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Home My WebLink About01-0822 FX ."'i<lWh. ~~"~ I , ,- , ','. ~ .......-mi!lll;!U8~ 1149U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utllltles Inc. Plaintiff Civil Action - In Law vs No. 01- j>~ Iyonna Anderson Defendant \ \"'" \"'" \ \ \ \ \ \"""""""'" ARBITRATION COMPLAINT NOTICE ~ou have been sued in court. If you wish to defend against the clQims set forth in the following pages, you must take action within twenty(20) days after this complaint and notice are se~ed, 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 WAANED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT yo~ and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or fo~ 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 TEtE PHONE 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 G'U'I.L '-r~ f ~, '" , -"","~ ~ ~~' , , -" ~ "-' -, - , ":f'i\i,~" 1149U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Civil Action - In Law No. 0/- f.22 ~/~ Iyonna Anderson Defendant "\ \ \ \" \ \ \"" \ \ \ \ \ \"""'" \"'" 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, Iyonna Anderson, is an adult individual residing at 4 Dulles Drive AG8, Camp Hill, PA 17011. "' ,.,--,~,... .il'.~~,_~ COUNT 1 UGI Utilities Inc. vs. Iyonna Anderson 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 Iyonna Anderson. 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. -. "~. ~ ~--~ . J' ~",^_ - , ". ,"-"._C,,,,, , :"'iliMil'$J!aih 1149U2 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: Court Costs: Service Costs: TOTAL $ 2292.44 $ 45.50 $ 100.00 $ 2437.94 Respectfully submitted, DATED: October 25, 2000 W-' - ~ " -,~- ~ _ I ~J" ""' .., ."0' ~." ~~: . . 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. UOI Utilities, Inc. Dated: /0 /z ~ BY: ~ ~~ Cyn la E. Coffin ~$l;I ~~ .......... .4. ". , '''''l!h~ , . 1l49U2 STATEMENT OF ACCOUNT Iyonna Anderson established the following accounts with UGI utilities Inc. with the following balances and charges: Account Number / Service Address Acct Type Service to: Balance -------------------------------------------------------------------------------- -------------------------------------------------------------------------------- 206-350-3270-84 G 1261 Bailey Street Harrisburg, PA 17103 / / $2292.44 Total Delinquent Balance: $2292.44 , " EXHIBIT A iiI!Iiiiil ''''1;" ~.".'.""__"_"""U'"b,,,,""',""""b_'.""~'~"- "",,-'." ~~wJ~l.illil~~~~l'la!~IiIi-P ill ~~ ~ ~ \ Jt}h~ cg~8~ oJ '\\r I I ~ ~~ J ~1c1 1.t,~.._,.,,~_., ^-'-"~-"-'-"~~""_-"~-'-~""'-'~' ., '>'- -~-- ." -,. 0 0 Ci C G <:' , ,oci', " !:!lrr f'1 Z:r'r (}J /,,- I c1j,,:- \.0 , ... -< :~~: " '..- r::=CJ ~~~~) ",". ...,., ,-,:'-1 Gj;:r\ T~ ,,-. j;:b - . '..J v) :s.~ 1"T1 C ~.::t z =< .::J ~ en ~ "'< . "~,d"",-",l","",-"'."",-,>_~"".,",_."~,"......"",,,,,,,,"'lr.lo;."',"=,,, "" -,~~ " ~.." -,-,~" "'~.1IIII1JB~,",,""; SHERIFF'S RETURN - REGULAR CASE NO: 2001-00822 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS ANDERSON IYONNA SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ANDERSON IYONNA the DEFENDANT , at 0017:24 HOURS, on the 26th day of February 2001 at 4 DULLES DRIVE G8 CAMP HILL, PA 17011 by handing to PORSCHIA ANDERSON (SISTER) a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.30 .00 10.00 .00 37.30 So Answers: ~~~~ R. Thomas Kline 02/28/2001 KRZYWICKI & Sworn and Subscribed to before By: me this J J1<..el day of ~ ~Arn J A.D. eAr- {J~ ~ . . Prothonotary' ~..,~-~ ,~ .'. , "" " . ~"'< "" , ~" ""~i<ir..; 1149U2 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUmberland County Courthouse * Carlisle, PA 17013 Lawrence E. Welker Prothonotary TO: Iyonna Anderson 4 Dulles Drive AG8 Camp Hill, PA 17011 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utllltles Inc. Plaintiff civil Action - In Law vs No. 01-822 CV Iyonna Anderson Defendant """"""""""""""""'" , ARBITRATION NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proCeeding~d b~W: ~ ~o.W.L <,;.,.;.u......c E. U (XX) ( ) ( ) ( ) ( ) ( ) ( ) Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings Prothonotary IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEY FOR THE FILING PARTY: Anthony P. Krzywicki Krzywicki and Associates 1 Neshaminy Interplex P.O. Box 505 New Hope, PA 18938 800-296-2103 Attorney I.D. No.23754 ~'~- 1.. ". -, . ~ , . "^,,, . ;, j. .k_ .'6' ,~. _ -rb 1149U2 In the Court of Common pleas of CUMBERLAND County, Pennsylvania UGI Utllltles Inc. Plaintiff Civil Action - In Law vs No. 01-822 CV Iyonna Anderson Defendant ,\ \ \""""""""""" \ \""" \ \ ARBITRATION PRAECIPE FOR JUDGMENT AGAINST DEFENDANT FOR FAILURE TO PLEAD To the Prothonotary: COUNT 1 UGI Utilitles Inc. vs. Iyonna Anderson Kindly enter default judgment in favor of Plaintiff, UGI Utilities Inc. and against Defendant, Iyonna Anderson for failure to plead to Plaintiff's Complaint as follows: Amount Past Due: Court Costs: Service Costs: TOTAL $ 2292.44 $ 45.50 $ 100.00 $ 2437.94 together with interest thereon from the date of judgment forward and all costs of this action. '-0 "-'- "'-'_iLn._ ,,-",' ,'" " d _ "'_. c_ ','_-' _-C'~ '. _~_ '- _1/, 1149U2 I hereby certify to the best of my knowledge and belief as follows: 1. The true and correct address of the Plaintiff, UGI Utilities Inc., is 225 Morgantown Road, Reading, PA 19612-3009. 2. Anderson, 17011. The true and correct address of the Defendant, Iyonna is 4 Dulles Drive AG8, Camp Hill, Cumberland County, PA Krzywicki d Associates DATED: May 9, 2001 By: Ant 0 1 Ne P.O New ope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 ._> ~-<~~- " " - ~ 1,,-,_[ -'-,- -.-" "-~!;j;_,,--i SHERIFF'S RETURN - REGULAR CASE NO: 2001-00822 P \ \~qw1. COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS ANDERSON IYONNA SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon I , ANDERSON IYONNA the DEFENDANT , at 0017:24 HOURS, on the 26th day of February, 2001 at 4 DULLES DRIVE G8 CAMP HILL, PA 17011 by handing to PORSCHIA ANDERSON (SISTER) a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.30 .00 10.00 .00 37.30 So Answers: ~~~~ R. Thomas Kline 02/28/2001 KRZYWICKI & Sworn and Subscribed to before By: me this .day of A.D. Prothonotary v ''"'~~." .~ - "-~.~ - .~ - .,-, Co- """'." 1149U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff Civil Action - In Law vs No. 01-822 CV Iyonna Anderson Defendant ARBITRATION \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ NOTICE TO: Iyonna Anderson 4 Dulles Drive AG8 Camp Hill, PA 17011 Date: April 11, 2001 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 cannot 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, PA 17013-3387 (717) 249-3166/ (800) 990-9108 Krzywicki and Associates By: 151 Anthony P. KrzYWlcKl 1 Neshaminy Interplex P.O. Box 505 New Hope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 < ... , , " , .. . ;. ~'''. ~___'~"i'" :",;.,-~< -~ "~-~~j,- . ~~ . . ~" .\ \. U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAYBE USED FOR DOMESTIC AND INTERNATIONAl.. MAIL. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Recal' Krzywicki & Associates P.O, Box 505 New Hope, PA 18938 .' /.. ' /Q'~-' J::;-': IV", 'm >- 'Loll ;g ~\ " '\;.. -: ::r:.~ ,) ~ 0 --'-'. . "3~~1 \ "'..~, ,~"''''~~!>\, . '1 .,.w ",~\~,~l. ~f'Z -,' 1a..~~t~~.~1\,; ,. ~';)Q)rri;l.t~"~ of... /..) o.=a3~!.~~';.5;\1 <::/ 'II ,1:\, . in ' ;~~j "'1 = !"~ I~I; ~ !HI Q :,~ lm I'"~ ',I; - ~..c .............~.1l-.}"'. One pi8C9 of Ordinary mall addressed to: -r)/IlI"ln/" /ll'ldf'/8d1 ~ 0 Jles V(({/p /16 ?- (J /U'r1CJ /-hl/ fI/J /7()(j I //i19ct? , ...es.f~u:n,~aF,M.r. .1sas ,/' .---.........- ~/ -"'~ ~~,~"~, " ,{If ~ ~ _ ,_ 1 ' -~" "-0 1149U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff Civil Action - In Law vs No. 01-822 CV Iyonna Anderson Defendant \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ ARBITRATION The undersigned hereby certifies that written notice of intention to file a praecipe for entry of judgment by default against the defendant, Iyonna Anderson, 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. and Associates DATED: May 9, 2001 P. aminy Box 505 Hope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 10<., !!IiI1lIJUfuk' ~..,j." ~ " ",,' "~ ;.;:,; C~, ~'"" p ~;f .. ., . 1149U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Ut~l~t~es Inc. Plaintiff Civil Action - In Law vs No. 01-822 CV Iyonna Anderson Defendant \ \ \ \ \"""" """'" \ \, \ """" II 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 of UGI Utilities Inc., 225 Morgantown Road, Reading, PA 19612-3009, Plaintiff herein, and as such state the following: 1. The defendant, Iyonna Anderson, 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. age and 17011. The defendant, Iyonna Anderson, is more than 18 years of currently resides at 4 Dulles Drive AG8, Camp Hill, PA 3. I have ascertained the above information by personal investigation and make this affidavit with due authority. . Krzyw~c ~ MICHEllE IT NOTARY PUBLIC OF NEWi.n:RSEV' MY COMMISSION 'EXf'IRES"JOL Y 9, 2002 ~[ii.'"..,;"",~~,".d'=~..Mi"2,Jrl,1!,!fJ.lli!$k~_ih1~1ia~~Hm,t5-<!'~bgJ.@~1~~1" f~() l!ill . ~==',., ~ ~. ~~-~ ~~ -"-~ ,;,..;,:," ~li!itilIiIIt, - ~,..~..j -0 ,~"' - A ~. C'_ t ~ (J ..cQ "-C ~ , 0 () 0 ~ (J ~ ::;J: t:!C: ~'3 ...... ~-V rrlr"": ..< Z-:- "' --" -7[" "- ~~~_: .,"'- 3 t o ~ <__.1 V ~R -."'" .... ()..J J )>c w ( ;~ =<! I:::> --"I . . . J:ll( . ,~. ,. .. ., "'~~-" . ."N.. .- -' 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. File No.: 01-822-CV Amount Due: $2437.94 Interest: $24.38 Arty's Comm: Costs: $ Iyonna Anderson Defendant 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 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 4 Dulles Drive AG8, Camp Hill, PA 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 ofthe 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 defendant(s) described in the attached exhibit. , Date: August 14, 2001 .""0 ~" 'v~ fj,'itbo~!jjl:iJIiI~~~."...&;~~~~mwb:r.iifj~'.1l~-' 1~ :::::: ..... ~ ..... ~ ~{:,f _1 .... V ~~ ~8 l'-~ ;- ~'-' ~ ,,,_~_ <~_~~H ~_,," -6f. ...... C> ...0 ~ I ~1I1i!i~.' ~ ~-'_.'''''~.<''''~IIIiI!1' , 0 ~..o~c.v~ . . :"1 ~ '1 ~8(9~o I I () ~ r~ Q 0 C1 \,~,,- -'1 :;,- --0"" U) .::: ... - nlU.; ", - ... ... z~f -0 ,- 7[~ ~v ~?d ~ 9"~~~ C) ... ... ~i~~; ~ ::~~l('S .. "T"-i-,_ ..... ~ -.>l~) " ----.;; =:! ~C. ~.;~C) )>c: w Om Z ,:.,:, :1>' -; :iJ -< (:::> -< ~ ~ - , ,,,.>~-=' --".~~'~ ' ~ C'1:!::!b!l ~ = [b!b, [b!b, Q) , , l...<- oj ~ ~.....ll>:Ilj;j;:,) ~ R. Thomas Kline, Sheriff, who being duly swom according to law, states thiswritisreturnedSTAYED.. DEFENDANT MOVED, LEFT NO FORWARDING ADDRESS. Sheriff s Costs: Advance Costs: 150.00 Sheriffs Costs:~~~_~~_ ijCj /11 Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge 20_00 Levy ';0, ;,' Post PoneSaie Garnishee ,..4, 18.00 ~A,g .50 1.00 9.75 Refunded to Atty on 11/5/01 ::II} ,,~ :'J . ~ y,3 Sworn and Subscribed to before me So Answers; t"'~~, \) 7"- ~ r-:. (-<. ., this 7 n;.. day of ,'-tuumj~, ) 2001 A.D. Qtl.".Lo' I} ~,i" l ~ p onotary R. Thomas Kline, Sheriff By Cfo lId)tLQ,/Ju.uJb a..t/ 'i1H.V!\1,\'3lI,1/3d 1-'\ ~~ ',<) iYlfJ ~ '~_J iO, ~!d 60 E I 130 ~-:'1 1blh,; 1L-iL __.::l iR:::::')' ---- '-~ eM \. ^" 'f\" /1\-1 .,- OP- I~:J ~ ^J.Nnc~: . " i .,.;JrtflO :I::Hit3HS JiLL .:i0 3:i1.:JAO 'i~r/-";""""",,~...,J;~<M'JM~jM~ilci,~$lI&j~-sIi\~i!fui!;~'f,"~:,,<:%/ ;_"~\i";ili;,,;;;';:i'i_',~!>t:,,,,";:"Bi&tiihm!t~~r;imifi~HIi!Il&!!!<lil4lL>!ii!i~~l!i!llOO~~Jl!!!.f~- WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 01-822 CIVIL 1~ TERM . CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due UGI Utilities, Inc. PLAINTIFF(S) from Iyonna Anderson, 4 Dulles Drive AG8, Camp Hill, PA DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell All property belonqinq to 4 Dulles Drive AG8, Camp Hill, PA (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the po$ession of anyone other than a named garnishee, you are directed to notify hinVherthathe/she has been added as a garnishee and is enjoined as above stated. Amount Due Interest Atty's Comm Atty Paid f'larnllll Paid $2437.94 % L.L. Due Prothy Other Costs $.50 524.38 51.00 $109.30 Date: september 28, 2001 Curtis R. Long Prothonotary, Civil Division ........hy. a~ D P - 7?fl./)~4/ Deputy REQUESTING PARTY: Name Anthony P, Krzywicki, Esq. PO Box 505 ~Address: V, Net" Hr.["". Ph 1 R9'3R :,,;,atlorney for: PIQinti ff ~ ;elePhone: 215-862-4390 Supreme Court ID No. 23754