HomeMy WebLinkAbout04-25-06
APR-12-2006 (WED) 10: 08
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: BARBARA SALIARIS
D.C. No. 21-05-0852
STIPULATION FOR GRANT OF PETITION FOR ACCOUNTING
Manor Healthcarc Corp. d/b/a ManorCare Health Services - Carlisle
(" Petitioner") and Niki Ritter ("Respondent") stipulate and agree to the following:
1. On or about September 22, 2005, Petitioner filed a Petition for Accounting
and Turn Over of Assets against Respondent.
2. The Petition seeks, among other things, to have Respondent account for
how she used approximately $37,028.64 belonging to her principal, Barbara Saliaris.
. 3. The parties agree to the entry of an Order directing Responden t to provide
said accounting within five (5) business days of the time that she is required to do so in
response to a. forthcoming action to be filed with this Court by the Commonwealth of
Pennsylvania, Office of Inspector General.
4. The parties further agree that if Respondent is able to settle the above-
~'"""-,)
C~J
referenced forthcoming action without any resulting penalty period, Le. s~sion ~
'<J~ () ;5
Medical Assistance benefits, said accounting will be unnecessary, and Respo~fi~t ~
lj J /,,~..
agrees to waive its right thereto.
()
.'r..
P 003/004
r-~
_.,.,.
o
N
0)
-~
RPR-12-200o(WEO) 10:08
P 004/00~
5. However, if an accounting is prepared by Respondent, upon receipt of
thereof, Petitioner reserves the right to pursue any and all available causes of action
against Respondent and/ or other transferees.
6. Petitioner agrees to withdraw, without prejudice, its Petition for
Accounting and Turn Over of Assets.
Dated: \-1 ( I ~ ( ~
Dated:
Lj-/7-Q(P
2
Respectfully submitted,
By:
('
,-~GI\S
Chadwick O. Bogar
Attorney for. Petitioner
'-
By:
~ -!iLbf
Elizabeth Goldstein
Attorney for Respondent
RPR-12-200fj (WED) 10: 08
P 002/00a
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: BARBARA SALIARIS
O.c. No. 21-05-0852
ORDER
AND NOW, this
day of
,2006, in consideration of the
parties' annexed Stipulation for Grant of Petition for Accounting, it is hereby
ORDERED AND DECREED that said Stipulation is GRANTED, the terms of which are
set forth therein.
BY THE COURT
J.
RPR-12-2005(WEO) 10:08
~ fl~/eall
RECEl. F 'j.' 'i :: .^ /
. ;..,.t ,,;', ",.~ , ~
A PR 2 5 2006 ;
BY. .~_i
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: BARBARA SALIARIS o.c. No. 21-05-0852
ORDER
AND NOW, this l b ~ day of ~ 2006, in consideration of the
parties' annexed Stipulation for Grant of Petition for Accounting, it is hereby
ORDERED AN'D DECREED that said Stipulation is GRANTED, the terms of which are
set forth therein.
BY THE COURT
J.
f'-...)
-".,.1
-;J
(r)
:::u
..:.-,;,
V.Oj
o
APR-12-2006(WED) 10:08
P.003/004
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: BARBARA SALIARIS
D.C. No. 21-05-0852
STIPULATION FOR GRANT OF PETITION FOR ACCOUNTING
Manor Healthcarc Corp. d/b/ a ManorCare Health Services - Carlisle
(II Petitioner") and Niki Ritter rIRespondent") stipulate and agree to the following:
1. On or about September 22, 2005, Petitioner filed a Petition for Accounting
and Turn Over of Assets against Respondent.
2. The Petition seeks, among other things, to have Respondent account for
how she used approximately $37,028.64 belonging to her principal, Barbara Saliaris.
,3. The parties agree to the entry of an Order directing Respondent to provide
said accounting within .five (5) business days of the time that she is required to do so in
response to a. forthcoming action to be filed with this Court by the Commonwealth of
Pennsylvania, Office of Inspector General.
4. The parties further agree that if Respondent is able to settle the above-
r-:>
c;::;;>
c:::>
referenced forthcoming action without any resulting penalty period, i.e. ~sion ~
'::- :0 -0
;o'i~~O :;0
Medical Assistance benefits, said accounting will be unnecessary, and Respt';"~~t ~
(j) 0';:>::
agrees to waive its right thereto.
C)Q
c)-on
c::
~~
00
-?
~
a
N
~
-::::~}
,0-1
(-)
:>-)
.~ )~~J
;- .)
..:...r1
~-:j
,---.,
~:::h
.-':J
. (0')
[ T \
l}
:ch
~
APR-12-2006(WED) 10:08
~r..~
5. However, if an accounting is prepared by Respondent, upon receipt of
thereof, Petitioner reserves the right to pursue any and all available causes of action
against Respondent and/ or other transferees.
6. Petitioner agrees to withdraw, without prejudice, its Petition for
Accounting and Turn Over of Assets.
Dated: ~~
Dated:
Lj-/7-0~
2
Respectfull y submitted,
By:
t-ho,~
Chadwick O. Bogar
Attorney for. Petitioner
By:
o;Jd 4LtA
Elizabeth Goldstein
Attomey for Respondent
P.004/004
('
'-
In Re: Estate of BARBARA SALIARIS
ORPHANS' COURT DIVISION
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
PENNSYLVANIA
NO. 21-05-0852
CERTIFICATE OF SERVICE OF ORDER
ORDER DATE: 4-27-06
JUDGE'S INITIALS: J. W. O. JR.
TIME STAMP DATE: 4-27-06
IN RE: ORDER OF COURT: STIPULATION FOR GRANT OF PETITION FOR ACCOUNTING
,'\, '\, '\ '\ '\ '\ '\" '\ "'.. '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\" '\ '\ '\ '\ '\ '\" '\ '\ '\ '\ '\""" '\ '\ '\"" '\ '\"" '\ '\ '\ '\ "" '\ ""'" '\ '\ '" '\"" '\ '\ '\ '\"" '\ '\ '\ '\" '\" '\" '\"" '\'" '\ '\ '\ '\
SERVICE TO:
KIRK S. SOHONAGE, ESQ.
ELIZABETH GOLDSTEIN, ESQ.
METHOD OF MAILING:
ENVELOPES PROVIDED BY:
~ USPS
DRRR
D HAND DELIVERED
D OTHER_
~ PETITIONER
D JUDGE
D CLERK OF ORPHANS COURT
MAILED: 4-28-06
'\ '\ '\ '\ '\... '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '" '\ '\ '\ '\ '\ '\... '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\"... '\ '\" '\ '" '\"" '\ '\ '" '\"... '\ '\ '\ '\ '\ "" '\ "'" '\ '\" '\ '\ '\ '\ '\ '\ '\... '\ '\ '\ '\ '\... '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\ '\
SERVICE TO:
METHOD OF MAILING:
ENVELOPES PROVIDED BY:
D USPS
DRRR
D HAND DELIVERED
D OTHER_
D PETITIONER
D JUDGE
D CLERK OF ORPHANS COURT
MAILED:
~--'Vl;&JU4-a ~U/tL
Deputy
Clerk of Orphans' Court