HomeMy WebLinkAbout11-0818A 't
Scott A. Dietterick, Esquire
Supreme Court I.D. #55650
Kimberly A. Bonner, Esquire
Supreme Court I.D. #89705
James, Smith, Dietterick & Connelly, LLP
PO Box 650
Hershey, PA 17033
(717) 533-3280
(717) 533-2795
Attorneys for Plaintiff
SURGICAL CARE AFFILIATES,
LLC, T/D/B/A GRANDVIEW
SURGERY & LASER CENTER,
PLAINTIFF
V.
LORI A. SISCO,
DEFENDANT
OF TNT FF° ? ONO TAR
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2011 JAN 24 PH 3: 4R
r?OMB-Er? LANG COL114TY
PC_fA4NSYLVmyIL II i
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA
. NO. C?CIVIL ACTION - LAW
NOTICE TO DEFEND
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 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
f-fd • OD ?oC affy
cc? 3?sy
?.?y 7 ?-
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 S. Bedford Street
Carlisle, PA 17013
(800) 990-9108
SURGICAL CARE AFFILIATES,
LLC, T/D/B/A GRANDVIEW
SURGERY & LASER CENTER,
PLAINTIFF
V.
LORI A. SISCO,
DEFENDANT
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA
. NO.
CIVIL ACTION - LAW
AVISO
USTED HA SIDO DEMONDADO/A EN CORTE. Si usted desea defenderse de las
demandas que se presentan mas adelante en las siguientes paginas, debe tomar
accion dentro do los proximos veinte (20) dias despues de la notifacacion de esta
Demanda y Aviso radicando personalmente o por medio de un abogado una
comperencencia escrita y redicanco en la Courte por escrito sus defensas de, y
objecciones a, los 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 0 propieded u
otros derechos importantes para usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABAGADO IMMEDIATAMENTE.
SI USTED NO TIENE UN ABOGADO 0 NO PUEDE PAGARLE A UNO, LLAME A
VAYA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR
ASISTENCIA LEGAL.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(800) 990-9108
Scott A. Dietterick, Esquire
Supreme Court I.D. #55650
Kimberly A. Bonner, Esquire
Supreme Court I.D. #89705
James, Smith, Dietterick & Connelly, LLP
PO Box 650
Hershey, PA 17033
(717) 533-3280
(717) 533-2795
Attorneys for Plaintiff
SURGICAL CARE AFFILIATES,
LLC, T/D/B/A GRANDVIEW
SURGERY & LASER CENTER,
PLAINTIFF
V.
LORI A. SISCO,
DEFENDANT
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA
: NO.
: CIVIL ACTION -LAW
COMPLAINT
The Plaintiff, Surgical Care Affiliates, LLC, t/d/b/a Grandview Surgery & Laser
Center, by its attorneys, James, Smith, Dietterick & Connelly, LLP, hereby presents the
following Complaint against the Defendant, Lori A. Sisco, as follows:
1. Plaintiff, Surgical Care Affiliates, LLC, t/d/b/a Grandview Surgery & Laser
Center (hereinafter referred to as "Grandview"), is an Alabama corporation, registered to
do business in Pennsylvania, with its office located at 205 Grandview Avenue, Camp
Hill, Cumberland County, Pennsylvania 17011.
2. Defendant, Lori A. Sisco, is an adult individual, with her last known
address at 1003 Walnut Street, Lemoyne, Cumberland County, Pennsylvania
17043.
COUNT I
BREACH OF CONTRACT
3. Grandview incorporates Paragraphs 1 through 2 as if fully reproduced
herein.
4. Grandview is a facility that performs same-day out-patient surgery to
patients who desire same.
5. On January 4, 2010, Defendant arrived at Grandview for a left shoulder
arthroscopy rotator cuff repair.
6. When Defendant arrived at Grandview, it was confirmed that Defendant
had health insurance through TriCare North (HealthNet).
7. Defendant signed Grandview's Financial Agreement, Assignment of
Benefits and Release of Records prior to her surgery. A copy of this Agreement is
attached hereto and identified as Exhibit "A."
8. Grandview submitted its bill for services rendered, totaling $7,123.90 to
Defendant's insurance company on or about January 5, 2010.
9. On or about March 4, 2010, Grandview received a notice from
Defendant's insurance company that the claim was not being paid as the Defendant did
not submit the necessary liability form to her insurance company in order for the
insurance company to process the claim and pay Grandview.
10. On March 4, 2010, Grandview contacted Defendant and left a message
stating that Defendant needed to contact her insurance company regarding the non-
payment of her claim.
11. According to the terms of Grandview's Financial Agreement, if accounts
are forwarded for further collection efforts, Grandview is entitled to collection fees
totaling 30% of the unpaid balance.
12. Collection fees incurred by Grandview total $2,137.17.
13. Defendant has continuously refused to make payment to Grandview for
the balance due and otherwise ignored Plaintiffs demands for payment of same.
WHEREFORE, Plaintiff, Surgical Care Affiliates, LLC, t/b/d/a Grandview Surgery
& Laser Center, demands judgment against Defendant Lori A. Sisco, in an amount not
in excess of $50,000.00, which amount requires submission of this matter to
compulsory arbitration.
COUNT II
UNJUST ENRICHMENT
14. Grandview incorporates Paragraphs 1 through 13 as is fully reproduced
herein.
15. Grandview provided Defendant with medical services, as requested by
Defendant, totaling $7,123.90; Grandview having done so to the benefit of Defendant;
Defendant became liable for the just and reasonable amount of the surgery.
16. Defendant has been unjustly enriched by accepting the service of
Grandview and not paying the total amount due for same.
17. Grandview has demanded that Defendant pay the total amount due of
$9,261.07, but Defendant has refused to do so.
WHEREFORE, Plaintiff, Surgical Care Affiliates, LLC, t/b/d/a Grandview Surgery
& Laser Center, demands judgment against Defendant Lori A. Sisco, in an amount not
in excess of $50,000.00, which amount requires submission of this matter to
compulsory arbitration.
RESPECTFULLY SUBMITTED,
JAMES, S ITH, rIE ERICK & CO ELLY, LLP X BY:
Scott A. Dietterick, Esquire
Supreme Court I.D. #55650
Kimberly A. Bonner, Esquire
Supreme Court I.D# 89705
James, Smith, Dietterick & Connelly, LLP
PO Box 650/1-lershey, PA 17033
(717) 533-3280
(717) 533-2795 fax
Attorneys for Plaintiff
DATE: January 24, 2011
Surgical Care Affiliates
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DATE TIME IN LAST NAME FIRSTNAME MI DEPOSIT I ATTACHMENT CI
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00 CASU
.
a DOS AGE MSW HOME PHONE RIDE'PHONE NEED TO CALL WILL BE HERE
F 12/28/64 49 M 717-512-7419
ADDRESS STREET on COUNTY STA - ZIP
1003 WALNUT ST LEMOYNE PA 17043
PRIOR ADMrr SSN -7 RIVER LICENSE O CUPRTK3N WORK PHONE
207-54-5605
RESPONSIBLE PARTY NAME AND ADDRESS IF DIFFERENT FROM ABOVE
SELF
RELATION TO RESPONSIBLE PARTY RESPONSIBLE PARTY SSN RESPONSIBLE PARTY EMPLOYER RESPONSIBLE PARTY PHONE
S
SAME
SELF
PRIMARY INSURANCE COMPANY NAMEMAME OF INSURED SECONDARY INSURANCE COMPANY NAMElNAME OF INSURED
TRICARE NORTH (HEALTHNET) - SISCO, RICKY
PO,BOX 870140
SURFSIDE BEACH, SC 29587
I.D. 9/SSN GROUP # AUTHORIZATION I.D. #/SSNI GROUP # AUTHORIZATION
175485463 2 0934542657 i
tNSURED'S EMPLOYER AND PHONE INSURED'S EMPLOYER AND PHONE
SURGEON
RAYMOND
DOi I CLAIM#
ATTENTION
DIAGNOSIS
(1) LEFT SHOULDER ARTHROSCOPY WITH MINI OPEN ROTATOR CUFF REPAIR AND ACROMIOPLASTY L.
FINANCIAL AGREEMENT, ASSIGNMENT OF BENEFITS AND RELEASE OF RECORD(S)
I hereby assign to and authorize payment directly to the facility named above (the "facility") of all benefits due me under Medicare, Medicaid, or any insurance policy
providing benefits for facility charges, for services rendered by the facility and anesthesia provider as designated.
A photostatic copy of this agreement shall be considered effective and valid as the original.
I irrevocably agree that the facility may disclose, to the extent allowed by law, my medical and financial record to (a) any affiliate of the facility. specifically including
Surgical Care Affiliates and Its employees and agents, Including entities under contract with same to provide quality and/or utilization review; (b) any person or entity
which may be liable under contract or by law to the facility or to me, or any person or entity responsible for all or pan of the facility's charges, specifically including any
insurance company or their agents or employees; (c) any person or entity to whom I have been referred by the facility or by my physician for corrtinued care; (co any
physician treating, consulting or otherwise performing services for me, including his or her employees and agents; (e) the Centers for Medicare and Medicaid Services,
any other governmental or accrediting agency, or their agents or employees.
All facility charges are due and owing at discharge. In consideration of the services to be rendered, to the extent not expressly prohibited by law or by the contract
between the facility and my third party payor, I HEREBY AGREE, WHETHER I AM SIGNING AS PATIENT OR GUARANTOR, TO PAY ALL SUMS DUE THE FACILITY AT
THE bSUAL AND CUSTOMARY CHARGE OF THE FACILITY. I hereby waive all claims of exemption. Should the account be referred to an attorney or collection agency
for collection, I shag pay reasonable attomeys fees and collection expenses whether suit is filed or not. Delinquent accounts and amounts (those not paid within 60
days from the date of service) may bear interest on the unpaid amount up to the maximum amount allowed by law. i understand that I em financially responsible for
charges not paid vMthm said 60 days and for charges not covered by this assignment I understand that the facility Pies for reimbursement from my insurer or other
payor as a courtesy, and failure on the part of the insurer to make payment shall not relieve me of my obligation to pay the facility,
t certify that i am the patient or that I am financially responsible forthe services rendered and do hereby unconditionally guaranty the payment of all amounts when and as due.
Facility employees are NOT able to define your insurance coverage. if you have coverage questions, you are advised to cag your insurance carrier.
CAUTION: DO NOT SIGN THIS AGREEMENT UNLESS YOU UNDERSTAND ITS CONTENTS.
DATE
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WITNESS "Y DATE
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Patient Name and Arrival Time
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SURGICAL CARE AFFILIATES, : IN THE COURT OF COMMON PLEAS
LLC, T/D/B/A GRANDVIEW : CUMBERLAND COUNTY, PENNA
SURGERY & LASER CENTER,
PLAINTIFF .
V. NO.
LORI A. SISCO, .
DEFENDANT CIVIL ACTION - LAW
VERIFICATION
I, Shelly Sollazzi, Office Manager, of Surgical Care Affiliates, LLC,
t/d/b/a Grandview & Laser Center, hereby verify the facts contained in the foregoing
Complaint are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein are subject to the penalties of 18 Pa.C.S.A.
§4904 relating to unsworn falsification to authorities.
DATE: 1 ?? l ?? I
l ?
FILED-0 = FI
-r nnitio
I MAR - I PH 2: It 4
Scott A. Dietterick, Esquire
Supreme Court I.D. #55650
Kimberly A. Bonner, Esquire
Supreme Court I.D. #89705
James, Smith, Dietterick & Connelly, LLP
PO Box 650
Hershey, PA 17033
(717) 533-3280
(717) 533-2795
Attorneys for Plaintiff
SURGICAL CARE AFFILIATES,
LLC, T/D/B/A GRANDVIEW
SURGERY & LASER CENTER,
PLAINTIFF
V.
LORI A. SISCO,
DEFENDANT
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA
: NO. 11-818-CIVIL
: CIVIL ACTION -LAW
IMPORTANT NOTICE
TO: Lori A. Sisco
1003 Walnut Street
Lemoyne, PA 17043
DATE OF NOTICE: February 28, 2011
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 (10) 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 NOTICE TO YOUR LAWYER AT
ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
A
TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET
LEGAL HELP.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(800) 990-9108
1
SURGICAL CARE AFFILIATES,
LLC, T/D/B/A GRANDVIEW
SURGERY & LASER CENTER,
PLAINTIFF
V.
LORI A. SISCO,
DEFENDANT
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA
NO. 11-818-CIVIL
: CIVIL ACTION -LAW
AVISO IMPORTANTE
A. Lori A. Sisco
1003 Walnut Street
Lemoyne, PA 17043
FECHA DEL AVISO: February 28, 2011
USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION
REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE
LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR
UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE
PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE
LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO
TIENTE UN ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICINA
ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA
LEGAL.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(800) 990-9108
JAMES SMITH DIETTERICK & CONNELLY LLP
DATE: F (./l1
ewruary 28, 211 BY:
Kimberly A. Bonner, Esquire
Attorneys for Plaintiff
FILED-OFFICE
OF THE PROTHONOTARY
2011 MAR 22 AM 9: 00
Scott A. Dietterick, Esquire
Supreme Court I.D. #55650
Kimberly A. Bonner, Esquire
Supreme Court I.D. #89705
James, Smith, Dietterick & Connelly, LLP
PO Box 650
Hershey, PA 17033
(717) 533-3280
(717) 533-2795
Attorneys for Plaintiff
SURGICAL CARE AFFILIATES,
LLC, T/D/B/A GRANDVIEW
SURGERY & LASER CENTER,
PLAINTIFF
V.
LORI A. SISCO,
DEFENDANT
TO THE PROTHONOTARY:
CUMBERLAND COUNTY
PENNSYLVANIA
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA
NO. 11-818-CIVIL
CIVIL ACTION - LAW
PRAECIPE
KINDLY ENTER JUDGMENT in favor of the Plaintiff and against the Defendant,
Lori A. Sisco, in the amount of $9,261.07, plus interest at the legal rate of 6% and costs
of suit for failure to answer an properly endorsed complaint. The 10-Day Notice was
filed with the Court and mailed to the Defendant on March 1, 2011.
DATE: March 22, 2011
)Qa 4111 c,1, a N9 /S e,,""U r
6'# 1-13f I
;FQ9 S1 -7
JAMES, SMITH, TERICK & CONNELLY, LLP
By:
Kimb y A. Bonner, Esqul
SURGICAL CARE AFFILIATES,
LLC, T/D/B/A GRANDVIEW
SURGERY & LASER CENTER,
PLAINTIFF
V.
LORI A. SISCO,
DEFENDANT
TO: LORI A. SISCO, DEFENDANT
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA
NO. 11-818-CIVIL
CIVIL ACTION -LAW
You are hereby notified that on March 22, 2011, judgment has been entered
against you in the above-captioned case in the amount of $9,261.07, plus interest at the
legal rate of six (6%) percent, plus costs of suit.
DATE: March 22, 2011 `
Prothonotary
I hereby certify that the following is the address of the Defendant stated in th
Certificate of Residence:
Lori A. Sisco
1003 Walnut Street
Lemoyne, PA 17043
TO: LORI A. SISCO, DEFENDANT
Por este medio se le esta notificando que el March 22, 2011, el siguiente Fallo
ha sido antode en contra suya en el case mecianado en el epigrafe.
FECHA: March 22, 2011
Prothonotario
Certifico que la siguiente direccion es la del defendido/a segun indicada en el
certificado de residencia:
Lori A. Sisco
1003 Walnut Street
Lemoyne, PA 17043
SURGICAL CARE AFFILIATES,
LLC, T/D/B/A GRANDVIEW
SURGERY & LASER CENTER,
PLAINTIFF
V.
LORI A. SISCO,
DEFENDANT
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA
NO. 11-818-CIVIL
CIVIL ACTION - LAW
CERTIFICATE OF RESIDENCE
I hereby certify that the addresses of the parties in the above-captioned action
are as follows:
Surgical Care Affiliates, LLC,
t/d/b/a Grandview Surgery & Laser Center
205 Grandview Avenue
Camp Hill, PA 17011
Plaintiff
Lori A. Sisco
1003 Walnut Street
Lemoyne, PA 17043
Defendant
JAMES, SMITH, DIETTERICK & CONNELLY, LLP
BY:
Denise L. Foster, Paralegal
E
Surgical Care Affiliates, LLC,
t/d/b/a Grandview Surgery
& Laser Center,
Plaintiff
V.
Lori A. Sisco,
Defendant
IA -
C
T
File No. 64
Amount Due $9,261.07
Interest at legal rate of 6% from
3122/2010 - @ $1.52 per day c?
Attorney's Comm.
Costs
TO THE PROTHONOTARY OF THE SAID COURT:
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The undersigned hereby certifies that the below does not arise out of a retail installment
sale, contract, or account based on a confession of judgment, but if it does, it is based on the
appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real
property pursuant to Act 6 of 1974 as amended.
PREACIPE FOR EXECUTION
Issue write of attachment to the Sheriff of CUMBERLAND County, for debt, interest and
costs, as above, directing attachment against the above-named garnishee(s) for the following
property (if real estate, supply six copies of description; supply four copies of lengthy personalty
list)
LEVY ON ALL PERSONAL PROPERTY, INCLUDING FURNITURE, APPLIANCES,
TELEVISIONS VCR'S, DVD PLAYERS, ENTERTAINMENT EQUIPMENT, JEWELRY,
COMPUTERS, ETC., LOCATED AT:
1003 WALNUT STREET, LEMOYNE, PA 17043
and all other property for the defendant(s) in the possession, custody or control of
the said garnishee(s).
(Indicate) Index this writ against the garnishee(s 97,? nsagainst real
estate of the defendant(s) described in the attached exhibit.
DATE: March 22, 2011 Signature:
?y Print Name: Kimberly A. Bonner, Esquire
James, Smith, Dietterick & Connelly, LLP
P// dal/ eW Address: PO Box 650, Hershey, PA 17033
At c?a, ft/ Telephone: (717) 533-3280
0 9a 1,v Supreme Court I.D.#89705
4 /q G6; Attorney for Plaintiff
17S 3I/
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 11-818 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due SURGICAL CARE AFFILIATES, LLC T/DB/A
GRANDVIEW SURGERY & LASER CENTER Plaintiff (s)
From LORI A. SISCO AT 1003 WALNUT STREET, LEMOYNE, PA 17043
(1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON ALL
PERSONAL PROPERTY, INCLUDING FURNITURE, APPLIANCES, TELEVISIONS,
VCR'S, DVD PLAYERS, ENTERTAINMENT EQUIPMENT, JEWELRY, COMPUTERS,
ETC., LOCATED AT 1003 WALNUT STREET, LEMOYNE, PA 17043.
(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 $9,261.07
L.L. $.50
Interest AT LEGAL RATE OF 6% FROM 3/22/2010- @ $1.52 PER DAY
Atty's Comm %
Atty Paid $53.75
Plaintiff Paid
Due Prothy $2.00
Other Costs
Date: 3/22/11
(Seal)
REQUESTING PARTY:
Name KIMBERLY A. BONNER, ESQUIRE
124.4 ?- -1? ?? A# 11? a -
David D. Buell, Prothonotary
?yf
Deputy
Address: JAMES, SMITH, DIETTERICK & CONNELLY, LLP
PO BOX 650, HERSHEY, PA 17033
Attorney for: PLAINTIFF
Telephone: 717533-3280
Supreme Court ID No. 89705
Scott A. Dietterick, Esquire
Supreme Court I.D. #55650
Kimberly A. Bonner, Esquire
Supreme Court I.D. #89705
James, Smith, Dietterick & Connelly, LLP
PO Box 650
Hershey, PA 17033
(717) 533-3280
(717) 533-2795
Attorneys for Plaintiff
SURGICAL CARE AFFILIATES,
LLC, T/D/B/A GRANDVIEW
SURGERY & LASER CENTER,
PLAINTIFF
V.
LORI A. SISCO,
DEFENDANT
f. t
Ai
? !I Auc -9 Am ,
CUMSERLA,k?D vU?Jr3
PF NNSYL.VA*"ri( h
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA
: NO. 11-818-CIVIL
: CIVIL ACTION - LAW
PRAECIPE TO AMEND WRIT OF EXECUTION
TO THE PROTHONOTARY:
KINDLY AMEND the Writ of Execution, originally filed on March 22, 2011, to an
amount due and owing of $630.50.
JAMES, SMITH, DIETT ICK & CONNELLY, LLP
By:
Kimberly A. Bonner, Esquire
DATE: August 9, 2011
AMr-_N"DED
WRIT OF EXECLI'1'14)N ::end/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 11-818 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due SURGICAL CARE AFFILIATES, LLC T/D/B/A
GRANDVIEW SURGERY & LASER CENTER Plaintiff (s)
From LORI A. SISCO AT 1003 WALNUT STREET, LEMOYNE, PA 17043
(1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON ALL
PERSONAL PROPERTY, INCLUDING FURNITURE, APPLIANCES, TELEVISIONS,
VCR'S, DVD PLAYERS, ENTERTAINMENT EQUIPMENT, JEWELRY, COMPUTERS,
ETC., LOCATED AT 1003 WALNUT STREET, LEMOYNE, PA 17043.
(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 $ 030.50
L.L. $.50
Interest AT LEGAL RATE OF 6% FROM 3/22/2010- @ $1.52 PER DAY
Atty's Comm %
Atty Paid $53.75
Plaintiff Paid
Date: 3/22/11
(Seal)
REQUESTING PARTY:
Due Prothy $2.00
Other Costs
David D. Buell, Prothonotary
Deputy
Name KIMBERLY A. BONNER, ESQUIRE
Address: JAMES, SMITH, DIETTERICK & CONNELLY, LLP
PO BOX 650, HERSHEY, PA 17033
Attorney for: PLAINTIFF
Telephone: 717533-3280
Supreme Court ID No. 89705
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
ay R Anderson
arlff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
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2-1l7 FEB -7 AH 8: 6't,
PENNSYLVAiM\
Surgical Care Affiliates, LLC
vs. Case Number
Lori A. Sisco 2011-818
SHERIFF'S RETURN OF SERVICE
03/31/2011 06:10 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on
March 31, 2011 at 1810 hours, she served a true copy of the within writ of execution, upon the defendant,
to wit: Lori A. Sisco, by making known unto Lori A. Sisco, at 1003 Walnut Street, Lemoyne, Cumberland
County, Pennsylvania 17043 its contents and at the some time handing to her personally the said true and
correct copy of the same. Upon serving the writ of execution, a levy was completed. Postcard and copy
of levy mailed to attorney and letter mailed to defendant on 04-06-11.
05/1312011 05:50 PM - Sale bill posted on 05-12-11 at 1748 hours by Deputy Michelle Gutshall. Sale date set for
Wednesday, June 8, 2011 at 1500 hours. Copy of sale bill mailed to Attorney Bonner.
06/09/2011 Property sale scheduled for 06-08-11 postponed per request of plaintiffs attorney.
08/15/2011 05:45 PM - Deputy Robert Bitner, being duly sworn according to law, states service was performed by
posting a true copy of the sale notice.
08/16/2011 Sheriffs sale scheduled for August 24, 2011 at 3:00 p.m.
08/1812011 Property sale scheduled for 08-24-11 postponed per request of plaintiffs attorney.
11/04/2011 04:56 PM - Deputy Amanda Cobaugh, being duly sworn according to law, states service was performed
by posting a true copy of the sale notice.
02/06/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ of execution is
returned STAYED per request of plaintiffs attorney.
SHERIFF COST: $200.00 SO ANSWERS,
February 06, 2012 RON R -ANDERSON, SHERIFF
{c1 CountyS cite Shen`:(. Te'0QS0ft- U1c.
iAte&a707s%
Scott A. Dietterick, Esquire
Supreme Court I.D. #55650
Kimberly A. Bonner, Esquire
Supreme Court I.D. #89705
James, Smith, Dietterick & Connelly, LLP
PO Box 650
Hershey, PA 17033
(717) 533-3280
(717) 533-2795
Attorneys for Plaintiff
SURGICAL CARE AFFILIATES,
LLC, T/D/B/A GRANDVIEW
SURGERY & LASER CENTER,
PLAINTIFF
V.
LORI-A. SISCO,
DEFENDANT
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA
: NO. 11-818-CIVIL
: CIVIL ACTION -LAW
PRAECIPE TO SATISFY, SETTLE & DISCONTINUE
TO THE PROTHONOTARY:
KINDLY ENTER the above-captioned matter as Satisfied, Settled and
Discontinued.
JAMES, SMITH, DIETTERICK & CONNELLY, LLP
By:
Kimberly A. Bonner, Esquire
DATE: February 3, 2012