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HomeMy WebLinkAbout06-6793? t Michael E. Kosik, Esquire Attorney ID# : 36513 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: mkosik@angino-rovner.com RUTH BRITTON IN THE COURT OF COMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNA. V. CIVIL ACTION -LAW / ?-)--' NO. 01,, ,- L l JOSEPH J. SOUTNER, Defendant JURY TRIAL DEMANDED 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 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 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 LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA Telephone number- 717- 249-3166 Cumberland County Bar Association 339359 RUTH BRITTON Plaintiff V. JOSEPH J. SOUTNER, Defendant IN THE COURT OF COMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVIL ACTION -LAW NO. : JURY TRIAL DEMANDED NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas sugnuientes, usted tiene viente (20) dias de plazo al 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 en forma escrita sus defensas o sus objeciones a las demandas en contra 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 y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEPFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEQUIR ASISTENCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA Telephone number- 717- 249-3166 339359 % I RUTH BRITTON Plaintiff IN THE COURT OF COMON PLEAS OF CUMBERLAND COUNTY, PENNA. VIL ACTION -LAW V. :CI NO. JOSEPH J. SOUTNER, Defendant JURY TRIAL DEMANDED COMPLAINT 1. Plaintiff Ruth Britton is an adult individual, citizen of the Commonwealth of Pennsylvania who resides at 2101 Cedar Run Drive, Apartment 107, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant Joseph Soutner is an adult individual, citizen of the Commonwealth of Pennsylvania who resides at 2101 Cedar Run Drive, Apartment 104, Camp Hill, Cumberland County, Pennsylvania. 3. The facts and occurrences hereinafter related took place on Tuesday, December 21, 2004, off the Highland Park Exit of US Route 15 South to Simpson Ferry Road. 4. At that time and place, Plaintiff Ruth Britton was operating a 2003 Buick Century which was at a complete stop. 5. At that time and place, Defendant Joseph Soutner was operating his 1995 Chevrolet vehicle directly behind Plaintiff Ruth Britton's vehicle. 6. At that time and place, Defendant Joseph Soutner was traveling too fast and failed to observe Plaintiff Ruth Britton's stopped vehicle. 7. At that time and place, Defendant Joseph Soutner violently and without warning struck the rear of Plaintiff Ruth Britton's car. 8. At that time and place, a violent collision occurred between Defendant Joseph Soutner's vehicle and the rear portion of Plaintiff Ruth Britton's car. 339359 9. The foregoing accident and all of the injuries and damages set forth hereinafter sustained by Plaintiff Ruth Britton is the direct and proximate result of the negligent, careless and reckless manner in which Defendant Joseph Soutner operated his vehicle as follows: (a) failure to have his vehicle under such control as to be able to stop within the assured clear distance ahead; (b) failure to keep alert and maintain a proper watch for the presence of other motor vehicles on the highway; (c) failure to travel at a safe speed; (d) failure to apply his brakes in sufficient time to avoid striking the rear of the Britton vehicle; (e) failure to take reasonable evasive action to avoid the accident; (f) failure to drive his vehicle with due regard for the highway and traffic conditions which were existing and of which he was or should have been aware; (g) failure to keep proper and adequate control over his vehicle; and (h) driving his vehicle upon the highway in a manner endangering persons and property and in a reckless manner with careless disregard to the rights and safety of others and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 10. Plaintiff Ruth Britton sustained painful and severe injuries which include but are not limited to neck pain, whiplash injury resulting in significant aggravation of a pre-existing arthritic condition of her cervical spine resulting in surgery, right hand pain, back pain and various other contusions and shock to her nervous system. 11. By reason of the aforesaid injuries sustained by Plaintiff Ruth Britton, she was forced to incur liability for medical treatment, medications, hospitalizations and similar miscellaneous expenses in an effort to restore herself to health, and claim is made therefor. 339359 12. Because of the nature of her injuries, Plaintiff Ruth Britton has been advised and, therefore, avers that she may be forced to incur similar expenses in the future, and claim is made therefor. 13. As a result of the aforementioned injuries, Plaintiff Ruth Britton has undergone and in the future will undergo great physical and mental suffering, great inconvenience in carrying out her daily activities, loss of life's pleasures and enjoyment, and claim if made therefor. 14. As a result of the aforementioned injuries, Plaintiff Ruth Britton has sustained work loss, loss of opportunity, and impairment of earning power and claims is made therefore. 15. Plaintiff Ruth Britton continues to be plagued by persistent pain and limitations and, therefore, avers that her injuries may be of a permanent nature, causing residual problems for the remainder of her lifetime and claim is made therefor. WHEREFORE, Plaintiff Ruth Britton demands judgement against Defendant Joseph Soutner in an amount in excess of Thirty Five Thousand ($35,000.00) Dollars exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. ANGINO & ROVNER, P.C. 339359 I.D. No. 36513 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Attorney for Plaintiff VERIFICATION I, RUTH BRITTON, do swear and affirm that the facts set forth in the foregoing COMPLAINT are true and correct to the best of my knowledge, information and belief. I understand that this verification is inade subject to the penalties of the Rules of Civil Procedure relating to unworn falsification to authorities. Dated: 1 I/ 3 IC) RUTH B TTON h C 4 x- t? OD Johnson, Duffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com RUTH BRITTON, Plaintiff V. JOSEPH J. SOUTNER, Defendant TO THE PROTHONOTARY: Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 06-6793 CIVIL TERM JURY TRIAL DEMANDED PRAECIPE PLEASE ENTER THE Appearance of the undersigned on behalf of the Defendant, Joseph J. Soutner, in the above-captioned matter. J H SON, DUFFIE, STEWART & WEIDNER f ?160&rson J. Shiprrian, Esquire Attorneys I.D. #: 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com Date: Attorneys for Defendant CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served upon the following, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on C Michael E. Kosik, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 Attorneys for Plaintiff JOHNSON, DUFFIE, STEWART & WEIDNER --1 Je rsbri J: Shipmar/, Esquire I.D #: 51785 P.O. Box 109 Lemoyne, PA 17043 Attorneys for Defendant 288806 Johnson, Duffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com Attorneys for Defendant RUTH BRITTON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW JOSEPH J. SOUTNER, NO. 06-6793 CIVIL TERM Defendant JURY TRIAL DEMANDED NOTICE TO: Michael E. Kosik, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 Attorneys for Plaintiff You are hereby notified to plead to the enclosed New Matter and Cross-Claim within twenty (20) days from the date of service. Date: 1131&-7 JOHNSON, DUFFIE, STEWART & WEIDNER Attorneys I.D. #: 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com Attorneys for Defendant Johnson, Duffle, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com RUTH BRITTON, V. Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA JOSEPH J. SOUTNER, Defendant : CIVIL ACTION - LAW NO. 06-6793 CIVIL TERM JURY TRIAL DEMANDED ANSWER AND NEW MATTER OF DEFENDANT, JOSEPH J. SOUTNER AND NOW, comes the Defendant, Joseph J. Soutner, by and through his counsel, Johnson, Duffie, Stewart & Weidner, and files the following Answer to Plaintiffs Complaint. 1. Admitted upon information and belief. 2. Admitted. 3. Admitted. 4. Admitted upon information and belief. 5. Admitted. 6. Denied. The averments contained in Paragraph 6 are conclusions of law and fact to which no response is required. If a response is deemed to be required, it is specifically denied that Mr. Soutner was traveling too fast and failed to observe Plaintiff Ruth Britton's stopped vehicle. To the contrary, Mr. Soutner was stopped behind the Plaintiff in traffic when his vehicle moved forward a very short distance and bumped the back of the Plaintiff's vehicle. 7. Denied. The averments contained in Paragraph 7 are conclusions of law and fact to which no response is required. If a response is deemed to be required the averments contained therein are specifically denied. To the contrary, Mr. Soutner was stopped behind the Plaintiff in traffic when his vehicle moved forward a very short distance and bumped the back of the Plaintiffs vehicle. 8. Denied. The averments contained in Paragraph 8 are conclusions of law and fact to which no response is required. If a response is deemed to be required the averments contained therein are specifically denied. By further response, after the bump the vehicles were driven to a location safely off the roadway and the vehicles were inspected. There was no indication of any damage to either vehicle. Mr. Soutner made no repairs to his vehicle. There was also no visible damage to the rear of Plaintiff's vehicle. Further, Plaintiff offered no complaints whatsoever of any pain at the scene. Consequently, the Defendant denies that this was in any way a violent collision as described in Plaintiffs Complaint. 9. Denied. The averments contained in Paragraph 9, and subparagraphs (a) through (h) are conclusions of law and fact to which no response is required. If a response is deemed to be required the averments contained in Paragraph 9, and subparagraphs (a) through (h), are specifically denied. (a) Denied. To the contrary, Mr. Soutner did have his vehicle under adequate control; (b) Denied. To the contrary, Mr. Soutner did keep alert and maintain a proper watch for the presence of other motor vehicles on the highway; (c) Denied. To the contrary, Mr. Soutner was stopped behind the Plaintiff when his vehicle moved at a very slow speed and bumped the rear of the Plaintiff's vehicle; (d) Denied. To the contrary, Mr. Soutner was stopped behind the Plaintiff waiting for the Plaintiff to move forward when his vehicle moved a very short distance and bumped the rear of the Plaintiffs vehicle; (e) Denied. To the contrary, Mr. Soutner did take reasonable evasive action to avoid the accident; (f) Denied. To the contrary, Mr. Soutner did operate his vehicle with due regard for the highway and traffic conditions existing; (g) Denied. To the contrary, Mr. Soutner kept proper control over his vehicle; and (h) Denied. To the contrary, Mr. Soutner did not operate his vehicle in a manner endangering persons and property and in a reckless and careless disregard to the rights and safety of others. By further response, it is specifically r denied that Mr. Soutner violated the Motor Vehicle Code of the Commonwealth of Pennsylvania. 10. Denied. After reasonable investigation, Mr. Soutner is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 10, relating to Plaintiffs alleged injuries, and the same are therefore denied and strict proof demanded at the time of trial. 11. Denied. After reasonable investigation, Mr. Soutner is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 11, relating to Plaintiffs alleged medical treatment, and the same are therefore denied and strict proof demanded at the time of trial. 12. Denied. After reasonable investigation, Mr. Soutner is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 12, relating to Plaintiffs alleged expenses, and the same are therefore denied and strict proof demanded at the time of trial. 13. Denied. After reasonable investigation, Mr. Soutner is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 13, relating to Plaintiffs alleged suffering and loss of life's pleasures and enjoyment, and the same are therefore denied and strict proof demanded at the time of trial. 14. Denied. After reasonable investigation, Mr. Soutner is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 14, and the same are therefore denied and strict proof demanded at the time of trial. 15. After reasonable investigation, Mr. Soutner is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 15, and the same are therefore denied and strict proof demanded at the time of trial. WHEREFORE, the Defendant, Joseph J. Soutner, respectfully requests that judgment be entered in his favor and that Plaintiffs Complaint be dismissed with prejudice. NEW MATTER 16. That the Plaintiffs alleged cause of action may be barred in whole or in part by the Pennsylvania Motor Vehicle Financial Responsibility Law and the limited tort option. 17. That if it should be found that there was any negligence on the part of Mr. Soutner, which is denied, then in that event any such negligence was not a substantial factor nor factual cause of the Plaintiffs alleged harm. 18. That the Plaintiffs injuries as alleged may have been pre-existing. 19. That the Plaintiff may have failed to mitigate her damages. 20. That the Plaintiffs alleged cause of action may have been caused in whole or in part by third parties or entities not presently involved in this action. WHEREFORE, the Defendant, Joseph J. Soutner, respectfully requests that judgment be entered in his favor and that Plaintiffs Complaint be dismissed with prejudice. JOHNSON, DUFFIE, STEWART & WEIDNER #ffbris6n J. Shipmfin, Esquire ttorneys I.D. #: 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 /1A e-mail: jjs@jdsw.com Date: ?/ '? Attorneys for Defendant VERIFICATION 1, Joseph J. Soutner, have read the foregoing Answer and New Matter and hereby affirm that it is true and correct to the best of my personal knowledge, or information and belief. This Verification and statement is made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities; I verify that all the statements made in the foregoing are true and correct and that false statements may subject me to the penalties of 18 Pa. C.S. §4904. Jo ph J. S(dutne-r DATE: ?? ?? Q (p 289172 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served upon the following, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on / 3 0 Michael E. Kosik, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 Attorneys for Plaintiff JOHNSON, DUFFIE, STEWART & WEIDNER B . 4a4(./ Shipma , Esquire Je k51789:5 I. P.O. Box 109 Lemoyne, PA 17043 Attorneys for Defendant 289167 r, , L fir. rn m F a ANGINO & ROVNER, P.C. Michael E. Kosik, Esquire Attorney ID# : 36513 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: mkosik@angino-rovner.com RUTH BRITTON Plaintiff V. JOSEPH J. SOUTNER, Defendant IN THE COURT OF COMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVIL ACTION -LAW NO. 06-6793 JURY TRIAL DEMANDED PLAINTIFF'S REPLY TO DEFENDANT'S NEW MATTER AND NOW comes the Plaintiff Ruth Britton, by and through her attorneys, Angino & Rovner, P.C., and hereby replies to the New Matter of Defendant as follows: 16. Denied. This averment is a conclusion of law to which no responsive pleading is required. It is specifically denied that Plaintiff Ruth Britton was covered by the limited tort option on her automobile insurance policy. To the contrary, it is averred that at all times, Plaintiff Ruth Britton had a policy which provided for full tort coverage under the Pennsylvania Motor Vehicle Financial Responsibility Law. See attached declaration page. 17. Denied. This averment is a conclusion of law to which no responsive pleading is required. To the extent that a response my be deemed proper, it is averred that that at all times, Plaintiff Ruth Britton had a policy which provided for full tort coverage under the Pennsylvania Motor Vehicle Financial Responsibility Law. 18. Denied. This averment is a conclusion of law to which no responsive pleading is required. To the extent that a response my be deemed proper, it is averred that that the negligence of the Defendant Joseph Soutner was a direct, substantial, and factual cause of Plaintiffs injuries 345156 and damage. It is specifically denied that the negligence of the Defendant as set forth in Plaintiff's Complaint was not the sole, direct, and factual cause of Plaintiff's injuries and harm. 18. Denied. This averment is a conclusory allegation unsupported by any factual statements and therefore no further response is required. To the extent that a response may be deemed proper, it is specifically denied that Plaintiff's injuries were as a result of a pre-existing condition. Plaintiff s injuries were a direct result of the negligence of the Defendant. Furthermore, Plaintiff maintains that Pennsylvania law permits a Plaintiff to recover to the extent that a pre- existing condition is aggravated, exacerbated, or made worse as a result of the Defendant's conduct, for which Plaintiff may fully recover. 19. Denied. This averment is a mixed conclusion of fact and law to which no responsive pleading is required. To the extent that a response may be deemed proper, it is specifically denied that Plaintiff Ruth Britton failed to mitigate her damages. To the contrary, at all times, Plaintiff Ruth Britton followed the advice of her treating physicians, and in every way attempted to minimize her damages and injury. 20. Denied. This averment is a conclusory statement unsupported by any factual allegations and therefore it is denied. To the extent that a further response may be deemed proper, it is specifically denied that the accident alleged in Plaintiff's Complaint or Plaintiffs injuries were caused in whole or in part by the conduct of at unidentified third party or entity. To the contrary, it is averred that the accident resulting in Plaintiffs injuries was directly caused by the negligence of Defendant striking the rear of her vehicle as set forth in Plaintiff's Complaint. WHEREFORE, Plaintiff respectfully requests that this Honorable Court dismiss 345156 Defendant's New Matter enter judgment in favor of Plaintiff and against Defendant. & ROVNER, P.C. Michael E. Kosik, Esquire I.D. 36513 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Attorneys for Plaintiff 345156 VERIFICATION I, RUTH BRITTON, do hereby swear and affirm that the facts set forth in the foregoing Reply to New Matter is true and correct to the best of our knowledge, information and belief. I understand that this verification is made subject to the penalties of the Rules of Civil Procedure relating to unsworn falsification to authorities. R H RITTON Dated: 1 `l 4) 7 I1I.VVI.VVVV 11 iV?c.vv• i.iv.auv a•• a•• a•??r r. r..- -????? ?.-.-?..---- ----- 120 0372504 PENN NATIONAL INSURANCE RENEWAL DECLARATION DECLARATIONS RENEWAL OF POLICY 120 0372504 PREFERRED ADVANTAGE AUTO POLICY POLICY NUMBER FROM OLICY PERIODTO COVERAGE IS PROVIDED IN THE AGENCY P 120 0372504 1 07/09/04 1 01/09/05 PA NATIONAL MUTUAL CAS INS CO 1 12110411 00 NAMED INSURED AND ADDRESS AGENT BRITTON RUTH LOOKER WOLFE GEPHART Y APT 107 P 0 BOX 4220 2101 CEDAR RUN DR HARRISBURG PA 17111 CAMP HILL PA 17011 EHICLES COVERED iNIT ST TER YR MAKE-DESCRIPTION SERIAL NUMBER SYM CLASS LIMIT CHG DATE '01 PA 007 03 BUIK CENTURY CU 2G4WS52J931223049 08 880110 07/09/04 NSURANCE IS PROVIDED WHERE A PREMIUM IS SHOWN FOR THE COVERAGE .EFER TO ENCLOSED FORM 70-2738 FOR INFORMATION CONCERNING COVERAGE FOR ,AMAGE TO RENTAL VEHICLES. :OVERAGE LIMITS OF LIABILITY PREMIUMS FULL TORT OPTION APPLIES UNIT 1 :ODILY INJURY $250,000 EACH PER SON $500,0 00 EACH ,CCIDENT 60.00 'ROPERTY DAMAGE $100,000 PER ACCIDENT 59.00 ININSURED MOTORIST :OVERAGE BODILY INJURY $ 15,000 EACH PERSON $ 30,000 EACH ACCIDENT STACKING R EJECTED 8.00 INDERINSURED MOTORIST :OVERAGE BODILY INJURY $ 15,000 EACH PERSON $ 30,000 EACH ACCIDENT STACKING R EJECTED 5.00 )THER THAN COLLISION $100 DEDUC TIBLE 27.00 :OLLISION $500 DEDUCTIBLE 93.00 IRST PARTY BENEFITS 60.00 MEDICAL EXPENSE BENEFIT UP T O $100,000 INCL WORK LOSS BENEFIT UP TO $5,000 SUBJECT TO A MAXIMUM OF $1,000 PER MONTH INCL FUNERAL EXPENSE BENEFIT UP TO $2,500 INCL ACCIDENTAL DEATH BENEFIT $5,000 INCL 120 0372504 PENN NATIONAL INSURANCE RENEWAL DECLARATION DECLARATIONS RENEWAL OF POLICY 120 0372504 PREFERRED ADVANTAGE AUTO POLICY POLICY NUMBER FROM OLICY PERIOD TO COVERAGE IS PROVIDED IN THE AGENCY P 120 0372504 07/09/04 1 01/09/05 PA NATIONAL MUTUAL CAS INS CO 1211041 00 NAMED INSURED AND ADDRESS AGENT BRITTON RUTH LOOKER WOLFE GEPHART Y APT 107 P 0 BOX 4220 2101 CEDAR RUN DR HARRISBURG PA 17111 CAMP HILL PA 17011 TOTAL BY UNIT 312.00 TOTAL TERM PREMIUM $312.00 HIS POLICY DOES NOT PROVIDE FIRST PARTY ENEFITS COVERAGE FOR: EXTRAORDINARY MEDICAL EXPENSE COVERAGE .NTI-LOCK BRAKING DISCOUNT APPLIES TO UNIT(S) 1 5% ANTI-THEFT DISCOUNT APPLIES TO UNIT(S) 1 ,UAL PASSIVE RESTRAINT CREDIT APPLIES TO UNIT(S) 1 IATURE DRIVER DISCOUNT APPLIES TO UNIT(S) 1 .AFE DRIVER DISCOUNT APPLIES 10% CREDIT APPLIES SINCE YOU HAVE AN ACTIVE HOMEOWNERS POLICY WITH OUR COMPANY DRIVER ID DRIVER NAME 01 RUTH BRITTON ,PPLICABLE FORMS LICENSE NUMBER BIRTH DATE 09055321 06/20/37 ORM # DATE UNIT FORM # DATE UNIT FORM # DATE UNIT FORM # DATE UNIT '0-30540204 * ALL 70-31390498 ALL PP00010698 ALL 70-30480699 ALL '0-448 01/99 ALL IL09100702 ALL 70-1672 ALL ACORD50 * ALL '0-16861085 ALL 70-26590790 ALL PP03381298 ALL 70-27380699 ALL '0-1512 ALL 70-31690199 ALL 70-32080799 ALL PP13011299 ALL '0-32820601 ALL 70-32890402 ALL 70-26580790 001 PP03050886 001 '0-31280802 001 70-31300802 001 PP05510694 001 120 0372504 PENN NATIONAL INSURANCE DECLARATIONS RENEWAL OF POLICY 120 0372504 RENEWAL DECLARATION PREFERRED ADVANTAGE AUTO POLICY POLICY NUMBER FROM OLICY PERIODTO COVERAGE IS PROVIDED IN THE AGENCY P 120 0372504 07/09/04 1 01/09/05 PA NATIONAL MUTUAL CAS INS CO 1 1211041 00 NAMED INSURED AND ADDRESS AGENT BRITTON RUTH LOOKER WOLFE GEPHART Y APT 107 P 0 BOX 4220 2101 CEDAR RUN DR HARRISBURG PA 17111 CAMP HILL PA 17011 LOSS PAYEE FOR UNIT #001 GMAC PO BOX 2525 HUDSON OH 44236 ANTI FRAUD NOTICE NY PERSON WHO KNOWINGLY AND WITH INTENT TO DEFRAUD ANY INSURANCE COMPANY OR ITHER PERSON FILES AN APPLICATION FOR INSURANCE OR STATEMENT OF CLAIM :ONTAINING ANY MATERIALLY FALSE INFORMATION OR CONCEALS FOR THE PURPOSE OF IISLEADING, INFORMATION CONCERNING ANY FACT MATERIAL THERETO COMMITS A RAUDULENT INSURANCE ACT, WHICH IS A CRIME AND SUBJECTS SUCH PERSON TO CRIMINAL .ND CIVIL PENALTIES. 05/26/04 PROCESS DATE CERTIFICATE OF SERVICE AND NOW, this 12?' day of January, 2007 I, Michelle M. Milojevich, an employee of Angino & Rovner, P.C., do hereby certify that I have served a true and correct copy of the PLAINTIFF'S REPLY TO DEFENDANT'S NEW MATTER in the United States mail, postage prepaid at Harrisburg, Pennsylvania, addressed as follows: Jefferson J. Shipman, Esquire Johnson, Duffie, Stewart & Weidner 301 Market Street P.O. Box 109 Lemoyne, PA 17043 Michelle M. Milo?evl ,h 345156 c ? ? `_ .?..? ,.,.,' ?. ? ?i? ?: ?, .,z?, ?? ?„3 fJ.?t ?"?1 ..-r- ?? /„ .l ,_p =_. r? T ?? . ;? . K JF? \ v+ .?w ? { ? -^+. SHERIFF'S RETURN - REGULAR CASE NO: 2006-06793 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BRITTON RUTH VS SOUTNER JOSEPH J GERALD N WORTHINGTON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SOUTNER JOSEPH J DEFENDANT at 2101 CEDAR RUN DRTVF.. the , at 1840:00 HOURS, on the 5th day of December-, 2006 T T M TTTRT -_ 1- n CAMP HILL, PA 17011 JOSEPH J SOUTNER by handing to 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 18.00 13.20 Postage .39 P Surcharge 10.00 R. Thomas Kline .00 ///q?o? ? 41.59 00/00/0000 Sworn and Subscibed to By: ?? Z4 ? ?_& before me this day 2 261 Deputy S iff of A.D. ANGINO & ROVNER, P.C. Michael E. Kosik, Esquire Attorney ID# : 36513 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: mkosik@angino-rovner.com RUTH BRITTON Plaintiff V. JOSEPH J. SOUTNER, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVIL ACTION -LAW NO. 06-6793 : JURY TRIAL DEMANDED PRAECIPE Please mark the above-captioned action as settled, satisfied, and discontinued. AN R, P.C. Ichael E. Kosik, Esquire I.D. No. 36513 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiff DATED: 10/3/07 cc: Jefferson J. Shipman, Esquire 345156 ?..._ ....3 _.?7 ..,.-,! ??? •? V??'i'i {{ ?. 1 '. 1 s ,.., lJ _.? i.. ?'?? 1\? ?~? ? "'(?