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Home My WebLink About99-03406 519U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Dawn Woolingham Defendant Civil Action - In Law No. 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 Lhe 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 sivuz In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Uti sties Inc. Plaintiff Civil Action - In Law vs No. 9/^ ??lO4 ?uC Tu«? Dawn Woolingham 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, Dawn Woolingham, is an adult individual residing at 6 W. Locust Street, Mechanicsburg, PA 17055. COUNT 1 UGI Utilities Inc. vs. Dawn Woolingham 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 Dawn Woolingham. 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. 519U2 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. 1 1 WHEREFORE, there is now due and owing from the Defendant to 1 the Plaintiff the following sums for which Plaintiff demands !! judgment against the Defendant: Amount Past Due: $ 1058.51 Court Costs: $ 50.00 Service Costs: $ 45.50 TOTAL $ 1154.01 Respectfully submitted, Krzywicki DATED: May 4, 1999 By: sociates 1 sh ny Interplex P. ox 505 New Hope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 VERIFICATION I, 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: 5-I M9 BY: ?? ? Cyn hia E. Coffin 519U2 STATEMENT OF ACCOUNT Dawn Woolingham established the following accounts with UGI Utilities Inc, with the following balances and charges: Account Number / Acct Type Service to: Balance Service Address 219-726-9379-55 G $1058.51 6 W. Locust Street Mechanicsburg, PA 17055 Total Delinquent Balance: $1.058.51 EXHIBIT A i i ?oj {C Cl. ? 1 ?1 r Diu ?„ fT: v ai V v ^I y ?? ? ? 'mob SHERIFF'S RETURN - REGULAR CASE NO: 1999-03406 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES I VS. WOOLINGHAM DAWN SHANNON SUNDAY , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT IN was served upon WOOLINGHAM DAWN the defendant, at - 9:59 HOURS, on the 9th day of June 1999 at 6 WEST LOCUST STREET MECHANICSBURG, PA 17055 CUMBERLAND County, Pennsylvania, by handing to DAWN WOOLINGHAM a true and attested copy of the _NOTICE AND COMPLAINT IN together with ARBITRATION and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00 Service 6.0 Affidavit .000 Surcharge 8.00 77,, T. I'nommas ru it , Sheriff ?0G6/113CKI & ASSOC 1999 by epu eri 19. A.D. Sworn and subscribe to before me this //G'" day of u,,.._... In the Court of Common Please of Cumberland County, Pennsylvania ® , UGI Utilities Inc. Plaintiff VS. Dawn Woolingham Defendant Civil Action - In Law No. 99-3406 Arbitration PRAECIPE TO DISCONTINUE To the Prothonotary: Plaintiff, UGI Utilities Inc., hereby withdraws and discontinues the above- captioned matter, without prejudice, pursuant to Pa. R. Civ. P. 229. Krzywicki and Associates Dated: July 8, 1999 By: Antho P. 1 Net ' y Interplex PO o 505 New Hope, PA 18938 (609) 397-7200 Attorney for Plaintiff Attorney I.D. 23754 w0 - C7-. Q En U w