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Home My WebLink About13-0846IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, Plaintiff, Civic Action - In Law No. 13 _ gc~ l~ l V t ~ ~rM1 ~'S. CAITLIN J. WOODS, Defendant COMPLAINT ARBITRATION 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 (2U) 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 t ~ ~ = i r .., C ~.. - ~.. .. ._. ~ - '- ., r Ora . '°- ,. - ~""~ . ! _ ~: :...3 ~ .~_ ~~ - _ - ~ . - ...__ ._.._ .. ,. .__ .; ~ 103~'?5 PA A~ C~ 158~f3 ~.~ ~8 (v5~1' IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, Civil Action - In Law Plaintiff, No. vs. CAITLIN J. WOODS, Defendant. COMPLAINT ARBITRATION 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. ~. Defendant, CAITLIN .i. WOODS, is an adult individual residing at 108 .Arnold Road, Enola, Pennsylvania, 17025. 4. 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 Plaintiff's Tariff presently on file with the Public Utility Commission. COUNTI PPL ELECTRIC UTILITIES CORPORATION VS. CAITLIN J. WOODS ~. Defendant, CAITLIN J. WOODS, while operating a vehicle, damaged property owned by Plaintiff. <. 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 travel; t) failed to operate the vehicle anal/or equipment within the posted speed limit or failed to operate the vehicle and/or equipment at a reasonable speed under the circumstances; g) 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 Commonwealth of Pennsylvania governing the operation of vehicles and/or equipment on public streets, highways and roadways; 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. 7. Defendant, on or about June 4, 2011, struck and damaged a utility pole and overhead facilities owned and operated by PPL ELECTRIC UTILITIES CORPORATION at the vicinity of 32] Salt Road, East Pennsboro, Cumberland County, Pennsylvania- 8. Defendant's actions or inaction as set forth above are the proximate cause of the dama~~es as set for above and herein. ~). Plaintiff made demand on Defendant to repay the sums then due and owing to Plaintiff, but Defendant has refiised to pay Plaintiff. l0_ Plaintiff has been damaged in the amount of $8,114.72, including costs and attorneys fees. WHEREFORE, Plaintiff, PPL ELECTRIC UTILITIES CORPORATION, demands judgment a~~ainst the Defendant in an amount of $8,114.72, including costs, prejudgment and post judgment interest, attorney's fees, punitive damages and delay damages as the law may allow. Respectfully subrnitted, KRZYVVICKI~,~rS~@~IATES, P.C. DATED: January 27. 2013 By! >f Anthony P ywicki, Es AttorPlaintif ,/ P. x 50.5 Ho A 18 ~8 ( _ 62-4390 PA Attorney I o. 23754 VERIFICATION Pursuant to Rule 1024 (c), I, ANTAONY 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 ~«~ithin the time for serving the foregoing to provide their verification; that I am sufficiently familiar with the facts sez 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: .Ianuary 27, 201 KRZYWICKI & ASSOCIATES, P.C. IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, Civil Action - In Law Plaintiff, No. 13-846 Civil Term -Ti w vs. ARBITRATION mco = t ^ • max, .-� ��-' CAITLIN J. WOODS, D Defendant. r} PRAECIPE FOR JUDGMENT AGAINST DEFENDANT FOR FAILURE TO PLEAD To the Prothonotary: COUNT PPL Electric Utilities Corporation vs. Caitlin J. Woods Kindly enter Default Judgment in favor of Plaintiff, PPL Electric Utilities Corporation, and against Defendant, Caitlin J. Woods, for failure to plead to Plaintiff's Complaint as follows: Amount Due: $ 5,860.97 Court Fees: $ 1.03.75 Service Costs: $ 1.50.00 TOTAL: S 6,1.14.72 together with interest thereon from the date of judgment forward and all costs of this action. ICo.5o Pn ►4TN c�Il�ag7 �# �qb317 No�c� `Ma�l�d 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, Caitlin I Woods, is 1.08 Arnold Road, Enola, Pennsylvania, 17025. KRZYWICKI& CIATES, P.C. Dated: April 23, 2013 By: nthon . Krz i c sq re 49 orth Sua ad P.O. Box 5 New Hope, PA 18938 (215) 862-4390 Attorney for Plaintiff Attorney I.D. No. 23754 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, Civil Action - In Law Plaintiff, No. 13-846 Civil Term vs. ARBITRATION CAITLIN J. WOODS, Defendant. The undersigned hereby certifies that written notice of intention to file a Praecipe for Entry of Judgment by default against the Defendant, Caitlin J. Woods, in this matter was mailed to the Defendant after the default occurred and at least ten (1.0) days prior to the filing of the Pra.ecipe 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 , ' P.O. Box 505 New Hope, PA 18938 (21.5) 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. 13-846 Civil Term vs. ARBITRATION CAITLIN J. WOODS, Defendant. NOTICE TO: Ms. Caitlyn J. Woods 108 Arnold Road Enola, PA 17025 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 W862-4390 IATES, P.C. DATE: March 25, 2013 BY: s e 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. 13-846 Civil Term vs. ARBITRATION CAITLIN J. WOODS, 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 25, 2013.. A cony P. Kr wic J, Es e ttorn ey f l ai ' f RZ _ ICKI SOCI ES P.O. Box 505 New Hope, PA 1.8938 (215) 862-4390 PA Attorney ID #23754 Sworn to and subscribed before me this Z3r-d day of Rffz 2013. 0-M, NO VARY ARY P IC 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. 13-846 Civil Term vs. ARBITRATION CAITLIN J. WOODS, Defendant. 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, Caitlin J. Woods, 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, Caitlin J. Woods, is more than 18 years of age and currently resides at 1.08 Arnold Road, Enola, Pennsylvania, 17025. 3. I have ascertained the above information by personal i ig tion and make this Affidavit with due authority. Ant Pe P. Krz ti, Es e Sworn to and subscribed before me this ZZMday o 1 _, 2013. 0.1. r)Y, NO ARY PUBLIC NOTARIAL 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 ��,�.��tlr of Cataraf�r,.fr�� Jody S Smith Chief Deputy ' Richard W Stewart Solicitor PPL Electric Utilites Corporation Case Number vs. Caitlin J. Woods 2013-846 SHERIFF'S RETURN OF SERVICE 02/25/2013 04:04 PM- Deputy Shawn Harrison, being duly sworn according to law, served t e equested Complaint & Notice by handing a true copy to a person representing themselves to be 10. e M ody, half brother of defendant,who accepted as"Adult Person in Charge"for Caitlin J. Woo at 08 A nold Road, East Pennsboro Township, Enola, PA 17025. I' SPAWN ISON, DEPUTY SHERIFF COST: $43.00 SO ANSWERS, February 26, 2013 RON J R ANDERSON, SHERIFF cl CountySuRe St enB,'T'eleosoft.Inc. OFFICE OF THE CLERK OF COURT COUNTY OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE * CARL ISLE,PA 1701.3 David D.Buell Prothonotary TO: Ms. Caitlin J. Woods 108 Arnold Road Enola, PA ]7025 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, Civil Action - In Law Plaintiff, No. 13-846 Civil Term vs. ARBITRATION CAITLIN J. WOODS, 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 beloN11. David D.13uell thonota (XX) Judgment by Default ( ) Money Judgment ( ) Judgment ill 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. Krzywicici, 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, Civil Action- In Law Plaintiff, No. 13-846 Civil Term VS. ARBITRATION CAITLIN J. WOODS, Defendant. CD AFFIDAVIT OF MOTOR VEHICLE JUDGMENT STATE OF PENNSYLVANIA) Ss.: COUNTY OF BUCKS 1, ANTHONY P. KRZYWICKI,Attorney for Plaintiff, verify that the above referenced caption is due to a motor vehicle accident. Antho P. KT7-yw s re Atto e y for in K ' Z � R y 1 Y KI SSr9;IAT C. P.O. Box 505 New Hope, PA 18938 (215) 862-4390 PA Attorney ID #23754 Sworn to and subscribed before me this �av of n AJM 2013. WOTARY PUBLIC NOTARIAL SEAL AMY M GLASGOW Notary Public NEW HOPE BORO.,BUCKS COUNTY My Commission Expires Mar 14,7016 0 1/7 a9 3 ylsyl