HomeMy WebLinkAbout06-30710
PAUL F. D'EMILIO, ESQUIRE
ATTORNEY I.D.# 16654
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064
(610) 338-0338
ATTORNEY FOR PLAINTIFF
THIS IS AN ARB
ERIE INSURANCE GROUP : CON
AS SUBROGEE OF RONALD A. BORSUK, JR. : CUM
4901 LOUISE DRIVE
MECHANICSBURG, PA 17055
VS. : NO.
RONALD E. REATH
634 BRANDY RUN ROAD
NEWVILLE, PA 17241
AND
TRACY WAGNER CIVIL
634 BRANDY RUN ROAD
NEWVILLE. PA 17241
NOTICE
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND Le han demandado a u
AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, de estas demandas exl
YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER (20) dias de plazo a pai
THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A Usted dabs presentar t
WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND abogado y arohivar an
FILING IN WRITING WITH THE COURT YOUR DEFENSES OR demandas encontra de
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU degende, Is torte tomai
ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY usted sin previo avlso c
PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED espedido an Is petition
AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE propiedades o otros de
FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY
OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. LLEVE ESTA DEMANt
YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS NO TIENE ABOGADO
IMPORTANT TO YOU. PARA PAGAR TAL BE
TELEFONO A LA OFI<
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. ESCRITA ABAJO PAR
IF YOU DO NOT HAVE A LAWYER„ GO TO OR TELEPHONE THE CONSEGUIR ASISTEI
OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU
WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TGLHIRE A LAWYER, THIS OFFICE
MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT
AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association Cumberland
32 Bedford Street 32 Bedford S
Carlisle, PA 17013 Carlisle, PA'
249 17Q (717) 249-31(
990 9108 (800) 990-91(
PLEAS
367
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PAUL F. D'EMILIO, ESQUIRE THIS IS AN
ATTORNEY I.D.# 16654
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064
(610) 338-0338
ATTORNEY FOR PLAINTIFF
ERIE INSURANCE GROUP : COMMON PLEAS
AS SUBROGEE OF RONALD A. BORSUK, JR. : CUMBERLAND C1
4901 LOUISE DRIVE
MECHANICSBURG, PA 17055
VS. NO.
RONALD E. REATH
634 BRANDY RUN ROAD
NEWVILLE, PA 17241
AND
TRACY WAGNER
634 BRANDY RUN ROAD
NEWVILLE. PA 17241
_ ,107/
CIVIL ACTION
NOTICE UNDER THE FAIR DEBT COLLECTION P CTICES.
15 U.S.C. §1601 (AS AMENDED)
THE PENNSYLVANIA UNFAIR TRADE PRAC ICES ACT
AND CONSUMER PROTECTION LA ,
73 PA.CON.STAT.ANN. §201, ET. SEQ. ("TH ACTS")
MATTER
RT OF
-7t -
INASMUCH AS THE ACTS MAY APPLY, PLEASE BE ADVISED THAI THIS
COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY INFORMATION OBTAINED W LL BE USED OR THAT
PURPOSE.
COMPLAINT
The Plaintiff, Erie Insurance Group by its attorney Paul
bring this action upon a cause whereof the following is a
1. The Plaintiff, Erie Insurance Group is a Corporation,
Louise Drive, Mechanicsburg, PA 17055.
Plaintiff brings this action as subrogee of Ronald A.
a policy of insurance # Q51 2907613, issued by Plaintiff.
2. The Defendant, Ronald E. Reath, is an individual
D'Emilio,
an office at 4901
Jr., ("Insured") under
at 634 Brandy Run
1
Road, Newville, PA 17241.
3. The Defendant, Tracy Wagner, is an individual residing at 634 Brandy Run
Road, Newville, PA 17241.
4. At all times hereinafter mentioned the Defendant, Ronald Reath waste agent,
workman, servant and employee of the Defendant, Tracy Wagner then and t ere in
engaged in the business of the Defendant, Tracy Wagner within the course a d scope
of his employment.
5. On or about June 28, 2004, a motor vehicle owned byt e Defendant, Tracy
Wagner and operated by the Defendant, Ronald E. Reath was traveling west on
Steeltown Road, Newville, PA when he lost control of the vehic le and struck t he
Insured's house causing the damages herein after mentioned.
6. Plaintiff avers that the personal property of the Insured as damaged as a result
of the occurrence hereinbefore mentioned, the reasonable co to repair the welling
thereto being is Forty Thousand Fourteen and 61/100 ($40, 14.61) Dollar ; plus the
cost of contents thereto being is Two Thousands Eight Hun red One and 7/100
($2,801.27) plus the Insured's deductible of Five Hundred an 00/100 ($50 0.00)
Dollars for a total of Forty Three Thousand Three Hundred Fifteen and 88 /100
($43,315.88) Dollars. A true and correct copy of the checks is ued which are attached
hereto, made part hereof and marked Exhibit "A."
Count I
Erie Insurance Group v. Ronald E. Reath
7. Plaintiff, Erie Insurance Group, incorporates by reference all of the allegations
contained in paragraphs 1 through 6 inclusive of this Complaint as fully as th ugh same
were herein and set forth at length.
8. The said occurrence was due solely to the negligence of the Defendant, Ronald
E. Reath in that he:
2
a. did fail to have the motor vehicle under proper and adequate
b. did operate the motor vehicle at an excessive rate of speed;
C. did fail to apply the brakes in time to avoid the collision;
d. did negligently apply the brakes;
e. did fail to observe Insured's property;
f. did fail to operate the vehicle in accordance with existing condit
g. did permit or allow the vehicle to strike and collid? with the insu
property;
h. did fail to drive at a speed and in the manner tha would allow h m to stop
within the assured clear distance ahead;
L did operate the motor vehicle without due regard
position of the Insured at the point of aforesaid and in a reck
j. did drive under the influence of alcohol and/or
k. did operate the vehicle without a valid driver's
1. did violate the various statutes and laws of the
Pennsylvania and County of Cumberland and Sections 3802
Vehicle Code, pertaining to the operation of motor vehicles
Count II
Erie Insurance Group v. Tracy
9. Plaintiff, Erie Insurance Group, incorporates by referen
contained in paragraphs 1 through 8 inclusive of this Complai
same were herein and set forth at length.
10. The said occurrence was do to the negligence of the D,
r the rights, afety and
manner;
s;
se; and
1543 of
Motor
all of the
as fully as
Wagner,
in that she:
a. negligently entrust her vehicle to another operate
or with a reasonable exercise of due care should have known
r for use
that the
she knew,
was not
capable of operating the motor vehicle properly;
3
b. negligently entrust her motor vehicle to a person which she
exercise of reasonable care should have known, was an incompetent driver;
C. negligently entrust her motor vehicle to a person known, should
known or in the exercise of reasonable care would have known, was going to
vehicle in an improper, dangerous or reckless manner;
d. negligently entrust her motor vehicle to another p rson who sh
should have known or in the exercise of due care would have nown would c
damages to another;
e. negligently entrust the motor vehicle to a person ho did not m
financial responsibility as required by the laws of the Common ealth of Penr
and
f. negligently entrusted her motor vehicle to a pers n who she kn
have known or in the exercise of due care would have known as under the
of alcohol and/or drugs.
WHEREFORE, Plaintiff demands judgment against the Defendants uF
count in an amount not in excess of Fifty Thousand and 00/10 ($50,000.00)
together with costs of suit.
PAUL F- D'EM LIO, ESQUIR
ATTORNEY F OR PLAINTIF
, or in the
the
knew,
ylvania;
?w, should
nfluence
ion each
dollars
4
VERIFICATION
I, Bobbi Maerki, Subrogation Specialist for Erie Insurance Group, PLAIN i FF in
the above captioned matter verifies that the facts contained in the foregoing Co plaint
are true and correct. I understand that false statements herein are made subje to the
penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authores.
DATE; ?J J
Exhibit "A"
03/09/2006 Claims Management System CSPP032B
15:34 Check Print Page: 1
Req ROWLES ,C
-----------------------------------------------------
CHECK NO 09816611 CMS NO 1816611 DATE 09/14/2004
Pay TWO THOUSAND SIX HUNDRED TWENTY-NINE AND 15/100
RONALD A BORSUK JR
501 STEELSTOWN ROAD Operator
To The NEWVILLE PA 17241-9317 2T5AUGHENBA
Order
of Claim
010170755908
For ACV SETTLEMENT FOR PERSONAL PROPERTY
PERSONAL PROPERTY COVERAGE
SERVICE DATE: 06-28-2004 TO 09-14-2004
$$$$$$2,629.15
Loss Date
06/28/2004
Tax Id No
Cashed
C 10/22/2004
----------------------------------------------------
CHECK NO 15163439 CMS NO 0163439 DAT- 12/10/2004
Pay ONE HUNDRED SEVENTY-TWO AND 12/100
$$$$$$$$172.12
DOUBLE GOLD INC
DBA RESTORECORE Operator Loss Date
To The 2322 N SEVENTH STREET 2T5SHISTLE 06/28/2004
Order HARRISBURG, PA 17110 2418
of Claim Tax Id No
010170755908 2517677750
For ELECTRONICS RESTORATION
PERSONAL PROPERTY COVERAGE Cashed
SERVICE DATE: 06-28-2004 TO 12-10-2004 C 12/16/2004
---------- ----------------------------------- ----------------
CHECK NO 09608917 CMS NO 1608917 DAT 07/28/2004
Pay TWO THOUSAND SIX HUNDRED SIXTY-THREE AND 97/100
DOUBLE GOLD INC
DBA RESTORECORE Operator
To The 2322 N SEVENTH STREET 2T5 UGHENBA
Order HARRISBURG, PA 17110 2418
of Cla m
010 70755908
For EMERGENCY SERVICES SETTLEMENT
DWELLING COVERAGE
SERVICE DATE: 06-28-2004 TO 07-28-2004
$$$$$$2,663.97
Loss Date
06/28/2004
Tax Id No
2517677750
Cashed
C 08/02/2004
l
03/09/2006 Claims Management System CSPP032B
15:34 Check Print Page: 2
Reg ROWLES ,C
-------------------------------------- ----------
CHECK NO 09644512 CMS NO 1644512 DATE 08/06/2004 -----
Pay SEVEN HUNDRED NINETEEN AND 86/100
EUGENE J. AUFIERO & ASSOC, INC
1309 BRIDGE ST.
To The NEW CUMBERLAND, PA 17070 1172
Order
of
For INVOICE#: 11723
DWELLING COVERAGE
SERVICE DATE: 06-28-2004 TO 08-06-2004
Cashed
C 08/12/2004
-------------------------------------------------------
CHECK NO R309824 CMS NO R309824 DAT-12/07/2004
Pay THIRTY-SIX THOUSAND SIX HUNDRED SIXTY AND 78/100
RONALD A. BORSUK, JR. &
RESTORE CORE & Operator
To The ABN AMRO MORTGAGE GROUP INC. 2T5SHISTLE
Order
of Claim
010170755908
For PARTIAL PAYMENT
DWELLING COVERAGE
OTHER STRUCTURES COVERAGE
$$$$$$$$719.86
Operator Loss Date
2T5AUGHENBA 06/28/2004
Claim Tax Id No
010110755908 2323857020
$$$$$36,660.78
Loss Date
06/28/2004
Tax Id No
Cashed
C 01/31/2005
-------------------------------------------------------------------------------
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PAUL F. D'EMILIO, ESQUIRE THIS IS AN ARBITRATION MATTER
ATTORNEY I.D.# 16654
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064
(610) 338-0338
ATTORNEY FOR PLAINTIFF
ERIE INSURANCE GROUP : COMMON PLEAS COURT OF
AS SUBROGEE OF RONALD A. BORSUK, JR. : CUMBERLAND COUNTY
4901 LOUISE DRIVE
MECHANICSBURG, PA 17055
VS. : NO. 06-3071
RONALD E. REATH
634 BRANDY RUN ROAD
NEWVILLE, PA 17241
AND
TRACY WAGNER CIVIL ACTION
634 BRANDY RUN ROAD
NE ILLE PA 17241
PRAECIPE FOR JUDGMENT AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY, C.P.:
Enter Judgment in the above entitled matter in-favor of the Plaintiff, Erie
Insurance Group, and against the Defendants, Ronald E. Reath and Tracy Wagner, for
want of an answer, and assess Plaintiffs damages in the sum of $43,315.88 in
accordance with a Complaint filed.
PAUL F. 'E 1 IO, ESQUIRE
ATTORNEY FOR PLAINTIFF
ATTORNEY I.D. #16654
Prothy as ses Plaints damages in the sum of $43,315.88.
Y
PR PRUTH
PAUL F. D'EMILIO, ESQUIRE
ATTORNEY I.D.# 16654
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064
(610) 338-0338
ATTORNEY FOR PLAINTIFF
THIS IS AN ARBITRATION MATTER
ERIE INSURANCE GROUP : COMMON PLEAS COURT OF
AS SUBROGEE OF RONALD A. BORSUK, JR. : CUMBERLAND COUNTY
4901 LOUISE DRIVE
MECHANICSBURG, PA 17055
VS.
NO. 06-3071
RONALD E. REATH
634 BRANDY RUN ROAD
NEWVILLE, PA 17241
AND
TRACY WAGNER CIVIL ACTION
634 BRANDY RUN ROAD
NEWVILLE. PA 17241
AFFIDAVIT OF ST KNOWN MAILING
ADDRESS OF DEFENDANT AND PLAINTIFF
Paul F. D'Emilio, Esquire, attorney for Plaintiff in the above-entitled matter
hereby certifies that the following is the last known mailing address of the Defendant
and Plaintiff:
DEFENDANTS: TRACY WAGNER RONALD E. REATH
634 BRANDY RUN ROAD 634 BRANDY RUN ROAD
NEWVILLE, PA 17241 NEWVILLE, PA 17241
PLAINTIFF: ERIE INSURANCE GROUP
4901 LOUISE DRIVE
MECHANICSBURG, PA 17055
PAUL F-. 'EMILIO, ESQUIRE
ATTORNEY FOR PLAINTIFF
PAUL F. D'EMILIO, ESQUIRE THIS IS AN ARBITRATION MATTER
ATTORNEY I.D.# 16654
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064
(610) 338-0338
ATTORNEY FOR PLAINTIFF
ERIE INSURANCE GROUP COMMON PLEAS COURT OF
AS SUBROGEE OF RONALD A. BORSUK, JR. CUMBERLAND COUNTY
4901 LOUISE DRIVE
MECHANICSBURG, PA 17055
VS.
RONALD E. REATH
634 BRANDY RUN ROAD
NEWVILLE, PA 17241
AND
NO. 06-3071
TRACY WAGNER CIVIL ACTION
634 BRANDY RUN ROAD
NEWVILLE. PA 17241
AFFIDAVIT AS TO NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF DELAWARE
PAUL F. D'EMILIO, being duly sworn according to law, deposes and says that he
is the agent for the Plaintiff above-named and is authorized to and does make this
Affidavit on its behalf; and that he has knowledge of the facts set forth herein:
That Defendants, Ronald E. Reath and Tracy Wagner, are over twenty-one
years of age and that they are not in the military service of the United States or
otherwise within the provisions of the Soldi and Sailor's Civil Relief Act of 1940
as amended. C ))ej yk?
PAUL F. D'EMI O, ESQUIRE
SWORN TO AND SUBSCRIBED
BEFORE ME THIS aottl DAY
OF JULY, 2006.
Q012- 4494- . gq=xh
BLIC
NOTARY PUBLIC
COMMONWIZA T ? NNaYLVANIA
NOTARIAL, SEAL.
MEUSSA RAMONDO, Notary public
M W Wq*n Twp., Montggo?mery Countyy
y Commission Expires Iknember t 2pp7
PAUL F. D'EMILIO, ESQUIRE
ATTORNEY I.D.# 16654
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064
(610) 338-0338
ATTORNEY FOR PLAINTIFF
THIS IS AN ARBITRATION MATTER
ERIE INSURANCE GROUP : COMMON PLEAS COURT OF
AS SUBROGEE OF RONALD A. BORSUK, JR. : CUMBERLAND COUNTY
4901 LOUISE DRIVE
MECHANICSBURG, PA 17055
VS.
: NO. 06-3071
RONALD E. REATH
634 BRANDY RUN ROAD
NEWVILLE, PA 17241
AND
TRACY WAGNER CIVIL ACTION
634 BRANDY RUN ROAD
NEWVILLE PA 17241
AFFIDAVIT OF NOTICE OF INTENT TO ENTER DEFAULT JUDGEMENT
I, PAUL F. D'EMILIO, ESQUIRE, attorney for the Plaintiff, Erie Insurance
Group, does hereby certify that a Notice of Intent to Enter Default Judgement was
mailed on July 7, 2006 to the Defendants listed below by Certificate of Mailing; a copy
of the Notice and the original certification of mailing are attached hereto, made a
part hereof, and marked Exhibit "A".
TRACY WAGNER RONALD E. REATH
634 BRANDY RUN ROAD 634 BRANDY RUN ROAD
NEWVILLE, PA 17241 NEWVILLE, PA 17241
L F. D'EMILIO, ESQUIRE
ATTORNEY FOR PLAINTIFF
Exhibit "A"
PAUL F. D'EMILIO, ESQUIRE
ATTORNEY I.D.# 16654
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064
(610) 338-0338
ATTORNEY FOR PLAINTIFF
THIS IS AN ARBITRATION MATTER
AS SUBROGEE OF RONALD A. BORSUK, JR
4901 LOUISE DRIVE
MECHANICSBURG, PA 17055
VS.
RONALD E. REATH
634 BRANDY RUN ROAD
NEWVILLE, PA 17241
AND
TRACY WAGNER
634 BRANDY RUN ROAD
: COMMON PLEAS COURT OF
: CUMBERLAND COUNTY
NO. 06-3071
CIVIL ACTION
DATE OF NOTICE: JULY 6, 2006
TO: TRACY WAGNER
634 BRANDY RUN ROAD
NEWVILLE, PA 17241
NOTICE OF INTENT TO ENTER DEFAULT JUDGMENT
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS
NOTICE, A JUDGMENT MAY BE ENTERED I D AGAINST YOU WITHOUT A HEARING
AND YOU MAY LOSE YOUR PROPERTY OR OTHER 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.
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 REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
FOR CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
905 W.
Suite 105
0)
2006-039
U.S. POSTAL SERVICE CER'TMATE OF UAKMG
WY W USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT ?J 'NY
PROVIDE FOR INSURANCE-POSTMASTER
T
LAW OFFICE
C
I
PAUL F. D'E [ILIO co
=
SUITE 105
905 WEST SPROUL ROAD
,
9
SPRINGFIELD. PENNSYLVANIA 19064
L
One piece of ordinary mail wMrosmd b: 6g
Tracy Wagner
634 Brandy Run Road a`
Newville, PA 17241
1 ...
Fm MR r, Jw%mn
PAUL F. D'EMILIO, ESQUIRE
ATTORNEY I.D.# 16654
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064
(610) 338-0338
ATTORNEY FOR PLAINTIFF
THIS IS AN ARBITRATION MATTER
AS SUBROGEE OF RONALD A. BORSUK, JR.
4901 LOUISE DRIVE
MECHANICSBURG, PA 17055
VS.
RONALD E. REATH
634 BRANDY RUN ROAD
NEWVILLE, PA 17241
AND
TRACY WAGNER
634 BRANDY RUN ROAD
: COMMON PLEAS COURT OF
: CUMBERLAND COUNTY
: NO. 06-3071
CIVIL ACTION
DATE OF NOTICE: JULY 6, 2006
TO: RONALD E. REATH
634 BRANDY RUN ROAD
NEWVILLE, PA 17241
NOTICE OF INTENT TO ENTER DEFAULT JUDGMENT
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN (10) 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 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 REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
FOR CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
PAUL F. MIL O, ESQUIRE
905 W. Sproul Road, Suite 105
Springfield, PA 19064
(610) 338-0338
2006-039
DOES NOT
Irt In3U1WYl:G-1'V.y I h IEN o
0
o
LAW OFFICE
PAUL F. D'EMILIO d JU?_ 1
905 WEST SPROUL ROAD. SUITE 105 td1
SPRINGFIELD. PENNSYLVANIA 19064 tiS`(J
Om Wece aolanlery mall edEreeeea to:
Ronald E. Reath o0
f.j ?a
634 Brandy Run Road
Newville, PA 17241 Z, T
vs
.c4„
?SJ
? c
c
?y:
IN THE COURT OF COMMON PLEAS OF BUCKS COUNTY, PENNSYLVANIA
CIVIL ACTION- LAW
(Rule of Civil Procedure No. 236)
ERIE INSURANCE GROUP : COMMON PLEAS COURT OF
AS SUBROGEE OF RONALD A. BORSUK, JR. : CUMBERLAND COUNTY
4901 LOUISE DRIVE
MECHANICSBURG, PA 17055
VS. : NO. 06-3071
RONALD E. REATH
634 BRANDY RUN ROAD
NEWVILLE, PA 17241
AND
TRACY WAGNER CIVIL ACTION
634 BRANDY RUN ROAD
NEWVILLE. PA 17241
Notice is given that a judgment in the above captioned matter has been entered
against you o2006.
TT Protho otary
If you have any questions concerning the above please contact:
Paul F. D'Emilio. Esquire
Attorney or Party Filing
905 West Sproul Road. Suite 105
Address
Springfield, PA 19064
City, State, Zip
(610) 338-0338
Telephone Number
SHERIFF'S RETURN - REGULAR
r
CASE NO: 2006-03071 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ER9E INSURANCE GROUP ETC
VS
REATH RONALD E ET AL
RICHARD SMITH , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT Sc NOTICE was served upon
REATH RONALD E the
DEFENDANT
, at 1212:00 HOURS, on the 14th day of June , 2006
at 634 BRANDY RUN ROAD
NEWVILLE, PA 17241 by handing to
ALEXIS WAGNER, DAUGHTER ADULT IN CHARGE
a true and attested copy of COMPLAINT & NOTICE together with
y
a...r
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So Answers:
Docketing 18.00
Service 21.12
Affidavit .00
Surcharge 10.00 R. Thomas Kline ""i
-»
.00
49.12,/ 06/15/2006
PAUL DEMILIO
Sworn and Subscibed to By:
before me this day puty Sheriff
of A.D.
• 'CASE NO: 2006-03071 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ER9E INSURANCE GROUP ETC
VS
REATH RONALD E ET AL
RICHARD SMITH , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
WAGNER TRACY the
DEFENDANT , at 1212:00 HOURS, on the 14th day of June 2006
at 634 BRANDY RUN ROAD
NEWVILLE, PA 17241 by handing to
ALESIS WAGNER, DAUGHTER ADULT IN CHARGE
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
Sworn and Subscibed to
before me this
of
So Answers:
6.00
.00
.00
10.00 R. Thomas Kline
.00
16.00,/ 06/15/2006
47,10 7 PAUL DEM I L I O
By:
day eputy Sheriff
Wei
A.D.
PAUL F. D'EMILIO, ESQUIRE
ATTORNEY I.D.# 16654
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064
(610) 338-0338
ATTORNEY FOR PLAINTIFF
THIS IS AN ARBITRATION MATTER
ERIE INSURANCE GROUP
AS SUBROGEE OF RONALD A. BORSUK, JR.
4901 LOUISE DRIVE
MECHANICSBURG, PA 17055
VS.
RONALD E. REATH
634 BRANDY RUN ROAD
NEWVILLE, PA 17241
: COMMON PLEAS COURT OF
: CUMBERLAND COUNTY
NO. 06-3071
AND
TRACY WAGNER CIVIL ACTION
634 BRANDY RUN ROAD
NEWVILLE. PA 17241
AFFIDAVIT MOTOR VEHICLE ACCIDENT
I hereby certify that the Judgment debtor, Ronald E. Reath is the same person
who is the Defendant in the Cumberland County Common Pleas Action No. 06-3071,
which was a result of a motor vehicle accident on June 28, 2004.
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PAUL F. D'EMILIO, ESQUIRE
SWORN TO AND SUBSCRIBED
BEFORE ME THIS 20th DAY
OF October, 2006.
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NOTARY PUBLIC
COWAONWEALTH OF
NOTARIAL SEAL
MELISSA RAMONDO, Notary Public
Whitpain Twp., Mont omery County
My Commission Expires er:;=n b ; 1 2307
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PAUL F. D'EMILIO, ESQUIRE
ATTORNEY I.D.# 16654
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064
(610) 338-0338
ATTORNEY FOR PLAINTIFF
THIS IS AN ARBITRATION MATTER
ERIE INSURANCE GROUP
AS SUBROGEE OF RONALD A. BORSUK, JR.
4901 LOUISE DRIVE
MECHANICSBURG, PA 17055
VS.
RONALD E. REATH
634 BRANDY RUN ROAD
NEWVILLE, PA 17241
AND
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COMMON PLEAS OUT
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: NO. 06-3071
TRACY WAGNER CIVIL ACTION
634 BRANDY RUN ROAD
NEWVILLE, PA 17241
AFFIDAVIT MOTOR VEHICLE ACCIDENT
I hereby certify that the Judgment debtor, Ronald E. Reath is the same person
who is the Defendant in the Cumberland County Common Pleas Action No. 06-3071,
which was a result of a motor vehicle accident on June 28, 2004.
PAUL F. D'EMILIO, ESQUIRE
SWORN TO AND SUBSCRIBED
BEFORE ME THIS 20th DAY
OF October, 2006.
NOTARY PUBLIC
co I bo58
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UNITED STATES BANKRUPTCY COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
IN RE:
RONALD EDWARD REATH, Chapter 7
Debtor
Case No. 1-09-bk-05884
RONALD EDWARD REATH,
Movant
V.
ERIE INSURANCE GROUP
as subrogee of RONALD A. BORSUK, JR.,
Respondent
ORDER
c a,
AND NOW, it appearing that the respondent has failed to answer or otherwise defend as
to the Motion to Avoid Judicial Lien filed herein by Movant, and upon this Court's finding that
the allegations of said motion are sufficient to state a good claim for relief, it is hereby
ORDERED, ADJUDGED and DECREED that:
1. The judicial lien held by the respondent, Erie Insurance Group, as subrogee of Ronald
A. Borsuk, Jr., against Debtor's real property located at 634 Brandy Run Road, Newville,
Cumberland County, Pennsylvania, and entered of record at Docket No. 2006-3071 Civil Term
at the Cumberland County (Pennsylvania) Court of Common Pleas, is declared void.
2. The respondent shall forthwith take all steps necessary to release said judicial lien
and remove it from the local judgment index.
By the C ow t,
B p JOF (PCP)
This document is electronically signed and f led on the same date.
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FP J THE REC;OPD this
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Dated: November 25, 2009 D??3ik % ik
Case 1:09-bk-05884-MDF Doc 21 Filed 11/25/09 Entered 11/25/0907:22:39 Desc
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