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Home My WebLink About01-0821l190U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff v$ Sheri L. Beyrent Defendant Civil Action - ARBITRATION In Law COMPLAINT NOTICE YOU have been sued in court. If you wish to defend against the claims ~et forth in the following pages, you must take action within ~wenty(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 aHainst 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 NAVE 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) 990-9108 1190U2 In the Court of Common Pleas of UGI Utilities Inc. Plaintiff Sheri L. Beyrent Defendant CUMBERLAND County, Pennsylvania 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, Sheri L. Beyrent, is an adult individual residing at 2608 Chestnut Street, Camp Hill, PA 17011. COUNT 1 UGI util~ z~-f~ Inc. vs. Sheri L. Beyrent 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 Sheri Lo Beyrent. 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. 1190U2 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 the Plaintiff the following sums judgment against the Defendant: and owing from the Defendant to for which Plaintiff demands DATED: October 25, 2000 Amount Past Due: Court Costs: Service Costs: TOTAL $ 1926 . 27 $ 45.50 $ loo.oo $ 2071.77 Respectfully submitted, Krzywicki and Associates By: n~~ Ant rzywicki 49/oj~th Su~an Road Attorney for Plaintiff Attorney I.D. 23754 VERIFICATION I, Cynthia E. 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 mlsworn falsification to authorities. UGI Utilities, Inc. Dated: Cynthia E. Coffin STATEMENT OF ACCOUNT Sheri L. Beyrent established the following accounts with UGI Utilities Inc. with the following balances and charges: 1190U2 Account Number / Acct Type Service to: Balance Service Address 218-571-4726-45 G 2608 Chestnut Street Camp Hill, PA 17011 / / $1926,27 Total Delinquent Balance: $1926.27 EXHIBIT A SHERIFF'S RETURN - CASE NO: 2001-00821 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS BEYRENT SHERI L REGULAR SHAWN HARRISON Cumberland County,Pennsylvania, Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the 14th day of February , by handing to together with says, the within COMPLAINT & NOTICE BEYRENT SHERRI L DEFENDANT , at 0015:22 HOURS, on the at 2608 CHESTNUT STREET CAMP HILL, PA 17011 SHERRI MARSICANO (FORMERLY BEYRENT) a true and attested copy of COMPLAINT & NOTICE 2001 and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.06 Affidavit .00 Surcharge 10.00 .00 36.06 Sworn and Subscribed to before me this .~Z~-- day of 'Prothonotary / So Answers: R. Thomas Kline 02/i5/200i KRZYWICKIBy: & AS/~ yDeput~ ;heriff In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff Civil Action - In Law No. 01-821 CV vs Sheri L. Beyrent Defendant ARBITRATION PRAECIPE FOR JUDGMENT AGAINST DEFENDANT FOR FAILURE TO PLEAD To the Prothonotary: COUNT 1 UGI Util~%-i-~s Inc. vs. Sheri L. Beyrent Kindly enter default judgment in favor of Plaintiff, UGI Utilities Inc. and against Defendant, Sheri L. Beyrent for failure to plead to Plaintiff's Complaint as follows: Amount Past Due: Court Costs: Service Costs: TOTAL $ 1926.27 $ 45.50 $ 100.00 $ 2071.77 together with interest thereon from the date of judgment forward and all costs of this action. 1190U2 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. Beyrent, 17011. The true and correct address of the Defendant, Sheri L. is 2608 Chestnut Street, Camp Hill, Cumberland County, PA DATED: April 12, 2001 Krzyw~ and Associates By: Ant/orl/~l~ 49/Nort~ Sugan Road B/x 505 N~w ~pe, PA 18938 8 0~96-2103 Attorney for Plaintiff Attorney I.D. 23754 1190U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff Civil Action - In Law Vs Sheri L. Beyrent Defendant NOTICE TO: Sheri L. Beyrent 2608 Chestnut Street Camp Hill, PA 17011 Date: March 19, 2001 ARB I TRAT I ON : ~[ 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. zywicki 49 North Sugan Road P.O. Box 505 New Hope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 u,s, ~OSTAL S~V~ CERTIFICATE OF MAILING K~cki & Assoc~t~ ~ P.O. BOX 505 ~ New Ho~, PA 180g~; ~/ ~ PS Form 3817, Mar. 1989 CASE NO: 2001-00821 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES BEYRENT SHERI INC VS L SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BEYRENT SHERRI L DEFENDANT , at 0015:22 HOURS, at 2608 CHESTNUT STREET CAMP HILL, PA 17011 SHERRI MARSICANO (FORMERLY BEYRENT) a true and attested copy of COMPLAINT & NOTICE the on the 14th day of February , 2001 by handing to together with and at the same time directing Her attention to the contents thereof, Sheriff's Costs: Docketing Service Affidavit Surcharge 18 00 8 O6 00 10 00 00 36 06 Sworn and Subs'cribed to before me this day of A.D. So Answers: R. Thomas Kline 02/15/2001 KRZYWICKIBy: & AS~ /Deput] ~heriff Prothonotary 1190U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Sheri L. Beyrent Defendant Civil Action - No. 01-821 CV ARBITRATION In Law The undersigned hereby certifies that written notice of intention to file a praecipe for entry of judgment by default against the defendant, Sheri L. Beyrent, 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 12, 2001 Krz~and Associates BY:An/hony~,t~. ~rzywicki No h 505 -- ~'Hope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 1190U2 In the Court of Common Pleas of cr0~IBERLg2q'D County, Pennsylvania UGI Utilities Inc. Plaintiff Civil Action - In Law vs No. 01-821 CV Sheri L. Beyrent 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, Sheri L. Beyrent, 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, Sheri L. Beyrent, is more age and currently resides at 2608 Chestnut Street, 17011. than 18 years of Camp Hill, PA 3. I have ascertained the above information by personal investigation and make this affidavit wi~ue authority. Sworn to and subscribed befom~--~ / / MiOHELLE NOTARY PUBLIC OF NEW JERSEY ~IY COMMISSION EXPIRES JULY g, 2002 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION UGI Utilities Inc. Plaintiff ( ) Confessed Judgment (XX) Other VS. Sheri L. Beyrent Defendant File No.: 01-821-CV Amount Due: $2071.77 Interest: $41.44 Atty's Corem: 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 Sheri L. Beyrent aka Sheri Marsicano located at 2608 Chestnut Street Camp Hill, PA 17011 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, supply six copies of the description; supply four copies 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: October 4, 2001 /~ ~ Box 505, New Hope, PA 18938 Attorney for Plaintiff 215-862-4390 iD No. 23754 R. THOMAS KLINE Sheriff EDWARD L, SCHORPP Solicitor OFFICE OF THE SHERIFF One Courthouse Square Carlisle, Pennsylvania 17013 RONNY R. ANDERSON Chief Deputy JODY S. SMITH Real Estate Deputy FEBRUARY 1, 2002 UGI Utilities, Inc. Sheri L. Beyrent No. 2001-821 Civil Prope~y Claim Dete~ination Dear Sir, Reference is made to Property Claim dated January 24, 2002 entered by Jerome A. Marsicano, Jr. pertaining to Execution No. 2001-82l Civil Term, UGI Utilities, Inc. -vs- Sheri L. Beyrent. R. Thomas Kline, Sheriff, has determined that the claimant, Jerome A. Marsicano, Jr. in the above mentioned property claim, is prima facie the owner of the property set forth therein. CC: Anthony Krzywicki, Atty for Pltff. Sheri L. Beyrent, Deft. Jerome A. Marsicano, Jr., Claimant So Answers: R. Thomas Kline, gheriff PROPERTY CLAIM Plaintiff ................................................ In The Court qf Comnzon Pleas qf Cumberland County Pennsvlvania No. 2001 -821 Term Writ of Execution TO THE SHERIFF OF CUMBERLAND COUNTY. PENNA. The property listed below and levied upon in this case is not the property qf the defendant but is the property of the undersigned. A list of the claimed property and the values thereqf are: L~T OF PROPERTY VALUE (2) Sofas $ 125.00 (1) Chair 15o00 Rugs, Misc 50.00 Mirrors, Misc 10.00 VCR (RCA) Dining Room Table with 3 chairs Dinette Table with 3 chairs Microwave Iron Board Dryer The Cla~antOb~ed Tft~ tothe Property asFo~ws: 5.00 100.00 50.00 25.00 5.00 25.00 (continued on attached sheet) Ail of the above property was purohas~d by ~h~ ~]a~man~ prior ~o hS~ marriage to the dofond~ N~n~ o~ ~hi5 property was ever owned by the defendant. State Of Pennsylvania, Cumberland County, ss: Jerome A. Marsican Claimant being duly sworn according to law, deposes and says, that the facts set forth in the above property claim are correct and true. Sworn andsubscribedbeforemethis ~d~l~day' WRIT OF EXECUTION and/or ATI'ACHMENT COMMONWEALTH OF PENNSYt. VANIA) NO COUNTY OF CUMBERLAND) 01-821 __ CIVIL 19 .... CIVIL ACTION - LAW TO THE SHERIFf: OF ._ _ CUMBERL_AN_D~ ..... COUNTY: UGI Utilities, To satisty the debt, interes~ and costs due .... Inc. trom Sheri L. Beyrent, 2608 Chestnut Sti~ ...... PLAINTIFF(S) PA 17011. DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell p r_op_e ~_tff. Ail personal (2) You are also directed to attach the property of 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) fhe garnishee(s) is/are enjoined from paying any debt fo or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) ~tpr~perty~~~hede~endant(s)n~t~eviedup~nansubjectt~attachmentis~~undinthepossessi~n~fan~~ne~ther than a named garnishee, you are directed fo notify him/her that he/she has been added as a garnishee and is enjoined as above stated Amount Due $2,071.77 Interest $41.44 Att y's Corem .......... % Atty Paid $108.06 Plaintiff Paid LL $.50 Due Prothy Other Costs $1.00 Date ..... N_o_v_e_~p_er__2_6_,__2_p0_l_ ...... CURTIS R. LONG REQUESTING PARTY: Name ~ A~n_~t~h0~n?~P_-~KK~rzywick~i_,- _Es~q~. _ Address P O Box 505 Attorney for __._ Plaintiff Telephone: ___~.215) 862-4390 Supreme Coud ID No. 23754 P~ ~ho mary, Civi( Oivision Deputy R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. SherifFs Costs: Docketing 18.00 Poundage 2 · 05 Advertising 10.00 Law Library .50 Prothonotary 1.00 Mileage ]. 8.20 Misc. Surcharge 20.00 Levy 20.00 Post Pone Sale 15.00 Garnishee 104.75 AdvanceCosts: 150.00 SheriWsCosts: 104,75 45.25 Refunded to Atty on 10/11/02 Sworn and Subscribed to before me this ~ day of 2oo promonotary So Answers; R. Thomas Kline, Sheriff /20 ;~4~ (3) Toaster Beds Radio (Emerson) Stereo (JVC) Telephone Tools Computer Vacuum (Eureka) Sony Play Station (2)Love Seats Lamps, Misc Pictures, Misc Television (Magnavox) Stereo (Fisher) Iron Refrigerator Washer (Kenmore) Coffee Pot Telephone (AT & T) (3) Dressers TV (Sony) TV (Admiral) Clock (2) Lawnmowers Hose Vacuum (Bissell) VCR (Panasonic) 5.00 60.00 10.00 20.00 2.00 5.00 35.00 15.00 75.00 25.00 15.00 5.00 35.00 50.00 10.00 35.0O 50.00 5.00 20.00 15.00 25.00 5.00 1.00 20.00 5.00 10.00 25.00 Page 2