HomeMy WebLinkAbout06-5932PAUL 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 SHAWN GOOD AND : CUMBERLAND COUNTY
MICHELLE GOOD
4901 LOUISE DRIVE
MECHANICBURG, PA 17055
VS.
NO. 0 G - 5'qi 3a2 e?t.( -TZ-
KEVIN MYERS
3023 HARVARD AVENUE
CAMP HILL, PA 17011
AND
: CIVIL ACTION
ENTERPRISE RENT-A-CAR .
3401 HARTZDALE DRIVE .
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 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„ 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.
Cumberland County Bar Association
32 Bedford Street
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
AVISO
Le han demandado a usted en la Corte. Si usted quiere defenderse
de estas demandas expuestas en las paginas siguientes, usted tiene
(20) dias de plazo a partir de la fecha de la demanda y la notificacion.
Usted debe presentar una apariencia escrita o en persona o por
abogado y archivar en la Corte sus defensas o sus objeciones a las
demandas encontra de su persona. Sea avisado que si usted no se
defiende, la Corte tomara medidas y puede entrar una orden Contra
usted sin previo aviso o notificacion o por cualgier queja o alivio que
espedido en la peticion de demanda. Usted puede perder dinero, sus
propiedades o otros derechos importantes pare usted.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI
NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE
PARA PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR
TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA
ESCRITA ABAJO PARA AVERIGUAR DONDE LISTED PUEDE
CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
32 Bedford Street
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
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 SHAWN GOOD AND : CUMBERLAND COUNTY
MICHELLE GOOD
4901 LOUISE DRIVE
MECHANICBURG, PA 17055
VS.
KEVIN MYERS
3023 HARVARD AVENUE
CAMP HILL, PA 17011
AND
ENTERPRISE RENT-A-CAR
3401 HARTZDALE DRIVE
CAMP HILL. PA 17011
NO. o c? sS 3 -2C I, ( -Ft-1-
CIVIL ACTION
NOTICE UNDER THE FAIR DEBT COLLECTION PRACTICES ACT,
15 U.S.C. §1601 (AS AMENDED)
THE PENNSYLVANIA UNFAIR TRADE PRACTICES ACT
AND CONSUMER PROTECTION LAW,
73 PA.CON.STAT.ANN. §201, ET. SEQ. ("THE ACTS")
INASMUCH AS THE ACTS MAY APPLY, PLEASE BE ADVISED
THAT THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE
COMPLAINT
The Plaintiff, Erie Insurance Group by its attorney Paul F. D'Emilio, Esquire,
bring this action upon a cause whereof the following is a statement:
The Plaintiff, Erie Insurance Group is a Corporation authorized to do business in
the Commonwealth of Pennsylvania, having an office at 4901 Louise Drive,
Mechanicsburg, PA 17055.
Plaintiff brings this action as subrogee of Shawn Good and Michelle Good,
("Insured") under a policy of insurance # Q081507702, issued by Plaintiff.
2. The Defendant, Kevin Myers, is an individual residing at 3023 Harvard Avenue,
Camp Hill, PA 17011.
3. The Defendant, Enterprise Rent-A-Car, is a Corporation authorized to do
business in the Commonwealth of Pennsylvania with its principal office at 3401
Hartzdale Drive, Camp Hill, PA 17011.
4. At all times hereinafter mentioned the Defendant, Kevin Myers was the
agent, workman, servant and employee of the Defendant, Enterprise Rent-A-Car then
and there in engaged in the business of the Defendant, Enterprise Rent-A-Car within
the course and scope of his employment.
5. On or about August 4, 2005, Plaintiff's Insured was traveling on Walnut Bottom
Road, Carlisle, PA when a motor vehicle owned by the Defendant, Enterprise Rent-A-
Car and operated by the Defendant, Kevin Myers struck the Insured's vehicle in the rear
causing the damages herein after mentioned.
6. Plaintiff avers that the motor vehicle of the Insured was damaged as a result of
the occurrence hereinbefore mentioned, the reasonable costs of repairs thereto being is
Five Thousand Eight Hundred Four and 07/100 ($5,804.07) Dollars plus the
Insured's deductible of Five Hundred and 00/100 ($500.00) Dollars for a total of Six
Thousand Three Hundred Four and 07/100 ($6,304.07) Dollars.
Count I
Erie Insurance Group v. Kevin Myers
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
though same were herein and set forth at length.
2
8. The said occurrence was due solely to the negligence of the Defendant, Kevin
Myers in that he:
a. did fail to have his motor vehicle under proper and adequate control;
b. did fail to apply his brakes in time to avoid the collision;
C. did negligently apply his brakes;
d. did fail to observe the Insured vehicle in accordance with existing traffic
conditions and traffic controls;
e. did permit or allow his vehicle to strike and collide with the automobile
operated by the Insured;
f. did fail to drive at a speed and in a manner that would allow him to stop
within the assured clear distance ahead;
g. did fail to keep a reasonable lookout for other vehicles lawfully on the
road;
h. did operate his motor vehicle without due regard for the rights, safety and
position of the Insured at the point aforesaid;
i. failed to maintain financial responsibility; and
j. did violate the various statutes and laws of the Commonwealth of
Pennsylvania and County of Cumberland, pertaining to the operation of motor vehicles.
Count II
Erie Insurance Group v. Enterprise Rent-A-Car
9. Plaintiff, Scottsdale Insurance Company, incorporates by reference all of the
allegations contained in paragraphs 1 through 8 inclusive of this Complaint as fully as
though same were herein and set forth at length.
10. The said occurrence was do to the negligence of the Defendant, Enterprise
Rent-A-Car, in that they:
a. entrusted its vehicle to an operator for use when it knew, or with a
3
reasonable exercise of due care should have known, that the operator was not capable
of operating the vehicle properly;
b. negligently entrusted the vehicle to a person which it knew, or in the
exercise of reasonable care should have known, was an incompetent driver;
C. negligently entrust the motor vehicle to another person who it knew,
should have known or in the exercise of due care would have known would cause
damages to another;
d. negligently entrusted its vehicle to a person known, should have known or
in the exercise of reasonable care could have known, was going to drive the vehicle in
an improper, dangerous or reckless manner; and
e. did violate the various statutes and laws of the County of Cumberland,
and Commonwealth of Pennsylvania pertaining to the operation of motor vehicles.
WHEREFORE, Plaintiff demands judgment against the Defendants upon each
count in an amount not in excess of Fifty Thousand and 00/100 ($50,000.00) dollars
together with costs of suit. 4 AUL 'EMI I , ESQUIRE
ATTORNEY FOR PLAINTIFF
4
VERIFICATION
I, vy ? 1 "\QQS'?A Claim Representative for Erie Insurance Group,
PLAINTIFF in the above captioned matter verifies that the facts contained in the
foregoing Complaint are true and correct. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom
falsification to authorities.
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DATE: _ ?? ?.
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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 SHAWN GOOD AND
MICHELLE GOOD
4901 LOUISE DRIVE
MECHANICBURG, PA 17055 .
VS.
KEVIN MYERS
3023 HARVARD AVENUE
CAMP HILL, PA 17011
COMMON PLEAS COURT OF
CUMBERLAND COUNTY
NO. 06-5932
AND
CIVIL ACTION
ENTERPRISE RENT-A-CAR
3401 HARTZDALE DRIVE
CAMP HILL, PA 17011
PRAECIPE TO REINSTATE THE COMPLAINT
TO THE PROTHONOTARY, C.P.:
Kindly reinstate the Complaint in the above-captioned matter.
AUL . D'EMILIO, ESQUIRE
ATTORNEY FOR PLAINTIFF
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SWEENEY & SHEEHAN, P.C.
By: Patrick J. Sweeney, Esquire
Identification No. 79120
1515 Market Street
Nineteenth Floor
Philadelphia, PA 19102
(215) 563-9811
Attorney for Defendant:
Penrac, Inc.
ERIE INSURANCE GROUP as Subrogee of COURT OF COMMON PLEAS
SHAWN GOOD and MICHELLE GOOD CUMBERLAND COUNTY
CIVIL DIVISION
V.
NO. 06-5932
KEVIN MYERS and ENTERPRISE RENT-A-CAR:
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of Defendant, Penrac, Inc.,(incorrectly designated as
Enterprise Rent-A-Car in Plaintiff's Complaint), in the above-captioned matter.
SWEENEY & SHEEHAN, P.C.
By: "V_V,
PatriJ. S eeney
DATE: November 22, 2006
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SWEENEY & SHEEHAN, P.C.
By: Patrick J. Sweeney, Esquire
Identification No. 79120
1515 Market Street
Nineteenth Floor
Philadelphia, PA 19102
(215) 563-9811
Attorney for Defendant:
Penrac, Inc.
ERIE INSURANCE GROUP as Subrogee of
SHAWN GOOD and MICHELLE GOOD
V.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL DIVISION
NO. 06-5932
KEVIN MYERS and ENTERPRISE RENT-A-CAR:
DEFENDANTS, PENRAC, INC.,LINCORRECTLY DESIGNATED AS ENTERPRISE
RENT-A-CAR IN PLAINTIFF'S COMPLAINT), ANSWER TO PLAINTIFFS'
COMPLAINT TOGETHER WITH NEW MATTER AND NEW MATTER
CROSSCLAIM
COMES NOW Defendant, Penrac, Inc. (incorrectly designated as Enterprise Rent-A-Car
in Plaintiffs' Complaint) (hereinafter "Penrac"), and files this its Answer to Plaintiffs' Complaint
together with New Matter and New Matter Crossclaim. In support thereof, Answering Defendant
avers as follows:
1. Denied. After reasonable investigation, Answering Defendant is without information
sufficient to affirm or deny the averments of this paragraph and strict proof is demanded at the time
of trial. For further answer, these averments constitute conclusions of law requiring no response.
2. Denied. For further answer, these averments constitute conclusions of law requiring
no response.
3. Admitted in part, denied in part. It is only admitted that Defendant, Penrac, is a
corporation license to conduct business in the Commonwealth of Pennsylvania. The remaining
averments of this paragraph are denied.
4. Denied. Answering Defendant, Penrac, denies that the Co-Defendant, Kevin Myers,
was its agent, workman and employee at any time relevant to this cause of action. Answering
Defendant denies that the Co-Defendant, Kevin Myers, was engaged in business on behalf of
Answering Defendant at any time relevant to this cause of action. Answering Defendant denies the
Co-Defendant, Kevin Myers, had permission to operate its vehicle at any time relevant to this cause
of action.
5. Denied. For further answer, these averments constitute conclusions of law requiring
no response.
6. Denied. After reasonable investigation, Answering Defendant is without information
sufficient to affirm or deny the averments of this paragraph and strict proof is demanded at the time
of trial. For further answer, these averments constitute conclusions of law requiring no response.
WHEREFORE, Answering Defendant, Penrac, Inc., demand that judgment be entered in
its favor and against the Plaintiffs together with all reasonable interests, counsel fees and costs.
COUNTI
Erie Insurance Group v. Kevin Myers
7. Answering Defendant incorporates by reference paragraphs 1 through 6, above, as
if the same were forth fully at length herein.
8. The averments of this paragraph relate to a Defendant other than Answering
Defendant no answer is required. To the extent that an answer is required, said averments are
denied.
WHEREFORE, Answering Defendant, Penrac, Inc., demand that judgment be entered in
its favor and against the Plaintiffs together with all reasonable interests, counsel fees and costs.
COUNT II
Erie Insurance Group v. Enterprise Rent-A-Car
9. Answering Defendant incorporates by reference paragraphs 1 through 8, above, as
if the same were forth fully at length herein.
10. Answering Defendant denied that it was negligent at any time relevant to this cause
of action. Answering Defendant denies that the Co-Defendant, Kevin Myers, had it permission
and/or authority to be operating its vehicle at any time relevant to this cause of action. Answering
Defendant denies that it negligently entrusted its vehicle to the Co-Defendant, Kevin Myers. All
averments of this paragraph are denied. For further answer, these averments constitute conclusions
of law requiring no response.
WHEREFORE, Answering Defendant, Penrac, Inc., demand that judgment be entered in
its favor and against the Plaintiffs together with all reasonable interests, counsel fees and costs.
NEW MATTER
11. Answering Defendant, Penrac, Inc., incorporates by reference paragraphs Ithrough
10, above, as if the same were forth fully at length herein.
12. The provisions of the Pennsylvania Comparative Negligence Act, 17 P.S. Sections
2101, 2102, apply in this case to limit or bar Plaintiff s cause of action.
13. The provisions of Pennsylvania's Motor Vehicle Financial Responsibility Law 75 Pa.
C.S.A. Section 1701, et M. apply in this case and limit or bar Plaintiffs cause of action.
14. Plaintiffs assume the risk of their own conduct.
15. Plaintiffs' cause of action is barred by the applicable Statute of Limitations.
16. This Court lacks subject matter jurisdiction of the within action.
17. Plaintiffs' Complaint fails to state a claim upon which relief can be granted.
18. Plaintiffs' injuries, if any, were caused by the negligence and/or liability producing
acts or omissions of parties or other entities over whom Answering Defendant neither has control
nor the ability to control.
19. Plaintiffs failed to mitigate damages, if any.
20. Plaintiffs' cause of action must fail due to the Sudden Emergency Doctrine.
21. Plaintiffs' cause of action must fail due to the Doctrine of Release.
22. Plaintiffs' cause of action must fail due to the defense of unavoidable accident.
WHEREFORE, Answering Defendant, Penrac, Inc., demands judgment be entered in its
favor, and against the Plaintiffs, together with all reasonable interest, expenses, counsel fees and
costs.
NEW MATTER PURSUANT TO Pa. R.C.P. 2252(d) IN THE NATURE OF A
CROSSCLAIM AGAINST DEFENDANT, KEVIN MYERS
23. If the allegations of Plaintiffs' Complaint are shown to be true, any negligence or
liability on the part of Answering Defendant, Penrac, Inc., being expressly denied, then Co-
Defendant, Kevin Myers, is primarily liable therefor, and is liable over to Answering Defendant,
Penrac, Inc., by way of indemnity for any amounts which the said Co-Defendant might be
required to pay Plaintiffs; or, in the alternative, Co-Defendant, Kevin Myers, is liable to
Answering Defendant, Penrac, Inc., for contribution.
WHEREFORE, Answering Defendant, Penrac, Inc., demands judgment of indemnity
against Co-Defendant, Kevin Myers, for all sums which Answering Defendant may be required to
pay Plaintiffs, or, in the alternative for contribution.
SWEENEY & SHEEHAN
By:
PatriJ. Sw ney
Attorney for Defendant,
Penrac, Inc.
DATED: November 30, 2006
VERIFICATION
PATRICK J. SWEENEY, ESQUIRE, verifies and says that he is an attorney-at-law in the
offices of SWEENEY & SHEEHAN; that he is authorized to make this Verification; and, the facts
set forth in the foregoing DEFENDANT, PENRAC, INC. (INCORRECTLY DESIGNATED AS
ENTERPRISE RENT-A-CAR IN PLAINTIFFS' COMPLAINT), ANSWER TO PLAINTIFFS'
COMPLAINT TOGETHER WITHNEWMATTER AND NEWMATTER CROSSCLAIM, are true and
correct to the best of his knowledge, information and belief.
This Verification is made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to
unsworn falsification to authorities.
kL,?P,/
PAT CK . SWEENEY
DATE: November 30, 2006
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SWEENEY & SHEEHAN, P.C.
By: Patrick J. Sweeney, Esquire
Identification No. 79120
1515 Market Street
Nineteenth Floor
Philadelphia, PA 19102
(215) 563-9811
ERIE INSURANCE GROUP as Subrogee of
SHAWN GOOD and MICHELLE GOOD
V.
KEVIN MYERS and ENTERPRISE RENT-A-CAR:
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL DIVISION
NO. 06-5932
STIPULATION TO AMEND CAPTION
It is hereby AGREED to and STIPULATED by the undersigned counsel that the caption
in all subsequent pleadings in the above-captioned matter is amended to reflect the proper name of
the Defendant as Penrac, Inc., incorrectly designated as Enterprise Rent-A-Car.
B a-0 I j P
Paul F. 'Emilio, squire
Attorney for Plaintiffs
Attorney for Defendant:
Penrac, Inc.
SWEENEY & SHEEHAN, P.C.
By: 4&04 Patrick Swe y, Esquire
Attorney for fendant,
Penrac, inc.
DATE: ?.? " 6 '`C,/ ,,
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2006-05932 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ERIE INSURANCE GROUP
VS
MYERS KEVIN 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
MYERS KEVIN but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT & NOTICE ,
NOT FOUND , as to
the within named DEFENDANT
MYERS KEVIN
3023 HARVARD AVENUE
CAMP HILL, PA 17011
DEFENDANT HAS NOT LIVED AT GIVEN
ADDRESS FOR OVER A YEAR.
Sheriff's Costs: So answers:
Docketing 18.00
Service 12.32.-
Not Found 5.00 R. Thomas Kline
Surcharge 10.00 Sheriff of Cumberland County
.00
45.32/
lilt-110t, L?-
Sworn and Subscribed to before
me this day of
PAUL DEMILIO
10/31/2006
A. D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-05932 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ERIE INSURANCE GROUP
VS
MYERS KEVIN ET AL
JASON VIORAL , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
the
ENTERPRISE RENT-A-CAR
was served upon
DEFENDANT
at 1649:00 HOURS, on the 30th day of October , 2006
at 3401 HARTZDALE DRIVE
CAMP HILL, PA 17011
by handing to
JON VRABEL, AREA MANAGER, ADULT IN CHARGE
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: So Answers:
Docketing
Service 6.00
12.32
rr9
%'
Affidavit .00 y
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Surcharge 10.00 R. Thomas Kline
.00
28.32x' 10/31/2006
1111710(, q, PAUL DEMILIO
Sworn and Subscibed t o By:
before me this
of
day put Sheriff
A.D. Z7---,
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 SHAWN GOOD AND : CUMBERLAND COUNTY
MICHELLE GOOD .
4901 LOUISE DRIVE .
MECHANICBURG, PA 17055
VS. NO. 06-5932
KEVIN MYERS
3023 HARVARD AVENUE
CAMP HILL, PA 17011
AND
CIVIL ACTION
PENRAC, INC.
3401 HARTZDALE DRIVE
CAMP HILL. PA 17011
ORDER TO DISCONTINUE AND END
AS TO DEFENDANT, PENRAC. INC. ONLY
TO THE PROTHONOTARY CP:
Kindly mark the above entitled matter settled and discontinued, upon the
Defendant, Penrac, Inc. only upon payment of your cost only.
caji ru""L
PAUL F. 'EMI IO, ESQUIRE
ATTORNEY FOR PLAINTIFF
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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 SHAWN GOOD AND CUMBERLAND COUNTY
MICHELLE GOOD .
4901 LOUISE DRIVE .
MECHANICBURG, PA 17055
VS. NO. 06-5932
KEVIN MYERS
3023 HARVARD AVENUE
CAMP HILL, PA 17011
AND
CIVIL ACTION
ENTERPRISE RENT-A-CAR .
3401 HARTZDALE DRIVE .
CAMP HILL. PA 17011
PRAECIPE TO REINSTATE THE COMPLAINT
TO THE PROTHONOTARY, C.P.:
Kindly reinstate the Complaint in the above-captioned matter.
L F. D'EMILIO, ESQUIRE
ATTORNEY FOR PLAINTIFF
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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 SHAWN GOOD AND : CUMBERLAND COUNTY
MICHELLE GOOD
4901 LOUISE DRIVE
MECHANICBURG, PA 17055
VS. NO. 06-5932
KEVIN MYERS
3023 HARVARD AVENUE
CAMP HILL, PA 17011
AND
CIVIL ACTION
ENTERPRISE RENT-A-CAR
3401 HARTZDALE DRIVE
CAMP HILL, PA 17011
PRAECIPE TO REINSTATE THE COMPLAINT
TO THE PROTHONOTARY, C.P.:
Kindly reinstate the Complaint in the above-captioned matter.
jzalzL
PAUL F. D'EMILIO, ESQUIRE
ATTORNEY FOR PLAINTIFF
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SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2006-05932 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ERIE INSURANCE GROUP
VS
MYERS KEVIN ET AL
R. Thomas Kline
Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
MYERS KEVIN
but was unable to locate Him
deputized the sheriff of YORK
serve the within COMPLAINT & NOTICE
County, Pennsylvania, to
On January loth , 2007 , this office was in receipt of the
attached return from YORK
Sheriff's Costs:
Docketing 18.00
Out of County 9.00
Surcharge 10.00
Dep York County 26.12
Postage .63
6 3 . 7 5
01/10/2007
PAUL DEMILIO
Sworn and subscribe to before me
this day of
to wit:
in his bailiwick. He therefore
So answers-
R. Thomas Kline
Sheriff of Cumberland County
1/it1c
A. D.
COUNTY OF YORK
OFFICE OF THE SHERIFF
45 N. GEORGE ST., YORK, PA 17401
SERVICE CALL
(717) 771-9601
SHERIFF SERVICE PLEASE T'1 M OMY LM 1 ''WW 12
PROCESS RECEIPT and AFFIDAVIT OF RETURN Dl's WT MMM MY COPM
1 PLAINTIFF/S/
Erie Insurance Group
3 DEFENDANT/S/
Kevin Myers
2
4. TYPE OF WRIT OR COMPLAINT C I C A
Civil Action Complaint
SERVE 5 NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD
Kevin Myers
6. ADDRESS (STREET OR RFO WITH B IWBER, APT NO.. CI BORO, TWP, STATE ND Z CODE)
, 0 W
AT 1890 Jug over, PA 17315 e
7. INDICATE SERVICE O P L U PERSON IN CHARGE )WbEPUTIZE U CERT MAIL U 1S U POSTED -I OTHER
NOW November 28 20 0 I, SHERIFF O TY, PA, do hereby deputize the sheriff of
York COUNTY to execute thi ?dsfrl rn t drding
to law. This deputization being made at the request and risk of the plaintiff.
SHERIFF OF4tIW COUNTY
8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICF0 U T OF COUNTY Culnberlan
ADVANCE FEE PAID BY ATTY.
Please mail return of service to Cumberland County Sheriff. Thank you.
NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within wnt may leave same
without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff
herein for any loss, destruction. or removal of any property before sheriff's sale thereof. 11 1
9. TYPE NAME and ADDRESS of ATTORNEY / ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER 11 L goo,
Paul F. D'Emilio, Es uire 1610-338-0338
905 W. Sproul Road uite 105, Springfield, PA 1917116
12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed d notice is to be mailed) C U M B E R L A N D CO S H E R I F F
Paul F. D'Emilio, Esquire 905 W. Sproul Road, Suite 105, Springfield, PA 19064
SPACE BELOW FOR USE OF THE SHERIFF - DO NOT WRITE BLOW TM LM
13. 1 acknowledge receipt of the writ 14. DATE RECEIVED 15 Expiration/Hearing Date
or complaint as indicated above. M J M C G I L L Y C S O 111/29/2006 112/27/2006
16. HOW SERVED: PERSONAL ( ) RESIDENCE ( ) POSTED( ) POE( ) SHERIFF'S OFFICE ( ) OTHER ( ) SEE REMARKS BELOW
17. I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, etc. named above. (See remarks below.)
18. fNAME AND TITLE OF INDIVIDUAL SERVED / LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 19. Date of Service 20 Time of Service
21. ATTEMPTSI DaL- I Time I ??Mile s I lot. I Date I Time I Miles I Int. I Date I Time I Miles I Int I Date I Time I Miles I Int. I Date I Time I Miles I Int. I Date I Time I Miles I Int.
22. REMARKS: I
23. Advance Costs 2 ervice Costs 25 N/F 26. Mileage 27. Postage 28. Sub Total 29. Pound 30. Notary 31. Surchg. 32. Tot. Costs 33 Costs Due efund ck No.
75.00
34. ForNyn County Costs 35. Advance Costs 36 Service Costs 37. Notary Cert. 38. Mileage/Postage Not Found 39. Total Costs 40 Costs Due or Refund
41. AFFIRM "1 t3e(oit? me tfiis ," a SO ANSWERS
44. Signature of 45. DATE
42. day of 20 ?P1T z Dep. Sheriff
LISA L. BOVJMA ?i _ /NOTARY 46. Signature of York 47 DATE
PUBLIC County Sheriff O
)F YORK YORK COUNTY
MY Ct? -, R
XPIP1=sA11r' nn. nn WILLIAM M HOSE SHERIFF a 1/4/07 _
- 48. Signature of Foreign 49 DATE
Cnunty Shnnrr
SHERIFF'S RETURN - OUT OF COUNTY
t
,CASE NO: 2006-05932 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ERIE INSURANCE GROUP
VS
MYERS KEVIN ET AL
R. Thomas Kline Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT to wit:
MYERS KEVIN
but was unable to locate Him in his bailiwick. He therefore
deputized the sheriff of YORK County, Pennsylvania, to
serve the within COMPLAINT & NOTICE
On March 16th , 2007 this office was in receipt of t
attached return from YORK
Sheriff's Costs: So answer
Docketing 18.00
Out of County 9.00
Surcharge 10.00 R. Thomas Kl ne
Dep York County 33.55 Sheriff of Cu erland County
Postage .87
71. 4 2 ?
03/16/2007
PAUL D'EMILIO
Sworn and subscribe to before me
this day of
A. D.
"07
' Y
VVVIV 1 T Vr T VRn
VICE
OFFICE OF THE SHERIFF SCR 77196 IL
45 N. GEORGE ST., YORK, PA 17401
SHERIFF SERVICE
PROCESS RECEIPT and AFFIDAVIT OF RETURN PLEAW TYPE OWY L M 1 THM 12
DO NOT DETA
1 PLAINTIFF/S/ 2. COURT NUMBER
Erie Insurance Group Cumberland CCP Nn- _
4. TYPE OF WRIT OR COMPLAINT
3 DEFENDANT1S/
Kevin Myers Complaint C I CA
SERVE 5 NAME OF INDIDUAL, COMPANY, CORPORATION, ETC TO SERVE OR DESCRI I N Of PROPERTY TO BE LEVIED, ATTACHED, OR SOLD
Kevin MyerVIs ?.
6 ADDRESS (STREET OR RFO WITH BOX NUMBER. APT NO., CITY, BORO,1T1fVP"', STATE ANO ZIP CODE)
??-?eeiFede ?4ve ;
AT
7 INDICATE SERVICE U PERSONAL U PERSON IN CHARGE XW DEPUTIZE 1.1 CERT. MAIL U 1ST CLASS MAIL U POSTED U OTHER
NOW February 5 2007 I, SHERIFF UNTY, PA, do hereby deputize the sheriff of
York COUNTY to execute t
=eretur; th cording
to law. This deputization being made at the request and risk of the plaintiff.. - 2do .040
SHERIFF OF YO1W UNTY
8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITINIAI cRF C 0 U N T Y Cumberland
ADVANCE FEE PAID BY ATTY.
Please mail return of service to Cumberland County Sheriff. Thank you.
NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same
without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff
herein for any loss, destruction. or removal of any property before sheriff's sale thereof.
9p TYP E rod ADDRESS of ATTORNEY / ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER 11 DATE FILED
au )? Emilio, Esquire
905 W. Sproul Road, Suite 105, S rin field PA 19064 610-338-0338 21112007
12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDR SS BELOW: (Thi a must be completed d notice is to be mailed).
CUMBERLAND CO SHERIFF
SPACE BELOW FOR USE OF THE SHERIFF - DO NOT MlRt1E 01N TM 1.11E
13. 1 wAnoMAedge receipt of the writ 14. DATE RECEIVED 15. Expiration/Heanng Date
or complaint as i n d i c a t e d above. M J M C G I L L Y C S O 2/7/2007 3/2/2007
16. HOW SERVED: PERSONAL ( ) RESIDENCE ( ) POSTED( ) POE( ) SHERIFF'S OFFICE ( ) OTHER( ) SEE REMARKS BELOW
17. hereby certify and return a NOT FOUND because I am unable to locate the individual, company, etc. named above. (See remarks below.)
18. NAME AND TITLE OF INDIVIDUAL SERVED/ LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 19. Date of Service 120 Time of Service
21. ATTEMPTSI 4na6 I Time IM M d?l -As I 1 nt I Date I Time I Miles I Int. jDatelTimelMilles; Int. Date Time Miles Int. Date Time Miles Int
22.
EVA SMITH CURRENT RESIDENT HAS LIVED AT ADDRESS SINCE 2002.
SHE DOES NOT KNOW OF A KEVIN MYERS.
23. Advance Costs 24. Service Costs 2 _ N(F 26. M07e, 27. Postage 28. Sub T 1 29. Pound 30 Notary 31. Surchg. 32. Tot. as 33 f>ue or d
$75.00
1 q.
'?' Illy (XJ 1 J 5
34. Foreign County Costs 35. Advance Costs 36 Service Costs 37. Notary Cert. 38. Mileage/Postage/Not Found 39. Total Costs 40. Costs Due or Refund
41. AFFIRMED and subscribed to b
42. day of F E B .20Q-7-43
.
so
41. Signature of 45. DATE
Dep. Sheriff r
46. Signature of York / 47 DATE
County Sheriff
FOR:WILLT M HOSE.SHERIFF 2/27/07
48. Signature of Foreign 49 DATE
County Sheriff
SHERIFF'S RETURN - NOT FOUND
CASE, NO: 2006-05932 P
,COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ERIE INSURANCE GROUP
VS
MYERS KEVIN 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
MYERS KEVIN but was
unable to locate Him in his bailiwick.
COMPLAINT & NOTICE ,
He therefore returns the
NOT FOUND , as to
the within named DEFENDANT
MYERS KEVIN
444 SIOUX DRIVE
MECHANICSBURG, PA 17050
PER POST OFFICE, DEFENDANT MOVED AND LEFT NO
FORWARDING ADDRESS.
Sheriff's Costs: So ansW?
Docketing 18.00
Service 19.20
Not Found 5.00 R. Thomas Kline
Surcharge 10.00 Sheriff of Cumberland County
?3o a? .00
??• ? 52.20 PAUL D'EMILIO
05/24/2007
Sworn and Subscribed to before
me this day of ,
A.D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-05932 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ERIE INSURANCE GROUP
VS
MYERS KEVIN ET AL
JACOB H. BAKER JR
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
MYERS KEVIN
the
DEFENDANT , at 1600:00 HOURS, on the 29th day of May 2007
at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE
CARLISLE, PA 17013 by handing to
KEVIN MYERS
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
Affidavit
Surcharge
513010 -7 C), ,,
Sworn and Subscibed to
before me this
of
So Answers:
.00
.00
.00
.00 R. Thomas Kline
.00
.00 00/00/0000
By:
1C
day ep y S eriff
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 : COMMON PLEAS COURT OF
AS SUBROGEE OF SHAWN GOOD AND : CUMBERLAND COUNTY
MICHELLE GOOD
VS.
NO. 06-5932
KEVIN MYERS
AND
CIVIL ACTION
ENTERPRISE RENT-A-CAR
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 Defendant, Kevin Myers, for want of an answer, and
assess Plaintiffs damages in the sum of $6,304.07 in accordance with a Complaint
filed.
ajiL?L)
PAUL F. 'EMILIO, ESQUIRE
ATTORNEY FOR PLAINTIFF
ATTORNEY I.D. #16654
Prothy assesses Plaintiffs damages in the sum of $6,304.07.
/-S/ 1444-. P- Dig y 62g167
'PRO PROTHY
z
64
T
00
VI
T
v
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 SHAWN GOOD AND : CUMBERLAND COUNTY
MICHELLE GOOD
VS.
KEVIN MYERS
AND
: NO. 06-5932
CIVIL ACTION
ENTERPRISE RENT-A-CAR
AFFIDAVIT OF LAST KNOWN MAILING
ADDRESS OF DEFENDANTS 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:
DEFENDANT
PLAINTIFF:
KEVIN MYERS
444 SIOUX DRIVE
MECHANICSBURG, PA 17050
ERIE INSURANCE GROUP
4901 LOUISE DRIVE
MECHANICSBURG, PA
SWORN TO AND SUBSCRIBED
BEFORE ME THIS !al DAY
OF_l4 (`l , 2007 `
"NOTARY PUBLIC
.. al_ SEAL
j?00 No'ary Public t
tgorrer r , ,y
17055
P UL F. D'EMILIO, ESQUIRE
ATTORNEY FOR PLAINTIFF
d ? w.
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 SHAWN GOOD AND : CUMBERLAND COUNTY
MICHELLE GOOD .
VS.
NO. 06-5932
KEVIN MYERS
AND
CIVIL ACTION
ENTERPRISE RENT-A-CAR
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 Defendant, Kevin Myers, is over twenty-one years of age and that he is not
in the military service of the United States or otherwise within the provisions of the
Soldier's and Sailor's Civil Relief Act of 1940 as amended.
UL F. MILIO, ESQUIRE
SWORN TO AND SUBSCRIBED
BEFORE ME THIS 191 DAY
OF 2007
NOTARY PUBLIC
J"
o
?,Cn
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 SHAWN GOOD AND : CUMBERLAND COUNTY
MICHELLE GOOD .
VS. NO. 06-5932
KEVIN MYERS .
AND .
CIVIL ACTION
ENTERPRISE RENT-A-CAR
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 June 26, 2007 to the Defendant 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".
KEVIN MYERS
444 SIOUX DRIVE
MECHANICSBURG, PA 17050
Gai
PAUL F. D'EMILIO, ESQUIRE
ATTORNEY FOR PLAINTIFF
b
O
T
Cow
w
0
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 SHAWN GOOD AND : CUMBERLAND COUNTY
MICHELLE GOOD
4901 LOUISE DRIVE
MECHANICBURG, PA 17055
VS.
NO. 06-5932
KEVIN MYERS
3023 HARVARD AVENUE
CAMP HILL, PA 17011
AND
CIVIL ACTION
ENTERPRISE RENT-A-CAR
3401 HARTZDALE DRIVE
CAMP HILL PA 17011
DATE OF NOTICE: JUNE 25, 2007
TO: KEVIN MYERS
444 SIOUX DRIVE
MECHANICSBURG, PA 17050
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.
Cumberland County Bar Association
32 Bedford Street
Carlisle, PA 17013
717 249-3166
800; 990-9108
UL F. D'E ILIO, ESQUIRE
2006-142 B
R
Its
U.S. POSTAL SERVICE CERT MATE OF WWLING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
POSTMASTER
PROVIDE FOR INSURANCE c +
-
o L?II P
LAW OFFICE N
PAUL F. D'EMIL10
905 WEST SPR-OUL ROAD, SUITE 105
SPRINGFIELD, PENNSYLVANIA 19064
Lnw Morro ui urwnary man aaaressw to: c L W
O mm m
Kevin Myers cam"'' ONtD3b
44 Sioux Drive .
c»^ cox3.
VI`s Z- pr-0(
Mechanicsburg, PA 17050 a r
PS Form 3817, January 2ool
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION- LAW
(Rule of Civil Procedure No. 236)
ERIE INSURANCE GROUP : COMMON PLEAS COURT OF
AS SUBROGEE OF SHAWN GOOD AND : CUMBERLAND COUNTY
MICHELLE GOOD
VS.
NO. 06-5932
KEVIN MYERS
AND
CIVIL ACTION
ENTERPRISE RENT-A-CAR
Notice is given that a judgment in the above captioned matter has been entered
against you on ?uL1 a? , 2007.
Prothonotary
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
PAUL F. D'EMILIO, ESQUIRE
ATTORNEY I.D.# 16654
905 W. SPROUL ROAD, SUITE 105
SPRINGFIELD, PA 19064
(610) 338-0338
ATTORNEY FOR PLAINTIFF
ARBITRATION MATTER
Im, JUL ? 6
?tJt?1?ER SY tViAKGO"
uX??
PENS
ERIE INSURANCE GROUP
AS SUBROGEE OF SHAWN GOOD AND
MICHELLE GOOD
VS.
KEVIN MYERS
AND
ENTERPRISE RENT-A-CAR
COMMON PLEAS COURT QF
CUMBERLAND COUNTY
NO. 06-5932
CIVIL. ACTION
PRAECIPE TO SATISFY THE JUDGMENT AND DISCONTINUE AND END
TO THE PROTHONOTARY, P.C.:
Satisfy the judgment against Kevin Myers in the above-entitled matter upon
payment of your costs only. Kindly mark the above-entitled matter discontinued and
ended.
Paul F. D'Emilio, Esquire
Attorney for Plaintiff