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HomeMy WebLinkAbout99-07790i u s" 1 7i: 8a,= In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Uti sties Inc, Civil Action - In Law Plaintiff .y T Cr vs No. Q Q [ 196 l U l,7EA'I Brenda A. Rohrer 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 twenty1201 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 :ours 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 J eoauz In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Uti sties Inc. Plaintiff vs Brenda A. Rohrer Defendant Civil Action - In Law ? ? No. 99. 779 3 &L y 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, Brenda A. Rohrer, is an adult individual residing at 60 E. Louther Street IF, Carlisle, PA 17013. i COUNT 1 UGI Utilities Inc. vs. Brenda A. Rohrer 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 Brenda A. Rohrer. 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. 00av2 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: $ 1292.55 TOTAL $ 1292.55 Respectfully submitted, DATED: December 15, 1999 By: Krzvwicki-and Associates 1 N amin Interplex Box 5 5 New Hope, P 8 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 I,i Y 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. BY: nAC-6, Dated: 1L\l7\?C? Cy Riia E. Coffin 80402 STATEMENT OF ACCOUNT I! Brenda A. Rohrer established the following accounts with UGI I1 Utilities Inc. with the following balances and charges: Acct Type Service to: Balance Account Number / Service Address __________________=_________------- $1292.55 206-762-3785-10 G 60 E. Louther Street 1F Carlisle, PA 17013 Total Delinquent Balance: $1292.55 EXHIBIT A ml? z ._ ? --- • Sri-.. ti' L(1 l.! ? _ V.iiJ 111111 ?1vJ r1 1 Vp 1 ? la? a SHERIFF'S RETURN - NOT FOUND CASE NO: 1999-07790 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND UGI UTILITIES INC VS ROHRER BRENDA A 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 ROHRER BRENDA A but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT IN ARBITRATION , CE NOT FOUND , as to the within named DEFENDANT , ROHRER BRENDA A DEFENDANT NO LONGER RESIDES AT ADDRESS STATED, LEFT. NO FWD. WITH P.O., BELIEVED TO BE IN N.C. Sheriff's Costs: So answers Docketing 18.00 Service 6.20 Not Found Return 5.00 R.R. Thomas ine Surcharge 10.00 Sheriff of Cumberland County .00 39.20 00/00/0000 Sworn and subscribed to before me this day of ,2v-u-v A. D. PiVot,honotary Baaua In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Civil Action - In Law No. QZ - / ! TO (2lUiL'ZC ? Brenda A. Rohrer 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 twenty120) 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 KAY 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 T" `.T T!!O WITSI!N IS .. ' t• TIECT COPY. t:x Party Filing TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and t'rRe sea) of said C t at Carlisle, Pa. TM dayof?, /L 19 Prothonotary NU•IU2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Uti hies Inc. Plaintiff ICivil Action - In Law vs No. Brenda A. Rohrer Defendant I 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, Brenda A. Rohrer, is an adult individual residing at 60 E. Louther Street IF, Carlisle, PA 17013. COUNT 1 UGI Utility'- enc. vs. Brenda A. Rohrer 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 Brenda A. Rohrer. 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. eaau2 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 DATED: December 15, 1999 $ 1292.55 $ 1292.55 Respectfully submitted, Krzywicki and Associates 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 i I} VERIFICATION 1. Cvnthia 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, [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. BY: Dated: 12 //S- AN Cyn hia E. Cofftt STATEMENT OF ACCOUNT Brenda A. Rohrer established the following accounts with UGI Utilities Inc. with the following balances and charges: 804U2 Account Number / Acct Type Service to: Balance Service Address 206-762-3785-10 G $1292.55 60 E. Louther Street 1F Carlisle, PA 17013 Total Delinquent Balance: $1292.55 EXHIBIT A I, aso 'OFFICE nC T"[fr?t_pG Jill 3 8 39 All '00 Q?D