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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 -~;~ ~'~ ~~~ _. -~' ~.~ ,~ ~~ ~ fi~~, -u, .,~~ . {..:... r-r-- ..~.~ ~i~'/ ~go1.00 Pp ATty ~~ la3?~ 2'~as355~6 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 - r .? co <= r 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 ? w as-r l?lC> 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 P-4 d893140 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 t r„ 0 - \7r. Swnlcr G. ISarnc 177;> A'n[vrood Road Sonde Sni m� AIU 'nRhn e • Complete items Restricted$andry A4e complete A. Sgna item 4 if r name an Delivery is desired.re i1 _ ❑/+gent • Print your name and addlESs On ltlB[BVBRB X r, 1 V ,k. -0Addu eeee so that we can return the card to you. Ived by kited Narne) G. e I OlA ry • Attach this card to the back of the mallplece, }Q /3 or on the front if space permits. i. grtideTdtlressetl m. D. Obi,ISdelivaryadtlrea dltterenl from item. . V II VCS,enter alllvery adds bolo.: 0 N Vh' �IUIJcc (i Itiuuo -_5 Non,.oud I1 uod Sande tiprin�_ AIU 'UAnu a. Service Type ❑Car lled Mall ❑ D,rees Mall ❑Registered ❑Return Receipt for Merchandise ❑Insured Mail ❑C.O.D. e Restricted DeNey?(E oa Fee) ❑yes Adcle Number aerulre la^ ��'r Y � n rr f. f> l 1 a 3t — At. Ilnnu 1 runnu 1$t rne> a'6-e )tcnnt 1A at,mc I:cllcc • Sandr tin m;. APt "J tSI� . 111 Complete items Restricted P.antl 3.Also complete A. 5lmlato'e ➢em 4 if r fme Deliverys on ere r• ` D Addo, • Print your name and atltlreaS on the reverse �- '+' �' r-' ��R Q Atld ev¢e so that We can return the card to you. n R p vud by(PA Pd Npmef. C Date of u-.ivw • Attach this card to the back of the mailpiece, t - )[on the front It Space pe""Is. _._._ _.__ `' . 1 1_ _••.. .—.- _. ._.. - O IS ee-e.•ry ankin 5d`XMBntiwt t liYCs Arallle A:yk,d tG: if YL$,1111e1 dellvery Addle,o blel; 0 N VI. Ilorrd 1Aunnc Nul 10s .; E. n ,hnu= Sr i.ant I:elicr ,ul tt..ar; Roc:d a. Scltleelype ,, 'Cr 1h1111°. ill) �I r1 r`II 1-J Conrad Mall 0 6xpreas Moll Q R ginteon ❑R urn Reca pt tar Merehnndlea ❑ lat, n R t .w:t oettvenrz(�zra�} Qves A,fide m bor 7pt1 . rya. �nn5 55[7�t F-54' I ' JO..,ocrvloe faCel; — i JIB/PQSTni$ER4ttt • I(cu�c UI (1 J ' i7 k �F IS' Vr Slamac C. 13ai nc� = i- 4and� Sprins., x.11) 'oOC i! ,�` PUS?A1. CHV it^ _ Cet MrcHle(.f 5 8; J .\ n il. Iion,i 1`•Fmnc 13arn���,`^ _ '—;a '1„1v.1,06 Road ,- 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 S Print your name and address on the reverse ,--,--y—ELAddressee so that we can return the card to you. B.—R4ved by Orinted Name) I C. of D¢livery 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 1, No1-\,.,( ci Road \11) 2.()8()(I 3. Service Type Certified Mail 0 Express Mall Registered 0 Return Receipt for Merchandise 0 Insured Mail 0 C.C.D. 4. Restricted Delivery?(Extra Fee) 0 Yes Article Number 10' —,—„ 11055 onnc alflCS 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 e 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, or on the front if space permits. - • 1 - D. Is delivery address different from item 1? 0 Yes Article Addressee to: If YES,enter delivery address below; 0 No \ 11011:i s1. onnc. liwncs H,,„„ .,,,pn, Kcnev ' oi\\.1)0d 1.<o 3. Service.Type "1:111(1\ 2:) ()11 0 Cenitied Mail 0 Express Mail 0 Registered 0 Return Receipt for Merchandise 0 Insured Mail 0 C.O.D. 4. Restricted Delivery?(Extra Fee) 0 Yes 1. Article Number 5 5 0 3 Li 3 ,.Tran.sfer fm-re service riber,, .- Hoim 3E '=e dYFklrhtC.i 1 ^.. -i!'" Ir': I!! 1,,,i,'', r'. „ I a 7- 3 �� ''�L.. I j o r . 1 :1 1 r z . 3 to w,T i •1Ir St�tniev' 6. Barnes °a0„ _j �'7 C7( 735 \c�n\'ood Road anciv Sprinu,. MI) 2 () `, 381': :*.3-::,'3'j44.c—';;!:.:11,:7E''''f;t. ::,::- Ck4titicatc.^Of ,',5, --- .''9:;- illill A r� m c` J `�I; Ilon^a �.v onne lame ,(, _� a w, CC..Dc C0 t_> \(,nvo d Road , 5;,7n(iv l-)rihi \1I) ?()Sou • 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 C'tH �