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Home My WebLink About01-65971537U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Sondra Peel Defendant COMPLAINT Civil Action - In Law ARBITRATION 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 rmay 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 LANYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT ~{ERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 (717) 249-3166/(800) 990-910 1537U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Sondra Peel 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, Sondra Peel, is an adult individual residing at 436 N. Pitt Street, Carlisle, PA 17013. COUNT 1 UGI Utilities Inc. vs. Sondra Peel 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 Sondra Peel. 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. 1537U2 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 $ 1104.41 $ 45.50 $ 100.00 $ 1249.91 Respectfully submitted, DATED: November 14, 2001 Krzywic~Associates BY:Anth/y p. Krzywicki 49 ~orth S~an Road P. . B 0 . ~t ~gn6eQ2 ~ °o~ ~laintlf f 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: ~t[Iq[O[ BY: UGI Utilities, Inc. 1537U2 STATEMENT OF ACCOUNT Sondra Peel established the following accounts with UGI Utilities Inc. with the following balances and charges: Account Number / Acct Type Service to: Balance Service Address 213-769-4822-03 G / / $1104.41 436 N. Pitt Street Carlisle, PA 17013 Total Delinquent Balance: $1104.41 EXHIBIT A SHERIFF'S RETURN - CASE NO: 2001-06597 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS PEEL SONDP~A REGULAR JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PEEL SONDRA the DEFENDANT , at 1709:00 HOURS, at 98 GROVE ROAD CARLISLE, PA 17013 MISTY SNYDER, ROOMMATE on the 30th day of November , 2001 by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18 00 7 15 00 10 00 00 35 15 Sworn and Subscribed to before me this /_~ day of ~ J.~-~ 3~! A.D. ~/ ~rothonotary' So Answers: R. Thomas Kline 12/o2/ OOl KRZYWICKI & ASSOC tySheriff YVETTE KANE, Appellant V. ' : CUMBERLAND : COUNTY BOARD OF : ASSESSMENT APPEALS,: Appellee : IN THE COURT OF COMMON PLEAS OF CUIvlBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-6797 CIVIL TERM ORDER OF COURT AND NOW, this 24th day of January, 2002, upon consideration of the stipulation filed in the above matter on January 24, 2002, the hearing scheduled for March 28, 2002, is cancelled. BY THE COURT, //Mark S. Silver, Esq. P.O. Box 1152 Harrisburg, PA 17108 Attorney for Appellant ~5tephen D. Tiley, Esq. South Hanover Street Carlisle, PA 17013 Attorney for Appellee irc J.QiVesley 01~ ~ 5.//I 1537U2 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse * Carlisle, PA 17013 Curtis R. Long Prothonotary TO: Sondra Peel 436 N. Pitt Street Carlisle, PA 17013 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff VS Sondra Peel Defendant Civil Action - In Law No. 01-6597 CV ARBITRATION NOT I CE 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 as indicated below. (XX ( ( ( ( ( ( IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, ATTORNEY FOR THE FILING PARTY: Anthony P. Krzywicki Krzywicki and Associates 49 North Sugan Road P.O. Box 505 New Hope, PA 18938 800-296-2103 Attorney I.D. No.23754 Curtis R. Long Prothonotary Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings PLEASE'~CALL 1537U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff VS Sondra Peel Defendant Civil Action - In Law No. 01-6597 CV ARBITRATION PRAECIPE FOR JUDGMENT AGAINST DEFENDANT FOR FAILURE TO PLEAD To the Prothonotary: COUNT 1 UGI Utilities Inc. vs. Sondra Peel Kindly enter default judgment in favor of Plaintiff, UGI Utilities Inc. and against Defendant, Sondra Peel for failure to plead to Plaintiff's Complaint as follows: Amount Past Due: Court Costs: Service Costs: TOTAL $ 1104.41 $ 45.5o $ 1oo.oo $ 1249.91 together with interest thereon from the date of judgment forward and all costs of this action. 1537U2 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. 2. The true and correct address of the Defendant, Sondra Peel, is 436 N. Pitt Street, Carlisle, Cumberland County, PA 17013. DATED: March 5, 2002 Krzywic~ciates./ BY: tho P. 49 Ng~th)g~fgan Ro~d P.O / Bo~505 /__ Ne~H~e, PA 18~ 80~96-2103 Attorney for Plaintiff Attorney I.D. 23754 SHERIFF'S RETURN - REGULAR · CASE NO: 2001-06597 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS PEEL SONDRA JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PEEL SONDRA the DEFENDANT , at 1709:00 HOURS, on the 30th day of November , 2001 at 98 GROVE ROAD CARLISLE, PA 17013 by handing to MISTY SNYDER, ROOMMATE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 7.15 Affidavit .00 Surcharge 10.00 .00 35.15 Sworn and Subscribed to before me this day of Prothonotary So Answers: R. Thomas Kline 12/03/2001 KRZYWICKI & ASSOC / ×~dputy Sherzff 1537U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff VS Sondra Peel Defendant Civil Action - In Law No. 01-6597 CV ARBITRATION NOTICE TO: Sondra Peel 436 N. Pitt Street Carlisle, PA 17013 Date: January 25, 2002 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 151 Anthony P. Krzywlcki 49 North Sugan Road P.O. Box 505 New Hope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 1537U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff VS Sondra Peel Defendant Civil Action - In Law No. 01-6597 CV ARBITRATION The undersigned hereby certifies that written notice of intention to file a praecipe for entry of judgment by default against the defendant, Sondra Peel, 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. DATED: March 5, 2002 Krzywic~ociates BY:Anthon~P.J~r~i~ki 49 No/th/9~gan P.O ~BO~' 505 -- New/~e, PA 18938 800~296-2103 Attorney for Plaintiff Attorney I.D. 23754 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Sondra Peel Defendant Civil Action - In Law No. 01-6597 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, Sondra Peel, 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, Sondra Peel, is more than 18 years of age and currently resides at 436 N. Pitt Street, Carlisle, PA 17013. 3. I have ascertained the above information by personal investigation and make this affidavit ~ due authority. ~t h~~ywicki Sworn~o. and s~/bscrib~ fore / / ~_._../- ~qOTARY PUBLIC OF NEW JERO~ ~Y COMMISSION ~PIRES JULY 9, 2~2