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Home My WebLink About08-6001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. No. Dl- TV rol COMPLAINT IN CIVIL ACTION DOUGLAS A BECHTEL Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I.D. #90963 Weltman,Weinberg & Reis CO., L.P.A. 1400 Kopper Building 436 Seventh Avenue Pittsburgh, PA 15219 WWR#6433031 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. DOUGLAS A BECHTEL 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 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: BECHTEL, DOUGLAS A F/C: P P/T: E A/C: 9325327 DSC CODE: 01 TO: BEC:HTEL, DOUGLAS A ADMISSION: 11/14/05 DISCHARGE: 11/14/05 1514 NEWVILLE RD CARLISLE PA 17013 D E P A R T M E N T A M O U N T 807.52 475.44 1,282.96- ----------------------------------------------------------------------------- TOTAL 0.00 SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY= CMD:I=DAR,2=PAT 4=DETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD Qoa?r 1 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. ZLZ 2k? (Signature) WWR4 C ? \. • ? \? F ? _ ?S i? ?? ?J =? ? ?? ? ?? 1? x.41 V SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-06001 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS BECHTEL DOUGLAS 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 BECHTEL DOUGLAS A but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE NOT FOUND , as to the within named DEFENDANT , BECHTEL DOUGLAS A 1514 NEWVILLE RD CARLISLE, PA 17013 JOHN JOHNSON LIVES HERE; JAIME COOK LIVED HERE BEFORE HIM OVER A YEAR AGO. POST OFFICE WILL NO LONGER HAVE FORWARDING INFO ON FILE. Sheriff's Costs: Docketing 18.00 Service 5.00 Affidavit .00 Surcharge 10.00 Not Found 5.00 38.00- 8 . 0 0 So answers: So R. Thomas Kline Sheriff of Cumberland County WELTMAN WEINBERG & REIS 10/14/2008 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 vs. DOUGLAS A BECHTEL Defendant No. 08-6001 CIVIL TERM PRAECIPE TO REINSTATE 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 Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6433031 .y IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No. 08-6001 CIVIL TERM DOUGLAS A BECHTEL Defendant PRAECIPE TO. REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: -41'4A I./ WILLIAM T MOLCZAN, QUIRE PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #6433031 ? ? ?' ? ?? ?, ,..? ' j` ' r _ ter. ? .-? ? ... , . ?,» ?rt r„? "? (/a ? ?` _ , R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Sheriffs Office of Cumberland County 6ti?uir of?tttrbrrF?,d Edward L Schorpp Solicitor Jody S Smith Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/30/2009 04:45 I'M - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on March 30, 2009 at 1645 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Douglas A. Bechtel, by making known unto Ellen Paulis, mother of defendant at 2137 Newville Road Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handii to her personally the said true and correct copy of the same. SHERIFF COST: $3;3.82 March 31, 2009 2008-6001 INTERNATIONAL PORTFOLIO INC. VS DOUGLAS A. BECHTEL SO ANS RS, R THOMAS KLINE, SHERIFF By Deputy Sheriff RD-OIR:a OF THE PnnONOTAAY 2009 APR -2 FM 3: 30 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, I CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff VS. DOUGLAS A BECHTEL Defendant No.: 08-6001 CIVIL TERM PRAECIPE FOR DEFAULT 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#6433031 Judgment Amount $ 1,352.56 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. DOUGLAS A BECHTEL Defendant Civil Action No.: 08-6001 CIVIL TERM III PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, DOUGLAS A BECHTEL above named, Answer, in the amount of $1,352.56 computed as follows: Amount claimed in Complaint $ 1,282.96 Interest from 05/23/08 to 05/21/09 at the legal interest rate of 6.00% per annum $69.60 in the default of an TOTAL $1,352.56 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: Fes' JAMES C. W BRODT, ESQUIRE PA I.D.#4252 Weltman, W inb g & Reis Co., LT 1400 Kopp s BI 436 Seven Av ue Piusbur P 15219 (412) 43 955 WWR#6433031 A. Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`s Avenue, Pittsburgh, PA 15419 And that the last known address of the Defendant is: 2137 NEWVILLE RD CARLISLE,PA 17015 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLV CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. DOUGLAS A BECHTEL Defendant Case no:: 08-6001 CIVIL TERM NON-MILITARY AFFIDAVIT The undersigned, who first being duly sworn, according to law, deposes and states as 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 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 BECHTEL is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Center (DMDC), which states that the Defendant, DOUGLAS A BECHTEL is not in the mil Further Affiant sayeth naught. AFFIANT my presence this day SWORN TO AND SUBSC BE in of ??k*?(1(? t 1 with the DOUGLAS A nse Manpower Data service. / / LoUMMUNWEALTH OF PENNS LVANIA Notarial Seal f OTARY PUbLIC Wendy L. Gault, Notary Publi c ity Of Pittsburgh, Allegheny Co my [:Cy Commission Expires July 15, o1 o Member, Pennsylvania Association of Notaries This law firm is a debt collector attempting to collect this debt for our client and any informati n obtained will be used for that purpose. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. DOUGLAS A BECHTEL Defendant TO: DOUGLAS A BECHTEL 2137 NEWVILLE RD CARLISLE, PA 17015 Date of Notice: Case No. 08-6001 CIVIL TERM IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITT PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSE TO THE CLAIMS SET.FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HA TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO P INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSO 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: Ma ew Urban 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 6433031 H PIT SMI =N APPEARANCE OR OBJECTIONS HE DATE OF THIS MAY LOSE YOUR A LAWYER, GO INFORMATION /IDE YOU WITH AT A REDUCED Request for Military Status Department of Defense Manpower Data Center S! t IL-A Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 MAY-19-2009 07:45:10 Last Name First/Middle Begin Date Active Duty Status Service/ A gency BECHTEL DOUGLAS Based on the information you have furnished, the DMDC does not posse indicating that the individual is currently on active duty. ss any information Upon searching the information data banks of the Department of Defense Manpower Data Center, 1 that you provided, the above is the current status of the individual as to aril branches of the Military. . if A A .0% . VVt Orel 0044, AAY? 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 m, Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hui of "does not possess any information indicating that the individual is currently on active duty" responses a small error rate. In the event the individual referenced above, or any family member, friend, or represe manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you encouraged to obtain further verification of the person's active duty status by contacting that person's Mi "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail t( additional Military Service verification, provisions of the SCRA may be invoked against you. on the information s the Defense ility for military 0 USCS Appx. §§ Ireds of thousands and has experienced tative asserts in any re strongly tary Service via the obtain this If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle ame), 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 points-of-contact. See: http://www.defenselink,miUfaq/pis/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report !D: ESLGTNKDX Service SCRA by the requester. https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 5/19/2009 F71EC-t:r-;?,?:E C HE PIR'. ?TAIRY 2009 JU14 I I PH 12: 5 9 COV4 f YD "h +Woo PO ATT-Y Cv.'v 406o1,75 t-T** aa(.589 00?ceQ, ?"d IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No.: 08-6001 CIVIL TERM DOUGLAS A BECHTEL Defendant 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 t (xx) Assumpsit Judgment in the amount of $1,352.56 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 regist will be suspended by the Department of Transportation, of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: AR DOUGLAS A BECHTEL 2137 NEWVILLE RD CARLISLE,PA 17015 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 70' Avenue, Pittsburgh, PA 15219 1-888-434-0085