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Home My WebLink About08-5874IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. PEGGY A HANCOCK Defendant No. ?e -SI37y C7Ks?C., Frurl 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#06433018 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. PEGGY A HANCOCK 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 470 CENTERVILLE ROAD, NEWVILLE, PA 17241. COUNT I - ACCT NO. 9321163 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, PEGGY A HANCOCK, 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, PEGGY A HANCOCK, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, PEGGY A HANCOCK, in the amount of $1662.92 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, PEGGY A HANCOCK, in the amount of $1662.92 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 -7396615 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, PEGGY A HANCOCK, 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, PEGGY A HANCOCK, agreed to pay. 14. Plaintiff avers that there is a balance due and owing from Defendant, PEGGY A HANCOCK, in the amount of $110.00 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, PEGGY A HANCOK, in the amount of $110.00 as to Count Il, totaling $1772.92 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 WWR4:06433018 06/13/08• PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COLD: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 06/12/08 361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 ---- ------- ----------------------------------------------- PATIENT: HANCOCK, PEGGY A F/C: B P/T: 0 A/C: 7396615 DSC CODE: 01 TO: HANCOCK, PEGGY A ADMISSION: 06/12/04 DISCHARGE: 06/12/04 470 CENTERVILLE RD NEWVILLE PA 17241 INS CD: 200/BC3 BLUE CROSS 361 PPO GROUP 005051420003 POL ID: YW2198505 D E P A R T M E N T A M O U N T 584.53 226.11- 358.42- ---------------------------------------------------------------- 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: HANCOCK, PEGGY A F/C: P P/T: E A/C: 9321163 DSC CODE: 01 TO: HANCOCK, PEGGY A ADMISSION: 09/19/05 DISCHARGE: 09/19/05 470 CENTERVILLE RD NEWVILLE PA 17241 D E P A R T M E N T A M O U N T 83.05 1,006.32 573.55 1,662.92- ----------------------------------------------------------------------- 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# n "q ? d C-01 b L4 r7i ?E p {V P03 SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-05874 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS HANCOCK PEGGY A 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 HANCOCK PEGGY A but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , HANCOCK PEGGY A 470 CENTERVILLE ROAD NEWVILLE, PA 17241 PER NEW OWNER, DEFENDANT MOVED OUT A MONTH AGO. PER POST OFFICE NO FORWARDING ADDRESS ON FILE. Sheriff's Costs: Docketing 18.00 Service 12.00 Affidavit .00 Surcharge 10.00 Not Found 5.00 ! o f ?2 2lD S? (,.. 4 So answe r- i R. Th as Kline Sheriff of Cumberland County WELTMAN WEINBERG & REIS 10/16/2008 Sworn and Subscribed to before me this day of , A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff No. 08-5874 CIVIL TERM vs. PRAECIPE TO REINSTATE COMPLAINT PEGGY A HANCOCK Defendant 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#6433018 ..-t • IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No. 08-5874 CIVIL TERM PEGGY A HANCOCK Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: ' WILLIA T MOLCZAN,E UIRE PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #6433018 r C 0 f3I ' f , Sheriffs Office of Cumberland County R Thomas Kline ti ttV' of ? +r+t?rr?rl nuwalu L awlulP}1 Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/03/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant to wit: Peggy A. Hancock, 219 Walnut Street, Unit 1 F, Carlisle, Cumberland County, Pennsylvania, 17013, but was unable to locate her in his bailiwick he therefore retun the within Complaint as not found as to the defendant, Peggy A. Hancock. Current resident advises the defendant does not reside at at this address. SHERIFF COST: $37.50 April 06, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF Docket No. 2008-5874 International Portfolio, Inc. v Peggy A. Hancock FILED -Gr-FX`3 'I: OF THE IF-F, ""'NOTARY 2H9 AFAR -7 Psi 3: 50 1 -01 2U4UKl, T t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO, INC Plaintiff vs. PEGGY A HANCOCK Defendant No. 08-5874-CIVIL TERM MOTION FOR ALTERNATE SERVICE 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 #6433018 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO, INC Plaintiff No. 08-5874-CIVIL TERM vs. PEGGY A HANCOCK Defendant PLAINTIFF'S MOTION FOR ALTERNATE SERVICE AND NOW, comes Plaintiff, by counsel, Weltman, Weinberg & Reis Co., L.P.A. and requests this Honorable Court to enter an Order allowing the Plaintiff to make service upon Defendant, Peggy A. Hancock, by certified U.S. Mail and Certificate of Mailing, addressed to 129 Walnut Street, #I F, Carlisle, Pa 17013, averring in support thereof the following: On or about October 2, 2008, Plaintiff filed a Complaint in Civil Action against Defendant to recover the unpaid balance due Plaintiff from Defendant in the amount of $1,772.92. 2. When the Sheriff of Cumberland County, Pennsylvania, attempted to make service of Plaintiffs Complaint on Defendant, the Sheriff was unable to do so, as evidenced by the Sheriffs return, a true and correct copy of which is attached hereto, marked Exhibit "I", and made a part hereof. 3. Upon receipt of the Sheriff's return of no service, Plaintiff conducted an investigation with the United States Postal Service to confirm the physical address of the Defendant. WWR #6433018 4. Pursuant to Plaintiff's request for information, the United States Postal Service confirmed Defendant's physical address of 129 Walnut Street, #1 F, Carlisle, Pa 17013, a true and correct copy of Plaintiff's Postal Request is attached hereto, marked as Exhibit "2", and made a part hereof. 5. Plaintiff conducted an online white pages search and was able to confirm a current address for Defendant of 129 Walnut Street, #1 F, Carlisle, Pa 17013. A true and correct copy of the search results is attached hereto as Exhibit "3", and made a part hereof. 6. Plaintiff contacted the Cumberland County Tax Assessment office, a representative from which could not confirm the Defendant as being the registered owner of 129 Walnut Street, #1F, Carlisle, PA 17013. 7. Upon receipt of the Sheriff's return of no service, Plaintiff conducted an investigation with the Accurint Total Research System to confirm the physical address of the Defendant. 8. Pursuant to Plaintiff's request for information, Accurint Total Research System confirmed Defendant's physical address of 129 Walnut Street, # 1 F, Carlisle, PA 17013, a true and correct copy of the Accurint search results is attached hereto, marked as Exhibit "4", and made a part hereof. 9. Based upon the foregoing, Plaintiff believes and therefore avers that Defendant is attempting to avoid service of process in the above-captioned matter and Plaintiff therefore seeks an Order of Court, pursuant to Pennsylvania Rule of Civil Procedure 430, granting Plaintiff leave to serve its Complaint on Defendant by alternative means. WWR #6433018 WHEREFORE, Plaintiff requests this Honorable Court to enter an Order pursuant to PA.R.C.P. 430(a), authorizing the Plaintiff to serve Defendant by Certified U.S. Mail and Certificate of Mailing sent to an address (129 Walnut Street, #1 F, Carlisle, Pa 17013) at which Defendant i s presently receiving mail according to information obtained from the Post Office, or by allowing service by a competent adult. William T. Molczan, Es re PA I.D. 947437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #6433018 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO, INC NO. 08-5874-CIVIL TERM Plaintiff vs. PEGGY A HANCOCK Defendant AFFIDAVIT PURSUANT TO PA R.C.P. 430 (a) BEFORE ME, a Notary Public, in and for the foregoing County and Commonwealth, personally appeared William T. Molczan, Esquire, of Weltman, Weinberg & Reis, Co., L.P.A., attorneys for Plaintiff, and deposes and says that the following accurately reflects efforts made to ascertain the exact whereabouts of Defendant named in the above-captioned matter. a. Plaintiff requested current address information from the United States Postal Service, which request for information confirmed the current address for Defendant as being 129 Walnut Street, #1 F, Carlisle, Pa 17013. A true and correct copy of the Postal Service Return is marked Exhibit "2" attached hereto and made a part hereof. b. Plaintiff conducted an online what pages search that confirmed the Defendant's address to be 129 Walnut Street, # 1 F, Carlisle, PA 17013. A true and correct copy of the search result is attached hereto as Exhibit "3" and made a part hereof. C. Plaintiff requested current address information from the Accurint Total Research System, which request for information confirmed the current address for Defendant as being 129 Walnut Street, # 1 F, Carlisle, PA 17013. A true and correct copy of the Accurint search results is marked Exhibit "4" attached hereto and made a part hereof. WWR #6433018 d. Plaintiff conducted an online tax-assessment search for the address of the Defendant that could not confirm the Defendant as being the registered owner of 129 Walnut Street, #1F, Carlisle, PA 17013. Finally, Affiant deposes and says that after the foregoing investigation, the exact whereabouts of the Defendant, Peggy A. Hancock, is 129 Walnut Street, #1 F, Carlisle, Pa 17013. WELTMAN, WEINBERG & REIS, CO., L.P.A. 4?4411 William T. Molczan, Esgtire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 Sworn to and sub?j 'bed before me this t44h /daJ? of March, 10 eaMMOWws NNI VANIA v 0 i W W% A A jorM, OWN pubtks GRy a? + sbu+G„. AilptMny QouOtY Caw4w w+ Exwm Juno 20,20 0 W Member. enra WWR #6433018 Sheriffs Office of Cumberland County R Thomas Kline aa?tr at cumb"r#,? Edward L Schorpp c, Sheri Solicitor r r` Ronny R Anderson Jody S Smith Chief Deputy OFFICE OF THE V ERIPF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/03/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant to wit: Peggy A. Hancock, 219 Walnut Street, Unit 1 F, Carlisle, Cumberland County, Pennsylvania, 17013, but was unable to locate her in his bailiwick he therefore retun the within Complaint as not found as to the defendant, Peggy A. Hancock. Current resident advises the defendant does not reside at at this address. SHERIFF COST: $37.50 April 06, 2009 Docket No. 2008-5874 International Portfolio, Inc, v Peggy A. Hancock SO ANSWERS, R THOMAS KLINE, SHERIFF EXHIBIT Postmaster CARLISLE, PA 17013 Date: September 2, 2009 REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDED FOR SERVICE OF LEGAL PROCESS Please furnish the new address or the name and street address (if a boxholder) for the following: Name: PEGGY A HANCOCK 129 WALNUT ST # 1 F Address: CARLISLE, PA 17013 Note: Only one request may be made per completed form. The name and last known address are required for change of address information. The name, if known, and Post Office box address. are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(5)(ii). There is no fee for providing boxholder or change of address information. 1. Capacity of requester (e.g., process server, attorney, party representing self): ATTORNEY 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se-except a corporation acting pro se must cite statute): PEGGY A HANCOCK, INTERNATIONAL PORTFOLIO INC. 3. The names of all known parties to the litigation: 4. The court in which the case has been or will be heard: PROTHONOTARY CUMBERLAND C 5. The docket or other identifying number (a or b must be filled out): X a. Docket or other identifying number: #08-5874 CIVIL TERM b. Docket or other identifying number has not been issued 6. The capacity in which this individual is to be served (e.g., defendant or witness): DEFENDANT WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANCE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OR LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). I certify that the above information is tnie and that the address information is needed and will be used solely for service of legal process in conjunction with act al cspective litigation. at WELTMAN, WEINBERG & REIS CO., L.P.A. William T. Molczan, Esquire/ PA ID# 47437 436 Seventh Avenue, 1400 Koppers Building Attorney Pittsburgh, PA 15219 Printed Name E. P,9 ' WWR File No. 6433018 D User: TSW 777??? ?' Z&ooo FOR POST OFFICE USE ONLY No change of address order on file: @ ohs 4-0/0res5 co Moved, left no forwarding address: (? ?6 No such address: S'P$ NEW ADDRESS OR BOXHOLDER'S AND STREET ADDRESS EXHIBIT Free People Search I WhitePages WhitePages Or search: Last name only Metro area Peggy Hancock Is this you? Edit 129 Walnut St Carlisle, PA 17013-3836 View phone ,__ a?;ftc? ,Sf La w NI Ctla E Pon pei AVID ??` QUUY ?t E Ctta,PW A Graham St r aka&±n w E .Smith S 1 Che rout Ave > ° Q L? , u7 '? ! L: q s1 <% tY. 6 m ir, ' '?., UV Vtrrtin?y St r1r Cr r?tors0 yds m 2010 Microsoft Corporat 4 Page 1 of 1 EXHIBIT 3 htfr?•//?z7lETll/ \,lThltPllA6PC rnm/cParrh/FinrlPPrcnn7firctnamP hPainc with=l RrfirctnamP=PFCC.V+R,namP= '1/1 R/7n l n Deep Skip Search Page 1 of 1 -..._............ _..- - - _...... -- PEGGY A HANCOCK i 129 WALNUT ST APT 1F 71740FJ? - EDT PEGGY ANN HANCOCK CARLISLE PA 17013-3836 HANCOCK PEGGY PEGGY S HANCOCK Link ID: 1045689869 Aug 08 - Mar 10 16 Active Phone PEGGY HANCOCK Probable curren address MILLER P HANCOCK MILLER HANCOCK PEGGY A MILLER 129 WALNUT ST # 1 717 EDT DOB- CARLISLE PA 17013-3836 HANCOCK PEGGY Age: 49 Aug 08 - Jan 10 "r Active Phone DOB Probable current address Age: 49 Gender - Female 129 WALNUT ST # 1!F 717-249-3735 - EDT L.? ?` Setup Alert CARLISLE PA 17013-3836 HANCOCK PEGGY Aug 08 - Feb 10 `* Active Phone httnc 1/cP.?nre ancnrint rnm/ann/hnc/mice VI R/?()1() CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of the within Motion for Alternate Service was served on the AV-1 day of ?, 2010, by first class, U.S. Mail, postage-prepaid, addressed as follows: Peggy A. Hancock 129 Walnut Street, #1 F Carlisle, Pa 17013 zl,? Attorney for Plaintiff WWR #6433018 APR *1 4 Z010 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO, INC Plaintiff No. 08-5874-CIVIL TERM n r ;, , cfvs. PEGGY A HANCOCK r ?- ORDER OF COURT AND NOW, to-wit, this 41 day of v`1 2010, upon consideration of the foregoing Motion for Service of the Complaint Pursuant to Special Order of Court and attached supporting affidavit, it is hereby ORDERED, ADJUDGED AND DECREED, that the service of the Complaint in Civil Action may be made on Defendant, Peggy A. Hancock, by permitting the Plaintiff to mail a copy of the Complaint to the Defendant the last known address being 129 Walnut Street, #1 F, Carlisle, Pa 17013 by Certified Mail and by Certificate of Mailing Postal Form 3817, postage prepaid. Service to be completed upon mailing. BY THE COURT: Dl,TRIBUTION: Peggy A Hancock 129 Walnut St # 1 F Carlisle, PA 17013 William T. Molczan, Esq. Weltman, Weinberg & Reis, Co. LPA 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 PIES' /Yt?IC W WR #6433018 S J • 1,J F-' [,f 2010 A -3 Avb 3 j z' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. PEGGY A HANCOCK Defendant(s) No. 08-5874 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Lyndsay E Rowland, Esquire PA ID #205520 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Buidling 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6433018 TIC (i) *10.00 PD ATr4 at 4W R 61-00 P"fd4&12T IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No. 08-5874 CIVIL TERM PEGGY A HANCOCK Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAP,1WEINBERG & REIS CO., L.P, By: ?- Lyndsay land, squire PA ID #205 p4o WELT EINBERG & REIS CO., L.P.A. 1400 Koppers Buidling 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #6433018 ~~ .~,ifr LJ~;} ._ 0~~fE ,,`t=a' ~rti.~t ~ j=~,~ ii '- ,',,`t~- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. PEGGY A HANCOCK Defendant No. 08-5874 CIVIL TERM AFFIDAVIT OF SERVICE OF 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 Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6433018 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff No. 08-5874 CIVIL TERM vs. PEGGY A HANCOCK Defendant AFFIDAVIT OF SERVICE OF COMPLAINT Before me, the undersigned authority, personally appeared William T. Molczan, Esquire, who, being duly sworn according to law, deposes and says that on JULY 30, 2010, he did cause to be sent to Defendant, Peggy A Hancock, Plaintiff's Complaint by Certificate of Mailing Postal Form 3817 and on JULY 30, 2010, he did cause to be sent to Defendant, Peggy A Hancock, Plaintiff's Complaint by Certified Mail, Return Receipt requested, directed to the Defendant at her last known address of 129 Walnut St, #1 F, Carlisle, PA 17013. True and correct copy of Plaintiff's Certificate of Mailing PS Form 3817 is attached hereto, marked as Exhibit "1" and made a part hereof. Furthermore, true and correct copy of Plaintiff's Receipt for Certified Mail is attached hereto, marked as Exhibit "2" and made a part hereof. As the Order of Court states, service is deemed to be perfected as of JULY 30, 2010, the date of mailing. WELTMAN, WEINBERG & REIS CO., L.P.A. ~- By: WILLIAM T. MOLCZAN, E QUIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 Sworn to and subscribed before me this /3 ~ dayof S~E,f,'T/EMBER,- 0. -' N~7ITARY PU i WWR#6433018 COMMONWEALTH OF_PENNSYI.VANIA Nofarlal Seal Wayne A. Jones, Npbry Publk Ctty of Pittsburgh, Alleph~ny COUnty MY Commission ~~ Jung 29, 2014 iMerrtber. ~er~svivanla Artc~Clattcwt of NAt»1'!ec ~~~~ ~, .,, a ,~~, ~ .,~, a-... pct ~l'°PlllaiBic-Ig 9~OST/~ L SERVICEM , Thla Cerllflcale of Malling p,ovldea avldanev Thal mall has hewn preaenlsd to USPSa tar malllny. Thls lone ma~y~h/e use{deylor ddnopmyeall~c~afnPd~Inpl~aamaIlan^al mall. Frvm: VV~'ll ~ 1'ti.tll Ir 97 GB1 t~~l~ ~ ~~~~ ~~. ~ 400 6Co~a~rs ~9c9g 436 7fih A~~a e s ur~h, ~~ ~ 52~ ~ F ~~ =-.d~~~, US . Post al Ser viceT ~, CE RTIF IED MAIL T~:, REC EIPT (Dom estic M ai! Only ;. No Ins urance C overage P rovided) o- m ~ I ru fT'1 r~ Postage ~~~ Certified Fee ~ ~ Return Receipt Fes O (Endorsement Required) O 7v d' k P t,n~ ,. ~-- ,~ , L%G; ~ e ~ r ~~ P H~i~j f,P~ Restricted Delivery Fee ~~, (Endorsement Required) Total Postage & Fees $ '` z~ Sent To --------------------J=----------- -----------------~------1-j~------------------------- Streei, Apt. No.; orP08oxNo. /~~ ~~RL/JL'~ 5T' ~ r/= City, State, ZIP+4 :aa ar. _ _ flJ O 0 a O ,: a • ~,) I £ ,:I ~r d i- ~.., ~~ _. s ~ ~ ~~):ar~ ~ r ~~ ~ ~ //pJO! ~ ~.~,i z .. ., r~ J_.I PS Form x(1'17, Anril 2007 PSi~ 7530-02-000-9065 FICE U j g c r { ,I, _ L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO, INC; Plaintiff No. 08-5874 CIVIL TERM vs. PRAECIPE FOR DEFAULT JUDGMENT PEGGY A HANCOCK defendant 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#6433018 Judgment Amount $ 1,996.16 ? • Do PIa A`CYN Cf''? B Z03I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO, INC Plaintiff vs. Civil Action No. 08-5874 CIVIL TERM PEGGY A 1 ANCOCK Defendant PRAECIPE FOR DEFAULT JUDGMENT COUNT I - XXX1163 TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, PEGGY A HANCOCK above named, in the default of an Answer, in the amount of $1872.31 computed as follows: Amount claimed in Complaint $1662.92 Interest from 09/19/2008 to 10/25/2010 at the interest rate of 6.00% per annum $209.39 TOTAL $1872. 1 COUNT I - XXX661.5 TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, PEGGY A HANCOCK above named, in the default of an Answer, in the amount of $123.85 computed as follows: Amount claimed in Complaint $I 1.0.00 Interest from 09/19/2008 to 10/25/2010 at the interest rate of 6.00% per annum $13.85 TOTAL $123.85 COUNT I & 11 TOTAL $1996,16 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. war rodt, Esquire PA I.D. #42 2 WELTMA1r, WtINBERG & REIS CO., L.P.A. 1400 Koppers Bilding 436 Seven Avgnue Pittsburghy PA 15219 (412) 434-79?4 WWR#.433018 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1.400 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 1521.9 And that the last known address of the Defendant is: 139 WALNUT ST, #1F, CARLISLE', PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. PEGGY A HANCOCK Defendant TO: PEGGY A HANCOCK 129 WALNUT ST #1 F CARLISLE:, PA 17013 Case No, 08-5874 CIVIL TERM IMPORTANT NOTICE 40. Date of 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 SETT 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 WELTMA.N?BERG & REIS CO., L.P.A By: G--,- Matthew Urban P.AJ,D.# 90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 6433018 H PIT TIC IN THE COMMON PLEAS COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION II INTERNATIONAL PORTFOLIO, INC Plaintiff Civil Action No. 08-5874 CIVIL TERM vs. NON-MILITARY AFFIDAVIT PEGGY A HANCOCK Defendant The undersigned is the duly authorized agent and/or attorney for the Plaintiff in the within matter and states as follows: Affiant states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' CivilRelief Act (SCRA), 50 U.S.C. App. 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, PEGGY A HANCOCK 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 DMDC does not possess any information indicating that the below individual is in the military service: PEGGYA HANCOCK 129 WALNUT ST, #1 F CARLISLE, PA 17013 Affiant further states that the averments contained herein are true and correct to the best of Affiant's knowledge,' information and belief and that these averments are 'made subject to the penalties of 18 Pa C.S.A. §4904 relating to unsworn falsification to authorities. Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Oct-28-2010 1-1:33:37 Last Service Name First/Middle Begin Date Active Duty Status Active,Duty End Date Agency HANCOCK PEGGY A Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. 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 Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). Aak?l 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 DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCR.A) (formerly known as 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 status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.mil/faq/Xis/PC09SLDR.html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50, USC App. §521(c). If you obtain additional 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 anew certificate for that query. This response reflects active duty status including date the individual was; last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCR.A points-of- contact. httnc-//www.clmcle.o.scl.mil/anni/..sera/nonrennrt do 1(1/2R/?.? 10 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Linder the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:UB06POREEJ httn-,-//www clmcir, nacl mi1/anni/ccra/nnnrPnnrt cin 1 n/ >R/?ni n IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO, INC Plaintiff VS. Civil Action No. 08-5874 CIVIL TERM PEGGY A HANCOCK 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 l 3 ?? (xx) Assumpsit Judgment in the amount of $1996.16 plus costs. Trespass Judgment in the amount of $ plus' costs. II ( ) 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 ARY (OR DEPUTY) JANE ADAMS, ESQUIRE 17 WEST SOUTH STREET CARLISLE, PA 17013 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7t' Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO, INC Plaintiff vs. PEGGY A HANCOCK Defendant PEGGY A I-IAN000K 129 WALNUT ST, 41F CARLISLE, PA 17013 c/o Weltman, Civil Action No. 08-5874 CIVIL TERM NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order o Judgment was entered against you on 1 /D (xx) Assumpsit Judgment in the amount of $1996.16 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 Prothono a' By: f PR O ARY (OR EPUTY) Plaintiff's address is: Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7"' Avenue, Pittsburgh, PA 1-888-434-0085 1_>219 WELTMAN, WEINBERG & REIS,CO., L.P.A. BY: William T. Molczan,47437 I.D. No. 47437 436 7th Ave Ste 1400 Pittsburgh PA 15219-1827 (412) 434-7955 FAX: 412-338-7130 File # 06433018 C H Pit SJS Attorney for Plaintiff(s) INTERNATIONAL PORTFOLIO INC. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY VS. PEGGY A HANCOCK CASE NO. 08-5874 CIVIL TERM PRAECIPE TO SATISFY TO THE PROTHONTARY: Kindly mark the case and judgment entered against Defendant PEGGY A HANCOCK as satisfied. WELTMAN, WEINBERG & REIS CO., L.P.A. By William T. Mo czan Attorney for Plai jiff 4.50 PO A ft/ a ',sworn e 804104