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Home My WebLink About08-5868IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. SAMIR A HALABI 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#06433077 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. SAMIR A HALABI 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 608 DEVONSHIRE DR, CARLISLE, PA 17013. COUNT I - ACCT NO. 9348146 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, SAMIR A HALABI, 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, SAMIR A HALABI, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, SAMIR A HALABI, in the amount of $1206.91 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, SAMIR A HALABI, in the amount of $1206.91 as to Count I, with continuing interest thereon at the rate of 6% per annum from SEPTEMBER 18, 2008 and costs. COUNT 11: ACCOUNT NO -9319865 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, SAMIR A HALABI, 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, SAMIR A HALABI, agreed to pay. 14. Plaintiff avers that there is a balance due and owing from Defendant, SAMIR A HALABI, in the amount of $1111.32 as of SEPTEMBER 18, 2008. 15, Plaintiff claims interest at the legal rate of six (6%) 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, SAMIR A HALABI, in the amount of $1111.32 as to Count II, totaling $2318.23 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. MOLC , 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#:06433077 06/13/08 PAGE 001 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: HALABI, SAMIR A F/C: P P/T: E A/C: 9348146 DSC CODE: 01 TO: HALABI, SAMIR A ADMISSION: 08/31/06 DISCHARGE: 08/31/06 608 DEVONSHIRE DRIVE CARLISLE PA 17013 D E P A R T M E N T A M O U N T 33.70 87.44 1,085.77 1,206.91- ----------------------------------------------------------------------------- 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 001 HEALTH MANAGEMENT ASSOCIATES DA17 COLD: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 06/12/08 3,c1 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 ----- -------- ------------------------------------------------------------------ PATIENq : HALABI, SAMANTHA M F/C: P P/T: E A/C: 9319865 DSC CODE: 01 TO: HA'=FBI, SAMIR A ADMISSION: 09/03/05 DISCHARGE: 09/03/05 608 DE'JONSHIRE DRIVE CARLISLE PA 17013 D E P A R T M E N T A M O U N T 31.85 505.92 573.55 1,111.32- ------------------------------------------------------------------------------ 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. ,4 J- (Signature) W WR4 Q ?J V k_Q o V TJ ? ? . "CJ t .sue SHERIFF'S RETURN - REGULAR CASE NO: 2008-05868 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS HALABI SAMIR A ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HALABI SAMIR A the DEFENDANT , at 0013:53 HOURS, on the 8th day of October , 2008 at 608 DEVONSHIRE DR CARLISLE, PA 17013 by handing to ANTONE HALABI ADULT IN CHARGE 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 1o 1/31t % - So Answers: 18.00 5.00 .00 10.00 R. Thomas Kline .00 33.00 10/09/2008 WELTMAN WEINBERG & REIS Sworn and Subscibed to before me this of By: day Deputy Sheriff A.D. INTERNATIONAL PORTFOLIO, INC. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008-5868 CIVIL ACTION SAMIR A. HALABI, Defendant PRAECIPE FOR ENTRY OF APPEARANCE To Curtis R. Long, Prothonotary: Please enter my appearance on behalf of the Defendant, SAMIR A. HALABI, in the above captioned case. Respectfully submitted, IRWIN & KNIGH By: 0'West Pomfret Street ` Carlisle, 'Pennsylvania 17013 (717) 249-2353 Attorney for Defendant Date: October 13, 2008 INTERNATIONAL PORTFOLIO, INC. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008-5868 CIVIL ACTION SAMIR A. HALABI, Defendant CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached Praecipe for Entry of Appearance was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: William T. Molczan, Esq. Weltman, Weinberg & Reis Co., LPA 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 IRWIN & M IGHT ?? F By: Marcus .M 'yMkight, III, Quire 60 West fret Street Cazlisle, A 17013 (717) 2 9-2353 Sunrem Court I.D. No. 25476 Date: October 12, 2008 C7 ''V as cw ma C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. SAMIR A HALABI Defendant(s) No. 08-5868-CIVIL PRAECIPE TO SETTLE, DISCONTINUE AND END WITH PREJUDICE TO REFILE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA I.D. 442524 WELTMAN, WEINBERG & REIS CO., L.P.A 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6433077 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No. 08-5868-CIVIL SAMIR A HALABI Defendant(s) PRAECIPE TO SETTLE DISCONTINUE AND END WITH PREJUDICE TO REFILE TO THE PROTHONOTARY OF COUNTY: Settle, Discontinue and End With Prejudice to Refile the above-captioned matter upon the records of the Court and mark the costs paid. Sworn to and subscrjb d Before me he u? Day of ?'!) NOTARY PUBLIC WELTMAN, WEINBERG & REIS CO., L.P.A. By James C. Wa brodt, PA I.D. #4 2 WELTM , EINB 1400 KO er Buildin 436 Sev nt Avenue Pittsbur , PA 15219 (412) 4-7955 WWR#6433077 & REIS CO., L.P.A COMMONWEALTH OF PENNSYLVANIA Wenary Public. City Of heny County Q.ni. al My ComJuly 15, 2010 Member, Penciation of Notarlee FLEE. 0c TI IE 2909 JUN Is Ar'l I I : ? A? f ??