HomeMy WebLinkAbout02-57882469U2
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
UGI utilities Inc.
Plaintiff
vs
william DeJesus
Defendant
Civil Action - In Law
ARBITRATION
COMPLAINT
NOTICE
YOU have been sued in Court. If you wish to defend against the
claims set forth in the following pages, you ~ust take action
within twenty(20) days after this complaint and notice are
served, by entering a writte~ 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 T~AT 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 LJ~WYER AT ONCE. IF YOU
DO NOT HAVE A I~WYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE TgE OFFICE SET FORTH BELOW TO FIND OL~ WHERE YOU
C~LN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013-3387
(717) 249-3166/(800) 990-910
2469U2
In the Court of Common Pleas of
UGI Utilities Inc.
Plaintiff
VS
William DeJesus
Defendant
CUMBERLAND County, Pennsylvania
Civil Action In Law
ARBITRATION
COMPLAINT
1. This is an action by Plaintiff, UGI Utilities Inc.
to recover damages from Defendant arising out of a debt Defendant
owes 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, William DeJesus, is an adult individual residing at
512 North Front Street, Wormleyburg, PA 17043.
COUNT 1
UGI Util~ Inc.
William DeJesus
vs.
4. 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.
5. Plaintiff supplied utility service to William DeJesus.
6. At the present time, Defendant account is in default and has
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.
7. The utility service which was provided by the Plaintiff to
the Defendant aforesaid, was received, accepted, and utilized for
the benefit of said Defendant.
2469U2
8. Defendant is in default of his/her obligation, having failed
to make the payments as they became due.
9. 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.
10. Despite demands upon Defendant for payment by the Plaintiff,
Defendant has failed and refused to pay Plaintiff the balance due
and owing on said account(s).
11. Defendant has been unjustly enriched by accepting service
without full payment.
WHEREFORE, there is now due and owing
the Plaintiff the following sums for which
judgment against the Defendant:
from the Defendant
Plaintiff demands
to
DATED: November 25, 2002
Amount Past Due:
Fees:
Court Costs:
Service Costs:
TOTAL
$ 1816.81
$ 425.00
$ 55.50
$ iO0.O0
$ 2397.31
Respectfully submitted,
Krzyw~ Associates
BY:Ant/ony P. Krzywicki
49/North S. uea~Road
P/O. Bo3f/505 [
yew Hj>pe, PA 1~938
Attorney I.D. 23754
VERIFICATION
l, Jeff Graeff, an employee of UGI 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.
Dated:
U~ Utilities, Inc.
2469U2
STATEMENT OF ACCOUNT
William DeJesus established the following accounts with UGI Utilities
Inc. with the following balances and charges:
Account Number / Acct Type Service to: Balance
Service Address
220-494-7400-83 G
3415 Sharon Street Harrisburg, PA 17111
/ / $~816.81
Total Delinquent Balance: $1816.81
EXHIBIT A
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2002-05788 p
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
UGI UTILITIES INC
VS
DEJESUS WILLIAM
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
DEJESUS WILLIAM
unable to locate Him
COMPLAINT & NOTICE
but was
in his bailiwick. He therefore returns the
the within named DEFENDANT
, NOT FOUND , as to
, DEJESUS WILLIAM
PER CURRENT TENANT, WILLIAM DEJESUS MOVED OUT AT
LEAST ONE YEAR AGO.
Sheriff,s Costs:
Docketing 18.00
Service 11.04
Not Found 5.00
Surcharge 10.00
.00
44.04
R~. Thomas Kl'1~e
Sheriff of Cumberland County
KRZYWICKI & ASSOC
12/19/2002
Sworn and subscribed to before me
this '~.~{ day of ~
~ 3 A.D.
Pr~tt~onot~ry ~ ~