The URL can be used to link to this page

Home My WebLink About08-6005V?y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. No. n U40S ?/-Vl'/ Rfm COMPLAINT IN CIVIL ACTION ANDREW M KERR 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#6433004 t N IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No. ANDREW M KERR 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 4 V COMPLAINT Plaintiff is a corporation with offices at 7465 N.W. 49TH ST, LAUDERHILLE, FL 33319- 0000. 2. Defendant is an adult individual residing at 75 QUARRY HILL RD NEWVILLE,PA 17241. 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, ANDREW M KERR, 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, ANDREW M KERR, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, ANDREW M KERR, in the amount of $1,269.85 as of MAY 29 2008. 8. Plaintiff claims interest at the legal rate of six (6%) percent per annum from MAY 29 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, ANDREW M KERR, in the amount of $1,269.85 with continuing interest thereon at the rate of 6% per annum from MAY 29 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. M ZAN, 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#:6433004 05/13/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 05/12/08 361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 ---- ------- ------------------------------------------------------------------ PATIENT: KERR, ANDREW M F/C: P P/T: E A/C: 9316124 DSC CODE: 01 TO: KERR, ANDREW M ADMISSION: 07/19/05 DISCHARGE: 07/19/05 75 QUARRY HILL RD NEWVILLE PA 17241 DE P A R T M E N T AM(?0UNT A 1 n TlTT7T T7TA7\ flV 90. 17 85.28 1,244.40 150.00- 1,269.85- ----------------------------------------------------------------------------- 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 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. .t?oj-- Z-441 (Signature) WWR# C> C= C?7 I r , "C1 fig} - d SHERIFF'S RETURN - REGULAR CASE NO: 2008-06005 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS KERR ANDREW M NOAH CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE KERR ANDREW M was served upon the DEFENDANT , at 0018:00 HOURS, on the 15th day of October , 2008 at 75 QUARRY HILL RD NEWVILLE, PA 17241 by handing to ANDREW M KERR 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 j0/,2a,/0r (.- 18.00 12.00 .00 10.00 .00 ? 40.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 10/16/2008 WELTMAN WEINBERG & REIS By: Deputy Sheriff of A. D. a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. ANDREW M KERR Defendant No.08-6005 CIVIL TERM PRAECIPE FOR ENTRY OF JUDGMENT BY CONSENT 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#06433004 Judgment 1269.85 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. ANDREW M KERR Defendant Civil Action No. 08-6005 CIVIL TERM PRAECIPE FOR JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment against Defendant, ANDREW M KERR, in the amount of $1269.85 plus costs, based upon the consent of the parties. CONSENTED TO: WELTMAN, WEINBERG & REIS CO., L.P.A., tv ' By: Attorney for P intiff WWR#06433004 ANDREW M KERR, `'//-10-- By. Defendant a IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No. 08-6005 CIVIL TERM ANDREW M KERR Defendant STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment in favor of Plaintiff and against the Defendants, ANDREW M KERR, above-named, in the amount of $1269.85 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment by Consent, as follows: Defendants admits indebtedness to Plaintiff in the amount of $1269.85 with continuing interest thereon at a rate of 6% per annum plus costs from DATE OF JUDGMENT. 2. To secure the repayment of said indebtedness, Defendants agrees that Judgment by Consent will be entered in favor of the Plaintiff and against the Defendants, ANDREW M KERR, in the amount of $1269.85 plus continuing interest thereon at the rate of 6% per annum from DATE OF JUDGMENT and costs. 3. Plaintiff agrees not to execute on its Judgment so long as Defendants causes to be delivered to Plaintiff the following payments in full by 12:00 NOON on the following dates: (a) $75.00 due by 11/30/08; (b) $75.00 due on the 30TH day of each consecutive month thereafter until the Judgment amount plus accrued interest and costs are paid in full. 4. All payments are to be made payable to the order of "INTERNATIONAL PORTFOLIO INC." 5. All payments due under this agreement are to be received at the offices of Weltman, Weinberg & Reis, Co., L.P.A., 1400 Koppers Building, 436 Seventh Avenue, Pittsburgh, PA 15219. All future payments are to be mailed to the offices of Weltman, Weinberg & Reis, Co., P.O. Box 5430, Cleveland, OH 44101-0430. 6. In the event of default, each payment received shall be first attributed to costs, interest and then to principal. 7. Time is of the essence of this agreement and shouid the Defendants fail to have in the hands of Plaintiff or Plaintiffs counsel any payment in full within five (5) calendar days of the stated due date, then Plaintiff shall be immediately free to issue Execution as well as pursue all other remedies, in law or in equity, to collect the full balance of the Judgment entered hereunder plus appropriate additional interest and costs. 8. No act or omission of the Plaintiff, nor of anyone alleged to be acting on its behalf, shall constitute a waiver, estoppel, or any other excuse for non-performance of any duty undertaken by the Defendant in this Stipulation which the parties agree is final and complete. 9. Intending to be legally bound, the parties set their hands and seals this -day of , 20 WELTMAN, WEINBERG & REIS CO., L.P.A. By: William 'N. Molcza ,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 No. 06433004 By: Defendant, ANDREW M KERR 9-1 00 Q r?r:. its 77 C"i3 ? r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No. 08-6005 CIVIL TERM ANDREW M KERR 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 (xx) Assumpsit Judgment in the amount of $1269.85 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 ( ) Default ( ) Verdict ( ) Arbitration ( ) Award (XX) By Consent Prothonotary ANDREW M KERR 75 QUARRY HILL ROAD NEWVILLE, PA 17241 By: j?L PR HONG TAI?Y_ 0 R D Fr'U vlt Ti r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO IN Plaintiff vs. ANDREW M KERR Defendant(s) No. 08-6005 CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Lyndsay E Rowland, Esquire PA I.D. # 205520 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6433004 TIC f1l. 11, 0 ' )V//Y ,2?lwlklml 9G ?U 7H IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO IN Plaintiff vs. Civil Action No. 08-6005 CIVIL TERM ANDREW M KERR Defendant(s) PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTM^WEINBERG & REIS CO., L.P.A. By: Lyndsay E ow an , squire PA I.D. # J0 52o WELTMA)g WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #6433004 Sworn to and subscribed before me this ,gyp ni day of July, 10 a l? TARY BLIC COMMONWEALTH OF PENNSYLVANIA NoanaI swl Wayne A. ,larvae, Notary Pubkc a y of ARWAV, AIN r QXMW MY _ .. _. 216 3014 M8"O II