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Home My WebLink About08-4243 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. JOSHUA R LOCKEY Defendant No. 0 S--- L/ ?_ V 3 c ??v 1) `4 crag 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#6432936 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No. 2y 3 c rr," l -f min JOSHUA R LOCKEY 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 Plaintiff is a corporation with offices at 7465 N.W. 49TH ST, LAUDERHILLE, FL 33319- 0000. 2. Defendant is an adult individual residing at 756 W LOUTHER ST 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, JOSHUA R LOCKEY, 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, JOSHUA R LOCKEY, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, JOSHUA R LOCKEY, in the amount of $1,660.27 as of MAY 29 2008. 8. Plaintiff claims interest at the legal rate of six (6%) percent per annum from MAY 29 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, JOSHUA R LOCKEY, in the amount of $1,660.27 with continuing interest thereon at the rate of 6% per annum from MAY 29 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. M(P;ZAN, 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#:6432936 05/13/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 CARLISLE REGIONAL MED CTR AS OF 08/16/07 361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 ---- ------- ------------------------------------------------------------------ PATIENT: LOCKEY, JOSHUA R F/C: P P/T: E A/C: 9289514 DSC CODE: 01 TO: LOCKEY, JOSHUA R ADMISSION: 08/14/04 DISCHARGE: 08/14/04 756 W LOUTHER ST CARLISLE PA 17013 A M O U N T 48.10 133.06 1,479.11 1,660.27- ----------------------------------------------------------------------------- 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 lg 14904 relating to unsworn falsifications to authorities, that she is LIN MONTEROSSO (Name) 'VLC P SI BN--T tO_F_OPERA LON of INTERNIATIOAL, PORTFOLIO INC., plaintiff (Title) (Comfy) 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. W## (O 1 C C a ?a C c n EJS rye' I Q3 --C SHERIFF'S RETURN - REGULAR CASE NO: 2008-04243 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS LOCKEY JOSHUA R MICHELLE GUTSHALL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LOCKEY JOSHUA R the DEFENDANT , at 0015:20 HOURS, on the 8th day of August , 2008 at 756 W LOUTHER STREET CARLISLE, PA 17013 by handing to DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing // 18.00 Service ? 8 01 15.00 00 Affidavit 48 . Surcharge "? Do 10.00 Sworn and Subscibed to before me this So Answers: R. Thomas Kline 43.00 08/11/2008 WELTMAN WEINBERG & REIS By: day Deputy Sheriff of A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. JOSHUA R LOCKEY Defendant No. 08-4243 CIVIL PRAECIPE FOR DEFAULT JUDGMENT 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#06432936 Judgment Amount $ 1707.21 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. JOSHUA R LOCKEY Defendant Civil Action No. 084243 CIVIL PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, JOSHUA R LOCKEY above named, in the default of an Answer, in the amount of $1707.21 computed as follows: Amount claimed in Complaint $1660.27 Interest from 05/29/08 to 11/17/08 at the legal interest rate of 6.00% per annum $46.94 TOTAL $1707.21 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. William T. Molcz squire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06432936 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7t' Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 756 W .LOUTHER ST, CARLISLE, PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. 08-4243 CIVIL JOSHUA R LOCKEY Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Jud ent was entered against you on (xx) Assumpsit Judgment in the amount of $1707.21 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: PR ONOTAR PUTY) JOSHUA R LOCKEY 756 W LOUTHER ST CARLISLE, PA 17013 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7`" Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Case no: 08-4243 CIVIL Plaintiff vs. JOSHUA R LOCKEY Defendant NON-MILITARY AFFIDAVIT 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, JOSHUA R LOCKEY 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, JOSHUA R LOCKEY is not in the military service. Further Affiant sayeth naught. AFFIANT SW d TQ AND SUBSCRIBED in my presence this day CC^v &ri0 1A' ALTI, OF PENl`!SYLVAN',I:'1 Nctarial Seal OTARY PUBLIC Wendy L. Gault, Notary Public City Of Pittsburgh, Al•':?gheny County My Commission Expires July 15, 2010 Member, Pennsylvz:ni ,t-,:?^ac;atiun of Notaries This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO IN Plaintiff JOSHUA R LOCKEY Defendant(s) IMPORTANT NOTICE TO: JOSHUA R LOCKEY 756 W LOUTHER ST CARLISLE,PA 17013 Date of Notice: ( 1 y / WWR#: 064.32936 Case # ?n rD? lJ' L.?V? 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 FOLLOWING 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 '-? BY • i?'a G?icA? 1 hwv.o-ti ?18 ass,-ww--- PATRICK THOMA W O MAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 (412) 434-7955 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 NOV-17-2008 07:51:42 "< Last Name First/Middle Begin Date Active Duty Status Service/Agency LOCKEY SEP 19-2008 Active Duty Army 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. Atut 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. See: http://www.defenselink.mil/faq/pis/PC09SLDR.html 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 11/17/2008 Request for Military Status Report ID: FILBGPOGWFK Page 2 of 2 https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 11/17/2008 i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. JOSHUA R LOCKEY Defendant(s) No. 08-4243-CIVIL PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF' Plaintiff COUNSEL OF RECORD OF THIS PARTY: 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7999 James C. Warmbrodt, Esquire PA I.D. # 42524 WELTMAN, WEINBERG & REIS CO L P A WWR#6432936 TSW IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No. 08-4243-CIVIL JOSHUA R LOCKEY Defendant(s) PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. PA I.D. # WELTM 1400 K ,mbrodt, Esquire 24 WEINBERG & REIS CO., L.P.A. Building 436 See h Avenue Pittsb , PA 15219 (412) 34-7999 WWR #6432936 Sworn to and sub gibed before me this day of May, 09 NOT Y PUBLIC COMMONWF.;aLTH 9f.PENNSYLVANIA t?as.anai Seal ?PVendy L CiNA, Moto Pubt'rc tarty of N ttst!urch Atiegheny County Mt" Comm xp?re4..xuty 15, 2010 ssociation of Notaries ember, pennsyrvanis A M FL`' }- ` THE «?Y 7ggg ^ 23 1! 10: 2 2 CU jt E •1,,,! ...r * 8 . ow Po ATIWT Cut 403g511 p4 ?2agoa8