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Home My WebLink About99-03961f i s .?. Ij ?d 1? .2? SI 1? I `+ V C• `? V V? ?`ap V 5s9U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Ut> sties Inc. Plaintiff Civil Action - In Law vs NO, W- _'9Q Beverly Stanford Defendant ARBITRATION 11111"111%1.11t' ................... 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 NAY 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 559U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff Civil Action - In Law vs Beverly Stanford Defendant No. jq. 9941 TQ,4-^ 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, Beverly Stanford, is an adult individual residing at 247 S. Spring Garden St., Carlisle, PA 17013. COUNT 1 UGI Utilities Inc. vs. Beverly Stanford 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 Beverly Stanford. 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. 559U2 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: $ 1028.47 Court Costs: $ 45.50 Service Costs: $ 50.00 TOTAL $ 1123.97 Respectfully submitted, Krzywic* ? d Associates DATED: June 22, 1999 By ?++ 1Vily Y. /W1CK1 1 esham' Int lex P O. c 505 N ope, 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 unworn falsification to authorities. UGI Utilities, Inc. Dated: U1%Attl BY: Q ow 7 ow' Cyn is E. Coffin 559U2 STATEMENT OF ACCOUNT Beverly Stanford established the following accounts with UGI Utilities Inc. with the following balances and charges: Account Number / Acct Type Service to: Balance Service Address 216-774-8371-79 G $1028.47 231 Lincoln Street, IF Carlisle, PA 17013 Total Delinquent Balance: $1028.47 EXHIBIT A r Crr .J 10 V ?(? SHERIFF'S RETURN - REGULAR CASE NO: 1999-03961 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS. STANFORD BEVERLY KATHY CLARKE 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 STANFORD BEVERLY _ the defendant, at 11:05 HOURS, on the 15th day of July 1999 at RODEWAY INN # 425 CARLISLE, PA 17013 CUMBERLAND County, Pennsylvania, by handing to BEVERLY STANFORD a true and attested copy of the NOTICE AND COMPLAINT IN together with ARBITRATION and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So answer Docketing 18.00 , Service 3.100 Affidavit .00 -%?Surcharge 8.00 R- Tiulliatlt - $;?9.lu-07Z16/ I1999& ASSOCIATES Q?trty-srsUrrfr- Sworn and subscribed to before me this A °= day of(_ 19A.D. .Dp? 1/ ??roLnonoza*-41L 559U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI utilities Inc. Plaintiff Civil Action - In Law vs No. 99-3961 CV Beverly Stanford (ARBITRATION Defendant To the Prothonotary: PRAECIPE FOR JUDGMENT AGAINST DEFENDANT FOR FAILURE TO PLEAD COUNT 1 UGI Utilities Inc. vs. Beverly Stanford Kindly enter default judgment in favor of Plaintiff, UGI Utilities Inc. and against Defendant, Beverly Stanford for failure to plead to Plaintiff's Complaint as follows: Amount Past Due: $ 1028.47 Court Costs: $ 45.50 Service Costs: $ 50.00 TOTAL 1123.97 together with interest thereon from the date of judgment forward and all costs of this action. b'IU] 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, Beverly Stanford, is 247 S. Spring Garden St., Carlisle, Cumberland County, PA 17013. Krzywicki and Associates DATED: September 14, 1999 By: 1 Anthony' P. rzyw c i - 1 Nes ' y Interplex P.O. 505 New Hope, PA 18938 800-296-2103 Attorney for Plaintiff: Attorney I.D. 23754 SHERIFF'S RETURN - REGULAR ?J / IOC CASE NO: 1999-03961 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS. STANFORD BEVERLY KATHY CLARKE , 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 STANFORD BEVERLY the defendant, at 11:05 HOURS, on the 15th day of July 1999 at RODEWAY INN # 425 CARLISLE, PA 17013 CUMBERLAND County, Pennsylvania, by handing to BEVERLY STANFORD a true and attested copy of the NOTICE AND COMPLAINT IN together with ARBITRATION and at the same time directing Her attention to the contents thereof Sheriff's Costs: So answers: Docketing 18.00 Service 3.10 -e e Affidavit .00 Surcharge 8.00 omas _.e, eriZ T7 0-iL4ZYWICKI & ASSOCIATES 07/16/1999 by / . yiaputy 5YIerirz i Sworn and subscribed to before me this day of 19 A.D. r n ary 559U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff Civil Action - In Law vs Beverly Stanford Defendant No. 99-3961 CV ARBITRATION The undersigned hereby certifies that written notice of intention to file a praecipe for entry of judgment by default against the defendant, Beverly Stanford, 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. Associates DATED: September 7, 1999 By: 1 Neh tiny Interplex P.0 ox 505 Ne ope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 55902 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff Civil Action - In Law vs Beverly Stanford Defendant No. 99-3961 CV ARBITRATION NOTICE TO: Beverly Stanford 247 S. Spring Garden St. Carlisle, PA 17013 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: ony rzywic i 1 Neshaminy Interplex P.O. Box 505 New Hope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 PRMAY dt OVIDE fS DOMESTIC AND INTERNA TIONA V INSURANCE -POSTMASTER ?,a 1g DOES NOT A.C. zywicki & Associates' ° o O. Box 505 i w Hope, PA 189' dinary mall ddreee.d m: Mar. 1989 r r il. I y I ?•? 1 'rI Im, lil 55902 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Beverly Stanford Defendant AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY COUNTY OF HUNTERDON Civil Action - In Law No. 99-3961 CV ARBITRATION 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, Beverly Stanford, 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, Beverly Stanford, is more than 18 years of age and currently resides at 247 S. Spring Garden St., Carlisle, PA 17013. 3. I have ascertained the above information by personal investigation and make this affidavit with due authority. Sworn to and subs me this 7 Aay/ of 199 MICHELLE WATT NOTARY PUBLIC OF NEW JERSEY MV COMMISSION EXPIRES JULY 9, 2002 r C? ' s CU j ? M r. N a. v, it 1 o ?°