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HomeMy WebLinkAbout01-06169MARLENE M. PALMER, Plaintiff V. SYNERTECH HEALTH SYSTEM SOLUTIONS, INC. a/k/a SYNERTECH HEALTH SYTEMS, LLC, and HARTFORD LIFE AND ACCIDENT INSURANCE COMPANY a/k/a HARTFORD LIFE INSURANCE COMPANY, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA 2001- 61 Oq CIVIL TERM CIVIL ACTION - LAW PRAECIPE FOR ISSUANCE OF A WRIT OF SUMMONS TO CURTIS R. LONG, PROTHONOTARY: Please issue a Writ of Summons against the defendants, Synertech Health System Solutions, Inc. a/k/a Synertech Health Systems, LLC, and Hartford Life and Accident Insurance Company a/k/a Hartford Life Insurance Company, and enter my appearance on behalf of the plaintiff, Marlene M. Palmer. Please direct the Sheriff to serve the defendants as follows: Synertech Health System Solutions, Inc 2400 Theo Drive Harrisburg, PA 17110 Home Address: Hartford Life and Accident Insurance Co. 200 Hopmeadow Street Hartford, CT 06089 Mailing Address: P. O. Box 2999 Hartford, CT 06104-2999 By: Date: October 26, 2001 Synertech Health Systems, LLC (CT Corporation System) Philadelphia, PA Home Address: Hartford Life Insurance Co. 200 Hopmeadow Street Hartford, CT 06089 Mailing Address: P. O. Box 2999 Hartford, CT. 06104-2999 To: . Synertech Health System Solutions, Inc. a/k/a Synertech Health Systems, LLC, and Hartford Life and Accident Insurance Company a/k/a Hartford Life Insurance Company You are hereby notified that Marlene M. Palmer, plaintiff, has commenced an action against you which you are required to defend or a default judgment may be entered against you. ^ i M1u, PRO NO By: OA \ 7 DEPUTY DateAk2001 60 West Pomfret Street, Carlisle, PA 17013 (717) 249-2353 - Supreme Court I.D. No: 70216 -? a CNI cf ,. ? a Qt ? y?- w r.> ?4 SHERIFF'S RETURN - U.S. CERTIFIED MAIL t _ f CASE NO: 2001-06169 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PALMER MARLENE M VS. SYNERTECH HEALTH SYSTEM SOLUTI R. Thomas Kline Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT HARTFORD LIFE AND ACCIDENT , INSURANCE COMPANY by United States Certified Mail postage prepaid, on the 29th day of October 2001 at 0000:00 HOURS, at 200 HOPMEADOW STREET PO BOX 2999 HARTFORD, CT 06104-2999 a true and attested copy of the attached WRIT OF SUMMONS with receipt card was signed by BRENDAN STONE 10/31/2001 . Additional Comments: Sheriff's Costs: Docketing 6.00 Postage 3.95 Affidavit .00 Surcharge 10.00 .00 19'. 95 Paid by IRWIN MCKNIGHT HUGHES Sworn and subscribed to before me this 13 9' day i o2?p A . D . ??2c C?c C?p T ` % 42 'Pfothonotary Together The returned on So answer-s. Thomas Kline Sheriff of Cumberland County on 12/06/2001 SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE NO: 2001-06169 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PALMER MARLENE M VS. SYNERTECH HEALTH SYSTEM SOLUTI R. Thomas Kline , Sheriff County, Pennvylvania, wh< within named DEFENDANT COMPANY prepaid, on the 29th day 200 HOPMEADOW STREET HARTFORD, CT 06104-2999 and attested copy of the with of Cumberland being duly sworn according to law served the ,HARTFORD LIFE INSURANCE by United States Certified Mail postage of October 2001 at 0000:00 HOURS, at PO BOX 2999 a true attached WRIT OF SUMMONS Together receipt card was signed by BRENDAN STONE 10/31/2001 . Additional Comments: on Sheriff's Costs: Docketing 6.00 Postage 3.95 Affidavit .00 Surcharge 10.00 .00 19.95 Paid by IRWIN MCKNIGHT HUGHES Sworn and subscribed to before me this j3Lt? day ?"A.D. rothonotary The returned So an _ s: f2. Thomas Kline Sheriff of Cumberland County on 12/06/2001 r SHERIFF'S RETURN - OUT OF COUNTY r CASE NO: 2001-06169 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PALMER MARLENE M VS SYNERTECH HEALTH SYSTEM SOLUTI 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: SYNERTECH HEALTH SYSTEM SOLUTIONS I but wav unable to locate Them deputized the sheriff of DAUPHIN serve the within WRIT OF SUMMONS County, Pennsylvania, to On December 6th , 2001 , this office was in receipt of the attached return from DAUPHIN Sheriffs Costs: Docketing Out of County Surcharge Dep Dauphin Cc 18.00 9.00 10.00 ? R. 29.25 .00 66.25 12/06/2001 IRWIN MCKNIGHT HUGHES Sworn and subscribed to before me this __Z-4 r? day of ,{,Quc,,,? ,2bp / A. D. Prothonotar in his bailiwick. He therefore ff of Cumberland County :- SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2001-06169 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PALMER MARLENE M VS SYNERTECH HEALTH SYSTEM SOLUTI 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: SYNERTECH HEALTH SYSTEMS LLC but was unable to locate Them in his bailiwick. He therefore deputized the sheriff of PHILADELPHIA serve the within WRIT OF SUMMONS County, Pennsylvania, to On December 6th , 2001 , this office was in receipt.of the attached return from PHILADELPH. Sheriff's Costs Docketing 6.00 Out of County 9.00 Surcharge 10.00 Dep Philadelphia 116.00 .00 141.00 12/06/2001 IRWIN MCKNIGHT HUGHES Sworn and subscribed to before me this 13 ?-`' day of ljlez ? J4/0 / A.D ?? Prothonotary ?? 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 PALMER MARLENE M vs County of Dauphin SYNERTECH HEALTH SYSTEMS SOLUTIONS INC Sheriff's Return No. 3123-T - - -2001 OTHER COUNTY NO. 01-6169 AND NOW:November 9, 2001 at 9:OOAM served the within SUMMONS upon SYNERTECH HEALTH SYSTEMS SOLUTIONS INC by personally handing to ED LOSCHER, VP OF CONTRACTS 1 true attested copy(ies) of the original SUMMONS and making known to him/her the contents thereof at 2400 THEA DRIVE HARRISBURG, PA 17110-0000 Sworn and subscribed to So Answers, /n efore me this 9TH day on?o V EMBER, 1 ti Sheriff plezjR phixr r -7- PROTHONOTARY By Pa. ty Sneriff office of .e ?$hrrfff Sheriff's Costs: $29.25 PD 10/30/2001 RCPT NO 156023 TORO In The Court of Common Pleas of Cumberland County, Pennsylvania Marlene M. Palmer vs. Synertech Health System Solutions, Inc. SERVE: same No. 01 6169 civil Now, October 29 20 01 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to a and made known to So answers, Sheriff of Sworn and subscribed before me this day of 20 copy of the original COSTS SERVICE _ MILEAGE _ AFFIDAVIT 20 , at o'clock M. served the the contents thereof. County, PA In The Court Of Common Pleas of Cumberland County, Pennsylvania Marlene M. Palmer vs. Synertech Health System Solutions, Inc. SERVE: No. 01 6169 civil Synertech Health Systems LLC Now, October 29 20 01 > I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Philadelphia County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to a and made known to copy of the original So answers, the contents thereof. Sheriff of Sworn and subscribed before me this _ day of 20 COSTS SERVICE _ MILEAGE _ AFFIDAVIT 20 , at . o'clock M. served the County, PA SHERIFF'S RETURN • NOT FOUND MA0eaKJc M. 019(,M6Z VERSUS Sp?N ?2_rO_? e y 17'k- H Syrre M SOC c/ rs o A-1J /N NOT FOUND as to S1 oyl-z 1-t e h? COMMON PLEAS NO. COUNTY COURT TERM/ NO. ?l 6 f the above named f _? defendant, within the County of Philadelphia, State of Pennsylvania, as of / / - /5' 1 C)D _ 12-225 (Rev. 12187) So answers, HN/D. GREEN, SHE By: Lit . Deputy Sheri ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Hertford Life Insurance Co. Hogleadow Street Box 2999 Hertford, CT 06104-2999 A. Received by (Please Print Clepfly) I B. Date of Delivery 0. Signatara6ndan - _.QuuI X ?f? Stone' ? Agent Y!^ - °`?„ ? Addre D. Is deliv _fwm tem.l? ? Yes If YES, enter delivery address below: ? No 3. Service Type }Certified Mail ? Express Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? yes 2. Article Number (Copy from service label) 7000 0001 8790 1045 01-6169 civil. PS Form 3$11 July 1999 Domestic Return Receipt 102595-99-M-17ee ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Hartford Life & Accident Insurance Company 200 Hopneadow Street PO Box 2999 Hartford, CT 06104-2999 2. Article Nd1°iiber (Copy from service label) PS Form 3611, July 1999 Domestic Return Receipt A. Receiveclk (Please Print Cl RO, ?Dattee of Dell CSf®??y-.. e?i C. Signature "• ? Agent ? Addre D. Is delivery address different from item 11 ? Yes If YES, enter delivery address below: ? No 3. Service Type 'M Certified Mail ? Express Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes ii MARLENE M. PALMER, Plaintiff V. SYNERTECH HEALTH SYSTEM SOLUTIONS, INC. a/k/a SYNERTECH HEALTH SYTEMS, LLC, and HARTFORD LIFE AND ACCIDENT INSURANCE COMPANY a/k/a HARTFORD LIFE INSURANCE COMPANY, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA 2001- CIVIL TERM CIVIL ACTION - LAW PRAECIPE FOR ISSUANCE OF A WRIT OF SUMMONS TO CURTIS R. LONG, PROTHONOTARY: Please issue a Writ of Summons against the defendants, Synertech Health System Solutions, Inc. a/k/a Synertech Health Systems, LLC, and Hartford Life and Accident Insurance Company a/k/a Hartford Life Insurance Company, and enter my appearance on behalf of the plaintiff, Marlene M. Palmer. Please direct the Sheriff to serve the defendants as follows: Synertech Health System Solutions, Inc 2400 Thea Drive Harrisburg, PA 17110 Synertech Health Systems, LLC (CT Corporation System) Philadelphia, PA Home Address: Hartford Life and Accident Insurance Co. 200 Hopmeadow Street Hartford, CT 06089 Mailing Address: P. O. Box 2999 Hartford, CT 06104-2999 By: Date: October 26, 2001 Home Address: Hartford Life Insurance Co. 200 Hopmeadow Street Hartford, CT 06089 Mailing Address: P. O. Box 2999 Hartford, CT. 06104-2999 To: . Synertech Health System Solutions, Inc. a/k/a Synertech Health Systems, LLC, and Hartford Life and Accident Insurance Company a/k/a Hartford Life Insurance Company You are hereby notified that Marlene M. Palmer, plaintiff, has commenced an action against you which you are required to defend or a default judgment may be tered against you. A kr,-&o ki• PRO N RY By: ? DEPUTY Date: ?C1iU a , 2001 60 West Pomfret Street, Carlisle, PA 17013 (717) 249-2353 - Supreme Court I.D. No: 70216 MARLENE M. PALMER, Plaintiff V. SYNERTECH HEALTH SYSTEM SOLUTIONS, INC. a/k/a SYNERTECH HEALTH SYSTEMS, LLC and HARTFORD LIFE AND ACCIDENT INSURANCE COMPANY a/k/a HARTFORD LIFE INSURANCE COMPANY, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2001-6169 CIVIL TERM CIVIL ACTION - LAW PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter my appearance as counsel of record on behalf of Hartford Life and Accident Insurance Company in the above-captioned matter. Dated: November 7, 2001 Pepper Hamilton LLP 200 One Keystone Plaza North Front and Market Streets P. O. Box 1181 Harrisburg, PA 17108-1181 (717) 255-1155 Attorney for Hartford Life and Accident Insurance Company Y ? CERTIFICATE OF SERVICE I hereby certify that on this 7th day of November, 2001, a true and correct copy of the foregoing document was served by First Class Mail delivery upon: Mark D. Schwartz, Esquire 60 West Pomfret Street Carlisle, PA 17103 Synertech Health System Solutions, Inc. 2400 Thea Drive Harrisburg, PA 17110 a .? V ?= ? h? JC7 ??. -r-, != + ? _ . +. ?_ /, t ,. _. _,?. i _.. ;? t _ _1 ? (,. ?? In The Court of Common Pleas of Cumberland County, Pennsylvania Fite No. PALMER MARLENE M VS SYNERTECH HEALTH SYSTEM SOLUTI 2001-06169 STATEMENT OF INTENTION TO PROCEED To the Court: MARLENE M. PALMER Date: October 25. 2004 intends to proceed with the above captioned matter. x a - Attorney for e . Palmer Plaintiff MARCUS A McKNIGHT III ESQ IRWIN & McKNIGHT 60 WEST POMFRET STREET CARLISLE PA 17013 1 U ..Ci ?.? r cc MARLENE M. PALMER, Plaintiff, v. SYNERTECH HEALTH SYSTEM SOLUTIONS, INC., a.Wa SYNERTECH HEALTH SYSTEMS, LLC, and HARTFORD LIFE AND ACCIDENT INSURANCE COMPANY a/k/a HARTFORD LIFE INSURANCE COMPANY, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA NO. 2001-6169 CIVIL TERM CIVIL ACTION - LAW STATEMENT OF INTENTION TO PROCEED TO THE COURT: Plaintiff intends to proceed with the above-captioned matter. By: Respectfully submitted, IRWIN &JVIcKNIGHT Marc s A. c ght, III, Esquire Supr e COrt I. . No: 25476 60 West Po et Street Carlisle, PA 17013 (717) 249-2353 Date: November 1, 2007 r?,?-?, t?'7 ?? Y..'- [??... -^""1 .? ? ; ?? ~? ? .,.` ? ? . ? (`J i ~It,ED-~~= F~C~ MARLENE M. PALMER, PLAINTIFF ~~ ~~~~ ~~~~~~~~~`~~`. vs ~~ ~ ~ ~C~ ~ ~ ~~' ~'aSe IGo. 2001-6169 CIVIL TERM SYNERTECH HEALTH SYSTEM SOLUTION$~.,sl ~~~ ~~~~ ~-,r a/k/a SYNERTECH HEALTH SYSTEMS, , i~~)j~.Itt''I~C HARTFORD LIFE AND ACCIDENT INSURANC~ ~~~a NFENDANTS Statement of Intention to Proceed To the Court: MARLENE M. PALMER, PLAINTIFF intends to procee 'th the a ove captioned matter. PrintNameMARCUS A. McKNIGHT, III Sign Name Date:OCTOBER 22, 2010 Attorney for MARLENE M. PALMER. PLAINTIFF Explanatory Comment The Supreme Court of Pennsylvania has promulgated new Rule of Civil Procedure 230.2 governing the termination of inactive cases and amended Rule of Judicial Administration .1901. 'Pwo aspects of the recommendation merit comment. I. Rule of civil Procedure New Rule of Civil Procedure 230.2 has been promulgated to govern the temunation of inactive cases within the scope of the Pennsylvania Rules of Civil Procedure. The termination of these cases for inactivity was previously governed by Rule of Judicial Administration 1901 and local rules promulgated pursuant to it. New Rule 230.2 is tailored to the needs of civil actions. It provides a complete procedure and a uniform statewide practice, preempting local rules. This rule was promulgated in response to the decision of the Supreme Court in Shop v. Eagle, 551 Pa. 360,710 A.2d 1104 (1998) in which the court held that "prejudice to the defendant as a result of delay in prosecution is required before a case maybe dismissed pursuant to local rules implementing Rule of Judicial Administration 1901." Rule of Judicial Administration 1901(b) has been amended to accommodate the new rule of civil procedure. The general policy of the prompt disposition of matters set forth in subdivision (a) of that rule continues to be applicable. II Inactive Cases The purpose of Rule 230.2 is to eliminate inactive cases from the judicial system. The process is initiated by the court. After giving notice of intent to terminate an action for inactivity, the course of the procedure is with the parties. If the parties do not wish to pursue the case, they will take no action and "the Prothonotary shall enter an order as of course terminating the matter with prejudice for failure to prosecute." If a party wishes to pursue the matter, he ar she will file a notice of intention to proceed and the action shall continue. a. Where the action has been terminated If the action is terminated when a party believes that it should not have been terminated, that party may proceed under Ru1e230(d) for relief from the order of termination. An example of such an occun•ence might be the temtination of a viable action when the aggrieved party did not receive the notice of intent to temvnate and thus did not timely file the notice of intention to proceed. The timing of the filing of the petition to reinstate the action is important. If the petition is filed within thirty days of the entry of the order of termination on the docket, subdivision (dx2) provides that the court must grant the petition and reinstate the action. If the petition is filed later than the thirty-day period, subdivision (d)(3) requires that the plaintiff must make a showing to the court that the petition was promptly filed and that there is a reasonable explanation or legitimate excuse both for the failure to file the notice of intention to proceed prior to the entry of the order of termination on the docket and for the failure to file the petition within the thirty-day period under subdivision (d)(2). B. Where the action has not been terminated An action which has not been terminated but which continues upon the filing of a notice of intention to proceed may have been the subject of inordinate delay. In such an instance, the aggrieved party may pursue the remedy of a common law non pros which exits independently of termination under Rule 230.2.