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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 c C= r" Fnm r mrn k: 90 No. 0 y. v 2 a 9 Ct n.0 c... r '2 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