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HomeMy WebLinkAbout06-3198POST & SCHELL, P.C. BY: PAULA J. MCDERMOTT I.D. #:46664 12 NORTH SECOND ST., 12TH FLOOR HARRISBURG, PA 17101-1601 (717) 731-1970 PRESBYTERIAN HOMES, INC., Plaintiff, LORRAINE DIAS, as Power-of-Attorney for GEORGE DIAS, Defendant. ATTORNEYS I!FOR PLAINTIFF PRESBYTERIAAN HOMES, INC. IN THE CIVIL NO. (DI. - NOTICE TO DEFEND You have been sued in court. If you wish to defend again; following pages, you must take action within twenty (20) days after i served, by entering a written appearance personally or by attorney a court your defenses or objections to the claims set forth against you. fail to do so the case may proceed without you and a judgment may I court without further notice for any money claimed in the complai relief requested by the plaintiff. You may lose money or property you. OF COMMON PLEAS COUNTY, - LAW e,)*LC`7? : the claims set forth in the its complaint and notice are id filing in writing with the You are warned that if you e entered against you by the it or for any other claim or :)r other rights important to YOU SHOULD TAKE THIS PAPER TO YOUR LAWYE AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO O OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CA GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIK 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere del expuestas en las paginas siguien-tes, usted tiene veinte dias de plan demanda y la notifica-cion. Hace falta ascentar una comparencia e abogado y entregar a la corte en forma escrita sus defensas o sus 6 contra de su persona. Sea avisado que si usted no se defiende, la a continuar la demanda en contra suya sin previo aviso o notificacic decidir a favor del deman-dante y requiere que usted cumpla con t4 deman-da. Usted puede perder dinero o sus propieda-des u otros usted. -derse de estas demandas al partir de la fecha de la ita o en persona o con un scions a las demandas en tomara medidas y puede Ademas, la corte puede is las provisio-nes de esta :rechos importan-tes para LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIA A-MENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE AGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFIC A CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIA" 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 800-990-9108 POST & SCHELL, P.C. BY: PAULA J. MCDERMOTT I.D. #:46664 12 NORTH SECOND ST., 12TH FLOOR HARRISBURG, PA 17101-1601 (717) 731-1970 PRESBYTERIAN HOMES, INC., ATTORNEYS?OR PLAINTIFF PRESBYTER N HOMES, INC. IN THE COUR? OF COMMON PLEAS CUMBERLAN COUNTY, Plaintiff, LORRAINE DIAS, as Power-of-Attorney for GEORGE DIAS, CIVIL ACTION I- LAW NO. Ol. - 3 ? (77 Defendant. COMPLAINT AND NOW, comes Plaintiff, Presbyterian Homes, through its attorneys, Post & Schell, P.C., and in support of this 1. Plaintiff PHI is a Pennsylvania non-profit Slate Hill Road, Camp Hill, Cumberland County, PA 1701 L. 2. Plaintiff operates a facility at Green Ridge Village, Spring Road, Newville, Cumberland County, PA 17241-9486. 3. Defendant Lorraine Dias, power of attorney for individual with an address of 209 Park Avenue, Coming, NY 1 4. George Dias is, upon information and belief, full power to act for him as his power of attorney. alutl-7l "PHI"), by and avers the following: with an address of 1217 Health Center, 210 Big Dias, is an adult and Lorraine Dias has 5. A true and correct copy of Lorraine Dias' power or attorney for her father is incorporated hereby and attached hereto as Exhibit "A." 6. Village. Defendant's mother, the late Jean Dias, was a private ?ay resident at Green Ridge 7. The elder Mrs. Dias died at Green Ridge Village on 8. At the time of Jean Dias' admission, Defendai admission agreement as Jean Dias' guardian and power of attorney. 9. As such, Lorraine Dias agreed to apply her mot treatment at Green Ridge Village. No payments have been receiv( 2004. 10. At the present time, the balance due and owing is and costs. 11. A true and correct copy of the agreement signed by I Jean Dias is incorporated hereby and attached hereto as Exhibit "B." 12. The averments of Paragraph 1-11 are incorporated at length. 13. George Dias, by and through his power of attorn obligation pursuant to the doctrine of necessaries to pay for the supplies provided to his wife by Plaintiff. 14. George Dias, by and through his power of attorney, do so. 15. Plaintiff has been damaged by this refusal in the a attorneys' fees and costs, ril 7, 2003. Lorraine Dias signed an is funds to her care and on this account since April plus attorneys' fees Dias as guardian for as if set forth fully and ;y, Lorraine Dias, has an medical care, service and Dias, has failed to of $22,000.00, plus 2 WHEREFORE, Plaintiff Presbyterian Homes, Inc. Court to grant judgment in its favor and against George Dias, attorney, Lorraine Dias, in the amount of $22,000.00, which limit for compulsory arbitration, plus attorneys' fees, costs, and may deem just and equitable. Respectfully POST & PAULA J. MeI Attorney I.D. # 17 North Secon 12th Floor Harrisburg, PA 717.612.6012 Dated: June 2, 2006 Attorneys for Plaintiff 3 requests this Honorable and through his power of is below the jurisdictional other relief the Court P.C. I Street 7101-1601 VERIFICATION I, Jeffrey Davis, a duly authorized representative of Presb nan Homes, Inc., Plaintiff, hereby swear and affirm that the facts and matters set forth in the f?regoing Complaint are true and correct to the best of my knowledge, information, and belief the undersigned understands that the statements made therein are made subject to the penalties o 18 Pa. C.S. §4904 relating to unswom falsification to authorities. Date: A5 2006 May 17 06 11:44a Lorraine K. Dias 607- DURABLE GENERAL POWER OF ATTORNEY NOTICE Isis p.6 THE PURPOSE OF THIS POWER OF ATTORNEY IS TO GIVE THE PERSON YOU DESIGNATE (YOUR "AGENT") BROAD POWERS TO HANDLE YOUR PROPERTY, WHICH MAY INCLUDE POWERS TO SELL OR OTHERWISE DISPOSE OF ANY REAL OR PERSONAL PROPERTY WITHOUT ADVANCE NOTICE TO YOU O APPROVAL BY YOU. THIS POWER OF ATTORNEY DOES NOT IMPOSE A DU ON YOUR AGENT TO EXERCISE GRANTED POWERS, BUT WHEN POWERS ARE EXE CIS ED, YOUR AGENT MUST USE DUE CARE TO ACT FOR YOUR BENEFIT AND IN AC ORDANCE WITH THIS POWER OF ATTORNEY. YOUR AGENT MAY EXERCISE THE POWERS GIVEN HER THROUGHOUT YOUR LIFETIME, EVEN AFTER YOU BECOME INCAPACITATED, UNL.SS YOU EXPRESSLY LIMIT THE DURATION OF THIS POWERS OR YOU REVOKE ESE POWERS OR A COURT ACTING ON YOUR BEHALF TERMINATES YOUR AGENT' AUTHORITY. YOUR AGENT MUST KEEP YOUR FUNDS SEPARATE FUNDS. A COURT CAN TAKE AWAY THE POWERS OF YOUR A AGENT IS NOT ACTING PROPERLY. THE POWERS AND DUTIES OF AN AGENT UNDER A POI EXPLAINED MORE FULLY IN 20 PA. C. S. CH. 56. IF THERE IS ANYTHING ABOUT THIS FORM THAT YOU YOU SHOULD ASK A LAWYER OF YOUR OWN CHOOSING TO E I HAVE READ OR HAD EXPLAINED TO ME THIS NOTICE CONTENTS. APRIL 24, 2000 YOUR AGENT'S IF IT FINDS YOUR OF ATTORNEY ARE NOT UNDERSTAND, 41N IT TO YOU. I UNDERSTAND ITS May 17 06 11:44a Lorraine K. Dias 607-936-11819 DURABLE GENERAL POWER OF ATTORNEY KNOW ALL MEN BY THESE PRESENTS, that I, GEORGE Street, Newville, Pennsylvania 17241, do by these presents make LORRAINE K. DIAS (hereinafter referred to as "my agent"), my tru a power of attorney, for me and in my name and on my behalf genen matters and things, including, without limiting the generality of the i business, to make, execute, acknowledge, endorse and deliver al certificates of stock, bonds, car titles, releases of lien or satisfaction k contracts, orders, releases, checks, notes and endorsements, transfer. such contracts, specifically including but in no way limited to the e checks or orders of any nature for the withdrawal of funds standing to account in any bank, building and loan association or other financis deposit in any accounts in my name in any such institutions any money payable or belonging to me; to enter my safe deposit boxes in any ai and to establish new safe deposit boxes and to add to and to rem thereof; to borrow money and to mortgage, pledge or hypotheca personal, now or hereafter owned by me as security therefor; to b manage, maintain, improve, lease, mortgage, pledge, encumber, conk of, or take any other action with respect to, any property, real or pe owned by me, on such terms and conditions as my agent may considr event of sale of any of my real estate, to execute the sales agreement r and to make settlement and receive the proceeds; and to prepare, returns, governmental reports and other instruments of whatever kind, any and all writin,3g, assuranops, instruments or documents which may effectuate any matter or thing appertaining or belonging to me. p.7 B. DIAS, of 935 Center constitute and appoint 3 and lawful agent under Ily, to do and perform all oregoing, to transact all deeds of conveyance, fi bonds and mortgages, and assignments of any cecution in my name of my credit in any type of I institution, and also to funds, checks or drafts, d all banking institutions we any of the contents e any property, real or ry, sell possess, insure, y and otherwise dispose rsonal, now or hereafter r appropriate, and In the nd the deed in my name :xecute and file any tax and likewise to execute he mquisite nr proper to I hereby authorize my agent to contract with and arrange or my entrance to any hospital, nursing home, health center, convalescent home, residents I care facility or similar institution, to authorize medical, therapeutic and surgical procedures T r me and to pay all bills in connection therewith. GIVING AND GRANTING unto my agent full authority and pow r to do and perform any and all other acts necessary or incident to the performance and execu Ion of the powers herein expressly granted, with power to do and perform all acts authorized he eby as fully to all intents and purposes and with the same validity as I might or could so if personally present, hereby ratifying and confirming whatsoever all that my agent shall lawfully d or cause to be done by virtue hereof. AND, I hereby declare that any act or thing lawfully done hereunder by my agent shall be binding on myself and my heirs, legal and personal representatives and assigns. AND. If incapacity proceedings for my estate or person are ereafter commenced. I hereby nominate my agent to be appointed the guardian of my estat or person by any court May 17 06 11:45a Lorraine K. Dias 607-936-1619 P.6 having jurisdiction in accordance with the provisions of Section 56 (c ) (2) of the Probate, Estates and Fiduciaries Code. This Power of Attorney shall continue in force and may be aoc anyone or any entity to whom it is presented despite my purported rev until actual written notice of any such event is received by such persor my incapacity from whatever cause, this Power of Attorney shall not shall thereupon become irrevocable and may be accepted and reliec entity to whom It is presented despite such incapacity, subject only to it further effect only upon receipt by such person or entity either of (t appointment of a guardian (or similar fiduciary) of my estate following : or (2) written notice of my death. This Power of Attorney shall subsequent disability or Incapacity. This power of attorney shall rescind and revoke any other made by me. IN WITNESS WHEREOF, I have hereunto set my hand and 2000. W SED BY: COMMONWEALTH OF PENNSYLVANIA :SS: COUNTY OF CUMBERLAND On this, the 24TH day of April, 2000, before me, the under appeared GEORGE B. DIAS, known to me or satisfactorily proven name is subscribed to the within instrument, and acknowledged that I purposes therein contained. 'A NoMdef Se51 Hsob S. erM Ie, Nobrc POIC cadwe am, c dXKWetl came MycammIeson ExPIMS sePL 23, 2002 Membx, PWMY1vmm ru`,pMOlWnof Nolef4ee ipted and relied upon by nation of it or my death, or entity. In the event of thereby be revoked but upon by anyone or any becoming void and of no written evidence of the djudication of incapacity, not be affected by my of attorney previously this 24TH day of April, ned officer, personally be the person whose executed same for the May 17 06 11:45a Lorraine K. Dias 607-936- 1819 p.9 I, LORRAINE K. DIAS, have read the attached Power of Att0ey executed by GEORGE B. DIAS and am the person identified as the Agent for the MRINCIPAL. I hereby acknowledge that in the absence of a specific provision to the contra in the Power of Attorney or in 20 PA. C. S. when I act as Agent: '' I shall exercise the powers for the benefit of the PRINCIPAL. I shall keep the assets of the PRINCIPAL separate from my I shall exercise reasonable caution and prudence. I shall keep a full and accurate record of all actions, receipts behalf of the PRINCIPAL. e April 24, 2000 COMMONWEALTH OF PENNSYLVANIA ; :SS: COUNTY OF CUMBERLAND On this, the 24TH day of April, 2000, before me, the appeared LORRAINE K. DIAS, known to me or satisfactorily name is subscribed to the within acknowledgment and acknoy for the purposes therein contained. WITNESS my hand and seal the day and NMOAdaW Niioltl 8. hwY? 14, NMry Puck Notary GMd0 sm. Cunbefto CmauV CiwgfflWOn WW SWL 23, 2W2 Mo1nhW P°'^+M'A"B '•SSDCM!k!n M.Ndafle! disbursements on igned officer, personally to bq the person :chose that she executed came 09/25/2003 10:13 Sep 24 03 09:59a 7177376763 P.C. Operator PHT 779-e349 % PRESBYTERL-.v HOMES, INC NLTRSLNG CARE ADMISSION :MGR 1. INTRO DUCTIOY PAGE 17 p.1 s AErmconent is a contract between the parties listed below setting for many rights and responsibili- _es of :lee nursiag facility and the resident. L--r.- ;erm case facilities and residents of longterm cart facilities have o er rights and resnonsibiIities unc_: Pennsyivanil law. All of these dt<hrs are not listed below. however w r exmtu that. this or any 0 ?.=- agreement. or nt--=g f iciliry policy, attempts to waive or limit the gal rights of a resident, such t. ;-cmpted waive- or limitadon is uncrforceable and may give rise ro a action against the facility. A..so, to the exrer_r that this Agreement conflicts with any cttzrent qr future provision of law, the law is CL, oiling. Residents of a facility that has been certified to participate in' Medic?e or. edicaid (i.e. the Pennsyiva- niz Medical Assistance Program) have addidotral rights under federal law. r:Ts hese tights generally extend to a csidcnts of a ::cd farlides, whether or not Medicare or Medicaid paying for this care. ? PA?ITIES %e uarties;o this .dye FAX V are: (a) Qd[ (herein "the facility'7. and. (b iii (herein "the resident"; if someone other t:'i the resident is named, in cite that indivicus relationship to the resident, for example, legal g, orattorney-in-fact). T.:e parties to tins Agreement recognize that the facility C=ot require a 140y competent person to des:g_nate an arromey-in-fact or other responsible part' as a condition flora on as a Resident. If a ::silent is nor a paxty to this Agre?men4 the responsible parry is a itiri to enforce all rights per- iai^ting to sesddericr on behalf of the resident and resident is entitled ro The me rights and privileges as accored to fully responsible residents who sign the Admission Agreement 3. MEI)ICAREIMEDICAID CERTIFICATION T:.e facility is cz: fied to participate in the Medicare and Medicaid progra*. Provider participation in the Medicare and/or Medicaid program is subject to termination by the f ty or by the responsible Bove.nmeriml endty. a. CHARGES Et. Covered services: Beginrting on the facility will admit the resident, herein. lituess and until the resident is eligible to have his or her paid for by Medicare or Medicaid. the facility will charge the per diem rate in Attachment for the provision of long term care sert:icts. This charge covers all loom and board, items, uipment and services tea sonably related to the care and treatment of the resident, Payment i due on the 06 day of the month. Charges in addition to room and board arc inciud d in Attachm fit A. {?-,,, ?h ??,? 'flat. will be no charge for any service, equipment or item which i not actually provided to the "'"" reSIG9.^.L b. Changes in charges The °aciiit-i may amend the charges set forth in the preceding sec" n (a(a)) upon thirty (30) days ancior an oral notice to the resident, legal representative (if ne exists) and responsible pa.;; fif or.::xists). ;y Al 0-02 09/25/2003 TH 10:28 [T% ry;,;y 09/25/2003 PHt 10:13 7177376763?g. Pact Le1 349 p•2 Sep 24 03 091588 p.c. Operator e Rebate on dLsc!rarge If the resident is discharged prior to the end of the mmnth, the will provide a pro-rug mfurd of any prepayment for covered services within 30 days of the of dischuge. d. Billing Medicare Payment for tesidents who are Medicare eareilees is aot d e unless and until Medicare has determined that there is no coverage. The facility hereby ackn wledges its legal miponsibility to submit any clamor for payment to the Medicare program if teq ' to do so by or on behalf of the resident. e. Billing Medicaid Residents Payment amounts for residents who are entitled to Medicaid determined by the Pennsylvania DcparrmentofPuhUeWelfam.AnypaytffiatmadetoaMMtsr.i.? f?tyfordiecost ofcam fora private pay resident who is Later found to be eligible far cal Assistants will be tdundcd within Aye(3)days ofnotiBcadonoftesidenteiigibility.T3ep hereto tecogirizedatitisillegal for a Medicaid ecrri$ed facility to charge, solicit, accept orrel ei addi ionaI monies beyond what the Medicaid program deterinines is due, as a condition for S. atpedidng the admission of, or retaining a resident snider Medicaid. The parties recognim that a Medicaid cadecd facility may char for items, equipment or services not reimbursable under the Medicaid program, if the provision such item, equipment or service and the charge therefore is disclosed and agreed to in advatrce, p to law. Medicaid recipients whoart: uncertain whether anitaniorserviccisnotteimbursable the Medicaidprogtamshould contact the Deputrunt of Public Weifarr, Long Term Care C8 Services at (717) 772-2500. f. Obtaining Private Payretent and Public Benefits The facility will assist the resident and orb= acting on behalf at die resident in applying for and obtaining =Ivate insutance and public benefits to cover the cost thn resident's trot The resident epees to cooperate to the best of his or her ability ' any such application g. Interference The parries ac'mowiedge that a Medicaid certified facility may require, in writing of orally, a prormse that a resident will remain in private pay stems orTchain from applying for Medicaid for a specified period of tune. h. Financial Guarantor The parties acknowledge that uttder Pennsylvania law, this A at standing alone is insuffi- cient to legally bind any individual as financial gua:satua for paved hmeutidCr. Any other person signing this nteemont is only obligated to make payment the tesideat't funds and only to the extent Thu those funds are available to such srgirrng n. Therefam if a gttarantat agreement exists, it is anached hereto as Attachment B. S. PROTECTION OF REMIUVr'S PROPERTY The facility will take reasonable steps to prevent the theft or loss of the reodent's property. The resident is not : eauired to deposit personal funds (including, but not 'rod m Social Security and pension checks) with the fa&Xty. If the resident wishes,.however, the factility will hold, safeguard and account for any personal funds deposited with the fatality, in accordance itit sate and federal law. The parties acknowledge that any resident Hinds held by the facility are st state and/or federal law governing access to the turicis, mandatoty posting the scams of said funds. T}re procedure for filing claims for property of the resident which is lost Attachment C. 09/25/2003 to variwrs provisions of erect and reporting on stolen is set forth in 10:26 [TX/RX NO 51531 n'i/'tb/'Lnn3 10:13 Sep 24 03 09169a 7177376763 p,C. Operator PHI 776 (, DISCHARGE OR TRANSFER OF THE RESIDENT FROM THE a. Reasons for Transfer or Discharge The facihry will not discharge or =Asfer the resident froin the h for his or her welfare or that of other tesidcnts, for nonpayment I has made reasonable effors to collet; the debt, or if the taCli:y b. Notice of Transfer or Discharge in the evenr that adischarge ora':rsferis necessary and. exceprin i 30 days advanca written nodce to the resident, to any legal fepre (if one exists) and to other required by law to receive this notice the reason for the wansfer or discharge, the enecdve date of the tra to which the resident will be transferred or discharged. The notice will also set forth any appeal righrs that the resident 1 Wormadon required by state andlor federal law. In the event of give the resident as much notice as is possible under the cscum: ^ p.3 cxceutfor medical reasons, or he» stay after the facility operate. ew cgency, the facilirywill give tntadve, to the responsible parry 110 written notice will set forth sfer or discharge and the location under law and additional emergency, the facility will c. Facility Responsibility for Transfer or Discharge In the event that a aansfer or discharge is ne essaty, the faciity I provide sufflrentprepam- don to assure that the tsnsfe; or discharge is safe and orderly. Tn facttty :s responsible for transferring the resident :o an approoriate level of car. d. Holding the Resident's Bed Lt Pon Transfer 1. HOSPITALIZATION. in the went hat the esident is the facility will hold the resident's bed for up w fifteen day . Medical Assistance eligibio and the faciliry is Medical As ' If the resident is endded to Medicaid benefits for the peal certified under the Medicaid program, the facility will acre payments as payment in 511.,If the resident is not Medical the facility :will ac----pt di. normal per diem listed in Attach 7- THERAFEL?IC LEAVE. In the event the resident is ohs therapeutic leave, the facility will hold the bed upon pavrnc Me dzeal Assistance intez:m per diem rare, or, if the facility i Medical Assistance, upon payment of the per diem rate list If the residentYz entitled to 4edicaid bc.Wits during therap the facility will accept Medicaid bed hold payments (limited tale idar year for skilled care residents and 30 days per railer intcrmediate care residents) as payment in full. The resident beg±ns on the day of Ist dherapeutic leave. 3. NEWT.. AYAII.ABLE BED. In the event the rosidsat and o resident choose not to pay to reserve a bed as set forth in pat the resident is nevertheless ended to the next available bed to return to the facility. 7. TRANSFERS WITFILN THE FACILITY sferr= to a hospital, if the Zsident is ante :etdnod.. and the facility is : Medicaid bed hold ssistance eligible, [cat A, at from the facility on t of the facility's not ce-afled tinder l in Aaachment A. udc leave, to 15 days per year for s calendar year acing on behalf of the ihs (1) and (2), t he/she is ready rat resident will not be transfer ed within the facility exc. t for medical tt ens, for his or her welfare or that of other residents, or with the voiuntary consent of the resident or ;us or he legal representative. In the event of a transfer hereunder. e:.cevr in an emergency, the facility 4 give prompt advance notice to the resident, to the responsible nary (ii one exists), to any legal mpresea dve and to any fitmay mt.IIibc who is known to the faclity, The notice will state the -mson for the transfer, the effective dat0 and the location to witch the resident will be :roved, in the event that a trars:e: within the foci rl is necessary, the facility will pr vide sufr3clenr preparation to assure that the ansferis safe and orde,:y. 09/25/2003 Tll? 10:20 IT%/R% NO 51531 PHI PAU-- ro ny/zo/zeds 10:13 7177376763 778- 949 p•4 Sep 24 03 09;594 P.C. Operator 3. RESIDENT'S RIGHTS The parties recognize that federal and star law guarantee the resident o errights which are not set forth fully in this agreement. The facility agrees to uphold sA of the tights of resident undue federal and state law. Resident rights are included in Attachment D. 9. VISITING HOURS ti504QfX&A.., cl?p1 rkq bd). Visiting hours are open, however the'facility 4:00 pmt) -With h -the'2 $Lratlon in-advaccer?y „ail1 ,,7 10. RESOLVING RESIDENT AND FA,IMMY CONCEIL4' tThe parties recognize the right of the resident to recommend changes in Wiry of the facility to respond to the suggestions of the residents Arm mamrer by which a resident or others acting on behalf bf the resident car the steps which the facility will take to encourage and assist residents in method by which the facility will review and respond to the suggutsrim s: an their behalf. The parries recognize that the Pennsylvania Department of Aging hum i nursingfzeJity in the state. The Otabudsmartmay assist thetesidentorothu in resolving disputes with the facility. 11. REGULATORY AGENCIES The parties recognizc that the facility is licensed by the Department i Pennsylvania Department of Welfare and the HxWth Care binantang mart of Health and Human Services. Both patties recog"i= that reg wnditions of this agecrocnL L» CIVEL RIGHTS COMPLIANCE facility and the respond- E hereto sets forth the suggest changes w she facility, gg their conceW, Stud the f nidents and others acting an Ombudsman to each acting of behalf of the resident Presbyterian Homes' facilities ass: open to all in need of = ssviom and Presbyterians. Also, in accordance with the Federal Civil Rights Act and Relations Act, P.L. 744: This faeiliry has agreed to comply with the provision of the Fodca and the Pennsylvania Saman Relations Act, and allregnisements l to the end that no persons shall on the grounds of race, color. relig ancestry, age, sax, handicap or disability should be wmWded from benefirs of, or otherwise be subject to dls riminadonin the pmvW The noa disc:i?mioataty policy of the institution applies to residem employees, Under no cfrtumstances will the application of this pc of buildings, wings, floors, and moms for reasons of nee, color, n ancestry, age, sex, handicap, or disability. 13. SIGNATURES Adounristrator C3F A?Y..2Qtw't Date or th and is mgularcd by the isnadon o uhf a US_ Depaa- changes may alter the not restricted to Pennsylvania Human tvvil Rigts Act of 1964, oposed putzaamt thereto, ms creed., national origin, attfcipating in, be denied u of any cast or service. , physicians, and all [cy result in the sc;mption igious aced, national origin, Witness (If the dente signs by a made or rs another) 09/25/2003 * 10:26 [T%/Rt NO 51533 T 4 w a f7 r t K N r, L 4 n ri ft? T t ?? r I `i7 POST & SCHELL, P.C. BY: PAULA J. MCDERMOTT I.D. #:46664 12 NORTH SECOND ST., 12TH FLOOR HARRISBURG, PA 17101-1601 (717) 731-1970 PRESBYTERIAN HOMES, INC., ATTORNEYS OR PLAINTIFF PRESBYTERIAN HOMES, INC. IN THE COURTI OF COMMON PLEAS CUMBERLAN COUNTY, Plaintiff, LORRAINE DIAS, as Power-of-Attorney for GEORGE DIAS, CIVIL ACTION LA/W/ ?I NO. ?? - I9tS l lv??JL Defendant. LIS PENDENS TO THE PROTHONOTARY: Kindly impose a Lis Pendens relative to the above-captioned i located at 935 Center Road, Newville, Cumberland County, PA 1 POST & PAULA J. MCI Attorney I.D. # 17 North Front 12th Floor Harrisburg, PA (717) 731-1970 on the property P.C. , ESQUIRE 7101-1601 Attorney for Plai?tiff, Presbyterian Homes, Date: June 2, 2006 Inc. ?? ?- . ,,,, `r , Q p? t``?' W N q v t S7J."'1 ?? -1---? ?' ? ? .?-... `; ` n_ - ? c_ ?,, : , n ? m: ,. .. 1, _: .??'} c, ' ? ,?, ?. ?,: , r --, ? t ? J i ? ;? W ? ;F POST & SCHELL, P.C. BY: PAULA J. MCDERMOTT I.D. #:46664 17 NORTH 2ND STREET, 12TH FLOOR HARRISBURG, PA 17101-1601 (717) 731-1970 PRESBYTERIAN HOMES, INC. Plaintiff, V. GEORGE DIAS, by his Power-of-Attorney, LORRAINE DIAS Defendant. ATTORNEYS FOR PLAINTIFF PRESBYTERIAN HOMES, INC. IN THE COURT OF COMMON PLEAS CUMBERLAND CTY., PENNSYLVANIA NO: 06-3198 CIVIL ACTION - LAW LIS PENDENS TO THE PROTHONOTARY: Kindly impose a Lis Pendens relative to the above-captioned matter on the property located at 935 Center Road, Newville, Cumberland County, PA 17241. POST & SCHELL, P.C. PAULA J. CDERMOTT, ESQUIRE Attorney I.D. # 46664 17 North Front Street 12th Floor Harrisburg, PA 17101-1601 (717) 731-1970 Attorney for Plaintiff, Presbyterian Homes, Date: June 12, 2007 Inc. J *o w ? , ? s