The URL can be used to link to this page

Home My WebLink About08-4335IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. DENNIS D NESS Defendant No. - ?f33s C 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#6431636 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. a.e - y 3 3 57 G f ?J DENNIS D NESS 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 7 SHERWOOD DR ENOLA,PA 17025. COUNT I - ACCOUNT NO. 8587435948 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, DENNIS D NESS, 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, DENNIS D NESS, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, DENNIS D NESS, in the amount of $28.14 as of MAY 29 2008. 8. Plaintiff claims interest at the legal rate of six (6%) percent per annum from MAY 29 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, DENNIS D NESS, in the amount of $28.14 with continuing interest thereon at the rate of 6% per annum from MAY 29 2008 and costs. COUNT II - ACCOUNT NO. 8587436965 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, DENNIS D NESS, received and accepted the aforementioned medical services which were provided by Plaintiff s assignor 13. The prices charged by Plaintiffs assignor were the prices that Defendant, DENNIS D NESS, agreed to pay. 14. Plaintiff avers that there is a balance due and owing from Defendant, DENNIS D NESS, in the amount of $1,613.40 as of MAY 29 2008. 15. Plaintiff claims interest at the legal rate of six (6%) percent per annum from MAY 29 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, DENNIS D NESS, in the amount of $1,613.40 with continuing interest thereon at the rate of 6% per annum from MAY 29 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. A//--, - WILLIAM T. MOLCZAN6Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219(412) 434-7955 WWR#:6431636 05/09/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES 858 OF 08/16/07 CARLISLE REGIONAL 361 ALEXANDER SPRING RD C MED CTR ARLISLE PA 17015 ------------- AS PHONE (717) 960-1680 ---- ------- ------------------ PATIENT: NESS, DENNIS D ---------- B . P/ 7435948 1CODE: 01 0/28/04 TO: NESS, DENNIS D ADMISS 10/28/04 ON 7 SHERWOOD DR ENOLA INS CD: 200/FEP BLUE CROSS 361 FEDERAL PA 17025 GROUP 105 PL ID: R21715248 D E P A R T N Z N T AMOUNT 57.94 390.66 229.80- 218.80- ---------------------------- TOTAL 0.00 SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY= CMD:1=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: NESS, DENNIS D F/C: B P/T: 0 A/C: 7436965 DSC CODE: 01 TO: NESS, DENNIS D ADMISSION: 11/02/04 DISCHARGE: 11/03/04 7 SHERWOOD DR ENOLA PA 17025 INS CD: 200/FEP BLUE CROSS 361 FEDERAL GROUP 105 POL ID: R21715248 D E P A R T M E N T A M O U N T 17, 371.05 1,418.20 758.40 370.92 2,190.14 2,421.67 1,963.50 167.93 140.00 34.36 1,224.43 CONTINUED... < ;D= * DATE/MDCY= * TO/MDCY= 7=RETURN,8=BACKWARD, ENTER=FORWARD EXHIBIT The undersigned does hereby verify subject to the penalties of 18 14904 to unsworn falsifications to authorities, that she is LJNA Iyfin1V ERQSSO (Name) VICE PRESMENUEDD X1111-NS of INUR??`l'I?NAL LIO INC., 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. WWR -i7 SHERIFF'S RETURN - REGULAR CASE NO: 2008-04335 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS NESS DENNIS D MICHELLE GUTSHALL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon NESS DENNIS D the DEFENDANT at 2011:00 HOURS, on the 22nd day of July , 2008 at 7 SHERWOOD DR ENOLA, PA 17025 ROXANNE NESS, SPOUSE 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 Service Affidavit Surcharge '71a 18.00 14.00 .00 10.00 / 00 V 42.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 07/23/2008 WELTMAN WEINBERG REIS By: Deputy Sheriff of A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. No.0$-4335 CIVIL PRAECIPE FOR ENTRY OF JUDGMENT BY CONSENT DENNIS D NESS Defendant 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#6431639 1,613.40 • IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff Vs. Civil Action No. 08-4335 CIVIL DENNIS D NESS Defendant PRAECIPE FOR JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment against Defendant, DENNIS D NESS, in the amount of $1,613.40 plus costs, based upon the consent of the parties. CONSENTED TO: WELTMAN, WEINBERG & REIS CO., L.P.A., By: Attorn for Plaintiff DENNIS D NESS, By: Defendant WWR#6431639 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No. 084335 CIVIL DENNIS D NESS Defendant STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment in favor of Plaintiff and against the Defendant, DENNIS D NESS, above-named, in the amount of $1,613.40 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment by Consent, as follows: Defendant admits indebtedness to Plaintiff in the amount of $1,613.40 with continuing interest thereon at a rate of 6% per annum plus costs from date of judgment. 2. To secure the repayment of said indebtedness, Defendant agrees that Judgment by Consent will be entered in favor of the Plaintiff and against the Defendant, DENNIS D NESS, in the amount of $1,613.40 plus continuing interest thereon at the rate of 6% per annum from date of judgment and costs. 3. Plaintiff agrees not to execute on its Judgment so long as Defendant causes to be delivered to Plaintiff the following payments in full by 12:00 NOON on the following dates: (a) $200.00 due by 2049 (b) $200.00 due on the 15TH day of each consecutive month thereafter until the Judgment amount plus accrued interest and costs are paid in full. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. DENNIS D NESS Defendant No. 08-4335 -CIVIL PRAECIPE FOR SATISFACTION OF 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 Kopper Building 436 Seventh Avenue Pittsburgh, PA 15219 WWR#6431636 f IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No. 08-4335 -CIVIL DENNIS D NESS Defendant PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. Sworn to and su?asc bed before me this _ 4 of April, 09 U COMMO ALTH OF PENNSYLVANIA ?tarial S f ,i Kel y, Not3 y public tspu?,, ANegheny My m, EV'? Nov. 42009 iWembersvivanla Association of Notaries WELTMAN, WEINBERG & REIS CO., L.P.A. By: ,-- JAMES C A BRODT, Esquire PA I . D. #4 24 Weltman, ei erg & Reis CO., L.P.A. 1400 Ko per uilding 436 Se Avenue Pittsb , PA 15219 WWR #6431636 2009 MAY --1 P 1: 4 3 g8. od?d. A?? c+c? y ??- ?sw7