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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 wwxa C rzz ( --- CTN \ c ? r s.-} N 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 00 r 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 .ez'-w+r^- .-v - 'r- 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 ' 209 NOV 17 AN Its 31 C 06 I?CL 4?j CIO q3wD4 S -p:tL a 3 3[+?? CA te, ptv *6L