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Home My WebLink About09-0978ROBERT D. KODAK, ESQUIRE KODAK & IMBLUM, P.C. 407 N FRONT STREET, PO BOX 11848 HARRISBURG, PA 17108-1848 (717) 238-7159 Attorney for Plaintiff PEDIATRIX MEDICAL GROUP, INC. IN THE COURT OF COMMON PLEAS OF Plaintiff Cumberland COUNTY, PENNSYLVANIA -wxw v NO. 09 q7$ Civet HEATHER J. SHORT Defendant(s) CIVIL ACTION - LAW NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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, 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 TWO LIBERTY AVENUE CARLISLE PA 17013 717-249-3166 Avlso LISTED 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 veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparencencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones 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 puede 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. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 717-249-3166 PEDIATRIX MEDICAL GROUP, INC. IN THE COURT OF COMMON PLEAS OF Plaintiff Cumberland COUNTY, PENNSYLVANIA v NO. 0 C/ c r,/: l' HEATHER J. SHORT Defendant(s) CIVIL ACTION - LAW COMPLAINT The Plaintiff, PEDIATRIX MEDICAL GROUP, INC., by its attorneys, KODAK & IMBLUM, P.C., brings this action of Assumpsit against the Defendant to recover the sum of FOUR THOUSAND THREE HUNDRED NINETEEN DOLLARS AND TWENTY-NINE CENTS ($4,319.29), along with interest thereon at the statutory rate from April 3, 2007, upon a cause of action of which the following is a statement: 1. The Plaintiff, PEDIATRIX MEDICAL GROUP, INC., is a corporation organized and existing under the laws of the State of Florida, duly registered and authorized to do business in the Commonwealth of Pennsylvania, having an office and place of business at 111 S. Front Street, Harrisburg, Pennsylvania. 2. The Defendant, HEATHER J. SHORT, is an adult individual residing at 812 Belmont Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. On or about February 21, 2007, Defendant sought out medical services from Plaintiff as evidenced by the signed Consent Form, a true and correct copy of which F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\PEDIATRIX 34907.wpd Z is attached hereto, marked Exhibit "A" and made a part hereof. 4. On or about March 3, 2007, Defendant sought out medical services from Plaintiff as evidenced by the signed Consent Form, a true and correct copy of which is attached hereto, marked Exhibit "6" and made a part hereof. 5. On the above dates, Plaintiff, at the special insistence of Defendant, provided medical care to Defendant and/or Defendant's newborn child on or about February 21, 2007 through March 6, 2007, to the total amount of Ten Thousand Three Hundred Eighty-Five Dollars ($10,385.00) as set forth on Plaintiff's Statement of Account attached hereto, marked Exhibit "C" and made a part hereof. 6. The prices charged for said medical services provided were just and reasonable, were the legal and market prices therefor and were the prices which the Defendant promised and agreed to pay to Plaintiff. 7. Defendant became entitled to certain credits against the charges aforementioned, as more particularly shown on Exhibit "C" to the total amount of Six Thousand Sixty- Five Dollars and Seventy-One Cents ($6,065.71). 8. The balance due and owing by Defendant to Plaintiff is the sum of Four Thousand Three Hundred Nineteen Dollars and Twenty-Nine Cents ($4,319.29), as appears F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\PEDIATRIX 3490.wpd 3 by Exhibit "C" hereto. 9. Plaintiffs Invoices are not attached to this pleading due to the voluminous nature of same and have previously been provided to Defendant. 10. Plaintiff frequently demanded payment from Defendant of said amount due and owing as aforesaid, but Defendant refused and neglected and still refuses and neglects to pay said amount or any part thereof. WHEREFORE, Plaintiff brings this suit to recover from Defendant the sum of FOUR THOUSAND THREE HUNDRED NINETEEN DOLLARS AND TWENTY-NINE CENTS ($4,319.29), together with interest as set forth herein. Respectfully submitted, KODAK & IM M, P.C. Robert D. Kodak, Esquire 407 North Front Street Post Office Box #11848 Harrisburg, PA 17108-1848 (717) 238-7159 Attorney ID No. 18041 Attorney for Plaintiff F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\PEDIATRIX 34907.wpd 4 __ ____ .._ _ , _ ?? .. r•r.. rrr •..v?.J G.?Y AV/. •.4 GG{ E.AUGA14. LVU - S ?•? CONSENT FOR TREATMENT =1 consent to the rendertrg of medical care. which may inducts diagnostic procedures end such • macflpl treatrnertl as rnry Mending or corhscllting physician eatsiders to be necessary, I also understand that. absrrd amoVe. my circumstances, no irmsive or experimental procedure will be parfornled upon me unless or until I have had an oppOnury'ty bi diec Liss the procedure with my physician and give informed consent 10 the procedure. I undarstand that the pradice of modldne and satrgery is not an exact science and that diagnosis and treatment may involve risk of Fury or seen death. I adwmWodge aunt no guarantee has • been made to me regarding any examination or treatment in tMs hospital. PRE-CERTIFICATION REGti1REMEMTS - If my insurance company or third party requires Pre- don, then I understand that it is Y rosponsibdky to contact *wn to obtain such conifloation. EXCEPTION: Medicare. ASSIGNMENT OF INSURANCE BENEFITS - I hereby authorize my Medicare and/or medical Inwrartoa benefits payable to no under the terms of my insurance policies to be paid directly to Pinnada Haallh Hospitals. If my attending physician and/or other Physician associated with him or whom he may designate accepts insurance awirgnrnsnt, then t herby authorize my Msdicttre srtdbr medical Hsurence benefits to be paid directly to Itxm physicians, l assign any and all lei rights tha11 have to coiled ber*Mss to ' Pinnade Health Hospitals. I understand !fiat I am ifnanclafly responsible for non•covared services. as well as any deduclfblM coinsurance or amounts in s=ass of Insurance beneflls. l permit a copy of this coraent to be used In place of the orlgirtel. GRIEVANCE APPEAL CONSENT - I hereby authorize Pinnacle Health Hospitals 10 act an my behalf in requesting a recomideraft of a medical determination wads by my managed care pan or ullftadorh review erttily regarding my medical care. ADVANCE DIREC rNE84NPATIEM ONLY - I understand that Pinnacle Health Hospitals wig provide me with written it" I, n&V regarding my right to make health care Imetmod decisions in cempllence with the Patent SGIM30481 rm1112 tbn Act r1f 19110. This intorwadon Wit be provided in the Patient Handbook, MEDICARE INPATIENTS ONLY - I carlify that the Wormallon given by me in a0plying for payment sunder Title XVII or the Social Security Adis corned. I admowiecIgs that 1 have received a copy of An Important Message front Madleani My sigtratuns ' adinowledges my receipt of Ws message from Pinnacle Health and does not wake any of my rights to request a review or rata no arty payment. I realize that fifettna reserve days ale a once Ilfelimme msa*num of 60 days. If I should usn all or my httl days fo*illabls urance days. I agree to use my Ilfstlwe reserve days for any remaining days. RIV ACY NOTICE; - I acknowledge Vol i have received a copy of PkuurJo Health Syslam'e Privacy Notice, ERSONAL VALUABLES - Pihnado Health Hospitals Is not responsible for pwoonat Isms brought to eke hospital A Soft for valuables such as cash. Important documents, credit prods and 1eWtlry that can not be sent home M Personal Items retained at the bedside are tit ads responsibility of the patient TELEPHONE AND TOL.EVINON - I understand that there la a minimal daily charge per day charge for the availability of id 0hona (local calls only) and television service as these services are not cornered by Inscranee. This amom vA be charged to nhp home telephone bill of which I sew euNalted to accept charges and allow the release of only informurdon to live Idephons company that is necessary to bill for those services. ATIENT ANONYMrry tFsd>Ity Okecw Opt Oct for Psdoncs in dw ttmarwey Dep eftent and Than Anbrad ban ich.HprW NO I NWOW r"th elio?tats Pa t Mo m ft ??dpor ny 1don ft and om"n" durig rids mum of core only. I ? that the Pirrone h pobw has baron expteirad to me and Ihat I haw boar provldad vAh the s?gnatun of fader a Rwow DateSI ' CONSENT MUST BE SIGNED BY THE PATIENT'S LEGAL REPRESENTATiVE IN THE mow A EN THE PATENT IS PHYSICALLY OR MENTALLY INCAPACITATED. Nadi or printod Nanto Leak Rapresenfatlvo and RehttiortsNp art Patient Pellent rs treble to sign because: J%. Hospital tjz4A PINNACLEHEALTH Havicah CONSENT FOR TREATMENT le?i?r?rr _ MR: 910038489 CASE 270207740 T."ZJffA7I, W F OATS 02/21/07 DM* 02/21r1 W PhJfc 717.214-4167 AGE 0 Oft DALY JANW F lei Ablood Cam INV Wo tartlA MR (Mot eta-1 eoiueWd 901-1 EXHIBIT -1011 L9:80 loot-z" - -• ---- -- --- * -.. . -" %-UxiOGUt- rarxn I - 31//dUU-f - 3 P•, .9 the undersgned .--understand that my nswborn infant has been admitted to the Neonotar Inionalm care unit or PlnrtadeHealfh at Harrisburg Hospital unbars he/she will receive dose observafon and care. I vokmtarily consent that my Infant receive services indudbng diagnostic and therapeutic procodunM emotions, h spital care, and medical treatment. In orderto assist In anBdpa V andfordhUnceMg evsslble complications and thereby carry out apprapriats measures to prevent and/or treat these compik owns, consent and auffiorhado6 is given forthe fbP&Ap prooodum to be perfomned under f1•la direction of tine Physicians of Pediakk Medical Group and thekAssoraates, via: 1. Resincitabort end enndobacheal Irdubation and vw* tiort (brsalhirg for he ktfant by a[ttlidai means). Comptic at(ons Include but we not Bmited to ao*bntW dislodgment, pkWng. and trauma to the vocal cords. 2. X-ray aidies. 3. Blood sbrdies by means of needle punchrre of a vein or artery or by indvaMM orberial or venous catheters. Connpk 114 one of kVMv i V wbrgal or venous Nne Dvwspy Include but are riot Imited to blood toe% Infs+ctiern, end breol ft kow or dots wtib went ogpn darn@W A AdtnhMadon of kdrOvenous fluids and Irtedkaflons via Perlpheral or cent l vein. p Corrocations of same Uxdude but are not ilmftd to leakage of tluld and r nedioution Ingo tissue sunoundrwp the veln and Wedlon. a Plaosrnerd of thoracAPIMbiny tube(s) to end a collapsed lung. Complications Include but are rot Wnkad to puncture of the MU Weedira and Inrect ion 6. CuMra. drawn by needle, of blood, urirne, andfcr apktal Hold for infection. Compiicatlone Invesligsdan d include but ass not limbed to infbdon anblooding. 7. Other such degnostio Piss And trsahnents that may be deemed advisable An effort wig be made to discuss these with me befornehand unless in mediate performance in necessary. am suitors that the pry of Lbdk kw is not an arced science and I a*w&fte that no gL=Wgggs have bean made to me concerning the results clef treobnenb wKft Deal Is at the NICU at Ph o wdeFleagh at Harrisburg Hospital. This form ha been fW e?xplafned to me and I cw* VW I understand b co -to *, U#Ah- OrMoew Date 3 Q 1 vm awaw?w?mp?w fPM SIN 800/IQO'd 901-1 Dube p a ntkknsromon MR:910039489 CASE:270207740 SHORT, Gr,L HS4I F DATE: 02121W DOS: 0212112eo7 PhAP6 717-2144167 AGE: 0 DP;MOGUA SERNAMNS EXHIBIT "?" SIC Inez-z"D I CIM712 Computers & Innovative Management, Inc. FOCUSED RECOVERY SOLUTIONS, INC. Account # 3427667 Clnt 723 Client's # 903277119 R/P SHORT HEATHER J 812 BELMONT ST Debtor SHORT 603 MARKET STREET Date: 9/29/2008 Page: 1 Collector 7 LILLIAN R MECHANICSBURG PA 17055-4311 NEW CUMBERLAND PA 17070 Phone 717 214 4167 Phone SS 704.2. SS # -? ADM-DTE 2/21/2007 DLS;2jL 3/06/2007 Placed 10/15/2007 PST-CK 0/00/0000 LST-PAY 1/17/200 11/28/2008MI7 a 700 STS 612 F/C 992 Rel Phy # Ltr # & date --C---1702/2008 Rate 0.00 Pay# Due 0/00/0000 Life Pay-amt $.00 Rt-mail 0/00/0000 Con-dte 0/00/0000 Con-pd 0 Con-amt W/O Date Spouse Pat-Typ DOB 2/21/2007 POR Empl COMMONWEALTH OF PA Emp2 Slfl ALT # 717-635-9883 Slf2 **POE DPW PA*** Slf3 Insl CAPITAL BLUE CROSS Group # 00502625 Cont# PFP80044994100 Filed 866 686 2242 - Ins2 Group # Cont# Filed Ins3 Group # Cont# Filed Ch 1 Pay $6,065.71- Adj $.00 g $.00 orplIrm Y-, Bal $4,319.29 Int $.00 Late $.00 Insl $.00 Ins2 $.00 Ins3 $.00 Pat Due $.00 rt EXHIBIT "C" 05/22/2004 23:17 FED-0"i-2009 11:14 9043465221 PEDIATRIX PAGE 09/09 KODAK AND 1NSLU14 P.C. 717 238 7158 P.07 VERIFICATION I, &&NOW- 4% ? •e ea ,, kS%?T C , (name) (KIM) of PEDIATRIX MEDICAL GROUP, INC., verify thatthe statements made in the eforegoing document are true and correct. I understand thatfalse statements herein are made subject to the penalties of 18 Pa. C. S. §4904, relating to unswom failstfcation to authorities. PEDIATRI MEDICAL GR =INC. By: MENEM Title; . . ? ? ?.?....?,..,?? Dated: Z 3 34907 sham TOTAL P.07 r._1 ) •.A , 00 t SHERIFF'S RETURN - REGULAR CASE NO: 2009-00978 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PEDIATRIX MEDICAL GROUP INC VS SHORT HEATHER J NOAH CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CuC1DT TJL ArPTJWT? .T the DEFENDANT , at 0015:33 HOURS, on the 20th day of February-, 2009 at 812 BELMONT ST MECHANICSBURG, PA 17055 by handing to HEATHER J SHORT DEFENDANT 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 Service Affidavit Surcharge Postage So Answers: 18.00 10.80 .00 10.00 R. 'Thomas Kline .42 39.22 02/23/2009 KODAK & IMBLUM Sworn and Subscibed to before me this By: day Deputy Sheriff of A. D. ?; ??: ,a' --? r,? a -. y _.,... ??'; PEDIATRIX MEDICAL GROUP, INC. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v NO. 2009-978 CIVIL TERM HEATHER J. SHORT Defendant(s) CIVIL ACTION - LAW TO: PROTHONOTARY, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PRAECIPE FOR DEFAULT JUDGMENT Please enter judgment in favor of Plaintiff and against Defendant(s) HEATHER J. SHORT, named for failure to file within the required time an Answer to the Complaint in the above-captioned case and assess the Plaintiff's damages as follows: Amount claimed in Plaintiff's Complaint $4,319.29 Interest at the statutory rate of 6% per annum from April 3, 2007 523.72 Total = $4,843.01 I hereby certify that a written Important Notice of the intent to file this Praecipe was mailed or delivered to the Defendant(s) and/or his/her Attorney of Record, if any, after the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe and a copy of the notice(s) is/ are attached. KODAK & I , P By Robert D. Kodak, Attorney for Plaintiff DATED: 4/I?F/o9 Judgment entered and damages assessed as above. rothonotary LAW OFFICES OF KODAK & IMBLUM, P.C. CAMERON MANSION Telephone Robert D. Kodak 407 NORTH FRONT STREET 717.238.7159 Gary J. Imblum POST OFFICE BOX 11848 Facsimile HARRISBURG, PA 17108-1848 717.238.7158 www.kodak-imblum.com March 16, 2009 FILE COPY HEATHERJSHORT 912 BELMONT STREET MECHANICSBURG PA 17055 RE: Pediatrix Medical Group, Inc. VS: Heather J. Short No.2009-978, Court of Common Pleas, Cumberland County, PA Our File No. 34032 Greetings: In accordance with Pennsylvania Rules of Civil Procedure 237.1(a)(2), we are enclosing herewith a Notice of a Praecipe for Entry of Default Judgment. According to the records as they are found in the Office of the Prothonotary of Cumberland County, you have not filed responsive pleadings to the Complaint filed against you to the above term and number, nor has any attorney entered an appearance on your behalf. Accordingly, we are forwarding to you the enclosed Notice which indicates that if you do not take action as set forth in this Notice, we, at the expiration of time indicated therein, will request the Office of the Prothonotary of Cumberland County to enter judgment against you in the amount as set forth in said Complaint. Very truly yours, KODAK & IMBLUM, P.C. ROBERT D. KODAK, ESQUIRE robert.kodak@kodak-imblum.com RDK/rzs Enclosure(s) THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. C ELIZABETH GERDING PRESIDENT FOCUSED RECOVERY SOLUTIONS INC 9701 METROPOLITAN COURT STE B I RICHMOND VA 23236 3427667 PEDIATRIX MEDICAL GROUP, INC. v HEATHER J. SHORT Plaintiff Defendants FILE COPY IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA NO. 2009-978 CIVIL TERM CIVIL ACTION - LAW IMPORTANT NOTICE TO: HEATHER J. SHORT Defendant(s) DATE OF NOTICE: March 16, 2009 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING` WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 717-249-3166 AVISO IMPORTANTE A: HEATHER J. SHORT Defendido(s) FECHA DEL AVISO: March 16, 2009 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE REGISTRAR COMPARENCENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO Y SOMETER CON LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN PRESENTADO CONTRA USTED. A MENOS QUE USTED ACTUE DENTRO DE DIEZ DIAS DE HABER RECIBIDO ESTE AVISO, LA CORTE PUEDE TOMAR UNA DECISION EN CONTRA SUYA SIN TENER DERECHOS A UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTA DOCUMENTO A SU ABOGADO INMEDIATEMENTE. 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. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 N i? FILED-01-TICE OF THE ; 17-'ONOTAPY 2009 APR 14 FM 2: 16 Ur t iN` r._ tp pi 1 I?) + f.? i "i K1T'f" *14 . oo PO CK-* rt9 39 eT4- aaa7aq PEDIATRIX MEDICAL GROUP, INC. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v NO. 2009-978 CIVIL TERM HEATHER J. SHORT Defendant(s) ' CIVIL ACTION - LAW TO: HEATHER J. SHORT, Defendant(s) 1 the following You are hereby notified that on /`loci 1 Jq ---,200 Qudgment) has been entered against you in the above-captioned case. judgment entered in the amount of $4,843.01 DATE: P thonot I hereby certify that the name and address of the proper person(s) to receive this notice is: HEATHERJSHORT 912 BELMONT STREET MECHANICSBURG PA 17055 PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 PEDIATRIX MEDICAL GROUP, INC. IN THE COURT OF COMMON PLEAS OF Plaintiff Cumberland COUNTY, PENNSYLVANIA vs Writ No. Term 20 No. ?009-978 Term 20 09 HEATHER J. SHORT Amount Due 812 BELMONT STREET 4/14/09 faint minus paymts . ~ 4,543.01 MECHANICSBURG PA 17055 Interest from jdmt -4/14/10 DEFENDANT(S) 0.75 per diem ............... $ 267.00 Att~~'s Commission PENNSYLVANIA STATE EMPLOYEES 5°%Jstatutor_v rate .......... $ ?27.15 CREDIT UNION ................ Garnishee Costs (to be aeterminea~ S '10 THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, **GARNISHMENT ONLY** (1) Directed to the Sheriff of DAUPHIN County, Pennsylvania (2) against HEATHER J. SHORT De enc ants ; (3) and against PENNSYLVANIA STATE EMPLOYEES CREDIT UNION i+ (llOf1 ~C1.C'8 arms ee s ; Pq i~iio (4) and index this writ (a) against HEATHER J. SHORT Defendant(s) and (b) against PENNSYLVANIA S'IATE EMPLOYEES CRIDIT UNION arms gee s , as a lis pendens against die real property of the defendant(s) in the name of the Garnishee(s) as follows: (Specifically describe property and note any specific direction to Sheriff) Furnish 4 copies for real estate levy): DO NOT LEVY GARNISH ABOVE BANK PENNSYLVANIA STATE EMPLOYEES CREDIT UNION AT: 1 CREDIT UNION PLACE, HARRISBURG, PA 17110 ACCOUNT # XXXXXX8940, SOCIAL SECURITY # XXX-XX-704 ~J (5) Exemption has (not) been waived. Dated 4/13/70 Robert D. Kodak, Esquire PO Box 11848 Harrisburg, PA 17108 (717) 238-7159 Attorney For Plaintiff(s) ~ ~ ~tr ~ ~_ Q' p O ~ ~ ~ .~. oho ~ t ~ C/ ~ (1~ ~~ r r7 J S~ O (n Sti p~ O O O w _ ~:~ D ~ ~ ~- ,_ ~ D o ~~ Y m n m O m x m n c O z m cn x O tr1 d ~_ X m d r~ c~ O c z n N~~,~~ Under pnragriph I I) when the writ is directed to the sheril7of another county as authoriicd h~~ Rulc3 IU3fbi. the count' should he indicated Under Rulc 3 I U31c 1 a ~s~rit issued on a translcrred judgment may be directed Dole to the sherifl of the county in which issued Paragraph (? i lahocc should be completed onl~~ in a named earnishce is to he included in the ~~rit) z 0 x ~~ z C Paragraph (l)(al should be compldcd only if indcsing of the czccutions in the counlc of isaurance. is desired a~ awhoriicd h~ Rule 310-4(a i. When the ~~rit issues to anothu counh~ indc.~in~~ is required us of coiuse in that counts h~ the prothonotar~~ Sec Kule ~ 101(hi- Paragraph (+11 h~ should he completed onk if real propcrtc in the name of the garnishee iti attached and indexing as a lis pendens is desired. Sec Rule 3101(cL ~1'~ ~ r-~~ ~~ ~a Mary Jane Sn~der Charlcn eeDep heaffer Real Estate Depu ;~~; William T. Tully ~ ~ Michael W. Rinehart Solicitor Assistant Chief Deputy Dauphin County ® 1 ~ O a --~/~ Harrisburg, Pennsylvania 17101 _ 1 _ ( 7'7J ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania PEDIATRIX MEDICAL GROUP, INC. VS County of Dauphin HEATHER J SHORT Sheriff s Return No. 2010-CV-07129-NT And now: MAY 28, 2010 at 11:47:00 AM served the within WRIT OF EXECUTION & CL V u(1 INTERROGATORIES upon PSECU-GARNISHEE by personally handing to PATTY KELLY- HOLJES; JUDGEMENT COLLECTO 1 true attested copy of the original WRIT OF EXECUTION & INTERROGATORIES and making known to him/her the contents thereof at 1 CREDIT UNION PLACE HARRISBURG PA 17110 So Answers, ~~~ Sheriff of Dauphin County, Pa. Deputy: G MILLER Plaintiff: PEDIATRIX MEDICAL GROUP, INC. Sheriffs Costs: $ PAID BY COUNTY Out Of County Cost: n ~ _ C7 'i3 rp-t T: Z ?> Tu N l ..~y rrs "~ ~~ PEDIATRIX MEDICAL GROUP, INC.. Plaintiff v HEATHER J. SHORT Defendant(s) v PENNSYLVANIA STATE EMPLOYEES CREDIT UNION Garnishee IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-978 CIVIL TERM CIVIL ACTION - LA4~~ rn ,, ,~, .~ ~°=~~-~ '~'' ~ t~ r F cNr; ~ ~ ~ ~ t ,~ ,~ ,.. ~ ~• ~ ~ s~ C U ~ .Q PRAECIPE i TO THE PROTHONOTARY: Please dissolve the Garnishment issued against Pennsylvania State Employees Credit Union, Garnishee in the above-captioned matter. TO: Cumberland County Prothonotary Dated: Tune 7, 2010 ~L ~~ -.,-r-; ~` f') .: -~ . ~,, ..r, ..~ Attorney I.D. No. 18041 PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 PEDIATRIX MEDICAL GROUP, INC., IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA Plaintiff vs HEATHER J. SHORT 812 BELMONT STREET MECHANICSBURG, PA 170504311 Writ No. Term 20 No. 2009-978 Term 20 11 Amount Due 4/14/09 jdmt minus pymts .. $ 2,466.00 Interest from jdmt -1/20/12 .41 per diem ................ $ 414.51 DEFENDANT(S) Atty's Commission 5% statutory rate .......... $ 123.30 Costs (to be determined) $ TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE. MATTER, (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania (2) against HEATHER J. SHORT e en ants ; (3) and against Garnishee(s); (4) and index this writ (a) again?.t HEATHER J. SHORT Defendant(s) and (b) against Garnishee(s), as a lis pendens against: the real property of the defendant(s) in the name of the Garnishee(s) as follows: (Specifically describe property and note any specific direction to Sheriff) Furnish 4 copies for real estate levy): LEVY UPON ALL PERSONAL PROPERTY OF THE ABOVE-LISTED DEFENDANT(S) AT THE ABOVE ADDRESS IN CUMBERLAND COUNTY, INCLUDING BUT NOT LIMITED TO FURNITURE, JEWELRY, ELECTRONICS, SUPPLIES, ETC., (5) Exemption has (not) been waived ;~ _3 Y y be D. Kodak, Esquire PO Box 11848 Harrisburg, PA 17108 (717) 238-7159 Dated 1/17112 Attorney For Plaintiff(s) Q 1 ti V D 0 m 0 rt. i I m 171 m a x { m i U C j y z { ;? tutt r ? r rT1 u tJ X o U i i ? J C ? ? I t? NI>,l Under paragraph ( I ) when the writ is directed to the sheriffofanother county as authorized by Rule 3103(1)), the cormty should be indicated Under Rule 3103(c) a writ issued on a transferred judgment may, be directed only to the sheriff ofthe county in which issued Paragraph (3) (above should be completed only in a named garnishee is to be included in the writ i Paragraph (4)(a) should be completed only if indexing of the executions in the county of insurance, is desired as authorized by Rule 3104(a) When the writ issues ta, another county indexing is required as of course in that county by the prothonotary See Rule 3104(b). Paragraph (4)(b) should be completed only if real property in the name of the garnishee is attached and indexing as a its pendens is desired See Rule - 1 04(c WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY" OF CUMBERLAND) NO 2009-978 Civil CIVIL ACTION - LAW TO THE `.SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PEDIATRIX MEDICAL GROUP, INC. Plaintiff (s) From HEATHER J. SHORT - 812 Belmont Street, Mechanicsburg, PA 17050-4311 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY OF THE ABOVE-LISTED DEFENDANT(S) AT THE ABOVE ADDRESS IN CUMBERLAND COUNTY, INCLUDING BUT NOT LIMITED TO FURNITURE, JEWELRY, ELECTRONICS, SUPPLIES, ETC.. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of 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 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 $2,466.00 L.L. Interest from jdmt - 1/20/ 12 (.41 per diem) -- $414.51 Atty's (:'ornm 5 %statutory rate -- $123.30 Due Prothy $2.25 Atty Paid $192.72 Other Costs Plaintiff Paid Date: 1, 23/12 David D. Buell, Prothonotary (Seal) Deputy REQUESTING PARTY: Name JEFFREY L. TROUTMAN, ESQUIRE FOR ROBERT D. KODAK, ESQUIRE Address: PO Box 11848 Harrisburg, PA 17108 Attorney for: PLAINTIFF Telephone: 717-238-7159 Supreme Court ID No. 53984