HomeMy WebLinkAbout13-3752 CAPOZZI ADLER, P.C. f /k/a IN THE COURT OF COMMON PLEAS OF
CAPOZZI & ASSOCIATES, P.C., CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff S v i
V. Docket No.: 13 .. 3�f o� �
RC OPERATOR, LLC,
Defendant Confession of Judgment for Money
CONFESSION OF JUDGMENT WHERE ACTION
COMMENCED BY COMPLAINT
Pursuant to the authority contained in the warrant of attorney, the copy of which is
attached to the Complaint filed in this action, I appear for the Defendant and confess judgment in
favor of the Plaintiff and against Defendant as follows:
Unpaid legal services $21,600.31
Unpaid interest to date $ 5,225.88
Attorney fees pursuant to Letter of Representation $ 650.50
Total Amount Due $27,476.69
*Plus interest from date of judgment until Defendant's obligation is satisfied, costs of collection,
and court costs.
CAPOZZI ADLER, P.C.
Date: By:
Marc . Crum, Esquire _
w Attor ey I.D. No.: 91273
u= Ca ozzi Adler, P.C.
P. . Boa 5866
- `� arris
CD burg, PA 17110
(717) 233 -4101
CO
Attorney for Defendant
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CAPOZZI ADLER, P.C. f /k/a IN THE COURT OF COMMON PLEAS OF
CAPOZZI & ASSOCIATES, P.C., CUMBERLAND COUNTY, PENT�§YI,�ANIA
Plaintiff CrJ c i_
V. Docket No.: ', ,
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RC OPERATOR, LLC, y ;;
Defendant Confession of Judgment for Mone cD r
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COMPLAINT IN CONFESSION OF JUDGMENT FOR MONEY
NOW COMES, Plaintiff, Capozzi Adler, P.C. f /k/a Capozzi & Associates, P.C., by and
through its attorneys, to confess judgment against the Defendant and seeks legal relief necessary
to obtain payment for legal services rendered and presented, but which remain unpaid. In support
of the relief requested herein, Capozzi Adler, P.C. hereby states the following:
1. Plaintiff, Capozzi Adler, P.C. ( "Capozzi "), is a Pennsylvania professional
corporation engaged in the practice of law, with a principal place of business located at 1200
Camp Hill Bypass, Suite 205, Camp Hill, Cumberland County, Pennsylvania 17011.
2. Defendant, RC Operator, LLC ( "RC Operator ") is a Delaware corporation having
a registered office address of One Penn Boulevard, Philadelphia,-Pennsylvania 19144.
3. Capozzi is engaged in business as a law firm composed of attorneys admitted to
the bar of the Supreme Court of the Commonwealth of Pennsylvania.
The Legal Representation Agreement
4. In April 2010, Capozzi and Defendant started a professional relationship for legal
services. A true and correct copy of a Letter of Representation ( "Fee Agreement "), dated April
7, 2010, is attached hereto and incorporated herein as Exhibit "A."
5. The terms of Capozzi's performance of legal services for Defendant were
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disclosed at the outset of the engagement.
6. The terms of the Fee Agreement provide that "this letter will describe the scope of
services to be provided, the basis for determining the fees for those services and our general
terms and conditions for billing."
7. The Fee Agreement also provides "In addition to the representation described
above, you may from time to time ask us to perform additional legal work or undertake your
representation in other matters. This letter constitutes your authorization for our Firm to
perform the additional legal work or represent you in other matters."
8. The Fee Agreement also provides that "our firm sends periodic invoices, usually
monthly, detailing services rendered during the last billing period ..."
9. The Fee Agreement also provides that "invoices are due upon receipt and must be
paid within thirty (30) days unless other acceptable arrangements are made in advance. We
reserve the right to charge interest at 1' /2% per month for any invoices not paid within sixty (60)
days of the date of the invoice."
10. The section of the Fee Agreement entitled "Disputed Billing" provides, "It is
imperative, under the terms of this agreement, that you notify us in writing of any disputed
billing within 15 days of your receipt of a bill. If we do not receive written notice within 15
days, the Parties agree that the amount of the bill can no longer be disputed and that said amount
is due and owing."
11. The Fee Agreement also provides for attorney's fees and costs of collection as
follows: "should it be necessary for us to take legal action to collect any overdue invoices, you
will also be responsible for any and all costs of collection including, without limitation,
reasonable attorneys fees and expenses."
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12. The Fee Agreement authorizes the Confession of Judgment against Defendant for
money due and owing Capozzi upon Defendant's default under the terms of the Fee Agreement.
Such provision states as follows:
CONFESSION OF JUDGMENT. THE UNDERSIGNED HEREBY EMPOWERS
ANY ATTORNEY OF ANY COURT OF RECORD WITHIN THE UNITED STATES
OF AMERICA OR ELSEWHERE TO APPEAR FOR THE UNDERSIGNED AND,
WITH OR WITHOUT COMPLAINT FILED, CONFESS JUDGMENT AGAINST THE
UNDERSIGNED IN FAVOR OF ANY HOLDER HEREOF, UPON THE
OCCURRENCE OF AN EVENT OF DEFAULT, AS HEREINABOVE DEFINED, FOR
THE UNPAID BALANCE OF UNDISPUTED LEGAL FEES, AS DESCRIBED
ABOVE, TOGETHER WITH UNPAID INTEREST THEREON, COSTS OF SUIT AND
ATTORNEY'S FEES, AS DESCRIBED ABOVE, ON WHICH JUDGMENT ONE OR
MORE EXECUTIONS MAY ISSUE FORTHWITH. THE UNDERSIGNED HEREBY
FOREVER WAIVES AND RELEASES ALL ERRORS IN SAID PROCEEDINGS,
WAIVES STAY OF EXECUTION, AND WAIVES ALL EXEMPTIONS FROM LEVY
AND SALE OF ANY PROPERTY THAT NOW ARE OR HEREAFTER MAY BE
APPLICABLE. NO SINGLE EXERCISE OF THE FOREGOING POWER TO
CONFESS JUDGMENT SHALL BE DEEMED TO EXHAUST THE POWER,
WHETHER OR NOT ANY SUCH EXERCISE SHALL BE HELD BY ANY COURT
TO BE VALID, VOIDABLE OR VOID, BUT THE POWER SHALL CONTINUE
UNDIMINISHED AND IT MAY BE EXERCISED FROM TIME TO TIME AS OFTEN
AS THE HOLDER HEREOF SHALL ELECT UNTIL SUCH TIME AS THE HOLDER
SHALL HAVE RECEIVED PAYMENT IN FULL OF THE DEBT, INTEREST,
ATTORNEY'S FEES AND COSTS. INTEREST ON THE OBLIGATION EVIDENCED
HEREBY SHALL CONTINUE TO ACCRUE AT THE ABOVE - STATED RATE
AFTER THE ENTRY OF JUDGMENT HEREON. THE UNDERSIGNED HEREBY
WAIVES ITS RIGHTS TO NOTICE AND A HEARING CONCERNING THE
VALIDITY OF THE HOLDER'S CLAIMS HEREUNDER AND AGREES AND
CONSENTS TO JUDGMENT BEING ENTERED BY CONFESSION IN
ACCORDANCE WITH THE TERMS HEREOF AND EXECUTION BEING LEVIED
ON SUCH JUDGMENT AGAINST ANY AND ALL PROPERTY OF THE
UNDERSIGNED, IN EACH CASE WITHOUT FIRST BEING GIVEN NOTICE AND
THE OPPORTUNITY TO BE HEARD ON THE VALIDITY OF THE CLAIM OR
CLAIMS UPON WHICH SUCH JUDGMENT IS ENTERED.
13. From the period April 7, 2010 through May 2013, Capozzi provided legal services
to Defendant in accordance with the Fee Agreement on or about the dates set forth in Capozzi's
business records (the "Account Invoices" or "Client Ledgers ").
14. On May 29, 2013, Capozzi contacted Defendant to demand payment on the
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outstanding balance.
15. At all times relevant hereto, Defendant agreed to pay Capozzi for all legal services
Capozzi would perform.
16. At all times relevant hereto, Capozzi performed legal services for Defendant
pursuant to Defendant's numerous requests.
17. At all times relevant hereto, the services rendered were done in a professional and
competent manner, with no complaints having been made by Defendant.
18. The rates, charges and other billing procedures performed under the Fee
Agreement were, at all times, in accordance with the Fee Agreement as referenced in "Exhibit
A."
19. Each of the subject legal matters performed on Defendant's behalf was billed on
an hourly basis. None of the legal matters were billed on a contingent fee basis.
20. Defendant never disputed the charges orally or in writing.
21. Defendant acknowledged and implied consent to the legal services provided by
Capozzi by remitting small partial payments to Capozzi.
22. Defendant had a duty under the terms of the Fee Agreement to remit payment
pursuant to each of the monthly invoices.
23. Defendant defaulted on their obligation under the Fee Agreement by failing to
make payment when due.
24. The rates and prices charged as set forth in the Account Invoices and the Fee
Agreement are the fair and reasonable charges for the legal services rendered, are the customary
charges of Capozzi in similar cases, and are the charges that Defendant agreed to pay for the
legal services.
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The Legal Services Performed Under the Legal Representation Agreement
25. Capozzi provided to Defendant monthly Invoices for the legal services provided
and fees and costs associated with the "Reorganization of RC Operator" (Matter # 320 -10) in the
total principal amount of $1,140.00. True and correct copies of the Client Invoices associated
with this matter are attached hereto and incorporated herein as Exhibit "B."
26. Capozzi provided to Defendant monthly Invoices for the legal services provided
and fees and costs associated with the "Second Reorganization of RC Operator" (Matter # 116-
12) in the total principal amount of $3,349.50. A true and correct copy of the Client Invoices
associated with this matter are attached hereto and incorporated herein as Exhibit "C."
27. Capozzi provided to Defendant monthly Invoices for the legal services provided
and fees and costs associated with the "Union Negotiations" (Matter # 440 -10) in the total
principal amount of $6,100.50. True and correct copies of the Client Invoices associated with
this matter are attached hereto and incorporated herein as Exhibit "D."
28. Capozzi provided to Defendant monthly Invoices for the legal services provided
and fees and costs associated with the "Willow Terrace ULP Termination" (Matter # 396 -10) in
the total principal amount of $317.50. True and correct copies of the Client Invoices associated
with this matter are attached hereto and incorporated herein as Exhibit "E."
29. Capozzi provided to Defendant monthly Invoices for the legal services provided
and fees and costs associated with "Miscellaneous Matters" (Matter # 328 -10) in the total
principal amount of $2,898.50. True and correct copies of the Client Invoices associated with
these matters are attached hereto and incorporated herein as Exhibit "F."
30. Capozzi provided to Defendant monthly Invoices for the legal services provided
and fees and costs associated with the "Willow Terrace Employee Handbook Review" (Matter #
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802 -11) in the total principal amount of $5,314.38. True and correct copies of the Client
Invoices associated with this matter are attached hereto and incorporated herein as Exhibit "G."
31. Capozzi provided to Defendant monthly Invoices for the legal services provided
and fees and costs associated with the "Willow Terrace MA Audit Appeal FYE 6/30/09" (Matter
# 695 -11) in the total principal amount of $2,479.93. True and correct copies of the Client
Invoices associated with this matter are attached hereto and incorporated herein as Exhibit "H."
32. The total amount of unpaid Account Invoices for the matters and during the
periods referenced above is $21,600.31.
33. The total amount due and owing to Capozzi from Defendant is $21,600.31, plus
$5,225.88 interest at the contract rate of 1.5 % per month and costs of collection. A true and
correct copy of the interest statement is attached hereto and incorporated herein as Exhibit "I."
Breach of the Fee Agreement
34. Capozzi performed all requested legal services for Defendant under the terms of
the Fee Agreement.
35. All of the legal services included in the Account Invoices were billed at the hourly
rates agreed to as described in the Fee Agreement.
36. Capozzi presented its claims for payments on a monthly basis to Defendant
pursuant to the terms of the Fee Agreement.
37. On numerous occasions Capozzi contacted Defendant for payment of the unpaid
Account Invoices.
38. Defendant did not dispute any of the monthly Account Invoices.
39. Defendant defaulted on their obligation under the Fee Agreement by failing to
make payment when due.
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40. To date, Defendant failed and refused to pay Capozzi all billed amounts at its
usual rates as provided under the Fee Agreement.
41. Defendant's failure to cure their default with Capozzi constitutes a breach of the
Fee Agreement.
Damages
42. Defendant's account is in arrears in the principal amount of $21,600.31, plus
$5,225.88 in unpaid interest to date „$650.50 in Attorney Fees pursuant to the Fee Agreement,
interest from date of judgment until Defendant's obligation is satisfied, costs of collection, and
court costs.
43. Capozzi has been financially damaged in the amount of $27,476.69 by
Defendant's failure to pay for the legal services rendered by Capozzi.
44. Defendant's obligation under the Fee Agreement has not been released,
transferred, or assigned by Capozzi or by Defendant.
45. Judgment has not been entered against Defendant in any jurisdiction.
46. This judgment is being entered in connection with a commercial transaction, and
is not being entered by confession against a natural person in connection with a consumer credit
transaction.
47. To date, Defendant has not cured the default.
48. Capozzi provided to Defendant monthly invoices for the legal services provided
and fees and costs incurred.
49. The total amount due to date under the Fee Agreement is $27,476.69, plus interest
from date of judgment until Defendant's obligation is satisfied, costs of collection, and court
costs.
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WHEREFORE, Capozzi confesses judgment against Defendant in the total sum of
$27,476.69, plus post judgment interest, costs of collection, and court costs.
Respectfully submitted,
CAPOZZI ADLER, P.C.
Date:
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Marc A. rum, Esquire
Attorne I.D. No.: 91273
Capo A Adler, P.C.
P.O. ox 5866
Harrisburg, PA 17110
(717) 233 -4101
Attorney for Plaintiff
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CAPOZZI ADLER, P.C. f /k/a IN THE COURT OF COMMON PLEAS OF
CAPOZZI & ASSOCIATES, P.C., CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. Docket No.:
RC OPERATOR, LLC,
Defendant Confession of Judgment for Money
VERIFICATION
I, Andrew R. Eisemann, Esquire, do hereby verify that the facts made in the foregoing
Complaint in Confession of Judgment for Money are true and correct to the best of my
knowledge, information and belief. I understand that any false statements therein are subject to
the penalties contained in Title 18 of the Pennsylvania Consolidated Statutes Section 4904,
relating to unsworn falsification to authorities.
Date:
q ndrew R. is ann, Esquire
ttorney I. o.: 7441
Managing Par
Capozzi Adler, P.C.
P.O. Box 5866
Harrisburg, PA 17110
(717) 233 -4101
Attorneys for Plaintiff
Louis J. Capozzi, Jr., Esqui
Daniel K. Natirbofl; Esquire
Donald R. Rea, C
eY. Esquire 29
a , 33 Notch Frott
' .:$$ t Street
Craie I nr3t r g 5 Harri
sburg, PA 17110
Bruce G. Baron, Esquire
Andrew Elsemann, Esquire " ": Telephone: (717) 233-4101
Michael M Jerominski, Esquire Fart: (717) 2334103
Dawn L. Richard Es 're : r '' : ' :: www.ca ozziassociates com
Timothy Ziegler, Reimb. Analyst
Karen L. Fisher, paralegal g' t
Jennifer Kain, Paralegal �` 4
Keyoung J. Gill, Par
' (licensed in P
A, NJ and
April 7, 2010
RC Operator, LLC
C/O Barry Feldscher
Barry Feldscher and Associates
3 Eves Drive, Suite 305
Marlton, NJ 08053
Re: Sunrise at Jenkintown
Our Matter Number: TBD ;Z LJ I , 1
Dear Mr. Feldscher:
Our Hiles of professional ethics require us to set forth our fee
commencement of a professional relationshingement in writing at the
t h e P rovid ed , the basis for p This letter will describe the scope of services to be
for billing. fees for those services and our general terms and conditions
SCOne of R�e•• *�c
The legal services to be provided by C
connection with your position as receiver for the assisted living facility known Operator, LLC are in
Jenkintown.
Sunrise at
In addition to the representation described above, you m
perform additional legal work or undertake our r y fr om time to time ask us to
constitutes your authorization for our Firm to perfom'1e ddi� in
legal work o * o
.r This letter
other matters. present you in
We customarily assign the cooi
a particular client to one attorne desi Ylinatin g all aspects of our representation of
channeled through that professional, wPonsibility d ho isthe responsible for coordina Al Work requests are
Of course, we encourage direct comma cation with the individua attorne c oo r d ina ting all work assignments.
Pa nccular project. The client coordinator also is and resp � working on a
questions relating to client fees and our representation. Lo of client coordinator for you. ui responsible for al l at s J. Capozzi, Jr., E quire
performing the rol to a!1
e
�l wire will be
EXHIBIT
A
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BASIS for Peterminin Fe
Fees and costs will be billed to you for this matter on an hourly basis.
Each attorney and professional staff member in our office prepares accurate
and daily time
records for each file on which they work. Hourly rate are determined
generally each year, and will
Of services requested r Y according to the attorney who provide serv and the i c e ,
e
A sc
s of current hourly rates in effect for our attorneys and professional
r Phone co are enclosed with this letter. There is a minimum charge of thr ee - tenths for phone communications, five -ten
the of an hour for review of pleadings, correspondence,
the preparation of pleadings or other
legal documents, and two hours for
resPonses. Travel time is from portal to portal disco
discovery requests and
Should the scope of services to be provided be changed or enlarged beyond those described
in this letter, we reserve the
change or increase in the right to amend or supplement he ent this letter and scope t services. Y
fees charged for the
We Ong a team approach to our work product which is desi
efficient and effective representation b m atching atching the hourly rates and experience provide economically
. Where perienec of our attorneys
to the professional requirements of a particular matter.
Paralegals for more routine and repetitive matters with the goal of a ppropri a te,
th
priate, we attempt
vera to utilize
sacrificing any quality in the product. reducin e oll cost without
Billing Te rms and f✓ondit oas
Periodic Invoices. Our firm rendered during rm sends periodic invo
as ices, usually monthly, detailing services
g the last billing period plus costs and fees which were advanced on your be
filing fees, outside reproduction, express mail fees, computerized research
consultant fees incurred on your behalf and travel ex half
h 'such
Photocopying, � any expert or
PYing telephone, telecopier (f travel expenses. Thy is no charge fbr in -house
ax), and
Invoices are due upon receipt and must be paid within thi
acceptable arrangements are made in advance, rty (30) days unless other
month for any invoices not paid within six We reserve the right to charge interest at I % p
should it be necessary for us to take legal ac t�daa��thhee date of the invoice. In addition,
responsible for any and all costs of collection including, without limitation, nv °icece
y overdue is, you will also be
fees and expenses. Such reasonable attorney's fees shall include times ant b nable attorneys
by this Firm at their usual hourly rates. In addition, the Parties agree that van y attorneys employed
action is necessary, is proper in Dauphin County, ue, in the event legal
In connection with collection of a 'ud gment, settlement
Your behalf, the Firm is authorized to receive and endorse for d
p other disposition of a case on
checks, drafts, money orders or other forms of a eposit to our escrow account any
and to disburse the proceeds, including attorney's fees dots, in aacccordaencpeawith to the Firm,
this Ietter. It is specifically agreed that the
the Fast due account has no relationship to the eOr which the Pro the terms n of
PPved to any past due account even if
r for ceeds were collected.
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Credit Hold. Should any invoice for fees and costs remain
sixty the days, consistent with unpaid for a period in excess of
reserve e the right to our responsibilities under the Rules of professional Conduct we
paid in full temporarily cease work on this engagement until such overdue fees and costs are
or, if our invoices remain unpaid d espite efforts at
Tight to terminate the representation. collecting the same, we reserve the
Disputed Billing: It is imperative, under the terms of this agreement, that you noti us in
writing of any disputed billing within 15 days of your rece do not receive
ipt of a bill. If we
nOh� within 15 days, the Parties agree that the amount of the bill written
that said amount is due and owing. can no longer be disputed and
UCC Lien. For value received for undisputed legal services, as described above, and after
default of this Fee Agreement in excess of 60 days, intending to be legally bound hereb , ou
hereby grant and assign and you agree that C Y Y
apozzi &Associates, P.C. shall have, and there is
hereby created in favor of Capozzi &Associates,
, intangible personal P.C., a security interest in your tangible and
now or hereafter in existence, including the proceeds th ereof and the
increases, substitutions, replacements, additions, and accessions thereto,
collectively as the "Collateral," to hereinafter referred to
Associates, P.C. aft secure that certain obligation of you owed to Capozzi &
er the declaration of Default of this Fee Agreement.
remedies given to Capozzi & Associates, P.C. by this Security B Agreement cap zzi Associtates '
an d
P.C. shall have all the rights and remedies of a secured
Party Commercial Code. I authorize Capoz2i &Associates, P.C. to file a financing
Collateral. state covering the
Reproduction of Complete File. In the event that ou
m' Your file in its entirety, it is complete p
understood that you wi!! paY a p charge ofl 0 otsy of your Sle
all time spent by our staff and attorneys, at their us gather
ual hourly rates, for ing the f! and CO PY and
insuring the requested copy is complete. The above
original file because we must keep a copy for our reph is applicable even if you request your
CONFESSION OF JUDGMENT. 7 E UNDERSIGNED HEREBY EMPOWERS
ATTORNEY OF ANY COURT OF RECORD WITHIN THE UNITED STATES O AME
OR ELSEWHERE TO APP EAR FOR THE UNDERSIGNED AND, W, OR WITHOUT
RI
COMPLAINT FILED, CONFESS JUDGMENTAGAINST THE UNDE
ANY HOLDER HEREOF, RSIGNED IN FAVOR OF
UPON THE OCCURRENCE OF AN EVENT OF DEFAULT, AS
HEItEINABOVE DEFINED, FOR THE UNPAID BALANCE OF UNDISPUTED LEGAL FEES
AS DESCRIBED ABOVE, TOGETHER WITH UNpAID INTEREST THEREON, COSTS OF
SUIT AND ATTORNEY'S FEES, AS DESCRIBED ABOVE, ON WHICH JUDGMENT ONE OR
MORE EXECUTIONS MAY ISSUE FORTHVVITi-I. THE UNDERSIGNED HEREBY FOREVER
WAIVES AND RELEASES ALL ERRORS IN SAID PROCEEDINGS, WAIVES STAY OF
EXECUTION, AND WAIVES ALL EXEMPTIONS FROM LEVY AND SALE OF ANY
PROPERTY THAT NOW ARE OR HEREAFTER MAY BE APPLICABLE: NO SINGLE
EXERCISE OF THE FOREGOING POWER TO CONFESS JUDG
TO EXHAUST THE POWER, WHETHER OR NOT ANY SUCH EXERCISE SHALL BE HELD
By ANY COURT TO BE VALID, VOIDABLE OR VOID, BUT THE SHALL
CONTINUE UNDIMINISHED AND IT MAY BE EXERCISED FROM P TIME TO TIME AS
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OFTEN AS THE HOLDER HEREOF SHALL ELECT UNTIL SUCH TIME AS THE HO
SHALL HAVE RECEIVED PAYMENT IN FULL OF LDER
FEES AND COSTS, INTEREST ON THE OBLIGATION EVIDENCED HEREBY SMALL YES
CONTINUE TO ACCRUE AT THE ABOVE - STATED .RATE AFTER THE ENTRY OF
JUD GMENT HEREON. THE UNDERSIGNED HEREBY
AND A HEARING CONCERNING, THE VALIDITY WAIVES ITS RIGHTS TO NOTICE
OF THE HOLDER'S CLAIMS
HEREUNDER AND AGREES AND CONSENTS TO JUDGMENT BEING ENTERED BY
CONFESSION IN ACCORDANCE WITH THE TERMS
LEVIED ON SUCH WITH
AGAINST ANY AND ALL PRO EX ELUTION BEING
UNDERSIGNED, IN EACH CASE WITHOUT FIRST BEING OCE F THE
OPPORTUNITY TO BE HEARD ON T GIVEN NOTI AND THE
WHICH SUCH JUDGMENT IS ENTERED HE VALIDITY OF THE CLAIM OR CLAIMS UPON
,
Attorney's Lien, As provided by Pennsylvania law, we will
Payment on all files and other. documents retain an attorney's lien for
course of this representation, and reserve and materials collected or generated by this firm in the
in full. the right to retain those files and other materials until paid
If, at any time during the course of our professional relationship, you have any questions
regarding our services or our fees, please raise them with me We strongly encourage open and
frank discussions about our work product and fees. We find that good comm
Professional relationship with our clients and facilitates our ability to address effectively cation ectively aad enhances our
economically the legal challenges facing them.
If these terms are acceptable to 0
retainer of $10,444, in the enclosed Self u please sign this letter and return it to us, along with the
letter is for your records. addressed, stamped envelope. The enclosed copy of this
We thank you for the oppo
LLC, and rtunity to continue to perform legal services for RC Operator,
we look forward to continuing to work with you.
Sincere!
Louis J. Capozzi, Jr., Esquire
enc.
ed d Agreed to:
17►
airy Feldscher, Managing Member
RC Operator, LLC
Date: p
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CAPOM & ASSOCIATES, P. C.
Current N , ly Rarp_ fir Attorneys Rnd Profiessio 1 �r
Members
Louis J. Capozzi, Jr. Esquire
Daniel K. Natirboff, Esquire $250
Donald R. Reave E uire $250
Craig I, Adler, Esquire $250
Bruce G. Baron, Esquire $250
Andrew R. Eisemann $250
ann, Esquire e
Andrew R. Eisem Esqu $200 Michael M. Ierorninski, Esquire $175 Collection Matters
Dawn L. Richards, Esquire $150
$150
Timothy T. Ziegler. Reimbursement Analyst $220
Law Clerks
Paralegals $90
$90
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Capon# d 866 P.C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member February 17, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075 File #: 320 -10
Inv #: 63072
RE: CLOSED. Reorganization of RC Operator
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Jan -03 -12 Telephone calls from Joseph Schwartz re 2.50 625.00 BGB
change in control of Ariel Investments, LLC to
move all 100% to him and need to update
12/30/2011 Notices to DOH and Department
of Welfare: a -mails to Joseph Schwartz re
information that will be required by DOH;
e -mail to Bob Notte to confirm changes;
e -mail from Joseph Schwartz with copy of
signed Agreement of Sale; telephone call from
Upneet Teji, Esq. from Harwood Lloyd
(Hackensack, NJ) concerning updating Ariel
Investments, LLC documents and notices to
PA Agencies of changes in control of same;
e -mail to same with documents and issues for
same; telephone calls to Joseph Schwartz re
same
Jan -05 -12 Communicate with Barry Feldscher re status of 1.00 250.00 BGB
discussions with Einstein on reorganization;
communicate with Barry Feldscher and Joseph
Schwartz re same and draft Notice letters to
DOH and DPW and combining them into one
next week when total deal is completed, as
well as probable DOH requirement for prior
approval of same through reorganization of
CHOW application
Jan -10 -12 Communicate with Upneet Teji, Esq. re 1.00 250.00 BGB
updates to RC Operator and Ariel Operating EXHIBIT
Invoice 4: 63072 Page 2 February 17, 2012
Agreements for submission to DOH as part of
CHOW process; telephone call from Joseph
Schwartz re status of same; review of updated
agreements and suggestions for changes to
promote flexibility for CHOW
Totals 4.50 $1,125.00
DISBURSEMENTS Disbursements Receipts
Jan -13 -12 Courier 15.00
Totals $15.00 $0.00
Total Fees & Disbursements $1,140.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
Cap o r 1e6' P.C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member February 17, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075 File #: 116 -12
Inv #: 63070
RE: CLOSED. 2nd Reorganization of RC Operator
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Jan -12 -12 Office conference with Barry Feldscher re 0.50 125.00 BGB
status of DOH approval of 50% stock changes;
e -mail from DOH re same; communicate with
Karen Fisher re same; office conference with
Barry Feldscher re status of full transition and
status of current staff and management in
same; communicate with Joseph Schwartz re
address to use for DOH documents
Draft Provider's response to DOH questions re 0.50 45.00 KF
change in make up of Ariel
Jan -13 -12 Review of /draft e -mails to Bruce Baron/Craig 0.60 165.00 LJC
Adler re regulatory issues
E -mail to DOH Counsel re additional 2.00 500.00 BGB
reorganization documentation; communicate
with Larissa Shuga at DOH re same; telephone
call from Larissa Shuga at DOH re same;
communicate with Barry Feldscher and Joseph
Schwartz re change in DOH position making
process simpler; telephone call from Joseph
Schwartz re same; communicate with Louis
Capozzi Jr. and Craig Adler re same; office
conferences with Karen Fishe re preparation of
supporting Q &A schedules for DOH
Jan -16 -12 Review of /draft e -mails re regulatory 0.40 110.00 LJC
approvals EXHIBIT
G
Invoice #: 63070 Page 2 February 17, 2012
Communicate with Rick Molfetta and Ed 2.00 500.00 BGB
Harding re information for DOH Q &A
responses; communicate with Ed Harding re
research CMP issues; update templates for
Q &A answers; e -mail to Barry Feldscher and
Joseph Schwartz re whether the registered
address of RC Operator will change; e -mail to
Craig Adler and Maya Druker re filing
paperwork to make corporate office changes
Jan -17 -12 Creation of Amendment to fictitious name(.. 5); 1.20 210.00 PVF
e -mail to National Corp. Research/RC
Operator re address change(.3);
correspondence with Bruce Baron and Maya
Druker(A)
Communicate with Ed Harding re review of 3.00 750.00 BGB
Mr. Schwartz' facilities prior CMS action
record; review of enforcement history;
communicate with DOH Licensure re
information required for 100% share buyout,
with copy to client and Karen Fisher for follow
up; telephone call from Joseph Schwartz and
Barry Feldscher re status; communicate with
Craig Adler and office conference with Craig
Adler re amendment of mailing address in
Delaware Corporate registration and PA
fictitious name registration; draft Q &A Notices
for DOH; e -mail to Karen Fisher re same;
office conference with Paul Van Fleet re
amendment to fictitious name registration and
sign forms for same; office conferences with
Karen Fisher re filing Q &A with DOH;
communicate with Barry Feldscher re copy of
membership assignment document from
Diane D.; e -mail to Joseph Schwartz with new
DPW April proposed rates and analysis; e -mail
from Joseph Schwartz with copy of
assignment from Barry Feldscher to Ariel
,Tan -18 -12 Communicate with Karen Fisher re copy of 0.30 75.00 BGB
Dianne D. Assignment of interests in
transaction and forwarding final packet of
information and documents to DOH;
communicate with Karen Fisher re Fictitious
Name Registration Amendment to put in new
owner address
Jan -19 -12 E -mail to Registered Agent re address change 0.30 52.50 PVF
Invoice #: 63070 Page 3 February 17, 2012
Telephone call from and e -mail from Rich 0.30 75.00 BGB
Molfetta re status of Notice to DOH about
100% reorganization; telephone call from
Barry Feldscher re same and effective date of
changes
Jan -21 -12 Strategy and status conference with Bruce 0.10 21.00 ARE
Baron re transfer of ownership to Joe Swartz
and MA/ Medicare enrollment
Jan -23 -12 Communicate with Upneed Teji, Esq. re 0.10 25.00 BGB
revisions to RC Operator, LLC operating
agreement to reflect current status
Jan -25 -12 Telephone call from Karen Simpson, DOH 0.30 27.00 KF
Office of Legal Counsel, Request for
additional documentation regarding the
reorganization of RC Operator
Jan -26 -12 Communicate with Upneet Tehji, Esq. re sign 0.30 75.00 BGB
copy of revised Operations Agreement for
DOH; e -mail to Karen Fisher re update DOH
with same
Office conference with Bruce Baron re request 0.10 9.00 KF
for DOH /Office of Legal Counsel requesting
additional information for reorganization of
Ariel Investments - RC Operator; fax
information to Karen Simpson, Acting Chief
Counsel, DOH
Jan -27 -12 Communicate with DOH Counsel re 0.30 75.00 BGB
documents on reorganization for DOH files;
e -mail to Upneet Teji, Esq. re same
Jan -30 -12 Communicate with Upneet Teji, Esq. re 0.30 75.00 BGB
documents for DOH Counsel; e -mail to DOH
Counsel re same
Jan -31 -12 Communicate with Upneet Teji, Esq. re signed 0.50 125.00 BGB
100% Reorganization Operating Agreement
for RC Operator to forward to DOH Counsel;
telephone call from Joseph Schwartz re same;
e -mail to DOH counsel with signed
Agreement, with copy to Karen Fisher and
Upneet Teji, Esq.
Totals 13.10 $3,039.50
Invoice #: 63070 Page 4 February 17, 2012
DISBURSEMENTS Disbursements Receipts
Jan -17 -12 File Fictitious Name Amendment to Change 70.00
Address
Jan -18 -12 Courier 15.00
Totals $85.00 $0.00
Total Fees & Disbursements $3,124.50
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
Capoz# A d866, P.C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member March 13, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075
File #: 116 -12
Inv #: 63588
RE: CLOSED. 2nd Reorganization of RC Operator
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Feb -03 -12 Communicate with DOH re clearance for two 0.30 75.00 BGB
reorganization steps, with copies to client
Feb -24 -12 Communicate with Karen Fisher re DPW 0.50 125.00 BGB
questions to update Medicaid files;
communicate with Joseph Schwartz re same;
office conference with Karen Fisher re
completion of forms
Totals 0.80 $200.00
Total Fees & Disbursements $200.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
Capgz# Adler P.C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN 4: 23- 2911821
Joseph Schwartz, Managing Member June 13, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075 File #: 116 -12
Inv #: 65241
RE: CLOSED. 2nd Reorganization of RC Operator
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
May -18 -12 Communicate with Rich Molfetta re 0.10 25.00 BGB
documentation from DOH on CHOW issues
Totals 0.10 $25.00
Total Fees & Disbursements $25.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
Capgz B d 866, PC
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member July 15, 2011
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075
File #: 440 -10
Inv #: 59407
RE: CLOSED. Union Negotiations
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Jun -08 -11 Review of e -mail Michele re CBA revisions 0.30 75.00 LJC
Jun -13 -11 Review of NLRB Order re posting; draft 0.50 125.00 LJC
e -mail to Diane re same
Jun -20 -11 Review proposed changes by Union and 1.00 250.00 LJC
redraft response to Mills
Jun -22 -11 Review /draft e -mails to Michele Mills re 0.60 150.00 LJC
revisions to CBA for WT
Totals 2.40 $600.00
Total Fees & Disbursements $600.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
EXHIBIT
a
M
Cap on #s d866, PC.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member August 10, 2011
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075
File #: 440 -10
Inv #: 59881
RE: CLOSED. Union Negotiations
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Jul -06 -11 Review of /draft e -mails re NLRB /Third 0.50 125.00 LJC
Circuit issues /case opening
Jul -07 -11 Review of /draft e -mails re NLRB Third Circuit 0.20 50.00 LJC
litigation
Jul -11 -11 Review of /draft e -mails Dawn Richards re 0.20 50.00 LJC
status of NLRB proceedings
Review letter from NLRB; e -mail to and from 0.60 117.00 DLR
Diane Donnelly re NLRB Order and
Stipulation Notice requirements
Jul -12 -11 Review of /draft e- mails; telephone call to and 0.50 125.00 LJC
from Michele Mills re final changes to CBA
Jul -14 -11 Review of /draft e -mails re CBA revisions; 0.50 125.00 LJC
telephone call to Diane Donnelly re response
to same
Jul -24 -11 Review of /draft e -mails to Union re Union 1.50 375.00 LJC
delegate /Bereavement leave issues
Jul -25 -11 Review of /draft e -mails re delegate /funeral 1.00 250.00 LJC
leave issue
Jul -27 -11 Review of /draft Review of /draft e -mails re 1.00 250.00 LJC
delegate /funeral leave issues; telephone call to
Diane Donnelly re next steps
Invoice #: 59881 Page 2 August 10, 2011
Totals 6.00 $1,467.00
Total Fees & Disbursements $1,467.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
CapgZ# d 866, PC
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member September 20, 2011
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075
File #: 440 -10
Inv #: 60388
RE: CLOSED. Union Negotiations
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Aug -06 -11 Review of /draft e -mails to Michele Mills re 0.20 50.00 LJC
status of CBA
Aug -07 -11 Review of /draft e -mails to Michele Mills re 0.20 50.00 LJC
CBA issues
Aug -09 -11 Review of /draft a -mails to Diane Donnelly re 0.20 50.00 LJC
CBA issues
Aug -16 -11 Review of /draft e -mails to Union re Union 0.80 200.00 LJC
Delegate /funeral leave status; telephone call
from Diane re same
Telephone call to Barry re CBA issues; review 0.50 125.00 LJC
of /draft e -mails re same
Aug -17 -11 Review of /draft e -mails to Union re 0.60 150.00 LJC
Delegates /funeral leave issues
Aug -22 -11 Telephone call from Diane Donnelly re Union 0.60 150.00 LJC
Agreement on CBA; review of /draft e -mails to
Usamah re same
Aug -25 -11 Revise /finalize Willow Terrace CBA and 0.20 50.00 LJC
transmit to Union
Aug -26 -11 Review of /draft e -mails Union re signing of 0.30 75.00 LJC
CBA
Invoice #: 60388 Page 2 September 20, 2011
Totals 3.60 $900.00
Total Fees & Disbursements $900.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
Capon #s d 866 P.C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member October 12, 2011
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075
File #: 440 -10
Inv #: 61012
RE: CLOSED. Union Negotiations
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Sep -17 -11 Review of /draft a -mails to Union re status of 0.20 50.00 LJC
CBA
Sep -28 -11 Follow up request from NLRB Compliance re 0.40 78.00 DLR
Board Order (posting and expungement);
e -mail to Barry Feldscher re same
Sep -30 -11 Telephone call to and from Shane Thurman at 2.30 448.50 DLR
NLRB re expungements and Notice; e -mail to
Shane Thurman re same; e -mail from Lisa
Woods; review of documents; research timing
of Notice; e -mail to Diane Donnelly re Notice
Totals 2.90 $576.50
Total Fees & Disbursements $576.50
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
r
Capgz s d 866, PC
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member November 17, 2011
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075
File #: 440 -10
Inv #: 61594
RE: CLOSED. Union Negotiations
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Oct -03 -11 E -mail to and from Diane Donnelly re Notice 1.90 370.50 DLR
posting; e -mail to Shane Thurman at NLRB re
same
Oct -04 -11 E -mail to and form Shane Thurman, NLRB re 0.50 97.50 DLR
notice posting; e -mail to and from Diane
Donnelly re same
Oct -06 -11 Review of file /bargaining notes re finalizing 1.00 250.00 LJC
CBA; draft e -mail to Diane Donnelly re open
issues; NLRB Certification
Review Certification and e -mail from Louis 0.60 117.00 DLR
Capozzi Jr. and Bruce Baron re contract
Review of comments and changes to 1199C 0.60 117.00 DLR
Contract
E -mails from and to Louis Capozzi Jr. re 0.10 25.00 BGB
current bargaining unit
Oct -10 -11 Review of /draft e -mails Diane Donnelly re 0.60 150.00 LJC
FMLA issues /finalization of CBA
Oct -11 -11 Review of /draft e -mails to Diane/Usamah re 0.80 200.00 LJC
FMLA /finalization of CBA
Oct -14 -11 Finalize CBA 0.60 150.00 LJC
Invoice 4: 61594 Page 2 November 17, 2011
Totals 6.70 $1,477.00
Total Fees & Disbursements $1,477.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
z
Capoz# 4866, PC
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member January 20, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075 File #: 440 -10
Inv #: 62563
RE: CLOSED. Union Negotiations
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Dec -20 -11 Review of /draft a -mails re Willow Terrace 0.70 175.00 LJC
CBA; telephone call to Usamah re same;
telephone call from Diane re revisions
Dec -21 -11 Telephone conference with Norman re Salem 0.70 175.00 LJC
CBA issues; Coyne handbook; Kearsley CBA
issues; draft e -mail re options
Dec -22 -11 Review of /draft e -mails re accrued vacation 0.50 125.00 LJC
issues
Totals 1.90 $475.00
Total Fees & Disbursements $475.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
Capoz# 4866,, P C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #:23-2911821
Joseph Schwartz, Managing Member February 17, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075
File #: 440 -10
Inv #: 63073
RE: CLOSED. Union Negotiations
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Jan -02 -12 Review of /draft e -mails re side letter for CBA 0.20 55.00 LJC
Jan -05 -12 Finalize side letter; telephone call to Diane 0.50 137.50 LJC
Donnelly re same
Totals 0.70 $192.50
Total Fees & Disbursements $192.50
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
Cap gig Ad 866 P C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member March 13, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075
File #: 440 -10
Inv #: 63589
RE: CLOSED. Union Negotiations
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Feb -02 -12 Review of /draft e -mails re FMLA issues 0.50 137.50 LJC
Feb -20 -12 Review of final CBA and execute same 1.00 275.00 LJC
Totals 1.50 $412.50
Total Fees & Disbursements $412.50
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
Capoz� lA dler, P.C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member January 20, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075 File #: 396 -10
Inv #: 62564
RE: CLOSED. Willow Terrace ULP Termination of Davis and Moore
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Dec -02 -11 Review of documents from Diane Donnelly; 1.00 195.00 DLR
e -mail to Shane Thurman re notice posters and
sworn statement
Dec -12 -11 Follow up with Shane Thurman NLRB re 0.50 97.50 DLR
poster and affidavit
Totals 1.50 $292.50
Total Fees & Disbursements $292.50
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
EXHIBIT
Cap o r Ad 866, P. C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member January 20, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075 File #: 328 -10
Inv #: 62561
RE: Miscellaneous
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Dec -02 -11 Review Louis Capozzi Jr's final comments to 0.30 58.50 BSW
NLRB response posters; edit posters; prepare
final forms of posters; e -mail posters to Barry
Feldscher and Diane Donnelly
Dec -07 -11 Telephone call to Barry re status of transfer of 1.00 250.00 LJC
lease; review of /draft e -mails re same
Dec -22 -11 Review status re final revisions to Employer 0.10 20.00 ARE
Posters to counter NLRB issues
Totals 1.40 $328.50
Total Fees & Disbursements $328.50
-- 75. �d
—w :Z6-3.6 - -
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
EXHIBIT
F
Capoz# d er P. C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #:23-2911821
Joseph Schwartz, Managing Member February 17, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075 File #: 328 -10
Inv #: 63071
RE: Miscellaneous
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Oct -27 -11 Telephone call from Barry Feldscher re 0.50 125.00 LJC
possible sale to Jacob Stern/next steps
Totals 0.50 $125.00
Total Fees & Disbursements $125.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
Cap Pz# d 866 P.C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #:23-2911821
Joseph Schwartz, Managing Member April 18, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075 File #: 328 -10
Inv #: 64098
RE: Miscellaneous
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Mar -28 -12 Telephone call from Joseph Schwartz re 0.10 25.00 BGB
possible CMP from recent G -Level deficiency
Totals 0.10 $25.00
Total Fees & Disbursements $25.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
Capoz Adler, P. C.
P. . Box 5866
Harrisburg, PA 17110
Ph:(717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member May 18, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075
File #: 328 -10
Inv #: 64673
RE: Miscellaneous
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Apr -27 -12 Communicate with Jack Paneth and Louis 0.10 25.00 BGB
Capozzi Jr. re Appeal FYE June 30, 2012 rates
and coordination of collection of
overpayments; communicate with Dan
Natirboff and Tim Ziegler re same
Totals 0.10 $25.00
Total Fees & Disbursements $25.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
Capgz# d se6' P.C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #:23-2911821
Joseph Schwartz, Managing Member June 13, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075 File #: 328 -10
Inv #: 65242
RE: Miscellaneous
DISBURSEMENTS Disbursements Receipts
May -17 -12 Courier 15.00
Totals $15.00 $0.00
Total Fees & Disbursements $15.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
Capgz# A dler P.C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member July 19, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075 File #: 328 -10
Inv #: 65789
RE: Miscellaneous
DISBURSEMENTS Disbursements Receipts
Jun -22 -12 Courier 15.00
Totals $15.00 $0.00
Total Fees & Disbursements $15.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
Capoz# Ad 866, P.C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #:23-2911821
Joseph Schwartz, Managing Member August 17, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075 File #: 328 -10
Inv #: 66217
RE: Miscellaneous
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Jul -03 -12 Compared Year 17 Quarter 4 Rate against Year 1.00 150.00 EEM
18 Quarter 1 Rate and estimated the quarterly
impact that DPW will owe Willow Terrace
Totals 1.00 $150.00
Total Fees & Disbursements $150.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
Cap gz s d 866, PC
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member September 18, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075 File #: 328 -10
Inv #: 66679
RE: Miscellaneous
DISBURSEMENTS Disbursements Receipts
Aug -22 -12 Courier (Annual CCRC Filing) 15.00
Totals $15.00 $0.00
Total Fees & Disbursements $15.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
Capoz# Ad 866, P.C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member October 24, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075 File #: 328 -10
Inv #: 67216
RE: Miscellaneous
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Sep -04 -12 Telephone call from Joseph Schwartz re 0.30 75.00 BGB
impact of 1.21 MACMI on rates; communicate
with Erin Motter re same with copies to Joseph
Schwartz
Totals 0.30 $75.00
Total Fees & Disbursements $75.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
Capon B d 866, PC
Harrisburg, PA 17110
Ph:(717) 233 -4101 Fax:(717) 233 -4103 EIN #:23-2911821
Joseph Schwartz, Managing Member November 14, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075 File #: 328 -10
Inv #: 67685
RE: Miscellaneous
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Oct -15 -12 Telephone call from Alex Ringkamp re wage 5.20 1,430.00 DRR
and hour audit by US Department of Labor;
review of letter setting out the audit
requirements; office conference with Dawn
Richards re same; draft e -mail to Alex
Ringkamp re same; review of possible
overtime calculations from prior owner; draft
e -mail to Alex Ringkamp re potential
employee interviews
Oct -16 -12 Telephone call from Alex Ringkamp re 2.20 605.00 DRR
Auditor's request to interview employees;
office conference with Dawn Richards re
same; draft e -mail to Alex Ringkamp re
allowing interviews to proceed; receipt and
review of e -mail re exit from Day one
Oct -31 -12 Draft e -mail to Alex Ringkamp re wages and 0.60 165.00 DRR
hours audit; receipt and review of response to
same
Totals 8.00 $2,200.00
Invoice #: 67685 Page 2 November 14, 2012
Total Fees & Disbursements $2,200.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
Capgz #B d 866, R C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #:23-2911821
Joseph Schwartz, Managing Member May 16, 2011
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075 File #: 802 -11
Inv #: 58566
RE: Willow Terrace Employee Handbook Review
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Apr -13 -11 Initial review of employee handbook 1.20 180.00 DLR
Apr -14 -11 Review of employee handbook and job 4.00 600.00 DLR
descriptions
Apr -15 -11 Review and update facility Employee 8.10 1,215.00 DLR
handbook
Apr -18 -11 Follow up on outstanding items from AL 1.50 225.00 DLR
application packet and Residence - Resident
contract
Apr -19 -11 Continued review of LPN job description and 2.80 420.00 DLR
performance evaluation
Apr -22 -11 Continued review of LPN job description and 1.70 255.00 DLR
employee handbook
Apr -25 -11 Continued review and update of employee 1.00 150.00 DLR
handbook
Apr -26 -11 Continued review of job description; e -mail to 0.70 105.00 DLR
Diane Donnelly
Apr -27 -11 Review of LPN job description and employee 2.30 345.00 DLR
handbook
Apr -29 -11 Continued review and update of employee 1.10 165.00 DLR
handbook EXHIBIT
Invoice #: 58566 Page 2 May 16, 2011
Totals 24.40 $3,660.00
Total Fees & Disbursements $3,660.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
Capgz# A 866, P
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member July 15, 2011
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075
File #: 802 -11
Inv #: 59409
RE: Willow Terrace Employee Handbook Review
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Jun -01 -11 Revisions to Employee Handbook 1.50 225.00 DLR
Jun -14 -11 Redraft RC Operator Employee Handbook 1.30 325.00 LJC
Jun -24 -11 Review of comments from Louis Capozzi, Jr. 2.00 300.00 DLR
revisions to handbook
Jun -29 -11 Status conference with Dawn Richards re 0.10 20.00 ARE
changes to Employee Handbook and issues
Status conference with Andrew Eisemann re 0.10 15.00 DLR
changes to Employee Handbook and issues
Totals 5.00 $885.00
Total Fees & Disbursements $885.00
790.00 PQtd
`T� 95, 00 [Dak
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
a
Capgz# d 866, P.C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member August 10, 2011
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075
File #: 802 -11
Inv #: 59884
RE: Willow Terrace Employee Handbook Review
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Jul-06-11 E -mail to Diane Donnelly re handbook; 0.50 75.00 DLR
revisions to handbook
Totals 0.50 $75.00
Total Fees & Disbursements $75.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
Capgz #B d866 P.C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member September 20, 2011
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075
File #: 802 -11
Inv #: 60392
RE: Willow Terrace Employee Handbook Review
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Aug -03 -11 Status conference with Dawn Richards re 0.10 20.00 ARE
updating and revisions to employee handbook
Totals 0.10 $20.00
Total Fees & Disbursements $20.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
i
Capoz# Ad 866, PC
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN 4: 23- 2911821
Joseph Schwartz, Managing Member November 17, 2011
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075
File #: 802 -11
Inv #: 61596
RE: Willow Terrace Employee Handbook Review
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Oct -10 -11 Rewrite FMLA language 1.00 195.00 DLR
Oct -11 -11 Review FMLA language; e -mail to and from 1.40 273.00 DLR
Louis Capozzi Jr. re implementation
Oct -12 -11 Telephone call from Diane Donnelly; 0.50 97.50 DLR
discussed NLRB sworn certification, posters
and Employee Handbook
Totals 2.90 $565.50
DISBURSEMENTS Disbursements Receipts
Oct -31 -11 Research 96.84
Totals $96.84 $0.00
Total Fees & Disbursements $662.34
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
CapgZ# Adler P C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member December 12, 2011
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075 File #: 802 -11
Inv #: 62101
RE: Willow Terrace Employee Handbook Review
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Nov -08 -11 E -mail to Diane Donnelly re implementation 0.70 136.50 DLR
of handbook; telephone call to Diane Donnelly
re same; review notes from Louis Capozzi Jr.
re potential sale of facility
Nov -09 -11 Review draft of Handbook; e -mail to David 0.50 97.50 DLR
Blumerkrantz and Louis Capozzi Jr.
Nov -22 -11 Continued review of handbook 1.20 234.00 DLR
Totals 2.40 $468.00
DISBURSEMENTS Disbursements Receipts
Nov -30 -11 Research 134.04
Totals $134.04 $0.00
Total Fees & Disbursements $602.04
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
a
Capgz# d 866, P.C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #:23-2911821
Joseph Schwartz, Managing Member July 19, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075
File #: 802 -11
Inv #: 65790
RE: Willow Terrace Employee Handbook Review
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Jun -11 -12 Review of e-mail from Louis Capozzi Jr.; 0.60 120.00 DLR
review of previous e -mails related to revisions
to Employee Handbook
Jun -12 -12 Review of e -mail re revisions to Employee 0.40 80.00 DLR
Handbook; communicate with Louis Capozzi
Jr. re implementation
Totals 1.00 $200.00
Total Fees & Disbursements $200.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
P
Ca poZ B d 866 P.C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member April 18, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075 File #: 695 -11
Inv #: 64099
RE: Willow Terrace MA Audit Appeal FYE 6/30/09
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Mar -09 -12 Analysis and review of Pre - Hearing 0.50 137.50 DKN
Conference Scheduling Order; review status of
Settlement offer preparation and trial
preparation
Mar -15 -12 Prepared for and conducted Pre - Hearing 0.50 137.50 DKN
conference
Communicate with Beth Duffy re request for 0.10 15.00 EEM
status of information
Mar -22 -12 Analysis and review of Order establishing 0.50 137.50 DKN
Provider Position Paper deadlines and check
status of production of documents from third
parties necessary to file same
Mar -27 -12 Communicate with Beth Duffy re status of 0.10 15.00 EEM
information requested
Totals 1.70 $442.50
EXHIBIT
Invoice #: 64099 Page 2 April 18, 2012
Total Fees & Disbursements $442.50
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
i
Cap Adl P. C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 2.33 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member May 18, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075 File #: 695 -11
Inv #: 64674
RE: Willow Terrace MA Audit Appeal FYE 6/30/09
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Apr -17 -12 Draft Subpoena Duces Tecum for 6/30/09 MA 2.00 350.00 MAT
Audit Appeal to gather information from
Albert Einstein Healthcare
Totals 2.00 $350.00
DISBURSEMENTS Disbursements Receipts
Apr -27 -12 Courier Charge 15.00
Totals $15.00 $0.00
Total Fees & Disbursements $365.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
r
Capgz s d 866, P.C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member July 19, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075
File #: 695 -11
Inv #: 65791
RE: Willow Terrace MA Audit Appeal FYE 6/30/09
DISBURSEMENTS Disbursements Receipts
Jun- 1.9 -12 Courier 15.00
Totals $15.00 $0.00
Total Fees & Disbursements $15.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
Cap Pz B d 866 P.C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member August 17, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075 File #: 695 -11
Inv #: 66218
RE: Willow Terrace MA Audit Appeal FYE 6/30/09
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Jul -09 -12 Draft Motion to Extend due date for Willow 0.60 105.00 MAT
Terrace Position Paper on 6/30/09 MA Audit
Appeal (still waiting on response to subpoena)
Jul -25 -12 Analysis /review of Order regarding position 0.60 165.00 DKN
paper and review status of discovery
production
Totals 1.20 $270.00
DISBURSEMENTS Disbursements Receipts
Jul -10 -12 Courier Charge 15.00
Totals $15.00 $0.00
Total Fees & Disbursements $285.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
Capon# d 866, P.C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member October 24, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075 File #: 695 -11
Inv #: 67217
RE: Willow Terrace MA Audit Appeal FYE 6/30/09
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Sep -17 -12 Preparation of reimbursement analysis for 2.00 300.00 EEM
Settlement proposal
Sep -18 -12 Multiple e -mails regarding pending document 0.50 137.50 DKN
request issues and subpoenas for same; review
of draft Motion to Enforce
Preparation of reimbursement analysis for 4.00 600.00 EEM
Settlement proposal
Totals 6.50 $1,037.50
DISBURSEMENTS Disbursements Receipts
Sep -30 -12 Research 78.15
Research 21.20
Totals $99.35 $0.00
Invoice #: 67217 Page 2 October 24, 2012
Total Fees & Disbursements $1,136.85
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
Capoz# d 866 P.C.
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member November 14, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075 File #: 695 -11
Inv #: 67686
RE: Willow Terrace MA Audit Appeal FYE 6/30/09
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Oct -02 -12 Analysis and review of Order granting 0.50 137.50 DKN
Extension on Position Paper and review status
of preparation of same and client production of
documents
Totals 0.50 $137.50
Total Fees & Disbursements $137.50
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
Capoz #B d 866 PC
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member December 11, 2012
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075 File #: 695 -11
Inv #: 68213
RE: Willow Terrace MA Audit Appeal FYE 6/30/09
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Nov -05 -12 Preparation of reimbursement analysis for 0.50 75.00 EEM
Settlement proposal
Totals 0.50 $75.00
Total Fees & Disbursements $75.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
fl
t ,
Capoz# d 866
Harrisburg, PA 17110
Ph: (717) 233 -4101 Fax:(717) 233 -4103 EIN #: 23- 2911821
Joseph Schwartz, Managing Member February 13, 2013
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075 File #: 695 -11
Inv #: 69280
RE: Willow Terrace MA Audit Appeal FYE 6/30/09
DATE DESCRIPTION HOURS AMOUNT TIMEKEEPER
Jan -29 -13 Drafted Motion to Withdraw 6/30/09 MA 0.50 1.00.00 MAT
Audit Appeal
Totals 0.50 $100.00
Total Fees & Disbursements $100.00
Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon
must be submitted in writing within 15 days of receipt.
Please put Invoice Number on your check, Thank You
Capozzi Adler, P.C.
P. O. Box 5866
Harrisburg, PA 17110
Telephone: (717) 233 -4101
Fax: 717 - 233 -4103
Joseph Schwartz, Managing Member As at Jun 27, 2013
RC Operator, LLC
505 Marlboro Road
Suite 5
Woodridge, NJ 07075
REMINDER NOTICE
Bill Date Matter # Inv # Billed Int Due Paid Due Aging
May -16 -11 802 -11 58566 3,660.00 1,286.92 0.00 4,946.92 > 120 days
Jul -15 -11 440 -10 59407 600.00 193.22 0.00 793.22 > 120 days
Jul -15 -11 802 -11 59409 885.00 216.43 790.00 31 1.43 > 120 days
Aug-10-11 440 -10 59881 1,467.00 453.60 0.00 1,920.60 > 120 days
Aug -10 -11 802 -11 59884 75.00 23.19 0.00 98.19 > 120 days
Sep -20 -11 440 -10 60388 900.00 260.09 0.00 1,160.09 > 120 days
Sep -20 -11 802 -11 60392 20.00 5.78 0.00 25.78 > 120 days
Oct -12 -11 440 -10 61012 576.50 160.35 0.00 736.85 > 120 days
Nov -17 -11 440 -10 61594 1,477.00 384.59 0.00 1,861.59 > 120 days
Nov -17 -11 802 -11 61596 662.34 172.46 0.00 834.80 > 120 days
Dec -12 -11 802 -11 62101 602.04 149.34 0.00 751.38 > 120 days
Jan -20 -12 328 -10 62561 328.50 66.81 75.00 320.31 > 120 days
Jan -20 -12 440 -10 62563 475.00 108.69 0.00 583.69 > 120 days
Jan -20 -12 396 -10 62564 292.50 51.88 135.00 209.38 > 120 days
Feb -17 -12 116 -12 63070 3,124.50 671.81 0.00 3,796.31
EXHIBIT
Feb -17 -12 328 -10 63071 125.00 26.88 0.00 151.88
v
> 120 days
Feb -17 -12 320 -10 63072 1,140.00 245.12 0.00 1.,385.12
Feb -17 -12 440 -10 63073 192.50 41.39 0.00 233.89 > 120 days
Mar -13 -12 116 -12 63588 200.00 40.54 0.00 240.54 > 120 days
Mar -13 -12 440 -10 63589 412.50 83.61 0.00 496.11 > 120 days
Mar -13 -12 396 -10 63591 160.00 32.43 0.00 192.43 > 120 days
Apr -18 -12 328 -10 64098 25.00 4.62 0.00 29.62 > 120 days
Apr -18 -12 695 -11 64099 442.50 75.16 76.92 440.74 > 120 days
May -18 -12 328 -10 64673 25.00 4.25 0.00 29.25 > 120 days
May -18 -12 695 -11 64674 365.00 62.10 0.00 427.10 > 120 days
Jun -13 -12 116 -12 65241 25.00 3.93 0.00 28.93 > 120 days
Jun -13 -12 328 -10 65242 15.00 2.36 0.00 17.36 > 120 days
Jul -19 -12 328 -10 65789 15.00 2.09 0.00 17.09 > 120 days
Jul -19 -12 802 -11 65790 200.00 27.91 0.00 227.91 > 120 days
Jul -19 -12 695 -11 65791 15.00 2.09 0.00 17.09 > 120 days
Aug -17 -12 328 -10 66217 150.00 18.79 0.00 168.79 > 120 days
Aug -17 -12 695 -11 66218 285.00 35.70 0.00 320.70 > 120 days
Sep -18 -12 328 -10 66679 15.00 1.64 0.00 16.64 > 120 days
Oct -24 -12 328 -10 67216 75.00 6.88 0.00 81.88 > 120 days
Oct -24 -12 695 -11 67217 1,136.85 104.28 0.00 1,241.13 > 120 days
Nov -14 -12 328 -10 67685 2,200.00 179.01 0.00 2,379.01 > 120 days
Nov -14 -12 695 -11 67686 137.50 11.19 0.00 148.69 > 120 days
Dec -11 -12 695 -11 68213 75.00 5.10 0.00 80.10 > 120 days
Feb -13 -13 695 -11 69280 100.00 3.65 0.00 103.65 > 120 days
Totals $22,677.23 $5,225.88 $1,076.92 $26,826.19
Balance Due and Owing $26,826.19
Your account is past due. If you require copies of any of the invoices listed above, please call our Billing Department.
Your prompt attention to these past -due invoices would be greatly appreciated. If payment has already been sent, please
disregard this notice.
CAPOZZI ADLER, P.C. f /k/a IN THE COURT OF COMMON PLEAS OF
CAPOZZI & ASSOCIATES, P.C., CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. : Docket No.:
RC OPERATOR, LLC,
Defendant Confession of Judgment for Money
CERTIFICATE OF RESIDENCE UNDER RULE 2951
I do hereby certify that the precise residence and complete post office address of the
Plaintiff, Capozzi Adler, P.C., is 1200 Camp Hill Bypass, Suite 205, Camp Hill, Cumberland
County, Pennsylvania 17011 — Mailing Address: P.O. Box 5866, Harrisburg, Dauphin County,
,
Pennsylvania 1 :7110.
I do hereby certify that the complete post office address of the Defendant is:
RC Operator, LLC
Willow Terrace — Penn Tower Building
One Penn Boulevard
Philadelphia, PA 19144
` f
Date: L n
Marc . Crum, Esquire ,�,
Atto ey I.D. No.: 91273 C=
g4 zzi Adler, P.C. -O w
P.O. Box 5866 70 -c r
Harrisburg, PA 17110 C CD
co
(717) 233 -4101 -rs�
Attorney for Plaintiff
CD
{
:tea
CAPOZZI ADLER, P.C. f /k/a IN THE COURT OF COMMON PLEAS OF
CAPOZZI & ASSOCIATES, P.C., CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. Docket No.:
RC OPERATOR, LLC,
Defendant Confession of Judgment for Money
NOTICE UNDER PA.R.C.P RULE 2958.1
OF JUDGMENT AND EXECUTION THEREON
NOTICE OF DEFENDANT'S RIGHTS
TO: RC OPERATOR, LLC, DEFENDANT:
A judgment in the amount of $27,476.69, plus post judgment interest, attorneys' fees and
costs of suit, has been entered against you and in favor of the Plaintiff without any prior notice or
hearing based on a Confession of Judgment contained in a written agreement or other paper
allegedly signed by you. The Sheriff may take your money or other property to pay the
judgment at any time after thirty (30) days after the date on which this notice is served on
you.
You may have legal rights to defeat the judgment or to prevent your money or property
from being taken. YOU MUST FILE A PETITION SEEKING RELIEF FROM THE
JUDGMENT AND PRESENT IT TO A JUDGE WITHIN THIRTY (30) DAYS AFTER THE
DATE ON WHICH THIS NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR
RIGHTS.
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, PA 17013
1- 800 - 990 -9108
r� 717- 249 -3,1 n 6
Date:��J
Mac A. Crum, Esquire
Attorney I.D. No.: 91273
apozzi Adler, P.C.
P.O. Box 5866
Harrisburg, PA 17110
(717) 233 -4101
Attorneys for Plaintiff
CAPOZZI ADLER, P.C. f /k/a IN THE COURT OF COMMON PLEAS OF
CAPOZZI & ASSOCIATES, P.C., CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v.
Docket No.:
RC OPERATOR, LLC,
Defendant : Confession of Judgment for Money
Rule 236 NOTICE OF ENTRY OF JUDGMENT
NOTICE OF DEBTOR'S RIGHTS
TO: RC OPERATOR, LLC, DEFENDANT
judgment
You are hereby notified that on LO /�'� �� pl post- ud ment interest and
by confession was entered against you in the sum of $27jPratho 476.69, p p J g�
costs of suit.
Date: -- �
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OF CANNOT AFFORD ONE U OCAN TO OR GET LEGAL NE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD
STREET CARLISLE, PA 17013
1- 800 - 990 -9108
717 -249 -3166
1 hereby certify that the following are the addresses of the Defendant(s) stated in the certificate of
residence: Willow Terrace — Penn Tower Building, One Penn Boulevard, Philadelphia, PA
19144. ,{ _
Date: Marc . Crum, Esquire
Attor ey I.D. No.: 91273
Capozzi Adler, P.C.
P.J. Box 5866
Harrisburg, PA 17110
(717) 233 -4101
Attorney for Plaintiff
9
CAPOZZI ADLER, P.C. f/k/a : IN THE COURT OF COMMON PLEAS OF
CAPOZZI & ASSOCIATES, P.C., : CUMBERLAND COUNTY, PENNSYLVANIA
•
•
Plaintiff
v. : Docket No.: 02 013 - i3 2
•
RC OPERATOR, LLC, •
•
Defendant : Confession of Judgment for Money
CERTIFICATE OF SERVICE
TO PROTHONOTARY OF CUMBERLAND COUNTY:
m
I hereby certify that on July 9, 2013, a true and correct copy of the Notice undit- le2
c-‘
--
2958.1 of Judgment and Execution was personally served upon the following: L.)
IN)
RC Operator, LLC — -
Willow Terrace–Penn Tower Building
One Penn Boulevard
Philadelphia, PA 19144
A true and correct copy of the proof of service is attached hereto and incorporated herein
as Exhibit "A."
Date: I
Marc • . Crum, Esquire
Attorney I.D. No.: 91273
Cap I zzi Adler, P.C.
P.O. Box 5866
Harrisburg, PA 17110
(717) 233-4101
Attorney for Plaintiff
11
111111 IIIII 11111111111111111111111111111111111111111111011111111031111
2 0 1 3 0 6 2 8 1 5 2 8 1 8
CAPOZZI ADLER, P.C., F/K/A CAPOZZI &ASSOCIATES, P.C. i 4b- Court Of COefln1Oo fleas
Plaintiff /;Ctr ,i
vs. Ct rn y I ct Venue
RC OPERATOR, LLC
Defendant Docket Number: 13 3752
Person to be served(Name and Address):
RC OPERATOR, LLC
WILLOW TERRACE-PENN TOWER BLDG ONE PENN BLVD AFFIDAVIT OF SERVICE
PHILADELPHIA PA 19144
By serving: RC OPERATOR, LLC (For Use by Private Service)
Attorney: MARC A. CRUM, ESQ. Cost of Service pursuant to R.4:4-3(c)
Papers Served: NOTICE UNDER PA.R.C.P. RULE 2958.1 OF JUDGMENT AND $
EXECUTION THEREON NOTICE OF DEFENDANT'S RIGHTS, NOTICE OF
ENTRY OF JUDGMENT NOTICE OF DEBTOR'S RIGHTS,CONFESSION OF
JUDGMENT, COMPLAINT, CERTIFICATES,VERIFICATION,ATTACHMENTS
Service Data: [X]Served Successfully [ ]Not Served
DateTme: 07/09/2013 12:45PM Attempts: Date/Time:
Date/Time:
[ ]Delivered a copy to him/her personally DateTme:
[ ]Left a copy with a competent household member over 14 years of age Name of.Person Served and relationship/title:
residing therein (indicate name&relationship at right)
LISA WOODS
[X] Left a copy with a person authorized to accept service,e.g. managing agent,
registered agent, etc. (indicate name&official title at right) ASSISTANT
Description of Person Accepting Service:
SEX: F AGE:51-65 HEIGHT:5'9"-6'0" WEIGHT: 161-200 LBS. SKIN: BLACK HAIR: BLACK OTHER: GLASSES
Unserved:
[ ]Defendant is unknown at the address furnished by the attorney
[ ]All reasonable inquiries suggest defendant moved to an undetermined address wealth of PA
[ ]No such street in municipality Common hja
[ ]Defendant is evading service County of Phjja°e p
[ ] No response on: Date/Time:
Date/Time:
Date/Time:
Other: COMMONWEAL Iii OF PENNSYLVANIA
_ Notarial Seal
Stuart 0.Kaplan,Notary Public
fly of PhiIathlOhia,Philadelphia County i
rly Com!n)csem F,,pires Aug.14,2015 j
,�,�c3=a i• nr _f vAm21 r C!)t4 f>F 105R1Efi
Served Data: �
Subscribed and Sworn to me this I, L�Yzv+c T 144)C 2 ,
was at the time of service a competent adult, over
t Z- day of 20 1 3 the age of 18 and not having a direct interest in the
litigation. I declare under penalty of perjury that the
Notary Signature: foregoing is true and correct.
. r C s1VIA. a■ / 1 12013
Name of Notary r Comm.-sion piration ignaa ess Server Date
■1
CAPOZZI ADLER, P.C. f/k/a IN THE COURT OF COMMON PLEAS OF
CAPOZZI & ASSOCIATES, P.C., CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. Docket No.: 13-3752
RC OPERATOR, LLC,
Defendant Confession of Judgment for Mon w
MCD CJ) ?3
;n m rt-j
f-
cte
r- --�y ;.v
PRAECIPE TO SATISFY JUDGMENT <a x -
c3 p
TO: THE PROTHONOTARY OF CUMBERLAND COUNTY (A)
Kindly mark the judgment in the above-referenced action entered on June 28, 2013 in the
amount of$27,476.69 as SATISFIED.
Date: ql�j A.
Marc rum, Esquire
Attorn ID #91273
Capo i Adler, P.C.
P. O. ox 5866
Ha isburg, PA 17110
(717) 233-4101
Attorney for Plaintiff
R 3
CAPOZZI ADLER, P.C. f/k/a IN THE COURT OF COMMON PLEAS OF
CAPOZZI & ASSOCIATES, P.C., CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. : Docket No.: 13-3752
RC OPERATOR, LLC,
Defendant Confession of Judgment for Money
CERTIFICATE OF SERVICE
I do hereby certify that I caused a true and correct copy of the foregoing Praecipe to
Satisfy Judgment to be served via first class U.S. mail, postage prepaid, addressed as follows:
RC Operator, LLC
Willow Terrace—Penn Tower Building
One Penn Boulevard
Philadelphia, PA 19144
Date: J�U
arc . Crum, Esqu e
Atto ey ID 991273
Ca ozzi Adler, P.C.
P. Box 5866
Harrisburg, PA 17110
(717) 233-4101
Attorney for Plaintiff