HomeMy WebLinkAbout95-03966
'1
I
~I
3
\
,
.
-?
~
3
I
(
~
J
'"'
...::J
a-
(Y)
. ,
\b
<
.....
Vl~
<>
UJ...J
...J>-
c..Vl
;Z;Z
O;Z
~~
o -3 Q
U>-< ~
U-~..J Z
O::J I <
o :E
.......UZ ~
gsC~
0;Z1- ;;!
U<U ......
UJ~< ~
:J:UJ...J t-
.......CC- >-
Z~> .0::
_UU~~
U">
?'
-,-
0.:
In
.....
,'")
r ::,
-.
."
.
.J \
'0
.__, I
~ '-.J'}
., , ,~
\
\:!-~
~
'"\"""'" ...,j
10' \Y>
.....!.~
'-i'
~I
'~ :B
.)
'-;2
~
~
qt)
,,~ 1.
~ .J
V~~C'
'- '
-,
-
'+-
'+-
.~
+->
c
+->
c
'"
"C
C
.e
CIJ
Q
~\
:;:
o
u
~\E~
Ulffi~~ ~
~ ~ i ~ l!:!
ii: 0 Z \ III
15a:e:~ ,;,
~.i=g ~
~O~~ ~
!Zffi C
"t"'I~
ZOa:
C~~
.~
'"
~
c..
a::
UJ
'"
;;!
3
.
a::
UJ
'"
...J
<
3
.
a::
<
Vl
Vl
.....
ul
:E
.
>
.
3
>-
a::
a::
UJ
r:>
.
caused by a deer and not by his negligence. On the issue of
damages, Defendant maintains that plaintiff Kenneth D. pifer was
bound by the limited tort option on his automobile insurance
pOlicy, and that his injury (a ruptured biceps tendon) was not
serious, so that non-economic losses are not recoverable. In
the case of plaintiff Melissa R. WalKer, the same issue does not
exist, because she had elected the full tort option.
This will be a jury trial in which, pursuant to
an agreement of counsel, each side will have four peremptory
challenges, for a total of eight. The trial is estimated to be
of a duration of two days.
In the event that any deposition testimony to be
utilized at trial will require rulings by the Court on
evidentiary issues, counsel are directed to supply a copy of the
transcript in question to the Court at least five days prior to
commencement of the trial term, with the areas of objection
still being pursued highlighted and with brief memoranda in
support of their respective positions. counsel are also
directed to furnish to the Court preliminary proposed jury
instructions and a preliminary proposed verdict slip with
respect to the issue of the damages of plaintiff Kenneth D.
Pifer in connection with the limited tort option issue.
With respect to settlement negotiations,
plaintiff in the case of pifer v. Walker has demanded
$32,500.00, and Defendant has offered $6000.00; in the case of
e. U) n
0' -'"I
...:[:J ;- I
o)r,; ::~j j:'J
',". -I
f:~L" C.) ';''J
,;,)
ill..
':":-. . -.,
~');!-I :.... ~ "j :f I
t~ - f', ',-\ )
:,'; t" '!? ;,,11'
>:,; ~:1
,-
'J ,:;. :j,!
-. -...
v.
119 , 120 OLER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN TRESPASS (M.V.)
/95-3966 CIVIL TERM
MELISSA R. WALKER,
plaintiff
JERRY W. WALKER,
Defendant
KENNETH D. PIFER, . IN THE COURT OF COMMON PLEAS OF
.
plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
v. CIVIL ACTION - LAW
IN TRESPASS (M.V.)
JERRY W. WALKER,
Defendant 95-3968 CIVIL TERM
-----------------------------
ORDER OF COURT
AND NOW, this 28th day of August, 1996, upon
consideration of the oral motion for consolidation of the cases
at No. 95-3968 CIVIL TERM and No. 95-3966 CIVIL TERM made on
behalf of the Defendant in those cases at a pretrial conference
on this date, and over the objection of the Plaintiffs' counsel,
the motion is granted, and the cases are consolidated for
purposes of trial.
J
RICHARD A. SADLOCK, ESQUIRE
For the plaintiffs
LAURALEE B. BAKER-STARR, ESQUIRE
STEPHEN L. BANKO, JR., ESQUIRE
For the Defendant
Court Administrator
wcy
t
f.1 U"> 0
(.P .\
....... .". 1
.,.,i'u ,- *0
tY)IY", :fi . \ i ~
e)~. t:~ 0) ___If'
'~CJ
(..1.... .::> ' )1
t-'~(.~ H;,(1
~~: ""'\
~~ ~'. .....,
.,,\.i I :C:")
,';(') \.,' .-.)1\'
, '~\-. t.: ., ';:,:~
~ - ',)1
-. 0 -:.
MELISSA R. WALKER,
plaintiff
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
.
: CIVIL ACTION - LAW
.
.
v.
: NO.
JERRY W. WALKER,
.
.
:
Defendant
: JURY TRIAL DEMANDED
HOTICI~
Le han demand ado a usted en la corte. Si usted quiere
defenderse de estas demandas expuestas en las paginas sugnuienteB,
usted tiene viente (20) dias de plazo al partir de la fecha de 1a
demanda Y la notificacion. usted debe presentar una apariencia
escrita 0 en persona 0 por abogado Y archivar en la corte en forma
escrita BUS defensas 0 sus objociones alas demBndas 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 por cualquier queja 0 alivio que es pedido
en la peticion de demanda. Usted puede perder dinero 0 SUB
propiedades 0 otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEMENTE. SI NO TIENE
ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA 0 LLAHE POR TELEPFONO A LA OFICINA CUYA DIRECCION
SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEQUIR
ASISTENCIA LEGAL.
court Administrator
cumberland county courthouse - 4th Floor
One courthouse square
carlisle, PA 17013-3387
(717) 240-6200
MELISSA R. WALKER,
plaintiff
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
v.
CIVIL ACTION - LAW
NO.
JERRY W. WALKER,
JURY TRIAL DEMANDED
Defendant
POKPLAINT
1. plaintiff Melissa R. WalKer is an adult individual,
citizen of the commonwealth of pennsylvania, who resides at R.D.
13, BoX 111C, Shelocta, Indiana county, pennsylvania.
2. plaintiff Jerry W. Walker is an adult individual, citizen
of the commonwealth of pennsylvania, who resides at 449 Hunters
Road, Newville, cumberland county, pennsylvania.
3. The facts and occurrences hereinafter related took place
on or about september 24, 1994, at approximatelY 11:10 a.m., on SR
641 _ Newville Road, west pennsboro Township, cumberland county.
4. At that time and place, Defendant Jerry R. WalKer was
operating a 1979 Ford F-250 piCK-UP trucK and was travelling eaet
on SR 641, West pennsboro Township, cumberland county.
5. At that time and place, plaintiff Melissa R. WalKer va.
a passenger in a vehicle being driven by Defendant Jerry R. walker.
6. At that time and place, Defendant Jerry R. Walker
observed a deer on the left side of the roadway.
72124/CLN
~
7. At that time and place, Defendant overreacted to the
presence of the deer, operated his vehicle at a high rate of speed,
unnecessarily swerved to avoid the deer, lost control of his
vehicle and struck a telephone pole on the right berm of the
roadway.
8. At that time and place, a violent collision occurred
between the left portion of the Ford trucK and the telephone pole.
9. The foregoing accident and all of the injuries and
damages sustained by Plaintiff Melissa R. Walker set forth
hereinafter, are the direct and proximate result of the negligent,
careless, wanton and reckless manner in which Defendant Jerry R.
Walker operated the 1979 Ford F-150 truck as follows:
(a) failure to have the vehicle under such control a.
to be able to stop within the assured clear
distance ahead;
(b) failure to keep alert and maintain a proper watch
on the highway;
(c) failure to stay within his lane of travel;
(d) failure to apply his brakes in sufficient time to
avoid colliding with the deer and telephone pole;
(e) failure to keep proper and adequate control over
his vehicle;
(f) failure to travel at a safe speed;
(g) failure to drive his vehicle with due regard for
the highway and traffic conditions which were
existing and of which he was aware or should have
been aware;
2
(h)
failure to take reasonable evasive action to avoid
the accident; and
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.
As a result of the aforementioned accident, Plaintiff
(i)
10.
Melissa R. Walker sustained painful and severe injuries, including
but are not limited to, a sprained left shoulder, cervical sprain,
and thoracic outlet syndrome.
11. By reason of the aforementioned injuries sustained by
Plaintiff Melissa R. Walker, 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.
12. Because of the nature of her injuries, Plaintiff Melissa
R. Walker 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
Melissa R. Walker 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 is made therefor.
3
\
14. As a result of the aforementioned injuries, Plaintiff
Melissa R. WalKer has been and in the future will be subject to
great humiliation and embarrassment, and claim is made therefor.
15. As a result of the aforementioned injuries, Plaintiff
Melissa R. Walker has sustained worK loss, loss of opportunity and
a permanent diminution of her earning power and capacity, and claim
is made therefor.
16. As a result of the aforesaid injuries, Plaintiff Melissa
R. Walker has sustained uncompensated work loss, and claim is made
therefor.
17. Plaintiff Melissa R. WalKer continues to be plagued by
persistent pain and limitation 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 Melissa R. Walker demands jUdgment
against Defendant Jerry R. Walker in an amount in excess of Twenty-
Five Thousand Dollars ($25,000.00), exclusive of interest and costs
and in excess of any jurisdictional amount requiring compulsory
arbitration.
ANGINO & ROVNER.-ll>, .
Date: July 25, 1995
R d-A. Sadlock, Esqu re
.Il:" No. 47281
4503 North Front Straet
Harrisburg, PA 17110
(717) 238-6791
Counsel for Plaintiff
COMMONWEALTH OF PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
MELISSA R. WALKER,
plaintiff
No. 3966 Civil 1995
v.
CIVIL ACTION - LAW
JERRY W. WALKER,
Defendant
JURY TRIAL DEMANDED
ANSWER OF DEFENDANT,
MELISSA R. WALKER, TO
PLAINTIFF'S COMPLAINT
1. Admitted.
2. Admitted in part and denied in part.
Jerry W.
Walker is apparently the Defendant in this matter.
3. Admitted.
4. Admitted.
5. Admitted.
6. Admitted.
7. Denied as stated. After Slowing his vehicle and it
appearing that the fawn would retreat from the roadside, it
suddenly darted into the left front corner of Defendant's vehicle.
The fawn became lodged under the left front tire causing the rear
of the vehicle to slide sideways striking a telephone pole on the
right.
8. Admitted in part and denied in part. The
characterization that the collision was "violent" is denied.
9(a) - (i).
Denied. The allegations contained in this
paragraph state a legal conclusion to which no response is
necessary.
10. Denied.
1l. Denied.
12. Denied.
13. Denied.
14. Denied.
15. Denied.
16. Denied.
17. Denied.
18. Denied.
19. Denied.
WHEREFORE, Defendant, Jerry W. Walker, demands judgment
in his favor and against Plaintiff, Melissa R. Walker.
Date:~~~/1~
REYNOLDS & HAVAS
A Professional Corporation
BY:~
st . Banko, Jr.
Atto ey I.D. *41727
101 pine Street
Harrisburg, PA 17108-0932
(717) 236-3200
Counsel for Defendant,
Jerry W. Walker
- 2 -
n If) n
~:; (7;) ~il
,,: t_ ")
-ui.:j (r.-:.
[Pt-;, ('- d~
" ,:I.:':l
t'.7t"
f'-I" N
...~;' i I'
,...... ~ 0
" ..,., '11
;,~t ..,
)-
Q
C1.. r",' ',1 \I
#'-'. ~ .. 'I
:,., -,
:J,
'D -',
r.\
"
..
"
MELISSA R. WALKER
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
.
.
:. NO. 95-3966 CIVIL TERM .
JERRY W. WALKER
KENNETH D. PIFER
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-3968 CIVIL TERM
v.
JERRY W. WALKER
VERDICT SLIP
1. Was Defendant, Jerry W. Walker, negligent In the operation of his motor
vehicle?
YES
NoL
If your answer to Question No. 1 Is NO, please do not answer any
additional questions and return to the courtroom. If your answer to
Question No. 1 Is YES, proceed to Question No.2.
2. Was the negligence of Defendant, Jerry W. Walker, a substantial factor In
bringing about the harm of Plaintiff, Melissa R. Walker-Pifer?
YES
NO
If your answer to Question No. 2 is NO, please do not answer
Question No.3, but proceed to question No.4. If your answer to
Question No. 2 is YES, please proceed to Question No.3.
3. What amount do you find would fully compensate Plaintiff, Melissa R.
Walker-Pifer, for any Injuries you find resulted from the motor vehicle
accident?
$
-.--....- .."-:.-.---.......;
. ..' '-.-
,I Do you find that tho nogligonce of Dofondant, Jerry W. Walker, Vias a
substantial factor In bringing about the hnrm to Plnintltf, Kenneth D. Pifer?
yES_____
NO
If your answer to Question No. 1\ is NO, ploase do not answer any
more questions and return to tho courtroom. If your answor to
Question No. :3 is YES, please procomlto Quostion No.5.
5. What amollnt do YOll find would fully componGnto Plaintiff, Kenneth D. Pifer,
for any InjurieS YOll find msultocl from thp motor vehicle Heddent?
$
G. Did the Injury, If any, sustained by Plaintiff, Kennoth D. Pifer, result in a
seriolls impairment 01 body function or pennm18nt :>eriOlJS disfiyuremont?
YES
NO__.-_.
'__'___.'~.'U'__'",'_______".~'__'__
IiI,' '
I ji,
(' \ ,- -.~
3~~-_:-i. C(," ~".~~-'_1~~ \i\~. ,,,, - ~
(ForejJersori) , ,..".,)
(Date)
i CORRECTION i
I
Previous Image
Refilmed to Correct
Possible Error
:cIlUilFI", fi[TUEtI
I;CGULtd,
L:A:-d-, flU: 1 'J':~5-i.....ItJ'Jbh 1-)
,-"ltINUIJW':AI,rH fW 1":/IIl:;YLVANIA:
Lilli/HI' I W cIJMHI-:I\LAI/il
W,\I.hl<l\ tll-:I.J :"i~;A R
vs.
W,~/,hl':fi JEIIRY W
:,n:VE WIllsrU:R, Sheriff or Deputy ~heriff e'f
CUM8EHLANV County, Pennsylvania, who being duly sworn according
tf' law, ;Jays, th... wlthin ~UflPl)~;NA AND L~:TT~:R was lJ,,,,"ved
upon II[IDI':R ~:DWARD H
defendilnt. at 1501<':00 HOURS. on th... 12th day ot Sept...mber
ttlf:.-'
l':l~16 at ,_JdlLJ.57-<-.llIG
ti.f';WV_!.Ll,~;,_ PA_U::?41
:';I-'RINI3 TERRACE
--
Cllunt y, rf.~nn8yJ vanla,
'--- ,CUMBERLAND
by hand1ng to PAULlNE HEIDER, ADUbT IN
C1ihllGjL,__
-"---"--
a true "'r,d attested copy of the SUHPOI::/i.A AND U,:rn:1l
and at tlw same time dlrect1ng II,,!:. attention to the contento thereof.
---~..
Shr~l'iff'E.l l.:ost.s:
1)1)("::I~l?tlng
:.:;ervicp
Affldavlt
Surch~rgE'
l/j.00
:~. 20
.00
2,00
So answers:
";2' .<" ',/" '
<'.>... " ~
~... '~.!t"'!'.......~-'l.:.!,-""". ~~.._.,.'
r ....,..,~,'....- __ ~ ._~
rr:--Th'JmaG r\Il-c\"e-;- ~ el'lff-
~'?J. 20,ICYNOLJl:3 & HAV,\:.;
0'j /13 / 1'39(.
II Y ..:J;~" " lL . n
, ~"-'- ;RtLL
"--. "....Ll:-I"'L'__~
L'",pUey '>IIE'I'l.11
Sworn anrl ~UbD~ribed to befoJ-~ me
I
thlB ,;H~ , day of ..J",ti",-t.........-
I 'oj --.2,,_ A. [J.
,
"-"~:-=71'1.I.'''''-I'(~'')I)I,<,.~...".~~,:_.___ _..,
I rOt 1t'JntJLary
4. Denied. By way of amplification, Plaintiff Kenneth D.
Pifer is the 2D.l:l named insured on the aforementioned General
Accident insurance policy. At no time applicable hereto did
Plaintiff Kenneth D. Pifer sign a tort option selection form.
Therefore, pursuant to the terms of the Pennsylvania Motor Vehicle
Financial Responsibility Law, Plaintiff Kenneth D. Pifer is deemed
to have the full tort option on his policy. See, 75 Pa.C.S.A.
S1705(a)(3). A copy of Mr. Pifer's declaration page is attached
hereto as Exhibit A. Further, attached hereto as Exhibit B is a
tort option selection form signed by Mr. Pifer's ex-wife, Kathleen
Pifer. The Pennsylvania Motor Vehicle Financial Responsibility Law
grants no power or authority to Kathleen Pifer to sign a tort
option selection form binding the named insured on the General
Accident policy, Kenneth D. Pifer.
5.-7. As Plaintiff Kenneth D. Pifer has the full tort option
on his policy, Defendant's averment is irrelevant to the instant
proceeding.
8. It is admitted that the testimony of Plaintiff's treating
physician was not taken until August 30, 1996. Further, documents
were not obtained from Plaintiff's insurer, General Accident, until
it responded to Plaintiff's Notice for Records Deposition on or
about September 11, 1995. As evidenced by Plaintiff's Exhibits A
and B herein, Plaintiff never selected the limited tort option and
is therefore entitled to all rights of the full tort option.
1
9.-10. AS plaintiff Kenneth D. pifer has the full tort option
on his policy, Defendant's averment is irrelevant to the instant
proceeding.
11.-12. It is admitted Plaintiff previously gave deposition
testimony in the instant action. However, Plaintiff has the full
tort option herein and the instant Motion should be denied.
13. Admitted.
14. It is admitted that the Plaintiff had physical therapy at
Keystone Rehabilitation center.
15.-16. Dr. Mira's deposition testimony speak. for itself.
However, the testimony relates to the amount of damage. sustained
by Plaintiff herein. Further, a. Plaintiff has the full tort
option, the extent of Plaintiff'. damage. remains s jury que.tion.
17. Defendant's averment is 8 conclu.ion of law to which no
responsive pleading is required. TO the extent the averment may be
deemed factual, it is hereby specificallY denied. By way of
amplification, Plaintiff did sustain a serious injury and
permanent, serious disfigurement 88 a result of the motor vehicle
accident on september 24, 1994. Further, Plaintiff has the full
tort option and is therefore entitled to recover all damage.
recognized by pennsylvania Law.
,,~ GENERAL
ACCIOEr-'T
INSURANCE
~~b .AL~UI ~I~CCI
PHI' 'ljELPHU PA l'HOb-316b
\,It"C""""" ''It.'-l-'LU' ll.oIW"- ,.....
'OHPANY OF AHERICA
)se
."OED
.LlIl.ATlON
: and address of Insured
Policv number
RPA 3'il-bb7-~9 1
Policv nod
01/17/9~ TO 07/17/94
ARent name and address
A en! code
427bb9
PIFER KENNETH 0
eOlt 1020 RDlll
lANOIsaURG PA L70~0
~
CUPP INSUIl.ANCE AGENCY
SO CA"1.1 SLE ST
POBOX 309
NEW BLOOHFIE:LD
PA 170b3
:Is
IS POLICY CO~E~5 THE
YE All. nAOE NAI'\E
-I. Z 88 TOYT
FOLLOwING
,"OOEL
SHORT llEO
VEHIClESI
VEHICLE I.O.NO.
JT4R~b3AltJOZL650~
CLASS SYH
80<:511 II
re;'R
53
SHTE 37
OIR. 81LL
.Ow IS A LIST OF THE COVERAGES PROVIOEO UNDER THIS POLICY. PLEASE NOTE THAT YC'
_ COVEREO ONLY wHERE A LIHIT OF LIA31LITY AND A PRE~IUH ARE SHOW~.
VEH. Z
~ LIHIT PIlEM.
FIRST 'ARTY BENEFITS
WORK LOSS .
MEDICAL, BENEFITS
~U~ER.L;.EXPE"SE'8ENEFITS
ACCIDENTAL DEATH BENEFITS
LUel(nY~';"" ",., .'.,
UNI~SUReO'MOTORISTS
UNOERINSUREO MOTORISTS
CAHAGE TO YOUR CAR
OTHER THAN COLLISION LOSS
ACTUAL.CASH'YALUE-LESS OED OF
fxTENOEO TRANSPORTATION EXPENSE
C.OLL1510N LOSS
ACTUAL CASH VALUE-LESS Dee OF
TOwING AHO LABOR
OPTlON-ll5
1000/5000 /
1.00,000
1.500
EXCLUDED 147
100,000 ZZ9
5(hOOO 19
50,000 2
100 9L
OPTION 01 5
500 237
T5 )
SURCHARGE OR AOUITIONAL AHOUHT
CHARGED A5 A RESULT OF
CHARGEA!LE ACCIDENT OR VIOLATION
111,.00
UR TOTAL POLICY PREHIUH ISI
~ITEQ TORT APPLIES
Se1,7.00
.~CRE ON NEXT PA~E...
.GIO 1
., P\~S.'O Rn. 1.M
"'plny Copy
c../ \ ;:'/""'. P,,;..':"" ~
t\~ GENERAL
^CCIOENT
J INSURANCE
_~b WllNUT STREET
PHI' lJELPHU U ,,,,Ob-HSO
CicNt:RlL lCCIOl:~1 &N~U"''''''''
'OMPlNY OF lMERItA
..--~----------'.-
oQse T of Ii Policv number Policv nod
ENOED PERSONll IlpA ,"-tob1-&" , 01/111"" TO 01/111<;4
CLAUTlOH AuTO,",O&IlE
,e and address of Insured ent name and address
PIFER IC.ENNETH 0 tUPP INSURANCE lGENCY
eOll 1020 RDlll SO t"RLULE ST
l.lNOISBUIlCi 1''' 170..0 I' 0 eOll 30"
NEW eLOOMFIELO Pol 110bS
:ails
l.eASE NOTE THE FOlLOwlhe; tHlhGES TO YOUIl rOlICY:
_ VEHICLE , HAS BEEN OELETEO.
'OUIl tHlHGE IS EFFECTIVe 04/01/<;4
tOUR RETURM PREMIUM IS: Slq.OO
10U ~lLL RECEIVE A SEPARATE 8ILLING STATEME"T IF NECESSllY.
YOUR-COVERAGE STARTS O~ 01/11/94 AT \Z,Ol A.M.
i
TriE fOLLowING
FORM D..n '
AT toblt
A19'-'
Al'''e.
lO)O)
FORMS AND ENDORSE"ENTS AlE ALSO PART Of YOUR
FOIlM . DATE FDIU' DAn FOR" DATE
AOOOIA A0151 IL0910
A19,9 2Z0tO A04Z1
A1Zbl A01)1 Alb'l
AlOlS
'OLltY'
fORM
Alb6'
A0105
AO..ll
DATE
/
T~e laSS PAYEE IS:
VEH.Z etc.. OF LANOIS~UIlG PO eOll 119
LlNOIsaURG
I'A110ltO
THIS IS l llehEW~L OF A POLICY ORIGINALLY ISSUEQ 01/17/90
'H!: FOllOWINc.
PE IU TOR 1
'E:IlATOR 2
WILL OPERATE VEHICLES
IC.ENNeTH pIFel'.
JOSEPH t PIHI'.
COVEReo ~V TH15
oe/01l5 ,
Ol,/ll/lb
POLICV:
5
PIP
OED
8
OPT T/P.
PIE OP
I' ,
15 SlCTION FOil CD~p"HY USE ONLY:
VEri elL POL MOL COMP Cull A/I' UM UM
pO
ull'!
PIP
Ll/4
o
z
o
005 o7T 9
5
z
~;\\
-I:::
'-
CE...E~ ~l
.~CCIDE'" T
I...Sl'"~...'=E
Jurng
.CC~
i..........
Notice To Named Insureds
fl, nCH) r'lE
U~\Vr r\
. .-
. ~ ..
A. "Llmiled Tort" Option, The laws of the Commonwealth of Pennsylva,,'la give you the
right to choose a form of Insurance that limits your right and the right of members of your
household to seek financial compensation for Injuries caused by other drivers. Under this
form of Insurance, you and other household members covered under this policy may seek
recovery for all medical and other out.of,pocket expenses. but not for pain and suffering
or other nonmonetary damages unless the Injuries suffered fall within the definition of
"serious Injury" as set forth In the polic)'. or unless one of several other e.ceptlons noted
in the poli'=)' applies. (See enclosed booklet for a descripTlo,~ of "serious Injury" and the
exceptions.) Theannuat premium for basic coverage Is S 1.462.00 which reflects the
coverages and amounts of coverage you have now. The annual premium for basic coveral!oe
as required by law under this "limited tort" option Is 5 1,140.00.
Additional coverages under this option are available at additional cost.
B. If you wish to choose the "limited tort" option descibed In paralraph ^' you must slln
this notice where Indlated below and retum It. If you do not slln and return thIs notice,
you will be considered to haJe chosen the "full tort" coverage as descibed in paragraph
C and you wiD be charJed the "full tort" premium. , wish to choose the "limited tort"
option descibed In paralraph I\: {If ,
Sllnaturtl Une I. ~#/-'- V.' (l~ /5/q911
T Named Insu I Date I
C. "full Tort" Option, The laws of the Commonwealth of Pennsylvania also live you the
rilht to choose a form of Insurance under which you maintain an unrestricted rilht for
you and the members of your household to s~k financial compensation for Injuries
au sed by other drivers. Under this form of Insurance. you and other household members
covered under this policy may seek recovery for all medial and other out.of,pocket
expenses and may also seek financial compensation for pain and sufferinl and other
nonmonetary damages as a result of Injuries caused by other drivers. The annual premium
for basic coverage Is 5 1,462.00 which refl.ects the coverages and amounts of coverage
you have now. The annual premium for basic coverage as required by law under this
"full tort" option Is S 1,316.00.
Additional coverages under this option are available at additional cost.
D. If you wish to chMse the "full tort" option described In paragraph C. you may sfln this
notice where Indicated below and retum It. However, Ii you do not sign and retum this
nt'llce. you will be consld.ered to have chosen the "full tort" coverage as described In
paragraph C and you will be charged the "full tort" premium. ~ ~ ~~ ~~\.... g,
Signature Line 11. . ~ - ,." ~ ~
"amed Insured Date ,'~ ", \.
'... \;:,
E. You may contact your insurance agent. broker or company to discuss the cost of other '.'oJ "'4~
coverages. ..... q'
JU",
"20 "990
1.998
;~~11 ;,90