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HomeMy WebLinkAbout10-0281LAW 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. AZEM JUSOVIC 512 79TH TERRACE NORTH BLDG 5 SAINT PETERSBURG FL 33702 ?-- N La l1 L Attorney for Pla gf co CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL ACTION NO lb-0181 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 CLARSAED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS RAPORTANT 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 sqa. oo P b Anry GL-V (54(p 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. AZEM JUSOVIC 512 79TH TERRACE NORTH BLDG 5 SAINT PETERSBURG FL 33702 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, AZEM JUSOVIC, is an individual residing at 512 79TH TERRACE NORTHBLDG 5, SAINT PETERSBURG FL 33702. 3. As a result of a certain medical condition, Defendant, AZEM JUSOVIC, was admitted to Carlisle Regional Medical Center on 01/27/2006 through 01/27/2006. 4. Carlisle Regional Medical Center rendered services to Defendant, AZEM JUSOVIC, 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 $3120.76 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, AZEM JUSOVIC. 6. Said medical care was commensurate with the condition of Defendant, AZEM JUSOVIC, 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 01/27/2006, Defendant, AZEM JUSOVIC, was discharged from Carlisle Regional Medical Center. 9. No payments have been made, and Defendant, AZEM JUSOVIC, breached the agreement with Carlisle Regional Medical Center by failing and/or refusing to pay the balance of the agreed price, $3120.76, although requested to do so by Plaintiff and their attorneys. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $3120.76, 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 C O 4 RGE TWARDY, JR., ESQUIRE ATTORNEY FOR PLAINTIFF EXHIBIT P-1 01/04/10 HEALTH ACCOUNT #: 9329261 DISCHARGE PAT NAME: JUSOVIC, AZEM GAR NAME: JUSOVIC, AZEM STREET: 227 WEST NORTH STREET ADDR-2: CITY: CARLISLE PHONE: (717) 701-0810 EMPLOYER: EXEL CODE DATE 1: 978 08/13/06 1,557 2: 3: 4: 5: PROCESS DATE USER 11/08/07 PBY454 11/08/07 PBY454 02/09/07 ASET 02/09/07 ASET MANAGEMENT ASSOCIATES ACCOUNTS RECEIVABLE RECORD ADMIT: 01/09/06 DISCHARGE: 01/09/06 LAST PAY: 01/09/06 PROGRAM: PA 17013 CONTRACT: .00 DA04 COID: 858 FINANCIAL CLASS: CONTRACT FREQ: MAIL RETURN: PAT TYPE: PAT SEX: COUNTRY: US CURR BAL: .00 GAR SEX: TOT CHARGES: 1,557.14 AGENCY CNCL: INSURANCE AGENCY BAL: .14- CODE PLAN DATE STAT POLICY 1: 2: 3: LST ACTN: 99 11/08/07 3: NN PAY AUD 1: KK 08/12/06 4: Ll REVIEW PAY AUD 2: UU 08/05/06 5: PP DATE ARTRAC ASSGN: 02/15/06 RETN 03/21/06 00/00/00 1 SOLD A/R TO IPI $1,557.14 00/00/00 1 PRIM CD:CSA-UNCOLLECTABLE ; SEC CD:1 00/00/00 14:45 is #17 ; Copied Acct: 133259 00/00/00 14:45 is #17 60670 53126 9 P S El M M CSA .00 NO 03/31/06 03/21/06 02/14/06 REASON 985 ?SA-UNCOLLECTABL 60670 53126 1 UP,2=PT,3=GAR,4=INS,5=[JB,6=HIS,7=RTN,8=CMTI,9=CMTU,10=DET,II=LOG,I3=ADJ,ENT=FW 4-© _ A Sess-1 10.200.98.7 XCAL5067 #§ 2/13 Printed on 01/04/10 12:57:08 --- 01/04/10 HEALTH MANAGEMENT ASSOCIATES DA04 COID: 858 ACCOUNT #: 7569187 DISCHARGE ACCOUNTS RECEIVABLE RECORD PAT NAME: JUSOVIC, AZEM ADMIT: 01/27/06 FINANCIAL CLASS: 9 P GAR NAME: JUSOVIC, AZEM DISCHARGE: 01/27/06 CONTRACT FREQ: S STREET: 860 CARLWYNNE MANOR A308 LAST PAY: 01/27/06 MAIL RETURN: ADDR-2: PROGRAM: PAT TYPE: OM CITY: CARLISLE PA 17013 CONTRACT: .00 PAT SEX: M PHONE: (717) 241-9720 COUNTRY: US CURR BAL: .00 GAR SEX: M EMPLOYER: EXEL TOT CHARGES: 1,563.62 AGENCY CNCL: CSA CODE DATE INSURANCE AGENCY BAL: .00 1: 978 09/24/06 1,563.62- CODE PLAN DATE STAT POLICY NO 2: 1: 3: 2: 4. 3. 5: LST ACTN: 99 11/08/07 3: NN 05/15/06 PAY AUD 1: KK 09/23/06 4: Ll 04/30/06 PROCESS REVIEW PAY AUD 2: UU 09/16/06 5: Sl 02/20/06 DATE USER DATE ARTRAC ASSGN: 02/24/06 RETN 04/30/06 REASON 985 11/08/07 PBY454 00/00/00 SOLD A/R TO IPI $1,563.62 11/08/07 PBY454 00/00/00 PRIM CD:CSA-UNCOLLECTABLE ; SEC CD:CSA-UNCOLLECTABL 02/09/07 ASET 00/00/00 14:45 is #17 ; Copied Acct: 133259 60670 53126 02/09/07 ASET 00/00/00 14:45 is #17 60670 53126 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 XCAL5067 #§ 2/13 Printed on 01/04/10 12:56:48 - 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 (' Of CV David�. �ueCC e Renee X Simpson prothonota P D 1St Deputy prothonotary it '�� I°7 y ' Irene E. Morrow �' ks Sohonage, ESQ __.. y Solicitor ,75o 2"'Deputy prothonotary Office of the Prothonotary Cumberland County, Pennsylvania 1Q "`42_$1 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 291H 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 • 'Faz(717)240-6573