The URL can be used to link to this page

Home My WebLink About03-0573IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BEVERLY ENTERPRISES- PENNSYLVANIA, INC. DBA CAMP HILL CARE CENTER Plaintiff VS. CHARLES W. MITCHELL, SR. COMPLAINT IN CIVIL ACTION Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02699988 iN THE CouRT OF coMMON PLEAS cuMBERLAND coUNTY, PENNSYLVANIA CIVIL D~VISION BEVERLY ENTERPRISES ' PENNSYLVANIA, INC. DBA CAMP HiLL CARE CENTER Plaintiff VS. CHARLES W. MITCHELL' SR. Defendant Civil Action No. 03 - COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, y6~ must take action within twenty (20) days after this complaint and notice are sewed, by enterincj a written appearance personally or by an 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 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 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 LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff is a corporation with offices at 46 Erford Road, Camp Hill, PA 17011. 2. Defendant is an adult individual residing at 5016 Trindle Road, Mechanicsburg, PA 17055. 3. At the specific instance and request of Ruth E. Mitchell, Plaintiff provided certain medical services to Ruth E. Mitchell. 4. Ruth E. Mitchell received and accepted the aforementioned medical services which were provided by Plaintiff. 5. The prices charged by Plaintiff were the prices that Ruth E. Mitchell agreed to pay. 6. Plaint'iff avers that there is a balance due and owing from Defendant in the amount of $1,146.90 as of December 26, 2000. 7. Defendant, Charles W. Mitchell, Sr., Ruth E. Mitchell's spouse, is statutorily liable for all medical necessities provided to said spouse. 8. Plaintiff claims interest at the legal rate of six (6%) percent per annum from December 26, 2000. 9. Plaintiff avers that interest calculated at the aforesaid rate from December 26, 2000 to January 20, 2003 amounts to $142.34. 10. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the aforementioned balance, or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Charles W. Mitchell, Sr., in the amount of $1,289.24 with legal interest at the rate of 6% per annum from January 20, 2003 and costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. William T. Molczan, Esq/~fe PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#:02699988 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsifications to authorities, that he/she is .~'~/7~/'4 ~Z'/'/'/~'7~/¢ (Name) ~'~0//¢(7¢/~/1 /¢/~',,(z.~,£ of /~'1~/~¢' ~/Z¢?.~/C~3~'J , plaintiff herein, that (Title) v (6ompany) he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint are true*.and correct to the best of his/her knowledge, information and belief. (Signature) Wwr"¢ 02699988 SHERIFF'S RETURN - REGULAR CASE NO: 2003-00573 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BEVERLY ENTERPRISES ET AL VS MITCHELL CHARLES W SR HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MITCHELL CHARLES W SR the DEFENDANT , at 2013:00 HOURS, on the 14th day of February , 2003 at 5016 TRINDLE ROAD MECHANICSBURG, PA 17055 by handing to CHARLES W MITCHELL 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 8.28 Affidavit .00 Surcharge 10.00 .00 36.28 Sworn and Subscribed to before me this 7 ~ day of ~ ~2. &'6~ A.D. ' Prothonotary ' So Answers R. Thomas Kline 02/19/2003 WELTMAN WEINBERG REIS By: Deputy/~heri f f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BEVERLY ENTERPRISES-PENNSYLVANIA, INC. Plaintiff VS. CHARLES W. MITCHELL, SR. Defendant No. 03-573 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. 11-47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02699988 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BEVERLY ENTERPRISES-PENNSYLVANIA, INC. Plaintiff VS. CHARLES W. MITCHELL, SR. Defendant Civil Action No. 03-573 CIVIL TERM in the PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, Charles W. Mitchell, Sr., above named, default of an Answer, in the amount of $1,301.53 computed as follows: Amount claimed in Complaint $1,289.24 Interest from 1/20/03 to 3/19/03 at the contract interest rate of 6% per annum $12.29 TOTAL $1,301 .§3 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. pA i.D. ¢~7~14~l~zan' Esquire/ WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02699988 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2601 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 5016 Trindle Road, Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BEVERLY ENTERPRISES-PENNSYLVANIA, INC. DBA CAMP HILL CARE CENTER Plaintiff VS. CHARLES W. MITCHELL, SR. Defendant TO: Charles W. Mitchell, Sr. 5016 Trindle Road Mechanicsburg, PA 17055 Civil Action No. 03-573 CIVIL TERM IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Mol-czan PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #02699988 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, that the parties against whom Judgment is to be entered according to the Praecipe attached are not members of the Armed Forces of the United States or any other military or non-military service covered by the Soldiers and Sailors Civil Relief Act of 1940. The undersigned further states that the information is true and correct to the best of the undersigned's knowledge and belief and upon information received from others. WELTMAN, WEINBERG & REIS CO., L.P.A. ...... William -r~. I~olczan, L:~'~uire~// PA I.D. #47437 ,~r WELTMAN, WEINBERG'& REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02699988 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BEVERLY ENTERPRISES-PENNSYLVANIA, INC. DBA CAMP HILL CARE CENTER Plaintiff VS, CHARLES W. MITCHELL, SR. Defendant No. 03-573 CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Gerianne Hannibal, Esquire PA I.D. # 66622 William T. Molczan, Esquire PA. I.D.#474:37 WELTMAN, ~NEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7c~55 WWR#02699988 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BEVERLY ENTERPRISES-PENNSYLVANIA, INC. DBA CAMP HILL CARE CENTER Plaintiff VS, Civil Action Ne. 03-573 CIVIL TERM CHARLES W. MITCHELL, SR. Defendant PRAEClPE FOR SATISFACTION OF JUDGMENT. At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. PA I.D. #66622 William T. Ivlolczan, Esquire PA. I.D.#47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #02699988 Sworn to and sub~4t~d before me this day of~~ ~OT~RY-P~_~LIC