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HomeMy WebLinkAbout11-5080FS`E FiC- A 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 Att(Wy i Aing r.UMBFRUJO, 00`t4- VALUE HEALTHCARE MANAGEMENT,LLC 152 WEST 57TH STREET NEW YORK, NY 10019 CUMBERLAND COUNTY COURT OF COMMON PLEAS V. CIVIL ACTION NO // -,SQ$p MATTHEW J HODGE 345 W PENN ST CARLISLE PA 17013 COMPLAINT - CIVIL ACTION NOTICE 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 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 OR TELEPHONE 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 Telephone: 717-249-3166 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notification. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su medidas y puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta damanda. Usta puede perder dinero o sus propiedades u otros derechos importantes para usted. "LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE 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." Asociacion De Licenciados De Cumberland County Servico De Referencia E. Informacion Legal Cumberland County Bar Association 32 South Bedford Street p Carlisle, PA 17013 Telephone: 717-249-3166 eke asc? a?o74? 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 VALUE HEALTHCARE MANAGEMENT,LLC: 152 WEST 57TH STREET NEW YORK, NY 10019 Vs. MATTHEW J HODGE 345 W PENN ST CARLISLE PA 17013 CUMBERLAND COUNTY COURT OF COMMON PLEAS COMPLAINT 1. Plaintiff, Value Healthcare Management, LLC, 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, MATTHEW J HODGE, is an individual residing at 345 W PENN ST, CARLISLE PA 17013. 3. As a result of a certain medical condition, Defendant, MATTHEW J HODGE, was admitted to Carlisle Regional Medical Center on 06/21/2007 through 06/21/2007. 4. Carlisle Regional Medical Center rendered services to Defendant, MATTHEW J HODGE, 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 $1500.00 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, MATTHEW J HODGE. 6. Said medical care was commensurate with the condition of Defendant, MATTHEW J HODGE, 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 06/21/2007, Defendant, MATTHEW J HODGE, was discharged from Carlisle Regional Medical Center. 9. No payments have been made, and Defendant, MATTHEW J HODGE, breached the agreement with Carlisle Regional Medical Center by failing and/or refusing to pay the balance of the agreed price, $1500.00, although requested to do so by Plaintiff and their attorneys. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $1500.00, 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 1 GEORGE TWARDY, JR., ESQUIRE ATTORNEY FOR PLAINTIFF EXHIBIT P-1 06/16/11 HEALTH MANAGEMENT ASSOCIATES DA04 COID: 858 ACCOUNT #: 7706310 DISCHARGE ACCOUNTS RECEIVABLE RECORD PAT NAME: HODGE, MATTHEW J ADMIT: 06/21/07 FINANCIAL CLASS: 9 I GAR NAME: HODGE, MATTHEW J DISCHARGE: 06/21/07 CONTRACT FREQ: S STREET: 345 W PENN ST LAST PAY: 07/03/07 MAIL RETURN: ADDR-2: PROGRAM: PAT TYPE: OZ CITY: CARLISLE PA 17013 CONTRACT: .00 PAT SEX: M PHONE: (717) 241-2414 COUNTRY: US CURR BAL: .00 GAR SEX: M EMPLOYER: FROG SWITCH TOT CHARGES: 6,445.81 AGENCY CNCL: CSA CODE DATE INSURANCE AGENCY BAL: .00 1: 951 07/03/07 2,836.15- CODE PLAN DATE STAT POLICY NO 2: 200 07/03/07 2,109.66- 1: 200 BS1 09/14/07 6,445 D ZAR110405681001 3: 978 04/24/08 1,500.00- 2: 4. 3. 5: LST ACTN: 99 11/19/09 3: IT 11/14/07 PAY AUD 1: QQ 04/23/08 4: Ll 11/04/07 PROCESS REVIEW PAY AUD 2: UU 04/16/08 5: 15 09/17/07 DATE USER DATE EARLYOUT ASSGN: 08/10/07 RETN 11/04/07 REASON 985 11/19/09 PBY454 00/00/00 1 SOLD A/R $1,500.00 11/19/09 PBY454 00/00/00 1 PRIM CD:CUN-UNCOLLECTABLE ; SEC CD:CSA-UNCOLLECTABL 11/09/09 JBAO 00/00/00 Cancel back principal 1500.00 07/23/08 JBAO 00/00/00 LMCOR 1=UP,2=PT,3GAR,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 XCAL1123_ #§ 2/13 Printed on 06/16/11 10:44:29 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities, that he/she is Ezra Zucker, Supervisor of Customer Care of Value Healthcare Management, LLC , plaintiff herein, that he/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 his/her knowledge, information and belief. Date: 6-/ -;0/ 1 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ?4???tr at ?:uutt,?rt??fr? OF THE PROTHONOTARY 2011 JUN 29 AM 9? 2 CUMBER`ANO COUNTY PENNSYLVANIA Value Healthcare Management, LLC vs. Matthew J. Hodge Case Number 2011-5080 SHERIFF'S RETURN OF SERVICE 06/24/2011 09:35 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on June 24, 2011 at 2135 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Matthew J. Hodge, by making known unto himself personally, at 331 W. North Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. ?? TIM K, DEPUTY SHERIFF COST: $46.00 June 27, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF %ci CourfySuite sherff. Teiee ;oft Inc. .I IN THE COURT OF COMMON PLEA OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION VALUE HEALTHCARE MANAGEMENT, LLC: 152 WEST 57TH STREET NEW YORK, NY 10019 NO. 2011-5080 VS. ;.7? =F D MATTHEW J HODGE 331 W NORTH STREET CARLISLE PA 17013 C =- 13C - - `' PRAECIPE FOR JUDGMENT Enter Judgment in favor of Plaintiff, Value Healthcare Management, LLC, and against Defendant, MATTHEW J HODGE for want of an answer in the amount of: Debt: $1500.00 Interest/costs: $138.00 + ongoing Total: $1638.00 I certify that the forgoing assessment of damages if for the specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. Pursuant to PA R.C.P. No. 237 (Notice of Praecipe for Final Judgment), I certify that a copy of this Praecipe has been mailed to each party who has appeared in the action or to his or her Attorney of Record. Pursuant to Pa. R.C.P., I certify that written Notice of Intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to his Attorney of Record if any, after the default occurred and at least ten (10) days prior to the date of the filing this Praecipe for not filing an answer to the complaint. DATE: "CO George Twardy, Jr. Esquire Q?& $e l Attorney for Value Healthcare h ?p `(u 11 M gement, LLC " ?CLL u-A NOW,_ St . J DGMENT IS ENTERED ABOVE. Proth c e v ision By:____ Deputy Ilk t? 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 IN THE COURT OF COMMON PLEAS OF CUMBERLANDCOUNTY VALUE HEALTHCARE MANAGEMENT, LLC. 152 WEST 57TH STREET NEW YORK, NY 10019 NO. 2011-5080 VS. MATTHEW J HODGE 331 W NORTH STREET CARLISLE PA 17013 . CERTIFICATE OF SERVICE- PRAECIPE FOR JUDGMENT I, George Twardy, Jr., Esquire, do hereby certify that a true and correct copy of the Praecipe for Judgment regarding the above captioned matter has been forwarded via U.S. First Class Mail, on -(-a 6 -011 MATTHEW J HODGE 331 W NORTH STREET CARLISLE PA 17013 LAW to the following: CES OF GEORGE TWARDY, JR. t-3?orge Twardy, Jr., Attorney for Plaintiff LAW OFFICES OF GEORGE TWARDY, JR. BY: GEORGE TWARDY, JR., ESQUIRE ATTORNEY ID# 52883 1026 WINTER STREET, SUITE 400 PHILADELPHIA, PA 19107 TEL.# 1-877-440-8182 Attorney for Plaintiffs V AL U t HEAL I HCARE MANAGEMENT, LLC. 152 WEST 57TH STREET COURT OF COMMON PLEAS NEW YORK, NY 10019 CUMBERLAND COUNTY VS. MATTHEW J HODGE NO. 2011-5080 331 W NORTH STREET CARLISLE PA 17013 VERIFICATION OF NON-MILITARY SERVICE I here by verify that I am Attorney for Plaintiff in the above captioned matter, and that on information and belief, I have knowledge of the following facts, to wit: (a) That the Defendant(s) is/are not in the Military or Naval Service of the United State or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) That the Defendant, MATTHEW J HODGE Or occupants, is over 18 years of age, and resides at 331 W NORTH STREET, CARLISLE PA 17013 This statement is made subject to the penalties of 10 PA CSS 4904 relating to unsworn falsification to authorities. George Twardy, Jr. Esq. Attorney for Plaintiffs 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 IN THE COURT OF COMMON PLEAS OF CUMBERLANDCOUNTY VALUE HEALTHCARE MANAGEMENT, LLC. 152 WEST 57TH STREET NEW YORK, NY 10019 NO. 2011-5080 VS. MATTHEW J HODGE 331 W NORTH STREET CARLISLE PA 17013 FICATE OF SERVICE- NOTICE OF PRAECIPE TO ENTER JUDGMENT I, George Twardy, Jr., Esquire, do hereby certify that a true and correct copy of the Notice of Praecipe for Judgment regarding the above captioned matter has been forwarded via U.S. First Class Mail, on q'I - O ?- „o 1 , to the following: MATTHEW J HODGE 331 W NORTH STREET CARLISLE PA 17013 LAW OFFICES OF GEORGE TWARDY, JR. s orge Twardy, Jr., Esquire Attorney for Plaintiff TWARDY & ASSOCIATES, LLC 1026 Winter Street, Suite 400 Philadelphia, PA 19107-1808 ' 877-440-8182 (toll free) September 9, 2011 MATTHEW J HODGE 33 i W NORTH STREET CARLISLE PA 17013 RE: VALUE HEALTHCARE MANAGEMENT, LLC. v. MATTHEW J HODGE Docket: 201.1-5080 COURT OF COMMON PLEAS CUMBERLAND COUNTY Dear MATTHEW J HODGE, Enclosed please find a copy of the Notice of Praecipe to Enter Judgment by Default. You are advised to take the appropriate legal action immediately so as to avoid judgment being entered against you in this matter. If you wish to amicably resolve this matter please feel free to call our office at the above toll free number. Singerely, George Twardy, Jr, Esq. GT/km Attorney for Plaintiff', International Portfolio, Inc. Encl. . . , 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY VALUE HEALTHCARE MANAGEMENT, LLC 152 WEST 57 T11 STREET NEW YORK, NY 10019 * NO. 2011-5080 MATTHEW J HODGE 331 W NORTH STREET CARLISLE PA 17013 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT TO: IbIATTHE W J HODG.E Defendant DATE OF NOTICE: September 9,2011 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTE[ AGAINST YOU. UNLESS YOU ACT WITEIJI TEN (tO) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland Bar Association Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 Telephre: 717-249-3166 i?eorge Twardy, Jr., Esquire Attorney for Plaintiff; hlternational Portfolio Inc. 1026 Winter St Philadelphia, PA 19107-1808 Phone: 877-440-8182 ID. No. 52883