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Home My WebLink About02-3400IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Civil Action - ( X ) Law ( ) Equity JURY TRIAL DEMANDED Livia Nicastro and Salvatore Nicastro, her husband 288 Bradley Cimle New Cumberland, PA 17070 Versus Gail P. Brummett 2001 Red Bank Road, Lot #202 Dover, PA 17315 PRAECIPE FOR WRIT OF SUMMON~ TO THE PROTHONOTARY OF SAID COURT: Please issue writ of summons in the above-captioned action. X Timothy A. Shollenberqer, Esq. Shollenberqer & Januzzi, LLP 1820 Linglestown Road .Harrisburq, PA 17110 (717) 234-3700 Writ of Summons shall be issued and forwarded to ( ) Attorney ( X )Sheriff Supreme Court ID No. 34343 Date: July 11, 2002 WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. Prothonotary ~ (- Deputy G:\WPDATA\DOCS\Pleadings AIIWicastro Livia Writ.wpd LIVIA NICASTRO and : SALVATORE NICASTRO,: her husband, Plaintiffs Vm GAlL P. BRUMMETT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3400 Civil Term JURYTRIALDEMANDED PRAECIPE FOR ENTRY OF APPEARANCF TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Gall P. Brummett, with regard to the above-captioned matter. Respectfully submitted, NEALON & GOVER, P.C. Date: By: Brian N. ZulliJ, Esquire Attorney I.D No. 85948 2411 North Front St. Harrisburg, PA 17110 (717) 232-9900 CERTIFICATE OF SERVICE AND NOW, this 13th day of August, 2002, I hereby certify that I have served the foregoing Praecipe to Enter Appearance on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Timothy A. Shollenberger, Esquire Shollenberger & Januzzi, LLP 1820 Linglestown Rd. Harrisburg, PA 17110 Eileen S. Smith, Secretary LIVIA NICASTRO and : SALVATORE NICASTRO,: her husband, Plaintiffs GAlL P. BRUMMETT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3400 Civil Term JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please issue a Rule upon the Plaintiff to file a Complaint within twenty days or suffer a judgment of non pros. Respectfully submitted, NEALON & GOVER, P.C. (20) Date: By: Bridal' N. Zul .~.Esquire Attorney I.D No. 85948 2411 North Front St. Harrisburg, PA 17110 (717) 232-9900 RULE TO THE PLAINTIFF: A Rule is hereby issued upon you to file a Complaint within twenty (20) days of service of this Rule or suffer a judgment of non pros. DATED: d~/~ /(,, ~2~,z.. ~,,,_tr~,' ~_ ;;~.~.. ~,~. / Prothonotary I ' / CERTIFICATE OF SERVlCF AND NOW, this 13th day of August, 2002, I hereby certify that I have served the foregoing Praecipe for Rule to File Complaint on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Timothy A. Shollenberger, Esquire Shollenberger & Januzzi, LLP 1820 Linglestown Rd. Harrisburg, PA 17110 Eileen S. Smith, Se~ret~ry SHERIFF'S RETURN CASE NO: 2002-03400 P COMMONWEALTH OF pENNSYLVANIA: COUNTY OF CUMBERLAND NICASTRO LIVIA ET AL VS BRUMMETT GAIL P Thomas Kline - OUT OF COUNTY Ro duly sworn according to and inquiry for the within named DEFENDANT BRUMNMETT GAIL P but was unable to locate Her deputized the sheriff of YORK serve the within WRIT OF SUMMONS , Sheriff or Deputy Sheriff who being law, says, that he made a diligent search and , to wit: He therefore Pennsylvania, in his bailiwick. County, to On August 14th , 2002 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing Out of County Surcharge Dep York Co 18.00 9.00 10.00 46.28 .00 83.28 o8/1 /2oo2 Sheriff of Cumberland County SHOLLENBERGER & JANUZZI Sworn and subscribed to before me this ~2~ day A.D. P-rSthonotary OFFICE OF THE SHERIFF 28 EAST MARKET S'E, YORK, PA 1740'1 SERVICE CALL (717) 771-9601 SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN Livia Nicastro & 3. DEFENDANT/S/ Salvatore Nicastro Gall P. Brummett SERVE INSTR ~U~IONS TO 12 DO i~ ANY COPIES. 2. COURT NUMBER (~)~ - ,~'Io/.~ 4. TYPE OF WRiT OR COMPLAINT Writ of S%~mons Civil - Jury Trial 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD, Gall P. Brummett 6. ADDRESS (STREET OR RFD WITH BOX NUMBER, A.a~ ~.~ CITY, BORe, TWR, STATE AND ZIP CODE 2001 Red Bank Road, Lot ~, Dover, PA 17315 AT 7. INDICATE SERVICE: [3 PERSONAL [3 PERSON IN CHARGE ~ "'-~' t ~ MAIL [3 1 ST CLA NOW July 22, 2002 m · ,_:.::::j~_~-?~-~. SSMAIL OPOSTED ~ I, SHERIFF OF '~ COUNTY~ P~, d~...hereby deputize the sheriff of · Y~rk COUNTY to execute-J~_ make return t~ccording to law. This deputation being made at the request and risk of the plaintiff. 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDmNG SERVICE: OUT OF COUNTY CUMBERLAND C~mb~rland ADVANCED FEE PAID BY ATTY. NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF~ATC~(~~- Any Ge~uty~sheriff Iqvyjng upon or attaching any prope~ unde within writ may leave same without a watchman, in cust~y of whomever is found in possessio~ ~e ~of'~r a t~nt witheut liability on the par of such depu~ or the sheriff to any plaintiff herein for any loss, destruction, or removal of any pmpe.y befor;/~~/~/~ ' ~ /. , 9. ~PE NAME AND ADDRESS of A~ORNEY/ORIGINATOR and SIG RE v ~ ~ ' ' ' ' EPHONE NUMBER 1 I. DATE FILED EU. Sox 60540 CUMBERLAND CO. SHERIFF HarrJs~,m pa SPACE BELOW FOR USE OF THE~H~IFF ~O NOT WRITE BELOW THIS LINE 13. I acknowledge receipt of the writ SIGNATURE OF AUTHORIZED CLERK or complaint as indicated above. R. AHRENS 16. ROWSERVED: PERSONAL(~),~,~ RESIDENCE(a~"-- POSTED( ) POE( ) SHERIFF'S OFF ( ) OTHER ( ) SEE REMARKS 17. O I hereby certify and return a NOT POUND because I am unable to locate the individual, company, corporation, etc, named above. (See remarks below.) 18. NAME,~,¥DTITLE OFIND~/IDUALSERVEDI LISTAODRESS HERE iF NOT SHOWN ABOVE (Relationship to Defendant)~= %~f~L ~, ~Z?7~ 7;/~.~_~1, 19. D teofSe ice 20. Time of Service 22. REMARKS21'A'~Ja'~"fb~ -Da're I Tirn'eJ Milesl'--I( l [ I lint'IDateITime MlleSl Int. IDate Timel Milesjl I I I I I lint' Date I Timel I Miles! Iht Date I TimelUiles [ [Int Date I !Time M,esint 12 . SO ANSWER 41.AFFIRMED and subscribed to be~re me ,his 44. Signature o,~~/~Deo. Sheriff ~ o ~p45. Signature of York 42.dayof AUGUST :,~ ~fl0 Coun~,,She,ff 4s~'~~ iNILLIANI H. HOSE / (~ .... :n:t:~/Nota~ Public 46. Signature of Foreign MY COMMISSION EXPIRES J ~unW Sheriff 50.1 ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RE~RN SIGNATURE OF A~HORIZED ISSUING AUTHORI~ ~O TITLE 4~3ate -' - 51. Date Received 1. WHITE - Issuing Authority 2. PINK - Affomey 3. CANARY - Sheriffs Office 4. BLUE - Sheriff's Office SHOLLENBERGER & JANUZZI, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 Attorneys for Plaintiff LIVIA NICASTRO AND SALVATORE NICASTRO, HER HUSBAND, Plaintiffs GAlL P. BRUMMETT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3400 CIVIL ACTION - LAW JURY TRIAL DEMANDED 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 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 G :\W P DATA/DOCSlPleadings AIl\Nicastro, Livia complainLwpd SHOLLENBERGER & JANUZZl, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 Attorneys for Plaintiff LlVlA NICASTRO AND SALVATORE NICASTRO, HER HUSBAND, Plaintiffs GAlL P. BRUMMETT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3400 CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICIA 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 plazo al partir de la fecha de la demanda y la notiflcacion. 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 tomaro medidas y puede entrar una orden contra usted sin previo aviso o notoficacaion y por cualquier queja o alivio que es pedido en la peticion do demanda, usted puede perder dinero o sus propiededas o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASlSTENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 G:\W P DATA\DOCSIPleadings AIl\Nicastro, Livia complaint.wpd SHOLLENBERGER & JANUZZl, LLP 1820 Linglestown Road P.O. Box 80545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 Attorneys for Plaintiff LIVlA NICASTRO AND SALVATORE NICASTRO, HER HUSBAND, Plaintiffs GAlL P. BRUMMETT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3400 CIVIL ACTION - LAW JURY TRIAL DEMANDED COMPLAINT AND NOW, comes the Plaintiffs, LIVIA AND SALVATORE NICASTRO, by and through their attorneys, SHOLLENBERGER & JANUZZI, LLP, and respectfully represents the following: COUNT I LIVIA NICASTRO V. GAlL P. BRUMMETT 1. Plaintiff, LlVlA NICASTRO, is an adult individual who currently resides at 288 Bradley Circle, York County, Pennsylvania. 2. Plaintiff, SALVATORE NICASTRO, is an adult individual who currently resides at 288 Bradley Circle, York County, Pennsylvania. 3. Plaintiffs, LlVlA AND SALVATORE NICASTRO, are husband and wife, having been married on February 10, 1968. G:\WPDATAIDOCS/Pleadings AIl\Nicastro, Livia complaint.wpd - 1 - 4. Defendant, GAlL P. BRUMMETT, is an adult individual whose last known address is 2001 Red Bank Road, Lot 313, Dover, Pennsylvania. 5. The facts and circumstances hereinafter set forth took place on July 21,2000, at or about 4:30 p.m. on Lisburn Road where it intersects with Forge Road, Lower Allen Township, Cumberland County, Pennsylvania. 6. At the aforesaid time and place, Plaintiff, LlVlA NICASTRO, was the operator of a 1998 Volvo S-70. 7. At the aforesaid time and place, Defendant, was the operator of a 1989 Chevy Ceo-Spectrum. 8. At the aforesaid time and place, Plaintiff, LlVlA NICASTRO, was operating the aforesaid Volvo S-70 traveling on Lisburn Road in Lower Allen Township, Cumberland County, Pennsylvania. 9. At the aforesaid time and place, Defendant, GAlL P. BRUMMETT, was operating the Chevy Ceo-Spectrum traveling on Lisburn Road following the Plaintiff's vehicle. At the aforesaid time and place, Plaintiff slowed down her vehicle to come to a complete stop to make a left hand turn onto Forge Road. The Defendant failed to see the Plaintiff's vehicle was stopped and slammed into the rear of the vehicle occupied by the Plaintiff, LIVlA NICASTRO causing a collision between the two vehicles. 10. The aforesaid collision was the direct and proximate result of the negligence of the Defendant, GAlL P. BRUMMETT in operating the Chevy Ceo-Spectrum in a careless, reckless, manner as follows: a. following another vehicle more closely than was reasonable and G:/WPDATA/DOCS/Pleadings AIl\Nicas[ro, Livia cornplaint.wpd -2- prudent, given the speed of the vehicles and the traffic upon and condition of the highway in violation of [}3310 (a) of The PA Motor Vehicle Code; b. driving at a speed greater than is reasonable and prudent under the conditions and having regard for the actual and potential hazards then existing and at a speed greater than will permit her to have brought her vehicle to a stop within the assured clear distance ahead in violation of Section 3361 of The PA Motor Vehicle Code. c. driving her motor vehicle in careless disregard for the safety of persons or property in violation of Section 3714 of The PA Motor Vehicle Code; d. failing to apply the brakes in time to avoid the collision and; e. permitting or allowing the vehicle to strike and collide with the rear of the vehicle operated by the Plaintiff. 11. As a result of the aforesaid collision, Plaintiff, LIVIA NICASTRO, has suffered serious and permanent injuries, including but not limited to the following: a. cervical strain; b. left cervical radiculopathy; c. thoracic strain; d. lumbar strain; and e. peripheral [lower motor neuron] dysfunction. 12. As a direct and proximate result of the aforesaid injuries, Plaintiff, LIVIA NICASTRO, has undergone and in the future will undergo great pain and suffering for which damages are claimed. G:\WPDATA~DOCSIPleadings AIl\Nicastro, Livia complainLwpd -3- 13. As a further result of the aforesaid injuries, Plaintiff, LIVIA NICASTRO, has sustained a permanent diminution in her ability to enjoy life and life's pleasures for which damages are claimed. 14. As a further result of this collision, Plaintiff, LIVIA NICASTRO, has and/or may incur reasonable and necessary medical and rehabilitative costs and expenses in excess of the amounts paid or payable pursuant to Subchapter B of the Pennsylvania Motor Vehicle Financial Responsibility Law, Workers' Compensation or any program, group contract, or other arrangement for payment of benefits as defined in 75 Pa. C.S.A. Section 1719 or which costs and expenses were paid by a self-funded medical plan governed by ERISA. 15. As a further result of the aforesaid injuries, Plaintiff, LIVIA NICASTRO, has incurred or may hereinafter incur financial expenses and losses which exceed sums recoverable under the limitations and exclusions of the Pennsylvania Motor Vehicle Financial Responsibility Law for which damages are claimed. 16. Plaintiff, SALVATORE NICASTRO, was the named insured on a policy of insurance issued to him by Allstate Indemnity Company bearing policy number 6 18 129587 06/06 which was in effect on the date of the above referenced collision. Plaintiff, LIVIA NICASTRO was a driver listed on the policy. Plaintiff's selected the full tort option regarding that policy. A copy of the declaration page of said policy is attached hereto and incorporated by reference herein as Exhibit 1. Therefore, Plaintiff, LIVIA NICASTRO, remains eligible to claim compensation for non economic loss and economic loss sustained in this collision pursuant to applicable tort law. 17. As a further result of the aforesaid injuries, Plaintiff, LIVIA NICASTRO, has and/or may in the future incur a loss of earning capacity for which damages are claimed. 18. As a further result of the aforesaid injuries, Plaintiff, LIVIA NICASTRO, has suffered and may continue to suffer a loss of earnings for which damages are claimed. WHEREFORE, Plaintiff, LIVIA NICASTRO demands judgment against Defendant, GAlL P. BRUMMETT for compensatory damages in an amount in excess of the amount requiring compulsory arbitration. COUNT II SALVATORE NICASTRO V. GAlL P. BRUMMETT 19. Paragraphs 1 through 18 of Plaintiff's Complaint are incorporated herein by reference and made a part hereof as if set forth in full. 20. As a further result of injuries sustained by his wife, Plaintiff, SALVATORE NICASTRO has been and will be deprived of the assistance, companionship, consortium and society of his wife, all of which has been and will be to her great detriment and loss. G:\WPDATA\DOCS/Pleadings AIl\Nicasb'o, Livia conlplaint.wpd -5- WHEREFORE, Plaintiff, SALVATORE NICASTRO demands judgment against Defendant, GAlL P. BRUMMETT for compensatory damages in an amount in excess of the amount requiring compulsory arbitration. Dated: Respectfully submitted, SHOLLE~ER~G,/~ & JANUZZl, LLP ~'Eorney I.D.//34343 G:\W PDATAIDOCS\Pleadings AIl\Ntcastro, Livia complaint.wpd -6= Ilstate Indemnity Company ( * )Allstate RENEWAL Auto Policy Declarations Summary NAMED INSURED(S) Saivatore A Nicastro 288 Bradley Circle New Cumberland FA 17070-2505 YOUR ALLSTATE AGENT IS C Jeffrey Conant (717) 258-4554 781 E High St Ste 10 Cadisle PA 17013 YOUR BILL win arrive approximately 2 weeks before the policy period begins. POLICY NUMBER 6 18 129587 06/06 POLICY PERIOD June 6, 2000 to Dec 6, 2000 at 12:01 a.m. standard time DRIVER(S) LISTED Eric Livia Salvatore DRIVER(S) EXCLUDED None VEHICLES COVERED 1. 98 Volvo S70 VEHICLEID NUMBER YV1LS5547W2550979 LIENHOLDER Volvo Finance North America lnc 2. 89 Ford Ranger 1FTCR14T8KPB33760 Norwest Financial 3. 97 Volkswagen GTI 3VWDA81H9VM075511 Amedchoice F C U Premium for 98 Volvo S70 $486.30 Premium for 89 Ford Ranger $35260 Premium for 97 Volkswagen GTI . $71080 TOTAL $1,549.70 v/ Your total premium reflects a combiner/r/iscount of $1,250.00 ~/ Yuur tutal premium l'aflecta a ¢ombinarl surcherga of $$7.00 Your Po/icy Effeotiue Oate is June 0, 2000 IN ACCORDANCE WiTH SECTION 1725 OF THE MOTOR VEHICLE FINANCIAL RESPONSIBILITY LAW, THIS IS TO INFORM YOU THAT COLLISION DAMAGE TO A RENTAL VEHICLE WILL BE COVERED IF: / ) THE RENTAL VEHICLE IS A FOUR WH[EL PRIVATE PASSENGER AUTOMOBILE OR A UTILiTY AUTOMOSILE, AN0 2) AT LEAST ONE PREMIUM FOR AUTO COLLISION COVERAGE APPEARS ON YOUR POLICY DECLARATIONS. COVERAGE WILL BE SUBJECT TO DEDUCTIBLES AND 1'o POLICY TERMS AND CONDITIONS, INCLUDING ANY APPLICABLE ENDORSEMENTS. Allstate lade,fruity Company Poticy Number: 6 18 129587 06/'06 Your Agsel; C Jeffrey Conan/ (717) 258-4554 PuJJcy Etfeclive Dele: June 6, 2000 COVERAGE FOR VEHICLE # t 1998 Volvo S70 Automobile LiabiiJly insurance -- Full Tor~ · 8odily Injury $50.000 each person $100,000 each occurrence · Property Damage $50,000 each occurrence Medico/Expenses 510,000 each person Funeral Expenses $2.500 each person Income Loss Each person up to Subject to $5,000 maximum benefit $1,000 monthly maximum Extraordinary Medical Each person up to $1,000 000 maximum benefit Uninsured Motorists insurance S50,000 each person Fuit Tort/Stacked Limits $100,000 each accident Undennsured Motorists insurance $50,000 each person Full Tort/Stacked Limits $100,000 each acc/dent Auto Collision insurance Actual Cash Value Auto Comprehensive insurance Actual Cash Value Total Premium ~'or 98 Volvo S70 DEDUCTIBLE Not Applicable Not Applicable Not Applicable Not Ap¢icabJe Not Applicable Not Applicable Not Applicable Not Applicable $50O $100 PREMIUM $4300 $34.00 $25 00 $0.80 $7.00 $1750 $1700 $17.00 $21200 $113.00 DISCOUNTS Multiple Car Renewal Prior Insurance Your premium for this vehicle redects the following discounts: S8500 $10500 Passive Restraint $165.00 Antilock Brakes $20.80 $31,00 RATING INFORMATION This vehicle is driven a maximum o'¢ 7,500 miles Per year, 3-9 miles to work/school, adult age 29, with no unmarried driver under 25 rstate Indemnity Company AIIstate Number: 6 18 129587 06/06 olicy EflecNve Date: June 6, 2000 YourAgenl: C Jeffrey Conanl (717) 258-4554 COVERAGE FOR VEHICLE # 2 1989 Ford Ranger COVERAGE LIMITS DEDUCTiSLE PREMIUM Automobile Liability Insurance -- Full Tod · 8odity Injury $50,000 each person Not Applicable $47.00 $100,000 each occurrence · Property Damage $50,000 each occurrence Not Applicable $37 O0 Medical Expenses $10,000 each person Not Applicable $35 O0 Funeral Expenses $2,500 each person Not Applicable $1.10 Income Loss Each person up to $5,000 maximum benelit Not Applicable $1000 Subject to $1,000 monthly maximum Extraordinary Medical Each person up 1o $1.000,000 maximum benefit Not Applicable $25 00 Uninsured Motorists Insurance $50,000 each person Not Applicable $19 10 Full Tort / Stacked Limits $100,000 each accident Underinsured MoEorists Insurance $50,000 each person Not Applicable $25 40 Full Tort/Stacked Limits $100,000 each accident Auto Collision insurance Actual Cash Value $500 $10200 Auto Comprehensive insurance Actual Cash Value $100 $51 00 Total Premium for 89 Ford Ranger $352.60 DISCOUNTS Multiple Car Prior insurance Your premium for this vehicle reflects the following discounts: $83.00 Renewat $100.O0 $119.00 RATING INFORMATION This vehicle is driven over 7,500 miles per year, 3-9 miles to work,/school.,_adult age 51, with no unmarried driver under 25 Page 3 Allstate Indemnity Company Policy Number: § 18 129587 05/'06 Policy Effective Date: June 6, 2000 Your Agenl: C Jeffrey Conant (717) 258-4554 COVERAGE FOR VEHICLE # 3 1997 Volkswagen GTI COVERAGE LIMITS DEDUCTIBLE PREMIUM Automobile Liability Insurance -- Fuit Tort · Bodily Injury $50.000 each person Nor Applicable $50.00 $t00,000 each occurrence · Property Damage 550,000 each occurrence Not Applicable $4800 Medical Expenses S10 000 each person Not Applicable $25.00 Funeral Expenses S2,500 each person Not Applicable $0.80 Income Loss Each person up to $5,000 maximum benefit Not Applicable $7.00 Subject to $1,000 monthly maximum Extraordina¢/Medical Each person up to $1 000,000 maxtmum benefit Not Applicable $1750 Uninsured Motorists Insurance $50.000 each person Nor Applicable $t 9.10 Full Tort / Stacked Limits $100,000 each accidenl Underinsured Motorists Insurance $50.000 each person Not Applicable $25.40 Full Tod: / Stacked Limifs Si 00,000 each accident Auto Collision insurance AcIual Cash Value $500 $328.00 Auld Comprehensive insurance Actual Cash Value $100 $19000 Total Premium for 97 Volkswagen GTJ $710.80 DISCOUNTS Your premium for this vehicle reflects the fo0owmg.discounts: Multiple Car S9500 ?assive Restraint $20,80 Renewal $136.00 Antilock Brakes $47.00 Prior insurance $251,00 SURCHARGES Your premium for this vehicle reflects the following surcharges: Accident Involvement S37,00 RATING INFORMATION This vehicle is driven over 7,500 miles per year, 0-3 miles to work/school, adult age 49, with no unmarried driver under 25 VERIFICATION I, ~/'~v,g. ~,~_,,~-w-~ , hereby acknowledge that l am a Plaintiff in this action and that I have read the_ and that the facts stated herein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: SHOLLENBERGER & JANUZZl, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 Attorneys for Plaintiff LIVIA NICASTRO AND SALVATORE NICASTRO, HER HUSBAND, Plaintiffs GAlL P. BRUMMETT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW this 2"~'~' day of .~, 2002, I hereby certify that I have served the following Complaint on the following by fo' ' - rwarding a true and correct copy of same in the United States mail, postage prepaid, addressed to: Gail P. Brummett c/o Brian N. Zulli, Esq. Nealon & Gover, P.C. 2411 North Front Street Harrisburg, PA 17110 Date: Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP