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HomeMy WebLinkAbout10-0675LAW 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. JEFFERY V EVANS 331 LANTERN LN LOT 40 CHAMBERSBURG PA 17201-3299 :4 T1 Attorney for Plaintiff t ._ -JO CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL ACTION NO 10 - (v'15 a-witIErm 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 0% 32 SOUTH BEDFORD STREET ga. OO P D CARLISLE, PA 17013 1-800-990-9108 CIG 157a 717-249-3166a 3(0 8(0?{ A`rW 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. JEFFERY V EVANS 331 LANTERN LN LOT 40 CHAMBERSBURG PA 17201-3299 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, JEFFERY V EVANS, is an individual residing at 331 LANTERN LNLOT 40, CHAMBERSBURG PA 17201-3299. 3. As a result of a certain medical condition, Defendant, JEFFERY V EVANS, was admitted to Carlisle Regional Medical Center on 02/17/2006 through 02/17/2006. 4. Carlisle Regional Medical Center rendered services to Defendant, JEFFERY V EVANS, 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 $1363.48 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, JEFFERY V EVANS. 6. Said medical care was commensurate with the condition of Defendant, JEFFERY V EVANS, 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 02/17/2006, Defendant, JEFFERY V EVANS, was discharged from Carlisle Regional Medical Center. g. No payments have been made, and Defendant, JEFFERY V EVANS, breached the agreement with Carlisle Regional Medical Center by failing and/or refusing to pay the balance of the agreed price, $1363.48, although requested to do so by Plaintiff and their attorneys. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $1363.48, 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 G ORGE TWARDY, JR., ESQUIRE ATTORNEY FOR PLAINTIFF EXHIBIT P-1 01/21/10 HEALTH MANAGEMENT ASSOCIATES DA04 COID: 858 ACCOUNT #: 8226773 DISCHARGE ACCOUNTS RECEIVABLE RECORD PAT NAME: EVANS, JEFFERY ADMIT: 02/17/06 FINANCIAL CLASS: 9 I GAR NAME: EVANS, JEFFERY DISCHARGE: 02/17/06 CONTRACT FREQ: S STREET: 173 E PENN ST LAST PAY: 04/10/06 MAIL RETURN: ADDR-2: PROGRAM: PAT TYPE: OS CITY: CARLISLE PA 17013 CONTRACT: .00 PAT SEX: M PHONE: (717) 385-5351 COUNTRY: US CURR BAL: .00 GAR SEX: M EMPLOYER: CARLISLE TIRE AND WHEEL TOT CHARGES: 10,616.12 AGENCY CNCL: CSA CODE DATE INSURANCE AGENCY BAL: .00 1: 967 04/10/06 2,123.22- CODE PLAN DATE STAT POLICY NO 2: 950 04/10/06 7,129.42- 1: 950 PHC 04/10/06 10,616 P 69030249111901 3: 978 01/25/07 1,363.48- 2: 4. 3. 5: LST ACTN: 99 11/08/07 3: TT 06/26/06 PAY AUD 1: QQ 01/24/07 4: Ll 06/08/06 PROCESS REVIEW PAY AUD 2: UU 01/17/07 5: Sl 04/10/06 DATE USER DATE ARTRAC ASSGN: 04/18/06 RETN 06/08/06 REASON 985 11/08/07 PBY454 00/00/00 1 SOLD A/R TO IPI $1,363.48 11/08/07 PBY454 00/00/00 1 PRIM CD:CUN-UNCOLLECTABLE ; SEC CD:CSA-UNCOLLECTABL 05/15/07 JBAO 00/00/00 TPOE NO CALLS 04/05/07 JBAO 00/00/00 TREF 9 WRONG # 1=UP,2=PT,_3=GAR,4=INS,5=UB,6=HIS,7=RTN,8=CMTI,9=CMTU,I0=D_ET,II=LOG,I3=ADJ,ENT=FW 4-© A Sess-1 10.200.98.7 XCAL1162 _ #§ 2/13 Printed on 01/21/10 10:24:04 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 Gina Sposito LAW OFFICE OF GEORGE TWARDY, JR Attorney ID: 52883 1026 Winter Street Suite 400 Philadelphia, PA 19107 215-440-8722 INTERNATIONAL PORTFOLIO INC VS. Jeffery V. Evans PRAECIPE TO REINSTATE PRAECIPE In the Court of Common Pleas of Cumberland County MARCH 5, 20 10 No. 10-675 cn ? C- - ? -,M Kindly Reinstate the complaint in the above captioned matter which was originally filed with the Prothonotary on January 27th, 20010. The cost of $10.00 for reinstatement was included with the filing of this Praecipe. George Twardy, Jr, Esquire Attorney for Plaintiff To: Prothonotary ,20 (i) 10.00 PA AT" 0TV 0111 a389?F/ 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. JEFFERY V EVANS 331 LANTERN LN LOT 40 CHAMBERSBURG PA 17201-3299 ~ n' NO. 10-675 ~ ' t . ~ ~^ ~- . - 1 ~„ "=~~ PRAECIPE FOR JUDGMENT Enter Judgment in favor of Plaintiff, International Portfolio Inc., and against Defendant, JEFFERY V EVANS for want of an answer in the amount of: Debt: $1363.48 Interest/costs: $182.00 + ongoing Total: $1545.48 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 o 's Praecipe for not filing an answer to the compl~a/int DATE: Za (~ George Twardy, Jr. Esquire Attorney for International Portfolio, Inc. NOW, l0 JUDGMENT IS ENTERED ABOVE. c Pro /clerk, Civil Di ision By: ~I~.00 PO 14`n'~ Deputy C~ o'~a.'1~{ 12~a~ (03a'~ 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. 10-675 vs. JEFFERY V EVANS 331 LANTERN LN LOT 40 CHAMBERSBURG PA 17201-3299 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 _ ~ Z g 2~ ~ to the following: JEFFERY V EVANS 331 LANTERN LN LOT 40 CHAMBERSBURG PA 17201-3299 TW AND ASSOCIATES, LLC ___. By: eorge Twardy, Jr., Esquire Attorney for Flaintiff 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. JEFFERY V EVANS 331 LANTERN LN LOT 40 CHAMBERSBURG PA 17201-3299 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-675 VERIFICATION OFNON-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, JEFFERY V EVANS Or occupants, is over 18 years of age, and resides at 331 LANTERN LN LOT 40, CHAMBERSBURG PA 17201-3299 This statement is made subject to the penalties of 10 PA CSS 4904 relating to unsworn falsification to authorities. 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. 10.675 vs. JEFFERY V EVANS 331 LANTERN LN LOT 40 CHAMBERSBURG PA 17201-3299 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 ? 2 (~, to the following: JEFFERY V EVANS 331 LANTERN LN LOT 40 CHAMBERSBURG PA 17201-3299 TWARDY AND ASSOCIATES, LLC .-----` - B .George Twardy, Jr., Es Attorney for Plaintiff Office of Prothonotary of Court of Common Pleas of Cumberland County NOTICE OF ENTRY OF JUDGMENT, ORDER OR DECREE INTERNATIONAL PORTFOLIO, INC, Plaintiff Case Number 16-675 VS 7 E F F E RY V EVANS, Defendant Pursuant to requirements of Pennsylvania Civil Procedural Rule #236, you are notified that there was entered in this office today, in the above-captioned case - a Judgment of $1545.48 for Plaintiff and against Defendant. -Judgment for Defendant and against Plaintiff. -Order or Decree in favor of Date: Mailed: First Class Mail To: JEFFERY V EVANS 331 LANTERN LN LOT 40 CHAMBERSBURG PA 17201-3299 PROTHONOTAR ~~S/la 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. 10-675 vs. JEFFERY V EVANS 331 LANTERN LN LOT 40 CHAMBERSBURG PA 17201-3299 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 forwarded via U.S. First Class Mail, on ~ l 1-~jJ , to the following: JEFFERY V EVANS 331 LANTERN LN LOT 40 CHAMBERSBURG PA 17201-3299 TWARDY AND ASSOCIATES, LLC eorge Twardy, Jr., e Attorney for Plaintiff TWARDY 8t ASSOCIATES, LLC Respond to: ATTORNEYS AT LAW ~Phlladelphia Toil Free: 877-440-8182 ^ Havertown ^ Voomees www.twardyandassociates.com Apri121, 2010 JEFFERY V EVANS 331 LANTERN LN CHAMBERSBURG PA 17201-3299 RE: INTERNATIONAL PORTFOLIO, INC. v. JEFFERY V EVANS Docket: I0-675 COURT OF COMMON PLEAS CUMBERLAND COUNTY Dear JEFFERY V EVANS, 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, ~ ./ --~~ _ George Twardy, Jr, Esq. Attorrxey for Plaintiff, International Portfolio, Inc. GT/pr Encl. PHILADELPHIA OFFECFS 1026 WINTER STREET NEW JERSEY OFFICES SUITE 400 22 ALPHA AVENUE PHILADELPHIA, PA 1 9 7 47-1 848 VOORHEES, NJ 08043 EMAIL: gtwardyesq®twardyandassociates.com DELAWARE COUNTY OFFICES 808 OARBY ROAD HAVERTOWN, PA 18083 Twardy and Associates, LLC By: Ceorge Twardy, Jr., Esquire Identif[cation 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 DR[VE * SUITE 400 WEST CONSHO.HOCKEN, PA 19428 * NO.10-675 vs. * JEF'FERY V EVANS 33i LANTERN LNLOT 40 CHAMBERSBURG PA 17201-3299 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT TO: JEFFERY V EVANS Defendant / DATE OF NOTICE: ~ Z 1 / 7r~j G 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 17D13 Telephone: 7-249-3166 _ ~ ~~-~ George Twardy, Jr., Esquire Attorney for Plaintitly International Portfolio Inc. 1026 Winter St Philadelphia, PA 19107-1808 Phone: 877-440-8182 ID. No. 52883