HomeMy WebLinkAbout05-1867
In the Court of Common Pleas of Cumberland County, Pennsylvania
PPL Electric Utilities Corp.
Plaintiff Civil Action - In Law
VS. No.US _IJe CW
Bret Michael Fitzpatrick
Horizon Satellites, Inc.
Defendant ARBITRATION
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 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
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
PPL Electric Utilities Corp.
Plaintiff
vs.
Civil Action - In Law
No. n g - /PL
Bret Michael Fitzpatrick
Horizon Satellites, Inc.
Defendants
COMPLAINT
ARBITRATION
This is an action by Plaintiff, PPL Electric Utilities Corp. to recover damages
from Defendant arising out of a vehicular collision which caused damage to property owned by
Plaintiff.
2. PPL Electric Utilities Corp. 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, PA
18101.
3. Defendant, Bret Michael Fitzpatrick, is an adult individual residing at 343 Walton
Street, Lemoyne, PA 17043.
4. Defendant, Horizon Satellites, Inc., is a foreign corporation doing business at 295
Oakwood Drive, Cedartown, GA 30125.
5. At all times relevant hereto, Plaintiff was engaged in the business of producing,
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
Plaintiffs Tariff presently on file with the Public Utility Commission.
COUNTI
PPL Electric Utilities Com. vs. Bret Michael Fitzpatrick
Defendant, Bret Michael Fitzpatrick while operating a vehicle and collided with
and damaged property owned by Plaintiff.
9. Defendant negligently operated the vehicle in that he:
a) operated said vehicle at an excessive rate of speed under the
circumstances;
b) failed to have said vehicle under proper and adequate control;
C) failed to keep a proper lookout;
d) operated said vehicle in a reckless and careless manner;
e) failed to keep vehicle in the proper lane of travel;
f) failed to operate the vehicle within the posted speed limit or failed to
operate the vehicle at a reasonable speed under the circumstances;
g) failed to remain alert and attentive under the circumstances;
h) operated the vehicle without due regard for the rights, safety and position
of the plaintiff;
i) operated the vehicle in a manner violating the statutes of the
Commonwealth of Pennsylvania governing the operation of vehicles on
public streets, highways and roadways;
j) being negligent at the law;
k) such other acts or omissions constituting carelessness, negligence and
recklessness may be ascertained during discovery or developed at the time
of trial.
10. Defendant struck and damaged a utility pole and overhead facilities owned and
operated by PPL Electric Utilities Corp., at the vicinity of Route 115, by Race Track, Blakeslee,
PA on or about August 30, 2004.
It. Defendant's actions or inaction as set forth above are the proximate cause of the
damages as set for above and herein.
12. Plaintiff made demand on Defendant to repay the sums then due and owing to
Plaintiff, but Defendant has refused to pay Plaintiff.
13. Plaintiff has been damaged in the amount of $3077.68 plus costs and attorneys
fees.
WHEREFORE, Plaintiff PPL Electric Utilities Corp. demands judgment against the
Defendant in an amount of $3077.68 including costs, prejudgment and post judgment interest,
attorney's fees, punitive damages and delay damages as the law may allow.
COUNT II
PPL Electric Utilities Corp. vs. Horizon Satellites Inc
14. Paragraphs 1 through 13 are incorporated as referenced as if fully set forth herein.
15. At all time relevant hereto, defendant, Horizon Satellites, Inc., were the owner of
the vehicle driven by defendant Bret Michael Fitzpatrick that hit the active utility pole and
overhead facilities.
16. At the time of the aforesaid accident, Defendant, Horizon Satellites, Inc. was
responsible for the actions of his agent, Bret Michael Fitzpatrick.
17. The aforementioned damages were the direct and proximate result of the
negligence of defendant, Horizon Satellites, Inc., including negligent acts and/or omissions of
defendant as performed individually and/or by and through others permitted to drive their vehicle
more specifically described as follows:
a) negligently entrusting the aforesaid vehicle to defendant, Bret Michael
Fitzpatrick;
b) negligently and carelessly failing to properly and adequately supervise
and/or train defendant, Bret Michael Fitzpatrick, in the operation of his/her vehicle;
C) negligently and carelessly failing to properly supervise the operation and
control of said vehicle;
d) negligently and carelessly failing to act with due care and regard for the
safety of others on the streets and highways;
e) violating the ordinances and the statutes of the Commonwealth of
Pennsylvania governing safe operation of motor vehicles on the streets and highways and;
f) otherwise failing to exercise reasonable care under the circumstances.
18. As a direct and proximate result of the negligence of defendant, Horizon
Satellites, Inc., plaintiff sustained damages as described above.
19. Plaintiffs property damage is in the amount of $3077.68.
WHEREFORE, Plaintiff PPL Electric Utilities Corp. demands judgment against the
Defendant in an amount of $3077.68 including costs, prejudgment and post judgment interest,
attorney's fees, punitive damages and delay damages as the law may allow.
Associates
DATED: April 8, 2005
By:
18938
Attorney I.D. 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 unswom
falsification to authorities.
Dated: April 8, 2005
44
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2005-01867 P
r COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
PPL ELECTRIC UTILITIES CORP
VS
FITZPATRICK BRET MICHAEL ET AL
R. Thomas Kline Sheriff or Deputy Sheriff, who eing
duly sworn according to law, says, that he made a diligent sea ch and
inquiry for the within named DEFENDANT
FITZPATRICK BRET MICHAEL
unable to locate Him in his bailiwick. He therefore returns
COMPLAINT & NOTICE ,
, NOT FOUND
the within named DEFENDANT FITZPATRICK BRET MICHAEL
343 WALTON STREET
LEMOYNE, PA 17043
PER DEFENDANT'S MOTHER, HE HAS NOT LIVED AT
GIVEN ADDRESS FOR 2 YEARS & SHE DOES NOT KNOW WHERE HE IS.
Sheriff's Costs: So answers:----- >
Docketing 18. 00
Service 10. 36 -,J
Not Found 5. 00 R. Thomas Kline
Surcharge 10. 00 Sheriff of Cumberland County
.00
43. 36 KRZYWICKI & ASSOCIATES
04/20/2005
Sworn and subscribed to before me
this day of
D.
rothonotary
was
as to
KRZYWICKI & ASSOCIATES
Anthony P. Krzywicki, Esquire
John L. Shearburn, Esquire
P.O. Box 505
New Hope, PA 18938
(215)862-4390
Attorney for Plaintiff
Attorney 1 D. 2 3 75 412 68 5 2
---------------------------
PPL Electric Utilities Corp
Plaintiff Court of Common Pleas
Cumberland County
VS. Civil Action
Bret Michael Fitzpatrick No. 05-1867
Horizon Satellites, Inc.
Defendant(s)
--------------------------------
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 days.
DATED: May 5, 2005
BY:
KRZYWICKI & ASSOCIATES
SHERIFF'S RETURN - REGULAR
CASE NO: 2005-01867 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PPL ELECTRIC UTILITIES
VS
FITZPATRICK BRET MICHAEL ET AL
SGT. JODY SMITH
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
FITZPATRICK BRET MICHAEL the
DEFENDANT , at 1250:00 HOURS, on the 23rd day of May , 2005
at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE
CARLISLE, PA 1701
BRET FITZPATRICK
by handing to
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 11.10
Affidavit .00
Surcharge 10.00
.00
39.10
Sworn and Subscribed to before
me this dq'" day of
,LUJ A. D.
r! _ ( a 0 h-t.et=e*-
r thonotary
So Answers:
R. Thomas Kline
05/23/2005
KRZYWICKI & ASSOCIATES
By;
Sal ?
0 Deputy Sheriff
PPL Electric Utilities Corp.
Vs.
Bret Michael Fitzpatrick
1. This is an action by Defendant, Bret Michael Fitzpatrick, to agree or dispute the
complaints brought upon him in Count 1, PPL Electric Utilities Corp. vs. Bret
Michael Fitzpatrick. Defendant will write in first person and be referred to as `I'.
&. I agree that the following statement as written is true.
9.
a. I disagree with the statement and as was told to the two (2) police officers
at the scene of the accident, I was traveling at a speed no greater then
twenty-five (25) mph.
b. I disagree with this statement stating that I was not driving out of control.
The road that I was driving on allowed for no marginal error.
c. I disagree with this statement and note again that I was not driving out of
control. I was completely aware of what was going on around me which
allowed me to not roll my vehicle as was stated had happened two (2) days
prior.
d. I disagree with this statement and driving record will show that I am not a
reckless or careless driver. My speed was appropriate,
c. I disagree with this statement. I was in my own lane of travel. I never
crossed into apposing traffic.
f I disagree with this statement and as stated above and at the time of the
accident, I was traveling at a speed no greater then twenty-five (25) mph.
g. I disagree with this statement. I was alert and attentive at all times. The
road left for no margin of error, however while sliding down the
embankment, I kept my vehicle under as much control as possible. An
PPL Electric Utilities Corp.
Vs.
Bret Michael Fitzpatrick
accident two (2) days prior disrupted the normal embankment and created
a rut that forced my vehicle to travel in a set direction.
h. I disagree with this statement. I was the only person involved. No one was
injured and the regard for the Plaintiff was not in my mischievous plan. As
stated above, once I was over the embankment, the rut forced me into the
pole.
i. I agree with this statement only and in frill compliance with if the
statement means that my vehicle left the roadway.
j. I disagree with this statement. I operated my vehicle in a safe and
professional way. I was professional and courteous in all manners of
business that took part on this day.
k. There is nothing to agree of disagree with on this account
10. I agree with this statement
11.1 agree with this statement
12. I disagree with this statement. It was not until I was served with the lawsuit that I
knew anything about negligence of pay. PPL Electric Utilities Corp. never sent
paper work or any other document that stated I was to pay for damages. There
was no refusal on my part. I plead ignorance of this entire situation. The reason
for insurance on the vehicle is to pay for accidents.
13. I would like to have in my possession, copies of all damages the plaintiff is
claiming.
PPL Electric Utilities Corp.
Vs.
Bret Michael Fitzpatrick
14. I ask of the court that the decision be found in my favor with respect for Horizon
Entertainment.
Si el}
Bret Michael Fitzpatrick
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2134PD
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Cumberland County Courthouse * Carlisle, PA 17013
Curtis R. Long
Prothonotary
TO: Horizon Satellites, Inc.
295 Oakwood Drive
Cedartown, GA 30125
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
PPL Electric Utilities Corp.
Plaintiff
Civil Action - In Law
vs
Bret Michael Fitzpatrick
Defendant
Horizon Satellites, Inc.
Defendant
No. 05-1867-CIVIL TERM
ARBITRATION
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified t t a
Judgment has been entered against you in the above proceedi nyJ'a-s ind; i-c at`e I?)bel
Curtis R. Long
(XX) Judgment by Default Prothonotary
( ) Money Judgment
) Judgment in 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. Krzywicki
Krzywicki and Associates
49 North Sugan Road
P.O. Box 505
New Hope, PA 18938
215-862-4390
Attorney I.D. No.23754
2134PD
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
PPL Electric Utilities Corp.
Plaintiff
Civil Action - In Law
vs
Bret Michael Fitzpatrick
Defendant
Horizon Satellites, Inc.
Defendant
No. 05-1867-CIVIL TERM
ARBITRATION
PRAECIPE FOR JUDGMENT AGAINST
DEFENDANT FOR FAILURE TO PLEAD
To the Prothonotary:
COUNT 1
PPL Electric Utilities Corp. vs.
Inc. Horizon Satellites
Kindly enter default judgment in favor of Plaintiff, PPL
Electric Utilities Corp. and against Defendant, Inc. Horizon
Satellites for failure to plead to Plaintiff's Complaint as follows:
Amount Past Due:
TOTAL
$ 3077.68
$ 3077.68
together with interest thereon from the date of judgment forward
and all costs of this action.
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 Corp., is 827 Hausman Road, Allentown, PA 18104.
2134PD
2. The true and correct address of the Defendant, Horizon
Satellites, Inc., is 295 Oakwood Drive, Cedartown, Cedarwood County,
GA 30125.
Krzywicki 9.rfd Associates
DATED: June 29, 2005 By:
49 N Bth Road
P. 0. 5
New pe, PA 18938
215-862-4390
Attorney for Plaintiff
Attorney I.D. 23754
Z C 34-M
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PPL Electric Utilities Corp.
Plaintiff
VS.
Bret Michael Fitzpatrick
Horizon Satellites Inc.
Defendant
Civil Action - In Law
No. 05-1867-Civil
AFFIDAVIT OF CERTIFICATION OF MAILING
STATE OF JERSEY
SS.
COUNTY OF HUNTERDON
I, Anthony P. Krzywicki, Attorney for Plaintiff, served a true and
correct copy of the Complaint in Civil Action on Defendant,
Horizon Satellites Inc., by certified mail (return receipt
attached) on April 18, 2005. 1---)
An on P, rz cki, Esq.
A o ey or jifTaintif
is and Associates
0. ox 505
New Hope, PA 18938
PA ID# 23754
215-862-4390
SWORN TO AND SUBSCRIBED
BEFORE ME THIS Z/ DAY
OF /'GYtC
,, l eGGO%/i?_
Notary Public
MICHEI_iC PYATT
ioTARY PURI..IC OF NEW JERSEY
^A'C C6MWSSION :_YPIRES JULY 9. 200
2134PD
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
PPL E ectric Uti sties Corp.
Plaintiff
vs
Civil Action - In Law
No. 05-1867-CIVIL TERM
Bret Michael Fitzpatrick
Defendant
Horizon Satellites, Inc.
Defendant
ARBITRATION
NOTICE
TO: Horizon Satellites, Inc.
295 Oakwood Drive
Cedartown, GA 30125
Date: June 3, 2005
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 17013-3387
(717) 249-3166/(800) 990-9108
Krzywicki and Associates
By. 151
Anthony P. Rrzywi`cT i
49 North Sugan Road
P.O. Box 505
New Hope, PA 18938
215-862-4390
Attorney for Plaintiff
Attorney I.D. 23754
2134PD
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
PPL E ectric Utilities Corp.
Plaintiff
vs
Horizon Satellites, Inc.
Defendant(s)
STATE OF NEW JERSEY
COUNTY OF HUNTERDON
SS.
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
06/29/2005.
Atto ney for tiff,
Krz icki d sociates
P.O. 505
New Hope, PA 18938
PA ID# 23754
215-862-4390
SWORN TO AND SUBSCRIBED
BEFORE ME THIS 2y DAY
?2 , -?S?
OF ??n /
c
Civil Action - In Law
No. 05-1867-CIVIL TERM
AFFIDAVIT OF SERVICE
MICHELLE PYATT
NOTARY PUBLIC OF NEW JERSEY
P,A-f COMMISSION EXPIRES JULY 9, 204
2134PD
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
PPL Electric Utilities Corp.
Plaintiff
VS
Bret Michael Fitzpatrick
Defendant
Horizon Satellites, Inc.
Defendant
Civil Action - In Law
No. 05-1867-CIVIL TERM
ARBITRATION
The undersigned hereby certifies that written notice of intention to
file a praecipe for entry of judgment by default against the
defendant, Horizon Satellites, Inc., in this matter was mailed to
the defendant after the default occurred and at least ten 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 that notice is attached
hereto and made a part of this certification.
Krzywicki/angt Associates
DATED: June 29, 2005 By:
49 rth g oad
P.O Bo 50
Ne e, 18938
215-862-43 0
Attorney for Plaintiff
Attorney I.D. 23754
2134PD
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
PPL Electric Utilities Corp.
Plaintiff
Civil Action - In Law
vs
Bret Michael Fitzpatrick
Defendant
Horizon Satellites, Inc.
Defendant
No. 05-1867-CIVIL TERM
ARBITRATION
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF NEW JERSEY
ss.
COUNTY OF HUNTERDON
I, Anthony P. Krzywicki, being duly sworn according to law,
deposes and state that I am a representative of PPL Electric
Utilities Corp., 827 Hausman Road, Allentown, PA 18104, Plaintiff
herein, and as such state the following:
1. The defendant, Horizon Satellites, Inc., 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, Horizon Satellites, Inc., is more than 18
years of age and currently resides at 295 Oakwood Drive, Cedartown,
GA 30125.
3. I have ascertained the above informa by personal
investigation and make this affidavit with Oie uthority.
Sworn to and subscribed before
MICHELLE "AST
NOTARY PUBLIC OF NEW JERSEY
MY COMMISSION EXPIRES JULY 9, 200
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PPL F3eetric Utilities asp..
VS:
B:et ILdiael F1tqmtridc
IN THE COURT OF COMMON PLEAS OF
CM4BERLAND COUNTY, PENNSYLVANIA
N0. 05-1867 CIVIL 19
RULE 1312-1. The Petition for Appointment of arbitrators shall be substantially
in the following form:
PETITION FOR APP014YNENT OF ARBITRATORS
TO THE HONORABLE, THE JUDGES OF SAID COURT:
And-any P. Krzyda , counsel for the plaintiff/4@dbW4MM in
the above action (or actions), respectfully represents that:
1. The above-captioned action (or actions) is (are) at issue•
2. The claim of the plaintiff in the action is $ 3077.68
The counterclaim of the defendant in the action is 0.00
The following attorneys are interested in the case(s) as counsel or are other-
wise disqualified to sit as arbitrators:
Pty P. Krzyaidci
WHEREFORE, your petitioner prays your Honorable Court to appoint three (3)
arbitrators to whom the case shall be submitted.
Respectfully submitted,
ORDER OF COURT
AND NOW
19 , in consideration of the
foregoing petition, Esq.,
Esq., and ,Esq., are appointed arbitrators in the
above-captioned action (or actions) as prayed for.
By the Court,
P. J.
b
p,? . J Ci
PPL Electric Utilities Qtrp,
VS.
Bret r4wir Fitzpatrick
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-1867 CIVIL 19
RULE 1312-1. The Petition for Appointment of arbitrators shall be substantially
in the following form:
PETITION FOR APPOINTMENT OF ARBITRATORS
TO THE HONORABLE, THE JUDGES OF SAID COURT:
Fnthay P. Plmy idki , counsel for the plaintif4/49ittodM in
the above action (or actions), respectfully represents chat:
1. The above-captioned action (or actions) is (are) at issue.
2. The claim of the plaintiff in the action is $ 3077.68
The counterclaim of the defendant in the action is 0.00
The following attorneys are interested in the case(s) as counsel or are other-
wise disqualified to sit as arbitrators:
Path P. PTW icci
WHEREFORE, your petitioner prays your Honorable Court to appoint three (3)
arbitrators to whom the case shall be submitted.
Respectfully submitted,
ORDER OF COURT
AND NOW, kg aS; in corsideratti?oGn of the
'?- )
foregoing petition, Esq.
Esq., and sq., are appointed arbitrators in the
above-captioned action (or actions) as prayed for.
By the C ,
P. J.
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w.?
tt,?j `lam , Ell. 9-
PPL Electric Utilities Gtrp•.
vs:
Bret Michel Fitzpatrick
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-1867 CIVIL 19
RULE 1312-1. The Petition for Appointment of arbitrators shall be substancialiy
in the following form:
PETITION FOR APPOINTMENT OF ARBITRATORS
TO THE HONORABLE, THE JUDGES OF SAID COURT:
PndxxY P. Krzyacki
counsel for the plaintiff/49,tW&W in
the above action (or actions), respectfully represents that:
1. The above-captioned action (or actions) is (are) at issue.
2. The claim of the plaintiff in the action is $ 3077.68
The counterclaim of the defendant in the action is 0.00
The following attorneys are interested in the case(s) as counsel or are other-
wise disqualified to sit as arbitrators:
Antlrc, P. Krzyvadd
WHEREFORE, your petitioner prays your Honorable Court to appoint three (3)
arbitrators to whom the case shall be submitted.
Respectfully submitted,
L ORDER OF COURT
AND NOW, ??} did ?p? J Q P. aS, in consideration of the
foregoing petition, ! 44J Esq., 'k6e
Esq., and sq., are appointed arbitrators in the
above-captioned action (or actions) as prayed for.
By the C ,
P. J.
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nE S,
Plaintif
Mrz6?1rxel f117 (1-14 fi-
t)(uZLIry',Sacr41i IP5 h(
Defendant
Law Firm
Oath
We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United
States and the Constitution of this Commonwealth and that we will discharge the duties of our office
ywi,thfli lity.
Signature Signature
Cl.?'C.. ? Vl, ?YA?? v ?,?CL.-v?1 S J?,n(?:? C
Name (Chairman) Name Name
Law Firm
35 I,N(G- 5T14,z0?
Address
3 'ji r? I YICr7 S t
Address
In The Court of Common Pleas of Cumberland
County, Pennsylvania No. d yi? b 1
Civil Action - Law.
(,c.fe,, eu550
Law Firm
33o-' Mtyh ,t?,. ail
Address
C7( 11,--, 0,??f Q 11Q)3I NleCiI?cst L /?%I) / 7Cs5 cemP
City, Zip city, Lin City, Zip
?/ /,ate 5a Award
We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the
following award: (Note: If damages for delay are awarded, they shall be separately stated.)
17E k -l b\0 it 4Gc1)Z)k d-1- .V{,emsrv.L + T 04V"t C CjLtt?17 r ris -tyPlYi-YY I
5
Date of Hearing: / 71 1 5
Date of Award: 12 d?
2 d"" ) 2 /1 C/DC/ ?
. Arb'tr iss nts. (Insert name if applicable
?7
(Cha rnan)
Notice of Entry of Award
Now, the , a 1" day of 20 -1??, at o i , .M., the above award was
entered upon the docket and notice thereof given by mail to the parties or their attorneys.
Arbitrators' compensation to be paid upon appeal: $ `?- '6
By:
44; Prothonotary
Deputy
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
----_?__ __._.____-________7{
PPL ELECTRIC UTILITIES CORP.,
Plaintiff,
Vs.
BRET MICHAEL FITZPATRICK and
HORIZON SATELLITES, INC.,
Defendants.
----------------------------------------------------X
Date: 08/26!1006
Civil Action - In Law
No. OS-1867
ARBITRATION
PRAECIPE FOR JUDGMENT ON AWARD VS.
DEFENDANT BRET MICHAEL FITZPATRICK
To the Prothonotary:
COUNTI
PPL ELECTRIC UTILITIES CORP. VS.
BRET MICHAEL FITZPATRICK
Kindly enter Judgment on Award in favor of Plaintiff, PPL ELECTRIC
UTILITIES CORP. and against Defendant BRET MICHAEL FITZPATRICK pursuant to
Arbitration Award Number 05-1867 dated December 8, 2005, as follows:
Amount Past Due: $2,172.18
TOTAL: $2,172.18
together with costs and interest from December 10, 2004.
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
CORP. is Two North Ninth Street, Allentown, Pennsylvania, 18101.
2. The true and correct address of the Defendant BRET MICHAEL
FITZPATRICK is 343 Walton Street, Lemoyne, Pennsylvania, 17043.
KRZYWICKI
Dated: August 26, 2006 By:
?tQr?gan Road L
O. 505
N ope, PA. 18938
(215) 862-4390
Attorney I.D. No. 23754
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Defendant
in The Court of Common Pleas of Cumberland
County, Pennsylvania No. 4 5 g-7-
Civil Action - Law.
Oath
We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United
States and the Constitution of this Commonwealth and that we will discharge the duties of our office
y'th lity.
Signature signature
Name Name
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Law Firm
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we, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the
following award: (Note: If damages for delay are awarded, they shall be separately stated.)
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name
Date of Hearing:
Date of Award: ) Z b
Notice of Entry of Award
Now, the _La day of r , 20a:?_, at 10 1 , -?-).M., the above award was
entered upon the docket and notice thereof given by mail to the parties or their attorneys.
Arbitrators' compensation to be paid upon appeal: $1- 90. r,
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OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013-3387
Curtis R Long, P'oltaalary
TO: BRET MICHAEL FITZPATRICK
343 Walton Street
Lemoyne, Pennsylvania 17043
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
__---°---------__---------- X
PPL ELECTRIC UTILITIES CORP.,
Plaintiff,
VS.
BRET MICHAEL FITZPATRICK and
HORIZON SATELLITES, INC.,
Defendants.
Date: 08/2612006
Civil Action - In Law
No. 05-1867
ARBITRATION
You are hereby notified in accordance with Pennsylvania Supreme Court Rule
236 and that judgment has been entered on a:
Final Order *
( ) Degree Nisi *
( ) Verdict *
( ) Viewers Report
( ) Default
( ) Assessment of Damages
(?IX) Arbitration Award
( ) Money Judgment
and entered to No. J.D.
against BRET MICHAEL FITZPATRICK, Defendant, concerning Civil Suit No. 05-
L[s o (o in the sum of $2,172.18, together with costs and
1867 ona/jQla
interest from December 10, 2004.
CURTIS R. LONG
By:
rothono
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE
CALL ATTORNEY FOR THE FILING PARTY:
Anthony P. Krzywicki, Esq.
KRZYWICKI & ASSOCIATES
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 CORP.,
Plaintiff, Civil Action-In Law
VS. NO.: 05-1867
BRET MICHAEL FITZPATRICK and
HORIZON SATELLITIES, INC.,
Defendants.
AFFIDAVIT OF JUDGMENT
STATE OF PENNSYLVANIA
SS.
44 4@_ _ V_'_ &_??
COUNTY OF
I, Anthony P. Krzywicki, being duly sworn according to law, deposes and state that I am a
representative of PPL Electric Utilities Corp., Two North Ninth, Allentown, PA 18101, Plaintiff,
herein, and as such state the following:
1. The Judgment against Defendant, Bret Michael Fitzpatrick arose out of a
vehicular collision in which he was the driver..
Esq.
P. O. Beh?505
New Hope, PA 1893
PA ID# 23754
215-862-4390
SWORN TO AND
Y,
Public
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IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORP.,
Plaintiff,
Civil Action - In Law
VS. No.: 05-1867 Civil Term
BRET MICHAEL FITZPATRICK and
HORIZON SATELLITES, INC.,
Defendants.
aTf)06
PRAECIPE TO uArV JUDGMENT ANZ? CASE
TO THE PROTHONOTARY:
Kindly mark the Judgment entered on against the defendants, satisfied and from the record upon
payment of your costs only.
KRZYWICKI & ASSOCIATES
DATED: March 24, 2008
BY:
Anthony P. Krz cki
Attorney for P n
P.O. Box 50
New Hope, PA 18938
(215)862-4390
Attorney I.D. 23754
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