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HomeMy WebLinkAbout08-4340D IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. STEVEN E KUNTZ No. U k- 4 3 to C ".- -r-t" COMPLAINT IN CIVIL ACTION 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#6433035 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No. O 8 - q 314 0 Cx-T; ,_, STEVEN E KUNTZ 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 33 LONGSTREET DRIVE 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, STEVEN E KUNTZ, 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, STEVEN E KUNTZ, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, STEVEN E KUNTZ, in the amount of $1,259.02 as of MAY 29 2008. 8. Plaintiff claims interest at the legal rate of six (61/4) 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, STEVEN E KUNTZ, in the amount of $1,259.02 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.R.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#:6433035 05/13/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 05/12/08 351 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 -------- ------------------------------------------------------------------ PATIENT: KUNTZ, STEVEN E F/C: P P/T: E A/C: 9327142 DSC CODE: 01 TO: KUNTZ, STEVEN E ADMISSION: 12/10/05 DISCHARGE: 12/10/05 33 LONGSTREET DRIVE CARLISLE PA 17013 D E P A R T M E N T A M O U N T 38.22 390.66 830.14 1,259.02- -------------------------------------------------------------------- TOTAL 0.00 SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY= CMD:I=DA:R,2=PAT 4=DETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD EXHIBIT The undersigned does :hereby verify subject to the penalties of 18 14904 relating to unsworn falsifications to authorities, that she is ._LINA MQN`I`1rRCSSO (Name) VICE PRFSWMI M CPS AMOM of N?`ERNA 'IQNAL POKUOL.IO IN C., 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. W# -? t'? ^_' co { oa N3 v J a Q SHERIFF'S RETURN - REGULAR CASE NO: 2008-04340 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS KUNTZ STEVEN E TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon KUNTZ STEVEN E the DEFENDANT , at 0018:38 HOURS, on the 23rd day of July 2008 at 33 LONGSTREET DRIVE CARLISLE, PA 17013 by handing to STEVEN E KUNTZ 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: Docketing Service Affidavit Surcharge Sworn and Subscibed to before me this of So Answers: 18.00 5.00 .00 10.00 R. Thomas Kline .00 33.00 07/24/2008 WELTMAN WEINBERG & REIS L By: _ - day D puty he iff A.D. or -.1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO, INC Plaintiff vs. No. 08-4340-CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE and END STEVEN E KUNTZ 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 1.521.9 (412) 434-7955 WWR#06433035 r .., IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO, INC Plaintiff VS. Civil Action No. 08-4340-CIVIL TERM STEVEN E KUNTZ Defendant PRAECIPE TO SETTLE DISCONTINUE and END TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue and End the above captioned matter upon the records of the Court and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: 0-"zz- William T. Molc , Esqu' PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06433035 Sworn to and subscribed Before me the 1. of SEPT, 2008 1ARY PUBL C COMMONWEALTH OF PENNSYLVANIA Notarial Seal Heidi J. Keity, Notary Public City Of Pittsburgh, Allegheny County MY Commission Expires Nov. 4, 2009 Member, Pennsylvania Association of Notaries 0 ? d C: °-n 7, cam, A mi r k -n r n} ' u - E'?3 ? ? C 3