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Home My WebLink About08-4324t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. TAMMY S JONES Defendant No. G56- y3atj 41/ COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: 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#6431637 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. TAMMY S JONES 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) 249-31661 COMPLAINT 1. Plaintiff is a corporation with offices at 7465 N.W. 49TH ST, LAUDERHILLE, FL 33319- 0000. 2. Defendant is an adult individual residing at 519 N WEST STREET CARLISLE,PA 17013 COUNT I - ACCOUNT NO. 8587435999 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, TAMMY S JONES, 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, TAMMY S JONES, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, TAMMY S JONES, in the amount of $437.63 as of MAY 30 2008. Plaintiff claims interest at the legal rate of six (6%) percent per annum from MAY 30 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, TAMMY S JONES, in the amount of $437.63 with continuing interest thereon at the rate of 6% per annum from MAY 30 2008 and costs. COUNT II - ACCOUNT NO. 8587478012 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, TAMMY S JONES, received and accepted the aforementioned medical services which were provided by Plaintiff's assignor 13. The prices charged by Plaintiff's assignor were the prices that Defendant, TAMMY S JONES, agreed to pay. 14. Plaintiff avers that there is a balance due and owing from Defendant, TAMMY S JONES, in the amount of $143.45 as of MAY 30 2008. 15. Plaintiff claims interest at the legal rate of six (6%) percent per annum from MAY 30 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, TAMMY S JONES, in the amount of $143.45 with continuing interest thereon at the rate of 6% per annum from MAY 30 2008 and costs. COUNT III - ACCOUNT NO. 8589306432 17. At the specific instance and request of Defendant, CARLISLE REGIONAL MEDICAL CENTER, provided certain medical services to Defendant. 18. This obligation was subsequently assigned to Plaintiff for value. 19. Defendant, TAMMY S JONES, received and accepted the aforementioned medical services which were provided by Plaintiff's assignor 20. The prices charged by Plaintiff s assignor were the prices that Defendant, TAMMY S JONES, agreed to pay. 21. Plaintiff avers that there is a balance due and owing from Defendant, TAMMY S JONES, in the amount of $673.45 as of MAY 30 2008. 22. Plaintiff claims interest at the legal rate of six (6%) percent per annum from MAY 30 2008. 23. 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, TAMMY S JONES , in the amount of $673.45 with continuing interest thereon at the rate of 6% per annum from MAY 30 2008 and costs. COUNT IV- ACCOUNT NO. 8587368324 24. At the specific instance and request of Defendant, CARLISLE REGIONAL MEDICAL CENTER, provided certain medical services to Defendant. 25. This obligation was subsequently assigned to Plaintiff for value. 26. Defendant, TAMMY S JONES, received and accepted the aforementioned medical services which were provided by Plaintiff s assignor 27. The prices charged by Plaintiff s assignor were the prices that Defendant, TAMMY S JONES, agreed to pay. 28. Plaintiff avers that there is a balance due and owing from Defendant, TAMMY S JONES, in the amount of $117.25 as of MAY 30 2008. 29. Plaintiff claims interest at the legal rate of six (6%) percent per annum from MAY 30 2008. 30. 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, TAMMY S JONES , in the amount of $117.25 with continuing interest thereon at the rate of 6% per annum from MAY 30 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. 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#:6431637 05/09/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 05/08/08 361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 ---- ------- ------------------------------------------------------- PATIENT: JONES, TAMMY S F/C: D P/T: 0 A/C: 7435999 DSC CODE: 01 TO: JONES, TAMMY S ADMISSION: 10/27/04 DISCHARGE: 10/27/04 519 N WEST STREET CARLISLE PA 17013 INS CD: 743/MAM PRIME SOURCE MAMCO GROUP 50503930 POL ID: 199484253 D E P A R T M E N T A M O U N T 673.27 673.27- ----------------------------------------------------------------------------- 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 05/09/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COLD: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 05/08/08 361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 ---- ------- -------------------------------------------------------- PATIENT: JONES, TAMMY S F/C: D P/T: 0 A/C: 7478012 DSC CODE: 01 TO: JONES, TAMMY S ADMISSION: 03/18/05 DISCHARGE: 03/18/05 519 N WEST STREET CARLISLE PA 17013 INS CD: 743/MAM PRIME SOURCE MAMCO GROUP 50503930 POL ID: 199484253 D E P A R T M E N T A M O U N T 111)r- T 7%n 374.54 100.00- 274.54- ----------------------------------------------------------------------------- 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 05/09/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 05/08/08 361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 ---- ------- ------------------------------------------------- PATIENT: JONES, TAMMY S F/C: D P/T: I A/C: 9306432 DSC CODE: 01 TO: JONES, TAMMY S ADMISSION: 03/18/05 DISCHARGE: 03/25/05 519 N WEST STREET CARLISLE PA 17013 INS CD: 743/MAM PRIME SOURCE MAMCO GROUP 50503930 POL ID: 199484253 -- ?••?**?+ AMOUNT 4,550.00 12,916.90 1,418.20 2,564.87 1,353.28 9,308.13 1,746.63 292.65 2,239.12 1,338.69 167.93 140.00 CONTINUED... SE DATE/MDCY= * TO/MDCY= * CM 7=RETURN,8=BACKWARD, ENTER=FORWARD EXHIBIT 05/09/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 CARLISLE REGIONAL MED CTR AS OF 08/16/07 361 ALEXANDER SPR ING RD CARLISLE PA 17015 PHONE (717) 960-1680 ---------- ------- ---- ------- --------- PATIENT: JONES, TAMMY --------- S F/C: D P/T: 0 A/C: 7368324 DSC CODE: 01 TO: JONES, TAMMY S ADMISSI ON: 03/06/04 DISCHARGE: 03/06/04 519 N WEST STREET INS CD: 7.43/MAM PRIME CARLISLE SOURCE MAMCO PA 17013 GROUP 50503930 POL ID: 199484253 - - ----- AMOUNT 241.93 40.00- 201.93- ----------------------------------------------------------------- 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 undersiped does hereby verify subject to the penalties of 28 PA.C.S.14904 relating to unsworn falsifications to authorities, that she is LIMA MONIMS O (Nam) VISE p II?EN C? {?P 96UMS of INI-ERNATIC)NAL P®RTPbLI02&., 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 # I i?? d N SHERIFF'S RETURN - REGULAR CASE NO: 2008-04324 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS JONES TAMMY S TIMOTHY REITZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE JONES TAMMY S was served upon the DEFENDANT , at 0020:47 HOURS, on the 23rd day of July 2008 at 519 N WEST STREET CARLISLE, PA 17013 TAMMY S JONES DEFENDANT by handing to 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 18.00 Service 5.00 Affidavit .00 Surcharge 10.00 00 33.00 Sworn and Subscibed to before me this day of , So Answers: R. 'Thomas Kline 07/24/2008 WELTMAN WEINBERG & REIS By: DDepu?ff S eriff A.D. (David 1D. Bueff prothonotary 2jrkS. Sohonage, ESQ Solicitor Rsnee X Simpson 1" Deputy prothonotary 911 l' Irene E. 9lorrou) 2 d Deputy prothonotary Office of the Prothonotary Cumberland County, (Pennsylvania 6 e -- Z32Y CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 25TH DAY OF OCTOBER, 2011, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE -THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P 230.2 BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square • Suite 100 • Carlisle, PA 17013 • (717 240-6195 9 Fa.X (717 240-6573