Loading...
HomeMy WebLinkAbout08-4346is IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. l Plaintiff No. ?8 - jaw. VS. ERIC SMITH 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#06601877 11 A IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. ERIC SMITH Defendant Civil Action No. OF--Y3 3 if G c )v I 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 L Plaintiff is a corporation with offices at 7465 N.W. 49TH ST, LAUDERHILLE, FL 33319- 0000. 2. Defendant is an adult individual residing at 3512 COUNTRYSIDE LN, CAMP HILL,PA 17011. 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, ERIC SMITH, 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, ERIC SMITH, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, ERIC SMITH, in the amount of $3,399.64 as of MAY 23, 2008. A 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, 3,399.64, in the amount of $3,399.64 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. O ZAN, 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#:06601877 451131'-gig PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 05/12/08 36 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 ------------------------------------------------------------------ PATIEV': SMITH, ERIC F/C: D P/T: 0 A/C: 7629859 DSC CODE: 01 TO: SMI:'H, ERIC ADMISSION: 09/05/06 DISCHARGE: 09/05/06 1143 SJ'1MERWOOD DR HARRISBURG PA 17111 D E P A R T M E N T A M O U N T 3,399.64 3,399.64- ----------------------------------------------------------------- TOTAL 0.00 SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY= CMD:1=I)I?R,2=PAT 4=DETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD EXHIBa The undersigned does hereby verify subject to the penalties of 18 PAX.& 14904 relating to unsworn falsifications to authorities, that she is l?tA MCJ ROB ? (Name _VCE I' IDgt'?P?ttA?thN of IN'IFtNA'It?N t PCR ) Ip INC., plaintiff ('T'itle) (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, ignat? as ara 0 SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-04346 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS SMITH ERIC 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 SMITH ERIC but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , the within named DEFENDANT 3512 COUNTRYSIDE LN SMITH ERIC NOT FOUND , as to CAMP HILL, PA 17011 DEFENDANT LIVES AT 415 N DUKE STREET HUMMELSTOWN, PA 17036. Sheriff's Costs: So answers: Docketing 18.00 Service 15.00 Not found 4.,408 5.00 R. Thomas,/,Kline Surcharge 0 10.00 Sheriff of Cumberland County 48.00 WELTMAN WEINBERG REIS 08/05/2008 Sworn and Subscribed to before me this day of A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND, COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. ERIC SMITH Defendant No. 08-4346-CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE 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#6601877 r IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No. 08-4346-CIVIL TERM ERIC SMITH 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 2718 Ko 436 SFi Pittsb(412) SWORN TO AND SUBSCRIBED before me this day of t 09 NOT 'laintiff s Building Avenue A 15219 877 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Wendy L. Gault, Notary Public City Of Pittsburgh, Allegheny Caudy My Commission Expires July 1S, 2010 Member, Pennsylvania A3800e00n Of N01110es y ? ?-ma r? ] s .. J i?i?'y^ - ?:7 ?, ( ?% ?1 _ ... e._m .::t _' ....- ? ri_ J; ? ?? ? ?V,J '?