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Home My WebLink About01-4535SAIDI$ Johnna J. Kopecky, Esquire iD # 53147 aaidis, Shuff, Flower & Lindsay 26 West High Street Carlisle, PA 17013-2956 717-243-6222 O. MURTORFF, JR. and MARIAN M. MURTORFF, Plaintiffs HEALTHMED, INC., its Successors and Assigns, and WILLIAM GULA, Individually, Defendants iN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Docket No.: 01-4535 Civil Civil Action - Law Jury Tdal Demanded pRAI=CIPF F~3R rtl=FAULT JIIrt~MFNT TO THE PROTHONOTARY: Please enter a judgment by default in favor of the Plaintiff and against the Defendant(s) for failure to Answer the Complaint in the amount of $38,875.00, plus costs, plus $250.00 attorney fees and other such attorney fees as the Plaintiffs shall incur. I certify the Ten (10) Day Notice of Entry of Default pursuant to Rule 237.1 was mailed U. S First Class mail postage prepaid and is attached hereto as Exhibit "A". Respectfully submitted, By: Dated: August 30, 2001 SA~NDsAY J~h/~a~/a~. Ko~ky, Esquir~' Ar-'~orney for~e Plaintiff Prothonotary ....... AND NOW, this ~Dday of ,2001 a default judgment has been entered in the amount of $38,875.00, plus costs, plus $250.00 attorney fees and other such attorney fees as the Plaintiffs shall Prothonotary J. Kopecky, Esquire iD # 53147 Saidis, Shuff, Flower & Lindsay 26 West High Street Carlisle, PA 17013-2956 717-243-6222 MELVIN O. MURTORFF, JR. and MARIAN M. MUP, TORFF, Plaintiffs HEALTHMED, INC., its Successors and Assigns, and WILLIAM GULA, individually, Defendants TO: William Gula 4811 Jonestown Road Suite 125 Harrisburg PA 17109 IN THE COURT OF COMMON PLEAS CUMBERLAND cOUNTY, PENNSYLVANIA Docket No.: 01-4535 Civil Civil Action - Law Jury Trial Demanded You are hereby notified that on /~(~<,~ ~)' '~ ~ ! 2001, the following Judgment has been entered against you in the above-captioned case, Prothonotary hereby certify that the name and address of the proper person to receive this notice is: William Gula 4811 Jonestown Road Suite 125 Harrisburg PA 17109 Johnna J. Kopecky, Esquire ID # 53147 Saldis, Shuff, Flower & Lindsay 26 West High Street Carlisle, PA 17013-2956 717-243-6222 MELVIN O. MURTORFF, JR. and MARIAN M. MURTORFF, Plaintiffs HEALTHMED, INC., its Successors and Assigns, and WILLIAM GULA, Individually, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Docket No.: 01-4535 Civil Civil Action - Law Jury Trial Demanded TO: Healthmed, Inc. Its Successors and Assigns 4811 Jonestown Road Suite 125 Harrisburg PA 17109 You are hereby notified that on ~J ~-~- ~"~l~, ~ ! 2001, the following Judgment has been entered against you in the above-captioned case. Date: Prothonotary I hereby certify that the name and address of the proper person to receive this notice is: Healthmed, Inc, Its Successors and Assigns 4811 Jonestown Road Suite 125 Harrisburg PA 17109 o~na-,~. Ke~ecky, Esquire Johnna J. Kopecky, Esquire ID # 53147 Saidis, Shuff, Flower & Lindsay 26 West High Street Carlisle, PA 17013-2956 717-243-6222 MELVIN O. MURTORFF, JR. and MARIAN M. MURTORFF, Plaintiffs HEALTHMED, INC., its Successors and Assigns, and WILLIAM GULA, Individua y, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Docket No.: 01-4535 Civil Civil Action - Law Jury Tdal Demanded TO: William Gula 4811 Jonestown Road Suite 125 Hamsburg PA 17109 DATE OF NOTICE: August 20, 2001 U.S. POSTAL SERVICE CERTIFICATE OF MAILINGS- Carlisle PA 17013-~6~ . .~. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FiND OUT WHERE YOU CAN GET LEGAL HELP: William Gula 4811 Jonestown Road Suite 125 Harrisburg PA 17109 _ PS Form 3817, January 2001 ~r Association nue 7013 Johnna J, Kopecky, Esquire ID # 53147 Saidi$, Shuff, Flower & Lindsay 26 West High Street Carlisle, PA 17013-2956 717-243-6222 MELVIN O. MURTORFF, JR. and MARIAN M. MURTORFF, Plaintiffs HEALTHMED, INC., its Successors and Assigns, and WILLIAM GUI. A, Individually, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Docket No.: 01-4535 Civil Civil Action - Law Jury Tdal Demanded TO: Healthmed, Inc. Its Successors and Assigns ,,811 Jonestown Road Suite 125 Harrisburg PA 17109 DATE OF NOTICE: August 20, 2001 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE U.S. POSTAL SERVICE CERTIFICATE OF MAILING ~ ~ EE USED ~O. DOMEST,C ^.0 ,.TE..^T~O.^L ~,L DOES .O~/ ~ Law Offices, s iai , sh ,, & 2~ West ~i~h Street ~ ~ Healthmed Inc, Its Successors and Assigns 4811 Jonestown Road Suite 125 Harrisburg PA 17109 '-"'-'^'~: '""' ' CAN GET LEGAL HELP: ir Association Rue 7'013 ~6 By: ornn; ~pecky,~squ~' y for the Plaintiff,,,~ PS Forrn3817, January 2001 MELVIN O. MURTORFF, JR. and MARI~LN M. MURTORFF, Plaintiffs HEALTHMED, INC., its Successors and Assigns, and WILLIAM GULA, Individually, Defendants :IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :Docket No.: 01- C.55- C;~; ~ :Civil Action - Law :Jury Trial Demanded NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA Dated: Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 SAIDIS, SHUFF, FLOWER & LINDSAY do~a J./~Ope~squire S~eme ~ourt I.D~ #53147 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Slreet Carlisle, PA MELVIN O. MURTORFF, JR. and MARIAN M. MURTORFF, Plaintiffs HEALTHMED, INC., its Successors and Assigns, and WILLIAM GULA, Individually, Defendants : :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA :Docket No.: ~ ' ' :Civil Action - Law : :Jury Trial Demanded AND NOW comes counsel, 1. Marian M. Carlisle, 2. assigns, Jonestown Road, Pennsylvania. COMPLAINT the Plaintiffs, by and through their Saidis, Shuff, Flower & Lindsay and avers as follows: The Plaintiffs are Melvin O. Murtorff, Jr. and Murtorff, his wife, of 1367 Georgetown Circle, Cumberland County, Pennsylvania. Defendant HealthMed, Inc., its successors or is a Pennsylvania corporation doing business at 4811 Suite 124, Harrisburg, Dauphin County, 3. Defendant William Gula is an adult individual whose last known address if 4811 Jonestown Road, Harrisburg., Dauphin County, Pennsylvania. 4. On or about March 7, 2000, the Plaintiffs, hereinafter "Lessor" and the Defendants, hereinafter "Lessee", entered into a Lease Agreement for the lease of an office space known as 43A Front, Brookwood Avenue, Carlisle, SAIDIS SHUFF, FLOWER & LINDSAY .A~ro~,s.~-;~--.'.'.'.'.'.~ 26 W, High S~reet Carlisle. PA Pennsylvania. A copy of said Lease Agreement is attached hereto and made a part hereof and marked as Exhibit "A". 5. Pursuant to the terms of the Lease, the Lease began on April 1, 2000, and expires at midnight on April 1, 2003. 6. Pursuant to said Lease Agreement, the amount of the rent for the initial term of the Lease is the sum of $42,750.00, payable at the rate of $1,187.50 per month, on or about the first of said month. 7. Sometime prior to January, 2001, the Defendants moved out of said leased premises. 8. Through and including January of 2001, the rental amounts were paid; however, there remains an unpaid balance under the term of the lease of $30,875.00. 9. Despite repeated demands for payment, the Defendants have failed and refused to pay the sum of $30,875.00 to the landlord. 10. Pursuant to said Lease Agreement, and specifically Paragraph 9 titled Default: If default should occur in the payment of any part of said rent after the same becomes due . it shall be lawful for the Prothonotary, or any attorney of any Court of record to appear for and enter and file in any competent court an amicable action in ejectment against Lessee and in favor of Lessors for the premises herein described and to direct the immediate issuing of a writ of executive for costs, rent due and unpaid SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA and an attorney fee of Two Hundred Fifty Dollars ($250.00) waiving all irregularities, without notice and without asking leave of court. WHEREFORE, the Plaintiffs demand judgement in favor of the Plaintiff and against the Defendant in the sum of $38,875.00, plus costs, plus $250.00 attorney fees and other such attorney fees as the Plaintiffs shall incur. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Dated: Johnn Attor~y I.D~ # 53147 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiffs VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. DATED: ,,/,,../Melvin O. /urtorf~u~ SAIDIS SHUFF, FLOWF, R & LINDSAY 26 w. High Street Carlisle, PA SHERIFF'S RETURN CASE NO: 2001-04535 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MURTORFF MELVIN 0 ET AL VS HEALTHMED INC ET AL - OUT OF COUNTY R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: HEALTHMED INC but was unable to locate Them in his bailiwick. deputized the sheriff of DAUPHIN County, serve the within COMPLAINT & NOTICE He therefore Pennsylvania, to On Au u__~g_~ 14th , 2001 , this office was in receipt of th-~---~ attached return from DAUPHIN Sheriff,s Costs: Docketing Out of County Surcharge Dauphin County 18.00 9.00 10.D0 36.50 .00 73.50 08/14/2001 R. Thomas Kline Sheriff of Cumberland County SAIDIS SHUFF FLOWER & LINDSAY Sworn and subscribed to before me this /~ day of ~ _ ~2~ A.D. , ! Prothonot~-~ SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2001-04535 p COMMONWEALTHOF PENNSYLVANIA: COUNTY OF CUMBERLAND MURTORFF MELVIN 0 ET AL VS HEALTHMED INC ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: GULA WILLIAM but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, serve the within COMPLAINT & NOTICE to On Au u___~g_q~__ 14th , 2001 , this office was in receipt of the attached return from DAUPHIN Sheriff,s Costs: Docketing 6.00 Out of County .00 Surcharge 10.00 .00 .00 16.00 08/14/2001 SAIDIS SHUFF FLOWER Sworn and subscribed to before me this /~ ~ day of ~ _ ~2~l A.D. ' ~ Prothonotary , Sheriff of Cumberland County & LINDSAY Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph:(717)255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania County of Dauphin : MURTORFF MELVIN O JR & MARIAN M MURTOR vs : GULA WILL IA/~ Sheriff's Return AND NOW: August 1, NOTICE & COMPLAINT GULA WILLIAM to HEATHER HAYES, HEALTH INFO COORDINATOR of the original NOTICE & COMPLAINT to him/her the contents thereof at 4811 JONESTOWN RD SUITE 125 HARRISBURG, PA No. 2092-T - -2001 OTHER COUNTY NO. 01-4535 2001 at 12:42PM served the within upon by personally handing 1 true attested copy(les) and making known 17112-0000 Sworn and subscribed to before me this 8TH day~~AU~o1 PROTHONOTARY So Answers, Sheriff of Dauphin County, Pa. epu%/y Sheriff ~ Sheri~s: $36.50 PD 08/01/2001 RCPT NO 152503 BARBAGE Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 Pr: (717) 255~2660 fax: (717) 255-2889 Jack Lotwick Sheriff J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania County of Dauphin : MURTORFF MELVIN O JR & MARIAN M MURTOR v$ GULA WILLIAM Sheriff's Return No. 2092-T - - -2001 OTHER COUNTY NO. 01-4535 AND NOW: August 1, 2001 NOTICE & COMPLAINT HEALTHMED INC to HEATHER HAYES, HEALTH INFO COORDINATOR of the original NOTICE & COMPLAINT to him/her the contents thereof at 4811 JONESTOWN RD. SUITE 125 HARRISBURG, PA at 12:42PM served the within upon by personally handing 1 true attested copy(les) and making known 17112-0000 Sworn and subscribed to before me this 8TH da~~o01 PROTHONOTARY So Answers, Sheriff of Dauphin County, Pa. $he~/01/2001 RCPT NO 152503 BARBAGE