HomeMy WebLinkAbout03-6659SHIPPENSBURG/
SOUTH HAMPTON MANOR, L.P
Plaintiff
V.
CHARLOTTE R. BUTLER and
WILLIAM D. RANSOM, as the
attorney-in-fact for
Charlotte R. Butler,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2003- G 6,5?
CIVIL TERM
CIVIL ACTION-LAW
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this complaint and notice are
served, by entering a written appearance personally or by 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 in the complaint or for any other
claim or relief requested by the plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
12/17/2003 17:37 7172495755 OBS
PAGE 13
VF,RMCATION
The statements in the foregoing Complaint are based upon information which has been
assembled by my attorney in this litigation. The language of the statements is not my own. I
have read the statements; and to the extent that they are based upon information which I have
given to my counsel, they are true and correct to the best of my knowledge, information and
belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §
4904 relating to unsworn falsifications to authorities. DATE: /a / 2 //)3 Jler?
Lamy Cottle, Administrator
I\ HEALTH CARE CENTER
121 walnut Bottom Road
Shippensburg, Pennsylvania
17257-9005
(717) 530-8300
FAX (717) 530-8304
TTY 1-800-654-5984
ADMISSION AGREEMENT
This Agreement is be een Shippensburg Health Care Center (the "Facility" or "we" and)
C` )0C ,( iGV e_ (the "Resident" or "you") and, if you or the court have
designated an individual to act on your ' ehalf, or there is another individual to act on your
behalf, or operation of law, \1 Q 0) ?Cl ?l ("your representative"). A,
checklist of the rights and responsibilities applicable to your representative is listed in Exhibit 1
and is incorroratcd into this Agreement.
Paving for Your Care
If you are applying to this facility as a private-pay resident, you must provide all financial
information requested by us. If we later find that the information you or your representative
provided was incomplete, or inaccurate; we will consider that as a breach of this Agreement
which gives us the right to pursue, all legal remedies against you or your representative.
Who Can Be Rrcyusred to Pav for Your Care
Only you and your insurer can be required to pay for your care No other person, (i.e. a fimiiy
nu`It'cbar, friend, neighbor, legal representative or guardian) can be required to pay horn their
ovvn funds for your care, although he or she may knowingly and voluntarily agree to guarantee
payment for ire cost of your care. We require the person responsible for making payments on
your behalf to pay i;71- your care under the terms of this contract in a timely manner.
If you are a beneficiary of Medicare, Medicaid or any other third-party payment plan, your
representative agrees to make ail necessary payments from your funds. Your representative
could face a civil penalty for intentionally failing to pay required amounts from your funds and
could face a criminal penalty for abusing your funds.
Private Pav Residents
The items and services included in our daily rate is basic room, board and general nursing care as
required by your medical condition. Payment for items and services that are included in the
daily rate and is payable one month in advance and due on the first of each month. Items and
services included in your daily rate are listed in Exhibit 2.A.
You will be charged separately for additional items and services not included in our daily rates
such as special nursing care, special equipment, pharmacy charges, laboratory charges, medical.
transportation and additional services such as telephone expense, dry cleaning beauty and barber
services and newspapers. Items and services for which you will be charged are listed in Exhibit
2.13. Payment for these additional items and services are due after you have requested them, and,
you have received and have been billed for them. Within 30 days of receiving an item or service,
EXHIBIT "A"
you have the right to ask us for an itemized financial statement that briefly but clearly describes
each item and the amount charged for it. You will be given an updated listing of services and
related charges, including any charges for services not covered under Medicare or by the
facilities basic per diem charges, annually on or about January I of each year.
Medicare Residents
We participate in the Medicare Program. Medicare may pay for some or all of your nursing
home care. For information on Medicare, see Exhibit 3. If you are eligible for Medicare, you
have the right to have claims for your nursing home care submitted to Medicare.
Medicaid Residents
We participate in the Medicaid program. For information on Medicaid, see Exhibit 3. You are
not required to give up any of your rights to Medicaid benefits to be admitted or to stay here. If
your private fimds are used up during your stay here and you are eligible for Medicaid; we will
accept Medicaid payments although Medicaid may require you to pay some amount in addition
to what Medicaid pays for your care. If you are planning on applying to Medical Assistance
later, you may want to find out now if your are "medically eligible" for nursing home payment
by Medicaid.
You are responsible for applying for and obtaining Medicaid benefits and we will assist you. We
may not charge, ask for, accept or receive any gift, money, donation or consideration other than
Medicaid reimbursement as a condition of your admission or continued stay here except that
Medicaid may require you to pay certain amounts from your private funds.
If you receive Medicaid, most of your nursing home charges such as room, board, and general
nursing care are covered. For a list of services covered by Medicaid, see Exhibit 4.A. The local
Board of Assistance will tell you whether you have to pay part of the charge for your care and, if
so, how much. Some of the items and services that we offer are not covered by Medicaid. If you
want any items or services, which are not covered by Medicaid, you or your representative will
have to pay for them. A list of the items and services not covered by Medicaid and the charges
for them are in Exhibit 4.13. Payment for items and services that are not covered by Medicaid is
due after you have requested them, and; have received and have been billed for them. Within 30
days of receiving the item or service, you have the right to ask us for an itemized statement that
briefly but clearly describes each item and the amount charged for it.
Increases in Char¢es and Fees
Anv time we increase a fee or charge for item or service or add a new item or service, we will
provide you and your representative with 30 days advance written notice.
Penalties
We may not charge you interest if you pay your bill in time. Your payment is on time if it is
made Nvithin 45 days of the date the bill is post marked, or 30 days after the end of the billing
period. whichever is later. The penalty we charge is 51/'0 of the amount due, calculated on a per
day basis.
If you or your representative do not pay the money you owe us and we hire a collection agency
or attorney, you agree to be liable for their fees and court costs.
Private Dutv Nurses Geriatric Aides
If you want a private duty nurse or a private duty geriatric aide, you are responsible for selecting
a person licensed and/or certified according to Pennsylvania laws and regulations. You are also
responsible for paying him or her and for letting us know that you have hired one. The person
you hire is not an employee or agent of the facility, but he or she must meet our standards and
follow our policies and procedures. Employees of the Facility may not serve as private duty
nurses or private duty geriatric aides.
Holding Your Bed if You Leave the Facility
If you are hospitalized or on leave from the Facility, we will hold your bed for you as follows:
A. If you are private-pay resident, or are receivin.- inpatient care reimbursed under Medicare
Program (and you are not covered under Medicaid), unless you notify us otherwise, we
will hold your bed for as long as you pay for it at the daily rate you are currently being
charged.
B. If Medicaid pays for part or all of your nursing home care and you need to be
hospitalized, we will hold your bed for up to the maximum number of days required by
this state, currently 15 days. If you leave for any other reason, we will hold your bed for
up to the maximum number of days required by this state, currently 13 days. You have a
right to be readmitted to the facility to the first available appropriate bed. While we are
holding your bed, you are still required to pay the Facility any amount for which you are
liable as determined by the Medicaid Program.
C. If you have applied for Medicaid, your bed will be reserved in accordance with Paragraph
B. However, if you are found to be ineligible for Medicaid, then you are required to pay
for the bed as a private pay resident as described in Paragraph A.
D. Other third-party payers may or may not have a bed hold policy. We will discuss this if it
applies to you.
Your Right to Blake Complaints and Suggest Chances in Policies and Services
As a nursing home resident, you have many rights according to State and Federal law. These are
described in detail in Exhibit 6, which is attached and is part of this Contract.
You may make complaints about your care in the Facility and you may also suggest changes in
the policies and services of the Facility. You will not be harassed or discriminated against for
making a complaint or suggesting a change in a policy or service. You may present your
complaints to facility, management company or to one of the following State agencies:
Larry D. Cottle, LNHA
Administrator
Shippensburg Health Care Center
121 Walnut Bottom Road
Shippensburg, PA 17257
717-530-8300
Ombudsman
Office of Aging
16 West High Street
Carlisle, PA 17013
717-240-6110
717-532-7286 Ext. 6110
Peter E. Perini, Sr.
President
Magnolia Management, Inc.
1710 Underpass Way
Hagerstown, MD 21740
301-745-8700
Department of Health
100 North Cameron Street
"' Floor
Harrisburg, PA 17101
717-783-3790
Your Right to Make Decisions
You have the right to make your own medical decisions and to manage your personal affairs. If
you become disabled, it may be necessary for someone else to make decisions for you. For this
reason, we recommend that you have a living will and/or advance directive for medical decisions
and a financial Power of Attorney but you are not required to do so. See Exhibit 7 for a
description of your legal rights to decide about your future medical treatment.
Transfer. Relocation and Discharge
You have the right to remain here, and you may not be transferred, relocated or discharged
against your will, except for the following reasons: (1) A medical reason (i.e. the facility cannot
provide the kind of care that you need, your condition has improved so that you no longer need
the care we provide, or a medical emergency arises; (2) Your welfare or the welfare of other
residents or staff; (3) Nonpayment for a stay, or (4) the Facility ceases to operate.
If we decide that you should be transferred or discharged, we will notify you, and an immediate
family member or legal representative, by letter 30 days in advance. If you are transferred
because of an emergency situation, we will provide the required notice as soon as practicable.
The letter will contain the reasons for the transfer or discharge and its effective date. The letter
will also tell you how you can appeal our decision to transfer or discharge you.
If you are discharged involuntarily, we will attempt to make other appropriate arrangements for
your care. However, if other arrangements are not available, your representative agrees to accept
you into his or her custody if it is medically appropriate.
Your Right to End This Contract
If you decide to end this Contract and leave the Facility, you must pay your bill before you leave.
You must give us five (5) days written notice to terminate this contract. If you leave before the
end of that time, you must still pay for each day of the required notice.
In the event you die while a resident of the facility, your representative is responsible for making
the funeral arrangements. We will notify your representative immediately. If we. are unable to
reach your representative, we will contact the funeral home of your choice to facilitate
arrangements.
Additional Documents
It is not possible to cover everything that is important to your stay in our Facility in the body of
this Contract. Therefore, we have included additional important documents as Exhibits. These
Exhibits are part of this Contract. Please verify that you received the Exhibits and that the
contents of the Exhibits were explained to you by placing your initials on the line next to the
description of each Exhibit.
x/
n /Exhibit 1. Rights and Obligations of Representatives.
?rl
??_ Exhibit 2. For Private Pay Residents:
(a) Items and services covered by daily rate.
(b) Items and services not covered by daily rate.
f Exhibit 3. How to Apply For and Use Medicare and Medicaid Benefits.
Exhibit 4. (a) Items and Services Covered by Medicaid.
(c) Items and Services Not Covered by Medicaid.
Exhibit 5. Physicians Who Practice at the Facility.
Exhibit 6. Legal Rights of Pennsylvania to Decide Future Medical Treatment.
( Exhibit 7. Policies and Procedures Concerning Your Personal Funds and Your
Personal Property.
ZExhibit 8. Services Provided by Outside Health Care Providers.
Changes in Law
Any provision of this Contract that is found to be invalid or unenforceable as a result of a change
in State or Federal law will not invalidate the remaining provisions of this Contract. If there are
services we have agreed to provide that are later found to be impossible to render as a result of a
change in State or Federal law, it is agreed that to the extent possible, the Resident and the
Facility will continue to fulfill our respective obligations under this Contract consistent with the
law.
IN WITNESS WHEREOF, the parties have executed this Contract on this Cot" , day of
ku uSk c?L?3 .
Witness
Witness
Resident
If the Resident has been adjudicated disabled or the Resident's doctor determines that the
Resident is incapable of understanding or exercising his or her rights and responsibilities, the
Facility may require the signature of another person on this contract. The other person may be:
(1) An appointed healthcare agent under an advance directive for medical care, (2) A guardian or
Witness
A
Larry D. Cottle, Administrator
Shippensburg Health Care Center
By: Power of Attorney of the person; (3) A surrogate or family member.
e'.E-? ?7G.Ic r
Responsible Party (Name)
a
Title: Indicate whether you are (1), (2) or (3)
Y 4Yv $ YTV t Y(? 3 t y V 4 3 T
,:?T?e Fo;t Cham?eis Bwldm?ssni?"' `.?- ' ?a`?l, t.-. `?`° 'r`te'` • .' , j a a ? ,
• ?? v ? ?,r f,.Kxr' {+'i; ? ? i. ? x 1 . + art :w BY APPoxntment Only.
`` ChatnL-eisbu?g; PA 17201 - " ? - _ 237 st ain'Srreec
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• x.717-267-2288 ' -_' ? _ Wayy"nes or 2 11317268
_____ Fax 11 1-267.1151 717.76 -
DURABLE POWER OF ATTORNEY
OF
CHARLOTTE R. BUTLER
Reichard Law Offices, LLC
70 West Kina Street
Chambersburg, PA 17201
717/267-2288
237 East Main Street
Waynesboro, PA 17268
717/762-1131
EXHIBIT "B"
DURABLE POWER OF ATTORNEY
BY CHARLOTTE R. BUTLER
NOTICE
THE PURPOSE OF THIS DURABLE POWER OF ATTORNEY IS TO GIVE
THE PERSON YOU DESIGNATE (YOUR "AGENT') BROAD POWERS TO
HANDLE YOUR PROPERTY, WHICH MAY INCLUDE POWERS TO SELL OR
OTHERWISE DISPOSE OF ANY REAL OR PERSONAL PROPERTY WITHOUT
ADVANCE NOTICE TO YOU OR APPROVAL BY YOU.
THIS DURABLE POWER OF ATTORNEY DOES NOT IMPOSE A DUTY ON
YOUR AGENT TO EXERCISE GRANTED POWERS, BUT WHEN POWERS ARE
EXERCISED, YOUR AGENT MUST USE DUE CARE TO ACT FOR YOUR
BENEFIT AND IN ACCORDANCE WITH THIS DURABLE POWER OF
ATTORNEY.
YOUR AGENT MAY EXERCISE THE POWER GIVEN HERE
THROUGHOUT YOUR LIFETIME, EVEN AFTER YOU BECOME
INCAPACITATED, UNLESS YOU EXPRESSLY LIMIT THE DURATION OF
THOSE POWERS OR YOU REVOKE THESE POWERS OR A COURT ACTING ON
YOUR BEHALF TERMINATES YOUR AGENT'S AUTHORITY.
YOUR AGENT MUST KEEP YOUR FUNDS SEPARATE FROM YOUR
AGENT'S FUNDS.
A COURT CAN TAKE AWAY THE POWERS OF YOUR AGENT IF IT
FINDS YOUR AGENT IS NOT ACTING PROPERLY.
THE POWERS AND DUTIES OF AN AGENT UNDER A DURABLE POWER
OF ATTORNEY ARE EXPLAINED MORE FULLY IN 20 Pa. C.S. Ch. 56 (20 Pa. C.S.
§5601 et seq.).
IF THERE IS ANYTHING ABOUT THIS FORM THAT YOU DO NOT
UNDERSTAND, YOU SHOULD ASK A LAWYER OF YOUR OWN CHOOSING TO
EXPLAIN IT TO YOU.
I HAVE READ OR HAD EXPLAINED TO ME THIS DURABLE POWER OF
ATTORNEY AND THIS NOTICE AND I UNDERSTAND ITS CONTENTS.
Date ? ' ? ? ? 7,f??., , ? /.,7 . ?it•?•?
Charlotte R -*tler
KNOW ALL MEN BY THESE PRESENTS, that I, CHARLOTTE R. BUTLER,
Social Security Number 207-20-8244, of Greene Township, Franklin County,
Pennsylvania, make, constitute and appoint my brother, WILLIAM D. RANSOM, of
1986 Philadelphia Avenue, Chambersburg, PA, Franklin County, Pennsylvania, my true
and lawful agent, for me and on my behalf, in my name and/or my agent's name, to take
all actions and to perform all acts concerning my affairs as my agent may deem necessary
or advisable, in my agent's absolute discretion, as fully as I could if personally present,
including, without limiting the generality of the foregoing:
To make unlimited gifts to my issue and to engage in Medicaid gift
planning. A power to make unlimited gifts shall mean that the agent may
make gifts for an on behalf of the principal to any such donees (including
my agent) and in such amounts as my agent may decide.
2. To create revocable and/or irrevocable trust(s) for my benefit and/or for
the benefit of all possible unlimited gift beneficiaries as set forth in
paragraph I above. To make additions to an existing trust for my benefit
or for the benefit of a beneficiary or beneficiaries as set forth in paragraph
1 above. I specifically authorize that the unlimited gift beneficiaries set
forth in paragraph 1 above may be designated income and/or remainder
beneficiaries of ay trust(s). My agent may terminate Revocable Trusts
over which I have a power of revocation.
3. To employ accountants, attorneys-at-law, investment counsel, custodians,
agents, servants, and others, and to delegate to them, to remove the, and to
pay them such remuneration as my agent sliall decor proper.
4. To disclaim any interest in property. To renounce fiduciary positions.
5. To withdraw and receive the income or corpus of a trust
6. To authorize my admission to a medical, nursing, residential or similar
facility and to enter into agreements for my care.
Charlotte R. Butler
To authorize medical and surgical procedures, and/or to withhold and/or
withdraw medical treatment as is consistent with my health care directive
(Living Will), if any, then in existence; or if not in existence, as my agent,
based upon prior discussions with me, shall utilize substituted judgment,
and may direct on my behalf.
8. To engage in real property transactions. My agent shall also have the
power to change my domicile.
9. To engage in tangible personal property transactions.
10. To engage in all stock, bond and other securities transactions, including
United States Treasury and United States Government Agency Securities,
and to purchase, sell and disburse bond, stocks, securities and mutual
funds held in my own name or in a broker's street namc.
11. To engage in commodity and option transactions.
12. To engage in banking and financial transactions.
13. To borrow money.
14. To enter safe deposit boxes, including authority to drill the box if keys are
misplaced.
15. To engage in insurance transactions.
16. To engage in retirement plan transactions.
17. To handle interests in estates and trusts.
18. To pursue claims and litigation.
19. To receive government benefits.
20. To pursue tax matters in, but not limited to, years 1995 through 2060,
including, but not limited to, Federal forms 1040, 709, and 2848.
21. To cash and demand payment of government securities, government
bonds, including but not limited to Series E, Series EE, Series H Bonds,
treasury notes, treasury bonds, and all state and local municipal bonds.
Charlotte R. Butler
4
22. LIFE INSURANCE POWERS. My agent is authorized to apply for and
own, cash in, surrender, borrow against, purchase, maintain, collect,
cancel, and/or change the ownership of any insurance policy insuring my
life and/or to designate and change the beneficiaryof any such insurance
policy and/or to exercise any incident of ownership over such policies; my
agent is also expressly authorized to assign or transfer ownership of any
insurance policy(ies) to himself/herself or others and/or to designate
himself/herself or others as beneficiary thereof; no such action shall be
considered self-dealing or in violation of fiduciary duty. The above
powers shall be consistent with gifting authority, if any, as set forth in
Paragraph 1 of this Durable Power of Attorney.
These powers, where applicable, are as defined in Chapter 56 of the Pennsylvania
Probate, Estates and Fiduciaries Code, as amended (20 Pa. C.S.A. §5601, et seq.).
I recognize that the agent I have named may be in a conflict of interest position either
because of a business, professional, or other relationship my agent has with me. I waive
any right I may have to object to my agent acting, notwithstanding the conflict, because I
believe my agent will act in accordance with my-desires. I recognize that the lawyer who
represented me with regard to the execution of this Power of Attorney and possible other
matters may be requested to represent my agent as Fiduciary in acting pursuant to this
Power of Attorney. I acknowledge that the said lawyer, being familiar with me and my
circumstances, may be an appropriate professional to represent my agent in following the
directions set forth in this document. In light of this possibility, I hereby authorize my
agent to retain the services of the lawyer who represented me in the execution of this
Power of Attorney and I waive any conflicts of interest that may exist for the lawyer in
regard to the said representation of my agent. In addition, I authorize the lawyer to reveal
such confidential information as may be appropriate to assist my agent in the
performance of my agent's duties under this document.
Charlotte R. Butler
In the event any third party fails to honor a request, instruction or direction
by my agent, I authorize my agent to proceed against said third party (e.g. bank, stock
broker, etc.) for incidental and consequential damages as authorized by 20 Pa. C.S.A.
§5608. My agent is further authorized to proceed to obtain incidental and consequential
damages, including court costs and attorneys fees, for any delay caused by said third -
party(s) refusal to honor this Power of Attorney.
And to make and transact any and every kind of business of every nature; hereby
ratifying and confirming all that my said agent shall lawfully do or cause to be done by
virtue of these presents.
This Durable Power of Attorney shall continue in force and may be accepted and
relied upon by anyone or any entity to whom it is presented despite my purported
revocation of it or my death. Until revoked by a recorded revocation of same in the
county in which the location of any transaction shall occur or until actual written notice
of revocation is received by such person or entity. This Durable Power of Attorney
shall not be affected by disability of the principal.
This Durable Power of Attorney has or may be executed in multiple duplicate
originals this date.
IN WITNESS WHEREOF, I have hereunto set my hand and seal on
2003.
Charlotte R. Butler
ACKNOWLEDGMENT BY AGENT
I, the undersigned, have read the attached (above) Durable Power of Attorney and
am the person identified as the agent for the principal. I hereby acknowledge that in the
absence of a specific provision to the contrary in the Durable Power of Attorney or in 20
Pa. C.S. when I act as agent:
I shall exercise the powers for the benefit of the principal and/or shall exercise the
powers consistent with the express authority granted in the Durable Power of
Attorney.
I shall keep the assets of the principal separate from my assets.
I small exercise reasonable caution and prudence.
I shall keep a full and accurate record of all actions, receipts and disbursements on
behalf of the principal.
Date
ti illiam D. Ranso ttorney-In-
Fact, Agent
WITNESS:
B m?? O . ?`C`
?L3als Cu ml?r t (?+?ctt N 1 ?, I,to Ry
Address
4E-wLrt?
Name
hA 1`2.40
Add're's?/?
COMMONIVEALTH OF PENNSYLVANIA:
SS
COUNTY OF FRANKLIN
On this, the S'kt' day of A vn 41 Qcc1, before me, the undersigned
officer, personally appeared Charlotte R. Butler, known to me (or satisfactorily proven)
to be the person whose name is subscribed to the within instrument, and acknowledged
that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Notary Public
Notarial Seal
Barbara Y. Leedy. Notary Public
7 My hantersbu on ExpireFranklin 22 2004
r Mew MvyWA Assodalm of 1101 a
NOV 25 '03 11:02AM P.2
STATEMENT
r
SHIPPENSBURG HEALTH CARE CTR
121 WALNUT BOTTOM RD
SHIPPENSBURG, PA 17257
Facility Phone: 717.530-8300
Resident: CHARLOTTE BUTLER
Statement Date: 11/25103
r
WILLIAM RANSOM
1986 PHILADELPHIA AVENUE
CHAMBERSBURG, PA 17201
Date Service Through Qty Description
Charcia
08/31/03 08/26/03 08/31/03 6 Co-Insurance
09/03/03 09/01/03 09/03103 3 Co-Insurance
11/01/03 09/04/03 09/30/03 39 Room Charges
Sub Total
Balance
Cash Receiots/Adiustments
11/01/03 09/19/03 09/30/03 12 ADJ. Room Charges
Sub Total
Balance
Total Amount Due
EXHIBIT "C"
Amount
630.00
315.00
6,396.00
7,341.00
7,341.00
-1,968.00
-1,968.00
5,373.00
5,373.00
Page 1
`
C1
11 l_J
IQ r,
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i
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2003-06659 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SHIPPENSBURG/SOUTH HAMPTON MAN
VS
BUTLER CHARLOTTE R ET AL
R. Thomas Kline
duly sworn according to law, says, that he
and inquiry for the within named DEFENDANT
RAMSON WILLIAM D AS ATTORNEY IN FACT FOR
but was unable to locate Him in his ba
deputized the sheriff of FRANKLIN
serve the within COMPLAINT & NOTICE
, Sheriff or Deputy Sheriff who being
made a diligent search and
to wit:
CHARLOTTE D BUTLER
iliwick. He therefore
County, Pennsylvania, to
On February 6th , 2004 , this office was in receipt of the
attached return from FRANKLIN
Sheriff's Costs: So answers:
Docketing 18.00
Out of County 9.00
Surcharge 10.00 R. Thomas Kline.
Dep Franklin Cc 28.00 Sheriff of Cumberland County
.00
65.00
02/06/2004
OBRIEN BARIC SCHERER
Sworn and subscribed to before me
this /;tom day of
cy
02o-oY A. D.
/?
- IprothonotJ a
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2003-06659 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SHIPPENSBURG/SOUTH HAMPTON MAN
VS
BUTLER CHARLOTTE R ET AL
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
RANSOM WILLIAM D
but was unable to locate Him
in his bailiwick
deputized the sheriff of FRANKLIN
serve the within COMPLAINT & NOTICE
to wit:
He therefore
County, Pennsylvania, to
On February 6th , 2004 , this office was in receipt of the
attached return from FRANKLIN
Sheriff's Costs: So answers:
Docketing 6.00 i -?
Out of County .00 Surcharge 10.00 R/ Thomas Kline
.00 Sheriff of Cumberland County
.00
16.00
02/06/2004
OBRIEN BARIC SCHERER
Sworn and subscribed to before me
this /d 61 day oft
fan y A.D.
qll-r'Prothono
In The Court of Common Pleas of Cumberland County, Pennsylvania
Shippensburg/South Hampton Manor LP
vs.
Charlotte R. Butler et al
SERVE: William D. Ranson attorney in No 03-6659 civil
fact for Charlotte R. Butler
Now, January 7, 2004 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Franklin County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
?Sheriff of Cumberland County, PA
Affidavit of Service
Now,
within
120 , at o'clock M. served the
upon
at
by handing to
a
and made known to
copy of the original
the contents thereof.
So answers,
Sheriff of County, PA
Sworn and subscribed before
me this _ day of 20
COSTS
SERVICE $
MILEAGE
AFFIDAVIT
SHERIFF'S RETURN - NOT SERVED
CASE NO: 2004-00002 T
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF FRANKLIN
SHIPPENSBURG/SOUTH HAMPTON MAN
VS
CHARLOTTE R BUTLER ET AL
ROBERT WOLLYUNG
C?rttk^r?k+n:k <'???+y
, Sheriff , who being duly sworn
according to law, says, that he made a diligent search and inquiry for
the within named DEFENDANT to wit:
RANSOM WILLIAM D but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT
NOT SERVED , as to
the within named DEFENDANT
1986 PHILADELPHIA AVENUE
CHAMBERSBURG, PA 17201
DEFENDANT IS DECEASED
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
RANSOM WILLIAM D
So answers:
00
00
00 ERT WOLLYlit riff
00
00
00 CUMBERLAND COUNTY SHERIFF
01/22/2004
Sworn and subscribed to before me
thi day of
ocOfJ D. 11
Notary
NVoi,rd....!?i.S?all
Richud D. MoCMy. Nosry Pudic
Chambe bwS Soso, Fmkpn 0wo
MY Commission $rpka he. V.W
In The Court of Common Pleas of Cumberland County, Pennsylvanian
Shippensburg/South Hampton Manor LP b - d a r ?'
vs.
Charlotte R. Butler et al
SERVE: William D. Ranson No 03-6659 civil
No.
Now, January 2, 2004 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Franklin County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
Affidavit of Service
Now,
within
upon
at
by handing to
a
and made known to
120 , at o'clock M. served the
copy of the original
the contents thereof.
So answers,
Sheriff of County, PA
Sworn and subscribed before
me this day of 20,
COSTS
SERVICE $
MILEAGE
AFFIDAVIT
SHERIFF'S RETURN - NOT SERVED
CASE NO: 2004-00002 T
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF FRANKLIN
SHIPPENSBURG/SOUTH HAMPTON MAN
VS
CHARLOTTE R BUTLER ET AL
ROBERT WOLLYUNG
cuMpUCWO,k eovw? 1
,l? 03 v ? `I
, Sheriff , who being duly sworn
according to law, says, that he made a diligent search and inquiry for
the within named DEFENDANT , to wit:
RANSOM WILLIAM D but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT
NOT SERVED , as to
the within named DEFENDANT
1986 PHILADELPHIA AVENUE
CHAMBERSBURG, PA 17201
DEFENDANT IS DECEASED
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
RANSOM WILLIAM D
So answers: ?j Fr
00
00 ;7
00 BERT WOLLYUNG, iff
0 0 00
00 CUMBERLAND COUNTY SHERIFF
01/22/2004
Sworn and subscribed to before me
this day of / l"elf,?t
??
Notary t?
Notarial Seal
Richard D. McCarty, Notary Public
Chambersburg Born. Franklin County
My Commission EVirea An. 29.2107
Curtis R. Long
Prothonotary
office of the Vrotbonotarp
Cumberlanb Countp
.'
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
02- 10&159 CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 5TH DAY OF NOVEMBER 2007 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,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573