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Home My WebLink About06-2648 HAROLD S. IRWIN, III, ESQUIRE ATTORNEYIDNO.~O M SOUTH PITT STREET CARLISLE PA 17013 (717) 24HOH ATTORNI!Y 'OR PLAlNnFF BRAMMER PIPE & STEEL, INC., Plalntlfl VS. DANIEL A. MILLER and DAVIDSON TRUCKING, INC., Defendants TO THE PROTHONOTARY: = IN THE COURT OF COMMON PLBAS OF = CUM.ERLAND COUNTY, PENNSYLVANIA . . : CIVIL ACTION. LAW . . : NO. 2008 . 2848 CIVIL TERM . . . . Please enter a default judgment against defendants, DANIEL A. MILLER and DAVIDSON TRUCKING, INC., in the above matter for failure to respond to the complaint within twenty days of service thereof. Service of the complaint was made upon these defendants on May 19, 2006, as shown on the attached Affidavit of Service (Exhibit "An). A ten day notice of intention to take default judgment was sent to these defendants on February 27,2007 (Exhibit "B"). To date, the defendants have failed to respond to the complaint. Kindly enter judgment against them for the sum of $4,504.82, plus costs of this action and delay damages from May 4, 2005, as requested in the complaint. March 12, 2007 HAROLD S. IRWIN, III Attorney for Plaintiff EXHIBIT "A.. Commonwealth of Pennsylvania County of Cumberland Common Pie.. Court \ \ AFFIDAVIT OF SERVICE Case Number: 2006-2648 CIVIL TERM Plaintiff: Brammer Pipe & Steel, Inc. vs. Defendant: Danle' A. Miller and Davidson Trucking, Inc. For: Irwin & Bayley Received by Pennsytvania Professional Process Svc. to be served on Davidson Trucking, Inc., 1227 Bowtlng Green Road East, Bradner, OH 43406. I, J C H rJ R. 8Aff-S , being duly sworn, depose and say that on the , q day of M Ii '" . 20" " at ~: IS" A .m., executed service by delivering a true copy of the Notice; Complaint in accordance with state statutes in the manner marked below: ( ) PUBLIC AGENCY: By serving the withln-named agency. as of ( ) SUBSTITUTE SERVICE: By serving as ~ CORPORATE SERVICE: By serving -'e~iGA 5H A &JAll> oR ,:- as ,9rF I WI IS-R.. / ( ) OTHER SERVICE: As described in the Comments below by serving as ( ) NON SERVICE: For the reason detailed in the Comments below. COMMENTS: I certify that I have no interest In the above action, am of legal age and have proper authority in the jurisdiction in which this service was made. and SWorn to before me on the /9".1 day ~~ by the affiant who is pers 'ally, own to me. /~~~ NOTARY PUBLIC ~.~. 8-/~-)O ~- RfS..-l- PR - E~SERVER II Appointed in accordance with State Statutes Pennsylvania Professional Procesa Svc. 48 W. High St. P.O. Box 1148 Carlisi., PA 17013 (717) 960-9260 Our Job Serial Number: 2006000123 Copyright 0 1992.-2005 DetlIb8Ie Servk:eI, Inc. - Process Server'1 Toolbox V5.51 "" EXHIBIT "B" IRWIN & BAYLEY HAROLD S IRWIN III ESQ SUPREME COURT ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 ATTORNEY FOR PLAINTIFF BRAMMER PIPE & STEEL, INC., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW DANIEL A. MILLER and DAVIDSON TRUCKING, INC., : NO. 2006 - 2648 CIVIL TERM Defendants . . TO: DANIEL A. MILLER and DAVIDSON TRUCKING, INC. 1227 BOWLING GREEN ROAD EAST BRADNER OH 43406 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: February 27, 2007 CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD ST CARLISLE PA 17013 717-249-(e (Q) rP'1( HAROLD S. IRWIN, III Attorney for Plaintiff 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 (J f"-o.,) 0 c~ ~~-: <-= -n ---' ~ ~ --:... :x ~::!J ~ \.> ? ~ '-1) ::';,,) ,.- iT'1 ..... ~ ,~.:) (' ~ ~ N (\ ........ ;- i.~ ~ "'" a -:l ,. -., ~ , ~ ~ ~ ~ " 1'-) ~ ~ ~ ~ l- 0 -. ; .......s Cjl -< ~ ~ ~ C::::> MARK F. BAYLEY. ElIQUIRE An'ORNEY ID NO. 878113 IRWIN a BAYLEY ..IOUTH 'ITT STREET CAIlUlLE 'A 17013 (717) J43.4IOlIO ATTORNEY FOR I'LAIIITIFF BRAMMER PIPE & STEEL, INC., Plaintiff I IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA I VS. I CIVIL ACTION - LAW DANIEL A. MILLER and DAViDsoN TRUCKING, INC., . ; NO. 2008 -d~ 'fg'CIVIL TERM DItf...dants . . 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 an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-243-3166 BRAMMER PIPE & STEEL, INC., Plalntlft = IN THE COURT OF COMMON PLEAS OF = CUMBERLAND COUNTY, PENNSYLVANIA = VS. = CIVIL ACTION - LAW DANIEL A. MILLER and DAVIDSON TRUCKING, INC., . . = NO. 2008. .l~ 'I! CIVIL TERM Defendants COMPLAINT NOW comes the plaintiff, by its attorney, Mark F. Bayley, Esquire, and files this complaint against the defendants, representing as follows: 1. Plaintiff is BRAMMER PIPE & STEEL, INC., a Texas corporation having its principal offices at P. O. Box 243, Gainesville, Texas 76241. 2. Defendants are DANIEL A. MILLER, an adult individual, and DAVIDSON TRUCKING, INC., an Ohio Corporation, both having principal mailing addresses at 1227 Bowling Green Road East, Bradner, Ohio 43406. 3. At all times relevant hereto, defendant Miller was in the employ of defendant Davidson Trucking, Inc. and was acting within the scope of his employment. 4. On March 2, 2005, defendant Miller, was operating a 2005 truck tractor (VIN No. 1 FUYDWEB8YPE71422) owned by Daniel Davidson, principal owner of defendant Davidson Trucking, Inc., in Middlesex Township, Cumberland County, Pennsylvania. 5. On said date and time, George E. Young, while in the employ of plaintiff and acting within the scope of his employment, was sleeping in a parked 1996 Peterbilt truck tractor (VIN No. 1XP5DR8X3TN412337) owned by the plaintiff. 6. The vehicles were parked side by side in the parking lot of the Flying J Truck Stop just east of the intersection of Interstate 81 and U.S. Route 11 in Middlesex Township, Cumberland County, Pennsylvania. 7. At approximately 7:50 p.m. on March 2, 2005, defendant Miller began to pull out of his parking space, striking the plaintiff's vehicle in the front left wheel, fender and bumper, as reported by Patrolman Keith Seibert of the Middlesex Township Police Department in his official report, a copy of which is incorporated herein by reference and attached hereto as Exhibit "A". 8. Fortunately, the accident caused no personal injuries; however, it did result in property damages to the truck owned by the plaintiff, as well as other damages as will be enumerated hereafter. 9. Said collision and the resulting damages incurred by the plaintiff were solely due to the carelessness, recklessness and negligence of defendant Miller, an employee of defendant Davidson Trucking, Inc., and acting within the scope of his employment, including but not limited to the following: A. In failing to have his vehicle under proper control; B. In failing to properly and safely maneuver his vehicle from his parking space without colliding with plaintiffs vehicle while the latter was at rest in its proper parking place; C. In failing to take appropriate action to avoid the plaintiffs vehicle; and D. In otherwise failing to exercise appropriate care and caution under the circumstances. 10. As the direct result of defendant's negligence, recklessness and carelessness as aforesaid and the collision that resulted therefrom, plaintiff incurred various property damages and other losses as follows: A. An initial day of inactivity and lost income for the truck and driver in the estimated amount of $1,700.00, due to work on the truck necessary to get it on the road (new front tires and removal of the front bumper); B. The sum of $945.52 in said initial repairs, as indicated on Exhibit "B", attached hereto and incorporated herein by reference; C. Additional repairs in the sum of $1,659.30 to the front end of the plaintiff's truck tractor once it was returned to Texas, as indicated on Exhibit "C", attached hereto and incorporated herein by reference; D. Front end alignment of the plaintiff's truck tractor at a cost of $200.00. 11. The total costs incurred by the plaintiff due solely to the negligence and carelessness of defendant amounted to $4,504.82. 12. Plaintiff's damages were the foreseeable result of Defendant's negligent conduct. 13. Defendant's negligence was the actual and proximate cause of Plaintiff's damages. 14. Plaintiff's counsel made a demand a comprehensive demand of the defendants to reimburse the plaintiff for these damages by letter dated May 4, 2005, a copy of which (less the documentation which was attached) is incorporated herein by reference and attached hereto as Exhibit "0". WHEREFORE, plaintiff demands judgment against the defendants in the amount of $4,504.82, plus costs of this action and delay damages from May 4, 2005. Date: ~0-tL IRWIN & BAYLEY \~ Mark F. Bayley, squire Attorney for Plaintiff , VERIFICATION I verify that I am the President of Brammer Pipe & Steel, Inc. and that, as such, I have been authorized to make this affidavit on its behalf. The facts contained in the foregoing complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S.A. Section 4094, relating to unsworn falsification to authorities. Date: y(/o ~ w-/ / GA Y B MER President of Brammer Pipe & Steel, Inc. Plaintiff -.-----~---. . - ---.-. ... . __'__ _....1 r"Ill'l.II'II~lll .......,'-''-'u "'YII;~~I!::JauVII r'\C,",VI L OR!: PA0211300 Incident Data Class (VCR) Code: 6010 Crimes Code: Title: Date/Time Reported: Discovered Date/Time: Last Known Secure : TIME - Received: 19:50 20050302M 1419 (01) TRAFFIC ACCIDENT - OTHER ACC. INVEST, Corr,plete o 03/02/2005 Wednesday 19:50 03/02/2005 Wednesday 19:50 03/02/2005 Wednesday 19:50 / Dispa~ched: 19:50 / A~~ived: 20:22 / clea=ed: 2::45 Badge: 14 - PTL KEITH SEIBERT Location: 1501 HARRISBU~G PK - CARLISLE Landmark: fLYING J TRUCK PLAZA Patrol Zone: 3 - SROOll - S MIDDLESEX Premise Type: BIAS: 88 NONE (NO BIAS) MO: Grid.: ..v";' - ?::::fING ...; ~eapon/Too13: Additio~al weapon: Persons Involved Number of Victims: 0 Number of Offenders: 0 Persons Involved: 2 DRIVER MILLER, DANIEL A (NP030210) Incident Classif.: 6010 TRAFfI::: ACCIDENT - OTEE? ACC. I:\YES~, Type: INDIVIDUAL/PERSON (NOT L.E.OFFICER) Inju~y: Age/DOB: 34 03113/1970 Race: W Sex: M E~~ni=, N Ma~ica~: U SS#: Height: 0 Weight: GBM 10 number: Resd~!c: ',j o Eve: Hair: 3c:i1d: 1 1 Co:np:'. : Date 2:u.e:r-ed: Date Re~~;.sed: 1 / , Comment: :;08e: 92-991 !.LlI.KAKILO DR ~O ~~?OLSI HI 96707 Hc.:::e ?~:.:; ~_e : Ko=k Phone: 940-665-4S07 :"";.""" " ':e~~ =',-~:::'-= : 2IT1-?lo),.er ~ 9~O-655-4807 DOC~:SNTS O~ FILE: - Vehic:'e DRIVER YOUNG, GEORGE E (N?030211) :::n.cid'2~t c:'5.3sif.: 6D10 -~:::",;;~-. :.----,=-,.- -----.. --' -'~-'----'- ::r",?e: I~~:~ID~A~/?~~S::~ ,-.-- - - "'---,-.-- - - - -- -' ....." ..;... ~"._'- - - ~-- ~ge/CC3: 5: :3/29/:952 -=-~. 357:': -~'.' . ::.... - --- - - . -;. ~ ....... - . -- --.....- -' - -. . . . ~ ~ .... -- . ._ 1.=_-:: ._'_" -'.~ ' - -, - . - =- . .- . - -, -.--- -.. ~3~': ::J :1''':',.::-==: - ' . .. - .==......=-. , -..-----. ...=:.. _= :.~_'::;5~::; :~:::-'"'":".~:-.: : :lS/s~::,::E: 151S"2':~ :-::'::-.2: : 5??:>;,:; =?::::=:-: - ---.::. -"-_.~' - . -.-..- . :::::~3~:L~E ~~ -~233 Officer: 27:' ::::::I7H S2I3S?,: Case Status:CLOS::::;/CLEA?,E9 Da:; Printed: 10 March 2C05 08:58 0,. Karen Kiehl Badge: :; Case Disposition:c:o.s:::. - :,;:) Page: :::';?:':::::~ ":.::-ZON 1 eXHI81T I' A II .______" .__.""-1'111 r Vl-lvC: UC;r-I-\I"'\.IIVIE:N I JnCIClent Investigation Report 20050302M1419 (01) ...>RI: PA0211300 Persons Involved DRIVER YOUNG, GEORGE E (NP030211) Work Phone: 419-288-3088 EX7: Cell ?hone: Employer: Pa::er: 419-288-3088 DOCu~ENTS ON :ILE: - Vehicle Vehicles Involved VYR Make Model Style Color :'icanse st (2) 1996 PETERBILT \rIN: "lX?"315R8X3TN412337 Owner Name: B~~ER PIPE & STEEL Owner Address: PO BOX 243 GAINESVILLE 7:< 7621}0 l!1..3i.~c::a Co: CONSUMERS COUN?Y ?oli.::y: S!..J~~71022= ((1)2005 FRHT , CONV TRUCK TRACTOR GOLD "~~B8YPE71422 Serial: Owner Name: D~~IEL DAVIDSON Owner Address: 1227 BOWLING GREEN Insurance Co: CONV. TRUCK TRACTOR BLACK RFKD38 Serial: TX PUM30B4 OH ,} ~ :! RD EAST B~~DNER OH 434G6 Po licy: Summary 03/02/2005 19:50 Page'l O:c, 14 -P7L KE=T~ SEIBERT THIS ACCIDENT OCCURREJ IN TH=: RE~_:\ ?4..?.KING LOT 02 Tr-:2 =::~ ::..c; n ??;"\~2:" CENTER. UNIT 1 WAS P?~RKEC N::X? 'YO Urr:T 2. I2S 0RIV28. 0; cr::: :. 3:::.:.=::': TO ?Vi..1 OUT OE" nIS P.-;RKING S?!..CE:, 3'1[8.:<=:<::1.'1':; ;"JS::::. :2 :::>: ~:-:2 =?~:::; :;,='.~::? :':.:"':5::2:", :ENDER ~VD a~!?ER. NOaODY WAS INJURED. 7:'IS ";_;5 ,', ,':8,.:-?"::=':?~-,:,=::':: ??:.-_:_::: =.;:=::?:",' .~c.:CIDENT . Officer: ?T: ~::::::! S:::13::::<.:- Case Status:CL03:::D/CLEA?ED Oat~ Printed: 10 March 2005 08:58 By K!fa-n :<ier,\ Badge: :~ Case Disposition:'::':S::D Page: 2 ?U?::::::R ACT:C~I - ;.,'1/'.' FLYING .J .J CARE SERVICE. CENTER 1501 Harrisburg Pike Carl ise, PA 17013 03-03-2005 InvQloe # 099P3310 Customer: Frequent Fueler No, BRAMMER oo0000422B46 .. Amount Tendered TCH XXXXXXXXXXXXXXX0021 SWIPEO AUTH # 395768 OB5001a 945,52 carol eXHJ~/T rl B" Year Make Model Color Trim 1995 PETERBfL T 379 & UNIBIL T CAB Unit Number License Plate # \\ti1eage Serial#NIN= Sup Seq Qt, Labor Labor Description I Part Part List (,tendell Labor Type Op Type Number Price Price Units I I Body Rem/Rep Fender L I New $3)0.22 T 5330.22 3.(" ! 2 I Body RemRep fender liner I New I I 5 II 077 T 5110.77 .5* I I I I 31 I Budy RemRep fender brace I Nco\\ I I S"'6.06 T 52606 I .5"' , I I 41 I Body RemRep huck pins and collars I New ! I S 1500 T, 51 ;00 I .fF~ I I I -I 1 Ref Ref Refinish Fender I Exis: I I I 2.(r" i )1 ! i , I Outside Rennish ! I I I I Hood Assy Outside i I \ I. I I 379X Hood Ronnish ! i i , I I Hood Assy OLltsid~' R , l i 61 I Bod) Rem Ins I R&I mifTirs , E\js[ ,. I 71 11 Body Rem'Rep I tront bumper i ~,:?I,.\ S3i}S ~ 5 r: S3 ~ .~ 'I' , , i, I 8) I ! Body Rem Rep L rear'ile\....- mrrr,)r i 'el,.l, S6'o,~ T " S-.~ f,~ ,. , I Body R R' . I -- I I 9: I em =r: L (l.;rr; slgnJ.: \;:....\ 5>;'":,:':; T S' "'.,' JI) ~ I - --- , , 1 J Body R~m Ref) L hOI)d bra...:k-:-I ',,'\\ I :) ':1.: -i! S I, ' ' I I II I Body Rem R~p L brace . '~"". , S8~(~I'i T s.~: ,-)1) . , , .' '. - ~ Estimate Prepared by: Accident Date: Date of LoSS: AfTival Date: 31] 02005 Type of Loss: Policy Number: Claim Number: Owner: Appraised for: I" 13) 1 I Bod) I R~m R~r L \'.-h~cllug CO\t~j I PJ:nr \tJt~riJ.:~ 5- ; !)'i Phil's Collision Repair 230 East 1M Lindsay Blvd Gainesville, TX, 76240 Tel: 940-612.4004 Fax: 940-612.0503 ph i 15coll ision@ritin,net Estimate Appraised for: Larry Brammer Date: 4/192005 Estimate=: 103 Company: Brammer Pipe and Steel Address: 6]78 E US Hwy 82 City, State, Zip Code: Gainesville, TX 76240 Telephone, Fax: 940-665-4807 Contact: Larry Btammer : ;\.,;,.'\l, ::> .~r) T ~ 211 \ ~~5t(!r: 1..S Da~.iba5e E::~i,)- PH r 04.0~ Tri.l.;;:~E:)~ \~; a Tra':~mJ.r\...of \l1tchell Int'tmari;Jn:.ll ~-I \NS-2003 !\tirchelllr1:ema[j()na1. Inc. A! i Rights R~~~r', cd. Pa~~ or" .2 e xH-JJ3/T " ~ IJ . * ~ Judgement {tern # - Labor Note "-pplies Labor Body Refinish Labor T ota I 8,5 Hrs @ 2,0 Hrs@ $35,00 $35,00 $297,50 $7000 $36750 h~ above is an estimate based on our inspection and does not cover any additional pam or labor which may be required after the work has started, Occasionally, worn or damaged parts are discovered which may not he evident on the first inspection, Because of this, the bo....e price3 are not gLta:-anteed. Quotations on parts nd labor are current and subject to change, Parts Parts Subtotal Less Adjustments Parts Total Additional Costs Add!. CostS/Ops Total Tax Totals Sub Total: Customer Resp, Net Total )c)c!~ Pt. iTRoE !. ~';'l_} 8.: L\IB1L T CAB \'~r:;iJn ! .S D~:2t-JS~ Edi!!on PHT O-+~O~ Trw.J,E5t is 3. Tmd':rTlJr~ of \litchell [nr-=matit)n2.1 ;;:: 1998-2003 :\Iitchelllntemationa!. Ine, .-\11 RigtH5 R6crl,ect. $1.221.80 $1.221,80 570,00 S 1.659,30 $0,00 $1.659,30 Pag~ 2 of ~ HAROLD S. IRWIN. III IRWIN LAW OFFICE M SOUTH PITT STREET CARUSLE, PIlNNSYLVANIA 17013 www.irwinlawoffice.com e-mail: irwinlaW@earthlink.net 717-243-6090 PHONE 717-243-9200 FACSIMILE RHONDA S, IRWIN ROBERT D, STAMBAUGH PARALEGALS May 4, 2005 DANIEL DAVIDSON DAVIDSON TRUCKING INC 1227 BOWLING GREEN RD EAST BRADNER OH 43406 RE: Claimant: D/L: BRAMMER PIPE & STEEL INC March 2, 2005 Dear Mr. Davidson: I have been retained to represent the interests of Brammer Pipe & Steel, Inc. regarding an accident caused by one of your drivers, Daniel A. Miller, on March 2, 2005. The accident occurred in the Flying J parking lot in Middlesex Township, Cumberland County, Pennsylvania. I have attached a police report prepared by Middlesex Police Department clearly indicating that Mr. Miller was at fault in this accident (see Exhibit "A"). Fortunately, no one was hurt by Mr. Miller's negligence; however, my client did incur property damages and other damages for which he intends to be reimbursed. The following is a statement of demand, which includes the repairs necessary to get the Brammer truck back on the road, the expenses of repairing the truck, lost wages for the driver and lost income from the inability to use the truck during its repair time. All of these items have been reported to your company, but, unfortunately, up to this time you have chosen to ignore Brammer's request for reimbursement. Damaaes Following the accident, Brammer's driver, who had been asleep in the sleeper at the time of the accident, spent a day trying to get the truck driveable to deliver his load. He was able to have this accomplished at Flying J by 5:00 p.m. the next day and left Carlisle with new front tires and the front bumper cut off. Once he arrived back in Gainesville, Texas, Brammer attempted for three days to contact your company, but only reached an answering service. When my client was finally called back by Tim Carr, Mr. Carr instructed him to obtain two estimates and then he would decide what to do. Unfortunately, Mr. Brammer was unable to take the time to obtain another estimate, as that would have required him to drive another 150 miles away to get a second estimate. He had the truck repaired locally and sent a request for payment of the Flying J repairs and Phil's Collision Repair initial estimate - a combined $1,963.52 (See I? XJt/8' T " n" IRWIN LAW OFFICE Brammer v. Davidson Moy 4, 2005 Page Two Pictures of truck at Exhibit "B" and repair bills at Exhibit "C"). At that point, Mr. Carr indicated that your company would refuse to make any compensation to Brammer. My client then proceeded to have the repairs performed by Phil's Collision Repair. The actual repairs, including additional parts that were needed, ended up costing my client$1,659.30, in addition to the Flying J repairs cost of $945.52. In addition, the vehicle required front end alignment ($200), the driver lost $200 in wages, and Brammer Pipe & Steel lost $1,500 in lost income during the downtime for repairs (see Exhibit "0"). Demand Based on all of the foregoing, I have been authorized to demand the sum of $4,504.82 in full satisfaction of this claim. Please review this claim and advise me as soon as possible as to your position. I look forward to resolving this amicably and hope that we will be able to do so. However, if I do not receive an appropriate response by May 11, 2005, I will recommend that my clients file suit against you here in Pennsylvania. Very truly yours, Harold S. Irwin, III ~~~ 3~ ~z ~'r-~ . ~ 'I; (") c Z -0 i;;-'~ rr",C :?: :i.." -'.:>' j-~ (h'~;:-'"' ~::; ~'~; ::~ :.: .-3 is "'"' ::s: ~ I v::> -0 :;]I: f':? ~-0 - ~ ~:n -ok! ~~ :1: ::u 9~ 53 ~ O'l