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HomeMy WebLinkAbout12-4704 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA LEAGUE OF CITIES AND MUNICIPALITIES d/b/a THE PENNPRIME LL42ELITY TRUST, as subrogee of HAM[PDEN TOWNS', PENNSYLVANIA 414 N. 2"d Street Harrisburg, Pennsylvania 17101 OF r 201?. . 23 PH P 03 ANyn COlIpTY Y ANIA and LEXINGTON INSURANCE COMPANY, as subrogce of MEMBERS OF PENNPRIME TRUST 100 Summer Street - 18th Floor Civil Action No. - Y ?? 1 Boston, MA 02110 Plaintiffs, CIVIL ACTION - LAW V. EATON CORPORATION d/b/a CUTLER HAMMER, INC. 1000 Cherrington Parkway Moan Township, Pennsylvania 15108 JURY TRIAL Defendant NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the fallowing pages ou must take action within twenty 20 days after this Complaint and Notice are served by entering a written appearance personall or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are w ed that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court witt, out further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may 1 se 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 CANNOT AFFORD ONE 00 TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT INHERE N MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE PA 17013 800-990-9108 717-249-3166 1) 9474321x.1 ?? SO NOTICIA LE RAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas deman4as expuestas a las pag ans sipienws usted tiene viente 20 dial de plazo al party de la fecha de la demanda y la notiflcacion Usted debe pres tar una apariencia escrita o en persona o por abosado y archivar on la torte on forrnm escrita sus defensas o ? objeciones las denmdas en contra de su persona Sea avisado que si usted no se defiende la torte tomes medidas y pue}lc entrar una den contra usted sin p vvio aviso o notifioacion y por cualquier queja o alivio que es pedido en la petition de deknanda Usted p ede perder dinero o sus propiedades o otros derechos importantes pars usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE SI NO TIENE ABOGADO O SI NO NE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO VAYA EN PERSONA O LLAME POR LEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE P DE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE PA 17013 800-990-9108 717-249-3166 -2- 9474321v.1 T IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Harrisburg, Pennsylvania 17101 and PENNSYLVANIA LEAGUE OF CITIES AND MUNICIPALfIM d/b/a THE PENNPRIME LIABILITY TRUST, as subrogee of HAMPDEN TOWNSHIP, PENNSYLVANIA 414 N. 2" ' Street LEXINGTON INSURANCE COMPANY, as subrogee of ME RS OF PENNPRIME TRUST 100 Sumner Street -18'h Floor Boston, MA 02110 Plaintiffs, V. EATON CORPORATION d/b/a CUTLER-HAMMER, INC. 1000 Cherrington Parkway Moon Township, Pennsylvania 15108 Defendant Civil Action No. CIVIL ACTION - LAW JURY TRIAL Plaintiffs, Pennsylvania League of Cities and Municipalities d/b/a The Pen Liability Trust, as subrogee of Hampden Township, Pennsylvania and Lexington In. Company, as subrogee of Members of PennPrime Trust, by and through their attorneys, and Williams LLP, for its Complaint against Defendant, Eaton Corporation d/b/a Hammer, Inc., hereby states as follows: 9474321v.1 PARTIES 1. Plaintiff, The PennPrime Liability Trust ("PennPrime"), is a organized under the laws of Pennsylvania, and is a self-insurance trust that services and is exclusively by Pennsylvania municipal entity members, with a principal place of located at 414 N. 2n' Street, Harrisburg, PA 17101. 2. At all times relevant hereto, Hampden Township ("the Township') was and is a municipality located in Cumberland County, Pennsylvania, and a member of the Pe e Liability Trust. 3. Pursuant to the terms of Hampden Township's membership in the Pe e Liability Trust, PennPrime is subrogated to the rights of the Township for all payments made or to be made to the Township by PennPrime. 4. Plaintiff, Lexington Insurance Company ("Lexington"), is a corporation organ d and existing under the laws of the State of Delaware, with a principal place of business located at 100 Summer Street, 18'h Floor, Boston, Massachusetts 02110. At all times relevant he to, Lexington was authorized to issue insurance policies in the Commonwealth of Pennsylvania. 5. At all times relevant hereto, Lexington insured Members of the Pe#3nPrime Tj - including Hampden Township - under Policy Number 012945042, and is subrogated to rights of the Members of the PennPrime Trust and Hampden Township for all payments made or to be made under the aforementioned policy. 6. Defendant, Eaton Corporation d/b/a Cutler-Hammer, Inc. ("Cutler-Hammer"), i? a company organized and existing under the laws of Ohio, with a principal place of located at 1000 Cherrington Parkway, Moon Township, Pennsylvania 15108. 9474321v.1 -2- 7. At all times relevant hereto, Cutler-Hammer manufactured, marketed, and soli in the Commonwealth of Pennsylvania a product called the Clipper Power System - SuperV sor Series, which is a Transient Voltage Surge Suppressor ("TVSS"). 8. At all times relevant hereto, Cutler-Hammer conducted regular, continuous d systematic business in the Commonwealth of Pennsylvania, including Cumberland County. JURISDICT ON AND VENUE 9. This Court has jurisdiction over the Defendant Cutler-Hammer and the sub ect matter of this action based upon the following substantial contacts with the Commonweal of Pennsylvania: (a) The Defendant Cutler-Hammer has conducted and continues to cond substantial business in Pennsylvania on a regular basis; and (b) The incident giving rise to this action occurred in Pennsylvania. 10. Venue is proper in this county because Defendant Cutler-Hamner regularly conducts business in Cumberland County, and the incident giving rise to this action occurred in Cumberland County. FACTUAL BACKGROUND 11. Plaintiffs incorporate the allegations contained in the foregoing paragraphs as if set forth more fully at length herein. 12. The Wastewater Division of the Hampden Township's Department of Works operates several wastewater and sewage pumping stations throughout the Township. -3- 9474321v.1 _r. 13. The facts that give rise to this lawsuit involve Pumping Station #1 ("the stati* ), located at 457 Lamp Post Lane, Mechanicsburg, PA. 14. Pumping Station #1 is a masonry constructed building with various, portions c structure divided to service the Township's various sewage-pumping needs. 15. Inside of Pumping Station #1 are four wastewater pumps, each powered by separate motors. The wastewater pumps control the flow of sewage and wastewater into and of the pumping station. 16. The building is a four level structure, with the rooftop designated as Level 4, Motor Control Center ("MCC") as Level 3, the pump-motor center as Level 2, I and the station as Level 1. 17. Within Pumping Station #1 are two separate underground cement Wells that what are referred to as the "wet well" and the "dry well." Each well is approximately deep and measures forty-feet wide. 18. Raw sewage flows into the "wet well" and is initially processed) there being pumped to the Township's main sewage treatment plant located at 4202 ! Roth Lane in Mechanicsburg, PA. 19. The "dry well," which is comprised of Levels 1 through 3, houses all of mechanical and electrical pumping equipment for Pumping Station # 1. 20. Between 2009 and 2010, Pumping Station #1 underwent a major renovai project that included the complete replacement of all mechanical and electrical component; the station. 21. After the renovation project was complete, Pumping Station #? returned operation in August 2010. in Ito -4- 9474321v.1 22. During its operation in March 2011, one of the four pumps for the station No. 3) was removed from service to undergo maintenance. During that period of time, station continued to operate using its three remaining pumps (Pump Nos. 1, 2, and 4). 23. On March 10, 2011 at 11:11 A.M., electrical power to Pumping Station #1 disrupted when the ground fault breaker to the station tripped. The loss of power'' shut down three operational pump-motors, along with the three corresponding pumps that they powered. 24. When the electrical power was disrupted, an electrical transfer switch in the N started an on-site emergency power generator, which then took over the task of electricity to operate the station's pumps. 25. While two of the pump-motors (Pump Nos. 2 and 4) started properly when emergency electrical power was turned on, Pump No. 1 failed to restart. 26. Upon discovering this condition, Township officials contacted IPSI Solutions, Inc. (PSI), the Township's electrical contractor, in an effort to diagnose! and repair system, and to return the station back to full functional operation. 27. A representative of PSI arrived at the station shortly after receiving notice the Township officials. 28. Upon inspection, it was determined that Pump No. 1 failed to restart because Variable Frequency Drive (VFD) - a device that controls the operation of the pump's moto? - indicated an over-voltage trip. 29. In addition, damage was observed at the Transient Voltage Surge 9 (TVSS), a device that is designed to suppress excessive transient overvoltage onl the power supply lines coming into the station from the public utility company. 30. PSI replaced the tripped VFD with a new VFD. 9474321v.1 -5- 31. The new VFD also failed to start the motor to Pump No. 1, indicating an voltage trip in the newly installed VFD as well. 32. At or around 3:30 P.M., Township officials were alerted to the fact that the level in the wet well was rising, apparently because the two remaining operational pumps Nos. 2 and 4) were unable to keep up with the incoming flow of wastewater and sewage. 33. Township officials responded to Pumping Station #1, discovering', that the level was approximately two feet below a ventilation duct pipe in the wet well,. In additi n, water was observed entering the dry well, which housed the pumps, the motors, and the statio 's motor control center. 34. At approximately 5:00 P.M. on March 10, 2011, sewage water from the wet reached the ventilation duct, broke it, and began to flow into the dry well, completely flooding Iit. 35. Temporary replacement pumps were quickly dispatched to the scene in an to alleviate the flow of water into the dry well. 36. At approximately 6:21 P.M., Township officials notified the ! Pennsyl Department of Environmental Protection (DEP) to advise them of the situation and to let know that temporary pumping was underway and that sewage was being discharged int a bypass connection line that had been installed during the 2010 renovation project. 37. On March 11, 2011 at approximately 3:30 A.M., Township officials received a telephone call from PSI, advising that Pump No. 1 was now operational. 38. At approximately 5:00 A.M. on March 11, 2011, Pumping Station #1 checked and sewage levels were still high in the wet well, but flow was controlled and not risin . 39. As of 6:20 A.M. on March 11, 2011, Pump Nos. 1, 2, and 4 were all and the water level in the dry well was below the motor control center floor. 947432]v.1 -6- 40. At approximately 11:00 A.M. on March 11, 2011, Township' officials notified that the water level in the dry well was again rising, threatening to submerge the motor control center. 41. It was determined that the water was flowing into the dry well through a 26-i hole in the wall of the wet well, which had been caused by the initial overflow of water into ventilation duct. 42. After taking remedial measures to repair the hole in the wet well, the water le, in Pumping Station #I returned to acceptable levels. 43. Following the incident on March 10, 2011, the TVSS and the VF6were ref from Pumping Station #l and secured with PSI for further inspection; specifically, to deter if they played a role in the failure of Pump No. 1. 44. The TVSS, branded as the Clipper Power System - SuperVisor Series, manufactured by Defendant, Cutler-Hammer, in March 2009 and was installed in Pun Station # 1 in May 2010. 45. Upon information and belief, on the day of the incident on March 10, 2011, a transient overvoltage event (power surge) occurred at Pumping Station #1. 46. Rather than suppressing the electrical power surge, the TVSS malfunctio d, allowing the electrical overvoltage to flow through the TVSS and into the first VFJ) in the control center. 47. The unsuppressed power surge was sufficient enough to disrupt the t control inside the VFD, resulting in a loss of control to the motor powering Pump No. 1. -7- 9474321v.1 48. The loss of proper control resulted in damage to the pump motor, t e., causing of the electrical phases of the motor to short to ground, thus resulting in the failure of Pump 1 and the resulting rise of wastewater into the dry well. 49. As a direct and proximate result of the acts and/or omissions of as set forth in greater detail below, the Township suffered significant damage to its work product, business interests, personal property, business property, collateral, e repair expenses, and incidental and consequential damages in the amount of $502,199.96. 50. Plaintiff, PennPrime, has made payments to the Township pursuant to the to s and conditions of the aforementioned insurance policy for the sum of $100,000.00, and subrogated to the extent of all payments made or to be made in the future to the rights of its said insured and subrogor against all persons, companies, and entities responsible for the occurre ce of the said equipment damage and resulting damages suffered by the Township. 51. Plaintiff, Lexington, has made payments to the Township by way of paymen? to the Members of PennPrime Trust, pursuant to the terms and conditions of the insurance policy, for the sum of $402,1999.96, and is subrogated to the extent of all made, or to be made in the future to the rights of its said insured and subrogor against persons, companies, and entities responsible for the occurrence of the said equipment and resulting damages suffered by the Township. 52. The aforesaid damages were directly and proximately caused by the acts omissions of Cutler-Hammer, and as a result of their culpable conduct as set forth }herein, Hammer is liable to PennPrime and Lexington for the damages sustained. -8- 9474321v.1 COUNT ONE &UL%aUA TTY (Plaintiffs V. Cut .Tiiemmer) 53. Plaintiffs incorporate the allegations contained in the foregoing paragraphs 4 if set forth more fully at length herein. 54. At all times relevant and material hereto, Defendant Cutler-Hammer was in the business of designing, manufacturing, distributing, selling and supplying transient surge suppressor (TVSS) units, including the one sold to the Plaintiffs' insured, H Township, for use in Pumping Station #1. 55. The TVSS sold to the Township, as well as its component parts, was defective. 56. Defendant Cutler-Hammer designed, manufactured, assembled, distributed, and/or supplied the TVSS in a dangerously defective condition. 57. The TVSS, as well as its component parts, was placed in the stream of comp by Defendant Cutler-Hammer. 58. The TVSS was expected to and did reach its intended users, including Township, without substantial change in the condition in which it was designed, assembled, distributed, sold and supplied. 59. A defect in the TVSS was a direct and proximate cause of the March 10, 2011 pump-motor failure and the resulting water damage at the Township's Pumping Station # 1. 60. Defendant Cutler-Hammer is strictly liable for all damage caused by the TVSS. WHEREFORE, Plaintiffs demand judgment against Defendant Cutler-Hammer damages in the amount of $502,199.96 together with interest, attorney's fees, costs of suit, a such other relief that the Court may deem appropriate. -9- 9474321v.1 COUNT TWO NEG_LICNCE (Plaintiffs v. Cutler-Hammer) 61. Plaintiffs incorporate the allegations contained in the foregoing paragraphs a s if set forth more fully at length herein. 62. Defendant Cutler-Hammer owed a duty of care to Plaintiffs' insured, Township, to properly design, manufacture, assemble, and/or otherwise distribute) the TVSS in a condition that was safe for its intended and reasonably foreseeable use. 63. Cutler-Hammer breached its duty of care owed to Plaintiffs' insured in on? or more of the following ways: (a) Designing, manufacturing, and/or assembling a TVSS that Cutler-H er knew or reasonably should have known created an unreasonable ris of harm; (b) Selling and/or otherwise distributing a TVSS in a defective condition Ihat Cutler-Hammer knew or reasonably should have known created an unreasonable risk of harm; (c) Designing, manufacturing, assembling, and distributing la TVSS th inadequate or defective component parts, including defective metal oxide varistors (MOVs), that Cutler-Hammer knew or reasonably should have known created an unreasonable risk of harm; (d) Designing, manufacturing, assembling, and distributing ' TVSS, when used for its intended purpose, created an unreasonable (risk of ha (e) Failing to design, manufacture, and/or assemble the TVSS I so that it safe for all reasonably foreseeable users; (f) Failing to exercise reasonable care in the design, assembly construe manufacture, fabrication, and/or selection of the TVSS's co>ponent Cr including the MOVs; and (g) Failing to use due care under the circumstances. 64. Cutler-Hammer's negligence was a direct and proximate cause of the March 0, 2011 pump-motor failure and the resulting water damage at the Township's Pumping Station 9474321v.1 -10- WHEREFORE, Plaintiffs demand judgment against Defendant Cutler-Hammer damages in the amount of $502,199.96 together with interest, attorney's fees, costs of suit, such other relief that the Court may deem appropriate. COUNT Y=E BREACH W A_NTV_ (PlaintWs v. Cutler-Hammer) 65. Plaintiffs incorporate the allegations contained in the foregoing paragraphs set forth more fully at length herein. 66. Cutler-Hammer knew or should have known that the consuming public, inch Plaintiffs' insured, would purchase and use its TVSS. 67. The Township was an intended user of the TVSS and relied!, upon Hammer's expertise and knowledge in properly designing, manufacturing, selling, otherwise distributing the TVSS. 68. Cutler-Hammer expressly and/or impliedly warranted that the TVSS reasonably fit for its intended use and was of merchantable quality. 69. Cutler-Hammer breached its expressed and/or implied warranties merchantability and fitness for a particular purpose in that the TVSS was not of merchant quality nor was it fit for use at the Township's Pumping Station #1. 70. Cutler-Hammer's breach of its expressed and/or implied warranties was a d and proximate cause of the March 10, 2011 pump-motor failure and the resulting water at the Township's Pumping Station #1. WHEREFORE, Plaintiffs demand judgment against Defendant Cutler?Hammer damages in the amount of $502,199.96 together with interest, attorney's fees, cos of suit, such other relief that the Court may deem appropriate. 9474321v.1 for if of WHITE AND LLIAMS, LLP By: 1y . Jaeger;, Esquire Crai A. ,Cohen, Esquire 16S Market Street - Suite 1800 Philadelphia, PA 19103-73951, Telephone: 215.864.6262 cohenc whiteandwilliams.cotn Attorneys for Plaintiffs The PennPrime Liability Trust and Lexington Insurance Company -12- 9474321v.1 VEMSATION I, a b? A • /4,v VAW , hereby verify that I have reviewed the contained in the foregoing Complaint and find them to be true and correct to' the best o my knowledge, information and belief. I understand that this statements is made subject t the penalties of 18 Pa.C.S.A. § 4904, relating to unworn falsification to authorities. Dated: J, t •!? t (. 7_0 I Z..._ On Behalf of The PennPrim Liability t -13- 9474321v.1 JulIV207:59a MTP Builders 9739485009 P.1 I, Patricia Prouh state that 1 am a Large Loss Recovery Specialist for Plsffi ff, Lecini ranee Company, I am authorized to make this Verification on its b amd tlmt potions set f t in the foregoing Complaint, as they pertain to Le n UMM gmny, are true and correct to the best of my knowledge, infarmation and belief. I tndeft this statement is made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsv f ca Lion to authatiiies. on 0$46403v.1 3 } Patricia Ptoulx Lexington Insurance Company IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA LEAGUE OF CITIES AND MUNICIPALITIES d/b/a THE PENNPRIME LIABILITY TRUST, as Civil Action No. 12-4704 subrogee of HAMPDEN TOWNSHIP, PA, AND LEXINGTON INSURANCE COMPANY, as subrogee of MEMBERS OF PENNPRIME TRUST, Plaintiffs, v. PRAECIPE FOR ENTRY OF ~ ~ Y APPEARANCE c ~ .;. c' ~ __ ,~~ o ~ `' ~ ~ ~~ ~, ,.` ~rn -t ,~,~ vc, ~' EATON CORPORATION d/b/a CUTLER- HAMMER, INC. Defendant. Filed on Behalf of: Defendant Eaton Corporation d/b/a Cutler-hammer, Counsel for Record for These Parties: Patrick L. Mechas, Esquire PA I.D. No. 61362 Nichole E. Humes, Esquire PA I.D. No. 203709 BURNS, WHITE Firm I.D. No. 828 Four Northshore Center 106 Isabella Street Pittsburgh, PA 15212 (412) 995-3000 JURY TRIAL DEMANDED IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA LEAGUE OF CITIES AND MUNICIPALITIES d/b/a THE PENNPRIME LIABILITY TRUST, as Civil Action No. 12-4704 subrogee of HAMPDEN TOWNSHIP, PA, AND LEXINGTON INSURANCE COMPANY, as subrogee of MEMBERS OF PENNPRIME TRUST, Plaintiffs, v. EATON CORPORATION d/b/a CUTLER- HAMMER, INC. Defendant. PRAECIPE FOR ENTRY OF APPEARANCE TO: Prothonotary: Kindly enter the appearances of Patrick L. Mechas and Nichole E. Humes as counsel record for Defendant, Eaton Corporation d/b/a Cutler-Hammer, Inc. Respectfully submitted, BURNS WHITE By: Patrick L. Mechas, Esquire Attorney for Defendant, Eaton Corporation d/b/a Cutler Hammer, Inc. - - , CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the within Praecipe for Ent of Appearance was served upon all counsel of record via first class mail, postage prepaid, this 8`~ day of August 2012: Edward A. Jaeger, Jr, Esquire Craig A. Cohen, Esquire White and Williams, LLP 1650 Market Street -Suite 1800 Philadelphia, PA 19103-7395 (Counsel for Plaintiffs) G~/~ Patrick L. Mechas, Esquire SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~~~~~tn at ~u,n~re~1~~0 ~ .: ~~~ r t~FF.t E ~3F ' ~•E SN~RIPF ~'l.~i1`tif~~~~ .c TNT ~'~'©T'NflN~ ~~„~~, Jody S Smith Chief Deputy Richard W Stewart Solicitor Z~12 SEP -5 QM !Q~ ! 4 C#7M~~RLANO CO.t1NTY ~E~ISY~.vi~rtiA Pennsylvania League of Cities and Municipalities Case Number vs. Eaton Corporation 2012-4704 SHERIFF'S RETURN OF SERVICE 08/03/2012 Ronny R. Anderson, Sheriff who being duly sworn according to taw states that he made a diligent search and inquiry for the within named defendant, to wit: Eaton Corporation d/b/a Cutler-Hammer, Inc., but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of Allegheny County, Pennsylvania to serve the within Complaint and Notice according to law. 08/17/2012 12:05 PM -Allegheny County Return: And now August 17, 2012 at 1205 hours I, William Mullen, Sheriff of Allegheny 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: Eaton Corporation d/b/a Cutler-Hammer, Inc. by making known unto Dawn Wolff, adult in charge for Eaton Corporation at 1000 Cherrington Parkway, Moontownship, Pennsylvania 15108 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 August 28, 2012 SO ANSWERS, ~~-~ RON R ANDERSON, SHERIFF (cl CountgSuite Sheriff, Teleos ft, Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy ~~~.,tits. ct ~ir~r~#~,~rt~~0 l>. gFFlCE ;~c ' ~ ~ 5-,RIFF V Richard W Stewart SOilCItOI' Pennsylvania League of Cities and Municipalities Case Number vs. Eaton Corporation 2012-4704 ryores: serve upon: Caton ~orporauon agora Luuer-hammer, inc. a a z z 0 ~a ~a Now, August 03, 2012 I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of Allegheny County to p execute service of the documents herewith and make return thereof according to law. V p Return To: F- Cumberland County Sheriffs Office w One Courthouse Square Carlisle, PA 17013 onny R Anderson, Sheriff