HomeMy WebLinkAbout03-4849
CdMMONWEALTH OF PENNSYLVANIA
COURT Of COMMON PLEAS
NOTICE OF APPEAL
FROM
JUDICIAL DISTRICT
DISTRICT JUSTICE JUDGMENT
COMMONPLI"SN.. OJ-.l./llf9 C~d...~f)Wj
NOTICE OF APPEAL
Notice i. giwn that the appellant has filed in the above Court of Comman Plea. an appeal from the judglMnt rendered by the Di.trict Ju.tice on the
date and in the case n.emolled bel"",
~ C"~DPA- 1~:'1:ME;y
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""TEf-TiT/oj IN cASE~~ C()~fJt;Jir- ~lQc. CII1(T';j.('a~(Plfl.SHff
CWANO. cv I f' ~ r~ ~ SlGNA~~' APPaL<NTCJJAnc.c ~ .v
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This block will be signed ONLY when this nota~on is required under Po. R PJP. No. If appellant was CLAIMANT (see Pa. RG.P.JP. No.
10088.
Thi. Notice of Appeal, when received by the District Justice, will operate a. a 1001 (6) in action before District Justice, he MUST
SUPERSEDEAS to the judglMnt for possession in this case. FILE A COMPLAINT within twenty (20) days after
filing his NOTICE of APPEAL
SignatlJre of Prothonotary or Deputy
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of frxm to be used ONLY when appellant was DEFENDANT (see Pa. HCP.JP. No. 1001 (7) in action before District Justice.
IF NOT USED, detach from copy of notice of appeal to be served upon appellee).
PRAECIPE: To Prothonotary ~
Enter rule upon tKPJ)C ~ 11 (fiE? 'i4f!I fJ'lt S/ftP ,appellee(.), to file a complaint in this appeal
Name of appeJJee(S)
Ie.......""," No 62-'1""9 (!,,,;/T,,,,,,\IW>;. '-" ",,,...... W tJ, tt 0I:.1'*' 01__
RULE: Ta~ 6 'f> L L(/'1I'Tep ~~,~E~iJt.fIee(,~ Signatureof_ahisartomeyaagert
Name of appeifoe(s)
(1) You are no~fied that a rule i. hereby entered upon you to file a complaint in this appeal within twenty (20) day. after the date of
_vice of this rule upon you by personal service or by certified or registe<ed maiL
(2) If you do not file a complaint within this ~me, a JUDGMENT Of NON PROS WILL BE ENTERED AGAINST YOU,
(3) The date of _vice of this rule if _vice was by mail is the date of mailing.
Date: .0ep+ I~, ~ '--- ~/UJ./).' P ,~r~~
AOPC 312-90
COURT FILE TO BE FILED WITH PROTHONOTARY
.
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTEFi tiling the notice at appeal. Check applicable boxes)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF . ss
AFFIDAVIT: I hereby swear or affirm that I served
D a copy of the Nolice ot Appeal. Common Pleas No. upon the District Juslice designated therein on
(date of service) D by personal service D by (certiiled) (regrstered) mail. sender's
receipt attached herelo. and upon the appellee. (name) on
D by personal service D by (certitied) (registered) mail. sender's receipt attached hereto.
D and further that I served the Rule to File a Complaint accompanYing the above Notice of Appeal upon the appellee(s) to whom
the Rule was addressed on D by personal serVice D by (certified) (registered)
mail. sender's receipt attached
SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME
THIS DAY OF
WJP
My commission on
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CUMBERLAND
09-3-04
NOTICE OF JUDGMENTITRANSCRIPl
CIVIL CASE .
PLAINTIFF: NAME andADORESS
'ROBC LIMITED PARTNERSHIP
202 BLACK MATT ROAD
DOUGLASSVILLE, PA 19518
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Mag, Dist. NQ,:
OJ Name: rwn.
Address:
'l'HOMAS A. PLACEY
104S. SPORTING HILL RD.
MECliANICSBURG, PA
T",ph"" (717.) 761- 8230
17050
DEFENDANT:
IcoTRONA, JOHN
2100 BENT CREEK BLVD APT/STE 227
MECHANICSBURG, PA 17050
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NAME ~;;DOAES~
.J
'/'Mr
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THOMASA. PLACEY
104 S. SPOR'l'ING HILL RD. .
MECHANICSBURG' PA 17050
.J
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THIS IS TO NOTIFY YOU THAT:
Judgment:
I' Docket No.:
Date Filed:
I
CV-0000152 -O~
3/24/03 .
-"? ~..:J7 L. (/((1)
FOR pT.7i TNTIFF
~
~
Judgment was entered for:
(Name)
1?01'lr. r,TMT'l'1m Pll.1?'l'IIT1'!1?flHTp
Judgment was entered against: (Name)
GO'l'1?ON7i, ,TORN
in the amount of $
A,1'l1.'ioon:
(Date of Judgment)
1l/1A/O'l
o Defendants are jointly and severally liable.
o Damages will be assessed on:
o This case dismissed without prejudice.
(Date & Time)
Amount of Judgment
Judgment Costs
Interest on Judgment
Attorney Fees
Total
$ 8,000.00
$ 131.50
$ .00
$ .00
$ 8,131.50
O Amount of Judgment Subject to
Attachmentl42 Pa.C.S. S 8127 $
o Portion of Judgment tor physical
damages arising out ofresidential
lease $
Post Judgment Credits $
Post Judgment Costs $
------------
------------
Certified Judgment Total $
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE E"'TRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERK QF THE CQURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COpy OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IF THE JUDGMENT HOLDER
ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT
OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE DISTRICT JUSTICE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE
. A REQUEST FOR ENTRY OF SATISFACTION WITH THE DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES,
OR OTHERWISE COMPLIES WITH THE JUDGMENT.
'X-l'~-03 Date
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1:~rtifY.~hat,~is is a true~r-ot'!l16,reCOrd o~ p
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My commission expires first Monday of January, 2004
AOPC 315.03
DATE PRINTED:
8/18/03
3:13:22 PM
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NOTICE OF APPEAL
COMMONWEALTH 0' PENNSYLVANIA
COURT 0' COMMON PLEAS
FROM
JUDICIAL DISTRICT
DISTRICT JUSTICE JUDGMENT
;
COMMON PUAS No. O~ -/./liI 'I G ;.j,LC I r: fl ~
NOTICE OF APPEAa. .
Notice is giwn that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District J\Jstice on the
date and in the case "MlI otioned below.
';j5'H'y C'>o'!-Rp P 4- \-;;r ~ O:j:~; ":/
uOfr~~,4?oc (~b,{, "'foeTi IX C1TYfAATE f1t.l;c;:,
""TE Of ~NT I'" THE CASE ~iff) /) r. ( (I,.,.,....,p, --/
r f/ t f c 3 J .\ ,l tJ [0<((" rJ 1t- ~ l? o;p C. I HI' E) ".('C-14pd/-S'Hrf
OAIM NO.- SlGNA:7f:URE APPaLANT ~ttS ATTOR~9R AGENT
CV I ~,.. , <0 ~ /. <-4 \J J G~ "'"
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This block will be signed ONLY when this noto~on is required under Po. R PJP. No. If appellant was CLAIMANT (see Pa. RCPJP No.
10088.
This Notice of Appeal, when recei...d by the District Justice, will operate as a 1001 (6) in action before District Justice, he MUST
SUPERSEDEAS to the judgment for posses~on in this case. FILE A COMPLAINT within twenty (20) days after
filing his NOTICE of APPEAL
Signature of Prothonotary or Deputy
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellant was DEFENDANT (see Pa. HC.P.J.P. No. 1001(7) in action before District Justice.
IF NOT USED, detach from copy of notice of appeal to be served upon appellee).
PRAECIPE: To Pro,thanol"'")otor~/, ; -R tC r" 0
Enter rule upon. '\ d/L- '--( 11 ( 1 C[) 1''''( fie t <-TI rp , appellee(s), to file a complaint in this appeal
Name 01 appeIlee(S)
(Common Pleas No. ().J ~JfPilq (!1I"i'/~) within t-.ty (20) days after !ll(~ice of r;'-1 sc~try of judgment of non pro~
/~D ;l; C. I . / [) ~J./ .J). Signal:::::::' ex his attomer or agent
RULE: To ~ DoL-; M I U.{J '''~'f ~ t: ~ ~ee(s).
Name of appellee( s)
(1) You are notified thot''i'''4Ie is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of
service of this rule "p"" ~ ~;PIii's~"$ervice or by certified or registered mail.
, .... :,
.' ,.
(2) If you da ""t file a complaintwill1i!1 this ~me, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOu.
(3) the date oMervice of this rule if service was by mail is the date of mailing.
Date: .0~pf l.c ,\_~ '-- aa~, p (71r~4
,
AOPC 312-90
COURT FILE
,,_._-_..._-_._..._---~-_.__._._------_.._-----_._._~_.-
......
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing the notice of appeal. Check applicable boxes)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF . ss
AFFIDAVIT: I hereby swear or affirm that I served,
o a copy of the NOiicif)Jf I. Common Pleas No.~Cl::,,-t{I'il.__ upon the District Justice designated therein on
(date 01. seTVIce) d-- ('~ 'z...~.l....._____..~QY,#. r.ijqna.lp.e.. r..vice ~. .,....Q\r@r.ttii.lf..I...e.~dU~.iS.....t..e. red) ma....i.I......s. ender's
receipt attached her 0, and upon lhe appellee. (name)' 6J'/;:l ~.L 4J.J.'15'LJ41'~I!(E......._._, on
_____.__,____.. 0 by personal servic 0 by (certified) fregistered) mail, sender's receipt attached hereto.
o and further that I served thl..... . H F..;iIj!........./l... comP.laint....i!(JlQ. m.....pp.&.n..vJl1o.. tho e!!llove Notice of Appeal upon the appellee(s) to whom
the Rule was addressed 011 _ 1I~ L{,d.I'1I(Ii'YJ:.<'l'lJfil.f:.tzJf..(rfJ by personal service ~\ by (certified) (registered)
mail, sender's receipt attache hereto.
SWOR. N (AFFIR...M...E..D) AND SU~SCRIBED BEF.OR..E..ME .
THIS /.22J!-._ DAY O~~JL ~r ~ 3>
.~'\~d~'
Slgn/lture of atl:ciA! bcfofi';Jom affit'!avtl W2.<:' m3rfe
~o~a-
My commission expires on
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Steven J. Proctor, Esquire
Attorney LD. #24428
Binder, Kalis & Proctor, P.C.
1035 High Street
Pottstown, P A 19464
610-323-6200
Attorneys for Plaintiff
COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
ROBC LIMITED PARTNERSHIP
202 Black Matt Road
Douglassville, P A 19518
Plaintiff
: CASE NO. 03-4849 Civil Term
V.
JOHN COTRONA
2830 Carol Road
York,PA 17402
Defendant
ENTRY OF APPEARANCE
To The Prothonotary:
Please enter my appearance for the Plaintiff in the above captioned matter.
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DATE: ;;...1'A1/0f
Steven J. proctor
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Steven J. Proctor, Esquire
Attorney J.D. #24428
Binder, Kalis & Proctor, P.C.
1035 High Street
Pottstown, P A 19464
610-323-6200
Attorneys for Plaintiff
COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION-LAW
ROBC LIMITED PARTNERSHIP
202 Black Matt Road
Douglassville, P A 19518
Plaintiff
: CASE NO. 03-4849 Civil Term
V.
JOHN COTRONA
2830 Carol Road
York,PA 17402
Defendant
NOTICE TO DEFEND
You must 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 an
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 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 }'IND OUT WHERE YOU
CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
717-249-3166
800-990-9108
Steven J. Proctor, Esquire
Attorney LD. #24428
Binder, Kalis & Proctor, P.C.
1035 High Street
Pottstown, PA 19464
610-323-6200
Attorneys for Plaintiff
COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
ROBC LIMITED PARTNERSHlP
202 Black Matt Road
Douglassville, PA 19518
Plaintiff
: CASE NO. 03-4849 Civil Term
V.
JOHN COTRONA
2830 Carol Road
York, PA 17402
Defendant
COMPLAINT
AND NOW, Plaintiff, ROBC Limited Partnership, through the undersigned counsel,
by way of Complaint against Defendant, John Cotrona, alleges the following:
I. Plaintiff, ROBC Limited Partnership, is a limited partnership duly organized in the
Commonwealth of Pennsylvania, with a principal office located at 202 Black Matt Road,
Douglassville, P A, 19518 (hereinafter referred to as "Plaintiff').
2. Defendant, John Cotrona, is an adult individual with a mailing address of2830
Carol Road, York, P A, 17402 (hereinafter referred to as "Defendant").
FACTUAL BACKROUND
3. On or about November 21,2002, the parties signed an "Assisted Living Admission
Agreement" for accommodations in an assisted living unit and related services at Plaintiff's
facility, The Bridges at Bent Creek, located at 2100 Bent Creek Boulevard, Mechanicsburg,
Cumberland County, P A, 17050 ("the Facility"). A true and correct copy of said agreement is
attached hereto, made a part hereof, and is marked as Exhibit "A".
4. The agreement stipulates that the Defendant was to receive the basic level of room,
board and care at a rate of $2,200.00 per month.
5. On or about December 1, 2002, it was determined by the staff ofthe Facility that
Defendant's condition required additional care and services that were not contracted for in the
original agreement.
6. A "Notice of Level of Care Re-Assessment" was agreed to and signed by Defendant
on December 11, 2002, wherein the parties agreed to additional services and an increase in the
rate to be paid by Defendant. A true and correct copy of said notice is attached hereto, made a
part hereof, and is marked as Exhibit "B".
7. Defendant was responsible for monthly charges associated with his care at the
facility, including rental fees in the amount of $2,200.00 per month and the level of care
charge equal to $1,350.00 per month, as well as monthly charges for incidental care items and
pharmacy charges.
8. On March 6, 2003 Defendant was given notice from the Facility that his rental and
care payments were delinquent, his behavior with the staff and fellow residents was
inappropriate, and that his pharmacy account was delinquent. A true and correct copy of said
notice is attached hereto, made a part hereof and is marked as Exhibit "C".
9. The notice provided Defendant with 30 days to correct the situation or he would
have to vacate the premises.
10. Defendant failed to cure his account delinquency, and vacated the premises on or
about April 5, 2003.
11. The Facility prorated the April rent and level of care charge, and provided a further
credit to Defendant's account in the amount of $500.00 for his security deposit.
12. Defendant currently owes a total of $8,832.20 for rent, assistance, and supplies for
the period from November 22, 2002 through April 2003, as detailed on Plaintiffs statement to
Defendant dated April 16, 2003, a true and correct copy of which is attached hereto, made a
part hereof and marked as Exhibit "D".
13. Plaintiff also claims interest at the legal rate of 6% per annum on the aforesaid
amount from April 16, 2003, at the daily rate of$1.45. Said interest claim, through the
anticipated March 1, 2004 date of filing this Complaint, amounts to $464.00.
14. In addition, Plaintiff claims entitlement to reimbursement of $131.50 in judgment
costs incurred by Plaintiff as the prevailing party in the civil action filed by Plaintiff against
Defendant on the instant claim in Cumberland County Magisterial District No. 09-3-04 at
Docket No. CV-0000152-03.
COUNT I
(BREACH OF CONTRACT)
15. Plaintiff incorporates paragraphs 1 through 14 as though, again, set forth in full
and complete detail.
16. The conduct by Defendant as described above constitutes a breach of contract.
17. Defendant has failed to pay the rental and care and supplies charges as agreed,
although the Facility provided all contracted services to Defendant.
18. As a direct and proximate result of said breach by Defendant of his contractual
obligations to Plaintiff, Plaintiff has been damaged in the amount of $9,427.70.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of
$9,427.70, together with interest at the legal rate of6% per amlUm from March 1,2004; costs
of suit; and for such other relief as the Court shall deem just and proper.
Respectfully submitted,
Binder, Kalis & Proctor, P.C.
~
By:
Steven J. Proctor, Esquire
Attorney for Plaintiff
VERIFICATION
I, Dale Kuhlman, hereby verify that I am the Vice President of Eldercare
Investments, LLC and General Partner of ROBC, Limited partnership, and am therefore
authorized to execute to this Verification on the Plaintiff s behalf, and do hereby verify that
the facts contained in the foregoing Complaint are true and correct to the best of my
knowledge, information, and belief and that the exhibits attached hereto are true and correct
copies of the originals. I understand that false statements made herein are subject to the
penalties of 18 Pa. C. S. 94904 relating to unsworn falsification to authorities.
Eldercare Investments, LLC
Dated: ~l ),7 j~ 'I
BY: ~ - --' .::>
Dale Kuhlman, Vice President
ASSISTED LIVING ADMISSION AGREEMENT
This Agreement is required by the Commonwealth of Pennsylvania's Regulations governing Personal i
Care Homes (hereafter "PCH"). The agreement is made in duplicate this J-;J.-icl- day 0['1w-f)h,,-/~
'}O 0 'v
.jtA~r,- ('oi YI7YVL----
Resident's Name
Street Address, City. State, Zip Code
1. Resident agrees to pay the Bridges at Bent Creek (hereafter "the Bridges") a:
.:.
Daily rateof$
for room, board and personal care services; or
.:. Monthly rate of $ )?-u [)
.:. Assisted Level of Care ,;0// /f
Additional charges for services and items may be billed according to the Bridges' rate and charge
schedule attached to this agreement. The amounts stated reflect the actual amount charged.
,L/'
Bill is to be sent to resident at the Bridges
Bill is to be sent to the following name and address:
2. The Bridges will provide the resident thirty (30) days notice in writing of any rent
increases.
3. The Resident agrees to abide by the House rules as attached to this agreement.
4. The resident is provided with a copy of "Resident's Rights" as attached to this agreement.
Assisted Living Agreement -- Page 7
5. Assu rance of Confidentiality
The Bridges acknowledges that the resident's personal and medical records are confidential. The
resident acknowledges that such records are hereby released and may be used internally by the
staff of the Bridges to determine appropriateness of care and to develop resident support plans
and in case of the resident's admission to a hospital or health care institution, may be released to
such institution.
6. Required Medical' Evaluation and Screening for Admission
The resident agrees to have a medical evaluation by a physician prior to commencement of
residency and annually thereafter. The resident also agrees to provide a copy of his/her annual
medical evaluation on the form designated by the Department of Public Welfare to the Bridges.
Prior to admission and annually thereafter, the resident agrees to participate in and share needed
intormation for the Bridges to complete the Screening Instrument and any other assessment tools
developed by the Bridges to determine the appropriateness of care available in light ofthe
resident's present medical and social needs.
7. Activities Program
The Bridges will have a program of social, physical, intellectual and recreational activities
designed to promote the resident's active involvement wi1:h other residents and family and the
community.
8. Basic Services
The Community agrees to provide to the Resident the foHowing basic services:
(i) Room accommodations;
(ii) Weekly laundry services for linens and towels (does not include personal laundry);
(iii) Weekly housekeeping;
(iv) Dietary services including three well-balanced meals and snacks on a daily basis and
regular diets or modified diets prescribed by physician order or supervised care;
(v) Transportation to medical appointments on allotted days;
(vi) Observation of the Resident's physical and mental condition;
(vii) Basic utilities: including water, electricity, heating and cooling (does not include personal
telephone services in the Resident's room or long distance telephone service).
The monthly base rates for Basic Services are dependent upon the room accommodations
provided to the Resident and are set forth on the Fee Schedule which is attached to and made a
part of this Agreement.
Assisted Living Agreement -- Page 3
The Community will provide the Resident access to a telephone for use in calling the local
service area. The Resident may also make long distance calls and will be charges for such calls
on the monthly bill as set forth in Paragraph 3.1.5 of this Agreement and in accordance with the
Fee Schedule. Additionally, the Resident should refer to the Fee Schedule for the cost of
personal telephone services in the Resident's room.
For information concerning the availability and cost of basic: and premium television cable
services at the Community, the Resident should refer to the Fee Schedule.
9. Personal Care Services
The Community acknowledges that residents will require assistance with personal care services
such as the following:
(i) Medication;
(ii) Dressing;
(iii) Bathing;
(iv) Hair Care;
(v) Mouth Care;
(vi) Toileting;
(vii) Eating Habits;
(viii) Walking/Moving;
(ix) Orienting;
(x) Redirecting;
(xi) Cuing.
The Community knows these needs will vary among residents and that a particular resident's
need for assistance may periodically change or fluctuate. To address these concerns, the
Community offers an Assisted Care program with additional levels of care: Assisted living Plus,
and Assisted Living Plus II. The difference between the programs is the number of personal
care services provided and the cost for the additional assistance. The Community will provide
the level of care that Resident needs based upon the Level of Care Assessment.
In addition to the charge for Basic Services, the Resident will pay a monthly charge for personal
care services. The charge for the personal care services is dependent upon the level of care the
Resident receives. If the needs of the Resident change, resulting in the need for a change in level
of care the Resident is receiving, the Community will immediately notify the Resident and the
Responsible Party and at the same time, will begin to provide the appropriate level of care and
make the applicable adjustment to the monthly charge for the level of care that is being provided.
The Resident, Responsible Party and Payor, if any, understand that the amended monthly
charges will become effective on the date that the level of care changes, and will be
prorated accordingly.
Assisted Living Agreement -- Page 4
10. Requirements for Discharge or Transfer
a. If the Bridges initiates a discharge or transfer of the resident, or if the Bridges is closing,
the Administrator shall give thirty (30) day prior written notice to the resident, the
designated person, and the referral agent, citing the reasons for the discharge or transfer.
b. If the resident chooses to leave the Bridges, the resident will provide to the bridges a
thirty (30) day prior written notice. The resident may be charged for up to (30) days of
rent and personal care services after the date of the notice whether or not the resident
remains on the Bridges for the entire time period.
c. If a delay in discharge or transfer would jeopardize the health or safety of the resident or
others in the Bridges, as certified by a physician or the Department of Public Welfare, or
both, the time periods required in Subsections a and b herein do not have to be observed.
d. The date and reason for the discharge or transfer, and the destination of the resident, if
known, shall be recorded in the resident's record.
11. Discharge due to change in the resident's condition
The adrninistrator shall notify both the resident and the designated person, if any, of the need to
transfer the resident in the following situations:
a. The resident's physician or a local appropriate assessment agency has determined that the
resident needs a higher level of care. In this situation, a plan for other placement shall be
made as soon as possible by the Administrator in conjunction with the resident or
designated person, if any, or both. If assistance with relocation is needed, the
Administrator shall contact appropriate local agencies, such as the Area Agency on
Aging, county mental health/mental retardation program or drug and alcohol program for
assistance. The Administrator shall also contact the appropriate PCH licensing field
office.
b. The resident's condition is such that the resident is a danger to self or other residents and
the resident must be removed from the Bridges. In this situation, the Administrator shall
take appropriate interim immediate action to protect the health and safety of the resident,
other residents of the Bridges and the staff.
12. Notice ofIntent to Leave
The resident shall give the Administrator written notice at ll~ast thirty (30) days in advance of
his/her intent to leave. The refund and/or additional charges incurred by the Resident will be
governed by the following Refund Section provisions.
Assisted Living Agreement -- Page 5
13. Refunds
a. If, after the Bridges gives notice of discharge or transfer, and the resident moves out of
the Bridges before the 30 days are over, the Bridges shall give the resident a refund equal
to the previously paid charges for rent and personal care services for the remainder of the
30 day time period.
b. Refunds of unused portion of payments for room and board will be made upon the death
of the resident, or the medical need for a resident to be permanently placed in another
institution.
14. Notice ofIntent to Leave
After a resident gives notice of intent to leave in accordance with this Agreement, and if the
resident moves out of the Bridges before expiration of the required thirty (30) days, the resident
owes the Bridges the charges for rent and personal care services for the entire length ofthe thirty
(30) day time period for which payment has not been made. The Agreement has been reviewed
by the resident and explained to the resident by the Administrator or his/her designee. The
resident understands that the Administrator must give the resident and his/her designated person.
If applicable, thirty (30) days advance written notice before changing the Agreement. It is
required that the Administrator acquaint resident with the Regulations which are posted in the
community. In signing this Agreement, the Resident acknowledges each of the conditions and
the fact that the Regulations have been explained.
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Designated Person or Referral Agency
(Signature is at the option of the resident)
Date Signed
Assisted Living Agreement - Page 6
If resident is unable to sign his/her name, resident should show bis/her mark below:
Resident's Mark
Date Marked
Witness to Mark (Other than Administrator)
Date Witnessed
A copy of the signed Admission Agreement shall be given to thl' resident and a copy shall be filed
in the resident's record.
In accordance with the Federal Civil Ril!hts Act and the Pennsvlvania Human Relations Act, P.L.
744: This community has agreed to comply with the provision!; ofthe Federal Civil Rights Act of
1964, and the Pennsylvania Human Relations Act, and all requirements proposed pursuant
thereto, to the end that no persons shall on the grounds of race, color, religious creed, national
origin, ancestry, age, sex, handicap or disability should be exclude from participating in, be denied
benefits of, or otherwise be subject to discrimination in the provision of any care or service. The
non-discriminatory policy of the institution applies to residents, physicians and all employees.
Under no circumstances will the application of this policy result in the segregation of buildings,
wings, floors, and rooms for reasons of race, color, religions creed, national origin, ancestry, age,
sex, handicap or disability.
Assisted Living Agreement -- Addena,. I -- Page 1 - Fee Schedule
The Bridges at Bent Creek
(Authorization of Services/Ancillary Charges Acknowledgement)
i-I
Resident: -rO[".. CorV'O}\"
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Authorization of Services
Would you prefer-
1. the community to do your personal laundry? (circle) yes or€)
2. to utilize the beauticianlbarber? (circle~ or no
3. to utilize the house podiatrist? (circle x'i~;jPr no
Initial DepositfWaiting List Fee
Reservations fee of $500.00 is required to place the resident's name on the waiting list for admission.
This fee is fully applied to the last month's statement. Ifapplicant for admission withdraws, the deposit
is refunded in full.
Ancillarv Chal1!es Acknowledl!ement
Services available:
Cost:
Additional Level of Care (LOC determined at time of assessmlmt or if a change in resident
condition occurs)
Assisted Living Plus I
Assisted Living Plus II
$450/month (N/ A to dementia)
$900/month
Pharmacy
per pharmacy's charges
Beauty/barber/manicure service
per salon's charges
Catering
Guest Meals (can be added to bill or paid at time of meal)
Breakfast
Lunch
Dinner
Specials
Available/charges per event request
$3.00 per guest
$6.00 per guest
$9.00 per guest
As po&ted
Guest Accommodations
Rollaway Bed
Guest Room
$10.00 daily rate
$25.00 per night
$5.00/key
Lost Key replacement
Assisted Living Agreement -- Addendu.., . -- Page 2 -- Fee Schedule
Services available:
Cost:
Lost Emergency Bracelet
$150.00
Personal Housekeeping
$25.00 per hour (in addition to weekly
service) Also provided in 'is hour
increments
Personal Laundry
$5.00 p"r load (including personal flat linen
service)
Community Supplied Flat Linens included
Personal Maintenance
$50.00 per hour (also provided in y, hour
Increments)
Podiatrist
Per Doctor's Charges
Transportation (Provided on Tuesday & Friday as stated below):
(This is within a 15-mile radius ofthe community)
Physician's Appointment (within a 15 mite radius) Included
Physician's Appointment (outside a 15 mite radius) $0.35 per mile
Personal Errands (within a t5 mile radius) $20.00 per trip
Driver Waiting Time (provided in y, hour increments) $8.00 per hour
Accompanied by Staff(provided in y, hour increments) $15.00 per hour
(Transportation on non-scheduled days at a rate of$0.35/mile)
Tray Service
$1.00 per tray
Telephone
Basic Local Service
Long Distance Charges
Installation and Transfer
$15.00 per month
$0.10 per minute
Included
Basic Supplies (i.e. gloves, tissues, incontinent items, wound care dressings) will be billed at the current
market rate
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Assisted Living Agreement -- Adden~.__.. II ~ Page I ~ Resident Rights
The Bridges at Bent Creek
Resident Rights
The right to be informed of your rights in writing.
The bridge's Administrator must tell you upon admission what your rights are and must post a
copy of them for easy viewing by residents. Your rights must also be made a part of the
admission agreement.
The right to be informed in writing of the Bridge's policies, services and charges.
The Bridges must have written policies about its rules and your responsibilities as a resident
You must also be informed in writing by the Bridges of all services and the charges for those
services.
The right to leave and return to the Bridges at reasonable times.
You are free to leave and return to the Bridges during reasonable times consistent with the
Bridge's rules.
The right to use your own clothing and possessions.
The amount and kind depends upon available space and whether other residents' rights would be
violated.
The right to receive visitors.
You are free to receive visitors for a minimum of 8 hours per day, 7 days per week.
The right to telephone access and privacy.
The Bridges must provide you access in reasonable privacy to a phone. You are free to make
local calls without charge, except where a standard pay phone is used. Arrangements for
payment oflong distance calls are to be included in the Admissions Agreement
The right to receive and send mail.
You have access to the U.S. Mail. You are free to write and send mail at your own expense.
Your mail should arrive to you unopened.
The right to be free of retaliation from complaints.
You are free to exercise your rights and voice grievances and recommend changes in policies
and services ofthe Bridges. The personal care home may not take any action against you
because you voiced a grievance.
Assisted Living Agreement - Addend, . -- Page 2 -- Resident Rights
The right to be free from mental, physical and sexual abuse, exploitation, neglect and involuntary
seclusion.
No one may mistreat, threaten or coerce you in anyway.
The right to privacy and to be treated with dignity and respect.
The right to privacy takes many forms. You are free to communicate and meet privately with
anyone. You should be treated with courtesy and afforded privacy for personal needs like
bathing and toileting.
The right to be provided with thirty (30) days advance written notice ofthe community's intent to
terminate your residency and the reason for termination.
The right to be free from chemical (drug) and physical restraints.
The right to keep at least $60.00 per month of your own funds for personal use.
The right to request and receive assistance in relocating.
The right to freely participate in any religious, social or commulBity activity of your choosing.
Assisted Living Agreement -- Addendm. ^ - Page 3 -- Resident Rights
Personal Care Home Licensure Regulations give rights to Personal Care Home residents in
Pennsylvania. For a more complete explanation of your rights and how they apply to your individual
circumstances, contact your local long-term care ombudsman:
Cumberland County Office of Aging & Community Services
16 West High Street Suite 100
Carlisle, PA 17013
Phone: 717-240-6110
An Ombudsman is:
. A resource
. A problem solver
. One concerned with protecting the rights of older Pennsylvania's in long-term care facilities by
answering questions, investigating complaints and resolving problems
Who may contaCT the Ombudsman for assistance:
. A resident
. Family or friends
. Staff
. Community groups
. Anyone
All communications with the Ombudsman are CONFIDENTIAL
The resident may voice grievances and recommend changes in policies and services of the Bridges
through Town Council or the Owner (610) 326-9090 if satisfaction is not obtained through the
community staff.
A resident may contact the Governor's Action Line if grievances carmot be resolved through these
means:
Governor's Action Line
304 Financial Building
Harrisburg, PA 17120
1-800-932;27, 8 4 (~ofree)
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ident's Signature
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Administrator/Designee Sig e
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Date
Assisted Living Agreement -- Addend, .II -- Page I - House Rules
The Bridges at Bent Creek
House Rules
1. Visiting:
Visiting hours are not restricted, Please feel free to schedule visiting times with your
loved ones at your convenience
2. Security:
Doors to the community will be secured at dusk for your safety and security. The front
entrance is accessible by pressing the keypad in the vestibule when the doors are secured.
3. Meals:
Meal times are as follows. Times are subject to change with appropriate resident
notification:
Breakfast
Lunch
Dinner
7:30am - 8:30am
11 :30am - 12:30pm
5:00pm - 6:00pm
4. Snacks:
A variety of snacks are available in the Cafe.
5, Alcoho I:
Alcohol may be used in moderation in the resident's room, as well as in the dining room,
if purchased by the resident and stored in the resident's room. The community may
provide both alcoholic and non-alcoholic beverages for scheduled events,
6. Tipping:
Tipping staff is not allowed.
7. Fire Drills:
Residents are required to participate in every fife drill. Move to the nearest exit and
safety and wait for further instructions. DO NOT IGNORE THE FIRE ALARM.
8. Personal Items:
Clothing and personal items should be labeled with the resident's name to assist in
returning items to the resident if they become lost. Residents are encouraged to furnish
their rooms with their own belongings or used furniture provided by the Bridges.
9. Mail:
U.S. Mail is delivered to an individualized locked mailbox near the dining room.
Assisted Living Agreement- Addendm.. -- Page 2 - House Rules
10. Team Members:
Team Members should be treated with respect and dignity enabling them to perform their
duties.
11. Smoking:
The Bridges is strongly committed to maintaining and improving the health and well-
being of all residents and staff; therefore, smoking is prohibited inside the building.
Smoking is allowed on the rear patio only. Residents who violate this rule or residents
who are deemed by the Bridges in its sole discretion to be unable to safely smoke without
supervision will be asked to give all cigarette and cigarette lighting devices to staff who
will supervise smoking so as to provide for the safety and well-being of other residents
and staff.
12. The Bridges Resident Handbook is incorporated herein and made a part hereof.
Assisted Living Agreement -- Addendu. . -- Page I
Assisted Living was developed to provide an alternative to nursing homes, emphasizing quality of life,
for our nation's elderly. With this choice each resident and their family must understand the rewards,
the risks and the shared responsibilities inherent in this type ofliving environment.
Assisted Living is often described with terms such as 'autonomy and independence', 'dignity and
respect' and 'freedom of choice'. If you choose to reside in our community, each resident and their
family members have chosen our quality of life setting rather than a medical or institutional care setting.
With your desire to remain as independent as possible there are potential risks. We do not provide 24-
hour skilled nursing care. As part of this resident agreement, you and your family members
acknowledge that some of these inherited risks to injury are beyond our control.
Because residents are not monitored 24-hours a day, the risk of bodily injury from falls and accidents is
a common reality. If you have sustained a previous fall prior to moving in our community there remains
an even higher risk of falling again. For the cognitively diminished resident, the risk of wandering into a
non-secure area is also present. Any resident that sits in a wheelchair for extended periods of time, has a
history of skin breakdown, or spends extended periods of time in bed has a high risk of skin breakdown
caused by pressure. Although these are some of the more common inherited risks in the aging process
there can be additional risks depending on each resident's needs, diagnosis, and medical conditions.
Assisted Living is what its name implies "assistance in living". Twenty-four (24) hour skilled nursing
care is not and will not be provided.
In summary, we want you and your fiunily members to be informed of the inherent risks we often cannot
control, as we respect your decision to retain your independence and maintain your quality oflife.
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Assisted Living Agreement - Addend"
-- Page 1 - Respite
It is understood that Resident is coming to the Bridges under a respite stay. Such respite stay is expected
to end on at which time Resident will be discharged from the
Community. Should Resident leave prior to the end of this respite stay or decide to leave after the
discharge date above, Resident shall be subject to paragraphs 9 and 12 above with respect to the thirty
(30) day notice period and the right of the Bridges to bill the resident for thirty (30) days following
Resident's written notice of his/her decision to leave.
PET POLICY
The Bridges consents to the Resident keeping the following Pet in his/her unit:
Kind and Breed
Name
Color
Weight
Age
The Resident will be completely responsible for the health, welfure, and c"'. of the Pet. The Resident will ensure that the Pet
does not disturb the rights ~other residents to the peaceful enjoymen, t of their units and of the common areas. The Resident
will walk and curb the Pet ty in areas designated by the Bridges and-'will be responsible for cleaning up after the Pet.
Wben the Pet is not in the R sident's unit, the Resident will keep i(on a leash no longer than five feet or in a cage or other
appropriate closed and ventil\ted container, and in the controt oflhe Resident. If the Pet is a bird, the Resident will keep it
caged both in and out of the ukit. i
\
The Resident will comply with all vaccinations and licensing/requirements applicable to the Pet, showing proof of this upon
request, and will comply with ap~opriate standards of car~/treatment, and grooming.
The Resident will be liable for any personal injury or property damage caused by the Pet that is suffered by the Bridges, its
employees or agents, other residents, guests, or invitee.. The Resident will pay all costs and expense, including reasonable
attorneys' lees and court costs, incurred ,by the Bridges in enforcing any liability of the Resident under this Addendum. The
Resident agrees tv pay a second securitydeposit of$250.00 to the Bridges that may be used by the Bridges to repair any
damage caused by the Pet andlor to clean the unil'and its carpeting due to Pet wast" or odors. The Bridges will return any
unused amounts to the Resident within thirty (30) days after the expiration of the Resident Agreement.
This Addendum will continue until the Resident Agreement between the Resident and Bridges is terminated unless either
party terminates this Addendum for any reason 'giving fourteen (14) days prior written notice to the other party. The Bridges
may terminate this Addendum upon 24'l>ours notice in the even the Resident fails to comply with any of the Resident's
obligations under this Addendum.' ,
lfthe Bridges determines th~t ~ Resident, for any !'ya, son, is unable to care for the Pet, the Bridges reserves the right to
arrange for the Pet to be del7red to a Sponsor whos~ name, address and tetephone number are listed below:
/ "
, \
Name: / \
/ \
J \
Address: J \
/ \
/ \
\
Teleph/ne:
! ,
In the event tI1~t the Bridges is unable to contact the Sponso~ or that the sponsor is unwilling to accept delivery of the Pet, the
Bridges wi,t( arrange for the Pet to be delivered to a tocal enlilY that the Bridges determines to be appropriate. The Resident
will pay all costs of delivery, feeding, care, treatment and hoUsing of the Pet.
Resident acknowledges that he/she has no right to keep a Pet except to the extent expressly permitted by this Addendum, and
that the Bridges reserves the right to withdraw its consent by terminating this Addendum as provided for above.
ResidentlRepresentative
Date
Adm inistrator/Designee
Date
Assisted Living Agreement - Addendum IV (3 Pages)
Assisted Living was developed to provide an alternative to nursing homes, emphasizing quality
oflife, for our nation's elderly. With this choice each resident and their family must understand
the rewards, the risks and the shared responsibilities inherent in this type ofliving environment.
Assisted Living is often described with terms such as 'autonomy and independence', 'dignity and
respect' and 'freedom of choice'. If you choose to reside in our community, each resident and
their family members have chosen our quality of life setting rather than a medical or institutional
care setting. With your desire to remain as independent as possible there are potential risks. We
do not provide 24-hour skilled nursing care. As part of this resident agreement, you and your
family members acknowledge that some of these inherited risks to injury are beyond our controL
Falls:
Because assisted living is specifically designed to offer residents more independence and
autonomy, and that 24-hour care and supervision is not provided on an individual basis, the risk
of bodily injury and severe consequences from fans and accidents is a common reality. If YOll or
your family member have/has sustained a previous tan prior to moving in our community, there
remains an even higher risk of falling again. Theretore, it is our policy that all new residents
moving into our community obtain an order from their primary care physician for an
Occupational and Physical Therapy evaluation. In addition, if you sustain a fall in our
community, your physician will be notified and another order for therapy may be obtained from
your primary care physician if appropriate. All residents receive an emergency call bracelet that
works with the community's emergency call system in each resident suite (not in the common
areas where additional Elcombe units and buttons are provided). We strongly suggest that you
wear this bracelet at all times so that you can notify staff in case help is needed or you are not
able to reach the Elcombe unit in the room or the button in your bathroom. I understand that I or
my family member am/is at risk for fulling and I/we acknowledge that IIwe have been given the
opportunity to discuss my or my family member's condition and any preventative interventions
with the community's staff members. 1 further understand that The Bridges at Bent Creek can
make no guarantee that I or my fumily member will not fall. The community has adopted a
shared-risk program to work together to minimize the risks that you or your family may fall in
the future and be harmed as a result. Your participation in the shared risk program by providing
any input or suggestions that you may have that would promote you or your family member's
safety, by carefully evaluating all of the options to reduce the risk of falls, and by supporting
those options that you believe to be in your or your family member's best interests is very
important to us and essential to reducing the risk of falls.
Addendum IV (nal!e 21
Elooement:
For the cognitively diminished resident, the risk of wandering into a non-secure area is also
present. Many residents come to assisted living with some form of dementia, and that coupled
with a resident being ambulatory will put them at risk for elopement. Because assisted living is
specifically designed to offer residents more independence and autonomy, and that 24-hour care
and supervision is not provided on an individual basis, the risk of elopement is a reality. In
addition, some medications that may alter mental status also may put a resident at risk for
elopement. With a physician order and family consent, a resident who has a history of elopement
or who we feel is strongly at risk may be placed in our community's secured unit. I/We
understand that I or my family member amlis at risk for elopement. I/We have been given the
opportunity to discuss my or my family member's condition and preventative interventions with
the community staff. I/We understand that the Bridges at Bent Creek can make no guarantee that
I or my family member will not leave the community unattended.
Self Administration of Medications:
We believe that in order for a resident to self administer medications he/she should be able to list
and identifY each prescribed medication, describe the purpose of the medication, describe and
demonstrate the correct dosage, and correctly take or apply the medication. If a resident or a
resident family member requests that a resident self administer medication, we will assess the
residents ability to do so. If a resident is unable to successfully complete the above task, we
believe that it is not safe for the resident to se!f~administer his/her own medications. I/We
understand that the Bridges at Bent Creek is not responsible for medications errors that result tor
the self administration of medications by a resident.
Smokiol!:
The Bridges at Bent Creek is a smoke free building. However, we do recognize that smoking is a
resident right and therefore the Bridges has designated an outdoor area where residents may
smoke. The location of this area may change from time to time. Residents may smoke onlv in
this designated area and must extinguish all their cigarette/cigar butts in community-designated
containers. If a resident does not fo I low these guidelines, at the option of the community, that
resident will not be allowed to smoke and all cigarettes/cigars will be taken from them or that
resident may be asked to leave the community. The Bridges at Bent Creek does not provide 24-
hour supervision and takes no responsibility for a resident smoking.
Addendum IV (page 3)
In summary, we want you and your family members to be informed of the inherent risks we
often cannot control, as we respect your decision to retain your independence and maintain your
quality 0 f1ife.
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Date
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Administrator or Designee '~
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Date
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NOTICE OF LEVEL OF CARE RE-ASSESSMENT
Date I.J IljOL
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ResidentJC)hn (Of\+ronQ..)
"
This is to inform you that effective as of the day of this Notice, The Bridges at Bent
Creek will provide to the Resident the '12)(; d~\ e., level of
care at a cost of$ ',~ SO, CO per month and ill s cost will be reflected on your
monthly statement and pro-rated, if necessary.
It is the Community's policy that residents are re-assessed as follows: I) quarterly; 2) llpon
a change in health condition or behavior; 3) Upon return from a hospital or other health
care facility; and 4) upon the request of the Resident or Responsible Party. We have
completed a re-assessment and determined that the community staff will assist you with
. the :OIlOWing :ervices: &~ ;:5 \'Q\lX~. dw:..t,' ~, ~~lJ fX;O-f, I 120
, (\COn:+II\C' ~ t I L.Lj v I I \ \ r 11 (qjJ r'I'{)(\ \--to V\("j
Please acknowledge receipt and acceptance of this otice y signing below and returning ,
the Notice to the Community in the enclosed addressed and stamped envelope.
If you have any questions or concerns regarding this notice, please feel free to contact me
or Linda Farrance, Resident Care Director. As always, it is!! pleasure to be of service to
you. . ,
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General Manager
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Dat I
2100 Bent Creek Boulevard. Mechanicsburg, PA 17050
Phone: (7J7) 795.1100 . FAX: (717) 795.9152
..'B
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. the,Bfidges
at BENT CREEK
'Ass istidl'1nJ"epend"i;nt
iivr:Il~.1 Community
March 6, 2003
Mr. John Controna
Apartment 227
The Bridges At Bent Creek
2100 Bent Creek Blvd.
Mechanicsburg, P A 17050
Dear Mr. Controna,
The staff at the Bridges has worked very hard to provide care to you and your challenging
situation. When other facilities have failed in the past on your care, we have succeeded.
Per our discussions in the past we agreed that to make this a successful experience for
you and the staffwe need to work together as a team. We have worked hard to make
schedules of bathing, treatments, and meals work not only for you, but also to have your
schedules work into the general operation of the community that affects all residents.
At this time it seems that you are not compliant on your end. On numerous occasions
you have negatively impacted on the resident's dining experience with your angry
outbursts in the dining room, especially at breakfast. You are bathed, dressed and your
treatment is applied every morning by the staff and you still make it to breakfast well
within our scheduled mealtime.
Furthermore, at times your actions may be construed as sexual towards some staff
members. Staff is feeling uncomfortable with comments you make towards them and
things you ask them to do that you are capable of doing independently.
In addition, your rent and pharmacy bills continue to be delinquent. At this time Alert
PhWplacy has refused to send you medications due to your account being delinquent. I
un4~fstand they have spoken to you on the phone about this matter. This leaves no
chqj!ie but for you to make other arrangements with another pharmacy for your
medications.
2100 Bent Creek Boulevard. Mechanicsburg, PA 17050
Phone: (717) 795-1100 . FAX: (717) 795.9152
Under the circumstances I find it necessary to give you a 30-day move out notice unless
the above situations are corrected immediately. I would be happy to discuss with you
how to resolve these issues.
Sincerely,
CiL'V~>i-~i'{j){ :J eLl;' cr
Christy DiGilio
General Manger
Resident Acknowledgement
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ROBe Limited Partnership
202 Black Mall Road
Douglassvlle, PA 19518
Statement
Account
horobc . 0227 . hoconjo1
Date: 04/16103
John Cottona
4833 E. Trindle Road
Apt 511
Mechanlcsburg, PA 17050
Payment:
Payment Due Upon Receipt.
Date Description Charges Payments Balance
Balance Forward 0.00
11/22/02 Deposit 500.00 500.00
11/22102 Rent for 9 Days 648.00 1,148.00
11/25102 chk# 620 2.700.00 -1,552.00
12/01102 Rent 2,200.00 648.00
12/01/02 Lavel of Care 1,350.00 1,998.00
12/17/02 Transporl-12/123 Flowers Dr. 12.00 2,010.00
, 12/17/02 Laundry Serv-12/5 5.00 2,015.00
12/17/02 Supplles-SoaP, Jergens Bath 11/23 0.57 2,015.57
12/17/02 Supplles-Gloves. Vinyl 11/23 6.48 2,022.05
12/17/02 Supplies-ShampoolBody Wash 11/23 2.72 2,024.77
12/17/02 Supplies-SureCare-slip on protec grmt 11 9.75 2,034.52
12/17/02 Supplles-Pads Tens ngt sp absorb sr 11/2 24.76 2,059.28
12/17/02 Supplies-SureCare-Underpads 11/26 6.05 2,065.33
12/17/02 Suppltes-24 Sure Ca,e Underpads 11/27 145.20 2,210.53
12/17/02 Supplles-Depends 12/6 12.59 2,223.12
12/17/02 Supplles-2 Clorox Bleach 12/6 2.68 2,225.80
12/17/02 Supplles-2 Vinegar 12/6 4.74 2,230.54
12/17/02 Supplles-Gloves, Vinyl 12/7 6.48 2,237.02
12/17102 Supplies-Liquid soap pump bottle 12/7 1.30 2,238.32
12/17/02 Supplies-Ultra Shield Wipes 12/9 5.48 2,243.60
12/17102 Supplles-2 Soap, Jergens Bath 12/9 1.14 2,244.94
12/17/02 Supplies-2 Fabreze spray 12/10 15.90 2,260.84
12/17/02 Supplles-Gloves, Vinyl 12/12 6.48 2,267.32
01/01/03 Rent 2,200.00 4,467.32
01/01/03 Level of Care "The Bridge' 1,350.00 5,817.32
01/10/03 Beauty Shop-Cut Only 1/6 8.50 5,825.82
01/20/03 Supplles-Gloves, Vinyl 12/16 5.40 5,831.22
01/20/03 Supplles.soap, Jergens bath 12/23 0.57 5,831.79
01/20/03 Suppltes-Gloves, Vinyl 12128 5.40 5,837.19
01/20/03 Supplles-laundry service for 1 month 1/1 132.50 5,969.69
01/20/03 Supplles-5oaP, Jergens bath 1/2 0.57 5,970.26
01/20/03 Supplles-L\quld soap pump boIIIe 1/8 1.30 5,971.56
01/20/03 Supplles-C-fold paper towels 1/8 1.14 5,972.70
01/20/03 Supplles-Uqutd soap pump bolUe 1/13 1.30 5,974.00
01/22/03 5,825.82 148.18
CONTINUED
ROBe LImited Partnership
202 Btack Malt Road
DouglassvUle, PA 19518
statement
Account:
ho,obc - 0227 - hocOnjo1
Date: 04116/03
John Cotrona
4833 E. T,lndle Road
Apt 511
Mechanlcsburg, PA 17050
Payment:
Payment Due Upon Recelpt
Date Description Charges payments Balance
Balance Forward 148.18
02/01/03 Rent 2,200.00 2,348.18
02101/03 Level of Care "The BrIdge" 1,350.00 3,698.18
02/04103 2 Gloves, Vinyl 10/30/02 10.80 3,708.98
02/04103 Ultra Shield Wipes 11/1/02 5.48 3,714.46
02/04103 C..fold Paper Towets 11/1/02 1.14 3,715.80
02/04103 Soap, Jergens Bath 11/11/02 0.51 3,716.17
02/04103 DIsinfectant Deodoran111/11/02 3.08 3,719.25
02/04103 2 Washcloth lanolin 11123102 11.00 3,730.25
02/04103 Liquid soap pump boltIe 1/1/03 1.30 3,731.55
02/20103 Supplies-2 Vinegar 1/16 4.74 3,736.29
02/20103 Supplies-2 Febrea Liquid 1/16 14.55 3,750.64
02/20103 SUpplles-Jergens Soap 1/16 5.70 3,756.54
02120103 SUpplles-C-fold paper towels 1/24 1.14 3,751.68
02/20103 SUpplies-2 Gloves, ~ 1/24 10.80 3,768.48
02/20103 SUpplles-Uttra Shield Wipes 1/24 5.48 3,773.96
02/20103 SUpplies-Dlslnfectant Deodorant 1/24 3.08 3,m.04
02/20103 SUpplles-Soap, Jergens Bath 1/24 0.57 3,m.61
02120103 Supplles-2 Washcloth lanolin 1/28 11.00 3,786.61
02/20103 Supplles-Qlntmentll31 5.26 3,793.87
02/20103 Supplies-Prescription drugs 2/5 46.38 3,840.25
02120103 Supplies-VInegar, Febreeze 2/14 39.68 3,879.93
02/20103 SUpplles-Laundry 4 weeks 2/15 132.50 4,012.43
03101/03 Rent 2,200.00 6,212.43
03101/03 Level of Care "The Bridge" 1,350.00 7,562.43
03111/03 Late Fee 25.00 7,587.43
03119103 Transport-315 Carlisle Hospital 4.90 7,592.33
03/19/03 SUpplles-Dlsinfectant Deodorant 2/17 3.08 7,595.41
03/19103 Supplles-GIov8S, Vinyl 2/21 5.40 7,600.81
03/19103 Supplles-GIov8S, ~ 3/5 5.40 7,606.21
03/19/03 Supplles-2 Soap, Jergens Bath 319 1.14 7,607.35
03/19/03 Supplies-Washclolh Lanoltn 3/13 5.50 7,612.85
03/19/03 Supplles-Laundry 3/13 125.00 7,737.85
04/01/03 Rent 2,200.00 9,937.85
04/01/03 Lave! of Care "The Brldge" 1,350.00 11,287.85
04102/03 Beauty Shop-Cut Only 3/31 10.00 11,297.85
CONTINUED
ROBe Limited Partnership
202 Black Matt Road
Dou91assvllle, PA 19518
Account
Statement
horobc - 0227 - hoconJol
Dale: 04/16103
John Colrona
4833 E. Trlndle Road
Apt 611
Mechanlcsburg, PA 17050
Payment Due Upon Receipt.
Payment:
Data DescrIption Charges Payments Balance
Balance Forward 11,297.85
04/03103 Credit AprU Levei of Care -1,350.00 9,947.85
04106I03 Rent Credil 04106I03-04130I03 -1,728.00 8,219.85
04106I03 Carpet Replacement 1,000.00 9,219.85
04/10103 :Deposit Credit -500.00 8,719.85
04/14/03 SUpplles-Gloves, Vinyl 3117 5.40 8,725.25
04/14103 SUpplles-3 Ba%a Cream 3118 35.55 8,760.80
04/14/03 SUpplles-Olsinfectant Deodorant 3121 3.08 8,763.88
04/14/03 SUpplles-3O Pads Tens night spr abs 3122 5.10 8,788.98
04/14/03 Supplles-l0 Pads lena nighl spr abs 3126 1.70 8,770.88
04/14103 Supplles-Gloves, VInyl 3129 5.40 8,776.08
04/14/03 Supplles-12 Pads lena night spr abs 3129 2.04 8,778.12
04/14/03 SUpplles-24 Pads lena night spr ebs 3/31 4.08 8,782.20
04/14/03 SUpplles-laundry Charge 50.00 8,832.20
Currant
30 Days
3,855.88
60 Days
3,231.55
1,744.77
90 Days Amount Due
0.00 8,832.20
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Steven J. Proctor, Esquire
Attorney LD. #24428
Binder, Kalis & Proctor, P.C.
1035 High Street
Pottstown, P A 19464
610-323-6200
Attorneys for Plaintiff
COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION-LAW
ROBC LIMITED PARTNERSHIP
202 Black Matt Road
Douglassville, P A 19518
Plaintiff
: CASE NO. 03-4849 Civil Term
V.
JOHN COTRONA
2830 Carol Road
York, PA 17402
Defendant
CERTIFICATE OF SERVICE
I, Steven J. Proctor, Esquire, hereby certify that a true and correct copy of Plaintiffs
Complaint has been served upon the above Defendant at the above address by U.S. Mail, first
class, postage prepaid on: February 27,2004:
Binder~alis & proctor,',p.c.
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By:
Steven J. Proctor, Esquire
Attorney for Plaintiff
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Steven J. Proctor, Esquire
Attorney I.D. #24428
Binder, Kalis & Proctor, P.C.
1035 High Street
Pottstown, P A 19464
610-323-6200
Attorneys for Plaintiff
COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION-LAW
ROBC LIMITED PARTNERSHIP
Plaintiff
: CASE NO. 03-4849
V.
JOHN COTRONA
Defendant
PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Please enter a judgment of default in favor of plaintiff ROBC Limited Partnership and
against defendant John Cotrona for defendant's failure to plead to the complaint in this action
within the required time. The complaint contains a notice to defend within 20 days from the
date of service thereof. Defendant was served the complaint on February 27, 2004 and
defendant's answer was due March 18,2004.
Attached as Exhibit "A" is a copy of Plaintiff's written Notice of Intention to File a
Praecipe for Entry of Default Judgment, which I certify was mailed by regular mail to the
defendant at his last known address on March 19,2004, which is at least 10 days prior to the
filing of this Praecipe.
Please assess damages in the amount of
complaint.
,485.85, being the amount demanded in the
.~~
Steve J. Proctor, Esquire
Attorney for Plaintiff
Steven J. Proctor, Esquire
Attorney J.D. #24428
Binder, Kalis & Proctor, P.C.
1035 High Street
Pottstown, P A 19464
610-323-6200
Attorneys for Plaintiff
COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
ROBC LIMITED PARTNERSHIP
202 Black Matt Road
Douglassville, P A 19518
Plaintiff
: CASE NO. 03-4849 Civil Term
V.
JOHN COTRONA
2830 Carol Road
York,PA 17402
Defendant
TO: JOHN COTRONA
2830 Carol Road
York,PA 17402
IMPORTANT NOTICE
Pursuant to Pa. R.C.P. No. 237.1(a)(2) and 237.5
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A
WRlTTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE N WRlTING
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 JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A
HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT
RlGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIA TION
2 LIBERTY A VENUE
CARLISLE, PA 17013
717-249-3166
800-990-9108
t2-XH! If, ( ('. A "
Steven J. Proctor, Esquire
Attorney I.D. #24428
Binder, Kalis & Proctor, P.C.
1035 High Street
Pottstown, P A 19464
610-323-6200
Attorneys for Plaintiff
COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
ROBC LIMITED PARTNERSHIP
Plaintiff
: CASE NO. 03-4849 Civil Term
V.
JOHN COTRONA
Defendant
AFFIDAVIT OF NON-MILITARY SERVICE
Steven J. Proctor, Esquire, being duly sworn according to law, deposes and says that
he makes this affidavit on behalf of the within plaintiff, being authorized so to do, and that he
knows of his own personal knowledge, and therefore avers, that defendant, John Cotrona, is at
least 65 years of age; that his place of residence is 2830 Carol Road, York, P A, 17402; that he
is retired, and that he is not in the military service of the United States or its allies, or
otherwise subject to the provisions of the Soldiers and Sailors Civil Relief Act of Congress of
1904 and its amendments, 50 U.S.C. App. ~ 501 et seq.
VERIFICATION
I, Steven J. Proctor, Esquire, hereby verify that I am the Attorney for ROBC Limited
Partnership, and am therefore authorized to execute to this Verification on the Plaintiff s
behalf, and do hereby verify that the facts contained in the foregoing Affidavit of Non-
Military Service are true and correct to the best of my knowledge, information, and belief. I
understand that false statements made herein are subject to the penalties of 18 Pa. C. S. ~4904
relating to unsworn falsification to authorities.
Dotod '( N'1
By:
J. Proctor, Esquire
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Steven J. Proctor, Esquire
Attorney l.D. #24428
Binder, Kalis & Proctor, P.C.
1035 High Street
Pottstown, PA 19464
610-323-6200
Attorneys for Plaintiff
COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
ROBC LIMITED PARTNERSHIP
Plaintiff
v.
JOHN COTRONA
Defendant
: CASE NO. 03-4849 Civil Term
PRAECIPE FOR WRIT OF EXECUTION
To the Prothonotary:
Please issue writ of execution in the above matter,
(1) directed to the sheriff of Cumberland County;
r"" Z<l-~ c"",( ReA'!>, Yo'2-I<-, fA 17'10-;;'"
(2) against John Cofrona; defendant; and
, 'P.".. 17013
f" Coot! ~ASl r\I'S" lSlr...d-, C-Ir sf... I I ,
(3) against Wachovia Bank, N.A., garnishee; and s.."-...,, "a"'7-....,~ I' ""p.o, ,,..Jre.-ro'1"''''<Z'e..s
j...s t:'J iTP'C~ c.9...
(4) index this writ
(a) against John Cofrona, defendant and
(b) against Wachovia Bank, N.A., as garnishee,
as a lis pendens against real property of the defendant in name of garnishee as follows:
(specifically describe property; if space is insufficient attach extra
sheets).
(5)
Amount due
Interest from April 15, 2004 (@$1.55perday)
(Costs to be added)
$9,485.85
$
$
Steven J. Proctor, Esq., Attorney for Plaintiff
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WRIT OF EXECUTION andlor ATTACHMENT
COMMONWEALTH OF PENNSYL VANIA)
COUNTY OF CUMBERLAND)
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due ROBC LIMITED PARTNERSHIP Plaintiff (s)
From JOHN COTRONA 2830 CAROL RD, YORK, PA 17402
NO 03-4849 Civil
CIVIL ACTION - LAW
(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
ofW ACHOVIA BANK, N. A. 604 E HIGH STREET, CARLISLE, P A 17013
GARNISHEE(S) as follows:
SERVE GARNISHMENT INTERROGATORIES AS ATTACHED
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 helshe has been added as a
garnishee and is enjoined as above stated.
Amount Due$9,485.85
L.L.$.50
Interest FROM APRIL 15, 2004@$1.55PERDAY
Ally's Comm % Due Prothy $1.00
Ally Paid $11.50 Other Costs
Plaintiff Paid $15.50
Date: MAY 4, 2004
CURTIS R. LONG
(Seal)
Prothonotary
By: ~~~ ~,~/~. 95
f/ Deputy
REQUESTING PARTY:
Name Steven J. Proctor, Esq.
Address: Binder, Kalls & Proctor, P.C.
1035 High Street
Poltstown, PA 19464
Attorney for: Plaintiff
Telephone: 610-323-6200
Supreme Court ID No. 24428
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2003-04849 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
ROBC LIMITED PARTNERSHIP
VS
COTRONA JOHN
And now RON KERR
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0020:23 Hours, on the 7th day of May
2004, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
COTRONA JOHN
in the
hands, possession, or control of the within named Garnishee
WACHOVIA BANK, N.A. 604 E. HIGH STREET
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
JILL MANLEY (FINANCIAL CENTER 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 Her .
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
.00
.00
.00
.00
.00
.00
So a;:w~ ~
R. Thomas Kl ine ~
Sheriff of Cumberland County
00/00/0000
Sworn and subscribed to before me
this /~ '"ti(.day of -1Y1...-J-o
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By
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Deputy Sheriff
SIRLIN GALLOGLY & LESSER, P.C.
By: Jon C. Sirlin, Esquire
Identification No.: 17498
1529 Walnut Street, Suite 600
Philadelphia, PA 19102
(215) 864-9700
Attorney for Garnishee
: COURT OF COMMON PLEAS
: COUNTY OF CUMBERLAND
ROBC LIMITED PARTNERSIDP
vs.
JOHN COTRONA
and
: NO. 03-4849
W ACHOVIA BANK, N.A.,
GARNISHEE
F,NTRVOF APPF.ARANCR
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of Wachovia Bank, N.A., Garnishee, in the
above-captioned matter.
Date: I,} fJ
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SIRLIN GALLOGLY & LESSER, P.c.
By: Jon C. Sirlin, Esquire
Identification No.: 17498
1529 Walnut Street, Suite 600
Philadelphia, PA 19102
(215) 864-9700
Attorney for Garnishee
ROBC LIMITED PARTNERSHIP
: COURT OF COMMON PLEAS
: COUNTY OF CUMBERLAND
vs.
JOHN COTRONA
and
: NO. 03-4849
W ACHOVIA BANK, NA,
GARNISHEE
ANSWRRS TO TNTRRROGATORmS TN ATTACHMRNT
TO: ROBC LIMITED PARTNERSHIP, Plaintiff
1. No.
2. Yes, an account titled John B. Cotrona with a balance of $861. 70 and an account
titled John B. Cotrona with a balance of $3,071.53. The Sunl of $3,833.23 has been restricted
pursuant to this Writ.
3. - 6. No.
7. See answer to number two above.
Dated: &/7 lac!
/ f
y for Garnishee
WACHOVIA
\\a('ho\i,l Balik. \. \.
P.(l. Bo, :\()(l7
l)hilallt,lllhia. Pt'llII:<~'hallia It)IOI-ahf)7
\'eriticatioll
h:.dlilk'~llliurll1ky, h":lll::: lilli) :-;\\\lrll ~ll.:cn["dillg ll) la\\. d":!llJ:)\.-'S ~llld S~lYS thal ~hc is the
\\'rll or E~eclltion ,,\dl11inlstrator 01' \\'achmla Bank. :\,,\, (j:lt'lllshee herCln. and \erilies
that the statements made in the ro!"cg<Jing :\Ils\\crs to 11ltcrro:~:lwril's ~lrc true and correct
ll) the hest 01' her kncm ledge, Said (j"l'Ilishee undersl"lllb tlLII 1',llsc sl"tel11el1lS herein arc
11l"lle suhJect to pCllaltlc's 01' IS 1',1. CS, Section -11)11-1. I'C"'l1112 l" 5\\ "I'll 1,1lsilicatlon to
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Steven J. Proctor, Esquire
Attorney 1.0. #24428
Binder, Kalis & Proctor, P.C.
1035 High Street
Pottstown, P A 19464
610-323-6200
Attorneys for Plaintiff
COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
ROBC LIMITED PARTNERSHIP
202 Black Matt Road
Douglassville, PA 19518
Plaintiff
: CASE NO. 03-4849 Civil Term
v.
JOHN COTRONA
2830 Carol Road
York, PA 17402
Defendant
v.
WACHOVIA BANK, N.A.
P.O. Box 8667
Philadelphia, PA 19101-8667
Garnishee
PRAECIPE FOR JUDGMENT UPON ADMISSION
To the Prothonotary:
Please enter judgment in favor of the plaintiff and against the garnishee, Wachovia Bank,
N.A, in the amount of$3,833.23, admitted in the answer to interrogatories to be in the garnishee's
possession, together with interests and costs. The amount of the judgment ofthe plaintiff against the
defendant is $9,485.85.
Plaintiff reserves the right to refrain from discontinuing attachment and to proceed against
Garnishee as to any further property or to contest any right in the property claimed by the Garnishee.
I hereby certifY that the precise address fPlaintiff, Defendant and Garnishee are as set
forth in the above caption.
Dated: June 15, 2004
Steven J. Proctor, Esq.
Attorneys for Plaintiff
SIRLIN GALLOGLY & LESSER, P.C.
By: Jon C. Sirlin, Esquire
Identification No.: 17498
1529 Walnut Street, Suite 600
Philadelphia, PA 19102
(215) 864-9700
Attorney for Garnishee
ROBC LIMITED PARTNERSHIP
: COURT OF COMMON PLEAS
: COUNTY OF CUMBERLAND
vs.
JOHN COTRONA
and
: NO. 03-4849
W ACHOVIA BANK, NA,
GARNISHEE
ANSWERS TO TNTRRROr.ATORTRS TN ATIAC.HMRNT
TO: ROBC LIMITED PARTNERSHIP, Plaintiff
1. No.
2. Yes, an account titled John B. Cotrona with a balance of $861.70 and an account
titled John B. Cotrona with a balance of $3,071.53. The sum of $3,833.23 has been restricted
pursuant to this Writ.
3. - 6. No.
7. See answer to number two above.
Dated: (;/7 ~f
IN
Y for Garnishee
WACHOVIA
".,U'llIl,-ia Bank. :"i.A.
P.(" Uo, nM17
l)hilacll,lllhiil. PI'IIIl~yh'allia ItJ!UI-B(){\7
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))hiblll"llhi;l. PI.llll~~.)\-allia 1()IOI~::MI-;
WACHOVIA
Vcri ilcation
1":.llblee:1l GUI'!1lley, be:ing dul) -'"0m according tn 1.1". ,lepuse:s alld "tiS Ihal she: is Ihc
\\'rit of Execution Administrator nl' "'acho\i;1 BanK, :\,A, (jal'lllshcc hcrclI1, und \crities
thut the statements made in the l<lI'egoing Answers 10 Interrogatorics urc true ami correct
tn the best ofber knoll ledge, Said Garnishee underslands th;1I !:rlse statcments herein arc
11U,1e subject to penalties of IS P;l. c.s, Section ..I()!).!. relaling Il' slI'orn J,rlsiilcation to
;lIlthnritics,
K~ecn Gormley
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SIRLIN GALLOGLY & LESSER, p.e
By: Jon e. Sirlin, Esquire, I.D. No.: 17498
1529 Walnut Street, Suite 600
Philadelphia, PA 19102
(215) 864-9700
Attorney for Garnishee
ROBC LIMITED PARTNERSHIP
: COURT OF COMMON PLEAS
: COUNfY OF CUMBERLAND
vs.
JOHN COTRONA
and
: NO. 03.4849
W ACHOVIA BANK, N.A.,
GARNISHEE
RTI,T. OF COSTS OF r.ARNTSHRF" WACHOVTA RANK, N.A
Garnishee, Wachovia Bank, N.A., hereby bills the following costs to the fund attached and
will be satisfied therefrom, as authorized by 42 Pa.C.S.A. Section 2503:
Garnishee's fee pursuant to
42 Pa. C.S.A Section 2503:
Notary Charges:
Entry of Appearance:
Answers to Interrogatories:
Order to Discontinue or Satisfy:
Other:
$1 Vi 00
$ 000
$ 000
$ 000
$ ~ 00
$ 000
$14000
Costs are hereby taxed in the amount of$ It/{) .O() this ~_ day of V' ~'1
,2004.
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ROBC LIMITED PARTNERSHIP
: COURT OF COMMON PLEAS
: COUNTY OF CUMBERLAND
vs.
JOHN COTRONA
and
: NO. 03-4849
W ACHOVIA BANK, N.A.
GARNISHEE
: ATTORNEY LD.# )... <t lfz.s>
ORnRR TO SATISFV .nmr.MRNT Ar.AINST r.ARNTSHRR
TO THE PROTHONOTARY:
Kindly mark the judgment entered against the Garnishee, Wachovia Bank, N.A., in the
above matter, satisfied upon payment of your costs only.
~~
STEVEN J. PROCTOR
Attorney for Plaintiff
Dated: 7! 13-( e '(
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Steven J. Proctor, Esquire
Attorney LD. #2442.8
Binder, Kalis & Proctor, P.C.
1035 High Street
Pottstown, P A 19464
610-323-6200
Attorneys for Plaintiff
COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
ROBC LIMITED PARTNERSHIP
Plaintiff
v.
JOHN COTRONA
Defendant
: CASE NO. 03-4849 Civil Term
PRAECIPE FOR WRIT OF EXECUTION
To the Prothonotary:
Please issue writ of execution in the above matter,
(1) directed to the sheriff of Cumberland County;
2-- 'dLl ~(D I KuCtt>l \{MK {74<JJ.,
~of b ~~k SJ-.. ~rUslL. nUl?
(2) against John Cotrona, defendant; and
(3) against Wachovia Bank, N.A., garnishee; and
(4) index this writ
(a) against John Cotrona, defendant and
(b) against Wachovia Bank, N.A., as garnishee,
as a lis pendens against real property of the defendant in name of garnishee as follows:
(specifically describe property; if space is insufficient attach extra
sheets).
(5)
Amount due
Interest from April 15, 2004 (@ $1.55 per day)
(Costs to be added)
$5,792.62
$ 215.45
$
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WRIT OF EXECUTION
Commonwealth of Pennsylvania ) SS
County of Cumberland )
To the Sheriff of Cumberland County:
To satisfy the judgment, interest and costs against John Cotrona, defendant:
(I) you are directed to levy upon the property of the defendant and to sell his interest therein;
(2) you are also directed to attach the property of the defendant not levied upon in the
possession of Wachovia Bank, N.A., as garnishee, including but not limited to any deposit
accounts (specifically describe property), and to notify the garnishee that
(a) an attachment has been issued;
(b) the garnishee is enjoined from paying any debt to or for the account of the
defendant and from delivering any property of the defendant or otherwise disposing thereof.
(3) if property of the defendant not levied upon and subject to attachment is found in the
possession of anyone other than a named garnishee, you are directed to notify him that he has
been added as a garnishee and is enjoined as above stated.
Arnountdue
Interest from April 15, 2004
(Costs to be added)
$5,792.62
$ 215.45
$
Curt Long, Prothonotary
(Clerk)
Seal of the Court by
(Deputy)
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-4849 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due ROBC LIMITED P ARTNERSmp Plaintiff(s)
From JOHN COTRONA, 2830 CAROL ROAD, YORK PA 17402.
(I) You are directed to levy upon the property of the defendant (s)and to seIl
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
ofW ACHOVlA BANK, N.A., 604 E. mGH ST., CARLISLE P A 17013 GARNISHEE(S) as foIlows:
ATTACH THE PROPERTY OF DEFT IN POSSESSION OF GARNISHEE INCLUDING BUT
NOT LIMITED TO ANY DEPOSIT ACCOUNTS. KINDLY SERVE INTERROGATORIES UPON
GARNISHEE BANK.
and to notify the gamishee(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 hirnlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $5,792.62
L.L.
Interest FROM 4/15/04 @ $1.55 PER DIEM = $215.45
Arty's Conun % Due Prothy $1.00
Arty Paid $45.00 Other Costs
Plaintiff Paid
Date: SEPTEMBER 13, 2004
CURTIS R. LONG
(Seal)
pr~th50~ ,J ~ . ~
By., ~,k /7
\ Depu~ ,
REQUESTING PARTY:
Name STEVEN J. PROCTOR, ESQUIRE
Address: 1035 mGH ST.
POTTSTOWN PA 19464
Attorney fur: PLAINTIFF
Telephone: (610) 323-6200
Supreme Court ID No. 24428
7
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
Surcharge
Levy
Certified Mail
Post Pone Sale
Garnishee
TOTAL $
Advance Costs:
Sheriffs Costs:
150.00
150.00
$ 000.00
18.00
68.05
.50
1.00
3.45
30.00
20.00
Refunded to Attyon 10104/04
9.00
150.00
Sworn and Subscribed to before me
This/]'" dayof(Pt.~
.,
2004 A.D.( .LIU.__ a fh,lt..." ~
T Pr~thonotary
So Answers;
~~~~
R. Thomas Kline, Shenff
CJ~~ q. ~halu/ (
By Claudia A. Brewbaker Il
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYL VANIA)
COUNTY OF CUMBERLAND)
'10 03.4849 Civil
CIVIL ACTION LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due ROBC LIMITED PARTNERSHIP Plaintiff (s)
From JOHN COTRONA 2830 CAROL RD, YORK, P A 17402
(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
ofW ACHOVIA BANK, N. A. 604 E HIGH STREET, CARLISLE. P A 17013
GARNISHEE(S) as follows:
SERVE GARNISHMENT INTERROGATORIES AS ATTACHED
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) [fproperty of the defendant(s) not tevied npon 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$9,485.85
L.L.$.50
Interest FROM APRIL 15, 2004 @ $1.55 PER DAY
Atty's Comm % Due Prothy $1.00
Atty Paid $11.50
Plaintiff Paid $15.50
Other Costs
Date: MAY 4, 2004
CURTIS R. LONG
(Seal)
Prothonotary
By. *~L~ /<' ~Y/.z1, #f
i/ Deputy
REQUESTING PARTY:
Name Steven J. Proctor, Esq.
Address: Binder, Kalis & Proctor, P.c.
1035 High Street
Pottstown, PA 19464
Attorney for: Plaintiff
Telephone: 610-323-6200
Snpreme Court ID No. 24428
SIRLIN GALLOGLY & LESSER, P.c.
By: Jon C. Sirlin, Esquire
Identification No.: 17498
1529 Walnut Street, Suite 600
Philadelphia, PA 19102
(215) 864-9700
Attorney for Garnishee
ROBC LIMITED PERTNERSHIP
: COURT OF COMMON PLEAS
: COUNTY OF CUMBERLAND
vs,
JOHN COTRONA
and
: NO, 03-4849
WACHOVIABANK, N.A.,
GARNISHEE
F,NTRV OF APPF,ARANCF
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of Wachovia Bank, N.A., Garnishee, in the
above-captioned matter,
c
JONCS
Attorney fi Garnishee
Date:
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SHERIFF'S RETURN - GARNISHEE
CASE NO: 2003-04849 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
ROBC LIMITED PARTNERSHIP
VS
COTRONA JOHN
And now ROBERT BITNER
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0014:21 Hours, on the 18th day of October ,2004, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
COTRONA JOHN
, in the
hands, possession, or control of the within named Garnishee
WACHOVIA BANK, N.A. 604 E. HIGH ST
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
JILL MANLEY (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 Her .
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
.00
.00
.00
.00
.00
.00
So ;s-:-~ "'t: _ ~
R. Thomas Kl ine ~
Sheriff of Cumberland County
00/00/0000
Sworn and subscribed to before me
this ;<'J!3': day of (]fJ.;.L
~tJt:)'( A.D.
n v.-C! ~
p~onotary
d;,vA
Sheriff
SIRLIN GALLOGLY & LESSER, P.c.
By: Jon C. Sirlin, Esquire
Identification No.: 17498
1529 Walnut Street, Suite 600
Philadelphia, PA 19102
(215) 864-9700
Attorney for Garnishee
ROBC LIMITED PERTNERSIllP
: COURT OF COMMON PLEAS
: COUNTY OF CUMBERLAND
vs.
JOHN COTRONA
: NO. 03-4849
and
W ACHOVIA BANK, N.A,
GARNISHEE
ANSWF,RS TO TN1"'F.RRO(;ATORTF,S TN ATIACHMF,NT
TO: ROBC LIMITED PERTNERSHIP, Plaintiff
1. No.
2. Yes, an account titled John B. Cotrona. The sum of $1,179.46 has been restricted
pursuant to this Writ.
3. - 6. No.
7. See answer to number two above.
Dated:
Wachovia Bank, N.A.
P.O. Box 8667
Philadelphia, Pennsylvania 19101-8667
WACHOVIA
Verification
Kathleen Gormley, being duly sworn according to law, deposes and says that she is the
Writ of Execution Administrator ofWachovia Bank, N.A Garnishee herein, and verifies
that the statements made in the foregoing Answers to Interrogatories are true and correct
to the best of her knowledge. Said Garnishee understands that false statements herein are
made subject to penalties of 18 Pa. C.S. Section 4904, relating to sworn falsification to
authorities.
K~~
Kathleen Gormley
Manager
Dated: / ( 1--- 0 '-'I
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Steven 1. Proctor, Esquire
Attorney J.D. #24428
Binder, Kalis & Proctor, P.C.
1035 High Street
Pottstown, P A 19464
610-323-6200
Attorneys for Plaintiff
"
COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION-LAW
ROBC LIMITED PARTNERSHIP
202 Black Matt Road
Douglassville, P A 19518
Plaintiff
: CASE NO. 03-4849 Civil Term
v.
JOHN COTRONA
2830 Carol Road
York, PA 17402
Defendant
v.
W ACHOVIA BANK, N.A.
P.O. Box 8667
Philadelphia, P A 19101-8667
Garnishee
PRAECIPE FOR JUDGMENT UPON ADMISSION
To the Prothonotary:
Please enter judgment in favor of the plaintiff and against the garnishee, Wachovia Bank,
N .A, in the amount of $1,179.46, admitted in the answer to interrogatories to be in the garnishee's
possession, together with interests and costs. The amount of the judgment of the plaintiff against the
defendant is $9,485.85.
Plaintiff reserves the right to refrain from discontinuing attachment and to proceed against
Garnishee as to any further property or to contest any right in the property claimed by the Garnishee.
I hereby certify that the precise address of Plaintiff, Defendant and Garnishee are as set
forth in the above caption.
Dated: November 8, 2004
\
Steven J. Proctor, Esq.
Attorneys for Plaintiff
Steven J. Proctor, Esquire
Attorney J.D. #24428
Binder, Kalis & Proctor, P.c.
1035 High Street
Pottstown, P A 19464
610-323-6200
Attorneys for Plaintiff
COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION-LAW
ROBC LIMITED PARTNERSHIP
202 Black Matt Road
Douglassville, P A 19518
Plaintiff
: CASE NO. 03-4849 Civil Term
v.
JOHN COTRONA
2830 Carol Road
York, PA 17402
Defendant
v.
W ACHOVIA BANK, N.A.
Garnishee
TO: Wachovia Bank, N.A.
CIO Sirlin Gallogly & Lesser
1529 Walnut Street
Suite 600
Philadelphia, P A 19102
Wachovia Bank
P.O. Box 8667
Philadelphia, P A 19101-8667
NOTICE
Pursuant to Rule 236, you are hereby notified that a judgment has been entered on
the decision in the above-entitled proceeding.
Date:
Prothonotary
, .
SIRLIN GALLOGLY & LESSER, P.C.
By: Jon C. Sirlin, Esquire
Identification No.: 17498
1529 Walnut Street, Suite 600
Philadelphia, PA 19102
(215) 864-9700
Attorney for Garnishee
ROBC LIMITED PERTNERSHIP
: COURT OF COMMON PLEAS
: COUNTY OF CUMBERLAND
vs.
JOHN COTRONA
: NO. 03-4849
and
W ACHOVIA BANK, N.A.,
GARNISHEE
A NSWF,RS TO TNTF.RROGA TORTRS TN A 11 ACHMF:NT
TO: ROBC LIMITED PERTNERSIDP, Plaintiff
1. No.
2. Yes, an account titled John B. Cotrona. The sum of $1,179.46 has been restricted
pursuant to this Writ.
3. -6. No.
7. See answer to number two above.
01
JONC. ~
Attorney for Garnishee
Dated:
Wachovia Bank, N.A.
P.O. Box 8667
Philadelphia. Pt"nnsylvania 19101-8667
WACHOVIA
Verification
Kathleen Gormley, being duly sworn according to law, deposes and says that she is the
Writ of Execution Administrator ofWachovia Bank, N.A. Garnishee herein, and verifies
that the statements made in the foregoing Answers to lnterrogatories are true and correct
to the best of her knowledge. Said Garnishee understands that false statements herein are
made subject to penalties of 18 Pa. C.S. Section 4904, relating to sworn falsification to
authorities.
K~~h
Manager
Dated: I (r /-.-- 0 l,-(
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ROBC LIMITED PERTNERSHIP
: COURT OF COMMON PLEAS
: COUNTY OF CUMBERLAND
vs.
JOHN COTRONA
: NO. 03-4849
and
W ACHOVIA BANK, N.A.
GARNISHEE
: ATTORNEYLD.# c2 Y t/ LP
ORDER TO SATISFY .rrIDGMENT AGAINST GARNISHEE
TO THE PROTHONOTARY:
Kindly mark the judgment entered against the Garnishee, Wachovia Bank, N .A., in the
above matter, satisfied upon payment of your costs only.
EVE J. PROCTOR
Attorney for Plaintiff
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Steven J. Proctor, Esquire
Attorney LD. #24428
Binder, Kalis & Proctor, P.C.
1035 High Street
Pottstown, P A 19464
610-323-6200
Attorneys for Plaintiff
COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
ROBC LIMITED PARTNERSHIP
Plaintiff
: CASE NO. 03-4849 Civil Term
v.
JOHN COTRONA
Defendant
To the Prothonotarv:
PRAECIPE FOR WRIT OF EXECUTION
Please issue writ of execution in the above matter,
(1) directed to the sheriff of Cumberland County;
(2) against John Cotrona, defendant; and
d-P:36 ,C22/'-0l 12.6 ;zd( L(c.vt...l. pI). 17l{u ~
(3) against Wachovia Bank, lV.A., garnishee; and
~"I f!.2s+- WI.:."- S'-1 &J.,{lc /)IJ- 17<J(]
(4) index this writ I I ,
(a) against John Cotrona, defendant and
(b) against Wachovia Bank, N.A., as garnishee,
as a lis pendens against real property of the defendant in name of garnishee as follows:
(specifically describe property; if space is insuf1lcient attach extra
sheets).
(5)
Amount due
Interest from April 15, 2004 (@ $1.55 per day)
(Costs to be added)
$2,736.36
$ 587.65
$
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Steven J. Proctor, Esq., Attorney for Plaintiff
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-4849 Civil
CIVIL ACTION -- LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due ROBC LIMITED PARTNERSHIP, Plaintiff (s)
From JOHN COTRONA, 2830 CAROL ROAD, YORK, PA 17402
(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 WACHOVIA BANK, N.A., 604 EAST HIGH ST., CARLISLE, PA 17013 - SERVE
INTERROGA TOARlES
GARNISHEE(S) as follows:
and to notify the gamishee(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) 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 himlher that he/she has been added as a
garnishee and is enjoined as above stated,
Amount Due $2,736.36
L.L.
Interest FROM 4/15/04 @ $1.55 PER DAY -- $587.65
Atty's Comm %
Atty Paid $283.75
Plaintiff Paid
Date: SEPTEMBER 16, 2005
Due Prothy $1.00
Other Costs
Prothonotar
(Seal)
By:
Deputy
REQUESTING PARTY:
Name STEVEN J. PROCTOR, ESQUIRE
Address: BINDER, KALIS & PROCTOR, P.C.
1035 EAST HIGH STREET
POTTSTOWN, PA 19464
Attorney for: PLAINTIFF
Telephone: 610-323-6200
Supreme Court ID No. 24428
WRIT OF EXECUTION andlor ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-4849 Civil
CIVIL ACTION -- LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due ROBC LIMITED PARTNERSHIP Plaintiff(s)
From JOHN COTRONA, 2830 CAROL ROAD, YORK PA 17402.
(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
ofW ACHOVIA BANK, N.A., 604 E. ffiGH ST., CARLISLE PA 17013 GARNISHEE(S) as follows:
ATTACH THE PROPERTY OF DEFT IN POSSESSION OF GARNISHEE INCLUDING BUT
NOT LIMITED TO ANY DEPOSIT ACCOUNTS. KINDLY SERVE INTERROGATORIES UPON
GARNISHEE BANK.
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 ofthe 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 gamishee, you are directed to notify himlher that helshe has been added as a
gamishee and is enjoined as above stated.
Amount Due $5,792.62
L.L.
Interest FROM 4/15/04 @ $1.55 PER DIEM = $215.45
Arty's Connn %
AttYPaid~ (q~"-(j()
Plaintiff Paid
Date: SEPTEMBER 13, 2004
Due Prothy $1.00
Other Costs
(Seal)
CURTIS R. LONG
:;,t:],; ~ 111~ ~
(j Dep~ a
REQUESTING PARTY:
Name STEVEN J. PROCTOR, ESQmRE
Address: 1035 HIGH ST.
POTTSTOWN PA 19464
Attorney for: PLAINTIFF
Telephone: (610) 323-6200
Suprerne Court ID No. 24428
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this
Writ is returned ABANDONED, no action taken in six months.
Sheriffs Costs:
Docketing
Poundage
Advertising
Law Library
Prothonotary
Mileage
Misc.
Surcharge
Levy
Post Pone Sale
Postage
Garnishee
TOTAL
So Answers;
18.00
61.13
Advance Costs: 150.00
Sheriffs Costs 142.83
7.17
1.00
3.70
Refunded to Atty on 09/21/05
30.00
20.00
9.00
142.83
Sworn and Subscribed to before me
~~&~
...c;
R. Thomas Kline, S erift "<l
BY( J Q f I ~ ~,_ ''b.~~.:okL/ .:;,
'0
""
,
2005 A.D.
Z-S:I d S 1 130 ~OOl
Vd,'AHHIO:J UN'rl838WI1:J
::Uflj3HS 3Hl .:10331.:1.:10
",
-; \ stH,:3J
{~i
-....:-.,......
~.;~-'
(\
.,r
{,J J
\.,'
"'~~!~~
,. I ~;\fol
./ 9f5/3<:>'1
~ //;9,;,,1
J....:. _
.j3\:.-
, ~~.j
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this
Writ is returned ABANDONED, no action taken in six months.
Sheriffs Costs:
Docketing
Poundage
Advertising
Law Library
Prothonotary
Mileage
Misc.
Surcharge
Levy
Post Pone Sale
Certified Mail
Postage
Garnishee
TOTAL
~"J)~~~~
18.00
1.64
1.00
4.00
30.00
20.00
9.00
83.64
Z I :[ d OZ dJS ~aoz
? ~-:" -~., ! i '_~
.:d I d j 11:.;-
'." l ~ .,'. '. j
~jO ':J:JU.JU
Advance Costs: 150.00
Sheriffs Costs 83.64
66.36
Refunded to Atty on 10/25/06
S" 0 An~swers;
~ V~^
, ~ 4"..-R'~,~-
,
R. Thomas Kline, Sheriff
Byt.l~di~ ~al~
~
~
~
"';>
~
~
'~~,'\ !.c\\'.'.
?)I~} \\
l.uV lIL. $41 q "-
lVA-- j~ lJ 9 ~~
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-4849 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due ROBC LIMITED PARTNERSHIP, Plaintiff (s)
From JOHN COTRONA, 2830 CAROL ROAD, YORK, P A 17402
(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 WACHOVIA BANK, N.A., 604 EAST HIGH ST., CARLISLE, PA 17013 - SERVE
INTERROGATOARIES
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 ofthe 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 him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $2,736.36
L.L.
Interest FROM 4/15/04 @ $1.55 PER DAY -- $587.65
Arty's Comm %
Atty Paid $283.75
Plaintiff Paid
Date: SEPTEMBER 16, 2005
Due Prothy $1.00
Other Costs
(Seal)
By:
Deputy
REQUESTING PARTY:
Name STEVEN J. PROCTOR, ESQUIRE
Address: BINDER, KALIS & PROCTOR, P.C.
1035 EAST IDGH STREET
POTTSTOWN, PA 19464
Attorney for: PLAINTIFF
Telephone: 610-323-6200
Supreme Court ID No. 24428