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Home My WebLink About01-71052253U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Dennis A. Carr Defendant Civil Action - In Law 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 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 WA~RNED 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 YOLrR LJ%WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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) 990-91 2253U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff v$ Dennis Ao Carr 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, Dennis A. Carr, is an adult individual residing at 122A W. North Street, Carlisle, PA 17013. COUNT 1 UGI Utilities Inc. vs. Dennis A. Carr 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 Dennis A. Carr. 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. 2253U2 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 $ 2156.22 $ 2156.22 Respectfully submitted, DATED: December 4, 2001 Krzyw~,~d Associates BY:An~y ~.l Krzywicki 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 subiect to the penalties of 18 P.A.C.S. Section 4904, relating to unsworn falsification to authorities. Dated: UGI Utilities, Inc. BY: d//~~.. Jam~ R. Gallagher 2253U2 STATEMENT OF ACCOUNT Dennis A. Carr established the following accounts with UGI Utilities Inc. with the following balances and charges: Account Number / Service Address Acct Type Service to: Balance 210-766-7200-95 G 122 W. North Street Carlisle, PA 17013 / / $2156.22 Total Delinquent Balance: $2156.22 EXHIBIT A ..< SHERIFF'S RETURN - CASE NO: 2001-07105 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS CARR DENNIS A REGULAR DOUGLAS DONSEN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CARR DENNIS A the DEFENDANT , at 1557:00 HOURS, on the 2nd day of January , 2002 at 122A W NORTH STREET CARLISLE, PA 17013 DENNIS CARR a true and attested copy of by handing to COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.25 Affidavit .00 Surcharge 10.00 .00 31.25 Sworn and Subscribed to before me this F~ day of ~ ~J~ A.D. ! ~rothonotary · So Answers. R. Thomas Kline 01/03/2002 KRZYWICKI & ASSOC. By: ~~ .... 'Deputy Sheriff 2253U2 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse * Carlisle, PA 17013 Curtis R. Long Prothonotary TO: Dennis A. Carr 122A W. North Street Carlisle, PA 17013 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff VS Dennis A. Carr Defendant Civil Action - In Law No. 01-7105 ARBITPOITION 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. Curtis R. Long Prothonotary (XX) 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 2253U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Dennis A. Carr Defendant Civil Action - In Law No. 01-7105 ARBITRATION PRAECIPE FOR JUDGMENT AGAINST DEFENDANT FOR FAILURE TO PLEAD To the Prothonotary: COUNT 1 UGI Utilities Inc. vs. Dennis A. Carr Kindly enter default judgment in favor of Plaintiff, UGI Utilities Inc. and against Defendant, Dennis A. Carr for failure to plead to Plaintiff's Complaint as follows: Amount Past Due: TOTAL $ 2156.22 $ 2156.22 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. 2253U2 2. The true and correct address of the Defendant, Dennis A. Carr, is 122A W. North Street, Carlisle, Cumberland County, PA 17013. DATED: April 9, 2002 Krzywi~ssociat es BY: Anthg~y P ./K~Z~;wi cki 49 ~rt~,,~uga~ Road A~'%orney for Plaintiff Attorney I.D. 23754 SHERIFF ' S RETURN - REGULAR CASjE NO: 2001-07105 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS CARR DENNIS A DOUGLAS DONSEN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CARR DENNIS A the DEFENDANT at 122A W NORTH STREET , at 1557:00 HOURS, on the 2nd day of January , 2002 CARLISLE, PA 17013 by handing to DENNIS CA/IR a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.25 Affidavit .00 Surcharge 10.00 .00 So Answers. R. Thomas Kline 31.25 01/03/2002 KRZYWICKI & ASSOC. 'Sworn and Subscribed to. before. BY: ~~.~____ me ~this day of 'Deputy Sheriff A.D. Prothonotary 2253U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Dennis A. Cart Defendant Civil Action - In Law No. 01-7105 ARBITRATION NOTICE TO: Dennis A. Carr 122A W. North Street Carlisle, PA 17013 Date: March 5, 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 Anthony P. Krzywicki 49 North Sugan Road P.O. Box 505 New Hope, PA 18938 215-862-4390 Attorney for Plaintiff Attorney I.D. 23754 U.S. POSTAL SERVICE C~.l'~ I ,:ICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATtONAL MAll., DOES NOT PROVIDE FOR iNSURANCE--POSTMASTER ~_~ Krzywicki & Associates -- P.O. Box 505 New Hope, PA 18938 -- "-'~ne ple~e of ordinary mlil~add~e~le.d to: . PS Form 3817, Mcr. 1989 2253U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Dennis A. Cart Defendant Civil Action - In Law No. 01-7105 ARBITRATION The undersigned hereby certifies that written notice of intention to file a praecipe for entry of judgment by default against the defendant, Dennis A. Carr, 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: April 9, 2002 Krzyw~ssociates BY:Anth~hy P. Krzywicki 49 ort Road N 8 215-862-4390 ~ Attorney for Plaintl~. Attorney I.D. 23754 2253U2 In the Court of Common Pleas of CUMBERI.d~D County, Pennsylvania UGI Utilities Inc. Plaintiff VS Dennis A. Carr Defendant Civil Action - In Law No. 01-7105 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, Dennis A. Carr, 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, Dennis A. Cart, is more than 18 years of age and currently resides at 122A W. North Street, Carlisle, PA 17013. 3. I have ascertained the above information by personal investigation and make this affidavit with/~ authority. An~~ P -~KrL~icki Sworn~o and subscribed before ~/ % me th~s/9~ay//gf Apr--02 Notary Public ~ / ~OTA~Y PUBL~ ~ ~~ .~Y COMMISSI~ EXPIRES ~Y 9, ~