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HomeMy WebLinkAbout99-07789i ,U is Z N r6 t 1 80 3U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs civil Action,- In Lawn 1 C I? No. Rrl - 7? T (2tc?fl. Eugenia L. Neidigh 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 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 e03U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Eugenia L. Neidigh Defendant Civil Action - In Law No. q q- 77 r 9 e,;, e -7-z,, 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, Eugenia L. Neidigh, is an adult individual residing at 3090 Spring Road, Carlisle, PA 17013. A.,.c,K 4r I. ?r i COUNT 1 UGI Utilities Inc. vs. Eugenia L. Neidigh 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 Eugenia L. Neidigh. 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 I the benefit of said Defendant. I 1 ' v ' na3uz 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: TOTAL $ 1034.53 $ 1034.53 Respectfully submitted, Krzywicki aannd` Associates DATED: December 15, 1999 By: n•SYBOX 503?? New H ope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 VERIFICATION 1, Cynthia E. Collin, an employee of UGI Utilities, Inc., being authorised 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 1 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. G n /{?' Dated: 12\15 1 BY: O M Nh F Cyn iia E. Coffin ?.Y i> r- f' f I t" eo3u2 STATEMENT OF ACCOUNT Eugenia L. Neidigh established the following accounts with UGI Utilities Inc. with the following balances and charges: Account Number / Acct Type Service to: Balance Service Address 209-765-2476-59 G $1034.53 159 S. Bedford Street Carlisle, PA 17013 Total Delinquent Balance: $1034.53 EXHIB r-. f L f ` __- v! O ? C. ' ?' Vl Q a o O c. SHERIFF'S RETURN - REGULAR i' CASE NO: 1999-07789 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS NEIDIGH EUGENIA Sheriff or Deputy Sheriff of DAVID MCKZNNEY ' Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT IN ARBITRATION was served upon the NEIDIGH EUGENIA L at 0010:22 HOURS, on the 7th day of January 2000 DEFENDANT at 3090 SPRING ROAD by handing to CARLISLE, PA 17013 EUGENIA L. NEZDIGH-SWARTZ a true and attested copy of COMPLAINT IN ARBITRATION together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: 00 18 Docketing . Service 0 3,.11 Affidavit 0 Surcharge 10.00 00 31.10 Sworn and Subscribed to before m-e/ this 1.4.4' day of //11 a2dy(? ,,A. A.D. lw.e L t? ?? Prothonotary So Answers: R. Thomas Kline 01/10/2000 KRZYWICKI & ASSOC. By : A ??iy?v?.litiv - Deputy Sheriff -V e..?anwo KRZYIVICKI & ASSOCIATES Anthony P. Krzyvickd Esquire John L. Shearhurn, Esqubr P. 0. Box 505 Netiv [lope, PA 18938 (609) 397-9014 Attorneys fr Plaintiff Attorney L D. 23754126852 ------------------ ___ -------------- UGI Utilities Inc. Plaintiff vs. Eugenia L. Neidigh Defendant(s) --------------------------------- Court of Common Pleas Cumberland County 99-7789 JUDGMENT BY STIPULATION TO THE PROTHONOTARY: Kindly enter judgment in favor of the plaintiff, UGI Utilities, Inc., and against the defendant(s), Eugenia L. Neidigh, in the amount of $1,034.53, together with interest at the contract rate from this date forward. DATED: February 16, 2000 Eu iia L. Nei ig at 3090 Spring Road Carlisle, PA 17013 KRZYWICKI BY: An ho Attorney fc ASSOCIATES ff g(i3t.?2 I ?- 803U2 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse . Carlisle, Ph 17013 Lawrence E. Welker Prothonotary TO: Eugenia L. Neidigh 3090 Spring Road Carlisle, PA 17013 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Ut> itiesPlaintiff Civil Action - In Law vs Eugenia L. Neidigh Defendant No. 99-7789 CV ARBITRATION NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding a? indicated btilow•? 1 P'r-`71o'thon?otary ( ) Judgment by Default (XX) Money Judgment ( ) Judgment in Replevin ( ) Judgment for Possession ( ) Judgment on Award of Arbitration ( ) Judgment on Verdict ( ) Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEY FOR THE FILING PARTY: Anthony P. Krzywicki Krzywicki and Associates 1 Neshaminy Interplex P.O. Box 505 New Hope, PA 18938 800-296-2103 Attorney I.D. N0.23754 11 1 T A Kill. _. ?Z C%j CV I:z V?O C C) j . Ci V o i' I j { i