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