HomeMy WebLinkAbout08-0173
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CHURCH OF GOD HOME, INC.,
Plaintiff,
V. No. b$ - I'73 Civ 1Term
ROBERT NORTON,
Defendant. CIVIL ACTION - EQUITY
NOTICE TO DEFEND
Pursuant to PA RCP No. 1018.1
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims
set forth in the following pages, you must take action within twenty (20) days after this
complaint and notice are served, by entering a written appearance personally or by
attorney and filing in writing with the court your defenses or objections to the claims set
forth against you. You are warned that if you fail to do so the case may proceed without
you and a judgment may be entered against you by the court without further notice for
any money claimed in the complaint or for any other claim or relief requested by the
plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Lawyer Referral Services
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
Telephone: (717) 249-3166
(800) 990-9108
ORIGINAL
EN LA CORTE DE ALEGATOS COMUN DEL
CONDADO DE CUMBERLAND, PENNSYLVANIA
CHURCH OF GOD HOME, INC.,
Plaintiff,
V. No.
ROBERT NORTON,
Defendant. CIVIL ACTION - EQUITY
AVISO PARA DEFENDER
Conforme a PA RCP Num. 1018.1
USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de
las demandas que se presentan mas adelante en las siguientes paginas, debe tomar
accion dentro de los proximos veiente (20) dias despues de la notificacion de esta
Demanda y Aviso radicando personalmente o por medio de un abogado una
comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objeccionee
a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de
tomar accion como se describe anteriormente, el caso puede proceder sin usted y un
fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra
reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya
por la Corte sin mas aviso adicional. Usted pued perder dinero o propiedad u otros
derechos importantes para usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO
INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA
SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A
CERCA DE COMO CONSEGUIR UN ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES
POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE
AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A
PERSONAS QUE CUALIFICAN.
Lawyer Referral Services
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
Telefono: (717) 249-3166
(800) 990-9108
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CHURCH OF GOD HOME, INC.,
Plaintiff,
V. No. 4S'-173 (Lr%! -6-
ROBERT NORTON,
Defendant. CIVIL ACTION - EQUITY
COMPLAINT
AND NOW COMES, Plaintiff, Church of God Home, Inc. ("Plaintiff Church of
God"), by and through its attorneys, SCHUTJER BOGAR LLC, and files the within
Complaint against Defendant, Robert Norton ("Defendant Norton"), and in support
thereof, provides as follows:
1. Plaintiff Church of God is a Pennsylvania corporation with its principal
offices located at 801 North Hanover Street, Carlisle, Pennsylvania 17103.
2. Defendant Norton is an adult individual who resides at 1829 Del Norte
SW, Albuquerque, New Mexico 87105.
3. On or about November 14, 2006, Defendant Norton made application on
behalf of his mother, Mildred Norton, for admission to Plaintiff Church of God's skilled
nursing facility located at 801 North Hanover Street, Carlisle, Pennsylvania 17103.
4. On or about November 14, 2006, Plaintiff Church of God and Defendant
Norton entered into a written Admission Agreement ("Agreement"). Pursuant to the
Agreement, Plaintiff Church of God agreed to provide Defendant Norton's mother with
skilled nursing care and services in exchange for Defendant Norton's promise to pay a
specific monetary fee from his mother's assets and to secure Medical Assistance benefits
in a timely and proper manner on her behalf when she became eligible for such benefits.
A true and correct copy of the Agreement is attached hereto as Exhibit "A."
5. After Ms. Norton's admission to Plaintiff Church of God's skilled nursing
care facility, she allegedly became insolvent. As a result, pursuant to the Agreement, an
application for Medical Assistance benefits was filed on her behalf.
6. The Application for Medical Assistance benefits was filed on December
18, 2007, and is now pending before the Cumberland County Assistance Office of the
Department of Public Welfare.
7. If the Defendant fails to provide all documents requested by the
Cumberland County Assistance Office and fully cooperate with any actions needed to
determine Ms. Norton's eligibility, the application will be denied.
2
COUNTI
BREACH OF CONTRACT/SPECIFIC PERFORMANCE
8. Paragraphs 1 through 7 are incorporated herein by reference as if fully set
forth.
9. Plaintiff Church of God has provided skilled nursing care and services to
Defendant Norton's mother, Mildred Norton, in accordance with the terms and
conditions of the Agreement.
10. Defendant Norton breached the Agreement with Plaintiff Church of God
when he failed to secure Medical Assistance benefits for his mother, and Defendant
Norton continues to breach the Agreement with Plaintiff Church of God by refusing to
cooperate and provide all documentation needed by the Cumberland County
Assistance Office to determine his mother's eligibility for Medical Assistance benefits.
11. Defendant Norton's breach of the Agreement with Plaintiff Church of God
has irreparably harmed and continues to irreparably harm Plaintiff Church of God.
12. Upon information and belief, at all times material hereto, Defendant
Norton's mother has been financially unable to fully compensate Plaintiff Church of
God for the care and services that it has rendered to her in accordance with the terms
and conditions of the Agreement.
3
13. Accordingly, only a decree of specific performance will adequately protect
the interests of Plaintiff Church of God and provide it with the benefits and/or
protections promised under the Agreement.
WHEREFORE, Plaintiff Church of God seeks a decree from this Honorable Court
which orders specific performance of the Agreement between the parties.
Respectfully submitted,
SCHUTJER BOGAR LLC
Dated: ? 6 26 By.
Brad y A. Schutjer
Attorney I.D. No. 75954
(717) 909-5921
Mariclare L. Hayes
Attorney I.D. No. 201289
(717) 909-5922
417 Walnut Street, 4th Floor
Harrisburg, PA 17101
Attorneys for Plaintiff
4
VERTE ,CATION
The undersigned hereby verifies that the Statements of fact in the foregoing
Complaint are true and correct to the best of my knowledge, information and belief. I
understand that any false statements therein are subject to the penalties contained in 1.8
Pa. C.S.A. § 4904, relating to unworn falsification to authorities.
Darted: ? r, 1, r, n - L-e 9-ra 4 4 -
Sharon Cramer, SR Billing/AR Specialist
Church of God Home, Inc.
E
_ .? CHURCH OF GOD HOME, INC'.
ADMISSION AND CARE AGREEMENT
TABLE OF CONTENTS
PAGE
1. PROVISION OF SERVICES . . . . . . . . . . .. . . . . 26
2. RECURRING CHARGES . . . . . . . . . . . . . . . . . . . . 26
3. NON-RECURRING CHARGES . . . . . . . . . . . . . . . ... .27
4. MISCELLANEOUS CHARGES AND OUTSIDE SERVICES . . . . . 27
5- ADMISSION .. .. 28
6. PERIODIC BILLINGS AND PAYMENT DUE DATE 28
7. CHANGES IN 'CAARGES . . . . . . . . . . . . . . . . . . 28
B. PARTICIPATION. IN MEDICARE/MEDICAID PROGRAMS 28
9. .OBLIGATIONS OF RESPONSIBLE PARTY .29
10. FXADMISSION - BED/ACCOMMODATION HOLD POLICY.... .. .29
11. REFUNDS. . . . . . . . . . . . . . ... . . _ . . . . . . 29
12. PERSONAL FINANCES . . . . . . . . . . . . . . 29
13. TERMINATION, TRANSFER OR DISCHARGE 30
14. THIRD-PARTY PAYMENTS . . . . ... 31
15. PERSONAL PROPERTY . . . . . . . . . . . . . . . . 32
16. RESPONSIBILITIES OF RESIDENT .32
17. MISCELLANEOUS PROVISIONS - .32
CHURCH OF GOD HOME, INC.
ADMISSION AND CARE AGREEMENT
THIS AGREEMENT is made on this y of 111,10=Ma . ;1C0L _ , by
and between The Church of God Home, Inc., called the "Facility," a
Pennsylvania non-profit corporation located at 801 North Hanover
street, C rlisle, 0Cumberland County, Pennsylvania,
and called Resident
and [)92E?Z-t- I/ UZ_ j j? called "Responsible Party"
The Resident and the Responsible Party reaffirm that the
information provided in the Pre-Admission Questionnaire is true and
correct and understand that the submission of false information may
constitute grounds to terminate this -Agreement.* The Resident has
applied for admission to the Facility and the Facility has approved
the. Application for Admission. Therefore, the .Facility, The
Resident and Responsible Party agree to the following. :ten
1. PROVISION OF SERVICES. The Facility will provide
Resident with:
(a) Skilled nursing care, i.e. professionally supervised
nursing care and related health services under a plan
of services regularly provided under a plan of care.
supervised by licensed personnel and, as required by
the Resident's. medical condition, assistance with
activities of daily living.
(b) Accommodations consistent with the level of care
provided to the Resident including heat, air
conditioning, electricity and hot and cold water.
(c) Bed, bedding, blankets and laundered bed linens, towels
and wash cloths.
(d) Three meals each day, except as otherwise medically
indicated.
(e) Activity programs and social services.
2. RECURRING CHARGES. In exchange for the above services,
the Resident shall pay the following recurring charges:
(a) For skilled nursing care: $. y? -dollars.per day.
714-
Admission and Care Agreement - r=tinued
-3-. NON-RECIIRRING CHARGES. The Resident shall pay the
following non-recurring charges:
(a) A security deposit in the amount of thirty-one (31)
.times the current daily rate for the level of care
required by the resident, will be billed after
admission day. The amount of the security deposit is
$ - No interest will be paid on the security
deposit. Asecurity deposit will not be charged to
residents who are receiving benefits for room and board
provided by Medicare, until the Medicare benefit
concludes. An applicant who is covered by Medicaid is
not required to pay a security deposit.
(b) The cost for enrollment in the community a ce
and ALS (Advance Life Support) Unit is $ This
fee must be paid prior to admission and wi be billed
annually to the.-Resident.
4. MISCELLANEOUS CHARGES AND OUTSIDE SERVICLS. Resident is
responsible :=to pay for other services provided by the Facility
which are not covered by the daily rate/charge.' A list of such
services/charges.is attached to this Agreement on the -Chart of
Costs. n
The services of a licensed physician and dentist, a
registered pharmacist and licensed pharmacy for the provision of
pharmaceutical supplies, a licensed hospital, and- diagnostic
services, will be made available at the Resident's expense.
THE RESIDENT HAS THE RIGHT TO SELECT HIS/HER OWN PHYSICIAN OR ANY
OTHER SERVICE PROVIDER SO LONG AS THE PHYSICIAN OR OTHER SERVICE
PROVIDER IS PROPERLY LICENSED OR REGISTERED UNDER THE LAW, AND THAT
ALL APPLICABLE GOVERNMENT RULES AND POLICIES OF THE-FACILITY ARE
MET.
In addition to the Facility's charges, the Resident is
responsible to pay 'all fees and costs *for goods or services
furnished to or for the Resident by anyone other than the Facility
under this Agreement. The responsibility of the Resident to pay
applies to all fees for costs of services provided for the Resident
by any physician, dentist, optometrist,. therapist, diagnostic or
testing-laboratory, pharmacist, pharmacy, hospital, or any other
person,-facility or entity providing services or goods to or for
the Resident, and for all drugs, medicines, medications,
pharmaceutical supplies, corrective eye lenses, hearing aids,
dentures, hair care, and other personal items or services for the
Resident. SUCH FEES AND COSTS ARE NOT INCLUDED IN THE ROME'S DAILY
RATE/CHARGE.
Admission and Care Agreement - continued
S. nDK_ISSION. The Resident will be admitt d, or a bed will
beginning on 1 t -'W r-, .
be reserved-for Resident,
All pre-admission charges will be billed after admission, and
recurring charges will begin to accrue as of the -above•date.
The Resident may reserve an available bed by paying the
daily rate for the bed reserved. The daily rate for the reserved
bed will continue to accrue and be payable until the reservation is
terminated, even if the Resident does not enter the - Home for
whatever reason, including illness, injury, incapacity or death.
6. PERIODIC BILL32MS AND PAYMENT DUE DATE..
(a) on the first of each month, Resident will be billed the
current daily rate for Resident's current level of care
times the number of days in the month. The bill is due
and payable-upon receipt.
(b) Miscellaneous charges (refer to "Chart of Costs"
attached to this Agreement) such as hair care, personal
laundry, incontinency, supplies, etc., are.additional
charges above the. daily rate. These miscellaneous
charges will be added to, and included with,- your
monthly bill.
(c) Pharmacy charges will be billed as a separate part
of the Facility's monthly bill, and will require
a separate check..
(d) -outside providers.will bill directly and separately..
7. CEMMES IN CEARGES. From time to time,the Facility may
change the amount of its charges. In addition, from time to time,
the Facility may change how and when .its charges are computed,
billed or become due. The Facility reserves the right to make any
such changes at any time. Written notice of any such changes will
be given to the Resident thirty (30) days in advance of
implementation, unless- the change is required earlier under any
federal or state law or assistance program.
g. PARTIC2pATSDN IN -MEDICARE/MEDICAID- PROGRAMS. The
Facility participates in the Medicare program administered pursuant
to Title XVIII of the Federal Social Security Act and the
Pennsylvania Medical Assistance Program ("Medicaid") administered
pursuant to the Pennsylvania state plan and Title XIX of the
Federal Social Security. Act. However, the Facility reserves the
right to withdraw from the Medicare/Medicaid.programs at any time
in accordance with the law.
Admission and Care Agreement - coatiaued
-9-. OBLIGATIONS _OF RESPONSIBLE PARTY- The Responsible Party
is responsible for services and supplies that are billed through
the Facility or billed directly to the Resident or Responsible
party by any other provider. The Responsible Party is responsible'
to pay all fees and costs from Resident's resources.
10. READMISSION - BED HOLD POLICY. If the Resident leaves
the Facility for a period of hospitalization, therapeutic .leave, or
any other reason, other than the Resident's death, and if the
Resident is not eligible for, or receiving medical assistance, the
Resident's bed will be reserved and charges for the reserved bed
will continue to accrue, unless the Resident or Responsible Party
-otherwise directs in writing. If the Resident or Responsible Party
elects not to reserve a bed, then the Resident will be eligible for
readmission upon the availability of the first bed suitable for the
Resident's level of care. =
If the Resident is receiving medical assistance benefits
and the Resident leaves. the Facility for -a period of
hospitalization or therapeutic leave, the Resident's bed will be
reserved for the applicable maximum number of days paid for the
reserved bed under the Pennsylvania Medical Assistance, Program.
The current °bed reservation period is fifteen (15) days for
hospitalization, regardless of level of care, fifteen (15) days for
therapeutic leave for residents receiving skilled nursing care,.. and
thirty (30) days for therapeutic leave for residents receiving
intermediate care. The bed reservation period may be subject to
change in accordance with any changes in the- Medical Assistance
Program. If the period of hospitalization or therapeutic leave
ends within 'the reservation period under the Medical Assistance
Program, the Resident may return to the Facility. If the period of
hospitalization or therapeutic leave exceeds the maximum time for
reservation of a bed under the Pennsylvania. Medical Assistance
Program, the Resident must wait until a suitable bed becomes
available for readmission. The Resident is entitled to the first
available bed suitable for the Resident's level of care if, at the
time of readmission, the Resident requires the services provided by
the Home.
11. REFUNDS. The security deposit for private pay residents,
of ter deductions for the payment of any outstanding bills owed to
the Facility, will be refunded within thirty (30) days after the
Resident's. discharge from the Facility or death. Those Nursing
Residents on Medical Assistance will receive their refund, if any
due,' within ninety (90) days. There will.be no other refunds, in
the absence of an overpayment, under this Agreement.-
12.. PERSONAL FINANCES. The Resident has the right to manage
his/her personal funds. The Resident is and will be responsible to
provide his/her personal funds. If the Resident elects, the
Resident may designate, in writing, that the Facility hold and
manage the Resident's personal funds. If the Resident _
Admission and Care Agreement - continued
desig rotes someone other than the Facility to manage his/her
personal funds, the Resident or Responsible Party shall notify the
Facility promptly.- The Resident is not required to make any
designation, and -is responsible for his/her own personal funds
unless such designation is made.
The Resident may revoke, at any time, the designation of
the Facility as the manager of his/her personal funds by providing
the Facility a written notice signed and dated by the Resident or
Responsible Party.
If the Resident transfers to the Home, responsibility to
-manage the Resident's personal funds, the Facility will do so in
accordance with the "Rights of Nursing Facility Residents", a copy
of which is- provided at the time of your admission, and the
Facility's personal funds management-policy. ..The Facility may
deduct, at any time, charges due to - the. Facility under this
agreement from .the Resident's personal funds managed by the
Facility.
13. TERMINATION. TRANSFER OR DISCHARGE.
(a) By .the Resident: The- ..Resident _may terminate this
Agreement upon thirty (30) days written notice to the
Facility. If the Resident leaves the -Facility for any
reason other than a medical=.emergency or his/her death,
the Resident must give.-written -notice to the. Facility
at -least thirty (30).= days , in advance of the departure/
transfer/discharge or termination of the Agreement.
If advance written .notice is -not given to the Facility,
-there will be due to.the Facility its daily and other
charges then in effect for the Resident's current level
of care for the required thirty (3 Q) day notice period.
The charge applies whether or not the Resident remains
at the Facility during the.thi.rty . (30) day period.
(b) By the Facility: The-Facility may terminate the
Resident's stay and transfer or discharge the Resident
if:
(I) the transfer or discharge is necessary.to
meet the Resident's welfare which cannot
be. met by the Facility;
(II) the Resident's health or condition has
improved sufficiently that'the Resident
no longer needs the services_provided by
the Facility;
(III) the safety or health of individuals in the
Facility is or otherwise would be endangered;
Admission and Care Agreement- continued
IV. The charges or other amounts due to the Facility under this Agreement
have not been paid to the Facility or treated as paid to the Facility on the
Resident's behalf by Medical Assistance under the `Medical Assistance
Program or by Federal Medicare benefits under Title XVIII of the Federal
Social Security Act; or
V. The Facility ceases to operate.
The Facility generally will notify the Resident and Responsible Party or if none, a family
member or legal representative of the Resident, if known to the Facility, at least thirty
(30) days in advance of such a transfer or discharge. However, in any case, describe in
subparagraph (l). (l)) and (II1) above. or if the Resident has not resided at the Facility for
at least thirty (30) days. the Facility will give such-notice before transfer or discharge as
is practicable under the circumstances.
14- THIRD PARTY PAYMENTS- The Resident may be or may become eligible
to receive financial-asMst - de'.? a m6urstrrient or'.otlier benefits from third-
parties, such as through p1jVate insurance,- employee lei efit plans. Medical
assistance under the Pennsylvania Macaf Assistance Program, Medicare
benefits, supplementary 7iiedical or other }iealth insurance, supplemental security
income insurance. or old-age survivors' or disability insurance under or pursuant
to the Federal Social Security Act or Pri grain_ lneReside tecomes eligible to
receive payments from any-tb d=parties for the, stay `and care of the Resident. the
Resident/Responsible-Party sfii ll;'ai ah times, cooperate fiWy witli he Facility
and each third-party payments. Cooperatioii'irtcludes; wben requested, providing
information, signing and delivering documents, and having the Facility
designated by the Social Security Adirnnts?ration'as the test ent'S. representative
payee for'receipt of Federal Social :Security benefits or any other governmental
assistance: reimbursement orbeinefits-to the extent of all charges due the Facility.
The Resident irrevocably authbriies t1ie'Facility to n ake:claims "and to take such
other actions as maybe necessary for the Facility's receipt of third-party
payments. To the fullest extent permitted by law. the Resident hereby assigns
now or hereafter payable to the extent of all charges due to the endorse and turn
over to the Facility any payments received from third-parties to the extent
necessary to satisfy the charges under this Agreement.
11/15/2006 10:15. 717-249-8622
Admission and Care Ate- ooetleoed
CH Rtx1 ur LCW r1j ir-
15. - The Resident/ Responsible Party is and will be
reapotnlble to fianifb and mai?tnirt alodrin& jo:wehY. Pei posatssions. sad
otim he= of piowThe fldllty may .lurdt tbt amamrt or type of property that
the Reddeta,may keegl at the fatuity if them is orient space, or if medically
indi ct ojfit:eesiii* is p otsct the riSW or of odw.. All: aor-clothing
items of Vdl bq rijw4led.an6v reddmes ppltoosal hrmSw7 kwAw with
th* medW mcid on the da ntadmit orramy-dqy *wmf cr. The same is
true if tq'Yiovittg an item dQW Suni the re%de4%1oe?? Yott.ere muested to
see the clwp mm regw tag mfdent'a personal property. If net ong labels are
,Oft Rau, please leave them at the nutting station.
tutdod fbr do
16. „Pll1 OF$ 7U Residoem sWl comply frlly with
a!l o tLe;prr?vi s oftltis Agtegmn and the
facll3tyTt; etci B.p¢1k m F" and reguletioru vdtide easy, from tiros to time,
be a the4 or antettdcd.
IT M1SCR&MU8ltOVYOIrt
a_ The Resident and Responmible Patty Wumwledge that they we adult
ho"duals and have reed and understand the teams of this Aptement.
b. The provisions of tl:ls Aareantaot -all bs? oboe Is," of the
b
CANYailN7,lw+eallb o'Pnaylvaale and t iipgo?azod irnm to
the beue5t.o?'oll ote d pthsittzsptave heirs
pt?otisl ` micct ors aria L_ .
C. Tltc va ikufto ?ecivis?? of d is AgecateJd.. ltJc one frorn
another. Ii'sr oir Otis ::. tpepat fegt?l
avtiiotity to be the othireig-in.f?itorce and
tlTect sa if the l?p[gvhdcn had riot liatcp?t O this Agent.
d. 71t: Facility. tMetnp the right, tq c• a?? germs-of dds
Agte mzk tq collf ait So a>s the lr .a:Yegnlatim and
ch ftes In cliisr will be 0? solf ce of
.BA of any
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Respondent
No. 08-173
CIVIL ACTION - EQUITY
AFFIDAVIT OF SERVICE
I, William Keslar, being duly sworn according to law, depose and say that
CHURCH OF GOD HOME, INC.,
Petitioner,
V.
ROBERT NORTON,
I served Defendant Robert Norton with the Complaint in the above-captioned
matter, via First-Class, Certified, Restricted, Return Receipt Requested, United
States Mail, at his residence at 1829 Del Norte SW, Albuquerque, New Mexico
87105, on the 19th day of January, 2008. A copy of the Domestic Return Receipt
and Track & Confirm is attached hereto as Exhibit "A."
V v
Dated: 00
William Keslar, Paralegal
Sworn , vnd Subscribed before me
this `iday of
2008.
bv-"?'-' Notary P is
My Co 'ssion Expires:
AL1H OF
CHRIS ;>u <?,uphin .,,l y Public
City of County
ENN:L YA u?
EAL
C(*ME
Notary 22- ? PuW
plin
ecember
C
ORIGINAL
d
EAFFIDAVIT OF SERVICE
i ?
¦ Complete Rom 1, 2, and 3. Also complete
Rem 4 if Restricted Delivery Is desired.
¦ Print your name and address on the reverse
so that we can return the card to you.
¦ Attach this card to the back of the mailpiece,
or on the front If space permits.
1. Article Addressed to:
ROBERT NORTON
1829 DEL NORTE 5W
71
05
ALBUQuERQuE, NM 84
X+9 J nt
? dressee
ed by (Prir;W N ) C. Date of Delivery
ffjj? l
D Is delivery address different from item 1? ? Yes
It YES, enter delivery address bebw: ? No
3. Service Type
)d Certifled Mail ? Ewess Mail
? Registered ? Return Receipt for Merchandise
? Insured Mail ? C.O.D.
4. Restricted Delivery? (Extra Fee) )(Yes
2. Article Number 7U07 071 d??3 61D8 6974
(rMnsfer from service 1
PS Form 3811, February 2004 Domestic Return Receipt IOM5-02-WI540
VJl J ' 11QGA LX l.Vllllllll
I l ltval 11 AGr1111111.JU11•LLJ}JJ.G VIlI/1 1 J1111G11IGl ?Y GV/1111G1 L0.VGlll111 Ull ?'.VV
UNITED 5Tl1TES
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Label/Receipt Number: 7007 0710 0003 6108 6974
Status: Delivered
Your item was delivered at 11:23 AM on January 19, 2008 in
ALBUQUERQUE, NM 87105.
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1 of 1 1 /31 /2008 2:08 PM I
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CHURCH OF GOD HOME, INC.,
Petitioner,
V.
ROBERT NORTON,
Respondent.
No. 08-173
CIVIL ACTION - EQUITY
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter the appearance of the following SCHUTJER BOGAR LLC attorney as
counsel of record in the above-captioned matter:
Maria G. Macus-Bryan
SCHUTJER BOGAR LLC
417 Walnut Street, 4th Floor
Harrisburg, PA 17101
Attorney I.D. No. 90947
(717) 909-8640
Dated. 3
Maria G. Macus-Brya
ORIGINAL
1 a
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Praecipe for Entry of
Appearance was served via first-class, United States mail, postage prepaid, upon the
following:
Robert Norton
1829 Del Norte SW
Albuquerque, NM 87105
Date: 13 0 $
William Keslar, Paralegal
C
4 . C -n
1 ?..
y
David D. Buell
Prothonotary
KirkS. Sohonage, ESQ
Solicitor
knee X Simpson
15` Deputy Prothonotary
Irene E. Morrow
2nd Deputy Prothonotary
office of the 1tothonotary
Cumberland County, Pennsylvania
6e -/73 CIVILTERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 25TH DAY OF OCTOBER, 2011, AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE -THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R.C.P 230.2
BY THE COURT,
DAVID D. BUELL
PROTHONOTARY
One Courthouse Square 9 Suite 100 • Carlisle, M 17013 9 (717) 240-6195 • Ea.X (717) 240-6573