HomeMy WebLinkAbout06-3209IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNT', PENNSYLVANIA
PPL ELECTRIC UTILITIES CORP.,
Vs.
Plaintiff,
Civil Acti n - In Law
No. 06 2„26 p l: c? ??. `?J2Yv?
DEREK E. EISENBERGER, a/k/a
ERIK E. EISENBERGER,
Defendant.
COMPLAINT
Noxlcs
You have been sued in court. If you wish to i
against the claims set forth in the following
you must take action within twenty (20) days
this complaint and notice are served, by enter
written appearance personally or by attorney
filing in writing with the court your defense:
objections to the claims set forth against yoi
are UWMM THAT IF YOU FAIL TO DO SO THE CASE
PROCEED WITHOUT you and a judgment may be enti
against you by the court without further notii
any money claimed in the complaint or for any
claim or relief requested by the plaintiff.
lose money or property or other rights importe
you.
fend
or
You
WAY
e for
other
ou may
nt to
YOU SHOULD TAKE THIS PAPER TO YOUR
ER
LOWY
AT ONCE. IF YOU DO NOT HAVE A LMMR
CANNOT AFFORD ONE, 00 TO OR TELEPHONE THE
OFFICE SET FORTH BELOK TO FIND OUT RE
YOU CAN GET LEGAL HELP.
CUNBERLAND COUNTY BAR ASSOCIA
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.
DEREK E. EISENBERGER, a/k/a
ERIK E. EISENBERGER,
Defendant.
COMPLAINT
Civil Acti n - In Law
No. o4 0.2 017
1. This is an action by Plaintiff, PPL ELECTRIC
damages from Defendant arising out of a vehicular collision which
owned by Plaintiff.
2. PPL ELECTRIC UTILITIES CORP. is a Pennsylvania
and existing and licensed to do business as a public utility under the
of Pennsylvania with a principal place of business at Two North Ninth
Pennsylvania, -18101.
3. Defendant, DEREK E. EISENBERGER, a/k/a ERIK E.
adult individual residing at 6 Circle Lane, Mechanicsburg,
4. At all times relevant hereto, Plaintiff was engaged in
furnishing, supplying and distributing utility service to persons and
utility service in accordance with the Rate Schedules and General
iS CORP. to recover
ed damage to property
orporation duly organized
vs of the Commonwealth
Street, Allentown,
ISENBERGER, is an
ti 17050-2312.
business of producing,
nesses who requested
and Regulations of
Plaintiffs Tariff presently on file with the Public Utility Commission.
h
COUNTI
PPL ELECTRIC UTILITIES CORP. VS.
5. Defendant, DEREK E. EISENBERGER, a/k/a ERIK E.
while operating a vehicle, damaged property owned by Plaintiff.
6. Defendant negligently operated the vehicle in that
a) operated said vehicle and/or equipment at an
the circumstances;
b) failed to have said vehicle and/or equipment
control;
c) failed to keep a proper lookout;
d) operated said vehicle and/or equipment in a red,
e) failed to keep vehicle and/or equipment in the p
f) failed to operate the vehicle and/or equipment
limit or failed to operate the vehicle and/or eq
speed under the circumstances;
g) failed to remain alert and attentive under the
h) operated the vehicle and/or equipment without
safety and position of the plaintiff;
i) operated the vehicle and/or equipment in a mar
the Commonwealth of Pennsylvania governing
rate of speed under
:r proper and adequate
and careless manner;
lane of travel;
the posted speed
at a reasonable
regard for the rights,
violating the statutes of
operation of vehicles
and/or equipment on public streets, highways ano roadways;
j) being negligent at the law;
k) such other acts or omissions constituting careles mess, negligence and
recklessness may be ascertained during discovery or developed at the time
of trial.
7. Defendant struck and damaged a utility pole and wires weed and operated by
PPL ELECTRIC UTILITIES CORP. at the vicinity of 710 West Main tweet, Mechanicsburg,
Cumberland County, PA., on or about June 15, 2004.
8. Defendant's actions or inaction as set forth above are th proximate cause of the
damages as set for above and herein.
9. Plaintiff made demand on Defendant to repay the sums on due and owing to
Plaintiff, but Defendant has refused to pay Plaintiff.
10. Plaintiff has been damaged in the amount of $9,704.45, . cluding costs and
attorneys' fees.
WHEREFORE, Plaintiff PPL ELECTRIC UTILITIES CORP. demands judgment against
the Defendant in an amount of $9,704.45, including costs, prejudgme t and post judgment
interest, attorneys' fees, punitive damages and delay damages as the la may allow.
Respectfully
DATED: May 25, 2006
TES
Esq.
VERIFICATION
Pursuant to Rule 1024 (c), I, ANTHONY P. ICRZYWICKI, g%, 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 t? take this verification;
and that such facts are true and correct to the best of my knowledge, in*ormation 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. S}at. Ann. § 4904 relating
to unworn falsification to authorities.
Dated: May 25, 2006
ESQ.
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IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORP.,
VS.
Plaintiff,
ERIK E. EISENBERGER,
Defendant.
Civil Action - Ian Law
No. 06-3209
AMENDED COMPLAINT
NOTICE
You have been sued in court. If you wish to deft
against the claims set forth in the following page
must take action within twenty (20) days after &
complaint and notice are served, by entering a W
appearance personally or by attorney and filing ii
with the court your defenses or objections to the
set forth against you. You are WARNED THA'
YOU FAIL TO DO SO THE CASE MAY PR
WITHOUT you and a judgment may be entered
you by the court without further notice for any m
claimed in the complaint or for any other claim c
requested by the plaintiff. You may lose money
property or other rights important to you.
you
IF
YOU SHOULD TAKE THIS PAPER TO YO PR
LAWYER AT ONCE, IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO O OR
TELEPHONE THE OFFICE SET FORTH BELOW
TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
CUMBERLAND COUNTY BAR ASSOCIA
2 LIBERTY AVENUE
CARLISLE, PA 17013-3387
(717) 249-3166
(800) 990-9108
i
IN THE COURT OF COMMON PLEAS, CUMBERLAND
PPL ELECTRIC UTaxnES CORP.,
Civil
Plaintiff, No.
VS.
ERIK E. EISENBERGER,
Defendant.
AMENDED COMPLAINT
1. This is an action by Plaintiff, PPL ELECTRIC
damages from Defendant arising out of a vehicular collision which
owned by Plaintiff.
2. PPL ELECTRIC UTILITIES CORP. is a
and existing and licensed to do business as a public utility under the
of Pennsylvania with a principal place of business at Two North
Pennsylvania, 18101.
3. Defendant, ERIK E. EISENBERGER, is an adult
2W Street, Dillsburg, York County, Pennsylvania, 17019.
4. At all times relevant hereto, Plaintiff was engaged in
famishing, supplying and distributing utility service to persons and
utility service in accordance with the Rate Schedules and General
,PENNSYLVANIA
- In Law
r-
CORP. to rli?&er
fl
damage to proper%
duly organized
of the Commonwealth
Street, Allentown,
residing at 2 South
business of producing,
who requested
and Regulations of
Plain ifPs Tariff presently on file with the Public UtiliCommission.
++eeen lf, ft
0
COUNTI
PPL ELECTRIC UTILITIES CORP.
ERIK E. EISENBERGER
5. Defendant, ERIK E. EISENBERGER, while
property owned by Plaintiff:
6. Defendant negligently operated the vehicle in that he
a) operated said vehicle and/or equipment at an
the circumstances;
b) failed to have said vehicle and/or equipment
control;
c) failed to keep a proper lookout;
d) operated said vehicle and/or equipment in a re
e) failed to keep vehicle and/or equipment in the
f) failed to operate the vehicle and/or equipment
limit or failed to operate the vehicle and/or eq
speed under the circumstances;
g) failed to remain alert and attentive under the
a vehicle, damaged
rate of speed under
proper and adequate
and careless manner;
lane of travel;
the posted speed
at a reasonable
h) operated the vehicle and/or equipment without cue regard for the rights,
safety and position of the plaintiff;
i) operated the vehicle and/or equipment in a
the Commonwealth of Pennsylvania governing
and/or equipment on public sh*WV s an
violating the statutes of
operation of vehicles
1 roadways;
j) being negligent at the law,
0
k) such other acts or omissions constituting carel ess, negligence and
recklessness may be ascertained during discov :ry or developed at the time
of trial.
7. Defendant struck and damaged a utility pole and owned and operated by
PPL ELECTRIC UTMITIES CORP. at the vicinity of 710 West M ' Street, Mechanicsburg,
Cumberland County, PA., on or about June 15, 2004.
8. Defendant's actions or inaction as set forth above are a proximate cause of the
damages as set for above and herein.
9. Plaintiff made demand on Defendant to repay the
Plaintiff, but Defendant has refused to pay Plaintiff.
10. Plaintiff has been damaged in the amount
attorneys' fees.
WHEREFORE, Plaintiff PPL ELECTRIC UT X11ES CORP
the Defendant in an amount of $9,704.45, including costs,
then due and owing to
including costs and
judgment against
and post judgment
interest, attorneys' fees, punitive damages and delay damages as the la'w may allow.
Respectfiilly
DATED: July 24, 2006
ASSOCIATES
By:,
i
VERIFICATION
Pursuant to Rule 1024 (c), I, ANTHONY P. KRZYWICKI,
attorney for Plaintiff in the within case; that the appropriate officers (
available within the time for serving the foregoing to provide their ve
sufficiently familiar with the facts set forth in the foregoing Pleading
and that such facts are true and correct to the best of my knowledge,
based upon the company's business records and matters of public reo
statements herein are made subject to the penalties of 19 Pa. Consol.
to unsworn falsification to authorities.
Dated: July 24, 2006
3Q., verify that I am the
he Plaintiff are not
ication; that I am
take this verification;
)rmation and belief,
. I understand that the
M Ann. § 4904 relating
0 LAW OFFICES 1
KRZYWICIQ & ASSOCIATES
P. O. BOX 505
NEW HOPE, PA 18938
(215) 862-4390
FAX: (215) 962,4393
July 19, 2006
Curds R. Long
Prothonotary
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA. 17013-3387
RE: PPL ELECTRIC UTILITIES CORP. VS.
DEREK E. ELSENBERGER, a/k/a
ERIK E. EISEN13ERGER
Civil Action number. 06-3209
Our Me number. 2255 PD
Dear Mr. Long:
Enclosed herewith please find an original Amended Complaint m the
the Court. Please return the time-stamped copy of the Amended Com
in the dosed, self-addressed, stamped envelope.
c
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Zy C -_
fj
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m
matter to be filed with
face sheet to our office
Also enclosed please find one (1) true copy of the Amended C laint to be served upon
Defendant ERIK E. EISENBERGER, via deputization by the Sheriff f Cumberland County to the
Sheriff of York County. Our check in the sum of $100.00, payable to the Sheriff of
Cumberland County, representing the fees for this deputization is encl sed.
Our check in the sum of $100.00, made payable to the Sheriff of Y?ork Coxmty, representing the
actual service of process fee is also enclosed. We have included the priate Return of Service
forms with a self-addressed, stamped envelope as well.
Thank you for your usual, kind attention.
Very truly yours,
5Calrine Ri
APK:car
Encl.
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CASE NO: 2006-03209 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PPL ELECTRIC UTILITIES CORP
VS
EISENBERGER DEREK E AKA ERIK E
GERALD WORTHINGTON , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
EISENBERGER DEREK E AKA ERIK E EISENBERGER the
DEFENDANT , at 2025:00 HOURS, on the 22nd day of June , 2006
at 6 CIRCLE LANE
MECHANICSBURG, PA 17050-2312
by handing to
TAYLOR EISENBERGER, WIFE
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 18.00
Service 8.80
Affidavit .00
So Answers:
Surcharge 10.00 R. Thomas Kline
.00
36.80/ 06/27/2006
`- KRZYWICKI & ASSOCIATES
Sworn and Subscibed to By:
before me this day Deputy S iff
of A.D.
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2006-03209 P
COMMONWEALTH O'ff' PENNSYLVANIA:
COUNTY OF CUMBERLAND
PPL ELECTRIC UTILITIES CORP
VS
EISENBERGER DEREK E AKA ERIK E
R. Thomas Kline
18.00
9.00
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT , to wit:
EISENBERGER DEREK E AKA ERIK E EISENBERGER
but was unable to locate Him
deputized the sheriff of YORK
serve the within COMPLAINT & NOTICE
County, Pennsylvania, to
On September 22nd , 2006 , this office was in receipt of t
attached return from YORK
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep York County
Postage
, Sheriff or Deputy Sheriff who being
in his bailiwick. He therefore
..-a -
So answers
10.00 R. Thomas Kline
84.41 Sheriff of Cumberland County
.87
122.28
09/22/2006
KRZYWICKI & ASSOCIATES
Sworn and subscribe to before me
this day of
A. D.
K
COUNTY OF YORK
OFFICE OF THE SHERIFF
28 EAST MARKET ST., YORK, PA 17401
009-1 `'_
SERVICE CALL
(717) 771-9601
SHERIFF SERVICE INSTRUCTIONS
PROCESS RECEIPT and AFFIDAVIT OF RETURN PLEASE TYPE ONLY LINE 1 THRU 12
DO N017 DETACH ANY COPIES
2. CC .-
-1 G-A
4. TV F WRIT ORCCOMPLAI T
3. DEF tM /
SERVE 5. AMEi INcf DU At_ PA Y, P O , ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD.
(vim, ?
6. DRE WWjft?tLQ- I P. AND ZI t r.
AT
7. INDICATE SERVICE: ERSONAL J PERSON IN CHARGE DEPUTIZE ? 1ST CLASS MAIL a POSTED _JOTHER
NOW ALclust 14 247_ 1, SHERIFF OF COUNTY, PA, do hereby deputize the sheriff of
York COUNTY to execute this Wr j rpa$ e return ther ording
Y
to law. This deputization being made at the request and risk of the plaintiff.
n i t n - n n t v n .. n.? n?LJOO?C¢ir1C (111nLN A
SP CIAL I ST TI N? QR 0 WI A TiIN/l E
G?^ ` `?Y?j? 0 "-?.
`J4j?( [ (J uwe-
ANC FE PAID BY ATTY.
Please mail e service to Cunberland County Sheri ;; ?.,
NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching an roperty under within writ may leave same
without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of suc•i deputy or the sheriff to any plaintiff
herein for any loss, destruction, or removal of any property before sheriffs sale thereof.
9. TYPE NAME and ADDRESS of ATTO GINAT? a IGN TU , E' . 1 T? _ NUMEJER 11. DAT FILE
1 ?/ . (7J
12. SEND NOTICE OF SERVICE COPY TO NAME AMEM SW: (This area must be com eted if otic is t e mailed). ( A/1 1/,200E
NEW HOPE, PA 18938 B E R L A N D CO. ?-I F F
SPACE BELOW FOR USE OF THE SHfiRI - DO NOT WRITE BELOW THIS LINE
11 1 acknowledge receipt of the writ 14. DATE RECEIVED 15. Expiration/Hearing Date
or complaint as indicated above. M J M C G I L L Y C S O 8/15/2006 19/10/2006
16. HOW SERVED: PERSONAL ( ) RESIDENCE POSTED( ) POE ( ) SHERIFF'S OFFICE ( ) OTHER ( SEE REMARKS BELOW
17. ? I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, etc. name above. (See remarks below.)
18. NAME A TITLE OF I IVIDUAL ER) WST ADDRESS H E 1F ABOVE ( elationship Defendant) Date of Service 20. Time of Service
23. Advance Costs 24 ervice Costs 25. N/F 26. Mileage
1 27. Postage 28. Sub Total 29. Pound 30. Notary 31. Surchg. 32. Tot. sts
'
?? 33. Costs Du
5 efund heck No.
""0
$100.00 tX? 4)
b/. r - 7
5. 7
i ja
34. Foreign County Costs 35. Advance Costs 36. Service Costs 37. Notary Cert. 38. Mileage/Posted/Not Found 39. Total Costs 40. Costs Due or Refund
O ANSWERS
41. AFFIRMED ? ed to before me this
V'E
LT
i nature of
45.
T
r- C>
day of
42 + ifF a
.
NOTAR1r1L SL RY 46. Signature of York 47, DATE
LfSA L. BOVdMf,,NJ NOTARY PUBLIC
ciTY
County Sheriff
??YORK ??
'RK COUN FOR WILLIAM M HOSE SHERIFF
9
/8/06
TY
MY COMMtSSf rY C
OPT
f F
i
t
48
Si 49 DATE
20Q9
F $ AUC, 12 gn
gna
ure o
ore
. .
,
Sheriff
County
50. (ACKNOWLE=DGE RECEIPT OF THE SHERIFF'S RET NATURE 51. DATE RECEIVED
OF AUTHORIZED ISSUING AUTHORITY AND TITLE
1. WHITE - Issuing Authority 2. PINK - Attorney 3. CANARY - Sheriffs Office 4. BLUE- Sheriffs Office
22. REMARKS:
A?ylo
KRZYWICKI & ASSOCIATES
Anthony P. Krzywicki, Esq.
P.O. Box 505
New Hope, PA 18938
(215) 862-4390
Attorney for Plaintiff
Attorney I.D. 23754
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORP.,
Civil Action In-Law
Plaintiff, No. 06-3209
vs.
ERIK E. EISENBERGER,
Defendant.
PRAECIPE TO REINSTATE AMENDED COMPLAINT
TO THE PROTHONOTARY:
Kindly reinstate the Amended Complaint against the
Defendant(s) in the above-captioned Civil Action for an additional
thirty (30) days.
KRZYWICKI & ASSOCIATES
DATED: November 13, 2006
BY:
An P. Krzywicki, Esq.
A orney for Plaintiff
-
?-
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2006-03209 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
PPL ELECTRIC UTILITIES CORP
VS
EISENBERGER DEREK E AKA ERIK E
R. Thomas Kline Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
EISENBERGER ERIK E but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT & NOTICE ,
NOT FOUND , as to
the within named DEFENDANT , EISENBERGER ERIK E
9 EAST ALLEN STREET APT 1-E
MECHANICSBURG, PA 17055-2312
DEFENDANT IS NOT KNOWN AT GIVEN ADDRESS.
Sheriff's Costs: So answer
Docketing 18.00
Service 8.80
Not Found 5.00 R. Thomas Kline
Surcharge 10.00 Sheriff of Cumberland County
.00
41.80 ? KRZYWICKI & ASSOCIATES
12/12/2006
Sworn and Subscribed to before
me this day of ,
A. D.
KRZYWICKI & ASSOCIATES
Anthony P. Krzywicki, Esq.
P.O. BOX 505
New Hope, PA 18938
(215) 862-4390
Attorney for Plaintiff
Attorney I.D. 23754
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
PPL ELECTRIC UTILITIES,CORP.,
Civil Action - In Law
Plaintiff, No. 06-3209
vs.
ERIK E. EISENBERGER,
Defendant.
ARBITRATION
PRAECIPE TO REINSTATE AMENDED COMPLAINT
TO THE PROTHONOTARY:
Kindly reinstate the Amended Complaint against the Defendant(s) in the above-captioned
Civil Action for an additional thirty (30) days.
DATED: May 3, 2007
KRZYWICKI & ASSOCIATES
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CID
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-03209 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PPL ELECTRIC UTILITIES CORP
VS
EISENBERGER DEREK E AKA ERIK E
BRIAN BARRICK , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
EISENBERGER ERIK E the
DEFENDANT , at 2000:00 HOURS, on the 14th day of May 2007
at 16 E KELLER STREET
MECHANICSBURG, PA 17055-2312 by handing to
ERIK EISENBERGER
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 9.60
Affidavit .00
Surcharge 10.00
.00
37.60
Sworn and Subscibed to
before me this day
of ,
So Answers:
R. Thomas Kline
05/16/2007
KRZYWICKI & ASS
By.
A. D.
Deputy"Sherif
2255PD
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
PPL Electric Utilities Corp.
Plaintiff
Civil Action - In Law
vs
ERIK E. EISENBERGER
Defendant
No. 06-3209
ARBITRATION
PRAECIPE FOR JUDGMENT AGAINST
DEFENDANT FOR FAILURE TO PLEAD
To the Prothonotary:
COUNT 1
PPL Electric Uti sties Corp. vs.
ERIK E. EISENBERGER
Kindly enter default judgment in favor of Plaintiff, PPL
Electric Utilities Corp. and against Defendant, ERIK E. EISENBERGER
for failure to plead to Plaintiff's Complaint as follows:
Amount Past Due: $ 7148.95
Fees: $ 2400.00
Court Costs: $ 55.50
Service Costs: $ 100.00
TOTAL $- 9704.45-
together with interest thereon from the date of judgment forward
and all costs of this action.
`.
2255PD
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 2 North 9th Street, Allentown, PA 18101.
2. The true and correct address of the Defendant, ERIK E.
EISENBERGER, is 16 E. Keller Street, Mechanicsburg, CUMBERLAND
County, PA 17055.
KRZYWICKI .R?MSOC
DATED: July 17, 2007 By:
tint on icki
4 N th an Road
BOX 05
ew Hope, PA 1893
215-862-4390
Attorney for Plainti
Attorney I.D. 23754
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CASE NO: 2006-03209 P
SHERIFF' S RETURN - REGU?,AR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PPL ELECTRIC UTILITIES CORP
VS
EISENBERGER DEREK E AKA ERIK E
BRIAN BARRICK
Sheriff or Deputy Sheriff of
ZZ545-PP
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
EISENBERGER ERIK E the
DEFENDANT , at 2000:00 HOURS, on the 14th day of May , 2007
at 16 E KELLER STREET
MECHANICSBURG, PA 17055-2312 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: So Answers:
Docketing 18.00
Service 9.60
r-O
Affidavit .00
Surcharge 10.00 R. Thomas Kline
.00
37.60 05/16/2007
KRZYWICKI & ASS IATES
Sworn and Subscibed to By:
before me this day Deputy Sheriff
of A.D.
s?
2255PD
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
PPL Electric Utilities Corp.
Plaintiff
vs
ERIK E. EISENBERGER
Defendant
Civil Action - In Law
No. 06-3209
ARBITRATION
The undersigned hereby certifies that written notice of intention to
file a praecipe for entry of judgment by default against the
defendant, ERIK E. EISENBERGER, 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 &/JtSSOCIATES
DATED: July 17, 2007 By:
xnr- icki
49 9-y"Lflj-45-n7load
P.O. Box 505
New Hope, PA 18938
215-862-4390
Attorney for Plaintiff
Attorney I.D. 23754
C.0
In-
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2255PD
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
PPL E ectric Uti sties Corp.
Plaintiff
Civil Action - In Law
vs
ERIK E. EISENBERGER
Defendant
No. 06-3209
ARBITRATION
TO: ERIK E. EISENBERGER
16 E. Keller Street
Mechanicsburg, PA 17055
Date: June 12, 2007
NOTICE
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
By:
KRZYWICKI
ASSOCIATES
rzv c ci
49 ljbr? Suga
P.O. ox 505'
New Hope, PA
215-862-4390
Attorney for
Attorney I.D.
18938
Plaintiff
23754
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2255PD
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
PPL Electric Utilities Corp.
Plaintiff
vs
ERIK E. EISENBERGER
Defendant(s)
Civil Action - In Law
No. 06-3209
AFFIDAVIT OF SERVICE
STATE OF
COUNTY OF MOSOMM 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 cla m it on
06/12/2007.
Ant ny . Krzywicki
At r y for lai
K icki a soc.iates
P.O. Box 505
New Hope, PA 18938
PA ID# 23754
215-862-4390
Cadverine Ross-Macaluso, public
MONWEALTH OFP. 6W9ftVAN1A
COM
NOTARIAL SEAL
Sole6uryTyvp.. Bucks?t'??J
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Conas'iission Expires M>irolti , 2010
SWORN TO AND SUBSCRIBED
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2255PD
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
PPL Electric Utilities Corp.
Plaintiff
Civil Action - In Law
vs
ERIK E. EISENBERGER
Defendant
No. 06-3209
ARBITRATION
AFFIDAVIT OF-NON-MILITARY SERVICE
STATE OF
COUNTY OF
ss.
I, Anthony P. Krzywicki, being duly sworn according to law,
deposes and state that I am a representative of PPL Electric
Utilities Corp., 2 North 9th Street, Allentown, PA 18101, Plaintiff
herein, and as such state the following:
1. The defendant, ERIK E. EISENBERGER, 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, ERIK E. EISENBERGER, is more than 18 years
of age and currently resides at 16 E. Keller Street, Mechanicsburg,
PA 17055.
3. I have ascertained the above informatio y personal
investigation and make this affidavit with du ority.
t trbnv.? .
Swor and subscri ed befo
me t4iff 17 day of y 2007
ary
WEALTH OF ""SYL.VAIV?,?
NOTARIAL SE,gL
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2255PD
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Cumberland County Courthouse * Carlisle, PA 17013
Curtis R. Long
Prothonotary
TO: ERIK E. EISENBERGER
16 E. Keller Street
Mechanicsburg, PA 17055
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
PPL Electric Utilities Corp.
Plaintiff
vs
ERIK E. EISENBERGER
Defendant
Civil Action - In Law
No. 06-3209
ARBITRATION
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
( ) Money Ju
( ) Judgment
( ) Judgment
( ) Judgment
( ) Judgment
( ) Judgment
Curtis R. Long
by Default Prothonotary
dgment
in Replevin
for Possession
on Award of Arbitration
on Verdict
on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL
ATTORNEY FOR THE FILING PARTY:
Anthony P. Krzywicki
KRZYWICKI & ASSOCIATES
49 North Sugan Road
P.O. Box 505
New Hope, PA 18938
215-862-4390
Attorney I.D. No.23754
111 aa, a0o7
KRZYWICKI & ASSOCIATES, P.C.
Anthony P. Krzvwicki, Esquire
Attorney for Plaintiff
P.O. Box 50.5
New Hope, PA 18938
(215) 862-4390
PA Attornev ID 23754
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORP..
vs.
ERIK E. EISENBERvER.
Plaintiff,
Civil Action - In Law
No.: 06-3209
Defendant.
MOTION TO COMPEL DISCOVERY
Pursuant to Pa.R.C.P. 4019, Plaintiff, PPL Electric Utilities Corp., moves the Court to
enter an order in the form attached, directing Defendant. Erik E. Eisenberger, to comply with
Plaintiff's discovery requests within thirty (30) days of the entry of the Order, and to pay to
Plaintiff costs incurred in preparing this motion and supporting memoranda. In support of this
motion Plaintiff alleges as follows:
1. Plaintiff served Interrogatories directed to Defendant, Erik E. Eisenberger, on
August 18, 2009 and October 1, 2009. See Exhibit A.
2. No answers or objections to Plaintiff's Interrogatories directed to Defendant,
Erik E. Eisenberger, have been received by Plaintiff as of the date of this motion.
3. A Judge has not ruled upon any other issues in this matter.
4. There is no opposing counsel of record.
WHEREFORE, Plaintiff, PPL Electric Utilities Corp. respectfully requests the Court
to enter an order-directing Defendant, Erik E. Eisenberger, to comply with Plaintiff's
discovery requests within thirty (30) days of the date of order, and to pay Plaintiff costs
incurred in preparing this motion and supporting memoranda.
DATED: November 20. 2009
Respectfully submitted,
KRZYWICKI
TES, P.C.
KRZYWICKI & ASSOCIATES. P.C.
Anthony P. Krzywicki. Esquire
Attorney for Plaintiff
P.O. Box 50.5
New Hope, PA 18938
(215) 862-4390
PA Attorney ID 23754
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORP..
Plaintiff,
vs.
Civil Action- In Law
No.: 06-3209
ERIK E. EISENBERGER,
Defendant.
MEMORANDUM IN SUPPORT OF
PLAINTIFF'S MOTION TO COMPEL DISCOVERY
1. STATEMENT OF FACTS
This case arose from an action brought by Plaintiff, PPL Electric Utilities Corp., to
recover sums due from damages to their property.
Plaintiffi's Interrogatories directed to Defendant. Erik E. Eisenberger, were served on
Defendant on August 18, 2009 and October 1, 2009.
Plaintiff has received no answers or objection to Plaintiff's Interrogatories directed to
Defendant, Erik E. Eisenberger, no answers have been produced and no extension of time to
answer has been requested by the Defendant.
II. DISCUSSION
Defendants' failure to answer Plaintiffs Interrogatories directed to Defendant, Erik E.
Eisenberger. is in violation of Pa.]Z.C.P. 3117. 4006 (a)(2) and 4009.
Rule 4019(a) (1) (1) and 4019 (a) (1) (vii) permit the court, upon motion, to impose
sanctions against a party who fails to respond to discovery requests. Additionally, Rule 4019 (c)
(5) states that "[t]he Court, when acting tinder subdivision (a) of this rule, may make ...such order
with regard to the failure to make discovery as is just." In Gonzalez v. Procaccio Brothers
Trucking Co_, 268 Pa. Super. 245. 407 A.2d 1' )38 (1972), the Court Stated:
Pa.R.C.P. 4019 is clear. It establishes an unequivocal and mandatory procedure.
Where [a party fails to comply with a discovery request] a motion must be
presented to the court to determine the default. [Citation omitted.] Upon finding
that a default has occurred, "the court may...make an appropriate order."
The imposition of specific sanctions, however, is largely within the discretion of
the court. [Citations omitted].
407 A.2d at 1341.
111. CONCLUSION
For the foregoing reasons. Plaintiff requests that the Court enter an order, in the form
attached, directing Defendant to comp]_v with Plaintiffs discovery requests.
Respectfully submitted,
KRZYWICKI & ASSOCIATES, P.C.
DATED: November 20, 2009
BY:
P.
EXHIBIT A
LAW OFFICES
KRZYWICKI & ASSOCIATES, P.C.
1'. O. [SOX 505
NEW HOPE, PA 18938
(215) 862-4390
FAX: (215) 862-4393
August 18, 2009
Mr. Erik E. Eisenberger
1132 Columbus Avenue
Lemoyne, PA 17043
Re: PPL Electric Utilities Corp. vs. Erik E. Eisenberger
Civil Action No.: 06-3209
Our File No.: 2255 PD
Dear Mr. Eisenberger:
Because you have failed to pay the judgment entered against you to the above term and
number, the Judgment-Creditor, has the right to attempt to collect that judgment by an involuntary
Judicial Sale (Sheriffs Sales) of your assets and has the right, for assistance in such sale, to inquire
concerning the existence and location of such assets.
Enclosed herewith for service upon you is an original set of Interrogatories in Aid of
Execution. The questions (interrogatories) contained therein must be answered by you in full in the
spaces provided, or on supplemental sheets if such space is insufficient. The answers must be
verified as true subject to criminal penalties as provided, and the original must be returned to this
office within thirty (30) days of receipt.
Failure to respond to the enclosed interrogatories may subject you to punishment in
accordance with law including being found to be in contempt of court with punishment imposed
therefore and also to substantial additional expense.
Service is made by regular mail as provided by law. In the event the proper response is not
received, the address will be verified through your local post office.
Relevant portions of the controlling law (Rules of Civil Procedure) are set forth below but if
you have any questions concerning this matter, it is strongly suggested you seek legal assistance or
guidance since your failure to respond to the enclosed truthfully and within the time required will
subject you to the sanctions imposed by law.
RULE 3117. Discovery in Aid of Execution.
(a) Plaintiff, at any time after judgment, before or after the issuance of a writ of
execution, may, for the purpose of discovery of assets of the defendant, take the testimony of any
person, including a defendant or garnishee, upon oral examination or written interrogatories as
provided by the rules relating to Depositions and Discovery...
(b) All reasonable expenses in connection with the discovery may be taxed against the
defendant as costs if it ascertained by the discovery proceedings that he has property liable to
execution.
RULE 4005. Written Interrogatories to a Party.
(a) ... any party may serve upon any other party the original and two copies of written
interrogatories to be answered by the party served... Interrogatories may be served upon any party
at the time of service of the original process or at any time thereafter...
(a) (1) Answers to interrogatories shall be in writing and verified. The answers shall
be inserted in the spaces provided in the interrogatories. If there is insufficient space to answer an
interrogatory, the remainder of the answer shall follow on a supplemental sheet.
RULE 4019. Sanctions.
(a) (1) The Court may, on motion, make an appropriate order if
(i) a party fails to serve answers, sufficient answers, or objections to written
interrogatories under Rule 4005...
(c) The Court, when acting under Subdivision (a) of this rule, may make...
(4) an order imposing punishment for contempt...
KRZYWICKI & ASSOCIATES, P.C.
Anthony P. Krzywicki, Esquire
Attorney for Plaintiff
APK/amg
Enclosures
cc: Court of Common Pleas
KRZYWICKI & ASSOCIATES, P.C.
Anthony P. Krzywicki, Esquire
Attorney for Plaintiff
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 CORP.,
vs.
Plaintiff,
Civil Action - In Law
No.: 06-3209
ERIK E. EISENBERGER,
Defendant.
INTERROGATORIES TO DEFENDANT, ERIK E. EISENBERGER
FOR DISCOVERY OF ASSETS IN AID OF EXECUTION
The Plaintiff, PPL Electric Utilities Corp. through its attorney, Anthony P. Krzywicki,
herewith and hereby makes demand that you, the Defendant, in this action give written answers,
verified as true pursuant to Pennsylvania Rules of Civil Procedure No. 3117, 4005 and 1006 within
thirty (30) days from service hereof.
These interrogatories are continuing and any information secured subsequent to the filing of
your Answers which would have been includable had it been known or available to you at the time
are to be supplied by Supplemental Answers.
All questions directed to you personally shall include and extend to any business conducted
or property interests you may have under or standing in any assumed, fictitious, or business name or
names.
1. State your name, current address, place of employment, occupation and present salary and
all sources of income and also prior addresses, other names used, and other places of employment
within the last two (2) years.
2. Identify any ownership interests you have, including under Agreements of Sale, in real
estate located anywhere in this country and identify such real estate by state, county, municipality
and address, date property was titled in current ownership, the assessed value thereof and the name,
address and relationship of any joint owners.
3. Identify any bank accounts recorded in your name, either jointly or with others, including
checking accounts, savings accounts, credit union accounts, certificates of deposit, or other
accounts. State the address of the bank, savings and loan association, building and loan association,
credit union or other institution, the identification numbers of the accounts, the amounts in each and
the name, address and relationship to you of any person whose name appears jointly with you on
such accounts.
4. Identify any motor vehicles in which you have an interest by make, model, title number,
serial number, registration plate, the exact name or names in which registered, the address and
relationship of any joint owners to you, the present location of the vehicle and the amount and
holder of any encumbrances thereon.
5. State the names, addresses and relationships of any persons whom you believe owe you
money, the amounts owed and a full description of any mortgage, judgment note or other evidence
of that indebtedness including date, amount, method of payment and whether recorded and, if so,
where.
6. Identify any interest you have in any pension plan, whether an individual plan, such as an
IRA, or a corporate plan through your employer, and identify your exact interest therein.
7. Identify any life insurance contracts, which you own on your life or that of another as to
name and address of the insurance company, policy number, and face amount of all such accounts,
named beneficiaries and their relationship to you and name, address and relationship of any joint
owners.
8. Identify any corporate, government or municipal bonds or stocks, or individual or corporate
mortgages owned by you as to number and value thereof and give the name, address and
relationship to you of any joint owners thereon.
9. Identify in full any property transferred by you as a gift or without full monetary
consideration therefore within the past two (2) years, the value of such property and the name,
address and relationship to you of the transferee.
10. Identify in full any business in which you have an ownership or proprietary interest and state
the nature of your interest therein, the assets, including accounts receivable thereof, and the names,
addresses and relationships to you of any persons with a joint interest with you in said business.
11. Identify any other items of particular value in which you may have any interest and the
nature and value of such interest, and the names, addresses and relationships to you of others having
a joint interest with you therein and the nature of such interest, including, but not necessarily
limited to:
a. Jewelry, works of art, stamp, coin or other collections or other items of personal
property of special value;
b. safe deposit boxes identified as to the location and contents thereof,
c. inheritances or interests in the estates of deceased persons;
d. interest, either current or future, in trust funds or annuity contracts or interests;
e. uncollected lottery or gambling winnings or awards and prizes of any kind and when
and how the same are to be paid;
f. other.
12. Identify any persons, other than your spouse, whom you feel are obligated to you by any
reason of their use of credit with PPL Electric Utilities Corp. and the reason for and extent of such
obligations.
13. Identify in full any judgments of record, other than that of Plaintiff, against you and any
suits or other legal proceedings presently pending for the collection of such judgments or overdue
and unpaid taxes of any kind.
Dated: August 18, 2009
KRZYWICKI & ASSOCIATES, P.C.
BY:
Anthony P. Krzywicki, Esquire
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORP.,
vs.
Plaintiff,
Civil Action - In Law
No.: 06-3209
ERIK E. EISENBERGER,
Defendant.
VERIFICATION
I verify that the statements contained in these Interrogatories in Aid of Execution are true
and correct, and I understand that any false statements made herein are made subject to the penalties
of 18 PA. C.S. 4904 relating to unsworn falsification to authorities.
Dated:
Defendant
CERTIFICATE OF SERVICE
I, Anthony P. Krzywicki, Attorney for Plaintiff, hereby certifies that a true and
correct copy of the foregoing document was placed in a depository under the exclusive care
and custody of the United States Postal Service to deliver via First Class Mail to the
following:
Mr. Erik E. Eisenberger
1132 Columbus Avenue
Lemoyne, PA 17043
KRZYWICKI & ASSOCIATES, P.C.
DATED: August 18, 2009
Anthony P. Krzywicki, Esquire
Attorney for Plaintiff
LAW OFFICES
KRZYWICKI & ASSOCIATES, P.C.
P. O. BOX 505
NEW HOPE. PA 18938
(215) 862-4390
FAX: (215) 862-4393
SECOND REOUEST
October 1, 2009
Mr. Erik E. Eisenberger
1132 Columbus Avenue
Lemoyne, PA 17043
Re: PPL Electric Utilities Corp. vs. Erik E. Eisenberger
Civil Action No.: 06-3209
Our File No.: 2255 PD
Dear Mr. Eisenberger:
Because you have failed to pay the judgment entered against you to the above term and
number, the Judgment-Creditor, has the right to attempt to collect that judgment by an involuntary
Judicial Sale (Sheriffs Sales) of your assets and has the right, for assistance in such sale, to inquire
concerning the existence and location of such assets.
Enclosed herewith for service upon you is an original set of Interrogatories in Aid of
Execution. The questions (interrogatories) contained therein must be answered by you in full in the
spaces provided, or on supplemental sheets if such space is insufficient. The answers must be
verified as true subject to criminal penalties as provided, and the original must be returned to this
office within thirty (30) days of receipt.
Failure to respond to the enclosed interrogatories may subject you to punishment in
accordance with law including being found to be in contempt of court with punishment imposed
therefore and also to substantial additional expense.
Service is made by regular mail as provided by law. In the event the proper response is not
received, the address will be verified through your local post office.
Relevant portions of the controlling law (Rules of Civil Procedure) are set forth below but if
you have any questions concerning this matter, it is strongly suggested you seek legal assistance or
guidance since your failure to respond to the enclosed truthfully and within the time required will
subject you to the sanctions imposed by law.
RULE 3117. Discovery in Aid of Execution.
(a) Plaintiff, at any time after judgment, before or after the issuance of a writ of
execution, may, for the purpose of discovery of assets of the defendant, take the testimony of any
person, including a defendant or garnishee, upon oral examination or written interrogatories as
provided by the rules relating to Depositions and Discovery...
(b) All reasonable expenses in connection with the discovery may be taxed against the
defendant as costs if it ascertained by the discovery proceedings that he has property liable to
execution.
RULE 4005. Written Interrogatories to a Party.
(a) ... any party may serve upon any other party the original and two copies of written
interrogatories to be answered by the party served... Interrogatories may be served upon any party
at the time of service of the original process or at any time thereafter...
(a) (1) Answers to interrogatories shall be in writing and verified. The answers shall
be inserted in the spaces provided in the interrogatories. If there is insufficient space to answer an
interrogatory, the remainder of the answer shall follow on a supplemental sheet.
RULE 4019. Sanctions.
(a) (1) The Court may, on motion, make an appropriate order if
(1) a party fails to serve answers, sufficient answers, or objections to written
interrogatories under Rule 4005...
(c) The Court, when acting under Subdivision (a) of this rule, may make...
(4) an order imposing punishment for contempt...
KRZYWICKI & ASSOCIATES, P.C.
Anthony P. Krzywicki, Esquire
Attorney for Plaintiff
APK/amg
Enclosures
cc: Court of Common Pleas
4
CERTIFICATE OF SERVICE
I, Anthony P. Krzywicki, Attorney for Plaintiff, hereby certifies that a true and correct
copy of the foregoing Motion to Compel, Memorandum in Support thereof and a form of
Order were placed in a depository under the exclusive care and custody of the United States
Postal Service to deliver via First Class Mail to the following:
Mr. Erik E. Eisenberger
1 132 Columbus Avenue
Lemoyne. PA 17043
KRZYWICKI &,AWCIATES, P.C.
DATED: November 20. 2009
By:
Xony P.
ywic &
x 505 .
New Hope,TA 1893'
(215) 862-4390 t
Attorney for Plaintiff
Attornev ID 23754
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LtiuF,? LJ IF C• v3)
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Nov 3 U zoos o
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL, ELECTRIC UTILITIES CORP.,
Plaintiff,
vs.
ERIK E. EISENBERGER.
Defendant.
Civil Action - In Law
No.: 06-3209
ORDER
AND NOW, this day of 2009, upon consideration of Plaintiff's
Motion to Compel Discovery, it is hereby ORDERED AND DECREED:
a. Defendant, Erik E. Eisenberger, is directed to provide full and complete answers
to Interrogatories within thirty (30) days of the date of this Order, and
b. Defendant, Erik E. Eisenberger, is required to respond fully and completely to
each discovery request item by item, in accordance with the Rules, within thirty (30) days of the
date of this Order: and
C. Defendant. Erik E. Eisenberger, is required to produce for inspection and copying
by Plaintiff all documents responsive to Plaintiff's document request within thirty (30) days of
the date of this Order
u
"r +riml f4+ five erm@..
+
e. In the alternative, may file within ^ r ,0) days of service hereof a motion for
hearing.
J.
RLE'&-D F
OF TF!w '')TA Y
2009 DEC -2 AN C: 3 6
Cui'vL- ,r
I?lalo?r - l.?P ? ES r?? c t.?cl.
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
PPL ELECTRIC UTILITIES CORP.,
Plaintiff,
vs.
ERIK E. EISENBERGER,
Civil Action - In Law
No.: 06-3209
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 Motion
to Compel Discovery in the above matter, addressed to Defendant, Erik E. Eisenberger, at his last
known address, which is 1132 Columbus Avenue, Lemoyne, PA 17043, by First Class Mail with
Certificate of Mailing under the exclusive care and custody of the United States Postal Service
on December 7, 2009. A copy of the Certificate of Mailing receipt is annexed hereto and made a
part hereof.
KRZYWIC,K '& 4SSOCIATES, P.C.
By:
P
Sworn to before me this
h day of A-C r 2009.
C-- M
NOTARY PUBLIC
NOTARIAL SEAL
AMY M GLASGOW
Notary Public
SOLEBURY TWP, BUCKS COUNTY
[My Commission Expires Mar 14, 2012
Esquire
O p5
N eL?'`Ope, PA 18938
Attorney ID No. 2375
(215) 862-4390
r ?J ? ru strtVlCE
CERTIFICATE OF
'jF R rR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR
INSURANC O E-POSTNTER
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Krzywicki 4-Associates, P.C. ° A A
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P.O. Box St
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