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Home My WebLink About00-00171 " ~ "~~...-~. .' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA COMFORT CARE OF HOLY SPIRIT, INC. NO. ,;;?6tJ-/71 a.cd Plaintiff vs. CIVIL ACTION - IN LAW JOHNNY O. FARROW and JULlANNA S. FARROW, Individually and Jointly, Husband and Wife, Defendants 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 is served, by entering a written appearance, personally of by attorney, and filing in waiting 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 document, or for any other claim or relief requested by he Plaintiff. You may lose money or property or other right 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICIA Le han demandado a used en la corte. Si used quaere defensas de esas demandas expuestas en las paginas, siguientes, used tiene viente (20) dias de plazo al partir de la fecha de lademanda y la notifiation. Used debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones a last demandas en contra de su persona. Sea avisado que si used no se defienda, la corte tomara medidas y psedido entrar una orden contra used sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Used puede perder dinero 0 sus propiedades 0 otros derechos importantes para used. LLEVE EST A DEMANDA A UN ABODOAGO IMMEDIA T AMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFFICIENTE DE PAGAR TAL SERVICIO VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRlT A ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR ASSIT ANCIA LEGAL. Court Administrator Cumberland County Court House 1 COUIt House Square, 4th Floor Carlisle, Pennsylvania 17013 (717) 240-6200 . IN THE COURT OF COMMON PLEAS YaIa< COUNTY, PENNSYLVANIA COMFORT CARE OF HOLY SPIRIT, INC. NO. ;2 {)'1nJ. 1'71 ~ ~ Plaintiff vs. CIVIL ACTION - IN LAW JOHNNY O. FARROW and JULlANNA S. FARROW, Individually and Jointly, Husband and Wife, Defendants COMPLAINT AND NOW, this ~ day of j(lht1O-VLJ:-, 2000, comes the Plaintiff, Comfort Care of Holy Spirit, Inc., by and through its attorneys, Wolfson & Associates, P.C, and files the within Complaint and in support avers as follows: 1. Plaintiff, Comfort Care of Holy Spirit, Inc., is a health care provider qualified to conduct business in the Commonwealth of Pennsylvania with offices and/or a place of business situate at P.O. Box 309, Camp Hill, Cumberland County, Pennsylvania. 2. Defendants, Johnny O. Farrow and Julianna S. Farrow, (hereinafter referred to as "Defendants"), Husband and Wife, are adult individuals with a last known address of P.O. Box 146, 561 Fishing Creek Road, New Cumberland, Cumberland County, Pennsylvania 1 7070. 3. On or about March, 1998 through August, 1998, Defendant, Julianna S. Farrow, was a patient of Comfort Care of Holy Spirit, Inc. where she did receive various necessary medical services and treatment by Plaintiff. Julianna S. Farrow is the wife of Defendant, Johnny O. Farrow. " . ',y" 4. In that the Defendants, Johnny O. Farrow and Julianna S. Farrow, incurred the debt as part of the marital estate. An itemization of said services is attached hereto, incorporated herein and collectively marked as Exhibit" A". 5. The prices charged for the services to Defendants were the fair and reasonable and prices the Defendants agreed to pay. 6. Plaintiff has submitted to Defendants copies of the statement of account accurately showing all debits and credits for transactions with Plaintiff. 7. Defendants have not objected to any of the monthly statements of account submitted by Plaintiff to Defendants. 8. As of November 3D, 1999, the balance due, owing and unpaid on Defendants' account as a result of said charges made by Defendant, Julianna S. Farrow, is Six Thousand Eight Hundred Seventy-eight and 96/100 Dollars ($6,878.96). See Exhibit "A". 9. Defendants have not been making timely payments towards this charge account and Defendants have not made a payment since August, 1 999. 10. Despite Plaintiff's reasonable and repeated demands for payment, Defendants have failed, refused and continue to refuse to pay all sums due and owing on Defendants's account balance, all to the damage of Plaintiff. 11 . Pursuant to the terms and conditions of the Medical Contract, Plaintiff is entitled to receive and Defendants agreed to pay reasonable attorney's fees in an amount not to exceed thirty (30%) ofthe outstanding balance in addition to all court and 2 , I~",' '~ collection costs in the event the account was placed for collection with an attorney. See Exhibit liB". 12. . Plaintiff has retained the services of the law firm of Wolfson & Associates, P.C, in the collection of the amounts due from Defendants. 13. As of the filing of this Complaint, Plaintiff has incurred reasonable attorneys fees from the law office of Wolfson & Associates, P .C, in the collection ofthe amounts due and owing by Defendants incident to the within action, and Plaintiff shall continue to incur such attorney's fees throughout the conclusion of the proceedings. 14. Plaintiff has incurred reasonable attorney fees in the amount of One Thousand Seven Hundred Thirty-two and 24/100 Dollars ($1,732.24). 15. Any and all conditions precedent to the bringing of this action have been performed by Plaintiff. 16. The amount in controversy is within the jurisdiction amount requiring compulsory arbitration. 3 - ~I '"""' ",L~~ ';.'_. WHEREFORE, Plaintiff, Comfort Care of Holy Spirit, Inc., respectfully requests this Honorable Court enter judgment in favor of Plaintiff and against Defendants, Johnny O. Farrow and Julianna S. Farrows, Individually and Jointly, Husband and Wife, in the amount of Six Thousand Eight Hundred Seventy-eight and 96/100 Dollars ($6,878.96), plus reasonable attorney fees in the amount of One Thousand Seven Hundred Thirty-two and 24/100 Dollars ($1,732.24), plus interest, the costs of this action and such other relief as the Court deems proper and just. Respectfully Submitted, ~~~- Daniel F. Wolfson, Esquire WOLFSON & ASSOCIATES, P.c. 267 East Market Street York, PA 17403 (717) 846-1252 I.D.No.20617 Attorney for Plaintiff 4 I ~ ~iIi!::-. VERI FICA TION I, Linda Thoman, Director of Business Operations for Comfort Care of Holy Spirit, Inc., verify that the statements made in the foregoing Complaint are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: /i'S/2WO . x:,~. X ;tf2" Linda Thoman '.~ ~I J~ - ' - .c, EXHIBIT 1/ A" "-' PAGE 1 PHN (717) 975-5526 COMFORT CARE POBOX 309 CAMP HILL PA 01 8860 04/27/99 17001,-0309 JULIANNA S FARROW FARROW JOHNNY PO BOX 146 NEW CUMBERLAND PA 232465952 031 17070 BC 60V/90 DAY 04/01/98 BALANCE 1,475.38 ************* NO NEW BILLINGS ***************************** TOTAL DUE FROM PATIENT 1,475.38 IF YOU HAVE ANY QUESTIONS PLEASE CALL 975-5526 18/IIlIII WIIISINTWlT8fJ6111CTIDN 1'"'8#2 .00 1,475.38 1,475.38 .00 .00 'J.'- - ~-"- PAGE 1 PHN (717) 975-5526 COMFORT CARE POBOX 309 CAMP HILL PA 01 9523 03/31/99 17001-0309 JULIANNA S FARROW FARROW JOHNIE PO BOX 146 561 FISHINGCRK NEW CUMBERLAND PA 17070 232465952 031 CBC MAJ MED 60V/90DA 06/01/98 BALANCE 1,990.58 07/01/98 BALANCE 1,000.00 08/01/98 BALANCE 1,403.00 ************* NO NEW BILLINGS ***************************** TOTAL DUE FROM PATIENT 4,393.58 PLEASE CALL 975-5526 IF YOU HAVE ANY BILLING QUESTIONS THIS BILL WAS SENT WITH A COLLECTION LETTER ATTACHED .00 4,393.58 4,393,5B .00 .00 ~.,--- .' PAGE 1 PHN (717) 975-5526 COMFORT CARE POBOX 309 CAMP HILL PA 17001-0309 JULIANNA S FARROW FARROW JOHN PO BOX 146 NEW CUMBERLAND PA 17070 CBC 6121V/90 DAY 05/01/98 BALANCE - ~\ ~ 01 9189 03/31/99 232465952 031 395.00 ************* NO NEW BILLINGS ***************************** TOTAL DUE FROM PATIENT 395.00 PLEASE CAL~ 975-5526 IF YOU HAVE ANY BILLING QUESTIONS THIS BILL WAS SENT WITH A COLLECTION LETTER ATTACHED ,0121 .00 .1210 395,00 395.00 ......, " "" I PAGE 1 PHN (717) 975-5526 COMFORT CARE POBOX 309 CAMP HILL PA 01 8176 03/31/99 17001-0309 JULIANNA S FARROW FARROW JOHNNIE POBOX 146 NEW CUMBERLAND PA 232465952 031 17070 CBC-60V/90 DAY 03/01/98 BALANCE 665.00 *****~******* NO NEW BILLINGS ***************************** TOTAL DUE FROM PATIENT 665.00 PLEASE CALL 975-5526 IF YOU HAVE ANY BILLING QUESTIONS THIS BILL WAS SENT WITH A COLLECTION LETTER ATTACHED. ,00 665.00 665.00 .00 ,00 '.'iJii'. .e ~' - - .-.,:~' , EXHIBIT "B" - . ~ ~ ,. ~ 12/09/1999 11:45 7179757554 COMFORT CARE PAGE. 03.. Cail)~~\\T~ A BIQMCICltHCI.YSfIIUT JtIAI.1HII'IIIM CONSBm:' FOR BOMB BBAIIl'H SBRV1:CBS I have been declared eligible to receive home health services from Comfort Care of HOly Spirit, Inc. and I desire to receive these services. I have been advised that as a patient, I have the right to choose the home health agency that shall be responsible fOr prov;l.ding home health services to me. r un~erstand that the agency I choose will follow the orders given to them by 1l\Y physieian. I hereby authorize the staff of Comfort Care of Holy Spirit, Inc.. to carry out all procedures as ordered by my physician. I understand that Comfort Care of Ho1y Spirit, :Inc. has specific policies re1a.ting to the care which will be given to. me. I further understand that these policies include termination of service at 1l\Y request, the request of my physician or by decision of the Agency. I have had the opportunity to aslt questions about the eare and procedu.res my physic:lom has ordered and agree to abide by the agency's policies 1n all respects. . I have received a copy Of the Patient's Sill of Rights and an explanation of its contents and. have had the opportunity to ask questions. I have received information concerning' where to call to report concerns and the patient hot-line number. ;r understand that Comfort Care of Holy Spirit, :Inc. does not deny services or discriminate based on race, color, religion, national origin, age, sex, or physical disability. I agree to take reasonable efforts to ensure the safety of the home health agency personnel while they are in my home and will restrain and contain animals during a home visit. I agree to abide by the above eonditions. upon the parties hereto, their respective successors and assigns. This agreement shall be binding heirs, executors, administrators, .u.~ S of Patient or Legal Guardian ~~~ ttJ U Witness s- 13"--? r n.te 5--1 a-- 9 ~ Date Revised. 5/96, 4/97 sa FOflMIJ CClHS-17(51117) ," -- 12/09/1999 11:45 71 79757554 COMFORT CARE . PAGE:, 02.' Authorization for AssignmentofB..:nefits; (~~~~J ~ J ~ ^SM\\ltaOPMOLYSl'llUiliEl\l:I}J~ I, \),\..1 trN!"A K). authorize and request my insurartce company to pay Comfurt Care of Patient's Hoty Spirit, Inc. benefits which may be due me for home health services and/or private duty care provided for the patient listed above. A phCllQS tic copy of this a~thorization shall be effective, lUld valid as the original, until revoked by me in wriling. , , V.e.k...J 41\1il~&' ' Ignllture of S 'ller Date Authorlziltion to Release InfonnatlOIl: r authorize Comfort Care of Holy Spirit. Inc. to release information in my medical record to the insurance tompBIlj' or agency Qcsignated below for services rtlldered by COInfort Care of Holy Spiril, Inc. to the patient referred to in this authorl:tatiOll. Also, I authorize the release of medical and other related inftmnation to sociallhealth care agencies and medical eqWplnem/supply vendors whose servi= may be required in COlIJlD1ction with the services provlded by ComfOrt Care afHoly Spirit, Inc. and regulatory or acaediati(lfi surveyorn. I. Medicare Patients: I am llWW'e that as of % of the (Date) costs for my service will be paid by Medicare. Claim Number 2. Medical Assistance:: I am aware that as of % afthe costs for my L3. (DAte) service will be: paid by the Medicaid. I am aWiIle that if I flt!l to apply for Medical Assistance, I will be held res,pOIl.i1:de for aU ""penses inCUr<<d during my treatmenl. Blue Cross Patients: I am aWlll'e that as Of~ If)O % of the; costS for my ~ce (Oato) will be paid by Blue Cross. I Wlderstand llIat In the event Major Medical should become Involved, I will be rC$potlsible fur any and all deductibles as well as tile 20"10 co-payment as prescribed by Blue Cross. Patients with other InS\Il'1lnce or other health care ~gelprivate duty patients; I9nl aware that as of % of the Costs _4. (Date) for my services will be: pa.id by . I \Wd,erstand that I will be: responsible for any deduclible and My balance tell: unpaid by my insurance company. I have checked above the appropriate paragraph indicating my inSUl'llllee or other source ofhealth care coverage. r understand that Comfbn Care of Holy Spirit, Inc. will make rellsonable cfi'orts 10 collect the amOlu1l. due from my insurance provid.cr before billing the patient. 1 also un4erstBIl4 that In the evmt of aIIY changes in my Insurance or other health care: coverage, or any change of the In_ee provider, I will be responslble fOl' noti1Yin1l Comfort Care Of aoly Spirit, Ine:. I Wlderstand that accounts which remain W1paid after thirty (30) days will be: In defltult and will incur a charge of one percent (1%) per month on the W1paid balance or the legal Interest rate, whichever is lower. I agree 10 pay default charges tcigetb with any collection costS ~ed. I X . ; ~ . "'- . (/~....J -1lllt ttk' lient or Lega Guardian ..;/1 vI ite Date 09/96 Rfiidl197 FORM. CCIHS.l 8(5197) "" " - . ~~ ~':-' 12/09/1999 11:45 7179757554 COMFORT CARE PAGE. 0,\' Authorization fur Assignm,mt ofBcnefilS: (lUiJCOMRJRTCARE ~HOME' Hi{LTH SERVICES A S!KVIC! Cfl' HOLY S1'Dm' HI!.\ml SYSnI.t I, j u I, 0. n nO t=l.i 11'( /AJ . authorlZ(: and request my insurance I100lpany to pay Comfort Care of :Patient', Namo Holy Spirit, Inc. benefits which may be: due me fur hQlDe health scn:ices and/or private duty care provid.\XI for the patient U~ above. A photostatic copy of/his authorization shaH be eftC<:tive, and valid as the original, until revoked by me in wrIting. /l, -j".- . c" '1::::(-);" d~,J &-PO-1'4 // Signature of Subscriber Date Authorization io ~lllase l"nfonnation: I amhorize ComfOrt Care of Ho]y Spirit, Inc. to release inform.atio.o in my medical record ttI the insurance <:ompany or agtncy designated below for services rendere(l by Comfurt Ca.c of Holy Spirit, Inc. to the patient referred to in this authorization. Ai$O, I amhorlze the release of mcd.ical and other related information to SOf;lal!beaJth care agencies and medica] equipment/supply vendors whose services may be req.ili<:d in conjunctJ<m with the setvi.:es provided by Comfort Care of Holy Spirit, Inc. ana. regulatory or accredlatJon surveyors. 1, Medicare PatienlS' I am sWll1'ethat as of ~ (Dalo] costs for my service will be paid by Medicare, Claim Number roo %ofthe fL47 :),U;';' M:> 4 2. Medical A~istance; I am aWlU'e that as of % of the com fur my ,,/' 3. (Dote) service will be paid by the Medicaid:. . I am aware that if I full to apply fur Medical Assistance, I will be held responsible for all expenses incurred during my treatmellt. Blue Cross Patients: I am aware that as of j ...UJ....C7 f) . WU % of the costs for my service (Dolo) will be paid by Blue Cross. I understand that In the evenl Major Medical should become involved, I will be responsible for any and all deduetibles as well as the 20% co-payment as presm'bed by :Blue Cross. Patients with other insurance or other h.:alth care coverage/private duty patients; I am aware that lIS of % of the costs 4. (IlalB) for my services will be paid by . I uuderslaDd that I will be responsible for any deductible and any balance 1(;11 unpaid by my insuran\:e company. I have checlccdabove the appropriate paragraph indicatlnljl my insurance or other source ofheallb care coverase. I undaslarul that Comfort Care of Ho]y Spirit, IIlc. will make reasonable eft'ons ttI collect the amounts due from my insurance provider before billing the patient. I also understand tbalin the event of any cha.nses in my insurance or other bea]1h care coverage, or any change of the insurance provider, I will be resp<)t\$lble for n.otitYins Comfbrt Care of Holy Spirit, Inc. I 1.UIderstand \hat accounts which remain unpaid after thirty (30) days will be in default and win incur a charlie of OIIe ~cent (1%) pel' tllonth on the unpaid balance or the legal Interesl rate, whichever is lower. r agree 10 pay default <:barges I ether with any c:ol\ll.Clion costs incurred. , J~J<J -J]atme of Patient or UZdi-fV ~Ilt ~ Witness S{gnature <1, Zo-;?) OMe Ir'U/Ie) Dale 09196 R<rris<d 319? FORM#CCJHs..1B(5191) ~~.lIlIlIi/!liiiJ;,j1lii0ll!Mlf<lli,;;jBiII'll!-"'1iI<i&!~W&/;;i~''''''',,"~.l!'",,"Il--W,'I''S''J~h~_'_.ch..AOIW ~'"' ~'~', ~"~""'r .,,', ~"-,'~~~. -~~ ~" ~ ." ~~"iiIIiliIliII ~ ~ ~ ~~ ~~ ~ ~~ ~ ~ \ \\j () Cl 0 \ c 0 -" ~ s:: <- ~.i. ~ \\ "'O,OJ :> ~i f11 f!1~ :;r; :z:.....~ =':~t9 CN 6jC ;dE; <::) tr ~ ,...lU ~tJ -V =;1 -ri ~O ::ll: ~26 :;;:2 ~ (~j rT1 ~-l Z :::> ~~.. :<! _0 0) -< " .j ~~~ _I" ~ SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2000-00171 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COMFORT CARE OF HOLY SPIRIT IN VS FARROW JOHNNY 0 ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: FARROW JOHNNY 0 but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania, to serve the within COMPLAINT & NOTICE On February 15th, 2000 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing Out of County Surcharge DEP. YORK CO 18.00 9.00 10.00 37.75 .00 74.75 02/15/2000 WOLFSON & ASSOCIATES s~~~ R. Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this .21{ <e: day of :J.J,..,,, __ 'j e2o-v-u A.D. CI"/''-- ~o~~y ~ ' ~_... ~ " ...~ ;;jf~ SHERIFF'S RETURN OUT OF COUNTY CASE NO: 2000-00171 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COMFORT CARE OF HOLY SPIRIT IN VS FARROW JOHNNY 0 ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: FARROW JULIANNA S but waS unable to locate Her in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania, to serve the within COMPLAINT & NOTICE On February 15th, 2000 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 02/15/2000 WOLFSON & ASSOCIATES R Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this J,lS~ day of 1.vt.... "1 .2.DIJV A. D . ()r~ Q Iv,. ,i-oJ I JJp4 ) Prothonotary "'"'[Ji " ~ ~,~~~ "1_ _I~_~- - 1r -".... -1 couwty.d1I; YORK OFFICE OF THE SHERIFF (1 of 2) SERVICE CALL (717) 771-9601 28 EAST MARKET ST., YORK, PA 17401 SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN 2.COURTNUMBER 2000-171 4. TYPE OF WRIT OR COMPLAINT Notice & Complaint Civil 1. PLAINTIFF/Sf Comfort Care of 01 3. DEFENDANT/51 Johnny 0, Farrow, et. al. S.ERVE { 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD. Serve: Johnny O. Farrow 6. ADDRESS (STREn OR RFD WITH BOX NUMBER, APT NO., CITY, BORO, TWP., STATE AND ZIP CODE AT 561 Fishing Creek Road, New Cumberland, PA 17070 7. INDICATE SERVICE: [J PERSONAL [J PERSON IN CHARGE )Q DEPUTIZE C':lImffi!;I!'!:lf#fi>rl NOW 1 / 11 / 2 000 19 _I, SHERIFF OFmDl'lK cOUN York COUNTY to execute t to law. This deputation being made at the request and risk 01 the plaintiff. 8. SPECIAL INSTRUCTIONS OR OTHER INfORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: S irit Inc NTY "'-. --,' I --... f11 l-'" CumbeNa"'" ,-, ,.: (f1 ~~ ....", OUT of County 2'" "" . Advance fee pd by Cumberland Co Sheriff -D :3 ""'0 '-, ~ 3-',~ "':', . ."'~O i !--l- I',) C') ',.. NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN. Any deputy sheriff levying upon or attaching any property JnCier withi!1 writ may t~ave same without a watchman, in custody of whonlever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or tl:1e sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriffs sale thereof. 9. TYPE NAME AND ADDRESS of ATTORNSY/ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER 11. DATE FILED Daniel F WOlfson, ESq 267 E Market ST York Pa 17403 717-846-1252 1-10-00 12. SEND NOTICE OF SERVICE COpy TO NAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed). Cumberland Co SHeriff ~ SIGNATURE OF AUTHORIZED CLERK T Kohr 1-25-00 16. HOW SERVED: PERSONA RESIDENC POSTED ( ) POEt ) SHERIFF'S OFF ( ) OTHER( ) SEE REMARKS 23. Advance Costs $75.00 10th 41. AFFIRMED and subscribe,d, to before me tl1is _,~r<\:..-," -'" _ . 00 44. Signature of De . Sheriff 45. Signature of York County Sheriff 48. Date 42. day of 43. William M. Hose, Sherif 46. Signature of Foreign MY COMM SSION EXPlRES~ , Coun Sheriff 50.1 ACKNOWLEDGE RECEIPT OF THESH~RIFF'S RETURN SIGNATURE OF AUTHORIZEO ISSUING AUTHORITY AND TilLE 1. WHITE - Issuing Authority 2. PINK. Attorney 3. CANARY ~ Sheriffs Office 4. BLUE ~ Sheriff's Office 2/10/00 49. Date 51. Date Received ~ ,I .J, .,- - "!".'" ~ liIlli>...~...~~'"'~;_~ ~I_~ .', .... ; 1lilfI~'<'" ~ ." k~"_ I<lo ~, , '" . COUNT'fOF YORK OFFICE OF rrt SHERIFF (2 of 2) SERVICE CALL (717) 771-9601 28 EAST MARKET ST., YORK, PA 17401 Comfort Care of Hol 3. DEFENDANT/Sf Johnny o. Farrow, et. al. S.E.RVE { 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD. Julianna S, Farrow 6. ADDRESS (STREET OR RFD WITH BOX NUMBER, APT NO., CITY, BORO, TWP., STATE AND ZIP CODE AT 561 Fishin Creek Road New Cumberland PA 17070 7. INDICATE SERVICE: 0 PERSONAL 0 PERSON IN CHARGE JI1l OEPUTIZE C Ul!l f: AlP 01 ST CLASS MAIL 0 POSTED 0 OTHER NOW 1/11/2000 19 _I, SHERIFF OF ~OUNTY, p,t'.....;:> ~by depUliZ-';. riff of York COUNTYtoexecutet. ~t . c'r 'ng to law. This deputation being made at the request and risk of the plaintiff. . SHERIFF OF OUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: S irit, Inc. 2. COURT NUMBER 4. TYPE OF WRIT OR COMPLAINT SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN ,. PLAIN1IFF/Sf Notice & Complaint Cumberland OUt of County NOTE ONLY APPLlCABL.E ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriff's sale thereof. 9. TYPE NAME AND ADDRESS of ATTORNEY/ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER 11. DATE FILED 1-10-00 Daniel F Wolf$on esq 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed). Cumberland Co Sheriff 13. r acknowledge receipt of the writ T Kohr or complaint as indicateKl above. 14. Date Received POEt ) 1-25-00 SHERIFF'S OFF ( ) 2-9-00 16. HOW SERVED: PERSONAL ( ) POSTED ( ) OTHER ( ) SEE REMARKS (See remarks below.) 19. Date of Service 20. Time of Service .;;;/ A i Time' Miles, Int. i ' SO ANSWER. 41. AFFIRMED and s.ubscrib'ed,t9' before..me this 42. day of 43. Sheriff 2/10/00 49. Date 51. Date Received 4. BLUE - Sheriff's Office .' l ~:;: .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVil DIVISION COMFORT CARE OF HOLY SPIRIT, INC., Plaintiff vs. NO. 2000-00171 JOHNNY O. FARROW and JULlANNA S. FARROW, Individually and Jointly, Husband and Wife, Defendants NOTICE OF ORDER, DECREE OR JUDGMENT TO: ( ) PLAiNTIFF (X) DEFENDANT(S) ( ) GARNISHEE ( ) ADDITIONAL DEFENDANT YOU ARE HEREBY NOTIFIED THAT THE FOLLOWING O~p~R"DEGRE-c O.R}lJ~.GMENrHAS . BEEN ENTERED AGAINST YOU ON IN ACCORDANCE WITH THE PROVISIONS OF PA.R.C.P. 236 ( ) DECREE NISI IN EQUITY ( ) FINAL DECREE IN EQUITY (X) JUDGMENT OF () CONFESSION (X) DEFAULT ( ) NON-PROS ( ) VERDICT ( ) NON-SUIT ( ) ARBITRATION AWARD (X) JUDGMENT IS IN THE AMOUNT OF $ 8,602.20 PLUS COSTS. $ 136.25 FOR A TOTAL OF $ 8,738.45 ( ) DISTRICT JUSTICE TRANSCRIPT OF JUDGMENT IN CIVIL ACTION IN THE AMOUNT OF $ PLUS COSTS. ( ) IF NOT SATISFIED WITHIN SIXTY (60) DAYS, YOUR MOTOR VEHICLE OPERATOR'S LICENSE WILL BE SUSPENDED BY THE PENNSYLVANIA DEPARTMENT OF TRANSPORTATION ~THONOTARY~ BY Is / :/J -:/;-~ ~ /). , IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: ~ /J. C;/oo TELEPHONE NUMBER: WOLFSON & ASSOCIATES, P.C. 267 EAST MARKET STREET YORK,PENNSYLVANIA 17403 (717) 846-1252 OR 800-321-8467 NAME OF (ATTORNEY/FILING PARTY): ADDRESS: . , ~. . ~" ! ~ ' [': . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMFORT CARE OF HOLY SPIRIT, INC. No. 2000-00171 vs. Action in: Civil-Law JOHNNY O. & JULlANNA S. FARROW 561 FISHING CREEK ROAD NEW CUMBERLAND, PA 17070 ENTER JUDGMENT in the above case for failure to file, enter, an ANSWER TO THE COMPLAINT against JOHNNY O. & JULlANNA S. FARROW in favor of COMFORT CARE OF HOLY SPIRIT, INC. in the sum of ~8,738.45 with interest AS ALLOWED BY STATUTE Total: .$8,738.45 Attorney for Plaintiff Daniel F. Wolfson, Esquire f7 ~~ ;J 9 ' 20 On Judgment entered by the Prothonotary this day according to the tenor of the above statement. 1$//J~-h)72~ Vr thonotary "-..~.... - [0,..; . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMFORT CARE OF HOLY SPIRIT, INC., Plaintiff NO. 2000-00171 v. JOHNNY O. & FARROW and JULlANNA S. FARROW Individually and Jointly, Husband and Wife, Defendants CIVil ACTION-LAW CERTIFICATION 1/ Daniel F. Wolfson, Esquire, due hereby certify that on February 29/ 2000/ I caused a true and correct copy of the 10 Day Notice attached hereto to be served on the Defendants, Johnny O. & Julianna S. Farrow. Date: 3/J-Y! m Daniel F. Wolfson, Esquire WOLFSON & ASSOCIATES, P.c. 267 East Market Street York, Pennsylvania 17403 Telephone No. (717) 846-1252 1.0. # 20617 Attorney for Plaintiff ~ ~ ,~ .J;. '''''"" . WOLFSON & ASSOCIATES, P.C. Attorneys at Law ATIORNEYS Daniel F. Wolfson Michael J. Connor Gerard J. Foulke 267 East Market Street York, Pennsylvania 17403 COUNSEL Morrison B. Williams Jodi Trout Bingaman (717) 846-1252 (800) 321-8467 FAX (717) 848-1146 PARALEGALS Angela S. Eaton Margaret L. Burg Susan K. Kostalas e-mail: dfwolfson@debtcollection.net February 29/2000 Johnny O. & )ulianna S. Farrow 561 Fishing Creek Road New Cumberland, PA 17070 Re: Comfort Care of Holy Spirit, Inc. v. Johnny O. & Julianna S. farrow Docket No. 2000-00171 (CP Cumberland County) Collection Matter Dear Mr. Farrow & Mrs. Farrow: , ~""' ~ it' BRANCH OFFICES: Center Square East Berlin, PA 17316 (717) 259-0713 8 Manchester Street Glen Rock, PA 17327 (717) 235-5014 PLEASE FORWARD ALL CORRESPONDENCE TO THE YORK OFFICE We enclose a 1 O-Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Sincerely, WOLFSON & ASSOCIATES, P.c. ~~~ Daniel F. Wolfson, Esquire DFW\ts enclosure ~- ' ".' ~, '\ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMFORT CARE OF HOLY SPIRIT, INC., Plaintiff NO. 2000-00171 vs. JOHNNY O. & JULlANNA S. FARROW, Defendants CIVIL ACTION - LAW TO: Johnny O. & Julianna S. Farrow 561 Fishing Creek Road New Cumberland, PA 17070 DATE OF NOTICE: FEBRUARY 29/2000 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU FAILED TO TAKE THE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (1 0) DAYS FROM THE DATE OF THIS NOTICE, A)UDGMENT 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. I' l' I~! Ij i I' i: Ii j-i Ii Court Administrator Cumberland County Court House 1 Court House Square/4th Floor Carlisle, Pennsylvania 17013 (717) 240-6200 By:A-~~ Daniel F. Wolfson/Esquire WOLFSON & ASSOCIATES, P.c. 267 East Market Street York, Pennsylvania 17403-2000 Telephone: (717) 846-1252 I.D. # 20617 Attorney for Plaintiff ._..._...~ ~~1lI _- ""~d~~Hl,.j."" , ~'. -.-............. ~.~-- (') 0 C C' 0 <' ~ -'It C ~ ~ ..IQ. l'Jij:""' -,-... ----I nirTi )~ Z:J~ :-~:) ,;". ~ ...0 ze- N . 0):-" '.0 :':';~j () ::$ ., !:-O '-11 fI" 'S 5>' V ~.:::.~ () ~ 0 ;';':2:J r zO ..... 6f~ --0 13 - Pc ~) f' j ~ ~ Z -=-.;! ~ w :0 tJ' ,n -< ~ $ r--- ~ \" . . . ~ " , "" '~j ..~ PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 to 3149 COMFORT CARE OF, HOLY SPIRIT, INC. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. JUDGMENT NO. 2000171 JOHNNY O. FARROW an JULlANNA S. FARROW, Individually and Jointly, Husband and Wife, Defendant( s) PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) To the Prothonotary: Issue writ of execution in the above matter, (1) Directed to the Sheriff OfCUMBE& County, Pennsylvania; (2) against, JOHNNY O. FARROW and JULlANNA S. FARROW, 561 FISHiNG CREEK, LEWISBERRY, PA 17339-9509 Defendant(s); (3) and against, WA YPOINT BANK, 449 Eisenhower Boulevard, Harrisburg, PA 17111 Garnishee(s); (4) and index this writ (a) against, JOHNNY O. FARROW and JULlANNA S. FARROW, Defendant(s) and (b) against, WAYPOINT BANK, Garnishee(s), as a lis pendens against the real property of the Defendant(s).in the name of the Garnishee(s) as follows: (Specifically describe property) . "'ADDRESS'" 561 FISHING CREEK, LEWISBERRY PA 17339-9509 All personal property of any nature located within the household or immediate vicinity of the defendant(s) address and all other personal property within the dominion and control of the defendant( s) wherever it is located shall be subject to the levy. Also: You are directed to attach the property of the Defendant(s) not levied upon in the possession of" WAYPOINT BANK 449 Eisenhower Boulevard Harrisburg, PA 17111, Garnishee(s) All accounts including but not limited to all savings, checking and other accounts, certificates of deposit, notes receivables, collateral, pledges, documents of title, securities, coupons and safe deposit boxes. Amount due $ 8.738.45 Interest from March 29, 2000 At an interest rate of 6% per year To Be Determined Total $ 8 738.45 Dated October 9. 2003 ;- ~........ "'-IIliiIIi""'~- .~~- ~ - p ~ ~ ~ ~ ~ ~ ~ W D ~-o fb-o i- t - E f ~~'ii...._ , ~~"_. ~ ~.t~ ~",,,,,,,,,,,,,,,;j- " ~'"-'iIH- - >. rt ~~'''l' ~ ~ '-'~' f: ~~~F ~~ ~ "~ ~l~ .~ vr~~ 8 ~lrt " Clto - ~ 0 0 , B~ ~~ I I I ... , , I "- "- ... ... , ;::8 ::: , :!:t: . ... , "- - ... '"" ... "-.<- - - - ----..- >1_ .... c) (') -n C ~ 0 -0 ~~D C~ -l\ '. ",,-{ r III " . ~".'.::::.!, i~i' .__ ,/,',-- c,"" _ r_',',,; ~~:2 ~~~ . _ _.~ -~ :e- _'__ (_) i~ '~~:'11 :;J m -< t F :0 fi; :~ f ..r--J-d ()'" )- r- r ~ ~ 0.' (\ Q~ t.~ V ~~ F- lY' (k.. " - ~" '-.... , -," WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 00-171 Civil CIVIL ACTION - LAW TO THE SHERIFF OF ,YORK. COUNTY: To satisfy the debt, interest and costs due COMFORT CARE OF HOLY SPIRIT, INC., Plaintiff (s) From JOHNNY O. FARROW AND JULIANNA S. FARROW, 561 FISHING CREEK, LEWISBERRY, P A 17339-9509 (I) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY OF ANY NATURE LOCATED WITIDN THE HOUSEHOLD OR IMMEDIATE VICINITY OF THE DEFENDANT(S) ADDRESS AND ALL OTHER PERSONAL PROPERTY WITHIN THE DOMINION AND CONTROL OF THE DEFENDANT(S) WHEREVER IT IS LOCATED SHALL BE SUBJECT TO THE LEVY . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of W AYPOINT BANK, 449 EISENHOWER BOULEVARD, HARRISBURG, P A 17111 - ALL ACCOUNTS INCLUDING BUT NOT LIMITED TO ALL SAVINGS, CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL, PLEDGES, DOCUMENTS OF TITLE, SECURITIES, COUPONS AND SAFE DEPOSIT BOXES GARNISHEE(S) as follows: " f1 :<1 ~:i I and to notify the garni~hee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. J !I I i , I ! ';1 I i I I " iii !I I ,I ':1 Amount Due $8,738.45 L.L. $.50 Interest FROM 3/29/00 AT AN INTEREST RATE OF 6% PER YEAR Arty's Corum % Arty Paid $163,25 Plaintiff Paid Date: OCTOBER 16, 2003 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) prothon~ [! ~ . ~ n....... IJ . 'YlAJ"r, r-- Deputy REQUESTING PARTY: Name AMY F. WOLFSON, ESQUIRE Address: 267 E. MARKET STREET YORK, PA 17043 Attorney for: PLAINtIFF Telephone 717-846-1252 Supreme Court ID No, 87062 - " " - -1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Comfort Care of Holy Spirit, Inc. Plaintiff NO. 2000-171 vs. CIVIL ACTION - LAW Johnny O. Farrow and Julianna S. Farrow: Individually and Jointly, Husband and Wife Defendants PRAECIPE TO V ACA TE JUDGMENT TO THE PROTHONOTARY: Kindly vaGue the Judgment entered pursuant to the above captioned matter, Respectfully submitted, _~ji!lillltll__""bi!iI_~I!;....~;.&:l;,-i/f"",l&"";'''';h11'''''-''''.Md*w-.f>. --~ ~ ~~~- ....~ "-,~.... ,-~,~ ~R'iD ~. &$.' .'.. u-:- C '. .~ -- " ~. ~~ ____._1liIlIIilIIlIiI . "''' 0 "'" () = C = ~'n ;'~:'~ .r:- ---\ '''On:! ~:n ::1:-.... rTi(n c: l"nf-i Z:-i:.: GJ 2:r:. "urn ~~'.~;~; 0"> :&lSJ -C) ~- ~~ ..'IU, -u :L~ :J: ~i;~ r:~ z ~ ~- :J:J 1".' --< I