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HomeMy WebLinkAbout07-0995i * t w IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORP., Civil Action - In Law Plaintiff, No. 0.1 , QQS VS. ARBITRATION SHAUN A. KONETSCO, Defendant. COMPLAINT 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 MUOVED 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 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. PLEASE GIVE THIS PAPER TO YOUR INSURANCE CARRIER n4mDIATELY. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA. 17013-3387 (717) 249-3166 (800) 990-9108 r IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORP., Civil Action - In Law Plaintiff, No. 97 9 9,S- e V S. : ARBITRATION SHAUN A. KONETSCO, Defendant. COMPLAINT 1. This is an action by Plaintiff, PPL ELECTRIC UTILITIES CORP. to recover damages from Defendant arising out of a vehicular collision which caused damage to property owned by Plaintiff. 2. PPL ELECTRIC UTILITIES CORP. is a Pennsylvania corporation duly organized and existing and licensed to do business as a public utility under the laws of the Commonwealth of Pennsylvania with a principal place of business at Two North Ninth Street, Allentown, Pennsylvania, 18101. 3. Defendant, SHAUN A. KONETSCO, is an adult individual residing at 922 Harrisburg Pike, Carlisle, Pennsylvania, 17013. 4. At all times relevant hereto, Plaintiff was engaged in the business of producing, furnishing, supplying and distributing utility service to persons and businesses who requested utility service in accordance with the Rate Schedules and General Rules and Regulations of Plaintiffs Tariff presently on file with the Public Utility Commission. COUNTI PPL ELECTRIC UTILITIES CORP. VS. SHAUN A. KONETSCO 5. Defendant, SHAUN A. KONETSCO, while operating a vehicle, damaged property owned by Plaintiff. 6. Defendant negligently operated the vehicle in that he/she: a) operated said vehicle and/or equipment at an excessive rate of speed under the circumstances; b) failed to have said vehicle and/or equipment under proper and adequate control; C) failed to keep a proper lookout; d) operated said vehicle and/or equipment in a reckless and careless manner; e) failed to keep vehicle and/or equipment in the proper lane of travel; f) failed to operate the vehicle and/or equipment within the posted speed limit or failed to operate the vehicle and/or equipment at a reasonable speed under the circumstances; g) failed to remain alert and attentive under the circumstances; h) operated the vehicle and/or equipment without due regard for the rights, safety and position of the plaintiff; i) operated the vehicle and/or equipment in a manner violating the statutes of the Commonwealth of Pennsylvania governing the operation of vehicles and/or equipment on public streets, highways and roadways; j) being negligent at the law; k) such other acts or omissions constituting carelessness, negligence and recklessness may be ascertained during discovery or developed at the time of trial. 7. Defendant struck and damaged a utility pole and wires owned and operated by PPL ELECTRIC UTILITIES CORP. at the vicinity of 1300 Millersville Road, Lancaster Township, Lancaster County, Pennsylvania, on or about October 7, 2005. 8. Defendant's actions or inaction as set forth above are the proximate cause of the damages as set for above and herein. 9. Plaintiff made demand on Defendant to repay the sums then due and owing to Plaintiff, but Defendant has refused to pay Plaintiff. 10. Plaintiff has been damaged in the amount of $9,042.64. WHEREFORE, Plaintiff PPL ELECTRIC UTILITIES CORP. demands judgment against the Defendant in an amount of $9,042.64, including costs, prejudgment and post judgment interest, punitive damages and delay damages as the law may allow. Respectfully DATED: February 12, 2007 KRZYWICK AXSSOCIJ.TES By: nth v P. I icki New H e, PA 18932 (215) 862-4390 GG Attorney for Plaintiff Attorney I.D. 23754 VERIFICATION Pursuant to Rule 1024 (c), I, ANTHONY P. KRZYWICKI, ESQ., verify that I am the attorney for PPL ELECTRIC UTILTIES CORP. in the within case; that the Plaintiff is not available within the time for serving the foregoing to provide its Verification; that I am sufficiently familiar with the facts set forth in the foregoing Pleading to take this Verification; and that such facts are true and correct to the best of my knowledge, information and belief, based upon business records and matters of public record. I understand that the statements herein are made subject to the penalties of 18 Pa. Consol. Stat. Ann. § 4904 relating to unworn falsification to authorities. Dated: February 12, 2007 IJ n _w rv Q N E5 N CC) r'n-n LIO rn KRZYWICKI & ASSOCIATES Anthony P. Krzywicki, Esq. P.O. Box 505 New Hope, PA 18938 (215) 8624390 Attorney for Plaintiff Attorney I.D. 23754 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORP., Plaintiff, VS. SHAUN A. KONETSCO, Defendants. Civil Action - In Law No. 07-995 CIV. TERM ARBITRATION PRAECIPE TO REINSTATE COMPLAM TO THE PROTHONOTARY: Kindly reinstate the Complaint against the Defendant(s) in the above-captioned Civil Action for an additional thirty (30) days. DATED: March 12, 2007 BY: KRZYWICKI & ASSOCIATES ?'GI b h ? O O ? ,? ? r -? , ? ? --3 iY n .?.-_ 'y. ?L - 'xr .? _ .-? (.sue SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2007-00995 P +COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PPL ELECTRIC UTILITIES CORP VS KONETSCO SHAUN A R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: KONETSCO SHAUN A but was unable to locate Him in his bailiwick deputized the sheriff of LANCASTER serve the within COMPLAINT & NOTICE He therefore County, Pennsylvania., to On May 1st , 2007 this office was in receipt of the attached return from LANCASTER Sheriff's Costs: So answers: J Docketing 18.00 Out of County 9.00 Surcharge 10.00 P. Thomas 1ne Dep Lancaster Co 39.41 Sheriff of Cumberland County Postage .63_ '01 7 7 . 0 4 ?5 1100 05/01/2007 KRZYWICKI & ASSOCIATES Sworn and subscribe to before me this day of A. D. SHERIFF'S OFFICE 50 NORTH DUKE STREET, P.O. BOX 83480, LANCASTER, PENNSYLVANIA 17608-3480 a (717) 299-8200 1 3 DE PLEASE TYPE OR PRINT DO NOT DETACH ANY t 2 COURT NUMBER 07-995 civil ,Y. H rn n x O n O 4 TYPE OF WRIT OR COMPLAINT Shaun A. Konetsco Notice and Complaint SERVE 5 NAME OF INDIVIDUAL. COMPANY. CORPORATION. ETC. TO BE SERVED Shaun A. Konetsco 6 ADDRESS (Street or RFD, Apartment No., City, Boro• Twp., State and ZIP Code) AT 1609 Chadwick Circle Apt B Lancaster, PA 17603 7. INDICATE UNUSUAL SERVICE. 0 DEPUTIZE ? OTHER Cumberland Now, Marr-h 30 20 07 , I, SHERIFF OF4MMONOW COUNTY, PA., do hereby deputize the Sheriff of Lancaster County to execute this Writ c>r r n thereof according to law. This deputation being made at the request and risk of the plaintiff. $N ff NTV 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: e.unberland Please mail return of service to Cumberland County Sheriff. Thank You. NUTE UNLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching aoy property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before sheriff's sale thereof 9. SIGNATURE of ATTORNEY or other ORIGINATOR 10. TELEPHONE NUMBER [TI . DATE 12. SEND NOTICE OF SERVICE COPY TO NAME AND KR7,Y69ICKT & ASSOCIATES P.O. BOX 505 (This area must be completed if notice is to be SPACE BELOW FOR USE OF SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE 13 1 acknowledge receipt of the writ NAME of Authorized LCSO Deputy or Clerk 114 Date Received 15 Expiration/Hearing date or complaintas indicated above, JASE.F MICCICHE 717-390-2309 4/2/07 I 11/30/07 10 nulCuy %.en r rrT ana RE r uRN that I [Whave personally served, ? have legal evidence of service as shown in "Remarks", ? have executed as shown in "Remarks", the writ or complaint described on the individual, company, corporation, etc., at the address shown above or on the individual, company, cor- poration, etc., at the address inserted below by handing a TRUE and ATTESTED COPY thereof. 17. ? 1 hereby certify and return a NOT FOUND because I am unable to locate the individual, company, corporation, etc , named above. (See remarks below) 18 Name and title of individual served (if not shown above) (Relationship to Defendant) 1 g ? No Service See Remarks Below (No. 30) 20 Address of where served (complete only if different than shown above) (Street or RFD, Apartment No , City, Boro, Twp 21 Date of Service 22 Time State and Zin Cndet 23. ATTEMPTS to Miles Dep. Int. Date 7f 4 MAC 24. Advance Costs 25. Service Costs R 150.00 36,50 30. REMARKS: S.T.A.: 31. AFFIRMED and subscribed to before me this 34, day of Miles Dep. Int. j Date 26 Notary Cert 27 M AM _PW_ _6640- -??-?? EDST Dep.Int. Date Miles Dep. lnt. Date Miles Dep.lnt. S ge/N.F. 28 Total Costs 29 COST DUE OR REFUN CIL cz Le, - L4 -;) SQ? )"Et of ?• 36 37, 1%j I Prothonotary/Deputy/Notary Public SHERIFF OF LANCASTER COUNTY MY COMMISSION EXPIRES 1. WHITE - Issuing Authority 2. PINK - Attorney 3. CANARY - Sheriffs Office 4. BLUE - Sheriffs Office SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN PPL Electric Utilities Corp 1 3 wd ?- j8v coo, SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-00995 P GOMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PPL ELECTRIC UTILITIES CORP VS KONETSCO SHAUN A R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT KONETSCO SHAUN A but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT , KONETSCO SHAUN A 922 HARRISBURG PIKE , NOT FOUND , as to CARLISLE, PA 17013 PER DEFENDANT'S GRANDMOTHER, HE HAS NEVER LIVED AT GIVEN ADDRESS. BELIEVED TO BE LIVING IN LANCASTER AREA. Sheriff's Costs: So answer Docketing 18.00 Service 5.76 Not Found 5.00 R. Thoma c.___. Surcharge 10.00 Sheriff of Cumberland County 00 3`DR161 -? 38.76 KRZYWICKI & ASSOCIATES 03/01/2007 Sworn and Subscribed to before me this day of , A. D. , ' 2428PD In the Court of Common Pleas of CUMBERLAND County, Pennsylvania PPL Electric Uti sties Corp. Plaintiff vs SHAUN A. KONETSCO Defendant Civil Action - In Law No. 07-995 ARBITRATION PRAECIPE FOR JUDGMENT AGAINST DEFENDANT FOR FAILURE TO PLEAD To the Prothonotary: COUNT 1 PPL Electric Ut1-1 es Corp. vs. SHAUN A. KONETSCO Kindly enter default judgment in favor of Plaintiff, PPL Electric Utilities Corp. and against Defendant, SHAUN A. KONETSCO for failure to plead to Plaintiff's Complaint as follows: Amount Past Due: $ 2300.00 Fees: $ 2300.00 Court Costs: $ 55.50 Service Costs: $ 100.00 TOTAL $ 4755.50 together with interest thereon from the date of judgment forward and all costs of this action. 2428PD I hereby certify to the best of my knowledge and belief as follows: 1. The true and correct address of the Plaintiff, PPL Electric Utilities Corp., is 2 North 9th Street, Allentown, PA 18101. 2. The true and correct address of the Defendant, SHAUN A. KONETSCO, is 1609 Chadwick Cir. Apt B, Lancaster, LANCASTER County, PA 17603. KrzywicX1 aid As5.G<Iates DATED: July 17, 2007 By: A ho P. yw 9 rth gan oad Bo 05 New Ho e, PA 18938 215-862-4390 Attorney for Plaintiff Attorney I.D. 23754 13 Q S; (? D ns -r, Q ?? SHERIFF'S OFFICE 50 NORTH, DUKE STREET, P.O. BOX 83480, LANCASTER, PENNSYLVANIA 17808-3480 • (717) 299-8200 G SHERIFF SERVICE PLEASE TYPE OR PRINT LEGIBLY. PROCESS RECEIPT, and AFFIDAVIT OF RETURN DO NOT DETACH ANY COPIES. 1 PLAINTIFF/S/ i PPL Electric Utilities Corp 07-995 civil 3 Shaun A. Konetsco 4 TYP Not t SERVE 5 NAME OF INDIVIDUAL. COMPANY. CORPORATION. ETC.. TO BE SERVED Shaun A. Konetsco 6 ADDRESS (Street or RFD, Apartment No.. City, Boro, Two.. State and ZIP Code) AT 1609 Chadwick Circle Apt B Lancaster, PA 17603 7 INDICATE UNUSUAL SERVICE: 0 DEPUTIZE O OTHER Cumberland Now,, Marsh 30 20 07 , 1, SHERIFF OF IMISPOW COUNTY, PA., do hereby deputize the Sheriff of Lancaster __ County to execute this Writ t r thereof according to law. This deputation being made at the request and risk of the plaintiff. „ r1F Mrs 6. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: timberland Please mail return of service to Curiberland County Sheriff. Thank you. NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.S. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave some without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before sheriff's sale thereof 9. SIGNATURE of ATTORNEY or other ORIGINATOR 10. TELEPHONE NUMBER 11. DATE 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed It notice is to ba malted) KR7,YVJICKI & ASSOCIATES P-0. BOX 505 SPACE BELOW FOR USE OF SHERIFF ONLY- DO NOT WRITE BELow THIS LINE 13 1 acknowledge receipt of the writ NAME of Authorized LCSO Deputy or Clerk 14. Date Received 15 Expiration/Hearing date or complaint as indicated above. JACt?TE MICCICHE 717-390-2309 I 4/2/07 ( 4/30/07 16. 1 hereby CERTIFY and RETURN that 134ave personally served, 0 have legal evidence of service as shown in "Remarks", C7 have executed as shown in "Remarks", the writ or complaint described on the individual. company, corporation, etc., at the address shown above or on the individual, company. cor- poration, etc.. at the address inserted below by handing a TRUE and ATTESTED COPY thereof. 17. 01 hereby Certify and return a NOT FOUND because I am unable to locate the individual, company, corporation. etc., named above. (See remarks below) 18 Name and title of individual served (if not shown above) (Relationship to Defendant) 18 0No8ervio ses Pmhm ks Below Ilia 30) 20 Address of where served (complete only if different than shown above) (Street or RFD, Apartment No , City, Boro,Twp 21 Date at Service 22 Time State and Zip Code) . M E 23. ATTEMPTS to Miles Dep. Int. Date Mites 000. Int. Date Miles Dep. Int. Date Miles Dep. Int. Date Miles Dap. Int. ,.. .....____ n_... 15r Cen.ira (:Wars 9R Netarv Cert 27 Mitesae/PAetaae/N F. 28 Total Cos Its 29. CO>fT DyE OR REFUND R S.T.A 31. AFFIRMED and subscribed to before me this 34 day of 37 Arnthnnat&rvj0aoutv1N0tarv Public 150.001 36.50 CG' 1. WHITE - Issuing Authority 2. PINK - Attorney 3. CANARY - Sheriffs Office 4. BLUE - Sheriff's Office SHERIFF'S RETURN - OUT OF COUNTY 'CASE NO: 2007-00995 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PPL ELECTRIC UTILITIES CORP VS KONETSCO SHAUN A R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: KONETSCO SHAUN A but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of LANCASTER County, Pennsylvania, to serve the within COMPLAINT & NOTICE On May 1st , 2007 , this office was in receipt of the attached return from LANCASTER Sheriff's Costs: So answers: Docketing 18.00 Out of County 9.00 Surcharge 10.00 K. Thomas lne Dep Lancaster Co 39.41 Sheriff of Cumberland County Postage .63 77.04 05/01/2007 KRZYWICKI & ASSOCIATES Sworn and subscribe to before me this day of A. D. 2428PD In the Court of Common Pleas of CUMBERLAND County, Pennsylvania PPL E ectric Utilities Corp. Plaintiff Civil Action - In Law vs SHAUN A. KONETSCO Defendant No. 07-995 ARBITRATION The undersigned hereby certifies that written notice of intention to file a praecipe for entry of judgment by default against the defendant, SHAUN A. KONETSCO, in this matter was mailed to the defendant after the default occurred and at least ten days prior to the filing of the praecipe for entry of judgment pursuant to Pa. R.C.P. 237.1. True and correct copies of that notice is attached hereto and made a part of this certification. Krzywicki,a6d ciates DATED: July 17, 2007 By: 49"North S anj? P. 0. Box 05 New Hope, PA 18938 215-862-4390 Attorney for Plaintiff Attorney I.D. 23754 O O ? A 0 7> 00 2428PD In the Court of Common Pleas of CUMBERLAND County, Pennsylvania PPL Electric Utilities Corp. Plaintiff Civil Action - In Law vs SHAUN A. KONETSCO Defendant No. 07-995 ARBITRATION NOTICE TO: SHAUN A. KONETSCO 1609 Chadwick Cir. Apt B Lancaster, PA 17603 Date: June 12, 2007 You are in default because you have failed to enter a written appearance personally or by an attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 (717) 249-3166/(800) 990-9108 Krzywicki/, nd By. ?.r orth uga 0. Bo 505 New Hope, PA 215-862-4390 Attorney for Attorney I.D. ates z is i Road 18938 Plaintiff 23754 Q3 00 2428PD In the Court of Common Pleas of CUMBERLAND County, Pennsylvania PPL E ectric Utilities Corp. Plaintiff Civil Action - In Law vs SHAUN A. KONETSCO Defendant (s) No. 07-995 AFFIDAVIT OF SERVICE , STATE OF SS. COUNTY OF I, Anthony P. Krzywicki, Attorney for Plaintiff, served a true and correct copy of the Notice of Intention to Take efault pursuant to Pa. R.C.P. 237.1 on Defendant(s), by first mail on 06/12/2007. c/l Ant on Kr icki A o ey fo lain f, K wicki nd Associates P.O. Box 505 New Hope, PA 18938 PA ID# 23754 215-862-4390 COMMONWEALTH OF PENNSYLVAtYtA NOTARIAL SEAL Catherine Ross-Macaluso, Notary Public ;S*bury Twp„ Bucks County Commission Expires March 30, 2010 SWORN TO AND SUBSCRIBED ? ro 2428PD In the Court of Common Pleas of CUMBERLAND County, Pennsylvania PPL Electric Uti sties Corp. Plaintiff Civil Action - In Law vs SHAUN A. KONETSCO Defendant No. 07-995 ARBITRATION AFFI VIT//O,,F NQ®N,-MILITARY SERVICE STATE OF 4MMEMOWSW V?l ss. COUNTY OF I, Anthony P. Krzywicki, being duly sworn according to law, deposes and state that I am a representative of PPL Electric Utilities Corp., 2 North 9th Street, Allentown, PA 18101, Plaintiff herein, and as such state the following: 1. The defendant, SHAUN A. KONETSCO, is not, to my knowledge, in the military or naval service of the United States or its allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of 1940, as amended. 2. The defendant, SHAUN A. KONETSCO, is more than 18 years of age and currently resides at 1609 Chadwick Cir. Apt B, Lancaster, PA 17603. 3. I have ascertained the above informat' y personal investigation and make this affidavit with aut ority? Swo me COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Catherine Ross-Macaluso, Notary Pubk Solebury Twp., Bucks County Commission Expires March 30, 2010 c C? 8s ? m to > 4. IQ( N t • OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse * Carlisle, PA 17013 Curtis R. Long Prothonotary TO: SHAUN A. KONETSCO 1609 Chadwick Cir. Apt B Lancaster, PA 17603 2428PD In the Court of Common Pleas of CUMBERLAND County, Pennsylvania PPL E ectric Uti sties Corp. Plaintiff Civil Action - In Law vs SHAUN A. KONETSCO Defendant No. 07-995 ARBITRATION NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. p1* 016, A007 Curtis R. Long Prothonotary (XX) Judgment by Default DKB ( ) Money Judgment (. ( ) Judgment in Replevin ( ) Judgment for Possession ( ) Judgment on Award of Arbitration ( ) Judgment on Verdict ( ) Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEY FOR THE FILING PARTY: Anthony P. Krzywicki Krzywicki and Associates 49 North Sugan Road P.O. Box 505 New Hope, PA 18938 215-862-4390 Attorney I.D. No.23754 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORP , Civil Action - In Law Plaintiff, No. 07-995 vs. ARBITRATION SHAUN A. KONETSCO, Defendant. ' N H AFFIDAVIT OF MOTOR VEHICLE JUDGMENT STATE OF PENNSYLVANIA) ss.: COUNTY OF BUCKS j I, ANTHONY P. KRZYWICKI, Attorney for Plaintiff, verify that the above referenced caption is due to a motor vehicle accident. Anth v P. Kr w it Atto ney PI 2 t KRZ WI & ASSO TES, P.C. P.O. Boy: 505 New Hope, PA 18938 (215) 862-4390 PA Attorney ID 9237.54 Sworn to and subscribed before me this day of 2013. NOTARY PUBLIC. sso