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Home My WebLink About08-7510v ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. No. O g - ^1'S'!O Plaintiff VS. COMPLAINT IN CIVIL ACTION JAIME ACUNA 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#6433009 r % IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. JAIME ACUNA 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 56 WILSON ST 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, JAIME ACUNA, 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, JAIME ACUNA, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, JAIME ACUNA, in the amount of $1,335.39 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, JAIME ACUNA, in the amount of $ 1,335.39 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#:6433009 06/12/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 AS OF 06/11/08 CARLISLE REGIONAL MEDICAL CTR PA 17015 PHONE (717) 960-1680 ---- 361-ALEXANDER-SPRING-RD-- CARLISLE ---------------------------------------- PATIENT: ACUNA, JAIME F/C-. P P/ E 9318457 DSC CODE: 01 ADMISSION: 08/17/05 DISCHARGE: 08/17/05 T0: ACUNA, JAIME A M O U N T 56 WILSON ST CARLISLE PA 17013 „ z• v a u m E N T 304.35 54.85 390.66 11.98 573.55 j 1,335.39- -------- - ---------------------------------------- TOTAL 0.00 SELECT: REV= * * DEPT= * CHGCD= * DATE/MDCY= * TO/MD_ CMD:I=DAR,2=PAT 4=DETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD ?HX3 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. 4 .) 0,A'k (Signature) WWR# OL?Az t'_ ? =rt OD cA ? ?ti ,r, r i w 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-07510 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS ACUNA JAIME NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ACUNA JAIME the DEFENDANT , at 1710:00 HOURS, on the 31st day of December , 2008 at 56 WILSON STREET CARLISLE, PA 17013 by handing to ROSARIO ACUNNA, WIFE 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 Service Affidavit Surcharge Sworn and Subscibed to before me this of So Answers: 18.00 4.50 .00 of 10.00 R. Thomas Kline .00 32.50 01/02/2009 WELTMAN WEINBERG REIS By: day Deputy Sheriff , A.D. ° 'Ab IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. No.08-7510-CIVIL TERM PRAECIPE FOR ENTRY OF JUDGMENT BY CONSENT JAIME ACUNA 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 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6433009 $1,335.39 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. JAIME ACUNA Defendant Civil Action No. 08-7510-CIVIL TERM PRAECIPE FOR JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment against Defendant, JAIME ACUNA , in the amount of $1,335.39 plus costs, based upon the consent of the parties. CONSENTED TO: WELTMAN, WEINBERG & REIS CO., L.P.A., By: ?- Attey for Plaintiff JAIME ACUNA , By: Defendant WWR#6433009 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. 08-7510-CIVIL TERM JAIME ACUNA 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 Defendant, JAIME ACUNA , above-named, in the amount of $1,335.39 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment by Consent, as follows: Defendant admits indebtedness to Plaintiff in the amount of $1,335.39 with continuing interest thereon at a rate of 6.00% per annum plus costs from February 18, 2009. 2. To secure the repayment of said indebtedness, Defendant agrees that Judgment by Consent will be entered in favor of the Plaintiff and against the Defendant, JAIME ACUNA.. in the amount of $1,335.39 plus continuing interest thereon at the rate of 6.00% per annum from February 18, 2009 and costs. 3. Plaintiff agrees not to execute on its Judgment so long as Defendant causes to be delivered to Plaintiff the following payments in full by 12:00 NOON on the following dates: (a) Defendant will pay a settlement amount of $650.00 at $75.00 a month beginning March 15, 2009; (b) If Defendant pays that amount in a timely fashion Plaintiff agrees to file a satisfaction of judgment (c) If Defendant fails to pay as agreed, Defendant will owe amount of judgment less any payments made plus accrued interest and costs. 4. All payments are to be made payable to the order of "INTERNATIONAL PORTFOLIO INC." The first payment due under this agreement is to be received at the offices of Weltman, Weinberg & Reis, Co., L.P.A., 436 Seventh Avenue, Suite 1400, 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 should the Defendant 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. 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 thv?l lday of L 20 07 . WELTMAN, WEINBERG & REIS CO., L.P.A. By: hew D. Urban, Esquire A I.D. 90963 Weltman, Weinberg & Reis Co., L.P.A 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 6433009 i' Defendant, JAIME ACUNA w C . ti cr, r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. 08-7510-CIVIL TERM JAIME ACUNA 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 1jj?0lI (xx) Assumpsit Judgment in the amount of $1,335.39 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 JAIME ACUNA 56 WILSON ST CARLISLE,PA 17013 By: le:xw PRO ONOTARY UTY) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. 08-7510-CIVIL TERM JAIME ACUNA 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 3l /U/0_ (xx) Assumpsit Judgment in the amount of $1,335.39 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 Stephanie Chertok, Esquire 61 West Louther Street Carlisle, PA 17013 By: PR ONOT OR D UTY) PA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. JAIME ACUNA Defendant(s) No. 08-7510 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#6433009 TSW I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No. 08-7510 CIVIL TERM JAIME ACUNA 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. Esquire Building 436 Sev Avenue Pittsbu PA 15219 (412) 434-7999 By: James C. W PA I.D. # 4' WELTM 1400 Ko p & REIS CO., L.P.A. WWR #6433009 Sworn to and subscribed before me this 30 day of October, 09 j4y -NOTARY PUBLIC CC G?-, +`N-.A ri'I OF PENNVLV.A^ - Notarial Seal Sneiia G. Bevan, Notary Public City Of Pittsburgh, kegheny County My Commission, Expires Nov. 15, 2010 l Member, Pennsylvania Association of Notaries 7 FILED-4 a=Fir,;E 2009 NOY 20 PH 3: 40 cutvii?- v11' PE SYLVA-,',fi Ig.0-:b ?,L P, e? gpao( of a3a??a