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HomeMy WebLinkAbout10-1493REPO ;E, OF THE 06H4NaTA"f 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 Attorney for Pattti§AR -3 11 111 CUM3'4r.'?.' U ,-)UWY ?.1 ahv5ti'L'?1?i X41 CUMBERLAND COUNTY COURT OF COMMON PLEAS V. CIVIL ACTION NO 1D - l193 0I . 011 C RENEE Y SHINDEL parent of SHINDEL, JAYDEN L 99 BEETEM HOLLOW ROAD NEWVILLE PA 17241 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 CD 32 SOUTH BEDFORD STREET / J CARLISLE, PA 17013 1-800-990-9108 / 717-249-3166 .,0517 2832-2 , 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. RENEE Y SHINDEL parent of SHINDEL, JAYDEN L 99 BEETEM HOLLOW ROAD NEWVILLE PA 17241 CUMBERLAND COUNTY COURT OF COMMON PLEAS 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, RENEE Y SHINDEL, is an individual residing at 99 BEETEM HOLLOW ROAD, NEWVILLE PA 17241 and is the parent of SHINDEL, JAYDEN L, who was a patient at Carlisle Regional Medical Center. 3. As a result of a certain medical condition, the minor child of Defendant, SHINDEL, JAYDEN L, was admitted to Carlisle Regional Medical Center on 03/24/2006 through 03/24/2006. 4. Carlisle Regional Medical Center rendered services to Defendant, SHINDEL, JAYDEN L, 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 $1081.00 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, RENEE Y SHINDEL on behalf of his/her minor child, SHINDEL, JAYDEN L. 6. Said medical care was commensurate with the condition of Defendant, RENEE Y SHINDEL, 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 03/24/2006, SHINDEL, JAYDEN L, was discharged from Carlisle Regional Medical Center to the care of Defendant.] 9. SHINDEL, JAYDEN L, 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, RENEE Y SHINDEL, breached the agreement with Carlisle Regional Medical Center by failing and/or refusing to pay the balance of the agreed price, $1081.00, although requested to do so by Plaintiff and their attorneys. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $1081.00, 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 B. 1 GORGE TWA DY, JR., ESQUIRE ATTORNEY FOR PLAINTIFF EXHIBIT P-1 02/23/10 HEALTH MANAGEMENT ASSOCIATES DA04 COID: 858 ACCOUNT #: 7582678 DISCHARGE ACCOUNTS RECEIVABLE RECORD PAT NAME: SHINDEL, JAYDEN L ADMIT: 03/24/06 FINANCIAL CLASS: 9 GAR NAME: SHINDEL, RENEE Y DISCHARGE: 03/24/06 CONTRACT FREQ: S STREET: PO BOX 80 LAST PAY: 04/13/06 MAIL RETURN: ADDR-2: PROGRAM: PAT TYPE: OS CITY: PLAINFIELD PA 17081 CONTRACT: .00 PAT SEX: M PHONE: (717) 240-0169 COUNTRY: US CURR BAL: .00 GAR SEX: F EMPLOYER: HOMEMAKER TOT CHARGES: 8,911.09 AGENCY CNCL: CSA CODE DATE INSURANCE AGENCY BAL: .00 1: 967 04/13/06 6,771.09- CODE PLAN DATE STAT POLICY NO 2: 432 04/13/06 1,140.00- 1: 432 04/13/06 8,911 P 85133881103 3: 978 10/22/06 1,000.00- 2: 4. 3: 5: LST ACTN: 99 01/31/08 3: ZZ 06/12/06 PAY AUD 1: RR 10/21/06 4: L1 05/25/06 PROCESS REVIEW PAY AUD 2: UU 10/14/06 5: L1 05/22/06 DATE USER DATE ARTRAC ASSGN: 05/23/06 RETN 05/25/06 REASON 997 01/31/08 PBY454 00/00/00 1 SOLD A/R TO IPI $1,000.00 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 01/08/08 MDS 00/00/00 GUARANTOR NOT AVAILABLE 1=UP,2=PT,3=GAR,4=INS,5=UB,6=HIS,7=RTN,8=CMTI,9=CMTU,10=DET,11=LOG,I3=ADJ,ENT=FW 4-© A Sess-1 10.200.98.7 XCAL6143 #§ 2/13 Printed on 02/23/10 14:35:56 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: Gina Sposito SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~~~~~~~ nt ~autb~~~~~~~ f ~ v Jody S Smith ~ ~' Chief Deputy - ~~~~ ~A~ 3~ ~~ ~: (~Q Edward L Schorpp !~' Solicitor ~,~F "~j'~~ {'ttr'~'; Cep International Portfolio Inc. Case Number vs. 2010-1493 Renee Y. Shindel SHERIFF'S RETURN OF SERVICE 03/22/2010 08:33 PM -Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on March 22, 2010 at 2030 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Renee Y. Shindel, by making known unto herself personally, at 99 Beetem Hollow Road Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to her personally the said true and correct copy of the same. ARK CONKLIN, DEPUTY SHERIFF COST: $38.80 March 23, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF c} C~i.i qS~ to Stc f T€ o-: sc`i. Vin,;. 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. RENEE Y SHINDEL 99 BEETEM HOLLOW ROAD NEWVII.,LE PA 17241 NO. 10-1493 c ~ T, ~~: . ~ `. , • _ ~ -; ~ ..~ .___ '~ C (° ;I PRAECIPE FOR JUDGMENT Enter Judgment in favor of Plaintiff, International Portfolio Inc., and against Defendant, RENEE Y SHINDEL for want of an answer in the amount of: Debt: $1000.00 Interest/costs: $211.80 + ongoing Total: $1211.80 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 fili of this Praecipe for not filing an answer to the co plaint. DATE: Z~ Zd J ~ 1 eorge Twardy, Jr. Esquire Attorney for International Portfolio, Inc. NOW By:_ Deputy Blot D JUDGMENT IS ENTERED ABOVE. ~14.oc~ P4 a-rt•y e* aazs ~2* oil l0 3a,~3 MJ~e~. ~la,.R.~ 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. 10-1493 vs. RENEE Y SHINDEL 99 BEETEM HOLLOW ROAD NEWVILLE PA 17241 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 th above captioned matter has been forwarded via U.S. First Class Mail, on _ ~ ~ Tl~/C>, to the following: RENEE Y SHINDEL 99 BEETEM HOLLOW ROAD NEWVILLE PA 17241 TWAR,~Y & ASSOCIATES, LLC George Twardy, Jr., 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 . SUTTE 400 , WEST CONSHOHOCKEN, PA 19428 NO. 10-1493 vs. RENEE Y SHINDEL 99 BEETEM HOLLOW ROAD NEWVILLE PA 17241 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 _ ~ ~ p , to the following: RENEE Y SHINDEL 99 BEETEM HOLLOW ROAD NEWVILLE PA 17241 TW Y & ASSOCIATES, LLC. By: George Twardy, Jr., Esquire Attorney for Plaintiff TWARDY & 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 Plaintiff INTERNATIONAL PORTFOLIO, INC 200 BAR HARBOUR DRIVE SUITE 400 WEST CONSHOHOCKEN, PA 19428 COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. RENEE Y SHINDEL 99 BEETEM HOLLOW ROAD NEWVILLE PA 17241 NO. 10-1493 VERIFICATION OF NON-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, RENEE Y SHINDEL Or occupants, is over 18 years of age, and resides at 99 BEETEM HOLLOW ROAD , NEWVILLE PA 17241 This statement is made subject to the penalties of 10 PA CSS 4904 relating to unsworn falsification to authorities. l George Twardy, Jr. Esq. Attorney for Plaintiffs 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. 10-1493 vs. RENEE Y SHINDEL 99 BEETEM HOLLOW ROAD NEWVILLE PA 17241 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 , to the following: RENEE Y SHINDEL 99 BEETEM HOLLOW ROAD NEWVILLE PA 17241 TWARI~ & ASSOCIATES, LLC By: George Twardy, Jr., Esquire Attorney for Plaintiff TWARDY 81~ ASSOCIATES, LLc Respo io: ATTORNEYS AT LAW Philadelphia Toll Free: 877-440-8182 ^ Havertown ^ Voorhees www.twardyandassociates.com Apri123, 2010 RENEE Y SHINDEL 99 BEETEM HOLLOW ROAD NEWVILLE PA 17241 RE: INTERNATIONAL PORTFOLIO, INC. v. RENEE Y SHINDEL Docket: 10-1493 COURT OF COMMON PLEAS CUMBERLAND COUNTY Dear RENEE Y SHINDEL, 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~, ----~ ~r ~ ~.-~''--~ .._ George Twardy, Jr, Esq. Attorney for Plaintiff, International Portfolio, Inc. GT/pr Encl. PHI[ADELPHU OFFICES 1028 WINTER STREET NEW JEILSEY OFFICES SUITE 400 22 ALPHA AVENUE PHfLADELPHIA, PA 1 91 07-1 808 VOORHEES, NJ 08043 EMAIL: glwardyesgt~twardyandassociates.COm DEIAWARE COUNTY OFFICES 806 DARBY ROAD HAVERTOWN, PA 19083 Twardy and Associates, LLC By: Ceorge Twardy, Jr., Esquire Identification No. 52883 1026 Winter Street Suite 400 Philadelphia, PA 1910'7 1-877-040-8182 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY INTERNATIONAL PORTFOLIO, INC. * 200 BAR HARBOUR DRIVE SUITE 900 * WEST CONSHOHOCICEN, PA 19428 * NO.10-1493 vs. RENEE Y SHIIYDEL 99 BEETEM HOLLOW ROAD NEWViLLE PA 17241 NOTICE OF PRAE~IPE TO ENTER JUDGMENT BY DEFAULT TO: RENEE Y SHINDEL Defend t DATE OF NOTICE: Z-~ G~G3~ 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 OBJECTTONS 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 17013 'telephone): 717-249-3166 1 ~'~`~ 'George Twardy, Jr., Esquire Attorney for Plaintiff, international Portfolio Inc. 1026 Winter St Philadelphia, PA 19107-1808 Phone: 877-440-8182 ID. No. 52883