HomeMy WebLinkAbout01-71032526U2
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
UGI Utilities Inc.
Plaintiff
VS
Rebecca J. Smith
Defendant
Civil Action -
No.O --
ARBITRATION
In Law
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
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 TEAT IF YOU FAIL TO DO SO TgE 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 LAWYER OR C/~NNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTE 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
2526U2
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
UGI Utilities Inc.
Plaintiff
vs
Rebecca J. Smith
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, Rebecca J. Smith, is an adult individual residing
at 126 Market Street, New Cumberland, PA 17070.
COUNT 1
UGI Utilities Inc. vs.
Rebecca J. Smith
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 Rebecca J. Smith.
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.
2526U2
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
$ 1605.42
$ 1605.42
Respectfully submitted,
DATED: December 4, 2001
Krzywicki and Associates
BY:Antb~f~zywicki
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.
J--am~ R. Gallagher
2526U2
STATEMENT OF ACCOUNT
Rebecca J. Smith established the following accounts with UGI
Utilities Inc. with the following balances and charges:
Account Number /
Service Address
Acct Type
Service to:
Balance
213-132-5070-85 G
126 Market Street New Cumberland, PA 17070
/ / $1605.42
Total Delinquent Balance: $1605.42
EXHIBIT A
SHERIFF'S RETURN -
'CASE'NO: 2001-07103 P
COMMONWEALTH OF pENNSYLVANIA
COUNTY OF CUMBERLAND
NOT FOUND
UGI UTILITIES INC
VS
SMITH REBECCA J
R. Thomas Kline ,Sheriff or Deputy Sheriff,
duly sworn according to law, says, that he made a diligent
inquiry for the within named defendant, DEFENDANT
SMITH REBECCA J
unable to locate Her in his bailiwick.
who being
search and
but was
He therefore returns the
COMPLAINT & NOTICE
, NOT FOUND , as to
the within named DEFENDANT
, SMITH REBECCA J
PER POST OFFICE, DEFENDANT LIVES AT
107 OLD YORK ROAD LOT 503 NEW CUMBERLAND - YORK CO.
Sheriff's Costs:
Docketing 18.00
Service 11.05
Not Found 5.00
Surcharge 10.00
.00
44.05
Sheriff of Cumberland County
KRZYWICKI & ASSOCIATES
01/24/2002
Sworn and subscribed to before me
this ~D ~ day of~
J.o~ ~ A.D.
Pro~notar~ ~ ~
TMO~,AAS KUNE
Sheriff
EDWARD L, SCHORPP
Solicitor
OFFICE OFTHE SHERIFF
One Courthouse Square
Carlisle, Pennsylvania 17013
RCZ)NNY I:t. ANDERSON
Chief Ospufy
To: ?omzna~d~r Age, ney Control No. /d~ / - "] / d ~
Address Informatio~ Reques~
PI=~ ~mish ~his agency w(d~ ~= new address, if ava able, for th~ following individual or v~ri~
whether ~ ~ddress given below is on~ at whici~ mail for this individual ks cu~ndy b~ing ddiwr~4.
[f~c following address is z post o~ce box, pl~e ~mish the ~m~t address as recorded on the
. . .~z-~ d ~forthcpcrfo~nc~efthisag~ncy,s ~'
~ cem~ thc address information for this md~wdua, = r~qmr~d
(Sieurs of encv O~oial)
FOR POST OFFICE USE ONLY
( ) MAIL I$ DELIVERED TO ADDKESS GIVEN
( ) NOT I~qOWN AT ADDKESS GIVEN
( )MOVED, LEFT'NO FORWAKDFNG ADDRESS
( ) NO SUCH ADDRESS
( ) OTHER iS?SC:FY):
Agency Return Address
Address Information Requ~t (Required Format)
Exhibk 352.44b
Pos~mark/Dat. e- Stamp
2526U2
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
UGI Utilities Inc.
Plaintiff
vs
Rebgcca J. Smith
Defendant
Civil Action - In Law
No. 01-7103
ARBITRATION
PRAECIPE TO
REINSTATE COMPLAINT
To the Prothonotary:
Kindly reinstate the Complaint in the above-captioned
Civil Action for an additional thirty days.
DATED: January 29, 2002
Krz~~ Associates
BY:~t~ny p. ~-~i
49 ~or[h~fgan Ro~d
p.~. Bo2~'505
215-862-4390
Attorney for Plaintiff
Attorney I.D. 23754
SHERIFF'S RETURN -
CASE NO: 2001-07103 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
UGI UTILITIES INC
VS
SMITH REBECCA J
OUT OF COUNTY
R. Thomas Kline , Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT , to wit:
SMITH REBECCA J
but was unable to locate Her in his bailiwick. He therefore
deputized the sheriff of YORK County, Pennsylvania,
serve the within COMPLAINT & NOTICE
to
On June
25th , 2002 this office was in receipt of the
attached return from YORK
Sheriff's Costs:
Docketing 18.00
Out of County 9.00
Surcharge 10.00
dep York County 61.61
.00
98.61
06/25/2002
So answer~ ~ / /
R. THomas Kline ~
Sheriff of Cumberland County
KRZYWICKI & ASSOCIATES
Sworn and subscribed to before me
this ~ day of~A~
A.D.
Prothonot a'r~-
COUNTY OF ?0RK
OFFICE OF THE SHERIFF
2526U2 28 EAST MARKET ST, YORK, PA 17401
SHERIFF SERVICE
PROCESS RECEIPT, and AFFIDAVIT OF RETURN
PLAINTIFF/S/
UGI Utilities Inc.
SERVICE CALL
(717) 771-9601
2. COURTNUMBER 01-710.
3. DEFENDANT/S/
Rebecca J. Smith
4. TYPE OF WRIT OR COMPLAINT
Notice & Cu,Iplaint ....
civil re3_ns~;a~:ect
SERVE s. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD.
Rebecca J. Smith
6. ADDRESS (STREET OR RFD WITH BOX NUMBER, APT NO., ClT~, BORO, TWR, STATE AND ZIP CODE
AT 107 Old York. New Curaber]~n~. PA 17070
7. INDICATE SERVICE: r~ PERSONAL [] PERSON IN CHARGE [] DEPUTIZE c, ~ ~. ;:;iT MAll r'l 1 ST CLASS MAIL [] POSTED
NOW JLLne 6, 2002 X~ I SHERIFF O1~-~''~-''';J' ........ [] OTHER
- - __. , ~--t,uuw t L ?q~J]oJ~reoy aeput~ze the sheriff of
lark COUNTY to execute tl~[~d~ke r~_tu..rn thJige~ording
to law. This deputation being made at the request and risk of the plaintiff. ~ ~ ..,,~.~.~_.~.
SHERIFF OF ~ COUNTY
8. Sr~oiAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXEE~i¥iNG SERVICE: Ct_~ber T and
OUT OF COUNTY
CUMBERLAND
ADVANCED FEE PAID BY ATTY.
NOTE ONLY APPUCABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave
same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any
plaintiff herein for an or removal of any properly before sheriff's sale thereof.
9. TYPE NAM
ANTHONY P ,KI 49
CO..
10. TELEPHONE NUMBER
). PO BOX 505 NEW HOPE,PA '>~K ~K'> ~qon
ADDRESS BELOW: (Th s area must b~ ~o"~t~[~ d if notice is to be mailed).
505 new 18938
11. DATE FILED
6-6-02
13. i acknowledge receipt of the writ
or complaint as indicated above,
SIGNATURE OF AUTHOHiZI=I,~ CLERK
R. AHRENS
14. ~)a,t_ell~e c_e(~v~ d
, ~...E~pi_r6t~ n/H ea ring Date
16. HOWSERVED: PERSONAL(~ RESIDENCE~') POSTED( ) POE( ) SHERIFF'S OFF ( ) OTHER( ) SEEREMARKR
17. [] I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, corporation, etc, named above. (See remarks below.)
18. NAIls-AND TITLE OF INDIVIDUal. SERVED I LIST &ODRESS HERE IF NOT SHOWN ABOVE Relationship to Defendant) 19. D~e of ~erv ce 20 Time of Se~ice
m m.]Mmme. J Int. I~'P [~m, r M.e,~, Int. I~ JTimei Mits, m int. I Date m' ~memMim,,m mntm I Date ~Tlme'Mites Int. Date Time 'Miles n, -
23. Advance Costs 24. Service Costs 27. Postage 28. Sub Total 29. Pound 30. Notao/Fee
75.00 18.00 ~s.N/F ~S.U,enge41.61 59.61 2.00
34. Foreign County Costs 35. Advance Costs 36. Service Costs 37. Notaty Cert. 38. Mileage/Postage/N.F.
41. AFFIRMED and subscribed to before me this 2 0
31. Surcharge 32. Total Costs 33. Cost Due ~
To,al c6oslt:61 O.L t' SRe,u d
, Shedff
~IGNATURE
OF AUTHORIZED ISSUING AUTHORilN( AND TITLE
1. WHITE - Issuing Authority 2. PINK - Attorney 3. CANARY - Sheriff's Olffce 4. BLUE - Sheriff's Office
6-20-02
49, Date
Date Received
COUN~'Y bF YORK
OFFICE OF THE SHERI, FF
28 EAST MARKET ST., YORK, PA 17401
2526[32
SHERIFF SERVICE
PROCESS RECEIPT, and AFFIDAVIT OF RETURN
UG£ Uti£i~ies l~c.
2. COURT NUMBER
YPE OF WRIT OR COMPLAINT
N¢-.t~ce & CcmDla~nt.
Rebecca J~ &nith civJ ]
PERS~DNAL [] PERSON IN CHARGE [] DEPUTIZE IL O 1 ST CLASS MAIL [] POSTE. . O. [] OTHE~R
Vork COUNTY to execu~~_.~mac,-,-,-,-,-,-,-,-,l~.,,,r,e'ur~,~,Y..~'
This deputation being---~-~--~-~-~sde et the request end r,~k~f the plaintiff. ~ /"~s,~,~'~-~o~ "~-ou.,~ --
L INSTRUCTIONS OB OTHER INFORMATION THAT WILL ASSIST iN EXPEDITING SERVICE: ~lJi¥!be r
OUi OF CuUNI
&DVANiEO FKL PA][) BY
ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within wdt may leave
without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the pad of such deputy or the sheriff to any
loss, des~aCtion, or removal of any property before sheriffs sale thereof,
TYPE NAME AND ADOI~-~'-''~ f ATTORNEY/ORIGINATOR and SIGNATURE 110. TELEPHONE NUMBER 11. DATE FILED
ANTH(!NY 49 9D. PC,, BOX 5(''~ ...... [iE?; ~pr¥ ·P~" 2!5-8(,2-~39~ " '~
E AND ,~ 0'h~s ~rea must be~.-,..p.~o.-, ~f notle~, is to be~ mailed).
!I~u 50~, new ifPS38
acknowledge receipt of the writ
or complaint as indicated abeye.
R. AHRE, 5
SIGNATURE OF AUTHORIZED CLERK
LHOW SERVE[D: PERSONAL~ ) RESIOENCE~ ) POSTED ( ) POE ( )
14. Date Received 15. Expiration/Hearing Date
SHERIFF'S OFF ( ) OTHER ( ) SEE REMARKS
cerlify and return a NOT FOUND because I am unable to ~ocate the individual, ~ompany, corporation, etc, named above. (See remarks below.)
NAME ~d~lD TITLE OF INDIVIDUAL SERVED / LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant)
of Service
Date [ Time Mites Int~
24, Service Costs 25. N/F 26, Mileage 27, Postage 28. Sub Total 29. Pound 30. Nota~ Fee 32. Total Costs 33. Cost Due or Refund
75.00 1~.00 ,'11.51 59,~]
Foreign County Costs ~ Service Costs 37. Nota~ Cert [ 38. Mileage/Postage/N.F. ~ 40. Cost Due or Refund
ANSWER.
~FFIRMED and subscribed to before me this 20 ~~Oeo. Sheriff
2092 ~_1~ 45. Signature of YorK/ .
County Shedfl
OF A~HORIZED ISSUING AUTHORI~ AND T~
48. Date
49, Date
1. Date Received
2526U2
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
C~mberland County Courthouse * Carlisle, PA 17013
Curtis R. Long
Prothonotary
TO:
Rebecca J. Smith
107 Old York Lot #503
New Cumberland, PA 17070
In the Court of Common Pleas of CUMBERLAND County,
Pennsylvania
UGI Utilities Inc.
Plaintiff
VS
Rebecca J. Smith
Defendant
Civil Action - In Law
No. 01-7103
ARBITRATION
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified~ t~ath a
Judgment has been entered against you in the above proceedin~s~_l~ed~ ~ow. ~ _
Curtis R. Long ~
(xx)
(
(
(
(
(
(
Prothonotary
Judgment by Default
Money Judgment
Judgment in Replevin
Judgment for Possession
Judgment on Award of Arbitration
Judgment on Verdict
Judgment on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE,
PLEASE CALL
ATTORNEY FOR THE FILING PARTY:
Anthony P. Krzywicki
Krzywicki and Associates
49 North Sugan Road
P.O. Box 505
New Hope, PA 18938
215-862-4390
Attorney I.D. NO.23754
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
UGI Utilities Inc.
Plaintiff
vs
Rebecca J. Smith
Defendant
Civil Action -
No. 01-7103
ARBITRATION
In Law
PP~AECIPE FOR JUDGMENT AGAINST
DEFENDANT FOR FAILURE TO PLEAD
To the Prothonotary:
COUNT 1
UGI Util~ m~- Inc. vs.
Rebecca J. Smith
Kindly enter default judgment in favor of Plaintiff, UGI
Utilities Inc. and against Defendant, Rebecca J. Smith for failure
to plead to Plaintiff's Complaint as follows:
Amount Past Due: $ 1605.42
TOTAL $ 1605.42
together with interest thereon from the date of judgment forward
and all costs of this action.
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.
2526U2
2. The true and correct address of the Defendant, Rebecca J.
Smith, is 107 Old York Lot #503, New Cumberland, Cumberland County,
PA 17070.
DATED: August 26, 2002
Krzywic~ssociates
BY:Antho~ P. ~.~J~_cki
49 N~rth~gan R~ad~
P.o/Bo/- 5 0 5 ~
Ne~H~e, PA 18938
21~..~62-4390
Attorney for Plaintiff
Attorney I.D. 23754
28 EAST MARKET ST. YORk. Pa 17401
2526U2
INSTRUCTIONS
SHERIFF SERVICE PLEASE TYPE ONLY LINES I TO 12
PROCESS RECEIPT, and AFFIDAVIT OF RETURN
DO NOT DETACH ANY COPIES.
1. PLAINTIFF/S/
UGI Utilities Inc.
3. DEFENDANT/S/
Re.ca J. Smith
2. COURT NUMBER 01-7103Q¢~
4. ~PE OF WRIT OR COMPLAINT
Notice & Cu~laint
civil reinstate(/
SERVE ~' 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC, TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD.
6. ADDRESS (STREET OR RFD WITH BOX NUMBER, APT NO,, CITY, BORe, TWR. STATE AND ZIP CODE
'AT ]07 Old York. New Ctmtberla~d. PA 17070 ~ofz~' ? ,'~/~,~
7. INDICATE SERVICE: [] PERSONAL n PERSON IN CHARGE [] DEPUTIZE r~, .n~]g~C~EliIT~,IL n 1 ST CLASS MAIL [] POSTED n OTHER
NOW June 6, 2002 ' X~ I, SHERIFFOF~'~i~-~C~O-0'~'TY, PA.,.do[,,~-ebydeputizeth..es. heriffof
- '~-'-"-- - COUNTY ,o execute .t~'f1'~~rn ,h.h.,,~ording
to law. This deputation being made at the request and risk of the plaintiff. '7 '~ ~'~" ~.~:'~."~
SHtiRIFF OF '~ COUNTy
8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDtTING SERVICE: C%~nberIand
OUT OF COUNTY
CUMBERLAND
ADVANCED FEE PAID BY ATTY.
NOTE ONLY APPUCABLE ON WRIT OF EXECU'r]ON: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave
same without a watchman, in cuatsdy of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any
plaintiff herein Ior any loss, destr,~uct~on, or removal of any propeAy before shehffs sale thereoL
9. TYPE NAME AND ADDR~9{ ATFORNEY/ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER
ANTHONY P KRZ KI 49 N. . PO BOX 505 NEW HOPE,PA
P/KRZ/~KI 49 N ...~F~--~ lgQgO I 215-862-4390
12' SEND NOTIC~,~M~ F C~ D T'~ ~E AND ADDRESS BELOw: (This area must be ~'°'~r'pt~t~d ft n°tlce is t° be mailed)'
CUM R C0..S ERIFF
an~oR~'~r~.~;ric~, mb 505, new hope, pa 18938
SPACE BELOW FOR USE OF THE SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE
11. DATE FILED
6-6-02
SIGNATURE OF AUTHORIZED CLERK
R. AHRENS
t ~....E~p~rst J_~IVH e ~ ti n g Date
16. HOW SERVED: PERSONAL (~ RESIDENCE~ POSTED ( ) POE ( ) SHERIFF'S OFF ( ) OTHER ( ) SEE REMARKS
17. Q I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, corporation, etc, named above. (See remarks below.}
1*~' ~'~ ~.~{~tB' NAME-AND TITLE OF IN OIVlOU~. ~-'~/~ ~SERVED / LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) II 1~///.~/~ ID~te el S. erviceI 20./.,d1~/o"Sme of Service
2t. ATTdMPTSI..O~ITImelM,esj I.,. p,~ TIme/M,T~a ,.t.~TIme Miles Int. OataJTIma Miles Int. Date TIme Mites; Int. Date ;Time Miles Int.
22. REMARKS:
26. Mileage 27. Postage
75.00
18-00
41.61
34. Foreign County Costs 35. Advance Costs 36. Service Costs 37, Notary Cart. 38.~ Mileage/Postage/N.F.
41 AFFIRMED and subscribed to before me this 20
J //al{l~q. ~,e.y~'angreen. Notary Public - I
,/ J My
M~ COM~,~u. ~,.:~ ~-2-,'~..'~ '
31. Surcharge 32.61,61Total Costs 33.13,39Cost Due ~
;V;;;ots, .Fou.d ..o,aryFee .00
39, Totai Costs
SO ~,NSWER.
44. Signature of
WILLIAM M. H"' OSE
50.1 ACKNOWLEDGE RECEIIST OF THE SHERIFF'S RETURN SIGNATURE
OF AUTHORIZED ISSUING AUTHORPtY AND TITLE
40. Cost Due or Refund
0-20-02
49. Da e
J51. Date Received
1. WHITE-IssuingAuthodty 2. PINK-Attorney 3. CANARY - Sheriff's Office 4. BLUE-SheriffsOffice
2526U2
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
UGI Utilities Inc.
Plaintiff
vs
Rebecca J. Smith
Defendant
Civil Action -
No. 01-7103
ARBITRATION
In Law
NOTICE
TO: Rebecca J. Smith 107 Old York Lot #503
New Cumberland, PA 17070
Date: July 15, 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
~knt bony P. wicki
49 North Sugan Road
P.0. Box 505
New Hope, PA 18938
215-862-4390
Atterney fer Plaintiff
Attorney I.D. 23754
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UGI Utilities Inc.
Plaintiff
VS.
Rebecca J. Smith
Defendant(s)
Civil Action - In Law
No. 01-7103
STATE OF NEW JERSEY
COUNTY OF HUNTERDON
AFFIDAVIT OF SERVICE
SS.
I, Anthony P. Krzywicki, Attorney for Plaintiff, served a tree 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
July 15, 2002.
An ny P.
PA ID# 23754
215-862-4390
SWORN TO AND SUBSCRIBED
BEFORE ME THIS ~-~ DAY
Notary Public
MICHELLE I~ATT
NOTARY PUBLIC ~ JERSEY
~lY COMMISSION EXPIRES,JULY 9. 200~LF
2526U2
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
UGI Utilities Inc.
Plaintiff
vs
Rebecca J. Smith
Defendant
Civil Action - In Law
No. 01-7103
ARBITRATION
The undersigned hereby certifies that written notice of intention to
file a praecipe for entry of judgment by default against the
defendant, Rebecca J. Smith, 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 26, 2002
Krzywi~d Associates
BY:Anthony P. J~icki
49 N~rth~gan
P.O/ BO~/505 k
Ne~ Ho~e, PA 189~--~
21~-8/2-4390
A~t~ney for Plaintiff
A~orney I.D. 23754
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
UGI Utilities Inc.
Plaintiff
( ) Confessed Judgment
(XX) Other
VS.
Rebecca J. Smith
Defendant
File No.: 01-7103
Amount Due: $1605.42
Interest: $96.33
Atty's Comm:
Costs: $
TO THE PROTHONOTARY OF SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail installment
sale, contract, or account based on a confession of judgment, but if it does, it is based on the
appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property
pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the sheriff of Cumberland County, for debt, interest
and costs, upon the following deScribed property of the defendant(s)
All property belonging to Rebecca J. Smith located at 107 Old York Lot #503, New Cumberland
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs,
as above, directing attachment against the above-named garnishee(s) for the following property
(if real estate, o,~t~['~: o': ~ut°ic~ u£ mc ~c~cripm)n; supply ~our copras of lengthy personality list) _
And all other property of the defendant(s) in the possession, custody or control of the said
garnishee(s).
[--] (Indicate) Index this writ against the garnishee(s) as a lis pendens against real
estate of the defendant(s) described in the attached exhibit. ,~~
Date: May 9, 2003
An4ny e. ~cki
PO ~Ne~38 -~
Attorney for Plaintiff
215-862-4390
ID No. 23754
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 01-7103 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due UGI UTILITIES, INC., Plaintiff (s)
From REBECCA J. SMITH, 107 OLD YORK, LOT #503, NEW CUMBERLAND, PA
(1) You are directed to levy upon the property of the defendant (s)and to sell ALL PROPERTY
BELONGING TO REBECCA J. SMITH LOCATED AT 107 OLD YORK LOT #503, NEW
CUMBERLAND.
(2) You are also directed to attach the property o£the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $1605.42
Interest $96.33
L.L. $.50
Atty's Comm % Due Prothy
Arty Paid $214.66 Other Costs
PlaintiffPaid
$1.00
Date: MAY 19, 2003
(Seal)
REQUESTING PARTY:
Name ANTHONY p. KRZYWICKI, ESQUIRE
Address: PO BOX 505
NEW HOPE, PA 18938
Attorney for: PLAINTIFF
Telephone: 215-862-4390
Supreme Court ID No. 23754
CURTIS R. LONG
Deputy