The URL can be used to link to this page

Home My WebLink About08-4238Lt. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff No () g- q?_ 3 K C tV I I Ttfib, VS. JOHN KECK 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#6432978 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. 0 ?r- y?- 3 S- c '?-u , l JOHN KECK 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) 249-31666 I % 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 1960 A FRY LOOP AVE CARLISLE,PA 17013. COUNT I - ACCOUNT NO. 8589307631 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, JOHN KECK, received and accepted the aforementioned medical services which were provided by Plaintiffs assignor 6. The prices charged by Plaintiff's assignor were the prices that Defendant, JOHN KECK, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, JOHN KECK, in the amount of $1,827.76 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, JOHN KECK, in the amount of $1,827.76 with continuing interest thereon at the rate of 6% per annum from MAY 28 2008 and costs. COUNT II - ACCOUNT NO. 8589307756 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, JOHN KECK, received and accepted the aforementioned medical services which were provided by Plaintiff s assignor 13. The prices charged by Plaintiffs assignor were the prices that Defendant, JOHN KECK, agreed to pay. 14. Plaintiff avers that there is a balance due and owing from Defendant, JOHN KECK, in the amount of $628.55 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, JOHN KECK, in the amount of $628.55 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. /4'.11, WILLIAM T. LCZAN, Esquire PA I.D. #4743 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219(412) 434-7955 WWR#:6432978 05/08/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 '361 CARLISLE REGIONAL MEDICAL CTR ALEXANDER SPRING RD CARLISLE AS OF 05/07/08 PA 17015 ----------------- PHONE (717) 960-1680 PATIENT: TO: KECK KECK, JOHN JOHN ------- ------- F/C: P P/T: E A/C: _ ____ --------------- 9307631 DSC CODE: 01 , 1960A FRY LOOP AVE ADMISSION: 04/03/05 CARLISLE PA 17013 DISCHARGE: 04/03/05 A M O U N T 31.81 104.32 133.05 178.10 1,380.48 1,827.76- ------------------------------------------ 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 05/08/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 05/07/08 361. ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 .---- --------- ------------------------------------------------------------------ PATIENT: KECK, JOHN F/C: P P/T: E A/C: 9307756 DSC CODE: 01 TO: KECK, JOHN ADMISSION: 04/05/05 DISCHARGE: 04/05/05 1960A. FRY LOOP AVE CARLISLE PA 17013 D E P A R T M E N T A M O U N T ^ 1 n CTTDDT.TF.C - MrnTrnT 16.88 611.67 628.55- ----------------------------------------------------------------------------- TOTAL 0.00 SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY= CMD:I=DAR,2=PAT 4=DETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD EXHIBIT The undersigned does hereby verify subject to the penalties of IS PA.C.S. 1490.4 relating to unsworn falsifications to authorities, that she is _LINA IyION`TEROSSO (N) V E P ESIDENfi OE OPIEB, TIIONS of _ . IIERNATIONAL PORTFOLIO INC., plaintiff (Title) (company) herein, that she is duly authorized to male this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the lest of her knowledge, information and belief. WWR l 1 e? r 6", CN. C) C V d yr V\nL 1A r+a °- CT ?3:3ft v t q X l_J SHERIFF'S RETURN - REGULAR CASE NO: 2008-04238 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS KECK JOHN GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon KECK JOHN the DEFENDANT at 2107:00 HOURS, on the 4th day of August 2008 at 1960 A FRY LOOP AVE CARLISLE, PA 17013 by handing to ELIFE NEELY, GIRLFRIEND ADULT IN CHARGE 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 Service ?a8?og Affidavit b Surcharge Sworn and Subscibed to before me this of So Answers: 18.00 10.00 .00 10.00 R. omas Kline .00 38.00 08/05/2008 WELTMAN WEINBERG REIS By: day Deputy eriff A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff VS. JOHN KECK Defendant No.08-4238-CIVIL PRAECIPE FOR ENTRY OF JUDGMENT BY CONSENT 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#06432978 t IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff VS. JOHN KECK Defendant Civil Action No. 08-4238-CIVIL PRAECIPE FOR JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment against Defendant, JOHN KECK, in the amount of $2456.31 plus costs, based upon the consent of the parties. CONSENTED TO: WELTMAN, WEINBERG & REIS CO., L.P.A., By: Attorney or Plaint' JOHN KECK, By: Dee ant WWR#06432978 %*T^ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. JOHN KECK Defendant Civil Action No. 08-4238-CIVIL STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment in favor of Plaintiff and against the Defendant, JOHN KECK, above-named, in the amount of $2456.31 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment by Consent, as follows: 1. Defendant admits indebtedness to Plaintiff in the amount of $2456.31 with.continuing interest thereon at a rate of 6% per annum plus costs from date of judgment. 2. To secure the repayment of said indebtedness, Defendant agrees that Judgment by Consent will be entered in favor of the Plaintiff and against the Defendant, JOHN KECK, in the amount of $2456.31 plus continuing interest thereon at the rate of 6% per annum from date of judgment and costs. Plaintiff agrees not to execute on its Judgment so long as Defendant causes to be delivered to Plaintiff the following payments in full by 12:00 NOON on the following dates: (a) $100.00 due by SEPTEMBER 20TH, 2008; (b) $100.00 due on the 20TH day of each consecutive month thereafter until the Judgment amount plus accrued interest and costs are paid in full. 4. All payments are to be made payable to the order of "INTERNATIONAL PORTFOLIO, INC." 5. All payments due under this agreement are to be received at the offices of Weltman, Weinberg & Reis, Co., L.P.A., P.O. BOX 5430, Cleveland, OH 44101-0430. 6. In the event of default, each payment received shall be first attributed to costs, interest and then to principal. 7. Time is of the essence of this agreement and should the Defendant fail to have in the hands of Plaintiff or Plaintiffs counsel any payment in full within five (5) calendar days of the stated due date, then Plaintiff shall be immediately free to issue Execution as well as pursue all other remedies, in law or in equity, to collect the full balance of the Judgment entered hereunder plus appropriate additional interest and costs. No act or omission of the Plaintiff, nor of anyone alleged to be acting on its behalf, shall constitute a waiver, estoppel, or any other excuse for non-performance of any duty undertaken by the Defendant in this Stipulation which the parties agree is final and complete. 9. Intending to be legally bound, the parties set their hands and seals this _day of 20 WELTMAN, WEINBERG & REIS CO., L.P.A. By: wn:? William T. Mo czan, Esq e PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 06432978 ? a ? ? ..? fir? _? ...,t ?. ? r -?.? ?? ?-: ? ? r- -?a ?? ,; ?. ? ? ?, ? n IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff VS. JOHN KECK Defendant Civil Action No. 08-4238-CIVIL 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 / FOR 4 I/ (xx) Assumpsit Judgment in the amount of $2456.31 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 ( ) Default ( ) Verdict ( ) Arbitration ( ) Award (XX) By Consent Prothonotary JOHN KECK 1960 A FRY LOOP AVE CARLISLE, PA 17013 By: PRO ONOT R D TY)