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Home My WebLink About07-3901THIS IS AN ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED TABAS & ROSEN, P.C. BY: LEWIS C. TRAUFFER, ESQUIRE Attorney I.D. #60267 Attorney for Plaintiff 1601 Market Street, Suite 2300 Philadelphia, PA 19103 (215) 569-5050 THE MILTON S. HERSHEY MEDICAL CENTER P.O. BOX 853 HERSHEY, PA 17033 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.07 - 3461 (2i VS LARRY WARAKSA 36 ESSEX ROAD CAMP HILL, PA 17011 CIVIL ACTION COMPLAINT - CIVIL ACTION NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717)249-3166 or(800)990-9108 COMPLAINT - CIVIL ACTION THE MILTON S. HERSHEY MEDICAL CENTER VS. LARRY WARARSA 1. Plaintiff is a non-profit corporation located at the address indicated in the caption hereof. 2. Defendant is an individual who resides at the address indicated in the caption hereof. 3. As the result of a certain medical condition, defendant was treated by the plaintiff on July 17, 2005 thru July 20, 2005. 4. The amounts, quantities and nature of said medical care, the dates on which said medical care was rendered, and the charges therefore are set forth in Exhibit "A" which is incor- porated herein as if set forth at length. 5. Said medical care was commensurate with the condition of defendant and was necessary for the health and welfare of defendant. 6. At or about the time of defendant's treatment by plain- tiff, implied, constructive and oral contracts arose between defendant and plaintiff by the terms of which defendant became obligated to pay plaintiff the charges for the medical care rendered by plaintiff to defendant. 7. Defendant refuses to pay the balance due although plaintiff has made demand that defendant do so. 8. As a result of the foregoing, there is due and owing from defendant to plaintiff the sum indicated in Exhibit "A" WHEREFORE, plaintiff demands judgment against defendant for the sum of $9,303.48 plus six percent (6%) interest per annum from the date of discharge to the date of judgment, record costs and non-record costs. TABAS & ROSEN, P.C. L S C. TRA FER, ESQUIRE Attorney for Plaintiff MS HERSHEY MEDICAL CENTER PAGE: 1 500 UNIVERSITY DRIVE HERSHEY, PA 17033 Statement on: 08/30/06 at 05:03 PM Guarantor: WARAKSA LARRY C 36 ESSEX RD CAMP HILL, PA 17011-0000 Patient: WARAKSA LARRY C Visit #: 6502176 -------------------------------------------------------------------------------- Date I Svc Code ( Description I Units Debits I Credits -------------------------------------------------------------------------------- 07/16/05 16502 ADULT LEVEL II TRAUMA 1 2805.00 07/16/05 37047 IV INF THERAPY UP TO 1 197.00 07/16/05 37048 IV INF THER EA ADDL H 8 784.00 07/16/05 46472 EMERGENCY VISIT, LEVE 1 559.00 07/16/05 46717 NONINVAS PULSE OX, MU 1 90.00 07/16/05 46924 IV INFUSION TX 0-1 HR 2 394.00 07/16/05 46925 IV INF TX,EA ADDL HR 2 196.00 07/16/05 70205 X5 OBS 5TH FLR M/S/HR 23 2024.00 07/16/05 101003 ABO BLOOD GROUP 1 20.00 07/16/05 101004 ANTIBODY SCREEN 1 45.00 07/16/05 101005 RH TYPE 1 19.00 07/16/05 104002 ALCOHOL (ETOH), BLOOD 2 98.00 07/16/05 104009 AMYLASE, BLOOD 2 84.00 07/16/05 104042 CREATININE, BLOOD 1 13.00 07/16/05 104060 GLUCOSE, BLOOD 1 12.00 07/16/05 104131 POTASSIUM (K), BLOOD 1 13.00 07/16/05 104145 SODIUM (NA), BLOOD 1 13.00 07/16/05 104711 DRUG SCREEN, URINE 1 92.00 07/16/05 105052 PARTIAL THROMBOPLAS T 1 36.00 07/16/05 105059 PROTHROMBIN TIME 1 22.00 07/16/05 105657 CBC W/PLT/DIFF AUTO 1 36.00 07/16/05 245963 DIAZEPAM 5 MG 1 3.00 07/16/05 246021 BACITRACIN 15 GM 1 4.35 07/16/05 246170 FOLIC ACID 1 MG 1 3.00 07/16/05 246705 MORPHINE SULFATE 4 MG 2 6.00 07/16/05 246706 MORPHINE SULFATE 2 MG 1 3.00 07/16/05 250022 THIAMINE 100MG 1 3.00 07/16/05 250667 KETOROLAC TROMETHAMIN 2 3.00 07/16/05 273737 PANTOPRAZOLE 40 MG TA 1 3.00 07/16/05 307101 CHEST 1 VIEW. 1 114.00 07/16/05 307205 C-SPINE 2-3 VIEWS 1 147.00 07/16/05 307209 T-SPINE 2 VIEWS 1 147.00 07/16/05 307213 L-SPINE 2-3 VIEWS 1 207.00 07/16/05 307220 PELVIS 1-2 VIEWS 1 150.00 07/16/05 310501 CT HEAD UNENHANCED 1 719.00 07/16/05 310534 CT MULTIPLANAR 3D 1 544.00 07/16/05 310560 CT C-SPINE UNENHANCED 1 797.00 07/16/05 621054 IV LACTATED RINGERS 1 4 24.00 07/16/05 622023 IRRIGATION SOD CHL 0. 1 6.00 07/16/05 627070 IV EXT SET 90" W/FLAS 2 34.00 07/17/05 10223 P PRIVATE MED/SURG RM 1 1180.00 07/17/05 37048 IV INF THER EA ADDL H 8 .784.00 -------------------------------------------------------------------------------- - Continue - MS HERSHEY MEDICAL CENTER PAGE: 2 500 UNIVERSITY DRIVE HERSHEY, PA 17033 Statement on: 08/30/06 at 05:03 PM Guarantor: WARAKSA LARRY C 36 ESSEX RD CAMP HILL, PA 17011-0000 Patient: WARAKSA LARRY C Visit #: 6502176 --------------------------------------P----------------------------------- - Date Svc Code Description Units Debits ---Credits--I --------------------------------------------------------------- 07/17/05 246170 FOLIC ACID 1 MG 1 3.00 07/17/05 246705 MORPHINE SULFATE 4 MG 2 6.00 07/17/05 246706 MORPHINE SULFATE 2 MG 1 3.00 07/17/05 250022 THIAMINE 100MG 1 3.00 07/17/05 250667 KETOROLAC TROMETHAMIN 6 9.00 07/17/05 273737 PANTOPRAZOLE 40 MG TA 1 3.00 07/17/05 347038 MRI L SPINE UNENHANCE 1 1571.00 07/17/05 347039 MRI T SPINE UNENHANCE 1 1571.00 07/17/05 621054 IV LACTATED RINGERS 1 4 24.00 07/18/05 10223 P PRIVATE MED/SURG RM 1 1180.00 07/18/05 246170 FOLIC ACID 1 MG 1 3.00 07/18/05 246705 MORPHINE SULFATE 4 MG 1 3.00 07/18/05 249402 CYCLOBENZAPRINE 10MG 3 9.00 07/18/05 250022 THIAMINE 100MG 1 3.00 07/18/05 250092 OXYCODONE APAP 1TAB 6 27.75 07/18/05 273737 PANTOPRAZOLE 40 MG TA 1 3.00 07/18/05 307213 L-SPINE 2-3 VIEWS 1 207.00 07/18/05 621054 IV LACTATED RINGERS 1 1 6.00 07/19/05 308 INITIAL EVALUATION-OT 1 151.00 07/19/05 701 BRUSH LONG BACK SCRUB 1 12.00 07/19/05 716 BOK TRIGGER REACHER 1 24.00 07/19/05 719 STOCKING AID 1 24.00 07/19/05 766 E-Z SLIDE SHOE HORN 2 1 13.00 07/19/05 1001 INTIAL EVALUATION-PT 1 151.00 07/19/05 10223 P PRIVATE MED/SURG RM 1 1180.00 07/19/05 246170 FOLIC ACID 1 MG 1 3.00 07/19/05 249402 CYCLOBENZAPRINE 10MG 3 9.00 07/19/05 250022 THIAMINE 100MG 1 3.00 07/19/05 250092 OXYCODONE APAP 1TAB 6 27.75 07/19/05 272811 DALTEPARIN 2500U/0.2M 2 91.50 07/19/05 273737 PANTOPRAZOLE 40 MG TA 1 3.00 07/20/05 434 THERAPEUT ACTIVITIES 1 50.00 07/20/05 1072 GAIT TRAINING 15MIN 2 100.00 07/20/05 11531 INSTR ADAP EQUIPMENT 1 50.00 07/20/05 246170 FOLIC ACID 1 MG 1 3.00 07/20/05 246470 SENNA CONCENTRATE TAB 1 3.00 07/20/05 249402 CYCLOBENZAPRINE 10MG 1 3.00 07/20/05 250022 THIAMINE 100MG 1 3.00 07/20/05 250092 OXYCODONE APAP 1TAB 4 18.50 07/20/05 272811 DALTEPARIN 2500U/0.2M 1 45.75 07/20/05 273737 PANTOPRAZOLE 40 MG TA 1 3.00 08/31/05 902040 AUTO/WORK COMP PAYMEN -1 Continue - 3659.57- f _.2i MS HERSHEY MEDICAL CENTER PAGE: 3 500 UNIVERSITY D RIVE HERSHEY, PA 17 033 Statement on: 08/30/06 at 05:03 PM Guarantor: WARAKSA LARRY C 36 ESSEX RD CAMP HILL, PA 17011-0000 Patient: WARAKSA LARRY C Visit #: 6502176 ---------- Date --------------- I Svc Code I --------------------- Description ---------- I Units) - --------- Debits -- ----- --------------- I Credits --------------- ---------- 11/30/05 --- ----------- 920125 - --------------------- HOSP MA 2ND INS W/O -------- -1 - -- 6076.55- 05/31/06 980090 HOSPITAL BAD DEBT W/O -1 9303.48- 05/31/06 980091 HOSPITAL BAD DEBT PLA 1 9303.48 ---- - -- ------------- ------------------------- * - Not posted --------------------- ---------- -- -- -- Balance: --------- 9303.48 --------------- pg?,Kgp?, LARRY #7002337 $9,303.48 (Hosp) VERIFICATION LINDA SCHLADER hereby states that she is the Team Manager, Customer Service of the Milton S. Hershey Medical Center and verifies that the statements made in the foregoing pleading are true and correct to the best of her knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. 4 LINDA SCHLADER DATE : / JZ.) 0 4-1 1 -.per ?J r 1 -w. d n C ?.a v W .G` ?i M 00 SHERIFF'S RETURN - REGULAR CASE NO: 2007-03901 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MILTON S HERSHEY MEDICAL CENTE VS WARAKSA LARRY GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WARAKSA LARRY the DEFENDANT , at 1004:00 HOURS, on the 20th day of July , 2007 at 36 ESSEX ROAD CAMP HILL, PA 17011 LARRY WARAKSA by handing to 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 18.00 Service 40.32 Affidavit .00 Surcharge 10.00 .00 $?Io'o?? 68.32 Sworn and Subscibed to before me this of day So Answers: R. Thomas Kline 07/23/2007 TABAS & ROSEN By: Deputy Sh ff A. D. ` "f'ABAS & ROSEN, P.C. BY: LEWIS C. TRAUFFER, ESQUIRE ID NO.: 60267 1601 Market Street, Suite 2300 PHILADELPHIA, PA 19103 215-569-5050 The Milton S. Hershey Medical Center P.O. Box 853 Hershey, PA 17011 VS. Larry Waraksa 36 Essex Road Camp Hill, PA 17011 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 07-3901 ORDER FOR JUDGMENT FOR WANT OF AN ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in the sum of $10,466.51 in favor of the Plaintiff(s) in the above entitled matter for failure of the Defendant(s) to file an Answer to Plaintiff(s) Complaint in Civil Action and assess Plaintiff(s) damages as follows: Amount of Claim: Interest at 6% per annum from date of discharge 7/20/05 $ 9,303.48 $ 1,163.03 Total: I assess damages as above Pro Prothonotary ,..-.. - e y certify that the ................. 10 )lay letter under R.C.P.R. 237.1 was forwarded to Defendant Larry Waraksa $ 10,466.51 Attorney or Plaintiff(s) I.:?-r.. .certify that the above names are correct and the Precise Residence Address of the Judgment creditor is Address 36 Essex Road, Camp Hill, PA 17011 Date August 10, 2007 Address: Same Address of Defendants: Same A MILTON S. HERSHEY MEDICAL CENTER VS. LARRY WARAKSA COMMONWEALTH OF PA COUNTY OF CUMBERLAND LEWIS C. TRAUFFER being legally sworn, deposes and says: COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 07-3901 (a) that the defendant (s) is/are not in the Military or Naval Service of the United States or or of its allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil relief action of Congress of 1940 as amended; (b) that defendant Larry Waraksa is over 21 years of age and resides at: 36 Essex Road, Camp Hill, PA 17011 and is employed in Private Business. (c) that defendant is over 21 years of age and resides at: and is employed in Private Business. Affidavit has ascertained the foregoing information by inquiry and belief and makes this Affidavit with due authority. Sworn to and subscribed before me on this 22' day of August, 2007. L WIS C. TkAUFFER, ESQUIRE Attorney for the Plaintiff o NOTARY PUBLIC ?AAWA ti/.J"2"VRVx 141-40 " m JAf 1 ? . r x 4: vCTa2 AVO .? ?.?»?'„ ?• + ? !fir Y? ... .... . M TABAS & ROSEN, P.C. BY: LEWIS C. TRAUFFER, ESQUIRE ID No.: 60267 1601 Market Street, Suite 2300 Philadelphia, PA 19103 (215)569-5050 The Milton S. Hershey Medical Center Court of Common Pleas P.O. Box 853 Hershey, PA 17033 Cumberland County VS. : No.: 07-3901 Larry Waraksa 36 Essex Road Camp Hill, PA 17011 NOTICE OF INTENTION TO TAKE DEFAULT JUDGMENT TO: Larry Waraksa 36 Essex Road Camp Hill, PA 17011 DATE OF NOTICE/FECHA DEL AVISO: August 10, 2007 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGEMENT MAY BE ENTERED AGAINST YOU WITHOUT A BEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE.A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 AVISO IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENIA ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECTIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE D2EZ DIAS DE LA FECHA DE ESTA NOTIFICATION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS DERECHOS IMPORTANTES. USED DEBE LLEVAR ESTE AVISO A UN ABOGADO ENSEGUIDA. SI USTED NO TIENE ABOGADO, VAYA PERSONALMENTE O LLAME POR TELEFONO A LA OFICINA MENCIONADA A CONTINUACTION. ESTA OFICINA LE PUEDE PROVEER LA INFORMACION NECESARIA PARA CONTRATAR A UN ABOGADO. SI USTED CARECE DE LOS MEDIOS NECESARIOS PARA CONTRATAR A UN ABOGADO, DICHA OFICINA LE PUEDE SUMINISTRAR LA INFORMACION NECESSARIA ACERCA DE AQUELLAS AGENCIAS QUE OFRECEN SERVICIOS LEGALES A LAS PERSONAS QUE TIENEN DERECHO A RECIBIR TAL AYUDA GRATIS 0 A UNA CUOTA REDUCIDA. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 LEWIS C. TRAUFFER, ESQUIRE ATTORNEY FOR THE PLAINTIFF THIS CORRESPONDENCE IS BEING USED TO COLLECT A DEBT AND THE INFORMATION OBTAINED WILL 99 USED FOR THAT PURPOSE. "'s g3 v ra G .:.. I3 t,n {'V C -' I . OFFICE OF THE PROTHONOTARY CUMBERLAND COUNTY COURT HOUSE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 TO: Larry Waraksa 36 Essex Road Camp Hill, PA 17011 The Milton S. Hershey Medical Center P.O. Box 853 Hershey, PA 17011 VS. Larry Waraksa CUMBERLAND COUNTY No.: 07-3901 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. ,?" R. o" PROTHONOTARY 91,14107 JUDGMENT BY DEFAULT MONEY JUDGMENT JUDGMENT IN REPLEVIN JUDGMENT FOR POSSESSION JUDGMENT ON AWARD OF ARBITRATION TRANSFER OF JUDGMENT IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY LEWIS C TRAUFFER. ESQUIRE AT THIS TELEPHONE NUMBER: 215-569-5050 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND THE MILTON S. HERSHEY MEDICAL CENTER P.O. BOX 853 HERSHEY, PA 17011 V. LARRY WARAKSA 36 ESSEX ROAD CAMP HILL, PA 17011 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 07-3901 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County; (1) against LARRY WARAKSA defendant(s) and (2) against M & T BANK 44 4a" a96eis,1 K"i l' wi *w+ li s<;+a on , the _ _ J 1 WEST HIGH STREET A.CGoun4sf +i„gs acr?ahts, es iFico"fe- ee c(oposrf-, aa.J CARLISLE, PA 17013 &post+ boww& 4 4+,e de?r?t t., tit (aotsesscor? cQ garnishee(s). (3) AMOUNT DUE $ 9,303.48 INTEREST FROM 7/20/05 AT 6% PER ANNUM $1,163.03 (COSTS TO BE ADDED) $ TABAS & ROSEN, P.C. L WIS C. TRA FER, I.D. No. 60267 1601 Market Street, 2300 Philadelphia, PA 19103 (215) 569-5050 Attorney for Plaintiff F 10. c t oA ? a$ 0 C= Q -n ?.? ?, :? c?A oo F o; O Q Jjp 01 10 '`r • • " ? r COURT OF COMMON PLEAS CUMBERLAND COUNTY THE MILTON S. HERSHEY MEDICAL CENTER COURT OF COMMON PLEAS V. LARRY WARAKSA NO. 07-3901 WRIT OF EXECUTION NOTICE This paper is a Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. If you wish to exercise your rights, you must act promptly. Exempt Property. The law provides that certain property cannot be taken. Such property is said to be exempt. There is a debtor's exemption of $300.00. There are other exemptions which may be applicable to you. Attached is a summary of some of the major exemptions. You may have other exemptions or other rights. If you have an exemption, you should do the following promptly: (1) Fill out the attached exemption claim form and demand for a prompt hearing; (2) Deliver the form or mail it to the Sheriffs Office at the address noted. You should come to court ready to explain your exemption. If you do not come to court and prove your exemption, you may lose some of your property. Property Belonging to Another Person. If there is property at your residence (or in your bank account that belongs to another person or that you own with another person, you should notify that person so that he/she can file a Property Claim or other legal papers with the Sheriffs Office to prevent his/her property from being taken or sold at Sheriffs Sale to satisfy your debt. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD TO GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LLEVE ESTA DOCUMENTO A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE ABOGADO, VAYA PERSONALMENTE O LLAME POR TELEFONO A LA OFFICINA LE PUEDE PROVEER LA INFORMACION NECESARIA PARA CONTRATAR A UN ABOGADO. SI USTED CARECE DE LOS MEDIOUS NECESARIOS PARA CONTRATAR A UN ABOGADO, DICHA OFICINA LE PUEDE SUMINISTRAR LA INFORMACION NECESARIA ACERCA DE AQUELLAS AGENCIAS QUE OFRECEN SERVICIOS LEGALES A LAS PERSONAS QUE TIENEN DERECHO A RECIBIR TAL AYUDA GRATIS 0 A UNA CUOTA REDUCIDA The Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW (1) $300.00 Statutory Exemption (2) Bibles, school books, sewing machines, uniforms and equipment (3) Most wages and unemployment compensation (4) Social Security benefits (5) Certain retirement funds and accounts (6) Certain veteran and armed forces benefits (7) Certain insurance proceeds (8) Such other exemptions as may be provided by law WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-3901 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE MILTON S. HERSHEY MEDICAL CENTER, Plaintiff (s) From LARRY WARAKSA, 36 ESSEX ROAD, CAMP HILL, PA 17011 (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 GARNISHEE(S) as follows: M&T BANK, 1 WEST HIGH STREET, CARLISLE, PA 17013 ANY AND ALL ASSETS, INCLUDING, WITHOUT LIMITATION, CHECKING ACCOUNTS, SAVINGS ACCOUNTS, CERTIFICATES OF DEPOSIT AND SAFE DEPOSIT BOXES OF THE DEFENDANT IN THE POSSESSION OF THE GARNISHEE. 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 anyone 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 $9,303.48 L.L. $.50 Interest FROM 7/20/05 AT 6% PER ANNUM - $1,163.03 Atty's Comm % Due Prothy $2.00 Atty Paid $187.82 Plaintiff Paid Date: 9/20/07 (Seal) REQUESTING PARTY: Other Costs C s R. Long, Prothonota By: Lh., r, Deputy Name LEWIS C. TRAUFFER, ESQUIRE Address: TABAS & ROSEN, PC 1601 MARKET STREET, 2300 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-569-5050 Supreme Court ID No. 60267 CUMBERLAND COUNTY Re: Writ of Garnishment on Garnishee received by Manufacturers and Traders Trust Company, Garnishee The Milton's Hershey Medical Center Vs Larry Waraksa No. 07-3901 civil Responses to Interrogatories MANUFACTURERS AND TRADERS TRUST COMPANY, pro se, for its answer to the Interrogatories states: (Questions and Answers Pursuant to 14 Pa C.S.A. Rule 32531 1. At the time you were served or at any subsequent time, did you owe the defendant(s) 9 money or were you liable to defendant(s) on any negotioble or other written instrument, or diJ defendant(s) claim that you owed any money or were liable to defendant(s) for any re0 Answer: NO Yes No open accounts (,.?r ?/ Denies knowledge or information sufficient to form a belief as to thb'?? answer to the question. Q 2. At the time you were served or at any subsequent time, was there in your possession, custody or control or in the joint possession, custody or control of yourself or one or more other persons any property of any nature owned solely or in part by the defendant(s)? Answer: ? Yes X No ? Denies knowledge or information sufficient to form a belief as to the answer to the question. At any time you were served or at any subsequent time, did you hold legal title to any property of any nature owned solely or in part by the defendant(s) or in which defendant(s) held or claimed any interest? Answer: ? Yes X No ? Denies knowledge or information sufficient to form a belief as to the answer to the question. 4. At any time you were served or at any subsequent time, did you hold as a fiduciary any property in which the defendant(s) had an interest? Answer: ? Yes X No ? Denies knowledge or information sufficient to form a belief as to the answer to the question. At any time before or after you were served, did the defendant(s) transfer or deliver any property to you or to any person or place pursuant to your direction or consent and, if so, what was the consideration therefor? Answer: ? Yes. The consideration was X No ? Denies knowledge or information sufficient to form a belief as to the answer to the question. 6. At the time you were served or at any subsequent time, did you pay, transfer or deliver any money or property to the defendant(s) or to any person or place pursuant to the direction of defendant(s) against you? Answer: ? Yes X No ? Denies knowledge or information sufficient to form a belief as to the answer to the question. [Additional Questions and Answer (f any) ] If any of the following reasons are checked, the account(s) in question are not subject to attachment because: Account(s) No(s). are escrow account(s) for real estate taxes and insurance. [Field 121 has a right of set off against the account(s) which it hereby elects to assert. Other: [Consult with Counsel's Office and type in reason] MANUFACTURERS AND TRADERS TRUST COMPANY Dated: SEP $ 6 2007 Name: Lorr e? Maska Title: Legal Document Analyst M&T Bank - Legal Document Processing PO Box 844 Buffalo New York 14240 Phone(716)635-7721 Fax (716)635-7725 !^?.J ---:9 [? "i-2 t -"a =1 Ca __..-n ?,, ? Cw _ ?.. '? t'i _.? 7 ._.?{ SHERIFF'S RETURN - GARNISHEE CASE NO: 2007-03901 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND MILTON S HERSHEY MEDICAL CENTE VS WARAKSA LARRY And now KENNETH GOSSERT ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0009:38 Hours, on the 25th day of September, 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , WARAKSA LARRY in the hands, possession, or control of the within named Garnishee M & T BANK 1 WEST HIGH ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to ASHLEY TIMBROOK (SALES) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her . true and made Sheriff's Costs: So answer Docketing .00 Service .00 `,? A Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 . 0 0 ?/ o?s f b ? ?-.. 09/25/2007 Sworn and Subscribed to before me this day of By epu y er'f A.D TABAS & ROSEN, P.C. BY: LEWIS C. TRAUFFER I.D. #60267 1601 Market Street, Suite 2300 Philadelphia, PA 19103 (215)569-5050 Attorney for Plaintiff THE MILTON S. HERSHEY MEDICAL CENTER : COURT OF COMMON PLEAS VS. : CUMBERLAND COUNTY LARRY WARAKSA AND : NO.: 07-3901 M&TBANK Garnishee PRAECIPE TO DISSOLVE WRIT OF ATTACHMENT TO THE PROTHONOTARY: Kindly dissolve the Writ of Attachment regarding the above captioned case against M & T Bank only, Garnishee. L I C. TRA R, ESQUIRE Attorney for Plaintiff 6 4 00 q .. r ,.z, IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: LARRY C. WARAKSA Case No. 1-07-bk-03690 ' Debtor LARRY C. WARAKSA . Movant(s) V. Chapter 13 MILTON S. HERSHEY MEDICAL CENTER PO Box 853 Hershey PA, 17033 ' Defendant(s) ORDER The Debtor's motion to avoid a judicial lien is hereby approved. The judicial lien filed in the Court of Common Pleas of Cumberland County, Pennsylvania at Milton S. Hershey Medical Center, number 07-3901, civil action-law, is hereby avoided. By the cowt, AW 9L. Jam (AG) This document is electronically signed and filed on the same date. CERTIFIED!rROM THE RECORD this day of /IPA' P/1? k.,- . 20 D-2 Clerk, u.S. Bankru tcy Court Dated: December 12, 2007 Pat Deputy Clerk ,A 1% S WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-3901 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE MILTON S. HERSHEY MEDICAL CENTER, Plaintiff (s) From LARRY WARAKSA, 36 ESSEX ROAD, CAMP HILL, PA 17011 (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 GARNISHEE(S) as follows: M&T BANK, 1 WEST HIGH STREET, CARLISLE, PA 17013 ANY AND ALL ASSETS, INCLUDING, WITHOUT LIMITATION, CHECKING ACCOUNTS, SAVINGS ACCOUNTS, CERTIFICATES OF DEPOSIT AND SAFE DEPOSIT BOXES OF THE DEFENDANT IN THE POSSESSION OF THE GARNISHEE. 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 anyone 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 $9,303.48 L.L. $.50 Interest FROM 7/20/05 AT 6% PER ANNUM - $1,163.03 Atty's Comm % Due Prothy $2.00 Atty Paid $187.82 Plaintiff Paid Date: 9/20/07 (Seal) REQUESTING PARTY: Other Costs /zs/ lb '- '0 . C is R. Long, Prothonot By: Deputy Name LEWIS C. TRAUFFER, ESQUIRE Address: TABAS & ROSEN, PC 1601 MARKET STREET, 2300 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-569-5050 Supreme Court ID No. 60267 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff's Costs: Advance Costs: 150.00 Sheriff's Costs 86.83 Docketing 18.00 63.17 Poundage 1.71 Advertising Law Library .50 Prothonotary 2.00 Refunded to Atty on 04/30/08 Mileage 4.80 Misc. Surcharge 30.00 Levy 20.00 Post Pone Sale Certified Mail Postage .82 Garnishee 9.00 TOTAL 86.83 ? gb4ItI So Answ s R. Thomas Kline, Sheriff By. 0 LAI c d