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HomeMy WebLinkAbout10-1643LAW 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 V. CIVIL ACTION NO 10 - I(o?3 l..ivilT?rn RONALD P BARNESS n 509 B STREET _n CARLISLE PA 17013-1539 COMPLAINT - CIVIL ACTION ? c is ti ? a 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 1-800-990-9108 ft oo pp AT Y 717-249-3166 e'101-:2109 a 38 (o oL8 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. RONALD P BARNESS 509 B STREET CARLISLE PA 17013-1539 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, RONALD P BARNESS, is an individual residing at 509 B STREET, CARLISLE PA 17013-1539. 3. As a result of a certain medical condition, Defendant, RONALD P BARNESS, was admitted to Carlisle Regional Medical Center on 03/22/2006 through 03/22/2006. 4. Carlisle Regional Medical Center rendered services to Defendant, RONALD P BARNESS, 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 $948.87 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, RONALD P BARNESS. 6. Said medical care was commensurate with the condition of Defendant, RONALD P BARNESS, 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 03/22/2006, Defendant, RONALD P BARNESS, was discharged from Carlisle Regional Medical Center. 9. No payments have been made, and Defendant, RONALD P BARNESS, breached the agreement with Carlisle Regional Medical Center by failing and/or refusing to pay the balance of the agreed price, $948.87, although requested to do so by Plaintiff and their attorneys. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $948.87, 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 J GEORGE TWARDY, JR., ESQUIRE ATTORNEY FOR PLAINTIFF EXHIBIT P-1 03/04/10 HEALTH MANAGEMENT ASSOCIATES DA04 COID: 858 ACCOUNT #: 9334962 DISCHARGE ACCOUNTS RECEIVABLE RECORD PAT NAME: BARNESS, RONALD P ADMIT: 03/22/06 FINANCIAL CLASS: 9 P GAR NAME: BARNESS, RONALD P DISCHARGE: 03/22/06 CONTRACT FREQ: S STREET: 42 S BALTIMORE ST LAST PAY: 03/22/06 MAIL RETURN: ADDR-2: PROGRAM: PAT TYPE: E1 CITY: DILLSBURG PA 17019 CONTRACT: .00 PAT SEX: M PHONE: (717) 571-9019 COUNTRY: US CURR BAL: .00 GAR SEX: M EMPLOYER: KEENER MASONARY TOT CHARGES: 948.87 AGENCY CNCL: CSA CODE DATE INSURANCE AGENCY BAL: .00 1: 978 11/24/06 948.87- CODE PLAN DATE STAT POLICY NO 2: 1: 3. 2. 4. 3: 5: LST ACTN: 99 11/08/07 3: TT 06/30/06 PAY AUD 1: QQ 11/23/06 4: L1 06/13/06 PROCESS REVIEW PAY AUD 2: UU 11/16/06 5: S3 04/17/06 DATE USER DATE ARTRAC ASSGN: 04/19/06 RETN 06/13/06 REASON 985 11/08/07 PBY454 00/00/00 1 SOLD A/R TO IPI $948.87 11/08/07 PBY454 00/00/00 1 PRIM CD:CUN-UNCOLLECTABLE ; SEC CD:CSA-UNCOLLECTABL 11/06/06 ASET 00/00/00 19:17 is #57 10/23/06 ASET 00/00/00 19:17 is #57 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 XCAL2067 #§ 2/13 Printed on 03/04/10 15:07:16 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: / /O Gina Sposito SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor i'0,1111tr ct Eiinb?r?414 T?:.C y..F RAF= 2010 Ni :i\ 3 v ! 2-" • 2',. "I,1Lt f. International Portfolio Inc. vs. Case Number Ronald P. Barness 2010-1643 SHERIFF'S RETURN OF SERVICE 03/11/2010 04:17 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on March 11, 2010 at 1617 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Ronald P. Barness, by making known unto himself personally, at 840 Baltimore Pike, Gardners, Cumberland County, Pennsylvania 17324 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $43.30 March 12, 2010 GERALD WORT EPUTY SO ANSWERS, RON R ANDERSON, SHERIFF icj County Smte Shellff TelcosOtl. fit;;. 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. RONALD P BARNESS 509 B STREET CARLISLE PA 17013-1539 cz r= ~., - ; NO. 10-1643 -- ~-~~ ---~ r~ .; i~t - r-- ~ -- • ~;_; -T, fir: •-~ PRAECIPE FOR JUDGMENT Enter Judgment in favor of Plaintiff, International Portfolio Inc., and against Defendant, RONALD P BARNESS for want of an answer in the amount o£ Debt: $948.87 Interest/costs: $135.30 + ongoing Total: $1084.17 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 filiof this Praecipe for not filing an answer to the complaint. ~------' ~~ ~/5/~U ~ ~ DATE: George Twardy, Jr. Esquire Attorney for International Portfolio, Inc. NOW, oZ010 JUDGMENT IS ENTERED ABOVE. onotary/clerk, ivil Division By:_ Deputy ~~~•oo Po A`rtY C~.~ a.1 s3 e,~ ~~roay 7 ~o~c-~.~. I~.~~.~ Office of Prothonotary of Court of Common Pleas ofGuH,~er/S,.~County NOTICE OF ENTRY OF JUDGMENT, ORDER OR DECREE International Portfolio, Inc, Plaintiff Case Number CI-10-1643 VS RONALD P BARNESS, Defendants 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 - ® Judgment of 1084.17 for Plaintiff and against Defendants. Judgment for Defendant and against Plaintiffs. ^Order or Decree in favor of ~J Date: PROTHONO ARY y~9~io Mailed: To:RONALD P BARNESS Address: 509 B STREET City: CARLISLE ,State: PAZip Code: 17013-1539 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. 10-1643 vs. RONALD P BARNESS 509 B STREET CARLISLE PA 17013-1539 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 and Certified Mail, on ~~~5,~~ , to the following: RONALD P BARNESS 509 B STREET CARLISLE PA 17013-1539 LAW OFFICES OF GEORGE TWARDY, JR. 1 y: George Twardy, Jr., Esquire 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. 10-1643 vs. RONALD P BARNESS 509 B STREET CARLISLE PA 17013-1539 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 and Certified Mail, on ~/S~l~ , to the following: RONALD P BARNESS 509 B STREET CARLISLE PA 17013-1539 LAW~QFFICES OF GEORGE TWARDY, JR. George Twardy, Jr., Attorney for Plaintiff LAW OFFICES OF GEORGE TWARDY, JR. 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. RONALD P BARNESS 509 B STREET CARLISLE PA 17013-1539 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-1643 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, RONALD P BARNESS Or occupants, is over 18 years of age, and resides at 509 B STREET ,CARLISLE PA 17013-1539 This statement is made subject to the penalties of 10 PA CSS 4904 relating to unsworn falsification to authorities. ge Twardy, Jr. Esq. Attorney for Plaintiffs Twardy and Associates, LLC By: Ceorge Twardy, Jr., Esquire Identification No. 52883 1026 Winter Street Suite 400 Philadelphia, PA 19107 1-87740-8182 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY INTERNATIONAL PORTFOLIO, INC. 200 BAR HARBOUR DRIVE SUITE 400 WEST CONSBOHOCKEN, PA 19428 vs. * NO. 10-1643 RONALD P BARNESS 509 B STRE ET CARLISLE PA 17013-1539 NOTICE QF PRAECIPE TO ENTER JUDGMENT BY .DEFAULT TO: RONALD P BARNE55 Defendant DATE OF NOTICE: ~ Z•~ ~'~~-~ 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 (l0) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAX 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 Telepho X717-249-3166 ~--- ~ ~ c~ ~~7 ~ -~ Geot'ge Twardy, Jr., Esquire - Attorneyfor Plaintiff; International Portfolio Inc. 102b Winter St Philadelphia, PA 19107-1808 Phone: 877-440-8182 ID. No. 52883 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. 10-1643 vs. RONALD P BARNESS 509 B STREET CARLISLE PA 17013-1539 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 and Certified Mail, on March 23, 2010, to the following: RONALD P BARNESS 509 B STREET CARLISLE PA 17013-1539 LAW FFICES OF GEORGE TWARDY, JR. t y: George Twardy, Jr., Es ire Attorney for Plaintiff