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Home My WebLink About00-04946 ':'!'~ l030U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utlllties Inc. Plaintiff vs civil Action - In Law No. OC-.II9Jlk C',o'll y~ Belema O. Dikibo Defendant Lolia L. Hunter 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 entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to t~e 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 claiJ 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 - ~"iLW ,~ l030U2 In the Court of Common Pleas of CUMBERLAND County, pennsylvania UGI Utllltles Inc. Plaintiff Civil Action - In Law vs No. IYO - L/ q '1<, Ci;J. I ~ Belema O. Dikibo Defendant Lolia L. Hunter Defendant ,\ \'" \'" \ \ \'" \ \ \ \ \ \ \ \" \ \ \ \ \ \ \ \ \ \ ARBITRATION COMPLAINT 1. This is an action by Plaintiff, UGI Utilities Inc. to recover damages from Defendants arising out of a debt Defendants owe to Plaintiff by virtue of utility service. 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 19612-3009. 3. Defendant, Belema O. Dikibo, is an adult individual residing at 42 Altoona Avenue, Enola, PA 17025. " ~. '~T~~'~' ~,~ ~ ~' 4. Defendant, Lolia L. Hunter, is an adult individual residing at 42 Altoona Avenue, Enola, PA 17025. COUNT 1 UGI Utilltles Inc. vs. Belema O. Dikibo and Lolia L. Hunter 5. At all time 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. 6. plaintiff supplied utility service to Belema O. Dikibo and Lolia L. Hunter. 7. At the present time, Defendants account is in default and have outstanding balance due and owing Plaintiff as reflected on the attached Statement of Accounts which contains information taken directly from Plaintiff's original business records, and which includes the unpaid balance and all appropriate debits, and credits, and late charges and which is attached hereto and marked Exhibit "A", incorporated herein by reference and made a part hereof. -", " "['I'.J:j":.f.j, l030U2 8. The utility service which was provided by the Plaintiff to the Defendants aforesaid, was received, accepted, and utilized for the benefit of said Defendants. Each in ordering and accepting service was acting individually and as agent for one another 9. Defendants are in default of their obligation, having failed to make the payments as they became due. 10. Plaintiff made demand on Defendants to repay the sums then due and owing to Plaintiff, but Defendants have refused and continue to refuse to pay Plaintiff. 11. Despite demands upon Defendants for payment by the Plaintiff, Defendants have failed and refused to pay Plaintiff the balance due and owing on said account(s). 12. Defendant has been unjustly enriched by accepting service without full payment. WHEREFORE, there is now due and owing from the Defendants to the Plaintiff the following sums for which Plaintiff demands judgment, jointly and severally, against the Defendants: ~- ,'- =~ Amount Past Due: Court Costs: Service Costs: TOTAL $ 2721.48 $ 45.50 $ 100.00 $ 2866.98 Respectfully submitted, Krzywicki and Associates DATED: April 25, 2000 By: Antho 1 Nes a y Interplex P.o. Box 505 New Hope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 ".~'i l030U2 -. ~ -=~" - '= ";;", 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 I 8 P.A. C.S. Section 4904, relating to unsworn falsification to authorities. UGI Utilities, Inc. Dated: "1/24 /(J() BY: &1iIk m~ Cynt a E. Coffin .. .~ .' ."( . . 1030U2 STATEMENT OF ACCOUNT Belema O. Dikibo and Lolia L. Hunter established the following accounts with UGI utilities Inc. with the following balances and charges: Account Number / Service Address Acct Type Service to: Balance -------------------------------------------------------------------------------- -------------------------------------------------------------------------------- 207-355-5995-99 G 36 N. 20th Street Harrisburg, PA 17103 / / $2721. 48 Total Delinquent Balance: $2721.48 EXHIBIT ~1lii.'.i.iisbl.~~,i"'<iii,"{"",,~,';"-~illj,~!!@l~~-liIk~!Ii!I~_1IlI';..,~"m);.'id~>'!'--,*,,,,;,,-,,,',~-h\""'~'+$fu<JIb-",~:!iM\<-"","",,~~~~"-=~~._' ,"', ~ "',""'"~ "<) ~ ~ ,c~ _", ,_"" =C",,^',,",",,"',',. , ,__ "','C.' " ,,','~" _ ,I .__v> ~ {?\b...t ~ 1.... <<1\ fr'\ () . . . ~ 9 q B ~ ~~ J ,,' < ~' lll;,~~~M'!~,i o C) c c::> ::::. c_ -0 ~~r) ? ll~) ~ '";:;- ..--:>" Z;\:] ..-:;( I ~?C . ;Z :;:..; -< ~! f'().... -~ ~-..) , R~ (Y C. !1.: ; ~' ',...~,' ~, -"j-"-" 7i;(~; __._-n .~~; (~ tI'n "f1 :< '1? '.J'l . . ~ r , . ... ~,,~~""'" "k~ " "~~ ~'~~ ~ " ii, --", ~' ,- ., <, "l~,...~,,~: SHERIFF'S RETURN - OUT OF COUNTY ~ASE NO: 2000-04946 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS DIKIBO BELEMA ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: DIKIBO BELEMA 0 but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT & NOTICE ARBITR On August 18th , 2000 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing SERVICE Surcharge OUT OF COUNTY DEP. DAUPHIN CO 18.00 9.30 10.00 9.00 31.50 77.80 08/18/2000 KRZYWICKI & ~ "Thomas Kline Sheriff of Cumberland County ASSOCIATES Sworn and subscribed to before me this 30 P day of ~ ~ A.D. n (l~, ~ ~ prothonotar~ ~ '~lI"li=''''' ~ .-- -oJ ~ ,_. ~ ,_ . ,& ..~;m"t_ " ~ ,~ '1Ml., SHERIFF'S RETURN - OUT OF COUNTY ~ASE NO: 2000-04946 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS DIKIBO BELEMA ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: HUNTER LOLIA L but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT & NOTICE ARBITR On Auqust 18th , 2000 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 08/18/2000 KRZYWICKI & ASSOCIATES ~r~ . Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this 1w go~ day of ~ .2b-tn:> A. D. ~. Q, nuip..... ~ Prothonotaryl ,~';." ~"1 " "" " , "~ - ~ ~ , Ji:_ -''"1';"' @ffite of tltt ~4t~iff William T. Tully Solicitor Ralph G. McAllister Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Hanisburg, Pennsylvania 17l 0 I ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania UGI UTILITIES vs County of Dauphin DIKIBO BELEMA 0 Sheriff's Return No. 1626-T - -2000 OTHER COUNTY NO. 00-4946 I, Jack Lotwi::k, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for DIKIBO BELEMA 0 the DEFENDANT named in the within COMPLAINT and that I am unable to find him(her in the County of Dauphin, and therefore return same NOT FOUND, August 15, 2000 NEED A BETTER ADDRESS, NO ODD NUMBERS IN THIS BLOCK Sworn and subscribed to So Answers, Jf~ = '"" ,,~,y~=oo PROTHONOTARY before Sheriff of Dauphin County, Pa. By Deputy Sheriff Sheriff's Costs: $31.50 PD 07(25(2000 RCPT NO 139258 HOPKINS , """""~-- ~.".~. - ~ "..., ,<. ,,~,",.~- - '"""~..-.. @ffitt of tlr:e ~4:e:riff William T. Tully Solicitor Ralph G. McAllister Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assis11mt Chief Deputy Dauphin County Harrisburg, Pennsylvania 171 0 I ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania UGI UTILITIES vs County of Dauphin DIKIBO BELEMA 0 Sheriff's Return No. 1626-T - -2000 OTHER COUNTY NO. 00-4946 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for HUNTER LOLIA L the DEFENDANT named in the within COMPLAINT and that I am unable to find him(her in the County of Dauphin, and therefore return same NOT FOUND, August 15, 2000 EXPIRED BEFORE DEFENDANT COULD BE FOUND. C!.-. f ~ So Answers, Jf~ Sworn and subscribed to before me this 15TH day AUGUST, 2000 Sheriff of Dauphin County, Pa. PROTHONOTARY By Deputy Sheriff Sheriff's Costs: $31.50 PD 07/25/2000 RCPT NO 139258 HOPKINS " .":" < ~ In The Court of Common Pleas of Cumberland County, Pennsylvania UGr Utilities, Inc. VS. Belema O. Dikibo, et. al. Serve: Belema O. Dikibo No. 20-4946 Civil Now, 7/17/00 , 20 C (j , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin County to exe.cute this Writ, this deputation being made at the request and risk of the Plaintiff. , ' r~~~'~ Sheriff of Cumberland County, P A Affidavit of Service Now, , 20_, at o'clock M. served the within upon at by handing to a copy ofthe original and made Imown to the contents thereof So answers, Sheriff of County, PA Sworn and subscribed before me this _ day of 20 '- COSTS SERVICE MILEAGE AFFIDA VIT $ $ "'~ ~'~M.: In The Court of Common Pleas of Cumberland County, Penn.sylvania UGI Utilities, Inc.. VS. Belema O. Dikibo t 1 , e . a . Serve: Lolio L. Hunter No. 20-4946 Civil Now, 7/17/00 , 20 0 tJ , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputatIOn being made at the request and risk oft~~ ~t Sheriff of Cumberland County, PA Affidavit of Service Now, , 20_, at o'clock M. served the within upon at by handing to a copy ofthe original and made lmown to the contents thereof So answers, Sheriff of County, FA Sworn and subscribed before methis_dayof ,20_ COSTS SERVICE MILEAGE AFFIDA VIT $ $ - --:j l030U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utllltles Inc. Plaintiff civil Action - In Law vs No. 00 -- Lfq~<.. c.'o;e L~ Belema O. Dikibo Defendant Lolia L. Hunter Defendant ARBITRATION \ \ \ \ \, \ \ \ \ \ \ \""" \ \ \ \ \ \, \ \ \ \ \ \ \ \" COMPLAINT NOTICE You have been sueu 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 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. ;1' 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 I ~ .., 'IiIIi YI!IIIIHtN II A" AND COPY, TRUE COpy FROM RECORD In TestlmonYWflllftlllf, IhareuntoS8t my hand andthe~, Of,~, .~"ca,rl,isIe,,"' Pa; "- ~"~D_~'" ',.,_. ~~u ry '~ l030U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI UtLlitLes Inc. Plaintiff Civil Action - In Law vs No. Belema O. Dikibo Defendant ARBITRATION Lolia L. Hunter Defendant \ \ \ \ \ \, \ \ \ \ \, \" \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ ~ COMPLAINT 1. This is an action by Plaintiff, UGI Utilities Inc. to recover damages from Defendants arising out of a debt Defendants owe to Plaintiff by virtue of utility service. 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 19612-3009. 3. Defendant, Belema O. Dikibo, is an adult individual residing at 42 Altoona Avenue, Enola, PA 17025. r ~. " '.Iii 'a '~~: 4. Defendant, Lolia L. Hunter, is an adult individual residing at 42 Altoona Avenue, Enola, PA 17025. COUNT 1 UGI Utilities Inc. vs. Belema O. Dikibo and Lolia L. Hunter 5. At all time 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. 6. Plaintiff supplied utility service to Belema O. Dikibo and Lolia L. Hunter. 7. At the present time, Defendants account is in default and have outstanding balance due and owing Plaintiff as reflected on the attached Statement of Accounts which contains information taken directly from Plaintiff's original business records, and which includes the unpaid balance and all appropriate debits, and credits, and late charges and which is attached hereto and marked Exhibit nAn, incorporated herein by reference and made a part hereof. . -. l03QU2 8. The utility service which was provided by the Plaintiff to the Defendants aforesaid, was received, accepted, and utilized for the benefit of said Defendants. Each in ordering and accepting service was acting individually and as agent for one another 9. Defendants are in default of their obligation, having failed to make the payments as they became due. 10. Plaintiff made demand on Defendants to repay the sums then due and owing to Plaintiff, but Defendants have refused and continue to refuse to pay Plaintiff. 11. Despite demands upon Defendants for payment by the Plaintiff, Defendants have failed and refused to pay Plaintiff the balance due and owing on said account(s). 12. Defendant has been unjustly enriched by accepting service without full payment. WHEREFORE, there is now due and owing from the Defendants to the Plaintiff the following sums for which plaintiff demands judgment, jointly and severally, against the Defendants: ,,~<" .,~- Amount Past Due: Court Costs: Service Costs: TOTAL $ 2721.48 $ 45.50 $ 100.00 $ 2866.98 Respectfully submitted, Krzywicki and Associates DATED: April 25, 2000 By: Anthony P. KrzYWlckl 1 Neshaminy Interplex P.O. Box 505 New Hope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 ~,<,~"." . """'1. l030U2 J~" ~'^ ,,~ , . 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: 4/24/00 BY: ~ ~~~ Cyn la E. Coffin -g<~~" - ,~, .....Ol..ill'~' ~.~-,,~~. ~ ". ~ "'-l':: . , l030U2 STATEMENT OF ACCOUNT Belema O. Dikibo and Lolia L. Hunter established the following accounts with UGI Utilities Inc. with the following balances and charges: Account Number / Service Address Acct Type Service to: Balance ================================================================================ 207-355-5995-99 G 36 N. 20th Street Harrisburg, PA 17103 / / $2721.48 Total Delinquent Balance: $2721.48 EXHIBIT ill ~ ~ diS ~ Off!Ci"'F '''", i;"~.",""" OVH," "''''I<rr liJHf'r' JUl 13 ;,1 ""'11'1 - J.:. f;d @'R) ~ ~ rDCC:.>,"; ,',: \ \.. - :'~ / Lv ,qj'-; ;,,\ '1 \ \ \ \ \ ~ , r j ~ '~, ~-,.-~,..~,,!. _, !1ff!il-'iJ~~~ili'\1lllI'IlI'~~. .. .~~~~~,~"~~I\It~~~o1fflliiif;j'r~mw;#l5!_}I\f-~\ll~~~ ~ ~ . - '--, if , 1030U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilitles Inc. Plaintiff vs Civil Action - In Law No. 00 - .l.(q~", (Zt~~l T~ Belema O. Dikibo Defendant Lolia L. Hunter Defendant ARBITRATION \ \ \ \ \ \ \ \ \ \ 111 \, \ "'" """'" 111 1 11 COMPLAINT NOTiCE You have been sued in court. If you wish co 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 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 I C!"fr!\?'f l'!lIII!l1 _ WJ!\HN IS A ll!l"JII AND rxHY. TRUE COpy FAOMRECORD In TestImOny whereof,l here unto SIlt my hand and the., ' of:m~~, lisle_u~~"'L ~ ~~DJ~t:=_.~I)~ .'u ...~~ .. ~ ",". 1"'~f, l030U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff Civil Action - In Law vs No. Belema O. Dikibo Defendant Lolia L. Hunter Defendant \ \ \ \ \ \ \ \ \ \ \ \ \ \ \"""""" \ \""'" ARBITRATION COMPLAINT 1. This is an action by Plaintiff, UGI Utilities Inc. to recover damages from Defendants arising out of a debt Defendants owe to Plaintiff by virtue of utility service. 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 19612-3009. 3. Defendant, Belema O. Dikibo, is an adult individual residing at 42 Altoona Avenue, Enola, PA 17025. ~ ~, ,~ - .' <;.g ~;;; 4. Defendant, Lolia L. Hunter, is an adult individual residing at 42 Altoona Avenue, Enola, PA 17025. COUNT 1 UGI Utilities Inc. vs. Belema O. Dikibo and Lolia L. Hunter 5. At all time 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. 6. Plaintiff supplied utility service to Belema O. Dikibo and Lolia L. Hunter. 7. At the present time, Defendants account is in default and have outstanding balance due and owing Plaintiff as reflected on the attached Statement of Accounts which contains information taken directly from Plaintiff's original business records, and which includes the unpaid balance and all appropriate debits, and credits, and late charges and which is attached hereto and marked Exhibit "A", incorporated herein by reference and made a part hereof. o ~ " " WM ~ 1030U2 8. The utility service which was provided by the Plaintiff to the Defendants aforesaid, was received, accepted, and utilized for the benefit of said Defendants. Each in ordering and accepting service was acting individually and as agent for one another 9. Defendants are in default of their obligation, having failed to make the payments as they became due. 10. Plaintiff made demand on Defendants to repay the sums then due and owing to Plaintiff, but Defendants have refused and continue to refuse to pay Plaintiff. 11. Despite demands upon Defendants for payment by the Plaintiff, Defendants have failed and refused to pay Plaintiff the balance due and owing on said account(s). 12. Defendant has been unjustly enriched by accepting service without full payment. WHEREFORE, there is now due and owing from the Defendants to the plaintiff the following sums for which plaintiff demands judgment, jointly and severally, against the Defendants: ..~ " " .. Amount Past Due: Court Costs: Service Costs: TOTAL $ 2721.48 $ 45.50 $ 100.00 $ 2866.98 Respectfully submitted, Krzywicki and Associates DATED: April 25, 2000 By: Anthony P. Krzyw~cki 1 Neshaminy Interplex P.O. Box 505 New Hope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 ":',' 1030U2 "~'~~~ ",~ ~, -~ . ~--~ ~ ~,.. ..w ~~' _Ll - Wt: 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: .::; /24/cc BY: ~ ~8--fr~ Cyn la E. Coffin - ~~ ~ . l030U2 STATEMENT OF ACCOUNT Belema O. Dikibo and Lolia L. Hunter established the following accounts with UGI utilities Inc. with the following balances and charges: Account Number / Service Address Acct Type Service to: Balance -------------------------------------------------------------------------------- -------------------------------------------------------------------------------- 207-355-5995-99 G 36 N. 20th Street Harrisburg, PA 17103 / / $2721.48 Total Delinquent Balance: $2721.48 EXHIBIT '~ ~ ~ ~"'" "~ I, ' 1- r ~ .1 '~'i ~ ,-' -,!, I; [."[ I'i \.' I'!, J '-l <:. ~ .,iln:')-~11!1l'11!!!IiIll!llJ!li~ll!l!liR!lW'Ii'j; _~,J ~"""'!l'I'~"""'~W1~._" OFFrCE JF T~"r: CUF"-' JUl rz -. ::;i-i~R!FF . ':I'HY 4 12 fl 'OJ PEC,'IH /1",' '.' ',\ ,I; \) , _. F-, "L-\ t"; -~ " - ~~"'-~*~~~',"',",I~"JO""',,!iqil'~'iJ'f.!II11!:~II!lfilI"!lffl:ll!lQ'l,",_ "",I*,"fijjlif!'i~rlilHf~1WI\1Il h " "h'~'__ @IV ~ ~ WVil "ll.gl!fJw.: ~b';'.,_\: l030U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff Civil Action - In Law vs No. 00-04946 Belema O. Dikibo Defendant Lolia L. Hunter Defendant \ \ \'" \' \ \ \, \ \ \ \" \"" \ \, \ \ \ \" \'" ARBITRATION PRAECIPE TO REINSTATE COMPLAINT To the Prothonotary: Kindly reinstate the Complaint in the above-captioned Civil Action for an additional thirty days. Krzywicki DATED: September 25, 2000 By: Ant 0 1 Ne P.O Ne e, PA 18938 80 -296-2103 Attorney for Plaintiff Attorney I.D. 23754 .,,~ " '-"':"'-~~-I ~~~ ~11II'.liJlbaili!M$~iJliJ;Hj,illiJi!li~~I~'"- ,~ ^ - . iIIiimilli_liJ -. .~iWIl1lllil.Mll!!.iilllltiil:l .....,;.-~..."""'"",._- .' (") C') (~.. c: 0 .- =' r.e;-., ~ -ceo c:') '-~'l rn"r;", ~",~': I~ ,~ Z :n 2~C '_J '''\" ~::( () r- c.; '. ..,\ ~() ,~, -1" ....:.;.,. " ~C.') oi T'~ ",,;:>-;;;:;; '..'-' --\ "'- ::> 'J;.. =< ::g C) -, ~.," ~ '".~ , 'I ~.L"~ ; ...."~. ~k '"~ t ~'~I;;'". i SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2000-04946 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ". UGI UTILITIES INC VS DIKIBO BELEMA ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: DIKIBO BELEMA 0 but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT & NOTICE REINST On December 21st , 2000 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge DEP. DAUPHIN CO 18.00 9.00 10.00 31.50 .00 68.50 12/21/2000 KRZYWICKI & c~ R. homas Kline Sheriff of Cumberland County ASSOCIATES Sworn and subscribed to before me this 3M-.. day of qw"",,; ;lirV I A.D. (~(1~~' prothonotar 'Ild'~ ' -" "'"" '"' ,LjJ:iol. ~ ~ ~. " - n '- SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2000-04946 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS DIKIBO BELEMA ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: HUNTER LOLIA L but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT & NOTICE REINST On December 21st , 2000 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 12/21/2000 KRZYWICKI & ~~ R. Thomas Kline Sheriff of Cumberland County ASSOCIATES Sworn and subscribed to before me this 3M day Of~ .2Q A.D. i!..R.--(2~ '1 Prothonotary . 'i-~ I I I I I ~ I I " 'I Ii I II I i @ffitt of tIre ~4c:riff Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Ralph G. McAllister Chief Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, peunsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania UGI UTILITIES vs County of Dauphin DIKI80 BELEMA 0 Sheriff's Return No. 2698-T - -2000 OTHER COUNTY NO. 00-4946 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for HUNTER LOLIA the DEFENDANT named in the within REINSTATED COMPLAINT and that I am unable to find him/her in the county of Dauphin, and therefore return same NOT FOUND, December 12, 2000 UNABLE TO FIND DEFENDANT HOME. EXPIRED C!-. ~~) PROTHONOTARY So Answers, JR~ Sworn and subscribed to before me this 12TH day of DECEMBER, 2000 Sheriff of Dauphin county, Pa. By Deputy Sheriff Sheriff's Costs: $31.50 PD 12/06/2000 RCPT NO 144120 ~ '- " '~ ,.'.- -.';., @ffite of tlr~ ~4~:riff William T. Tully Solicitor Ralph G. McAllister Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant ChiefDepuly Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff """ Commonwealth of Pennsylvania UGI UTILITIES vs County of Dauphin DIKIBO BELEMA 0 Sheriff's Return No. 2698-T - -2000 OTHER COUNTY NO. 00-4946 . ., .~. I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for DIKIBO BELEMA 0 the DEFENDANT named in the within REINSTATED COMPLAINT and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, December 12, 2000 1825 CHESTNUT ST., HBG ADDRESS DOES NOT EXIST. NEED A BETTER ADDRESS FOR DEFENDANT. ~.~~ So Answers, JR~ Sworn and subscribed to before me this 12TH day of DECEMBER, 2000 Sheriff of Dauphin County, Pa. PROTHONOTARY By Deputy Sheriff Sheriff's Costs: $31.50 PD 12/06/2000 RCPT NO 144120 - -., - -Wi} In Th~ 'Court of Common Pleas of Cumberland County, Pennsylvania 'UGI Utilities, Inc. VS. Belema o. Dikibo, et. al. Serve, BeIema O. Dikibo No. 20-4946 Civil Now 11/71/00 , , 20 10 IQ , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauohin County to execute this Writ, this deputation being made at the request and risk ofthe Plaintiff. .' rJ76~m~~t Sheriff ofCumberlan,d County, P A Affidavit of Service Now, , 20_, at o'clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof So answers, Sberiff of County, PA Sworn and subscribed before me this _ day of 20 '- COSTS SERV1CE MILEAGE AFFIDAVIT ' $ $ - ::... I~ Th.e'Court of Common Pleas of Cumberland County, Pennsylvania UGI Utilities, Inc. VS. Belema O. Dikiba, et. al. Serve: Lalia L. Hunter N 20-4946 Civil o. Now, 11/21/00 , 200 () , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Pla.intiff., ,,/':A/t '. " r~~' Sheriff of Cumberland County, PA Affidavit of Service Now, ,20_, at o'clock M. served the within upon at by handing to a copy ofthe original and made lmown to the contents thereof. So answers, Sheriff of County, PA 20 '- COSTS SERVICE MILEAGE AFFIDA VIT $ Sworn and subscribed before me this _ day of $ - ",1;; l030U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilitles Inc. Plaintiff vs Civil Action - In Law No. 00- 4'141::. G~~L '-T~ Belema O. Dikibo Defendant Lolia L. Hunter 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 entering a written appearance personally or by attorney and filing in writing with the court your defenses or abjections 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 , J Q7;I~ \'L~\'b' _ ~N IS A 'K:;;!!! , 'KT COpY. Rlln!! ECOPY FROM RECORD to Testimony whereof," hereunto set my hand ... ... ... . 'ald~ """", . Pa. This ~~ day p1"1 , ~ "- a /'),1. ~r;: othonotary C', - - -~--. ~ "'~lIMIhi~ .:-- ' l030U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilltles Inc. Plaintiff vs Civil Action - In Law No. Co - (:JLNLJ& GuJT~ Belema O. Dikibo Defendant Lolia L. Hunter Defendant \ \ \ \ \ \ \"""""""", \""""'" ARBITRATION C) c:=;. ..-, -:;~ ~~ ~: COMPLAINT ,(', I , ,'- J' z~' 'c :::-?::: L '., 1. This is an action by Plaintiff, UGI Utilities ~~.c:' ,,- ,.~~ to recover damages from Defendants arising out of a debt: Defendants :::.-1, _ - _ u, owe to Plaintiff by virtue of utility service. L ~;, : ~.) 2. UGI Utilities Inc. is a pennsylvania corporation duly organized and existing and licensed to do business FS a public utility under the laws of the Commonwealth of Pennsylvania with a principal place of business at 225 Morgantown Road,." Reading, PA 19612-3009. \ 3. Defendant, Belema 0, Dikibo, is an adult individual residing at 42 Altoona Avenue, Enola, PA 17025. " L "'- ,"0--- . . -~ ~ "c, , . -"" 4. Defendant, Lolia L. Hunter, is an adult individual residing at 42 Altoona Avenue, Enola, PA 17025. COUNT 1 UGI Utillties Inc. vs. Belema O. Dikibo and Lolia L. Hunter 5. At all time 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. 6. Plaintiff supplied utility service to Belema O. Dikibo and Lolia L, Hunter. 7. At the present time, Defendants account is in default and have outstanding balance due and owing Plaintiff as reflected on the attached Statement of Accounts which contains information taken directly from Plaintiff's original business records, and which includes the unpaid balance and all appropriate debits, and credits, and late charges and which is attached hereto and marked Exhibit "A", incorporated herein by reference and made a part hereof. , e - ~; " rii-'", l030U2 8. The utility service which was provided by the Plaintiff to the Defendants aforesaid, was received, accepted, and utilized for the benefit of said Defendants. Each in ordering and accepting service was acting individually and as agent for one another 9. Defendants are in default of their obligation, having failed to make the payments as they became due. 10. Plaintiff made demand on Defendants to repay the sums then due and owing to Plaintiff, but Defendants have refused and continue to refuse to pay Plaintiff. 11. Despite demands upon Defendants for payment by the Plaintiff, Defendants have failed and refused to pay Plaintiff the balance due and owing on said account(s). 12. Defendant has been unjustly enriched by accepting service without full payment. WHEREFORE, there is now due and owing from the Defendants to the Plaintiff the following sums for which Plaintiff demands judgment, jointly and severally, against the Defendants: - ~ , , ~, ~.......", - '[ -,;; 1030U2 Amount Past Due: Court Costs: Service Costs: TOTAL $ 2721.48 $ 45.50 $ 100.00 $ 2866.98 Respectfully submitted, Krzywicki and Associates DATED: April 25, 2000 By: Anthony P. Krzywicki 1 Neshaminy Interplex P.O. Box 505 New Hope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 , . ~. ~" '~', ; ',i VERIFICA TIO)\, 1. Cynthia E. Coffin. an emplo; ce ofUGI Ctilities. Inc.. being <:tllthcorizcd [0 do so. verify that the statements made in the foregoing pleadings <:tre true and COlTect to the best of my knowledge. information and belief. To the extent <:tny 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 ,me ,,[ them is true. This statement is made subject to the penalties of 18 P.A C.S. Section -+90-+. relating to unsworn falsitication to authorities. lGI ltilities. Inc. . Dated: i /2.1 CC BY 6/"'A1.IY1.L c; ~ftN Cynthia E. Coffin ~ - r.__ -,- -,-- '''1 I I I I ;1 . l030U2 STATEMENT ,OF ACCOUNT Belema O. Dikibo and Lolia L. Hunter established the following accounts with UGI Utilities Inc. with the following balances and charges: Account Number / Service Address Acct Type Service to: Balance =~~=~=======~~~~~~~~~~~~======================================================== 207-355-5995-99 G 36 N. 20th Street Harrisburg, PA 17103 / / $2721.48 Total Delinquent Balance: $2721.48 EXHIBIT <A" , J ~. ;~~;,;:' . . 'II ,~~~! _......'"~.-, ',J"'I,r'-, ~~:; ~ ,ie-=-' ~...."~: ,\,~~ ~-- ~ ,~=- '!lIJlII'II!II , __"_VJ!,T{II'l"._ C1'O:: I ('-I II t'" J.I"",! ~u , T'! '-'j ., v @/V CiVil ~ ~ IiVi " . MijN!let');lI~l!f J~;!l!j:,f~H;"~1-~""-~""o;'{:~"~'!!~f;_,",'N';;!'i!jf!8~jji"~"Wl!!~j!.~r~F!ij!\JII'Jjl1>!Jml!'if";,,,,-"""f,;q>ryI"'1_;(101,,~~~ -~ ",' ~"'~ ~.".,- 5_ """,-,-,,-, . ~, j l030U2 Amount Past Due: Court Costs: Service Costs: TOTAL $ 2721.48 $ 45.50 $ 100.00 $ 2866.98 Respectfully submitted, Krzywicki and Associates DATED: April 25, 2000 By: Anthony P. Krzywickl 1 Neshaminy Interplex P.O. Box 505 New Hope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 " J' .. VERIFICA no!\ L Cynthia E. Coffin. an employee ofUGI Ltilities. lnc.. being amhorized [0 do so, verify that the statements made in the foregoing pleadings are true and cOlTect 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 informatioll sufficient to form a belief that one 0 f them is true. This statement is made subject to the penalties of 18 P.A. C.S. Section -IQI!4. relating to unsworn falsitic:nion to authorities. CGI Uilities. Inc. Dated: -1 j24/cc i 'I-- r /1_ ' BY (...-~1 11Th '- r- v r,h/'/' Cynthia E. Coffin U . " .,~~~~ ,...:"<;~: l030U2 STATEMENT OF ACCOUNT Account Number / Service Address Acct Type Service to: Balance 1 :1 .1 Belema O. Dikibo and Lolia L. Hunter established the following accounts with UGI Utilities Inc. with the following balances and charges: -------------------------------------------------------------------------------- -------------------------------------------------------------------------------- 207-355-5995-99 G 36 N. 20th Street Harrisburg, PA 17103 / / $2721,48 ,'I i'l 'I -~j II II ".! 11' ::i: , Total Delinquent Balance: $2721.48 1 I ,I Ii , I EXHIB;; A '. ~ ." '"', 1f!1!1I!I~U!llllQ!!!.,._ J'~ ~ ~. , - ",-," ^"V < " r:' ". -'. '-f i,C".; "'~ _ ~;^~_ ",",1dff;,.'''' -,' ',-~"~---,,-,-, ~ -~,'- ,-"ii'I ~ fii:i:li ~ ces , lFii=il ~ , ~""'I',~~'~."..,,,it>J:, ~ __~.'" -. ~!!'~<f(j~~#~"'J11''!,!,%I''~fIllIli'?f. _ " IT':Wlfi~JG-}I!I,,~iM-,_ '_ -r- ~~f - "J ,; ~ . 1030U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utlllties Inc. Plaintiff vs Civil Action - In Law No. 06-494(", e~("(~~ Belema 0, Dikibo Defendant Lolia L. Hunter 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 eneering 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 I ....'t<"IlY?( _~_ ...,.. ;;:2:- '~f r FI ___ ',(", _Vl.-;... " TRUe:COPV.FROM RECORD In TeGtimony 1'i118r001, I Ililra unto set my hand afld tt..e 51' lllf said Coort al Carlisle. Pa. TlIIs day . ' .."--~ ~ ~, li- -:- . l030U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utllitles Inc. Plaintiff vs Civil Action - In Law No. 00 - tJY'il1& GuJ't~ Belema O. Dikibo Defendant Lolia L. Hunter ARBITRATION Defendant . \ \ \ \"'" \ \ \ \ \ \""" \ \, \ \ \ \ \ \ \ \, \ \, I o co s.; 0 -:-~ ~~ -, <--- ~2S-: 1- zr 1. This is an action by Plaintiff, UGI Utilities :(n~. ,,' ~::::\_- . , to recover damages from Defendants arising out of a debt~'Defendants =1, _" - _,_' COMPLAINT owe to Plaintiff by virtue of utility service. z -' -<' :;"'"; r,) 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 19612-3009. 3. Defendant, Belema O. Dikibo, is an adult individual residing at 42 Altoona Avenue, Enola, PA 17025. , L ~t,' . 4. Defendant, Lolia L. Hunter, is an adult individual residing at 42 Altoona Avenue, Enola, PA 17025. COUNT 1 UGI Utilitles Inc. vs. Belema O. Dikibo and Lolia L. Hunter 5. At all time 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. 6. Plaintiff supplied utility service to Belema O. Dikibo and Lolia L. Hunter. 7. At the present time, Defendants account is in default and have outstanding balance due and owing Plaintiff as reflected on the attached Statement of Accounts which contains information taken directly from Plaintiff's original business records, and which includes the unpaid balance and all appropriate debits, and credits, and late charges and which is attached hereto and marked Exhibit "A", incorporated herein by reference and made a part hereof. " - ~~~ "--, I -'~ , 1030U2 8. The utility service which was provided by the Plaintiff to the Defendants aforesaid, was received, accepted, and utilized for the benefit of said Defendants. Each in ordering and accepting service was acting individually and as agent for one another 9. Defendants are in default of their obligation, having failed to make the payments as they became due. 10. Plaintiff made demand on Defendants to repay the sums then due and owing to Plaintiff, but Defendants have refused and continue to refuse to pay Plaintiff. t1 II 11. Despite demands upon Defendants for payment by the Plaintiff, Defendants have failed and refused to pay Plaintiff the balance due and owing on said account(s). 12. Defendant has been unjustly enriched by accepting service without full payment. WHEREFORE, there is now due and owing from the Defendants to the Plaintiff the following sums for which Plaintiff demands judgment, jointly and severally, against the Defendants: ,