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Home My WebLink About01-06595 , ~ I~ 0_' ~.'''' .' c'- '"' ~ -.- . ~~>;~- ~Iliit."i[,,\~~''''h-. In the Court of Common Pleas of Cumberland County, Pennsylvania UGI Utilities Inc. Plaintiff Civil Action - In No. Ot - (p 616- vs. Kathy Coffey Defendants 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 Law ~ ~;~ - ~ -- -"H.1!!. nill!ir~l1IiMiJi"'J";k!";_",.,; In the Court of Common Pleas of Cumberland County, Pennsylvania UGI Utilities Inc. Plaintiff vs. Civil Action - In Law No. Kathy Coffey Defendants ARBITRATION COMPLAINT 1. This is an action by plaintiff, UGI Utilities Inc. to recover damages from defendant(s) arising out of a debt defendant(s) owes to plaintiff by virtue of an 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. 3. Defendant, Kathy Coffey, is an adult individual residing at 111 2nd Street, Apt. 4, 2F, West Fairview, PA 17025. ~~ J , I' I ~w_~ '. ','-.-- - ;-. ~-,- ,., "~I"-~~J;kh COUNT 1 UGI Utilities Inc. vs. Kathy Coffey 5. At all times 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 Kathy Coffey. 7. At the present time, defendant(s) are in default and have an 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. 8. The utility service which was provided by the plaintiff to the defendant(s) aforesaid, was received, accepted, and utilized for the benefit of said defendant(s). f:~i . , ",1 ;.,;. ^"'''''~-,"*,,:''_-, 9. With the knowledge, and approval of defendant(s), her daughter, Samantha Coffey, opened an account for gas service. 10. Gas service was provided to the defendant(s) under 23 Fa. C.S.A. sec 4102 for the support and maintenance of the family of the defendant(s). 11. Plaintiff made demand on defendant(s) to repay the sums then due and owing to plaintiff, but defendant(sl have refused and continue to refuse to pay plaintiff. 12. Despite demands upon defendant(sl for payment by the plaintiff, defendant(s) have failed and refused to pay plaintiff the balance due and owing on said account(s). 13. Defendant(s) have been unjustly enriched by accepting service without full payment. ;~ '. . "~ ,~-, Jl~L . jl1i~",,:ifu;'Xf-';_ WHEREFORE, there is now due and owing from the defendant(s) to the plaintiff the following sums for which plaintiff demands judgment against the defendant(s): Amount Past Due: Attorney Costs: Court Costs: Service Costs: TOTAL $1978.37 $ 250.00 $ $ $2228.37 Respectfully submitted, Krzywicki and Associates By: ny o 505 ope, PA 1893 -862-4390 Attorney for Plaintiff Attorney I.D. 23754 DATED: October 5, 2001 ~j o ~ ~, "' , . ~'" '"". ."" ~ j~,~~t*'i."',,~ j VERIFICATION I, Aprille Beasley, 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. Aprille Beasley Dated: lOiS-h) BY: -- -~~" . " . ~.. . ~~ ....; , ~' ,~;;;I.;j,",~:;'t;;,c'" STATEMENT OF ACCOUNT Kathy Coffey established the following accounts with UGI Utilities Inc. with the following balances and charges: Account Number/ Service Address Acct Type Service to: Balance 221-609-3666-15 Ga 111 2nd Street, Apt. 4, 2F, West Fairview, PA 17025 / / $1978.37 Total Delinquent Balance: $1978.37 EXHIBIT A 11) illf~~_~~~Ji~.J1i1il';'1H,,,,!lii.Wi~~ii!'fW""~'j!dlf;;'V,",)',j~...;, '>"i';';'5'\;o::_,.-f_\~,A.-,,&."iMo;,;I~0;:%::oi;\Uilii\l1if;j;-mro:i:dillllilll~II~:Ill.i:~lL.j~~M!li4~iilttIl!li ~ Q~ -- )-.-- --.. --..l' 4:\ ~ -" ....., ---1 ~ ~ -p-- ~ fc7s q... = _" ''''''' ""''''_"S' .,~., ."'..... =,,'~"'~ ",~~,,,,,,.., --',,-~-,.-, -~.-'" -"~ ~) ~ ~\ JJ 0' '.."'. ~"t' - <A <::: - 0 C) 0 C -n ?: z t '""{}CC '::J ,. Pip .,- ;'~i~ 2~:~ "- N 'jc ~6 (J"> l)(L) E t~)?~ )>C'i -,-:b- i~c5 - ..v-C - I,..) -l ~ .t.,) Z >> Q"\ -< . . 8 "' ~~< "'--...;~-~- ~ .,- lIh\l1i,.1!;Iq"""" ~ I: -< '-.. '.. ~ lliiril-""" ,~- ~~~" ~ '" n___j~ ~~i !iJii,')._~./i SHERIFF'S RETURN - NOT SERVED CASE NO: 2001-06595 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND UGI UTILITIES INC VS COFFEY KATHY R. Thomas Kline , Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: COFFEY KATHY but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE NOT SERVED , as to the within named DEFENDANT , COFFEY KATHY UNABLE TO SERVE PRIOR TO EXPIRATION. ATTEMPTED EIGHT TIMES. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 20.80 .00 10.00 .00 48.80 ~ /,cP"/" ~ COUNTY KRZYWICKI & ASSOC 12/27/2001 Sworn and subscribed to before me this .l...uL day of 0'"u~'1 ~:u A.D. ~,Q /;"Jt'a_-}AqAf; Pro h notary , \ jJ , , -~"II - ~ -,~ ~'" ~ '" ~ , , --~- '"iRm,~",2 ". In the Court of Common Pleas of Cumberland County, Pennsylvania UGI Utilities Inc. Plaintiff Civil Action - In Law No. 0 /- (P~1'16- ~ vs. Kathy Coffey Defendants 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 TRUE COPY FROM RECORD ,.:c".,":, "I'''I1'!'i(!; ~lS In Testimony whereof, I here ulltO set myhai\<l It ""'\'~ ~ and the seat of s l' at CarllSle,~,. " COPY. flli a ,~ ""', I ' ~~ Ii ~~,--~. ,J ,<< ~~"',;.~~,~ I ',-' ~,;;, - ~l~lj.oo?j", . In the Court of Common Pleas of Cumberland County, Pennsylvania UGI Utilities Inc. Plaintiff vs. Civil Action - In Law No. Kathy Coffey Defendants ARBITRATION COMPLAINT 1. This is an action by plaintiff, UGI utilities Inc. to recover damages from defendant(s) arising out of a debt defendant(s) owes to plaintiff by virtue of an 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. 3. Defendant, Kathy Coffey, is an adult individual residing at 111 2nd Street, Apt. 4, 2F, West Fairview, PA 17025. ',~ ... ~~ .>-" . .......~ ~ -, W;~~"'li COUNT 1 UGI Utilities Inc. vs. Kathy Coffey 5. At all times 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 Kathy Coffey. 7. At the present time, defendant(s) are in default and have an 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. 8. The utility service which was provided by the plaintiff to the defendant(s) aforesaid, was received, accepted, and utilized for the benefit of said defendant(s). F,fij -~ ~' , "' ,1 , > ,-~--; - """"<,;"~~, 9. With the knowledge, and approval of defendant(s), her daughter, Samantha Coffey, opened an account for gas service. 10. Gas service was provided to the defendant(s) under 23 Pa. C.S.A. see 4102 for the support and maintenance of the family of the defendant(s). 11. Plaintiff made demand on defendant(s) to repay the sums then due and owing to plaintiff, but defendant(s) have refused and continue to refuse to pay plaintiff. 12. Despite demands upon defendant(s) for payment by the plaintiff, defendant(s) have failed and refused to pay plaintiff the balance due and owing on said account(s). 13. Defendant(s) have been unjustly enriched by accepting service without full payment. ~ft liiI1l ,- I...~", " . ,J - ,- -~, . " .,~~'t"J"" WHEREFORE, there is now due and owing from the defendant(s) to the plaintiff the following sums for which plaintiff demands judgment against the defendant(s): Amount Past Due: Attorney Costs: Court Costs: Service Costs: TOTAL $1978.37 $ 250.00 $ $ $2228.37 Respectfully submitted, Krzywicki and Associates DATED: October 5, 2001 By: Anthony P. Krzywicki PO Box 505 New Hope, PA 18938 215-862-4390 Attorney for Plaintiff Attorney I.D. 23754 ''!,: I','" ". - j~, ."-'J" "-'-""1 - - '--'.' , ""'-"-"'.0,..,:1'; VERIFICATION I, Aprille Beasley, 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. Aprille Beasley Dated: lo/s;b; BY: "\1 ~"~I , , ^ ~__.; ,j- __'_.~_'J _ ,.,,~w STATEMENT OF ACCOUNT Kathy CoffllY established the following accounts with UGI Utilities Inc. with the following balances and charges: Account Number/ Service Address Acct Type Service to: Balance 221-609-3666-15 Ga 111 2nd Street, Apt. 4, 2F, West Fairview, PA 17025 / / $1978.37 Total Delinquent Balance: $1978.37 EXHIBIT A , c. 'I i '_I $1Jf!/j1~ ~ ~~ C' - ~ll>~-A~., -~> ~q:~;;r;r& !~""I';:le ~ ~. .rr~' . "~ OFfiCE OF' THE SHE"'FF CUkEEPL,.lNO COUNTY Nor 26 3 26 PH 'at CAdLJSLf.~~ PENNSYLVANiA . >fl^!'i"~_'l'T(..,-","'"~' !1;r"'1twM~-< . ''1' ~btlll\l,!iJg!lil "-"'''\'T',j~'!f;'Y'M''''t-.jij~",-,"~M;W,j~tWJ.'~f.li!i~~J,___\-,; ',; ,~J