HomeMy WebLinkAbout14-0339 Supreme CO U 00 - nsylvania
Cout occerinino leas For Prothonotary Use Only:
Civil C v eet r� sI`1
"� 1. Docket No:
Cu'Fnb�erla d'�' �yY County
1
The information collected on this form is used solely for court administration purposes. This fora? does not
supplement or replace the filing and service of pleadings or other papers as required by law or rules of court.
Commencement of Action:
S Complaint El Writ of Summons El Petition
Transfer from Another Jurisdiction ❑ Declaration of Taking
E
C Lead Plaintiff's Name: Lead Defendant's Name:
T BCC Shippensburg Operation, LLC Anna Gettel
I Are money damages requested? El Yes El No Dollar Amount Requested: x within arbitration limits
(check one) El outside arbitration limits
O
N Is this a Class Action Suit? Yes fX No Is this an MDJAppeal? I_] Yes H No
A Name of Plaintiff /Appellant's Attorney: Dennis C. Vondran, Jr., Esquire
El Check here if you have no attorney (are a Self - Represented [.I'ro Se] .Litigant)
Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
0 Intentional [I Buyer Plaintiff Administrative Agencies
El Malicious Prosecution 0 Debt Collection: Credit Card El Board of Assessment
M7 Motor Vehicle x Debt Collection: Other 0 Board of Elections
Nuisance Nursing Home 0 Dept. of Transportation
S I" 1 Premises Liability [�] Statutory Appeal: Other
Q Product Liability (does not include
E mass tort) E3 Employment Dispute:
Q Slander /Libel/ Defamation Discrimination
C 0 Other:❑ Employment Dispute: Other E] Zoning Board
T Q Other:
I 0 Other:
O MASS TORT
E l Asbestos
! N 0 Tobacco
M Toxic Tort - DES
❑— Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
Toxic Waste El Ejectment IQQ Common Law /Statutory Arbitration
B 0 Other: 0 Eminent Domain /Condemnation Declaratory Judgment
El Ground Rent Mandamus
0 Landlord /Tenant Dispute Q Non - Domestic Relations
El Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABLITY 0 Mortgage Foreclosure: Commercial 0 Quo Warranto
Q Dental El Partition Replevin
M Legal 0 Quiet Title l Other:
rl Medical 0 Other:
E] Other Professional:
Updated 1/1/2011
LAW OFFICE OF BRIAN SCOTT DIETRICH, P.C.
BRIAN SCOTT DIETRICH, ESQUIRE ATTORNEYS FOR PLAINTIFF
Attorney I.D. # 57174 BCC Shippensburg Operations, LLC
DENNIS C. VONDRAN JR., ESQUIRE d /b /a Elmcroft of Shippensburg
Attorney I.D. # 306396
P.O. Box 1627
Blue Bell, Pennsylvania 19422 -0450
[T] (610) 629 -6300
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -- LAW
BCC Shippensburg Operations, LLC �n
S C= --�
d /b /a Elmcroft of Shippensburg No.
129 Walnut Bottom Road',T� te r~
Shippensburg, PA 17257 ��� ....
CD
cr'
V. -C� �Cf ry
Anna Gettel a /k/a A. Gettel ARBITRATION CASE
a /k/a Anna Grace Gettel
474 East King Street
Shippensburg, PA 17257
NOTICE TO DEFEND
You have been sued in Court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this complaint and notice are served, by entering
a written appearance personally or by an 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
against you by the Court without further notice for any money claims in the complaint or for any other claims
or relief requested by the plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
717 - 249 -3166 OR 800 - 990 -9108
S
LAW OFFICE OF BRIAN SCOTT DIETRICH, P.C.
BRIAN SCOTT DIETRICH, ESQUIRE ATTORNEYS FOR PLAINTIFF
Attorney I.D. # 57174 BCC Shippensburg Operations, LLC
DENNIS C. VONDRAN JR., ESQUIRE d/b /a Elmcroft of Shippensburg
Attorney I.D. # 306396
P.O. Box 1627
Blue Bell, Pennsylvania 19422 -0450
[T] (610) 629 -6300
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -- LAW
BCC Shippensburg Operations, LLC
d /b /a Elmcroft of Shippensburg No.
129 Walnut Bottom Road
Shippensburg, PA 17257
V.
Anna Gettel a /k/a A. Gettel ARBITRATION CASE
a /k/a Anna Grace Gettel
474 East King Street
Shippensburg, PA 17257
AND NOW, comes Plaintiff, BCC Shippensburg Operations, LLC d/b /a Elmcroft of
Shippensburg, by and through its attorneys, LAW OFFICE OF BRIAN SCOTT DIETRICH,
P.C., to request relief before this Honorable Court and, in support thereof, avers as follows:
COMPLAINT
1. Plaintiff, BCC Shippensburg Operations, LLC d /b /a Elmcroft of Shippensburg
(hereinafter referred to as "Plaintiff'), is a corporation doing business as a personal care home
facility at 129 Walnut Bottom Road, Shippensburg, PA 17257.
2. Defendant, Anna Gettel a/k/a A. Gettel a/k/a Anna Grace Gettel (hereinafter
referred to as "Anna Gettel "), is an adult individual with an address of 474 East King Street,
Shippensburg, PA 17257.
3. On information and belief Anna Gettel is the spouse of the late Leroy Gettel.
4. Jurisdiction in this case is proper in the Court of Common Pleas of Cumberland
County, Pennsylvania.
5. Leroy Gettel was admitted to Plaintiff's facility on September 6, 2011.
6. Leroy Gettel was discharged from Plaintiff's facility on December 2, 2012
7. On information and belief Leroy Gettel expired on December 2, 2012.
8. Leroy Gettel received necessary services from Plaintiff.
9. Leroy Gettel incurred necessary service expenses at Plaintiff's facility.
10. The necessary services rendered to Leroy Gettel all reasonable standards of care
for the type and quality of services.
11. Plaintiff's charges are usual, customary, and normal industry amounts for
necessary services of this type and quality.
12. Plaintiff billed for the necessary service expenses incurred by Leroy Gettel. A
true and correct copy of Plaintiff's charges are attached hereto, made a part hereof, and marked
Exhibit A.
13. Plaintiff has demanded payment from Anna Gettel under the Doctrine of
Necessities.
14. Anna Gettel made a payment of $2,000 on June 4, 2013 but has refused payment
of the remaining debt.
15. The amount owed Plaintiff for the necessary services provided to Leroy Gettel is
as follows:
(a) Principal $ 10,653.51
(See Exhibit A)
(b) Interest as of November 30, 2013 $ 651.27
(c) Sub - total .............. ............................... $ 11,304.78
(d) per diem interest commencing December 1, 2013 is $1.75 per day.
16. Plaintiff is permitted to claim and receive interest at the statutory rate of 6% per
annum.
17. Due to Anna Gettels' refusal to remit payment in full each month for the
necessary services rendered by Plaintiff, the account is in arrears.
Page 2 of 5
18. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq.
(1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s)
dispute the debt in writing, within thirty (30) days of receipt of this pleading, counsel for Plaintiff
will obtain and provide Defendant(s) with written verification thereof, otherwise, the debt will be
assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading,
counsel for Plaintiff will send Defendant(s) the name and address of the original creditor, if
different from above. Defendant must file a written response with the court to avoid the entry of
a default judgment in this case. Defendant should take this paper to an attorney or contact the
lawyer referral service printed on the Notice to Defend.
a. This communication is from a debt collector.
b. This is an attempt to collect a debt and any information obtained will be
used for that purpose.
C. Unless you dispute the validity of this debt, or any portion thereof, within
thirty (30) days after receipt of this notice, the debt will be assumed to be
valid by the Plaintiff and Plaintiff's agents, attorneys and employs.
d. If you notify the Plaintiff's attorney, in writing, within thirty (30) days of
the receipt of this notice, that the debt, or any portion thereof, is disputed,
the Plaintiff will provide you verification of the debt or a copy of evidence
of the debt and, a copy of such certification will be mailed to you by the
Plaintiff.
COUNT I
Elmcroft of Shippenburg v Anna Gettel
NECESSITIES ACT
19. Plaintiff incorporates by reference paragraphs 1 through 18 herein as if set forth in
full.
20. Plaintiff believes and, therefore, avers that at all times relevant to this action,
Leroy Gettel was married to Anna Gettel.
21. Under Pennsylvania Law, 23 Pa. C.S. Section 4102, a spouse is responsible for
the necessities provided for the support and maintenance of the other spouse.
22. On information and belief, Leroy Gettel expired without assets from which to pay
the outstanding balance owed to Plaintiff.
Page 3 of 5
23. Anna Gettel has failed and /or refused to pay for the necessary services provided to
Leroy Gettel by Plaintiff.
24. Plaintiff has been damaged by Anna Gettel's failure to pay for Leroy Gettel's
necessities.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an order
as follows:
(a) Granting judgment for Plaintiff and against Defendant, Anna Gettel, in the
amount of $ 11,304.78;
(b) Requiring Defendant to submit an accounting to Plaintiff of the use and
disposition of all assets of Leroy Gettel;
(c) Granting Plaintiff its expenses, including reasonable attorney fees, incurred in
connection with this action; and,
(d) Granting such other relief as the Court deems appropriate.
COUNT II
Elmeroft of Shippenburg v Anna Gettel
UNJUST ENRICHMENT — QUANTUM MERUIT
25. Plaintiff incorporates by reference paragraphs 1 through 24 herein as if set forth in
full.
26. As more fully described herein, Plaintiff's expectation of payment in exchange for
rendering the necessary services was reasonable.
27. As Leroy Gettel's spouse, Anna Gettel was obligated under the Necessities Act to
provide for Leroy Gettel's necessities.
28. Plaintiff, in rendering the necessary services, has conferred a substantial benefit
upon Anna Gettel, who has been relieved of the obligation of providing Leroy Gettel with
necessary services at Plaintiff's detriment and expense.
29. Plaintiff believes and, therefore, avers that it would be unjust and unreasonable for
Anna Gettel to be permitted to retain the benefits and value of Plaintiff's provision of necessary
services to Leroy Gettel without making restitution to Plaintiff.
Page 4 of 5
30. Anna Gettel wrongfully secured and /or passively received the benefits and value
of Plaintiff's provision of necessary services to Leroy Gettel and, despite repeated demands,
failed and /or refused to make restitution to Plaintiff.
31. Due to the unjust enrichment of Anna Gettel, Plaintiff is entitled to er ro
p p
compensation for the necessary services rendered.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order
as follows.
(a) Granting judgment for Plaintiff and against Defendant, Anna Gettel, in the amount
of $ 11,304.78;
(b) Requiring Defendant to submit an accounting to Plaintiff of the use and
disposition of all assets of Leroy Gettel;
(c) Granting Plaintiff its expenses, including reasonable attorney fees, incurred in
connection with this action; and,
(d) Granting such other relief as the Court deems appropriate.
Date: /201 ''^ C
BRIAN SCOTT DIETRICH, ESQUIRE
DENNIS C. VONDRAN JR., ESQUIRE
Attorneys for Plaintiff
BCC Shippensburg Operations, LLC
d /b /a Elmcroft of Shippensburg
Page 5 of 5
Exhibit A
( f
y J
A Resident Statement
ELMCROFT TM Statement Date 12/21/2012
SENIOR LIVING
Resident Acct # 353500205
Elmcroft of Shippensburq
129 Walnut Bottom Road Statement Number 0401982
Shippensburg, PA 17257
717 - 530 -1400 Resident Gettel, W. Leroy
1 Date Invoice Descriotion Days Price Line Amount
12/21/201 Outstandinq Balance $12.466.51
Current Activity - January 2013 Resident Care Fees & Ancillar
1/1/2013 0401982 LATE FEES $187.00
Balance Due: $12,653.51
For Billing Questions please call: (866)575 -7813
Bill To: Tonya Crouse
42 Parsonage Street
Newville, PA 17241
Your cancelled check is your receipt - Keep this portion for your records
Return this portion with your payment
BCC- SHIPPENSBURG OPERATIONS, LLC Payment Due Date: 1/1/2013
PLAZA.II OFFICE BUILDING, STE 101
9510 ORMSBY STATION RD Amount Due: $12,653.51
LOUISVILLE, KY 40223
Statement Number: 0401982
Resident: Gettel, W. Leroy
,Resident Acct# 353500205
Send Remittance to:
BCC SHIPPENSBURG OPERATIONS, LLC
PLAZA 11 OFFICE BUILDING, STE 101
9510 ORMSBY STATION RD Make Check Payable to: BCC SHIPPENSBURG OPERATIONS
LOUISVILLE, KY 40223
000000000401982403560035002054122120124000126535153
r ( .
Resident Statement
L M F FM
Statement Date 12/14/2012
SENIOR LIVING
Elmcroft of Shippensburq Resident Acct # 353500205
129 Walnut Bottom Road Statement Number 0400342
Shippensburg, PA 17257
717 - 530 -1400 Resident Gettel, W. Leroy
iD
ate Descriotion Days Price Line Amount:
12/14/201 Outstandinq Balance $15.457.15
Current Activity - January 2013 Resident Care Fees & Ancillar
1/1/2013 0400342 AL LEVEL M MONTHLY CARE Dec -24 124.61 ($2.990.64)
Balance Due: $12,466.51
For Billing Questions please call: (866)575 -7813
Bill To: Tonya Crouse
42 Parsonage Street
Newville, PA 17241
Your cancelled check is your receipt - Keep this portion for your records
Return this portion with your payment
BCC SHIPPENSBURG OPERATIONS, LLC Payment Due Date: 111/2013
PLAZA II OFFICE BUILDING, STE 101
9510 ORMSBY STATION RD Amount Due: $12,466.51
LOUISVILLE, KY 40223
Statement Number: 0400342
Resident: Gettel, W. Leroy
Resident Acct# 353500205
Send Remittance to:
BCC SHIPPENSBURG OPERATIONS, LLC
PLAZA II OFFICE BUILDING, STE 101
9510 ORMSBY STATION RD Make Check Payable to: BCC SHIPPENSBURG OPERATIONS
LOUISVILLE, KY 40223
000000000400342203560035002054121420129000124665128
Resident Statement
EL MC l r Statement bate 11/20/2012
SENIOR LIVING
Resident Aect # 353500205
Eimcroft of Shippensburq
129 Walnut Bottom Road Statement Number 0399395
Shippensburg, PA 17257
717- 530 -1400 Resident Gettel, W. Leroy
Date Invoice Descriotion Days Price Line Amount
11/20/201 Outstandinq Balance $13.474.13
Current Activity - December 2012 Resident Care Fees & Ancil
12/1/20120399395 AL LEVEL M MONTHLY CARE SVC 31 124.61 $Y862:
12/1/2012 0399449 LATE FEES - 202.11 $202.11
Balance Due: $17,539.15
For Billing Questions please call: (866)575 -7813
Bill To: Tonya Crouse
42 Parsonage Street
New\ ille, PA 17241
Your cancelled check is your receipt - Keep this portion for your records
Return this portion with your payment
BCC SHIPPENSBURG OPERATIONS, LLC Payment Due Date: 12/1/2012
PLAZA II OFFICE BUILDING, STE 101
9510 ORMSBY STATION RD Amount Due: $17,539.15
LOUISVILLE, KY 40223
Statement Number: 0399395
Resident: Gettel, W. Leroy
Resident Acct# 353500205
Send Remittance to:
BCC SHIPPENSBURG OPERATIONS, LLC
PLAZA II OFFICE BUILDING, STE 101
9510 ORMSBY STATION RD Make Check Payable to: BCC SHIPPENSBURG OPERATIONS
LOUISVILLE, KY 40223
000000000399395303560035002054112020128000175391564
� r
Resident Statement
LM F tai Statement Date 10/22/2012
SENIOR LIVING
Elmcroft of Shippensbum Resident Acct # 353500205
129 Walnut Bottom Road Statement Number 0392831
Shippensburg, PA 17257
717- 530 -1400 Resident Gettel, W. Leroy
Date Invoice Descriotion Days Price Line Amount
10/22/201 Outstandinq Balance $15.242.20
Current Activity - November 2012 Resident Care Fees & Ancil
11/1/2012 0392881 LATE FEES 228.63 $228.63
11/1/2012 0392881 BEAUTY /BARBER FEE 15.00 $15.00
11/1/2012 0392831 AL LEVEL E MONTHLY CARE SVC 30 89.61 $2.688.30
Balance Due: $18,174.13
For Billing Questions please call: (866)575 -7813
Bill To: Tonya Crouse
42 Parsonage Street
Newville, PA 17241
Your cancelled check is your receipt - Keep this portion for your records
Return this portion with your payment
BCC SHIPPENSBURG OPERATIONS, LLC Payment Due Date: 11/1/2012
PLAZA II OFFICE BUILDING, STE 101
9510 ORMSBY STATION RD Amount Due: $18,174.13
LOUISVILLE, KY 40223 Statement Number: 0392831
Resident: Gettel, W. Leroy
Resident Acct# 353500205
Send Remittance to:
BCC SHIPPENSBURG OPERATIONS, LLC
PLAZA II OFFICE BUILDING, STE 101
, KY 40223 Make Check Pa y STATION RD
LOUISVILLE, M able to: BCC SHIPPENSBURG OPERATIONS
LOUI
000000000392831403560035002054102220126000181741369
Resident Statement
F111iii
Statement Date 9/20/2012
Elmcroft of Shippensburg Resident Acct # 353500205
129 Walnut Bottom Road Statement Number 0386402
Shippensburg, PA 17257 Gettel W. Le roy
717- 530 -1400 Resident y
D��Fe invoice Description
Lines Pritce Line Amount
9/20/20 Outstanding Balance $12,280.09
Current Activity - October 2012 Resident Care Fees & Anclll
1011/20 038732 LATE FEES $184.20
10/1/20 038640 AL LEVEL E MONTHLY CARE SVC 31 89 $ 2,777. 9 1
Balance Due: $15,242.20
For Blliing Questions please call: (866)575 -7813
Bill To: Tonya Crouse
42 Parsonage Street
Newville, PA 17241
Your cancelled .h .ck I y AlJr rA J nt -Keel I� his portion for you records
Return this portion with you payment
BCC SHIPPENSBURG OPERATION Payment Due Date; 10/1/2012
PLAZA II OFFICE BUILDING, STE 10
9510 ORMSBY STATION RD
LOUISVILLE, KY40223 Amount Due: $15,242.20
Statement Number: 0386402
Send Remittance to:
BCC SHIPPENSBURG OPERATION
PLAZA 11 OFFICE BUILDING, STE 10
9510 ORMSBY STATION RD
LOUISVILLE, KY 40223
Resident: Gellei, W. Leroy
Resident Acct# 353500205 Make Check Payable to: BCC SHIPPENSBURG OPERATION
000000000386402203560035002054092020122000152422093
Resident Statement
ELM F ".
Statement Date 8/20/2012
SENIOR LIVING
Resident Acct # 353500205
Elmcroft of Shippensburq
129 Walnut Bottom Road Statement Number 0380292
Shippensburg, PA 17257
717 - 530 -1400 Resident Gettel, W. Leroy
Date Invoice Descriotion Days Price Line Amount'
8/20/2012 Outstandinq Balance $9.415.56
Current Activity September 2012 Resident Care Fees & Anci
9/1/2012 0380343 LATE FEES $141.23
911/2012 0380343 TRANSPORTATION FEE 20.00 $20.00
9/1/2012 0380343 BEAUTY /BARBER FEE 15.00 $15.00
9/1/2012 0380292 AL LEVEL E MONTHLY CARE SVC 30 89.61 $2.688.30
Balance Due: $12,280.09
For Billing Questions please call: (866)575 -7813
Bill To: Tonya Crouse
42 Parsonage Street
Newville, PA 17241
Your cancelled check is your receipt - Keep this portion for your records
Return this portion with your payment
BCC SHIPPENSBURG OPERATIONS, LLC Payment Due Date: 9/1/2012
PLAZA II OFFICE BUILDING, STE 101
9510 ORMSBY STATION RD Amount Due: $12,280.09
LOUISVILLE, KY 40223
Statement Number: 0380292
Resident: Gettel, W. Leroy
Resident Acct# 353500205
Send Remittance to:
BCC SHIPPENSBURG OPERATIONS, LLC
PLAZA II OFFICE BUILDING, STE 101
9510 ORMSBY STATION RD Make Check Payable to: BCC SHIPPENSBURG OPERATIONS
LOUISVILLE, KY 40223
000000000380292303560035002054082020124000122800950
f
a Resident Statement
LMR1 Fw Statement Date 7/20/2012
SENIOR LIVING
Elmcroft of Shirmensburq Resident Acct # 353500205
129 Walnut Bottom Road Statement Number 0374371
Shippensburg, PA 17257
717 - 530 -1400 Resident Gettel, W. Leroy
Date Invoice Descriotion Days Price Line Amount
7/20/2012 Outstandinq Balance $6.285.10
Current Activity - Aunust 2012 Resident Care Fees $ Ancillari
8/1/2012 0374371 AL LEVEL E MONTHLY CARE SVC 31 89.61 $2.777.91
8/1/2012 0374424 BEAUTY /BARBER FEE 15.00 $15.00
8/1/2012 0374424 TRANSPORTATION FEE 10.00 $10.00
Balance Due: $9,088.01
For Billing Questions please call: (866)575 -7813
Bill To: Tonya Crouse
42 Parsonage Street
Newville, PA 17241
Your cancelled check is your receipt - Keep this portion for your records
Return this portion with your payment
BCC SHIPPENSBURG OPERATIONS, LLC Payment Due Date: 8/1/2012
PLAZA II OFFICE BUILDING, STE 101
9510 ORMSBY STATION RD Amount Due: $9,088.01
LOUISVILLE, KY 40223
Statement Number: 0374371
Resident: Gettel, W. Leroy
Resident Acct# 353500205
Send Remittance to:
BCC SHIPPENSBURG OPERATIONS, LLC
PLAZA Il OFFICE BUILDING, STE 101
9510 ORMSBY STATION RD Make Check LOUISVILLE, KY 40223 Payable to: BCC SHIPPENSBURG OPERATIONS
000000000374371303560035002054072020126000090880148
Resident Statement
EMCF M Statement Date 6/20/2012
SENIOR LIVING
Elmcroft of Shippensburg Resident Acct # 353500205
129 Walnut Bottom Road❑ Statement Number 0369310
Shippensburg, PA 17257
717 - 530 -1400 Resident Gettel, W. Leroy
Date Invoice Description DaVs Price Line Arnounf;
6/20/2012 Outstandinq Balance $5,462.19
Current Activitv - July 2012 Resident Care Fees & Ancillaries
7/1/2012 0369365 TRANSPORTATION FEE 30.00 $30.00
7/1/2012 0369365 BEAUTY /BARBER FEE 15.00 $15.00
7/1/2012 0369310 AL LEVEL E MONTHLY CARE SVC 31 89.61 $2,777.91
Balance Due: $8,285.10
For Billing Questions please call: (866)575 -7813
Bill To: Tonya Crouse
42 Parsonage Street
Newville, PA 17241
Your cancelled check is your receipt - Keep this portion for your records
Return this portion with your payment
BCC SHIPPENSBURG OPERATIONS, LLC Payment Due Date: 7/1/2012
PLAZA II OFFICE BUILDING, STE 101
9510 ORMSBY STATION RD Amount Due: $8,285.10
LOUISVILLE, KY 40223
Statement Number: 0369310
Resident: Gettel, W. Leroy
Resident Acct# 353500205
Send Remittance to:
BCC SHIPPENSBURG OPERATIONS, LLC
PLAZA II OFFICE BUILDING, STE 101
, KY 40223 y STATION RD
LOUISVILLE, Make Check Payable to: BCC SHIPPENSBURG OPERATIONS
LOU
000000000369310803560035002054062020128000082851084
Resident Statement
MRFT
Statement Date 5/21 /2012
E W O R LIVING
Elmcroft of Shippensburg Resident Acct # 353500205
129 Walnut Bottom Roado Statement Number 0364951
Shippensburg, PA 17257
717 - 530 -1400 Resident Gettel, W. Leroy
I Date Invoice Description DaVs Price Line Amount:
5/21/2012 Outstanding Balance $5,819.15
Current Activitv - June 2012 Resident Care Fees & Ancillaries
6/1/2012 0365003 TRANSPORTATION FEE 60.00 $60.00
6/1/2012 0365003 BEAUTY /BARBER FEE 15.00 $15.00
6/1/2012 0365003 Cable 20.00 $20.00
6/1/2012 0364951 AL LEVEL E MONTHLY CARE SVC .30 89.61 $2,688.30
6/1/2012 0367467 LATE FEES $87.29
Balance Due: $8,689.74
For Billing Questions please call: (866)575 -7813
Bill To: Tonya Crouse
42 Parsonage Street
Newville, PA 17241
Your cancelled check is your receipt - Keep this portion for your records
Return this portion with your payment
BCC SHIPPENSBURG OPERATIONS, LLC Payment Due Date: 6/112012
PLAZA II OFFICE BUILDING, STE 101
9510 ORMSBY STATION RD Amount Due: $8,689.74
LOUISVILLE, KY 40223
Statement Number: 0364951
Resident: Gettel, W. Leroy
Resident Acct# 353500205
Send Remittance to:
BCC SHIPPENSBURG OPERATIONS, LLC
PLAZA II OFFICE BUILDING, STE 101
9510 LOUISVILLE, STATION RD Make Check Payable to: BCC SHIPPENSBURG OPERATIONS
LOUISVILLE, KY 40223 y .
000000000364951403560035002054052120128000086897475
mill Resident Statement
i Statement Date 4/19/2012
Elmcroft of Shippensburg Resident Acct # 353500205
129 Walnut Bottom Roac Statement Number 0356424
Shippensburg, PA 17257
717 - 530 -1400 Resident Geltei, W. Leroy
Date Invoice Description Lines Price
4/19/20 Outstandlna Balance $5,621.91
Current Activity - May 2012 Resident Care Fees & Ancillarie
5/11201 035853 LATE FEES $84.33
5/1/201 035642 AL LEVEL E MONTHLY CARE SVC 31 89.61 $2,777.91
5/1/201 035647 Cable 20.00 $20.00
5/1 035647 BEAUTY / FEE 15.00 $15.00
8allance Due: $8,519.15
For Billing Questions please call. (866)575.7813
Bill To: Tonya Crouse
42 Parsonage Street
Newuiile, PA 17241
Your cancelled check Is your receipt - K this portion for y ou records
Return thls portion with you payment
BCC SHIPPENSBURG OPERATION Payment Due Date: 5/1/2012
PLAZA 11 OFFICE BUILDING, STE 10
9510 ORMSBY STATION RD Amount Due: $8,519.15
LOUISVILLE, KY40223
Statement Number: 0356424
Send Remittance to:
BCC SHIPPENSBURG OPERATION
PLAZA II OFFICE BUILDING, STE 10
9510 ORMSBY STATION RD
LOUISVILLE, KY40223
Resident: Gettel, W. Leroy
Resident Acct# 353500205 Make Check Payable to; BCC SHIPPENSBURG OPERATION
000000000356424203560035002054041920125000085191598
� t
Resident Statement
LMCRFT -M Statement Date 3/20/2012
SEN[O'R LIVING
Elmcroft of Shippensburg Resident Acct # 353500205
129 Walnut Bottom Roado Statement Number 0353545
Shippensburg,_PA 17257 ,
717 - 530 -1400 Resident Gettel, W. Leroy
Date Invoice Description Days Price Line Amount
3/20/2012 Outstanding Balance $2,933.61
Current Activitv - April 2012 Resident Care Fees & Ancillaries
4/1/2012 0353545 AL LEVEL E MONTHLY CARE SVC 30 89.61 $2,688.30
Balance Due: $5,621.91
For Billing Questions please call: (866)575 -7813
Bill To: Tonya Crouse
42 Parsonage Street
Newville, PA 17241
Your cancelled check is your receipt - Keep this portion for your records
Return this portion with your payment
BCC SHIPPENSBURG OPERATIONS, LLC Payment Due Date: 4/1/2012
PLAZA II OFFICE BUILDING, STE 101
9510 ORMSBY STATION RD Amount Due: $5 ,621.91
LOUISVILLE, KY 40223
Statement Number: 0353545
Resident: Gettel, W. Leroy
Resident Acct# 353500205
Send Remittance to:
BCC SHIPPENSBURG OPERATIONS, LLC
PLAZA 11 OFFICE BUILDING, STE 101
9510 ORMSBY STATION RD Make Check Payable to: BCC SHIPPENSBURG OPERATIONS
LOUISVILLE, KY 40223
0000004003535457 035600350020540320201250000562191 70
Resident Statement
Statement Date 2/21/2012
Elmcroft of Shippensburg Resident Acct # 353500205
129 Walnut Bottom Road❑ Statement Number 0348320
Shippensburg, PA 17257
717 - 530 -1400 Resident Gettel, W. Leroy
Date Invoice Description Days Price Line Amount
2/21/2012 Outstandinq Balance $5,409.60
Current Activitv - March 2012 Resident Care Fees & Ancillari
3/1/2012 0348320 AL LEVEL E MONTHLY CARE SVC 31 89.61 $ 2,777.91
Balance Due: $8,187.51
,For Billing Questions please call: (866)575 -7813
Bill To: Tonya Crouse
42 Parsonage Street
Newville, PA 17241
l
Your cancelled check is your receipt - Keep this portion for your records
Return this portion with your payment
BCC SHIPPENSBURG OPERATIONS, LLC Payment Due Date: 3/1/2012
PLAZA II OFFICE BUILDING, STE 101
9510 ORMSBY STATION RD Amount Due: $8,187.51
LOUISVILLE, KY 40223
Statement Number: 0348320
Resident: Gettel, W. Leroy
Resident Acct# 353500205
Send Remittance to:
BCC SHIPPENSBURG OPERATIONS, LLC
PLAZA II OFFICE BUILDING, STE 101
9510 ORMSBY STATION RD Make Check Payable to: BCC SHIPPENSBURG OPERATIONS
LOUISVILLE, KY 40223 y
t
000000000348320303560035002054022120125000081875103
{ (
Resident Statement
Statement Date 1/20/2012
Elmcroft of Shippensburg Resident Acct # 353500205
129 Walnut Bottom Road Statement Number 0344445
Shippensburg, PA 17257
717 - 530 -1400 Resident Gettel, W. Leroy
Date Invoice Description Days Price Line Amount
1/2012012 Outstanding Balance $5,492.91
1/20/2012 0331089 Payment - Thank You ($2,697.00)
Current Activity - February 2012 Resident Care Fees & Ancill
2/1/2012 0344445 AL LEVEL E MONTHLY CARE SVC 29 89.61 $2,598.69
2/1/2012 0344502 BEAUTY /BARBER FEE 15.00 $
Balance Due: $5,409.60
For Billing Questions please call: (866)575 -7813
t
Bill To: Tonya Crouse
42 Parsonage Street
Newville, PA 17241
Your cancelled check is your receipt - Keep this portion for your records
Return this portion with your payment
BCC SHIPPENSBURG OPERATIONS, LLC Payment Due Date: 2/112012
PLAZA II OFFICE BUILDING, STE 101
9510 ORMSBY STATION RD Amount Due: $5,409.60
LOUISVILLE, KY 40223
Statement Number: 0344445
Resident: Gettel, W. Leroy
Resident Acct# 353500205
Send Remittance to:
i BCC SHIPPENSBURG OPERATIONS, LLC
PLAZA II OFFICE BUILDING, STE 101
, KY 40223 Y STATION RD
LOUISVILLE, Make Check Payable to: BCC SHIPPENSBURG OPERATION
LOUI
- Resident Statement
I Statement Date 12/20/2011
Elmcroft of Shippensburg Resident Acct # 353500205
129 Walnut Bottom Road❑ Statement Number 0336394
Shippensburg, PA 17257
717- 530 -1400 Resident Gettel, W. Leroy
Date Invoice Description DaVs Price Line Amount
12/20/201 Outstandinq Balance $2,697.00
Current Activitv - January 2012 Resident Care Fees & Ancilla
1/1/2012 0336451 ADDITIONAL MEALS FEE 8.00 $8.00
1/1/2012 0336451 TRANSPORTATION FEE 10.00 $10.00
1/1/2012 0336394 AL LEVEL E MONTHLY CARE SVC 31 89.61 $2,777.91
Balance Due: $5,492.91
For Billing Questions please call: (866)575 -7813
1
Bill To: Tonya Crouse
42 Parsonage Street
Newville, PA 17241
Your cancelled check is your receipt - Keep this portion for your records
Return this portion with your payment
BCC SHIPPENSBURG OPERATIONS, LLC Payment Due Date: 1/1/2012
PLAZA II OFFICE BUILDING, STE 101
9510 ORMSBY STATION RD Amount Due: $5,492.91
LOUISVILLE, KY 40223
Statement Number: 0336394
Resident: Gettel, W. Leroy
Resident Acct# 353500205
Send Remittance to:
I BCC SHIPPENSBURG OPERATIONS, LLC
PLAZA II OFFICE BUILDING, STE 101
9510 ORMSBY STATION RD
LOUISVILLE, KY 40223 Make Check Pa Y able to: BCC SHIPPENSBURG OPERATION
LOUI
Resident Statement
l
w. W
Statement Date 11/21/2011
Elmcroft of Shippensburg Resident Acct # 353500205
129 Walnut Bottom Roadn Statement Number 0331089
Shippensburg, PA 17257
717 - 530 -1400 Resident Gettel, W. Leroy
Date Invoice Description DaVs Price U - ne - Arnount
11/21/201 Outstandinq Balance $0.00
Current Activitv - December 2011 Resident Care Fees & Ancil
12/1/2011 0331089 AL LEVEL E MONTHLY CARE SVC 31 87.00 $2,697.00
Balance Due: $2,697.00
For Billing Questions please call: (866)575 -7813
{
Bill To: Tonya Crouse
42 Parsonage Street
Newville, PA 17241
Your cancelled check is your receipt - Keep this portion for your records
Return this portion with your payment
BCC SHIPPENSBURG OPERATIONS, LLC Payment Due Date: 12/1/2011
PLAZA II OFFICE BUILDING, STE 101
9510 ORMSBY STATION RD Amount Due: $2,697.00
LOUISVILLE, KY 40223
Statement Number: 0331089
Resident: Gettel, W. Leroy
Resident Acct# 353500205
Send Remittance to:
I BCC SHIPPENSBURG OPERATIONS, LLC
PLAZA II OFFICE BUILDING, STE 101
, KY 40223 Y STATION RD
LOUISVILLE, Make Check Payable to: BCC SHIPPENSBURG OPERATIONS
LOUI
Resident Statement
a Statement Date 10/20/2011
Elmcroft of Shippensburg Resident Acct # 353500205
129 Walnut Bottom Road❑ Statement Number 0326932
Shippensburg, PA 17257
717 -530 -1400 Resident Gettel, W. Leroy
Days Price Line Am
Date Invoice Description ount
10/20/201 Outstanding Balance $0.00
Current Activitv - November 2011 Resident Care Fees & Ancil
11/1/2011 0326985 BEAUTY /BARBER FEE 13.00 $13.00
11/1/2011 0326932 AL LEVEL E MONTHLY CARE SVC 30 87.00 $2,610.00
Balance Due: $2,623.00
For Billing Questions please call: (866)575 -7813
Bill To: Tonya Crouse
42 Parsonage Street
Newville, PA 17241
Your cancelled check is your receipt - Keep this portion for your records
Return this portion with your payment
BCC SHIPPENSBURG OPERATIONS, LLC Payment Due Date: 11/1/2011
PLAZA II OFFICE BUILDING, STE 101
9510 ORMSBY STATION RD Amount Due: $2,623.00
LOUISVILLE, KY 40223
Statement Number: 0326932
Resident: Gettel, W. Leroy
Resident Acct# 353500205
Send Remittance to:
( BCC SHIPPENSBURG OPERATIONS, LLC
PLAZA II OFFICE BUILDING, STE 101
, KY 40223 STATION RD
LOUISVILLE, Make Check Payable to: BCC SHIPPENSBURG OPERATIONS
LOUI
f
Resident Statement
i Statement Date 9/20/2011
Elmcroft of Shippensburg Resident Acct # 353500205
129 Walnut Bottom Road[] Statement Number 0322203
Shippensburg, PA 17257
717 -530 -1400 Resident Gettel, W. Leroy
Date Invoice Description Days Price Line Amo
9/20/2011 PP1 Prepayment for Resident Care Fees & Ancillaries ($1,250.00)
Current Activity - October 2011 Resident Care Fees & Ancilla
10/1!2011 0322204 AL LEVEL E MONTHLY CARE SVC 31 87,00 $2,697.00
10/1/2011 0322203 New Resident Fee $1,250.00
10/1/2011 0322203 AL LEVEL E MONTHLY CARE SVC 25 87.00 $ 2,175.00
Balance Due: $4,872.00
For Billing Questions please call: (866)575 -7813
(
Bill To: Tonya Crouse
42 Parsonage Street
Newville, PA 17241
Your cancelled check is your receipt - Keep this portion for your records
Return this portion with your payment
BCC SHIPPENSBURG OPERATIONS, LLC Payment Due Date: 10/1/2011
PLAZA II OFFICE BUILDING, STE 101
9510 ORMSBY STATION RD Amount Due: $4,872.00
LOUISVILLE, KY 40223
Statement Number: '0322203
Resident: Gettel, W. Leroy
Resident Acct# 353500205
Send Remittance to:
BCC SHIPPENSBURG OPERATIONS, LLC
PLAZA II OFFICE BUILDING, STE 101
9510 ORMSBY STATION RD Make Check Payable to: BCC SHIPPENSBURG OPERATIONS
LOUISVILLE, KY 40223
LAW OFFICE OF BRIAN SCOTT DIETRICH, P.C.
BRIAN SCOTT DIETRICH, ESQUIRE ATTORNEYS FOR PLAINTIFF
Attorney I.D. # 57174 BCC Shippensburg Operations, LLC
DENNIS C. VONDRAN JR., ESQUIRE d/b /a Elmcroft of Shippensburg
Attorney I.D. # 306396
P.O. Box 1627
Blue Bell, Pennsylvania 19422 -0450
[T] (610) 629 -6300
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION — LAW
BCC Shippensburg Operations, LLC
d/b /a Elmcroft of Shippensburg No.
129 Walnut Bottom Road ,
Shippensburg, PA 17257
V . .
Anna Gettel a/k/a A. Gettel ARBITRATION CASE
a/k/a Anna Grace Gettel ,
474 East King Street .
Shippensburg, PA 17257
VERIFICATION
I, -�" a� '1 , a representative of Elmcroft of Shippensburg, hereby state I am
authorized to execute this Verification on behalf of the Plaintiff above named, and the statements
made in the foregoing Complaint are true and correct to the best of my knowledge, information and
belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S.
Section 4904, relating to unworn falsification to authorities.
Date: /2013
Representative of
Elmcroft of Shippensburg
Plaintiff
Page 1 of 1
LAW OFFICE OF BRIAN SCOTT DIETRICH, P.C.
BRIAN SCOTT DIETRICH, ESQUIRE ATTORNEYS FOR PLAINTIFF
Attorney I.D. # 57174 BCC Shippensburg Operations, LLC
DENNIS C. VONDRAN JR., ESQUIRE d/b/a Elmcroft of Shippensburg
Attorney I.D. # 306396
P.O. Box 1627
Blue Bell, Pennsylvania 19422-0450
[T] (610) 629-6300
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL ACTION-- LAW
BCC Shippensburg Operations, LLC .
d/b/a Elmcroft of Shippensburg No. 14-339
v. .
Anna Gettel a/k/a A. Gettel ARBITRATION CASE
a/k/a Anna Grace Gettel c) r,a -°
PRAECIPE TO REINSTATE COMPLAINT = r?
HI
(i)r- 1\) �a ;
:
TO THE PROTHONOTARY: v -,y
Kindly reinstate the Complaint in the above-captioned matter.
»,. " f
Respectfully Submitted,
LAW 0 FICES OF BRIAN SCOTT DIETRICH,P.C.
' C 1/1-2/1
Date: 02/07/2014
DENNIS C. VONDRAN, JR., ESQUIRE
Attorney for Plaintiff
%,\.--,,, (166
'2 .-t9 9
Page 1 of 1 144 I 9
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff i `_', ' ` '
Jody S Smith
Chief Deputy '014 FEB 25 PH 3: C.. :,
Richard W Stewart
Solicitor °`,UMBERLA O COUNTY
PENNSYLVANIA
BBC Shippensburg Operation, LLC d/b/a elcroft of Shippensburg Case Number
vs.
Anna Gettel 2014-339
SHERIFF'S RETURN OF SERVICE
02/19/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Anna Gettel, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Complaint& Notice as"Not Served"at 474
East King Street, Shippensburg Borough, Shipppensburg, PA 17257. Eight attempts at service were
made but deputies were unable to make contact with anyone at the residence and the Complaint has
since expired.
SHERIFF COST: $95.80 SO ANSWERS,
February 19, 2014 RON■Y R ANDERSON, SHERIFF
LAW OFFICE OF BRIAN SCOTT DIETRICH, P.C.
BRIAN SCOTT DIETRICH, ESQUIRE
Attorney I.D. # 57174
DENNIS C. VONDRAN JR., ESQUIRE
Attorney I.D. # 306396
610 Sentry Parkway, Suite 200
Blue Bell, Pennsylvania 19422 -0450
[T] (610) 629 -6300
ATTORNEYS FOR PLAINTIFF
BCC Shippensburg Operations, LLC
d /b /a Elmcroft of Shippensburg
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYIN1A4
CIVIL ACTION -- LAW 'ice' }
q-' 1 C ,
cs• - t
BCC Shippensburg Operations, LLC •
d /b /a Elmcroft of Shippensburg No. 14 -339 `=
. z C 4fir
V.
ARBITRATION CASE
Anna Gettel a /k/a A. Gettel
a /k/a Anna Grace Gettel
r art
PLAINTIFF'S MOTION FOR SPECIAL ORDER DIRECTING SERVICE
BY MAIL UPON DEFENDANT, ANNA GETTEL, A/K/A A. GETTEL
A/K/A ANNA GRACE GETTEL
Plaintiff, BCC Shippensburg Operations, LLC d /b /a Elmcroft of Shippensburg, by its
undersigned attorney and pursuant to Pa. R.C.P. No. 430(a), moves this Court for an Order
permitting special service of the Complaint in this action upon defendant, Anna Gettel a/k/a A.
Gettel a/k /a Anna Grace Gettel (hereinafter referred to as "Anna Gettel "), by United States First
Class Mail. In support of this motion, Plaintiff avers the following:
1. The instant action concerns Anna Gettel failure and /or refusal to pay for necessary
services provided by Plaintiff to the late Leroy Gettel.
2. The last known address for the Defendant, Anna Gettel, is 474 East King Street,
Shippensburg, PA 17257;
3. Attempts have been made to serve the complaint in this action at the 474 East King
Street, Shippensburg, PA 17257 address under the regular procedures set forth in Pennsylvania Rules
of Civil Procedures. All efforts have been unsuccessful. A true and correct copy of the Cumberland
County Sheriff's Return of Service Form is attached hereto and made a part hereof and marked
Exhibit A.
Page 1 of 2
4. According to the Postmaster, Shippensburg, Pennsylvania office, there is no change
of address order on file for Anna Gettel at 474 East King Street, Shippensburg, PA 17257. A true
and correct copy of the Request for Change of Address is attached hereto and made a part hereof
and marked Exhibit B.
5. To the best of Plaintiffs knowledge, information and belief, the residence address of
474 East King Street, Shippensburg, PA 17257 is the only known address of Defendant, Anna Gettel.
6. Plaintiff has made a good faith effort to locate and serve Defendant, Anna Gettel, but
has been unsuccessful because the process server is unable to locate the Defendant, Anna Gettel.
7. Plaintiff believes that service by regular United States First Class mail is the only
reasonable method to serve the defendant, Anna Gettel, with process in this action.
8. Unless the Court allows service by regular United States First Class mail, Plaintiff
will be unable to maintain this action and injustice will result.
WHEREFORE, the Plaintiff requests the Court enter a special order directing service of the
complaint upon Defendant, Anna Gettel, by regular United States First Class Mail.
Date: 03/03/2014
DENNIS C. VONDRAN, JR.
Attorney for Plaintiff
Page 2 of 2
EXHIBIT A
Anderson
S Smith
f Deputy
and W Stewart
itor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
vsm of EnrraL'ct744
OFFtCF, OF THE $kmRIFF
BC Shippensburg Operation, LLC d /b /a elcroft of Shippensburg
vs.
nna Gettel
Case Number
2014 -339
SHERIFF'S RETURN OF SERVICE
'19/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Anna Gettel, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Served" at 474
East King Street, Shippensburg Borough, Shipppensburg, PA 17257. Eight attempts at service were
made but deputies were unable to make contact with anyone at the residence and the Complaint has
since expired.
IERIFF COST: $95.80 SO ANSWERS,
:bruary 19, 2014
(c) CountySulte Sheriff, Teleosoft. Inc.
RONNY R ANDERSON, SHERIFF
EXHIBIT B
LAW C FICE OF BRIAN SCOTT 1 - TRICH
A PROFGSS!ONAL CORPORATION
Brian Scott Dietrich
Regina B. Diamond •
Dennis C. Vondran, Jr.
350 Sentry Parkway East
610 Sentry Parkway, Suite 200
Blue Bell, PA 19422 -2314
Telephone (610) 629 -6300
Facsimile (610) 629 -6301
of Counsel
Michael F. Wenke
Date January 25, 2013
CM- 11633.001
Postmaster
Shippensburg PA 17257
V IIIIIIIIIIIIIIIIIIIIIIIIIIIIII
REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER
INFORMATION NEEDED FOR SERVICE OF LEGAL PROCESS
Please furnish the new address or the name and street address (if a boxholder) for the following:
Name: Anna Grace Gettel
Address: 474 East King Street Shippensburg PA 17257
NOTE: The name and last known address are required for change of address information. The name, if known, and
post office box address are required for boxholder information.
The following information is provided in accordance with 39 CFR 265,6(d) (6) (ii). There is no fee for providing
boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR
265.6(d) (1) and (2) and corresponding Administrative Support Manual 352.44a and b.
1. Capacity of requester (e.g., process server, attorney, party representing himself) Attorney
2. Statute or regulation that empowers me to serve process (not required when requester, is.an attorney or a
party acting pro se - except a corporation acting pro se must cite statute:
3. The names of all known parties to the litigation: Elmcroft of Shippensburg vs. Anna Grace Gettel
4. The court in which the case has been or will be heard: Cumberland County
5. The docket or other identifying number if one has been issued:
6. The capacity in which this individual is to be served (e.g. defendant or witness): Defendant
WARNING
THE SUBMISSION OF FALSE INFORMATION EITHER (1) TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR
BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL
OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT
OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OR NOT MORE THAN 5 YEARS, OR BOTH
(TITLE 18 U.S.C. SECTION 1001).
I certify that the above information is true and that the address information is needed and will be used solely for
sery of legal process in connection with actual or prospective litigation.
LVA
Signature
DENNIS C. VONDRAN, JR., ESQUIRE
Printed Name
Law Office of Brian Scott Dietrich, P.C.
Post Office 1627
Blue Bell, PA 19422 -0450
�,rGr1:,a1.JA.h.
FOR POST, OFFICE USE ONLY -
MUST AFFIX POST OFFICE SEAL AND PROVIDE SIGNATURE F,d1 COURT
No change of address order on file. l'NEW ADDRESS or BOXHOLDEk'S P,� r
Mail delivered as addressed. NAME and STREET ADDRESS:
Person known at address.
Mail is delivered at address given.
Not known at address given.
Moved, left no forwarding address.
_Months Ago / /
No such address.
Property Vacant
LAW OFFICE OF BRIAN SCOTT DIETRICH, P.C.
BRIAN SCOTT DIETRICH, ESQUIRE
Attorney I.D. # 57174
DENNIS C. VONDRAN JR., ESQUIRE
Attorney I.D. # 306396
610 Sentry Parkway, Suite 200
Blue Bell, Pennsylvania 19422 -0450
[T] (610) 629 -6300
ATTORNEYS FOR PLAINTIFF
BCC Shippensburg Operations, LLC
d/b /a Elmcroft of Shippensburg
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -- LAW
BCC Shippensburg Operations, LLC
d /b /a Elmcroft of Shippensburg
v.
No. 14 -339
Anna Gettel a /k/a A. Gettel ARBITRATION CASE
a /k/a Anna Grace Gettel
AFFIDAVIT IN SUPPORT OF PLAINTIFF'S MOTION FOR SPECIAL SERVICE
I, DENNIS C. VONCRAN, JR., ESQUIRE, being duly sworn according to law, depose
and say the following:
1. I am the Plaintiffs attorney in the above action.
2. At my direction, an investigation was conducted into the whereabouts of the
Defendant, Anna Gettel a/k/a A. Gettel a/k/a Anna Grace Gettel (hereinafter referred to as "Anna
Gettel "). The efforts to locate the Defendant, Arma Gettel, included the following:
A. Attempts have been made by the Cumberland County Sheriff to serve the
complaint in this action at 474 East King Street, Shippensburg, PA 17257
under the regular procedures set forth in Pennsylvania Rules . of Civil
Procedures. All efforts have been unsuccessful. See Exhibit A.
B. Plaintiff confirmed with the Postmaster, Shippensburg, Pennsylvania office,
that there is no change of address order on file for Anna Gettel at 474 East
King Street, Shippensburg, PA 17257. See Exhibit B.
Page 1 of 2
3. The stated address 474 East King Street, Shippensburg, PA 17257 is only known
address to the best of my knowledge, information and belief.
4. As set forth in the attached Exhibit A, efforts to date to serve defendant Anna Gettel,
at this address have not been successful.
5. The allegations in the foregoing Motion for Special Order and the attached Exhibits
are true and correct to the best of my knowledge, information and belief.
Date: 03/03/2014
Sworn to and subscribed to before me
this (3 day of /174r�( , 2014.
4.—// 4.13:tiffu.-1-
otary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Jessica L. Bartholomew, Notary Public
Whltpaln Twp., Montgomery County
M .commission Expires Dec. 4 2016
Mr1 b , P NNSYLVAN%Msoc ATi N OF NCJTAMES
V'
DENNIS C. VONDRAN, JR.
Attorney for Plaintiff
Page 2 of 2
EXHIBIT A
iAnderson
ly S Smith
ef Deputy
hard W Stewart
'citor OFFICE OF THE MERIFF
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
BC Shippensburg Operation, LLCd/b/asdonoftofShippenoburg
vs.
nna Gette
Case Number
2014-339
SHERIFF'S RETURN OF SERVICE
19/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Anna Gettel, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Served" at 474
East King Street, Shippensburg Borough, Shipppensburg, PA 17257. Eight attempts at service were
made but deputies were unable ho make contact with anyone at the residence and the Complaint has
since expired.
ERIFF COST: $95.80 SO ANSWERS,
-uary 19, 2014 RONR R ANDERSON, SHERIFF
EXHIBIT B
LAW CE OF BRIAN SCOTT F----A'TRICH
A PROPIISIONAL CORPORATION
Brian Scott Dietrich
Regina B. Diamond •
Dennis C. Vondran, Jr.
350 Sentry Parkway East
610 Sentry Parkway, Suite 200
Blue Bell, PA 19422-2314
Telephone (610) 629-6300
Facsimile (610) 629-6301
of Counsel
Michael F. Wenke
Date January 25, 2013
CM-11633.001
Postmaster
Shippensburg PA 17257
11111illiiiiiiiiiii1111111111111
REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER
INFORMATION NEEDED FOR SERVICE OF LEGAL PROCESS
Please furnish the new address or the name and street address (if a boxholder) for the following:
Name: Anna Grace Gettel
Address: 474 East King Street Shippensburg PA 17257
NOTE: The name and last known address are required for change of address information. The name, if known, and
post office box address are required for boxholder information.
The following information is provided in accordance with 39 CFR 265.6(d) (6) (ii). There is no fee for providing
boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR
265.6(d) (1) and (2) and corresponding Administrative Support Manual 352.44a and b.
1. Capacity of requester (e.g., process server, attorney, party representing himself) Attorney
2. Statute or regulation that empowers me to serve process (not required when requester, is, an attorney or a
party acting pro se - except a corporation acting pro se must cite statute:
3. The names of all known parties to the litigation: Elmcroft of Shippensburg vs. Anna Grace Gettel
4. The court in which the case has been or will be heard: Cumberland County
5. The docket or other identifying number if one has been issued:
6. The capacity in which this individual is to be served (e.g. defendant or witness): Defendant
WARNING
THE SUBMISSION OF FALSE INFORMATION EITHER (1) TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR
BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL
OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT
OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OR NOT MORE THAN 5 YEARS, OR BOTH
(TITLE 18 U.S.C. SECTION 1001).
1 certify that the above information is true and that the address information is needed and will be used solely for
serv)E of legal process in connection with actual or prospective litigation.
UlA
Si nature
DENNIS C. VONDRAN, JR., ESQUIRE
Printed Name
Law Office of Brian Scott Dietrich, P.C.
Post Office 1627
Blue Bell, PA .19422-0450
FOR POST OFFICE USE ONLY -
MUST AFFIX POST OFFICE SEAL AND PROVIDE SIGNATURE F
No change of address order on file.
!,./NEW ADDRESS or BOXHOLDER'S P1-MARX
Mail delivered as addressed. NAME and STREET ADDRESS: i klY U
Person known at address. t
Mail is delivered at address given.
Not known at address given.
Moved, left no forwarding address.
Months Ago / / ....
No such 'ardress.
Property Vacant
LAW OFFICE OF BRIAN SCOTT DIETRICH, P.C.
BRIAN SCOTT DIETRICH, ESQUIRE
Attorney I.D. # 57174
DENNIS C. VONDRAN JR., ESQUIRE
Attorney I.D. # 306396
610 Sentry Parkway, Suite 200
Blue Bell, Pennsylvania 19422 -0450
[T) (610) 629 -6300
ATTORNEYS FOR PLAINTIFF
BCC Shippensburg Operations, LLC
d /b /a Elmcroft of Shippensburg
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -- LAW
BCC Shippensburg Operations, LLC
d /b /a Elmcroft of Shippensburg
v.
No. 14 -339
Anna Gettel a /k/a A. Gettel ARBITRATION CASE
a /k/a Anna Grace Gettel
CERTIFICATE OF SERVICE
I, the undersigned, attorney for Plaintiff, BCC Shippensburg Operations, LLC d/b /a Elmcroft
of Shippensburg, hereby certify that a true and correct copy of Plaintiff's Motion for Special Order
Directing Service by Mail Upon Defendant, Anna Gettel was served upon the following:
Date: 03/03/2014
Anna Gettel
474 East King Street
Shippensburg, PA 17257
C (1M
D NNIS C. VONDRAN, JR.
Attorney for Plaintiff
Page 1 of 1
LAW OFFICE OF BRIAN SCOTT DIETRICH, P.C.
BRIAN SCOTT DIETRICH, ESQUIRE
Attorney I.D. # 57174
DENNIS C. VONDRAN JR., ESQUIRE
Attorney I.D. # 306396
610 Sentry Parkway, Suite 200
Blue Bell, Pennsylvania 19422-0450
[T] (610) 629-6300
ATTORNEYS FOR PLAINTIFF
BCC Shippensburg Operations, LLC
d/b/a Elmcroft of Shippensburg
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -- LAW
BCC Shippensburg Operations, LLC
d/b/a Elmcroft of Shippensburg No. 14-339
v.
Anna Gettel a/k/a A. Gettel ARBITRATION CASE
a/k/a Anna Grace Gettel
ORDER
AND NOW, this /7.-day of "7...r...4 , 2014, upon consideration of the
Plaintiff's Motion for Special Order Directing Service By Mail upon Defendant, Anna Grace Gettel,
pursuant to Pa. R. Civ. P. 430(a), and it appearing to the Court that the Plaintiff has made a good
faith effort to locate and serve the defendant in the regular course, it is hereby ORDERED that the
motion is granted, and service upon defendant Anna Grace Gettel, is to be made by United States
First Class Mail.
BY THE COURT
(7)
LAW OFFICE OF BRIAN SCOTT DIETRICH, P.C.
BRIAN SCOTT DIETRICH, ESQUIRE
Attorney I.D. # 57174
DENNIS C. VONDRAN JR., ESQUIRE
Attorney I.D. # 306396
610 Sentry Parkway, Suite 200
Blue Bell, Pennsylvania 19422 -0450
[T] (610) 629 -6300
ATTORNEYS FOR PLAINTIFF
BCC Shippensburg Operations, LLC
d /b /a Elmcroft of Shippensburg
r-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNS A ANAA
CIVIL ACTION -- LAW ry
BCC Shippensburg Operations, LLC
d /b /a Elmcroft of Shippensburg
v.
Anna Gettel a /k/a A. Gettel
a /k/a Anna Grace Gettel
No. 14 -339
ARBITRATION CASE
cp
CERTIFICATE OF SERVICE
I, the undersigned, attorney for Plaintiff, BCC Shippensburg Operations, LLC d/b /a
Elmcroft of Shippensburg, hereby certify that a true and correct copy of the Civil Complaint upon
Defendant, Anna Gettel a/k/a A. Gettel a/k/a Anna Grace Gettel was served via United States
First Class Mail, upon the following:
DATE: 3 / `f /2014
Anna Gettel
474 East King Street
Shippensburg, Pa 17257
BRIAN SCOTT DIETRICH, ESQUIRE
DENNIS C. VONDRAN JR., ESQUIRE
Attorneys for Plaintiff
Page 1 of 1
LAW OFFICE OF BRIAN SCOTT DIETRICH, P.C.
BRIAN SCOTT DIETRICH, ESQUIRE ATTORNEYS FOR PLAINTIFF
Attorney I.D. # 57174 BCC Shippensburg Operations, LLC
DENNIS C. VONDRAN JR., ESQUIRE d/b/a Elmcroft of Shippensburg
Attorney I.D. # 306396
610 Sentry Parkway, Suite 200
Blue Bell, Pennsylvania 19422-0450
[T] (610) 629-6300
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL ACTION--LAW r
BCC Shippensburg Operations, LLC
d/b/a Elmcroft of Shippensburg No. 14-339
V.
F:E,
Anna Gettel a/k/a A. Gettel ARBITRATION CAS ry' f
a/k/a Anna Grace Gettel
y C-7
PRAECIPE FOR JUDGMENT
Enter Judgment in favor of plaintiff and against defendant, Anna Gettel a/k/a A.Gettel`a/k/e�knna.
Grace Gettel of an Answer. r= wy
Principal $ 12,653.51 `
Costs $ 349.37
TOTAL ........................................................ $ 13,002.88 .
I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED
AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM
CERTAIN FROM THE COMPLAINT.
I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party
against whom judgment is to be entered and to his attorney of record, if any, after the default
occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is
attached. Pa.R.C.P. 237.1
Date: /2014
DENNIS C. VONDRAN, JR.
Attorney for Plaintiff S�
oLq
Ck�� 3s�s g
Page 1 of 2
This day of t A l , 2014, judgment is entered in favor of
plaintiff,BCC Shippensburg peratio s,d/b/a Elmcroft of Shippensburg, and against Anna
Gettel a/k/a A. Gettel a/k/a Anna Grace Gettel, by default for want of an answer and damages
assessed at the sum of$13,002.88 as per the above certification.
PROTHONOTARY
Page 2 of 2
LAW OFFICE OF BRIAN SCOTT DIETRICH, P.C.
BRIAN SCOTT DIETRICH, ESQUIRE ATTORNEYS FOR PLAINTIFF
Attorney I.D. # 57174 BCC Shippensburg Operations, LLC
DENNIS C. VONDRAN JR., ESQUIRE d/b/a Elmcroft of Shippensburg
Attorney I.D. # 306396
610 Sentry Parkway, Suite 200
Blue Bell, Pennsylvania 19422-0450
[T] (610) 629-6300
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL ACTION--LAW
BCC Shippensburg Operations, LLC
d/b/a Elmcroft of Shippensburg No. 14-339
V.
Anna Gettel a/k/a A. Gettel ARBITRATION CASE
a/k/a Anna Grace Gettel
CERTIFICATION OF SERVICE
I, Dennis C. Vondran Jr., Esquire, hereby certify a true and correct copy of the Notice of
Praecipe to Enter Judgment by Default and accompanying cover letter were served upon the
following individual(s)by United States Postal Service,First Class,postage pre-paid,addressed as
follows:
Anna Gettel
474 East King Street
Shippensburg, PA 17257
/Z /2014 k_ (
DENNIS C. VONDRAN, JR.
Attorney for Plaintiff
Page 1 of 1
LAW OFFICE OF BRIAN SCOTT DIETRICH
A PROFESSIONAL CORPORATION
Brian Scott Dietrich
Regina B.Diamond Post Office Box 1627 Telephone(610)629-6307
Dennis C.Vondran,Jr. Blue Bell, Pennsylvania Facsimile(610)629-6301
of Counsel 19422-0450
Michael F.Wenke
April 8, 2014
Ms. Anna Gettel
474 East King Street
Shippensburg, Pa 17257
I �Iill� ll�lllllll
RE: BCC Shippensburg Operations LLC d/b/a Elmcroft of Shippensburg v.
Anna Gettel
Cumberland County Court of Common Pleas Docket No.: 14-339
LOBSDPC NO.: 11633
Dear Ms. Gettel:
I represent BCC Shippensburg Operations LLC d/b/a Elmcroft of Shippensburg in the
above referenced litigation matter.
Enclosed please find a Written Notice of Intention to File Praecipe for Entry of Default
Judgment. Please read this notice carefully.
This communication is given to you in conformity with the Fair Debt Collection Practices
Act, as amended. This letter is an attempt to collect a debt, and any information obtained will be
used for that purpose.
Please contact the undersigned to make payment arrangements in this case.
Ve truly yours,
UAL
Dennis C. Vondran, Jr.
DCV:jmg
Enc. 10 Day Notice
LAW OFFICE OF BRIAN SCOTT DIETRICH, P.C.
BRIAN SCOTT DIETRICH,ESQUIRE ATTORNEYS FOR PLAINTIFF
Attorney I.D. # 57174 BCC Shippensburg Operations,LLC
DENNIS C. VONDRAN JR.,ESQUIRE d/b/a Elmcroft of Shippensburg
Attorney I.D. # 306396
P.O. Box 1627
Blue Bell, Pennsylvania 19422-0450
[T] (610) 629-6300
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL ACTION--LAW
BCC Shippensburg Operations, LLC
d/b/a Elmcroft of Shippensburg No. 14-339
V.
Anna Gettel a/k/a A. Gettel ARBITRATION CASE
a/k/a Anna Grace Gettel
WRITTEN NOTICE OF INTENTION TO FILE PRAECIPE FOR
ENTRY OF DEFAULT JUDGMENT
TO: Anna Gettel
474 East King Street
Shippensburg, Pa 17257
DATE OF NOTICE: April 8, 2014
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU.
UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY
LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS
NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT
AFFORD ONE,GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE
YOU CAN GET LEGAL HELP:
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE,PA 17013
717-249-3166 OR 800-990-9108
1" C V ��
DATE: April 8, 2014
DENNIS C. VONDRAN, JR., ESQUIRE
Attorney for Plaintiff
Page 1 of 1
LAW OFFICE OF BRIAN SCOTT DIETRICH, P.C.
BRIAN SCOTT DIETRICH, ESQUIRE ATTORNEYS FOR PLAINTIFF
Attorney I.D. # 57174 BCC Shippensburg Operations, LLC
DENNIS C. VONDRAN JR., ESQUIRE d/b/a Elmcroft of Shippensburg
Attorney I.D. # 306396
610 Sentry Parkway, Suite 200
Blue Bell, Pennsylvania 19422-0450
[T] (610) 629-6300
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL ACTION--LAW
BCC Shippensburg Operations, LLC
d/b/a Elmcroft of Shippensburg No. 14-339
V.
Anna Gettel a/k/a A. Gettel ARBITRATION CASE
a/k/a Anna Grace Gettel
CERTIFICATION OF ADDRESS
TO THE PROTHONOTARY:
Plaintiffs Address is:
Elmcroft of Shippensburg
c/o Law Office of Brian Scott Dietrich
610 Sentry Parkway, Suite 200
Blue Bell, PA 19422
Defendant's Address is:
Anna Gettel
474 East King Street
Shippensburg, PA 17257
DATE. / Z 1 /2014 C
DENNIS C. VONDRAN, JR.
Attorney for Plaintiff
Page 1 of 1
LAW OFFICE OF BRIAN SCOTT DIETRICH, P.C.
BRIAN SCOTT DIETRICH, ESQUIRE ATTORNEYS FOR PLAINTIFF
Attorney I.D. # 57174 BCC Shippensburg Operations, LLC
DENNIS C. VONDRAN JR., ESQUIRE d/b/a Elmcroft of Shippensburg
Attorney I.D. # 306396
610 Sentry Parkway, Suite 200
Blue Bell, Pennsylvania 19422-0450
[T] (610) 629-6300
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL ACTION--LAW
BCC Shippensburg Operations, LLC
d/b/a Elmcroft of Shippensburg No. 14-339
V.
Anna Gettel a/k/a A. Gettel ARBITRATION CASE
a/k/a Anna Grace Gettel
AFFIDAVIT OF NON-MILITARY SERVICE
I, Dennis C. Vondran, Jr., Esquire, hereby state the following:
1. I am authorized on behalf of the plaintiff, BCC Shippensburg Operations, d/b/a
Elmcroft of Shippensburg, to execute this Affidavit of Non-military Service;
2. Plaintiff believes,and therefore avers,that the defendant,Anna Gettel a/k/a A.Gettel
a/k/a Anna Grace Gettel, is of adult years over the age of majority;
3. Plaintiff believes, and therefore avers, that the defendant resides at 474 East King
Street, Shippensburg, PA 17257;
4. Plaintiff believes,and therefore avers,that the defendant is not in the military or naval
services of the United States or its allies, or is otherwise within the provisions of the Soldiers and
Sailors Civil Relief Act of Congress of 1940 and its amendments.
DATE: `� / - /2014 L, C l
DENNIS C. VONDRAN, JR.
Attorney for Plaintiff
Page 1 of 1
LAW OFFICE OF BRIAN SCOTT DIETRICH, P.C.
BRIAN SCOTT DIETRICH, ESQUIRE ATTORNEYS FOR PLAINTIFF
Attorney I.D. # 57174 BCC Shippensburg Operations, LLC
DENNIS C. VONDRAN JR., ESQUIRE d/b/a Elmcroft of Shippensburg
Attorney I.D. # 306396
610 Sentry Parkway, Suite 200
Blue Bell, Pennsylvania 19422-0450
[T] (610) 629-6300
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL ACTION--LAW
BCC Shippensburg Operations, LLC
d/b/a Elmcroft of Shippensburg No. 14-339
V.
Anna Gettel a/k/a A. Gettel ARBITRATION CASE
a/k/a Anna Grace Gettel
Notice 236
Notice is given that a judgment in the above-captioned matter has been entered against
defendant, Anna Gettel a/k/a A. Gettel a/k/a Anna Grace Gettel.
DATE: S / /2014
Prothonotary
If you have any questions concerning the above, please contact:
Law Office of Brian Scott Dietrich, P.C.
610 Sentry Parkway, Suite 200
Blue Bell, PA 19422-0450
610-629-6300
Page 1 of 1
LAW OFFICE OF BRIAN SCOTT DIETRICH, P.C.
BRIAN SCOTT DIETRICH, ESQUIRE
Attorney I.D. # 57174
DENNIS C. VONDRAN JR., ESQUIRE
Attorney I.D. # 306396
610 Sentry Parkway, Suite 200
Blue Bell, Pennsylvania 19422-0450
[T] (610) 629-6300
ATTORNEYS FOR PLAINTIFF
BCC Shippensburg Operations, LLC
d/b/a Elmcroft of Shippensburg
IN THE COURT OF COMMON PLEAS OF CUMBERLAND
CIVIL ACTION -- LAW
BCC Shippensburg Operations, LLC
d/b/a Elmcroft of Shippensburg
v.
Anna Gettel a/k/a A. Gettel
a/k/a Anna Grace Gettel
COUNTY, PENNSYLVANIA2
rTi ria No. 14-339
<cJ -v c;
3>C)
r
ARBITRATION CASE ep
PRAECIPE TO SATISFY JUDGMENT
TO THE PROTHONOTARY:
Please mark the judgment in the above case SATISFIED as to Anna Gettel a/k/a A.
Gettel a/k/a Anna Grace Gettel, upon payment of Prothonotary's costs only.
OLLA
Debra Vance
Representative for Plaintiff
Date: 7 / �� / 2014
C vV
Dennis C. Vondran Jr., Esquire
Attorney for Plaintiff
Date: '7 / '7 / 2014
Page 1 of 1
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