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Home My WebLink About08-5869IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. ROBIN R JENKINS Defendant No. Q ? ??lo? dur 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 W WR#06431679 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No. ROBIN R JENKINS 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 101 VAUGHN ROAD, SHIPPENSBURG, PA 17257. COUNT I - ACCT NO. 7523176 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, ROBIN R JENKINS, 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, ROBIN R JENKINS, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, ROBIN R JENKINS, in the amount of $654.59 as of SEPTEMBER 19, 2008. 8. 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, ROBIN R JENKINS, in the amount of $654.59 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 -7520293 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, ROBIN R JENKINS, 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, ROBIN R JENKINS, agreed to pay. 14. Plaintiff avers that there is a balance due and owing from Defendant, ROBIN R JENKINS, in the amount of $358.26 as of SEPTEMBER 19, 2008. 15. Plaintiff claims interest at the legal rate of six (61/o) 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, ROBIN R JENKINS, in the amount of $358.26 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 -7539053 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, ROBIN R JENKINS, 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, ROBIN R JENKINS, agreed to pay. 21. Plaintiff avers that there is a balance due and owing from Defendant, ROBIN R JENKINS, in the amount of $261.98 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, ROBIN R JENKINS, in the amount of $261.98 as to Count III, totaling $1274.83 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. WILLIAM T. OCZAN, Zsqube PA I.D. #4743 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR#:06431679 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: JENKINS, ROBIN R F/C: C P/T: 0 A/C: 7523176 DSC CODE: 01 TO: JENKINS, ROBIN R ADMISSION: 08/18/05 DISCHARGE: 08/18/05 101 VAUGHN ROAD SHIPPENSBURG PA 17257 :=NS CD: 120/PHC AMERIHEALTH ADMIN GROUP 076307 POL ID: 040411357 D E P A R T M E N T A M O U N T 1,626.41 646.54- 979.87- ------------------------------------------------------ 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 2 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: JENKINS, ROBIN R F/C: C P/T: 0 A/C: 7520293 DSC CODE: 01 TO: JENKINS, ROBIN R ADMISSION: 08/12/05 DISCHARGE: 08/12/05 101 VAUGHN ROAD SHIPPENSBURG PA 17257 INS CD: 120/PHC AMERIHEALTH ADMIN GROUP 076307 POL ID: 04041135T D E P A R T M E N T A M O U N T 2,239.12 1,433.04- 806.08- ----------------------------------------------------------------------------- TOTAL 0.00 SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY= CMD:I=DAR,2=PAT 4=DETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD 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: JENKINS, ROBIN R F/C: D P/T: 0 A/C: 7539053 DSC CODE: 01 TO: JENKINS, ROBIN R ADMISSION: 10/26/05 DISCHARGE: 10/26/05 101 VAUGHN ROAD SHIPPENSBURG PA 17257 INS CD: 120/PHC AMERIHEALTH ADMIN GROUP 076307 POL ID: 04041135T D E P A R T M E N T A M O U N T 10.98 1,626.41 1,047.93- 589.46- ---------------------------------------------------------------------------- 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# CD ?ti ? SHERIFF'S RETURN - REGULAR CASE NO: 2008-05869 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS JENKINS ROBIN R NOAH CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon JENKINS ROBIN R the DEFENDANT , at 0016:40 HOURS, on the 15th day of October , 2008 at 101 VAUGHN ROAD SHIPPENSBURG, PA 17257 ROBIN R JENKINS by handing to DEFENDANT together with a true and attested copy of COMPLAINT & NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 17.00 Affidavit .00 Surcharge 10.00 .00 to/a2fOp 45.00 Sworn and Subscibed to before me this day So Answers: .;;roor - R. Thomas Kline 10/16/2008 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. ROBIN R JENKINS Defendant(s) No. 08-5869 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. #42524 WELTMAN, WEINBERG & REIS CO., L.P.A 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6431679 TSW IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff VS. Civil Action No. 08-5869 CIVIL ROBIN R JENKINS 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 subscribed Before niwtbe a Day o ?' .,be aOb °? OTARY PUBL C WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. W PA I.D. #42 W ELTMAI 1400 Kopp 436 Seve 1 Pittsbur , (412) 43 Esquire 'Building venue A 15219 955 1679 & REIS CO., L.P.A wlgi o!'I?V . i H t3F, !' YLiiAN1A l?-? Noteria18ee1 Wendy L vault. Notary Public Qty of Pittsburgh r, Alle$ltsny County my CoTrn;?sion cxgires Jul 15 2.010 ,uu ,.! . i? snaylVnlsz5m0 at pR g1?H?e FiLE-b- 1""F 2089 OCT 13 PM 2: 1 2