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HomeMy WebLinkAbout99-0715711h u y a M J Ch 2 .e P ,j • ',ti a ?. 720U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Andrea L. Foster Defendant C No. ivil Actio?nJ/- In Law, .' 0 1 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 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 r; ^? 72GU2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Uti sties Inc. Plaintiff vs Andrea L. Foster Defendant Civil Action - In Law No. %9- y/ 57 ?u L? Tt 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 i 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, Andrea L. Foster, is an adult individual residing at 227 S. Pitt Street, Carlisle, PA 17013. COUNT 1 UGI Utilities Inc. vs. Andrea L. Foster 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 Andrea L. Foster. 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. 'l2LV2 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: $ 1313.34 Court Costs: $ 45.50 Service Costs: $ 50.00 TOTAL $ 1408.84 Respectfully submitted, Associates DATED: November 8, 1999 By: Ant ny P. xrzywicxi 1 shaminy Interplex P Bo w pe, P 18938 0--296-2103r torney foPlaintiff Attorney I.D. 23754 C?? 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: it'd?C11 BY: Cynthia E. Coffin reau2 STATEMENT OF ACCOUNT Andrea L. Foster established the following accounts with UGI Utilities Inc. with the following balances and charges: Account Number / Acct Type Service to: Balance Service Address 208-764-1368-55 G $1313.34 227 S. Pitt Street Carlisle, PA 17013 Total Delinquent Balance: $1313.34 EXHIBIT A a': ? Gl Mll CJ Ol U% O SHERIFF'S RETURN - NOT FOUND I: CASE NO: 1999-07157 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND UGI UTILITIES INC VS FOSTER ANDREA L R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT FOSTER ANDREA L unable to locate Her in his bailiwick COMPLAINT IN ARBITRATION , but was He therefore returns the , NOT FOUND as to the within named DEFENDANT FOSTER ANDREA L ADDRESS STATED IS NOT VALID, ALTERNATE ADDRESS NOT PROVIDED PRIOR TO EXPIRATION DATE OF 12124/99 . Sheriff's Costs: So answ _ Docketing 18.00 Service 3.10 NOT FOUND RETURN 5.00 R. Thomas Kline Surcharge 8.00 Sheriff of Cumberland County .00 34.10 KRZYWICKI & ASSOCIATES 01/04/2000 Sworn and subscribed to before me this .7*7 CL day of ,:7a-L,o A. D. ?2 ?7'1 OCR tiC/ Pro notary 72GU2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Uti sties Inc. Plaintiff vs Andrea L. Foster Defendant Civil Action - In Law No. l4 !6s/ ARBITRATION i COMPLAINT NOTICE You have been sued in court. If you wish to defend against the claims set forth in tha 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 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 impprtant to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT WAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUP WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 (717) 249-3166/(800) 990-9108 f T"5 V!17 !. IS A a CG" .i3CT COPY. '?anmml?sTPC41Y ii6ng TRW DOPY nom REooW IY T wh®rW, I here unW set my how i71d yOv011 4,cafl( ' , ft. , ma r7 72GU2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Andrea L. Foster Defendant Civil Action - In Law 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, Andrea L. Foster, is an adult individual residing at 227 S. Pitt Street, Carlisle, PA 17013. t COUNT 1 UGI UtilitiesInc• vs. Andrea L. Foster 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 Andrea L. Foster. 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. i 726U2 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: $ 1313.34 Court Costs: $ 45.50 Service Costs: $ 50.00 TOTAL $ 1408.84 Respectfully submitted, Krzywicki and Associates DATED: November 8, 1999 By: Anthony P. Krzywic i 1 Neshaminy Interplex P.O. Box 505 New Hope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 11 - 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: S' BY: Cynthia E. Coffin E _-A 72GU2 STATEMENT OF ACCOUNT Andrea L. Foster established the following accounts with UGI Utilities Inc. with the following balances and charges: Account Number / Acct Type Service to: Balance Service Address 208-764-1368-55 G $1313.34 227 S. Pitt Street Carlisle, PA 17013 Total Delinquent Balance: $1313.34 EXHIBIT A c'i1r?, -Q6 ?S[? o ri,'.' . pff,._.. 5`?1????ta d ?.i G 1? ?? ?? ..? 726U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Uti sties Inc. Plaintiff vs Andrea L. Foster Defendant Civil Action - In Law No. 99-7157-CV ARBITRATION PRAECIPE TO REINSTATE COMPLAINT To the Prothonotary: Kindly reinstate the Complaint in the above-captioned Civil Action for an additional thirty days. DATED: January 24, 2000 Krzywicki 64d Associates By: / - Anthony P. Krzywic i 1 Neshaminy Interplex P.O. BoV505 New Hope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 ?- rc c? ? ; - : _? -- LL ;;; `-; :) iJ , SHERIFF'S RETURN - NOT FOUND CASE NO: 1999-07157 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND UGI UTILITIES INC VS FOSTER ANDREA L R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT FOSTER ANDREA L but was unable to locate Her in his bailiwick. He therefore returns the .OMPLAINT IN ARBITRATION-, NOTICE the within named DEFENDANT , FOSTER ANDREA DEFT. NO LONGER LIVES AT ADDRESS STATED, , NOT FOUND , as to LEFT NO FWDG AT P.O., RETURN NOT FOUND AS PER ATTY. Sheriff's Costs: So swe Docketing 18.00 Service 4.34 NOT FOUND RETURN 5.00 R.'Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 37.34 KRYZWICKI & ASSOCIATES 03/03/2000 Sworn and subscribed to before me this -) I -J-J- day of .,7c-vo A.D. Pr.t onotary 92602 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Uti sties Inc. Plaintiff vs Civil Action - In Law No. qci --7157-C.? Andrea L. Foster Defendant ARBITRATION COMPLAINT NOTICE You hav- been sued :n court. It 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 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 TARE 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 'r'?T 7!81:^, T::hJ IS T COPY. ?''?^Y or ^ _ Filing TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and tits seal of said Court It Carlisle, Pa. thonotary T_'6u2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Andrea L. Foster Defendant Civil Action - In Law 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, Andrea L. Foster, is an adult individual residing at 227 S. Pitt Street, Carlisle, PA 17013. COUNT 1 UGI Utilities Inc. vs. Andrea L. Foster 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 Andrea L. Foster. 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 her=in 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. 726u2 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 fell-wing sums for which Plaintiff demands judgment against the Defendant: Amount Past Due: $ 1313.34 Court Costs: $ 45.50 Service Costs: $ 50.00 TOTAL $ 1408.84 Respectfully submitted, Krzywicki and Associates DATED: November 8, 1999 By: Anthony P. Krzywicki 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 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, f have been unable, after reasonable investigation, to ascertain which are true. but I have knowiedge or information sufficient to form a belief that one of them is true. This statement is made subject to the penalties of 13 P.A. C.S. Section 4904, relating to unswom falsification to authorities. UGI Utilities, Inc. Dated: 11 /1(/`/ f BY: 64/t& F I , vi Cynthia offin' 726U2 STATEMENT OF ACCOUNT Andrea L. Foster established the following accounts with UGI Utilities Inc. with the following balances and charges: Account Number / Acct Type Service to: Balance Service Address -------------------------------------------------------------------------------- -------------------------------------------------------------------------------- 208-764-1368-55 G $1313.34 227 S. Pitt Street Carlisle, PA 17013 Total Delinquent Balance: $1313.34 EXHIBIT A j ?a N J\, ?iFFt':' • ?• ??'n,iF ?:lj? FED