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HomeMy WebLinkAbout14-5453 Supreme Cop nnsylvania Cou Col<nnao leas For Prothonotary Use Only: A, Cil S� Docket No: C rl d rl 0,11y,tTem County 14- S4573 t The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of eadings or other papers as required by law or rules of court. Commencement of Action: S 2 Complaint El Writ of Summons 0 Petition F1 Transfer from Another Jurisdiction F1 Declaration of Taking E c Lead Plaintiffs Name: Lead Defendant's Name: UGI Utilities Inc. W. G. Tomko, Incorporated T Dollar Amount Requested: 2within arbitration limits I Are money damages requested? 2 Yes 0 No (check one) Doutside arbitration limits 0 N Is this a Class Action Suit? El Yes 2 No Is this an MDJAppeal? n Yes R1 No A Name of Plaintiff/Appellant's Attorney: Anthony P. Krzywicki, Esquire ❑ Check here if you have no attorney(are a Self-Represented [Pro 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 you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS D Intentional El Buyer Plaintiff Administrative Agencies ❑Malicious Prosecution ❑Debt Collection:Credit Card F1 Board of Assessment Motor Vehicle ❑Debt Collection: Other ❑ Board of Elections Nuisance Dept. of Transportation S Premises Liability HStatutory Appeal:Other Product Liability(does not include El Employment Dispute: E mass fort) ❑ Discrimination Slander/Libel/Defamation C H V Other: ❑Employment Dispute:Other rl Zoning Board T Underground utility damage E3Other: I F1 Other: o MASS TORT ❑ Asbestos N Tobacco Toxic Tort-DES Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑Ejectment n Common Law/Statutory Arbitration B ❑ Other: Eminent Domain/Condemnation F1 Declaratory Judgment 8 Ground Rent H Mandamus El Landlord/Tenant Dispute Non-Domestic Relations Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY H Mortgage Foreclosure:Commercial ❑Quo Warranto D Dental E]Partition El Replevin Legal n Quiet Title ❑Other: ❑ Medical E]Other: ❑ Other Professional: Updated 11112011 y IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY,PENNSYLVANIA UGI UTILITIES INC., Civil Action- In Law Plaintiff, No. I+- Sg53 ►V<<T� vs. ARBITRATION C= W. G. TOMKO, INCORPORATED and w STAN PAYJACK, :' � -ur", c!,r~ — ::;:)C,-1 Defendants. -t -: `-n CD c.+ CD SCD 1'"> 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 S NT7-q 0*311100 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA UGI UTILITIES INC., Civil Action- In Law Plaintiff, No. VS. ARBITRATION W. G. TOMKO, INCORPORATED and STAN PAYJACK, Defendants. COMPLAINT 1. This is an action by Plaintiff,UGI UTILITIES INC. to recover damages from Defendant arising out of a debt the Defendants owes to plaintiff by virtue of a utility service. 2. UGI UTILITIES INC. 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 P.O. Box 12677, Reading, Pennsylvania, 19612-2677. 3. Defendant, W. G. TOMKO, INCORPORATED, is a Pennsylvania corporation with a principle place of business located at 2559 State Route 88, Finleyville, Pennsylvania, 15332. 4. Defendant, STAN PAYJACK, is an adult individual whose current whereabouts is unknown but is employed by Defendant, W. G. TOMKO, INCORPORATED. 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. COUNT UGI UTILITIES INC. VS. STAN PAYJACK NEGLIGENCE PER SE 6. The allegations contained in Paragraphs 1 through 5 above are incorporated by referenced as if fully set forth. 7. Defendant, STAN PAYJACK, violated the Underground Utility Line Protection Law, Act 187 of 1996 in that he: a) did not employ prudent excavation techniques to ascertain the precise position of underground utilities; b) did not exercise due care and take all reasonable steps necessary to avoid damage to Plaintiff's underground utility lines; C) determined that markings identifying the location of the utility line were not clear but continued to dig with equipment in the area eventually severing an active gas line risking a catastrophe; d) did not hand dig to locate the utility line when Defendant, STAN PAYJACK, determined that the markings were not clear; and e) did not hand dig a test hole to identify location of the gas line. 8. Defendant, STAN PAYJACK, on or about March 18, 2013, while operating a trackhoe struck and damaged an underground active gas utility line owned and operated by UGI UTILITIES INC. at the vicinity of 323 W. North Street, Carlisle, Cumberland County, Pennsylvania. 9. Defendant's actions or inaction as set forth above are the proximate cause of the damages as set for above and herein. 10. Plaintiff has been damaged in the amount of$5,563.18, including costs and attorneys fees. WHEREFORE, Plaintiff, UGI UTILITIES INC., demands judgment against the Defendants, in an amount in excess of$5,563.18, together with costs,prejudgment and post judgment interest and delay damages as the law may allow. COUNT II UGI UTILITIES INC. VS. STAN PAYJACK COMMON LAW TORT 11. The allegations contained in Paragraphs 1 through 10 above are incorporated by reference as if fully set forth. 12. Plaintiff used standard industry markings to identify the location of its active- underground gas utility line prior to April 10, 2014. 13. Defendant, STAN PAYJACK, did not exercise due care and did not take all reasonable steps to avoid damage to the active gas utility line owned by UGI UTILITIES INC., in that he/she; a) did not employ prudent excavation techniques to ascertain the precise position of underground utilities; b) did not exercise due care and take all reasonable steps necessary to avoid damage to Plaintiff's underground utility lines; C) determined that markings identifying the location of the utility line were not clear but continued to dig with equipment in the area eventually severing an active gas line risking a catastrophe; d) did not hand dig to locate the utility line when Defendant, STAN PAYJACK, determined that the markings were not clear; and e) did not hand dig a test hole to identify location of the gas line. WHEREFORE, Plaintiff, UGI UTILITIES INC., demands judgment against the Defendants, in an amount in excess of$5,563.18, together with costs, prejudgment and post judgment interest and delay damages as the law may allow. COUNT III UGI UTILITIES INC. VS. W. G. TOMKO, INCORPORATED VICARIOUS LIABILITY FOR ACTION OF EMPLOYEE 14. Paragraphs 1 through 13 are incorporated by reference as if fully set forth herein. 15. Defendant, W. G. TOMKO, INCORPORATED, was the owner of the trackhoe that struck and damaged an underground active gas utility line. 16. Defendant, W. G. TOMKO, INCORPORATED,permitted and encouraged the actions of its agents and employees by not implementing a training program which addressed circumstances such as those which occurred on the date of the accident. 17. Defendant, W. G. TOMKO, INCORPORATED, is vicariously responsible for the actions of its agents and employees. 18. Defendant's actions or inaction as set forth above are the proximate cause of the damages as set forth above and herein. 19. The aforementioned damages were the direct and proximate result of the negligence of Defendant, W. G. TOMKO, INCORPORATED, including negligent acts and/or omissions of defendant as performed individually and/or by and through others permitted to use a trackhoe more specifically described as follows: a) negligently and carelessly failing to properly and adequately supervise and/or train Defendant's employee, in the operation of his/her trackhoe; b) negligently and carelessly failing to properly supervise the operation and control of said trackhoe; and C) otherwise failing to exercise reasonable care under the circumstances. 20. Plaintiff has been damaged in the amount of$5,563.18, including costs and attorneys fees. WHEREFORE, Plaintiff, UGI UTILITIES INC., demands judgment against the Defendant, in an amount in excess of$5,563.18, together with costs,prejudgment and post judgment interest and delay damages as the law may allow. Respectfully submitted, KRZYWICKI & ASSOCIATES, P.C. DATED: September 10, 2014 B . Anthony P wic ire P.O. 5 N H e 189 15-8 - 390 Attorney for aintiff Attorney 1. . 237 1 • 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. Dated: September 10, 2014 THONY Y C , ESQUIRE IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA UGI UTILITIES INC., Civil Action - In Law Plaintiff, No. 14-5453 Civil Term vs. W. G. TOMKO, INCORPORATED and . STAN PAYJACK, Defendants. ARBITRATION CD PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint against the Defendants, in the above -captioned Civil Action for an additional thirty (30) days. DATED: October 15, 2014 BY: ey P.O. Box 505 New Hope, PA 1 (215)862-4390 Attorney I.D. 23754 (.16:7.0) IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA UGI UTILITIES INC., Civil Action - In Law Plaintiff, No. 14-5453 Civil Term vs. W. G. TOMKO, INCORPORATED and : STAN PAYJACK, Defendants. ARBITRATION PRAECIPE TO SETTLE, DISCONTINUE, AND END TO THE PROTHONOTARY: Kindly mark this matter Settle, Discontinue, and End against the Defendants, without prejudice upon payment of your costs only. DATED: October 27, 2014 BY: KRZYWICKI : • CIATES, P.C. A hony P. orne P.O. Box 505 New Hope, PA 18938 (215) 862-4390 Attorney I.D. 23754 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S����8����������� OFFICE o~°~~ OF CUMBERLAND COUNTY " OF`FICZ OF Tr .sHERIFF F//ED-OFF/0E: T!{EPR0T1-1[NOTAi-Y 2614 NOV17 �� �� O� '-' '.. , "` CUMBERLAND COUNTY PENNSYLVANIA UGI Utilities Inc. W.G. Tomko, Incorporated (et al.) Case Number 2014-5453 SHERIFF'S RETURN OF SERVICE 09/16/ 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: W.G. Tomko, Incorporated, but was unable to locate the Defendant in the Sheriffs baiUwick. The Sheriff therefore deputizes the Sheriff of AlIegheny, Pennsylvania to serve the within Complaint & Notice according to law. 09/16/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Stan Payjack, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Allegheny, PennsyJvania to serve the within Complaint & Notice according to Iaw. 10/15/2014 The requested Complaint & Notice returned by the Sheriff of Allegheny County, the within named Defendant Stan Payjack, not found. VVilliam Mullen, Sheriff, Return of Service attached to and made part of the within record. The address 5 in Washington County. 10/15/2014 The requested Complaint & Notice returned by the Sheriff of Allegheny County, the within named Defendant WG. Tomko, Incorporated, not found. William W1u||on, Sheriff, Return of Service attached to and made part of the within record. The address is located in Washington County. 10/21/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: WG, Tomko, Incorporated, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Washington, Pennsylvania to serve the within Complaint & Notice according to law. 10/21/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Stan Payjack, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Washington, Pennsylvania to serve the within Complaint & Notice according to law. J10/28/2014 11:00 AM - The requested Complaint & Notice served by the Sheriff of Washington County upon Chad VWeoingar. VP of Risk N1anagement, who accepted forVV.G, Tomko, Incorporated, at 2559 State Route 88, Finleyville, PA 15332. Samuel F. Romano, Sheriff, Return of Service attached to and made part of the within record. /10/28/2014 11:10 AM - The requested Complaint & Notice served by the Sheriff of Washington County upon Chad Wissinger, VP of Risk Management, who accepted for Stan Payjack, at 2559 State Route 88, Fin|eyviUo, PA 15332. Samuel F. Romano, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $82.00 SO ANSWERS, November 07, 2014 RONNY R ANDERSON, SHERIFF EXP: 10/15/2014 csi eel ul 0 nrlc y'R Anderson Sheriff Jody S Smith Chief Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY ot Combete 11. °mos or THE SHERIFF p Richard W Stewart Solicitor UGI Utilities Inc. vs. W.G. Tomko, Incorporated (et al.) Case Number (2014-5453? SERVICE COVER SHEET Service Details: Category: Manner: Notes: Civil Action - Complaint & Notice Deputize Expires:( 0/15/2014 - Zone: Warrant: Serve To: Name: ( IStan Payjack j [Final Service: nmary 2559 State Route 88 ddress:' Finleyville, PA 15332 2559 STATE ROUTE 88, F 4' 1— co >- 4 a_ • P ne: Alternate Address: Phone: DOB: Served: Personally • Adult In Charge • Posted • Other Adult In Charge: Relation: . Date: Deputy. Time: Mileage: Attorney Originator: Name: Krzywicki & Associates, PC Phone: 215-862-4390 [Service Attempts: Date: Time: Mileage: Deputy: 4 6 Notes I Specialnstructions: Now, September 16, 2014 I, Sheriff of to execute service of the documents Return To: Cumberland County Sheriffs Office One Courthouse Square Carlisle, PA 17013 u c\f\ /' a • ( • CO1/4.3,, COMMONWEALTH OF PENNSYLV PN Notarial Seal Eda lean Woodward, Notary Public Oty of Pitsburgh, Allegheny County My Commission Expires May 28, 2016 SYLVANIA ASSOCIATION OF NOTARIES k\CSA,tv-r.._5 "S 110-All/iL C'110- tLa eat/Lk ER, P , ennsy v nia .0 e e.y •eputize the Sheriff of Allegheny County 0 ake return thereof according to law. 0 n (c) CorintyStrte Sheriff. Tefoosort. Ronny R Anderson, Sheriff 'et nny R Anderson lV Sheriff — EXP: 10/16/2014 v.) a. w LT. co w 0 LLJ1— at) ce) .zr u? 0 0 0 0 t -- Jody S Smith Chief Deputy EYP SHERIFF'S OFFICE OF CUMBERLAND COUNTY UGI Utilities Inc. vs. W.G. Tomko, Incorporated vos of Clunben, ‘°\ ,-- OF FiCE OF THE SREPIFF Richard W Stewart Solicitor Case Number ( 2014-5453- / SERVICE COVER SHEET Service Details: Category: Manner: Notes: ur rServe To: me: W.G. Tomko, Incorporated aryl i559 State Route 88 dress': Finleyville, PA 15332 Civil Action - Complaint & Notice Deputize Zone: Expires: ; 1.0/15/2014 Warrant: Ph Alternate Address: Phone: DOB: [Attorney / Originator: Name: [P lila/ Service: Served: Adult In Charge: Relation: Date: Personally Adult In Charge • Posted • Other Deputy: Time: Mileage: \arx? 4. Krzywicki & Associates, PC Phone: 215-862-4390 [Service Attempts: Date: Time: Mileage: Deputy: [Notes / Special Instructions: Now, A4\r-e,s vipt ber 16, 2014 I, Sheriff of to execute ervice of the documents he Return To: Cumberland County Sheriffs Office One Courthouse Square Carlisle, PA 17013 y, ake return thereof accordingto law. fc)CounlySuire Sheriff. Teleosoll. Inc. tiz COMMONYQ OF NNSYLVAN NotariaSeal Eda Jean Woodward, Notary Public aty of Plt.sburgh, Allegheny County the a. a l pt es May 28,2016 • J- • 4 OupftlARiEs pEritiV Ronny R Anderson, Sheriff WASHINGTON COUNTY, PENNSYLVANIA OFFICE OF THE SHERIFF SAMUEL F. ROMANO SHERIFF JAMES B. DALESSANDRO CHIEF DEPUTY Court Docket #: 2014-5453 County of Washington, Commonwealth of Pennsylvania UGI UTILITIES INC. vs. W.G.TOMKO INC., STAN PAYJACK COURTHOUSE SQUARE SUITE 303 100 WEST BEAU STREET WASHINGTON, PA 15301 724-228-6840 FAX 724-223-4719 Sheriff File Number — 14003203 Affidavit of Service COMPLAINT I hereby CERTIFY and RETURN that on 10/28/2014 at 11:10 AM at 2559 STATE ROUTE 88 FINLEYVILLE, PA 15332 the within COMPLAINT, was served on STAN PAYJACK, the defendant named therein, in the following manner: ALTERNATE PERSON By delivering to and leaving with CHAD WISSINGER the V P OF RISK MANAGEMENT to the defendant a true copy thereof, a person over the age of eighteen. Said address was the business of the defendant. SERVICE ATTEMPTS Date: 10/28/2014 @ 11:10 AM - 2559 STATE ROUTE 88 FINLEYVILLE, PA 15332 Attorney Name: KRZYWICKI & ASSOCIATES, P.C., P.O. BOX 505 NEW HOPE, PA 18938 Affirmed & Subscribed to before Me 10/29/2014 JASON LUCI, Deputy Sheriff Notary Public My commission expires: Sheriff ashington County NLL-Ub Notar,r ASHINGTON CITY, WeCitiIrtiCTCN COUNTY My Com ion Expi:es ugust 15, 2017 _ WASHINGTON COUNTY, PENNSYLVANIA OFFICE OF THE SHERIFF SAMUEL F. ROMANO SHERIFF JAMES B. DALESSANDRO CHIEF DEPUTY Court Docket #: 2014-5453 County of Washington, Commonwealth of Pennsylvania UGI UTILITIES INC. vs. W.G.TOMKO INC., STAN PAYJACK COURTHOUSE SQUARE SUITE 303 100 WEST BEAU STREET WASHINGTON, PA 15301 724-228-6840 FAX 724-223-4719 Sheriff File Number — 14003203 Affidavit of Service COMPLAINT I hereby CERTIFY and RETURN that on 10/28/2014 at 11:10 AM at 2559 STATE ROUTE 88 FINLEYVILLE, PA 15332 the within COMPLAINT, was served on STAN PAYJACK, the defendant named therein, in the following manner: ALTERNATE PERSON By delivering to and leaving with CHAD WISSINGER the V P OF RISK MANAGEMENT to the defendant a true copy thereof, a person over the age of eighteen. Said address was the business of the defendant. SERVICE ATTEMPTS Date: 10/28/2014 @ 11:10 AM - 2559 STATE ROUTE 88 FINLEYVILLE, PA 15332 Attorney Name: KRZYWICKI & ASSOCIATES, P.C., P.O. BOX 505 NEW HOPE, PA 18938 Affirmed & Subscribed to before Me 10/29/2014 JASON LUCI, Deputy Sheriff Notary Public My commission expires: Sheriff of Washington County ronrARIAf=SEAL DANIELLE (QUATTRO Notary F'u1' i. WASHINGTON CITY, WA:z°11NG T ON COUNTY My CnrnmissioII Expires:. iitaaurit 15, 2017 WASHINGTON COUNTY, PENNSYLVANIA OFFICE OF THE SHERIFF SAMUEL F. ROMANO SHERIFF JAMES B. DALESSANDRO CHIEF DEPUTY Court Docket #: 2014-5453 County of Washington, Commonwealth of Pennsylvania UGI UTILITIES INC. vs. W.G.TOMKO INC., STAN PAYJACK COURTHOUSE SQUARE SUITE 303 100 WEST BEAU STREET WASHINGTON, PA 15301 724-228-6840 FAX 724-223-4719 Sheriff File Number — 14003203 Affidavit of Service COMPLAINT I hereby CERTIFY and RETURN that on 10/28/2014 at 11:00 AM at 2559 ROUTE 88 HIGHWAY FINLEYVILLE, PA 15332 the within COMPLAINT, was served on W.G.TOMKO INC., the defendant named therein, in the following manner: ALTERNATE PERSON By delivering to and leaving with CHAD WISSINGER the V P OF RISK MANAGEMENT to the defendant a true copy thereof, a person over the age of eighteen. Said address was the business of the defendant. SERVICE ATTEMPTS Date: 10/28/2014 @ 11:00 AM - 2559 ROUTE 88 HIGHWAY FINLEYVILLE, PA •15332 Fees Received from Attorney: FIRST DEFENDANT BASE COST ($24.50) POSTAGE ($1.00) ADDITIONAL DEFENDANT(S) BASE COST ($11.00) MILEAGE ($20.16) Total: $56.66 Attorney Name: KRZYWICKI & ASSOCIATES, P.C., P.O. BOX 505 NEW HOPE, PA 18938 Affirmed & Subscribed to before Me 10/29/2014 Notary Public My commission expires: NOTARIAL SEAL N1EILLE QUATTRO Notary Put;Iic WASHINGTON CITY, WPSHNCTON COUNTY 'ti' My]Oar mission+ Expires August ' 5, 2017 §� AS1 i P( JASON LUCI, Deputy Sheriff Ctn. otivuthAn- miff of Washington County WASHINGTON COUNTY, PENNSYLVANIA OFFICE OF THE SHERIFF SAMUEL F. ROMANO SHERIFF JAMES B. DALESSANDRO CHIEF DEPUTY Court Docket #: 2014-5453 County of Washington, Commonwealth of Pennsylvania UGI UTILITIES INC. vs. W.G.TOMKO INC., STAN PAYJACK COURTHOUSE SQUARE SUITE 303 100 WEST BEAU STREET WASHINGTON, PA 15301 724-228-6840 FAX 724-223-4719 Sheriff File Number — 14003203 Affidavit of Service COMPLAINT I hereby CERTIFY and RETURN that on 10/28/2014 at 11:00 AM at 2559 ROUTE 88 HIGHWAY FINLEYVILLE, PA 15332 the within COMPLAINT, was served on W.G.TOMKO INC., the defendant named therein, in the following manner: ALTERNATE PERSON By delivering to and leaving with CHAD WISSINGER the V P OF RISK MANAGEMENT to the defendant a true copy thereof, a person over the age of eighteen. Said address was the business of the defendant. SERVICE ATTEMPTS Date: 10/28/2014 @ 11:00 AM - 2559 ROUTE 88 HIGFIWAY FINLEYVILLE, PA 15332 Fees Received from Attorney: FIRST DEFENDANT BASE COST ($24.50) POSTAGE ($1.00) ADDITIONAL DEFENDANT(S) BASE COST ($11.00) MILEAGE ($20.16) Total: $56.66 Attorney Name: KRZYWICKI & ASSOCIATES, P.C., P.O. BOX 505 NEW HOPE, PA 18938 Affirmed & Subscribed to before Me 10/29/2014 JASON LUCI, Deputy Sheriff Notary Public My commission expires: \1: 1 Sheriff of Washington County NOTARiAl_ SEAL DANIELli: MIATTRO Notary I'dohlic 11N9oN vypt.1,7-CITY, WAWHiNGTON COUNTY My Commission Expires August 15, 2017 ASIORIMISS.