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Home My WebLink About08-4329IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. DANIEL L LANG Defendant No. - y3 2 y' &J 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#06431671 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. Q 1- 7 3 )-7 c ; j, DANIEL L LANG 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 Plaintiff is a corporation with offices at 7465 N.W. 49TH ST, LAUDERHILLE, FL 33319- 0000. 2. Defendant is an adult individual residing at 1154 NEWVILLE ROAD, 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, DANIEL L LANG, 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, DANIEL L LANG, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, DANIEL L LANG, in the amount of $1,319.47 as of MAY 23, 2008. 8. Plaintiff claims interest at the legal rate of six (6%) percent per annum from MAY 23, 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, DANIEL L LANG, in the amount of $1,319.47 with continuing interest thereon at the rate of 6% per annum from MAY 23, 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. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#:06431671 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: LANG, DANIEL L F/C: B P/T: 0 A/C: 7501239 DSC CODE: 01 TO: LANG, DANIEL L ADMISSION: 06/15/05 DISCHARGE: 06/15/05 1154 NEWVILLE ROAD CARLISLE PA 17013 INS CD: 200/BC5 BLUE CROSS 361 COMP GROUP 005064290000 POL ID: YWC800127 D E PARTMIANT AMOUNT 5,010.86 1,309.94 389.35 237.72 981.79 822.69 3,713.14- 5,039.21- ----------------------------------------------------------------------------- TOTAL 0.00 SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY= CMD:I=DAR,2=PAT 4=DETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD EXF;... The undersigned does hereby -verify subject to the penalties of 18 PA.C.S.14904 relating to unsworn falsifications to authorities, that she is LIMA UQha OSSO (Nwne) YNE MMENT OF OP RA` HOESof INT RNA`TIONAL POMOL INC., plaintiff (Title) (Cony) herein, that she is duly authorized to make this Verification, and that the facts sat forth in the foregoing Complaint in Civil Action are true and correct to the best of her knowledge, information and belief. Wt C) Q p r TT 4 -- N 4-pi C g 1 SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-04329 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS LANG DANIEL 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 LANG DANIEL L but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , the within named DEFENDANT LANG DANIEL L 1154 NEWVILLE ROAD NOT FOUND , as to CARLISLE, PA 17013 DEFENDANT IS IN THE NAVY, STATIONED IN HAWAII. Sheriff's Costs: Docketing Service Not Found Surcharge i1O9/", Q,- ? So answers 18.00 /'rte 5.00 5.00 R. Thomas Kline 10.00 Sheriff of Cumberland County .00 38.00 WELTMAN WEINBERG REIS 08/01/2008 Sworn and Subscribed to before me this day of A. D. r? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO, INC. Plaintiff vs. No. 08-4329-CIVIL PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE DANIEL L LANG Defendant 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#06431671 t --. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO, INC. Plaintiff vs. Civil Action No. 08-4329-CIVIL DANIEL L LANG Defendant PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Settle, Discontinue and End the above-captioned matter upon the records of the Court without prejudice to refile and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: JAII Attorney for Plaintiff 2718 Koppers Build' g. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06431671 SWORN TO AND SUBSCRIBED before me this day o 12008 ARY PUB I COMMONWEALTH OF PENNSYLVANIA Notarial Seal Heidi J. Kelly, Notary Public City Of Pittsburgh, Allegheny County My Commission Expires Nov. 4, 2009 Member, Pennsylvania Association of Notaries rv va -4.T 517 cry