The URL can be used to link to this page

Home My WebLink About08-42460 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. ANNE F MORRIS Defendant No. OF- q x4 (o " ? 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#6431673 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. 02- 4 a q u e..,J; Q Te.- ANNE F MORRIS 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 1144 PHEASANT DR N 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, ANNE F MORRIS, 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, ANNE F MORRIS, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, ANNE F MORRIS, in the amount of $ 5,063.51 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, ANNE F MORRIS, in the amount of $5,063.51 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. rodt, P.A.I.D 4252 Wel ,We' berg & Reis Co.,L.P.A. 436 ven Avenue, Suite 1400 Pitt ur , PA 15219 (41 )43 -7955 F 2-338-7130 WWR#:6431673 06/13/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COLD: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 06/12/08 361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 ----,------- ----------------------------------- PATIENT: MORRIS, ANNE F F/C: D P/T: 0 A/C: 7512805 DSC CODE: 01 TO: MORRIS, ANNE F ADMISSION: 07/14/05 DISCHARGE: 07/14/05 1144 PHEASANT DR N CARLISLE PA 17013 INS CD: 743/MAM PRIME SOURCE MAMCO GROUP 7466 POL ID: 208466539 -- A M O U N T 794.40 4,269.11 5,063.51- ------------------------------------------------------------ TOTAL 0.00 SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY= CMD:I=DAR,2=PAT 4=DETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD The undersigned does hereby veri?r subject to the penalties of 18 PA.C.S.14904 relating to unsworn falsifications to authorities, that she is LWA MIQN'I'RRCJSSQ (Narne) VICE pRFSIDE, MOf CJpE n-O- $ of IN RNA`fIONA.L OR'I OLIO 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 convet to the best of her knowledge, information and belief. WWR# CP N Y f? tY, ?; Cl1 ON X _ - I Y n3 i. 3 M v S SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-04246 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS MORRIS ANNE F 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 MORRIS ANNE F but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT , MORRIS ANNE F 1144 PHEASANT DR N NOT FOUND , as to CARLISLE, PA 17013 PER MOTHER. DEFENDANT LIVES AT 38 W SEYMOUR ST #1 GERMANTOWN, PA Sheriff's Costs: So answerrs,??- Docketing ? 18.00 Service 8 ?0 10.00 ` Not Found 8' 5.00 R. Thomas Kline Surcharge Ott 10.00 Sheriff of Cumberland County .00 43.00 WELTMAN WEINBERG REIS 08/05/2008 Sworn and Subscribed to before me this day of A.D. ' 11 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. No. 08-4246 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE ANNE F MORRIS Defendant(s) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA I.D. 442524 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR#6431673 TSW Pe -? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No. 08-4246 CIVIL TERM ANNE F MORRIS Defendant(s) PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF Cumberland COUNTY: SIR Kindly settle, discontinue and end without prejudice to refile the above-captioned matter upon the records of the Court and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. Wa brodt, Esquire PA 1. D. #425 4 WELTMAN EINBERG & REIS CO., L.P.A. 1400 Kopp rs uilding 436 Seven i venue Pittsburg , A 15219 (412) 43 - 955 SWORN TO AND SUBSCRIBED before me this 30 day of 2009 OTARY PUBLIC a`S;=/ai Seal Sneila G. e3evan, Notary Public City Of Pittsburgh, kegher.y Co,inty My Commissior. Expires Nov. 15, 2010 Member, Pennsylvania Association of Notaries TARY T THE 2009 NOY 20 Ply 3: 39