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Home My WebLink About04-24771838U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff Civil Action - In Law No. d>q- 2 77 VS A~ngelique R. Brown Defendant ARBITRATION COMPLAINT NOTICE YOU have been sued in court. If you wish to defend a~ainst the claims set forth in the following pages, you must take action within twenty(20) days after this complaint and notice are se~;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 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 I~WYER 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 1838U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff VS Angelique R. Brown Defendant Civil Action - In Law 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, Angelique R. Brown, is an adult individual residing at 303 Farmington Drive, Shippensburg, PA 17257. COUNT 1 UGI Utilm-~-i~-~ Inc. vs. Angelique R. Brown 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 Angelique R. Brown. 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. 1838U2 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: $ 2808.65 Fees: $ 400.00 Court Costs: $ 55.50 Service Costs: $ 150.00 TOTAL $ 3414.15 DATED: May 26, 2004 Respectfully submitted, Krzyw~ssociates BY:Anth~y P. ~--~ki 49 ~orth,~ugan Roa~d~ P.q. 505 New~-h~ope, PA 18938 215-862-4390 Attorney for Plaintiff Attorney I.D. 23754 VERIFICATION I, Cindy 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. Dated: 1838U2 STATEMENT OF ACCOUNT Angelique R. Brown established the following accounts with UGI Utilities Inc. with the following balances and charges: Account Number / Acct Type Service to: Balance Service Address ================================================================================ 206-341-4432-80 G 1250 Swatara Street Harrisburg, PA 17104 / / $2808.65 Total Delinquent Balance: $2808.65 EXHIBIT A co . SHERIFF'S CASE NO: 2004-02477 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLanD UGI UTILITIES INC VS BROWN ANGELIQUE R RETURN - REGULAR RONALD KERR , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE BROWN ANGELIQUE R DEFENDANT , at 1512:00 HOURS, at 303 FARMINGTON DRIVE SHIPPENSBURG, PA 17257 ANGELIQUE R BROWN a was served upon on the 3rd day of June by handing to the , 2004 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 13.80 Affidavit .00 Surcharge 10.00 .00 41.80 Sworn and Subscribed to before me this /0~ day of ~6~3~ A.D. , t~rothonotary i ' So Answers: R. Thomas Kline 06/04/2004 KRZYWICKI & ASSOC Deputy Sheriff In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff Civil Action - In Law No. 04-2477 vs Angelique R. Brown Defendant ARBITRATION PRAECIPE FOR JUDGMENT AGAINST DEFENDANT FOR FAILURE TO PLEAD TO the Prothonotary: COUNT 1 UGI Utilz z~--f~ Inc. vs. Angelique R. Brown Kindly enter default judgment in favor of Plaintiff, UGI Utilities Inc. and against Defendant, Angelique R. Brown for failure to plead to Plaintiff's Complaint as follows: Amount Past Due: $ 2808.65 Fees: $ 400.00 Court Costs: $ 55.50 Service Costs: $ 150.00 TOTAL $ 3414.15 together with interest thereon from the date of judgment forward and all costs of this action. 1838U2 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~ Angelique R. Brown, is 303 Farmington Drive, Shippensburg, Cumberland County, PA 17257. DATED: August 25, 2004 Krz/ Associates By:~ New Hope, PA 18938 215-862-4390 Attorney for Plaintiff Attorney I.D. 23754 SHERIFF'S CAS~ NO: 2004-02477 P COHMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS BROWN ANGELIQUE R RETURN - REGULAR RONALD KERR , cumberland County, Pennsylvania, says, the within COMPLAINT & NOTICE BROWN ANGELIQUE R DEFENDANT at 1512:00 HOURS, on the at 303 FARMINGTON DRIVE SHIPPENSBURG, PA 17257 ANGELIQUE R BROWN a true and attested copy ef COMPLAINT & NOTICE 3rd day of June Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the 2004 by handing to together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18 Service 13 Affidavit Surcharge 10 '41 00 8O 00 00 00 8O Sworn and Subscribed to before me this day of A.D. Prothonotary So Answers R. Thomas Kline 06/04/2004 KRZYWICKI & ASSOC //__ -- Deputy Sheriff 1838U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff Civil Action - In Law vs No. 0R-2477 Angelique R. Brown Defendant ARBITP~ATION NOTICE TO: Angelique R. Brown 303 Farmington Drive Shippensburg, PA 17257 Date: July 2, 2004 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 youl 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 Anthony P. wicki 49 North Sugan Road P.O. Box 505 New Hope, PA 18938 215-862-4390 Attorney for Plaintiff Attorney I.D. 23754 1838U2 In the Court of Common Pleas of UGI Utilities Inc. Plaintiff vs Angelique R. Brown Defendant(s) CUMBERLAND County, Pennsylvania Civil Action No. 04-2477 In Law AFFIDAVIT OF SERVICE STATE OF NEW JERSEY COUNTY OF HUNTERDON SS. I, Anthony P. Krzywicki, Attorney for Plaintiff, served a true and correct copy of the Notice of Intention to Take Default pursuant to Pa. R.C.P. 237.1 on Defendant(s), by first class mail on 07/02/2004. SWORN TO AND SUBSCRIBED BEFORE ME THIS 2¢ DAY MICHELLE PYA~ NOTARY PUBLIC ~ NEW JERS~ i~Y COMMISSION EXPIRES JULY g, ~ Anthy/~Ywicki Att~r3~e~for/Plaintiff, Kr~icki a~d P.O. Box New Hope, PA 18938 PA ID# 23754 215-862-4390 1838U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff Civil Action - In Law No. 04-2477 vs Angelique R. Brown Defendant ARBITRATION The undersigned hereby certifies that written notice of intention to file a praecipe for entry of judgment by default against the defendant, Angelique R. Brown, 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: August 25, 2004 Krzy~ Associates BY: Antt~zywicki Attorney for Plaintiff Attorney I.D. 23754 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff Civil Action - In Law vs No. 04-2477 Angelique R. Brown Defendant 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, Angelique R. Brown, 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, Angelique R. Brown, is more than 18 years of age and currently resides at 303 Farmington Drive, Shippensburg, PA 17257. investigation and make this affidavitwi~ authority. Sworn to and subscr~ed~ // / ~ me 20 04/y MICHELLE PYATI' NOTARY PUBLIC OF NEW JERSEY MY COMMISSION EXPIRES JULY 9, 20~ I have ascertained the above information by personal