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Home My WebLink About08-4223IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. B ELIZABETH FANUS Defendant No. ?) - ?Qo-0 41? 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#6431714 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. B ELIZABETH FANUS 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, 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 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 1128 PETERSBURG RD BOILING SPRING,PA 17007 . COUNT I - ACCOUNT NO. 8587598575 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, B ELIZABETH FANUS, received and accepted the aforementioned medical services which were provided by Plaintiff's assignor 6. The prices charged by Plaintiffs assignor were the prices that Defendant, B ELIZABETH FANUS, agreed to pay. 7. A copy of Plaintiffs statement is attached and marked as Exhibit "I". 8. Plaintiff avers that there is a balance due and owing from Defendant, B ELIZABETH FANUS, in the amount of $1,120.98 as of MAY 29 2008. 9. Plaintiff claims interest at the legal rate' of six (6%) percent per annum from MAY 29 2008. 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, B ELIZABETH FANUS, in the amount of $1,120.98 with continuing interest thereon at the rate of 6% per annum from MAY 29 2008 and costs. COUNT II - ACCOUNT NO. 8589323119 11. At the specific instance and request of Defendant, CARLISLE REGIONAL MEDICAL CENTER, provided certain medical services to Defendant. 12. This obligation was subsequently assigned to Plaintiff for value. 13. Defendant, B ELIZABETH FANUS, received and accepted the aforementioned medical services which were provided by Plaintiff's assignor 14. The prices charged by Plaintiff s assignor were the prices that Defendant, B ELIZABETH FANUS, agreed to pay. 15. A copy of Plaintiffs statement is attached and marked as Exhibit "2". 16. Plaintiff avers that there is a balance due and owing from Defendant, B ELIZABETH FANUS, in the amount of $ 40.00 as of MAY 29 2008. 17. Plaintiff claims interest at the legal rate of six (6%) percent per annum from MAY 29 2008. 18. 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, B ELIZABETH FANUS, in the amount of $ 40.00 with continuing interest thereon at the rate of 6% per annum from MAY 29 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. M ZAN, 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#:6431714 05/13/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 05/12/08 3F1. ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 .---- ------- ------------------------------------------------------------------ PATIEN7: FANUS, B ELIZABETH F/C: B P/T: 0 A/C: 7598575 DSC CODE: 01 T0: FANUS, B ELIZABETH ADMISSION: 05/26/06 DISCHARGE: 05/26/06 1128 PETERSBURG RD BOILING SPRING PA 17007 INS CD: 200/BS1 PBSHM 378 PPO_ GROUP 02899990 POL ID: ZAR103847 A M O U N T 5,122.23 1,418.20 395.09 356.58 1,869.19 1,409.11 140.00 4,983.94- 5,726.46- --- -------------------------------------------- TOTAL 0.00 SEI * DATE/MDCY= * TO/MDCY= CML 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 3?1 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 ---- ------- ------------------------------------------------------------------ PATIENT: FANUS, B ELIZABETH F/C: B P/T: E A/C: 9323119 DSC CODE: 01 TO: FANUS, B ELIZABETH ADMISSION: 10/15/05 DISCHARGE: 10/15/05 1128 PETERSBURG RD BOILING SPRING PA 17007 INS CD: 200/BS1 PBSHM 378 PPO GROUP 02899990 POL ID: ZAR103847 A M O U N T 6.37 301.60 620.16 573.55 815.95- 685.73- ----------------------------------------------------------------------------- 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 The undersigned does hereby verify subject to the penalties of 18 PA.C. S. 14904 relating to unsworn falsifications to authorities, that she is _L A Mt)MROSSQ (N) YMEY-UMEN C?- MR&T ONS-of W-URNAIMNAL L ., plaintiff (Title) (Comfy) herein, that she is duly authorized to snake this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are try and correct to the best of her knowledge, information and belief. WWR# f, 1 o V , SHERIFF'S RETURN - REGULAR CASE NO: 200$-04223 P COMMONWEALTHIbF PENNSYLVANIA: COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC FANUS B ELI VS MICHELLE GUT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon FANUS B ELI the DEFENDANT ? , at 1931:00 HOURS, on the 21st day of July , 2008 at 1128 PETERSBURG ROAD BOILING SPRINGS, PA 17007 RONALD FANUS by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Cost Docketing Service Affidavit Surcharge So Answers: 18.00 7.00 _ .00 10.00 Thomas Kline 00 35.00 07/22/2008 WELTMAN WEINBERG REIS ?_.._. -7/212/06 txAi Sworn and Subscibed to By: before me this day Deputy Sheriff of --- - A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. B ELIZABETH FANUS Defendant No.08-4223 PRAECIPE FOR ENTRY OF JUDGMENT BY CONSENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I.D. #90963 Weltman,Weinberg & Reis CO., L.P.A. 1400 Kopper Building 436 Seventh Avenue Pittsburgh, PA 15219 WWR#6431714 1120.98 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff Vs. Civil Action No. 08-4223 B ELIZABETH FANUS Defendant PRAECIPE FOR JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment against Defendant, B ELIZABETH FANUS, in the amount of $1120.98 plus costs, based upon the consent of the parties. CONSENTED TO: WELTMAN, WEINBERG & REIS CO., L.P.A., By: Attorney for Plaintiff B ELIZABETH FANUS, By: 0 "z? a?N??aFinl?4 Defendant WWR#6431714 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. 08-4223 B ELIZABETH FANUS Defendant STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment in favor of Plaintiff and against the Defendant, B ELIZABETH FANUS, above-named, in the amount of $1120.98 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment by Consent, as follows: Defendant admits indebtedness to Plaintiff in the amount of $1120.98 with continuing interest thereon at a rate of 6% per annum plus costs from date of judgment. 2. To secure the repayment of said indebtedness, Defendant agrees that Judgment by Consent will be entered in favor of the Plaintiff and against the Defendant, B ELIZABETH FANUS, in the amount of $1120.98 plus continuing interest thereon at the rate of 6% per annum from date of judgment and costs. Plaintiff agrees not to execute on its Judgment so long as Defendant causes to be delivered to Plaintiff the following payments in full by 12:00 NOON on the following dates: (a) $100.00 due by 8/10/08; (b) $100.00 due on the 10TH day of each consecutive month thereafter until the Judgment amount plus accrued interest and costs are paid in full. 4. All payments are to be made payable to the order of "INTERNATIONAL PORTFOLIO INC" 5. The first payment due under this agreement is to be received at the offices of Weltman, Weinberg & Reis, Co., L.P.A., 436 Seventh Avenue, Suite 1400, Pittsburgh, PA 15219. All future payments are to be mailed to the offices of Weltman, Weinberg & Reis, Co., P.O. Box 5430, Cleveland, OH 44101- 0430. 6. In the event of default, each payment received shall be first attributed to costs, interest and then to principal. 7. Time is of the essence of this agreement and should the Defendant fail to have in the hands of Plaintiff or Plaintiff's counsel any payment in full within five (5) calendar days of the stated due date, then Plaintiff shall be immediately free to issue Execution as well as pursue all other remedies, in law or in equity, to collect the full balance of the Judgment entered hereunder plus appropriate additional.interest and costs. 8. No act or omission of the Plaintiff, nor of anyone alleged to be acting on its behalf, shall constitute a waiver, estoppel, or any other excuse for non-performance of any duty undertaken by the Defendant in this Stipulation which the parties agree is final and complete. day of 9. Intending to be legally bound, the parties set their hands and seals thiDIP, 20 0'?d WELTMAN, WEINBERG & REIS CO., L.P.A. / Matthew D. Urban, Esquire PA I.D. #90963 Weltman,Weinberg & Reis CO., L.P.A. 1400 Kopper Building 436 Seventh Avenue Pittsburgh, PA 15219 WWR No. 6431714 By: IUA Defendant, B EL ETH FANUS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. ELIZABETH B FANUS Defendant(s) No. 08-4223-CIVL PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA I.D. # 42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7999 W WR#6431714 TIC J ? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff VS. Civil Action No. 08-4223-CIVL ELIZABETH B FANUS Defendant(s) PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. W odt, PA I.D. # 42 4 WELTMA INB 1400 Kop er uildin 436 Sev Avenue Pittsburgh, PA 15219 (412) 434-7999 WWR #6431714 Sworn to and subsSribV before me this day of A us NO RY P LIC Esquire & REIS CO., L.P.A. CO.ARA-14WEALTH OF PENNSYLVANIA Notarial Seal Wendy L. Gault, Notary Public $ 2y of Pittsburgh, Allegheny County " ?rijrnisSiCn ?xtSrtQ July 2010 OF THE PR^" pP )-NF0TARY 2009 OCT -b AN 8: 4 Y. t.i .?'JI V1 Woo Po A7" Cr,-k U3(339 PT*,231q-18