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Home My WebLink About10-2200O .(0 CARP 2j; la • 1 Craig A. Diehl, Esquire r: 'fva? I.D. No. 52801 LAW OFFICES OF CRAIG A. DIEHL 3464 Trindle Road Camp Hill, PA 17011 Attorney for Plaintiff, Cornerstone Adminisystems, Inc. CORNERSTONE ADMINISYSTEMS, IN THE COURT OF COMMON PLEAS OF INC., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff nn•• v. NO. t 0- 6161 p 1.:?V.i l t e" AMERICAN HOSE & CHEMICAL FIRE COMPANY, : Defendant 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 THE TELEPHONE OR 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 1-800-990-9108 717-249-3166 l?J 4q.1.00 Po A,-ty CL* 16as(o P* a3q 17dy AVISO USTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion dentro de veinte (20) dias a partir de la fecha en que recibio la demanda y el aviso. Usted debe presentar comparecencia escrita en persona o por abogado y presentar en la Corte por escrito sus defensas o sus objeciones a las demandas en su contra. Se le avisa que si no se defiende, el caso puede proceder sin usted y la Corte puede decidir en su contra sin mas aviso o notificacion por cualquier dinero reclamado en la demanda o por cualquier otra queja o compensacion reclamados por el Demandante. USTED PUEDE PERDER DINERO, O PROPIEDADES U OTROS DERECHOS IMPORTANTES PARA LISTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE O NO CONOCE UN ABODAGO, VAYA O LLAME A LA OFICINA EN LA DIRECCION ESCRITA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 CORNERSTONE ADMINISYSTEMS, INC., Plaintiff V. AMERICAN HOSE & CHEMICAL FIRE COMPANY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW COMPLAINT 1. Plaintiff, Cornerstone Adminisystems, Inc., is a Pennsylvania corporation with a business address at P.O. Box 726, New Cumberland, Pennsylvania 17070. 2. Defendant, American Hose & Chemical Fire Company, is an unregistered entity conducting business operations in Pennsylvania with a mailing address of 203 South Poplar Street, Mt. Carmel, Pennsylvania 17851, and a physical address of 250 South Vine Street, Mt. Carmel, Pennsylvania 17851-1561. 3. Plaintiff and Defendant entered into an oral contract whereby Plaintiff would perform certain ambulance consulting services on behalf of Defendant. 4. Plaintiff performed consulting services for Defendant for a period of time including March 1, 2009, through January 31, 2010. 5. Plaintiff charged rates for its services that are reasonable and customary for this type of services. 6. Plaintiff provided Defendant with monthly itemized invoices substantiating the time incurred performing services for the consulting project. 7. The amount due to Plaintiff from Defendant is Thirty-Five Thousand One Hundred Thirty-Five Dollars ($35,135.00). See Exhibit "A" attached hereto and incorporated herein for true and correct copies of the invoices. 8. Despite demand, Defendant has failed to pay for the services rendered. 9. The amount in controversy requires compulsory arbitration. WHEREFORE, Plaintiff, Cornerstone Adminisystems, Inc., respectfully requests judgment to be entered in its favor and against Defendant, American Hose & Chemical Fire Company in the amount of Thirty-Five Thousand One Hundred Thirty-Five Dollars ($35,135.00), plus interest, costs, and reasonable attorney fees. Respectfully submitted, LAW OFFICES OF CRAIG A. DIEHL Date: p By: ox'I'w d A-"Jff Craig Diehl, Esquire Attorney I.D. No. 52801 3464 Trindle Road Camp Hill, PA 17011 Tel: (717) 763-7613 Fax: (717) 763-8293 Attorney for Plaintiff, Cornerstone Adminisystems, Inc. EXHIBIT "A" Box 726 Comers Ne New Cumberland, PA 17070 Statement P: 717.724.4157 - F: 717.214.6020 www.casys.com - balnor@casys.com Date 3/10/2010 American Hose Co Ambulance James Reed 203 S Poplar St Mt Carmel, PA 17851 $35,135.00 02/28/2009 Balance forward 03/31/2009 INV #1089. Due 03/31/2009. 0.00 690 00 -- American Hose Co Ambulance Consulting Project . 690.00 --- Period 3/1/09 - 3/31/09 --- Senior Consultant Client Rate, 7 @ $95.00 = 665.00 --Technical Asst Client Rate, 0.5 @ $50.00 = 25.00 04/30/2009 INV #1090. Due 04/30/2009. 2 450 00 --American Hose Co Ambulance Consulting Project , . 3,140.00 -- Period 4/1/09 - 4/30/09 -- Senior Consultant Client Rate, 20 @ $95.00 =1,900.00 -- Technical Asst Client Rate, 11 @ $50.00 = 550.00 05/31/2009 INV #1098. Due 05/31/2009. 2 090 00 --American Hose Co Ambulance Consulting Project , . 5,230.00 -- Period 5/1/09 - 5/31/09 --- Senior Consultant Client Rate, 22 @ $95.00 = 2 090 00 06/30/2009 , . INV #1100. Due 06/30/2009. --- American Hose Co Ambulance Consulting Project 4,655.00 9,885.00 --- Period 6/1/09 - 6/30/09 --- Senior Consultant Client Rate, 49 @ $95.00 = 4,655.00 0.00 I 665.00 l 2,090.00 3,040.00 29,340.00 I $35,135.00 Page 1 Cumberland, PA 17070 Ratement 157 - F: 717.214.6020 P. PO Box N 717Box.724726 .4 www.casys.com balnor@casys.com Date 3/10/2010 American Hose Co Ambulance James Reed 203 S Poplar St Mt Carmel, PA 17851 $35,135.00 07/31/2009 INV #1101. Due 07/31/2009. 6,480.00 16 365 00 -- American Hose Co Ambulance Consulting Project , . --- Period 7/1/09 - 7/31/09 --- Senior Consultant Client Rate, 64 @ $95.00 = 6,080.00 --- Technical Asst Client Rate, 8 @ $50.00 = 400.00 08/31/2009 INV #1102. Due 08/31/2009. 4,995.00 21 360 00 --- American Hose Co Ambulance Consulting Project , . --- Period 8/1/09 - 8/31/09 --- Senior Consultant Client Rate, 51 @ $95.00 = 4,845.00 --- Technical Asst Client Rate, 3 @ $50.00 =150.00 09/30/2009 INV #1107. Due 09/30/2009. 4 655 00 --- American Hose Co Ambulance Consulting Project , . 26,015.00 --- Period 9/1/09 - 9/30/09 -- Senior Consultant Client Rate, 49 @ $95.00 = 4 655.00 10/31/2009 , INV #1103. Due 10/31/2009. 3 325 00 -- American Hose Co Ambulance Consulting Project , . 29,340.00 - Period 10/1/09 -10/31/09 -- Senior Consultant Client Rate, 35 @ $95.00 ='3 325.00 11/30/2009 , INV #1108. Due 11/30/2009. 3 040 00 --- American Hose Co Ambulance Consulting Project , . 32,380.00 -- Period 11/1/09 - 11/30/09 --- Senior Consultant Client Rate, 32 @ $95.00 = 3,040.00 0.00 R R 665.00 2,090.00 3,040.00 29,340.00 $35,135.00 Page 2 Comerstone NPO Box 726 ew Cumbe P: 717.724. 4157 F: 717.214.6020 www.casys. American Hose Co Ambulance James Reed 203 S Poplar St Mt Carmel, PA 17851 rland, PA 17070 Statement com bainor@casys.com Date 3/10/2010 $35,135.00 12/31/2009 INV #1112. Due 12/31/2009. 2,090.00 34,470.00 -- American Hose Co Ambulance Consulting Project --- Period 12/1/09 -12/31/09 --- Senior Consultant Client Rate, 22 @ $95.00 = 2,090.00 01/31/2010 INV #1111. Due 01/31/2010. 665.00 35,135.00 --- American Hose Co Ambulance Consulting Project --- Period 1/1/10 -1/31/10 --- Senior Consultant Client Rate, 7 @ $95.00 =665.00 0.00 I 665.00 2,090.00 I 3,040.00 Page 3 29,340.00 $35,135.00 PO Box 726 Cornerstone New Cumberland, PA 17070 P: 717.724.4157 - F: 717.214.6020 www.casys.com - balnor@casys.com American Hose Co Ambulance James Reed 203 S Poplar St Mt Carmel, PA 17851 American Hose Co Ambulance Consulting Project Period 1/1/10 -1/31/10 Senior Consultant Billable Hours Date 1/31/2010 Invoice # 1111 Terms Due on Receipt Invoice 7 1 95.001 Per Hour 665.00 + Make check payable to Cornerstone Adminisystems, Inc. Include invoice number on check All major credit cards accepted . (All charges will appear on your credit card statement as "Ambulance Transport") Card Number Name on Card Exp. Date Card Billing Address City, State, Zip Email, Phone Number Total $665.00 Payments/Credits $0.00 Balance Due $665.00 Thank you for Partnering with Cornerstone An Evolution in Ambulance Billing Cornerstone Billable Time Classifications Date Task Performed Performed By 01/20/10 Ryno F01/21/10 Ryno Number of Billable Hours Worked Senior Technical Admin Consultant Assistance Assistance Task Overview - Notes Membership Items with Michael H +. , Tom Alleman 1 Kulpmont Issues 01/26/10 Ryno 0 Strategic Planning AH ; SEEMS ti!'T 1 ki - _ Total Billable Hours _ Billable Rates Subtotal Billable Amount TOTAL Billable Amount 7.00 $ 95.00 $ 665.00 $ - - $ 50.00 $ 25.00 $ - $ - 665.00 Prepared by Cornerstone Adminisystems, Inc. Cornerstone Ne Box 726 New Cumberland, PA 17070 P: 717.724.4157 - F: 717.214.6020 www.casys.com - balnor@casys.com American Hose Co Ambulance James Reed 203 S Poplar St Mt Carmel, PA 17851 American Hose Co Ambulance Consulting Project Period 12/1/09 -12/31/09 Senior Consultant Billable Hours Invoice Date 12/31/2009 Invoice # 1112 Terms Due on Receipt 22 95.00 Per Hour 1 2,090.00 T Make check payable to Cornerstone Adminisystems, Inc. Include invoice number on check All major credit cards accepted (All charges will appear on your credit card statement as "Ambulance Transport") Card Number Name on Card Exp. Date Card Billing Address City, State, Zip Email, Phone Number Total $2,090.00 Payments/Credits $0.00 Balance Due $2,090.00 Thank you for Partnering with Cornerstone An Evolution in Ambulance Billing Cornerstone =Muni= -W Performed Performed By Consultant Assistance Assistance Task Overview - Notes icr 1 VIV?7 _- rt nV Membership Follow Up with M. Henry 12/15/09 Ryno 2.00 ;F/U with Tom and Jimmy on various items --- 12/17/09 - 0 ' - 3.00 _ jTom Alleman planning for lease /meeting - i 12/21/09 2100 Coordinate and nd Plan Meeting AH /SEEMS L 12/22/0 j _ R?yno 0 - -- Me mbershl Issues and Follow U Item -- 12/29/09 12/30/09 Ryno ? 7.00 Ryno ?4 {?p _ Travel and Meeting at AH with SEEMS / AH Final Membership Revisions & Lease F/U ? t n V ''ytX' ? -. I ? t F. x r . _ Total Billable Hours 22.00 - - Billable Rates $ 95.00 $ 50.00 $ 25.00 Subtotal Billable Amount $ 2,090.00 $ - $ - TOTAL Billable Amount $ 2,090.00 Prepared by Cornerstone Adminisystems, Inc. Billable Time Classifications ........ __.__ _Number of Billable Hours Worked Date Task Senior ??? Technical Admin PO Box 726 Cornerstone New Cumberland, PA 17070 P: 717.724.4157 - F: 717.214.6020 www.casys.com - balnor@casys.com American Hose Co Ambulance James Reed 203 S Poplar St Mt Carmel, PA 17851 American Hose Co Ambulance Consulting Project Period 11/1/09 -11/30/09 Senior Consultant Billable Hours Date 11/30/2009 Invoice # 1108 Terms Due on Receipt Invoice 32 95.001 Per Hour 3,040.00 Make check payable to Cornerstone Adminisystems, Inc. Include invoice number on check All major credit cards accepted (All charges will appear on your credit card statement as "Ambulance Transport") Card Number Name on Card Exp. Date Card Billing Address City, State, Zip Email, Phone Number Total $3,040.00 Payments/Credits $0.00 Balance Due $3,040.00 Thank you for Partnering with Cornerstone An Evolution in Ambulance Billing r Cornerstone Performed Performed By Consultant Assistance AssistanrP 11/02/09 Ryno 4.00 .. - - Travel to AH for Mbship Pics & FU items J 11/04/09 Ryno 2.p0 -- TF/U on items and plan meeting(s) 11/09/09 !Ryno Meeting at American Hose w/SEEMS & AH 11/13109 Ryno 2,00 - _ , F/U on items with Tom Alleman for AH 11/16/09 RYno :- 3.00 _ Complete Membership & Mail to M. Henry 11/19/09 Ryno 2.00 : - _ _ F/U and Review Membership with M. Henry 11/20/09 Ryno,00 F/U with Tom Alleman and AH Management 11/24/09 Ryno VFIS Insurance Issues & Kulpmont F/U 11/23/09 Ryno F/U with Joe Schmider & DOH at PFESI 11/26/09 R no Y - F Research Lease Options & F/U with Alleman 11/30/09 Ryno Coordinate Mtgs & F/U on outstanding issues t 4 h, r 1 yy ^ t j - w C ?? Y HI f-?- _- ?a_ Tota l Billable Hours 32.00 - I - - _ Billable Rates $ 95.00 $ 50.00 $ 25.00 Subtotal Billable Amount $ 3,040.00 $ - $ - TOTAL Billable Amount $ 3,040.00 Prepared by CornerstoneAdminisystems, Inc. Billable Time Classifications Number of Billable Hours Worked Date Task Senior Technical Admin PO Box 726 Cornerstone New Cumberland, PA 17070 P: 717.724.4157 - F: 717.214.6020 www.casys.com - bainor@casys.com American Hose Co Ambulance James Reed 203 S Poplar St Mt Carmel, PA 17851 American Hose Co Ambulance Consulting Project Period 10/1/09 -10/31/09 Senior Consultant Billable Hours Svc Date 10/31/2009 Invoice # 1103 Terms Due on Receipt 35 I 95.00 Per Hour 1 3,325.00 T Make check payable to Cornerstone Adminisystems, Inc. Include invoice number on check All major credit cards accepted ANEW (Ali charges will appear on your credit card statement as "Ambulance Transport") Card Number Name on Card Exp. Date Card Billing Address City, State, Zip Email, Phone Number Total $3,325.00 Payments/Credits $0.00 Balance Due $3,325.00 Thank you for Partnering with Cornerstone An Evolution in Ambulance Billing r' Cornerstone MWI]MIM Performed Performed By Consultant Assistance Assistance T-e rl., Ki.. -10/05/09 ?-10/07/09 Ryno R 2.Op? -T F/U on Membership &?Outstanding Items Ryno ; 2,00 Schedule Training and F/U items with Tom 10112/08 - ; Ryno3.001 Membership Program with Michael /Tom 10/13109 10/15/09 Ryno 4.00 Ryno 3 00- _ F/U Items and Kulpmont Ambulance / DOH DOH and Licensure Updates 10/16/09 Ryno ' 2,001 Insurance F/U and research with VFIS 10/19/09 Ryno ,gyp - _ F/U with American Hose and Tom Alleman 10/20/09 R Yno Letters for Insurance and various Vendors 10/22/09 10/23/09 10/26/09 10/28/09 Ryno Ryno Ryno Ryno F/U items and compile "to do" list for meeting Coordinate items with AH, SEEMS, DOH F/U on items from SEEMS planning meeting 'Membership planning and F/U items 10/29/09 Ryno VFIS letter of request and letters to Kulpmont Tota l Billable Hours 35.00 - _ Billable Rates $ 95.00 $ 50 #0 $ 25.00 Subtotal Billable Amount $ 3,325.00 $ - TOTAL Billable Amount $ 3.325.00 Prepared by Cornerstone Adminisystems, Inc. Billable Time Classifications Number of Billable Hours Worked Date Task Senior - Technical Admin PO Box 726 Cornerstone New Cumberland, PA 17070 P: 717.724.4157 - F: 717.214.6020 www.casys.com - balnor@casys.com American Hose Co Ambulance James Reed 203 S Poplar St Mt Carmel, PA 17851 American Hose Co Ambulance Consulting Project Period 9/1/09 - 9/30/09 Senior Consultant Billable Hours n i e Date 9/30/2009 Invoice # 1107 Terms Due on Receipt 49 I 95.00 Per Hour 1 4,655.00 Make check payable to Cornerstone Adminisystems, Inc. Include invoice number on check All major credit cards accepted". us is (All charges will appear on your credit card statement as "Ambulance Transport") Card Number Name on Card Exp. Date Card Billing Address City, State, Zip Email, Phone Number Total $4,655.00 Payments/Credits $0.00 Balance Due $4,655.00 Thank you for Partnering with Cornerstone An Evolution in Ambulance Billing rrrCornerstone Performed Performed By Consultant ASSiStAnro acci&-. r 09!01/09 Ryno 2.p - - Thea / Jimmy, finances / bills follow u p 09/02/09 Ryno 2.00 Jimmy and Regional Council follow 9 04/ up - _ 1 _ 0 9 R no Y 4.00, Review Financial Conference Cali --- 0 09/07/09 RYno 3 0 Membership Program Research / Quotations 09/08/09 Ryno 2.00 _ Follow Up Kulpmont ALS territory issues 09/09/09 Ryno 2.00 I FollowUp /Phone Calls Jimmy and Tom 09/14/09 Ryno $OQ # Follow Up on Kulpmont Issues / Membership 09/15/09 Ryno Follow Up Council / Jimmy / Tom / DOH 09/16/09 Ryno Press Release and Draft Letter to Thea 09/17/09 Ryno ; F Follow Up with Jimmy and Tom - Re: Thea 09/18/09 Ryno Follow Up with Regional Council and DOH 09/21/09 Ryno phone Calls with Jimm - R Att y e: orney 09/22/09 R no Draft and Review "to do" list with Tom 09/23/09 Ryno Follow Up with Jimmy and Kulpmont Amb 09/24/09 Ryno ,=r; . Updates and Follow Up with Tom and Jimmy 09/27/09 Ryno Ed O'Hearn /Kulpmont Follow Up Issues 09/28/09 no Tom Alleman work session for "to do" list 09/29/09 Ryno Follow Up with Kulpmont and DOH 09/30/09 Ryno Update Ambulance Licensure for AH - I .rY'yy to _ + Y/. 1. -a?-'S P 1 Tota l Billable Hours 49.00 - - Billable Rates $ 95.00 $ 50.00 $ 25.00 Subtotal Billable Amount $ 4,655.00 $ - $ - TOTAL Billable Amount $ 4.655.00 Prepared by Cornerstone Adminisystems, Inc. Billable Time Classifications Number of Billable Hours Worked Date Task Senior Technical Admin PO Box 726 Corner tone New Cumberland. PA 17070 ?? P: 717.724.4157 F: 717.214.6020 www.casys.com - balnor@casys.com American Hose Co Ambulance Thea Tafner c/o Creations by Carter 498 Elysburg Rd, Rte 54 Danville, PA 17821 American Hose Co Ambulance Consulting Project Period 8/1/09 - 8/31/09 Senior Consultant Billable Hours Technical Assistance Billable Hours T Make check payable to Cornerstone Adminisystems, Inc. Include invoice number on check All major credit cards accepted= 1)? (All charges will appear on your credit card statement as "Ambulance Transport") Card Number Name on Card Exp. Date Card Billing Address City, State, Zip Email, Phone Number Invoice Date 8/31/2009 Invoice # 1102 Terms Due on Receipt 51 95.00 Per Hour 4,845.00 3 50.00 Per Hour 150.00 Total $4,995.00 Payments/Credits $0.00 Balance Due $4,995.00 Thank you for Partnering with Cornerstone An Evolution in Ambulance Billing Cornerstone Performed Performed By Consultant Assistanra 08/03/09 --- asn VYCIVMW - rvotes Ryno 4:00; ^-- F/U v arious items and Kul t A b 08/04/09 08105/09 pmon m ulance Ryno mm 2 00 - - Kulpmont Meeting letter and Phone Calls 1 Ryno 3,00 F/U Employment and Tech Transport issues 08/06/09 08!07/09 - R no F/U and Draft Press Release for Council Ryno ;. 2.00 - - F/U with Thea and Kulmont Ambulanc 08/10/09 08/11/09 Ryno 3.00 Ryno z 100 e DOH F/U and coordinate with Tom Alleman ; - New System Development and related F/U 08/12/09 Ryno Ty Mtg with FD Tom Alleman and Thea 08/13/09 08/17/09 08/18/09 08/20/09 Ryno Ryno Ryno/Minnich Ryno I { ",- 3.Op , Review documents from Thea /Attorney F/U Mbship Review /Schedule Meetings & F/U Budget Mtg / Mbship and New System F/U Follow Up with Tom Alleman 08/25/09 R - ? " 08/28/09 08/31/09 yno ` Ryno Ryno s F/U with Council, Alleman, Jimmy /Thea Develop outstanding action item list & F/U s.? F/U on action items with Tom Alleman s K k yl. T 'nf ,r Tota l Billable Heurr l ?? 11r1 I ran I Billable Rates $ 95.00 $ 50.00 $ 25.00 Subtotal Billable Amount $ 4,845.00 $ 150.00 $ - TOTAL Billable Amount $ 4,995.00 Prepared by Cornerstone Adminisystems, Inc. Billable Time Classifications Number of Billable Hours Worked Date Task Senior Technical Admin PO Box 726 Cornerstone New Cumberland, PA 17070 P: 717.724.4157 - F: 717.214.6020 www.casys.com - balnor@casys.com American Hose Co Ambulance Thea Tafner c/o Creations by Carter 498 Elysburg Rd, Rte 54 Danville, PA 17821 American Hose Co Ambulance Consulting Project Period 7/1/09 - 7/31/09 Senior Consultant Billable Hours Technical Assistance Billable Hours T Make check payable to Cornerstone Adminisystems, Inc. Include invoice number on check All major credit cards accepted (All charges will appear on your credit card statement as "Ambulance Transport") Invoice Date 7/31/2009 Invoice # 1101 Terms Due on Receipt 64 95.00 Per Hour 1 6,080.00 8 1 50.001 Per Hour 1 400.00 Total $6,480.00 Payments/Credits $0.00 Balance Due $6,480.00 Card Number Name on Card Exp. Date Card Billing Address City, State, Zip Email, Phone Number Thank you for Partnering with Cornerstone An Evolution in Ambulance Billing r Cornerstone Performed Performed By Consultant Assistance Assistance Task Overview - Notes 07/01/09 Ryno -2.001" Tom Alleman and Medical Director F/U 07/02/09 j Ryno/Alnor 2.001 2.00 Prepare Financials and Info for Tom Alleman -- 07/03/091Ryno 2:00, T F/U with DOH, Tom Alleman and Thea ui/unua?l-cyno 3;001 Meeting with Thea and Tom Alleman 07/07/09 Ryno _ 0 - Document for DOH pre Conference Call 07/08/097, 2.00 Conference Call with DOH & Regional Council 07/08/09 Ryno/Morrison G.00 Prepare for DOH Licensure Inspection 07/09/09 Ryno 07/10109 Ryno : DOH/Regional Council Licensure Inspection F/U with DOH, Tom Alleman and Thea 07/13/09 Ryno 07/14/09 Ryno 07/15/09 Ryno t r =„ r DOH and Regional Council Follow Up Meet with Kevin Doran at Tech Transport 'Meet with Tom Alleman / Medical Direct r 07/16/09 Ryno , o Follow up with Tom Alleman and Thea 07/17/09 Ryno $.?p F/U and Conference Call Alleman / Minnich 07/19/09 Ryno 07/22/09 R no Y a` 2 00 1. - Letter of Understanding for AH and SEEMS --- Conference Call with Alleman and Minnich 07/23/09 Ryno 07/27/09 R no 07/28/09 Ryno 07/29/09 R no 07/30/09 RynoY yT ,= ; 00 " Conference Call x2 over LOU new system r ,rr?? x =< FU on items to establish new EMS system Mtgs Mt Carmel for FU & New System New System, Complaints, DOH, FU New System & Meeting in Mount Carmel Total Billable Hours 64.00 8.00 - Billable Rates $ 95.00 $ 50.00 $ 25.00 Subtotal Billable Amount $ 6,080.00 $ 400.00 $ - TOTAL Billable Amount $ 6,480.00 Prepared by Cornerstone Adminisystems, Inc. Billable Time Classifications Number of Billable Hours Worked Date Task Senior Technical Admin Cornerstone Ne Box 726 New Cumberland, PA 17070 P: 717.724.4157 - F: 717.214.6020 www.casys.com - balnor@casys.com American Hose Co Ambulance Thea Tafner c/o Creations by Carter 498 Elysburg Rd, Rte 54 Danville, PA 17821 American Hose Co Ambulance Consulting Project Period 6/1/09 - 6/30/09 invoice Date 6/30/2009 Invoice # 1100 Terms Due on Receipt Senior Consultant Billable Hours I 49 I 95.001 Per Hour I 4,655.00 Make check payable to Cornerstone Adminisystems, Inc. Total $4,655.00 Include invoice number on check All major credit cards accepted 10 Payments/Credits $0.00 (All charges will appear on your credit cord statement as "Ambulance Transport") Balance Due $4,655.00 Card Number Name on Card Exp. Date Card Billing Address City, State, Zip Email, Phone Number Thank you for Partnering with Cornerstone An Evolution in Ambulance Billing Cornerstone Performed Performed By Consultant Assistance Ascictanra T-1, rl..e...:..... ki..a.._ 06/02/09 Ryno 2,00 BLS hour change / Payroll / FU with Thea 06103/09 Ryno 'L2:00 FU with Schmider & Gibbons - DOH Issues 06/05/09 ? - ?_ - Geisinger - New Medical Director 06/09/09 R no 2:00 Y _ _ FU with Tom Alleman / Thea and Gibbons 06/09/09 R no Y Doran / Gibbons complaint to Council 06/10/09 r -_ - Ryno i'.2,00 ?- Meet Tom Alleman discuss a Plan B staffing 06/10/09 Ryno FU Complaint / Radio / DOH and Thea 06/11/09 Ryno Review Contract /Payroll / George Denke 06/12/09 Ryno Payroll Transfer/ FU various with Thea 06/15/09 Ryno f, Thea FU / Tech Transport email mtg request 06/16/09 Ryno ra "FU with Gibbons & DOH Issues 06/17/09 Ryno FU with Geisinger & Medical Command issue 06/18/09 Ryno 0 _ FU with Doran / Alleman and Thea 06/22/09 Ryno' Meeting with Dick Gibbons at Council Office 06/23/09 Ryno FU Gibbons / Payroll and Thea 06/24/09 Ryno Meeting with Doran / Fanella and Gibbons 06/25/09 R no FU with Thea / Payroll issues / Gibbons 06/26/09 Ryno Command FU and BLS analyzation 06/29/09 Ryno r ? ; ; r Complaint Issue from Regional Council 06/30/09 Ryno Meeting with Tom Alleman / Thea / EMMA 06/30109 Ryno Schmider / Gibbons -Complaint Issue(s) - - µx . -4 Tota l Billable Hours 49.00 _ Billable Rates $ 95.00 $ 50.00 $ 25.00 Subtotal Billable Amount $ 4,655.00 $ - $ - TOTAL Billable Amount $ 4,655.00 Prepared by Cornerstone Adminisystems, Inc. Billable Time Classifications Number of Billable Hours Worked Date Task -? Senior Technical Admin Cornerstone Ne Box 726 New Cumberland, PA 17070 P: 717.724.4157 - F: 717.214.6020 www.cas s.com - balnor@casys.com asys.com American Hose Co Ambulance Thea Tafner c/o Creations by Carter 498 Elysburg Rd, Rte 54 Danville, PA 17821 Invoice Date 5/31/2009 Invoice # 1098 Terms Due on Receipt American Hose Co Ambulance Consulting Project Period 5/1/09 - 5/31/09 Senior Consultant Billable Hours 22 95-001 Per Hour 2,090.00 T Make check payable to Cornerstone Adminisystems, Inc. Include invoice number on check All major credit cards accepted X WO IN (All charges will appear on your credit card statement as "Ambulance Transport") Card Number Name on Card Exp. Date Card Billing Address City, State, Zip Email, Phone Number Total $2,090.00 Payments/Credits $0.00 Balance Due $2,090.00 Thank you for Partnering with Cornerstone An Evolution in Ambulance Billing rrrCornerstone Billable Time Classifications -Number of Billable Hours Worked Date Task Senior Technical Admin Performed Performed By Consultant Assistance Assistanra Tx4 n,m. i-, _ nl. - 05/03/09 Ryno ,1.Op Medical Supply Review and Vendor Research - 05/04/09 Ryno ='1 .OD - - F/U with Kevin Doran via phone and e-mail L 05/05/09 05/06/09 1 Ryno Ryno 1.00; Review contract amendments from Tech E-mail and phone calls Kevin Doran & Thea 05/07/09 Ryno 1 Q0 Training & Operational Issues with Thea _05/07/09 Ryno ` 3.00 Letter coordination with Joe Schmider / The a 05/07/09 Ryno _ ... _ _ Review Joint Billing, etc with Kulpmont BLS 05/08/09 Ryno Review / comment e-mail Jim Reed/ Tech 05/11!09 Ryno Coordinate EMMA / DOH electronic transfer 05/11/09 Ryno F/U with Dick Gibbons & coordinate meeting 05/15/09 Ryno ' F/U with Thea and Tech Transport officials 05/18/09 Ryno Meeting coordination for Thea and D. Gibbons 05/20!09 Ryno Meet with Joe Schmider on Medical Director 05/26/09 05/28/09 Ryno Ryno F/U with Dick/Joe/Thea via e-mail & phone Dinner meeting with Dick Gibbons and Thea 05/29/09 Ryno k Medical Director and DOH follow up issues ?F k Tot al Billable Hours 22.00 - - _ _ Billable Rates $ 95.00 $ 50.00 $ 25.00 -Subtotal Billable Amount $ 2,090.00 $ - $ - TOTAL Billable Amount $ 2,090.00 Prepared by Cornerstone Adminisystems, Inc. ornerstone Box 726 New Cumberland, PA 17070 P: 717.724.4157 - F: 717.214.6020 www.casys.com - balnor@casys.com American Hose Co Ambulance Thea Tafner c/o Creations by Carter 498 Elysburg Rd, Rte 54 Danville, PA 17821 invoice Date 4/30/2009 Invoice # 1090 Terms Due on Receipt American Hose Co Ambulance Consulting Project Period 4/1/09 - 4/30/09 Senior Consultant Billable Hours 20 95.00 Per Hour 1,900.00 Technical Assistance Billable Hours 11 50.00 Per Hour 550.00 Make check payable to Cornerstone Adminisystems, Inc. Total $2,450.00 Include invoice number on check All major credit cards acceptedPayments/Credits $0.00 (All charges will appear on your credit cord statement as "Ambulance Transport") Balance Due $2,450.00 Card Number Name on Card Exp. Date Card Billing Address City, State, Zip Email, Phone Number Thank you for Partnering with Cornerstone An Evolution in Ambulance Billing r' Cornerstone Performed Performed By Consultant Assistance Assistance Task Overview- Notes 04/02/09 Ryno 2.00; Conference Call with Thea and various a-mails vv rvivvuny wun r\GVm wren a DLO supervisor -- ? ^ no/Alnor 3 04/08/091R , ! 1.00 _ Draft letter to DOH and fallow up with Kevin Y ? _ 04109/09 Ryno/Alnor 2.00 1.00' L Complete DOH letter, meet Thea & deliver 04116/09 Ryno 3.00 Meeting at CAS with Thea, Ranee & Tom 0 04/24/09 Ryno 1. Conference Call with DOH 04/24/09 Morrison 9,00 Trip Log Comparison (Dispatch vs. CAS Billed) 04/29/09 Ryno k a _ Follow up / review issues with Regional Council 04/30/09 Ryno Follow up /discuss new plan with DOH officials 0. - - ?y.. F4- f _ I ea syt Kk LH l' ` x , _Y To_tal_Billable Hours 20.00 11.00 - _ Billable Rates $ 95.00 $ 50.00 $ 25.00 Subtotal Billable Amount $1,900.00 $ 550.00 $ - TOTAL Billable Amount $ 2,450.00 Prepared by Cornerstone Adminisystems, Inc. Billable Time Classifications Number of Billable Hours Worked Date Task Senior Technical Admin PO Box 726 Cornerstone New Cumberland, PA 17070 P: 717.724.4157 - F: 717.214.6020 www.casys.com - balnor@casys.com American Hose Co Ambulance Thea Tafner c/o Creations by Carter 498 Elysburg Rd, Rte 54 Danville, PA 17821 mice Date 3/31/2009 Invoice # 1089 Terms Due on Receipt American Hose Co Ambulance Consulting Project Period 3/1/09 - 3/31/09 Senior Consultant Billable Hours 7 95.00 Per Hour 665.00 Technical Assistance Billable Hours 0.5 50.00 Per Hour 25.00 T Make check payable to Cornerstone Adminisystems Inc , . Include invoice number on check Total $690.00 All major credit cards accepted All h Payments/Credits $0 00 ( c arges will appear on your credit card statement as Ambulance Transport) . Balance Due $690.00 Card Number Name on Card Exp. Date Card Billing Address City, State, Zip Email, Phone Number Thank you for Partnering with Cornerstone An Evolution in Ambulance Billing rrr. Cornerstone Date Task Performed Performed Billable Time Classifications Number of Billable Hours Worked Senior Technical Admin Consultant Assistance Assistance Task Overview - Notes 03/17/09 Ryno/Alnor 2.0 0 0.50 Draft Letter to Tech Transport, F/U with Thea 03/18/09 R no Itip le Phone Cal & Kevin OL l 1 03122/09 ? - M{ DO re a at on for TecthTrawort o 03/23 03/23/09 Ryno -2.00 Mtg with Tech Transport - Kevin Doran < yy _ Total Billable Hours 7.00 0.50 - Billable Rates $ 95.00 $ 50.00 $ 25.00 Subtotal Billable Amount $ 665.00 $ 25.00 $ - TOTAL Billable Amount $ 690.00 Prepared by Cornerstone Adminisystems, Inc. VERIFICATION I, THOMAS N. MINNICH, Vice-President of Plaintiff Cornerstone Adminisystems, Inc., above-named, being duly sworn according to law, deposes that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief. The undersigned understands that the statements made therein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date: 3 0?3 I THOMAS N. MINNICH Vice-President ,1 HUMMEL &LEWIS, LLP Michael B. Smith, Esquire I.D. No. 207158 3 East Fifth Street Bloomsburg, PA 17815 ~570~784-7516 Attorney for Defendant IN THE COURT OF COMMON PLEAS OF THE 9T" JUDICIAL DISTRICT CUMBERLAND COUNTY, PENNSYLVANIA CORNERSTONE ADMINISYSTEMS, INC PLAINTIFF, VS. AMERICAN HOSE & CHEMICAL FIRE COMPANY, DEFENDANT CIVIL ACTION -LAW NO. 10-2200 ~ T ;e p _.-E ` : c cn ____~ .;. -~ _,. y ~ . .y ' ~ : ~; ~ ~ ^ r~ ~ :=C ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of the Defendant, American Hose & Chemical Fire Company, and direct all further correspondence in this matter to me at the address indicated above. LAW OFFICES HUMMEL &LEWIS, LLP DATE: MAY 4, 2010 / ~d~~~ ,~ ,l' \ MICHAEL B. SMITH, SQUIlZE ATTORNEY FOR DEFENDANT i .~ IN THE COURT OF COMMON PLEAS OF THE 9T" JUDICIAL DISTRICT CUMBERLAND COUNTY, PENNSYLVANIA CORNERSTONE ADMIMSYSTEMS, INC. CNIL ACTION -LAW PLAINTIFF, VS. : NO. 10-2200 AMERICAN HOSE & CHEMICAL FIRE COMPANY, DEFENDANT. CERTIFICATE OF SERVICE I, MICHAEL B. SMITH, ESQUIRE, do hereby certify that I served a true and correct copy of the attached document in the above-captioned matter by first class mail, postage prepaid, on the 4th day of May, 2010, upon the following individuals: Craig A. Diehl, Esquire 3464 Trindle Road Camp Hill, PA 17011 LAW OFFICES HUMMEL & LEWIS, LLP ~ ~a N~P~ MICHAEL B. SMITH, ESQUIRE ATTORNEY FOR DEFENDANT SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~~„~tititr of ~irfrfl+rr/~at@ t ~~,FF.;~ ~~ rr._ >~~~I~~ ~(` .r i~ T'....,' r . ? `f t ~-?~ ~a/t_ ! %~ Cornerstone Adminisystems, Inc. vs. Case Number American Hose & Chemical Fire Company (et al.) 2010-2200 SHERIFF'S RETURN OF SERVICE 06/07/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Thea Tafner, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Northumberland County, PA to serve the within Complaint and Notice according to law. 06/29/2010 Northumberland County Return: And now June 29, 2010 at 1530 hours I, Chad A. Reiner, Sheriff of Northumberland County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Thea Tafner by making known unto herself personally, at The Northumberland County Sheriffs Office, 201 Market Street, Sunbury, PA 17801 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.44 July 06, 2010 SO ANSWERS, ~,_._ RON ~R ANDERSON, SHERIFF ,ci CouniySuite Sheriff. Te!eosuft. In.^ SHERIFF'S OFFICE OF NORTHUMBERLAND COUNTY Chad A Reiner '~`` " `-" Ton Matulewicz Es Y q ~- Sheriff `""'~.~- `-, =' ~ Solicitor . ._ ~ ~ "~ ~ ~ Randy Coe . , ~~~ ; ~~` Chief Deputy - , +,i,== CORNERSTONE ADMINISYSTEMS, INC. Case Number vs. AMERICAN HOSE & CHEMICAL FIRE COMPANY (et al.) 10 CV 02200 SHERIFF'S RETURN OF SERVICE 06/29/2010 03:30 PM -SERVED THE REQUESTED CIVIL ACTION BY "PERSONALLY" HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE THE DEFENDANT, TO WIT: THEA TAFNER AT THE NORTHUMBERLAND COUNTY SHERIFF'S OFFICE, 201 MARKET ST., SUNBURY, PA 17801 BY: CHAUNDY, BERNADETTE SHERIFF COST: $52.00 SO ANSWERS, ~~,r July 01, 2010 CHAD A REINER, SHERIFF nd ~ubsctibed before ~~~ ,~ . J "d"l _ _~, S. ~~ ~~-,<.e . ~~_~ 2014 Mil c~tnm. ~`~~.1st Mon. Jan. Craig A. Diehl, Esquire I.D. No. 52801 LAW OFFICES OF CRAIG 3464 Trindle Road Camp Hill, PA 17011 Attorney for Plaintiff, Corner CORNERSTONE ADM INC., v. AMERICAN HOSE & C FIRE COMPANY, ,. DIEHL Adminisystems, Inc. 2Q 10 JJ_ i ~ ~s I ~ ~ 1 cur:~~~ - '~ ~~~~~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ~1ISYSTEMS, Plaintiff NO. 10-2200 Civil Term 3EMICAL Defendant CIVIL ACTION -LAW 'S NEW MATTER AND NOW COMES Law Offices of Craig ~ 10. Denied. pleading is required. 11. Denied. pleading is required. 12. Denied. pleading is required. 'laintiff, Cornerstone Adminisystems, Inc., by and through its counsel, Diehl, answering the pleadings as follows: NEW MATTER The averment contains a conclusion of law to which no responsive The averment contains a conclusion of law to which no responsive The averment contains a conclusion of law to which no responsive 13. Denied. pleading is required. 14. Admitted. 15. Denied. Tafner. 16. Denied. I 17. Denied. pleading is required. 18. Denied. pleading is required. 19. Denied. information sufficient to 20. Denied. ' Tafner. 21. Denied. pleading is required. 22. Denied. prejudicial averment and 23. Denied. pleading is required. 24. 25. averment contains a conclusion of law to which no responsive transactions were entered into by the Chairman of Defendant, Thea )efendant did receive reports reflecting the outstanding cash advances. The averment contains a conclusion of law to which no responsive The averment contains a conclusion of law to which no responsive After reasonable investigation, Plaintiff is without knowledge or form a belief as to the truth of the averment. ['he transactions were entered into by the Chairman of Defendant, Thea The averment contains a conclusion of law to which no responsive Plaintiff has no idea what Defendant is even suggesting by this strict proof thereof is demanded at trial. The averment contains a conclusion of law to which no responsive COUNTERCLAIM Denied. o responsive pleading is required. 26. 27. Denied. withheld by Corner; Adminisystems, Inc. m~ WHEREFORE, entered in favor of Fire Company, and for s' 28. Four Thousand Six Huns Hose & Chemical Fire Company. 29. A the same amount. 's President, James Reed was fully aware of the monies being one Adminisystems, Inc. A representative from Cornerstone in person with James Reed on several occasions regarding this issue. 'ornerstone Adminisystems, Inc. respectfully requests that judgment be erstone Adminisystems, Inc. and against American Hose & Chemical ch other relief this Court deems just and reasonable. NEW MATTER TO COUNTERCLAIM ne Adminisystems, Inc. admits that it has withheld the sum of Thirty- fired Ninety-Five Dollars and Ninety Cents ($34,695.90) from American Company with full knowledge of American Hose & Chemical Fire pion case docketed with this Court at No. 10-2199 also seeks an offset of 30. Only one offset of Thirty-Four Thousand Six Hundred Ninety-Five Dollars and Ninety Cents ($34,695. 0) should be granted in this proceeding and should not be duplicated in the companion case doc eted at 10-2199. Respectfully submitted, LAW OFFICES OF CRAIG A. DIEHL Date: By. r Craig iehl, Esquire Attorney I.D. No. 52801 3464 Trindle Road Camp Hill, PA 17011 Tel: (717) 763-7613 Fax: (717) 763-8293 Attorney for Plaintiff V~ItIFICATION z, Thomas 'Vice President of Plaintiff, Cornerstone Adtninisystems, Inc., above- named, being duly sworn according to law, deposes that the facts set forth in the foregoing Plaintiffs Answer ~ to Defendant's New Ma#er and counterclaim with New Matter to Counterclaim are t~te and correct to the best of my knowledge, information, and belief, The undersigned under ands that the statements made therein are made subject to the penalties of 1 S Fa. C.S. §4904 rely ' g to unsworn falsification to authoi7ties, r Date: vl O'l01 homes Minnick, ice President Cornerstone Adminisystems, Ina. CERTIFICATE OF SERVICE AND NOW, the /~ ~ day of July, 2010, the undersigned hereby certifies that a true and correct copy f the foregoing Plaintiff's Answer to Defendant's New Matter and Counterclaim with New Matter to Counterclaim was served upon the opposing party by way of United States first class ail, postage prepaid, addressed as follows: Michael B. Smith, Esquire Hummel & Lewis, LLP 3 East Fifth Street Bloomsburg, PA 17815 e A. Fike, Legal Secretary Laurence C. Kress Attorney and Counselor at Law PA Bar No. 93137 P.O. Box 247 Duncannon, PA 17020 (717) 834-4137 Counsel for Thea Tafner FILED-OFFICE OF THE PROTHONOTARY 1011 APR - I AM 8: 4 5 CUMBERLANDAN COUNTY IN THE COURT OF COMMON PLEAS FOR THE 9th JUDICIAL DISTRICT CUMBERLAND COUNTY, PENNSYLVANIA CORNERSTONE ADMINISYSTEMS, INC., Plaintiff, V. AMERICAN HOSE & CHEMICAL FIRE COMPANY, Defendant, V. THEA TAFNER, Additional Defendant. Docket No. 10-2200 Civil Term CIVIL ACTION -LAW JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of Laurence C. Kress, Esquire, as counsel for the Defendant, Thea Tafner, in the above-captioned case. Respectfully submitted, Date: Laurence C. Kress, Esquire CERTIFICATE OF SERVICE I hereby certify that on the date set forth below, I served a copy of the foregoing Praecipe for Entry of Appearance via l st class mail, postage pre-paid upon the following: Craig A. Diehl, Esquire LAW OFFICES OF CRAIG A. DIEHL 3464 Trindle Road Camp Hill, PA 17011 Counsel for Cornerstone Adminisystems, Inc. Michael B. Smith, Esquire HUMMEL & LEWIS, LLP 3 East Fifth Street Bloomsburg, PA 17815 Counsel for American Hose & Chemical Fire Company Date: I' / ,, ..,_, '- . /,I(. -- L urence C. Kress, Esquire Laurence C. Kress Attorney and Counselor at Law PA Bar No. 93137 P.O. Box 247 Duncannon, PA 17020 (717) 834-41.37 Counsel for Thea Tafner 09- r ye! pR-CFPICE 2011 APR + r?C' 10 r4 Cat S l 41f 8: N/A IN THE COURT OF COMMON PLEAS FOR THE 9`h JUDICIAL DISTRICT CUMBERLAND COUNTY, PENNSYLVANIA CORNERSTONE ADMINISYSTEMS, INC., Plaintiff, V. AMERICAN HOSE & CHEMICAL FIRE COMPANY, Defendant, V. THEA TAFNER, Additional Defendant. Docket No. 10-2200 Civil Term CIVIL ACTION -LAW JURY TRIAL DEMANDED DEFENDANT THEA TAFNER'S ANSWER TO DEFENDANT AMERICAN HOSE & CHEMICAL FIRE COMPANY'S COMPLAINT AGAINST HER AS ADDITIONAL DEFENDANT AND NOW comes the Defendant, Thea Tafner, by and through her counsel, Laurence C. Kress, Esquire, and answers Defendant American Hose & Chemical Fire Company's Complaint Against her as Additional Defendant as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Averment sets forth Defendant American Hose's asserted conclusion of law to which no response is required. 6. Averment states a conclusion of law to which no answer is required. 7. Admitted in part and denied in part. It is admitted that Additional Defendant Tafner served as Defendant American Hose's Chairperson of the Ambulance Committee during the specified period. After reasonable investigation, Additional Defendant Tafner is without information sufficient to form a belief as to the truth of the averment that she had unfettered control over Defendant American Hose's financial affairs during that time. Strict proof thereof is demanded. 8. Averment states a conclusion of law to which no answer is required. 9. Averment states a conclusion of law to which no answer is required. 10. Admitted in part and denied in part. It is admitted that Additional Defendant Tafner converted funds for her personal use during her tenure as Chairperson of the Ambulance Committee. After reasonable investigation, Additional Defendant Tafner is without information sufficient to form a belief as to the truth of the averment that the conversion of funds resulted in Defendant American Hose being unable to meet its financial obligations. Strict proof thereof is demanded. 11. Averment states a conclusion of law to which no answer is required. 12. Denied. Additional Defendant Tafner never received any invoices from Plaintiff Cornerstone. Further, if any such invoices were mailed, such invoices were addressed to Additional Defendant Tafner in her capacity as Chairperson. Further, some of the alleged invoices attached to Plaintiff Cornerstone's Complaint as Exhibit A were addressed to Defendant American Hose to the attention of its president, James Reed. 2 13. Averment states a conclusion of law to which no answer is required. 14. Averment states a conclusion of law to which no answer is required. WHEREFORE, Additional Defendant Tafner respectfully demands: A. Judgment in her favor and against Defendant American Hose; B. Judgment that, if there is any liability to Plaintiff Cornerstone, Defendant American Hose is solely liable to Plaintiff Cornerstone; C. In the event that Plaintiff Cornerstone obtains a judgment against Defendant American Hose, that Additional Defendant Tafner is not liable to Defendant American Hose by way of indemnification and/or contribution for the amount recovered by Plaintiff Cornerstone against Defendant American Hose; D. Costs and attorney's fees; and E. Any other appropriate relief as determined by the Court. NEW MATTER 15. Additional Defendant Tafner engaged Plaintiff Cornerstone to perform certain consulting services. 16. At all relevant times, Additional Defendant Tafner acted in her capacity as Chairperson of the Ambulance Committee. 17. Additional Defendant Tafner had authority to engage Plaintiff Cornerstone to perform consulting services on behalf of Defendant American Hose. 18. Defendant American Hose, and specifically its president, James Reed, was well aware that Plaintiff Cornerstone was performing consulting services for the company. 19. In response to inquiries from Additional Defendant Tafner as to its rates for consulting services, Plaintiff Cornerstone told her "not to worry about it," and that "it would be worked out later." No such information was provided to Additional Defendant Tafner until she received the Complaint against her. 20. It is believed, and therefore averred, that Defendant American Hose continued to utilize the consulting services of Plaintiff Cornerstone after Additional Defendant Tafner's termination as Chairperson. 21. Additional Defendant Tafner asserts the defense of waiver. 22. Defendant American Hose has failed to mitigate its damages. 23. Defendant American Hose's Complaint against Additional Defendant Tafner fails to state a claim upon which relief can be granted. 24. If Additional Defendant Tafner is liable to Defendant American Hose, any judgment must be reduced by the amount paid by Additional Defendant Tafner to Defendant American Hose as restitution pursuant to a criminal judgment. WHEREFORE, Additional Defendant Tafner respectfully demands: A. Judgment in her favor and against Defendant American Hose; B. Judgment that, if there is any liability to Plaintiff Cornerstone, Defendant American Hose is solely liable to Plaintiff Cornerstone; C. In the event that Plaintiff Cornerstone obtains a judgment against Defendant American Hose, that Additional Defendant Tafner is not liable to Defendant American Hose by way of indemnification and/or contribution for the amount recovered by Plaintiff Cornerstone against Defendant American Hose; D. Costs and attorney's fees; and 4 E. Any other appropriate relief as determined by the Court. Respectfully submitted, C. 14?-e _ 1-4 ence C. Kress, Esquire Counsel for Thea Tafner Dated: . Mar 31 11 04:02p Wetzel Notary Services 5702756521 p.1 VERIFICATION I hereby verify that the information contained in the foregoing Answer is true and correct to the best of my knowledge. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification. CIZ, Qj?-? Date: '3 3 1 Thea Tafner 6 CERTIFICATE OF SERVICE I hereby certify that on the date set forth below, I served the foregoing Answer via 1 St Class United States mail, postage pre-paid upon the following: Craig A. Diehl, Esquire LAW OFFICES OF CRAIG A. DIEHL 3464 Trindle Road Camp Hill, PA 17011 Counsel for Cornerstone Adminisystems Michael B. Smith, Esquire HUMMEL & LEWIS, LLP 3 East Fifth Street Bloomsburg, PA 17815 Counsel for American Hose & Chemical Fire Company Date: / Laurence C. Kress, Esquire 7 HUMMEL & LEWIS, LLP Michael B. Smith, Esquire 2%.11 F? j Fs I 7 I.D. No. 207158 3 East Fifth Street CUMBERLAND CMIT Y Bloomsburg, PA 17815 PENNSYLVANIA (57) 784-7516 Attorney for Defendant IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT CUMBERLAND COUNTY, PENNSYLVANIA CORNERSTONE ADMINISYSTEMS, INC. CIVIL ACTION - LAW PLAINTIFF, VS. NO. 10-2200 AMERICAN HOSE & CHEMICAL FIRE COMPANY, DEFENDANT, JURY TRIAL DEMANDED VS. THEA TAFNER, ADDITIONAL DEFENDANT. DEFENDANT'S REPLY TO ADDITIONAL DEFENDANT'S NEW MATTER Defendant, by its attorney, Michael B. Smith of Hummel & Lewis, LLP, files this Reply to Additional Defendant's New Matter as follows: 15. Additional Defendant Tafner engaged Plaintiff Cornerstone to perform certain consulting services. ANSWER: It is denied that Additional Defendant Tafner engaged Plaintiff Cornerstone to perform certain consulting services. In further answer thereto, Additional Defendant Tafner received no permission from Defendant American Hose and had no authority to do so. In further answer thereto, any alleged consulting services performed by Plaintiff Cornerstone were performed because the Plaintiff had a financial interest in the success of Defendant American 1 Hose as Plaintiff Cornerstone received a share of Defendant American Hose's revenue. 16. At all relevant times, Additional Defendant Tafner acted in her capacity as Chairperson of the Ambulance Committee. ANSWER: It is denied that at all relevant times, Additional Defendant Tafner acted in her capacity as Chairperson of the Ambulance Committee. 17. Additional Defendant Tafner had authority to engage Plaintiff Cornerstone to perform consulting services on behalf of Defendant American Hose. ANSWER: The allegation of the preceding paragraph is a conclusion of law to which no response is required. To the extent a response is required, it is denied that Additional Defendant Tafner had authority to engage Plaintiff Cornerstone to perform consulting services on behalf of Defendant American Hose. In further answer thereto, Additional Defendant Tafner only had authority to bind Defendant American Hose after discussing the venture at a meeting and receiving approval by vote, which she did not do in this circumstance. In further answer thereto, Plaintiff Cornerstone knew that Additional Defendant Tafner had no authority to bind Defendant American Hose relative to the consulting services. 18. Defendant American Hose, and specifically its president, James Reed, was well aware that Plaintiff Cornerstone was performing consulting services for the company. ANSWER: It is denied that Defendant American Hose, and specifically its president, James Reed, was well aware that Plaintiff Cornerstone was performing consulting services for the company. 19. In response to inquiries from Additional Defendant Tafner as to its rates for consulting services, Plaintiff Cornerstone told her "not to worry about it," and that "it would be worked out later." No such information was provided to Additional Defendant Tafner until she received the Complaint against her. ANSWER: Defendant American Hose cannot admit or deny the allegations of the 2 preceding paragraph because, after reasonable investigation, Defendant is unable to determine the truth or falsity of the statements. 20. It is believed, and therefore averred, that Defendant American Hose continued to utilize the consulting services of Plaintiff Cornerstone after Additional Defendant Tafner's termination as Chairperson. ANSWER: It is denied that Defendant American Hose continued to utilize the consulting services of Plaintiff Cornerstone after Additional Defendant Tafner's termination as Chairperson. In further answer thereto, Defendant American Hose denies any agreement with Plaintiff to provide consulting services for a fee. 21. Additional Defendant Tafner asserts the defense of waiver. ANSWER: The preceding allegation is a conclusion of law to which no response is required. 22. Defendant American Hose has failed to mitigate its damages. ANSWER: The preceding allegation is a conclusion of law to which no response is required. 23. Defendant American Hose's Complaint against Additional Defendant Tafner fails to state a claim upon which relief can be granted. ANSWER: The preceding allegation is a conclusion of law to which no response is required. 24. If Additional Defendant Tafner is liable to Defendant American Hose, any judgment must be reduced by the amount paid by Additional Defendant Tafner to Defendant American Hose as restitution pursuant to a criminal judgment. ANSWER: The preceding allegation is a conclusion of law to which no response is required. In further answer thereto, Defendant American Hose has other creditors seeking 3 payment because of the acts of Additional Defendant Tafner. Defendant American Hose will use all monies received as restitution from Additional Defendant Tafner to pay its creditors. Therefore, any reduction should be proportionate to the amount for which Defendant American Hose is liable to Cornerstone relative to the total amount Defendant American Hose is responsible to all creditors on account of Additional Defendant Tafner's actions. LAW OFFICES HUMMEL & LEWIS, LLP DATE: APRIL 26, 2011 MICHAEL B. SMITH, ESQUIRE ATTORNEY FOR DEFENDANT 4 VERIFICATION I, James Reed, President of American Hose & Chemical Fire Company, being vested with full authority to make this Verification, do hereby verify that the facts set forth in the foregoing document are true and correct to the best of my personal knowledge, information, and belief I further understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsifications to authorities. AESED IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT CUMBERLAND COUNTY, PENNSYLVANIA CORNERSTONE ADMINISYSTEMS, INC. CIVIL ACTION - LAW PLAINTIFF, VS. NO. 10-2200 AMERICAN HOSE & CHEMICAL FIRE COMPANY, DEFENDANT, : JURY TRIAL DEMANDED VS. THEA TAFNER, ADDITIONAL DEFENDANT. CERTIFICATE OF SERVICE I, MICHAEL B. SMITH, ESQUIRE, do hereby certify that I served a true and correct copy of Defendant's Reply to Additional Defendant's New Matter in the above-captioned matter by first class mail, postage prepaid, on the 26th day of April, 2011, upon the following individuals: Craig A. Diehl, Esquire Laurence C. Kress, Esquire 3464 Trindle Road P. 0. Box 247 Camp Hill, PA 17011 Duncannon, PA 17020 Attorney for Plaintiff Attorney for Additional Defendant LAW OFFICES HUMMEL & LEWIS, LLP P ,v, 4 5?.. MICHAEL B. SMITH, ESQUIRE ATTORNEY FOR DEFENDANT T ?• L,L HUMMEL & LEWIS, LLP A[E Michael B. Smith, Esquire n 0 11 A r, 2 7 F M I: 4 7 I.D. No. 207158 c ?" 3 East Fifth Street CUMBERLAND COUNITY Bloomsburg, PA 17815 PENNSYLVANIA (570) 784-7516 Attorney for Defendant IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT CUMBERLAND COUNTY, PENNSYLVANIA CORNERSTONE ADMINISYSTEMS, INC. CIVIL ACTION - LAW PLAINTIFF, VS. NO. 10-2200 AMERICAN HOSE & CHEMICAL FIRE COMPANY, DEFENDANT, : JURY TRIAL DEMANDED VS. THEA TAFNER, ADDITIONAL DEFENDANT. DEFENDANT'S REPLY TO PLAINTIFF'S NEW MATTER TO COUNTERCLAIM Defendant, by its attorney, Michael B. Smith of Hummel & Lewis, LLP, files this Reply to Plaintiff's New Matter to Counterclaim as follows: 27. Cornerstone Adminisytems, Inc. admits that it has withheld the sum of Thirty-Four Thousand Six Hundred Ninety-Five Dollars and Ninety Cents ($34,695.90) from American Hose & Chemical Fire Company with full knowledge of American Hose & Chemical Fire Company. REPLY: Admitted. 28. A companion case docketed with this Court at No. 10-2199 also seeks an offset of the same amount. REPLY: Admitted. 29. Only one offset of Thirty-Four Thousand Six Hundred Ninety-Five Dollars and Ninety Cents ($34,695.90) should be granted in this proceeding and should not be duplicated in 1 the companion case docketed at 10-2199. REPLY: Admitted. DATE: APRIL 26, 2011 LAW OFFICES HUMMEL & LEWIS, LLP MICHAEL B. SMITH, ESQUIRE ATTORNEY FOR DEFENDANT 2 i VERIFICATION I, James Reed, President of American Hose & Chemical Fire Company, being vested with full authority to make this Verification, do hereby verify that the facts set forth in the foregoing document are true and correct to the best of my personal knowledge, information, and belief. I further understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsifications to authorities. JAMES REED IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT CUMBERLAND COUNTY, PENNSYLVANIA CORNERSTONE ADMINISYSTEMS, INC. PLAINTIFF, VS. AMERICAN HOSE & CHEMICAL FIRE COMPANY, DEFENDANT, VS. THEA TAFNER, ADDITIONAL DEFENDANT CIVIL ACTION - LAW NO. 10-2200 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, MICHAEL B. SMITH, ESQUIRE, do hereby certify that I served a true and correct copy of Defendant's Reply to Plaintiff's New Matter to Counterclaim in the above-captioned matter by first class mail, postage prepaid, on the 26th day of April, 2011, upon the following individuals: Craig A. Diehl, Esquire Laurence C. Kress, Esquire 3464 Trindle Road P. O. Box 247 Camp Hill, PA 17011 Duncannon, PA 17020 Attorney for Plaintiff Attorney for Additional Defendant LAW OFFICES HUMMEL & LEWIS, LLP MICHAEL B. SMITH, ESQUIRE ATTORNEY FOR DEFENDANT Craig A. Diehl, Esquire I.D. No. 52801 LAW OFFICES OF CRAIG A. DIEHL 3464 Trindle Road Camp Hill, PA 17011 Attorney for Plaintiff, Cornerstone Adminisystems, Inc. / , e ,A1 -7 0 - i • CORNERSTONE ADMINISYSTEMS, : IN THE COURT OF COMMON PLEAS OF INC., : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 10-2200 Civil Term AMERICAN HOSE & CHEMICAL FIRE COMPANY, THEA TAFNER, To the Prothonotary: Date: Defendant : CIVIL ACTION — LAW V. Additional Defendant : PRAECIPE TO SETTLE AND DISCONTINUE Kindly mark the above -captioned proceeding as settled and discontinued. By: Respectfully submitted, LAW OFFICES OF CRAIG A. DIEHL Craig A. viehl, Esquire Attorney I.D. No. 52801 3464 Trindle Road Camp Hill, PA 17011 Tel: (717) 763-7613 Fax: (717) 763-8293 Attorney for Plaintiff CERTIFICATE OF SERVICE AND NOW, the /Lo day of June, 2014, the undersigned hereby certifies that a true and correct copy of the foregoing Praecipe to Discontinue was served upon the opposing parties by way of United States first class mail, postage prepaid, addressed as follows: Michael B. Smith, Esquire Hummel & Lewis, LLP 3 East Fifth Street Bloomsburg, PA 17815 Laurence C. Kress, Esquire P.O. Box 247 Duncannon, PA 17020 kOAJ,_<_ a .2J_,__ Debra A. Fike, Legal Secretary