HomeMy WebLinkAbout06-0824
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
MANOR HEALTHCARE CORP, d/b/a
MANORCARE HEALTH SERVICES -
CARLISLE,
Plaintiff,
v,
No, (fc - fJ.Y
c.-,vL~VYi.
RICHARD DICK, in his capacity
as Executor of the Estate of Paul E. Dick.
Defendant.
CIVIL ACTION - LAW
MORTGAGE FORECLOSURE
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims
set forth in the following pages, you must take action within twenty (20) days after this
complaint and notice are served, by entering a written appearance personally or by
attorney and filing in writing with the court your defenses or objections to the claims set
forth against you, You are warned that if you fail to do so the case may proceed without
you and a judgment may be entered against you by the court without further notice for
any money claimed in the complaint or for any other claim or relief requested by the
plaintiff, You may lose money or property or other rights important to you,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
MANOR HEALTHCARE CORP, d/b/a
MANORCARE HEALTH SERVICES -
CARLISLE,
Plaintiff,
v,
No,
RICHARD DICK, in his capacity
as Executor of the Estate of Paul E. Dick.
Defendant.
CIVIL ACTION - LAW
MORTGAGE FORECLOSURE
A VISO
USTED HA SlOO DEMANDADO/ A EN CORTE. Si usted desea defenderse de
las demandas que se presentan mas adelante en las siguientes paginas, debe tomar
accion dentro de los proximos veiente (20) dias despues de la notificacion de esta
Demanda y A viso radicando personalmente 0 por medio de un abogado una
comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objeccionee
a, las demandas presentadas aqui en contra suya, Se Ie advierte de que si usted falIa de
tomar accion como se describe anteriormente, el caso puede proceder sin usted y un
falIo por cualquier suma de dinero reclamada en la demanda 0 cualquier otra
reclamacion 0 remedio solicitado por el demandante puede ser dictado en contra suya
por la Corte sin mas aviso adicionaL Usted pued perder dinero 0 propiedad u otros
derechos importantes para usted,
USTED DEBE LLEV AR ESTE DOCUMENTO A SU ABOGADO
INMEDIA T AMENTE. SI USTED NO IlENE UN ABOGADO 0 NO PUEDE P AGARLE
A UNO, LLAME 0 VAYA A LA SIGUIENTE OFICINA PARA AVERIGUAR DONDE
PUEDE ENCONTRAR ASISTENCIA LEGAL.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
MANOR HEALTHCARE CORP. d/b/ a
MANORCARE HEALTH SERVICES -
CARLISLE,
Plaintiff,
v,
No, 01.- JJ.cl ~'/~
RICHARD DICK, in his capacity
as Executor of the Estate of Paul E. Dick.
Defendant.
CIVIL ACTION - LAW
MORTGAGE FORECLOSURE
COMPLAINT IN MORTGAGE FORECLOSURE
AND NOW, COMES, Plaintiff, Manor Healthcare Corp, d/b/a ManorCare
Health Services - Carlisle, ("Plaintiff ManorCare"), by and through its attorneys,
SCHUTJER BOGAR LLC, and files the within Complaint against Defendant, Richard
Dick ("Defendant R. Dick"), in his capacity as Executor of the Estate of Paul E. Dick, and
in support thereof, provides as follows:
1. Plaintiff ManorCare is a Delaware corporation licensed to do business in
the Commonwealth of Pennsylvania, with its principal offices located at 940 Walnut
Bottom Road, Carlisle, Pennsylvania 17013,
2, Defendant R. Dick, the Executor of Paul E. Dick's estate, is an adult
individual who currently resides at 671 Old Mill Road, Newville, Pennsylvania 17241,
3, On October 26, 2005, Paul E, Dick, through his attorney-in-fact, Roger B.
Irwin, executed and delivered to Plaintiff ManorCare an Open-End Mortgage
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("Mortgage"), A true and correct copy of the Mortgage is attached as Exhibit" A" and
is incorporated by reference,
3, The legal description of the land subject to that Mortgage is as follows, to
wit:
ALL that certain piece or parcel of land with the
improvements thereon situate in North Middleton Township,
County of Cumberland and State of Pennsylvania, bounded and
described as follows, to wit:
BEGINNING at stones at land formerly of Harry Dick,
now of C. K. Snyder; thence by said lands, South 16 degrees 30
minutes East 276 perches to a white oak; thence by the same,
South 2 1/2 degrees East 6 perches to a point at public road;
thence by lands formerly of Jacob A. Dick, now of Walter
Meloy, South 71 degrees 30 minutes West 112.5 perches to a
point at lands formerly of Tillie B. Dick now of Harry Ronan;
thence by said lands, North 31 degrees West 43,6 perches to a
point corner of land now or formerly of William Long; thence
by said lands, North 81 1/2 degrees East 15,1 perches to stones;
thence by same, North 37 degrees West 36.7 perches to stone in
public road; thence North 44 % degrees East 9,3 perches to a
point at side of road; thence by land now or formerly of Albert
Thomas, North 46 % degrees West 47 perches to a point at
corner of lands formerly of A. L Bierbower, now of Audrey B.
Baldwin; thence by the same, North 4 degrees 15 minutes East
102.2 perches to stone; thence by same, North 80 degrees 30
minutes West 46.5 perches to a point; thence by the same, North
1 degree 15 minutes East 96.5 perches to stones at lands
formerly of Mrs, V, Pemose, now of Paul E. Dick, Grantee
herein; thence by said lands, South 86 degrees East 122 perches
to stones at lands formerly of Harry Dick, now of C. K. Snyder,
the Place of BEGINNING.
CONTAINING 234 acres and 150 perches, strict measure,
BEING the same property which Stella Baitsell, Executrix
of the Estate of Harry Dick, granted and conveyed to Paul E,
Dick, Mortgagor herein, by deed dated July 2, 1947 and
2
recorded in the Office of the Recorder of Deeds for Cumberland
County, Pennsylvania, in Deed Book "0", Volume 13, Page 271,
LESS, HOWEVER, a track of land containing 1,9 acres
conveyed to Thomas and Betty Stewart, by deed dated June 22,
1979 and recorded in Deed Book "M", Volume 28, Page 593,
4, The Mortgage was recorded with the Cumberland County Recorder of
Deeds on October 26, 2005 in Book Volume 1928, Page 1299,
5, Paul E. Dick died on December 17, 2005 and Defendant R. Dick was
appointed as Executor of Paul E. Dick's Estate on January 19, 2006,
6, Because Paul E. Dick died, pursuant to paragraph (3)(a) of the Mortgage,
an event of default has occurred.
7. Accordingly, Plaintiff ManorCare is entitled under paragraphs (3)(a) and
(5)(a) of the Mortgage to bring this foreclosure action to collect the following amounts
due and owing:
a, The original principle amount of $14,587,00;
b, The amount of $4,248.55 for additional nursing facility services
provided to Paul E. Dick. A true and correct copy of Plaintiff
ManorCare's itemized charges is attached as Exhibit "B" and is
incorporated by reference; and
c. The attorney's fees and legal costs in the amount of $7,073.75,
8, Therefore, Plaintiff ManorCare is entitled to recover a total of $25,909,30
pursuant to the Mortgage attached as Exhibit" A."
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WHEREFORE, Plaintiff ManorCare seeks a judgment in the amount of
$25,909,30.
Respectfully submitted,
SCHUTJER BOGAR LLC
D,ted, ~
By:
Bradley.PI. ch 'r
Attorney LD, No, 75954
717,909.5921
Rodney Alan Myer
Attorney LD, No, 89381
717,909,8160
305 N, Front Street, Suite 401
Harrisburg, PA 17101
Attorneys for Plaintiff
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F[B-05-~005 (~ON) 15: U
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VERIFICATION
The undersigned hereby verifies that the statements of fact in the foregoing
Complaint are tnleand correct to the best of my knowledge. information and belief. I
understand that any false statements therein are subject to the penalties contained in 18
Fa. CS,A. !l 4904. relating to unsworn falsification to authorities.
Dated:
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l~l[U -f:'" \J..,~: d
Kimberly L, Etzler,B<DM
ManorCare Health Services - Carlisle
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EXHIBIT "A"
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Parcel ID # 29-04-0377-030
OPEN-END MORTGAGE
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THIS MORTGAGE INDENTURE ("Mortgage"), made this 0< 1.0 ''- day of
UctJ:..e'L_ ,2005, between Paul E. Dick, an adult individual, by and through his agent in
fact, Roger B. Irwin, Esq" (the "Mortgagor"),
-AND-
HCR ManorCare - Carlisle, a Pennsylvania organization (the "Mortgagee"),
WITNESSETH, that Mortgagor, in consideration for and to secure his payment to
Mortgagee of principal indebtedness in the amount FOURTEEN THOUSAND, FNE
HUNDRED AND EIGHTY-SEVEN AND 00/100 DOLLARS ($14,587,00) and to secure all
future advances and other extensions of credit by the Mortgagee for care and services rendered to
the Mortgagor up to an amount not to exceed FIFTY THOUSAND 00/100 DOLLARS
($50,000,00) in the aggregate, costs and other amounts due or becoming due under the terms of
this Mortgage, and Mortgagor's performance of all covenants and obligations contained herein,
Mortgagor hereby does convey and mortgage unto Mortgagee ALL THAT CERTAIN tract or
parcel ofland situated in North Middleton Township, Cumberland County, Pennsylvania, more
fully described in Exhibit "A" attached hereto (hereby made an integral part hereof and
incorporated by reference as if herein fully set forth verbatim),
TOGETHER with, all and singular, any buildings and improvements thereon and the
additions thereto, and all ways, streets, alleys, passages, waters, water-courses, rights, liberties,
privileges, hereditaments and appurtenances, whatsoever thereunto belonging, or in any wise
appertaining (collectively, the "Premises"),
TO HAVE A1','O TO HOLD the Premises unto Mortgage", to arid for Mortgagee's only
proper use and behoof, forever; PROVIDED, however, that if and only if all indebtedness, future
advances, amounts, and obligations under this Mortgage are fully paid, satisfied and performed
as herein or therein provided, then this Mortgage and the estate hereby granted shall cease,
terminate and become void, otherwise to be and remain in full force and effect.
Mortgagor further covenants and agrees that:
(1) Mortgagor at all times: (a) has and shall have fee simple title to, and the right to
mortgage the Premises; (b) shall maintain the Premises in good order and repair, and not commit
or allow any waste, impairment or deterioration of or with respect to the Premises or any
nuisance to occur or exist thereon; (c) shall observe and comply with all applicable federal, state,
municipal, local and other laws, mles and regulations, including but not limited to
environmental, land development zoning or building codes; (d) shall pay when and as due all
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taxes, charges, assessments and other amounts due or becoming due to any governmental
authorities and all water, sewer and other utility rents, charges and expenses upon or with respect
to the Premises, and shall deliver to Mortgagee receipts for or other satisfactory proof of such
payment; (e) shall take all actions to maintain the lien of this Mortgage as a first lien against the
Premises, including without limitation not incurring any debts and timely paying all amounts that
have or could have a lien priority equal to or greater than the lien of this Mortgage and properly
obtaining and timely filing valid stipulations against and waivers of all mechanics',
materialmen's and similar liens or claims so as to prevent the same from arising,
(2) Mortgagor at all times shall keep in force with respect to the Premises fire and
extended coverage and general public liability insurance in the form and content acceptable to
Mortgagee, any and all proceeds of which shall be payable first and delivered to Mortgagee
which proceeds Mortgagee may apply to pay and discharge any and all indebtedness and other
amounts of any kind due to Mortgagee under this Mortgage, All such insurance coverage shall
be issued by one or more reputable insurance companies duly qualified to do business in the
Commonwealth of Pennsylvania, and shall provide that such coverage shall not be canceled
without giving Mortgagee at least thirty (30) days advance written notice thereof and that if
Mortgagor shall fail to keep such insurance in effect or give notice of its non-renewal, the insurer
immediately shall notify Mortgagee thereof. Upon request Mortgagor shall deliver to Mortgagee
a copy of each current insurance policy, certificate of insurance or other proof satisfactory to
Mortgagor showing that the insurance coverage hereby required is in force and effect.
(3) The occurrence of any of the following will be a default under this Mortgage,
although the potential events of default are not limited to the below provided, upon which all
indebtedness and other amounts due or that may become due under this Mortgage, whether of
principal, interest or otherwise, together with any reasonable attorneys' fees arising from
Mortgagee's attempts to exercise its rights under this Mortgage, shall be and become
immediately due and payable in full and Mortgagee may exercise any and all Mortgagee's rights
or remedies set forth in this Mortgage or otherwise available to Mortgagee, however and
whenever Mortgagee may determine, including, but not limited to, the methods of enforcement
provided under paragraph (5)(a) and (b):
(a) The death of Paul E, Dick;
(b) All monies due under this Mortgage are not paid in full by December 31,
2006; or
(c) The Premises, or any portion thereof, are sold,
(4) If Mortgagor fails to perform any covenant or obligation of Mortgagor under this
Mortgage, Mortgagee may (but need not) advance funds, incur expenses and take other actions
appropriate to cure such default in whole or in part, Should Mortgagee do so, any and all funds
so advanced and expenses so incurred shall be additional amounts due under this Mortgage and
hereby secured, payable to Mortgagee upon demand, and until so paid shall bear interest at the
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annual rate of six percent (6%) from the date so advanced or incurred,
(5) If Mortgagor fails to observe or perform any other covenant or obligation of
Mortgagor under this Mortgage, such failure shall be a default under this Mortgage, upon which
all indebtedness and other amounts due or that may become due under this Mortgage, whether of
principal, interest or otherwise, together with any reasonable attorneys' fees arising from
Mortgagee's attempts to exercise its rights under this Mortgage, shall be and become
immediately due and payable in full and Mortgagee may exercise any and all Mortgagee's rights
or remedies set forth in this Mortgage or otherwise available to Mortgagee, however and
whenever Mortgagee may determine, including without limitation: (a) bring an action of
mortgage foreclosure upon this Mortgage and proceed to judgment execution and sale to recover
all such indebtedness, amounts, attorneys' fees and interest and all costs thereof; (b) with or
without notice, legal action or otherwise, take possession of the Premises and collect and apply
any and all rents and profits therefrom to payor discharge all costs of collection and
administrative expenses (including fees of agents and attorneys), taxes, and costs and expenses
of maintenance, construction, improvement repair, management and operation of the Premises
and/or to reduce the aforesaid indebtedness, amounts, attorneys' fees and interest all as and in
such order and amounts as Mortgagee may elect with Mortgagee to be liable to account for only
rents and profits actually received by it.
(6) This Mortgage shall be binding upon and inure to the benefit of each of
Mortgagor and Mortgagee, and their respective heirs, personal and legal representatives,
successors, and assigns, and wherever used in this Mortgage, the term "Mortgagor" and
"Mortgagee" shall be so construed and enforced, Where used in this Mortgage, the plural shall
include the singular, and vice-versa, All costs of satisfying this Mortgage as of record shall be
paid by Mortgagor.
IN WITNESS WHEREOF, the Mortgagor, Paul E, Dick, by and through his agent in
fact, Roger B, Irwin, intending to be legally bound hereby, has duly executed this Mortgage as of
the day, month and year first above written,
WITNESS:
MORTGAGOR:
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Paul E. Dick, by nd through his agent in
fact, Roger B,' win, Esq,
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Parcel ill # 29-04-0377-030
STATE OF PENNSYLVANIA
COUNTY OF CV7??,b 't-t-Ca. -n ~
CIA
Onthis,the :II, dayof Pc.COD.v\.-. ,2005,beforeme, the undersigned
officer, a Notary Public in and for said State and County, personally appeared Roger B, Irwin,
Esq" agent in fact for Paul E. Dick, of the County of -'dLm..h 'lA 'co n d known to me
(or satisfactorily proven) to be the person whose name is subscribed to the within instrument and
acknowledged that he executed the same for the purposes therein contained,
SS,
IN WITNESS WHEREOF, I hereunto set my hand and official seaL
~~~
(Seal)
~EAlTH OF PENNSYLVANIA
NolartaI Seal
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lA.. . - '......., Counly
"'1 Com,........ Expires Sept. 18, 2007
Member, Pennsylvania ASSOCiation Of Notaries
Commission Expires:
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Parcel ill # 29-04-0377-030
EXHIBIT" A"
LEGAL DESCRIPTIONS OF REAL ESTATE
ALL that cert:~ piece or parcd 01' 'lMd Wit:h the :!J>pmVOJ1let1cs
theL~on si~ual;e :in Ilot'ttl ~<ldl.aton 'ltlimOh1p, (i:">1ty el' Cullb..,.lend.-.n<l State or
Pe"""yl'lln'lie., bOU'lded Md olesct1J>ed "" t'olkMc, 1:0 vla.t:, -
. BEGINm:NG ae sto""" at 1lll1d 1'onrer]J e~ ~ DioK, n"" or c. lC. SnYCet'~ .
t:l1cnca Oy said 1Bn<lS. Sout:h 16 Celrees JO nrl.nuteS Ea!It: :!i.6 percl;es to a ~ite -;
thence by t:be sane, SOUth . 11. degree. Ease 6 perch,;s to a poln.t at: pub;tie road;
teen"e by l2nds fotnerJ,y er J= A. Dl.ck, l\W oj.' Walter Moloy. South 7:L degrees
30 mLn.u1:es WC!lj; 112.5 pet'Ches 1:0 U po1nt; at l.ands !imrerJ,y er Tillie il. Ol.cl< nO>{
of U3rr,{ Il:>nan; thence b:i tond lands, llor\:h 31 ~r;reee \lest Q).6 perch.' to a po:lnt
comer or ltlnd nOM 0[' 1"0nrer~ of ~ Long; l;hencc by said lands, North III 1/2
de"",e. Enst 15.1 perche. to etOll<!Slthence oy .a:re, Nortn 31 del;l'ees ~eot 36.7
,,~rcheo to stone in pUbUo road; therloe I/Orth ~4 3/" c!ogroes 1::ase 9.3 1l"rth"" to ..
-po!.nt at side 01' :ro!Ul; tiJE,noe by l!!lld 110'0' Or rorrrer~ or A,lbert ~o""",. North
46 31" <lee;re<!s West 41 po:rthes te o. point ar; comar or lands fermorJ,y of A. L.
Biu;bowor, new or _y 8. Ilal<>dn; t\>!nce by t:ho. "''''''c. Nort:l1 Q degrel!ll 15 m1nutes
8>0" W2.. perches to "tone: t:hence by $aIre, N<J""'h So dei9"es 30 m1nut:e" WC!lt
~6.5 peI'Cl1"" to a peine; !:hence by the seme, North 1 ",""",e 15 mlnl.\ta" East 96.5
perchee to scone" eo 1and3 !'QIlIIOrlY of '''''''. V. Penrose. 110,", or f'=1. l1., D~ok,
Grantee herein] thence by "ald Jands, Scut:l\ 06 d"l;I'Coo F.:a.." 1.22 P""ell!" to 000=
at lands 1'Omer1y Or Ilart1 Dl.ok, rtOW' of C. K. Sl'\Ydar, the l'lace of ElE:C1NlIl'Nll.
i- tr.m'AININiJ 234 ec",. Ill'od 1;0 porcheS, st:riet: ..,,,"ure.
5E.UlG tho, .""'" propertY wh1ch Stella 1l.u.t:3ell, E;i:o.cutrtx or tt>> E>.'tate of"
llarry DIck, granted ;mcl cen"".."d cO l'aul. 1':. !lick, M:>""~r herein, \>y ","00. OataO
ilul.y 2, 19'7 and ",corded j.n th. Om,oe of the !1ecorrl." or Doe<l:l tet' C\>rIl""land
Cotnty! ~YJ.vanu.J 10 teQ~_~.ll?~~Yl?~~ ~3~ page ::71..
LESS, HOWEVER a tract ofland coolsining a 1_9 acres conveyed 10
Thcmas and Betty Slewart, by deed dated June 22, 1979 and recorded in Deed
Beck "M", Voleroe 28, Page 593,
JS iO be recorded
:;;"'i':land County PA
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Recorder of Deeds
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EXHIBIT "B"
DICK, PAUL 24250
~~tl,lll;lliliillllll! ,111111!II~t~i~1'imlli(ftll!1111~t(:illlfllllll: Irll~IIIII.lil~ ..'.'" t
12/15/2004 CUT WITH BEARD TRIM $10,00
1/31/2005 CO INSURANCE NOT PD BY INSURANCE $3,420,00
2/1/2005 CUT WITH BEARD TRIM $10,00
2/28/2005 CO INSURANCE NOT PD BY INSURANCE $1,543,32
3/17/2005 FREE CUT W/BEARD TRIM $10,00
3/31/2005 INSURANCE PREMIUM
03/23-03/31/05 PRIVATE PORTION
3/31/2005 CO INSURANCE NOT PD BY INSURANCE
4/30/2005 INSURANCE PREMIUM
04/01-04/19/05 PRIVATE PORTION
5/26/2005 FREE HAIRCUT
5/31/2005 INSURANCE PREMIUM
05101-05/17/05 PRIVATE PORTION
6/30/2005 INSURANCE PREMIUM
06101-06/30/05 PRIVATE PORTION
7/31/2005 INSURANCE PREMIUM
07101-07/31/05 PRIVATE PORTION
8/2/2005 FREE HAIRCUT
08//31/05 INSURANCE PREMIUM
08/01-08/31/05 PRIVATE PORTION
9/30/2005 INSURANCE PREMIUM
09/01-09/05/05 PRIVATE PORTION
10/5/2005 FREE HAIRCUT
11/22/2005 FREE HAIRCUT
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HCR*ManorCare
MANORCARE CARLISLE 372
940 WALNUT BOTTOM ROAD
CARLISLE, PA 17013
(717)-249-0085
Payment Due Upon Receipt
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PRIVATE
STATEMENT
ROOM
1/31/2006
$1,429,37
$827,36
$2,253,14
$8,50
$2,253,14
$2,253,14
$2,253,14
$8,50
$2,253,14
$877,20
$10,00
$10,00
Amount Due
-$10,00
-$78,20
-$76,20
-$8,50
-$76,20
-$78,20
-$76;;20
-$8,50
-$78,20
-$76,20
-$10,00
-$1'060
$18,635,55
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fin:rr IRnl)gnnZ-Tf-NV' aW!l/'l'n "M
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MANOR HEALTHCARE CORP.
d/b/a MANOR CARE HEALTH
SERVICES - CARLISLE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 06-824 CIVIL TERM
RICHARD DICK, in his capacity : CIVIL ACTION - LAW
As Executor of the Estate of Paul E. Dick, :
Defendant : MORTGAGE FORECLOSURE ACTION
PRAECIPE TO ENTER APPEARANCE
To Curtis R. Long, Prothonotary:
Please enter my appearance on behalf of the Defendant, Richard L. Dick, Executor of the
Estate of Paul E, Dick, in the above captioned case,
Respectfully Submitted,
IRWIN & McKNIGHT
HI!~
Douglas G. 'Iler, Esquire
Supreme Court LD, No, 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Date: March 7, 2006
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CERTIFICA TE OF SERVICE
I, Douglas G, Miller, Esquire, do hereby certify that I have served a true and correct copy
of the foregoing document upon the persons indicated below by first class United States mail,
postage paid in Carlisle, Pennsylvania 17013, on the date set forth below:
Bradley A. Schutjer, Esquire
Schutjer Bogar, LLC
305 North Front Street
Suite 401
Harrisburg, PA 17101
(Attorney for Plaintiff)
Date: March 7, 2006
IRWIN & McKNIGHT
~A1~
Douglas Miller, Esquire
Supreme Court ID # 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Attorney for Defendant
C)
jo.'
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SHERIFF'S RETURN - REGULAR
CASE NO: 2006-00824 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MANOR HEALTHCARE CORP ET AL
VS
DICK RICHARD EXEC OF ESTATE OF
ROBERT BITNER
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
DICK RICHARD EXEC OF ESTATE OF PAUL DICK
the
DEFENDANT
, at 1237:00 HOURS, on the 24th day of February
2006
at 671 OLD MILL ROAD
NEWVILLE, PA 17241
by handing to
RICHARD DICK
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
7.04
,00
10.00
,00
35.04
So Answers:
,~~~,<<~
(/
R, Thomas Kline
02/27/2006
SCHUTJER BOGAR LLC
Sworn and Subscribed to before
me this ';'''''''
day of
By: ~
cJ.,. +- 7J.~
Deputy Sheriff
~ """~ AD
;!t1~ 'a1