The URL can be used to link to this page

Home My WebLink About10-2855LAW 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. MARLIN LEROY HIPPENSTEEL, Jr. Parent of MARLIN HIPPENSTEEL III 12844 ECHO DELL ROAD LOT 61 EAST LIVERPOOL OH 43920 Tur: 2010 Atiom2y 41 l1 AtIff cu l CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL ACTION NO ?o - 61855 iV; t?rx 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 RaORTANT 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 OA 1-800-990-9108 *Ra - oo PO A-MY 717-249-3166 k,** a 179 2,? ay 1.:3,23 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. MARLIN LEROY HIPPENSTEEL, Jr. Parent of MARLIN HIPPENSTEEL 111 12844 ECHO DELL ROAD LOT 61 EAST LIVERPOOL OH 43920 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, MARLIN LEROY HIPPENSTEEL, Jr., is an individual residing at 12844 ECHO DELL ROADLOT 61, EAST LIVERPOOL OH 43920 and is the parent of MARLIN HIPPENSTEEL III, who was a patient at Carlisle Regional Medical Center. The Defendant, MARLIN LEROY HIPPENSTEEL, Jr., was also a patient at Carlisle Regional Medical Center. 3. As a result of a certain medical condition, the minor child of Defendant, MARLIN HIPPENSTEEL III, was admitted to Carlisle Regional Medical Center on 06/19/2006 through 06/19/2006. The Defendant, MARLIN LEROY HIPPENSTEEL, Jr., was admitted to Carlisle Regional Medical Center on 08/15/2006 through 08/15/2006. 4. Carlisle Regional Medical Center rendered services to Defendant, MARLIN HIPPENSTEEL Jr and his minor child, 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 $3803.28 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, MARLIN LEROY HIPPENSTEEL, Jr. on behalf of himself and his/her minor child, MARLIN HIPPENSTEEL III. 6. Said medical care was commensurate with the condition of Defendant, MARLIN LEROY HIPPENSTEEL, Jr., 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 06/19/2006, MARLIN HIPPENSTEEL III, was discharged from Carlisle Regional Medical Center to the care of Defendant. 9. MARLIN HIPPENSTEEL III, is the minor child of Defendant and is living with Defendant, therefore, Defendant is liable for his/her necessaries under the support law of Pennsylvania. 10. No payments have been made, and Defendant, MARLIN LEROY HIPPENSTEEL, Jr., breached the agreement with Carlisle Regional Medical Center by failing and/or refusing to pay the balance of the agreed price, $3803.28, although requested to do so by Plaintiff and their attorneys. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $3803.28, 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- 1( GORGE TWARDY, JR., MUM— ATTORNEY FOR PLAINTIFF EXHIBIT P-1 31/09 HEALTH MANAGEMENT ASSOCIATES DA04 COID: 858 . .ACCOUNT #: 9342222 DISCHARGE ACCOUNTS RECEIVABLE RECORD .PAT NAME: HIPPENSTEEL, MARLIN III ADMIT: 06/19/06 FINANCIAL CLASS: 9 P . .GAR NAME: HIPPENSTEEL, MARLIN IR DISCHARGE: 06/19/06 CONTRACT FREQ: S STREET: 131 N WEST STREET LAST PAY: 06/19/06 MAIL RETURN: ADDR-2: PROGRAM: PAT TYPE: E1 CITY: CARLISLE PA 17013 CONTRACT: .00 PAT SEX: M PHONE: (717) 226-7091 COUNTRY: US CURR BAL: .00 GAR SEX: M .EMPLOYER: ASSOCIATED PRODUCTS TOT CHARGES: 2,201.84 AGENCY CNCL: CSA . CODE DATE INSURANCE AGENCY BAL: .00 .1: 978 05/11/07 2,201.84- CODE PLAN DATE STAT POLICY NO .2: 1: .3: 2: .4: 3: .5: LST ACTN: 99 11/08/07 3: NN 12/18/06 PAY AUD 1: KK 05/10/07 4: L1 11/28/06 .PROCESS REVIEW PAY AUD 2: UU 05/03/07 5: S3 07/17/06 . DATE USER DATE ARTRAC ASSGN: 07/27/06 RETN 11/28/06 REASON 985 .11/08/07 PBY454 00/00/00 SOLD A/R TO IPI $2,201.84 .11/08/07 PBY454 00/00/00 PRIM CD:CSA-UNCOLLECTABLE ; SEC CD:CSA-UNCOLLECTABL. .07/12/07 ASST 00/00/00 11:11 res 717-226-7091 weak 60823 40308 .06/21/07 ASST 00/00/00 10:16 res 717-226-7091 LEFT AUTO MSG =UP,2=PT,3=GAR,4=INS,5=UB,6=HIS,7=RTN,8=CMTI,9=CMTU,10=DET,11=LOG,I3=ADJ,ENT=FW. /09 HEALTH MANAGEMENT ASSOCIATES DA04 COID: 858 . ACCOUNT #: 9346862 DISCHARGE ACCOUNTS RECEIVABLE RECORD PAT NAME: HIPPENSTEEL, MARLIN JR L ADMIT: 08/15/06 FINANCIAL CLASS: 9 P . GAR NAME: HIPPENSTEEL, MARLIN JR L DISCHARGE: 08/15/06 CONTRACT FREQ: S STREET: 131 N WEST STREET LAST PAY: 08/15/06 MAIL RETURN: ADDR-2: PROGRAM: PAT TYPE: E1 CITY: CARLISLE PA 17013 CONTRACT: .00 PAT SEX: M PHONE: (717) 226-7091 COUNTRY: US CURR BAL: .00 GAR SEX: M EMPLOYER: ASSOCIATED PRODUCTS TOT CHARGES: 1,601.44 AGENCY CNCL: CSA . CODE DATE INSURANCE AGENCY BAL: .00 1: 978 06/13/07 1,601.44- CODE PLAN DATE STAT POLICY NO 2: 1: 3: 2: 4: 3: 5: LST ACTN: 99 11/08/07 3: NN 11/17/06 PAY AUD 1: KK 05/10/07 4: L1 11/07/06 PROCESS REVIEW PAY AUD 2: UU 05/03/07 5: S3 09/11/06 DATE USER DATE ARTRAC ASSGN: 09/12/06 RETN 11/07/06 REASON 985 11/08/07 PBY454 00/00/00 SOLD A/R TO IPI $1,601.44 11/08/07 PBY454 00/00/00 PRIM CD:CSA-UNCOLLECTABLE ; SEC CD:CSA-UNCOLLECTABL. 07/12/07 ASET 00/00/00 11:11 res 717-226-7091 weak; Copied 07/12/07 ASET 00/00/00 11:11 Acct: 3766774 60823 40 .1=UP,2=PT,3=GAR,4=INS,5=UB,6=HIS,7=RTN,8=CMTI,9=CMTU,10=DET,11=LOG,I3=ADJ,ENT=FW. 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 °F CV41 David-D. Buell e P Renee X Simpson Prothonotary lT� ;;., D 15` Deputy prothonotary �irkS. Sofionage, ES `� Irene E. Morrow Solicitor 7750 2nd-Deputy prothonotary Office of the Prothonotary Cumberland County, cPennsyCvania -.2ggr 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, PA 17013 • (717)240-6195 • Faz(717)240-6573