HomeMy WebLinkAbout11-8122
L 771
i
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 fax
Attorneys for Plaintiff
i1 t,t
H.B. MCCLURE COMPANY, : IN THE COURT OF COMMON PLEAS
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. /? g?ao- 4 Uf L /G/m
FOX SUBACUTE AT CLARA BURKE, :
DEFENDANT : 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
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
?l 9aAO Pd
41 F
,? x6636 ?j
H.B. MCCLURE COMPANY, : IN THE COURT OF COMMON PLEAS
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO.
FOX SUBACUTE AT CLARA BURKE, :
DEFENDANT : 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. Listed puede perder dinero O propieded u
otros derechos importantes para usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABAGADO IMMEDIATAMENTE.
SI USTED NO TIENE UN ABOGADO O 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 fax
Attorneys for Plaintiff
H.B. MCCLURE COMPANY, : IN THE COURT OF COMMON PLEAS
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO.
FOX SUBACUTE AT CLARA BURKE, :
DEFENDANT : CIVIL ACTION -LAW
COMPLAINT
The Plaintiff, H.B. McClure Company, by its attorneys, James, Smith, Dietterick &
Connelly, LLP, hereby presents the following Complaint against the Defendant, Fox
Subacute At Clara Baurk, as follows:
1. Plaintiff, H.B. McClure Company, is a Pennsylvania corporation, with its
corporate office located at 600 South 17th Street, Harrisburg, Dauphin County,
Pennsylvania 17104.
2. Defendant, Fox Subacute At Clara Burke, is a Pennsylvania corporation,
with its corporate office located at 251 Stenton Avenue, Plymouth Meeting, Montgomery
County, Pennsylvania and a local office located at 121 S. Filbert Street, Mechanicsburg,
Cumberland County, Pennsylvania 17055.
COUNT I
BREACH OF CONTRACT
3. H.B. McClure incorporates Paragraphs 1 through 2 as if fully reproduced
herein.
4. On April 27, 2009, Plaintiff and Defendant entered into a Preventive
Maintenance Agreement (hereinafter referred to as "Agreement"), for service work to be
done at the Filbert Street property. A true and correct copy of the Agreement is
attached hereto and identified as Exhibit "A."
5. In accordance with the terms of the Agreement, Defendant was to be filled
a total of $4,250.00 to be paid for in four quarterly payments, of $1,062.50, plus tax,
each quarter.
6. On or about August 14, 2009, Plaintiff submitted an invoice to Defendant
for worked performed at the Filbert Street property on July 31, 2009 and August 19,
2009. The total amount billed was $1,583.29. A copy of the invoice is attached hereto
and identified as Exhibit "B."
7. On or about August 17, 2009, Plaintiff submitted an invoice to Defendant
for worked performed at the Filbert Street property for work on August 10, August 11
and August 13, 2009. The total amount billed was $1,315.08. A copy of the invoice
is attached and identified as Exhibit "C."
8. On or about August 19, 2009, Plaintiff submitted an invoice to Defendant
for worked performed at the Filbert Street property for work on August 14, 2009. The
total amount billed was $1,255.00. A copy of the invoice is attached and identified as
Exhibit "D."
9. On or about August 20, 2009, Plaintiff submitted an invoice to Defendant
for worked performed at the Filbert Street property for work on August 19, 2009. The
total amount billed was $216.00. A copy of the invoice is attached and identified as
Exhibit "E."
10. On or about August 28, 2009, Plaintiff submitted an invoice to Defendant
for worked performed at the Filbert Street property for work on August 26, 2009. The
total amount billed was $688.08. A copy of the invoice is attached and identified as
Exhibit "F."
11. On or about September 10, 2009, Plaintiff submitted an invoice to
Defendant for the quarterly billing statement on the Agreement. The total amount billed
was $1,126.25. A copy of this invoice is attached and identified as Exhibit "G."
12. On or about December 11, 2009, Plaintiff submitted an invoice to
Defendant for the quarterly billing statement on the Agreement. The total amount billed
was $1,126.25. A copy of this invoice is attached and identified as Exhibit "H."
13. The current amount due for the outstanding balances owed for the
Preventative Agreement and unpaid invoices total $7,309.95.
14. According to the terms of Preventive Maintenance Agreement and the
invoices for work performed by Plaintiff signed by the Defendant, if accounts are
forwarded for further collection efforts, H.B. McClure is entitled to attorney and collection
fees.
15. Collection fees incurred by H.B. McClure total $1,341.50.
16. The current outstanding balance on Defendant's account with H.B.
McClure is $8,651.45.
17. Defendant has continuously refused to make payment to H.B. McClure of
the balance due and otherwise ignored Plaintiffs demands for payment of same.
WHEREFORE, Plaintiff, H.B. McClure Company, demands judgment
against Defendant Fox Subacute At Clara Burke, in an amount not in excess of
$50,000.00, which amount requires submission of this matter to compulsory arbitration.
COUNT II
UNJUST ENRICHMENT
18. H.B. McClure incorporates Paragraphs 1 through 17 as is fully reproduced
herein.
19. Plaintiff performed work, at the request of the Defendant, to the benefit of
Defendant and Defendant became liable for the just and reasonable amount of work
performed.
20. Defendant has been unjustly enriched by accepting the labor and products
and not paying the total amount due for same.
21. Plaintiff has demanded that Defendant pay the total amount due of
$8,651.45, but Defendant as refused to do so.
WHEREFORE, Plaintiff, H.B. McClure Company, demands judgment against
Defendant Fox Subacute At Clara Burke, in an amount not in excess of $50,000.00,
which amount requires submission of this matter to compulsory arbitration.
RESPECTFULLY SUBMITTED,
JAMES, SMITH, RICK & CONNELL/Y, LLP
J
BY:
Scott A. Die erick, 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 fax
Attorneys for Plaintiff
Date: October 24, 2011
Page 9 0l' 9
Fox Subacute
121 S Filbert Street
Mechanicsburg, Pas 17055
April 27, 2009
Attn: Bill Haig
Re: Preventive Maintenance
Quote #.37017
TO ACCEPT THE AGREEMENT, PLEASE SELECT THE SERVICE OPTION(S) DESIReb,
TOTAL THE ANNUAL AMOUNT, SELECT THE PAYMENT TERMS, THEN SIGN ANb
RETURN ONE COPY TO OUR OFFICE. YOU WILL BE INVOICED AT A LATER DATE:
(Annual) Two complete Inspections for; $4,250.00 per year
? Optional Anti-Bactedal condensate pan treatment t'or: ADd $250.00 per year
Total Annual Agreement Amount;
$ /-/ Z? a .
Tax, Ir appllcabaa, wlil bo addod at limo of Involro
Please check in -Payment option. you will he Invoiced at a later date
Annual Agreement
? One annual payment
? Two semi-annual payments
amour quarterly payments
We thank you for the opportunity.to submit this agreement. If you have any questions please
feel free to contact us. '
ACCEPTANCE OF THIS,AGREEMENI`: the above prices, (plus applicable sales tax),
specifications and conditions are satisfactory and are hereby accepted. H. B. McClure is
authorized to do the work as speclfled,
Date of Acceptance: 2- /10
'l?'??GL`"'?'1ii.
Signature;
Purchase Order #
Need a payment plan or a seivice option not listed in this agreement? Please call Matt
Mundy at (797) 214-3156.
2/2'd 0ZLRt722L14T6:0l 626L828M 31n3uens xoj:Woad LT:£T 6002-K-MW
Page 8 of 9
Only the equipment and services descrlbed herein shall be Included In this'program, Equipment
repairs, either recommended or required, shall be discussed with you before any work is started
and will be performed only upoh your approval. Maintenance agreement holders receive d labor
discount for HVAC and plumbing repairs performed on o time and material basis, Quoted work
will be calculated at the preferred customer rate,
Scheduled maintenance will be performed during normal business hours unless otherwise
specified, We reserve the right; with prior approval from customer, to schedule maintenance Eo
be performed outside normal business hours when necessary. The client Is to provide
reasonable means of access. W.B. McClure must be free to start and stop all primary
equipment that Is part of the mechanical system(s) covered,
H.S. McClure Company extends a ninety-day warranty on labor for both routine maintenance
and for service repairs, unless quoted otherwise. Parts are also warranted for ninety days,
unless a manufacturer extended warranty applies. Our main underlying policy is one of fairness
to our customers, and this guides our approach not only to warranty situations but also to all of
our practices.
H.B. McClure will not be liable for failure of any piece of equipment due to fire, flood, freezing,
misuse, negligence, Improper: voltages or voltage surges. We will also not be responsible for
failure to furnish material or 4ervice due to fire, flood, strike. lockout, dispute with workman,
inability to obtain material, war, act of God or any cause beyond reasonable control, A49, rithibt
??' _ f81
Gpq -AMPWs. McClure will not be liable for failure of equipment R the systems are serviced or
altered in any way by others, aqalanclf air distribution is not. Included in this agreement.
Gur Terms Are; Total due WO by toOrwayw ? after invoice date, Amounts past due are subject to a
finance charge of 1,5% per month (18% annually). The cost of collection, Including attorney
fees will be the responsibility of the debtor.
In addition to the rice set forth, the client will be liable for an
p any present or future taxes or any
other government charges Imposed by existing or future laws with respect to the equipment to
which this schedule relates. H.B. McClure Co. reserves the right to change published hourly
labor rates without prior written notification,
Please accept this agreement as notification of cancellation or any existing or pending
agreement(s). This agreement is void if not accepted within thirty days of your receipt,
Updates to the contract or cancellation of the contract, by elthe' party, may be made with thlrty
days' written notice.
i
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2i2'd BULb22L11TS:01 626L828M 31n0bens xoj;wojd LI:zt 6oo2-bT-Auw
HA mcclure
?
Since1914 n n
P.O. Box 1745, Harrisburg, Pennsylvania 17105-1745
Service (717) 232-HEAT (4328) s PAX (717) 234.3730
Federal I.D. #23-0855020 ® http://www.hbmccIure.com
i ACCCLJNT N±,MBEl
i
57-125
FOX SUBACUTE
120 S FILBERT STREET
ME C HAN I C S BU RG , PA
17055
?I
t)Al t f ?M LET_ - -
8/14/2009
--SERVICES RENDERED AT----
Approved by- SMG/BIL HAIG 16:18 7/30/2009 PO Number-
------- ITEM_DES_C_RIPTO_N___ AMOUNT 1
REP LACED MOTOR 7.
2 MOTOR 865.98
2 RAINSHIELD 38-34
1 FAN BLADE 343.98
2 3/8" ROMEX CONN_ (NEER C 1.99;
04TE
I
SMG 7/31/200
SMG? 7/31/200
SKB? 7/31/200
SMGI 8/13/200
i
Phase pay
of receipt
TOTA
_ _ P'APTS
HOURS- - -- ------ RATE
1:00
1:30
1:30
1:00
Hrs:Mi M
Hrs:Mi- M
Hrs:Mi H
Hx-s : Mi M
TO7, AL
-ABOR
within 10 DAYS
of this invoice
PAS'
T
4 PLEASE DETACH HEERE AND RETURN BOTTOM POI? FION WiT?i PAY'I/iENT- -
RE M 17- T
H. ?i)n
ip ?'7
•
383278
Subtotal
Tax
Total
•
383278
'?M
FOX SUBACUTE -?
r 9?s RYl?'_ _' 57-125
i
1,583- 29 ?
Questions about this invoice should be directed to Service Bi11inQ
h'b' "IelUre 600 S. 17th St., P.O. Box 1745, Harrisburg, PA 1 7 1 05-1 745
Service (717) 232-HEAT (4328) . FAX (717) 214-3264
company Federal I.D. # 23-0855020. http://www.hbmcclure.com
AXSince1914
PARTS SERVICE TICKET INFORMATION
001 FAN BLADE MTL5BL CONTRACT TICKET#: 383278-S138
002 3/8" ROMEX CONN. [NEER C SERVICE CONTRACT 57-125
NORMAL ACCT#:
PLUMBING
RES PO#:
COMM PHONE: (000)
CUSTOMER INFORMATION
BILL TO: FOX SUBACUTE
120 S FILBERT STREET
MECHANICSBURG, PA 17055
WORK @:
1
ORIGINATION OF CALL
PROBLEM: 57 FOLLOW-UP REPAIR
DATE: 7/30/2009 BY: SMG/BIL HAIG
EQUIPMENT INFORMATION
CHCNDI ROOF
MCQAU V CONDE APD--0P`-,0 . V .1 2 4-QA0006' -ma
+ TECH '_J?TC 121 Hf-'CC-.MII\. ? SMG 6 Pi o ff,JU CA'? ' c r, 4q,s ;? r?r
-'OMP
I _ I
?- WORK DONE
I ALREADY HAD THE MOTOR MOUNTED FROM A PREVIOUS DATE. WIRED MOTOR AND CHE
CKED ROTATION. INSTALLED NEW FAN BLADE. REASSEMBLED FAN GAURD AND CHECKED
MOTOR AMPS(3). JOB IS COMPLETE.
REFRIG QTY CHANGED OUT (OR
YES NO PARTS WARRANTY
RECOVERED QTY REPLACED) All parts as recorded are warranted as per
RECLAIMED QTY
DISMANTLED
YES NO
manufacture's specifications
RE-USED QTY
REFRIGERANT DISPOSAL
LABOR WARRANTY
NOT-USED QTY The labor required as recorded here relative to
DISPOSAL
QTY the equipment serviced as noted, is guaranteed
for a period of 90 days We do not guarantee
Itheundersignedowner/authorizedrepresentativeofthe
property at which the work above is to be done, have authorized you to perform the diagnosis and/or repair
The parts other than those we supplied If repairs
,
materials required, rendered and installed have been completed in a satisfactory manner and I acknowledge receipt of my copy. Terms are net 30 days for credit later become necessary
as a result of other
approved accounts. Amounts not paid in accordance are subject to finance charge of 1.5% per month, 18% annually. Cost of collection,. including attorney and/or filing
fees will be the res
onsibilit
r
of the debt defective parts, they will be charged separately.
p
y
o DATE
X
.. ??C'?? ? S. 17th St., P.O. Box 1745, Harrisburg, PA 17105-1745
h600
Service (717) 232-HEAT (1328) . FAX (717) 214-3264
COC?1p8(ly Federal I.D. # 23-0855020 . http://www.hbmcclure.com
M
PARTS SERVICE TICKET INFORMATION
002 MOTOR 4MB81
002 RAINSHIELD
-F J?;", '-
WARRANTY TICKET#: 383278-S138
CONTRACT
SERVICE CONTRACT 57-125
NORMAL ACCT#:
PLUMBING
RES PO#:
Comm PHONE: (000)
CUSTOMER INFORMATION
BILL To: FOX SUBACUTE
120 S FILBERT STREET
MECHANICSBURG, PA 17055
WORK @:
ORIGINATION OF CALL
PROBLEM: 57 FOLLOW-UP REPAIR
DATE: 7/30/2009 BY: SMG/BIL HAIG
EQUIPMENT INFORMATION
CHCNDI ROOF
MCQAUY CONDE APP-3850-1J-12 4--QA0006.?r-04
TECH DATEBEGIN ?NL;' _HRS.MIN Rlai
-,N.- r?I^ _t y _ ._3 i?I Ul t' Or. 21 _ f 012, - ll. WORK DONE ?.?
PICKED UP MOTORS FROM VENDOR AND ARRIVED ON SITE. MOUNTED BOTH MOTORS AND
INSTALLED FAN BLADE I WAS ABLE TO GET OFF ONE OF THE OLD MOTORS. WIRED
IN ONE MOTOR AND CAPPED OFF LEADS FOR THE OTHER MOTOR. APPLIED POWER TO
MOTOR AND CHECKED ROTATION. MOTOR IS WORKING CORRECTLY AT THIS TIME.
MOTOR AMPS L1 3 L2 3.1 L3 2.9 CHILLER PRESSURES CHILLER 1 64 SUCTION AND
275 HEAD CHILLER 2 62 SUCTION AND 250 HEAD.
t REFRIG QTY CHANGED OUT (OR PARTS WARRANTY
REPLACED) YES NO
RECOVERED QTY All parts as recorded are warranted as per
?'
RECLAIMED QTY DISMANTLED YES NG manufacture's specifications
r
RE-USED QTY REFRIGERANT DISPOSAL LABOR WARRANTY
The labor required as recorded here relative to
NOT-USED QTY
the equipment serviced as noted, is guaranteed
DISPOSAL QTY for a period of 90 days We do not guarantee
parts other than those we supplied If repairs
I the undersigned owner/ authorized representative of the property at which the work above is to be done, have authorized you to perform the diagnosis and/or repair, The later become
necessary as a result of other
materials required, rendered and installed have been completed in a satisfactory manner and I acknowledge receipt of my copy. Terms are net 30 days for credit defective parts, they will
be charged separately.
approved accounts. Amounts not paid in accordance are subject to finance charge of 1.5% per month, 18% annually. Cost of collection, including attorney and/or filing
fees will be the responsibility of the debtor. DATE
X
•
my L13
383945
ACCOUfNT NUMtlER
57-125
I DATE COMPLETE----
8/17/2009
i
FOX SUBACUTE
120 S FILBERT STREET
ME C HAN I C S BU RG , PA
17055
App r o v e cd b y- BILL HA I G
ITEM DESCRIPTC
C A/C SERVICE
1 DISCONNECT 60 AMP
3 50 AMP FUSES
4 REFRIGERANT LB
2 ACCESS FITTING
1 60 AMP DISCONNECT
3 50 AMP FUSES
O.ATF - -
TJO 8/10/200
TJO 1 8/11/200
TJO 8/13/200
I
i
HOURS
2:15 Hrs : Mir M
4:30 Hrs : Mirk M
1:15 Hrs : Mirll M
Please pay within 10 DAYS
of receipt o£ this invoice
TOTAL
PARTS i ?
? I
739.
0 8
RATE -_ -._ I- AMOUNT
TOTAL -- j
?-
LABOR 576.00
PAY
TH!S
AMOUNT
PLEASE DILTAC_ H HERE ANA ,'' RETURN BOTTOM PORTION WITH PAYMENT <i -
arm ? y {
SERVICES RENDERED AT _
I
10:38 8/10/2009 PO Number-
NT
i 269.93
71.65
48.00
7.92
269.93
71.65
1,315.08 1 Subtotal
Tax
Total
•
383945 7
--.l
FOX SUBACUTE !
aafi 1?'? 57-125
<66k?e"$0.i 1,315.08
0 ue Sti Or153 1-1 hC)7lt t.h i -; i -?7?i rP _)., - , , I A I- - rA7 ro,-t_ -1 ,- Co- i .-o a; i i -; --
600 S. 17th St., P.O. Box 1745, Harrisburg, PA 17105-1745 1
t"r Service (717) 232-HEAT (4328) r, FAX (717) 214-3264
y
Federal I.D. # 23-0855020 http://www.hbmcclure.com
1 1
Since1914 k -
PARTS SERVICE TICKET INFORMATION
WARRANTY
a 001 DISCONNECT 60 AMP CO
NTRACT TICKET#: 363945-S27 5
SERVICE
003 5rJ AMP FUSES N
ORMALCON7RAC7 ACCT# 57-125
li PLUMBING
a RES PO#:
Comm
PHONE: (000)
CUSTOMER INFORMATION
j BILL TO: FOX SUBACUTE
120 S FILBERT STREET
MECHANICSBURG, PA 17955
WORK @:
I- ORIGINATION OF CALL
PROBLEM: 60 AIC REF, DISC.
DATE: 8/19/2009 BY: BILL HAIG
I EQUIPMENT INFORMATION
AIR PNEUMATICS
TECH DATE BEGIN END HRS:MIN RATE 01
TJO 08/10/2009 13:45 17:30 03:45 M/REG
SIGNATURE
e001-
OPEN
WORK D
AIR HANDLER ##24 THE AIR HANDLER WAS NOT RUNNING AS WELL AS THE CONDENSER
UNITS. CUSTOMER HAD REPLACED THE FUSE IN THE DISCONNECT. CHECKED FOR
VOLTAGE OK. RESET BOTH MOTOR STARTERS AND THE LEFT MOTOR STARTER WAS
I TRIPPED. BOTH MOTORS STARTED RUNNING. CHECKED THE TWO CONDENSER UNITS.
BOTH DID NOT RUN. ONE CONDENSER UNIT HAD CONTROL VOLTAGE BUT THE OTHER.
a DID NOT. FOUND A BAD DISCONNECT ON THE ONE CONDENSER UNIT. REPLACED THE
DISCONNECT. THIS CONDENSER IS NOW RUNNING. THE OTHER CONDENSER STILL
NEEDS TO BE CHECKED OUT. THE AREA IS SLOWLY COOLING DOWN AT THIS TIME.
a
E
R REFRIG QTY CHANGED OUT (OR
JF RECOVERED QTY REPLACED) vES No
R
I DISMANTLED YES NO
tia RECLAIMED QTY
1p? RE-USED QTY REFRIGERANT DISPOSAL
NpN NOT-USED QTY
T DISPOSAL QTY
I the undersigned owner I authorized representative of the property at which the work above is to be done, have authorized you to perform the diagnosis and/or repair, The
materials required, rendered and installed have been completed in a satisfactory manner and I acknowledge receipt of my copy. Terms are net 30 days for credit
approved accounts. Amounts not paid in accordance are subject to finance charge of 1.5% per month, 18% annually. Cost of collection, including attorney and/or filing
fees will bathe responsibility of the deotor.
PARTS WARRANTY
All parts as recorded are warranted as per
manufacture's specifications
t ASOR WARRANTY
The labor required as recorded here relative to ti
the equipment serviced as noted, is guaranteed
for a period of 90 days We do not guarantee
parts other than those we supplied If repairs
later become necessary as a result of other
defective parts, they will be charged separately. f!,
'5- F
I ?, a y 600 S. 17th St., P.O. Box 1745, Harrisburg, Pq 17105-1745
ata Service (717) 232-HEAT (4328) FAX (717) 214-3264
Federal I.D. # 23-0855020 http://www.hbmcciure.com
Since1914 a -t t
?;•s^r^._,• it + u .: if
a HAK15 SERVICE TICKET INFORMAT ION'
WARRANTY
004 LB (S) R22 REFRIGERANT (30 CONTRACT TICKET#: 383545-S275
002 t 7 q? SERVICE CONTRACT {i EA..CORE VLV.Sci I:HD F/PKiA.3 NORMAL ACCT#: 'j^.-1_25 a
r, PLUMBING
RES PO#:
COMM J
PHONE: (000'
I
INFORMATI
BILL TO: FOR SUBACUTE
120 S FILBERT STREET
MECHANICSBURG g PA.
WORK @:
TION OF
1%055
PROBLEM: 60 A/C PEF, MISC.
DATE: 8/10/2009 BY: BILL I.AIG
I _ EQUIPMENT INFORMATION
AIR PNEUMATICS
TECH DATE BEGIN END HRS:MIN RATE
TJO 08/11/2009 11:00 17:00 06:00 M/REG
TECHNICIANS SIGNATURE CALL STATUS
)<LDPT
WORK DONE
CHECKED CONDENSER UNIT A FOR AIR HANDLER #24. THE UNIT WAS NOT RUNNING.
! WHEN I MOVED SOME WIRES IN THE LOW VOLTAGE SECTION THE UNIT CAME ON. I
REPAIRED THE WIRE CONNECTIONS. I HAD TURNED OFF THE DISCONNECT WHEN I
REPAIRED THESE WIRE. WHEN I TURNED THE DISCONNECT ON THE UNIT DID NOT
WORK. I HAD LOST PRIMARY POWER TO THE UNIT. THE DISCONNECT SPRING IS
BAD AND NOT COMPLETELY CLOSING THE CONNECTIONS. DISCONNECT IS ON ORDER.
d CHECKED THE PRESSURES ON THE UNIT AND I HAD A VERY LOW SUCTION WITH A
f SUPER HEAT OF 50 DEGREES. ADDED REFRIGERANT AND THE PRESSURES DID NOT '
IMPROVE. FOUND THE HOT GAS BYPASS WAS FULLY OPEN WHILE THE COMPRESSOR
WAS RUNNING. ALSO THERE WAS NO REAL HEAT GIVEN OFF BY THE CONDENSER. I
DISCONNECTED THE HOT GAS BYPASS SOLENOID AND WHEN THE COMPRESSOR CAME ON
THE HEAD PRESSURE INCREASED IN A FEW SECONDS AND TRIPPED THE HIGH PRESSUR
? E SWITCH. THERE IS A MAJOR RESTRICTION IN THE REFRIGERANT CIRCUIT. IT
i MAY BE THE TXV IS BLOCKED. WILL SUBMIT ESTIMATE TO REPAIR THE UNIT.
'R REFRIG QTY ,.-.. I CHANGED OUT (OR
YES PJO PARTS WARRANTY
5R RECOVERED QTY REPLACED) All parts as recorded are warranted as per
f I
RECLAIMED
QTY DISMANTLED YES PJO manufacture's specifications
R RE
USED QTY REFRIGERANT DISPOSAL
LABOR WARRANTY
- j
fN NOT-USED QTY
The labor required as recorded here relative to '
h
r T t
e equipment serviced as noted, is guaranteed Il
DISPOSAL QTY for a period of 90 days We do not guarantee
- I the undersigned owner! authorized representative of the property at which the work above is to be done. have authorized you to perform the diagnosis and/or repair
The parts other than those we supplied If repairs
,
materials required, rendered and installed have been completed in a satisfactory manner and I acknowledge receipt of my copy. Terms are net 30 days for credit later become necessary
as a result
other
approved accounts. Amounts not paid in accordance are subject to finance charge of 1.5 % per month. 18% annually. Cost of collection. including attorney and/or filing
feeswill be the res
onsibilit
of th
d
, s
d
efective parts, they will be charged separately.
p
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eoto DATE
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?b K t s 14 ?i ?? 600 S. 17th St., P.O. Box 1745, Harrisburg, PA 17105-1745
f, * Service 717 232.-HEAT (4328) : FAX (717) 214-3264 II
Federal I.D. # 23-0855020
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001 60 AMP DISCONNECT
Ge3 50 AMP FUSES
SERVICE T ICKET 1NIFORMATION
WARRANTY
CONTRACT
TICKET#: 383945-S275
SERVICE CONT
NORMAL RACT
ACCT#: 5 `/- 125
....
PLUMBING
RES PO#:
Comm PHONE (tbilj(1) )
CUSTOM ER INFORMATION
BILL TO: FO -A SUBACUTE
120 S FILBERT STREET
MECHANICSBURG, PA 1.7055
WORK @:
I ORIGINATION OF CALL
PROBLEM: 60 A/C REF, MISC.
DATE: 8/10/2009 BY: BILL HAIG
EQUIPMENT INFORMATION
.'SIR PNEUMATICS
TECHNICIANS SIGNATURE
rl
TECH DATE BEGIN END HRS:MIN RATF
TJO 08/13/2jil 15.00 1615 31:15 M/REG
WORK OnNF
REPLACED THE DISCONNECT ON THE CONDENSER (A CIRCUIT) UNIT #24. CHECKED
OPERATIOki OK THIS JOB IS CLOSED
g"
g
E REFRIG QTY CHANGED OUT (OR ?Ant S WARRANT`.'
g
y R
RECOVERED
QTY
REPLACED) YES NO j
All parts as recorded are warranted as per
P I
a RECLAIMED QTY DISMANTLED YES NO I manufacture's specifications
i
6R RE-USED QTY REFRIGERANT DISPOSAL LABOR WARRANTY
?A
1
NOT-USED
QTY
The labor required as recorded here relative to I;
T
DISPOSAL
QTY the equipment serviced as noted. is guaranteed
for a period of 90 days We do not guarantee
I the undersigned owner) authorized representative of the property at which the work above is to be done. have authorized you to perform the diagnosis and/or re
air
Th
i
l parts other than those we supplied If repairs
p
.
mater
e
a
s required rendered and installed lave been completed in a satisfactory manner and I acknowledge receipt of my copy Terms are net 30 days for credit
approved accounts. Amounts not paid in accordance are s
b
fi
t t aler become necessary as a result of other
u
jec
o
nance charge of 1.5% per month, 18% annually Cost of collection. including attorney and/or filing
fees will be/he responsibility ofthe gCpto,. defective parts, they will be charged separately.
DATE
CALL STATUS
COMP
h.h. moolupe
fice1914 pan
P.O. Bolt 1745, Harrisburg, Pennsylvania 17105-1745
Service (717) 232-HEAT (4328) a FAX (717) 234-3730
Federal I.D. #23-0855020 a http://www.hbmcclure.com
4G000N7 NUMBER
57-125
FOX SUBACUTE
120 S FILBERT STREET
MECHANICSBURG, PA
17055
I
384192
DA T_ C0M?LETE --
6/19/2009
___ SERVICE: REN:)ERCDFl+ -_1
Approved by- MATT MUNDY 16.35 8/11/2009 PO Number-
ITEM DESCRIPTON AMOUtiT
A/C SERVICE - --- i _----- -
j 1 FILTER CORE
1 TXV
1 FILTER DRIER
4 5/8 OD COUPLING
4 REFRIGERANT LB
4 ACCESS CAP
2 ACCESS FITTING
1 OIL,VACUUM JBDVO-12
1 CONTRACT AMOUNT 1,255.00
I
- - AT .
TOTAL
FARTS
HgURS -RATE - -
Please pay within 10 DAYS
of receipt of this invoice
TOTAL
LABOR
PAY
g T ?.4
AMOUN T
j, PLEF.;3c i1?TACA MERE AND R_E_' RNI BOTTOM PORTION WETH BAYMENT ;.
?55_UO Subtotal
Tax
Total
ILI ®.
I 384192
FOX SUBACUTE
T 57-125
J 1,255.00
j
Questions about this invoice shc-,i,lc] t rt; ,--4„_t-i t , c e- -
' f
s
600 S 17th St., P.O. Box 1745, Harrisburg, PA 17105-1745 0
g lrl {j ,7! Service (717) 232-HEAT (4328) FAX (717) 214-3264
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FrR
PARTS SERVICE TICI:ET 11\IF0RivlA_FI0N
r OC'r1 FILTER COPE RPE48BD
061 TXV SVESGA
OOl FILTER. DRIER C:305S
004 5/8 OD COUPLING
004: LB(S) R22 REFRIGERANT(30
r 004 EA.CAP(1G/PR)SVCEPORT,S'HR
002 EA. CORE VLV,. SHR D G/PI ; t',3
WARRANTY
CONTRACT TICKET#: 38'_192- 2%5
SERVICE CONTRACT ,, - ,
NORMAL ACC I #: r' ?_ 25
PLUMBING
RES PO#:
Comm PHONE: (00i? )
CUSTOI%AER INFORMATION!
BILL TO: FOX SUBACUTE
120 S FILBERT STREET
MECHANICSBURG, PA 17055
WORK @:
ORIGINATION OF CALL
PROBLEM: 51 CONTRACT SALES - SERVICE
DATE: 8/11/2009 BY: M,TT MUNDY
EQUIPMENT INFORMATION
N I S C
1 TECH DATE BEGIN END HRS-MIN RATE
TJO 08/i4/2009 07:3C :6.210 09:06 MYREG
4 TECHNICIANS SIGNATURE CALL STATUS
///mil COMP
WORK DONE
a
ry PUMPED DOWN THE SYSTEM. REMOVED THE LIQUID LINE FILTER, +'HE SUCTION SCRE
EN FILTER,- REBUILT THE 'fXV. BRAZED IN THE LIQUID LIRE FILTER AND INSTAL
LED A WEIR SUCTION FILTER. EVACUATED THE SYSTEM TO 500 MICRONS. RELEASED
THE CHARGE. ADJUSTED THE TXV AND ADDED SOME REFRIGERANT:. THE SUCTION
j PRESSURE IS NOT AS HIGH k,S IT SHOULD BE. THE EVAPORATOR COIL NEEDS A
THOROUGH CLEANING AS WELL AS THE CONDEMSER COILS. BOTH UNIT 24 AND 25 %E
ED THE CLEAMING, PRESSURES WERE 65/2121 PSIG 5H 20 DEGREES, SC; 24 DEGREE
S. THIS jOB IS CLOSED,
I : -= 3Y51 tlw --
R REFRIG QTY CHANGED OUT (OR -r =
AF RECOVERED QTY REPLACEDf ves No
3R
a' I RECLAIMED QTY DISMANTLED vES No
R RE-USED QTY REFRIGERANT DISPOSAL
N NOT-USED QTY
T? DISPOSAL QTY
I the undersigned owner / authorized representative of the property at which the work above is to be done, have authorized you to perform the diagnosis and/or repair. The
materials required, rendered and installed have been completed in a satisfactory manner and I ?eknowtedge receipt of my copy. Terms are net 30 days for credit
approved accounts. Amounts not paid in accordance , e subject to finance charge of '..5% per n,onth, annually. Cost of collection. Including attorney and/or filing
I'. fees will be the responsibility ofth .btor.
do
f PARTS WARRANTY
All parts as recorded are warranted as per
manufacture's specifications
i
LABOR WARFAHITv
The labor required as recorded here relative to
the equipment serviced as noted, is guaranteed
for a Denod of 90 days We do not guarantee
parts other than those we supplied If repairs
later become necessary as a result of other
detective parts, they will be charged separately.
"SERVICE INVOICE
384597
ACCOUNT RJM6tR?
57-125
)ATE Cpi_ PL_ETE -!
L 8/20/2009
FOX SUBACUTE
120 S FILBERT STREET
MECHANICSBURG, PA
17055
Approved by- BILL
ITEM DESCRIPTON___ _
A/C SERVICE
wFE
TJO 8/19/200
i
I
--4(__- I
3:00 Hrs : Mira M
Please pay within 10 DAYS
of receipt of this invoice
TOTAL
LABOR
PAY
7H1 11511
AMOUNT
Subtotal
Tax
----- Total
PL EASE Dt=TACHERE AND nETURN BOTTOM PORTION WITri PAYMENT !
•
384597
i
4,*?r<'-0? 7' I FOX SUBACUTE
57-125
i m (MV.; a y ?ti.?i i W I 2 1 6. 00 n
SERVICES PANDER=D AT
L
7:11 8/19/2009 PO Number-
Questions about this invoice should be dirPC tPrl r,-, c? -4114
600 S. 17th St., P.O. Box 1745, Harrisburg. PA 17105-1745
Service 717 232-HEAT 4328 FAX 717 214-3264 j
Federal I D # 23-0855020 http://www.hbmcclure.com
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?;Since1914
PARTS
TECHNICIANS SIGNATURE CALL STA-
' ?IA COI;P
SERVICE TICKET Ir.IFQR?iiATION
_ i
WARRANTY
CONTRACT TICKET#: 3841.597-S275 ;y
SERVICE CONTRACT ACCT#: 577 _ 125
NORMAL PLUMBING
RES PO#:
Comm
PHONE. 6
CUSTOMER INFORMATION
--t.
BILL TO: FON SUBACUTE
120 S FILBERT STREET
NECHAFICSSURG., Fir, 1"17055
l
WORK @:
4
I
ORIGINATION OF CALL
PROBLEM: 53 A/C REF, FORE -EMERGEEC" !!
DATE: 8/19/2009 BY: BILL
EQUIPMENT INFORMATION
i,
TM1 I S C a
I TECH DATE BEGIN END HRS:MiN RATE
TJO 08/1912009 07'00 10:00 03:00 M/REG
WORK DONE
TRANE PACKAGE UNIT AC14 SUPPLIES CONDITIONED AIF., TO THIS AREA. CHECKED
THE UOIT AMD IT WAS RUNNING. CHECKED THE FIRE DAMPER OK. CHECKED THE
ZONE DAMPER AND IT e;AS OPEN. CHECKED THE SUPPLY AIR INTO THESE AREAS AND
I WAS ONLY GETTING 67 DEGREE. LOOKED AT THE PACKAGE UNIT AND SAW BOTH
COMPRESSORS RUNNING CHECKED THE ECONOMIZER AND AND FOUND 17 FULLY OPEN.
IT WAS BRINGING Iiq 100% OF OUTSIDE AIR. RESET THE ECONOMIZER AND WHEN 1
CHECKED THE SUPPLY AIR AG`;IF IT HAD DROPPED TO 61 DEGREES. THE AREAS ARE
COOLING DOWN AND THE SUPPLY AIR IS DROPPING. THIS JOB IS CLOSED.
E REFRIG QTY CHANGED OUT (OR
REPLACED)
YES NO
F RECOVERED QTY
R
REC
ME
QTY DISMANTLED 77 7YES NO
G
LAI
D
REFRIGERANT DISPO
SAL
R RE-USED QTY
;N NOT-USED QTY
T DISPOSAL QTY
I the undersigned owner/ authorized representative of the property at which the work above is to be done. have authorized you to perform the diagnosis and/or repair. The
materials required, rendered and installed have been completed in a satisfactory manner and I acknowledge receipt of my copy. Terms are net 30 days (or credit
approved accounts. Amounts not pad in accordance are subject to fina nce charge of 1.5% per month, 18% annually. Cost of collection including attorney and/or filing
fees will be the respons- y of t of the deot
orrr
t
PARTS WARPANT`.'
All parts as recorded are warranted as per
manufacture's specifications
_ABOR WARRANTY
The labor required as recorded here relative to II
the equipment serviced as noted, is guaranteed
for a period of 90 days We do not guarantee
pans other than those we supplied If repairs
later become necessary as a result of other
defective parts, they will be charged separately.
DATE
I I-)
h.h. mcclupe 384836
Since1914 co pen
®v -- ---- --- ----- - - - -
-ACCOUNTNUMBER- j 0.17E COMPLETE 1
P.O. Box 1745, Harrisburg, Pennsylvania 17105-1745 1
Service (717) 232-HEAT (4328) , FAX (717) 234-3730 57-125 8/28/2009
Federal I.D. #23-0855020 a http://www.hbmcclure.com
LRENDERED T - ---
FOX SUBACUTE
120 S FILBERT S TREET
MECHANICSBURG, PA
17055
i
i
Approved by- BILL 15:08 8/20/2009 PO NumbE?!r-
? ITEM DESCPIPTON AMOUNT
__
A/C SERVICE - -
1 60 AMP DISCONNECT 269-93
?
3 50 AMP FUSES 71 - 6 -?
i
DATE
TJOI 8/26/200
HSH i 8/26/200
I
HOURS
2:45 Mir I M
2:45 Hr.s:Mi H
i
Please pay within 10 DAYS
of receipt of this invoice
TOTA L
_ FARTS
RATE -
TOTAL
LABOR
- -
PAY
r>.
THIS
AMOUNT
PLEASE DETACH HERF AND RETURN BOTTOM PORTION WITH PAYi/iEi\IT .,„
REMM 7 TD"
341-58
AMOUNT
1 'ice -m? ', mean FOX SUBACUTE
4 ' ay ^i dd r _-_ - _. r N k eel P? 57-125
W, 688.08
Questions about this invoice shout Ci be directed to SE--rVi CE? Ri l l i n"
h-?- mcclure 600 S. 17th St., P.O. Box 1745, Harrisburg, PA 17105-1745
Service (717) 232-HEAT (4328) . FAX (717) 214-3264
Federal I.D. # 23-0855020 . http://www.hbmcclure.com
Since1914 Menu
PARTS SERVICE TICKET INFORMATION
001 60 AMP DISCONNECT WARRANTY
CONTRACT TICKET#: 384$36-5275
!y, F FUSES
003 50 AMP SERVICE CONTRACT 57-125
NORMAL ACCT#:
PLUMBING
RES PO#:
Comm PHONE: (000)
CUSTOMER INFORMATION
BILL TO: FOX SUBACUTE
120 S FILBERT STREET
MECHANICSBURG, PA 17055
WORK @:
ORIGINATION OF CALL
PROBLEM- 57 FOLLOW-UP REPAIR
DATE: 8/20/2009 BY: BILL
' EQUIPMENT INFORMATION
AC25D ROOFTOP
j TECH DATE_ BEGIhJ_ HRS:MIN _RATE
WORK DONE
REPLACED THE DISCONNECT ON AIR HANDLER #25. CHECKED OPERATION OK THIS
JOB IS CLOSED.
REFRIG QTY CHANGED OUT (OR PARTS' WARRANTY
REPLACED)
RECOVERED
QTY aj?
All parts as recorded are warranted as per
RECLAIMED
QTY DISMANTLED manufacture's specifications
RE-USED QTY REFRIGERANT DISPOSAL LABOR WARRANTY
NOT-USED QTY
The labor required as recorded here relative to
th
i
t
i
d
t
i
DISPOSAL QTY e equ
pmen
serv
ce
as no
ed,
s guaranteed
for a period of 90 days We do not guarantee
I the undersigned owner/ authorized re resentative of the pro
p perry at which the work above is to be done, have authorized you to perform the diagnosis and/or repair
The parts other than those we supplied If repairs
,
materials required, rendered and installed have been completed in a satisfactory manner and I acknowledge receipt of my copy. Terms are net 30 days for credit later become necessary
as a result of other
approved accounts. Amounts not paid in accordance are subject to finance charge of 1.5% per month, 18% annually. Cost of collection, including attorney and/or filing
f
ilt defective parts, they will be charged separately.
ees w
be the respo of the debtor. DATE
1h.h. mcclure
EEO
Since1914 com an -
P.O. Box 1745, Harrisburg, Pennsylvania 17105-1745
Service (717) 232-HEAT (4328) • FAX (717) 234-3730
Federal I.D. #23-0855020 • hftp://www.hbmcclure.com
SERVICES RENDERED AT
FOX SUBACUTE
120 S FILBERT STREET
MECHANICSBURG, PA 17055
ITEM DESCRIPTON AMOUNT
CONTRACT BILLING FOR YOUR ? -
BEGINNING: September 1, 2009
AND ENDING: November 30, 2009
Maintenance Plan
i
I 1,062.50
Invoice Copy
TOTAL - --
L_ _ PARTS
_ DATE HOURS..
I _
RATE I
i
- AMOUNT
TOTAL
LABOR
PAY Subtotal: 1,062.50
THIS Tax: 63.75
AMOUNT Total: 1,126.25
: PLEASE DETACH HERE AND RETURN BOTTOM PORTION WITH PAYMENT 4,
REMIT TO
H.B. McClure, Company
PO Box 745
ara lsbur f ?A 17105
ACCOUNT NUMBER DATE COMPLETE
57-125 09/10/2009
FOX SUBACUTE
SERVICE INVOI
J0109085
SERVICE INVOICE
J0109085
ACCOUNT NUMBER 57-125
AMOUNT
V huh. mcclure
Since1914 company -
P.O. Box 1745, Harrisburg, Pennsylvania 17105-1745
Service (717) 232-HEAT (4328) • FAX (717) 234-3730
Federal I.D. #23-0855020 • http://www.hbmcclure.com
ACCOUNT NUMBER
57-125
FOX SUBACUTE
120 S FILBERT STREET
MECHANICSBURG, PA 17055
•
J0109115
DATE COMPLETE
C 12,11,2009
SERVICES RENDERED AT
ITEM DESCRIPTON AMOUNT
CONTRACT BILLING FOR YOUR
BEGINNING: December 1, 2009
AND ENDING: February29, 2010
I
j Maintenance Plan
III 1,062.50
i
Invoice Copy
TOTAL
PARTS
DATE- .-HOURS _ -RATE- AMOUNT
TOTAL
LABOR
PAY Subtotal: 1,062.50
THIS Tax: 63.75
AMOUNT Total: 1,126.25
. PLEASE DETACH HERE AND RETURN BOTTOM PORTION
REMIT TO-
H.B. Mc iure Company
PO Box 1, 7,45
liar risbur , P A.17105
PAYMENT s SERVICE INVOICE
JO 109115
FOX SUBACUTE
ACCOUNT NUMBER 57-125
! AMOUNT 1,126.25
H.B. MCCLURE COMPANY,
PLAINTIFF
V.
FOX SUBACUTE AT CLARA BURKE,
DEFENDANT
: IN THE COURT OF COMMON PLEAS
: CUMBERALND COUNTY, PENNSYLVANIA
. NO.
CIVIL ACTION -LAW
VERIFICATION
I, Linda Spotts, Credt Manager, of H.B. McClure Company, 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.
r7? W
LINDA SPOTS
DATE: ) 6-d 1 II
' I -0-OI" IGE
?`I{ONO
-
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 fax
Attorneys for Plaintiff
H.B. MCCLURE COMPANY,
PLAINTIFF
V.
Z01 1 NOV 22 AM 9: 22
ST
CUMBERLAND PENNSYLVANIA
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 11-8122 CIVIL TERM
FOX SUBACUTE AT CLARA BURKE, :
DEFENDANT : CIVIL ACTION -LAW
TO: FOX SUBACUTE AT CLARA BURKE
DATE: NOVEMBER 22, 2011
IMPORTANT NOTICE
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
PAPER TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE
TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(800) 990-9108
H.B. MCCLURE COMPANY, : IN THE COURT OF COMMON PLEAS
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 11-8122 CIVIL TERM
FOX SUBACUTE AT CLARA BURKE, :
DEFENDANT : CIVIL ACTION -LAW
TO: FOX SUBACUTE AT CLARA BURKE
DATE: NOVEMBER 22, 2011
AVISO IMPORTANTE
USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION
REQUERIDA EN ESTE C.ASO. 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.
JAMES, SMITH, RICK & CONNELLY, LLP
By:
Kimberly . Bonner, Esquire
H.B. MCCLURE COMPANY, : IN THE COURT OF COMMON PLEAS
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 11-8122 CIVIL TERM
FOX SUBACUTE AT CLARA BURKE, :
DEFENDANT : CIVIL ACTION -LAW
CERTIFICATE OF SERVICE
I, Denise L. Foster, Paralegal, do hereby certify that I have served a true and
correct copy of the 10-Day Notice, by First Class Mail to the following address:
Fox Subacute at Clara Burke
121 S. Filbert Street
Mechanicsburg, PA 17055
H, DIETTERICK & CONNELLY, LLP
By:
6 jc,. 2z
e L. Foster, Paralegal
DATE: November 22, 2011