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HomeMy WebLinkAbout08-6006M, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. No, COMPLAINT IN CIVIL ACTION BRADLEY W CASSELL 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#6433073 • w IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. BRADLEY W CASSELL 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 v ' w COMPLAINT 1. Plaintiff is a corporation with offices at 2171 NW 139 TERR PEMBROKE PINES, FL 33028-0000. 2. Defendant is an adult individual residing at 105 HEBERLIG 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, BRADLEY W CASSELL, 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, BRADLEY W CASSELL, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, BRADLEY W CASSELL, in the amount of $3,462.92 as of JULY 1 2008. 8. Plaintiff claims interest at the legal rate of six (6%) percent per annum from JULY 1 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, BRADLEY W CASSELL, in the amount of $3,462.92 with continuing interest thereon at the rate of 6% per annum from JULY 1 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. MOYCZAN, 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#:6433073 06/13/08'b 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: CASSELL, BRADLEY W F/C: P P/T: E A/C: 9345586 DSC CODE: 01 TO: CASSELL, BRADLEY W ADMISSION: 07/30/06 DISCHARGE: 07/30/06 105 HEBERLIG RD NEWVILLE PA 17241 D E P A R T M E N T A M O U N T 71.03 170.98 292.65 1,006.32 550.20 390.66 981.08 3,462.92- ----------------------------------------------------------------------------- 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 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# c?a C7) -4 J.3 V ?V V SHERIFF'S RETURN - REGULAR CASE NO: 2008-06006 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS CASSELL BRADLEY W 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 CASSELL BRADLEY W the DEFENDANT , at 0016:36 HOURS, on the 13th day of October , 2008 at 105 HEBERLIG RD NEWVILLE, PA 17241 by handing to BRADLEY W CASSELL 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 18.00 Service 16.00 Affidavit .00 Surcharge 10.00 1011('101 9, 00 44.00 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 10/14/2008 WELTMAN WEINBERG E S BY 1 / Deputy Sheri A. D. r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. No. 08-6006 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE and END BRADLEY W CASSELL 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 WWR906433073 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No. 08-6006 CIVIL TERM BRADLEY W CASSELL Defendant PRAECIPE TO SETTLE DISCONTINUE and END TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue and End the above captioned matter upon the records of the Court and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: / /William T. Mo1c?eCn, 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#06433073 COUMC`NkNEP,LTE__'? '?a?L?_- °/``hi' Notai'ni weal Wendy L. Glut , No}YY PUblic City Of Pitt ?';k" ghe'ny county sis 20i My Coma", + r??r uty 5 Penncyivcr!...._. r:ai,w o' No?aris Ykember, Sworn to and subscribed Before me the 0 ?:::.; C'? i ?E . b ???? .?