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HomeMy WebLinkAbout10-2853 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 v. HOPE M MONISMITH 132 Mooredale Rd CARLISLE PA 17015 2010 APR 29 Ali 10: 51 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL ACTION NO n t 0- as.53 e iv i l T erm 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 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 O 1-800-990-9108 717-249-3166 * qa . 00 Pb ATTY ??-? ago F?s 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. HOPE M MONISMITH 132 Mooredale Rd CARLISLE PA 17015 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, HOPE M MONISMITH, is an individual residing at 132 Mooredale Rd, CARLISLE PA 17015. 3. As a result of a certain medical condition, Defendant, HOPE M MONISMITH, was admitted to Carlisle Regional Medical Center on 06/29/2006 through 06/29/2006 and on 11/26/2006 through 11/26/2006. 4. Carlisle Regional Medical Center rendered services to Defendant, HOPE M MONISMITH, of the kinds and for the prices set forth in their bill which is now part of Plaintiffs records and is set forth as Exhibit P-1. 5. The charges of $3334.79 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, HOPE M MONISMITH. 6. Said medical care was commensurate with the condition of Defendant, HOPE M MONISMITH, 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 06/29/2006, Defendant, HOPE M MONISMITH, was discharged from Carlisle Regional Medical Center. 9. No payments have been made, and Defendant, HOPE M MONISMITH, breached the agreement with Carlisle Regional Medical Center by failing and/or refusing to pay the balance of the agreed price, $3334.79, although requested to do so by Plaintiff and their attorneys. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $3334.79, plus six percent (6%) interest per annum, from the date of discharge to the date of judgment, and record and non-record costs. TWARD ND ASSOCIATES GEORGE TWARDY, JR., ESQUIRE ATTORNEY FOR PLAINTIFF EXHIBIT P-1 04/27/10 HEALTH MANAGEMENT ASSOCIATES DA04 COID: 858 ACCOUNT #: 9355177 DISCHARGE ACCOUNTS RECEIVABLE RECORD PAT NAME: MONISMITH, HOPE M ADMIT: 11/26/06 FINANCIAL CLASS: 9 P GAR NAME: MONISMITH, HOPE M DISCHARGE: 11/26/06 CONTRACT FREQ: S STREET: 439 NORTH EAST STREET LAST PAY: 11/26/06 MAIL RETURN: ADDR-2: PROGRAM: PAT TYPE: E1 CITY: CARLISLE PA 17013 CONTRACT: .00 PAT SEX: F PHONE: (717) 713-3651 COUNTRY: US CURR BAL: .00 GAR SEX: F EMPLOYER: NOT EMP TOT CHARGES: 1,629.01 AGENCY CNCL: CSA CODE DATE INSURANCE AGENCY BAL: .00 1: 978 09/24/07 1,629.01- CODE PLAN DATE STAT POLICY NO 2: 1: 3: 2: 4. 3: 5: LST ACTN: 99 11/08/07 3: NN 03/12/07 PAY AUD 1: KK 07/12/07 4: L1 02/20/07 PROCESS REVIEW PAY AUD 2: UU 07/05/07 5: S1 11/30/06 DATE USER DATE EARLYOUT ASSGN: 12/24/06 RETN 02/20/07 REASON 985 11/08/07 PBY454 00/00/00 I SOLD A/R TO IPI $1,629.01 11/08/07 PBY454 00/00/00 I PRIM CD:CSA-UNCOLLECTABLE ; SEC CD:CSA-UNCOLLECTABL 07/15/07 ASET 00/00/00 20:03 is #8 60826 72225 07/13/07 ASET 00/00/00 18:21 lser #999 et T02AOOCR 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 14:35:10 04/27/10 HEALTH MANAGEMENT ASSOCIATES DA04 COID: 858 ACCOUNT #: 9342947 DISCHARGE ACCOUNTS RECEIVABLE RECORD PAT NAME: MONISMITH, HOPE M ADMIT: 06/29/06 FINANCIAL CLASS: 9 P GAR NAME: MONISMITH, HOPE M DISCHARGE: 06/29/06 CONTRACT FREQ: S STREET: 439 NORTH EAST STREET LAST PAY: 06/29/06 MAIL RETURN: ADDR-2: PROGRAM: PAT TYPE: E1 CITY: CARLISLE PA 17013 CONTRACT: .00 PAT SEX: F PHONE: (717) 713-3651 COUNTRY: US CURR BAL: .00 GAR SEX: F EMPLOYER: NOT EMP TOT CHARGES: 1,624.78 AGENCY CNCL: CSA CODE DATE INSURANCE AGENCY BAL: .00 1: 978 04/18/07 1,624.78- CODE PLAN DATE STAT POLICY NO 2: 978 04/27/07 .00 1: 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 09/21/06 PROCESS REVIEW PAY AUD 2: UU 03/08/07 5: S1 07/10/06 DATE USER DATE :EARLYOUT ASSGN: 07/27/06 RETN 09/22/06 REASON 985 11/08/07 PBY454 00/00/00 1 SOLD A/R TO IPI $1,624.78 11/08/07 PBY454 00/00/00 1 PRIM CD:CSA-UNCOLLECTABLE ; SEC CD:CSA-UNCOLLECTABL 06/19/07 ASET 00/00/00 11:23 res 717-713-3651 LEFT AUTO MSG 06/19/07 ASET 00/00/00 11:23 ON MACH 60800 41003 1=UP,2=PT,3=GAR,4=INS,5=UB,6=HIS,7=RTN,8=CMTI,9=CMTU,I0=DET,II=LOG, I3=ADJ,ENT=FW 4-© A Sess-1 10.200.98.7 XCAL1022 #§ 2/13 Printed on 04/27/10 14:36:12 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. of co,„ David 1n. Buell- r p 1�,enee Simpson Prothonotary 1St Deputy Prothonotary �irkS. Sohonage, ESQ Irene E. Morrow Solicitor 1750 2nd Deputy Prothonotary Office of the Prothonotary Cumberland County, Pennsylvania 10 - ,..2S53 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 • Carlisle, 2'A 17013 • (717)240-6195 • Fax(717)240-6573