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Home My WebLink About05-2219 In the Court of Common pleas of Cumberland County, pennsylva la PPL Electric Utilities Corp. plaintiff vs. Civil Action - In Law No. 0')" - ;)..;219 c,~,' Carolyn A. Reim aka Carolyn Ryan 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 enter~ng 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 '05- ~~/Cf Carolyn !\. Reim aka Carolyn Ryan Defendant ARBITRATION COMPLAINT 1. This is an action by Plaintiff, PPL Electric Utilities Corp. to recover damage from Defendant arising out of a vehicular collision which caused damage to property owne by Plaintiff. 2. PPL Electric Utilities Corp. is a Pennsylvania corporation duly organized an existing and licensed to do business as a public utility under the laws of the Commonwealt of Pennsylvania with a principal place of business at Two North Ninth Street, Allentown, PA 18101. 3. Defendant Carolyn A. Reim aka Carolyn Ryan. is an adult individual residi gat 225 Springfield Road, Shippensburg, p/\ 17257. 4. At all times relevant hereto, Plaintiff was engaged in the business of produc ng, furnishing, supplying and distributing utility service to persons and businesses who reques ed utility service in accordance with the Rate Schedules and General Rules and Regulations 0 Plaintiffs Tariff presently on file with the Public Utility Commission. COUNT I PPL Electric Utilities Corp. vs. CarolYl.2!\.j~cirn aka Carolvn RY_(~!l 5. Defendant, Carolyn i\. Reim aka Carolyn Ryan while operating a vehicle and collided with and damaged property owned by Plaintiff. 6. Defendant negligently operated his vehicle in he/she: 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 pos tion of the plaintiff; i) operated the vehicle in a manner violating the statutes of the Commonwealth of Pennsylvania governing the operation of vehicle on public streets, highways and roadways; j) being negligent at the law; k) such other acts or omissions constituting carelessness, negligence a d recklessness may be ascertained during discovery or developed at t of trial. 7. Defendant struck and damaged a utility pole owned and operated by PPL Elec ric Utilities Corp., at the vicinity of 3512 Ritner llighway, W. Pcnnsboro T\vp., P A on or about Fcbruary 2004. 8. Dcfendant's actions or inaction as set forth above are the proximate cause oft e damages as set for above and herein. 9. Plaintiff made demand on Defendant to repay the sums then due and owing t 10. Plaintiff has been damaged in the amount of $7155.34 plus costs and attorney Plaintiff, but Defendant has refused to pay Plaintiff. fees. WHEREFORE, Plaintiff PPL Electric Utilities Corp. demands judgment against the Defendant in an amount of $7155.34 together with costs, prejudgment and post judgment interest, attorney's fees, punitive damages and delay damages as the law may allow. Respectfully submitted, Krzywicki a sociates By: DATED: April 20, 2005 VERIFICATION Pursuant to Rule 1024 (c), I, Anthony P. Krzywicki, Esquire, verify that I am the att for Plaintiff, in the within case; that thc 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 s ch facts are true and correct to the best of my knowledge, information and belicf, based upon t company's business records and matters of public record. I understand that the statements h rein are made subject to the penalties of 18 Pa. Consol. Stat. Ann. S 4904 relating to unsworn falsification to authorities. Dated: April 20, 2005 SHERIFF'S RETURN - REGULAR CASE NO: 2005-02219 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PPL ELECTRIC UTILITIES CORP VS REIM CAROLYN A AKA CAROLYN RYA RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon REIM CAROLYN A AKA CAROLYN RYAN the DEFENDANT , at 2003:00 HOURS, on the 4th day of May at 225 SPRINGFIELD ROAD 2005 SHIPPENSBURG, PA 17257 by handing to ILENE REIM, MOTHER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 11.10 .00 10.00 .00 39.10 /"~ .;/ . R. Thomas Kline 05/05/2005 KRZYWICKI & Deputy Sheriff Sworn and Subscribed to before By: me this " ,.c: ,- day of 1M... t. ';HC5 A.D. . () )' } ~-hp;oth~n~~' ~ . 2143PD OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse * Carlisle, FA 17013 Curtis R. Long Prothonotary TO: Carolyn Reim aka Carolyn Ryan 225 Springfield Road Shippensburg, PA 17257 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania PPL Electrlc Utillties Corp. Plaintiff Civil Action - In Law vs No. 05-2219-CIVIL Carolyn Reim aka Carolyn Ryan Defendant ARBITRATION NOTICE PUlsuant to Rule 236 at the Supreme Court of Pennsylvan1a, you are hereby notlf:ed t)rjt a Judgment has been entered agalnst you In the above proceedl~d~l~~ Curtis R. Long~ prothonotarY:; (XX) ( ) ( ) ( ) ( ) ( ) ( ) Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings ~ lIs-lor 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 2143rn In the Court of Common Pleas of CUMBERLAND County, Pennsylvania PPL Electrlc Utllltles Corp. Plaintiff civil Action - In Law vs No. 05-2219-CIVIL Carolyn Reim aka Carolyn Ryan Defendant ARBITRATION PRAECIPE FOR JUDGMENT AGAINST DEFENDANT FOR FAILURE TO PLEAD To the Prothonotary: COUNT 1 PPL Electric Utllltles Corp. vs. Carolyn Reim aka Carolyn Ryan Kindly enter default judgment in favor of Plaintiff, PPL Electric Utilities Corp. and against Defendant, Carolyn Reim aka Carolyn Ryan for failure to plead to Plaintiff's Complaint as follows: Amount Past Due: TOTAL $ 7155.34 $ 7155.34 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. 2143rn 2. The true and correct address of the Defendant, Carolyn Reim aka Carolyn Ryan, is 225 Springfield Road, Shippensburg, Cumberland County, PA 17257. DATED: June 29, 2005 18938 Krzywicki SHERIFF'S RETURN - REGULAR 2J1-j::.-PD CASE NO: 2005-02219 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PPL ELECTRIC UTILITIES CORP VS REIM CAROLYN A AKA CAROLYN RYA RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon REIM CAROLYN A AKA CAROLYN RYAN the DEFENDANT , at 2003:00 HOURS, on the 4th day of May , 2005 at 225 SPRINGFIELD ROAD SHIPPENSBURG, PA 17257 by handing to ILENE REIM, MOTHER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 11.10 .00 10.00 ..00 39.10 So Answers: -""..l-"""C;:::-~.,,,,. f~ .( ,:Y'~ F ... ';;;,"'..........._-", R. Thomas Kline 05/05/2005 KRZYWICKI & S Sworn and Subscribed to before By: me this day of Deputy Sheriff A.D. Prothonotary r 2143PD In the Court of Common Pleas of CUMBERLAND County, Pennsylvania PPL Electrlc Utllltles Corp. Plaintiff Civil Action - In Law vs No. 05-2219-CIVIL Carolyn Reim aka Carolyn Ryan Defendant ARBITRATION NOTICE TO: Carolyn Reim aka Carolyn Ryan 225 Springfield Road Shippensburg, PA 17257 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: ~J Anthony P. Krzywlckl 49 North Sugan Road P.O. Box 505 New Hope, PA 18938 215-862-4390 Attorney for Plaintiff Attorney I.D. 23754 2143PD In the Court of Common Pleas of CUMBERLAND County, Pennsylvania PPL Electrlc Utlllties Corp. Plaintiff Civil Action - In Law vs No. 05-2219-CIVIL Carolyn Reim aka Carolyn Ryan Defendant(s) AFFIDAVIT OF SERVICE STATE OF NEW JERSEY SS. COUNTY OF HUNTERDON 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 firs a s mail on 06/03/2005. 18938 SWORN TO AND SUBSCRIBED BEFORE ME THIS 2 f DAY OF ~ ,2"", \~ '~~ /~J- Notary Pu lC ~ :l::~H(-=u.E PYATT -- AP.\" PUc-'UC OF NEW JERSEY ", C..JMMISSION EXPIRES JULY 9, 2JJ01 2143PD In the Court of Common Pleas of CUMBERLAND County, Pennsylvania PPL Electric Utllities Corp. Plaintiff Civil Action - In Law vs No. 05-2219-CIVIL Carolyn Reim aka Carolyn Ryan Defendant ARBITRATION The undersigned hereby certifies that written notice of intention to file a praecipe for entry of judgment by default against the defendant, Carolyn Reim aka Carolyn Ryan, 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. DATED: June 29, 2005 Krzywicki 2143PD In the Court of Common Pleas of CUMBERLAND County, Pennsylvania PPL Electrlc Utlllties Corp. Plaintiff Civil Action - In Law vs No. 05-2219-CIVIL Carolyn Reim aka Carolyn Ryan Defendant 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, Carolyn Reim aka Carolyn Ryan, 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, Carolyn Reim aka Carolyn Ryan, is more than 18 years of age and currently resides at 225 Springfield Road, Shippensburg, PA 17257. Sworn to me this before 3. I have ascertained the above investigation and make this affidavit N r;',~:C\~i~. ..;~: PYA !.IOTARY PU3UC OF NEW JERSEY :J MY COMMISS'ON EXPIRES JULY 9. 200f t p -'9. 7J :-G .-.> ~ \. ,,~:;'.> C~,:.) \l:- e> oJ' <?t- '-- ::;1.-,. ~ C'- r--:' ~,;~S~; f ( - ""- " (j1 ()(1.) ~ ~ r -;-,; -)--)>, r ,j;Q ?i - ",.J \..-) ~ >-: i"n ,.~ " r:? 'jl ..t) -C E ,\ Q.S Vf" -") CD -~-Z ~ - -<.. ~ r -...r... - ,----- KRZYWICKI & ASSOCIATES Anthony P. Krzywicki, Esquire P.G. Box 505 New Hope, P A. 18938 (215)862-4390 Attorney for Plaintiff Attorney I.D. 23754/26852 COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA ------------------------------------------------------------------------)( PPL ELECTRIC UTILITIES CORP. Plaintiff Civil Action No. 05-2219-CIVIL VS. CAROLYN A. REIM AKA CAROLYN RYAN Defendant ------------------------------------------------------------------------)( PRAECIPE TO SETTLE, DISCONTINUE, AND END TO THE PROTHONOTARY: Kindly mark this matter Settled, Discontinue, and End against the defendant, Carolyn A. Reim aka Carolyn Ryan without prejudice, upon payment of your cost only. BY: KRZYWICKI & DATED: October 24, 2006 ~ = C-" c""\. o "') o ., :;:l ---n rnp .....c' \11 TIC ;,--'::, l ,~~ ....-'1 ~~~ -< C-,) .t'~' ~ \,z':) o U1