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HomeMy WebLinkAbout10-0280LAW 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. DAVID S ROBINSON 303 A NORTH BEDFORD ST CARLISLE PA 17013 C-) a O LU "t'1 Attorney for Piair?iffT cs?:? co ???? t n r j r -? r t) CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL ACTION NO 10 - ,250 ?v?t ,r'Y1f1 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 ;wbl.0o PO A7?`1 CK.v 15µg Pd? a3(,035 Twardy and Associates, LLC By: George Twardy, Jr., Esquire Identification No. 62883 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. DAVID S ROBINSON 303 A NORTH BEDFORD ST 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, DAVID S ROBINSON, is an individual residing at 303 A NORTH BEDFORD ST, CARLISLE PA 17013. 3. As a result of a certain medical condition, Defendant, DAVID S ROBINSON, was admitted to Carlisle Regional Medical Center on 01/09/2006 through 01/09/2006. 4. Carlisle Regional Medical Center rendered services to Defendant, DAVID S ROBINSON, 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 $1256.86 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, DAVID S ROBINSON. 6. Said medical care was commensurate with the condition of Defendant, DAVID S ROBINSON, 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 01/09/2006, Defendant, DAVID S ROBINSON, was discharged from Carlisle Regional Medical Center. 9. No payments have been made, and Defendant, DAVID S ROBINSON, breached the agreement with Carlisle Regional Medical Center by failing and/or refusing to pay the balance of the agreed price, $1256.86, although requested to do so by Plaintiff and their attorneys. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $1256.86, 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 I' B GORGE TWARDY, JR., ESQUIRE ATTORNEY FOR PLAINTIFF EXHIBIT P-1 12/28/09 HEALTH MANAGEMENT ASSOCIATES DA04 COID: 858 ACCOUNT #: 9329229 DISCHARGE ACCOUNTS RECEIVABLE /09/0 RECORD FINANCIAL CLASS: 9 PAT NAME: ROBINSON, DAVID S GAR NAME: ROBINSON, DAVID S DISCHARGE: 01/09/06 CONTRACT FREQ: S STREET: 323 N WEST STREET LAST PAY: 01/09/06 MAIL RETURN: ADDR-2: PROGRAM: PAT TYPE: El CITY: CARLISLE PA 17013 CONTRACT: .00 PAT SEX: M PHONE: (717) 422-6915 COUNTRY: US CURR BAL: .00 GAR SEX: M EMPLOYER: EXEL TOT CHARGES: 1,256.86 AGENCY CNCL: CSA CODE DATE INSURANCE AGENCY BAL: .00 1: 978 09/27/06 1,256.86- CODE PLAN DATE STAT POLICY NO 2: l: 3: 2: 4: 3: 5: LST ACTN: 99 01/31/08 3: ZZ 04/24/06 PAY AUD 1: RR 09/26/06 4: L1 04/04/06 PROCESS REVIEW PAY AUD 2: UU 09/19/06 5: Sl 01/16/06 DATE USER DATE ARTRAC ASSGN: 02/06/06 RETN 04/04/06 REASON 985 01/31/08 PBY454 00/00/00 1 SOLD A/R TO IPI $1,256.86 01/31/08 PBY454 00/00/00 1 PRIM CD:CSA-UNCOLLECTABLE ; SEC CD:CSA-UNCOLLECTABL 01/25/08 PBY454 00/00/00 1 PRIM CD:CSA-UNCOLLECTABLE ; SEC CD:CSA-UNCOLLECTABL 08/14/07 MDS 00/00/00 EMPLOYMENT NUMBER DISC WRONG NUMBER 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 XCAL1099 #? 2/13 4-© A Sess-1 10.200.98.7 Printed on 12/28/09 12:09:45 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: / 4aposito SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor 4t??tt of k mjl jtlfllt IMF TNT PR(-) HrDN0 VY 2010 FEB -8 PM 12: 00 CUP; -,!NTY J International Portfolio Inc. vs. David S. Robinson Case Number 2010-280 SHERIFF'S RETURN OF SERVICE 02104/2010 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: David S. Robinson, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant David S. Robinson. The Carlisle Postmaster has advised the defendant is not known at 303A North Bedford Street, Carlisle, PA 17013. SHERIFF COST: $38.40 7RON-N RS, February 04, 2010 NDER SON, SHERIFF ,.?:Vnu=ti ?nr?^ent iee soft,I?a;. 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. DAVID S ROBINSON 303 A NORTH BEDFORD ST CARLISLE PA 17013 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS C7 -1C? CIVIL ACTION NO. 2010-280 .. PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Civil Action Complaint in the above-captioned matter. The cost of $10 for reinstatement was paid with the filing of this Praecipe. To: s ? . TWARDY & ASSOCIATES, LLC Prothonotary 20 !a ley: George Twardy Jr.,-E's_q-uire Attorney for Plaintiff, IPI 410.0c> PO k1w e* a400 ?,? X4848'7 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor International Portfolio Inc. Case Number vs. David S. Robinson 2010-280 SHERIFF'S RETURN OF SERVICE 10/04/2010 03:25 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on October 4, 2010 at 1525 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: David 5. Robinson, by making known unto himself personally, at 94 B Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the ame handing to him personally the said true and correct copy of the same. (~ /~ S SHERIFF COST: $33.40 October 05, 2010 DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF 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 NO. 10-280 Vs. C b DAVID S ROBINSON rn rn 94 B STREET X x M C5 C CARLISLE PA 17013 C.4 c. PRAECIPE FOR JUDGMENT za -?'?? M Enter Judgment in favor of Plaintiff, International Portfolio Inc., and again4 Defendant, DAVID S ROBINSON for want of an answer in the amount of: Debt: $1230.66 Interest/costs: $0.00 + ongoing Total: $1230.66 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 filing this Praecipe for not filing an answer to the complaint. DATE: l 8 l 10 George Twardy, Jr. Esquire Attorney for International Portfolio, Inc. NOW, JUDGMENT IS ENTERED ABOVE. Pr y c erk, Civil Division By: Deputy 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. 10-280 VS. DAVID S ROBINSON 94 B 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 above captioned matter has been forwarded via U.S. First Class Mail, on 1) f 19 / 10 , to the following: DAVID S ROBINSON 94 B STREET CARLISLE PA 17013 LAW MFICES OF GEORGE TWARDY, JR. By: George Twardy, Jr., Attorney for Plaintiff LAW OFFICES OF GEORGE TWARDY, JR. 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. DAVID S ROBINSON 94 B STREET CARLISLE PA 17013 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-280 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, DAVID S ROBINSON Or occupants, is over 18 years of age, and resides at 94 B STREET, CARLISLE PA 17013 This statement is made subject to the penalties of 10 PA CSS 4904 relating to unsworn falsification to authorities. Attorney for Plaintiffs 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. 10-280 VS. DAVID S ROBINSON 94 B 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 I / 19 / 10 , to the following: DAVID S ROBINSON 94 B STREET CARLISLE PA 17013 =Twardy, TWARDY, JR. u' Attorney for Plai ntiff TWAR..DY & ASSOCIATES, LLC ATTORNEYS AT LAW 11 Toll Free: 877-440-8182 www.twardyandassociates.com October 28, 2010 David S Robinson 94 B Street Carlisle PA 17013 Re: International Portfolio, Inc. v. David S Robinson Docket#: CI-10-280 Dear David S Roinson Respond hiladelphia??: avertown ? Voorhees Enclosed please find a copy of the Notice o 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. Very truly yours, GEORGE TWARDY, JR. GT/dd Enclosure SASE PHILADELPHIA OFFICES 1026 WINTER STREET NEW JERSEY OFFICES SUITE 400 22 ALPHA AVENUE PHILADELPHIA, PA 19107-1808 VOORHEES, NJ 08043 EMAIL: gtwardyesgotwardyandassociates.corn DELAWARE COUNTY OFFICES 806 DARBY ROAD HAVERTOWN, PA 19083 I Twardy and Associates, LLC By: George Twardy, Jr., Esquire. Identification No. 52883 1,026 Winter Street Suite 400 Philadelphia, PA 19107 t-877-440-8182 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY INTERNATIONAL PORTFOLIO, INC. 200 BAR HARBOUR DRIVE SUITE 400 WEST CONSHOHOCKEN, PA 19428 * NO. 20.10-280 Vs. * * DAVID S ROBINSON 303 A NORTH BEDFORD ST * CARLISLE PA 17013 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT TO: DAVID S ROBINSON Defendant DATE OF NOTICE: OCTOBER 28, 2010 Attorney for Plaintiff IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY 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 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 17013 Telephone: 717-249-3166 t-rie -wardy, Sr., Esquire - Attorney for Plaintiff, International Portfolio inc. 1026 Winter St Philadelphia, PA 19107-1808 Phone: 877-44D-8182 ID. No. 52883