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Home My WebLink About08-4227 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff No. e5' - -2 vs. JACOB W MOYER Defendant 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#6433002 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. JACOB W MOYER 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 1497 KUHN RD BOILING SPRINGS,PA 17007. COUNT I - ACCOUNT NO. 8589315657 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, JACOB W MOYER, 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, JACOB W MOYER, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, JACOB W MOYER, in the amount of $499.85 as of MAY 28 2008. 8. Plaintiff claims interest at the legal rate of six (6%) percent per annum from MAY 28 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, JACOB W MOYER, in the amount of $499.85 with continuing interest thereon at the rate of 6% per annum from MAY 28 2008 and costs. COUNT II - ACCOUNT NO. 8589343934 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, JACOB W MOYER, 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, JACOB W MOYER, agreed to pay. 14. Plaintiff avers that there is a balance due and owing from Defendant, JACOB W MOYER, in the amount of $829.78 as of MAY 28 2008 15. Plaintiff claims interest at the legal rate of six (6%) percent per annum from MAY 28 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, JACOB W MOYER, in the amount of $829.78 with continuing interest thereon at the rate of 6% per annum from MAY 28 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. w WILLIAM T. M CZAN, Esquire PA I.D. #4743 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219(412) 434-7955 WWR#:6433002 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: MOYER, JACOB W F/C: C P/T: E A/C: 9315657 DSC CODE: 01 TO: MOYER, JACOB W ADMISSION: 07/13/05 DISCHARGE: 07/13/05 80 W LOUTHER ST CARLISLE PA 17013 INS CD: 472/ MEGALIFE INS CO GROUP ST01008250 POL ID: 172705176 D E P A R T M E N T A M O U N T 133.28 109.11 1,656.84 1,399.38- 499.85- ----------------------------------------------------------------------------- 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: MOYER, JACOB W F/C: C P/T: E A/C: 9343934 DSC CODE: 01 TO: MOYER, JACOB W ADMISSION: 07/10/06 DISCHARGE: 07/10/06 80 W LOUTHER STREET CARLISLE PA 17013 A M O U N T 52.74 301.60 475.44 829.78- ----------------------------------------------------------------------------- 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 LrINA hdQNMQSSO (Name) VICE-PRESIDENT OF-OPERATIONS of lNTEERNA` MNAL, EQMOL.IO INS., 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 acne true and correct to the best of her knowledge, information and belief. WWR D A\ o ? 11 C? 4 c79 .,_ J c 11 14 SHERIFF'S RETURN - REGULAR CASE NO: 2008-04227 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS MOYER JACOB W GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MnV7'0 .TArnR W the DEFENDANT , at 0019:01 HOURS, on the 5th day of August 2008 at 116 E LOUTHER ST CARLISLE, PA 17013 by handing to AMANDA MOYER WIFE OF DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit 8`??09 Surcharge / i0a Sworn and Subscibed to before me this of So Answers: 18.00 5.00 .00 10.00 R. Thomas Kline .00 33.00 08/06/2008 WELTMAN WEINBERG & REIS By day Deputy riff A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO, INC Plaintiff vs. No. 08-4227-CIVIL PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE JACOB W MOYER 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#06433002 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO, INC Plaintiff vs. Civil Action No. 08-4227-CIVIL JACOB W MOYER Defendant PRAECIPE TO SETTLE. DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Settle, Discontinue and End the above-captioned matter upon the records of the Court without prejudice to refile and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: Attorney for Plai iff 2718 Koppers gilding 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06433002 SWORN TO AND SUBSCRIBED before me this (t"1 day of 008 N TARY UB C COMMONWEALTH C f'ENNISYLVAMA Notarial Seal Wendy L. Gault, Notary Public City Of Pittsburgh, Allegheny County MY Commission Expires .1uiy 15, 2010 Member, Pennsylvania Z;odatiun of Notaries . r r c r ? -?, rrt ?rcr , . 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 PRAECIPE TO ENTER AN APPEARANCE TO CUR TIS R. LONG, PROTHONA TAR Y. Please enter my appearance on behalf of the Defendant, David A. Heinbaugh, Sr. of Carlisle, Cumberland County, Pennsylvania, in this matter. Respectfully submitted, IRWIN & McKNIGHT, P. C. September 4, 2009 By: Matthew A. McI night, Esquire Supreme Court ID#: 93010 60 West Pomfret Street Carlisle, PA 17013 (717) 249-2353 Attorney for the Defendant, David A. Heinbaugh, Sr. CERTIFICATE OF SERVICE I, the undersigned hereby certify that on this 4th day of September, 2009, a copy of the Praecipe to Enter an Appearance was served by first-class, postage prepaid United States mail in Carlisle, Pennsylvania upon the following: James C. Warmbrodt, Esquire WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 IRWIN & McKNIGHT, P.C. Matthew A. Mc fight, Esquire Supreme Court I.D. No: 93010 60 West Pomfret Street Carlisle, PA 17013 (717) 249-2353 Attorney for Defendant FILED-? IICE OF THE PPcTHcNoTARY 2009 SEP -4 P!i 2: 39 CUMSSIL,i -J') tVfiY PDMYLVANIA