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Home My WebLink About08-5864IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. SHERYL M BAADE Defendant No. m -sg'(' ?t e4'j 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#06431660 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No. SHERYL M BAADE 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 2171 NW 139 TERR, PEMBROKE PINES, FL 33028. 2. Defendant is an adult individual residing at 431 FIRST ST, CARLISLE, PA 17013. COUNT I - ACCT NO. 7470915 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, SHERYL M BAADE, 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, SHERYL M BAADE, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, SHERYL M BAADE, in the amount of $855.90 as of SEPTEMBER 19, 2008. Plaintiff claims interest at the legal rate of six (6%) percent per annum from SEPTEMBER 19, 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, SHERYL M BAADE, in the amount of $855.90 as to Count I, with continuing interest thereon at the rate of 6% per annum from SEPTEMBER 19, 2008 and costs. COUNT II: ACCOUNT NO -9292353 10. At the specific instance and request of Defendant, CARLISLE REGIONAL MEDICAL CENTER provided certain medical services to Defendant. 11. This obligation was subsequently assigned to Plaintiff for value. 12. Defendant, SHERYL M BAADE, 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, SHERYL M BAADE, agreed to pay. 14. Plaintiff avers that there is a balance due and owing from Defendant, SHERYL M BAADE, in the amount of $400.00 as of SEPTEMBER 19, 2008. 15. Plaintiff claims interest at the legal rate of six (6%) percent per annum from SEPTEMBER 19, 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, SHERYL M BAADE, in the amount of $400.00 as to Count II, totaling $1255.90 for Counts I & II with continuing interest thereon at the rate of 6% per annum from SEPTEMBER 19.2008 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. MOLCZ^, 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#:06431660 0611310,8 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 06/12/08 351 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 ---- -------- ------------------------------------------------------------------ PATIENT: BAADE, SHERYL M F/C: B P/T: 0 A/C: 7470915 DSC CODE: 01 TO: BAADE, SHERYL M ADMISSION: 02/25/05 DISCHARGE: 02/25/05 431 FIRST ST CARLISLE PA 17013 INS CD: 200/BC3 BLUE CROSS 361 PPO GROUP NONE POL ID: SLT983963 D E P A R T M E N T A M O U N T 40.09 755.45 260.36 200.00- 855.90- ----------------------------------------------------------------------------- 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 1 06/13/08 PAGE 002 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 06/12/08 361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 ---- ------- ------------------------------------------------------------------ PATIENT: BAADE, SHERYL M F/C: B P/T: I A/C: 9292353 DSC CODE: 01 TO: BAADE, SHERYL M ADMISSION: 09/18/04 DISCHARGE: 09/20/04 431 FIRST ST CARLISLE PA 17013 INS CD: 200/BS1 PBSHM 378 PPO GROUP NONE POL ID: SLT196488 D E P A R T M E N T A M O U N T 133.33 34.36 2,720.38 11,775.00- 16,512.00- ----------------------------------------------------------------------------- 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 unworn 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# 0 ? ? C.. `rt - ? TI 4 ft1I._ - t _. ? F v ? 1 J) ^f}yy ? SHERIFF'S RETURN - REGULAR CASE NO: 2008-05864 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS BAADE SHERYL M MICHELLE GUTSHALL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BAADE SHERYL M the DEFENDANT at 431 FIRST ST at 0011:02 HOURS, on the 16th day of October , 2008 CARLISLE, PA 17013 SHERYL BAADE DEFENDANT by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge "p4C,Q /" 18.00 5.00 .00 10.00 .00 33.00 Sworn and Subscibed to before me this day So Answers: "1 . R. Thomas Kline 10/17/2008 WELTMAN WEINBERG & REIS By: Deputy Sheriff of A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. SHERYL M BAADE Defendant No.08-5864 CIVIL PRAECIPE FOR ENTRY OF JUDGMENT BY CONSENT 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 WWR906431660 Judgment $1255.90 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No. 08-5864 CIVIL SHERYL M BAADE Defendant PRAECIPE FOR JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment against Defendant, SHERYL M BAADE, in the amount of $1255.90 plus costs, based upon the consent of the parties. CONSENTED TO: WELTMAN, WEINBERG & REIS CO., L.P.A., By: Attorney or Plaintif SHERYL M BAADE, By: - -- Defendant WWR#06431660 Judgment $1255.90 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No. 08-5864 CIVIL SHERYL M BAADE Defendant STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment in favor of Plaintiff and against the Defendant, SHERYL M BAADE, above-named, in the amount of $1255.90 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment by Consent, as follows: 1. Defendant admits indebtedness to Plaintiff in the amount of $1255.90 with continuing interest thereon at a rate of 6% per annum plus costs from date of judgment. 2. To secure the repayment of said indebtedness, Defendant agrees that Judgment by Consent will be entered in favor of the Plaintiff and against the Defendant, SHERYL M BAADE, in the amount of $1255.90 plus continuing interest thereon at the rate of 6% per annum from date of judgment and costs. 3. Plaintiff agrees not to execute on its Judgment so long as Defendant causes to be delivered to Plaintiff the following payments in full by 12:00 NOON on the following dates: (a) $75.00 due by NOVEMBER 5TH, 2008; (b) $75.00 due on the 5TH day of each consecutive month thereafter until the Judgment amount plus accrued interest and costs are paid in full. 4. All payments are to be made payable to the order of "INTERNATIONAL PORTFOLIO INC." All payments due under this agreement are to be received at the offices of Weltman, Weinberg & Reis, Co., L.P.A., P.O. BOX 5430, Cleveland, OH 44101-0430. 6. In the event of default, each payment received shall be first attributed to costs, interest and then to principal. 7. Time is of the essence of this agreement and should the Defendant fail to have in the hands of Plaintiff or Plaintiffs counsel any payment in full within five (5) calendar days of the stated due date, then Plaintiff shall be immediately free to issue Execution as well as pursue all other remedies, in law or in equity, to collect the full balance of the Judgment entered hereunder plus appropriate additional interest and costs. No act or omission of the Plaintiff, nor of anyone alleged to be acting on its behalf, shall constitute a waiver, estoppel, or any other excuse for non-performance of any duty undertaken by the Defendant in this Stipulation which the parties agree is final and complete. 9. Intending to be legally bound, the parties set their hands and seals this _day of , 20 WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Mol 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 W WR No. 06431660 By: efenda M BAADE o * '? S Cl C C=np C= gn Fri 00 t3? T 4s. .%`y? Y ? C 7 C7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. SHERYL M BAADE Defendant Civil Action No. 08-5864 CIVIL NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Jud ment was entered against you on I lie (xx) Assumpsit Judgment in the amount of $1255.90 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession ( ) Default ( ) Verdict ( ) Arbitration ( ) Award (XX) By Consent Prothonotary S14ERYL M BAADE 431 FIRST ST CARLISLE, PA 17013 By: 5 Lici t? . PR ONOTARY (OR DEPU 0 /Gg