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Home My WebLink About99-03960 i 1 C? ? l 572U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Uti sties Inc. Plaintiff Civil Action - In Law vs No. Kimberly A. Campbell 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 twentyf20) 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 end 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 512U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Kimberly A. Campbell Defendant Civil Action - In Law No. 99• 9960 Cu,d 7--. 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, Kimberly A. Campbell, is an adult individual residing at 6A Boeing Road, New Cumberland, PA 17070. L COUNT 1 UGI Utilities Inc. vs. Kimberly A. Campbell 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 Kimberly A. Campbell. 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. 3 532U2 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: $ 1283.90 Court Costs: $ 45.50 Service Costs: $ 50.00 TOTAL $ 1379.40 Respectfully submitted, Krzywi DATED: June 22, 1999 By: Associates J;i 1 esh my Index P.O ox 505 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 unsworn falsification to authorities. UGI Utilities, Inc. Dated: 6I'7I m BY: Each ? Cynyn tia E. Coffin 532U2 STATEMENT OF ACCOUNT Kimberly A. Campbell established the following accounts with UGI Utilities Inc. with the following balances and charges: Account Number / Acct Type Service to: Balance Service Address 203-250-2700-23 G $1283.90 11 Lewis Lane Enola, PA 17025 Total Delinquent Balance: $1283.90 EXHIBIT A a ? ° Ct SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1999-03960 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS. CAMPBELL KIMBERLY A 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: CAMPBELL KIMBERLY A but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania. to serve the within NOT & COMPLAINT IN ARBITRATION On July 21st 1999 this office was in receipt of the attached return from YORK County, Pennsylvania. Sheriff's Costs: So answe Docketing 18.00 /?/ Out of County 9.00 Surcharge 38.0000 omas ine,/ 5 ri DEP. YORK CO Sb'T4U KR7YWZCKI & ASSOCIATES 07M 1999 Sworn and subscribed to before me this ,y /".}- day of 19 ?9 A. D. • .cO i0 ?r COUNTY OF YORK OFFICE OF THE SHERIFF S 717)1771 960 L 28 EAST MARKET ST, YORK. PA 17401 SHERIFF SERVICE INSTRUCTIONS PLEASE TYPE ONLY LINES 7 TO 2 PROCESS RECEIPT, and AFFIDAVIT OF RETURN O NOT DETACH ANY COPIES.' UGI Utilities, Inc:. 3. DEFENDANT/S/ Kimberly A. Campbell SERVE 5. NAME OF INDIVIDUAL, C Kimberly A. Campbell 6. ADDRESS (STREFT OR RFD WITH BOX NUMBER. APT NO., CITY, BORO, TWP., STATE AND ZIP CODE AT 6A Boeing Road, New Cumberland, PA 17070 7. INDICATE SERVICE: Q PERSONAL O PERSON IN CHARGE GYDE-tUTIZE Culit>'REITTlfAfind D 1ST CLASS MAIL O POSTED OOTHER NOW 19 _ I, SHERIFF OF OUN , P o hereby d he sheriff of York COUNTY to exec a r ccgding to law. This deputation being made at the request and risk of the plaintiff. T ADVANCE FEE PD BY CUMBERLAND COUNTY SHERIFF NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN -Any deputy sheriff levying upon or allaching any proponytuntler within TO may leave same without a watchman. In custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the pan of 90 deputy or the sheriff to any plaintiff herein for any loss, destruction. or removal of any property balers sheriffs sale thereof. 9. TYPE NAME AND ADDRESS Of ATTORNEYIORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER 11. DATE FILED Anthony P. Krzywicki, Esq. B00- 296-2103 6/28/99 1 h1 H T I- 1 D n P y ri _ns Nu., Ur DA 100]1] Cumberland Countv Sheriff Notice & Complaint aer.Lo,n% = p m rn o 0 n m -0 to < 3 a=o M a 1.30A 011 clio) 18.00 112.401 130.40 I 2.00 35. Advance Costs 36. Service Costs 37. Notary Con. 38. Mileage/POSlage/N.F. 31. 32.40 1$42.60 9 42. day of 43. AUKNUWLEUGE HEUbIY I UP I HI, SHEHIFYJ HE I UHN 51UNAT UHL 151 IF AUTHORIZED ISSUING AUTHORITY AND TITLE RITE - Issuing Authority 2. PINK - Attorney 3. CANARY - Sheriff's Office 4. BLUE - Sheriff's Office 13.1 acknowledge receipt of the W61 SIUHAI UHL Ur AU mVHIZeD CLERK 14. Dale Receivetl 76. Expiratisn/ Ida or complehTl as indicated above. B. Feeser 7/6/99 7ratio 16.HOW SERVED: PERSONAL( ) RESIDENCE ( ) POSTED( ) POE ( ) SHERIFF'S OFF ( ) OTHER SEE REMARKS 532U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Uti sties Inc. Plaintiff (Civil Action - In Law vs INO. 99-3960 CV Kimberly A. Campbell Defendant ARBITRATION ...%.....t...%........%... PRAECIPE FOR JUDGMENT AGAINST DEFENDANT FOR FAILURE TO PLEAD To the Prothonotary: COUNT 1 UGI Utilities Inc. vs. Kimberly A. Campbell Kindly and default ?Defendant, Kimberly A. Campbell U for failure to plead to Plaintiff's Complaint as follows: Amount Past Due: $ 1283.90 Court Costs: $ 45.50 Service Costs: $ 50.00 TOTAL $ 1379.40 together with interest thereon from the date of judgment forward and all costs of this action. 532U2 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. The true and correct address of the Defendant, Kimberly A. Campbell, is 6A Boeing Road, New Cumberland, Cumberland County, PA 17070. Krzywicki alfdj Associates DATED: September 14, 1999 By: 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 1 Ne am Inter?e? P.O. Bo 505 New e, PA 18938 CASE NO: 1999-03960 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS. CAMPBELL KIMBERLY A 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: CAMPBELL KIMBERLY A but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania. to serve the within NOT & COMPLAINT IN ARBITRATION On July 21st, 1999 this office was in receipt of the attached return from YORK County, Pennsylvania. Sheriff's Costs: So answers: Docketing 18.00 ! Out of County 9.00 i Surcharge 8.00 R. noma ine„ eri DEP. YORK CO 32.40 S'o T-40 KRZYWICKI & ASSOCIATES 07/21/1939 Sworn and subscribed to before me this day of 19 A. D. o no ary V 532U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Uti sties Inc. Plaintiff vs Kimberly A. Campbell Defendant .................. Civil Action - In Law No. 99-3960 CV ARBITRATION The undersigned hereby certifies that written notice of intention to file a praecipe for entry of judgment by default against the defendant, Kimberly A. Campbell, 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. DATED: September 7, 1999 Krzywicki an ssociates By: Anthony zywic i 1 Nesha i Interplex P.O. Bo kl-S 05 New Hope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 531117 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff Civil Action - In Law vs Kimberly A. Campbell Defendant No. 99-3960 CV ARBITRATION NOTICE TO: Kimberly A. Campbell 6A Boeing Road New Cumberland, PA 17070 Date: August 16, 1999 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.7E ony rz iCki 1 Neshaminy Interplex P.O. Box 505 New Hope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 POSTAL SERVICE_ CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIQf/AL MAIL. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Fiscal, Krzywicki & Associates P.O. Box 505 - New Hope, PA 18938 - Om Pleee or ordinary mail addressed to: '7 0 \ ? I 1 rnl _ ?"1'? PS Farm 3817, Mar. 1989 532U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff Civil Action - In Law vs Kimberly A. Campbell Defendant ........%....,......, No. 99-3960 CV ARBITRATION AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY COUNTY OF HUNTERDON ss. 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, Kimberly A. Campbell, 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, Kimberly A. Campbell, is more than 18 years of age and currently resides at 6A Boeing Road, New Cumberland, PA 17070. 3. I have ascertained the above information by personal investigation and make this affidavit with due authority. Sworn to and subscr' d before me this 7 y of a tem er 1999 Notary u is MICHELLE PYATT NOTARY PUBLIC OF NEW JERSEY MY COMMISSION EXPIRES JULY 9. 2002 CT- [L. ? Y pp C?l ii Q J O ?o