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HomeMy WebLinkAbout08-4248 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. JASON M HERSHEY Defendant No. 4 y- qa (1 p &c`7 t -77,, 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#6432950 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No. JASON M HERSHEY 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 9 PARTRIDGE CIRCLE 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, JASON M HERSHEY , 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, JASON M HERSHEY , agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, JASON M HERSHEY , in the amount of $1,844.60 as of JUNE 24 2008. 8. Plaintiff claims interest at the legal rate of six (61/o) percent per annum from JUNE 24 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, JASON M HERSHEY, in the amount of $1,844.60 with continuing interest thereon at the rate of 6% per annum from JUNE 24 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. J ames C. brodt, .A.I.D. 42 4 Weltm Wei berg & Reis Co.,L.P.A. 436S enth Avenue, Suite 1400 Pittsb gh, A 15219 (412 34 955 Fax/ 4 338-7130 6432950 06/12/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES CARLISLE REGIONAL MEDICAL CTR F06 COID: 858 -' '361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717)1960-1680 -------------------------------------- _ ____ PATIENT: HERSHEY, JASON M F/C: F P/T: E A/C: 9297993 DSC CODE: 01 TO: HERSHEY, JASON M ADMISSION: 11/29/04 DISCHARGE: 11/29/04 9 PARTRIDGE CIRCLE CARLISLE PA 17013 INS cn: 200/KCE BLUE CROSS 361 KCE GROUP 140648 POL ID: YWH207660 A M O U N T 103.69 104.32 1,636.59 1,844.60- -------------------------------- SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * 0.00 * CMD:1=DAR,2=PAT 4=DETAIL TO/MDCY= 7=RETURN,8=BACKWARD, ENTER=FORWARD BIT" wwwm? woo-ow fihe undersigned does :hereby verify subject to the penalties of 18 .PA.C.& 14904 to unsworn falsifications to authorities, that she is LINA MON'f .RQ-Q!QQ ame CId u ANT t?? R A n of (Nr ) r^T ?^ 1% T014 INIE ? ., 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 am true and correct to the best of her knowledge, information and belief. WWR# ;z , . co •? L 11 c- 3T Ell- 17 B SHERIFF'S RETURN - REGULAR CASE NO: 2008-04248 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC CIS HERSHEY JASON M 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 HERSHEY JASON M the DEFENDANT at 1507:00 HOURS, on the 21st day of July 2008 at 9 PARTRIDGE CIRCLE CARLISLE, PA 17013 WILLIAM HERSHEY, FATHER by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the saline 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 11/.2310$ 1-' l Sworn and Subscibed to By: before me this day Deputy Sheriff of A.D. e IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO, INC Plaintiff VS. JASON M HERSHEY Defendant No. 08-4248 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE and END 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#06432950 _. i IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO, INC Plaintiff VS. Civil Action No. 08-4248 CIVIL TERM JASON M HERSHEY Defendant PRAECIPE TO SETTLE DISCONTINUE and END TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue and End the above captioned matter upon the records of the Court and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: l- William T. Molczan, Esquire PA I.D. 447437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06432950 Sworn to and subscribed Before me the of SENT, 2008 (7( TARY PUBLI COMMONWEALTH OF PENNSYLVANIA Notarial Sea! Heidi J. Kelly, Notary Public City Of Pittsburgh, Allegheny County My Commission Expires Nov. 4, 2009 Member, Pennsylvania Association of Notaries -t -V Ol _ V) rri r ? i r