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Home My WebLink About08-7512IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff No. VS. COMPLAINT IN CIVIL ACTION DALE E HUNT 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#06427146 r IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff VS. Civil Action No. DALE E HUNT 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 212 N BALTIMORE AVE APT 2, POB 222, MOUNT SPRINGS, PA 17065. 3. At the specific instance and request of Defendant, BARTOW REGIONAL MEDICAL CENTER, provided certain medical services to Defendant. 4. This obligation was subsequently assigned to Plaintiff for value. 5. Defendant, DALE E HUNT, 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, DALE E HUNT, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, DALE E HUNT, in the amount of $1582.84 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, DALE E HUNT, in the amount of $1582.84 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 AN, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR#:06427146 05/13/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 816 BARTOW REGIONAL MEDICAL CENTER AS OF 05/12/08 2L00 OSPREY BLVD BARTOW FL 33831 ---------------- PHONE (863) 519-1490 ---------------- ---- ----- PATIENT: -- -------- HUNT, DALE ----------------- E F/C: P 'P/T: E A/C: 5029813 DSC CODE: 01 TO: HUNT, DALE E ADMISSION: 11/04/05 DISCHARGE: 11/04/05 530 W KING ST ABBOTTSTOWN PA 17301 D E P A R T M E N T A M O U N T 125.70 739.64 932.50 185.00- 1,612.84- ------------------------------------------------------------------------- ---- 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 V .r 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# p942.11 D CP ^ ' M r ? C 1`71 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-07512 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS HUNT DALE E MARK CONKLIN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HUNT DALEE the DEFENDANT , at 2100:00 HOURS, on the 30th day of December-, 2008 at CUMBERLAND COUNTY PRISON 1101 CLAREMONT ROAD CARLISLE, PA 17013 by handing to DALE HUNT 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 Service Affidavit Surcharge Sworn and Subscibed to before me this of So Answers: 18.00 9.90 .00 10.00 R. Thomas Kline .00 37.90 12/31/2008 WELTMAN WEINBERG REIS By: day Deputy heriff A.D. -.' ?:? x ? ..i? ,.? ,.-? c... ?'i:-y . w': p (: 'T' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff VS. DALE E HUNT Defendant No. 08-7512 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, P.A.I.D.# 42524 Weltman,Weinberg & Reis Co.,L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412)434-7955 Fax: 412-338-7130 WWR#6427146 Judgment Amount $ 1,631.49 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. DALE E HUNT Defendant TO THE PROTHONOTARY: Civil Action No. 08-7512 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, DALE E HUNT above named, in the default of an Answer, in the amount of $1,631.49 computed as follows: Amount claimed in Complaint $1,582.84 Interest from 10/22/08 to 4/27/09 at the legal interest rate of 6.00% per annum $48.65 TOTAL $1,631.49 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: D James C. W dt, P.A.I.D.# 425 4 Weltman,W rg & Reis Co.,L.P.A. 436 Seven enue, Suite 1400 Pittsbur P 15219 (412)43 -7 55 Fax:4 38-7130 WWR#6427146 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7dAvenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 1101 CLAREMONT ROAD CARLISLE,PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. DALE E HUNT . Defendant TO: DALE E HUNT 1101 CLAREMONT ROAD POB 222 CARLISLE, PA 17013 Date of Notice: Case No. OB-7512 CIVIL TERM IMPORTANT NOTICE 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 TEN 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 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA. 17013 (717) 249-3166 WELTk*N, WEINBERG & REIS CO., L.P.A. By: Ma ew Urban P.A.I.D.# 90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 6427146 H PIT SMI Request for Military Status Department of Defense Manpower Data Center 4 Military Status Report Pursuant to the Servicemembers Civil Relief Act k Page 1 of 1 APR-23-2009 07:50:06 Last Name First/Middle Begin Date Active Duty Status Service/Agency HUNT DALE 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. Af% Alut lot 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: http:H ww defenselink mil/tNq/pis/PC09SLDR html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: JLQFXIKYOY https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 4/23/2009 . . A % IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. DALE E HUNT Defendant Case no: 08-75 ] 2 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, DALE E HUNT 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, DALE E HUNT is not in the military service. Further Affiant sayeth naught. SWO T AND SUB C 6ED in my presence this A day of PUBLIC ?- COMMONWEALTH OF PENNSYLVANIA NotarFal Steal Heidi J. Kelly, Notary Public Gty OF Pittsburgh, Allegheny County L __ - My Commission E?ires Nov. 4, 2009 Member, Pennsylvania Association of Notaries , .. ?y FILE(', ?. 210"O91 ,Y -5- A",1 8: 1 bi +14.00 P A Arri CV* qoaSS-*7Q ' 4 y IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. DALE E HUNT Defendant Civil Action No. 08-7512 CIVIL TERM NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or ud ent was entered against you on (xx) Assumpsit Judgment in the amount of 51,631.49 plus costs. ( ) Trespass Judgment in the amount of S 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: d- R, rl.di PRO ONOTARY (OR DEPU ) DALE E HUNT 1101 CLAREMONT ROAD CARLISLE,PA 17013 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7's Avenue, Pittsburgh, PA 15219 1-888-434-0085