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HomeMy WebLinkAbout08-4343 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff No. 0,9- q3 y3 l'W J z`"" vs. JUSTINA F ANUSZEWSKI 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#06433079 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No. 0 8 - `f 3t-3 ? e,- JUSTINA F ANUSZEWSKI 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 196 ACRE 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, JUSTINA F ANUSZEWSKI, 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, JUSTINA F ANUSZEWSKI, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, JUSTINA F ANUSZEWSKI, in the amount of $5,177.44 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, JUSTINA F ANUSZEWSKI, in the amount of $5,177.44 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. OL AN, 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#:06433079 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: ANUSZEWSKI, JUSTINA F F/C: P P/T: E A/C: 9350100 DSC CODE: 07 TO: ANUSZEWSKI, JUSTINA F ADMISSION: 09/24/06 DISCHARGE: 09/24/06 196 ACRE DRIVE CARLISLE PA 17013 D E P A R T M E N T A M O U N T 9.49 71.03 142.29 2,096.66 486.61 140.00 2,431.36 200.00- 5,177.44- ----------------------------------------------------------------------------- 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 rilfy subject to the penalties of 18 PA.C.S. 14 relating to unsworn falsifications to authorities, that she is LINA MQM&QSSO - (Name) VICE PRESMENT OE OPERATIONS of IMIERNSAITH NAL, 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 connect to the best of her knowledge, information and belief. WWR# x i = iZ - ?,s 09 N a'r't SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-04343 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS ANUSZEWSKI JUSTINA F R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT ANUSZEWSKI JUSTINA F but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT ANUSZEWSKI JUSTINA F 196 ACRE DRIVE CARLISLE, PA 17013 HOUSE IS VACANT - PER POST OFFICE, MOVED TO 1360 BICYCLE ROAD STOYSTOWN. PA 15563. Sheriff's Costs: So answers- Docketing ? 18.00 ?- Service ?pg 5.00 Affidavit SI .00 R. Tho. s Kline Surcharge 10.00 Sheriff of Cumberland County Not Found 5.00 38.00 WELTMAN WEINBERG & REIS 08/11/2008 Sworn and Subscribed to before me this day of A. D. k - _ _ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. JUSTINA F ANUSZEWSKI Defendant No. 08-4343-CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE 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#06433079 *s . - ! IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No. 08-4343-CIVIL TERM JUSTINA F ANUSZEWSKI Defendant PRAECIPE TO SETTLE DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Settle, Discontinue and End the above-captioned matter upon the records of the Court without prejudice to refile and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: Attorney for Plain?ff 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06433079 SWORN TO AND SUBSCRIBED before me this _ day of AN 2008 VOTARY PUBLIC COV No aE ?l Sea, puChc Wendy L. Gau c, iticta?' CRy Of pdsbusgn, r a teeny GO 2Q10 sion Duty MY commis Fxrnie5 Yiocr 05hoi.aries Member. Pe^^=??" . P^ °t ?_.J ?.y? 1 ? y -, i ?