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Home My WebLink About08-7502IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. COMPLAINT IN CIVIL ACTION NICKOLAS R JOHNSON 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#06431659 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No. NICKOLAS R JOHNSON 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 Plaintiff is a corporation with offices at 2171 NW 139 TERR,PEMBROKE PINES, FL 33028-0000 . 2. Defendant is an adult individual residing at 141 PEACH LN, 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. Defendant, NICKOLAS R JOHNSON, 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, NICKOLAS R JOHNSON, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, NICKOLAS R JOHNSON, in the amount of $1426.05 as of OCTOBER 22, 2008. 8. Plaintiff claims interest at the legal rate of six (6%) percent per annum from OCTOBER 22, 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, NICKOLAS R JOHNSON, in the amount of $1426.05 with continuing interest thereon at the rate of 6% per annum from OCTOBER 22, 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. MOL 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#:06431659 05/09/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 05/08/08 361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 PATIENT: JOHNSON, NICKOLAS R F/C: C P/T: O A/C: 7470095 DSC CODE: O1 T0: JOHNSON, NICKOLAS R ADMISSION: 02/22/05 DISCHARGE: 02/22/05 296 FOX HOLLOW RD SHERMANSDALE PA 17090 INS CD: 120/PHC AMERIHEALTH ADMIN GROUP 094736 POL ID: 013784167 D E P A R T M E N T A M O U N T 4n~ nnr'n-^^'T•'~' - - 7, 349.24 1,418.20 785.38 118.86 1,879.77 1, 746.63 2,700.00 140.00 11,484.41- 4,653.67- ----------------------------------------------------------------------------- TOTAL 0.00 SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY= CMD:l=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. (Signature) WWR# ~'~ji l.~'tT ~ ~M W ~~ n V/ ~`\ ~~ c F`~ ~~ -~- T., ~ r~a ~~ c-3 r..~j c--~ ~~ ~.1~ "i_7 ~`J ~`Y~ -~ ~i -~ ~~ #t.~~ -F? t-p -~ ; it "~ ~~ _• SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-07502 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS JOHNSON NICKOLAS R 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 JOHNSON NICKOLAS R but was unable to locate Him in his bailiwick. He therefore returns the _ _~ _ ~ _ ~ _'., ,. , T,.m T „T, the within named DEFENDANT l4l PRACH LANE CARLISLE, PA 17013 PT?R C~'TTRRRNT OWNER, DEFENDANT MOVED OUT 3 YEARS AGO. Sheriff's Costs: Docketing Service Not Found Surcharge So answers : ~.--"- ~~-' 18.00 5.40 5.00 R. T mas Kline 10.00 Sheriff of Cumberland County .00 38.40 WELTMAN WEINBERG REIS 01/02/2009 Sworn and Subscribed to before me this day of NOT FOUND as to T/1TTTTC~/lTT MTnT7(IT.TC A A.D. c.,_ ~~ ~,