HomeMy WebLinkAbout12-2953U.S. RENAL CARE, INC. f/k/a
DIALYSIS CORPORATIO14 OF AMERICA
d/b/a DCA OF EDGEFIELD,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. Docket No.: ?a - o?Q U Vlf/it
MATTIE STEVENS.
'
Civil Action - Law -
Defendant
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
the complaint and notice are served, by entering a
written appearance personally or by attorney and
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are warned that if you fail to do so the case may
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any money claimed in the complaint or for any other
claim or relief requested by Plaintiff. You may lose
money or property or other rights important to you.
YOU SHOULD TAKE THIS P
LAWYER AT ONCE. IF YOU DO-NO] IAVE
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, PA 17013
1-800-990-9108
717-249-3166
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AVISO
LLEVE ESTA DEMANDA A UN ABOGADO
INMEDIATAMENTE, SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO
SUFICIENTE DE PAGAR TAL SERVICIO.
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TELEFONO A LA OFICINA CUYA
DIRECCION SE ENCUENTRA ESCRITA
ABAJO PARA AVERIGUAR DONDE SE
PUEDE CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD
STREET CARLISLE, PA 17013
1-800-990-9108 -1?
717-249-3166
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IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
U.S. RENAL CARE, INC. f'k/a CIVIL COURT DIVISION
DIALYSIS CORPORATION OF AMERICA
d/b/a DCA OF EDGEFIELD,
Plaintiff
V.
Docket No.:
MATTIE STEVENS,
Civil Action -Law
Defendant
COMPLAINT
NOW COMES, U.S. Renal Care, Inc. f/k/a Dialysis Corporation of America d/b/a DCA
of Edgefield ("U.S. Renal Care"), by and through its attorney, Capozzi & Associates, P.C., and
makes the following Complaint for a money judgment against Defendant, and in support thereof,
respectfully avers as follows:
1. Plaintiff, U.S. Renal Care is a registered Pennsylvania limited liability corporation
having its principal a place of business at Camp Hill, Cumberland County, Pennsylvania.
2. Defendant Mattie Stevens ("Patient' or "Defendant") is an adult individual with a last
known address at 37 Monument Drive, Johnston, South Carolina 29832.
3. The clinic formerly known as DCA of Edgefield is an operating subsidiary of U.S.
Renal Care with a dialysis clinic located at 306 Main Street, Edgefield, SC 29824.
4. U.S. Renal Care provides dialysis treatments and services to its patients.
5. On or about November 9, 2007, Defendant executed a Consent for Hemodialysis
Agreement ("Consent Agreement") to allow Defendant to receive regular dialysis treatments
2
From U.S. Renal Care as scheduled by her physician and U.S. Renal Care. A true and correct
copy of the Consent Agreement is attached hereto and incorporated herein as Exhibit "A."
6. On or about November 9, 2007, Defendant executed a Patient Assignment and
Authorization of Payment of Insurance Benefits Agreement ("Assignment and Authorization
.Agreement''), which required. the Defendant to assign and transfer any insurance money or
benefits that. she received for the dialysis treatments from U.S. Renal Care. A true and correct
copy of the .Assignment and Authorization Agreement is attached hereto and incorporated herein
as Exhibit "B."
7. Paragraph 5 of the Assignment and Authorization Agreement provides that Defendant
"hereby acknowledges that, notwithstanding the foregoing assignment and authorization of
benefit payments to U.S. Renal Care, the Patient shall be responsible for any and all charges and
costs billed by U.S. Renal Care for dialysis treatments and related services ... and that U.S.
Renal Care is authorized to bill the Patient directly for payment of such charges and costs."
8. U. S. Renal Care, ,at the special insistence and request of Defendant during the period
of November 2007 through February 2009 ("Dates of Service"), provided numerous separate
dialysis treatments ("Dialysis") at the rates and on the dates set forth in U.S. Renal Care's
business records ("Account Statement"). A true and correct copy of the Account Statement is
attached hereto and incorporated herein as Exhibit "C."
9. On April 2 and June 9, 2010, U.S. Renal Care's counsel mailed to Defendant a
demand letter, which provided information on how to pay the debt owed to U.S. Renal Care. A
true and correct copy of the demand letters are attached hereto and incorporated herein as
Exhibit "D."
COUNT I - BREACH OF CONTRACT
10. Paragraphs 1 through 9 are incorporated herein by reference.
11. The rates and total charges set forth in the Account Statement are just and
reasonable and are the rates that Defendant agreed to pay for the Dialysis.
12. Under the terms of Defendant's policy with her insurance provider, Blue
Cross/Blue Shield of South Carolina, Defendant received monthly checks from Blue Cross/Blue
Shield of South Carolina pursuant to the claims filed by U.S. Renal Care.
13. Defendant's insurance provider did not always pay 100°,'/0 of U.S. Renal Care's
claims, which resulted in Defendant owing a co-pay to U.S. Renal Care ("Co-pay")
14. Pursuant to the Assignment and Authorization Agreement attached as Exhibit B,
Defendant was required to transfer the payments she received from Blue Cross/Blue Shield of
South Carolina directly to U.S. Renal Care on a monthly basis.
15. The amounts that Defendant received from Blue Cross/Blue Shield of South
Carolina pursuant to the claims submitted by U.S. Renal Care are indicated in the "Amount
Paid" column.
16. As provided from Blue Cross/Blue Shield of South Carolina's records, Defendant
received a total of $38,400.64 from Blue Cross/Blue Shield of South Carolina for the Dialysis
treatments during the Dates of Service.
17. Defendant failed to transfer the insurance checks that she received from Blue
Cross/Blue Shield of South Carolina.
18. The total amount of principal that has become due and owing by Defendant to
U.S. Renal Care as a result of her failure to transfer the insurance payments that she received is
$38,400.64.
4
19. To date, Defendant has failed and refused to pay the total due as provided under
the Account Statement and the Assignment and Authorization Agreement.
20. Under the terms of the Authorization and Assignment Agreement and
Defendant's insurance policy agreement, Defendant had a duty to transfer $$38,400.64.
21. Defendant's failure to pay her Co-pay, her failure to transfer the insurance
payments, and her failure to cure her default with U.S. Renal Care pursuant to the Assignment
and Authorization Agreement constitute a breach of contract.
22. U.S. Renal Care has been financially damaged in the amount of $$38,400.64, plus
interest and costs of collection.
WHEREFORE, Plaintiff, U.S. Renal Care, demands judgment against Defendant in the
sum of $38,400.64, plus interest at the legal rate of 6% per annum from the date of the judgment.
COUNT II - QUANTUM MERUIT - UNJUST ENRICHMENT
If this Honorable Court should find that an express contract did not exist between U.S.
Renal Care and Defendant, which is denied, then, in that event, U.S. Renal Care pleads the
following alternative cause of action in quantum meruit against the Defendant.
23. Plaintiff incorporates paragraphs 1 through 22 of this Complaint as if set forth at
length herein.
24. Having requested U.S. Renal Care to provide the dialysis treatments and U.S.
Renal Care having done so to the benefit of Defendant, Defendant became liable to U.S. Renal
Care for the just and reasonable charges for the Dialysis.
25. The Defendant has been unjustly enriched by accepting the Dialysis.
26. The rates reflected in the Account Statement as Exhibit C are the just and
reasonable rates for dialysis treatments and services.
27. The total value by which Defendant has become enriched on account of the
Dialysis is $38,400.64, as is more specifically reflected in the Account Statement.
28. U.S. Renal Care has demanded Defendant pay this amount, but Defendant has
failed to do so.
29. To date, the Defendant has not paid the total amount due.
WHEREFORE, Plaintiff, U.S. Renal Care, demands judgment against Defendant in the
sum of $38,400.64, plus interest at the legal rate of 6% per annum from the date of judgment.
COUNT III -CONVERSION OF MONEY
30. U.S. Renal Care incorporates Paragraphs 1 through 29 of this Complaint as if set
forth herein.
31. Defendant was aware that due to the contractual relationship between Defendant
and U.S. Renal Care pursuant to the Assignment and Authorization Agreement, the insurance
payments Defendant received from Blue Cross/Blue Shield of South Carolina properly belonged
to U.S. Renal Care.
32. Defendant had a legal and contractual duty to safeguard and forward the insurance
payments by Blue Cross/Blue Shield of South Carolina made payable to Defendant to reimburse
U.S. Renal Care for the Dialysis it provided to her.
33. During the Dates of Service, Defendant's insurance provider paid to her
$38,400.64.
34. Defendant intentionally and permanently retained possession of the monies owed
to U.S. Renal Care by failing; to transfer a total of $38,400.64 of the insurance benefits Blue
Cross/Blue Shield of South Carolina paid to her as required under the Assignment and
Authorization Agreement.
6
35, Defendant's intentional possession of and her failure to forward the Blue
Cross/Blue Shield of South Carolina insurance monies to U.S. Renal Care for the Dialysis
provided to Defendant constitutes conversion.
36. U.S. Renal Care has been financially damaged by Defendant's conversion in the
amount of at least $38,400.64.
WHEREFORE, Plaintiff, U.S. Renal Care, demands judgment against Defendant for
conversion in the sum of $38,400.64, plus interest at the legal rate of 6% per annum from the
date of judgment.
Respectfully submitted,
CAPOZZI & ASSOCIATES, P.C. 1? ja
Dated:' _ By:
holic, Esquire
Philip C. tr86341
Attorney 1200 Camp Hill Bypass, Suite 205
Camp Hill, PA 17011
(717) 233-4101
Attorneys for Plaintiff
7
11/09/200'P 141:17 8030,73929 EDGTUA-D rr,'A PAGt' 08/17
DIALYSIS C4iltPORAT'ION d A.MlMICA
DCA OF EDGEII'1 I LD
• ?' 1 SE?1 R 1F?>i?11?? >r . IyY,?1 ? .
ipINumber:, _ ` .. nare_ I ar?
( it I, the undersigned patient;
( ) 1, tho undersigned parent or guar an of the above patient who is tinder
18 years of ago or otherwise iucat ablu of consonting;
hereby request and authorize Tar. SOU!"V...?_. and whomever he or she may
designate as his or her associato or assistant to Administer t ine (or to the above nuied
patient) tho procedure known as hemodialysis, under such onditions as shall be deter3. hwd
by the pi 'slrtan (s) in attendance. I agree to abide by the I Mcies, rules, and egula00 s
established by the above named Dialysis Unit in can)+% t Its hernodialysis progtur.
It has been explained to )no that homodittlynis is a i?rocMu used in the caso of patients With
iatpainnent of failure of kidney function by which certain =pooents of the blood arc
separated by a semi-permeable substance which permits th passage, of. certain molecules and
hWers that of others when the blood Is circulated through t artificial kidney, called a
dialyzer, I understand that there. axe different t}j)es of'equi cnt employed for the dialysis
treatmem and Meront typos of atlificia.l kidlwys (dialyzer.) ttsed In tiro process.
l aoknowledgo that tlr?o possiUlt: ta$l?s and compllciitians of emodfalysis such as but not
limited to leakage of the dlnlyrer, changes W blood prGSSU artd malfunction of equipment
have been explained to me by the professlonal personne) o- tiro Malysi.s Unit and I accept, on
behalf of myself ancbbr the above patient the dialysis trea ettt with all potontxal risks and
complicaatiomg. I also understand that any disorder, which afflicts me, can have effects on my
treatment and on myself during the Ilene that I am recelvit a dialysis treatment but that this
fact does not mean that the dialysis treatment land atVtltina to do with the development of the
problem related to this condition. I forthor consent to the a ministration of such drugs,
transfusions of blood! or, blood components, or any outer tr atmont and testing, including IVV
tt:4qting, tlccmCcl necessVkty Or desirable in fhe jud&:ent of e physician (s) in attendance,
I am aware that the practice of medicine is not amt exact scf nco, and I acknowledge that 110
guarantee, wa malty o£zeptesotttatiozl wht3tsoevel leas been offered or made to me or anyono
on my bahalf e nvz errting the results of the hemodialysis pt eedu>:e.
Sigttaturc• ? ?-J?'/L??._.. of ._ .._._ .. .__._ ?_ ...
1 P?aricnt ? ? ?? }?c?ai Gtt?rdlan or Paccnt'
Print Nerve:
Vlitness,{? _ _ )7atc: ?,
1'// -?
EXHIBIT
it/rS /zC'0? 1?t,17 E3tiit.:i13229 FtX3F'lkt.U ;1, Ptw1F 16/17
DIALYR$ CORPORATION OI AAU UCA
PATIENT ASSIGN EN'T AND
OF PAYMENT OF INSURA
Facility.- DCA of d ek
Patient Name: 1411 J
(Please Prot.-)
iTHORIZATION
le,, BENlWITS
atlont XD#. 0005q___
1. ASSIGNMENT
The undoislgr;ed hereby s,<tlgns, tra„sfera ?rid sets over to IX
whiol) thr, pationt le (or rntiy he) entitled from Any Insurance an
county or Iecal gove"i.mental agenty, Including tiro Medicare
who may be flnonalelly tlablo for the Patient's dialysis trcdtm
by andlor At DOA of Edvcfr4ld, ineludiq health insurmecs I
rttadlcal payinont covcrage or other P;?llcy coverogo for wbtoh
dialysis traatrnorst and sen lees and any other medical care rcr
Vgefield.
of tdgtfiald monies and/or benefits to
r hoalth care provider or nmfonol, stoic,
tttrante program, as vtclt as any others
s and services and related medical care
,fits, maior mWiral benefits and other
Patient Is enthlod, to cowry the costs of
red io rite Patient by and/or at WA of
2. 0THORIZATION Or VAY'NWNT OF
Tiae undarFlgned itt;-ratty autltorizxs astd dtrccts that paytncnt of atinsurancc bcnc?'its, including A9cttirsrc
benefits, if npp130blo„ Wolin?, to any charges and costs Incurre I as ix result of dislysiq treaimcnts turd
rotated services and medical care provided to the Patlenl by an or at DCA of NgF('teld, be, paid and
remitted directly to DCA, of Edgofield in auor<lance with Instrv tions provided or to bo proviW by an
agent or rRpi<:wntativc of DVA of Ugetlold,
If the tunietsiped's insurantr. polioy or program dons not prov€d. Cot mment of the monies or benefits
in the name. of DCA of Ugofield, rho tsradwignod hereby fiutlt atttitOrizt=s and ittsimotc the insurantri
provider or agency responsible for ianyrneni of the applicable Ins ranee benefits to issue tiro payrnwit In
the Patient's natm and to deliver aaid payment to DCA of Rd? wfleld. at its address as set forth In rho
irstrudkns provided arto be provided by In agent or repmscntati •o of DCA ofPdgefteld.
:?. Al;,I:AVERYO IlI rr1 I{z'i°a'A?'M1<;iv`I'S
The uudcrsigned bereby Ackno?rlodgts that the wonie-4 or
susuronce providor or govorkiment agmiq for the ehorgos,I
irdgcil0d to its provision of dialysis treabnonis and related se,
Is and shall at :all times rexonlr, the property of JXA of Eft
undersigned hereby covenants stud agrees that In the event the
lucludlug Medicuro Ibenotlts, wbich Mate directly to the tbarg
Rdgefleld as n result of its prati•iston of dlsls'sIs treatments aw
the Patient is sent to the Patient or such Patton(', guardian,
he case sans br, inndverte:aity or ofhonyis,e, drat thi
unconditionally forward such payment directly to DCA of Ne
itRO'>[ PROVIDER
mo its to be paid by the Patient's
:oats and fees incurred by DCA of
vices and medical care to the Patient
held, and in furtherance thereof the
t any payment oflnsurawo benefits,
.i, cost., anti fees tnturrcd by DCA of
r0ated services and medical cire to
morney-la-fact or represontnilve, na
tutdersfgsi0 will promptly and
:fieltt,
pagc 1 Of 2
EXHIBIT
tI/09/900 tai:i7 003003229 EDGE1:IEt.U DC,'t\ r'nC?t ti/17
000 5 ?l
4. RELEASE OV INk OIti1'UTION
The undorsignrd hereby authorizes And contents to the WOO t
or representetivcsr of all or part of any 109ti tatlon, records
nature, to or with any person, corporatlon or goverrimmi nbe
and/or lteaiQt care provider, who is tinamlally liable for the
scrvict?s do Kett as medical care, which lnformatlon is necessary
conflrmstion of pa)uont of charges and costs to DCA of Edw--k
dialysis tmatmontc and tainted scrOccx fs well as medical ow.
S. RESPONSMILITY FOR PAYMENTS
DCA of Edgefield, or any of Ite agents
reports, either medical or financial In
:y, including ally third-party Insurance
at'ient's dla(ysls treatments and related
sr the substrintiation, venflMlon andtor
f for the provision to tha Patient of such
`rho urdetsignM hen'Dy Acknowledges that, notwithstanding the foreyo(ng ess18nn3ent and authorization
of benefit payments Io ACA of Edgefield, the Patient shall be etponsibls for any and all chartes mid
costs billet by DCA of Edg4cid for dialysis truatmcnis and rein eti services provided and not otherwise
coveted or pall by s,)ch third-party payor or governmental a oy, including, without llmitation all
deduttQIA;, co-InAutan,cc and co-payment amounts, and that- T)C of BdgellOd Is su(ltorizad to bill the
PAtlent directly for payment of such cbat$es and costs.
6, RMfrx' MILI Y
Tho undersigned hereby uh-nowlodges (bat thls PA`WNT ASt 10N}riBNT AND AUTHORIZA7'10)q
OP PAYMENT OF INSURANCE BENEFITS may not b r3voked unicss such revocation is
accompanied by the written consent to such rovocation try DCA o ftofleld.
7 PHOT'OCO:F WS
Tlyd undcrciped he'r'eby agroos drat a Photocopy of tills PATIUNI' ASSIONlt4ENT AND
AUTHORCyATION OF PAYMMT 0? INrSUMME, l ESM-P TS shall be cortslderrd as valid its on
original for purposos horeof and may be used to place of tho o ldinal with respect to each of ttctns I
througn 5 above.
Signature: • f? C.f. ?'?'ttnt
hint Natrte:
If you art signing as a guardian, attorney-in-fact of rcprrsentstiv4 f e patient, picric indicate by marklnp
t1w box and Complete this infortnalfon WOW: 0
CERMCATXON OF CII}A1tt?7ARIATTOItiVEX?\-kA?t°I`/k?EP SEi?'t#TIVE
The undersigned hcreay cw1ftes Owt hJs e i c duly a;.rpo4t ted gu_rdtan, attorney-in•fACt author
rcpresentativo of (ha above- tnclidonod ?tler , a at helshe h ' full auti,ority to execute this for,n on
behalf of such tlapenrl-,ant patient. ?
Signature:
Print Name: Date:
Pago J of 2
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64
EXHIBIT
a
1 .1
Louis J. Capozzi, Jr., Esquire*
Daniel K. Natirboff, Esquire
Donald R. Reavey, Esquire
Craig 1. Adler, Esquire
Bruce G. Baron, Esquire
Andrew R. Eisemann, Esquire
Michael M, Jerominski, Esquire
Dawn L. Richards. Esquire
Timothy Ziegler, Reimb. Analyst
Karen L. Fisher, Paralegal
Jennifer Kain, Paralegal
Keyoung Gill, Paralegal
•(licrnscd in PA. NJ and MD)
Mattie Stevens
37 Monument Drive
Johnston, SC 29832
Re: Account with Dialysis Corporation of America
Patient Name: Mattie Stevens
Account Balance: $57,918.64, plus costs of collection
Our Matter No.: 1087-08
Dear Ms. Stevens:
2933 North Front Street
Harrisburg, PA 17110
Telephone: (717) 233-4101
Fax: (717) 233-4103
www.capozziassociates.com
Please be advised that our law firm represents Dialysis Corporation of America regarding
your delinquent account. Although you have 30 days to make payment or settlement arrangements,
we will prosecute a lawsuit, if necessary, against you to obtain asset information, force a settlement,
or obtain a money judgment.
You received numerous treatments from our client's facility in Edgefield from November 9,
'1007 through February 19, 2009, and your health insurance carrier, Blue Cross/Blue Shield,
provided checks to you for the specific purpose of reimbursing the Dialysis Corporation of
America. You have failed, however, to transfer the payments as required by the Provider
Agreement.
When suit is filed it may give rise to the following consequences:
1. To defend this suit, it may be necessary for you to appear in court.
2. If a judgment is obtained against you, you may be required to pay court costs,
attorney's fees, and interest in addition to the money you now owe.
3. If a judgment is obtained against you, a writ of execution may be issued ordering
the seizure and sale of your personal or real property.
4. A judgment is a matter of public record, and it will negatively affect your credit
rating.
NOTICE: UNLESS YOU DISPUTE THE VALIDITY OF THIS DEBT, OR ANY
PORTION THEREOF, WITHIN 30 DAYS AFTER RECEIVING THIS NOTICE, THE
EXHIBIT
April 1, 2010
DEBT WILL BE CONSIDERED TO BE VALID. IF YOU NOTIFY OUR OFFICE IN
WRITING WITHIN 30 DAYS AFTER RECEIVING THIS NOTICE THAT THIS DEBT,
OR ANY PORTION THEREOF, IS DISPUTED, WE WILL OBTAIN VERIFICATION OF
THE DEBT AND WE WILL MAIL A COPY TO YOU. THE NAME OF THE ORIGINAL
CREDITOR OF THIS DEBT IS IDENTIFIED ABOVE.
THIS LETTER AND ALL OTHER COMMUNICATIONS FROM US ARE
ATTEMPTS TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED
FOR THAT PURPOSE.
Please make arrangements to pay this debt in one or more installment payments, or you may
call me if you have any other questions. You have the right to consult with an attorney for advice
regarding this serious matter. I trust that you will give this Notice your immediate attention.
Very truly yours,
^14W *. ),---
MM. Jerominski
MMJ/kjg
I= Lisa A. Laudeman, DCA
Louis J. Capozzi, Jr., Esquire*
Daniel K.. Natirboff, Esquire
Donald R. Reavey, Esquire
Craig I Ajler. Esquire**
Bruce G, Baron, Esquire
Andrew R. Eisemann, Esquire
Michael M. Jcrominski, Esquire
Dawn L. Richards. Esquire
Timothy Ziegler, Reimb. Analyst
Karen L. Fisher, Paralegal
Keyoung J. Gill, Paralegal
Janice 1. Fisher, Paralegal
* (Licensed in PA, NJ and MD)
** (Licensed in PA and NJ)
Mattie Stevens
37 Monument Drive
Johnston, SC 29832
Re: Account with Dialysis Corporation of America
Patient Name: Mattie Stevens
Account Balance: $57,918.64, plus costs of collection
Our Matter No.: 230-10
Dear Ms. Stevens:
2933 North Front Street
Harrisburg, PA 17110
Telephone: (717) 233-4101
Facsimile: (717) 233-4103
www, capozziassociates, com
Mid-Penn Abstract Company
Charter Settlement Company
Telephone: (717) 234-3289
Facsimile: (717) 234-1670
As you will recall, our law firm represents the Dialysis Corporation of America regarding
the above-referenced delinquent account. From November 9, 2007 through February 19, 2009,
you received treatment from Dialysis Corporation of America in Edgefield. As part of this
treatment, you agreed to and signed a Payment Agreement with our client, which I have enclosed
for your convenience. As a result of the treatment on the dates above, you received checks from
Blue Cross/Blue Shield of South Carolina totaling $57,918.64. To date, not one of these checks
has been endorsed and sent to Dialysis Corporation of America to satisfy your outstanding account
balance. It is our position that this represents a breach of contract and possibly insurance fraud.
This is a very serious balance that has accrued and a very serious matter. This will be our
firm's final correspondence to you before recommending legal action to Dialysis Corporation of
America. Contact me at once so that we may discuss settlement arrangements. Thank you for
your prompt attention to this ]matter.
Very truly yours,
Michael M. Jerominski
/kj g
Enclosure
ce: Lisa A. Laudeman, DCA
THIS LETTER AND ANY FUTURE LETTERS FROM OUR FIRM ARE AN ATTEMPT TO COLLECT A
DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
June 9, 2010
11169/2807 14;65 8036373229
D
.?
DALYSIS CURPQRArim or AAaSi cA
EDCEFTFID DCA
Novamber 8,
Manic Stcvcas
Rv Payment AUMPA
Par Me, Stevens,
...... I
Iliie l ettor is to confirm our "Mont rogaming Par
by our Mgeffeld foollity.
Our 1d41goffeld facility is loaded hear your bume and t
for your sohodute. We ere viludful of th t eorrdatfoia I
schedule, Wity comoalenee and anwities said coiq
dialysis mglmen. At Dialysis Corporation of America
aocomimvdate our patients' needs and teailhate their el
We understand that you ere inewwl under a plan issue
Our Rdgefield unit cvrrontly.does not participate in IN
ponallmd for choosing our Acuity. Tbaref % We wit
rupmslble for the same arnotmts as you would be if r
Mth Your plan.
Picric oumtact me if you have any questions ropardlas
W c look Pbnvard to providing services io you.
Sincerely,
Susan Kenny
Coordination of Beftnts Spociallst
M 5IW" Awwa %a" $00 • Grop
40/b0 'd FFIM R)ID. InN XVA
for services furnished to you
S an opening that is aonvenlent
ttwevn f r-fto such as tsealOwt
Ilanoe writ a three. t1ma weekly
we make every effort to
oice Udialysis unit.
by SCIUS of Saudi Carolina.
plan. We do not want you to be
agreo dW you will only be
e were a patilclpstiag ytvvider
lather.
PAGE 61/82
aoai-y
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11/09/2887 14:35 8836373229
^lata) '
ED(EFIE1A DCA
?leuec, per
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PAGE 82/82
000
tj?e viem
(PfrticlltNante)
Magma AoccuAl N)
RS: (Name oflnmgrance C mpelly) Paym=u
DW(PIMC tNat>aa) /ya* tf?tver?
I have been aWOW by (Name of Iaslm es Compwny) t dt payom t for y= &*sis WViM
may be "M dirootl3? to you. MA bft ittatp>d m oompisiae cvay 30 days. In appoxtsnately
4$.60 da^ you may nmlve a Cheek with an eocplhnW of ba oft (BOB) !lent ym im mace
ooimpamy. Upoa receipt dixo lr np=w the* view hthk the ohark and the BOB to your
Wlfly, DCA of (Nance of i4oci'iify); aft payment oafs 66 poseed to You smootimlt is *timely
it aura. The eectetuy at d» frallity will gin you a no* and all* make it copy Of the Chock
and *a BOB for year reoosde. Choc6 will ooio?d == to 6 anal to your vz mstt address Picase
remit all cheCka wad BQB's to your tbaiiify npm Mood
PIWO sign on the lice below acicaowlsdSW$ that you 1?ve read IMs lefties end win Mlit, upon
rece4K, all nhsokx ad BOB's far dialysis services to DdA1 of (Name of facility).
9 Lo? AaL-L? jkhk? ,
P?rti, 'er si?cuae ,
Thank you for c miles DCA for your diolyals needs.
Sirac+inly, •
Save IGaanr
Owdiaation of Benefits Specialist
aft/till 'a f77nfU'11 i f *nN m ,iTtM M."Id W 99111 hill. 1.003-90-AON
ivy, _ s
Ih hiV,1
U.S. RENAL CARE, INC. f/k/a
DIALYSIS CORPORATION OF AMERICA
d/b/a DCA OF EDGEFIELD,
Plaintiff
V.
MATTIE STEVENS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Docket No.: 2012 - 2953
: Civil Action - Law
PRAECIPE TO ATTACH VERIFICATION
To The Prothonotary:
Kindly affix the attached Verification to the Complaint filed on May 14, 2012 in
the above-captioned matter. It was inadvertently omitted at the time11001lini
A
Date:
And ann, Esquire
Attorney ' .: 87441
Capozzi ociates, P.C.
1200 Camp Hill Bypass, Suite 205
Camp Hill, PA 17011
(717) 233-4101
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
U.S. RENAL CARE, INC. f/k/a CIVIL COURT DIVISION
DIALYSIS CORPORATION OF AMERICA
d/b/a DCA OF EDGEFIELD,
Plaintiff
V.
MATTIE STEVENS,
Defendant
Docket No.:
Civil Action -Law
VERIFICATION
I, Charla Williams, Vice President of Reimbursement of U.S. Renal Care, Inc., owner
and operator of DCA of Edgefield, do hereby verify under penalties of perjury and upon personal
knowledge that the contents of the foregoing Complaint are true and correct.
Date: 5 12 t Z
Ctt e'? '6-
Charla Williams
Vice President of Reimbursement
U.S. Renal Care, Inc.
8
U.S. RENAL CARE, INC. f/k/a IN THE COURT OF COMMON PLEAS OF
DIALYSIS CORPORATION OF AMERICA CUMBERLAND COUNTY, PENNSYLVANIA
d/b/a DCA OF EDGEFIELD,
Plaintiff
Docket No.: 2012 - 2953
MATTIE STEVENS, Civil Action - Law
Defendant
PRAECIPE TO REINSTATE
TO THE PROTHONOTARY: . Nk
Pursuant to Pa. R.C.P. 401, please reinstate the above-captioned Complaint, attached.
Date: l? ?)
Andrew R. se , Esquire
7?iCbrney I. o.: 7441
Capozzi & A ates, P.C.
1200 Camp Hill Bypass, Suite 205
Camp Hill, PA 17011
(717) 233-4101
Attorney for Plaintiff
I')
???- av?35
d
U.S. RENAL CARE, INC. f/k/a
DIALYSIS CORPORATION OF AMERICA
d/b/a DCA OF EDGEFIELD,
Plaintiff
V.
MATTIE STEVENS,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVAP
Docket No.: 2012 - 2953
Civil Action - Law
Defendant Cl
c?
-GPM N
PRAECIPE TO ENTER RETURN OF SERVICE Z
-! CO
.[CD
TO THE PROTHONOTARY/CLERK OF SAID COURT: xd
A
=?
Kindly enter as a matter of record the attached Affidavit of Service forms o
of personal service of the above-referenced Complaint upon the Defendant Mattie Stevens, 102
Aiken Avenue, Johnston, SC 29832. A competent adult served the Complaint in accordance
with Pa.R.C.P. No. 402(a) on July 3, 2012.
Dated: `7 6
l
9rrew use Esquire
Attorney I.D. o, 87441
Capozzi & ate s, P.C.
P. O. Box 5866
Harrisburg, PA 17110
(717) 233-4101
Attorney for Plaintiff
?YT3
C..)
-4 r
J.
U.S. RENAL CARE, INC. F/K/A DIALYSIS CORPORATION OF AMERICA D/B/A
DCA OF EDGEFIELD
vs.
MATTIE STEVENS
Person to be served (Name and Address):
MATTIE ALEWINE STEVENS
102 AIKEN AVENUE
JOHNSTON SC 29832
By serving: MATTIE ALEW INE STEVENS
Attorney: PHILIP C. WARHOLIC, ESQ.
Plaintiff
Defendant
Papers Served: NOTICE TO DEFEND, COMPLAINT, EXHIBITS A-D
Service Data: [r] Served Successfully [ ] Not Served
Date/Time: 67 - 0.3 - J01.2 9:5o Ani
k Deiivered a copy to him/her personally
[ ] Left a copy with a competent household member over 14 years of age
residing therein (indicate name & relationship at right)
[ ] Left a copy with a person authorized to accept service, e.g. managing agent,
registered agent, etc. (indicate name & official title at right)
I1 2 0 1 "216111512101311111
I n Tn'J Court
Venue
Docket Numbel: 12 2953
AFFIDAVIT OF SERVIC
(For Use by Private Service)
Cost of Service pursuant to R. 4:4-3(c)
Attempts: Date/1-ime:
Date/Time:
Date/Time:
Name of Person Served and relationship/title:
Description of Person Accepting Service: J?
SEX: AGE: EIGHT: 53 WEIGHT: t SKIN: b lK HAIR: A OTHER:
Unserved:
[ ] Defendant is unknown at the address furnished by the attorney
[ ] All reasonable inquiries suggest defendant moved to an undetermined address
[ ] No such street in municipality
[ ] Defendant is evading service
[ ] No response on: DateMme:
Date/Time:
Date/Time:
Other:
Served Data:
Subscribed and Sworn to me this
3 4 day of u 201
Notary Signat e: "I"
09.0'7 - >o,'7
Name of Notary Commission Expiration
was at the time of service a competent adult, over
the age of 18 and not having a direct interest in the
litigat' n. I declare under penalty of perjury hat the
f is is true an rrect.
?/20 1?-
Sign ure of Pr ess Server Dat
JB