The URL can be used to link to this page

Home My WebLink About01-49101721U7 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Paul's Christian g~bbey Inspirations Defendant Civil Action - No. 01 - 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 THAT IF YOU PAIL TO DO SO THE CASE 5LAY 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 CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CA~ GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 (717) 249-3166/(800) 990-9108 1721U7 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff VS Paul's Christian Abbey Inspirations Defendant Civil Action ARBITRATION - In Law COMPLAINT t. 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, Paul's Christian Abbey Inspirations, is a Unincorporated Association doing business at 4902 Carlisle Pike #352, Mechanicsburg, PA 17050. COUNT 1 UGI Utilz m~- Inc. vs. Paul's Christian Abbey Inspirations 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 Paul's Christian Abbey Inspirations. 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. 1721U7 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. 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: 1721U7 Amount Past Due: Court Costs: Service Costs: TOTAL $ 1051.55 $ 45.50 $ lOO.OO $ 1197.05 Respectfully submitted, DATED: July 12, 2001 Krzywicki and Associates New,ope, PA 18938 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: 7//Z/~/ UGI Utilities, Inc. Jam~ R. Gallagher 1721U7 STATEMENT OF ACCOUNT Paul's Christian Abbey Inspirations established the following accounts with UGI Utilities Inc. with the following balances and charges: Account Number / Acct Type Service to: Balance Service Address ================================================================================ 213-402-4609-34 G 3876 Union Deposit Road Harrisburg, PA 17109 / / $1051.55 Total Delinquent Balance: $1051.55 EXHIBIT A 1721U7 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse * Carlisle, PA 17013 ~rtis R. Long Prothonota~ TO: Paul's Christian Abbey Inspirations 4902 Carlisle Pike #352 Mechanicsburg, PA 17050 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Paul's Christian Abbey Inspirations Defendant Civil Action - No. 01-4910 ARBITRATION In Law NOTICE P~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 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.2 1721U7 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Paul's Christian Abbey Inspirations Defendant Civil Action - No. 01-4910 ARBITRATION In Law PRAECIPE FOR JUDGMENT AGAINST DEFENDANT FOR FAILURE TO PLEAD To the Prothonotary: COUNT 1 UGI Utill 1~-~ Inc. vs. Paul's Christian Abbey Inspirations Kindly enter default judgment in favor of Plaintiff, UGI Utilities Inc. and against Defendant, Paul's Christian Abbey Inspirations for failure to plead to Plaintiff's Complaint as follows: Amount Past Due: $ 1051.55 Court Costs: $ 45.50 Service Costs: $ 100.00 TOTAL $ 1197.05 together with interest thereon from the date of judgment forward and all costs of this action. 1721U7 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, Paul's Christian Abbey Inspirations, is 4902 Carlisle Pike #352, Mechanicsburg, Cumberland County, PA 17050. DATED: December 21, 2001 Krzywic~sociates BY :Antho/p. /~'Pz~/~' ki 49 N~th~gan Rc~%~L--~'~ P.o BoFs05 New/H~e, PA 18938 21 -~'62-4390 Attorney for Plaintiff Attorney I.D. 23754 CASE NO: 2001-04910 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS PAUL'S CHRISTIAN ABBEY INSPIRA RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon. PAUL'S CHRISTIAN ABBEY INSPIRATIONS the DEFENDANT , at 1937:00 HOURS, at 432 PAWNEE DRIVE MECHANICSBURG, PA 17055 on the 18th day of September, 2001 STELLAANN FINE ADULT a true and attested copy of COMPLAINT & NOTICE by handing to IN CHARGE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 15.60 Affidavit .00 Surcharge 10.00 .00 43.60 Sworn and Subscribed to before me this day of A.D. Prothonotary So Answers: R. Thomas Kline 09/19/2001 By: ~ . ~ / ~eputy Sheriff 1721U7 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Paul's Christian Abbey Inspirations Defendant Civil Action No. 01-4910 ARBITRATION - In Law NOTICE TO: Paul s Christian Abbey Inspirations 4902 Carlisle Pike #352 Mechanicsburg, PA 17050 Date: November 21, 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 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 1721U7 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff vs Paul's Christian Abbey Inspirations Defendant Civil Action No. 01-4910 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, Paul's Christian Abbey Inspirations, 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: December 21, 2001 Krzywicki~sociates BY:Anthony Z K~cki 49 Nort~ S~an R~ad P.O. B~x/F05 [ / New H~e~, PA 1892~--'~ 215-86-2-4390 Attorney for Plaintiff Attorney I.D. 23754 1721U7 In the Court of Common Pleas of CUMBERLg2',ID County, Pennsylvania UGI Utilities Inc. Plaintiff vs Paul's Christian Abbey Inspirations Defendant Civil Action - No. 01-4910 ARBITP_ATION In Law 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, Paul's Christian Abbey Inspirations, 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, Paul's Christian Abbey Inspirations, is more than 18 years of age and currently resides at 4902 Carlisle Pike #352, Mechanicsburg, PA 17050. invest3igatIiohnaV%n~SmCae~etag~.~sd atfh~i~abv°.~ inf°rmatia°untbhoYrlP.~.s°nal Ant' n ~ K' 'r ~ u~o n~,,~. ~rzywic~l M~OHELLE NOTARy PUBLIO MY COMMISSION EXP~RE~, JULY 9, 2002