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HomeMy WebLinkAbout12-1034IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION. Civil Action - In L,avv Plaintiff, No. /a. IV it Term S. ARBITRATION G C= .? MICHAEL S. GOODHART a/k/a -vm W -? MIKE GOODHART and M xZ -Vrn MICHAEL, SCOTT MURPHY a/k/a n -- =C:) MICHAEL S. MURPHY d/b/a r?-z 4° MIKE MURPHY RENTALS, <a c) To ca-? C; o -?? Defendants. cn COMPLAINT NOTICE You have been sued in Court. If you wi>h to defend against the claims set forth in the fol.-owing pages, you must take action within twenty ;20) days after this Complaint and Notice are served by entering a written appearance personal,_y, oi- by at1-orney, 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 he 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 O 410.5.?5 Pb AnY ?? t4ao8 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, Civil Action - In Law Plaintiff No. VS. ARBITRATION MICHAEL S. GOODHART a/k/a MIKE GOODHART and MICHAEL SCOTT MURPHY a/k/a MICHAEL S. MURPHY d/b/a MIKE MURPHY RENTALS, Defendants COMPLAINT This is an action by Plaintiff, PPL ELECTRIC UTILITIES CORPORATION, to recover damages from Defendant arising out of damage to property owned by PPL ELECTRIC UTILITIES CORPORATION. 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, 18101-1179. Defendant, MICHAEL, S. GOODHART A/K/A MIKE GOODIIAR1. is an adult individual who currently resides at 184 Texaco Road, Mechanicsburg, Pennsylvania, 17050. 4. Defendant, MICHAEL SCOTT MIJRPIiY A/K/A MICHAEL S. Mt JIZPFIY D/B/A MIKE MURPHY RENTALS, is an adult individual who currently resides at 3320 Derry Street. Harrisburg, Pennsylvania, 17111. 5. 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 CORPORATION VS. MICHAEL S. GOODHART A/K/A MIKE GOODHART NEGLIGENCE PER SE 6. The allegations contained in Paragraphs I through 5 above are incorporated by referenced as if fully set forth. 7. Defendant, MICHAEL S. GOODHART A/K/A MIKE GOODHART. while employed by Defendant, MICHAEL SCOTT MURPHY A/K/A MICHAEL S. MURPHY D/B/A MIKE MURPHY RENTALS. violated the Underground Utility Line Protection Law_ Act 187 of 1996 in that he: a) did not employ prudent excavation techniques to ascertain the precise position of underground utilities; b) did not exercise due care and take all reasonable steps necessary to avoid damage to Plaintiffs underground utility lines: C) did not hand dig to locate the utility line when Defendants determined that the markings were not clear; d) did not hand dig a test hole to identify location of the primary cable; e) Defendant, MICHAEL S. GOODHART A/K/A MIKE GOODHART, did not place a call to Call One system prior to excavating thereby risking a catastrophe. 8. Defendant, MICHAEL S. GOODHART A/K/A MIKE GOODHART, on or about April 6. 2010, while excavating with a cat skid loader, struck and damaged an underground primary cable owned and operated by PPL ELECTRIC UTILITIES CORPORATION at 422A Duke Street. East Pennsboro. Cumberland County, Pennsylvania. 9. Defendant's actions or inaction as set forth above are the proximate cause of the damages as set for above and herein. I (). Plaintiff made demand on Defendant. MICHAEL S. GOODHART A/I?!A MIKE GOODHART. to repay the sums then due and owing to plaintiff ; but Defendant. N/11(_'I-IAEL S. GOODHART A/11,//A MIKE GOODHART, has refused to pay Plaintiff. 1 1. Plaintiff has been damaged in the amount ol_$4,485.13, includin- costs and attorneys fees. WHEREFORE. Plaintiff. PPL ELECTRIC UTILITIES CORPORATION. demands judgment against the Defendants, in an amount in excess of $4,485.13, together with costs, prejudgment and post judgment interest, punitive damages and delay damages as the law may allow. COUNT II PPL ELECTRIC UTILITIES CORPORATION VS. MICHAEL S. GOODHART A/K/A MIKE GOODHART COMMON LAW TORT 12. The allegations contained in Paragraphs 1 through 1 I above are incorporated by reference as if fully set forth. Plaintiff used standard industry markings to identify the Location of its act' 13. ive- underground primary cable prior to April 5, 2010. 14. Defendant, MICHAEL S. GOODHART A/K/A MIKE GOODHART, did not exercise due care and did not take all reasonable steps to avoid damage to the active cables owned by PPL ELECTRIC UTILITIES CORPORATION, in that he/she; a) did not employ prudent excavation techniques to ascertain the precise position of underground utilities: b) did not exercise due care and take all reasonable steps necessarv to avoid damage to Plaintiffs underground utility lines; C) did not hand dig to locate the utility line when Defendants determined that the markings were not clear; d) did not hand dig a test hole to identity location of the primary cable; e) Defendant, MICHAEL S. GOODHART A/K/A MIKE GOODHART, did not place a call to Call One system prior to excavating thereby risking a catastrophe. WHEREFORE. Plaintiff, PPL ELECTRIC UTILITIES CORPORATION. demands judgment against the Defendants, in an amount in excess of $4,485.13, together with costs, prejudgment and post judgment interest, punitive damages and delay damages as the law may allow. COUNT III PPL ELECTRIC UTILITIES CORPORATION VS. MICHAEL SCOTT MURPHY A/K/A MICHAEL S. MURPHY D/B/A MIKE MURPHY RENTALS VICARIOUS LIABILITY FOR ACTION OF AGENT 15. Paragraphs 1 through 14 are incorporated by reference as if fully set forth herein. 16. Defendant. MICHAEL SCOTT MURPHY A/K/A MICHAEL S. ML RPI-1Y D/B/A MIKE MURPHY RENTALS , was the owner of the equipment that struck and damaged underground primary cable. ¦ 17. Defendant, MICHAEL SCOTT MURPHY A/K/A MICHAEL S. MURPHY D/B/A MIKE MURPHY RENTALS , permitted and encouraged the actions of its agents and employees by not implementing a training program which addressed circumstances such as those which occurred on the date of the accident. 18. Defendant, MICHAEL SCOTT MURPHY A/K/A MICHAEL S. MURPHY D/B/A MIKE MURPHY RENTALS , is vicariously responsible for the actions of its agents and employees. I O. Defendant's actions or inaction as set forth above are the proximate cause Of tile damages as set forth above and herein. 20. The aforementioned damages were the direct and proximate result of the negligence of Defendant. MICHAEL SCOTT MURPHY A/K/A MICHAEL S. MURPHY D/B/A MIKE MURPHY RENTALS , including negligent acts and/or omissions of defendant as performed individually and/or by and through others permitted to use equipment more speciticatly described as follows: a) negligently and carelessly failing to properly and adequately supervise and/or train. Defendant, MICHAEL S. GOODHART A/K/A MIKE GOODHART, in the operation of his/her equipment, b) negligently and carelessly failing to properly supervise the operation and control of said equipment: and c) otherwise failing to exercise reasonable care under the circumstances. 21. Plaintiff has been damaged in the amount of $4,485.13, including costs and attornevs tees. WHEREFORE, Plaintiff PPL ELECTRIC UTILITIES CORPORATION demands judgment against the Defendant, in an amount in excess oaf $4,485.13, together with costs, prejudgment and post judgment interest, punitive damages and delay damages as the law may allow-. Respectfully submitted. KRZYWICKI &,,, CIATES, P.C. DATED: February 15, 2012 By: Autl y P. r cki ?s P Bo eva H e, A 938 (215)862- - 0 Attorney for Plaintif Attorney I.D. 23754 VERIFICATION Pursuant to Rule 1024 (c), 1. ANTHONY P. KRZYWICKI, ESQUIRE, verify that f 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 1 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. ti 4904 relating to unsworl falsification to authorities. Dated: Februarv 15. 2012 KRZYWI(='KI & ASSOCIATES, P.C. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor PPL Electric Companies Corp vs. Michael Scott Murphy (et al.) r 2 r,' 14 U 9EtlLA,t D 0 0U1 i PEMSYLVAWA Case Number 2012-1034 SHERIFF'S RETURN OF SERVICE 02/21/2012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Michael Scott Murphy, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Daupin County, Pennsylvania to serve the within Complaint and Notice according to law. 02/24/2012 08:14 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on February 24 2012 at 2014 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Michael S. Goodhart, by making known unto himself personally, at 184 Texaco Road, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. DEN FRY, DEPU 02/28/2012 12:58 PM - Dauphin County Return: And now February 28, 2012 at 1258 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do hereby certify and return that I served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Michael Scott Murphy d/b/a Mike Murphy Rentals by making known unto Colleen Maurer, Agent for Mike Murphy Rentals at 3320 Derry Street, Harrisburg, Pennsylvania 17111 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $23.45 March 02, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF Mtfirg of the,,*hcrTff Jack Duignan ief Deputy William T. Tully A!i Ch Solicitor Michael W. Rinehart Assistant Chief Deputy Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania PPL ELECTRIC UTILITIES CORPORATION VS MICHAEL SCOTT MURPHY, AKA County of Dauphin MICHAEL S. MURPHY, DBA MIKE MURPHY RENTALS Sheriff s Return No. 2012-T-0615 OTHER COUNTY NO. 2012-1034 And now: FEBRUARY 28, 2012 at 12:58:00 PM served the within NOTICE & COMPLAINT upon MICHAEL SCOTT MURPHY, AKA MICHAEL S. MURPHY, DBA MIKE MURPHY RENTALS by personally handing to COLLEEN MAURER 1 true attested copy of the original NOTICE & COMPLAINT and making known to him/her the contents thereof at 3320 DERRY ST. HARRISBURG PA 1711.1 AGENT Sworn and subscribed to So Answers, before me this 29TH day of February, 2012 V-?? Sher' f f Dauphin County, Pa. By COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL D ty Sheriff Karen M. Hoffman, Notary Public uty. J MILLER City of Harrisburg, Dauphin County M Commission Expires August 17, 2014 eriff s Costs: $47.25 2/24/2012 OFFICE OF THE CLERK OF COURT COUNTY OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE * CARLISLE, PA 17013 Curtis R. Long Prothonotary TO: Mr. Michael S. Goodhart a/k/a Mike Goodhart 184 Texaco Road Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, Civil Action - In Law Plaintiff, No. 12-1034 Civil Term vs. ARBITRATION MICHAEL S. GOODHART a/k/a MIKE GOODHART and MICHAEL SCOTT MURPHY a/k/a MICHAEL S. MURPHY d/b/a MIKE MURPHY RENTALS, Defendants 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. (XX) Judgment by Default ( ) Money Judgment ( ) Judgment in Replevin ( ) Judgment for Possession ( ) Judgment on Award of Arbitration ( ) Judgment on Verdict ( ) Judgment on Court Findings Prothonotary 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 No. 12-1034 Civil Term vs. MICHAEL S. GOODHART a/k/a MIKE GOODHART and MICHAEL SCOTT MURPHY a/k/a MICHAEL S. MURPHY d/b/a MIKE, MURPHY RENTALS, Defendants ARBITRATION C (-) -q r- c 7-U n c : r. ") C 'i ?? ?''c, `D mac: Caw - 5 >c= f.0 I --? C n ' • ? E::r'a PRAECIPE FOR JUDGMENT AGAINST DEFENDANT FOR FAILURE TO PLEAD To the Prothonotary: COUNTI PPL Electric Utilities Corporation vs. Michael S. Goodhart a/k/a Mike Goodhart Kindly enter Default Judgment in favor of Plaintiff, PPL Electric Utilities Corporation, and against Defendant, Michael S. Goodhart a/k/a Mike Goodhart, for failure to plead to Plaintiff's Complaint as follows: Amount Due: $ 3,084.13 ? Airy ? Court Fees: $ 103.75 Service Costs: $ 197.25 TOTAL: $ 3,385.13 together with interest thereon from the date of judgment forward and all costs of this action. $10.50 Pp ATE 01146 11 e (914N D Nome Mailed 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, Michael S. Goodhart a/k/a Mike Goodhart, is 184 Texaco Road, Mechanicsburg, Pennsylvania, 17050. KRZYWICKI & A.,S.QCIATES, P.C. Dated: April 17, 2012 By: 9N .0., P. Jew HoXYA 189 (215) 8 4390 Attorney for Pl f Attorney I.D. No. 23754 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, Civil Action - In Law Plaintiff, No. 12-1034 Civil Term vs. ARBITRATION MICHAEL S. GOODHART a/k/a MIKE GOODHART and MICHAEL SCOTT MURPHY a/k/a MICHAEL S. MURPHY d/b/a MIKE MURPHY RENTALS, Defendants The undersigned hereby certifies that written notice of intention to file a Praecipe for Entry of Judgment by default against the Defendant, Michael S. Goodhart a/k/a Mike Goodhart, 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: April 17, 2012 By: thony P 4orth ?pXar?,l?oad P.O. Box g-< New Hope, PA 938 (215) 862-439 Attorney I.D. No. 23754 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, Civil Action - In Law Plaintiff, No. 12-1034 Civil Term vs. ARBITRATION MICHAEL S. GOODHART a/k/a MIKE GOODHART and MICHAEL SCOTT MURPHY a/k/a MICHAEL S. MURPHY d/b/a MIKE MURPHY RENTALS, Defendants. NOTICE TO: Mr. Michael S. Goodhart a/k/a Mike Goodhart 184 Texaco Road Mechanicsburg, PA 17050 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 maybe 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 & P.C. DATE: April 2, 2012 BY: Fw y P. 109 i, u o 5 ope, P 8 (215) 862-426 Attorney I.D. 23754 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, Civil Action - In Law Plaintiff, No. 12-1034 Civil Term vs. ARBITRATION MICHAEL S. GOODHART a/k/a MIKE GOODHART and MICHAEL SCOTT MURPHY a/k/a MICHAEL S. MURPHY d/b/a MIKE MURPHY RENTALS, Defendants. STATE OF PENNSYLVANIA) COUNTY OF BUCKS ) AFFIDAVIT OF SERVICE SS.: 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 on April 2, 2012. P. Kyzywic?t'i, Esquire KICKI ASS IAT , P.C. BOX 505 New Hope, 18938 (215) 862-4390 PA Attorney ID #23 Sworn to and subscribed before me this j q`")day of , 2012. OTARY PUBLIC NOTARIAL SEAL AMY M GLASGOW NEW HOPE ? P°O auC KS colarn? h conanM=?°" Mtr M, 2018 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, Civil Action - In Law Plaintiff, No. 12-1034 Civil Term vs. ARBITRATION MICHAEL S. GOODHART a/k/a MIKE GOODHART and MICHAEL SCOTT MURPHY a/k/a MICHAEL S. MURPHY d/b/a MIKE MURPHY RENTALS, 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 Defendant, Michael S. Goodhart a/k/a Mike Goodhart, 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, Michael S. Goodhart a/k/a Mike Goodhart, is more than 18 years of age and currently resides at 184 Texaco Road, Mechanicsburg, Pennsylvania, 17050. 3. I have ascertained the above infori Affidavit with due authority. Sworn to and subscribed before me this 'of , 2012. 6L4 d"'I* N ARY PUB IC 9UMIV Noe E? this AMY M GLASGOW 1'uMNEW NW 60AO E NUMWAI SQ2016 Iv ('I ,- SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff tttr of cuinfrrrf Jody S Smith Chief Deputy ??rA Goa Richard W Stewart Solicitor OFFICE OF THE SHERIFF PPL Electric Companies Corp Case Number vs. Michael Scott Murphy (et aQ 2012-1034 SHERIFF'S RETURN OF SERVICE 02/21/2012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Michael Scott Murphy, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Daupin County, Pennsylvania to serve the within Complaint and Notice according to law. 02/24/2012 08:14 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on February 24 2012 at 2014 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Michael S. Goodhart, by making known unto himself personally, at 184 Texaco Road, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. DEN FRY, DEPU 02/28/2012 12:58 PM - Dauphin County Return: And now February 28, 2012 at 1258 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do hereby certify and return that I served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Michael Scott Murphy d/b/a Mike Murphy Rentals by making known unto Colleen Maurer, Agent for Mike Murphy Rentals at 3320 Derry Street, }C? Harrisburg, Pennsylvania 17111 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $23.45 March 02, 2012 SO ANSWERS, RONKY- R ANDERSON, SHERIFF (c) CountySuile Shenff. Teleosoff, inc. IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLV PPL ELECTRIC UTILITIES CORPORATION, Plaintiff, vs. MICHAEL S. GOODHART a/k/a MIKE GOODHART and MICHAEL SCOTT MURPHY a/k/a MICHAEL S. MURPHY d/b/a MIKE MURPHY RENTALS, Civil Action - In Law No. 12-1034 Civil Term ARBITRATION Defendants PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: ~.~ '~' ~~' -~ ~~ ~a ~ ~ r +o ~ c Nth" ~ ~< ~~ -v ~~ ~~ 3 z T~' --t ~ ~``~' ~ ~ Kindly mark the Judgment entered on against the Defendant, Michael S. Goodhart a/k/a Mike Goodhart, satisfied and from the record upon payment of your costs only. KRZYWICKI & ASSOCIATES, P.C. DATED: August 29, 2012 BY: ~'9 soar ~.~ C~# /sar3 ~,~ ~sor~ (215) 862-4390 Attorney I.D. 23754 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLV PPL ELECTRIC UTILITIES CORPORATION, Plaintiff, vs. MICHAEL S. GOODHART a/k/a MIKE GOODHART and MICHAEL SCOTT MURPHY a/k/a MICHAEL S. MURPHY d/b/a MIKE MURPHY RENTALS, Defendants. Civil Action - In Law No. 12-1034 Civil Term ARBITRATION PRAECIPE TO SETTLE, DISCONTINUE, AND END TO THE PROTHONOTARY: c~ ~_ "~, -o ~~ t t~ -v Fc~ ~ ,,,.; N ~..~ ~.o Kindly mark this matter Settle, Discontinue, and End against the Defendants, prejudice upon payment of your costs only. DATED: August 29, 2012 BY: KRZYWICKI & ASSOCIATES, P.C. 3> ~e; ;` ~' Attorney for Plaintiff Attorney LD. 23754