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Home My WebLink About01-3319 TI-IIS IS AN ARBITRATION MATft~R ASSESSMENT OF DAMAGES HEARING NOT REQUIRED TABAS & ROSEN, P.C. BY: LEWIS C. TRAI~i~¥ER, ESQUIRE Attorney for Plaintiff Attorney I.D. 04287 1845 Walnut Street, 22nd Floor Philadelphia, PA 19103 (21~ S69-S0S0 THOMAS JEp~t~RSON UNIVERSITY HOSPITAL : IN TI-IE COURT OF COMMON PLEAS The Curtis Center, 9th Floor : OF CUMBERLAND COUNTY, PENNA. 170 South Independence Square West : vs. : CIVIL ACTION : RICHARD KARSLAKE and : MARIANNE KARSLAKE, h/w : 1901 Cooper Circle : Camp Hill, PA 17011 : COMPLAINT - CIVIL ACTION NOTIC~ Youlmve becn suedin corot ffyou wish todefondn?i-nt the claims set forth in the following pages, yo~ must take ectinn within twenty (20) days al~ this ~mmplaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the com~ your defenses or objections to ~ claims set fm~h *gni-st you. You are warned that ifyo~ fail to do so the cese may preoned without you ond a judgmont may be ontewd a~ainst yon by the conrt without fuflher notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may Ioue nm~ey or in ot,erty or othor d~hts important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, DO TO OR TELEPHONE THE OFFICE SET FORTH BF. EOW TO FIND OUT WHERE YOU CAN OET LEGAL 14~t .P. Cumberland Cueaty Bar Association 2 Liben~ Avenue Carlisle, PA 17013 (717) 249-3166 COMPLAINT - CIVIL ACTION THOMAS JEFFERSON UNIVERSITY HOSPITAL VSo RICHARD KARSLAKE 1. Plaintiff is a non-profit corporation located at the address indicated in the caption hereof. 2. Count I defendant is an individual who resides at the address indicated in the caption hereof. 3. As the result of a certain medical condition, Count I defendant was treated at the plaintiff hospital from November 16 through November 21, 1998. 4. The amounts, quantities and nature of the medical care rendered, the date on which said medical care was rendered, and the charges therefore are set forth in Exhibit 'A*, which is incorporated herein as if set forth at length. 5. Said medical care was commensurate with the condition of Count I defendant and was necessary for the health and welfare of Count I defendant. 6. At or about the time of Count I defendant's treatment at the plaintiff hospital, implied, consffuctive and oral contracts arose between Count I defendant and plaintiff by the terms of which Count I defendant became obligated to pay plaintiff the charges incurred for the medical care rendered by plaintiff to Count I defendant. 7. Count I defendant refuses to pay the balance due although plaintiff has made demand that Count I defendant do so. Tiffs CORRESPONDENCE IS BEING USED IN CONNECTION WITH TI~ COl J-ECTION OF A DEBT ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE 8. As a result of the foregoing, there is due and owing from Count I defendant to plaintiff the sum indicated in Exhibit "A". WHEREFORE, plaintiff demands judgment against Count I defendant for the sum of $34,658.86 plus six percent (6%) interest per annum from the date of discharge to the date of judgment, record costs and non-record costs. COUNT H THOMAS JEFFERSON UNIVERSITY HOSPITAL ¥5. 9. The foregoing paragraphs are incorporated herein as if set forth at length. 10. Count II defendant is an individual who resides at the address indicated in the caption hereof. 11. At ail times material hereto, Count II defendant was the spouse of Count I defendant. 12. Count I defendant is indigent. 13. Count II defendant is financially able to pay for the medical care of Count I defendant. 14. By virtue of the marital relationship, the Act of 1937, June 24, P.L. 2045, Sec. as amended, 62 Pa. Cons. Stat. Ann. Sec. 1973 and Article 1, Sec. 28 of the Pennsylvania Constitution and ail other applicable statutes, laws and ordinances, Count II defendant has a duty to support Count I defendant. 15. Count II defendant has been unjustly enriched by plaintiff's diseharge of Count II CORRESPONDENCE IS BEING USED IN CONNECTION WITH THE COLLECTION OF A DEBT ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE defendant'a duty to aupport Count I defendant, which duty Count II defendant failed to perform. 16. Count II defendant refuses to pay the balance due, although plaintiff has made demand that Count I1 defendant do so. 17. As a result of the foregoing, there is due and owing from Count II defendant to plaintiff the sum indicated in Exhibit "A'. WHF. REFORE, plaintiff demands judgment against Count II defendant for the sum of $34,658.86 plus six percent (6%) interest per annum from the date of discharge to the date of judgment, record costs and non-record costs. TABAS & ROSEN, P.C. BY: Attorney for Plaintiff CORRESPONDENCE IS BEING USED IN CONNECTION WITH THE COLLE~Ji'iON OF A DEBT ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE Patient ~K}12265386148 -- Pntient Nnme: Karslake, Richard VERIFICATION BEVERLEY KELTER, hereby states that she is the representative of plaintiff, THOMAS ~EFFERSON UNIVERSITY HOSPITAL, in this action and verifies that the statements made in the foregoing Complaint - Civil Action are t~ue and correct to the best of her knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Tm~q CORRESPONDENCE IS BEING USED IN CONNECTION WITH -rna COI]~ECTION OF A DEBT ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE TABAS & ROSEN, P.C. BY: LEWIS C. TRAUFFER, ESQUIRE I.D. #60267 22nd F1.,1845 Walnut Street Philadelphia, PA 19103 (215)569-5050 Attorney for Plaintiff THOMAS JEFFERSON UNIVERSITY HOSPITAL : COURT OF COMMON PLEAS The Curtis Center, 9th Floor 170 South Independence Square West Philadelphia, PA 19106 : CUMBERLAND COUNTY VS : RICHARD F4%RSLAKE : NO. 01-3319 Civil Term MARIANNE KARSLAKE, h/w 1901 Cooper Circle Camp Hill, PA 17011 : P RAE C I P E TO T~{E PROTHONOTARY: Please reinstate the attached Complaint and serve the defendants, Richard Karslake and Marianne Karslake, h/w, by certified mail. 'FER, ESQUIRE Attorney for Plaintiff SHERIFF'S RETURN - U.S. CERTIFIED MAIL cASE NO: 2001-03319 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND THOMAS JEFFERSON UNIVERSITY VS. KARSLAKE RICHARD ET AL R. Thomas Kline , Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,KARSLAKE RICHARD by United States Certified Mail postage prepaid, on the 3rd day of July ,2001 at 0000:00 HOURS, at 14 COOKMANAVE CHAUTAQUA, NY 14722 , a true and attested copy of the attached COMPLAINT & NOTICE Together with The returned receipt card was signed by ILLEGIBLE on 07/06/2001 Additional Comments: Sheriff's Costs: So answe~. ...-~-~ .---u,~ Docketing 18.00 ~~~ Service 9.30 Thomas Kline Not Found 5.00 Sheriff of Cumberland County Surcharge 10.00 Cert Mail 5.66 47.96 Paid by TABAS & ROSEN on 07/11/2001 Sworn and subscrik~ad .to before me this. __~/~___ day of ~t~ ~ A.D. / Prot tfo~ot az~ TABAS & ROSEN, P.C. BY: LEWIS C. TRAUFFER, ESQUIRE I.D. NO. 60267 1845 Walnut St., 22nd Fl. Philadelphia, PA 19103 (215)569-5050 Attorney for Plaintiff THOMAS JEFFERSON UNIVERSITY HOSPITAL : COURT OF COMMON PLEAS The Curtis Center, 9th Floor 170 South Independence Square West Philadelphia, PA 19106 : CUMBERLAND COUNTY No. 01-3319 Civil Term VS RICHARD KARSLAKE & MARIA/NNE KARSLAKE, h/w 1901 Cooper Circle Camp Hill, PA 17011 P RAE C I P E TO THE PROTHONOTARY: Please mark the above matter settled, discontinued and ended. ~RE Attorney for Plaintiff · Complete items 1.2. and 3. Also complete A. Received by ~Waese P#nt C. ma6y) e of Dalwe~/ Item 4 If Restricted Delivery is desired. · Print your name and address on the reverse · Attach this cord to the back of the rnallpisoe, or on the front if space pe~nits. · O. isdallv~yaddre~sdiffenmtfmmiteml? r'lyes 1. Article .Addr~ to: if YES, enter delivery mddm~ below: [] NO Richard Karslake (Tnautat~c,a, NY 1 '~ 3. Service Type ~ Cen'ffied Mall [] Exl~e~ Mall [] Registered [] Retum Nocmpt for Me~h~m~ae [] Insured Mall [] C.O.D. 2. Nticle Numbe~ ~,opy from se~,/ce/abe0 7099 3220 0009 1573 3006 01-3319 civil PS Form 3811, July 1999 Oomeafic Return Receipt 102r~S'O0'M'0~2. Sender: Please print your name, address, and ZIP+4 in thl'~.~:(ox CUMBERLAND COUNTY SHERIFF'S DEPARTMENT ONE COURTHOUSE SQUARE CARLISLE PA 17013 h,lllh,,llh,,,,,Ih,lh,,Ih,,Ih,,hh,lhhh,hh,hl,,I