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HomeMy WebLinkAbout10-0674LAW 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. FERIDA TODOROVAC And HILMAJA TODOROVAC 7 E SOUTH STREET CARLISLE PA 17013 H/W Attorney for PlainF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL ACTION NO 10 - (M COMPLAINT - CIVIL ACTION N ?J T- c. , -T, ?a CAA t I kerM YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAWS 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 *Aa- d0 PA Alr-f C1C.,# 15,1D 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. FERIDA TODOROVAC And HILMAJA TODOROVAC 7 E SOUTH STREET CARLISLE PA 17013 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL ACTION NO H/W . COMPLAINT -7 q r-.vI I clime 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, FERIDA TODOROVAC and HILMAJA TODOROVAC, are husband and wife and are adult individuals residing at 7 E SOUTH STREET, CARLISLE PA 17013. 3. As a result of a certain medical condition, Defendant, FERIDA TODOROVAC, was admitted to Carlisle Regional Medical Center on 02/02/2006 through 02/02/2006. 4. Carlisle Regional Medical Center rendered services to Defendant, FERIDA TODOROVAC, 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 $943.61 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, FERIDA TODOROVAC and HILMAJA TODOROVAC. 6. Said medical care was commensurate with the condition of Defendant, FERIDA TODOROVAC, 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 02/02/2006, Defendant, FERIDA TODOROVAC, was discharged from Carlisle Regional Medical Center. 9. At or about the time that treatment was rendered, Defendant, HILMAJA TODOROVAC was the spouse of Defendant, FERIDA TODOROVAC, and is therefore liable for the cost of necessaries furnished to Defendant, FERIDA TODOROVAC. 10. No payments have been made since 11/15/2006, and Defendants, FERIDA TODOROVAC and HILMAJA TODOROVAC, breached the agreement with Carlisle Regional Medical Center by failing and/or refusing to pay the remaining balance of, $943.61, although requested to do so by Plaintiff and their attorneys. WHEREFORE, Plaintiff demands judgment against Defendants in the amount of $943.61, 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: GEORGE TWARDY, JR., ESQUIRE ATTORNEY FOR PLAINTIFF EXHIBIT P-1 01/22/10 HEALTH MANAGEMENT ASSOCIATES DA04 COID: 858 ACCOUNT #: 9330991 DISCHARGE ACCOUNTS RECEIVABLE RECORD PAT NAME: TODOROVAC, FERIDA ADMIT: 02/02/06 FINANCIAL CLASS: 9 GAR NAME: TODOROVAC, FERIDA DISCHARGE: 02/02/06 CONTRACT FREQ: S STREET: 7 E SOUTH STREET LAST PAY: 11/15/06 MAIL RETURN: ADDR-2: PROGRAM: PAT TYPE: E1 CITY: CARLISLE PA 17013 CONTRACT: .00 PAT SEX: F PHONE: (717) 218-8975 COUNTRY: US CURR BAL: .00 GAR SEX: F EMPLOYER: ROSS DISTRIBUTION WCOMP TOT CHARGES: 1,018.61 AGENCY CNCL: CSA CODE DATE INSURANCE AGENCY BAL: .00 1: 972 11/15/06 45.00 CODE PLAN DATE STAT POLICY NO 2: 150 11/15/06 45.00- 1: 200 KCE 12/21/06 1,018 P YWV80061775601 3: 200 1.2/21/06 500.21 2: 4: 951 1.2/27/06 443.40 3: 5: 978 04/12/07 943.61- LST ACTN: 99 01/31/08 3: ZZ 6/06 4• L1 PROCESS REVIEW DATE USER DATE 01/31/08 PBY454 00/00/00 01/31/08 PBY454 00/00/00 01/25/08 PBY454 00/00/00 04/12/07 858105 00/00/00 PAY AUD 1: RR 09/2 PAY AUD 2: UU 09/19/06 5: S3 04/24/06 04/10/06 03/27/06 SOLD A/R TO IPI $943.61 1 PRIM CD:CSA-UNCOLLECTABLE SEC CD:CSA-UNCOLLECTABL PRIM CD:CSA-UNCOLLECTABLE SEC CD:CSA-UNCOLLECTABL 978 W/O ...DJC 1=UP,2=PT,3=GAR,4=INS,S=UB,6=HIS,7=RTN,8=CMTI,9=CMTU,I0=DET,II=LOG, I3=ADJ,ENT=FW - -- - - XCAL3037_____ - #§ 2/13 4-© A Sess-1 10.200.98.7 -- Printed on 01/22/10 09:48:09 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: ?Z ? ` t7 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy ~~,~att~ of i"uiuGr~~~,~ir~ ,, _ ~~ ~IL~ Jf=riG~ ~,~ ~-~.,~ ~ ~~-rj_.~~~ i~TARY Z~~~f~~ ~~ ~i~`'~~ Q~+ Edward L Schorpp Solicitor r~l~da~~t ~; International Portfolio Inc. vs. Ferida Todorovac and/or Hilmaja Todorovac Case Number 2010-674 SHERIFF'S RETURN OF SERVICE 01/28/2010 09:20 AM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on January 28, 2010 at 0917 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Ferida Todorovac and/or Hilmaja Todorovac, by making known unto Ferida Todorovac, at 7 E. South Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. Ferida Todorovac's son translated for Sheriffs service. SHERIFF COST: $33.40 February 03, 2010 SO ANS ERS, O NY R ANDERSON, SHERIFF Deputy Sherif ;r.. CamfySuRe 5t`eriff. Teleaso`t. Irn:.