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Home My WebLink About08-4241 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. WENDY E ANDERSON Defendant No. 0 %" kl'?-y ( '", i fzf't' 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#6433016 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No. O b ? ya Lj l WENDY E ANDERSON 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 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 158 A STREET 158 A STREET CARLISLE,PA 17013 . COUNT I - ACCOUNT NO. 8589320054 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, WENDY E ANDERSON, received and accepted the aforementioned medical services which were provided by Plaintiffs assignor 6. The prices charged by Plaintiffs assignor were the prices that Defendant, WENDY E ANDERSON, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, WENDY E ANDERSON, in the amount of $439.41 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, WENDY E ANDERSON, in the amount of $439.41 with continuing interest thereon at the rate of 6% per annum from MAY 28 2008 and costs. COUNT II - ACCOUNT NO. 8587531505 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, WENDY E ANDERSON, 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, WENDY E ANDERSON, agreed to pay. 14. Plaintiff avers that there is a balance due and owing from Defendant, WENDY E ANDERSON, in the amount of $868.54 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, WENDY E ANDERSON, in the amount of $ 868.54 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. MO AN, 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#:6433016 05/13/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES CARLISLE REGIONAL MEDICAL CTR DA17 COID: 858 AS OF 05/12/08 /08 361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE 717 960-1680 --------------------------------- ___ PATIENT: ANDERSON, WENDY E F/C: F P/T: E A/C: 9320054 DSC CODE: 01 TO: ANDERSON, WENDY E ADMISSION: 09/05/05 DISCHARGE: 09/05/05 158 A STREET CARLISLE PA 17013 INS CD: 200/KCE BLUE CROSS 361 KCE GROUP 140648 POL ID: YWH170561 A M O U N T 13.97 475.44 50.00- 439.41- ---------------- ---------------- 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 I 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: ANDERSON, WENDY E F/C: F P/T: 0 A/C: 7531505 DSC CODE: 01 TO: ANDERSON, WENDY E ADMISSION: 09/15/05 DISCHARGE: 09/15/05 158 A STREET CARLISLE PA 17013 INS CD: 200/KCE BLUE-CROSS--361 KCE GROUP 140648 POL ID: YWH170561 A M O U N T 868.54 868.54- ------------------0.00------------ 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 veri?r subject to the penalties of I g 14904 relating to unsworn falsifications to authorities, that she is L t1 MCIN't`l ROSS() VI P F IT)FN " ?P b R-Anp S of t ItNA`I"tONAt pnR' atTr, t1`rr 'Title) plaintiff (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## ? o V C"1 C C= CJ T....,t `? fi' 8. _ ti SHERIFF'S RETURN - REGULAR CASE NO: 2008-04241 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS ANDERSON WENDY E MICHELLE GUTS14ALL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ANDERSON WENDY E the DEFENDANT , at 2113:00 HOURS, on the 21st day of July , 2008 at 158 A STREET CARLISLE, PA 17013 T.Tvmnv ATTT1vv cnT.T 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 Service Affidavit Surcharge Sworn and Subscibed to before me this So Answers: 18.00 5.00 00 10.00 R. Thomas Kline .00 33.007/22/2008 W LTMAN WEINBERG REIS 7/u/oa By. day Deputy Sheriff of A. D. - a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff VS. No.08-4241-(-IVIL TERM PRAECIPE FOR ENTRY OF JUDGMENT BY CONSENT WENDY E ANDERSON Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esq. PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR06433016 .,._ ., _ '? ?f,. ? _ ...? ,.?. .. _ ... .. ? _ .,... IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff VS. Civil Action No. 08-4241-CIVIL TERM WENDY E ANDERSON Defendant PRAECIPE FOR JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment against Defendant, WENDY E ANDERSON, in the amount of $1307.95 plus costs, based upon the consent of the parties. CONSENTED TO: WELTMAN, WEINBERG & REIS CO., L.P.A., By: Attorney or Plaintiff WENDY E ANDERSON, By: Awwf WVJ-OA Defendant WWR#06433016 .. ,. .? _„ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff VS. Civil Action No. 08-4241-CIVIL TERM WENDY E ANDERSON Defendant 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, WENDY E ANDERSON, above- named, in the amount of $1307.95 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment by Consent, as follows: Defendant admits indebtedness to Plaintiff in the amount of $1307.95 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, WENDY E ANDERSON, in the amount of $1307.95 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. ? d! 4. All payments are to be made payable to the order of "INTERNATIONAL PORTFOLIO INC." 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 Plaintiff's 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 o 601f , 20 l WELTMAN, WEINBERG & REIS CO., L.P.A. By: atthew D. Urban, Esq. PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 06433016 By: Defend t, WENDY E ANDERSON 00 Q .S1 p 0000 y 52 -OF rs N GJ A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff VS. Civil Action No. 08-4241-CIVIL TERM WENDY E ANDERSON Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or ud ment was entered against you on D (xx) Assumpsit Judgment in the amount of $1307.95 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 Ordet ( ) Non-Pros ( ) Confession ( ) Default ( ) Verdict ( ) Arbitration ( ) Award (XX) By Consent Prothonotary WENDY E ANDERSON 158 A STREET CARLISLE, PA 17013 By: PR O R D UTY)