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HomeMy WebLinkAbout01-05056r SANDLER & MARCHESINI, P.C. BY: PAUL N. SANDLER, ESQUIRE Attorney I.D. #15711 1429 Walnut Street, 16th Floor Philadelphia, PA 19102 (215) 568-9300 LITTLE DATA CENTER, INC. 2315 East York Street Philadelphia, PA 191 COURT OF COMMON PLEAS CUMBERLAND v. DR. JOHN PAUL REHEIS Lansdowne Tower Apartments Building A 770 Providence Road Aldan, PA 19018 NO . QI - SQS(.. ~f U l~,~e2YV~ PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment on behalf plaintiff, Little Data Center, Inc. and against defendant, Dr. John Paul Reheis, in the sum of $17,796.93. Attached hereto is a certified copy of a judgment entered in the Court of Common Pleas of Philadelphia County. I hereby certify that the above judgment is still due and owing. SANDLER & MARCHESINI, P.C. __--- BY• AUL N. SANDLER, ESQUIRE Attorney for Plaintiff F:\WPFILES\R\ROSEN\DATACTR\REHEIS\CUmbexland.JUdgment.Wpd SANDLER & MARCHESINI, P.C. BY: PAUL N. SANDLER, ESQUIRE Attorney I.D. #15711 1429 Walnut Street, 16th Floor Philadelphia, PA 19102 (215) 568-9300 LITTLE DATA CENTER, INC. 2315 East York Street Philadelphia, PA 19125 v. COURT OF COMMON PLEAS Cumberland County DR. JOHN PAUL REHEIS Lansdowne Tower Apartments Building A 770 Providence Road Aldan, PA 19018 CERTIFICATION OF ADDRESSES TO THE PROTHONOTARY: I hereby certify that the above stated address of plaintiff and defendant are true and correct. SANDLER & MARCHESINI, P.C. BY• UL N. S ER, ESQUIRE Attorney for Plaintiff F:\WPFILES\R\ROSEN\DATACTR\REHEIS\CERTIF2.wpd OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS ROOM 58~, C1YY HALL • PHILAa ELPHIA, PA. 19107 N J. PE771T, JR. q OTNONOTARY °' 'Dr. Richard Reheis Lansdowne Tower Apartments Building A 770 Providence Road Aldan, PA 19018 • -7,ITTLR DATA CENTER, INC. 2315 East York Street Philadelphia, PA 19125 DR. JOHN PAi~L REHEIS I,ANSDOWNE TOWER APARTMENTS BUILDING A - 770 PROVIDENCE ROAD Aldan, PA 19018 NOTICE r COURT OF COMMON PLE.~S (Philadelphia County) February Teral, 19 99 No. 3552 Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. JOti~( J•. P°_TTiT, JR. Prathanota: ~ ~Yjudgmeat by Deiauit Money judgment ["'I Judgment in Replevia ~ .r . .~. .L'f judgmeat for Possessica ~ -~' ~ - - >. C Judgment on Awazd of Arbittation ~_.. I %~. '' :~ r- ["j Judgment on Ve;dict - ry - ~ .`; r~; Cj - Judgment on Court Findiags -- ~ `;; IF YOU HAVE ANY QUESTIONS CONCERMNO THIS NOTICE, PLEASE CALL: ATTORNEY Paul N. Sandler, Esquire ((mere Aetomey'~s None) at this telephone anmber. 5 6 8- 9 3 0 0 lzl cR... anal SANDLER & MARCHESINI, P.C. BX: PAUL N. SANDLER, ESQUIRE Attorney I.D. #15711 1429 Walnut Street, 16th Floor Philadelphia, PA 19102 (215) 568-9300 LITTLE DATA CENTER, INC. 2315 East York Street Philadelphia, PA 191 V. DR. JOHN PAUL REHEIS . Lansdowne Tower Apartments Building A , 770 Providence Road . Aldan, PA 19018 COURT OF COMMON PLEAS PHILADELPHIA COUNTY FEBRUARY TERM, 1999 ~n NO. 355.2 ;n - ~ __ ~, v -~Z .-C PRAECIPE TO ENTER JUDGMENT AND ASSESS DAMAGES TO THE PROTHONOTARY: ;-: t c, ~_ ;~~ ~, ,..1 Kindly enter judgment on behalf plaintiff, Little Data Center, Inc. and against defendant, Dr. John Paul Reheis, for failure of defendant to answer plaintiff's complaint within twenty (20) days. Kindly assess damages in the amount of $17,796.93. I certify that a Notice of Intent to Take Default Judgment was sent to the defendant on April 12, 1999, a true and correct copy of said Notice is attached hereto and referred to as Exhibit "A". I further certify the above address is true and correct. SANDLER & MARCHESINI, P.C. BY: 1lI cuA. PAUL N. SAND ER, ESQUIRE Attorney for Plaintiff SANDLER & MARCHESINI, P.C. BY: PAUL N. SANDLER, ESQUIRE Attorney I.D. #15711 1429 Walnut Street, 16th Floor Philadelphia, PA 19102 (215) 568-9300 LITTLE DATA CENTER, INC. vs. DR. JOHN PAUL REHEIS COURT OF COMMON PLEAS PHILADELPHIA COUNTY FEBRUARY TERM, 1999 N0. 3552 AFFIDAVIT OF NON MILITARY SERVICE V Paul N. Sandler, Esquire, being duly sworn according to law, deposes and says that he represents the Plaintiff in the above matter; that he is authorized to make this Affidavit on behalf of the Plaintiff; and the above-named Defendant is over 18 years of age; the address of the Defendant is Lansdowne Tower Apartments, Building A, 770 Providence Road, Aldan, PA 19018; that the occupation of the Defendant is unknown; and that the Defendant is not in the Military Service of the United States nor any State or Territory thereof or its allies as defined in the Soldiers and Sailors Civil Relief Action of 1940 and the amendments thereto. & MARCHESINI, P.C. SWORN TO AND SUB C IBED RE ME THIS DAY OF ~ 19~. A '_ Public BY: PAUL N. SANDLER, ESQUIRE Attorney for Plaintiff Notary Publ(c ~ - 2 - SANDLER & MARCHESINI, P.C. BY: PAUL N. SANDLER, ESQUIRE Attorney I.D. #15711 1429 Walnut Street, 16th Floor Philadelphia, PA 19102 (215) 568-9300 LITTLE DATA CENTER, INC. 2315 East York Street Philadelphia, PA 19125 COURT OF COMMON PLEAS PHILADELPHIA COUNTY FEBRUARY TERM, 1999 v. DR. JOHN PAUL REHEIS Lansdowne Tower Apartments Building A 770 Providence Road- Aldan, PA 19018 DATE OF NOTICE: April 12, 1999 T0: DR. JOHN PAUL REHEIS N0. 3552 V 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: PHILADELPHIA HAR ASSOCIATION LAWYER REFERENCE AND INFORMATION SERVICE One Reading Center Philadelphia, PA 19107 Telephone: (215) 238-1701 - S TDLEFjI& MARCHESINI, P.C. PAUL N. SANDLER, ESQUIRE Attorney for Plaintiff F: \HPFILES\R\ROSEN\DATACiR\REHEIS\}pDAY.NOT ~ ` y PAGE 1 REPORT ZDRDOCT First Judicial District RUN DATE 08/17/01 USER ID: COS CIVIL DOCKET REPORT RUN TIME 01:35 PM CASE ID 990203552 -------------------------------------------------------------- CASE NUMBER CASE CAPTION 990203552 LITTLE DATA CENTER INC VS REHEIS FILING DATE COURT LOCATION JURY 24-FEB-1999 AR AC N CASE TYPE: CONTRACTS OTHER STATUS: JUDGMENT BY DEFAULT/FINAL DISP Seq # Assoc E~Date 1 2 1 3 4 T e ID Party Name / Address & Phone No. APLF A15711 SANDLER, PAUL N 1429 WALNUT ST 16TH FLOOR PHILADELPHIA PA 19102 (000)568-9300 PLF Q3928171 LITTLE DATA CENTER INC 2315 E YORK ST PHILADELPHIA PA 19125 DFT Q3928178 REHEIS DR, JOHN PAUL LANSDOWNE TOWER APTS BLDG A 770 PROVIDENCE RD PRIMOS PA 19018 DGR Q4075568 MADISON BANK 1767 SENTRY PARKWAY WEST BLUE BELL PA 19422 Filing Date / Tim2 Docket Entry 24-FEB-99 16:15:00 COMMENCEMENT OF CIVIL ACTION 24-FEB-99 16:15:00 SHERIFF'S SURCHARGE 1 DEFT SANDLER, PAUL N SANDLER, PAUL N 24-FEB-99 16:15:00 COMPLAINT FILED NOTICE GIVEN SANDLER, PAUL N COMPLAINT WITH NOTICE TO DEFEND WITHIN TWENTY (20) DAYS AFTER SERVICE IN ACCORDANCE WITH RULE 1018.1 FILED.ASSESSMENT OFDAMAGES NOT REQUIRED. 24-FEB-99 16:16:50 ACTIVE CASE 25-FEB-99 10:28:29 ARBITRATION HEARING SCHEDULED t ~ r PAGE 2 REPORT ZDRDOCT First Judicial District RUN DATE 08/17/01 USER ID: COS CIVIL DOCKET REPORT RUN TIME 01:35 PM CASE ID 990203552 Filing Date / Time Docket Entry OB-MAR-99 16:20:00 SHERIFF'S SERVICE SHERIFF'S SERVICE OF COMPLAINT ON DR. JOHN PAUL REHEIS ON 3-8-99. 17-MAY-99 12:19:00 JUDGMENT BY DEFAULT/FINAL DISP 17,796.93 PRAECI PE FOR ENTRY OF DEFAULT JUDGMENT FILED. JUDGMENT FOR PLAINTIFF(S) AGAINST DEFENDANT(S) FOR FAILURE TO FILE ANSWER WITHIN REQUIRED TIME. PRO-PROTHONOTARY NOTICE UNDER RULE 236. NOTICE UNDER 237.5. AFFIDAVIT OF NON-MILITARY SERVICE FILED DAMAGES ASSESSED $ 17,79.6.93 24-FEB-00 13:47:00 PRAECIPE TO ISSUE WRIT FILED SANDLER, PAUL N PRAECIPE FOR WRIT OF ATTACHMENT AGAINST MADISON BANK FILED. WRIT OF EXECUTION IN ATTACHMENT AND SUMMONS ISSUED UPON GARNISHEE. 29-MAR-00 11:54:00 ANSWERS-INTEROGS IN ATTACHMENT MADISON BANK, GARNISHEE ANSWERS TO INTERROGATORIES FILED. 24-APR-00 12:22:00 JUDGMENT ENTERED BY ADMISSION 721.77 SANDLER, PAUL N PRAECIPE FOR ENTRY OF JUDGMENT FILED. JUDGMENT IN FAVOR OF PLAINTIFF AND AGAINST GARNISHEE MADISON BANK IN THE SUM OF $721.77 ., ADMITTED DUE IN ANSWER TO INTERROGATORIES FILED. NOTICE UNDER RULE 236. 18-AUG-00 10:58:53 ORDER ENTERED/236 NOTICE GIVEN ORDERED THAT THE PLAINTIFF'S MOTION TO COMPEL DISCOVERY IS GRANTED. SEE ORDER FOR ADDITIONAL DETAILS. MCINERNEY, J 8-18-00 06-OCT-00 11:13:56 ORDER ENTERED/236 NOTICE GIVEN ORDERED THAT PLAINTIFFS MOTION TO COMPEL A DEPOSITION IS GRANTED. DEFENDANT PAY 300.00 FOR FILING. SEE ORDER FOR ADDITIONAL DETAILS. MCINERNEY J. 10 06 00 20-NOV-00 08:58:25 ORDER ENTERED/236 NOTICE GIVEN ORDERED THAT PLAINITFFS MOTION FOR CONTEMPT RULE RETURNABLE 12 OS 00 IN COURTROOM 285. SEE ORDER FOR ADDITIONAL DETAILS. MCINERNEY J. 11 17 00 08-DEC-00 09:47:57 PARTIAL SATISFACTION FILED ORDER TO SATISFY THE JUDGMENT FILED AGAINST GARNISHEE MADISON BANK 08-DEC-00 10:48:03 ORDER ENTERED/236 NOTICE GIVEN ORDERED THAT DEFENDANT, DR. JOHN PAUL REHEIS, IS HELD IN CONTEMPT OF COURT. THE DEFENDANT, DR. JOHN PAUL REHEIS, SHALL PAY THE PLAINTIFF'S COUNSEL THE SUM OF REPORT ZDRDOCT First Judicial District USER ID: COS CIVIL DOCKET REPORT CASE ID 990203552 Filing Date / Time Docket Entry . . PAGE 3 RUN DATE 08/17/01 RUN TIME 01:35 PM $500.00 IN COUNSEL FEES FOR PREPARATION AND FILING OF THIS MOTION AND APPEARANCE IN COURT. SEE ORDER FOR ADDITIONAL DETA'I LS. WOLF, J 12/8/00 * * * End of Docket * * * Judgment certified in the amount of $17,796.93 CERTIFIEDFROMTHERECORDON ~UG ~ ~ 2001 JOSEPH H.EVER3 PROT (•IOTARYOFPHILADELPHIACOUNTY BY• (ViJJ Y ~ ~ - ~ ,~ -. ~ ~ ~.. ~ ~ z i J- r~ ~3 -~ -G ~ ~. n r`+. ~ G Y~I Mxr~.r#:.i1?Yd~'~i~{~~. v~l_)?twk Y. n s.`S}/~.~fU~+~".. .r._. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRiT OF EXECUTION Caption: ( )Confessed Judgment LITTLE DATA CENTERS, INC. 2315 E. York. Street (XX) Other ~,hiladelphia, PA 19125 File No. C'~~- ~r7s~ vs. DR. JOHN PAUL REHEIS ~ Lansdowne Tower Apts., Bldg. A '770 Providence Road Aldan, PA 19018 & HiGHMABIf, INC., GARNISHEE 1800 Center St, Camp Hill, PA 17089 TO THE PROTHONOTARY OF THE SAID COURT: Amount Due $17,796.93 Interest $2580.55 Atty's Comm Costs The undersigned hereby ce+'~#ies that the below does not arise out of a retail installment sale, contract, or account based on a confession ofjt~dgment, but if it"does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act"6 of 1974 as amended. Issue writ of execution in the above" matter to the Sheriff of for debt, interest and costs, upon the following described property of the defendant(s) County, PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) AnY and all monies due and payable to Dr. John Paul Reheis including but not limited to all monies due or payable from Blue Cross, Blue Shield, Medicare and/or Medicard. (it is believed Dr. Rehe and all other property of the defendant(s) in the possession, custody or control of the said 199935 (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendanht(s) desc~r±ibed in the attached exhibit. ~~ ` Date l J L~ ~ -1 ~ ~ ~ Signature: CA/ V Print Name: Paul N. Sandler, Esquire Address Philadelphia, PA 19102 Attorney for: Plaintiff Telephone: (215) 568-9300 Supreme Court ID No.: 15711 (over) Notes: If real property, supply six copies of description including improvements and an original and copy of affidavit of ownership (PaR.C.P. No. 3129). If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. __\ ~l V ~ ~4 ~~ ~ c /Q~v, a /~J~ c $ n ~~ o ~ ~ a n ~ ~~ e~. ~ c-~ =; © ~ ~'' ~' i r r~~ _~ T. - ~. ~ ' z ~ ;,, T -~~ . ~ :,~ ~~ , ~, f " ~ > _ - _~ -~ t", { SHERIFF'S RETURN - GARNISHEE CASE NO: 2001-05056 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND TILE DATA CENTER INC VS REHEIS JOHN PAUL DR And now SHANNON SUNDAY Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, at 0014:10 Hours, on the 1st day of November 2001, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , REHEIS JOHN PAUL DR in the hands, possession, or control of the within named Garnishee HIGHMARK, INC 1800 CENTER ST CAMP HILL, PA 17011 Cumberland County, Pennsylvania, by handing to SALLY MCCOY (PARALEGAL) , personally 3 true and attested copies of the within EXEMPLIFIED RECORD and made the contents thereof known to Her Sheriff's Costs: So answers: Docketing Service .00 .00 ~s~. ~~/ Affidavit .00 ~~ ~. h Surcharge .00 R. Thomas Kline -mac .00 Sheriff of Cumber land County .00 00/00/0000 '' ~~ ~ ~ By . [ ~„ cu~da,~., Deputy Sherif Sworn and subscribed to before me this _~ day of ,u," alru) A.D. ~s. ~.ri. ~dQ1.J R.Q~~!' ProthFSr[btary WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 01-5056 CIVIL t~ TES COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF nand COUNTY: To satisfy the debt, interest and costs due Little Data Centers, Inc. PLAINTIFF(S) from Dr. John Paul Reheis, Lansdowne Tower Apts., Bldg. A, 770 Providence Road, Aldan, PA 19018 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to (2) You are also directed to attach the property of the detendant(s) not levied upon in the possession of Any and all monies due and payable to Dr. John Paul Reheis including but not limited + x11 monies due.-pr navahla frrxn Blr, B1 , Shield Medicare and/or Medican9. (It ~~ bP1; ved Dr Reheis' provider number is 199935) Highmark Inc. Garnishee 1800 Center St. , Camp HI11, PA 17089 GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are 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 oithedefendant(s)notlevieduponansubjecttoattachmentisfoundinthepossessionofanyoneother than a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $17,796.93 Interest Atty's Comm Atty Paid Plaintiff F Other Costs 5.50 Due Garnishee Date: October 23, 2001 REQUESTING PARTY: Name Paul N. Sandler, Esq. Address: 1429 Walnut Street, 16th Floor Curtis R. Long Prothonotar~yjCi~vil Division Deputy Philadelphia, PA 19102 Attorney for: 1?laintifP Telephone:_215-568-9300 Supreme Court ID No. 15711 L.L. $.50 Due Prothy 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: Docketing 18.00 Poundage 1.57 Advertising ; Law Library . 50 Prothonotary 1.90 Mileage 9.7 5 Misc. Surcharge 20.00 Levy 20.00 Post Pone Sale Advance Costs: 150.00 Sheriffls Costs: 8., Refunded Co Atty on 7 / 15 / 0 2 Garnishee 9.00 ~$0~- Sworn and Subscribed to before me this /L'F'dayof 2002 A.D. pro onotary v ~SoAnswers; ! `~ R. T~hoc'm~a}sIK, line, Sheriff ,.., ~~~ /` r, ~i.l 'c ~ O u~ 13 +, c . r„~d Al~,.,,~ zr1l~+ „ 33ii:~~ =-4 ~_g+L _. I "_^; ,~-~,, ~ ~~ ~ 3'] SI7 ~u,~ lad's PR~n~~~£~ix~Nh .'?~ [3aRt~3'S~vtGffi+~F§'~FFAe°JF}4'4M1 V3~Y~y£FW~°!`W~._