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Home My WebLink About01-0437 FX ""'~ 0" '" - ...~-- 0'. 'IW-' .. ~, 1735PP In the Court of Common Pleas of CUMBERLAND County, Pennsylvania PPL Electric Ut~l~t~es Corp. Plaintiff vs civil Action - In Law No. 01 - -'/),7 G(J~l y~ Millers Auto Body Defendant Ron Miller aka Don Miller 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 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 ',"'- ".. ._- , '"~~~~"-. "ill~\\.II;", " .. 173SPP In the Court of Common Pleas of CUMBERLAND County, Pennsylvania PPL Electric Utilities Corp. Plaintiff vs Civil Action - In Law No. 0/- </37 Q;;J /~ Millers Auto Body Defendant Ron Miller aka Don Miller Defendant ARBITRATION COMPLAINT 1. This is an action by Plaintiff, PPL Electric Utilities Corp. to recover damages from Defendants arising out of a debt Defendants owe to Plaintiff by virtue of utility service. 2. PPL Electric Utilities Corp. 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 827 Hausman Road, Allentown, PA 18104. 3. Defendant, Millers Auto Body, is a Sole Proprietorship doing business and/or residing at 3537 Hartzdale Ave, Ut. D, Camp Hill, PA l70ll. " L~ W' ~A~"~j#j,ll, 4. Defendant, Ron Miller aka Don Miller, is an adult individual residing at 3537 Hartzdale Ave, Ut. D, Camp Hill, PA 17011. COUNT 1 PPL Electric Utilltles Corp. vs. Millers Auto Body and Ron Miller aka Don Miller 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 Millers Auto Body and Ron Miller aka Don Miller. 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. .- ~"'~11.11 , 1735PP 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: Fees: Court Costs: Service Costs: TOTAL $ 3576.44 $ 895.00 $ 45.50 $ 100.00 $ 4616.94 Respectfully submitted, Krzywicki and Associates DATED: January 19, 2001 on rz N h Road . Box 505 New Hope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 _0 ~,'ill~kIiiI>k:'it""c,i 1735PP . ~- , ~." ,.;,'" VERIFICATION I, Anthony P. Krzywicki, Attorney for PPL Electric Utilities Corp., verify that the facts, stated in the foregoing pleading, are true 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. PPL Electric Utilities Corp. DATED: January 19,2001 By: .cki -~- ,-' "'- , =, -~1i:bl,Wlllliq:'l"'tJ,-' 1735PP STATEMENT OF ACCOUNT Millers Auto Body and Ron Miller aka Don Miller established the following accounts with PPL Electric Utilities Corp. with the following balances and charges: Account Number / Service Address Acct Type Service to: Balance -------------------------------------------------------------------------------- -------------------------------------------------------------------------------- 33460-81028 E 3537 Hartzdale Ave, Unit D Camp Hill, PA 17011 / / $3576.44 Total Delinquent Balance: $3576.44 EXHIBIT A 1iM--' k,'""-"~M~j]l\;-;#li,;;;,t,;liii~1ciI!i~w.i~ll!"1i!!~"Uqm5&,,';-,,HI~lir4~i:.wIiiila;~'it ........-..,.~ '-"~,,:tl ~ '-~"~-~lrl'')J'~ "'-"~~'U - "" $ ~ ()q 8 0 0 --w.. .." ~ ~ s:: L. S2trl -I ~ :Po ,.. {0 en Z i'li?J h ~ ~~ N -r,f"n ~ , N "fry ~ B II{ roo ~{~ ~ ~o -0 ;:Tfl <Y :J!:: !;to t; I I >8 ':1 om ~ ~ ~ :Jl ~ p:; .... ~ ,.~ ~ "" -, ,,~, , ,~ " ..,,,o~ "~. ^~j _ O~ s - c,' ,~ ., ~.. '" Il,U;)"'_~^,: ~ -".; ,... CASE NO: 2001-00437 P SHERIFF'S RETURN - REGULAR \ COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PPL ELECTRIC UTILITIES CORP VS MILLERS AUTO BODY ET AL HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MILLERS AUTO BODY the DEFENDANT , at 0010:15 HOURS, on the 24th day of January , 2001 at 3537 HARTZDALE AVENUE UNIT D CAMP HILL, PA 17011 by handing to RYAN MILLER (OWNER) 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 So Answers: 18.00 8.68 .00 10.00 .00 36.68 ~~~~~~~ R. Thomas Kline 01/26/2001 KRZYWICKI & ASSOCIATES Sworn and Subscribed to before By: 7JAA~~ kJ----tr Deputy Sherlff . me this i~ day of J~'t~ ,,'= I . .A.D. . _ -,--u-O ~ ~ r thonotary ::i ,. ,-~ .~ ~- .~~~. ,'';';''k_ I -I".r. -~~ _~1"'~). t ., SHERIFF'S RETURN - REGULAR r CASE NO: 2001-00437 P '", COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PPL ELECTRIC UTILITIES CORP VS MILLERS AUTO BODY ET AL HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MILLER RON A/K/A MILLER DON the DEFENDANT , at 0010:15 HOURS, on the 24th day of January ,2001 at 3537 HARTZDALE AVENUE UNIT D CAMP HILL, PA 17011 by handing to RYAN MILLER (OWNER) 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 6.00 .00 .00 10.00 .00 16.00 So A~ ;c ~-~~, R. Thomas Kline 01/26/2001 KRZYWICKI & ASSOCIATES Sworn and Subscribed to before By: 7~AJ/ ~ Deputy Sherif~ me this J.J- day of ;!~ cJr.."f A.D. C;- n. 0' )u,tJ;,., ~ r~thonotary ,