Preview
D9793
- x64
IN THE FRANKLIN COUNTY COURT OF COMMON PLEAS
OHIO DEPARTMENT OF MENTAL
HEALTH
CASE NO. 09 CV 11 16735
Plaintiff,
Judge Sheward
vs.
Plaintiff's Reply Memorandum in Support
WENDY V. SHINGLER, et al of its Motion for Summary Judgment
Defendant. i
PLAINTIFF QHIO DEPARTMENT OF MENTAL HEALTH'S
REPLY MEMORANDUM IN SUPPORT OF ITS MOTION FOR §
JUDGMENT
I. ODMITI’s right to recover its costs is governed by R.C. $121.33 a
which do not incorporate requirements from other statutes.
Plaintiff's right to reimbursement for its costs in supporting Wendy Shingles eed
nw
by R.C. 5121.33 and .34. However, under Defendants” theory, Defendael cage self any
subsection from Revised Code Chapter 5£21. demand proof of compliance. and then allege that
failure to provide proof of compliance is a bar to recovery under R.C. 5121.33 and .34.
Defendants provide no support for this assertion. R.C. $121.33 speaks for itself’ in setting forth
the amounts to be charged. and R.C. 5121.34 sets forth the liable parties for this amount. These
statutes require nothing further for collection.
I. Judge Whitney’s alleged failure to comply with R.C. 5121.50 is an issue for
appeal in the underlying criminal case, not a bar to Plaintiff's recovery.
Defendants assert that Judge Whitney's failure to comply with R.C. 5121.50 in Delaware
County Case 04 CR 1-01-027 is a bar 10 recovery. This assertion fails for two reasons. First.
Defendants provide no support for the assertion that R.C. 5121.50 is requirement before ODMH
can recover its costs. Second. if Judge Whitney made an error of law in this respect, it wasD9793 - x65
incumbent upon criminal defense counsel to raise the issue in the criminal case and appeal any
error. Failure to do so does not provide a waiver from the requirements of R.C. 5121.33 and .34.
Il. Although it is not a requirement to recover under R.C. 5121.33 and 34, the
Department of Mental Health did conduct a financial assessment to determine if
a discounted amount should he charged.
Again Defendants attempt to pull additional requirements into the right of recovery
contained in R.C. 5121.33 and .34 by stating that ODMH must provide evidence of compliance
with R.C. $121.37 before recovering its costs. First. no such requirement exists to collect under
R.C. 5121.33 or 34. Second, ODMII did conduct a financial assessment of the Shinglers and
determined that they were not entitled to a discount (See Exhibit A). Third, under R.C. 5121.37
the department of mental health is not obligated to notily the Shinglers of anything if a discount
is not applied under R.C, 5121.37. Finally, if the Shinglers wanted ODMII to have more
information for its review, R.C. 5121.36 provides the process by which Defendants could have
applied for a discounted rate and supplied additional information to ODMH. They failed to do
so, and in fact according to ODMH records, James Shingler refused to supply requested financial
information (Exhibit A, pp. 2 & 7)
IV. The Ohio Department of Mental Health has made a prima facia showing of the
amount owed in this case, shifting the burden to Defendant to produce rebuttal
evidence.
The Appeals Count in State v. Stuch (1988), 55 Ohio App. 3d 189. faced an identical
issue to the present case where defendant-appellant Frieda Szuch was involuntarily hospitalized
at the Toledo Mental Health Center. Plaintitf-appellee. Ohio Department of Mental Health
Reimbursement Services ("DMHRS"). billed Szuch for the cost her hospitalization. Szuch tiled
suit contesting liability for these expenses and the trial court granted summary judgment in favor
of DMHRS for the hospitalization expenses.D 97 93 - X66
Just as in this case, DMHRS presented as evidence of the applicable rate of support an
authenticated transcript of charges accrued during appellant's hospitalizations. which the Court
determined was “prima facie evidence of a debt.” In presenting an identical argument to the
Defendants in this case. defendant Szuch “without support or documentation of any kind, stated
that these costs were excessive.” /d at 190. In holding for the DMHRS the Court noted that
“[bJecause of appellant's failure to set forth any such facts™ to support the contention that the
costs were excessive “no issue requiring trial has been set forth as to the amount of fees owed.”
Id.
In a similar action to recover costs of care at a state institution. the Appeals Court in
Dept. of Mental Health and Mental Retardation vy. Wiedemann (1980), 1 Ohio App. 3d 27, held
that the "proof of claim" provided by the Department of Mental Health was sufficient evidence
of the facts thercin contained to carry the state's initial burden, then placing on the defendant the
burden to go forward with rebuttal evidence. /d at 28.
Defendants in this case are attempting the same defense presented in Szueh and
Weidemann. Defendants protest the amount being billed in Plaintiffs proof of claim, labeling it
as an “exorbitant sum”, with nothing to back up this assertion.
a. R.C, 5121.32 requires ODMH to determine per-dicm rates for each of its
facilities.
As required by R.C. 5121.32. ODMH has determined the per-diem rates for each of its
facilities. Then, following the statutory requirement in R.C. 5121.33. the Department then
multiplied this rate by the number of days Shingler spent in each facility to reach the amount
stated on the notarized proof of claim and affidavit. It is unclear what more Defendants want in
this case.D9793 - X67
b. ODMH has provided more information to support its claim than what was
held to be sufficient in Szach and Wiedmann.
Finally, the Defendants assert that ODMII's proof of claim is “the only evidence Plaintiff
puts forth” in support of this motion. Defendants ignore the certitied copics of the indictment,
judgment entry on verdicts, warrants for removal. and judgment entry transferring Shingler trom
‘Twin Valley to Ieartland attached to Plaintiff's motion. All of which are more than the proof of
claim which was held sufficient for judgment for the Department of Mental Health in both
Wiedmamnn and Szuch.
Plaintiff ODMH has established Defendants’ liability and the amount owed in this case.
For these reasons, ODMH requesis that its motion for summary judgment be granted.
Respectlully submitted,
"LN COOKE & ASSOC., LLC
Adam Bennett (0077831)
Andrew P. Cooke (0040810)
As Special Counsel for the Attorney General
243 North Fifth Street, Third Floor
Columbus, Ohio 43215
(614) 464-3900 Telephone
(614) 222-4830 Facsimile
Attorneys for PlaintiffODMH
Certificate of Service
‘The undersigned certifies that a true and accurate copy of the foregoing was served upon
the following this_€ day of March, 2010, via regular U.S. Mait.
Richard A.L. Piatt
Saia & Piatt, Inc.
713 South Front St
Columbus. Ohio 43206
L. Din.
Adam Bennett (0077831)vée/(éo/éul0 RL 14:25 FAX 6162224830 Anarew Cooke & AsBOC 1 goo2/
D9793 - X68
County of Franklin =}
i
AFFIDAVIT OF TONYAFASONE | | |
1
lament daneab ad oe
State of Ohio }
The undersigned, being duly cautioned and sworn, hereby certifies that she ihas pestonal
knowledge of the statements and facts alleged in the foregoing paragraphs, ind that the
statements contained therein are true and accurate to the best of her knowledge.
lL. My name is Tonya Fasone, and I serve as Fiscal Manager for the Ohio Department of
Mental Health (“ODMH”). |
2. The attached documents are official records and reports for Wendy Shingler, which are
recorded and filed in the offices of the ODMH. : , |
3. After Wendy Shingler’s admission to Twin Valley Behavioral Healthcare] obM did
not receive requested financial information from the Shinglers, so no discount was applied to the:
|
amount owed. . ; |
4. After Wendy Shingler's transfer to Heartland Behavioral Healthcare, ODMH! conducted a
new financia) assessment and applied a 10% discount after verifying James Shingler’s income.
This discount was applied to the entire balance owed for Shingler’s care at Heartland Behavioral
Healthcare and is reflected in the proof of claim.
1
5. I am a custodian of the attached records which document the ODMH's financial
assessment of the Shinglers. !
ye
7 2 | | 3
o J LU. | ap mt
Tonya Fagone . :
1
I. 4
Sworn fO before me and subscribed before me this Biay of February, 2010, 5 1
PLAINTIFF'S Mand Js ,
EXHIBIT be
] A Q Notary Public "4 CONAAAISS/an3 ep 3-4-2013
6. I certify these documents as authentic.
Further affiant sayeth naught.Feb;26-2010 08:37am = Froa- 1-974 P.003/012 F613
DoySP x60
Master Sheet
10/9/2009 9:16:14
AM Dianna Watts
Proof of Claims requested by Tonya F. done and faxed to AG's office, 1st adm done at per cap, the
second done as billed at modified rate.
iwera009 9:14:12 Dianna Watts
07/08/04 Wage Letter Sent Ji
07/29/04 SENT CHARGES TO INSURANCE CO 06/28/04 ADM TB
01/06/05 INSURANCE FILE CLOSED CLAIM OVER 90 DAYS DUE 06/28/04 ADM TB
01/19/05 INS DENIED 'NO COVERAGE' TB
08-16-05 AG setup adm: 06-28-04 to 06-30-05: $20,894.40. Still Pt. DRW
10-17-05 Liability & wage letter sent, J1
11-10-05 Recd rsp to wg ltr. Sent e-mail to theworknumber.com. Recd wages. Entrd into PCS. SAS
02/22/06 period 5/1/05 to 9/30/05 denied by Anthem (Nationwide) policy not in effect on first date of
service MNK
03/17/06 period 10/3/05-1/3 1/06 ins req. records. Karla is sending to them. mnk
04/17/06 period 10/1/05-10/3/05 Avalon Ins Co denied. Coverage terminated 7/31/04. mnk
06/26/06 Anthem denied appeal for period 1/15/06sp. Not medically necessary. mnk
7/25/06 - adm 10/03/05 - AG setup 10/03/05 to 1/31/06 - $17,195.46 drw
10/9/2009 Dianna Watts
Master Sheet Started
file://C:\Documents and Settings\SteeleS\Local Settings\Temp\FB Viewer\ODMH.FILEBOUND.COMND... 2/25/2014Febr26-2010 08:37am = Frow- 1-974 = P.004/012 F~613
199 PG 332_Thy Fer 25, 2010
OHIO DEPARTMENT OF MENTAL HEALTH 02/25/2010 09:16
COMMENTS SCREEN
PATIENT NAME: SHINGLER, WENDY V PATIENT NUMBER: 737069
10-3-05 PT. INSURANCE TERMINATED ON 7-31-04.
MARRIED AND HAS ONE BYR OLD SON.PT HAS BEEN INDICTED ON
FELONIOUS ASSAULT ATTEMPTED AGG MURDER, ATTEMPTED MURDER,
FELONIOUS ASSAULT,ENDANGERING CHILDREN CASE@04CR-1-01-027.
TALKED TO PT,S SPOUSE WHO JUST BECAME EMPLOYED BY NATIONWIDE
INS AS A CHEIF TECHNOLOGY OFFICER.PATIENT IS UNEMPLOYED AND HAS
BEEN A HOUSEWIFE. PT AND SPOUSE HAVE A HOME VALUED AT $283,500
BY THE DELAWARE CTY AUDITORS OFFICE.SPOUSE REFUSED TO SAY HOW
MUCH THE HOME WAS WORTH OR HOW MUCH HE OWES ON IT.TPQY RETURN
SHOWS NO BENEFITS ON PT.PROCESS INSURANCE FHROUGH SPOUSE.
DATE INITIATED: 06292004 DATE CHANGED: 10132005 SIGNONID: PRSKMUO1
PLEASE KEY IN CHANGES AND PRESS ENTER
P5 {SELECT NEXT PATIENT) F7 {PATIENT MENU}
PRSCROOSFob;26-2010 08:38am = From 1-974 P.005/012F-613
D9793 - X71
“Yb
To verify employment
The Associate should; D
Obtain an authorization code to provide to the verifier by dialing |-800-EMP-
AUTII ( 1-800-367-2884 )
When calling, the associate will need;
The Nationwide company code 10329
Social Security Number
PIN ( the associates PIN is the dollar and cents amount of his/her most recent net
pay. For example, if the associates net pay was $1024.76, the personnal PIN
would be 102476.
The associate should then provide the authorization code to the verifier.
The Verifier should;
Contact “The Work Number” by visiting the Website at
wow theworknumber.com or by calling 1-800-367-5690 ( For TTY, please call 1-
800-424-0253 ) to verify the associates information, The verifier must have the
authorization code before calling or visiting the website in order to obtain
information.
For Customer Service, the associate and/or the verifier can call 1-800-996-7566, Monday
thru Friday from 9am to 8pm.
Den
WindFeb-26-2010 58:30am Froa-
D9793 - X72
r S74 P.008/012 F-613
Aaut Dera Gtoss Pay YIP Catgutaed ingomy
10/2 1/2005 $91,153.87 . $4,192.31
16:06/2005 $86,961.56 $4,192.31
09/22/2005, $62.769.25 4,192.31
5108/2005 878,576.94 94.192.31
08/26/2005 $74,384.63 $4,192.31
0871122005 $70,192.32 4,192.31
7 H2N0R $66.000.02 34,192.31
07/14/7005, $61,807.70 4.192 1
art: 2005 957,015,39 $4,192.32
06/16:2005 $69,423.08 $4,192.33
067022005 $44,230.77 54,192.81
O6/18:2006 945,038.46 #4,192.3),
96012:2005 $40,346.25 $4,192.31
0472112005 $36,653.04 $4,192.31
- 407200 wee 322,461.53 ce 4192.0.
03/25:2008 $28,269.22 $4,094.46
6311172005 $24,230.76 64,038.46
02:26/2005 $20,192.30 55,280.42
vat 200% $16,153.84 4.038.46
01;28/2005 $22,115.38 $4,038.46
0171472006 $8,076.92 94,038.46
B04 20Un $4,038.46
l2s1mz0N4a 950,480.75 4,038.46
72:02;2004 $46,442.20 $4,038.46,
Vinwau04 $42,403.89 $4,088.46
140572004 $48,305.37 $4,038.45
1512232004 $34.326.92 ‘4,038.45
1008/2004 $30,288.45 54,098.46
03/2472004 $26,249.99 84,058.46
09:09/2004 $22,211.53 $8,076.92
08/13/2008 $14.144.61 £4.098.46
07/30/7009 $10,096.15 $4,038.46
0716/2004 $6,057.69 4,038.46
8201/2004 $2,019.23
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www. TeworknuMUar 201 2013 Pages Far Customer Serace
1-000-660-3399 1-800-996-7566Feb>26-2010 08:38am = From- T-974 -P.007/012 = F-613
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Preview
D9793 - x64 IN THE FRANKLIN COUNTY COURT OF COMMON PLEAS OHIO DEPARTMENT OF MENTAL HEALTH CASE NO. 09 CV 11 16735 Plaintiff, Judge Sheward vs. Plaintiff's Reply Memorandum in Support WENDY V. SHINGLER, et al of its Motion for Summary Judgment Defendant. i PLAINTIFF QHIO DEPARTMENT OF MENTAL HEALTH'S REPLY MEMORANDUM IN SUPPORT OF ITS MOTION FOR § JUDGMENT I. ODMITI’s right to recover its costs is governed by R.C. $121.33 a which do not incorporate requirements from other statutes. Plaintiff's right to reimbursement for its costs in supporting Wendy Shingles eed nw by R.C. 5121.33 and .34. However, under Defendants” theory, Defendael cage self any subsection from Revised Code Chapter 5£21. demand proof of compliance. and then allege that failure to provide proof of compliance is a bar to recovery under R.C. 5121.33 and .34. Defendants provide no support for this assertion. R.C. $121.33 speaks for itself’ in setting forth the amounts to be charged. and R.C. 5121.34 sets forth the liable parties for this amount. These statutes require nothing further for collection. I. Judge Whitney’s alleged failure to comply with R.C. 5121.50 is an issue for appeal in the underlying criminal case, not a bar to Plaintiff's recovery. Defendants assert that Judge Whitney's failure to comply with R.C. 5121.50 in Delaware County Case 04 CR 1-01-027 is a bar 10 recovery. This assertion fails for two reasons. First. Defendants provide no support for the assertion that R.C. 5121.50 is requirement before ODMH can recover its costs. Second. if Judge Whitney made an error of law in this respect, it wasD9793 - x65 incumbent upon criminal defense counsel to raise the issue in the criminal case and appeal any error. Failure to do so does not provide a waiver from the requirements of R.C. 5121.33 and .34. Il. Although it is not a requirement to recover under R.C. 5121.33 and 34, the Department of Mental Health did conduct a financial assessment to determine if a discounted amount should he charged. Again Defendants attempt to pull additional requirements into the right of recovery contained in R.C. 5121.33 and .34 by stating that ODMH must provide evidence of compliance with R.C. $121.37 before recovering its costs. First. no such requirement exists to collect under R.C. 5121.33 or 34. Second, ODMII did conduct a financial assessment of the Shinglers and determined that they were not entitled to a discount (See Exhibit A). Third, under R.C. 5121.37 the department of mental health is not obligated to notily the Shinglers of anything if a discount is not applied under R.C, 5121.37. Finally, if the Shinglers wanted ODMII to have more information for its review, R.C. 5121.36 provides the process by which Defendants could have applied for a discounted rate and supplied additional information to ODMH. They failed to do so, and in fact according to ODMH records, James Shingler refused to supply requested financial information (Exhibit A, pp. 2 & 7) IV. The Ohio Department of Mental Health has made a prima facia showing of the amount owed in this case, shifting the burden to Defendant to produce rebuttal evidence. The Appeals Count in State v. Stuch (1988), 55 Ohio App. 3d 189. faced an identical issue to the present case where defendant-appellant Frieda Szuch was involuntarily hospitalized at the Toledo Mental Health Center. Plaintitf-appellee. Ohio Department of Mental Health Reimbursement Services ("DMHRS"). billed Szuch for the cost her hospitalization. Szuch tiled suit contesting liability for these expenses and the trial court granted summary judgment in favor of DMHRS for the hospitalization expenses.D 97 93 - X66 Just as in this case, DMHRS presented as evidence of the applicable rate of support an authenticated transcript of charges accrued during appellant's hospitalizations. which the Court determined was “prima facie evidence of a debt.” In presenting an identical argument to the Defendants in this case. defendant Szuch “without support or documentation of any kind, stated that these costs were excessive.” /d at 190. In holding for the DMHRS the Court noted that “[bJecause of appellant's failure to set forth any such facts™ to support the contention that the costs were excessive “no issue requiring trial has been set forth as to the amount of fees owed.” Id. In a similar action to recover costs of care at a state institution. the Appeals Court in Dept. of Mental Health and Mental Retardation vy. Wiedemann (1980), 1 Ohio App. 3d 27, held that the "proof of claim" provided by the Department of Mental Health was sufficient evidence of the facts thercin contained to carry the state's initial burden, then placing on the defendant the burden to go forward with rebuttal evidence. /d at 28. Defendants in this case are attempting the same defense presented in Szueh and Weidemann. Defendants protest the amount being billed in Plaintiffs proof of claim, labeling it as an “exorbitant sum”, with nothing to back up this assertion. a. R.C, 5121.32 requires ODMH to determine per-dicm rates for each of its facilities. As required by R.C. 5121.32. ODMH has determined the per-diem rates for each of its facilities. Then, following the statutory requirement in R.C. 5121.33. the Department then multiplied this rate by the number of days Shingler spent in each facility to reach the amount stated on the notarized proof of claim and affidavit. It is unclear what more Defendants want in this case.D9793 - X67 b. ODMH has provided more information to support its claim than what was held to be sufficient in Szach and Wiedmann. Finally, the Defendants assert that ODMII's proof of claim is “the only evidence Plaintiff puts forth” in support of this motion. Defendants ignore the certitied copics of the indictment, judgment entry on verdicts, warrants for removal. and judgment entry transferring Shingler trom ‘Twin Valley to Ieartland attached to Plaintiff's motion. All of which are more than the proof of claim which was held sufficient for judgment for the Department of Mental Health in both Wiedmamnn and Szuch. Plaintiff ODMH has established Defendants’ liability and the amount owed in this case. For these reasons, ODMH requesis that its motion for summary judgment be granted. Respectlully submitted, "LN COOKE & ASSOC., LLC Adam Bennett (0077831) Andrew P. Cooke (0040810) As Special Counsel for the Attorney General 243 North Fifth Street, Third Floor Columbus, Ohio 43215 (614) 464-3900 Telephone (614) 222-4830 Facsimile Attorneys for PlaintiffODMH Certificate of Service ‘The undersigned certifies that a true and accurate copy of the foregoing was served upon the following this_€ day of March, 2010, via regular U.S. Mait. Richard A.L. Piatt Saia & Piatt, Inc. 713 South Front St Columbus. Ohio 43206 L. Din. Adam Bennett (0077831)vée/(éo/éul0 RL 14:25 FAX 6162224830 Anarew Cooke & AsBOC 1 goo2/ D9793 - X68 County of Franklin =} i AFFIDAVIT OF TONYAFASONE | | | 1 lament daneab ad oe State of Ohio } The undersigned, being duly cautioned and sworn, hereby certifies that she ihas pestonal knowledge of the statements and facts alleged in the foregoing paragraphs, ind that the statements contained therein are true and accurate to the best of her knowledge. lL. My name is Tonya Fasone, and I serve as Fiscal Manager for the Ohio Department of Mental Health (“ODMH”). | 2. The attached documents are official records and reports for Wendy Shingler, which are recorded and filed in the offices of the ODMH. : , | 3. After Wendy Shingler’s admission to Twin Valley Behavioral Healthcare] obM did not receive requested financial information from the Shinglers, so no discount was applied to the: | amount owed. . ; | 4. After Wendy Shingler's transfer to Heartland Behavioral Healthcare, ODMH! conducted a new financia) assessment and applied a 10% discount after verifying James Shingler’s income. This discount was applied to the entire balance owed for Shingler’s care at Heartland Behavioral Healthcare and is reflected in the proof of claim. 1 5. I am a custodian of the attached records which document the ODMH's financial assessment of the Shinglers. ! ye 7 2 | | 3 o J LU. | ap mt Tonya Fagone . : 1 I. 4 Sworn fO before me and subscribed before me this Biay of February, 2010, 5 1 PLAINTIFF'S Mand Js , EXHIBIT be ] A Q Notary Public "4 CONAAAISS/an3 ep 3-4-2013 6. I certify these documents as authentic. Further affiant sayeth naught.Feb;26-2010 08:37am = Froa- 1-974 P.003/012 F613 DoySP x60 Master Sheet 10/9/2009 9:16:14 AM Dianna Watts Proof of Claims requested by Tonya F. done and faxed to AG's office, 1st adm done at per cap, the second done as billed at modified rate. iwera009 9:14:12 Dianna Watts 07/08/04 Wage Letter Sent Ji 07/29/04 SENT CHARGES TO INSURANCE CO 06/28/04 ADM TB 01/06/05 INSURANCE FILE CLOSED CLAIM OVER 90 DAYS DUE 06/28/04 ADM TB 01/19/05 INS DENIED 'NO COVERAGE' TB 08-16-05 AG setup adm: 06-28-04 to 06-30-05: $20,894.40. Still Pt. DRW 10-17-05 Liability & wage letter sent, J1 11-10-05 Recd rsp to wg ltr. Sent e-mail to theworknumber.com. Recd wages. Entrd into PCS. SAS 02/22/06 period 5/1/05 to 9/30/05 denied by Anthem (Nationwide) policy not in effect on first date of service MNK 03/17/06 period 10/3/05-1/3 1/06 ins req. records. Karla is sending to them. mnk 04/17/06 period 10/1/05-10/3/05 Avalon Ins Co denied. Coverage terminated 7/31/04. mnk 06/26/06 Anthem denied appeal for period 1/15/06sp. Not medically necessary. mnk 7/25/06 - adm 10/03/05 - AG setup 10/03/05 to 1/31/06 - $17,195.46 drw 10/9/2009 Dianna Watts Master Sheet Started file://C:\Documents and Settings\SteeleS\Local Settings\Temp\FB Viewer\ODMH.FILEBOUND.COMND... 2/25/2014Febr26-2010 08:37am = Frow- 1-974 = P.004/012 F~613 199 PG 332_Thy Fer 25, 2010 OHIO DEPARTMENT OF MENTAL HEALTH 02/25/2010 09:16 COMMENTS SCREEN PATIENT NAME: SHINGLER, WENDY V PATIENT NUMBER: 737069 10-3-05 PT. INSURANCE TERMINATED ON 7-31-04. MARRIED AND HAS ONE BYR OLD SON.PT HAS BEEN INDICTED ON FELONIOUS ASSAULT ATTEMPTED AGG MURDER, ATTEMPTED MURDER, FELONIOUS ASSAULT,ENDANGERING CHILDREN CASE@04CR-1-01-027. TALKED TO PT,S SPOUSE WHO JUST BECAME EMPLOYED BY NATIONWIDE INS AS A CHEIF TECHNOLOGY OFFICER.PATIENT IS UNEMPLOYED AND HAS BEEN A HOUSEWIFE. PT AND SPOUSE HAVE A HOME VALUED AT $283,500 BY THE DELAWARE CTY AUDITORS OFFICE.SPOUSE REFUSED TO SAY HOW MUCH THE HOME WAS WORTH OR HOW MUCH HE OWES ON IT.TPQY RETURN SHOWS NO BENEFITS ON PT.PROCESS INSURANCE FHROUGH SPOUSE. DATE INITIATED: 06292004 DATE CHANGED: 10132005 SIGNONID: PRSKMUO1 PLEASE KEY IN CHANGES AND PRESS ENTER P5 {SELECT NEXT PATIENT) F7 {PATIENT MENU} PRSCROOSFob;26-2010 08:38am = From 1-974 P.005/012F-613 D9793 - X71 “Yb To verify employment The Associate should; D Obtain an authorization code to provide to the verifier by dialing |-800-EMP- AUTII ( 1-800-367-2884 ) When calling, the associate will need; The Nationwide company code 10329 Social Security Number PIN ( the associates PIN is the dollar and cents amount of his/her most recent net pay. For example, if the associates net pay was $1024.76, the personnal PIN would be 102476. The associate should then provide the authorization code to the verifier. The Verifier should; Contact “The Work Number” by visiting the Website at wow theworknumber.com or by calling 1-800-367-5690 ( For TTY, please call 1- 800-424-0253 ) to verify the associates information, The verifier must have the authorization code before calling or visiting the website in order to obtain information. For Customer Service, the associate and/or the verifier can call 1-800-996-7566, Monday thru Friday from 9am to 8pm. Den WindFeb-26-2010 58:30am Froa- D9793 - X72 r S74 P.008/012 F-613 Aaut Dera Gtoss Pay YIP Catgutaed ingomy 10/2 1/2005 $91,153.87 . $4,192.31 16:06/2005 $86,961.56 $4,192.31 09/22/2005, $62.769.25 4,192.31 5108/2005 878,576.94 94.192.31 08/26/2005 $74,384.63 $4,192.31 0871122005 $70,192.32 4,192.31 7 H2N0R $66.000.02 34,192.31 07/14/7005, $61,807.70 4.192 1 art: 2005 957,015,39 $4,192.32 06/16:2005 $69,423.08 $4,192.33 067022005 $44,230.77 54,192.81 O6/18:2006 945,038.46 #4,192.3), 96012:2005 $40,346.25 $4,192.31 0472112005 $36,653.04 $4,192.31 - 407200 wee 322,461.53 ce 4192.0. 03/25:2008 $28,269.22 $4,094.46 6311172005 $24,230.76 64,038.46 02:26/2005 $20,192.30 55,280.42 vat 200% $16,153.84 4.038.46 01;28/2005 $22,115.38 $4,038.46 0171472006 $8,076.92 94,038.46 B04 20Un $4,038.46 l2s1mz0N4a 950,480.75 4,038.46 72:02;2004 $46,442.20 $4,038.46, Vinwau04 $42,403.89 $4,088.46 140572004 $48,305.37 $4,038.45 1512232004 $34.326.92 ‘4,038.45 1008/2004 $30,288.45 54,098.46 03/2472004 $26,249.99 84,058.46 09:09/2004 $22,211.53 $8,076.92 08/13/2008 $14.144.61 £4.098.46 07/30/7009 $10,096.15 $4,038.46 0716/2004 $6,057.69 4,038.46 8201/2004 $2,019.23 SA A www. 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