HomeMy WebLinkAbout08-4333
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff No. e g7 - 1-133-3 &J
VS.
COMPLAINT IN CIVIL ACTION
JARED C KECK
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#06432944
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff
VS. Civil Action No. 6t-L/333 f 1v,
JARED C KECK
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
r
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 311 FAIRVIEW ST, CARLISLE,PA 17015.
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, JARED C KECK, 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, JARED C
KECK, agreed to pay.
7. Plaintiff avers that there is a balance due and owing from Defendant, JARED C KECK, in
the amount of $5,999.47 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, JARED C KECK,
in the amount of $5,999.47 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. 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
W WR#:06432944
05/09/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858
CARLISLE REGIONAL MED CTR AS OF 08/16/07
361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680
---- ------- ------------------------------------------------------------------
PATIENT: KECK, JARED C F/C: P P/T: I A/C: 9293517 DSC CODE: 07
TO: KECK, JARED C ADMISSION: 10/03/04 DISCHARGE: 10/04/04
32 WEST HIGH ST APT 303 CARLISLE PA 17013
D E P A R T M E N T A M O U N T
650.00
83.39
997.60
184.50
483.91
901.06
390.66
2,308.35
5,999.47-
-----------------------------------------------------------------------------
TOTAL 0.00
SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY=
CMD:I=DAR,2=PAT 4=DETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD
EXHIbi 1
v
'The undersigned does hereby -verify subject to the penalties of Ig 14904
relating to unsworn falsifications to authorities, that she is _LINA Mt)N' MS.SO
(N)
VICE PRESH)EN1OP OPERATIONS of ERNA` 19NAL. PORTFOLIO 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 true and correct to the best of her knowledge,
information and belief.
WWR
N
O
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-04333 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
INTERNATIONAL PORTFOLIO INC
VS
KECK JARED C
RONALD HOOVER Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
KECK JARED C
the
DEFENDANT , at 0010:13 HOURS, on the 28th day of July , 2008
at 230 A YORK ROAD
CARLISLE, PA 17015 by handing to
JARED C KECK DEFENDANT
a true and attested copy of COMPLAINT & NOTICE together with
and at the same 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
F'?ilb8., 33.00 07/29/2008
WELTMAN WEINBERG & REIS
Sworn and Subscibed to By: jll?e
before me this day Deputy S eriff
of A.D.
FILED-OFFICE
OF THE PROTH®NQTARY
DEC 22 PM 12: 20
C LAMS VAN A OUNTY
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff
No. 08-4333-CIVIL
vs. PRAECIPE FOR WRIT OF EXECUTION
AND ENTER IT IN THE JUDGMENT INDEX
(BANK ATTACHMENT ONLY)
JARED C KECK
a3 G R y0jzk U l: Lisle t ???
Defendant i
PSECU, ^? 'fin
! C¢,?e?ar`>- /,L?bN t _ S a? fir f ?! ?d
Garnishee,
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 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#6432944
$?2q ge> -L_)94
eK=d ioZZr3
t?-4- .2.L8937
7
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff
vs. Civil Action No. 08-4333-CIVIL
JARED C KECK
Defendant
PSECU,
Garnishee
PRAECIPE TO INDEX WRIT OF EXECUTION
AND ENTER IT IN THE JUDGMENT INDEX
TO THE PROTHONOTARY:
Kindly issue a Writ of Execution in the above matter...
1. directed to the Sheriff of DAUPHIN County:
2. against JARED C KECK, Defendant
3. against PSECU, Garnishee
4. and enter this writ in the judgment index
(a) against JARED C KECK, defendant, and
(b) against PSECU, as garnishee ,
as a lis pendens against real property of the defendant in the name of garnishee as follows:
Any and/or all personal property belonging to the defendant(s) in possession of the garnishee(s).
5. Judgment Amount
Less payments of/Adjustments made
Interest
Costs
SUBTOTAL:
Costs (to be added by Prothonotary):
33•?
ga.ao
It{ •Od
?,sa
$ 2,378.11 " eZIDI.Q?
$ 276.14
$ 26.09
$ 2142.06
WELTJVJAAY, d INBERG & REIS CO., L.P.A.
By: ` -
Matthew D. Urban, Esquire
PA I.D. #90963
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
4'-2.06
.1 . s'o ??--?
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-4333 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF DAUPHIN COUNTY:
To satisfy the debt, interest and costs due INTERNATIONAL PORTFOLIO, INC., Plaintiff (s)
From JARED C. KECK, 230 A YORK RD., CARLISLE, PA 17013
(l) You are directed to levy upon the property of the defendant (s)and to sell
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of PSECU, 1 CREDIT UNION PL, HARRISBURG, PA 17110 -ANY AND/OR ALL PERSONAL
PROPERTY BELONGING TO THE DEFENDANT(S) IN POSSESSION OF THE GARNISHEE(S)
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $2101.97 L. L. $.50
Interest $26.09
Arty's Comm % Due Prothy $2.00
Atty Paid $166.00 Other Costs:
Plaintiff Paid
Date: DECEMBER 22, 2011
(Seal)
REQUESTING PARTY:
7a2a'4i? . IVILI)
David D. Buell, Prothonotary
Deputy
Name MATTHEW D. URBAN, ESQ.
Address: WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 KOPPERS BUILDING
436 SEVENTH AVENUE
PITTSBURGH, PA 15219
Attorney for: PLAINTIFF
Telephone: 412-434-7955
Supreme Court ID No. 90963
C'
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL A
CIVIL DIVISION f Q
fit') G7 rt
INTERNATIONAL PORTFOLIO INC. yp r?
O?61a Ov5ao-ti/T
Plaintiff No. 08-4333-CIVILL
A.«S[.V&Lj '_F6
vs. INTERROGATORIES W ATTACHMENT
PSECU
JARED C KECK
Defendant'
and y
PSECU'
Garnishee FILED ON BEHALF OF:
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
Matthew D. Urban, Esquire
PA I.D. 490963
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#6432944
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff
vs. CI-VII Action No.: 08-4333-CIVIL
JARED C KECK t
Defendant -
and
PSECU ?p
Garnishee
TO: PSECU Suggested Reference No.: XXX-XX-6960
I CREDIT UNION PL
HARRISBURG, PA 17110
RE: JARED C KECK
230 A YORK ROAD
CARLISLE, PA 17013
IMPORTANT NOTICES TO GARNISHEE!
A. You are required to file answers to the following interrogatories within twenty (20) days after
service upon you. Failure to do so may result in Judgment against you.
B. Herein, the word "defendant" means any one or more of the defendants against whom the writ of
Execution is issued.
C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to
attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes
into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the
resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's account, either at the
time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited
and withdrawn during the intervening period.
INTERROGATORIES IN ATTACHMENT
I. At the time you were served or at any subsequent time did you owe the defendant any money or
were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money
or were liable to him for any reason (including funds on deposit for checking or savings accounts and certificates of
deposit)?
Yes. See attached.
I a. If the answer to Interrogatory I is in the affirmative, state the following: the amount
of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof;
the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written
instruments and the present location of each of such instruments; the amount or amounts that defendant claims or
claimed that you owe or owed to him; and the nature and amount of each of such liabilities.
See attached.
2. At the time you were served or at any subsequent time was there in your possession, custody or
control of yourself and one or more other persons any property of any nature owned solely or in part by the
defendant.
No.
3. At the time you were served or at any subsequent time did you hold legal title to any property of
any nature owned solely or part by the defendant or in which defendant held or claimed any interest?
No.
4. At the time you were served or at any subsequent time did you hold as fiduciary any property in
which the defendant had an interest?
No.
5. At any time before or after you were served, did the defendant transfer or deliver any property to
you or to any person or place pursuant to your directions or cor,s?,nt and if so what was the coosideration thereof?
No.
6. At any time after you were served did you pay, transfer, or deliver any money or property to the
defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant
against you?
No.
7. if you are a bank or other financial institution, at the time you were served or at any subsequent
time did the defendant have funds on deposit in an account in which funds are deposited electronically on a
recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or
attachment under Pennsylvania or federal law? If so, Identify each account and state the reason for the exemption,
the amount being withheld under each exemption and the amount of funds in each account, and the entity
electronically depositing those funds on a recurring basis.
No.
8. If you are a bank or other financial institution, at the time you were served or at any subsequent
time did the defendant have funds on deposit in an account in which the funds on deposit, not including any
otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If
so, identify each account.
No.
9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these
interrogatories on this institution.
1/23/2012
10. If the answer to Interrogatory 1 is in the affirmative, state the date the written instrument, checking
or savings account, certificate of deposit, or other funds were frozen, restricted, or otherwise put on hold b_v this
institution.
1/23/2012
11. If the response to Interrogatory 7 is in the affirmative, are other funds comingled in the account
which are not deposited electronically on a recurring basis and which are identified as being funds that upon deposit
are exempt from execution, levy or attachment under Pennsylvania or federal law?
N/A
12. If the response to Interrogatory 1 l is in the affirmative, state the amount of non-exempt funds on
deposit in the account.
N/A
WELTMAN, WEINBERG & REIS CO., L.P.A.
By: _
Matthew D. Urban, Esquire
PA I.D. #90963
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#6432944
INTERNATIONAL PORTFOLIO INC.,
Plaintiff
VS.
JARED C. KECK,
Defendant
and
PA STATE EMPLOYEES CREDIT UNION,
Garnishee
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 08-4333-CIVIL
No. 2012-CV-520-NT
CIVIL ACTION -LAW
ANSWERS TO INTERROGATORIES
1. Account #0170586960 Jared C. Keck - Primary
Deborah D. Lerew - Joint Owner
SI Regular Shares $ 29.39*
S4 Checking $ 592.89
$ - 300.00**
*$5.00 Membership Fee held in Regular Shares.
**$300.00 Exempt from attachment under 42 Pa.C.S. 8123.
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating
to unsworn falsifications to authorities, that he/she is Kathleen Weinstein
(Name)
Judqment Collector of PSECU , garnishee herein,
(Title) (Company)
that he/she is July authorized to make this verification, and that the facts set forth in the foregoing
Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief.
A??) " '
(SIGNATURE)
-I' UE: (Pv ATTESTED
014-1,11, r.
SHERIFF 4 t. JPHIN CO., PA
£ :ZI did OZ Nvc 1101
WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: James C Warmbrodt, Esquire
I.D. No.42524
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
Phone: 412.434.7955
Fax: 412.434.7959
File # 6432944
INTERNATIONAL PORTFOLIO INC
vs.
JARED C KECK
and
PSECU
Garnishee(s)
F-ROTHONOTA 't
Attorney for Piaintiff%2 FEB 10 AM 11 : 33
uU PENNSYLVANIA TY
Cumberland County
Court of Common Pleas
NO. 08-4333-CIVIL
PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION
TO THE PROTHONOTARY:
Kindly marked the above matter discontinued and ended as to Garnishee(s), PSECU, only.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By
Sworn to and subscribed
Beforatne thel_ day-4 February, 2012
N(YTARY
COMMONWEALTH OF PENNSYLVANIA
Notarial seal
f Wayne A. Japes, Notary Public
I City of Pittsburgh, Allegheny County
My Commission Expires June 29, 2014
Momber. Pennsvlvanla Association of Notaries
James--` Warmbrodt, Esquire
Atto v for Plaintiff
et k 1039(ola) I
103518(0(
Vu ;.l'7A4^/