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Home My WebLink About01-65961903U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff VS William L. Martin Defendant Civil Action - In Law No. 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 sei~;ed, 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 m~ney 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 p~YPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE T~E OFFICE SET FORT~ BELOW TO FIND OUT W}{ERE YOU C~%N GET LEGAL ~LP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 (717) 249-3166/(800) 990-910 1903U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs William L. Martin 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, William L. Martin, is an adult individual residing at 623 High Street, Enola, PA 17025. COUNT.1 UGI Utilities Inc. vs. William L. Martin 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 William L. Martin. 6. At the present time, Defendant accounts are in default and has outstanding balances due and owing Plaintiff as reflected on the attached Statement of Account 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. 1903U2 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: Court Costs: Service Costs: TOTAL $ 5789.13 $ 45.50 $ s0.00 $ 5884.63 Respectfully submitted, DATED: September 7, 2001 Krzyw~Associates By: / ~ _ ~. A~t~n~ P. 5rzywicKl W~9~North Su~an Road P.O. Box 50~ / New Hope, PDr-~18938 215-862-4390 Attorney for Plaintiff Attorney I.D. 23754 VERIFICATION I, James R. Gallagher, 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. Dated: UGI Utilities, Inc. Jam'eg R. Gallagher 1903U2 STATEMENT OF ACCOUNT William L. Martin established the following accounts with UGI Utilities Inc. with the following balances and charges: Account Number / Service Address 206-358-8432-14 G 125 S. 14th Street, iF Harrisburg, PA 17104 206-358-8296-21 G . 129 S. 14th Street, 3F Harrisburg, PA 17104 Acct Type Service to: Balance ===================================== $3868.61 / / / / $1920.52 Total Delinquent Balance: $5789.13 EXHIBIT A SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-06596 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND UGI UTILITIES INC VS MARTIN WILLIAM L R. Thomas Kline duly sworn according to law, inquiry for the within named defendant, MARTIN WILLIAM L ,Sheriff or Deputy Sheriff, who being says, that he made a diligent search and DEFENDANT but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT MOVED LEFT NO FORWARDING. ENOLA AND CAMP HILL POST OFFICES. , MARTIN WILLIAM L CHECKED WITH BOTH Sheriff's Costs: Docketing 18.00 Service 20.15 Not Found 5.00 Surcharge 10.00 .00 53.15 So answer~, j..~ ~ Sheriff of Cumberland County KRZYWICKI & ASSOC 2/lO/2OOl Sworn and subscribed to before me this /3~ day of ~ ~2~/ A.D. ~r&thonot ary