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Home My WebLink About01-03294 ';;:~ _~ _ ~ I .d _) ~_- , '" :"'J ,-__C':'_ ~ " ~ ~i 'i ~. ~ ~~~~:Ri~~~ , HCR MANOR CARE, \, ) Plaintiff "J ~ " :OMMON PLEAS OF HY, PENNSYLVANIA NO. CI - .&291 CIU'J,-' vs. CIVIL ACTION - LAW JOYCE A. HEFFELBOWER, Individually, and ROBERT HEFFELBOWER, Individually, and on Behalf of JOYCE A. HEFFELBOWER, 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 ia corte en forma esctita sus defensas 0 sus objeciones a last demandas en contta 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 pOt cualquier queja 0 alivio que es pedido en la peticion de demanda. Used puede perder dinero 0 sus propiedades I> otros derechos importantes para used. LLEVE ESTA DEMANDA A UN ABODOAGO IMMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFFICIENTE DE PAGAR TAL SERVICIO VA Y A EN PERSONA 0 LLAME POR TELEFONO A LA OFlCINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSITANCIA LEGAL. '1:<iWyer Referral Service 'Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 1 70 1 3 (717) 249-3166 . j .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HCR MANOR CARE, Plaintiff NO. 0/- 3:2 9'( (5wJ Jp..--.. vs. CIVIL ACTION - LAW JOYCE A. HEFFELBOWER, Individually, and ROBERT HEFFELBOWER, IndMdually, and on Behalf of JOYCE A. HEFFELBOWER, Defendants COMPLAINT AND NOW, this~ day of(YllZ-::; ,2001, comes the Plaintiff, HCR Manor Care, by and throu@ itsa.~rney, Daniel F. Wolfson, Esquire, and the law firm of Wolfson & Associates, P ,c., and files the within Complaint and in support avers as follows: 1. Plaintiff, HCR Manor Care (hereinafter referred to as Plaintiff), is a health care provider qualified. 'to conduct business in the Commonwealth of Pennsylvania with offices and/or a place of business situate at 940 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013, 2. Defendant, Joyce A; Heffelbower, (hereinafter referred to as "Defendant Joyce"), is an adultiridividtial with a last known address of 940 Walnut Bottom Road, Carlisle, Cunibel'l~nd County, Pennsylvania 17013. 3. Defendant, Robert Heffelbower, (hereinafter referred to as "Defendant Robert"), is an adult individualW,ith a last known address of 258 West North Street, Carlisle, Cumberland County;Ptmnsylvania 17013. ; II ", . II -.""" do'l 'l..:c.~ ." ~".;,,'~.~...'~'_"_" .,~,~-, '; .-- 4. That Defendant Robert represented himself to be Power of Attorney for Defendant Joyce. Defendant Robert is the son of Defendant Joyce. 5. That on or about October 18, 1999, through the present, Defendant Joyce was a health care resident of Plaintiff, where she did receive and where she continues to receive various necessary residential health care services and health care treatment by Plaintiff. An it~mization of said services is attached hereto, incorporated herein and collectively marked as ~xhibit "A". 6. That on or about October 18, 1999, Defendant Robert, as Defendant Joyce's Responsible Party, executed an Admission Agreement which Agreement outlined various terms of residential health care services to be provided by Plaintiff and the Responsible Party therefor; A true and correct copy of the Admission Agreement is attached hereto, incorporated herein, and collectively marked as Exhibit "B". 7. By executing said Admission Agreement, Defendant Robert did assume and accept responsibility for the debt tdbeincurred by Defendant Joyce. 8. That Paragraphforir( 4) of the Admission Agreement did describe the various responsibilities of Defendants, which responsibilities did include payment for the daily rate and charges for supplemental services, supplies not paid by any third party, as well as applicable co~insurance and deductibles and all expenses of discharge or transfer. See Exhibit "B". 9 . That Plaintiff submitted to. Defendants a copy of the itemization of services accurately showing all debits and credits for transactions with Plaintiff. Said 2 Ii ,.,;ill!!il.. . r ... .. Statement of Account has been previously identified as Exhibit "A" and incorporated herein by reference. 10. That Defendants did not object to the above mentioned Statement of Account submitted by Plaintiff to Defendants. 1 1. As of May 1, 2001, the balance due, owing and unpaid on Defendant Joyce's account as a result of said charges is the sum of Twenty-Nine Thousand Three Hundred Six and 07/100 Dollars ($29,306.07). See Exhibit "A". 12. Despite Plaintiff's reasonable and repeated demands for payment, Defendants have failed, refused,~nd continues to refuse to pay all sums due and owing on the outstanding account balance, which accrued due to residential health care services provided to Defendant Joyce, all to the damage and detriment of the Plaintiff. 13. Plaintiff has made numerous requests to Defendant Robert, Responsible Party for Defendant]oyce, demanding that the sums due and owing to Plaintiff be paid, and Defendant"Robert, as Responsible Party for Defendant Joyce, has ignored his fiduciary obligation to pay necessary and appropriate bills and obligations for his mother, Defendant JoYce. 14. Plaintiff has retained the services of the law firm of Wolfson & Associates, P .c., in the colledidrt'Of tI1eamounts due from Defendants. 15. As of the filing of this Complaint, Plaintiff has incurred reasonable attorney's fees from the law officE! of Wolfson & Associates, P .c., in the collection of 3 II " II , .. '"' ",,'\ 4 II , . '" WHEREFORE, Plaintiff, HCR Manor Care, respectfully requests this Honorable Court enter judgment in favor of Plaintiff and against Defendants, Joyce A. Heffelbower, Individually and Robert Heffelbower, Individually and on Behalf of Joyce A. Heffelbower, in the amount of Twenty-Nine Thousand Three Hundred Six and 07/1 00 Dollars ($29)3.06.07l,reasonable attorney's fees in the amount of Eight Thousand Seven Hundred Ninety-One and 82/1 00 Dollars ($8,791.82), the costs of this action, and such other relief as the Court deems proper and just. Respectfully Submitted, Daniel F. Wolfson, Esquire WOLFSON & ASSOClAT' S, P.c. 267 East Market Street York, PA 17403 (717) 846-1252 I.D. No. 20617 Attorney for Plaintiff 5 " I il -,j~ ,"- .. ~ ,. ..".l~.~ . _- , ~,;'l , a EXHIBIT "A" ~ ., " , ,,'--~-'- ,. ~-. "'-~Li(' '~'t: HCR.ManorCare Statement .-j . MANORCARE CARLISLE 372 940 WALNUT BOTTOM ROAD CARLISLE, PA 17013 (717)-249-0085 ROBERT HEFFELBOWER FOR JOYCE HEFFELBOWER 258 W. NORTH STREET APT 2 CARLISLE, PA 17013 t1EDICAID PRIVATE ROOr.1 119 -A Please Return This Portion With Your Payment HEFFlEBOWER, JOYCE A I' 99116 01/26/00 01/31/01 J CHARGES I 28,976.27 CATEOF I ~ SERVICE ; CODE \ SERVICE RENDERED 01/01/01 BALANCE FORWARD -.---- 01/01/01 11900 MCB PREMIUM ( QTY 02/01/01 ADV PVT PORTION 08/31/00 ADJ RVS COINS 8-00 09/30/00 ADJ RVS COINS 9-00 10/31/00 ADJ RVS COINS 10-00 CREDITS 1- ) 50.00 515.32 48.98 48.98 37.56 PAYMENT DUE BY THE 10TH OF THE MONTH 1'/ / '" ,/ r / , 29,306.07 AMOUNT DUE - L~ ili:i; t. (' 4'. .. ,.......... '.' .....;ADMISSI(9ti.I.:)A.SaE,sllllEil.:la;;.{........%......"..'... ..,ii;'.')'; CONTRACT BE'fWEEN:~PA1fitI~iilltf~flIiiNiPJ:ANb liACt'lrr~ ~ ManorCare Health Services THIS ADMISSION AGREEMENT (the "Agreement") is entered into this day of ..-ct::-.1'l1~ ,between MANORCARE HEALTH SERVICES (t~L:'~a~!i}y'''), and Jo~ce./tt. f/~JPOwef(the "Patient/Resident"), and/or ,JZoIOert-' ~1Ul;7 (the" esponsible Party"), As used herein, the term "Patient/Resident" shall also mean the Responsible Party, if any. The parties agree as follows: 1. Commencement. This Agreement shall begin on the date of admission of the Patient/Resident to the Facility. 2. Termination of Agreement, Discharge and Transfer. a. Termination by Patient/Resident. The Patient/Resident may terminate this Agreement by giving the Facility at least five (5) days advance written notice. The Patient/Resident is responsible for payment of all charges for five (5) days after notice is given, or until the Patient/Resident actually leaves the Facility, whichever is last. If the Patient/Resident leaves the Facility (i) before the attending physician discharges the Patient/Resident, or (ii) against medical advice, the Patient/Resident and Responsible Party agree to assume all responsibility for injury or harm to the Patient/Resident, and hereby release the Facility, its employees and agents, from all liability connected with such departure. b. Termination by Facility. The Facility may terminate this Agreement and discharge the Pat- ient/Resident upon at least thirty (30) days prior written notice if (1) the Patient/Resident's needs cannot be met; (2) the Patient/Resident presents a danger to the health or safety of other indivi- duals; (3) the Patient/Resident fails to pay charges for supplies or services after notice; (4) the Patient/Resident's health has improved sufficiently so that the PatientlResident no longer needs the services provided; or (5) the Facility ceases to operate. However, the Patient/Resident may be transferred or discharged upon less than thirty (30) days notice if: (1) an immediate transfer or discharge is required due to the Patient/Resident's medical needs; (2) the Patient/Resident presents a threat to the health and safety of individuals in the Facility; or (3) the Patient/Resident .has not resided in the Facility for thirty (30) days. Such notice shall be given as soon as practical. The Patient/Resident acknowledges receipt from the Facility of materials as to the Patient/Resident's right to appeal a discharge decision with State authorities and the appeals process. If this Agreement is terminated and/or the Patient/ Resident is discharged by the Facility, the Responsible Party agrees to accept custody of the Patient/Resident upon discharge and cooperate with the Facility to facilitate the Patient/Resident's discharge. 3. Responsible Party. The Patient/Resident shall execute Exhibit A regarding Responsible Party appointment. 4. Fees & Payments. The Patient/Resident is responsible for, and shall pay, the daily rate and charges for supplemental services and supplies not paid by any third party as described in the Fee Schedule, attached as Exhibit S, as well as applicable co-insurance and deductible amounts and all expenses of discharge or transfer. 5. Release of Information. The Patient/Resident hereby authorizes all persons and/or entities to release all or any part of his/her medical/health records to the Facility. The Patient/Resident also authorizes the release of records or information to any health care institution to which the Patient/ Resident may be transferred, any provider involved in the care of the Patient/Resident, any third party payor, including, but not limited to, government and private insurers, or any other person entitled or authorized to receive such information by law or by the Patient/Resident. MHc.ooa.20 (Rev. 7/96) pg 3 1 of 3 ,1 " .. ,:,~,.., -~" , ."7. 6. Consent to Treatment. Patient/Reslde!"!t s;cknowledges that he/she is under the medical treat- ment and, care of an attending physician, and consents to the Facility rendering nursing care therapeutic, and other treatment under the general or special instructions of said physician or i . case of emergency. r ( 7. Attending Physician. The Patient/Resident is solely responsible for selection of a licensee attending physician. The Patient/Resident agrees that the Facility may require the Patient/Resident to utilize another physician if the attending physician (1) has his/her own professional license limited. suspended or revoked; (2) fails to follow the Facility's rules and regulations; or (3) is unavailable ir case of emergency. The Patient/Resident is responsible for all charges for physician services. 8. Pharmacy. The Patient/Resident shall execute the Pharmacy Agreement attached as Exhibit C 9. Independent Contractors. The Patient/Resident acknowledges and agrees that all physicians dentists and barbers/beauticians, including those whose services are arranged by the Facility, are independent contractors and are not employees or agents of the Facility, and the Facility shall no: be responsible for their acts or omissions or for the consequences of following physician or centis: orders. 10. Private Duty Personnel. The Patient/Resident acknowledges that all private duty personnel the' the Patient/Resident utilizes are not employees or agents of the Facility and that the Facility is nc: liable for acts or omissions by such personnel. Employees of the Facility may not be employed e~ private duty personnel at the Facility. All private duty personnel shall comply with all policies an:: procedures of the Facility as may be amended from time to time without notice. Failure te co sc may result in their being denied access to the Facility. Patient/Resident and Responsible Party she be solely responsible for the cost of private duty personnel. \ 11. Facility Guidelines for "No Heroics" Requests. Decisions regarding life support sr,ould be COf.. sidered by each Patient/Resident or his/her authorized surrogate decision-maker. The Pet;ent; Resident acknowledges receipt of rights under state law to make decisions about mecical care, in- cluding rights to accept or refuse care and rights to make an advance decision abcut care. The Patient/ Resident acknowledges receipt of a summary of the "Facility Guidelines for No Heroic~ Requests" (the "Guidelines"). A full text of the Guidelines will be provided upon request. In part, thE Guidelines provide that the Facility will not withhold or withdraw life-sustaining or life-prolongin~ measures from a Patient/Resident without a written and legally sufjioient authorization of a competen: Patient! Resident or legally authorized surrogate decision-maker and a physician order. The Patien!; Resident agrees to comply with the Guidelines. 12. liability and Indemnification. The Patient/Resident understands that the Facility is liable ani;. for injuries caused by the negligent acts. or omissions of the Facility and as required by law. ThE Patient/Resident shall indemnify and hold the Facility harmless from any and all claims, suits anc actions made against the Facility by any person resulting from any damage or injury caused by thE Patient/Resident to any person ~r the property of any person or entity (including the Facility). 13. Patient/Resident's Handbook. The Patient/Resident acknowledges receipt of the Facility'" Resident's Handbook and agrees to comply with such Rules and Regulations contained therein. ThE Patient/Resident acknowledges and agrees that he/she shall be responsible for and shall hold thE Facility harmless for any injuries or damages which are caused by the Patient/Resident's failure te comply with such rules and regulations. The polioies, procedures, rules and regulations regardlO~ the following areas, among others, are detailed in the Resident's Handbook: VHC-OCM..;tQ \ReY.4/961 O<'J 4 2013 I " .- . Federal Resident Rights . .. .. . Resident Responsibilities . Life Sustaining Treatment Policy . Medical/Nursing Education . Dental, Vision and Hearing Services . Interdisciplinary Care Conference . Utilization Review Meetings (if applicable) . Personal Laundry Policy ,--~ L_ ", ^ '''. /, Ili:j@.}' . Barber/Beauty Services . Mail Policy . Voting Materials . Photo/Media Events . Personal Fund Account Procedure . Tobacco Policy . Grievance Procedures . State Resident Rights (if applicable) 14. GOVERNING LAW. THIS AGREEMENT SHALL BE GOVERNED AND CONSTRUED IN ACCORDANCE WITH THE LAWS AND REGULATIONS OF THE STATE WHERE THE FACILITY IS LOCATED. TO THE EXTENT ANY PROVISION HEREOF CONFLICTS WITH STATE LAW, STATE LAW SHALL CONTROL. THE STATE LAW ADDENDUM ATTACHED HERETO AS EXHIBIT D SETS FORTH ANY DELETIONS FROM OR ADDITIONS TO, THIS AGREEMENT REQUIRED BY STATE LAW, WHICH AMENDMENTS SHALL BE A PART OF THIS AGREEMENT. 15. Miscellaneous. The provisions of this Agreement shall bind the parties, their respective executors, administrators, heirs, beneficiaries, and assigns. The waiver by either party of any breach or default of this Agreement shall not operate as a waiver of any subsequent breach or default. The provisions ofthis Agreement shall be severable and the invalidity or unenforceability of any provision shall not affect the validity or enforceability of any other provision. This Agreement and all Exhibits are the entire agreement and any changes shall be in writing and signed by both parties. IN WITNESS WHEREOF, the parties hereto have executed this AdmiSS;njAgreement as and year above written. Dj Responsible Party - Signature Re~~1:: !t~~J;Mer- 10 -{ 5('-- 99 Date Date i MHC_008_20 (Rev. 4/96) pg 5 3 of 3 -,;lW ~, --';-'~'-""~i~ .- .) EXHIBIT "B" t >;\JM<Jr,:l,I;"U.".H,'-'iIJrdfi:ilid.,_, 2""--5 tp d-~)," d;k";'.l~'-<'.'".' : ,.~~, " '&,"\L'~''''F"c;;~';;A-:'. . ~,,--_.~~~- ",.,,","!"--'- .!I~i'JinJjiSif' .,j.;ag -~'Ml~9~l~ ~ ~W81~1 _,.-'_.A!'i_.",;,.[<%"t-\1:$ffi:~, t . ~ It- ~~ ~ -6Q.. ~ !: ~~ ~ '- ~ 8 8 ..... ~ ..... I I ~ ~ ~1 ~~ ..".., o C <::= ."CJ ~. J ' [Pl.:.: -;",'" ~). ~:~ ~-, ~,. .< =< I:;'~ :;ti' ~. (') j, --..... (..') (=, ~ "'1j -; (f) '" -< -r~' ;:,--, r~- C:'J ~ ~, -', " -"'~''''';h' -~ - . 0<'" -.. -':~_, . . SHERIFF'S RETURN - REGULAR .., . I CASE NO: 2001-03294 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HCR MANOR CARE VS HEFFELBOWER JOYCE A ETAL BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HEFFELBOWER JOyCE A the DEFENDANT , at 1005:00 HOURS, on the 4th day of June , 2001 at 940 WALNUT BOTTOM RD CARLISLE, PA 17013 by handing to JOYCE A HEFFELBOWER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.10 .00 10.00 .00 31. 10 r~~ R. Thomas Kline me this / ~#. day of 06/28/2001 WOLFSON & ASS/,7'~ES d By: ~J?1. Deputy Sheriff Sworn and Subscribed to before A.D. ....-............ ~- ~~ .~ .,. ~ . " 0.' .~ ~ 111'"---" c,'_ -;1>, of . SHERIFF'S RETURN - REGULAR r t . CASE NO: 2001-03294 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HCR MANOR CARE VS HEFFELBOWER JOYCE A ETAL CPL TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HEFFELBOWER ROBERT IND AND ON BEHALF OF JOYCE A HEFFELBOWER the DEFENDANT , at 1951:00 HOURS, on the 27th day of June 2001 at 258 W NORTH ST CARLISLE, PA 17013 by handing to ROBERT HEFFELBOWER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 3.10 .00 10.00 .00 19.10 So Answers: ~~~ot:~ R. Thomas Kline day of 06/28/2001 WOLFS::: & ;;:~~~~/ /0/. ./~~;fy ~herifl' Sworn and Subscribed to before A.D. " , , ~ ~ ~ 4 . ,. ......' ~ c. '<' i. ~. -.,' ~"'=/ It:!i IN THE COURT OF C0MJ\10N PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA HCR MANOR CARE, Plaintiff vs. : NO. 01-3294 JOYCE A. HEFFELBOWER, Individually, and ROBERT HEFFELBOWER, Individually and on behalf of JOYCE A. HEFFELBOWER, Defendants CNIL ACTION - LAW DEFENDANT ROBERT HEFFELBOWER'S PRELIMINARY OBJECTIONS AND NOW comes the Defendant, Robert Heffelbower, Individually and on behalf of Joyce A. Heffelbower, pro se, and preliminarily object to Plaintiffs Complaint, as follows: Motion to Strike 1. Pa. R.C.P. 1028(a)(2) permits a Motion to Strike pleadings which do not comply with law or rule of Court. 2. Pa. R.C.P. 1019(a) states that the material facts on which a cause of action is based shall be stated in a concise and summary form. 3. Pa. R.C.P. 1019(f) states that averments of time and place shall be specifically stated. 4. Pa. R.C.P. 1019(i) requires that when any claim is based upon a writing, a copy of that writing shall be attached. 5. Plaintiff did not itemize the services it allegedly performed or state the times and , - ~' -. "~.~ ~ .&.IU'::'I:>" t places that the services were allegedly performed in its Complaint, in violation of Rules 1019(a) and 1019(1). 6. Plaintiff alleges in its Complaint that the Admission Agreement specifies that Defendants are responsible for paying certain fees and/or charges, but no such writing is attached to Plaintiffs Complaint, in violation ofPa. R.C.P. lOl9(i). 7. Plaintiff alleges in its Complaint that a document exists which exposes Defendant Robert Heffelbower to liability for the amount sought, but no such writing is attached to Plaintiffs Complaint, in violation ofPa. R.C.P. lOl9(i). 8. Plaintiff alleges in its Complaint that a document exists which exposes Defendants to liability for Plaintiff s attorneys fees, but no such writing is attached to Plaintiff s Complaint, in violation ofPa. R.C.P. lOl9(i). WHEREFORE, Defendant Robert Heffelbower requests that this Court strike Plaintiffs' Complaint. Motion for a More Specific Pleading 9. The allegations set forth in Paragraphs 1 through 8, above, are incorporated herein by reference as though fully set forth. 10. Pa. R.C.P. 1028(a)(3) permits a motion for a more specific pleading. 11. In the alternative, in the event that this Court does not Strike Plaintiff s Complaint, Plaintiff should be required to amend its Complaint to state specifically which services were allegedly performed and when and where they were allegedly performed, to state specifically which fees and charges Defendants are allegedly liable to pay, to state specifically the basis for the alleged liability of Defendant Robert Heffelbower, and to state specifically the ~-~ ,~.~ r.1 ~. ,~' ':l' ' ,~ '" "0'-';,; basis for Plaintiff s claim for attorneys fees so that Defendant has sufficient information to prepare a defense of this matter. WHEREFORE, Defendant Robert Heffelbower requests that this Court direct Plaintiff to amend its Complaint to state specifically which services were allegedly performed and when and where they were allegedly performed, to state specifically which fees and charges Defendants are allegedly liable to pay, to state specifically the basis for the alleged liability of Defendant Robert Heffelbower, and to state specifically the basis for Plaintiff's claim for attorneys fees. Motion to Dismiss 12. The allegations set forth in Paragraphs 1 through 11, above, are incorporated herein by reference as though fully set forth. 13. Pa. R.C.P. I028(a)(4) permits a preliminary objection forlegal insufficiency of a pleading. 14. The Statute of Frauds requires that a writing is required in order to hold one liable for the alleged debt of another. Plaintiff has not produced any writing in which Defendant Robert Heffelbower agreed to be financially responsible for any alleged debt of Defendant Joyce Heffelbower. 15. Plaintiff has not alleged that any services were performed for or on behalf of Defendant Robert Heffelbower. 16. Plaintiff has stated no basis for the alleged liability of Defendant Robert Heffelbower. 17. Under Pennsylvania law, one cannot be held responsible for the alleged debt of .. L". ,"-.L"-_Lh '"'...._~'., j another, except by written agreement. 18. Plaintiffs Complaint against Defendant Robert Heffelbower should be dismissed because Plaintiff has alleged no basis for Defendant Robert Heffelbower's alleged liability. 19. Under PelIDsylvania law, each party must bear its own attorneys fees absent some statutory authority or agreement. 20. Plaintiff has not attached a copy of any agreement to its Complaint which would provide a basis for its claim for attorneys fees against the Defendants. 21. Plaintiff has not alleged any statutory or contractual basis for its claim for attorneys fees against the Defendants. 22. Plaintiffs claim for attorneys fees against Defendants should be dismissed because Plaintiff has alleged no basis for Defendants' alleged liability for Plaintiffs attorneys fees. WHEREFORE, Defendant Robert Heffelbower requests that this Court dismiss Plaintiffs Complaint in its entirety or, alternatively, in part with respect to Plaintiffs request for attorneys fees. pt--1l. Robert Heffelbower, Defi 258 West North Street Carlisle, P A 17013 Telephone: (717) 258-1660 Dated: .4'1,;<1- 3, ~&o J / ' . .. . , . ~, ~~- :,-"" ,,' -..., ',,' : ,~~ , ~- 'I'''~--'''''',; , - -~ . ,,""., . CERTIFICATE OF SERVICE 1.1/ If .I. A~lJS+ ~hereby certify that on the3d day of~ 2001 copies of the foregoing Preliminary Objections were served upon the following by United States First Class mail, postage prepaid, addressed as follows: Daniel F.Wo1fson, Esquire WOLFSON & ASSOCIATES, P.C. 267 East Market Street York,PA17403 ~ Robert Heffe1bower, Defi 258 West North Street Carlisle, P A 17013 Telephone: (717) 258-1660 . _;,I/j~n1",,;J;L'1;l~l;~~,,""':"bl1:";l''''i';, ,U1iol'f,i!'H:;:t:"^p;:",,,-',');,-.:.,~,h,,,,-.'.h:,j".tly,:,, ','j;~~-,W, ~'":;!!i'~"'-'bz"~,,,,''';iiik;h:\l.j;g;~~.~.II_irll4lfiaI'IlIillIllillf!'i!lf ~.., ~ ~ -'"'^-~' .<, ~ ~ _ , ~','~ ,~,">,,"~~~ ,~. ~.,~,~ ~.' _ ,r. _,...,."" ""_~ _ _~ __~, ., ,.. -" - ~"'," ~ "' - , ;,;~ 0 CO 0 C -11 g: ~ " -OeD (;) ;';i{':::- rnm Z:r 1 '~'J!,'~ Zr- ;::-:~~';:~j cn:Cc <...' -<''''-:-'- ':;20 -u ~~~ -0- ~: 2:0 tjfTi :5>2- ry --; ~ N J+; C" ~ '-,^ 'D_"'"' ""~~". ~ '" _.' ~, -"-,", ;""_:;'';','_''''0 -"-"''''-''''-.'''l:.o,;'",'~c"",--'7-- '0:'--"1", r . HCR MANOR CARE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVILACTION-LAW OI-~9Lf ~'vl1 v. JOYCE A. HEFFLEBOWER, Individually, and on behaf of JOYCE A. HEFFLEBOWER, Defendants PRELIMINARY OBJECTIONS AND NOW, comes Joyce A. Hefflebower and pursuant to Rule 1028 of the Pennsylvania Rules of Civil Procedure offers the following Preliminary Objections: 1. Plaintiffs Complaint fails to comply with Rule 1028(a)(2) insomuch as it demands arbitration. 2. Rules 1301 et seq. of the Pennsylvania Rules of Civil Procedure govern arbitration generally. 3. The rules of arbitration allow the local jurisdiction wide latitude in creating administrative and procedural rules thereunder and in setting the jurisdictional limit for compulsory arbitration. 4. Cumberland County Rule of Procedure 1301-1 et seq. provides for compulsory arbitration when the amount in controversy is less than $25,000. 5. The Cumberland County Rules of Procedure do not create any apparatus to voluntarily submit a case to arbitration or to demand arbitration if the amount in controversy is in excess of $25,000. 6. Plaintiff, in its prayer for relief, asks for $38,097.89 as liquidated damages. -----", .^~ ~ -'<""- __c_,'<.___ - -" "',,,~ <_'_~, _-_._~_-_.",.'~, ,,,~_';O-~.;,,,;";'J _>--,,_. -...~~ r , 7. The Plaintiff has improperly demanded arbitration and insomuch that Plaintiff has demanded arbitration and the amount in controversy is in excess of $25,000, the Complaint is not in compliance with the Cumberland County Rules of Court as read in conjunction with the Pennsylvania Rules of Civil Procedure. WHEREFORE, Defendants respectfully request that this Court strike Plaintiffs Complaint for failure to substantially conform with the Cumberland County Rules of Court and the pennsylvania Rules of Civil Procedure. Respectfully submitted, - Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Defendants -" _,,,',, -",2 __~" ,-,,,. "'-F;";c'''",~~-",-'''-"l'~",",k-. '-~, -" _ '<L" .- . HCR MANOR CARE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW v. JOYCE A. HEFFLEBOWER, Individually, and on behaf of JOYCE A. HEFFLEBOWER, Defendants CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Defendant, do hereby certify that I this day served a copy of the Preliminary Objections upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Daniel F. Wolfson, Esquire Wolfson & Associates, P.C. 267 East Market Street York, PA 17403 / Dated: /17 2~Lo<P'( / ---Karl E. Rominger, Esquire Attorney for Defendant - --~ i~~~~~' "7( c...-~~ t--1o llJl!LJ"llUJlll~ '~~~.- ~ ~~;iL"';;"'';'';'':;''':'' ." ~"~ II!lJl!l!l M 1" ~'.'__ "'c.," - ""-~""""('''' -.' ce,,, ",,,,",,, '_,^~.' ''''~''_ ~. '_<,..""",, ,,,~'__',,.~, _0"-' '.",,'- ",~~ '.,"Y" ".-"".-- ._~ . "ltil~I" ~." <, --"." ., t 0 0 ~=-) c:: Cl <. p -0 lJj f"1l I '. ::n Z -'i-i Zr r'0- -~ ~~'.. C,:J ~.) (S -, <_l. .-0 .~c "l'j ;.>e; lc._; -n 7.) - is );Q w orn ,- ~ Z )> =< 0:) :n -< . ~ - " . ~ n; L '^ ~. -. - .' !::r"~"""f'+--i .. ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HCR MANOR CARE, Plaintiff NO. 01-3294 vs. CIVIL ACTION - LAW JOYCE A. HEFFELBOWER, Individually, and ROBERT HEFFELBOWER, Individually, and on Behalf of JOYCE A. HEFFELBOWER, Defendants PLAINTIFF'S REOUEST FOR THE PRODUCTION OF DOCUMENTS Pursuant to Pa.R.C.P. No. 4009, the Plaintiff, HCR Manor Care, serves the within Request for the Production and Inspection of Documents on Defendant, Robert Heffelbower, and demands that same respond to this request within thirty (30) days from the date of service hereof. 1. All documents in your possession, control, or custody constituting, relating to, or pertaining to the documents identified in the Interrogatories directed towards Defendant. 2. All documents in your possession, control or custody constituting, relating to, or pertaining to the documents identified in response to Plaintiff's Interrogatories. 3. All documents prepared by Defendant or by a third party representative, agent, or anyone acting on its behalf during an investigation of any 1 , ~ ~ -,- ~ , ~ ' ^ r-~i!wif,l---- "-'::.. aspect of the matter in question. Such documents shall include any documents made or prepared up through the present time, with the exclusion of the mental impressions, conclusions, or opinions respecting the value or merit of a claim or defense, or respecting strategy or tactics. 4. All documents, photographs and tangible evidence you intend to introduce at trial. 5. Any and all correspondence exchanged by and between the parties in litigation. 6. All documents containing the names and addresses of witnesses or potential witnesses. 7. All statements of any person who will be called as a witness at trial. 8. Copies of all exhibits which you intend to offer into evidence at trial of this matter. 9. All correspondence between Plaintiff and Defendant from on or about October t 8, t 999 to the present. to. All statements of account received by Defendant from Plaintiff from on or about October t 8, t 999 to the present. t t. All other documents of whatever kind or description upon which Defendant or Defendant's attorney intends to rely or may rely in establishing any of Defendant's defenses against Plaintiff's claims in this matter. 2 M '" '" =" \ "". ~~!lk4:- 12. All other documents in the file or files of Defendant and Defendant's attorney concerning this action which have not been requested by any of the preceding paragraphs hereof, and which are not expressly exempted from discovery by Pa.R.C.P. No. 4003.3 or No. 4011 (c). 13. The production and inspection of the foregoing is requested at such time and place and in such a manner as shall be agreed upon. NOTE: As referred to herein, "documents" includes written, printed, typed, recorded or graphic matter, however produced or reproduced, including correspondence, telegrams, other written communications, data processing storage units, tapes, contracts, agreements, notes, memoranda, analysis, projections, indices, work papers, studies, reports, surveys, diaries, calendars, films, photographs, diagrams, drawings, minutes of meetings or any other writing, [including copies of the foregoing regardless of whether the parties to whom this request is addressed have the original now in their possession, custody or control] now in the possession, custody or control of Defendant, her former or present counsel, agents, employees, officers, insurers, third party insurers, or any other person acting on her behalf. Respectfully submitted, Daniel F. Wolfson, Esquire WOLFSON & ASSOCIATES, P.c. 267 East Market Street York, PA 17403 (717) 846.1252 I.D. No. 2061 7 Attorney for Plaintiff 3 JOl:!ij .~ ' ,,,L ~lt1f . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HCR MANOR CARE, Plaintiff NO. 01.3294 vs. CIVIL ACTION. LAW JOYCE A. HEFFELBOWER, Individually, and ROBERT HEFFELBOWER, Individually, and on Behalf of JOYCE A. HEFFELBOWER, Defendants CERTIFICATE OF SERVICE AND NOW, thi~ day of October, 2001, I, Daniel F. Wolfson, Esquire, do hereby certify that I have served a copy of the foregoing Request for the Production of Documents upon the parties and/or counsel of record in the following manner and addressed as follows: CERTIFIED MAIL RETURN RECEIPT REOUESTED REGULAR MAIL POSTAGE PRE.PAID Mr. Robert Heffelbower 258 West North Street Carlisle, PA 17013 (Pro Se Defendant) Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PAl 7013 (Counsel for Defendant, Joyce Heffelbower) Daniel F, Wolfson, Esquire WOLFSON & ASSOCIATES, P.c. 267 East Market Street York, PA 17403 (717) 846-1252 ID No. 20617 Attorney for Plaintiff 4 ~~~">ili"J;!!:!'H,{J4I~!fuMWlllii"""~~i0;lc".ii>""";\,'i'\"",,;,-,;';"i;i;<~'l!..!_l!.r,,;iJ'Mil""",,,,J.,g;d~~..hIolMt-JliilffilillEill~~~'U..l ,- s rf .~~I;:~.~ r~,(_~I!,Ll'I!r. ~_,-.",-", JIUI~-:J}_.,lr.J,J!J\ttt:o_~",,~ /_,'i."" ,,,",,,".:;"" '* '".,-"" -'''''''.'''. ""'''',,%.<."..,,,,,.,Y.,_ ~~ ,'-" -.""" ..-,. ,,=-- "";,.,.,,""""lliiiiilJ....--...;. o ,-- ? mal k-',J ~~;~ !:;::C b Z:C' ...........c.. rc "7 ~ ~- -' -~ -~ .~, I: C) C) ~-") ...... i"..J: 0", .'T) _!.:. ~ ,~\ ~T-. -- ::-r, i..~ 6j"\1 ~, -'"~ :D -< ,.) :..i1 01 ~ -. ~ . lV" -" [ -"'illr,llilli1iI;lIrJirttJ:' T -,. , " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HCR MANOR CARE, Plaintiff NO. 01.3294 vs. CIVIL ACTION - LAW JOYCE A. HEFFELBOWER, Individually, and ROBERT HEFFELBOWER, Individually, and on Behalf of JOYCE A. HEFFELBOWER, Defendants PLAINTIFF. HCR MANOR CARE'S INTERROGATORIES DIRECTED TOWARDS DEFENDANT. ROBERT HEFFELBOWER Pursuant to Rule 4005 of the Pennsylvania Rules of Civil Procedure, Plaintiff, HCR Manor Care, serves the within Interrogatories on Defendant, Robert Heffelbower, Individually and on behalf of Joyce A. Heffelbower, and makes demand on Defendant to answer the same under oath within thirty (30) days of the date of service hereof. A. Definitions and Instructions 1. These Interrogatories are considered to be continuing and, therefore, should be modified or supplemented as you obtain further or additional information. 2. Where exact information cannot be furnished, estimated information is to be supplied. Where an estimate is to be used, it should be identified and accompanied by an explanation as to the basis on which the estimate is made and the reason the exact information cannot be furnished. 3. As used herein, "documents" include any written, recorded or graphic matter, however produced or reproduced, including, but not limited to, 1 , ~ -.-,' C,'''' '. -~'- '';'''~''~-~f-!j'-' 0: , '. . correspondence, telegrams, other written communications, contracts, agreements, notes, statements, memoranda, photographs, tape recordings, or any other writings, including copies of the foregoing, now in the possession, custody or control of the Defendant, Defendant's counsel and all persons acting on behalf of said Defendant. 4. Where knowledge, information or documents in the possession of a party is requested, such request includes knowledge, information or documents in the possession of the party's agents, representatives or attorneys. 5. As used herein, "identity" or "identify" used in reference to any individual person means to state their full name and present address, their present employment position or business affiliation, and their telephone number. "Identity" or "identify" when used in reference to a document means to state the date and author, type of document (e.g., letter, memorandum, telegram, chart, etc.) or some other means of identifying the document, and its present location and custodian. It is sufficient to attach a copy of the document for the purpose of answering these interrogatories. 6. When the word "incident" is used in these interrogatories, it is to refer to those occurrences alleged in Plaintiff's Complaint. 7. If any document was, but no longer is, in your possession or subject to your control, state what disposition has been made of it. 2 '~~t~*",~ < . B. Interro2atories 1. Please state your full name, address, age and telephone number. 2. Please describe your present employment and occupations with stating: a. The names and addresses of your employer; b. Your duties and responsibilities; c. The date you started work for your employer; d. The exact weekly, monthly or annual wage or rate of pay being received from your employer. 3 "' ,,-~ - '"'~~~ ".- ~-" <, 'M"a,-l[~_', , . 3. Please identify any statements which you made in any form, whether in writing, tape recording device or otherwise, to any person regarding any of the events or happenings in regard to the present cause of action brought against you. 4. Identify and describe each and every communication between Plaintiff and Defendant regarding the relative obligations of Defendant concerning the hospital stay of Defendant's mother, Defendant Joyce A. Heffelbower. 4 ~ " , ~ '......'" ,-.;. A>'" '.' l"':"!l:@:I[@l":J < <. . 5. Please state the name and address of each person who has acted or will act as an agent for Defendant or Defendant's attorney in preparing material in anticipation of litigation. 6. As to any person named in your answer to Interrogatory No.5, please identify any and all documents, reports, memoranda, notes or summaries from such individual. 5 . , ~~ - -~ ......~"""w--! * * 7. Please provide specific examples of times when the Defendant spoke to Plaintiff where Plaintiff stated to Defendant that Defendant would not be financially responsible for any charges relative to Defendant Joyce A. Heffelbower. In doing so, please provide the names of Plaintiff's employees who were spoken to by the Defendant and the dates on which such conversations took place. 6 ~ - .1 __..">. --'"~-~lb'l . 8. Please provide specific examples of times when the Defendant spoke to Plaintiff where Plaintiff stated to Defendant that Plaintiff would complete any and all third- party applications for all third-party payor programs, including Medicaid. In doing so, please provide the names of Plaintiff's employees who were spoken to by the Defendant and the dates on which such conversations took place. 7 , ''-~~ " - ,,"'.'b''''''''''''',.' , -JiKj~',; 9. Please provide specific examples of times when the Defendant spoke to Plaintiff where Plaintiff stated to Defendant that no monies would be due and owing to Plaintiff in that all charges would be covered by Medicaid. In doing so, please provide the names of Plaintiff's employees who were spoken to by the Defendant and the dates on which such conversations took place. 8 =. J ,-_. l _J .' "'""_!il1l1"X'!:' 1 O. Please provide specific examples of times when the Defendant spoke to Plaintiff where Plaintiff stated to Defendant that after the delivery of a check, in the amount of $3,281.00, that all charges relating to Defendant Joyce Heffelbower's account would be taken care of and that no further charges would accrue. In doing so, please provide the names of Plaintiff's employees who were spoken to by the Defendant and the dates on which such conversations took place. 9 " ~ " " ',~ ~':8'k."~~ ' .' ". V"'>f!L- . , 11. Please specifically state your reasoning for averring that by presenting a check to Plaintiff, on behalf of your mother, Defendant Joyce Heffelbower, in the amount of $3,281.00, you believe that constitutes a novation of any agreement which existed between the parties, where there is no documentation to show that said payment was in full and final satisfaction of the debt and where said payment is only a small percentage of what is currently due and owing on Defendant Joyce Heffelbower's account balance. 10 '""'., I',. " -'-, ,v~ ,;;;; ,,- .~ l;",j1 Wils1!.-:' , " ~i1'-i 12. State the names and addresses of any person, other than Francis Kline, who has had access to Joyce A. Heffelbower's income and/or assets, since the time of her admission to Plaintiff's facility on or about October 18, 1999. 13. State any objections or any defenses, that Defendant plans to put forward during litigation, that Defendant may have for not paying the account balance that has, and continues to be, due and owing to Plaintiff concerning his mother, Defendant Joyce A. Heffelbower's stay with Plaintiff. 1 1 '"_.c,,, _-,lc ';',J'" ~"-:C'-""" ",c ""~~ ~M,' 14. Please state a proposal payment schedule that would be fair and beneficial to both parties in this cause of action, and that you would be able to meet to try to payoff your overdue account balance that has, and continues to be, due and owing to Plaintiff. 15. Please state all actions, etc., that you have taken, in the past year, if any, in furtherance of paying off your overdue balance which is, and will continue to be, due and owing to Plaintiff. If no action has been taken, please explain why there has been none. ~ '_"",~k..,","'I, ~-"",~," _ .,' iI~ "<t'~;:. ,. t: ~. ~ , . 16. Please state the reasons that Defendant Robert Heffelbower believes that he is not responsible for the account balance amassed by Joyce A. Heffelbower when Defendant Robert Heffelbower breached his duty to utilize Joyce A. Heffelbower's income and assets, as set forth in the Admission Application and Admission Agreement, to pay Plaintiff for Joyce A. Heffelbower's care. 1 7. Please identify the names and addresses of any witnesses who you intend to call at trial. Respectfully submitted, aniel F. Wolfson, Esquire WOLFSON & ASSOCIATE, P.c. 267 East Market Street York, PA 17403 (717) 846-1252 I.D. No. 20617 Attorney for Plaintiff M , ~~ ", " , ',,-,,-.,; ~ -.. "''''J;j,(.lc _J/<< . .. -'- , ..... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HCR MANOR CARE, Plaintiff NO. 01-3294 vs. CIVIL ACTION - LAW JOYCE A. HEFFELBOWER, Individually, and ROBERT HEFFELBOWER, Individually, and on Behalf of JOYCE A. HEFFELBOWER, Defendants CERTIFICATE OF SERVICE AND NOW, this d!l~ay of October, 2001, I, Daniel F. Wolfson, Esquire, do hereby certify that I have served a copy of the foregoing Interrogatories upon the parties and/or counsel of record in the following manner and addressed as follows: CERTIFIED MAIL RETURN RECEIPT REOUESTED REGULAR MAIL POSTAGE PRE-PAID Mr. Robert Heffelbower 258 West North Street Carlisle, PA 17013 (Pro Se Defendant) Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PAl 7013 (Counsel for Defendant, Joyce Heffelbower) ?i/~~ Daniel F. Wolfson, Esquire WOLFSON & ASSOCIATES, P.c. 267 East Market Street York, PA 17403 (717) 846-1252 ID No. 20617 Attorney for Plaintiff ~~~i1.iiliii,'~,!',j''<''';;;-;'~')'il'J;.':~''':~~~'1f!i!b-~~!.!WJ'Ah'#,;j,1;Ii!&i;-MB".~_ll{I~: ~ H" w-_illiiItlIi>>Iii~,L" U~~. Z:)" fr ~;JTr~."~n,,,,.'b'_.,,"",,,,"~,, >._ ,""y_>^ ,.~.__^""". ,'-'~",""__~" ""',, ~~"'_' ,~ ,,~, "'..", '''',d'''';'''''' _~'r" '.,- ~. ~~.~ "rl - . C C';J C S ~.:J -o~',!_1 ::::~) rnp', '-~', -r :1..1 "- ;-..) 2: [,. eI) (J) - CJ ~. ~'-r) )> ,~..... c~~ .:.;;:~ - Z. b " 1 );> "..:? C) C :::-r;:-~ ~ 01 ~I <./1 -< - itttr> , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HCR MANOR CARE, Plaintiff NO. 01.3294 vs. CIVIL ACTION . LAW JOYCE A. HEFFELBOWER, Individually, and ROBERT HEFFELBOWER, Individually, and on Behalf of JOYCE A. HEFFELBOWER, Defendants RULE AND NOW, TO WIT, this 2.g'" day of 1"?""1 , 2002, a Rule is issued upon Defendant Robert H. Hefflebower to show cause why the aforementioned Motion should not be granted. RULE RETURNABLE .to days from the date of service hereof. BY THE COURT, :5-;r: Pjf to: RObeRt ~effeLbwe~ .,ettld' . "Ro r;_i~q a. I ft<lp-h"'J .1 Co ~trJ J. ./ Ii ~ _i-'_ ~"- .. ~ ,~,,~ u'~ ~O. ,c_." "~_,~ ^_~,_'~_ .,,'~ - ~',n,..., OF FlU?D.'Oi~f]CA= --;-, Ir' '-'-rRV . :1- .~)IA . U.,., "0" r.,., i "'It.;f C:o e,~i I:?D .nUI';~"':C' ...,- ." "rC\ v vl~Li l~..r", -,L.J --"'_Ail\; 1 ( PENi'\~SYLV/\l\lr.A , ~..~. < "l,<,l",~,'_<''?ff!'~'''''~~!Jli.:t'1~~~~*!','l'i!l(WjF''_", 'ie-_ ';;;"T~' ';"f)-'i" 7'"".':;~' c' nFwF"'-'~'fi'I;if;;'L'I~''';\'''iF~tl,\\,:iT-'ln''~H,7',;'!\'''-'~-,~tf1!'~"'iPt'l'!tl~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HCR MANOR CARE, Plaintiff NO. 01-3294 vs. CIVIL ACTION - LAW JOYCE A. HEFFELBOWER, Individually, and ROBERT HEFFELBOWER, Individually, and on Behalf of JOYCE A. HEFFELBOWER, Defendants ORDER PURSUANT TO Pa.R.C.P. 4019 AND NOW, TO WIT, this day of , 2002, upon consideration of Plaintiff's Motion to Compel Compliance, it is ORDERED and DECREED that: ! i a. The Rule is made absolutej and b. Defendant Robert H. Hefflebower is directed, pursuant, to Pa.R.C.P. 4019, to immediately answer in detail Plaintiff's Interrogatories and Request for Production of Documents in the above-captioned matter within days of the date of this Order. c. Defendant Robert H. Hefflebower be held in Contempt of Court and be required to pay the Plaintiff's reasonable expenses for preparing and presenting this Motion in the amount of $300.00j and, d. Any other relief that the Court may deem necessary and appropriate. BY THE COURT: i 'i !I J. II , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HCR MANOR CARE, Plaintiff NO. 01-3294 vs. CIVIL ACTION - LAW JOYCE A. HEFFELBOWER, Individually, and ROBERT HEFFELBOWER, Individually, and on Behalf of JOYCE A. HEFFELBOWER, Defendants MOTION TO COMPEL COMPLIANCE PURSUANT TO Pa.R.C.P. 4019(aHi) and (vii) AND NOW, TO WIT, this 29th day of April, 2002, comes the Plaintiff, HCR Manor Care, by and through its attorneys, Amy F. Wolfson, Esquire and the law firm of Wolfson & Associates, P .c., and files the within Motion in which the following is a statement: 1. Plaintiff, HCR Manor Care, is a health care provider qualified to conduct business in the Commonwealth of Pennsylvania with offices and/or a place of business situate at 940 Walnut Bottom Road, Carlisle, Cumberland County, I I Pennsylvania 17013. 2. Defendant, Joyce A. Heffelbower, is an adult individual with a last ; known address of 940 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. Defendant, Robert Heffelbower, is an adult individual with a last known address of 258 West North Street, Carlisle, Cumberland County, il .~~, Pennsylvania 17013. 4. On or about October 25, 2001, Plaintiff served the original and one copy of the "Plaintiff's Interrogatories Directed Towards Defendants" and "Plaintiff's Request for the Production of Documents" upon Defendant, Robert H. HeffIebower, by mailing the same to Defendant. S. Plaintiff avers that thirty (30) days have passed since the service of said Interrogatories and Request for Production of Documents and Defendant has failed to answer the same. 6. The discovery requested by the Plaintiff is necessary for the Plaintiff and its counsel to prepare their case for trial. 7. Plaintiff has incurred attorneys fees in pursuit of this Motion. II WHEREFORE, Plaintiff, HCR Manor Care, respectfully requests this Honorable Court to enter the following: a. an Order compelling Defendant Robert H. Hefflebower to comply with Pennsylvania Rule of Civil Procedure 401 9 and immediately respond in detail to the Plaintiff's Interrogatories and Plaintiff's Request for the Production of Documents directed to the Defendant; b. reasonable attorney's fees for the preparation and presentation of this Motion; and c. any other such relief as the Court deems necessary and appropriate. Respectfully submitted, A y F. olfson, ire WOLFSON & AS OCIA TES, P.c. 267 East Market Street York, PA 17403-2000 (717) 846-1252 J.D. No. 87062 Attorney for Plaintiff )1 ;'~"-, ,'I VERIFICATION Amy F. Wolfson, Esquire, hereby states that she is the attorney for the Plaintiff, HCR Manor Care, and she is authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Motion to Compel complaince are true and correct to the best of her knowledge, information, and belief. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: 'i --). 9-- 02 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HCR MANOR CARE, Plaintiff NO. 01.3294 vs. CIVIL ACTION . LAW JOYCE A. HEFFELBOWER, Individually, and ROBERT HEFFELBOWER, Individually, and on Behalf of JOYCE A. HEFFELBOWER, Defendants CERTIFICATE OF SERVICE I, Amy F. Wolfson, Esquire, hereby certify that on the 29th day of April, 2002, I served a copy of the within Motion to Compel Compliance upon the unrepresented Defendant, by first class mail, postage prepaid, addressed as follows: Robert H. Hefflebower 258 West North Street Carlisle, PA 17013 Respectfully submitted, II '~;~~0l'i",'Oii."!""'f&"1",0k'_i:!Y2."'IJh';:~+;;B'''Ii<:'-lif"1;1~1-",*~,;';Jt'i;-,i-,Gt~1'-8<J~i1:oO':,,""iM't'J.""'i:";,>i~ih'i~~.iii~~iMii1~_ilillliiillldl'~"-'''''" E{.p .1.'. ,<<~O_, .~~H,',~_.'"". ", ",~^,,_- ,_~ 'A' 0~.~", ".~. ,_. _~",,~I-, ~ ,-'? -~ ,',"' I:J:a"iJj,i!IlIlt.~..all!:l ~~"? "= ,. 0 CJ ~~ c.: r<, ;;;: _('l.. :~ "'0 rr:- :;:,,~ ;-:g 1'1"1 iT; ..." -; ::---J.I :-:'1 "- t'-,,) m~:: ,-" r......:' ~ ~:~. ~ r. C_ i +;~:' <:: ., .,;.i ~. C) ('5 /~ () '2 n j;~ c: S :.?..: -, ...... ::::> ';$ -< to -< c - -~- "'-- --x-.O",.,~"'",,.-~' ';;:~l-,' "., - PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.RC.P. 3101 to 3149 HCR Manor Care, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. JUDGMENT NO. 01-3294 Joyce A. Heffelbower, Individually, and Robert Heffelbower, Individually, and on Behalf of Joyce A. Heffelbower, Defendant PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) To the Prothonotary: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of Cumberland County, Pennsylvania; (2) against, Joyce A. Heffelbower c/o Karl E. Rominger, Esq.- 155 S Hanover St., Carlisle, PA 17013, Defendant(s); (3) and against, Members First Federal Credit Union- 1166 Walnut Bottom Rd., Carlisle, PA 17013 Garnishee(s); (4) and index this writ (a) against, Joyce A. Heffelbower, Defendant(s) and (b) against, Members First Federal Credit Union, 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) ****GARNISH ONL Y*** You are directed to attach the property of the Defendant(s) not levied upon in the possession of Members First Federal Credit Union 1166 Walnut Bottom Road Carlisle, PA 17013 Garnishee(s) All accounts including but not limited to all savings, checking and other accounts, certificates of deposit, note, receivables, collateral, pledges, documents of title, securities, coupons and safe deposit boxes. Amount due $ 38,097.89 Interest from May 16, 2002 At an interest rate of 6% per year To Be Determined Total $ 38.097.89 Plus costs & interest Dated 3 Februarv 2003 'fl ~~~~~~;M~~"ikj,;i#"qH,..H"G1,,{"lk09jo1\1Im!~~!h\;-:;1<J_Na-'i'!,I~'fu:~'W,',"'",i;K,'+i",":Ji"iJ""8JM''''~~'''''!l!li~~Iil!i'''' E e. + ~ ....... ~~ t~ [I W ~ P 70 't~ #- hi:. 1:- D ""Q - ~ .'-. () o ~ ~< '" t~IlI' "" ,. '''''"''''~ '- ' .1 ../.c;). cO ~ ..0-';: ....... (,.; ......... ~ O~..fI1'O.......~ o ODD't............-1f( . DO 0 D D I I / I ,0r :~: :~: :~b ~ . -J:- "f{ " ..- o ff "lJ U~ 0.1 n-: ..z -:r' ~f;~ ~~E ,~ .2: (J ~C) Pc Z -.... -< - .... o (..) -r; CT1 V:J () " C) -0 G:< N .,,--;-J "'>~-J.. ,",< '-~ :...~-l fI ~. ~ :;.;> .~-~ ~.- _1iI<,",-C_"""""..j ~~" .-- ..."...."..-..L"L1UdLULII..~I..~IUj... . ~'-, - JiliII.i~"~"'I-"~11 '~I "..ltiliM~.ILdlljlllilllliwtlitlJ " jill- "'" -~- ;....~"'~~"Ii~'H "" -- WRIT OF EXEcutIONaild!or ATTA:CHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-3294 Civil CML ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HCR MANOR CARE, Plaintiff (s) From JOYCE A. HEFFELBOWER, INDIVIDUALLY, AND ROBERT HEFFELBOWER, INDIVIDUALLY, AND ON BEHALF OF JOYCE A. HEFFELBOWER (1) You are directed to levy upon the property of the defendant (s)and to sell ,. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of MEMBERS FIRST FEDERAL CREDIT UNION - 1166 WALNUT BOTTOM ROAD, CARLISLE, P A 17013 - 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: and to notify the garnishee(s) that: (a) an attaclunent has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defep.dant (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 attaclunent is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that helshe has been added as a garnishee and is enjoined as above stated. Amount Due $38,097.89 1.1. Interest FROM MAY 16, 2002 AT AN INTEREST RATE OF 6% PER YEAR Atty's Comm % Due Prothy $1.00 Atty Paid $149.70 Plaintiff Paid Date: FEBRUARY 11, 2003 Other Costs CURTIS R. LONG (Seal) prothon'Z>Ab.Ao e ~ IJ_ Deputy ~A~~ REQUESTING PARTY: Name AMY F. WOLFSON, ESQIDRE Address: 267 Eo MARKET STREET YORK, PA 17403 Attorney for: PLAINTIFF Telephone: 717-846-1252 Supreme Court ID No. 87062 - "",".,- t.,,- '" \' ".'~ .". .. ~;,~: : SHERIFF'S RETURN - GARNISHEE ~ASE NO: 2001-03294 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND HCR MANOR CARE VS HEFFELBOWE~ JOYCE A ETAL And now JASON VIORAL ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0018:00 Hours, on the 21st day of June , 2002, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT HEFFELBOWER JOYCE A , in the hands, possession, or control of the within named Garnishee MEMBERS 1ST FEDERAL CREDIT UNION 1166 WALNUT BOTTOM ROAD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to TAMMY MISLYAN (ASST. MANAGER) personally three copies of interogatories together with 3 true and attested copies of the within COMPLAINT & NOTICE and made the contents there of known to Her . Sheriff's Costs: Docketing Service Affidavit Surcharge .00 .00 .00 .00 .00 .00 So an~ ~ ~ ~ -t; _ '.:.e R. Thomas Kline Sheriff of Cumberland County 00/00/0000 By this 5~ ,JLrm.:L. (~Q ~,~ P ot onotary subscribed to day Of~ A.D. before me Sworn and ,,,,~........w -co,", """""^_lX SHERIFF'S RETURN - GARNISHEE , r:A~ NO: 2001-03294 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND HCR MANOR CARE VS HEFFELBOWER JOYCE A ETAL And now JASON VIORAL ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0018:00 Hours, on the 21st day of June , 2002, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT HEFFELBOWER ROBERT IND AND ON BEHALF OF JOYCE A HEFFELBOWER in the hands, possession, or control of the within named Garnishee MEMBERS 1ST FEDERAL CREDIT UNION 1166 WALNUT BOTTOM ROAD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to TAMMY MISLYAN (ASST. MANAGER) personally three copies of interogatories together with 3 true and attested copies of the within COMPLAINT & NOTICE and made the contents there of known to Her . Sheriff's Costs: Docketing Service Affidavit Surcharge .00 .00 .00 .00 .00 .00 S~~"'.<~R R. Thomas Kline Sheriff of Cumberland County 00/00/0000 Sworn and subscribed to before me this. !f'f:: day of Q,P'l dlnJv A.D. p~o~ar~ ,~ By 1 _ ~_, , ._-~, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HCR MANOR CARE, Plaintiff, v. NO. 01-3294 Joyce A. Heffelbower, Individually and Robert Heffelbower, Individually an on Behalf of Joyce A. Heffelbower, Defendants, v. CIVIL ACTION-LAW MEMBERS FIRST FEDERAL CREDIT UNION,: Garnishee, PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, Members First Federal Credit Union, discontinued, upon payment of your costs only. Respectfully submitted, WOLFSON & ASSOCIATES, P.C. BY:~~~~ Daniel F. Wolfson, Esquire Attorney for Plaintiff WOLFSON & ASSOCIATES, P.C. 267 East Market Street York, Pennsylvania 17403 Telephone No. (717)846-1252 Attorney I.D. No. 20617 Dated: 19 Julv 2002 ~ ~ifiiiH;ijiinl..~~:JeAI'ii!"')I'-~:-;~;"-2l_%':HiI\w>,"'~~;''''!!,*"k---."""~-'.u:[Jj.'i _,\<:;,HR~_ ~'H:i'il:,"" 'ff_:,,&-',~,'~M,ii.l'fuf~:-'~' "jJI_rill~IiI~1ilH~.~~':'iILE "-~^"'_I111fS. 1-~ ~ () 0 "- &: ).J -U ~ l.!( ~ f ~ -.2 ~ --.:..., ~ ~ o.~~ ~_....".,.,._ _!!!c 0 c:> 0 c '" -'n s: '- :~ -00:; := :'l';i ;:2 gJrn ~, ~~. _.~,'" N ~~- (.;.) l,-~ t....-' -e ~~~< ..-\:~ .c;~-:C) 5> 'J N (.;?\ rn c:: -, .~, ~ ''::::t :b -< to '-< ~ . -"'- ~ - ~ ...~,; I >t , PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 to 3149 HCR Manor Care, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JUDGMENT NO. 01-3294 vs. Joyce A. Heffelbower, Individually, and Robert Heffelbower, Individually, and on Behalf of Joyce A. Heffelbower, Defendant PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) To the Prothonotary: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of Cumberland County, Pennsylvania; (2) against, Joyce A. Heffelbower clo Karl E. Rominger, Esq.- 155 S Hanover St., Carlisle, PA 17013, Defendant(s); (3) and against, Members First Federal Credit Union-1166 Walnut Bottom Rd., Carlisle, PA 17013 Garnishee(s); (4) and index this writ (a) against, Joyce A. Heffelbower, Defendant(s) and Garnishee(s), (b) against, Members First Federal Credit Union, as a lis pendens against the real property of the Defendant(s) in the name of the Garnishee(s) as follows: (Specifically describe property) ****GARNISH ONL Y*** You are directed to attach the property of the Defendant(s) not levied upon in the possession of Members First Federal Credit Union 1166 Walnut Bottom Road Carlisle, PA 17013 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 $ 38.097.89 Interest from May 16, 2002 At an interest rate of 6% per year To Be Determined Total $ 38.097.89 Plus costs & interest Dated 11 June 2002 Daniel F. Wolfson, Esquire Attorney ID # 20617 267 E. Market Street York, PA 17403 (717)846-1252 ~_~lM!b--:;;'""i\lli-Y-01I,';f'>i;;~if,~c',~~,J"";H;;!!";~"'''I';'''d''1'O'~"_"'"''''-i!~t;tJf,G_,-!!.i~~',j\;;,,,,,,iPf,lM~",~~~~~'''''''\i1lli1lMIQiItil;~~ ,~, -,,"= ~"~R_ -, 1, I < " fJ -lQ. ).J I{j ~~ ~ It> i0- N .... U-J {)1 .0 ...... 'l ...... --- !'l 0 ~ 6 . ...:l 0 0 0 d c: N 0 0 l) ..... " s: 'n C 0 0 -um L. .-, "- 0 I ~ -., ~ I I li1rn iZ ~1~ ~I I 2::0 I zc e'r'ro u' 0 ~ ~~?: .r.- "f.jS:J f} ~ - ~~ ~ r " - ~C} "- .... ::;;; " d?;C: " ~ -i... ----c: ~-c Pc w om " ~ ~t .-::, - Z -, - =< => ?5 "" -< .~ ~._ M l~ 0, ~,~ ';;;U;.'.-i"''''' ..A .~ WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYL VANTA) COUNTY OF CUMBERLAND) NO 01-3294 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HCR MANOR CARE, Plaintiff (s) From JOYCE A. HEFFELBOWER, INDIVIDUALLY, AND ROBERT HEFFELBOWER, INDIVIDUALLY, AND ON BEHALF OF JOYCE A. HEFFELBOWER (1) You are directed to levy upon the property of the defendant (s)and to sell JOYCE A. HEFFELBOWER C/O KARL E. ROMINGER, ESQ. -155 S HANOVER ST., CARLISLE, PA 17013 . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of MEMBERS FIRST FEDERAL CREDIT UNION, 1166 WALNUT BOTTOM ROAD, CARLISLE, P A 17013 GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the accoWlt of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty 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 hirnlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $38,097.89 L.L. $.50 Interest FROM 5/16/02 AT AN INTEREST RATE OF 6% PER YEAR Ally's Comm Due Prothy $1.00 Other Costs % Ally Paid $122.70 Plaintiff Paid Date: JUNE 14,2002 CURTIS R. LONG (Seal) protho~ 21f <By: ~ _ 2. ~/l.Iu')(J Deputy REQUESTING PARTY: Name DANIEL F. WOLFSON, ESQUIRE Address: 267 E. MARKET STREET YORK, PA 17403 Attorney for: PLAINTIFF Telephone: 717-846-1252 Supreme Court ill No. 20617 "~'" .' ~., "'.,w....;,..' -,- """ ""'''-'''mrJi ./' SHERIFF'S RETURN - GARNISHEE CASE NO: 2001-03294 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND \ HCR MANOR CARE VS HEFFELBOWER JOYCE A ETAL And now KENNETH GOSSERT ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0015:03 Hours,'on the 24th day of February, 2003, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT HEFFELBOWER ROBERT IND AND ON BEHALF OF JOYCE A HEFFELBOWER , in the hands, possession, or control of the within named Garnishee MEMBERS 1ST FEDERAL CREDIT UNION 1166 WALNUT BOTTOM ROAD CARLISLE, PA 17013 Cumberland County, pennsylvania, by handing to ANTHONY DAMORE (BRANCH MANAGER personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to His . Sheriff's Costs: Docketing Service Affidavit Surcharge .00 .00 .00 .00 .00 .00 sOE' tF-~'~"'(~~!, R. Thomas Kline Sheriff of Cumberland County 00/00/0000 this 1f!:- day of~ .2.tJo3 A . D . p~/?ar~' dp:;' By Sworn and subscribed to before me '_o",~ ,. "-~ - '.. ]ij[J'c ~-~~; > ^ ", SHERIFF'S RETURN - GARNISHEE CASE NO: 2001-03294 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND HCR MANOR CARE VS HEFFELBOWER JOYCE A ETAL And now KENNETH GOSSERT ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0015:03 Hours, on the 24th day of February, 2003, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT HEFFELBOWER JOYCE A , in the hands, possession, or control of the within named Garnishee MEMBERS 1ST FEDERAL CREDIT UNION 1166 WALNUT BOTTOM ROAD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to ANTHONY DAMORE (BRANCH MANAGER) personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to His . Sheriff's Costs: Docketing Service Affidavit Surcharge .00 .00 .00 .00 .00 .00 So a~:.;:;.ee~r: : .. v~. ~;~<~~ R. Thomas Kli e Sheriff of Cumberland County 00/00/0000 this 1& day of ~ .2t1{J3 A.D. ~Q/hP'?'u Aq~' Pro onotary I By A~ff Sworn and subscribed to before me " ~ -' , . . .... \ ,__,_~_"",l _; "':.' - ~~" .' ,4 . ,;- - :'-~i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HCR Manor Care, Plaintiff, v. Joyce A. Heffelbower, Individually and Robert Heffelbower, Individually and on Behalf of Joyce A. Heffelbower, Defendants, v. Members First Federal Credit Union, Garnishee, NO. 01-3294 Garnishee: Members First Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 PRAECIPE FOR JUDGMENT UPON ADMISSION To the Prothonotary: Please enter judgment in favor of the Plaintiff and against the Garnishee, Members First Federal Credit, in the amount of $ 7,497.20, as admitted in the answer to interrogatories to be in the Garnishee's possession. The amount of the judgment together with interest and costs of the Plaintiff against the Defendant is $38,097.89, Dated: 3 July 2002 Damel F. Wolfson, Esquire Attorney for Plaintiff I.D.No.20617 WOLFSON & ASSOCIATES, P.C. 267 East Market Street York, PA 17403-2000 Telephone: (717) 846-1252 ,- -~"-=q- >'l, i", ;.- . ^ ,0_,' ........~~; I' " / IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HCR Manor Care, Plaintiff, v. NO. 01-3294 Joyce A. Heffelbower, Individually and Robert Heffelbower, Individually an on Behalf of Joyce A. Heffelbower, Defendants, NOTICE OF FlUNG JUDGMENT v. Members First Federal Credit Uniorr, Garnishee, (x) Notice is hereby given that ajudgment in the above-captioned matter has been entered against you in the amount of $ 7.497.20 . ( ) A copy of all documents filed with the Prothonotary in support of the within judgment islare enclosed. '7/ u, 10 ).... by: If you have any questions regarding this Notice, please contact the filing party. Daniel F. Wolfson, Esquire WOLFSON & ASSOCIATES, P.C. 267 East Market Street York, PA 17403-2000 (717) 846-1252 (This Notice is given in accordance with Pa.R.C.P. 236.) NOTICE SENT TO: Members First Federal Credit Union 500 Louise Drive Mechanicsburg, PA 17055 Joyce A. Heffelbbwer clo Karl E. Rominger, Es 155 S. Hanover Street Carlisle, PA 17013 cl_~~ilt~,;ik"tl;;Kb,i!-!Jh~I)""",:;ji'_'~i,;,~,,,i:,;:~'__;;"O.~,;, ,':".,-6;, i\" ";>""'I'j:"'__'/c""_!a,ei:~<"';"'''''"~!;,%ti",\i$'iJl1~~''iI*)'~dJIijj~~ ~Iii!-' ~,hrV'."~~i1l,liiti!lll!Jk'~ ' ' t t1-ft ~ :-0 0 g tv () j ~ ~ r p..I 1- - ~ r--, ~~~. ~,~..., _" ._.~"L^,"'_r '~""_~-~",'<"''' _,~,~__ ./ '- 0 c::> 0 c: 1'-.) " ;;: L- .-l ""00::\ c:: :~:i~# men , Z::I1 "Cr~ &;L". a' :,;')9 -< ~~~ -;:::-1() r:;CI ~ -~t-~ j; ---; ;~-,t2(:S .7(~ .."c <D :~rn Pc: =-\ ~ r:- ?fl -< ,,.... '< ., ,''C _""~,,,,~,~~"""'.,,"r" ,-_~, ,_e,~ ~'""',~.~ ~-'" - , c ...l, ,~O~-"'- _, = '^_ . ,_^ """ ,:,,' r'ili ~a2-02 01:41 PM MEMBERS1ST ~CU INS. DEPT 7177955178 ! -,-~, ,,,., , P.03 , . 0/... 3:8lf G~~l f) I~t HA:)~W~ -10 PLAINTIFF'S INTERROGATORIES TO GARNISHEE DEFENDANT. JOYCE A. HEFFELBOWER 55# 209.12.9273 1. OEPOSITORY ACCOUNT$: At the time you were served or at any subsequent time, stat!! whether or not the Defendant(s), maintains any checkin~, savings, lines of credit, . certificate of deposit's or other depOSitory accounts with your Institution. If so, state the !dentification numbers of those accounts, and the amount or amounts the Defendant(s) has. In each account. If the Defendant(s) maintains any of these jointly with any other person, or ' persons. give their name and. address. '" S~V:~~ '4-Q.~~~ltJq AC.(l.OLl.r.Ji'1-IO~15"(', ~vl~f.M~ ~ 11t- "10, ~~l~, ~J.:c~~~I5"(~,J~. <;A~I~~1~~.~~h'c1r(() ~ q~".?4. 101A/,. tJwJ ~v~tL~ li.11~q1.J-D 1A. ~ECT DEPOSIT ACCOUNTS: Are any of the accounts you have listed above direct depOSit accounts? If yes, please state the identification numbers of those accounts. ~~, 1"1\f:.. S!tV, N~s.. ~. I bq)~6' 2. D OXES: At the time you were served or at any subsequent time, state whet er or not the e endant(s) maintains any safe deposit box or boxes. If so, include the identification number or other designation of the box or boxes. Include a full description of the contents and also the amount of cash among those contents. If the Defendant(s) maintains any of these jointly with any other person or persons give their full name and address. No 3. esBSON~ PRQPERlY: At the time you were served or at any subsequenttime, slale whether or not efendant(s) owns any personal property that was in your possession and/or control, If so, include a full description of all personal property giving full value and present location. State also whether or not there are any encumberances or liens holders, the present balance of the encumberance, State where and when the encumberances or liens was recorded. If the Defendant(s) owns any personal property jointly with any person or persons, give names and address. )JU i,"/-" . "-~-,.= - "O"~ '~-~ ,~l.'n ""-.-idfu,:~'- , ,- -~'ji _/82-02 01:40 PM MEMBERS1ST Feu INS~ DEPT 7177955178 P.02 " IN THE COURT OF COMMON PLEAS Of CUMBERLAND COUNTY, PENNSYLVANIA HeR Manor Care, Plaintiff NO. 01.3294 vs. Joyce A. Heffelbower, Individually, and Robert Heffelbower, Individually, and on Behalf of Joyce A. Heffelbower, Defendants CIVIL ACTION. LAW INTERROGATORIES TO GARNISHEE IN AID OF EXECUTION TO: Members First Federal Credit Union 1166 Walnut Bottom Rd. Carlisle, PA 17013 PURSUANT TO RULE 3114 OF THE RULES OF CIVIL PROCEDURE, THE I FOLLOWING INTERROGATORIES HAVE BEEN SERVED UPON YOUR INSTITUTION. GARNISHEE IS HEREBY REQUIRED TO ANSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARATELY AND FULLY. PLEASe COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE CREDITOR'S EFFORTS TO SA TlsFYTHE LAWFUL OBLIGATION OF THE ABOVE REFERENCED DEBTOR(S). IMPORTANT NOTICES AND INSTRUCTIONS TO GARNISHEEI A. You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you. B.. The tE!rm "Defendant(s)" means the individual(s) or entity against whom the Writ of Execution was Issued. C. ''You'' means the main office and all branch offices, representativeS,' employees, and agents of your organization. D. By service of the Writ of Execution upon you, all property of the Defendant(s/ subject to attachment which is in your possession, custody or control is attached, including a I property of the Defendant(s) which comes Into your possession thereafter. E. These Interrogatories are considered to be continuing and therefore should be modified or supplemented as you receive further or additional information. F. Where exact Information cannot be furnished estimated information is to be supplied. When an estimate is to be used, it should be identihed as such; and an explanation should be given as to the basis on which the estimate is made, and the reason the exact information cannot be furnished. G. Where knowledge or information in possession of a party is requested, such request includes knowledge of the party's agents, representatives, ana attorneys. . 66#209.12.9273 .~ ~, -, ...' -"'0 t' ;' ;.,: ,:;. , ,~^ -~,: "~,-. ' "" , ~~~2-e2 01:41 PM MEMBERS 1ST Feu INS. DEPT 7177955178 !,_ool>"" , , ,i P.84 4. ~THER ASSETS; At the time you were served or at any subsequent time, did you knowo. the existence of any other asset(s) of the Defendant(s) which are not diselosed in the preceding Interrogatories. If so, please set forth all details concerning those asset. N';) 5. PROPI;~TY; At the time you were served or at any subsequent time, was there in your possession, custody, or control orin the joining possessIon, custody, or control ofyoul'$elf and one or more other persons any property of any nature owned solely or in part by any Defendant(s)? If so, please describe for each Defendant each item of property including ~s value. lJi) 6. REAL P60PE8T'(: At the time you were served or at any subsequent time, did you hold legal, or equitable title to any property of any nature owned solely or in part by the Defendant(s) or In Which and Defendant(s) held or claimed any interest? If so, descritle for each Defendant each item of property including its value and the Interest held by the Defendant(s). ~t) ,- -'. ,-, '''''"--;~, ".' -41 JUL-e2-e2 el:42 PM MEMBERSIST Feu INS. DEPT 7177955178 . I . P.05 c . , . 7. PROPERTY HELD AS A FIDUCIARY: At the time you were served or at any ~ubsequent time, did you hold as a fiduciary any property in which any Oefendant(s) had an Interest? If so, please describe for each Defendant(s) the nature of the property including its value and the interest of Defendant(s). . Nt 8. TRANSFER OF PROPERTX: At any time before or after you were served, did any Defendant(s) transfer or deliver any property to you or to any person or place pursuantto your direction Or consent Ifso, for each Defendant(s) describe the property transferred or delivered including the dates of delivery or transfer and state the consideration paId. i ~tl 9. fEE~ OUTs1ANDIN~TO GABNISHEE.: Are there any attorneys fees or processing fees chargedby you against the Defendant(s) or account(s) of the Defendant(s) for the completion of this Answer. If yes, outline the exact amount of any fees due and owing to the garnishee or the attorney for the gamlshee for the preparation of the Answer. ~~ WOLFSON & ASSOCIATES, P.C. B Dated: 11 June 2002 ". ~~W~1ilI~'!Oib,hlii;;v.M1;~"0,i.'_".I'!,I':'L'J'i5i:1H',";ii:;jI",iIl'ij&,c",l;;",~.,;,:i1<";'\),'J~~f<'''o'''>'.''-:;!:~A:I;",-,;;jli.l!1;?-lfuiklj;}.I>fijEM~f_~~_,d1~' j~" - ... .I I \ 0 0 0 C N " s: '- :,=, -OeD S nlfn !'~--l-n Z:rJ , .' ,.... zr-' 'rjm (J) );, 0" TJQ -<./ 0,1., r::o J:;> ~:;j ~,r; ~c:-; ::E: ;=-i :D '!E::::c\ .~?C) );~c UJ i:Sm ~"':>" ---I L_ "'" ~- --;l ,n ::0 -, -< ~ ,. -~. -" ,,"~~-"" . " '"""' , '"'~ ~,~"d' "', "~, , '", - ,;_",,' '0-" . "r{",': ... ~.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HCR MANOR CARE, Plaintiff vs. No. 01-3294 Action in: Civil-Law JOYCE A. HEFFELBOWER, Individually, and ROBERT HEFFELBOWER, Individually, and on Behalf of JOYCE A. HEFFElBOWER, Defendants PRAECIPE FOR JUDGMENT ENTER JUDGMENT in the above case for failure to file, enter, an TO ENTER A DEFENSE against JOYCE A. HEFFELBOWER in favor of HCR MANOR CARE in the sum of.$ 38.097.89 with interest AS ALLOWED BY STATUTE Total: _$38.097.89 AND COURT COSTS ~~~. Attorney for Plaintiff D....IF. Wol.... ....n. - - ~ . - m ~ ~ J (,..., . 20 6;;;( Judgment entered by the Prothono ry this day according to the tenor of the above statement. (L~,124 Prothonotary '" ,,'..,.-~' ." ,~i-- ",;, c,' < , ~ , ~'~"-~" ~ .. . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA HCR MANOR CARE, Plaintiff NO. 01-3294 vs. CIVIL ACTION - LAW JOYCE A. HEFFELBOWER, IndMdually, and ROBERT HEFFELBOWER, Individually, and on Behalf of JOYCE A. HEFFELBOWER, Defendant CERTIFICATION I, Daniel F. Wolfson, Esquire, due hereby certify that on October 4, 200 I, I caused a true and correct copy of the 10 Day Notice Prior to Filing Judgment attached hereto to be served on the Defendant, Joyce Heffelbower. Date: 5114~(\'L, , Daniel F. Wolfson, Esquire WOLFSON & ASSOCIATES, P.c. 267 East Market Street York, Pennsylvania 17403 Telephone No. (717) 846-1252 I.D. # 20617 Attorney for Plaintiff ,~''''''"''''''''"'' ~ " ,'.-' ~~.' ", , ' ~ .. ~,-. ATTORNEYS Daniel F. Wolfson Amy F. Wolfson Philip C. Warholic WOLFSON & ASSOCIATES, P.C. Attorneys at Law 267 East Market Street York, Pennsylvania 17403 COUNSEL Morrison B, Williams Donald L. Hoage' (717) 846-1252 (800) 321-8467 FAX (717) 848-1146 P ARALIiGALS Margaret L. Burg Susan K. Kostalas e-mail: dfwolfson@debtcollection.net .. Ucensed to Practice in Maryl~nd October 4, 2001 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pa 1 701 3 Re: HCR Manor Care vs Joyce A. Heffelbower Et. AI. Docket No. 01-3294 (CP Cumberland County) 10 Day Notice Dear Attorney Rominger: ~>\'M~,L\,i:l-- BRANCH OFFICE: 8 Manchester Street Glen Rock, PA 17327 (717) 235-5014 PLEASE FORWARD ALL CORRESPONDENCE TO THE YORK OFFICE We enclose a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Sincerely, w~~~~~ Daniel F. Wolfson, Esquire DFW/cc enclosure ~..'>~~ ' ~, ~ -~' . ~ " 'd' _-,,"_ ", '....t..~~."',' . ~>,: ~ ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HCR MANOR CARE, Plaintiff NO. 01.3294 vs. . . CIVIL ACTION. LAW . . JOYCE A. HEFFELBOWER, Individually, and ROBERT HEFFELBOWER, Individually, and on Behalf of JOYCE A. HEFFELBOWER, Defendants > . . TO: JOYCE HEFFELBOWER C/O KARL E. ROMINGER, ESQ. 1 SS SOUTH HANOVER STREET CARLISLE, PAl 7013 DATE OF NOTICE: October 4, 2001 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 JUDGMENT MAYBE 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 'tOU 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. Court Administrator Cumberland County Court House 1 Court House Square, 4th Floor Carlisle, Pennsylvania 1 701 3 (717) 240-6200 ./~ BY~~~~ Daniel F. Wolfson, Esquire WOLFSON & ASSOCIATES, P.c. 267 East Market Street York, Pennsylvania 17403-2000 Telephone: (717) 846-1252 J.D. # 2061 7 -,~..."-......" <- '''' ~. "'--- j!i!id.h~" --. ." ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HCR MANOR CARE, Plaintiff NO. 01-3294 vs. CIVIL ACTION - LAW JOYCE A. HEFFELBOWER, Individually, and ROBERT HEFFELBOWER, Individually, and on Behalf of JOYCE A. HEFFELBOWER, Defendants NOTICE OF ORDER, DECREE OR JUDGMENT TO: ( ) PLAINTIFF (X) DEFENDANT ( ) GARNISHEE ( ) ADDITIONAL DEFENDANT YOU ARE HEREBY NOTIFIED THAT THE FOLLOWING ORDER, DECREE OR JUDGMENT HAS BEEN ENTERED AGAINST YOU ON IN ACCORDANCE WITH THE I"ROVfSIONS OF PA.R.C.P. 236 ( ) DECREE NISI IN EQUITY ( ) FINAL DECREE IN EQUITY (X) JUDGMENT OF () (X) ( ) CONFESSION DEFAULT NON-PROS ( ) ( ) ( ) VERDICT NON-SUIT ARBITRATION AWARD (X) JUDGMENT IS IN THE AMOUNT OF $38,097.89 PLUS COSTS $95.70 FOR A TOTAL OF $38,193.59. ( ) 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 BY IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: 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: NOTICE SENT TO: JOYCE A. HEFFELBOWER C/O KARL E. ROMINGER, ESQUIRE 155 SOUTH HANOVER STREET CARLISLE, PA 17013 ~~i~~fu,;.i:;"OE,%,';J<.;.'t:;fr'!iJ;L",:""':iliiN~:';:"i"~~I,,,,~;;6\'1i'-'\;~'ijt'~!ih0~'1::,h~-,;f;,f.,N:",,;i-,,:.d,:,'''''i'b-Ci,wji.mm~I..W~m~~~I'Sjf~~~~i'iiliWM.,Ill!1l!'~,b-,;dIoi>;j~l '1 ... ". . -- .. (~ t f:J P .lQ. -:0 II:.. ~ 8 0 C'l 0 - <;; f''-..1 -0'1 f" -:t.: :J: ~ -o(~n ;:-"" nlrl~1 -n p :z: ::.: -< r rr, if! zr; -~1i"T! ~ 6" (f) ~!~ en -:30 RJ -<-- :~}~ ~ r--- -~ _L... "'1J ", J 3> :::'i: :~; :1J 7(') ~'~J f-~"" ~O '-!? f;'rn >c ,.) -I Z ::::> )> :;! :rJ (""'., (,:J -< '"~~, .~, ,e_ - ~, ~ , , ,~"'~"""..._,~.- ~. '~.si~I'a""',,!!, - . , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA HCR Manor Care, Plaintiff, v. NO. 200103294 Joyce A. Heffelbower, Indiv., and Robert Heffelbower, Indiv. and on Behalf of Joyce A. Heffelbower, Defendant( s), v. Members First Federal Credit Union, Garnishee, Garnishee: Members First Federal Credit Union 1166 Walnut Bottom Rd. Carlisle, PA 17013 PRAECIPE FOR JUDGMENT UPON ADMISSION To the Prothonotary: Please enter judgment in favor of the Plaintiff and against the Garnishee, Members First Federal Credit Union, in the amount of$ 982.70, as admitted in the answer to interrogatories to be in the Garnishee's possession. The amount of the judgment together with interest and costs of the Plaintiff against the Defendant is $ 38.097.89 Dated: 3 March 2003 fson, Esquir Attorney or Plaintiff LD. No. 87062 WOLFSON & ASSOCIATES, P.C. 267 East Market Street York, P A 17403-2000 Telephone: (717) 846-1252 , - " " r<<.IP~!~'--""'- ~~,IlMf!"';'3iJ';EI""~"""!,w,-;+;;*r,",,,,,,~._h",_1d',,!, n'.,fB ';,;;,0iilt%.it*,,,i.i;i!M",:.,~c,,,,,;t'iii~..nn--t iT' , '-"'v';' "~'K ~~ ~[lli~.ill".' ~ ~._"~~ ~.. . - f c ^i (.) ..(,;). ~ ..0 ~ 0 (") S; ~-o-_." --;::;. c: 0 't)0; -- "" r ti [DC:-_ ~:I ~, t;::, t7f~- h) fIl (=, ~ ~ -<., ~ ~(- 6"'- ~~(' ;>.;," (J) >E~: -- Q.J 1..':' - J ~ z -.;::-~:! p: -:I ::J S.J -, (P .< ~ _.,>-) <,,,,,~ ,',~ ,""',"IU,,,"_ <=~"^ ~_ ,~~ ~",," ,~~. "<""""'Y,"""."~"'" :>'#_,"," ",,,,,"',,~.""''''''~,,''''.'''-';P.,,,,._ ",,'_,''-'''''_,~'''~W' ~,,~ , . ",- """ ~- ^"~ ,,"., ~,., _i;~,,-"'--I ~ - ~"- < ~J ..~'".:i"'~WM.ii" . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA HCR Manor Care, Plaintiff, v. NO. 200103294 Joyce A. Heffe1bower, lndiv., and Robert Heffelbower, Indiv. and on Behalf of Joyce A. Heffelbower, Defendant( s), NOTICE OF FILING JUDGMENT v. Members First Federal Credit Union, Garnishee, (x) Notice is hereby given that ajudgment in the above-captioned matter has been entered against you in the amount of $ 982.70. ( ) A copy of all documents filed with the Prothonotary in support of the within judgment is/are enclosed. --hy: AC);>.p 2.~~ If you have any questions regarding this Notice, please contact the filing party. Amy F. Wolfson, Esquire WOLFSON & ASSOCIATES, P.c. 267 East Market Street York,PA 17403-2000 (717) 846-1252 (This Notice is given in accordance with Pa.R.C.P. 236.) NOTICE SENT TO: Members First Federal Credit Union P.O. Box 40 Mechanicsburg, P A 17055 Joyce A. Heffelbower clo Karl E. Rominger, Esq. 155 S Hanover St., Carlisle, PA 17013 '~._~~\f'i#i;j;,;ii@-ft;iH~~;vH"E-&.:nj"".i'jUji-iil!irni-$",-,,,;,'~;i1d~';{"'~1'0,t;r'\~/'*"'''di.'''''fr,{,,'''-fj!cl,jbti,~~!lltlliiJ~o,~"" ''<l'iJ!ll1l'II''" '~"""~liM.' '~ .,--~- ,~" ""~, "'~,"","~"""_r~,"__ .. '~"''''~'''''",~_"~,,,r -ob .T!I' ~~:' /_" 1~ en ~' -< ~:l. ~~~~, , ~""" ,~~~, _',,"~,O~^ ,= '.' ,~ J~,~," ~ .~ o ~~~ .-~' ,.;. -' -, .., "J "j~i1kIj = !'?' . c' 1',,) (=' '-.f:: -cr;! :=> co S:l ."'-. 11 ~ 'ri ,~~ , i ''',,"'~ ~" ,'^ .L .a.:.;.~-i 1,;.", " ----':;'~;, 03/20/03 21:29 FAX 19J03 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HCR Manor Care, NO. 01-3294 Plaintiff vs. Joyce A. Heffelbower, Individually, and Robert Heffelbower, Individually, and on Behalf of Joyce A. Heffelbower, : CIVIL ACTION - LAW Defendants f) ~ HI0Sc..uEAE' 10 INTERROGATORIES TO GARNISHEE IN AID OF EXECUTION .. ,a_ . . TO: Members Firs! Federal Credit Union 1166 Walnut Bottom Rd. Carlisle, PA 17013 PURSUANT TO RULE 3114 OF THE RULES OF CIVIL PROCEDURE, THE FOLLOWING INTERROGATORIES HAVE BEEN SERVED UPON YOUR INSTITUTION. GARNISHEE IS HEREBY REQUIRED TO ANSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARATELY AND FULLY. PLEASE COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE CREDITOR'SEFFORTS TO SA TISFYTHE LAWFUL OBLIGATION OF THE ABOVE REFERENCED DEBTOR(S). IMPORTANT NOTICES AND INSTRUCTIONS TO GARNISHEE! A. You are required to file answers to the following interrogatories within twenty (20) . days after service upon you. Failure to do so may result in judgrnent against you. .! .1 ;: B. The term "Defendant(s)" means the individual(s) or entity against whom the Writ of.. : Execution was issued. _...~.~ I . C. "You" means the main office and all branch offices. representatives. employees, I and agents of your organization"1 D. By service of the Writ of Execution upon you, all property of the Defendant(s) I subject to attachment which is in your possession, custody or control is attached. including all I' property of the Defendant(s) which comes into your possession thereafter. i E. These Interrogatories are considered to be continuing and therefore should be ,i modified or supplemented as you receive further or additional information. F, Where exact information cannot be furnished, estimated information is to be supplied. When an estimate is to be used. it should be identified as such. and an explanation .' should be given as to the basis on which the estimate is made, and the reason the exact I information cannot be furnished. ;, I G. Where knowledge or information in possession of a party is requested. such request i includes knowledge of the party's agents, representatives. and attorneys. 55#209-12-9273 1 --~' ,- 1 J~ ~ '" ~~ >' ~;, '-'" r, " '~~'>, , "~ 03/20/03 21:29 FAX 14104 ., . PLAINTIFF'S INTERROGATORIES TO GARNISHEE DEFENDANT. JOYCE A. HEFFELBOWER 55# 209.12.9273 1. DEPOSITORY ACCOUNTS: At the time you were served or at any subsequent lime, stat~ whether or not the Defendant(s) maintains any checking. savings, lines of credit, certificate of deposIt's or other depository accounts with your institution. If so state the identification n.umbers of those accounts. and the amount or amounts the Defendant(s) has In each account If the Defendant(s) maintains any of these jointly with any other person. or persons, give their name and address. / 'St...i{IN~;, + WS~L(N9 AC.~o1J.,fJ'( l" q ?>, '5", SfrVi~ bA~Ne.t.. . '1-).4-. t\.\~C.ll f\I~ ~ALAJJL'-- i~ g~.TO . _..._. .. '_'II . : 1A. DIRECT DEPOSIT ACCOUNTS: Are any of the accounts you have listed above direct deposit accounts? If yes, please state the identifi~on numbers of those accounts. "I fcS ~ S A II N~) 1\t.c.0UjIJl '0 q ?J ~ 2. SAFE DEPOSIT BOXES: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any safe deposit box or boxes. If so, include the identification number or other designation of the box or boxes. Include a full description of the contents and also the amount of cash arnong those contents. If the Defendant(s) maintains any of these jointly with any other person or persons give their full name and address. lJ1) -. .- 1 3. PERSONAL PROPERTY: At the time you were served or at any subsequent time. slate whether or not Defendant(s) owns any personal property that was in your possession and/or control. If so, include a full description of all personal property giving full value and present location. State also whether or not there are any encurnberances or liens holders, the present balance of the encumberance. Stale where and when the encumberances or liens was recorded. If the Defendant(s) owns any personal property jointly with any person or persons, give names and address. ND "... ... . . "',"",,,-<- 03/20/03 21:29 FAX 14105 .'.\ ..,.. "~I ~,. .~~r;lJ ^ '0 ' ,-, ,~ '. 4. OTHER.ASSETS: At the time you were served or at any subsequent time. did you know o!the eXistence of any other asset(s) ofthe Defendant(s) which are not disclosed in the preceding Interrogatories. If so, please set forth all details concerning those asset. !\fa 5_ PROPERTY; At the time you were served or at any subsequent time. wail tiI&ra . .. your possession. custody, or control or in the joining possession. custody. or control of yourself and one or more other persons any property of any nature owned solely or in part by any Defendant{s)? If so, please describe far each Defendant each item of property including its value. tJ-o 6. REAL PROPERTY: At the time you were served or at any subsequent tiTT!e. did you hold legal. or equitable title to any property of any nat~re owne~ solely or In part ~y the Defendant{s) or in which and Defendant(s) held or claimed any Intere~t? If so. descnbe for each Defendant each item of property including its value and the Interest held by the Defendant(s). . __ _ ,..~ i ~ ""...'" .- '=~'- - ", "~~li!i!!<,...- 03/20/03 21:29 FAX 14106 J. ..,.' , , 7. PROPERTY HELD AS A FIDUCIARY: At the time you were served or at any subsequent time, did you hold as a fiduciary any property in which any Defendant(s) had an Interest? If so, please describe for each Defendant(s) the nature of the property including its value and the interest of Defendant(s). No , ........ .... ..... 8. TRANSFER OF PROPERTY: At any time before or after you were served, did any Defendant(s) transfer or deliver any property to you Qrto any person or place pursuant to your direction or Consent If so, for each Defendant(s) describe the property transferred or delivered including the dates of delivery or transfer and state the consideration paid. tJo 9. FEES OUTSTANDING TO GARNISHEE: Are there any attorneys fees or processing f~es charged by you against the Defendant(s) or account(s) ofthe Defendant(~) for the comp!etlon of this Answer. If yes, outline the exact amount of any fees due and oWing to the garnishee or the attorney for the garnishee for the preparation aT the Answer. rvb .., WOLFSON & ASSOCIATES. P.C. Dated: 3 February 2003 _ili:~jWJ-W,'*k~~~'M~.illl:~*hh,k"k,!:"",o:","_~'~"~__ik~";"'E"",;,/,:...;,,,,,, ~,,','~,,~.~ "'"-- _.~--" ~ "iH)'~ C"iii<"l,;i;'~Ai!!LSci'YL""---">i"'l-&""j,,,"\Wi!lI~~~"~!~~"""'" ~-~~ -~,- ".~ ^~," o r: -0(::': ;;; ~~- (1:,'\ --< "". f:':;',_. '-- ~:h .~ ::2 -'(:. "') C::',I U:,') :=> (P j )H:1L:IIJ "'0' . I -~ (', r'i-l At; ,,""'- ~, - ,,;.' -co'"~ "'^ I;,~ . ,_ ,.. ~n-iil'Iu.\-" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HCR Manor Care, Plaintiff, v. NO. 01-3294 Joyce A. Heffelbower, Individually, and Robert Heffe1bower, Individually, and on Behalf of Joyce A. Heffelbower, Defendants, v. CIVIL ACTION-LAW Members First Federal Credit Union, Garnishee, PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, Members First Federal Credit Union, discontinued, upon payment of your costs only. Respectfully submitted, WOLFSON & ASSOCIATES, P.C. By: AmyF. Wol Attorney fi laintiff WOLFSON & ASSOCIATES, P.C. 267 East Market Street York, Pennsylvania 17403 Telephone No. (717)846-1252 Attorney J.D. No. 87062 Dated: March 20. 2003 ~~"""Mii-6irM;!JJ;'jfl,!i.fH"'dJiK;:~!""";i''''lK\'''~~U.!l",,;;":.H"'''''-:''i,,,''j'dro;;;itiB0j:1-!l);Mi:'li1>liU'":j),M,,It~~i~lI<fil_~l!t>lilli'" -"'~'~'fu!Ii{lM~~W.i!~.U:" -- .." "t''''~''-'''''''' --~.~-~> 1,;! B5~ p R ~ 0 0 0 c w " :s: :1: :;::J ~ "Om "'" ;-~'\;~ l. D !:!)IT' ::0 ..... ,. 0- ze- N -"G;.l.! CD "'. -.! .:;": <-J 2~ ~~~(S -- tS p! ,<C.' -0 7-'"[ W ~o ::;; ;-S:n ,2:0 ~ f' >8 6rn z .-j VI )> ~ 0" =< Cl" ~ "~,,~ ,~,,," ,'''''''-"",",,"'' ,--~, -, '"<,,,,~'''' ,<, ,~,,,,..,,-,,,"'(>%'~,,-" '" ,'~-~ '-, ,.-, ~ ~."""""~,,,,~~,), ~. ,~<-",= ... ~" ff n .~ . . Ib!b!l ~ = 11Jb,. i!db ~ , ~"-~ - " o . R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff s Costs: Docketing Poundage Advertising . Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Garnishee 18.00 1.44 .50 1.00 6.90 20.00 20.00 9.00 76.84 Sworn and Subscribed to before me This 1"!:: daYOf~ 2003A.D.~a ~ I~ Prothonotary "0:: Advance Costs: Sheriffs Costs: 150.00 76.84 73.16 Refunded to Atty on 4/4/03 ~,... j,('''ti'",': a '- , "" \., " "" So Answers; .~~ 1~€~; R. Thomas Kline, S'tn~ ByBrl"L~<-a, ~~~d-f . ", ...1.. c,..... i, I., '" =' d VI ;-;"if'- .:J ~c I,e, 1<:' nll LI Hnr t ': ~ , Utic. .HI~3IE J;,i;l~ ]'J;.:JJO ,~.';~, ,,; It) 1.':)uJ \. (A <fOLI:''! u'0.u / Jf. <IIi ~'YJ ~ = fId6 ',1 n .'=:::, g ''- ;3i~_"':if~Af$:,i:!:lI;'IT',-ii~M~,;;,iHifk$'la.h1;&""":'f""~ .:.;,J.;!;-J.~;w~;w~~~~iI!illilU~~~~~IM"" ~'o' ." ~~j#-" --- ...-....n WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYL VANTA) COUNTY OF CUMBERLAND) NO 01-3294 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfY the debt, interest and costs due HCR MANOR CARE, Plaintiff (s) From JOYCE A. HEFFELBOWER, INDMDUALL Y, AND ROBERT HEFFELBOWER, INDIVIDUALLY, AND ON BEHALF OF JOYCE A. HEFFELBOWER (1) You are directed to levy upon the property of the defendant (s)and to sell JOYCE A. HEFFELBOWER CIO KARL E. ROMINGER, ESQ. -155 S HANOVER ST., CARLISLE, PA 17013 . (2) You are also directed to attach the property of the defendant(s) not levied npon in the possession of MEMBERS FIRST FEDERAL CREDIT UNION, 1166 W ALNUTBOTTOM ROAD, CARLISLE, PA 17013 GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attaclnnent has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the accoUllt of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) lfproperty of the defendant(s) not levied upon an subject to attaclnnent is fOUlld in the possession of anyone other than a named garnishee, you are directed to notifY himlher that helshe has been added as a garnishee and is enjoined as above stated. Amount Due $38,097.89 L.L. $.50 Interest FROM 5/16/02 AT AN INTEREST RATE OF 6% PER YEAR Ally's Comm % Due Prothy $1.00 Other Costs Ally Paid $122.70 Plaintiff Paid Date: JUNE 14, 2002 CURTIS R. LONG (Seal) prothon~ I!Y: o/'J^ ~ P. 7?zrf) /)Lx..J Deputy REQUESTING PARTY: Name D.<\.1"'!IEL F. WOLFSON, ESQUIRE Address: 267 E. MARKET STREET YORK, PA 17403 Attoruey for: PLAINTIFF Telephone: 717-846-1252 Supreme Court ID No. 20617 "','~,~~;~._~ '" ,m~" _ "~=_ --,'~~,~ ", ~,"' ~,,>~--~~ c" It - - 1~~.J\l-uJ.J!. ,-,-"",.1-..'" _I "j"ltj~Ji:<ll~"",,,___.....,;;m'l'i'hV ,_ -4 -"'" WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) com!ITY OF CUMBERLAND) NO 01-3294 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HCR MANOR CARE, Plaintiff (s) From. JOYCE A. HEFFELBOWER, INDIVIDUALLY, AND ROBERT HEFFELBOWER, INDIVIDUALLY, AND ON BEHALF OF JOYCE A. HEFFELBOWER (I) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of MEMBERS FIRST FEDERAL CREDIT UNION - 1166 WALNUT BOTTOM ROAD, CARLISLE, PA 17013 - 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: and to notify the garnishee(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 aIlyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $38,097.89 L.L. Interest FROM MAY 16, 2002 AT AN INTEREST RATE OF 6% PER YEAR Arty's Conun % Due Prothy $LOO Arty Paid $149.70 Other Costs Plaintiffpaid Date: FEBRUARY 11, 2003 CURTIS R. LONG (Seal) prothon~lV>J ~ Q ~ By;.... . 'OAJ'L r-- Deputy REQUESTING PARTY: Name AMY F. WOLFSON, ESQillRE Address: 267 Eo MARKET STREET YORK, PA 17403 Attorney for: PLAINTIFF Telephone: 717-846-1252 Supreme Court ill No. 87062 ~"~M.~iiill'irill"""'l9fiE\~~ij,'lf!i;rikWdiihi;d'~"I';'f.c: ;_',:",--,u,'''';'-""c":"t',,.,'';'it31'F1r%i,:'5'lIjj!(,,,-r,:;,)o;,rj,ji"""Wi~A~.1i:~A;~t~(';mJ~~,::"i>l..~-W1k'iciM1!m~@;~ t~f J;U,._';"",..", .'~~"""" If!; _l~ #--. ... >. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriffs Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Garnishee Advance Costs: Sheriff s Costs: 150.00 101.10 48.90 18.00 19.65 1.00 3.45 Refunded to Arty on 4/4/03 30.00 20.00 9.00 101.10 Sworn and Subscribed to before me This _ day of 2003 A.D. ~~~~t~; R. Thomas Kline, S'Zn~ By ~ ~ ~ I Ld-~<.- a. ~J~~ Prothonotary /b!b1J ~ t:': ..:::::J [,-:'10, !JJt.~ -.,-. k3' '.--.-P ." ~. _ .~ '~""'."'..,N" = "'~ ,I I " ," iL ,Ii" i.!::!.i' )," ':=J --.:,:::i \S.-..:3,' ':::"-.... ,:?J ,; =-"'> c.~ l,(,~ ,.:::,;:-.::::;; "~ ,.JL., J~ ..,j, I::,;"'" ~',"",~,~' __,,,~,,.,__"~~, ,,~ J ^~ .."'"~' I ,'.. " ~,,,"- -" "~, "~" ,- ~~~.-""",ic!'"">JJ."""","",' . r . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HCR MANOR CARE, Plaintiff NO. 01-3294 vs. CIVIL ACTION - LAW JOYCE A. HEFFELBOWER, Individually, and ROBERT HEFFELBOWER, Individually, and on Behalf of JOYCE A. HEFFELBOWER, Defendants PLAINTIFF'S REPLY TO DEFENDANT ROBERT HEFFELBOWER'S NEW MATTER AND NOW, TO WIT, this;4 ~ay of October, 200 l,comes the Plaintiff, HCR Manor Care, by and through its attorney, Daniel F. Wolfson, Esquire, and the law firm of Wolfson & Associates, P.c., and files the following Reply to New Matter and in support thereof avers as follows: The allegations and averments contained within paragraphs One (1) through Twenty-Five (25) of the Plaintiff's Amended Complaint are incorporated herein by reference as if set forth in full. 26. Paragraph 26 of Defendant's Answer and New Matter is an incorporation paragraph to which no response is required. To the extent that a response is necessary, same is denied and the allegations contained in Plaintiff's Complaint are incorporated herein by reference as if set forth in full. 27. Denied. By way of further answer, Defendant Robert Heffelbower represented himself to be the Legal representative and! or Responsible Party for Defendant 1 -0 ~'" "~" - . 'L " _~ ,I.',~_ , -.......- h"'tJ",jj,_,,,",~s;j, Joyce Heffelbower, and in that capacity, on or about October 18, 1999, Defendant Robert Heffelbower executed an Admission Agreement, on behalf of Defendant Joyce Heffelbower, which Agreement outlined various terms of residential health care services to be provided by Plaintiff and the Responsible Party therefor. By executing said Admission Agreement, Defendant Robert Heffelbower did acknowledge that Plaintiff would be relying on the "Conditions", which are incorporated into the Admission Agreement in admitting the Patient, and that if Defendant Robert Heffelbower did not follow through with said Conditions, Plaintiff will have detrimentally relied upon said Conditions and Plaintiff would suffer financial harm and loss. That Paragraph four (4) of the Admission Agreement did describe the various responsibilities of Defendants, which responsibilities did include payment for the daily rate and charges for supplemental services, supplies not paid by any third party, as well as applicable co-insurance and deductibles and all expenses of discharge of transfer, and Paragraph five (5) ofthe Responsible Party Appointment, which was attached to the Admission Agreement, did describe Defendant Robert Heffelbower's responsibilities in compiling and completing applications for all third party payor programs, including but not limited to, Medicaid. The remaining allegations contained in Paragraph 27 of Defendant's Answer and New Matter are conclusions of law to which no response is required. To the extent that a response is necessary, same is denied and strict proof is demanded at trial. 28. Denied. It is specifically denied that Plaintiff represented to Defendant Robert Heffelbower that Defendant Robert Heffelbower would not be financially 2 ~>- '> '.."~ ~t<>."i,,,,,,,~,,,_,~{,,: responsible for any charges of any kind or nature whatsoever relative to Defendant Joyce Heffelbower. Therefore, same is denied and strict proof is demanded at trial. 29. Denied. It is specifically denied that Plaintiff at any time represented to Defendant Robert Heffelbower that Plaintiff would complete any and all third-party applications for all third-party payor programs, including Medicaid, as the completion of said applications is the direct responsibility of the Resident and the Resident's Legal Representative and/or Responsible Party, as detailed in the Admission Agreement which was signed and executed by Defendant Robert Heffelbower, and which is attached to Plaintiff's Amended Complaint as Exhibit "B". 30. Denied. It is specifically denied that any Statements of Account sent to Defendant Robert Heffelbower concerning Defendant Joyce Heffelbower conflicted in any way. As for the remainder of the allegation contained in Paragraph 30 of Defendant Robert Heffelbower's Answer and New Matter, after reasonable investigation, Plaintiff is without sufficient information or knowledge to form a belief as to the truth or veracity of this allegation. Therefore, same is denied and strict proof is demanded at trial. 31 . Denied. It is specifically denied that Plaintiff represented to Defendant Robert Heffelbower that no monies would be due and owing to Plaintiff or that all charges would be covered for Defendant Joyce Heffelbower's stay at Plaintiff's facility would be covered by Medicaid. 32. Admitted in part; denied in part. It is admitted only that Defendant Robert Heffelbower delivered a check to Plaintiff, as a payment on the account of Defendant Joyce 3 - ~ - '"" 'M ' -",,,,~,,,,,,,,,,,,-, Heffelbower, in the amount of$3,281.00. As for the remainder of the allegation contained in Paragraph 32 of Defendant Robert Heffelbower's Answer and New Matter, after reasonable investigation, Plaintiff is without sufficient information or knowledge to form a belief as to the truth or veracity of this allegation. Therefore, same is denied and strict proof is demanded at trial. 33. Denied. It is specifically denied that Plaintiff represented to Defendant Robert Heffelbower that after delivery of a check to Plaintiff that all charges relating to Defendant Joyce Heffelbower's account would be taken care of and that no further charges would accrue. It is also specifically denied that Plaintiff represented that it would complete and submit all necessary paperwork for Medicaid, as the completion of said applications is the direct responsibility of the Resident and the Resident's Legal Representative and/or Responsible Party, as detailed in the Admission Agreement which was signed and executed by Defendant Robert Heffelbower. 34. Denied. The allegations contained in paragraph 34 of Defendant Robert Heffelbower's Answer and New Matter are conclusions of law to which no response is required. To the extent that a response is necessary, same is denied and strict proof is demanded at trial. 35. Denied. The allegations contained in paragraph 35 of Defendant Robert Heffelbower's Answer and New Matter are conclusions of law to which no response is required. To the extent that a response is necessary, same is denied and strict proof is demanded at trial. By way of further answer, it is specifically denied that Plaintiff is 4 ~. -' l"">WA1"r,~,,!~i, i estopped from claiming any additional damages from Defendants as there was never any agreement between the parties that the check in the amount of $3,281.00, delivered by Defendant Robert Heffelbower to Plaintiff as a payment on the account of Defendant Joyce Heffelbower, would be a payment in full and final satisfaction the account balance due and owing by Defendants. 36. Denied. The allegations contained in paragraph 36 of Defendant Robert Heffelbower's Answer and New Matter are conclusions of law to which no response is required. To the extent that a response is necessary, same is denied and strict proof is demanded at trial. By way of further answer, the Admission Agreement, which is attached to Plaintiff's Amended Complaint as Exhibit "B", which was signed and executed by Defendant Robert Heffelbower is the writing which Plaintiff is utilizing to hold Defendant Robert Heffelbower liable, individually and on behalf of Defendant Joyce Heffelbower, for the account balance which is currently due and owing. 37. Denied. It is specifically denied that Plaintiff has not produced any writing in which Defendant Robert Heffelbower agreed to be financially responsible for the debt of Defendant Jouce Heffelbower. By way of further answer, the Admission Agreement, which is attached to Plaintiff's Amended Complaint as Exhibit "B", which was signed and executed by Defendant Robert Heffelbower is the writing which Plaintiff is utilizing to hold Defendant Robert Heffelbower liable, individually and on behalf of Defendant Joyce Heffelbower, for the account balance which is currently due and owing. 38. Denied. It is specifically denied that Plaintiff's Amended Complaint is barred , 5 ~, ~~ ...-J '~ ~i"<ili~ Ci.jllli&",~~ \. in any way by the Statute of Frauds as Plaintiff has produced a writing required in order to hold one liable for the debt of another. By way of further answer, the Admission Agreement, which is attached to Plaintiff's Amended Complaint as Exhibit "B", which was signed and executed by Defendant Robert Heffelbower is the writing which Plaintiff is utilizing to hold Defendant Robert Heffelbower liable, individually and on behalf of Defendant Joyce Heffelbower, for the account balance which is currently due and owing. 39. Admitted in part; denied in part. It is admitted that no services were rendered by Plaintiff to Robert Heffelbower individually. By way of further answer, Defendant Robert Heffelbower did in fact receive consideration for executing the Admission Agreement as the Legal Representative and/or Responsible Party for Defendant Joyce Heffelbower as Plaintiff rendered necessary residential health care services and health care treatment to Defendant Robert Heffeibower's mother, Defendant Joyce Heffelbower. 40. Denied. It is specifically denied that Plaintiff has no basis for the liability of Defendant Robert Heffelbower in the present matter. By way of further answer, the Admission Agreement, which is attached to Plaintiff's Amended Complaint as Exhibit "B", which was signed and executed by Defendant Robert Heffelbower is the writing which Plaintiff is utilizing to hold Defendant Robert Heffelbower liable, individually and on behalf of Defendant Joyce Heffelbower, for the account balance which is currently due and owing. Also, Defendant Robert Heffelbower did in fact receive consideration for executing the Admission Agreement as the Legal Representative and/or Responsible Party for Defendant Joyce Heffelbower as Plaintiff rendered necessary residential health care services and health 6 ;- , lM' ,~ ~,..,"",,,,,,,,,,,,",",.,' care treatment to Defendant Robert Heffelbower's mother, Defendant Joyce Heffelbower. 41. Denied. The allegations contained in paragraph 41 of Defendant Robert Heffelbower's Answer and New Matter are conclusions of law to which no response is required. To the extent that a response is necessary, same is denied and strict proof is demanded at trial. 42. Denied. The allegations contained in paragraph 42 of Defendant Robert Heffelbower's Answer and New Matter are conclusions of law to which no response is required. To the extent that a response is necessary, same is denied and strict proof is demanded at trial. By way of further answer, the Admission Agreement, which is attached to Plaintiff's Amended Complaint as Exhibit "B", which was signed and executed by Defendant Robert Heffelbower, specifically states in Paragraph of the Fee Schedule that, . . . "Should the Patient/Resident's account be turned over for collection to an attorney or collection agency, . . ., the Patient/Resident agrees to pay all court costs and reasonable attorney's fees of the Facility if the Facility prevails. 43. Denied. It is specifically denied that Plaintiff's Amended Complaint is barred in whole or in part by the applicable Statute of Limitations. 44. Denied. The allegations contained in paragraph 44 of Defendant Robert Heffelbower's Answer and New Matter are conclusions of law to which no response is required. To the extent that a response is necessary, same is denied and strict proof is demanded at trial. By way of further answer, the Admission Agreement, which is attached to Plaintiff's Amended Complaint as Exhibit "B", which was signed and executed by 7 " I "-, ,- '""..1i..L.-..'",,'" JI._ "'~i-, Defendant Robert Heffelbower is the writing which Plaintiff is utilizing to hold Defendant Robert Heffelbower liable, individually and on behalf of Defendant Joyce Heffelbower, for the account balance which is currently due and owing. Also, Defendant Robert Heffelbower did in fact receive consideration for executing the Admission Agreement as the Legal Representative and!or Responsible Party for Defendant Joyce Heffelbower as Plaintiff rendered necessary residential health care services and health care treatment to Defendant Robert Heffelbowers mother, Defendant Joyce Heffelbower. 45. Denied. The allegations contained in paragraph 45 of Defendant Robert Heffelbower's Answer and New Matter are conclusions of law to which no response is required. To the extent that a response is necessary, same is denied and strict proof is demanded at trial. By way of further answer Defendant Robert Heffelbower violated his fiduciary duty and responsibilities as the Legal Representative and! or Responsible Party for Defendant Joyce Heffelbower by not utilizing Defendant Joyce Heffelbower's finances to pay Plaintiff when she knew or should have known there were outstanding medical care bills for Defendant Joyce Heffelbower, and therefore Plaintiff detrimentally relied on Defendant Robert Heffelbower following through with the aforementioned Conditions. Also, the finances of Defendant Joyce Heffelbower should have been utilized to pay Plaintiff for her necessary and appropriate medical services and treatment rendered by Plaintiff to Defendant Joyce Heffelbower, but Defendant Robert Heffelbower failed to use Defendant Joyce Heffelbower's finances for that purpose, and therefore Plaintiff detrimentally relied on Defendant Robert Heffelbower following through with the aforementioned Conditions.4 8 ~, "f _ ." , .'~" ~" 46. Denied. It is specifically denied that Plaintiff's Amended Complaint is barred in any way by the doctrines of novation and/or accord and satisfaction. 47. Denied. It is specifically denied that Plaintiff's Amended Complaint is barred in any way by the doctrine of consent. 48. Denied. It is specifically denied that Plaintiff's Amended Complaint is barred in any way by the doctrines of estoppel, laches and/or waiver. 49. Denied. The allegations contained in paragraph 49 of Defendant Robert Heffelbower's Answer and New Matter are conclusions of law to which no response is required. To the extent that a response is necessary, same is denied and strict proof is demanded at trial. By way of further answer, Defendant Robert Heffelbower did in fact receive consideration for executing the Admission Agreement as the Legal Representative and/or Responsible Party for Defendant Joyce Heffelbower as Plaintiff rendered necessary residential health care services and health care treatment to Defendant Robert Heffelbower's mother, Defendant Joyce Heffelbower. 50. Denied. It is specifically denied that Plaintiff's Amended Complaint is barred in any way by the doctrine of failure of consideration. S!. Denied. It is specifically denied that Plaintiff's Amended Complaint is barred in any way by the doctrine of impossibility of performance. 52. Denied. It is specifically denied that Plaintiff's Amended Complaint is barred in any way by the doctrine of consideration. 53. Denied. It is specifically denied that Plaintiff's Amended Complaint is barred 9 ..:-~ ,.', -J.i~ --~~' ~~'" """...~~_-""'X in any way by the doctrines of payment and/or release. 54. Denied. As previously stated, it is specifically denied that Plaintiff's Amended Complaint is barred in any way by the doctrines of payment and/or release. 55. Denied. It is specifically denied that Plaintiff's Amended Complaint is barred in any way by the doctrines of contributory and/or comparative negligence, and/or by Plaintiff's assumption of the risk. 56. Denied. The allegations contained in paragraph 56 of Defendant Robert Heffelbower's Answer and New Matter are conclusions of law to which no response is required. To the extent that a response is necessary, same is denied and strict proof is demanded at trial. WHEREFORE, Plaintiff respectfully requests that this Honorable Court dismiss Defendant Robert Heffelbower's New Matter and enter judgment in favor of Plaintiff and against Defendants, along with the allowable costs of this action, and such further relief as the Court deems appropriate. Respectfully submitted, aniel F. Wolfson, Esquire WOLFSON & ASSOCIATES, P.c. 267 East Market Street York, PA 17403 (717) 846.1252 J.D. No. 20617 Attorney for Plaintiff 10 '" ~ -, ~ ......,. ......-,;~'"r""~~ VERIFICATION Daniel F. Wolfson, Esquire, hereby states that he is the attorney for the Plaintiff, HCR Manor Care, and he is authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Reply to New Matter are true and correct to the best of his knowledge, information, and belief, based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: /~/zl/o! Daniel F. Wolfson, Esquire WOLFSON & ASSOCIAT 267 East Market Street York, PA 17403 (717) 846.1252 ID No. 20617 Attorney for Plaintiff , '- , ~ ~ ~ -~ "-;i<!,""!-X~,",il1i'''__," IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HCR MANOR CARE, Plaintiff NO. 01-3294 vs. CIVIL ACTION - LAW JOYCE A. HEFFELBOWER, Individually, and ROBERT HEFFELBOWER, Individually, and on Behalf of JOYCE A. HEFFELBOWER, Defendants CERTIFICATE OF SERVICE AND NOW, this dfl;;y of October, 2001, I, Daniel F. Wolfson, Esquire, do hereby certify that I have served a copy of the foregoing Reply to New Matter upon the parties and/or counsel of record in the following manner and addressed as follows: CERTIFIED MAIL RETURN RECEIPT REQUESTED REGULAR MAIL POSTAGE PRE-PAID Mr. Robert Heffelbower 258 West North Street Carlisle, PA 17013 (Pro Se Defendant) Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (Counsel for Defendant, Joyce Heffelbower) Daniel F. Wolfson, Esquire WOLFSON & ASSOCIA T 267 East Market Street York, PA 17403 (717) 846.1252 ID No. 2061 7 Attorney for Plaintiff ~~1Nt;t;$4irkl'ii!\~'W,-~%!iIi!;1!i\M!;iil:1~~j"";t;r~,f-.;;,.;,iri!1;""@rl>R';,;r"f';! ,,~,""~'.; \';;'~\~,"')}'w!@bm,~':~ill#,.-'--~~&iIl~~~il.' .-." :1 0?tt ," '" _ ~ ~" _0 <~"_ .'< _~N~__~~',= - ,~ "0 .._~" '_0.<, ~" , ,_ ~,. <., ,.C.~ __~ ,- e""_.,,_'.< - "." O~ . o c 5~ ci;F~:' ,~_:J._! ~f:i zC) ~c! ;' c: z =< ", , ~- C) -n :"':,J ',,") ----I -,--:< ;8 , .; (~') !~-~;~ ;;~~ ~i':.n ~.' ~ ::0 -< ~, :"'-~) C' ~n :1;'- :0 (J1 (fl ~~ ~ -, . .......- ...... =' i--" '" -'. .-J"'''''"''~!lol,),.;m.tiN .. , .i'lo " , ;r--,h' . " ,,,,, ., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HCR MANOR CARE, Plaintiff NO. 01-3294 vs. CIVIL ACTION - LAW JOYCE A. HEFFELBOWER, Individually, ! and ROBERT HEFFELBOWER, Individually, . and on Behalf of JOYCE A. HEFFELBOWER, 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 tiling 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 importalll 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 hall 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 notitiation. 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 detienda, la corte tomara medidas y psedido entrar una orden contra used sin previo aviso 0 notiticacion 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. 51 NO T1ENE ABOGADO 0 SI NO TIENE EL DINERO SUFFICIENTE DE PAGAR TAL SERVICIO V A Y A EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CON5EGUIR i ASSIT ANClA LEGAL. Lawyer Referral Service of the Cumberland County Bar Association 2 liberty Avenue Carlisle, Pennsylvania 1 7013 (717) 249.3166 Ii ~~'1j'- { . t, '. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ! HCR MANOR CARE, Plaintiff NO. 01-3294 vs. CIVIL ACTION - LAW JOYCE A. HEFFELBOWER, Individually, and ROBERT HEFFELBOWER, Individually, and on Behalf of JOYCE A. HEFFELBOWER, Defendants AMENDED COMPLAINT AND NOW, this 29th day of August, 2001, comes the Plaintiff, HCR Manor Care, by and through its attorney, Daniel F. Wolfson, Esquire and the law firm of Wolfson & Associates, P.c., and files the within Amended Complaint and in support avers as follows: I. Plaintiff, HCR Manor Care, is a health care provider qualified to conduct business in the Commonwealth of Pennsylvania with offices and/or a place of business situate at 940 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant, Joyce A. Heffelbower, is an adult individual with a current mailing address of 940 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. Defendant, Robert Heffelbower, is an adult individual with a last known address of 258 West North Street, Carlisle, Cumberland County, Pennsylvania, 17013. 4. That a Complaint was filed in this matter on or about May 30, 2001. -... "',,--- "~','.~-." "j'~ , . ., .' " 5. That Defendant Robert Heffelbower filed Preliminary Objections to said Complaint on or about August 3, 200 I, and Defendant Joyce Heffelbower filed Preliminary Objections to said Complaint on or about August 21, 2001. 6. That the within Amended Complaint attempts to cure both sets of Preliminary Objections filed by the Defendants in this matter. 7. That Defendant Robert Heffelbower represented himself to be the legal representative and/or Responsible Party for Defendant Joyce Heffelbower. Defendant , Robert Heffelbower is the son of Defendant Joyce Heffelbower. ',.,'1 'I, 8. That on or about October 18, 1999, through the present, Defendant ;1, ii II Robert Heffelbower was a health care resident of Plaintiff, where she did receive various q i! necessary residential health care services and health care treatment by Plaintiff. An 1': I' I 'itemization of said services is attached hereto, incorporated herein and marked as Exhibit I "A". , I 9. That on or about October 18, 1999, Defendant Robert Heffelbower executed an Admission Agreement, on behalf of Defendant Joyce Heffelbower, which Agreement outlined various terms of residential health care services to be provided by Plaintiff and the Responsible Party therefor. A true and correct copy of the Admission Agreement including addendums is attached hereto, incorporated herein, and collectively marked as Exhibit "B". 1 O. That by executing said Admission Agreement, Defendant Robert Heffelbower did acknowledge that Plaintiff would be relying on the "Conditions", which are incorporated into the Admission Agreement in admitting the Patient, and that if Defendant 2 .".pMl!&c"J - L , .. .' ., I, Robert Heffelbower did not follow through with said Conditions, Plaintiff will have I ! detrimentally relied upon said Conditions and Plaintiff would suffer financial harm and loss. See Exhibit "B" as previously identified and incorporated herein. I I. That Paragraph four (4) of the Admission Agreement did describe the various responsibilities of Defendants, which responsibilities did include payment for the daily rate and charges for supplemental services, supplies not paid by any third party, as well as applicable co-insurance and deductibles and all expenses of discharge of transfer. See Exhibit "B" as previously identified and incorporated herein. 12. That Paragraph five (5) ofthe Responsible Party Appointment, which was attached to the Admission Agreement, did describe Defendant Robert Heffelbower's responsibilities in compiling and completing applications for all third party payor programs, including but not limited to, Medicaid. See Exhibit "B" as previously identified and incorporated herein. I 3. That Plaintiff submitted to Defendants a copy of the itemization of services accurately showing all debits and credits for transactions with Plaintiff. 14. That Defendants did not object to the above mentioned Statement of Accounts submitted by Plaintiff to Defendants. 15. As of the date of the within Complaint, the balance due, owing and unpaid on Defendant Joyce Heffelbower's account as a result of said charges, is the sum of Twenty-Nine Thousand Three Hundred Six and 07/1 00 Dollars ($29,306.07). See Exhibit"A" as previously identified and incorporated herein. II 3 II ',-=,-,.';;., "~, "' '"' .. . . 16. 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 Defendant Joyce Heffelbower's account balance, all to the damage and detriment of the Plaintiff. 17. Plaintiff has made numerous requests to Defendant Robert Heffelbower, as the Legal Representative and/or Responsible Party for Defendant Joyce Heffelbower, demanding that the sums due and owing to Plaintiff be paid, and Defendant Robert Heffelbower, as the Legal Representative and/or Responsible Party for Defendant Joyce Heffelbower, has ignored his fiduciary obligation to pay necessary and appropriate bills and obligations for his mother, Defendant Joyce Heffelbower, or to apply for Medicaid on behalf of his mother, Defendant Joyce Heffelbower. 18. That Defendant Robert Heffelbower violated his fiduciary duty and responsibilities as the Legal Representative and/or Responsible Party for Defendant Joyce Heffelbower by not utilizing Defendant Joyce Heffelbower's finances to pay Plaintiff when she knew or should have known there were outstanding medical care bills for Defendant Joyce Heffelbower, and therefore Plaintiff detrimentally relied on Defendant Robert Heffelbower following through with the aforementioned Conditions. 1 9. That the finances of Defendant Joyce Heffelbower should have been utilized to pay Plaintiff for her necessary and appropriate medical services and treatment rendered by Plaintiff to Defendant Joyce Heffelbower, but Defendant Robert Heffelbower failed to use Defendant Joyce Heffelbower's finances for that purpose, and therefore Plaintiff detrimentally relied on Defendant Robert Heffelbower following through with the aforementioned Conditions. II 4 II 1111 Ii"""...... . ^ ='~'~"'~- ",,-~- '" ' .l;'--"'~'''-'''''~,~,~,n , . . I" .. 20. Plaintiff has retained the services of the law firm of Wolfson & Associates I P.c., in the collection of the amounts due from Defendants. 21. Pursuant to Paragraph 8 of the Fee Schedule, which is attached as part of the I ! Admission Agreement, Plaintiff is entitled to receive and Defendants have agreed to pay all court costs, reasonable attorney's fees, and contractual interest if the account is referred over to an attorney for collection. See Exhibit "8" as previously identified and incorporated herein. 22. As of the filing of this Complaint, Plaintiff has incurred reasonable attorneys . i fees from the law office of Wolfson & Associates, P .c., in the collection of the 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 in the amount of thirty percent (30%) of the principal balance due and owing to the Plaintiff by the Defendants. 23. The amount of attorney's fees which represents thirty percent (30%) of the principal amount due and owing is the sum of Eight Thousand Seven Hundred Ninety-One and 82/100 Dollars ($8,791.82). 24. Any and all conditions precedent to the bringing of this action have been performed by Plaintiff. 25. The amount in controversy exceeds the jurisdictional amount requiring compulsory arbitration. 5 II '"---~""=-~ , " J~ , ". -- j" -='>:~-~ "-, i,'n-_~~;;i.,'. - , .I> ,. " WHEREFORE, Plaintiff, HCR Manor Care, respectfully requests this Honorable Court enter judgment in favor of Plaintiff and against Defendants, Joyce A. Heffelbower, Individually, and Robert Heffelbower, Individually and on Behalf of Joyce A. Heffelbower, in the amount of Twenty-Nine Thousand Three Hundred Six and 07/100 Dollars ($29,306.07), reasonable attorney's fees in the amount of Eight Thousand Seven Hundred Ninety-One and 82/1 00 Dollars ($8,791.82), the costs of this action, and Stich other relief as the Court deems proper and just. Respectfully Submitted, Daniel F. Wolfson, Esquire WOLFSON & ASSOCIA T 267 East Market Street York, PA 17403 (717) 846-1252 I.D. No. 20617 Attorney for Plaintiff I , I 6 , !~I~c): , J VERI FICA TION Daniel F. Wolfson, Esquire, hereby states that he is the attorney for the Plaintiff, HCR Manor Care, and he is authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Amended Complaint are true and correct to the best of his knowledge, information, and belief, based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: ~/2 ~/fJI I I Daniel F. Wolfson, Esquire WOLFSON & ASSOCIA T 267 East Market Street York, PA 17403 (717) 846-1252 ID No. 2061 7 Attorney for Plaintiff il ..' 01 EXHIBIT "A" ,,".--,"'h~' - ~ - .,",.~. _' ,0..:.' , , _1- -'~ - ""';~,:i HCR..Ma.UorCare Stater-hent , " MANORCARE CARLISLE 372 ,940 WALNUT BOTTOM ROAD CARLISLE, PA 17013 (717)-249-0085 ROBERT HEFFELBOWER fOR JOYCE HEFFELBOWER 258 W. NORTH STREET APT 2 CARLISLE, PA 17013 t'lEDICAID PRIVATE ROOM 119 -A Please Return This Portion \\lith Your Payment I' HEFFLEBOWER, JOYCE A 99116 01/26/00 01/31/01 i , . i~~:i,1 ~c, t :,,,,. ",w,::;;:,",:o~~...... . ... J... ~:~::;::, i.. .~:,;::. ..1 (H /01/01 11900 MCB PREtnUM (QrY 1-) 50.0 02(01(01 AOV PVT PORTION 515.32 ~ 08(31/00 ADJ RVS COINS 8-00 48.9 09/30/00 ADJ RVS COINS 9-00 48.9 10/31/00 ADJ RVS COINS 10-00 37.5~ , , PAYMENT DUE BY THE 10TH OF THE MONTH /' / ./ ,r!' "I 29,3136.0 AMOUNT DUE ~>- "L ~~ ,-- ,-, ~',. .- . , GGI8Glli RESl8EiIT LEDGER ~, lJ ~ WE OF fIRS! mIvm pm iAR561 RESIDHT RESIDE::; f,ESIDElP OIL ACCDum RECEIVABLE IIU!BER TYPE ~I A ~ E DW CTY ACCOUln CHARGES cmITS BALANCE SSllG HDIcm HEfFllSOWlR, meE h 1111\111 m cm. 8m: 1.18 RDO~ 1lS -A LEVEl 2 OIS P8IV PORT : 534,81 "PRIVI.Tr - Aue 18 ~IH ;,,..' - " '-J', -~v ~, -" L~'" ~ 7BBUI 375 5.U I 3BBUI 376UI 1366B.79 31954.79 PAH:r:T 88!1C loe II1100C1ceo 3181.00 18106 PT I CG-IIIS LAB-GLUCOSE ! 08/81{88 1.75 11m C~BLE RtllHl 08111181 i 59l58mm 5.08 1010B " I C 0 - I1~ S lAB-GLUCOSE N 8B/81/00 1 1.75 ' , 1mB PT 8 CHI!S LAB-GLUCOSE r- OBICl101 1 1.75 1 ~ 2 0 t F' E CG-I1lS LAB-GLUCOSE :i o 8/0 ~ /0 {\ 1 1.75 1010B PI B CO-I1iS LAB-GLUCOSE N OB{05/CC 1 1.75 10106 PT 6 CO-IllS LAB-GLUCOSE N 3B!HIDC , 1.75 , lOW t.' , CG- UiS lAB.GlUCOSE r- 061Ci/Ol 1 1.75 " , 11m ?: 5 ce-INS LAB-GlUmE I 18118111 2 1.7\ Wit Pi [ C G -lt~ S LAHlUCOSE r, 08/01!" , 1. 7 5 10m " 8 CHiS lAHlUCDSE ~ 08/llt10 ^ U\ " Jom , f [['-HS LH,-HUCOSf. . 08 Ii 1i 0, ' 'C " l.IJ WOE Pi E CO-HIS LAHLUCOIE . CB/ll/~O 1.75 ,'; WOE ~. "': E CC - I I~ S L H:-Gt U[ OSE r- OB/l3!CO " 1. 75 , H20E Pi E Cu-INS LA8-GlUCOSE ~ 1E/14/" 1 Ll5 11218 ?i 5 ttl-HS l~8-mlDSE ~ IBI15/H 1 1.15 JIm Pi 6 C {i - l ~; S lAHLUCOSE ,~ 15/16/11 " LIS lG2Ct r'i Cl-l!;S "HeUe')5E . CE I' 17 r~c i U\ , ,. 102~ t. Pi 5 CG-UIS ~ A B-u l U [oS[ , 03/18/0 r: 1 US " 1m, PT 5 CO-I1iS LAB-GLUCOSE r- OS/B!OO ^ U\ 11101 P' , CG-IN$ l~e-6lUCOSE . 1i!11/01 1 1.75 , " lC2CE PT E CO-INS LAHl,COS, r- C8/11/00 1 US 102~f PT 5 CO-IllS ,AHlUlOS, . 08n2/0(~ 1 U5 " 10138 p'7 , CO-H~S L~8-6lUCOSE ~ ~ 8 ! 13/ 0 0 1 .87 , l~nt f: CG-U;S L~e-HtlCQSt ii ~8 {2 4 {C ~ , 1.75 11105 Pi , eu-!:i5 lAB-GlUCOSE . 08/25./(\(: 1.75 " 10106 Pi CO-!:l5 l~B-GLUeOSE ~ 0Bf26f00 , ,87 10106 PI 8 co-m LAB-GLUCOSE ~ 18{17/10 1 U5 11m p' I CO-}:l$ lAS-GLUCOSE , 18/28/10 2 Ll5 , , " lcn~ P1 , CO-INS l~HLueO\t r. 08/2l/Cl' 1 ,37 WOt Pi 8 CO-i:!S U,B-GLUCOSE ~ C6/30/00 ,87 1.['1 l ~Ii r,o Re 051111'0 \311111I11I 3m.1I PRIVATE PORTIOEI 18/~1/10 -- IB/31/11 31 468.00 AOV ?VT pomol: 09/011C8 13111 iIO m 468.10 HEtlOING BALANCE 26788.77 "NEOlCAIO - AUG 00 ROO~ CHARGE AT 13LCC u8!CJfCI -- i8/3 m 31 51350102101 416L11 ROO~ fiRm OFf IE/ll/10 -- 18/3 {IC 31 5155711210C 685-71 DtDm PV1 mi 18}Cl}II -- 18/3 III 31 46UI HE~J~HiG BAt A ~i C r 1907.26 ur,lUlCI,H , - I\UG 00 " -~:; eS/C8/Cl RESIoEln lEDGER A~ OF oAE OF FIRST ~~TJVITY PAGE IAR8B) RESIoEliT RESIoEl;; R:SlDu:; G/L -- ACCOUNTS RECEIVABLE mBER TYPE ;lAlE om OT\' ACCOUIIT CHARGES CREDITS BALAIICE S9ilB HoJCAE ~ E ff l E BOWER. JOY E A CJ/2f Ice AOr. CnARAl[: UO : 00~ ~ 19 -t. LE tL , C ~ s pm PORT: 534,f,2 "r.rOIC,FE i - AUB 6e (con BAl f~JO -LiI- -30- -60- -9~- -120+- 82B3.34 82B3.34 -"U;DING BAlA::C[ 82B3.34 ur,EDlCAkE i; - AUG eo 10m cAi-GLUCOSE !ONITORlilG OB 101lC0 56151S1l20C B.7A 10m FT E CO-illS LAB-GLUCOSE ,j OB/Ol/oe 1.78 10m L~~-~lUCOSE t,C~IT~RI~G 081nloe SblS1 g'J.120t 8.1' H2~~ (i : ~D-I;b LAB-bLUC0~i , lib! ~" ill i: L/5 10m LAHEUCOSE ~OfiITORH~G OBje3m 86181911200 B.74 101" Pi: CO-I:I$ LAB-GlUCOSE ~ OB fe31C, 1.78 lem LIlF-ulUCOSE miTOmG 08/04/ee 5615191120C 8.74 WOE Pi E CO-IllS LAB-GLUCOSE l OB/04/0t 1.75 lC2ef cAHlUCOSE !OI:ITORJI:b 08/e5/oc 86151911100 8.74 10m ~ 1 : CO- III S l,HLUCOSE l OS/G5111 1.75 meB ~At.GlUCOSE r.oriIiORHG edeem 56l519112ec 8.7A 1000E PT E CO-IllS LAB-GLUCOSE " 0B/05/00 !.i5 " lC20f ;.A[:-GlUCOSE r,OIlITORgG CSle7/oe 5615191110C B.74 102ct. ,o! : CG ~ 1:1 S lA5-GLUCGSE , 08/07/80 1.15 " 101es l"-GLUCOSE !omomG eBleB/eo 56l51S111OC B.), 10m " E co-m LAHLUCOSE ~ OBjOSlni 1. 75 H2et ~~~-~lU~CSt r,OI:ITORJI:b ~q~s I~( 5G151911m B.lI 10m ,- . C 0 - I ~1 S lAB-GLUCOSE ~ 08/09100 1.75 rl: 10m c.~ t, - ':; ~ U C fJ S E !OI:mRlliO 06/IC/eo 56181S112CC B.7A 1010t n f CO-INS LAB-GlUCOSE ~ OS lie /00 1.75 wee LA?'-~LlICOSE mmRJliG OB/ll!ee 8615191120e B.74 102H p;, co-m LAS-GlUtOSE , 08/11/00 1.75 " mOl :.Af<~!JCllSE !Oi:mmG Call2jer 861519il2CC 8.74 1010B ~ i : C Q- I:i S lAB-GLUCOSE l 08/12 fQe 1.75 lenE. ,AE-!;lUtOSE r.OtaiORHG oBIl3iee 1 561519l12ee B.74 10108 ~'7 :' CD -1;i S LAB-GLUCOSE ,1 08/U/OC 2 1.75 10m lAS-GLUCOSE ~O~ITORING OB(14/00 2 56l519112CC U4 1020,: n E CO-L'IS ,AHLUCOSE " 0e/l~!00 1 1.75 " 1020B lH-GlUCOSE ~omOR!l:G 08fl5fOC 56181911200 8.74 102~2 Pi E CO-INS LH-SLUCOSE ~ 08!15/09 1.75 10m iAhlUCOSE ~omORllil OB116/~e " 80181911200 B.74 , 10m PI E CO-JiIS LAHlUCOSE ,\ 0B/16/00 1 1.75 10208 LAI-GLUCOSE !omOR!l:G OB/17/09 56151911101 8. 7 ~ 1mB Pi I CG-IIIS l,0-I1UCD5E ~ 00/11100 1.15 18208 L0HLUCOSE !omOR!l:G 08/1Bice 2 56151911100 8.74 10108 PT S CO-HIS LAB-GLUCOSE " OB/IB/OO 1 1.75 ,I 10m LA~-GLUCOSE !OllmR!l:I IB/19/eo 2 56151911100 8.7. 1020B PT E CO-INS LAB-GLUCOSE ~ IB/19/OO 1.75 102eB LAB-GlUCOSE ~omom6 08/2e /00 "15191110e B.7. 10m PT E CO-niS lAHLUCOSE ,\ OB/l0/90 1.75 10m l~I-6lUEISE !IUll0Rlili tBI21111 2 5\181911210 B.14 10108 PT E CO-HIS LAB-GLUCOSE ! OB/l1/00 2 1.75 ",'., ~'~~ -,' ""';"'~lii'~, RESIDEI:1 lEDGER R~ 0' DATE Of fIRST RC1JVm PAGE GIL -- ACCDUm RECEIVABLE DATE O'l'\-, ACCDUill CHARGES CREDITS BALANCE " ~' I ^,.- I t,,-, ' ~. ~ .'Tf r, ~ '[' r -, ~ r. VIS PRIV PORT: 53U2 C8/22.!CC 56H191120C 8,74 18122181 1.75 CSj23iCC 561519112ce U7 OB/23}00 .87 s811we S61S1911m 8.74 08/24/00 1.75 08/25/08 SG1S1911100 8.74 08/2S/8S 1.75 88/26/08 56151911208 U7 88/2U0t: 1 .87 8B/27/08 1 50151911280 B.74 88/27 180 2 1.75 88128/88 2 56151911200 B.74 B8/28/81 , 1.75 18m/It , S&15191l2~t ~.3i 88/29/88 .87 08/3U8C 561519112CC C37 8B/38/88 .Bl 195.74 SB/OB/Sl IAA56) RESIDENT RESIDE~l mBER TYPE RESIOEI;T I~ A ~ E -,,:1; "rr'Tr~-. ..:~~-:t'~ll("~, or,''"; . ~0D~ liS -A lEVtL ~ "IEDICAI, E - AUG 88 ICDIT! 1828B LAE-ElUCDSE 10lITOllli 11218 PT E CO-1NS LAS-GLUCOSE ~ lC2CE LAS-GLutOSE ~O~ITORING 1128S PT, CO-Ins lA8-GLUiOSE : 11216 LAB-GLUCOSE !OlITDRIlG 18116 PI, CO-liS LAB-GLUCOS, N 1021B LAS-GLUCOSE !OlITOAIIO 18288 PT, CO-Ins lAB-GLUCOSE! 18208 lAS-ElUCOSE !DIITORIIE 10106 PT R CO-1NS LAB-GLUCOSE ! 1828S lAE-GLUCOSE NOIITOAl16 18200 PT E CO-1NS LAB-GLUCOSE! 11206 lAS-OlUCOS! !OIITORII, 18186 PT R CO-1NS LAB-ClUCOSE ! 11216 LAI-GlICOSE 1011TOR]IG 18188 PT E CO-Ins lAS-GLUCOSE! 1020S LAB-GLUCOSE 101lTORIIG 18208 PT, CO-Ins LAO-GlUCGS, ~ ~~E~GING BAlA~CE "PRlvAT, - SEP 00 8ri~ ~;~D -Lr.- ~3C- 989.91 .ClU0 18101 Pi, CO-liS LA8-GLUCOSE N 10288 PT 1 CO-Ins lA8-ClUCOS, ! lC2C8 Pi [ Cv-I~S LAB-GlUCuSE r. lC2~B PT f :O-INS LAB-GLUCOSE M lC2C? Pi t CO-INS LAB-GLUCOSE ~ lC2CB Pi f :O-INS lAS-GLUCOSE ~ 18206 'T, CO-liS lAS-OLUeOS, N 18288 Pi E CO-lnS LA6-GLUCDSE ! 10210 PT 1 CD-1r.S lAO-GLUCOSE I 102Ct PT E CG-INS LAE-GLUCOSE ~ 18218 PT E CO-IRS LAB-GlUiOSE I 1811S PI I CI-1IS LAB-BLUCDS! I 10288 PT E iO-IIS LRS-GLUCOSE N 18218 PT 8 CO-liS LA8-GLOCOSE ! 11188 PI BCD-lIS LA8-GLUCOSE I 1118S PT e CO-Ins LA8-GlUCOSE I 18218 PT B iO-IIS LA8-GLUCDSE I 1828S PT E CO-lIS LAS-GLUCOSE! 11218 PT BCD-INS LA8-CLUCOSE ~ 11108 PT 0 CO-liS LAB-Clucose I 1828S PI B CO-lIS LAS-GLUCOSE! 1810S PT S CG-1IS LAS-GlUCOSE! 11288 PT S CO-IRS LA8-GLUCOSE I 10288 PT 1 CD-liS LAB-GlUCOSe I -58- -ge- 3755.01 388S.88 19/81/18 89/82/88 89183/81 o 9 /05 ! 0~ 09/05/C(: 89/85/01' 19/17111 19/8S/80 89)19181 cg/1u~e 89/11/10 19}12}11 89/13/11 89/1'/88 19115 Ice 89/H/II 89/17/88 19/18/80 19/19/81 19f10 /80 89/11}81 09/21/01 19/23/88 89/1./88 -12u+- H1Si,79 2 , , , 2 5 2 1 2 2 ...~ ~""'" ""-~'~ .. 26788.77 1.75 1.75 1.75 1.75 1. i 5 1.75 1.75 1.75 1.75 1.75 1.75 1.75 2.62 1.75 l.n 1.75 U7 1.75 1.75 US 1.75 .87 1.75 1.75 0610S/81 iAR56) IESIDENT RESIDEii NUMSER TYPE ,,:~lOUi'l ~~ A ~ E ~ 9 jj 6 PA\'i::iT t~f~~IRG BAlA~CE .*~EDICARE & . SEF ~C B A ~ '" l' - l i. - 1 ~ ~. 74 i828S LA,-, uCOSE ~ONITORIIIG 10288 PT, C-!~S LA8-GLUCOSE ~ 10288 LA8-, VCOSE ~ONITORIIIG 11288 PT EO-IllS lAS-GLUCOSE M 11208 LAE-, VCOSE !OIlITORIIIO 11201 PT i 0-115 LAI-GLUCOSE II lC208 LAE-~ UCUS~ ~O~ITOP,ING 18208 lA8-, UCOSE ~811ITORIIG 18208 PT i O-IIS LAB-GLUCOSE! 11208 11 EO-INS lAi-GLUCOSE ! 11218 lAE-i UCOSE tOllllORINO 10218 PT 8 0-1115 LA8-GLUCOSE II 10211 LAB-o UCOSE tOlllTORIIIG 10288 PI EO-IllS LAS-GLUCOSE II 11218 LAB-G uceSE MOIITORIIIG 11208 PI 8 O-IIS LA8-GLUCOSE II 11218 lAS-o UCOSE tOlllTOIIIIO RESIOEIIT LEOOEI AS OF DATE Of 'IRST ACTIVITY " PAOE i" -- ACCOUIITS RECEIVABLE DATE QTY ACCOUliT CHARGES CREDITS BALANCE OJ/:C / C C AO~ DIS OS/25/DO IS/26/OO OS/27/IO OS/Ol/ID OS/01/00 -- DS/3D/OO 38 11{IIIDI -31- -60- -S0- r.EDICI:H <~~lEGGI';E~, JOVe( A RDO~ lIS -A LEVEL 2 "PRIVATE - SEP 10 iCOllll 10208 PT LD-IIIS LAi-GLUCOSE I 1120S PI CD-IlS LAB-GLUCOSE N 1020, PT, CD-I~S liB-GLUCOSE" REV LAST 110 PP Hl"';TE PQUIOr; AOV 'VI PORTIOII **E~:ING BALANCE >'0E01~h:~ ~ ~t; ~~ SAl FWD -L~- 2907.2E 2SDOl PHH;,ACi ,EUEI:D 19/01/10 -- D9/30/DC 2900! PHAR~ACY LEmo 19/11/11 -- 19/30/80 31001 PHWlCi ::01: lEGE~O 19/01/10 -- 09/30/80 30001 PHARNACY 101 LEGEND 09/11/10 -- 19/31110 AIIC:.,RR' WRITE Off DSI3D/DC ROO! CHARGE AT 131,00 OS/0 /01 -- OS/30/10 3; RW WIT;' Off DS/O /00 -- oS13e/00 38 OEOe: 1 P\'T PORi 09/0 /00 -- OS /30/10 3e ~'E~~;~t ~ALA~[: '~~EDICA?-c ~ - 3Ef G~ SA l :;i[: - L ~- -36- -6C- -~~- 69/2610e -30- -GO- -9c- 89/01/00 09/01/00 09/02/00 19/02/10 19/03(Oe 09/13{00 09/CSm 09/15/10 19/05/00 19115jOO 09/16/00 09/0G/00 19/07/00 19{0711D D9/0S/00 09{D8/01 19/IS/8D C~TR RATE: 0.00 PRIV 10RT: 534.S2 2 1 13211001010 1.75 US .17 HUD 13211001010 ,68.01 -12It- 2917.18 5~551n22Ce 54551202200 29G2.0S 5495130220, 54951312281 7.95 57557502208 51351082210 3931.10 51SSir.r,2n~ -12e"!'- 5282.34 5283.34 l1mloml -120.- 56H19112C{: .. 56151911200 2 . 561S1S112ce i 561SJ.91i2tC 56151911210 2 2 561519112eC 1 2561519112DC 561519112CC 5G1519112DC 195.14 8.ii I.il B.ll 8.ii 8,7G 8.i4 8.i, 8.7i 8.74 468.01 208.39 1.89 275S.n 663 .6e HUO 2591.40 2i315.75 5 7C5, ~s 2691.9. 1.75 1.75 1.75 1.75 1.75 1.75 1.75 1.75 ~""-~' "~ - "-'-.';;' -'-- - ~-' .~~[-, '-'- .>' 08/08101 RESIDENT mGEF AS OF DATE OF FIRST ACTIVITY PAGE (AR561 ,"S10Elil RESIDEI\T RESluti:: 61l -- ReCOUNTS RECElVABlE mm TYPE II AJ~ E OW DiY ACCOUIIT CHARGES CREDITS BAlAilCE S9116 ~EDlCAlC ~ ~ f F L E B 0 l~ E fi . ,10 \'l: ~ , C 1 ;:' ~ i e t A o~ em RATE: UB ., "OO~ 119 -A lEVEL 2 DIS PRIV PORT, 534.82 "H Dlt ARt B - m BI I (.Oi:1! 1C2CZ Pi 8 CO-ltiS lAHlUCOst ., B9/0S118 us 10m lAHlUCOSE ~ o lIlT 0 R IIIG 19/10 Iii S61S191l2i8 8.74 HitS " f CO-IllS lAf.-GLCCOSE ~ is llt iDC 2 US " 10208 IAHlUCOSE !OIliTORIIIC 09111/08 2 56151911200 6.74 11m Pi B CQ-It:S lAHlUCOSE ~ 19I11/IC 2 1. 75 10106 lAHlUCISE !IIIITORIIIG 09/11/00 2 5615191120C S. 7~ 18m Pi ; CO-IllS lRHlum: r C9lilliC , 1.75 l~,~t di:-,,~i,;~u~E ;'lUiij"iunl,lu O/LI~" ~ 50151S~1~~C ~~ d. 11218 PT [ CO-IllS IA8-6lUCISE ~ 19/13/01 3 2.62 lmS lAHlUCOsE ~O!nTORING G 9 f l~ f 0 C 1 561519111Ia UP lC2li ~ i , CO-!I:S lAH,UlOSf r, 191" / tt 1.75 lim lAHlUCISE !IIIITDRriIG 09/15/00 2 56151911200 8.74 18m PT 5 CG-!I:S lAB-GLUCOSE r tSjlSjCC 2 1.75 1020E lAHlUCOS[ M DIIITO R I ~j G 19/W00 , 5615191121i 8. ); 11208 Pi CO-HIS IAB-HUlISE . 09116/8C " 1.1: ,. 10211 ,AHIUCOSE ~OIHTORING 09/11/00 56151911201 2l.85 11m n [ CG-lHS l!l;-Helem ~9f17 Hit \ ~ .3; 1C2CE ,AHlueOSE ~ 0 ~~ I i 0 R I N G 89/ lilac 56151F1i1S8 8.74 11m Pi s CO-HiS LAB-GLUCOSE 19118/00 0 1.75 , W8[ :'AB-~LU:OSf ~OI'HTORn;G 0911 S {~~ - 56151911200 8.n 1C2tf ~, T f ~ 0 - I r~ s lAD - G L U C O~. E ~ e 9/lS !e~ i.75 102~E LAS-GLUCOSE ~ 0 lilT 0 R 1 r; G 0Sl20/CC 56151911200 U4 10m ~i eo-HIS l AB-G( ue OSE . 09/2C/OC 2 1.75 ,. 11m lRHlDtOSE ~D:1I10RlNf; 09111100 1 5615191i2i~ s.n 1C2ce FT CG-IliS lAB-GLUCOSE !, 19/11/10 l.n It2~t LA8-GLUCOSE ~ 0 il I TOR I ~j G 0912i/SO 1 56151911200 L37 H2~f. '" C U ~ 1115 lAf1-Gi.UCOSE r 09/22/00 1 .87 10H~f, ~Ao-~LUCOSE ,~o ~i IT OR I N G 09/23/00 5615191120C 8.74 112 OS PI , C['>-H{S l Af:-G L UC OSE I C ~; 2:' r ~ ~ 1.75 g20b lAHlUCOSE ~O;HiORHjG 09/24/00 561519112~C U4 lt2C8 PT B CO-HS LAB-GLUCOSE ~ 19/24/01 2 1.75 1e268 IAHlUCOS, ~O~HTORnlij 09lnlOO 56151911181 ~ . i J Im5 Pi 5 CO-lIIS lAHlUCO" ~ 09/25/18 1.75 mBS l!S-mm[ ~OIlIiORlliS BsI2S/BI SSl\1mm a.n 10208 Pi , CO-lIiS lAHlUCI5[ ~ 09120/00 I 1.75 10208 lRB-GlUCISE MOlllTORIIIS 19/27/11 1 50151911218 4.37 1i215 PT B CO-I:;S lRHlUeOS[ ~ i9{27{08 1 .87 HENOING BAlAilCE 391,48 "PRIVATE - OCT i0 BAl FWD -l~- -30- -6C- -S0- -12It- 9BUB 521.9B mUi 3i55.0i lBi31.7J 27305.75 1128B PT B CO-I1iS lAB-GlUCOSE r, 10/BlI18 3 2.62 WII CABLE RENTAL 11/01{00 -- li/31/00 1 59158401200 5.00 11m Pi B CO-lIiS lAHlUCls[ r, 11/01110 j .B7 mlB PT , CD-IllS lAHlUCOSE M 11/03/01 2 1.75 mCB PT B CO-lIls lAHlUCOSE ~ 11{04{08 1.75 .'....._- , 'u'- ~ , " . 0B/8B/01 RESIDENT lEDGER AS OF DATE OF FIRS; ACTIVITY PAGE (AR56 ! RESIDEJ:1 BESIDEI:' H~IO~I;i &/, -- ACCOU~1S RECEIVABLE :iU!8ER TYPE ~f A ~ ~ DATE DIY ReCDUliT CHARGES CREDITS BAlAlICE SSW m JCA lD HEFFlEBOWEB, JDYCE A 01/26/0C m cm BATE: U0 ROOh 119 -, LEVEL 2 013 PRIV PORT: 531.81 "PRIVATE - OCT 0C (COt:i: W0B p f; C0'-HiS IAH,UCOSE ~ 10/05/00 1.75 W0B P B CHIIS lAB-GLUCOSE II 10/06/00 1.75 10208 P 8CHI15 lAHlUCOSE ~ 10/07/00 .57 1120! P BCD-IllS LAB-G10COSE : 10}0B100 .B7 H?eF: , ~ rn-Il!~ ' ~ S -f! lir n ~ ~ . j ~ j r ~ ! C r .f' 1020B PT SCHIIS lAHLUCOSE . lU/lU/00 2 1.75 " 10108 PI 8 CO'IIIS LAB-GLUCOSE II 10{11{00 2 1.75 10108 PI E CO_IllS IAB-ClUCOSE . 10/12{00 , .87 " 10108 PI B CHIIS LAS-GLUCOSE II 10{13/00 1.75 W0B AT e CO~!IIS lAB-GlUCOSE ! 10/H/00 2 1. 75 10m P; E CD~I~~ lAB-&tUtDSE t 1tfl\lt~ ". IS 1020B Pi 8 CO-IllS lAHIUCOSE II 10/ 16/0~ .87 10208 Pi B CO-HS l ~&-GL UCOSE t H/17/0C 1.75 10108 81 8 CO~INS W-6lUCOSE ~, 10/1B/00 1.75 10208 Pi 8 CG-JI:S LAB-GLUCOSE r. 10{19)00 .8i 10208 PT B co-n;s lAB-GlUCOSE , 10{10/00 .87 " 10m PI 8 co-m LH-GLUCOSE ~ Hll1/00 :.15 1mB Pi BCD-INS tAS-GLUtOSE fI 10111/00 l .B7 1010B Pi B CO-illS lA8-GlUCOSE h 10/13/00 1 1.75 10108 Pi e CO-INS LAB-G~UCOSE ~ 10/2_/00 .87 10m n ~ CO-HS LU-~;,UCOSt r. 1012\{00 .B) 1010B PIS CO-1Ii5 lA8-~~UCOSf ~ 10/19/00 1.75 1010B PT ~ CCi-IIlS lAB-GLUCOSE h 10/30/00 .87 REV l A S1 I~ 0 P P 10/01/00 13111000000 46 8.0 0 PRIVhTE P 0 R T 1 0 r~ 10/01/00 -- 10/31/00 31 46 8.0 0 ADI,' PVT PORTIO~~ 11/01/00 13211000000 468.00 '*ENDJt;G 8AlAm 27Bl6.31 "*,HDICAIO - on O~ BAt FlJD -lh- -3G- -60- -90- -i2C+- USB.40 2ge1.18 570 5.6 8 19001 PHARhACY lEmo 10101/00 -- 10{31/00 1 54551102100 230.51 30001 PHAR~ACY :WN lEGEIIO 10/01/00 -- 10131/00 1 54951301200 5.37 Al:ClllARY WRlIE Off 10/31/00 57557501100 235.88 ROO~ CHARGE ATnU0 10/01/00 -- 10/31;00 31 51350002200 m1.00 ROot. WRiH Off 10101}01 -- 10131!00 3i SiSSi0t2lH H~.37 DEDUCT PVT PORT 10/01/00 -- 10/31{00 31 468.00 "EIIDIIIO BAIAIICE B591.Bl "ICDICARE P - OCT 80 BA[ FWD -LN- -38- -60- -90- -110+- 2691.94 1691.9. .. EI:OII:O BAlAl:CE 1891.94 "HDICARC 8 - 0C1 00 BA! FWD -[r,- ~3C- -80- -90- -110+- 195. '" 195.74 31U8 k'"_ ,.-","'. ,",oLe,_ C&/0S/Ci IAI5&) !l5IDEII !ESIDi,: iiU~BER TYPE USltlt\;\ IIA ~E ~:9il6 r.EDICAi: ",~FfUBO~;EI" JOY:~ I, RDOl 11S -I LEVEL 2 i*r.EDICARE [ - OCT 6C iCO~T) le2e~ l~E-~LUCOSE r,O~I1CRI~G 10211 PI 1 CD-INS LAB-GLUCOSE ~ lC2CE LA1-a~UCDSE ~O~ITORI~G 11211 Pi, CO-lIS LAS-SLUCOSE ! 11218 lAf-GLUCOSE nOiiITORIiiG 1120S Pi l CO-INS LAS-SLUCOSE I 1021., LAS-GLUCOSE ~OiiliORliiG 1~2~~ tl ~ ~&-lhS LAD-GLUCOSE H 1021S LAS-GLUCOSE !OiiITORlii6 10218 pi l CO-INS LAS-DLUCOSE M 1011! ,Ai-iLUCOSE IINIIORI16 10211 Pi E CO-INS LAS-GLUCOSE ~ 10201 LAl-OLUCOS1 r,OiiITORliiO 10201 pT l CO-INS LAS-GLUCOSE I 10211 LAE-iLUCOSE r,ONITOlliii 1110E PI i CD-INS LAS-OLUCOSE ~ 11.211 :Ai-iLUCOSE ~ONriOR1iiO 11101 PT lCD-INS LAO-CcUCOS[ ! 1121., lA,-OlUCOSE ~OiiliORI,O 102~E F:: CO-I~S lAB-GLUCOSE ~ lC2C8 LA~-:LU~nSE tD~lTDRl~G 102Cf p. ~ CG~lnS LAS-GLUCOSE ~ 112" cA'-;lUCOSE ~O~IIIRI,E 1020e ?T: CO~I~S LAB-GLUCOSE M 102Ce LAE-~LU~OS[ r.O~ITORI~6 1020[ PI: CO-INS IAE-CLUCOSE A 1010E ,Ai-iIBCOSE KONliORIiiG 1~218 ~1 ~ CD-INS l~R-6lUCOSE ~ 10208 LAt-3LUtOSE ~O~ITORIN6 1120E Pi E CO-IUS LA8-0LUCOSE A 1121E lAE-EIUCISE KO~ITORliiE 10218 'i l CO-IUS IAB-OIUCOSE ~ 11101 IAE-OlUCOSE KOiilTORIIO lC20f t;? CO-INS LAS-GLUCOSE ~ 11101 LAB-ElUEISE KllITIRII& 11218 PT 0 CO-INS IAB-OIUEOSE ~ 1110S lAB-GLUCOSE KOIIiORING 11208 PI l CO-INS IAI-OIUCOSE ~ 10108 lAS-GLUCOSE ~ONIIORIIO 1021.8 'i I EO-INS LAB-ILUEOSE ! 1120S LAt-CIUCOSE KONITORINI 10118 PT 0 EO-INS LAB-llUCOIE ! 1121.8 lAS-OLUEOSE r,OIIiORIiiG 1121B PI E CO-INS LAO-CLUCOSE ~ 10208 lAB-GlUCOSE KONITOR!iil 11111 PT 8 CO-INS LAS-OLUEOSE ! ~ ~ ~!; - - ,~~ ,""""",,,,.,-, RESIDUIT meEt h: (;; Dur O~ fIEST ACT I V ITY PAGE 1/, ACEOUITI RECEIVABLE DAE 0'" mOUiiT CHARGES CRE on S IAlANCE " Cl/26/6[: ACt cnR RAE: UI 01S PRIV PORi: 53LSl 10 II ill' \6111511101 13.11 10/11/1.1 1.62 H/,: /0, 5615i9112H U7 11/02/er .87 10113/00 561\1911111 S . 7 ~ II'flllll 1.11 ltlC4/0r 56151~112CC e.7' H/6;d~ 1.75 10/15111 51111911201. 8.7, 10/05i60 1.15 11}ib/lt 5ml\1lm B.l. 10/061" 1.15 10(1.1 lee 56111S11210 U) 11/17/00 .87 lilli/Ie 56151S;;20C 4.37 11/08/10 .87 10)09/10 5615191l2eC UI 10(09100 .87 le/1e/ec 16151911101. 8.7. Hl10!0~ 1.75 ltJllJCt 561519il?Ce 0.7, 10/11/00 1. 75 B/12 .i~~, S61S1Sl1n~ 1.3) H(12/le .87 10/13/er 561S191111C 8.7, 10/13/00 1.71 HIHIOI :,51SiSl :2CC 8.), 10jHiii 1.75 l1/1SIIC 561519112CC U, lO{15[00 1.75 10/16101 56111911ne U7 H/H/0(, .87 H/17/0C 5615191i11C S.I, Hi li I~e 1.75 IIIH}ei S6iS131120t 0.74 10/11/00 1. II 10/19/IC 16151911210 U7 10/19;00 .17 11/2011.1 56151S1WI U) H}mOI .17 11/21/11 56111911100 S.74 10(1111C 1.75 10122/11 16151911m U) 11./21/01 ,I) 10/1*0 5b1519um S.7. 11/23/11 1.71 . ~ .' , C~' ! 0 8/ C 1 REmm lEDmASO' DATE Df fIRST AC TlV ITY PAGE ,.m" UIOEl:i RESIDE!;; RESIGEI;: G{~ -- AClOU!;)S R:C:!VABll II LI,~ BE R TYPE t~ A ,~ E DATE on ACCOUIIT CHARGES CREDITS BAIAlIlE ~'g 116 m!CA 10 H:HlEBOWER, JOYCE A 01/26/0e AO~ cm RATE: UO ROOii 11 S -~ LEVEL 2 OIS HlV PORT: S34.B2 "!EOlCARE B - OCT 00 ( COliT) le208 lAHLUCOSE mmRll:6 10/2,/oe , 56151911200 4.37 10208 PI E CO-liIS LAB-GLUCOSE n 10/24/00 1 .87 1020B LAB-GIUCOS: !OIiIiOmG 10/25/00 1 56151911200 4.37 H2li PTBco-m lAHlUCOS: ! 10/25111 .i7 lens l ~ P -0: [lr~s~ r.o~!qnFH~G 1 ~ l? Q I P ~ t, ~ : ~ ~ Q! ! :' ~ 0 ~ . i! Im8 p- . co-m lAB-GLUCOSE ! 10{2S/00 LIS 11218 LA8-GIUCOSE !omORlliG 10{30/00 561519112CC U7 11208 PT S ~0-IU$ lAHIUCOSE ~ lC /3C /0[' .n "[!;OI!;G BAlAICE 5\1.83 "PRlVAH - ::OV 00 BA. h~L -l~- -30- -60- -S0- -12~+- 97B.56 516.98 521.9B 4012.00 21786.79 27816.31 11m CABl I REIilAI 11/01/00 -- 11/30/00 59158,01200 5.00 11110 ~t~t:'y mmm 11/16101 5mmmo 3\.10 11100 BEAITY A!;O BARBER 11/16/00 5S15m12OC UC 11101 eEAL'iy AllOBARm 11(30 (00 5Sl5BIOI2CO 9.0C REV LAST ~O pp 11/01/00 I31liOOOOOO 46UC PRIVAiE PGRiION 11/CliOO -- 11{30{00 30 515.32 I,OV PVl Rom 011 I2/01/;C 132i1;00000 \15.32 ~*E~DIN6 BALA~CE 2B437.95 ur,~OICAlO - llOV ce. B" ;\\iC -l~- -30- -6C- -9i- -120+- 23B7,13 21Sg,4C 29Gi.28 8591.81 29001 PHAR;,ACY lEBEliO 11/01/00 -- 11/30/iC 5 '51 120220C 24U5 3eOCl PHAR.~AC Y NOti lEBEIIO 11/01{Oe -- 11/30/00 5<951362130 17.17 A~:;.,ARY WRI1E OfF 11/3i/Oi 57S575C22CC 265,72 ROD; CHARGE AT 131.OC 11/11/iO -- ii/30/0C 30 51350002200 3930.60 ROOr WRITE Off 11/01/00 -- 11/3Cl00 3{: 51557C02200 683,lC OEe,:T PVT PORT 11/11/00 -- 11/30/00 3i 515,3? ~1Eh~I~6 BAlA~CE L32~,39 "lEOlDARE , - lDV II BA, ~WD - L~- -30- -6i- -90- -12C+- 2691.94 269l.94 HY",::;T 10 131 /~(\ il21 e ~c20cc 213C5C C 01;: At l DI~A ~;C E 08/31/00 51557010120 H7.~4 *'E~DINb BAlA~tE .ne "r.EOlCARE B - I:OV 00 BAl fi10 -It,- -31- -61- -90- -12i+- 150.35 195.74 195.74 541.83 pmm 11/1./0e WI00e2000 244.72 PA Y ~ E NT 11/14/10 ii1100mOl 244.72 1021B LAB-GlUCOSE lO~llORIIIG 11/01/00 2 56151911200 8.74 lO2lB LAB-ilUt05E lOllTORllli 11102100 56151911100 4.17 m08 lAB-GLUCOSE mlTOR!liG 11/13/0C 56151911200 B.7. ;,,'-' "--"'-'''0'''___,,''; -"'-'),: '-, . " 8S118)11 (AR56) RESIDEI! RESIDEIT IU!BEP TYPE RESIDEUT LEDGER AS Of DATE Of fIRST ACTIVITY PAGE RESIOU;T ti A ,~ ~ DATE (:Tv 61, -- ACCDUm RECEIVABLE ACCQUI' CHARGES CREOITS 8ALRIC! SSLI6 mlCm ,EffLEDDI"R, JOYCE R 01/16/81 RO~ CInR RAE: c.oe R00~ US , LEVEL] DIS RRIV ROR!: 53U1 -, "IEOICRRE f - 10V 81 :COi:T) Jim LRHlUCOSE r.DI:liDR!I:G 11/C4/8C 561519112Cr ~ . 37 11218 LRS-GLUCDSE lOllTORING l1IC5/DC , 55151sum 8.74 11118 LAB-GlUCOSE IDI:mRING 11/16/Ie '. \61519112CI 4037 , 1I21B LRS-GLUCOSE lONITORING 11/17/11 5615lS111ee 4.37 11m lAHLUCOSE 10i:JTORING 11/I8/IC 561519112~e 4037 11218 lRE-GlUCDSE lONITORING 11/19/01 561519111eC 4.37 mlB LA,-GLUCOSE 101!TOIIN6 '1ltHlce 551S191'12CC U( 1 ~ ~ \):- Lht-QLU~0~~ ~O~l~Dil~G l * fl i.; ~~, ~{'*:J..~.I.l~~~ i.j; WIB lA,-GlUCOSE !OIITORIIG 11/12/CO 1 561519i12eC 4037 10m l!!-Glucose ',OllllORING 111\3100 2 56151911201 8.H A~::ll~RY WRITE Off 11 m/IO S755751l20e is. i1 meROj 08/31/1e 57557611100 ~ 8 . 9 8 foE[- B ADJ ISI30lCI o755HIICC(' <B .9B *~~~DIN6 8~L~~CE 213,3G "PRIVATE - ose Ie BL ,:WG -Lt.- -3C- -60- -91- -In+- 10 S 9. 6 ~ 510.56 516.98 51UE 257ge.79 28~3j .95 iIm Ci\L~ REn~'. 1210IIIe -- i213liee '. SSl584e120, \.Ie , 11111 8EIUTY RNO 8ARBER 12/15/10 59158101200 !.Co ll1Ct Bu'~:TY At~p 6AR8H 12/2110r: s ~ 15 flle 1: ~ c 9.CO RE\: l~31 hG n 12 j ~ ~ i ~ t i32110~~~~~' 515.32 PF.IVATE POR'm 11/el/Ie -- 12/3ifOO 31 515.32 A DV P Vi PO R Tl 0 ~~ 11/01/01 13211000C", 515.32 "E~Ol~fi BA~A~tE 18976.27 "lEOlCR!O - DEe 00 ai, F l~ 0 -Lr.- -3t- -60- -90- -~2r:-l'- '), '1 ,~ 1887,13 179 &.41 1m.1B 11324.39 ~ I :>. . ,J e, PW,u:T 12/" 101 i121Cmm 2537,53 P~~~,t~n 121e; !OO il21~~tnn B~S.~f, PArr.HT 12/"/01 1 ~ 21 ce C 2 C C [~ 2905.45 pmEIiT 12{04/00 1111COl11CI 2751.0 8 PhnHi 1210\ lee 1121~CenH mUi PAY~ENT 11/11/01 11211012011 2731.5 8 WII TRA~SPDRTRTIO~ SERVICES 17/31/10 S915BBCneC 32,CI 11110 TRRISPORTAT!ON SERVICES 08/14/01 5S15880220~ 32.00 11110 TRAISPORTATIOI SERVrCES eB/25!OC 5S15881ml 32.0C AICIllAIY YRITE OFf 11111110 mmmle 96.10 Roar. CHI.ROE AT 13UI 12/11/10 -- Il/31/0e 3 513SIII120l ~I61,01 ROO~ ~IRm OFF 12/11/11 -- 12/31/01 3 5l5m 0 120 I 705.87 OEuun RVT ROf.1 11111110 -- I2131!II 3 511.32 I~E~DING BALANCE 1616,77- "IEorERIE B - DEC Ie 8AL FWD -L~- -30- -60- -SO- -120.- 62.95 151.35 213,30 "'''=' - "~'." - " - . , -~ ) _. ~.; _"""," '_'C ~ , GiICS /el RESIom lEOm ~\ D' om 0, flf:Si hemIn PAGE 11 iAR561 RESIDua RESIOE::- RESIOEP '/1 u ACCoum RECEIVABLE Up :lU!m m, :t~~~ ow (\11{ ACCOUII1 [HARm mom mAm ::9116 ~EOICW H~ F f L E 6 Ol~EF. , ~ GYC[ ; Cl /26 J C ~ m CI~ T ;, Rr.H: UC Rm 115 -I lEVEl " GIS PR1V POR] : 53U2 , **r.EDICAR , - GEl 00 I COI:1) AnENT I2/es/o" 11 2 1 n t c- 2 e 0 (~ IB7,91 10m AHlUCOSE AOilITOmG 12/01/66 56151911200 S.74 10m IHLUCOSE !OI:m,mG 12/C2/ee 56151511m C.74 102fif AE - SlUCOSE ~O tl IT 0 R I1~ G 1 2 ,I e 3 ! C [~ 2 56lS191120fi e. 74 InnE kHlUCOSE !OllmmG 12/64/ee i 561519112CC e.H 10m AS-GLUCOSE ~ONITOR ING 12/0S/tC 2 S615191120~ 8.74 10m AHlUCOSE ~ot:Imlli6 12/e6/0e 1 5615191120C ~ . 37 1020f AB-SLUCOSE 1IOtlITORING 12/0if61 5 € 15191120 ~ G.37 1ms AHlUCDSE !D I: !lORII/O 11/ GC! 0(' 56151S11200 8.1, 10m AH1UeOst AOlmORau 11( 0 9 (; ~ 1 56151911~fjG 8.li 1C2C(. _~:~~lUCDSE ml1Omo 1i/H/U . 5~l5Eil2(:0 b . i ~ 1n261 la-3lQeOSE AOIIIlORIIIO 12/11/0e i 5 6151 Sl12~ ~ 8.74 lem ~ ~ f.-6 L ueOH !OI:ITORII,G 11/11!eC 1 561,j91WC ~ .37 11m ~~: -SL Ut~S~ ~O~\ nOR I :It 12i13f~~ 2 561S1~112H e . 7 ~ mCt ~ ~ f - ~ L U C 0 S E r.OI;,ITOR11;G 11/14/ec 56H191120C B, 7 ~ 16m ,ii-ilUCDSE ~ OinT OR I ~~ G l1f15/iO 56151911m UJ 16m L ~,E -G L uta SE r.onTORItlil 12/Hi" Sg151?112Cr G ?; .0 am .~S-"ucOSE ~DlnTORI;jG 12/11110 55i~1911n~ 4.37 11m ,AHlUCOSE ~omomG 12/1i/00 56151S1110C UI 102M ..H-SLUCOSE ~ 0 1; I TO R I N G 12/1S/C~ S61S1911200 4 ~ 7 lC2Cf ,'HlU,OSE r.or;ITORlr:G 11/1S /oe 56HJSll2[\~ t.i4 102r.f .;, 5 - ~:.. Den SE ,10:!lTOF:ING 12 /2~ /0 C 561519112C0 E.n 1C2CE .i.HlUCDSE r.OI;ITORII;G 12/21/Ct 551519112C0 U4 1020B lH-OlUCOSE ~OllITORniG 12 f 2 2 f ~ 6 5615191120n 8.74 1C1CB ;.E-G~UC05E r.OI;nOF.IliG 12/2 j i ~ e - 56151911206 8. 1 ~ 10208 L t 8~ G L ueo Sf ~O~IITORING t1!24/~0 , 55151911W 8. 7 ~ 1020& c;.:<~UCOSE ~ 0 I; I T e R 1 ~i G 1 i /2:, I ~(~ 5&151,Lm C3i 102n: ~ ~ i' - S l U C 0 5 E ~OlllTORm 12/2&/~C 06151911200 4.37 lC2C8 .A:-6LCCOSE r.OliITDRIN& 12/27 !0t 561519112H C3i 102C5 iAHlUCOSE ~O:mORIII, 12/18/10 i 561519112G~ 8.i. 102ep ~~.~-6~UCOSE ~omomu 12119/eo 1 561.51S1120C U7 102ct LAt--GLUCOSE ,~o:nTDRIi;G 12 j 3~.{ fi rl , 561519112(\C s.n ;&~lLtAR~ \1RIH Off 11/31.10e ~15snllnt ~S . 4 4 10?tS .f_S-SLUCOSE ~O:nTOP.I:iG 12j31JJt 1 50519112GC 4.37 r. E ~ " AOJ 10/31/Ci 5i557611W 37.56 uE~iDI:IG RAlAIICE 159.63 "PR]V~iE - JAIl e1 ~H fWO -l~- -3C- -00. -90- -12C+- 1053.6q 574.31 516.55 516,98 26326. 7i 18976.11 11m ~~!i pmm e1/01/el 3300401100 5UC ".." REV lAST ~o PP 01/01/01 13211000000 515.32 PRIVATE PORTIOt: 01/01/01 -- e1/31fol 31 515.32 AOV m PORTION 02{01/01 13211000000 515.32 "'/" CO illS HC CR131(ec lW105em A8,98 1\ \ ~, R"e COINS H0 09130/60 lW105000C 48,98 ,';,) Of/OB/Ol (AR56) RESIDE II RESIDEII IIU!BER TYPE ;,ESlUEIiI IIAIE RESIDENT LEDGER ~s O~ DATE OF ~IRS: ~CTIVITY PA6E 11 G Il -- moms RECEIVABlE DATE oTY hCCOUIiT CHARGES CREOJT5 BAlAIICE 'Sil6 mIcm HEfflECO"lf" JUICE A 01/16100 ROt cm Rm: UO iOO:: 119 -R LEVEl 1 015 PiIV PORi: 534.81 "PRIVAIE - JAI 01 (COil) RVS CDBS H-Cc lC/31JCC 1441H5r.C~C 37.56 "EIIOI::6 8AlA::CE 19306.07 "!EOICAID - JAI OJ BI,i fHO -Lr,- -30- -60- -90- 2 B S S . 81 ~ 7 , 3 ~ ~ 7 , 22 Pi~rEII 11100 Ri 19 111/5101 11911 m 'REm:: 11/11111 1:~~Cl hd;,~~~C~ l:~t;\l: L/l'lIL 30113 PHARlRC! ::OAlCGEAD 11}ll}01 -- 11}18}01 31009 PHARW! l:mEmD 01/ll!ll AUCiLLARY WRliE Dff 01/31ffil ROOt CHARGE AI 131.10 01{01/01 -- 11{31JOl ROOt WRIIE OFf 11/01/11 -- 01/31/11 OElvel PVl POil 01101111 -- 11/31iOl *~EN~ING 8AlAN~E ~~r.EDICARE t - JA~ Cl 8L 'WD -Lt- -30- 11l.80 62.95 PAY~E~l 11-01-11-13-00 1- PAY~ENT 12-]-:2-31 1-23 lC2ce lA~-~tUCCSE ~O~I!DRING ~"C~Ll~R~ WRI1E Df~ RVS WRO~G ADJ 8-CU RV~ con~s 6-Gfi RVS ~RONG A~J RVS :on;$ 9-00 R\'~ i~ROt;G AD] H Ice RVS CDI~S II-DC ' RVS ANC W~iTE OFF '*E~DING BkLAhtE tAPRIVATE - FEB Cl Bil FljD -lr- -30- 98U, 538,32 11110 BEIU11 HI! 1/3C 11601 C!tlE R[~lil . 11900 !Ci PRE!IU! iEV lAST lO PP PRIVATE POR1lO1: ADV PVI PORTID~ REe eO-l~!URR~eE miRB iV! lAB RV! i I a 19 D!lS Rce PRIV!l! PDRIIO:: -61- -n- 75.11- 01/Cl/01 01{13/01 01{01/01 -- 01/31/01 11/3111l 08/31/0C. 18/31/0' 69/30f6' 09{31/00 IC/31/0C 10/31/00 11/30/06 -9,- ~ 73. ~ D 02/0110! 6211tll1 -- 01128!i1 01/18/01 01{01/61 12/01}01 -- 01128101 28 03{ll/01 01/11(10 01/11/06 61/11/66 61111100 01/01/0C -66- 574.31 -111.- 5S~:.22- 2606. i7 11110112111 183Ul 33430402200 50.0C -.", , -,', :;'~~~H~':~~~ l~,' ~,on 5.951361106 36.78 5~9513C22ce 2E ,29 575575CnO{: H67. e~ 31 513500eml 4061.C0 31 51557001m 705.87 31 111.31 2556.71- -120+- 169.63 111l00CmO JUS 11210mm 227.24 Sfl Sl 9112CC 8.71 57SS7S112~t 1.71 5755i51120e H.98 WI1156COI .U8 575575l12CC 48.98 P41H50~0C .U8 575575i1nC 37.56 lW1G5CCCO 37.56 5i5575112C0 15.71 3UI- -12(\..- 26139.iS 2S306.07 j 5?E,8Hl2Cr 9.0e 5Si5B4~12~3 S.ufi 3343040110C 13211610600 SUI 511.3/ S15,32 13111061001 515.31 1~~jI05600C 1304,10 16151961161 56151901161 \1%0061200 14411150lCI ~6S.82 11.17 19.92 3615.01 'J, "...... 38108/01 (ARS6i R,SIDE~l RESIOE~T meEk mE RESIOE~T lEDGER A1 OF DATE 0' RIF,' ACTIVITY RE1:0m ~!AH om ~9116 r.EOICAIC HEfflEBOWER, JOVCE A ROO~ 11~ -A LEVEL 2 "PRIVATE - FEE C1 rcom REl PRIVATE PORTIO~ REC PRIVATE PORTIOA RVS PODIATRIST RVS LEGE:iO ~Vt pi R ~:1 C3/"/CC 03/01/0C C3/3i1CC C3't31jC0 r? /3! I ~ ~ 0./01/0C 04/3C/00 ~5 J C 1 ! c r C5{31iCC 06/01/00 36/36;3C 07/Cl/03 C7/31/CC OUSIICD 01/31/C1 Cl/2S/CC m OIS RE[ PRIVATi PORTIO~ RVS R . B 3C RE: PRIVATE PORTIOA RVI R B 6 31 REC PRIVATE PORTIO~ R v:~ R & 5 3 ~ REC PRIVATE PORTIOA RVS RT 6 31 DAYS RVS TRR~SPGRTATleN CR6lEREm: l~E~DIN5 BALANCE "r.EDICAID - FES C1 BL FIJO - ~~~ -36- -60- -9C- 1ee\.81 ,U1 PA\~[~T 02/21/Cl 3OOC: PW~RCY 1I0:i :EGEIID 02/05/01 -- 02/17/01 A~::llARY WRITE OFF 02/28/01 119 0 ~ !:is PRE ~ ~ c u fA C P D (P A) 02/28/01 1 RODr mm Ai 131,00 02101101 -- 02128101 20 ROOr WRlE OFF 02/01/01 -- Cl/28/01 28 DEDUCT PVT PORT 02/01/01 -- 01/2UOl 28 RVS Cu-l~S WRITE OfF 01J01!~t RVS co-niSliRM~CE el/cl/e~ Rt: lA8 02/01/80 REe lAB 02/01/00 FEC R & 8 29 DAYS 01/01/00 RE~ R~, WRITE Off 19 01/01/CO REC A~~C WRITE OFf 02{01/00 RfC PRIVATE PORTIOIi 02/01/00 RE~ POOIAiRlST 03/31/" REC lE6EliD 03/31/00 REeR&B310m 03/31/00 REe R~ mTE OFF 03/31100 RV5 Aile WRITE OPF 03/31/00 REC PRIVATE PORTIO~ OI/Ol/eo RH R & R 30 0~/3C/00 REC R~ WRITE OFF 30 01/30/00 RlC PRIVRll PORTIOR 05101(30 RfC Rr. WRnt OFF 05/31/00 RfC R & B 31 05/31/00 ", , PAGE 12 0'" " GI~ -- meum RECEIVPSlC -- AceOUIi' CHARGES CREDITS RAlANCE CI;TR RATE; UC pm PORT: 53U1 1I1liCSmo ",9.82 Wl1050m 469. B2 561525C12O[ 18.00 545 S 12 ~ 12~t HUO ~.1 S ~, r. c ~: : 0 ~ 38 7~, . r r, IWiOSOOOO 465.82 513500C1200 muo 144l105mc HS.82 5135000i1lC 387 s.o 0 1I~l1OSe0ee 469.32 5135Cer'l2CC muo 1wmOm 469. B2 5135000120C 3m.CC 59158e.~ 12 .~~ SUi 5S1S84eiCee 5.0C 12596.34 -12e+- 1,91.91- j121030200C 549513~~2JC 1~,1~ 5755i502no 3343e4e22e~ 50.00 I1S500C?2eC 3688.00 51557fi022fit 5855!1?S~~t 23fi~,Cfi lWmCOOC 56151902:CC 20.1i 561519C22ce 19.92 51350002200 3625.30 5155700220C 575575C22C0 14411e5CCCe 5615250n~c 18.00 5<SSW22C0 5135000220e 3875.00 515~,7Ce2ne 575S75e2100 99.30 llli105mO 513500e2200 3iSO,00 5155 7ee~2Ce 14A11058m 515576C22ce 51350002200 3875,00 2556. )] 288Ui lU( 637.56 515.32 230UC 636.87 40.09 169 .82 117.30 682.93 169.81 660.90 m.81 682.93 3f:/08/Cl I AR56 i RESIDE~T R~SIDE~; ::mER mE RmDEr:; liA~: Y9116 !EDICAIC HE'fl~EO~ER, JDYCE A RDD~ US -I, lEVEl "!EiItAIi - FEE 11 ItON1) REe PRIVAIE PDRTIDN REC R & B 3D R~C R~ WRITE OF; 30 REC PRIVA1E PORTIO:: REC ~::c W~ITE Off RH . & B 31 REC Rf. WRITE OFF 31 ~E: i~~~;~0~T~7~~~ "ENDIN& BALANCE "lEiICAR, E - FEB 0\ fiAL FW[i -LrL- -30~ 6.99 ~5.~4- 1020S lAE-GlUCOSE ~O~ITDRING ANCIllARY WRITE Dff i"t~el~~ B~LA~Ct *iPRIV~TE ~ ~AR 01 EAl fWD -l~- 994 . 6 ~ 11600 CABLE RE~TAl \1101 SEIU'l AID IIRBEI PERI 1190C r.c~ PRtr.1Ur, REV ~AST ,% pp PRlvm PDRTm ADV PVT PDf:TIDil *iE~8I~G B~tAUtE "IEDICRID - ~AR 01 BAl FWD -[ r,- 2565,1: PAYtE~l r.EDICAL ~ SISTANC liOil PHII:III ICI lEIE i ANCIllARY WRITE 0 f 1191C ICS PREIIU~ R DD~ CHARGE RDD~ WRm Dff UEOm m PORI "ENDING SAlANCE **r.EDICARE B - roAR 01 S A I FWD -I ~- U9 pmENTm PAY~E:H I~C8 1020S LAB-GlUCCSE ~DIIIDRIHG 102CS lAB-GIUCDSE lDIITDRING 10208 lAB-GlUCCSE ~DNITDRIND -30- 47~. 32 -3C- RESIDE~! lEOIEI AS 0' DITE D' FIISI ACTIVITI DITE On " G/l ACCOUfr:- -- ACCDU::TS RECEIVISlE CHARGES CREDITS SAlANCE 01/26/0im em RITE: UO DIS PRIV PDn: 51UI 06/01100 IW1050001 16S.B2 06130110 51351001200 3751.00 0611C{OC 515570C2200 612.&0 07{Il{00 lwmoooo 46U2 t7f31ltt S7S57St22~C 9f. Ii 07/31/00 51350001200 3875.0i 07/31/00 51557002201 49~,72 .. i;'i!iJi S S .. 5 B b~,: :;i ~ S 6. ~ ~ -60- -91- 01{01/01 -- Ol/2B{01 02/18{01 -61- -9i- 53S.12 574032 03{01/01 -- 03/31111 ~3 f 13 f~ i 03111/01 Ol/il{il 03{01/01 -- 03/31/01 31 o ~ {O 1/ I 1 -BO- -90- 03{12101 031"101 03/31/01 01/31{e; AI 131.00 C3/0 /01 -- 01/31/01 01/0 i01 -- W31iOI t 3 f ~ it 1 w_ e 3 i ~ 1 i e 1 -3i- 6.99 -60- 45. ~ 4- ..90- 011il{01 01/27{Il OI/Ol{Il 03/C2{01 03/03{01 -1201'- 56151911201 57557511200 8.74 -12C+- 10016.74 11596.34 1 59158101201 5.00 , 5S1\BI01100 IUD 530W120l 13211000000 515.32 13211000000 515.12 -120,- 11140.57 137il.49 1121000200e &495i3~~20~ li.~S 575575C220C 1 3343C~C220n 50.00 51 51150002200 1061.00 11 51557002200 21 -120+- I11lOiClOOO 11210002000 5615191i200 56151911200 561519112C0 38.45 5UI 515.32 nfS,~:- 11.49 705.87 ~1~.3L 3l.46 U. 8 . 7 ~ 8.71 S.74 B.14 , <,'~ . PAGE 15 11711.49 1.75 11.\5- 1Il12.65 14056.18 I" '-'-..... lor;; "" ~8 /05Je 1 I AR58 i RESIDENT lEDGER AS Of DATE Of fI~ST RCTIVITY PAGE Ii R~SIDENT RESIDE~l mm TYPE ~ESIUEln ~i A ~ E u/l -- Amum RECllVABli om 0" ACCDUin CHARGES CREDITS WANCE 99116 mIeW WFlEBOWER, JOYCE A Bl/26! ~ C m cm RATE: UB ~QO~; :15 -I, lE\jH " DIS PRIV PORT : 534.11 , "r,EDICARE E - r,AR 01 icom 10m lAO-GlUCOSE r,OI:ITORm 03104101 561519L2C~ B. Ii 10208 LAB-GLUCOSE NOIllTOm, 03/05 I Cl 2 56151S11200 6.74 lCm LAB-GLUCOSE r,omORJliG 03/06/01 1 5615191120C B.74 10m 'i.JS-SLUtOS'E mmmo 0310T/01 1 56151911200 B.T. 10m lAHlUCOSE r,OI;ITORU~G 0310B/Ol ) 56151911200 6.7 A 10m lH-GLUCGSE ~ONITORING 03{09/Cl 5615191120C 8.74 10205 LAHIUCOSE r,OlimRJliG 03{10/01 56151911108 8.74 10208 lAB-GLUCOSE !OIIITOR!:i5 03/11 Itl S6151911m 5.7. Bm lAHlUCOSE r,omomG 03/13/01 561519112CD 5. )A 10205 lAHlUCOSE NOIimmG 03/1./01 56151911100 8, 7 ~ 10m LA[,- ~ L UC G 5 t mmmB C3 Ii5 /0 I . 56151SL:'Ot e. 7 ~ 10108 lAHLUCOSE MOiImRIIIG 03116/01 . 56151911200 S.7. W0e LAS-GLUCOSE r.onTORHG 03117{01 E,615191l2CC B . 7 ~ 1020S lAHlUCOS6 MONITORll!B C3/18101 561519112~~ 8.74 10m lAB-5LUCDSE mITOme 83/19/01 5615191l?fiC 8.n 10268 iH<~UCDSE ~ O:~ I TOR I 11 G 03/20/Cl 2 5615191W0 8.74 10iCf, l Af, - 0L U C O~. E r. 0 I; I TOR r I~ G 03/10/01 , 56E.1S112CC 8.7~ 10200 l4c-~~uas: HO~;: T 0 RI:i ~ n3 /221 ~ 1 5il51111100 ~.H 102ce lAO-BLUCOSE mITORIliG 03/13/01 561519112CD 8.7A 10Ulf LA t -,~ ~ U tc S E ~ Q ~~ I TOR I,'! Q 03{1./01 561S~9112~~ s,n 10m ~ ~!:-:; ~ U C C S E r,omomB 83/1Sf01 S615J.9l~nc 3.74 lO2eE, LAS-dCOIE ~i II Ii I TOR 1:1 G 03/26/01 561519112 ~ 3 5.n 11208 ,8HeUCOS; t,Om0mB 1312J!ll i 561~lSl1200 8.n lOW lAC-2LUCOSE ,~O II i TOR I riB 03/28/01 2 56151511100 S.H W0B lAHlUCOS! ~ 0;, I TOR I l~ G c3/29/e~ 56151911n0 8. 7 ~ H20f lA5-,j'.UCO:E ~ C~! r T C: R I!j & 03/30101 561S19112~C 8.74 Ai,', _, AR i ~R LTE Orr C,j 131 i 01 57:,Snll:eC S:',5C WH ~A~-.jLUC03E ~Q~dTORnlG 03 /31 /~ 1 5 C1519112~r, 8.1, RVS (i' ~ t~ Pc 1:- E 0" 81131101 575:nl~2?5 1.75 ". " , ~ E;~ [ ;: N ~ 5HAtiCE 162.51 "PRIVAl' - m 01 BAL F l~ 0 -lr.~ .3e- -60- -9C- -12C..- H21.64 479.32 00.31 538.32 10553.06 13102.66 1W3 BE8liIY m BARSER OR 110101 59158101280 9.88 ll1C~ 5WlY A:iO BAR8ER 04)11101 5 915S1012~C 9.00 11600 CABLE REliTAl 04/30/81 5915 8 ~ C 12 ~ C 5.00 REV LAST NO PP 01/0l!01 lJ1ll00G001 515.32 PUVAIE PORTIOli 0./e1/C1 -- 0./30/01 SO 515.31 AOV PVI PORTIOli 05{01/01 13211000m 515.31 ~ ~ EI~ DIN G 8 A l A ~;C E BW.98 **~EOIChIG - APR 01 B~ l ,WO -1(,- -3~- -,0- -91- -120..- 2889.81 11146.37 lm6.18 pmm mICm OA/16IBl 1121C0C2CCe 18B9.81 30001 PHAR!ACY NOtl LEGEND 0./01/11 1 W5130120e 14.14 , '0 _ ~_, ,I" ,....> ;L:~ ,;...'c..' ,~ 'foe (:8/88/01 I AiS< i RESIDE~T RESIDEI! ~IU ~ 8 E R T Y P E RESIDE~T lEDGER IS D' OlTE Gf fItS' ~cTIVIT1 m, H >0 RESIDE/iT ~\ A ~: GI: -- moum RECEIVABLE AC~DU:;: CHARGES CREDlTS mAlICE O~"lE QT\ S'Sl16 r.EDICAIP ~;:FFl[80l~~R. JOYCE fi 81/2618~ ADt cm RATS: U8 c:; nrl; POR~; S34.82 ~ao~ _._ -~ lEV~t "!EGICRIO - APi 81 (CDITI A~\:LlARY IJUTE OF~ 0~/3(~fCl iO~' CHARGE IT 131.00 04/81/01 -- 04/30101 S0Dt WiITE Ocf 0410111i -- 14130}11 DEeCCT PVT P0RT 04/01/81 -- 14/30/01 "SI,I~G BRlA~CE "MEDICARE f - APR 01 8 ~ ~ F~e -1 r.- 189.78 PAYtmm 10208 IAS-ILUC0SE ~O~ITORI~& 1020, lA;-olUCOSE !OIITORIIG 10208 lA~-GLUCOSE ~ONITORING 10/88 lA8-GIUCOSE !OIITORI~& 10/81 lAS-GLUCOSE ~O~ITORING lC2CB tA~-GlUtOSF ~OkjTORI~& I0leE LA~-GLUCOSE ~O~ITORlrlG lC2~8 lA5-ElUCDSE ~O~ITCRI~G 102~E LA:-GLUlGSE ~O~ITOnING 10288 IA2-GIUCDS2 !O~ITDRIHO l02Cf LA3-ElUCDSE ~ONITORlrlG lC2CS LhE-~LUCDSi ~D~IiORl~6 10202 LA~-~LUCDSE ~O~ITORI~G 18/80 lA5-,IUCOSE ~O~IJORI~O 10208 LAf-GlUCOSf ~ONITORI~G lCZCf LAr-~LU(DS~ r.O~ITORI~G 1C20E LA:-G~UCOSf ~ONITORING lC2C~ ~A~-~LUCaS~ ~O~lTORI~G 102Cf LA:-SlUCD~E ~ONITORI~G 1C2e~ l~3-:LVtDSE r.O~ITOR1NG le!~f LA~-~LUtOS~ ~G~ITORI~G lC2C8 LA~-GlUtus~ r.O~ITORING 101C5 lAO-GLUCOSE ~DHITORI~G 10/80 lAf-GIUt05E !O~ITORIHO 11211 lAB-ilICDIE ~D.ITORIHO 1~2C8 LA~-6L6tDSE r.ONITORIN6 10208 IAO-SlUC05E ~D~rJDRING 10/05 lAi-GLUCOSE !OIITORI~O A~~ittARY WRITE OFf 10208 IAO-OlUC05E !O~IJORIHO "E~OINO BAIA~CE "PRIVATE - !AY 81 Bill FWn -1 r,- lOS3 .O~ 11100 BSAUTY A~O BARBER 11600 CABLE RENTAL t. 7 5 5 7 :. e :: : c (~ 30 51350001100 3930.00 305155mm8 30 lU~ m.30 515.32 1 ~ C 71. 7 S -3t- 1.75- -60- -90- 45 , ~ ~- C ~ /2 ~ lei 04/11101 0.)82/01 W03/Bl 04/8./01 OW5/Il 04/06/01 04/li/Ol O. /89 In 0,/10101 0./11/81 04(12!{\1 C ~ ! 131 C 1 04114101 0./15/Ci 04/10/01 0./17/Bl C4/18/01 84 ill ICl o ~ l2 ~ leI c ~ i 21 ! C 1 ~4fnf~1 0./13/01 04/14/01 0./15/01 14116}01 04/2i/81 0,/20/01 0./29/01 04)30/01 04m /81 -12~+- 162.51 1111008200e 56151311200 8.74 2 SG15131110C 8.1. 56151911208 0.i4 2 56151911181 0.1. S 615191120c 8.74 5c1519112ce 8.74 5615191110e B.14 561519112~~ S.7~ 56151911101 6.74 1 56151911188 B." 2 56151911101 l.i4 5615191~2CC S.j~ 5615t9t12~C &.74 50151911208 8.7~ 56151911200 8.74 561519112CC 8.74 5615191120~ 8.74 5&1519112CC B.7~ 561519112C~ 8.74 561519112CC 8.74 561S19112t~ S.I~ 50151911208 8.i~ 56151911100 8.71 56151911108 B.i4 Sc151~111t0 8,74 561519112CC 8.7~ 56151911100 8.74 56151911280 8.i4 58557e1120C 56151911100 8.7~ 262.11 10.75 103.82 -60- 419.32 -90- 470.31 OS/29/81 05/31/01 -118+- 11131.38 13640.98 1 S915010128C 9.00 1 59158401101 5.00 -3C- 506.31 ".,.., <, . " '" - ,~"'-;.~"''^' - < - , '<;~~<Oi~""",,~ 08108/Cl RlmEl:1 lEom I" 0: 0;1[ o- f"' 0" ~=:lvnl' PAGE 16 .r !/,,:, , iAR56i ,~f SIP E t~ T RESIDU;T RESJDEI:1 cl. -- ACCOUNTS RECEIVABlE :IUlBE8 mE mE D~1t OiY ACCOU~n CHARGES CREOITS BAIAIICE 99116 mICA][ HEfFIEBom. JOYCE ~ Cl/26/ce Aut CIaR RATE , 0.00 RDO~ 119 -A LEVU ? 018 PRIV PORT, 53LS? "PRIVATE - W 01 (com REI' l~:T ~ [r Pi 05!Cl/Cl 13;lmmC 515.31 PRlVAlE POf;TlO(( 05101/01 -- 05131101 H Sl~.32 ADV PVT PURiIOl: 06/01/01 1321100Wl 515.32 uEIIDING BAlAIICE 1417UO Hr.EDrcQO - m 01 BAl f~O -lY,- -30- -60- -n- -120.- 2925.38 111<6.37 14071.75 PAYr.E::T mICAI P.SSEiAI;C 0511.'01 11 i 1 C r. r.2 C C ~ 292S.38 30001 PHARMACY NOli lEGEIID 05/01/01 5m1302260 1l.49 mlllm ~RlTE OFF 05/31/01 57557502200 11, as R00~ CHARGE AT 1;)0.00 05/01/01 -- 05/311('; .Jl 5135GOr220(: ~215,C~ ROOr WRITE OFf 05/01/01 -- OS/31m 31 51557CC22eC 660.61 DElIUer p"T POR: OS/01/01 -- 05! 31 f ~ 1 31 515.32 v, HEI;OING BAl Am 1m"" "mEm B - .m 01 BAl fi4D -lr.- -3B- -60- -s~- -i2t+- 2il2.71 52.\0- 1.7S- 4S.44- m.02 'mm m 05/19/01 IJ.21cecnH 2SU6 10m LAB-GLUCOSE !omORIilS 05/01/01 1 56151911100 B.74 102cr LAS-GlUCOSE rOI:ITOR:IIS 05/02/01 561519112cr B,74 1~2H l,H'cUCDSE ~Ol\ I TDR 1 :(~ 0SI11111 1 55H1S~120t B.). 10m lAHIUCOSE ~OIiITOmG 05/04/01 561S1911100 B.), !Om lAB-GLUCOSE MOIIlTORIiIG 05/05/01 561519l12~0 B.7. 10m lAB-GlUCOSE r.o~nTORH6 05/06/01 2 ~,b1 S191120C Ui lOW LAHlUCOSE ~OtlITORIN6 0S/07/01 5615191110r, B.74 10m lI,HlUCOSE ~OtilTORH~G 05/08!01 " :,6151911ne 8.7, 10m LAo-GLUCDSE !OilliORIIiG 05/09101 2 56151911100 &.7, 10208 tAB-GLUCOSE 110mOR!l:G 0S/10/Cl :,615191120C 8.7i 10201 I.AE-GLliCOS~ ~o~nTORING CS/ll(Cl 56151911200 B.74 102C8 ~A~-GlUCOSf f,OIUTORBG C 5/12 f ~ 1 5f.1519112CC B.7, mOB LAHlUCOSE ~OtnTORltlG 05/13101 i 56151911100 8.74 10205 l~~-HUCOSE r,omoms 05114!01 1 ~61S19112~~ e.7\ 10208 lAHLUCOSE ~OIlITORI:!S 05/15/01 561519112 0 ~ e . i ~ 1I20B IAHlUCOSE !OmORII!G 05/16/Cl 561519112ce 8.7i 1010B IAHlUCOSE MOrnrORING 05/17{01 S6151911200 8.74 10m l~Hlucm mmmc 01/HiOl ) SC1Slmm B.7. 11208 lAHIUCOSE lO:IITORIIiS 05/19/01 1 561519 112~f B.74 10208 LAB-GlUCOSE rOIiITORIliC 05/1OiCl :.61519112 C {~ 6.7. 10108 IAHlUCOSE ~OIlITORING OS{21/01 56151911200 B.7" 1010B lAHIUCOSE r,omORIIiG 05/12/Cl 56151911100 8.7i 10m lAB-GlUCOSE MOIIITORIIIS C5/23/01 2 56151911200 B.74 1010B lAB-GlUCRSE r.OfiITORII:G OS/24/01 1 5615191110C 8.74 10108 lAB-GLUCOSE mITOmG 05125{01 1 5615191110e \.7 R 10208 IAHlUCOSE r.omoRIlis C5/26/01 2 561519112CC 8.7' .,. ,,~- - "' ~B/08 /0 1 \ A R ~,) R,SI0E~T RESIOE~i liUISER TYPE RESIOENi lEOGEf, AS OF DATE DF fIRS; ACTIVITY PAGE Ii RESIDEl-'T Ii A.~ E 51' -- ACCOUm RECEIVRBLE Dm ,p ACCOU:IT CHAms CREDITS BALAIICE 99116 mlCAID HEi f L EOOWE R, JOYCE A Cl/26/00 m CII!R Rm: 0.00 R DO.", II ~ - A LEVEL 2 ,. ~ c PRn PORT ~ 5H.82 u ~ J "~EDICARE , - ~AY Cl (COI:!) lC208 lH-GL1.!trSt ~Ot~ITORH6 OS/27 ,Ie 1 S615El:n[' S . 7 ~ 10208 lAHLUCOSE hOll!TORING OS/28/01 2 561 5191 i20~ 8.1. H20! lAS-oLUCOSE ~O~ITORIl\o 05129)01 2 501S191120C 8.14 10208 LAS-GLUCOSE 101l1TORIIIG 05/30/01 2 5S151911100 U4 mIlIARY WRITE OFF 05/31/01 58S570112C~ 54.15 10m LAB-GlUC0SE !011110RII1G 05131101 1 ~61S19112\\~ !.7. *~E~OING BALANCE 66.25 ttpRIVATf - J U ~I 01 8Al fWO -L!- -30- -6C- -90- -110+- 1044.04 531.32 506.32 479,32 11601.7C 14170.30 1160C CHLE RU;HL o6/2SiCl 1 59158461nc S.00 REV LASi !O PP 06/01/C1 1321100C00O 515.31 PRIVAiE puRiIOr; 06/01101 h 06/30/01 3C 53Ul A OV PVi PORT 1 O~i 07/0llC1 13211000006 534.82 ~ ~EI~OH6 BAlmE 14729.51 "HOltm - JU1J ~i SA.. fWD -tr,., -30- -60- -90- -120+- 3 Q ~ C , 0? 111\6.37 14186,44 PRY~E~T ~EOICAl RSSIS1A~t "111101 1l1l0mm 30,0.17 30001 PHAP.~AC Y IlON lEGEIIO 06/15/01 549513C2W 22.98 Ai;~ IL LARY lJUTi: Ofr 06/30/01 5755i5C22rC 11.98 ROO: tHARGE AT 136.C0 C6{01/01 -- 06{30{01 3{' 51350001W 408UC Roor. WRITE OFf 06/01/01 -- 06/30/01 3C 51557CC22CC 639,30 0EDUCT PVT PORT 06/01/01 -- 06/30/Cl 30 534,81 ill U;OItjG SHWE 14051.25 ~~~EDICRRE ~ - J Uii ij i 8 P. ~ PlW -l~- -30- -60- -9C- -12(:+- ')',- cc, 50.75- 52.50- 1.75- ~5,44~ 'c "'c ~ ~ c. . ,,~ Cv.L.' PAHtliT I",CB C6/19/0! 1121Cccnce 270.94 10208 lH-(;LUCGSE ~o~niDRlilG 06/01/01 56151S112CC 8.14 lo2oB lAHLUCOSE ~mTORIIi6 06/02/01 56151911100 8.74 10m lAB-GLUCOSE ~OlllTORII1G 06/0311, S~lS1911H~ s.n 10108 lAB-GLUtOSE ~OlimRlIi6 06/04/01 1 56151911200 8.74 10208 lAB-GLUCOSE ~OIlITORIIIG 16/C5/01 2 561519111CO 1.74 10208 lAB-GlUC05E ~OI:ITORlIi6 C6{C6/01 c 561519112CC 6.74 . 10208 LA8-SlUCOSE ~OlllTORIIIS 06/07/01 , 56151911200 B.74 , 10208 lAB-SLUC05E r.OIiITORII:G o6/o8/C! 2 56151911200 8.74 WC8 LAB-GLUCm MONrrORH1G 06/09101 , 56151911200 8.1q , 10108 lAB-GlUCOSE ~o~mRlliG 06/10/01 , 561519112~C e.7. , 102C8 LA8-GLUtOSE !OIlITORIIIG 06/11/Cl 561519l1W 8.7, 1mB lAB-GLUCOSE mlTOms 06/12/01 56151911206 B.74 11m lAS-SIUCDSE !OIlITORINS 06/13/Cl 1 56151911100 8.74 10208 LAO-GLUCOSE r,OliITORm C6/14/Cl 2 5615BI110C 8. 7 ~ 10208 LAB-SlUCOSE ~OIlITORIIIS 06/15/Cl 561519111CO 8.74 ,~- . "., '.,;.",;,..C~~ ~ ~ -"':j eS/08/0i ,AR56) RE5JOE~T RESJOE~i ::uM8ER TYPE RESIom ~i A ~ E 55li6 ~EOICAIO REfilE80WER. JOYCE A Rm 115 -A LEVEL 2 "MEOICARE [- JUI; 01 (COliTi 10208 LAS-OLUCOSE ~O~ITORI~G 1020S LAS-OlUCOS! Mo~rTORI~G 16265 lAS-OlUCOSE UOUITORJNG 1620S lAS-GLUCOSE MONITORING 1026S lAS-GLUCOSE ~OUJTORJUG 1121S lAf-OlUCOSE MO~ITORI>>\ 16268 LAS-6lUCOSE ~O~ITORI>>G 10208 LA~-~LUCOSE ~onITORING 11208 LAB-6LUCOSE 10~ITORIU6 10208 LAS-6LUCOSE MOUITORIN6 10218 LA,-GLUCOSE UOUIT8RIU6 10268 LAE-6lUCOSE MONITORIN6 lC2C5 LAS-GLUCOSE ~ONliORIN6 1021l lAl-SlUCOSE M8NITORIUI AN:IlLARY WRIT~ OFF 10208 lAE-,LUCOSE MO~ITORIN6 *~E~OING 8AlANCE uPRIVATE - JUl Cl Bfll, tWO ~t 1',_ -3t- W".6< 529.02 116ee C~,~, R,~IAL REV LAS -; ~ c p P PRIV~H PORTIOi; AO\' PVT PORTIOli 'jE~&]AG BAlA~[E "MEDICAIO - JUL [1 a h. ::,~D ~ L ~- 2ScS.SE '0 RESIOENT LEOGER AS Or OATE Of fIRST ACTIVITY ['-1'"",-,,"'_ '-"'".0''' ,~" ~" '';;;:';~,: PA6E 18 G/l -- ACCoum RECEIVABLE OATE UTY mOUl1T CHAR6ES CREOITS 8ALAm 1112&110 m mRRm: 0.10 DIS PRIV PORI: 53U2 06/16/el 2 561519i12CC 8, 7 ~ R6/1i{01 2 56151911200 8.74 00118101 2 \6l1lS II m B.i4 06{19/01 56151911260 8.i. 06{20101 561519112eo 8.i4 06! ~ 1 ! ~ 1 , 561\1111260 r..i~ , 06{21/DI , 56151911200 U4 , 06/23/01 5615191120D B.n 06/2A{Oi 56151911200 B.74 06/25/01 2 56151911260 8.74 0&{20 {01 2 561519WOI 8.74 06 /2i {01 2 56151911260 8.74 C6/28/01 , 5615191i20C B.74 , 66/29101 2 56151911200 8.7, 06/30/Cl 58557811200 52.SC 06/30101 5615191120R 8.i4 5.61 -\1- -SO- -iH+- 538.32 506.32 120B1.R2 14729.62 eifel/Ol -- 07j31jCl 591584C12CC 5.60 0)/01/01 13111000m 53L82 07/01/01 -- 01 III /01 31 53U2 RB{O do 1 13211000000 53U1 -3C- -60- -90- ?~n~);1 r,EDICUu cllnicl 3C0fi; PH~R~Acr NOrl LEGEND 67/23/61 ANCILLARY WRlif OFF cii31JCl ROO~ mRGE AT 116.60 01 !ll!ll -- R1 !31jU ROOU WRITE Off Oi/01{01 -- Oi/3i{01 DEDUCI PVi PORi 61/0i/Rl -- 0U31/n jjE~O!NG B~lA~CE "MEOICARE 8 - JUl 0J B~~ ~WG ~l~- 219.70 P A Hun ~ CB 10208 lAB-GLUCOSE lOUITORING 10206 LAB-6lUCOSE IOUITORIU6 lR268 LAB-GLUCOSE !IUIIORING 102R8 LAB-6LUCOSE !OUITORIN6 lR108 LAE-6LUCOSE Mo~rTORIN6 -30- 54.15- -00- -se- 50.1S- 52.50- 07131/D1 07101/01 oue2/er R7IR3/Rl R7/04/01 07/C5/61 -12C+- 11140.37 14052.25 ii2lOmm 5~9513C2200 11.4S 57557502200 \\l\0102200 ,2\0.00 5155iCC22CC 2905.88 11.49 401 . 76 534.82 -i2Q+- 47 .19- 5.01 ii2100moo 201.20 2 50151911200 B.74 2 56151511106 U, 1 S615191W6 8.i4 1 56151911260 8.74 2 56151911260 6.74 15269.~4 lW5,79 . "' " , , CBI~II~l RESIDENT lEOGER AS 0: OATE OF fIR:! A,TlV!T' PAGE 19 IRRI,; PESIUm RlSlOm K: S lG E ~;I' Sll "" AlGOl1,1S REGE]VRI1E :iUlHR TYPE mE ORiE OTY mOUtiT GHARGES G REO ITS BALAtlCE : ~ 116 r,EDIU.lD H:,=rLEf;OI~U,. ,1DYCE I, e 1 i 2 i, ,I 0 {~ ROt, enE HATE: UC R OO~, 119 - A lEVEl 2 OIS PRIV PORT: 534.82 "NEOICARE B - JU, 01 (Coni 11m LAB-SLICISl NINITIRl1,i 67/6S/01 2 5&1\1911200 U4 10201 LAB-GLUCOSE lONITORING 07/07/01 2 56151911200 8.74 10m lAB-SlUCOSE r,01,110RIN, 07/01/Bl 2 561519llnC I. " 10m LAB-SLUCOSE lONITORING 07{09/01 2 561119li2BO &.74 1ml LAB-GLUCOSE NORITORING OI/le/01 2 56151911200 U4 10m LAB-GLUCOSE 10NITORING 07/11/01 2 5615191120C 8.74 10201 LAB-GLUCOSE r,ONITORING 67/12/01 2 561519112BB 1.7. 11m LAI-S1UCOSE 10NITORINS 17/13/61 2 1&151911260 8.74 10m LAB-GLUCOSE !ON1TORIN6 07/14!01 2 56111911260 8.7. 10266 LAB-GLUCOSE !ONI10RING 61{15/01 2 16J51911206 B. Ii 1020B LAB-GLUCOSE ION110R1N6 67 {16{01 2 56151911200 B.74 1620B LAI-GLUCISE ION1TORING 07/17/01 2 16151911200 8.74 16201 LAS-GLUCOSE r,ONITORING 07/11/C1 " 16151911208 B.74 , 1620G LAB-GLUCOSE lONITORING 67/19/61 2 16151911W UJ 10m LAB-GllCOSE I01,111R1N6 6unlcl 1 56151~112Ct &.7, J0266 LAB-GLUCOSE IONITOR1NG 67{21{01 2 161\1911200 8.74 1026B LAB-GLUCOSE r,ONITOR1NG 07/22/01 2 5615i91120C 8,74 16201 LAB-GLUCOSE 10N1TOR1NG 67/13/01 2 16tI1911216 U4 1620B lAB-GLUCOSE NON1TOR1RG 07/24!61 2 561519112CO 8.7. 10268 lAB-GLUCOSE 10NITORING 07/25/01 2 56151911206 5.74 102ce LAC-GLUCOSE NORITORIRG 6i/2C/01 , 5U519112cr, 1.74 , 16201 lAI-SllCCSE !ON1TORIIG 61/27101 5615191120~ 8.74 10208 LAS-GlUCOSE 10NITORIIG 67/28/01 55151911200 B.74 10261 LAB-GLUCOSE 10NITORING 67/29/01 2 56151911206 8. i ~ le2e~ L4B-SLICOS6 NONITOR1NG e7 pc /01 S~151S1i2~0 E.T4 ANC1,lARY WRITE OFF 07/31/01 5B511B11206 54.25 102e8 LA5~GLUCDSE nO~ITORING C7{31!Cl 55151911260 8.74 ~tENuING BALANCE 40.50~ , '~ ," ~ , - ~ .<";",c.;;i;)' " . ~~4.f:-" , " ,. EXHIBIT "B" Ii ~ - - '~,""=-- M. ~ ~> ~ ~ ,-. ~, - 'r>lii~:Qik>'" rJ ," "tJ: Manorcare Health Services .. , . ADMISSION AGRJ:J:MENT CONTRACT BETWEENPATIENTIRESIDENT AND FACILITY THIS ADMISSION AGREEMENT (the "Agreement") is entered into this day of . .---ct:;,..1?J,~ ,between MANORCARE HEALTH SERVICES (t~L:'~~i!ity."), and JOQCf ~ It.f! f!jff'1t::x>lIJef(the "Patient/Resident"), and/or ;Zol()e~ J7t::f17.Ll;;iO (the ".Responsible Party"). As used herein, the term "Patient/Resident" shall also mean the Responsible Party, if a.ny. The parties agree as follows: 1. Commencement. This Agreement shall begin on the date of admission of the Patient/Resident to the Facility. 2. Termination of Agreement, Discharge and Transfer. a. Termination by Patient/Resident. The Patient/Re.sident may terminate this Agreement by giving the Facility at least five (5) days advance written notice. The Patient/Resident is responsible for payment of all charges for five (5) days after notice is given, or until the Patient/Resident actually leaves the Facility, whichever is last. If the Patient/Resident leaves the Facility (i) before the attending physician discharges the Patient/Resident, or (ii) against medical advice, the Patient/Resident and Responsible Party agree to assume all responsibility for injury or harm to the Patient/Resident, and hereby release the Facility, its employees and agents, from all liability connected with such departure. b. Termination by Facility. The Facility may terminate this Agreement and discharge the Pat- ient/Resident upon at least thirty (30) days prior written notice if (1) the Patient/Resident's needs cannot be met; (2) the Patient/Resident presents a danger to the health or safety of other indivi- duals; (3) the Patient/Resident fails to pay charges for supplies or services after notice; (4) the Patient/Resident's health has improved sufficiently so that the Patient/Resident no longer needs the services provided; or (5) the Facility ceases to operate. However, the Patient/Resident may be transferred or discharged upon less than thirty (30) days notice if: (1) an immediate transfer or discharge is required due to the Patient/Resident's medical needs; (2) the Patient/Resident presents a threat to the health and safety of individuals in the Facility; or (3) the Patient/Resident .has not resided in the Facility for thirty (30) days. Such notice shall be given as soon as practical. The Patient/Resident acknowledges receipt from the Facility of materials as to the Patient/Resident's right to appeal a discharge decision with State authorities and the appeals process. If this Agreement is terminated and/or the Patient/ Resident is discharged by the Facility, the Responsible Party agrees to accept custody of the Patient/Resident upon discharge and cooperate with the Facility to facilitate the Patient/Resident's discharge. 3. Responsible Party. The Patient/Resident shall execute Exhibit A regarding Responsible Party appointment. 4. Fees & Payments. The Patient/Resident is responsible for, and shall pay, the daily rate and charges for supplemental services and supplies not paid by any third party as described in the Fee Schedule, attached as Exhibit S, as well as applicable co-insurance and deductible amounts and all expenses of discharge or transfer. 5. Release of Information. The Patient/Resident hereby authorizes all persons and/or entities to release all or any part of his/her medical/health records to the Facility. The Patient/Resident also authorizes the release of records or information to any health care institution to which the Patient/ Resident may be transferred, any provider involved in the care of the Patient/Resident, any third party payor, including, but not limited to, government and private insurers, or any other person entitled or authorized to receive such information by law or by the Patient/Resident. MHC-OO"'O (ReV. 7/961 P9 3 1 QL~ .. -;"""'"~'~~~~~~!~~,.^::,~i;,.~,~:..~.~..,-;,,~~~;"::=~;~:.:.:,~",: ,6., Consent to' Treatment. Patient/Resident acknowledges that ht3/sne .Is under the medical treat- ment and care of an attending physician, and consents to the Facility rendering' nursing ca therapeutic, and other treatment under the general or special instructions of said physician o/~ case of emergency. ( 7. Attending Physician. The Patient/Resident is solely responsible for selection of a licensee attending physician. The Patient/Resident agrees that the Facility may require the Patient/Resident to utilize another physician if the attending physician (1) has his/her own professional license limited. suspended or revoked; (2) fails to follow the Facility's rules and regulations; or (3) is unavailable ir case of emergency. The Patient/Resident is responsible for all charges for physician services. 8. Pharmacy. The Patient/Resident shall execute the Pharmacy Agreement attached as Exhibit C 9. Independent Contractors. The Patient/Resident acknowledges and agrees that all physicians dentists and barbers/beauticians, including those whose services are arranged by the Facility, are independent contractors and are not employees or agents of the Facility, and the Facility shall no: be responsible for their acts or omissions or for the consequences of following physician or centis: orders. 10. Private Duty Personnel. The Patient/Resident aCknowledges that all private duty personnel tha: the Patient/Resident utilizes are not employees or agents of the Facility and that the Facility is no: liable for acts or omissions by such personnel. Employees of the Facility may not be employed ao: private duty personnel at the Facility. All private duty personnel shall comply with all policies aG: procedures of the Facility as may be amended from time to time without notice. Failure to co s: may result in their being denied access to the Facility. Patient/Resident and Responsible Party sha be solely responsible for the cost of private duty personnel. 11. Facility Guidelines for "No Heroics" Requests. Decisions regarding life support sr.ould be ~or.' sidered by each Patient/Resident or his/her authorized surrogate decision-maker. The Patient, Resident acknowledges receipt of rights under state law to make decisions about medcal care, ir:- eluding rights to accept or refuse care and rights to make an advance decision abcut care. The Patient! Resident acknowledges receipt of a summary of the "Facility Guidelines for No Heroic~ Requests" (the "Guidelines"). A full text of the Guidelines will be provided upon request. In part, the Guidelines provide that the Facility will not withhold or withdraw life-sustaining or life-prolor.gin~ measures from a Patient/Resident without a written and legally suHicient authorization of a competer: Patient/ Resident or legally authorized surrogate decision-maker and a physician order. The Patient; Resident agrees to comply with the Guidelines. \ 12. Liability and indemnification. The Patient/Resident understands that the Facility is liable onl~. for injuries caused by the negligent acts or omissions of the Facility and as required by law. The Patient/Resident shall indemnify and hold the Facility harmless from any and all claims, suits ar,( actions made against the Facility by any person resulting from any damage or injury caused by thE Patient/Resident to any person ~r the property of any person or entity (including the Facility). 13. Patient/Resident's Handbook. The Patient/Resident acknowledges receipt of the Fac:lity'" Resident's Handbook and agrees to comply with such Rules and Regulations contained therein. Tr.e Patient/Resident acknowledges and agrees that he/she shall be responsible for and shall hold thE Facility harmless for any injuries or damages which are caused by the Patient/Resident's failure. Ie comply with such rules and re<;Julations. The policies, procedures, rules and reguiations regarcm, the following areas, among others, are detailed in the Resident's Handbook: WMc_oba.zd; t~lW. 4/9al P<l4. ',: " ,."Q<,f:'If",~,.. , ~=.....- ~'~ ~.~~, ~~~ "~~lllj.lliod;,.. I~< '-, i!i "'~,;.-}.~L" . FeBeral Resident Rights . Resident Responsibilities . Life Sustaining Treatment Policy · Medical/Nursing Education . Dental, Vision and Hearing Services . Interdisciplinary Care Conference · Utilization Review Meetings (if applicable) . Personal Laundry Policy , 'J .. . Barber /Belluty Services , " . Mail Policy . Voting Materials . Photo/Media Events . Personal Fund Account Procedure . Tobacco Policy . Grievance Procedures . State Resident Rights (if applicable) 14. GOVERNING LAW. THIS AGREEMENT SHALL BE GOVERNED AND CONSTRUED IN ACCORDANCE WITH THE LAWS AND REGULATIONS OF THE STATE WHERE THE FACILITY IS LOCATED. TO THE EXTENT ANY PROVISION HEREOF CONFLICTS WITH STATE LAW, STATE LAW SHALL CONTROL. THE STATE LAW ADDENDUM ATTACHED HERETO AS EXHIBITD SETS FORTH ANY DELETIONS FROM OR ADDITIONS TO, THIS AGREEMENT REQUIRED BY STATE LAW, WHICH AMENDMENTS SHALL BE A PART OF THIS AGREEMENT. 15. Miscellaneous. The provisions of this Agreement shall bind the parties, their respective executors, administrators, heirs, beneficiaries, and assigns. The waiver by either party of any breach or default . of this Agreement shall not operate as a waiver of any subsequent breach or default. The provisions ofthis Agreement shall be severable and the invalidity or unenforceability of any provision shall not affect the validity or enforceability of any other provision. This Agreement and all Exhibits are the entire agreement and any changes shall be in writing and signed by both parties. IN WITNESS WHEREOF, the parties hereto have executed this AdmiSS~ion Agreement as f the, day and year above written. . / ! I Responsible Party - Signature ReE:.~!; !L~~r- /0-/51'-- 99' Date Date ,I MHC.OOS.20 (Rev.4/96} pg 5 30i 3 '~--~, "~,,- .,",.~ .~ - , ~""'."" .-...~~~.......i~. ~. ~ '''''_~~k - "~ ~ .v 1 , (EXHIBIT A - RESPONSIBLEPARTY APPdtNTriIIENT) The Patient/Resident's Responsible Party may be any person legally responsible for the Patient/ Resident. A competent Patient/Resident shall not be required to designate a Responsible Party, Please check one of the four following, whichever is most appropriate. o I I The undersigned has been legally appointed guardian, conservator and/or holder of a power I of attorney to act on the behalf of the Patient/Resident and shall serve as Responsible Party I for the Patient/Resident. The undersigned has delivered to the Facility copies of the leg~1 I ~~~',-"'--''-'~'+'"' (-1--,-.;....,,.,,..,.;.;.....,,, 1 ;"YJ./h,-," '=10 tl,~ u 1 r-l:..,.... ........ "I""'~""" ':\ ~! "h lrlo f"" I ~ I llJ",'.-l'II:;:'-;;I,-,; ...;.:;.~I::>'~..:,'::J J1:",; ,.:;, c",.' ,,1::: L!1.,cLt.JlctL CO:F:,8,\-<:--"_,, c,n,-, , 0, ,.J,"-,.....r O. C', pO\f..er 0, . , atiorney of the Patient/Resident. In consideration of the Facility's agreement to admit the . Patient/Resident to the Facility, the undersigned, individuaHy and personally, hereby warrants, represents, covenants and agrees to the Conditions (as herein after set forth and defined). o The Patient/Resident does not have a legally appointed representative and wishes to give the responsibility to someone else. I hereby appoint as my representative (the "Responsible Party") and hereby authorize him/her to handle my finances, pay my expenses, receive my personal funds and, if I am unable, to execute the Admission Agreement on my behalf. Any signature of Patient/Resident or- Responsible Party on the Admission Agreement and/or this or any other exhibit or document attached thereto or referenced therein shall be considered binding on both the Patient/Resident and the Responsible Party. The undersigned hereby agrees to the Conditions (as herein after set forth and defined). o f Facility Representative Signature Patient/Resident - Signature Patient/Resident Printed Name Facility Representative - Printed Name & Titie Date Date The Patient/Resident is competent and does not have a court-appointed guardian, conser- vator or power of attorney and has not appointed a Responsible Party, but alone shall execute the Agreement. In consideration of his/her admission to the Facility, the undersigned hereby agrees, warrants and represents to the Conditions (as herein after set forth and defined). The Patient/Resident is mentally or physically incapable of executing this Agreement, handling his/her own affairs or appointing a Responsible Party and does not have a guardian, conser- I vator or durable power of attorney. The Patient/Resident's physician will certify in writing that the Patient/Resident is incapable of executing the Agreement and that pl~cement i.n the I Facility is appropriate. The undersigned voluntarily agrees, on behalf of the Patient/Resident, I to act and serve as Responsible Party for the Patient/Resident. In consideration of the Facility's I agreement to admit the Patient/Resident to the Facility, the undersigned individually hereby: warrants, represents, covenants and agrees to the Conditions (as herein after set forth and . defined). " 1 of 2 MHC-OOS-20 (Rev, 4/96) pg 6 Jl! ,2. 3. 4. 45' ::> 6. -,~,~,~ ~ t-;-' W"111'~'"_'~,.' 1, I, : Conditions (collectively referred to as "Conditions") 1. The assets of the Patient/Resident will be utilized to pay, when due, all costs incurred by the Patient/Resident at the Facility not covered by a third party payor, at the rates set forth in the Fee Schedule (Exhibit B). The Responsible Party will arrange for the provision of personal clothing and care supplies as needed or desired by the Patient/Resident and as required by the Facility. The assets of the Patient/Resident will be utilized to replace any and all furnishings or other property of the facility, other Patient/Residents or employees of the facility damaged by the Paljeni/F;esjwb.i~. All of the information, including but not limited to that contained on the attached Application for Residency, dated , 199 , and which is attached hereto and made part of this Exhibit and of the Admission Agreement, is true and accurate as of this date and all assets listed in the application are in fact available to the Patient/Resident for the Patient/Resident's care while at the facility. Neither the Responsible Party nor the Patient/Resident will take action to dissipate or other- wise transfer the Patient/Resident's assets and/or assets which are available for the Pat- ient/ Resident's care so as to prevent such assets from being used to pay for the care of the Patient/Resident while at the facility. When the assets available to pay for the Patient/Resident's care at the Facility are not sufficient to pay for the anticipated length of stay, the Responsible Party or Patient/Resident will so notify the Facility and will file, on behalf of the Patient/Resident, al\ applications and other documents necessary or advisable to qualify him/her for all third party payor programs for which he/she may be eligible, including Medicaid. If the Patient/Resident is a Medicaid Patient/Resident, that Responsible Party or Patient/ Resident will provide financial information regarding monthly credits, increases and decreases in the Patient/Resident's bank account(s) and other assets to the Facility to enable the Facility to provide requested data to Medicaid representatives. 7. If the Patient/Resident is covered by a third party payor, the assets of the Patient/Resident will be utilized to pay extra charges not covered by the third party payor in a timely manner, and to notify the administrator of the Facility of any problem anticipated in paying such charges. The undersigned understands and acknowledges that the Facility is relying upon the above Conditions in admitting the Patient/Resident to the Facility and understands and acknowledges that if the above warranties and representations are not true, or if the above covenants nd a ments are not complied with, the Facility will have detrimentally relied upon them)~id the acility II suffer financial harm and lOSS.. -frl7[: txfj Responsible Party - Signature /:>err Responsible Party - Printed Nam 10 -If> --1f Date ) __~_,,,~.__~w____,_____,_~...._....~_~~~~ MHC-OOS.20 (Rev. 4/96) pg 7 2012 ~ " ..~~-~ "' dit"~': Iiiiidij~'tlr;ijjt'- \ , ( EXHIBITB-FEESCHEDULE ) " 1, Daily Rate. The daily rate is $ The monthly rate equals the daily rate multiplied by the " number of days in the month, The aily rate is billed one month in advance and includes: ., Routine Nursing Care .. Linens .. Social Services " Meals (additional fees may apply) .. Activities .. Housekeeping " Room (circle one): Private Semi-Private Triple The following are paid by Medicare in addition to the items included in the daily rate: " Ap;1TOved Rehabilitative/Therapy Services " Approved Medications " Approved Nursing Supplies " Approved Equipm8;T' , I The following are paid by Medicaid in addition to the items included in the daily rate (to the extent covered and paid for by the state program): " A.p';Jroved Rehabi!it2.tive/Therapy Services .. Approved Nursing Supplies " Approved Routine Personal Hygiene Items/Services .. Other approved services/items covered and paid for under the state Medicaid program. " Approved Medications .. Approved Equipment 2. Supplemental Services & Supplies. The daily rate may not include the following items, which will be provided at request of Patient/Resident and/or by physician order at the rate set forth in the attached facility rate sheet and will be the responsibility of the Patient/Resident. ITEM RATE .. Private Room Based on location & level of care .. Prescription & Non-Prescription Drugs As determined by pharmacy .. Nursing & Personal Care Supplies See business office for current prices .. Transportation As determined by transport company .. Nursing Care (Other than ordinary nursing care) See attached fee list .. Physical, Occupational & Speech Therapies See attached fee list .. Phone, Cable TV, Newspaper, Barber/Beauty See attached fee list to Special Equipment See attached fee list to Bed Hold Fees See attached fee list .. Personal Laundry (Personal Clothing) See attached fee list .. Nutritional Supplements See attached fee list .. Alternative Nutrition (Tube Feeding, TPN, etc.) See attached fee list 3. Bed Hold Fee. The Facility charges a daily fee for reserving a bed whenever a Patient/Resident leaves the Facility. For Medicaid Patient/Residents, bed holds are pursuant to state law. 4. Other Charges. Because at Admission, the Facility is unable to ascertain all services/supplies which may be needed by and provided to the Patient/Resident, all additional costs/charges may not be listed here. If such services/supplies are provided to the Patient/Resident, the bill will reflect associated charges and he/she agrees to pay them in accordance with the Agreement. 6. Adjustment of Charges. The Facility may adjust any and all rates upon thirty (30) days prior written notice, or, in case of emergency or change in level of care, with such prior notice as is reasonably possible. Adjustments shall be deemed agreed to by the Patient/Resident unless the Facility is notified in writing to the contrary within ten (10) days after mailing such a notice. If the Patient/Resident does not consent to the rate adjustment, the Patient/Resident agrees to leave the I Facility no later than the day before the rate increase is effective. ) iilH.C-COa-2C {Rev.4/96} pg 8 1 ot 2 "'~-~ - "1lIliI' ~ ~ " ,--,....,.',,'- ~ (, :... . , 6. Refunds. Refunds shall be paid within thirty (30) days after discharge or transfer. 7. Funding Sources. The Facility makes no assurances that the Patient/Resident's care will be covered by any third party payor. 8. Payment Policy. All amounts due shall be paid promptly within ten (10) days of billing. Failure to pay any amount when due is a breach of this Agreement for non-payment of stay and grounds for ter'mination of this I\greement and discharge of the Patient/Resident. Any account not paid in full shall be subject to a one and one-half percent (1112%) service charge on the past due balance each month uniil the balance due is paid in full. This amounts to eighteen percent (18%) annually on the unpaid balance. It the maximum annual service charge allowed by state law is less than eighteen percent (i8%), the maximum interest rate allowed by state law shall apply. Should the Patient/Resident's account be turned over for collection to an attorney or collection agency, or should the Facility seek to interpret or enforce any other provision of the Agreement, the Patient/Resident agrees to pay all court costs and reasonable attorney's fees of the Facility if the Facility prevails. 9. Responsibilities. The Patient/Resident is responsible for, and shall pay, the daily rate and charges for supplemental services/supplies not paid by any third party, as well as applicable co-insurance and deductibles and all expenses of discharge or transfer. The daily rate may change if the Patient/ Resident is transferred to a different room or the level of care or payor status changes. The Patient/ Resident and/or Responsible Party will be notifiGd of the rate change. If the Patient/Resident or Responsible Party refuses supplemental services/supplies or to make payment for them, the Facility is released from all liability for harm which may result. Medicare Beneficiaries: The Patient/Resident understands that Medicare eligibility and coverage is established by federal guidelines which limit payment to a fixed number of days. If the Patient/Resident enters the Facility and the Medicare application is denied, the Patient/Resident shall be liable for all charges. The Patient/Resident is responsible for payment for items covered by Medicare supple- mental insurance and for applying for reimbursement from hiS/her insurer. Medicaid Beneficiaries: (circle correct number) 1) The Facility does not currently participate in the Medicaid program. Accordingly, persons who are admitted as another payor status will be unable to convert to Medicaid status. In order to facilitate proper discharge planning, the Patient/Resident and/or Responsible Party agree to provide the Facility with at least four (4) months rior written notice of the Patient/Resident's becoming eligible for the Me" rage or their being unable to pay p . I; OR currentl partici ates in the Medicaid pro If the Patient/Resident believes he/sn she shall rom tl e and submit all documents required to apply for coverage, including pre-admission approval. If Medicaid coverage is denied, the Patient/ Resident will be liable for all charges from the admission date. When Medicaid pays for only a portion of the incurred charges, the Patient/Resident shall be responsible for paying his/her portion, as determined by Medicaid regulations. This charge will be billed to the Patient/Resident by the Facility and shall be his/her responsibility. The Patient/Resident shall also be responsible for pay- ment of Facility's current charges for any requested non-Medicaid covered services/supplies. The Patient/Resident will provide financial information regarding monthly credits, increases/decreases in the Patient/Resident's bank account{s), and other assets to the Facility for provision to Medicaid representatives. MHC-aoa-20 (Rev.4/96) pg 9 2 of 2 , -- -"~,~~ - ~ ~' ......~ ..' .,'. ~~- \ ,,~ ~ ,\II ' . (EXHIBIT C.~ PHARMACY AGREEMENT ) The Facility has developed policies and procedures for drug therapy, distribution and control which provide for a uniform medication distribution system. The Facility has selected a pharmacy (the "Designated Pharmacy") to provide medication under such distribution system. The Facility reserves the right to change the Designated Pharmacy at any time. I The Patient/Res~dent i~. hereby notified t.hat the Facili.ty's parent. corporation (I.e., Manor HealthCare I Corp. 0;' one of Its affiliates) has a significant financial Interest In Vltallnk Pharmacy Servl:::es, Inc., I which operates under the following names: Vitalink, Northern Nursing Home Pharmacy, West End Family Pharmacy, Propac Pharmacy, Apothecary Pharmacy Services, Parker's Pharmacy, Home Intravenous Care and Brentview Pharmacy. The Facility may have selected one of these entities as the Designated Pharmacy. The Patient/Resident has the right to use any pharmacy so long as that pharmacy will furnish the same medication distribution system noted above, and comply with the Facility policies and pro- cedures and all applicable laws and regulations. For Medicaid Patient/Residents, the Designated Pharmacy will file claims for payment directly with the Medicaid Program for any covered claims. If the Patient/Resident utilizes a different pharmacy, the Patient/Resident must make arrangements with such pharmacy for similar filing of claims for payment. All charges shall be billed to the Patient/Resident or the Patient/Resident's third party payor directly and shall be payable in full. The Designated Pharmacy reserves the right to terminate any account for any reason after written notice of such intent has been given to the Patient/Resident. \0 The undersigned selects the Designated Pharmacy (as may be changed by the Facility r from time to time) as the supplier of medications prescribed for the Patient/Resident while at the Facility. The undersigned selects as the supplier of medications prescribed for the Patient/Resident while at the Facility. The undersigned understands and agrees that such pharmacy must comply in all respects with the Facility's uniform medication distribution system, all Facility policies and procedures and applicable law. If such pharmacy fails to do so, the undersigned shall be required to select another pharmacy. The above pharmacy shall acknowledge d agree in writing that it will comply with the Facility's uniform medication distributio stem, t e'Facility's policies and procedures and applicable law. ~ Responsible Party Signature 20 esponsible Party - Printed IO-{<( AjCj Date MHc.ooa-20 (Rev. 4/96) P910 "j of 1 . ~ '.:.~ -. , --- "_"~'k.,..:.' ." ii,;i , . , "',:" , -" '<"..,..' ""'>'^'b''''~1l','''<i;:.''' ," '< ,,' ",~,: ' ," h,".w,," ,,":;J.' '." '" ,",~" ",,,.:~_ ,<' . ",~;EXBIB1;r,,;D:,,;':STATE [jAW~~DDENDU ' ,,', - , "" " '", -- ",t ----~, " ,'" __ ,,,' , '" . '",'~'__ The Admission Agreement is amended in the following manner, in order to comply with state law and/or regulation: (Indicate additions to, and/or deletions from, the Admission Agreement required by state law. If no additions/deletions are necessary, indicate "NONE".) "NONE" MHC.ooa.20 (Rev.4/96) pg 11 1 of 1 ........' - -- u",: ~ ' , ''''', ~'~i,~lit!;~,:~. 'I 0\ I ~ , , , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HCR MANOR CARE, . Plaintiff NO. 01-3294 vs. CIVIL ACTION - LAW JOYCE A. HEFFELBOWER, Individually, and ROBERT HEFFELBOWER, Individually, and on Behalf of JOYCE A. HEFFELBOWER, Defendants CERTIFICATE OF SERVICE AND NOW, this 29th day of August, 2001, I, Daniel F. Wolfson, Esquire, do hereby certify that I have served a copy of the foregoing Amended Complaint upon the I, ! parties and/or counsel of record in the following manner and addressed as follows: CERTIFIED MAIL RETURN RECEIPT REQUESTED REGULAR MAIL POSTAGE PRE-PAID Mr. Robert Heffelbower 258 West North Street Carlisle, PA 17013 (Pro Se Defendant) Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PAl 701 3 (Counsel for Defendant, Joyce Hefflebower) I I 'I ~ Daniel F. Wolfson, Esquire WOLFSON & ASSOCIA 267 East Market Street York, PA 17403 (717) 846-1252 ID No. 206 I 7 Attorney for Plaintiff ~ IGf w. _,~ - -. , ~, -,,'--"~ >;"Y""'":2:d~,,~,:tiW'~I~!ifl__?!L[jt: ~!liUl4l~,~Mj;jr'dllt!_Filiti1 >",...'~-.lJ"bl ~ ,. , "" n' < .~ '^~"~ '" ~~~,...~I. 'mMn'._"- IIltII.I '''~JjI;lM''!:!.'~~ _ . . , ~~r l~~ ~': ; j ~Q c r::: > "-:;l-:' ~:;-:C) )-"'c": Z ::;! s-~ , . ,,- c::) , 1\; ~ (::J 2':" -'-;'- .', !ill . ' 0'<" d---"i.~, i.J;&F';c_';:;:"';,,'-,"'_".' '0' ,: "Gi" :,;" ", ,;, ','.':/;'~", ,'"o,;;,\&" ,J",~"',__ . :('-d r HCR MANOR CARE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW v. JOYCE A. HEFFLEBOWER, Individually, and on behaf of JOYCE A. HEFFLEBOWER, Defendants No. 01-3294 PRELIMINARY OBJECTIONS AND NOW, comes Joyce A. Hefflebower and pursuant to Rule 1028 of the Pennsylvania Rules of Civil Procedure offers the following Preliminary Objections: 1. Plaintiffs Complaint fails to comply with Rule 1028(a)(2) insomuch as it demands arbitration. 2. Rules 1301 et seq. of the Pennsylvania Rules of Civil Procedure govern arbitration generally. 3. The rules of arbitration allow the local jurisdiction wide latitude in creating administrative and procedural rules thereunder and in setting the jurisdictional limit for compulsory arbitration. 4. Cumberland County Rule of Procedure 1301-1 et seq. provides for compulsory arbitration when the amount in controversy is less than $25,000. 5. The Cumberland County Rules of Procedure do not create any apparatus to voluntarily submit a case to arbitration or to demand arbitration if the amount in controversy is in excess of $25,000. 6. Plaintiff, in its prayer for relief, asks for $38,097.89 as liquidated damages. .. ""'."- '''' -"',;, ,": ;,,<,,;->~ ,'''- """""'--'-!'_'''ii,'~"<,, "~-" - i61 7. The Plaintiff has improperly demanded arbitration and insomuch that Plaintiff has demanded arbitration and the amount in controversy is in excess of $25,000, the Complaint is not in compliance with the Cumberland County Rules of Court as read in conjunction with the Pennsylvania Rules of Civil Procedure. WHEREFORE, Defendants respectfully request that this Court strike Plaintiff's Complaint for failure to substantially conform with the Cumberland County Rules of Court and the Pennsylvania Rules of Civil Procedure. Respectfully submitted, /-- , Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, P A 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Defendants <0 ,~~'^ "_h'~' ,~"'^'"..'~U~,~"', ',"k__c~ ,,", - , "';"" """"""""'''':;'''''''''''';'~I~',',,,,,,,- "'-"'"'".;,.: t HCR MANOR CARE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW v. JOYCE A. HEFFLEBOWER, Individually, and on behaf of JOYCE A. HEFFLEBOWER, Defendants No. 01-3294 CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Defendant, do hereby certify that I this day served a copy of the Answer to Complaint upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Daniel F. Wolfson, Esquire Wolfson & Associates, P.C. 267 East Market Street York, PA 17403 :::7.---- Karl E. Rominger, Esquire Attorney for Defendant Dated: October 9, 2001 _~'~__t'lIiiiaiI!mlr~~'~ -.: :~""~""',~,.,;.c.,';;;'~~~M-.tM"" , "i'_' .~~,~",. C;/ U?f c"<, ,",<<'" ~,,<,=~, _~ o. .,0'0._,'."0"0"'_"'_'__'0'__'"' ,."., " o <;;;. ~DiT," ;5', Ci)> ---";- ~r ~~ i~: ::;J <-- .', ,~, """~ ,,'~ ,~o, "O~ . D W :'.) ._,-~ , \,.8 [\) :.11 " ",' ..../] ...,,;::- --':':, . I~ It I....'.. :! ]! , I.',',' , ~! I~I Ii J .~"" ~ " - -, '~~ ~ ""i'''-' '-"'1:1 <: : l~DD<<DDDDDDDD"ODD~D'D'D"D'D'DDDDDDDDDDDDDDDDDDDDDDDDDD0000000000000000000000000 DDDDDDDDDDDDDDODDODDOODDDD'OODDDBODDDDDDDDDDOOODIN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HCR MANOR CARE, Plaintiff vs. NO. 01-3294 JOYCE A. HEFFELBOWER, Individually, and ROBERT HEFFELBOWER, Individually and on behalf of JOYCE A. lJEFFELBOWER, Defendants CIVIL ACTION - LAW TO: HCR MANOR CARE c/o Daniel F. Wolfson, Esquire WOLFSON & ASSOCIATES, P.C. 267 East Market Street York, PA 17403 NOTICE TO PLEAD You are hereby notified to file a written response to the enclosed New Matter within twenty (20) days from service hereof or a judgment may be entered against you. Dated: I fc, tJCid.68r' / ~ / / / Robert Heffelb 258 West North tr et Carlisle, PA 17013 Telephone: (717) 258-1660 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HeR MANOR CARE, Plaintiff vs. NO. 01-3294 JOYCE A. HEFFELBOWER, Individually, and ROBERT HEFFELBOWER, Individually and on behalf of JOYCE A. HEFFELBOWER, Defendants CIVIL ACTIoN - L~w DEFBNDANT ROBERT HEFFELBOWER' S l'.NSWER lINO m;W lMTn:R TO Ji'LArNTIFF'S AMENDJi:P COMPLAINT lIND NOW comes the Defendant, Robert Heffelbower, Individually and on behalf of Joyce A. Heffelbower, pro se, and responds to Plaintiff's Amended Complaint, as follows: 1. Defendant Robert Heffelbower lacks information sufficient to form a Qell~~ ~$ _0 tAe t~yth of th& ~ve~mefit$ $et fQ~th In Fat~graph 1 Qf Fl~lnelff'~ Amended Complaint. They are specifically denied, and strict proof thereof is demanded. 2 _ Admi ttect. 3. Admitted. 4. The averments set forth in Paragraph 4 of Plaintiff's Amended Complaint refer or relate to documents filed of record which speaks for itself. Any mi ~rp.prp,$pT'l.r,rtf,i.!)n. n.-f thp., r.D.nt-p.nt-.$. rhB,Y.'~fIf i $. $-D-8r5 -r-i r.,a1.ly df'D,,11?.d--;< ,::m.o Rrri r.t- proof thereof is demanded. 5. The averments set forth in Paragraph 5 of Plaintiff's Amended Complaint refer or relate to documents filed of record which speaks for itself. Any misrepresentation of the contents thereof is specifically denied, and strict proof thereof is demanded. 6. Defendant Robert Heffelbower lacks information sufficient to form a belief as eo the truth of the averments set forth in Paragraph 6 of Plaiheiff's Amended Complaint. They are specifically denied, and strict proof thereof is demanded. 7. Admitted in part, denied in part. It is admitted that Defendant Robert Heffelbower is the son of Defendant Joyce Heffelbower. It is specifically denied that Defendant Robert Heffelbower represented himself to be the legal representative and/or ResponsIble Party for Defendant Joyce Heffelbower, and strict proof thereof is demanded. The question of whether Defendant Robert Heffelbower is the legal representative and/or Responsible Party for Defendant Joyce Heffelbower is a conclusion of law to which no response is required. To the extent that any response is required, this allegation is speci.fically denied and strict proof thereof is demanded. By way of further answer, Defendant Robert Heffelhower merely assisted his mother with paperwork necessary for her admission into the Plaintiff's facility. In doing so, Defendant Robert Heffelbower followed the directions and instructions given to him by the Plaintiff. 8. Denied. It is specifically denied that on or about October i8, 1999, through the present, Defendant Robert Reffelbower was a health care resident of Plaintiff, Where she did receive varioUs necessary residential ~~ . ~-'- , ~ "<~ - -~ <~-~'~"- ~^' ,"'="",;.-~~^~ . , -, ~''', health care services and health care treatment by Plaintiff and that an itemization of such services is attached to Plaintiff's Amended Complaint as Exhibit "An, and strict proof thereof is demanded. By way of further answer, Defendant Robert Heffelbower admits that Defendant Joyce Heffelbower was a health care resident of Plaintiff from on or about October 18, 1999, through the present. Defendant Robert Heffelbower lacks information sufficient to form a belief as to the truth of any averment that Defendant Joyce Heffelbower received various necessary residential health care services and health care treatment by Plaintiff, any averment that she received the services itemized on the document attached to Plaintiff's Amended Complaint as Exhibit "A", and any averment that such services were necessary, proper and/or authorized to be given. These allegations are specifically denied, and strict proof thereof is demanded. 9. The averments set forth in Paragraph 9 of Plaintiff's Amended Complaint refer or relate to a document which speaks for itself. Any misrepresentation of the contents thereof is specifically denied, and strict proof thereof is demanded. By way of further answer, at the time of signing of the Admission Agreement, Plaintiff represented to Defendant Robert Heffelbower that Defendant Robert Heffelbower would not be financially responsible for any charges of any kind or nature whatsoever relative to Defendant Joyce Heffelbower. 10. Denied. It is specifically denied that by executing said Admission Agreement, Defendant Robert Heffelbower did acknowledge that Plaintiff would be relying on the "Conditions", which are incorporated into the Admission Agreement in admitting the Patient, and that if Defendant Robert Heffelbower did not follow through with said Conditiohs, Plaintiff will have detrimentally relied upon said Conditions and Plaintiff would suffer financial harm and loss, and strict proof thereof is demanded. With respect to the allegation concerning Exhibit "B" to Plaintiff's Amended Complaint, see Paragraph 9, above. By way of further answer, at the time of signing of the Admission Agreement, Plaintiff represented to Defendant Robert Heffelbower that Defendant Robert Heffelbower would not be financially responsible for any charges of any kind or nature whatsoever relative to Defendant Joyce Heffelbower. . . . 11. The averments set forth in Paragraph 11 of plaintiff's Amended Complaint refer or relate to a document which speaks for itself. Any misrepres~ntatibn of the contents th~revf is specifically denied, and strict proof thereof is demanded.. By way of further anSv-!eri at the time of signing of the Admission Agreement, Plaintiff represented to Defendant Robert Heffelbower that Defendant Robert Heffelbower would not be financially responsible for any charges of any kind or nature whatsoever relative to Defendant Joyce Heffelbower. See Paragraph 9, above. 12. The averments set forth in Paragraph 12 of Plaintiff's Amended Complaint refer or relate to a document which speaks for itself. Any misrepresentation of the contents thereof is specifically denied, and strict proof thereof is demanded. By way of further answer, at the time of signing of the Admission Agreement, Plaintiff represented to Defendant Robert Heffelbower that Defendant Robert Heffelbower would not be financially responsible for any charges of any kind or nature whatsoever relative to Defendant Joyce Heffelbower. Further, Plaintiff represented to Defendant Robert Heffelbower, both at the time of signing of the Admission Agreement and thereafter, that Plaintiff would complete any and all third-party applications for all third- party payor programs, inCluding Medicaid. See Paragraph 9, above. 13. Denied. It is specifically denied that Plaintiff submitted to Defendants a copy of the itemization of services accurately showing all debits and credits for transactions with Plaintiff, and strict proof thereof is demanded. By way of further answer, Defendant Robert Heffelbower received several statemen~urporting to show amounts due and owing to Plaintiff by Defendant Joyce ~ffelbower, but these statements conflicted with each other such that Defendant Robert Heffelbower was unable to ascertain exactly what, if anything, Plaintiff was claiming was due and owing. Moreover, Plaintiff represented to Defendant Robert Heffelbower that no monies would be due and owing to Plaintiff in that all charges would be covered by Medicaid. 14. Denied. It is specifically denied that Defendants did not object to the above-mentioned Statement of Accounts submitted by Plaintiff to Defendants, and strict proof thereof is demanded. By way of further answer, see Paragraph 13, above. 15. Denied. It is specifically denied that as of the date of the Complaint, the balance due, owing and unpaid on Defendant Joyce Heffelbower's account as a result of said charges, is the sum of Twenty-Nine Thousand Three Hundred Six and 07/100 Dollars ($29,306.07), and strict proof thereof, and strict proof thereof is demanded. By way of further answer, it is specifically denied that any amount is due and owing from either Defendant to the Plaintiff, and strict proof thereof is demanded. See also Paragraphs 8 through 14, above. 16. Denied. It is specifically denied that 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 Defendant Joyce Heffelbower's account balance, all to the damage and detriment of the Plaintiff, and strict proof thereof is demanded. It is specifically denied that Defendant suffered any damages whatsoever as a result of the actions of Defendant Robert Heffelqower, and strict proof thereof is demanded. By way of further answer, see Paragraph 15, above. 17. Denied. It is specifically denied that Plaintiff has made numerous requests to Defendant Robert Heffelbower, as the Legal Representative and/or Responsible Party for Defendant Joyce Heffelbower, demanding that the sums due and owing to Plaintiff be paid, and Defendant Robert Heffelbower, as the Legal Representative and/or Responsible Party for Defendant Joyce Heffelbower, has ignored his fiduciary obligation to pay necessary and appropriate bills and obligations for his mother, Defendant Joyce Heffelbower, or to apply for MedIcaid on behalf of his mother Defendant Joyce Heffelbower, and strict proof thereof is demanded. The questions of whether Defendant Robert Heffelbower has any fiduciary duties with regard to Defendant Joyce Heffelbower, as well as the extent of any such duties and whether they were breached are conclusions of law to which no response is required. To the extent that any response is required, they are specifically denied, and strict proof thereof is demanded. By way of further answer, see Paragraphs 8 through 16, above. 18. The allegations contained in Paragraph 18 of Plaintiff's Amended Complaint constitute conclusions of law to which no response is required. To the extent that any response is required, they are specifically denied, and strict proof thereof is demanded. By way of further answer, see Paragraphs 8 through 17, above. 19. The allegations contained in Paragraph 19 of Plaintiff's Amended Complaint constitute conclusions of law to which no response is required. To the extent that any response is required, they are specifically denied, and strict proof thereof is demanded. By way of further, see Paragraphs 8 through 18, above. Moreover, at Plaintiff's request, Defendant Robert Heffelbower delivered a check to Plaintiff from Defendant Joyce Heffelbower's account in the amount of $3,281.00 on August 9, 2000. Plaintiff duly cashed the check. At that time, Plaintiff represented to Defendant Robert Heffelbower that after delivery of that check all charges relating to Defendant Joyce Heffelbower's account would be taken care of and that no further charges would accrUe. Plaintiff also represented that it would complete and submit all necessary paperwork for Medicaid. 20. Defendant Robert Heffelbower lacks information sufficient to form a belief as to the truth of the averments set forth in Paragraph 20 of Plaintiff's ~~" "'- co , "--"" "41'; ':;~"- ",",""""' - -"" ;" " '0 ';".' ';:i] , Amended Complaint. They are specifically denied, and strict proof thereof is demanded. 21. The averments set forth in Paragraph 21 of Plaintiff's Arrtended Complaint refer or relate to a doc~~ent. Any misrepresentation of the contents t-he:reof 4.s sp'?c"i,fici!l.l,ly G'?l1,;ied, and strict proof thereof is demanded~ By way of further answer.. it is specifically denied that the "Fee Agreement" was executed by either Defendant and that it is binding on either Defendant, and strict proof thereof is demanded. 22. Defendant Robert Heffelbower lacks information sufficient to form a belief as to the truth of the averments set forth in Paragraph 22 of Plaintiff's Amended Complaint. They arc apccifically denied, and strict proof thereof is demanded. By way of further answerf it is specifically denied that Defendant Robert Heffelbower is liable for Plaintiff's attorneys fees and that Plaintiff has incurred any attorneys fees, and strict proof thereof is demanded. 23. Defendant Robert Heffelbower lacks information sufficient to form a belief as to the truth of the averments set forth in Paragraph 23 of Plaintiff's Amended Cornplaint_ They are specifically denied, and strict proof thereof is demanded. See also Paragraph 22, above. 24. Denied. It is specifically denied that all ,conditions precedent to bringing of this action have be€n performed by Plaintiff, and strict proof, thereof is demanded. 25. The allegations contained in Paragraph 25 of Plaintiff's Amended Complaint constitute conclusions of law to which no response is required. To the extent that any response is required, they are specifically denied, and strict proof thereof is demanded. WHEREFORE, Defendant Robert Heffelbower requests that judgment be entered in his favor and against the Plaintiff, and that he be awarded costs and such other relief as this Court deems just and equitable. New Matter 26. The answer-s and allegations set forth in Paragraphs 1 through 25, -abov,e, -ar,e incorpor.ated herein by r.ef,erence ,as though fully S€t forth. ,).7:, 'D'$'fend&y;),t ',"Rob~:rt ,Heffel.b:ower's Qnly role in this ,matter was to assist his mother, Defendant Joyce Heffelbower, with paperwork necessary for her admission into the Plaintiff's facility. In doing so, Defendant Robert Heffelbower followed the directions and instructions given to him by the Plaintiff. 28. Plaintiff represented to Defendant Robert Heffelbower that Defendant RobQrt HQffGlbowcr would not be financially rC5pon~iblc for any charges of any kind or nature whatsoever relative to Defendant JQyne HA-ffelbQwer~ 29. Plaintiff represented to Defendant Robert Heffelbower, both at the time of signing of the Admission Agreement and thereafter, that Plaintiff would complete any and all third-party applications for all third-party payor programs, including Medicaid. 30. Defendant Robert Heffelbower received several statement purporting to show amounts due and owing to Plaintiff by Defendant Joyce Heffelbower, but these statements conflicted with each other such that Defendant Robert Heffelbower was unable to ascertain exactly what, if anything, Plaintiff was claiming wag due and owing. 31. Plaintiff represented to Defendant Robert Heffelbower that no wnnies would be due and owing to Plaintiff in that all charges would be covered by Medicaid. 32. At Plaintiff's request, Defendant Robert Heffelbower delivered a check to Plaintiff from Defendant Joyce Heffelbower's account in the amount of $3,281.00 on August 9, 2000, which check Plaintiff duly cashed. '. 33. At that time, Plaintiff represented to Defendant Robert Heffelbower that after delivery of that check all charges relating to Defendant Joyce Heffelbower's account would be taken care of and that no further charges would accrue. Plaintiff also represented that it would complete and submit all necessary paperwork for Medicaid. 34. Plaintiff's acceptance of the check referred to above constitutes a novation of any agreement which allegedly existed prior thereto and/or an accord and satisfaction. 35. As a result of Plaintiff's acceptance of the check as aforesaid, Plaintiff is estopped from claiming any additional alleged damages from Defendants. 36. The statute of Frauds requires that a writing is required in order to hold one liable for the alleged debt of another. 37. Plaintiff has not produced any writing in which Defendant Robert Heffelbower agreed to be financially responsible for any alleged debt of Defendant Joyce Heffelbower. 38. Accordingly, Plaintiff's Amended Complaint is barred in whole or in part by the Statute of Frauds. 39. No services were performed for or on behalf of Defendant Robert Heffelbower by the Plaintiff. 40. Plaintiff has no basis for the alleged liability of Defendant Robert Heffelbower. 41. Under Pennsylvania law, each party must bear its own attorneys fees absent some statutory authority or agreement. 42. No statutory authority or agreement exists which would provide a basis for Plaintiff's claim for attorneys fees against Defendant Robert Heffelbower. 43. Plaintiff's Amended Complaint is barred in whole or in part by the applicable statute of Limitations. 44. Defendant Robert Heffelbower did not owe any fiduciary duty to the Plaintiff. 45. In the alternative, in the event that Defendant Robert Heffelbower did owe a fiduciary duty to the Plaintiff, Defendant Robert Heffelbower did no breach any such duty and Plaintiff did not suffer any damages from any alleged breach. 46. Plaintiff's Amended Complaint is barred in whole or in part by the doctrines of novation and/or accord and satisfaction. 47. Plaintiff's Amended Complaint is barred in whole or in part by the doctrine of consent. 48. Plaintiff's Amended Complaint is barred in whole or in part by the doctrines of estoppel, laches and/or waiver. 49. Any alleged agreement that Plaintiff had with Defendant Robert Herfelbower lacked consideration. 50. Plaintiff's Arr~nded Complaint is barred in whole or in part by the doctrine of failure of consideration. 51. Plaintiff's ~"'ended Complaint is barred in whole or in part by the doctrine of impossibility of performance. 52. Plaintiff's Amended Complaint is barred in whole or in part by the doctrine of justification. 53. Plaintiff's Amended Complaint is barred in whole or in part by the doctrines of payment andior release. 54. Plaintiff's Amended Complaint is barred in whole or in part by the doctrines of payment and/or release. 55. Plaintiff's Amended Complaint is barred in whole or in part by the doctrines of contributory and/or comparative negligence, andior by Plaintiff's assumption of the risk. - '"' "~ . ' '." ,-O,i. _, ',~.,,,,,c. ~"_' ""~j' '. 56. Plaintiff's Amended Complaint fails to state a claim against Pefendant Robert Heffelbower upon which relief can be granted. WHEREFORE, Defendant Robert Heffelbower requests that judgment be entered in his favor and against the Plaintiff, and that he be awarded cost and such other relief as this Court deems just and equitable. Dated: /J.p &G-+4er, zco/ I ( ",:' "'-" ;:,- ,,'j,,~' ,,'''t~~ '-"'''0 >~>:w,"" ,', 0 ',._';',' ,,' '. CERTIFICATE OF SERVICE I hereby certify that on the/~ day of October,2001 001 copies of the foregoing Preliminary Objections were served upon the following by United States first Class mail, postage prepaid, addressed as follows: Daniel F. Wolfson, Esquire WOLFSON & ASSOCIATES, P.C. 267 East Market Street Yo.rk, PA 17403 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 Robert Heffelbo r, 258 West North Str Carlisle, PA 1701 Tell'phonl': (717) 258~1660 - ~' - "k '1" ~'~"d~''''',; ,;." "j.-~,,,-',.";';-_~',-_,',,-",', ii.', " VERIFICATION Robert Heffelbower hereby states that he is a Defendant in the forego' g and that the facts set forth herein are true, correct and accurate to the st of his knowledge, information and belief. He further understands that f se statements made herein are subject to the penalties set forth in 18 B. .5. Section 4904, relating to unsworn falsification to authorities. Dated: I &/ ~c.f-vber!UJo I Ro ert Heffelbower, 258 West North Str Carlisle, PA 1701 Telephone: (717) 258-1660 ~l.U"",~--",~~~ft~,~-,;"",~&.I:i1clili,~~",;wlli;',t~M<ll~,@llli~"'ti!,f!,CV4?ir"^^^,,"j~;',jl;ji,~lSil"i"ifm\i;'~~~~i~iOJ!~...i-'~ ~j,...',;." -- : ~J? 2 0 0 " s:: a --; ~w " f.~;g m --t ::u ZC -":Jrr1 0" '"<frO ~~ (S l~ ~c.J .,~J,C...J :.,. ~,c=+; )> ::>: ")- zO 2:~~ -0 'i! >c: E""':; _ ,~ -I ~ :::> ~ C~ ~,,"~~c~~~,_~ - , "-".~~ - .~, .