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HomeMy WebLinkAbout10-1156 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. ANDREA T LONGENECKER ASHLEY J LONGENECKER 10 BUTLER CT CARLISLE PA 17013-1745 Attorney for Plaintiff CUMBERLAND COUNTY ??'- COURT OF COMMON PLEAS CIVIL ACTION NO io -115(p Civi I Term -' rn c -c 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 Q CARLISLE, PA 17013 1-800-990-9108 igol. oo Pa 717-249-3166 Ck,* 010 a (P ed3'7'74L AT-rY 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. . ANDREA T LONGENECKER ASHLEY J LONGENECKER 10 BUTLER CT CARLISLE PA 17013-1745 CUMBERLAND COUNTY COURT OF COMMON PLEAS A) 0, ' Q / 15-6 / 'V") f ez-,"l COMPLAINT 1. Plaintiff, International Portfolio, Inc., is the Assignee of the debt from Carlisle Regional Medical Center, with offices in CUMBERLAND County, 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, ANDREA T LONGENECKER, is an individual residing at 10 BUTLER CT, CARLISLE PA 17013-1745 and is the parent of ASHLEY J LONGENECKER, who was a patient at Carlisle Regional Medical Center. 3. As a result of a certain medical condition, the minor child of Defendant, ASHLEY J LONGENECKER, was admitted to Carlisle Regional Medical Center on 02/25/2006 through 02/25/2006. 4. Carlisle Regional Medical Center rendered services to Defendant, ASHLEY J LONGENECKER, 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 $1066.80 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, ANDREA T LONGENECKER on behalf of his/her minor child, ASHLEY J LONGENECKER. 6. Said medical care was commensurate with the condition of Defendant, ANDREA T LONGENECKER, 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 02/25/2006, ASHLEY J LONGENECKER, was discharged from Carlisle Regional Medical Center to the care of Defendant.] 9. ASHLEY J LONGENECKER, is the minor child of Defendant and is living with Defendant, therefore, Defendant is liable for his/her necessaries under the support law of Pennsylvania. 10. No payments have been made, and Defendant, ANDREA T LONGENECKER, breached the agreement with Carlisle Regional Medical Center by failing and/or refusing to pay the balance of the agreed price, $1066.80, although requested to do so by Plaintiff and their attorneys. h WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $1066.80, 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 /, GEORGE TWARDY,_ ".QUIRE ATTORNEY FOR PL NTIFF EXHIBIT P-1 02/15/10 HEALTH MANAGEMENT ASSOCIATES DA04 COID: 858 ACCOUNT #: 9332858 DISCHARGE ACCOUNTS RECEIVABLE RECORD PAT NAME: LONGENECKER, ASHLEY J ADMIT: 02/25/06 FINANCIAL CLASS: 9 I GAR NAME: LONGENECKER, .ANDREA T DISCHARGE: 02/25/06 CONTRACT FREQ: S STREET: 230 W SOUTH ST LAST PAY: 03/22/06 MAIL RETURN: ADDR-2: PROGRAM: PAT TYPE: E1 CITY: CARLISLE PA 17013 CONTRACT: .00 PAT SEX: F PHONE: (717) 701-3040 COUNTRY: US CURR BAL: .00 GAR SEX: F EMPLOYER: STUDENT ST PATRICKS SCH TOT CHARGES: 1,496.56 AGENCY CNCL: CSA CODE DATE INSURANCE AGENCY BAL: .00 1: 242 03/22/06 429.76- CODE PLAN DATE STAT POLICY NO 2: 978 11/19/06 1,066.80- 1: 242 03/22/06 P 214847786 3. 2. 4. 3: 5: LST ACTN: 99 11/08/07 3: NN 07/10/06 PAY AUD 1: KK 11/18/06 4: L1 06/22/06 PROCESS REVIEW PAY AUD 2: UU 11/11/06 5: S3 04/17/06 DATE USER DATE ARTRAC ASSGN: 04/26/06 RETN 06/22/06 REASON 985 11/08/07 PBY454 00/00/00 SOLD A/R TO IPI $1,066.80 11/08/07 PBY454 00/00/00 PRIM CD:CSA-UNCOLLECTABLE ; SEC CD:CSA-UNCOLLECTABL 03/23/07 ASET 00/00/00 10:41 res 717-701-3040 LEFT AUTO MSG 03/23/07 ASET 00/00/00 10:41 ON MACH 60712 38497 1=UP,2=PT,3=GAR,4=INS,5=tJB,6=HIS,7=RTN,8=CMTI,9=CMTU,10=DET,II=LOG,I3=ADJ,ENT=FW_ 4-© B Sess-2 10.200.98.7 _ XCAL407_8 #§ 2/13 Printed on 02/15/10 11:1"7:02 - - -- 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: , , ?S l U Gina Sposito SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor ~4k~f1~}~ iYt pip llcr~7jlo _};. ,,.; ,r. QF=it,E ~F Ytr 4 ~G,',F= t ~, . ..,,~ ~;~~t,-~ -, ~~__ 2~l0 ~~~ 2~+ t ~ 2~ z~+ r~ a;~~`rr P .~`l International Portfolio Inc. Case Number vs. Andrea T. Longenecker (et al.) 2010-1156 SHERIFF'S RETURN OF SERVICE 02/22/2010 04:00 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on February 22, 2010 at 1600 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Andrea T. Longenecker, by making known unto herself personally, at 10 Butler Court, 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. ROB RT BITNER, DEP TY 02/23/2010 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: Ashley J. Longenecker, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Ashley J. Longenecker. Ashley J. Longenecker is a Penn State student and does not reside at 10 Butler Court, Carlisle, PA 17013. SHERIFF COST: $54.40 February 23, 2010 SO ANS S, ` RON V ANDERSON, SHERIFF Vic) Ceu^iySuite Sheriff. 1~e+ecsti,ft. Inc C�j David-D. Buell- Me 12enee Simpson lnrothonota •� , y 1' Deputy Prothonotary u `0 7iie (fir.`' �irkS. Sohonage, ESQ ,%' Irene E. Morrow Solicitor 1754 Zwf Deputy Prothonotary Office of the Prothonotary Cumberland County, <Pennsy[vania �v —`/S'lp CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH 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 • Fax(717)240-6573