if any, after the default occurred and at least ten (10) ays prior to the date of the filing of this Praecipe. E ESQ IRE Filed: By the Prothonotary: AND NOW, this "11 r-+- day of is entered in favor of the plaintiff(s) and want of an answer and damages assessed at per the above certification. Prot , 200b Judgment t defendant, for of , $4,791.00 as ~ GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 Erie Insurance Company, Individually and as Subrogee on behalf of Janet Corl and Gary Corl 3225 Andrea Avenue Harrisburg, PA 17109 COURT OF CO MON PLEAS CUMBERLAND OUNTY vs. DOCKET NO. 06-1530 Russ Rineer CERTIFICATION OF ADDRESS I hereby certify that the precise residence of the holder of the within judgment is Erie Insurance Company, Indivi ually and as Subrogee on behalf of Janet Cor 1 and Gary Corl 32 5 Andrea Avenue Harrisburg, PA 17109 ; and that the last known address of defendant,Russ Rineer, 104 South 17 Street, Camp ill PA 17011. GORDON & WEINBER , P.C. BY: FREDERIC I. WEI RG, ESQUIRE PAUL M. SC LD, JR. ,ESQUIRE Attorney for Plaintiff Date May 17, 2006 4 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 Erie Insurance Company, Individually and as Subrogee on behalf of Janet Cor1 and Gary Cor1 3225 Andrea Avenue Harrisburg, PA 17109 COURT OF CO CUMBERLAND ON PLEAS OUNTY vs. DOCKET NO. 06-1530 Russ Rineer AFFIDAVIT OF NON-MILITARY SERV CE FREDERIC I. WEINBERG, ESQUIRE, being duly s orn according to law, deposes and says that he represents the p1ai tiff in the above- entitled case; that he is authorized to make this affidavit on behalf of the plaintiff; and that the above-named defend nt is over twenty- one years of age; that the address of the defenda t is, Russ Rineer, 104 South 17 Street, Camp Hill PA 17011; that the occupation of the defendant is unknown; and that the defendant is n t in the Military Service of the United States, nor any State or Te ritory thereof or its allies as defined in the Soldiers' and Sailor' Civil Relief Act of 1940 and the amendments thereto. Sworn to and Subscribed Before me this ;';t~ Day ~~ r ~~ ,- Notary Public COAfAfON~ LTHOFp CHRISTIN~~TARIA~ S~r-'!'l.VJl.N "- CII}' of Phl/f4e COLON, Notary 1/1II", Phl/. C Public . . OUnry 00 FREDERIC I PAUL M. SC Attorney for PIa RG, ESQUIRE , JR. ESQUIRE ntiff .. 202336 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, Identification No.: PAUL M. SCHOFIELD, JR., Identification No.: 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 ESQUIRE 41360 ESQUIRE 81894 Janet Cor1 and Gary Cor1 3225 Andrea Avenue Harrisburg, PA 17109 COURT OF COMM CUMBERLAND CO vs. DOCKET NO. Russ Rineer NOTICE OF INTENTION TO TAKE DEFAUL TO/PARA Russ Rineer 104 South 17 Street Camp Hill PA 17011 DATE OF NOTICE/FECHA DEL AVISO: May 3, 2006 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENT PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH T OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLE DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE EN WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTH A WRITTEN APPEARANCE COURT YOUR DEFENSES S YOU ACT WITHIN TEN ERED AGAINST YOU R IMPORTANT RIGHTS. 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. IS 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 OF R LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 GORDON & WEINBERG, P.C. FREDERIC I. PAUL M. SCH G, ESQUIRE J ., ESQUIRE BY: P10D-2 p b P,*, i\- S-- - ()-..> M - - ~ !i ~ ~ lrt w ~ '--..J. P= ~ ..() \) o ~ :D +- -.r- , ,...., o = c; ~ ,_., ~ -" .-\ X-n ~ rnp: . -am (~S'\ .~~) (":;;;1 ~::~(n 9 "::""~ ~;5 (J1 '< f',O w s~ . GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 Erie Insurance Company, Individually and as Subrogee on behalf of Janet Cor1 and Gary Cor 1 3225 Andrea Avenue Harrisburg, PA 17109 COURT OF CO ON PLEAS CUMBERLAND OUNTY vs. DOCKET NO. 06-1530 Russ Rineer NOTICE PURSUANT TO RULE 236 OF THE SUPREME COURT OF PENN YLVANIA, YOU ARE HEREBY NOTIFIED THAT A JUDGMENT BY DEFAULT HAS BE N ENTERED AGAINST YOU IN THE ABOVE PROCEEDING IN THE AMOUNT OF $4,7 1.00. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL GORDON & WEINBERG, P.C. AT 215/988-9600. GORDON & WEINBER , P.C. FREDERIC PAUL M. S Attorney fo NBERG, ESQUIRE FIELD, JR. ,ESQUIRE Plaintiff BY: Dated: May 17, 2006 SHERIFF'S RETURN - REGULAR CASE NO: 2006-01530 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ERIE INSURANCE COMPANY ET AL VS RINEER RUSS KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon RINEER RUSS the DEFENDANT , at 1740:00 HOURS, on the 11th day of April , 2006 at 104 SOUTH 17TH STREET CAMP HILL, PA 17011 by handing to RUSS RINEER 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 Aff idavit Surcharge So Answers: 18.00 39.60 .00 10.00 .00 67.60 ~~~-'<:~ R. Thomas Kline 04/12/2006 GORDON & WEINBERG fk; ... 1'1- day of ,2tJD(. A.D. Sworn and Subscribed to before By: me this Prothonotary