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Home My WebLink About04-3905 In the Court of Common Pleas of Cumberland County, Pennsylvania PPL Electric Utilities Corp. Plaintiff vs. Civil A9tiop n. Jl1 J;..aw No. D'/- .1'105 \.:-l.J^.< I~ Ryan Nickel Defendants ARBITRATION 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 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PPL Electric Utilities Corp. Plaintiff vs. Civil Action - In Law No. ~.., ./ O-'-..Jt:fq..S Ryan Nickel Defendant ARBITRA IION ~OMPLAINI I. 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 oWIled 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, AllentoWIl, PA 18l01. 3. Defendant, Ryan Nickel, is an adult individual residing at 1010 Crains Gap Road, Carlisle, PA 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. COUNT! PPL Electric Utilities Corp. vs. Ryan Nickel 5. Defendant, Ryan Nickel while operating a vehicle and collided with and damaged property owned by Plaintiff. 6. Defendant negligently operated his vehicle in he/she: a) operated said vehicle at an excessive rate of speed under the circumstances; b) failed to have said vehicle under proper and adequate control; c) failed to keep a proper lookout; d) operated said vehicle in a reckless and careless manner; e) failed to keep vehicle in the proper lane of travel; f) failed to operate the vehicle within the posted speed limit or failed to operate the vehicle at a reasonable speed under the circumstances; g) failed to remain alert and attentive under the circumstances; h) operated the vehicle without due regard for the rights, safety and position of the plaintiff; i) 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; 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 owned and operated by PPL Electric Utilities Corp., at the vicinity of920 Cranes Gap Road, North Middleton Township, PA on Of about January 3,2003. 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 fepay the sums then due and owing to PlainOtitI, but Defendant has refused to pay Plaintiff. 10. Plaintiff has been damaged in the amount of $4439. 78 plus costs and attorneys fees. WHEREFORE, PlaintitI PPL Electric Utilities Corp. demands judgment against the Defendant in an amount of $4439. 78 together with costs, prejudgment and post judgment interest, attorney's fees, punitive damages and delay damages as the law may allow. Respectfully submitted, Krzywicki and Associates By: DATED: July 29,2004 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. 9 4904 relating to unsworn falsification to authorities. Dated: July 29, 2004 Anthony P. Krzywicki, Esquire ~ ~ p (Y ~ j t ..... lI" '^. ~ Ii' ....(. ~ "') lr, ~, L" . , ""'" v ci ~- '-oJ 1;" <:0 -<- W -n c v, ,,~ , , SHERIFF'S RETURN - REGULAR CASE NO: 2004-03905 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PPL ELECTRIC UTILITIES CORP VS NICKEL RYAN BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE NICKEL RYAN was served upon the , at 2102:00 HOURS, on the 7th day of September, 2004 DEFENDANT at 6 WEST LOUTHER STREET CARLISLE, PA 17013 RYAN NICKLE APT 3 by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.70 .00 10.00 .00 31.70 Sworn and Subscribed to before me this It ~ day of J~YA' ~iV'I A.D. r;. (2 '!Ju;C,,-, ~ ~honotary I So Answers: ?'~~ R. Thomas Kline 09/08/2004 KRZYWICKI & ASSOC BY:;"", J-J~J / ~ty Sheriff 2060PD In the Court of Common pleas of CUMBERLAND County, Pennsylvania PPL Electric Utilities Corp. Plaintiff Civil Action - In Law vs No. 04-3905-Civil Term Ryan Nickel Defendant ARBITRATION PRAECIPE FOR JUDGMENT AGAINST DEFENDANT FOR FAILURE TO PLEAD To the Prothonotary: COUNT 1 PPL Electric Utilities Corp. vs. Ryan Nickel Kindly enter default judgment in favor of Plaintiff, PPL Electric Utilities Corp. and against Defendant, Ryan Nickel for failure to plead to Plaintiff's Complaint as follows: Amount Past Due: TOTAL $ 4439.78 $ 4439.78 together with interest thereon from the date of judgment forward and all costs of this action. 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 827 Hausman Road, Allentown, PA 18104. 2060PD 2. The true and correct address of the Defendant, Ryan Nickel, is 1010 Crains Gap Road, Carlisle, Cumberland County, PA 17013. DATED: November 17, 2004 ~. SHERIFF'S RETURN - REGULAR CASE NO: 2004-03905 P tfF0 1pU COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PPL ELECTRIC UTILITIES CORP VS NICKEL RYAN BRYAN WARD t Sheriff or Deputy Sheriff of Cumberland County,Pennsylvaniat who being duly sworn according to lawt says, the within COMPLAINT & NOTICE was served upon NICKEL RYAN the DEFENDANT , at 2102:00 HOURS, on the 7th day of Septembert 2004 at 6 WEST LOUTHER STREET APT 3 CARLISLE, PA 17013 by handing to RYAN NICKLE a true and attested copy of COMPLAINT & NOTICE together with and at the sa~e time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.70 .00 10.00 .00 31.70 /j .,.~:Y ~ r~~~f~ R. Thomas Kline 09/08/2004 KRZYWICKI & ASSOC Sworn and Subscribed to before By: /~ty 1;d::d me this day of A.D. Prothonotary G 2060PD In the Court of Common Pleas of CUMBERLAND County, Pennsylvania PPL Electric Utilities Corp. Plaintiff Civil Action - In Law vs No. 04-3905-Civil Term Ryan Nickel Defendant ARBITRATION NOTICE TO: Ryan Nickel 1010 Crains Gap Road Carlisle, PA 17013 Date: October 11, 2004 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 and Associates By: IsI Anthony P. Krzywicki 49 North Sugan Road P.O. Box 505 New Hope, PA 18938 215-862-4390 Attorney for Plaintiff Attorney I.D. 23754 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMEST1C AND INTERNAT10NAL MAil. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Recei' Krzywicki & Associates P.O. Box 505 New Hope, P A 18938 One piece of ordinery meil eddre.sed to: 11 W'C'\ N lC \c..~- L \~~ l ~~~ C:n~ ~ ~ . \. t'\~ \.\~~ I ry~ \'\~ \~ PS Form 3817. Mar. 1989 ~tno~ I .a. ttllt tAR here in stamps ~. / ~ g iV~.dn ~/; '~ _\( . ....., ':':.....o(.h' '1' ;l ~~\f: ~ ~j~~""~r~:;" ~ "':S.""'~~ :{) g ,;~~~~" ~ Q "")-' ~ IEf!1 1~lj ...0 '/". :~ 0 I I", .1 I mJ 1'1 'L'\ i . I \.! ....................;10 2060PD In the Court of Common Pleas of CUMBERLAND County, Pennsylvania PPL Electric Utilities Corp. Plaintiff Civil Action - In Law vs No. 04-3905-Civil Term Ryan Nickel Defendant ARBITRATION The undersigned hereby certifies that written notice of intention to file a praecipe for entry of judgment by default against the defendant, Ryan Nickel, 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. DATED: November 16, 2004 Krzywicki 2060PD In the Court of Common Pleas of CUMBERLAND County, Pennsylvania PPL Electric Utilities Corp. Plaintiff Civil Action - In Law vs No. 04-3905-Civil Term Ryan Nickel Defendant ARBITRATION AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY ss. COUNTY OF HUNTERDON I, Anthony P. Krzywicki, being duly sworn according to law, deposes and state that I am a representative of PPL Electric Utilities Corp., 827 Hausman Road, Allentown, PA 18104, Plaintiff herein, and as such state the following: 1. The defendant, Ryan Nickel, 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, Ryan Nickel, is more than 18 years of age and currently resides at 1010 Crains Gap Road, Carlisle, PA 17013. 3. I have ascertained the above information by personal investigation and make this affidavit with due_authority. icki -----.. M!CHELLE PYA .':;TN~Y DUBlIC OF NEW JERSEY ')",viN:iS310N EXPIRES JULY 9. 2007 C7V(:)~ i.~'i8 F ~ ~ ~ ~ ~ - ~ (U' l)' ~ 1- () r-..) c.:> 0 ~.:; C.--:'J -n ...:- ~~."'l \. 0 -l -,- : , , \"'<'1 ....1- ...,., , n1 c;'C".. ("'J , I -CJnl .' .'.~~\f? ~. 01.:') c--,; .' '" :~ -I', -0 )- ''-' , :x. '.... ')-- , ".(j ~5jTI --I :~l )> :r:- ~-,O -<. 0""1 -< KRZYWICKI & ASSOCIATES Anthony P. Krzywicki. Esquire John L. Shear burn, Esquire P.a. Box 505 New Hope, PA 18938 (215) 862-4390 Attorney for Plaintiff Attorney ID. 23754/26852 PPL Electric Utilities Corp. Plaintiff vs. Ryan L. Nickel Defendant( s) Court of Common Pleas Cumberland County Civil Action No. 04-3905-CV AFFIDAVIT !, Anthony P. Krzywicki, of full age, being duly sworn according to law, upon my oath depose and say: I. ! am an attorney tor PPL Electric Utilities Corp. and am duly authorized to make this affidavit. 2. A judgment was taken against Defendant, Ryan L. Nickel, for damages done in a motor vehicle accident on January 3,2003. SWo.RN TO. AND SUBSCRIBED BEFo.RE ME THIS ,c!fc DAY o.F lc:--) ,27 ,-'r "//<1:< Notary Public MICHELLE PYATT AI("i"'A"Y PU"" . . -, " ,',.Ie OF ~JEW JERSEY 1.'1 " C:JMM1SSI()N t:Y?iRES JULY 9, 2001 -, nthopy P. Krzywicki, AttOriJey for PPL Electric ~ (:) --ig. ~ 0v () --- - CJ ~ .t -l:: -U t".) ':'::1 ,'. t () ;-', '"j F CJl 'I -; --, :1'" I'-!'! b -'I'] , +----- ~ .- , , (,) ,,, , .,j IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORP., Plaintiff, vs. RYAN NICKEL, Defendant. Civil Action - In Law No. 04- Civil Term 3~ 6S ARBITRATION PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly_ mark the Judgment entered on against the Defendant, satisfied and from the record upon payment of your costs only. DATED: October 11, 2010 BY: KRZYWICKI P P.O. Box SOSI/ New Hope, PA 18938 (215)862-4390 Attorney I.D. 23754 TES, P.C. ~ ~ ~~ ~~ ~~ ~ ° --~ ~ ~ c -a --~ ~ ~~ ~ ~' °c' ~ ~~~ ~~ ~. ~ 3:7w ~ Q -T1 ~~ ~C`? ~'~ =" ~~ -~ ~- -- ~~~ S ~a'~ ~-'~~y