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HomeMy WebLinkAbout94-05481 ~ II a.. a' ..t:. )- . \I) 7 . <J . ~ v '- <.. UJ I~ J -- I ::t- o- . / ERIE INSURANCE COMPANY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA I L v.. C :,} T-...zA.J.,.~ NO. q, - 54-0 J ~ v. JAYME THARP, Defendant CIVIL ACTION - LAW NOT I C B 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 Plaintiffs. 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. Court Administrator Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6100 NOTIc....LA LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 par abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas 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 0 notificacion y par cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL . ERIE INSURANCE COMPANY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. NO. JAYME THARP, Defendant CIVIL ACTION - LAW COMPLAINT AND NOW comes Plaintiff, Erie Insurance Company, by and through its attorneys, METTE, EVANS & WOODSIDE, P.C., and in bringing this action before this Court, avers as follows: 1. Plaintiff, Erie Insurance Company, Inc~ is a Pennsylvania corporation with offices located at 4901 Louise Drive, Mechanicsburg, Pennsylvania. 2. Defendant, Jayroe Tharp, is an adult individual who currently resides at 386 pitt Road, Kingsport, Tennessee 37660. 3. Defendant purchased an automobile insurance policy from Plaintiff which covered a 1985 Renault Alliance, vehicle identification number 1XMAC9761FK144207. 4. The policy of insurance purchased by Defendant prohibited an assignment of the insurance without the written consent of the Plaintiff. A copy of the automobile insurance policy purchased by Plaintiff is attached hereto as Exhibit "A." 5. Upon information and belief, Defendant entered into a contract for the sale of the above-referenced insured vehicle and agreed to assign his insurance coverage to the purchaser, said assignment being given without knowledge or consent of the Plaintiff. 6. On October 17, 1992, the purchaser of the automobile was involved in a collision causing a total loss to the insured vehicle. 7. Defendant's unauthorized assignment of his insurance constituted a violation of Exhibit "A" which constituted grounds for a denial of coverage by Plaintiff for the loss incurred. 8. Nonetheless, under the loss payable clause of Exhibit "A," Plaintiff was required to pay the lien holder the losses it incurred in connection with the accident. 9. Pursuant to the terms of Exhibit "A," Plaintiff paid the Citizens Bank, Elizabethton, Tennessee 37644, One Thousand Seven Hundred Seventy-Eight Dollars and Twenty-Four ($l,778.24) Cents. 10. Also pursuant to the terms of Exhibit A, Plaintiff paid Five Hundred Twenty-Four ($524.00) Dollars in costs attempting to resell the insured automobile for salvage value. 11. Under the terms of the loss payable clause of Exhibit "A," Plaintiff is entitled to recover the amounts paid a lien holder for a loss for which the named insured is not insured. 12. Because of Defendant's unauthorized assignment of insurance, Defendant was not insured for the subject loss. 13. Plaintiff is entitled to recover the amount of Two Thousand Three Hundred Two Dollars and Twenty-Four ($2,302.24) Cents from the Defendant. WHEREFORE, Plaintiff Erie Insurance Company, Inc. demands judgment in its favor and against Defendant in the amount of Two Thousand Three Hundred Two Dollars and Twenty-Four ($2,302.24) plus interest and cost of suit, this amount being less than the arbitration limit and requiring submission of this action to mandatory arbitration. By: strowski, Esquire . D. #66420 DATE: q/~3!~1 WP+ 75~' 3401 North Front Streat P. O. Box 5950 Harrisburg, PA 17110-0950 (717) 232-5000 Attorneys for Plaintiff Erie Insurance Company, Inc. VER I F.lCA1'lilli I, DAN PERON, Claims Adjuster, Erie Insurance Group, have read the foregoing document and verify that the facts set forth therein are true and correct to the best of my knowledge, information and belief. To the extent that the foregoing document and/or its language is that of counsel, I have relied upon counsel in making this Verification. I understand that any false statements made herein are subject to the penalties of 18 Pa. C.S.A. S4904, relating to unsworn falsification to authorities. DATE: q N t/'t ~ Jh111 ~) { 'a~\MwrJ4.~'~ DAN PERON Claims Adjuster Erie Insurance Group Exhibit A .--.f__ _ I , , , ' ~.....-- - . . - . _.; ....,., ".~ "", ,... , ~~: t-..... . ."',, . " " . ~ . <-' ' Liability Protection .,.,.,...,.""",...,.,.6 Physical Damsge Coverages . , ' , , . . ' , . , . . , . ' . ,8 ...."..."".,."".3 ,....9 ...,...""".,..",.""',,... ,5 Owned Autos We Insure,. ...".,.",..,.",5 Autos and Trailers ' ' , , . , . . . . , , . , , , . ,5 MisceUaneous Vehicles. . , . , . , . ' , ' . , , , . . , , , . I) Non.Owned Autos We Insure, . . ' . . . . ' , , , , , . , . I) Bodily Injury Liability . . . . , , , . . . , ' , ' , . . , .6 Collision . ,. .."".".,..,.".",."...,.,,7 Comprehensive ...,.",.,..,..,."."".,.,7 Property Damage Liability . , . . ' . . . , . , . , , , , . ' .6 Reimbursement For Coverage In Mexico and Other Foreign Countries .",..,.,.",., .10 Road Service, . ' . . . . . ' , ' . , , . , . . . 10 Transportation Expenses (Collision) , . . . . . . .. 10 Transportation Expenses (Comprehensive) , . , ' , 10 ,....",.,...,..,..".,..,...,.,., ,3 .......".". ,6 Liebility Protection ' ' . , , . . . , . . .7 Physical Damage Coverages . , ' , . . . , . ' , ,8 .,...,..."..."."..,'" ,9 f ~ ,',. :"t',,\ j t~\J II- \. - "... "'.... ~ './:' '1":, t -liP,. , ... . . . ..... ., ..., ,.,. .. ,.9 .r nv. Uability Protection ...""".,.".,,'" . , . . . 7 Physical Damage Coverages ' , , . , . ' ' . , ' . ' . ' , , ,9 '~, .'...., ., Liability Protection . ,6 .' ."..,.., ... ....... :,; r>': '^ ~'_ Physical Damage Coverages. . . . . ' , , . , , . ' , . , . . 9 Ri9t,t:. aile; O\.Jtte:.- . Cinnern\ POil:;\' ,. ~:'~lctl\lnno::_ . . . .10 Accounting IE;cchang.) "..,."""...",.,.12 Assignment, , , . ' , , ' . . , , . . , . . ' . , , , , . ' , . , , . ,10 Bankruptcy of Anyone We Protect. . ' , , . , . , . .10 Cancellation, . , . , . , . , . ' , ' . . . , , . . , , , , , . , , ' , ,10 Concealment, Fraud or Misrepresentation ",., 11 Continuous Policy, . . . , . , ' ' . , . . , . . . ' , . ' 11 Cooperation ' . , . ' . . . . , . , ' . . , , . ' 11 How Your Policy May Be Changed, . . . . , ' . , , ,11 Lawsuits Against Us, ' . ' . ' . . . . , ' . , , . , , . ' , ' . 12 No Contingent Liability IExchang.), , ' , , . ' . ' . ,12 Our Right To Recover From Others ,.... . . ' . ,12 Priority . , . , , ' , , . . , , , . . . ' , . , , ' , , , . . . , . . , 12 ", ..~ i-;- ;.::.;.:;; T"n' "",.,.'",.,..,.. ..'"". .12 I ~ . ~'.-~_ . r::, .:~~~ :""', Liability Protection .., , . , , , . , . , , , . ' . . , . , . , , .6 Physical Damage Coverages. ".,.',..".'" . ,8 ..........,,4 ERIE . ERIE INSURANCE GROUP Mcmtier~. Elle Ins,jtance E 'chill1gl-~. tIle In<;urance Company Home OIt.Ct>. 100 ~".~ IW,llfc!nCf: F'LKe. tlll~ PA 1i)~,IIJ' (81"1 870.2000 .2, ERIE INSURANCE GROUP Is proud to pr..antthls PIONEER FAMILY AUTO INSURANCE POLICY. This Important contract batwaan YOU and tha ERIE' consists of this policy with covaraga agraamants, IImltallons, axcluslons and condlllons, a Daclsrallons, plus any andorsamants, It Is wrlttan In plain, slmpla tarms so that It can be asally undarstood. Wa urga YOU to read It. This Policy contslns many XTRA PROTECTION FEATURES davalopad by tha ERIE' . Wharavar an "X" appaars In tha margin of this policy, YOU racelva XTRA PROTECTION, althar as addlllonal cover. aga or .. a covarage that Is not In most auto policies. Tha protacllon glvan by this policy Is In kaaplng with tha slngla purposa 01 our Foundars: "To pro- vida YOU with.. naar PERFECT PROTECTION, IS naar PERFECT SERVICE, IS Is humanly posslbla. and to do so attha LOWEST POSSIBLE COST," i .~. r ~"'lH I t\. I # ... , I r"'; l":" ~.- {.,', a':~ r=f....... ...~ll-j......,.~,,~"".:I... ~ !,=,Pf~ It'S'J~ll\'~~L: E~::."':t~!\'::~t. In return for your timely premium payment, your com' pliance with all of the provisions of this policy, and your signing of a Subscriber's Agreement with Erie Indem, nity Company and other Subscribers, we agree to pro- vide the coverages you have purchased, Your coverages and limits of protection are shown on the Declarations, which are part of this policy. Your signing the Subscriber's Agreement, which in' cludes a limited power.of.attorney, permits Erie Indem, nity Company, 89 Attorney.in'Fact, to make reciprocal insurance contracts between you and other Subscribers and otherwise manage the business of the Erie Insur' ance Exchange. This power.of,attorney applies only to your insurance business at the Exchange and is limit, ed to the purposes described in the Subscriber's Agreement, Your responsibility as a Subscriber is determined by this policy and the Subscriber's Agreement. You are lia' ble for just the policy premiums charged and are not subject to any other premium liability under the policy. Throughout your policy and its endorsement {arms, the {allowing words have a special meaning when they ap' pear in bold type: . "Amended Declarations": see definition of "Decla, ratioos. to . "anyone we protect" means any person or organiza, tion we specifically state is protected under the cover' age being described. In the RIGHTS AND DUTIES , GENERAL POLICY CONDITIONS Section, "any. one we protect" means: III you and This agreement is made in reliance on the information you have given us and is subject to all the terms of this policy, This policy, all endorsements to it, and the Subscriber's Agreement constitute the entire agreement between you and us. ~-:-1~' H"~~,!:~-:."~p. ~:.:'., ~:.::" In return for your timely premium payment and your compliance with all of the provisions of this policy, we agree to provide the coversges you have purchased, Your coverages and limits of protection are shown on the Declarations, which are port of this policy, This agreement is made in reliance on the information you have given us and is subject to all the terms of this policy, This policy and all endorsements to it constitute the en. tire aweement between you and us. (21 persons or organizations listed under OTHERS WE PHOTECT in the LIABILITY PROTECTION Section, . Houto" t "automobile" or "car" means any two to six wheel land motor vehicle or trailer except: 111 a vehicle designed for use principally off public roads, while not on public roads: or 121 a vehicle operated on rails or crawler treads; or (31 a vehicle located for use as a residence: or 14) a miscellaneous vehicle. . "auto buslne.s" means the husiness of selling, repair. .3, ing, servicing, clel1lling. pllinting. storulg or parking au' tomobiles or miscellaneoua vehicles. . "autos we iosure" means any vehicle descriht..~ in the AUTOS WE INSURE Section of this policy, . "Continuation Notice": see definition of "Decla' rations ,. . "Declaratloos"," Amended Declarations", "Revh;ed Declarations", "Reinstatemeot of Coverage" or "Coo' tiouatloo Notice" means the form which shows your coverages, limits of protection, autos we insure, premi. um charges and other information. This form is part of your policy, An Ameoded Declaratloos shows you the policy has been changed, A Revised Declarationa shows you the policy has been corrected, A Reinstatement of Cover' age shows you the previously cancelled policy and coverages are back in force. A Continuation Notice sbows you the policy is being continued for another polio cy period. . "miscellaneous vehicle" means a motorcycle, moped, snowmobile, golfmobile. all terrain vehicle and any simi' lar recreational vehicle. . "Doo-owned auto we insure" or "Don-owned auto" means any vehicle described in the NON.OWNED AU, TOS WE INSURE Section of this policy, . "occupying" means in or upon, getting into or get. ting out of. . "owned auto we iosure" or "owned auto" means any vehicle described in tbe OWNED AUTOS WE IN, SURE Section of this policy. . "private pasaenger auto" means a four wheel land motor vehicle designed mainly to transport people on public roads, It includes station wagons and the follow, ing types of vehicles, even with dual rear wheels, when not used for business purposes, except farming or ranching: (1) motor homes (2) pickups 13) vans. . "Reinstatement of Coverage": see definition IIf "Declarations.' . . "relative" means a resident of your household who is: II) a person related to you by blood. marriage or adop' This policy applies to accidents or losses that happen during the policy period in the United States of Ameri. co, its territories and possessions. Puerto Hieo. Cana. do or bet ween their ports. The policy period is shown tion. or 121 a ward or any other person under 21 years old in your care. . "Revised ()eclarations": see delinition 01 "[)ecla, ratioDs." . "~ound equipment" includes tape players, compaCL disc players, citizens band radios. two-way mobile ra' dios or telephones, scanners and their accessories. at. tachments and antennas. . "trailer" means a vehicle designed to be pulled by a private passenger auto, if not being used for business purposes except with a private passenger auto. In the LIABILITY PROTECTION Section 01 this policy, trailer includes a farm wagon or a farm implement while used with a private passenger auto. .9 ',:. '. !..',~: :.. The following words have a special meaning in policies issued at Erie Insurance Exchange when they appear in bold type: . "Subacriber" means the personls) wbo aigned tbe Subacriber'a Agreement. . "Subscriber'a Agreement" means the agreement, in. c1uding a limited power,of,attomey. among the Sub, scribers and the Erie I ndemnity Company. as Attorney.in,Facl, . "we", "us" or "our" means the Subscribers at Erie Insurance Exchange as represented by their common Attorney,in,Fact. Erie Indemnity Company, . "you", "your" or "Named Insured" means the Sub, scriber and others named in I tem I on the Declarations. Except in the GENERAL POLICY CONDITIONS See' tion, these words include the spouse of the Subacriber if a resident of the same household, ..., " ..~,,,., " The following words have a special mel1lling in policies issued by Erie Insurance Company when they appear in bold type: . "we", "us" or "our" means the Erie Insurance Company, . "you", "your" or "Named Insured" means the per. sonlsl named in Item 1 on the Declaratlona. Except in the GENERAL POLICY CONDITIONS Section, these word. include your spouse if a resident of the same household, on lhe Declarationa. Amended Declaratlona. Revlaed Declarationa. Reinstatement or Coveralle or Continua- tion Notice. -4- r f L I I t, . " [ i r f t ! , f r I "'f.....,... "'~ ,..-.,-,.. HIo.. J t..;.w Yt ~ i..~.:>~..n 1.":' It'.'....- , , - .: :......,:-'~ ~,':- :, :':")r:~ :... I' ._; f'or the coverages you have purchased. we insure: 10) Owned Autos and Trailers, Any auto IIr trailer described on your Declarations. (b) Replacement Autos and Trailers. Any private passenger auto or trailer you own which replaces an auto or troller described on your Decla, rations, Ic) Additional Auto" and TlOil..rs, Any private pas' senger suto or trailer you acquire. War coverages to apply, we must insure all private passenger autos and trailers yoa own on the date you ac' quire an additional private passenller auto or traUer.) Pravisions applicable only to Replacement and Additional Autos and Trailers: You must notify us during the policy period of your intention to have this policy apply to the replacement or additional private passenger auto or trailer. If a replacement or addition is made within 30 days prior to the end of the poli, cy period, you have 60 days after acquisition to notify us. Id) Temporary Substitute Autos and Trailers. Any auto or trailer which is a substitute for a trailer or an owned auto we Insure. (The owned auto or trailer must be withdrawn from normal use be. cause of its breakdown. destruction, loss. repair or servicing. The temporary substitute cannot be owned by you and must be used with the per' mission of the owner,) Provisions applicable only to troilers: Liability Protection applies to any trailer you own while used with u. private passenger auto we insure for Liability Protection. For the coverages you have purchased, we insure: (al Owned Mi"cellaneous Vehicles, Any miscellan.~ ous vehicle described on your Declarations. Ibl Replacement Miscellaneous Vehicle" . Any mis. cellaneous vehicle which replaces a miscellane, ous vebicle of the same type described nn your Declarations. You must notify us during the policy period of your intention to have this poli, cy apply to the replacement mlscellaneouH ve. hicle. If a replacement is made within 30 duvs prior La the end of tbe policy perilld, you hu~e 60 duys after acquisition to notify us. kl Temporary Sub,o;titute ^,/iscellaneuus 1,.'(.hid('.o; . A substitute for an owned mlscellaneoas vehl. cle of the same type we insure. (The owned mls. cellaneous vehicle must be withdrawn from normal use becuuse of its breakdown, destruc' tion, loss, repair or servicing. The temporary substitute cannot be owned by you and must be used with the permission of the owner,) For Liability Protection, we insure: Additional Miscellaneous Vehicles, Any miscellane- ous vehicle other than a replacement miscellaneous vehicle, which yoa acquire,(For coverage to apply, we must insure all owned miscellaneous vehicles of the same type on the date you acquire an addition. 01 miscellaneous vehicle, We will not automatically cover an additional miscellaneous vehicle when we do not already In sur. a miscellaneous vehicle of the same type owned by you,) You must notify us dur' ing the policy period of your intention to hove this policy apply to the additional miscellaneous vehi. cle, If the addition is mude within 30 days prior to the end of the policy period, you have 60 days after acquisition to notify us, : ,:,,..C.WN!:[1 f.UTO~ WE INSURE We insure for Liability Protection while you are using ~ it, any auto or trailer not owned by you except any auto or trailer furnished or available for your regular use by any governmental agency or unit, Your operation or other use must be with the permission of the owner or you must reasonably believe you have permission. Com' prehensive and Collision coverages, if purchused on owned private passenger autos or trailers, will apply only while you are operating or have possession or cus' tody of 0 private passcnger auto or trailer not furnished or available for the reb'\1lur use of you or a relative, We insure for Liability Protection, while u relative is using it, any private passenger auto or trailer not owned by or furnished or availuble for the reb'\1lar use of you or a relative. The IIptration or other use by a relative must be with the permission of the owner or the relo, tive must reasonably believe permission exists. If a prl, vate passenKer auto or trailer is furnished or available for your reb'111ur use by unyone other than u gO\1crnmen- tal agency or unit, we will insure It under Liability Pro. tection while u relative is using it. Comprehensive and Collision tlJv"rages, if purchused on owned private pas' senller autos or trollers, will up ply only while a relative is opNuting or has possession or custody of a private pasHenKer auto or trailer not owned by or furnished or avuiluble for th., reb'\1ll1r use of you or a relative. A private passenller auto rented to you for a period of mOf(' than :lll consecutive days shull be considered as furnished or uvailable for the fCh'\1lar use of you or a relutive. -!j. , : l ~I~ r,...v ....lo._~..._i. . C' ~'r n ~. ..... l'r:-- . "".)- ; :~ ~., , " ~.I , rJ~')', -." [!~'f'l"(' ~!i~";':" We will pay u1l sums you legally mu~t pa~ as damage~ caused by an accident covered by thIs policy, The accl' dent must urise out of the ownership, maintenance, use, loading or unloading of an auto we Inaure, Damages must involve: (I) bodily injury, meaning physicul hurm, sickness or disease, including cure, loss of services or resultant death; or 121 property damage, meaning damage to tangible property, including loss of its Use. . ....... 'hl- r .. ;.r:-.'''''> We will make the following payments in addition to the limit of protection; however, our payment of the limit of protection for 0 settlement. judgment. or deposit in court ends our duty to pay under Item (I): (I) u1l costs to investigate and defend or settle, as we !:alieve proper, any claim or suit against anyooe we protect for damages covered under this section, (2) uIl interest which accrues on that purt of any judg' ment that does not exceed the limit of protection on a suit we defend, until we offer or deposit in court the limit of protection, (3) uIl reasonable expenses anyone we protect may in. cur at our request to help us investigate or defend a claim or suit. This includes up to $100 a day for actual loss of earnings. (4) uIl premiums on the following types of honds, but not for bond amounts greater than the limit of pro' tection: 101 appeal bond in a suit we defend; Ib) bail bond Iwith premium of $500 or less I required due to an accident or related traffic violation in' volving an auto we insure: Ic) attachment blind to release property of aayone we protect due to un accident or reluted truffic violation involving an 8UtO we insure. We have no duty to apply for or furnish such bonds, 151 all reasonable costs for first aid to other people and animals at the time of an occident involving an autll we iOf;ure, llil u1l reasonable lawyers' fees up to $50 which anyone we protect incurs because of arrest, resulting from on accident involving an auto we insure. 171 prejudgment interest awurded on the amount of the judgment we pay, If we offer to pay the applicable limit of protection, we will not pay any prejudgment interest for the period of time after the oller. We also protect: r',- C~ ...'~~ ,-To j,' '''r. .' I __ ~J t...: III Any relative using un auto we inHure. 121 Any person using or any person or organization Ie. gully responsible for the use of on owned aato we InHure. This use must he with your permission un. less the use is by a resident of your hllusehold. (3) Any person or organization legully responsible for the use, by you or a relative. of any nono()wned auto we insure, This protection applies only if the per. son or organization does not own or hire the vehi. cle being used. ~ ~'i;JT~:-I:'1 IJ'I.. : 7.... - ~ ,.J" When laws of a state where an auto we Insure is being used require higher limits and/or more coverages than shown on the Declurations, your coveragels) will com' ply with tbe minimum requirements of such laws, State includes the District of Columbia. a territory or posses' sion of the United States of America. Puerto Rico or u province of Canada. The insurance under this provision will be reduced by any other collectible insurance under this or any other auto insurance policy, We will not pay any person twice for the same elements of loss. L1f"ii'ATlONS ON OUR DUTY TO PAY \,'r.,' '.\ r 0;; ,~'.'!! Cr.lf\!" . Er~:'.l",:8r;" We do not cover: III damage caused by anyone we protect to property they own or are transporting, 121 damage caused by anyone we protect to property rented to them or in their churge, This exclusion does not apply to house bold goods or premises. 131 uamages caused intentionully by or at the direction of anyone we protect. 14) an owned auto while being used in the auto business. This exclusion does not apply if the owned auto is being used by: 101 you or a resident of your household, or Ib) any partner. ugent.. or employee of you or a resi. dent of your household. 151 an owned auto while heing used in the business of the United States Government where the United States Government is responsible under the Feder' 01 Tort Claims Act '28USCA~13"6, 2671,2680). llil a non.owned auto while used in connection with: 10) the aato business, or Ibl any other business or occupation of anyone we protect. IExclusion 1611b) does nllt apply to a pri. vote passenger auto or trailerl. t7I bodily injury to employees of onyooe we protect 0<:' curring in the rourse of employment. We will pro- vide coverage for such an injury to a domestic emploYL'" not covered and not requinod to be covered hy u workers compensation law. .1 .fj. (8) a vehicle you acquire during the policy period or any temporary substitute for it if there is other ap' plicable insurance. (9) an auto we in.ure while hired by or rented to others for a fee or while available for hire by the public. We will protect you or a relative held responsible for damages while occupying but not driving such a vehicle, if it is a non-owned auto we insure. "Fcc" does not include payment received in a car pool or for trips for non'profit social, educational, or charitable agencies, liD) damages for which there is insurance under a nuclear energy liability insurance policy, even if the limits of protection under that policy have bccn used up. 111) an auto we insure while being used in any pre- arranged or organized racing, speed or demolition contest, stunting activity or similar activities, or in practice for any such activities. , _'I.. ..-' :. _ --;:: :~i :....1' . ,,'. . ,I, ..... \ We will pay no mora than the limit(sl shown on the Declarations for one auto in anyone accident as ex. plained below. It makes no difference how many per, sons we protect, autos we insure, claims are mode or autos are involved in the accident. An auto and attached trailer are considered one auto under this coverage, If coverage is purchased on a "Split Limits" basis, your Declarations will show a per PERSON and per ACCI, DENT limit for Bodily Injury Liability and a per AC- ;"\~"\"~'i"""." f"\o'~r: . -_, .~ .- - ;.". .1',.. Throughout this section, the word "loss" means direct and accidental damage or loss, ,; Hr- We will pay for loss to an auto we insure and its equip' ment not caused by collision or upset, We will pay lor loss less the deductible, if any, shown on the Declara- tions. Comprehensive coverage includes glass breakage, contact with persons, animals, birds, missiles or falling objects. Should only your windshield be damaged. we will not subtract the deductible if you agree to have it repaired rather than replaced. '0_ I ':. ~'l..l;-i We will pay for loss to an auto we Insure and its equip' ment caused by collision or upset. We will pay for loss CIDENT limit for Property Dumage Liability, The per PEHSON limit for Bodily Injury Liability is the most we will pay for damages arising out of bodily injury to one person in anyone accident, The per ACCIDENT limit for Bodily Injury Liability is the most we will pay for damages arising out of bodily injury to all persons resulting from anyone accident, subject to the per PER- SON limit. The per ACCIDENT limit for Property Damage Liability is the most we will pay for all property damage caused by anyone occident. If an individual's damages derive from bodily injury to another person injured in the acciden~ we will pay only for such derivative damages within the per PERSON limit available to the person injured in the accident, If coverage is purchased on a "Single Umit" basis, your Declarations will show a per ACCIDENT limit for Bodi, Iy Injury Liability and Property Damage Liability, Thie is the most we will pay for all damages arising out of bodily injury and property damago caused by anyone occident. OTHER IrJSURt./!CE This policy provides primary insurance for any owned auto we Insure. The policy's coverage is excess over any other collectible insurance on an auto we insure tbat you do not own (including a temporary substitute), up to the limit(s) of protection for one auto, If other insurance, collectible or not, covers an suto rented or leased for less than one year and it states that coversge is void if there is other avnilable insurance, then coversges un. der this section are void, When there is other insurance applicable to the accident on the same basis, we will pay our share, Our share is the proportion that our limit 01 protection bears to the total 01 nil applicable limits, We will never pay more than the limit 01 protection, ,~....'- ~... "-l"""" "'r:'~ .~_;..,. ........, '~~;':'Io.,,;.I...~~...oJ less the deductible shown on tho Declarations, We will not subtract the deductible if the accident is between an auto we insure and another auto: 11) insured by the Erie Insurance Group, 121 not insured by the Erie Insurance Group, if: lal tho loss to the auto we insure is greater than the deductible amount: and (bl the owner 01 the other auto has been identified; and tcl the owner or operator of the other auto is solely liable lor the loss; and (dl there is adequate property damage liability in' surance which protects anyone responsible for the loss. ,7, ;.ODITI::)I.~Al PA Yr,,~rNTS :NC' Oecucti:Jlt> Apr.lles We will pay: 11) all expenses necessary to return your stolcn auto we insure. 121 trunsportatlon expenses rmmlting fro~l u co~ered Comprehensive loss, These expenses will be pwd by us until the auto we Insure is returned to you 10 us- able condition or we offer settlement. whichever comes first. TlUs payment will not exceed $15 per day nor total more than $450. per los.s unles~ a higher limit is purchased. No wwtmg period applies. (31 travel costs including meals and lodging, anyone in an auto we Insure pays because you were unable to reach your destination after loss under these cover- ages, Payment will not exceed $75 per person for each loss, (41 for loss to personal effects lincluding clothes and lug- gage) that are normally carried by a person, while the personal effects are in or upon an aoto we Insure. In) Personal t..'Hects must he owned by ,you or u relative. Ihl Money, profession~ or occupational tools .or machines. salesmen s samples. and merchandise for sale. delivery or exhibition are not considered personal effects. (cl Theft losses are covered only If the entire velU- cle is stolen. Id) When loss results from a collision, there must be enough damage to the auto we Insure to re' quire a Collision loss payment by us. (c) Payment for loss to personal effects will not ex- ceed $350. (5) all expenses necessary to replace a deployed sir bag, 16) up to $50 for the cost incurred for locksmith serv- ices if keys are accidentnlly locked in an auto we insure, U'l' will not pay for loss: III confined to or resulting from wear and tear. freez' ing, mechanical or electrical breakdown or failure. We will pay for such damage resulting from a co. vered loss, We will pay for the burning of wiring. 121 caused intentionally by or at the direction of you or u relative. 1:1) to sound eqoipment unless permanently installed, Payment for loss to permanently installed sound equipment shall be limited to $750 unless installed in the opening of the dash or console normally used by the auto maker to instnll a radio, Payment for loss to tapes or compact discs will be limited to five tapes or compact discs in anyone loss. When there is loss of tapes or compact discs by theft, we will pay for only one tape or compact disc, unless the entire uuto is stolen. 1,1) to lux machines, personal computers and peripher' uI equipment and similar electronic equipment that receives or transmits audio, visuul or data signals. If.) to a vehicle you acquire during the policy p"riod or nny temporary substitute lor it, if there is other upplicuhll! insurunce. WI to a non...wned auto while USL'<i in connLoction with: (a) the aoto buslne.s: or Ibl any other business or occupation, (Exclusion (6I1b) docs not apply to a private pusenger aato or trailer,) 171 to any trailer USL'<i as a residence, office. store, dis, play or passenger trailer. (81 to any auto we Insure while hired by or rented to others for a fee, or while available for hire by the public, "Fee" dop.s not include payment received in a car pool or for trips for non-profit nodal. educa' tiono! or charitable agencies, (9) due to any act or condition of war, including dis' charge of any nucluar we upon (evun if accidental). War (declared or undeclared) means 0 state of armed hostile conflict between states or notions, civil war, insurrection, rebellion or revolution, 1101 due to radioactive contamination, Ill) to camper bodies unless described on your Decla, raliona or replacing one described there. A camper body is 0 unit designed and equipped for use os living quarters to be mounted on an auto with 0 separate cob, 112) tn radar detectors and other equipment designed to give advance warning of the operation of a speed, measuring device, 113) to tires caused by road damage. such as a blowout or puncture, unless it results from another loss co- vered by this policy, (14) to an DUto we insure because of destruction or con' fiscation by governmental authorities if you or a relative are involved in illegal activities. liS) to sn Duto we insure while being used in any pre- arranged or organized racing, speed or demolition conle8t. stunting activity or similar activities. or in practice for any such activities. We will pay the Actual Cash Value for loss to stolen or damaged property, but no more than: III what it wlluld cost to repair or replace the property with other of like kind and quality; or 121 the Stated Amount that may be shown on the Decla' rations. Actual Cash Value reflects fair market value, age and condition 01 the property at the time of the loss, An auto and attached trailer are considered to be two separate vehicles under these coverages. The limit of protection for loss to any trailer not owned by you is $500. -8, An Buto und its equipment lire considered one Buto un. der these coverages including any deductibl" provision that applies. Equipment means that whicb is usual or incidental to the US" of an auto as a vehicle and includes the following customized or individually adapted items when buill or fit in or upon pickups or vans: lurnish- ings, carr",ting, insulation, wall coverings, interior wall decorations, TV s, TV anwnnas, beverage bars, addition' al air conditillning units, sink and ice box consoles: as wdl as Illurals, decals and graphics. Equipment includes camper hody il: III it is described on tbe Declarations or replaces one described there, and 12) it is mounted on an auto. Loss to II camper hody while not mounted on un Buto will he paid in accordance with the deductibles pur. chased on the camper hody. When there is other insurance for loss to an auto we insure under these coverages, we will pay our share 01 the loss. When there is loss to an auto we iosure that you do not own !including a temporary substitute) or to an addi- tional or replacement auto we iosure, we will pay the loss not covered by other insurance. When there is other insurance on an auto we iosure that you do not own, and it states that coverage is void il there is other applicable insurance, then coverages un' der this section are void, When there is loss to personal effects, we will pay up to $350 01 the loss not covered by other insurance. I I you and we lail to a;,'I''''' on the amount 01 loss, either party may make written demand for an appraisal, Each party will sdect an appraiser and notify the other of the appraiser's identity within 20 days atwr the demand is received. The appraisers will select a competent nnd impartial umpire, If the appraisers are unabl<l to agree upon an umpire within 15 days alter both appraisers have been identified. you or we can ask u judge of a court of record in the stute where you reside at the tirol' the policy is issued to select an umpire, The appraisers shall then set tbe amount of loss. 11 th" upprai~il'rs suhmit u written report of an Uh'1'eement to us, the amount ab'l'eed upon sbull be tbe amount of 10,". 11 they cannot agree, they will submit their differences to the umpire, A written award by two will determine the amount of loss. Each party will PllY the appraiser it chooses, and equally hear expenses for the umpire and ull other expenses 01 the appraISal, However, il the written demand lor ap- praisal is made hy us, we will pay lor tbe reasonable cost 01 your appraiser and your share 01 the cost 01 the umpire. We will not be hdd to have waived any rights by any aet related to appraisal. -: \ ~ :-.:-; 0;:' LOS~, We may pay the loss in money, or repair or replace th" damag"d or stolen property, At any time bl'fore the loss is paid or tbe property is repJaCl't!, we may return any stol"n property to you. We will pay the expense for its return and lor any damage to it. Upon payment 01 the Il1ss, we huve the right to take ull or part 01 the property at its &grel'll or appraised value. The,,, can ?e no aban, dOllment of property to us, We may settle uny claim for loss with you or anyone that has an interest in the property, For damage to a oon,owned auto, we will pay the highest amount available among tbe coverages you pur' chased under this section. ,.;: L~t:EFiT TO ElP,IL~" No bailee shall benefit, directly or indirectly, Irom this insurance. _'::~~ i.. ."t.E'~~ c:.JtVSZ: This clause applies to the Physical Damage coverages provided by this policy for the Lienholder named in Item 3 of the policy Declaratioos. It protects the Lien' holder's financial interest in the vehicle insured. I'ayment lor any loss under tbese coverages will be made in accordance with the financial intere,t tbe Named Insured and the Lienholder, as its interedt may appear lor specific vehiclelsl, have in the loss, Payment may be made to the Named Insured and the Lienholder jointly or to either or both separately. If separate pay' ments are made, the financial interests 01 both will be protected by us, When we pay tt.e Lienholder for a loss for which the Named Insured is not insured, we are entitled to the Lienholder's right 01 recovery against the Named In' Nured. to the extent of our payment. Our r~overy wiU not impair the right 01 the Lienholder to recover the lull amount of its claim. The Lienholder will, on demand, pay any premium due under this policy lor coverages which prlltect the Lien- holder's interests, if tbe Named Insured lails to do so, We Promise The Lienholder ThaI: 11 , The Lienholder's financial interest will be protect, ed regartiless of the acts or neglect 01 the Named Insured, subsequent legal encumbrance or any change in ownership 01 the property. However, this e1ause does nllt apply in any case of fraudulent acts or omissions by the Named Insured or anyone representing him. 12) If we cancel or refuse to renew this policy, not less than 10 days advance notice 01 such termination will he given to the Lienholder. 1:1I If this policy is cancelled by the Named Insured, we will send notice 01 cancellation to the Lienholder, ,9, ACD!T10t\A~ -co '\'~;:'.MlE; 1_ i_.; " . '.' WARNING: We will not be lioble for domages or other expenses incurred in any foreign country where this policy does not apply, (In Mexico, however, Collision coveroga, if purchased will apply,) We will reimburse you for premium paid for up to 30 days coverage in a foreign country where this policy ~ .... """.* . ' ; \..i.~~ ! t'-"!\i-.~ The following coverages apply only to specific autos when a premium is shown for these coverages on your Declarations: ; ..J/,L' S:...'il\jl~~ ChF Pf:()r..~I:.::. We will pay reasonable towing and labor costs required because an auto we losure ia diaabled. Labor must be done at the site of the disablement. (No deductible applies,) 0',- 1""::'" :-. :-. ";' ..- ..": .' :.;: I'::' ~;.:-~ ~ Transportallon Expansas. Collision' We will pay trans. portation expenses thot result from a Collision loss to the auto that hos 0 premium shown on the Declarations for this coveroge, Transportsllon Expsnses. Comprehensive, We will pay " We, you and onyone else protected by this policy must do certain things in order for the terms of this policy to opply: interest in this policy moy be transferred only with our written consent. If you die, the policy will cover: (01 your spouse if residing in the same household ot the time of YOUt deoth; (bl anyone having proper custody of an owned auto we Insure until a representative is appointed, but only until the end of the policy period during which your death occurs; and (c) your legal representative, but only while per' ,.~:~, ~~..t:" Q1H~,::t., ;:iJl._i....r. .. ....' ,1..- .. docs not apply, Ileimbursement wlll be made ONLY for similar coveruges. Such coverages must apply to an owned auto we losure, used by you or a relative in the foreign country, Heimbursement will not be made to anyone employed, stationed in tho armed services or at' tending school in a foreign country, " ....,. I Gr..... "I .._ ~ : ,"- :i .:.~': transportation expenses that result from a Comprehen' sive loss to the auto that has 8 premium shown on the Declarations for this coverage. Auto rental. hUB or taxi fare aro ell.amploa of covered expen.... Payment may .tart on tho day of tho 10.. If i tho BUtO cannot be driven, If drlveable, paym.nt may start the day you I.ave the BUtO at a garage for repairs, Payment ends on the day we offer s.ttlement or on the day the BUtO: (1) is r.placed; or (2) is retl:med to you in usable condition; or (3) could reasonably be expected to be repaired. whichever com.s first, Payment will not exceed the specific limits shown on the Declaratlona, (No deducti, ble applies,) This coverage applies whetber or not w. pay for dwoag.s under Comprehensive or Collision coverage, f<lrming duties as your represent8tive and only until the end 01 the policy p.riod during which your d.ath occurs, Bankruptcy or Insolvency of 8nyooe w. protect will not relieve us of our obligations, Your Right to Cancel You may cancel this policy by mailing or delivering to our Agent or U8 written notice stating at what future date you want the cancellation to take effect, We may waive these requirements by confirming the date of can' collation t" you in writing. ,10, "- Our Right to Cencel or Relu.. 10 Renew We may cancel or refuse to renew this policy or any coverage by mailing yuu written notice stating the ef. fective date of our action. Our action will comply with the laws of the state in which yuu reside at the time the policy is iSBued. We reserve the right to cancel for your noncompliance with our premium payment plans, We do not waive our right to cancel. even if we have accepted prior late payments. Stele Provisions IlliNOIS, INDIANA, PENNSYLVANIA, TENNESSEE. WEST VIRGINIA COllcellations moiled during the first 60 days the po/i- cy is ill effect. The effective dote of canceUulion will never btJ eurlier than: (a) to days after we send it IIN, I'A, TN): lb) 30 days after we seed it 1[1., WVI. Cance/lations mailed after the first 60 days the policy is in effect, The effective date of cancellation will never be eurlier than: la) 20 days after we selld it ON, TN); (b) 30 days after we send it 01., WVI; lcl 60 days after we send it IPA). DISTRICT OF COLUMBIA Cance/lations mailed during the first 30 ,lays the po/j, cy i" in effect. The effective date of cancellation will never be earlier than 21 days after we send it, Cancel/ation., mailed after the first .10 days the policy is in effect. The effective date of cancellation will never be earlier than 30 days after we send it. ~HIO Cance/lation.' mailed during the first 90 days the poli, cy is in effect, The ell.ctive date of callcellation will never be earlier than 21 days after we send it, Cancel/ations mailed after the first 90 days the policy is in effect, The effective date of cancellation will never be eurlier than 30 days after we send it. MARYLAND The ellective date of cancellation will nt,ver be earlier than 45 days after we send it. Non,Payment 01 Premium The effective date of cancellation will never be earlier than 30 days after we send it. Relurn 01 Premium If yoar policy is cancelled by you or 09, we will return . tlw pro ruta unu~wd share of your premium. Cancella- tion will be effl'Ctive even if we huve nlll given or offered Hny rt!turn premium. Renewsl Rlghls Should we roluse to renew this policy, we will do so in c"mpliance with the laws of tlw state in whicb you reo side. We will notify you before the end of the policy peri, lid. We will send this notice: illl at least 20 days in advance of the end of the polio cy period (IN); ih) at least 30 days in advance of the end of the polio cy period lOC. IL, OH. TN); lc) at least 45 days in advance of the end of the polio cy period (MD. WVI; ld) utleast 60 days in advance of the end of the poli, cy period (pAl, ST ATE PROVISION. OHIO Should we refuse to reneW this policy, we can do so only at each second anniversary of this policy's original ef, fective date, Method of Giving Nolice Mailing notice to the address shown on the DeclaratloDs will be sufficient proof of notice, The policy period will end on the date and time stated in the notice. ! ,; ~\ i i~r. This entire policy is void if, before or after an accident or loss, anyone we protect has intentionally concealed or misrepresented any material fact or circumstance concerning this insurance. In the event of a fraudulent claim, we will not make pay. ment for the occident or loss, Your policy is 0 continuous policy, It will continue in force until cancelled by you or terminated by us as ex, ploined in the Cancellation Condition. Each year we will send y"u a Continuation Notice which shows the premi. um due for the next policy period, I n return for this service. you must mail us written ncr lice prior to the new policy period if you want to can. eel. if we du not receive this notice. your/olley remains in force and you must pay us the eurne premium due for this time, You awee to cooperate with us by promptly and truth, fully answering all questillns about drivers and autos we insure and sib'lling all papers relating to such in, sur ann', This policy conforms to the laws of the state in which you reside at the time it is issued. If the laws of the state change, this policy will comply with those changes. Your policy may be changed by asking us, Your request must contain enough information to identify you. Ask. ing our Agent is the sarne as asking us. If we agree with your request, we will then issue an Amended Decla. ratioDs. ,II, We will givt~ yuu tht, ht'ndit (If any l'hJngt! .1~Il~dl' by u,." if it (!ties not n~quirc uddltHlIlul prt'l1lltllll. I tll~ changl' will he effective U:i of the dull' WI.' lJllpll'IIH'nt tllt' cllllllgt' for you in yuur Slllh'. H the inforl1l11tion Wi' lIHt' to dl'lt'rrninc tht' pn'miulII for your rovtlru~;wl~l (hungl'~ durillK the polIcy pl'rwd, ~~ ~nay UdJUNl your premium. Premium udju~tn\t'nt:i will be made wlIng' ruh!s and rtltes in l'ffect for uur ww. You must rom ply wilh the terms of lhis policy befure you may sue us, The le~alliabilily of anyone we pr~.' leet must he dt,termincd hefore we may lw sued, ThiS determinaliun may bfJ made by a courl of law or by writ, len ab.,.e,'ment of all parties. including us. No one has the righttu mak" us a party tu a SUit to deter~llle ,the liability uf any on" we prnterl. I n event of ., Ml~hcall ay' owolS claim or a Comprehensiv" or CollISIOn I"ss. no suil Olav be brought against U8 until au days after proof of loss 'is filed. .\ft,'r WI.' flll1kpll pUYflIl'nt untll'r lhi~ Ilfllicy, we willl~uvl' i hl' ng-hl (0 rl'l'll\.'t'f. frull! unyOlH.' dsl.' held rl!s(lumuhlt!. Anyone we prolect is rcquired tu ~rumdt.~r thi9 ri~ht ,to UN, und do nnthinK tu hurm this tight. Anyon" rel:cIV' ing puyment from utj and from someune else for the same uccir..hmt or 105s will reimhurse UH up to our payment. At our opliun, this insurance will first prot~ct you th"n. your spouse residing in your household and finally others we protect. \\'hen then- is an accident or loss, uoyom.' we prolect will: lal notify us or our Agent in writing us soon as pus' sibl" stating: \, the name IInd policy number of our policy. holder; 2. the time, place and circumstances of lh" IIC- cident or loss; :3. names and uddn-sses of injurt>d persons und wilnes~c~. Ihl promptly notif~' lhl- polin. in CU~l' of thl!fl. lrl give us: I. promptly, any papers thal relate to the ac' cidenl or los", 2, a si!{l1ed slatement containing all the filcts about the claim: :1. proof of loss to damaged pruperty. Idl at our request: L answer all questions about the IIccidl'nl or loss; " ~,Uhlllil lo ...t.alt'I1H'lIlS Hillin oath; ;t. It'i'ii'it In ITIllking ~l'lllt~I1II'l1t. .1. hdp Uh looforn' IIny right of recovery again:it unyolII' huh"- to IInymU' WI! protect: :1. t'olllwrull' in lht, conduct of Hur invt!stigu- lIun'i und uny luwsuit'i; fj nltl'nd lwurinl{s und lrials; 7. u)i~ht UN in securing Hnd gl\.'lI1g' evichmce and in ohtuining the uttendance of wit. nt!!HiCS; H, submit I" physical and n"mtal eXlIminalion by d()(~lOrs we cho()s~ us often OM we ".asonably require tWe will pay lor thes,' uxaminations); U, si!{l1 papers to allow UH to obtain medic.1 reports, eurnings statements and copies of recurds; 10. ullow as damaged disposal. Ie) nllt make payments, assume obligations or in. cur expenses, except at their own cost. lfl prolt!d autUM we im~ure from further clumuKlL We will pay for reusonuhle costs to do so. We will "ut pay for luss due to your failure to pro' tl!\:t un auto we insure (rom further damage af. ler u loss. to inspecl and property before IIppraise the its repair or The lollowing condilions apply only to policies issued al Brie Insuru/Jce Exchange: This policy is not subject to contingent liability or as. sessment, Erie Indemnity Company may ke,'p up to 25% of th" premium wrillen or liS slimed by Erie Insurance Ex. cbange as compensation for IAI becoming and acting as Attorney'in.Fact. tHI managing the business and af, fairs of Erie Insurllnce Exchllnge, its affiliates and sub, Sldiaries, and ICI puying general administrative l'xpenses, including- sales commissions. salaries and em- ployee iwm.fits, tuxes, n~nt. dllprt.!ciulion. supplius and dalu prol'cssing. The resl of the premium will be placed on the books of thl' Erie Insurance Exchllnge, We will deposit or invest this amount as permitted by law. This amount will be used to pay loss"s. loss adjustment expenses, invest' ment expenses, damug~s, legal expenses. court costs. taxes, asscs~rncnts. licenses. fees, any othl!T govemmlm- tal fines and charges. estllblishment of res"rves and sur' plus. and reinsurance. and may b~ used for divid"nds and other purposes Erie Indemnity Company decides ure to the advllntage of the Subscribers, TillS POLICY liAS BEEN SIGNEIJ ON OUIlBEIIAl.F AT EllIE, PE:-JNSYLV AN\A BY OUIl CIIAIltMAN AND SE('ltETAHY. IF HEqUIlU:1J BY LA \\'. IT liAS BEEN COl.!,\;TEItSIGNED ON TilE UECLAIlATIONS BY OUIl AUTIlOltlZED AGENT, FAl'lEd :; 911 /1 ': 1./-/ ~--. /. If' ~'~- "~~,. Sl'crt'tar~' 7'/ " ..~'. /1 .L._~. Chairman -12 j'''-: ,f 1:. 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