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Home My WebLink About08-4332IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff No. - G/ 3,? vs. JEREMY J LACOMBE Defendant 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#06433040 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. 6 r' q3 3.2 c I* I JEREMY J LACOMBE 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 4170 ENOLA ROAD, NEWVILLE,PA 17241. 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, JEREMY J LACOMBE, 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, JEREMY J LACOMBE, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, JEREMY J LACOMBE, in the amount of $1,383.15 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, JEREMY J LACOMBE, in the amount of $1,383.15 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. ku!/ WILLIAM T. MOLD N, 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#:06433040 05/08/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 • CARLISLE REGIONAL MEDICAL CTR AS OF 05/07/08 361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 ---- ------- ------------------------------------------------------------------ PATIENT: LACOMBE, JEREMY J F/C: F P/T: E A/C: 9328943 DSC CODE: 01 TO: LACOMBE, JEREMY J ADMISSION: 01/05/06 DISCHARGE: 01/05/06 4170 ENOLA ROAD NEWVILLE PA 17241 D E P A R T M E N T A M O U N T TT T T••? ^111.23 45.35 292.65 933.92 1,383.15- ----------------------------------------------------------------------------- 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 undersigned does hereby verify subject to the penalties of Ig 14904 relating to unsworn falsifications to authorities, that she is L,INA MON` EROSSO (Name) - VtCE PRESIDE i O -OPE-RAnONS of INTER NATIONAI PORT` OLIO INC., 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 are try and correct to the best of her knowledge, information and belief. WVR# 7 C- 4:. {fitir n ("' -TI r7i Ry AKA, C!? - 73 .r C 7 3 ?- It1 ell, A\ - Fa??rl r, n?.. SHERIFF'S RETURN - REGULAR CASE NO: 2008-04332 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS LACOMBE JEREMY J JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE LACOMBE JEREMY J DEFENDANT the DEFENDANT , at 0013:36 HOURS, on the 2nd day of August , 2008 at 408 CROSSROADS SCHOOL ROAD NEWVILLE, PA 17241 JEREMY LACOMBE was served upon by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Additional Comments ADDRESS PROVIDED OF 4170 ENOLA ROAD NEWVILLE IS VACANT. Sheriff's Costs: Docketing Service Affidavit Surcharge ,11600.0 6?, Sworn and Subscibed to before me this of So Answers: 18.00 9.00 .00 10.00 R. Thomas Kline .00 37.00 08/04/2008 WELTMAN WEINBERG & REIS By. day p y Sheriff A.D. it IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. JEREMY J LACOMBE Defendant No. 08-4332 CIVIL PRAECIPE FOR DEFAULT JUDGMENT 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#06433040 Judgment Amount $ 1412.48 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN TI4E COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. JEREMY J LACOMBE Defendant TO THE PROTHONOTARY: Civil Action No. 08-4332 CIVIL PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, JEREMY J LACOMBE above named, in the default of an Answer, in the amount of $1412.48 computed as follows: Amount claimed in Complaint $1383.15 Interest from 05/23/08 to 09/29/08 at the legal interest rate of 6.00% per annum $29.33 TOTAL $1412.48 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: WAk2? -- William T. Molc , 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#06433040 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7"' Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 408 CROSSROADS SCHOOL ROAD, NEWVILLE, PA 17241 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. 08-4332 CIVIL JEREMY J LACOMBE 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 lo 107.M1 (xx) Assumpsit Judgment in the amount of $1412.48 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: - ?. F PRO ONOTAR TY) JEREMY J LACOMBE 408 CROSSROADS SCHOOL ROAD NEWVILLE, PA 17241 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7'h Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. JEREMY J LACOMBE Defendant Case no: 08-4332 CIVIL NON-MII,ITARY 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, JEREMY J LACOMBE 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, JEREMY J LACOMBE is not in the military service. Further Affiant sayeth naught. AFFIANT O SWORN TO AND SUBSCRIBED in my presence this36'1?' day of '? . N ARY PU IC V' 3vne A Jr N t vV Ci`, C7. 4'il sburcg i; .a t ?sntV fJPifluEt ri i v, _ ?s r e" 3!les 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. Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 SEP-29-2008 13:50:02 `<Last Name First/Middle Begin Date Active Duty Status Service/Agency LACOMBE 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. Aavt lot 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: Up://www.defenselink.mil/faq/pis/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 9/29/2008 Request for Military Status Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: BA UNWNBPR UB https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 9/29/2008 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO IN Plaintiff Case # ob-433'-? -Coiil. JEREMY J LACOMBE Defendant(s) IMPORTANT NOTICE TO: JEREMY J LACOMBE 408 CROSSROADS SCHOOL RD NEWVILLE,PA 17241 Date of Notice: o8 WWR#: 06433040 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 FOLLOWING 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 `.? `r C' ? -rt ? ?'} ? _ C ? c5l _ -?- r=. ? i:? N 4 1 `? 1:J!t tm? s .?? .i= °C WELTMAN, WEINBERG & REIS CO., L.P.A. BY: Sarah E. Ehasz, Esquire Attorney for Plaintiff(s) I.D. No.86469 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 6433040 INTERNATIONAL PORTFOLIO, INC. Cumberland County Court of Common Pleas vs. JEREMY J LACOMBE NO. 08-4332-CIVIL PRAECIPE FOR SATISFACTION OF JUDGMENT TO THE PROTHONOTARY: FILED-OFFICIE OF -1 HE PROTHONOTARY, 2011 JUL 18 AM 11: 15 CUMBERLAND COUNT`' PENNSYLVANIA Please kindly Satisfy the Judgment of the above-captioned matter upon the records of the Court and mark the cost paid. WELTMAN, WEINBEgREIS L.P.A. B y Sarah E. Ehasz, Esquire Attorney for Plaintiff Sworn to and subscribed Before me the !I T'' day of July, 2011 NOTARY PUBLIC COMMONWEALTH OF PENNSYLVANIA Notarial Sea' Public Sheila G. Bevan, Nota Yunty Ross Twp., Allegheny My Commission Expires Nov. N or NOTAPAE5 MEMBER PENNvLvANTA AS500 CK sa s z 97 1 14' -? 4 19,Z3