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HomeMy WebLinkAbout09-0268 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff No. 09 ^ ).48 vs. PATRICIA A MATEYA COMPLAINT IN CIVIL ACTION 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#6432945 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff VS. Civil Action No. PATRICIA A MATEYA 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 FI 33028. 2. Defendant is an adult individual residing at 117 Race St, Boiling Springs, Pa 17007. COUNT I ACCOUNT # 9293918 3. At the specific instance and request of Defendant, Patricia A Mateya, Plaintiff provided certain medical services to Defendant. 4. Defendant, Patricia A Mateya, received and accepted the aforementioned medical services which were provided by Plaintiff. 5. The prices charged by Plaintiff were the prices that Defendant, Patricia A Mateya, agreed to pay. 6. Plaintiff avers that there is a balance due and owing from Defendant, Patricia A Mateya, in the amount of $1103.60 as of December 7, 2007. 7. Plaintiff claims interest at the legal rate of six (6%) percent per annum from December 7, 2007. 8. 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, Patricia A Mateya, in the amount of $1103.60 with legal interest at the rate of 6% per annum from December 7, 2007 and costs. COUNT II ACCOUNT # 7517771 9. At the specific instance and request of Defendant, Patricia A Mateya, Plaintiff provided certain medical services to Defendant. 10. Defendant, Patricia A Mateya, received and accepted the aforementioned medical services which were provided by Plaintiff. 11. The prices charged by Plaintiff were the prices that Defendant, Patricia A Mateya, agreed to pay. 12. Plaintiff avers that there is a balance due and owing from Defendant, Patricia A Mateya, in the amount of $660.32 as of December 7, 2007. 13. Plaintiff claims interest at the legal rate of six (6%) percent per annum from December 7, 2007. 14. 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, Patricia A Mateya, in the amount of $660.32 with legal interest at the rate of 6% per annum from December 7, 2007 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. 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#:6432945 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. 'JaQ \JO OAJ (Signature) WWR# 1 40 (-Zl -ft OD o w f :.a N C? fV L? i? C?f+iP -?C G SHERIFF'S RETURN - REGULAR CASE NO: 2009-00268 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTERNATIONAL PORTFOLIO INC VS MATEYA PATRICIA A AMANDA COBAUGH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MATEYA PATRICIA A the DEFENDANT , at 1312:00 HOURS, on the 23rd day of January , 2009 at 117 RACE STREET BOILING SPRINGS, PA 17007 by handing to ANNE AUMILLER, ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE day together with and at the same time directing Her attention to the contents thereof. f Sheriff's Costs: Docketing 18.00 Service 5.40 Affidavit .00 Surcharge 10.00 .00 33.40 Sworn and Subscibed to before me this of So Answers: R. Thomas Kline 01/26/2009 WELTMAN WEINBERG REIS By: Deputy She ff A. D. ;: Y INTERNATIONAL PORTFOLIO INC., Plaintiff V. PATRICIA A. MATEYA, Defendant : IN THE COURT OF 1 : CUMBERLAND COI :NO. 09-268 - CIVIL CIVIL ACTION - LA ENTRY OF APPEARANCE Please enter my appearance on behalf of the Defendant, matter. Respectfully "k. VION PLEAS , PENNSYLVANIA ;ia A. Mateya in the above Date: U Mark A. Mateya Esgyire Attorney ID No. 78931 P.O. Box 127 Boiling Springs, A 17007 (717) 241-6500 (717) 241-3099 F x ?' . . `• CERTIFICATE OF SERVICE I, Mark A. Mateya, Esquire, hereby certify that I have served APPEARANCE on the following person(s) by depositing a true and United States Mail, first class, postage prepaid, at Harrisburg, addressed to: WILLIAM T. MOLCZAN ESQUIRE WELTMAN WEINBERG & REIS CO LPA 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH PA 15219 DATED: U / Mark A. I P.O. Box Boiling S (717) 241 a copy of the ENTRY OF copy of the same in the County, Pennsylvania 27 rings, PA 17007 5500 Attorney for Defendant EL r;-? t : ? ?a tom-.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. PATRICIA A MATEYA Defendant No. 09-268-CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT 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#6432945 Judgment Amount 1913.64 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. PATRICIA A MATEYA Defendant TO THE PROTHONOTARY: Civil Action No. 09-268-CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT COUNTI Kindly enter Judgment against the Defendant, Patricia A Mateya, above named, in the default of an Answer, in the amount of $1197.21 computed as follows: Amount claimed in Complaint $1103.60 Interest from December 7, 2007 to May 7, 2009 at the legal interest rate of 6% per annum $93.61 TOTAL $1197.21 COUNT II Kindly enter Judgment against the Defendant, Patricia A Mateya, above named, in the default of an Answer, in the amount of $716.33 computed as follows: Amount claimed in Complaint $660.32 Interest from December 7, 2007 to May 7, 2009 at the legal interest rate of 6% per annum $56.01 TOTAL $716.33 TOTAL COUNT I & COUNT 11 $1913.54 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: k William T. Molczarl, Esq)ffe PA. I . D.#47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6432945 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 59 WALNUT ST, BEAVER,PA 15009 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. Civil Action No. 09-268-CIVIL TERM PATRICIA A MATEYA 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 n2=!j I (xx) Assumpsit Judgment in the amount of $1197.21 plus costs as to Count I. (xx) Assumpsit Judgment in the amount of $716.33 plus costs as to Count ll. ( ) 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 (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary MARK MATEYA 155& POB 127 By: BOILING SPRINGS PA 17007 PR HONG R DICPUTY) I- r Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7?' Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff Case No. 09-268 CIVIL TERM VS PATRICIA A MATEYA Defendant IMPORTANT NOTICE TO: PATRICIA A MATEYA 117 RACE ST BOILING SPRING, PA 17007 C/O MARK MATEYA POB 127 BOILING SPRINGS, PA 170 7 Date of 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 WELTMO, WEINBERG & REIS CO., L.P.A. By; I --- ;ttla?w Urts?h FCLt'1VIA"f k4it6`& RiE'IS C©., "L.P.A 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 6432945 H PIT VOC IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff Case No. 09-268 CIVIL TERM VS PATRICIA A MATEYA Defendant IMPORTANT NOTICE TO: PATRICIA A MATEYA 117 RACE ST BOILING SPRING, PA 17007 C/O MARK MATEYA POB 127 BOILING SPRINGS, PA 17007 Date of Notice: ---? a ? 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 WELTMAN, WEINBERG & REIS CO., L.P.A. Bv; !d :iJ?k7e"h :zLli4?1,1Ifd131'.?`& FtE1S CC3., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 6432945 H PIT VOC IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. PATRICIA A MATEYA Defendant Case no: 09-268-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, PATRICIA A MATEYA 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, PATRICIA A MATEYA, is not in the military service. Further Affiant sayeth naught. j 4 AFFIANT SWO TO AND SUBSCRIB D in my presence this jg/oday of. f N!?sn w?wo? coM io a.TH OF NOTAR UBLI N°' N JentNhr M. BoMrowkiv+`k{. ??S?YCoumY con-am F ueo y Fib. 2Z, ?Qt. NOhtia Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 MAY-07-2009 13:01:41 "K Last Name First/Middle Begin Date Active Duty Status Service/Agency MATEYA PATRICIA A 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. 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: np://www.defenselink.mil/faq/pis/PC09SLDR.htm1 WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 5/7/2009 Request for Military Status Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: BSHGHMUTAYT https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 5/7/2009 FII. C wr6lCE ,)c THE 11 ?" -I TAP. 2099 MAY 18 PN Z: 'Li 'i `r oo?rdA4 eK? 4c?lo7/? ?? aas?.?7