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Home My WebLink About08-3486THIS IS AN ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED TABAS & ROSEN, P.C. BY: LEWIS C. TRAUFFER, ESQUIRE Attorney I.D. #60267 1601 Market Street, Suite 2300 Philadelphia, PA 19103 (215) 569-5050 MILTON S. HERSHEY P.O. Box 853 Hershey, PA 17033 VS Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MEDICAL CENTER : NO. 02- 348(0 CIVIL ACTION EVANGELOS DASKALAKIS & PAMELA DASKALAKIS, h/w 226 Bella Vista Drive Marysville, PA 17053 COMPLAINT - CIVIL ACTION NOTICE 3"'t( -rent, 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 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717)249-3166 or(800)990-9108 COMPLAINT - CIVIL ACTION COUNT I THE MILTON S. HERSHEY MEDICAL CENTER VS. PAMELA L. DASKALAKIS 1. Plaintiff is a non-profit corporation located at the address indicated in the caption hereof. 2. Count I defendant is an individual who resides at the address indicated in the caption hereof. 3. As the result of a certain medical condition, Count I defendant was treated at the plaintiff hospital on Oct. 29, 2005 thru Oct. 31, 2005. 4. The amounts, quantities and nature of the medical care rendered, the date on which said medical care was rendered, and the charges therefore are set forth in Exhibit "A", which is incorporated herein as if set forth at length. 5. Said medical care was commensurate with the condition of Count I defendant and was necessary for the health and welfare of Count I defendant. 6. At or about the time of Count I defendant's treatment at the plaintiff hospital, implied, constructive and oral con- tracts arose between Count I defendant and plaintiff by the terms of which Count I defendant became obligated to pay plaintiff the charges incurred for the medical care rendered by plaintiff to Count I defendant. 7. Count I defendant refuses to pay the balance due although plaintiff has made demand that Count I defendant do so. 8. As a result of the foregoing, there is due and owing from Count I defendant to plaintiff the sum indicated in Exhibit "All WHEREFORE, plaintiff demands judgment against Count I defendant for the sum of $10,429.20 plus six percent (6%) interest per annum from the date of discharge to the date of judgment, record costs and non-record costs. COUNT II THE MILTON S. HERSHEY MEDICAL CENTER VS. EVANGELOS DASKALAKIS 9. The foregoing paragraphs are incorporated herein as if set forth at length. 10. Count II defendant is an individual who resides at the address indicated in the caption hereof. 11. Count II defendant is the spouse of Count I defendant. 12. Defendant's spouse was treated at the plaintiff hospi- tal on Oct. 29, 2005 thru Oct. 31, 2005. 13. Said medical care was commensurate with the condition of defendant's spouse and was necessary for the health and welfare of defendant's spouse. 14. Count I defendant is indigent. 15. Count II defendant is financially able to pay for the medical care of Count I defendant. 16. By virtue of the marital relationship, the Act of 1937, June 24, P.L. 2045, Sec. 3, as amended, 23 Pa. Cons. Stat. Ann. Sec. 4603 and Article 1, Sec. 28 of the Pennsylvania Constitution and all other applicable statutes, laws and ordinances, Count II defendant has a duty to support Count I defendant. 17. Count II defendant has been unjustly enriched by plain- tiff's discharge of Count II defendant's duty to support Count I defendant, which duty Count II defendant failed to perform. 18. Count II defendant refuses to pay the balance due, although plaintiff has made demand that Count II defendant do so. 19. As a result of the foregoing, there is due and owing from Count II defendant to plaintiff the sum indicated in Exhibit "A" WHEREFORE, plaintiff demands judgment against Count II defendant for the sum of $10,429.20 plus six percent (60) interest per annum from the date of discharge to the date of judgment, record costs and non-record costs. TABAS & ROSEN, P.C. WE IS C. TRAUVF R, ESQUU E- Attorney for Plaintiff MS HERSHEY MEDICAL CENTER PAGE: 500 UNIVERSITY DRIVE HERSHEY, PA 17033 Statement on: 04/03/07 at 03:44 PM Guarantor: DASKALAKIS PAMELA L 226 BELLA VISTA DR MARYSVILLE, PA 17053-0004 Patient: DASKALAKIS PAMELA L Visit #: 6093267 -------------------------------------------------------------------------------- Date I Svc Code I Description I Unitsi Debits I Credits -------------------------------------------------------------------------------- 10/29/05 10158 M OB/GYN PRIVATE RM 1 10/29/05 105036 HEMATOCRIT 1 10/29/05 245854 BUTORPHANOL TARTRATE 2 10/29/05 246353 OXYTOCIN 10 UNITS 3 10/29/05 274275 HEPARIN SOD 1000U/1ML 2 10/29/05 274480 FENTANYL 2MCG/ML BUP 1 10/29/05 439011 SPEC CARE OBSTETR HI 1 10/29/05 439012 DELIVERY 1 10/29/05 439166 RECOVERY RM - PER 15M 8 10/29/05 502010 EPIDURAL ANESTHESIA 1 10/29/05 503100 EPIDURAL TRAY 2 10/29/05 621053 I V LACTATED RINGERS 1 10/29/05 621054 IV LACTATED RINGERS 1 3 10/29/05 627070 IV EXT SET 90" W/FLAS 2 10/29/05 670724 TRANSDUCER INTRAUTERI 2 10/30/05 10158 M OB/GYN PRIVATE RM 1 10/30/05 246605 RUBELLA VACCINE 1 VIA 1 10/30/05 250371 IBUPROFEN 600MG 4 10/31/05 250371 IBUPROFEN 600MG 1 11/17/05 920001 BLUE CROSS CONTR ADJ -1 08/09/06 920001 BLUE CROSS CONTR ADJ 1 01/31/07 980090 HOSPITAL BAD DEBT W/O -1 017-11-107-- --- 1-- -HaSPI TALBAD DEBT PLA -- - -1 985.00 17.00 9.95 20.65 .7.30 19.45 1277.00 614.00 816.00 130.00 102.00 6.00 18.00 34.00 112.00 985.00 52.85 12.00 3.00 2010.84- 2010.84 5221.20- ------- -------------------------------------------------------------------------------- * - Not posted ( Balance: 5221.20 -------------------------- A-1 The Milwn., The COllep L DASKALAKIS A VISTA DR MLLE PA 17053-9640 ACCOUNT # 904269 IF ANY QUESTIONS, PLEASE CONTACT: MMSHMC STATEMENT DATE: 04108!07 LAST STATEMENT DATE: Coll 9106 6093267 PERFORMED BY: VIRGINIA E HALL MD DIVISION OF WOMENS HEALTH PLACE OF SVC: INPATIENT VAGINAL DELIVERY OB CARE 3360.00 BC PBYS PAYMENT BC PHYS CONTRACTUAL AD BC OFFSET BC OFFSET B/C OFFSET BS TAKEBACK B/C OFFSET BC PHYS CONTRACTUAL ADJ BALANCE TRANSFER TO GUAR 10/29/05 59400.GC 664.11 01/11/06 01/11/06 01/18/06 01/25/06 02/01/06 02/08/06 02/15/06 01/11/06 10/06/06 PERFORMED BY: JANISE PROZESKY MD DIV OF ANESTHESIA 10/29/05 M%D.GC 664.11 21 VAGINAL DELIVERY ONLY 1848.00 59400 12/07/05 BC PWS PAYMENT 0 3360.00 .OD INDICATES NEM FINANCIAL ACTIVITY SINCE LAST BILL. I IF YOU HAVE ANY QUESTIONS ABOUT THE AMOUNT YOUR INSURANCE COMPANY PAID, CONTACT THEM DIRECTLY. FOR ANY OTHER QUESTIONS REGARDING YOUR BALANCE, PLEASE CONTACT OUR OFFICE. IF PAYMENT HAS BEEN MADE, THANK YOU AND DISREGARD THIS BILL. RNMT3 THANK YOU FOR USING MSHMC PHYSICIANS GROUP FOR YOUR PHYSICIAN SERVICES. IF YOU HAVE ANY QUESTIONS REGARDING THIS BILL, PLEASE CONTACT US AT 717-531-5069 OR 800-254-2619, BETNEEN 8:DDAM AND 5:30PM MONDAY THROUGH WEDNESDAY OR BETNEEN 8:OOAM AND 4:30PM THURSDAY AND FRIDAY. FED TAX ID # 2 1705.20- 1228.50- 251.74 60.00 180.00 244.90 968.56 1228.50 CHECK BOX AND ENTER ANY ADDRESS OR INSURANCE CORRECTIONS ON BACK 9TA DR PA 17053-9640 STATEMENT DATE: 04103107 LAST STATEMENT DATE: 09119106 0TAX1002511 m 5208.00 STATEMENT DATE: GUARANTOR RESPONSIBILITY: MINIMUM PAYMENT: BFb 041031+07 $ 5208.00 $ 5208.00 MSHMC PHYSICIANS GROUP BILLING SERVICES P O BOX 654 HERSHEY PA 17033.0854 00000904269 UP 0000000000520800040307 malt MSHMC PHYSICIANS GROUP PAMELA L DASKALAKIS TO., 226 BELLA VISTA DR PO BOX 643313 MARYSVILLE PA 17053-9640 PITTSBURGH PA 15264-3313 OFFICE USE ONLY CHECK ONE FOR CREDIT CARD PAYMENT, PLEASE FILL IN INFORMATION BELOW (! 1 1 1 1--111 111--1 1 111 904269 wC CARD NUMBER D(P DATE VISA co 5208.04/24! HG; F6130 -DISC CARDHOLDER NAME (PRINT) TYP : DMND CREDIT CARD SIGNATURE MSHMC PHYSICIANS GROUP ? CHECK BOX AND ENTER ANY ADDRESS OR INSURANCE CORRECTIONS ON BACK A 3 ACCOUNT # 904269 IF ANY QUESTIONS, PLEASE CONTACT: MSHMC PATIENT FINANCIAL SERVICES FF DASKALAKIS, PAMELA #904269 $5,221.20 (Hosp) • 5,208.00 (Phys) VERIFICATION LINDA SCHLADER hereby states that she is the Team Manager, Customer Service of the Milton S. Hershey Medical Center and verifies that the statements made in the foregoing pleading are true and correct to the best of her knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. LINDA SCHLADER DATE :: (J? i- o0 00 cn O (3? b b C_) r"ll ce ze r `0 N CO n .7j O . ?1 CASE NO: 2008-03486 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MILTON S HERSHEY MEDICAL CTR VS DASKALAKIS EVANGELOS ET AL STEPHEN BENDER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon DASKALAKIS EVANGELOS the DEFENDANT , at 0915:00 HOURS, on the 21st day of June 2008 at 226 BELLE VISTA DRIVE MARYSVILLE, PA 17053 by handing to EVANGELOS DASKALAKIS 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 16.00 Affidavit .00 Surcharge 10.00 .00 1??241(7g 44.00 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 06/23/2008 TABAS & ROSEN By. Dep Sheriff A. D. 1 SHERIFF'S RETURN - REGULAR CASE NO: 2008-03486 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MILTON S HERSHEY MEDICAL CTR VS DASKALAKIS EVANGELOS ET AL STEPHEN BENDER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon DASKALAKIS PAMELA the DEFENDANT , at 0915:00 HOURS, on the 21st day of June , 2008 at 226 BELLE VISTA DRIVE MARYSVILLE, PA 17053 by handing to EVANGELOS DASKALAKIS, HUSBAND 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 Service Affidavit Surcharge 4l14 j6r 9?- ? Sworn and Subscibed to before me this of So Answers: 6.00 ? .00 .00 ' 10.00 R. Thomas Kline .00 16.00 06/23/2008 TABAS & ROSEN By: ? day eputy Sheriff , A. D. DaviciD. Buell' Prothonotary Office o the Trothonotag Cum6errancf County, (Pennsylvania KirkS. Sofionage, 'SQ Solicitor 6c2--.34/gk:, CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE —THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square C Suite100 ® CarCisCe, PJ q None 717 240-6195 et (F 717 240-6573