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HomeMy WebLinkAbout10-2691 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 KRISTOPHER M STRICKLAND 1550 HOLLY PIKE v. CARLISLE PA 17015 Attorney for P161f , "7' CUMBERLAND COUNTY COURT OF COMMON PLEAS 0 N N -1s N ca r m ?C) CIVIL ACTION NO 10 -XAI civil-ferra 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 CLAIIvIED 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 CARLISLE, PA 17013 O 1-800-990-9108 $Qa, p 0 P Al 717-249-3166 ?,? o2lSo1 12* .14/010 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. KRISTOPHER M STRICKLAND 1550 HOLLY PIKE -- -- - - CARLISLE PA 17015 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, KRISTOPHER M STRICKLAND, is an individual residing at 1550 HOLLY PIKE, CARLISLE PA 17015. 3. As a result of a certain medical condition, Defendant, KRISTOPHER M STRICKLAND, was admitted to Carlisle Regional Medical Center on 05/29/2006 through 05/29/2006 and again on 06/02/2006 through 06/02/2008. 4. Carlisle Regional Medical Center rendered services to Defendant, KRISTOPHER M STRICKLAND, 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 $2496.44 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, KRISTOPHER M STRICKLAND. 6. Said medical care was commensurate with the condition of Defendant, KRISTOPHER M STRICKLAND, 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 06/02/2006, Defendant, KRISTOPHER M STRICKLAND, was discharged from Carlisle Regional Medical Center. 9. No payments have been made, and Defendant, KRISTOPHER M STRICKLAND, breached the agreement with Carlisle Regional Medical Center by failing and/or refusing to pay the balance of the agreed price, $2496.44, although requested to do so by Plaintiff and their attorneys. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $2496.44, 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 J __ GEORGE TWARDY, JR., ESQUIRE ATTORNEY FOR PLAINTIFF EXHIBIT P-1 03/18/10 ACCOUNT PAT NAME: GAR NAME: STREET: ADDR-2: CITY: PHONE: EMPLOYER: CODE l: 950 07 2: 978 02 3: 4: 5: HEALTH MANAGEMENT ASSOCIATES DA04 COID: 858 9340843 DISCHARGE ACCOUNTS RECEIVABLE RECORD STRICKLAND, KRISTOPHER ADMIT: 06/02/06 FINANCIAL CLASS: 9 STRICKLAND, KRISTOPHER M DISCHARGE: 06/02/06 CONTRACT FREQ: S 901 SADLER COURT LAST PAY: 07/12/06 MAIL RETURN: PROGRAM: PAT TYPE: E1 CARLISLE PA 17013 CONTRACT: .00 PAT SEX: M (717) 258-6356 COUNTRY: US CURR BAL: .00 GAR SEX: M INGERSOLL RAND X5782 TOT CHARGES: 1,361.06 AGENCY CNCL: CSA DATE INSURANCE AGENCY BAL: .00 /12/06 175.00- CODE PLAN DATE STAT POLICY NO /28/07 1,186.06- 1: 950 001 07/12/06 1,361 P 17944801104 PROCESS DATE USER 01/31/08 PBY454 01/31/08 PBY454 01/25/08 PBY454 06/05/07 MDS 2: 3: LST ACTN: 99 01/31/08 3: ZZ 10/16/06 PAY AUD 1: RR 02/27/07 4: L1 09/26/06 REVIEW PAY AUD 2: UU 02/20/07 5: S1 07/17/06 DATE ARTRAC ASSGN: 08/01/06 RETN 09/27/06 REASON 985 00/00/00 1 SOLD A/R TO IPI $1,186.06 00/00/00 1 PRIM CD:CSA-UNCOLLECTABLE ; SEC CD:CSA-UNCOLLECTABL 00/00/00 1 PRIM CD:CSA-UNCOLLECTABLE ; SEC CD:CSA-UNCOLLECTABL 00/00/OC LEFT MESSAGE AT RESIDENCE 1=UP,2=PT,3=GAR,4=INS,5=UB,6=HIS,7=RTN,8=CMTI,9=CMTU,IO=DET,II=LOG,I3=ADJ,ENT=FW 4-© A Sess-1 10.200.98.7 XCAL2027 #§ 2/13 Printed on 03/18/10 17:05:20 03/18/10 ACCOUNT #: PAT NAME: GAR NAME: STREET: ADDR-2: CITY: PHONE: EMPLOYER: CODE 1: 950 07 2: 978 02 3: 4: 5: HEALTH MANAGEMENT ASSOCIATES DA04 COID: 858 9340463 DISCHARGE ACCOUNTS RECEIVABLE RECORD STRICKLAND, KRISTOPHER M ADMIT: 05/29/06 FINANCIAL CLASS: 9 STRICKLAND, KRISTOPHER M DISCHARGE: 05/29/06 CONTRACT FREQ: S 901 SADLER COURT LAST PAY: 07/12/06 MAIL RETURN: PROGRAM: PAT TYPE: E1 CARLISLE PA 17013 CONTRACT: .00 PAT SEX: M (717) 258-6356 COUNTRY: US CURR BAL: .00 GAR SEX: M INGERSOLL RANI) X5782 TOT CHARGES: 1,485.38 AGENCY CNCL: CSA DATE INSURANCE AGENCY BAL: .00 /12/06 175.00- CODE PLAN DATE STAT POLICY NO /28/07 1,310.38- 1: 950 001 07/12/06 1,485 P 17944801104 PROCESS DATE USER 01/31/08 PBY454 01/31/08 PBY454 01/25/08 PBY454 06/05/07 MDS 2: 3: LST ACTN: 99 01/31/08 3: ZZ 10/09/06 PAY AUD 1: RR 02/27/07 4: L1 09/21/06 REVIEW PAY AUD 2: UU 02/20/07 5: Si 07/17/06 DATE ARTRAC ASSGN: 07/28/06 RETN 09/22/06 REASON 985 00/00/OC SOLD A/R TO IPI $1,310.38 00/00/00 PRIM CD:CSA-UNCOLLECTABLE ; SEC CD:CSA-UNCOLLECTABL 00/00/00 PRIM CD:CSA-UNCOLLECTABLE ; SEC CD:CSA-UNCOLLECTABL 00/00/00 LEFT MESSAGE AT RESIDENCE 1=UP,2=PT,3=GAR,4=INS,5=UB,6=HIS,7=RTN,8=CMTI,9=CMTU,IO=DET,II=LOG,I3=ADJ,ENT=FW 4-© A Sess-1 10.200.98.7 XCAL2027 -#§2/13 Printed on 03/18/10 17:05:39 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 TWARDY AND ASSOCIATES, LLC. BY: GEORGE TWARDY JR., ESQUIRE ATTORNEY I.D. 52288 1026 WINTER STREET PHILADELPHIA, PA. 19107 1-877-440-8182 Attorney for Plaintiff INTERNATIONAL PORTFOLIO, INC. Vs. KRISTOPIiER M STRICKLAND CUMBERLAND COUNTY COURT OF COMMON PLEAS ' DOCKET #: 10-2691 C'3 ~"~' i^- -- ~-` .„ ~ -J ORDER TO SETTLE. DISCONTINUE. AND END .. =~ :'~~' ~~~ _, ~ - TO THE HONORABLE JUDGES OF SAID COURT: ~~ ` `_~~'' `~' -, ~, c- a : ;} ~::, ~ :. Kindly mark the above captioned matter SETTLED, DISCONTINUED, and ENDED. TWARDY & ASSOCIATES, LLC By: George rdy Jr., Esquire Attorney for aintiff, IPI