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HomeMy WebLinkAbout09-8864LAW OFFICES OF GEORGE TWARDY, JR. BY: GEORGE TWARDY, JR., ESQUIRE Attorney for Plaintiff Attorney ID: 52883 1026 Winter Street, Suite 400 Philadelphia, PA 19107-1808 1-877-440-8182 INTERNATIONAL PORTFOLIO, INC. 200 BAR HARBOUR DRIVE CUMBERLAND COUNTY SUITE 400 COURT OF COMMON PLEAS WEST CONSHOHOCKEN, PA 19428 V. CIVIL ACTION NO TERRY LEE MILLER, Jr. 09 - 154 GLENWOOD ROAD DILLSBURG PA 17019 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 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 VS. TERRY LEE MILLER, Jr. 154 GLENWOOD ROAD DILLSBURG PA 17019 COMPLAINT 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, TERRY LEE MILLER, Jr., is an individual residing at 154 GLENWOOD ROAD, DILLSBURG PA 17019. 3. As a result of a certain medical condition, Defendant, TERRY LEE MILLER, Jr., was admitted to Carlisle Regional Medical Center on 01/01/2006 through 01/01/2006. 4. Carlisle Regional Medical Center rendered services to Defendant, TERRY LEE MILLER, Jr., 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 $2019.30 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, TERRY LEE MILLER, Jr.. 6. Said medical care was commensurate with the condition of Defendant, TERRY LEE MILLER, Jr., 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 01/01/2006, Defendant, TERRY LEE MILLER, Jr., was discharged from Carlisle Regional Medical Center. 9. No payments have been made, and Defendant, TERRY LEE MILLER, Jr., breached the agreement with Carlisle Regional Medical Center by failing and/or refusing to pay the balance of the agreed price, $2019.30, although requested to do so by Plaintiff and their attorneys. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $2019.30, 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 BY- G ORGE TWARDY, JR., ESQUIRE ATTORNEY FOR PLAINTIFF EXHIBIT P-1 12/23/09 HEALTH MANAGEMENT ASSOCIATES DA04 COID: 858 ACCOUNT #: 9328609 DISCHARGE ACCOUNTS RECEIVABLE RECORD PAT NAME: MILLER, TERRY L ADMIT: 01/01/06 FINANCIAL CLASS: 9 P GAR NAME: MILLER, TERRY L DISCHARGE: 01/01/06 CONTRACT FREQ: S STREET: 815 SANDBANK RD LAST PAY: 01/01/06 MAIL RETURN: ADDR-2: PROGRAM: PAT TYPE: E1 CITY: MT HOLLY SPRG PA 17065 CONTRACT: .00 PAT SEX: M PHONE: (717) 577-6399 COUNTRY: US CURR BAL: .00 GAR SEX: M EMPLOYER: WILLIAMS EXCAVATING TOT CHARGES: 1,933.30 AGENCY CNCL: CSA CODE DATE INSURANCE AGENCY BAL: .00 1: 978 08/27/06 1,933.30- CODE PLAN DATE STAT POLICY NO 2: 1: 3: 2: 4. 3: 5: LST ACTN: 99 11/08/07 3: NN 03/31/06 PAY AUD 1: KK 08/26/06 4: L1 03/28/06 PROCESS REVIEW PAY AUD 2: UU 08/19/06 5: S1 01/09/06 DATE USER DATE ARTRAC ASSGN: 01/30/06 RETN 03/28/06 REASON 985 11/08/07 PBY454 00/00/00 1 SOLD A/R TO IPI $1,933.30 11/08/07 PBY454 00/00/00 1 PRIM CD:CSA-UNCOLLECTABLE ; SEC CD:CSA-UNCOLLECTABL 09/20/06 ASET 00/00/00 08:01 MRD 09/18/06 ASET 00/00/00 11:45 CK'D TU 1=UP,2=PT,3=GAR,4=INS,5=UB,6=HIS,7=RTN,8=CMTI,9=CMTU,I0=DET,II=LOG, I3=ADJ,ENT=FW 4-© A Sess-1 10.200.98.7 XCAL2001 #§ 2/13 _ Printed on 12/23/09 08:43:55 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: 4) Gina Sposito ,?. i °1111,_ T ,? a3s'Si,3 IN THE COURT OF COMMON PLEA OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO, INC 200 BAR HARBOUR DRIVE SUITE 400 WEST CONSHOHOCKEN, PA 19428 vs. TERRY LEE MILLER, Jr. 534 GRAHAMS WOODS RD CARLISLE PA 17015 e~ ~ N ca, -x3 N0.09-8864 . -~,. ~ --i rn . ~ ~ o ~ r ~---- ~~ _ ~~ + ,..~ ~ w ~ -~-~ o ;mac a ?~ °'~ ~ ~ iWi . .,~~ w ,~r=-~ .:-~ -~; ~ __~ PRAECIPE FOR JUDGMENT Enter Judgment in favor of Plaintiff, International Portfolio Inc., and against Defendant, TERRY LEE MILLER, Jr. for want of an answer in the amount of: Debt: $1933.30 Interestlcosts: $274.50 + ongoing Total: $2207.80 I certify that the forgoing assessment of damages if for the specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. Pursuant to PA R.C.P. No. 237 (Notice of Praecipe for Final Judgment), I certify that a copy of this Praecipe has been mailed to each party who has appeared in the action or to his or her Attorney of Record. Pursuant to Pa. R.C.P., I certify that written Notice of Intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to his Attorney of Record if any, after the default occurred and at least ten (10) days prior to the date of the filin of this Praecipe for not filing an answer to thie complai`n'tf. ~ / DATE: ) ~ / / / ~ C/ J eorge Twardy, Jr. E re Attorney for International Portfolio, Inc. NOW, C~~~(ocl l.~ ~/~ /cl rk, Civil Division By: Deputy JUDGMENT IS ENTERED ABOVE. c~~d-ya9 f 1~~j~G ~l ~d 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 CUMBERLANDCOUNTY INTERNATIONAL PORTFOLIO, INC. 200 BAR HARBOUR DRIVE SUITE 400 WEST CONSHOHOCKEN, PA 19428 N0.09-8864 vs. TERRY LEE MILLER, Jr. 534 GRAHAMS WOODS RD CARLISLE PA 17015 CERTIFICATE OF SERVICE- PRAECIPE FOR JUDGMENT I, George Twardy, Jr., Esquire, do hereby certify that a true and correct copy of the Praecipe for Judgment regarding the above captioned matter has been forwarded via U.S. First Class Mail, on f ~ / ~~~ U , to the following: TERRY LEE MILLER, Jr. 534 GRAHAMS WOODS RD CARLISLE PA 17015 TWARDY AND ASSOCIATES, LLC /~ _ G/ t~ eorge Twardy, Jr., Esquire Attorney for Plaintiff TWARDY AND ASSOCIATES, LLC BY: GEORGE TWARDY, JR., ESQUIRE ATTORNEY ID# 52883 1026 WINTER STREET, SUITE 400 PHILADELPHIA, PA 19107 TEL.# 1-877-440-8182 Attorney for Plaintiffs INTERNATIONAL PORTFOLIO, INC 200 BAR HARBOUR DRIVE SUITE 400 WEST CONSHOHOCKEN, PA 19428 VS. TERRY LEE MILLER, Jr. 534 GRAHAMS WOODS RD CARLISLE PA 17015 COURT OF COMMON PLEAS CUMBERLAND COUNTY N0.09-8864 VERIFICATION OF NON-MILITARY SERVICE I here by verify that I am Attorney for Plaintiff in the above captioned matter, and that on information and belief, I have knowledge of the following facts, to wit: (a) That the Defendant(s) is/are not in the Military or Naval Service of the United State or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) That the Defendant, TERRY LEE MILLER, Jr. Or occupants, is over 18 years of age, and resides at 534 GRAHAMS WOODS RD ,CARLISLE PA 17015 This statement is made subject to the penalties of 10 PA CSS 4904 relating to unsworn falsification to authorities. ~ ~ ~e Twardy, Jr. Esq. Attorney for Plaintiff 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 CUMBERLANDCOUNTY INTERNATIONAL PORTFOLIO, INC. 200 BAR HARBOUR DRIVE SUITE 400 WEST CONSHOHOCKEN, PA 19428 N0.09-8864 vs. TERRY LEE MILLER, Jr. 534 GRAHAMS WOODS RD CARLISLE PA 17015 CERTIFICATE OF SERVICE- RULE 236 NOTICE I, George Twardy, Jr., Esquire, do hereby certify that a true and correct copy of the Rule 236 Notice regarding the above captioned matter has been forwarded via U.S. First Class Mail, on ~ ~ ~ 7 ~ ~ ~ , to the following: TERRY LEE MILLER, Jr. 534 GRAHAMS WOODS RD CARLISLE PA 17015 LAW OFFICES OF GEORGE TWARDY, JR. 1/~--~ By: eorge Twardy, Jr., Esquire Attorney for Plaintiff 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 CUMBERLANDCOUNTY INTERNATIONAL PORTFOLIO, INC. 200 BAR HARBOUR DRIVE . SUITE 400 WEST CONSHOHOCKEN, PA 19428 N0.09-8864 vs. TERRY LEE MILLER, Jr. 534 GRAHAMS WOODS RD CARLISLE PA 17015 CERTIFICATE OF SERVICE- NOTICE OF PRAECIPE TO ENTER JUDGMENT I, George Twardy, Jr., Esquire, do hereby certify that a true and correct copy of the Notice of Praecipe for Judgment regarding the above captioned matter has been forwarded via U.S. First Class Mail, on ~ ~ ~ ~ CJ , to the following: TERRY LEE MILLER, Jr. 534 GRAHAMS WOODS RD CARLISLE PA 17015 TWARDY AND ASSOCIATES, LLC ~~ By: George Twardy, Jr., re Attorney for Plaintiff T`WARD~ S~ As s o cIATES ~ LLC Respo,nd >n: ATTORNEYS AT LAW [~hiladelphia ~: Toll Free: 877-440-8182 ^ Havertown ^ Voorhees www.twardyandassociates.com March 18, 2010 TERRY LEE MILLER, Jr. S34 GRAHAMS WOODS RD CARLISLE PA 17015 RE: INTERNATIONAL PORTFOLIO, INC. v. TERRY LEE MILLER, Jr. 09-88b4 Dear TERRY LEE MILLER, Jr., Enclosed please find a copy of the Notice of Praecipe to Enter Judgment. Please contact our office as soon as possible regazding the above referenced matter. S' cerely, George Twardy, Jr, Esq. Attorney for Plaintiff, International Portfolio, Inc. GT/jh Encl. PHILADELPHIA OFF[CES 1026 WINTER STREET NEW JERSEY OFFICES SUITE 400 DELAWARE COUNTY OFFICES 22 ALPHA AVENUE PHILADELPHIA, PA 19147-1808 806 DARBY ROAD VOORHEES, NJ 08043 EMAIL: gtwardyesq®twardyandassociates.com HAV>rRTOWN, PA 19083 Twardy and Associates, LLC By: Ceorge Twardy, Jr., Esquire [dentificatton No. 52883 1926 Winter Street Suite 400 Philadelphia, PA 19107 1-877-440-8182 Attorney for Plaintiff W THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY INTERNATIONAL PORTFOLIO, INC. 200 BAR HARBOUR DRIVE SUITE 400 * WEST CONSkIOIIOCKEN, PA 19428 * N0.09-8864 vs. TERRY LEE MILLER, Jr_ 534 GRAHAMS WOODS RD CARLISLE PA 17015 NOTICE OF PRAECIPE TO ENTER JUDGMENT$Y DEFA LT TO: TERRX LEE MILLER, Jr. Defendtu- DATE OF NOTICE: IMPORTANT NOTECE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FELE EN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITEfIN TEN {1 O) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARENG AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland Bar Association Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17413 Telephone: 717-249-3166 f~~ J George Twardy, Jr., Esquire Attorney for Plaintiff, International Portfolio Inc. 1026 Winter St Philadelphia, PA 19107-[808 Phone: 877-440-8182 [D. No. 52883