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HomeMy WebLinkAbout10-0676LAW OFFICES OF GEORGE TWARDY, JR. BY: GEORGE TWARDY, JR., ESQUIRE Attorney for Plaintiff Attorney ID: 52883 1026 Winter Street, Suite 400 Philadelphia, PA 19107-1808 1-877-440-8182 INTERNATIONAL PORTFOLIO, INC. 200 BAR HARBOUR DRIVE CUMBERLAND COUNTY SUITE 400 COURT OF COMMON PLEAS WEST CONSHOHOCKEN, PA 19428 N c? + T1 lei =-c v. CIVIL ACTION NO 10 - (o'i'(o eivii ' TU°fM TAMMY ANN WHITE-CORL 415 WREN CT MECHANICSBURG PA 17050 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 O CARLISLE, PA 17013 3 1-800-990-9108 717-249-3166 061.00 PQ ATT-V CI-If Is'7I 04 a-6('0 R&'5 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. TAMMY ANN WHITE-CORL 415 WREN CT MECHANICSBURG PA 17050 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, TAMMY ANN WHITE-CORL, is an individual residing at 415 WREN CT, MECHANICSBURG PA 17050. 3. As a result of a certain medical condition, Defendant, TAMMY ANN WHITE- CORL, was admitted to Carlisle Regional Medical Center on 02/06/2006 through 02/07/2006. 4. Carlisle Regional Medical Center rendered services to Defendant, TAMMY ANN WHITE-CORL, 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 $1049.96 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, TAMMY ANN WHITE-CORL. 6. Said medical care was commensurate with the condition of Defendant, TAMMY ANN WHITE-CORL, 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 02/07/2006, Defendant, TAMMY ANN WHITE-CORL, was discharged from Carlisle Regional Medical Center. 9. No payments have been made, and Defendant, TAMMY ANN WHITE-CORL, breached the agreement with Carlisle Regional Medical Center by failing and/or refusing to pay the balance of the agreed price, $1049.96, although requested to do so by Plaintiff and their attorneys. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $1049.96, 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 l? BY. 'r1 GEORGE TWARDY, JR., ATTORNEY FOR PLAINTIFF EXHIBIT P-1 01/21/10 HEALTH MANAGEMENT ASSOCIATES DA04 COID: 858 26 DISCHARGE ACCOUNTS RECEIVABLE RECORD ACCOUNT #: 93313 PAT NAME: WHITE, TAMMY A ADMIT: 02/06/06 FINANCIAL CLASS: 9 GAR NAME: WHITE, TAMMY A DISCHARGE: 02/07/06 CONTRACT FREQ: S STREET: 415 REN CT LAST PAY: 02/22/06 MAIL RETURN: ADDR-2: PROGRAM: PAT TYPE: 05 CITY: MECHANICSBURG PA 17050 CONTRACT: .00 PAT SEX: F PHONE: (717) 796-6614 COUNTRY: US CURR BAL: .00 GAR SEX: F EMPLOYER: VOLUNTEER AMERICA TOT CHARGES: 8,230.29 AGENCY CNCL: CSA CODE DATE INSURANCE AGENCY BAL: .00 1: 200 02/22/06 3,620.19- CODE PLAN DATE STAT POLICY NO 2: 200 03/16/06 234.10 1: 200 BC3 03/16/06 8,230 P YWP80005174601 3: 951 03/21/06 3,582.63 2: 4: 951 03/21/06 3,357.09- 3: 5: 978 12/03/06 968.96- T ACTN: 99 RR 02/02/06 4: Ll 06/20/06 PROCESS REVIEW PAY AUD 2: UU 11/25/06 5: Sl 03/20/06 DATE USER DATE ARTRAC ASSGN: 04/10/06 RETN 06/21/06 REASON 985 01/31/08 PBY454 00/00/00 1 SOLD A/R TO IPI $968.96 01/31/08 PBY454 00/00/00 1 PRIM CD:CSA-UNCOLLECTABLE ; SEC CD:CSA-UNCOLLECTABL 01/25/08 PBY454 00/00/00 1 PRIM CD:CSA-UNCOLLECTABLE ; SEC CD:CSA-UNCOLLECTABL 04/17/07 MDS 00/00/00 RESIDENCE NUMBER DISC WRONG NONPUB 1=_UP,2=PT,3=GAR,4=INS,5=UB,6=HIS,7=RTN,8=CMTI,9=CMTU,10=DET,II=LOG, I3 ADJ,ENT=FW 4-© A Sess-1 10.200.98.7 XCAL1162 _ _ _#§ 2/13 Printed on 01/21/10 10:24:55 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities, that she is Gina Sposito, Supervisor of Customer Care of International Portfolio, Inc., plaintiff herein, that she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action, and any attachments thereto, are true and correct to the best of her knowledge, information and belief. Date: ZZ ZO Gi a Sposito SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy ~4~~ttiv' o~ 4~~ir~Grr! ~~~ a ~fC~[~r~rCE ~~F THE ~~~r1-1,~,,~r 7Qt0~'EB _$ ~i'~It~ 59 Edward L Schorpp SOilCIfOr 'ti` 1 'h. International Portfolio Inc. vs. Tammy Ann White-Cori Case Number 2010-676 SHERIFF'S RETURN OF SERVICE 01/28/2010 07:29 PM -Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on January 28, 2010 at 1929 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Tammy Ann White-Cori, by making known unto herself personally, at 415 Wren Court, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 February 03, 2010 SO AN RS R Y R ANDERSON, SHERIFF 13y Deputy S riff (r,) G9u;i±y8irite SheriSf. 7ele.^suft, Lic. TWARDY AND ASSOCIATES, LLC. BY: GEORGE TWARDY JR., ESQUIRE ATTORNEY I.D. 52288 1026 WINTER STREET PHILADELPHIA, PA. 19107 1-877-440-8182 INTERNATIONAL PORTFOLIO, INC. Vs. TAMMY ANN WHITE-CORL Attorney for Plaintiffs CUMBERLAND COUNTY COURT OF COMMON IEAi ?r DOCKET #: 10-676 6 - ORDER TO SATISFY, DISCONTINUE. AND END TO THE HONORABLE JUDGES OF SAID DISTRICT COURT: Kindly mark the above captioned matter SATISFIED, DISCONTINUED, and ENDED. & ASSOCIATES, LLC George Twardy Jr., Esq Attorney for Plaintiff, IPI