HomeMy WebLinkAbout08-4816R a
LAW OFFICES OF ANDREW SKLAR, P.C.
By: Steven M. Zelinger
I.D. No. 206272
411 E. Route 70, Suite 200
Cherry Hill, New Jersey 08034
File No.: 15593.08
IN THE COURT OF COMMON PLEAS OF MONROE COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
MIDATLANTIC MEDEVAC LLC
Plaintiff
i
vs.
:No. 08 - 4 19((0
TERM
awl i (tiem
AMY STIGERS
Defendant
p.
CIVIL ACTION
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this complaint and notice are
served, by entering a written appearance personally or by attorney and filing in writing with the
court your defenses or objections to the claims set forth against you. You are warned that if you
fail to do so the case may proceed without you and a judgment may be entered against you by the
Court without further notice for any money claimed in the Complaint or for any other claim or
relief requested by the Plaintiff. You may lose money or property or other rights important to
you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
Telephone: 717-249-3166
J
AVISO
Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas
en las paginas siguientas, usted tiene veinte (2) dias de plazo al partir de la fecha de la demanda y
la notificaion. Hace falta asentar una comparencia escrita o en persona o con un abogado y
entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su
persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la
demanda en contra sya sin previo aviso o notificaion. Ademas, la corte puede decidir a favor del
demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede
perder dinero o sus propiedades u otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL A LA OFICINA
CUY A DIRECIQN SE ENCUENTRA ESCRITA ABAJO PARA AVERGUAR DONDE SE
PUEDE CONSE9?UIR ASISTENCIA LEGAL.
li
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
Telephone: 717-249-3166
t
Steven M. Zelinger, Esquire (ID#206272)
Law Offices of Andrew Sklar, P.C.
411 Route 70 East - Suite 200
Cherry Hill, NJ 08034
856-616-8710
Attorneys for Plaintiff
FILE NO.: 15593.08
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
MIDATLANTIC MEDEVAC LLC
HAHNEMANN,UNIVERSITY
HOSPITAL
BROAD & VINE STS.- MAIL STOP 300
PHILADELPHIA, PA 19102
Plaintiff,
VS.
AMY STIGERS
604 THIRD STREET
ENOLA, PA 17025
Defendant.
No.
TERM
CIVIL ACTION
VERIFIED COMPLAINT
Quantum Meruit
Unjust Enrichment
Plaintiff, b`y way of its complaint against Defendant in this matter, alleges and states as
follows:
PARTIES. JURISDICTION & VENUE
1. Plaintiff herein is Midatlantic Medevac LLC, a Pennsylvania limited liability
company, with its primary offices located at the address in the above caption.
2. Defendant herein is Amy Stigers, mother and responsible party for the minor
child patient Cars6n Stigers, an individual who, upon information and belief, currently resides at
the address in the above caption.
3. Jurisdiction and venue are therefore proper in this action.
FACTS
4. On or about February 10, 2007, Plaintiff provided medical services to Defendant
(the "Services") totaling $19,136.50 as set forth by Plaintiff in its financial statement (the
Statement'); there is currently a remaining balance of $19,036.50 (the "Subject Indebtedness")
due and owing.
A true and correct copy of the Statement generated by Plaintiff for the Services
provided to Defendant is attached hereto and marked as Exhibit "A".
6. The supply of services by Plaintiff to Defendant, memorializes the "bargain"
from which Plaintiff expected and was entitled to benefit.
7. Plaintiff is aware that the insurance provider Blue Cross Blue Shield provided
payment for the claim herein in the amount of $19,086.50 which was cashed by Plaintiff for her
own use and benefit. See Plaintiff's internal collection notes attached as Exhibit "B".
FIRST COUNT
Quantum Meruit
8. Defendant, by failing to pay Plaintiff the Subject Indebtedness as required by the
oral contract, deprived Plaintiff of the benefit of the bargain and caused Defendant to be unjustly
II
enriched, which Subject Indebtedness remains unpaid.
9. Although repeated demands have been made upon Defendant for payment of the
Subject Indebtedness, Defendant has continually failed and refused to pay same to date, leaving
the total amount of the Subject Indebtedness due and owing.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of
$19,036.50 plus accrued interest, costs and all other relief to the full extent permitted by law.
SECOND COUNT
Unjust Enrichment
10. Plaintiff adopts and restates each and all of the averments set forth in paragraphs
1 through 9 hereinabove as though same were fully set forth at length.
11. Defendant, although having agreed, orally and by receipt of services to pay for
the medical services which Plaintiff provided to Defendant, Defendant has deprived Plaintiff of
the fair and reasonable value of the Services and/or as they were billed by Plaintiff.
12. Plaintiff is entitled to be paid for the Services, having provided same to
Defendant and relying upon the promise of Defendant to pay.
13. Although demand has been made by Plaintiff upon Defendant for payment for the
Services, Defendant has failed and continues to refuse to pay same through current date.
14. Although Defendant actually received insurance reimbursement for the services
provided, she converted said funds for her own use by cashing the insurance check, denying
Plaintiff of the reasonable value of services.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of
$19,036.50 plus at crued interest, costs and all other relief to the full extent permitted by law.
LAW OFFICES OF ANDREW SKLAR, P.C.
By: zi? M Y
Steven M. Zelinger, Esquire
Attorneys for Plaintiff
PA ID # 206272
411 Route 70 East - Suite 200
Cherry Hill, NJ 08034
(856) 661-8710 x 303
Dated: , 2008
VERIFICATION
I, I- gyW5 ///lo W& j1 , hereby depose and say that I am employed by Plaintiff
as At?evqT e5C , that I am authorized to make this
verification on behalf of Plaintiff, that I have reviewed the files of Plaintiff pertaining to the
subject matter hereof, that I have personal knowledge of the facts and circumstances relating
thereto, that I have reviewed the foregoing pleading, that the facts set forth therein are true and
correct to the best of my knowledge and belief. I understand that false statements made herein
are subject to the penalties of 18 PA. C.S, Subsection 4904, relating to unsworn falsifications to
authorities.
Date: V
File No.: 15593.08
o MOT-99731
Jul 3 1 2008
EXHIBIT A
1000061853552M02/10/20 07 Stigers, Carson .
52 Winchester Gardens
Carlisle PA
419601/22/2007Male 17103- - (717) 440-
PA 17013 ChildrensHos Carlisle Reg Med
34&CivicCenter, Philadelphia PA 1 246 Parker St
9104Sti
ers Carlisle
A
52 Winchester Gardens g
, my
Carlisle PA 17103- (717) 440-4196
2077089 OTHER RESPIRATORY PROBLEMS AFTER BIRTH
20486 PNEUMONIA, ORGANISM NOS
20V4611 DEPENDENCE ON RESPIRATOR, STATUS
30NEWBABASE RATE 1 $9708
0 0
30NEWMIMILES .
4003/01/2007 1C First Bill Commercial Ele$0,00 109 $9428.5
$0
00 0
$0
00
$19136.50 . .
4003/06/2007 SG Matching Patient Bill $0.00 $0.00 $0
00
$0.00 $19136.50 , .
' 4003/07/2'007
SG
Matching Patient Bill
$0.00
$0.00
$0
00
$
$0.00 $1913 6.50 .
4004/12/2007 JC
0 COMMERCIAL BILL REJECTED $0.00 $0.00 $0
00
$
.00 $19136.50 .
4004/12/2007 OC
$
19 OFFSET Commercial Electro$0.00 $0.00 $0
00
-
136.50$0.00 .
4004/12/2007 1C
$19136.50 $19136.50 First Bill Commercial Ele$0.00 $0.00 $0.00
4004/16/2007 JC
$0 COMMERCIAL BILL REJECT ED $0.00 $0.00 $0.00
.00 $19136.50
4004/16/2007 OC
$
19 OFFSET Commercial Elec tro$0.00 $0.00 $0.00
-
136.50$0.00
4004/16/2007 1C
$19136.50 $19136.50 First Bill Commercial $0.00 $0.00 $0.00
4010/09/2007 JC
$0 COMMERCIAL BILL REJECTED $0.00 $0.00 $0
00
.00 $19136.50 .
4010/09/2007 OC
$-191 OFFSET Commercial $0.00 $0.00 $0.00
36.50$0.00
4010/09/2007 1P First Bill Patient $0.00 $0.00 $0
00
$19136.50 $1913.6.50 .
4012/05/2007 JP
$0 PATIENT BILL REJECTED $0.00 $0.00 $0
00
.00 $19136.50 .
4012/05/2007 OP
$-19 OFFSET Patient $0.00 $0.00 $0.00
136.50$0.00
4012/05/2007 1P
$19136.50 $19136.50 First Bill Patient $0.00 $0.00 $0.00
4001/03/2008 SG
$0 Reprinted Bill $0.00 $0.00 $0
00
.00 $19136.50 .
4001/30/2008 WE WRITE OFF TO BAD DEBT $0.00 $0.00 $-
19136.50$0.00 $0.00
EXHIBIT B
New trip # 00061853552M
2/16/7
pt has ins as PBSHM 378 PPO POB 890173 Camp Hill PA 17089 ph# 866-803-3708 pl#
SVR110032323001 grp# 02882002-AJ
2/16/7
called BCBS 378 PPO @ 866-588-6966 spk w Kelly
p1 # SVR110032323001
grp# 02882002
ph Amy Stigers
of f 1/22/07
co pay 50.00
covers 100%
1500.00 ded
mi al to POB 890016 Camp Hill PA 17089 Aj
2/16/7
called pt @ 717 440 4196 spk w grandmother ver all demos to be correct w index
and she sd that she dont the know the ins took down name and # -AJ
Thu Apr 12, 2007 12:40:46: working corr batch 3/28/07 - received rejected claims
report - claim was sent to the wrong address - sending to correct address/bs
Fri Apr 13, 2007 07:49:32: Working zirmed rejections- claim was rejected in
zirmed b/c of invalid provider #- corrected and resubmitted in zirmed-RC
Mon Apr 16, 2007 08:36:25: Working zirmed rejections- claim was rejected in
zirmed b/c of invalid provider #- dropped to paper and hid in zirmed-RC
Mon Jun 25, 2007 15:14:50: caking rpt-bcbs/sylvia sd pd member 19086.50 on 5-24-
07 ck # 0062966570 ck was cashed 5-30-07-pt call no answer lvm to rtn call-
sending pt bill with contact our office-moving to self pay folder in if-bl
Tue Oct 09, 2007 14:55:06: wking commercial rpt=per above narrative bcbs pd pmt
to member-ck has been cashed-pt/call na lmom-putting into pt status and moving
to self pay folder in if-bl*** CAR *** Wed Dec 05, 2007 10:04:45: Called
residence and lmom. Sending 2nd statement-CAR
*** CAR *** Thu Jan 03, 2008 11:57:53: Called and left message, sending final
statement-CAR
Fri Jan 25, 2008 15:41:15: working pt report. called pt-lmom. placing on bad
debt spreadsheet-RR
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-04816 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MIDATLANTIC MEDEVAC LLC
VS
STIGERS AMY
MARK CONKLIN , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
CT T("=DC 7T MV the
DEFENDANT , at 1717:00 HOURS, on the 4th day of September, 2008
at 604 THIRD STREET
ENOLA, PA 17025
by handing to
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 15.00
Affidavit .00
Surcharge 10.00
9flz?os C .00
43.00
Sworn and Subscibed to
before me this day
So Answers:
R. Thomas Kline
09/05/2008
ANDREW SKLAR
By:
epu Sheriff
of A. D.
LAW OFFICES OF ANDREW SKLAR, P.C.
BY: Steven M. Zelinger
IDENTIFICATION NUMBER 206272
401 ROUTE 70 EAST, SUITE 200
CHERRY HILL, NJ 08034
(856) 616-8710
Attorney for Plaintiff
File No.: 15593.08
MIDATLANTIC' MEDEVAC LLC
Plaintiff
MUNICIPAL COURT
CUMBERLAND-PA COUNTY
VS.
AMY STIGERS
Defendant
No. 08-4816
: JUDGMENT BY AGREEMENT
This matter, having been amicably adjusted by and between the Plaintiff, MIDATLANTIC
MEDEVAC LLC, and the defendant(s) AMY STIGERS, and the parties wishing to settle all
disputes by and Between them, it is hereby agreed that:
1. The undersigned Defendant(s) agree that a JUDGMENT BE ENTERED against them in the
above matter in the amount of $19,115.00, inclusive of costs.
2. Defendant(s), AMY SMERS, shall pay to plaintiff the total sum of $19,115.00 as follows:
An initial payment of $100.00 due on or before September 12, 2008, and then bi-weekly
payments of at least $100.00 each, starting September 26, 2008. Payments shall be sent to Law
Offices of Andrew Sklar, P.C., 411Route 70 East, Suite 200, Cherry Hill, NJ 08034.
3. In the eve Defendant(s) default on repayment terms as stated above, Plaintiff will be
gent' d to ' nt in the full amount of $19,115.00, less credit for any payments made.
ti
t
IG S eve Zelinger, Esquire
PPrWe Jefendan ,
i Attorney for Plaintiff
Dated: Dated: ?Iklbr
-F-
SO
'D ;
b trj ? ?
?? SE,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
MIDATLANTIC MEDEVAC LLC
Plaintiff(s)
V.
AMY S TIGERS
to0'4 3 Stt
Enokz, PA 1'70&5 Defendant(s)
TO THE PROTHONATORY:
I
No. 08-4816
I
I Term
I
I CIVIL ACTION
PRAECIPE FOR WRIT OF EXECUTION
I (Applicable to real estate and personal
I property)
Issue writ of execution in the above matter, directed to the Sheriff of CUMBERLAND-PA
County:
against AMY STIGERS , defendant(s) and C
-r ?,
c =ra
(2) against, MEMBERS FIRST FEDERAL CREDIT UNION, garnishee; ?.
(3) - C w ;.
•
AMOUNT DUE $19,115.00 -2 C
Less: Credits ($2,812.00)
?a4. so ATr(
q.5. cc e&F
x/8.50 to
µ{.O0 "
a,5o
4'40.So-PD A-RI
INTEREST from:
September 19, 2008
$1,766.49
$a.oo puee.
'.50 L.L
COSTS
Fk
Sub-Total = fit! f ?o
Costs to be Added: I
Total 418, 00.49
Andrew Sklar, Esquire
Attorney for Plaintiff
ID #65332
Sklar - Markind
102 Browning Lane, Building B, Suite 1
Cherry Hill, New Jersey 08003
(856) 616-8710
FILE NO.: 15593.08
1.080va
Q, A 35'1(
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-4816 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due MIDATLANTIC MEDEVAC LLC, Plaintiff (s)
From AMY STIGERS, 604 3RD Street, Enola, PA 17025
(1) You are directed to levy upon the property of the defendant (s)and to sell .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
MEMBERS FIRST FEDERAL CREDIT UNION, 1711 Spring Rd, Carlisle, PA 17013
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $16,303.00
L.L. $.50
Interest from 9 /19/08 -- $1,766.49
Atty's Comm %
Atty Paid $162.50
Plaintiff Paid
Due Prothy $2.00
Other Costs
Date: 6/11/10
(Seal)
REQUESTING PARTY:
Name ANDREW SKLAR, ESQUIRE
Address: SKLAR - MARKIND
102 BROWNING LAND, BUILDING B, SUITE 1
CHERRY HILL, NJ 08003
Attorney for: PLAINTIFF
Telephone: 856-616-8710
Supreme Court ID No. 65332
a . Buell, P othonotary
By:
Deputy
RECEIVED
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIAUN 2 4 101U
CIVIL ACTION - LAW
MIDATLANTIC MEDEVAC LLC
Plaintiff
VS.
AMY STIGERS
No. 08-4816
: TERM
C=
?
C-- -??
CJ '3'_'
-
' CIVIL ACTION
Defendant
I?t1?.SWG4S ?j
INTERROGATORIES IN ATTACHMENT
TO: MEMBERS FIRST FEDERAL CREDIT UNION, Garnishee:
You are required to file answers to the following interrogatories within twenty (20) days after
service upon you. Failure to do so may result in judgment against you.
(1) At the time you were served or at any subsequent time did you owe the defendant(s)
any money or were you liable to him (her/them) on any negotiable or other written
instrument, or did he (she/they) claim that you owed him (her/them) any money or
were liable to him (her/them) for any reason?
N6
(2) At the time you were served or at any subsequent time was there in your possession,
custody or control or in the joint possession, custody or control of yourself and one or
more persons any property of any nature owned solely or in part by the defendant?
W0
(3) At the time you were served or at any subsequent time did you hold legal title to any
property of any nature owned solely or in part by the defendant or in which the
defendant held or claimed any interest?
N?
(4) At the time -you were served or at any subsequent time did you hold as fiduciary any
property in which the defendant had any interest?
1
(5) At any time before or after you were served did the defendant(s) transfer or deliver any
property to you or to any person or place pursuant to your direction or consent and
what was the consideration thereof?
(6) At any time after you were served did you pay, transfer or deliver any money or
property tot he defendant(s) or to any person or place pursuant to his (her/their)
direction or otherwise discharge any claim of the defendant(s) against you?
(lo
(7) If you are a bank or other financial institution, at the time you were served or any
subsequent time did the defendant have funds on deposit in an account in which funds
are deposited electronically on a recurring basis and which are identified as being
funds that upon deposit are exempt from execution, levy or attachment under
Pennsylvania or federal law? If so, identify each account and state the reason for the
exemption, the amount being withheld under each exemption and the entity
electronically depositing those funds on a recurring basis.
W
(8) If you are a bank or other financial institution, at the time you were served or at any
subsequent time did the defendant have funds on deposit in an account in which the
funds on deposit, not including any otherwise exempt funds, did not exceed the amount
of the general monetary exemption under 41 Pa.C.S § 8123? If so, identify each
account.
(9) How much is the value of any property in your possession belonging to the
defendant(s)?
Date: June 1, 2010
Andrew Sklar, Esquire
Sklar - Markind
102 Browning Lane, Building B, Suite 1
Cherry Hill, NJ 08003
(856) 616-8710
i - , r
June 24, 2010
Amy Stigers
604 3`d St
Enola, Pa 17025
Account Number: XXX833
Name on Account:
Amy Stigers
Daryl Stigers (joint)
Savings:
Checking:
Vacation Club
Holiday Club:
$8.70
-5.00 (Membership Fee)
$3.70
-3.70 (Processing Fee)
$0.00
$0.00
$7.56
-7.56 (Processing Fee)
$0.00
$0.00
$300.00 Statutory Exemption was not taken out.
Adyurkholder
Deposit Operations Analyst
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson r, r
?1LF', 1; Rv
Sheriff ?? .
Jody S Smith
Chief Deputy ?d?a „`ur 29i'
t
Richard W Stewart
Solicitor NTY
Midatlantic Medevac, LLC
vs. Case Number
Amy Stigers 2008-4816
SHERIFF'S RETURN OF SERVICE
06/24/2010 09:40 AM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on June 24,
2010 at 0935 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendant, to wit: Amy Stigers, in the hands, possession, or control of the within named
garnishee, Members 1st Federal Credit Union, 1711 Spring Road, Carlisle, Cumberland County,
Pennsylvania 17013, by handing to Lisa Kramer, Adult in Charge, personally three copies of interrogatories
together with three true and attested copies of the writ of execution and made the contents there of known
to her.
The writ of execution and notice to defendant was mailed on June 29, 2010 to Amy Stigers at 604 3rd
Street, Enola, PA 17025.
SO ANSWERS,
June 28, 2010 RON R ANDERSON, SHERIFF
Ro ert Bitner, Deputy
01 CounfySuile Sher ff. I eleosofi. Inc.
Andrew Sklar, Esquire (ID#65332)
SKLAR - MARKIND
102 BROWNING LANE, BLDG B, STE 1
CHERRY HILL, NJ 0 003
(856) 616-8710
Attorney for Plaintiffs
Our File Number: 15 93.08
IN THE COURT OF COMMON PLEAS OF CUMBERLAND-PA COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
MIDATLANTIC
Plaintiff
VS.
AMY STIGERS
Defendant
PRAECIPE TO
TO THE PROTI
Please dissolve the
the above captioned
Date: July 13, 2010
>EVAC LLC : No. 08-4816
"TERM
CIVIL ACTION ,
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LYE ATTACHMENT
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as to garnishee, MEMBERS 1 ST FEDERAL CREDIT UNION, in
Andrew Sklar, Esquire
Attorneys for Plaintiff'
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` SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff r`; Y HE PR074 ".OTA;> '
Jody S Smith "4 t rye
Chief Deputy - 7-011 JAN -6 All 9: 2?
Richard W Stewart
Solicitor
Midatlantic Medevac, LLC Case Number
vs. 2008-4816
Amy Stigers
SHERIFF'S RETURN OF SERVICE
06/24/2010 09:40 AM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on June 24,
2010 at 0935 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendant, to wit: Amy Stigers, in the hands, possession, or control of the within
named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, Carlisle, Cumberland County,
Pennsylvania 17013, by handing to Lisa Kramer, Adult in Charge, personally three copies of
interrogatories together with three true and attested copies of the writ of execution and made the contents
there of known to her.
The writ of execution and notice to defendant was mailed on June 29, 2010 to Amy Stigers at 604 3rd
Street, Enola, PA 17025.
01/05/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is
returned as ABANDONED. No action on writ in over 6 months.
SHERIFF COST: $88.05 SO ANSWERS,
January 05, 2011 RON R ANDERSON, SHERIFF
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Sharon R.
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-4816 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due MIDATLANTIC MEDEVAC LLC, Plaintiff (s)
From AMY STIGERS, 604 3RD Street, Enola, PA 17025
(1) You are directed to levy upon the property of the defendant (s)and to sell .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
MEMBERS FIRST FEDERAL CREDIT UNION, 1711 Spring Rd, Carlisle, PA 17013
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $16,303.00 L.L. $.50
Interest from 9 /19/08 -- $1,766.49
Atty's Comm % Due Prothy $2.00
Atty Paid $162.50 Other Costs
Plaintiff Paid
Date: 6/11/10
Da Buell, Prothon tary
(Seal) By:
Deputy
REQUESTING PARTY:
Name ANDREW SKLAR, ESQUIRE
Address: SKLAR - MARKIND
102 BROWNING LAND, BUILDING B, SUITE 1
CHERRY HILL, NJ 08003
Attorney for: PLAINTIFF
Telephone: 856-616-8710
Supreme Court ID No. 65332