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HomeMy WebLinkAbout10-0277LAW 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. TERRY L COANT 519 SOUTH WEST ST APT C CARLISLE PA 17013 n Attorney for Plain 1'x'3 r- j1- CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL ACTION NO 10- a'71 COMPLAINT - CIVIL ACTION N d 0 c.. L. o? c.a .c- 0 R i M rn C) J rn 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 49a.oc Pa ATT`/ 717-249-3166 ct;o 1553 I?31 a,%050 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 L COANT 519 SOUTH WEST ST APT C CARLISLE PA 17013 COMPLAINT 1. Plaintiff, International Portfolio, Inc., is the Assignee of the debt from Carlisle Regional Medical Center, with offices in CUMBERLAND county, 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 L COANT, is an individual residing at 519 SOUTH WEST STAPT C, CARLISLE PA 17013. 3. As a result of a certain medical condition, Defendant, TERRY L COANT, was admitted to Carlisle Regional Medical Center on 01/21/2006, 01/27/2006, and 02/01/2006. 4. Carlisle Regional Medical Center rendered services to Defendant, TERRY L COANT, of the kinds and for the prices set forth in their bill which is now part of Plaintiffs records and is set forth as Exhibit P-1. 5. The charges of $5360.26 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 L COANT. 6. Said medical care was commensurate with the condition of Defendant, TERRY L COANT, 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 02/01/2006, Defendant, TERRY L COANT, was last discharged from Carlisle Regional Medical Center. 9. No payments have been made, and Defendant, TERRY L COANT, breached the agreement with Carlisle Regional Medical Center by failing and/or refusing to pay the balance of the agreed price, $5360.26, although requested to do so by Plaintiff and their attorneys. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $5360.26, 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 GEORGE TWARDY, JR., ESQUIRE ATTORNEY FOR PLAINTIFF EXHIBIT P-1 01/06/10 HEALTH MANAGEMENT ASSOCIATES DA04 COID: 858 ACCOUNT #: 9330075 DISCHARGE ACCOUNTS RECEIVABLE RECORD PAT NAME: COANT, TERRY L ADMIT: 01/21/06 FINANCIAL CLASS: 9 P GAR NAME: COANT, TERRY L DISCHARGE: 01/21/06 CONTRACT FREQ: S STREET: 20 MUENCH ST # 1 LAST PAY: 01/21/06 MAIL RETURN: ADDR-2: PROGRAM: PAT TYPE: E1 CITY: HARRISBURG PA 17102 CONTRACT: .00 PAT SEX: M PHONE: (717) 701-1265 COUNTRY: US CURR BAL: .00 GAR SEX: M EMPLOYER: HOLIDAY INN TOT CHARGES: 2,656.44 AGENCY CNCL: CSA CODE DATE INSURANCE AGENCY BAL: .00 1: 978 09/27/06 2,656.44- CODE PLAN DATE STAT POLICY NO 2: 3: 4: 5: PROCESS REVIEW DATE USER DATE 11/08/07 PBY454 00/00/CO 11/08/07 PBY454 00/00/CO 09/04/06 ASET 00/00/00 09/04/06 ASET 00/00/00 1: 2: 3: LST ACTN: 99 PAY AUD 1: QQ PAY AUD 2: UU 11/08/07 3: TT 05/10/06 09/26/06 4: Ll 05/08/06 09/19/06 5: S3 04/17/06 I SOLD A/R TO IPI $2,656.44 1 PRIM CD:CUN-UNCOLLECTABLE ; SEC CD:CSA-UNCOLLECTABL 18:34 is #57 18:34 is #57 ; Copied Acct: 53011574 1=_UP,2=PT,3=GAR,4=INS,5=UB,6=HIS,7=RTN,8=CMTI,9=CMTU,IO=DET,II=LOG,1_3_=_ADJ,ENT=FW 4_-© _ A Sess-1 10.200.98.7 XCAL3201 _#§ 2/13 Printed on 01/06/10 10:55:11 01/06/10 HEALTH MANAGEMENT ASSOCIATES DA04 COID: 858 ACCOUNT #: 9330499 DISCHARGE ACCOUNTS RECEIVABLE RECORD PAT NAME: COANT, TERRY L ADMIT: 01/27/06 FINANCIAL CLASS: 9 P GAR NAME: COANT, TERRY L DISCHARGE: 01/27/06 CONTRACT FREQ: S STREET: 208 MUENCH ST #1 LAST PAY: 01/27/06 MAIL RETURN: ADDR-2: PROGRAM: PAT TYPE: E1 CITY: HARRISBURG PA 17102 CONTRACT: .00 PAT SEX: M PHONE: (717) 701-1265 COUNTRY: US CURR BAL: 00 GAR SEX: M EMPLOYER: NOT EMP TOT CHARGES: 976.00 AGENCY CNCL: CSA CODE DATE INSURANCE AGENCY BAL: .00 1: 978 09/27/06 976.00- CODE PLAN DATE STAT POLICY NO 2. 1: 3. 2. 4. 3. 5: LST ACTN: 99 11/08/07 3: TT 04/28/06 PAY AUD 1: QQ 09/26/06 4: L1 04/20/06 PROCESS REVIEW PAY AUD 2: UU 09/19/06 5: S1 01/31/06 DATE USER DATE ARTRAC ASSGN: 02/24/06 RETN 04/20/06 REASON 985 11/08/07 PBY454 00/00/00 1 SOLD A/R TO IPI $976.00 11/08/07 PBY454 00/00/00 1 PRIM CD:CUN-UNCOLLECTABLE ; SEC CD:CSA-UNCOLLECTABL 09/11/06 ASET 00/00/00 16:08 DHE FIANCE CI STS DNT LIVE THERE ANY LONGER 09/04/06 ASET 00/00/00 18:34 is #57 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 XCAL3201 _ #§ 2/13 __ Printed on 01/06/10 10:55:41 01/06/10 HEALTH MANAGEMENT ASSOCIATES DA04 COID: 858 ACCOUNT #: 9330884 DISCHARGE ACCOUNTS RECEIVABLE RECORD PAT NAME: COANT, TERRY L ADMIT: 02/01/06 FINANCIAL CLASS: 9 P GAR NAME: COANT, TERRY L DISCHARGE: 02/01/06 CONTRACT FREQ: S STREET: 601 N PITT ST LAST PAY: 02/01/06 MAIL RETURN: ADDR-2: PROGRAM: PAT TYPE: E1 CITY: CARLISLE PA 17013 CONTRACT: .00 PAT SEX: M PHONE: (717) 386-711.1 COUNTRY: US CURR BAL: .00 GAR SEX: M EMPLOYER: NOT EMP TOT CHARGES: 1,727.82 AGENCY CNCL: CSA CODE DATE INSURANCE AGENCY BAL: .00 1: 978 09/27/06 1,727.82- CODE PLAN DATE STAT POLICY NO 2: 1: 3: 2. 4. 3. 5: LST ACTN: 99 11/08/07 3: TT 05/10/06 PAY AUD 1: QQ 09/26/06 4: L1 05/07/06 PROCESS REVIEW PAY AUD 2: UU 09/19/06 5: S3 02/28/06 DATE USER DATE ARTRAC ASSGN: 03/01/06 RETN 05/07/06 REASON 985 11/08/07 PBY454 00/00/00 1 SOLD A/R TO IPI $1,727.82 11/08/07 PBY454 00/00/00 1 PRIM CD:CUN-UNCOLLECTABLE ; SEC CD:CSA-UNCOLLECTABL 09/04/06 ASET 00/00/00 18:34 is #57 09/04/06 ASET 00/00/00 18:34 is #57 ; Copied Acct: 53011574 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 XCAL3201 #§ 2/13 Printed on 01/06/10 10:54:42 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:- / / ;7 1 (-) Gina Sposito SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff FILQ y pvti141t p rrrrr,CFr f+}'! kl 1l l tit Jody S Smith Chief Deputy ? d10 JAIN 25 AN 11: 5:3 Edward L Schorpp Solicitor International Portfolio Inc. VS. Terry L. Coant Case Number 2010-277 SHERIFF'S RETURN OF SERVICE 01/20/2010 03:33 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on January 20, 2010 at 1533 hours, he served a true copy of the within Complaint and Notice, upon the withir named defendant, to wit: Terry L. Coant, by making known unto himself personally, at 601 N. Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $33.40 January 21, 2010 S S ONNY R ANDERSON, SHERIFF By W- Deputy Sheriff ?d; Gougry5uite 5"er?ff, i'eieosofil_ !nc_ 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 L COANT 601 North Pitt Street CARLISLE PA 17013 n . c~- NO. 10-277 ~'- ~~ -'~ ~~ ct .~ ---- • =~4c; :- W c._ PRAECIPE FOR JUDGMENT Enter Judgment in favor of Plaintiff, International Portfolio Inc., and against Defendant, TERRY L COANT for want of an answer in the amount of: Debt: $5360.26 Interest/costs: $125.40 + ongoing Total: $5485.66 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 f this Praecipe for not filing an answer to the complaint: DATE: Z ~ ~` f eorge Twardy, Jr. Esquire Attorney for International Portfolio, Inc. NOW, '~ aoio JUDGMENT IS ENTERED ABOVE. r o /cler , it Division By:_ Deputy #I~.oo Pp ~A~ e~ aa~~ E~ a N la~.a ~akea, ~..buJuc~ 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 NO. 10-277 vs. TERRY L COANT 601 North Pitt Street CARLISLE PA 17013 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 a>*ove captioned matter has been forwarded via U.S. First Class Mail, on _ . ~~, to the following: TERRY L COANT 601 North Pitt Street CARLISLE PA 17013 TWA,~Y AND ASSOCIATES, LLC George Twardy, Jr., wire 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 L COANT 601 North Pitt Street CARLISLE PA 17013 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-277 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 L COANT Or occupants, is over 18 years of age, and resides at 601 North Pitt Street ,CARLISLE PA 17013 This statement is made subject to the penalties of 10 PA CSS 4904 relating to unsworn falsification to authorities. George 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 NO. 10-277 vs. TERRY L COANT 601 North Pitt Street CARLISLE PA 17013 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 _`_~ '; v , to the following: TERRY L COANT 601 North Pitt Street CARLISLE PA 17013 TWA~Y AND ASSOCIATES, LLC ~i George 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 NO. 10.277 vs. TERRY L COANT 601 North Pitt Street CARLISLE PA 17013 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 E forwarded via U.S. First Class Mail, on ~ ~'/d, to the following: TERRY L COANT 601 North Pitt Street CARLISLE PA 17013 LA FILES OF GEORGE TWARDY, JR. eorge Twardy, Jr., squire Attorney for Plaintiff TWARDY S•L ASSOCIATES, LLC ATTORNEYS AT LAW ''f' Toll Free: 877-440-8182 www+.twardyandassociates.corn April S, 2010 TERRY L COANT 519 SOUTH WEST ST CARLISLE PA 17013 Resp/o~nd to: l71 Philadelphia C1 Havertown Q Voorhees RE: INTERNATIONAL PORTFOLIO, INC. v. TERRY L COANT Docket: 10-277 COURT OF COMMON PLEAS CUMBERLAND COUNTY Dear TERRY L COANT, Enclosed please find a copy of the Notice of Praecipe to Enter Judgment by Default. You are advised to take the appropriate legal action immediately so as to avoid judgment being entered against you in this matter. If you wish to amicably resolve this matter please feel free to call our.. office at the above toll free number. Sincerely, ",~ d George Twardy, Jr, Esq. Attorney for Plaintiff, International Portfolio, Inc. GT/pr Encl. PHILADELPHIA OFFICES 1026 VYINTER STREET NEW JERSEY OFFICES _ SUITE 400 22 ALPHA AVENUE PHILADELPHIA, PA 19107-1808 VOORHEES, NJ 08043 EMAIL: gtwardyesq~iwardyarMassociates.com DELAWARE COUNTY OFFICES 808 DARBY ROAD HAVERTOWN, PA 19083 Twardy and Associates, LLC By: George Twardy, Jr., Esquire Identification No. 52883 1026 Winter 5trcct 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 SULTE 400 * WEST CONSHOHOCKEN, PA 19428 * NO. 10-277 vs. * TERRY L COANT 519 SOUTH WEST 5TAPT C CARLISLE PA 17013 NOTICE OF PRA FCIPE TO ENTER J m~.naFNT BY DEFAULT T0: TERRY L COANT Defen ant ~,~~~~"D DATE OF NOTICE: IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR IiY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN {10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTX 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 17013 Telephone: 717-249-316fi (?eorgb Twardy, Jr., Esquire Attorney for Plaintiff, •International Paertfolio Inc. 1026 Winter St Philadelphia, PA 19107-1808 Phone: 877-440-8182 1D. No. 52883