The URL can be used to link to this page

Home My WebLink About10-4481IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNV, N PENNSYLVANIA F, C CIVIL ACTION-LAW David Bronstein, D.O. Richard H. Jefferies, D.O. Professional Association 25 Spirit Drive Carlisle, PA 17015, COMPLAINT c Plaintiff V. Kathy Wilson, Executrix for the Estate of Steven Wilson and Kathy Wilson, individual 1409 Goodyear Road Gardners, PA 17324, Defendants No. 10 -021 NOTICE 0--tv*1 lTem, 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 upon you, by entering a written appearance personally (or by attorney) and by 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 OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 NOTICIA Le han demandado a usted en la corte. Se usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defenses o sus objectiones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demands. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association Lawyer Referral Service G) 32 South Bedford Street 0100 PO ATT'/ Carlisle, PA 17013 C o50y (717) 249-3166 2t ay4q-,?s COMPLAINT AND NOW, comes Plaintiff, by and through its attorney, Rebecca S. McClure, Esq., and complains against Defendants as follows: Count I 1. The Plaintiff is David Bronstein, D.O. Richard H. Jeffries, D.O. Professional Association, and is a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with a principal place of business at 25 Spirit Drive, Carlisle, Cumberland County, Pennsylvania 17015. 2. One of the Defendants is Kathy Wilson, Executrix for the Estate of Steven Wilson, last known to reside at 1409 Goodyear Road, Gardners, Cumberland County, Pennsylvania, 17324. 3. One of the Defendants is Kathy Wilson who is an adult individual last known to reside at, 1409 Goodyear Road, Gardners, Cumberland County, Pennsylvania, 17324. 4. During the period from approximately December 20, 2007 through October 22, 2008 Plaintiff rendered medical services, medical supplies and/or medications to Steven Wilson. 5. Steven Wilson died on January 22, 2009. 6. Defendant Kathy Wilson is the Executrix for the Estate of Steven Wilson and, as such, is responsible, through his Estate, for the payment of the balance due and owing to Plaintiff as a result of the medical services that were rendered to Steven Wilson. 7. As the spouse of Steven Wilson at the time medical services were rendered to him, Defendant Kathy Wilson is legally responsible for the cost of these necessary medical services rendered to Defendant Steven Wilson. ti 8. The total unpaid balance remaining due and owing to Plaintiff from Defendants for said medical services, medical supplies and/or medications rendered to/supplied by Plaintiff is $11,015.50 9 Despite repeated requests, Defendants have failed and refused to pay Plaintiff the balance due and owing to Plaintiff of $11,015.50 for the medical services, medical supplies and medications provided to Defendant Steven Wilson. 10. As a result of said default and Defendants' failure and refusal to pay Plaintiff, the following amounts are due and owing to Plaintiff from Defendants: $11,015.50, plus costs and interest at 6% per annum ($1.81/diem) from the date of judgment. WHEREFORE, David Bronstein, D.O. Richard H. Jeffries, D.O. Professional Association, Plaintiff demands judgment against Defendants Kathy Wilson, Executrix for the Estate of Steven Wilson and Kathy Wilson individually in the amount of $11,015.50, together with 6% per annum ($1.81 per diem) interest, costs, and any and all other relief as the Court deems appropriate. Count II 11. Plaintiff incorporates herein by reference each and every allegation set forth in Paragraphs 1 through 10 herein. 12. As a result of the aforementioned, Defendants have become unjustly enriched and received the benefits of Plaintiffs said goods, merchandise, and services without paying for same in the remaining balance of $11,015.50 plus 6% per annum ($1.81/diem) interest and costs, which are the fair, reasonable, and market charges for said goods, merchandise, and services provided by Plaintiff to and upon the, request of Defendants, and which remain unpaid despite Plaintiffs demand for payment. ti WHEREFORE, Plaintiff David Bronstein, D.O. Richard H. Jeffries, D.O. , Professional Association demands judgment against Defendants Kathy Wilson, Executrix for the Estate of Steven Wilson and Kathy Wilson individually in the amount of $11,015.50, together with 6% per annum ($1.81 per diem) interest, costs, and any and all other relief as the Court deems appropriate. Count III 13. Plaintiff incorporates herein by reference each and every allegation set forth in Paragraphs 1 through 12 herein. 14. Because Defendant Kathy Wilson was the spouse of Steven Wilson at the time services were rendered to him, Defendant Kathy Wilson is legally responsible for the cost of these necessary medical services rendered to Steven Wilson. WHEREFORE, Plaintiff David Bronstein, D.O. Richard H. Jeffries, D.O. , Professional Association demands judgment against Defendant Kathy Wilson in the amount of $11,015.50, together with 6% per annum ($1,81 per diem) interest, costs, and any and all other relief as the Court deems appropriate. AM /11 e (I.D. #46662) Attorney for Plaintiff P.O. Box 64 Mountville, PA 17554 (717) 285-7172 VERIFICATION I, Robert C. Schwartz M.D., Managing Partner and President for Plaintiff David Bronstein, D.O. Richard H. Jeffries, D.O., Professional Association, hereby verify and affirm that that the averments set forth in this Complaint are true and correct to the best of my knowledge, information and belief, and that I am an officer of David Bronstein, D.O. Richard H. Jeffries D.O., Professional Association and have been duly appointed and authorized to execute this verification on its behalf. gd.?'?? C. 3Cam. ?. , Date Robert C. Schwartz, M.D., Managing Partner and President David Bronstein, D.O. Richard H. Jeffries, D.O., Professional Association SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~~' ~~`~ ' ~ ~ _ Sheriff ~ 1~ Tt r ; ; _ ~~V ~,~tcr ~i ~~r,rt~yr~,~~~~ Jody S Smith Chief Deputy ~~' .. ~ `,~r Z~ ~ Q .' ._ E~ 1+ ~ ~ I ~ Richard W Stewart ~' ~ •.~ ,. m~ Solicitor f~e~ --,.,G ~,.~~~r~ ~ i ~ - . ; ~:+~ z s Richard Bronstein Case Number vs. 2010-4481 Kathy Wilson SHERIFF'S RETURN OF SERVICE 07/13/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Kathy Wilson, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Kathy Wilson. Request for service at 1409 Goodyear Road, Gardners, PA 17324 is vacant and currently for sale. However, The Gardners Postmaster has advised they are delivering Kathy Wilson's mail to 1409 Goodyear Road, Gardners, PA 17324. 07/13/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Kathy Wilson as the Executrix for the Estate of Steven Wilson and Kathy Wilson, individual, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Kathy Wilson. Request for service at 1409 Goodyear Road, Gardners, PA 17324 is vacant and currently for sale. However, The Gardners Postmaster has advised they are delivering Kathy Wilson's mail to 1409 Goodyear Road, Gardners, PA 17324. SHERIFF COST: $64.34 July 13, 2010 SO ANSWERS, ___. RON ~ R ANDERSON, SHERIFF (c CountySuite Shenff. Teleosoft Inc. David ED. Buell' Prothonotary Office of the Prothonotary Cum6er[and County, (Pennsylvania rkS. Sohonage, ESQ, Solicitor A() - ANSI CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2014, 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 0 Suite100 0 Car[is(z, TA 0 (Phone 717 240-6195 0 Ea. 717 240-6573