HomeMy WebLinkAbout08-6009
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff
VS.
No.
COMPLAINT IN CIVIL ACTION
DEBORAH OCKER
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#6432948
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff
vs. Civil Action No.
DEBORAH OCKER
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
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 320 EASY RD CARLISLE,PA 17013.
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, DEBORAH OCKER, 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, DEBORAH
OCKER, agreed to pay.
7. Plaintiff avers that there is a balance due and owing from Defendant, DEBORAH
OCKER, in the amount of $1,932.68 as of JUNE 25 2008.
8. Plaintiff claims interest at the legal rate of six (6%) percent per annum from JUNE 25
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, DEBORAH
OCKER, in the amount of $1,932.68 with continuing interest thereon at the rate of 6% per annum from
JUNE 25 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.
M tthew D. Urban, Esquire
PA I.D. #90963
Weltman,Weinberg & Reis CO., L.P.A.
1400 Kopper Building
436 Seventh Avenue
Pittsburgh, PA 15219
WWR#:6432948
OG/12/0£s 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: NASTELLI, KAYTLYNNE M F/C: P P/T: E A/C: 9296851 DSC CODE: 01
TO: OCKER, DEBORAH ADMISSION: 11/14/04 DISCHARGE: 11/14/04
320.EASY RD CARLISLE PA 17013
D E P A R T M E N T A M O U N T
45.28
334.34
1,553.06
1,932.68-
-----------------------------------------------------------------------------
TOTAL 0.00
SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY=
CMD:I=DAR,2=PAT 4=DETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD
-im -
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.
aJ4A
(Signature)
W WR#
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(V?V
O
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-06009 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
INTERNATIONAL PORTFOLIO INC
VS
OCKER DEBORAH
KENNETH GOSSERT , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
OCKER DEBORAH the
DEFENDANT , at 0012:34 HOURS, on the 11th day of October , 2008
at 320 EASY RD
CARLISLE, PA 17013 by handing to
DEBORAH OCKER BLACKBURN DEFENDANT
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 18.00
Service 5.00
Affidavit .00
Surcharge 10.00
.00
3 3 . 0 0
Sworn and Subscibed to
before me this day
of ,
So Answers:
R. Thomas Kline
10/13/2008
WELTMAN WEINBERG & REIS
By:
DeA5ut
A. D.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff
vs.
DEBORAH OCKER
Defendant
No. 08-6009 CIVIL TERM
PRAECIPE FOR DEFAULT JUDGMENT
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#06432948
Judgment Amount $ 1981.29
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. 08-6009 CIVIL TERM
DEBORAH OCKER
Defendant
TO THE PROTHONOTARY:
PRAECIPE FOR DEFAULT JUDGMENT
Kindly enter Judgment against the Defendant, DEBORAH OCKER above named, in the default of an
Answer, in the amount of $1981.29 computed as follows:
Amount claimed in Complaint
$1932.68
Interest from 06/25/08 to 11/25/08
at the legal interest rate of 6.00% per annum $48.61
TOTAL
$1981.29
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:
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#06432948
Plaintiffs address is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7 h Avenue, Pittsburgh, PA 15219
And that the last known address of the Defendant is: 320 EASY ROAD, CARLISLE, PA 17013
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO INC.
Plaintiff
VS. Civil Action No. 08-6009 CIVIL TERM
DEBORAH OCKER
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 $1981.29 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
(xx) Default
( ) Verdict
( ) Arbitration
Award
Prothonotary
By:
PRO ONO (OR PUTY)
DEBORAH OCKER
320 EASY ROAD
CARLISLE, PA 17013
Plaintiffs address is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 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.
DEBORAH OCKER
Defendant
Case no: 08-6009 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, DEBORAH
OCKER 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, DEBORAH OCKER is not in the military service.
Further Affiant sayeth naught.
AFFIANT
SWORN T AND UBSCRIBED in my presence this Zs clay
of ovl;,?ll?22?d' .
COMM®NWEAI.TN eF PENN yL,VANIA
Noterial Seal
NO RY PUB WWm a Jones, Notary Public
City Of PtMburph, ANepheny County
My commission Expires June 28, 2010
Member, Pennsylvania Association of Notaries
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 Case #
DEBORAH OCKER
Defendant(s)
IMPORTANT NOTICE
TO: DEBORAH OCKER
320 EASY RD
CARLISLE, PA 1170)113
Date of Notice: I q I _
WWR#: 06432948
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 T.EN 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: :a uk_ trl ?bOZ
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
Military Status Report
Pursuant to the Servicemembers Civil Relief Act
Page 1 of 2
NOV-25-2008 05:46:29
`K Last Name First/Middle Begin Date Active Duty Status Service/Agency
OCKER 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.
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: httg://www.defenselink.mil/faq/Tis/PC09SLDR.htm1
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 11/25/2008
. Request for Military Status
Page 2 of 2
by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided.
Report ID: BMPABONML WF
https://www.dmdc.osd.mil/scra/owa/scra.prq_Select 11/25/2008
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO IN
Plaintiff
Vs.
DEBORAH OCKER
Defendant(s)
No. 08-6009 CIVIL TERM
PRAECIPE FOR SATISFACTION OF
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 Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7999
WWR#6432948 TSW
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
INTERNATIONAL PORTFOLIO IN
Plaintiff
vs. Civil Action No. 08-6009 CIVIL TERM
DEBORAH OCKER
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.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
James fh,PA brodt, Esquire
PA I.DWELTEINBERG & REIS CO., L.P.A.
1400 Kuilding
436 Se enue
Pittsbu 15219
(412) 434-7999
R 46432948
WW
Sworn to and subscribed
before me this
day of September, 09
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Notarial Seal P
VJayne A. Jones Notary 0110
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