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Home My WebLink About08-5865IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. KENNETH L KEITER JR Defendant No. 0? - 4%u^•( 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#06433048 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. KENNETH L KEITER JR 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 23 SHERYL DRIVE, NEWVILLE, PA 17241. COUNT I - ACCT NO. 9336254 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, KENNETH L KEITER JR, 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, KENNETH L KEITER JR, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, KENNETH L KEITER JR, in the amount of $833.09 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, KENNETH L KEITER JR, in the amount of $833.09 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 -9298739 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, KENNETH L KEITER JR, 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, KENNETH L KEITER JR, agreed to pay. 14. Plaintiff avers that there is a balance due and owing from Defendant, KENNETH L KEITER JR, in the amount of $664.40 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, KENNETH L KEITER JR, in the amount of $664.40 as to Count II with continuing interest thereon at the rate of 6% per annum from SEPTEMBER 19.2008 and costs. COUNT III: ACCOUNT NO -92985424 17. At the specific instance and request of Defendant, CARLISLE REGIONAL MEDICAL CENTER provided certain medical services to Defendant. 18. This obligation was subsequently assigned to Plaintiff for value. 19. Defendant, KENNETH L KEITER JR, received and accepted the aforementioned medical services which were provided by Plaintiff's assignor 20. The prices charged by Plaintiff's assignor were the prices that Defendant, KENNETH L KEITER JR, agreed to pay. 21. Plaintiff avers that there is a balance due and owing from Defendant, KENNETH L KEITER JR, in the amount of $483.04 as of SEPTEMBER 19, 2008. 22. Plaintiff claims interest at the legal rate of six (6%) percent per annum from SEPTEMBER 19, 2008. 23. 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, KENNETH L KEITER JR, in the amount of $483.04 as to Count III, totaling $1980.53 for Counts I, II, & III 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. W ' 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 WWR#:06433048 0'6/13/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 AS OF 06/12/08 CARLISLE REGIONAL MEDICAL CTR 361 ALEXANDER SPRING RD CARLISLE PA 17015---PHONE-(717)-960_1680-- ------------------ ------------------------------ PATIENT: HINTON, KAYLA H F/C: P P/T: E A/C: 9336254 DSC CODE: 01 TO: KEITER, KENNETH L JR ADMISSION: 04/07/06 DISCHARGE: 04/07/06 23 SHERYL DRIVE NEWVILLE D E P A R T M E N T A M O U N T 259.54 573.55 833.09- --------------------------------------- TOTAL 0.00 TO/MDCY= SELECT: REV= * DEPT= * CHGCD= * DARETURNY8=BACKWARD, ENTER=FORWARD CMD:I=DAR,2=PAT 4=DETAIL EXHIBIT DA17 COID: 858 06/13/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES AS OF 06/12/08 CARLISLE REGIONAL MEDICAL CTR 361 ALEXANDER SPRING RD CARLISLE PA 17015---PHONE-(717-960_1680-- ----------------------------------------- PATIENT: HINTON, KAYLA H F/C: P P/T: E A/C: 9298739 DSC CODE: 01 TO: KEITER, KENNETH L JR ADMISSION: 12/09/04 DISCHARGE: 12/09/04 23 SHERYL DRIVE NEWVILLE PA 17241 DEPARTMENT AMOUNT 16.88 647.52 664.40- ------------- ---------TOTAL 0.00 * * = SELECT: REV= * DEPT= * CHGCD= DATE/MDCY= TO/MDCY * CMD:I=DAR,2=PAT 4=DETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD 06/13/`08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 AS OF 06/12/08 CARLISLE REGIONAL MEDICAL CTRPA-17015 PHONE (717) 960-1680 361 ALEXANDER SPRING RD CARLISLE ---------- _----------- ___ _ ----------------------------- PATIENT: HINTON, KAYLA H ADMISSIONP/12/06/04 9DISCHARDEC 102/06/04 T0: KEITER, KENNETH L JR 23 SHERYL DRIVE NEWVILLE PA 1724.1 DEPARTMENT AMOUNT 7.60 475.44 483.04- ------------- -------------------- TOTAL 0.00 - * * SELECT: REV= * DEPT= * CHGCD= DATE/MDCY= TO/MDCY= 7=RETURN,8=BACKWARD, ENTER=FORWARD CMD:1=DAR,2=PAT 4=DETAIL 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) WWR# D V V SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-05865 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS KEITER KENNETH L JR 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 KEITER KENNETH L JR but was unable to locate Him in his bailiwick COMPLAINT & NOTICE, , He therefore returns the NOT FOUND , as to the within named DEFENDANT , KEITER KENNETH L JR 23 SHERYL DRIVE NEWVILLE, PA 17241 CURRENT RESIDENT HAS LIVED HERE FOR THREE YEARS; POST OFFICE WILL NO LONGER HAVE FORWARDING INFORMATION ON FILE. Sheriff's Costs: So answers: Docketing 18.00 --?- Service 13.00 - f Affidavit .00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County Not Found 5.00 46.00 WELTMAN WEINBERG & REIS 10/14/2008 Sworn and Subscribed to before me this day of , A. D. .e IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. KENNETH L KEITER JR Defendant No. 08-5865 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#6433048 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No. 08-5865 CIVIL KENNETH L KEITER JR Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: I.4 - f J WILLIAM T MOLCZAN,ErUIRE PA I. D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400, Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #6433048 -44 Sheriffs Office of Cumberland County R Thomas Kline a ttxr at'Cumbcr? o- Edward L Schorpp Sheriff Solicitor 4:. .:Y. Ronny R Anderson f Jody S Smith Chief Deputy OR CE -,,F r"= $"?RiFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/30/2009 04:25 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on March 30, 2009 at 1625 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Kenneth L. Keiter, Jr., by making known unto Connie Keiter, mother of defendant at 30 Carlisle Road Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handii to her personally the said true and correct copy of the same. SHERIFF COST: $37.90 SO ANSWERS March 31, 2009 2008-5865 INTERNATIONAL PORTFOLIO INC. VS KENNETH L. KEITER, JR. R THOMAS KLINE, SHERIFF By- De puty Sheriff OF ovW 2003 APR --2 PN 3: 29 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. KENNETH L KEITER JR Defendant No. 08-5865 CIVIL PRAECIPE FOR DEFAULT JUDGMENT 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#6433048 Judgment Amount 2,103.91 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. KENNETH L KEITER JR Defendant TO THE PROTHONOTARY: Civil Action No. 08-5865 CIVIL PRAECIPE FOR DEFAULT JUDGMENT COUNT 1 Kindly enter Judgment against the Defendant, KENNETH L KEITER JR, above named, in the default of an Answer, in the amount of $884.99 computed as follows: Amount claimed in Complaint $833.09 Interest from SEPTEMBER 19, 2008 TO OCTOBER 2, 2009 at the legal interest rate of 6.00% per annum $51.90 TOTAL $884.99 COUNT II Kindly enter Judgment against the Defendant, KENNETH L KEITER JR, above named, in the default of an Answer, in the amount of $705.79 computed as follows: Amount claimed in Complaint $664.40 Interest from SEPTEMBER 19, 2008 TO OCTOBER 2, 2009 at the legal interest rate of 6.00% per annum $41.39 TOTAL $705.79 COUNT III Kindly enter Judgment against the Defendant, KENNETH L KEITER JR, above named, in the default of an Answer, in the amount of $513.13 computed as follows: Amount claimed in Complaint $483.04 Interest from SEPTEMBER 19, 2008 TO OCTOBER 2, 2009 at the legal interest rate of 6.00% per annum $30.09 TOTAL TOTAL COUNTS I, II, & III $513.13 $2,103.91 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Molczan, Esre PA. I. D.#47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6433048 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 30 CARLISLE RD, NEWVILLE, PA 17241 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff M KENNETH L KEITER JR AKA KENNETH L KEITER Defendant TO: KENNETH L KEITER JR 30 CARLISLE RD NEWVILLE, PA 17241 51-'] Date of Notice: Case No. 08-5866 CIVIL IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA. 17013 (717) 249-3166 WELT AN, WEINBERG & REIS CO., L.P.A. By: Matthew Urban P.A.I.D.# 90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 6433048 H PIT SMI Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Case no: 08-5865 CIVIL Plaintiff vs. KENNETH L KEITER JR Defendant NON-MILITARY AFFIDAVIT The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. § 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, KENNETH L KEITER JR is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the Defendant, KENNETH L KEITER JR, is not in the military service. Further Affiant sayeth naught. AFFIANT SWORN TO AW SUBSCRIBED in my presence this 40 day Of OCTOBEFY 2009- NOT, Q2!N9 LfW 2F PENNSYLVANIA Not" Seal WOO L. Gout Notary Public City of Pittsburgh, A kgheny County My Cwffds ion 00res July 15, 2010 ber hnnsyC ania Assoclation of Notaries Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 JUL-20-2009 11:01:30 * Last Name First/Middle Begin Date Active Duty Status Service/Agency KEITER KENNETH L Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. y6y- lot 404,4??_ Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: http://www.defenselink.mil/faq/is/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: CBAAISXKP https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 7/20/2009 OF THE f=` 2609 OCT 16 P1i 2: 15 ,r $14 . oo P b A`rTq 4.30W 47 R?` a,3o2ta5 IJAee I?lo?•d IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No. 08-5865 CIVIL KENNETH L KEITER JR Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Gamishee You are hereby notified that the following Order or Jud ment was entered against you on Lo /& o _ (xx) Assumpsit Judgment in the amount of $884.99 plus costs as to Count I. (xx) Assumpsit Judgment in the amount of $705.79 plus costs as to Count II. (xx) Assumpsit Judgment in the amount of $513.13 plus costs as to Count III. ( ) 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 (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: A, , kvxq PRO ONOTARY (OR DEPUTY) p KENNETH L KEITER JR 30 CARLISLE RD NEWVILLE, PA 17241