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Home My WebLink About08-7121IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORP., Plaintiff, VS. MARK M. GOULD and MICHELLE M. GOULD a/k/a Civil Action-In Law No. dg - ?id i ARBITRATION C,vi ? Lek MICHELE M. HINKLE, his wife, as Legal Guardians for their son, NATHAN MICHAEL HINKLE, Defendants 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 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 Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013-3387 (717) 249-3166 (800) 990-9108 L_ C IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORP., Plaintiff, Civil Action-In Law No. 0 P- '71a l C.uit -? vs. MARK M. GOULD and MICHELLE M. GOULD a/k/a MICHELE M. HINKLE, his wife, as Legal Guardians for their son, NATHAN MICHAEL HINKLE, Defendants. ARBITRATION COMPLAINT 1. This is an action by Plaintiff, PPL ELECTRIC UTILITIES CORP. to recover damages from Defendants arising out of damage to property owned by PPL ELECTRIC UTILITIES CORP. 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, MARK M. GOULD, is an adult individual residing at 8 Mayberry Lane, Mechanicsburg, Pennsylvania, 17050. 4. Defendant, MICHELLE M. GOULD A/K/A MICHELE M. HINKLE, his wife, is an adult individual residing at 8 Mayberry Lane, Mechanicsburg, Pennsylvania, 17050. 5. NATHAN MICHAEL HINKLE, is a minor residing with his parents and legal guardians, MARK M. GOULD and MICHELLE M. GOULD A/K/A MICHELE M. HINKLE at 8 Mayberry Lane, Mechanicsburg, Pennsylvania, 17050. 6. 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. MARK M. GOULD and MICHELLE M. GOULD A/K/A MICHELE M. HINKLE, his wife, as Legal Guardians for their son, NATHAN MICHAEL HINKLE 7. NATHAN MICHAEL HINKLE, a minor, while operating a vehicle, collided with and damaged property owned by Plaintiff. 8. NATHAN MICHAEL HINKLE, a minor, on or about March 1, 2008, damaged a utility pole and overhead facilities owned and operated by the Plaintiff in the vicinity of 72 Northview Drive, Mechanicsburg, Cumberland County, Pennsylvania. 9. Defendants, MARK M. GOULD and MICHELLE M. GOULD A/K/A MICHELE M. HINKLE, as Legal Guardians of NATHAN MICHAEL HINKLE, a minor under the age of 18 years, are vicariously responsible for the acts of their child. 10. Defendants did not exercise due care and did not take all reasonable steps to avoid damage or injury to property owned by PPL ELECTRIC UTILITIES CORP. 11. Defendants had a duty to protect Plaintiff's property. 12. Defendants damaged a utility pole and its overhead facilities owned and operated by Plaintiff. 13. Plaintiff made demand on Defendants to repay the sums then due and owing to Plaintiff, but Defendants have refused and continues to refuse to pay Plaintiff. 14. Plaintiff has been damaged in the amount of $2,512.56. WHEREFORE, Plaintiff PPL ELECTRIC UTILITIES CORP. demands judgment against the Defendants in an amount of $2,512.56, together with pre judgment and post judgment interest, punitive damages, and delay damages as the law may allow. DATED: December 1, 2008 Respectfully submitted, KRZYWICKI & ASS6MTES By: Anthony P.O. Ww Ho , PA 18938 (215 62-4390 Attorney for Plaintiff Attorney I.D. 23754 W r ? t?,y, r 7 -Tl 0 ? c SHERIFF'S RETURN - REGULAR 1 CASE NO: 2008-07121 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PPL ELECTRIC UTILITIES CORP VS GOULD MARK M ET AL RONALD KERR , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon GOULD MARK M the DEFENDANT at 0013:11 HOURS, on the 6th day of December 2008 at 8 MAYBERRY LANE MECHANAICSBURG, PA 17050 by handing to MARK M GOULD DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.10 Affidavit .00 Surcharge 10.00 C?- .00 ,/ 36.10 Sworn and Subscibed to before me this day of , So Answers: Th s 1ne 12/08/2008 KRZWICKI & ASSOC By: ? (?-- Deputy Sheriff A. D. 1 CASE NO: 2008-07121 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PPL ELECTRIC UTILITIES CORP VS GOULD MARK M ET AL RONALD KERR , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon GOULD MICHELLE M AKA HINKLE MICHELLE M the DEFENDANT , at 0013:11 HOURS, on the 6th day of December , 2008 at 8 MAYBERRY LANE MECHANAICSBURG, PA 17050 by handing to MARK M GOULD ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 f? ?Ed?b p' ? 16.00 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 12/08/2008 KRZWICKI & ASSOC By. [Z-- Deputy Sheriff A. D. IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORP., Civil Action-In Law Plaintiff, No. 08-7121 Civil Term vs. MARK M. GOULD and MICHELLE M. GOULD a/k/a MICHELE M. HINKLE, his wife, as Legal Guardians for their son, NATHAN MICHAEL HINKLE, Defendants. ARBITRATION PRAECIPE TO SETTLE DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark this matter Settle, Discontinue, and End against the Defendants, without prejudice upon payment of your costs only. KRZYWICKI & ASSOCIATES DATED: March 26, 2009 BY: A:f fhony P. P.O. Box New Hope, PA 18938 (215)862-4390 Attorney for Plaintiff Attorney I.D. 23754 r Y? I ZY