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Home My WebLink About08-4244 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff No. 0 ?- , % ), L/ /-/ C ?ti ; 4-C.rn vs. NGHIA T NGUYEN 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#6433038 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. 0?-- V L tl y c d v, i NGHIA T NGUYEN 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 Plaintiff is a corporation with offices at 7465 N.W. 49TH ST, LAUDERHILLE, FL 33319- 0000. 2. Defendant is an adult individual residing at 7 FORGEDALE DR CARLISLE,PA 17013. COUNT I - ACCOUNT NO. 8589327718 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, NGHIA T NGUYEN, 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, NGHIA T NGUYEN, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, NGHIA T NGUYEN, in the amount of $1,401.09 as of MAY 28 2008. 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, NGHIA T NGUYEN, in the amount of $1,401.09 with continuing interest thereon at the rate of 6% per annum from MAY 28 2008 and costs. COUNT II - ACCOUNT NO. 8589312964 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, NGHIA T NGUYEN, 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, NGHIA T NGUYEN, agreed to pay. 14. Plaintiff avers that there is a balance due and owing from Defendant, NGHIA T NGUYEN, in the amount of $2,719.81 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, NGHIA T NGUYEN, in the amount of $2,719.81 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. M CZAN, 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#:6433038 05/13/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES CARLISLE REGIONAL MEDICAL CTR DA17 COID: 858 AS OF 05/12/08 361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE 717 960-1680 ---- ------- -----------------------?----_ _ ____ ---------------------_ PATIENT: NGUYEN, NGHIA T F /C: P P/T: E A/C: 9327718 DSC CODE: 01 TO: NGUYEN, NGHIA T ADMISSION: 12/19/05 DISCHARGE: 12/19/05 7 FORGEDALE DR CARLISLE PA 17013 4 A M O U N T 4 337.44 830.14 233.51 1,401.09- ---------------- ---------------- SELECT: REV= * DEPT= * CHGCD= * TOTAL 0.00 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: NGUYEN, NGHIA T F/C: P P/T: E A/C: 9312964 DSC CODE: 01 TO: NGUYEN, NGHIA T ADMISSION: 06/11/05 DISCHARGE: 06/11/05 7 FORGEDALE DR CARLISLE PA 17013 11 T T 71 w . _ .. A M O U N T 79.79 80.64 1,006.32 1,553.06 2,719.81- ----------------------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 a no unders*fed does hereby Verify subject to the penalties of 18 PA.C.S. 14 relating to unsworn falsifications to authorities, that she is LM& MdN'1' RCI. C) ME p??:.1???? O? ???RAI1?1?S of Il?Tfi1;1??TA`'tQNAt, pnAR'?'? O 1N?., 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# N \ ^1 d p C) "a te r - ns r ? 1. cm J . ` CJ c SHERIFF'S RETURN - REGULAR CASE NO: 2008-04244 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS NGUYEN NGHIA T 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 HGUYEN NGHIA T the DEFENDANT at 1851:00 HOURS, on the 21st day of July , 2008 at 7 FORGEDALE DRIVE CARLISLE, PA 17015 -T TTTT TTrITTU177TT by handing to 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: So Answers: Docketing 18.00 Service 5.00 Affidavit .00? Surcharge 10.00 R. Thomas Kline .00 33.00 07/22/2008 WELTMAN WEINBERG REIS T/23/DS trin Sworn and Subscibed to By: before me this day Deputy Sheriff of A.D. I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. NGHIA T NGUYEN Defendant No. 08-4244-CIVIL PRAECIPE TO SETTLE, DISCONTINUE AND END WITH PREJUDICE 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#06433038 i IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. 08-4244-CIVIL NGHIA T NGUYEN Defendant PRAECIPE TO SETTLE DISCONTINUE AND END WITH PREDJUDICE TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue the above captioned matter upon the records of the Court with prejudice and mark the cost paid. Sworn to and subscribed Before me the oZ Day of August, 2008 ARY P C WELTMAN, WEINBERG & REIS CO., L.P.A. By: '!? JAM C ARMBRC PA. 4 h WEWEINBE 140 Building 436 venue Pitts 15219 Esquire & REIS CO., L.P.A. (411) 4-7955 WRIFN06433038 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Wayne A. Jones, Notary Public City Of Pittsburgh, Allegheny County My Commission Expires June 29, 2010 Member, Pennsylvania Asscci lion of Notaries 4 -.`I M1 1 7'k , ?Y r°?' ty _ 7 . , c? -?; ,r s'?.: c.t?