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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 ?" rA„ 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 n..4:,,_. mrtr:?.i. 'q nn t t ii• _t d ?-,,nt :fl- 177R5 DATE TIME IN LAST NAME FIRSTNAME MI DEPOSIT I ATTACHMENT CI 0 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 L4 o WITNESS "Y DATE &p JP-'()4 - `>p? ? Patient Name and Arrival Time ,s F= ? DATE LU a 1IVD3131V1S-11V 2008 Sts vardw 2 t 0 $C 1:WSr.iV2L01 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: c -?3 zrn snp v? b? N p a N iv 3 O 0 -urn moo, C3 Cl --i -c 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 $2.00 Other Costs David D. Buell, Prothonotary Deputy Name KIMBERLY A. BONNER, ESQUIRE Address: JAMES, SMITH, DIETTERICK & CONNELLY, LLP PO BOX 650, HERSHEY, PA 17033 Attorney for: PLAINTIFF Telephone: 717533-3280 Supreme Court ID No. 89705 I;-- ufion armed Ac t. q, a0l, SHERIFF'S OFFICE OF CUMBERLAND COUNTY ay R Anderson arlff Jody S Smith Chief Deputy Richard W Stewart Solicitor ?pttt?4?' s71 is a ?t#$t'?.f??? 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 ..? rv < c. , to •- : 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