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Home My WebLink About08-5877IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff No. 08 -- X8 A17 VS. KEITH A MCKEEHAN Defendant 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#06432971 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. KEITH A MCKEEHAN 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 235 SPRINGVIEW ROAD, CARLISLE. COUNT I - ACCT NO. 9305339 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, KEITH A MCKEEHAN, received and accepted the aforementioned medical services which were provided by Plaintiffs assignor 6. The prices charged by Plaintiff's assignor were the prices that Defendant, KEITH A MCKEEHAN, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, KEITH A MCKEEHAN, in the amount of $940.64 as of SEPTEMBER 24, 2008. 8. Plaintiff claims interest at the legal rate of six (6%) percent per annum from SEPTEMBER 24, 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, KEITH A MCKEEHAN, in the amount of $940.64 as to Count I, with continuing interest thereon at the rate of 6% per annum from SEPTEMBER 24, 2008 and costs COUNT II: ACCOUNT NO -9305415 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, KEITH A MCKEEHAN, 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, KEITH A MCKEEHAN, agreed to pay. 14. Plaintiff avers that there is a balance due and owing from Defendant, KEITH A MCKEEHAN, in the amount of $43.02 as of SEPTEMBER 24, 2008. 15. Plaintiff claims interest at the legal rate of six (6%) percent per annum from SEPTEMBER 24, 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, KEITH A MCKEEHAN, in the amount of $43.02 as to Count II, totaling $983.66 for Counts I & H with continuing interest thereon at the rate of 6% per annum from SEPTEMBER 24, 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. t-" ' WILLIAM T. MOLCZAN squire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#:06432971 . s 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# I (* J* Is R's C) C) C7 c.;:a C-4:> -n 7 ? C7`y L'I Lon SHERIFF'S RETURN - REGULAR CASE NO: 2008-05877 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS MCKEEHAN KEITH A MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MCKEEHAN KEITH A the DEFENDANT , at 0015:18 HOURS, on the 13th day of October , 2008 at 235 SPRINGVIEW ROAD CARLISLE, PA WILLIAM MCKEEHAN by handing to 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: Docketing Service Affidavit Surcharge loll(-ior 9- 18.00 8.00 .00 10.00 .00 36.00 So Answers: R. Thomas Kline 10/14/2008 WELTMAN WEINB & REIS ;-' By Sworn and Subscibed to before me this day of , Deputy Sher A. D. _J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. KEITH A MCKEEHAN Defendant No.: 08-5877 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT 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 Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6432971 Judgment Amount $ 958.43 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.: 08-5877 CIVIL TERM KEITH A MCKEEHAN Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: COUNTI Kindly enter Judgment against the Defendant, KEITH A MCKEEHAN above named, in the default of an Answer, in the amount of $958.43 computed as follows: Amount claimed in Complaint $ 940.64 Interest from 09/24/08 to 01/12/09 at the legal interest rate of 6.00% per annum $17.79 TOTAL COUNT H $958.43 Kindly enter Judgment against the Defendant, KEITH A MCKEEHAN above named, in the default of an Answer, in the amount of 9y3.Wcomputed as follows: Amount claimed in Complaint $ 43.02 Interest from 09/24/08 to 01/12/09 at the legal interest rate of 6.00% per annum $0.78 TOTAL $43.80 TOTAL COUNT I & H $1,002.23 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 BROi T, ESQUIRE PA I.D.#42524 Weltman, We' b rg & Reis Co., L.P.A. 1400 Koppe 1 436 Seventh v ue Pittsburgh, 15219 (412)434- 5 WWR#6432971 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 235 SPRINGVIEW ROAD CARLISLE,PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. KEITH A MCKEEHAN Defendant Civil Action No.: 08-5877 CIVIL TERM NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Jud ent was entered against you on _112 if (xx) Assumpsit Judgment in the amount of,116620Z3plus 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 ONOT Y} KEITH A MCKEEHAN 235 SPRINGVIEW ROAD CARLISLE,PA 17013 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7 h Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. KEITH A MCKEEHAN Defendant Case no:: 08-5877 CIVIL TERM 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, KEITH A MCKEEHAN 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, KEITH A MCKEEHAN is not in the military service. Further Affiant sayeth naught. AFFIANT SWORN TO AND SUBSC ED ' my presence this -14 day of COMMONWEALTH OF `UNNSYLVANIA NOTA Y PUB C ?bC><R14f?burc ?1'MnI?YIQn K?1Y 11 ?I MNIIbN, Pwmaylvrnf, 7,,'aciatlon Npyrfs9 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 KEITH A MCKEEHAN Defendant(s) IMPORTANT NOTICE TO. KEITH A MCKEEHAN 235 SPRINGVIEW ROAD CARLISLE,PA 17013 Date of Notice; ( QR)0? WWR#: 06432971 Case # d$ -SV t' ( jefq 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 : ~r -N? Wvors'?'N,cN- 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 12:10:01 < Last Name First/Middle Begin Date Active Duty Status Service/Agency MCKEEHAN KEITH A 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. & 14. vj(0jj4._ Y -F1 40? 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./pis/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 1/12/2009 ?r z O @?pA d C7 F?-- W _?3 ?aJ