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Home My WebLink About04-4634 COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS Judicial District, County Of C..~~ NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. ()L/- 4L.?,l./ e,,~L TJ2..1 NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case referenced below. ('I. .."u,.,\ C\.., M _ -\)(,1 V\ \r ~ .. NAME OF APPELLANTj' ;"~h F -p(1I~ k4..1 MA;;T:O\ - O~ ADDRESS OF APPELLANT ., CITY Un Ac\.o..ms ec\ C A).A\s ~ DctJ6~E~4- I'NT)l;h~"l;\miY\l(k 04 DOCKET No. SIGNAT c V - bbOO?"Cj 4 - o'-{ I NAMR~bf.l-_t \). MOK\\o\je., STATE ~A no\"S -Jos-tPh -r'"l>~1 n \e. L}-~, C\( v\"\Vlit>. 'f:(\. LLANTORATTO, NEYORAGENT _ 'bt.~""'1 ThJ~~ I~~~"J- No. 1001 (6) in action ZIP CODe This block will be signed ONLY when this notation is required under Pa. RC'p,D.J, No, 1006B. This Notice of Appeal, when received by the District Justice, will operate as a SUPERSEDEAS to the judgment for possession in this case. before a District Justice, A COMPLAINT MUST BE FILED within twenty (20) days afte' filing the NOTICE of APPEAL. Signature ofProlhonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONL Y when appeUant was DEFENDANT (see PaRC,P,D,J, No, 1001(7) in action before District Justice, IF NOT USED, detach from copy of notice of appeal to be seNed upon appeUee, PRAECIPE: To Prothonotary Enter rule upon +h \~V'\ - b lVV\ lV\\ CK. 0'14 ho appellee(s), to file a complaint in this appeal Name of appellee(s) (Com~ ".. '" DlJ-4 '-?8 (i,;, J ) .... ~""'")'~ - _re. N" 0' T"""'" ~)~ 00, ~. 1e.A-rY) . ~~~..; - Signature of appel/ant or attorney agent RULE: To Jhl~I'\-l.JtMlt'"\l~ ()r~D Name of appel/ee(s) , appellee( s) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mall. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. Date(3r~;;~~i::Z~ ruie if service was by maii is the date ofth:=ffi n,., . P. ~~o~;,iJi;J YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENTfTRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312-02 COURT FILE TO BE FILED WITH PROTHO~OTARY (Tt)fS service !,f!UST BE:": wrnfiN TEN PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT COMMONWEALTri OF PF::NNSYL\f/\Nif\ OF AFFIDAVIT: lhdl i 3 copy d tik'J Notice Apooal (it service) \/,S,i4FTEf? Picas rJc; ;:md 8Ppene(~ by personal service tJY (certified) (registered) (SWORN) (AFFIRMED) AND SUBSCRiBED BEFORE THIS DAY OF Sign8ture of offfcl~?f before whom affi(iavit WAS made Title ofoftici{Jj My commiSSIon expires AOPC 312/\ [)'y' ~ /1(;[/<0 :jjJj)/iCojj)!" /)nX2' upon the Jusfjce cieEilqnated t!lf)181>; ,In $:erv:',;t: ; -^,bjrtiUed; i;(~9Istured; i tI) "" w ~ """" l/1 .11) ~ fF! P- JtKJ go '-. ~ Iv (' (,~"1 ';'lorotut8,jinf'.fjnf '" CO::", V) ;"1, ."o-f '.r.-,; l'J1p= vQ-~: :'-J'-....-_ C{(~J - -'1', ;.:;:::r~ (.r .rn ---; COMMONWEALTH OF PENNSYLVANIA 'COUNTYOF: CUMBERLAND 1 Mag. Dist. No.: 09-1-02 NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS IgILTON-DIMINICK ORTHO. ASSO., P.C.' 3412 TRINDLE ROAD CAMP HILL, PA 17011 L ..J VS. OJ Name: Hon. ROBERT V. MANLOVE Add"" 1901 STATE STREET CAMP HILL, PA T.I,p",oo (717) 761- 0583 17011- 0000 DEFENDANT: NAME and AODFlESS rpUNLEY, JOSEPH F, ET AL. 617 ADAMS RD CARLISLE, PA 17013 L , ATTORNEY DEF PRIVATE : JOHN H. BROUJOS, ESQ. 4 N. HANOVER ST CARLISLE, PA 17013 'Docket'No.: CV-0000294-04 Date Filed: 6/30/04 ..J 1& THIS IS TO NOTIFY YOU THAT: Judgment: FOR PT,ATNTIFF ~ ~ Judgment was entered for: (Name) HTTi"Ofoj'-nTMTfoj'T(,,1f OR'I'HO. ARRO., Judgment was entered against: (Name) PA T1ITT.F.Y, ,TOREPH F in the amount of $ 1 , /i41 , 1'l on: (Date of Judgment) 'l/DR/D4 o Defendants are jointly and severaliy liable, o Damages wiil be assessed on: o This case dismissed without prejudice, (Date & Time) Amount of Judgment Judgment Costs Interest on Judgment Attorney Fees Total $ 1, 564 . 89 $ 78.50 $ .00 $ .00 $ 1,643.39 O Amount of Judgment Subject to Attachmentl42 Pa.C,S, ~ 8127 $ D Portion of Judgment for physical damages arising out of rE?sidentiai lease $ , Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION, YOU MUST INCLUDE A COpy OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL, EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE iSSUED BY THE DISTRICT JUSTICE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MA Y FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE DISTRICT JUSTICE iF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT, '..')/')/1.': Yd~qgu "",,""'''':'2::'>., \'::/'1/(l~' ,- ~ ~~_ "......:1'....... fEd . Date .t' . .:,. ZJ?;;,:~;~1-.:'DiSltj~~JUstice ICferJiJ.~ ti~t PI's is a true~..~'"-.9_9fie9t20pyOf.l)i_~e'$.0t.fc9 :.'9U.~. ~P...l~..geegiJ:1Jl~f2't. ~!0~"~~. J~.d~m~nf. :; ",1\ l.tU 'I .. ;.(~rt4v / j'.?lr;;p1~"f ;:t'I'}' \" a.'. ~"'. '.: - " ~,'-,~/,.__.:__ Date _,_~___ ." / -, ... t. _\':.;~lstncJ.JustJce I . .:,S~. ~ .,' .'. My commission expires first Monday of January, 2006 ,::::.~~,~k,.'.:.. AOPC 315-03 DATE PRINTED: 9/08/04 2:01:58 PM COrVIM6NWEALTH OF PENNSYLVANIA -COUNTY OF~ CUMBERLAND 09-1-02 NOTICE OF JUDGMENTITRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS fHILTON-DIMINICK ORTHO. ASSO., P.C.' 3412 TRINDLE ROAD CAMP HILL, PA 17011 L ~ VS. Mag. Ois(. No. OJ Name; Hon. ROBERT V. MANLOVE Add",,, 1901 STATE STREET CAMP HILL, PA T",p",o, (717) 761-0583 17011-0000 DEFENDANT: NAME and ADDRESS IpAINLEY, JOSEPH P, ET AL. 617 ADAMS RD CARLISLE, PA 17013 L , CYNTHIA M. PAINLEY 617 ADAMS RD CARLISLE, PA 17013 Docket No,: CV- 0000294 - 04 Date Filed: 6/30/04 ~ ..-- ~ THIS IS TO NOTIFY YOU THAT: ~'--~Ji1OgmenC'"-""'" . POR PT.l\.TNTIFP [!] [!] Judgment was entered for: (Name) JlTT,'I'ON - nn>fTTlTTr.1f nR'I'RO Jl.~Rn_ , Judgment was entered against: (Name) PJl.TNT,RY, CYNTHTJl. M in the amount of $ 1,641 lQ on: (Date of Judgment) Q/OR/04 o Defendants are jointly and severaiiy liable, o Damages will be assessed on: o This case dismissed without prejudice, (Date & Time) Amount of Judgment Judgment Costs Interest on Judgment Attorney Fees Total $ 1.564.89 $ 78.50 $ .00 $ .00 $ 1,643.39 O Amount of Judgment Subject to Attachment/42 Pa,C,S, S 8127 $ o Portion of Judgment for physical damages arising out of residential lease $ Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ "ANY'PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE'FNTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION, YOU MUST INCLUDE A COpy OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL, EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE DISTRICT JUSTICE, UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS iN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT, 1/f/ot)." 715.>, ./,.:;f.,~~J~.i" i certlf~t t ~hiS 's a tru.~~1.r J;QPY (lth~/;?~~f th1~' proceedings con~l,ni~lb$ jUdQment j al. () / ' ./ l." ~i/~Jo:._I, : >.~ "Z ,'" ( I Date / [,/''"''L . '?' /,:~.r ~' t ~ -', ,niitrict'Justice f '~;""t;"C; " - 1 c, ~. ': My commiSSion expires first Monday of January, 2006 &i;J;L " " AOPC 315-03 DATE PRINTED: 9/08/04 2:02:39 PM ;t'_lt~"~ l.... ,.,., '. BUTLER LAW FIRM Ronald D, Butler, Esquire Attorney I.D, No,: 09826 500 North Third Street P,O, Box 1004 Harrisburg, P A 17108-1004 (717) 236-1485 lawyers@butlerlawfirm,com HIL TON-DIMINICK ORTHODONTIC ASSOCIATES, p,c. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA y, NO, 04-4634 CIVIL JOSEPH F, PAINLEY and CYNTHIA M, PAINLEY, Defendants CIVIL ACTION - LAW NOTICE TO DEFEND 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 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 claim or relief requested by the Plaintiff You may lose money or other rights important to you, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE OR KNOW A LAWYER, THEN YOU SHOULD GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 or (800) 990-9108 NOTICIA LE HAN DEMAND ADO A USTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion, Usted debe presentar una apariencia escrita or en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona, Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previa aviso 0 notificacion Y por cualquier queja 0 alivio que es pedido en la peticion de demanda, Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDlATEMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE P AGAR TAL SERVICIO, V A Y A EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DlRECCION SE ENCUENTRA ESCRIT A ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEQUIR ASISTENCIA LEGAL CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 BUTLER LAW FIRM Ronald 0, Butler, Esquire Attorney 1.0, No,: 09826 500 North Third Street P,O, Box 1004 Harrisburg, P A 17108-1004 (717) 236-1485 lawyers@butlerlawfirm,com HIL TON-DlMINICK ORTHODONTIC ASSOCIATES, P.c. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, NO, 04-4634 CIVIL JOSEPH F, PAINLEY and CYNTHIA M, P AINLEY, Defendants CIVIL ACTION - LAW COMPLAINT AND NOW, comes the Plaintiff, Hilton-Diminick Orthodontic Associates, P.c., by and through its attorneys, Butler Law Firm, and files this Complaint against Defendants, Joseph F, Painley and Cynthia M. Painley, and in support thereof avers the following: L The Plaintiff, Hilton-Diminick Orthodontic Associates, P,C., is a professional corporation organized and existing under the laws of the Commonwealth of Pennsylvania with its principal place of business located at 3412 Trindle Road, Camp Hill, Cumberland County, Pennsylvania 17011, 2, The Defendant, Joseph F, Painley, is an adult individual residing at 617 Adams Road, Carlisle, Cumberland County, Pennsylvania 17013, 3, The Defendant, Cynthia M, Pain1ey, is an adult individual residing at 617 Adams Road, Carlisle, Cumberland County, Pennsylvania 17013, 4, Defendants are currently indebted to Plaintiff in the amount of$970,00 for orthodontic services rendered to Defendants' minor daughter, Erin M, Pain1ey, A true and correct copy of the invoice for services rendered is attached hereto and made a part hereof as Exhibit "A", 5, Defendants are also indebted to Plaintiff for interest in the amount of 1,5% per month on all outstanding balances, The interest accrued from April 28, 2003 through September 28,2004 is $247,35 A true and correct copy ofthe statement signed by Defendant Cynthia Painley agreeing to pay interest is attached hereto and made a part hereof as Exhibit "B", 6, Defendants are also indebted to Plaintifffor attorney's fees in the amount of $405,78 (see Exhibit "B") and District Justice court costs in the amount of $78.50, 7, Plaintiff has demanded payment from Defendants of said amount due and owing but Defendants have refused and neglected to pay said amount or any part thereof 8, The prices Plaintiff charged Defendants for said services were just and reasonable and were the legal and market prices therefor. WHEREFORE, Plaintiff demands judgment against Defendants in the sum of $1,70\.63 and all such other relief as this Honorable Court deems appropriate, Respectfully submitted, BUTLER LAW FIRM By: ~,'~ Ronald 0, Butler, Esquire 1.0, #09826 Jana Butler Toole, Esquire LD, #80574 500 North Third Street P,O, Box 1004 Harrisburg, P A 17108 (717) 236-1485 . . "'- Hilton-Diminick Orthodontic Associates, P,C, 3412 Trindle Road Camp Hill, PA 17011 4455 (717) 761-3402 Mr. Joseph F painley 617 Adams Road Carlisle, PA 17013 5/6/2004 Account Number: 2 1 13280F A Patient Name: Erin M Painley Orthodontist: Hilton-Diminick Orthod, AS80cs, PC End Balance Post Date Trans Date Description 6/18/1999 6/17/1999 Initial Ortho Exam 6/18/1999 6/18/1999 Check Received 11113/2000 11/13/2000 Fee for Ortho TX 11/13/2000 11/ 13/2000 Prof. Courtesy 11/13/2000 11/13/2000 Correct Data 3/14/2001 3/14/2001 7/27/200 I 7/27/2001 Prof. Courtesy 7/27/2001 7/27/2001 8/16/2001 8/16/2001 Correct Data 8/16/2001 8/16/2001 Check Received 10/2/2001 10/2/200 I Check Received 10/17/2001 10/17/2001 Check Received 11/13/2001 11/13/2001 Check Received 12/28/2001 12/28/2001 Check Received 1/18/2002 1/18/2002 Check Received 1/18/2002 1/18/2002 Correct Data 2/20/2002 2/20/2002 Check Received 3121/2002 3121/2002 Check Received 4/18/2002 4/18/2002 Check Received 5/24/2002 5/24/2002 Check Received 6/19/2002 6/19/2002 Check Received 7/24/2002 7/24/2002 Check Received 8/16/2002 8/16/2002 Check Received 9/25/2002 9/25/2002 Check Received 10/29/2002 10/29/2002 Check Received 12/2/2002 12/2/2002 Check Received 1/6/2003 1/6/2003 Check Received Due This Month $52,25 30 Days Old $51.50 60 Days Old $50,00 f:lwinnh IData Iledger,rpt Reference Charges/Adjust initex 30,00 3256 needs FS 4800,00 discount -480,00 to ins -1820,00 KR 20% -480,00 Payments 30,00 KR conunent _"-~L\ f""",.,.t -25,00 4438 4522 4562 4592 4658 4692 conunent ..,.!-'^ P*' -25,00 4751 4800 4845 4890 4918 4961 4998 5051 4480 4548 4611 25,00 50,00 50,00 50,00 50,00 25,00 50,00 50,00 50,00 50,00 50,00 50,00 50,00 50,00 50,00 50,00 50,00 30,00 0,00 4,800,00 4,320,00 2,500,00 2,500,00 2,020,00 2,020,00 1,995,00 1,970.00 1,920,00 1,870,00 1,820,00 1,770,00 1,745,00 1,720,00 1,670,00 1,620,00 1,570,00 1,520,00 1,470,00 1,420,00 1,370,00 1,320,00 1,270,00 1,220,00 1,170,00 Total Balance of Account for above Responsible Party (does not include insurance) balance $ 973,75 90 Days Old J 20 Days Old $ 50,00 $ 50,00 = Total Amount due now $ 253.75 EXHIBIT OJ " Hilton-Diminick Orthodontic Associates, P.C. 3412 Trind1e Road Camp Hill, PA 17011 4455 (717) 761-3402 Mr. Joseph F Painley 617 Adams Road Carlisle, PA \7013 Post Date Trans Date Description Reference 1/28/2003 1/28/2003 Check Received 4639 2/2412003 2/24/2003 Check Received 4674 3/2712003 3/27/2003 Check Received 4759 4/28/2003 4/28/2003 Check Received 4810 9/4/2003 9/4/2003 5% discount family d 9/8/2003 9/8/2003 5 % discount wrong ac 4/1/2004 411/2004 late fee me 1 fee 5/3/2004 5/3/2004 late fee me I fee 5/612004 Account Number: 2 1 13280FA Patient Name: Erin M Painley Orthodontist: Hilton- Diminick Orthod, Assocs, PC Charges/AdJust Payments End Balance 50,00 50,00 50,00 50,00 1,120.00 1,070,00 1,020,00 970.00 730,00 970,00 97L50 973,75 -240,00 240,00 L50 2,25 Comments: Due This Month $52.25 30 Days Old $5L50 60 Days Old $50,00 90 Days Old 120 Days Old $ 50,00 $ 50,00 = Total Amount due now $ 253.75 Tota/ Balance of Account for above Responsible Party (does not include insurance) balance $ 973,75 f:\winnh\Data \ledger,rpt ~HfBIT nfl The Federal Truth in Lending Act, Regulation A, REQUIRES a Federal Truth in Lending Statement if there are more than 4 payments involved in paying for a service. 7-~7-tJ I FEDERAL T' fH IN LENDING DISCLOSURE S' fEMENT Q 11 . FOR-dOFESSIONAL SERVICES REND! ~D' \ . ~ DATE Erin M painley PATIENT'S NAME RESPONSffiLE PARTY Joseph Painley!Cynthia Painley ADDRESS 263 W south Street, Carlisle PA 17013 n//4 NEAREST RELATIVE NOT LIVING WITH YOU ADDRESS OF RELATIVE Less initial Fee: PROFESSIONAL ORTHODONTIC SERVICES $'1fi'OOcc'- .;!Cl?o jJc:~(gO c..' .::. />.35l,10oc, AI /11- PlK~O.OO ..." C Professional Fee: Estimated Insurance Coverage: Balance/Total Contract Fee: Total unpaid balance of JJ,;;(o;/O ~- is payable to Hilton-Diminick Orthodootic Associates in tJC- monthly payments of '$ so c,d with .ff,p,cJ (/ .7 due the VI .t"""month. The initial payment is due-- with the first monthly payment due ~ / (J..ot' I and payable each month thereafter until paid in full. The due date for your payments will be stated on your coupons. '$ ;J.CI~O In the event that lIwe amlare more than ninety (90) days late on any monthly installment payment, l/we understand the remaining unpaid balance will be due and payable in full. lIwe agree to pay interest on any unanticipated late payments at the rate of I 1/2% per month. In the event that my account is turned over to an attorney for collection, lIwe agree to pay legal fees in the amount of33 113% of the outstanding balance plus all court costs. [ b=by oem"';:: JJwo havo <e'" "" n<eived' ropy o,<he - -"""" -'" ,;17771 day of CROCI / and agree to the terms thereof. If the insurance company fails to pay any portion of the amount indicated lIwe will ass full responsibility for any remaining balance. S"~ ,,-' 19n1iture ~~ Signature Witness ;(41?c~ EXH\B\T !B' NO. t ~ 5 ? r: , , SEP, n 201}4 3: 55PN, J11236ii71 Vll','R1l1'TCA TIQN I. Kenneth J. Diminiok. Secretary and TreasW'Cf of the Plaintiff herein, hereby certify that the facts set forth in the foregoing Complaint are true and correct according to the best of my lmowledge. infonnation and belief I understand that llJ'ly false statements herein are made 5ubject to penalties of i8 Pa, C.S. 949,04 relating to unsworn falsification to authorities. ~~ Dated: IOl'\II~ HlLTON-DIMINICK ORTHODONTIC ASSOCIATES, p,c. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, NO, 04-4634 CIVIL JOSEPH F, PAINLEY and CYNTHlAM, pAINLEY, Defendants CIVIL ACTlON- LAW $f" 1, Jana Butler Toole, Esquire, hereby certify that on the L day of October, 2004, I served a true and correct copy of the foregoing Complaint by depositing same in the United States Mail, postage prepaid in Harrisburg, Pennsylvania, addressed as follows: CERTIFICATE OF SERVICE John H. Broujos, Esquire Broujos & Gilroy, p,c. 4 N. Hanover Street Carlisle, PA 17013 500 North Third Street P,O, Box 1004 Harrisburg, P A 17108 (717) 236-1485 () c. ", ~,:::} -::-:;-:1 ~C- Cr C-:" -j , ,J.;:- (-) -or, --j fE~'D ["'- ~31.':,~~ ,) .;- ;,.} 'T'; .-,,:;~ ') rO';/'T1 ~..1 I> -::' ~,.,~'.. ~-: r,) r" -.;:': HILTON- DIMINICK ORTHODONTIC: ASSOCIATES, P.C., : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff v. : NO. 04 - 4634 JOSEPH F. PAINLEY and CYNTHIA M. PAINLEY, Defendants : CIVIL ACTlON- LAW NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following Complaint, 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 ajudgment 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 SOUTH BEDFORD STREET CARLISLE, PAl 70 13 (717) 249-3166 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. HILTON - DIMINICK ORTHODONTIC: ASSOCIATES, P.c., : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 04 - 4634 CIVIL JOSEPH F. PAINLEY and CYNTHIA M. P AINLEY Defendants : CIVIL ACTION - LAW ANSWER TO COMPLAINT, NEW MATTER, & COUNTERCLAIM Counsel John H, Broujos for Defendants Joseph F. Painley and Cynthia M. Painley set forth below Answer, New Matter, and Counterclaim. I. Admitted. 2. Admitted. 3. Admitted. 4. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of the averment. 5. Denied. On the contrary Defendants are not indebted to Plaintiff. Denied that Exhibit A represents a true and correct copy of invoices for services rendered, On the contrary some contracted services for Orthodontic services were not rendered, Erin was fitted for full braces for upper maxillary, followed by removal of braces and fitted with splint, and fitted with a Hawley retainer for the lower mandibular, Plaintiff was not seen for monitoring and final appliances were not installed, This was to be done during the retention phase of treatment for a period of time to satisfY stability of the position of the teeth. Erin was to have been seen for a year or more after braces were removed, The original treatment fee included all work to be done, in three phases: Initial work was installation of appliances; second phase was monitoring for a year; and final phase was installation of permanent appliances (splints). Denied that interest is owed by Defendants to Plaintiff in any amount Denied that the statement in Exhibit B is a true and correct statement signed by Cynthia M. Painley, After reasonable investigation Defendants are without knowledge or information sufficient to form a belief as to the truth of the averment As to Exhibit A, after reasonable investigation Defendants are without knowledge or information sufficient to form a belief as to the truth of the averment Other services were not rendered, including follow up consultations to determine if any complications have occurred, 6. Admitted that Exhibit B contains a reference to claimant owing legal fees in the amount of 33 and 1/3 % of the outstanding balance, Denied that this or any sum or court costs are due. On the contrary, a 33 and 1/3% charge for legal fees is unconscionable, illegal, and not collectable. Proof is demanded. After reasonable investigation Defendants are without knowledge or information sufficient to form a belief as to the truth of the averment 7, Denied that Defendants owe any sum of money to Plaintiff and denied that Defendants have neglected to pay sums claimed unpaid. Defendants paid the bill monthly until they had financial problems in part emanating from the cancer of Defendant Cynthia, Plaintiff granted extension for delayed payments. Then on December 8, 2003, Defendant Cynthia was terminated without cause. Then on December 13,2003, Erin was terminated as a patient 8, Denied that the prices charged for services are just and reasonable and were the market prices therefore; on the contrary no sums are owed. After reasonable investigation Defendants are without knowledge or information sufficient to form a belief as to the truth of the averment NEW MATTER 9, Defendants incorporate herein paragraphs I through 8 above. 10. Defendants are not indebted to Plaintiff. Plaintiff breached any contract that existed since it failed and refused to perform services of monitoring and fitting her with new maxillary upper Hawley, required under the Orthodontic services promised by Plaintiff and inherent in the agreement II. Plaintiff had no right to terminate care and the contract, since Plaintiff has entered into a binding agreement, as evidenced by Exhibit B. 12. Erin came under the care of another orthodontist, who fitted her with new maxillary upper Hawley, performed monitoring, and performed other services, tasks which would ordinarily have been done by P and tasks to which Plaintiff verbally had committed itself when services began. 13. Defendants paid the bill monthly until they had financial problems in part emanating from the cancer of Defendant Cynthia, Plaintiff granted extension for delayed payments. Then on December 8, 2003, Defendant Cynthia was terminated without cause. Then on December 13, 2003, Erin was terminated as a patient 14. Plaintiff has no right to terminate care and the contract, since Plaintiff has entered into a binding agreement, as evidenced by Exhibit B. 15. Erin came under the care of another orthodontist, who fitted her with new maxillary upper Hawley, performed monitoring, and performed other services, tasks which would have ordinarily been done by p, 16, Services to Erin at the inception of work were fitting for full braces for upper maxillary, followed by removal of braces and fitting with splint and fitting with a Hawley retainer and other services for the lower mandibular. 17. In completed work by Plaintiff included failure to complete the treatment plan. 18. Plaintiff failed to perform required complete monitoring of Erin's Temora Mandibular Joint function (TMJ), after the braces were removed for regular checkup until installation of permanent appliances within a year or more during the retention phase of treatment; and further until stability of the position of the teeth was satisfied. 19, Plaintiff failed to install permanent appliances as agreed to in original agreement. 20. Erin was fitted by another orthodontist with new maxillary upper Hawley. COUNTERCLAIM 21. Defendants incorporate herein I through 20 above. 22, Plaintiff has contracted from an orthodontic firm for services of monitoring and installation of fitted new maxillary, with an initial consulation on August 27, 2004 with a current payment made of$50 due on billing of October 25,2004 with a balance of$45.00. Attached as Exhibit ;I? As of date of filing Answer, estimated costs are not available for future services, including follow-up protection visits (monitoring), required for periods every 6 to 9 months. 23. Defendants demand payment therefore. WHEREFORE Defendants asks the Court to dismiss the complaint and to award damages prayed for. Date: ,t? t5' o,..f:- TOP L A I N T IFF: NOT ICE TOP LEA D YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED PLEADING WITHIN 20 DAYS FROM THE DATE OF SERVICE HEREOF OR A JUDGMENT MAYBE ENTERED AGAINST Y U. John . I verifY that the statements made in this pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. D~~ d..-r;/d.OOLt c~, \2 -- C thia M. Painley I verifY that the statements made in this pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.SA. Section 4904 relating to unsworn falsification to authorities, Date: d>c:r: 2!; z...u:r( OCT-2~-2004 e~;a2 PM MINJUM.KEARNS 7177742::568 Minium ."d KlNlr"$ Ortho(/(Jntlsts 1411 Bridge Street N_ Cumberlflnd, PA 17070-1146 (717) 774.1200 Date: October 25, 2004 Reference: Erin Painley Mr. Joseph Palnley 6/7 Adams Road Carlisle, PA J 70J 3 _..'_..____,._,..__ All of your last statement, your account balance was 08/2712004 08/2712004 09/0812004 New Essix Appliance New Patient Consult Payment (Ck S2S0). Thank You Your remaining balance (Including amount due now) is: Total Now Due Current ,00 L }.I -6ODays- ._ i 4S,00 C-12o,days _ ,00 61-90 days .00 f2'x H .4 - ))$ p.et $ 4S,00 70,00 2S.00 .SO.OO ---- - $ 4S.oo --- $./5.00 over 120 dayS ,00 '" r", ,>:'." c::-) C --I c. el f''> "';, BUTLER LAW FIRM Ronald D. Butler, Esquire Attorney LD. No.: 09826 500 North Third Street P.O. Box 1004 Harrisburg, PAl 71 08-1 004 (717) 236-1485 lawyers@butlerlawfirm.com HILTON-DIMINICK ORTHODONTIC ASSOCIATES, P.C. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-4634 CIVIL JOSEPH F. PAINLEY and CYNTHIA M. PAINLEY, Defendants CIVIL ACTION - LAW REPLY TO NEW MATTER AND ANSWER TO COUNTERCLAIM AND NOW, comes the Plaintiff, Hilton-Diminick Orthodontic Associates, P.C., by and through its attorneys, Butler Law Firm, and files this Reply to Defendants' New Matter and Answer to Defendants' Counterclaim and in support thereof avers the following: REPL Y TO NEW MATTER 9. No response is required. 10. Denied. The allegations made in this paragraph constitute a conclusion of law to which no response is required. By way of further response and explanation, Plaintiff fitted the patient with a maxillary splint which serves the same purpose and function as a maxillary Hawley retainer. Plaintiff completed all orthodontic services on patient up to but not including basic follow-up or monitoring, for which Defendants were not charged. 11. Denied. The allegations made in this paragraph constitute a conclusion of law to which no response is required. To the extent a response is deemed to be required, said allegations are specifically denied. By way of further response, no Exhibit "B" was attached to Plaintiff's copy of Defendants' New Matter. 12. Denied. Plaintiff is without sufficient information and knowledge to form a belief as to the truth of the allegations made in this paragraph. As such, said allegations are specifically denied and strict proof thereof is demanded at trial. By way of further response and explanation, Plaintiff completed all orthodontic services on patient up to but not including basic follow-up or monitoring, for which Defendants were not charged. 13. Denied. Defendants last payment was in April.. 2003. Plaintiff did not learn of Defendant's cancer until after December 8, 2003. Plaintiff never granted Defendants an extension to make payments. Defendant was terminated for cause on December 8, 2003. Plaintiff referred the patient to another orthodontist for follow-up services by letter dated December 23,2003, because Plaintiff believed this would be in the patient's best interest. 14. Denied. The allegations made in this paragraph constitute a conclusion oflaw to which no response is required. To the extent a response is deemed to be required, said allegations are specifically denied. By way of further response and explanation, no Exhibit "B" was attached to Plaintiffs copy of Defendants' Answer, New Matter and Counterclaim. 15. Denied. Plaintiff is without sufficient knowledge or information to form a belief as to the truth of the allegations made in this paragraph. As such, said allegations are specifically denied and strict proof thereof is demanded at trial. By way of further response and explanation, Plaintiff fitted the patient with a maxillary splint which serves the same purpose and function as a maxillary Hawley retainer. Furthermore, Plaintiff completed all orthodontic services on patient up to but not including basic follow-up or monitoring, for which Defendants were not charged. 16. Admitted in part and Denied in part. Plaintiff completed all orthodontic services on patient up to but not including basic follow-up or monitoring, for which Defendants were not charged. 17. Admitted in part and Denied in part. Plaintiff completed all orthodontic services on patient up to but not including basic follow-up or monitoring, for which Defendants were not charged. 18. Denied. Treatment and/or monitoring of patient's alleged TMJ was never part of the treatment plan. Plaintiff completed all orthodontic services on patient up to but not including basic follow-up or monitoring, for which Defendants were not charged. 19. Denied. Plaintiff completed all orthodontic services on patient up to but not including basic follow-up or monitoring, for which Defendants were not charged. 20. Denied. Plaintiff is without sufficient information or knowledge to form a belief as to the truth of the allegations made in this paragraph. As such, said allegations are specifically denied and strict proof thereof is demanded at trial. WHEREFORE, Plaintiff respectfully requests this Honorable Court to dismiss Defendants' New Matter and enter judgment against Defendants in the sum of$1,701.63 and grant all such other relief as the Court deems appropriate. ANSWER TO COUNTERCLAIM 21. No response is required. 22. Denied. Plaintiff is without sufficient information and knowledge to form a belief as to the truth of the allegations made in this paragraph. As such, said allegations are specifically denied and strict proof thereof is demanded at trial. By way of further response and explanation, Plaintiff completed all orthodontic services on patient up to but not including basic follow-up or monitoring, for which Defendants were not charged. 23. Denied. It is specifically denied that Plaintiff owes Defendants the amount demanded or any amount whatsoever. WHEREFORE, Plaintiff respectfully requests this Honorable Court to dismiss Defendants' New Matter and enter judgment against Defendants in the sum of$I,701.63 and grant all such other relief as the Court deems appropriate. Respectfully submitted, BUTLER LAW FIRM BY:~~ Ronald D. Butler, Esquire I.D. #09826 lana Butler Toole, Esquire I.D. #80574 500 North Third Street P.O. Box 1004 Harrisburg, PA 17108 (717) 236-1485 NOV, 5.2004- !: 13P~-71i236i777- NO, 924 P, 7 VlUllFICATION I, K.enneth], Diminick, Secretary and Treasurer ofthl~ Plaintiffherein~ hereby certify that the facts set forth in the foregoing Complaint are true iU'ld correct according to the best of my knowledge, infon11ation and belief. 1 understand that any false statements herein are made sUbject to penalties of 18 Pa. C.S, ~4904 relating to unsworn falsifica.tio11 to authorities. Dated: r I / 12../ 0 if HILTON-DIMINICK ORTHODONTIC ASSOCIATES, P.c. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-4634 CIVIL JOSEPH F. P AINLEY and CYNTHIA M. P AINLEY, Defendants CIVIL ACTION - LAW CERTIFICATE OF SERVICE I, Jana Butler Toole, Esquire, hereby certify that on the 16th day of November, 2004, I served a true and correct copy of the foregoing Complaint by depositing same in the United States Mail, postage prepaid in Harrisburg, Pennsylvania, addressed as follows: John H. Broujos, Esquire Broujos & Gilroy, P.C. 4 N. Hanover Street Carlisle, P A 17013 500 North Third Street P.O. Box 1004 Harrisburg, PAl 71 08 (717) 236-1485 (") r--' c' " Ci ,- : 'I 1 --.,'," :,'.\ 1 .~",,' .c..:, ~ ,! _.J " .- ) -.-, i .. : r. :' i , '[ c:) 0', ., " HIL TON-DIMINICK ORTHODONTIC ASSOCIATES, p,c. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO, 04-4634 CIVIL JOSEPH F, PAINLEY and CYNTHIA M, PAINLEY, Dettmdants CIVIL ACTION - LAW PRAECIPE Please enter my appearance as attorney for Hilton-Diminick Orthodontic Associates, p,c., in the above-captioned matter. ~~.' Robert B. Lieberman, Esquire LD,#O?O'icr 500 N, Third Street, 12'" Floor Hanisburg, PA 17101 (717) 236-1485 " -- - HILTON-DIMINICK OR'flIOI:X:N1'1C A.SSCXCIATFS, P .C., Pla,i:ntiff IN THE COUR'r CF COMMON PLEAS OF C(]MBERLAi~TJ COt1NTY, l'F.NNSYL V ANJA v. NO'_U4..4634--_____,________ 20___ :JOSEPH F. PAJNr..EY and C"fN!'HIA M. PAWLEY, Defendants CIV".J. ACI'ION -- lAW RULE 1312-1 The Petition [or Appemtment of Arb'!:J"ators shaH be substantially in 'he Following ['>TIn: PETITION FOR Al'POLl\'T1\n:NT OF ARBlTR,\TORS TC,'H~ HONORABLE, THE JUDGES OF SAID COURT: .RcJtK~~J;:,,_J4~_Esquire.,_.,___, ,>-,ur;sel ,,,,. ,h~{Pl~intillJdd",,,d,,]t in the above action (or actions)\ respectfully repres(."nts :htit' .,,- 1 < The above-captioned action (or actions)i~ (ar~} ;1( ;",';31J.e. The dairn ofpJaintiffin the actior. is $ ..lLI!2.~,'.~'!..__ __,____ fh(; ~,:nunterc1alrn of the defcnr...anrin 1'l~t' aci:i0.i.'; is :~ ~Q,.9g ____ ~'<hl~ foUow>ng attorneys are interested m tile; easels) ~'~:j ':~)J!lst:ll}r Il't: X~,ef';V~iS(' (L~squaldled to slt 3S arh,:,t:ratOJ:'~ . R.~!Ii?:llLJ2.~...~itJ.er, -.-~WL6-_J~~'1..,~Jt.l~J;..J"Y..Q~lp~ .~~~-1O_-'-.,r.~_Ji;:Jltl,.i!.___ 'P.!-r..ujos.,.....F.sq... \}lHOtEf'C}R 12, YOUi' petitioner pra;t3 Y\jL~:r HOL(1Tf"J.,:C; ('Ut.1~-" to a!-;l?'Ji::~!" th~(.,e OJ arbitrator;j t;d \i\-;.,c'-,n t1:!!, ed.se s;J1~H he subrmtted. RespecrVJlly S,JbH~irt;.~0._ ~~.~ R&~!:'t B.. L.iel:):t'rf~ar:. ':'.:sqcLre ORDER OF' CO,illf A~\:.I) N"()\V, '~C',: ..J ~D cQ.n:.lfL'tJ.':....,fI'tl '.If tt.:."~ .\)['~g,}ing p~tJl!(Jn, . ~--,. ..__._-----_._..~._--.._..._." ------_.. -".--.- 3-\:3 L:e,. (..~..,J'.. E:...:c:.. ':-~',: ;2.pp(l,r:\:'~i ...~:.t,i:r?:Ur3 \"1 ~he abo'/e .::'3[.".; :'r~'l,.::.'::.;~j;:.-(" (-,r _"C~~')L~;' a.~ praye;j l~~~. Eo, ch" '_>'liJ:, :;~;,(X.:..,)'i: " }.<'F~.r2., i', f -Ii:). p ~ '0 t In:- 'g, - ~ \ ~ ~ rY C; }J r ";t? +-- ---L ~ *- ~ '"'l'\ "" "'" 1"" (.;'"\ -<') :?,. ...." .> l5\ '-"> m:r.:IDN--DIMINICK ORTHOf.XNrlC ASsc.X::IATF's, 1'. C. I Plaintiff n..:r rHE CorJ-:tT UF COMMON P.LE.AS OF C!JMBERLAi~l) COtJNTY, PENNS"'LVANJA v. NO._Q.4:..-4.63.4-______.__ __._._ 20__.__ ,1Q[{f:PH F. PATNLEY and CYNTHIA M. PATNU';Y i Defendants CIVIL ACllJ:ON - LAW RULE 1312-1 The Petition for App(,jn.tF;eni of ,~.rb)trators shaH he substantIally In the Following fonn: PETITION .FOR Ar'POINTMENl OF ARBITRA.IO.RS TC TIT}: HONOR.ABLE, THE JUDGFS ~)F '~AJD C'U)RT: Rr~"'x'ry---1_. ~B Li~L''\\.-U"''''-'f'l.'MT1 v ',. '-~~1.-(.....1 ~-:"r I'r ,-~~.~' t,Ai':;~I"P;-":''''''nt _~~.",:;hJ.._..____.~~~._~Q9Y.l.L~_,..__,""" .I,..,\:" ,,',J. . l;.tF~Jm ~'-." ",U-t J. :;t,'tlOTl (or actions), respectfully represt..11!'S :b..,t '''-'.- 1, The ab\>ve-captioned action (or actions) is \an.') :~t :,sue, m the G'.bove Th 1 r" 'ffb .'. '-."'"("d 6~ '. le l,!ann vI plamt:! . m t,e actIOY,.$ ~ ":LL::,_~.',..::.._.. __.., fhe (:ount~rc1alrn of the defJ.n'~'1,rn :n n'e aC:l''';:; is ,;~n.I)O C;l'~ fo),J,)w'ng attomevs ar~ interested m ;;,/;;; cas,,::(s} <.:; ..::);.:nse:: flfUr; :);.1,'f.~r';'i;;c ilisq',l:iililed to sit <3 S f:!r~J7,trator~. F!c.r:i'.dd D. B-..tl.c'.c Esc'" JaI"'l cntlpr ';-r,.-,,..,ip (;"t.y"' k'~,,;J p.~r.".,nc. ''"'''(': ~- - ._--. _N - -~.--~ .-..-." -" ~"._- ._...r.~,.._.__.._1..~L___._.__.:~__,__~_'.. ._'!~'_._--':..:~~l~4-'I'1..J:.. _.-'.....t'If,~.'.a:--.....-r._~..... :...~.H\.!Il. __.ol.-,...k>_ '~~"""~.J,-..,.-..1~_~'-1- nl)l.EICeJ~'(l}~, )'''0);;';.' petiboner pra~v'5 'yl.~~.\.-r lIor;(lr(".J.l>~ (.~(.4);'~ -::0 :J.ppcJi:;~tt.h((,~ (3} arbitrato:s to ,<: ,':"i'.I fr:' G",e ~.):n~i1 !:'Ie subrrmted J?l.t::Siiecrf1.1ily S'~;hlT..iftf:'~:~ ~~.~ !~(:t;i:-;;rt :~~ L:,;,:2~~.~1"rC:it!~,. '~.~5t~l::!.I-E: GE.~TlEIt OF' C;O!,iRf 1:.>:r~\'jO){ i?! It" A / } 0:(3 ',"'.'1 ~/ :1" l'r"l'lA.,._-,;~.,.,., ,.-:-'''f-i;. ('('('~jY'l''''' __L.__,,_.~..._,,_,,_._ ___u_._.....~'.',.,..I._,_,_.," .,,,1. ~ ,.."'__....,.,',, c.,. ,.J ~I:.,'r ut: P,~tlt!(Fl" '''~~f7=Lf~'---'---''7......r-:5;;:''J a.,;3 -N-:A4lW:~~-~ T.,,;;(!, ;':"":(.'~., ....."" ./U'. r . /7,,/ A AoU A / ';" "~.' ""'_,' ,':'1.'.' ,(.;,,", ~i""~ '.'-;';','" c,~ ",..11~: i"l t+,,,, abO','f~ ~. ~-,/c ....,~.t'"_~_._~ ../.~~'-/?~~_~~'___ --\..:-'-1.; .......' -;"~' '"~ ...,J. ~j. _'. "'-.......<... .~., _ \0.. > .. .:"'~lp:.i_~\f'_~~,..;. ~:;~i.r;.~._~ ~,'.:.. ~.~>~~~}r~~~: a'=. fJ!'Gye;j i~~!. 4tf A'r__1J eI.-. d,~ #.',' .1,;, '",'N'. . ~ ~ :J/J.:>j-J I .'J,.... s; &:: ~ f J\~-: ~26 ;.;- :1: 9E5 ac: Lua.. -l t.,.. [L1 ......;:.r:. ~. I.!... o "- C:,,- C'? C\j n::: 'Il<K"~ -- -<- v" l:;;;) = c~ ~ ttJ N C"') C'") 2: %~~ 2 (fj p ~ - 't- ~ ~ I;) ~ 0- -- ~ ~ ~ ~ - ~ C) }J 6"'"- t ~ ()- ~ ~ ~ ~ -I-- ::t -L r:::? tn ~ rt..< '~...I, Jef ~j i..lO~ -\)\t^(}..hCtc' 0t<\\to~)f->lG ~S $' c). ( f', C . In The Court of Common Pleas of Cumberland , PJaintiff "Tb<;;E"\r"t1 PAcNL.E't' County,PennsylvaniaNo.O't - "'~'-t c. <( t-J~ <.-\U;" l1,l , f' AWL. EX Defendant Civil Action.. Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution ofthe United States and the Constitution of this Commonwealth and that we will discharge the duties of our office with fidelity. ~0iJr-.. Signature {Mbl(, ~A nO\) City, tl JJ?/9 Award We, the undersigned arbitrators, having been duly appointed and sworn (or affIrmed), make the following awar~: (Note: If damages f~r d~lay are ~awarded, they shall be se aratelyytated,) ~e. \', -'11 0.00 c1Al\,r\ r (') ~s: c::e. t""{ So: s-o . 61<.~R-2 6, f\8EW Name (Chairman) A'66{..N (.J'uJ 0R=tC€< Law Firm '3'l t:;, ~~~ ::>1'.. Address cAP-UClE r It \lOG' City, \ Zip ti 1()0)Cj ;?U'.ufll/t1. V Signature ('''~\?~<.''~._,''-~~:'''''-''-''''''\) ':"0 (~_~":'_'"Y-:-:J _-~,. Signature fI ,,\ A i'~ t-cY" .~ II Cia. \I't::.s. Name ~ ftL.~"t\ M 'Serul'\;~~ Name TUID ~I\"" Of~:u) Law Firm ~r::.....I/'VE'. Law Firm H ~, ?:\\ Address (/4 \JJ C:1C.V'I~5:f' Address . .! ,,t., I /l/l"--..v,e,,\.C'LNI. ,,/(, City, J r ZiP,), 7~) <)") 111003;). "l Zip Date ofHearing:~( \l( (j<;;"' Date of Award:~ s. (Insert name if applicable.) /h", / Iu.A ' '1/!//,Mr1M /rv/ ~ \ ~ ---. \ '" ~\?=c.'--=' ) ~~........ - ~-(-~~ Notice of Entry of Award Now, the ~ I 'St day of ..Al~'I\/l,,,b(r , 20 0)' , at {(;07 , L.M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys, Arbitrators' compensation to be paid upon appeal: $ [)90 By: rothonotary Deputy .:''\:; "-. o ~~\p \0 ~ " --' --\-.- -:-, "::" ~ .-.., "" ~~ ';:' .~ ., ~' ~ ,) '.~' ...------ . -~ :~ ~,.,. .~ ':::'. r-. ~-\ (j0 " '" ~s- ~-::) c ~~ .:J ;-0; ->-'f:' c; '- Q '..-"\ I ") 'I--'~ (3, p -r-:, (' " . , "'" HIL TON-DIMINICK ORTHODONTIC ASSOCIATES, p,c. Plainti ff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, NO, 04-4634 CIVIL JOSEPH F, PAINLEY and CYNTHIA M, PAINLEY, Defendants CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: Pursuant to Arbitration Award entered on November 21, 2005, a copy of which is attached hereto, please enter Judgment in favor of the Plaintiff, Hilton-Diminick Orthodontic Associates, p,c., and against the Defendants, Joseph F, Painley and Cynthia M. Painley in the amountofSl,04B,5G, .t'q7c>.oQ ancL cariS' o-l! .!l7J>.~D..t. Dated: January 1],2006 dZf~jk- Ronald D, Butler, Esquire Attorney for Plaintiff LD, #09826 500 North Third Street, 12th Floor P,O, Box] 004 Harrisburg, PA 17]08 (717) 236-1485 ~^ii - ...... --- f\ ~ i; ~:g -~ lIS .--- - ff7 \' =is- C- D fl! :e r- -----. ~ ~r - f I? 'T- , \ -- (r<- ~1= r.- \' . ...-i (. lo~-\)\N~lNvC\;;: 0~\\to\vc{'.JlG ..'\;--:;; ~ C, ( P. C . In The Court of Common Pleas of Cumberland -!JIaintiff 7Cl"G7et f'A-(N LE , Connty, Pennsylvania No. O"t - <-$;~ 't (..'-(lv""t-\( A !lA., 0A(Ni..~ Defendant Civil Action - Law, Oath We do solemnly swear (or affinn) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office with fidelity, ~C1~~ Signature 1;1&44fl1/41. V Signature f'\,i..~f>tl }JI, "'Se(i)l'\;~~ Name ';,' ...,~ , ( C":s:----,,--...., --'-.. " , "'~',,":.. -', - ';':,~::-) ".-....'- ..""", Signature ~ ^ ~, ,,~. f I J\ r\$~{,'iV' I CiQ j"r~ Name' .:':, EP..~~ 5~ A8€41 Name (Chairman) A'86'-t0 UvJJ Offt~ Law Finn T VIO ~~"" 0 f~: (e~ Law Finn .r; G-. VV '2_ Law Finn '5'l E'", ~'\fVl..~ 51 ~ Address H c" ?:\\ ~J Address (/4 llJ Q{"v~ ~ ::;:{:., Address lAAuCiE Pit \"10'lF City, I Zip ti I Oc.1) J q Ltll L,I \ , ?A \10$ City, i:J IJ?/9 Award We, the nndersigned arbitrators, having been duly appointed and sworn (or affIrmed), make the following awar~: (Note: ~ damages f~r d~lay are "awarded, they ~hall be s~aratel~tated.) UJe. .~cll.~'-lfKe ptbiA~'~ I(,.J~ 6;;{)1l.;.~Ktt~ Q,[U,~O r.kJl,..\' {Of]>~.c ~ f""Ui::, s-a , (' ,j "" \". \;oUv-r C\ Z' \ IP '-->1 7;) <;") Zip Date ofHearing:~\,( e,-:;- Date of Award:---1i{i"\ ( OS- I/h", I II.. ..' , to'V'1/I.-fM{ ;r Vf. .r;;--- \~.~ 'j - '-- ':::) J.c-= .' s. (Insert name if applicable.) Notice of Entry of Award Now, the 'd I st day of tI/oVv\b(r, 20 0) , at '1;07 , P.M., the above award was entered upon the docket and notice-thereof given by mail to the parties or their attorneys, Arbitrators' compensation to be paid upon appeal: $ f}?O By: ~" rothonotary Deputy -.:: C', -.,) ("J --4 =r:: ,-;j L IN TIIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Defendants o Confessed Judgment ~ Other FileNo. 04-4634 CIVIL Amount Due $1,948. so 49'10. o~4-- Interest $ 41 . 94 ( as 0 f 9 /18/06 ) Atty's Comm Costs .f 7P. ~O 4-- Caption: Hilton-Diminick Orthodontic Associates, P.C., Plaintiff vs. Joseph painley and Cynthia Painley, TO THE PROTHONOTARY OF THE SAID COURT: 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. Issue writ of execution in the above matter to the Sheriff of C:l1mnpr 1 ~"O r.mm ty County, for debt, interest and costs, upon the following described property of the defendant (s) Please levy against all personal property of the Defendants, Joseph Painley and Cynthia Painley Said ppr~onal propprty i~ located at 617 Adams Road, Carlisle. PA 17013. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of 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 the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(st Address: 500 N. Third St., 12th Fl. Harrisburg, PA 17101 Plaintiff Date o (Indicate) Index this writ against the garnishee (s) as a lis ~ defendant(s) described in the attached exhibit. 'It II{ Ow Signature: Print Name: Attorney for: Telephone: (717) ?'ifi-14Fl'1 Supreme Court ill No: 80'176 ~, ~ :t- 7f- ''It ~ ..... ~ rl'. ~ W ~v ~ ~ ~ C), ~ 1. ~ t ~~ ~~ r--(f [ "\ ~ Vt-- ~ -oJ.) '" ~ :- . 'en ~ \) ~ C>C"l\> ~ ~ \ ~~ " ~ ~11~ e:;t- .. ,- .T ... '""' 'f-f - " ...- G' .,' ~.....,~' ~; ~ - t ~~ ~ l:.- -- ~ r- V '011 "'" '" HILTON-DIMINICK ORTHODONTIC ASSOCIATES, P.c. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-4634 CIVIL JOSEPH F. PAINLEY and CYNTHIA M. P AINLEY, Defendants CIVIL ACTION - LAW PRAECIPE C") "-> c.:::;) 0 TO THE PROTHONOTARY: ~ ~ ~ ;.~ (: ~ ::2-n ,_. :r: ril;::::: Pursuant to Arbitration Award entered on November 21,2005, a copy~:ofwhich is :'='12] _.f - - co ,<": y- attached hereto, please enter Judgment in favor of the Plaintiff, Hilton-Diminick orl1?dont@? 2~~ ,-~~ r-- ~~ IT1 Associates, P.c., and against the Defendants, Joseph F. Painley and Cynthia M. Painl~ in the :D , a --<; amount of $1 ,048.50. Dated: January 11,2006 tf6!4k- Ronald D. Butler, Esquire Attorney for Plaintiff J.D. #09826 500 North Third Street, 12th Floor P.O. Box 1004 Hanisburg, P A 17108 (717) 236-1485 , "' ~\ t:-t'Q ~-..l- \")\N\.W~CK' (..'.~{~\~ ~C:.~N lG /1iSS-C;, ( p_C. _ P)aintiff "7Cs:~c-t PA-(,V~ LE,-<", C5( C;..f"t"l-$;~ it"" 0Al}-Ji..~ Defendant In The Court of Common Pleas of Cumberland County, Pennsylvania No. (5 'i' - '-\'-'') t..t Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office with fidelity. ~a~ Signature C~JI;~lll ~A \10$ City, Zip J Q id IJ<t/9 fi 00 J t Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following awar~: (Note: If damages f~r d~lay are ..,awardeft, they shall be se arately~tated.) C '\ ,e, _' ~ ,C\~ -l' , I ' '(vi ( ~ '--71' 0.00 ~~A ("'ft~h: ~ f""{g, s-o . 6l<.~~ 0;. PSt24/ Name (Chairman) A'66U.J (.,)oJ Qt=Rce:c Law Firm '3'l t" ~~-r- 51... Address l..4AuC'U? Pit \'10\)> City, l Zip 07Ut1J( 1/11. V Signature ()' fl',J..u.d #I. -Se{D\'YI;~~ Name . (~-" , ~-", ",', 0,., )\ '-"--'.~~~-:.:_.. .:~t.:.d.:~~~ Signature f\, ~ ~( . )~ ~ Q vr ~ ~ L\;'t'~yu Name..~ T Vf D ~(A\oJ 0 f~; (e) Law Firm .s. G..-. N' E:... Law Firm l~ ~. ?;t\ ~J. o f!"M ~ -' ~v'l <: ~t-' J?C\ ( /q to Address Address i 7d <)) Date ofHearing:~ lll&~ Date of Award: l\(\\ (0) s. (Insert name if applicable.) I~ IM.~ .\. ((( ~~~ \ -"--~ " " ',,-,- ~. __ cC5)~ - .-. -- Notice of Entry of Award Now, the 'd I S\ day of lU(J\/~'1'\.b(r, 20 0) , at ~.DI , P ,M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ //90 By: rothonotary Deputy " JUDGMENT NOTE $8,222.65 November 6, 2003 FOR VALUE RECEIVED, we promise to pay to the order ofHILTON-DIMINICK ORTHODONTIC ASSOCIATES, P.c. the sum of Eight Thousand Two Hundred Twenty-Two and 65/1 00 ($8,222.65) Dollars, without offset, together with interest at the rate of six (6%) percent per annum, in minimum installments of One Hundred Twenty-Five ($125.00) Dollars every two (2) weeks, the tirst payment due on Friday, November 7, 2003 and on every Olner Friday thereafter until paid in full. Cynthia M. Painley is an employee of HiIton-Diminick Orthodontic Associates, P.C. and agrees to have the One Hundred Twenty-Five ($125.00) Dollar payment paid to HiIton-Diminick Orthodontic Associates, P.C. by means of a payroll deduction. On non-payment of any installment when due, all remaining installments shall, at the option of the holder and without notice, become immediately due and payable. Ifthis Note is placed in the hands of an attorney for collection, we agree to pay as a reasonable attorney's fee 15% of the amount due and owing on this defaulted Note. To secure payment ofthis Note, we hereby authorize, irrevocably, the Prothonotary, Clerk of Court or any attorney of any court ofrecord to appear for us in such court at any time before or after maturity and confess judgment against us in favor of any holder of this Note with or without the filing of an Averment of Default, with release of enors, without stay of execution, and for such amount as appears above, together with charges, attorney's fees and costs as herein provided, and we hereby waive and release all benefit and relief from any and all appraisement, stay or exemption laws of any state, now in force or hereafter to be passed. 2--- ~ .'-- r '~.-"-------,. ~d L " '-'" . ~ ... \....~, -, ~ ~ Cynthia M. Painley e~ dP~., . . Joseph F. Painley -r- ... EXPLANATION OF RIGHTS (Full Confession) A. We clearly and specifically understand that by signing a note dated November 7, 2003 in the amount of $8,222.65 payable to Hilton-Diminick Orthodontic Associates, P.C. which contains a Confession of Judgment clause: 1. We will authorize the Payee(s) to enter a judgment against us and in its favor which will give the Payee(s) a lien upon any real estate which we may own, including our homes; 2. We will give up the right to any notice or opportunity to be heard prior to the entry of this judgment on the records ofthe court; 3. We will agree that the Payee(s) can enter this judgment without any proof of non-payment or other default on our part; 4. We will subject all of our property, both personal and real estate, to execution (and Sheriffs Sale), pursuant to this judgment, prior to proof of non-payment or other default on our part; 5. We will be unable to challenge this judgment, should the Payee(s) enter it, except by a proceeding to open or strike the judgment and such a proceeding will result in attomey's fees and costs which we will have to pay. B. We know and understand that it is the Confession of Judgment clause in the above-described note which gives the Payee(s) the rights enumerated in sub-paragraphs 1 through 5 of paragraph A above. IF WE DO NOT SIGN A NOTE WHICH CONTAINS A CONFESSION OF JUDGMENT CLAUSE, WE UNDERSTAND THAT WE WOULD HAVE THE FOLLOWING: 1. Th~ [igllc [u have nuiiu; ancl an opponuIlity to be heard prior to Judgment; 2. The right to have the burden of proving default rest upon the Payee(s) before our property can be exposed to execution; 3. The right to avoid the additional expense of attomey's fees and costs incident to opening or striking off a confessed judgment. C. Fully and completely understanding these rights which we have prior to signing the above-described note; and clearly aware that these rights will be given up, waived, relinquished and abandoned if we sign the note, we nevertheless freely and voluntarily choose to ... sign the note, our intention being to give up, waive, relinquish and abandon my known rights (as described in paragraph B above) and subject ourselves to the circumstances described in paragraph A above. WITNESS: WE HAVE READ THIS ENTIRE FORM AND WE FULL Y UNDERSTAND ITS CONTENTS (6)/~' -1 I:4bJ.----- COMMONWEALTH OF PENNSYLVANIA COUNTY OF -D2"'}lhl-l\ ) : SS. ) On this, the 31--J day of UCCW) t"!t.-- ,2003, before me, a Notary Public, the undersigned officer, personally appeared CYNTHIA M. P AINLEY and JOSEPH F. PAINLEY, known to me (or satisfactorily proven) to be the persons whose names are subscribed to the within instmment, and acknowledged that they executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. .........., NOTmAl.. SEAl. ROSAtfE M. THCtiPSON, ~ NIle L.owIr Paldm Twp., DauMn COIIIty My CommIIaIon e;na Mirt:h 28, 2G06 . /---.) ---\ /J / I II)' . II'! (-fl-.-- '.a,__ N~taryP4&1it--- My Commission Expires: '~ I.',~ L i ) WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 04-4634 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HILTON-DIMINICK ORTHODONTIC ASSOCIATES, P.c., Plaintiff (s) From JOSEPH P AINLEY AND CYNTHIA P AINLEY, 617 ADAMS ROAD, CARLISLE, P A 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell PLEASE LEVY AGAINST ALL PERSONAL PROPERTY OF THE DEFENDANTS, JOSEPH PAINLEY AND CYNTHIA PAINLEY. SAID PERSONAL PROPERTY IS LOCATED AT 617 ADAMS ROAD, CARLISLE, P A 17013 . (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) Ifproperty 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 $970.00 Interest $41.94 (AS OF 9/18/06) Atty's Comm % Atty Paid $81.75 Plaintiff Paid L.L. $.50 Due Prothy $1.00 Other Costs $78.50 Date: SEPTEMBER 14, 2006 (Seal) By: Deputy REQUESTING PARTY: Name JANA BUTLER TOOLE, ESQUIRE Address: 500 N. THIRD ST., 12TH FL. HARRISBURG, PA 17101 Attorney for: PLAINTIFF Telephone: 717-236-1485 Supreme Court In No. 80576 HILTON-DIMINICK ORTHODONTIC ASSOCIATES, P.C., Plaintiff v. JOSEPH F. PAINLEY and CYNTHIA M. P AINLEY, Defendants TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW NO. 04-4634 CIVIL PRAECIPE Please satisfy the judgment entered in the above-captioned matter. Dated: December 18, 2006 {lalJk Ronald D. Butler, Esquire Attorney for Plaintiff LD. #09826 Butler Law Firm 500 North Third Street P.O. Box 1004 Harrisburg, PAl 7108-1004 (717) 236-1485 r-:> c:::> c::::> 0"' o rn (J - ~ ..-\ :r:-n rne, ~S~~), .- ',', :~;:i~, ~ ;...::. \.D -:J _~;O> -,"" r:-? o cr"'~ ~ .. ........ R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned SATISFIED. Sheriffs Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Garnishee Bad Check Charge Postage TOTAL $ 18.00 19.40 .50 1.00 5.28 30.00 20.00 94.18 /'9- j:2-/or/c" Pd by Defendant C) ~ SO~ /~ ~ .,.~,r~ R. Thomas Kline, Sheriff -4:: (' \J.J "<". ~" I,', ' l '. . . I '. " I 4 . : ~'~ A"\ w... .l. ~. C1 a.uJ k ~I\.lwb~l~ By. Claudia A. Brewbaker !1E<:JJ ~__2 =:-:=' ~dhj [Uh {is; ,.,,-~ z Z'Z j ,.... . C.J ~ G dJS quaz ... "(~ . -t .1 I, ':J Ck. S,"S'LJ (.. ~ / y(, -jl.-~ WRIT OF EXECUTION and/or ATTACHMEi\i1 COMMONWEAL TH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) '\0 04-4634 Civil CIVIL ACTION LA \V TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HILTON-DIMINICK ORTHODONTIC ASSOCIATES, P.c., Plaintiff (s) From JOSEPH PAlNLEY AND CYNTHIA PAINLEY, 617 ADAMS ROAD, CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell PLEASE LEVY AGAINST ALL PERSONAL PROPERTY OF THE DEFENDANTS, JOSEPH PAINLEY AND CYNTHIA PAlNLEY. SAID PERSONAL PROPERTY IS LOCATED AT 617 ADAMS ROAD, CARLISLE, P A 17013 . (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 $970.00 L. L. $.50 Interest $41.94 (AS OF 9/18/06) Atty's Comm % Due Prothy $1.00 Other Costs $78.50 Atty Paid $81.75 Plaintiff Paid Date: SEPTEMBER 14, 2006 (Seal) Curtis By:~~ Deputy REQUESTING PARTY: Name JANA BUTLER TOOLE, ESQUIRE Address: 500 N. THIRD ST., 12TH FL. HARRISBURG, PA 17101 Attorney for: PLAINTIFF Telephone: 717-236-1485 Supreme Court ID No. 80576 ... .. DISTRIBUTION ATTY FOR PLTFF: Jana Butler Toole WRIT NO. 2004-4634 Civil Hilton-Diminick Orthodontic Assoc. P.C. -vs- Joseph Painley & Cynthia Painley Real Debt Interest Attorney's Comm. Writ Costs, Atty Writ Costs, Pltff. Miscellaneous Attorneys Fees Sheriffs Costs: Docketing Poundage Posting Sale Bills Law Library Prothonotary Service Postage Advertising Postpone Sale Bad Check Charge Surcharge Garnishee Levy TOTAL Defendant Paid to Sheriff Advance Costs Total Collected DISTRIBUTION Pd. To Pltff. Refund of Adv. Costs Pd. To Prothonotary $ 970.00 41.94 81.75 78.50 $ 1172.19 $ 18.00 19.40 .50 1.00 5.28 $ 30.00 20.00 $ $ $ 1172.19 150.00 1.50 94.18 1266.37 150.00 1416.37 So Answers: ,....,~ l~ ~ R. Thomas Kline, -r --. " Sheriff Bt1J1J~~~11