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Home My WebLink About00-00573 I" ~ ~ """"'"--_ill!lfu' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA -------------------------------------------------------- UGI Utilities Inc, Plaintiff Civil Action - In Law No, 2000-573-CV vs, Jeffery Wolaver alk/a Jeff Wolaver t1a Wolaver Plumbing Defendant(s) ARBITRATION PRAECIPE FOR JUDGMENT AGAINST DEFENDANT FOR F AlLURE TO PLEAD To The Prothonotary: COUNT 1 UGI Utilities Inc, vs, Jeffery Wolaver alk/a Jeff Wolaver t1a Wolaver Plumbing Kindly enter default judgment in favor of Plaintiff, UGI Utilities Inc, , and against Defendant, Jeffery Wolaver alk/a Jeff Wolaver t/a Wolaver Plumbing, for failure to plead to Plaintiffs Amended Complaint as follows: Amount Past Due: TOTAL $1.553,54 $1,553.54 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: I, The true and correct address of the Plaintiff, UGI Utilities Inc, , is 225 Morgantown Road, Reading, P A 17602. 2, The true and correct address of the Defendant, Jeffery Wolaver alkla Jeff Wolaver t/a Wolaver Plumbing, is One Center Street, Enola, PA 17025, Krzywicki and Associates BY: DATED: April 24, 2000 - -__"C1c SHERIFF'S RETURN - REGULAR CASE NO: 2000-00573 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS WOLAVER PLUMBING CPL, MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WOLAVER PLUMBING the DEFENDANT , at 0016:05 HOURS, on the 4th day of February, 2000 at 1 CENTER STREET ENOLA, PA 17025 by handing to CHRALES WOLAVER (FATHER) a true and attested copy of COMPLAINT & NOTICE together with IN ARBITRATION and at the same time directing His attention to the contents thereof, Sheriff's Costs: Docketing Service Affidavit Surcharge 18,00 9.92 ,00 10,00 ,00 37,92 sO;:~~f R. Thomas Kline 02/07/2000 KRZYWICKI & ASSOC. me this day of By: ~~~ ' Deputy S eri ~) V Sworn and Subscribed to before A.D, Prothonotary e ~-~ """""",.>j''L'"''''~_''' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UGI Utilities Inc. Plaintiff Civil Action-In Law vs. Jeffery Wolaver a/k/a Jeff Wolaver t/a Wolaver Plumbing Defendant(s) No. 2000-573-CV 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 AMENDED CIVIL ACTION COMPLAINT on Defendant (s) by Proof of mailing (PS Form 3817, Mar, 1989) on March 16, 2000. ic for Plaintiff, Kr cki and Associates p, O. Box 505 New Hope, PA 18938 PA ID# 23754 609-397-9014 SWORN TO AND SUBSCRIBED BEFORE ME THIS 2'1 DAY otary ~J?ublic MICHELLE PYATT NOTAI'lYPUBLIC OF NEW JERSEY MY C,?MMI,S.$ION EXPIRES JULY 9, 2002 . '-, , , _~~dW1tl~"'~' U.S, POST SERVICE CERTIFICATE OF MAILING MAYBE USED FOR DOMESTIC AND INTERNA TlONAl MAil, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Recel' Krzywicki & Associates P.O. Box 505 New Hope, PA 18938 One piece of ordinary mall addressed to: Ss<..('~'{ (n-,\,.., l)@ r LLb\CU1e (" '71 u--tv1() In j ()"jL Cr; '" f-e ( S-b-v o:t fnolo PA 17025- I S Form ;;,;;;;;:;J989 ~/~ . .~...~ : \/ .~ ~ ,11 .. ' -- II (v ~ :~',I -, \7 '." .~'.! " ...,-'.1 ! ':....--;..>/)I"r,,:.. 'I. ~ "C~t\:l'~.,"'{~~ -j~~. // / ~~$!~::1\ ~~ t~ f of b ;;:~~Q\ll \~~ ~.~.. ~~~ ',--=~'~\ ~ \1\\ lQ' t.t.\ jmJ i't! ...>>-.........It...lt''' ,... I~~ _= ~ - ";1,"IIO>i'I~;' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA UGI Utilities Inc, Plaintiff Civil Action - In Law No. 2000-573-CV vs. Jeffery Wolaver a/k/a Jeff Wolaver t/a Wolaver Plumbing Defendant( s) NOTICE TO: Jeffery Wolaver a1k/a Jeff Wolaver tla Wolaver Plumbing One Center Street Enola, PA 17025 DATE: April 11, 2000 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 caunot 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, P A 17013 (717) 249-3166/(800) 990-9108 Krzywicki & Associates BY: IS/ Anthony p, Krzywicki PO Box 505 NewHope,PA 18938 609-397-7200 Attorney I.D, 23754 1- .....Ii!;'" U,S. POSTAL S!!llVlce CERT FICATE OF MAILING MAY BE USED FOR DOMESnc AND INTERNATIONAL MAil. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER R.ceI' - Krzywicki & Associates p,O. Box 50S New Hope, PA 18938 -; , :::'f .::::.,';., ~ One Piece of ordinary mail addre..ed to: ., -'. , cit'~;;:i{';f~;U 2i ' .,~' (:":,~ '\;t ~. '" _"'';:', I., '::;'};~;I:=-S~II ill-:,M~' = l"~ :iJl ,HI i ~ ,j l We Ia.(Je..- 'Vlu...,-..~. ':E ()no (i"".Ie..- f:::f.-...v,: + 2- ',,,, \..---~~..~~'.._r......_."_..i .... *........,.I.~*~.i}..lIlo. ... " ~ 1- I!i,~'.' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UGI Utilities Inc, Plaintiff Civil Action - In Law No, 2000-573-CV vs, Jeffery Wolaver alk/a Jeff Wolaver t/a Wolaver Plumbing Defendant( s) ARBITRATION The undersigned hereby certifies that written notice of intention to file a praecipe for entry of judgment by default against the defendant, Jeffery Wolaver a/k1a Jeff Wolaver t/a Wolaver Plumbing, 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 & Associates BY: DATED: April 24, 2000 An ony P P Bo 05 NewHope,PA 18938 609-397-7200 Attorney for Plaintiff Attorney ID 23754 ;~~= ~...""..~, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UGI Utilities Inc, Plaintiff Civil Action - In Law No, 2000-573-CV vs, Jeffery Wolaver a/k/a Jeff Wolaver t/a Wolaver Plumbing Defendant(s) 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 ofUGI Utilities'Inc, i 225 Morgantown Road, Reading, P A 17025, Plaintiff, herein, and as such state the folloWing: 1. The defendant( s), Jeffery W 91avera/k/a Jeff Wolaver t/a Wolaver Plumbing, 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, J~ffery Wolaver aIkIa Jeff Wolaver t/a Wolaver Plumbing, is more than 18 years of age and currently doing business at One Center Street, Enola, P A 17025, 3, I have ascertained the above information by personal investigation and make this affidavit with due authority, Sworn to and subscribed before me this Z'1 day of ~II 2000 ILU! & Notary c I .. '; :MICHEllE PYATT NOTARY PUBLIC DFNEWJEASEv MY CUMMISSION EXPfRESJUlY9, 2002 Iil-"- "--....1.'" "-_~nlWilii!~ _ Illh!.tlWHW~~""'" iSj , J.'.' . c .....'~ ' . -- " '" "~ ~ ,~ t ~ ~ (') 0 0 ~ C C> S': -" -0 CO ::c :r . J"" 8 nlrn Z:J:J -< '_"'''Tl ~ z~ I ..p ..0 ~ (j)"""" .j;"' 1i~ =0:;7- S:J ~ ~a ~ -tJ ~o ....., :::c "T' :x o:D ~ f :c:..;:(~) ~ e;~ c .... ~ ~ t J- <="" ~" _c J_ ~,&=".."I,b!"'L,_. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF NO, 00-573 CIVIL 1\1 CIVIL ACTION, LAW Cumbp.rlnnn COUNTY: To satisfy the debt, interest and costs due UGI utilities Inc. PLAINTIFF(S) fmm Jeffery Wolaver a/k/a Jeff Wolaver t/a Wolaver Plumbing 1030 Chester Road Enola, PA 17025 DEFENDANT(S) (1) You are directed to levy upon the pmperty of the defendant(s) and to sell ,,11 prop"rty bel oo\/i!l9:-- Tn ,lp-ffp-ry Wnl rlVAr nkrl ,lp..ff Wol rlViAr t/ a Wol avp.r Plumbing at 1030 Chester Road. Enola, PA 17025 (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of __ GARNISHEE(S) as follows: and to nomy the garnishee(s) that: (a) an attachment has been issued: (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlherthat he/she has been added as a garnishee and is enjoined as above stated, Amount Due Interest $1553.54 Atty's Comm Atty Paid Plaintiff Paid % LL Due prothy Other Costs $1. 00 $141 ql:; Date: October 12, 2001 Curtis R. Long Prothonotary, Civil Division by: ~~ )!. >>./r;, W Deputy REQUESTING PARTY: Name Anthony P. Krzywicki, Esq. Address: P.O. Box 505, New Hope, PA 18938 Attorney for: Plaintiff Telephone: 215 862-4390 Supreme Court ID No. 23754 m . . ~~>~"- -~~~_~I!IaMil~ll!,jl~#~~~.. ~.., ~"'"' tI:Iii!ti W_': Wl U =-> &!!::, i:!b ~ ,- ~ ~~~ .i-", " ,~ -- R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED, Sheriff's Costs: Docketing Poundage Advertising Law Library Prothonotary 1.00 Mileage 10.40 Misc, Surcharge 20.00 Levy Post Pone Sale Garnishee 18.00 .98 50.38 Sworn and Subscribed to before me this .z8;Q<'dayof !La.,..,n. j",,-, 2001 A,D.~. () I1..dd, ~ . "-,_/ I o onotary Advance Costs: Sheriff's Costs: 150.00 50.38 YY.6L Refunded to Arty on 11/21/01 So Answers; ~~~~ 2( v, ~ R, Thomas Kline, Sheriff By CJa{l~(LQ,~Io~ '~1 \ ~'1 \',' /-; -1.,\ !.: 1-: t'o:"3 d "I .' I-~}h~r e~ = fh!6 ~ i.Q) \.~ ~3~WB ~, 1/1)3.0 i (I. \ \J OS Z Z I 130 .U~::':-.;' ,,,ii'l:J ;!,:I1lJ3,," C c'. 3'iH,W ~~~.o -~"""= WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF Cumberland NO. 00-573 CIVIL ~re:rm CIVIL ACTION. LAW COUNTY: To satisfy the debt. interest and costs due nm nH 1 i ties. Inc. PLAINTIFF(S) from ,T",ff",ry Wolaver a/k/a Jeff Wolaver t/a Wolaver plumbing, One Center Street, mola, PA 17025 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell all personal property (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of __ GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from payin!l any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise displ)sing thereOf; (3) If property ofthe defendant(s) not levied upon an subject to attachment is found inthe possession of anyone other than a named garnishee. you are direCted to notify him/her that he/she has been addee! as agarnishee and is enjoined as above stated. Amount Due Interest $1553.54 $53.55 L.L. $.50 $1. 00 $165.00 Atty's Comm Atty Paid Plaintiff Paid % Due Prothy Other Costs $lO'l.'l? Date: ,Tno", 1 6. 2000 Curtis R. Long Prothonotary. Civil Division -bv: a,,/Y> G 2. 7p()7/UJf s Deputy REQUESTING PARTY: Name Anthony P. Krzywicki, Esq. Address: PO Box 505 New Hope, PA 18938 Attorney for~ Plaintiff Telephone: 215-862-4390 Supreme Court ID No. 23754 - .iIiili" '''~'...., "'-'-"'--" .~.... ',~"'., ..~~ ,'. . .~~ R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriffs Costs: Docketing $ 18.00 Poundage .79 Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale ~nishee @ c;:::::::l ~ ~ ~orn and Subscribed to before me .50 1.00 10.40 10.00 40.69 this /:1 e- day of (JJ~ 2001 A.D. 2~"" C!. !k.,d.. '.~' p onotary " . ,,' '"1 I "1 \ \-~ ~ -'\ l. ("-. ;:',- ',It j G \' \ ;': v i\ ! ,', " ',', n ....,'. 01 \) \2 !lnf .. .., :13.\\:) ^ ; }~. ;', ( " ' :~..' '7"'; \ ..d fJ ,-:-\'-'.I\C -:--i.H1. :;1.) .;:ld -' ;l"\ {\;'. ~-' ~-- Advance Costs: $ Sheriffs Costs: 150.00 40.69 109.31 Refunded to Atty on 10/5/01 So Answers; ~~~~~, ~ . G.\ ~ R. Thomas Kline, Sheriff By Cia (uJj(L.Q,~b~ ~ ,:~'V Q 3'/n.\ R....... 1/1&<{/ . ~ I_~ul-<,,,,,,,,wt"'" COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION UGI Utilities Inc. Plaintiff ( ) Confessed Judgment (XX) Other vs. Jeffery Wolaver aJk/a Jeff Wolaver t1a Wolaver Plumbing Defendant File No.: 00-573-CV Amount Due: $1553.54 Interest: $ Atty's Comm: Costs: $ TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1 966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant( s) All property belonging to Jeffery Wolaver aka Jeff Wolaver t1a Wolaver Plumbing at 1030 Chester Road. Enola, PAl 7025 PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies oflengthy personality list) . And all other property of the defendant(s) in the possession, custody or control of the said garnishee( s). o (Indicate) Index this writ against the gamishee(s) as a lis pendens against real estate of the ~efendant( s) described in the attached exhibit Date: September 27, 2001 _.c;:-~= - ..tF. ~ .- '.~, ' .....""'~~, , ~ ~ r...._lilii~(jll!&iJMag- ~~~I!lilM~ ,l'~~'~ .'. ~.>., """. In > R..., "- ~~~~ '- q ~ &~~\::S0~<.v ~ ~ \5<.;J~' )J;Jt\ " \)~ ~~,\:\'1 . r 0 ~~9J& ~ r r 'i' "\, , r , " . . , . '~ " c" ".,..- "T1Cl:" m,T ~~: .... .~- ,"r" .__ ,"-,J ;B , "0; ::::! ~~ - ~ ~ ~ -... -.J ~ . "'-'''-, ~ e:::" c:> n -J i'''-.) f,::; r-- f0 ........'v. ~,~' ~,~~ ~ ~~ ~- ~ - _, .I ~"',""'-'<1l"'~,""". SHERIFF'S RETURN - NOT FOUND ", CASE NO: 2000-00573 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND UGI UTILITIES INC VS WOLAVER PLUMBING 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, DEFENDANT WOLAVER MARY but was unabl~ to locate Her in his bailiwick. He therefore returns the SUBPOENA , NOT FOUND , as to the within named DEFENDANT , WOLAVER MARY DEFT. IS BELEIVED TO BE DECEASED, RETURN NOT FOUND AS PER ATTY. Sheriff's Costs: Docketing Service Not Found Return Surcharge 18.00 9.92 5.00 10.00 .00 42.92 ~ . . Thomas llne _// Sheriff of Cumberland County KRZYWICKI & ASSOCIATES 11/22/2000 Sworn and subscribed to before me this :.3De day of 71J""~ ~1JlJV A.D. q;l' Q 'rM,gi, J )~ r thonotary =~-='=' " - "- 1__Yl'-",-,~" SHERIFF'S RETURN - REGULAR ; CASE NO: 2000-00573 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS WOLAVER PLUMBING HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsy1vania, who being duly sworn according to law, says, the within SUBPOENA TO PRODUCE was served upon WOLAVER CHARLES the DEFENDANT , at 0016:17 HOURS, on the 21st day of November, 2000 at 1 CENTER ST ENOLA, PA 17025 by handing to CHARLES WOLAVER a true and attested copy of SUBPOENA TO PRODUCE together with DOCUMENTS and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.92 .00 10.00 .00 37.92 So Answers: r~~A'~~ R. Thomas Kline 11/22/2000 KRZYWICKI & ASSOCIATES Sworn and Subscribed to before By: '7~U~ Deputy Sheri/V me this ..36t9' day of ~.~ A.D. Q,(-,- () fn..lb,.. ~- P othonotary I -~~ I...... : __~"~ ''''''i "'l;'~.;,.~ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION DOl Utilities Inc. Plaintiff ( ) Confessed Judgment (XX) Other vs. Jeffery Wolaver alk/a Jeff Wolaver Va Wolaver Plumbling Defendant File No.: 2000-573-CV Amount Due: $1553.54 Interest: $53.55 Atty's Comrn: Costs: $165.00 TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the a];lOv,e matterto the sheriff of Cumberland, County, for debt, interest and costs, upon the followingdescribedproperty'ofth~ iiefendant(s) All personal property of belonging to Jeffery W oraver alk/a Jeff Wolaver Va Wolaver Plumbing at One Center Street. Enola. PA. 17025 PRAECIPE FO~ ATTA~~NT EXECUTION Issue writ of attachmellt':to th~ Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment ligaiqst th;e above~named gamishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personality list) . And all other property of the defendant( s) in the possession, custody or control of the said gamishee(s). o (Indicate) Index this writ against the gamishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date: May 22, 2000 'Ifff~""" ,( ^ -, '1 ~. ~II--""""""""'-;mI_~I~""""~~~ -,:Jf-\ fi,#: ...at..... 6' r-- ~~ ~~ ~ & frY ~ ..... o -0 ..() f - " , "j'. "JM"lfi'n' , ... .t::~~ ~..o~~Ct? ., .. '7C~~O C' C' ". I () " , ~~ ~ ... ... a- ~ ~ :.. :. ~ .V-f o c: z = ""'(jc'er nl['n Z"T, zr~' (j) "t.-e, -<:2: ,<0 ~"r-, Z>< >c Z :< '" ."' C? o t: z r) ~n ~':'~ =] h" I-j -t ._--.() --_~~ :r~ ~~~ > :n -< 0'. '.' -,;j.. c.-->-J ,>> co --1,,1 ----"'""-""!><;,', SHERIFF'S RETURN - REGULAR CASE NO: 2000-00573 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS WOLAVER PLUMBING CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WOLAVER PLUMBING the DEFENDANT , at 0016:05 HOURS, on the 4th day of February, 2000 at 1 CENTER STREET ENOLA, PA 17025 by handing to CHRALES WOLAVER (FATHER) a true and attested copy of COMPLAINT & NOTICE together with IN ARBITRATION and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.92 .00 10.00 .00 37.92 sO;:7i2~~~t R. Thomas Kline Sworn and Subscribed to before 02/07/2000 ~,""::n;:;~ ~ Q Deputy S~l ~ me this .J. "t day of ~~ ,;l..rn.n.J A. D. 9r- a. /rid;,." +z, rothonotary - 1--'~_~I3<'"i.i", , In the Court of Common Pleas of Cumberland County, Pennsylvania UGI Utilities Inc. Plaintiff Civil Action - In Law No. 2000-573-CV vs. Jeffrey Wolaver a/k/a Jeff Wolaver t/a Wolaver Plumbing Defendants ARBITRATION AMENDED 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 rnoeney 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 .- '. ~' . l"!""''''''''-''<i"y~ In the Court of Common Pleas of Cumberland County, pennsylvania UGI utilities Inc. Plaintiff civil Action - In Law No. 2000-573-CV vs. Jeffery Wolaver a/k/a Jeff Wolaver t/a Wolaver Plumbing Defendants ARBITRATION AMENDED COMPLAINT 1. This is an action by plaintiff, UGI Utilities Inc. to recover damages from defendant arising out of damage to property owned by UGI Utilities Inc.. 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 225 Morgantown Road, Reading, PA 17602. 3. Defendant, Jeffrey Wolaver a/k/a Jeff Wolaver t/a Wolaver Plumbing , is a Pennsylvania sole proprietorship conducting business at One Center Street, Eno1a, PA 17025. " 1~_~11,~' COUNT 1 UGI Utilities Inc. vs. Jeffrey Wolaver a/k/a Jeff Wolaver t/a Wolaver Plumbing 4. 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 Plaintiff's Tariff presently on file with the Public Utility Commission. 5. Defendant did not comply with the Underground Utility Line Protection Law, Act 187 of 1996. 6. Defendant performed excavation work on April 2, 1998 at 15 Wertzvi11e Road, Enola, Pennsylvania. 7. Defendant did not request to identify the location of underground pipes through the Call One System. 8. Defendant did not exercise due care and did not take all reasonable steps to avoid damage or injury to property owned by UGI Utilities Inc.. 9. Defendant damaged a utility line owned by plaintiff. 10. Plaintiff made demand on defendant to repay the sums then due and owing to plaintiff, but defendant has refused and . I_~"" ~-"', ~ continues to refuse to pay plaintiff. 11. Plaintiff has been damaged in the amount of $1553.54 plus costs and attorneys fees. WHEREFORE, there is now due and owing from the defendant to the plaintiff the following sums: Amount Past Due: Attorney Fees: Court Costs: Service Costs: TOTAL $ 1,553.54 $ $ s $ 1,553.54 Respectfully submitted, Krzywicki and Associates By: DATED: March 15, 2000 tho o eshaminy Interplex PO Box 505 New Hope, PA 18938 609-397-9014 Attorney for Plaintiff Attorney I.D. 23754 . " , , ."'.- . ~' '0>i.I~ . . . VERIFICATION I, Cynthia E. Coffin, an employee ofUGI Utilities, Inc., being authorized to do so, verify that the statements made in the foregoing pleadings are true and correct to the best of my knowledge, information and belief. To the extent any averments therein are inconsistent in fact, I have been unable, after reasonable investigation, to ascertain which are true, but I have knowledge or information sufficient to form a beliefthat one of them is true. This statement is made subject to the penalties of 18 P.A. C.S. Section 4904, relating to unsworn falsification to authorities. UGI Utilities, Inc. Dated: :slrs-/oa BY: ~ PlJlJ"66lA/l Cyn . a E. Coffin 17'= .'..,.. r, ~"~".,, .'_ ' ., .,,,, ~'"",""~ " ~. =,=r.<_, _ ~=-'........"~ ~~ll!IIilb-' "'T.. ~" ~" ,. ~ '- ''''''ll!liIiiWir'~ , -'",,, ,,' ",' _0 ~"'-:'" ,~ - 0 0 <;f1 c: 0 :s:: :x '-'I ;:Rfg ". :r.; "T1 ::0 <'1_ Z:rJ "M ~~ -.I -nO Ot:' ~c:J -0 ~~ ~o :x 90 )>of! ~ 15m z N ~. =<! f<o.> -< !1Z ~~~ I,' , . 1- 'i"~,"?'~K In the Court of Common Pleas of Cumberland County, pennsylvania UGI Utilities Inc. Plaintiff civil Action - In No. ~OOO- .t:'t.3 vs. Wolaver Plumbing Defendants 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 I 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 moeney 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 Law Ci<.>~l't~ ". - , .1 .. 1- ~"""'>lO~.-,--' , In the Court of Common Pleas of Cumberland County, Pennsylvania UGI Utilities Inc. Plaintiff Civil Action - In Law No. dtrrrV.5''73 ~ ~ vs. Wolaver Plumbing Defendants ARBITRATION COMPLAINT 1. This is an action by plaintiff, UGI Utilities Inc. to recover damages from defendant arising out of damage to property owned by UGI Utilities Inc.. 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 225 Morgantown Road, Reading, PA 17602. 3. Defendant, Wolaver Plumbing is an Pennsylvania Company conducting business at One Center Street, Eno1a, PA 17025. ~~~"- 1- ~'>1'" ,. COUNT 1 UGI Utilities Inc. vs. Wolaver Plumbing 4. 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 Plaintiff's Tariff presently on file with the Public Utility Commission. 5. Defendant did not comply with the Underground Utility Line Protection Law, Act 187 of 1996. 6. Defendant performed excavation work on April 2, 1998 at 15 Wertzville Road, Enola, PA. 7. Defendant did not request to identify the location of underground pipes through the Call One System. 8. Defendant did not exercise due care and did not take all reasonable steps to avoid damage or injury to property owned by UGI Utilities Inc.. 9. Defendant damaged a utility line owned by plaintiff. 10. Plaintiff made demand on defendant to repay the sums then due and owing to plaintiff, but defendant has refused and continues to refuse to pay plaintiff. ,__ ~ ~c I ' ~"~~"'_I*'.'__1 , 11. Plaintiff has been damaged in the amount of $1470.12 plus costs and attorneys fees. WHEREFORE, there is now due and owing from the defendant to the plaintiff the following sums: Amount Past Due: Court Costs: Service Costs: TOTAL $ 1,470.12 $ $ $ 1,470.12 Respectfully submitted, Krzywicki and Associates hony P. Krzywicki e Ne . Interp1ex ox 505 New Hope, PA 609-397-9014 Attorney for Plaintiff Attorney I.D. 23754 DATED: January 24, 2000 By: , " ~- _I _~R,e5;I,,_e/:'-;, , ,? VERIFICATION I, Cynthia E. Coffin, an employee ofUGI Utilities, Inc., being authorized to do so, verify that the statements made in the foregoing pleadings are true and correct to the best of my knowledge, information and belief. To the extent any averments therein are inconsistent in fact, I have been unable, after reasonable investigation, to ascertain which are true, but I have knowledge or information sufficient to form a belief that one of them is true. This statement is made subject to the penalties of 18 P.A. C.S. Section 4904, relating to unsworn falsification to authorities. UGI Utilities, Inc. Dated: '/l'l/oq BY: ~~~~ Cyn 'a E. Coffin ilil '""" , ~, .~- "--'iii ';1~!!IIIll;g~lIlr " -~"~~~f;""'",""" " ~ '""9.. () <:::> 0 ~ ''It c 0 ..,-, ~ ). :s: ..." ".:'1 vee- r" riifR ~ mrr: co . . 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