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Home My WebLink About08-4225c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. p? J ?la?S No. COMPLAINT IN CIVIL ACTION DAVID A HEINBAUGH SR 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. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6433032 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. DAVID A HEINBAUGH SR 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 182 SMITH ROAD NEWVILLE,PA 17241. 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, DAVID A HEINBAUGH SR, received and accepted the aforementioned medical services which were provided by Plaintiff's assignor 6. The prices charged by Plaintiff's assignor were the prices that Defendant, DAVID A HEINBAUGH SR, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, DAVID A HEINBAUGH SR, in the amount of $1,434.04 as of MAY 29 2008. 8. Plaintiff claims interest at the legal rate of six (6%) percent per annum from MAY 29 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, DAVID A HEINBAUGH SR, in the amount of $1,434.04 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. /,I)- WILLIAM T. MOLC, 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#:6433032 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: HEINBAUGH, DAVID A SR F/C: D P/T: E A/C: 9325664 DSC CODE: 01 TO: HEINBAUGH, DAVID A SR ADMISSION: 11/19/05 DISCHARGE: 11/19/05 182 SMITH ROAD NEWVILLE PA 17241 INS CD: 950/PHC LUMENOS GROUP CARLISE COMP POL ID: 142354309 -- - - - - - AMOUNT 27.16 87.44 505.92 2,239.12 857.85 390.66 630.16 2,356.61- 2,381.70- -------------------------------------------- TOTAL 0.00 SEL] * DATE/MDCY= * TO/MDCY= CMD 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 i INA. IyIC7NTI ROS-SO (Name) "VICE PRESIDENT OP C? RRAIM- 5 -of W-URNATMAAt PM=10 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# \ \ t `V V ?J V l? C.) a r? ? M ? ??'ae? r• SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-04225 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS HEINBAUGH DAVID A SR 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 HEINBAUGH DAVID A SR but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT 182 SMITH ROAD NEWVILLE, PA 17241 NOT FOUND , as to HEINBAUGH DAVID A SR DEFENDANT IS NOT KNOWN AT GIVEN ADDRESS. Sheriff's Costs: Docketing 18.00 Service 11.00 Not Found 5.00 Surcharge 10.00 .00 Y/o/OF 4?,„ y 44. 00 So answers: R. Thom Kline Sheriff of Cumberland County WELTMAN WEINBERG REIS 08/01/2008 Sworn and Subscribed to before me this day of A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. DAVID A HEINBAUGH SR Defendant No. 09 - 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#6433032 TRUE COPY FF'"Al RECORD 14 Testimony wh-rraf, i h_r urto set my hand and the seal of said Court at Carlisle, Pa. Ails ......&..... day of.. ....., °` .°. ? .............. ...... ............ . e. Prothonota ry IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. DAVID A HEINBAUGH SR 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 182 SMITH ROAD NEWVILLE,PA 17241. 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, DAVID A HEINBAUGH SR, 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, DAVID A HEINBAUGH SR, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, DAVID A HEINBAUGH SR, in the amount of $1,434.04 as of MAY 29 2008. 8. Plaintiff claims interest at the legal rate of six (6%) percent per annum from MAY 29 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, DAVID A HEINBAUGH SR, in the amount of $1,434.04 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. MOLC;AN, 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#:6433032 A05/13/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COLD: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 05/12/08 361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 ---- ------- ------------------------------------------------ PATIENT: HEINBAUGH, DAVID A SR F/C: D P/T: E A/C: 9325664 DSC CODE: 01 TO: HEINBAUGH, DAVID A SR ADMISSION: 11/19/05 DISCHARGE: 11/19/05 182 SMITH ROAD NEWVILLE PA 17241 INS CD: 950/PHC LUMENOS GROUP CARLISE COMP POL ID: 142354309 --- AMOUNT 27.16 87.44 505.92 2,239.12 857.85 390.66 630.16 2,356.61- 2,381.70- -------------------------------------------- TOTAL 0.00 SEL1 * DATE/MDCY= * TO/MDCY= CMD; 7=RETURN,8=BACKWARD, ENTER=FORWARD EXHIBIT The undersigned does hereby'erify subject to the penalties of 18 14904 relating to unsworn falsifications to authorities, that she is LINA MRO b ('blame) Y E I CJ?? f A'Y IMS of W-URNAII-0-NA r PnR T or rn mT, plaintiff (Title) (company) herein, that she is duly authorized to snake this Verification, and that the facts set forth in the foreegoit Complaint in Civil Action are true and correct to the best of her knowledge, information and belief; WWR I t G ` ! !o';? vuu? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. DAVID A HEINBAUGH SR Defendant No. 08-4225-CIVIL PRAECIPE TO REINSTATE COMPLAINT 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. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6433032 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No. 08-4225-CIVIL DAVID A HEINBAUGH SR Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By, Jamet, Esquire PA WERG & REIS CO., L.P.A. 271g 436 Pitts (412 WWR #6433032 T . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. DAVID A HEINBAUGH SR 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#6433032 I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. DAVID A HEINBAUGH SR 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 I . 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 182 SMITH ROAD NEWVILLE,PA 17241. 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, DAVID A HEINBAUGH SR, received and accepted the aforementioned medical services which were provided by Plaintiff s assignor 6. The prices charged by Plaintiff s assignor were the prices that Defendant, DAVID A HEINBAUGH SR, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, DAVID A HEINBAUGH SR, in the amount of $1,434.04 as of MAY 29 2008. Plaintiff claims interest at the legal rate of six (6%) percent per annum from MAY 29 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, DAVID A HEINBAUGH SR, in the amount of $1,434.04 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. MOLC;AN, 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#:6433032 -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: HEINBAUGH, DAVID A SR F/C: D P/T: E A/C: 9325664 DSC CODE: 01 TO: HEINBAUGH, DAVID A SR ADMISSION: 11/19/05 DISCHARGE: 11/19/05 182 SMITH ROAD NEWVILLE PA 17241 INS CD: 950/PHC LUMENOS GROUP CARLISE COMP POL ID: 142354309 A M O U N T 27.16 87.44 505.92 2,239.12 857.85 390.66 630.16 2,356.61- 2,381.70- -------------------------------------------- TOTAL 0.00 SEL1 * DATE/MDCY= * TO/MDCY= CMD; 7=RETURN,8=BACKWARD, ENTER=FORWARD EXHIBIT -.L-? The undersigned does hereby verify subject to the penalties of 18 14904 relating to unsworn falsifications to authorities, that she is _LMA hdQNT EROS O (Name) VICE PRESIDENT OF OPE ATIC)N& of IMRTIATTONAL POKEOI IO INC., plaintiff (Title) (comfy) 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# V a :z CA SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-04225 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS HEINBAUGH DAVID A SR 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 HEINBAUGH DAVID A SR but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE NOT FOUND , as to the within named DEFENDANT HEINBAUGH DAVID A SR M 135 MEDIA ROAD CARLISLE, PA 17013 CURRENT RESIDENT HAS BEEN AT GIVEN ADDRESS FOR A YEAR AND DOES NOT KNOW DEFENDANT. Sheriff's Costs: Docketing 18.00 SO answers Service 4.50 Not Found 5.00 R. T omas Kline Surcharge 10.00 Sheriff of Cumberland County .00 37.50 WELTMAN WEINBERG REIS 02/02/2009 Sworn and Subscribed to before me this day of A.D. ' jgNno,, !1Pr^t4a ilW 3HI IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. DAVID A HEINBAUGH Defendant No. 08-4225-CIVIL PRAECIPE TO REINSTATE COMPLAINT 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) 434-79555 WWR#06433032 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No. 08-4225-CIVIL DAVID A HEINBAUGH Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: U 7 James C. W brodt, Esquire PA I.D. #4 ' WELTM WEINBERG & REIS CO., L.P.A. 1400 K p rs Building 436 See th Avenue Pittsb h, PA 15219 (412) 434-79555 WWR #06433032 6 21 lui !Y:, J 410.00 ppA7W Gtr M Is(o97 e34 aa9 o4Q Sheriffs Office of Cumberland County R Thomas Kline F1 LED--',.,i-FI E Sheriff OF ? ; , ?._ r1n i 1T Ronny R Anderson f AUG 2009 Chief Deputy Jody S Smith 24 AM 10: 05 Civil Process Sergeant Edward L Schorpp Solicitor International Portfolio Inc. Case Number vs. 2008-4225 David A. Heinbaugh SHERIFF'S RETURN OF SERVICE 08/19/2009 08:34 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 19, 2009 at 2034 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: David A. Heinbaugh, by making known unto Sharon Clark, Adult in charge at 1 Cooper Circle Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $33.40 SO ANSWERS, August 20, 2009 R THOMAS KLINE, SHERIFF Deputy Sheriff INTERNATIONAL PORTFOLIO, INC. Plaintiff, VS. DAVID A. HEINBAUGH, SR. Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO: 08-4225 CIVIL TERM ANSWER TO PLAINTIFF'S COMPLAINT AND NOW this 5th day of November, 2009, come the Defendant by and through his attorneys, Irwin & McKnight, and respectfully files this Answer to the Plaintiffs' Complaint, and in support thereof aver as follows: 1. The averments of fact contained in paragraph one (1) of the Plaintiff's Complaint are admitted. 2. The averments of fact contained in paragraph two (2) are specifically denied. By way of further answer, the Defendant resides at 1 Cooper Circle, Carlisle, Pennsylvania 17015. 3. The averments contained in paragraph three (3) are specifically denied and strict proof thereof is demanded at trial. 4. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in paragraph four (4) of Plaintiff's Complaint so they are therefore specifically denied and strict proof thereof is demanded at trial. 5. The averments contained in paragraph five (5) are specifically denied and strict proof thereof is demanded at trial. 6. The averments contained in paragraph six (6) are specifically denied and strict proof thereof is demanded at trial. 7. The averments contained in paragraph seven (7) are specifically denied and strict proof thereof is demanded at trial. 8. The averments contained in paragraph eight (8) are conclusions of law to which no response is required. To the extent that a response is required, the averments are specifically denied and strict proof thereof is demanded at trial. 9. The averments contained in paragraph nine (9) are specifically denied and strict proof thereof is demanded at trial. WHEREFORE, Defendant respectfully requests that this Honorable Court enter a judgment in their favor and against Plaintiffs in this matter. Respectfully submitted, IRWIN & McKNIGHT, AC November 5, 2009 By: Matthew A. McWight, Esquire Supreme Court 1D#: 93010 60 West Pomfret Street Carlisle, PA 17013 (717) 249-2353 Attorney for the Defendant, David A. Heinbaugh, Sr. VERIFICATION The foregoing Answer to Plaintiffs Complaint on behalf of Defendant, David A. Heinbaugh, Sr., is based upon information which has been gathered by counsel for the Defendant in the preparation of this Document. The statements made in this Answer to Plaintiffs Complaint are true and correct to the best of the counsel's knowledge, information and belief. The Defendant's verification cannot be obtained within the time allowed for filing the pleading. The undersigned is therefore verifying on behalf of the Defendant according to 42 Pa.C.S.A. § 1024(c)(2). The undersigned understands that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Matthew A. Mc ght, Esquire Date: November 5, 2009 CERTIFICATE OF SERVICE I, Matthew A. McKnight, Esquire, do hereby certify that I have served a true and correct copy of the foregoing document upon the persons indicated below by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below: Matthew Urban, Esquire WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 IRWIN & McKNIGHT, P.C. CJ? Matthew A. cKnight, Esquire Supreme Court I.D. No: 93010 60 West Pomfret Street Carlisle, PA 17013 (717) 249-2353 Attorney for Defendant David A. Heinbaugh, Sr. Al Fl- THE FFC'_ ;,T,'.1TARY OF 2009 NOV -5 PM 3: 2O C?' lY ~~ THfl~~'~TARY sip ~~-~ -s Ica ~o~ 54 ~MPE~,r~ SnvAN-A c~st`t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. DAVID A HEINBAUGH Defendant(s) No. 08-4225-CIVIL PRAECIPE TO SETTLE, DISCONTINUE AND END WITH PREJUDICE TO REFILE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Lyndsay E Rowland, Esquire PA I.D. #205520 WELTMAN, WEINBERG & REIS CO., L.P.A 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WW.R#6433032 TIC IN THE COURT OP COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No. 08-4225-CIVIL DAVID A HEINBAUGII Defendant(s) PRAECIPE TO SETTLE DISCONTINUE AND END WITH PREJUDICE TO REFILE TO THE PROTHONOTARY OF COUNTY: Settle, Discontinue and End With Prejudice to Refile the above-captioned matter upon the records of the Court and mark the costs paid. Sworn to and subscribed Before me the 6 ~ Day of u~usT ~oio N TARY WELTIyIAN,~WEINBERG & REIS CO., L By• Lynd E wlan , s uire PA I.D. #2 20 WELTMA WEINBERG & REIS CO., L.P.A 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA ] 5219 (412) 434-7955 WWR#6433032 C®MMQNW F NNSYLVANIA Nplell~i Seel Wendy 1. Gaulle, Notary Kubik City of Pittsburgh, Allegheny County My Commissbn Expires )uly 15, 2014 Member. PennsNvanla Assodatlon of Notaries