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Home My WebLink About08-5872IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. EMINA CATOVIC Defendant No. m -sg7'), &vim' 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#06434169 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. EMINA CATOVIC 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 Plaintiff is a corporation with offices at 2171 NW 139 TERR, PEMBROKE PINES, FL 33028 . 2. Defendant is an adult individual residing at 1416 BRADLEY DRIVE APT 214, CARLISLE, PA 17013. COUNT I - ACCT NO. 9352798 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, EMINA CATOVIC, 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, EMINA CATOVIC, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, EMINA CATOVIC, in the amount of $2539.54 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, EMINA CATOVIC, in the amount of $2539.54 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 -9330002 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, EMINA CATOVIC, 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, EMINA CATOVIC, agreed to pay. 14. Plaintiff avers that there is a balance due and owing from Defendant, EMINA CATOVIC, in the amount of $566.90 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, EMINA CATOVIC, in the amount of $566.90 as to Count II, totaling $3106.44 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. w WILLIAM T. MOAN, 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#:06434169 06/13/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 06/12/08 3?1 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 ---- -------- ------------------------------------------------------------------ PATIENT: CATOVIC, EMINA F/C: P P/T: E A/C: 9352798 DSC CODE: 01 TO: CATOVIC, EMINA ADMISSION: 10/27/06 DISCHARGE: 10/27/06 1446 BRADLEY DRIVE CARLISLE PA 17013 D E P A R T M E N T A M O U N T 17.08 71.03 142.29 292.65 441.24 1,575.25 2,539.54- ----------------------------------------------------------------------------- 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 06/13/'+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: CATOVIC, EMINA F/C: C P/T: E A/C: 9330002 DSC CODE: 01 TO: CATOVIC, EMINA ADMISSION: 01/20/06 DISCHARGE: 01/20/06 1446 BRADLEY DRIVE CARLISLE PA 17013 :INS CD: 950/MUL SOUTH CENTRAL PREFERRED GROUP 253901 POL ID: GH0192750 D E P A R T M E N T A M O U N T 163.95 16.88 1,159.74 639.61- 700.96- ----------------------------------------------------------------------------- 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# 1 >3 'V o ? D i T T.?' SHERIFF'S RETURN - REGULAR CASE NO: 2008-05872 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS CATOVIC EMINA KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CATOVIC EMINA the DEFENDANT at 0012:00 HOURS, on the 11th day of October , 2008 at 1416 BRADLEY DRIVE APT 214 CARLISLE, PA 17013 by handing to ABID CATOVIC FATHER OF DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 5.00 i?l???,•rsl '?/? Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 /?'I??bY ?.., ? 33.00 10/13/2008 WFT,TMAIXT WWThTT7F.Pr fu 'PVTQ Sworn and Subscibed to By: before me this day of A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. EMINA CATOVIC Defendant No.: 08-5872 CIVIL PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C. WARMBRODT, ESQUIRE PA I.D.#42524 Welt man, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6434169 Judgment Amount $ 2,598.78 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No.: 08-5872 CIVIL EMINA CATOVIC Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: COUNTI Kindly enter Judgment against the Defendant, EMINA CATOVIC above named, in the default of an Answer, in the amount of $2,598.78 computed as follows: Amount claimed in Complaint $2,539.54 Interest from 09/18/08 to 01/12/09 at the legal interest rate of 6.00% per annum $59.24 TOTAL $2,598.78 COUNT H Kindly enter Judgment against the Defendant, EMINA CATOVIC above named, in the default of an Answer, in the amount of $ S77. 71 computed as follows: Amount claimed in Complaint $566.90 Interest from 09/18/08 to 01/12/09 at the legal interest rate of 6.00% per annum $10.81 TOTAL $577.71 TOTAL COUNT I & 11 $3,176.49 r 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: JAMES C. W M RODT, ESQUIRE PA I.D.#425 Weltman, einb rg & Reis Co., L.P.A. 1400 Kopp rs B g. 436 Seve A nue 15219 (412) WWR#6434169 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 70' Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 1910 SPRING RD REAR CARLISLE,PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No.: 08-5872 CIVIL EMINA CATOVIC Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on 1.12 g (xx) Assumpsit Judgment in the amount of $.31 17G. q? 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 (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: PR HONOTAR DEP TY) EMINA CATOVIC 1910 SPRING RD REAR CARLISLE,PA 17013 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7s' Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. EMINA CATOVIC Defendant Case no:: 08-5872 CIVIL 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 affant's belief that the Defendant, EMINA CATOVIC 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, EMINA CATOVIC is not in the military service. Further Affiant sayeth naught. AFFIANT SWORN TO AND SUB D in my presence this day of COMMONWEAL,, 7 PENNSYLVANIA Noa?rii ?Ua[ NOTARY LIC W0nd' L.G u[t, Pqntary Public Cky Of PAtsburgh, A,;, =g teeny counly MY COm?gLSSion E:=Vr" s July is' am MemEer, PennsyIVan1- ;sociation p/Noferlea This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO IN Plaintiff EMINA CATOVIC Defendant(s) IMPORTANT NOTICE TO: EMINA CATOVIC 1416 BRADLEY DRIVE ## 214 CARLISLE,PA 17013 Date of Notice: WWR##: 06434169 Case # as .?'8?ct "I 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 FOLLOWING 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 BY LbOC) Kte.-- PATRICK THOMAS_-WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 (412) 434-7955 Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 JAN-12-2009 10:10:24 'K Last Name First/Middle Begin Date Active Duty Status Service/Agency CATOVIC EMINA 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. A. JM4._A?? lot 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. cf/pis/PC09SLDR.htm1 See: http://www.defenselink.mil/fa WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.miUscra/owa/scra.prc_Select 1/12/2009 u M