Loading...
HomeMy WebLinkAbout10-2852LAW 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 1 AttornVAr 41406,- SUITE 400 CUMBERLAND COUNTY WEST CONSHOHOCKEN, PA 19428 COURT OF COMMON PLEAS V. CIVIL ACTION NO RONALD L MARTIN And l0 ` d85 CI V i l TZ°Xp't GRETTA R MARTIN a 199 QUIGLEY ROAD NEWBURG PA 17240 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 O 32 SOUTH BEDFORD STREET 5 CARLISLE, PA 17013 $ga.00 PD AiT1J 1-800-990-9108 C? a 181 717-249-3166 ?,'? d 4 !3x20 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 L MARTIN And GRETTA R MARTIN 199 QUIGLEY ROAD NEWBURG PA 17240 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL ACTION NO 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. Defendants, RONALD L MARTIN and GRETTA R MARTIN, are husband and wife and are adult individuals residing at 199 QUIGLEY ROAD, NEWBURG PA 17240. 3. As a result of a certain medical condition, Defendant, RONALD L MARTIN, was admitted to Carlisle Regional Medical Center on 08/13/2006 through 08/13/2006. 4. Carlisle Regional Medical Center rendered services to Defendant, RONALD L MARTIN, 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 $1148.07 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, RONALD L MARTIN and GRETTA R MARTIN. 6. Said medical care was commensurate with the condition of Defendant, RONALD L MARTIN, 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 Defendants 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 08/13/2006, Defendant, RONALD L MARTIN, was discharged from Carlisle Regional Medical Center. 9. At or about the time that treatment was rendered, Defendant, GRETTA R MARTIN was the spouse of Defendant, RONALD L MARTIN, and is therefore liable for the cost of necessaries furnished to Defendant, RONALD L MARTIN. 10. No payments have been made, and Defendants, RONALD L MARTIN and GRETTA R MARTIN, breached the agreement with Carlisle Regional Medical Center by failing and/or refusing to pay the balance of the agreed price, $1148.07, although requested to do so by Plaintiff and their attorneys. WHEREFORE, Plaintiff demands judgment against Defendants in the amount of $1148.07, plus six percent (6%) interest per annum, from the date of discharge to the date of judgment, and record and non-record costs. AND ASSOCIATES wtuhccit I WARDY, JR., ESQUIRE ATTORNEY FOR PLAINTIFF EXHIBIT P-1 04/27/10 HEALTH MANAGEMENT ASSOCIATES DA04 COID: 858 ACCOUNT #: 9346686 DISCHARGE ACCOUNTS RECEIVABLE RECORD PAT NAME: MARTIN, RONALD L ADMIT: 08/13/06 FINANCIAL CLASS: 9 P GAR NAME: MARTIN, RONALD L DISCHARGE: 08/13/06 CONTRACT FREQ: S STREET: PO BOX 253 LAST PAY: 08/13/06 MAIL RETURN: ADDR-2: PROGRAM: PAT TYPE: E1 CITY: NEWBURG PA 17240 CONTRACT: .00 PAT SEX: M PHONE: (717) 423-6981 COUNTRY: US CURR BAL: .00 GAR SEX: M EMPLOYER: NOT EMPLOYED TOT CHARGES: 1,148.07 AGENCY CNCL: CSA CODE DATE INSURANCE AGENCY BAL: .00 1: 978 06/11/07 1,148.07- CODE PLAN DATE STAT POLICY NO 2: 3: 4: 5: PROCESS REVIEW DATE USER DATE E 11/08/07 PBY454 00/00/00 11/08/07 PBY454 00/00/00 05/17/07 ASET 00/00/00 05/15/07 ASET 00/00/00 1: 2: 3: LST ACTN: 99 11/08/07 3: NN 11/27/06 PAY AUD 1: KK 05/10/07 4: L1 11/07/06 PAY AUD 2: UU 05/03/07 5: Sl 08/21/06 ARLYOUT ASSGN: 09/11/06 RETN 11/07/06 REASON 985 I SOLD A/R TO IPI $1,148.07 I PRIM CD:CSA-UNCOLLECTABLE ; SEC CD:CSA-UNCOLLECTABL 19:14 is #8 60767 69248 14:20 lser #999 et T02ACCCR index 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 XCAL1022 #§ 2/13 Printed on 04/27/10 14:43:50 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. v ?. Date: Gi posito °f CU'tt David D. Buell- ¢` e Renee 7 Simpson prothonotary o :.;f, Z 1St Deputy prothonotary o �irkS. Sofionage, ES \X a - Irene E. Morrow SoCicitor x750 2nd Deputy prothonotary Office of f the Prothonotary Cum6erfand County, cPennsyCvania -429 5I 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 • CarlisCe, TA 17013 • (717)240-6195 • Eax,(717)240-6573