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Home My WebLink About03-07192922U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Ann E. Peragine Defendant Civil Action - No. - ARBITRATION In Law 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 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 }{AVE A LAWYER OR CD/~NOT 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) 990-910 2922U2 In the Court of common pleas of CUMBERLAND county, Inc. Plaintiff vs Ann E. Peragi~fendant Pennsylvania civil Action - In Law iARBITRATION 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, Ann E. Peragine, is an adult individual residing at 16 Eastgate Drive, Camp Hill, PA 17011. COUNT 1 UGI Utilities Inc. vs. Ann E. Peragine 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 Ann E. Peragine. 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. 2922U2 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 from the Defendant to the Plaintiff the following sums for which Plaintiff demands judgment against the Defendant: Amount Past Due: $ 2975.80 Fees: $ 400.00 Court Costs: $ 45.50 Service Costs: $ 100.00 TOTAL $ 3521.30 DATED: September 11, 2002 Respectfully submitted, Krz~nd~ Associates An~hony. P,,-~Krzywicki Attorney for Plaintiff Attorney I.D. 23754 VERIFICATION I, Anthony P. Krzywicki, Attorney for UGI Utilities Inc., verify that the facts, stated in the foregoing pleading, are tree and correct to the best of my information and belief and that this verification is made subject to the penalties of 18 P.A.C.S. Section 4904, relating to unsworn falsification to authorities. DATED: September 13, 2002 By: UGI Utilities Inc. 2922U2 STATEMENT OF ACCOUNT Ann E. Peragine established the following accounts with UGI Utilities Inc. with the following balances and charges: Account Number / Service Address Acct Type Service to: Balance 213539152002 16 Eastgate Drive Camp Hill, PA 17110 G / / $2975.80 Total Delinquent Balance: $2975.80 EXHIBIT SHERIFF'S RETURN - NOT FOUND CASE NO: 2003-00719 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND UGI UTILITIES INC VS PERAGINE ANN E 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 PERAGINE ANN E unable to locate Her COMPLAINT & NOTICE in his bailiwick. but was He therefore returns the the within named DEFENDANT , PERAGINE ANN E , NOT FOUND , as to PER POST OFFICE, DEFENDANT MOVED AND LEFT NO FORWARDING ADDRESS. Sheriff's Costs: Docketing 18.00 Service 10.35 Not Found 5.00 Surcharge 10.00 .00 43.35 SR,~ Thoma~li _i ~eriff of C~erland County KRZYWICKI & ASSOCIATES 03/07/2003 Sworn and subscribed to before me this /0 ~ day of~t~ ~,~o3 A.D. PrOthonotary ~