The URL can be used to link to this page

Home My WebLink About08-5880IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. SONIA RODRIGUEZ Defendant No. DS-- S086 l: rv? 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#06432969 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No. SONIA RODRIGUEZ 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 1.7013 (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 151 CEDAR ST, CARLISLE, PA 17013. COUNT I - ACCT NO. 9304907 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, SONIA RODRIGUEZ, 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, SONIA RODRIGUEZ, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, SONIA RODRIGUEZ, in the amount of $1470.41 as of SEPTEMBER 18, 2008. 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, SONIA RODRIGUEZ, in the amount of $1470.41 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 -9303859 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, SONIA RODRIGUEZ, 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, SONIA RODRIGUEZ, agreed to pay. 14. Plaintiff avers that there is a balance due and owing from Defendant, SONIA RODRIGUEZ, in the amount of $768.09 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, SONIA RODRIGUEZ, in the amount of $768.09 as to Count II, totaling $2238.50 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. G? WILLIAM T. MOL7AN, Esquire PA I.D. #47437 WEI.,TMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR#:06432969 06/12/08. PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 06/11/08 361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 ---- ------- ------------------------------------------------------------------ PATIENT: MACHIN, ALEXIS JR F/C: F P/T: E A/C: 9304907 DSC CODE: 01 TO: RODRIGUEZ, SONIA ADMISSION: 02/26/05 DISCHARGE: 02/26/05 151 CEDAR ST CARLISLE PA 17013 INS CD: 200/KCE BLUE CROSS 361 KCE GROUP 055133 POL ID: YWH185703 D E P A R T M E N T A M O U N T 7.60 29.54 292.65 1,140.62 1,470.41- ----------------------------------------------------------------------------- TOTAL 0.00 SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY= CMD:I=DAR,2=PAT 4=DETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD 06/12/08. PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA'_7 COLD: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 06/11/08 361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE ('117) 960-1680 ---- ------- ------------------------------------------------------------------ PATIENT: MACHIN, ALEXIS J F/C: F P/T: E A/C: 9303859 DSC CODE: 01 TO: RODRIGUEZ, SONIA ADMISSION: 02/13/05 DISCHARGE: 02/13/05 151 CEDAR ST CARLISLE PA 17013 D E P A R T M E N T A M O U N T 292.65 475.44 768.09- ----------------------------------------------------------------------------- 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# RJ d n r_ - _TI C? Q w c-a - ri i TI W ? 1 ? t l . , t_ 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-05880 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS RODRIGUEZ SONIA 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 RODRIGUEZ SONIA the DEFENDANT , at 0014:30 HOURS, on the 8th day of October , 2008 at 151 CEDAR ST CARLISLE, PA 17013 DEFENDANT by handing to 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 j0//3pp 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. OF THE F90TP,: V. AIRY 2810 MAY I I AM 10? 02 ClUtwLr COL NTY IN THE COURT OF COMMON PLEAS OF eUMBERLAND COUNTY, PRNNSVLVANIA CIVIC, DIVISION INTERNATIONAL- PORTFOLIO INC, Plaintiff us. SONIA RODRIGUE Defendant No, 08.5880 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT WILL 0 ON BEHALF OF Rleii'tiff COUNSEL OF RECORD OF THIS PARTY: Willhom T, k4olo xl?n, a>wq JiP PA, I,D,047437 WELTMAN, WRINBBRG & REIS 00., L,P,A. 1400 Koppers Building 431 Sevsnth Avenue Pittsburgh, PA 15219 (412) 434-7055 WWR#6432069 Judgment Amount 2,454.87 414. oo PO RTTq CO 457801 -11o P.,* a4I S4S IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff ua, Civil Action No. 08-5860 CIVIL TERM SONIA RODRIGUEZ Defendant P F N TO THE PROTHONOTARY: OWNI I Kindly enter Judgment against the Defendant, SONIA RODRIGUEZ, above named, in the default of an Answer, in the amount of $1,512.54 computed as follows: Amount claimed in Complaint $1,470.41 Interest from SEPTEMBER 18, 2008 TO APRIL 29, 2010 at the legal interest rate of 6.00% per annum $142.13 TOTAL $1,612.54 290111 Kindly enter Judgment against the defendant, SONIA RODRIGUEZ, above named, in the default of an Answer, in the amount of $842.33 computed as follows: Amount claimed in Complaint $768.09 Interest from SEPTEMBER 18, 2008 TO APRIL 29, 2010 at the legal interest rate of 6.00% per annum $74.24 TOTAL $842.33 TOTAL COUNT I $ COUNT 11 $2,454.87 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. WELTIVIAN, WEINUERRe & REIS M, L.P.A. ,r } ey? Willi?im ` b1e eh, ! re ?RA. I . D.047437 WELTMAN, WEINBERG & REIS CO., L.R.A. 1400 hoppers Building 436 Seventh Avenue Pittsburgh, PA 18219 (412) 434.7968 WWR 438969 Plaintiff's address is; clo Weltman, Weinberg & Geis Ce„ L.P,A„ 1400 hoppers Building, 436 7`p Avenue, Pittsburgh, PA 18219 And that the last known address of the Defendant is, 151 CEDAR ST, CARLISLE, PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. SONIA RODRIGUEZ Defendant Case No. 08-5880 CIVIL TERM IMPORTANT NOTICE TO: SONIA RODRIGUEZ 151 CEDAR ST CARLISLE, PA 17013 Date of Notice: ao log 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 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 WELTMAN, WEINBERG & REIS CO., L.P.A. By: -- Matthe Ur an P.A.I.D.# 90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 6432969 H PIT TSW IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Aotion No. 08-6860 CIVIL TERM SONIA RODRIGUEZ Defendant NOTIQE OF,JUPPLAENT QB QRDEB TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on 10 _-- (xx) Assumpsit Judgment in the amount of $1,612.54 plus costs as to Count I. (xx) Assumpsit Judgment in the amount of $842.33 plus costs as to Count II. ( ) 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: ? ) ?a PROTH Y (QR DE UTY) SONIA RODRIGUEZ 151 CEDAR ST CARLISLE, PA 17013 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7'" Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Case no: 08-5880 CIVIL TERM Plaintiff vs. SONIA RODRIGUEZ Defendant 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, SONIA RODRIGUEZ 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, SONIA RODRIGUEZ, is not in the military service. Further Affiant saayeth naught. AFFIANT SWORN TO AND SUBrIBED in my presence this 39'?'day Of MAY. 2010. t"41MM70NWEALTH OF PENNSYLVANIA Notarial Seal --! A Jon@e, N018rY Public 'Msburgh. All"heny Cou " iFxN?es Juns 2?, 2010 '` Yes ^?!?'ir?9w.vM?:c ??A9?''dation ?+! N41?rlel? Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Apr-29-2010 10:46;31 •< Last N First/Middle Begin Date Active Duty Status Active Duty End Date Service A ame gency RODRIGUEZ SONIA Based on the information you have furnished, the DMDC does not possess an 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, NOAH, Public Health, and Coast Guard). 4101 )4. Vif 04itai- 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) (SCRA) (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.millfall/pis/PC09SLDR.htmi. 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 a new 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 SCRA points-of- contact. httna,//unww rimrie ngri mi1/Anni/4era/rnnrPnnrt rin Q/9A/9f11() Request for Military Status Page 2 of 2 More Information on "Active Busy Status to 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 (NOAH Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under 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:I 1 Q2NIETTB httnS,//www dm, dr. opid mi1/m»;ii/oP..ra/,nnnrennrt do 4/94/0)(11 f)