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Home My WebLink About08-4245 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No. o y- q l us CcL?-f % WILMA L CURTIS 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 33 S PENN ST APT 1 SHIPPENSBURG,PA 17257. 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, WILMA L CURTIS, 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, WILMA L CURTIS, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, WILMA L CURTIS, in the amount of $1,430.00 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, WILMA L CURTIS, in the amount of $1,430.00 with continuing interest thereon at the rate of 6% per annum from JUNE 26 2008 and costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. James C. W fi' rodt, P.A.I.D.# 4 524 einb g & Reis Co .,L.P.A. 436 SA enue, Suite 1400 Pittsb5219 Weltmt2-8-7130 (412)4 Fax: 4 6433044 06/13/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 06/12/08 361. ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 ---- ------- ------------------------------------------------------------------ PATIENT: CURTIS, WILMA L F/C: D P/T: I A/C: 9334266 DSC CODE: 01 TO: CURTIS, WILMA L ADMISSION: 03/14/06 DISCHARGE: 03/16/06 33 S PENN ST APT 1 SHIPPENSBURG PA 17257 INS CD: 105/POS AETNA-QPOS GROUP 811306011000 POL ID: W14335229 A M O U N T F 1,300.00 1,609.92 71.03 473.13 292.65 1,297.66 843.57 1,575.72 1,726.19 4,320.00- 4,869.87- -- --------------------------------------------- TOTAL 0.00 SEz`:-"'?e°" • CHGCD= * DATE/MDCY= * TO/MDCY= CMD:I=DAR,2=PAT 4-D"AIL 7=RETURN,8=BACKWARD, ENTER=FORWARD T'lm- undetsi d does hereby =verify subject to the penalties of 18 14904 relatinu to unsworn falsifications to authorities, that she is LIM MOMROSSO (Name) Yi -E P_ SIDJEN_T QF- Ol' ,RATIO N-$-- 'i 1iNA`fIONAL PORTFOLIO INS., plaintiff ('T'itle) (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## ??l Q t?f• C , SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-04245 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS CURTIS WILMA L R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT CURTIS WILMA L but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT , CURTIS WILMA L 33 S PENN ST, APT 1 SHIPPENSBURG, PA 17257 PER NEIGHBOR, CURTIS MOVED OUT OVER A YEAR AGO. NOT FOUND , as to Sheriff's Costs: Docketing Service Affidavit gig Surcharge pICB Not Found So answer 18.00 21.00 .00 R. Thomas ine 10.00 Sheriff of Cumberland County 5.00 54.00 WELTMAN WEINBERG & REIS 08/13/2008 Sworn and Subscribed to before me this day of A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. WILMA L CURTIS Defendant No. 08-4245 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. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6433044 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No. 08-4245 CIVIL TERM WILMA L CURTIS Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. W r brodt, Esquire PA 1. D. #42 4 WELTMA , W INBERG & REIS CO., L.P.A. 2718 Kop ers uilding 436 Sev th enue Pittsbur h, A 15219 (412) 4 4 955 WWR #6433044 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. WILMA L CURTIS Defendant No. 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#6433044 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No. WILMA L CURTIS 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 33 S PENN ST APT 1 SHIPPENSBURG,PA 17257. 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, WILMA L CURTIS, 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, WILMA L CURTIS, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, WILMA L CURTIS, in the amount of $1,430.00 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, WILMA L CURTIS, in the amount of $1,430.00 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. W rodt, P.A.I.D.# 4 524 Weltman, einb g & Reis Co.,L.P.A. 436 Sev th A enue, Suite 1400 Pittsbur ,P 5219 (412)44-79? Fax: 4 2-3,3'8-7130 3044 106/13/08 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: CURTIS, WILMA L F/C: D P/T: I A/C: 9334266 DSC CODE: 01 TO: CURTIS, WILMA L ADMISSION: 03/14/06 DISCHARGE: 03/16/06 33 S PENN ST APT 1 SHIPPENSBURG PA 17257 INS CD: 105/POS AETNA-QPOS GROUP 811306011000 POL ID: W14335229 A M O U N T F 1,300.00 1,609.92 71.03 473.13 292.65 1,297.66 843.57 1,575.72 1,726.19 4,320.00- 4,869.87- ---------------------------------------- TOTAL 0.00 SELnuir: 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 PA.C.S.14904 relating to unsworn falsifications to authorities, that she is LM IM()NTEROSSO ME pR F IDEI?tT OF PRO A TTAX o f UMENA T0 t.Pb IE9 IO INC ., plaintiff ('Title) (company) herein, that she is duly authorized to make this Verification, and that the facts set forth in the fbregoia Complaint in Civil Action are true and correct to the best of her knowledge, information and belief, WWR# d D O ? t7 ? 'L1 ^ti? Co SHERIFF'S RETURN - REGULAR CASE NO: 2008-04245 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS CURTIS WILMA L ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CURTIS WILMA L the DEFENDANT , at 1526:00 HOURS, on the 30th day of January , 2009 at 976 RITNER HIGHWAY SHIPPENSBURG, PA 17257 by handing to LINDA STULL, ROOMMATE 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 Affidavit Surcharge Sworn and Subscibed to before me this of So Answers: 18.00 18.00 .00 10.00 R. Thomas Kline .00 46.00 02/02/2009 WELTMAN WEIN13ERG REIS BY ' day Deputy Sheriff A.D. _ .cs ? !"a?` , . r, -? ? ? C'; ? ?. f + ` FTi '= [? :? f ? ?s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. No.08-4245 CIVIL TERM PRAECIPE FOR ENTRY OF JUDGMENT BY CONSENT WILMA L CURTIS Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I.D. 490963 Weltman,Weinberg & Reis CO., L.P.A. 1400 Kopper Building 436 Seventh Avenue Pittsburgh, PA 15219 WWR#6433044 $1,430.00 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No. 08-4245 CIVIL TERM WILMA L CURTIS Defendant PRAECIPE FOR JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment against Defendant, WILMA L CURTIS , in the amount of $1,430.00 plus costs, based upon the consent of the parties. CONSENTED TO: WELTMAN, WEINBERG & REIS CO., L.P.A., By: Attorney for Plaintiff WILMA L CURTIS, By: =W Lom , Lwyt? Defendant WWR#6433044 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No. 08-4245 CIVIL TERM WILMA L CURTIS 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, WILMA L CURTIS , above-named, in the amount of $1,430.00 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 $1,430.00 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, WILMA L CURTIS , in the amount of $1,430.00 plus continuing interest thereon at the rate of 6% per annum from date of judgment and costs. 3. 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 3/20/09; (b) $100.00 due on the every two weeks 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. The first payment due under this agreement is to be received at the offices of Weltman, Weinberg & Reis, Co., L.P.A., 436 Seventh Avenue, Suite 1400, Pittsburgh, PA 15219. All future payments are to be mailed to the offices of Weltman, Weinberg & Reis, Co., 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 _?L?day of 4r?1 , 20 pet WELTMAN, WEINBERG & REIS CO., L.P.A. By: Matthew D. Urban, Esquire PA I.D. #90963 Weltman,Weinberg & Reis CO., L.P.A. 1400 Kopper Building 436 Seventh Avenue Pittsburgh, PA 15219 WWR No. 6433044 By: dW.A", LAA82L, Defendant, WILMA L CURTIS ? ? ? ? ? -?, L -? ? --? 4 _ ? _ ?? ?-- -?-.rtz V c.s`? ? C_3 'T3 -} ) -, ,?.? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff VS. Civil Action No. 08-4245 CIVIL TERM WILMA L CURTIS 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 02,41" 2j? ;,009 (xx) Assumpsit Judgment in the amount of $1,430.00 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 WILMA L CURTIS 976 RITNER HWY SHIPPENSBURG,PA 17257 By;H0N PR O T (OR PUTY) 71 0' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. WILMA L CURTIS Defendant(s) No. 08-4245 CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT 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) 434-7999 WWR#6433044 TSW IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No. 08-4245 CIVIL TERM WILMA L CURTIS 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. W brodt, Esquire PA I.D. # 24 WELTM WEINBERG & REIS CO., L.P.A. 1400 Ko pe s Building 436 Se nt Avenue Pittsb g PA 15219 (412) 43 -7999 WWR #6433044 Sworn to and subscribed before me this f0? day of July, 09 OT Y PUBLLI MAaroe gel.. Wayne A. Joao N )rwr, City of PittsL'urgtt Asir .,c ;. toy Cc rn.rnission e OF FU?1 r _. ?i7i r r ?;? r r??)4d 2009 jui 23 ; t I °