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#
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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
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