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HomeMy WebLinkAbout10-0279LAW 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. NIGEL L RHOADS 2059 RELLIM STREET CARLISLE PA 17013 Attorney for Plaintifhh Z_' CUMBERLAND COUNTY x r__ COURT OF COMMON PLEAS N a c. z?• ao w r CIVIL ACTION NO 10 - a?q Ctvi t lt°I'M COMPLAINT - CIVIL ACTION 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 $ga.Ob PO A-t1t"f CI%? 15'I? -E, rn IZT* a 3 (o03a 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. NIGEL L RHOADS 2059 RELLIM STREET CARLISLE PA 17013 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, NIGEL L RHOADS, is an individual residing at 2059 RELLIM STREET, CARLISLE PA 17013. 3. As a result of a certain medical condition, Defendant, NIGEL L RHOADS, was admitted to Carlisle Regional Medical Center on 01/14/2006 through 01/14/2006. 4. Carlisle Regional Medical Center rendered services to Defendant, NIGEL L RHOADS, 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 $1098.47 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, NIGEL L RHOADS. 6. Said medical care was commensurate with the condition of Defendant, NIGEL L RHOADS, 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 01/14/2006, Defendant, NIGEL L RHOADS, was discharged from Carlisle Regional Medical Center. 9. No payments have been made, and Defendant, NIGEL L RHOADS, breached the agreement with Carlisle Regional Medical Center by failing and/or refusing to pay the balance of the agreed price, $1098.47, although requested to do so by Plaintiff and their attorneys. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $1098.47, plus six percent (6%) interest per annum, from the date of discharge to the date of judgment, and record and non-record costs. ASSOCIATES G GE TWARDY, JR., ESI ATTORNEY FOR PLAINTIFF EXHIBIT P-1 12/28/09 HEALTH MANAGEMENT ASSOCIATES DA04 COID: 858 ACCOUNT #: 9329585 DISCHARGE ACCOUNTS RECEIVABLE RECORD PAT NAME: RHOADS, NIGEL L ADMIT: 01/14/06 FINANCIAL CLASS: 9 GAR NAME: RHOADS, NIGEL L DISCHARGE: 01/14/06 CONTRACT FREQ: S STREET: 26 W GLEBE AVE LAST PAY: 03/17/06 MAIL RETURN: ADDR-2: PROGRAM: PAT TYPE: E1 CITY: NEWVILLE PA 17241 CONTRACT: .00 PAT SEX: M PHONE: (717) 701-1322 COUNTRY: US CURR BAL: .00 GAR SEX: M EMPLOYER: CARLISLE FOODS TOT CHARGES: 1,634.17 AGENCY CNCL: SA CODE DATE INSURANCE AGENCY BAL: .00 1: 967 03/17/06 326.84- CODE PLAN DATE STAT POLICY NO 2: 120 03/17/06 289.86- 1: 120 PHC 03/17/06 1,634 P 01378819TPA 3: 978 12/03/06 1,017.47- 2: 4: 3: 5: LST ACTN: 99 01/31/08 3: ZZ 07/10/06 PAY AUD 1: RR 12/02/06 4: Ll 06/20/06 PROCESS REVIEW PAY AUD 2: UU 11/25/06 5: Sl 03/20/06 DATE USER DATE ARTRAC ASSGN: 03/21/06 RETN 06/21/06 REASON 985 01/31/08 PBY454 00/00/00 I SOLD A/R TO IPI $1,017.47 01/31/08 PBY454 00/00/00 I PRIM CD:CSA-UNCOLLECTABLE SEC CD:CSA-UNCOLLECTABL 01/25/08 PBY454 00/00/00 I PRIM CD:CSA-UNCOLLECTABLE SEC CD:CSA-UNCOLLECTABL 02/08/07 MDS 00/00/00 LETTER PL2 SENT TO THE DEBTOR 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 XCAL6009 #§ 2/13 Printed on 12/28/09 16:23:44 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: L. a posito SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp SOI%CItOr ~~~''~~~' of ~auuGe~.f~r J~j .~ ~ _~~ ~ s`-, ` u~ ,'-- ^ a ~ ~ ~, ~ :. i ~ ~ ~;~; f 2I~ J~~~ e ~ i~i~ .5' ~~ t' L +,,,. ~~ k~ t , . :i?a International Portfolio Inc. vs. Nigel L. Rhoads Case Number 2010-279 SHERIFF'S RETURN OF SERVICE 01/21/2010 09:05 AM -Jason Vioral, Sergeant, who being duly sworn according to law, states that on January 21, 2010 at 0905 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Nigel L. Rhoads, by making known unto himself personally, at The Cumberland County Sheriffs Office, 1 Courthouse Square Room 303, 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 SO WE NNY R ANDERSON, SHERIFF Ssrge t p' Cau,' Su;tn S. ~,~rtf. Te'~e•cs~'t. Inc.