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Home My WebLink About99-07158 I> •y S v l sH L 6zi s tl%. 741U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI utilities Inc. Plaintiff Civil Action (- In Law vs No. q - y //c)-p Nina L. Brown 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 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 ehe 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 lase 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 741U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff (Civil Action - In Law vs No. 1?9 • 71.5 ac -Zx Tto - Nina L. Brown 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, Nina L. Brown, is an adult individual residing at 2211A Cedar Run Drive, Camp Hill, PA 17011. i? I- r. w 4 COUNT 1 UGI Utilities Inc. vs. Nina L. Brown 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 Nina L. Brown. 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. l t;r 741U2 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: $ 2088.35 Court Costs: $ 45.50 Service Costs: $ 50.00 TOTAL $ 2183.85 Respectfully submitted, Associates DATED: November 8, 1999 By: 1 N hamin n erplex P.O. Box o!D 05 Ne Ho , PA 1 80 6-2103 Attorney for Plaintiff Attorney I.D. 23754 VBRIPICATION I, Cynthia G 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: BY: d1Mt, r dq#a2 Cy hia E. Coffin 7-1 1U2 STATEMENT OF ACCOUNT Nina L. Brown established the following accounts with UGI Utilities Inc. with the following balances and charges: Account Number / Acct Type Service to: Balance Service Address 204-263-7485-92 G $2088.35 334 Woodbine Street Harrisburg, PA 17110 Total Delinquent Balance: $2088.35 EXHIBIT A L j i cn U 4? CL4 V ?cr? J) SHERIFF'S RETURN - REGULAR CASE NO: 1999-07158 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS. BROWN NINA L CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT IN ARBITRATION was served upon BROWN NINA L the defendant, at 11:46 HOURS, on the 6th day of December 1999 at 2211 A CEDAR RUN DRIVE CAMP HILL, PA 17011 CUMBERLAND County, Pennsylvania, by handing to NINA L. BROWN a true and attested copy of the COMPLAINT IN ARBITRATION together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 So answers- Service 9.92 ? ? Affidavit 00 . Surcharge 8.00 omas ine, eri 2- ANTHONY KRZYWICKI 12/07/1999 by epu eri Sworn and subscribed.to before me this /` day of L 09 A.D. C nCwL,?. ? n1y r ono ary I 741 W In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Plaintiff vs Nina L. Brown Defendant Civil Action - In Law No. 99-7158-CV ARBITRATION PRAECIPE FOR JUDGMENT AGAINST DEFENDANT FOR FAILURE TO PLEAD To the Prothonotary: COUNT 1 UGI Utilities Inc. vs. Nina L. Brown Kindly enter default judgment in favor of Plaintiff, UGI Utilities Inc. and against Defendant, Nina L. Brown for failure to plead to Plaintiff's Complaint as follows: Amount Past Due: TOTAL $ 2183.85 $ 2183.85 together with interest thereon from the date of judgment forward and all costs of this action. 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. 74 1u2 2. The true and correct address of the Defendant, Nina L. Brown, is 2211A Cedar Run Drive, Camp Hill, Cumberland County, PA 17011. Krzywicki 4xd)Associates DATED: January 25, 2000 By: 1 N sham: lex P c 505 N. ope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 Fl- ?, jF ` ; .? { !: ? ?, j ?' f i:! ? ? . r tV ., ?i i.?. __ ....: ?:::.:. c =- ? i 7 ?. ' J ? Ci ? ?? (T; G.. JiU ?, ? C?l_ c• U 11 ? i r f 1 1 'n ? , SHERTFF'S RETURN - REGULAR CASE NO: 1999-07158 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS. BROWN NINA L CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of CUMBERLAND Countv, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT IN ARBITRATION was served upon BROWN NINA L the defendant, at 11:46 HOURS, on the 6th day of December 1999 at 2211 A CEDAR RUN DRIVE CAMP HILL, PA 17011 CUMBERLAND County, Pennsylvania, by handing to NINA L. BROWN a true and attested copy of the COMPLAINT IN ARB_TTRATIODi together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00 Service 9.92 Affidavit .00 r , Surcharge 8.00 n. nomas ine, miner ?7.7L ANTHONY KRZYWICKI 12/07/1999 by epu 1 ?ner::?? Sworn and subscribed to before me this day of 19 A. D. Prothonotary .SC_/ 74 tut In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Uti sties Inc. Plaintiff (Civil Action - In Law vs No. 99-7158-CV Nina L. Brown Defendant ARBITRATION ,,,,,,,,,,,,,,,%. NOTICE TO: Nina L. Brown 2211A Cedar Run Drive Camp Hill, PA 17011 Date: December 30, 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:_ 151 nt ony rzywicki 1 Neshaminy Interplex P.O. Box 505 New Hope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 ,B r• Z. otu °J V U u Recei, Klzywicki & Associates P.O. Box SOS New Hope, PA X18938; ; Ons oiaee Of ortlinery mall atltln wYaro: ; .\ PS Form 3817, j` -. r • ? G {- _ ':=', cv _ u-! -- ..- Li-.- L. dal:.'. /t;1 ' li c ?_ , t 1i1? ? _ •,1iiJ ? ([. lY _7 i': ' V (J !?Y ,. ,,:: 7410 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Nina L. Brown Defendant ,,,,,,,,,,,,,,,,,,,,,,, Civil Action - In Law No. 99-7158-CV ARBITRATION The undersigned hereby certifies that written notice of intention to file a praecipe for entry of judgment by default against the defendant, Nina L. Brown, 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. Krzywicki A Associates DATED: January 25, 2000 By: 1 aminy nterplex P. Box 505 New Hope, PA 38 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 c? _,. -? ? , c: -n = ' ...t .:, ?; ,'? _ . _ i; ;` ,7 = •TJ ;.';= i _ _ . n y' 4 ' J < ??I '? 741U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Uti sties Inc. Plaintiff Civil Action - In Law vs Nina L. Brown Defendant No. 99-7158-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, Nina L. Brown, 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, Nina L. Brown, is more than 18 years of age and currently resides at 2211A Cedar Run Drive, Camp Hill, PA 17011. 3. I have ascertained the above information by personal investigation and make this affidavit with due authority. Sworn to and subscribed before MICHELLE PYATT NOTARY PUBLIC OF NEW JERSEY MY COMMISSION EXPIRES JULY 9, 2002 C p U G? r I (= ?' v Yt? •F^:1 KRZYVICKI d• ASSOCIAI EN Anthony P. Krsywicki, Esquire John L. Shearhurn, Esquire P.O. /lox 505 New Hope, PA 18938 (215)802-4390 Allnrneyfr PhJnlif' Alrorney I. D. 23 754 /26852 ------------------------------- UGI Utilities Inc. Plaintiff VS. Court of Common Pleas Cumberland County Civil Action No. Nina L. Brown Defendant(s) ------------------------------- 99-7158-CV PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly mark the Judgment against the defendant(s) satisfied and from the record upon payment of your costs only. DATED: August 17, 2000 BY: KRZYWICKI & ASSOCIATES ?--? Cam'. ?? ?? '- n ? i .t }?. 1= __ _ J:1 L' ' ?? } n :.? - ' , ? h : i _ . i? n_ _? _. iJ