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HomeMy WebLinkAbout94-04048 ~, i Fi jj . . ,. " . . " fA &, ~I-rj ,1''0 ~ ~ ~ .,.. ~~ "<j \,., <.;;;) tfi ....~.. ~ ~ " e ~~l...r :T ('() , -~1.)4 "'- = ,...(. '. ~ , ",.1:0.".1 nl-'"i.>.. ~ ~ N .1.'", - J,-:'", ,. ..t-.; ~ fa ' . I ~~~ l~. ~~b .".. ',I..:,,,. ~ '6 ' ;"l .lit '{;j ~,' @J Iq 2 ~=jel ~hU iJ!Jl , , , . . . . METROPOLITAN EDISON COMPANY, I IN TilE COURT OF COMMON PLEAS Plaintiff I CUMBERLAND COUNTY, PENNA. I v. I CIVIL ACTION - LAW I NOI LARRY L. SIlAULIS, I Defendant I JURY TRIAL DEMANDED COMPLAINT AND NOW, comes Plaintiff, Metropolitan Edison Company, by and through its attorneys, Peters & Wasilefski, and files this Complaint against Defendant, Larry L. Shaulis ("Defendant"), based upon the followingl 1. Plaintiff, Metropolitan Edison Company, is a Pennsylvania Corporation with offices and principal place of business located at 2800 pottsville Pike, Reading, Berks County, Pennsylvania. 2. Defendant, Larry L. Shaulis, is an adult individual residing at 431 Old State Road, Gardners, Adams County, Pennsylvania 17324. 3. At all times relevant hereto, Plaintiff, Metropolitan Edison Company, was in the business of generating, supplying, distributing and selling electrical power, and pursuant to that business owned a utility pole designated as ME 16854-29442 with attached electrical facilities situated along Lerew Road in South Middleton Township, Cumberland County, Pennsylvania. 4. On or about January 24, 1993, Defendant, Larry L. Shaulis was operating a 1977 GMC Scottsdale east on Lerew Road in such a negligent, careless and reckless manner, and at such an unsafe speed so as to permit the vehic 113 to leave the traveled portion of Lerew Road and strike a utility pole owned by Plaintiff, Metropolitan Edison Company. 5. As a direct and proximate result of the negligence, carelessness and recklessness of Defendant, Larry Shaulis, Plainti ff, Metropoli tan Ediaon Company Buf fered damages in the amount of $5,078.49, relative to the repair/replacement of the utility pole and related facilities, and for the labor and related expenses incurred therefor. 6. The damages complained of by Plaintiff, Metropolitan Edison Company in the instant Complaint, were caused by the negligent, careless and reckless manner in which Defendant, Larry Shaulis operated the motor vehicl.e on the date and at the time in question. 7. Defendant, Larry L. Shaulis, was negligent, careless and reckless in the manner in which he operated the vehicle in question, at the time and on the date in question, as follows: (a) In failing to keep adequate control over the vehicle which he was operatingl (b) In failing to apply his brakes in time to avoid striking the utility pole owned by Plaintiff, Metropolitan Edison Company; (c) In failing to exercise the degree of care required while operating a motor vehicle on the highway; (d) In operating the motor vehicle at a speed greater than was reasonable and prudent under the conditions having regard to the actual and potential hazards then and - 2 - there existing, (e) In operating his vehicle at a speed greater than would permit him to negotiate the curve on Lerew Road in the eastbound direction at or near the area where the , collision with the utility pole occurred, (fl In operating the vehicle at a speed greater than would permit him to bring the vehicle to a stop within the assured clear distance ahead, (g) In failing to drive at a safe and appropriate speed with respect to the conditions and the design of the highway I (h) In driving the vehicle at a speecl in excess of the maximum posted speed limit; and (i) In operating his vehicle in careless disregard for the safety of persons or property. 8. Defendant, Larry L. Shaulis, is negligent per se based upon his violations of the Motor Vehicle Code of the Commonwealth of Pennsylvania. WHEREFORE, Plaintiff, Metropolitan Edison Company, demands judgment in its favor and against Defendant, Larry L. Shaulis in the amount of $5,078.49 plus costs. Datf!ltftfff' PETERS & WASILEFSKI ~_/ /'~ By L.,4'/t7.,.".'/~r.p_ /.~ THOMAS A. LANG1, '!rSQUIRE Attorney I.D~.t52670 2931 North ~ront Street Harrisburg, PA 17110 (717) 238-7555 Counsel for Plaintiff, Metropolitan Edison Co. ~ I"", . METROPOLITAN EDXSON COMPANY, I IN THE COURT OF COMMON PLEAS Plaintiff I CUMBERLAND COUNTY, PENNA. I v. I NOI 94-4048 I CIVIL ACTION - LAW LARRY SHAULIS, I Defendant I JURY TRIAL DEMANDED IMPORTANT NOTICE TOI Defendant, Larry Shaulis and his attorney, Robert B. Kreidler, Esquire 126 Locust Street P.O. Box 11409 Harrisburg, PA l7l08-l408 DATE OF NOTICE: October 7, 1994 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM TilE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER RIGHTS. YOU SHOULD TAKE THIS NOTICE 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 LAWYER REFERRAL SERVICE Cumberland County Courthouse One Courthouse Square Carlisl.e, PA 17013 (717) 240-6200 PETERS & WASILEFSKI S A. LAN , Attorney I.D. 293l Nortn Front Street Harrisburg, PA 17110 (717) 238-7555 Datelt1~-t- ~ Iff'! Attorney for Plaintiff ... \r... ~ c:>> :~ C ,--, ~ . )', I~ .. ~~5 ~, ~- .) ,);;t [~ ~L: " ,- - >;. 8' ." I i1 ''I t,I.'J' 1'.) t.n '1"0 ~ ::'~J ': ,0.. "" .,e ~ VJ :., en W sq 0 ~=jEI ~JfH Hi/I D. <C ... . "'".. .