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Home My WebLink About10-4722r .~ RICHARD MCMINN LINDA MCMINN 248 REDWOOD LANE CARLLSLE PA, 17015 717-620-8992 INTERNATIONAL PROTFOLIO, INC. , 200 BAR HARBOUR DRIVE , SUITE 400 WEST CONSHOHOCKEN, PA 19428 , v. RICHARD MCMINN LINDA MCMINN 248 REDWOOD LANE CARLISLE PA, 17015 , Defendants f ~, , CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVII.. ACTION NO 10-4722 RESPONSE/ANSWER TO COMPLAINT RICHARD MCMINN LINDA MCMIlVN 248 REDWOOD LANE CARLISLE PA, 17015 717-620-8992 INTERNATIONAL PROTFOLIO, INC. 200 BAR HARBOUR DRIVE SUITE 400 WEST CONSHOHOCI~N, PA 19428 v. RICHARD MCMINN LINDA MCMIlVN 248 REDWOOD LANE CARLISLE PA, 17015 Defendants CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL ACTION NO 10-4722 RESPONSE/ANSWER TO COMPLAINT 1. Plaintiff International Portfolio, Inc., as the Assignee of the debt from Carlisle Regional Medical Center, have already obtained a judgmem against our daughter MICHELLE L MCMINN for this debt. 2. Defendants, RICHARD MCMINN and LINDA MCMINN do reside at 248 REDWOOD LANE, CARLISLE PA 17015 and are indeed the parents of MICHELLE L MCMINN, who was a patient at Carlisle Regional Medical Center. 3. As a result of a certain medical condition, the adult child of Defendants, MICHELLE L MCMINN was seen at the emergency room at Carlisle Regional Medical Center on 07/20/2006 through 07/20/2006. 4. Carlisle Regional Medical Center did indeed render services to MICHELLE L MCMINN, as set forth in plaintii~s Exhibit P-1. 5. The charges of $1672.30 for Carlisle Regional Medical Center, were charges prior to the uninsured discount by said party. After applying said discount Carlisle Regional Medical Center's charges totaled $638.13. Defendants RICHARD MCMINN and LINDA MCMINN did not agree to any charges, the charges were not discussed with Defendants. Defendants have never been considered the responsible party for said charges. 6. Said medical care was commensurate with the condition of MICHELLE L MCMINN, and was indeed necessary for the health and welfare of MICHELLE L MCMINN. 7. Defendants RICHARD MCMINN and LINDA MCMINN, did not have any agreement with Carlisle Regional Medical Center, implied, constructive and/or verbal contracts for services rendered on 07/20/06 for MICHELLE L MCMINN, due to MICHELLE L MCMINN'S age of 19 years, Carlisle Regional Medical Center registered MICHELLE L MCMINN as responsible parry. 8. On 07/20/06, MICHELLE L MCNiINN, was discharged from Carlisle Regional Medical Center under her own care. 9. MICHELLE L MCMINN, was on 07/20/06 the adult child of Defendants RICHARD MCMINN and LINDA MCMINN, and was living in defendants residence. 10. No bills were received by the Defendants, RICHARD MCMINN and LINDA MCMINN, therefore there was no breach of contract, Carlisle Regional Medical Center was addressing the bills to MICHELLE L MCMINN set forth as Exhibit D-2. WHEREFORE, Defendant pleads not guilty and asks the court to examine evidence of non-responsibility attached. Date: ~ " ~ q ` Defendant Date: 1 ' ~~ " c endant E~:HIBIT D-1 From: Rose, Suzanne (Suzanne.Rose@hma.com) To: linc~a mcminn716@yahoo.com; D$te: Thu, July 22, 2010 2:41:24 PM Cc: Subject: RE: 2006 Bill Hi Linda, My supervisor and I went into check these accounts as well, and they were indeed under your daughter's name as both patient and responsible party. These accounts are older accounts that were solo to International Portfolio, and no where on the accounts do we show you as responsible party. So, I would send them the e-mail I just sent to you and that you are not the responsible party, she was of legal age at that time. Let us know if we can be of any further help. Suzanne Rose Bitter Business Office Carlisle Regional Medical Center 717-960-3273 From: Linda Mcminn [mailto:linda_mcminn715@yahoo.com] SeniG Thursday, July 22, 2010 3:31 PM Ta Rose, Suzanne Subjeeit~ Re: 2006 Bill I~ Suzanne, Thank you for your response. I am being sued for this bill by a company named "Internation Portfolio, Inc". If I have no rights to the bill or the records how can I be held responible? Thank You Linda McMinn Fran: "Rose, Suzanne" <Suzanne.Rose~hma.com> T« Linda Mcminn <linda_rncminn716@yahoo.corn> Senn Thu, )uly 22, 2010 2:25:40 PM 9ubJec~ RE: 2006 Bill Hi Linda, As discussed by telephone, since your daughter was 19 at the time of date of service, she would have to get the medical recorcls or give you permission to get the records. Everything would have to be in writing as there is a release of records form that would have to be signed. The bill would also have to go to her, as well. There are privacy laws (HIPAA) that protect this information and are very strict about disclosure of any information. Any further questions, please let me know. Suzanne Rose Business Office Carlisle Regional Medical Center 717-ARn-~97~ Fran: Linda Mcminn [mailbo:iinda_mcminn716C~yahoo.oom] Send Thursday, July 22, 2010 3:18 PM Ta Rose, Suzanne Subject: 2006 &II Hi Suzanne, I need copies of records and a bill for Michelle McMinn (daughter), service date 7/20/06, birthdate 12/03/86. She was 19 at the time, but living at home. The bills I believe were mailed to her in her name. 1Vfichelle MclVfinn 248 Redwood Lane Carlisle Pa 17013 Thank You Linda McMinn VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, that Richard McMinn and Linda McMinn, Defendants herein, and that the facts set forth in the Response/Answer to the foregoing Complaint in Civil Action, and any attachments thereto, are true and correct to the best of their knowledge, information and belief. Date: ~ ~q • I D Date: I ` (~)q Defendant fendant SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor International Portfolio Inc. vs. Richard McMinn (et al.) ~~~pcr nt ~u~~pr~~~ ~ ,,. .° ty1 tf.~3 ~~r , . `?~ £YFFEGE r. F r~E $~ERIFE . m. ~.~ ~~ . ~- .: ~1 f 55 ~~ k~ i:v ,J ~ J f-~:: ~ .. z.J , X1010 f~'Ub 9 ~tih ~ :S~- C':.. Case Number 2010-4722 SHERIFF'S RETURN OF SERVICE 07/20/2010 08:21 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on July 20, 2010 at 2021 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Linda McMinn, by making known unto herself personally, at 248 Redwood Lane, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to her personally the said true and correct copy of the same. NOAH CLINE, D TY 07/28/2010 11:45 AM -Brian Garrick, Corporal, who being duly sworn according to law, states that on July 28, 2010 at 1145 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Richard McMinn, by making known unto himself personally, at The Cumberland County Sheriffs Office, 1 Courthouse Square Room 303, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct co f the same. ~- BRIA BARRICK, DEPUTY SHERIFF COST: $49.40 July 28, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (cj CountySuite Sheaff. Teleosofl. loc. ®avid D. Buelr Prothonotary Office of the Prothonotary Cum6er[and County, Pennsylvania 7�yrkS. Sohonage, ESQ Solicitor 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 CarCisCe, TA 0 Phone 717 240-6195 0 Fax 71 7 240-6573