HomeMy WebLinkAbout12-2975U.S. RENAL CARE, INC. f/k/a
DIALYSIS CORPORATION OF AMERICA
d/b/a DCA OF HYATTSVILLE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V. Docket No.:`
CINDERELLA CAMPBELL, Civil Action - Law mM M r r-
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
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 Plaintiff. You may lose
money or property or other rights important to you.
YOU SHOULD TAKE THIS PA]g% T(T:YO"
LAWYER AT ONCE. IF YOU DO O"U'VE
A LAWYER OR CANNOT AFFOR6 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
AVISO
Le ban demandado a usted en la corte. Si usted
quiere defenderse de estas de estas demandas
expuestas an las paginas signientes, usted tiene
veinte (20) dias de plazo al partir de is fecha de la
demanda y is notificacion. Hace falta asentar una
comparencia escrita o en persona o con un abogado
y entregar a la corte en forma escrita sus defensas o
sus objeciones a las demandas en contra de su
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corte tomara medidas y puede continuar la demanda
en contra suya sin previo aviso o notificacion.
Ademas, la corte puede decidir a favor del
demandante y requiere que usted cumpla con todas
las provisiones de esta demanda. Usted puede
perder dinero o sus propiedades u ostros derechos
importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO
INMEDIATAMENTE, SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO
SUFICIENTE DE PAGAR TAL SERVICIO.
VAYA EN PERSONA O LLAME POR
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
717-249-3166
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U.S. RENAL CARE, INC. f/k/a
DIALYSIS CORPORATION OF AMERICA
d/b/a DCA OF HYATTSVILLE,
Plaintiff
V.
CINDERELLA CAMPBELL,
Defendant
IN THE COURT OF COMMON PLEAS FOR
CUMBERLAND COUNTY, PENNSYLVANIA
: Docket No.:
: Civil Action - Law
COMPLAINT
NOW COMES, U.S. Renal Care, Inc., f/k/a Dialysis Corporation of America d/b/a DCA
of Hyattsville ("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 a principal place of business address at 214 Senate Avenue, Camp Hill, Cumberland
County, Pennsylvania 17011.
2. Defendant Cinderella Campbell ("Patient" or "Defendant") is an adult individual with
a last known address at 1011 Harlem Ave., Baltimore, MD 21217-2429.
3. The clinic formerly known as DCA of Hyattsville is an operating subsidiary of
U.S. Renal Care with a dialysis clinic located at 4920 Lasalle Road, Hyattsville, Maryland
20782.
4. U.S. Renal Care provides dialysis treatments and services to its patients.
5. On or about January 2, 2009, 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 January 2, 2009, 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 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, not withstanding 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
January 2, 2009 through December 31, 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. Prince George County Department of Social Services denied Medicaid to Defendant
because she was unable to verify her citizenship or provide proof of identification.
10. On February 3, 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 letter is attached hereto and incorporated herein as Exhibit "D."
COUNT I - BREACH OF CONTRACT
11. Paragraphs 1 through 10 are incorporated herein by reference.
12. 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 treatments.
13. 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 qualify for Medicaid and pay the account balance is
$300,057.97.
14. To date, Defendant has failed and refused to pay the total amount due as required
pursuant to the Account Statement and the Assignment and Authorization Agreement.
15. Defendant's failure to cure her default with U.S. Renal Care pursuant to the
Assignment and Authorization Agreement constitute a breach of contract.
16. U.S. Renal Care has been financially damaged in the amount of $300,057.97, plus
interest and costs of collection.
WHEREFORE, Plaintiff, U.S. Renal Care, Inc., f/k/a Dialysis Corporation of America
d/b/a DCA of Hyattsville, demands judgment against Defendant in the sum of $300,057.97, plus
post judgment interest and attorney's fees and costs, which sum exceeds the local limit for
arbitration.
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.
17. Plaintiff incorporates paragraphs 1 through 16 of this Complaint as if set forth at
length herein.
4
18. 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.
19. The Defendant has been unjustly enriched by accepting the Dialysis treatments.
20. The rates reflected in the Account Statement as Exhibit C are the just and reasonable
rates for dialysis treatments and services.
21. The total value by which Defendant has become enriched on account of the Dialysis
is $300,057.97, as is more specifically reflected in the Account Statement.
22. U.S. Renal Care has demanded Defendant pay this amount, but Defendant has failed
to do so.
23. To date, the Defendant has not paid the total amount due.
WHEREFORE, Plaintiff, U.S. Renal Care, Inc., f/k/a Dialysis Corporation of America
d/b/a DCA of Hyattsville, demands judgment against Defendant in the sum of $300,057.97, plus
post judgment interest and attorney's fees and costs, which sum exceeds the local limit for
arbitration.
Respectfully submitted,
Dated: By:
Philip C. W*#olic, Esquire
Attorney I.D: 6341
Camp Hill Bypass, Suite 205
Camp Hill, PA 17011
(717) 233-4101
Attorneys for Plaintiff
5
CAPOZZI & ASSOCIATES, P.C.
U.S. RENAL CARE, INC. f/k/a IN THE COURT OF COMMON PLEAS FOR
DIALYSIS CORPORATION OF AMERICA CUMBERLAND COUNTY, PENNSYLVANIA
d/b/a DCA OF HYATTSVILLE,
Plaintiff
v.
CINDERELLA CAMPBELL.,
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 Hyattsville, do hereby verify under penalties of perjury and upon
personal knowledge that the contents of the foregoing Complaint are true and correct.
Date:
Charla Williams
Vice President of Reimbursement
U.S. Renal Care, Inc.
DIALYSIS CORPORATION OF AMERICA
DCA OF HYATTS'VILLE
CONSENT !FOR REMODLALYSIS
Patient: n AUeA Xl) (umber: Date:
( ) I, the undersiped patient;
( ) 1, the undersigned parent or guardian of the above patient who is under
18 years of a e or otherwise incapable of consenting;
hereby request and authorize Dr. A H 61 and whomever he or she may
-rr
designate as his or her associate or assistant to administer to me (or to the above named
patient) the procedure known as hemodi4lysis, under such conditions as shall be determined
by the physician (s) in attendance. I agree to abide by the policies, rules, and regulations
established by the above named Dialysi? Unit in carrying out its hemodialysis program.
It has been explained to me that hemodioysis is a procedure. used in the case of patients with
impairment of failure of kidney function; by which certain components of the blood are
separated by a semi-permeable substanc? which permits the passage of certain molecules and
hinders that of others when the blood is pirculated through an artificial kidney, called a
dialyzer. I understand that there are different types of equipment employed for the dialysis
treatment and different types of artificial kidneys (dialyzers) used in the process.
I acknowledge that the possible risks anal complications of hemodialysis such as but not
limited to leakage of the dialyzer, changes in blood pressure and malfunction of equipment
have been explained to me by the profes' ional personnel of the Dialysis Unit and I accept, on
behalf of myself and/or the above patient the dialysis treatment with all potential risks and
complications. I also understand that and disorder, which afflicts me, can have effects on my
treatment and on myself during the tthat I am receiving a dialysis treatment but that this
fact does not mean that the dialysis tr eatment had anything to do with the development of the
problem related to this condition. I further consent to the administration of such drugs,
transfusions of blood or blood components, or any other treatment and testing, including HIV
testing, deemed necessary or desirable irk the judgment of the physician (s) in attendance.
I am aware that the practice of medicine is not an exact science, and I acknowledge that no
guarantee, warranty of representation whatsoever has been offered or made to me or anyone
on my behalf concerning the results of the hemodialysis procedure.
LL
Signature: t 'ate or
P tient- Legal Guardian or Parent
Print Name: Date: I o
I
Witness: Date. --a- o
i
DCA Form # 1049
Revised 10/00
Exhibit A
DIALYSIS
I CORPORATION
of A M E R I C A
PATIENT ASSIGNMENT AND AUTHORIZATION
OF PAY1V.[ NT OF INSURANCE BENEFITS
Facility: DCA of HyatlSVille ]Date: 1 U
Patient Name: i nrLlle Oo rY1 1.??/ Patient ID#•
(Ple= Print)
1. ASSIGNMN'T
'Me undersigned hereby assigns, transfers and sets over to DCA of Hyattsville monies and benefits to
which the Patient is (or may be) entitled from any insurance and/or health care provider or national, state,
county or local governmental agency, including the Medicare insurance program, as well as any others
who may be financially liable for the Patient's dialysis treatments and services and related medical care
by and/or at DCA of Hyattsville, including health insurance benefits, major medical benefits and other
medical payment coverage or other policy coverage for which the Patient is entitled, to cover the costs of
dialysis"treatment and services and any other medical care rendered, to the Patient by and/or at DCA of
Hyattsville.
2. AUTHORIZATION OF PAYMENT OF INSURANCE BENEFITS
The undersigned hereby authorizes and directs that payment of all insurance benefits, including Medicare
benefits, if applicable, relating to any charges and costs incurred as a result of dialysis treatments and
related services and medical care provided to the Paiient by and/or at DCA of Hyattsville, be paid and
remitted directly to DCA of Hyattsville in accordance with instructions provided or to be provided by an
agent or representative of DCA of Hyattsville.
If the undersigned's insurance policy or prpgram does not provide for payment of the monies or benefits
in the name of DCA of Hyattsville, the undersigned hereby further authorizes and instructs the insurance
provider or agency responsible for payment of the applicable insurance benefits to issue the payment in
the Patient's name and to deliver said payment to DCA of Hyattsville at its address as set forth in the
instructions provided or to be provided by an agent or representative of DCA of Hyattsville.
3. DELIVERY OF BENEFIT PAYMENTS RECEIVED FROM PROVIDER
The undersigned hereby acknowledges that the ironies or benefits to be paid by the Patient's
insurance provider or government agency for the charges, costs and tees incurred by DCA of
Hyattsville in its provision of dialysis treatments and related services and medical care to the
Patient is and shall at all times remain, the property of DCA of Hyattsville, and in 11urtherance
thereof the undersigned hereby covenants and agrees that in the event that any payment of
insurance benefits, including Medicare benefits, which relate directly to the charges, costs and fees
incurred by DCA of Hyattsville as a result of its provision of dialysis treatments and related
services and medical care to the patient is sent to the Patient or such Patient's guardian, attorney-
in-fact or representative, as the case may be, inadvertently or otherwise, that the undersigned will
promptly and unconditionally forward such payment directly to DCA of Hyattsville.
rev 8/08
Policy No. OP 07-32
Outpatient Manual
Page 1 of 2
Exhibit B
DIALYSIS
CORPORATION
of A M E R I C. A
4. RELEASE OF INFORMATION
The undersigned hereby authorizes and consents to the release by DCA of Hyattsville, or any of its agents
or representatives, of all or part of any information, records or reports, either medical or financial in
nature, to or with any person, corporation or government agency, including any third-party insurance
and/or health care provider, who is financially liable for the Patient's dialysis treatments and related
services as well as medical care, which information is necessary for the substantiation, verification and/or
confirmation of payment of charges and costs to DCA of Hyattsville for the provision to the Patient of
such dialysis treatments and related services as well as medical care.
5., RESPONSIBILITY FOR PAYMMNTS
The undersigned hereby acknowledges that, notwithstanding the foregoing assignment and authorization
of benefit payments to DCA of Hyattsville, the Patient shall be responsible for any and all charges and
costs billed by DCA of Hyattsville for dialysis treatments and related services provided and not otherwise
covered or paid by such third-party payor or governmental agency, including, without limitation all
deductible, co-insurance and co-payment amounts, and that DCA of Hyattsville is authorized to bill the
Patient directly for payment of such charges and costs.
6. REVOCABILITY
'the undersigned hereby acknowledges that this PATIENT ASSIGNMENT AND AUTHORIZATION
OF PAYMENT OF INSURANCE BENEFITS may not be revoked unless such revocation is
accompanied by the written consent to such revocation by DCA of Hyattsville.
7. PROTOCOPMS
The undersigned hereby agrees that a photocopy of this PATIENT ASSIGNMENT AND
AUTHORIZATION OF PA1'IYMNT OF INSURANCE BENEFITS shall be considered as valid as an
original for purposes hereof and may be used in place of the original with respect to each of items 1
through 5 above. }
A
Signature: ?., Witness:
-- r
Print Name: Date:
If you are signixlg as a guardian, attorney-in-fact or representative of a pati'ent,' Tease indicate by marking
the box and complete the information below: p
CERTIFICATION OF GUARDIAN/A.TTORNEY-IN-FACT/REPRESENATM
The undersigned hereby certifies that he/she is the duly appointed guardian, attorney-in-fact and/or
representative of the above-mentioned patient, and that he/she has full authority to execute this form on
behalf of such dependent patient.
Signature: Witness:
Print Name: Date:
rev 8/08
Policy No. OP 07-32
Outpatient Manual
Page 2 oft Exhibit B
Sf. T'E calms l1'Iorc, Di%lysis (-inter, f.,1.,(
AuthnriZSC(icir? for and verification of consent co Hemodialysis ProcedurQ
I hereby, acknuwltzip drat 1 have read and understand the foregaing, that I have
asked wl'catever questions I leave regal-ding tilt pruhosed treatments and drat If I leave
any furthec questions during the c iursG o! the trtatrnent I will ask them. I htereby
r:011sr,cct (u the adMinistratiOres of hi rilodialysc. (reatrnents by the staff of ,S'(. •I'liocnas
Marc i,ialys): Ccrcttr as prc°scnbc;d by L?r. and
further Consent to any care or treatn-cent considered necessary due (o complications,
vrhic:h may tlew"e"•li p
--
Uate ?,7 ?? V. ,..? T1 Me
Patient Nacre:
(Please M
Signature: ? - _??
(Patien PMYent/COnserv3tor/Guardian)
If signed by uth?r than patien(, indicate relationship;
tnt,ss Narre;
(Please Print)
Exhibit B
DIALYSIS
CORPORATION
Of A M E R I C A
Cinderella Campbell #9SITY/276
DOS
IM
I Char Total Account
_
%h M
1/2-31/09 $ 40,974.90 $ 40,974.90
2/3-26/09 $ 13,657.75 $ 23,657.75
3/5-31/09 $ _13,516.46 $ 23,516.46
4/2-30/09 $ 15,806.48 $ 15,806.48
5/2-30/09 $ 16,326.39 $ 16,326.39
6/1-30/09 $ 16,406.97 $ 16,406.97
7/1-31/09 $ 41,148.83 $ _ 41,148.83
8/1-31/09 $ 28,696.74 $ 28,696.74
9/1-30/09 $ 15,713.20 $ 15,713.20
y
10/1-31 09 $ 25,570.06 $ 250570.06
J
11/1-30/09 j _
11,394.61 $ 25,394.61
12/1-31/09 _'
$ 26,842.58 $ 26,841.58
TOTALS: $ 300,054.97 300,054.97
214 Senate Avenue, Suite 300, Camp Hill, PA 17011 - Phone (717) 730-6164 - Fox (717) 730-9133
www.dialysiscorporation.com Exhibit C
Louis J. Capozzi, Jr., Esquire*
Daniel K. Natirboff, Esquire
Donald R. Reavev. Esquire
Bruce G. Baron, Esquire
Andrew R. Eisemann, Esquire
Michael M. Jerominski, Esquire
Dawn L. Richards, Esquire
Timothy Ziegler, Re'imb. Analyst
Karen L. Fisher, Paralegal
Jennifer Kain, Paralegal
Keyoung Gill, Paralegal
,'kissed in Pn. 147 and MDC
February 3, 2010
Cinderella Campbell
502 Chillum Road, Apt. 100
Hyattsville, MD 20783
RE: DCA of Chevy Chase and DCA of Hyattsville
Account Balance: $300,057.97
Our Matter No.: 143-10
Dear Ms. Campbell:
2933 North Front Street
Harrisburg, PA 17110
Telephone: (717) 233-4101
Fax: (717) 233-4103
vvww. capozzi associates. coin
Craig I. Adler, Esq.
Of Counsel
Please be advised that our law finn represents Dialysis Corporation of America regarding
your delinquent account. Your Payment Agreement with our client is currently in default. If you fail
to cure the default or contact me to make payment 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 facilities from January 2009 through
December 2009 at our client's Hyattsville clinic. You have failed, however, to submit the necessary
documents to the Prince George County Department of Social Services as required for the Medical
Assistance approval process or to remit any payment to our client as required under the Service
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. Exhibit D
4. A judgment is a matter of public record, and it will negatively affect your credit
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.
ARE/kjg
cc: Lisa A. Laudeman, DCA
Exhibit 0
DCA OF HYATTSVILLE, LLC
d/b/a DCA OF HYATTSVILLE,
Plaintiff
V.
CINDERELLA CAMPBELL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Docket No.: 12-2975
CIVIL ACTION - LAW
PRAECIPE TO REINSTATE
TO THE PROTHONOTARY:
Pursuant to Pa. R.C.P. 401, please reinstate the above-captioned
Date: G
se
Attorney I.D.
Capozzi & A es
P.O. Box 5866
Harrisburg, PA 17110
(717) 233-4101
Attorney for Plaintiff
Esquire
441
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DCA OF HYATTSVILLE, LLC
d/b/a DCA OF HYATTSVILLE,
Plaintiff
V.
CINDERELLA CAMPBELL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVAT
Docket No.: 12-2975
CIVIL ACTION - LAW
PRAECIPE TO ENTER RETURN OF SERVICE
TO THE PROTHONOTARY/CLERK OF SAID COURT:
Kindly enter as a matter of record the attached Affidavit of Service form as proof of
personal service of the above-referenced Complaint upon the Defendant.
A competent adult served the Complaint upon Defendant in accordance with Pa.R.C.P.
No. 402(a) on July 8, 2012.
Dated: -
fey I.D. No.: 41
Capozzi & Associ rte)s P.C.
P. O. Box 5866
Harrisburg, PA 17110
(717) 233-4101
Attorney for Plaintiff
r^-a
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. * 1
U.S. RENAL CARE, INC FKA DIALYSIS CORPORATION OF AMERICA DBA
DCA OF HYATTSVILLE
Plaintiff
Vs.
CINDERELLA CAMPBELL
Person to be served (Name and Address):
CINDRELLA CAMPBELL
2653 DULANY ST
BALTIMORE MD 24M 2-12-2-3
By sewing: CINDRELLA CAMPBELL
Attorney: PHILIP C WARHOLIC. ESO
Papers Served: NOTICE TO DEFEND, COMPLAINT, VERIFICATION
CONSENT FOR HEMODIALYSIS, EXHIBITS
Service Dab: [x] Served Successfully ( J Not Served
Date/Time: 07/08/2012 at 5:11 PM
Defendant
[ 1 Delivered a copy to himlher personally
J9 Left a copy with a competent household member over 14 years of age
residing therein (indicate name & relationship at right)
[ 1 Leff a copy with a person authorized to accept service, e.g. managing agent,
registered agent, etc. (indicate name & official title at right)
i nn-rre . Court Of ? b
l 1 ?rYtrLILtY? tn enue
Docket Number. 12 29 5 CV
AFFIDAVIT OF SERVICE
(For Use by Private Service)
Cost of Service pursuant to R. 4:4.3(c)
Attempts: DateMme:
DaIWITime:
DateMme:
Name of Person Served and relationship/Gde:
Seymour Campbell, Father
Desaiption of Person Accepting Service:
SEX: M AGE: 6 5 HEIGHT: 5 ' 10 WEIGHT: 17 0 -18 0 SKIN: B HAIR: Gray OTHER:
Unserved:
( ] Defendant is unknown at the address fumbled by the attorney
[ ] AN reasonable des suggest defendant moved to an undetermined address
(J No such street in municipality
[ ] Defendant is evading service
[ ] No response on: Date/Time:
Date ffime:
Date/Time:
Other:
Served Data:
Subscribed and Swam to me this I, ANDRE S. POWELL
10th day of Jul , 20 12 was at the time of service a competent adult,
the age of lea having a direct interest
C litigation. I d are er penally of perjury th
Notary Signature: fore is ea
n rrect.
Betty A. Brown 12/19/2015 07/10/2
Name of Notary Commission Expiration ??•??( A. Q/Q nature of Process Server Date
NOTAR 2
PUBLIC
JB 0,
the
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