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Home My WebLink About08-6011lc? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. TONY G GRIMES Defendant No. f 4 " ON/ &-1/1 / TIf m COMPLAINT IN CIVIL ACTION 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#6433083 4b IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No. TONY G GRIMES 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. 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 565 OPOSSUM LAKE 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, TONY G GRIMES, 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, TONY G GRIMES, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, TONY G GRIMES, in the amount of $2,216.73 as of JUNE 25 2008. ,4b 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, TONY G GRIMES, in the amount of $2,216.73 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. 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#:6433083 06/12/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 .4 CARLISLE REGIONAL MEDICAL CTR AS OF 06/11/08 361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 ----------------------------------------------------- PATIENT: GRIMES, TONY G F/C: P P/T: E A/C: 9351950 DSC CODE: 01 TO: GRIMES, TONY G ADMISSION: 10/16/06 DISCHARGE: 10/16/06 565 OPOSSUM LAKE RD CARLISLE PA 17013 DEPARTMENT AMOUNT 132.06 171.24 1,913.43 2,216.73- ------------------------------------------ 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 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. (Signature) WWR# C- n ?? _T_ -vet Qs ;: , . N SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-06011 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS GRIMES TONY G 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 GRIMES TONY G but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE NOT FOUND , as to the within named DEFENDANT , GRIMES TONY G 565 OPOSSUM LAKE RD CARLISLE, PA 17013 PER RESIDENT, DEFT MOVED OUT IN FEB. PER PO, MAIL IS DELIVERED TO GIVEN ADDRESS. HE CALLED & SAID HE WOULD PICK UP - NO SHOW. Sheriff's Costs: Docketing 18.00 Service 12.00 Not Found 5.00 Surcharge 10.00 00 ?1lIH/OS-? 45.00 So answers: R. Thomas/Kline Sheriff of Cumberland County WELTMAN WEINBERG REIS 10/30/2008 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. TONY G GRIMES Defendant(s) No. 08-6011 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE 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) 434-7955 WWR#6433083 TSW IN THE COAT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No. 08-6011 CIVIL TERM TONY G GRIMES Defendant(s) PRAECIPE TO SETTLE DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Kindly settle, discontinue and end without prejudice to refile the above-captioned matter upon the records of the Court and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By. __> James C. rmbrodt, Esquire PA I.D. 2 4 WELT AN WEINBERG & REIS CO., L.P.A. 1400 opp s Building 436S vet i Avenue Pitts ur , PA 15219 (41 4-7955 SWORN TO AND SUBSCRIBED before me this 714 day of T (An 009 NOT Y PUBL f,a(.)NWEALTH OF PENNSYLVANIA Notarial Seal „«;qne A. Jones, Notary Public City of Pittsburgh, Allegheny County 1Ay Commission Ex Ines June 29. 2010 -" - "nmvsZ.,n a ssociatlon of Notaries ALE'(D- OF TH," i. uU9 JLI ] 23 it ;10: ^',