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HomeMy WebLinkAbout13-6679 Supreme Co -o Pennsylvania COUP '�COnnm For Prothonotary Use Only: C. ><1 � Docket No: Curn e land County The in collected on this fibrin is used solely for court adrninistration purposes. This form does not suppleinent or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S © Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: PPL Electric Utilities Corporation Matthew C. Barnard T Dollar Amount Requested: ❑✓ within arbitration limits I Are money damages requested? ❑✓ Yes ❑ No (check one) ❑outside arbitration limits O N Is this a Class Action Suit? ❑ Yes ❑✓ No Is this an MDJAppeal? ❑ Yes ❑✓ No ! � A Name of Plaintiff /Appellant's Attorney: Anthony P. Krzywicki, Esquire ❑ Check here if you have no attorney (are a Self - Represented 1Pro Sel Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that E 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 0 Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections Nuisance Dept. of Transportation Premises Liability B Statutory Appeal: Other S Product Liability (does not include mass tort) ❑Employment Dispute: E Slander/Libel/ Defamation Discrimination C e 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 ❑Ejectment ❑Common Law /Statutory Arbitration B Other: ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment e Ground Rent Mandamus ❑ Landlord/Tenant Dispute e Non - Domestic Relations Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 1/1/2011 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, Civil Action - In Law C' Plaintiff, No. 3 _ (t U vs. ARBITRATION MATTHEW C. BARNARD, Defendant. COMPLAINT 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 r:1 may be entered against you by the Court without further notice for any money claimed in the r"rT ::arm Complaint or for any other claim or relief - -4+: requested by the Plaintiff. You may lose money or m C; property or other rights important to you. G C 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249 -3166 (800) 990 -9108 (l Q� 7 a 716 CI IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, Civil Action - In Law Plaintiff, No. vs. ARBITRATION MATTHEW C. BARNARD, 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, MATTHEW C. BARNARD, is an adult individual residing at 456 Falling Springs Road, Landisburg, Pennsylvania, 17040. 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. MATTHEW C. BARNARD 5. Defendant, MATTHEW C. BARNARD, 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 August 29, 2012, struck and damaged a utility pole and overhead facilities owned and operated by PPL ELECTRIC UTILITIES CORPORATION at the vicinity of 7249 Wertzville Road, 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 $5,431.43, including costs and attorneys fees. WHEREFORE, Plaintiff, PPL ELECTRIC UTILITIES CORPORATION, demands judgment against the Defendant in an amount of $5,431.43, including costs, prejudgment and post judgment interest, attorney's fees, punitive damages and delay damages as the law may allow. Respectfully submitted, KRZYWICKI & ASSOCIATES, P.C. DATED: November 7, 2013 By: Ant ony P. Kr is it At rney f lai i P. . x 505 New Hope, PA 189 (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: November 7, 2013 NTH P. I I, ESQUIRE SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff r i _ t ,, i �,,tti Jody S Smith `.. LI Chief Deputy g .� 7 i Richard W Stewart "F t� P;Lht i ,; Solicitor OP-Cr-. ...r. 'EU SYLVANI PPL Electric Utilities Corporation Case Number vs. 2013-6679 Matthew C Barnard SHERIFF'S RETURN OF SERVICE 11/13/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Matthew C Barnard, but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Complaint&Notice according to law. 12/12/2013 The requested Complaint& Notice returned by the Sheriff of Perry County, the within named Defendant Matthew C Barnard, not found. Carl E. Nace, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $37.00 SO ANSWERS, December 12, 2013 RONNR ANDERSON, SHERIFF SHERIFF'S RETURN In the Court of Common Pleas Of the 41st Judicial District of Pennsylvania- Perry County Branch No.: 2013-6679 Cumberland Co. PPL Electric Utilities Corp. VS Matthew C.Barnard 456 Falling Springs Road Landisburg,PA 17040 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 Matthew C. Barnard,but was unable to locate him/her in his bailiwick. He therefore returns the within Complaint for the above named Defendant(s) Matthew C.Barnard at 456 Falling Springs Road,Landisburg,PA 17040. NOT FOUND. UNABLE TO MAKE SERVICE-DEFENDANT LIVES AT ADDRESS BUT NOBODY IS HOME DURING BUSINESS HOURS TO SERVE. COMPLAINT EXPIRED. Sincerely, r.".47: Nt•ce Carl E.Nace Sworn an subscribed to before me Sheriff of Perry County this //` day of tL m&r, 2013. - ziaTt-fidz- -Wt-feilg a,c COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL MARGARET F.FLICKINGER,Notary Public Bloomfield Boro,Perry County My Commission Expires February 16,2016 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson cif C.MU ar,f,9 Sheriff k"�a'�, r i ICS: 50 Jody S Smith { y� : ' Richard W Stewart Chief Deputy r utY Solicitor PPL Electric Utilities Corporation vs. Case Number Matthew C Barnard 2013-6679 o SERVICE COVER SHEET I= g Service Details: • Category: Civil Action -Complaint& Notice w p ..._. a .... Zone: O Manner: Deputize Expires:p � Warrant: G Notes: .. ti a (9 co Serve To: Final Seriefee =.. oName: Matthew C Barnard Served: Personally • Adult In Charge • Posted • Other Q Primary 465 Falling Springs Road Adult In —r Address: Landisburg, PA 17040 Charge: 0 oO Phone: Relation: DOB: -- 0 Alternate z Address: Date: Time: a. Phone: Deputy: Mileage: J ney/Attar Originator: `t w Name: Krz y wicki & PC Phon e: 215-862-4390 � cp `. ✓ Service Attempts: Date: Time: co MEI 19 Mileage: N Deputy: MINI Mill MI= Notes/Special Instructions: U w 2 I— F- g Now, November 13', 2013 I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of Dauphin County tc o execute service of the documents herewith and make return thereof according to law. cc z Return To: Q Cumberland County Sheriff's Office m One Courthouse Square Carlisle, PA 17013 Ronny R Anderson, Sheriff NAME: Anthony P. Krzywicki, Esquire Krzywicki& Associates, P.C. ADDRESS: P.O. Box 505 New Hope, PA 18938 Jv c. PHONE: 215-862-4390 f> IN THE COURT OF COMMON PLEAS, PERRY COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, : Civil Action -In Law Plaintiff, • No. • vs. A RBITRATION MATTHEW C. BARNARD, Defendant. : TO THE DEPUTY OF PERRY COUNTY: Please serve Defendant personally or in the alternative an adult member of the household willing to accept service on his/her behalf. PLEASE SERVE: Matthew C. Barnard 456 Falling Springs Road Landisburg, PA 17040 COUNTY: Perry County c_n RETURN OF SERVICE 77, SERVICE ATTEMPTS: Date: Time Date Date: Person served: Date: Relation: Date: Place of Service: Date: Deputy: IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, : Civil Action - In Law Plaintiff, : No. 13-6679 Civil vs. • ARBITRATION • MATTHEW C. BARNARD, t=3. Defendant. : -el?' o- r, r~ .-o _.. PRAECIPE TO REINSTATE COMPLAINT '; c..� TO THE PROTHONOTARY: Kindly reinstate the Complaint against the Defendant(s)in the above-captioned Civil Action for an additional thirty(30) days. KRZYWICKI&A .: IATES,P.C. DATED: December 20, 2013 / BY: Ant ony P. .;* 'cki,E • e A rorne •r ' aintif P.O. :ox 5i5 New Hop-, 'A 189. : (215)862-4390 Attorney I.D. 23 4 CO 4//. -P4E/944kf /7,396 R,4-0299zl2 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Cr THE PROTHCNC iA I Sheriff St B, 1 k: DI d 3P#idt`tawp)� Jody S Smith 2014 FEB -4 FM 3: l 9 Chief Deputy CUMBERLAND COUNTY Richard w Stewart Solicitor PENNSYLVANIA , ~' PPL Electric Utilities Corporation vs. Case Number Matthew C Barnard 2013-6679 SHERIFF'S RETURN OF SERVICE 12/27/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Matthew C Barnard, 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. 01/29/2014 The Sheriff of Perry County, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Matthew C Barnard, but was unable to locate the Defendant in his bailiwick. The Perry County Sheriff therefore returns the within requested Complaint& Notice as "Not Served"at 465 Falling Springs Road, Landisburg, PA 17040. SHERIFF COST: $37.49 SO ANSWERS, W":"/2 January 29, 2014 RON& R ANDERSON, SHERIFF SHERIFF'S RETURN In the Court of Common Pleas Of the 41st Judicial District of Pennsylvania- Perry County Branch No.: 2013-6679 Cumberland Co. PPL Electric Utilities Corp. VS Matthew C.Barnard 465 Falling Springs Road Landisburg,PA 17040 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 Matthew C. Barnard,but was unable to locate him/her in his bailiwick. He therefore returns the within Complaint for the above named Defendant(s) Matthew C.Barnard at 465 Falling Springs Road,Landisburg,PA 17040. NOT FOUND. UNABLE TO MAKE SERVICE BEFORE COMPLAINT EXPIRED EVEN AFTER MAKING AN EVENING ATTEMPT. Sincerely, r--/C(7 ,0440, Carl E. Nace Sworn and subscribed to before me Sheriff of Perry County this o24(-14 day of S Hair, 2014. 1 4 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL MARGARET F.FLICKINGER,Notary Public Bloomfield Boro,Perry County My Commission Expires February 16,2016 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, Civil Action - In Law Plaintiff, No. 13-6679 Civil vs. ARBITRATION MATTHEW C. BARNARD, Defendant. rn 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&ASSOCI TES,P.C. DATED: February 7, 2014 BY: ny P. K&Kicki s e Attorney for Plaintiff P.O. Box 505 New Hope,PA 18938 (215)862-4390 Attorney I.D. 23754 • S 0 41� -6 d Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY CF THE PROTHONOTARY 7 Ati 10: 00 CUMBERLAND COUNTY PENNSYLVANIA oF fl1 $RERFF PPL Electric Utilities Corporation vs. Matthew C Barnard Case Number 2013-6679 SHERIFF'S RETURN OF SERVICE 02/14/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Matthew C Barnard, 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. 03/12/2014 The requested Complaint & Notice returned by the Sheriff of Perry County, the within named Defendant Matthew C Barnard, not found. Carl E. Nace, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $37.00 SO ANSWERS, March 12, 2014 RONNY R ANDERSON, SHERIFF (c) CauntySuite Sheriff. Teleooft, SHERIFF'S RETURN In the Court of Common Pleas Of the 41st Judicial District of Pennsylvania - Perry County Branch No.: 2013 -6679 Cumberland Co. PPL Electric Utilities Corp. VS Matthew C. Barnard 465 Falling Springs Road Landisburg, PA 17040 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 Matthew C. Barnard, but was unable to locate him/her in his bailiwick. He therefore returns the within Complaint for the above named Defendant(s) Matthew C. Barnard at 465 Falling Springs Road, Landisburg, PA 17040. NOT FOUND. NOT ABLE TO MAKE SERVICE BEFORE COMPLAINT EXPIRED- NOBODY AT RESIDENCE DURING THE DAY, NO CONTACT MADE. Sworn and subscribed to before me this //4 day of {a,v`eiG , 2014. --Mkt /L / i COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL MARGARET F. FLICKINGER, Notary Public -Bloomfield Boro, Perry County My Commission Expires February 16, 2016 Sincerely, r, Carl E. Nace Sheriff of Perry County IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, VS. MATTHEW C. BARNARD,. Civil Action - In Law Plaintiff, No. 13-6679 Civil Defendant. ARBITRATION 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: March 19, 2014 Hop (215)86 39 Attorney I.D. 23754 SHERIFF'S OFFICE OF CUMBERLAND COUNTY THE R Ronny R Anderson ICI 17 Sheriff 0 TII-ON ot Jody S Smith Chief Deputy Richard W Stewart Solicitor ,Lts' OF Fu-,E QF rf-IS V4E-Ripe 2014 APR -7 PM 3: 22 CUMBERLAND COUaY PENNSYLVANIA PPL Electric Utilities Corporation vs. Matthew C Barnard Case Number 2013-6679 SHERIFF'S RETURN OF SERVICE 03/25/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Matthew C Barnard, 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. 04/03/2014 The requested Complaint & Notice returned by the Sheriff of Perry County, the within named Defendant Matthew C Barnard, not found. Carl E. Nace, Sheriff, Return of Service attached to and made part of the within record. *Defendant's Father will not accept service for Defendant states that the defendant is at the University of Pittsburgh, Bradford Campus, 300 Campus Drive, Bradford, PA, 16701 which is located in McKean County. SHERIFF COST: $37.00 SO ANSWERS, April 03, 2014 RON R ANDERSON, SHERIFF (iri) County:Suite Sheriff, Toiciosoft. SHERIFF'S RETURN In the Court of Common Pleas Of the 41" Judicial District of Pennsylvania- Perry County Branch No.: 2013-6679 Cumberland County PPI Electric Utilities Corp. VS Matthew C. Barnard 465 Falling Springs Rd. Landisburg, PA 17040 Carl E. Nace, Sheriff, who being duly sworn according to law, says that he made a diligent search and inquiry for the within named Defendant(s) to wit Matthew C. Barnard, but was unable to locate him/her in his bailiwick. He therefore returns the within Complaint for the above named Defendant(s) Matthew C. Barnard at 465 Falling Springs Rd. Landisburg, Pa 17040 NOT FOUND. DEFENDANTS FATHER WILL NOT ACCEPT SERVICE FOR HIM. HE STATES DEFENDANT IS AT THE UNIVERSITY OF PITTSBURGH, BRADFORD CAMPUS, 300 CAMPUS DR. BRADFORD, PA 16701, THIS IS IN McKEAN COUNTY. PHONE 1-800-8724787. Sworn and subscribed to before me this ,2v d day of A-er , 2014. COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL MARGARET F. FUCKINGER, Notary Public Bloomfield Boro, Perry County My Commission Expires February 16, 2016 Sincerely, Carl E. Nace Sheriff of Perry County IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, vs. MATTHEW C. BARNARD, Civil Action - In Law Plaintiff, No. 13-6679 Civil Defendant. ARBITRATION PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: "c-, Kindly reinstate the Complaint against the Defendant(s) in the above -captioned Civil `Action for an additional thirty (30) days. DATED: April 30, 2014 BY: KRZYWICKI & : * C IATES, P.C. New Ho (215)862-4390 Attorney I.D. 23754 C_J_-.6 i Pr as 1�u. '3,(,53$a SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson apt tttl4l t7 rd EU -OFF Ii. Sherif �"_ THE Rfii i : iciruPlorJody S Smith 201.41 MAY 1 it PH 3: 10 Chief Deputy Richard W Stewart '`' CUMBERLAND COUNTY Solicitor PENNSYLVANIA OFF i ; OF 1142 �L_RIFF PPL Electric Utilities Corporation vs. Matthew C Barnard Case Number 2013-6679 SHERIFF'S RETURN OF SERVICE 05/06/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Matthew C Barnard, 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. 05/07/2014 12:25 PM - The requested Complaint & Notice served by the Sheriff of Perry County upon Matthew C Barnard, personally, at 465 Falling Springs Road, Landisburg, PA 17040. Carl E. Nace, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $37.00 SO ANSWERS, May 09, 2014 RONR ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft, Inc. PPL Electric Utilities Corp. Versus Matthew C. Barnard IN THE COURT OF COMMON PLEAS OF THE 41st JUDICIAL DISTRICT OF PENNSYLVANIA, PERRY COUNTY BRANCH No. 2013-6679 Cumberland Co. SHERIFF'S RETURN And now May 7 , 2014: Served the within name Matthew C. Barnard the defendant(s) named herin, personally at his place of residence in Spring Twp -465 Falling Springs Rd. Landisburg, PA Perry County, PA, on May 7 , 2014 at 12:25 o'clock PM by handing to Matthew C. Barnard, Def. copy(ies) of the within Complaint and made known to him the contents thereof Sworn and subscribed to before me this %l day of 4108 , aopy indtg,f4 y -'.1112L-6,24 att,p,„,„ft----__P-r4444eRetiOy COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL MARGARET F. FLICKINGER, Notary Public Bloomfield Boro, Perry County My Commission Expires February 16, 2016 1 true and attested So answers Deputy Sheriff of Perry County IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, Civil Action - In Law Plaintiff, No. 13-6679 Civil vs. ARBITRATION MATTHEW C. BARNARD, Defendant. To the Prothonotary: PRAECIPE FOR JUDGMENT AGAINST DEFENDANT FOR FAILURE TO PLEAD COUNT I PPL Electric Utilities Corporation vs. Matthew C. Barnard Kindly enter Default Judgment in favor of Plaintiff, PPL Electric Utilities Corporation, and against Defendant, Matthew C. Barnard, for failure to plead to Plaintiff s Complaint as follows: Amount Due: $ 3,802.68 Court Fees: $ 103.75 Service Costs: $ 225.00 TOTAL: $ 4,131.43 together with interest thereon from the date of judgment forward and all costs of this action. ti4//83(,y 0 3o -)c -GK ])'e /'flaL/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, Matthew C. Barnard, is 465 Falling Springs Road, Landisburg, Pennsylvania, 17040. Dated: June 16, 2014 KRZYWIC SSOCIATES, P.C. Ant cki, E No P.O. Box 50 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, vs. MATTHEW C. BARNARD, Civil Action - In Law Plaintiff, No. 13-6679 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, Matthew C. Barnard, 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: June 16, 2014 KRZYWICKI & ASSOCIATES, P.C. orne 49 North - ' oad P.O. Box 05 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, vs. MATTHEW C. BARNARD, Civil Action - In Law Plaintiff, No. 13-6679 Civil Defendant. NOTICE TO: Mr. Matthew C. Barnard 465 Falling Springs Road Landisburg, PA 17040 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: DATE: June 5, 2014 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 KRZYWIC .00IATES, P.C. (21 86 Attorne . 1. 23754 Attorney for Plaintiff i IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, Civil Action - In Law Plaintiff, No. 13-6679 Civil vs. ARBITRATION MATTHEW C. BARNARD, 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 . on P efendant(s), by first class mail on June 5, 2014. Sworn to and subscribed before me this 114h day of U( Q _ , 2014. NaARY PUBLIC NOTARIAL SEAL AMY M GLASGOW Notary Public NEW HOPE BORO., BUCKS COUNTY My Commission Expires Mar 14, 2016 i, Esquire y fo 'ntiff YWICKI & ASSOCIATES, P.C. P.O. Box 505 New Hope, PA 18938 (215) 862-4390 PA Attorney ID #23754 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, Civil Action - In Law Plaintiff, No. 13-6679 Civil vs. ARBITRATION MATTHEW C. BARNARD, 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, Matthew C. Barnard, 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, Matthew C. Barnard, is more than 18 years of age and currently resides at 465 Falling Springs Road, Landisburg, Pennsylvania, 17040. 3. I have ascertained the above information by persona ' estigafio ► and .• . e this Affidavit with due authority. Sworn) to and subscribed before me this J�lhday of 1_e1,p_ , 2014. OTMA\ PU : IC NOTARIAL SEAL AMY M GLASGOW Notary Public NEW HOPE BORO., BUCKS COUNTY My Commission Expires Mar 14, 2016 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY .lp pi Cir and ber,' rjr‘o yU� QC PPL Electric Utilities Corporation vs. Matthew C Barnard Case Number 2013-6679 SHERIFF'S RETURN OF SERVICE 05/06/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Matthew C Barnard, 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. 05/07/2014 12:25 PM - The requested Complaint & Notice served by the Sheriff of Perry County upon Matthew C Barnard, personally, at 465 Failing Springs Road, Landisburg, PA 17040. Carl E. Nace, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $37.00 SO ANSWERS, May 09, 2014 RONNY R ANDERSON, SHERIFF ;c) CounhySulte Sherri, Toleoscfi Inc OFFICE OF THE CLERK OF COURT COUNTY OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE * CARLISLE, PA 17013 David D. Buell Prothonotary TO: Mr. Matthew C. Barnard 465 Falling Springs Road Landisburg, PA 17040 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, vs. MATTHEW C. BARNARD, Civil Action - In Law Plaintiff, No. 13-6679 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 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, vs. MATTHEW C. BARNARD, Civil Action - In Law Plaintiff, No. 13-6679 Civil Defendant. ARBITRATION AFFIDAVIT OF MOTOR VEHICLE JUDGMENT STATE OF PENNSYLVANIA) ss.. COUNTY OF BUCKS ) I, ANTHONY P. KRZYWICKI, Attorney for Plaintiff, verify that the above referenced caption is due to a motor vehicle accident. Antl}ony P. Krzy ' i`squir Attoney, f. KRZI{IC & ASSOCIATES, P.C. P.O. Box 505 New Hope, PA 18938 (215) 862-4390 PA Attorney ID #23754 Sworn to and subscribed before me 2-44 this day of , /2-K2013. NOT Y PUBLIC NOTARIAL SEAL AMY M GLASGOW Notary Public NEW HOPE BORO., BUCKS COUNTY My Commission Expires Mar 14, 2016 s. cis p d /.htl� C�/ 9363 e�3i1/97q