A recent legal filing outlines allegations that unsafe conditions at a residential property resulted in severe injuries for a visitor, raising questions about responsibility among several property owners and contractors. The complaint was submitted by Celeste Golub on March 24, 2026, in the Court of Common Pleas of Delaware County against Kit Raven, William D. Conwell, William D. Conwell, Inc., Dan Marrollo Electric Inc., Dan Marrollo Electric Service, Inc., John Dickerson, John Dickerson Design Group, and an unidentified party referred to as John Doe.
According to the complaint prepared by attorneys Louis B. Himmelstein and Timothy J. Alles of Louis B. Himmelstein & Associates P.C., the plaintiff alleges that she sustained “serious and permanent orthopedic and neurological injuries” after falling on or near March 31, 2024, at or near 21 Dartmouth Avenue in Swarthmore. The suit claims that the defendants either owned, controlled, maintained, leased, or performed contracting work on the premises where the incident occurred.
The document describes a range of alleged hazardous conditions present at the time of the incident. These include “a dangerous staircase, loose concrete/slate, dangerous steps, steps without a railing/handrail, defective steps,” as well as issues with lighting such as “disconnected lighting” leading to an “extremely dark area.” The complaint asserts that these conditions were left unaddressed without warning signs or barriers to prevent accidents: “the dangerous condition presented an unreasonable risk of harm to pedestrians such as Plaintiff…and said dangerous condition caused the Plaintiff…to slip, trip, stumble and fall violently to the ground.”
Specific allegations are made against various defendants regarding their roles in creating or failing to remedy these hazards. For example, it is claimed that “William D. Conwell and/or William D. Conwell Inc. was the contractor who installed the dangerous concrete/slate and/or step and/or patio that caused the said trip hazard,” while “Dan Marrollo Electric Service Inc. and/or Dan Marrollo Electric Inc., was the electrician who was responsible for the lighting and/or did take out a light causing the area to be dangerous or too dark.” The complaint further states that all defendants had both actual and constructive notice of these dangers but failed to correct them despite having sufficient time.
Golub’s filing lists numerous alleged failures by those responsible for maintaining or working on the property: “Failing to properly maintain the premises…failing to exercise due care under the circumstances; being otherwise careless and negligent; allowing the dangerous and defective steps…to remain on a path used by pedestrians; failing to warn or otherwise notify…of said defect.” The plaintiff contends these acts constitute negligence under local ordinances and statutes.
As a result of her fall, Golub claims she suffered injuries including fractures, sprains (notably cervical sprain/strain and lumbar sprain/strain), pain described as “excruciating,” mental anguish, cosmetic disfigurement such as scarring, loss of earnings capacity, medical expenses already incurred with more anticipated in future treatment needs: “Plaintiff has been and continues to be obliged to receive medical attention…and will be obliged to continue…for an indefinite time in the future.” She also asserts diminished ability to perform daily duties due to her injuries.
The legal action seeks damages from each defendant individually or collectively “for an amount in excess of Fifty Thousand Dollars ($50,000.00).” Each count within the complaint reiterates this demand based on allegations specific to each named party’s involvement with ownership or maintenance responsibilities related to hazardous conditions at 21 Dartmouth Avenue.
The case is represented by attorneys Louis B. Himmelstein (ID# 41140) and Timothy J. Alles (ID# 311442) from Louis B. Himmelstein & Associates P.C., located at 1420 Walnut Street-Suite 1000 in Philadelphia. The case was filed under Civil Action No.: (number not specified) in Delaware County.
Source: CV2026002661_Celeste_Golub_v_Kit_Raben_Complaint_Delaware_County_of_Pennsylvania.pdf
