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Home My WebLink About06-5434IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Colby D. Neil Plaintiff VS. AAA Insurance Company Defendant No. SW : Civil Action - Law NOTICE 0CjCC-r&kV-1 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 ANY OTHER CLAIM FOR 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 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA (717) 249-3166 H. ANTHONY ADAMS ATTORNEY AT LAW SUPREME COURT ID NO. 25502 49 WEST ORANGE STREET, SUITE 3 SHIPPENSBURG, PA 17257 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Colby D. Neil Plaintiff VS. AAA Insurance Company Defendant No. Civil Action - Law COMPLAINT 1. Plaintiff is Colby D. Neil, an adult individual, who resides at 306 Walnut Street, Shippensburg, Pennsylvania, 17257. 2. Defendant is AAA Life Insurance Company with an address of 17250 Newburg Road, Suite 100, Livonia, MI 48152. 3. On or about April 13, 2003 the Defendant issued to Charles C. Neil a term life insurance policy number T555694592. 4. The certificate promised to pay to the named beneficiary upon the death of the certificate holder the amount of $100,000.00. 5. The beneficiary to whom payment was to be made was the Plaintiff, Colby D. Neil. 6. A claim for payment was made by Plaintiff and the claim was denied by Defendant on March 19, 2004. 7. The denied of the claim for payment is a breach of contract. 8. The Plaintiff is entitled to the benefit of the insurance contract and demands payment from Defendant in the amount of $100,000.00. WHEREFORE, Plaintiffs pray you Honorable Court enter judgment in his favor and against Defendants in an amount of $100,000.00. Respectfully submitted, H. Anthony Adams, Esquire Attorney for Plaintiffs 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 VERIFICATION We verify that the statements made in this Amended Complaint are true and correct. We 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:? /2-a( IL ?" COLBY D. IL 77 7r, V1 _ d V .J IN THE COURT OF COMMON PLEAS OF THE 39TH JUDICIAL DISTRICT OF PENNSYLVANIA - FRANKLIN COUNTY BRANCH Colby D. Neil Plaintiff : No. c;?006 ~- C)S V 3 1 vs. : Civil Action - Law AAA Insurance Company Defendant AFFIDAVIT OF SERVICE '"I. ? I 7- o OD ?J O O Ln L-j 03 ti 0 0 0 0 Ln Er w w Q' 0 03 W H. Anthony Adams, Esquire being duly sworn according to law deposes and states that a complaint was mailed to AAA Insurance Company, of 17250 Newburg Road, Suite 100, Livonia, MI, 48152, by certified mail, return receipt requested on September 29, 2006 and was accepted on delivery by an agent of AAA Insurance Company on September 29, 2006. V' --3 i o yy T ff R? 1000 5 a a 3 H. Anthony Adams, Esquire l m Attorney for Plaintiff y m = 70 49 W. Orange Street, Suite 3 a (D 3 s y o w a 1 Shippensburg, PA 17257 E o v N (717)-532-3270 00 C? FD ; akI Q < ? a a z a 3 3 FO ID -o ? m m a w ? ??, _ sn ;r m MM CL ? F ?40 ? ?? o 1 m a O m Sworn to and subscribed this 6' day of 2006. Notary Public My Commission Expires: COMMONWEALTH OF pENNSYLvg*A NtJTARiAL SEAL DRENDA L W*HM, Notary Pubes 1WYN0OW00. *County Oomrniseion Expires Jan. 8. 2M `? ' {'z r 1 ?? y ?1 ?? •? ? ? 1 ? 1 s ?. ` ? ??1f - ..-?' { : e _ ?. ; ?? r ?11... ?? ? Y? ? y ., ?e?? ... COLBY D. NEIL IN THE COURT OF COMMON PLEAS Plaintiff(s) : OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW V. : NO. 06-5434 AAA Insurance Company Defendant(s) PRAECIPE FOR ENTRY OF APPEARANCE To the Prothonotary: Please enter the appearance of Andrew W. Norfleet, Esquire, on behalf of Defendant, AAA Insurance Company in the above-captioned action. Respectfully submitted, METZGER, WIZSHAM, KNAUSS & ERB, P.C. Andrew W. Norfleet, Esquire Attorney I.D. No. 83894 P.O. Box 5300 3211 North Front Street Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Defendants Dated: December 5, 2006 368398-1 .'P w CERTIFICATE OF SERVICE AND NOW, this day of Ct? , 2006, I, Angela Lentz, of Metzger, Wickersham, Knauss & Erb, P.C., attorneys for Defendant, hereby certify that I served a copy of the foregoing document Addressed to All Parties this day by depositing the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: H. Anthony Adams, Esquire Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburg, Pa 17257 368398-1 C? ? - Cn C_Tt I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Colby D. Neil Plaintiff VS. AAA Insurance Company Defendant TO THE PROTHONOTARY: : No:06-5434 CIVIL Term Civil Action - Law Praecipe Please dismiss the complaint in the above captioned matter and marked the action as having been settled. Respectfully, Date: /0 ?) H Anthony Adams, Esquire Attorney for Plaintiff 49 West Orange Street, Suite 3 Shippensburg, PA 17257 Attorney ID No. 25502 (717) 532-3270 - _.., C? , ? .. ,?,..? i? ?? .? fit - ? i,. ` ) ?i 4 Mr-? " w