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HomeMy WebLinkAbout08-4237D IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. RODNEY D CONRAD Defendant No. ag" y x-37 C=J' 1 -t COMPLAINT IN CIVIL ACTION 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: 412-338-7130 WWR#6433043 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No. o 9- _ Ll ?- 3 7 C NJ 14 «"` RODNEY D CONRAD 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 2171 NW 139 TERR PEMBROKE PINES, FL 33028-0000. 2. Defendant is an adult individual residing at 12 COOPER DR CARLISLE,PA 17013. 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, RODNEY D CONRAD, 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, RODNEY D CONRAD, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, RODNEY D CONRAD, in the amount of $1,865.95 as of JUNE 26 2008. 8. Plaintiff claims interest at the legal rate of six (6%) percent per annum from JUNE 26 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, RODNEY D CONRAD, in the amount of $1,865.95 with continuing interest thereon at the rate of 6% per annum from JUNE 26 2008 and costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. James C. Warm 6d P.A.LD.# 4252 Weltman,We' berg Reis Co.,L.P.A. 436 Seven Ave e, Suite 1400 Pittsburgh A 1 19 (412)43 95 Fax: 41 -3 -7130 '6433043 06/13/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 06/12/08 361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 ---- ------ ------------------------------------------------- PATIENT: CONRAD, RODNEY D F/C: P P/T: E A/C: 9330392 DSC CODE: 01 TO: CONRAD, RODNEY D ADMISSION: 01/25/06 DISCHARGE: 01/25/06 12 COOPER DR CARLISLE PA 17013 A M O U N T 105.88 16.88 505.92 407.61 829.66 1,865.95- ----------------------------------------------------------------------------- TOTAL 0.00 SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY= CMD:I=DAR,2=PAT 4=DETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD The undersigned does :hereby verify subject to the penalties of 18 14904 relating to unsworn falsifications to authorities, that she is t.INA MON'I`1 -$ O (Name) ytC pRF ID ?iT OF OP RA` O-IS of IN-URNATIONAL 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 are true and correct to the best of her knowledge, information and belief. WWR## d V ff, 1) o C') C= m 73 t'^' T30 r?T Paul J. Hennessy, Esquire Hennessy & Walker Group, P.C. 142 W. Market Street West Chester, PA 19382 610-431-2727 Attorney I.D. 65396 State Farm Mutual Automobile Insurance Company A/S/O Denise A Caudill PO Box 2373 Bloomington, IL 61702-2373 VS Marc D. Hoffman 102 Beard Road Enola, PA 17025 PRAECIPE FOR JUDGMENT TO THE PROTHONOTARY: Enter Judgment in the above case by default for want of response to the Complaint filed against the Defendant Marc D. Hoffman, and assess the damages as per the statement below: Real Debt: $5,322.5hee., 00, "4ez Pa 1 . sy,Esquir I hereby certify that written notice of the intention to file this Praecipe was mailed to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this Praecipe. A copy of said notice is attached hereto. Attorney for Plaintiffs : In The Court of Common Pleas : Cumberland County, Pennsylvania Civil Action Law No. 2008-04257 0Jg1,6"y*' Paul J. Henn ssy, Esquire And now, , . ,0 , 2009, Judgment entered in favor of the Plaintiff and against the Defendant by default for want of response to the Complaint and damages assessed at the sumo :$5,322.58 per above statement. .. __ uthonotaa° . OFFICE OF TES PROTHONOTARY COURT OF COMMON PLEAS Dated: December 23, 2008 • Marc D. Hoffinan To: 102 Beard Road Enola, PA 17025 State Farm Mutual Automobile Ins. Co. A/S/O Denise Caudill COURT OF COMMON PLEAS Cumberland County, Pennsylvania Civil Action Law VS Marc D. Hoffman No: 2008-04257 Notice, Rule 237.5 Notice of Praecipe to Enter Judgment by Default IMPORTANT NOTICE 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 notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help. Cumberland County Bar Association 32 S. Bedford St. Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber presentado una comparecencia escrita, ya seapersonalmente o por abogado y por no haber radicado por escrito con este Tribunal sus defenses u objeciones a los reclamos formulados en contra suyo. Al no tomar laaccion debida dentro de diez (10) dial de la fecha de esta notificacion, el Tribunal podra, sin necesidad de comparecer usted en corte u oir preuba alguna, dictar sentencia en su contra y usted podria perder bienes u otros derechos importantes. Debe llevar esta notiftacion a unabogado inmediatamente. Si usted no tiene abogado, o si no tiene dinero suficiente para tal sericio, vaya en persona o flame por telefono a la oficina, nombrada para averiguar si puede consegui asistencia legal. Cumberland County Bar Association 32 S. Bedford St. Carlisle, PA 17013 717-249-3166 800-990-9108 If you have any question concerning this notice, please call: Paul J He essv, Fsguire (Name of Attorney or Plaintiff) 142 W Market Street. Suite 2 West-Chester, PA 19382 (Attorney's or Plaintiff's Address) at this telephone number: 610-431-2727 Paul J. Hennessy, Esquire Hennessy & Walker Group, P.C. 142 W. Market Street West Chester, PA 19382 610-431-2727 Attorney I.D. 65396 Attorney for Plaintiffs State Farm Mutual Automobile Insurance Company A/S/O Denise A Caudill PO Box 2373 Bloomington, IL 61702-2373 VS Marc D. Hoffman 102 Beard Road Enola, PA 17025 In The Court of Common Pleas : Cumberland County, Pennsylvania : Civil Action Law : No. 2008-04257 AFFIDAVIT OF NON-MILITARY SERVICE STATE, OF PENNSYLVANIA: . ss. COUNTY OF CHESTER Paul J. Hennessy, Esquire, being duly sworn according to law, deposes and says that he represents the Plaintiff(s) in the above entitled case; that he is authorized to make this affidavit on behalf of the Plaintiff(s); and that the above named Defendant(s) is(are) unknown years of age; the address of Defendant(s) is 102 Beard Road Enola, PA 17025,; occupation of Defendant(s) is unknown; and Defendant is not in the Military Service of the United States nor any State or Territory thereof or its allies as defined in the Soldier A' and Sailors' Civil Relief Act of 1940 and the amendments thereto. /X? 'r. / / . . . , PiGl-J. HoMessy, Esquire Sworn to and subscribed before me thi /b71/day of _,:%Vj tty 2009. Notary Public COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL THERESA B. CHUPLIS, Nota Public West Chester Boro., Chps}?:r ro?rnty M Gammieiii0h Expires Nevetnbu 01,Q__ r..a ? a -s3 Ull I- . a State Farm Mutual Automobile Insurance Company A/S/O Denise A Caudill PO Box 2373 Bloomington, IL 61702-2373 VS Marc D. Hoffman 102 Beard Road Enola, PA 17025 : In The Court of Common Pleas : Cumberland County, Pennsylvania Civil Action Law No. 2008-04257 NOTICE IS GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST YOU. ?1 G P THON dac4 ? If you have any questions concerning the above, please contact: Paul J. Hennessy, Esquire Attorney or Party Filing 142 West Market Street, Suite 2 West Chester, PA 19382 610-431-2727 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLI O INC Plaintiff vs. RODNEY D CONRAD Defendant No. 08-4237-CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT 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 Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6433043 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLI O INC Plaintiff vs. Civil Action No. 08-4237-CIVIL TERM RODNEY D CONRAD Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: dt, Esquire JamT PA WEERG & REIS CO., L.P.A. 271ng 436 Pitts(412WWR #6433043 Of 7HF 2 09t i 13 VH19, r? cK? ss?m?7 Sheriffs Office of Cumberland County R Thomas Kline g10", $t tumbrpt tawara L 6cnorpp Sheriff ? Solicitor .µ " ->? Ronny R Anderson Jody S Smith Chief Deputy OFFICE OF T 4E 5,4E RIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/22/2009 03:35 PM - R. Thomas Kline, Sheriff, who being duly swom according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Rodney C. Conrad, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Rodney C. Conrad. The Newville Postmaster has advised the defendant is not known at address given. An exact address is not available. SHERIFF COST: $43.80 SO AWP'PISr' // May 27, 2009 / lj?. R 2008-4237 International Portfolio Inc. VS Rodney D. Conrad KLINE, SHERIFF c.? - La -0 - CX) 4 c? F1LF,D_ . ,,. . f-E 7' Lr! t4P R J hi l ??; L i 9 y i'I live', IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO, INC Plaintiff VS. RODNEY D CONRAD Defendant No. 08-4237-CIVIL TERM MOTION FOR ALTERNATE SERVICE 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 #6433043 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO, INC Plaintiff No. 08-4237-CIVIL TERM vs. RODNEY D CONRAD Defendant PLAINTIFF'S MOTION FOR ALTERNATE SERVICE AND NOW, comes Plaintiff, by counsel, Weltman, Weinberg & Reis Co., L.P.A. and requests this Honorable Court to enter an Order allowing the Plaintiff to make service upon Defendant, Rodney D. Conrad, by certified U.S. Mail and Certificate of Mailing, addressed to 151 Oak Flat Road, Newville, Pa 17241, averring in support thereof the following: On or about July 16, 2008, Plaintiff filed a Complaint in Civil Action against Defendant to recover the unpaid balance due Plaintiff from Defendant in the amount of $1,865.95. 2. When the Sheriff of Cumberland County, Pennsylvania, attempted to make service of Plaintiff's Complaint on Defendant, the Sheriff was unable to do so, as evidenced by the Sheriff's return, a true and correct copy of which is attached hereto, marked Exhibit "1", and made a part hereof. 3. Upon receipt of the Sheriff's return of no service, Plaintiff conducted an investigation with the United States Postal Service to confirm the physical address of the Defendant. WWR #6433043 4. Pursuant to Plaintiff's request for information, the United States Postal Service confirmed Defendant's physical address of 151 Oak Flat Road, Newville, Pa 17241, a true and correct copy of Plaintiff's Postal Request is attached hereto, marked as Exhibit "2", and made a part hereof. 5. Plaintiff conducted an online white pages search and was able to confirm a current address for Defendant of 151 Oak Flat Road, Newville, Pa 17241. A true and correct copy of the search results is attached hereto as Exhibit "3" and made a part hereof. 6. Plaintiff contacted the Cumberland County Tax Assessment office, a representative from which could not confirm the Defendant as being the registered owner of 151 Oak Flat Rd, Newville, PA 17241. 7. Upon receipt of the Sheriff's return of no service, Plaintiff conducted an investigation with the Accurint Total Research System to confirm the physical address of the Defendant. 8. Pursuant to Plaintiff's request for information, Accurint Total Research System confirmed Defendant's physical address of 151 Oak Flat Rd, Newville, PA 17241, a true and correct copy of the Accurint search results is attached hereto, marked as Exhibit "4", and made a part hereof. 9. Based upon the foregoing, Plaintiff believes and therefore avers that Defendant is attempting to avoid service of process in the above-captioned matter and Plaintiff therefore seeks an Order of Court, pursuant to Pennsylvania Rule of Civil Procedure 430, granting Plaintiff leave to serve its Complaint on Defendant by alternative means. WWR #6433043 WHEREFORE, Plaintiff requests this Honorable Court to enter an Order pursuant to PA.R.C.P. 430(a), authorizing the Plaintiff to serve Defendant by Certified U.S. Mail and Certificate of Mailing sent to an address (151 Oak Flat Road, Newville, Pa 17241) at which Defendant is presently receiving mail according to information obtained from the Post Office, or by allowing service by a competent adult. William T. Molcz 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 #6433043 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO, INC NO. 08-4237-CIVIL TERM Plaintiff vs. RODNEY D CONRAD Defendant AFFIDAVIT PURSUANT TO PA R.C.P. 430 (a) BEFORE ME, a Notary Public, in and for the foregoing County and Commonwealth, personally appeared William T. Molczan, Esquire, of Weltman, Weinberg & Reis, Co., L.P.A., attorneys for Plaintiff, and deposes and says that the following accurately reflects efforts made to ascertain the exact whereabouts of Defendant named in the above-captioned matter. a. Plaintiff requested current address information from the United States Postal Service, which request for information confirmed the current address for Defendant as being 151 Oak Flat Road, Newville, Pa 17241. A true and correct copy of the Postal Service Return is marked Exhibit "2" attached hereto and made a part hereof. b. Plaintiff conducted an online what pages search that confirmed the Defendant's address to be 151 Oak Flat Rd, Newville, PA 17241. A true and correct of the search results is attached hereto as Exhibit "3" and made a part hereof. C. Plaintiff requested current address information from the Accurint Total Research System, which request for information confirmed the current address for Defendant as being 151 Oak Flat Rd, Newville, PA 17241. A true and correct copy of the Accurint search results is marked Exhibit "4" attached hereto and made a part hereof. WWR #6433043 d. Plaintiff conducted an online tax-assessment search for the address of the Defendant that could not confirm the Defendant as being the registered owner of 151 Oak Flat Rd, Newville, PA 17241. Finally, Affiant deposes and says that after the foregoing investigation, the exact whereabouts of the Defendant, Rodney D. Conrad, is 151 Oak Flat Road, Newville, Pa 17241. WELTMAN, WEINBERG & REIS, CO., L.P.A. William T. Molczan, uire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 Sworn to and subscribed before me this day arch, 10 Not Y "Pie ? #anhN, ?jp#i?ry ?uM10 et rktgd+?rgR.Ma Gaunly in 2!.014 ?n WWR #6433043 Sheriffs Office of Cumberland County R Thomas Kline 1"'Vx1r 01 culnhrr4 Edward L Schorpp Sheriff Solicitor k Ronny R Anderson Jody S Smith Chief Deputy OFFICE OF r?ss SRERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/22/2009 03:35 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Rodney C. Conrad, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Rodney C. Conrad. The Newville Postmaster has advised the defendant is not known at address given. An exact address is not available. SHERIFF COST: $43.80 SO AI? May 27, 2009 R yHoMAS KLINE, SHERIFF 2008-4237 Intemational Portfolio Inc. VS Rodney D. Conrad EXHIBIT l Postmaster NEWVILLE, PA 17241 Date: July 13, 2009 REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDED FOR SERVICE OF LEGAL PROCESS Please furnish the new address or the name and street address (if a boxholder) for the following: Name: RODNEY D CONRAD 151 OAK FLAT RD Address: NEWVILLE, PA 17241 Note: Only one request may be made per completed form. The name and last known address are required for change of address information. The name, if known, and Post Office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(5)(ii). There is no fee for providing boxholder or change of address information. 1. Capacity of requester (e.g., process server, attorney, party representing self): ATTORNEY 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se-except a corporation acting pro se must cite statute): RODNEY D CONRAD, INTERNATIONAL PORTFOLIO INC. 3. The names of all known parties to the litigation: 4. The court in which the case has been or will be heard: PROTHONOTARY CUMBERLAND C 5. The docket or other identifying number (a or b must be filled out): X a. Docket or other identifying number: #08-4237-CIVIL TERM b. Docket or other identifying number has not been issued 6. The capacity in which this individual is to be served (e.g., defendant or witness): DEFENDANT WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OR LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO 510,000 OR IMPRISONMENT OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). I certify that the above i formation is true and that the address information is needed and will be used solely for service of legal process in conluncpon with actual ective litigation. ?[-r+ SiRna ure William T. Molczan, Esquire / PA ID# 47437 Attorney Printed Name WWR File No. 6433043 User: TSW No change of address order on file: Moved, left no forwarding address: No such address: _ WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 ?L ,.-PA I FOR POST OFFICE USE ONLY NEW ADDRESS OR BOXHOLDER'S NAME POSTMARK U r AND STREET ADDRESS EXHIBIT Page 1 of 1 Free People Search I WhitePages WhftePages (But no listings in Newville, PA) Or search: Last name only Metro area Rodney C Conrad Jr is this you? Edit 2323 N Third St Harrisburg, PA 17110-1816 (717) ?y r 5i?" ? ?? rr ct P?? F1t+' ? ?. ? 71 y 2 ?? ? ?yrti4 r `3 N ? D r, n? c,4 Sr , m Y ?1 LT 7 ^(Y`? mil. r? 500 yds © 2010 Microsoft Corporat Listing date: Nov. 2009 Blocked Website v our access to t:?te L eL)sit:e rat.tP:/, 1vie'w.at.dmr .com/AVE/iview/192038337/ click=i?ttp://atl.whitepages.co r=/adclick/ CID vvas blocked for the following reason: locked Reason: Blocked URL: Rule type is: Domain, Rule is: *.atdrnt.corn To report a alts-categorized URL pl EXHIBIT httn•/hxnxnv vuhite-nRcy- rnm/cParrh/FinriPPrcnn7firctnamP hPOinc uAth=1 R fiirgtnamp=ROT)NFVRrnamP= vi wmi n Deep Skip Search RODNEY DALE CONRAD RODNEY D CONRAD RODNEY CONRAD DOB- Age: 52 Gender - Male Setuo Alert 151 OAK FLAT RD NEWVILLE PA 17241-9467 Link ID: 499704508 Nov 05 - Feb 10 httnc•//cPrnrP arrnrint rnm/ann/hnc/micr Page 1 of 1 EXFII811 vi Rom n CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of the within Motion for Alternate Service was served on the day of 2010, by first class, U.S. Mail, postage-prepaid, addressed as follows: Rodney D. Conrad 151 Oak Flat Road Newville, Pa 17241 Attorney for Plainti WWR #6433043 APR 1 4 tuiu IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION d _?- INTERNATIONAL PORTFOLIO, INC Plaintiff No. 08-4237-CIVIL TERM vs. RODNEY D CONRAD ORDER OF COURT AND NOW, to-wit, this 1444 day of Avuj.2010, upon consideration of the foregoing Motion for Service of the Complaint Pursuant to Special Order of Court and attached supporting affidavit, it is hereby ORDERED, ADJUDGED AND DECREED, that the service of the Complaint in Civil Action may be made on Defendant, Rodney D. Conrad, by permitting the Plaintiff to mail a copy of the Complaint to the Defendant the last known address being 151 Oak Flat Road, Newville„Pa 17241 by Certified Mail and b y ; 4 6? P60-60164 Certificate of Mailing Postal Form 3817, postage prepaid. Service to be completed upon mailing" ?"? ? • BY THE COURT: DISTRIBUTION: Rodney D Conrad 151 Oak Flat Rd Newville, PA 17241 W' iam T. Molczan, Esq. 1 eltman, Weinberg & Reis, Co. LPA 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 WWR #6433043 v' A Tt{'.a -~ ,. Av63 cwt ~~ :so IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. No. 08-4237-CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT RODNEY D CONRAD Defendant(s) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Lyndsay E Rowland, Esquire PAID #205520 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Buidling 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6433043 TIC C'IE IQq ~.'~ a~-~ i s~f v I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CNIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No. 08-4237-CNIL TERM RODNEY D CONRAD Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTM~IN~ WEINBERG & REIS CO., L.P.A. By: Lyndsay R wland, Esquire PA ID #2 0 WELTM , WEINBERG & REIS CO., L.P.A. 1400 Koppers Buidling 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #6433043 F4~_~~?-~s FIGS ~~ c o-?d_ ~''~~ 1 rC?~~~Tk ~'f X010 S^t ? ~ ,,'`' I~~ -~D "'.~'1~~~k_~~~C~ CC~v~" E. _ 3a,~^'~`rl in ~`~l"~ ,..:l e,°tib . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. RODNEY D CONRAD Defendant No. 08-4237-CIVIL TERM AFFIDAVIT OF SERVICE OF 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 Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6433043 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. RODNEY D CONRAD Defendant No. 08-4237-CIVIL TERM AFFIDAVIT OF SERVICE OF COMPLAINT Before me, the undersigned authority, personally appeared William T. Molczan, Esquire, who, being duly sworn according to law, deposes and says that on JULY 30, 2010, he did cause to be sent to Defendant, Rodney D Conrad, Plaintiff's Complaint by Certificate of Mailing Postal Form 3817 and on JULY 30, 2010, he did cause to be sent to Defendant, Rodney D Conrad, Plaintiff's Complaint by Certified Mail, Return Receipt requested, directed to the Defendant at his last known address of 151 Oak Flat Rd, Newville, PA 17241. True and correct copy of Plaintiff's Certificate of Mailing PS Form 3817 is attached hereto, marked as Exhibit "1" and made a part hereof. Furthermore, true and correct copy of Plaintiff's Receipt for Certified Mail is attached hereto, marked as Exhibit "2" and made a part hereof. As the Order of Court states, service is deemed to be perfected as of JULY 30, 2010, the date of mailing. WELTMAN, WEINBERG & REIS CO., L.P.A. By: ~ .~~ WILLIAM T. MOLCZAN, ESQUIRE PA I . D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6433043 Sworn to and subscribed before me this i3'N day of SEPTEMBER, 2010. '"~~ ARY PU IC COMMONWEALTH OF PENNSYLVANIA Notarlal5eal Public Wayne A. Jones, Notary Pty ~( pfgsburgh, pUegheny County ~, Commission res June 29, 2014 Member, Pennsvlvanla pssodadon of Notaries /1A ~~ (JNl7',EI)ST~~7'iES Ceri<ifica~e Of ,~OST/~ L SER V1CE1~ M a i i i n This Cerllflcale o1 Malling provldec evidence lhal mall has E.en prseenled to USPSB for mailing. d InlemaUonal mall. ti i-_=, i _. 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FILEQ-aF~ic~ DF THE PROTHONOTARY 2fl1~10CT 25 Phi 2~ ~6 G1.~9~aERLAP~O COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO, INC Plaintiff vs. RODNEY D CONRAD defendant No. 08-4237 CiVL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff CO[JNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA I.D. #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6433043 Judgment Amount $ 2l 23.30 ~iV od ~ e,c~' y8.2s1 ~.~ a,s-p c ~r,S IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO, INC Plaintiff vs. Civil Action No. 08-4237 CIVL TERM RODNEY D CONRAD 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 (xx) Assumpsit Judgment in the amount of $2123.30 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: ~ - PROTH O R RODNEY D CONRAD 151 OAK FLAT RD NEWVILLE, PA 17241. Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO, INC Plaintiff vs. Civil Action No. 08-4237 CIVL TERM RODNEY D CONRAD Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, RODNEY D CONRAD above named, in the default of an Answer, in the amount of $2123.30 computed as follows: Amount claimed in Complaint $1865.95 Interest from 06/26/08 to 10/15/10 at the interest rate of 6.00% per annum $257.35 TOTAL $2123.30 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 & RE1S CO., L.P.A. By: James C. Wa PA I.D. #42 WELTMA 1400 Kopp ~ 436 Seven (412) Esquire & REIS CO., L.P.A. Av nue P 15219 WWR#6433043 Plaintiff s address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7~' Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 151 OAK FLAT RD, NEWVILLE, PA 17241 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. RODNEY D CONRAD Defendant Case No. 08-4237-CIVIL TERM IMPORTANT NOTICE TO: RODNEY D CONRAD 151 OAK FLAT RD NEWVILLE, PA 17241 TT Date of Notice: ~Z~ ~ ~l~' 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. lF 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, WE_,1Al~ERG & REIS CO., L.P.A. By: Matthew Urban P.A.I. D.# 90963 WELTMAN, WEINBERG &REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 6433043 H PIT TIC IN THE COMMON PLEAS COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO, INC Plaintiff vs. RODNEY D CONRAD Defendant Civil Action No. 08-4237 CIVIL TERM NON-MILITARY AFFIDAVIT The undersigned is the duly authorized agent and/or attorney for the Plaintiff in the within matter and states as follows: Affiant 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, RODNEY D CONRAD 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 DMDC does not possess any information indicating that the below individual is in the military service: RODNEY D CONRAD 151 OAK FLAT RD NEWVILLE, PA 17241 Affiant further states that the averments contained herein are true and correct to the best of Affiant's knowledge, information and belief and that these averments are made subject to the penalties of 18 Pa C.S.A. §4904 relating to unsworn falsification to authorities. Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Oct-20-2010 07:21:34 ~` Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency CONRAD RODNEY D Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. 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 Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). ~~ ~-~ 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 DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as 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 status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.mil/faq/pis/PC09SLDR.htm1. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional 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 active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. httr~c~//www.dmdc.ncd mil/a»»i/ccra/nnnrennrt ~~ 1(1/2(1/x(11(1 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:ALVCNU6N97 httnc•//www ~lm~l~. nc~l mil/anni/c~ra/nnnrPnnrt ~n 1 nnn/~~~ n