Free Complaint - District Court of Delaware - Delaware

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KENNETH REYNOLDS
And his wife :
JOAN CHIEN :
v. 2
z CIVIL Acriow No. O”|- F] i, @$*42}
STATE FARM INSURANCE COMPANIES. ; y _
One State Farm Drive ._ pre iii "
Frederick MD 21709 : D .;.Q. Lg
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Plaintiffs, Kenneth Reynolds and Joan Chien, move this court, ..1..e¢:..;—,;-._...wT.l
Pennsylvania Rule of Clvll Procedure 3146(a)(1), for a hearing and assessment ofthe {.3 O
LIABILITY ofthe insurer under policy number ln effect on July 3, 2006and aver the
following:
l. Plaintiffs obtained a valid judgment against uninsured Defendants Viking
Transport, Ine., Frank Bueno, and Jorge Gonzales (“Defendants") ln the Court of
Common Pleas of Philadelphia County, Pennsylvania after suing for damages for sn
· accident occurring in Philadelphia Pennsylvania on July 3, 2002..
2. At all times, plaintiffs were insured by defendant under a Delaware
automobile insurance policy believed to be number 41734-F14·-08
3, Despite repeated timely demand. defendant refused to provide the
statutory coverage of Uninsured Motoridl coverage which could be as much as $300,QOO
per plalntifi
WHEREFORE, Plaintiflil MEN tbngghlaialonorable Court schedule a hearing to
assess damages pursuant to the insurance polioyor permit reclaim for damages
under DIVERSITY jurisdiction.
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m¤»=:—o5-geoéiaee JAQ7-evqOO176-SLR Document 23 Filed O4/05/2007 Page 2 of 3
vehicle for uninsured motorist coverage; yet when multiple vehicles on the
same policy have uninsured motorist coverage, only the highest amount of
coverage for any vehicle on the same policy is permitted to be paid out; in
other words, one need only pay for one vehicle to have maximum coverage
to have maximum coverage on all vehicles on the policy so long as any
lessor coverage (but not N0 coverage) ls purchased; and therefore collecting
additional fees for maximum coverage on all other vehicles on the same
policy once maximum uninsured motorist benefits are purchased for one
- vehicle on the same policy. Purchasing any level cf uninsured motorist
benefits affords no greater uninsured motorist coverage amounts than if the
minimal amount of coverage is purchased for all other vehicles on the same
policy so long as all vehicles on the policy have some type of uninsured
motorist coverage and one vehicle on the policy has maximum coverage.
WHEREFORE, A CLASS OF DELAWARE MOTORISTS IS PAYING HIGHER
PREMIUMS THAN NECESSARY AND GETTING NO GREATER BENEFIT THAN
IF THEY PURCHASED LESSER COVERAGE FOR ALL BUT ONE VEHICLE ON
THEIR POLICY WITH DEFENDANT.
U1RE
- Attorney for Plaintiffs
2619 West Chester Pike
Broomall, Pa 19008
(610) 356-3900
PA. Attomey Id # 33726
2

Q P R _ Q 5 _ 2 E, Q ?Cg,ge: ],:Q7;q.y-00176-SLR Document 23 Filed O4/05/2007 Page 3 of 3
` l U A www PENNSYLVANIA UF"'-
KENNETH REYNOLDS and JOAN CHIBN:
Plaintiffs :
z No. 06—CV-03013
v, 1
STATE FARM INSURANCE COMPANY
Defendant :

TO THE CLERK OF COURT:
The undersigned counsel of record in this case hereby accepts service of
Plaintiff‘s Complaint on this day of September, 2006.
BBNNET. BRICKLIN & SALTSBURG LLP
BY:
LOUIS E. BRICKLIN, ESQUIRE
LD. NO. 20281
1601 Market Street, 16* Floor
Philadelphia, Pa 19103
(215) 5614300