HomeMy WebLinkAbout08-4229IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff
VS.
DEBRA K KEPPLEY
AKA DEBRA K KEPPLEY
Defendant
No. 0 9- 4 2 Z0( e t3-d
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#6431646
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff
Civil Action No. OF - L/23 9 &,;U `e-
vs.
DEBRA K KEPPLEY
AKA DEBRA K KEPPLEY
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) 249-31665
COMPLAINT
Plaintiff is a corporation with offices at 7465 N.W. 49TH ST, LAUDERHILLE, FL 33319-
0000.
2. Defendant is an adult individual residing at 180 VIRGINIA AVE CARLISLE,PA 17013.
COUNT I - ACCOUNT NO. 8587447573
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, DEBRA K KEPPLEY, 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, DEBRA K
KEPPLEY, agreed to pay.
7. Plaintiff avers that there is a balance due and owing from Defendant, DEBRA K
KEPPLEY, in the amount of $78.16 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, DEBRA K
KEPPLEY, in the amount of $78.16 with continuing interest thereon at the rate of 6% per annum from
MAY 30 2008 and costs.
COUNT II - ACCOUNT NO. 8589319555
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, DEBRA K KEPPLEY, 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, DEBRA K
KEPPLEY, agreed to pay.
14. Plaintiff avers that there is a balance due and owing from Defendant, DEBRA K
KEPPLEY, in the amount of $122.50 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, DEBRA K
KEPPLEY, in the amount of $122.50 with continuing interest thereon at the rate of 6% per annum from
MAY 30 2008 and costs.
COUNT III - ACCOUNT NO. 8589321239
11. 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, DEBRA K KEPPLEY, 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, DEBRA K
KEPPLEY, agreed to pay.
14. Plaintiff avers that there is a balance due and owing from Defendant, DEBRA K
KEPPLEY, in the amount of $122.50 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, DEBRA K
KEPPLEY, in the amount of $122.50 with continuing interest thereon at the rate of 6% per annum from
MAY 30 2008 and costs.
COUNT IV - ACCOUNT NO. 8589327625
12. 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, DEBRA K KEPPLEY, 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, DEBRA K
KEPPLEY, agreed to pay.
14. Plaintiff avers that there is a balance due and owing from Defendant, DEBRA K
KEPPLEY, in the amount of $1,676.14 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, DEBRA K
KEPPLEY, in the amount of $1,676.14 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.
4PA LIAM T. LCZAN, Esquire
I.D . #474 7
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219(412) 434-7955
WWR#:6431646
05/09/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858
AS OF 05/08/08
CARLISLE REGIONAL MEDICAL CTR PA 17015 PHONE (717) 960-1680
361 ALEXANDER SPRING RD CARLISLE -- ----------
-------------------------------------------------
PATIENT: KEPPLEY, DEBRA K F/C: D P/T: 0 A/C: 7447573 DSC CODE: 01
TO: KEPPLEY, DEBRA K ADMISSION: 12/09/04 DISCHARGE: 12/09/04
180 VIRGINIA AVE CARLISLE PA 17013
INS CD: 432/ HEALTHASSURANCE GROUP 1736560001 POL ID: 850888919
A M O U N T
10.98
146.44
1,626.41
703.47-
1,080.36-
----- ------- ------------------ 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
DA17 COID: 858
05/09/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES AS OF 05/08/08
CARLISLE REGIONAL MEDICAL CTR PA 17015 PHONE (717) 960-1680
361 ALEXANDER SPRING RD CARLISLE ---
_ _ ---------------------------------------
PATIENT: BARRICK, COREY B F/C'DONP/08/31/05. 9DI319555 0CODE 8/31/05
T0: KEPPLEY, DEBRA K ADMISS
CARLISLE PA 17013
1807 WILLOW ROAD GROUP 1736560001 POL ID: 850888919
INS CD: 432/ HEALTHASSURANCE A M O U N T
nF?nuTM?r'aT 52.19
16.88
292.65
573.55
427.50-
507.77-
---------------
----------------
------------------------- 0.00
TOTAL
* DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY=
SELECT. REV- 7=RETURN,8=BACKWARD, ENTER=FORWARD
CMD:I=DAR,2=PAT 4=DETAIL
EXHIBIT
05/09/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858
AS OF 05/08/08
CARLISLE REGIONAL MEDICAL CTR PA 17015 PHONE (717) 960-1680
361 ALEXANDER SPRING RD CARLISLE -------
_ _ -------------------------------------
PATIENT: BARRICK, COREY B F/ISSDONP/09/20/05 9DISCHARDEC 0CODE 9/20/05
T0: KEPPLEY, DEBRA K ADM
CARLISLE PA 17013
1807 WILLOW ROAD GROUP 1736560001 POL ID: 850888919
INS CD: 432/ HEALTHASSUFtANCE A M O U N T
12.74
292.65
573.55
427.50-
451.44-
------------------------
------------------- TOTAL 0.00
*
SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY=
7=RETURN,8=BACKWARD, ENTER=FORWARD
CMD:I=DAR,2=PAT 4=DETAIL
EXHIBIT
3
DA17 COID: 858
05/09/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES AS OF 05/08%08
CARLISLE REGIONAL MEDICAL CTR PA 17015 PHONE (717) 960-1680
361 ALEXANDER SPRING RD CARLISLE ---
PATIENT: BARRICK, COREY B F/C: C p/1: E A/C: 932 625 DEC 102/18/05
T0: KEPPLEY, DEBRA K ADMISSION:
1807 WILLOW ROAD CARLISLE PA 17013 INS CD: 120/AMH AMERIHEALTH ADMIN GROUP 094736 POL ID: 014239187
A M O U N T
196.19
1,454.95
100.00-
1,551.14-
______ ----------
---------------------------
TOTAL 0.00
*
DEPT= * * DATE/MDCY= * TO/MD _
ENTER=FORWARD
SELECT: REV= * CHGCD= 7=RETURN,8=BACKWARD,
CMD:I=DAR,2=PAT 4=DETAIL
EXHIBIT
The unde rsigmed does hereby verify subject to the penalties of 18 14904
r ttr ? fi T R t?S?t)
relating to unsworn falsifications to authorities, that she is be
rPRATf(15 of? ?T:bhA PC?i?bT..ib INS., plaintiff
?nr? n?t?fiTD?T b?.b
(Title) (Company)
herein, that she is duly authorized to make this Verification, and that the facts set forth in
Complaint in Civil Action are true and correct to the best of her knowledge,
the foregoing
information and belief.
W
r
bt d
ev
c.°, C3
`
. ? Ag t1
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-04229 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
INTERNATIONAL PORTFOLIO INC
VS
KEPPLEY DEBRA K ET AL
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
KEPPLEY DEBRA K AKA KEPPLEY DEBRA K but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT & NOTICE
NOT FOUND , as to
the within named DEFENDANT , KEPPLEY DEBRA K
AKA KEPPLEY DEBRA K
180 VIRGINIA AVE
CARLISLE, PA 17013
PER POST OFFICE, MOVED AND LEFT NO FORWARDING ADDRESS.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
Not Found
So answers:
18.00
5.00 Jo-.
.00 ,- R. Thomas Kline
10.00 Sheriff of Cumberland County
38.00 WELTMAN WEINBERG & REIS
07/24/2008
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.
DEBRA K KEPPLEY
AKA DEBRA K KEPPLEY
Defendant
No. 08-4229-CIVIL TERM
PRAECIPE TO REINSTATE COMPLAINT
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#06431646
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff
VS. Civil Action No. 08-4229-CIVIL TERM
DEBRA K KEPPLEY
AKA DEBRA K KEPPLEY
Defendant
PRAECIPE TO REINSTATE COMPLAINT
Kindly reinstate the Complaint in the above captioned matter.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By: '
William T. Molczan, quire
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR 406431646
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff
vs.
n
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No. 0 y. v 2 a 9 Ct n.0
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COMPLAINT IN CIVIL ACTION -
DEBRA K KEPPLEY
AKA DEBRA K KEPPLEY
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#6431646
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff
VS. Civil Action No. j?,- 4 a 2 l C) J
DEBRA K KEPPLEY
AKA DEBRA K KEPPLEY
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) 249-31665
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 180 VIRGINIA AVE CARLISLE,PA 17013.
COUNT I - ACCOUNT NO. 8587447573
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, DEBRA K KEPPLEY, 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, DEBRA K
KEPPLEY, agreed to pay.
7. Plaintiff avers that there is a balance due and owing from Defendant, DEBRA K
KEPPLEY, in the amount of $78.16 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, DEBRA K
KEPPLEY, in the amount of $78.16 with continuing interest thereon at the rate of 6% per annum from
MAY 30 2008 and costs.
COUNT II - ACCOUNT NO. 8589319555
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, DEBRA K KEPPLEY, received and accepted the aforementioned medical
services which were provided by Plaintiffs assignor
13. The prices charged by Plaintiffs assignor were the prices that Defendant, DEBRA K
KEPPLEY, agreed to pay.
14. Plaintiff avers that there is a balance due and owing from Defendant, DEBRA K
KEPPLEY, in the amount of $122.50 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, DEBRA K
KEPPLEY, in the amount of $122.50 with continuing interest thereon at the rate of 6% per annum from
MAY 30 2008 and costs.
COUNT III - ACCOUNT NO. 8589321239
11. 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, DEBRA K KEPPLEY, received and accepted the aforementioned medical
services which were provided by Plaintiff s assignor
13. The prices charged by Plaintiffs assignor were the prices that Defendant, DEBRA K
KEPPLEY, agreed to pay.
14. Plaintiff avers that there is a balance due and owing from Defendant, DEBRA K
KEPPLEY, in the amount of $122.50 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, DEBRA K
KEPPLEY, in the amount of $122.50 with continuing interest thereon at the rate of 6% per annum from
MAY 30 2008 and costs.
COUNT IV - ACCOUNT NO. 8589327625
12. 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, DEBRA K KEPPLEY, received and accepted the aforementioned medical
services which were provided by Plaintiffs assignor
13. The prices charged by Plaintiff s assignor were the prices that Defendant, DEBRA K
KEPPLEY, agreed to pay.
14. Plaintiff avers that there is a balance due and owing from Defendant, DEBRA K
KEPPLEY, in the amount of $1,676.14 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, DEBRA K
KEPPLEY, in the amount of $1,676.14 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. LCZAN, Esquire
PA I.D. #47457
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219(412) 434-7955
W WR#:6431646
05/09/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858
CARLISLE REGIONAL MEDICAL CTR AS OF 05/08/08
361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680
---- ------- ------------------------------------------------------------------
PATIENT: KEPPLEY, DEBRA K F/C: D P/T: 0 A/C: 7447573 DSC CODE: 01
TO: KEPPLEY, DEBRA K ADMISSION: 12/09/04 DISCHARGE: 12/09/04
180 VIRGINIA AVE CARLISLE PA 17013
INS CD: 432/ HEALTHASSURANCE GROUP 1736560001 POL ID: 850888919
A M O U N T
10.98
146.44
1,626.41
703.47-
1,080.36-
-----------------------------------------------------------------------------
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
05/09/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858
CARLISLE REGIONAL MEDICAL CTR AS OF 05/08/08
361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680
---- ------- ------------------------------------------------------------------
PATIENT: BARRICK, COREY B F/C: D P/T: E A/C: 9319555 DSC CODE: 01
TO: KEPPLEY, DEBRA K ADMISSION: 08/31/05 DISCHARGE: 08/31/05
1807 WILLOW ROAD CARLISLE PA 17013
INS CD: 432/ HEALTHASSURANCE GROUP 1736560001 POL ID: 850888919
n V. v a u m w ? u m A M O U N T
52.19
16.88
292.65
573.55
427.50-
507.77-
-------------------------7---------------------------------------------------
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
a
05/09/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858
CARLISLE REGIONAL MEDICAL CTR AS OF 05/08/08
3c1 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680
•---- -------- ------------------------------------------------------------------
PATIENT: BARRICK, COREY B F/C: D P/T: E A/C: 9321239 DSC CODE: 01
TO: KEPPLEY, DEBRA K ADMISSION: 09/20/05 DISCHARGE: 09/20/05
1807 WILLOW ROAD CARLISLE PA 17013
INS CD: 432/ HEALTHASSURANCE GROUP 1736560001 POL ID: 850888919
A M O U N T
12.74
292.65
573.55
427.50-
451.44-
-----------------------------------------------------------------------------
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
05/09/08 PAGE 001 HEALTH MANAGEMENT' ASSOCIATES DA17 COID: 858
CARLISLE REGIONAL MEDICAL CTR AS OF 05/08/08
30 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680
----- ------- ------------------------------------------------------------------
PATIENT: BARRICK, COREY B F/C: C P/T: E A/C: 9327625 DSC CODE: 01
TO: KEPPLEY, DEBRA K ADMISSION: 12/18/05 DISCHARGE: 12/18/05
1807 WILLOW ROAD CARLISLE PA 17013
INS CD: 120/AMH AMERIHEALTH ADMIN GROUP 094736 POL ID: 01423918T
---- AMOUNT
196.19
1,454.95
100.00-
1,551.14-
•-----------------------------------------------------------------------------
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 LMA 1yIONTEROSS0
(Name)
VIDE P FSIDENT OF OPERATIONS of INTERNATIONAL PQ OLIO 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.
la O
pp O
4b 0
V? 00 V
.?-' I
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-04229 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
INTERNATIONAL PORTFOLIO INC
VS
KEPPLEY DEBRA K ET AL
MICHELLE GUTSHALL
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
KEPPLEY DEBRA K AKA KEPPLEY DEBRA K
the
DEFENDANT , at 0013:48 HOURS, on the 22nd day of November-, 2008
at 180 VIRGINIA AVE
CARLISLE, PA 17013 by handing to
FRED KEPPLEY SPOUSE OF DEFENDANT
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 5.00
Affidavit .00
Surcharge 10.00
.00
33.00
Sworn and Subscibed to
before me this day
So Answers:
•
R. Thomas Kline
11/24/2008
WELTMAN WEINBERG & REIS
B N&F- Deputy eriff
of A. D.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff
VS.
DEBRA K KEPPLEY
AKA DEBRA K KEPPLEY
Defendant
No.: 08-4229-CIVIL TERM
PRAECIPE FOR DEFAULT 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 Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#6431646
Judgment Amount S 2,074.89
THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
1
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff
VS. Civil Action No.: 084229-CIVIL TERM
DEBRA K KEPPLEY
AKA DEBRA K KEPPLEY
Defendant
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONOTARY:
COUNTI
Kindly enter Judgment against the Defendant, DEBRA K KEPPLEY
AKA DEBRA K KEPPLEY above named, in the default of an Answer, in the amount of $81.12 computed
as follows:
Amount claimed in Complaint $ 78.16
Interest from 05/30/08 to 01/15/09
at the legal interest rate of 6.00% per annum $2.96
TOTAL $81.12
COUNT H
bo-&
Kindly enter Judgment against the Defendant, DEBRA K KEPPLEY 41 a?,13 0--0
AKA DEBRA K KEPPLEY above named, in the default of an Answer, in the amount of SOH2 computed
as follows:
Amount claimed in Complaint $122.50
Interest from 05/30/08 to 01/15/09
at the legal interest rate of 6.00% per annum $4.63
TOTAL $127.13
. . a
COUNT III
Kindly enter Judgment against the Defendant, DEBRA K KEPPLEY # (011.13
AKA DEBRA K KEPPLEY above named, in the default of an Answer, in the amount of4*142-eomputed
as follows:
Amount claimed in Complaint
$122.50
Interest from 05/30/08 to 01/15/09
at the legal interest rate of 6.00% per annum $4.63
TOTAL
$127.13
COUNT IV
Kindly enter Judgment against the Defendant, DEBRA K KEPPLEY 1,'139.51Qy
AKA DEBRA K KEPPLEY above named, in the default of an Answer, in the amount of ° &1- -computed
as follows:
Amount claimed in Complaint
$1,676.14
Interest from 05/30/08 to 01/15/09
at the legal interest rate of 6.00% per annum $63.37
TOTAL
$1,739.51
TOTAL COUNT 1, II, 111, & IV $2,074.89
ago ao
p.is.
I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA
R.C.P. 237.1 on the dates indicated on the Notices.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
JAMES C. WA
PA I.D.#42524
, ESQUIRE
Weltman, Wei er & Reis Co., L.P.A.
1400 Koppers ld
436 Seventh ve e
Pittsburgh, A 15219
(412) '75
WWR#6431646
Plaintiff's address is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7"' Avenue, Pittsburgh, PA 15219
And that the last known address of the Defendant is: 1807 WILLOW RD CARLISLE,PA 17013
I , . • .,
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff
Case No. 08-4229-CIVIL TERM
vs.
DEBRA K KEPPLEY
AKA DEBRA K KEPPLEY
Defendant
IMPORTANT NOTICE
TO:
DEBRA K KEPPLEY
1807 WILLOW RD
CARLISLE, PA 17013
Date of Notice: l a. ? aI 6 8
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS
TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS
NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO
TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER.
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
32 SOUTH BEDFORD STREET
CARLISLE, PA. 17013
(717) 249-3166
WELTMAN, WEINBERG & REIS CO., L.P.A.
By: ^iwz,,X- U'Mow w--
Patrick Woodman
P.A:I.D.* 34507
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, 1400 Koppers Building
Pittsburgh, PA 15219
Phone: (412) 434-7955
6431646 H PIT KLA
Request for Military Status
Department of Defense Manpower Data Center
3 Military Status Report
Pursuant to the Servicemembers Civil Relief Act
Page 1 of 1
APR-23-2009 07:48:00
"< Last Name First/Middle Begin Date Active Duty Status Service/Agency
KEPPLEY DEBRA Based on the information you have furnished, the DMDC does not possess any information
indicating that the individual is currently on active duty.
Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information
that you provided, the above is the current status of the individual as to all branches of the Military.
Awt fit. 94*4- A?M_
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense
Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military
medical care and other eligibility systems.
The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§
501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands
of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced
a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any
manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly
encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the
"defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this
additional Military Service verification, provisions of the SCRA may be invoked against you.
If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can
submit your request again at this Web site and we will provide a new certificate for that query.
This response reflects current active duty status only. For historical information, please contact the Military Service SCRA
points-of-contact.
See: http://www.defenselink-mil/f4q/pis/PC09SLDR.htTnl
WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester.
Providing an erroneous name or SSN will cause an erroneous certificate to be provided.
Report ID: JLOKYCYUWO
https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 4/23/2009
. ? , A
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff
vs.
DEBRA K KEPPLEY
AKA DEBRA K KEPPLEY
Defendant
Case no:: 084229-CIVIL TERM
NON-MILITARY AFFIDAVIT
The undersigned, who first being duly sworn, according to law, deposes and states as follows:
That he/she is the duly authorized agent of the Plaintiff in the within matter.
Affiant further states that the within Affidavit is made pursuant to and in accordance with the
Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. § 521.
Affiant further states that based upon investigation it is the affiant's belief that the Defendant, DEBRA K
KEPPLEY
AKA DEBRA K KEPPLEY is not in the military service.
Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data
Center (DMDC), which states that the Defendant, DEBRA K KEPPLEY
AKA DEBRA K KEPPLEY is not in the military service.
Further Affiant sayeth naught.
AFFIANT
SWQ TO ND SUBS D in my presence thi? day
of,1--1? N;
COMMONWEALTH OF PENNSYLVANIA
Y P LI Notarial Sea!
Heidi J. Kelly, Notary Public
City Of Pittsburgh, Allegheny County
My Commission E)ires Nov. 4, 2009
Member, Pennsylvania Association of Notaries
This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be
used for that purpose.
RLED-OFFICE
OF THE PPOTHOINIYOTARY
2004 MAY -7 PM 12: 37
Ctrl r ? w, COUNTY
PENNSYLVANIA
14 -oo PO A" t
Ctl* ?- 81(04 ??13
R3* a? '441go(o
. 4 ' • ..
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff
VS. Civil Action No.: 08-4229-CIVIL TERM
DEBRA K KEPPLEY
AKA DEBRA K KEPPLEY
Defendant
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the following
Order or Judgm nt was entered against you
on
(xx) Assumpsit Judgment in the amount
of $2,074.89 plus costs.
( ) Trespass Judgment in the amount
of $ plus costs.
( ) If not satisfied within sixty (60)
days, your motor vehicle operator's license and/or registration
will be suspended by the Department of Transportation, Bureau
of Traffic Safety, Harrisburg, PA.
(xx) Entry of Judgment of
( ) Court Order
( ) Non-Pros
( ) Confession
(xx) Default
( ) Verdict
( ) Arbitration
Award
Prothonotary
By:
PR ONO OR DE TY)
DEBRA K KEPPLEY
1807 WILLOW RD
CARLISLE,PA 17013
Plaintiffs address is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7 h Avenue, Pittsburgh, PA 15219
1-888-434-0085