HomeMy WebLinkAbout13-6107 Supreme Co urt of Pennsylvania
Cour ofr,Common Pleas For Prothonotary Use Only:
CI<vilCover Sheet
County
Docket No:
Cumberland'
The 11710r712a1101? collected 011 1111s form Ls' used solely for court administration nulposes. This 101'117 does 1101
s'uly)letnent or rel)lace tlle,iling and service (?f pleadings Or other palmrs as required by /air Or rules O1 court.
Commencement of Action:
S ❑✓
E Complaint ❑ Writ of Summons ❑ Petition
❑ Transfer from Another Jurisdiction r - 1 Declaration of Taking
C Lead Plaintiff's Name: Lead Defendant's Name:
T PPL Electric Utilities Corporation John C. Mears Jr.
I Are money damages requested? [Z Yes
Dollar Amount Requested: ❑✓ within arbitration limits
❑ No
O (check one) ❑outside arbitration limits
N Is this a Class Action Suit? ❑ Yes ❑✓ No Is this an MDJAppeal? ❑ Yes ❑✓ No
A Name of Plaintiff /Appellant's Attorney: An P. Krzywi Esq
❑ Check here if you have no attorney (are a Self - Represented (Pro Se] Litigant)
Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARYCASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
❑ Intentional ❑ Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment
Q Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
Nuisance Dept. of Transportation
Premises Liability ❑ Statutory Appeal: Other
S Product Liability (does not include
E mass tort) E] Employment Dispute:
C e Slander /Libel/ Defamation Discrimination
Other: ❑ Employment Dispute: Other ❑ Zoning Board
T ❑ Other:
I ❑ Other:
O MASS TORT
❑ Asbestos
N Tobacco
Toxic Tort - DES
Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
❑ Toxic Waste
❑ Other: ❑ Ejectment E] Common Law /Statutory Arbitration
B ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment
Ground Rent ❑ Mandamus
❑ Landlord /Tenant Dispute Non- Domestic Relations
Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABLITY e Mortgage Foreclosure: Commercial ❑ Quo Warranto
❑ Dental ❑ Partition ❑ Replevin
❑ Legal ❑ Quiet Title ❑ Other:
❑ Medical Other:
❑ Other Professional:
Updated 111/2011
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORPORATION,
Civil Action - In L�w .�
Plaintiff, No.
vs. ARBITRATION
JOHN C. MEARS JR.,c?,
Defendant. -
c
COMPLAINT y
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
�� t O .7�oJ
e 1
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORPORATION,
Civil Action - In Law
Plaintiff, No.
VS. ARBITRATION
JOHN C. MEARS JR.,
Defendant.
COMPLAINT
1. 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.
3. Defendant, JOHN C. MEARS JR., is an adult individual residing at 316 N.
Baltimore Avenue, Mount Holly Springs, Pennsylvania, 17065.
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.
COUNT
PPL ELECTRIC UTILITIES CORPORATION VS.
JOHN C. MEARS JR.
5. Defendant, JOHN C. MEARS JR., while operating a vehicle, damaged 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 travel;
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;
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 1.4, 2012, struck and damaged a utility pole and
overhead facilities owned and operated by PPL ELECTRIC UTILITIES CORPORATION at the
vicinity 3128 Spring Street, Carlisle, Cumberland County, Pennsylvania.
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 repay the sums then due and owing to
Plaintiff, but Defendant has refused to pay Plaintiff.
10. Plaintiff has been damaged in the amount of $9,374.80, including costs and
attorneys fees.
WHEREFORE, Plaintiff, PPL ELECTRIC UTILITIES CORPORATION, demands
judgment against the Defendant in an amount of $9,374.80, including costs, prejudgment and
post judgment interest, attorney's fees, punitive damages and delay damages as the law may
allow.
Respectfully submitted,
KRZYWICKI CIATES, P.C.
DATED: October 14, 2013
y:
Ant y zyw' i, Esquire
for or P 'ntiff
P.O. Box 50
New Hope, PA 18938
.(215) 862 -4390
PA Attorney ID No. 23754
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. § 4904 relating
to unsworn falsification to authorities.
KRZYWICKI & ASSOCIATES, P.C.
Dated: October 14, 2013
Z A HO P. Z , ESQUIRE
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy ! is
Richard W Stewart
Solicitor :'; c k w [C y c.. ♦� }J f, g_f
PPL Electric Companies Corp
Case Number
vs.
John C Mears, Jr. 2013-6107
SHERIFF'S RETURN OF SERVICE
10/18/2013 02:43 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search
and inquiry for the within named Defendant to wit: John C Mears, Jr., but was unable to locate the
Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint& Notice as"Not
Found"at 316 N. Baltimore Avenue, Mt. Holly Springs Borough, Mt. Holly Springs, PA 17065. Deputies
were advised by current resident, Rose that the defendant was her granddaughter's ex-boyfriend and has
not lived at this address for several years and is belived to be residing in Perry County.
SHERIFF COST: $40.91 SO ANSWERS,
'.,
4"
October 23, 2013 RONW R ANDERSON, SHERIFF
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORPORATION,
Civil Action - In Law
Plaintiff, No. 13-6107 Civil
VS. ARBITRATION
JOHN C. MEARS JR.,
Defendant. ;
d- r
D
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.
KRZYWICKI & SOCIATES,P.C.
DATED: November 13,2013
BY:
thony P w' i, quire
ttorn o ntif
. . ox 505
New Hope, PA
(215)862-4390
Attorney I.D. 23754
V Vv�
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson E r.r
Sheriff
Citirlberf
Jody S Smith t.r;
Chief Deputy ~
eVvt Richard W Stewart Li l t .
rte,-"kfr. v3 'i alibi
Solicitor r`R1F c i . J i a t t
PPL Electric Companies Corp
vs. Case Number
John C Mears, Jr. 2013-6107
SHERIFF'S RETURN OF SERVICE
12/06/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: John C Mears, Jr., but was unable to locate the Defendant in the
Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Perry, Pennsylvania to serve the within
Complaint& Notice according to law.
12/09/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: John C Mears, Jr., but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Complaint& Notice as"Not Found"at 901 S.
Spring Garden Lot 59, South Middleton, Carlisle, PA 17015. Deputies were advised that the new tenants
moved in in August 2013 and the Carlisle Postmaster has confirmed that the defendant is not known at
the address provided.
12/11/2013 The requested Complaint& Notice returned by the Sheriff of Perry County, the within named Defendant
John C Mears, Jr., not found. Carl E. Nace, Sheriff, Return of Service attached to and made part of the
within record.
SHERIFF COST: $53.78 SO ANSWERS,
January 02, 2014 RONNY R ANDERSON, SHERIFF
C.;osc`r
SHERIFF'S RETURN
In the Court of Common Pleas
Of the 41st Judicial District
of Pennsylvania-
Perry County Branch
No.: 2013-6107 Cumberland Co.
PPL Electric Utilities Corp.
VS
John C.Mears Jr.
463 S.3rd Street
Newport,PA 17074
Carl E. Nace, Sheriff, who being duly sworn according to law, says that he made a
diligent search and inquiry for the within named Defendant(s)to wit John C. Mears Jr.,
but was unable to locate him/her in his bailiwick. He therefore returns the within
Complaint for the above named Defendant(s) John C.Mears Jr.at 463 S.3rd Street,
Newport,PA 17074.NOT FOUND. ADDRESS DOES NOT EXIST-NUMBERS GO
FROM 444 TO 504.
Sincerely,
Carl E. Nace
Sworn and subscribed to before me Sheriff of Perry County
this JO-Eh day of , 2013.
Ira,,y, '4-4
C ONvVEAITH OF pENNSYLVANIA
WI
NOTARIAL SEAL QubliC
AppqE F.FLICKINGER,Notary
Aspprnfield Born,Perry Cau 8,
lion Expires February
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORPORATION,
vs.
Civil Action - In Law
Plaintiff, No. 13 -6107 Civil
ARBITRATION
c-3
JOHN C. MEARS JR.,
CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENA
PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena for documents and things pursuant to Rule
4009.22, I certify that:
Defendant.
1. a notice of intent to serve the subpoena with a copy of the subpoena attached thereto
was mailed or delivered to each party at least twenty (20) days prior to the date on
which the subpoena is sought to be served;
2. a copy of the notice of intent, including the proposed subpoena, is attached to this
certificate;
3. no objection has been received; and
4. the subpoena which will be served is identical to the subpoena which is attached to
the notice of intent to serve subpoena.
DATED: March 3, 2014
BY:
KRZYWICKI & e _ OCIATES, P.C.
ew ope,
(215) 862 -4
Attorney I.D. 23754
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORPORATION,
VS.
JOHN C. MEARS JR.,
Civil Action - In Law
Plaintiff, No. 13-6107 Civil
Defendant.
ARBITRATION
NOTICE OF INTENT TO SERVE A SUBPOENA
TO PRODUCE DOCUMENTS AND THINGS FOR
DISCOVERY PURSUANT TO RULE 4009.21
PPL Electric Utilities Corporation intends to serve a subpoena identical to the one that is
attached to this notice. You have twenty (20) days from the date listed below in which to file of
record and serve upon the undersigned an objection to the subpoena. If no objection is made the
subpoena may be served.
Dated: February 10, 2014
KRZYWICKI & ASS TES, P.C.
215) 862-4
Attorney for ntiff
PA Attorney ID 23754
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORPORATION,
Civil Action - In Law
Plaintiff, No. 13-6107 Civil
vs. ARBITRATION
JOHN C. MEARS JR.,
Defendant.
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: PennDOT, Driver Licensing Services
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things:
Current address and basic driver information for John C. Mears Jr.
at Krzywicki & Associates, P.C., P.O. Box 505, New Hope, PA 18938
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek in advance the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving the subpoena may see a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
Name: Anthony P. Krzywicki, Esquire
Address: P.O. Box 505
New Hope, PA 18938
Telephone: 215-862-4390
Supreme Court ID # 23754
Attorney For: Plaintiff
Date:
BY THE COURT:
Prothonotary/Clerk, Civil Division
Seal of the Court Deputy
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORPORATION,
vs,
JOHN C. MEARS JR.,
Civil Action - In Law
Plaintiff, No. 13-6107 Civil
Defendant.
ARBITRATION
CERTIFICATE OF SERVICE
I certify that on this date, 1 served a copy of PPL Electric Utilities Corporation's Notice of Intent
to Serve Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21
on the persons listed below, by United States Mail, first class postage prepaid:
Dated: February 10, 2014
Mr. John C. Mears Jr.
316 N. Baltimore Avenue
Mount Holly Springs, PA 17065
By:
KRZYWICKI & ASSOCIATES, P.C.
(215) 862- 90
Attorney for Plaintiff
PA Attorney ID 23754
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORPORATION,
vs.
JOHN C. MEARS JR.,
Civil Action - In Law
Plaintiff, No. 13 -6107 Civil
Defendant.
ARBITRATION
CERTIFICATE OF SERVICE
I certify that on this date, I served a copy of the Certificate Prerequisite to Service of
Subpoena Pursuant to Rule 4009.22 on the persons listed below, by United States Mail, first
class postage prepaid:
DATED: March 3, 2014
Mr. John C. Mears Jr.
316 N. Baltimore Avenue
Mount Holly Springs, PA 17065
BY:
2
KRZYWICKI
ATES, P.C.
thony P. Kr
Attorney
ox 5
New Hope, PA 1
(215) 862 -4390
Attorney I.D. 23754
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORPORATION,
Civil Action - In Law
Plaintiff, No. 13-6107 Civil
vs. ARBITRATION
JOHN C. MEARS JR.,
Defendant.
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Kindly reinstate the Complaint against the Defendant(s) in the above-captioned Civil Action
3 (2
for an additional thirty (30) days.
DATED: April 2, 2014
BY:
KRZYWICKI & IATES, P.C.
ew Hope, PA 1893
(215)862-4390
Attorney I.D. 23754
P 9c8,
r_JICY—f(51-1
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson t E 1J (F F i C
Sheriff ; THE PRO l HONO1AR
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
OF iF
2OI4 MAY -7 AMR I
CUMBERLAND COUNTY
PENNSYLVANIA
PPL Electric Companies Corp
vs.
John C Mears, Jr.
Case Number
2013-6107
SHERIFF'S RETURN OF SERVICE
04/07/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: John C Mears, Jr., but was unable to locate the Defendant in the
Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within
Complaint & Notice according to law.
04/15/2014 02:05 PM - The requested Complaint & Notice served by the Sheriff of York County upon John C Mears,
Jr., personally, at 1 South Baltimore Street, Franklintown, PA 17323. Richard Keuerleber, Sheriff, Return
of Service attached to and made part of the within record.
SHERIFF COST: $37.00 SO ANSWERS,
May 01, 2014
(c) CountyS.uite Sheriff, Teleosoft, Inc.
RONR ANDERSON, SHERIFF
SHERIFF'S OFFICE OF YORK COUNTY
Richard P Keuerleber ¢ PETER J. MANGAN,
ES
Rhefiff �
Michael S. Hose { Richard E Rice
Chief Deputy, Operations Chief Deputy, Administrat,
PPL ELECTRIC UTILITIES CORPORATION
vs.
JOHN C. MEARS, JR.
Case Number
13-6107 CIVIL
SHERIFF'S RETURN OF SERVICE
04/15/2014 02:05 PM - DEPUTY TYLER STEPANCHICK, 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: JOHN C. MEARS, JR.
AT 1 SOUTH BALTIMORE STREET, APT 10, DILLSBURG, PA 17019.
SHERIFF COST: $67.80
TYLER STEPANCHICK, D--PUTY
SWERS,
April 29, 2014 '!CHARD P KEUERL BER, SH RIFF
COMMONWEALTH OF PENNSYLVANIA
Notarial Se&
Lisa L. Thorpe, Notary Public
City of York, York County
My Commission Expires Aug. 12, 2017
MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES
NOTARY
Affirmed and subscribed to before me this
29TH day of APRIL 2014
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORPORATION,
vs.
JOHN C. MEARS JR.,
Plaintiff,
Defendant.
To the Prothonotary:
Civil Action - In Law
No. 13-6107 Civil
ARBITRATION
PRAECIPE FOR JUDGMENT AGAINST
DEFENDANT FOR FAILURE TO PLEAD
COUNT I
PPL Electric Utilities Corporation vs.
John C. Mears Jr.
Kindly enter Default Judgment in favor of Plaintiff, PPL Electric Utilities Corporation,
and against Defendant, John C. Mears Jr., for failure to plead to Plaintiff's Complaint as follows:
Amount Due:
Court Fees:
Service Costs:
TOTAL:
$ 6,821.05
$ 103.75
$ 150.00
$ 7,074.80
together with interest thereon from the date of judgment forward and all costs of this action.
DA Ici
to. 56p
0J-74-1Y-syyt
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, John C. Mears Jr., is 1 S. Baltimore
Street, P.O. Box 12, Franklintown, Pennsylvania, 17323.
Dated: July 17, 2014
KRZYWICKI & AS i : TES, P.C.
Bo
New Hope, PA :938
(215) 862-4390
Attorney for Plaintiff
Attorney I.D. No. 23754
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORPORATION,
vs.
JOHN C. MEARS JR.,
Civil Action - In Law
Plaintiff, No. 13-6107 Civil
Defendant.
ARBITRATION
The undersigned hereby certifies that written notice of intention to file a Praecipe for Entry of
Judgment by default against the Defendant, John C. Mears Jr., 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.
Dated: July 17, 2014
KRZYWICKI & ASSOCIATES, P.C.
y for
9 North S
P.O. Box
New Hope, PA 189.8
(215) 862-4390
Attorney I.D. No. 23754
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORPORATION,
vs.
JOHN C. MEARS JR.,
Civil Action - In Law
Plaintiff, No. 13-6107 Civil
Defendant.
NOTICE
TO: Mr. John C. Mears Jr.
1 S. Baltimore Street
P.O. Box 12
Franklintown, PA 17323
ARBITRATION
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
(717) 249-3166
(800) 990-9108
DATE: June 25, 2014
KRZ
CKI & ASSOCI
ES .C.
Anthon '. 'ick' 'squire
ox 50
New Hop=, ' 18938
(215) 86 -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. 13-6107 Civil
vs. ARBITRATION
JOHN C. MEARS JR.,
Defendant.
AFFIDAVIT OF SERVICE
STATE OF PENNSYLVANIA)
ss.:
COUNTY OF BUCKS
I, ANTHONY P. KRZYWICKI, Attorney for Plaintiff, serve
the Notice of Intention to Take Default pursuant to PA. R.0
class mail on June 25, 2014.
Sworn to and subscribed before me
this ri")day of , 2014.
N&TARY PUBLIC
NOTARIAL SEAL
AMY M GLASGOW
Notary Public
NEW HOPE BORO., BUCKS COUNTY
My Commission Expires Mar 14, 2016
e and correct copy of
fendant(s), by first
y 10
KRZYWI
P.O. Bo
New ope, P
(215) 862-43
PA Attorne
05
0
ID #23754
8938
CIATES, P.C.
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORPORATION,
Civil Action - In Law
Plaintiff, No. 13-6107 Civil
vs. ARBITRATION
JOHN C. MEARS JR.,
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, John C. Mears Jr., 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, John C. Mears Jr., is more than 18 years of age and currently resides at
1 S. Baltimore Street, P.O. Box 12, Franklintown, Pennsylvania, 17323.
3. I have ascertained the above information by personal
Affidavit with due authority.
Sworn to and subscribed before me
this ( day of JUJ. 3 , 2014.
TARRY PUBLIC
NOTARIAL SEAL
AMY M GLASGOW
Notary Public
NEW HOPE BORO., BUCKS COUNTY
My Commission Expires Mar 14, 2016.
n and make this
•
SHERIFF'S OFFICE OF YORK COUNTY
Richard P Keuerleber
Sheriff
Michael S. Hose
Chief Deputy, Operations
PPL ELECTRIC UTILITIES CORPORATION
vs.
JOHN C. MEARS, JR.
PETER J. MANGAN, E
Soli
Richard E Ric
Chief Deputy, Administr
Case Number
13-6107 CIVIL
SHERIFF'S RETURN OF SERVICE
04/15/2014 02:05 PM - DEPUTY TYLER STEPANCHICK, 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: JOHN C. Iv1EARS, JR.
AT 1 SOUTH BALTIMORE STREET, APT 10, DILLSBURG, PA 17019.
I. rer
TYLER STEPANCHICK, DEPUTY
SHERIFF COST: $67.80
April 29, 2014
SWERS,
4ICHARD P KEUERL BER, SH RIFF
COMMONWEALTH OF PENNSYLVANIA
Notarial Sea!
Lisa L. Thorpe, Notary Public
City of York, York County
My Commission Expires Aug. 12, 2017
MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES
NOTARY
Affirmed and subscribed to before me this
29TH day of APRIL 2014
•
OFFICE OF THE CLERK OF COURT
COUNTY OF COMMON PLEAS
CUMBERLAND COUNTY COURTHOUSE * CARLISLE, PA 17013
David D. Buell
Prothonotary
TO: Mr. John C. Mears Jr.
1 S. Baltimore Street
P.O. Box 12
Franklintown, PA 17323
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORPORATION,
vs.
JOHN C. MEARS JR.,
Civil Action - In Law
Plaintiff, No. 13-6107 Civil
ARBITRATION
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.
(XX) Judgment by Default
) Money Judgment
) Judgment in Replevin
) Judgment for Possession
) Judgment on Award of Arbitration
) Judgment on Verdict
) Judgment on Court Findings
David D. Buell
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