The URL can be used to link to this page

Home My WebLink About01-7105 FX . >3q,'''4iffl, ~, .' 2253U2 In the Court of Common pleas of CUMBERLAND County, Pennsylvania UGI Utillties Inc. Plaintiff Civil Action - In Law vs No. 01 - I'f IOS C!,o~l 't~ Dennis A. Carr 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 (20J 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) 990-91 " ~~.~ , " ~ ~.~ ""-="'1'"-' .~m;,~"lI"'l 'k1~{'O]~,,~'i.'i>~':L.;.L't '~"":: ('.~'" ,. T:_ I III 2253U2 In the Court of Common pleas of CUMBERLAND County, Pennsylvania UGI Utllities Inc. Plaintiff Civil Action - In Law vs No. ot - '"lID.!; C2ioc'l c.,-~ Dennis A. Carr 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, Dennis A. Carr, is an adult individual residing at 122A W. North Street, Carlisle, PA 17013. "';;~i,\<:W_", - 11 _ ~n ~.jC~ ,O;~, .'^ -c.'~-',' :1--' "_,,1'1" . . COUNT 1 UGI Utilitles Inc. vs. Dennis A. Carr 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 Dennis A. Carr. 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.-";>l-iI"JI'I~, ,. ~ , ""I~ " ~ " '" ~-4 IC"'-r ~~-i." 'I ",_ r, i _ ~ -, - 2253U2 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: TOTAL $ 2156.22 $ 2156.22 Respectfully submitted, DATED: December 4, 2001 d Associates 18938 ~-'1\1"'1'^ -_, _ _ _ 7.', ,~'~,. c'__"_' , - ~ I . . "-, "'?'l"-"'~~ r-'hr''\'T'''T'tlt''nr ~"_~TT1-:] - i -m . VERIFICATION I, James R. Gallagher, an employee ofUGI Utilities, Inc., being authoTized 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 beliefthat one of them is true. This statement is made sub'ject to the penalties of 18 P.A. C.S. Section 4904, relating to unsworn falsification to authorities. UGI Utilities, Inc. Dated: IZ/I' /;/ BY: ~0h1W~' ~~ Jam R. Gallagher : ,,!!<;li1., ."" -, _ "~,, ,"'__~' ='" _ . '--'~-'i"""c' ;-m-,', - ___0_"""" , - '--~ -- ,"~- ,,~ " . - J jq,: r;;-lj['-fi_- 2253U2 STATEMENT OF ACCOUNT Dennis A. Carr established the following accounts with UGI Utilities Inc. with the following balances and charges: Account Number / Service Address Acct Type Service to: Balance ---------------~---------------------------------------------------------------- -------------------------------------------------------------------------------- 210-766-7200-95 G 122 W. North Street Carlisle, PA 17013 / / $2156.22 Total Delinquent Balance: $2156.22 EXHIBIT A .--:;:'".-';'''''''''1'~U!![~~J;I~Jl_ ,~ -, ~" - " -- ~ ", - "' ~.~ ~<,,_," ., .., k~ """":.< ;;oo;/'<''''.;;'~;~~~'rfr3;,F- ':Of~~ ~Tj{J1?Vlf'I"~"n,"offfffffl""J'rl~Jtr:fnlli,v:'>ijh1r~~~ ~ f.:i ~ ~ ~ t '" ~ ~ ~ , -' ~ ~ ~ :::1 G ~ ~ , I ~ 0 "') ~ () ~ t,D --a CY i 6"- f -...0 ~ ~ "- , ):= ~,L) -,Ii '-) ~ ~ ~-~ -< "--c.; , " :'! i-:' I" ,'~ ~ ~" '~~_!~'-""r" -~',.r -, _'~_~'-;_"J~,-iJ;cj,Imi'i'{f"~:::~'!\,r~,_~JlTU:J~j!j~~~!.fif,'1F<f'#-i';-':"i-':",r,'J"';,-,;'~"'FF-J".fo"':""""\-''i'~'''fl'f)l>\l.~';i_~:'il.l"U~''1 ~ ~~~J))~r; -,,~ 1] SHERIFF'S RETURN - REGULAR CASE NO: 2001-07105 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS CARR DENNIS A DOUGLAS DONS EN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, was served upon says, the within COMPLAINT & NOTICE CARR DENNIS A the DEFENDANT , at 1557:00 HOURS, on the 2nd day of January ,2002 at 122A W NORTH STREET CARLISLE, PA 17013 by handing to DENNIS CARR a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surchar':1e 18.00 3.25 .00 10.00 .00 31.25 Sworn and Subscribed to before me this 8"/C;' day of ~ dOo:L, A.D. ~~n~,+J '-'I_':lWlI"_ilL'f!!,!l il ~ I So?~/~ R. Thomas Kline 01/03/2002 KRZYWICKI & ASSOC. By:~Q Deputy Sheriff ~~ ~ ..,-~~-.",. CUrtis R. Long Prothonotary TO: Dennis A. Carr 122A W. North Street Carlisle, PA 17013 2253U2 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse * Carlisle, PA 17013 In the Court of Common pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff Civil Action - In Law vs Dennis A. Carr Defendant No. 01-7105 \ \ \ \ \ \ \ \'" \ \ \ \, \ \ \ \" \, \ \, \"'" \ \, 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 as indicated below. (XX) ( ) ( ) ( ) ( ) ( ) ( ) Curtis R. Long Prothonotary Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEY FOR THE FILING PARTY: "'(",,,",(,. . "- ,~~ , ,. ,^ ~ 'v " Anthony P. Krzywicki Krzywicki and Associates 49 North Sugan Road P.O. Box 505 New Hope, PA 18938 215-862-4390 Attorney I.D. No.23754 ~~- - - ,-~, ~ I 2253U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilltles Inc. Plaintiff Civil Action - In Law vs No. 01-7105 Dennis A. Carr Defendant ARBITRATION ,\'" \ \, \, \"" \ \, \" \"" \ \, \ \, \ \, \ PRAECIPE FOR JUDGMENT AGAINST DEFENDANT FOR FAILURE TO PLEAD To the Prothonotary: COUNT 1 UGI Utilitles Inc. vs. Dennis A. Carr Kindly enter default judgment in favor of plaintiff, UGI Utilities Inc. and against Defendant, Dennis A. Carr for failure to plead to Plaintiff's Complaint as follows: Amount Past Due: TOTAL $ 2156.22 $ 2156.22 together with interest thereon from the date of judgment forward and all costs of this action. 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. ri','0<'m _e,_. ~, '" "-' O'c - "~~ ~ ,~ - ""."..,,.... ,,'''' %~"~W~l r TI 'l[ 2 . Carr, is 17013. 22S3U2 The true and correct address of the Defendant, Dennis A. 122A W. North Street, Carlisle, Cumberland County, PA Krzywicki DATED: April 9, 2002 :~''I;'r,i'!!':i ,." ,.-. .," - , - _~-'F ~-r--' " i I i ,I I , " ~ )1 !! ! l! '''~~m:'!fl,,, SHERIFF'S RETURN - REGULAR .;J0l53 Ud, CASE NO: 2001-07105 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS CARR DENNIS A DOUGLAS DONSEN , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CARR DENNIS A the DEFENDANT , at 1557:00 HOURS, on the 2nd day of January , 2002 at 122A W NORTH STREET CARLISLE, PA 17013 by handing to DENNIS CARR a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge SOf:;R2~/~ 18.00 3.25 .00 10.00 .00 31.25 R. Thomas Kline 01/03/2002' KRZYWICKI & ASSOC. By:~Q ",. Deputy ~heriff Sworn and Subscribed to, before,. me .this day of A.D. Prothonotary - &II'~'",j'.'.'., .~!.,. " ..~ ,-, - "',.......".,.. .' -.r-- ~~. 2253U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff Civil Action - In Law vs No. 01-7105 Dennis A. Carr Defendant ARBITRATION ,\" \ \'" \ \ \ \ \, \ \ \, \ \ \ \ \ \ \""'" \" NOTICE TO: Dennis A. Carr 122A W. North Street Carlisle, PA 17013 Date: March 5, 2002 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:AnthOny \~lrZYWlCkl 49 North Sugan Road P.O. Box 505 New Hope, PA 18938 215-862-4390 Attorney for Plaintiff Attorney I.D. 23754 *'W"~H ., 0"... _ ~, -~" >"'~-" ~~.,- L__ '..- ,.~ ".. " ';;/'\1" :'. lrfl1~ lJr-~'-<'---' H -- -- --. :1 , i ! I I ; , I I o,:.llL ~o .),-', us, P TAL SERVI E CERTIFICATE OF MAILING MAY BE usee FOR DOMESTIC AND lNTERNA nONAl MAIL. DOES NOT PROVIDE FOR INSUAANCE-POSTMASTEJL-_.,.--" .-.. ~ Kn~cki &Assoc~tes P.O. Box 505 New Hope, PA 18938 Am.. ,_ .......... i... at......."lS ,;d .~ <0 <0 <0 <0 a!~1 !ij la .' Q~ '~>1E:~j: .Il!l 1:~4~' :I>~ ~ ~ I\~;'~ . :z - "'tJ. caoo:J:::I) C::-.JCCO~-o Z.W""CCO -I -com "I)... . C .. - ~ N " :0 > 'I~ T.\~~s".[1:" J~ ~Q.rt ~'h ~~e-~!U=\ . \~ l Pt\ \'\0 \ . eN ,----_.----~ PS Form 3817. Mar. 1989 ----.--.. -. -- 'n ,. ~ .." ~ ,'- ~ 2253U2 In the Court of Common pleas of CUMBERLAND County, Pennsylvania UGI Utillties Inc. Plaintiff Civil Action - In Law vs No. 01-7105 Dennis A. Carr Defendant ARBITRATION ,\ \ \ \ \'" \ \ \ \ \'" \, \" \ \ \ \ \ \ \ \ \, \" \ The undersigned hereby certifies that written notice of intention to file a praecipe for entry of judgment by default against the defendant, Dennis A. Carr, 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. Krzywicki DATED: April 9, 2002 By: Ant 49 P. N Hope, PA 215-862-4390 Attorney for plaintl Attorney I.D. 23754 ';-~~, ~-, ,;"',~ ",'F ~, - 2253U2 In the Court of Common pleas of CUMBERLAND County, Pennsylvania UGI Utilitles Inc. Plaintiff civil Action - In Law vs No. 01-7105 Dennis A. Carr Defendant \ \ \ \ \ \, \'" \, \, \, \ \, \, \, \, \"""" \ 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, Dennis A. Carr, 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. The defendant, Dennis A. Carr, is more than 18 years of age and currently resides at 122A W. North Street, Carlisle, PA 17013. 3. I have ascertained the above information by personal investigation and make this affidavit with d MicHEllE FYI!. NOTARY PUBLIC OF NEW JEI'lSEY .W COMMISSION EXPIRES JULY 9. 2002 :)m_ ~ ~..". ". ., -->> . ~ ~ i ~ ~- ~ ~~'--"" ,-' ~ - ,,^ ,~ t~ -- R ~ {: ~ lU ~ ~ K: ,1 "., H.~ ','>' ...~,- -~ ~- W><,~, '8-'^'~"-"-Eo-n*(r;'Yi;T~\{ftfr~~i1IFJ'-~-~'~":~~~~i'''fft~l'Ji:j;~~~~ (0~ 'l6 ~ 0 ctp:! t'f? ----Z:- () ~; ~~~ ~r, ---:;.>' r"~ D) ~:~::- GC'~, :,cc,__" ~~t::j .;.;' C:.: 2:. --1 -~ ~" .~ f'~J ~~ :;-0 \...J -n co --n ;;::.:-: ~;b _:-~() ~.~~ ~~ ~' ',.,. S -< '.'" 0-' _r~l~, Ji '_ ~~~,~- "awl.!!!il:!'~~,I.._~~:"!~fr!"-;m;l1~,~,,,,"}.{1!c.""-l;<",,''''r, ,,,,C';,,,,"o;-~,ii"--d';-'f<',''','i';';:illml\W~J~~~~~:r_'