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Home My WebLink About08-4222IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. JASON A MOTT Defendant No. COMPLAINT IN CIVIL ACTION 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. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6433006 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No. JASON A MOTT Defendant 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, you must take action within twenty (20) days after this complaint and notice are served, by entering 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, FORTH BELOW TO FIND OUT WHERE YOU CAN GGO TO OR ET LEGAL HELP PHONE THE OFFICE SET LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff is a corporation with offices at 7465 N.W. 49TH ST, LAUDERHILLE, FL 33319- 0000. 2. Defendant is an adult individual residing at 35 REAR NORTHEAST ST CARLISLE,PA 17013. COUNT I - ACCOUNT NO. 8589316373 3. At the specific instance and request of Defendant, CARLISLE REGIONAL MEDICAL CENTER, provided certain medical services to Defendant. 4. This obligation was subsequently assigned to Plaintiff for value. 5. Defendant, JASON A MOTT, received and accepted the aforementioned medical services which were provided by Plaintiffs assignor 6. The prices charged by Plaintiff's assignor were the prices that Defendant, JASON A MOTT, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, JASON A MOTT, in the amount of $489.62 as of MAY 30 2008. 8. Plaintiff claims interest at the legal rate of six (6%) percent per annum from MAY 30 2008. 9. 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, JASON A MOTT, in the amount of $489.62 with continuing interest thereon at the rate of 6% per annum from MAY 30 2008 and costs. COUNT II - ACCOUNT NO. 8589322587 10. At the specific instance and request of Defendant, CARLISLE REGIONAL MEDICAL CENTER, provided certain medical services to Defendant. 11. This obligation was subsequently assigned to Plaintiff for value. 12. Defendant, JASON A MOTT, received and accepted the aforementioned medical services which were provided by Plaintiff s assignor 13. The prices charged by Plaintiff s assignor were the prices that Defendant, JASON A MOTT, agreed to pay. 14. Plaintiff avers that there is a balance due and owing from Defendant, JASON A MOTT, in the amount of $768.09 as of MAY 30 2008. 15. Plaintiff claims interest at the legal rate of six (6%) percent per annum from MAY 30 2008. 16. 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, JASON A MOTT, in the amount of $768.09 with continuing interest thereon at the rate of 6% per annum from MAY 30 2008 and costs. COUNT III - ACCOUNT NO.8589330372 17. At the specific instance and request of Defendant, CARLISLE REGIONAL MEDICAL CENTER, provided certain medical services to Defendant. 18. This obligation was subsequently assigned to Plaintiff for value. 19. Defendant, JASON A MOTT, received and accepted the aforementioned medical services which were provided by Plaintiff's assignor 20. The prices charged by Plaintiff s assignor were the prices that Defendant, JASON A MOTT, agreed to pay. 21. Plaintiff avers that there is a balance due and owing from Defendant, JASON A MOTT, in the amount of $648.02 as of MAY 30 2008. 22. Plaintiff claims interest at the legal rate of six (6%) percent per annum from MAY 30 2008. 23. 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, JASON A MOTT, in the amount of $648.02 with continuing interest thereon at the rate of 6% per annum from MAY 30 2008 and costs. COUNT I I - ACCOUNT NO. 8589354186 24. At the specific instance and request of Defendant, CARLISLE REGIONAL MEDICAL CENTER, provided certain medical services to Defendant. 25. This obligation was subsequently assigned to Plaintiff for value. 26. Defendant, JASON A MOTT, received and accepted the aforementioned medical services which were provided by Plaintiff's assignor 27. The prices charged by Plaintiff's assignor were the prices that Defendant, JASON A MOTT, agreed to pay. 28. Plaintiff avers that there is a balance due and owing from Defendant, JASON A MOTT, in the amount of $658.58 as of MAY 30 2008. 29. Plaintiff claims interest at the legal rate of six (6%) percent per annum from MAY 30 2008. 30. 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, JASON A MOTT, in the amount of $658.58 with continuing interest thereon at the rate of 6% per annum from MAY 30 2008 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. 9(1 KCZAN, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219(412) 434-7955 WWR#:6433006 05/13/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 361 CARLISLE ALEXANDER SPRI REGIONAL MEDICAL CTR NG RD CARLISLE AS OF 05/12/08 -- PA 17015 ----------------- PHONE (717) 960-1680 PATIENT: TO: MOTT MOTT, JASON A JASON A -------------- - F/C: W P/T: E A/C: ____ ----------------- 9316373 DSC CODE: 01 , 35 REAR NORTHEAST ST ADMISSION: 07/22/05 rART.TCLE PA 17013 DISCHARGE: 07/22/05 A M O U N T 14.18 475.44 489.62- ----------------------0.00------------ TOTAL 0.00 SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY= * CMD:I=DAR,2=PAT 4=DETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD EXHIBIT i 05/13/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 05/12/08 361 ---- ALEXANDER SPRING RD CARLISLE PA 17015 --- -------------------------- PHONE (717) 960-1680 PATIENT: MOTT, JASON A ---------------- F/C: P P/T: E A/C: ------------------------ 9322587 DSC CODE: 01 TO: MOTT, JASON A ADMISSION: 10/08/05 DISCHARGE: 10/08/05 .35 NORTH EAST ST CART.TCT T' PA 17013 A M O U N T 292.65 475.44 768.09- --------------------------------------------------------------------- TOTAL 0.00 SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY= CMD:I=DP,R,2=PAT 4=DETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD EXHIBIT 05/13/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 05/12/08 361 ---- ----- ALEXANDER SPRING RD CARLISLE PA 17015 --- ----------- PHONE (717) 960-1680 PATIEN`P: MOTT, JASON A ------------------------------- F/C: P P/T: E A/C: ------------------------ 9330372 DSC CODE: 01 TO: MOTT, JASON A ADMISSION: 01/24/06 DISCHARGE: 01/24/06 35 NORTH EAST ST CARLISLE PA 17013 AMOUNT 19.47 16.88 611.67 648.02- ----------------------------------------------------------------------------- TOTAL 0.00 SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY= CMD:I=DAR,2=PAT 4=DETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD EXHIBIT 05/13/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 05/12/08 361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 ---- ---- PATIENT: --- ---------- MOTT, JASON A -------------------------------- F/C: P P/T: E A/C: ------------------------ 9354186 DSC CODE: 01 TO: MOTT, JASON A ADMISSION: 11/13/06 DISCHARGE: 11/13/06 35 NORTH EAST ST CARLISLE PA 17013 A M O U N T 11.40 14.77 58.86 573.55 658.58- ----------------------------------------------------------------------------- TOTAL 0.00 SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY= CMD:I=DAR,2=PAT KDETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD EXHIBIT The undersigned does hereby verify subject to the penalties of 18 14904 relating to unsworn falsifications to authorities, that she is LIMA MQM OSSO (Name) TI E P SII) NT ('P OPER-A IO 5 of INI'lrltNA?`I(?NAI? PaRT'FOLIC1 INC., plaintiff (Title) (Company) herein, that she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of her knowledge, information and belief WWR W i? ?v ? p C (.?? cr% (,) d t'j 1 ?r _ . SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-04222 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS MOTT JASON A R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT MOTT JASON A but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT 35 REAR NORTH EAST STREET , MOTT JASON A NOT FOUND , as to CARLISLE, PA 17013 NOT KNOWN AT GIVEN ADDRESS. CURRENT RESIDENT HAS BEEN THERE FOR 1 1/2 YEARS. Sheriff's Costs: Docketing 18.00 Service 5.00 Not Found 5.00 Surcharge 10.00 00 38.00 Sworn and Subscribed to before me this day of So answers: j-t'rR.Th#ffias Kline Sh riff of Cumberland County WELTMAN WEINBERG REIS 07/23/2008 A. D.