HomeMy WebLinkAbout07-0546
LIEDERBACH, HAHN, FOY & VAN BLUNK, P.C.
HENRY E. VAN BLUNK, ESQUIRE I.D. No. 70751
TYLER TOMLINSON, ESQUIRE I.D. No.: 76678
KENNETH FERRIS, ESQUIRE I.D. NO.: 92335
892 Second Street - Ste. C
Richboro, PA 18954-1005
(215) 322-8300 Attorneys for Plaintiff
Arden Seven Penn Partners, LP Court of Common Pleas
Seven Penn Center Cumberland County, Pennsylvania
1635 Market Street, 17"' Floor
Philadelphia, PA 19103
Plaintiff
V.
Mylotte, David & Fitzpatrick
Whetstone Run Office Complex
450 Parkway, Suite 300
Broomall, PA 19008
Defendant
Docket No.: 07-5'q6' Praecipe to Transfer Judgment
TO TEE PROTHONOTARY:
Please enter this Praecipe to transfer the judgment against Mylotte, DaN-id & Pitzpatric':<
from Philadelphia County, Pennsylvania to Cumberland County, Pennsylvania. 1, certified copy
of th,- Philadelphia County Docket and Judgment is attached hereto as E tA6A
LIEDERBACH, HAIIN,
FOY &VA fNK, P.C.
By-,
1)ate?1: J near%, 26, '200
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- Y 1.. dAN I3L,UNK, ESQUiI21:
T ' ?ER'FO1Vfl-INSON. ESQUIRE:
EN`rE IH FERRP_ SQUIRE
Attorneys for Plaintiff,
Arden Seven Penn Partners, LP
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. PAGE' 1
REPORT : ZDRDOCT First Judicial District RUN DATE 01/22/07
USER ID: COS CIVIL DOCKET REPORT RUN TIME 09:14 AM
CASE ID 050401545
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CASE NUMBER CASE CAPTION
050401545 ARDEN SEVEN PENN PARTNERS LP VS MYLOTTE DAVID&FITZ
FILING DATE COURT LOCATION JURY
13-APR-2005 NE CH N
CASE TYPE: CONTRACTS (GOODS), ENFORCE
STATUS: JUDGMENT ENTERED
Seq # Assoc Expn Date Type ID Party Name / Address & Phone No.
1 APLF A82205 ADLER, MICHAEL
BLANK ROME LLP
ONE LOGAN SQUARE
PHILADELPHIA PA 19103
(215)569-5323
(215)832-5323 - FAX
2 1 PLF @5195405 ARDEN SEVEN PENN PARTNERS LP
SEVEN PENN CENTER
1635 MARKET ST 17TH FL
PHILADELPHIA PA 19103
3 5 DFT @5195410 MYLOTTE DAVID&FITZPATRICK
WHETSTONE RUN OFFICE COMPLEX
450 PARKWAY SUITE 300
BROOMALL PA 19008
4 TL J289 SHEPPARD, JR., ALBERT W
529 CITY HALL
PHILADELPHIA PA 19107
(215)686-7934
(215)686-3717 - FAX
5 ADFT A2745 DAVID, EDWARD J
MYLOTTE DAVID & FITZPATRICK
WHETSTONE RUN OFFICE COMPLEX
450 PARKWAY, SUITE 300
BROOMALL PA 19008
(610)946-0572
(610)946-0588 - FAX
6 1 APLF A86258 CHERICO, COLIN M
BLANK ROME LLP
ONE LOGAN SQUARE
PHILADELPHIA PA 19103
(215)569-5316
(215)832-5376 - FAX
7 1 APLF A82871 HYMOWITZ, CRAIG L
PAGE 2
REPORT : ZDRDOCT' First Judicial District RUN DATE 01/22/07
USER ID: COS CIVIL DOCKET REPORT RUN TIME 09:14 AM
CASE ID 050401545
Seq # Assoc Expn Date Type ID Party Name / Address & Phone No
ONE LOGAN SQ
BLANK ROME COMISKY&MCCAULEY
PHILADELPHIA PA 19103
(215)569-5345
Filing Date / Time Docket Entry Date Entered
13-APR-05 13:36:53 ACTIVE CASE 13-APR-05
13-APR-05 13:44:11 COMMENCEMENT OF CIVIL ACTION 13-APR-05
ADLER, MICHAEL
13-APR-05 13:44:11 SHERIFF'S SURCHARGE 1 DEFT 13-APR-05
ADLER, MICHAEL
13-APR-05 13:44:11 WAITING TO LIST CASE MGMT CONF 13-APR-05
13-APR-05 13:44:11 COMPLAINT FILED NOTICE GIVEN 13-APR-05
ADLER, MICHAEL
COMPLAINT WITH NOTICE TO DEFEND WITHIN TWENTY (20) DAYS
AFTER SERVICE IN ACCORDANCE WITH RULE 1018.1 FILED.
31-MAY-05 13:49:26 LISTED FOR CASE MGMT CONF 31-MAY-05
02-JUN-05 00:02:17 NOTICE GIVEN 02-JUN-05
29-JUN-05 14:50:00 ENTRY OF APPEARANCE FILED 30-JUN-05
DAVID, EDWARD J
ENTRY OF APPEARANCE OF EDWARD J DAVID ESQ FILED ON
BEHALF OF DFTS MYLOTTE, DAVID AND FITZPATRICK.
02-JUL-05 00:01:25 NOTICE GIVEN 02-JUL-05
29-JUL-05 10:48:05 CASE MGMT CONFERENCE COMPLETED 29-JUL-05
SHEPPARD, JR., ALBERT W
29-JUL-05 10:48:05 CASE MANAGEMENT ORDER ISSUED 29-JUL-05
IN THE COURT OF COMMON PLEAS OF PHILADELPHIA
COUNTY FIRST JUDICIAL DISTRICT OF
PENNSYLVANIA CIVIL TRIAL
DIVISION ARDEN SEVEN PENN PARTNERS LP VS MYLOTTE
050401545
COMMERCE PROGRAM CASE
MANAGEMENT ORDER EXPEDITED
TRACK AND NOW, 29-JUL-2005, it is Ordered that:
1. The case management and time standards adopted
for commerce program, expedited track cases shall
apply and are hereby incorporated into this Order.
2. All discovery on the above matter shall be
completed not later than 05-DEC-2005. 3.
Plaintiff shall identify and submit curriculum vitae
and expert reports for all expert witnesses intended
PAGE' 3
REPORT : ZDRDOCT' First Judicial District RUN DATE 01/22/07
USER ID: COS CIVIL DOCKET REPORT RUN TIME 09:14 AM
CASE ID 050401545
Filing Date / Time Docket Entry Date Entered
to testify at trial to all other parties not later
than 05-DEC-2005. 4. Defendant(s) and any
additional defendant(s) shall identify and submit
curriculum vitae and expert reports for all expert
witnesses intended to testify at trial not later than
03-JAN-2006. 5. All pre-trial motions (other
than motions in limine) shall be filed not later than
17-JAN-2006. 6. A settlement conference may be
scheduled at any time after 06-MAR-2006. On or before
that date all counsel shall serve all opposing counsel
and file a settlement memorandum containing the
following: (a) The plaintiff(s)shall provide a
concise statement of the theory of the case. The
defendant(s) and additional defendant(s) shall provide
a concise statement as to the nature of the defense.
(b) A statement by the plaintiff(s) itemizing all
damages sought by categories and amount; (c)
Defendant(s) and additional defendant(s) shall
identify all applicable insurance carriers, together
with corresponding limits of liability. 7. A
pre-trial conference will be scheduled any time after
03-APR-2006. Fifteen days prior to pre-trial
conference, all counsel shall serve all opposing
counsel or pro se parties and file a pre-trial
memorandum containing the following: (a)
The plaintiff(s) shall provide a concise statement of
the theory of the case. The defendant(s) and
additional defendant(s) shall provide a concise
statement as to the nature of the defense; (b)
A list of all witnesses who may be called to testify
at trial by name and address. Counsel should expect
witnesses not listed to be precluded from testifying
at trial; (c) A list of all exhibits the party
intends to offer into evidence. All exhibits shall be
numbered and exchanged among counsel prior to the
conference. Counsel should expect any exhibit not
listed to be precluded at trial; (d) Plaintiff
shall itemize all damages claimed by category and
amount; (e) Defendant(s) and additional
defendant(s) shall state a position regarding damages
claimed and shall identify all applicable insurance
carriers, together with applicable limits of
liability; and, (f) An estimate of the
anticipated length of trial. 8. It is expected
that the case will be ready for trial 01-MAY-2006,
which is the earliest date pursuant to Pa.R.C.P.
212.1, and counsel should anticipate trial to begin
expeditiously thereafter. 9. All counsel are
under a continuing obligation and are hereby Ordered
to serve a copy of this Order upon all unrepresented
parties and upon all counsel entering an appearance
subsequent to the entry of this Order.
REPORT : ZDRDOCT' . PAGE` 4
First Judicial District RUN DATE 01/22/07
USER ID: COS CIVIL DOCKET REPORT RUN TIME 09:14 AM
CASE ID 050401545
Filing Date / Time Docket Entry
Date Entered
BY THE COURT:
ALBERT SHEPPARD, JR., J.
TEAM LEADER
29-JUL-05 10:48:05 LISTED FOR SETTLEMENT CONF 29-JUL-05
29-JUL-05 10:48:06 LISTED FOR TRIAL 29-JUL-05
29-NOV-05 15:14:46 ORDER ENTERED/236 NOTICE GIVEN 29-NOV-05
SHEPPARD, JR., ALBERT W
AND NOW, THIS 28TH DAY OF NOVEMBER, 2005 UPON
CONSIDERATION OF THE MOTION OF PLAINTIFF ARDEN SEVEN
PENN PARTNERS, L.P. TO COMPEL RESPONSES TO
INTERROGATORIES AND REQUESTS FOR PRODUCTION OF
DOCUMENTS FROM DEFENDANT MYLOTTE, DAVID & FITZPATRICK
PURSUANT TO PA.R.CIV. P. 4019 ("THE MOTION TO COMPEL")
AND ANY RESPONSE THERETO, IT IS HEREBY ORDERED AND
DECREED THAT THE MOTION TO COMPEL IS GRANTED.
DEFENDANT MYLOTTE SHALL PROVIDE FULL AND COMPLETE
RESPONSES TO THE DISCOVERY REQUESTS, WITHOUT
OBJECTION, WITHIN TWENTY (20) DAYS OF THIS ORDER, OR
SUFFER SANCTIONS UPON FURTHER APPLICATION TO THE
COURT .... BY THE COURT: SHEPPARD, J. 11-28-05
29-NOV-05 15:23:37 ORDER ENTERED/236 NOTICE GIVEN 29-NOV-05
SHEPPARD, JR., ALBERT W
AND NOW, THIS 28TH DAY OF NOVEMBER, 2005, UPON
CONSIDERATION OF THE MOTION OF PLAINTIFF ARDEN SEVEN
PENN PARTNERS, L.P. TO COMPEL RESPONSES TO
INTERROGATORIES AND REQUESTS FOR PRODUCTION OF
DOCUMENTS FROMD EFENDANT MYLOTTE, DAVID & FITZPATRICK
PURSUANT TO PA.R.CIV.P. 4019 ("THE MOTION TO COMPEL")
AND ANY RESPONSE THERETO, IT IS HEREBY ORDERED AND
DECREED THAT THE MOTION TO COMPEL IS GRANTED.
DEFENDANT MYLOTTE SHALL PROVIDE FULL AND COMPLETE
RESPONSES TO THE DISCOVERY REQUESTS, WITHOUT OBJECTION
WITHIN TWENTY (20) DAYS OF THIS ORDER, OR SUFFER
SANCTIONS UPON FURTHER APPLICAITON TO THE COURT ..... BY
THE COURT: SHEPPARD, J 11-28-05
27-FEB-06 09:30:19 CONFERENCE DATE SET 27-FEB-06
SHEPPARD, JR., ALBERT W
27-FEB-06 09:31:58 LISTED FOR SETTLEMENT CONF 27-FEB-06
27-FEB-06 10:49:09 CASE RESCHEDULED BY COURT 27-FEB-06
SHEPPARD, JR., ALBERT W
27-FEB-06 10:50:00 LISTED FOR SETTLEMENT CONF 27-FEB-06
REPORT ZDRDOCT'
USER ID: COS
First Judicial District PAGk 5
RUN DATE 01/22/07
CIVIL DOCKET REPORT RUN TIME 09:14 AM
CASE ID 050401545
Filing Date / Time Docket Entry
Date Entered
01-MAR-06 00:01:31 NOTICE GIVEN
O1-MAR-06
20-MAR-06 10:43:57 CASE RESCHEDULED BY COURT
20-MAR-06
SETTLEMENT CONF OF 3/17/06 IS RESCHEDULED TOB4/11/06TQHELL L
10:30
20-MAR-06 10:45:06 LISTED FOR SETTLEMENT CONF
20-MAR-06
22-MAR-06 00:01:12 NOTICE GIVEN
22-MAR-06
22-MAR-06 13:20:17 CASE RESCHEDULED BY COURT
22-MAR-06
PER LETTER OF MITCHELL BACH SETTLEM ENT CONF BSCH, MITCHELL L
RESCHEDULED TO 4/14/06 @ 10:30
22-MAR-06 13:25:27 LISTED FOR SETTLEMENT CONF
22-MAR-06
24-MAR-06 00:01:23 NOTICE GIVEN
24-MAR-06
03-AUG-06 16:05:11 WAITING TO LIST PRE-TRIAL CONF
03-AUG-06
SHEPPARD, JR., ALBERT W
03-AUG-06 16:05:15 SETTLEMENT CONF COMPLETED
03-AUG-06
SETTLEMENT CONF OF 4/13/06 IS COMPLETED BACH, MITCHELL L
03-AUG-06 16:08:44 LISTED FOR PRE-TRIAL CONF
03-AUG-06
05-AUG-06 00:01:14 NOTICE GIVEN
05-AUG-06
17-AUG-06 16:31:23 ENTRY OF APPEARANCE-CO COUNSEL
18-AUG-06
ENTRY OF APPEARANCE OCOLIN M. CHERI
CO,
ALFOLIN M
CO FILEDCONRBEH
OF PLAINTIFF.
22-AUG-06 00:01:12 NOTICE GIVEN
22-AUG-06
25-AUG-06 13:35:00 ENTRY OF APPEARANCE FILED
28-AUG-06
ENTRY OF APPEARANCE OF CRAIG HYMOWITZ FILEDHONOBEHALFCRAIG L
OF PLF.
28-AUG-06 12:34:00 PRETRIAL CONFERENCE COMPLETED
28-AUG-06
SHEPPARD, JR., ALBERT W
28-AUG-06 12:34:06 WAITING TO LIST FOR TRIAL
28-AUG-06
SHEPPARD, JR., ALBERT W
28-AUG-06 12:35:05 LISTED FOR TRIAL
ONE DAY NON JURY TRIAL SCHEDULED FOR 9/21/06 AT 9:308AMUG-06
IN COURTROOM 513 CITY HALL.
REPORT ZDRDOCT'
USER ID: COS
First Judicial District
CIVIL DOCKET REPORT
CASE ID 050401545
' PAGE 6
RUN DATE 01/22/07
RUN TIME 09:14 AM
Filing Date / Time Docket Entry
28-AUG-06 12:41:57 STATUS RESPONSE RECEIVED
SHEPPARD,
STATUS REPORT RECEIVED AUGUST 15, 2006.
Date Entered
28-AUG-06
JR., ALBERT W
28-AUG-06 12:43:41 CORRECTIVE ENTRY 28-AUG-06
STATUS RESPONSE RECEIVED INCORRECTLY DOCKETED ON THIS
CASE.
30-AUG-06 00:01:07 NOTICE GIVEN
30-AUG-06
20-SEP-06 11:20:29 CASE RESCHEDULED BY COURT 20-SEP-06
SHEPPARD, JR., ALBERT W
20-SEP-06 11:21:20 LISTED FOR TRIAL 20-SEP-06
ONE DAY NON JURY TRIAL RESCHEDULED TO 10/20/06 AT 9:30
AM IN COURTROOM 513 CITY HALL.
22-SEP-06 00:01:11 NOTICE GIVEN 22-SEP-06
20-OCT-06 12:22:54 WAITING TO LIST STATUS CONF 20-OCT-06
SHEPPARD, JR., ALBERT W
TRIAL CONTINUED. STATUS HEARING SCHEDULED FOR 1/9/07
AT 9:30 AM IN COURTROOM 513 CITY HALL.
20-OCT-06 12:24:01 LISTED FOR STATUS CONFERENCE 20-OCT-06
24-OCT-06 00:01:09 NOTICE GIVEN 24-OCT-06
09-JAN-07 11:47:21 JUDGMENT ENTERED 377,000.00 09-JAN-07
SHEPPARD, JR., ALBERT W
UPON CONSIDERATION OF ALL MATTERS OF RECORD AND THE
LISTING OF THIS MATTER FOR TRIAL AND IT APPEARING THAT
THE DEFENDANT DOES NOT HAVE A DEFENSE, IT IS ORDERED
THAT A JUDGMENT IN FAVOR OF PLAINTIFF AND AGAINST THE
DEFENDANT IN THE AMOUNT OF $377,000.00 BE ENTERED OF
RECORD. BY THE COURT .... SHEPPARD, JR., J. 1/9/07
09-JAN-07 11:47:22 NOTICE GIVEN UNDER RULE 236 09-JAN-07
* * * End of Docket * * *
Judgment certified in the amount of $377,000.00
CERTIFIED FROM THE RECORD ON JAN 2 2 2001
JOSEPH H. EVERS
PROT 0 TARY OF PHILAD , HIA COUNTY
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LIEDERBACH, HAHN, FOY & VAN BLUNK, P.C.
HENRY E. VAN BLUNK, ESQUIRE I.D. No. 70751
TYLER TOMLINSON, ESQUIRE I.D. No.: 76678
KENNETH FERRIS, ESQUIRE I.D. NO.: 92335
892 Second Street - Ste. C
Richboro, PA 18954-1005
(215) 322-8300 Attorneys for Plaintiff
Arden Seven Penn Partners, LP Court of Common Pleas
Seven Penn Center Cumberland County, Pennsylvania
1635 Market Street, 17`h Floor
Philadelphia, PA 19103
Plaintiff
V.
Mylotte, David & Fitzpatrick
Whetstone Run Office Complex
450 Parkway, Suite 300
Broomall, PA 19008
Defendant
And
Pennsylvania Medical Society
Liability Insurance Company
1700 Bent Creek Boulevard
Mechanicsburg, PA 17050-1865
Garnishee
Docket No.: 0 ?- 5Y? C6qj 7;il
PRAECIPE FOR WRIT OF EXECUTION - MONEY JUDGMENTS
TO THE PROTHONOTARY:
ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER.
(1) Directed to the Sheriff of Cumberland Count PA,
(2) against Mylotte, David & Fitzpatrick. Defendant(s);
(3) and against Pennsylvania Medical Society Liability Insurance Company, 1700 Bent Creek
Boulevard, Mechanicsburg, PA 17050-1865 Garnishee(s);
(4) and index this writ
(A) against Mylotte, David & Fitzpatrick Defendant(s)
(B) and against Pennsylvania Medical Society Liability Insurance Company
Garnishee(s),
t
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as a lis pendens against the real property of the defendant(s) in the name of the garnishee(s).
Specifically describe the property per attached property description:
(5) Amount Due: $377,000.00
Interest From:
Attorneys' Fees
Total:
$377,000.00
T er Tomlinson, Esquire
"Print Name
I.D. No. 76678
892 Second Street Pike, Suite C
Richboro, PA 18954
Address
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N007-546 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due Arden Seven Penn Partners, LP Seven Penn Center 1635
Market Street, 17`h Floor, Philadelphia, Pa. 19103 Plaintiff (s)
From Mylotte, David & Fitzpatrick Whetsone Run Office Complex 450 Parkway Suite 300,
Broomall, Pa. 19008
(1) You are directed to levy upon the property of the defendant (s)and to sell .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of Pennsylvnia Medical Society Liability Insurance Company 1700 Bent Creek Boulevard,
Mechanicsburg, Pa. 17050
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $377,000.00
Interest
Atty's Comm %
Atty Paid $ 38.00
Plaintiff Paid
Date: January 29, 2007
L.L.$ 0.50
Due Prothy $1.00
Other Costs
i3/ c'r"
C is R. Long, Prothonotary
(Seal)
By:
Deputy
REQUESTING PARTY:
Name Tyler Tomlinson Esquire
Address: 892 Second Street Pike, Suite c
Richboro, Pa. 18954
Attorney for: Plaintiff
Telephone: (215)322-8300
Supreme Court ID No. 76678
OFFICE OF THE PROTHONOTARY OF
COMMON PLEAS OF CUMBERLAND COUNTY
NOTICE OF ENTRY
OF JUDGMENT, ORDER OR DECREE
LIEDERBACH, HAHN, FOY & VAN BLUNK, P.C.
HENRY E. VAN BLUNK, ESQUIRE I.D. No. 70751
TYLER TOMLINSON, ESQUIRE I.D. No.: 76678
KENNETH FERRIS, ESQUIRE I.D. NO.: 92335
892 Second Street - Ste. C
Richboro, PA 18954-1005
(215) 322-8300 Attorneys for Plaintiff
Arden Seven Penn Partners, LP Court of Common Pleas
Seven Penn Center Cumberland County, Pennsylvania
1635 Market Street, 17 1h Floor
Philadelphia, PA 19103
Plaintiff
V.
Mylotte, David & Fitzpatrick
Whetstone Run Office Complex
450 Parkway, Suite 300
Broomall, PA 19008
Defendant
Docket No.: a eecr -7
JUDGMENT NOTICE
Pursuant to Pa. R.C.P. No. 236, this .20'day of January, 2007, Judgment of $377,000.00
(three hundred seventy-seven dollars), together with costs and interest, for Plaintiff, Arden Seven
Penn Partners, LP., and against Defendant, Mylotte, David & Fitzpatrick was transferred to
Cumberland County from Philadelphia County.
PROTHONOTARY:
By: fs I C ,ti '
Should you have any questions, please contact:
Tyler Tomlinson, Esquire, LIEDERBACH, HAHN, FOY & VAN BLUNK, P.C.
892 Second Street Pike, Suite C, Richboro, PA 18954
Telephone: 215/322-8300
Facsimile: 215/322-7646
LIEDERBACH, HAHN, FOY & VAN BLUNK, P.C.
HENRY E. VAN BLUNK, ESQUIRE I.D. No. 70751
TYLER TOMLINSON, ESQUIRE I.D. No.: 76678
KENNETH FERRIS, ESQUIRE I.D. NO.: 92335
892 Second Street - Ste. C
Richboro, PA 18954-1005
(215) 322-8300 Attorneys for Plaintiff
Arden Seven Penn Partners, LP Court of Common Pleas
Seven Penn Center
Cumberland County, Pennsylvania
1635 Market Street, 17th Floor
Philadelphia, PA 19103
Plaintiff
V.
Mylotte, David & Fitzpatrick
Whetstone Run Office Complex
450 Parkway, Suite 300
Broomall, PA 19008
Docket No.:
Defendant
AFFIDAVIT OF JUDGMENT
COMMONWEALTH OF PENNSYLVANIA }
} SS.
COUNTY OF BUCKS }
TYLER TOMLINSON, ESQUIRE, being duly sworn according to law, deposes and says
that he the attorney for Plaintiff; that he is authorized to make this Affidavit on behalf of Plaintiff,
that the judgment against Defendant, Mylotte, David & Fitzpatrick is valid enforceab , and
unsatisfied.
TOMLINSON, ESQUIRE
SWORN to and subscribed before
me this 26th day of January, 2007.
c
to Public
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
STEPHANIE K. WINKLER, Notary Public
Northampton Twp., Bucks County
My Commission Expires May 20, 2010
LIEDERBACH, HAHN, FOY & VAN BLUNK, P.C.
HENRY E. VAN BLUNK, ESQUIRE I.D. No. 70751
TYLER TOMLINSON, ESQUIRE I.D. No.: 76678
KENNETH FERRIS, ESQUIRE I.D. NO.: 92335
892 Second Street - Ste. C
Richboro, PA 18954-1005
(215) 322-8300 Attorneys for Plaintiff
Arden Seven Penn Partners, LP Court of Common Pleas
Seven Penn Center
Cumberland County, Pennsylvania
1635 Market Street, 17th Floor
Philadelphia, PA 19103
Plaintiff
V.
Mylotte, David & Fitzpatrick
Whetstone Run Office Complex
450 Parkway, Suite 300
Broomall, PA 19008
Docket No.:
Defendant
AFFIDAVIT OF ADDRESSES
COMMONWEALTH OF PENNSYLVANIA
SS.
COUNTY OF BUCKS
TYLER TOMLINSON, ESQUIRE, being duly sworn according to law, deposes and says
that he the attorney for Plaintiff; that he is authorized to make this Affidavit on behalf of Plaintiff;
that the address of the Plaintiff is Arden Seven Penn Partners, LP, Seven Penn Center, 1635
Market Street, 17th Floor, Philadelphia, Pennsylvania 19103; and the address of the Defendant is
Mylotte, David & Fitzpatrick, Whetstone Run Office, 450 Parkway, Suite 300, Bro all,
Pennsylvania, 19008.
v
TOMLINSON, ESQUIRE
SWORN to and subscribed before
me this 26th day of January, 2007.
7 •otar Public
COMMONWEALTH OF PANNSY V Nib
NOTARIAL SEAT.
STEPHANIE K. WINKLER, Notary Public
Northampton Twp.. Bucks County
My Commission Expires May 20.2010
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IN THE CUMBERLAND COUNTY COURT OF COMMON PLEAS
ARDEN SEVEN PENN PARTNER, LP.
Plaintiff,
V. No. 07-546
MYLOTTE, DAVID, & FITZPATRICK
Defendant
PENNSYLVANIA MEDICAL SOCIETY LIABILITY
INSURANCE COMPANY
Garnishee
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance as counsel for garnishee PENNSYLVANIA MEDICAL
SOCIETY LIABILITY INSURANCE COMPANY and send all orders and notices to me at the
address noted below.
Robert B. Hoffman
Wolf Block Schorr and olis-Cohen LLP
I.D. No. 23846
213 Market Street, 9th F r
P. O. Box 865
Harrisburg, PA 17108-0865
(717) 237-7182
HAR:71493.1 /PEN 2 60-22 1 7 1 9
." 44t
IN THE CUMBERLAND COUNTY COURT OF COMMON PLEAS
ARDEN SEVEN PENN PARTNER, LP.
Plaintiff,
V. No. 07-546
MYLOTTE, DAVID, & FITZPATRICK
Defendant
PENNSYLVANIA MEDICAL SOCIETY LIABILITY
INSURANCE COMPANY
Garnishee
CERTIFICATE OF SERVICE
I hereby certify that on February 22, 2007, I caused a copy of the foregoing document to
be served by first class mail, postage prepaid, on the following counsel of record:
Henry E. Van Blunk
Tyler Tomlinson
Kenneth Ferris
Liederbach, Hahn, Foy & Van Blunk
892 Second Street -- Suite C
Richboro PA 18954-1005
Ed David
Mylotte David & Fitzpatrick
Whetstone Run Office Complex
450 Parkway, Suite 300
Broomall, PA 19008 j
Robert B. Hoffinan '
Wolf Block Schorr and S lisc
I.D. No. 23846
213 Market Street, 9th Fl or
P. O. Box 865
Harrisburg, PA 17108-0865
(717) 237-7182
HAR:71494.1 /PEN260-221719
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ARDEN SEVEN PENN PARTNERS, LP
Plaintiff
V.
Docket No. 07-546
MYLOTTE DAVID & FITZPATRICK
Defendant
PENNSYLVANIA MEDICAL SOCIETY
LIABILITY INSURANCE COMPANY
Garnishee
ANSWERS OF THE PENNSYLVANIA MEDICAL SOCIETY
LIABILITY INSURANCE COMPANY TO INTERROGATORIES
Garnishee the PENNSYLVANIA MEDICAL SOCIETY LIABILITY INSURANCE
COMPANY ("PMSLIC") responds as follows to Plaintiff's Interrogatories.
1. At the time you were served or at any subsequent time, did you owe the
Defendant(s) any money or were you liable to Defendant(s) on any negotiable or other written
instrument, or did Defendant(s) claim that you owed the Defendant(s) any money or were liable
to Defendant(s) for any reason?
Response: Yes.
Defendant is representing PMSLIC insured in one open matter (Weiner vs. Fisher, M.D.,
file #336585), in which there are no outstanding bills; the matter is pending decision on a
Petition for Allowance of Appeal. Defednat has represented PMSLIC insureds in two additional
cases, now closed, in which invoices were recently received, as follows:
Colon vs. Temple - Abernathy vs. Salkind, M.D. -
File # 339190 File # 339769
Case closed on 12/19/06 Case closed on 9/1/06
Final bill received seeking payment in Bill for $51.75 received
the amount of $1,732.50
2. At the time you were served or any subsequent time, was there in your possession,
custody or control or in the joint possession, custody or control of yourself or one or more other
persons any property of any nature owned solely or in part by the Defendant(s)?
Response: No.
3. At the time you were served or at any subsequent time, did you hold legal title to
any property of any nature owned solely or in part by the Defendant(s) or in which Defendant(s)
held or claimed any interest?
HAR:71496.1
PEP/22/21C7/THU 11:59 Ark FMSLIC Claims FAY No.717-796-8080 P.003
Response: No.
4. At the time you were served or at any subsequent time, did you hold as a fiduciary
any property in which the Defendant(s) had an interest?
Response: No.
5. At any time beFore or after you were served, did the Defendant(s) transfer or
deliver any property to you or to any person or place pursuant to your direction or consent and, if
so, what was the consideration therefore?
Response: No.
6. At the time you were served, did you pay, transfer or deliver any money or
property to the Defendant(s) or to any person or place pursuant to the direction of Defendant(s)
or otherwise discharge any claim of the Defendant(s) against you?
Response: No. In particular, PMSLIC has not.paid over the monies noted in response to
Interrogatory #1.
7. Does Defendant maintain any accounts with FMSLIC?
Response: No.
8. If so, please identify any and all accounts and the balance that is maintained in the
accounts.
Response: N/A.
9. Please identify all accounts/matters that Mylotte, David & Fitzpatrick is currently
handling for FMSLIC.
Response: See response to Interco tory I above.
As to Answers: - /L__'Zj
RIC ANGLE
Claims Teams Leader
Robert B. Hoffman
Wolf Block Schorr and Solis-Cohen LLP
I.D. No. 23846
213 Market Street, 9th Floor
P. O. Box 865
Harrisburg, PA 17108-0865
(717) 237-7182
-
2-;AA: 71496.1.
P s
Response: No.
4. At the time you were served or at any subsequent time, did you hold as a fiduciary
any property in which the Defendant(s) had an interest?
Response: No.
5. At any time before or after you were served, did the Defendant(s) transfer or
deliver any property to you or to any person or place pursuant to your direction or consent and, if
so, what was the consideration therefore?
Response: No.
6. At the time you were served, did you pay, transfer or deliver any money or
property to the Defendant(s) or to any person or place pursuant to the direction of Defendant(s)
or otherwise discharge any claim of the Defendant(s) against you?
Response: No. In particular, PMSLIC has not paid over the monies noted in response to
Interrogatory #1.
7. Does Defendant maintain any accounts with PMSLIC?
Response: No.
8. If so, please identify any and all accounts and the balance that is maintained in the
accounts.
Response: N/A.
9. Please identify all accounts/matters that Mylotte, David & Fitzpatrick is currently
handling for PMSLIC.
Response: See response to Interrogatory 1 above.
As to Answers:
RICHARD ZANGLE
Claims Team Leader
Robert B. Hofiihari(
Wolf Block Schorr/an is-Cohen LLP
I.D. No. 23846
213 Market Street, 9th Floor
P. O. Box 865
Harrisburg, PA 1 108-0865
(717) 237-7182
HAR:71496.1
-2-
1 4.
IN THE CUMBERLAND COUNTY COURT OF COMMON PLEAS
ARDEN SEVEN PENN PARTNER, LP.
Plaintiff,
V. : No. 07-546
MYLOTTE, DAVID, & FITZPATRICK
Defendant
PENNSYLVANIA MEDICAL SOCIETY LIABILITY
INSURANCE COMPANY
Garnishee
CERTIFICATE OF SERVICE
I hereby certify that on February 22, 2007, I caused a copy of the foregoing document to
be served by first class mail, postage prepaid, on the following counsel of record:
Henry E. Van Blunk
Tyler Tomlinson
Kenneth Ferris
Liederbach, Hahn, Foy & Van Blunk
892 Second Street -- Suite C
Richboro PA 18954-1005
Ed David
Mylotte David & Fitzpatrick
Whetstone Run Office Complex
450 Parkway, Suite 300
Broomall, PA 19008
Robert B. Hofflnank `-?
Wolf Block Schorr d Solis-Cohen LLP
I.D. No. 23846
213 Market Street, 9 h Floor
P. O. Box 865
Harrisburg, PA 17108-0865
(717) 237-7182
HAR:71494.1 /PEN260-221719
-T I
'
t. -rn
..
r
LIEDERBACH, HAHN, FOY & VAN BLUNK, P.C.
HENRY E. VAN BLUNK, ESQUIRE I.D. No. 70751
TYLER TOMLINSON, ESQUIRE I.D. No.: 76678
KENNETH FERRIS, ESQUIRE I.D. NO.: 92335
892 Second Street - Ste. C
Richboro, PA 18954-1005
(215) 322-8300 Attornevs for Plaintiff
Arden Seven Penn Partners, LP Court of Common Pleas
Seven Penn Center Cumberland County, Pennsylvania
1635 Market Street, 17th Floor
Philadelphia, PA 19103
Plaintiff
V. Docket No.: 07-546
Mylotte, David & Fitzpatrick
Whetstone Run Office Complex
450 Parkway, Suite 300
Broomall, PA 19008
Defendant
And
Pennsylvania Medical Society
Liability Insurance Company
1700 Bent Creek Boulevard
Mechanicsburg, PA 17050-1865
Garnishee
PRAECIPE FOR ENTRY OF JUDGMENT BY ADMISSION
AGAINST GARNISHEE AND CERTIFICATION OF ADDRESSES
1( O THE PROTHONOTARY:
Enter judgment in favor of Plaintiff and against the above named Garnishee, Pennsylvania
Medical Society Liability Insurance Company in the sum of $1,784.25 said sure being admitted in
their Answers to Interrogatories as being owing tv the Defendant and which is not greater than the
stem from Defendant to Plaintiff. See PMSLIC's Answers to Interrogatories attached hereto as
Exhibit "A".
Plaintiff reserves the right to refrain from discontinuing attachment and to proceed against
the Garnishee as to any further property or to contest any right in the property claimed by the
Garnishee.
I certify that the precise address(es) of Plaintiff, Defend;uit, and Garnishee are its set forth
in the above caption.
LIEDERBACI:I, I IAIIN,
Ia0Y &VAN U N I P. C.
By:
--
E RY E. VAN SLUNK, ESQUIRE
T I_,ER TOML.INSON, ESQUIRE.
KENNETH FERRIS, ESQUIRE
Attorneys for Plaintiff,
Dated: February 26; 2007 Arden Seven Penn Partners, LP
JUDGMENT SO ENTERED
AND DAMAGES ASSESSED AS ABOVE;
NOT K'E GIVEN PURSUANT TO Pa. R.C.P. 22")
SEAL
PIZ Li " ' ONO''ARY
y
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ARDEN SEVEN PENN PARTNERS, LP
Plaintiff
V.
Docket No. 07-546
MYLOTTE DAVID & FITZPATRICK
Defendant
PENNSYLVANIA MEDICAL SOCIETY
LIABILITY INSURANCE COMPANY
Garnishee
ANSWERS OF THE PENNSYLVANIA MEDICAL SOCIETY
LIABILITY INSURANCE COMPANY TO INTERROGATORIES
Garnishee the PENNSYLVANIA MEDICAL SOCIETY LIABILITY INSURANCE
COMPANY ("PMSLIC") responds as follows to Plaintiff's Interrogatories.
1. At the time you were served or at any subsequent time, did you owe the
Defendant(s) any money or were you liable to Defendant(s) on any negotiable or other written
instrument, or did Defendant(s) claim that you owed the Defendant(s) any money or were liable
to Defendant(s) for any reason?
Response: Yes.
Defendant is representing PMSLIC insured in one open matter (Weiner vs. Fisher, M.D.,
file #336585), in which there are no outstanding bills; the matter is pending decision on a
Petition for Allowance of Appeal. Defednat has represented PMSLIC insureds in two additional
cases, now closed, in which invoices were recently received, as follows:
Colon vs. Temple - Abernathy vs. Salkind, M.D. -
File # 339190 File # 339769
Case closed on 12/19/06 Case closed on 9/1/06
Final bill received seeking payment in Bill for $51.75 received
the amount of $1,732.50
2. At the time you were served or any subsequent time, was there in your possession,
custody or control or in the joint possession, custody or control of yourself or one or more other
persons any property of any nature owned solely or in part by the Defendant(s)?
Response: No.
3. At the time you were served or at any subsequent time, did you hold legal title to
any property of any nature owned solely or in part by the Defendant(s) or in which Defendant(s)
held or claimed any interest?
HAR:71496.1
PED/22/2007/THU 11.59 AM PMSLIC Maims FAX No. 717-796-8060 FWSJ
Response: No.
4. At the time you were served or at any subsequent time, did you hold as a fiduciary
any property in which the Defendant(s) had an interest?
Response: No.
5. At any time before or alter you were served, did the Defendant(s) transfer or
deliver any properly to you or to any person or place pursuant to your direction or consent and, if
so, what was the consideration therefore?
Response: No.
6. At the time you were served, did you pay, transfer or deliver any money or
property to the Defendant(s) or to any person or place pursuant to the direction of Defendant(s)
or otherwise discharge any claim of the Defendant(s) against you?
Response: No. In particular, PMSLIC has not.paid over tine monies noted in response to
Interrogatory #1.
7. Does Defendant maintain any accounts with PMSLIC?
Response: No.
8. If so, please identify any and all accounts and the balance that is maintained in the
accounts.
Response: N/A,
. 9. Please identify all accounts/matters that Mylotte, David & Fitzpatrick is currently
handling for PMSLIC.
Response: See response to int!NG tort' I above.
As to Answers:
RIC E
Cla ims Teaiocr Leader
Robert B. HoOman
Wolf Block Schorr and Solis-Cohen LLP
I.D. No. 23846
213 Market Street, 9th Floor
P. O. Box 865
Harrisburg, PA 17108-0865
(717) 237-7182
RAR:71496-1
is
Response: No.
4. At the time you were served or at any subsequent time, did you hold as a fiduciary
any property in which the Defendant(s) had an interest?
Response: No.
5. At any time before or after you were served, did the Defendant(s) transfer or
deliver any property to you or to any person or place pursuant to your direction or consent and, if
so, what was the consideration therefore?
Response: No.
6. At the time you were served, did you pay, transfer or deliver any money or
property to the Defendant(s) or to any person or place pursuant to the direction of Defendant(s)
or otherwise discharge any claim of the Defendant(s) against you?
Response: No. In particular, PMSLIC has not paid over the monies noted in response to
Interrogatory # 1.
7. Does Defendant maintain any accounts with PMSLIC?
Response: No.
8. If so, please identify any and all accounts and the balance that is maintained in the
accounts.
Response: N/A.
9. Please identify all accounts/matters that Mylotte, David & Fitzpatrick is currently
handling for PMSLIC.
Response: See response to Interrogatory 1 above.
As to Answers:
RICHARD ZANGLE
Claims Team Leader
Robert B. Hoffrhan(
Wolf Block Schorr an is-Cohen LLP
I.D. No. 23846
213 Market Street, 9th Floor
P. O. Box 865
Harrisburg, PA 1 108-0865
(717) 237-7182
HAR:71496.1
-2-
lb" .
IN THE CUMBERLAND COUNTY COURT OF COMMON PLEAS
ARDEN SEVEN PENN PARTNER, LP.
Plaintiff,
V. No. 07-546
MYLOTTE, DAVID, & FITZPATRICK
Defendant
PENNSYLVANIA MEDICAL SOCIETY LIABILITY :
INSURANCE COMPANY
Garnishee
CERTIFICATE OF SERVICE
I hereby certify that on February 22, 2007, I caused a copy of the foregoing document to
be served by first class mail, postage prepaid, on the following counsel of record:
Henry E. Van Blunk
Tyler Tomlinson
Kenneth Ferris
Liederbach, Hahn, Foy & Van Blunk
892 Second Street -- Suite C
Richboro PA 18954-1005
Ed David
Mylotte David & Fitzpatrick
Whetstone Run Office Complex
450 Parkway, Suite 300
Broomall, PA 19008
Robert B. Hoffhian\
Wolf Block Schorr d Solis-Cohen LLP
I.D. No. 23846
213 Market Street, 9 h Floor
P. O. Box 865
Harrisburg, PA 17108-0865
(717) 237-7182
HAR:71494.1 /PEN260-22 1 71 9
Certificate of Service
I, TYLER TOMLINSON, ESQUIRE, hereby certify that a copy of the foregoing document
was served via first class mail on February 26, 2007, upon the following individuals:
Robert B. Hoffman, Esquire
Wolf Block Schorr and Solis-Cohen, LLP
213 Market Street, 9th Floor
P.O. Box 865
Harrisburg, PA 17108-0865
Attorney for PMSLIC, Garnishee
Edward J. David, Esquire
Mylotte, David & Fitzpatrick
Whetstone Run Office Complex
450 Parkway, Suite 300
Broomall, PA 19008
Attorney for Defendant
t/
T LER TOMLINSON, ESQUIRE
F
? c
c
r W
n
OFFICE OF THE PROTHONOTARY OF
COMMON PLEAS OF CUMBERLAND COUNTY
NOTICE OF ENTRY
OF JUDGMENT, ORDER OR DECREE
LIEDERBACH, HAHN, FOY & VAN BLUNK, P.C.
HENRY E. VAN BLUNK, ESQUIRE I.D. No. 70751
TYLER TOMLINSON, ESQUIRE I.D. No.: 76678
KENNETH FERRIS, ESQUIRE I.D. NO.: 92335
892 Second Street - Ste. C
Richboro, PA 18954-1005
(215) 322-8300 Attorneys for Plaintiff
Arden Seven Penn Partners, LP Court of Common Pleas
Seven Penn Center Cumberland County, Pennsylvania
1635 Market Street, 17th Floor
Philadelphia, PA 19103
Plaintiff
V. Docket No.: 07-546
Mylotte, David & Fitzpatrick
Whetstone Run Office Complex
450 Parkway, Suite 300
Broomall, PA 19008 .
Defendant
And .
Pennsylvania Medical Society
Liability Insurance Company
1700 Bent Creek Boulevard
Mechanicsburg, PA 17050-1865
Garnishee
JUDGMENT NOTICE
Pursuant to Pa. R.C.P. No. 236, this 27th day of February, 2007, Judgment of $1,784.25
(one thousand seven hundred eighty-four dollars and twenty-five cents), for Plaintiff, Arden Seven
Penn Partners, LP., and against Garnishee, Pennsylvania Medical Society Liability Insurance
Company is entered.
PROTHONOTARY:
By:
Should you have any questions, please contact:
Tyler Tomlinson, Esquire, LIEDERBACH, HAHN, FOY & VAN BLUNK, P.C.
892 Second Street Pike, Suite C, Richboro, PA 18954
Telephone: 215/322-8300
Facsimile: 215/322-7646
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2007-00546 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
ARDEN SEVEN PENN PARTNERS LP
VS
MYLOTTE DAVID & FITZPATRICK
And now ROBERT BITNER
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0014:50 Hours, on the 31st day of January , 2007, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
MYLOTTE DAVID & FITZPATRICK in the
hands, possession, or control of the within named Garnishee
PENNSYLVANIA MEDICAL SOCIETY LIABILITY INSURANCE COMPANY
1700 BENT CREEK BLVD
MECHANICSBURG, PA 17055
Cumberland County, Pennsylvania, by handing to
JOHN ZDANOWICZ (DIRECTOR OF CLAIMS
personally three copies of interogatories together with 3
and attested copies of the within WRIT OF EXECUTION
the contents there of known to His .
Sheriff's Costs:
Docketing .00
Service .00
Affidavit .00
Surcharge .00
.00
/ .00
a115'Ia ?s
Sworn and Subscribed to
before me this
true
and made
S o a
0000
R. Thomas Kline
Sheriff of Cumberland County
02/01/2007
day of By
Deputy er ff
A.D
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this
Writ is returned ABANDONED, no action taken in six months.
Sheriff's Costs: Advance Costs: 150.00
Sheriff's Costs 89.05
Docketing 18.00 60.95
Poundage 1.75
Advertising
Law Library .50
Prothonotary 1.00 Refunded to Atty on 09/11/07
Mileage 8.80
Misc.
Surcharge 30.00
Levy 20.00
Post Pone Sale
Certified Mail
Postage
Garnishee 9.00
TOTAL 89.05 ,/ io11P'o 7 So 31p,
R. Thomas Kline, Sheriff
By(? n L'X--ed 41
hZ .E d E N V Vr loll
I , so
0
v
Ck 66'? 9F
0, /991" 1
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N007-546 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due Arden Seven Penn Partners, LP Seven Penn Center 1635
Market Street, 17`n Floor, Philadelphia, Pa. 19103 Plaintiff (s)
From Mylotte, David & Fitzpatrick Whetsone Run Office Complex 450 Parkway Suite 300,
Broomall, Pa. 19008
(1) You are directed to levy upon the property of the defendant (s)and to sell .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of Pennsylvnia Medical Society Liability Insurance Company 1700 Bent Creek Boulevard,
Mechanicsburg, Pa. 17050
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $377,000.00
Interest
Atty's Comm %
Atty Paid $ 38.00
Plaintiff Paid
Date: January 29, 2007
(Seal)
L.L.$ 0.50
Due Prothy $1.00
Other Costs
/5/ P ' r L
Cuitis R. Long, Prothonotary
By:
Deputy
REQUESTING PARTY:
Name Tyler Tomlinson Esquire
Address: 892 Second Street Pike, Suite c
Richboro, Pa. 18954
Attorney for: Plaintiff
Telephone: (215)322-8300
Supreme Court ID No. 76678