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HomeMy WebLinkAbout09-8863LAW OFFICES OF GEORGE TWARDY, JR. BY: GEORGE TWARDY, JR., ESQUIRE Attorney ID: 52883 1026 Winter Street, Suite 400 Philadelphia, PA 19107-1808 1-877-440-8182 INTERNATIONAL PORTFOLIO, INC. 200 BAR HARBOUR DRIVE SUITE 400 WEST CONSHOHOCKEN, PA 19428 v. SUZETTE M CHAMBERLIN 49 REGENCY WOODS NORTH CARLISLE PA 17015 Og' - ?7slo? ??" 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 THE TELEPHONE OR THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL ACTION NO Twardy and Associates, LLC By: George Twardy, Jr., Esquire Identification No. 52883 1026 Winter Street Suite 400 Philadelphia, PA 19107 1-877-440-8182 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY INTERNATIONAL PORTFOLIO, INC. 200 BAR HARBOUR DRIVE SUITE 400 WEST CONSHOHOCKEN, PA 19428 NS. SUZETTE M CHAMBERLIN 49 REGENCY WOODS NORTH CARLISLE PA 17015 COMPLAINT Ll? - X6 3 c?,j 'I 1. Plaintiff, International Portfolio, Inc., is the Assignee of the debt from Carlisle Regional Medical Center, with offices in CUMBERLAND, Pennsylvania. At all times mentioned herein, Plaintiff is regularly licensed and authorized to do business as a Corporation in the Commonwealth of Pennsylvania. 2. Defendant, SUZETTE M CHAMBERLIN, is an individual residing at 49 REGENCY WOODS NORTH, CARLISLE PA 17015. 3. As a result of a certain medical condition, Defendant, SUZETTE M CHAMBERLIN, was admitted to Carlisle Regional Medical Center on 01/07/2006 through 01/07/2006. 4. Carlisle Regional Medical Center rendered services to Defendant, SUZETTE M CHAMBERLIN, of the kinds and for the prices set forth in their bill which is now part of Plaintiff's records and is set forth as Exhibit P-1. 5. The charges of $1270.04 for Carlisle Regional Medical Center's services were fair, reasonable, and proper charges for the same at the time that they were rendered, and they were agreed to by the Defendant, SUZETTE M CHAMBERLIN. 6. Said medical care was commensurate with the condition of Defendant, SUZETTE M CHAMBERLIN, and was necessary for the health and welfare of Defendant. 7. At or about the time that Defendant received treatment from Carlisle Regional Medical Center, implied, constructive and/or verbal contracts were made between the parties, and Defendant agreed to pay Carlisle Regional Medical Center for the charges of the medical care provided to Defendant by Carlisle Regional Medical Center. 8. On or about 01/07/2006, Defendant, SUZETTE M CHAMBERLIN, was discharged from Carlisle Regional Medical Center. 9. No payments have been made, and Defendant, SUZETTE M CHAMBERLIN, breached the agreement with Carlisle Regional Medical Center by failing and/or refusing to pay the balance of the agreed price, $1270.04, although requested to do so by Plaintiff and their attorneys. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $1270.04, plus six percent (6%) interest per annum, from the date of discharge to the date of judgment, and record and non-record costs. TWARDY AND ASSOCIATES B J ORGE rTWARDY, JR., ESQUIRE ATTORNEY FOR PLAINTIFF EXHIBIT P-1 12/23/09 HEALTH MANAGEMENT ASSOCIATES DA04 COID: 858 ACCOUNT #: 9329044 DISCHARGE ACCOUNTS RECEIVABLE RECORD PAT NAME: CHAMBERLIN, SUZETTE M ADMIT: 01/07/06 FINANCIAL CLASS: 9 P GAR NAME: CHAMBERLIN, SUZETTE M DISCHARGE: 01/07/06 CONTRACT FREQ: S STREET: 353 N HANOVER ST LAST PAY: 01/07/06 MAIL RETURN: ADDR-2: PROGRAM: PAT TYPE: E1 CITY: CARLISLE PA 17013 CONTRACT: .00 PAT SEX: F PHONE: (717) 422-4466 COUNTRY: US CURR BAL: .00 GAR SEX: F EMPLOYER: TACO BELL TOT CHARGES: 1,179.04 AGENCY CNCL: CSA CODE DATE INSURANCE AGENCY BAL: .00 1: 978 09/16/06 1,179.04- CODE PLAN DATE STAT POLICY NO 2: 1: 3: 2: 4. 3: 5: LST ACTN: 99 11/08/07 3: TT 04/17/06 PAY AUD 1: QQ 09/15/06 4: L1 04/02/06 PROCESS REVIEW PAY AUD 2: UU 09/08/06 5: S1 01/16/06 DATE USER DATE ARTRAC ASSGN: 02/06/06 RETN 04/02/06 REASON 985 11/08/07 PBY454 00/00/00 ( SOLD A/R TO IPI $1,179.04 11/08/07 PBY454 00/00/00 I PRIM CD:CUN-UNCOLLECTABLE ; SEC CD:CSA-UNCOLLECTABL 08/18/06 ASET 00/00/00 17:54 res 717-422-4466 LM ON AM 08/09/06 ASET 00/00/00 14:06 res 717-422-4466 LM ON AM 1=UP,2=PT,3=GAR,4=INS,5=UB,6=HIS,7=RTN,8=CMTI,9=CMTU,10=DET,II=LOG,I3=ADJ,ENT=FW 4-© A Sess-1 10.200.98.7 XCAL2001 #§ 2/13 Printed on 12/23/09 08:58:31 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities, that she is Gina Sposito, Supervisor of Customer Care of International Portfolio, Inc., plaintiff herein, that she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action, and any attachments thereto, are true and correct to the best of her knowledge, information and belief. Date: Gina Sposito CE 1'' _... 29 Al 11: G i ?? t??q 4 A of c V David D. Buell '''',‘,,p Renee 7 Simpson z , Prothonotary o i ` , Z 1st Deputy cProthonotary it S Sofionage, F.SQ '� "` `'" x k � �, Irene E. .91f orrow Solicitor 1 50 2nd Deputy Prothonotary Office of the (Prothonotary Cumberland-County, Pennsylvania 69--49 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER, 2013,AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE-THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square • Suite 100 • Carlisle, PA 17013 • (717)240-6195 • Ea/x(717)240-6573