HomeMy WebLinkAbout01-6595In the Court of Common Pleas of Cumberland County, Pennsylvania
UGI Utilities Inc.
Plaintiff
VS.
Kathy Coffey
Defendants
Civil Action - In Law
ARBITRATION
COMPLAINT
NOTICE
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claim or relief requested by the plaintiff. You may
lose money or property or other rights important to
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Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013-3387
(717) 249-3166/(800) 990-9108
In the Court of Common Pleas of Cumberland County, Pennsylvania
UGI Utilities Inc.
Plaintiff
VS.
Kathy Coffey
Defendants
Civil Action - In Law
No.
ARBITRATION
COMPLAINT
1. This is an action by plaintiff, UGI Utilities Inc. to
recover damages from defendant(s) arising out of a debt
defendant(s) owes to plaintiff by virtue of an 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.
3. Defendant, Kathy Coffey, is an adult individual
residing at 111 2nd Street, Apt. 4, 2F, West Fairview, PA 17025.
COUNT 1
UGI Utilities Inc. vs.
Kathy Coffey
5. At all times 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.
6. Plaintiff supplied utility service to Kathy Coffey.
7. At the present time, defendant(s) are in default and
have an 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.
8. The utility service which was provided by the plaintiff
to the defendant(s) aforesaid, was received, accepted, and
utilized for the benefit of said defendant(s).
9. With the knowledge, and approval of defendant(s), her
daughter, Samantha Coffey, opened an account for gas service.
10. Gas service was provided to the defendant(s) under 23
Pa. C.S.A. sec 4102 for the support and maintenance of the family
of the defendant(s).
11. Plaintiff made demand on defendant(s) to repay the sums
then due and owing to plaintiff, but defendant(s) have refused
and continue to refuse to pay plaintiff.
12. Despite demands upon defendant(s) for payment by the
plaintiff, defendant(s) have failed and refused to pay plaintiff
the balance due and owing on said account(s).
13. Defendant(s) have been unjustly enriched by accepting
service without full payment.
WHEREFORE, there is now due and owing from the defendant(s)
to the plaintiff the following sums for which plaintiff demands
judgment against the defendant(s):
Amount Past Due:
Attorney Costs:
Court Costs:
Service Costs:
TOTAL
$1978.37
$ 25o.00
$
$
$2228.37
DATED:
October 5, 2001
Respectfully submitted,
Krzywicki and Associates
By:
Antny~..,~---R~zywicki
Attorney for Plaintiff
Attorney I.D. 23754
VERIFICATION
I, Aprille Beasley, an employee of UGI Utilities, Inc., being authorized to do so,
verify that the statements made in the foregoing pleadings are tree 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.
Dated:
BY:
UGI Utilities, Inc.
Aprl[[~ ~~
STATEMENT OF ACCOUNT
Kathy Coffey established the following accounts with UGI Utilities Inc. with the following balances and charges:
Account Number/ Acct Type Service to: Balance
Service Address
221-609-3666-15
111 2nd Street, Apt. 4, 2F, West Falrview, PA 17025
Ga / / $1978.37
Total Delinquent Balance: $1978.37
EXHIBIT A