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HomeMy WebLinkAbout99-02990WPM ti 1 i r i CJ 4 0. ® o 1 90002 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Uti sties Inc. Plaintiff vs William A. Cornell Jr. Defendant Civil Action - In La/w?.. . No. (7? -pZ99O ARBITRATION COMPLAINT NOTICE You have been sued in court. If you wish to defend against the claims set forth in the followinq pages, you must take action within twenty(20) days after this complaint and notice are nerved, 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 4//-? 4NNU2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff I Civil Action - In Law vs William A. Cornell Jr. Defendant No. 94- X990 CL Tee 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, William A. Cornell Jr., is an adult individual residing at 222 S. Front Street 1F, Wormleysburg, PA 17043. COUNT 1 UGI Utilities Inc. vs. William A. Cornell Jr. 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 William A. Cornell Jr. 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. 4HHU2 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: $ 914.88 Court Costs: $ 45.50 Service Costs: $ 50.00 TOTAL $ 1010.38 Respectfully submitted, DATED: April 9, 1999 Krzywi0,q and Associates By: 1 NeNmi;kf Interplex- P.O. 505 New Hope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 VERIFICATION 1, Cynthia E. Coffin, an employee of UGI 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 unswom falsification to authorities. UGI Utilities, Inc. Dated:4Ahl BY: _(2't.4nxL, Cyn hia E. Coffin -IY 9BHU2 STATEMENT OF ACCOUNT William A. Cornell Jr. established the following accounts with UGI Utilities Inc. with the following balances and charges: Account Number / Acct Type Service to: Balance ' Service Address 221-601-2025-60 G $914.88 222 S. Front Street IF Wormleysburg, PA 17043 Total Delinquent Balance: $914.88 EXHIBIT A 71- r> >- a iii r? a ' ?. (V7 _J r- V G CJ `?? SHERIFF'S RETURN - NOT FOUND `CASE NO: 1999-02990 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS. CORNELL WILLIAM A JR R. Thomas Kline Sheriff, who being duly to.law, says, that he made a diligent search and inquiry sworn according for the within named defendant, to wit: CORNELL WILLIAM A JR but was unable to locate Him in his bailiwick. He therefore returns the NOTICE AND COMPLAINT IN ARBITRATION NOT FOUND as to the within named defendant CORNELL WILLIAM A JR PAPER EXPIRED BEFORE DEFENDANT COULD BE LOCATED. Sheriff's Costs: So answers: s Docketing 18.00 Service 21.08 Not Found 5.00 Surcharge 8.00 RT omas-RTi $b2.08 KR?YW?1999& ASSOCIATES 06 22 Sworn and subscribed to before me this 1anaC day of 19nn? A.D. ?1(?.gt. : ono & Y - 488U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Ut> ities Inc. Plaintiff Civil Action - In Law vs No. ?? - a99d b-?c William A. Cornell Jr. Defendant ARBITRATION COMPLAINT ( ) to i 7 NOTICE . W? •+ You have been sued iu court. If you wish to defend against the 't;1' claims set forth in the following pages, you must take action n i, II ?_ .. 71 within twenty(20) days after this complaint and notice are . . ? served, by entering a written appearance personally or fy ; ., !L1 . i by attorney and filing in writing with the court your defenses r ` - or objections to the claims set forth against You. You are •,('? ? ' WARNED THAT IF YOU FAIL TO DO 50 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 3.7013-3387 (717) 249-3166/(800) 990-9108 A I:.=%. ?C=ECT COPY, tomoy Of Party Fi{ing TRUE 4X)PY FROM RE%XNO In T10mony were W, I here urft MW M rar and Uw o'x?fd C?ur?a4 ?Pe OBNU2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff Civil Action - In Law vs William A. Cornell Jr. Defendant No. 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, William A. Cornell Jr., is an adult individual residing at 222 S. Front Street IF, Wormleysburg, PA 17043. COUNT 1 UGI Utilities Inc. vs. William A. Cornell Jr. 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 William A. Cornell Jr. 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. 4 BOU2 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: $ 914.88 Court Costs: $ 45.50 Service Costs: $ 50.00 TOTAL $ 1010.38 Respectfully submitted, Krzywicki and Associates DATED: April 9, 1999 By: Ant ony P. I:rzywic 1 1 Neshaminy Interplex P.O. Box 505 New Hope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 VERIFICATION 1. Cynthia E. Coffin, an employee ol'UGI 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 l 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. Dated: BY: Clo 11 t?:= O Cyn hia E. Coffin .4;, i 488U2 STATEMENT OF ACCOUNT William A. Cornell Jr. established the following accounts with UGI Utilities Inc. with the following balances and charges: Account Number / Acct Type Service to: Balance Service Address 221-601-2025-60 G $914.88 222 S. Front Street 1F Wormleysburg, PA 17043 Total Delinquent Balance: $914.88 EXHIBIT A KRZYWICKI & ASSOCIATES Anthony P. Krzywicki, Esquire John L. Shearhurn, Esquire P.O. Box 505 New Hope, PA 18938 (215) 862-4390 Allorney for Plaintiff Attorney I.D. 23754126852 --------------------------------------- UGI Utilities Inc. Plaintiff Court of Common Pleas Cumberland County Civil Action No. VS. William A. Cornell, Jr. Defendant -------------------------------------- 99-2990 CV PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark this matter settled, discontinued, and ended, for the defendants upon payment of your costs only. KRZYWICKI & ASSOCIATES DATED: May 10, 2001 BY: An hony Krzywicki At e-y fo tiff ?r, ?; . ? ?i1 P7 _`i -?v ?? __ l•_i ti _. in . - ?' .. .1 ?_? v