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Home My WebLink About08-4344 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. No. &a - -yy G, Cat 1,? COMPLAINT IN CIVIL ACTION MELISSA A FREEMAN 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#6433021 7 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. d r` 113 y MELISSA A FREEMAN 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 1125 EASY ROAD 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, MELISSA A FREEMAN, 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, MELISSA A FREEMAN, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, MELISSA A FREEMAN, in the amount of $1,865.19 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, MELISSA A FREEMAN, in the amount of $1,865.19 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. WILLIAM T. MO 4CZAN, 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#:6433021 05/13/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 05/12/08 361_,ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 - - - i - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - PATIENT: FREEMAN, MELISSA A F/C: P P/T: E A/C: 9321509 DSC CODE: 01 TO: FREEMAN, MELISSA A ADMISSION: 09/24/05 DISCHARGE: 09/24/05 1125 EASY ROAD CARLISLE PA 17013 D E P A R T M E N T A M O U N T T,TI-AnT,97\(-V 124 . 73 71.03 125.41 121.58 1,422.44 1,865.19- ----------------------------------------------------------------------------- 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 I The undersigned does herebyverii?r subject to the penalties of 18 PA.C,S.14 1 relating to unsworn falsifications to authorities, that she is LINA MONTEROSS (Name) YL E PRFSHM OF OPEItAT?of INTERNATI NAIL 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 correct to the best of her knowledM information and belief. WR ? na Q ) a G m -n _ 0 SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-04344 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS FREEMAN MELISSA A 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 FREEMAN MELISSA A but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT FREEMAN MELISSA A 1125 EASY ROAD CARLISLE, PA 17015 PER POST OFFICE, DEFENDANT LIVES IN PORTAGE, PA. Sheriff's Costs: Docketing Service Not Found Surcharge R/ U Alp P- ? So answers: .; 18.00 6.00 5.00 m R. Thomas Kline 10.00 Sheriff of Cumberland County .00 39.00 WELTMAN WEINBERG REIS 08/22/2008 Sworn and Subscribed to before me this day of A. D. -1 4, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff No. 08-4344-CIVIL TERM vs. PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE MELISSA A FREEMAN Defendant 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 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 WWR#6433021 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No. 08-4344-CIVIL TERM MELISSA A FREEMAN 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 PI 2718 Koppers 436 Seventh Pittsburgh, A (412) 434-7 5 SWORN TO AN?BSCRIBED e -this , -) day ARY Nolaft Seol Heil J. Kelly, Notary Public CNY Of Pllletwrgh, AAepllerly cou,ty W ConxNae m EVWM Nov. 4, 2009 rber, PW tVW-2F4 Alfa- Itton o/ Net. ing e 19 1 ??..? ? y - CRS q ^J T ^w. ? ?`v. tt^^?. 7 ?`_ \..? ti 4 ' ( 4 `a.. m