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Home My WebLink About12-6481 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSI'LVANIA PPL ELECTRIC UTILITIES CORPORATION Civil Action - In Lai Plaintiff, No. ~_ ~~ D ~ ~i~(~ I 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 Comp:aint and Notice are served by entering a written appearance personally, or by attorney, and failing, in writing with the Court, your defenses o~_ 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 farther notice i'_or any money claimed i.n the Complaint or for any other claim or relief r~=_quested by the' Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THI5 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 ASSOCCATION 2 Liberty Avenue Carlisle, PA 17013-3387 (717) 249-3166 (800) 990-9108 ,~°~`,. ~d_~ ~~~~ 1~~~ ~ `~ ~~ ~ C~ ~ v~ a~ ~ IN T1IE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, Civi! Action - In L~~w Plaintiff, No• ~~s. JF.ANNE L C3EAR, Defendant. COMPLAINT A12BLTRATION 1 . This is an action by Plaintiff, PPL ELECTRIC UTILITIES CORPORATION, to recover damages from Defendant arising out of a vehicular collision which cai.ised damage to property owned by Plaintiff. :?. PPL ELECTRIC UTILITIES CORPORATION is a Pennsylvania corporation daily 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, Allento~.vn_ Pennsylvania, 18101. Defendant, JEANNE L. BEAR, is an adult individual residing at ~8? C;reenspring Road, Ne~~~ville, Pennsylvania, 17241. ~ At all times relevant hereto, Plaintiff was engaged in the business o1~ fi>>rnishing, supplying and distributing utility service to persons and businesses who requested utility service in accordance ~~°ith the Rate Schedules and General Rules and Regulations of Pla7ntiff~s Tariff present~.y nn file with the Public Utility Commission. COUNTI PPL ELECTRIC UTILITIES CORPORATIOht VS. JEANNE L. BEAR {. Defendant, JEANNE L. BEAR, while operating a vehicle, dama~~ed property owned by Plaintiff. 6. Defendant negligently operated the vehicle in that he/she: a) operated said vehicle and/or equipment at an excessive rate of speed under the circumstances; b) failed to have said vehicle and/or equipment under proper and adequate control; c) failed to keep a proper lookout; d} operated said vehicle and/or equipment in a reckless and careless manner; e) failed to keep vehicle and/or equipment in the proper lane of tra~~el; f) failed to operate the vehicle and/or equipment within the posted speed limit or failed to operate the vehicle and/or equipment at a reasonable speed under the circumstances; ~r) failed to remain alert and attentive under the circumstances. h) operated the vehicle and/or equipment without due regard for the rights, safety and position of the plaintiff. i) operated the vehicle and/or equipment in a manner violating, the statutes of the Commonv~realth of Pennsylvania governing the operation of ~~ehicles and/or equiprrient on public streets, highways and road :nays; j) being negligent at the law; and k) such other acts or omissions constituting carelessness, negligence and recklessness may be ascertained during discovery_ or developed at the time of trial . ;'. Defendant, on ar about November 29, 2010, struck and damaged a utility pole and overhead facilities owned and operated by PPL ELECTRIC UTILITIES CORPORATION at the vicinity of ~~l York Road, Carlisle, Cumberland County, Pennsylvania. ~. 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 repay the sums then due and. o~a~ing to Plaintiff, but Defendant has refused to pay Plaintiff. (0 Plaintiff has been damaged in the amount. of $17,160.00, including costs and attorneys fees. 'WHEREFORE, Plaintiff, PPL ELECTRIC UTILITIES CORPORATION. demands judgment against the Defendant in an amount of $17,160.00, including costs, prejud<m~ent and post jud~7ment interest, attorney's fees, punitive damages and delay damages as the law may allo« Respectfully submitted, KRZYWTCKI & ASSOC(A'TES, P.C. DATED: October 13. 2012 Y trntnony xrzy n,~cluire Attor y f ai , P.O. ox 505 _ New Hope, PA 938 (215) X62-4390 PA Attorney ID No. ?3754 VERIFICATION Pursuant to Rule 1024 (c), I, ANTAONY P. [d2lYWICKI, 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. ~ ~~~;~114 relating to unsworn falsification to authorities. KRZYWICKI & ASSOCIATES, P.C. Dated: October 1 ~, 2012 i1IRE f L./~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~,t'~~tts' w1 43~11-0ttpt~;.l,.,~ Jody S Smith Chief Deputy Richard W Stewart Solicitor - ~ - - .-_ r~ PPL Electric Utilites Corporation vs. Jeanne Lee Bear ~_ ~~~~-Or ~ iE:'.. ;~= ~~~ ~'R~J~`i1~3P~~ Ir'~~'~u 212 t~QV -8 PM 3, 4 1 ~UMgERLA~d~ ~ut1N ~ ~` PENNSYLVANIA Case Number 2012-6481 SHERIFF'S RETURN OF SERVICE 11/05/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Jeanne Lee Bear, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Found" at 35 N. Hanover Street, Apartment 2, Carlisle Borough, Carlisle, PA 17013. Per the Newville Postmaster defendant moved and left no forwarding address. SHERIFF COST: $57.00 SO ANSWERS, ~~ November 05, 2012 RON R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, Plaintiff, vs. JEANNE L. BEAR, Defendant C Civil Action - In Lae. N ? No. 12-6481 Civil r,?r,-TI, R) -7arny ARBITRATION `f 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: December 7, 2012 KRZYWICK_1,&-'SSOCIATES, P.C. Ant P. ick -Esquire ttorney f lair A P.O. Box 505 c New Hope, PA 18938 (215)862-4390 Attorney I.D. 23754 II.-7SPd °` &R ass?s pi p?qq3° BY: c IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, Civil Action - In Law Plaintiff, No. 12-6481 Civil vs. ARBITRATION JEANNE L. BEAR, : -TJ ,-� = -0¢-r-, Defendant. '; x Fj o C) c n? _ ern PRAECIPE FOR JUDGMENT AGAINST s- DEFENDANT FOR FAILURE TO PLEAD To the Prothonotary: COUNT PPL Electric Utilities Corporation vs. Jeanne L. Bear Kindly enter Default Judgment in favor of Plaintiff, PPL Electric Utilities Corporation, and against Defendant-, Jeanne L. Bear, for failure to plead to Plaintiff's Complaint as follows: Amount Due: $ 1.2,706.25 Court Fees: $ 103.75 Service Costs: $ 150.00 TOTAL: $ 12,960.00 together with interest thereon from the date of judgment forward and all costs of this action. Pd WKe Oc�led Gc�► I hereby certify, to the best of my knowledge and belief, as follows: L The true and correct address of the Plaintiff, PPL Electric Utilities Corporation, is Two North Ninth Street, Allentown, Pennsylvania, 181.01. 2. The true and correct address of the Defendant, Jeanne L. Bear, is Northumberland County Prison, 1101 Claremont Road, Carlisle, Pennsylvania, 17241. KRZYWICKI& ASSOCIATES, P.C. Dated: April 23, 2013 n icki, Es ui.re 9 r u n P.O. o New Hope, PA 1.8938 (215) 862-4390 Attorney for Plaintiff Attorney I.D. No. 23754 4 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, Civil Action - In Law Plaintiff, No. 12-6481 Civil vs. ARBITRATION JEANNE L. BEAR, Defendant. The undersigned hereby certifies that written notice of intention to file a Praecipe for Entry of Judgment by default against the Defendant, Jeanne L. Bear, 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 23, 2013 By: L ny P. I ick' ire e r a' f rth Sugan R d 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, Civil Action - In Law Plaintiff, No. 12-6481 Civil vs. ARBITRATION JEANNE L. BEAR, Defendant. NOTICE TO: Ms. Jeanne L. Bear 1101 Claremont Road Carlisle, PA 17241 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 (71.7) 249-3166 (800) 990-91.08 KRZYWICKI& ASSOCIATES, P.C. DATE: March 26, 2013 BY: Anthony P. w- 1, quire P.O. Bo o , A 1 (21.5) 862-4390 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. 12-6481. Civil vs. ARBITRATION JEANNE L. BEAR, .Defendant. 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 on March 26, 2013. Antho Kr ws 're rney f l ' KRZY WI & TES, P.C. P.O. Box 505 New Hope, PA 18938 (215) 862-4390 PA Attorney ID #23754 Sworn to and subscribed before me this L day of_ , 2013. N4tARY P LIC 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, Civil Action - In Law Plaintiff, No. 1.2-6481 Civil vs. ARBITRATION JEANNE L. BEAR, Defendant. AFFIDAVIT OF NON-MILITARY SERVICE STATE OF PENNSYLVANIA ) 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, Jeanne L. Bear, 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, Jeanne L. Bear, is more than 18 years of age and currently resides at 11.01. Claremont Road, Carlisle, Pennsylvania, 17241. 3. I have ascertained the above information by personal inve tip ion and make this Affidavit with due authority. Anth ty P. Krzy i' squ Sworn to and subscribed before me this �Aay of 10 2013. N ARY PUBLIC NO SEAL AMY.M GLASGOW Notary Public NEW HOPE BORO.,;BUCKS COUNTY My Commission Expires Mar.14,2016 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ti� 4.Rtrd yY, Jody S Smith Dt Chief Deputy j �yY Richard W Stewart Solicitor PPL Electric Utilites Corporation vs. Case Number Jeanne Lee Bear 2012-6481 SHERIFF'S RETURN OF SERVICE 02/26/2013 10:35 AM - Deputy William Cline, being duly sworn according to law, served the requested Complaint& Notice by"personally"handing a true copy to a person representing themselves to be the Defendant, to wit: Jeanne Lee Bear at 1101 Claremont Road, Carlisle, PA 17241. J WfLIAKkCLI NE, DEPUTY SHERIFF COST: $46.00 SO ANSWERS, February 27, 2013 RONIV R ANDERSON, SHERIFF (G)County5uilo Sheriff,Tcleoso8,Inc. t OFFICE OF THE CLERK OF COURT COUNTY OF COMMON PLEAS CUMBERLAND COUNTY COURTIIOUSE * CARLISLE,PA 17013 David D.Buell Prothouotaiy TO: Ms. Jeanne L. Bear 1101 Claremont Road Carlisle, PA 17241 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, Civil Action - In Law Plaintiff, No. 12-6481 Civil vs. ARBITRATION JEANNE L. BEAR, Defendant. 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. David D.Buell Prothoi tar), (XX) Judgment by Default ( ) Money Judgment ( ) Judgment in Replevin 00090 ( ) Judgment for Possession ( ) Judgment on Award of Arbitration ( ) Judgment on Verdict y laq 1 ( ) 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 Sultan Road P.O. Box 505 New Hope, PA 18938 (215) 862-4390 Attorney 1.D. No. 23754