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HomeMy WebLinkAbout10-2547LAW 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. JAMIE C KING And CINDY KING Parent 10 SUNSET LANE MILFORD DE 19963 n e•? O n Attorney for PliO # ?n c.r+ CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL ACTION NO (D -a5µ1 COMPLAINT - CIVIL ACTION (a?? lTexrr? 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 IlOORTANT 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 CA ARLISLE, PA 17013 ' C 1-800-990-9108 44x.00 PO AMY 717-249-3166 co aly8 0,2q a'7q y 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 CUMBERLAND COUNTY WEST CONSHOHOCKEN, PA 19428 COURT OF COMMON PLEAS VS. JAMIE C KING And CINDY KING Parent 10 SUNSET LANE MILFORD DE 19963 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. Defendants, JAMIE C KING and CINDY KING, are individuals residing at 10 SUNSET LANE, MILFORD DE 19963. CINDY KING is the parent of JAMIE C KING, who was a patient at Carlisle Regional Medical Center. 3. As a result of a certain medical condition, the child of Defendant, JAMIE C KING, was admitted to Carlisle Regional Medical Center on 04/26/2006 through 04/26/2006. 4. Carlisle Regional Medical Center rendered services to Defendant, JAMIE C KING, 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 $1250.25 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 Defendants, JAMIE C KING and CINDY KING. 6. Said medical care was commensurate with the condition of Defendant, JAMIE C KING, 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 04/26/2006, JAMIE C KING was discharged from Carlisle Regional Medical Center to the care of Defendant CINDY KING. 9. JAMIE C KING, is the child of Defendant CINDY KING and is living with Defendants, therefore, the Defendants are liable for his/her necessaries under the support law of Pennsylvania. 10. No payments have been made, and Defendants, JAMIE C KING AND CINDY KING, breached the agreement with Carlisle Regional Medical Center by failing and/or refusing to pay the balance of the agreed price, $1250.25, although requested to do so by Plaintiff and their attorneys. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $1250.25, 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 04/09/10 HEALTH MANAGEMENT ASSOCIATES DA04 COID: 858 ACCOUNT #: 9337794 DISCHARGE ACCOUNTS RECEIVABLE RECORD PAT NAME: KING, JAMIE C ADMIT: 04/26/06 FINANCIAL CLASS: 9 P GAR NAME: KING, JAMIE C DISCHARGE: 04/26/06 CONTRACT FREQ: S STREET: 10 SUNSET LANE LAST PAY: 04/26/06 MAIL RETURN: ADDR-2: PROGRAM: PAT TYPE: El CITY: MILFORD DE 19963 CONTRACT: .00 PAT SEX: M PHONE: (302) 236-7138 COUNTRY: US CURR BAL: .00 GAR SEX: M EMPLOYER: DICKINSON STUDENT TOT CHARGES: 1,169.25 AGENCY CNCL: CSA CODE DATE INSURANCE AGENCY BAL: .00 1: 978 03/16/07 1,169.25- CODE PLAN DATE STAT POLICY NO 2: 1: 950 001 07/06/06 1,169 N 80012601705 3: 2: 4. 3: 5: LST ACTN: 99 11/08/07 3: NN 10/09/06 PAY AUD 1: KK 03/15/07 4: L1 09/19/06 PROCESS REVIEW PAY AUD 2: UU 03/08/07 5: 14 07/10/06 DATE USER DATE EARLYOUT ASSGN: 07/06/06 RETN 09/19/06 REASON 985 04/23/08 CC 00/00/00 MOM CALLED AND WANTED TO KNOW HOW TO HAVE THIS RESOLVE 04/23/08 CC 00/00/00 TOLD HER TO CALL IPI 04/22/08 CC 00/00/00 PT CALLED ABOUT THIS ACCT TOLD HIM WE SOLD IT HE WANTE 04/22/08 CC 00/00/00 TO KNOW ALL KINDS OF QUESTIONS ON THIS 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 XCAL3065 #§ 2/13 Printed on 04/09/10 10:52:41 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: q 1? / 0 TWARDY AND ASSOCIATES, LLC. BY: GEORGE TWARDY JR., ESQUIRE Attorney for Plaintiff ATTORNEY I.D. 52288 1026 WINTER STREET PHILADELPHIA, PA. 19107 1-877-440-8182 INTERNATIONAL PORTFOLIO, INC. COURT OF COMMON PLEAS Vs. CUMBERLANDCOUNTY JANIIE C KING AND CINDY KING PARENT DOCKET #: 10-2547 cn ORDER TO SETTLE DISCONTINUE AND END ' 1: j~`~-a .~ { ~.~, ~_~ W ,, . TO THE HONORABLE JUDGES OF SAID COURT: ~ ' .: ~ ~:; -- Kindly mark the above captioned matter SETTLED, DISCONTINUED, and __~, -, DY & ASSOCIATES, LLC ~~ l ~ ~y: George Twardy Jr., Esquire Attorney for Plaintiff, IPI