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Home My WebLink About01-04535Johnna 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 v. HEALTHMED, INC., its Successors and Assigns, and WILLIAM GULA, Individually, Defendants TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Docket No.: 01-4535 Civil Civil Action -Law Jury Trial Demanded 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, S][~ F~DFLO~ 2s w ;fin s1~ Crrliele, PA Dated: August 30, 2001 By: Y .~` Prothonotary AND NOW, this ,~}day of ~us~ , 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 incur. ~~~~~ Prothonotary SAIDIS, SHUFF FLOWE LINDSAY r i J a J. Ko cky, Esquire torne for a Plaintiff 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 v. 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 Nil4u5~ ~~ a ~ 1 2001, the following Judgment has been entered against you in the above-captioned case. Date: ~~t -~ 30 DO j (s Prothonotary I hereby certify that the name and address of the proper person to receive this notice is: SAIDIS SHSLUFF~pFLO~ ,vroarsr~uruw 26 W. High Street Carllsle~ PA William Gula 4811 Jonestown Road Suite 125 Harrisburg PA 17109 Joh J. Ko cky, E~ 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 v. HEALTHMED, INC., its Successors and Assigns, and WILLIAM GULA, Individually, Defendants TO: Healthmed, Inc. Its Successors and Assigns 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 ~us~-'~ ~~ 2001, the following Judgment has been entered against you in the above-captioned case. Date: Prothonotary I hereby certifythat the name and address of the proper person to receive this notice is: SAIDIS Sim F~FLO~ .n'mamisw•uw ?b W. High Street Carlisle, PA Healthmed, Inc. Its Successors and Assigns 4811 Jonestown Road Suite 125 Harrisburg PA 17109 ~~ o na J. K ecky, Esquire Johnna J. Kopeeky, Esquire ID # 53147 Saidis, Shuff, Flower 8 Lindsay 26 West High Street Carlisle, PA 17013-2956 717-243222 MELVIN 0. MURTORFF, JR. and MARIAN M. MURTORFF, Plaintiffs v. HEALTHMED, INC., its Successors and Assigns, and WILLIAM GULA, Individually, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Docket No.: 01-4535 Civil Civil Action -Law Jury Trial Demanded Defendants TO: William Gula 4811 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 'i THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: . ,, O.S. POSTAL SERVICE CERTIFICATE OF MAILING-~"'~ ~ - ~"A~>tee Here in stamps ''~ ~. •~... "_pr mete[ ROSta9e and MV 88 USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT / S'..IYI ~~Y2 ~~ w!,a!kjlnquire of Received From: {( :fig >>' Law Offices '' :- j Saidis, Shuff, Flower &~Li ds p 26 West High Street Carlisle PA 1 701 3-255 6 GSp, One piece of ortlinary mail atltlre5setl io: William Gula 4811 Jonestown Road Suite 125 Harrisburg PA 17109 PS Form 3817, January 2001 .~=-~ _- t ~ ~ ', ~~'.': `_~. ;, ]i `- rI C: d tr Association nue ?013 i6 By: o na J. opecky, E orne or the Plaintiff Johnna J. Kopecky, Esquin; ID # 53147 Saidis, Shuff, Flower 8 Lindsay 26 West High Street Carlisle. PA 17013-2956 717-243-6222 MELVIN O. MURTORFF, JR. and MARIAN M. MURTORFF, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Docket No.: 01-4535 Civil v. HEALTHMED, INC., its Successors and Assigns, and WILLIAM GULA, Individually, Defendants TO: Healthmed, Inc. Its Successors and Assigns 4811 Jonestown Road Suite 125 Harrisburg PA 17109 DATE OF NOTICE: August 20, 2001 Civil Action -Law Jury Trial Demanded 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, GC TO OR TELEPHONE u.S. POS7AL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC ANO INTERNATIONAL MAIL, DOES NOT PROVID FOR INSURANCE~OSTMASTER ., :''. 1 ReceE'etl Fmm: Law Offices: Saidis, Shuff, Flower & 26 West High Stregt Carlisle PA 17013-2~ One piece of ordinary mail addressetl tp: Healthmed Inc, Its Successors and Assigns 4811 Jonestown Road Suite 125 Harrisburg PA 17109 IT\ nrucoc ~.~~ ~ CAN GET LEGAL HELP: 'A(rix tsa'llere in stamps ar dfebr postage and t m5rk;lnquire of Masttq for current ~; i..,~ ~: --.. ,1. r ~1 Ir Association nue 7013 i6 By: na opecky, Esqui orney for the Plainti PS Form 3817, January 2001 SHERIFF'S RETURN - OUT OF COUNTY Z"ASE N0: 2001-04535 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MURTORFF MELVIN O 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 HEALTHMED INC but was unable to locate Them deputized the sheriff of DAUPHIN serve the within COMPLAINT & NOTICE County, Pennsylvania, to On August 14th 2001 this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dauphin County .00 73.50 08/14/2001 SAIDIS SHUFF FLOWER & LINDSAY So answer 18.00 9 . 0`0 10.00 R. homas Kline 36.50 Sheriff of Cumberland County Sworn and subscribed to before me this /~~' day of ~,,,_,,_~- ~~..r, A . /D~. ~.~_._, u. 7~1,,.¢e,_. do ~~ Prothonot r to wit: in his bailiwick. He therefore ,~,~,~,. SHERIFF' RETURN - OUT OF COUNTY ^` SASE NO: 2001-04535 P COMMONWEALTH OF PENNSYLVANI COUNTY OF CUMBERLAND MURTORFF MELVIN O 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 deputized the sheriff of DAUPHIN serve the within COMPLAINT & NOTICE County, Pennsylvania, to On August 14th 2001 this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: So answ Docketing 6.00 Out of County .00 , Surcharge 10.00 R. Thomas Kline .00 Sheriff of Cumberland County .00 16.00 08/14/2001 SAIDIS SHUFF FLOWER & LINDSAY Sworn and subscribed to before me this ~ day of ,.,.h~ ate/ A.D. ~ G 7h,~» Prothonotary in his bailiwick. He therefore 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 CommonWealYh Of POttnS}'1Vaula MURTORFF MELVIN 0 JR & MARIAN M MURTOR vs COUntyOfDauphin GULA WILLIAM Sheriff's Return No. 2092-T - - -2001 OTHER COUNTY NO. 01-4535 AND NOW: August 1, 2001 NOTICE & COMPLAINT GULA WILLIAM at 12:42PM served the within upon by personally handing to HEATHER HAYES, HEALTH ZNFO COORDINATOR 1 true attested copy(ies) of the original NOTICE & COMPLAINT and making known to him/her the contents thereof at 4811 JONESTOWN RD SUITE 125 HARRISBURG, PA 17112-0000 Sworn and subscribed to before me this 8TH day AUGUST, 2001 ~... f ~~ PROTHONOTARY ff Sheri~f"'s Costs: 536.50 PD 08/01/2001 RCPT NO 152503 So Answers, ~~i~~~ Sheriff of Dauphin County, Pa. By BARBAGE . . .. , (~~ftx~ ~~ E O ~e.~tff 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. Dattiel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy COmmonWealth Of PonnSylVania MURTORFF MELVIN 0 JR & MARIAN M MURTOR vs County of Dauphin GULA WILLIAM Sheriff's Return No. 2092-T - - -2001 OTHER COUNTY NO. 01-4535 AND NOW: August 1, 2001 at 12:42PM served the within NOTICE & COMPLAINT upon HEALTHMED ZNC by personally handing to HEATHER HAYES, HEALTH INFO COORDINATOR 1 true attested copy(ies) of the original NOTICE & COMPLAINT and making known to him/her the contents thereof at 4811 JONESTOWN RD. SUITE 125 HARRISBURG, PA 17112-0000 Sworn and subscribed to before me this 8TH day, AUGUST, 2001 f PROTHONOTARY So Answers, ~~°~~~ Sheriff of Dauphin County, Pa. By 's Costs; $36.50 PD 08/01/2001 RCPT NO 152503 BARBAGE n MELVIN O. MURTORFF, JR. and MARIAN M. MURTORFF, v. HEALTHMED, INC Successors and WILLIAM GULA, :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA :Docket No.: Q~-~6~ Ct~t6~ :Civil Action - Law Jury Trial Demanded NOTICE TO DEFEND SAIDIS SHiIFF, FLOWER & LINDSAY ATTORNCYS~AT~LAW 2G W. High Street Carlisle, PA 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. Plaintiffs ., its Assigns, and Individually, Defendants Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 Dated: ~/~ ~~• ~00~ SAIDIS, SNUFF FLOWER & LINDSAY By: Jo a J. ope squire S eme ourt I.D. #53147 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiff MELVIN 0. MURTORFF, JR. and :IN THE COURT OF COMMON PLEAS MARIAN M. MURTORFF, :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs :Docket No.: ~~-yU~c~ G6Vi~ v. . :Civil Action - Law HEALTHMED, INC., its Successors and Assigns, and :Jury Trial Demanded WILLIAM GULA, Individually, Defendants COMPLAINT AND NOW comes the Plaintiffs, by and through their counsel, Saidis, Shuff, Flower & Lindsay and avers as follows: 1. The Plaintiffs are Melvin O. Murtorff, Jr. and Marian M. Murtorff, his wife, of 1367 Georgetown Circle, Carlisle, Cumberland County, Pennsylvania. 2. Defendant HealthMed, Inc., its successors or assigns, is a Pennsylvania corporation doing business at 4811 Jonestown Road, Suite 124, Harrisburg, Dauphin County, Pennsylvania. 3. Defendant William Gula is an adult individual whose SAIDIS SHUFF, FLOWER & LINDSAY ATTORI~YS~AT~WW 26 W. High Street Carlisle, PA 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, 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 SAIDIS SHUFF, FLOWER & LINDSAY ATTORNEYS•AT•LAW 26 W. High Street Carlisle, PA 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 and an attorney fee of Two Hundred Fifty Dollars ($250.00) waiving all irregularities, without notice and without asking leave of court. the Plaintiffs demand judgement in favor of the Plaintiff and against the Defendant in the sum of $38,875.00, plus costs, plus $250.00 attorney fees and other such attorney fees as the Plaintiffs shall incur. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Dated: ~ 2-I,.si ~' Johnna Ko ky, ire Attor y I.D. # 53147 26 West H igh Street Carlisle, PA 17013 (717) 243 -622 2 Attorney for Plaintiffs SAIDIS SHUF$ FLOWER & LINDSAY ATTORNEYS•AT•I.AW 26 W. High Street Carlisle, PA VERIFICATION SAIDIS SHUFF, FLOWER ;i & LINDSAY ATI(IRI~Y$•AT•LAW ~;I 26 W. High Street Carlisle, PA 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: ~ _ Z~b~d ~