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HomeMy WebLinkAbout08-7511 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff No. 0s - 7S'!( VS. CHRISTOPHER K STRUCHEN Defendant COMPLAINT IN CIVIL ACTION 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#06603941 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. CHRISTOPHER K STRUCHEN 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 300 CORNMAN 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, CHRISTOPHER K STRUCHEN, 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, CHRISTOPHER K STRUCHEN, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, CHRISTOPHER K STRUCHEN, in the amount of $5580.32 as of OCTOBER 10, 2008. 8. Plaintiff claims interest at the legal rate of six (6%) percent per annum from OCTOBER 10, 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, CHRISTOPHER K STRUCHEN, in the amount of $5580.32 with continuing interest thereon at the rate of 6% per annum from OCTOBER 10, 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. Z. WILLIAM T. MZAN, 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#:06603941 08/22/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES '--)AI-7 COID: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 08/21/08 361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 ---- ------- ---------------------------------------- PATIENT: STRUCHEN, CHRISTOPHER K F/C: P P/T: E A/C: 9349608 DSC CODE: 01 TO: STRUCHEN, CHRISTOPHER K ADMISSION: 09/18/06 DISCHARGE: 09/18/06 16 WESTMINSTER COURT CARLISLE PA 17013 D E P A R T M E N T A M O U N T 167.90 71.03 316.54 2,239.12 423.71 390.66 140.00 1,831.36 5,580.32- ------------------------------------------ TOTAL 0.00 SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY= CMD:I=DAR,2=PAT 4=DETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD EXHIBIT 1 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) WWR# OU QUY61 d w ?J ? iN ft -a c-? Czo 0 3 _.a a 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-07511 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS STRUCHEN CHRISTOPHER K MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE gTRUCHEN CHRISTOPHER K was served upon DEFENDANT the at 2100:00 HOURS, on the 30th day of December , 2008 at CUMBERLAND COUNTY PRISON CARLISLE, PA 17013 CHRISTOPHER STRUCHEN by handing to 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 14.40 Affidavit .00 Surcharge 10.00 .00 42.40 Sworn and Subscibed to before me this day 1101 CLAREMONT ROAD So Answers: R. Thomas Kline 12/31/2008 WELTMAN WEINBERG REI By: L Deputy Sheriff of A. D. v °°C'Y 77 IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff No. 0g Olswel2 Vs CIVIL ACTION CHRISTOPHER K. STRUCHEN Defendant FILED ON BEHALF OF Defendant BY POWER OF ATTORNEY: Claudette A. Fortman 47 North East Street Apartment 1 Carlisle, PA 17013 (717) 386-6913 IN THE COURT OF COMMON PLEASE CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff Vs. Civil Action No. CHRISTOPHER K. STRUCHEN Defendant NOTICE OF ANSWER Defendant has been duly served with complaint and notice and is entering the following response: 1. Defendant acknowledges receiving and accepting the medical services as described in complaint. 2. Defendant's current address is Torrence State Mental Hospital Unit C 1 PO Box B Torrance, PA 15779 were he shall remain until such time that he is deemed no longer a threat to himself. 3. That upon release from Torrence State Mental Hospital, defendant will be returned to the care and custody of Cumberland County Prison 1101 Claremont Rd Carlisle, PA 17013 until such time that pending criminal charges against him are adjudicated. 4. That until his release, defendant has no resources to pay said debt. VERIFICATION The undersigned does verify subject to the penalties of 18 PA.C.S. §4904 relating to unworn falsifications to authorities, that she is Claudette A. Fortman who has Power of Attorney to act in behalf of Christopher K. Struchen and that such document is attached to response. (Signature) NOTICE THE PURPOSE OF THIS POWER OF ATTORNEY IS TO GIVE THE PERSON YOU DESIGNATE YOUR AGENT, CLAUDETTE A. FORTMAN, BROAD POWERS TO HANDLE YOUR PROPERTY, WHICH MAY INCLUDE POWERS TO SELL OR OTHERWISE DISPOSE OF ANY REAL OR PERSONAL PROPERTY WITHOUT ADVANCE NOTICE TO YOU OR APPROVAL BY YOU. THIS POWER OF ATTORNEY DOES NOT IMPOSE A DUTY ON YOUR AGENT TO EXERCISE GRANTED POWERS, BUT WHEN POWERS ARE EXERCISED, YOUR AGENT MUST USE DUE CARE TO ACT FOR YOUR BENEFIT AND IN ACCORDANCE WITH THIS POWER OF ATTORNEY. YOUR AGENT MAY EXERCISE THE POWERS GIVEN HERE THROUGHOUT YOUR LIFETIME, EVEN AFTER YOU BECOME INCAPACITATED, UNLESS YOU EXPRESSLY LIMIT THE DURATION OF THESE POWERS OR YOU REVOKE THESE POWERS OR A COURT ACTING ON YOUR BEHALF TERMINATES YOUR AGENTS AUTHORITY. YOUR AGENT MUST KEEP YOUR FUNDS SEPARATE FROM YOUR AGENTS FUNDS. A COURT CAN TAKE AWAY THE POWERS OF YOUR AGENT IF IT FINDS YOUR AGENT IS NOT ACTING PROPERLY. THE POWERS AND DUTIES OF AN AGENT UNDER A POWER OF ATTORNEY ARE EXPLAINED MORE FULLY IN 20 PA.C.S. CH. 56. IF THERE IS ANYTHING ABOUT THIS FORM THAT YOU DO NOT UNDERSTAND, YOU SHOULD ASK A LAWYER OF YOUR OWN CHOOSING TO EXPLAIN IT TO YOU. I HAVE READ OR HAD EXPLAINED TO ME THIS NOTICE AND I UNDERSTAND ITS CONTENTS. Date Christopher K S Chen, Principal ACKNOWLEDGEMENT BY AGENT I, Claudette A. Fortman, have read the attached power of attorney and am the person identified as the agent for the principal. I hereby acknowledge that in the absence of a specific provision to the contrary in the power of attorney or in Title 24 of the Pennsylvania Consolidated Statutes when I act as agent: I shall exercise the powers for the benefit of the principal. I shall keep the assets of the principal separate from my assets. I shall exercise reasonable caution and prudence. I shall keep a full and accurate record of all actions, receipts and disbursement on behalf of the principal. P. Al If a /0'f -- , - 4 ? Date Claudette A. Fortman 2 GENERAL DURABLE POWER OF ATTORNEY KNOW ALL MEN BY THESE PRESENTS, that I, 'Christopher K. Struchen, do hereby appoint, my mother, Claudette A. Fortman, of 47 North East Street, Apt. 1, Carlisle, Cumberland County, Pennsylvania 17013, my true and lawful Attorney-In-Fact, for me and in my name, place and stead, and for my use and benefit; 1. To ask, demand, sue for, recover, collect, and receive all sums of money, debts, dues, accounts, legacies, bequests, interest, dividends, annuities, goods, merchandise, chattels, effects, things of whatsoever nature and demands whatsoever as are now or shall hereafter become due, owing, pavable or belonging to me in or by anylight whatsoever, including but not limited to by this reference amounts due from the Social Security Administration, the Internal Revenue Service or the Pennsylvania Department of Revenue, and to have, use, and take all lawful ways and means in my name or otherwise for the recovery thereof, by attachments, arrests, distress, or otherwise, and to compromise and agree to the same and to give acquittance or other sufficient discharges for the same, and upon receipts, releases or other discharges for the same respectively as she shall think fit. 2. To deposit any monies which may come into her hands as such attorney with any bank or banker, either in my or her own name, and any of such money or any other money to which I am entitled which now is or shall be so deposited to withdraw as she shall think fit; to sign mutual savings banks and federal savings and loan association withdrawal orders; to sign and endorse checks payable to my order and to draw, accept, make, endorse, discount, or otherwise deal with any bills of exchange,' checks, promissory notes or other commercial or mercantile instruments; to borrow any sum or sums on such terms and with such security as she may think fit and for that purpose, to execute all notes or other instruments which may be necessary or proper; and to have access to any and all safe deposit boxes registered in my name. 3. To sell, assign, transfer and dispose of any and all stocks, bonds, including U.S. Savings Bonds, loans, mortgages, or other securities registered in my name; and to collect and receipt for all interest and dividends due and payable to me. 4. To invest in my name in any stock, shares, bonds, securities or other property, real or personal, and to vary such investments as she, in her sole discretion, may deem best; and to vote at meetings of shareholders or other meetings of any corporation or company and to execute any proxies or other instruments in connection therewith. 3 5. To sell, either at public or private sale, or exchange any part or parts of my personal property for such consideration and upon such terms as she shall think fit, and to execute and deliver good and sufficient deeds or other instruments for the conveyance or transfer of the same, with such covenants or warranty or otherwise as she shall sees fit, and to give good and effectual receipts for all or any part of the purchase price or other consideration. 6. To commence, prosecute, discontinue or defend all actions or other legal proceedings touching my estate or any part whatsoever, or touching any matter in which I or my estate may be concerned; to settle, compromise, or submit to arbitration any debt, demand or other right or matter due me or concerning my estate as he, in her sole discretion, shall deem best and for such purpose to execute and deliver such releases, discharges or other instruments as she may deem necessary and advisable; and to satisfy mortgages, including the execution of a good and sufficient, release, or other discharge of such mortgage. 7. To execute, acknowledge and file Federal, State and Local Income Tax and Personal Tax Returns, and to contest or appeal any assessment of my real property for purposes of ad valorem taxation of such property. 8. To engage, employ and dismiss any agents, clerks, servants, attorneys, accountants, financial advisors, tax consultants, insurance consultants or other persons as she, in her sole discretion, shall deem necessary and advisable. 9. Notwithstanding any limitations otherwise herein relating to the power to grant, to sell or 1 convey any real estate which I may have an interest, to create a trust for my benefit and to make additions to an existing trust for my benefit, to withdraw and receive for my benefit the income or corpus of any trust and to effectuate any fund any trust made to my benefit, to execute a deed or trust for such purpose designating one or more persons, including herself as the original or successor trustees, or to make any additions to an existing trust consistent with the provisions of the Pennsylvania Probates, Estates and Fiduciaries Code, as amended. 10. To authorize my admission to a medical, nursing, residential or similar facility, execute any consent or admission forms required by such facility which are consistent with this paragraph, and enter such agreements for the care of the principal by such facility or elsewhere during her lifetime or for such lesser period of time the Agent may designate, including retention of nurses for principal. I authorize and direct my physician, health care professional, health care provider and medical care facility to provide my Agent information relating to my physical and mental condition and the diagnosis, prognosis, care and treatment thereof upon the request of my Agent. It is my intention that this authorization for my Agent to be considered a personal representative under privacy regulations related to protected health information and for my Agent to be entitled to all health information in the same as if I personally were making the request. This authorization and direction shall also be considered a consent to the release of information under current and future regulations, laws and rules, including but not limited to, the express grant of authority to personal representatives as provided Regulation Section 164.502(8) of Title 45 of the Code of Federal Regulations and the medical information privacy law and regulations generally referred to as HIPPA. 11. To authorize or to refrain from authorizing medical and surgical procedures including arranging for and consenting to or refusing to authorize or accept medical, therapeutical and surgical procedures and/or treatment for me including the administration of drugs and to execute any consent, release or admission forms required by the provider of such medical, therapeutic or surgical procedures, as she, in her judgment, sees fit for my best interest, benefit or care, consistent with my wishes and desires for such medical, therapeutic or surgical care as I have made known to her. 12. In general, to do all other acts, deeds, matters whatsoever in or about my person, estate, property and affairs and things herein, either particularly or generally described, as fully and effectually to all intents and purposes as I could do in my own proper person if personally present or capable of undertaking, giving to my said attorney power to make and substitute under her an attorney or attorneys for all the purposes herein described as she, in her sole discretion, deems fit and in my best interest, hereby ratifying and confirming all that the said attorney or substitutes shall do by virtue of these presents. 13. In addition to the powers and discretion herein specifically given and conferred upon her, and notwithstanding any usage or custom to the contrary, to have full power, right and authority to do, perform and to cause to be done and performed all such acts, deeds, matters and things in connection with my person, property and estate as she, in her sole discretion, shall deem reasonable, necessary and proper, as fully, effectually and absolutely as if she were the absolute owner and possessor thereof. This is a durable Power of Attorney as specified in the Pennsylvania Probates, Estates and Fiduciaries Code, as amended, and this Power of Attorney shall not be affected by my subsequent disability or incapacity and all acts done by my Attorney-In-Fact pursuant to this durable Power of Attorney during any period of my disability or incapacity shall have the same effect and inure to my . , h benefit and bind me and my successors in interest as if it were done at a time when I was competent and not disabled. In the event I am adjudicated an incompetent person, it is my desire that the Court rendering such adjudication appoint my Attorney-In-Fact, Claudette A. Fortman, as the guardian of my estate and my person unless she be otherwise disqualified, unable or unwilling to serve in such capacity. IN WITNESS WHEREOF, I have hereunto signed my name and seal this / day of /",ld4t, 4 , 2008. Witness: tA4,_ j Christopher K. Struchen, Principal ACKNOWLEDGMENT COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF ALLEGHENY ) +ti On this, the 8 day of A" a.5 - , 2008, before me, the undersigned officer, personally appeared, Christopher,K. Struchen, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he voluntarily executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. NrrrMr? OIrM K DM?w?, MMr??yMMc cam (Signature & Seal of N ry_ Public, officer or Attorney and, if Attorney, Attorney's state of admission and Supreme Court Identfication Number) NoiMlr f>w WAft k rdpro, No1MfFI ? i CD ?.? t ;.may Ul IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC, Plaintiff, vs. Case No.: 08-7511 CIVIL TERM MOTION FOR SUMMARY JUDGMENT CHRISTOPHER K STRUCHEN, Defendant. MOTION FOR SUMMARY JUDGMENT AND NOW COMES, Plaintiff, by and through its counsel, Weltman, Weinberg & Reis, Co., L.P.A., and hereby files this Motion for Summary Judgment against the Defendant. In support thereof, Plaintiff avers as follows: 1. Plaintiff filed a Complaint against Defendant seeking judgment in the amount of $5580.32 with interest at the interest rate of 6.00% per annum from October 10 2008, and costs. A true and correct copy of the Complaint is attached hereto as Exhibit "A" and made a part hereof. 2. Attached to the Complaint was Verification from an authorized representative of Plaintiff verifying the accuracy of the amount sought. See Exhibit "A". 3. Defendant filed an Answer to Plaintiff's Complaint. A true and correct copy of the Answer is attached hereto as Exhibit "B" and made a part hereof. 4. On or around June 15 2009, Plaintiff served upon Defendant a set of requests for admissions and requests for production of documents. A true and correct copy of the same is attached hereto as Exhibit "C" and made a part hereof. 5. No response to the discovery demands has been received from the Defendant. 6. The requests for admissions are now deemed admitted under Pennsylvania Rule of Civil Procedure 4014(b). Thus Defendant has admitted that he has made no payment on the account since September 18 2006; that the statement attached to Plaintiffs Discovery Request correctly identify the W WR No. 6603941 payments, charges, and balances on the account; that he has not submitted any written disputes as to billing inaccuracies; and that $5580.32 is a correct and accurate balance on the credit card account. 7. By way of his Answer, the documents attached to this Motion, and the Requests for Admissions, deemed admitted under Pa.R.C.P. 4014(b), the Defendant has admitted all facts material to this matter and verified the amount owed. 8. There are no meritorious defenses against this action and Plaintiff is entitled to summary judgment as a matter of Law against defendant. WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant summary judgment in favor of Plaintiff and against Defendant for $5580.32 with interest at the legal interest rate of 6.00% per annum from October 10 2008, and costs. Respectfully Submitted: By: Benja i B r squire Pa. I.D. 935 8 Weltman, einberg & Reis, Co. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 6603941 IN THE COURT OF COMMON PLEAS O CIVIL MBE AND COUNTY, PENNSYLVANIA DIVISI INTERNATIONAL PORTFOLIO INC. Plaintiff vs. CHRISTOPHER K STRUCHEN Defendant No. COMPLAINT IN CIVIL ACTION 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#06603941 E,, IN THE COURT OF COMMON PLEAS CUMS AND COUNTY, PENNSYLVANIA p INTERNATIONAL PORTFOLIO INC. Plaintiff Civil Action No. VS. CHRISTOPHER K STRUCHEN 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 without noti proceed without you and a judgment may be entihd cgailm or relief quest d by the plaint ff. You ay any money claimed in the complaint or for any o lose money or property or other rights important to you. GO LAWYER AT ONCE. IF YOU YOU SHOULD TAKE THIS PAPER TON YOUR TELEPHONE THE OFFICOE SOFT HAVE A LAWYER OR CANNOT AFFORD 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 300 CORNMAN 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, CHRISTOPHER K STRUCHEN, 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, CHRISTOPHER K STRUCHEN, agreed. to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, CHRISTOPHER K STRUCHEN, in the amount of $5580.32 as of OCTOBER 10, 2008. 8. Plaintiff claims interest at the legal rate of six (6%) percent per annum from OCTOBER 10, 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, CHRISTOPHER K STRUCHEN, in the amount of $5580.32 with continuing interest thereon at the rate of 6% per annum from OCTOBER 10, 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. MVCZAN, Esquire PA I.D. 947437 / WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#:06603941 08/22/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES' DA17 COID: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 08/21/08 361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 ---- ------- ----------------------------------------------------------------- PATIENT: STRUCHEN, CHRISTOPHER K AF/C: PONP/0: E A/C: -9349608RGEC ODE: 001 6 TO: STRUCHEN, CHRISTOPHER K 16 WESTMINSTER COURT CARLISLE PA 17013 A M O U N T DE P A R T M E N T 167.90 71.03 316.54 2,239.12 423.71 390.66 140.00 1,831.36 5,580.32- ---------------- ---------------------- - -------- TOTAL 0.00 SELECT: REV= * DEPT= * CHGCD= * TO/MDCY= CMD:I=DAR,2=PAT 4=DETAIL EXHIBIT VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 (?e) relating to unworn falsifications to authorities, that she is GAIL WO (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# OU L9 T IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff Vs No. Ott 0 11 1 Awv5ale2 :(CIVIL ACTION CHRISTOPHER K. STRUCHEN Defendant FILED ON BEHALF OF Defendant BY POWER OF ATTORNEY: Claudette A. Fortman 47 North East Street Apartment I Carlisle, PA 17013 (717) 386-6913 C" C .? r 1 IN THE COURT OF COMMON PLEASE CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff Vs. Civil Action No. CHRISTOPHER K. STRUCHEN Defendant NOTICE OF ANSWER Defendant has been duly served with complaint and notice and is entering the following response: 1. Defendant acknowledges receiving and accepting the medical services as described in complaint. 2. Defendant's current address is T®rrence State Mental Hospital Unit C1 PO Box B Torrance, PA 15779 were he shall remain until such time that he is deemed no longer a threat to himself. 3. That upon release from Torrence State Mental Hospital, defendant will be returned to the care and custody of Cumberland County Prison 1101 Claremont Rd Carlisle, PA 17013 until such time that pending criminal charges against him are adjudicated. 4. That until his release, defendant has no resources to pay said debt. VERIFICATION The undersigned does verify subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsifications to authorities, that she is Claudette A. Fortman who has Power of Attorney to act in behalf of Christopher K. Struchen and that such document is attached to response. (Signature) NOTICE THE PURPOSE OF THIS POWER OF ATTORNEY IS TO GIVE THE PERSON YOU DESIGNATE YOUR AGENT, CLAUDETTE A. FORTMAN, BROAD POWERS TO HANDLE YOUR PROPERTY, WHICH MAY INCLUDE POWERS TO SELL OR OTHERWISE DISPOSE OF ANY REAL OR PERSONAL PROPERTY WITHOUT ADVANCE NOTICE TO YOU OR APPROVAL BY YOU. THIS POWER OF ATTORNEY DOES NOT IMPOSE A DUTY ON YOUR AGENT TO EXERCISE GRANTED POWERS, BUT WHEN POWERS ARE EXERCISED, YOUR AGENT MUST USE DUE CARE TO ACT FOR YOUR BENEFIT AND !N ACCORDANCE WITH THIS POWER OF ATTORNEY. YOUR AGENT MAY EXERCISE THE POWERS GIVEN HERE THROUGHOUT YOUR LIFETIME, EVEN AFTER YOU BECOME INCAPACITATED, UNLESS YOU EXPRESSLY LIMIT THE DURATION OF THESE POWERS OR YOU REVOKE THESE POWERS OR A COURT ACTING ON YOUR BEHALF TERMINATES YOUR AGENT'S AUTHORITY. YOUR AGENT MUST KEEP YOUR FUNDS SEPARATE FROM YOUR AGENT'S FUNDS. A COURT CAN TAKE AWAY THE POWERS OF YOUR AGENT IF IT FINDS YOUR AGENT IS NOT ACTING PROPERLY. THE POWERS AND DUTIES OF AN AGENT UNDER A POWER OF ATTORNEY ARE EXPLAINED MORE FULLY iN 20 PA.C.S. CH. 56. IF THERE IS ANYTHING ABOUT THIS FORM THAT YOU DO NOT UNDERSTAND, YOU SHOULD ASK A LAWYER OF YOUR OWN CHOOSING TO EXPLAIN IT TO YOU. I HAVE READ OR HAD EXPLAINED TO ME THIS NOTICE AND I UNDERSTAND ITS CONTENTS. ??-1 -v? Date Christopher K Sti Chen, Principal ACKNOWLEDGEMENT BY AGENT I, Claudette A. Fortman, have read the attached power of attorney and am the person identified as the agent for the principal. I hereby acknowledge that in the absence of a specific provision to the contrary in the power of attorney or in Title 20 of the Pennsylvania Consolidated Statutes when I act as agent: I shall exercise the powers for the benefit of the principal. I shall keep the assets of the principal separate from my assets. I shall exercise reasonable caution and prudence. I shall keep a full and accurate record of all actions, receipts and disbursement on behalf of the principal. - rv a ? 16 Date Claudette A. Fortman 2 GENERAL DURABLE POWER OF ATTORNEY KNOW ALL MEN BY THESE PRESENTS, that I, Christopher K. Struchen, do hereby appoint, my mother, Claudette A. Fortman, of 47 North East Street, Apt. 1, Carlisle, Cumberland County, Pennsylvania 17013, my true and lawful Attorney-In-Fact, for me and in my name, place and stead, and for my use and benefit; 1. To ask, demand, sue for, recover, collect, and receive all sums of money, debts, dues, accounts, legacies, bequests, interest, dividends, annuities, goods, merchandise, chattels, effects, things of whatsoever nature and demands whatsoever as are now or shall hereafter become due, owing, -payable or belonging to me in or by any right whatsoever, including but not limited to by this reference amounts due from the Social Security Administration, the Internal Revenue Service or the Pennsylvania Department of Revenue, and to have, use, and take all lawful ways and means in my name or otherwise for the recovery thereof, by attachments, arrests, distress, or otherwise, and to compromise and agree to the same and to give acquittance or other sufficient discharges for the same, and upon receipts, releases or other discharges for the same respectively as she shall think fit. 2. To deposit any monies which may come into her hands as such attorney with any bank or banker, either in my or her own name, and any of such money or any other money to which I am entitled which now is or shall be so deposited to withdraw as she shall think fit; to sign mutual savings banks and federal savings and loan association withdrawal orders; to sign and endorse checks payable to my order and to draw, accept, make, endorse, discount, or otherwise deal with any bills of exchange, checks, promissory notes or other commercial or mercantile instruments; to borrow any sum or sums on such terms and with such security as she may think fit and for that purpose, to execute all notes or other instruments which may be necessary or proper; and to have access to any and all safe deposit boxes registered in my name. 3. To sell, assign, transfer and dispose of any and all stocks, bonds, including U.S. Savings Bonds, loans, mortgages, or other securities registered in my name; and to collect and receipt for all interest and dividends due and payable to me. 4. To invest in my name in any stock, shares, bonds, securities or other property, real or personal, and to vary such investments as she, in her sole discretion, may deem best; and to vote at meetings of shareholders or other meetings of any corporation or company and to execute any proxies or other instruments in connection therewith. 5. To sell, either at public or private sale, or exchange any part or parts of my personal property for such consideration and upon such terms as she shall think fit, and to execute and deliver good and sufficient deeds or other instruments for the conveyance or transfer of the same, with such covenants or warranty or otherwise as she shall sees fit, and to give good and effectual receipts for all or any part of the purchase price or other consideration. 6. To continence, prosecute, discontinue or defend all actions or other legal proceedings touching my estate or any part whatsoever, or touching any matter in which I or my estate may be concerned; to settle, compromise, or submit to arbitration any debt, demand or other right or matter duel me or concerning my estate as he, in her sole discretion, shall deem best and for such purpose to and deliver such releases, discharges or other instruments as she may deem tee: es?ary and advisable; and to satisfy mortgages, including the execution of a good and sufficient, release, or other discharge of such mortgage. 7. To execute, acknowledge and file Federal, State and Local Income Tax and Personal Tax Returns, and to contest or appeal any assessment of my real property for purposes of ad valorem taxation of such property. 8. To engage, employ and dismiss any agents, clerks, servants, attorneys, accountants, financial advisors, tax consultants, insurance consultants or other persons as she, in her sole discretion, shall deem necessary and advisable. 9. Notwithstanding any limitations otherwise herein relating to the power to grant, to sell or convey any real estate which I may have an interest, to create a trust for my benefit and to make additions to an existing trust for my benefit, to withdraw and receive for my benefit the income or corpus of any trust and to effectuate any fund any trust made to my benefit, to execute a deed or trust for such purpose designating one or more persons, including herself as the original or successor trustees, or to make any additions to an existing trust consistent with the provisions of the Pennsylvania Probates, Estates and Fiduciaries Code, as amended. 10. To authorize my admission to a medical, nursing, residential or similar facility, execute any consent or admission forms required by such facility which are consistent with this paragraph, and enter such agreements for the care of the principal by such facility or elsewhere during her lifetime or for such lesser period of time the Agent may designate, including retention of nurses for principal. I authorize and direct my physician, health care professional, health care provider and medical care facility to provide my Agent information relating to my physical and mental condition and the diagnosis, prognosis, care and treatment thereof upon the request of my Agent. It is my intention that this authorization for my Agent to be considered a personal representative under privacy regulations related to protected health information and for my Agent to be entitled to all health information in the same as if I personally were making the request. This authorization and direction shall also be considered a consent to the release of information under current and future regulations, laws and rules, including but not limited to, the express grant of authority to personal representatives as provided Regulation Section 164.502(g) of Title 45 of the Code of Federal Regulations and the medical information privacy law and regulations generally referred to as HIPPA. 11. To authorize or to refrain from authorizing medical and surgical procedures including arranging for and consenting to or refusing to authorize or accept medical, therapeutical and surgical procedures and/or treatment for me including the administration of drugs and to execute any consent, release or admission forms required by the provider of such medical, therapeutic or surgical procedures, as she, in her judgment, sees fit for my best interest, benefit or care, consistent with my wishes and desires for such medical, therapeutic or surgical care as I have made known to her. 12. In general, to do all other acts, deeds, matters whatsoever in or about my person, estate, property and affairs and things herein, either particularly or generally described, as fully and effectually to all intents and purposes as I could do in my own proper person if personally present or capable of undertaking, giving to my said attorney power to make and substitute under her an attorney or attorneys for all the purposes herein described as she, in her sole discretion, deems fit and in my best interest, hereby ratifying and confirming all that the said attorney or substitutes shall do by virtue of these presents. 13. In addition to the powers and discretion herein specifically given and conferred upon her, and notwithstanding any usage or custom to the contrary, to have full power, right and authority to do, perform and to cause to be done and performed all such acts, deeds, matters and things in connection with my person, property and estate as she, in her sole discretion, shall deem reasonable, necessary and proper, as fully, effectually and absolutely as if she were the absolute owner and possessor thereof. This is a durable Power of Attorney as specified in the Pennsylvania Probates, Estates and Fiduciaries Code, as amended, and this Power of Attorney shall not be affected by my subsequent disability or incapacity and all acts done by my Attomey-In-Fact pursuant to this durable Power of Attorney during any period of my disability or incapacity shall have the same effect and inure to my benefit and bind me and my successors in interest as if it were done at a time when I was competent and not disabled. In the event I am adjudicated an incompetent person, it is my desire that the Court rendering such adjudication appoint my Attorney-In-Fact, Claudette A. Fortman, as the guardian of my estate and my person unless she be otherwise disqualified, unable or unwilling to serve in such capacity. IN WITNESS WHEREOF, I have hereunto signed my name and seal this day of A6-t, -? ?- , 2008. iVitr_ess: ,? iCY•I. ? ,tom C ,... ? .. CCJJ Christopher K. Struchen, Principal ACKNOWLEDGMENT COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY SS: On this, the 18 day of Act a 5 -/ , 2008, before me, the undersigned officer, personally appeared, Christopher,K. Struchen, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he voluntarily executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. TH OF PENNBYLVAN A NOW aad Diana M. Datlono, Nolary.Nuble tiMutl i (Signature & Seal of N tary Public, officer or Attorney and, if Attorney, Attorney's state of admission and Supreme Court Identification Number) 7H of PENNSYLVANIA MAIM Anal u'Diane M. Dallow, Notary-public A WA, WA, Fr1y61% 'I. WM"7 _Cni,JWW ' E Al.1 OF PENt?SYI-VANWI IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION INTERNATIONAL PORTFOLIO INC, Plaintiff, V. NO.: 08-7511 CIVIL TERM CHRISTOPHER K STRUCHEN Defendant. PLAINTIFF'S FIRST REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION OF DOCUMENTS Plaintiff demands that the defendants answer and respond to the following Request for Production of Documents under oath pursuant to the Pennsylvania Rules of Civil Procedure within 30 days from the date of service hereof. Plaintiff also demands that defendants answer and respond to the following Request for Admissions pursuant to Pa. Rules of Civil Procedure 4014. You are requested to admit the truth of each of the statements of fact hereinafter stated. You are instructed that: 1. These requests are made under Pennsylvania Rules of Civil Procedure 4001, et seq., and each of these matters of which an admission is requested shall be deemed admitted unless your sworn statement in compliance with such Rules is timely made. 2. If you do not admit each of such statements, you must specifically deny each one not admitted or set forth in detail the reasons why you cannot truthfully either admit or deny each such matter. 3. Your answer, signed and properly verified, must be delivered to the undersigned attorney of record for the Plaintiff within thirty (30) days after delivery hereof. 4. If you fail or refuse to admit the truth of any such statement of fact and the Plaintiff thereafter proves the truth thereof, you may be required to pay the reasonable expenses incurred in making such proof, including attorneys' fees, witness expenses, etc. 5. If, in response to any of the following statements of fact, it is your position that the statement is true in part or as to some items, but not true in full or as to all items, then answer separately as to each part or item. 6. If you have been sued in more than one capacity or if y was would be different if answered in any different capacity, such as partner, agent, corpo a l ector ---- C. 11 or the like, then you are requested to answer separately in each such capacity. Failure to do so constitutes an admission in any such capacity. 7. In these Requests for Admissions: A. The word "person(s)" means all entities, and, without limiting the generality of the foregoing, includes natural persons, joint owners, associations, companies, partnerships, joint ventures, trusts, and estates; & The word "document(s)" means all written, printed, recorded, graphic, or photographic matter, or, sound reproductions, however produced or reproduced, pertaining to any manner to the subject matter indicated; C. The words "identity", "identify", "identification", when used with respect to a person(s) means to state the full name and present or last known address and business address of such person(s) and, if an actual person, his present or last known job title, and the name and address of his present or last known employers; D. The words "identity", "identify" "identification", when used with respect to a date, subject matter, name(s) or person(s) that wrote, signed initialed, dictated or otherwise participated in the creation of the same, the name(s) of the addressee or addressees if any and the name(s) and address(es) of each person who have possession, custody, and control of said document(s). If any such document was, but is no longer in your possession, custody, or control, or in existence, state the date and manner of its disposition; and E. The word "identify", when used with respect to an act (including an alleged offense), occurrence, statement, or conduct (hereinafter collectively called "act"), means to (1) describe the substance of the event or events constituting such an act, and to state the date when such act occurred; (2) identify each and every person(s) participating in such an act; (3) identify all other person(s) (if any) present when such act occurred; (4) state whether any minutes, notes, memoranda, or other record of such act was made; (5) state whether such record now exists; and (6) identi the person(s) presently having possession, custody or control of such record. & Unless otherwise indicated, all Requests herein relate to those certain events, persons, and period of time more fully described in the pleading in this case. These requests are of a continuous nature. These Requests for Production of Documents shall be deemed continuing so as to require supplemental answers and documents if any information of documents are acquired subsequent to the filing of responses hereto, which information or documents would have been included in the answers and documents produced had it been known or available at the time the answers and the documents provided pursuant hereto were produced. Defendants shall supply such information and documents by supplemental answers and production of documents as soon as such information becomes known or available and in all events, prior to trial of this action. If objection is made to any requests for production of documents, it is demanded that the requests for which there is no objection be answered and furnished within the aforesaid period. All documents identified in response hereto shall be organized and labeled to correspond with the request to which it pertains. For all documents produced, list the individual and his or her job title and department from whose files it was produced and the current custodian of said document. If a document called for is believed to exist or is known to exist, but is in the possession, custody or control of another person or party, the existence of the document, the identity of the possessor, custodian and one in control of such docu vents shall be provided along with any applicable common description or citation utilized by the publisher, possessor, custodian or disseminator of such document. If any document called for by this request is withheld on the basis of any claim of privilege or any similar claim, identify that document as follows: author; addressee; indicated or blind copies, date, subject matter; number of pages; attachments or appendices; all persons to whom distributed, shown or explained; present custodian; and nature of the privilege or similar claim asserted- REQUEST FOR PRODUCTION OF DOCUMENTS 1: Produce any and all documents evidencing proof of all payments on the subject credit card referenced in the Complaint, including, but not limited to, cancelled checks, receipts, coupons, statements, accountings, memoranda, invoices, financial statements, accounting entries, diaries, charts, lists, phone records, data compilations etc. REQUEST FOR PRODUCTION OF DOCUMENTS 2: Produce any and all documents you intend to introduce and/or provide testimony on as evidence at the time of trial. REQUEST FOR ADMISSION NO. 1:_ The attached statement from 9/18/06 correctly identify the payments, charges, and balances on the account. Admitted Denied If the answer to Request for Admissions No. 1 is "denied", then supply copies of canceled checks, both front and back, and/or if not available, specific written documentation supporting the denial. REQUEST FOR ADMISSION NO. 2: The last payment on the account was made on September 18 2006. Admitted Denied If the answer to Request for Admissions No. 2 is "denied", then supply specific written documentation supporting the denial. REQUEST FOR ADMISSION NO. 3: Defendant has not submitted any written dispute as to billing inaccuracy concerning the account in question. Admitted Denied If the answer to the Request for Admissions No. 3 is "denied", then supply copies of specific written disputes as to any billing inaccuracies. REQUEST FOR ADMISSION NO. 4: $5580.32 is a correct and accurate current balance of the account in question. Admitted Denied If the answer to Request for Admissions No. 4 is "denied", then supply specific written documentation supporting the denial. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. isenja n.. ?,i jujull L.ayuuc PA .D. 3598 WF TMAN. WEMBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-79555 WWR:6603941. DEFENDANT'S VERIFICATION (please print) under penalty of perjury and subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities verify that the foregoing Responses are true and correct to the best of my knowledge, information and belief. Date Signature CERTIFICATE OF SERVICE A true and correct copy of Plaintiff's First Request for Production of Documents and Request for Admissions has been served by U.S. Mail, on the Il!5 day ofd uj? , 2009, upon the following: Christopher K Struchen 142 Pine Grove Rd # A Gardners Pa 17324 )8/22/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 08/21/08 361 ALEXANDER SPRING RD CARLISLE PA 17015 ------- PHONE (717) 960-1680 ------------------------- ---- ---- PATIENT: --- ---------------------------------- STRUCHEN, CHRISTOPHER K F/C: P P/T: E A/C: 9349608 DSC CODE: 01 TO: STRUCHEN, CHRISTOPHER K ADMISSION: 09/18/06 DISCHARGE: 09/18/06 16 WESTMINSTER COURT CARLISLE PA 17013 D E P A R T M E N T A M O U N T 412 PHARMACY 167.90 416 IV THERAPY 71.03 418 SUPPLIES - MEDICAL 316.54 429 RADIOLOGY - CT SCAN 2,239.12 436 LAB 423.71 444 EKG 390.66 450 ONCOLOGY 140.00 480 EMERGENCY ROOM 1,831.36 ADJUSTMENTS 5,580.32- ----------------------------------------------------------------------------- TOTAL 0.00 SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY= CMD:I=DAR,2=PAT 4=DETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD CERTIFICATE OF SERVICE A true and correct copy of the within Plaintiff's Motion for Summary Judgment has been served by U.S. Mail, Postage Pre-Paid, on day of DCJOte , 2009 upon the following: Claudette A Fortman 47 North East Street Apartment 1 Carlisle Pa 17013 By: Pa. I.D. 598 Weltm einberg & Reis, Co. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 6603941 rr- F, t. co U o l_/q LA ,It PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter for the next Argument Court- CAPTION OF CASE (entire caption must be stated in full) In4err?cnhU?no?? ?or?r?o??U lNC- (Plaintiff) VS. ?,hY1S?C?-2 ?. S?YUCI?iv ( Defendant ) of o. _ Civil 1- State matter to be argued (i-e plaintiff's motion for new trial, defendant's demurrer to ccmplaint, etc-)-. I 1 _ LY) M f 2. Identify counsel who will argue case: (a) for plaintiff : BC n _ Cl YY) k IV b . Address: Weltman, Weinberg & Reis Co,.. (b) for defendant : I 1400 Koppers Bldg. Address: S 436 7th Ave. Pittsburgh, PA 15219 (412) 434-7955 3. I will notify all parties in writing within two days that this case has been listed for argument- 4. Argument Court Date: 11 'ab'` 0a CERTIFICATE OF SERVICE A true and correct copy of the Praecipe to List Case for Argument has been served by U.S. Mail, Postage Pre-Paid, on 15"day of t , 2009 upon the following: Claudette A Fortman 47 North East St Apartment 1 Carlisle Pa 17013 By: Benjamin R er; ire PA ID# 935 8 Weltman,Wemberg & Reis CO L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 CA 4-- 14-.. INTERNATIONAL PORTFOLIO, INC., IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTOPHER K. STRUCHEN, DEFENDANT 08-7511 CIVIL TERM IN RE: MOTION FOR SUMMARY JUDGMENT BEFORE BAYLEY, J. AND EBERT, J. ORDER OF COURT AND NOW, this -:30 day of November, 2009, summary judgment IS GRANTED to plaintiff International Portfolio, Inc., against defendant Christopher K. Struchen in the amount of $5,580.32 with prejudgment interest at the rate of six percent per annum from October 10, 2008. By the , Edgar B. Bayley, J. Andrew J. Bender, Esquire Stephen R. Maitland, Esquire 61 West Louther Street Carlisle, PA 17013 Christopher K. Struchen, Pro se c/o Claudette A. Fortman 47 North East Street Apartment 1 Carlisle, PA 17013 sal L 2103 O Sli ' . I i Office of lthe Prothonotary Cumberland County Curtis R. Long Prothonotary Christopher K. Struchen 300 Cornman Rd. Carlisle, PA 17013 DATE: November 5, 2009 TO Mr. Struchen: THIS IS TO NOTIFY YOU THAT CASE NUMBER 08-7511 International Portfolio Inc. VS. Christopher K. Struchen HAS BEEN LISTED FOR ARGUMENT ON November 25, 2009 !`..mhnr?on? rrmintw Araument Court Rules 1028(c), CURTIS R. LONG Prothonotary v0 /gyp _ n5) I, I 1 Cumberland County Suite 100 One Courthouse Square F11 FD-- Carlisle, PA 17013 OF THE F '' I' --I?OTARY LUU rsU t 7 e:i 1 I I- v .) Christopher K. Struchen 300 Cornman Rd. Carlisle, PA 17013 -1, 7 ®Wrcr aovrE 02 1A $ 00.4 0004631598 NOV06 2 MAILED FROM ZIP CODE 17 x 116 Nrm 1 soex o0 111aeiog FORWARD TIME EXP RTN TO SEND STRUCWEN 142 PINE GROVE RD # A GARDNERS PA 17324 -8020 RETURN TO SENDER ?'-' s 11 II 11 !l 1 1 X „ ,,, .,, ,,, 1 r, 'OF THE NARY 20 10 APR 19 AM 11. 37 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUIOJ) jEtE,NN- CIVIL DIVISION PFIN'N SYLVAR lA INTERNATIONAL PORTFOLIO INC Plaintiff vs. Case No.: 08-7511 CIVIL TERM TYPE OF PLEADING PRAECIPE FOR JUDGMENT PER ORDER OF COURT CHRISTOPHER K STRUC14EN Defendant. FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: Benjamin R Bibler, Esquire PA I.D. #93598 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR No. 6603941 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. CHRISTOPHER K STRUCHEN Defendant. TO THE PROTHONOTARY: Case No.: 08-7511 CIVIL TERM PRAECIPE FOR JUDGMENT Pursuant to Pa.R.C.P. 237, I certify that a copy of this Praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. In light of the Court Order granting Judgment in favor of Plaintiff on November 30 2009, kindly enter Judgment against the Defendants, Christopher K Struchen, in the amount of $6,078.42 computed as follows: Amount Awarded per Order: $5,580.32 P ?rper 0 Interest from 10/10/08 through 4/13/10 $ at the legal rate of 6.00% per annum: TOTAL: $' Attached is a copy of the Court Order in favor of Plaintiff for Judgment. WELTMAN, WEINBERG & REIS, CO., L.P.A. By: Benjamin R Bibler, Esquire PA I.D. #93598 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 Plaintiff's addresF is: Weltman, Weinberg & Reis, 1400 Koppers Building, 436 7"' Avenue, Pittsburgh, PA 15219 And Defendant's address is: 142 Pine Grove Rd #A Gardners Pa 17324 41q.00 pa iATY `/ 441p4q-2? WWR No. 6603941 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff Case No.: 08-7511 CIVIL TERM vs. CHRISTOPHER K STRUCHEN Defendant. NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendants ( ) Garnishee You are hereby notified that he f ]lowing Order or Judgment was entered against you on (xx) Assumpsit Judgment in the amount of $6,078.42, plus interest at 6% per annum, 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 (xx) Court Order ( ) Non-Pros ( ) Confession ( ) Default ( ) Verdict ( ) Arbitration Award ( ) By Consent Prothonotary Christopher K Struchen 142 Pine Grove Rd #A Gardners Pa 17324 ? ; .? By: < NOTAR (OR PUTY) PRO, WWR No. 6603941 INTERNATIONAL PORTFOLIO, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTOPHER K. STRUCHEN, DEFENDANT : 08-7511 CIVIL TERM IN RE: MOTION FOR SUMMARY JUDGMENT BEFORE BAYLEY, J. AND EBERT, J. ORDER OF COURT AND NOW, this 30, day of November, 2009, summary judgment IS GRANTED to plaintiff International Portfolio, Inc., against defendant Christopher K. Struchen in the amount of $5,580.32 with prejudgment interest at the rate of six percent per annum from October 10, 2008. By the , _ N Edgar B. Bayley, J. -Andrew J. Bender, Esquire Stephen R. Maitland, Esquire 61 West Louther Street Carlisle, PA 17013 Christopher K. Struchen, Pro se c/o Claudette A. Fortman 47 North East Street Apartment 1 Carlisle, PA 17013 :sal I l? 3o?crf' i ILEI 2109 NON 3% # f 1 G .. d '1` -low - WELTMAN,WEINBERG&REIS CO.,L.P.A. BY: William T Molczan,Esquire Attorney for Plaintiff(s) , I.D.No.47437 c 436 Seventh Avenue, Suite 1400 s '-n rnav Pittsburgh,PA 15219 r- ;;0� -;rn Phone: 412.434.7955 cn� tvG Fax: 412.434.7959 -4 File#6603941 Z INTERNATIONAL PORTFOLIO INC Cumberland County Court of Common Pleas vs. CHRISTOPHER K STRUCHEN NO. 08-7511 CIVIL TERM and PNC BANK Garnishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s),PNC BANK, only. WELTMAN,WEINBERG&REIS CO.,L.P.A. B � ` . Y William T Molc squire Attorney for Plain 4.5o PA A l 11ao9 04 g*'d88a0& SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff P rR0TH0N0TAR`` Jody S Smith ss Chief Deputy ` 2013 SEP 19 AN 1 1 ;{ I Richard W Stewart Solicitor OFNCEOF TVESHER1F� CUMBERLAND CCklN Y PENNSYLVANIA International Portfolio Inc. Case Number vs. 2008-7511 Christopher Struchen SHERIFF'S RETURN OF SERVICE 02/15/2013 10:13 AM-William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, PNC Bank, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Susan Casale, Customer Service Rep., personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on February 20, 2013 to Christopher K. Struchen at 300 Cornman Road, Carlisle, PA 17013. 09/18/2013 Ronny R.Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $87.93 SO ANSWERS, �7 September 18, 2013 RbNrrY R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoft,inc.