HomeMy WebLinkAbout11-0247IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORPORATION,
vs.
STANLEY G. BARNES and
ILONA YVONNE BARNES a/k/a
ILONA YVONNE KELLEY,
Plaintiff,
Defendants.
COMPLAINT
Civil Action - In Lannw
No. (l - aa7 l.~iv i) 1~.tTM
ARBITRATION
NOTICfi
You have been sued in Court. Tf you wi:;h 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 MA.Y
PROCEED WITHOUT you and a judgment may k~e 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
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IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORPORATION,
Plaintiff, Civil Action - In Law
vs. No.
STANLEY G. BARNES and
ILONA YVONNE BARNES a/k/a
ILONA YVONNE KELLEY,
Defendants
COMPLAINT
ARBITRATION
1. This is an action by Plaintiff, PPL ELECTRIC UTILITIES CORPORATION, to
recover damages from Defendant arising out of a vehicular collision which caused damage to
property owned by Plaintiff.
2. PPL ELECTRIC UTILITIES CORPORATION 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, STANLEY G. BARNES, is an adult individual residing at 301 Brook
Meadow Drive, Mechanicsburg, Pennsylvania, 17050.
4. Defendant, ILONA YVONNE BARNES A/K/A ILONA YVONNE KELLEY, is
an adult individual residing at 301 Bi•ook Meadow Drive, Mechanicsburg, Pennsylvania, 17050.
5. At all times relevant hereto, Plaintiff was engaged in the business of 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 CORPORATION VS. STANLEY G. BARNES
6. Defendant, STANLEY G. BARNES, while operating a vehicle, collided with and
damaged property owned by Plaintiff.
7. Defendant negligently operated the vehicle in that he/she:
a) operated said vehicle while under the influence of alcohol.
b) operated said vehicle at an excessive rate of speed under the
circumstances;
c) failed to have said vehicle under proper and adequate control;
d) failed to keep a proper lookout;
e) operated said vehicle in a reckless and careless manner;
f) failed to keep vehicle in the proper lane of travel;
g) failed to operate the vehicle within the posted speed limit or failed to
operate the vehicle at a reasonable speed under the circumstances;
h) failed to remain alert and attentive under the circumstances;
i) operated the vehicle without due regard far the rights, safety and position
of the Plaintiff;
j) operated the vehicle in a manner violating the statutes of the
Commonwealth of Pennsylvania governing the operation of vehicles on
public streets, highways and roadways;
k) being negligent at the law; and
1) such other acts or omissions constituting carelessness, negligence and
recklessness may be ascertained during discovery or developed at the time
of trial.
8. Defendant, on or about March 10, 2009, struck and damaged a utility pole and
overhead facilities owned and operated by PPL ELECTRIC UTILITIES CORPORATION at the
vicinity of Mulberry Drive and Woods Drive, Silver Spring Township, Cumberland. County,
Pennsylvania.
9. Defendant's actions or inactions as set forth above are the proximate cause of the
damages as set for above and herein.
10. Plaintiff made demand on Defendant to repay the' sums then due and owing to
Plaintiff, but Defendant has refused to pay Plaintiff.
11. Plaintiff has been damaged in the amount of $13,374.80, including costs and
attorney fees.
WHEREFORE, Plaintiff, PPL ELECTRIC UTILITIES CORPORATION, demands
judgment against the Defendant in an amount of $13,374.80, together with pre judgment and
post judgment interest, punitive damages and delay damages as the law may allow.
COUNT II
PPL ELECTRIC UTILITIES CORPORATION VS.
ILONA YVONNE BARNES A/K/A ILONA YVONNE KELLEY
12. Paragraphs 1 through 11 are incorporated as referenced as if fully set forth herein.
13. At all time relevant hereto, Defendant, ILONA YVONNE BARNES A/K/A
ILONA YVONNE KELLEY, was the owner of the vehicle driven by Defendant, STANLEY G.
BARNES, that hit the active utility pole and overhead facilities.
14. At the time of the aforesaid accident, Defendant, ILONA YVONNE BARNES
A/K/A ILONA YVONNE KELLEY, was responsible for the actions of her agent, STANLEY G.
BARNES
15. The aforementioned damages were the direct and proximate result of the
negligence of Defendant, ILONA YVONNE BARNES A/K/A I:LONA YVONNE KELLEY,
including negligent acts and/or omissions of Defendant as performed individually and/or by and
through others permitted to drive their vehicle more specifically described as follows:
a) negligently entrusting the aforesaid vehicle to Defendant, STANLEY G.
BARNES;
b) negligently and carelessly failing to properly and adequately supervise and/or train
Defendant, STANLEY G. BARNES, in the operation of his/her vehicle;
c) negligently and carelessly failing to properly supervise the operation and
control of said vehicle;
d) negligently and carelessly failing to act with due care and regard for the
safety of others on the streets and highways;
e) violating the ordinances and the statutes of the Commonwealth of
Pennsylvania governing safe operation of motor vehicles on the streets and
highways; and
f) otherwise failing to exercise reasonable care under the circumstances.
16. As a direct and proximate result of the negligence of Defendant, ILONA
YVONNE BARNES A/K/A ILONA YVONNE KELLEY, Plaintiff sustained damages as
described above.
17. Plaintiff has been damaged in the amount of $13,374.80, including costs and
attorney fees.
WHEREFORE, Plaintiff, PPL ELECTRIC UTILITIES CORPORATION, demands
judgment against the Defendant in an amount of $13,374.80, together with pre judgment and
post judgment interest, punitive damages and delay damages as the law may allow.
Respectfully submitted,
KRZYWICKI & ASSOCIATES, P.C.
DATED: December 20, 2010
By:
Attorney for 1
P.O. Bax 505
New Hope, PA 18938
(215) 8tS2-4390
PA Attorney ID No. 23754
VERIFICATION
Pursuant to Rule 1024 (c), I, ANTHONY P. KRZYWICKI, ESQUIRE, verify that I am
the attorney for Plaintiff, in the within case; that the appropriate officers of the plaintiff are not
available within the time for serving the foregoing to provide their 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 the company's 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
unsworn falsification to authorities.
Dated: December 20, 2010
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORPORATION,
vs.
STANLEY G. BARNES and
ILONA YVONNE BARNES a/k/a
ILONA YVONNE KELLEY,
Plaintiff,
Defendants.
Civil Action - In Law
No. 11-247 Civil Term
ARBITRATION
-
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PRAECIPE TO REINSTATE COMPLAINT
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 23, 2011
BY:
KRZYWICKI & A
ey fo mtiff ?
P.O. Bo 5
0 New Hope, PA 18938
(215)862-4390
Attorney I.D. 23754
TES, P.C.
Cl:? 1 ar?7 3
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IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORPORATION,
Plaintiff, : Civil Action -In Law
vs. No. 11-247 Civil Term
STANLEY G. BARNES and : ARBITRATION
ILONA YVONNE BARNES a/k/a 4
ILONA YVONNE KELLEY, Cz
• T"r1 ,�
Defendants. -
- =
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Kindly reinstate the Complaint against the Defendant(s)in the above-captioned Civil Action
for an additional thirty (30)days.
KRZYWICK SOCIATES,P.C.
DATED: April 11, 2013
BY:
Antho r i ,Esquire
me 'ntiff '
P.O. Box
New Hope, PA 18938
(215)862-4390
Attorney I.D. 23754
011,15 PI) ATH
0110a3a
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IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILTT'LES CORPORATION, _
Plaintiff, Civil Action- In Law
vs. _ No. 11-247 Civil Term
STANLEY G. BARNES and ARBITRATION_
IL ONA YVONNE BARNES aikla
ILONA YVONNE KELLEY,
Defendants. <rr
AFFIDAVIT OF SERVICE
SI'N'II OPPENNSYLVAMA ) -
C IT",Try Ot Hi tCKS � )
1, Anthony P. Kr'zywicki, Attorney for Plaintiff, served a true and correct copy of the
Complaint in the above matter, addressed to Defendants, Stanley G. Barnes and Ilona Yvonne
Barnes afkla Ilona Yvonne Kelley, at their last known address, which is 17735 Norwood Road,
Sandy Spring,, Maryland, 20860, by Certified Mail, Return Receipt Requested, under the
exclusive taro* and custody April 29, 2013 and by Certificate of Mailing on May 1, 2013. A
copg of the USPS receipts are annexed hereto and made a pan hereof.
KRZYWLC SOCIATES,P.C.
By:
nthony , Esquire
Alto f tiff
Box
New H 18938
Attorney ti.) No 23754
(215) 862-4390
Sworn to before me this
day of )hn 2013_
w--
NOTARY T RY PU� BBLIC
NOTARIAL SEAL
AMY M GLASGOW
Notary Public
NEW HOPE SGRO..SUCKS COUNTY
My Cammis8ion EIPints Mar 1A.2016
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IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORPORATION, :
Plaintiff, • Civil Action - In Law
vs. • No. 11-247 Civil Term
•
STANLEY G. BARNES and ARBITRATION ==
ILONA YVONNE BARNES a/k/a •
T t
ILONA YVONNE KELLEY, •
•
(51
Defendants.
v
PRAECIPE FOR JUDGMENT AGAINST !✓
DEFENDANT FOR FAILURE TO PLEAD
To the Prothonotary:
COUNT I
PPL Electric Utilities Corporation vs.
Stanley G. Barnes and Ilona Yvonne Barnes a/k/a Ilona Yvonne Kelley
Kindly enter Default Judgment in favor of Plaintiff, PPL Electric Utilities Corporation,
and against Defendants, Stanley G. Barnes and Ilona Yvonne Barnes a/k/a Ilona Yvonne Kelley,
for failure to plead to Plaintiff's Complaint as follows:
Amount Due: $ 9,832.80
Court Fees: $ 92.00
Service Costs: $ 150.00
TOTAL: $ 10,074.80
together with interest thereon from the date of judgment forward and all costs of this action.
t11D5 Sa
Ck / / o( '(
1 \cs.il'' ALGII
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 Corporation, is
Two North Ninth Street, Allentown, Pennsylvania, 18101.
2. The true and correct address of the Defendant, Stanley G. Barnes, is 17735 Norwood
Road, Sandy Spring, Maryland, 20860.
3. The true and correct address of the Defendant, Ilona Yvonne Barnes a/k/a Ilona
Yvonne Kelley, 17735 Norwood Road, Sandy Spring, Maryland, 20860.
KRZYWICKI& : SOCIATES, P.C.
Dated: July 2, 2013
By
Anthon zywic.', s "re
49 ■ •rth , ga ' oad
'.O. B.
New Hope, PA 18' 8
(215) 862-4390
Attorney for Plaintiff
Attorney I.D. No. 23754
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORPORATION, :
Plaintiff, : Civil Action - In Law
vs. • No. 11-247 Civil Term
•
STANLEY G. BARNES and • ARBITRATION
ILONA YVONNE BARNES a/k/a :
ILONA YVONNE KELLEY, :
•
Defendants. :
The undersigned hereby certifies that written notice of intention to file a Praecipe for Entry of
Judgment by default against the Defendants, Stanley G. Barnes and Ilona Yvonne Barnes a/k/a
Ilona Yvonne Kelley, in this matter was mailed to the Defendant after the default occurred and at
least ten (10) 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 those notices are attached hereto and made a part of
this Certification.
KRZYWICKI& ASSOCIATES, P.C.
Dated: July 2, 2013
B
Antho ' , cki squire
A . ne, • • ainti "
49 No Sugan ' •ad
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 CORPORATION, :
Plaintiff, • Civil Action - In Law
vs. : No. 11-247 Civil Term
•
STANLEY G. BARNES and • ARBITRATION
ILONA YVONNE BARNES a/k/a
•
ILONA YVONNE KELLEY, :
Defendants. :
NOTICE
TO: Mr. Stanley G. Barnes
17735 Norwood Road
Sandy Spring, MD 20860
a
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
(717) 249-3166
(800) 990-9108
KRZYWICKI& AS • IATES, P.C.
DATE: June 19, 2013
BY:
An ony P.10111 .. ir=
P •. Box .
- . -ope, 3:
(215) 862 390
Attorney I.D. 23754
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITLFS CORPORATION, :
Plaintiff, • Civil Action - In Law
vs. • No. 11-247 Civil Term
•
•
STANLEY G. BARNES and : ARBITRATION
ILONA YVONNE BARNES a/k/a :
•
ILONA YVONNE KELLEY,
•
Defendants. :
NOTICE
TO: Ms. Ilona Yvonne Barnes a/k/a Ilona Yvonne Kelley
17735 Norwood Road
Sandy Spring, MD 20860
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
(717) 249-3166
(800) 990-9108
KRZYWICKI : ° • IATES, P.C.
DATE: June 19, 2013
BY: .7
A-thony P. . z • ' • 're
'.O. Bo 0
- op- ' • 89
(215) 86- - 90
Attorney I.D. 23754
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORPORATION, :
Plaintiff, : Civil Action - In Law
vs. : No. 11-247 Civil Term
•
STANLEY G. BARNES and • ARBITRATION
•
ILONA YVONNE BARNES a/k/a
ILONA YVONNE KELLEY,
Defendants. :
AFFIDAVIT OF SERVICE
STATE OF PENNSYLVANIA)
ss.:
COUNTY OF BUCKS )
I, ANTHONY P. KRZYWICKI, Attorney for Plaintiff, served a true and correct copy of
the Notice of Intention to Take Default pursuant to PA. R.C.P. 237.1 on Defendant(s), by First
Class Mail, under the exclusive care and custody of the United St. - 'ost.1 Service on June 19,
2013.
.4107
A ony P. y cki, Esqu.
• tome or P :mtiff
'WIC & • . " OCI• .' S, P.C.
P.O. Bo 05
NewHs. , 'A 18938
(215) 862-4390
PA. Attorney ID #23754
Sworn to and subscribed before me
this C day of .)(,31-11 , 2013.
N
NO FARY PUBLIC
NOTARIAL SEAL
AMY M GLASGOW
Notary Public
NEW HOPE BORO.,BUCKS COUNTY
My Commission Expires Mar 14,2016
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORPORATION, :
Plaintiff, • Civil Action - In Law
vs. No. 11-247 Civil Term
•
STANLEY G. BARNES and : ARBITRATION
•
ILONA YVONNE BARNES a/k/a
•
ILONA YVONNE KELLEY,
•
Defendants. :
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF PENNSYLVANIA )
ss.:
COUNTY OF BUCKS )
I, ANTHONY P. KRZYWICKI, being duly sworn, according to law, deposes and states
that I am a representatives of PPL Electric Utilities Corporation, the Plaintiff herein, and as such,
state the following:
1. The Defendants, Stanley G. Barnes and Ilona Yvonne Barnes a/k/a Ilona Yvonne
Kelley, are 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, Stanley G. Barnes, is more than 18 years of age and currently resides
at 17735 Norwood Road, Sandy Spring, Maryland, 20860.
3. The Defendant, Ilona Yvonne Barnes a/k/a Ilona Yvonne Kelley, is more than 18
years of age and currently resides at 17735 Norwood Road, Sandy Spring, Maryland, 20860.
4. I have ascertained the above information by personal '- estigation a : make this
Affidavit with due authority.
_.7 .......
Anth y P. Krz, 1 e
Sworn to and subscribed before me
this ' CC-1 day of ,Lai , 2013.
NO Y PUBLIC
NOTARIAL SEAL
AMY M GLASGOW
Notary Public
NEW HOPE BORO., BUCKS COUNTY
My Commission Expires Mar 14,2016
•
'o,L_ (-1 to rig
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY,PENNSYLVANIA
PPL ELECTRIC UTILITIES CORPORATION, :
Plaintiff, Civil Action - In Law
vs. : No. 11-247 Civil Term
STANLEY G. BARNES and ARBITRATION
ILONA YVONNE BARNES a/k/a E _
ILONA YVONNE KELLEY, • m {
rn
Defendants. : �, < '"
AFFIDAVIT OF SERVICE =: ?
STATE OF PENNSYLVANIA )
ss.:
COUNTY OF BUCKS
I, Anthony P. Krzywicki, Attorney for Plaintiff, served a true and correct copy of the
Complaint in the above matter, addressed to Defendants, Stanley G. Barnes and Ilona Yvonne
Barnes alk/a Ilona Yvonne Kelley, at their last known address, which is 17735 Norwood Road,
Sandy Spring, Maryland, 20860, by Certified Mail, Return Receipt Requested, under the
exclusive care and custody April 29, 2013 and by Certificate of Mailing on May 1, 2013. A
copy of the USPS receipts are annexed hereto and made a part hereof.
KRZYWIC • ' OCIA'1'ES,P.C.
By: ■ "'
• thony P. �� s••ire
Atto o ' iff
•. G. Bo ii5
New Hope, PA
Attorney ID No. 23754
(215) 862-4390
Sworn to before me this
day of , 2013.
a
NO Y PUBLIC
NOTARIAL SEAL
AMY M GLASGOW
Notary Public
NEW HOPE BORO., BUCKS COUNTY
My Commission Expires Mar 14,2016
•
cC
Mr Stanley (1 Barnes
17735 \ol-NA.ood Road
sandy pi nu ) -)rw,()
SENDER: COMPLETE THIS SECTION COMPLETE'THIS SECTION ON DELIVERY
Of Complete items 1,2,and 3.Also complete A. Signa
tern 4 if Restricted Delivery is desired. 1/ 1/144 .(if.L. - 0 Agent
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W Attach this card to the back of the mailpiece,
or on the front it space permits.
D. Is deliveni address different from rtemfil 0 Yes
Arttele Addressed to:
if YES.enter delivery address below: 0 No
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Article Number
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a/k.,:a Ilona .1.\0115 Kelley
773:s ood ko,ici
Sandy 20800
SENDER:COMPLETE THIS SECTION COMPLETE THIS SECTION ON DELIVERY
IN Complete items 1,2,and 3.Also complete A. Signature
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item 4 if Restricted Delivery is desired. 0 Agent
Print your name and address on the reverse X_ 0 Addressee
so that we can return the card to you. B. Received by(Frinted Neme).. C. Date ot Delivery
Attach this card to the back of the mailpiece,
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Article Addressee to: If YES,enter delivery address below; 0 No
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•
OFFICE OF THE CLERK OF COURT
COUNTY OF COMMON PLEAS
CUMBERLAND COUNTY COURTHOUSE *CARLISLE.PA 17013
David D.Buell
Prothonotar
TO: Ms. Ilona Yvonne Barnes a/k/a Ilona Yvonne Kelley
17735 Norwood Road
Sandy Spring, MD 20860
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORPORATION, :
Plaintiff, • Civil Action -In Law
vs. • No. 11-247 Civil Term
•
STANLEY G. BARNES and • ARBITRATION
ILONA YVONNE BARNES a/k/a
ILONA YVONNE KELLEY, •
•
Defendants. :
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania,you are hereby notified that a gment has been
entered against you in the above proceeding as indicated below. ` t
Davi .„64:11..w,r,
Prbhonotary
(XX) Judgment by Default ")'S/.?
( ) 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, Esquire
KRZYWICKI& ASSOCIATES, P.C.
49 North Sugan Road
P.O. Box 505
New Hope, PA 18938
(215) 862-4390
Attorney I.D. No. 23754
OFFICE OF THE CLERK OF COURT
COUNTY OF COMMON PLEAS
CUMBERLAND COUNTY COURTHOUSE *CARLISLE,PA 17013
David D.Buell
Prothonotary
TO: Mr. Stanley G. Barnes
17735 Norwood Road
Sandy Spring, MD 20860
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORPORATION, :
Plaintiff, • Civil Action - In Law
vs. : No. 11-247 Civil Term
•
STANLEY G. BARNES and • ARBITRATION
•
ILONA YVONNE BARNES a/k/a
•
ILONA YVONNE KELLEY,
•
Defendants. :
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania,you are hereby notified tha Judgment has been
entered against you in the above proceeding as indicated below. '"1
David D.Bue
Protho
(XX) Judgment by Default ����� 2
( ) 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, Esquire
KRZYWICKI& ASSOCIATES, P.C.
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 CORPORATION,
Plaintiff, Civil Action - In Law
VS. No. 11-247 Civil Term
STANLEY G. BARNES and ARBITRATION
ILONA YVONNE BARNES a/k/a — r~'
ILONA YVONNE KELLEY,
r*� M F
Defendants.
AFFIDAVIT OF MOTOR VEHICLE JUDGMENT }"
STATE OF PENNSYLVANIA)
ss.:
COUNTY OF BUCKS )
I, ANTHONY P. KRZYWICKI, Attorney for Plaintiff, verify that the above referenced
caption is due to a motor vehicle accident.
Antho P. Kr wi 1, E it
Attor Vey lai if
KRZ ICKI ASS "CIATE :C.
P.O. Box 505
New Hope, PA 18938
(215) 862-4390
PA Attorney ID #23754
Sworn to and subscribed before me
this 2�*\ day of uJ , 2013.
NOTARIAL SEAL
AMY M GLASGOW
Notary Public
NEW HOPE Notary BUCKS :14. Y
My Commission Expires Mar 016
aRk I
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