HomeMy WebLinkAbout97-01165
I
I
I
\
~
...
\I
~
~
~
u
~
-l
-
~
" II')
... \I
,.., \
.., "-
~ ~
~
~
. '" "'"
~"'i-
~ -
'II
'it \J
'-J~
.
""
,
\
\
I
{'
~
~
:--..
,
.:)
..
'-.J
\.-,
~
::::::
./
to--'
~
~
I' \1-IU~'N)"TA.t"ll.I.'II(ISI'rr^I.llCll'\~1I ('(1\1 I La_n!I.
('rrw.J II:U'<<loll":or",
Itnutd O\tkl.", 10 W \\ ^'"
\O.t~U '!VII
CARLISLE HOSPITAL AND
HEALTH SERVICES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
CIVIL ACTION - LAW
NO,cn-/l/P~ CIVIL TERM -1997
GLENN E, HOCKENBERRY,
Defendant
JURY TRIAL DEMANDED
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 tiling 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 Plaintiffs, 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:
Court Administrator
Fourth Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
Telephone (717) 240-6200
Attorneys for Plaintiff
Date: March 6, 1997
COUNT I
BREACH OF CONTRACT FOR PROVIDING NECESSARY CARE
6, Plaintiff hereby incorporates by reference the averments contained in paragraphs 1
through 5 of this Complaint.
7, Defendant has breached an expressed or implied agreement to pay the reasonable
value of the services rendered,
WHEREFORE, Plaintiff demands judgment against the Defendant in the amount of
$10,914,12 plus pre-judgment and post-judgment interest and costs,
COUNT II
OIJANTIJM MERIJIT
8, Plaintiff hereby incorporates by reference the averments contained in paragraphs 1
through 7 of this Complaint.
9, The Defendant is liable to the Plaintiff and/or has been unjustly enriched in the
amount of$IO,914,12 plus pre-judgment and post-judgment interest and costs,
WHEREFORE, Plaintiff demands judgment against the Defendant in the amount of
$10,914,12 plus pre-judgment and post-judgment interest and costs,
MARTSON, DEARDORFF, WILLIAMS & OTTO
By
Geor
LO, 49813
Ten ast High Street
Carlisle, PA 17013-3093
(717) 243-3341
Attorneys for Plaintiff
Date; March 6. 1997