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HomeMy WebLinkAbout06-4617 File #04-06-340 LAW OFFICES OF STEWART C. CRAWFORD & ASSOCIATES BY: Stewart C. Crawford, Esquire ATTORNEY I.D. NO: 09827 223 North Monroe Street ATTORNEY FOR PLAINTIFF Media, P A 19063 Telephone: (610) 565-7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION-LAW STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY a/s/o WESLEY METZGER P.O. Box 2371 Bloomington,IL 61702 v. KRISTY BITNER 106D Wolf Bridge Road Carlisle, P A 17013 and SHANNON HENDERSON 2141 Lee Morgan Road Jayees, MS 39641 IN CIVIL LAW NO. Ot.. - 4(,'7 c;u ~L'T €/l.h'\ NOTICE TO DEFEND 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 attomey and filing in writing with the court your defenses or objections 10 the claims set forth against you. You are further 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 00 NOT HAVE A LA WYEROR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Le han demandado a usted en Ia corte. Si usted quicre defenderse de estas demandas expuestas en Ias paginas siguientes, usted tiene veinte (20) dias de plaza al partir de 1a fecha de la demanda y la notificacion. Hace faita asentar una comparencia escrita 0 en persona o con un abogado y entregar a la corte en fonna sus defensas o sus objectiones alas demandas en contra de su persona. Ses avisado que si usted no se defiende la corte tomara modidas ypuede continuar i1a demanda en contra suya sin previo aviso 0 notificacion. Ademas, la corte puede decidir a filvor del demandante y requiem que usted cumpia con todas las provisions de esta demanda. Usted puede perder dinero 0 sus propiedaces u otros derechos importantes parausted. USTED DEOE LLEVAR ESTA AVISO A UN ABOOAoo ENESEQUIDA. SI USTED NO IlENE UN ABOOAoo Y NO PUEDEPAGAR LOS SERVICIOS DE UN ABOOADO, DEOE COMUNICARSE CON LA SIGUIENTE OFlClNA PARA A VERIGUAR OONDE PUEDE OBTENER A YUDA LEGAL. TARYN DIXON, COURT ADMINISTRATOR ONE COURTHOUSE SQUARE CARLISLE, PA 17013 (717) 240-6200 File #04-06-340 LAW OFFICES OF STEWART C. CRAWFORD & ASSOCIATES BY: Stewart C. Crawford, Esquire ATTORNEY J.D. NO: 09827 223 North Monroe Street ATTORNEY FOR PLAINTIFF Media, P A 19063 Telephone: (610) 565-7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION-LAW STATE FARM MUTUAL AUTOMOBILE : INSURANCE COMPANY als/o WESLEY METZGER P.O. Box 2371 Bloomington,IL 61702 IN CIVIL LAW NO.C){. -.q/,I"{ (!;o~L'-r~ v. KRISTY BITNER 106D Wolf Bridge Road Carlisle, P A 17013 and SHANNON HENDERSON 2141 Lee Morgan Road Jayees, MS 39641 COMPLAINT Motor Vehicle Property Damage I. Plaintiff is an insurance company licensed and authorized to do business in the Commonwealth of Pennsylvania with one of its principle places of business at the above captioned address. 2. Defendant, Kristy Bitner, is an adult individual and was the owner of the motor vehicle involved in this incident on May 5, 2005, and at all times pertinent hereto resided at the above-captioned address. I 3. Defendant, Shannon Henderson, is an adult individual and at all times pertinent hereto resided at the above-captioned address and was the operator of Defendant owner's motor vehicle. 4. On the aforesaid date, Plaintiff had a policy of insurance with Wesley Metzger, hereinafter referred to as named insured. 5. On the aforesaid date, a motor vehicle insured by Plaintiff hereafter, the insured vehicle, was involved in an incident with Defendant's vehicle. 6. On the aforesaid date, the insured vehicle was stopped at a red light in the 1 st block of North Spring Garden Street in Carlisle, Pennsylvania, when the Defendant, who was traveling directly behind the insured vehicle, failed to maintain a safe following distance and rear-ended the insured vehicle causing damage. 7. Defendant driver was negligent and careless and the sole cause of this incident in that Defendant driver: (a) operated the vehicle at an unsafe rate of speed; (b) was inattentive; (c) failed to make proper observation; (d) violated local laws and the laws of the Commonwealth of Pennsylvania. 8. Pursuant to the aforesaid policy of insurance, Plaintiff became liable for damages that arose out of this incident. 9. Due to this incident, expenses were incurred for damage to the insured vehicle, towing, storage and car rental. 10. Pursuant to the aforesaid policy of insurance, the Common Law and governing statutes, Plaintiff is subrogated for all money paid and seeks recovery ofthese sums totaling $3,784.88. 2 COUNT I PLAINTIFF V. SHANNON HENDERSON II. Plaintiff incorporates paragraphs I through 10 inclusive as if fully set forth at length herein. 12. Defendant is liable as the negligent driver. WHEREFORE, Plaintiff demands judgment for $3,784.88 plus interest and costs of suit. COUNT II PLAINTIFF V. KRISTY BITNER 13. Plaintiff incorporates paragraphs I through 12 inclusive as if fully set forth at length herein. 14. Defendant owner is liable under the Doctrine of Respondeat Superior for the negligence of Defendant driver. 15. Defendant owner was negligent in entrusting this motor vehicle to someone who Defendant knew or could have known was a dangerous, unlicensed, inexperienced or careless with a motor vehicle. WHEREFORE, Plaintiff demands judgment for $3,784.88 plus interest and costs of suit. STEWART C. eRA WFORD, Attorney for Plaintiff 3 . , . . VERIFICATION The undersigned hereby states that he is an authorized agent of Plaintiff insurance company in this action and verifies that the statements contained in the foregoing Complaint are true and correct. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. T WARTC. CRAWFORD, ES Attorney for Plaintiff Date: 8/8/;)60& 4 . . ~ ~ A:) \. tI'\ ~ ~ U'\ (") = ~ c:: "'"" ~:P II'( :s: ~ -ot~: t2 () l......if j I !~ z -~~-~ - ;l(: r~_ ~ ~ ~ cO ,,":~:. 0 -<: <- ~1'; r:;C' ~_ 1'1 ~ -...(:) '- -0 %~ ?(; :;J: ?-'C) ~ ;~". c: ':? "'" ;;-:, N ~ _4 -< - ~ SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-04617 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STATE FARM MUTUAL AUTOMOBILE VS BITNER KRISTY ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT BITNER KRISTY but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , BITNER KRISTY 106D WOLF BRIDGE ROAD CARLISLE, PA 17013 NO SUCH PERSON AT GIVEN ADDRESS. NO RECORD WITH POST OFFICE. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 5.28 5.00 10.00 .00 38.28./ ~rj6? ~ Subscribed to before County STEWART CRAWFORD 08/30/2006 Sworn and me this day of A.D. File #04-06-340 LAW OFFICES OF STEWAR-'E~.\-,CM WFORD & ASSOCIATES ". ... , BY: Stewart C. Crawfor4, EsqUire f ATTORNEY LD. NO: 09827 ~ 223 North Monroe Street ATTORNEY FOR PLAINTIFF Media, P A 19063 Telephone: (610) 565-7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION-LAW ST ATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY a/s/o WESLEY METZGER P.O. Box 2371 Bloomington,IL 61702 v. KRISTY BITNER 106D Wolf Bridge Road Carlisle, PAl 7013 IN CIVIL LA W NO. O~ - .LI['11 ClUJ 1€IL~ TRUE COPY FROM'RECORD In lilllmony wIB'eof, I here unto -",baoo and tlleJ~_~ Cou1!- ~ Pa. Is, '--- "*u'~~ NOTICE TO DEFEND and SHANNON HENDERSON 2141 Lee Morgan Road Jayees, MS 39641 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 tiling in writing with the court your defenses or objections to the claims set forth against you. You are further 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 LA WYER AT ONCE, IF YOU DO NOT HAVE A LA WYEROR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes. usted tiene veinte (20) dias de plaza al partir de la fecha de la demanda y la notificacion. Hace tilita asentar una comparencia escrita 0 en persona o con un abogado y entre gar a la corte en forma sus detensas o sus objectiones alas demandas en contra de su persona, Ses avisado que si usted no se defiende la corte tomara modidas ypuede continuar ila demanda en contra suya sin previo aviso 0 notiticacion, Ademas, la corte puede decidir a favor del demandante y requiera que usted cumpia con todas las provisions de esta demanda, Usted puede perder dinero 0 sus propiedaces u otros derechos importantes para usted, USTED DEBE LLEV AR EST A A VISO A UN ABOGADO ENESEQUlDA, SI USTED NO TIENE UN ABOGADO Y NO PUEDEPAGAR LOS SERVICIOS DE UN ABOGADO. DEBE COMUNICARSE CON LA SIGUIENTE OFlCINA PARA A VERIGUAR DONDE PUEDE OBTENER A YUDA LEGAL. T ARYN DIXON, COURT ADMINISTRATOR ONE COURTHOUSE SQUARE CARLISLE, P A 17013 (717) 240-6200 .. File #04-06-340 LAW OFFICES OF STEWART C. CRAWFORD & ASSOCIATES BY: Stewart C. Crawford, Esquire ATTORNEY LD. NO: 09827 223 North Monroe Street ATTORNEY FOR PLAINTIFF Media, P A 19063 Telephone: (610) 565-7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION-LAW STATE FARM MUTUAL AUTOMOBILE: INSURANCE COMPANY a/s/o WESLEY METZGER P.O. Box 2371 Bloomington, IL 61702 IN CIVIL LAW NO. v. KRISTY BITNER 1 06D Wolf Bridge Road Carlisle, P A 17013 and SHANNON HENDERSON 2141 Lee Morgan Road Jayees, MS 39641 COMPLAINT Motor Vehicle Property Damage 1. Plaintiff is an insurance company licensed and authorized to do business in the Commonwealth of Pennsylvania with one of its principle places of business at the above captioned address. 2. Defendant, Kristy Bitner, is an adult individual and was the owner of the motor vehicle involved in this incident on May 5, 2005, and at all times pertinent hereto resided at the above-captioned address. 1 .. 3. Defendant, Shannon Henderson, is an adult individual and at all times pertinent hereto resided at the above-captioned address and was the operator of Defendant owner's motor vehicle. 4. On the aforesaid date, Plaintiffhad a policy of insurance with Wesley Metzger, hereinafter referred to as named insured. 5. On the aforesaid date, a motor vehicle insured by Plaintiff hereafter, the insured vehicle, was involved in an incident with Defendant's vehicle. 6. On the aforesaid date, the insured vehicle was stopped at a red light in the 1 st block of North Spring Garden Street in Carlisle, Pennsylvania, when the Defendant, who was traveling directly behind the insured vehicle, failed to maintain a safe following distance and rear-ended the insured vehicle causing damage. 7. Defendant driver was negligent and careless and the sole cause of this incident in that Defendant driver: (a) operated the vehicle at an unsafe rate of speed; (b) was inattentive; ( c) failed to make proper observation; (d) violated local laws and the laws of the Commonwealth of Pennsyl vania. 8. Pursuant to the aforesaid policy of insurance, Plaintiffbecame liable for damages that arose out of this incident. 9. Due to this incident, expenses were incurred for damage to the insured vehicle, towing, storage and car rental. 10. Pursuant to the aforesaid policy of insurance, the Common Law and governing statutes, Plaintiff is subrogated for all money paid and seeks recovery of these sums totaling $3,784.88. 2 ~ COUNT I PLAINTIFF V. SHANNON HENDERSON 11. Plaintiff incorporates paragraphs 1 through 10 inclusive as if fully set forth at length herein. 12. Defendant is liable as the negligent driver. WHEREFORE, Plaintiff demands judgment for $3,784.88 plus interest and costs of suit. COUNT II PLAINTIFF V. KRISTY BITNER 13. Plaintiff incorporates paragraphs 1 through 12 inclusive as if fully set forth at length herein. 14. Defendant owner is liable under the Doctrine of Respondeat Superior for the negligence of Defendant driver. 15. Defendant owner was negligent in entrusting this motor vehicle to someone who Defendant knew or could have known was a dangerous, unlicensed, inexperienced or careless with a motor vehicle. WHEREFORE, Plaintiff demands judgment for $3,784.88 plus interest and costs of suit. I .? J 17/" ~ itA/d;(/( (. UIli/;, ~ ./STEW ART C. CRAWFORD, QUIR Attorney for Plainti ff 3 . . ,. . . VERIFICATION The undersigned hereby states that he is an authorized agent of Plaintiff insurance company in this action and verifies that the statements contained in the foregoing Complaint are true and correct. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: 8/8/;)()OU 4 ~lEmw~ g Z :[ dOl 9nV QOOl ~lrn1wrc ,j I d ~~1 :".I~; ~~ j .....-il ~ , File #04-06-340 LAW OFFICE OF STEWART C. CRAWFORD & ASSOCIATES BY: Stewart C. Crawford, Esquire ATTORNEY LD. #09827 223 North Monroe Street P.O. Box E Media, Pennsylvania 19063 (610) 565-7050 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW STATE FARM AUTOMOBILE INSURANCE COMPANY a/s/o WESLEY METZGER IN CIVIL ACTION NO.: 06-4617 CIVIL TERM V. KRISTY BITNER and SHANNON HENDERSON PLAINTIFF'S MOTION FOR ALTERNATE SERVICE 1. Attached as Exhibit "A" and incorporated reference herein is a copy of the certified mailing which was returned as "unclaimed", yet the regular mail was not returned to us. 2. Attached as Exhibit "B" and incorporated by reference herein is a true and correct copy of a Skip Tracing print out indicating that there is an individual located at 2141 Lee Morgan Drive, Jayess MS 39641, by the name of Shannon Henderson. 3. Attached as Exhibit "C" and incorporated by reference herein is a true and correct copy of Post Office inquiry letter indicating that the address is "Good as Addressed." It is apparent that the Defendant is avoiding service, therefore, Plaintiff respectfully requests this Honorable Court grant Plaintiffs Motion for Alternate Service. WHEREFORE, Plaintiff respectfully requests this Honorable Court grant Plaintiffs Motion for Alternate Service. BY: WFORD File #04-06-340 LAW OFFICE OF STEWART C. CRAWFORD & ASSOCIATES BY: Stewart C. Crawford, Esquire ATTORNEY J.D. #09827 223 North Monroe Street P.O. Box E Media, Pennsylvania 19063 (610) 565-7050 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW STATE FARM AUTOMOBILE INSURANCE COMPANY a/s/o WESLEY METZGER IN CIVIL ACTION NO.: 06-4617 CIVIL TERM V. KRISTY BITNER and SHANNON HENDERSON MEMORANDUM OF LAW Plaintiff has verified that Defendant Shannon Henderson's address is 2141 Lee Morgan Drive, Jayess MS 39641. Certified mail service was attempted at that address without success. Plaintiff has confirmed that this is the Defendant's current address. It is clear that the Defendant is avoiding service,. and . therefore, Plaintiff respectfully requests this Honorable Court to enter an Order allowing Plaintiff to serve Defendant by regular and certified mail pursuant to Pa. R.C.P.430. WHEREFORE, Plaintiff respectfully requests this Honorable Court grant Plaintiffs Motion for Alternate Service. LAW OFFICE OF STEWART CRAWFORD BY: tewart C. Crawford, Es Attorney for Plaintiff VERIFICATION The undersigned hereby states that he is an authorized agent of Plaintiff insurance company in this action and verifies that the statements contained in the foregoing Plaintiffs Motion for Alternate Service with supporting Memorandum of Law are true and correct. The undersigned understands that false statements herein are made subject to the penalties of 18 P A. C. S. Section 2004, relating to unsworn falsification to authorities. DATE:J.# ------ EXH\B\1 A. ----- Stewart C. Crawford, Jr. LAW OFFICE OF STEWART C. CRAWFORD & ASSOCIATES 223 NORTH MONROE STREET P. O. BOX E MEDIA, P A 19063 E-MAIL ADDRESS:SCCRAWFORD@SUBROLAW.US Tel: (610) 565-7050 Fax: (610) 565-5348 Stewart C. Crawford Leslie S. Britt Admitted in P A & NJ August 28, 2006 Shannon Henderson 2141 Lee Morgan Road Jayees, MS 39641 Re: State Farm Mutual Automobile Insurance Company a/s/o Wesley Metzger vs. Kristy Bitner & Shannon Henderson Our File No.: 04-06-340 Cumberland County, Pennsylvania, C.C.P. No.: 06-4617 Dear Ms. Henderson: Enclosed please find a copy of a Civil Action Complaint filed against you in the Cumberland County Court of Common Pleas. Very truly yours, ~ STEWART C. CRAWFORD SCC:gv Enclosure VIA CERTIFIED,& FIRST CLASS MAIL ..II -...J LtJ ..r:: CJ (]:I ..r:: ..r:: . \'..\.~ ~.,,,, <~:~, ~.<::~':~' :~~, . ... . \1..."'\.... >p':f_ <~." ;~', .:. . '.' ;" " ; I!~ t~ \' <~ ~l \t.\'\:. ... >l'" \.,,' "," ...!> , ~...o ~~ ~/:,c,\ .;.. .. o?'" ;.~ ~.~ . , ~~;.; ~ 0 . ~) ,\\Q,~.; .,o<!' 2pe"" . . ; ~ . -------- EXH\6\1 6 ------------ SUBRO INVESTIGATIONS P.O. BOX 286 METUCHEN, NJ 08840 TEL: (866) 600-7547 FAX: (732) 548..8026 SUBRO REPORT & INVOICE Prepared for: STBWART C. CRAWFORD &. ASSOCIATES fO BOX E MEOlA. PA 19063 AT!: GINA VALLEm 61112006 0406340 I Date CASE/CLAIM # ITEMS REPORT: ADDRESS INSURED/PLAINTIFF: WESLEY METZGER DATE OF LOSS~ 2;j..oS-200S NAME: SHANNON HENDERSOli ADDRESS: 2141 LEE MORGAN ROAD. CITY, STATE, ZIP: JAYESS. MS 39641 TELEPHONE: SOCIAL SECURITY: 587-45-7788 DRIVER LICENSE #: DATE OF BIRTH: 02~1~-1983 EMPLOYMENT: ADDRESS: CITY, STAm, 'zIP: TELEPHONE: pOSITION: lNCOtvffi $: BANK: BANK ADDlU!SS: CITY. STATE, ZIP: TELEPHONE; BANK ACCOUNT: BALANCE $; REAL PROPERTY: COMMENTS: S~QN'S CURRENT ADDRESS HAS BEEN CONFIRMED BY NEIGHBORHOOD SEARCH AND P9STAL RECORD. SEE COPY OF RECORD. HIS CREDIT REPORT INDICATES THIS ADDRESS AS A FORMER ONE: OUR SEARCH INDICATES SHANNON CURR:BNTL Y RESIDES WITH RELATIVES AT ~ LEE ~=ROAo. SEE COpy OF CREDIT REPORT. fIKE COUNTY. MS. TAX ASSESSOR ICATE TI'E. COWART OWNS 1HE MOBILE HO~ AT 2141 LEE MORG~ RD' ASSESSED VALUE IS 5367; PLEASE MAKE CHECKS PAYABLE TO SUBRO INVESTIGA TJONS FED TAX InN 22-3056426 Total $75.00 \, J-' Skip Tracing Inc. PO Box 286 Metuchen, NJ 08840 732-548-7741 FAX 732-548-8026 Date: May 30, 2006 ~ POS1MASlER JAYESS. MS 39641 REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMA nON NEEDED FOR SERVICE OF LEGAL PROCESS Please :furnish the new address or the name and slreet address (if a box holder) for the following: NAME: SHANNON HENDERSON ADDRESS: 2141 lEE MORGAN ROAD, JAVSSS, MS 39641 The following is provided in accordance with 39CF265.6(D)(6)(II). 1HERE IS NO FEE FOR PROVIDING BOXHOLDER. INFORMATION. The fee for providing change of address infonnation is waNed in accordance with 39CFR 265.6 (d) (1) and (2) and corresponding Administrative Support Manual 352.44 1. CapaciW of Requester: PROCESS SEaVER 2. Statute or regulation that empowers me to seJVe process: NJ ST A roTE 45: 19.22 NEW JERSEY STATE POLICE PRIVATE DETECI1VE LICENSE NUMBER 4323 3. The names of all parties known to the litigation: CRAWF~ V. HENDERSON 4. The court in which the case has been or win be heard: PI1IU\OELPH", COUNTY: SPECI.AI.. CIVIL PMT 5. The docket or other identifying number if one has been issued: 04~ 6. The capacity in whicb the individual is to be seIVed: DEPENDANr WARNING The submission of false infonnation to obtain and use change of address information for any purpose other, than the service of legal process in connection with actual or prospective litigation could result in criminal penalties including a fine of up to $l()~OOO.OO or imprisomnent or (2) to avoid payment of the fee for change ofaddres$ information of not more than 5 years or both (Title 1.7 U.S.C. Section 1001). I certify that the above information is true and that the address infonnation is needed a.nd wilt be used solely for service of legal pr:ocess. h~ooC ....... -,,,,,,.,, . r"'~ ~,~ ~~..4, "'-..r . ,'," ..1'. ~ ...J 1'\ ..".(,_.,~, ~ tl.l!17~~~ yj ~.!.~...../~... .~ Signature mOMAS BLACK PO BOX 286 METUCHEN. NJ 08840 FOR POST OffICE USE ONLY XGOOP AS ADDRESSED _NOt KNOWN AT ADDRESS _MOVED LEFT NO FORW AR,DING ADDRJ?:SS _NO SUCH ADDRESS NEW ADDRESS 3!Y EXHIBIT C File #04-06-340 LAW OFFICE OF STEWART C. CRAWFORD & ASSOCIATES 223 NORTH MONROE STREET P. O. BOX E MEDIA, P A 19063 E-MAIL ADDRESS:SCCRAWFORD@SUBROLAW.US Tel: (610) 565-7050 Fax: (610) 565-5348 Stewart C. Crawford Leslie S. Britt Admitted in PA & NJ Stewart C. Crawford, Jr. September 28, 2006 POSTMASTER UNITED STATES POST OFFICE JA)1ESS,~S 39641 Request for change of address or Boxholder Information needed for Service of Legal Process Name: Address: Shannon Henderson 2141 Lee Morgan Road, Jayess, MS 39641 The following information is provided in accordance with 39 CFR265.6 (d) (ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6 (d) (1) and (2) and corresponding Administrative Support ~anual352.44 (a) and (b). 1. Capacity of requested (e.g. process server, attorney, party representing her/himselt): attorney 2. Statute of regulation that empowers me to serve process (not required when requestor is attorney): 3. 'The names of all known parties to .th'e litigation: State Farm Insurance Company 4. The Court in which the case has been or will be heard: Court of Common Pleas of Cumberland County 5. The docket or other identifying number, if one has been issued:. 06-4617 6. The capacity in which this individual is to be served (e.g. defendant or witness): Defendant ~. WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES, INCLUDING A FINE UP TO $10,000.00 OR IMPRISONMENT OR TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT ~ORE THAN FIVE )1EARS OR BOTH (TITLE 18 U.S.C. SECTION 1001). I certify that the above information is true and the address information is needed and will be used solely for the service oflegal process or locating defendant/witness in connection with actual or prospective litigation. LAW OFFICE OF STEWART C. CRAWFORD 223 Monroe Street, P.O. Box E ~edia, P A 19063 STEWARTC. CRAWFORD. Esquire ~ GOODASADDRESSED. No CHANGE OF ADDRESS ORDER ON FILE. FOR POST OFFICE USE ONLY NEW ADDRESS OR BOXHOLDER'S STREET ADDRESS: POSTMARKlDATE STAM NOT KNOWN AT ADDRESS GIVEN. _ ~OVED, LEFT NO FORWARDING ADDRESS. NO SUCH ADDRESS. SF aJslo Metzger v. Bitner & Henderson \. ~' File #04-06-340 LAW OFFICE OF STEWART C. CRAWFORD & ASSOCIATES BY: Stewart C. Crawford, Esquire ATTORNEY I.D. #09827 223 North Monroe Street P.O. Box E Media, Pennsylvania 19063 (610) 565-7050 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW STATE FARM AUTOMOBILE INSURANCE COMP ANY a/s/o WESLEY METZGER IN CIVIL ACTION NO.: 06-4617 CIVIL TERM V. KRISTY BITNER and SHANNON HENDERSON CERTIFICATE OF SERVICE I, STEW ART C. CRAWFORD, Esquire, Attorney for Plaintiff, hereby certify that a true and correct copy of the Plaintiff s Motion for Alternate Service filed in the above-entitled action was served upon the following by regular mail on November 9, 2006 at the addresses set forth below by the U.S. Postal Service. Shannon Henderson 2141 Lee Morgan Road Jayess, MS 39641 Kristy Bitner 106 D Wolf Bridge Road Carlisle, P A 17013 DATE:~ ~~~-- Attorney for Plaintiff () ~; (j -rl ~-.: c:..:, -;:,-... f'J :;0 c:; .< STATE FARM AUTOMOBILE INSURANCE COMPANY, alslo WESLEY METZGER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LA W KRISTY BITNER and SHANNON HENDERSON, Defendants NO. 06-4617 CIVIL TERM ORDER OF COURT AND NOW, this 21 st day of November, 2006, upon consideration of Plaintiffs Motion for Alternate Service, and it appearing that Plaintiff s attempt at service of original process upon Defendant Shannon Henderson by restricted delivery mail which was returned "unclaimed," the Plaintiff s request for alternate service in the form of regular and certified mail is denied and Plaintiff is directed to proceed in accordance with Pa. R.C.P. 403(2). BY THE COURT, Stewart C. Crawford, Esq. 223 North Monroe Street P.O. Box E Media, P A 19063 ,~ C>>fJ Attorney for Plaintiff /1- :1,)/0(, c+ :rc 9<1 .\1 I p..' ., /' I~Jll~J Qnn7 I .. i Jt;~: (;v ~-,~'.;'1 .IvY..... File #04-06-340 LAW OFFICES OF STEWART C. CRAWFORD BY: Stewart C. Crawford, Esquire ATTORNEY LD. # 09827 223 North Monroe Street P.O. Box E Media, P A 19063 Telephone: (610) 565-7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION-LAW STATE FARM MUTUAL AUTOMOBILE: INSURANCE COMPANY alslo WESLEY METZGER IN CIVIL ACTION NO.: 06-4617 Civil Term v. KRISTY BITNER & SHANNON HENDERSON PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate this Complaint an additional ninety (90) days pursuant to Pa.R.C.P. 404(2). ,'-."' Dated: /~~ (") ,-- ~~~. T"V = = <::1"' c::> 1'1 CJ , --' o -n --I Xl :n n...- -om -00 U6 ~.-( """'j .'''C -V'l ~..~~ ~~ o -I ?D =< "" 3: N .. N ex> FILE #04-06-340 LAW OFFICES OF STEWART C. CRAWFORD & ASSOCIATES BY: STEWART C. CRAWFORD, ESQUIRE ATTORNEY I.D. NO. 09827 223 NORTH MONROE STREET MEDIA, PA 19063 TELEPHONE: (610) 565-7050 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA, CIVIL ACTION LAW STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY a/s/o WESLEY METZGER IN CIVIL LAW NO.: 06-4617 v. KRISTY BITNER & SHANNON HENDERSON PRAECIPE TO ORDER TO SETTLE. DISCONTINUE AND END TO THE PROTHONOTARY: Please mark the record in the above-captioned matter as "Settled, Discontinued and Ended" upon payment of costs. DATE: / ItJ. ;{" , , t-'::> c.::> :3 (,..... ~; ....... N ...0 ~ .-\ ~-r. ,11 r:: -ot::r; '.U'1' :=:;l9" V?? ~ p -,$ - - (.J' Cl'"