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Home My WebLink About08-5856IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. GARY R LUTZ Defendant No. 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#06433013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No. GARY R LUTL 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 1.7013 (717) 249-3166 COMPLAINT 1. Plaintiff is a corporation with offices at 2171 NW 139 TERR, PEMBROKE PINES, FL 33028 . 2. Defendant is an adult individual residing at 187 BIG SPRING TER, NEWVILLE, PA 17241. COUNT I - ACCT NO. 9319147 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, GARY R LUTZ, 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, GARY R LUTZ, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, GARY R LUTZ, in the amount of $1939.34 as of SEPTEMBER 18, 2008. 8. Plaintiff claims interest at the legal rate of six (6%) percent per annum from SEPTEMBER 28, 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, GARY R LUTZ, in the amount of $1939.34 as to Count I, with continuing interest thereon at the rate of 6% per annum from SEPTEMBER 18, 2008 and costs. COUNT II: ACCOUNT NO -9335280 10. At the specific instance and request of Defendant, CARLISLE REGIONAL MEDICAL CENTER provided certain medical services to Defendant. H. This obligation was subsequently assigned to Plaintiff for value. 12. Defendant, GARY R LUTZ, received and accepted the aforementioned medical services which were provided by Plaintiff s assignor 13. The prices charged by Plaintiff's assignor were the prices that Defendant, GARY R LUTZ, agreed to pay. 14. Plaintiff avers that there is a balance due and owing from Defendant, GARY R LUTZ, in the amount of $75.25 as of SEPTEMBER 18, 2008. 15. Plaintiff claims interest at the legal rate of six (6%0) percent per annum from SEPTEMBER 18, 2008. 16. 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, GARY R LUTZ, in the amount of $75.25 as to Count II, totaling $2014.59 for Counts I & II with continuing interest thereon at the rate of 6% per annum from SEPTEMBER 18, 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.'MOXZAN, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR#:06433013 06/12/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 06/11/08 361 ALEXANDER SPRING RD CARLISLE -------- --- PA 17015 PHONE (717) 960-1680 PATIENT: LUTZ, LAURIN M F/C: ---- - ----- C P/T: 0 A/C: -------- 9319147 DSC CODE: 01 TO: LUTZ, GARY R ADMISSION: 08/25/05 DISCHARGE: 08/25/05 200 W WEBSTER AVE ROSELLE PARK NJ 07204 INS CD: 950/001 DEFINITY HEALTH CLAIMS GROUP 102363 POL ID: 800476163 D E PAR_T_MENT AMOUNT 5,567.60 1,201.68 173.73 83.84 341.88 1,240.35 927.83 1,237.19 7,757.35- 3,016.75- --------------------------- --------------- TOTAL ---------------------- 0.00 SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY= CMD:I=DAR,2=PAT 4=DETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD EM19 1 06/12/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 361 CARLISLE ALEXANDER SPRI REGIONAL MEDICAL CTR NG RD CARLISLE AS OF 06/11/08 - PA 17015 -------------- PHONE (717) 960-1680 PATIENT: TO: LUTZ LUTZ, GARY R GARY R ----------------- - F/C: C P/T: E A/C: ____ -----------------_-- 9335280 DSC CODE: 01 , 187 BIG S PRING TERRACE ADMISSION: 03/26/06 NEWVILLE PA 17241 DISCHARGE: 03/26/06 INS CD: 3 47/UHC DEFINITY HEALTH CLAIMS GROUP 102363 POL ID: 800465738 D E P A R T M E N T A M O U N T 34.57 18.96 573.55 301.00- 326.08- ---------------------------------------- TOTAL 0.00 SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY= CMD:I=DAR,2=PAT 4=DETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsifications to authorities, that she is GAIL WOOD (Name) DIRECTOR of Customer Care of INTERNATIONAL 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 knowledge, information and belief. (Signature) W WR# NJ 7713 ig^ 1 SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-05856 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS LUTZ GARY R 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 LUTZ GARY R but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT 187 BIG SPRING TER NEWVILLE, PA 17241 LUTZ GARY R NOT FOUND , as to MOVED - NOT KNOWN AT ADDRESS PER POST OFFICE Sheriff's Costs: Docketing 18.00 Service 12.00 Affidavit .00 Surcharge 10.00 Not Found 5.00 "012J/0r 4;;,-,? 45.00 So answers- Thomas Kline R. Sheriff of Cumberland County WELTMAN WEINBERG & REIS 10/16/2008 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. GARY R LUTZ Defendant No. 08-5856 CIVIL PRAECIPE TO REINSTATE COMPLAINT 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#6433031 _, „? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. GARY R LUTZ Defendant Civil Action No. 08-5856 CIVIL PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: uo'-4 I WILLIAM T MOLCZAN,EYUIRE PA I. D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #6433031 f?`' ?/ xJ ? ???? ?-_. ..? ?= ? ? r ?' r ` ?' _-- .. c.? c3? >= ._... c?_ Sheriffs Office of Cumberland County R Thomas Kline o'11, at k? 41Anbcrt rr0 Lawara L ?)cnorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy rs - - Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/30/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant to wit: Gary R. Lutz, 216 E. Garfield Street, Shippensburg, Cumberland County, Pennsylvania, 17257, but was unable to locate him in his bailiwick he therefore returlS the within Complaint as not found as to the defendant, Occupant. Current resident advises the defendant longer resides at this address. Post Office advises forwarding address is: 4391 Young Road, Ramseur, NC 27316. SHERIFF COST: $51.00 April 06, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF Docket No. 2008-5856 International Portfolio v Gary r. Lutz OF THE P OII ?`TNDTARY 2009 APP -7 PH 3: 50 8 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. GARY R LUTZ Defendant No.: 08-5856 CIVIL 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 (412) 434-7955 WWR#6433013 r J I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No.: 08-5856 CIVIL GARY R LUTZ 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 1400 Kopp 436 Seven Pittsburg I (412) 43 7, SWORN TO AND SUBSCRIBED before me this day of a C40 _" r y NOTAY PUBLI COMMONWEALTH OF PENN&YLVANIA Notarial Seal Wayne A. Jones, Notary Public city of Pittsburgh, Allegheny CGUF* 0 My cornmissim Eepi4? "ember, PannsyINm"la Assam- Of "On intiff uilding venue 15219 5 3 Al FD-'r "I" '?E OF T i) G_ ^I?0'ARY 2009 OCT 13 PM 2: 12 cl 1 N"'y