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HomeMy WebLinkAbout10-02741,9 LAW 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. SARAH E NEAL And ERIC NEAL H/W 17 MCBRIDE AVE CARLISLE PA 17013 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL ACTION NO ' 10 -a,74 COMPLAINT - CIVIL ACTION n N ct) o Tr L Co {1 i W V 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 CLAB4ED 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 0 4 U. 00 Pb A TTy CLIP- /!S55 0?S&Oa7 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 INTERNATIONAL PORTFOLIO, INC. 200 BAR HARBOUR DRIVE SUITE 400 WEST CONSHOHOCKEN, PA 19428 VS. SARAH E NEAL And ERIC NEAL H/W 17 MCBRIDE AVE CARLISLE PA 17013 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL ACTION NO 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. Defendants, SARAH E NEAL and ERIC NEAL, are husband and wife and are adult individuals residing at 17 MCBRIDE AVE, CARLISLE PA 17013. 3. As a result of a certain medical condition, Defendant, SARAH E NEAL, was admitted to Carlisle Regional Medical Center on 01/10/2006 and 09/03/2006. 4. Carlisle Regional Medical Center rendered services to Defendant, SARAH E NEAL, 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 $2829.97 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 Defendants, SARAH E NEAL and ERIC NEAL. 6. Said medical care was commensurate with the condition of Defendant, SARAH E NEAL, 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 Defendants 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 09/03/2006, Defendant, SARAH E NEAL, was discharged from Carlisle Regional Medical Center. 9. At or about the time that treatment was rendered, Defendant, ERIC NEAL was the spouse of Defendant, SARAH E NEAL, and is therefore liable for the cost of necessaries furnished to Defendant, SARAH E NEAL. 10. No payments have been made, and Defendants, SARAH E NEAL and ERIC NEAL, breached the agreement with Carlisle Regional Medical Center by failing and/or refusing to pay the balance of the agreed price, $2829.97, although requested to do so by Plaintiff and their attorneys. WHEREFORE, Plaintiff demands judgment against Defendants in the amount of $2829.97, plus six percent (6%) interest per annum, from the date of discharge to the date of judgment, and record and non-record costs. GE TWARDY, JR., ESQUIRE ATTORNEY FOR PLAINTIFF TWARDY D ASSOCIATES G EXHIBIT P-1 01/04/10 HEALTH MANAGEMENT ASSOCIATES DA04 COID: 858 ACCOUNT #: 9329346 DISCHARGE ACCOUNTS RECEIVABLE RECORD PAT NAME: NEAL, SARAH E ADMIT: 01/10/06 FINANCIAL CLASS: 9 P GAR NAME: NEAL, SARAH E DISCHARGE: 01/10/06 CONTRACT FREQ: S STREET: 17 MCBRIDE AVE LAST PAY: 01/10/06 MAIL RETURN: ADDR-2: PROGRAM: PAT TYPE: E1 CITY: CARLISLE PA 17013 CONTRACT: .00 PAT SEX: F PHONE: (717) 777-7777 COUNTRY: US CURR BAL: .00 GAR SEX: F EMPLOYER: HOMEMAKER TOT CHARGES: 1,261.80 AGENCY CNCL: CSA CODE DATE INSURANCE AGENCY BAL: .00 1: 978 08/13/06 1,261.80- 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 08/12/06 4: L1 03/14/06 PROCESS REVIEW PAY AUD 2: UU 08/05/06 5: S3 02/06/06 DATE USER DATE ARTRAC ASSGN: 02/07/06 RETN 03/14/06 REASON 985 11/08/07 PBY454 00/00/00 1 SOLD A/R TO IPI $1,261.80 11/08/07 PBY454 00/00/00 1 PRIM CD:CSA-UNCOLLECTABLE ; SEC CD:CSA-UNCOLLECTABL 09/21/06 ASET 00/00/00 10:11 res 717-258-6938 DETECT TRIPLE TONE 09/21/06 ASST 00/00/OC 14:04 res 717-258-6938 DETECT TRIPLE TONE 1=UP,2=PT,3=GAR,4=INS,5=UB,6=HIS,7=RTN,8=CMTI,9=CMTU,IO=DET,II=LOG,I3=ADJ,ENT=FW 4-© A Sess-1 10.200.98.7 XCAL6130 #§ 2/13 Printed on 01/04/10 16:04:59 01/04/10 HEALTH MANAGEMENT ASSOCIATES DA04 COID: 858 ACCOUNT #: 9348421 DISCHARGE ACCOUNTS RECEIVABLE RECORD PAT NAME: NEAL, SARAH E ADMIT: 09/03/06 FINANCIAL CLASS: 9 P GAR NAME: NEAL, SARAH E DISCHARGE: 09/03/06 CONTRACT FREQ: S STREET: 221 PINE SCHOOL ROAD LAST PAY: 09/03/06 MAIL RETURN: ADDR-2: PROGRAM: PAT TYPE: El CITY: GARDNERS PA 17324 CONTRACT: .00 PAT SEX: F PHONE: (717) 486-5070 COUNTRY: US CURR BAL: .00 GAR SEX: F EMPLOYER: HOMEMAKER TOT CHARGES: 1,568.17 AGENCY CNCL: CSA CODE DATE INSURANCE AGENCY BAL: .00 1: 978 07/02/07 1,568.17- CODE PLAN DATE STAT POLICY NO 2: 1: 3. 2 4. 3: 5: LST ACTN: 99 11/08/07 3: NN 12/18/06 PAY AUD 1: KK 05/10/07 4: Ll 11/28/06 PROCESS REVIEW PAY AUD 2: UU 05/03/07 5: S1 09/11/06 DATE USER DATE ARTRAC ASSGN: 10/02/06 RETN 11/28/06 REASON 985 11/08/07 PBY454 00/00/00 1 SOLD A/R TO IPI $1,568.17 11/08/07 PBY454 00/00/OC I PRIM CD:CSA-UNCOLLECTABLE ; SEC CD:CSA-UNCOLLECTABL 10/03/07 ASET 00/00/OC 15:55 res 717-486-5070 LEFT AUTO MSG 10/03/07 ASST 00/00/00 15:55 ON MACH 60906 57339 1=UP,2=PT,3=GAR,4=INS,5=UB,6=HIS,7=RTN,8=CMTI,9=CMTU,IO=DET,II=LOG,I3=ADJ,ENT=FW 4-© A Sess-1 10.200.98.7 XCAL6130 #§ 2/13 Printed On 01/04/10 16:05:21 -- 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: -7110 eena posito SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy $>sry?t+, at Ctl+fafjp?,???? FILE}-D±TICE ( Tr{E PPOTh 'C inT1 Y 2010 FEB --8 Pill 12: 01 Edward L Schorpp Solicitor International Portfolio Inc. vs. Sarah E. Neal c c _, :-Ec?:FF Case Number 2010-274 SHERIFF'S RETURN OF SERVICE 02/04/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Sarah E. Neal, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Sarah E. Neal. Nancy Caldwell, current resident at 17 McBride Avenue, Carlisle, PA 17013 advised Deputies she has resided at this address since 2008, and does not know the defendant. The Carlisle Postmaster has confirmed Sarah E. Neal is not known at 17 McBride Avenue, Carlisle, PA 17013. 02/04/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Eric Neal, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Eric Neal. Nancy Caldwell, current resident at 17 McBride Avenue, Carlisle, PA 17013 advised Deputies she has resided at this address since 2008, and does not know the defendant. The Carlisle Postmaster has confirmed Eric Neal is not known at 17 McBride Avenue, Carlisle, PA 17013. SHERIFF COST: $59.84 February 04, 2010 SO R ANDERSON, SHERIFF fc; Coun?r Suitt. Sher-!t. T@le^,sxt. In:;. �F c04, 1Davi( D. Buell Wia Renee Simpson Prothonotary .,� , 15t Deputy�rothonota o , �,r�, Z p y �' :1 era_. .. �irkS. Sofionage, ESQ A\7177..iw Irene E. Morrow Solicitor 1750 2nd Deputy Prothonotary Office of the Prothonotary Cumberland County, Pennsylvania /a - CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 291" 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 • 'Fa, ,(717)240-6573