HomeMy WebLinkAbout08-4230IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff
vs.
KYUATI A BETHEA
Defendant
No. ? "70 3,
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#6432998
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff
vs. Civil Action No.
KYUATI A BETHEA
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 116 S PITT STREET CARLISLE,PA 17013.
COUNT I - ACCOUNT NO. 8589314783
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, KYUATI A BETHEA, 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, KYUATI A
BETHEA, agreed to pay.
7. Plaintiff avers that there is a balance due and owing from Defendant, KYUATI A
BETHEA, in the amount of $35.00 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, KYUATI A
BETHEA, in the amount of $35.00 with continuing interest thereon at the rate of 6% per annum from
MAY 28 2008 and costs.
COUNT II - ACCOUNT NO. 8589316294
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, KYUATI A BETHEA, 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, KYUATI A
BETHEA, agreed to pay.
14. Plaintiff avers that there is a balance due and owing from Defendant, KYUATI A
BETHEA, in the amount of $1,300.77 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, KYUATI A
BETHEA, in the amount of $1,300.77 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.
/'I 1A
WILLIAM T. MOLC,O?iN, 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#:6432998
05/13/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES
CARLISLE REGIONAL MEDICAL CTR DA17 /COID: 08 858
361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE OF (717) 9 717) 90608
' -
-----------------
---= -1680
------------------------------------------------
PATIENT: BETHEA, KYUATI A F/C: D P/T: E A/C: 9314783 DSC CODE: 01
TO: BETHEA, KYUATI A ADMISSION: 07/03/05 DISCHARGE: 07/03/05
116 S PITT STREET CARLISLE
INS CD: 432/ HEALTHASSURANCE PA 17013
_ D E P A R T M E N T GROUP 1097620001 POL ID: 850190268
-? "-? _ ------ A M O U N T
71.23
1,042.51
365.00-
748.74-
---------------- ---------
SELECT: REV= * DEPT= * TOTAL 0.00
CMD:l=DAR,2=PAT 4= DETAIL CHGCD= * DATE/MDCY= * TO/MDCY=
7=RETURN,8=BACKWARD, ENTER=FORWARD
EXHIBIT
05/13/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES
CARLISLE REGIONAL MEDICAL CTR F05 /08 858
361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE OF (717) 9 717) 90608
-- ___-
- -1680
-------------------------------------------------
PATIENT: BETHEA, KYUATI A -----------------
TO: BETHEA, KYUATI A ADMISSION: 07/21/05 9DISCHARGE: 070/21 05
116 S PITT-STREET CARLISLE PA 17013 / 5
A M O U N T
43.91
292.65
390.66
573.55
1,300.77-
---------------- -------
SELECT: REV= * DEPT= * * TOTAL 0.00
CMD:I=DAR,2=PAT 4=DETAIL CHGCD-_ DATE/MDCY= * TO/MDCY=
7=RETURN,8=BACKWARD, ENTER=FORWARD
EXHIBIt
The undersigned does :hereby'verify subject to the penalties of 18 PA-C.& 14904
relating to unswOrn falsifications to authorities, that she is _I A MOIV`l'
U C)
V 1fi ntA the f A'IONAt n (N)
(Title) (Company) 4&T1~ QLLQ 1 ., plaintiff
herein, that she is duly authorized to make this Verification, and that the facts set forth in
the foregoing complaint in Civil Action aft true and correct to the best of her knowledge,
information and belief
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-04230 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
INTERNATIONAL PORTFOLIO INC
VS
BETHEA KYUATI A
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
BETHEA KYUATI A but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT & NOTICE
the within named DEFENDANT
BETHEA KYUATI A
NOT FOUND , as to
116 S PITT STREET
CARLISLE, PA 17013
DEFENDANT DOES NOT LIVE AT GIVEN ADDRESS
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
Ylb gl.- P 9-
8.00 So answers-
15.00
5.00 R. TE-o-ma'5 Kline
10.00 Sheriff of Cumberland County
.00
38.00 WELTMAN WEINBERG REIS
07/30/2008
Sworn and Subscribed to before
me this day of
A. D.
4 .
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff No. X - ? 30 a?
vs.
KYUATI A BETHEA
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#6432998
TRUE COPY FR,' ?,j RECORD
In Testimony whereof, I hire unto set m and the seal of said Court at Carlisle, Pa.y hand
This ...,1 ......wday of.. ..........
Prothonotary ..
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff
vs. Civil Action No.
KYUATI A BETHEA
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
t
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 116 S PITT STREET CARLISLE,PA 17013.
COUNT I - ACCOUNT NO. 8589314783
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, KYUATI A BETHEA, 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, KYUATI A
BETHEA, agreed to pay.
7. Plaintiff avers that there is a balance due and owing from Defendant, KYUATI A
BETHEA, in the amount of $35.00 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, KYUATI A
BETHEA, in the amount of $35.00 with continuing interest thereon at the rate of 6% per annum from
MAY 28 2008 and costs.
COUNT II - ACCOUNT NO. 8589316294
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, KYUATI A BETHEA, 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, KYUATI A
BETHEA, agreed to pay.
Ws.
14. Plaintiff avers that there is a balance due and owing from Defendant, KYUATI A
BETHEA, in the amount of $1,300.77 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, KYUATI A
BETHEA, in the amount of $1,300.77 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.
i .
WILLIAM T. MOL(-ZFA N, 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#:6432998
.05/13/08 PAGE JJl 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: BETHEA, KYUATI A F/C: D P/T: E A/C: 9314783 DSC CODE: 01
TO: BETHEA, KYUATI A ADMISSION: 07/03/05 DISCHARGE: 07/03/05
116 S PITT STREET CARLISLE PA 17013
INS CD: 432/ HEALTHASSURANCE GROUP 1097620001 POL ID: 850190268
`D ^E P -ART_MEN T AMOUNT
71.23
1,042.51
365.00-
748.74-
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
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: BETHEA, KYUATI A F/C: D P/T: E A/C: 9316294 DSC CODE: 01
TO: BETHEA, KYUATI A ADMISSION: 07/21/05 DISCHARGE: 07/21/05
116 S PITT STREET CARLISLE PA 17013
A M O U N T
43.91
292.65
390.66
573.55
1,300.77-
------------------------------------------------------------
TOTAL 0.00
SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY=
CMD:I=DAR,2=PAT 4=DETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD
EXHIBf!
The undersigned does :hereby verify subject to the penalties of 18 PA.C.S,14904
relating to unsworn falsifications to authorities, that she is LINE ON` &QSSO
(Name)
"VIC> RF,SLD>? Ip1N OI'IPA`IO 5 of INT`MADDYAr, PC)RT`Pf)t.tO 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
F
1
dc
V
vo: R-630
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff
VS.
KYUATI A BETHEA
Defendant
No. 08-4230 CIVIL
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#06432998
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff
VS. Civil Action No. 08-4230 CIVIL
KYUATI A BETHEA
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, E uire
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR #06432998
FILED-OFFICE
OF THE PR,0 400NOTASY
2008 JUL 15 AM 1 I *- 2 2
'UNTY
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff No. Of - 4;130 &V41?
VS.
KYUATI A BETHEA
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#6432998
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff
vs. Civil Action No. 6Y-Y,2-36
?, <<ti rte
KYUATI A BETHEA
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 116 S PITT STREET CARLISLE,PA 17013.
COUNT I - ACCOUNT NO. 8589314783
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, KYUATI A BETHEA , 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, KYUATI A
BETHEA, agreed to pay.
7. Plaintiff avers that there is a balance due and owing from Defendant, KYUATI A
BETHEA, in the amount of $35.00 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, KYUATI A
BETHEA, in the amount of $35.00 with continuing interest thereon at the rate of 6% per annum from
MAY 28 2008 and costs.
COUNT II - ACCOUNT NO. 8589316294
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, KYUATI A BETHEA, 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, KYUATI A
BETHEA, agreed to pay.
14. Plaintiff avers that there is a balance due and owing from Defendant, KYUATI A
BETHEA, in the amount of $1,300.77 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, KYUATI A
BETHEA, in the amount of $1,300.77 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.
WILLIAM T. MOL5XAN, 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#:6432998
.05/13/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858
CARLISLE REGIONAL MEDICAL CTR AS OF 05/12/08
351 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680
---- -------- ------------------------------------------------------------------
PATIENT: BETHEA, KYUATI A F/C: D P/T: E A/C: 9314783 DSC CODE: 01
TO: BETHEA, KYUATI A ADMISSION: 07/03/05 DISCHARGE: 07/03/05
116 S PITT STREET CARLISLE PA 17013
INS CD: 432/ HEALTHASSURANCE GROUP 1097620001 POL ID: 850190268
D E P A R T M E N T A M O U N T
71.23
1,042.51
365.00-
748.74-
-----------------------------------------------------------------------------
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 DAi7 COLD: 858
CARLISLE REGIONAL MEDICAL CTR AS OF 05/12/08
3E1 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680
---- ------- ------------------------------------------------------------------
PATIENT: BETHEA, KYUATI A F/C: D P/T: E A/C: 9316294 DSC CODE: 01
TO: BETHEA, KYUATI A ADMISSION: 07/21/05 DISCHARGE: 07/21/05
116 S PITT STREET CARLISLE PA 17013
A M O U N T
43.91
292.65
390.66
573.55
1,300.77-
-----------------------------------------------------------------------------
TOTAL 0.00
SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY=
CMD:I=DAR,2=PAT 4=DETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD
EXHIBI
?
The undersigned does hereby verify subject to the penalties of lE PA.C.S. 14904
relating to unsworn falsifications to authorities, that she is LIMA MONTEROSSO
(Name)
VICE PRESIDENT OF OPE TIONS of INTERNATIONAL PORTFOLIO 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 am true and correct to the best of her knowledge,
information and belief.
wwR#
90, €
W C5
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x?
CD
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-04230 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
INTERNATIONAL PORTFOLIO INC
VS
BETHEA KYUATI A
NOAH CLINE
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
BETHEA KYUATI A the
DEFENDANT , at 1915:00 HOURS, on the 6th day of November-, 2008
at 256 W POMFRET STREET
CARLISLE, PA 17013
KYUATI A BETHEA
by handing to
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 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
11/07/2008
WELTMAN WEINBERG REIS
By: Deputy Sheriff
of A. D.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC
Plaintiff
vs.
KYUATI A BETHEA
Defendant
No.: 08-4230-CIVIL
PRAECIPE FOR DEFAULT JUDGMENT
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James C. Warmbrodt,
P.A.I.D.# 42524
Weltman,Weinberg & Reis Co.,L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412)434-7955
Fax: 412-338-71305
WWR#6432998
Judgment Amount $ 1,407.43
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC
Plaintiff
Vs.
KYUATI A BETHEA
Defendant
Civil Action No.: 08-4230-CIVIL
PRAECIPE FOR DEFAULT JUDGMENT
COUNT 1- 8589314783
TO THE PROTHONOTARY:
Kindly enter Judgment against the Defendant, KYUATI A BETHEA above named, in the default of an
Answer, in the amount of $37.91 computed as follows:
Amount claimed in Complaint $35.00
Interest from 5/28/08 to 10/15/09
at the legal interest rate of 6.00% per annum $2.91
TOTAL $37.91
COUNT II- 8589317486
Kindly enter Judgment against the Defendant, KYUATI A BETHEA above named, in the default of an
Answer, in the amount of $37.91 computed as follows:
Amount claimed in Complaint $1,300.77
Interest from 5/28/08 to 10/15/09
at the legal interest rate of 6.00% per annum $68.75
TOTAL $1,369.52
COUNT I & 11 TOTAL $1,407.43
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: c
James C. W
P.A.I.D.# 4,
Weltman,Wei er & Reis Co .,L.P.A.
436 Seven venue, Suite 1400
Pittsburgh, 5219
(412)434- 5
Fax: 41 8-71305
WWR#6432998
Plaintiff's address is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7s' Avenue, Pittsburgh, PA 15219
And that the last known address of the Defendant is: 12 MAPLE AVENUE WALNUT BOTTOM,PA 17266
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC
Plaintiff
vs. Civil Action No.: 08-4230-CIVIL
KYUATI A BETHEA
Defendant
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the following
Order or Judgment was entered against you
on if In
(xx) Assumpsit Judgment in the amount
of $1,407.43 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: /S/
PROTHONOTARY (OR DEPUTY J,9Z
CHRISTINA A JONES
12 MAPLE AVENUE
WALNUT BOTTOM,PA 17266
Plaintiff's 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
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC
Plaintiff
vs
KYUATI A BETHEA
Case no:: 08-4230-CIVIL
NON-MILITARY AFFIDAVIT
Defendant
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, KYUATI A
BETHEA 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, KYUATI A BETHEA is not in the military service.
Further Affiant sayeth naught.
SN
of
AFFIANT
presence thim day
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NOTARY PUBLIC
C0idlrr C,NWEALTIi (: ' PENNSYLVANj.
Notar-4, 3091
Sheila G.13evaa.. votary Public
City Of Pittsburgh Ala agheny Cou*
My Commission ExDres Nov. 15, 2010
1
Member, Pennsylvania Association of Notaries
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff
vs.
KYUATI A BETHEA
Defendant
Case No. 08-4230-CIVIL
IMPORTANT NOTICE
TO:
KYUATI A BETHEA
256 W POMFRET ST
CARLISLE, PA 17013
Date of Notice: 1211?0(;b
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: [o? U130u'?sv?r?er--
Patrick Woodman
P.A.1,D.# 34507
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, 1400 Koppers Building
Pittsburgh, PA 15219
Phone: (412) 434-7955
6432998 H PIT KLA
Request for Military Status
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Servicemembers Civil Relief Act
Page 1 of 2
OCT-16-2009 05:10:45
Last Name First/Middle Begin Date Active Duty Status Service/Agency
BETHEA KYUATI A 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.
A VL
kut lot.
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.
http://www.defenselink.mil/fa
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.
https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 10/16/2009
OF THE '
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