The URL can be used to link to this page

Home My WebLink About08-43301 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. No. COMPLAINT IN CIVIL ACTION ROBIN L MELHORN 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#06434159 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff Q- 1133 d 40J, ( ft?. VS. Civil Action No. D ROBIN L MELHORN 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 7465 N.W. 49TH ST, LAUDERHILLE, FL 33319- 0000 2. Defendant is an adult individual residing at 636 N HANOVER STREET, 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, ROBIN L MELHORN, received and accepted the aforementioned medical services which were provided by Plaintiffs assignor 6. The prices charged by Plaintiff's assignor were the prices that Defendant, ROBIN L MELHORN, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, ROBIN L MELHORN, in the amount of $1,301.45 as of MAY 23, 2008. v 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, ROBIN L MELHORN, in the amount of $1,301.45 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. MOLC AN, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR4:06434159 DA17 COLD: 858 05/09/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES AS OF 05/08/08 CARLISLE REGIONAL MEDICAL CTR PA 17015 PHONE (717) 960-1680 4-361 ALEXANDER SPRING RD CARLISLE _ _ ------------------------------------ PATIENT: MELHORN, ROBIN L F/C: P P/T: E A/C: 9313482 DSC CODE: 01 TO: MELHORN, ROBIN L ADMISSION: 06/17/05 DISCHARGE: 06/17/05 636 N HANOVER STREET CARLISLE PA 17013 n W. V A R T M L N T A M O U N T 44.59 292.65 390.66 573.55 1,301.45- ---------------------------------------- TOTAL 0.00 * = SELECT: REV= * DEPT= * CHGCD= DATE/MDCY= TO/MDCY * 7=RETURN,8-BACKWARD, ENTER=FORWARD CMD:I=DAR,2=PAT 4=DETAIL - exr?rerr The undersigned does hereby verily subject to the penalties of 18 PA.C.S.14904 relating to unsworn falsifications to authorities, that she is ?.- (Name) vtr pRF ttm N' CF E-RAU-01of ..T ?`:A?'YC)I?AIP4I?jEQLIp IN-Q plaintiff (company) (Title) herein, that she is club 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 li?,? 1 IV Q?l 'v V C7 G? rn?^ r r i?? CC) f SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-04330 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS MELHORN ROBIN 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 MELHORN ROBIN L but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT MELHORN ROBIN L 636 N HANOVER STREET CARLISLE, PA 17013 NOT FOUND , as to PER POST OFFICE, MOVED AND LEFT NO FORWARDING ADDRESS. Sheriff's Costs: So answe - Y=-' ) Docketing 18.00 ? l Service ? pg 10.00 Affidavit 0 .00 R. Tho as Kline l d Surcharge 0 10.00 Sheriff County an of Cumber Not Found 5.00 43.00 WELTMAN WEINBERG & REIS 08/11/2008 Sworn and Subscribed to before me this day of A. D. 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. ROBIN L MELHORN Defendant No. 08-4330-CIVIL PRAECIPE TO REINSTATE COMPLAINT 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#6434159 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No. 08-4330-CIVIL ROBIN L MELHORN Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: WILLIAM T MOL N, QUIRE PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #6434159 4 d ? [,Z7 4F • -py R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Sheriffs Office of Cumberland County ?4?ti"tn o{ ?*?c?rrbrr?,try? OFF; :E F THE SrERiFF 03/30/2009 SHERIFF'S RETURN OF SERVICE Sergeant 04:00 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on March 30, 2009 at 1600 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Robin L. Melhorn, by making known unto herself personally, defendant at 70 E. Main Street Plainfield, Cumberland County, Pennsylvania 17081 its contents and at the same time handing to h, personally the said true and correct copy of the same. SHERIFF COST: $32.50 March 31, 2009 ; so ,PZN:001W R THOMAS KLINE, SHERIFF 2008-4330 INTERNATIONAL PORTFOLIO INC. VS ROBIN L. MELHORN By Deputy Sheriff Edward L Schorpp Solicitor Jody S Smith ft rICE OF T)f MARY 2009 APP --2 PM 3: 30 t?TY PEN IN11"'YL AIN,lea IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. ROBIN L MELHORN Defendant No.: 08-4330-CIVIL PRAECIPE FOR DEFAULT 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 Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6434159 Judgment Amount $ 1,379.11 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. s IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No.: 084330-CIVIL ROBIN L MELHORN Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, ROBIN L MELHORN above named, in the default of an Answer, in the amount of $1,379.11 computed as follows: Amount claimed in Complaint $ 1,301.45 Interest from 05/23/08 to 05/21/09 at the legal interest rate of 6.00% per annum $77.66 TOTAL $1,379.11 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By: JAMES C. WA RODT, ES ' DIRE PA I.D.#42524 Weltman, W nbe & Reis Co., L.P.A. 1400 Koppe Bld 436 Seven Ave e Pittsbur P 15219 (412) 43 -7 5 WWR#6434159 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7 h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 70 E MAIN ST PLAINFIELD,PA 17081 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff VS. ROBIN L MELHORN Defendant Case no:: 08-4330-CIVIL NON-MILITARY AFFIDAVIT The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. § 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, ROBIN L MELHORN is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the Defendant, ROBIN L MELHORN is not in the military service. Further Affiant sayeth naught. SW O AND SUB my presence this day of COMMONWEALTH OF PENNSYLVANIA Notarial Seal NOTAXY PUBLIC Wendy L. Gault, Notary Public Cky of Plbburgh, Allegheny County My Corrmission Expires July 15, 2010 Member, Pennsylvania Association of Notaries This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. ROBIN L MELHORN Defendant TO: ROBIN L MELHORN 70 E MAIN ST POB 73 PLAINFIELD, PA 17081 Date of Notice: Case No. 08-4330-CIVIL IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS-FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA. 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. By: ig Matthew Urban P.A.I.D.# 90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 6434159 H PIT SMI Reques* for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 MAY-19-2009 07:46:44 `11", Last Name First/Middle Begin Date Active Duty Status Service/Agency MELHORN ROBIN Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. 14. Ohl rev J10114., A?M_ Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: http://www.defenselink.mil/faq/pis/PC09SLDR.htm1 WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: EVISCHRRR https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 5/19/2009 PLED- -? -! -'ICE OF THE 2009 JUG 15 PH 1: 2 7 fNW fd,- #/?w W/? ?VA#. aal?7al A?/7? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff VS. Civil Action No.: 08-4330-CIVIL ROBIN L MELHORN 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 11<_ (xx) Assumpsit Judgment in the amount of $1,379.11 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 (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: PR HONOT EP Y) 17 ROBIN L MELHORN 70 E MAIN ST PLAINFIELD,PA 17081 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7 h Avenue, Pittsburgh, PA 15219 1-888-434-0085