The URL can be used to link to this page

Home My WebLink About01-08221149U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff Iyonna Anderson 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 ~ake action within twenty{20) days after this complaint and notice are 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 re0fuested by the plaintiff. You YOU SHOULD TAKE THIS PAPER TO YOLrR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR C~QYNOT 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 1149U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Iyonna Anderson 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. Defendant, Iyonna Anderson, is an adult individual residing at Dulles Drive AG8, Camp Hill, PA 17011. COUNT 1 UGI Util~ m~i~ Inc. Iyonna Anderson vs. 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 Iyonna Anderson. 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 the Defendant aforesaid, was received, the benefit of said Defendant. provided by the Plaintiff to accepted, and utilized for 1149U2 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: DATED: October 25, 2000 Amount Past Due: $ 2292,44 Court Costs: $ 45.50 Service Costs: $ 100.00 TOTAL $ 2437.94 Respectfully submitted, Krzywicki and Associates --~ Aq~nony,~K~zywicki 800-296-2103 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 unswom falsification to authorities. UGI Utilities, Inc. Dated: 1149U2 STATEMENT OF ACCOUNT Iyonna Anderson established the following accounts with UGI Utilities Inc. with the following balances and charges: Account Number / Acct Type Service to: Balance Service Address ================================================================================ 206-350-3270-84 1261 Bailey Street Harrisburg, PA 17103 / / $2292.44 Total Delinquent Balance: $2292.44 EXHIBIT A SHERIFF'S RETURN - REGULAR CASE NO: 2001-00822 P COMMONWEALTH OF PENNSYLVDHqIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS ANDERSON IYONNA SHAWN HARRISON Cumberland County, Pennsylvania, says, the within COMPLAINT & NOTICE ANDERSON IYONNA DEFENDPdqT at 0017:24 HOURS, at 4 DULLES DRIVE G8 CAMP HILL, PA 17011 PORSCHIA ANDERSON (SISTER) a Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 26th day of February , __ by handing to together with 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 9.30 Affidavit .00 Surcharge 10.00 .00 37.30 Sworn and Subscribed to before me this ~ day of '~ ~e-O t A.D, / Prothonotar!/ So Answers: R. Thomas Kline 02/2s/2001 KRZYWICKIBy: & OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse * Carlisle, PA 17013 Lawrence E. Welker Prothonota~ TO: Iyonna Anderson 4 Dulles Drive AG8 Camp Hill, PA 17011 In the Court of Common Pleas of CUMBERI~%ND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Iyonna Anderson Defendant Civil Action - In Law No. 01-822 CV ARBITRATION NOTICE ~rsuant 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~d b/~wj ~ 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 }{AVE AirY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEY FOR THE FILING PARTY: Anthony P. Krzywicki Krzywicki and Associates 1 Neshaminy Interplex P.O. Box 505 New Hope, PA 18938 800-296-2103 Attorney I.D. No.23754 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Iyonna Anderson Defendant Civil Action - In Law No. 01-822 CV ARBITRATION PRAECIPE FOR JUDGMENT AGAINST DEFENDANT FOR FAILURE TO PLEAD To the Prothonotary: COUNT 1 UGI Utillz--~-i-~ Inc. vs. Iyonna Anderson Kindly enter default judgment in favor of Plaintiff, UGI Utilities Inc. and against Defendant, Iyonna Anderson for failure to plead to Plaintiff's Complaint as follows: Amount Past Due: Court Costs: Service Costs: TOTAL $ 2292.44 $ 45.5o $ lOO.OO $ 2437.94 together with interest thereon from the date of judgment forward and all costs of this action. 1149U2 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, Iyonna Anderson, is 4 Dulles Drive AGS, Camp Hill, Cumberland County, 17011. PA DATED: May 9, 2001 Krzywi~d Associates BY :Antho/ P/~ic~i 1 Ne~ha3~Iny Int~ P. O ~_~x 505 New ~ope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 SHERIFF ' S CASE NO: 2001-00822 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS ANDERSON I YONNA RETURN - REGULAR SFLAWN HARRISON , Cumberland County, Pennsylvania, says, the within COMPLAINT & NOTICE was served upon ? Sheriff or Deputy Sheriff of who being duly sworn according to law, by handing to together with ANDERSON IYONNA the DEFENDANT , at 0017:24 HOURS, on the 26th day of February , at 4 DULLES DRIVE G8 CAMP HILL, PA 17011 PORSCHIAANDERSON (SISTER) a true and attested copy of COMPLAINT & NOTICE 2001 and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Service 9.30 Affidavit .00 Surcharge 10.00 R. Thomas Ktine .00 37.30 02/28/2001 KRZYWICKI Sworn and Subscribed to before me this day of By: Prothonotary 1149U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff Civil Action - In Law vs No. 01-822 CV Iyonna Anderson Defendant ARBITRATION NOTICE TO: Iyonna Anderson 4 Dulles Drive AG8 Camp Hill, PA 17011 Date: April 11, 2001 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 IS/ Anthony P. Krzywicki 1 Neshaminy Interplex P.O. Box 505 New Hope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 POSTAL SE~VI[~E CERTIFICATE OF MAILING MAY I~E USEO FOR DOMESTIC AND INTERNATIONAL MAIL, DO~S NOT ...... ~ ~ ~_~ Fo~ 3817, Mar, 1989 1149U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Iyonna JM~.derson Defendant Civil Action No. 01-822 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, Iyonna Anderson, 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: May 9, 2001 Krzyw~ and Associates By: An~o~rzywicki 1/Ne~qaminy~I nt~ 1 ex P/.O/ Box 505 ~ Hope, 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 Civil Action - In Law vs No. 01-822 CV Iyonna Anderson 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, Iyonna Anderson, 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, Iyonna Anderson, is more than 18 years of age and currently resides at 4 Dulles Drive AGS, Camp Hill, PA 17011. 3. I have ascertained the above information by personal investigation and make this affidavit with due authority. Sworn to and subscribed/before r,tOTARY PUBLIC OF NE'~ JERSEY r~Y COMMISSION EXPIRES JULY 9. 2002 An~ywicki COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION UGI Utilities Inc. Plaintiff ( ) Confessed Judgment (XX) Other VS. Iyorma Anderson Defendant File No.: 01-822-CV Amount Due: $2437.94 Interest: $24.38 Atty's Corem: Costs: $ TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installmem sale, contract, or account based on a confession of judgment, but if it does, k 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 4 Dulles Drive AGS, Camp Hill, PA 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: August 14, 2001 Ant~Krzy~, wicki.~ PqBox 505, New~, PA 18938 21~62 -4390 ID No. 23754 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. , DEFE. NDANT MOVED, LEF~P NO I~ORI~IARDING ADDRESS. Sheriff' s Costs: Docketing l 8.00 Poundage ', g8 Advertising Law Library .50 Prothonotary t. 00 Mileage 9.75 Misc. Surcharge 20.00 Levy Post Pone Sale Garnishee Advance Costs: 150. O0 Sheriff's Costs: 5'0 .~3~ Refunded to Atty on I i / 5 / 0 l Sworn and Subscribed to before me this ?~ day of_.~.a~.. ~ 2oo pgot~onotary So Answers; R. Thomas Kline, Sheriff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO.__ COUNTY OF CUMBERLAND) TO THE SHERIFF OF C~nberland COUNTY: TO satisfy the debt, interest and costs due UGI Util±ties, Thc. from Iyonna Anderson, 4 Dulles Drive AG8, Camp Hill, PA 01-822 CIVIL 13JX TERM CIVIL ACTION - LAW PLAINTIFF(S) (~) You are directed to levy upon the properly of the defendant(s) and to sell_ to 4 Dulles Drive AG8, C~np H~ill, PA _DEFENDANT(S) All property belonqJ~q (2) You are also directed to attach the property ol 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/are 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 nolify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $2437.94 __ L.L._ $.50 Interest $24.38 Due Prothy $1.00 Alty's Corem % Other Costs Arty Paid $109.30 __ Plainlirf Paid Date: REQUESTING PARTY: Name Address: September 28, 2001 Anthony P, Krzywicki, Esq. PO Box 505 · . by; Curtis R. Long Prothonotary, Civil Division N~w Hop,:,, P,~ 1Rq38 Attorney for: Pleinti'Ff -- Telephone: 215-862-4390 Supreme Court ID No. 23754